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 $145,596,972Entergy'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 $366,784,526As 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 $15,240,194Escalated to 2013 Overhead (Entergy 2011 Dollars) 60% of fixed labor and material costs $2,987,400 $2,893,550Escalated 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 Johnson, 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 Scrubbing Costs." 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 G. Tracy Johnson, 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 this proposed rulemaking. White Bluff Wet FGDYear CEPCI Annual

Composite Index 2008 575.4 2009 521.9 2010 550.8 2011 585.7 2012 584.6 2013 567.3

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 Johnson, 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 Scrubbing Costs."
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 G. Tracy Johnson, 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 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)

2Entergy also includes annualized capital costs as an indirect annual cost, but we separate it out here, as its correction factor is significantly different. 1Uses 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

Entergy also includes annualized capital costs as an indirect annual cost, but we separate it out here, as its correction factor is significantly different. 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.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 SO2Removal 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($) 18,738,000Base reagent BMB($) 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 17,545,000Capital, engineering and construction cost subtotal

Capital, engineering and construction cost subtotal per kW Owner's costs including all "home office" costs (owner's engineering, management, and 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, electrical, etc.) Adjustment to base module balance of plant costs (including ID or booster fans, piping, ductwork, electrical, etc.), if elevation is greater than 500 feet. See page 2 of the S&L documentation. 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 difficulty 

### 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 fan power (Refer 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, else 12 operators 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)** Independence1
**<--- User Input (An "average" retrofit has a factor =1.0)** 2

**<--- User Input** 5 -yr avg. excluding max and min White Bluff1 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. 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, management, and Base reagent preparation and waste recycle/handling cost Base balance of plant costs (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. Adjustment to base module balance of plant costs (including ID or booster fans, piping, ductwork, electrical, etc.), if elevation is greater than 500 feet. See page 2 of the S&L documentation. Total Base module cost including retrofit factor

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 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.



### Costs are all based on 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.

FOM*(Gross Load)*(1000kw/MW)*(8760 hours/year) Variable O&M costs for limestone reagent

Variable O&M costs for additional auxiliary power required including additional fan power (Refer Total Project Cost per kW (including 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. Fixed O&M additional operating labor costs. IF MW > 500, then 16 operators, else 12 operators 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 per kW without AFUDC AFUDC (Based on a 3 year engineering and construction cycle)MW850

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**  **Potential Facilities to Analyze**



### Choices for Input BoxesFacility 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 SO2Removal 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($) 11,532,000Base reagent BMB($) 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 16,396,000Capital, engineering and construction cost subtotal

Capital, engineering and construction cost subtotal per kW Owner's costs including all "home office" costs (owner's engineering, management, and 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, electrical, etc.) Adjustment to base module balance of plant costs (including ID or booster fans, piping, ductwork, electrical, etc.), if elevation is greater than 500 feet. See page 2 of the S&L documentation. 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 difficulty 

### 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 fan power (Refer 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, else 12 operators 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)** Independence1
**<--- User Input (An "average" retrofit has a factor =1.0)** 2

**<--- User Input** 5 -yr avg. excluding max and min White Bluff1 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. 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, management, and Base reagent preparation and waste recycle/handling cost Base balance of plant costs (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. Adjustment to base module balance of plant costs (including ID or booster fans, piping, ductwork, electrical, etc.), if elevation is greater than 500 feet. See page 2 of the S&L documentation. Total Base module cost including retrofit factor

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 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.



### Costs are all based on 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.

FOM*(Gross Load)*(1000kw/MW)*(8760 hours/year) Variable O&M costs for limestone reagent

Variable O&M costs for additional auxiliary power required including additional fan power (Refer Total Project Cost per kW (including 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. Fixed O&M additional operating labor costs. IF MW > 500, then 16 operators, else 12 operators 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 per kW without AFUDC AFUDC (Based on a 3 year engineering and construction cycle)MW850

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**  **Potential Facilities to Analyze**



### Choices for Input Boxes