## Operating company Otter Tail Power PGE

Facility Big Stone Generating Station Boardman State SD OR

Proposed Controls SD/FF LSD/FF Unit #1 Boiler type cyclone wall-fired Fuel PRB PRB sub-bituminous Rating (MW Gross) 475 617 Presumptive BART limit (lb/mmBtu) or 0.15 0.15 Presumptive BART limit 95% 95% Reductions (tpy) 16,120 11,988 Capital Cost 141,300,000 $ 247,300,000 $ Capital Cost ($/kW ) 297 $ 401 $ Total Annual Cost 23,570,000 $ 36,600,000 $ Cost-Effectiveness ($/ton) 1,462 $ 3,053 $

Proposed BART Limit 0.09 0.12 units lb/mmBtu lb/mmBtu

Proposed BART Limit by SD DENR OR DEQ

Visibility analyses Visibility Improvement (dv at Max Class I) 0.156 1.04 Cost-Effectiveness ($/98th % dv at Max Class I) 51,350,763 $ 35,192,308 $ Visibility Improvement (dv at Summed Class I) 0.719 10.59 Cost-Effectiveness ($/98th % dv at Summed Class I) 32,759,951 $ 3,456,091 $

## Minnesota Power Dominion PacifiCorp PacifiCorp PacifiCorp

Boswell Energy Center Brayton Point Jim Bridger Jim Bridger Jim Bridger

MN MA WY WY WY

wet FGD 0.5% S residual oil FGD Upgrade FGD Upgrade FGD Upgrade Unit #3 #4 JB #1 JB #2 JB #3 tangential DB wall-fired tangential tangential tangential sub-bituminous #6 oil sub-bituminous sub-bituminous sub-bituminous 375 530 530 530 0.15 0.15 0.15 0.15 95% 95% 95% 95% 57,458 550 4,021 4,021 4,021 79,000,000 $

- $ 12,999,990 $ 12,999,990

$ 12,999,990

$ 211 $

- $ 25 $ 25

$ 25

$ 17,933,022 $ 1,728,198 $ 2,494,857 $ 2,494,857

$ 2,494,857

$ 1,640 $ 3,043 620 $ 620

$ 620

$

0.09 0.15 0.15 0.15 lb/mmBtu lb/mmBtu lb/mmBtu lb/mmBtu

0.5% S residual oil MPCA MassDEP PacifiCorp PacifiCorp PacifiCorp

1.02 33,919,486 $

## PacifiCorp Mirant Mirant Great River Energy Great River Energy

Jim Bridger Canal Station Canal Station Coal Creek Coal Creek WY MA MA ND ND

FGD Upgrade 0.5% S residual oil FGD Upgrade FGD Upgrade JB #4 #1 #2 #1 #2 tangential DB wall-fired DB wall-fired tangential tangential sub-bituminous #6 oil #6 oil ND lignite ND lignite 530 550 550 0.15 0.15 0.15 95% 95% 95% 1,656 20,760 20,760 5,759,814 $ 76,222,700 $ 76,222,700 $ 11 $ 139 $ 139 $ 1,206,614 $ $11,520,000 $11,520,000

729 $ $ 3,170 3,170 $ 555

$ 555 $

0.15 0.15 0.15 lb/mmBtu lb/mmBtu lb/mmBtu

0.5% S residual oil PacifiCorp MassDEP MassDEP ND DOH ND DOH

1.041 1.041 11,064,070 $ 11,064,070 $ 1.939 1.939 5,941,232 $ 5,941,232 $

## Colorado Springs Utilities PacifiCorp PacifiCorp

Martin Drake Martin Drake Dave Johnston Dave Johnston CO CO WY WY IL IL

new LSD new LSD Dry FGD+FF Dry FGD+FF new DSI+Trona new DSI+Trona #6 #7 DJ #3 DJ #4 #1 #2 wall-fired wall-fired wall-fired cell burner tangential cyclone cyclone bit/sub-bit mix bit/sub-bit mix sub-bituminous sub-bituminous sub-bituminous sub-bituminous 85 145 230 330 660 660 0.15 0.15 0.15 0.15 0.15 0.15 95% 95% 95% 95% 95% 95% 2,368 3,610 11,589 5,657 2,904 2,901 169,500,000 $ 222,776,105

$ 30,000,000

$ 30,000,000

$

- $

-

$ 737

$ 675

$ 45

$ 45

$ $6,665,771 $8,216,864 $21,419,765 $26,833,206 $12,410,000 $12,410,000 2,815 $ 2,276

$ 1,848

$ 4,743

$ 4,274

$ 4,277

$

0.13 0.13 0.15 0.15 0.18 0.18 lb/mmBtu lb/mmBtu lb/mmBtu lb/mmBtu lb/mmBtu lb/mmBtu

PacifiCorp PacifiCorp IL EPA IL EPA

0.240 0.390 1.217 1.017 27,774,046 $ 21,068,882

$ 16,703,531

$ 16,703,531

$ 2.049 1.673 9,439,943 $ 9,439,943

$ Dominion

Kincaid

## Xcel Energy PacifiCorp PacifiCorp PacifiCorp Basin Electric Power

King Laramie River Laramie River Laramie River Leland Olds MN WY WY WY ND

FGD upgrade Upgrade wet FGD Upgrade wet FGD existing Dry FGD FGD addition Unit #1 LRS #1 LRS #2 LRS #3 #1 cyclone wall-fired wall-fired wall-fired wall-fired sub-bituminous sub-bituminous sub-bituminous sub-bituminous ND lignite & PRB 550 550 550 550 216 0.15 0.15 0.15 0.15 0.15 95% 95% 95% 95% 95% 20,244 234 233 32,949

2,363,000 $ 2,363,000

$ 107,220,000 $ 4 $ 4

$ 496 $ 1,000,000 $ $366,000 $366,000 19,310,000 $ 49 $ 1,564

$ 1,571

$ 586 $

0.15 0.15 0.15 either 0.15 lb/mmBtu lb/mmBtu lb/mmBtu lb/mmBtu lb/mmBtu

or 95% reduction MPCA PacifiCorp PacifiCorp PacifiCorp ND DOH

1.216 15,885,246 $ 2.425

7,962,711 $

## Basin Electric Power Minnkota Power Boston Generating

Leland Olds MR Young MR Young Mystic Station ND ND ND ND MA

FGD addition FGD addition 95% FGD upgrade 90% FGD upgrade 0.5% S residual oil #2 #1 #2 #2 #7 cyclone cyclone cyclone cyclone tangential ND lignite & PRB ND lignite ND lignite ND lignite 1% S #6 oil 440 257 477 477 600 0.15 either 0.15 0.15 0.15 95% or 95% or 95% or 95% 64,465 20,443 14,898 29,630 147,600,000 $ 111,776,000

$ 24,989,000

$ 19,225,000

$ 335 $ 435

$ 52

$ 40

$ 29,840,000 $ 22,584,000

$ $8,414,000 $7,333,000 463 $ 1,105

$ 565

$ 247

$ $ 4,270

either 0.15 95% 95% either 0.15 lb/mmBtu lb/mmBtu

or 95% reduction or 95% reduction 0.5%

S residual oil ND DOH ND DOH ND DOH ND DOH MassDEP 95%

2.378 1.831 1.186 0.685 12,546,601 $ 12,331,999

$ 7,096,430

$ 10,705,109

$ 4.745 3.187 2.201 1.479 6,289,167 $ 7,085,547

$ 3,823,387

$ 4,958,080

$

## PacifiCorp PacifiCorp PacifiCorp Northshore Mining Rochester Public Utilities

Naughton Naughton Naughton Silver Bay Power Plant Silver Lake Plant WY WY WY MN MN

new wet FGD new wet FGD upgraded wet FGD DSI+FF dry FGD #1 #2 #3 Unit #2 Unit #4 tangential tangential tangential wall-fired wall-fired sub-bituminous sub-bituminous sub-bituminous sub-bituminous bituminous 160 210 330 75 60 0.15 0.15 0.15 0.15 0.15 95% 95% 95% 95% 95% 7,657 9,934 4,084 897 1,504 89,400,000 $ 117,400,000

$ 6,000,000

$ 46,360,000

$ 559 $ 559

$ 18

$ 618

$ $13,068,302 $16,889,165 $1,186,280 6,556,000 $ 1,707 $ 1,700

$ 290

$ 7,309

$

0.15 0.15 0.27 0.60 lb/mmBtu lb/mmBtu lb/mmBtu lb/mmBtu

PacifiCorp PacifiCorp MPCA MPCA

0.845 0.926 0.695 0.25 15,471,844 $ 18,244,289

$ 1,706,878

$ 26,224,000

$ 1.033 1.577 1.098 0.00028 12,650,331 $ 10,712,715

$ 1,080,401

$

## Dominion Xcel Energy Great River Energy

Salem Harbor Sherburne County Generating Station Stanton MA MN ND

0.5% S residual oil FGD upgrade FGD upgrade Proposed new LSD/FF Proposed new

LSD/FF #4 Unit #1 Unit #2 #1 #1 DB wall-fired tangential tangential wall-fired wall-fired #6 oil sub-bituminous sub-bituminous ND lignite PRB sub-bituminous 690 683 188 188 0.15 0.15 either 0.15 either 0.15 or 95% or 95% 550 4,200 4,200 8,438 5,594

3,700,000 $ 3,700,000

$ 79,514,000

$ not av ailable 5 $ 5

$ 423

$ not av ailable 1,728,198 $ 1,000,000

$ 990,000

$ $11,220,000 $11,220,000 3,043 238 $ 236

$ 1,330

$ 2,006

$

0.15 0.15 0.24 0.16 lb/mmBtu lb/mmBtu lb/mmBtu lb/mmBtu

0.5% S residual oil or 90% reduction or 90%

reduction MassDEP MPCA MPCA ND DOH ND DOH

1.38 0.275 0.275 0.772 0.512 25,082,697 $ 3,636,364

$ 3,600,000

$ 14,533,679

$ 21,922,100

$ 0.795 0.795 1.511 1.002 1,257,862 $ 1,245,283

$ 7,427,184

$ 11,202,909

$

## MN Power Florida Power & Light PacifiCorp

Taconite Harbor Wyman Wyodak MN ME WY

FSI and new FF 1% S #6 oil Upgraded Dry FGD & Fabric Filter Unit #3 3 tangential Tangentially-fired wall-fired bit/sub-bituminous 2%S #6 oil sub-bituminous 75 100 335 0.15 0.15 0.15 95% 95% 95%

880 1,190 6,272 15,508,000 $ 354 7,686,328 $ 207 $ 1.803 23 $ 1,868,000 $ 680,000 $ $8,954,051 5,300 $ 2,189 $ 1,428 $

0.32 0.90 0.16 lb/mmBtu lb/mmBtu lb/mmBtu

50.0% MPCA 4,699 PacifiCorp (4,345)

