# Printed 4/4/2012



# Comparison of SCR Control Costs (Original, 2008)

**Parameter**

**NDEP Revised EPA**  **NDEP Revised EPA**  **NDEP Revised EPA**  Unit Output (kW) Heat Input (MMBtu/hr) Boiler Type Ctrl technology Ctrl Emission Rate (lb/MMBtu) 0.085 0.085 0.083 0.083 0.098 0.098

Total Capital Costs $35,048,000 $26,840,000 $35,048,000 $26,840,000 $35,048,000 $26,840,000 Total Annual Costs Fixed Costs $330,000 $330,000 $330,000 $330,000 $330,000 $330,000 Variable Costs $699,801 $699,801 $748,551 $748,551 $670,893 $670,893 Capital Recovery $3,703,556 $2,533,506 $3,703,556 $2,533,506 $3,703,556 $2,533,506 20 yrs @ 8.5%20 yrs @ 7.0%20 yrs @ 8.5%20 yrs @ 7%20 yrs @ 8.5%20 yrs @ 7% Total Annual Costs $4,733,357 $3,563,307 $4,782,107 $3,612,057 $4,704,449 $3,534,399

NOx Removed from baseline (tpy) 1,850 1,850 2,010 2,009 1,774 1,775 Average Cost per ton ($/ton) $2,559 $1,926 $2,379 $1,798 $2,652 $1,991 Incremental Cost per ton ($/ton) $5,684 $4,067 $5,425 $3,885 $3,446 $2,477 Previous ctrl technology **Reid Gardner Unit 2**  **Unit 3**

Wall-fired Wall-fired Wall-fired 1132 1132 100,000 1132 100,000 100,000 **Unit 1**

ROFA+Rotamix ROFA+Rotamix ROFA+Rotamix SCR+LNB+OFA SCR+LNB+OFA SCR+LNB+OFA

SCR Cost Comparisons Page 1 of 1

# Reid Gardner NOx Control Effectiveness Summary - EPA Revised Costs

**Unit No. Annual Heat Input** **1**



# (MMBtu/yr) Unit 1 9,818,313 Unit 2 10,501,749 Unit 3 10,063,851

**Unit No. Parameter**  **Units Baseline** **2**

# LNB+OFA**LNB+OFA+SNCR ROFA+Rotamix** **SCR+LNB+OFA SCR+ROFA** 

Emission Rate (tpy) 2,267 1,784 1,340 959 417 417 Removed (tpy)

-- 483 927 1,308 1,850 1,850 Removal Rate (%)

-- 21.3% 40.9% 57.7% 81.6% 81.6% Emission Factor (lb/MMBtu)0.462 0.363 0.273 0.195 0.085 0.085 Annual Cost ($) $442,469 $946,040 $1,360,867 $3,563,307 $4,084,427 Average Cost Effectiveness ($/ton) $916 $1,021 $1,040 $1,926 $2,208 Incremental Cost Effectiveness($/ton)

-- $1,135 $1,088 $4,067 $5,030 Previous ctrl technology

-- LNB+OFALNB+OFA+SNCRROFA+RotamixROFA+Rotamix Emission Rate (tpy) 2,445 1,866 1,401 1,003 436 436 Removed (tpy)

-- 579 1,044 1,442 2,009 2,009 Removal Rate (%)

-- 23.7% 42.7% 59.0% 82.2% 82.2% Emission Factor (lb/MMBtu)0.466 0.355 0.267 0.191 0.083 0.083 Annual Cost ($) $442,469 $968,449 $1,408,676 $3,612,057 $4,159,306 Average Cost Effectiveness ($/ton) $764 $928 $977 $1,798 $2,070 Incremental Cost Effectiveness($/ton)

-- $1,131 $1,106 $3,885 $4,850 Previous ctrl technology

-- LNB+OFALNB+OFA+SNCRROFA+RotamixROFA+Rotamix Emission Rate (tpy) 2,268 2,118 1,590 1,399 493 493 Removed (tpy)

-- 150 678 869 1,775 1,775 Removal Rate (%)

-- 7% 30% 38% 78% 78% Emission Factor (lb/MMBtu)0.451 0.421 0.316 0.278 0.098 0.098 Annual Cost ($) $442,469 $895,762 $1,290,483 $3,534,399 $4,091,349 Average Cost Effectiveness ($/ton) $2,958 $1,321 $1,485 $1,991 $2,305 Incremental Cost Effectiveness($/ton)

-- $858 $2,064 $2,477 $3,092 Previous ctrl technology

-- LNB+OFALNB+OFA+SNCRROFA+RotamixROFA+Rotamix 1)Based on NDEP Reid-Gardner BART Determination, October 22, 2009, Table 1. Heat input values appear to be based on 1.0 capacity factor and 1152 MMBtu/hr 2)Baseline emissions and control option emissions based upon NDEP's October 22, 2009 BART determination, Table 1. Based on NDEP baseline, which is higher than NVE submittal. By comparison, NVE's Unit 1 baseline was 1625 tpy NOx Unit 1

Unit 2

Unit 3

# Reid Gardner NOx Emission Estimates (Based upon NDEP Cost and Control Estimates)

**Unit No. Annual Heat Input** **1**



# (MMBtu/yr) Unit 1 9,818,313 Unit 2 10,501,749 Unit 3 10,063,851

**Unit No. Parameter**  **Units Baseline** **2**

# LNB+OFA**LNB+OFA+SNCR ROFA+Rotamix** **SCR+LNB+OFA SCR+ROFA** 

Emission Rate (tpy) 2,267 1,784 1,340 959 417 417 Removed (tpy)

