Colorado Department of Public Health and Environment - Air Pollution Control Division

Best Available Retrofit Technology (BART) Analysis – PSCo Hayden Station Page 1 Best Available Retrofit Technology (BART) Analysis of Control Options For Public Service Company – Hayden Station

I. Source Description

Owner/Operator: Public Service Company Source Type: Electric Util ity Steam Generating Unit SCC (EGU): Unit 1: 10100222 Unit 2: 10100226 Boiler Type: Pulverized Coal, Dry-Bottom, Front-Fired, firing coal (Unit 1 a) Pulverized Coal, Dry Bottom, Ta ngentially-Fired, firing coal (unit 2)

The facility is located four miles east of Hayden, Colorado at 13125 U.S. Highway 40 in Routt County. This facility consists of two (2) steam dr iven turbine/generator units (Units 1 and 2) and the associated equipmen t needed for generating electricity. The Unit 1 ignitors utilize either natura l gas or No. 2 fuel oil and th e Unit 2 ignitors utilize No. 2 fuel oil for startup, shutdown and/or flame stabilization. In addition to the coal fired boilers, other significant sources of emissions at this facility include fugitive emissions from coal handling, ash handling and dispos al and vehicle traffic on paved and unpaved roads. Point source emissions of particulate matter include coal crushing and conveying, an ash storage silo, two (2) ash recycle silo s (recycle ash used with lime in the spray dryer), two (2) lime storage silos, two (2) ball mill slakers (prepares lime slurry for spray dryer) and two (2) recycle mixers (prepares recy cle as slurry for spray dryer). Additional emission units at this facility include two (2 ) cooling towers. Only Units 1 and 2 are BART-eligible. Table 1 below lists the units at Public Service Company Hayden Station that the Division examined for control to m eet BART-eligible requirements. Controlled and uncontrolled emission factors and CAMD da ta were used to evaluate the control effectiveness of the current emission controls.

Table 1: Hayden Boilers Technical Information
Unit 1 Unit 2
Placed in Service July 1965 1976
Boiler Rating, MMBtu/Hr for coal 1,963 2,712

Electrical Power Rating, Gross Megawatts 190 275

Description Riley-Stoker Pulverized Coal Front Fired Dry Bottom, firing coal with natural gas and No. 2 fuel oil used for start up, shutdown and/or flame stabilization. Combustion Engineeri ng Pulverized Coal Tangentially Fired Dry Bo ttom, firing coal with No. 2 fuel oil used for startup, shutdown, and/or flame stabilization.

Air Pollution Control Equipment PM/PM 10 - Reverse-Air Fabric Filter Baghouse
NO x – Low NO x Burners with Over-Fire Air
SO 2 – Lime Spray Dryer PM/PM 10 – Reverse-Air Fabric Filter Baghouse
NO x – Low NO x Burners with Over-Fire Air
SO 2 – Lime Spray DryerColorado Department of Public Health and Environment - Air Pollution Control Division

Best Available Retrofit Technology (BART) Analysis – PSCo Hayden Station Page 2 All equipment commenced operation in December 1998 All equipment commenced operation in October – December 1999

Emissions Reduction (%)* NO x – 54.1% SO 2 – 82.0%
PM – 99.7%

PM 10 – 98.8% NO x – 33.3% SO 2 – 79.6%
PM – 99.7%

PM 10 – 98.9% *Emissions Reduction estimated by comparing uncontrolled AP-42 factor to actual average emission factor for PM/PM 10 . For NO x and SO 2 estimates, CAMD data was used to calculate reductions. See “Hayden APCD Technical Analysis” for further details. Not based on actual testing.

Units 1 and 2 are considered BART-eligible, being fossil-fuel steam electric plants of more than 250 MMBtu/hr heat input with the potential to emit 250 tons or more of haze forming pollution (NO x , SO 2 , PM 10 ), and commenced operation in the 15-year period prior to August 7, 1977. These boilers also cause or contribute to visibility impairment at a federal Class I area at or above a 0.5 deci view change; consequently, both boilers are subject-to-BART. Public Service Company (PSCo) submitted a BART analysis to the Division on September 14, 2006 with revi sions submitted on November 1, 2006 and January 8, 2007. In response to Division requests, PSCo submitted additional information on May 25 and July 14, 2010. The submittals are included as “PSCo BART Submittals”.

II. Emissions for Units 1 & 2

PSCo estimated that a realistic depiction of anticipated annual emissions for Units 1 and 2, or “Baseline Emissions”, to be conservati ve, was the average of two previous years (2004, 2005) of emissions data in the Septem ber 14, 2006 analysis. Several years have passed since the original BART submittal, in which the Division has updated modeling and technical analyses. Therefore, the Di vision used years 2006 – 2008 (annual averages and 30-day rolling) for baseline emissions for reduction and cost calculations. The highest 24-hour peak emission rate duri ng this timeframe was used for modeling visibility results. The Division verified th ese emissions using Colorado’s Air Pollutant Emission Notices and EPA’s CAMD database . These emissions are summarized in Table 2.

Table 2: PSCo Hayden Units 1 & 2 Emissions

Pollutant Unit 1 Unit 2 Annual Emissions* (tpy) Annual emissions** (lb/MMBtu) Annual Emissions* (tpy) Annual emissions** (lb/MMBtu) NO x 3,750 0.415 3,743 0.320 SO 2 1,172 0.131 1,469 0.127 PM 10 88.0 0.006*** 109.3 0.004*** *Using daily CEMs data from 2006 – 2008 calendar years (CAMD data). **The Division calculated average emission rate (lb/MMBtu) from the 2006 - 2008 calendar years (CAMD data) based on average daily reported data for each unit for NO x and SO 2 emissions. ***The PM 10 emission rate is determined from the latest Title V permit compliance stack test (June 2009). These values are as follows: Hayden Unit 1: 0.006 lb/MMBtu Hayden Unit 2: 0.004 lb/MMBtuColorado Department of Public Health and Environment - Air Pollution Control Division

Best Available Retrofit Technology (BART) Analysis – PSCo Hayden Station Page 3 III. Units Evaluated for Control

PSCo notes that the Hayden boilers burn Colo rado coal that primarily comes from two different mines in northwestern Colorado, the Twenty Mile Mine and the ColoWyo Mine. Coal characteristics are very similar from both of these mines. However, the ColoWyo coal is ranked as sub-bituminous while the Twenty Mile coal is ranked as bituminous (ASTM Method 388). However, PSCo performe d an analysis using the Electric Power Research Institute (“EPRI”) NOx/LOI Pred ictor software program (Version 2.1) to demonstrate that the more appropriate ra ting for ColoWyo coal is bituminous. The specifications for these coals are listed below in Table 3. Note that with the exception of moisture content, the coal characteristics are reasonably close for the two coals.

Table 3: Hayden Station Coal Specifications (2004 – 2005) Coal Mine/Region Colowyo Twentymile Coal Rank Classification Sub-bituminous, Class A Bituminous As Received Analysis H 2 O (Moisture %) 16.8 9.8 Ash (%) 5.82 9.5 Sulfur (%) 0.36 0.49 Nitrogen (%) 1.33 1.65 Heating Value (HHV Btu/lb) 10,450 11,350 EPRI Model NO x Prediction (lb/MMBtu) 0.46 0.39

Uncontrolled emission factors are outlined in Table 4. The factors are based on firing bituminous coal as well as the highest ash and sulfur content fr om the two coals for conservative estimates.

Table 4: Uncontrolled emission factors for PSCo Hayden BA RT-eligible sources 1 Pollutant (lb/ton)* Emission Unit NO x SO 2 PM (filterable) PM 10 (filterable) Hayden Unit 1 22** 18.6 95 21.9 Hayden Unit 2 15** 18.6 95 21.9 *SO 2 and PM/PM 10 factors are determined by the applicab le AP-42 equation, where %S and %A are the % of sulfur and ash present in the coal su pply, respectively, determined from Table 3. **Assumed no low-NO x burners.