0.990 0.200 686,869 $ 44,730,957 $ 2.610 0.406 260,536 $ 22,055,587 $

## SO2 Summary Statistics BA RT at 37 EGUs Me dian Me an Ma x Rating (MW Gross) 475 393 690 Presumptive BA RT limit (lb/mmBtu) 0.15 0.15 0.15 Reductions (tpy ) 4,200 11,051 64,465 Capital Cost 30,000,000 $ 61,351,160

$ 247,300,000

$ Capital Cost ($/kW ) 45 $ 199

$ 737

$ Total Annual Cost 8,315,432 $ 10,113,639

$ 36,600,000

$ Cost-Effectiveness ($/ton) 1,571 $ 1,966

$ 7,309

$

Proposed BA RT Limit 0.15 0.25 0.95 units lb/m mB tu lb/m mB tu lb/m mB tu

Visibility analyses Visibility Improvement (dv at Max Class I) 0.926 0.863 2.378 Cost-Effectiveness ($/98th % dv at Max Class I) 15,885,246 $ 18,369,830

$ 51,350,763

$ Visibility Improvement (dv at Summed Class I) 1.577 2.084 10.590 Cost-Effectiveness ($/98th % dv at Summed Class I) 6,687,357 $ 8,249,505

$ 32,759,951

$

## Min Totals

60 14,558 0.15 233 408,881

- $ 1,901,885,971

$

- $ 131

$ 366,000 $ 364,091,007

$ 49 $ 890

$

0.09 lb/m mB tu

0.156 21.6 686,869 $ 16,873,755

$ 0.000 43.8 260,536 $ 8,317,828

$Operating company Otter Tail Power Facility Big Stone Generating Station State SD Contact

Proposed Controls SD/FF company report SD/FF DENR Unit #1 company report #1 DENR Boiler Type cyclone company report cyclone DENR Fuel PRB company report PRB DENR Rating (MW Gross) 475 company report 475 company report Presumptive BART limit (lb/mmBtu) 0.15 company report 0.15 DENR Rating (mmBtu/hr) 5,609 company report 5,609 DENR Current Emissions (tpy) 18,000 company report 18,000 DENR Current Emisison Rate (lb/mmBtu) 0.86 company report 0.86 company report

Cost-benefit Analyses Control Efficiency 90% company report 90% calculated New Emisison Rate (lb/mmBtu) 0.09 company report 0.09 DENR New Emissions (tpy) 1,880 company report 1,880 calculated Emissions Reduction (tpy) 16,120 company report 16,120 DENR Capital Cost 141,300,000 $ company report 141,300,000 $ DENR Capital Cost ($/kW) 297 $ calculated 297 $ calculated O&M Cost 7,660,000 $ company report 7,660,000 $ DENR Total Annual Cost 23,570,000 $ company report 23,570,000 $ DENR Cost-Effectiveness ($/ton) 1,462 $ company report 1,462 $ DENR

Proposed BART Limits Proposed BART limit (company) 0.09 company report Proposed BART limit (state) 0.09 DENR Effective Reduction from Current 90% calculated 90% calculated Effective BART Limit (tpy) 2,211 calculated 2,211 calculated Effective Reduction from Current (tpy) 15,789 calculated 15,789 calculated

Visibility analyses According to DENR: Visibility Impact before BART (dv at Max Class I) 1.079 company report 1.079 DENR 

### Otter Tail Power Company did not provide a cost per deciview reduction Visibility Impact after BART (dv at Max Class I) 0.620 company report 0.923 calculated for each of the proposed control options. DENR calculated a cost per deciview Visibility Improvement (dv at Max Class I) 0.459 calculated 0.156 calculated reduction by summing the annualized cost of each of the control alternatives Cost-Effectiveness ($/98th % dv at Max Class I) 51,350,763 $ calculated $51,350,763 DENR associated with the control options and dividing by the visibility reduction Pollutant Control Effectiveness (dv/ton) 0.000028 calculated 0.000010 calculated identified by the modeling from the baseline condition. Visibility Impact before BART (dv at Summed Class I) 3.447 calculated 3.447 calculated (calculated by NPS for seven Class I areas modeled by company) Visibility Impact after BART (dv at Summed Class I) 2.73 calculated 2.73 calculated (calculated by NPS for seven Class I areas modeled by company) Visibility Improvement (dv at Summed Class I) 0.719 calculated 0.719 calculated (calculated by NPS for seven Class I areas modeled by company) Cost-Effectiveness ($/98th % dv at Summed Class I) 32,759,951 $ calculated 32,759,951 $ calculated (calculated by NPS for seven Class I areas modeled by company) Pollutant Control Effectiveness (dv/ton) 0.000045 calculated 0.000045 calculated (calculated by NPS for seven Class I areas modeled by company)Operating company PGE Facility Boardman State OR Contact Brian Finneran finneran.brian@deq.state.or.us 503-229-6278

Proposed Controls OR DEQ recommended LSD/FF Boiler type wall-fired OR DEQ BART Report subcritical, opposed wallFuel PRB sub-bituminous OR DEQ BART Report fired boiler that operates on balanced draft. Rating (MW Gross) 617 OR DEQ BART Report Presumptive BART limit (lb/mmBtu) or 0.15 BART Guidelines > 200 MW only low-sulfur Presumptive BART limit 95% BART Guidelines > 200 (~0.3% by weight) sub-bituminous coal from the Powder River Basin in Wyoming has been Rating (mmBtu/hr) 5,793 Company report burned in the boiler, although other types of coal could be fired Current Actual Control Efficiency 0% OR DEQ BART Report Current Emissions (tpy) 14,037 OR DEQ BART Report Sulfur dioxide: Current Emisison Rate (lb/mmBtu) 1.2 OR DEQ BART Report The Department considers a semi-dry flue gas desulfurization system to be BART for the Cost-benefit Analyses following reasons: Reduction 90% calculated New Emisison Rate (lb/mmBtu) 0.12 OR DEQ BART Report The Department recommends semi-dry flue gas desulfurization (SDFGD) as BART New Emissions (tpy) 2,049 calculated because it provides slightly more visibility improvement than wet flue gas desulfurization Reductions (tpy) 11,988 OR DEQ BART Report and the cost is $135 million dollars less. Capital Cost 247,300,000 $ OR DEQ BART Report SDFGD is consistent with EPA’s BART analysis for coal fired electric generating units Capital Cost ($/kW) 401 $ OR DEQ BART Report greater than 200 MW located at 750 MW plants. The unit at the Boardman plant is 617 O&M Cost MW even though the plant is less than 750 MW. Total Annual Cost 36,600,000 $ OR DEQ BART Report EPA expected that a semi-dry flue gas desulfurization system can achieve 90% emissions Cost-Effectiveness ($/ton) 3,053 $ OR DEQ BART Report reductions or 0.15 lb/mmBtu heat input. The Department’s proposed control effectiveness of 0.12 lb/mmBtu heat input is more stringent than EPA’s BART analysis. Proposed BART Limit 0.12 OR DEQ BART Report The control effectiveness proposed by the Department is actually slightly better than Effective Reduction from Current 90% calculated demonstrated in practice at similar units. Effective BART Limit (tpy) 3,045 calculated A wet flue gas desulfurization system has the following negative drawbacks: Effective Reduction from Current 11,988 calculated o More water is required for a wet system and the plant is located in a semi-arid Visibility analyses region. Visibility Improvement (dv at Max Class I) 1.04 OR DEQ BART Report o The water will have to be treated to avoid water pollution Cost-Effectiveness ($/98th % dv at Max Class I) 35,192,308 $ calculated o A wet/visible plume will be present almost all of the time Pollutant Control Effectiveness (dv/ton) 0.00009 calculated o The wet exhaust gas is corrosive, requiring more maintenance of the duct work Visibility Improvement (dv at Summed Class I) 10.59 OR DEQ BART Report and stack Cost-Effectiveness ($/98th % dv at Summed Class I) 3,456,091 $ calculated o An additional fabric filter will have to be added to be compatible with potential Pollutant Control Effectiveness (dv/ton) 0.00088 calculated mercury controls o The existing stack will have to be replaced with a new corrosion resistant stack.

### Operating Company Minnesota Power Facility Name Boswell Energy Center Contact Anne Jackson Distance to nearest Class I Area (km) # of Class I Areas evaluated/within 300 km 0 of 4

Data Source Proposed Controls wet FGD MPCA report EGU Unit #3 Boiler type tangential MPCA report Fuel sub-bituminous MPCA report Rating each (MW gross) 375 MPCA report Presumptive BART limit (lb/mmBtu) 0.15 BART Guidelines EGU >200 MW at facility >750 MW Heat Input (mmBtu/hr) 3,750 NPS estimate Current Emissions (tpy) 58,780 MPCA report Current Emisison Rate (lb/mmBtu) 0.95 company report

Cost-benefit Analyses Control Efficiency 91% calculated New Emisison Rate (lb/mmBtu) 0.09 MPCA report New Emissions (tpy) 1,322 MPCA report Emissions Reduction (tpy) 57,458 MPCA report Capital Cost 79,000,000 $ company report Capital Cost ($/kW ) 211 $ calculated O&M Cost 6,500,000 $ company report Total Annual Cost 17,933,022 $ company report Cost-Effectiveness ($/ton) 1,640 $ company report

Proposed BART limit (lb/mmBtu) 0.09 MPCA report The MPCA issued permit no. 06100004-003 on March 28, 2007 that allows Power boiler No. 3 Effective Reduction from Current 91% calculated to be retrofitted with Low NOX burners, over fire air and selective catalytic reduction for Effective BART Limit (tpy) 1,478 calculated nitrogen oxides control. It will be retrofitted with a baghouse filter for particulate and mercury Effective Reduction from Current (tpy) 57,302 calculated control, and finally, with a wet scrubber for SO2 control. Currently the only control equipment serving the boiler is a wet scrubber for particulate emissions. Combustion controls will be Visibility analyses not done installed and/or updated for CO control. Visibility Improvement (dv at Max Class I) Cost-Effectiveness ($/98th % dv at Max Class I) Pollutant Control Effectiveness (dv/ton) Visibility Improvement (dv at Summed Class I) Cost-Effectiveness ($/98th % dv at Summed Class I) Pollutant Control Effectiveness (dv/ton)

## Operating company Dominion Facility Brayton Point State MA Contact Glenn Keith

Proposed Controls 0.5% S residual oil Unit #4 Boiler Type DB wall-fired Fuel #6 oil Rating (MW Gross) each Presumptiv e BA RT limit (lb/mmBtu) Rating (mmBtu/hr) 4,800 company report 2002 Actual Emissions (tpy) 2,037 MassDEP 2002 Actual Emissions (lb/mmBtu) 0.85 2002 CAM data 2007 Actual Emissions (tpy) 741 MassDEP 2007 Actual Emissions (lb/mmBtu) 0.90 2007 CAM data Current Actual Control Efficiency -6% calculated

