### March 22, 2012

Mr. Robert Irvine Supervisor, Strategy Development Unit Air Quality Division Michigan Department of Environmental Quality 525 West Allegan Street Lansing, Michigan 48909

Re: NewPage Corporation, Escanaba Paper Company (EPC) Response to U.S. EPA Comments on Michigan Regional Haze SIP

Dear Mr. Irvine,

This letter is being submitted by the Escan aba Paper Company (EPC) to the Michigan

Department of Environmental Quality (MDEQ) in response to comments received by the State

from the U.S. EPA regarding the proposed Michig an State Implementation Plan (SIP) changes to

address regional haze and the related Best Available Retrofit Technology (BART) analysis

submitted by EPC in January 2007. The EPC BART analysis was prepared in accordance with

40 CFR Part 51, Subpart P and Appendix Y to addr ess the regional haze rule requirements. EPC

believes that U.S. EPA’s conclusion that the Michigan regional haze plan must mandate the

installation of Selective Cataly tic Reduction (SCR) to control NO X 

### emissions from the Escanaba

Mill’s No. 8 and No. 9 Boilers may have been reached without the benefit of important sitespecific information and as a result is incorrect. EPC’s belief is based on two critical factors; (1)

the excessive control cost effectiveness associat ed with installing SCR on the boilers that takes

into account site-specific technical details, and (2) the imperceptible impact on visibility that

would result at the Seney Wild life Refuge and any other Class I areas due to installing such

controls. The information provided below suppor ts the conclusion that EPC’s original BART

analysis remains valid and should be incl uded in the State’s re gional haze plan.

1. The original cost estimates for installing SCR on the No. 8 and No. 9 Boilers at the

Escanaba Mill were prepared in late 2006 using control technology available at that time

and based on an SCR system vendor quote th at was provided to MD EQ (see Attachment

A). While the vendor provided some operatin g cost information in the proposal, EPCMr. Robert Irvine Response to U.S. EPA Comments on Michigan Regional Haze SIP Page 2 of 6



### included additional installation and operating co st data based on site-specific details,

which included a limited footprint of area in which the equipment can be installed. The

cost effectiveness analysis used by U.S. EPA to support the conc lusion that SCR should

be installed on the EPC boilers used simple de fault factors from the agency’s control cost

handbook that did not account for the Mill’s unique site-specific conditions. EPC

believes that U.S. EPA’s conclusions would be different when more detailed information

is considered. For example, EPC does not be lieve that U.S. EPA had the opportunity to

review the SCR system vendor quote that provided the cost information and other

technical data used in the orig inal control cost analyses.

To confirm that the initial SCR vendor quote is representative, EPC contacted the vendor

and requested an updated quote (Attachment B) . After receiving th e updated quote, EPC

contacted CCA to better understand the differe nces between the 2006 and revised quotes.

Since 2006, CCA has gained over five (5) ye ars of experience quoting and actually

installing SCR systems. During that period, CCA’s experience has indicated that the

SCR system catalyst is extremely sensitive to fouling which leads to inefficient or

ineffective NO
x 

### removal. CCA has refined the SCR systems that they install in several

ways to protect the SCR system catalyst and protect the integrity of the system. A key

component to this is the addition of reverse flow to periodically cl ean the surface of the

SCR catalyst. This SCR system design change requires a significant increase in

construction materials (e.g., ductwork, air nozzles , dampers, etc.). In 2006, the system

was quoted with a basic “off the shelf” pro cess control system. Since then, CCA’s SCR

systems have been updated to include a cu stomized process control system that has

greatly improved system reliability and eff ectiveness. CCA has even switched the

catalyst vendors for better SCR system pe rformance and support. All of these

improvements enhance SCR system performance and reliability, but come at an increased

cost. Furthermore, the 2006 quote is over five (5) years old and updated quote reflects

the increase in costs of goods and services since then. For these reasons, it was

EPC BART Response 3-22-2012.docxMr. Robert Irvine Response to U.S. EPA Comments on Michigan Regional Haze SIP Page 3 of 6



### concluded that the 2006 quote is not completely representative of the actual cost that

would be incurred to install an SCR system today.

EPC used the updated quote and incorporated U.S. EPA’s “default” costs assumptions

into a revised cost effectiveness determination. The revised NO X 

### cost effectiveness

analyses for the No. 8 and 9 Boilers are attach ed with this letter (Attachment C). As can

be seen in these revised analyses, the cost e ffectiveness associated w ith the application of
SCR on either boiler is greater than $10,000 per ton and thus EPC belie ves that the use of

SCR is not cost effective on either boiler. EPC further notes that even though the revised

cost effectiveness analysis incorporated the use of U.S. EPA’s “default” cost

assumptions, a more detailed engineering analysis would support the position that

retrofitting SCR to these boilers would require significant additional expense.

The revised the control cost estimates that are provided in Attachment C reflect the

following specific changes recommended by U.S. EPA:

• The direct installation cost multiplier was reduced from 1.85 to 0.85 consistent

with the U.S. EPA comments.

• For both boilers the reagent costs have been revised to reflect a current
$1.75/gallon price and natural gas cost s have been revised to reflect a
$4.15/MMBtu 2012 forecasted annual average price.

• For both boilers the SCR system life expectancy was adjusted to 15 years and the

interest rate was adjusted to 7% consistent with U.S. EPA comments.

• The catalyst life is revised to reflect 25,000 hours consistent with the vendor’s

revised quote.

Although EPC incorporated the U.S. EPA defa ult cost assumptions there are several

factors that would result in additional retrofitti ng expenses that shou ld be considered and

would require the use of non-default cost assumptions. The Escanaba Mill has limited

space available in the immediate vi cinity of the two power boilers in which to locate the

EPC BART Response 3-22-2012.docxMr. Robert Irvine Response to U.S. EPA Comments on Michigan Regional Haze SIP Page 4 of 6



### new SCR systems. As a result, the SCR equipment would need to be installed on

elevated platforms designed to handle the we ight of the new components, significantly

increasing the installation costs for the SCR systems. As noted by the vendor, the new

systems would likely require new induced draf t fans to overcome the added resistance

associated with the catalyst systems and associated duct work. Although the revised

quote did not factor the cost for a new st ack, EPC believes that a replacement stack

would likely be required for the two stacks cu rrently exhausting the No. 9 boiler. U.S.

EPA appears to believe that 75% of the energy used to reheat the No. 9 Boiler stack gases

can be readily captured and reused by the Mill for other purposes. Technically, this may

or may not be accurate, but assu ming that it were true, there would be substantial costs to

recover the heat to make steam and then to pipe the steam to the Mill’s existing supply

system. None of the costs associated with the items mentioned in this paragraph are

included in the revised cost effectiveness determinations.

Of significant importance to consider is that in the five (5) years since the EPC BART

analysis was submitted to MDEQ, much expe rience has been gained regarding SCR

installation and operation. However, EPC has no t been able to identify a single wood or

biomass fired boiler that incorporates S CR technology following a wet scrubber system

such as that installed on the No. 9 Boiler at the Escanaba Mill. A ll of the SCR systems

identified on these types of boilers are installed following dry particulate matter control

devices such as ESPs or fabric filters. Al so it should be noted that the original cost

effectiveness analysis reflected a 90% NO X 

### removal efficiency and in practice, the actual

NO X 

### control efficiency is likely between 75% and 80% (based on review of multiple

applications of SCR to biomass boilers). The updated cost effectiveness analysis reflects

a 76% NO X 

### control efficiency.

2. In addition to the technical and economic lim itations of applying SCR to the No. 9 and

No. 8 Boilers, the po ssible reduction of NO X 

### emissions has a minimal effect on

improving visibility. Visibil ity modeling that was conducted to support the original

EPC BART Response 3-22-2012.docxMr. Robert Irvine Response to U.S. EPA Comments on Michigan Regional Haze SIP Page 5 of 6



### BART submittal in January 2007 as well as fo llow-up visibility modeling in September

2007, which reflected use of the new “Impro ve” equation, both demonstrated that

visibility improvement associat ed with a 90% reduction in NO X 

### emissions was minimal.

As shown in the tables pr ovided to Michigan DEQ in May 2008, the individual baseline

visibility modeling for the two boilers indicates that the 98 th 

### percentile deciview values

due to emissions of all visibility impair ing pollutants (VIP) are less than 0.50 for each

boiler for each of the three y ears evaluated. Of special not e is that the No. 9 Boiler 98 th



### percentile deciview values are all less than 0.20 deciviews. When SO 2 

### and particulate

matter emissions are held at baseline levels and NO X 

### emissions are reduced by 90%,

there is very little change in the 98 th 

### percentile values fo r both boilers. The 98 th



### percentile deciview values fo r the No. 9 Boiler decrease by less than 0.10 deciview, thus

there is no meaningful visibility improvement to controlling NO X 

### emissions from the No.

9 Boiler. For the No. 8 Boiler reducing NO X 

### emissions by 90% results in a 0.29 deciview

improvement in visibility at the 98 th 

### percentile value, which is also imperceptible. Also,

comparing the existing actual NO X 

### emission factors for both boilers with emission limits

from recent BACT determinations, applica tion of SCR would likely produce a 75-80%

reduction in NO X 

### emissions, not a 90% reduction and t hus the visibility modeling that

was performed in 2007 and 2008 for the S CR 90% control scenarios for both boilers

over-states the possible visibility improvement.

It is also noted that the baseline emission s cenario evaluated for the No. 8 Boiler reflects

a combination of peak SO 2 

### emissions (due to peak oil firing rates) and peak NO X 

### emissions (due to peak natural gas firing rate ). It is not physica lly possible to achieve

this dual fuel, peak firing rates simultaneous ly. In fact a review of the No. 8 Boiler

operating records conducted for the May 2008 re sponse to Michigan DEQ shows that the

peak firing of either natural gas or fuel oil o ccurs very infrequently. With respect to the

peak No. 8 Boiler NO X 

### emission rate of approximately 390 lbs/hr, the daily operating

records indicated that the boiler emitted NO X 

### at this rate on th ree days in 2005 and no

days in 2004, 2006, 2007, and 2008. Thus the No. 8 Power Boiler never actually emitted

EPC BART Response 3-22-2012.docxM r

. R o b e rt i rv in e Res p o n s e t o U

. S

. E P A Co mm en t s on M i c hi gan Reg i o n a l H a z e S lP

P age 6 of6

a t a r a t e for e n o ugh d ay s t o excee d th e 98 th p e r ce ntil e ( i. e

. , th ere we r e l ess th a n 8 d ays

w h e n th e boil e r e mitt e d a t e l eva t e d N O x l e ve l s

. ) Th e hi g h es t N O x e mi s s ion r a t e that w a s

s u s t a in e d f o r at m os t seve n (7) d ays durin g th e 2 004 to 2 009 p e ri o d was 1 6 0 lb s p e r h o ur

.
Vi s ibili ty mod e lin g f or a tru e , wo r s t

- c a se b ase l in e op e ratin g sce n a ri o f o r th e No. 8 Boi l e r

indi c at es a 9 8 1 h p e r ce ntil e v i s ibi l i ty imp act of 0 .23 d ec i v i e w

. furth e r co ntr o l o f th e No. 8

B o il e r N O x e mi ss i o n s wo uld r es ult 

### in in co n se qu e ntial impr ove m e n t t o v i s ibili ty w hil e

i nc u rri n g s ub s t ant ial o n- go in g co s t s t o t h e fac ili ty

.

We a pp rec i a t e th e o pp o rtu nity t o p rov id e th e r e s p o n ses t o t h e U

. S

. E P A 's co m me nt s o n t h i s

port i on of t h e MDEQ r e gional ha ze S I P and EPC 's rel a ted BART analy s i s. I f d u ring th e re v i ew

of thi s inform a ti o n , th e r e ar e qu es ti o n s or a dditional inf o rm a ti o n i s r e quir e d

, pl e a se d o n o t

h es it a t e t o c o nt ac t m e at 9 0 6-233-2929 o r v i a e mail a t t o dd .sc hmidt @ n ew p a p eco rp .com. Th a nk

yo u f o r yo ur ass i s tance w ith thi s m a tt e r.

S in ce r e l y , 

# Sls c hnll : 3£G

E n v ir o nm e nt a l M a n ager E s ca n a b a Pa per Co mp a n y

E ncl o s ur es:

EPC B A R T Response 3·22

· 20 1 2

. docx A TI A C H MEN T A

- 2 00 6 CC A S C R BUD GE T PR O PO SAL

ATTA C HM EN T B

- 2 0 1 2 REV I SE D CC A S C R BUD GE T PROPO SA L
ATTA CHMEN T C

- REVI SE D C O N TROL C O S T TA BL ES

## ATTACHMENT A – 2006 CCA SCR BUDGET PROPOSAL

### All4 UNIT # 8 & 9 LOW NOx SCR
BUDGET PROPOSAL

For

Marvin Gregory
All4 Inc Jackson, OH

EMAIL: mgregory@all4inc.com



### Proposal No. ESS12162006 December 16, 2006

Prepared by:

Edmund SchindlerCombustion Components Associat es, Inc. 884 Main Street Monroe, CT 06468 203-268-3139 PH
203-261-7697 FAX 

### 2

TABLE OF CONTENTS

2.0 OBJECTIVES ............................................................................................................. 4
3.0 PROGRAM ACTION PLAN .................................................................................... 4 3.1 SCR System .............................................................................................................. 4 3.2 Optimization, StartUp, Testing and Interim Report.................................................. 6
4.0 COMMERCIAL TERMS .......................................................................................... 7 4.1 Program Budget ........................................................................................................ 7 4.2 Program Schedule ..................................................................................................... 7 4.3 Validity ..................................................................................................................... 8
4.4 Terms of Payment..................................................................................................... 8
4.5 Commercial Terms.................................................................................................... 8

APPENDIX
Appendix A – Experience Lists Appendix B– CCA Fees & Scope of Service Sheets

Confidentiality and Proprietary Information

Notice to Recipient of Proposal:

In consideration of CCA preparation of this proposal and disclosure of certain propr ietary information, its recipient agrees to treat as confidential all CCA proprietary information disclosed herein. Such proprietary information includes, but is not limited to, all technical requirements, specification(s), p rint(s), and information relating to the description and operation of the system, which is the subject of this proposal, its components, equipment, options and related services, design s, processes, techniques, documentation, pricing, installation, and safety. The recipient furt her acknowledges that CCA proprietary inform ation is unique and valuable, was devel oped or acquired by CCA at substantial expense, and is the subject of efforts by CCA to maintain the secrecy ther eof. The recipient agrees not to reverse engineer, to use or t o disclose this proprietary information to any person or party without the prior written consent of CCA. This agreement is effective between the recipien t and CCA regardless of whether the parties enter into a contract for sale of the goods and/or services that are the subject matter of this proposal. © Copyright 2006, CCA. An unpublished work. All rights reserved. This document may be reproduced as required only for the inter nal use of its recipient in evaluation of this proposal.Combustion Components Associat es, Inc. 884 Main Street Monroe, CT 06468 203-268-3139 PH
203-261-7697 FAX 

### 3

1.0 INTRODUCTION

Boiler #8 at another location is a small natura l gas/fuel oil-fired unit that does not have any add on PM controls. The heat input is 400 mmBtu/hr.

