Coal Creek question 

Gail Fallon to: tbachman 05/19/2011 03:53 PM 

From: Gail Fallon/RS/USEPAIUS 

To: tbachman@state.nd .us 

Hi Tom, 

I am having trouble reconciling the total annualized cost for SCR in Appendix C.2 of the RH SIP for Coal 

Creek. In the company's December 2007 BART report there is a summary table in Appendix A from which 

I believe you got the figures for the State's BART determination in Appendix B.2 of the RH SIP. All the 

numbers in the company's summary for other control technologies seem to match up with the subsequent 

tables that break down the cost analyses in their Appendix A except SCR. There are two annualized cost 

totals for SCR in Table A-13 21,379,562 and 37,136,403 (includes lost fly ash sales). The figure reported 

in the summary is $56,150,000; can you help me figure out how to get to that figure? I may not be seeing 

an updated supplemental report or something along those lines. 

Thanks! 

Gail 

Gail Fallon 

Regional Haze Program Manager 

Air Quality Planning Unit (8P-AR) 

US EPA Region 8 

1595 Wynkoop Street 

Denver, CO 80202-1129 

Phone: 303-312-6281 

Fax: 303-312-6064 

Email: Fallon.Gail@epa.gov 
Coal Creek question 

Dendy, Lewis H. to: Gail Fallon 05/23/2011 12:28 PM 

Cc: "Bachman, Tom A.", "Semerad, Jim L.", "dnelson@grenergy.com" 

From: "Dendy, Lewis H." <Idendy@nd.gov> 

To: Gail Fallon/R8/USEPAlUS@EPA 

Cc: "Bachman, Tom A." <tbachman@nd.gov>, "Semerad, Jim L." <jsemerad@nd.gov>, 

"dnelson@grenergy.com" <dnelson@grenergy.com> 

History: This message has been replied to and forwarded. 

1 attachment 

~ ~ 

GRE CCS BART AppxA-E pdf.pdf 

Gail, 

You are the first person to have raised this point and I agree with everything 

you say in your message below. The answer to your question is provided in the 

Great River Energy (GRE) BART Analysis on the Appendix A-14 page (attached) 

from the 2/27/07 version. The page documents the Cost of Flue Gas Re-Heating 

(Thermal Oxidizer) at $19,017,610. Unfortunately, that detailed page does not 

appear in the final (12/12/07) version of the GRE analysis. 

The $19,017,610 for flue gas reheating plus the $37,136,403 is $56,154,013, 

which matches the total cost we used from the SCR cost summary page in Table 

A-13. I apologize for any inconvenience the omission may have caused you. 

please let us know if we can be of further assistance. 

Thanks, 

Lew Dendy 

Environmental Scientist 

ND Division of Air Quality 

918 E. Divide Ave., Bismarck, NO 58501-1947 

Ph 701.328.5188, Fax 701.328.5185 

http://www.ndhealth.gov/AQ/Airhomepage.htm 

-----Original Message----­

From: Fallon.Gail@epamail.epa.gov [mailto:Fallon.Gail@epamail.epa.gov] 

Sent: Thursday, May 19, 2011 4:53 PM 

To: Bachman, Tom A. 

Subject: Coal Creek question 

Hi Tom, 

I am having trouble reconciling the total annualized cost for SCR in 

Appendix C.2 of the RH SIP for Coal Creek. In the company's December 

2007 BART report there is a summary table in Appendix A from which I 

believe you got the figures for the State's BART determination in 

Appendix B.2 of the RH SIP. All the numbers in the company's summary 

for other control technologies seem to match up with the subsequent 

tables that break down the cost analyses in their Appendix A except SCR. 

There are two annualized cost totals for SCR in Table A-13 21,379,562 

and 37,136,403 (includes lost fly ash sales). The figure reported in 

the summary is $56,150,OOOi can you help me figure out how to get to 
that figure? I may not be seeing an updated supplemental report or 

something along those lines. 

Thanks! 

