### 5/20/15 CITY OF PHILADELPHIA Department of Public Health
Environmental Protection Division Air Management Services



### InterOffice Memo

To: File

From: Edward Wiener & Kassahun Sellassie

Date: May 20, 2015
Subject: 1997 8-Hour RACT Analysis for Veolia Energy – Schuylkill Station.

Introduction:

The Clean Air Act (CAA) requires that moderate (or worse) ozone nonattainment areas implement reasonably available control technology (RACT) controls on all major sources of Volatile Organic Compounds (VOC) and Nitrogen Oxides (NOx). Philadelphia County is part of the Philadelphia-Wilmington-Atlantic City moderate ozone nonattainment area for the 1997 8-hour ozone NAAQS. This document presents the findings of the reevaluation of NOx RACT for the 1997 8-hour ozone standard for this facility

Company Description:

Veolia Energy Philadelphia - Schuylkill Station (Veolia – Schuylkill) owns and operates a steam generating facility in 2600 Christian Street, Philadelphia, PA 19146. Equipm ent used at the facility includes three (3) boilers. The facility was named Trigen Philadelphia Energy Company, but adopted the name of its parent company Veolia Energy Philadelphia in December 2000.

Applicability for NOx and VOC RACT:

In addition to owning Veolia – Schuylkill, Veolia is part owner of the Veolia Energy Efficiency PA (LLC), a steam generating facility, and Grays Ferry Cogeneration Partners hip (GFCP), an electric generating facility, all facilities adjacently located at 2600 Christian Street, Philadelphia, PA 19146. The three facilities have been determined a single source since Plan Approval Application No. 10277 was submitted for the new Veolia Energy Efficiency boilers on October 25, 2010. The three facilities as a sing le source are major for NOx, due to having potential NOx emissions greater than 100 tons per year, the major source threshold in Philadelphia County that is applicable to NOx RACT for the 1997 8-hour ozone NAAQS. The three facilities as a single source are not major for VOC, due to having potential VOC emissions not greater than 50 tons per year, the major source threshold in Philadelphia County that is applicable to NOx RACT for the 1997 8-ho ur ozone. Veolia Schuylkill is subject to 1-hour ozone RACT, as approved into the SIP by EPA on December 15, 2 000 (65 FR 78418), and is being evaluated for 1997 8- hour ozone RACT as documented in this memo. RACT determinations for GFCP and Veolia Energy Efficiency have been provided in separate memos.

Process Descriptions:

Veolia - Schuylkill Station currently has two (2) tange ntial-fired boilers rated 795 MMBTU/hr (CU02 and CU01- Boilers No. 23 and No. 24) and one (1) front wall-fired boiler rated 761 MMBTU/hr (CU05-Boiler No. 26). Each boiler burns No. 6 oil as the primary fuel. Boilers No. 23 and No. 24 both burn No. 2 oil as the ignition fuel.

These boilers do not operate at maximum capacity for 365 days per year. The boilers at Schuylkill Station operate seasonally and predominately su pply district steam heat as such the boilers operate at peak capacity in the non-ozone season and operate minimally or not at all during ozone season

. See emissions inventories in Appendix.

NOx RACT Evaluation:Veolia Schuylkill’s three boilers, Boiler #23, #24, and 26, are subject to 1-hour RACT. As a result of AMS case-bycase-RACT determination, the facility is subject to a RA CT Plan Approval (PA Permit Number 51-04942) issued on December 1, 1999 and approved into the SIP by EPA on December 15, 2 000 (65 FR 78418). In the 1-hour RACT Plan Approval, the boilers were given a combined No. 6 oil limit of 65,526,316 gallons per rolling 12-month period and a combined NOx emissions limit of 1,646 tons in any rolling 12-month period

. Also, Boilers No. 23 and No. 24 each were given NOx emission limits of 0.35 pounds per MMBTU. Boiler No. 26 was required to have low NOx burners (LNB) installed and was given a NOx emission limit of 0.36 pounds per MMBTU on a 30-day rolling average.

