Copyright © 1997 Global Compliance, LLC. ALL RIGHTS RESERVED.

Basics

Case No: 12-008-U - Flint Creek Retrofit Date Entered: 03/27/2012 09:30:33 AM

Party/Requestor: Sierra Club, Jeff Speir Date Received: 03/26/2012

Date Requested: 03/26/2012 Internal Due Date: 04/03/2012

Service Due Date: 04/11/2012

Answer Status: New Service Date:

Question No: 1-043

The Weaver direct testimony discusses the prospect that future NAAQS could potentially 

require installation of an SCR system to meet NOx or ozone emission requirements. 

Consequently, for purposes of the Flint Creek disposition alternative modeling, 

SWEPCO conservatively assumed that installation of an SCR system would not be 

required until at least 2020. (Table 5 at p. 24.)

a. Has the Company performed any NOx NAAQS modeling for Flint Creek? If yes, 

please provide all input and output files and any resulting reports or summaries.

b. Please identify any impediments to achieving 90% NOx control at Flint Creek 

using SCR both with and without LNB/OFA.

c. Please specify NOx emission levels that can be achieved with an SCR system at 

Flint Creek both with and without LNB/OFA. 

d. Please identify any impediments at Flint Creek to achieving the same NOx 

emission level currently being achieved at the W.A. Parish Electric Generating Station 

units burning a similar coal and required in the New Mexico FIP for the San Juan 

Generating Station, i.e., 0.05 lb/MMBtu on a 30-day rolling boiler operating day basis.

e. Do you anticipate any improvements in the SCR technology over the next eight 

years that might improve expected performance? These might include, for example, 

longer guaranteed catalyst lifetimes from improved catalyst formulations and longer 

operating experience, or improvements in NH3 mixing technology. Please identify any 

such improvements that you anticipate, including those that are at an early stage of 

research and development. Please also discuss their effect on the performance of an SCR 

at Flint Creek.

f. Given the assumed feasibility of an SCR for Flint Creek, please discuss why NOx 

removal with an SCR would not be considered BART, if CSAPR in its current form is 

not upheld by the D.C. Circuit Court of Appeals, or if EPA’s proposed rule that CSAPR 

compliance achieves visibility improvements better than BART is not finalized as 

proposed. 
Copyright © 1997 Global Compliance, LLC. ALL RIGHTS RESERVED.

g. Please provide cost estimates for your Option 1 analysis assuming installation of 

an SCR system concurrent with the proposed emission controls for purposes of meeting 

the requirements of the Arkansas Regional Haze SIP and MATS instead of installation in 

2020. (See Option #1B at p. 51.)

h. Would installation of SCR eight years after designing and installing the other 

pollution controls result in increased costs, e.g., separate mobilization, separate 

contracting, separate design teams, access issues requiring larger cranes, additional 

outages, losses in volume discounts, inflation, etc. Please identify and quantify any such 

additional costs that would accrue from 2020 or later installation of the SCR.

Answer:

a. Please see Sierra Club 1-43a, Attachments 1 and 2 for internal reports and summaries. 

A CD is provided under separate mailing for the DFGD Modeling input, output, and 

analysis files. 

b. Currently, an SCR is not planned for Flint Creek. As a result, the design work 

required to respond to this request is not available.

c. Currently, an SCR is not planned for Flint Creek. As a result, the design work required 

to respond to this request is not available.

d. Currently, an SCR is not planned for Flint Creek. As a result, the design work 

required to respond to this request is not available.

e. Currently, an SCR is not planned for Flint Creek. As a result, the design work required 

to respond to this request is not available.

f. BART is identified by conducting a 5-step analysis which has not yet been completed 

for Flint Creek. 

Based on a 5-step analysis for a similar AEP facility in Oklahoma (Northeastern), BART 

was identified to be LNB/OFA and SCR was rejected as not being a cost-effective 

technology under the Regional Haze Rule. EPA upheld that conclusion in approving the 

Oklahoma Regional Haze SIP portion for NOx controls. SWEPCO believes that the 

5-factor analysis for Flint Creek will provide a similar conclusion relative to SCR.

g. The cost estimates for Option #1B would be the same as those for Option 1 with the 

exception of the cost amounts and timing of the installation of the SCR system. 

Attachment 1 provides the nominal and 2011 dollar cost estimates for the SCR in the 

same format as presented in the supporting calculations for Table 6 (p. 37) of the Weaver 

direct testimony.

h. Yes. However, an SCR installation is not currently planned at Flint Creek; therefore, 

detailed cost estimating has not been performed.. No cost estimates have been performed 
Copyright © 1997 Global Compliance, LLC. ALL RIGHTS RESERVED.

for the potential installation of an SCR at the Flint Creek plant.

Advanced

Date Verified: Date Accepted:

Confidential: No

Yes

Attachments:

Sierra Club 1-43g Attachment 1.xls

Voluminous: No

Yes

Highly Sensitive: No

Yes

Comments:

Preparer(s): Bruce W Moore; Christian T Beam; David W 

Toalson; Edward J Locigno; John C Hendricks; John F 

Torpey; Kristen P Gaus; Mark A Becker; Michael L Wilkinson; 

Scott C Weaver; Twana Banks-Smith; William E Mast; William 

K Castle

Witness: 

Modification History

Created by Twana Banks-Smith Created on 03/30/2012 04:28:53 PM Modified on 04/24/2012 03:38:35 PM

Edit History

18. Twana Banks-Smith 04/24/2012 03:38:26 PM

17. Henry C Steele 04/24/2012 08:59:06 AM

16. Henry C Steele 04/24/2012 08:59:01 AM