Stack temp 300F - 320F Moisture 7% Flow rate 180,000 acfm SO2 115 tpy NOx 137 tpy
O2 5% PM 7.6 lbs/MMCF when burning gas (AP-42) PM 12.4 lbs/MMCF when burning fuel oil (AP-42) Flue gas temp prior to air heater 600F
CO and CO2 data are not available for this unit.

Boiler #9 adjacent to boiler #8 burns wood wast e and natural gas. The unit is equipped with multiclones and parallel wet scrubbers for PM control. The boiler is rated at 360 mmBtu/hr heat input.

Stack temp 140F to 150F Moisture 20% Flow rate 140,000 acfm SO2 43 tpy NOx 932 tpy
O2 7 to 8.5%
PM 0.119 lb/mmBtu after PM controls CO 800 ppm
CO2 10 to 11% Flue gas temp prior to air heater 375FCombustion Components Associat es, Inc. 884 Main Street Monroe, CT 06468 203-268-3139 PH
203-261-7697 FAX 

### 4



## 2.0 OBJECTIVES

The program objectives are as follows:

1. Provide an SCR system for 90% NOx reducti on for the worst fuel of each of the three
boilers. 2. Supply a urea supply and injection system to supply ammonia to the catalyst. 3. Identify ID Fan upgrade requirements



## 3.0 PROGRAM ACTION PLAN

The program action plan consists of three (3) parts:

1. Survey the units and locate space to install the catalyst bed and the urea tank. 2. Design the system and the ductwork. 3. Provide the system 4. Provide installation supervision 5. Provide startup, optimization and testing.



## 3.1 SCR System

CCA has provided SCR to mobile and stationary diesel engines ranging from a diesel engine in a pickup truck to a 2MW electric generation diesel system. We have supplied over 150 of these systems to date. All of these typically reduce the NOx 80 to 90% while moving down the road. Because we have focused on small mobile sources our SCR systems can be supplied for much less then the large OEM suppliers of SCR technolog y. Our patented injection and control system provides a compact and straightforward system th at can easily be applied to small industrial boilers. In addition volume production of key components and pre-engineered systems has reduced the cost to provide a complete system. Our system uses no atomizing air or steam to atomize the urea or ammonia and the total power requirements is less then 100 watts for each complete system.

The system is designed for 100% flow of flue gas through the catalyst bed at a temperature of 600F. The SCR can maintain 90% reduction of NOx within a temperature range that is dependent on the catalyst used. Up stream of the catalyst the urea is injected into the duct and it converts to ammonia in the hot flue gas. Th e ammonia combines with the NOx at the catalyst
surface and reduces the NOx to N2. After NOx reduction is achieved the Flue gas from theCombustion Components Associat es, Inc. 884 Main Street Monroe, CT 06468 203-268-3139 PH
203-261-7697 FAX 

### 5

catalyst is passed on to the ID fan and then to th e ESP. Each of the two boilers will require a slightly different system. Boiler 9 will require a high dust catalyst, Boiler #8 can use a low dust catalyst used for oil and gas and boiler 9 will require a duct heater to bring the flue gas temperature up to 600F or to the minimum catalyst temperature. There are catalysts available that can operate down to 450F but they are more expe nsive and it may make sense to just bring the temperature up to 600F. For boiler #9 that burn s wood waste, the trace gas
constituents must be defined and limited to in sure that no catalyst poisons are present.

The Equipment and engineering supply is as follows:

Boilers 1, 8&9 SCR Component Unit #8 Unit #9 Tank-6000 gallon polymer tank for inside storage of urea with urea pump and motor, inline filters
and tank level sensor One tank for Boiler #8 & 9

Catalyst Type, Installed before the air heater. Oil and gas High dust
wood and

gas Catalyst Volume, CM 22.3 20.1 Catalyst Shell-CS fabrication 1 1 Transition Duct 20 feet of CS duct included per
boiler 1 1

Bypass Duct and two dampers to bypass minimum boiler load at 500F flue gas temperature
and below. 1 1

Additional ID fan requirements to be tested and proven or upgraded 109,000

a 180,000
acfm at 4
inwc 140,000 at 6
inwc

Gas Duct burner to raise flue gas to 600F None 1 Return Flow Injectors with SS hoses 4 4 Electronic Control Units (ECU) 2 2

Lot of instrumentation (flow sensor, temperature of gas) 1 1

Urea pumps for each unit with auto backup 2 2 Urea Day Tank for each boiler including urea pump and motor, inline filter, level sensor, ECU and wiring harness 200 gallons 200 gallons

CFD model to determine best injection point and mixing for each unit. 1 1

Installation Supervision 4 days total 4 days total 

### Note the Multiclone must be operating at its design condition to minimize the PM carryover to the SCR.

Utilities Required for the System

Boilers8 & 9
Electric 110 VAC 100
Watts eachCombustion Components Associat es, Inc. 884 Main Street Monroe, CT 06468 203-268-3139 PH
203-261-7697 FAX 

### 6

Air None
Water None
Urea Rate #8 #9 Urea Average Rate, gph 6 43

Control Voltage 0-5 VDC

The ELIM-NOx pump system automatically starts when the boiler is started. Injection begins when the exhaust temperature at the catalyst reaches 500 degrees F or above. The system ECU takes in Boiler and load and sets the injection rate based upon a map that is programmed into the ECU at start-up. The bypass dampers switchover the flow to pass through the catalyst. The injection rate is set by modulation of the injector pulse width (injector % on time). If the exhaust temperature drops below 500 degrees F, such as during startup or shutdown, the injection will stop automatically and the bypass dampers will redirect the flow around the catalyst. When the boiler is turned off, the circulation pump through the injector continues for 10 minutes, until the exhaust pipe cools off. Then the pump
shuts off. No compressed air is required for the ELIM-NOx system. A flow schematic of the system is shown below;

There is no power or performance penalty associated with the ELIM-NOx system, other that the 100 watts of auxiliary power requirements and the urea consumption. The catalyst is guaranteed for 3 years or 12,000 hours, whichever comes first. The injection system is warranted for one year.

CCA takes no responsibility for undisclosed trace elements in the wood waste that are catalyst poisons that may degrade catalyst performance prematurely. Known catalyst poisons will shorten the life of the catalyst.



## 3.2 Optimization, StartUp, Testing and Interim Report

Upon completion of the installation of the SCR system, CCA’s engineer will advise All4 on optimization of operational changes which will improve overall unit performance and reduce NOx emissions. The performance of the boiler will also be evaluated by operating the unit with bias firing. The performance testing will be conducted over the complete load range of the boiler. The SCR load range is limited by the catalyst in let temperature. The unit will be operated and tested at various conditions, including:

• Excess oxygen

• Load

• Fuel

• Urea injection rate

• Ammonia slip

This performance and emission testing is expected not to exceed a total of 15 days for the two boilers. All emission monitoring equipment and personnel to operate it are to be provided by CCA. Upon completion of testing, an interim report will be issued containing the followingCombustion Components Associat es, Inc. 884 Main Street Monroe, CT 06468 203-268-3139 PH
203-261-7697 FAX 

### 7

information:

1. Conclusions of the program and recommendations for future corrective actions, if any. 2. Comprehensive report of the NOx reduction over the load range. 3. Test Data Summary of the results of the optimization testing.



### If additional time is required through no fault of CCA, this will be charged at per diem rates.



## 4.0 COMMERCIAL TERMS

4.1 Program Budget

CCA will perform the NOx Reduction Program outlined in this proposal in Section 3 for the Budget Price of $1,223,000 for unit #8&9 in accordance with our
Commercial Terms and Conditions and Fees and Scope of Service schedules located in the Appendix. CCA is not responsible for incidental, consequential or special damages.

I have included $50,000 for a duct burner allowance for unit #8. During a firm bid quote we can supply the duct burner or other means to raise the temperature of boiler #9. No provision has been included to upgrade the ID fans if that is required.

The urea storage system is included in Boiler # 8 price. Urea storage is designed for indoor location. If outdoor is required then heating and insulation must be added.

All prices are quoted exclusive of state and local sal es, excise, use or any ot her taxes. Such taxes, if applicable, will be in addition to the above prices and will be charged to your account. Any
taxes assessed to CCA at a later date will be ch arged to your account. If the above items are tax exempt, the applicable tax exemption certificate is to be sent to CCA with your purchase order



### .

The price is FOB the factory in Connecticut, with freight prepaid and included.



## 4.2 Program Schedule

CCA can complete the work outlined in Secti on 3 in approximately 10-12 weeks after the authorization to proceed and all required details.

The actual schedule will vary depending upon manpower loading at the time the authorization to proceed is received.Combustion Components Associat es, Inc. 884 Main Street Monroe, CT 06468 203-268-3139 PH
203-261-7697 FAX 

### 8



## 4.3 Validity

This proposal is valid for a cceptance for sixty (60) days.



## 4.4 Terms of Payment

Twenty percent (20%) of the contract price shall accompany your written purchase order. The remaining eighty percent (80%) shall be paid in progress payments upon completion of each phase or portion of phase as follows:

With PO-------------------------------------------20% Engineering Complete--------------------------20% Purchase of Long Lead Items------------------20% Equipment ready for shipment----------------30% Completion of Startup--------------------------10%

Note: Final payment is due 60 days after successf ul demonstration of contract performance or (when performance testing is delayed) 180 days from final shipment of equipment, whichever
comes first.



## 4.5 Commercial Terms

CCA terms and conditions will be used for this pr oject. They can be found in the appendix.Combustion Components Associat es, Inc. 884 Main Street Monroe, CT 06468 203-268-3139 PH
203-261-7697 FAX 

### 9

Low-Cost Environmental Compliance for Stationary Reciprocating Engines CCP\s breakthrough ELIM

- NOxlll SCR system cost

- effectively re<luces NOx emissions from stationary reciprocating engines. The CCA ELIM · Noxn.o SCR system i s an Advanced Reagent I njection System that incorporates a urea-based Selective Cata l ytic Reduc ti on (SCR) techno l ogy

. This next generation techno l ogy with a proprietary ' se l f- l earn· injec ti on system achieves 90%+ NOx reduction at a very low**cap~al** and operating cost.

CCA ELIM-NOx"' SCR· How Does it Work? The CCA ELIM-NOx n.o SCR system meters precise amounts of a safe reagent- urea, i nto the exhaust stream of d i esel or lean burn natural gas engines. When injected into the exhaust gas stream of an engine

, urea deoomposes to ammonia (NH

, ) and reacts**w~h** oxides of nitrogen (NOx)

across a cata l yst lo cate<! downstream of the injection point to reduce NOx. The s i mple chemical process described be l ow represents the chemical reaction ;

4 N 0+4 N H

, +0

, ->4N

, +6H

, O
2 N

0

, +4 NH

, +0

, -> 3 N

, + 6 H

, O

The i ntegrate<! CCA ELIM-NOx n.o SCR system comprises of just 4
p ri mary components. These i ncl u de a tank (on which the ECU

, pump, fitter, level and urea pressure sensors are mounted}

, an injector, the catalyst housing, and a w iri ng h arness

.

CCA SCR Uses Urea

- No Danger of Spills The CCA ELIM-NOx n.t SCR system uses a urea based reducing reagent
to de l iver ammon i a to the catalyst. Th i s reagent conta i ns 32.5% to 40%

urea and water. Injector p u lse width modulation (PWM)**w~h** bypass fl ow is utlfized for metering the reagent. The reagent meets specific standards
tor water and urea**qual~** and contains surfactants a n d stabilizers that prevent fouling of the urea i njection system

. I t is safe, does not pose a serious concern in case of sp i lls and contains no harmful chem i ca l s (such

as phosphorus) that may poison the catalyst Moreover, the reagent does not have to be heated, j u st mainta i ned above 1 5• F

.

A Next Generation SCR Design Proprietary l rfection System Achieves**O~mum** Urea Distribution

- The CCA ELIM-NOx"' SCR system has a unique and proprietary injec ti on system with a single flu id atomizer designe<l for optimum distrib u tion of the reagent

- urea

. This proprietary i n j ection system comprises a single-fluid return flow urea reagent injector, comb i ned wit h a low-pressure pump, a pressure regulator and electronic controls that accurate l y meter the amo u nt of reagent i njected

.

E l ectronic Controls I ncrease I n jectio n E fficiency· The i njector Electron ic Contro l Unit (ECU) is progra m med to control the urea injectio n rate as a function of engine parameters such as rpm, load or NOx output signal. The ECU is programmed to modulate the signal to the so l enoid act u ate<! i njector va l ve. w h ich reg u lates the pe ri od of time the i n jector remains open during each cycle of the factory set injector cycle frequency.

COMBUSTION COMPONENTS ASSOCIATES, INC • 884 MAIN STREET • MONROE • CT • 203 268 3139

www.cca· 1 nc.netCombustion Components Associat es, Inc. 884 Main Street Monroe, CT 06468 203-268-3139 PH
203-261-7697 FAX 

### 10

N

o Steam or Ai r Atom iz ation Require d

- One of the unique advantages of CCA's injector system is that it is capable of providing the droplet size distribution required, without an atomiz in g medium, such as steam or compressed air. This feature reduces the lifecycle cost of the system. Depend i ng on the reagent flow required, one or more injectors are fitted to the exhaust gas duct upstream of the catalyst. A standard technology prefabricated pumping and control module will feed up to two injectors and is suitable for engines rated up to 3000 HP (2,250 kW)

. For larger applications above 3,000 hp requiring multiple injectors or for mu ltipl e engine sites, CCA offers custom engineered systems. T hese systems use

a common reagent circulation loop feeding a number of eng ine s**w~h** multiple injectors on the exhaust duct of each eng in e.