Gail 

Gail Fallon 

Regional Haze Program Manager 

Air Quality Planning Unit (8P-AR) 

US EPA Region 8 

1595 Wynkoop Street 

Denver, CO 80202-1129 

Phone: 303-312-6281 

Fax: 303-312-6064 

Email: Fallon.Gail@epa.gov 
Great River Energy Coal Creek 

BART Emission Control Cost Analysis 

Table A-14: Cost of Flue Gas Re-Heating (Thermal Oxidizer) 

CAPITAL COSTS 

Direct Capital Costs 

Purchased Equipment (A) (1) 

Purchased Equipment Costs (A) - Absorber + packing + auxiliary equipment, EC 

Instrumentation 

ND Sales Taxes 

Freighl 

Purchased Equipment Total (B) 

Installation 


Foundations & supports 


Handling & erection 


Electrical 


Piping 

Insulation 

Painting 

Installation Subtolal Standard Expenses 

Site Preparation, as required 

Buildings, as required 

Site Specific - Other 


Total Site Specific Costs 


installation Total 


Total Direct Capital Cost, DC 


Indirect Capital Costs 

Engineering, supervision 

Construction & field expenses 

Contractor fees 

Start-up 

Perlormance lesl 


Model Studies 


Contingencies 


Total Indirect Capital Costs, IC 

Total Capital Investment (TCI) = DC + IC 

10% or control device cost (A) 

0 .0% of control device cost (A) 

5% of control device cost (A) 

15% 

8% of purchased equip cosl (8) 

14% of purchased equip cost (8) 

4% of purchased equip cos I (8) 

2% of purchased equip cost (8) 

1 % of purchased equip cos I (8) 

1 % of purchased equip cost (8) 

30% 

Site SpeCific 


Site Specific 


Site Specific 


10% 01 purchased equip cost (8) 

5% of purchased equip cost (8) 

10% of purchased equip cost (8) 

2% of purchased equip cost (8) 

1 % of purchased equip cost (8) 

of purchased equip cost (8) 

3% of purchased equip cosl (8) 

31 % of purchased equip cost (8) 

Adjusted TCI for Replacement Parts (Catalyst, Filler Bags, etc) for Capital Recovery Cost 

OPERATING COSTS 

Direct Annual Operating Costs, DC 

Operating Labor 


Operalor 


Supervisor 


Maintenance 


Maintenance Labor 

Maintenance Materials 

37.00 $/Hr, 0.5 hr/8 hr shrtt, 8586 hr/yr 

15% 15% of Operator Costs 

37.00 $/Hr, 0.5 hr/8 hr shift, 8586 hr/yr 

100% of maintenance labor costs 

Utilities, Supplies, Replacements & Waste Management 

Electricity 

Natural Gas 


NA 


NA 


NA 


NA 


NA 


NA 


NA 


NA 


NA 


NA 


NA 


NA 


NA 


NA 


Total Annual Direct Operating Costs 

Indirect Operating Costs 

Ovenhead 

Administration (2% total capital costs) 

Property tax (1% total capilal costs) 

Insurance (1% total capital costs) 

Capital Recovery 

Total Annual Indirect Operating Costs 

0.05 $/kwh, 9,218 kW-hr, 8586 hr/yr, 100% utilization 

6.85 $/kscf, 4,167 scfm, 8586 hr/yr, 100% utilization 


NA 


NA 


NA 


NA 


NA 


NA 


NA 


NA 


NA 


NA 


NA 


NA 


NA 


NA 


60% of total tabor and material costs 

2% of lotal capital costs (TCI) 


1 % of total capital costs (TCI) 


1% of total capital costs (TCI) 


0.0837 	for a 20- year equipmenllife and a 5.5% interest rate 

Sum indirect oper costs + capital recovery cost 

Total Annual Cost (Annualized Capital Cost + Operating Cost) 

Reheat · Rev. May 2006 

898,458 

89,846 

44,923 

1,033,227 

82,658 

144,652 

41,329 

20,665 

10,332 

10,332 

309,968 

NA 

NA 

NA 

NA 

309,968 

1,343,195 

103,323 

51,661 

103,323 

20,665 

10,332 

o 30,997 

320,300 

1,663,495 

1,663,495 

19,855 

2,978 

19,855 

19,855 

4,006,731 

14,705,069 

18,774,344 

37,526 

33 ,270 

16,635 

16,635 

139,200 

243,266 

19,017,610