Cost-benefit A nalysis Emission Reductions (tpy) 568 company report Emission Reductions (tpy) 550 calculated @ 5% utilization Capital Cost 0 company report Capital Cost ($/kW ) 0 company report O&M Cost 1,718,629 $ calculated @ 5% utilization Annualized Cost 1,728,198 $ company report Cost-Effectiveness ($/ton) 3,043 MassDEP

Proposed BA RT Limits Proposed BART Limit (company) 1% S residual oil Proposed State BA RT Limit 0.5% S residual oil 0.53 lb/mmBtu Effective Reduction from Current 41%

Visibility A nalyses Visibility Improvement (dv at Max Class I) 1.02 company report Cost-Effectiveness ($/98th % dv at Max Class I) 33,919,486 $ MassDEP (based upon AECOM calculation @ 100% utilization) Pollutant Control Effectiveness (dv/ton) 0.0019 calculated Visibility Improvement (dv at Summed Class I) Cost-Effectiveness ($/98th % dv at Summed Class I) Pollutant Control Effectiveness (dv/ton)Operating company PacifiCorp Facility Jim Bridger State WY Contact

Proposed Controls FGD Upgrade FGD Upgrade FGD Upgrade FGD Upgrade FGD Upgrade Unit Combined JB #1 JB #2 JB #3 JB #4 Boiler Type tangential tangential tangential tangential WY DEQ report Fuel sub-bituminous sub-bituminous sub-bituminous sub-bituminous WY DEQ report Rating (MW Gross) each 2,120 530 530 530 530 WY DEQ report Presumptive BART limit (lb/mmBtu) 0.15 0.15 0.15 0.15 BART Guidelines > 200 MW at facility > 750 MW Presumptive BART limit 95% 95% 95% 95% BART Guidelines > 200 MW at facility > 750 MW Rating (mmBtu/hr) 24,000 6,000 6,000 6,000 6,000 WY DEQ report Current Uncontrolled Emissions (tpy) 113,496 28,374 28,374 28,374 28,374 Company report Current Uncontrolled Emissions (lb/mmBtu) 1.20 1.20 1.20 1.20 Company report Current Actual Emissions (tpy) 23,179 6,386 6,386 6,386 4,021 WY DEQ report Current Actual Emissions (lb/mmBtu) 0.27 0.27 0.27 0.17 WY DEQ report Current Actual Control Efficiency 78% 78% 78% 86% Company report

Cost-benefit Analysis Upgraded Overall Control Efficiency 91.7% 91.7% 91.7% 91.7% calculated Upgraded Controlled Emissions (lb/mmBtu) 0.10 0.10 0.10 0.10 WY DEQ report Upgraded Controlled emissions (tpy) 9,460 2,365 2,365 2,365 2,365 WY DEQ report Reduction due to Upgrade 63.0% 63.0% 63.0% 41.2% calculated Emission Reductions (tpy) 13,719 4,021 4,021 4,021 1,656 WY DEQ report Capital Cost 44,759,784 $ 12,999,990

$ 12,999,990

$ 12,999,990

$ 5,759,814

$ WY

DEQ report Capital Cost ($/kW) 21 $ 25

$ 25

$ 25

$ 11

$ calculated O&M Cost 4,433,211 $ 1,258,176

$ 1,258,176

$ 1,258,176

$ 658,683

$ WY

DEQ report Annualized Cost 8,691,185 $ 2,494,857

$ 2,494,857

$ 2,494,857

$ 1,206,614

$ WY

DEQ report Cost-Effectiveness ($/ton) 634 $ 620

$ 620

$ 620

$ 729

$ WY

DEQ report

Proposed BART Limits Proposed BART Limit (company) 0.15 0.15 0.15 0.15 Company report Proposed State BART Limit--either lb/mmBtu (30-day rolling average) Proposed State BART Limit--either reduction (30-day rolling average) Effective Reduction from Current 44% 44% 44% 12% calculated Effective BART Limit (tpy) 3,942 3,942 3,942 3,942 calculated Effective Reduction from Current 2,444 2,444 2,444 79 tpy

Visibility Analyses Visibility Impact before BART (dv at Max Class I) 4.759 1.321 0.884 1.317 1.237 Company report Visibility Impact after BART (dv at Max Class I) Visibility Improvement (dv at Max Class I) 0.000 no modeling results for SO2 controls alone Cost-Effectiveness ($/98th % dv at Max Class I) #DIV/0! calculated Pollutant Control Effectiveness (dv/ton)

- - - - - Visibility Impact before BART (dv at Summed Class I) 10.152 2.804 1.933 2.802 2.613 calculated Visibility Impact after BART (dv at Summed Class I) Visibility Improvement (dv at Summed Class I) 0.000 no modeling results for SO2 controls alone Cost-Effectiveness ($/98th % dv at Summed Class I) #DIV/0! calculated Pollutant Control Effectiveness (dv/ton)

- - - - - calculated

## Operating company Mirant Facility Canal Station State MA Contact Glenn Keith

Proposed Controls 0.5% S residual oil Unit #1 #2 Boiler Type DB wall-fired DB wall-fired Fuel #6 oil #6 oil Rating (MW Gross) each Presumptive BA RT limit (lb/mmBtu) Rating (mmBtu/hr) 2002 Actual Emissions (tpy) 13,066 8,948 MassDEP 2002 Actual Emissions (lb/mmBtu) 0.96 0.92 2002 CAM data 2007 Actual Emissions (tpy) 5,169 1,506 MassDEP 2007 Actual Emissions (lb/mmBtu) 0.54 0.50 2007 CAM data Current Actual Control Efficiency 43% 46% calculated

Cost-benefit A naly sis Emission Reductions (tpy) Capital Cost Capital Cost ($/kW ) O&M Cost Annualized Cost Cost-Effectiveness ($/ton) 3,170 $ 3,170

$ MassDEP

Proposed BA RT Limits Proposed BART Limit (company) 1% S residual oil Proposed State BA RT Limit 0.5% S residual oil 0.53 lb/mmBtu Effective Reduction from Current 3% -6%

Visibility

A naly ses no visibility analyses preformed Visibility Improvement (dv at Max Class I) Cost-Effectiveness ($/98th % dv at Max Class I) Pollutant Control Effectiveness (dv/ton) Visibility Improvement (dv at Summed Class I) Cost-Effectiveness ($/98th % dv at Summed Class I) Pollutant Control Effectiveness (dv/ton)Operating company Great River Energy Facility Coal Creek State ND Contact Tom Bachman tbachman@nd.gov (701) 328-5188 Distance to nearest Class I Area (km) # of Class I Areas evaluated/within 300 km 2 of 2

Proposed Controls FGD Upgrade FGD Upgrade Unit #1 #2 Boiler Type tangential tangential Fuel ND lignite ND lignite Rating (MW Gross) each 550 550 ND DOH report Presumptive BART limit (lb/mmBtu) 0.15 0.15 BART Guidelines > 200 MW at facility > 750 MW Presumptive BART limit 95% 95% BART Guidelines > 200 MW at facility > 750 MW Rating (mmBtu/hr) 6,015 6,022 ND DOH report Current sulfur content 0.61% 0.61% ND DOH report Current Uncontrolled Emissions (lb/mmBtu) 0.82 0.75 calculated A four-module flue gas desulfurization (FGD) system for each Current Actual Emissions (tpy) 14,086 12,407 ND DOH report boiler removes approximately 90% of the sulfur dioxide from 60% of Current Actual Emissions (lb/mmBtu) 0.56 0.51 ND DOH report the flue gas. Each boiler is served by a 655 foot high stack.

Cost-benefit Analysis Baseline sulfur content 1.10% 1.10% ND DOH report Baseline Uncontrolled Emissions (tpy) 76,888 76,888 ND DOH report The evaluation of alternative SO2 cleaning Baseline Uncontrolled Emissions (lb/mmBtu) 1.49 1.35 calculated Current Controlled Emissions (tpy) 24,604 24,604 ND DOH report equipment will be based on future dried coal with an expected Currrent Control Efficiency 68% 68% ND DOH report worst case (98 percentile) sulfur content of 1.10%, as Upgraded Overall Control Efficiency 95% 95% ND DOH report predicted for Falkirk coal and provided by GRE. Therefore, Upgraded Controlled Emissions (lb/mmBtu) 0.146 0.146 ND DOH report the uncontrolled baseline SO2 emissions above must be adjusted Controlled emissions (tpy) 3,844 3,844 ND DOH report to the future sulfur content so that an apples to apples Reduction due to Upgrade 74% 71% calculated comparison will correctly determine emission reductions Emission Reductions (tpy) 20,760 20,760 ND DOH report expected to result from employing the alternative equipment. Capital Cost 76,222,700 $ 76,222,700 $ GRE report Capital Cost ($/kW ) 139 $ 139 $ calculated O&M Cost 2,090,296 $ 2,090,296 $ GRE report Annualized Cost $11,520,000 $11,520,000 ND DOH report Cost-Effectiveness ($/ton) 555 $ 555 $ ND DOH report

Proposed BART Limits Proposed BART Limit (company) 0.15 0.15 GRE report The Department proposes that BART is scrubbing 100% of the Proposed State BART Limit--either 0.15 0.15 lb/mmBtu (30-day rolling average) flue gas stream, the use of wet scrubber modifications to Proposed State BART Limit--either 95% 95% reduction (30-day rolling average) achieve a minimum control efficiency of 94% (30-day rolling Effective Reduction from Current 73% 71% calculated average) on the inlet sulfur dioxide concentration to the Effective BART Limit (tpy) 3,952 3,956 calculated scrubber or 0.15 lb/106 Btu (30-day rolling average). Unit 1 Effective Reduction from Current (tpy) 10,134 8,451 calculated and Unit 2 emissions may be averaged provided the average does Effective Reduction from Current (tpy) 72% 68% reduction not exceed the limit. Effective Reduction from Current (lb/mmBtu) basis) 73% 71% reduction Effective Reduction from Future (lb/mmBtu) basis) 90% 89% reduction Effective Reduction from Future (tpy) 72,936 72,932 tpy Effective Reduction from Future (tpy) 95% 95% reduction

Visibility Analyses Visibility Improvement (dv at Max Class I) 1.041 1.041 calculated Cost-Effectiveness ($/98th % dv at Max Class I) 11,064,070 $ 11,064,070 $ calculated Pollutant Control Effectiveness (dv/ton) 0.00005 0.00005 calculated Visibility Improvement (dv at Summed Class I) 1.939 1.939 calculated Cost-Effectiveness ($/98th % dv at Summed Class I) 5,941,232 $ 5,941,232 $ calculated Pollutant Control Effectiveness (dv/ton) 0.00009 0.00009 calculatedOperating company Colorado Springs Utilities Facility Martin Drake State CO Contact Jim Geier james.geier@state.co.us (303) 692-3167