-- 483 927 1,308 1,850 1,850 Removal Rate (%)

-- 21.3% 40.9% 57.7% 81.6% 81.6% Emission Factor (lb/MMBtu) 0.462 0.363 0.273 0.195 0.085 0.085 Annual Cost ($) $550,024$1,130,186 $1,652,724 $4,733,357$5,379,929 Average Cost Effectiveness3 

# ($/ton) $1,139 $1,219 $1,264 $2,559 $2,908
Incremental Cost Effectiveness3 

# ($/ton)

-- $1,307 $1,371 $5,684 $6,877 Emission Rate (tpy) 2,445 1,866 1,401 1,003 435 435 Removed (tpy)

-- 579 1,044 1,442 2,010 2,010 Removal Rate (%)

-- 23.7% 42.7% 59.0% 82.2% 82.2% Emission Factor (lb/MMBtu) 0.466 0.355 0.267 0.191 0.083 0.083 Annual Cost ($) $550,024$1,152,595 $1,700,533 $4,782,107$5,454,808 Average Cost Effectiveness3 

# ($/ton) $950 $1,104 $1,179 $2,379 $2,714
Incremental Cost Effectiveness3 

# ($/ton)

-- $1,296 $1,377 $5,425 $6,610 Emission Rate (tpy) 2,268 2,121 1,590 1,400 494 494 Removed (tpy)

-- 147 678 868 1,774 1,774 Removal Rate (%)

-- 6.5% 29.9% 38.3% 78.2% 78.2% Emission Factor (lb/MMBtu) 0.451 0.421 0.316 0.278 0.098 0.098 Annual Cost ($) $550,024$1,079,908 $1,582,340 $4,704,449$5,386,851 Average Cost Effectiveness3 

# ($/ton) $3,742 $1,593 $1,823 $2,652 $3,037
Incremental Cost Effectiveness3 

# ($/ton)

-- $998 $2,644 $3,446 $4,199
1)As listed in NDEP Reid-Gardner BART Determination, October 22, 2009, Table 1, "Base Heat Input." Based on listed emission rates and emission factors, "base heat input" and not "total heat input" was used. 2)Baseline emissions and control option emissions based upon NDEP's October 22, 2009 BART determination, Table 1. Based on NDEP baseline, which is higher than NVE submittal. By comparison, NVE's Unit 1 baseline was 1625 tpy NOx 3)Average and incremental cost effectiveness values as reported in NDEP's October 22, 2009 BART determination, Table 1. Unit 1

Unit 2

Unit 3Printed 4/4/2012



### Control Cost Comparison - LNB+OFA

NDEP costs not allowed by EPA Control Cost Manual NDEP costs allowed by EPA Control Cost Manual, but modified from NDEP estimate

**NDEP EPA Revised**  **Cost NDEP**  **EPA Revised Cost**  **Value %**  **Value %**  **Comments** 

### Capital Costs **Low NOx Burners (Upgrade) + OFA/ROFA**

Major Materials Design and Supply Construction $1,600,000 $1,600,000 $1,600,000 $1,600,000 $1,600,000 $1,600,000Vendor estimate. Comparable to Purchased Equipment Cost (PEC) as described in EPA CCM, although this line item description suggests it includes more than just PEC. The CCM provides more detailed guidance on what constituent elements may be included in this line item, but the NDEP appendix does not provide sufficient detail to make more specific determinations. Construction $1,120,000 70% $1,120,00070%$1,120,000 $1,120,000 $1,120,000 $1,120,000Vendor estimate. Comparable to Indirect installation costs as described in EPA CCM. Again, more detailed guidance on what constituent elements are allowed in this line item, but the NDEP appendix Balance of Plant $800,000 50% $800,000 50% $800,000 $800,000 $800,000 $800,000Balance of plant is construed to refer to other capital expenditures beyond PEC. Such costs are allowed in the CCM, and are considered part of direct capital costs (DCC). Electrical (Allowance) $80,000 5% $80,000 5% $80,000 $80,000 $80,000 $80,000 Electrical equipment is included in the EPA control cost manual as part of direct capital costs (DCC), and so are retained here without revision Owner's Costs $160,000 10% $0 0% $160,000 $0 $160,000 $0 Owner's costs such as project management, advisory fees, legal, etc., are not included in the Control Cost Manual. Although it is possible that certain CCM-allowed costs are included in this line item, additional details would be needed to make that dete Surcharge $256,000 16% $0 0% $256,000 $0 $256,000 $0 There is no provision for surcharge in the EPA Control Cost Manual AFUDC $192,000 12% $0 0% $192,000 $0 $192,000 $0 AFUDC is not allowed for any of the applications listed in the EPA Control Cost Manual Subtotal, LNB+OFA Capital Cost$4,208,000 $3,600,000 $4,208,000 $3,600,000 $4,208,000 $3,600,000 Contingency $240,000 15% $240,000 15% $240,000 $240,000 $240,000 $240,000EPA Control Cost Manual provides for project contingency costs of up to 15% of the total of direct capital costs (DCC) and indirect installation costs. **Total LNB+OFA Capital Cost $4,448,000**  **$3,840,000 $4,448,000**  **$3,840,000 $4,448,000**  **$3,840,000** 

### Total Capital Cost **$4,448,000 $3,840,000**  **$4,448,000 $3,840,000** **$4,448,000 $3,840,000**  **Unit 1 Unit 2**  **Unit 3 NDEP**  **EPA Revised Cost**