U r

ea I n j e ct i o n b eg in s at 

### 2 so• c -Injection occu r s above a minimum exhaust gas temperature, wh i ch enables the thermal decomposit ion of

urea to ammonia upstream of the catalyst. The injector is kept coo l and prevents urea deposits from forming in the in jector by using the r eturn flow of urea from the in j ector. The pump provides the proper recirculation flow rate from the tank to the inj ector and back to the tank

. The Electronic controls are designed to cease u r ea inject i on if the urea tank level sensor ind ica tes low leve l s of the reagent.

Pa te nted Se l f- L earn Sys t em

- The self learn system te m porarily attaches to the exhaust outlet duct and records uncontrolled NOx, temperature and exhaust flow rate. The system monitors key engine parameters and automatically populates the in jection strategy map. This sets the urea injection rate for the various engine operating conditions so that the system operates at peak performance under all condit i ons. This method m i nimizes start -u p and opti m ization costs.

Choosing the Best Catalyst The se l ection of a catalyst primarily depends on its NOx conversion performance over the range of exhaust gas temperatures encountered on the particular application. Performance of a catalyst is usually a function of its specific catalytic act i vity and NOx reduction required which, in turn, determines the volume of catalyst required.

The CCA ELIM-NOx ru SCR system can be designed for several d iff erent types of catalysts including vanadium/titanium wash coated or extruded and zeolite based catalysts. These catalysts operate in exhaust gas temperatures between 

### 25o•c

- soo·c. CCA has establ i shed relationships

w

ith so m e of the largest catalyst manufacturers to ensure that our customers get the optimal catalyst design and best prices.

We Guarantee Your Success Success of an SCR application depends on the exhaust gas tempe r ature being adequate for urea decomposttion and the selection of a catalyst that matches the exhaust gas temperature and exhaust gas flow rate. Actual NOx reduction then becomes a function of project in g the reagen t in jection accurat9 l y and sizing th9 catalyst. With 20,000 MW of combustion experience on l arge power boilers. CCA brings expert understand i ng of the process that enables us design and implement comprehensive low

cost NOx solutions for o u r customers. O u r n e xt g e nerat i o n SCR d e s i gn

an d su pport se rv i c es gua ra n tee re su l ts, e n su r in g tha t o u r cu st om e rs sta y i n co m p l i a n c e in a**t~ ff** **tive** an d reliable m a n ner

. Our ifllegrated SCR design with fll$t 4 pflmary components and comprehensive support servicos guarantoes performance w1th tho least diSIUplion

to your operations ot vory offordoblo pncos

.

COMBUSTION COMPONENTS ASSOCIATES, INC • 884 MAIN STREET • MONROE • CT • 203 268 3139

www.cca- 1 nc.netCombustion Components Associat es, Inc. 884 Main Street Monroe, CT 06468 203-268-3139 PH
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Boiler 

### BoilerCombustion Components Associat es, Inc. 884 Main Street Monroe, CT 06468 203-268-3139 PH
203-261-7697 FAX 

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Manpower Rate:
Manpower charges shall be on an hourly, porta l-to-portal basis at the following rates:
Principal Consultant $200/hr Senior Engineer $160/hr Engineer $125/hr Designer $100/hr Draftsman $90/hr Technician $100/hr Secretary $50/hr

The basic rates shall apply for work on M onday through Friday for an 8-hour period between the hours of 7 A.M. to 7 P.M. Wo rk in excess of 8 hour s, night work and Saturday work shall be at a rate of 1.5 tim es the basic rate. Sunday and holiday work shall be at 2 times the basic rate. Travel tim e charges shall be at the basic rate for hours actually spent in travel.

Minimum Daily Charges:

A minimum daily charge for personnel in the field shall apply of 8 hours per day per person at the basic manpower rate. The mini mum daily charge sha ll apply to travel on weekends, but not weekdays.

Expenses : Per-diem charges per person shall be actual co st plus 10% G&A. Ve hicle travel charges shall be:

Automobile .48cts/mi Truck or Trailer .75cts/mi

All other travel costs such as air fare, car rent al, taxi, parking, tolls, etc., shall be charged at cost plus 10% G&A.
CEM Van Rental: $750/Day Portable Gas Analyzer : $250/Day Coal Flow Testing Equipment : $600/Day LOI Testing: $600/Day Flow Laboratory Facility $1,300/Day Combustion Test Rig $2,500/Day Field Delays:

Delays imposed on CCA personnel in the field resulting from causes beyond CCA's direct control, such as partial or complete process shutdown or irre gularity, strike, flood, fire, inclement weather, or failure of the client to meet herein stated responsibilities, shall be charged at the minimum daily rate plus per diem and applicab le travel expenses, unless exceeded by actual time at the facility. Then, actual time will be charged. No delay time shall be charged fo r a delay directly caused by CCA, such as, malfunction of CCA test equipment.

Quotations:

Unaccepted quotations shall expire 30 days from date of issuance. Requested changes in project work scope shall subjec t a price quotation to change.

Acceptance:

A purchase order or a written commitment for a quoted amount shall be received prior to the rendering of any service. A purchase or der with a "not to ex ceed" amount will result in the termination of services before the amount is exceeded. Issuance of a new purchase order, a written addition to the existing purch ase order, or other written authorizationCombustion Components Associat es, Inc. 884 Main Street Monroe, CT 06468 203-268-3139 PH
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from the client shall be received before rendering of services is resumed. Authorization by the client to proceed shall constitute the client's acceptance of these terms and conditions.

Escalation:

Once yearly, the outstanding portion of a quotation or budget for a project conducted over a time span of more than one year shall be subject to escalation for any new manpower rates or expense schedules issued by CCA.

Payments:
Invoiced payments shall be due in full within 30 days of the date of invoice. Invoices 30 days past due shall accrue in terest charges at the rate of 1 1/2% per month, due and payable by the client. Reasona ble attorney fees, collectio n fees and other expenses incurred in collecting overdue amounts may be charged.

Extra Services:

Quotations for work do not in clude pre or post conf erences or follow-up services, unless otherwise noted. CCA's standard charges for such extra services will apply unless provided at CCA's option.

Research and Development Projects:

Research and development prog rams are by nature subject to frequent changes in scope, direction, and budget. CCA Corporation undertakes such programs on a time-and- materials basis only. For each research and development program, a best-estimate budget shall be presented. Charges against is budget shall be made for time spent and costs incurred. Should a program require funding in excess of the budget, the client will be notified for written authoriza tion of the new budget prior to initiating work, which would incur charges above the old budget.

Combustion Optimization Programs:

The performance requirements of combusti on optimization programs necessitate that CCA Corporation charge such programs on a time-and-materials basis. However, for each program a budget will be presented to th e client. Should a program require funding in excess of the budget, the clie nt will be notified for writ ten authorization of the new budget prior to initiating further work.

Patents and Proprietary Technology:

CCA reserves all proprietary rights, including patent rights, in and to all devices, concepts, processes, products , inventions or other technol ogy conceived or developed by CCA personnel during work conducted for a client. The client may use such CCA proprietary technology, r oyalty free, solely fo r the specific installation for which CCA's work was provided, and client may negotiate terms with CCA for expanded use to other installations.

Warranty - Services:

CCA represents and warrants that its procedures are generally ac cepted practices and methods and its personnel are qualified to a ffect such procedures. Tests are performed on a best-efforts basis and CCA assumes no liab ility for deviations required by existing conditions beyond its control or field of resp onsibility. No guara ntee or warranty is issued, implied or intended and no responsibil ity is assumed for testing other than the accuracy of observed results. Should CCA’s te sting be materially defective, the sole liability of CCA shall be to re peat said test run at no addi tional cost to C lient, provided, however, that said test run wa s not defective because of a failure of Client to supply critical information or to fulfill responsibilities.

Warranty – Products:

CCA represents and warrants that (a) products manufactur ed by it shall be (i) free of defects in materialsCombustion Components Associat es, Inc. 884 Main Street Monroe, CT 06468 203-268-3139 PH
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and workmanship for a period of sixty (60) days from date of shipment to client and (ii) shall conform in all material respects to the specifications for such prod uct agreed upon in this contract. For products not manufactured by CCA the original manufacturers warranty, if any, shall be assigned to client to the extent permitted and such assigned warranty shall be in lieu of any other warranty express or implied. CCA’s sole liability hereunder shall be during th e sixty (60) day product warranty pe riod to repair or replace, at its option, products that are defective or non-conforming to agreed specifications. CCA shall have no liability for removal, transportation and replacement of such products.

Limitation and Disclaimer of Warranties:

CCA shall not be liable under the warranties hereunder unless:

(a) Client promptly notifies CCA in writing of the alleged deficiency in the product or service and offers CCA a reasonable opportun ity to cure such deficiency, and (b ) if a product deficiency in a CCA manufactured product, CCA inspection verifies the exis tence of the deficiency and determines it was not caused by damage or destruction, including any occurring while in shipment, improper installation, testing or repair (including any repair not by CCA agents or employees or otherwise not consented to in writing by CCA), misuse, neglect, or alteration.

THESE WARRANTIES ARE IN LIEU OF AND CCA DISCLAIMS ALL OTHER WARRANTIES, EXPRESS OR IMPLIED, WRITTEN OR ORAL, INCLUDING THOSE MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, OR OTHERWISE, AND MAY BE MODIFIED BY CCA ONLY IN A WRITING SIGNED BY CCA IN WHICH IT INTENDS TO BE FOUND.


### Limitation of Liability:

CCA SHALL NOT BE LIABLE FOR ANY SPECIAL, INCIDENTAL OR CONSEQUENTIAL DAMAGES, WHETHER BASED ON BREACH OF CONTRACT OR WARRANTY, NEGLIGEN CE, OR ANY OTHER MATTER RELATING TO THIS CONTRACT. CCA’S MAXIMUM LIABILIT Y SHALL IN NO CASE EXCEED THE AMOUNT THAT HAS BEEN PAID TO CCA FOR THE PRODUCT OR SERVICE PRIOR TO THE EVENT WHICH RESULTS IN SUCH LIABILITY OR, FOR INSURED MATTERS, THE AMOUNT OF SUCH INSURANCE.

The prices quoted in this sale were determined in part on the basis that CCA’s liabilities and Client’s remedies are lim ited as provided in this Statem ent and the prices would have been substantially different had those limitations not been agreed.

Choice of Law:

Any controversy between the parties shall be governed by the laws of the State of Connecticut, to the exclusion of the law of any other forum, without regard to the jurisdiction in which any action or sp ecial proceeding shall be instituted.

Entire Agreement:

With respect to the subject matter herein, this document contains the entire agreement between the parties involved, and supersedes all other agreements between the parties except as noted in the Special Provi sions section of this document.

Special Provisions:

## ATTACHMENT B – 2012 REVISE D CCA SCR BUDGET PROPOSAL

### All4 UNIT # 8 & 9 LOW NOx SCR
BUDGET PROPOSAL

For

Nicholas Leone
All4 Inc
2393 Kimberton Road
P.O. Box 299 Kimberton, PA 19442-0299

EMAIL: nleone@ALL4INC.COM

Proposal No. 12-528

February 17, 2012

Prepared by:

Edmund SchindlerCombustion Components Associates, Inc. 884 Main Street Monroe, CT 06468 203

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TABLE OF CONTENTS

1.0 INTRODUCTION ...................................................................................................... 3 2.0 OBJECTIVES ............................................................................................................. 3
3.0 PROGRAM ACTION PLAN .................................................................................... 4 3.1 SCR System .............................................................................................................. 4 3.2 Optimization, StartUp, Testing and Interim Report .................................................. 6 3.3 Long Term Costs....................................................................................................... 7 3.4 Heat Recovery ........................................................................................................... 7 3.4 By Others .................................................................................................................. 8
4.0 COMMERCIAL TERMS .......................................................................................... 9 4.1 Program Budget ........................................................................................................ 9 4.2 Program Schedule ..................................................................................................... 9 4.3 Validity ..................................................................................................................... 9 4.4 Terms of Payment ................................................................................................... 10
4.5 C ommercial Terms .................................................................................................. 10

APPENDIX
Appendix A

– Experience Lists Appendix B Case Histories Appendix C CCA Broc hure Appendix D– CCA Fees & Scope of Service Sheets

Confidentiality and Proprietary Information

Notice to Recipient of Proposal:

In consideration of CCA preparation of this proposal and disclosure of certain proprietary information, its recipient a grees to treat as confidential all CCA proprietary information disclosed herein. Such proprietary information includes, but is not limited to, all technical requirements, specification(s), print(s), and information relating to the description and operation of the system, which is the subject of this proposal, its components, equipment, options and related services, designs, proce sses, techniques, documentation, pricing, installation, and safety. The recipient further acknowledges that CCA proprietary inform ation is unique and valuable, was developed or acquired by CCA at substantial expense, and is the subject of efforts by CCA to maintain the secrecy thereof. The recipient agrees not to reverse engineer, to use or to disclose this proprietary information to any person or party without the prior written consent of CCA. This agreement is effective between the recipient and CCA regardless of whether the parties enter into a contract for sale of the goods and/or services that are the subject matter of this propo sal. © Copyright 2012 , CCA. An unpublished work. All rights reserved. This document may be reproduced as required only for the internal use of its recipient in evaluation of this proposal.Combustion Components Associates, Inc. 884 Main Street Monroe, CT 06468 203

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## 1.0 INTRODUCTION

Changes from previous p roposal

1. Lessons learned on two wood fired boilers and the added equipment associated with the lessons. Primarily the reverse flow system to prevent the catalyst f ro m plugging.
2. Changes in the controls and injections system
3. The duct burner is now included in the boiler 9 propo sal.
4. Change to 50% urea to lower the cost of the reactant.
5. Added catalyst to Blr 9 for the duct burner NOx.

Boiler #8 at another location is a small natural gas/fuel oil -fired unit that does not have any add on PM controls. The heat input is 400 mmBtu/hr.

