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power generation group Utility MACT Regulation Briefing November 10, 2011 Rich Killion B&W Power Generation Group President and Chief Operating Officer a Babcock & Wilcox company

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Page 1: Utility MACT Regulation Briefing - whitehouse.gov · Utility MACT Regulation Briefing . November 10, 2011 . Rich Killion . B&W Power Generation Group ... Scrubber (50. 2) Equipment

bull ~

power generation group

Utility MACT Regulation Briefing November 10 2011

Rich Killion BampW Power Generation Group

President and Chief Operating Officer a Babcock amp Wilcox company

babcock amp wi l cox power gener-atron group

Bwe NYSE babcockampwiI COgtlt middot I

BampW is Technically Financially and Strategically Positioned to Support its Customers

through our Nations Energy Transformation

Company Profile A leader in clean energyHeadquarters Charlotte NC technology and services

Incorporation Delaware primarily for the fossil nuclear and renewableCEO Brandon C Bethards power markets as well as

13000 plus 10000 premier advanceEmployees joint venture employees technology and mission critical defense contractor Ticker Symbol NYSE BWC

babcock amp wi l cox power generation group

The Babcock amp Wilcox Company

BampW Technical Services

Group Inc

bull Nuclear material handling storage and security

bull Nuclear laboratories

bull Weapons complex bull Decontamination and

decommissioning

bull Strategic Petroleum Reserve

BampW Nuclear Operations

Group Inc

bull Virginia-Class submarine program

bull Ford-Class carrier program

bull Refueling bull Fuel processing and

fabrication

BampW Power Generation

Group Inc

bull Environmental systems (FGD SCR Hg Particulate Carbon)

bull Coal-fired power generation

bull Service operation and maintenance

bull Construction and EPC

bull Renewables (Biomass solar waste-to-energy)

BampW Nuclear

Energy Inc

bull Field services

bull Plant modifications

bull Component manufacturing and installation

bull Fuel design enrichment and fabrication

bull BampW mPowertrade

babcock amp wilcox power generation group

BampW Power Generation Group (BampW PGG)

Business Footprint

3 ~ =

Lf ~ T Do _ ~_ ~M_

bull $14 B Revenue in 2010 _$01011

bull $15 B Backlog as of 6130111

bull Headquartered in Barberton OH

bull Approximately 8270 employees (including JVs) as of August 2011

Location Employees USA 4464 Canada 573 Mexico 199 Europe 434 Asia 2374 Australia 226

Totsl 8270

Product Line Portfolio

Utility and industrial boilers Firing fossil fuels

Environmental products Control regulated emissions

Boiler cleaning and auxiliaries

Field services Upgrade replace equipment

Construction Install all BampW supplied scope

OampM services Operate maintain power plants

babcock amp w il cox power generation group

BampW PGG Global Operations

Houston TX

+ + Legend

bull BampW PGG Operations

+ Diamond Power Operations

D BampW Licensee BampW Sales Rep

Diamond Sales Rep

o

Extensive experience in manufacturing and sourcing worldwide

babcock amp w il cox power generat i on group

Developing and Delivering Technology Solutions

Environmental

bull NOx reduction

bull SO control bull Particulate control

bull Acid gas reduction

bull Mercury removal bull Ash management

Total Environmental Solutions

Ultra Supercritical

bull Highest efficiency coal-fired design

bull 133 Supercritical Boilers

bull Largest supercritical boilers in world (9 x 1300 MW)

bull Base-loaded and Full-cycling designs

bull Preferred technology for India and China

Ultra-Supercritical Boiler

I I 1

Renewables

bull Biomass

bull Waste-ta-Energy bull Concentrated Solar

Power (CSP)

bull Operate and Maintain

Solid Waste Authority West Palm Beach FL

CO2 Capture

bull Oxy-Coal Combustion

bull Regenerable Solvent Absorption Technology (RSA PM)

bull Extensive commitment to RampD

bull Wide variety of programs

middot Oxy-coal combustion project FutureGen 20

~ ~ --~--~--

- - ----~ Recently Expanded RampD Facility

00

babcock amp w i l cox power generation group

Bamp W is Providing Power for the United States

i 0

00 0

00

00 86J

0 0 0

000 ffil

0 S 0

0

~~~ amp8 ctl3

00 00

0

-

o

obull BampW Power Plants

Fossil Energy

it lt500 MW

500 - 1000 MW

gt 1000 MW

Nuclear

Biomass

BampW Owned and Government Operations

Laboratory and cg RampD Operations

88 Nuclear Manufacturing Operations

Manufacturing and Operations

babcock amp w il cox power generation group

Bamp Wis a Major Supplier of Utility Power Plant Equipment

bull Wisconsin Public Service - Weston 4 bull AEP - Mitchell 1 and 2 bull BampW 530 MW Supercritical Boiler bull 2 x 800 MW Wet Scrubber Systems bull seR Dry Scrubber and Baghouse

babcock amp w il cox power generation group

StackCSAPR andUMACT Fabric Filter

Baghouse (Ash) DryFGD ScrubberCompliance

(502 )

StackEquipment

Scrubber (502 )

Electrostatic Precipitator (Ash)

Supercritical Boiler Coal

Pulverizer

babcock amp N il cox pONer generation group

A Complete Environmental Technology Portfolio

I I ~

-Total Solutions Provider

babcock amp vV il cox pONer generation group

US Bamp W Installed Capacity and Market Share

Wet Dry Fabric Wet FGD FGD Filter ESP

BampW Installed 19966 10023 8717 46607 2710Capacity (MW)

Market Share 28 49 21 32 35

babcock amp wi l cox power generation group

Environmental Equipment Forecast for US Power Companies

Industry Sources CapacIty In GIgawatts (GW) L H h ow 19 Scrubbers (FGO) 25 45 SCR (Oe-NOx) 15 25 Oirect Sorbent Injection (OSI) of PAC 100 200Trona etc Fabric Filter (FF) 75 175

Total in GW 215 445

B II f D 1 $ Industry Sources I Ions 0 0 ars L H how 19 Total in $ $12 $25

EPC value =$24 - 48 B BampW core scope (furnish and install) is $12 - 24 B

babcock amp w i lcox power generation group

Policy Goals for Environmental Compliance

bull Achieve environmental compliance bull Increase number of US jobs bull Minimize economic impact to rate payers bull Maintain reliability of electricity supply

Longer compliance schedule maximizes US jobs and still supports environmental stewardship

babcock amp vvilcox povver generation group

Timeline for Project Execution

Permitting RFQ and Contracting Phase

Takes one to two years before Engineer-Procure-Construct (EPC) project begins

Project Execution Phase ~E~~co ~ FabrtC~iItr (3~onthS)~~P amp Testing PC Spe~~=~~ F e~~0-35 M~~~

EPC Scope Dry FGD (30-36 Months) Startup amp Testing

amp Testing

EPCScop WI G ont ~ n amp Testing e et F D (40-42M hS) ~it ~~

babcock amp wilcox power generation group

Short Compliance Deadlines Will Lead to Significant Challenges for Engineering PM and US Suppliers

45

tilt t- 40-- a ICI CIIuCII-_ 35-5 oS O)~ ~~ 30 t t -- ICI 25II) -5 t () CII c E 20 tamp ~g 15 O~ 11) 10t U ~ ~ ~()-- 5~Q

3 year Compliance Period In MACT sect112

Estimated High Capacity (Indicative Only)

Estimated Low

Field Construction Phase 2014 -2015

20182012 2013 2014 2015 2016 2017

babcock amp w il cox power generation group

Short Compliance Deadlines Will Lead to Significant Challenges for Engineering PM and US Suppliers

45

tilrr5 40- - CI3l u gt 355 Q

~~ 301IJtI r r - CI II 25 r3Q)Os 20-CQ)ro ~g 15 O~ 111shyr u 10 9 ~0 5~Q

3 year Compliance Period in MACT sect112

Estimated High Capacity (Indicative Only)

Estimated Low

1n1lACT Extension

Field Construction Phase

2012 2013 2014 2015 2016 2017 2018

babcock amp wilcox power generation group

Economic Impact of Major AQCS Project

Total Customer Project Cost $14B

Project Duration 4+ years

(Representative Sample of Large Project)

bull BampW Scope of Supply middot3 X 800 MW Wet FGD (core scope erected) bull 2 X 800 MW SCR retrofit (EPC)

bull BampW Supply = $ 400 M bull Engineering - 270 engineering

and material supply personnel bull Procurement

bull $ 81 M US procurement bull 10 states withgt $1 M in manufacturing

Iservices supplied bull Supply chain spanned over 20 states bull Equipment Supply

bull Construction bull Core scope Wet FGD = 500000 man hours bull EPC SCR = 1000000 manhours

babcock amp wilcox power generation group

Economic Impact of Major AQCS Project (Representative Sample of Large Project)

bull Equipment supply bull Absorber trays bull Agitators bull Alloy headers bull Bolts bull Electrical wiring bull Piping engineering bull Gaskets bull Monitors bull Pressure transmitters bull Pumps bull Steel plate bull Structural steel bull Ball and plug valves10 states withgt $1M in manufacturingservices supplied

States with lt $1M in manufacturingservices supplied

babcock amp wilcox power generation group

Construction Installation Services to Meet Regulatory Demand

babcock amp wilcox power generation group

BampW is a Major US Employer of Boilermaker Union Craft

bull One of top three boilermaker employers every year for last ten years

bull Top tier power plant constructor

Boilermaker union craft is the single largest union craft employed on power and emissions control projects nationwide

babcock amp wilcox power generation group

Total Boilermaker Man-Hour Forecast 3 year compliance schedule requires 16 more man-hours than highest recent peak

Man-hours (Millions)

~~~~~~~~~~~~~~~~~~~~ ~~~~~~~~~~~~~~~~~~~~

50 45 40 35 30 25 20 15 10

5 o

babcock amp wilcox power generation group

Construction Challenges in Meeting Regulatory Demand

bull Demands on craft labor will be significant - particularly on a regional basis

bull Time for implementation is too short

bull Project execution risk increases - safety quality cost

bull Although best practice mitigation strategies will be deployed results are questionable in meeting cost and schedule requirements given current UMACT compressed timeframe

babcock amp w il cox p o wer generation group

BampW Comments to EPA on Utility MACT

J~ ltgtU ~ ~ ~ ~

~~-_ ~ - - B~W

t Liipound7-- shyI~ _~ NyenltI_G lt1W~tOC-

- -_ - ~ ~

bull BampW reviewed the proposed Utility MACT rule and provided detailed comments

bull Proposed limits on new and reconstructed units too stringent

bull Some proposed limits on new and reconstructed units lower than capabilities of reference test methods

babcock amp w il cox power generation g oup

UMACT for New Units (NSPS)

45 of all US electricity is generated from coal from only 30 of installed US generation capacity bull Competitively priced long term bull 2417 availability (base load) bull Clean source of generation - virtually all plants will be clean

by 2015-2018 because of Utility MACTCSAPR bull Large jobs generator (mining railroad Boilermaker union construction

engineering manufacturing plant operations etc)

No new coal powered plants will be built in US under proposed rule emission limits bull BampW knows of no technology or combination of technologies commercially

available worldwide to achieve Total PM Hg and HCI emission limits bull Proposed limits are approximately an order of magnitude lower than what can

reliably be achieved by current technology bull Proposal is based on very low measured emissions at single units which are

believed to be the result of site-specific interactions of fuels test equipment and operations not regularly reproducible For example proposed limits are near the limits of detection of the measurement methods

babcock amp wi l cox power generation group

Challenges to Achieve Environmental Compliance reg Three year UMACT compliance period cannot be fulfilled

due to large number and duration of major projects

reg Attempts to meet UMACT three year compliance

reg Will drive extensive US manufacturing engineering and project management jobs offshore

reg Will increase risk substantially for project cost schedule completion and safety

reg There is insufficient experienced field craft to construct the required projects within three year period

reg UMACT emissions requirements for new installations cannot be met with current technology - no new coal based power plant will be built in the US under the proposed emission limits

reg As a major environmental system supplier BampW urges consideration for a six year compliance period

Page 2: Utility MACT Regulation Briefing - whitehouse.gov · Utility MACT Regulation Briefing . November 10, 2011 . Rich Killion . B&W Power Generation Group ... Scrubber (50. 2) Equipment

babcock amp wi l cox power gener-atron group

Bwe NYSE babcockampwiI COgtlt middot I

BampW is Technically Financially and Strategically Positioned to Support its Customers

through our Nations Energy Transformation

Company Profile A leader in clean energyHeadquarters Charlotte NC technology and services

Incorporation Delaware primarily for the fossil nuclear and renewableCEO Brandon C Bethards power markets as well as

13000 plus 10000 premier advanceEmployees joint venture employees technology and mission critical defense contractor Ticker Symbol NYSE BWC

babcock amp wi l cox power generation group

The Babcock amp Wilcox Company

BampW Technical Services

Group Inc

bull Nuclear material handling storage and security

bull Nuclear laboratories

bull Weapons complex bull Decontamination and

decommissioning

bull Strategic Petroleum Reserve

BampW Nuclear Operations

Group Inc

bull Virginia-Class submarine program

bull Ford-Class carrier program

bull Refueling bull Fuel processing and

fabrication

BampW Power Generation

Group Inc

bull Environmental systems (FGD SCR Hg Particulate Carbon)

bull Coal-fired power generation

bull Service operation and maintenance

bull Construction and EPC

bull Renewables (Biomass solar waste-to-energy)

BampW Nuclear

Energy Inc

bull Field services

bull Plant modifications

bull Component manufacturing and installation

bull Fuel design enrichment and fabrication

bull BampW mPowertrade

babcock amp wilcox power generation group

BampW Power Generation Group (BampW PGG)

Business Footprint

3 ~ =

Lf ~ T Do _ ~_ ~M_

bull $14 B Revenue in 2010 _$01011

bull $15 B Backlog as of 6130111

bull Headquartered in Barberton OH

bull Approximately 8270 employees (including JVs) as of August 2011

Location Employees USA 4464 Canada 573 Mexico 199 Europe 434 Asia 2374 Australia 226

Totsl 8270

Product Line Portfolio

Utility and industrial boilers Firing fossil fuels

Environmental products Control regulated emissions

Boiler cleaning and auxiliaries

Field services Upgrade replace equipment

Construction Install all BampW supplied scope

OampM services Operate maintain power plants

babcock amp w il cox power generation group

BampW PGG Global Operations

Houston TX

+ + Legend

bull BampW PGG Operations

+ Diamond Power Operations

D BampW Licensee BampW Sales Rep

Diamond Sales Rep

o

Extensive experience in manufacturing and sourcing worldwide

babcock amp w il cox power generat i on group

Developing and Delivering Technology Solutions

Environmental

bull NOx reduction

bull SO control bull Particulate control

bull Acid gas reduction

bull Mercury removal bull Ash management

Total Environmental Solutions

Ultra Supercritical

bull Highest efficiency coal-fired design

bull 133 Supercritical Boilers

bull Largest supercritical boilers in world (9 x 1300 MW)

bull Base-loaded and Full-cycling designs

bull Preferred technology for India and China

Ultra-Supercritical Boiler

I I 1

Renewables

bull Biomass

bull Waste-ta-Energy bull Concentrated Solar

Power (CSP)

bull Operate and Maintain

Solid Waste Authority West Palm Beach FL

CO2 Capture

bull Oxy-Coal Combustion

bull Regenerable Solvent Absorption Technology (RSA PM)

bull Extensive commitment to RampD

bull Wide variety of programs

middot Oxy-coal combustion project FutureGen 20

~ ~ --~--~--

- - ----~ Recently Expanded RampD Facility

00

babcock amp w i l cox power generation group

Bamp W is Providing Power for the United States

i 0

00 0

00

00 86J

0 0 0

000 ffil

0 S 0

0

~~~ amp8 ctl3

00 00

0

-

o

obull BampW Power Plants

Fossil Energy

it lt500 MW

500 - 1000 MW

gt 1000 MW

Nuclear

Biomass

BampW Owned and Government Operations

Laboratory and cg RampD Operations

88 Nuclear Manufacturing Operations

Manufacturing and Operations

babcock amp w il cox power generation group

Bamp Wis a Major Supplier of Utility Power Plant Equipment

bull Wisconsin Public Service - Weston 4 bull AEP - Mitchell 1 and 2 bull BampW 530 MW Supercritical Boiler bull 2 x 800 MW Wet Scrubber Systems bull seR Dry Scrubber and Baghouse

babcock amp w il cox power generation group

StackCSAPR andUMACT Fabric Filter

Baghouse (Ash) DryFGD ScrubberCompliance

(502 )

StackEquipment

Scrubber (502 )

Electrostatic Precipitator (Ash)

Supercritical Boiler Coal

Pulverizer

babcock amp N il cox pONer generation group

A Complete Environmental Technology Portfolio

I I ~

-Total Solutions Provider

babcock amp vV il cox pONer generation group

US Bamp W Installed Capacity and Market Share

Wet Dry Fabric Wet FGD FGD Filter ESP

BampW Installed 19966 10023 8717 46607 2710Capacity (MW)

Market Share 28 49 21 32 35

babcock amp wi l cox power generation group

Environmental Equipment Forecast for US Power Companies

Industry Sources CapacIty In GIgawatts (GW) L H h ow 19 Scrubbers (FGO) 25 45 SCR (Oe-NOx) 15 25 Oirect Sorbent Injection (OSI) of PAC 100 200Trona etc Fabric Filter (FF) 75 175

Total in GW 215 445

B II f D 1 $ Industry Sources I Ions 0 0 ars L H how 19 Total in $ $12 $25

EPC value =$24 - 48 B BampW core scope (furnish and install) is $12 - 24 B

babcock amp w i lcox power generation group

Policy Goals for Environmental Compliance

bull Achieve environmental compliance bull Increase number of US jobs bull Minimize economic impact to rate payers bull Maintain reliability of electricity supply

Longer compliance schedule maximizes US jobs and still supports environmental stewardship

babcock amp vvilcox povver generation group

Timeline for Project Execution

Permitting RFQ and Contracting Phase

Takes one to two years before Engineer-Procure-Construct (EPC) project begins

Project Execution Phase ~E~~co ~ FabrtC~iItr (3~onthS)~~P amp Testing PC Spe~~=~~ F e~~0-35 M~~~

EPC Scope Dry FGD (30-36 Months) Startup amp Testing

amp Testing

EPCScop WI G ont ~ n amp Testing e et F D (40-42M hS) ~it ~~

babcock amp wilcox power generation group

Short Compliance Deadlines Will Lead to Significant Challenges for Engineering PM and US Suppliers

45

tilt t- 40-- a ICI CIIuCII-_ 35-5 oS O)~ ~~ 30 t t -- ICI 25II) -5 t () CII c E 20 tamp ~g 15 O~ 11) 10t U ~ ~ ~()-- 5~Q

3 year Compliance Period In MACT sect112

Estimated High Capacity (Indicative Only)

Estimated Low

Field Construction Phase 2014 -2015

20182012 2013 2014 2015 2016 2017

babcock amp w il cox power generation group

Short Compliance Deadlines Will Lead to Significant Challenges for Engineering PM and US Suppliers

45

tilrr5 40- - CI3l u gt 355 Q

~~ 301IJtI r r - CI II 25 r3Q)Os 20-CQ)ro ~g 15 O~ 111shyr u 10 9 ~0 5~Q

3 year Compliance Period in MACT sect112

Estimated High Capacity (Indicative Only)

Estimated Low

1n1lACT Extension

Field Construction Phase

2012 2013 2014 2015 2016 2017 2018

babcock amp wilcox power generation group

Economic Impact of Major AQCS Project

Total Customer Project Cost $14B

Project Duration 4+ years

(Representative Sample of Large Project)

bull BampW Scope of Supply middot3 X 800 MW Wet FGD (core scope erected) bull 2 X 800 MW SCR retrofit (EPC)

bull BampW Supply = $ 400 M bull Engineering - 270 engineering

and material supply personnel bull Procurement

bull $ 81 M US procurement bull 10 states withgt $1 M in manufacturing

Iservices supplied bull Supply chain spanned over 20 states bull Equipment Supply

bull Construction bull Core scope Wet FGD = 500000 man hours bull EPC SCR = 1000000 manhours

babcock amp wilcox power generation group

Economic Impact of Major AQCS Project (Representative Sample of Large Project)

bull Equipment supply bull Absorber trays bull Agitators bull Alloy headers bull Bolts bull Electrical wiring bull Piping engineering bull Gaskets bull Monitors bull Pressure transmitters bull Pumps bull Steel plate bull Structural steel bull Ball and plug valves10 states withgt $1M in manufacturingservices supplied

States with lt $1M in manufacturingservices supplied

babcock amp wilcox power generation group

Construction Installation Services to Meet Regulatory Demand

babcock amp wilcox power generation group

BampW is a Major US Employer of Boilermaker Union Craft

bull One of top three boilermaker employers every year for last ten years

bull Top tier power plant constructor

Boilermaker union craft is the single largest union craft employed on power and emissions control projects nationwide

babcock amp wilcox power generation group

Total Boilermaker Man-Hour Forecast 3 year compliance schedule requires 16 more man-hours than highest recent peak

Man-hours (Millions)

