p.1 

OAR Box 1778 

Prepped by Ollie Stewart 

Document Number: 

20) ll-A-4 

Docket Number: 

A-90-06 

Printed 10/28/2008 9:50:52 AM Sheet 20 of 276 
TET jcill — : i :u—i ^ • u o—is u . u<->•-» n—. ^ — 

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MEMORANDUM 

TO: Nancy Ketc, U.S. EPA 

FROM: Carolyn Lang, RCG/Hagler, Bailly, Inc. &b£> 

DATE: September 13, 1990 

SUBJECT: Life Extension Paper - Final Draft 

Attached is the final draft of the Life Extension Paper with final cost estimates. Although 

the paper is in an easy-to-rcad format, it assumes a high level of knowledge of utility lingo 

and operating practice. If you would like me to tone it down, let me know and I will rewrite some sections. ' 

I am forwarding this final draft to you by Fed..Ex with a diskette in Word Perfect 5.0 format 

so that you can make modifications to the paper as needed. 

As a follow-up to this project, we could do some detailed investigation into existing project 

costs such as a telephone survey of the example projects and a study of the actual costs and 

project tasks. I would really like to continue pursuing this topic and suggest that we jointly 

author a paper for either a conference or PUF....something about the coming "Age Wave" 

in utility environmental regulation. Let me know what you think. 

RCG/I Ingle r, [Uilly, Inc. 
P__ 

TEL: Jan 9,91 13=08 Mo.004 P.03 

LIFE EXTENSION OF FOSSIL POWER PLANTS 

Introduction 

This paper focuses on life extension issues related to fossil-fired power plants (coal, oil and 

gas) and whether these plants are considered new sources under the New Source 

Performance Standards and PSD. Typical projects are identified and corresponding costs 

for life extension, with and without Best Available Control Technology (BACT) are 

included. The issues are presented in a discussion format that is designed to identify and 

explain these issues in a quick easy-to-read document. A list of references is attached with 

sources that contain more detail on particular topics. The primary issues pre.sented include: 

Why is life extension an important'environmental issue today? 

What is life extension? 

What makes a good life extension candidate? 

What is a new source? 

Cost estimates of life extension projects (w/wo BACT) 

Case Studies of typical projects: description and costs 

Why is life extension an important environmental issue? 

Life extension of fossil-fired power plants is an important environmental issue because it is 

expected that as the current fleet of fossil power plants ages, utilities will life extend these 

plants rather than replace them. There are several advantages to life extension: 

a) Fossil power plant technology has remained relatively constant for the past 20 

years. A typical fossil-steam plant built in the early 1970's is very similar in 

technology to a plant built today. This means that there is little technological 

advantage to building a new plant. 

b) The cost of life extension is approximately one-quarter the cost of a new 

power plant, mainly because of looser environmental requirements and the 

cost of siting and improving a new plant location. 

The current fleet of fossil plants in the U.S. is aging and will be reaching their useful 

lifetime during the next 20 years. The average expected lifetime of a fossil plant ranges 

from 30-45 years for coal steam units and 3040 years for oil and gas steam units. Fossil 

units accounted for about two-thirds of the installed generating capacity in the U.S. in 1986. 

(DOE/EIA, 1988) In 1995, the average fossil unit will be 26 years old. More than onequarter of all coal-fired plants, and half of all oil- and gas-fired units will more than 30 years 

old in 1995. (Smock, 1987) 

KCU/llABlcr, Bnilly, Im. 2 September 1.1,1990 
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Jan 9,91 13:08 No.004 P.04 

Given that electricity demand is growing throughout the U.S. and that announcements of 

new power plants are well below the capacity required to meet this demand after 2000, life 

extension appears to be a likely option for utilities in the future. Regulatory treatment of 

life extension projects, especially air regulations which currently only affect new sources, are 

not fully in place. This relatively new phenomenon of life extension is outside the present 

regulatory domain and new precedents and guidelines still need to be determined. The 

electric utility industry argues that this uncertainty in regulatory treatment is deterring them 

from pursuing life extension projects and unless this issue is resolved, capacity shortages may 

be a reality early in the next decade. 

What is life extension? 

