Appendix 10.13 

Table 10-16 

Reference 8: 

Tables 21 and 22 on pages 26 and 27 of "BART Application Analysis 

(AP-6042) for Naughton Power Plant", May 28, 2009 
DEPARTMENT OF ENVIRONMENTAL QUALITY 

AIR QUALITY DIVISION 

BART Application Analysis 

AP-6042 

May 28, 2009 

NAME OF FIRM: PacifiCorp 

NAME OF FACILITY: Naughton Power Plant 

FACILITY LOCATION: Sections 32 and 33, T21N, R116W 

 UTM Zone: 12 

 Easting: 533,450 m, Northing: 4,622,700 m 

 Lincoln County, Wyoming 

TYPE OF OPERATION: Coal-Fired Electric Generating Plant 

RESPONSIBLE OFFICIAL: Angie Skinner, Plant Managing Director 

MAILING ADDRESS: P.O. Box 191 

 Kemmerer, WY 83101 

TELEPHONE NUMBER: (307) 828-4211 

REVIEWERS: Cole Anderson, Air Quality Engineer 

James (Josh) Nall, Air Quality Modeler 

PURPOSE OF APPLICATION:

Sections 169A and 169B of the 1990 Clean Air Act Amendments require states to improve visibility at 

Class I areas. On July 1, 1999, EPA first published the Regional Haze Rule, which provided specific 

details regarding the overall program requirements to improve visibility. The goal of the regional haze 

program is to achieve natural conditions by 2064. 

Section 308 of the Regional Haze Rule (40 CFR part 51) includes discussion on control strategies for 

improving visibility impairment. One of these strategies is the requirement under 40 CFR 51.308(e) for 

certain stationary sources to install Best Available Retrofit Technology (BART) to reduce emissions of 

three (3) visibility impairing pollutants, nitrogen oxides (NOx), particulate matter (PM), and sulfur 

dioxide (SO2). EPA published Appendix Y to part 51 - Guidelines for BART Determinations Under the 

Regional Haze Rule in the July 6, 2005 Federal Register to provide guidance to regulatory authorities for 

making BART determinations. Chapter 6, Section 9, Best Available Retrofit Technology was adopted 

into the Wyoming Air Quality Standards and Regulations (WAQSR) and became effective on December 

5, 2006. The Wyoming Department of Environmental Quality, Air Quality Division (Division) will 

determine BART for NOx and PM10 for each source subject to BART and include each determination in 

the §308 Wyoming Regional Haze State Implementation Plan (SIP). 
PacifiCorp Naughton Plant 

AP-6042 BART Application Analysis 

Page 26 

Table 19: Naughton Unit 1 Economic Costs

Cost Existing 

Dry FGD with 

Existing ESP 

Dry FGD with 

Polishing Fabric Filter 

Wet FGD with 

Existing ESP 

Control Equipment Capital Cost $0 $64,297,623 $108,995,970 $89,400,000 

Capital Recovery Factor N/A 0.09513 0.09513 0.09513 

Annual Capital Recovery Costs $0 $6,116,633 $10,368,787 $8,504,622 

Annual O&M Costs $0 $3,226,295 $4,006,095 $4,563,874 

Annual Cost of Control $0 $9,342,928 $14,374,882 $13,068,496 

Table 20: Naughton Unit 1 Environmental Costs

Existing 

Dry FGD with 

Existing ESP 

Dry FGD with 

Polishing Fabric Filter 

Wet FGD with 

Existing ESP 

SO2 Emission Rate (lb/MMBtu) 1.20 0.41 0.15 0.15 

Annual SO2 Emission (tpy) (a)

8,7516 2,990 1,094 1,094 

Annual SO2 Reduction (tpy) N/A 5,761 7,657 7,657 

Annual Cost of Control $0 $9,342,928 $14,374,882 $13,068,496 

Cost per ton of Reduction N/A $1,622 $1,877 $1,707 

Incremental Cost per ton of 

Reduction N/A $1,622 $2,654 $1,965 (b)

(a) Annual emissions based on an average coal sulfur content of 1.02%, a heat input rate of 1,850 MMBtu/hr, and 7,884 hours of 

operation per year. 

(b) Incremental cost from installing dry FGD with a polishing fabric filter cannot be calculated since the reduced tons of SO2

 are 

anticipated to be the same. Therefore, the incremental cost from installing dry FGD with the existing ESP was calculated. 

Table 21: Naughton Unit 2 Economic Costs

Cost Existing 

Dry FGD with 

Existing ESP 

Dry FGD with 

Polishing Fabric Filter 

Wet FGD with 

Existing ESP 

Control Equipment Capital Cost $0 $88,896,713 $141,244,778 $117,400,000 

Capital Recovery Factor N/A 0.09513 0.09513 0.09513 

Annual Capital Recovery Costs $0 $8,456,744 $13,436,616 $11,168,262 

Annual O&M Costs $0 $4,251,261 $5,259,175 $5,721,158 

Annual Cost of Control $0 $12,708,005 $18,695,791 $16,889,420 
PacifiCorp Naughton Plant 

AP-6042 BART Application Analysis 

Page 27 

Table 22: Naughton Unit 2 Environmental Costs

Existing 

Dry FGD with 

Existing ESP 

Dry FGD with 

Polishing Fabric Filter 

Wet FGD with 

Existing ESP 

SO2 Emission Rate (lb/MMBtu) 1.20 0.41 0.15 0.15 

Annual SO2 Emission (tpy) (a)

11,353 3,879 1,419 1,419 

Annual SO2 Reduction (tpy) N/A 7,474 9,934 9,934 

Annual Cost of Control $0 $12,708,005 $18,695,791 $16,889,420 

Cost per ton of Reduction N/A $1,700 $1,882 $1,700 

Incremental Cost per ton of 

Reduction N/A $1,700 $2,434 $1,700 (b)

(a) Annual emissions based on an average coal sulfur content of 1.02%, a heat input rate of 2,400 MMBtu/hr, and 7,884 hours of 

operation per year. 

(b) Incremental cost from installing dry FGD with a polishing fabric filter cannot be calculated since the reduced tons of SO2

 are 

anticipated to be the same. Therefore, the incremental cost from installing dry FGD with the existing ESP was calculated. 

Table 23: Naughton Unit 3 Economic Costs

Cost 

Existing 

Wet FGD 

Upgraded 

Wet FGD with 

Waste Liquor 

Upgraded 

Wet FGD with 

Soda Ash Reagent 

Control Equipment Capital Cost $0 $6,000,000 $27,798,972 

Capital Recovery Factor N/A 0.09513 0.09513 

Annual Capital Recovery Costs $0 $570,780 $2,644,516 

Annual O&M Costs $0 $615,513 $1,656,269 

Annual Cost of Control $0 $1,186,293 $4,300,785 

Table 24: Naughton Unit 3 Environmental Costs

Existing 

Wet FGD 

Upgrade 

Wet FGD Using 

Waste Liquor 

Upgrading 

Wet FGD Using 

Soda Ash Reagent 

SO2 Emission Rate (lb/MMBtu) 0.50 0.21 0.15 

Annual SO2 Emission (tpy) (a)

7,293 3,063 2,188 

Annual SO2 Reduction (tpy) N/A 4,230 5,105 

Annual Cost of Control $0 $1,186,293 $4,300,785 

Cost per ton of Reduction N/A $280 $842 

Incremental Cost per ton of Reduction N/A $280 $3,559 

(a) Annual emissions based on an average coal sulfur content of 1.02%, a heat input rate of 3,700 MMBtu/hr, and 7,884 hours 

of operation per year.