~~~~~~~~~~~~~~~~~~~~ ~~~~~~~~~~~~~~~~~~~~

50 45 40 35 30 25 20 15 10

5 o

babcock amp wilcox power generation group

Construction Challenges in Meeting Regulatory Demand

bull Demands on craft labor will be significant - particularly on a regional basis

bull Time for implementation is too short

bull Project execution risk increases - safety quality cost

bull Although best practice mitigation strategies will be deployed results are questionable in meeting cost and schedule requirements given current UMACT compressed timeframe

babcock amp w il cox p o wer generation group

BampW Comments to EPA on Utility MACT

J~ ltgtU ~ ~ ~ ~

~~-_ ~ - - B~W

t Liipound7-- shyI~ _~ NyenltI_G lt1W~tOC-

- -_ - ~ ~

bull BampW reviewed the proposed Utility MACT rule and provided detailed comments

bull Proposed limits on new and reconstructed units too stringent

bull Some proposed limits on new and reconstructed units lower than capabilities of reference test methods

babcock amp w il cox power generation g oup

UMACT for New Units (NSPS)

45 of all US electricity is generated from coal from only 30 of installed US generation capacity bull Competitively priced long term bull 2417 availability (base load) bull Clean source of generation - virtually all plants will be clean

by 2015-2018 because of Utility MACTCSAPR bull Large jobs generator (mining railroad Boilermaker union construction

engineering manufacturing plant operations etc)

No new coal powered plants will be built in US under proposed rule emission limits bull BampW knows of no technology or combination of technologies commercially

available worldwide to achieve Total PM Hg and HCI emission limits bull Proposed limits are approximately an order of magnitude lower than what can

reliably be achieved by current technology bull Proposal is based on very low measured emissions at single units which are

believed to be the result of site-specific interactions of fuels test equipment and operations not regularly reproducible For example proposed limits are near the limits of detection of the measurement methods

babcock amp wi l cox power generation group

Challenges to Achieve Environmental Compliance reg Three year UMACT compliance period cannot be fulfilled

due to large number and duration of major projects

reg Attempts to meet UMACT three year compliance

reg Will drive extensive US manufacturing engineering and project management jobs offshore

reg Will increase risk substantially for project cost schedule completion and safety

reg There is insufficient experienced field craft to construct the required projects within three year period

reg UMACT emissions requirements for new installations cannot be met with current technology - no new coal based power plant will be built in the US under the proposed emission limits

reg As a major environmental system supplier BampW urges consideration for a six year compliance period

Page 3: Utility MACT Regulation Briefing - whitehouse.gov · Utility MACT Regulation Briefing . November 10, 2011 . Rich Killion . B&W Power Generation Group ... Scrubber (50. 2) Equipment

babcock amp wi l cox power generation group

The Babcock amp Wilcox Company

BampW Technical Services

Group Inc

bull Nuclear material handling storage and security

bull Nuclear laboratories

bull Weapons complex bull Decontamination and

decommissioning

bull Strategic Petroleum Reserve

BampW Nuclear Operations

Group Inc

bull Virginia-Class submarine program

bull Ford-Class carrier program

bull Refueling bull Fuel processing and

fabrication

BampW Power Generation

Group Inc

bull Environmental systems (FGD SCR Hg Particulate Carbon)

bull Coal-fired power generation

bull Service operation and maintenance

bull Construction and EPC

bull Renewables (Biomass solar waste-to-energy)

BampW Nuclear

Energy Inc

bull Field services

bull Plant modifications

bull Component manufacturing and installation

bull Fuel design enrichment and fabrication

bull BampW mPowertrade

babcock amp wilcox power generation group

BampW Power Generation Group (BampW PGG)

Business Footprint

3 ~ =

Lf ~ T Do _ ~_ ~M_

bull $14 B Revenue in 2010 _$01011

bull $15 B Backlog as of 6130111

bull Headquartered in Barberton OH

bull Approximately 8270 employees (including JVs) as of August 2011

Location Employees USA 4464 Canada 573 Mexico 199 Europe 434 Asia 2374 Australia 226

Totsl 8270

Product Line Portfolio

Utility and industrial boilers Firing fossil fuels

Environmental products Control regulated emissions

Boiler cleaning and auxiliaries

Field services Upgrade replace equipment

Construction Install all BampW supplied scope

OampM services Operate maintain power plants

babcock amp w il cox power generation group

BampW PGG Global Operations

Houston TX

+ + Legend

bull BampW PGG Operations

+ Diamond Power Operations

D BampW Licensee BampW Sales Rep

Diamond Sales Rep

o

Extensive experience in manufacturing and sourcing worldwide

babcock amp w il cox power generat i on group

Developing and Delivering Technology Solutions

Environmental

bull NOx reduction

bull SO control bull Particulate control

bull Acid gas reduction

bull Mercury removal bull Ash management

Total Environmental Solutions

Ultra Supercritical

bull Highest efficiency coal-fired design

bull 133 Supercritical Boilers

bull Largest supercritical boilers in world (9 x 1300 MW)

bull Base-loaded and Full-cycling designs

bull Preferred technology for India and China

Ultra-Supercritical Boiler

I I 1

Renewables

bull Biomass

bull Waste-ta-Energy bull Concentrated Solar

Power (CSP)

bull Operate and Maintain

Solid Waste Authority West Palm Beach FL

CO2 Capture

bull Oxy-Coal Combustion

bull Regenerable Solvent Absorption Technology (RSA PM)

bull Extensive commitment to RampD

bull Wide variety of programs

middot Oxy-coal combustion project FutureGen 20

~ ~ --~--~--

- - ----~ Recently Expanded RampD Facility

00

babcock amp w i l cox power generation group

Bamp W is Providing Power for the United States

i 0

00 0

00

00 86J

0 0 0

000 ffil

0 S 0

0

~~~ amp8 ctl3

00 00

0

-

o

obull BampW Power Plants

Fossil Energy

it lt500 MW

500 - 1000 MW

gt 1000 MW

Nuclear

Biomass

BampW Owned and Government Operations

Laboratory and cg RampD Operations

88 Nuclear Manufacturing Operations

Manufacturing and Operations

babcock amp w il cox power generation group

Bamp Wis a Major Supplier of Utility Power Plant Equipment

bull Wisconsin Public Service - Weston 4 bull AEP - Mitchell 1 and 2 bull BampW 530 MW Supercritical Boiler bull 2 x 800 MW Wet Scrubber Systems bull seR Dry Scrubber and Baghouse

babcock amp w il cox power generation group

StackCSAPR andUMACT Fabric Filter

Baghouse (Ash) DryFGD ScrubberCompliance

(502 )

StackEquipment

Scrubber (502 )

Electrostatic Precipitator (Ash)

Supercritical Boiler Coal

Pulverizer

babcock amp N il cox pONer generation group

A Complete Environmental Technology Portfolio

I I ~

-Total Solutions Provider

babcock amp vV il cox pONer generation group

US Bamp W Installed Capacity and Market Share

Wet Dry Fabric Wet FGD FGD Filter ESP

BampW Installed 19966 10023 8717 46607 2710Capacity (MW)

Market Share 28 49 21 32 35

babcock amp wi l cox power generation group

Environmental Equipment Forecast for US Power Companies

Industry Sources CapacIty In GIgawatts (GW) L H h ow 19 Scrubbers (FGO) 25 45 SCR (Oe-NOx) 15 25 Oirect Sorbent Injection (OSI) of PAC 100 200Trona etc Fabric Filter (FF) 75 175

Total in GW 215 445

B II f D 1 $ Industry Sources I Ions 0 0 ars L H how 19 Total in $ $12 $25

EPC value =$24 - 48 B BampW core scope (furnish and install) is $12 - 24 B

babcock amp w i lcox power generation group

Policy Goals for Environmental Compliance

bull Achieve environmental compliance bull Increase number of US jobs bull Minimize economic impact to rate payers bull Maintain reliability of electricity supply

Longer compliance schedule maximizes US jobs and still supports environmental stewardship

babcock amp vvilcox povver generation group

Timeline for Project Execution

Permitting RFQ and Contracting Phase

Takes one to two years before Engineer-Procure-Construct (EPC) project begins

Project Execution Phase ~E~~co ~ FabrtC~iItr (3~onthS)~~P amp Testing PC Spe~~=~~ F e~~0-35 M~~~

EPC Scope Dry FGD (30-36 Months) Startup amp Testing

amp Testing

EPCScop WI G ont ~ n amp Testing e et F D (40-42M hS) ~it ~~

babcock amp wilcox power generation group

Short Compliance Deadlines Will Lead to Significant Challenges for Engineering PM and US Suppliers

45

tilt t- 40-- a ICI CIIuCII-_ 35-5 oS O)~ ~~ 30 t t -- ICI 25II) -5 t () CII c E 20 tamp ~g 15 O~ 11) 10t U ~ ~ ~()-- 5~Q

3 year Compliance Period In MACT sect112

Estimated High Capacity (Indicative Only)

Estimated Low

Field Construction Phase 2014 -2015

20182012 2013 2014 2015 2016 2017

babcock amp w il cox power generation group

Short Compliance Deadlines Will Lead to Significant Challenges for Engineering PM and US Suppliers

45

tilrr5 40- - CI3l u gt 355 Q

~~ 301IJtI r r - CI II 25 r3Q)Os 20-CQ)ro ~g 15 O~ 111shyr u 10 9 ~0 5~Q

3 year Compliance Period in MACT sect112

Estimated High Capacity (Indicative Only)

Estimated Low

1n1lACT Extension

Field Construction Phase

2012 2013 2014 2015 2016 2017 2018

babcock amp wilcox power generation group

Economic Impact of Major AQCS Project

Total Customer Project Cost $14B

Project Duration 4+ years

(Representative Sample of Large Project)

bull BampW Scope of Supply middot3 X 800 MW Wet FGD (core scope erected) bull 2 X 800 MW SCR retrofit (EPC)

bull BampW Supply = $ 400 M bull Engineering - 270 engineering

and material supply personnel bull Procurement

bull $ 81 M US procurement bull 10 states withgt $1 M in manufacturing

Iservices supplied bull Supply chain spanned over 20 states bull Equipment Supply

bull Construction bull Core scope Wet FGD = 500000 man hours bull EPC SCR = 1000000 manhours

babcock amp wilcox power generation group

Economic Impact of Major AQCS Project (Representative Sample of Large Project)

bull Equipment supply bull Absorber trays bull Agitators bull Alloy headers bull Bolts bull Electrical wiring bull Piping engineering bull Gaskets bull Monitors bull Pressure transmitters bull Pumps bull Steel plate bull Structural steel bull Ball and plug valves10 states withgt $1M in manufacturingservices supplied

States with lt $1M in manufacturingservices supplied

babcock amp wilcox power generation group

Construction Installation Services to Meet Regulatory Demand

babcock amp wilcox power generation group

BampW is a Major US Employer of Boilermaker Union Craft

bull One of top three boilermaker employers every year for last ten years

bull Top tier power plant constructor

Boilermaker union craft is the single largest union craft employed on power and emissions control projects nationwide

babcock amp wilcox power generation group

Total Boilermaker Man-Hour Forecast 3 year compliance schedule requires 16 more man-hours than highest recent peak

Man-hours (Millions)

~~~~~~~~~~~~~~~~~~~~ ~~~~~~~~~~~~~~~~~~~~

50 45 40 35 30 25 20 15 10

5 o

babcock amp wilcox power generation group

Construction Challenges in Meeting Regulatory Demand

bull Demands on craft labor will be significant - particularly on a regional basis

bull Time for implementation is too short

bull Project execution risk increases - safety quality cost

bull Although best practice mitigation strategies will be deployed results are questionable in meeting cost and schedule requirements given current UMACT compressed timeframe

babcock amp w il cox p o wer generation group

BampW Comments to EPA on Utility MACT

J~ ltgtU ~ ~ ~ ~

~~-_ ~ - - B~W

t Liipound7-- shyI~ _~ NyenltI_G lt1W~tOC-

- -_ - ~ ~

bull BampW reviewed the proposed Utility MACT rule and provided detailed comments

bull Proposed limits on new and reconstructed units too stringent

bull Some proposed limits on new and reconstructed units lower than capabilities of reference test methods

babcock amp w il cox power generation g oup

UMACT for New Units (NSPS)

45 of all US electricity is generated from coal from only 30 of installed US generation capacity bull Competitively priced long term bull 2417 availability (base load) bull Clean source of generation - virtually all plants will be clean

by 2015-2018 because of Utility MACTCSAPR bull Large jobs generator (mining railroad Boilermaker union construction

engineering manufacturing plant operations etc)

No new coal powered plants will be built in US under proposed rule emission limits bull BampW knows of no technology or combination of technologies commercially

available worldwide to achieve Total PM Hg and HCI emission limits bull Proposed limits are approximately an order of magnitude lower than what can

reliably be achieved by current technology bull Proposal is based on very low measured emissions at single units which are

believed to be the result of site-specific interactions of fuels test equipment and operations not regularly reproducible For example proposed limits are near the limits of detection of the measurement methods

babcock amp wi l cox power generation group

Challenges to Achieve Environmental Compliance reg Three year UMACT compliance period cannot be fulfilled

due to large number and duration of major projects

reg Attempts to meet UMACT three year compliance

reg Will drive extensive US manufacturing engineering and project management jobs offshore

reg Will increase risk substantially for project cost schedule completion and safety

reg There is insufficient experienced field craft to construct the required projects within three year period

reg UMACT emissions requirements for new installations cannot be met with current technology - no new coal based power plant will be built in the US under the proposed emission limits

reg As a major environmental system supplier BampW urges consideration for a six year compliance period

Page 4: Utility MACT Regulation Briefing - whitehouse.gov · Utility MACT Regulation Briefing . November 10, 2011 . Rich Killion . B&W Power Generation Group ... Scrubber (50. 2) Equipment

babcock amp wilcox power generation group

BampW Power Generation Group (BampW PGG)

Business Footprint

3 ~ =

Lf ~ T Do _ ~_ ~M_

bull $14 B Revenue in 2010 _$01011

bull $15 B Backlog as of 6130111

bull Headquartered in Barberton OH

bull Approximately 8270 employees (including JVs) as of August 2011

Location Employees USA 4464 Canada 573 Mexico 199 Europe 434 Asia 2374 Australia 226

Totsl 8270

Product Line Portfolio

Utility and industrial boilers Firing fossil fuels

Environmental products Control regulated emissions

Boiler cleaning and auxiliaries

Field services Upgrade replace equipment

Construction Install all BampW supplied scope

OampM services Operate maintain power plants

babcock amp w il cox power generation group

BampW PGG Global Operations

Houston TX

+ + Legend

bull BampW PGG Operations

+ Diamond Power Operations

D BampW Licensee BampW Sales Rep

Diamond Sales Rep

o

Extensive experience in manufacturing and sourcing worldwide

babcock amp w il cox power generat i on group

Developing and Delivering Technology Solutions

Environmental

bull NOx reduction

bull SO control bull Particulate control

bull Acid gas reduction

bull Mercury removal bull Ash management

Total Environmental Solutions

Ultra Supercritical

bull Highest efficiency coal-fired design

bull 133 Supercritical Boilers

bull Largest supercritical boilers in world (9 x 1300 MW)

bull Base-loaded and Full-cycling designs

bull Preferred technology for India and China

Ultra-Supercritical Boiler

I I 1

Renewables

bull Biomass

bull Waste-ta-Energy bull Concentrated Solar

Power (CSP)

bull Operate and Maintain

Solid Waste Authority West Palm Beach FL

CO2 Capture

bull Oxy-Coal Combustion

bull Regenerable Solvent Absorption Technology (RSA PM)