There are several different types of life extension projects. The common terms related to 

life extension are: 

Life Extension; 

(LE) 

Refurbishment: 

Repowcring: 

Phased Life Extension: 

Extended Maintenance: 

Front-End LE: 

De-mothballing: 

Investments make to maintain the operating status of a power 

plant at acceptable levels of efficiency and availability beyond 

its originally anticipated retirement date. In life extension, a 

plant is usually restored to its original performance without 

installing new combustion technologies. (DOE/EIA, 1988) 

Same as life extension. Usually assumed to extend the life of 

plant approximately 20 years, with availability and efficiency 

declining over time. (DOE/EIA, 1998) 

The boiler at a unit is replaced with a new combustion 

technology such as an atmospheric fluidi2ed-bed unit or 

combined cycle combustion turbine. This results in better 

performance, and usually, larger capacity. (DOE/EIA, 1988) 

Life extension is done over time, during normal maintenance 

outages. This approach is the one chosen most often because 

the utility can plan its LE effort to minimize outage time and 

keep the plant in service. Also, since the LE work is extended 

over several years, the utility does not need to have large cash 

reserves on hand. (DOE/EIA, 1988) 

This LE approach is used by utilities to rehabilitate plants just 

prior to the end of their design lives. This strategy may be 

appropriate in situations where other major changes to the 

plant are scheduled to be installed (fuel conversion, emissions 

control technologies) or to restore a "moth-balled" plant into 

active service. In front-end LE, a major portion of the lifeRCC/lla-aglfr, D.iilt}-, Inc. September 1,1, 1990 
P.5 

TEL Jan 9,91 13=08 No.004 P.O! 

extension work is performed during a single planned outage. 

(DOE/EIA, 1988) 

What are good life extension candidates? 

There are several dimensions that a utility must consider before deciding to invest in a life 

extension program at a particular unit. The issues range from demand growth in the service 

territory to the condition of individual plant components. These issues are presented below 

in a key work format: 

Demand Growth Forecasted demand growth and electric use patterns. Will future 

demand patterns match the dispatch capabilities of the life extended 

unit? 

System Status Age, condition and operating characteristics of all plants in the system. 

Is it cost-effective to extend the life of a base load plant when there 

will be a shortage of peak capacity? 

Reserve Margins Need for future capacity or supplemental resources. 

Unit 

Characteristics 

Unit Condition 

Financial 

Condition 

Site Constraints 

Boiler Design 

Size, age, and operating characteristics. About 90% of the units 

that have been identified as LE candidates are 200 MW or less 

because of their performance flexibility in being able to operate as 

peaking/cycling units. 

Has the proposed unit been constantly maintained, or was 

refurbishment intended for life extension? 

Is. there cash on hand for the investments required? Would a pha<.ed 

LE approach be appropriate? 

Many of the units suitable for LE are located in central business 

centers to provide adequate load support for these high demand areas. 

There may be geographic expansion constraint or even a social 

acceptance threshold that limit the extent of new equipment that can 

be added to the site. 

Some of the older top-fired boilers do not lend themselves well to 

retrofit measures (namely, low NOx burners). Current research has 

focused on modern tangcntially-fired or horizontally-fired boilers. 

RCC/l(.icl«r, Dallly, Inc. Sc|..t-n.0«r 13, 1990 
PJ5_ 

TEL: Jan 9,91 13=08 Mo.004 P.06 

Hazardous The cost to remove hazardous materials such as asbestos from units 

Materials that were built when this was normal insulating practice can 

significantly increase the cost of a project. 

Regulatory Will environmental controls be required for this project? 

Impact If LE will increase effluents from the plant, do emissions permits need 

to be upgraded? 

What is a New Source? 

The principal environmental regulations that affect life-extension decisions are Federal and 

State laws that control air and water quality and solid waste. The Federal air-quality 

regulations are the New Source Performance Standards (NSPS), and the Revised New 

Source Performance Standards (RNSPS), and the Prevention of Significant Deterioration 

(PSD) rules. These standards limit the emissions of sulfur dioxide ($02), nitrogen oxides 

(NOx), and particulate matter from power plants. 

NSPS and RNSPS have special importance in life-extension decisions because they impose 

emission standards on generating units based on when construction began. Pre-NSPS units 

(those whose construction began before August 18, 1977) are subject only to State 

Implementation Plans, which are generally less stringent than NSPS. NSPS and RNSPS 

units must not emit more than 1.2 pounds of S02 per million Btu of heat input. In 

addition to the 1.2 lb/mmBtu limit, RNSPS units must reduce their S02 emissions by 70-

90% (depending upon emissions rate) which usually requires the use of flue gas 

desulfurizatton (FGD) equipment. 

