Item

Entergy Calculation 

Explanation

Entergy's Cost 

Estimates EPA (2013) EPA Comments

Capital Costs Unit 1 Unit 1

Total Equipment Costs (EC) (Entergy 2012 Dollars)1 $150,037,000 $145,596,972 Entergy's costs escalated to 2013

Purchased Equipment Cost (PEC)

PEC=1.18 X EC as 

per CCM $177,043,660 $171,804,428

Total Capital Investment (TCI) $389,496,052 $366,784,526

As per Table 1.3 of the CCM, Entergy calculated TCI = 

DC + IC = (1.85 * PEC) + Site Preparation + Bldg + (0.35 

* PEC). Costs escalated to 2013.

Direct Annual Costs (DC) (Entergy 2011 Dollars)2 $15,734,500 $15,240,194 Escalated to 2013

 Overhead (Entergy 2011 Dollars)

60% of fixed labor and 

material costs $2,987,400 $2,893,550 Escalated to 2013

 Administrative Charges

2% of TCI

$7,335,691

 Property Tax 1% of TCI $3,667,845

 Insurance 1% of TCI $3,667,845

Indirect Annual Costs (IC) $17,564,931

1: A breakdown of the Total Equipment Costs (EC) can be found in the June 10, 2013 letter addressed to Mike Bates, Air Division Chief, Arkansas Department of Environmental Quality, from G. Tracy Jo

 Arkansas Environmental Support, Entergy. See the section of the letter titled "EPA Region 6 Questions and Entergy Responses," Table 3 and "Attachment C: Supporting Documentation for Wet Scrubbi

 Acopy of the June 10, 2013 letter and its appendices is found in the docket for this proposed rulemaking. 

 

2: A breakdown of the Direct Annual Costs (DC) (2011 Dollars) can be found in the June 10, 2013 letter addressed to Mike Bates, Air Division Chief, Arkansas Department of Environmental Quality, from 

 Arkansas Environmental Support, Entergy. See the section of the letter titled "EPA Region 6 Questions and Entergy Responses," Table 4. A copy of the June 10, 2013 letter is found in the docket for th

 

White Bluff Wet FGD 
Year

CEPCI Annual 

Composite Index

2008 575.4

2009 521.9

2010 550.8

2011 585.7

2012 584.6

2013 567.3

tal Quality, from G. Tracy Johnson, 

cumentation for Wet Scrubbing Costs." 

Environmental Quality, from G. Tracy Johnson, 

r is found in the docket for this proposed rulemaking. 
Item

White Bluff 

Cost at 2.0 

lbs/MMBtu

Ratio of 0.68 

lb/MMBtu to 2.0 

lb/MMBtu1

Corrected White 

Bluff Cost to 0.68 

lbs/MMBtu

Annualized Capital Costs $29,557,846 0.9345 $27,621,162

Total Direct and Indirect Annual Costs2

$32,805,125 0.6677 $21,905,005

$49,526,167

7

30

0.0806

0.65

93.87

15,816

14,847

$3,336

Corrected White 

Bluff Cost to 0.68 

lbs/MMBtu

$49,526,167

7

30

0.0806

0.68

94.11

16,697

15,713

$3,152

Corrected White 

Bluff Cost to 0.68 

lbs/MMBtu

$49,526,167

7

30

0.0806

0.63

93.66

14,269

13,364

$3,706

Corrected White 

Bluff Cost to 0.68 

lbs/MMBtu

$49,526,167

7

30

0.0806

0.61

93.46

15,511

14,497

$3,416

Capital Recovery Factor (CRF)

SO2 Emission Rate (lbs/MMBtu)

Controlled SO2 Emission Rate (%)

SO2 Emission Baseline (tons)

SO2 Emission Reduction (tons)

2

 Entergy also includes annualized capital costs as an indirect annual cost, but we separate it out here, as its correction factor is significantly different.

1

 Uses the annualized capital and the sum of the fixed and variable operating costs from the "IPM WB 1 - 2 lb" and the "IPM WB 1 - 0.68 lb" tabs. 