IV. BART Evaluation of Units 1 and 2

A. Sulfur Dioxide (SO 2 )

Step 1: Identify All Available Technologies

Semi-Dry FGD Upgrades – As discussed in EPA’s BART Guidelines 2 , electric generating units (EGUs) with existing controls achieving removal e fficiencies of greater than 50 percent are not

1 EPA AP-42, Fifth Edition, Volume I, Chapte r 1, Section 1.1, Tables 1.1-3 and 1.1-4. http://www.epa.gov/ttn/chief/a p42/ch01/final/c01s01.pdf

2 EPA, 2005. Federal Register, 40 CFR Part 51. Regi onal Haze Regulations and Guid elines for Best Available Retrofit Technology (BART) Determinations: Final Rule. Pgs. 39133.Colorado Department of Public Health and Environment - Air Pollution Control Division

Best Available Retrofit Technology (BART) Analysis – PSCo Hayden Station Page 4 required to remove these controls and replace th em with new controls. The Division interprets this to include fuel switching to natural gas, which would require significant boiler modifications, including re moving the semi-dry FGD.

However, based on Appendix Y [70 FR 39171], th e following dry scrubber upgrades should be considered for Hayden Units 1 and 2 if tec hnically feasible. Th ese upgrades include: -Use of performance additives -Use of more reactive sorbent -Increase the pulverizati on level of sorbent -Engineering redesign of atomizer or slurry injection system -Additional equipment and maintenance: In the May 25, 2010 response to the Division, PSCo noted that Hayden Units 1 and 2 could potenti ally achieve a new reduced 30-day average emission rate limit of 0.13 lbs/MMBtu by conducting changes to the dry sc rubber systems, so this option will be evaluated as part of possible semi-dry FGD upgrades.

The current Operating Permit limits are depicted in Table 5.

Table 5: Hayden Units 1 & 2 SO 2 Operating Permit Limits SO 2 limits (lb/MMBtu) Reduction (%) Required 30-day rolling 3-hr rolling 30-day rolling 90-day rolling Units 1 & 2 1.2 0.160 0.130 82 (rounded)

Step 2: Eliminate Techni cally Infeasible Options

At the Division’s request, PSCo submitted an SO 2 upgrade analysis to the Division on May 25, 2010 regarding potential upgrades for the LSDs installed on Hayden Units 1 and 2. The following summarizes PSCo’s submittal and the Divi sion’s analysis of the information provided.

FGD: Flue gas desulfurization removes SO 2 from flue gases by a variety of methods. The most common dry FGD system is a lime spray dry absorber uses that slaked lime slurry sprayed into the flue gas, which is subsequently dried by the heat of the flue gas, and then collected in a particulate control device. Generally, FGD control systems need to be located in close proximity to the boiler exhaust gas stream to prevent condensation (e.g. coo ling of the exhaust gases) that result in acidic precipitation in the duct which results in corrosion issues.

Dry FGD Upgrades: Dry FGD systems are commonly known as spray dry absorbers (SDA) or lime spray dryers (LSD), and currently make up about 12% of FGD systems at U.S. power plants 3 . SDA systems are typically utilized at units that burn lower-sulfur coal in the western U.S., where water resources are limited. A SDA sy stem must be located before the boiler flue gases enter the baghouse. Each reactor vessel re quires a “foot print” area comprising about 2,000 to 4,000 square feet (depending on volume of flue gas treated) along with additional space for support equipment access, slurry prepar ation, mixing and associated tanks.

3 Electric Power Research Institute: A Review of Literature Related to the Use of Spray Dryer Absorber Material – Production, Characterization, Utili zation Applications, Barriers, and Recommendations, Technical Report, September 2007. University of North Dakota: Energy & Environmental Research Center – Coal Ash Resources Research Consortium. 15 North 23 rd Street, Stop 9018. Grand Forks, ND, 58202. Pg. v.Colorado Department of Public Health and Environment - Air Pollution Control Division

Best Available Retrofit Technology (BART) Analysis – PSCo Hayden Station Page 5 PSCo installed lime spray dryers (LSDs) in c onnection with baghouses on Hayden Units 1 and 2 1998 and 1999, respectively. PSCo notes that both of these dryers cu rrently achieve greater than 80% removal, with actual annual averages of 0.13 lbs SO 2 /MMBtu (each unit) in comparison with the permit limits 4 depicted in Table 5. This syst em exceeds EPA’s presumptive limits stated in 40 CFR Part 51 Appendix Y of 0.15 lb/MMBtu, although the current permit limit is higher than the presumptive limits.

At the Division’s request, PSCo submitted a SO 2 upgrade analysis to the Division on May 25, 2010 regarding potential upgrades for the lime spra y dryer systems at Hayd en Station. Hayden’s Babcock and Wilcox (B&W) lime spray dryers that use a single atomizer per scrubber module design that sprays a mixture of lime and recycled as h into the flue gas. This atomized mist then dries, reacts with SO 2 in the flue gas and is collected in the baghouse.

PSCo examined potential upgrades to the Hayde n dry scrubbers, with the following results:

-Use of performance additives: The supplier (Babcock & W ilcox) of PSCo’s Colorado dry scrubbing equipment does not recommend the use of any performance additive. PSCo is aware of some additive trials, using a chlorine-based ch emical, which have been used on dry scrubbers. Chlorides are used to slow the drying time of the fly ash/lime mixture used to capture the gaseous SO 2 . The chemistry of the calcium sulfate/sulf ite reaction is much more effective when liquid water droplets exist. By slowing the drying time the theory is that the lime sorbent will be more efficient and the lime use coul d be decreased to obtain the same SO 2 reduction capability of the equipment unless the unit is limited on the to tal amount of lime slurry injection. There are cases on units that use high sulfur coal (signifi cantly greater than 1.2 lb s/MMBtu) where the total amount of lime slurry injection is limited by the solids content of the slurry. When the total limit injection for a unit is limited, additives may allow some increase in SO 2 removal. However, because the Hayden boilers burn low sulfur west ern coals, PSCo is not limited on lime slurry injection and the use of performance additives on the scrubbers would not be expected to increase the SO 2 removal. Based on the information pr ovided by PSCo, the Division agrees that the use performance additives are not likely to increase SO 2 removal and therefore warrants no further consideration.

-Use of more reactive sorbent: All PSCo dry scrubbers were desi gned to use a highly reactive lime with 92% calcium oxide content. The scrubb ers were also designed to inject fly ash to maximize available surface area and allow efficient lime reagent use. Some dry scrubbers used by other companies were designed to use a lower quality lime, a dry hydrated lime product, or operate on lime without fly ash. On these scrubbers, the option of using a higher quality lime or injecting fly ash possibly could improve SO 2 removal. The only other common reagent option for a dry scrubber is sodium-based products which are more reactive than freshly hydrated lime. Sodium has a major side effect of converting some of the NO x in the flue gas into NO 2 . Since NO 2 is a visible gas, large coal-f ired units can generate a visi ble brown/orange plume at high SO 2 removal rates, such as thos e experienced at Hayden.

4 Colorado Operating Permit Number 96OPROB132 Last Revised 5/14/10. Pgs. 6, 9.Colorado Department of Public Health and Environment - Air Pollution Control Division

Best Available Retrofit Technology (BART) Analysis – PSCo Hayden Station Page 6 Lime is the reagent of choice in modern spray dryer systems on utility scale units. PSCo is aware of only one exception that was designe d to use sodium carbonate to remove SO 2 . The Coyote Station, a 420MW unit located near Beul ah, North Dakota and operated by Otter Tail Power Company, was placed in service in 1981. The spray dryer was supplied by Rockwell and used rotary atomizers. The unit was designed to obtain 70% SO 2 removal. This unit was reported to have a visible plume at times likely due to the conversion from NO to NO 2 due to the sodium reagent. This unit was converted from sodium carbonate to lime after a number of years in service. PSCo verified with the two major suppliers of utility sized spray dryers, B&W and Alstom, and confirmed that there are no other operat ing utility spray dryers in the United States. B&W also states that in theory the sodium base d reagents are more reactive as they have a slower drying time than lime reagents. However, because of their slower drying time, the spray dryer absorber would need to be larger to ensure the product was dry when l eaving the scrubber. Thus, the use of sodium r eagent in a unit designed for lime would not allow higher SO 2 removal and it may not even be possible to convert to a sodium reagent with the existing equipment.