bull Extensive commitment to RampD

bull Wide variety of programs

middot Oxy-coal combustion project FutureGen 20

~ ~ --~--~--

- - ----~ Recently Expanded RampD Facility

00

babcock amp w i l cox power generation group

Bamp W is Providing Power for the United States

i 0

00 0

00

00 86J

0 0 0

000 ffil

0 S 0

0

~~~ amp8 ctl3

00 00

0

-

o

obull BampW Power Plants

Fossil Energy

it lt500 MW

500 - 1000 MW

gt 1000 MW

Nuclear

Biomass

BampW Owned and Government Operations

Laboratory and cg RampD Operations

88 Nuclear Manufacturing Operations

Manufacturing and Operations

babcock amp w il cox power generation group

Bamp Wis a Major Supplier of Utility Power Plant Equipment

bull Wisconsin Public Service - Weston 4 bull AEP - Mitchell 1 and 2 bull BampW 530 MW Supercritical Boiler bull 2 x 800 MW Wet Scrubber Systems bull seR Dry Scrubber and Baghouse

babcock amp w il cox power generation group

StackCSAPR andUMACT Fabric Filter

Baghouse (Ash) DryFGD ScrubberCompliance

(502 )

StackEquipment

Scrubber (502 )

Electrostatic Precipitator (Ash)

Supercritical Boiler Coal

Pulverizer

babcock amp N il cox pONer generation group

A Complete Environmental Technology Portfolio

I I ~

-Total Solutions Provider

babcock amp vV il cox pONer generation group

US Bamp W Installed Capacity and Market Share

Wet Dry Fabric Wet FGD FGD Filter ESP

BampW Installed 19966 10023 8717 46607 2710Capacity (MW)

Market Share 28 49 21 32 35

babcock amp wi l cox power generation group

Environmental Equipment Forecast for US Power Companies

Industry Sources CapacIty In GIgawatts (GW) L H h ow 19 Scrubbers (FGO) 25 45 SCR (Oe-NOx) 15 25 Oirect Sorbent Injection (OSI) of PAC 100 200Trona etc Fabric Filter (FF) 75 175

Total in GW 215 445

B II f D 1 $ Industry Sources I Ions 0 0 ars L H how 19 Total in $ $12 $25

EPC value =$24 - 48 B BampW core scope (furnish and install) is $12 - 24 B

babcock amp w i lcox power generation group

Policy Goals for Environmental Compliance

bull Achieve environmental compliance bull Increase number of US jobs bull Minimize economic impact to rate payers bull Maintain reliability of electricity supply

Longer compliance schedule maximizes US jobs and still supports environmental stewardship

babcock amp vvilcox povver generation group

Timeline for Project Execution

Permitting RFQ and Contracting Phase

Takes one to two years before Engineer-Procure-Construct (EPC) project begins

Project Execution Phase ~E~~co ~ FabrtC~iItr (3~onthS)~~P amp Testing PC Spe~~=~~ F e~~0-35 M~~~

EPC Scope Dry FGD (30-36 Months) Startup amp Testing

amp Testing

EPCScop WI G ont ~ n amp Testing e et F D (40-42M hS) ~it ~~

babcock amp wilcox power generation group

Short Compliance Deadlines Will Lead to Significant Challenges for Engineering PM and US Suppliers

45

tilt t- 40-- a ICI CIIuCII-_ 35-5 oS O)~ ~~ 30 t t -- ICI 25II) -5 t () CII c E 20 tamp ~g 15 O~ 11) 10t U ~ ~ ~()-- 5~Q

3 year Compliance Period In MACT sect112

Estimated High Capacity (Indicative Only)

Estimated Low

Field Construction Phase 2014 -2015

20182012 2013 2014 2015 2016 2017

babcock amp w il cox power generation group

Short Compliance Deadlines Will Lead to Significant Challenges for Engineering PM and US Suppliers

45

tilrr5 40- - CI3l u gt 355 Q

~~ 301IJtI r r - CI II 25 r3Q)Os 20-CQ)ro ~g 15 O~ 111shyr u 10 9 ~0 5~Q

3 year Compliance Period in MACT sect112

Estimated High Capacity (Indicative Only)

Estimated Low

1n1lACT Extension

Field Construction Phase

2012 2013 2014 2015 2016 2017 2018

babcock amp wilcox power generation group

Economic Impact of Major AQCS Project

Total Customer Project Cost $14B

Project Duration 4+ years

(Representative Sample of Large Project)

bull BampW Scope of Supply middot3 X 800 MW Wet FGD (core scope erected) bull 2 X 800 MW SCR retrofit (EPC)

bull BampW Supply = $ 400 M bull Engineering - 270 engineering

and material supply personnel bull Procurement

bull $ 81 M US procurement bull 10 states withgt $1 M in manufacturing

Iservices supplied bull Supply chain spanned over 20 states bull Equipment Supply

bull Construction bull Core scope Wet FGD = 500000 man hours bull EPC SCR = 1000000 manhours

babcock amp wilcox power generation group

Economic Impact of Major AQCS Project (Representative Sample of Large Project)

bull Equipment supply bull Absorber trays bull Agitators bull Alloy headers bull Bolts bull Electrical wiring bull Piping engineering bull Gaskets bull Monitors bull Pressure transmitters bull Pumps bull Steel plate bull Structural steel bull Ball and plug valves10 states withgt $1M in manufacturingservices supplied

States with lt $1M in manufacturingservices supplied

babcock amp wilcox power generation group

Construction Installation Services to Meet Regulatory Demand

babcock amp wilcox power generation group

BampW is a Major US Employer of Boilermaker Union Craft

bull One of top three boilermaker employers every year for last ten years

bull Top tier power plant constructor

Boilermaker union craft is the single largest union craft employed on power and emissions control projects nationwide

babcock amp wilcox power generation group

Total Boilermaker Man-Hour Forecast 3 year compliance schedule requires 16 more man-hours than highest recent peak

Man-hours (Millions)

~~~~~~~~~~~~~~~~~~~~ ~~~~~~~~~~~~~~~~~~~~

50 45 40 35 30 25 20 15 10

5 o

babcock amp wilcox power generation group

Construction Challenges in Meeting Regulatory Demand

bull Demands on craft labor will be significant - particularly on a regional basis

bull Time for implementation is too short

bull Project execution risk increases - safety quality cost

bull Although best practice mitigation strategies will be deployed results are questionable in meeting cost and schedule requirements given current UMACT compressed timeframe

babcock amp w il cox p o wer generation group

BampW Comments to EPA on Utility MACT

J~ ltgtU ~ ~ ~ ~

~~-_ ~ - - B~W

t Liipound7-- shyI~ _~ NyenltI_G lt1W~tOC-

- -_ - ~ ~

bull BampW reviewed the proposed Utility MACT rule and provided detailed comments

bull Proposed limits on new and reconstructed units too stringent

bull Some proposed limits on new and reconstructed units lower than capabilities of reference test methods

babcock amp w il cox power generation g oup

UMACT for New Units (NSPS)

45 of all US electricity is generated from coal from only 30 of installed US generation capacity bull Competitively priced long term bull 2417 availability (base load) bull Clean source of generation - virtually all plants will be clean

by 2015-2018 because of Utility MACTCSAPR bull Large jobs generator (mining railroad Boilermaker union construction

engineering manufacturing plant operations etc)

No new coal powered plants will be built in US under proposed rule emission limits bull BampW knows of no technology or combination of technologies commercially

available worldwide to achieve Total PM Hg and HCI emission limits bull Proposed limits are approximately an order of magnitude lower than what can

reliably be achieved by current technology bull Proposal is based on very low measured emissions at single units which are

believed to be the result of site-specific interactions of fuels test equipment and operations not regularly reproducible For example proposed limits are near the limits of detection of the measurement methods

babcock amp wi l cox power generation group

Challenges to Achieve Environmental Compliance reg Three year UMACT compliance period cannot be fulfilled

due to large number and duration of major projects

reg Attempts to meet UMACT three year compliance

reg Will drive extensive US manufacturing engineering and project management jobs offshore

reg Will increase risk substantially for project cost schedule completion and safety

reg There is insufficient experienced field craft to construct the required projects within three year period

reg UMACT emissions requirements for new installations cannot be met with current technology - no new coal based power plant will be built in the US under the proposed emission limits

reg As a major environmental system supplier BampW urges consideration for a six year compliance period

Page 5: Utility MACT Regulation Briefing - whitehouse.gov · Utility MACT Regulation Briefing . November 10, 2011 . Rich Killion . B&W Power Generation Group ... Scrubber (50. 2) Equipment

babcock amp w il cox power generation group

BampW PGG Global Operations

Houston TX

+ + Legend

bull BampW PGG Operations

+ Diamond Power Operations

D BampW Licensee BampW Sales Rep

Diamond Sales Rep

o

Extensive experience in manufacturing and sourcing worldwide

babcock amp w il cox power generat i on group

Developing and Delivering Technology Solutions

Environmental

bull NOx reduction

bull SO control bull Particulate control

bull Acid gas reduction

bull Mercury removal bull Ash management

Total Environmental Solutions

Ultra Supercritical

bull Highest efficiency coal-fired design

bull 133 Supercritical Boilers

bull Largest supercritical boilers in world (9 x 1300 MW)

bull Base-loaded and Full-cycling designs

bull Preferred technology for India and China

Ultra-Supercritical Boiler

I I 1

Renewables

bull Biomass

bull Waste-ta-Energy bull Concentrated Solar

Power (CSP)

bull Operate and Maintain

Solid Waste Authority West Palm Beach FL

CO2 Capture

bull Oxy-Coal Combustion

bull Regenerable Solvent Absorption Technology (RSA PM)

bull Extensive commitment to RampD

bull Wide variety of programs

middot Oxy-coal combustion project FutureGen 20

~ ~ --~--~--

- - ----~ Recently Expanded RampD Facility

00

babcock amp w i l cox power generation group

Bamp W is Providing Power for the United States

i 0

00 0

00

00 86J

0 0 0

000 ffil

0 S 0

0

~~~ amp8 ctl3

00 00

0

-

o

obull BampW Power Plants

Fossil Energy

it lt500 MW

500 - 1000 MW

gt 1000 MW

Nuclear

Biomass

BampW Owned and Government Operations

Laboratory and cg RampD Operations

88 Nuclear Manufacturing Operations

Manufacturing and Operations

babcock amp w il cox power generation group

Bamp Wis a Major Supplier of Utility Power Plant Equipment

bull Wisconsin Public Service - Weston 4 bull AEP - Mitchell 1 and 2 bull BampW 530 MW Supercritical Boiler bull 2 x 800 MW Wet Scrubber Systems bull seR Dry Scrubber and Baghouse

babcock amp w il cox power generation group

StackCSAPR andUMACT Fabric Filter

Baghouse (Ash) DryFGD ScrubberCompliance

(502 )

StackEquipment

Scrubber (502 )

Electrostatic Precipitator (Ash)

Supercritical Boiler Coal

Pulverizer

babcock amp N il cox pONer generation group

A Complete Environmental Technology Portfolio

I I ~

-Total Solutions Provider

babcock amp vV il cox pONer generation group

US Bamp W Installed Capacity and Market Share

Wet Dry Fabric Wet FGD FGD Filter ESP

BampW Installed 19966 10023 8717 46607 2710Capacity (MW)

Market Share 28 49 21 32 35

babcock amp wi l cox power generation group

Environmental Equipment Forecast for US Power Companies

Industry Sources CapacIty In GIgawatts (GW) L H h ow 19 Scrubbers (FGO) 25 45 SCR (Oe-NOx) 15 25 Oirect Sorbent Injection (OSI) of PAC 100 200Trona etc Fabric Filter (FF) 75 175

Total in GW 215 445

B II f D 1 $ Industry Sources I Ions 0 0 ars L H how 19 Total in $ $12 $25

EPC value =$24 - 48 B BampW core scope (furnish and install) is $12 - 24 B

babcock amp w i lcox power generation group

Policy Goals for Environmental Compliance

bull Achieve environmental compliance bull Increase number of US jobs bull Minimize economic impact to rate payers bull Maintain reliability of electricity supply

Longer compliance schedule maximizes US jobs and still supports environmental stewardship

babcock amp vvilcox povver generation group

Timeline for Project Execution

Permitting RFQ and Contracting Phase

Takes one to two years before Engineer-Procure-Construct (EPC) project begins

Project Execution Phase ~E~~co ~ FabrtC~iItr (3~onthS)~~P amp Testing PC Spe~~=~~ F e~~0-35 M~~~

EPC Scope Dry FGD (30-36 Months) Startup amp Testing

amp Testing

EPCScop WI G ont ~ n amp Testing e et F D (40-42M hS) ~it ~~

babcock amp wilcox power generation group

Short Compliance Deadlines Will Lead to Significant Challenges for Engineering PM and US Suppliers

45

tilt t- 40-- a ICI CIIuCII-_ 35-5 oS O)~ ~~ 30 t t -- ICI 25II) -5 t () CII c E 20 tamp ~g 15 O~ 11) 10t U ~ ~ ~()-- 5~Q

3 year Compliance Period In MACT sect112

Estimated High Capacity (Indicative Only)

Estimated Low

Field Construction Phase 2014 -2015

20182012 2013 2014 2015 2016 2017

babcock amp w il cox power generation group

Short Compliance Deadlines Will Lead to Significant Challenges for Engineering PM and US Suppliers

45

tilrr5 40- - CI3l u gt 355 Q

~~ 301IJtI r r - CI II 25 r3Q)Os 20-CQ)ro ~g 15 O~ 111shyr u 10 9 ~0 5~Q

3 year Compliance Period in MACT sect112

Estimated High Capacity (Indicative Only)

Estimated Low

1n1lACT Extension

Field Construction Phase

2012 2013 2014 2015 2016 2017 2018

babcock amp wilcox power generation group

Economic Impact of Major AQCS Project

Total Customer Project Cost $14B

Project Duration 4+ years

(Representative Sample of Large Project)

bull BampW Scope of Supply middot3 X 800 MW Wet FGD (core scope erected) bull 2 X 800 MW SCR retrofit (EPC)

bull BampW Supply = $ 400 M bull Engineering - 270 engineering

and material supply personnel bull Procurement

bull $ 81 M US procurement bull 10 states withgt $1 M in manufacturing

Iservices supplied bull Supply chain spanned over 20 states bull Equipment Supply

bull Construction bull Core scope Wet FGD = 500000 man hours bull EPC SCR = 1000000 manhours

babcock amp wilcox power generation group

Economic Impact of Major AQCS Project (Representative Sample of Large Project)

bull Equipment supply bull Absorber trays bull Agitators bull Alloy headers bull Bolts bull Electrical wiring bull Piping engineering bull Gaskets bull Monitors bull Pressure transmitters bull Pumps bull Steel plate bull Structural steel bull Ball and plug valves10 states withgt $1M in manufacturingservices supplied

States with lt $1M in manufacturingservices supplied

babcock amp wilcox power generation group

Construction Installation Services to Meet Regulatory Demand

babcock amp wilcox power generation group

BampW is a Major US Employer of Boilermaker Union Craft

bull One of top three boilermaker employers every year for last ten years

bull Top tier power plant constructor

Boilermaker union craft is the single largest union craft employed on power and emissions control projects nationwide

babcock amp wilcox power generation group

Total Boilermaker Man-Hour Forecast 3 year compliance schedule requires 16 more man-hours than highest recent peak

Man-hours (Millions)

~~~~~~~~~~~~~~~~~~~~ ~~~~~~~~~~~~~~~~~~~~

50 45 40 35 30 25 20 15 10

5 o

babcock amp wilcox power generation group

Construction Challenges in Meeting Regulatory Demand

bull Demands on craft labor will be significant - particularly on a regional basis

bull Time for implementation is too short

bull Project execution risk increases - safety quality cost

bull Although best practice mitigation strategies will be deployed results are questionable in meeting cost and schedule requirements given current UMACT compressed timeframe

babcock amp w il cox p o wer generation group

BampW Comments to EPA on Utility MACT

J~ ltgtU ~ ~ ~ ~

~~-_ ~ - - B~W

t Liipound7-- shyI~ _~ NyenltI_G lt1W~tOC-

- -_ - ~ ~

bull BampW reviewed the proposed Utility MACT rule and provided detailed comments

bull Proposed limits on new and reconstructed units too stringent

bull Some proposed limits on new and reconstructed units lower than capabilities of reference test methods

babcock amp w il cox power generation g oup

UMACT for New Units (NSPS)

45 of all US electricity is generated from coal from only 30 of installed US generation capacity bull Competitively priced long term bull 2417 availability (base load) bull Clean source of generation - virtually all plants will be clean

by 2015-2018 because of Utility MACTCSAPR bull Large jobs generator (mining railroad Boilermaker union construction

engineering manufacturing plant operations etc)

No new coal powered plants will be built in US under proposed rule emission limits bull BampW knows of no technology or combination of technologies commercially

available worldwide to achieve Total PM Hg and HCI emission limits bull Proposed limits are approximately an order of magnitude lower than what can

reliably be achieved by current technology bull Proposal is based on very low measured emissions at single units which are

believed to be the result of site-specific interactions of fuels test equipment and operations not regularly reproducible For example proposed limits are near the limits of detection of the measurement methods

babcock amp wi l cox power generation group

Challenges to Achieve Environmental Compliance reg Three year UMACT compliance period cannot be fulfilled

due to large number and duration of major projects

reg Attempts to meet UMACT three year compliance

reg Will drive extensive US manufacturing engineering and project management jobs offshore

reg Will increase risk substantially for project cost schedule completion and safety

reg There is insufficient experienced field craft to construct the required projects within three year period

reg UMACT emissions requirements for new installations cannot be met with current technology - no new coal based power plant will be built in the US under the proposed emission limits

reg As a major environmental system supplier BampW urges consideration for a six year compliance period

Page 6: Utility MACT Regulation Briefing - whitehouse.gov · Utility MACT Regulation Briefing . November 10, 2011 . Rich Killion . B&W Power Generation Group ... Scrubber (50. 2) Equipment

babcock amp w il cox power generat i on group

Developing and Delivering Technology Solutions

Environmental

bull NOx reduction

bull SO control bull Particulate control

bull Acid gas reduction

bull Mercury removal bull Ash management

Total Environmental Solutions

Ultra Supercritical

bull Highest efficiency coal-fired design

bull 133 Supercritical Boilers

bull Largest supercritical boilers in world (9 x 1300 MW)

bull Base-loaded and Full-cycling designs

bull Preferred technology for India and China

Ultra-Supercritical Boiler

I I 1

Renewables

bull Biomass

bull Waste-ta-Energy bull Concentrated Solar

Power (CSP)

bull Operate and Maintain

Solid Waste Authority West Palm Beach FL

CO2 Capture

bull Oxy-Coal Combustion

bull Regenerable Solvent Absorption Technology (RSA PM)