Proposed Controls new LSD new LSD Unit #6 #7 Boiler Type wall-fired wall-fired CDPHE report Fuel bit/sub-bit mix bit/sub-bit mix CSU report Rating (MW Gross) each 85 145 CDPHE report Presumptive BART limit (lb/mmBtu) or 0.15 0.15 BART Guidelines Presumptive BART limit 95% 95% BART Guidelines Rating (mmBtu/hr) 850 1,336 CDPHE report Current Emissions (tpy) Current Emissions (lb/mmBtu) 1.00 0.99 CDPHE report

CDPHE Cost-benefit Analysis Future Uncontrolled Emissions (lb/mmBtu)

- - Future Uncontrolled Emissions (tpy) Overall Control Efficiency (FGD) 85% 85% CDPHE report Controlled Emissions (lb/mmBtu) Controlled emissions (tpy) Emission Reductions (tpy) 2,368 3,610 CDPHE report Capital Cost Capital Cost ($/kW)

- $

- $ calculated O&M Cost Annualized Cost $6,665,771 $8,216,864 CDPHE report Cost-Effectiveness ($/ton) 2,815 $ 2,276 $ CDPHE report

Proposed BART Limits Proposed BART Limit (company) none none CSU report Accordingly, as part of its five factor consideration the state has elected to generally Proposed BART Limit (CDPHE) 0.13 0.13 lb/mmBtu 30-day rolling average employ criteria for NOx post-combustion control options to aid in the assessment and Effective Reduction from Current determinations for BART – a $/ton of NOx removed cap, and two minimum applicable Effective BART Limit (tpy) Δdv improvement figures relating to CALPUFF modeling for certain emissions control types, as follows. Visibility analyses - For the highest-performing NOx post-combustion control options (i.e., SCR Visibility Improvement (dv at Max Class I) 0.240 0.390 CDPHE report systems for electric generating units) that do not exceed $5,000/ton of pollutant Cost-Effectiveness ($/98th % dv at Max Class I) 27,774,046 $ 21,068,882 $ calculated reduced by the state’s calculation, and which provide a modeled visibility benefit Pollutant Control Effectiveness (dv/ton) 0.00010 0.00011 calculated from CDPHE report on 0.50 Δdv or greater at the primary Class I Area affected, that level of control is Visibility Improvement (dv at Summed Class I) not provided generally viewed as reasonable. Cost-Effectiveness ($/98th % dv at Summed Class I) not provided - For lesser-performing NOx post-combustion control options (e.g., SNCR Pollutant Control Effectiveness (dv/ton) not provided technologies for electric generating units) that do not exceed $5,000/ton of pollutant reduced by the state’s calculation, and which provide a modeled visibility benefit of 0.20 Δdv or greater at the primary Class I Area affected, that level of control is generally viewed as reasonable.Operating company PacifiCorp Facility Dave Johnston State WY Contact

Proposed Controls Dry FGD+FF Dry FGD+FF Unit Combined DJ #3 DJ #4 Boiler Type wall-fired cell burner tangential Company report Fuel sub-bituminous sub-bituminous Company report Rating (MW Gross) 560 230 330 Company report Presumptive BART limit (lb/mmBtu) 0.15 0.15 0.15 BART Guidelines > 200 MW at facility > 750 MW Presumptive BART limit 95% 95% 95% BART Guidelines > 200 MW at facility > 750 MW Rating (mmBtu/hr) 6,600 2,500 4,100 Company report Current Emissions (tpy) 21,398 13,316 8,082 Company report Current Emission Rate (lb/mmBtu) 1.21 0.50 Company report

Cost-benefit Analyses Control Efficiency 87.6% 70.0% Company report New Emisison Rate (lb/mmBtu) 0.15 0.15 Company report New Emissions (tpy) 4,081 1,656 2,425 Company report Emissions Reduction (tpy) 17,246 11,589 5,657 Company report Capital Cost 392,276,105 $ 169,500,000 $ 222,776,105 $ Company report Capital Cost ($/kW) 700 $ 737 $ 675 $ calculated O&M Cost 10,936,598 $ $5,295,598 $5,641,000 Company report Total Annual Cost 48,252,971 $ $21,419,765 $26,833,206 Company report Cost-Effectiveness ($/ton) 2,798 $ 1,848 $ 4,743 $ Company report

Proposed BART Limits Proposed BART limit (company) 0.15 0.15 Company report Effective Reduction from Current 87.6% 70.0% Company report Effective BART Limit (tpy) 1,643 2,694 calculated Effective Reduction from Current (tpy) 11,674 5,388 calculated

Visibility analyses Visibility Improvement (dv at Max Class I) 1.217 1.017 no modeling results for SO2 controls alone Cost-Effectiveness ($/98th % dv at Max Class I) 16,703,531 $ 16,703,531 $ calculated Pollutant Control Effectiveness (dv/ton) 0.00010 0.00018 calculated Visibility Improvement (dv at Summed Class I) 2.049 1.673 no modeling results for SO2 controls alone Cost-Effectiveness ($/98th % dv at Summed Class I) 9,439,943 $ 9,439,943 $ calculated Pollutant Control Effectiveness (dv/ton) 0.00018 0.00030 calculated

## Operating company Dominion Facility Kincaid State IL Contact

Proposed Controls new DSI+Trona new DSI+Trona Unit #1 #2 Boiler Type cyclone cyclone IL EPA Fuel sub-bituminous sub-bituminous IL EPA Rating (MW Gross) 660 660 Company report Presumptive BART limit (lb/mmBtu) 0.15 0.15 boiler > 200 MW burning sub-bituminous coal Rating (mmBtu/hr) 6,634 6,406 Company report Current Emissions (tpy) 8,891 8,774 IL EPA Current Emisison Rate (lb/mmBtu) 0.55 0.54 IL EPA

Cost-benefit Analyses Control Efficiency 67.3% 66.9% calculated New Emisison Rate (lb/mmBtu) 0.18 0.18 IL EPA New Emissions (tpy) 1,129 1,128 IL EPA Emissions Reduction (tpy) 2,904 2,901 IL EPA Capital Cost 30,000,000 $ 30,000,000 $ Company report Capital Cost ($/kW ) 45 $ 45 $ Company report O&M Cost $8,910,000 $8,910,000 Company report Total Annual Cost $12,410,000 $12,410,000 Company report Cost-Effectiveness ($/ton) 4,274 $ 4,277 $ calculated

Proposed BART Limits Proposed BART limit (company) 0.18 0.18 Company report Proposed BART limit (state) 0.18 0.18 IL EPA Effective Reduction from Current 67.3% 66.9% calculated Effective BART Limit (tpy) 5,230 5,050 calculated Effective Reduction from Current (tpy) 1,404 1,356 calculated

Visibility analyses Visibility Improvement (dv at Max Class I) Cost-Effectiveness ($/98th % dv at Max Class I) Pollutant Control Effectiveness (dv/ton) Visibility Improvement (dv at Summed Class I) Cost-Effectiveness ($/98th % dv at Summed Class I) Pollutant Control Effectiveness (dv/ton)

### Operating Company Xcel Energy Facility Name Allen S. King Generating Plant State MN Contact Anne Jackson Permit action 005 authorized modification of the King Plant. The Rehabilitation Project is Distance to nearest Class I Area (km) # of Class I Areas evaluated/within 300 km 0 of 1 Data Source complete and includes the installation of new pollution control equipment, modification of the Proposed Controls FGD upgrade MPCA report plant heat rejection system, and rehabilitation and life extension of the main (EU 001, coal-fired) EGU Unit #1 boiler. The rehabilitation allows the plant to operate at a capacity approaching its original design Boiler type cyclone MPCA report rating. Fuel sub-bituminous MPCA report Rating each (MW gross) 550 MPCA report Presumptive BART limit (lb/mmBtu) 0.15 calculated Heat Input (mmBtu/hr) Current Emissions (tpy) 23,271 Current Emisison Rate (lb/mmBtu) 1.47 CAM data for 2002 - 2004

Cost-benefit Analyses company report The boiler rehabilitation consisted of: Control Efficiency 87% calculated 0.25 company report New Emisison Rate (lb/mmBtu) 0.12 company report • Installation of new cyclone burners and re-entrant throats. New Emissions (tpy) 3,027 MPCA report • Replacement of furnace sidewalls and furnace floor tubes. Emissions Reduction (tpy) 20,244 company report • Installation of induced draft fans to accommodate additional draft requirements of new Capital Cost control equipment. Capital Cost ($/kW) The new (additional) control equipment consists of: O&M Cost • Selective Catalytic Reduction (SCR) reactor for control of NOX emissions. Total Annual Cost 1,000,000 $ MPCA report • Spray dryer absorber lime-based semi-dry Flue Gas Desulfurization (FGD) system for Cost-Effectiveness ($/ton) 49 $ MPCA report control of SO2 emissions • Pulse-Jet cleaned Fabric Filter (PJFF) for additional control of PM. Proposed BART limit (lb/mmBtu) 0.12 Effective Reduction from Current 92% Effective BART Limit (tpy)

- Effective Reduction from Current (tpy)

Visibility analyses company report Visibility Improvement (dv at Max Class I) none done Cost-Effectiveness ($/98th % dv at Max Class I) Pollutant Control Effectiveness (dv/ton) Visibility Improvement (dv at Summed Class I) Cost-Effectiveness ($/98th % dv at Summed Class I) Pollutant Control Effectiveness (dv/ton)

### Operating company PacifiCorp Facility Laramie River State WY Contact

Proposed Controls Upgrade wet FGD Upgrade wet FGD existing Dry FGD Unit LRS #1 LRS #2 LRS #3 Boiler Type wall-fired wall-fired wall-fired Company report Fuel sub-bituminous sub-bituminous sub-bituminous Company report Rating (MW Gross) each 550 550 550 Company report Presumptive BART limit (lb/mmBtu) 0.15 0.15 0.15 BART Guidelines > 200 MW at facility > 750 MW Presumptive BART limit 95% 95% 95% BART Guidelines > 200 MW at facility > 750 MW Rating (mmBtu/hr) 6,420 6,420 6,600 Company report Current Uncontrolled Emissions (lb/mmBtu) 1.28 1.28 Company report Current Actual Emissions (tpy) 3,745 3,725 Current Actual Emissions (lb/mmBtu) 0.16 0.16 Company report Current Actual Control Efficiency 87.5% 87.5% Company report

Cost-benefit Analysis Upgraded Overall Control Efficiency 88.3% 88.3% Company report Upgraded Controlled Emissions (lb/mmBtu) 0.15 0.15 Company report Upgraded Controlled emissions (tpy) 3,511 3,492 Company report Reduction due to Upgrade 6.3% 6.3% Company report Emission Reductions (tpy) 234 233 Company report Capital Cost 2,363,000 $ 2,363,000 $ Company report Capital Cost ($/kW ) 4 $ 4 $ calculated O&M Cost 160,000 $ 160,000 $ Company report Annualized Cost $366,000 $366,000 Company report Cost-Effectiveness ($/ton) 1,564 $ 1,571 $ Company report

