# Progress Energy

March 30, 2006

Mrs. Geneva S. Thigpen Chief Clerk North Carolina Utilities Commission 4325 Mail Service Center Raleigh, NC 27699-4325 Re: Annual NC Clean Smokestacks Act Compliance Report Docket No. E-2, Sub 815 Dear Mrs. Thigpen:

a 

## Progre§s Energy Carolinas, Inc. submits the attached report for calendar year 2005 regarding the status of compliance with the provisions of the North Carolina Clean Smokestacks Act. Section 9(i) of the Act requires that an annual report of compliance progress be submitted to the Commission by April 1 of each year for the previous calendar year. Very truly yours,

~ 

## Len S. Anthony Deputy General Counsel-Regulatory Affairs fl[.Y.R'

~ 

### fiTi 1 

## Attachment

232822



# E

Progress Energp Service Company, LLC P.O. ©ox 1551 Haleigh, NC 27602 

### AIR

~ 12_7/

## March 30, 2006

Mr. William G. Ross, Jr. Secretary North Carolina Department of Environment and Natural Resources 1601 Mail Servicc Center Raleigh, NC 27699-1601 Dear Secretary Ross: Progress Energy Carolinas, Inc. (PEC) submits the attached report for calendar year 2005 regarding the status of compliance with the provisions of the North Carolina Clean Smokestacks Act. Section 9(i) of the Act requires that an annual eompliance progress report be submitted by April I of each year for the previous calendaz year. PEC appreciates the efforts of your staff to work with us and looks forward to continuing our posifive working relationship to facilitate fiilfillment ofPEC's obligations with this important law. Please don't hesitate to contact me at (919) 546-3775 if you have any questions.

Director, Environmental Services c: North Carolina Utilities Commission Keith Overcash, DAQ

Progress Eneryy service Company, LLC P-f1.Ow i.5.''it 8aiei0h. NC 21602 

### Zuf,'b

## Progress Energy Carolinas, Inc. North Carolina Clean Smokestacks Act Calendar Year 2005 Progress Report

On lune 20, 2002, North Carolina Senate Bill 1078, also known as the "Clean Smokestacks Act," was signed into effect. This law requires significant reductions in theemissions of nitrogen oxides (NOx) and sulfur dioxide (SOz) from utility owned coalfired power plants located in North Carolina. Section 9(i) of the bill, which is now incorporated as Section 62-133.6(i) of the North Carolina General Statutes, requires that an annual progress report regerding compliance with the Clean Smokestacks Law be submitted on or before April 1 of each year. The report must contain the following elements, taken verbatim from the statute: l. A detailed report on the investor-owned public utility's plans for meeting the emissions limitations set out in G.S. 143-215.1071). 2. T1te actual environmental compliance costs incurred by the investor-owned public utility in the previous calendar year, including a description of the construction undertaken and completed that year. 3. The amount of the investor-owned public utility's environmental compliance costs amortized in the previous calendar year. ` 4. An estimate of the investor-owned public utility's environmental compliance costs and the basis for any revisions of those estimates when compared to the estimates submitted during the previous year. 5. A description of all pemvts required in order to comply with the provisions of G.S. 143-215.107D for which the investor-owned public utility has applied and the status of those permits or permit applications. 6. A description of the construction related to compliance with the provisions of G.S. 143-215.107D that is anticipated during the following year. 7. A description of the applications for perntits required in order to comply with the provisions of G.S. 143-215.107D that are anticipated during the following year. 8. The results of equipment testing related to compliance with G.S. 143-215.107D. 9. The number of tons of oxides of nitrogen (NOx) and sulfur dioxide (SOZ) emitted during the previous calendar year from the coal-fired generating units that are subject to the emissions limitations set out in G.S. 143-215.107D. 10. The emissions allowances described 

## in G.S. 143-215.107D(i) that are acquired by the investor-owned public utility that result from compliance with the emissions limitations set out in G.S. 143-215.107D. 11. Any other information requested by the Commission or the Department of Environment and Natural Resources. Information responsive to each of these report elements follows. The responses are given by item number in the order in which they are presented above.