Many of the plants that will be considered for LE in the near future will be pre-NSPS 

plants. If utilities can preserve the pre-NSPS status of these plants, they will be able to 

avoid the capital and maintenance costs of FGD equipment. In these cases, RNSPS also 

applies to any existing units when refurbishment makes them "new", "modified" or 

. "reconstructed" facilities. 

The interpretation of "new source" for RNSPS application has recently shifted. Originally, 

it was assumed that any LE project whose capital costs exceeded 50 percent of a new boiler 

unit would be considered new sources. Until recently, however, EPA did not enforce this 

criteria. But, an effort to improve the new-source review process has shifted EPA's stance. 

In the fall of 1988, Wisconsin Electric Power Co. (WEPCO) proposed to renovate the five 

units at their 40-year-old Port Washington plant to restore degraded output to design 

capacity and to extend their operating life. The federal EPA ruled that this project would 

cause Port Washington to become affected by RNSPS and emissions control measures would 

have to be installed at the plant. The basis for this ruling was not on the 50% capital costs 

because the proposed $80 million capital investment was well below half of the cost of new 

RCC/UflBlcr,nnil.y,I„c. 5 Sep.en.ber 1.1. 1990 
_7_ 

TEL: Jan 9,91 13 = 08 No.004 P.07 

boilers. EPA based, this ruling on the plant's capacity to emit pollutants. If LE increases 

the plant's capability to emit compared to the baseline period -- usually the two years prior 

to the LE program - then the new source regulations would be triggered. 

After a court battle, EPA and WEPCO reached an agreement that only partial S02 removal 

was required at two of the five units. This agreement was based on a test that proved two 

of the five units were capable of operating at their full capacity even though these units 

were not actually dispatched during the baseline period for economic dispatch reasons. 

Therefore, the proposed LE program would not increase these units ability to emit 

pollutants. Of the remaining three units, one was eliminated from the LE program because 

extensive repairs would be required to restore it to operation, and the other two units will 

be required to reduce S02 emissions approximately 10 to 20 percent. PSD standards must 

also be met by upgrading the precipitators at the plants. PSD applies to the plant as a 

whole rather than individual units, so all four refurbished units arc affected. 

Under the basis of the current interpretation of new source, utilities are motivated to 

continue to operate units designated for LE, so that they can prove the units ability to emit 

has not increased. Other LE programs have been recently cited by EPA as new sources. 

These projects include Detroit Edison's project to add new burners to allow an oil-fired 

plant to burn gas. Increased operating hours due to the economic advantage of gas fuel will 

result in increased emissions of NOx. Another affected LE project could be a Clean Coal 

Technology program project involving a new type of FGD system that will also increase the 

capacity factor of a Northern Indiana Public Service Company plant. The increased 

utilization of this plant is expected to increase NOx emissions triggering a new source 

review. This project may be excepted from new source standards because it is primarily a 

pollution control project. 

Costs of Life Extension ' 

The wide variety of LE projects (phased, front-end, repowering) have different total costs. 

Phased projects have low annual capital investments, but these investments stretch over 

several years. Front-end and repowering projects have large initial capital investments. The 

difference in cash flow of these projects requires that they be compared on a levelizcd 

annual cost basis. This basis may __\ be the best indicator, however, of triggering new 

source reviews. The actual LE project tasks may show the extent of "modification" and the 

corresponding increase in S02 or NOx emissions better than cost alone. 

The BACT requirements for a refurbished plant can be met with a variety of control 

technologies. For sulfur dioxide compliance a wet or dry scrubber can be added, 

Limestone/Calcium Injection - Multi-stage Burning (LIMB) Technology can be used or a 

the plant can switch to low-sulfur coal and add one of these technologies. For NOx 

reduction the combustion technology can be modified with low NOx burners or Selective 

Catalytic Reduction (SCR) technology can be added. In addition to these modification, the 

RCG/I(n6ttr, Dull.;, loe. , 6 Sep.cml.cr 1.1, 1990 
TEL 

P.8 

Jan 9,91 13=08 No .004 P.08 

particulate control^ system may need to be upgraded which usually requires modifications or 

replacement of the Electrostatic Precipitator (ESP). The addition of S02 control or coalswitching will usually change the composition and resistivity of the flue gases so that 

particulate controls will be affected. 