Proposed BART Limits Proposed BART Limit (company) 0.15 0.15 Proposed State BART Limit--either lb/mmBtu (30-day rolling average) Proposed State BART Limit--either reduction (30-day rolling average) Effective Reduction from Current 6% 6% calculated Effective BART Limit (tpy) 4,218 4,218 calculated Effective Reduction from Current (473) (493) tpy

Visibility Analyses see combined control/pollutant reduction analyses Visibility Improvement (dv at Max Class I) no modeling results for SO2 controls alone Cost-Effectiveness ($/98th % dv at Max Class I) calculated Pollutant Control Effectiveness (dv/ton) calculated Visibility Improvement (dv at Summed Class I) no modeling results for SO2 controls alone Cost-Effectiveness ($/98th % dv at Summed Class I) calculated Pollutant Control Effectiveness (dv/ton) calculatedOperating company Basin Electric Power Facility Leland Olds State ND Contact Tom Bachman tbachman@nd.gov (701) 328-5188 Distance to nearest Class I Area (km) # of Class I Areas evaluated/within 300 km

Proposed Controls FGD addition FGD addition Unit #1 #2 Boiler Type wall-fired ND DOH report cyclone ND DOH report Fuel ND lignite & PRB ND DOH report ND lignite & PRB ND DOH report Rating (MW Gross) each 216 ND DOH report 440 ND DOH report Presumptive BART limit (lb/mmBtu) 0.15 BART Guidelines > 200 MW 0.15 BART Guidelines > 200 MW Presumptive BART limit 95% BART Guidelines > 200 MW 95% BART Guidelines > 200 MW Rating (mmBtu/hr) 2,622 ND DOH report 5,130 ND DOH report Current Emissions (tpy) 16,666 ND DOH report 30,828 ND DOH report Current Emissions (lb/mmBtu) 1.82 ND DOH report 1.83 ND DOH report Current Uncontrolled Emissions (tpy) 16,666 ND DOH report 30,828 ND DOH report Current Control Efficiency 0% ND DOH report 0% ND DOH report

ND DOH Cost-benefit Analysis Future Uncontrolled Emissions (tpy) 34,683 ND DOH report 67,858 ND DOH report Future Uncontrolled Emissions (lb/mmBtu) 3.02 ND DOH report 3.02 ND DOH report Controlled Emissions (lb/mmBtu) 0.15 ND DOH report 0.15 ND DOH report Overall Control Efficiency (FGD) 95% ND DOH report 95% ND DOH report Controlled emissions (tpy) 1,734 ND DOH report 3,393 ND DOH report Emission Reductions (tpy) 32,949 ND DOH report 64,465 calculated Capital Cost 107,220,000 $ company report 147,600,000 $ company report Capital Cost ($/kW) 496 $ calculated 335 $ calculated O&M Cost 8,350,000 $ company report 14,210,000 $ company report Annualized Cost 19,310,000 $ ND DOH report 29,840,000 $ company report Cost-Effectiveness ($/ton) 586 $ ND DOH report 463 $ calculated

ND DOH Proposed BART Limits #1 Future Uncontrolled Emissions (lb/mmBtu) 3.90 ND DOH report 4.04 ND DOH report BART is an emission Proposed BART Limit (company) 0.39 lb/mmBtu 0.19 lb/mmBtu reduction efficiency of 95% of the inlet sulfur Proposed State BART Limit--either 0.15 lb/mmBtu (30-day rolling average) 0.15 lb/mmBtu (30-day rolling average) dioxide concentration to the scrubber or 0.15 lb/106 Proposed State BART Limit--or 95% reduction (30-day rolling average) 95% reduction (30-day rolling average) Btu on a 30-day rolling average basis. Effective Limit (tpy) 1,723 tpy 3,393 tpy #2 Effective Reduction from Current (lb/mmBtu) basis) 92% reduction 92% reduction The Department proposes that BART is 95% Effective Reduction from Current (tpy) 14,943 tpy 27,435 tpy reduction efficiency from the inlet of the scrubber Effective Reduction from Current (tpy) 90% reduction 89% reduction #2 Effective Reduction from Future (lb/mmBtu) basis) 96% reduction 96% reduction The Department proposes that BART is 95% Effective Reduction from Future (tpy) 32,960 tpy 64,465 tpy reduction efficiency from the inlet of the scrubber Effective Reduction from Future (tpy) 95% reduction 95% reduction to the outlet of the scrubber, or 0.15 lb/106 Btu, on a 30-day rolling average basis. Visibility analyses Visibility Improvement (dv at Max Class I) 1.216 calculated 2.378 calculated from company & ND DOH reports 5.596 NPS resuts uisng P-G stability Cost-Effectiveness ($/98th % dv at Max Class I) 15,885,246 $ calculated 12,546,601 $ calculated 5,332,063 $ calculated Pollutant Control Effectiveness (dv/ton) 0.00004 calculated 0.00004 calculated from company & ND DOH reports 0.00009 calculated Visibility Improvement (dv at Summed Class I) 2.425 calculated 4.745 calculated from company & ND DOH reports 9.417 NPS resuts uisng P-G stability Cost-Effectiveness ($/98th % dv at Summed Class I) 7,962,711 $ calculated 6,289,167 $ calculated 3,168,625 $ calculated Pollutant Control Effectiveness (dv/ton) 0.00007 calculated 0.00007 calculated from company & ND DOH reports 0.00015 calculatedOperating company Minnkota Power Facility MR Young State ND Contact Tom Bachman tbachman@nd.gov (701) 328-5188 Distance to nearest Class I Area (km) # of Class I Areas evaluated/within 300 km

Proposed Controls FGD addition 95% FGD upgrade or 90% FGD upgrade Unit #1 #2 #2 Boiler Type cyclone cyclone cyclone Fuel ND lignite ND lignite ND lignite Rating (MW Gross) each* 257 ND DOH report 477 ND DOH report 477 ND DOH report *actual capacity may be greater Presumptive BART limit (lb/mmBtu) either 0.15 BART Guidelines > 200 MW 0.15 BART Guidelines > 200 MW 0.15 BART Guidelines > 200 MW at facility > 750 MW Presumptive BART limit or 95% BART Guidelines > 200 MW or 95% BART Guidelines > 200 MW or 95% BART Guidelines > 200 MW at facility > 750 MW Rating (mmBtu/hr) 3,200 ND DOH report 6,300 ND DOH report 6,300 ND DOH report Current Emissions (tpy) 20,148 ND DOH report 12,404 ND DOH report 12,404 ND DOH report Unit 2 is equipped with a lime/flyash scrubber that achieved Current Emissions (lb/mmBtu) 1.88 ND DOH report 0.67 ND DOH report 0.67 ND DOH report an average SO2 reduction efficiency (inlet to outlet) of Current Uncontrolled Emissions (tpy) 20,148 ND DOH report 34,805 calculated 34,805 ND DOH report approximately 65% for the period 2000-2004. It is obvious Current Control Efficiency 0% ND DOH report 64% calculated 64% calculated that upgrading the existing scrubber to either 90% and 95% control efficiency will be the most cost effective ND DOH Cost-benefit Analysis alternative. Future Baseline Emissions (tpy) 21,519 ND DOH report 16,728 ND DOH report 30,965 calculated Future Baseline Emissions (lb/mmBtu) 3.48 ND DOH report Control Efficiency 95% ND DOH report 95% ND DOH report 96% calculated Controlled Emissions (tpy) 1,076 ND DOH report 1,830 ND DOH report 1,335 calculated Controlled Emissions (lb/mmBtu) 0.10 ND DOH report 0.10 ND DOH report 0.15 ND DOH report Emissions Reduction (tpy) 20,443 ND DOH report 14,898 ND DOH report 29,630 calculated Capital Cost 111,776,000 $ company report 24,989,000 $ company report 19,225,000 $ company report Capital Cost ($/kW) 435 $ calculated 52 $ calculated 40 $ calculated O&M Cost 10,282,000 $ company report 4,993,000 $ company report 4,530,000 $ company report Annualized Cost 22,584,000 $ ND DOH report $8,414,000 ND DOH report $7,333,000 ND DOH report Cost-Effectiveness ($/ton) 1,105 $ ND DOH report 565 $ ND DOH report 247 $ calculated

ND DOH Proposed BART Limits Future Uncontrolled Emissions (lb/mmBtu) 3.48 ND DOH report 3.48 ND DOH report 3.48 ND DOH report Proposed BART limit (company) 0.15 lb/mmBtu 0.30 lb/mmBtu 0.30 company report Proposed State BART Limit--and 0.15 lb/mmBtu (30-day rolling average) Proposed State BART Limit--and 95% reduction (30-day rolling average) 95% reduction (30-day rolling average) 96% reduction (30-day rolling average) Effective Reduction from Current 95% 78% reduction Effective BART Limit (tpy) 1,076 calculated 836 calculated 4,139 calculated Effective Reduction from Current (tpy) 19,072 calculated 11,568 calculated 8,265 calculated

Visibility analyses Visibility Improvement (dv at Max Class I) 1.831 calculated from company & ND DOH reports 1.186 calculated from company & ND DOH reports 0.685 calculated from company & ND DOH reports Cost-Effectiveness ($/98th % dv at Max Class I) 12,331,999 $ calculated 7,096,430 $ calculated 10,705,109 $ calculated Pollutant Control Effectiveness (dv/ton) 0.00009 calculated 0.00008 calculated 0.00002 calculated Visibility Improvement (dv at Summed Class I) 3.187 calculated from company & ND DOH reports 2.201 calculated from company & ND DOH reports 1.479 calculated from company & ND DOH reports Cost-Effectiveness ($/98th % dv at Summed Class I) 7,085,547 $ calculated 3,823,387 $ calculated 4,958,080 $ calculated Pollutant Control Effectiveness (dv/ton) 0.00016 calculated 0.00015 calculated 0.00005 calculated