PSCo is using a highly reactiv e reagent that maximizes SO 2 removal; there are no known acceptable reagents without side eff ects that would allow additional SO 2 removal in the dry scrubbing systems present at Hayden Station. The Division agrees with PSCo’s assessment and considers that use of a more reactive sorbent does not warra nt further consideration.

-Increase the pulverization level of sorbent: The Hayden dry scrubbers are designed with either horizontal or vertical ball mills to obtai n optimum particulate size and reduce lime grit generation. There have been some technical papers presented by pulverizer suppliers, that state vertical ball mills may provide a smaller pa rticulate size and reduce lime use. PSCO’s experience is that there is no SO 2 removal benefit in using vertical ball mills versus horizontal ball mills and there is also no measurable reduction in lime use. Since PSCo already uses the best available grinding technologies, the Division would agree that changes to the design of the atomizers are unlikely to result in a higher SO 2 removal.

-Engineering redesign of atomizer or slurry injection system: The Hayden dry scrubber systems are from B&W and use the same size and genera l design atomizer, a Model F800. While there are differences in the motor size and exact atomi zer wheel construction that relate to the total slurry injection rate, the atomizer design is based on the vendor’s experience to maximize both SO 2 removal and lime use efficiency. B&W offe rs no upgrade in atomizer design to improve SO 2 removal. There are certain th ird-party suppliers who offer di fferent atomizer nozzle designs that they claim can reduce lime use or provide longer maintenance life. To PSCo’s knowledge, no vendors claim an improved SO 2 removal. PSCo has tried some of these different nozzle designs and doesn’t believe any of the designs improve the SO 2 removal level, although some have improved wear life and re duced maintenance costs.

However, PSCo provided to the Division upon additional request (July 14, 2010) additional information stating that an additional scrubber m odule (i.e. atomizer) would be required for each unit as well as additional spare parts and maintenance personne l in order to meet a lower emission limit. Therefore, this option is technically feasible.Colorado Department of Public Health and Environment - Air Pollution Control Division

Best Available Retrofit Technology (BART) Analysis – PSCo Hayden Station Page 7 -Additional equipment and maintenance : PSCo reviewed actual ope rating experience on Hayden along with possible changes to the systems nece ssary to achieve lower emission rates on a 30- day average basis. The primary factors that affect SO 2 control efficiency for short-term averages are start-ups, equipment malfunctions, and low lo ad operation. In order to begin injecting lime/recycle ash slurry into the scrubber, a minimum inlet scrubber temperature must be achieved so the lime/recycle ash slurry dries wh en it hits the hot flue gas. When the scrubber inlet temperature is below this minimum level, the lime slurry drops out in the scrubber and forms concrete-like deposits that eventually plug the scrubber vessel. This situation actually occurred while operating PSCo’s Comanche Unit 2 and Valmont Unit 5 scrubbers and resulted in extended maintenance outages to cl ean the scrubbers. During unit st art-ups, it can take anywhere from 12-24 hours to get the inlet scrubber temperat ures up to the level necessary for safe lime slurry injection.

During these start-up periods, SO 2 emissions rates are at uncontroll ed levels based on the sulfur content in the coal. Typicall y, if the unit only starts once du ring a 30-day period, operators can over-control SO 2 by running the scrubber below the 30-day average emission rate to "make-up" for higher emission rates during start-up. If the unit has more than one start-up in a 30-day period, which certainly happens with older units, it becomes nearly impossible to scrub hard enough to achieve the 30-day rol ling emission rate limits. The same situation occurs under low load operation, especially during winter months . Inlet temperature to the baghouse due to air heater in-leakage can approach minimum acceptable levels, thus lowering overall SO 2 control efficiency during low load operation. PSCo coal-f ired units will be requi red to cycle (under 60% load) more in the future to accommodate the intermittent nature of ever increasing wind generation on the electric grid a nd thus requiring the boilers to ope rate more frequently at low loads.

Based on a review of actual operating data and th e factors noted above that affect short-term average SO 2 emission rates, PSCo believes Hayden Units 1 and 2 can achieve a lower 30-day average emission rate limit of 0.13 lbs/MMBtu as BART. This is currently the 90-day average emission limit for these units. In order to meet this lower limit on a 30-day average basis, the plant needs to purchase additional spare atom izer parts and increase annual operating and maintenance due to increased labor and reagent requirements.

Step 3: Evaluate Control Effectiveness of Each Remaining Technology

PSCo provided the Division 30-day rolling average control estimates. In the Division’s experience, 30-day SO 2 rolling average emission rates are expected to be approximately 5% higher than the annual average emission rate. The Division projected an annual average emission rate at 5% for Hayden to determine control efficiencies and annual reductions.

The Division has reviewed the data supplied by PS Co as well as other cont rol techniques applied to pulverized coal boilers. A Division revi ew of the EPA’s RBLC revealed recent BACT SO 2 determinations range from 0.06 – 0.167 lbs/MM Btu. The Division narrowed down this range depending on the averaging time, permit type, facility size, and fuel type. This narrowed range is 0.095 – 0.161 lbs/MMBtu, with an average of 0.119 lbs/MMBtu rounded to 0.12 lbs/MMBtu. While determinations made by other states do no t dictate the emissions rate choice made by theColorado Department of Public Health and Environment - Air Pollution Control Division

Best Available Retrofit Technology (BART) Analysis – PSCo Hayden Station Page 8 Division, they do provide information on the range to validate the emissions rate chosen by the Division. Refer to “Division RBLC Analysis” for more details.

Engineering redesign of atomizer or slurry injection system: At the Division’s request, PSCo sent cost information regarding the requirement s for an additional scrubber module on July 14, 2010 in order to meet a SO 2 30-day rolling emission limit of 0.08 lb/MMBtu, or 90% control efficiency (pre-control). This upgrade/redesign will result in control efficiencies of 41.7% and 40.1% beyond the current reductions shown in Tabl e 1 on Units 1 and 2, respectively. Using this information, the Division calculated the resultan t control effectiveness using the baseline and annual emissions for each unit. See “Hayden AP CD Technical Analysis” for more information.

Dry FGD Upgrade – Additional equipment and maintenance: To evaluate the control effectiveness of tightening th e 30-day rolling emission limits on Hayden Units 1 and 2, the Division used the annual baseline emissions, the average annual operating hours (2006 – 2008), and the daily heat input (MMB tu/day) to determine the emi ssion rates at 0.13 lb/MMBtu and calculated the resultan t control effectiveness and annua l emissions for each unit.

Table 6 summarizes each available technol ogy and technical f easibility for SO 2 control.

Table 6: Hayden Units 1 and 2 SO 2 Technology Options and Technical Feasibility Technology Emission Reduction Potential (%) Technically Feasible? (Y = yes, N = no) Dry FGD Upgrades Use of performance additives n/a N Use of more reactive sorbent n/a N Increase pulverization level of sorbent n/a N Engineering redesign of atomizer or slurry injection system ~40 – 42% Y

Additional equipment and maintenance ~3 - 5% Y

Step 4: Evaluate Impacts and Document Results

Cost of Compliance Engineering redesign of atomizer or slurry injection system : The Division calculated cost estimates for an additional scrubber module – based on total capital and operating and maintenance costs provided in PSCo’s July 14, 2010 letter. PSCo stated that Hayden Station will need for an additional module on each unit as we ll as estimated spare parts and additional maintenance personnel (i.e. O&M costs). PSC o estimated capital costs for Unit 1 at $37,000,000 and Unit 2 at $43,000,000 and operating & maintenance costs at $650,000 and $750,000 for Units 1 and 2, respectively. These costs are de termined based on meeting a more stringent 30- day rolling limit of 0.08 lb/MMBtu for each unit.