Cost estimates for retrofit control technologies vary greatly with the project. Critical 

parameters include retrofit difficulty (is there space for a scrubber on site?), solid waste 

removal and storage capabilities, boiler type (some boilers do not lend themselves to low 

NOx burners), and existing control system size and condition. Increased operating and 

maintenance costs due to the additional pollution control equipment, waste removal, and 

plant availability could add 1 to 3 mils/kwh to the energy cost. Without pollution control 

equipment, the energy cost would probably be reduced because of improved heat rate and 

lower maintenance costs. Replacement catalyst for SCR systems is relatively expensive and 

is often capitalized in the initial cost estimates. Most retro-fit pollution control projects in 

the U.S. have been for units larger than 200 MW, so it is not clear what control technologies 

utilities will use on the smaller, older units that would be life-extended. The attached cost 

tables show both costs and project tasks for several different types of life extension projects 

and the corresponding BACT technologies. Tables 1-3 show typical project tasks and costs 

for the three major types of LE projects: Phased, Front-end and Repowering. Table 4 shows 

a cost comparison of these projects and several actual LE projects. 

The costs of LE without adding pollution controls are generally: 

Project Tvpe 

Phased LE 

Front-End LE 

Coal-fired 

Oil-fired 

Gas-fired 

Repowering 

NGCC 

AFBC 

IGCC 

JWO/kw 

150 - 250 

270 

130 

- 85 

500-1050 

900 

1600 

For retrofit pollution controls add: 

Control Tvpe 

Wet FGD 

Dry FGD 

Particulate Upgrade 

Low NOx Burners 

SCR 

RCC/Huglcr, Dflilly, Inc. 

$1990/kw 

$170-400 

$100-300 

$ 50-200 

$ 7-12 

$ 65-150 

September 1.1,1990 
p__ 

TEL: Jan 9,91 13 = 08 No.004 P.09 

W>_?Z£_ ^ x

b0ttt*ndl£ °l 20(LM W c ?a ,

-

flr

.

ed

 TM< that is required ,o add 

or about $380/kw. 

r. r?r<\-s *—«&»">i » «wiu-cuu i^o ui tvv IVIVY coai-nrea unit mat is requ 

^h^P««n/[f W N °

X bumer S ran *e s fro m $7 6 t 0 % milIio n dollars capital investment 

Conclusion 

f^m u^Ti tHe ! !

 preliniina,

y

 cost

 estimates, it appears that LE costs for good candidates 

is still well below the current costs for new power plants of $1650/kw for coal and $800/kw 

for natural gas combined-cycle. The higher costs for new plants are not for equipment and 

engineering, but rather, for site improvements, permitting, and transmission costs 

RCO/HagW, Bailly, Inc. o 

O Sep«iiili<T 1.1, 1990 
P.10 

TEL : Jan 9,91 13 = 08 No.004 P.10 

Table 1 

Phased Life Extension Example 

Description. Phased life extension is usually a multi-year investment to inspect and replace 

major equipment components at a 20-30 power plant. Tiie advantages to this 

LE approach is the low capital investment required each year and the 

continued availability of a unit during the LE program. 

Assumptions: 

The project is assumed to require four years for "completion. The LE enhancements are 

performed during three unit outages. These outages are scheduled for Month 1-3, Month 

21-24, and Month 42-45. The phased life extension program is projected to extend the 

generating unit life by twenty years. 

The investment in LE will be in the areas of critical equipment and non-critical or 

redundant systems equipment that could have a significant impact on the unit efficiency or 

availability. The phase LE program assumes that non-critical equipment have been the 

recipient of a quality routine maintenance program. In addition, the maintenance of noncritical systems will continue as a function of this program. 

The cost estimate for the phased LE program assumes a 6% escalation rate for labor and 

materials. Indirect costs are assumed to be 16% of direct costs. 