Minnkota Power Cooperative, Inc. operates the Milton R. Young Station near Center, North Dakota. Minnkota has proposed that BART is The Consent Decree that covers M.R. Young Station A scrubber operating at 95% removal efficiency will MRYS is a steam electric generating plant with two units. Unit No. 1 is a Babcock & Wilcox (B&W) a wet scrubber operating at 95% control efficiency Unit 2 only requires 90% reduction of SO2 emissions achieve an emission rate of 0.11 lb/106 Btu based on cyclone-type coal-fired boiler burning lignite coal, serving a turbine generator with a nameplate rating with an emission limit of 0.15 lb/106 Btu. The by the scrubber. Minnkota has proposed that BART average coal or 0.17 lb/106 Btu based on a design of 257 MW. 2 Particulate control is provided by a Research-Cottrell Electrostatic Precipitator rated at Department concurs with the use of a wet scrubber is represented by improvements to the existing sulfur content of 1.46%. The existing scrubber is approximately 99% control. Unit 1 has no sulfur dioxide (SO2) control system and exhausts to a 300 achieving a 95% reduction efficiency. Minnkota is scrubber such that a 90% reduction efficiency will a mid 1970s design and maintaining 95% reduction foot tall stack. Unit No. 2 is a B&W cyclone-fired unit burning lignite coal, with a turbine-generator a party to a Consent Decree which resolved alleged be achieved on a 30-day rolling average basis. continuously will be more difficult than with new name plate rating of 477 MW. 2 Particulate control for Unit 2 is provided by a Wheelabrator-Lurgi New Source Review violations at the M.R. Young Minnkota states that the costs associated with each designs that are 30 years more advanced. Because precipitator rated at approximately 99% control. Unit 2 has a Combustion Equipment Associates wet Station. The Consent Decree states that if alternative (90% or 95% reduction) are reasonable of the age of the scrubber and some uncertainty in flue gas desulfurization (FGD) system (modified by Combustion Engineering) that treats Minnkota installs a wet scrubber, they must comply based on other regulatory analysis. Minnkota has the future coal sulfur content, the Department approximately 78 percent of the flue gas with the remaining flue gas by-passed for stack gas reheat. with a 95% reduction requirement with no not identified any energy or non-air quality proposes that an alternative limit be incorporated The FGD system achieves approximately 75 percent SO2 removal and exhausts to a 550 foot tall alternative emission rate (lb/106 Btu) limit. impacts that would preclude either alternative. into the BART limit. Minnkota has agreed to limit stack. Unit 1 began commercial operation on November 20, 1970 and Unit 2 on May 11, 1977. Therefore, the Department proposes that BART is a Minnkota’s choice of 90% reduction as BART is based SO2 emissions to no more than 0.15 lb/106 Btu. The On 17 June 2002, Minnkota Power Cooperative, Inc. received a Notice of Violation (NOV) from reduction efficiency of 95% of the inlet sulfur on the visibility modeling results. The Department proposes that BART is 95% reduction or EPA. The NOV states that Minnkota allegedly violated the Prevention of Significant Deterioration dioxide concentration to the scrubber on a 30-day difference, according to Minnkota’s results, 0.15 lb/106 Btu on a 30-day rolling average basis. (PSD) regulations. The NOV was issued pursuant to Section 113 of the Clean Air Act. The alleged rolling average basis (30 d.r.a.) indicate an average visibility impact reduction of However, the violation was caused by modifications to both Unit 1 and 2 at MRYS which allegedly resulted in a only 0.082 deciviews based on the 90th percentile Consent Decree requires a minimum of 90% reduction. potential increase of SO2, NOX and PM. Without an admission of liability, Minnkota entered into a value (0.250 dv based on 98th percentile). However, This requirement will also be incorporated into the settlement in the form of a Consent Decree (CD) with the EPA and NDDH to resolve the issues. The the difference in visibility impact between the two BART limit. CD requires that Minnkota install a level of control for SO2, NOX and PM on both Unit 1 and 2 at alternatives will be as much as 0.228 deciviews MRYS, equivalent to BACT. The effect of the CD on the BART analysis and the requirement to based on the 90th percentile (0.479 deciviews based install BACT-level controls are discussed later in the report. on 98th percentile) for year 2001 in TRNP-NU. After considering the cost of compliance, the energy and non-air quality environmental impacts, the remaining useful life (> 20 years) and the degree of visibility improvement, the Department proposes that BART is represented by improvements to the existing wet scrubber which will achieve approximately 95% reduction in SO2 emissions. BART is 95% reduction efficiency from the inlet of the scrubber to the outlet of the scrubber.

## Operating company Boston Generating Facility My stic Station State MA Contact Glenn Keith

Proposed Controls 0.5% S residual oil MassDEP Unit #7 Boiler Ty pe tangential MassDEP Fuel 1% S #6 oil MassDEP Rating (MW Gross) each 600 Presumptive BA RT limit (lb/mmBtu) Rating (mmBtu/hr) 6,000 company report 2002 Uncontrolled Emissions (tpy ) 3,727 MassDEP 2002 Uncontrolled Emissions (lb/mmBtu) 0.49 2002 CAM data 2007 Actual Emissions (tpy ) 1,922 MassDEP 2007 Actual Emissions (lb/mmBtu) 0.31 2007 CAM data Current Actual Control Efficiency 36% calculated

Cost-benefit A nalysis Capital Cost Capital Cost ($/kW ) O&M Cost Annualized Cost Cost-Effectiveness ($/ton) 4,270 $ MassDEP

Proposed BA RT Limits Proposed BART Limit (company ) 1.0% S residual oil company report Proposed State BA RT Limit 0.5% S residual oil 0.53 lb/m mB tu Effective Reduction from Current -69% calculated

Visibility A nalyses no visibility analy ses preformed Visibility Improvement (dv at Max Class I) Cost-Effectiveness ($/98th % dv at Max Class I) Pollutant Control Effectiveness (dv/ton) Visibility Improvement (dv at Summed Class I) Cost-Effectiveness ($/98th % dv at Summed Class I) Pollutant Control Effectiveness (dv/ton)

### Operating company PacifiCorp Facility Naughton State WY Contact

Proposed Controls new wet FGD new wet FGD upgraded wet FGD Unit #1 #2 #3 Combined Boiler Type tangential tangential tangential Company report Fuel sub-bituminous sub-bituminous sub-bituminous Company report Rating (MW Gross) each 160 210 330 Company report 700 Presumptive BART limit (lb/mmBtu) 0.15 0.15 0.15 BART Guidelines > 200 MW at facility > 750 MW Presumptive BART limit 95% 95% 95% BART Guidelines > 200 MW at facility > 750 MW Rating (mmBtu/hr) 1,850 2,400 3,700 WY DEQ report 7950 Current Emissions (tpy) 8,624 11,187 7,293 WY DEQ report 27104 Current Emissions (lb/mmBtu) 1.20 1.20 0.50 WY DEQ report Current Actual Control Efficiency 0% 0% 82.8% Company report

Cost-benefit Analysis Control Efficiency 87.5% 87.5% 92.4% Company report Controlled Emissions (lb/mmBtu) 0.15 0.15 0.21 WY DEQ report Controlled emissions (tpy) 1,094 1,419 3,063 Company report 5,576 Emission Reductions (tpy) 7,657 9,934 4,230 Company report 21,821 Capital Cost 89,400,000 $ 117,400,000

$ 6,000,000

$ WY DEQ report 212,800,000 $ Capital Cost ($/kW ) 559 $ 559

$ 18

$ calculated 304 $ O&M Cost 4,563,874 $ 5,721,158

$ 615,513

$ WY DEQ report 10,900,545 $ Annualized Cost 13,068,302 $ 16,889,165

$ 1,186,293

$ WY DEQ report 31,143,760 $ Cost-Effectiveness ($/ton) 1,707 $ 1,700

$ 280

$ WY DEQ report 1,427 $

Proposed BART Limits Proposed BART Limit (company) 0.15 0.15 Proposed State BART Limit--either lb/mmBtu (30-day rolling average) Proposed State BART Limit--either reduction (30-day rolling average) Effective Reduction from Current 88% 88% 58% calculated Effective BART Limit (tpy) 1,215 1,577 3,403 calculated Effective Reduction from Current 7,409 9,610 3,890 tpy

Visibility Analyses Visibility Improvement (dv at Max Class I) no modeling results for SO2 controls alone Cost-Effectiveness ($/98th % dv at Max Class I) calculated Pollutant Control Effectiveness (dv/ton) calculated Visibility Improvement (dv at Summed Class I) no modeling results for SO2 controls alone Cost-Effectiveness ($/98th % dv at Summed Class I) calculated Pollutant Control Effectiveness (dv/ton) calculatedOperating Company Northshore Mining Facility Name Silver Bay Power Plant Contact Anne Jackson Distance to nearest Class I Area (km) # of Class I Areas evaluated/within 300 km

Data Source Proposed Controls DSI+FF MPCA report The Silver Bay Power EGU Unit #2 plant has two boilers identified as Unit 1 and Unit 2. Unit 1 has a wall-fired configuration with Boiler type wall-fired MPCA report a maximum heat input rating of 517 MMBtu/hr heat input and about 35 megawatts output. Unit Fuel sub-bituminous MPCA report 2 has a dry bottom, front-wall fired configuration with a maximum heat input rating of 765 Rating each (MW gross) 75 MPCA report MMBtu/hr and an output of 75 megawatts. Both units are permitted to fire natural gas and coal, Presumptive BART limit (lb/mmBtu) 0.15 BART Guidelines and both use a fabric filter to control particulate matter (PM). NOX emissions are controlled Heat Input (mmBtu/hr) 765 MPCA report through good combustion practices. There are no post-combustion SO2 controls. Current Emissions (tpy) 1,551 calculated Boiler No. 2 at the facility is subject to BART as start-up for this unit was in 1963. Boiler No. 1 Current Emisison Rate (lb/mmBtu) 0.45 calculated is not subject to BART because start-up of that unit was in 1959, prior to the BART-eligibility date of 1962. Cost-benefit Analysis Control Efficiency 55% company report New Emisison Rate (lb/mmBtu) 0.27 MPCA report 0.25 company report New Emissions (tpy) 654 company report Emissions Reduction (tpy) 897 MPCA report Capital Cost 46,360,000 $ company report Capital Cost ($/kW) 618 $ calculated O&M Cost

- $ Total Annual Cost 6,556,000 $ MPCA report Cost-Effectiveness ($/ton) 7,309 $ MPCA report

Proposed BART limit (lb/mmBtu) 0.48 MPCA report If the MPCA were to rely on pollutant by pollutant reduction options, BART appears to be the Effective Reduction from Current -6% calculated use of Low NOX burners and overfire air on Unit 2 to achieve an emissions rate of 0.31 Effective BART Limit (tpy) 905 calculated lb/MMBtu, and spray drying/fabric filters to achieve an SO2 emissions rate of 0.06 lb/MMBtu. Effective Reduction from Current (tpy) 646 calculated The cost-effectiveness of this combined pollutant reduction is $2,634. This cost is nearly indistinguishable from the biomass co-firing alternative preferred by Visibility analyses NSM and modified by the MPCA Visibility Improvement (dv at Max Class I) 0.25 company report Cost-Effectiveness ($/98th % dv at Max Class I) 26,224,000 $ calculated Pollutant Control Effectiveness (dv/ton) 0.00028 calculated Visibility Improvement (dv at Summed Class I) Cost-Effectiveness ($/98th % dv at Summed Class I) Pollutant Control Effectiveness (dv/ton)