Dry FGD Upgrade – Additional equipment and maintenance: The Division calculated cost estimates for dry FGD upgrade – additional equipment and maintenance – based on total capital and operating and maintenance costs provided in PSCO’s May 25, 2010 letter. PSCo stated that Hayden Station will need spare atomizer parts at a cost of $330,000 along with increased annual operating and maintenance costs of $220,000 per year fo r reagent and labor to meet the moreColorado Department of Public Health and Environment - Air Pollution Control Division

Best Available Retrofit Technology (BART) Analysis – PSCo Hayden Station Page 9 stringent 30-day rolling SO 2 emission limit of 0.13 lbs/MMBtu. This cost analysis was conducted to demonstrate the impact of meeting th e more stringent limit only. Table 7, Table 8, Table 9, and Table 10 show the SO 2 control cost per unit.

Table 7: Hayden Unit 1 Control Resultant SO 2 Emissions

Alternative Control Efficiency (%) Resultant Emissions

Annual Emissions (tons/year) Annual Average (lb/MMBtu) 30-day Rolling Average (lb/MMBtu)
Baseline

--- 1,172 0.131 Dry FGD Upgrade – Additional Equipment and Maintenance 5.2% 1,111 0.124 0.130

Additional Scrubber Module 41.7% 684 0.076 0.080

Table 8: Hayden Unit 2 Control Resultant SO 2 Emissions

Alternative Control Efficiency (%) Resultant Emissions
Annual Emissions (tons/year) Annual Average (lb/MMBtu) 30-day Rolling Average (lb/MMBtu) Baseline --- 1,469 0.127 Dry FGD Upgrade – Additional Equipment and Maintenance 2.7% 1,430 0.124 0.130

Additional Scrubber Module 40.1% 880 0.076 0.080

Table 9: Hayden Unit 1 SO 2 Cost Effectiveness

Alternative Emissions Reduction (tpy) Annualized Cost ($) Cost Effectiveness ($/ton) Incremental Cost ($/ton)

Baseline 0 $0 $0

--- Dry FGD Upgrade – Additional Equipment and Maintenance 61 $141,150 $2,317 $2,317

Additional Scrubber Module 488 $4,142,538 $8,490 $9,370Colorado Department of Public Health and Environment - Air Pollution Control Division

Best Available Retrofit Technology (BART) Analysis – PSCo Hayden Station Page 10 Table 10: Hayden Unit 2 SO 2 Cost Effectiveness

Alternative Emissions Reduction (tpy) Annualized Cost ($) Cost Effectiveness ($/ton) Incremental Cost ($/ton)

Baseline 0 $0 $0

--- Dry FGD Upgrade – Additional Equipment and Maintenance 39 $141,150 $3,626 $3,626

Additional Scrubber Module 589 $4,808,896 $8,164 $8,485

Energy and Non-Air Quality Impacts There are no energy and non-air qu ality impacts related to tightening the emission limit for SO 2 beyond the acquisition of additional reagent. Thus, this factor does not influence the selection of controls.

Remaining Useful Life PSCo asserts that the remaining useful life of Hayden Units 1 a nd 2 are each in excess of 20 year, which is the maximum amortization period allowed in the BART analysis. Thus, this factor does not influence th e selection of controls.

Step 5: Evaluate Visibility Results CALPUFF modeling was used to determine the proj ected visibility improve ment associated with various control technologies. The modeling guid eline requires that modeled baseline emission rate is the 24-hour peak emission rate. The mode ling guideline also requires that, at a minimum, the presumptive emission rate scenario be modele d. Table 11 shows the number of days pre- and post-control. Table 12 depict s the visibility results (98 th percentile impact and improvements) as well as cost effectiveness in $/deciview and the calcula tion methodology utilized by the Division.

Per the April 2010 modeling protocol 5 , to isolate the effects of a given unit for controls on a given pollutant, the Division has judiciously cons tructed each emissions scenario to isolate the impact of a given BART control on a given unit. For example, to determine the effect of a SO 2 BART control technology on a given unit, em ission rates for the ot her pollutants (NO x and PM/PM 10 ) and other BART-eligible units are held constant at pre- control levels. For BART sources with more than one BART unit, modeli ng the units individually would ignore important atmospheric chemical reactions that occur when units operate simultaneously. The combination scenario assumed Units 1 and 2 with NO x emissions at 0.07 lb/MMBtu and SO 2 emissions at 0.12 lb/MMBtu.

In situations where the BART-eligible units at a given BART-eligible source operate simultaneously, the sulfate and nitrate estimates from the modeling system will be more realistic, in general, if all BART units and all pollutants at a BART-eligible source are modeled together.

5 Colorado Air Pollution Control Division, Technical Se rvices Program, 2010. “Supplemental BART Analysis CALPUFF Protocol for Class I Federal Area Visibility Improvement Modeling Analysis.”Colorado Department of Public Health and Environment - Air Pollution Control Division

Best Available Retrofit Technology (BART) Analysis – PSCo Hayden Station Page 11 The combined unit approach has the added bene fit of allowing Colorado to estimate the net degree of visibility improvement from the simu ltaneous operation of BART controls on multiple units for multiple pollutants at a given BART-eligible source.

Table 11: Visibility Results – Change in Days >0.5 dv and >1.0 dv at highest affected Class I Area

SO2 Control Scenario Boiler(s) SO2 Emission Rate (lb/MMBtu)* Class I Area Affected 3-year totals 3-year totals

PreControl Days >0.5 dv PostControl Days >0.5 dv ∆ days PreControl Days >1.0 dv PostControl Days >1.0 dv ∆ days

Max 24-hr SO 2 rates 1 0.339

Rocky Mountain National

Park 236 --- --- 155 --- --- 2 0.402

Dry FGD Upgrade 1 0.160* n/a

2 0.160* n/a

Dry FGD Upgrade 1 0.130 236 228 8 155 147 8
2 0.130 236 224 12 155 143 12 Additional Scrubber Module 1 0.100 236 228 8 155 146 9

2 0.100 236 223 13 155 143 12 Additional Scrubber Module 1 0.070 236 228 8 155 146 9

2 0.070 236 223 13 155 142 13

Combo 1 0.070

236 57 179 155 6 149 2 0.070 * Denotes that output was interpolated by the Division and is not an actual modeled output. See “Hayden BART Modeling Summary” for more details.

Table 12: Visibility Results – SO 2 Control Options

SO2 Control

Scenario Boiler(s) SO2 Emission Rate (lb/MMBtu)* Output (@ 98 th Percentile

Impact) 98 th Percentile Impact Improvement 98 th Percentile Improvement from Maximum Cost Effectiveness

(dv) ( ∆ dv) (%) ($/dv)

Max 24-hr SO 2 rates 1 0.339 3.627 --- --- --- 2 0.402

Dry FGD Upgrade 1 0.160* 3.540 0.09 2% n/a

2 0.160* 3.445 0.18 5% n/a

Dry FGD Upgrade 1 0.130 3.525 0.10 3% $1,383,820 2 0.130 3.422 0.21 6% $688,535
Additional Scrubber Module 1 0.100 3.505 0.12 3% $33,955,232
2 0.100 3.395 0.23 6% $20,727,999

Additional Scrubber Module 1 0.070 3.485 0.14 4% n/a

2 0.070 3.367 0.26 7% n/aColorado Department of Public Health and Environment - Air Pollution Control Division

Best Available Retrofit Technology (BART) Analysis – PSCo Hayden Station Page 12 Combo 1 0.120 0.91 2.72 75% n/a 2 0.120 * Denotes that output was interpolated by the Division and is not an actual modeled output. See “Hayden BART Modeling Summary” for more details.