Stack temp 300F - 320F
Moisture 7% Flow rate 180,000 acfm
SO2 115 tpy
NOx 137 tpy
O2 5%
PM 7.6 lbs/MMCF when burning gas (AP-42)
PM 12.4 lbs/MMCF when burning fuel oil (AP -42) Flue gas temp prior to air heater 600F
CO and CO2 data are not available for this unit.

Boiler #9 adjacent to boiler #8 burns wood waste and natural gas. The unit is equipped with multiclones and paral lel wet scrubbers for PM control. The boiler is rated at 360 mmBtu/hr heat input.

Stack temp 140F to 150F
Moisture 20%
Flow rate 140,000 acfm
SO2 43 tpy
NOx 932 tpy
O2 7 to 8.5%
PM 0.119 lb/mmBtu after PM controls
CO 800 ppm
CO2 10 to 11% Flue gas temp prior to air heater 375F



## 2.0 OBJECTIVES

The program objectives are as follows:

1. Provide an SCR system for 90% NOx reduction for the worst fuel of each of the two
boilers. 2. Supply a urea supply and injection system to supply ammonia to the catalyst.Combustion Components Associates, Inc. 884 Main Street Monroe, CT 06468 203

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3. Identify ID Fan upgrade requirements



## 3.0 PROGRAM ACTION PLAN

The program action plan consists of three (3) or 5 parts:

1. Survey the units and locate space to install the catalyst bed and the urea tank.
2. Design the system and the ductwork.
3. Provide the system 4. Provide installation supervision 5. Provide startup, optimization and testing.

Inst allation is not included.



## 3.1 SCR System

CCA has provided SCR systems to mobile and stationary diesel engines ranging from a diesel engine in a pickup truck to a 2 .5 MW electric generation diesel system. We have supplied ov er 150 of these systems to date, and supplied two S CR ’ s to green wood fired boilers, at which many
lessons were learned. All of these typically reduce the NOx 80 to 90%. Because we have focused on small mobile sources our SCR systems can be supplied for much less then the large OEM

supp liers of SCR technology. I have attached two Case Histories in the Appendix for similar projects.

The system is designed for 100% flow of flue gas through the catalyst bed at a temperature of
600F. The SCR can maintain 90% reduction of NOx within a temperature range that is dependent on the catalyst used. Up stream of the catalyst the urea is injected into the duct and it converts to ammonia in the hot flue gas. The ammonia combines with the NOx at the catalyst surface and
reduces the NOx to N2. Each of the two boilers will require a slig htly different system. Boiler 9 will require a high dus t catalyst a duct heater and a reverse flow system , Boiler #8 can use a low dust catalyst used for oil and gas

. There are catalysts available that can operate down to 450F but they are more expensive and it may make sense to just bring the temperature up to 600F. For
boiler #9 that burn wood waste, the trace gas constituents must be defined and limited to insure that no catalyst poisons are present.

The Engineering Included is as follows:



### • Baseline Survey

• Baseline Test

• CFD Model of the flow path to insure good mixing

• P&ID’s and GA Drawings

• Bill of Materials

• Specification Sheets

• Installation and Instruction Manuals

• Training

• Structural Engineering with State Stamp.Combustion Components Associates, Inc. 884 Main Street Monroe, CT 06468 203

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• Ins tallation Supervision

• Startup and Tuning Including Ammonia Slip Testing

The Equipment Supply is as f ol lows :

Boilers 8 &9 SCR Component Unit #8 Unit #9
Tank

- 14 ,000 gallon polymer tank for inside storage of urea with urea pump and motor, inline filters a nd tank level sensor for 14 days supply

. One tank for Boiler #8 & 9

Catalyst Type, Installed before the air heater in 8 and after the
duct burner in #9 Oil and gas High dust wood and gas Catalyst Volume, M 3 with space for an extra layer 15’ x 17’ x 2’ 21’ x 22’ x 5 ’ Catalyst Shell

- CS fabrication 1 1 Transition Duct 200 feet of CS duct included per boiler 1 1 Reverse Flow Bypass Duct and four low leakage dampers to back flow catalyst ever y 12 hours. None 1

Support and Stair Tower 2 per SCR required 2 2 Expansion Joints 2 8 Additional ID fan requirements to be tested and proven or upgraded 180,000 acfm
at 4 in wc 140,000 acfm
at 6 in wc Gas Duct burner to raise flue gas to 600F None 1

- 85 mmBtu/hr Retractable Urea Flow Injectors with SS hoses 4 8 Compressor, receiver and filter 240 SCFM with backup 2 for both units
PLC based Control Units 1 1 Lot of instrumentation (flow sensor, temperature of gas) 1 1 Urea pumps for each unit with auto backup 2 2 CFD model to determine best injection point and mixing for
each unit. 1 1

Installation Supervision 6 weeks total 6 weeks total


### Note : 1. the Multiclone must be operating at its design condition to minimize the PM carryover to the
SCR.
2. The NOx of the duct burner is included in the estimate of NOx reduction. 

### Utilities Required for the System

Boilers 8,9
Electric *10 HP pump 10 KW
heaters
Air 240scfm
Water None
Boiler #8 #9
Gas Fuel 0 85000scfm
Urea Rate %50
Urea Full Load Rate, gph 5 32

Control Voltage 0

- 5 VDC
Notes: *excludes fan Anhydrous Ammonia would be half the usage rate.Combustion Components Associates, Inc. 884 Main Street Monroe, CT 06468 203

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The injection system automatically starts when the boiler is started. Injection begins when the exhaust temperature at the catalyst reaches 500 degrees F or above. The system controls takes
in b oiler and loa d and sets the injection rate based upon a map that is programmed into the
controls at start

- up. The bypass dampers will reverse the flow to pass through the catalyst in the opposite direction about every 12 hours on boiler # 9; boiler #8 does not require a bypass

. If the exhaust temperature on boiler #9 drops below 500 degrees F, such as during startup or shutdown, the injection will stop automatically and the bypass dampers will redirect the flow around the catalyst. When the boiler is turned off, the cir cu lation pump through the tank and
heaters continues to prevent crystall ization of the 50% urea.

The catalyst is guaranteed for 1 years or 8760 hours of operation or fro m installation date,
time , whichever comes first. The injection system is warranted for one year. The expected life is for 25,000 hours or 3 years, whichever comes first.

CCA takes no responsibility for undisclosed trace elements in the wood waste that are catalyst poisons that may degrade catalyst performance prematurely. Known catalyst poisons will shorten the life of the catalyst.

Ammonia Anhydrous Supply

Anhydrous ammonia can be used as an alternate. Ammonia is typically less costly then urea but harder to site near suburban or urban settings. Ammonia also requires a vaporizer to heat the ammonia to a gas for injection. The overall capital cost would be approximately similar.



## 3.2 Optimization , StartUp, Testing and Interim Report

Upon completion of the installation of the SCR system , CCA ’s engineer will advise All4 on opt imizatio n of operational changes which will improve overall unit performance and reduce
NOx emissions. The performance of the boiler will also be evaluated by operating the unit with bias firing. The performance testing will be conducted over the complete load ran ge of
the boiler. The SCR load range is limited by the catalyst inlet temperature

. The unit will be operated and tested at various conditions, including:

• E xcess oxygen

• Load

• Fuel

• Urea injection rate

• Ammonia slip

This performance and emission testin g is e xpected not to exceed a total of 15 days for both
boilers . All temporary emission monitoring equipment and personnel to operate it are to be provided by CCA . Upon completion of testing, an inte rim report will be issued containing the following informati on:

1. Conclusions of the program and recommendations for future corrective actions, if any. 2. Comprehensive report of the NOx reduction over the load range.
3. Test Data Summary of the results of the optimization testing.Combustion Components Associates, Inc. 884 Main Street Monroe, CT 06468 203

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If additional time is required through no fault of CCA, this will be charged at per diem rates.



## 3.3 Long Term Costs

Long term costs are an important part of the overall cost of the project. I have attempted to provide in this section the cost or a way to estimate the cost for both of these projects.
These costs include:

• Catalyst replacement
– After 1 years one layer per year is replaced $2 50,000/yr blr
9 and $150,000 Blr 8

.

• Gas fuel for duct reheater to bring Blr #9 to 600F

• Urea cost $1.75 gal

• Annual operating cost

o Annual stack testing/tuning $40,000 yr and/or CEM maintenance cost

o Truck Unloading 2 hours/wk.

o Operating Manpower-2 hours/day

o Training and safety - 40 hours yr.

o Water

o Elect r ic TBD

o D epreciation TBD

o Project Management 5% for the first year.



## 3.4 Heat Recovery

The duct heater to bring the flue gas temperature up to 600F normal operating temperature is a substantial operating cost. There are a number of systems for heat recovery but all would likely have substantial cost. 70% recovery is un likely since the boiler is probab ly that efficient.

1. Air heater to reheat air to the boiler: besides the cost of the system the duct cost back to the boiler FD fan system would be substantial.
2. Organic Rankine Cycle recovery: this converts the waste heat to electricity and
would be the mo st flexible but probably the most expensive.
3. Economizer: I recently quoted an economizer for a boiler with 100mmBtu heat input and it was $450,000 installed. This is likely to r educe the heat into the boiler 5.5% at full load and 3.0% at half load, or the hot water could be used somewhere else. This would require an added boiler performance study to reduce the potential for boiling in the economizer if the boiler has an economizer already.
4. Heat recovery steam generator: this would be expensive and the temperatures would normally be closer to 1400F to make sense.

All the above would add pressure drop 3-5 inwc to the ID fan and almost assure a new fan is required besides the extra power required.Combustion Components Associates, Inc. 884 Main Street Monroe, CT 06468 203

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## 3.4 By Others

The following is a partial list of items not included.

1. Installation of equipment
2. Waste and hazardous waste identification and removal
3. Site Safety Training as required
4. Site Drawings
5. Recent ultimate and proximate fuel analysis
6. Access to the unit for site survey
7. Test loads for the optimization in a t imely manner
8. Freight to the job siteCombustion Components Associates, Inc. 884 Main Street Monroe, CT 06468 203

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## 4.0 COMMERCIAL TERMS

4.1 Program Budget

CCA will supply the NOx Re duction System outlined in this proposal in Secti on 3 for the Budget
P rice of $5,8 00,000.00 for unit # 9 and for unit #8 a budget price of $2,3 50,000.00 in accordance with our Commercial Terms and Conditions and Fees and Scope of Service schedules located in the Appendix. CCA is not responsible for incidental, consequential or special damages.

Installation is not included in the above price but is likely to be equal to the supply price.

I have included the duct burner in the above price. No provision has been included to upgrade the ID fans if that is required.

The common systems such as the urea storage system and compressed air are included in the Boiler 9 price

. Urea storage is designed for indoor location. If outdoor is required then heating
and insulation must be added.

All prices are quoted exclusive of state and local sales, excise, use or any other taxes. Such taxes, if applicable, wil l be in addition to the above prices and will be charged to your account. Any
taxes assessed to CCA at a later date will be charged to your account. If the above items are tax exempt, the applicable tax exemption certificate is to be sent to CCA with your purchase order



### .

The price is FOB the factory in Connecticut, with freight prepaid and included.



## 4.2 Program Schedule

CCA can complete the work outlined in Section 3 in approximately 20-26 weeks after the authorization to proceed and all required details.

The actual schedule will vary depending upon manpower loading at the time the authorization to proceed is received.



## 4. 3 Validity

This proposal is budgetaryCombustion Components Associates, Inc. 884 Main Street Monroe, CT 06468 203

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## 4.4 Terms of Payment

Twenty percent (20%) of the contract price shall accompany your written purchase order. The remaining eighty percent (80%) shall be paid in progress payments upon completion of each phase or portion of phase as follows:

With PO

------------------------------------------- 20% Engineering Complete

-------------------------- 20% Purchase of Long Lead Items

------------------ 20% Equipment ready for ship ment

---------------- 30% Completion of Startup

-------------------------- 10%

Note: Final payment is due 60 days after successful demonstration of contrac t performance or (when performance testing is delayed) 180 days from final shipment of equipment, whichever
comes first

.



## 4.5 Commercial Terms

CCA terms and conditions will be used for this project. They can be found in the appendix.Combustion Components Associates, Inc. 884 Main Street Monroe, CT 06468 203

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# Appendix A

– Exper ience Lists Appendix B Case Histories Appendix C CCA Brochure Appendix D

– CCA Fees & Scope of Service Sheets

### No. Client/Station **MW No. of Fuel Type of Firing**

**Burners**
1 CIPCO - Fair Station #2 42 6 Coal Front 1 Intermountain Power Service #1 850 48 Coal Opposed 1 Intermountain Power Service #2 850 48 Coal Opposed 1 Champion International - #1 12 4 Coal/Oil Front 1 Champion International - #2 12 4 Coal/Oil Front 1 Madison Gas & Electric Co. - Blount #8 50 6 Coal/Gas Front 1 Madison Gas & Electric Co. - Blount #9 50 6 Coal/Gas Front 1 Rochester Public Service - Silver Lake #4 65 6 Coal/Gas Front 1 Mid American Energy - Neal #2* 300 16 Coal Front 1 Tucson Electric Power - Irvington #4 120 9 Coal Front 1 First Energy - Bayshore #3 * 150 12 PRB Coal Front 1 First Energy - Bayshore #4 * 230 18 Coal Front
1 Mirant - Chalk Point #1* 355 24 Coal/Gas Opposed
1 Mirant - Chalk Point #2* 355 24 Coal/Gas Opposed 1 PECO - Cromby #1* 160 16 Coal Front 1 Michigan South Central - Endicott #1 62 8 Coal Front 1 Northeast Utilities - PSNH Schiller #4 50 6 Coal/Oil Front 1 Northeast Utilities - PSNH Schiller #5 50 6 Coal/Oil Front 1 Northeast Utilities - PSNH Schiller #6 50 6 Coal/Oil Front 1 First Energy - Sammis #1 190 15 Coal Front 1 First Energy - Sammis #2 190 15 Coal Front 1 First Energy - Sammis #4 190 15 Coal Front
1 Ontario Power - Lakeview #5 300 18 Coal Front
1 Ontario Power - Lakeview #6 300 18 Coal Front
1 Ontario Power - Lakeview #1 300 24 Coal Front
1 Ontario Power - Lakeview #2 300 24 Coal Front 1 Orion Energy - New Castle #4 * 100 12 Coal Front 1 Orion Energy - New Castle #3 * 100 12 Coal Front 1 Orion Energy - New Castle #5 * 100 12 Coal Front
1 Detroit Edison - St. Clair #1* 163 12 Coal/Oil Front
1 Detroit Edison - St. Clair #2* 163 12 Coal/Oil Front
1 Detroit Edison - St. Clair #3* 163 12 Coal/Oil Front
1 Detroit Edison - St. Clair #4* 163 12 Coal/Oil Front
1 Otter Tail Power - Hoot Lake #3 100 8 Coal Front 1 Packaging Corp of America - Filer City #2 15 4 Coal Front 1 City of Hamilton - Ohio #9 55 12 Coal/Gas Tangential 1 Mirant Potomac River 3,4,5 100 16 Coal Tangential 1 Mirant Potomac River 1,2 80 16 Coal Tangential 1 Bayer Institute Plant 250 KPPH 4 Coal Front
* Has Overfire Air 