Boiler No. 24 was shut down in January 2014 as part of Plan Approval No. 10277 and thus is not being re-evaluated
for RACT.

The following were considered possible NOx controls for Boilers #23 and #26: (1) Selective Catalytic Reduction (SCR), (2) Ultra Low-NOx Burners and switch to natura l gas (ULNB with NG), (3) Selective Non-Catalytic Reduction (SNCR), (4) Flue Gas Recirculation (FGR), (5) Low NOx Burner (LNB) without switching fuel type, (6) Ultra Low NOx Burners (ULNB), and (7) Burners Out of Service (BOOS) and other combustion modifications.

The following were determined technologically infeasible for all boilers: Burners-out-of-service and other combustion modifications were determined technologically infeasible for both boilers because they would cause a reduction in boiler capacity, which could cause issues durin g peak periods. Selective Non-Catalytic Reduction was determined to be technologically infeasible for both boilers because the boilers have frequent load changes and periods of low load operation.

ULNB are burners designed to create a larger, lower te mperature flame. They wo uld reduce NOx emissions by around 30% for Boiler #23 and around 12.3% for Boiler #26 (the reduction for Boiler #26 is lower because it was
modified with Low-NOx Burners as a re sult of the 1 hr case-by-case RACT).

LNB are burners designed to create a larger, lower temp erature flame. They woul d reduce NOx emissions by around 20% for Boiler #23. Boiler #26 was modified with Low-NOx Burners as a result of the 1 hr case-by-case
RACT.

FGR takes some of the exhaust gas from the stack and ducts it to the burner. It lowers peak flame temperatures and lowers the oxygen content of the air. FGR is determined technologically in feasible for Boiler No. 23 due to space limitations. NOx emissions from Boiler No. 26 are expected to be reduced by around 40 % with this technology.

ULNB with NG are ULNB that are accompanied by a switch from oil to natural gas. They reduce NOx emissions by around 57.2% for Boiler #23 and around 34.4% for Boiler #26 (the reduction is greater than ULNB alone due to the switch from oil to lower emitting natural gas, Boiler #26 has a lower reduction because it has Low-NOx Burners from the 1 hr case-by-case RACT).

SCR injects ammonia upstream of a cat alyst. NOx, ammonia (NH3), and oxyg en (O2) react on the surface of the catalyst to form nitrogen (N2) and water (H20). NOx emissions are reduced by around 80%. SCR is determined technologically infeasible for Boiler No. 23 due to space limitations.

Boiler No. 23 has a NOx emission limit of 0.35 lbs/MMBTU from the 1-hour RACT determination. This limit is being reduced to 0.34 lb/MMBTU, based on stack test data. , Additionally, under the facility’s Title V/State Operating Permit No. V11-014 issued May 24, 2012 (Section D. 2 (b)(3)), the boiler is restricted to operate up to 30% of its hourly heat input capacity on an annual basis. This heat input limit is Federally enforceable and thus considered in this RACT analysis.

The following NOx controls were determined technologically feasible for Boilers No. 23 and No. 26. A summary of cost effectiveness is provided below. The RACT baseline NOx emissions for Boiler No. 23 are 355.15 tons per year based on the applicable capacity factor of 30% and revised NOx emissions rate[795 mmbtu/hr *8760 hr/yr * 0.34 lb/mmbtu *0.3= 355.15 tons per year]. The RACT baselin e emissions for Boiler No. 26 are 1199.9 tons per year and was determined based on the rated capacity of 761 MMBTU/hr, 8,760 hours per year, and the 0.36 lbs/MMBTU
NOx emission limit from the 1-hour RACT determination.