Step 6: Select BART Control Based upon its consideration of the five factors su mmarized herein, the state has determined that SO 2 BART the following SO 2 emission rates: Hayden Unit 1: 0.13 lb/MMBtu (30-day rolling average) Hayden Unit 2: 0.13 lb/MMBtu (30-day rolling average)

The state assumes that the BART emission li mits can be achieved through the operation of existing lime spray dryers (LSDs). The state evaluated the option of tightening the emission limit for Hayden Units 1 and 2 and determined that a more stringent 30-day rolling SO 2 limit of 0.13 lbs/MMBtu represents an appropriate level of emissions control for semi-dry FGD control technology. The tighter emission ra te for both units is achievable with a negligible investment and the facility operator has offe red to undertake these actions to allow for refinement of the emissions rate appropriate for th is technology at this source despite the lack of appreciable modeled visibility improvement, and the state accepts this.

B. Filterable Particulate Matter (PM 10 )

Hayden Units 1 and 2 are each equipped with reve rse-air fabric filter baghouses to control PM/PM 10 emissions. Baghouses, or fabric filters, ope rate on the same principle as a vacuum cleaner. Air carrying dust partic les is forced through a cloth bag. As the air passes through the fabric, the dust accumulates on the cloth, providing a cleaner air stream. The dust is periodically removed from the cloth by shaking or by reversing the air flow. The layer of dust, known as dust cake, trapped on the surface of the fabric results in high efficiency rates for particles ranging in size from submicron to several hundred microns in diameter. Additionally, fabric filters are the best PM control for western coals, due to the higher electrical resistivity.

Table 13 shows the most recent stack test data (2009). Real-time data demonstrates that these baghouses are meeting >99% control. The Title V permit limit is 0.03 lb/MMBtu. The most recent stack test data is used to determine comp liance with the permit limit, which at a minimum, occurs every five years, and more frequently depending on the results.

Table 13: Hayden Units 1 and 2 Stack Test Results (2009) Pollutant Unit 1 (lb/MMBtu) Unit 2 (lb/MMBtu) Filterable PM 10 0.006 0.004 PM 10 Control efficiency 99.85% 99.91%

A Division review of EPA’s RBLC revealed recent BACT PM/PM 10 determinations ranging from 0.010 – 0.1 lbs/MMBtu, which are dependent on a number of factors, including PSD netting, EGU type and age, coal type, and adjacent controls (i.e. wet and dry FGD systems). The above stack test results are well below the ra nge of recent BACT determinations. While determinations made by other states do not di ctate the emissions rate choice made by theColorado Department of Public Health and Environment - Air Pollution Control Division

Best Available Retrofit Technology (BART) Analysis – PSCo Hayden Station Page 13 Division, they do provide information on the range to validate the emissions rate chosen by the Division. Refer to “Division RBLC Analysis” for more details.

Both boilers must meet the PM emission standa rd of 0.03 lb/MMBtu in accordance with the Long-Term Strategy Review and Revision of Colo rado’s SIP for Class I Visibility Protection Part I: Hayden Station Require ments (8/15/96), as approved by EPA at 62 FR 2305 (1/16/97), Section VI.C.V.8.c.ii(2).

The state has determined that the emission limit of 0.03 lb/MMBtu (PM/PM 10 ) represents the most stringent level of available control for PM/PM 10. The units are exceeding a PM control efficiency of 95%, and the state has selected this control technology and emission limit for PM/PM 10 as BART. The state assumes that the BART emission limit can be achieved through the operation of the existing fabric filter baghouses. Thus, as described in EPA’s BART Guidelines, a full five-factor analysis for PM/PM 10 is not needed for Hayden Units 1 and 2.

C. Nitrogen Oxide (NO x )

Step 1: Identify All Available Technologies PSCo identified three options for NO x control: Low NO x burners (next generation) Selective Non-Catalytic Reduction (SNCR) Selective Catalytic Reduction (SCR)

The Division also identified and examined th e following additional control options for these units: Electro-Catalytic Oxidation (ECO)® Rich Reagent Injection (RRI) Rotating overfire Air (ROFA) Separated overfire Air (SOFA) Low NO x Burners (LNB) LNB + SOFA Coal reburn +SNCR

Step 2: Eliminate Techni cally Infeasible Options Low NO x burners (PSCo – LNB): PSCo evaluated low NO x burner upgrades for Hayden Units 1 and 2, completing studies in July 2006. Units 1 and 2 currently have first-generation low NO x burners and over-fire air systems. The combus tion modifications include upgrades to these existing low NO x burners rather than complete burner re placements. In addition, changes to the over-fire air systems were also needed to achieve further NO x reductions on these units. LNB upgrades are technically feasib le for Hayden Units 1 and 2.

SNCR: Selective non-catalytic reduction is ge nerally utilized to achieve modest NO x reductions on smaller units. With SNCR, an amine-based reag ent such as ammonia or urea is injected into the furnace within a temperature range of 1,600°F to 2,100°F, where it reduces NO x to nitrogen and water. NO x reductions of up to 60% have been ach ieved, although 20-40% is more realistic for most applications. Reagent utilization, a measure of the effi ciency with which the reagentColorado Department of Public Health and Environment - Air Pollution Control Division

Best Available Retrofit Technology (BART) Analysis – PSCo Hayden Station Page 14 reduces NO x , can have a significant impact on ec onomics, with higher levels of NO x reduction generally resulting in lower reagent utilization a nd higher operating cost. SCNR is considered a technically feasible alterna tive for Hayden Units 1 and 2.

SCR: SCR systems are the most widely used post-combustion NO x control technology. In retrofit SCR systems, vaporized ammonia (NH 3 ) injected into the flue gas stream acts as a reducing agent, achieving NO x emission reductions as low as 0.07 lb/MMBtu when passed over an appropriate amount of catalyst as demonstrat ed by recent determinations found in the EPA’s RBLC database. The NO x and ammonia reagent form nitrog en and water vapor. The reaction mechanisms are very efficient with a reagen t stoichiometry of approximately 1.0 (on a NO x reduction basis) with very low ammonia slip.

While a lower controlled NO x emission values have been demonstrated by SCR system applications in new coal units, for Hayden, two retrofit SCR systems, the 0.07 lb/MMBtu controlled NO x value is more expected. The SCR reaction occurs within the temperature range of 550°F to 850°F where the extremes are highly de pendent on the fuel quality. There are three different types of SCR arrangements – high-dust, low-dust, and tail-e nd. The pre-dominant arrangement applied in the United States has been high-dust. In most circumstances, a high-dust SCR system is the most economical arrangemen t alternative. PSCo economically evaluated a high-dust SCR arrangement. SCR is a technically feasible alternative fo r Hayden Units 1 and 2.

ECO®: The Powerspan ECO® system is installed downstream of a coal-f ired power plants’ existing baghouse. The ECO® Reactor then oxidi zes pollutants, which are removed downstream in an absorber vessel during cooling and saturati on of the flue gas. This technology has not been demonstrated on a full-si ze pulverized coal-fired boiler 6 and thus, is considered technically infeasible.

RRI: Rich reagent injection is the process of adding NO x reducing agents in a staged lower furnace to reduce the formation of NO x , accomplished by injecting urea into the fuel-rich region of a furnace, where the reducing conditions in the lower furnace make RRI ideal for NO x reductions. The combustion process is then complete d with the use of overfir e air. Rich reagent injection was developed for cyclone boilers 7 and has not been demonstrated for other types of units. Therefore, RRI is considered t echnically infeasible for Units 1 and 2.

LNB/ROFA®/SOFA/LNB+SOFA: Hayden Units 1 and 2 are alr eady equipped with low NO x burners with over-fire air (LNB+O FA)as part of a consent decree entered by the District Court on August 19,1996, Civil Action 93-B-1749 and adopted into revisions to Co lorado’s Visibility SIP, specified in a document entitled “Long-Term Strategy Review and Revision of Colorado’s State Implementation Plan for Class I Visi bility Protection Part I: Hayden Station Requirements,” dated August 15, 1996. Table 1 illu strates that these systems achieve 49.5% and 43.3% NO x reductions (based on actual emissions) on Units 1 and 2, respectively.