## 1. A detailed report on the investor-owned public utility's plans for meeting the

emissions limitat'ions set out in G.S. 143-215.107D. The plan for Progress Energy Carolinas, Inc. was originally submitted on July 29, 2002. Appendix A contains an updated version of this plan, effective April 1, 2006. We continue to evaluate various design, technology and generation options that could affect our future compliance plans. 2. The actual environmental compliance costs incurred by the investor-owned public utility in the previous calendar year, including a description of the construction undertaken and completed that year. The actual capital costs incurred by Progress Energy in 2005 were $181,274,000. We successfully placed in service our first wet scrubber on Asheville Unit 1 in November 2005. A significant amount of work was performed at the Asheville plant in 2005 in order to place the Unit 1 scrubber in service. This work included the installation of electrical power and control cables and circuits, piping, pumps, valves, oxidation air compressors, instnunents and controls (including the scrubber distributed control system), agitators, absorber tower outlet hood, spray headers, trays and other tower internals, limestone and gypsum handling equipment, and gypsum dewatering equipment. Work efforts also included constructing the wetlands and industrial wastewater treatment system for treating scrubber blowdown wastewater, completing ductwork from the precipitator to the scrubber tower and from the scrubber tower to the stack, and installing new induced draft fans and various other process equipment. Much of the equipment noted above was also installed for the Asheville Unit 2 scrubber, which will be placed in service in 2006. In addition to the sctubber projects at AsheviIle, detailed design, engineering and procurement activities began for the Asheville Unit 1 SCR, which will be installed andoperational in late 2007. Based on the changes in forecasted energy demand, the inservice date for these NOx controls was accelerated from 2008 to ensure compliance with the Act's annual tonnage cap. Detailed design and engineering activities included preparation of various specifications and bill of materials, civil engineering of foundation systems, structural engineering of flue gas path components and associated structural steel, and mechanical engineering for various piping systems. Work on the Asheville Unit 1 SCR also included issuing purchase orders for the SCR catalyst, ammonia injection grids, static mixers, urea to ammonia system equipment, ash handling system changes, and sonic homs. At the Roxboro plant, environmental projects work increased significantly in 2005. Engineering, procurement and construction began or continued for each of the four units. The new electrical switchgear building that will provide power for much of the common

## scrubber equipment was completed. Various power distribution panels and load centers

located in the electrical switchgear building were placed into service. Purchase orders were issued for most of the major equipment. Structural steel was erected, along with various floor elevations for the new limestone preparation/gypsum dewatering building. Erection began on the limestone ball mills and the limestone storage silos. Two new concrete chimney shells (one for Units 1 and 2 and one for Units 3 and 4) were constructed. Many of the fiberglass reinforced plastic sections that make up the flue gas liners were fabricated off site to be ready for installation beginning in early 2006. Foundations were completed for all four absorber towers and their adjacent pump buildings. The ceramic tile-lined concrete absorber tower for the Unit 2 scrubber was built. Excavation began for the limestone storage pile and conveying equipment. Erection also started on the pipe bridge between the absorber towers and the limestone preparation/gypsum dewatering building. At the Mayo plant, initial general arrangement drawings for the wet scrubber were developed. Engineering studies were completed for the scrubber distributed controls system, electrical power distribution, and induced draft fans options. Work began on the water supply, scrubberblowdown wastewater treatment, and boiler/ductwork transient analysis studies. Engineering was also performed to support the modeling required to determine the height of the new chimney. A purchase order was issued for the absorber recycle pumps. The procurement of these pumps cequires a long lead time; they were purchased in 2005 to ensure availability and min;m;z 

## e cost increases. A milestone project schedule was developed. There were no construction activities in 2005. At the Lee plant, preliminary engineering, design, and procurement activities were initiated for the installation of low-NOx burners in 2006. The PSD petmit application was prepared and submitted to the Division of Air Quality for review and approval. There were no construction activities in 2005. At the Sutton Plant, preliminary engineering, design, and procurement activities were initiated for the installation of low-NOx bumers in 2006. There were no constmction activities in 2005. 3. The amount of the Investor-owned public utility's environmental compliance costs amortlzed in the previous calendar year. Progress Energy Carolinas, Inc. amortized $147 million in 2005.
4. An estimate of the investor-owned public utility's environmental compliance costs and the basis for any revisions of those estimates when compared to the estimates submitted during the previous year. Appendix B contains the capital costs incurred toward compliance with G.S. 143- 215.107D in 2005 and the projected costs for future yeazs through 2013, which show the net cost to PEC excluding the portion for which the Power Agency is responsible. The