For more detailed calculations, please see the Appendix.Source Control Technology Baseline NOx Emissions (tons per year) NOx
Reduction (%) NOx
Reduction (tpy) Total Annualized Cost ($/year) Cost
Effectiveness ($/Ton) Schuylkill
Boiler #23 ULNB 355.15 30 106.54 1,049,236 9,848 LNB 355.15 20 71.03 986,193 13,884 ULNB with NG 315.15 57.2 203.14 1,972,937 9,712 Schuylkill
Boiler #26 ULNB 1199.9 12.3 147.59 653,905 4,431 ULNB with NG 1199.9 34.4 412.77 1,552,809 3,762 FGR 1199.9 40 479.96 1,357,452 2,828 SCR 1199.9 80 959.92 3,342,088 3,482

All of these control options have been determined ec onomically unreasonable. Additionally, these boilers seldom operate during the ozone season, as noted in the Appendix . Actual NOx emissions for each boiler are a fraction of the potential emissions listed above.

Although no additional RACT controls are reasonable for Boiler #23, the existing 30% capacity factor limit is more stringent than the current SIP-approved RACT limit on an annual basis. Thus, to further reduce NOx emissions AMS is proposing to incorporate as RACT 355.15 tons per 12-month rolling NOx emissions limit based on the 30% capacity factor for Boilers # 23. Additionally, after ev aluating public comments, the boiler is being given an additional 270.30 lbs/hr limit, which corresponds to the lbs/MMBTU limit and capacity.

Currently allowed RACT emissions for Boiler #23: 1,183.8 tons per rolling of 12 months Proposed allowed RACT emissions for Boiler #23: 355.15 tons per rolling of 12 months

AMS finds that the existing RACT limits for Boiler No. 26 continue to represent RACT. After evaluating public comments, Boiler No 26 is being given additional 0.41 lbs/MMBTU and 312.01 lbs/hr limits, both on an hourly basis, so there are additional shorter-term limits. AMS determined the bo iler could achieve these shorter term limits under existing technology based on CEM data.

By taking the heat input restriction on Boiler #23, the total potential emissions from Boilers #23 and #26 (1,555.1 tons per year) are less than the 1-hour RACT combined emissions limit of 1,646 tons in any rolling 12-month period. AMS is proposing to remove the 1,646 tons per year limit.

With the removal of Boiler #24 and the 30% capacity factor restriction on Boiler #23, the combined potential #6 oil usage for Boilers #23 and #26 is 58,370,800 gallons per rolling 12-month period (based on the rated capacities, 8,760 hrs/yr, 0.15 MMBTU/gal of No. 6 oil, and a 30% capac ity factor for Boiler #23). Since this is lower than the existing combined No. 6 oil limit of 65,526,316 gallons per rolling 12-month period, the existing limit is being
removed.

Conclusions and Recommendations:

AMS is determining the 365.6 tons of NOx per rolling 12-month period emission limit for Boiler #23 as an additional RACT requirement. AMS requests this limit to be approved into the SIP. Also, AMS requests to remove the combined NOx emissions limit and the combined No. 6 oil usage limit for Boilers 23 and 26. AMS recommends that these updates to the NOx RACT requirements curren tly approved in the SIP for the 1-hour ozone standard represent NOx RACT for the 1997 8-hour ozone standard for Veolia Schuylkill.

The following requirements are recommended as RACT:

- Boiler No. 23 NOx emission shall not exceed 0.34 pounds per MMBTU and 355.15 tons of NOx per rolling 12-month period.

- Boiler No. 26 is required to have low NOx burners (LNB). Its NO x emissions shall not exceed 0.36 pounds per MMBTU on a 30-day rolling average. Boiler No 26 was given the additional NOx limits of 0.41 lbs/MMBTU on an hourly basis and 312.01 lbs/hr on an hourly basis.