Total Annualized Cost

Interest Rate (%)

Equipment Lifetime (years)

Capital Recovery Factor (CRF)

SO2 Emission Rate (lbs/MMBtu)

Controlled SO2 Emission Rate (%)

SO2 Emission Baseline (tons)

SO2 Emission Reduction (tons)

Cost Effectiveness ($/ton)

Item

Independence Unit 1

Item

Total Annualized Cost

White Bluff Unit 1

White Bluff Unit 2

Total Annualized Cost

Interest Rate (%)

Equipment Lifetime (years)

Cost Effectiveness ($/ton)

SO2 Emission Baseline (tons)

SO2 Emission Reduction (tons)

Cost Effectiveness ($/ton)

Independence Unit 2

Item

Interest Rate (%)

Equipment Lifetime (years)

Capital Recovery Factor (CRF)

SO2 Emission Rate (lbs/MMBtu)

Controlled SO2 Emission Rate (%)

Controlled SO2 Emission Rate (%)

SO2 Emission Baseline (tons)

SO2 Emission Reduction (tons)

Cost Effectiveness ($/ton)

Total Annualized Cost

Interest Rate (%)

Equipment Lifetime (years)

Capital Recovery Factor (CRF)

SO2 Emission Rate (lbs/MMBtu)
Comments

Using TCI from Entergy Costs tab

Sum of direct and indirect cost from Entergy Cost tab

Max monthly value from 2009-2013 for Unit 1

Assume 98%. If outlet < 0.04 lbs/MMBtu, then assume 

% control for 0.04 lbs/MMBtu.

3 -yr avg. 2009-2013 for Unit 1, excluding max and min

Comments

Assumed same as White Bluff Unit 1

Max monthly value from 2009-2013 for Unit 2

Assume 98%. If outlet < 0.04 lbs/MMBtu, then assume 

% control for 0.04 lbs/MMBtu.

3 -yr avg. 2009-2013 for Unit 2, excluding max and min

Comments

Assumed same as White Bluff Unit 1

Max monthly value from 2009-2013 for Unit 1

Assume 98%. If outlet < 0.04 lbs/MMBtu, then assume 

% control for 0.04 lbs/MMBtu.

3 -yr avg. 2009-2013 for Unit 1, excluding max and min

Comments

Assumed same as White Bluff Unit 1

Max monthly value from 2009-2013 for Unit 2

Assume 98%. If outlet < 0.04 lbs/MMBtu, then assume 

% control for 0.04 lbs/MMBtu.

3 -yr avg. 2009-2013 for Unit 2, excluding max and min

 it out here, as its correction factor is significantly different.

e "IPM WB 1 - 2 lb" and the "IPM WB 1 - 0.68 lb" tabs. 
Facility Unit

White Bluff 1

Variable Designation Units Value

Unit Size (Gross) A (MW) 850

Retrofit Factor B 1

Gross Heat Rate C (Btu/kWh)

10,770

SO2 Rate D (lb/MMBtu) 2.00

Type of Coal E PRB

Coal Factor F 1.05

Heat Rate Factor G 1.076998521

Heat Input H (Btu/Hr) 9,154,487,425

Operating SO2 Removal J (%) 98.00

Design Limestone Rate K (Ton/Hr) 16 

Design Waste Rate L (Ton/Hr) 29 

User Input ---> Include Aux Power in VOM M (%) 1.62 

Makeup Water Rate N (1000 gph) 75 

Limestone Cost P ($/Ton) 38

Waste Disposal Cost Q ($/Ton) 8.58

Aux Power Cost R ($/kWh) 0.047

Makeup Water Cost S ($/1000[gal]) 0.92

Operating Labor Rate T ($/hr) 40

Elevation adjustment if > 500 

Feet (feet) 0

Interest Rate (%) 7

Equipment Lifetime (years) 30

Gross Load (MW-hours) 6,275,922

SO2 Emission Baseline (tons/year) N/A

Capital Cost Calculation

BMR($) 78,690,000

BMF($) 31,826,000

BMW($) 18,738,000 Base reagent 

BMB($) 140,673,000

BMBA($) 140,673,000

BM($) 269,927,000

BM($/kW) 318

Total Project Cost

A1 26,993,000

A2 26,993,000

A3 26,993,000

CECC ($) 350,906,000

CECC($/kW) 413

B1 17,545,000

Capital, engineering and construction cost subtotal

Capital, engineering and construction cost subtotal per kW

Owner's costs including all "home office" costs (owner's engineering, manageme

procurement activities)

Contractor profit and fees. 