## estimated total capital costs, including escalation, are cunently projected to be between

$1.1B and $1.413, with the cunent point estimate being $1.96B. This represents an increase of 52% from the 2005 cost estimate of $895 million. Prior reports have discussed the cost impact of project scope changes such as the use of a wet scrubber at Asheville in lieu of a dry scrubber, the capability to bum higher sulfur coals, and increased sulfur removal effrciency; all of which provide increased fuel flexibility for the Asheville, Roxboro, and Mayo plants. These additional cost increases reflect 1) increased costs for materials of construction, such as steel, concrete, and electrical power and control cables; 2) the need for a greater volume of these materials than originally forecast; 3) increased costs for equipment, such as pumps, fans, and electrical transformers; 4) the addition of wastewater treatment facilities, which were not included in the original program estimate; and 5) adjusting future project costs based on the actual project costs for our first completed scrubber and the current detailed cost estimates for the sctubbers under construction. It should be noted that significant design work remains to be completed, especially for the SOZ controls at Mayo, Cape Fear, and Sutton. Our cun•ent estimates are subject to further adjustment as the engineering for these projects is completed. The cost increases that we are experiencing are not unique to PEC. Other utilities with major construction pFojects for environmental controls are experiencing sinzilar increases. Significant cost increases are also being experienced on other, non-utility, large construction projects in North Carolina, especially in the Raleigh area. For example, the project costs for the expansion of Temiinal C at the Raleigh Durham Inteznational Airport were recently reported to have increased by 23% over the last 3 years due to inflation and rising building costs; projected costs for new Wake County schools were recently reported to have increased by 18-20% a year compared with an overall inflation rate of 2.7 to 3.4% due to higher prices for construction materials; the project costs for the planned commuter rail service from Raleigh to Durham were recently reported to have increased by 9% since 2004 (not adjusted for inflation); and the costs for the new Raleigh convention center currently under construction were recently reported to have increased by 12% due to the volatility of equipment and material prices in the consttuction market. Independent cost indices, such as the Chemical Engineering Plant Cost Index, also show that the costs for construction labor and materials have increased sharply. The net overall plant escalation from December 2002 through November 2005 was 19%, which is substantially higher than the 2.0 to 2.5% per year (7.7% over the same December 2002- November 2005 period) escalation rates used for the original program cost estimates.
5. A description of all permits required in order to comply with the provisions of G.S. 143-215.107D for which the investor-owned public utility has applied and the status of those permits or permit applications. Progress Energy applied for the following permits in 2005:

### Asheville Plant



## Erosion and Sedimentation Control Plan Several updates were submitted for the erosion and sedimentation control plan: Rev H for the wastewater treatment discharge pipeline, truck scale, truck wash station was approved April 6, 2005. Rev 1 for the river pumps conduit was approved June 2, 2005. Rev I for the Unit 1 SCR was appmved November 14, 2005.
NPDES Permit An Authorization to Construct (ATC) the wastewater treatment system for the pretreatment of flue gas desulfurization wastewater was approved March 29, 2005 —ATC No. 0000396A03. The ATC engineer's certifications for pretreatment and constructed wetlands were submitted November 8, 2005.
Roxboro Plant 

## Aif Permit An update to the air permit for coal handling and limestone handling was submitted on August 25, 2005. This perntit was issued on February 9, 2006.
Erosion and Sedimentation Control Plan Several updates were submitted for the erosion and sedimentation control plan: • Rev G for the gypsum storage area was approved January 21, 2005 • Rev H was rolled in with Rev G(revision H was a response to questions on revision G) and so was also approved January 21, 2005. • Rev I for the emergency access road, fire protection piping, conduit, temporary haul road was approved May 17, 2005. • Rev J for the makeup water pipeline, gypsum conveyor foundations, settling pond and bioreactor site was approved September 13, 2005 Wetlands Permitting An Army Corps of Engineers permit and water quality certification to fill wetlands for gypsum storage area was received September 6, 2005. NPDES permit