- Compliance shall be monitored and recorded based on annual NOx stack tests for each boiler
and NOx CEMS for Boiler #26.- Compliance shall be monitored and recorded based on annual NOx stack tests for each boiler and NOx CEMS for Boiler#26. The facility shall monito r and record compliance with them based on daily hours of operation, fuel ty pe, fuel usage, fuel sulf ur content for each boiler, and NOX CEMs for boiler #26 and annual stack test for Boiler #23 compliance with them based on fuel usage and the annual NOx stack

tests

5 / 2 0 / 1 5

Edward Wiener, Chief of Source Registration Date



## Appendix

Ozone Season Emission Inventory for Veolia Schuylkill Boiler #26 & Boiler 23 combined that indicated that during ozone season the emissions are zero (0) and yearly emissions combined two boilers #23 & #26 is 5.36 tpy in April, 2013. Based on emission data, the bo iler #26 which has LNB doesn’t need to install SCR or
other control device.

Year of Inventory Month of Inventory NOx Emissions (tons)



### 2011 April 17.85

2011 May 0.00

2011 June 0.10

2011 July 0.00

2011 August 0.00

2011 September 0.35

2011 October 12.24

2012 April 9.32

2012 May 0.00

2012 June 0.00

2012 July 0.39

2012 August 0.00

2012 September 1.09

2012 October 0.05

2013 April 5.36

2013 May 0.00

2013 June 0.05

2013 July 0.00

2013 August 0.00

2013 September 0.00

2013 October 0.00

Detailed Calculations Summary The following costs are calculated in order to evaluate the cost eff ectiveness of each emission control technology:‐ Total Capital Investment (TCI)

‐ NOx Emission Reduction (tons/yr)

‐ Cost Effectiveness ($/ton)

‐ Capital Recovery = Convert from P (present) to A(Annual amount), A=P(A/P,i%,n),



### 1 ) 1 ( ) 1 (

  


n n



### i i i CR 20% interest and 10 yrs = A/P=0.2385; Annual Cost = TCI x CRF



### For the Catalyst , The catalyst life is 5 years. The annual cost is given by th e sinking fund factor, the amount of money the facility will need to set aside each year to be able to replace the catalyst at the end of its life, based on the lifespan of the catalyst and the interest rate. Sinking Fund Factor (SFF) = Convert from F (Futur e) to A(Annual amount), A=F(A/F,i%,n),



### 1 ) 1 (



 

n 

### i i SFF 10% interest and 5 yrs = A/F=0.1638

Where i= Annual interest Rate (10%); n= catalyst system life (5 years);

Catalyst Annual Cost = SFF x Catalyst Cost

Ammonia Cost

2NH 3 

### + 2NO + 1/2O 2 

### 2N 2 

### + 3H 2 

### O

Ammonia Cost = (17/30 * 2moles of NH 3 /2 moles of NO *1.05 * NOx emission (tpy) *$410/ton)

NH 3 = Ammonia, NO = Nitric Oxide; O 2 = Oxygen; H 2 O = Water; 1.05= Ammonia slip and excess ammonia

## Veolia - Schuylkill Boiler #23

Table 1 Detail Calculations for Veolia - Schuylkill Boiler for ULNB with NG



### Veolia SCH Boiler # 23 Factors used CF=30% Summer time no NOx emission or very low NOx <1 tpy

Boiler Capacity 795 MMBTU/hr
Total capital Cost
Total Capital Investment Cost (TCI) $6,585,800 TCI from 1 hour RACT Proposal plus inflation adjustment. Original TCI includes equipment and installation cost estimates
from ABB Power Plan Service Sales and JACA Corp 4