ROFA® injects air into the furnace first to break up the fireball and then to create a cyclonic gas flow to improve combustion. ROFA® differs from OFA in that ROFA® utilizes a booster fan to

6 Powerspan ECO®: Overview and Advantages, 2000 – 2010. http://www.power span.com/ECO_overview.aspx

7 Fuel Tech: Air Pollution Control – Rich Reagent Injection (RRI), 1998 – 2009. http://www.ftek.com/apcRRI.phpColorado Department of Public Health and Environment - Air Pollution Control Division

Best Available Retrofit Technology (BART) Analysis – PSCo Hayden Station Page 15 increase the velocity of air to promote mixing a nd to increase the retention time in the furnace. To date, ROFA® has only been installed as a retrofit technology on units firing eastern bituminous coals.

Based on data published by the manufacturer , ROFA® technology has been reported as achieving NO x emission reductions from 45 to 65 % based on fuel load 8 . While ROFA is considered superior to SOFA alone, ROFA alone is not superior to LNB+SOFA and is not expected to increase emissions reductions fo r Hayden Units 1 and 2. Since ROFA® technology would not be expected to provide better emi ssions performance than the LNB+SOFA baseline for these units, ROFA® technology is not c onsidered further in this analysis.

Coal Reburn + SNCR: Several research and development ef forts in the United States evaluated using a combination of technologies to reduce NO x emissions, including combining coal reburn and SNCR. A novel injection pro cedure into the fuel -rich, post-combustion zone with staged, fuel-rich primary combustion and SN CR injection was found to reduce NO x emissions by 93% or well below 0.1 lb/MMBtu 9 . However, this procedure has not been performed on a full-size pulverized coal-fired boiler yet and thus, is considered technically infeasible.

Step 3: Evaluate Control Effectiveness of Each Remaining Technology

PSCo provided the Division 30-day rolling aver age control estimates. The Division, from experience and other state BART proposals 10 , determined that 30-day NO x rolling average emission rates are expected to be about 5 -15% higher than th e annual average emission rate. The Division projected an annual average emissi on rate at 15% for Hayde n to determine control efficiencies and a nnual reductions.

Low NO x burners (PSCo – LNB): PSCo stated in their April 20, 2010 submittal that Hayden Units 1 and 2 can meet a 30-day rolling limit of 0.30 lb/MMBtu and 0.24 lb/MMBtu respectively with upgraded low NO x burner systems. The baselines from Table 2 show that Hayden Unit 1 baseline NO x emissions are 0.415 lb/MMBtu and Unit 2 baseline NO x is 0.320 lb/MMBtu. Therefore, the control eff ectiveness for upgraded low NO x systems for Unit 1 is 37.1% and Unit 2 is 34.8%. As shown in Table 1, the current low-NO x burners with overfire air systems achieve 54.1% and 31.3% control respectively. These upgr ade control estimates are greater than EPA’s AP-42 emission factor table, which estimate LNB with OFA as achieving 40 – 60% reduction. 11 In a recent AWMA study, wall-fi red boilers burning sub-bituminous coal fitted with LNB+OFA system achieved NO x reductions from 40 – 80.9% (similar to Hayden Unit 1). Tangential-fired boilers achieved NO x reductions ranging from 11.3 – 74.4%. 12 With such wide control

8 Nalco-Mobotec, ROFA Technology, 1992-2009, http://www.nalcomobotec.com/technology/rofa-technology.html

9 Coal Tech. Corp, 2002. “Tests on Combined Stag ed Combustion, SNCR & Reburning for NOx Control and Combined NOx/SO2 Control on an Industrial & Utility Boilers.” http://www.netl.doe.gov/publications/proceedin gs/04/NOx/summary/h11.50zauderer-summary.pdf

10 State of North Dakota BART Determination for Le land Olds Station Units 1 and 2. Page 16.

11 EPA AP-42, Fifth Edition, Volume I, Chapter 1, Section 1.1, Table 1.1-2. http://www.epa.gov/ttn/chief/a p42/ch01/final/c01s01.pdf

12 Srivastava et. al, 2005. Nitrogen Oxides Emission Contro l Options for Coal-Fired Electric Utility Boilers. Journal of Air & Waste Management Association 55:1367 – 1388.Colorado Department of Public Health and Environment - Air Pollution Control Division

Best Available Retrofit Technology (BART) Analysis – PSCo Hayden Station Page 16 efficiency ranges, the Division concludes thatthe 88.9% and 66.1% (pre-control) reductions estimated by PSCo are reasonable.

SNCR: PSCo stated in their April 20, 2010 submitta l that Hayden Units 1 and 2 can meet a 30- day rolling limit of 0.30 lb/MMBtu and 0.21 lb/ MMBtu respectively by installing SNCR on each boiler. Therefore, the contro l effectiveness for SNCR on Unit 1 is 37.1% and Unit 2 is 43.0%. These control effectiveness estimate is consistent with EPA’s SNCR Air Pollution Control Technology Fact Sheet between 30 – 50% control efficiency for tangentially fired boilers. Control effectiveness has been hist orically noted to be lower for wall fired boilers similar to Unit 1. Therefore, the Division conc ludes that the reductions estimat ed by PSCo are reasonable.

SCR: PSCo stated in their April 20, 2010 submittal that Hayden Units 1 and 2 can meet a 30-day rolling limit of 0.08 lb/MMBtu and 0.07 lb/MMB tu respectively by installing SCR on each boiler. Therefore, the contro l effectiveness for SCR on Unit 1 is 83.2% and Unit 2 is 81.0%. These control efficiencies are consistent wi th EPA’s AP-42 emission factor tables, which estimate SCR as achieving 75 – 85% NO x emission reductions and al so with a recent AWMA study citing SCR as achieving 80 – 90% reduction. 13,14

Table 14 summarizes each available tec hnology and technical feasibility for NO x control.

Table 14: Hayden Units 1 and 2 NOx Tech nology Options and Technical Feasibility Technology Emission Reduction Potential (%) Technically Feasible? (Y = yes, N = no)

Low NO x Burner (LNB) Upgrade ~35 - 37% Y

SNCR 20 – 50% Y SCR 75 – 90% Y Electro-Catalytic Oxidation (ECO)® n/a N

Rich Reagent Injection (RRI) n/a N Low NO x Burners (LNB) 10-30% Y – installed LNB + OFA 25-45% Y – installed Air Staging – overfire air (OFA) 5-40% Y – installed

Rotating overfire air (ROFA) 45 – 65% N Coal reburn+SNCR n/a N

13 EPA AP-42, Fifth Edition, Volume I, Chapter 1, Section 1.1, Table 1.1-2. http://www.epa.gov/ttn/chief/a p42/ch01/final/c01s01.pdf

14 Srivastava et. al, 2005. Nitrogen Oxides Emission Contro l Options for Coal-Fired Electric Utility Boilers. Journal of Air & Waste Management Association 55:1367 – 1388.Colorado Department of Public Health and Environment - Air Pollution Control Division

Best Available Retrofit Technology (BART) Analysis – PSCo Hayden Station Page 17 Step 4: Evaluate Impacts and Document Results

Cost of Compliance

Low NO x burners (PSCo – LNB)/SNCR/SCR: PSCo completed engineer ing studies in July 2006 to evaluate the cost of combus tion controls on Hayden Units 1 and 2. These cost estimates, in 2006 dollars, were based on vendor data and not on actual bids with performance guarantees. PSCo used the Coal Utility Environmental Cost Workbook (CUECost) to develop cost estimates for capital and annual costs ,an EPA-appr oved methodology to estimate rough order-ofmagnitude (ROM) cost estimates for air pollution control systems installed on coal-fired power plants (± 30%). 15 PSCo provided CUECost input files at the Division’s request on April 20, 2010. PSCo used this program for LNB, SNCR, and SCR system estimates. The Division concurs that CUECost is an appropriate methodology for dete rmining cost effectiveness regarding these cont rol technologies.