# Experience - Coal Fired Units

**CCA - Combustion Components Associates, Inc.**

**www.cca-inc.net • info@cca-inc.net • Tel: 203-268-3139 • Fax: 203-261-7697**

### No. Client/Station **MW No. of Fuel Description**

**Burners** 1 Bayer CropScience - #10 250 KPPH 4 Coal/Gas Front 1 Bayer CropScience - #11 250 KPPH 4 Coal/Gas Front 1 Bayer CropScience - #12 250 KPPH 4 Coal/Gas Front
1 Customer Confidential 780 70 Coal Opposed 1 Detroit Edison - St. Clair #1 163 12 Coal/Oil Front 1 Detroit Edison - St. Clair #2 163 12 Coal/Oil Front 1 Detroit Edison - St. Clair #3 163 12 Coal/Oil Front 1 Detroit Edison - St. Clair #4 163 12 Coal/Oil Front 1 Exelon - Cromby #1 160 16 Coal Front 1 First Energy - Bayshore #3 150 12 PRB Coal Front 1 First Energy - Bayshore #4 230 18 PRB Coal Front 1 First Energy - Sammis #1 190 15 Coal Front 1 First Energy - Sammis #4 180 15 Coal Front 1 Orion Energy - New Castle #3 100 12 Coal Front 1 Orion Energy - New Castle #4 100 12 Coal Front 1 Orion Energy - New Castle #5 100 16 Coal Front 1 Upgrade OFA & Burner Mods Work in Progress 860 32 Oil Tangential 1 Pulp and Paper Mill 390k pph 12 Wood/CoalStoker/T-Fired 1 Schenectady International 100k pph 0 Wood/Coal Stoker 1 Suez Energy Pinetree Power
Bethlehem 16 0 Wood Stoker 1 Suez Energy Pinetree Power
Bethlehem 18 0 Wood Stoker 

# Experience - Overfired Air Units

**CCA - Combustion Components Associates, Inc.**

**www.cca-inc.net • info@cca-inc.net • Tel: 203-268-3139 • Fax: 203-261-7697**

### No. Client/Station **MW No. of Fuel Description**

**Burners** 1 Conectiv, B.L. England Unit #1 130 3 Coal Cyclone 1 Conectiv, B.L. England Unit #1
SNCR & RRI Demo 130 3 Coal Cyclone 1 Conectiv, B.L. England Unit #2 160 4 Coal Cyclone 1 Conectiv, B.L. England Unit #3 160 12 Oil Tangential 1 Exelon, Cromby Unit #1 160 16 Coal Front 1 Northeast Utilities, Schiller Unit #4 50 6 Coal/Oil Front 1 Northeast Utilities, Schiller Unit #5 50 6 Coal/Oil Front 1 Northeast Utilities, Schiller Unit #6 50 6 Coal/Oil Front 1 Suez Energy Pinetree Power
Bethelem 16 0 Wood Stoker 1 Suez Energy Pinetree Power
Tsamworth 18 0 Wood Stoker 1 Schenectady International 12 0 Wood Stoker 1 Utility 4 boilers 600 16 Coal Tangential



# Experience - Tangential Fired Units

**No. Client/Station MW No. of Fuel Description** 

**Burners** 1 City of Austin - Decker 1 320 16 Gas Burner Modifications Low NOx 1 City of Austin - Holly 4 185 16 Gas Burner Modifications Low NOx 1 City of Hamilton 55 12 Coal Burner Modifications 1 Conectiv [Atlantic Electric] 160 12 Oil Burner Modifications Low NOx - B.L. England 3 & SNCR 1 MIRANT Potomac River 1 90 16 Coal Burner Modifications Low NOx
1 MIRANT Potomac River 2 90 16 Coal Burner Modifications Low NOx
1 MIRANT Potomac River 3 105 16 Coal Burner Modifications Low NOx
1 MIRANT Potomac River 4 105 16 Coal Burner Modifications Low NOx
1 MIRANT Potomac River 5 105 16 Coal Burner Modifications Low NOx
1 MIRANT Potomac River 5 105 16 Coal Burner Modifications Low NOx 

# Experience - SNCR Units

**CCA - Combustion Components Associates, Inc.**

**www.cca-inc.net • info@cca-inc.net • Tel: 203-268-3139 • Fax: 203-261-7697**

# Experience - Tangential Fired Units - Gas, Oil, Gas-Oil Fired

**No. Client/Station MW No. of Fuel Description** 

**Burners** 1 City of Austin - Decker 1 320 16 Gas Burner Modifications Low NOx 1 City of Austin - Holly 4 185 16 Gas Burner Modifications Low NOx 2 Duke - South Bay 4 220 12 Gas Burner Modifications & Combustion Tempering 1 Entergy - Sabine 5 480 16 Gas Burner Modifications & OFA 1 Exelon Eddystone #3 600 32 Gas/Oil Burner Modifications Low NOx 1 Exelon Eddystone #4 600 32 Gas/Oil Burner Modifications Low NOx 1 Mirant [PEPCO] 640 32 Gas/Oil Burner Modifications Low NOx
- Chalk Point 3 1 Mirant [PEPCO] 640 32 Gas/Oil Burner Modifications Low NOx
- Chalk Point 4 1 Conectiv [Atlantic Electric] 160 12 Oil Burner Modifications Low NOx - B.L. England 3 & SNCR 1 Customer Confidential 860 32 Oil Burner Modifications Low NOx & OFA Upgrade 1 Exelon Mystic #4 135 24 Oil Burner Modifications Low NOx 1 Exelon Mystic #5 135 24 Oil Burner Modifications Low NOx 1 Exelon Mystic #6 135 24 Oil Burner Modifications Low NOx 1 EXELON MYSTIC #7 600 16 Oil Burner Modifications Low NOx
& SCOFA 1 FPL-WYMAN #3 125 12 Oil Burner Modifications Low NOx
& OFA 1 Northeast Utilities 84 16 Oil Atomizer Upgrade
- Montville 5 1 Northeast Utilities 165 24 Oil Burner Modifications Low NOx
- Norwalk Harbor 1 & SNCR 1 Northeast Utilities 175 24 Oil Burner Modifications Low NOx
- Norwalk Harbor 2 & SNCR 1 PP&L - Martins Creek 3 850 32 Oil Burner Modifications Low NOx 1 PP&L - Martins Creek 4 850 32 Oil Burner Modifications Low NOx 1 CSW/Swepco - Knox Lee 340 20 Oil/Gas NOx Tempering 3 Dynegy - Roseton 1 600 20 Oil/Gas Low NOx Atomizer 1 Dynegy - Roseton 2 600 20 Oil/Gas Low NOx Atomizer 1 Northeast Utilities 400 20 Oil/Gas Burner Modifications & - Newington 1 Combustion Tempering



# CCA - Combustion Components Associates, Inc.

**www.cca-inc.net • info@cca-inc.net • Tel: 203-268-3139 • Fax: 203-261-7697**

### No. CLIENT/STATION MW No. of Fuel Boiler Type of Baseline Final **Burners Mfg. Firing NOX NOX lb/mm lb/mm** 

**Btu Btu** 1 AEP (CSW/West Texas Utilities)- Paint Creek Unit 4 120 8 Gas Riley Front 0.55 0.24 (3) 1 AEP (CSW/West Texas Utilities)- Rio Pecos Unit 6 102 9 Gas/Oil Riley Front 0.7 0.315 1 AEP (SWEPCO) -
Wilkes Unit 2 348 18 Gas B&W Opposed 0.7 0.228 1 AEP (SWEPCO) -
Wilkes Unit 3 348 18 Gas B&W Opposed 0.37 0.228
1 AES Redondo Beach
Unit 5 170 12 Gas B&W Front 0.2 0.1 1 Austin Energy -
Decker Unit 1 320 16 Gas CE Tangential 0.23 0.14 1 Austin Energy -
Decker Unit 2 420 18 Gas B&W Front 0.11 0.055 (3) 1 Austin Energy - Holly Unit 3 195 12 Gas/Oil B&W Opposed 0.24 0.125 1 Austin Energy - Holly Unit 4 185 16 Gas CE Tangential N/A 0.147
1 Brazos Electric Power - R.W. Miller Unit 3 220 9 Gas/Oil Riley Front 0.35 (1) 0.23 (1) 1 City of Bryan - Dansby Plant 110 6 Gas B&W Front 0.18 0.08 1 City of Dover (DE) - McKee Run Unit 1 18 4 Gas/Oil B&W Front 0.57 (2) 0.37 (2) 1 City of Dover (DE) - McKee Run Unit 2 18 4 Gas/Oil B&W Front 0.57 (2) 0.37 (2) 1 City of Dover (DE) - McKee Run Unit 3 95 9 Gas/Oil Riley Front 0.42 (2) 0.27 (2) Conectiv Edge Moor #5 440 28 Oil B&W Opposed 0.35 0.2 1 Conectiv (Atlantic Electric) - B.L. England Unit 3 160 12 Oil CE Tangential 0.43 0.28 1 ConEd-60 1.4M KPPH 12 Oil FW Opposed 0.31/ 0.22/

0.33 0.17 1 ConEd-70 w/wo FGR 180 18 Oil/Gas FW Rear 0.31/ wo/0.2/

0.33 0.17 w/na/0.11 1 Customer Confidntial 860 32 Oil CE Tangential 0.21 0.174 

# Experience - Gas, Oil or Gas/Oil Installations

**CCA - Combustion Components Associates, Inc.**

**www.cca-inc.net • info@cca-inc.net • Tel: 203-268-3139 • Fax: 203-261-7697**

### No. CLIENT/STATION MW No. of Fuel Boiler Type of Baseline Final **Burners Mfg. Firing NOX NOX lb/mm lb/mm** 

**Btu Btu** 1 Duke - South Bay Unit 4 220 12 Gas CE Tangential 0.18 0.11 1 Dynegy - Roseton Unit 1 600 20 Oil CE Tangential 0.25 0.2 (3) 1 Dynegy - Roseton Unit 2 600 20 Oil CE Tangential 0.25 0.2 (3) 1 Eastern Fine Paper -
Boiler 1 12 4 Oil B&W Front N/A 0.22 1 Eastern Fine Paper -
Boiler 2 12 4 Oil B&W Front N/A 0.23
1 El Paso Electric - Newman Unit 2 80 12 Gas/Oil B&W Front 0.52 0.22
1 El Paso Electric - Newman Unit 3 105 9 Gas/Oil B&W Front 0.72 (1) 0.32 (1)
1 El Paso Electric - Rio Grande Unit 7 50 8 Gas/Oil B&W Front 0.52 0.26
1 El Paso Electric - Rio Grande Unit 8 163 12 Gas B&W Front 0.3 0.25
1 El Paso Electric - Newman Unit 1 80 12 Gas/Oil B&W Front 0.54 0.267 1 Entergy -
Lousiana Unit 10 42 6 Gas C&E Front 0.17 0.10 1 Entergy -
Lousiana Unit 11 42 6 Gas C&E Front 0.13 0.085 1 Entergy -
Lousiana Unit 12 62 12 Gas C&E Front 0.14 0.10 1 Entergy -
Monroe Unit 12 74 6 Gas C&E Front 0.53 0.091 1 Entergy - Sabine Unit 5 480 16 Gas CE Tangential 0.15 0.094 (3) 1 Entergy - Willow Glen Unit 3 485 24 Gas FW Opposed 0.20 0.20 (4) 1 Exelon (PECO) - Fairless Hills Unit 1 40 6 Gas/Oil Riley Front 0.15 (1) 0.10 (1) 1 Exelon (PECO) - Fairless Hills Unit 2 40 6 Gas/Oil Riley Front 0.15 (1) 0.10 (1) 1 Exelon (PECO) - Fairless Hills Unit 3 40 6 Gas/Oil Riley Front 0.15 (1) 0.10 (1) 1 Exelon (PECO) - Fairless Hills Unit 4 40 6 Gas/Oil Riley Front 0.15 0.10 1 Exelon (PECO) - Fairless Hills Unit 5 40 6 Gas/Oil Riley Front 0.15 0.10 1 Exelon (TXU) - Mountain Creek Unit 6 115 15 Gas/Oil Riley Front 0.56 (1) 0.23 (1) 

# Experience - Gas, Oil or Gas/Oil Installations

**CCA - Combustion Components Associates, Inc.**

**www.cca-inc.net • info@cca-inc.net • Tel: 203-268-3139 • Fax: 203-261-7697**

### No. CLIENT/STATION MW No. of Fuel Boiler Type of Baseline Final **Burners Mfg. Firing NOX NOX lb/mm lb/mm** 

**Btu Btu** 1 Exelon (TXU) - Mountain Creek Unit 7 125 12 Gas/Oil B&W Front 0.73 (1) 0.48 1 Exelon-Mystic #7 600 16 Oil CE Tangential 0.29 .2