. Capital Recovery $1,570,713 0.2385 10 yrs @20% from 1 hr RACT; A/P=0.2385

Annual Operating Costs

Direct Annual Cost
Electricity Cost 2 $70,080 100kw @ $0.08/kwh, 8760 hrs/yr

Operator 3 $16,425 0.5hr/shift, 3 shift/day, $30/hr

Supervisor 3 $2,463.75 15% of Operator

Maintenance 3 $19,162.50 0.5hr/shift, 3 shift/day, $35/hr

Material 3 $19,162.50 100% of Maintenance

Total Direct Annual Cost $127,294

Indirect Annual Cost

Overhead 3 $11,498 60% of maintenance-OAQPS 1

Administrative Charge $131,716 2% of TCI-OAQPS 1

Property Taxes 3 $65,858 1% of TCI-OAQPS 1

Insurance 3 $65,858 1% of TCI-OAQPS 1

Total Indirect Annual Cost $274,930

Total Annual Operating Costs $1,972,937

NOx Baseline Emissions (TPY) 355.15 Based on 795 mmbtu/hr, 8760 hr/yr , 0.34 lb/mmbtu RACT limit, and 0.3 capacity
factor NOx Emission Reduction (TPY) 203.14 Based on 57.2 % of NOx removed.Cost Effectiveness ($/ton NOx removed) $9,712Table 2 Detail Calculations for Veolia Schuylkill Boiler ULNB



### Veolia SCH Boiler # 23 Factors used CF=30% Summer time no NOx emission or very low NOx <1 tpy

Boiler Capacity 795 mmbtu/hr
Total capital Cost
Total Capital Investment Cost (TCI) $3,269,100 TCI from 1 hr RACT proposal plus inflation adjustment. Original TCI includes equipment and
installation cost estimates from ABB Power Plan Service Sales and JACA Corp.

Capital Recovery $779,680 0.2385 10 yrs @20% -from 1-hr RACT ; A/P=0.2385 Annual Operating Costs

Direct Annual Cost
Electricity Cost $70,080 100kw @ $0.08/kwh, 8760 hrs/yr

Operator $16,425 0.5hr/shift, 3 shift/day, $30/hr
Supervisor $2,463.75 15% of Operator

Maintenance $19,162.50 0.5hr/shift, 3 shift/day, $35/hr

Material $19,162.50 100% of Maintenance

Total Direct Annual Cost $127,294

Indirect Annual Cost

Overhead $11,498 60% of maintenance-OAQPS
Administrative Charge $65,382 2% of TCI-OAQPS 1

Property Taxes $32,691 1% of TCI-OAQPS 1

Insurance $32,691 1% of TCI-OAQPS 1

Total Indirect Annual Cost $142,262

Total Annual Operating
Costs $1,049,236

NOx Baseline Emissions (TPY) 355.15 Based on 795 mmbtu/hr, 8760 hr/yr , 0.34 lb/mmbtu RACT limit, and 0.3 capacity factor
NOx Emission Reduction (TPY) 106.54 Based on 30 % of NOx removed.

Cost Effectiveness ($/ton NOx removed) $9,848Table 3 Detail Calculations for Veolia Schuylkill Boiler LNB



### Veolia SCH Boiler # 23 Factors used CF=30% Summer time no NOx emission or very low NOx <1 tpy

Boiler #23 Capacity 795 MMBTU/hr
Total capital Cost

LNB is 2-5% less in TCI than ULNB EPA 454/R-94- 0022; NOx Control report, Northeast States for Coordinated Air Use Management, Dec 2000(NESCAUM)

Total Capital Investment Cost (TCI) $3,105,645 TCI from 1-hr RACT proposal plus inflation adjustment. Original TCI includes equipment cost estimates from vendor-supplied estimates for similar units or industry data gathered for similar projects.

Capital Recovery $740,696 0.2385 10 yrs @20% -from 1 hr RACT

Annual Operating Costs

Direct Annual Cost

Electricity Cost $52,560 75kw @ $0.08/kwh, 8760 hrs/yr

Operator $16,425 0.5hr/shift, 3 shift/day, $30/hr

Supervisor $2,463.75 15% of Operator

Maintenance $19,162.50 0.5hr/shift, 3 shift/day, $35/hr

Material $19,162.50 100% of Maintenance

Total Direct Annual Cost $109,774

Indirect Annual Cost
Overhead $11,498 60% of maintenance-OAQPS 1

Administrative Charge $62,113 2% of TCI-OAQPS 1

Property Taxes $31,056 1% of TCI-OAQPS 1

Insurance $31,056 1% of TCI-OAQPS 1

Total Indirect Annual Cost $135,723

Total Annual Operating
Costs $986,193

NOx Baseline Emissions (TPY) 355.15 Based on 795 mmbtu/hr, 8760 hr/yr , 0.34 lb/mmbtu RACT limit, and 0. 3 capacity factor
NOx Emission Reduction (TPY) 71.03 Based on 20 % of NOx removed.

