### 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, Iam having trouble reconciling the total annualized costfor SCR in Appendix C

.2ofthe 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 gotthe figures for the State's BART determination in Appendix B.2 ofthe 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 theirAppendix 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 getto 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 1595Wynkoop 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. 

### 1attachment

# ~**~** GRE CCS BARTAppxA-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.govGreat 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 cosI (8) 2% of purchased equip cost (8) 1% of purchased equip cosI (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)

AdjustedTCI for Replacement Parts (Catalyst, Filler Bags, etc)forCapital 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 hrshrtt, 8586 hr/yr 15% 15% ofOperator 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 IndirectOperating 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% oftotal capital costs (TCI) 0
.0837for 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