LNB: In reviewing PSCo’s estimates, the Division f ound that the ratio of a nnual costs to the total costs for LNBs, which at 11.7% is consistent with an EPA assessment that concluded that other facilities in Arizona, New Mexico, a nd Oregon presented annual costs that ranged from 12 – 15% of total capital investments. 16 Therefore, the Division concludes that PSCo’s estimates for LNBs are reasonable.

SNCR: A typical breakdown of annua lized costs for SNCR on indus trial boilers will be 15 – 25% for capital recovery and 65 – 85% for operating expenses. 17 The PSCo-estimated SNCR costs for operating expenses are 74% and 77% for Hayden Units 1 and 2 respectively. Since SNCR is an operating expense-driven technology, its cost varies directly with NO x reduction requirements and reagent us age. There is a wide range of cost effectiveness for SNCR due to differentboiler configurations and site-specific conditions, even with a given industry. Co st effectiveness is impacted primarily by uncontrolled NO x level, required emission reductions , unit size and thermal efficiency, economic life of the unit, and degree of retrofit difficulty. 18

The cost effectiveness for SNCR on Units 1 and 2 is about $1,000 and $1,200 per ton, respectively. Recent NESCAUM studies estim ate SNCR retrofits on tangentially fired boilers (similar to Unit 2) achieving NO x emission rates of 0.30 – 0.40 lb/MMBtu and emission reductions of 30 – 50% as costing $630 - $1,300 per ton of NO x reduced,

15 2009, Yelverton, William H. “Coal Utility Enviro nmental Cost (CUECost) Workbook Development Documentation Version 5.0. Prepared by: ARCADIS, 4915 Prospectus Drive, Suite F, Durham, NC 27713. Prepared for: U.S. Environmental Protection Agency, Office of Research and Development, Air Pollution Prevention and Control Division, Research Triangle Park, NC 27711.

16 Environmental Protection Agency, 2009. 40 CFR Part 49 : Assessment of Anticipated Visibility Improvements at Surrounding Class I Areas and Cost Effectiveness of Best Available Retrofit Technology for Four Corners Power Plant and Navajo Generating Station: Advance Notice of Proposed Rulemaking. Pg. 44318.

17 ICAC, 2000. Institute of Clean Air Companies, Inc. “White Paper: Selective Non-Catalytic Reduction (SNCR) for Controlling NO x Emissions.” Washington, D.C. 2000.
18 EPA, 2003. “SNCR Air Pollution Control Technology Fact Sheet.” http://www.epa.gov/ttn/catc/dir1/fsncr.pdfColorado Department of Public Health and Environment - Air Pollution Control Division

Best Available Retrofit Technology (BART) Analysis – PSCo Hayden Station Page 18 depending on initial capital costs and capacity factor. 19,20 This same study estimate SNCR retrofits on wall fired boilers (sim ilar to Unit 1) achieving 0.50 – 0.65 lb/MMBtu and emission reductions of 30 – 50% as costing $590 - $1,100 per ton of NO x reduced, depending on initial capital costs and capacity factor. It should be noted that PSCo is estimating resultant emission rates lowe r than 0.30 lb/MMBtu for both boilers. EPA’s SNCR Fact Sheet cites SNCR as cos ting from $400 - $2,500 per ton of NO x reduced. 21 PSCo’s estimates are within this range. Therefore, the Division concludes that PSCo’s cost estimates for SNCR are reasonable.

SCR: Recent NESCAUM studies estimate SCR retrof its on tangentially fired boilers achieving NO x emission rates of 0.10 – 0.15 lb/MMBtu and emission reductions of 75 – 85% as costing $2,600 - $5,000 per ton of NO x reduced, depending on initial capital costs and capacity factor. 22,23 In reviewing PSCo’s estimates, th e Division found that the ratio of annual costs to the total costs for LNBs, whic h at 17% is higher than an EPA assessment that concluded that other facilities in Ariz ona, New Mexico, and Oregon presented annual costs that ranged from 12 – 15% of total capital investments. 24 However, PSCo’s cost estimates are within the NESCAUM study range s, so the Division concludes that PSCo’s cost estimates for SCR are reasonable.

Table 15, Table 16, Table 17, and Ta ble 18 depict controlled NO x emissions and control cost comparisons.

Table 15: Hayden Unit 1 Control Resultant NO x Emissions Alternative Control Efficiency (%) Resultant Emissions

Annual Emissions (tons/year) Annual Average (lb/MMBtu) 30-day Rolling Average

(lb/MMBtu) Baseline

--- 3,750 0.415
LNB* 37.1 2,359 0.261 0.300
SNCR* 37.1 2,359 0.261 0.300
SCR** 83.2 630 0.070 0.080 *Determined based on difference between baseline (2006 – 2008) and PSCo’s expected emission rates

19 Neuffer, Bill – ESD/OAQPS, 2003. “NO x Controls for Existing Utility Boilers.” http://www.epa.gov/ttn/nsr/gen/u3-26.pdf
20 Amar, Praveen, 2000. “Status Report on NOx Contro ls for Gas Turbines, Cement Kilns, Industrial Boilers, Internal Combustion Engines: Technologies & Cost Effectiveness.” Northeast States for Coordinated Air Use Management, 129 Portland Street, Boston, MA 02114.

21 EPA, 2003. “SNCR Air Pollution Control Technology Fact Sheet.” http://www.epa.gov/ttn/catc/dir1/fsncr.pdf

22 Neuffer, Bill – ESD/OAQPS, 2003. “NO x Controls for Existing Utility Boilers.” http://www.epa.gov/ttn/nsr/gen/u3-26.pdf

23 Amar, Praveen, 2000. “Status Report on NOx Contro ls for Gas Turbines, Cement Kilns, Industrial Boilers, Internal Combustion Engines: Technologies & Cost Effectiveness.” Northeast States for Coordinated Air Use Management, 129 Portland Street, Boston, MA 02114.

24 Environmental Protection Agency, 2009. 40 CFR Part 49 : Assessment of Anticipated Visibility Improvements at Surrounding Class I Areas and Cost Effectiveness of Best Available Retrofit Technology for Four Corners Power Plant and Navajo Generating Station: Advance Notice of Proposed Rulemaking. Pg. 44318.Colorado Department of Public Health and Environment - Air Pollution Control Division

Best Available Retrofit Technology (BART) Analysis – PSCo Hayden Station Page 19 **The Division calculated SCR reductions using a consistent baseline whereas PSCo uses an adjusted baseline depending on the control technology which results in different control costs.

Table 16: Hayden Unit 2 Control Resultant NO x Emissions Alternative Control Efficiency (%) Resultant Emissions

Annual Emissions (tons/year) Annual Average (lb/MMBtu) 30-day Rolling Average

(lb/MMBtu) Baseline

--- 3,743 0.320
LNB* 34.8 2,441 0.209 0.240
SNCR* 43.0 2,134 0.183 0.210
SCR** 81.0 711 0.061 0.070 *Determined based on difference between baseline (2006 – 2008) and PSCo’s expected emission rates **The Division calculated SCR reductions using a consistent baseline whereas PSCo uses an adjusted baseline depending on the control technology which results in different control costs.

Table 17: Hayden Unit 1 NO x Cost Comparisons Alternative Emissions Reduction (tpy) Annualized Cost ($) Cost Effectiveness ($/ton) Incremental Cost ($/ton)

Baseline 0 $0 $0

--- LNB 1,391 $572,010 $411 $411

SNCR 1,391 $1,353,500 $973

--- SCR 3,120 $10,560,612 $3,385 $5,326

Table 18: Hayden Unit 2NO x Cost Comparisons

Alternative Emissions Reduction (tpy) Annualized Cost ($) Cost Effectiveness ($/ton) Incremental Cost ($/ton)

Baseline 0 $0 $0

--- LNB 1,303 $992,729 $762 $762

SNCR 1,610 $1,893,258 $1,176 $2,934

SCR 3,032 $12,321,491 $4,064 $7,331

Energy and Non-Air Quality Impacts LNB: There are no known non-air quality impact s associated with upgrades on low-NO x burner systems. Energy impacts are not significant. Thus , this factor does not in fluence the selection of this control.