Cost Effectiveness ($/ton NOx removed) $13,884

## Veolia - Schuylkill Boiler #26

Table 4 Detail Calculations for Veolia - Schuylkill Boiler for SCR



### Grays ferry Factors used

761 MMBTU/hr Total capital Cost

Total Capital
Investment Cost (TCI) $6,385,200 Based EPA Cost Control Manual of $6000/MMBTU/Hr. Escalate 1997 $ using
the Marshall and swift Index.

Capital Recovery $1,020,355 0.1598 20 yrs @15% -from 1-hr RACT Annual Operating
Costs
Direct Annual Cost
Electricity Cost 2 $70,080 100kw @ $0.08/kwh, 8760 hrs/yr (PA DEP RACT State Implemen tation Plan (SIP) revision, Sep, 2006, page 18)

Maintenance 3 $95,778.00 1.5%x TCI

Catalyst cost 3 $190,000 0.1638 $190,000 total catalyst from litrature and
vendors
Sinking Fund Factor year 5, interest10%= A/F=0.1638
Total catalyst Replacement Cost 3 $31,122

Ammonia cost 3 $453,709 (17/30 * 1.05 * 2 mole NH3/2 mole NO *NOx emission (1199.9tpy) *$410/ton*5yr*1.55

Total Direct Annual
Cost $650,689

Indirect Annual
Cost 3 $1,020,355 Capital Recovery

Total Annual Cost $1,671,044

Total Annual Operating Costs $3,342,088

NOx Emission Reduction (TPY) 959.92

Cost Effectiveness ($/ton NOx removed) $3,482Table 5 Detail Calculations for Veolia Schuylkill Boiler FGR



### Veolia SCH Boiler # 26 No Factors used but Summer time no NOx emission or very low NOx <1 tpy
Boiler Capacity 761 MMBTU/hr
Total capital Cost

Total Capital Investment Cost (TCI) $4,375,800 TCI from 1 hr RACT proposal plus inflation adjustment. Original TCI includes equipment and
installation cost estimates from Sierra Environmental Engineering, Inc.

Capital Recovery $1,043,628 0.2385 10 yrs @20% -from 1-hr RACT; ; A/P=0.2385
Annual Operating Costs

Direct Annual Cost

Electricity Cost $70,080 100kw @ $0.08/kwh, 8760 hrs/yr

Operator $16,425 0.5hr/shift, 3 shift/day, $30/hr

Supervisor $2,463.75 15% of Operator

Maintenance $19,162.50 0.5hr/shift, 3 shift/day, $35/hr

Material $19,162.50 100% of Maintenance

Total Direct Annual Cost $127,294

Indirect Annual Cost

Overhead $11,498 60% of maintenance-OAQPS 1

Administrative Charge $87,516 2% of TCI-OAQPS 1

Property Taxes $43,758 1% of TCI-OAQPS 1

Insurance $43,758 1% of TCI-OAQPS 1

Total Indirect Annual Cost $186,530

Total Annual Operating
Costs $1,357,452 761 mmbtu/hr *8760 hr/yr * 0.36 lb/mmbtu

NOx Baseline Emissions (TPY) 1199.9 Based on 761 mmbtu/hr, 8760 hr/yr, and 0.36
lb/mmbtu RACT limit
NOx Emission Reduction (TPY) 479.96 Based on 40 % of NOx removed.

