# Printed 4/16/2012



# Comparison of SCR Control Costs (Updated, 2011)

**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 $39,754,076 $30,443,946 $39,754,076 $30,443,946 $39,754,076 $30,443,946 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 $4,200,852 $2,873,693 $4,200,852 $2,873,693 $4,200,852 $2,873,693 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 $5,230,653 $3,903,494 $5,279,403 $3,952,244 $5,201,745 $3,874,586

NOx Removed from baseline (tpy) 1,850 1,850 2,010 2,009 1,774 1,775 Average Cost per ton ($/ton) $2,827 $2,110 $2,627 $1,967 $2,932 $2,183 Incremental Cost per ton ($/ton) $6,370 $4,534 $6,080 $4,330 $3,856 $2,756 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 ($) $491,140 $1,019,864 $1,448,604 $3,903,494 $4,447,126 Average Cost Effectiveness ($/ton) $1,017 $1,100 $1,107 $2,110 $2,404 Incremental Cost Effectiveness($/ton)

-- $1,191 $1,124 $4,534 $5,538 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 ($) $491,140 $1,042,273 $1,496,413 $3,952,244 $4,522,005 Average Cost Effectiveness ($/ton) $848 $998 $1,038 $1,967 $2,251 Incremental Cost Effectiveness($/ton)

-- $1,185 $1,141 $4,330 $5,334 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 ($) $491,140 $969,586 $1,378,220 $3,874,586 $4,454,048 Average Cost Effectiveness ($/ton) $3,284 $1,430 $1,586 $2,183 $2,510 Incremental Cost Effectiveness($/ton)

-- $906 $2,137 $2,756 $3,396 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 ($) $613,138$1,228,736 $1,778,147 $5,230,653$5,915,459 Average Cost Effectiveness3 

# ($/ton) $1,269 $1,325 $1,359 $2,827 $3,198
Incremental Cost Effectiveness3 

# ($/ton)

-- $1,386 $1,442 $6,370 $7,633
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 ($) $613,138$1,251,145 $1,825,956 $5,279,403$5,990,338 Average Cost Effectiveness3 

# ($/ton) $1,059 $1,198 $1,266 $2,627 $2,980
Incremental Cost Effectiveness3 

# ($/ton)

-- $1,372 $1,444 $6,080 $7,332
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 ($) $613,138$1,178,458 $1,707,763 $5,201,745$5,922,381 Average Cost Effectiveness3 

# ($/ton) $4,171 $1,738 $1,967 $2,932 $3,338
Incremental Cost Effectiveness3 

# ($/ton)

-- $1,065 $2,786 $3,856 $4,652
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 4/16/2012



### Control Cost Comparison - LNB+OFA (enhanced)

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 $1,814,842 $1,814,842 $1,814,842 $1,814,842 $1,814,842 $1,814,842Vendor 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 $1,270,38970%$1,270,38970%$1,270,389 $1,270,389 $1,270,389 $1,270,389Vendor 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 $907,421 50% $907,421 50% $907,421 $907,421 $907,421 $907,421Balance 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) $90,742 5% $90,742 5% $90,742 $90,742 $90,742 $90,742 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 $181,484 10% $0 0% $181,484 $0 $181,484 $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 $290,375 16% $0 0% $290,375 $0 $290,375 $0 There is no provision for surcharge in the EPA Control Cost Manual AFUDC $217,781 12% $0 0% $217,781 $0 $217,781 $0 AFUDC is not allowed for any of the applications listed in the EPA Control Cost Manual Subtotal, LNB+OFA Capital Cost$4,773,034 $4,083,395 $4,773,034 $4,083,395 $4,773,034 $4,083,395 Contingency $272,226 15% $272,226 15% $272,226 $272,226 $272,226 $272,226EPA Control Cost Manual provides for project contingency costs of up to 15% of the total of direct capital costs (DCC) and indirect installation costs. For example, Section 4.2 (NOx Post-Combustion), Tables 1.4 and 2.5 allow a project contingency of 15% for SNCR and SCR applications. **Total LNB+OFA Capital Cost $5,045,261**  **$4,355,621 $5,045,261**  **$4,355,621 $5,045,261**  **$4,355,621** 

### Total Capital Cost **$5,045,261 $4,355,621**  **$5,045,261 $4,355,621** **$5,045,261 $4,355,621**  **Unit 1 Unit 2**  **Unit 3 NDEP**  **EPA Revised Cost**