bull Extensive commitment to RampD

bull Wide variety of programs

middot Oxy-coal combustion project FutureGen 20

~ ~ --~--~--

- - ----~ Recently Expanded RampD Facility

00

babcock amp w i l cox power generation group

Bamp W is Providing Power for the United States

i 0

00 0

00

00 86J

0 0 0

000 ffil

0 S 0

0

~~~ amp8 ctl3

00 00

0

-

o

obull BampW Power Plants

Fossil Energy

it lt500 MW

500 - 1000 MW

gt 1000 MW

Nuclear

Biomass

BampW Owned and Government Operations

Laboratory and cg RampD Operations

88 Nuclear Manufacturing Operations

Manufacturing and Operations

babcock amp w il cox power generation group

Bamp Wis a Major Supplier of Utility Power Plant Equipment

bull Wisconsin Public Service - Weston 4 bull AEP - Mitchell 1 and 2 bull BampW 530 MW Supercritical Boiler bull 2 x 800 MW Wet Scrubber Systems bull seR Dry Scrubber and Baghouse

babcock amp w il cox power generation group

StackCSAPR andUMACT Fabric Filter

Baghouse (Ash) DryFGD ScrubberCompliance

(502 )

StackEquipment

Scrubber (502 )

Electrostatic Precipitator (Ash)

Supercritical Boiler Coal

Pulverizer

babcock amp N il cox pONer generation group

A Complete Environmental Technology Portfolio

I I ~

-Total Solutions Provider

babcock amp vV il cox pONer generation group

US Bamp W Installed Capacity and Market Share

Wet Dry Fabric Wet FGD FGD Filter ESP

BampW Installed 19966 10023 8717 46607 2710Capacity (MW)

Market Share 28 49 21 32 35

babcock amp wi l cox power generation group

Environmental Equipment Forecast for US Power Companies

Industry Sources CapacIty In GIgawatts (GW) L H h ow 19 Scrubbers (FGO) 25 45 SCR (Oe-NOx) 15 25 Oirect Sorbent Injection (OSI) of PAC 100 200Trona etc Fabric Filter (FF) 75 175

Total in GW 215 445

B II f D 1 $ Industry Sources I Ions 0 0 ars L H how 19 Total in $ $12 $25

EPC value =$24 - 48 B BampW core scope (furnish and install) is $12 - 24 B

babcock amp w i lcox power generation group

Policy Goals for Environmental Compliance

bull Achieve environmental compliance bull Increase number of US jobs bull Minimize economic impact to rate payers bull Maintain reliability of electricity supply

Longer compliance schedule maximizes US jobs and still supports environmental stewardship

babcock amp vvilcox povver generation group

Timeline for Project Execution

Permitting RFQ and Contracting Phase

Takes one to two years before Engineer-Procure-Construct (EPC) project begins

Project Execution Phase ~E~~co ~ FabrtC~iItr (3~onthS)~~P amp Testing PC Spe~~=~~ F e~~0-35 M~~~

EPC Scope Dry FGD (30-36 Months) Startup amp Testing

amp Testing

EPCScop WI G ont ~ n amp Testing e et F D (40-42M hS) ~it ~~

babcock amp wilcox power generation group

Short Compliance Deadlines Will Lead to Significant Challenges for Engineering PM and US Suppliers

45

tilt t- 40-- a ICI CIIuCII-_ 35-5 oS O)~ ~~ 30 t t -- ICI 25II) -5 t () CII c E 20 tamp ~g 15 O~ 11) 10t U ~ ~ ~()-- 5~Q

3 year Compliance Period In MACT sect112

Estimated High Capacity (Indicative Only)

Estimated Low

Field Construction Phase 2014 -2015

20182012 2013 2014 2015 2016 2017

babcock amp w il cox power generation group

Short Compliance Deadlines Will Lead to Significant Challenges for Engineering PM and US Suppliers

45

tilrr5 40- - CI3l u gt 355 Q

~~ 301IJtI r r - CI II 25 r3Q)Os 20-CQ)ro ~g 15 O~ 111shyr u 10 9 ~0 5~Q

3 year Compliance Period in MACT sect112

Estimated High Capacity (Indicative Only)

Estimated Low

1n1lACT Extension

Field Construction Phase

2012 2013 2014 2015 2016 2017 2018

babcock amp wilcox power generation group

Economic Impact of Major AQCS Project

Total Customer Project Cost $14B

Project Duration 4+ years

(Representative Sample of Large Project)

bull BampW Scope of Supply middot3 X 800 MW Wet FGD (core scope erected) bull 2 X 800 MW SCR retrofit (EPC)

bull BampW Supply = $ 400 M bull Engineering - 270 engineering

and material supply personnel bull Procurement

bull $ 81 M US procurement bull 10 states withgt $1 M in manufacturing

Iservices supplied bull Supply chain spanned over 20 states bull Equipment Supply

bull Construction bull Core scope Wet FGD = 500000 man hours bull EPC SCR = 1000000 manhours

babcock amp wilcox power generation group

Economic Impact of Major AQCS Project (Representative Sample of Large Project)

bull Equipment supply bull Absorber trays bull Agitators bull Alloy headers bull Bolts bull Electrical wiring bull Piping engineering bull Gaskets bull Monitors bull Pressure transmitters bull Pumps bull Steel plate bull Structural steel bull Ball and plug valves10 states withgt $1M in manufacturingservices supplied

States with lt $1M in manufacturingservices supplied

babcock amp wilcox power generation group

Construction Installation Services to Meet Regulatory Demand

babcock amp wilcox power generation group

BampW is a Major US Employer of Boilermaker Union Craft

bull One of top three boilermaker employers every year for last ten years

bull Top tier power plant constructor

Boilermaker union craft is the single largest union craft employed on power and emissions control projects nationwide

babcock amp wilcox power generation group

Total Boilermaker Man-Hour Forecast 3 year compliance schedule requires 16 more man-hours than highest recent peak

Man-hours (Millions)

~~~~~~~~~~~~~~~~~~~~ ~~~~~~~~~~~~~~~~~~~~

50 45 40 35 30 25 20 15 10

5 o

babcock amp wilcox power generation group

Construction Challenges in Meeting Regulatory Demand

bull Demands on craft labor will be significant - particularly on a regional basis

bull Time for implementation is too short

bull Project execution risk increases - safety quality cost

bull Although best practice mitigation strategies will be deployed results are questionable in meeting cost and schedule requirements given current UMACT compressed timeframe

babcock amp w il cox p o wer generation group

BampW Comments to EPA on Utility MACT

J~ ltgtU ~ ~ ~ ~

~~-_ ~ - - B~W

t Liipound7-- shyI~ _~ NyenltI_G lt1W~tOC-

- -_ - ~ ~

bull BampW reviewed the proposed Utility MACT rule and provided detailed comments

bull Proposed limits on new and reconstructed units too stringent

bull Some proposed limits on new and reconstructed units lower than capabilities of reference test methods

babcock amp w il cox power generation g oup

UMACT for New Units (NSPS)

45 of all US electricity is generated from coal from only 30 of installed US generation capacity bull Competitively priced long term bull 2417 availability (base load) bull Clean source of generation - virtually all plants will be clean

by 2015-2018 because of Utility MACTCSAPR bull Large jobs generator (mining railroad Boilermaker union construction

engineering manufacturing plant operations etc)

No new coal powered plants will be built in US under proposed rule emission limits bull BampW knows of no technology or combination of technologies commercially

available worldwide to achieve Total PM Hg and HCI emission limits bull Proposed limits are approximately an order of magnitude lower than what can

reliably be achieved by current technology bull Proposal is based on very low measured emissions at single units which are

believed to be the result of site-specific interactions of fuels test equipment and operations not regularly reproducible For example proposed limits are near the limits of detection of the measurement methods

babcock amp wi l cox power generation group

Challenges to Achieve Environmental Compliance reg Three year UMACT compliance period cannot be fulfilled

due to large number and duration of major projects

reg Attempts to meet UMACT three year compliance

reg Will drive extensive US manufacturing engineering and project management jobs offshore

reg Will increase risk substantially for project cost schedule completion and safety

reg There is insufficient experienced field craft to construct the required projects within three year period

reg UMACT emissions requirements for new installations cannot be met with current technology - no new coal based power plant will be built in the US under the proposed emission limits

reg As a major environmental system supplier BampW urges consideration for a six year compliance period

Page 7: Utility MACT Regulation Briefing - whitehouse.gov · Utility MACT Regulation Briefing . November 10, 2011 . Rich Killion . B&W Power Generation Group ... Scrubber (50. 2) Equipment

00

babcock amp w i l cox power generation group

Bamp W is Providing Power for the United States

i 0

00 0

00

00 86J

0 0 0

000 ffil

0 S 0

0

~~~ amp8 ctl3

00 00

0

-

o

obull BampW Power Plants

Fossil Energy

it lt500 MW

500 - 1000 MW

gt 1000 MW

Nuclear

Biomass

BampW Owned and Government Operations

Laboratory and cg RampD Operations

88 Nuclear Manufacturing Operations

Manufacturing and Operations

babcock amp w il cox power generation group

Bamp Wis a Major Supplier of Utility Power Plant Equipment

bull Wisconsin Public Service - Weston 4 bull AEP - Mitchell 1 and 2 bull BampW 530 MW Supercritical Boiler bull 2 x 800 MW Wet Scrubber Systems bull seR Dry Scrubber and Baghouse

babcock amp w il cox power generation group

StackCSAPR andUMACT Fabric Filter

Baghouse (Ash) DryFGD ScrubberCompliance

(502 )

StackEquipment

Scrubber (502 )

Electrostatic Precipitator (Ash)

Supercritical Boiler Coal

Pulverizer

babcock amp N il cox pONer generation group

A Complete Environmental Technology Portfolio

I I ~

-Total Solutions Provider

babcock amp vV il cox pONer generation group

US Bamp W Installed Capacity and Market Share

Wet Dry Fabric Wet FGD FGD Filter ESP

BampW Installed 19966 10023 8717 46607 2710Capacity (MW)

Market Share 28 49 21 32 35

babcock amp wi l cox power generation group

Environmental Equipment Forecast for US Power Companies

Industry Sources CapacIty In GIgawatts (GW) L H h ow 19 Scrubbers (FGO) 25 45 SCR (Oe-NOx) 15 25 Oirect Sorbent Injection (OSI) of PAC 100 200Trona etc Fabric Filter (FF) 75 175

Total in GW 215 445

B II f D 1 $ Industry Sources I Ions 0 0 ars L H how 19 Total in $ $12 $25

EPC value =$24 - 48 B BampW core scope (furnish and install) is $12 - 24 B

babcock amp w i lcox power generation group

Policy Goals for Environmental Compliance

bull Achieve environmental compliance bull Increase number of US jobs bull Minimize economic impact to rate payers bull Maintain reliability of electricity supply

Longer compliance schedule maximizes US jobs and still supports environmental stewardship

babcock amp vvilcox povver generation group

Timeline for Project Execution

Permitting RFQ and Contracting Phase

Takes one to two years before Engineer-Procure-Construct (EPC) project begins

Project Execution Phase ~E~~co ~ FabrtC~iItr (3~onthS)~~P amp Testing PC Spe~~=~~ F e~~0-35 M~~~

EPC Scope Dry FGD (30-36 Months) Startup amp Testing

amp Testing

EPCScop WI G ont ~ n amp Testing e et F D (40-42M hS) ~it ~~

babcock amp wilcox power generation group

Short Compliance Deadlines Will Lead to Significant Challenges for Engineering PM and US Suppliers

45

tilt t- 40-- a ICI CIIuCII-_ 35-5 oS O)~ ~~ 30 t t -- ICI 25II) -5 t () CII c E 20 tamp ~g 15 O~ 11) 10t U ~ ~ ~()-- 5~Q

3 year Compliance Period In MACT sect112

Estimated High Capacity (Indicative Only)

Estimated Low

Field Construction Phase 2014 -2015

20182012 2013 2014 2015 2016 2017

babcock amp w il cox power generation group

Short Compliance Deadlines Will Lead to Significant Challenges for Engineering PM and US Suppliers

45

tilrr5 40- - CI3l u gt 355 Q

~~ 301IJtI r r - CI II 25 r3Q)Os 20-CQ)ro ~g 15 O~ 111shyr u 10 9 ~0 5~Q

3 year Compliance Period in MACT sect112

Estimated High Capacity (Indicative Only)

Estimated Low

1n1lACT Extension

Field Construction Phase

2012 2013 2014 2015 2016 2017 2018

babcock amp wilcox power generation group

Economic Impact of Major AQCS Project

Total Customer Project Cost $14B

Project Duration 4+ years

(Representative Sample of Large Project)

bull BampW Scope of Supply middot3 X 800 MW Wet FGD (core scope erected) bull 2 X 800 MW SCR retrofit (EPC)

bull BampW Supply = $ 400 M bull Engineering - 270 engineering

and material supply personnel bull Procurement

bull $ 81 M US procurement bull 10 states withgt $1 M in manufacturing

Iservices supplied bull Supply chain spanned over 20 states bull Equipment Supply

bull Construction bull Core scope Wet FGD = 500000 man hours bull EPC SCR = 1000000 manhours

babcock amp wilcox power generation group

Economic Impact of Major AQCS Project (Representative Sample of Large Project)

bull Equipment supply bull Absorber trays bull Agitators bull Alloy headers bull Bolts bull Electrical wiring bull Piping engineering bull Gaskets bull Monitors bull Pressure transmitters bull Pumps bull Steel plate bull Structural steel bull Ball and plug valves10 states withgt $1M in manufacturingservices supplied

States with lt $1M in manufacturingservices supplied

babcock amp wilcox power generation group

Construction Installation Services to Meet Regulatory Demand

babcock amp wilcox power generation group

BampW is a Major US Employer of Boilermaker Union Craft

bull One of top three boilermaker employers every year for last ten years

bull Top tier power plant constructor

Boilermaker union craft is the single largest union craft employed on power and emissions control projects nationwide

babcock amp wilcox power generation group

Total Boilermaker Man-Hour Forecast 3 year compliance schedule requires 16 more man-hours than highest recent peak

Man-hours (Millions)

~~~~~~~~~~~~~~~~~~~~ ~~~~~~~~~~~~~~~~~~~~

50 45 40 35 30 25 20 15 10

5 o

babcock amp wilcox power generation group

Construction Challenges in Meeting Regulatory Demand

bull Demands on craft labor will be significant - particularly on a regional basis

bull Time for implementation is too short

bull Project execution risk increases - safety quality cost

bull Although best practice mitigation strategies will be deployed results are questionable in meeting cost and schedule requirements given current UMACT compressed timeframe

babcock amp w il cox p o wer generation group

BampW Comments to EPA on Utility MACT

J~ ltgtU ~ ~ ~ ~

~~-_ ~ - - B~W

t Liipound7-- shyI~ _~ NyenltI_G lt1W~tOC-

- -_ - ~ ~

bull BampW reviewed the proposed Utility MACT rule and provided detailed comments

bull Proposed limits on new and reconstructed units too stringent

bull Some proposed limits on new and reconstructed units lower than capabilities of reference test methods

babcock amp w il cox power generation g oup

UMACT for New Units (NSPS)

45 of all US electricity is generated from coal from only 30 of installed US generation capacity bull Competitively priced long term bull 2417 availability (base load) bull Clean source of generation - virtually all plants will be clean

by 2015-2018 because of Utility MACTCSAPR bull Large jobs generator (mining railroad Boilermaker union construction

engineering manufacturing plant operations etc)

No new coal powered plants will be built in US under proposed rule emission limits bull BampW knows of no technology or combination of technologies commercially

available worldwide to achieve Total PM Hg and HCI emission limits bull Proposed limits are approximately an order of magnitude lower than what can

reliably be achieved by current technology bull Proposal is based on very low measured emissions at single units which are

believed to be the result of site-specific interactions of fuels test equipment and operations not regularly reproducible For example proposed limits are near the limits of detection of the measurement methods

babcock amp wi l cox power generation group

Challenges to Achieve Environmental Compliance reg Three year UMACT compliance period cannot be fulfilled

due to large number and duration of major projects

reg Attempts to meet UMACT three year compliance

reg Will drive extensive US manufacturing engineering and project management jobs offshore

reg Will increase risk substantially for project cost schedule completion and safety

reg There is insufficient experienced field craft to construct the required projects within three year period

reg UMACT emissions requirements for new installations cannot be met with current technology - no new coal based power plant will be built in the US under the proposed emission limits

reg As a major environmental system supplier BampW urges consideration for a six year compliance period

Page 8: Utility MACT Regulation Briefing - whitehouse.gov · Utility MACT Regulation Briefing . November 10, 2011 . Rich Killion . B&W Power Generation Group ... Scrubber (50. 2) Equipment

babcock amp w il cox power generation group

Bamp Wis a Major Supplier of Utility Power Plant Equipment

bull Wisconsin Public Service - Weston 4 bull AEP - Mitchell 1 and 2 bull BampW 530 MW Supercritical Boiler bull 2 x 800 MW Wet Scrubber Systems bull seR Dry Scrubber and Baghouse

babcock amp w il cox power generation group

StackCSAPR andUMACT Fabric Filter

Baghouse (Ash) DryFGD ScrubberCompliance

(502 )

StackEquipment

Scrubber (502 )

Electrostatic Precipitator (Ash)

Supercritical Boiler Coal

Pulverizer

babcock amp N il cox pONer generation group

A Complete Environmental Technology Portfolio

I I ~

-Total Solutions Provider

babcock amp vV il cox pONer generation group

US Bamp W Installed Capacity and Market Share

Wet Dry Fabric Wet FGD FGD Filter ESP

BampW Installed 19966 10023 8717 46607 2710Capacity (MW)

Market Share 28 49 21 32 35

babcock amp wi l cox power generation group

Environmental Equipment Forecast for US Power Companies

Industry Sources CapacIty In GIgawatts (GW) L H h ow 19 Scrubbers (FGO) 25 45 SCR (Oe-NOx) 15 25 Oirect Sorbent Injection (OSI) of PAC 100 200Trona etc Fabric Filter (FF) 75 175

Total in GW 215 445

B II f D 1 $ Industry Sources I Ions 0 0 ars L H how 19 Total in $ $12 $25

EPC value =$24 - 48 B BampW core scope (furnish and install) is $12 - 24 B

babcock amp w i lcox power generation group

Policy Goals for Environmental Compliance

bull Achieve environmental compliance bull Increase number of US jobs bull Minimize economic impact to rate payers bull Maintain reliability of electricity supply

Longer compliance schedule maximizes US jobs and still supports environmental stewardship

babcock amp vvilcox povver generation group

Timeline for Project Execution

Permitting RFQ and Contracting Phase

Takes one to two years before Engineer-Procure-Construct (EPC) project begins

Project Execution Phase ~E~~co ~ FabrtC~iItr (3~onthS)~~P amp Testing PC Spe~~=~~ F e~~0-35 M~~~

EPC Scope Dry FGD (30-36 Months) Startup amp Testing

amp Testing

EPCScop WI G ont ~ n amp Testing e et F D (40-42M hS) ~it ~~

babcock amp wilcox power generation group

Short Compliance Deadlines Will Lead to Significant Challenges for Engineering PM and US Suppliers

45

tilt t- 40-- a ICI CIIuCII-_ 35-5 oS O)~ ~~ 30 t t -- ICI 25II) -5 t () CII c E 20 tamp ~g 15 O~ 11) 10t U ~ ~ ~()-- 5~Q

3 year Compliance Period In MACT sect112

Estimated High Capacity (Indicative Only)

Estimated Low

Field Construction Phase 2014 -2015

20182012 2013 2014 2015 2016 2017

babcock amp w il cox power generation group

Short Compliance Deadlines Will Lead to Significant Challenges for Engineering PM and US Suppliers

45

tilrr5 40- - CI3l u gt 355 Q

~~ 301IJtI r r - CI II 25 r3Q)Os 20-CQ)ro ~g 15 O~ 111shyr u 10 9 ~0 5~Q

3 year Compliance Period in MACT sect112

Estimated High Capacity (Indicative Only)

Estimated Low

1n1lACT Extension

Field Construction Phase

2012 2013 2014 2015 2016 2017 2018

babcock amp wilcox power generation group

Economic Impact of Major AQCS Project

Total Customer Project Cost $14B

Project Duration 4+ years

(Representative Sample of Large Project)

bull BampW Scope of Supply middot3 X 800 MW Wet FGD (core scope erected) bull 2 X 800 MW SCR retrofit (EPC)

bull BampW Supply = $ 400 M bull Engineering - 270 engineering

and material supply personnel bull Procurement

bull $ 81 M US procurement bull 10 states withgt $1 M in manufacturing

Iservices supplied bull Supply chain spanned over 20 states bull Equipment Supply

bull Construction bull Core scope Wet FGD = 500000 man hours bull EPC SCR = 1000000 manhours

babcock amp wilcox power generation group

Economic Impact of Major AQCS Project (Representative Sample of Large Project)

bull Equipment supply bull Absorber trays bull Agitators bull Alloy headers bull Bolts bull Electrical wiring bull Piping engineering bull Gaskets bull Monitors bull Pressure transmitters bull Pumps bull Steel plate bull Structural steel bull Ball and plug valves10 states withgt $1M in manufacturingservices supplied

States with lt $1M in manufacturingservices supplied

babcock amp wilcox power generation group

Construction Installation Services to Meet Regulatory Demand

babcock amp wilcox power generation group

BampW is a Major US Employer of Boilermaker Union Craft

bull One of top three boilermaker employers every year for last ten years

bull Top tier power plant constructor

Boilermaker union craft is the single largest union craft employed on power and emissions control projects nationwide

babcock amp wilcox power generation group

Total Boilermaker Man-Hour Forecast 3 year compliance schedule requires 16 more man-hours than highest recent peak