## An NPDES penvit for the wastewater treatment system was received August 10, 2005.

Submissions were made for the Authorization to Consuuct (ATC) the wastewater treatment system on October 3, November 1 and December 2, 2005. Approval for construction of the settling basin is expected in March 2006. Approval for the construction of the bioreactor is expected in the second quarter of 2006. Dam/Impoundment Safety Progress Energy's letter to the NCUC identifying work in the ash pond was approved December 5, 2005.
Lee Plant Air Pemiit A prevention of significant deterioration (PSD) permit application for the installation of low NOx bumers was subniitted on December 7, 2005. A draft permit was received February 13, 2006 and is expected to be final in March 2006. Sutton Plant Air Permit Air permit 01318T18 for the installation of Low NOx Bumers was received Februazy 21, 2005. 6. A description of the construction related to compliance with the provisions of G.S.143-215.107D that is anticipated during the following year. 

## Appendix C presents the planned construction schedule for compliance with G.S. 143- 215.107D. Please note that this is a projected schedule of construction activity through 2013 that is subject to modification. The schedule will be updated as part of this report each year. The planned construction activities at Asheville in 2006 include the completion of the mechanical, electrical and controls systems for the Unit 2 scrubber. This includes completion of the flue gas ductwork from the precipitator to the absorber tower, and installation, checkout and commissioning of the major equipment including the distributed controls system and absorber recycle pumps. Systems common to both Units 1 and 2 were commissioned during the checkout and startup activities for the Unit 1 scrubber. The unit 2 scrubber is expected to be placed into service at the end of May Construction activities will also begin for the Asheville Unit 1 SCR project. These activities include installafion of foundations for the new SCR structural steel; fabrication,

## delivery and erection of the SCR support steel; fabrication and delivery of the inlet and

outlet ducts for the SCR and the SCR reactor modules; and various mechanical and electrical activities to support placing this SCR in service in 2007. At Roxboro, the significant construction activities for the Unit 2 scrubber include installation of the absorber recycle pumps, hydroclones, oxidation air compressors, absorber tower outlet hood, flue gas ductwork from the precipitator to the absorber tower and from the absorber tower to the chimney, spray headers, trays and other tower internals, agitators, and various process piping and tanks. Flue liners for each boiler will be installed in the chimney. The stmctural steel for the absorber recycle pump building will be erected. Systems common to the scrubbers for all units such as the gypsum handling conveyors, limestone handling and preparation equipment (conveyors, feeders, silos, and ball mills), dewatering equipment (belt filters), wastewater treatment settling ponds and bio-reactor will be installed. Various mechanical, electrical and controls equipment that support the scrubber process will also be installed. Installation of the gypsum conveyor from the dewatering building to the storage pile will begin. Consttuction activities for the Unit 3 and Unit 4 scmbbers will include the erection of the absorber tower for each unit and installation of the flue gas liners in the Units 3 and 4 chimneys. histallation will begin for various electrical power and control cables and circuits along with the installation of various process equipment and piping. Minimal constmction activities for Unit 1 will be performed. Construction of these systems and the scrubber blowdown wastewater treatment system will continue through 2008.
7. A description of the apptications for permits required in order to comply with the provisions of G.S.143-215.107D that are anticipated during the following year. Several recent changes to pemritting processes in the state have dramatically increased the lead time to prepare and review environmental permits necessary for Clean Smokestacks projects. A recent court decision [D.C. Circuit Court of Appeals Decision in New York v. EPA, No. 02-1387 (June 24, 2005)] eliminated the provision exempting pollution control equipment from new source review. For Progress Energy Carolinas, this results in increased costs for consultants and modeling. For the NC Division of Air Quality (DAQ), this results in longer permit application pmcessing times. For example, the application for the installation of a low-NOx burner, which formerly took 34 months, now requires review under the PSD program, a process typically lasting a year or more. The staff at the DAQ has expedited this process for the recent pemut submission for the Lee plant. We appreciate the collaborative efforts the DAQ staff has made to assure our construction and installation schedules remain on track. However, the longer permit proccssing times continue to be a serious concem for future projects as not every permit can reasonably be expedited. PEC wishes to work collaboratively with the DAQ to prevent such delays from occurring. The following permit applications and permit approvals are anticipated for 2006:

### Asheville Plant



## Air Permit Revisions to the air permit may be necessary to test and, if necessary, install technology to reduce emissions of S03.
Erosion and Sedimentation Control Plan Revision J for the construction of the demineralizer pipe, pump and ductbank was approved in January 2006.
Roxboro Plant 

## Air Permit Revisions to the air permit will be necessary to address fugitive emissions of hydrogen sulfide from the wastewater treatment system.
NPDES Permit The ATC for the gypsum settling pond was received March 3, 2006. Receipt of the ATC for the bioreactor is anticipated in the second quarter 2006.
Erosion and Sedimentation Control Plan Rev K for the haul road, transformers, main plant area wastewater pipe trench and gypsum conveyor foundations was approved in February 2006 Rev L for burying the wastewater pipeline - approval is anticipated second quarter 2006 Additional revisions to the plan may be necessary.
Mavo Plant 

## Air Permit A construction permit will be required for the flue gas desulfurization system - anticipated submission Spring 2005.
NPDES Permit NPDES permit modification application for wastewater treatment system submitted February 23, 2006.



## 10

## A request for authorization to construct the wastewater treatment system is expected to be

submitted in the fourth quarter 2006.
Erosion and Sedimentation Control Plan The first of the erosion and sedimentation plans for the main construction area and laydown yards will be submitted during the second quarter, 2006. Additional plan revisions will be necessary as construction plans are developed.
Cane Fear Plant Air Permit A construction permit may be required to conduct a trial of an air pollution control technology. If required, this permit application will be submitted during the second quarter of 2006. Lee Plant
Air Permit A construction permit will be required for the installation of the Rotamix system for NOx control. This pemiit application will be submitted during the second quarter 2006. 8. The results of equipment testing related to compliance with G.S. 143-215.107D. No equipment testing related to compliance with G.S. 143-215.107D occurred in 2005. 9. The number of tons of oxides of nitrogen (NOx) and sulfur dioadde (SO.) emitted during the previous calendar year from the coal-fired generating units that are subject to the emissions limitatlons set out in G.S. 143-215.107D. The total calendar year 2005 emissions from the affected coal-fired Progress Energy Carolinas units are: NOx 49,621 tons SOZ 202,041 

## tons 10. The emissions allowances described in G.S. 143-215.107D(i) that are acquired by the investor-owned public utility that result from compliance with the emissions limitations set out in G.S.143-215.107D. During 2005, PEC did not acquire any allowances as a result of compliance with the emission limitations set out in N.C. General Statute 143-215.107D.

### 11. Any other information requested by the Commission or ihe Department of

Environment and Natural Resources, 

## NC Clean Smokestacks Audit Public Staff Data Request No. 5 was issued to Progess Energy Carolinas in February of 2005, and a response was provided on March 4, 2005. NC Clean Smokestacks Commission staff request was issued to Progress Energy Carolinas in April of 2005, and a response was provided on May 2, 2005 with revisions filed on May 6, 2005, NC Clean Smokestacks Audit Public Staff Data Request No. 6 was issued to Progress Energy Carolinas in February of 2006, and a response was provided on March 24, 2006.

