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 Input1

(MMBtu/yr)

Unit 1 9,818,313

Unit 2 10,501,749

Unit 3 10,063,851

Unit No. Parameter Units Baseline2LNB+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+OFA LNB+OFA+SNCR ROFA+Rotamix ROFA+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+OFA LNB+OFA+SNCR ROFA+Rotamix ROFA+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+OFA LNB+OFA+SNCR ROFA+Rotamix ROFA+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 Input1

(MMBtu/yr)

Unit 1 9,818,313

Unit 2 10,501,749

Unit 3 10,063,851

Unit No. Parameter Units Baseline2LNB+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 3
Printed 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 $1,814,842 Vendor 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 $1,270,389 70% $1,270,389 70% $1,270,389 $1,270,389 $1,270,389 $1,270,389 Vendor 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 $907,421 Balance 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 $272,226 EPA 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 2
Printed 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 $411,140 Regarding 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 2
Printed 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 $1,814,842 Vendor 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 $1,270,389 70% $1,270,389 70% $1,270,389 $1,270,389 $1,270,389 $1,270,389 Vendor 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 $907,421 Balance 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 $272,226 EPA 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 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 $1,531,273 Vendor 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 

Construction ROFA above. $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 $229,691 EPA 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 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 2
Printed 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 $623,616 Regarding 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 2
Printed 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 $3,266,715 Vendor 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 $742,500 Vendor 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% $1,633,358 50% $1,633,358 $1,633,358 $1,633,358 $1,633,358 Balance 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 $980,015 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 $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 $490,007 EPA 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 $1,167,100 Vendor 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 $247,500 Vendor 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% $140,052 12% $140,052 $140,052 $140,052 $140,052 Balance 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% $175,065 15% $175,065 $175,065 $175,065 $175,065 EPA 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 2
Printed 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 $126,347 EPA 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 $297,221 The 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 $834,652 Regarding 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 2
Printed 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 $1,814,842 Vendor 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% $1,270,389 70% $1,270,389 $1,270,389 $1,270,389 $1,270,389 Vendor 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 $907,421 Balance 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 $272,226 EPA 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 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 $22,685,500 Vendor 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 

Construction above. $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% $3,402,825 15% $3,402,825 $3,402,825 $3,402,825 $3,402,825 EPA 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 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 2
Printed 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

Fixed 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 $257,830 EPA CCM does provide for certain raw material costs such as reagent costs. 

Catalyst Replacement $150,000 $150,000 $150,000 $150,000 $150,000 $150,000 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 $248,609 $248,609 $271,735 $271,735 $263,063 $263,063 The 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 $2,873,693 Regarding 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.

SCR+LNB+OFA

Page 2 of 2
Printed 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

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 $3,266,715 Vendor 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 $742,500 Vendor 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% $1,633,358 50% $1,633,358 $1,633,358 $1,633,358 $1,633,358 Balance 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 $980,015 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 $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 $490,007 EPA 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 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 $22,685,522 Vendor 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 

Construction above. $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% $3,402,828 15% $3,402,828 $3,402,828 $3,402,828 $3,402,828 EPA 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 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 2
Printed 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

Fixed 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 $257,830 EPA CCM does provide for certain raw material costs such as reagent costs. 

Catalyst Replacement $112,500 $112,500 $112,500 $112,500 $132,000 $132,000 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 $529,500 $529,500 $578,755 $578,755 $560,284 $560,284 The 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 $3,133,934 Regarding 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.

SCR+ROFA

Page 2 of 2