Man-hours (Millions)

~~~~~~~~~~~~~~~~~~~~ ~~~~~~~~~~~~~~~~~~~~

50 45 40 35 30 25 20 15 10

5 o

babcock amp wilcox power generation group

Construction Challenges in Meeting Regulatory Demand

bull Demands on craft labor will be significant - particularly on a regional basis

bull Time for implementation is too short

bull Project execution risk increases - safety quality cost

bull Although best practice mitigation strategies will be deployed results are questionable in meeting cost and schedule requirements given current UMACT compressed timeframe

babcock amp w il cox p o wer generation group

BampW Comments to EPA on Utility MACT

J~ ltgtU ~ ~ ~ ~

~~-_ ~ - - B~W

t Liipound7-- shyI~ _~ NyenltI_G lt1W~tOC-

- -_ - ~ ~

bull BampW reviewed the proposed Utility MACT rule and provided detailed comments

bull Proposed limits on new and reconstructed units too stringent

bull Some proposed limits on new and reconstructed units lower than capabilities of reference test methods

babcock amp w il cox power generation g oup

UMACT for New Units (NSPS)

45 of all US electricity is generated from coal from only 30 of installed US generation capacity bull Competitively priced long term bull 2417 availability (base load) bull Clean source of generation - virtually all plants will be clean

by 2015-2018 because of Utility MACTCSAPR bull Large jobs generator (mining railroad Boilermaker union construction

engineering manufacturing plant operations etc)

No new coal powered plants will be built in US under proposed rule emission limits bull BampW knows of no technology or combination of technologies commercially

available worldwide to achieve Total PM Hg and HCI emission limits bull Proposed limits are approximately an order of magnitude lower than what can

reliably be achieved by current technology bull Proposal is based on very low measured emissions at single units which are

believed to be the result of site-specific interactions of fuels test equipment and operations not regularly reproducible For example proposed limits are near the limits of detection of the measurement methods

babcock amp wi l cox power generation group

Challenges to Achieve Environmental Compliance reg Three year UMACT compliance period cannot be fulfilled

due to large number and duration of major projects

reg Attempts to meet UMACT three year compliance

reg Will drive extensive US manufacturing engineering and project management jobs offshore

reg Will increase risk substantially for project cost schedule completion and safety

reg There is insufficient experienced field craft to construct the required projects within three year period

reg UMACT emissions requirements for new installations cannot be met with current technology - no new coal based power plant will be built in the US under the proposed emission limits

reg As a major environmental system supplier BampW urges consideration for a six year compliance period

Page 9: Utility MACT Regulation Briefing - whitehouse.gov · Utility MACT Regulation Briefing . November 10, 2011 . Rich Killion . B&W Power Generation Group ... Scrubber (50. 2) Equipment

babcock amp w il cox power generation group

StackCSAPR andUMACT Fabric Filter

Baghouse (Ash) DryFGD ScrubberCompliance

(502 )

StackEquipment

Scrubber (502 )

Electrostatic Precipitator (Ash)

Supercritical Boiler Coal

Pulverizer

babcock amp N il cox pONer generation group

A Complete Environmental Technology Portfolio

I I ~

-Total Solutions Provider

babcock amp vV il cox pONer generation group

US Bamp W Installed Capacity and Market Share

Wet Dry Fabric Wet FGD FGD Filter ESP

BampW Installed 19966 10023 8717 46607 2710Capacity (MW)

Market Share 28 49 21 32 35

babcock amp wi l cox power generation group

Environmental Equipment Forecast for US Power Companies

Industry Sources CapacIty In GIgawatts (GW) L H h ow 19 Scrubbers (FGO) 25 45 SCR (Oe-NOx) 15 25 Oirect Sorbent Injection (OSI) of PAC 100 200Trona etc Fabric Filter (FF) 75 175

Total in GW 215 445

B II f D 1 $ Industry Sources I Ions 0 0 ars L H how 19 Total in $ $12 $25

EPC value =$24 - 48 B BampW core scope (furnish and install) is $12 - 24 B

babcock amp w i lcox power generation group

Policy Goals for Environmental Compliance

bull Achieve environmental compliance bull Increase number of US jobs bull Minimize economic impact to rate payers bull Maintain reliability of electricity supply

Longer compliance schedule maximizes US jobs and still supports environmental stewardship

babcock amp vvilcox povver generation group

Timeline for Project Execution

Permitting RFQ and Contracting Phase

Takes one to two years before Engineer-Procure-Construct (EPC) project begins

Project Execution Phase ~E~~co ~ FabrtC~iItr (3~onthS)~~P amp Testing PC Spe~~=~~ F e~~0-35 M~~~

EPC Scope Dry FGD (30-36 Months) Startup amp Testing

amp Testing

EPCScop WI G ont ~ n amp Testing e et F D (40-42M hS) ~it ~~

babcock amp wilcox power generation group

Short Compliance Deadlines Will Lead to Significant Challenges for Engineering PM and US Suppliers

45

tilt t- 40-- a ICI CIIuCII-_ 35-5 oS O)~ ~~ 30 t t -- ICI 25II) -5 t () CII c E 20 tamp ~g 15 O~ 11) 10t U ~ ~ ~()-- 5~Q

3 year Compliance Period In MACT sect112

Estimated High Capacity (Indicative Only)

Estimated Low

Field Construction Phase 2014 -2015

20182012 2013 2014 2015 2016 2017

babcock amp w il cox power generation group

Short Compliance Deadlines Will Lead to Significant Challenges for Engineering PM and US Suppliers

45

tilrr5 40- - CI3l u gt 355 Q

~~ 301IJtI r r - CI II 25 r3Q)Os 20-CQ)ro ~g 15 O~ 111shyr u 10 9 ~0 5~Q

3 year Compliance Period in MACT sect112

Estimated High Capacity (Indicative Only)

Estimated Low

1n1lACT Extension

Field Construction Phase

2012 2013 2014 2015 2016 2017 2018

babcock amp wilcox power generation group

Economic Impact of Major AQCS Project

Total Customer Project Cost $14B

Project Duration 4+ years

(Representative Sample of Large Project)

bull BampW Scope of Supply middot3 X 800 MW Wet FGD (core scope erected) bull 2 X 800 MW SCR retrofit (EPC)

bull BampW Supply = $ 400 M bull Engineering - 270 engineering

and material supply personnel bull Procurement

bull $ 81 M US procurement bull 10 states withgt $1 M in manufacturing

Iservices supplied bull Supply chain spanned over 20 states bull Equipment Supply

bull Construction bull Core scope Wet FGD = 500000 man hours bull EPC SCR = 1000000 manhours

babcock amp wilcox power generation group

Economic Impact of Major AQCS Project (Representative Sample of Large Project)

bull Equipment supply bull Absorber trays bull Agitators bull Alloy headers bull Bolts bull Electrical wiring bull Piping engineering bull Gaskets bull Monitors bull Pressure transmitters bull Pumps bull Steel plate bull Structural steel bull Ball and plug valves10 states withgt $1M in manufacturingservices supplied

States with lt $1M in manufacturingservices supplied

babcock amp wilcox power generation group

Construction Installation Services to Meet Regulatory Demand

babcock amp wilcox power generation group

BampW is a Major US Employer of Boilermaker Union Craft

bull One of top three boilermaker employers every year for last ten years

bull Top tier power plant constructor

Boilermaker union craft is the single largest union craft employed on power and emissions control projects nationwide

babcock amp wilcox power generation group

Total Boilermaker Man-Hour Forecast 3 year compliance schedule requires 16 more man-hours than highest recent peak

Man-hours (Millions)

~~~~~~~~~~~~~~~~~~~~ ~~~~~~~~~~~~~~~~~~~~

50 45 40 35 30 25 20 15 10

5 o

babcock amp wilcox power generation group

Construction Challenges in Meeting Regulatory Demand

bull Demands on craft labor will be significant - particularly on a regional basis

bull Time for implementation is too short

bull Project execution risk increases - safety quality cost

bull Although best practice mitigation strategies will be deployed results are questionable in meeting cost and schedule requirements given current UMACT compressed timeframe

babcock amp w il cox p o wer generation group

BampW Comments to EPA on Utility MACT

J~ ltgtU ~ ~ ~ ~

~~-_ ~ - - B~W

t Liipound7-- shyI~ _~ NyenltI_G lt1W~tOC-

- -_ - ~ ~

bull BampW reviewed the proposed Utility MACT rule and provided detailed comments

bull Proposed limits on new and reconstructed units too stringent

bull Some proposed limits on new and reconstructed units lower than capabilities of reference test methods

babcock amp w il cox power generation g oup

UMACT for New Units (NSPS)

45 of all US electricity is generated from coal from only 30 of installed US generation capacity bull Competitively priced long term bull 2417 availability (base load) bull Clean source of generation - virtually all plants will be clean

by 2015-2018 because of Utility MACTCSAPR bull Large jobs generator (mining railroad Boilermaker union construction

engineering manufacturing plant operations etc)

No new coal powered plants will be built in US under proposed rule emission limits bull BampW knows of no technology or combination of technologies commercially

available worldwide to achieve Total PM Hg and HCI emission limits bull Proposed limits are approximately an order of magnitude lower than what can

reliably be achieved by current technology bull Proposal is based on very low measured emissions at single units which are

believed to be the result of site-specific interactions of fuels test equipment and operations not regularly reproducible For example proposed limits are near the limits of detection of the measurement methods

babcock amp wi l cox power generation group

Challenges to Achieve Environmental Compliance reg Three year UMACT compliance period cannot be fulfilled

due to large number and duration of major projects

reg Attempts to meet UMACT three year compliance

reg Will drive extensive US manufacturing engineering and project management jobs offshore

reg Will increase risk substantially for project cost schedule completion and safety

reg There is insufficient experienced field craft to construct the required projects within three year period

reg UMACT emissions requirements for new installations cannot be met with current technology - no new coal based power plant will be built in the US under the proposed emission limits

reg As a major environmental system supplier BampW urges consideration for a six year compliance period

Page 10: Utility MACT Regulation Briefing - whitehouse.gov · Utility MACT Regulation Briefing . November 10, 2011 . Rich Killion . B&W Power Generation Group ... Scrubber (50. 2) Equipment

babcock amp N il cox pONer generation group

A Complete Environmental Technology Portfolio

I I ~

-Total Solutions Provider

babcock amp vV il cox pONer generation group

US Bamp W Installed Capacity and Market Share

Wet Dry Fabric Wet FGD FGD Filter ESP

BampW Installed 19966 10023 8717 46607 2710Capacity (MW)

Market Share 28 49 21 32 35

babcock amp wi l cox power generation group

Environmental Equipment Forecast for US Power Companies

Industry Sources CapacIty In GIgawatts (GW) L H h ow 19 Scrubbers (FGO) 25 45 SCR (Oe-NOx) 15 25 Oirect Sorbent Injection (OSI) of PAC 100 200Trona etc Fabric Filter (FF) 75 175

Total in GW 215 445

B II f D 1 $ Industry Sources I Ions 0 0 ars L H how 19 Total in $ $12 $25

EPC value =$24 - 48 B BampW core scope (furnish and install) is $12 - 24 B

babcock amp w i lcox power generation group

Policy Goals for Environmental Compliance

bull Achieve environmental compliance bull Increase number of US jobs bull Minimize economic impact to rate payers bull Maintain reliability of electricity supply

Longer compliance schedule maximizes US jobs and still supports environmental stewardship

babcock amp vvilcox povver generation group

Timeline for Project Execution

Permitting RFQ and Contracting Phase

Takes one to two years before Engineer-Procure-Construct (EPC) project begins

Project Execution Phase ~E~~co ~ FabrtC~iItr (3~onthS)~~P amp Testing PC Spe~~=~~ F e~~0-35 M~~~

EPC Scope Dry FGD (30-36 Months) Startup amp Testing

amp Testing

EPCScop WI G ont ~ n amp Testing e et F D (40-42M hS) ~it ~~

babcock amp wilcox power generation group

Short Compliance Deadlines Will Lead to Significant Challenges for Engineering PM and US Suppliers

45

tilt t- 40-- a ICI CIIuCII-_ 35-5 oS O)~ ~~ 30 t t -- ICI 25II) -5 t () CII c E 20 tamp ~g 15 O~ 11) 10t U ~ ~ ~()-- 5~Q

3 year Compliance Period In MACT sect112

Estimated High Capacity (Indicative Only)

Estimated Low

Field Construction Phase 2014 -2015

20182012 2013 2014 2015 2016 2017

babcock amp w il cox power generation group

Short Compliance Deadlines Will Lead to Significant Challenges for Engineering PM and US Suppliers

45

tilrr5 40- - CI3l u gt 355 Q

~~ 301IJtI r r - CI II 25 r3Q)Os 20-CQ)ro ~g 15 O~ 111shyr u 10 9 ~0 5~Q

3 year Compliance Period in MACT sect112

Estimated High Capacity (Indicative Only)

Estimated Low

1n1lACT Extension

Field Construction Phase

2012 2013 2014 2015 2016 2017 2018

babcock amp wilcox power generation group

Economic Impact of Major AQCS Project

Total Customer Project Cost $14B

Project Duration 4+ years

(Representative Sample of Large Project)

bull BampW Scope of Supply middot3 X 800 MW Wet FGD (core scope erected) bull 2 X 800 MW SCR retrofit (EPC)

bull BampW Supply = $ 400 M bull Engineering - 270 engineering

and material supply personnel bull Procurement

bull $ 81 M US procurement bull 10 states withgt $1 M in manufacturing

Iservices supplied bull Supply chain spanned over 20 states bull Equipment Supply

bull Construction bull Core scope Wet FGD = 500000 man hours bull EPC SCR = 1000000 manhours

babcock amp wilcox power generation group

Economic Impact of Major AQCS Project (Representative Sample of Large Project)

bull Equipment supply bull Absorber trays bull Agitators bull Alloy headers bull Bolts bull Electrical wiring bull Piping engineering bull Gaskets bull Monitors bull Pressure transmitters bull Pumps bull Steel plate bull Structural steel bull Ball and plug valves10 states withgt $1M in manufacturingservices supplied

States with lt $1M in manufacturingservices supplied

babcock amp wilcox power generation group

Construction Installation Services to Meet Regulatory Demand

babcock amp wilcox power generation group

BampW is a Major US Employer of Boilermaker Union Craft

bull One of top three boilermaker employers every year for last ten years

bull Top tier power plant constructor

Boilermaker union craft is the single largest union craft employed on power and emissions control projects nationwide

babcock amp wilcox power generation group

Total Boilermaker Man-Hour Forecast 3 year compliance schedule requires 16 more man-hours than highest recent peak

Man-hours (Millions)

~~~~~~~~~~~~~~~~~~~~ ~~~~~~~~~~~~~~~~~~~~

50 45 40 35 30 25 20 15 10

5 o

babcock amp wilcox power generation group

Construction Challenges in Meeting Regulatory Demand

bull Demands on craft labor will be significant - particularly on a regional basis

bull Time for implementation is too short

bull Project execution risk increases - safety quality cost

bull Although best practice mitigation strategies will be deployed results are questionable in meeting cost and schedule requirements given current UMACT compressed timeframe

babcock amp w il cox p o wer generation group

BampW Comments to EPA on Utility MACT

J~ ltgtU ~ ~ ~ ~

~~-_ ~ - - B~W

t Liipound7-- shyI~ _~ NyenltI_G lt1W~tOC-

- -_ - ~ ~

bull BampW reviewed the proposed Utility MACT rule and provided detailed comments

bull Proposed limits on new and reconstructed units too stringent

bull Some proposed limits on new and reconstructed units lower than capabilities of reference test methods

babcock amp w il cox power generation g oup

UMACT for New Units (NSPS)

45 of all US electricity is generated from coal from only 30 of installed US generation capacity bull Competitively priced long term bull 2417 availability (base load) bull Clean source of generation - virtually all plants will be clean

by 2015-2018 because of Utility MACTCSAPR bull Large jobs generator (mining railroad Boilermaker union construction

engineering manufacturing plant operations etc)

No new coal powered plants will be built in US under proposed rule emission limits bull BampW knows of no technology or combination of technologies commercially

available worldwide to achieve Total PM Hg and HCI emission limits bull Proposed limits are approximately an order of magnitude lower than what can

reliably be achieved by current technology bull Proposal is based on very low measured emissions at single units which are

believed to be the result of site-specific interactions of fuels test equipment and operations not regularly reproducible For example proposed limits are near the limits of detection of the measurement methods

babcock amp wi l cox power generation group

Challenges to Achieve Environmental Compliance reg Three year UMACT compliance period cannot be fulfilled

due to large number and duration of major projects

reg Attempts to meet UMACT three year compliance

reg Will drive extensive US manufacturing engineering and project management jobs offshore

reg Will increase risk substantially for project cost schedule completion and safety

reg There is insufficient experienced field craft to construct the required projects within three year period

reg UMACT emissions requirements for new installations cannot be met with current technology - no new coal based power plant will be built in the US under the proposed emission limits

reg As a major environmental system supplier BampW urges consideration for a six year compliance period

Page 11: Utility MACT Regulation Briefing - whitehouse.gov · Utility MACT Regulation Briefing . November 10, 2011 . Rich Killion . B&W Power Generation Group ... Scrubber (50. 2) Equipment

babcock amp vV il cox pONer generation group

US Bamp W Installed Capacity and Market Share

Wet Dry Fabric Wet FGD FGD Filter ESP

BampW Installed 19966 10023 8717 46607 2710Capacity (MW)

Market Share 28 49 21 32 35

babcock amp wi l cox power generation group

Environmental Equipment Forecast for US Power Companies

Industry Sources CapacIty In GIgawatts (GW) L H h ow 19 Scrubbers (FGO) 25 45 SCR (Oe-NOx) 15 25 Oirect Sorbent Injection (OSI) of PAC 100 200Trona etc Fabric Filter (FF) 75 175

Total in GW 215 445

B II f D 1 $ Industry Sources I Ions 0 0 ars L H how 19 Total in $ $12 $25

EPC value =$24 - 48 B BampW core scope (furnish and install) is $12 - 24 B

babcock amp w i lcox power generation group

Policy Goals for Environmental Compliance

bull Achieve environmental compliance bull Increase number of US jobs bull Minimize economic impact to rate payers bull Maintain reliability of electricity supply

Longer compliance schedule maximizes US jobs and still supports environmental stewardship

babcock amp vvilcox povver generation group

Timeline for Project Execution

Permitting RFQ and Contracting Phase

Takes one to two years before Engineer-Procure-Construct (EPC) project begins

Project Execution Phase ~E~~co ~ FabrtC~iItr (3~onthS)~~P amp Testing PC Spe~~=~~ F e~~0-35 M~~~

EPC Scope Dry FGD (30-36 Months) Startup amp Testing

amp Testing

EPCScop WI G ont ~ n amp Testing e et F D (40-42M hS) ~it ~~

babcock amp wilcox power generation group

Short Compliance Deadlines Will Lead to Significant Challenges for Engineering PM and US Suppliers

45

tilt t- 40-- a ICI CIIuCII-_ 35-5 oS O)~ ~~ 30 t t -- ICI 25II) -5 t () CII c E 20 tamp ~g 15 O~ 11) 10t U ~ ~ ~()-- 5~Q

3 year Compliance Period In MACT sect112

Estimated High Capacity (Indicative Only)

Estimated Low

Field Construction Phase 2014 -2015

20182012 2013 2014 2015 2016 2017

babcock amp w il cox power generation group

Short Compliance Deadlines Will Lead to Significant Challenges for Engineering PM and US Suppliers

45

tilrr5 40- - CI3l u gt 355 Q

~~ 301IJtI r r - CI II 25 r3Q)Os 20-CQ)ro ~g 15 O~ 111shyr u 10 9 ~0 5~Q

3 year Compliance Period in MACT sect112

Estimated High Capacity (Indicative Only)

Estimated Low

1n1lACT Extension

Field Construction Phase

2012 2013 2014 2015 2016 2017 2018

babcock amp wilcox power generation group

Economic Impact of Major AQCS Project

Total Customer Project Cost $14B

Project Duration 4+ years

(Representative Sample of Large Project)

bull BampW Scope of Supply middot3 X 800 MW Wet FGD (core scope erected) bull 2 X 800 MW SCR retrofit (EPC)

bull BampW Supply = $ 400 M bull Engineering - 270 engineering

and material supply personnel bull Procurement

bull $ 81 M US procurement bull 10 states withgt $1 M in manufacturing

Iservices supplied bull Supply chain spanned over 20 states bull Equipment Supply

bull Construction bull Core scope Wet FGD = 500000 man hours bull EPC SCR = 1000000 manhours

babcock amp wilcox power generation group

Economic Impact of Major AQCS Project (Representative Sample of Large Project)

bull Equipment supply bull Absorber trays bull Agitators bull Alloy headers bull Bolts bull Electrical wiring bull Piping engineering bull Gaskets bull Monitors bull Pressure transmitters bull Pumps bull Steel plate bull Structural steel bull Ball and plug valves10 states withgt $1M in manufacturingservices supplied

States with lt $1M in manufacturingservices supplied

babcock amp wilcox power generation group

Construction Installation Services to Meet Regulatory Demand

babcock amp wilcox power generation group

BampW is a Major US Employer of Boilermaker Union Craft

bull One of top three boilermaker employers every year for last ten years

bull Top tier power plant constructor

Boilermaker union craft is the single largest union craft employed on power and emissions control projects nationwide

babcock amp wilcox power generation group

Total Boilermaker Man-Hour Forecast 3 year compliance schedule requires 16 more man-hours than highest recent peak

Man-hours (Millions)