Tbe order of the phased program is: 

Uv..*ayv " 

OiatS^ 2 

Ov>t2£e3 

Os* Estimates 

E£f£2 

&^£-i 

T;^co>Generator 

Gx»3«s^s System 

Iks: Rqeoion Syst 

Month 1-3 

Month 21-24 

Month 42-45 

t 

em 

CtVK TtL-t?me Equipment 

S^Sssgar 

lr5cr-TKrj:ition/Coi ntrol - Turbine 

Turbine Upgrade 

Boiler Enhancements 

Non-critical and Redundant Systems 

rotal $1990/kw 

54.10 

2.49 

0.93 

0.70 

5.61 

0.07 

63.90 

5CiJWfcv3aai>.Uc. September 1.1, 199U 
P.11 

TEL : Jan 9,91 13 = 08 No.004 P.11 

Outage 2 

Fossil Steam Supply System 

Instrumentation and Controls 

Draft System 

Fccdwater Heating System 

Total 

Outage 3 

Stack Structure 

Protective Equipment 

Power and Control Wiring 

Air, Water and Steam Systems 

Wastewater Treatment Equipment 

• 

82.89 

6.13 

22.31 

0.79 

112.12 

0.22 

0.09 

0.37 

0.70 ~ 

0.21 

Make-up Water Structure & Equipment 0.13 

Total 

Direct Cost/kw 

Indirect Cost/kw 

TOTAL Cost/kw 

Pollution Control 

Dry FGD 

Low NOx Burners 

Particulate System Upgrade 

1.72 

177.74 

28.76 

206.50 

$100-200 

$ 10-15 

$50-200 

TOTAL with Pollution Control $366-621 

Example Projects: 

1) Potomac Electric Power Co. - Potomac River plant 

$88 million over 10 years for 5 units totaling 514 MW. 

RCC/lla-ekr, Dailty, Inc. ' 10 Sfpli-mbcr 1.1. 1990 
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Jan 9,91 13=08 No.004 P.1. 

Table 2 

Front End Life Extension Example 

Description: One-time rehabilitation of a unit or plant to increase availability or return the 

unit to "active" service after being "mothballed". Usually major work is 

completed during a single outage and capital investment. 

Assumptions and Notes 

Front-end LE or refurbishment candidates are assumed to be units that are in above 

average condition and will require a relatively low level of effort to increase unit availability 

and operating efficiency. Candidates for refurbishment are units that have been operated 

with a high quality Routine Maintenance Program (RMP). In addition, these units have not 

been subjected to abusive operating practices such as ovcrfiring, operation without feedwater 

heaters, significant water chemistry imbalance, infrequent boiler and condensation system 

cleanings. 

Non-critical equipment is defined as machinery that can be repaired under the RMP or 

equipment that can be repaired during reduced load periods (nights, holidays, and 

weekends). A significant segment of the non-critical equipment will consist of machinery 

with redundant systems in place as part of the original facility design such as feedwater 

pumps, condensate pumps, and compressed air systems. It is assumed that non-critical 

equipment will be overhauled or replaced over the remaining life of the unit as part of the 

RMP. 

Instrument and control systems will be upgraded to enhance boiler/turbine/gencrator 

response and subsequent ability of the unit to respond to load change requirements 

including cycling and peaking operation. The control system upgrade will use existing final 

drive components as applicable and integrate digital control technology into replacements. 

Variable speed drives and sliding pressure control are also integrated into the unit to reduce 

power consumption and the impact of cycling/peaking operation on the unit. 

Cost Estimates 

Project $1990/kw 

Coal-fired Unit 

Stack Structure 0.18 

Fossil Steam Supply 44.71 

Draft System 12.15 

Instrumentation and Controls 3.01 

Turbine Generator 33.10 

RCO/|lnei*r, B.iilly, Inc. 11 Svp.cml.cr 1.1, 1990 
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Condensing System 2.51 

Feed Heating System 3.54 

Turbine Plant Equipment (other) 4.69 

Process Controls 0.05 

Make Water Structures & Equip. 0.69 

Heat Rejection System 5,53 

Direct Cost/kw 110.16 

Indirect Cost/kw 17.82 

TOTAL Cost/kw 127.98 

Pollution Control 

Dry FGD $100-200 

Low NOx Burners $ 10-15 

Particulate System Upgrade $ 50-200 

TOTAL with Pollution Control $288-543 

Example Projects: 

1) Cincinnati Gas & Electric - Beckjord Unit 3 (1987) 

$13 million at 125 MW unit, $121/kw. 

2) Wisconsin Electric Power Company - Port Washington 

Estimated at $88 million for 4-80 MW units 

Estimated at $32 million for pollution control 

RCC/Haglfr, D..il!y, Inc. 