Base absorber island cost

Base reagent preparation and waste recycle/handling cost

Base balance of plant costs (including ID or booster fans, piping, ductwork, electr

Adjustment to base module balance of plant costs (including ID or booster fans, 

electrical, etc.), if elevation is greater than 500 feet. See page 2 of the S&L docu

Total Base module cost including retrofit factor

Base cost per kW

Engineering and Construction Mnagement costs

Labor adjustment for 6 x 10 hour shift premium, per diem, etc.

Includes: Equipment, installation, buildings, foundations, electrical, and retrofit d

Costs are all based on 2012 dollars

Explanation of Calculation 
TPC' ($) 368,451,000

TPC' ($/kw) 433

B2 36,845,000

TPC ($) 405,296,000

TPC ($/kW) 477

Fixed O&M Cost

FOMO ($/kW-yr) 1.57

FOMM ($/kW-yr) 4.76

FOMA ($/kW-yr) 0.10

FOM ($/kW-yr) 6.43

Variable O&M Cost

VOMR ($/MWh) 0.72

VOMW ($/MWh) 0.29

VOMP ($/MWh) 0.76

VOMM ($/MWh) 0.08

VOM ($/MWh) 1.85

Annualization

 Capital, engineering and 

construction cost $350,906,000

Capital Recovery factor 0.0806

Annualized capital costs $28,278,253

Variable operating costs $11,624,809

Fixed operating costs $4,609,278

Total annualized costs $44,512,339

SO2 emissions reduction (tons) N/A

$/ton N/A

FOM*(Gross Load)*(1000kw/MW)*(8760 hours/year)

J/(100%)*(SO2 emission baseline)

Excludes owner's costs and AFUDC

VOM*(Gross Load)

Total Fixed O&M costs

Variable O&M costs for limestone reagent

Variable O&M costs for waste disposal

Variable O&M costs for additional auxiliary power required including additional f

to Aux Power % above)

Variable O&M costs for makeup water

Total Variable O&M Costs

Total Project Cost per kW (including AFUDC and owner's costs)

Fixed O&M additional operating labor costs. IF MW > 500, then 16 operators, el

Fixed O&M additional maintenance material and labor costs

Fixed O&M additional administrative labor costs

Total Project Cost (including AFUDC and owner's costs)

Total project cost without AFUDC

Total project cost per kW without AFUDC

AFUDC (Based on a 3 year engineering and construction cycle)
Comments

Calculation Facility Unit

<--- User Input (Greater than 50 MW) Independence 1

<--- User Input (An "average" retrofit has a factor =1.0)

2

<--- User Input 5 -yr avg. excluding max and min

White Bluff 1

Avg. of months with full operating 

time 2

<--- User Input (PRB, BIT, or LIG)

If blending, run once for PRB and one 

for LIG

Bit=1, PRB=1.05, Lig=1.07

C/10000

A*C*1000

<--- User Input (Used to adjust actual operating costs)

Assume 98%. If outlet < 0.04 

lbs/MMBtu, then assume % control 

for 0.04 lbs/MMBtu.

(17.52*A*D*G/2000 (Based on 98% SO2 removal)

1.811*K (Based on 98% SO2 removal)

(1.05e^(0.155*D+1.3))*F*G

Assume aux power is included in 

VOM

(1.674*D+74.68)*A*F*G/1000

<--- User Input

<--- User Input default value

<--- User Input default value

<--- User Input default value

<--- User Input (Labor cost including all benefits) default value

<--- User Input (no entry needed if less than 500 feet) Default value - check elevation.

<---- User Input

<---- User Input

<---- User Input 5 -yr avg. excluding max and min

<---- User Input 5 -yr avg. excluding max and min

Comments

Excludes Owner's Costs.

Excludes Owner's Costs.

nstruction cost subtotal

nstruction cost subtotal per kW

home office" costs (owner's engineering, management, and 

nd waste recycle/handling cost

including ID or booster fans, piping, ductwork, electrical, etc.) The cost algorithms present an 

additional factor, BMWW, for a 

possible future base wastewater 

treatment facility. It is currently not 

used, so it is not included here.

 balance of plant costs (including ID or booster fans, piping, ductwork, 

s greater than 500 feet. See page 2 of the S&L documentation.

uding retrofit factor

n Mnagement costs

hour shift premium, per diem, etc.

ation, buildings, foundations, electrical, and retrofit difficulty

Potential Facilities to Analyze

S&L has a drop down menu for 

selection of an additional WWTP 

facility, but no capital or operational 

cost are implemented so it is not 

reproduced here.