LNB+OFA Page 1 of 2Printed 4/4/2012



### Control Cost Comparison - LNB+OFA

NDEP costs not allowed by EPA Control Cost Manual NDEP costs allowed by EPA Control Cost Manual, but modified from NDEP estimate

**NDEP EPA Revised**  **Cost NDEP**  **EPA Revised Cost**  **Value %**  **Value %**  **Comments**

**Unit 1 Unit 2**  **Unit 3 NDEP**  **EPA Revised Cost**



### Annual Costs **Fi xed O&M Costs** 

Operating Labor $0 $0 $0 $0 $0 $0 No estimate of additional operating labor was provided. Maintenance Materials $32,000 $32,000 $32,000 $32,000 $32,000 $32,000 Maintenance Labor $48,000 $48,000 $48,000 $48,000 $48,000 $48,000 Administrative Labor $0 $0 $0 $0 $0 $0 No estimate of additional administrative labor was provided. Subtotal, fixed O&M costs $80,000 $80,000 $80,000 $80,000 $80,000 $80,000 **Variable Costs**

Reagent $0 $0 $0 $0 $0 $0 EPA CCM does provide for certain raw material costs such as reagent costs. Catalyst Replacement $0 $0 $0 $0 $0 $0 The EPA Control Cost Manual does provide for SCR catalyst replacement costs. The basis for NDEP's estimate is not clear, however, and it is difficult to determine how catalyst costs determined using the CCM might compare. Auxiliary Power $0 $0 $0 $0 $0 $0 The EPA Control Cost Manual does provide for utility costs, such as those needed to operate SCR equipment. Subtotal, variable costs $0 $0 $0 $0 $0 $0 Debt Service/Capital Recovery1 $470,024 $362,469 $470,024 $362,469 $470,024 $362,469Regarding interest rates, EPA calculated capital recoveries using 3% and 7% interest rates in determining cost effectiveness for the Regulatory Impact Analysis for the Final Clean Air Visibility rule and the Guidelines for BART Determinations under the Regional Haze regulations. The EPA Control Cost Manual uses 7% interest rate in SNCR example calculations (Section 4-2, Chap 1, p1-37). In addition, the CCM also recommends a 20 year economic lifetime for SNCR (p1-37), although 30 year lifetimes have often been specified in BART and BACT analyses. 

### Total Annual Costs $550,024 $442,469 $550,024 $442,469 $550,024 $442,469

1) Debt Service/Capital Recovery

Interest rate (%) = 8.5% 7.0% Equipment lifetime (years) =20 20 The EPA Control Cost Manual provides for maintenance materials and labor. These costs are included in the revised EPA estimate, although no basis was provided.

LNB+OFA Page 2 of 2Printed 4/4/2012



### Control Cost Comparison - LNB+OFA+SNCR

NDEP costs not allowed by EPA Control Cost Manual NDEP costs allowed by EPA Control Cost Manual, but modified from NDEP estimate

**NDEP EPA Revised**  **Cost NDEP**  **EPA Revised Cost**  **Value %**  **Value %**  **Comments** 

### Capital Costs **Low NOx Burners (Upgrade) + OFA**

Major Materials Design and Supply Construction $1,600,000 $1,600,000 $1,600,000 $1,600,000 $1,600,000 $1,600,000Vendor estimate. Comparable to Purchased Equipment Cost (PEC) as described in EPA CCM, although this line item description suggests it includes more than just PEC. The CCM provides more detailed guidance on what constituent elements may be included in this line item, but the NDEP appendix does not provide sufficient detail to make more specific determinations. Construction $1,120,00070%$1,120,00070%$1,120,000 $1,120,000 $1,120,000 $1,120,000Vendor estimate. Comparable to Indirect installation costs as described in EPA CCM. Again, more detailed guidance on what constituent elements are allowed in this line item, but the NDEP Balance of Plant $800,000 50% $800,000 50% $800,000 $800,000 $800,000 $800,000Balance of plant is construed to refer to other capital expenditures beyond PEC. Such costs are allowed in the CCM, and are considered part of direct capital costs (DCC). Electrical (Allowance) $80,000 5% $80,000 5% $80,000 $80,000 $80,000 $80,000Electrical equipment is included in the EPA control cost manual as part of direct capital costs (DCC), and so are retained here without revision Owner's Costs $160,000 10% $0 0% $160,000 $0 $160,000 $0 Owner's costs such as project management, advisory fees, legal, etc., are not included in the Control Cost Manual. Although it is possible that certain CCM-allowed costs are included in this line item, additional details would be needed to make that dete Surcharge $256,000 16% $0 0% $256,000 $0 $256,000 $0 There is no provision for surcharge in the EPA Control Cost Manual AFUDC $192,000 12% $0 0% $192,000 $0 $192,000 $0 AFUDC is not allowed for any of the applications listed in the EPA Control Cost Manual Subtotal, LNB+OFA Capital Cost$4,208,000 $3,600,000 $4,208,000 $3,600,000 $4,208,000 $3,600,000 Contingency $240,000 15% $240,000 15% $240,000 $240,000 $240,000 $240,000EPA Control Cost Manual provides for project contingency costs of up to 15% of the total of direct capital costs (DCC) and indirect installation costs. **Total LNB+OFA Capital Cost $4,448,000**  **$3,840,000 $4,448,000**  **$3,840,000 $4,448,000**  **$3,840,000 Selective Non-Catalytic Reduction (SNCR)** 