### Operating Company Rochester Public Utilities Facility Name Silver Lake Plant State MN Contact Anne Jackson Distance to nearest Class I Area (km) # of Class I Areas evaluated/within 300 km

Proposed Controls dry FGD EGU Unit #4 MPCA report Boiler type wall-fired MPCA report Fuel bituminous MPCA report Rating each (MW gross) 60 MPCA report Presumptive BART limit (lb/mmBtu) Heat Input (mmBtu/hr) 600 NPS assumption Current Emissions (tpy) 7,725 MPCA report 1666 CAM data for 2002 - 2004 Current Emisison Rate (lb/mmBtu) 1.61 CAM data for 2002 - 2004

Cost-benefit Analyses Control Efficiency 63% calculated New Emisison Rate (lb/mmBtu) 0.60 MPCA report New Emissions (tpy) 6,221 MPCA report 621 calculated Emissions Reduction (tpy) 1,504 calculated 1044 calculated Capital Cost Capital Cost ($/kW ) O&M Cost Total Annual Cost Cost-Effectiveness ($/ton)

Proposed BART limit (lb/mmBtu) 0.60 SO2 controls consist of installing a spray-dryer absorber designed to achieve a 70 - 85% removal Effective Reduction from Current 63% rate. The MPCA has determined that installation of this system represents BART for SO2 on Effective BART Limit (tpy) 1,577 Unit 4. To control PM, the existing ESP will be replaced by a fabric filter that includes a bag Effective Reduction from Current (tpy) leak indicator. The MPCA has determined that installation of this system represents BART for PM10 on Unit 4. Visibility analyses none conducted Visibility Improvement (dv at Max Class I) Cost-Effectiveness ($/98th % dv at Max Class I) Pollutant Control Effectiveness (dv/ton) Visibility Improvement (dv at Summed Class I) Cost-Effectiveness ($/98th % dv at Summed Class I) Pollutant Control Effectiveness (dv/ton)

## Operating company Dominion Facility Salem Harbor State MA Contact Glenn Keith

Proposed Controls 0.5% S residual oil Unit #4 Boiler Type DB wall-fired Fuel #6 oil Rating (MW Gross) each Presumptiv e BA RT limit (lb/mmBtu) Rating (mmBtu/hr) 4,800 company report 2002 Actual Emissions (tpy) 2,886 MassDEP 2002 Actual Emissions (lb/mmBtu) 0.94 2002 CAM data 2007 Actual Emissions (tpy) 164 MassDEP 2007 Actual Emissions (lb/mmBtu) 0.49 2007 CAM data Current Actual Control Efficiency 48% calculated

Cost-benefit A nalysis Emission Reductions (tpy) 568 company report Emission Reductions (tpy) 550 calculated @ 5% utilization Capital Cost 0 company report Capital Cost ($/kW ) 0 company report O&M Cost 1,718,629 $ calculated @ 5% utilization Annualized Cost 1,728,198 $ company report Cost-Effectiveness ($/ton) 3,043 MassDEP

Proposed BA RT Limits Proposed BART Limit (company) 1% S residual oil Proposed State BA RT Limit 0.5% S residual oil 0.53 lb/mmBtu Effective Reduction from Current -8%

Visibility A nalyses Visibility Improvement (dv at Max Class I) 1.38 company report Cost-Effectiveness ($/98th % dv at Max Class I) 25,082,697 $ MassDEP (based upon AECOM calculation @ 100% utilization) Pollutant Control Effectiveness (dv/ton) 0.0024 calculated Visibility Improvement (dv at Summed Class I) Cost-Effectiveness ($/98th % dv at Summed Class I) Pollutant Control Effectiveness (dv/ton)Operating Company Xcel Energy Facility Name Sherburne County Generating Station State MN Contact Anne Jackson Distance to nearest Class I Area (km) # of Class I Areas evaluated/within 300 km 3 of 3

Data Source The air pollution control equipment for Units 1 and 2 consists primarily of spray towers (wet Proposed Controls FGD upgrade FGD upgrade MPCA report scrubbing) and high efficiency wet electrostatic precipitators to control particulate and sulfur EGU Combined Unit #1 Unit #2 dioxide (SO2) emissions. In 2007 Xcel installed low NOX burners, separated/close coupled overfire Boiler type tangential tangential MPCA report air systems, and a combustion optimization system for Unit 1. For Unit 2, Xcel installed a Fuel sub-bituminous sub-bituminous MPCA report computer based combustion optimization system for the overfire air system in 2006. Rating each (MW gross) 1373 690 683 MPCA report Presumptive BART limit (lb/mmBtu) 0.15 0.15 BART Guidelines EGU >200 MW at facility >750 MW Heat Input (mmBtu/hr) 14,222 7,111 7,111 company report Uncontrolled emissions 0.98 0.98 calculated from company coal data Current Emissions (tpy) 15,000 7,500 7,500 calculated SO2 is controlled by wet flue gas desulfurization (FGD) systems (scrubbers) for each unit, which currently achieve 75% removal. Xcel Energy proposes Current Emisison Rate (lb/mmBtu) 0.27 0.27 company report to retrofit the existing scrubbers with sparger tubes and lime injection. Current control efficiency 72% 72% calculated

Cost-benefit Analysis Proposed control Efficiency 88% 88% calculated New Emisison Rate (lb/mmBtu) 0.12 0.12 MPCA report New Emissions (tpy) 6,600 3,300 3,300 company report Emissions Reduction (tpy) 8,400 4,200 4,200 MPCA report Capital Cost 7,400,000 $ 3,700,000

$ 3,700,000

$ company report Capital Cost ($/kW) 5 $ 5

$ 5

$ calculated O&M Cost 1,267,000 $ 667,000

$ 600,000

$ company report Total Annual Cost 1,990,000 $ 1,000,000

$ 990,000

$ MPCA report Cost-Effectiveness ($/ton) 237 $ 238

$ 236

$ MPCA report

Proposed BART limit (lb/mmBtu) 0.12 0.12 MPCA report The MPCA has determined that the SO2 emissions limitation of 0.12 lb/MMBtu on a 30-day rolling Effective Reduction from Current 56% 56% calculated average is BART for Sherco Units 1 and 2. The emission limit is achieved with the installation of Effective BART Limit (tpy) 3,738 3,738 calculated sparger tubes in the existing scrubbers and the injection of lime to lower pH of the scrubbing Effective Reduction from Current (tpy) 3,762 3,762 calculated system. The technology achieves the “presumptive BART” emissions rate, and does not prohibit or prevent the future installation of any known additional SO2 control technology. Visibility analyses Visibility Impact before BART (dv at Max Class I) 2.68 Visibility Impact after BART (dv at Max Class I) Visibility Improvement (dv at Max Class I) 0.550 0.275 0.275 company report Cost-Effectiveness ($/98th % dv at Max Class I) 3,600,000 $ 3,636,364

$ 3,600,000

$ company report Pollutant Control Effectiveness (dv/ton) 0.00007 0.00007 0.00007 calculated Visibility Impact before BART (dv at Summed Class I) 6.81 Visibility Impact after BART (dv at Summed Class I) Visibility Improvement (dv at Summed Class I) 1.590 0.795 0.795 company report Cost-Effectiveness ($/98th % dv at Summed Class I) 1,245,283 $ 1,257,862

$ 1,245,283

$ calculated Pollutant Control Effectiveness (dv/ton) 0.00019 0.00019 0.00019 calculatedOperating company Great River Energy Facility Stanton State ND Contact Tom Bachman tbachman@nd.gov (701) 328-5188 Distance to nearest Class I Area (km) # of Class I Areas evaluated/w ithin 300 km

Proposed Controls Proposed new LSD/FF Proposed new LSD/FF Stanton Station is currently permitted to fire both Lignite and PRB Unit #1 #1 coal. Boiler Type wall-fired ND DOH report wall-fired ND DOH report The use of two coals with different sulfur contents offers a degree of Fuel ND lignite ND DOH report PRB sub-bituminous ND DOH report complexity in terms of SO2 emissions for Unit 1. To respond to NDDH’s request, PRB Rating (MW Gross) 188 ND DOH report 188 ND DOH report has been included as an operational control in conjunction with post combustion control Presumptive BART limit (lb/mmBtu) either 0.15 BART Guidelines > 200 MW either 0.15 BART Guidelines > 200 MW associated limits can be determined based upon each fuel, cost effectiveness and most Presumptive BART limit or 95% BART Guidelines > 200 MW or 95% BART Guidelines > 200 MW importantly, expected deciview improvements. Rating (mmBtu/hr) 1800 ND DOH report 1800 ND DOH report technologies. GRE does not intend to blend fuels. Therefore, BART controls and Current Emissions (tpy) 8,242 ND DOH report not relevant ND DOH report Actual SO2 emissions from Unit 1 at the Stanton Station were Current Emisison Rate (lb/mmBtu) 1.70 ND DOH report not relevant ND DOH report approximately 0.44 lb/million Btu heat input for calendar year Current Control Efficiency 0% ND DOH report 0% ND DOH report 2006. However, Great River Energy has indicated that the mine from which the current PRB coal is received has a contractual ND DOH Cost-benefit Analysis arrangement with Great River to supply coal with a sulfur Baseline Emisison Rate (lb/mmBtu) 1.81 ND DOH report 1.2 ND DOH report content which equates to an SO2 emission limit no greater than Baseline Emissions (tpy) 9,376 ND DOH report 6,216 ND DOH report 0.8 lb/million Btu heat input with a financial penalty if the Control Efficiency 90% ND DOH report 90% ND DOH report sulfur content is greater than this amount. The mine uses a Controlled emissions (tpy) 938 ND DOH report 622 ND DOH report sulfur reject value of 1.2 lb/million Btu heat input. Controlled Emissions (lb/mmBtu) 0.181 ND DOH report 0.120 ND DOH report Great River Energy has indicated that the contract for PRB Emission Reductions (tpy) 8,438 ND DOH report 5,594 ND DOH report coal from the existing mine expires in 2009 and has indicated Capital Cost 79,514,000 $ company report not available that other potential PRB coal mines have PRB coal average Capital Cost ($/kW) 423 $ calculated not available sulfur contents of 0.34% sulfur, 1.28% sulfur and 1.60% O&M Cost 4,071,674 $ company report not available sulfur, Annualized Cost $11,220,000 ND DOH report $11,220,000 ND DOH report For purposes of this analysis, an SO2 emission rate of 1.2 Cost-Effectiveness ($/ton) 1,330 $ ND DOH report 2,006 $ ND DOH report lb/million Btu will be used to calculate uncontrolled emissions when combusting PRB coal. ND DOH Proposed BART Limits Future Uncontrolled Emisison Rate (lb/mmBtu) 2.40 ND DOH report 1.6 ND DOH report Proposed BART limit (company) 0.24 company report 0.15 company report Proposed State BART Limit--either 0.24 lb/mmBtu (30-day rolling average) 0.16 lb/mmBtu (30-day rolling average) Proposed State BART Limit--either 90% reduction (30-day rolling average) 90% reduction (30-day rolling average) Effective Reduction from Current (lb/mmBtu) basis) 86% calculated 91% calculated Effective BART Limit (tpy) 1,892 calculated 1,261 calculated Effective Reduction from Current (tpy) 6,350 calculated 6,981 calculated Effective Reduction from Current (tpy) 77% calculated 85% calculated Effective Reduction from Future (lb/mmBtu) basis) 90% reduction 90% reduction Effective Reduction from Future (tpy) 7,484 tpy 4,955 tpy Effective Reduction from Future (tpy) 80% reduction 80% reduction