LNB+OFA Page 1 of 2Printed 4/16/2012



### Control Cost Comparison - LNB+OFA (enhanced)

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 $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 $533,138 $411,140 $533,138 $411,140 $533,138 $411,140Regarding 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 $613,138 $491,140 $613,138 $491,140 $613,138 $491,140

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 4/16/2012



### 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 $1,814,842 $1,814,842 $1,814,842 $1,814,842 $1,814,842 $1,814,842Vendor 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 $1,270,38970%$1,270,38970%$1,270,389 $1,270,389 $1,270,389 $1,270,389Vendor 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 $907,421 50% $907,421 50% $907,421 $907,421 $907,421 $907,421Balance 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) $90,742 5% $90,742 5% $90,742 $90,742 $90,742 $90,742 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 $181,484 10% $0 0% $181,484 $0 $181,484 $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 $290,375 16% $0 0% $290,375 $0 $290,375 $0 There is no provision for surcharge in the EPA Control Cost Manual AFUDC $217,781 12% $0 0% $217,781 $0 $217,781 $0 AFUDC is not allowed for any of the applications listed in the EPA Control Cost Manual Subtotal, LNB+OFA Capital Cost$4,773,034 $4,083,395 $4,773,034 $4,083,395 $4,773,034 $4,083,395 Contingency $272,226 15% $272,226 15% $272,226 $272,226 $272,226 $272,226EPA Control Cost Manual provides for project contingency costs of up to 15% of the total ofdirect capital costs (DCC) and indirect installation costs. For example, Section 4.2 (NOx PostCombustion), Tables 1.4 and 2.5 allow a project contingency of 15% for SNCR and SCR **Total LNB+OFA Capital Cost $5,045,261**  **$4,355,621 $5,045,261**  **$4,355,621 $5,045,261**  **$4,355,621 Selective Non-Catalytic Reduction (SNCR)** 

Major Materials Design and Supply Construction $1,531,273 $1,531,273 $1,531,273 $1,531,273 $1,531,273 $1,531,273Vendor 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 $229,691 15.0% $229,691 15% $229,691 $229,691 $229,691 $229,691 Balance of Plant $183,753 12.0% $183,753 12% $183,753 $183,753 $183,753 $183,753 Electrical (Allowance) $76,564 5.0% $76,564 5% $76,564 $76,564 $76,564 $76,564 Owner's Costs $153,127 10.0% $0 0% $153,127 $0 $153,127 $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 $245,004 16.0% $0 0% $245,004 $0 $245,004 $0 There is no provision for surcharge in the EPA Control Cost Manual AFUDC $183,753 12.0% $0 0% $183,753 $0 $183,753 $0 AFUDC is not allowed for SCR in the EPA Control Cost Manual Subtotal, SCR Capital Cost $2,603,164 $2,021,280 $2,603,164 $2,021,280 $2,603,164 $2,021,280 Contingency $229,691 15% $229,691 15% $229,691 $229,691 $229,691 $229,691EPA Control Cost Manual provides for project contingency costs of up to 15% of the total ofdirect capital costs (DCC) and indirect installation costs. For example, Section 4.2 (NOx PostCombustion), Tables 1.4 and 2.5 allow a project contingency of 15% for SNCR and SCR applications. **Total SNCR Capital Cost $2,832,855**  **$2,250,971 $2,832,855**  **$2,250,971 $2,832,855**  **$2,250,971** 

### Total Capital Cost **$7,878,116 $6,606,592**  **$7,878,116 $6,606,592** **$7,878,116 $6,606,592** 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 4/16/2012



### 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 $98,612 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 $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 $832,488 $623,616 $832,488 $623,616 $832,488 $623,616Regarding 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 $1,228,736 $1,019,864 $1,251,145$1,042,273$1,178,458$969,586