Major Materials Design and Supply Construction $1,350,000 $1,350,000 $1,350,000 $1,350,000 $1,350,000 $1,350,000Vendor estimate. Comparable to Purchased Equipment Cost (PEC) as described in EPA CCM, although this line item description suggests it includes more than just PEC. See comments in ROFA above. Construction $202,500 15.0% $202,500 15% $202,500 $202,500 $202,500 $202,500 Balance of Plant $162,000 12.0% $162,000 12% $162,000 $162,000 $162,000 $162,000 Electrical (Allowance) $67,500 5.0% $67,500 5% $67,500 $67,500 $67,500 $67,500 Owner's Costs $135,000 10.0% $0 0% $135,000 $0 $135,000 $0 Owner's costs such as project management, advisory fees, legal, etc., are not included in the Control Cost Manual. Although it is possible that certain CCM-allowed costs are included in this line item, additional details would be needed to make that dete Surcharge $216,000 16.0% $0 0% $216,000 $0 $216,000 $0 There is no provision for surcharge in the EPA Control Cost Manual AFUDC $162,000 12.0% $0 0% $162,000 $0 $162,000 $0 AFUDC is not allowed for SCR in the EPA Control Cost Manual Subtotal, SCR Capital Cost $2,295,000 $1,782,000 $2,295,000 $1,782,000 $2,295,000 $1,782,000 Contingency $202,500 15% $202,500 15% $202,500 $202,500 $202,500 $202,500EPA Control Cost Manual provides for project contingency costs of up to 15% of the total of direct capital costs (DCC) and indirect installation costs. **Total SNCR Capital Cost $2,497,500**  **$1,984,500 $2,497,500**  **$1,984,500 $2,497,500**  **$1,984,500** 

### Total Capital Cost **$6,945,500 $5,824,500**  **$6,945,500 $5,824,500** **$6,945,500 $5,824,500** See comments in LNB+OFA section above. While these costs to not directly correspond to EPA CCM line items, they are comparable to certain allowed costs. As a result, these costs are retained without revision. **Unit 1 Unit 2**  **Unit 3 NDEP**  **EPA Revised Cost**

SNCR+LNB+OFA Page 1 of 2Printed 4/4/2012



### Control Cost Comparison - LNB+OFA+SNCR

NDEP costs not allowed by EPA Control Cost Manual NDEP costs allowed by EPA Control Cost Manual, but modified from NDEP estimate

**NDEP EPA Revised**  **Cost NDEP**  **EPA Revised Cost**  **Value %**  **Value %**  **Comments**

**Unit 1 Unit 2**  **Unit 3 NDEP**  **EPA Revised Cost**



### Annual Costs **Fixed O&M Costs**

Operating Labor $0 $0 $0 $0 $0 $0 No estimate of additional operating labor was provided. Maintenance Materials $83,000 $83,000 $83,000 $83,000 $83,000 $83,000 Maintenance Labor $124,500 $124,500 $124,500 $124,500 $124,500 $124,500 Administrative Labor $0 $0 $0 $0 $0 $0 No estimate of additional administrative labor was provided. Subtotal, fixed O&M costs $207,500 $207,500 $207,500 $207,500 $207,500 $207,500 **Variable Costs**

Reagent $151,080 $151,080 $169,985 $169,985 $98,612 $98,612EPA CCM does provide for certain raw material costs such as reagent costs. Catalyst Replacement $0 $0 $0 $0 $0 $0 The EPA Control Cost Manual does provide for SCR catalyst replacement costs. The basis for NDEP's estimate is not clear, however, and it is difficult to determine how catalyst costs determined using the CCM might compare. Auxiliary Power $37,668 $37,668 $41,172 $41,172 $39,858 $39,858 The EPA Control Cost Manual does provide for utility costs, such as those needed to operate SCR equipment. Subtotal, variable costs $188,748 $188,748 $211,157 $211,157 $138,470 $138,470 Debt Service/Capital Recovery1 $733,938 $549,792 $733,938 $549,792 $733,938 $549,792Regarding interest rates, EPA calculated capital recoveries using 3% and 7% interest rates in determining cost effectiveness for the Regulatory Impact Analysis for the Final Clean Air Visibility rule and the Guidelines for BART Determinations under the Regional Haze regulations. The EPA Control Cost Manual uses 7% interest rate in SNCR example calculations (Section 4-2, Chap 1, p1-37). In addition, the CCM also recommends a 20 year economic lifetime for SNCR (p1-37), although 30 year lifetimes have often been specified in BART and BACT analyses. 

### Total Annual Costs $1,130,186 $946,040 $1,152,595$968,449$1,079,908$895,762

1) Debt Service/Capital Recovery

Interest rate (%) = 8.5% 7.0% Equipment lifetime (years) =20 20 The EPA Control Cost Manual provides for maintenance materials and labor. These costs are included in the revised EPA estimate, although no basis was provided.