SNCR/ SCR: SCR retrofit impacts the existing flue gas fan systems, due to the additional pressure drop associated with the catalyst, which is typically a 6- to 8- inch water gage increase for the high temperature applications, and poten tially somewhat lower for the low temperature alternatives. In addition, any fl ue gas reheat requirements for the low temperature applications may require significant energy input to heat the fl ue gas. SCR reagent injection systems have minimal power requirements.Colorado Department of Public Health and Environment - Air Pollution Control Division

Best Available Retrofit Technology (BART) Analysis – PSCo Hayden Station Page 20 Post-combustion add-on control technologies su ch as SNCR do increase power needs, in the range of 100 – 300 kilowatts (kW) depending on th e boiler size, to operate pretreatment and injection equipment, drive the pumps and fans necessary to supply reagents, overcome additional pressure drops caused by the control equipmen t, and provide steam in some cases. 100 – 300 kW is less enough energy to power about 10 homes for a year. These energy requirements are minimal.

SCR systems require additional auxiliary power or power from the existing flue gas fan systems to overcome the pressure loss across the catalys t, to supply dilution air for mixing with the ammonia, and to pump ammonia into the vapori zer. These energy requirements are moderate.

Installing SNCR or SCR increases levels of ammonia, and may create a ‘blue plume’, if ammonia rates are not adequately controlled. Other environmental fa ctors include ammonia storage and transportation, particularly for a nhydrous ammonia. Anhydrous ammonia is clear in the liquid state and boils at a temperature of - 28°F. With its low boiling point, liquid anhydrous ammonia must be stored under pr essure at ambient temperatures to remain a liquid. With anhydrous ammonia, an invisible vapor or gas is formed as the liquid evaporates during depressurization. Accidental atmospheric release of a nhydrous ammonia vapor can be hazardous; therefore, stringent requirements for sa fety are enforced, and obtaining the permits to allow the storage of large quantities of anhydr ous ammonia may prove difficult in densely populated areas.

Remaining Useful Life PSCo asserts that there are no near-term limitations on the useful of these boilers, so it can be assumed that they will remain in service for th e 20-year amortization period. Thus, this factor does not influence the selection of controls.

Step 5: Evaluate Visibility Results CALPUFF modeling was used to determine the proj ected visibility improve ment associated with various control technologies. The modeling guid eline requires that modeled baseline emission rate is the 24-hour peak emission rate. The mode ling guideline also requires that, at a minimum, the presumptive emission rate scenario be modele d. Table 19 shows the nu mber of days pre- and post-control. Table 20 depicts the visibility results (98 th percentile impact and improvements) as well as cost effectiveness in $/deciview and the calcula tion methodology utilized by the Division.

Per the April 2010 modeling protocol 25 , to isolate the effects of a given unit for controls on a given pollutant, the Division has judiciously cons tructed each emissions scenario to isolate the impact of a given BART control on a given unit. For example, to determine the effect of a NO x BART control technology on a given unit, em ission rates for the ot her pollutants (SO 2 and PM/PM 10 ) and other BART-eligible units are held constant at pre- control levels. For BART

25 Colorado Air Pollution Control Division, Technical Se rvices Program, 2010. “Supplemental BART Analysis CALPUFF Protocol for Class I Federal Area Visibility Improvement Modeling Analysis.”Colorado Department of Public Health and Environment - Air Pollution Control Division

Best Available Retrofit Technology (BART) Analysis – PSCo Hayden Station Page 21 sources with more than one BART unit, modeli ng the units individually would ignore important atmospheric chemical reactions that occur when units operate simultaneously. The combination scenario assumed Units 1 and 2 with NO x emissions at 0.07 lb/MMBtu and SO 2 emissions at 0.12 lb/MMBtu.

In situations where the BART-eligible units at a given BART-eligible source operate simultaneously, the sulfate and nitrate estimates from the modeling system will be more realistic, in general, if all BART units and all pollutants at a BART-eligible source are modeled together. The combined unit approach has the added bene fit of allowing Colorado to estimate the net degree of visibility improvement from the simu ltaneous operation of BART controls on multiple units for multiple pollutants at a given BART-eligible source.

Table 19: Visibility Results – Change in Days >0.5 dv and >1.0 dv at highest affected Class I Area

NOx Control Scenario Boiler(s) NOx Emission Rate (lb/MMBtu)* Class I Area Affected 3-year totals 3-year totals

PreControl

Days >0.5 dv PostControl

Days >0.5 dv ∆ days PreControl

Days >1.0 dv PostControl

Days >1.0 dv ∆ days

Max 24- hr NOx

rates 1 0.610

Mt. Zirkel Wilderness Area 236 --- --- 155 --- --- 2 0.367

NOx Scenario 1 0.390 236 227 9 155 131 24

2 0.280 236 230 6 155 144 11

NOx Scenario 1 0.300 236 218 18 155 125 30

2 0.210 236 226 10 155 137 18

LNB 1 0.261* n/a

2 0.209* n/a

SNCR 1 0.261* n/a

2 0.183* n/a

SCR 1 0.070 236 188 48 155 91 64

2 0.070 236 213 23 155 116 39

Combo 1 0.070 236 57 179 155 6 149 2 0.070 * Denotes that output was interpolated by the Division and is not an actual modeled output. See “Hayden BART Modeling Summary” for more details.

Table 20: Visibility Results – NO x Control Options

NOx Control Scenario Boiler(s) NOx Emission Rate (lb/MMBtu)* Proposed Limit (@ 98 th Percentile

Impact) 98 th Percentile Impact Improvement 98 th Percentile Improvement from Maximum Cost Effectiveness

(deciviews) (deciviews) (%) ($/deciview)

Max 24-hr 1 0.610 3.63 --- --- ---Colorado Department of Public Health and Environment - Air Pollution Control Division

Best Available Retrofit Technology (BART) Analysis – PSCo Hayden Station Page 22 NOx rates 2 0.367

NOx Scenario 1 0.390 3.13 0.50 14% n/a

2 0.280 3.42 0.20 6% n/a

NOx Scenario 1 0.300 3.02 0.60 17% n/a

2 0.210 3.23 0.40 11% n/a

LNB 1 0.261* 2.94 0.69 19% $832,621 2 0.209* 3.23 0.40 11% $2,500,576

SNCR 1 0.261* 2.94 0.69 19% $1,970,161 2 0.183* 3.15 0.48 13% $3,969,094

SCR 1 0.070 2.51 1.12 31% $9,462,914 2 0.070 2.77 0.85 24% $14,427,975

Combo 1 0.070 0.91 2.72 75% n/a 2 0.070 * Denotes that output was interpolated by the Division and is not an actual modeled output. See “Hayden BART Modeling Summary” for more details.

Step 6: Select BART Control Based upon its consideration of the five factors su mmarized herein, the state has determined that NO x BART is the following NO x emission rates: Hayden Unit 1: 0.08 lb/MMBtu (30-day rolling average) Hayden Unit 2: 0.07 lb/MMBtu (30-day rolling average)

The state assumes that the BART emission lim its can be achieved thr ough the installation and operation of selective catalytic re duction (SCR). For these emission limits, the cost per ton of emissions removed, coupled with the estimated vi sibility improvements gained, falls within the guidance criteria presented in Chapter 6 of the Regional Haze State Implementation Plan:

• Unit 1: $3,385 per ton NO x removed; 1.12 deciview of improvement

• Unit 2: $4,064 per ton NO x removed; 0.85 deciview of improvement

The dollars per ton control costs, coupled with notable visibility improveme nts leads the state to this determination. The NO x emission limits of 0.08 lb/MMBtu (30-day rolling average) for Unit 1; and 0.07 lb/MMBtu (30-day rolling average) for Unit 2; are technically feasible and have been determined to be BART for Hayden Units 1 and 2.