2 FPLPort Everglades #3 & 4 400 18 Oil FW Rear 0.65 .45 1 FPL- Wyman #1 55 6 Oil FW Front 0.41 0.27 1 FPL- Wyman #2 55 6 Oil FW Front 0.41 0.27
1 FPL-Manatee #1 800 32 Oil FW Front 0.38 .32
1 FPL-Manatee #2 800 32 Oil FW Front 1 FPL-Wyman #3 125 12 Oil CE Tangential 0.26 .145 1 FPL-Wyman #4 630 30 Oil FW Front 0.24 .167 1 Huntsman Corporation - Port Neches Boiler 5 12 6 Gas Vogt Front 0.12 0.05 1 Huntsman Corporation - Port Neches Boiler 6 12 6 Gas Vogt Front 0.12 0.06 1 Huntsman Corporation - Port Neches Boiler 7 20 4 Gas Vogt Front 0.14 0.08 1 Huntsman Corporation - Port Neches Boiler 7@C4 65 12 Gas Vogt Front 0.20 0.02 1 Huntsman Corporation - Port Neches Boiler 8 20 4 Gas Vogt Front 0.14 0.08 1 International Paper -
Boiler 1 43 6 Oil B&W Front 0.43 0.25 1 International Paper -
Boiler 2 43 6 Oil B&W Front 0.43 0.25 1 JEA - Northside Unit 3 500 24 Gas/oil Riley Front 0.5 0.375 (3) 1 Kimberly Clark (Scott Paper Co) -
Boiler 2 18 4 Oil Riley Front 0.54 0.23 1 Kimberly Clark (Scott Paper Co) -
Boiler 3 18 4 Oil Riley Front 0.29 0.22 1 Massport 10 3 Oil Keeler Front 0.35 0.20 1 Mirant (Potomac Electric) - Chalk Point Unit 3 640 32 Gas/Oil CE Tangential 0.48 (2) 0.24 (2) 1 Mirant (Potomac Electric) - Chalk Point Unit 4 640 32 Gas/Oil CE Tangential 0.48 (2) 0.24 (2) 1 NRG (NU) - Middletown Unit 2 122 12 Oil Riley Front 0.38 0.29 

# Experience - Gas, Oil or Gas/Oil Installations

**CCA - Combustion Components Associates, Inc.**

**www.cca-inc.net • info@cca-inc.net • Tel: 203-268-3139 • Fax: 203-261-7697**

### No. CLIENT/STATION MW No. of Fuel Boiler Type of Baseline Final **Burners Mfg. Firing NOX NOX lb/mm lb/mm** 

**Btu Btu** 1 NRG (NU) - Norwalk Harbor Unit 1 165 24 Oil CE Tangential 0.4 0.25 1 NRG (NU) - Norwalk Harbor Unit 2 175 24 Oil CE Tangential 0.4 0.25
1 NRG Cabrillo -
Encina Unit 1 110 10 Gas/Oil B&W Front 0.13 0.075
1 NRG Cabrillo -
Encina Unit 2 110 10 Gas/Oil B&W Front 0.13 0.085
1 NRG Cabrillo -
Encina Unit 3 115 10 Gas/Oil B&W Front 0.13 0.08 1 Packaging Corporation of America (Tenneco Packaging) - Filer City Boiler 2 15 4 Gas/Coal B&W Front 0.20 (1) 0.15 (1)
1 PG&E -
Hunters Point Unit 4 170 15 Gas C&E Front 0.11 0.03 1 PP&L Martins Creek #3 850 32 oil CE Tangential 0.4 0.27 1 PP&L Martins Creek #4 850 32 oil CE Tangential 0.36 0.29
1 Reliant - WA Parish Unit 2 180 20 Gas CE Front 0.35 0.20 (3)
1 Rhode Island Prison Authority - Unit 7 10 4 Oil Riley Front 0.29 0.091 1 Texas Utilities (TXU) - Eagle Mountain Unit 2 175 24 Gas/Oil Riley Front 0.43 (1) 0.19 (1) 1 Texas Utilities (TXU) - Eagle Mountain Unit 3 400 16 Gas FW Opposed 0.31 0.15 1 Texas Utilities (TXU) - Lake Hubbard Unit 2 540 32 Gas/Oil B&W Opposed 0.36 (1) 0.18 (1) 1 Texas Utilities (TXU) - Parkdale Unit 2 115 15 Gas/Oil B&W Front 0.81 (1) 0.29 (1) 1 Texas Utilities (TXU) - Parkdale Unit 3 134 12 Gas/Oil B&W Front 0.76 (1) 0.42 (1) 1 Texas Utilities (TXU) - Stryker Creek Unit 1 175 18 Gas/Oil B&W Front 0.72 0.45 (3) 1 Texas Utilities (TXU) - Valley Unit 1 175 9 Gas/Oil B&W Front 0.46 0.20
1 U.S Gen Salem
Harbor #4 450 24 Oil Riley Rear 0.55 0.28
1 US Pharmaceuticals -
Boiler 1 12 4 Oil CE Front 0.38 0.23 

# Experience - Gas, Oil or Gas/Oil Installations

**CCA - Combustion Components Associates, Inc.**

**www.cca-inc.net • info@cca-inc.net • Tel: 203-268-3139 • Fax: 203-261-7697**

### No. CLIENT/STATION MW No. of Fuel Boiler Type of Baseline Final **Burners Mfg. Firing NOX NOX lb/mm lb/mm** 

**Btu Btu** 1 US Pharmaceuticals -
Boiler 2 12 4 Oil CE Front 0.38 0.23
1 US Pharmaceuticals -
Boiler 3 12 4 Oil CE Front 0.38 0.23

1 Western Farmers Electric Coop - Mooreland Unit 2 138 9 Gas Riley Front 0.45 0.30

1 Western Farmers Electric Coop - Mooreland Unit 3 153 9 Gas Riley Front 0.6 0.30

**88 Totals 18,725 1173** 

** Does not include coal-fired expertise



# Overfire Air - Gas, Oil, Oil-Gas

**No. CLIENT/STATION MW No. of Fuel Boiler Type of Baseline Final Burners Mfg. Firing NOX NOX**  **lb/mm lb/mm**

**Btu Btu** 1 Entergy-Sabine #5 480 20 Gas CE Tangential 0.15 0.094 (4) (5)
1 PG&E Hunters Point #4 BOOS w/FGR 175 15 GAS CE Front 0.11 0.03 (4) 1 Conectiv Edge Moor 5 440 28 Oil B&W Opposed 0.35 0.2 (5) (4) 1 FPL-Wyman 3 125 12 Oil CE Tangential 0.29 0.16 1 FPL-Wyman 4 630 30 Oil FW Rear 0.3 0.21 1 Customer Confidential 860 32 Oil CE Tangential 0.21 0.174 (5) 1 Con Ed-Unit 60 1.4M KPPH 12 Oil/Gas FW Opposed 0.31/ 0.22/ 0.33 0.17 (2) (4)
1 Con Ed-Unit 70 w/wo FGR 180 18 Oil/Gas FW Rear .31/.33 wo/ 0.20/0.17 w/na/0.11 1 Exelon-Mystic #7 BOOS 600 16 Oil/Gas CE Opposed 0.29 0.2 (3) 

# Experience - Gas, Oil or Gas/Oil Installations

**CCA - Combustion Components Associates, Inc.**

**www.cca-inc.net • info@cca-inc.net • Tel: 203-268-3139 • Fax: 203-261-7697**

### No. CLIENT/STATION MW No. of Fuel **Boiler Type of** 

**Burners Mfg.**  **Firing** 1 NRG - Northeast Utilities - Middletown - # 3 245 5 Gas/Oil Babcock & Wilcox Cyclone
1 Northeast Utilities - Newington Station #1 406 16 Gas/Oil Combustion Engineering Tangential
1 Western Farmers Elec. -
Mooreland #3 153 9 Gas Riley Front 1 CSW/Swepco - Knox Lee #5 350 16 Gas Combustion Engineering Tangential 1 PG&E - Hunters Point #4 170 15 Gas Combustion Engineering Front 1 Entergy - Monroe #12 74 6 Gas Combustion Engineering Front 1 CSW - Sweeny #8 & 9 65 16 Gas Babcock & Wilcox Front 1 Lowe Paper 7 2 Gas Bieglo Front 1 Duke Power - South Bay #4 220 12 Gas Combustion Engineering Tangential
3 NRG - Cabrillo - Encina #1, 2 & 3 110 30 Gas Babcock & Wilcox Front 1 Austin Energy - Holly #3 165 12 Gas/Oil Babcock & Wilcox Opposed 2 Entergy - Louisianna #10 & 11 40 6 Gas Combustion Engineering Front 1 Entergy - Louisianna #12 60 12 Gas Combustion Engineering Front 1 Conectiv - B.L. England #2 160 4 Coal Babcock & Wilcox Cyclone 1 Austin Energy - Decker #1 321 16 Gas/Oil Combustion Engineering Tangential 1 Austin Energy - Holly #4 180 12 Gas Combustion Engineering Tangential 1 Austin Energy - Decker #2 410 18 Gas/Oil Babcock & Wilcox Opposed
1 El Paso Electric -
Rio Grande #8 163 12 Gas Babcock & Wilcox Front 1 Exelon-Mystic #7 600 16 OIL Combustion Engineering Tangential
4 Lucent Bell Labs - 1 Gas B&W ‘D’ Package 

# NOx Tempering Installation List **(T-Fired, Front, Opposed, Cyclone Boilers)**

**CCA - Combustion Components Associates, Inc.**

**www.cca-inc.net • info@cca-inc.net • Tel: 203-268-3139 • Fax: 203-261-7697**

### Company **Plant Combustion Upgrade &**  **Nox Reduction Scope** International Paper Jay Maine – Boilers 1 & 2 425k pph Oil Fired
Burner Modifications International Paper Riegelwood North Carolina – 300k pph Bark & Oil Fired
Boiler 2 Burner Modifications International Paper Riegelwood North Carolina– Site Survey for Combustion
Boiler 1 Upgrade International Paper Bucksport Maine Atomizer Upgrade International Paper Pensacola Florida – CFD Modeling for NOx Reduction
Thermal Oxidizer Burner Modifications International Paper Pensacola Florida – Boiler 4 420k pph Steam Bark & Coal fired boiler
Coal burner modifications International Paper Mansfield Louisiana - 500k pph Steam Bark & Power Boiler #1&2 Coal fired boiler
Coal burner modifications International Paper Georgetown South Carolina – 450k pph steam Bark & Power Boilers 1 & 2 Coal fired boilers
Coal Burner Modifications International Paper Prattville Alabama – 450k pph steam Bark, Power Boiler 2 Coal & Oil Boiler OFA System International Paper Augusta Georgia 1-400kpph Bark, Coal Gas and Oil Boiler
Coal and Gas Burner Modifications Schenectady Intl. New York PH wood Boiler for Electric Gen. OFA, FGR & SNCR for NOx Reduction Suez New Hampshire 160 and 250 KPPH Wood Boiler for Electric Gen. - OFA, FGR, SNCR & SCR for NOx Reduction Champion Paper Deferiet, NY Low NOx Coal Warsau Paper New York Low NOx Oil Garden State Paper New Jersey Low NOx Oil

PCA Filer City, MI Low NOx Gas & Coal Huhtamachi Paper Watertown, ME Low NOx Oil Lincoln Paper Lincoln, ME Low NOx Oil Eastern Fine Paper Lincoln, ME Low NOx Oil Finch Pruyn Glens Falls, NY Low NOx Oil
Simkins Conn. and New Jersey Low NOx Oil 

# Experience - Pulp & Paper Units

**CCA - Combustion Components Associates, Inc.**

**www.cca-inc.net • info@cca-inc.net • Tel: 203-268-3139 • Fax: 203-261-7697**Confidential Proposal

CCA firm Proposal 10

‐ 282r1 17 May 14, 2010 CASE HISTORY 

## CLIENT Pinetree Power Tamworth New Hampshire

PLANT NAME Pinetree Power Tamworth Station (GDF Suez NA)



### APPLICATION Biomass fired stoker boiler burning clean wood chips requiring low NOx

emissions for renewable fuel credits.



### PROJECT SCOPE Engineer, supply, install and commission OFA modifications, installation of a FGR
system, SNCR and SCR systems to the existing Zurn boiler.

Manufacturer Zurn Type Wood Fired Stoker Boiler Capacity 220,0001blhr

Steam Conditions 700 PSIG @ 900F SH
Fuels Clean Wood Chips

Burners 5 Zurn Feeders Firing Arrangement Traveling Grate Stoker

Combustion Air Temperature 450 F

Furnace Plan 18 feet x 22 feet

Overfire Air 6 Ports on the side walls

FOR 5 Ports Undergrate

SNCR 6 Tilting Injectors

SCR 2 Layers 

### BOILER DATA

Baseline NOx 0.212 Ib/MMbtu



### CONTACT PERSON Russ Dowd Plant Manager Tel: 1

‐ 603

‐ 323

‐ 8187



### DESCRIPTION The plant desired to reduce NOx emissions to less than 0.065 lb/MMBtu to apply
for renewable energy credits through the sale of power to the States of

Connecticut and Massachusetts.

This project was executed on a very tight schedule with 5 months from order to

outage. The scope of work was to modify the existing OFA system to reduce the undergra te air to provide im proved combustion for a reduction in LOI and CO

emissions. The FGR system was installed to maintain the bed fluidity with the
reduction of the undergrate air and provide NOx reduction.

The SNCR system was installed to provide significant NO x reduction to reduce

the size of th e SCR catalyst volume. The SCR was installed after the ESP and the
flue gases of the boiler were relatively low at 375 F. A by

‐ pass was installed
around the air heater to reheat the flue gas at the SCR to 420 F. The SCR was installed to ach i eve the remainder of the NOx reduction to the 0.065 lb/MMBtu goal. The outage duration was 8 days.



### PERFORMANCE

The NOx was reduced to 0.05 lb/MMBtu. The LOI was reduced by 60% from 28%

to 11%. The CO emissions were unchanged at 200 ppm. NOx emissions
decreased 76% from 0.212lb/MMBtu to 0.05 lb/MMBtu. The control of ash fouling of the SCR catalyst was effectively achieved with the installation of a forward

‐ reverse duct arrangement. A new booster ID fan was installed to help

overcome limited existi ng ID fan capacity.Confidential Proposal

CCA firm Proposal 10

‐ 282r1 18 May 14, 2010 

## CASE HISTORY

CLIENT Pinetree Power Bethlehem New Hampshire

PLANT NAME Pinetree Power Bethlehem Station (GDF Suez NA)



### APPLICATION Biomass fired stoker boiler burning clean wood chips requiring low NOx

emissions for renewable fuel credits.