Cost Effectiveness ($/ton NOx removed) 2,828Table 6 Detail Calculations for Veolia Schuylkill Boiler ULNB with NG



### Veolia SCH Boiler # 26 No Factors used but Summer time no NOx emission or very low NOx <1 tpy

Boiler Capacity 761 MMBTU/hr
Total capital Cost

Total Capital Investment Cost (TCI) $5,077,264 TCI from 1 hr RACT proposal plus inflation adjustment. Original TCI includes equipment
and installation cost estimates from Sierra Environmental Engineering, Inc.; A/P=0.2385
Capital Recovery $1,210,927 0.2385 10 yrs @20% -from 1-hr RACT Annual Operating Costs

Direct Annual Cost
Electricity Cost $70,080 75kw @ $0.08/kwh, 8760 hrs/

Operator $16,425 0.5hr/shift, 3 shift/day, $30/hr
Supervisor $2,463.75 15% of Operator
Maintenance $19,162.50 0.5hr/shift, 3 shift/day, $35/hr

Material $19,162.50 100% of Maintenance

Total Direct Annual Cost $127,294

Indirect Annual Cost
Overhead $11,498 60% of maintenance-OAQPS 1

Administrative Charge $101,545 2% of TCI-OAQPS 1

Property Taxes $50,773 1% of TCI-OAQPS 1

Insurance $50,773 1% of TCI-OAQPS 1

Total Indirect Annual Cost $214,588

Total Annual Operating
Costs $1,552,809

NOx Baseline Emissions (TPY) 1199.9 Based on 761 mmbtu/hr, 8760 hr/yr, and 0.36
lb/mmbtu RACT limit
NOx Emission Reduction (TPY) 412.77 Based on 34.4 % of NOx removed.

Cost Effectiveness ($/ton NOx removed) $3,762Table 7 Detail Calculations for Veolia Schuylkill Boiler ULNB



### Veolia SCH Boiler # 26 No Factors used but Summer time no NOx emission or very low NOx <1 tpy

Boiler Capacity 761 MMBTU/hr
Total capital Cost
Total Capital Investment Cost (TCI) $1,849,600 TCI from 1 hr RACT proposal plus inflation adjustment. Original TCI includes equipment
and installation cost estimates from Sierra Environmental Engineering, Inc.

Annual Operating Costs

Direct Annual Cost
Electricity Cost $70,080 75kw @ $0.08/kwh, 8760 hrs/yr

Operator $16,425 0.5hr/shift, 3 shift/day, $30/hr
Supervisor $2,463.75 15% of Operator
Maintenance $19,162.50 0.5hr/shift, 3 shift/day, $35/hr

Material $19,162.50 100% of Maintenance

Total Direct Annual Cost $127,294

Indirect Annual Cost
Overhead $11,498 60% of maintenance-OAQPS 1

Administrative Charge $36,992 2% of TCI-OAQPS 1

Property Taxes $18,496 1% of TCI-OAQPS 1

Insurance $18,496 1% of TCI-OAQPS 1

Capital Recovery $441,130 0.2385 10 yrs @20% -from 1-hr RACT Total Indirect Annual Cost $526,611

Total Annual Operating
Costs $653,905

NOx Baseline Emissions (TPY) 1199.9 Based on 761 mmbtu/hr, 8760 hr/yr, and
0.36 lb/mmbtu RACT limit
NOx Emission Reduction (TPY) 147.59 Based on 12.3 % of NOx removed.

Cost Effectiveness ($/ton NOx removed) $4,431



## References

1. Office of Air Quality Planning and standards ( OAQPS) Environmental Protection Agency (EPA) Air Pollution Control Manual, Six Edition, EPA/452/B-02-001, January 2002.

2. Electricity cost: EPA cost calculation, Appendix A-NOx Control Analysis

3. North East States for Coordinated Air Use Management (NESCAUM)

4. http://new.abb.com/power-generation