~~~~~~~~~~~~~~~~~~~~ ~~~~~~~~~~~~~~~~~~~~

50 45 40 35 30 25 20 15 10

5 o

babcock amp wilcox power generation group

Construction Challenges in Meeting Regulatory Demand

bull Demands on craft labor will be significant - particularly on a regional basis

bull Time for implementation is too short

bull Project execution risk increases - safety quality cost

bull Although best practice mitigation strategies will be deployed results are questionable in meeting cost and schedule requirements given current UMACT compressed timeframe

babcock amp w il cox p o wer generation group

BampW Comments to EPA on Utility MACT

J~ ltgtU ~ ~ ~ ~

~~-_ ~ - - B~W

t Liipound7-- shyI~ _~ NyenltI_G lt1W~tOC-

- -_ - ~ ~

bull BampW reviewed the proposed Utility MACT rule and provided detailed comments

bull Proposed limits on new and reconstructed units too stringent

bull Some proposed limits on new and reconstructed units lower than capabilities of reference test methods

babcock amp w il cox power generation g oup

UMACT for New Units (NSPS)

45 of all US electricity is generated from coal from only 30 of installed US generation capacity bull Competitively priced long term bull 2417 availability (base load) bull Clean source of generation - virtually all plants will be clean

by 2015-2018 because of Utility MACTCSAPR bull Large jobs generator (mining railroad Boilermaker union construction

engineering manufacturing plant operations etc)

No new coal powered plants will be built in US under proposed rule emission limits bull BampW knows of no technology or combination of technologies commercially

available worldwide to achieve Total PM Hg and HCI emission limits bull Proposed limits are approximately an order of magnitude lower than what can

reliably be achieved by current technology bull Proposal is based on very low measured emissions at single units which are

believed to be the result of site-specific interactions of fuels test equipment and operations not regularly reproducible For example proposed limits are near the limits of detection of the measurement methods

babcock amp wi l cox power generation group

Challenges to Achieve Environmental Compliance reg Three year UMACT compliance period cannot be fulfilled

due to large number and duration of major projects

reg Attempts to meet UMACT three year compliance

reg Will drive extensive US manufacturing engineering and project management jobs offshore

reg Will increase risk substantially for project cost schedule completion and safety

reg There is insufficient experienced field craft to construct the required projects within three year period

reg UMACT emissions requirements for new installations cannot be met with current technology - no new coal based power plant will be built in the US under the proposed emission limits

reg As a major environmental system supplier BampW urges consideration for a six year compliance period

Page 12: Utility MACT Regulation Briefing - whitehouse.gov · Utility MACT Regulation Briefing . November 10, 2011 . Rich Killion . B&W Power Generation Group ... Scrubber (50. 2) Equipment

babcock amp wi l cox power generation group

Environmental Equipment Forecast for US Power Companies

Industry Sources CapacIty In GIgawatts (GW) L H h ow 19 Scrubbers (FGO) 25 45 SCR (Oe-NOx) 15 25 Oirect Sorbent Injection (OSI) of PAC 100 200Trona etc Fabric Filter (FF) 75 175

Total in GW 215 445

B II f D 1 $ Industry Sources I Ions 0 0 ars L H how 19 Total in $ $12 $25

EPC value =$24 - 48 B BampW core scope (furnish and install) is $12 - 24 B

babcock amp w i lcox power generation group

Policy Goals for Environmental Compliance

bull Achieve environmental compliance bull Increase number of US jobs bull Minimize economic impact to rate payers bull Maintain reliability of electricity supply

Longer compliance schedule maximizes US jobs and still supports environmental stewardship

babcock amp vvilcox povver generation group

Timeline for Project Execution

Permitting RFQ and Contracting Phase

Takes one to two years before Engineer-Procure-Construct (EPC) project begins

Project Execution Phase ~E~~co ~ FabrtC~iItr (3~onthS)~~P amp Testing PC Spe~~=~~ F e~~0-35 M~~~

EPC Scope Dry FGD (30-36 Months) Startup amp Testing

amp Testing

EPCScop WI G ont ~ n amp Testing e et F D (40-42M hS) ~it ~~

babcock amp wilcox power generation group

Short Compliance Deadlines Will Lead to Significant Challenges for Engineering PM and US Suppliers

45

tilt t- 40-- a ICI CIIuCII-_ 35-5 oS O)~ ~~ 30 t t -- ICI 25II) -5 t () CII c E 20 tamp ~g 15 O~ 11) 10t U ~ ~ ~()-- 5~Q

3 year Compliance Period In MACT sect112

Estimated High Capacity (Indicative Only)

Estimated Low

Field Construction Phase 2014 -2015

20182012 2013 2014 2015 2016 2017

babcock amp w il cox power generation group

Short Compliance Deadlines Will Lead to Significant Challenges for Engineering PM and US Suppliers

45

tilrr5 40- - CI3l u gt 355 Q

~~ 301IJtI r r - CI II 25 r3Q)Os 20-CQ)ro ~g 15 O~ 111shyr u 10 9 ~0 5~Q

3 year Compliance Period in MACT sect112

Estimated High Capacity (Indicative Only)

Estimated Low

1n1lACT Extension

Field Construction Phase

2012 2013 2014 2015 2016 2017 2018

babcock amp wilcox power generation group

Economic Impact of Major AQCS Project

Total Customer Project Cost $14B

Project Duration 4+ years

(Representative Sample of Large Project)

bull BampW Scope of Supply middot3 X 800 MW Wet FGD (core scope erected) bull 2 X 800 MW SCR retrofit (EPC)

bull BampW Supply = $ 400 M bull Engineering - 270 engineering

and material supply personnel bull Procurement

bull $ 81 M US procurement bull 10 states withgt $1 M in manufacturing

Iservices supplied bull Supply chain spanned over 20 states bull Equipment Supply

bull Construction bull Core scope Wet FGD = 500000 man hours bull EPC SCR = 1000000 manhours

babcock amp wilcox power generation group

Economic Impact of Major AQCS Project (Representative Sample of Large Project)

bull Equipment supply bull Absorber trays bull Agitators bull Alloy headers bull Bolts bull Electrical wiring bull Piping engineering bull Gaskets bull Monitors bull Pressure transmitters bull Pumps bull Steel plate bull Structural steel bull Ball and plug valves10 states withgt $1M in manufacturingservices supplied

States with lt $1M in manufacturingservices supplied

babcock amp wilcox power generation group

Construction Installation Services to Meet Regulatory Demand

babcock amp wilcox power generation group

BampW is a Major US Employer of Boilermaker Union Craft

bull One of top three boilermaker employers every year for last ten years

bull Top tier power plant constructor

Boilermaker union craft is the single largest union craft employed on power and emissions control projects nationwide

babcock amp wilcox power generation group

Total Boilermaker Man-Hour Forecast 3 year compliance schedule requires 16 more man-hours than highest recent peak

Man-hours (Millions)

~~~~~~~~~~~~~~~~~~~~ ~~~~~~~~~~~~~~~~~~~~

50 45 40 35 30 25 20 15 10

5 o

babcock amp wilcox power generation group

Construction Challenges in Meeting Regulatory Demand

bull Demands on craft labor will be significant - particularly on a regional basis

bull Time for implementation is too short

bull Project execution risk increases - safety quality cost

bull Although best practice mitigation strategies will be deployed results are questionable in meeting cost and schedule requirements given current UMACT compressed timeframe

babcock amp w il cox p o wer generation group

BampW Comments to EPA on Utility MACT

J~ ltgtU ~ ~ ~ ~

~~-_ ~ - - B~W

t Liipound7-- shyI~ _~ NyenltI_G lt1W~tOC-

- -_ - ~ ~

bull BampW reviewed the proposed Utility MACT rule and provided detailed comments

bull Proposed limits on new and reconstructed units too stringent

bull Some proposed limits on new and reconstructed units lower than capabilities of reference test methods

babcock amp w il cox power generation g oup

UMACT for New Units (NSPS)

45 of all US electricity is generated from coal from only 30 of installed US generation capacity bull Competitively priced long term bull 2417 availability (base load) bull Clean source of generation - virtually all plants will be clean

by 2015-2018 because of Utility MACTCSAPR bull Large jobs generator (mining railroad Boilermaker union construction

engineering manufacturing plant operations etc)

No new coal powered plants will be built in US under proposed rule emission limits bull BampW knows of no technology or combination of technologies commercially

available worldwide to achieve Total PM Hg and HCI emission limits bull Proposed limits are approximately an order of magnitude lower than what can

reliably be achieved by current technology bull Proposal is based on very low measured emissions at single units which are

believed to be the result of site-specific interactions of fuels test equipment and operations not regularly reproducible For example proposed limits are near the limits of detection of the measurement methods

babcock amp wi l cox power generation group

Challenges to Achieve Environmental Compliance reg Three year UMACT compliance period cannot be fulfilled

due to large number and duration of major projects

reg Attempts to meet UMACT three year compliance

reg Will drive extensive US manufacturing engineering and project management jobs offshore

reg Will increase risk substantially for project cost schedule completion and safety

reg There is insufficient experienced field craft to construct the required projects within three year period

reg UMACT emissions requirements for new installations cannot be met with current technology - no new coal based power plant will be built in the US under the proposed emission limits

reg As a major environmental system supplier BampW urges consideration for a six year compliance period

Page 13: Utility MACT Regulation Briefing - whitehouse.gov · Utility MACT Regulation Briefing . November 10, 2011 . Rich Killion . B&W Power Generation Group ... Scrubber (50. 2) Equipment

babcock amp w i lcox power generation group

Policy Goals for Environmental Compliance

bull Achieve environmental compliance bull Increase number of US jobs bull Minimize economic impact to rate payers bull Maintain reliability of electricity supply

Longer compliance schedule maximizes US jobs and still supports environmental stewardship

babcock amp vvilcox povver generation group

Timeline for Project Execution

Permitting RFQ and Contracting Phase

Takes one to two years before Engineer-Procure-Construct (EPC) project begins

Project Execution Phase ~E~~co ~ FabrtC~iItr (3~onthS)~~P amp Testing PC Spe~~=~~ F e~~0-35 M~~~

EPC Scope Dry FGD (30-36 Months) Startup amp Testing

amp Testing

EPCScop WI G ont ~ n amp Testing e et F D (40-42M hS) ~it ~~

babcock amp wilcox power generation group

Short Compliance Deadlines Will Lead to Significant Challenges for Engineering PM and US Suppliers

45

tilt t- 40-- a ICI CIIuCII-_ 35-5 oS O)~ ~~ 30 t t -- ICI 25II) -5 t () CII c E 20 tamp ~g 15 O~ 11) 10t U ~ ~ ~()-- 5~Q

3 year Compliance Period In MACT sect112

Estimated High Capacity (Indicative Only)

Estimated Low

Field Construction Phase 2014 -2015

20182012 2013 2014 2015 2016 2017

babcock amp w il cox power generation group

Short Compliance Deadlines Will Lead to Significant Challenges for Engineering PM and US Suppliers

45

tilrr5 40- - CI3l u gt 355 Q

~~ 301IJtI r r - CI II 25 r3Q)Os 20-CQ)ro ~g 15 O~ 111shyr u 10 9 ~0 5~Q

3 year Compliance Period in MACT sect112

Estimated High Capacity (Indicative Only)

Estimated Low

1n1lACT Extension

Field Construction Phase

2012 2013 2014 2015 2016 2017 2018

babcock amp wilcox power generation group

Economic Impact of Major AQCS Project

Total Customer Project Cost $14B

Project Duration 4+ years

(Representative Sample of Large Project)

bull BampW Scope of Supply middot3 X 800 MW Wet FGD (core scope erected) bull 2 X 800 MW SCR retrofit (EPC)

bull BampW Supply = $ 400 M bull Engineering - 270 engineering

and material supply personnel bull Procurement

bull $ 81 M US procurement bull 10 states withgt $1 M in manufacturing

Iservices supplied bull Supply chain spanned over 20 states bull Equipment Supply

bull Construction bull Core scope Wet FGD = 500000 man hours bull EPC SCR = 1000000 manhours

babcock amp wilcox power generation group

Economic Impact of Major AQCS Project (Representative Sample of Large Project)

bull Equipment supply bull Absorber trays bull Agitators bull Alloy headers bull Bolts bull Electrical wiring bull Piping engineering bull Gaskets bull Monitors bull Pressure transmitters bull Pumps bull Steel plate bull Structural steel bull Ball and plug valves10 states withgt $1M in manufacturingservices supplied

States with lt $1M in manufacturingservices supplied

babcock amp wilcox power generation group

Construction Installation Services to Meet Regulatory Demand

babcock amp wilcox power generation group

BampW is a Major US Employer of Boilermaker Union Craft

bull One of top three boilermaker employers every year for last ten years

bull Top tier power plant constructor

Boilermaker union craft is the single largest union craft employed on power and emissions control projects nationwide

babcock amp wilcox power generation group

Total Boilermaker Man-Hour Forecast 3 year compliance schedule requires 16 more man-hours than highest recent peak

Man-hours (Millions)

~~~~~~~~~~~~~~~~~~~~ ~~~~~~~~~~~~~~~~~~~~

50 45 40 35 30 25 20 15 10

5 o

babcock amp wilcox power generation group

Construction Challenges in Meeting Regulatory Demand

bull Demands on craft labor will be significant - particularly on a regional basis

bull Time for implementation is too short

bull Project execution risk increases - safety quality cost

bull Although best practice mitigation strategies will be deployed results are questionable in meeting cost and schedule requirements given current UMACT compressed timeframe

babcock amp w il cox p o wer generation group

BampW Comments to EPA on Utility MACT

J~ ltgtU ~ ~ ~ ~

~~-_ ~ - - B~W

t Liipound7-- shyI~ _~ NyenltI_G lt1W~tOC-

- -_ - ~ ~

bull BampW reviewed the proposed Utility MACT rule and provided detailed comments

bull Proposed limits on new and reconstructed units too stringent

bull Some proposed limits on new and reconstructed units lower than capabilities of reference test methods

babcock amp w il cox power generation g oup

UMACT for New Units (NSPS)

45 of all US electricity is generated from coal from only 30 of installed US generation capacity bull Competitively priced long term bull 2417 availability (base load) bull Clean source of generation - virtually all plants will be clean

by 2015-2018 because of Utility MACTCSAPR bull Large jobs generator (mining railroad Boilermaker union construction

engineering manufacturing plant operations etc)

No new coal powered plants will be built in US under proposed rule emission limits bull BampW knows of no technology or combination of technologies commercially

available worldwide to achieve Total PM Hg and HCI emission limits bull Proposed limits are approximately an order of magnitude lower than what can

reliably be achieved by current technology bull Proposal is based on very low measured emissions at single units which are

believed to be the result of site-specific interactions of fuels test equipment and operations not regularly reproducible For example proposed limits are near the limits of detection of the measurement methods

babcock amp wi l cox power generation group

Challenges to Achieve Environmental Compliance reg Three year UMACT compliance period cannot be fulfilled

due to large number and duration of major projects

reg Attempts to meet UMACT three year compliance

reg Will drive extensive US manufacturing engineering and project management jobs offshore

reg Will increase risk substantially for project cost schedule completion and safety

reg There is insufficient experienced field craft to construct the required projects within three year period

reg UMACT emissions requirements for new installations cannot be met with current technology - no new coal based power plant will be built in the US under the proposed emission limits

reg As a major environmental system supplier BampW urges consideration for a six year compliance period

Page 14: Utility MACT Regulation Briefing - whitehouse.gov · Utility MACT Regulation Briefing . November 10, 2011 . Rich Killion . B&W Power Generation Group ... Scrubber (50. 2) Equipment

babcock amp vvilcox povver generation group

Timeline for Project Execution

Permitting RFQ and Contracting Phase

Takes one to two years before Engineer-Procure-Construct (EPC) project begins

Project Execution Phase ~E~~co ~ FabrtC~iItr (3~onthS)~~P amp Testing PC Spe~~=~~ F e~~0-35 M~~~

EPC Scope Dry FGD (30-36 Months) Startup amp Testing

amp Testing

EPCScop WI G ont ~ n amp Testing e et F D (40-42M hS) ~it ~~

babcock amp wilcox power generation group

Short Compliance Deadlines Will Lead to Significant Challenges for Engineering PM and US Suppliers

45

tilt t- 40-- a ICI CIIuCII-_ 35-5 oS O)~ ~~ 30 t t -- ICI 25II) -5 t () CII c E 20 tamp ~g 15 O~ 11) 10t U ~ ~ ~()-- 5~Q

3 year Compliance Period In MACT sect112

Estimated High Capacity (Indicative Only)

Estimated Low

Field Construction Phase 2014 -2015

20182012 2013 2014 2015 2016 2017

babcock amp w il cox power generation group

Short Compliance Deadlines Will Lead to Significant Challenges for Engineering PM and US Suppliers