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 4/16/2012



## 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 $3,266,715 $3,266,715 $3,266,715 $3,266,715 $3,266,715 $3,266,715Vendor 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 $1,633,35850%$1,633,35850%$1,633,358 $1,633,358 $1,633,358 $1,633,358Balance 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) $980,015 30%$980,01530% $980,015 $980,015 $980,015 $980,015Electrical 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 $326,672 10% $0 0% $326,672 $0 $326,672 $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 $522,674 16% $0 0% $522,674 $0 $522,674 $0 There is no provision for surcharge in the EPA Control Cost Manual AFUDC $392,006 12% $0 0% $392,006 $0 $392,006 $0 AFUDC is not allowed for any of the applications listed in the EPA Control Cost Manual Subtotal, ROFA Capital Cost $7,863,939 $6,622,587 $7,863,939 $6,622,587 $7,863,939 $6,622,587 Contingency $980,015 30%$490,00715% $980,015 $490,007 $980,015 $490,007EPA Control Cost Manual provides for project contingency costs of up to 15% of the total of direct capital costs (DCC) and indirect installation costs. For example, Section 4.2 (NOx Post-Combustion), Tables 1.4 and 2.5 allow a project contingency of 15% for SNCR and SCR applications. **Total ROFA Capital Cost $8,843,953**  **$7,112,594 $8,843,953**  **$7,112,594 $8,843,953**  **$7,112,594 Rotamix** Major Materials Design and

Supply Construction $1,167,100 $1,167,100 $1,167,100 $1,167,100 $1,167,100 $1,167,100Vendor 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 $140,052 12.0%$140,05212% $140,052 $140,052 $140,052 $140,052Balance 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 $116,710 10.0% $0 0% $116,710 $0 $116,710 $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 $186,736 16.0% $0 0% $186,736 $0 $186,736 $0 There is no provision for surcharge in the EPA Control Cost Manual AFUDC $140,052 12.0% $0 0% $140,052 $0 $140,052 $0 AFUDC is not allowed for SNCR (comparable to Rotamix) in the EPA Control Cost Manual Subtotal, Rotamix Capital Cost $1,998,150 $1,554,652 $1,998,150 $1,554,652 $1,998,150 $1,554,652 Contingency $175,065 15%$175,06515% $175,065 $175,065 $175,065 $175,065EPA Control Cost Manual provides for project contingency costs of up to 15% of the total of direct capital costs (DCC) and indirect installation costs. For example, Section 4.2 (NOx Post-Combustion), Tables 1.4 and 2.5 allow a project contingency of 15% for SNCR and SCR applications. **Total Rotamix Capital Cost $2,173,215**  **$1,729,717 $2,173,215**  **$1,729,717 $2,173,215**  **$1,729,717** 

## Total Capital Cost **$11,017,168 $8,842,311**  **$11,017,168 $8,842,311** **$11,017,168 $8,842,311**  **Unit 1 Unit 2**  **Unit 3 NDEP**  **EPA Revised Cost**

ROFA+Rotamix Page 1 of 2Printed 4/16/2012



## 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 $1,164,195 $834,652 $1,164,195 $834,652 $1,164,195 $834,652Regarding 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 $1,778,147 $1,448,604 $1,825,956$1,496,413$1,707,763$1,378,220

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 4/16/2012



### 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 $1,814,842 $1,814,842 $1,814,842 $1,814,842 $1,814,842 $1,814,842Vendor 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 $1,270,389 70% $1,270,38970%$1,270,389 $1,270,389 $1,270,389 $1,270,389Vendor 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 $907,421 50% $907,421 50% $907,421 $907,421 $907,421 $907,421Balance 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) $90,742 5% $90,742 5% $90,742 $90,742 $90,742 $90,742 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 $181,484 10% $0 0% $181,484 $0 $181,484 $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 $290,375 16% $0 0% $290,375 $0 $290,375 $0 There is no provision for surcharge in the EPA Control Cost Manual AFUDC $217,781 12% $0 0% $217,781 $0 $217,781 $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 $4,773,034 $4,083,395 $4,773,034 $4,083,395 $4,773,034 $4,083,395 Contingency $272,226 15% $272,226 15% $272,226 $272,226 $272,226 $272,226EPA Control Cost Manual provides for project contingency costs of up to 15% of the total of directcapital costs (DCC) and indirect installation costs. For example, Section 4.2 (NOx PostCombustion), Tables 1.4 and 2.5 allow a project contingency of 15% for SNCR and SCR **Total ROFA Capital Cost $5,045,261**  **$4,355,621 $5,045,261**  **$4,355,621 $5,045,261**  **$4,355,621 Selective Catalytic Reduction (SCR)** 