12

# Appendix A

Progress Energy Carolinas, Inc's (PEC) Air Quality Improvement Plan Supplement April 1, 2006 On June 20, 2002, Governor Easley signed into law SB1078, which caps emissions of nitrogen oxides (NOx) and sulfur dioxide (SO>) from utility owned coal-8red power plants located in North Carolina. PEC's annual NOx emissions must be less than 25,000 tons beginning in 2007 and annual SO, emissions must be less than 100,000 tons beginning in 2009 and less than 50,000 tons beginning in 2013. These caps represent a 56% reduction in NOx emissions from 2001 levels and a 74% reduction in SOz from 20011evels for PEC. PEC owns and operates 18 coal-fired units at seven plants in North Carolina. The locations of these plants are shown on Attachment 1. Nitroeen Oxides Emissions Control Plan PEC has been evaluating and installing NOx emissions controls on its coal-fired power plants since 1995 in order to comply with Title'IV of the Clean Air Act and the NOx SIP Call rule adopted by the Environmental Management Commission (EMC). Substantial NOx emissions reductions have already been achieved (50,000 tons of NOx in 2004 compared with 112,000 tons in 1997) and further reductions will ensure compliance with the Clean Smokestacks Act 25,000 ton cap in calendar year 2007. This target will be achieved with a mix of combustion controls (which minimize the formation of NOx) such as low-NOx bumers and over-fire air technologies, and post-combustion controls (which reduce NOx produced during the combustion of fossil fuel to molecular nitrogen) such as selective catalytic reduction (SCR) and selective non-catalytic reduction (SNCR) technologies. Attachment 2 details PEC's North Carolina coal-fired electric generating units, their name plate generation capacity, the control technologies already installed, and those planned for installation. As technologies evolve or other circumstances change, a different mix of controls may be selected. Attachment 2 also projects the NOx emissions on a unit-by-unit basis based on the energy demand forecast and expected efficiencies of the NOx emissions controls employed. This information is provided only to show how compliance may be achieved and is not intended in any way to suggest unit-specific emission liniits. Actual emissions for each unit may be substantially different in 2007. Sulfur Dioxide Emissions Control Plan PEC will be installing wet flue gas desulftxrization systems (FGD or "scrubbers") to remove 97% of the SOZ from the flue gas of its Asheville, Roxboro and Mayo boilers. Screening studies will be conducted for the Cape Fear 5 and 6 and Sutton 3 units to select the most appropriate technology for these plants. Wet scrubbers produce unique waste

13

## and by-product streams. Issues related to wastewater permitting and solid waste disposal

are being addressed for each site. PEC plans to treat the scrubber wastewater stream at the Asheville Plant using an innovative constructed wetlands treatment system to ensure compliance with discharge limits. A bioreactor technology is being evaluated for the Roxboro Plant. A contract has been executed with a gypsum product end-user that will construct a wallboard facility near the Roxboro plant to use the synthetic gypsum produced by the Roxboro and Mayo plants for the manufacture of drywall products. PEC is also negotiating with another gypsum company for the use of the synthetic gypsum that will be produced at the Asheville plant Specific units are listed in Attachment 3 with data on projected schedules and projected annual emissions in 2009 and 2013. These projections assume a 97% SOZ removal efficiency, forecasted energy demand, 3.31bs SOZ/Mbtu coal on scrnbbed units, and 1.2 !bs SOz/Mbtu coal on the other units. Please note that these are projected schedules and are subject to revision. Particular units controlled and control technologies utilized are subject to change depending on future developments in SOz removal technologies, energy demand, sulfur content of coal, and other circumstances which may produce a more opfimal plan for meeting the SO Z emissions limits in 2009 and 2013. DENR will be advised as changing a circumstances dictate.