45

tilrr5 40- - CI3l u gt 355 Q

~~ 301IJtI r r - CI II 25 r3Q)Os 20-CQ)ro ~g 15 O~ 111shyr u 10 9 ~0 5~Q

3 year Compliance Period in MACT sect112

Estimated High Capacity (Indicative Only)

Estimated Low

1n1lACT Extension

Field Construction Phase

2012 2013 2014 2015 2016 2017 2018

babcock amp wilcox power generation group

Economic Impact of Major AQCS Project

Total Customer Project Cost $14B

Project Duration 4+ years

(Representative Sample of Large Project)

bull BampW Scope of Supply middot3 X 800 MW Wet FGD (core scope erected) bull 2 X 800 MW SCR retrofit (EPC)

bull BampW Supply = $ 400 M bull Engineering - 270 engineering

and material supply personnel bull Procurement

bull $ 81 M US procurement bull 10 states withgt $1 M in manufacturing

Iservices supplied bull Supply chain spanned over 20 states bull Equipment Supply

bull Construction bull Core scope Wet FGD = 500000 man hours bull EPC SCR = 1000000 manhours

babcock amp wilcox power generation group

Economic Impact of Major AQCS Project (Representative Sample of Large Project)

bull Equipment supply bull Absorber trays bull Agitators bull Alloy headers bull Bolts bull Electrical wiring bull Piping engineering bull Gaskets bull Monitors bull Pressure transmitters bull Pumps bull Steel plate bull Structural steel bull Ball and plug valves10 states withgt $1M in manufacturingservices supplied

States with lt $1M in manufacturingservices supplied

babcock amp wilcox power generation group

Construction Installation Services to Meet Regulatory Demand

babcock amp wilcox power generation group

BampW is a Major US Employer of Boilermaker Union Craft

bull One of top three boilermaker employers every year for last ten years

bull Top tier power plant constructor

Boilermaker union craft is the single largest union craft employed on power and emissions control projects nationwide

babcock amp wilcox power generation group

Total Boilermaker Man-Hour Forecast 3 year compliance schedule requires 16 more man-hours than highest recent peak

Man-hours (Millions)

~~~~~~~~~~~~~~~~~~~~ ~~~~~~~~~~~~~~~~~~~~

50 45 40 35 30 25 20 15 10

5 o

babcock amp wilcox power generation group

Construction Challenges in Meeting Regulatory Demand

bull Demands on craft labor will be significant - particularly on a regional basis

bull Time for implementation is too short

bull Project execution risk increases - safety quality cost

bull Although best practice mitigation strategies will be deployed results are questionable in meeting cost and schedule requirements given current UMACT compressed timeframe

babcock amp w il cox p o wer generation group

BampW Comments to EPA on Utility MACT

J~ ltgtU ~ ~ ~ ~

~~-_ ~ - - B~W

t Liipound7-- shyI~ _~ NyenltI_G lt1W~tOC-

- -_ - ~ ~

bull BampW reviewed the proposed Utility MACT rule and provided detailed comments

bull Proposed limits on new and reconstructed units too stringent

bull Some proposed limits on new and reconstructed units lower than capabilities of reference test methods

babcock amp w il cox power generation g oup

UMACT for New Units (NSPS)

45 of all US electricity is generated from coal from only 30 of installed US generation capacity bull Competitively priced long term bull 2417 availability (base load) bull Clean source of generation - virtually all plants will be clean

by 2015-2018 because of Utility MACTCSAPR bull Large jobs generator (mining railroad Boilermaker union construction

engineering manufacturing plant operations etc)

No new coal powered plants will be built in US under proposed rule emission limits bull BampW knows of no technology or combination of technologies commercially

available worldwide to achieve Total PM Hg and HCI emission limits bull Proposed limits are approximately an order of magnitude lower than what can

reliably be achieved by current technology bull Proposal is based on very low measured emissions at single units which are

believed to be the result of site-specific interactions of fuels test equipment and operations not regularly reproducible For example proposed limits are near the limits of detection of the measurement methods

babcock amp wi l cox power generation group

Challenges to Achieve Environmental Compliance reg Three year UMACT compliance period cannot be fulfilled

due to large number and duration of major projects

reg Attempts to meet UMACT three year compliance

reg Will drive extensive US manufacturing engineering and project management jobs offshore

reg Will increase risk substantially for project cost schedule completion and safety

reg There is insufficient experienced field craft to construct the required projects within three year period

reg UMACT emissions requirements for new installations cannot be met with current technology - no new coal based power plant will be built in the US under the proposed emission limits

reg As a major environmental system supplier BampW urges consideration for a six year compliance period

Page 15: Utility MACT Regulation Briefing - whitehouse.gov · Utility MACT Regulation Briefing . November 10, 2011 . Rich Killion . B&W Power Generation Group ... Scrubber (50. 2) Equipment

babcock amp wilcox power generation group

Short Compliance Deadlines Will Lead to Significant Challenges for Engineering PM and US Suppliers

45

tilt t- 40-- a ICI CIIuCII-_ 35-5 oS O)~ ~~ 30 t t -- ICI 25II) -5 t () CII c E 20 tamp ~g 15 O~ 11) 10t U ~ ~ ~()-- 5~Q

3 year Compliance Period In MACT sect112

Estimated High Capacity (Indicative Only)

Estimated Low

Field Construction Phase 2014 -2015

20182012 2013 2014 2015 2016 2017

babcock amp w il cox power generation group

Short Compliance Deadlines Will Lead to Significant Challenges for Engineering PM and US Suppliers

45

tilrr5 40- - CI3l u gt 355 Q

~~ 301IJtI r r - CI II 25 r3Q)Os 20-CQ)ro ~g 15 O~ 111shyr u 10 9 ~0 5~Q

3 year Compliance Period in MACT sect112

Estimated High Capacity (Indicative Only)

Estimated Low

1n1lACT Extension

Field Construction Phase

2012 2013 2014 2015 2016 2017 2018

babcock amp wilcox power generation group

Economic Impact of Major AQCS Project

Total Customer Project Cost $14B

Project Duration 4+ years

(Representative Sample of Large Project)

bull BampW Scope of Supply middot3 X 800 MW Wet FGD (core scope erected) bull 2 X 800 MW SCR retrofit (EPC)

bull BampW Supply = $ 400 M bull Engineering - 270 engineering

and material supply personnel bull Procurement

bull $ 81 M US procurement bull 10 states withgt $1 M in manufacturing

Iservices supplied bull Supply chain spanned over 20 states bull Equipment Supply

bull Construction bull Core scope Wet FGD = 500000 man hours bull EPC SCR = 1000000 manhours

babcock amp wilcox power generation group

Economic Impact of Major AQCS Project (Representative Sample of Large Project)

bull Equipment supply bull Absorber trays bull Agitators bull Alloy headers bull Bolts bull Electrical wiring bull Piping engineering bull Gaskets bull Monitors bull Pressure transmitters bull Pumps bull Steel plate bull Structural steel bull Ball and plug valves10 states withgt $1M in manufacturingservices supplied

States with lt $1M in manufacturingservices supplied

babcock amp wilcox power generation group

Construction Installation Services to Meet Regulatory Demand

babcock amp wilcox power generation group

BampW is a Major US Employer of Boilermaker Union Craft

bull One of top three boilermaker employers every year for last ten years

bull Top tier power plant constructor

Boilermaker union craft is the single largest union craft employed on power and emissions control projects nationwide

babcock amp wilcox power generation group

Total Boilermaker Man-Hour Forecast 3 year compliance schedule requires 16 more man-hours than highest recent peak

Man-hours (Millions)

~~~~~~~~~~~~~~~~~~~~ ~~~~~~~~~~~~~~~~~~~~

50 45 40 35 30 25 20 15 10

5 o

babcock amp wilcox power generation group

Construction Challenges in Meeting Regulatory Demand

bull Demands on craft labor will be significant - particularly on a regional basis

bull Time for implementation is too short

bull Project execution risk increases - safety quality cost

bull Although best practice mitigation strategies will be deployed results are questionable in meeting cost and schedule requirements given current UMACT compressed timeframe

babcock amp w il cox p o wer generation group

BampW Comments to EPA on Utility MACT

J~ ltgtU ~ ~ ~ ~

~~-_ ~ - - B~W

t Liipound7-- shyI~ _~ NyenltI_G lt1W~tOC-

- -_ - ~ ~

bull BampW reviewed the proposed Utility MACT rule and provided detailed comments

bull Proposed limits on new and reconstructed units too stringent

bull Some proposed limits on new and reconstructed units lower than capabilities of reference test methods

babcock amp w il cox power generation g oup

UMACT for New Units (NSPS)

45 of all US electricity is generated from coal from only 30 of installed US generation capacity bull Competitively priced long term bull 2417 availability (base load) bull Clean source of generation - virtually all plants will be clean

by 2015-2018 because of Utility MACTCSAPR bull Large jobs generator (mining railroad Boilermaker union construction

engineering manufacturing plant operations etc)

No new coal powered plants will be built in US under proposed rule emission limits bull BampW knows of no technology or combination of technologies commercially

available worldwide to achieve Total PM Hg and HCI emission limits bull Proposed limits are approximately an order of magnitude lower than what can

reliably be achieved by current technology bull Proposal is based on very low measured emissions at single units which are

believed to be the result of site-specific interactions of fuels test equipment and operations not regularly reproducible For example proposed limits are near the limits of detection of the measurement methods

babcock amp wi l cox power generation group

Challenges to Achieve Environmental Compliance reg Three year UMACT compliance period cannot be fulfilled

due to large number and duration of major projects

reg Attempts to meet UMACT three year compliance

reg Will drive extensive US manufacturing engineering and project management jobs offshore

reg Will increase risk substantially for project cost schedule completion and safety

reg There is insufficient experienced field craft to construct the required projects within three year period

reg UMACT emissions requirements for new installations cannot be met with current technology - no new coal based power plant will be built in the US under the proposed emission limits

reg As a major environmental system supplier BampW urges consideration for a six year compliance period

Page 16: Utility MACT Regulation Briefing - whitehouse.gov · Utility MACT Regulation Briefing . November 10, 2011 . Rich Killion . B&W Power Generation Group ... Scrubber (50. 2) Equipment

babcock amp w il cox power generation group

Short Compliance Deadlines Will Lead to Significant Challenges for Engineering PM and US Suppliers

45

tilrr5 40- - CI3l u gt 355 Q

~~ 301IJtI r r - CI II 25 r3Q)Os 20-CQ)ro ~g 15 O~ 111shyr u 10 9 ~0 5~Q

3 year Compliance Period in MACT sect112

Estimated High Capacity (Indicative Only)

Estimated Low

1n1lACT Extension

Field Construction Phase

2012 2013 2014 2015 2016 2017 2018

babcock amp wilcox power generation group

Economic Impact of Major AQCS Project

Total Customer Project Cost $14B

Project Duration 4+ years

(Representative Sample of Large Project)

bull BampW Scope of Supply middot3 X 800 MW Wet FGD (core scope erected) bull 2 X 800 MW SCR retrofit (EPC)

bull BampW Supply = $ 400 M bull Engineering - 270 engineering

and material supply personnel bull Procurement

bull $ 81 M US procurement bull 10 states withgt $1 M in manufacturing

Iservices supplied bull Supply chain spanned over 20 states bull Equipment Supply

bull Construction bull Core scope Wet FGD = 500000 man hours bull EPC SCR = 1000000 manhours

babcock amp wilcox power generation group

Economic Impact of Major AQCS Project (Representative Sample of Large Project)

bull Equipment supply bull Absorber trays bull Agitators bull Alloy headers bull Bolts bull Electrical wiring bull Piping engineering bull Gaskets bull Monitors bull Pressure transmitters bull Pumps bull Steel plate bull Structural steel bull Ball and plug valves10 states withgt $1M in manufacturingservices supplied

States with lt $1M in manufacturingservices supplied

babcock amp wilcox power generation group

Construction Installation Services to Meet Regulatory Demand

babcock amp wilcox power generation group

BampW is a Major US Employer of Boilermaker Union Craft

bull One of top three boilermaker employers every year for last ten years

bull Top tier power plant constructor

Boilermaker union craft is the single largest union craft employed on power and emissions control projects nationwide

babcock amp wilcox power generation group

Total Boilermaker Man-Hour Forecast 3 year compliance schedule requires 16 more man-hours than highest recent peak

Man-hours (Millions)

~~~~~~~~~~~~~~~~~~~~ ~~~~~~~~~~~~~~~~~~~~

50 45 40 35 30 25 20 15 10

5 o

babcock amp wilcox power generation group

Construction Challenges in Meeting Regulatory Demand

bull Demands on craft labor will be significant - particularly on a regional basis

bull Time for implementation is too short

bull Project execution risk increases - safety quality cost

bull Although best practice mitigation strategies will be deployed results are questionable in meeting cost and schedule requirements given current UMACT compressed timeframe

babcock amp w il cox p o wer generation group

BampW Comments to EPA on Utility MACT

J~ ltgtU ~ ~ ~ ~

~~-_ ~ - - B~W

t Liipound7-- shyI~ _~ NyenltI_G lt1W~tOC-

- -_ - ~ ~

bull BampW reviewed the proposed Utility MACT rule and provided detailed comments

bull Proposed limits on new and reconstructed units too stringent

bull Some proposed limits on new and reconstructed units lower than capabilities of reference test methods

babcock amp w il cox power generation g oup

UMACT for New Units (NSPS)

45 of all US electricity is generated from coal from only 30 of installed US generation capacity bull Competitively priced long term bull 2417 availability (base load) bull Clean source of generation - virtually all plants will be clean

by 2015-2018 because of Utility MACTCSAPR bull Large jobs generator (mining railroad Boilermaker union construction

engineering manufacturing plant operations etc)

No new coal powered plants will be built in US under proposed rule emission limits bull BampW knows of no technology or combination of technologies commercially

available worldwide to achieve Total PM Hg and HCI emission limits bull Proposed limits are approximately an order of magnitude lower than what can

reliably be achieved by current technology bull Proposal is based on very low measured emissions at single units which are

believed to be the result of site-specific interactions of fuels test equipment and operations not regularly reproducible For example proposed limits are near the limits of detection of the measurement methods

babcock amp wi l cox power generation group

Challenges to Achieve Environmental Compliance reg Three year UMACT compliance period cannot be fulfilled

due to large number and duration of major projects

reg Attempts to meet UMACT three year compliance

reg Will drive extensive US manufacturing engineering and project management jobs offshore

reg Will increase risk substantially for project cost schedule completion and safety

reg There is insufficient experienced field craft to construct the required projects within three year period

reg UMACT emissions requirements for new installations cannot be met with current technology - no new coal based power plant will be built in the US under the proposed emission limits

reg As a major environmental system supplier BampW urges consideration for a six year compliance period

Page 17: Utility MACT Regulation Briefing - whitehouse.gov · Utility MACT Regulation Briefing . November 10, 2011 . Rich Killion . B&W Power Generation Group ... Scrubber (50. 2) Equipment

babcock amp wilcox power generation group

Economic Impact of Major AQCS Project

Total Customer Project Cost $14B

Project Duration 4+ years

(Representative Sample of Large Project)

bull BampW Scope of Supply middot3 X 800 MW Wet FGD (core scope erected) bull 2 X 800 MW SCR retrofit (EPC)

bull BampW Supply = $ 400 M bull Engineering - 270 engineering

and material supply personnel bull Procurement

bull $ 81 M US procurement bull 10 states withgt $1 M in manufacturing

Iservices supplied bull Supply chain spanned over 20 states bull Equipment Supply

bull Construction bull Core scope Wet FGD = 500000 man hours bull EPC SCR = 1000000 manhours

babcock amp wilcox power generation group

Economic Impact of Major AQCS Project (Representative Sample of Large Project)

bull Equipment supply bull Absorber trays bull Agitators bull Alloy headers bull Bolts bull Electrical wiring bull Piping engineering bull Gaskets bull Monitors bull Pressure transmitters bull Pumps bull Steel plate bull Structural steel bull Ball and plug valves10 states withgt $1M in manufacturingservices supplied

States with lt $1M in manufacturingservices supplied

babcock amp wilcox power generation group

Construction Installation Services to Meet Regulatory Demand

babcock amp wilcox power generation group

BampW is a Major US Employer of Boilermaker Union Craft

bull One of top three boilermaker employers every year for last ten years

bull Top tier power plant constructor

Boilermaker union craft is the single largest union craft employed on power and emissions control projects nationwide

babcock amp wilcox power generation group

Total Boilermaker Man-Hour Forecast 3 year compliance schedule requires 16 more man-hours than highest recent peak

Man-hours (Millions)

~~~~~~~~~~~~~~~~~~~~ ~~~~~~~~~~~~~~~~~~~~

50 45 40 35 30 25 20 15 10

5 o

babcock amp wilcox power generation group

Construction Challenges in Meeting Regulatory Demand

bull Demands on craft labor will be significant - particularly on a regional basis

bull Time for implementation is too short

bull Project execution risk increases - safety quality cost

bull Although best practice mitigation strategies will be deployed results are questionable in meeting cost and schedule requirements given current UMACT compressed timeframe

babcock amp w il cox p o wer generation group

BampW Comments to EPA on Utility MACT

J~ ltgtU ~ ~ ~ ~

~~-_ ~ - - B~W

t Liipound7-- shyI~ _~ NyenltI_G lt1W~tOC-

- -_ - ~ ~

bull BampW reviewed the proposed Utility MACT rule and provided detailed comments

bull Proposed limits on new and reconstructed units too stringent

bull Some proposed limits on new and reconstructed units lower than capabilities of reference test methods

babcock amp w il cox power generation g oup

UMACT for New Units (NSPS)

45 of all US electricity is generated from coal from only 30 of installed US generation capacity bull Competitively priced long term bull 2417 availability (base load) bull Clean source of generation - virtually all plants will be clean

by 2015-2018 because of Utility MACTCSAPR bull Large jobs generator (mining railroad Boilermaker union construction

engineering manufacturing plant operations etc)

No new coal powered plants will be built in US under proposed rule emission limits bull BampW knows of no technology or combination of technologies commercially

available worldwide to achieve Total PM Hg and HCI emission limits bull Proposed limits are approximately an order of magnitude lower than what can

reliably be achieved by current technology bull Proposal is based on very low measured emissions at single units which are

believed to be the result of site-specific interactions of fuels test equipment and operations not regularly reproducible For example proposed limits are near the limits of detection of the measurement methods

babcock amp wi l cox power generation group

Challenges to Achieve Environmental Compliance reg Three year UMACT compliance period cannot be fulfilled

due to large number and duration of major projects

reg Attempts to meet UMACT three year compliance

reg Will drive extensive US manufacturing engineering and project management jobs offshore

reg Will increase risk substantially for project cost schedule completion and safety

reg There is insufficient experienced field craft to construct the required projects within three year period

reg UMACT emissions requirements for new installations cannot be met with current technology - no new coal based power plant will be built in the US under the proposed emission limits

reg As a major environmental system supplier BampW urges consideration for a six year compliance period

Page 18: Utility MACT Regulation Briefing - whitehouse.gov · Utility MACT Regulation Briefing . November 10, 2011 . Rich Killion . B&W Power Generation Group ... Scrubber (50. 2) Equipment

babcock amp wilcox power generation group

Economic Impact of Major AQCS Project (Representative Sample of Large Project)

bull Equipment supply bull Absorber trays bull Agitators bull Alloy headers bull Bolts bull Electrical wiring bull Piping engineering bull Gaskets bull Monitors bull Pressure transmitters bull Pumps bull Steel plate bull Structural steel bull Ball and plug valves10 states withgt $1M in manufacturingservices supplied