SNCR+LNB+OFA Page 2 of 2Printed 4/4/2012



## Control Cost Comparison - ROFA+Rotamix

NDEP costs not allowed by EPA Control Cost Manual NDEP costs allowed by EPA Control Cost Manual, but modified from NDEP estimate

**NDEP EPA Revised**  **NDEP EPA Revised**  **Value %**  **Value %**  **Comments** 

## Capital Costs **Rotating Overfire Air (ROFA)**

Major Materials Design and Supply Construction $2,880,000 $2,880,000 $2,880,000 $2,880,000 $2,880,000 $2,880,000Vendor estimate. Comparable to Purchased Equipment Cost (PEC) as described in EPA CCM, although this line item description suggests it includes more than just PEC. The CCM provides more detailed guidance on what constituent elements may be included in this line item, but the NDEP appendix does not provide sufficient detail to make more specific determinations. Construction $742,500 $742,500 $742,500 $742,500 $742,500 $742,500Vendor estimate. Comparable to Indirect installation costs as described in EPA CCM. Again, more detailed guidance on what constituent elements are allowed in this line item, but the NDEP appendix does not provide sufficient detail to make this evaluation Balance of Plant $1,440,00050%$1,440,00050%$1,440,000 $1,440,000 $1,440,000 $1,440,000Balance of plant is construed to refer to other capital expenditures beyond PEC. Such costs are allowed in the CCM, and are considered part of direct capital costs (DCC). Electrical (Allowance) $864,000 30%$864,00030% $864,000 $864,000 $864,000 $864,000Electrical equipment is included in the EPA control cost manual as part of direct capital costs (DCC), and so are retained here without revision Owner's Costs $288,000 10% $0 0% $288,000 $0 $288,000 $0 Owner's costs such as project management, advisory fees, legal, etc., are not included in the Control Cost Manual. Although it is possible that certain CCM-allowed costs are included in this line item, additional details would be needed to make that determination. Surcharge $460,800 16% $0 0% $460,800 $0 $460,800 $0 There is no provision for surcharge in the EPA Control Cost Manual AFUDC $345,600 12% $0 0% $345,600 $0 $345,600 $0 AFUDC is not allowed for any of the applications listed in the EPA Control Cost Manual Subtotal, ROFA Capital Cost $7,020,900 $5,926,500 $7,020,900 $5,926,500 $7,020,900 $5,926,500 Contingency $864,000 30%$432,00015% $864,000 $432,000 $864,000 $432,000EPA Control Cost Manual provides for project contingency costs of up to 15% of the total of direct capital costs (DCC) and indirect installation costs. **Total ROFA Capital Cost $7,884,900**  **$6,358,500 $7,884,900**  **$6,358,500 $7,884,900**  **$6,358,500 Rotamix** Major Materials Design and

Supply Construction $1,029,000 $1,029,000 $1,029,000 $1,029,000 $1,029,000 $1,029,000Vendor estimate. Comparable to Purchased Equipment Cost (PEC) as described in EPA CCM, although this line item description suggests it includes more than just PEC. See comments in ROFA above. Construction $247,500 $247,500 $247,500 $247,500 $247,500 $247,500Vendor estimate. Comparable to Indirect installation costs as described in EPA CCM. Again, more detailed guidance on what constituent elements are allowed in this line item, but the NDEP appendix does not provide sufficient detail to make this evaluation Balance of Plant $123,480 12.0%$123,48012% $123,480 $123,480 $123,480 $123,480Balance of plant is construed to refer to other capital expenditures beyond PEC. Such costs are allowed in the CCM, and are considered part of direct capital costs (DCC). Electrical (Allowance) $0 0.0% $0 0% $0 $0 $0 $0 Zero estimate provided by NDEP. Based upon the documentation provided, it is unclear if these costs are accounted for elsewhere Owner's Costs $102,900 10.0% $0 0% $102,900 $0 $102,900 $0 Owner's costs such as project management, advisory fees, legal, etc., are not included in the Control Cost Manual. Although it is possible that certain CCM-allowed costs are included in this line item, additional details would be needed to make that determination. Surcharge $164,640 16.0% $0 0% $164,640 $0 $164,640 $0 There is no provision for surcharge in the EPA Control Cost Manual AFUDC $123,480 12.0% $0 0% $123,480 $0 $123,480 $0 AFUDC is not allowed for SNCR (comparable to Rotamix) in the EPA Control Cost Manual Subtotal, Rotamix Capital Cost $1,791,000 $1,399,980 $1,791,000 $1,399,980 $1,791,000 $1,399,980 Contingency $154,350 15%$154,35015% $154,350 $154,350 $154,350 $154,350EPA Control Cost Manual provides for project contingency costs of up to 15% of the total of direct capital costs (DCC) and indirect installation costs. **Total Rotamix Capital Cost $1,945,350**  **$1,554,330 $1,945,350**  **$1,554,330 $1,945,350**  **$1,554,330** 

## Total Capital Cost **$9,830,250 $7,912,830**  **$9,830,250 $7,912,830** **$9,830,250 $7,912,830**  **Unit 1 Unit 2**  **Unit 3 NDEP**  **EPA Revised Cost**

ROFA+Rotamix Page 1 of 2Printed 4/4/2012



## Control Cost Comparison - ROFA+Rotamix

NDEP costs not allowed by EPA Control Cost Manual NDEP costs allowed by EPA Control Cost Manual, but modified from NDEP estimate

**NDEP EPA Revised**  **NDEP EPA Revised**  **Value %**  **Value %**  **Comments**

**Unit 1 Unit 2**  **Unit 3 NDEP**  **EPA Revised Cost**



## Annual Costs **Fixed O&M Costs**

Operating Labor $0 $0 $0 $0 $0 $0 No estimate of additional operating labor was provided. Maintenance Materials $48,000 $48,000 $48,000 $48,000 $48,000 $48,000 Maintenance Labor $72,000 $72,000 $72,000 $72,000 $72,000 $72,000 Administrative Labor $0 $0 $0 $0 $0 $0 No estimate of additional administrative labor was provided. Subtotal, fixed O&M costs $120,000 $120,000 $120,000 $120,000 $120,000 $120,000 **Variable Costs**