14

# Attachment 1: Location of PEC's Coal-Fired Power Plants in North Carolina



# Roxboro Cape Fear 

# I , Mayo

Asheville

Lee

Sutton Weatherspoon

## Attachment 2: PEC NOx Control Plan for North Carolina Coat-fired Units

Unit MW Rating Control Technology Operation Date l Projected 

## NOx Tons, 2007 2
Asheville 1 198 LNB/AEFLGR/SCR 2009 2,625 

## Aslteville 2 _ ------ - 

## 1 94 

## LNB/OFA/SCR 432 Cape Fear 5 — 

## 143 ROFA ROTAMIX



## _ 580 Ca e Fear 6 173 ROFA/RO'1'AMIX 770

_ Lee 1 79 WIR 928 

## Lee 2 76 

## LNB 2006 ^ 493 

## Lee 3 252 LNB/OFA/ROTAMIX 2010 1,689 Mqo 1 745

_ – 

## LNB/OFA/SCR 1 ' 741 Roxboro 1 385 LNB/OF A/SCR



## _ 1,084 Roxboro 2 670 TFS2000/SCR G 

### 1,292

_ 

## Roxboro 3 707 LNB/OFA/SCR 2,036

_ Roxboro 4 700 LNB/OFA/SCR 1,938 Su tt 

### on 1 97 SAS 1 008 

## Sutton 2 106 LNB 

## 2006 1,116 Sutton 3 410 LNB/ROFA/RO"1•AMIX 3,716 Ws n 1 49

_ 879_ ` Ws n 2 49 915 

## Ws n 3 78 WIR 1,028
'1'otal

~ 

### 5,111 24,271

AEFLOR - Amine-Enhanced Ilue L<an Gas Rebnm LND - Low NOx llnnrer SNCR - Seleclive NmnCalalvlic Reducliun OFA = OvcrOre AiF BOFA = Rotaling Oppoaed-Rred Air ROTAP1IX = Injection of Amnionia (o fnrtber rednce NOs (used in combinetion wilh ROF'A) NIR - Unrkvfirc Air TFS2000 - Cmnbinnlion I.n.-NOa 1l4nreAOverEre Air SAS = Separated Air Staging

' Note: 'I'Iris is the operalion date for the control technolugy installed to comply with the North Carolina Improve Air Quelity/Gleetrie Utilities Act oldy (show•n in bold). ' Unit by urnit cmissiuns are illustrative only and spccific ernissions litnils shonld no1 he inferred Aclual emissinns in 2007 mny be differenl fronr unit to uniL 

### 2

## Attachment 3: PEC S02 Control Plan for North Carolina Coal-Fired Units

Unit MW Rating Technology Operation Date Projected S02 Tons, 2009 1 Projected S02 Tons, 2013 1 Asheville 1 198 Scrubber 2005 864 818 Asheville 2 194
---._..____-_.-_.__ 

## Scrubber



# _ _ 2006 886 960 Ca e Fear 5 143 Scrubber 2012 6,249 656 Ca e Fear 6 173 Scrubber 2011 7,725 787 Lee 1 79 

## 2,940 2,6 60 Lee 2 76 2,637 2,756 Lee 3 252 10,078 7,493 Ma o 1 745 Scrubber 2009 14,361 3,203 Roxboro 1 385 Scrubber 2008 1,741 1,700 Roxboro 2 670 Scrubber 2007 2,853 2,577 Roxboro 3 707 Scrubber 2008 2,928 3,005 Raxboro 4 700 Scrubber 2007 2,363 2,902 Sutton 1 97 4,402 3,217 Sutton 2 106 4,052 2,768 Sutton 3 410 Scrubber 2012 16,269 1,823 Ws n 1 49 1,458 

## 1,208 Ws n 2 49 1,587 1 

### 1,286 Wspn 3 78 3,301 3,480
'I'otal 

## 5,111 86,692 44,485

I Unil by unit emissions ere illustralive only and specific en,issions lirnils should not be inferred. Aelual enrissions in 2009 and 2013 tnay be differenr frotn unil lo unil. Z Projeclions are based on 97%S02 reniovel c0icfency, farecasled energy demand, 3.3 Ibs S02/Mbtu coal on serubbed units, and 1.21bs S02/Mblu coel on others 

### 3

## Appendix B PEC's Actual Costs Through 2005 and Projected Costs Through 2013

for Clean Smokestacks Compliance (thousands)

2002 w3Ub3 -1
~ OD

~ . 4 3005 ~ '3066 2007 , f' ~ 2008 2009 = ~ 2010 011 201 2 _2013 ~ Totnl

~ w4li)0 ~

$ O

. ~ 'S: i 5 S

~ $ 0 ,~ r

~ .: P

~ ~~'~ a$35 ~69'~

~ x - ~ ' Adht ~ illt 1 rGD A6hlvillt3.§Clt

.

.. $3 141 z'~~ , n _ $U

. $ I_6 z 363 ~ $0

~ SO EO

SO i SO It . ~ . _ U ~ $ U $U — ~ — 0 — $0 EO _ 582,235 S35.7_5_2_

a• dl B SIO i 606

_ SO j $0 , $0 ~ $O

~ $O $0_! $0 .