States with lt $1M in manufacturingservices supplied

babcock amp wilcox power generation group

Construction Installation Services to Meet Regulatory Demand

babcock amp wilcox power generation group

BampW is a Major US Employer of Boilermaker Union Craft

bull One of top three boilermaker employers every year for last ten years

bull Top tier power plant constructor

Boilermaker union craft is the single largest union craft employed on power and emissions control projects nationwide

babcock amp wilcox power generation group

Total Boilermaker Man-Hour Forecast 3 year compliance schedule requires 16 more man-hours than highest recent peak

Man-hours (Millions)

~~~~~~~~~~~~~~~~~~~~ ~~~~~~~~~~~~~~~~~~~~

50 45 40 35 30 25 20 15 10

5 o

babcock amp wilcox power generation group

Construction Challenges in Meeting Regulatory Demand

bull Demands on craft labor will be significant - particularly on a regional basis

bull Time for implementation is too short

bull Project execution risk increases - safety quality cost

bull Although best practice mitigation strategies will be deployed results are questionable in meeting cost and schedule requirements given current UMACT compressed timeframe

babcock amp w il cox p o wer generation group

BampW Comments to EPA on Utility MACT

J~ ltgtU ~ ~ ~ ~

~~-_ ~ - - B~W

t Liipound7-- shyI~ _~ NyenltI_G lt1W~tOC-

- -_ - ~ ~

bull BampW reviewed the proposed Utility MACT rule and provided detailed comments

bull Proposed limits on new and reconstructed units too stringent

bull Some proposed limits on new and reconstructed units lower than capabilities of reference test methods

babcock amp w il cox power generation g oup

UMACT for New Units (NSPS)

45 of all US electricity is generated from coal from only 30 of installed US generation capacity bull Competitively priced long term bull 2417 availability (base load) bull Clean source of generation - virtually all plants will be clean

by 2015-2018 because of Utility MACTCSAPR bull Large jobs generator (mining railroad Boilermaker union construction

engineering manufacturing plant operations etc)

No new coal powered plants will be built in US under proposed rule emission limits bull BampW knows of no technology or combination of technologies commercially

available worldwide to achieve Total PM Hg and HCI emission limits bull Proposed limits are approximately an order of magnitude lower than what can

reliably be achieved by current technology bull Proposal is based on very low measured emissions at single units which are

believed to be the result of site-specific interactions of fuels test equipment and operations not regularly reproducible For example proposed limits are near the limits of detection of the measurement methods

babcock amp wi l cox power generation group

Challenges to Achieve Environmental Compliance reg Three year UMACT compliance period cannot be fulfilled

due to large number and duration of major projects

reg Attempts to meet UMACT three year compliance

reg Will drive extensive US manufacturing engineering and project management jobs offshore

reg Will increase risk substantially for project cost schedule completion and safety

reg There is insufficient experienced field craft to construct the required projects within three year period

reg UMACT emissions requirements for new installations cannot be met with current technology - no new coal based power plant will be built in the US under the proposed emission limits

reg As a major environmental system supplier BampW urges consideration for a six year compliance period

Page 19: Utility MACT Regulation Briefing - whitehouse.gov · Utility MACT Regulation Briefing . November 10, 2011 . Rich Killion . B&W Power Generation Group ... Scrubber (50. 2) Equipment

babcock amp wilcox power generation group

Construction Installation Services to Meet Regulatory Demand

babcock amp wilcox power generation group

BampW is a Major US Employer of Boilermaker Union Craft

bull One of top three boilermaker employers every year for last ten years

bull Top tier power plant constructor

Boilermaker union craft is the single largest union craft employed on power and emissions control projects nationwide

babcock amp wilcox power generation group

Total Boilermaker Man-Hour Forecast 3 year compliance schedule requires 16 more man-hours than highest recent peak

Man-hours (Millions)

~~~~~~~~~~~~~~~~~~~~ ~~~~~~~~~~~~~~~~~~~~

50 45 40 35 30 25 20 15 10

5 o

babcock amp wilcox power generation group

Construction Challenges in Meeting Regulatory Demand

bull Demands on craft labor will be significant - particularly on a regional basis

bull Time for implementation is too short

bull Project execution risk increases - safety quality cost

bull Although best practice mitigation strategies will be deployed results are questionable in meeting cost and schedule requirements given current UMACT compressed timeframe

babcock amp w il cox p o wer generation group

BampW Comments to EPA on Utility MACT

J~ ltgtU ~ ~ ~ ~

~~-_ ~ - - B~W

t Liipound7-- shyI~ _~ NyenltI_G lt1W~tOC-

- -_ - ~ ~

bull BampW reviewed the proposed Utility MACT rule and provided detailed comments

bull Proposed limits on new and reconstructed units too stringent

bull Some proposed limits on new and reconstructed units lower than capabilities of reference test methods

babcock amp w il cox power generation g oup

UMACT for New Units (NSPS)

45 of all US electricity is generated from coal from only 30 of installed US generation capacity bull Competitively priced long term bull 2417 availability (base load) bull Clean source of generation - virtually all plants will be clean

by 2015-2018 because of Utility MACTCSAPR bull Large jobs generator (mining railroad Boilermaker union construction

engineering manufacturing plant operations etc)

No new coal powered plants will be built in US under proposed rule emission limits bull BampW knows of no technology or combination of technologies commercially

available worldwide to achieve Total PM Hg and HCI emission limits bull Proposed limits are approximately an order of magnitude lower than what can

reliably be achieved by current technology bull Proposal is based on very low measured emissions at single units which are

believed to be the result of site-specific interactions of fuels test equipment and operations not regularly reproducible For example proposed limits are near the limits of detection of the measurement methods

babcock amp wi l cox power generation group

Challenges to Achieve Environmental Compliance reg Three year UMACT compliance period cannot be fulfilled

due to large number and duration of major projects

reg Attempts to meet UMACT three year compliance

reg Will drive extensive US manufacturing engineering and project management jobs offshore

reg Will increase risk substantially for project cost schedule completion and safety

reg There is insufficient experienced field craft to construct the required projects within three year period

reg UMACT emissions requirements for new installations cannot be met with current technology - no new coal based power plant will be built in the US under the proposed emission limits

reg As a major environmental system supplier BampW urges consideration for a six year compliance period

Page 20: Utility MACT Regulation Briefing - whitehouse.gov · Utility MACT Regulation Briefing . November 10, 2011 . Rich Killion . B&W Power Generation Group ... Scrubber (50. 2) Equipment

babcock amp wilcox power generation group

BampW is a Major US Employer of Boilermaker Union Craft

bull One of top three boilermaker employers every year for last ten years

bull Top tier power plant constructor

Boilermaker union craft is the single largest union craft employed on power and emissions control projects nationwide

babcock amp wilcox power generation group

Total Boilermaker Man-Hour Forecast 3 year compliance schedule requires 16 more man-hours than highest recent peak

Man-hours (Millions)

~~~~~~~~~~~~~~~~~~~~ ~~~~~~~~~~~~~~~~~~~~

50 45 40 35 30 25 20 15 10

5 o

babcock amp wilcox power generation group

Construction Challenges in Meeting Regulatory Demand

bull Demands on craft labor will be significant - particularly on a regional basis

bull Time for implementation is too short

bull Project execution risk increases - safety quality cost

bull Although best practice mitigation strategies will be deployed results are questionable in meeting cost and schedule requirements given current UMACT compressed timeframe

babcock amp w il cox p o wer generation group

BampW Comments to EPA on Utility MACT

J~ ltgtU ~ ~ ~ ~

~~-_ ~ - - B~W

t Liipound7-- shyI~ _~ NyenltI_G lt1W~tOC-

- -_ - ~ ~

bull BampW reviewed the proposed Utility MACT rule and provided detailed comments

bull Proposed limits on new and reconstructed units too stringent

bull Some proposed limits on new and reconstructed units lower than capabilities of reference test methods

babcock amp w il cox power generation g oup

UMACT for New Units (NSPS)

45 of all US electricity is generated from coal from only 30 of installed US generation capacity bull Competitively priced long term bull 2417 availability (base load) bull Clean source of generation - virtually all plants will be clean

by 2015-2018 because of Utility MACTCSAPR bull Large jobs generator (mining railroad Boilermaker union construction

engineering manufacturing plant operations etc)

No new coal powered plants will be built in US under proposed rule emission limits bull BampW knows of no technology or combination of technologies commercially

available worldwide to achieve Total PM Hg and HCI emission limits bull Proposed limits are approximately an order of magnitude lower than what can

reliably be achieved by current technology bull Proposal is based on very low measured emissions at single units which are

believed to be the result of site-specific interactions of fuels test equipment and operations not regularly reproducible For example proposed limits are near the limits of detection of the measurement methods

babcock amp wi l cox power generation group

Challenges to Achieve Environmental Compliance reg Three year UMACT compliance period cannot be fulfilled

due to large number and duration of major projects

reg Attempts to meet UMACT three year compliance

reg Will drive extensive US manufacturing engineering and project management jobs offshore

reg Will increase risk substantially for project cost schedule completion and safety

reg There is insufficient experienced field craft to construct the required projects within three year period

reg UMACT emissions requirements for new installations cannot be met with current technology - no new coal based power plant will be built in the US under the proposed emission limits

reg As a major environmental system supplier BampW urges consideration for a six year compliance period

Page 21: Utility MACT Regulation Briefing - whitehouse.gov · Utility MACT Regulation Briefing . November 10, 2011 . Rich Killion . B&W Power Generation Group ... Scrubber (50. 2) Equipment

babcock amp wilcox power generation group

Total Boilermaker Man-Hour Forecast 3 year compliance schedule requires 16 more man-hours than highest recent peak

Man-hours (Millions)

~~~~~~~~~~~~~~~~~~~~ ~~~~~~~~~~~~~~~~~~~~

50 45 40 35 30 25 20 15 10

5 o

babcock amp wilcox power generation group

Construction Challenges in Meeting Regulatory Demand

bull Demands on craft labor will be significant - particularly on a regional basis

bull Time for implementation is too short

bull Project execution risk increases - safety quality cost

bull Although best practice mitigation strategies will be deployed results are questionable in meeting cost and schedule requirements given current UMACT compressed timeframe

babcock amp w il cox p o wer generation group

BampW Comments to EPA on Utility MACT

J~ ltgtU ~ ~ ~ ~

~~-_ ~ - - B~W

t Liipound7-- shyI~ _~ NyenltI_G lt1W~tOC-

- -_ - ~ ~

bull BampW reviewed the proposed Utility MACT rule and provided detailed comments

bull Proposed limits on new and reconstructed units too stringent

bull Some proposed limits on new and reconstructed units lower than capabilities of reference test methods

babcock amp w il cox power generation g oup

UMACT for New Units (NSPS)

45 of all US electricity is generated from coal from only 30 of installed US generation capacity bull Competitively priced long term bull 2417 availability (base load) bull Clean source of generation - virtually all plants will be clean

by 2015-2018 because of Utility MACTCSAPR bull Large jobs generator (mining railroad Boilermaker union construction

engineering manufacturing plant operations etc)

No new coal powered plants will be built in US under proposed rule emission limits bull BampW knows of no technology or combination of technologies commercially

available worldwide to achieve Total PM Hg and HCI emission limits bull Proposed limits are approximately an order of magnitude lower than what can

reliably be achieved by current technology bull Proposal is based on very low measured emissions at single units which are

believed to be the result of site-specific interactions of fuels test equipment and operations not regularly reproducible For example proposed limits are near the limits of detection of the measurement methods

babcock amp wi l cox power generation group

Challenges to Achieve Environmental Compliance reg Three year UMACT compliance period cannot be fulfilled

due to large number and duration of major projects

reg Attempts to meet UMACT three year compliance

reg Will drive extensive US manufacturing engineering and project management jobs offshore

reg Will increase risk substantially for project cost schedule completion and safety

reg There is insufficient experienced field craft to construct the required projects within three year period

reg UMACT emissions requirements for new installations cannot be met with current technology - no new coal based power plant will be built in the US under the proposed emission limits

reg As a major environmental system supplier BampW urges consideration for a six year compliance period

Page 22: Utility MACT Regulation Briefing - whitehouse.gov · Utility MACT Regulation Briefing . November 10, 2011 . Rich Killion . B&W Power Generation Group ... Scrubber (50. 2) Equipment

babcock amp wilcox power generation group

Construction Challenges in Meeting Regulatory Demand

bull Demands on craft labor will be significant - particularly on a regional basis

bull Time for implementation is too short

bull Project execution risk increases - safety quality cost

bull Although best practice mitigation strategies will be deployed results are questionable in meeting cost and schedule requirements given current UMACT compressed timeframe

babcock amp w il cox p o wer generation group

BampW Comments to EPA on Utility MACT

J~ ltgtU ~ ~ ~ ~

~~-_ ~ - - B~W

t Liipound7-- shyI~ _~ NyenltI_G lt1W~tOC-

- -_ - ~ ~

bull BampW reviewed the proposed Utility MACT rule and provided detailed comments

bull Proposed limits on new and reconstructed units too stringent

bull Some proposed limits on new and reconstructed units lower than capabilities of reference test methods

babcock amp w il cox power generation g oup

UMACT for New Units (NSPS)

45 of all US electricity is generated from coal from only 30 of installed US generation capacity bull Competitively priced long term bull 2417 availability (base load) bull Clean source of generation - virtually all plants will be clean

by 2015-2018 because of Utility MACTCSAPR bull Large jobs generator (mining railroad Boilermaker union construction

engineering manufacturing plant operations etc)

No new coal powered plants will be built in US under proposed rule emission limits bull BampW knows of no technology or combination of technologies commercially

available worldwide to achieve Total PM Hg and HCI emission limits bull Proposed limits are approximately an order of magnitude lower than what can

reliably be achieved by current technology bull Proposal is based on very low measured emissions at single units which are

believed to be the result of site-specific interactions of fuels test equipment and operations not regularly reproducible For example proposed limits are near the limits of detection of the measurement methods

babcock amp wi l cox power generation group

Challenges to Achieve Environmental Compliance reg Three year UMACT compliance period cannot be fulfilled

due to large number and duration of major projects

reg Attempts to meet UMACT three year compliance

reg Will drive extensive US manufacturing engineering and project management jobs offshore

reg Will increase risk substantially for project cost schedule completion and safety

reg There is insufficient experienced field craft to construct the required projects within three year period

reg UMACT emissions requirements for new installations cannot be met with current technology - no new coal based power plant will be built in the US under the proposed emission limits

reg As a major environmental system supplier BampW urges consideration for a six year compliance period

Page 23: Utility MACT Regulation Briefing - whitehouse.gov · Utility MACT Regulation Briefing . November 10, 2011 . Rich Killion . B&W Power Generation Group ... Scrubber (50. 2) Equipment

babcock amp w il cox p o wer generation group

BampW Comments to EPA on Utility MACT

J~ ltgtU ~ ~ ~ ~

~~-_ ~ - - B~W

t Liipound7-- shyI~ _~ NyenltI_G lt1W~tOC-

- -_ - ~ ~

bull BampW reviewed the proposed Utility MACT rule and provided detailed comments

bull Proposed limits on new and reconstructed units too stringent

bull Some proposed limits on new and reconstructed units lower than capabilities of reference test methods

babcock amp w il cox power generation g oup

UMACT for New Units (NSPS)

45 of all US electricity is generated from coal from only 30 of installed US generation capacity bull Competitively priced long term bull 2417 availability (base load) bull Clean source of generation - virtually all plants will be clean

by 2015-2018 because of Utility MACTCSAPR bull Large jobs generator (mining railroad Boilermaker union construction

engineering manufacturing plant operations etc)

No new coal powered plants will be built in US under proposed rule emission limits bull BampW knows of no technology or combination of technologies commercially

available worldwide to achieve Total PM Hg and HCI emission limits bull Proposed limits are approximately an order of magnitude lower than what can

reliably be achieved by current technology bull Proposal is based on very low measured emissions at single units which are

believed to be the result of site-specific interactions of fuels test equipment and operations not regularly reproducible For example proposed limits are near the limits of detection of the measurement methods

babcock amp wi l cox power generation group

Challenges to Achieve Environmental Compliance reg Three year UMACT compliance period cannot be fulfilled

due to large number and duration of major projects

reg Attempts to meet UMACT three year compliance

reg Will drive extensive US manufacturing engineering and project management jobs offshore

reg Will increase risk substantially for project cost schedule completion and safety

reg There is insufficient experienced field craft to construct the required projects within three year period

reg UMACT emissions requirements for new installations cannot be met with current technology - no new coal based power plant will be built in the US under the proposed emission limits

reg As a major environmental system supplier BampW urges consideration for a six year compliance period

Page 24: Utility MACT Regulation Briefing - whitehouse.gov · Utility MACT Regulation Briefing . November 10, 2011 . Rich Killion . B&W Power Generation Group ... Scrubber (50. 2) Equipment

babcock amp w il cox power generation g oup

UMACT for New Units (NSPS)

45 of all US electricity is generated from coal from only 30 of installed US generation capacity bull Competitively priced long term bull 2417 availability (base load) bull Clean source of generation - virtually all plants will be clean

by 2015-2018 because of Utility MACTCSAPR bull Large jobs generator (mining railroad Boilermaker union construction

engineering manufacturing plant operations etc)

No new coal powered plants will be built in US under proposed rule emission limits bull BampW knows of no technology or combination of technologies commercially

available worldwide to achieve Total PM Hg and HCI emission limits bull Proposed limits are approximately an order of magnitude lower than what can

reliably be achieved by current technology bull Proposal is based on very low measured emissions at single units which are

believed to be the result of site-specific interactions of fuels test equipment and operations not regularly reproducible For example proposed limits are near the limits of detection of the measurement methods

babcock amp wi l cox power generation group

Challenges to Achieve Environmental Compliance reg Three year UMACT compliance period cannot be fulfilled

due to large number and duration of major projects

reg Attempts to meet UMACT three year compliance

reg Will drive extensive US manufacturing engineering and project management jobs offshore

reg Will increase risk substantially for project cost schedule completion and safety

reg There is insufficient experienced field craft to construct the required projects within three year period

reg UMACT emissions requirements for new installations cannot be met with current technology - no new coal based power plant will be built in the US under the proposed emission limits

reg As a major environmental system supplier BampW urges consideration for a six year compliance period

Page 25: Utility MACT Regulation Briefing - whitehouse.gov · Utility MACT Regulation Briefing . November 10, 2011 . Rich Killion . B&W Power Generation Group ... Scrubber (50. 2) Equipment

babcock amp wi l cox power generation group

Challenges to Achieve Environmental Compliance reg Three year UMACT compliance period cannot be fulfilled

due to large number and duration of major projects

reg Attempts to meet UMACT three year compliance

reg Will drive extensive US manufacturing engineering and project management jobs offshore

reg Will increase risk substantially for project cost schedule completion and safety

reg There is insufficient experienced field craft to construct the required projects within three year period

reg UMACT emissions requirements for new installations cannot be met with current technology - no new coal based power plant will be built in the US under the proposed emission limits

reg As a major environmental system supplier BampW urges consideration for a six year compliance period