Reagent $213,062 $213,062 $234,741 $234,741 $126,347 $126,347EPA CCM does provide for certain raw material costs such as reagent costs. Catalyst Replacement $0 $0 $0 $0 $0 $0 Auxiliary Power $280,890 $280,890 $307,020 $307,020 $297,221 $297,221The EPA Control Cost Manual does provide for utility costs, such as those needed to operate SNCR (comparable to Rotamix) equipment. Subtotal, variable costs $493,952 $493,952 $541,761 $541,761 $423,568 $423,568 Debt Service/Capital Recovery1 $1,038,772 $746,915 $1,038,772 $746,915 $1,038,772 $746,915Regarding interest rates, EPA calculated capital recoveries using 3% and 7% interest rates in determining cost effectiveness for the Regulatory Impact Analysis for the Final Clean Air Visibility rule and the Guidelines for BART Determinations under the Regional Haze regulations. The EPA Control Cost Manual uses 7% interest rate in SNCR example calculations (Section 4-2, Chap 1, p1-37). In addition, the CCM also recommends a 20 year economic lifetime for SNCR (p1-37), although 30 year lifetimes have often been specified in BART and BACT analyses. 

## Total Annual Costs $1,652,724 $1,360,867 $1,700,533$1,408,676$1,582,340$1,290,483

1) Debt Service/Capital Recovery

Interest rate (%) = 8.5% 7.0% Equipment lifetime (years) =20 20 The EPA Control Cost Manual provides for maintenance materials and labor. These costs are included in the revised EPA estimate, although no basis was provided.

ROFA+Rotamix Page 2 of 2Printed 4/4/2012



### Control Cost Comparison - SCR+LNB+OFA

NDEP costs not allowed by EPA Control Cost Manual NDEP costs allowed by EPA Control Cost Manual, but modified from NDEP estimate

**NDEP EPA Revised**  **Cost NDEP**  **EPA Revised Cost**  **Value %**  **Value %**  **Comments** 

### Capital Costs **Low NOx Burners (Upgrade) + OFA**

Major Materials Design and Supply Construction $1,600,000 $1,600,000 $1,600,000 $1,600,000 $1,600,000 $1,600,000Vendor estimate. Comparable to Purchased Equipment Cost (PEC) as described in EPA CCM, although this line item description suggests it includes more than just PEC. The CCM provides more detailed guidance on what constituent elements may be included in t Construction $1,120,000 70% $1,120,00070%$1,120,000 $1,120,000 $1,120,000 $1,120,000Vendor estimate. Comparable to Indirect installation costs as described in EPA CCM. Again, more detailed guidance on what constituent elements are allowed in this line item, but the NDEP appendix Balance of Plant $800,000 50% $800,000 50% $800,000 $800,000 $800,000 $800,000Balance of plant is construed to refer to other capital expenditures beyond PEC. Such costs are allowed in the CCM, and are considered part of direct capital costs (DCC). Electrical (Allowance) $80,000 5% $80,000 5% $80,000 $80,000 $80,000 $80,000 Electrical equipment is included in the EPA control cost manual as part of direct capital costs (DCC), and so are retained here without revision Owner's Costs $160,000 10% $0 0% $160,000 $0 $160,000 $0 Owner's costs such as project management, advisory fees, legal, etc., are not included in the Control Cost Manual. Although it is possible that certain CCM-allowed costs are included in this line item, additional details would be needed to make that dete Surcharge $256,000 16% $0 0% $256,000 $0 $256,000 $0 There is no provision for surcharge in the EPA Control Cost Manual AFUDC $192,000 12% $0 0% $192,000 $0 $192,000 $0 AFUDC is not allowed for SCR in the EPA Control Cost Manual, Section 4.2, Chap 2, Table 2.5 Subtotal, LNB+OFA Capital Cost $4,208,000 $3,600,000 $4,208,000 $3,600,000 $4,208,000 $3,600,000 Contingency $240,000 15% $240,000 15% $240,000 $240,000 $240,000 $240,000EPA Control Cost Manual provides for project contingency costs of up to 15% of the total of direct capital costs (DCC) and indirect installation costs. **Total ROFA Capital Cost $4,448,000**  **$3,840,000 $4,448,000**  **$3,840,000 $4,448,000**  **$3,840,000 Selective Catalytic Reduction (SCR)** 

Major Materials Design and Supply Construction $20,000,000 $20,000,000 $20,000,000 $20,000,000 $20,000,000 $20,000,000Vendor estimate. Comparable to Purchased Equipment Cost (PEC) as described in EPA CCM, although this line item description suggests it includes more than just PEC. See comments in ROFA above. Construction $0 0.0% $0 0% $0 $0 $0 $0 Balance of Plant $0 0.0% $0 0% $0 $0 $0 $0 Electrical (Allowance) $0 0.0% $0 0% $0 $0 $0 $0 Owner's Costs $2,000,000 10.0% $0 0% $2,000,000 $0 $2,000,000 $0 Owner's costs such as project management, advisory fees, legal, etc., are not included in the Control Cost Manual. Although it is possible that certain CCM-allowed costs are included in this line item, additional details would be needed to make that dete Surcharge $3,200,000 16.0% $0 0% $3,200,000 $0 $3,200,000 $0 There is no provision for surcharge in the EPA Control Cost Manual AFUDC $2,400,000 12.0% $0 0% $2,400,000 $0 $2,400,000 $0 AFUDC is not allowed for SCR in the EPA Control Cost Manual Subtotal, SCR Capital Cost $27,600,000 $20,000,000 $27,600,000 $20,000,000 $27,600,000 $20,000,000 Contingency $3,000,000 15% $3,000,00015%$3,000,000 $3,000,000 $3,000,000 $3,000,000EPA Control Cost Manual provides for project contingency costs of up to 15% of the total of direct capital costs (DCC) and indirect installation costs. **Total SCR Capital Cost $30,600,000**  **$23,000,000 $30,600,000**  **$23,000,000 $30,600,000**  **$23,000,000** 