### PROJECT SCOPE Engineer, supply, install and commission OFA modifications, installation of a
FGR system, SNCR and SCR systems to the existing Zurn boiler.

Manufacturer Zurn Type Wood Fired Stoker Boiler Capacity 165,0001blhr

Steam Conditions 635 PSIG @ 825F SH
Fuels Clean Wood Chips

Burners 4 Zurn Feeders Firing Arrangement Traveling Grate Stoker

Combustion Air Temperature 450 F

Furnace Plan 18 feet x 20 feet

Overfire Air 6 Ports on the side walls

FOR 4 Ports Undergrate

SNCR 6 Tilting Injectors

SCR 2 Layers 

### BOILER DATA

Baseline NOx 0.212 Ib/MMbtu



### CONTACT PERSON Mark Driscoll Plant Manager Tel: 1

‐ 603

‐ 444

‐ 9993



### DESCRIPTION The plant desired to reduce NOx emissions to less than 0.065 lb/MMBtu to apply for renewable energy credits through the sale of power to the States of

Connecticut and Massachusetts.

This project was executed on a very tight schedule with 5 months from order

to outage. The scope of work was to modify the existing OFA system to
reduce the undergrate air to provide imp r oved combustion for a reduction in

LOI and CO emissions. The FGR system was installed to maintain the bed fluidity with the reduction of the undergrate air and provide NOx reduction.

The SNCR system was installed to provide significant NO x reduction to reduce

the size of th e SCR catalyst volume. The SCR was installed after the ESP and
the flue gases of the boiler were relatively low at 375 F. A by

‐ pass was installed around the air heater to reheat the flue gas at the SCR to 420 F. The

SCR was installed to achieve th e re mainder of the NOx reduction to the 0.065 lb/MMBtu goal. The outage duration was 8 days.



### PERFORMANCE

The NOx was reduced to 0.05 lb/MMBtu. The L01 was reduced by 25% from

20% to 15%. The CO emissions decreased from 360 to 232 ppm. NOx

emissions decreased 76% from 0.212lb/MMBtu to 0.05 lb/MMBtu. The
control of ash fouling of the SCR catalyst was effectively achieved with the
installation of a forward

‐ reverse duct ar rangement.

# C C A

**Combustion Components**  **Associates, Inc.**

**www.cca-inc.net**

### CCA is a global provider of combustion control technologies to reduce NOx, particulate matter (PM), unburned carbon and CO emissions at various types of combustion facilities including utility power plants, paper & pulp mills, chemical plants, oil refineries, ethanol plants, marine vessels, and diesel engines.

CCA specializes in supplying in-furnace and post combustion emission control technologies. CCA’s technologies have been installed in over 100 steam generators worldwide ranging in size from 10 MW to 800 MW (50,000 to 5,500,000 lb/hr steam flow) on coal, natural gas, fuel oil, refinery gas, and biofuelfired units. CCA technologies also have been installed on thermal oxidizers and dryers.

CCA’s in-furnace combustion control technologies achieve up to 70% reduction in NOx emissions through patented and proprietary modifications on wall-fired, tangential-fired, cyclone-fired, circulating fluid bed (CFB), and stoker-fired boilers, in addition to heaters and dryers. NOx reductions up to 95%can be achieved with the addition of post combustion systems such as SNCR and SCR. The combination of combustion system modifications with postcombustion technologies provides the most cost effective approach to minimize NOx emissions. 

# About CCA

CCA’s core expertise is emissions technologies for gaseous, liquids, and solid fuels, including combustion and post combustion
NOx controls. CCA offers burner upgrades
for coal, oil, and gas-fired systems, new
burners, overfire air (OFA), flue gas recirculation (FGR), targeted water tempering,
SNCR, and SCR. Technologies can be implemented alone or in combination to
achieve high levels of NOx control.

Flue Gas Recirculation 

## SCR Furnace and Stack Emissions Testing

Urea or NH 3 Injection

ESP Air Heater
Rich Reagent Injection Overfire Air System Urea Injection SNCR

Burners: - Flame

Stabilizers - Atomizers - Coal

Nozzles - Gas

Injectors - Combustion

Tempering Computer Modeling and Simulation 

# Combustion Products & Services

# Overfire Air (OFA)

CCA’s Overfire Air (OFA) system typically diverts 20-30% of the combustion air from the burners to the upper furnace to stage the combustion process beyond what can be achieved with low-NOx burners. CCA’s OFA technology has been applied to wall, cyclone, tangential, and stoker-fired boilers burning oil, gas, coal, and biofuels. CCA’s unique OFA port design ensures good air/fuel mixing and carbon burnout

at all boiler loads. CCA offers patented technologies that can be retrofit to existing coal, oil, and gas burners to achieve NOx emissions comparable tonew low-NOx burners at a fraction of the cost. CCA has performed upgrades on over 3,000 OEM burners on wall-fired and tangential-fired boilers, package boilers, heaters,and dryers. CCA also supplies new burners that incorporate our low-NOx technologies for applications where burner upgrades are not practical.

The basis of CCA’s NOx reduction technology isfuel and air staging. Fuel staging is accomplished using fuel injectors that produce fuelrich and fuel lean zones immediately downstream of the burner. Similarly, the combustion air is staged into air lean and air rich zones by a

multi-zone flame stabilizer. The end result is fuel

rich and fuel lean zones that can reduce NOx emissions by up to 50% with extremely stable flames. 

# Low-NOx Burners

Standard Oil Fired Burner Oil/Gas Burner

Low-NOx Flame Stabilizer

### The unique ports are designed to inject air at theproper velocity and direction to complete combustion prior to the furnace exit at all boiler loads. If required to improve burnout, tilting (vertical) and yawing (horizontal) port designs are available. CCA uses CFD modeling to locate the OFA ports on the furnace walls and to design the geometry of the OFAport. NOx reductions achieved with a CCA OFA system range from 25-40% depending on the fuel and

initial NOx level.



# Flue Gas Recirculation (FGR)

Flue Gas Recirculation (FGR) is a powerful NOx control technique where flue gases from the boiler exhaust duct are mixed with the combustion air stream and enter the furnace throughthe windbox and burners. FGR reduces peak flame temperature and therefore reduces thermal NOx formation. Consequently, FGR is most effective on gaseous fuels where NOx emissions are almost always 100% thermal NOx. FGR is less effective on liquid fuels because a portion of the NOx emissions can be generated from fuel bound nitrogen compounds.

Two approaches are commonly used to inject the FGR into the combustion air. Forced FGR uses a separate fan (FGR fan) to inject the flue gas into the combustion air downstream of theFD fan. The second approach uses the suction of the FD fan to induce flue gas from the exhaust duct, through the FD fan, and into the windbox (induced FGR). Induced FGR is lowerin cost, but has the disadvantage of reduced effectiveness at high load as FD fan suction diminishes. CCA offers both forced and induced FGR, which are compatible with CCA’s other NOx control technologies.


# Combustion Tempering

Combustion tempering is a patented NOx reduction process by which micronized water, steam, or flue gas is target injected into the flame. Typically water is used because of low capital cost. The water is injected just upstream of the flame which reduces the temperature at the point of initial combustion. CFD modeling is used to determine the injection droplet size, velocity,spray pattern and direction to insure that the water is injected into the most effective NOx reduction zone. Research has shown that NOx production decreases about 50% for every 190°Freduction in flame temperature in the NOx production zone of a flame. CFD modeling effectively identifies the optimum zone to minimize the water and maximize the NOx reduction when compared to conventional bulk water injection. Laser doppler spray testing is used to confirm that the water spray is consistent with the design requirements. CCA also provides skid mounted pumps and control skids to control the water usage and to integrate our systems with

the boiler controls. 

## CCA’s Overfire Air Ports

# Selective Non-Catalytic Reduction (SNCR)

CCA’s SNCR system provides a lowcost technique to reduce NOx emissions by 30%-60%. The SNCR process involves injecting a reagent (urea or ammonia) into the flue gasin the appropriate temperature window. The reagent reacts with NOx to form harmless nitrogen and water. The optimum temperaturewindow for efficient SNCR operation typically occurs between 1,620°F and 2,010°F (900°-1,100°C) and is usually located in the upper furnace and convective areas. The design, arrangement, and location of the reagent injectors is critical to the performance of the SNCR system.

CCA uses CFD modeling to optimally locate the injectors on the boiler to provide for complete mixing of the reagent with the flue gas across the injection plane. Depending on the application, multiple levels of injectors, along with other proprietary techniques, are used to ensure that the reagent is injected in the optimal temperature window across the operating range of the boiler. The modeling results also provide design information related to reagent flow requirements and design aspects to minimize ammonia slip.

CCA’s SNCR systems include reagent storage tanks, pumping and flow control, reagent injection systems, and a boiler control interface. CCA also provides experienced field engineers for optimizing the SNCR in conjunction with the combustion system and overall operations. SNCR Temperature Window Optimal SNCR

Temperature

Window

Temperature oFChemical Utilization 80%

60%

40%

20%

0%

1290 1650 1470 1830 2010 2190 2370



## CCA SNCR Injector

CCA’s SCR System on a stoker-fired unit in New Hampshire

# Rich Reagent Injection (RRI)

CCA is a licensed implementer of the Rich ReagentInjection (RRI) technology. RRI was jointly developed by Reaction Engineering International
(REI) in collaboration with EPRI and DOE.

RRI is similar to SNCR in that a reducing reagent is injected into the furnace to chemically reduce NOx formed by the combustion process. RRI, however, is injected into a fuel rich zone of the combustion process to react with NOx. Overfire air is used to complete combustion above the RRI zone. RRI is useful in many applications, since it generates very little ammonia slip.


# Selective Catalytic Reduction

CCA supplies Selective Catalytic Reduction (SCR) systems which convert NOx into nitrogen and water with the aid of a catalyst and an injected reagent such as ammonia or urea. The reagent is injected prior to the catalyst chamber and mixes with the flue gas. NOx reduction takes place as flue gas passes through the catalyst chamber.SCR systems can provide any level of NOx reduction required depending on the size of the catalyst chamber and the type of catalyst used.

CCA supplies complete SCR systems using ammonia (aqueous NH 3 

### , anhydrous NH 3 

### , or the

urea-to-NH 3 

### process) to suit customer and regulatory requirements. Our system includes the reagent storage tank, pumping and flow control, reagent injection system, boiler control interface, and the SCR catalyst chamber.

The SCR catalyst chamber is designed as a complete unit to provide for proper flow patternsthrough the catalyst and easy access for maintenance. Our catalysts chambers are equipped with sootblowers or sonic horns as necessary and can accommodate layer additions. Experienced CCA field engineers provide technical support inthe start-up and operation of the CCA SCR system. 

# Contact Information

Corporate & Engineering Offices

CCA

884 Main Steet
Monroe, CT 06468
Tel: 203-268-3139
Fax: 203-261-7697

Manufacturing Plant
Holmes Tools & Engineering Inc.

1019 N. Waukesha St Bonifay, FL 32425

Tel: 850-547-4417

Fax: 850-547-9329

Web: www.cca-inc.net

Email: info@cca-inc.netCCA PROJECT LOCATIONSAbska...II1Iz..-·-.NewVermonll.lmsecht.SeHs.a.I.:......<;000000%00Rhadelsbncl'ConnecticutNewJen;eyDeJ.lwybncl........,,"'ocWeat•Coalo()IJ•Gas•Wood0Paper&PulpCCA CORPORATION FEES, TERMS, AND CONDITIONS
JANUARY 2012

PAGE 1 OF 3

Manpower Rate:

Manpower charges shall be on an hourly, porta l-to-portal basis at the following rates:

Principal Consultant $240/hr Senior Engineer $195/hr Engineer $155/hr Designer $130/hr Draftsman $120/hr Technician $130/hr Secretary $65/hr

The basic rates shall apply for work on Monday through Friday for an 8-hour period between the hours of 7 A.M. to 7 P.M. Work in excess of 8 hours, night work and Saturday work shall be at a rate of 1.5 times the basic rate. Sunday and holiday work shall be at 2 times the basic rate. Travel time charges shall be at the basic rate for hours actually spent in travel.

Minimum Daily Charges:

A minimum daily charge for personnel in the field shall appl y of 8 hours per day per person at the basic manpower rate. The minimum daily charge shall apply to travel on weekends, but not weekdays.

Expenses :

Per-diem and shipping charges shall be actual cost plus 10% G & A.

All travel costs shall be charged at cost plus 10% G & A.

Automobile 55.5 cts/mi Truck or Trailer 90 cts/mi CEM Van Rental: $850/Day Portable Gas Analyzer : $270/Day NH3 Test Equipment $270/Day Coal Flow Testing Equipment : $630/Day LOI Testing: $630/Day Flow Laboratory Facility $1600/Day Combustion Test Rig $2650/Day Diesel Engine Test Rig $2650/Day

Diesel Engine and Combustion Test rig costs do not include the cost of the set-up & dismantling, fuel, SNCR or SCR reagent, or freight, which shall be billed at cost plus 10%.

Field Delays:

Delays imposed on CCA personnel in the field resulting from causes beyond CCA's direct control, such as partial or complete process shutdown or irregularity, strike, flood, fire, inclement weather, or failure of the client to meet herein stated responsibilities, shall be charged at the minimum daily rate plus per diem and applicable travel expenses, unless exceeded by actual time at the facility. Then, actual time will be charged. No delay time shall be charged for a delay directly caused by CCA, such as, malfunction of CCA test equipment.

Quotations:

Unaccepted quotations shall expire 30 days from date of issuance. Requested changes in project work scope shall subject a price quotation to change. Projected schedules in quotati ons are based upon manpower loadi ngs at the time a quotation is provided. Actual schedules are subject to change ba sed upon manpower loading at the time the order is received.CCA CORPORATION FEES, TERMS, AND CONDITIONS
JANUARY 2012

PAGE 2 OF 3

Acceptance:

A purchase order or a written commitment for a quoted amount sha ll be received prior to the rendering of any service. A purchase order with a "not to exceed" amount will result in the termination of services before the amount is exceeded. Issuance of a new purchase order, a written addition to the existing purchase order, or other written authorization from the client shall be received before rendering of services is resumed. Authorization by the client to proceed shall constitute the client's acceptance of these terms and conditions.