Visibility analyses Visibility Improvement (dv at Max Class I) 0.772 calculated from company & ND DOH reports 0.512 calculated Cost-Effectiveness ($/98th % dv at Max Class I) 14,533,679 $ calculated 21,922,100 $ calculated Pollutant Control Effectiveness (dv/ton) 0.00009 calculated 0.00009 calculated Visibility Improvement (dv at Summed Class I) 1.511 calculated from company & ND DOH reports 1.002 calculated Cost-Effectiveness ($/98th % dv at Summed Class I) 7,427,184 $ calculated 11,202,909 $ calculated Pollutant Control Effectiveness (dv/ton) 0.00018 calculated 0.00018 calculated

Based upon information submitted by Great River Energy, the Based upon information submitted by Great River Energy, the lignite coal to be combusted in the future could have a sulfur possibility exists that PRB coal received in the future could content which would result in uncontrolled SO2 emissions (on have a sulfur content which would result in uncontrolled SO2 a 30 day rolling average basis) of approximately 2.4 emissions of approximately 1.6 lb/million Btu heat input. lb/million Btu heat input. Therefore, BART for SO2 when Therefore, BART for SO2 when combusting PRB coal is an SO2 combusting lignite coal is an SO2 emission limit of 0.24 emission limit of 0.16 lb/million Btu heat input on a 30 day lb/million Btu heat input (on a 30 day rolling average) or a rolling average basis or a reduction efficiency of 90% (on a reduction efficiency of 90% (on a 30 day rolling average) on 30-day rolling average basis) on the inlet SO2 concentration the inlet SO2 concentration to the pollution control to the pollution control equipment. equipment.Operating Company MN Pow er Facility Name Taconite Harbor State MN Contact Anne Jackson Distance to nearest Class I Area (km) # of Class I Areas evaluated/w ithin 300 km

Data Source Data Source Data Source Minnesota Power has undertaken an emissions reduction project for the three generating units, EGU Unit #3 Unit #3 Unit #3 referred to as the Arrowhead Regional Emissions Abatement (AREA) Project. Minnesota Power Boiler type tangential MPCA report tangential MPCA report tangential MPCA report selected to begin the project with the retrofitting of Unit 2, which is not a BART eligible unit due Fuel bit/sub-bituminous MPCA report bit/sub-bituminous MPCA report bit/sub-bituminous MPCA report to its construction date (1957). The MPCA issued permit no. 03100001-006 on January 8, 2007 Rating each (MW gross) 75 MPCA report 75 MPCA report 75 MPCA report that allows Power boiler No. 2 to be retrofitted with additional air pollution controls as a Presumptive BART limit (lb/mmBtu) 0.23 BART Guidelines 0.15 BART Guidelines 0.15 BART Guidelines demonstration project. Heat Input (mmBtu/hr) 745 MPCA AREA report 745 MNPWR report 745 MNPWR report Current Emissions (tpy) 1,854 2,190 MNPWR report 2,190 MNPWR report The emissions reduction project involves the installation of Nalco-Mobotec’s ROFA/Rotomix Current Emisison Rate (lb/mmBtu) 0.454545455 0.70 MNPWR report 0.70 MNPWR report control system to reduction NOx and SO2. Additionally, Mobotec’s “Minplus” injection system was installed to control mercury emissions. The project also involved modifying the electrostatic Proposed Controls FSI MPCA AREA report FSI and new FF MNPWR report FSI and new FF MPCA report precipitators from “hot-side” to “cold-side”. Control Efficiency 55% company report 55% MNPWR report 54% calculated New Emisison Rate (lb/mmBtu) 0.24 MPCA AREA report 0.25 company report 0.32 MPCA report Operation of the Rotamix system throughout 2008 demonstrated that the ROFA/Rotamix system New Emissions (tpy) 654 company report 986 calculated 1,310 calculated controlled emissions below the “presumptive BART” level for very large power boilers of 0.15 Emissions Reduction (tpy) 1200 MPCA AREA report 1,205 calculated 880 MPCA report lb/MMBtu. Operation of the system however did not achieved SO2 removals as planned. Capital Cost 46,360,000 $ company report 15,508,000 $ MNPWR report 15,508,000 $ MNPWR report Therefore the MPCA requested Minnesota Power prepare a BART analysis for Unit 3. The Capital Cost ($/kW) 618 $ 207 $ calculated 207 $ calculated analysis for NOx, SO2 and PM was submitted November 2008, recommending the installation of O&M Cost 1,868,000 $ MNPWR report

- $ a fabric filter to achieve up to 50% removal of SO2 with the use of Rotamix. Total Annual Cost 1,139,000 $ MPCA AREA report 4,679,000 $ MNPWR report 1,868,000 $ MPCA report Cost-Effectiveness ($/ton) 949 $ calculated 3,900 $ MNPWR report 5,300 $ MPCA report

Proposed BART limit (lb/mmBtu) 0.25 MNPWR report 0.32 MPCA report The MPCA concurs with Minnesota Power’s assessment of controls and their costs. NalcoEffective Reduction from Current 64% calculated 54% calculated Mobotec is BART for NOx; furnace sorbent injection with a PM10 control limit of 0.012 Effective BART Limit (tpy) +R[-11]C*R[-17]C*8760/2000 816 calculated 1,044 calculated lb/MMBtu, achievable with the installation of a new fabric filter, is BART for SO2 and PM10. Effective Reduction from Current (tpy) #VALUE! 1,374 calculated 1,146 calculated

Visibility analyses none conducted none conducted none conducted Visibility Improvement (dv at Max Class I) 0.25 company report Cost-Effectiveness ($/98th % dv at Max Class I) 4,556,000 Pollutant Control Effectiveness (dv/ton) Visibility Improvement (dv at Summed Class I) Cost-Effectiveness ($/98th % dv at Summed Class I) Pollutant Control Effectiveness (dv/ton)

With a baghouse however, we [MN PWR]estimate the system will readily achieve a capture efficiency of 55+%. Based on this, the cost-effectiveness of the hydrate injection/baghouse combination will be lower than the hydrate injection/ESP conversion option.

### Operating company Florida Pow er & Light Facility Wyman State ME Contact

Proposed Controls 1% S #6 oil Unit 3 Boiler Type Tangentially-fired Company report Fuel 2%S #6 oil Company report Rating (MW Gross) 100 Company report Presumptive BART limit (lb/mmBtu) 0.15 BART Guidelines > 200 MW Presumptive BART limit 95% BART Guidelines > 200 MW Rating (mmBtu/hr) 1,190 Company report Current Emissions (tpy) 354 Company report Current Emisison Rate (lb/mmBtu) 1.803 Company report

Cost-benefit A nalyses Proposed control efficiency 50% Company report New Emisison Rate (lb/mmBtu) 0.90 calculated New Emissions (tpy) Emissions Reduction (tpy) 311 calculated Capital Cost Capital Cost ($/kW ) O&M Cost Total Annual Cost 680,000 $ Company report Cost-Effectiveness ($/ton) 2,189 $ Company report

Proposed BART Limits Proposed BART limit (company) 0.90 Company report Effective Reduction from Current 50.0% Company report Effective BART Limit (tpy) 4,699 calculated Effective Reduction from Current (tpy) (4,345) calculated

Visibility analyses Visibility Impact before BART (dv at Max Class I) 3.36 Company report Visibility Impact after BART (dv at Max Class I) 2.37 Company report Visibility Improvement (dv at Max Class I) 0.990 calculated Cost-Effectiveness ($/98th % dv at Max Class I) 686,869 $ Company report Pollutant Control Effectiveness (dv/ton) 0.00319 calculated Visibility Impact after BART (dv at Summed Class I) 9.73 calculated Visibility Improvement (dv at Summed Class I) 7.12 calculated Visibility Improvement (dv at Summed Class I) 2.610 calculated Cost-Effectiveness ($/98th % dv at Summed Class I) 260,536 $ calculated Pollutant Control Effectiveness (dv/ton) 0.00840 calculated

### Operating company PacifiCorp Facility Wyodak State WY Contact

Proposed Controls Upgraded Dry FGD & Fabric Filter Unit Boiler Type wall-fired Company report Wyodak is equipped with a wall-fired boiler manufactured by Babcock & Wilcox Fuel sub-bituminous Company report Rating (MW Gross) 335 Company report Presumptive BART limit (lb/mmBtu) 0.15 BART Guidelines > 200 MW Presumptive BART limit 95% BART Guidelines > 200 MW Rating (mmBtu/hr) 4,049 Company report Current Uncontrolled Emissions (lb/mmBtu) 1.61 Company report Current Emissions (tpy) 9,264 Company report Joy Niro, three-tower, lime-based spray dryer was added for Current Emisison Rate (lb/mmBtu) 0.50 Company report flue gas desulfurization (FGD) in 1986. Current Actual Control Efficiency 69% Company report

Cost-benefit Analyses Proposed control efficiency 90% Company report New Emisison Rate (lb/mmBtu) 0.16 Company report New Emissions (tpy) 2,992 Company report Emissions Reduction (tpy) 6,272 Company report Capital Cost 7,686,328 $ Company report Capital Cost ($/kW) 23 $ calculated O&M Cost $1,267,722 Company report Total Annual Cost $8,954,051 Company report Cost-Effectiveness ($/ton) 1,428 $ Company report

Proposed BART Limits Proposed BART limit (company) 0.16 Company report Effective Reduction from Current 68.0% Company report Effective BART Limit (tpy) 2,838 calculated Effective Reduction from Current (tpy) 6,426 calculated

Visibility analyses Visibility Improvement (dv at Max Class I) 0.200 no modeling results for PM controls alone Cost-Effectiveness ($/98th % dv at Max Class I) 44,730,957 $ calculated Pollutant Control Effectiveness (dv/ton) 0.00003 calculated Visibility Improvement (dv at Summed Class I) 0.406 no modeling results for PM controls alone Cost-Effectiveness ($/98th % dv at Summed Class I) 22,055,587 $ calculated Pollutant Control Effectiveness (dv/ton) 0.00006 calculated