S71,277

— — AehetUleFGllCpnlnlou • —, _ % ~~~,~7~ y __$0' $0

r7 ~ + SU

. ~ :#` ~ $0 rty'`. 6"''x ~ v

, ~ j+^+? SO

r'^t"„

~ "M°' ti
~~ $G3 a ~ rBOb ~~'~,~ r 653ti

SO r. $0

.'-,. _ $0 r — __ _ SU

_ $ O

_—_ — —

~ _ $0 $467 $IS7 1 $0

~ I,G,if
~ t $ 3.664 9 $4,46 2 $0 _ __. EO

_ $0 S202i5
~ 8

. Roxbp10i17GOCOtpmotl ` ` $403 $ti61

.. ~ _. $10,033 ~ $51,7i7

_ , ~ $56,598

. $10483

. ~ $10365

- 51,670 ~ $0 .

~ ..

—_ So $O

_ . $0 _S146,830 Roxboro 1 FGD_ $0

. SO

. $ll 10 $3 670 ~ $0 I_ _ _. $O r
__ Sll $O
__. _ $8B GS7

t __..._ _— 

### Rqxboro 2 l RGU M V ~ ~ w

~ 

### SI
~ 

### O EF .,_ ~ 

### _ ' ~ 

### ' 1 ; ~ 

### 14

~ 

### 1 3 SI 117 SO

.__ _ . i SO 

### SO E98A20 ~ 

### SO ~ SO
x ~ +SN 522 SO

_ _ SO

_ SO SO

_. , Ruxboro9 FGD

. . , $O

_ SO_

__ ~ ~ SO_ $ 95,285

. $ O T _ SO 0 ~ t

. .

. .;, ~ .d

..
_ , ~ '(( , t i ~,t_

. ,4~ Roxbbr04FG11 - '$3S S6384

.... $0 ~ .,. $0 ~ SO $0 $0 . _ $ 84,294 $O

_ SU ~ $O SO So $0 $ O a S~ 'S 2
~ 3' $ O BI_

_ $82

, , ,.;8 ~ SO

_ $ O SO S0 j

~ $0

. _ ~ '~ 1 52 " 6,b66 $0 $0

_ S78,C4U

~ _ $ O

SO $O $U 4~ 8 ~ $ I4 603 $O

~ $0 $0

4 EO

~~ 41
~ 0 . ~ So

~~ ... ~ 'S So

$ 4 2 x 200 ~ $0

_ $ 67

~ 9 ~ $O $ O S14AOU $ 175,244 601tOp3F
~ ill r u, SO EO SO 1 0 ~ E 1 3 6 SO .__ $U SI33 ~ .li ] ~

_ $2,723

.. ._. EO_ ~ $ O ( $0

_ F S57 —.__. _._. _ $0

. . ~ : . $0 $0

_ .......
_ $ 3187_ S LL8 pp24N1< $0 I
~ SO $O

~ 'w,$°

~ i
~ B, $1.822

~ _ $59_ 90

_ $O SO Eo SO $0 $2,117 At
~ tr111t ~V~1'~ ,7 1

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_ $O 90

~ $O $12,365

j __.,.,__ SO ~ SO

____ $O SO S26791 So

$1,415
_._ $D S12,G02 $O

$14,415 $0 — $I710

. _ .. $U

_ 53
~ 461„

~ 53271

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_U $O

S12344 

## $o

_ ..__...._

. $0 SO

SO $739 

## Eo . $O

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## 4 $ O 1 $ 0

__$0 $0 $0 _512,365_

,.. $19,291_ _E16,353 $ 41,R95 RoXbO T r~l1 y N"1Y ' Y

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$ O $2649' $13821 i ~ .. _$I ~ O55 

### $ 17,724 ' T01h1 '"^ ~ e F ~ "'' ~ ` S1377 S2 

### 6 29 

### $80,186 S 1 61,274 5286137 5205 34 SI59765 581,987 S110,972 S120AG4 $81,303 ' $7364 51,362,293
E3f ~ Iif8lb ~ li ~ NUDC

. , _`' " ~~ i 

### 1 $4,000 $10,00o S9,000 $20.000 $21 Uoo [ $8011 $64,800
Note: Rxcludes 1'ower Agency owncrship: 16.17% of Mzyo, 3.779'0 of Roxboro C:ommon, and 12.94%of Roxhoro 4



### 4

# Appendix C

PEC Clean Smokestacks Compliance Plan

Scrubber Design and Construction 

### Sehedule as of 41112006 Scrubber in service
MNOx

NOx Controls Design and Construction Controls in service

rG