Escalation:

Once yearly, the outstanding portion of a quotation or budget fo r a project conducted over a time span of more than one year shall be subject to escalation for any new manpower rates or expense schedules issued by CCA.

Payments:

Invoiced payments shall be due in full within 30 days of th e date of invoice. Invoices past due shall accrue interest charges at the rate of 1 1/2% per month, due and payable by the client. Reasonable attorney fees, collection fees and other expenses incurred in collecting overdue amounts may be charged.

Extra Services:

Quotations for work do not include pre or post conferen ces or follow-up services, unless otherwise noted. CCA's standard charges for such extra services will apply unless provided at CCA's option.

Research and Development Projects:

Research and development programs are by nature subject to frequent changes in scope, direction, and budget. CCA Corporation undertakes such programs on a time-and-materials basis only. For each research and development program, a best-estimate budget shall be presented. Charges against is budget shall be made for time spent and costs incurred. Should a program require funding in excess of the budget, the c lient will be notified for written authorization of the new budget prior to initiating work, which would incur charges above the old budget.

Combustion Optimization Programs:

The performance requirements of combustion optimization pr ograms necessitate that CCA Corporation charge such programs on a time-and-materials basis. However, for each program a budget will be presented to the client. Should a program require funding in excess of the budget, the client will be notified for written authorization of the new budget prior to initiating further work.

Patents and Proprietary Technology:

CCA reserves all proprietary rights, including patent right s, in and to all devices, concepts, processes, products, inventions or other technology conceived or developed by CCA personnel during work conducted for a client. The client may use such CCA proprietary technology, royalty free, solely for the specific installation for which CCA's work was provided, and client may negotiate terms with CCA for expanded use to other installations.

Warranty - Services:

CCA represents and warrants that its procedures are ge nerally accepted practices and methods and its personnel are qualified to affect such procedures. Tests are perform ed on a best-efforts basis and CCA assumes no liability for deviations required by existing conditions beyond its control or field of respons ibility. No guarantee or warranty is issued, implied or intended and no responsibility is assumed for testing other than the accuracy of observed results. Should CCA’s testing be materially defectiv e, the sole liability of CCA shall be to repeat said test run at no additional cost to Client, provided, however, that said test run was not defective because of a failure of Client to supply critical information or to fulfill responsibilities.

Warranty – Products:

CCA represents and warrants that (a) products manufactured by it shall be (i) free of defects in materials and workmanship for a period of one year from date of shipment to client and (ii) shall conform in all material respects to theCCA CORPORATION FEES, TERMS, AND CONDITIONS
JANUARY 2012

PAGE 3 OF 3

specifications for such product agreed upon in this contr act. For products not manufactured by CCA the original manufacturers warranty, if any, shall be assigned to client to the extent permitted and such assigned warranty shall be in lieu of any other warranty express or implied. CCA’s so le liability hereunder shall be during the one year product warranty period to repair or replace, at its option, products that are defective or non-conforming to agreed specifications. CCA shall have no liability for on-site diagnostics, rem oval, transportation and reinstallation of such products.

Limitation and Disclaimer of Warranties:

CCA shall not be liable under the warranties hereunder unless:

(a) Client promptly notifies CCA in writing of the allege d deficiency in the product or service and offers CCA a reasonable opportunity to cure such deficiency, and (b) if a product deficiency in a CCA manufactured product, CCA inspection verifies the existence of the deficiency and dete rmines it was not caused by damage or destruction, including any occurring while in shipment, improper installation, tes ting, operation or repair (including any repair not by CCA agents or employees or otherwise not consented to in writing by CCA), misuse, neglect, or alteration.

THESE WARRANTIES ARE IN LIEU OF AND CCA DISCLAIMS ALL OTHER WARRANTIES, EXPRESS OR IMPLIED, WRITTEN OR ORAL, INCLUDING THOSE MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, OR OTHERWISE, AND MAY BE MODIFIED BY CCA ONLY IN A WRITING SIGNED BY CCA IN WHICH IT INTENDS TO BE FOUND.

Limitation of Liability:

CCA SHALL NOT BE LIABLE FOR ANY SPECIAL, INCIDENTAL OR CONSEQUENTIAL DAMAGES, WHETHER BASED ON BREACH OF CONTRACT OR WARRANTY, NEGLIGENCE, OR ANY OTHER MATTER RELATING TO THIS CONTRACT. CCA’S MAXIMU M LIABILITY SHALL IN NO CASE EXCEED THE AMOUNT THAT HAS BEEN PAID TO CCA FOR THE PRODUCT OR SERVICE PRIOR TO THE EVENT WHICH RESULTS IN SUCH LIABILITY OR, FOR INSURE D MATTERS, THE AMOUNT OF SUCH INSURANCE.

The prices quoted in this sale were dete rmined in part on the basis that CCA’s liabilities and Client’s remedies are limited as provided in this Statement and the prices would have been substantially different had those limitations not been agreed.

Choice of Law:

Any controversy between the parties shall be governed by the la ws of the State of Connecticut, to the exclusion of the law of any other forum, without regard to the jurisdiction in which any action or special proceeding shall be instituted.

Entire Agreement:

With respect to the subject matter herein, this document cont ains the entire agreement between the parties involved, and supersedes all other agreements between the parties except as noted in the Special Provisions section of this document.

Special Provisions:

## ATTACHMENT C – REVISED CONTROL COST TABLESCAPITAL COSTSANNUALIZED COSTSNO. 8 BOILERANNUALCOST ITEM FACTORCOST ($)COST ITEMCOST FACTORUNIT COSTCOST ($)Costs to Purchase and Install EquipmentAnnual Operating CostsPurchased Equipment CostsDirect Annual Costs(a)SCR system including urea storage and delivery system, andcatalyst$1,991,525Operating Labor(d)Platform materials to support the new equipment$0 (c) Labor, one employee 0.5 hours/shift $56.00 per hour $27,594(d)New fan$0(d)New stack$0(d)Electrical for the fan$0MaintenancePurchased Equipment Costs SubtotalA$1 991 525(b)Maintenance Labor and Materials0 015TCI$91 793TABLE C-1 (REVISED 3/21/2012)ESCANABA PAPER COMPANYBART EVALUATION CAPITAL AND ANNUALIZED COSTSNO. 8 BOILER NOxCONTROLSELECTIVE CATALYTIC REDUCTION (SCR)PurchasedEquipmentCostsSubtotalA$1,991,525(b)MaintenanceLaborandMaterials0.015TCI$91,793(b) Instrumentation0.100 A$199,153Utilities(b) Sales taxes0.030 A$59,746(a),(c) Reagent39,420 gal/yr$1.75per gal$68,985(b) Freight0.050 A$99,576(a),(c) Electricity0.1KWh$0.05 per kWh$42Total Purchased Equipment CostB$2,350,000(a)Catalyst replacement (1/3 of total peryear)5m3$150,000per year$150,000Direct Installation CostsTotal Direct Annual CostsDAC $338,414(c)Installation of SCR system including urea storage and deliverysystem, platform, demolition of old stack, demo of old fan,installation of new fan, new stack, foundations and supports,electrical, piping, insulation, and painting0.85 B $1,997,500Direct Installation CostC $1,997,500Indirect Annual Costs(b) Overhead60% of sum of operating & maintenance costs$71,632Total Direct CostD$4,347,500(b) Administrative Charges2% of TCI$122,391(b) Property Taxes1% of TCI$61,195Indirect Costs (Installation)(b) Insurance1% of TCI$61,195(b)General Facilities0.05 D $217,375(b)Engineering and Home Office Fees0.10 D $434,750Total Indirect Annual CostsIAC $316,414(b)Process Contingency0.05 D$217,375(b)Project Contingency0.15 (D+Gen Fac+Eng+Proc Cont)$782,550Total Annual O&M CostsO&M$654,828(b)Total Plant Cost(D+Gen Fac+Eng+Proc Cont+Proj Cont)$5,999,550(b)Preproduction Cost0.02 Total Plant Cost$119,991Cost EffectivenessExpected lifetime of equipment, years15Interest rate, %/yr7.0%Total Capital Investment (TCI).............................................................................(Tot Plt Cost+Preprod Cost)$6,119,541Capital recovery factor0.110Total capital investment cost$6,119,541Annualized capital investment cost$671,893Total Annualized Cost (Including O&M)$1,326,721Cost Effectiveness143.2 tons NOx/yrNOx EvaluationAnnual Cost/Ton Removed108.9 tons NOx/yr 76% NOx removal$12,188Incremental Cost EffectivenessUncontrolled Emissions (Worst-Case Scenario ifcurrent FGR control is decommissioned and NOT inUse)Controlled Emissions if the Mill were to Utilize115.7 tons NOx/yrNOx EvaluationAnnual Cost/Ton Removed87.9 tons NOx/yr 76% NOx removal$15,090current FGR on a Year-Round Basis and Also InstallSCRNotes:(a) Cost information obtained from Mr. Ed Schindler at Combustion Components Associates (CCA) on December 16, 2006 and revisedFebruary 2012.(b) Cost information estimated using the U.S. EPA Air Pollution Control Cost Manual (6th edition) published in January 2002 bythe OAQPS. The website for the manual is available at http://www.epa.gov/ttn/catc/dir1/c_allchs.pdf.(c) Cost information estimated by the Mill. Direct installation costs were approximated using a combination of Mill historical information and experience with multiple capital equipment installations. This experience indicates that the total capital investment should equal four times the purchased capital equipment cost becauseof the complexity of the installation that would need to occur at high elevations. Operating labor and maintenance costs wereestimated using an assumption of one employee per shift, 3 shifts per day, and 90% utilization.d) EPC has identified additional retrofitting costs that have not been included in the quotation provided by CCA. EPC has notincluded specific cost for the additional retrofitting that would be required. Given that additional cost for these retrofit items would be required, the annual cost/ton removed would only increase fromcurrent levels.No. 8 PB Cost Effectiveness Calcs 2_22_12.xls, 8PB SCR3/21/2012CAPITAL COSTSANNUALIZED COSTSNO. 9 BOILERANNUALCOST ITEMFACTORCOST ($)COST ITEMCOST FACTORUNIT COSTCOST ($)Costs to Purchase and Install EquipmentAnnual Operating CostsPurchased Equipment CostsDirect Annual Costs(a)SCR system including urea storage and delivery system, catalyst,and air heater$4,915,254Operating Labor(d)Platform materials to support the new equipment$0(c) Labor, one employee0.5 hours/shift$56.00 per hour$27,594(d)New fan$0(d)New stack$0(d)Electrical for the fan$0MaintenancePurchased Equipment Costs SubtotalA$4,915,254(b)Maintenance Labor and Materials0.015TCI$226,553TABLE C-10 (REVISED 3/21/2012)ESCANABA PAPER COMPANYBART EVALUATION CAPITAL AND ANNUALIZED COSTSNO. 9 BOILER NOxCONTROLSELECTIVE CATALYTIC REDUCTION (SCR) WITH AIR HEATERq p, ,( )(b) Instrumentation0.100 A$491,525Utilities(b) Sales taxes0.030 A$147,458(a),(c) Reagent252,288 gal/yr$1.75per gal$441,504(b) Freight0.050 A$245,763(a),(c)Natural gas for air heater system (350F to600F)21.25 MMBtu/hr$4.15per MMBtu$695,270Total Purchased Equipment CostB$5,800,000(a),(c) Electricity0.1KWh$0.05 per kWh$42(a),(c) Catalyst replacement22m3$250,000per year$250,000Direct Installation Costs(c)Installation of SCR system including air heater, urea storage anddelivery system, platform, demolition of old stack, installation ofnew fan, new stack, foundations and supports, electrical, piping,insulation, and painting0.85 B $4,930,000Total Direct Annual CostsDAC $1,640,963Direct Installation CostC $4,930,000Indirect Annual CostsIndirectAnnualCostsTotal Direct CostD $10,730,000(b) Overhead 60% of sum of operating & maintenance costs $152,488(b) Administrative Charges 2% of TCI $302,071Indirect Costs (Installation)(b) Property Taxes1% of TCI$151,035(b)General Facilities0.05 D$536,500(b) Insurance1% of TCI$151,035(b)Engineering and Home Office Fees0.10 D$1,073,000(b)Process Contingency0.05 D$536,500Total Indirect Annual CostsIAC$756,630(b)Project Contingency0.15 (D+Gen Fac+Eng+Proc Cont)$1,931,400(b)Total Plant Cost(D+Gen Fac+Eng+Proc Cont+Proj Cont)$14,807,400Total Annual O&M CostsO&M$2,397,594(b)Preproduction Cost0.02 Total Plant Cost$296,148Cost EffectivenessExpected lifetime of equipment, years15Total Capital Investment (TCI)...................................................................................(Tot Plt Cost+Pre Prod Cost)$15,103,548Interest rate, %/yr 7.0%Capital recovery factor 0.110Total capital investment cost $15,103,548Annualized capital investment cost$1,658,288Total Annualized Cost (Including O&M)$4,055,882296.6 tons NOx/yrNOx EvaluationAnnual Cost/Ton Removed225.4 tons NOx/yr 76% NOx removal$17,995Uncontrolled Emissions (Updated Estimate of Emissions)Notes:(a) Cost information obtained from Mr. Ed Schindler at Combustion Components Associates (CCA) on December 16, 2006 and revisedFebruary 2012.(b) Cost information estimated using the U.S. EPA Air Pollution Control Cost Manual (6th edition)published in January 2002 by the OAQPS. The website for the manual is available at http://www.epa.gov/ttn/catc/dir1/c_allchs.pdf.(c) Cost information estimated by the Mill. Direct installation costs were approximated using a combination of Mill historical information and experience with multiple capital equipment installations. This experience indicates that the total capital investment should equal four times the purchased capital equipment cost because of the complexityof the installation that would need to occur at high elevations. Operating labor and maintenance costs were estimated using anassumption of one employee per shift, 3 shifts per day, and 90% utilization.d) EPC has identified additional retrofitting costs that have not been included in the quotation provided by CCA. EPC has notincluded specific cost for the additional retrofitting that would be required. Given that additional cost for these retrofit items would be required, the annual cost/ton removed would only increase from current levels.No. 9 PB Cost Effectiveness Calcs 2_22_12.xls, 9PB SCR3/21/2012