n 2012 dollars

Explanation of Calculation 
Includes Owner's Costs

Includes Owner's Costs

Includes Owner's Costs and AFUDC

Includes Owner's Costs and AFUDC

In the calculation, the factor of "10" 

results from dividing the conversion 

from kilo to mega (1000) by 100% , 

since the input for M is a percentage.

w/MW)*(8760 hours/year)

stone reagent

tional auxiliary power required including additional fan power (Refer 

ncluding AFUDC and owner's costs)

The cost algorithms present 

additional factors, FOMWW and 

VOMWW, for a possible future base 

wastewater treatment facility. They 

are currently not used, so they are 

not included here.

ting labor costs. IF MW > 500, then 16 operators, else 12 operators

enance material and labor costs

nistrative labor costs

 AFUDC and owner's costs)

thout AFUDC

ngineering and construction cycle)
MW

850

850

850

Aux Power 

VOM 

Possibilities

Include Aux 

Power in 

VOM

Don't 

include Aux 

Power in 

VOM

850 Type of Coal BIT PRB LIG

Facilities to Analyze

Choices for Input Boxes 
Facility Unit

White Bluff 1

Variable Designation Units Value

Unit Size (Gross) A (MW) 850

Retrofit Factor B 1

Gross Heat Rate C (Btu/kWh)

10,770

SO2 Rate D (lb/MMBtu) 0.68

Type of Coal E PRB

Coal Factor F 1.05

Heat Rate Factor G 1.076998521

Heat Input H (Btu/Hr) 9,154,487,425

Operating SO2 Removal J (%) 94.12

Design Limestone Rate K (Ton/Hr) 5 

Design Waste Rate L (Ton/Hr) 10 

User Input ---> Include Aux Power in VOM M (%) 1.32 

Makeup Water Rate N (1000 gph) 73 

Limestone Cost P ($/Ton) 38

Waste Disposal Cost Q ($/Ton) 8.58

Aux Power Cost R ($/kWh) 0.047

Makeup Water Cost S ($/1000[gal]) 0.92

Operating Labor Rate T ($/hr) 40

Elevation adjustment if > 500 

Feet (feet) 0

Interest Rate (%) 7

Equipment Lifetime (years) 30

Gross Load (MW-hours) 6,275,922

SO2 Emission Baseline (tons/year) N/A

Capital Cost Calculation

BMR($) 77,010,000

BMF($) 23,027,000

BMW($) 11,532,000 Base reagent 

BMB($) 140,673,000

BMBA($) 140,673,000

BM($) 252,242,000

BM($/kW) 297

Total Project Cost

A1 25,224,000

A2 25,224,000

A3 25,224,000

CECC ($) 327,914,000

CECC($/kW) 386

B1 16,396,000

Capital, engineering and construction cost subtotal

Capital, engineering and construction cost subtotal per kW

Owner's costs including all "home office" costs (owner's engineering, manageme

procurement activities)

Contractor profit and fees. 

Base absorber island cost

Base reagent preparation and waste recycle/handling cost

Base balance of plant costs (including ID or booster fans, piping, ductwork, electr

Adjustment to base module balance of plant costs (including ID or booster fans, 

electrical, etc.), if elevation is greater than 500 feet. See page 2 of the S&L docu

Total Base module cost including retrofit factor

Base cost per kW

Engineering and Construction Mnagement costs

Labor adjustment for 6 x 10 hour shift premium, per diem, etc.

Includes: Equipment, installation, buildings, foundations, electrical, and retrofit d

Costs are all based on 2012 dollars

Explanation of Calculation 
TPC' ($) 344,310,000

TPC' ($/kw) 405

B2 34,431,000

TPC ($) 378,741,000

TPC ($/kW) 446

Fixed O&M Cost

FOMO ($/kW-yr) 1.57

FOMM ($/kW-yr) 4.45

FOMA ($/kW-yr) 0.10

FOM ($/kW-yr) 6.12

Variable O&M Cost

VOMR ($/MWh) 0.23

VOMW ($/MWh) 0.10

VOMP ($/MWh) 0.62

VOMM ($/MWh) 0.08

VOM ($/MWh) 1.03

Annualization

 Capital, engineering and 

construction cost $327,914,000

Capital Recovery factor 0.0806

Annualized capital costs $26,425,410

Variable operating costs $6,457,001

Fixed operating costs $4,383,006

Total annualized costs $37,265,416

SO2 emissions reduction (tons) N/A

$/ton N/A

FOM*(Gross Load)*(1000kw/MW)*(8760 hours/year)

