# Appendix 10.13

Table 10-16

Reference 8: Tables 21 and 22 on pages 26 and 27 of "BART Applic ation Analysis (AP-6042) for Naughton Power Plant", May 28, 2009DEPARTMENT 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 regi onal haze program is to achieve natural conditions by 2064.

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

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

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

SO 2 Emission Rate (lb/MMBtu) 1.20 0.41 0.15 0.15

Annual SO 2 Emission (tpy) (a) 8,7516 2,990 1,094 1,094

Annual SO 2 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 b e calculated since the reduced tons of SO 2 are anticipated to be the same. Therefore, the incremental cost from insta lling 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 $16,889,420PacifiCorp 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

SO 2 Emission Rate (lb/MMBtu) 1.20 0.41 0.15 0.15

Annual SO 2 Emission (tpy) (a) 11,353 3,879 1,419 1,419

Annual SO 2 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 b e calculated since the reduced tons of SO 2 are anticipated to be the same. Therefore, the incremental cost from insta lling 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

SO 2 Emission Rate (lb/MMBtu) 0.50 0.21 0.15

Annual SO 2 Emission (tpy) (a) 7,293 3,063 2,188

Annual SO 2 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.