### Total Capital Cost **$35,048,000 $26,840,000**  **$35,048,000 $26,840,000** **$35,048,000 $26,840,000** Zero estimate provided by NDEP. Based upon the documentation provided, it is unclear if these costs are accounted for elsewhere **Unit 1 Unit 2**  **Unit 3 NDEP**  **EPA Revised Cost**

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### Control Cost Comparison - SCR+LNB+OFA

NDEP costs not allowed by EPA Control Cost Manual NDEP costs allowed by EPA Control Cost Manual, but modified from NDEP estimate

**NDEP EPA Revised**  **Cost NDEP**  **EPA Revised Cost**  **Value %**  **Value %**  **Comments**

**Unit 1 Unit 2**  **Unit 3 NDEP**  **EPA Revised Cost**



### Annual Costs **Fi xed O&M Costs** 

Operating Labor $0 $0 $0 $0 $0 $0 No estimate of additional operating labor was provided. Maintenance Materials $132,000 $132,000 $132,000 $132,000 $132,000 $132,000 Maintenance Labor $198,000 $198,000 $198,000 $198,000 $198,000 $198,000 Administrative Labor $0 $0 $0 $0 $0 $0 No estimate of additional administrative labor was provided. Subtotal, fixed O&M costs $330,000 $330,000 $330,000 $330,000 $330,000 $330,000 **Variable Costs**

Reagent $301,192 $301,192 $326,816 $326,816 $257,830 $257,830EPA CCM does provide for certain raw material costs such as reagent costs. Catalyst Replacement $150,000 $150,000 $150,000 $150,000 $150,000 $150,000The EPA Control Cost Manual does provide for SCR catalyst replacement costs. The basis for NDEP's estimate is not clear, however, and it is difficult to determine how catalyst costs determined using the CCM might compare. Auxiliary Power $248,609 $248,609 $271,735 $271,735 $263,063 $263,063The EPA Control Cost Manual does provide for utility costs, such as those needed to operate SCR equipment. Subtotal, variable costs $699,801 $699,801 $748,551 $748,551 $670,893 $670,893 Debt Service/Capital Recovery1 $3,703,556 $2,533,506 $3,703,556 $2,533,506 $3,703,556 $2,533,506Regarding interest rates, EPA calculated capital recoveries using 3% and 7% interest rates in determining cost effectiveness for the Regulatory Impact Analysis for the Final Clean Air Visibility rule and the Guidelines for BART Determinations under the Regional Haze regulations. The EPA Control Cost Manual uses 7% interest rate in SCR example calculations (Section 4-2, Chap 2, p2- 57). In addition, the CCM also recommends a 20 year economic lifetime for SCR (p2-57), although 30 year lifetimes have often been specified in BART and BACT analyses. 

### Total Annual Costs $4,733,357 $3,563,307 $4,782,107$3,612,057$4,704,449$3,534,399

1) Debt Service/Capital Recovery

Interest rate (%) = 8.5% 7.0% Equipment lifetime (years) = 20 20 The EPA Control Cost Manual provides for maintenance materials and labor. These costs are included in the revised EPA estimate, although no basis was provided.

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### Control Cost Comparison - SCR+ROFA

NDEP costs not allowed by EPA Control Cost Manual NDEP costs allowed by EPA Control Cost Manual, but modified from NDEP estimate

**NDEP EPA Revised**  **Cost NDEP**  **EPA Revised Cost**  **Value %**  **Value %**  **Comments** 

### Capital Costs **Rotating Overfire Air (ROFA)**

Major Materials Design and Supply Construction $2,880,000 $2,880,000 $2,880,000 $2,880,000 $2,880,000 $2,880,000Vendor estimate. Comparable to Purchased Equipment Cost (PEC) as described in EPA CCM, although this line item description suggests it includes more than just PEC. The CCM provides more detailed guidance on what constituent elements may be included in this line item, but the NDEP appendix does not provide sufficient detail to make more specific determinations. Construction $742,500 $742,500 $742,500 $742,500 $742,500 $742,500Vendor estimate. Comparable to Indirect installation costs as described in EPA CCM. Again, more detailed guidance on what constituent elements are allowed in this line item, but the NDEP appendix does not provide sufficient detail to make this evaluation Balance of Plant $1,440,000 50% $1,440,00050%$1,440,000 $1,440,000 $1,440,000 $1,440,000Balance of plant is construed to refer to other capital expenditures beyond PEC. Such costs are allowed in the CCM, and are considered part of direct capital costs (DCC). Electrical (Allowance) $864,000 30% $864,000 30% $864,000 $864,000 $864,000 $864,000Electrical equipment is included in the EPA control cost manual as part of direct capital costs (DCC), and so are retained here without revision Owner's Costs $288,000 10% $0 0% $288,000 $0 $288,000 $0 Owner's costs such as project management, advisory fees, legal, etc., are not included in the Control Cost Manual. Although it is possible that certain CCM-allowed costs are included in this line item, additional details would be needed to make that determination. Surcharge $460,800 16% $0 0% $460,800 $0 $460,800 $0 There is no provision for surcharge in the EPA Control Cost Manual AFUDC $345,600 12% $0 0% $345,600 $0 $345,600 $0 AFUDC is not allowed for any of the applications listed in the EPA Control Cost Manual Subtotal, ROFA Capital Cost $7,020,900 $5,926,500 $7,020,900 $5,926,500 $7,020,900 $5,926,500 Contingency $864,000 30% $432,000 15% $864,000 $432,000 $864,000 $432,000EPA Control Cost Manual provides for project contingency costs of up to 15% of the total of direct capital costs (DCC) and indirect installation costs. **Total ROFA Capital Cost $7,884,900**  **$6,358,500 $7,884,900**  **$6,358,500 $7,884,900**  **$6,358,500 Selective Catalytic Reduction (SCR)** 

