Copyright © 1997 Global Compliance, LLC. A LL 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, p lease provide all input and output files and any resulting reports or summaries. b. Please identify any impediments to achieving 90% N Ox 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, p lease 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 p roposed.Copyright © 1997 Global Compliance, LLC. A LL 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 p ollution 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 ( N ortheastern), 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 p rovides 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.. N o cost estimates have been performedCopyright © 1997 Global Compliance, LLC. A LL 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