# Appendix 10.13

Table 10-16

Reference 5: Tables 16 and 17 on page 22 and Table 28 on page 39 of "BART Application Analysis (AP-6041) for Dave Johnston Po wer Plant", May 28, 2009DEPARTMENT OF ENVIRONMENTAL QUALITY AIR QUALITY DIVISION

BART Application Analysis

AP-6041

May 28, 2009

NAME OF FIRM: PacifiCorp

NAME OF FACILITY: Dave Johnston Plant

FACILITY LOCATION: Sections 7 and 18, T33N, R74W
UTM Zone: 13 Easting: 436,592 m, Northing: 4,742,918 m Converse County, Wyoming

TYPE OF OPERATION: Coal-Fired Electric Generating Plant

RESPONSIBLE OFFICIAL: Gary Slanina, Managing Director

MAILING ADDRESS: 1591 Tank Farm Road Glenrock, WY 82637

TELEPHONE NUMBER: (307) 436-2001

REVIEWERS: Cole Anderson, Air Quality Engineer Josh Nall, Air Quality Modeler

PURPOSE OF APPLICATION:

Sections 169A and 169B of the 1990 Clean Air Act Amendments require states to improve visibility at Class I areas. On July 1, 1999, EPA first published the Regional Haze Rule, which provided specific details regarding the overall program requirements to improve visibility. The goal of the regi onal haze program is to achieve natural conditions by 2064.

Section 308 of the Regional Haze Rule (40 CFR part 51) includes discussion on control strategies for improving visibility impairment. One of these strategies is the requirement under 40 CFR 51.308(e) for certain stationary sources to install Best Available Retrofit Technology (BART) to redu ce emissions of three (3) visibility impairing pollutants, nitrogen oxides (NO

x ), particulate matter (PM), and sulfur dioxide (SO 2 ). EPA published Appendix Y to part 51 - Guidelines for BART Determinations Under the Regional Haze Rule in the July 6, 2005 Federal Register to provide guidance to regulatory authorities for making BART determinations. Chapter 6, Section 9, Best Available Retrofit Technology was adopted into the Wyoming Air Quality Standards and Regulations (WAQSR) and became effective on December 5, 2006. The Wyoming Department of Environmental Quality, Air Quality Division (Division ) will determine BART for NO

x and PM 10 for each source subject to BART and include each determination in the §308 Wyoming Regional Haze State Implementation Plan (SIP).PacifiCorp Dave Johnston Plant

AP-6041 BART Application Analysis Page 22

Table 16: Dave Johnston Unit 3 Economic Costs

Cost Existing Combustion Control Dry FGD

with ESP Dry FGD with

ESP and Polishing Fabric Filter Wet FGD

with ESP Control Equipment Capital
Cost $0 $91,499,734 $169,500,000 $144,300,464

Capital Recovery Factor N/A 0.09513 0.09513 0.0951 3
Annual Capital Recovery
Costs $0 $8,704,370 $16,124,535 $13,727,303

Annual O&M Costs $0 $4,455,188 $5,295,598 $6,044,908

Annual Cost of Control $0 $13,159,558 $21,420,133 $19,772,211

Table 17: Dave Johnston Unit 3 Environmental Costs

Existing Combustion Control Dry FGD

with ESP Dry FGD with

ESP and Polishing Fabric Filter Wet FGD

with ESP

SO 2 Emission Rate (lb/MMBtu) 1.2 0.22 0.15 0.06

Annual SO 2 Emission (tpy) (a) 13,316 2,428 1,656 662

Annual SO 2 Reduction (tpy) N/A 10,888 11,660 12 ,654

Annual Cost of Control $0 $13,159,558 $21,420,133 $19,772,211

Cost per ton of Reduction N/A $1,209 $1,837 $1,563
Incremental Cost per ton of Reduction N/A $1,209 $10,700 -$1,658 (b)

(a) Annual emissions based on unit heat input rate of 2,800 MMBtu/hr and 7,884 hours of operation per year. (b) Incremental cost from dry FGD with ESP and fabric filter is negative as a result of the lower annual cost of control for wet FGD with ESP.

Table 18: Dave Johnston Unit 4 Economic Costs

Cost Existing Combustion Control Dry FGD with

Full -scale Fabric Filter Wet FGD with

Full -scale Fabric Filter
Control Equipment Capital Cost $0 $243,100,000 $289,166,335

Capital Recovery Factor N/A 0.09513 0.09513

Annual Capital Recovery Costs $0 $23,126,103 $27,508,393

Annual O&M Costs $0 $5,318,117 $6,961,183

Annual Cost of Control $0 $28,444,220 $34,469,576