Major Materials Design and Supply Construction $20,000,000 $20,000,000 $20,000,000 $20,000,000 $20,000,000 $20,000,000Vendor estimate. Comparable to Purchased Equipment Cost (PEC) as described in EPA CCM, although this line item description suggests it includes more than just PEC. See comments in ROFA above. Construction $0 0.0% $0 0% $0 $0 $0 $0 Balance of Plant $0 0.0% $0 0% $0 $0 $0 $0 Electrical (Allowance) $0 0.0% $0 0% $0 $0 $0 $0 Owner's Costs $2,000,000 10.0% $0 0% $2,000,000 $0 $2,000,000 $0 Owner's costs such as project management, advisory fees, legal, etc., are not included in the Control Cost Manual. Although it is possible that certain CCM-allowed costs are included in this line item, additional details would be needed to make that determination. Surcharge $3,200,000 16.0% $0 0% $3,200,000 $0 $3,200,000 $0 There is no provision for surcharge in the EPA Control Cost Manual AFUDC $2,400,000 12.0% $0 0% $2,400,000 $0 $2,400,000 $0 AFUDC is not allowed for SCR in the EPA Control Cost Manual, Section 4.2, Chap 2, Table 2.5 Subtotal, SCR Capital Cost $27,600,000 $20,000,000 $27,600,000 $20,000,000 $27,600,000 $20,000,000 Contingency $3,000,000 15% $3,000,00015%$3,000,000 $3,000,000 $3,000,000 $3,000,000EPA Control Cost Manual provides for project contingency costs of up to 15% of the total of direct capital costs (DCC) and indirect installation costs. **Total SCR Capital Cost $30,600,000**  **$23,000,000 $30,600,000**  **$23,000,000 $30,600,000**  **$23,000,000** 

### Total Capital Cost **$38,484,900 $29,358,500**  **$38,484,900 $29,358,500** **$38,484,900 $29,358,500** Zero estimate provided by NDEP. Based upon the documentation provided, it is unclear if these costs are accounted for elsewhere **Unit 1 Unit 2**  **Unit 3 NDEP**  **EPA Revised Cost**

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### Control Cost Comparison - SCR+ROFA

NDEP costs not allowed by EPA Control Cost Manual NDEP costs allowed by EPA Control Cost Manual, but modified from NDEP estimate

**NDEP EPA Revised**  **Cost NDEP**  **EPA Revised Cost**  **Value %**  **Value %**  **Comments**

**Unit 1 Unit 2**  **Unit 3 NDEP**  **EPA Revised Cost**



### Annual Costs **Fi xed O&M Costs** 

Operating Labor $0 $0 $0 $0 $0 $0 No estimate of additional operating labor was provided. Maintenance Materials $148,000 $148,000 $148,000 $148,000 $148,000 $148,000 Maintenance Labor $222,000 $222,000 $222,000 $222,000 $222,000 $222,000 Administrative Labor $0 $0 $0 $0 $0 $0 No estimate of additional administrative labor was provided. Subtotal, fixed O&M costs $370,000 $370,000 $370,000 $370,000 $370,000 $370,000 **Variable Costs**

Reagent $301,192 $301,192 $326,816 $326,816 $257,830 $257,830EPA CCM does provide for certain raw material costs such as reagent costs. Catalyst Replacement $112,500 $112,500 $112,500 $112,500 $132,000 $132,000The EPA Control Cost Manual does provide for SCR catalyst replacement costs. The basis for NDEP's estimate is not clear, however, and it is difficult to determine how catalyst costs determined using the CCM might compare. Auxiliary Power $529,500 $529,500 $578,755 $578,755 $560,284 $560,284The EPA Control Cost Manual does provide for utility costs, such as those needed to operate SCR equipment. Subtotal, variable costs $943,192 $943,192 $1,018,071 $1,018,071 $950,114 $950,114 Debt Service/Capital Recovery1 $4,066,737 $2,771,235 $4,066,737 $2,771,235 $4,066,737 $2,771,235Regarding interest rates, EPA calculated capital recoveries using 3% and 7% interest rates in determining cost effectiveness for the Regulatory Impact Analysis for the Final Clean Air Visibility rule and the Guidelines for BART Determinations under the Regional Haze regulations. The EPA Control Cost Manual uses 7% interest rate in SCR example calculations (Section 4-2, Chap 2, p2-57). In addition, the CCM also recommends a 20 year economic lifetime for SCR (p2-57), although 30 year lifetimes have often been specified in BART and BACT analyses. 

### Total Annual Costs $5,379,929 $4,084,427 $5,454,808$4,159,306$5,386,851$4,091,349

1) Debt Service/Capital Recovery

Interest rate (%) = 8.5% 7.0% Equipment lifetime (years) = 20 20 The EPA Control Cost Manual provides for maintenance materials and labor. These costs are included in the revised EPA estimate, although no basis was provided.

SCR+ROFA Page 2 of 2