Major Materials Design and Supply Construction $22,685,500 $22,685,500 $22,685,500 $22,685,500 $22,685,500 $22,685,500Vendor 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 $2,268,550 10.0% $0 0% $2,268,550 $0 $2,268,550 $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 $3,629,680 16.0% $0 0% $3,629,680 $0 $3,629,680 $0 There is no provision for surcharge in the EPA Control Cost Manual AFUDC $2,722,260 12.0% $0 0% $2,722,260 $0 $2,722,260 $0 AFUDC is not allowed for SCR in the EPA Control Cost Manual Subtotal, SCR Capital Cost $31,305,990 $22,685,500 $31,305,990 $22,685,500 $31,305,990 $22,685,500 Contingency $3,402,825 15% $3,402,82515%$3,402,825 $3,402,825 $3,402,825 $3,402,825EPA Control Cost Manual provides for project contingency costs of up to 15% of the total of directcapital costs (DCC) and indirect installation costs. For example, Section 4.2 (NOx PostCombustion), Tables 1.4 and 2.5 allow a project contingency of 15% for SNCR and SCR applications. **Total SCR Capital Cost $34,708,815**  **$26,088,325 $34,708,815**  **$26,088,325 $34,708,815**  **$26,088,325** 

### Total Capital Cost **$39,754,076 $30,443,946**  **$39,754,076 $30,443,946** **$39,754,076 $30,443,946** 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**

SCR+LNB+OFA Page 1 of 2Printed 4/16/2012



### 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**

**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 $4,200,852 $2,873,693 $4,200,852 $2,873,693 $4,200,852 $2,873,693Regarding 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 $5,230,653 $3,903,494 $5,279,403$3,952,244$5,201,745$3,874,586

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 $3,266,715 $3,266,715 $3,266,715 $3,266,715 $3,266,715 $3,266,715Vendor 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 $1,633,358 50% $1,633,35850%$1,633,358 $1,633,358 $1,633,358 $1,633,358Balance 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) $980,015 30% $980,015 30% $980,015 $980,015 $980,015 $980,015Electrical 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 $326,672 10% $0 0% $326,672 $0 $326,672 $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 $522,674 16% $0 0% $522,674 $0 $522,674 $0 There is no provision for surcharge in the EPA Control Cost Manual AFUDC $392,006 12% $0 0% $392,006 $0 $392,006 $0 AFUDC is not allowed for any of the applications listed in the EPA Control Cost Manual Subtotal, ROFA Capital Cost $7,863,939 $6,622,587 $7,863,939 $6,622,587 $7,863,939 $6,622,587 Contingency $980,015 30% $490,007 15% $980,015 $490,007 $980,015 $490,007EPA Control Cost Manual provides for project contingency costs of up to 15% of the total of directcapital costs (DCC) and indirect installation costs. For example, Section 4.2 (NOx PostCombustion), Tables 1.4 and 2.5 allow a project contingency of 15% for SNCR and SCR **Total ROFA Capital Cost $8,843,953**  **$7,112,594 $8,843,953**  **$7,112,594 $8,843,953**  **$7,112,594 Selective Catalytic Reduction (SCR)** 

Major Materials Design and Supply Construction $22,685,522 $22,685,522 $22,685,522 $22,685,522 $22,685,522 $22,685,522Vendor 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 $2,268,552 10.0% $0 0% $2,268,552 $0 $2,268,552 $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 $3,629,684 16.0% $0 0% $3,629,684 $0 $3,629,684 $0 There is no provision for surcharge in the EPA Control Cost Manual AFUDC $2,722,263 12.0% $0 0% $2,722,263 $0 $2,722,263 $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 $31,306,020 $22,685,522 $31,306,020 $22,685,522 $31,306,020 $22,685,522 Contingency $3,402,828 15% $3,402,82815%$3,402,828 $3,402,828 $3,402,828 $3,402,828EPA Control Cost Manual provides for project contingency costs of up to 15% of the total of directcapital costs (DCC) and indirect installation costs. For example, Section 4.2 (NOx PostCombustion), Tables 1.4 and 2.5 allow a project contingency of 15% for SNCR and SCR applications. **Total SCR Capital Cost $34,708,849**  **$26,088,350 $34,708,849**  **$26,088,350 $34,708,849**  **$26,088,350** 

### Total Capital Cost **$43,552,802 $33,200,945**  **$43,552,802 $33,200,945** **$43,552,802 $33,200,945** 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**

SCR+ROFA Page 1 of 2Printed 4/16/2012



### 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 $4,602,267 $3,133,934 $4,602,267 $3,133,934 $4,602,267 $3,133,934Regarding 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 $5,915,459 $4,447,126 $5,990,338$4,522,005$5,922,381$4,454,048

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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