1 2 Stpirmltor I), 1990 
P.14 

TEL Jan 9,91 13:08 No.004 P.14 

Table 3 

Repowering Example 

Description: A life extension project in which the steam generating unit (boiler) is replaced 

or augmented by a new technology either natural gas combined cycle 

technology (NGCC), atmospheric fluidized bed combustion (AFBC), or other 

clean coal technology such as integrated gasified combined cycle (IGCC). 

Repowering usually increases the available capacity at the unit. 

Major Modifications 

Most major plant components are replaced or upgraded 

Turbine generator refurbishment 

These projects are generally considered new sources becau.se the boiler 

is replaced. 

Cost Estimates 

Project 

NGCC 

AFBC 

IGCC 

Pollution Control 

Steam Injection 

SCR w/o catalyst 

$1990/kw 

$550-1050 

$900 

$1600 

$5 

$65-150 

Example Projects: 

1) Long Island Lighting Co. - Port Jefferson 

NGCC • $625-105O/kw 

2) San Diego Gas and Electric - South Bay Unit 3 

NCGG - $500/kw 

RCO/IIa-clcr, Ballly, Inc. 13 S«|.KmlK.T 1.1, 1900 
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Jan 9,91 13:08 No.004 P.15 j 

ILL - .-~4 

References 

Baylor, Jill, "Acid Rain Lnpacts on Utility Plans for Life Extension", Public Utilities 

Fortnightly, March 1, 1990, pgs. 22-28. 

Catalano, Lee, "Evaluate non-technical barriers to life-extension programs", JPower, 

December, 1984, pgs. 67-70. 

Democker, James, Judith Greenwald, Paul Schwengels, "Extended Lifetimes for Coal-fired 

Power Plants: Effects Upon Air Quality", Public Utilities Fortnightly. March 

20, 1986, pgs. 30-37. 

DOE/EIA-0509, Estimating the Capital Costs of T.ifc Extension for Fossil-fired Sream 

Plants. July 1988. 

Smock, Robert, Tower plant owners 'phase in' life extension", Power Engineering. February, 

1987. pgs. 18-23. 

"Competition raises the value of life extension, aging plant upgrading", Power 

Engineering. February, 1988. pgs 24-29. 

"Power plant life extension trend takes new directions", Power Engineering. 

February, 1989. pgs. 21-27. 

"Is life extension dead?", Power Engineering. September, 1989, pgs. 78-79. 

"Life Extension runs into environmental barriers", Power Engineering. 

February, 1990., pgs. 19-24. 

"Repowering old plants gains favor", Power Engineering. May, 1990, pgs. 25-

27. 

RCG/IlnfiW, Bailly, Inc. 1 4 September M, 1990 

;.'•.:••* » &m 
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P.16 

Jan 9.91 13:08 No.004 P.16 

Table 4 

Typical Life Extension Cost Ranges 

Study/Prolect 

DOE/EIA Concept 5 

Model Unit w/o FGO 

Model Unit w/o FGO' 

Model unit w/FGD 

Model Unit w/FGD* 

CEC/Stone& Webster 

Model Unit w/o FGD 

Model unit w/FGD 

DOE Report to 1987 American 

Coal-fired Units 

Oil-fired Units 

Gas-fired Units 

Unit Size 

>200MW 

<20OMW 

>200MW 

<200MW 

n/a 

n/a 

Powor Conference 

(All Costs St 990/kw) 

LE Cost FGD Cost 

188 

282 

207 

445 

100-250 

250-550 

270 

131 

84 

0 

0 

0 

0 

NOx Cosi 

0 

0 

0 

0 

1990 EPRIS02 Control Symposium 

FGD System - retro-fit 

Low NOx Burners 

Tangential 8oilor Retrofit* * 

Selective Catalytic Reduction (European) 

170 

65 

1.5-3.0 million 

Phased Life Extension 

PEPCO - Potomac River Plant 

CG&E - Beckjord Plant 

Unit 1 

Unit 2 

Front End Life Extension 

WGPCO - Pt. Washington 1 -4 

CG&E Beckjord Unit 3 

500 

115 

112 

320 

125 

176 

203 

187 

250 

127 

0 

0 

0 

100 

0 

0 

0 

0 

0 

0 

' With FGD refers to life extension work on an existing system 

* * This capital investment is not expected to vary greatly with size of unit 

•ii 

^ •V.T-ai. 

•}..iiW.-:SP 

2$*