J/(100%)*(SO2 emission baseline)

Excludes owner's costs and AFUDC

VOM*(Gross Load)

Total Fixed O&M costs

Variable O&M costs for limestone reagent

Variable O&M costs for waste disposal

Variable O&M costs for additional auxiliary power required including additional f

to Aux Power % above)

Variable O&M costs for makeup water

Total Variable O&M Costs

Total Project Cost per kW (including AFUDC and owner's costs)

Fixed O&M additional operating labor costs. IF MW > 500, then 16 operators, el

Fixed O&M additional maintenance material and labor costs

Fixed O&M additional administrative labor costs

Total Project Cost (including AFUDC and owner's costs)

Total project cost without AFUDC

Total project cost per kW without AFUDC

AFUDC (Based on a 3 year engineering and construction cycle)
Comments

Calculation Facility Unit

<--- User Input (Greater than 50 MW) Independence 1

<--- User Input (An "average" retrofit has a factor =1.0)

2

<--- User Input 5 -yr avg. excluding max and min

White Bluff 1

Avg. of months with full operating 

time 2

<--- User Input (PRB, BIT, or LIG)

If blending, run once for PRB and one 

for LIG

Bit=1, PRB=1.05, Lig=1.07

C/10000

A*C*1000

<--- User Input (Used to adjust actual operating costs)

Assume 98%. If outlet < 0.04 

lbs/MMBtu, then assume % control 

for 0.04 lbs/MMBtu.

(17.52*A*D*G/2000 (Based on 98% SO2 removal)

1.811*K (Based on 98% SO2 removal)

(1.05e^(0.155*D+1.3))*F*G

Assume aux power is included in 

VOM

(1.674*D+74.68)*A*F*G/1000

<--- User Input

<--- User Input default value

<--- User Input default value

<--- User Input default value

<--- User Input (Labor cost including all benefits) default value

<--- User Input (no entry needed if less than 500 feet) Default value - check elevation.

<---- User Input

<---- User Input

<---- User Input 5 -yr avg. excluding max and min

<---- User Input 5 -yr avg. excluding max and min

Comments

Excludes Owner's Costs.

Excludes Owner's Costs.

nstruction cost subtotal

nstruction cost subtotal per kW

home office" costs (owner's engineering, management, and 

nd waste recycle/handling cost

including ID or booster fans, piping, ductwork, electrical, etc.) The cost algorithms present an 

additional factor, BMWW, for a 

possible future base wastewater 

treatment facility. It is currently not 

used, so it is not included here.

 balance of plant costs (including ID or booster fans, piping, ductwork, 

s greater than 500 feet. See page 2 of the S&L documentation.

uding retrofit factor

n Mnagement costs

hour shift premium, per diem, etc.

ation, buildings, foundations, electrical, and retrofit difficulty

Potential Facilities to Analyze

S&L has a drop down menu for 

selection of an additional WWTP 

facility, but no capital or operational 

cost are implemented so it is not 

reproduced here.

n 2012 dollars

Explanation of Calculation 
Includes Owner's Costs

Includes Owner's Costs

Includes Owner's Costs and AFUDC

Includes Owner's Costs and AFUDC

In the calculation, the factor of "10" 

results from dividing the conversion 

from kilo to mega (1000) by 100% , 

since the input for M is a percentage.

w/MW)*(8760 hours/year)

stone reagent

tional auxiliary power required including additional fan power (Refer 

ncluding AFUDC and owner's costs)

The cost algorithms present 

additional factors, FOMWW and 

VOMWW, for a possible future base 

wastewater treatment facility. They 

are currently not used, so they are 

not included here.

ting labor costs. IF MW > 500, then 16 operators, else 12 operators

enance material and labor costs

nistrative labor costs

 AFUDC and owner's costs)

thout AFUDC

ngineering and construction cycle)
MW

850

850

850

Aux Power 

VOM 

Possibilities

Include Aux 

Power in 

VOM

Don't 

include Aux 

Power in 

VOM

850 Type of Coal BIT PRB LIG

Facilities to Analyze

Choices for Input Boxes