P.1 

OAR Box 1781 

Prepped by Ollie Stewart 

Document Number: 

23)11-1-15 

Docket Number: 

A-90-37 

Printed 10/29/2008 10:46:19 AM Sheet 23 of 142 
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AIR SCIENCES INC. 

* A* -. 

March 23,1989 

Project 48-02 

Ms. Cathy Rhodes 

Air Pollution Control Division 

Colorado Department of Health 

4210 E. 11th Avenue 

Denver, CO 80220 

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2 7 1989 

^^•'••••viAKrSJJiwilES 

Re: Response to request for more information regarding the Cimarron 

Chemical Cogeneration Project - Permit No. 89BA060 

Dear Cathy: 

Air Sciences is submitting the following information pursuant to your letter 

dated March 13,1989. Information required to complete the air permit application 

for the Cimarron Chemical Cogeneration Project, as we understand, is as follows: 

• Topographic presentation of pollutant concentrations 

• Statement on additional impacts 

• Further quantification of specific costs regarding BACT 

Topographic presentation of pollutant impacts cannot be made as the PTPLU 

model used to estimate these impacts for the application is a screening model, and 

produces only the maximum concentrations irrespective of location based on worst 

case meteorology. Isopleths cannot be produced from the PTPLU output. 

The facility will require minimal staff for operation (less than 20 full time 

employees), so no growth of the area is anticipated as a result of the project. 

Furthermore, the project will not impact soils or water, so additional impacts 

addressed herein are limited to visibility. 

Visibility degradation due to NOx, SO2 and particulate emissions of the project 

is estimated using the procedure set forth in the Workbook for Estimating Visibility 

Impairment (EPA 1980), Level 1 analysis. Summaries of input parameters and 

results of the analysis are attached. Downwind distances between the property 

boundary (approximately two kilometers from the source) to 20 kilometers were 

considered. Values for the Level 1 parameters Ci and C2 which indicate acceptable 

visibility degradation for Class I areas occur at minimum distances of 14.6 and 5.8 

kilometers from the property boundary, respectively. No Class I areas are located 

within these distances. Values for the C3 parameter were zero for all cases 

considered. The relationships between Ci and C2 and downwind distance are shown 

in Figure 1. 

•' ->':'• U ' ' ii't <r.i a:'/! / •''v c. 

4268_____5__S__tei_Bli.v.e. Lakewood. Colorado 80228 303/988 2960 
P.3 

Ms. Cathy Rhodes 

March 23,1989 

Page 2 

Incremental costs were developed for increasing steam injection levels for the 

control of NOx emissions from 100 ppm, the proposed BACT control level, to 75 and 

42 ppm. Costs developed include incremental increases in capitol and operating 

costs for each of the two steam injection levels considered. These costs were 

developed by Malcolm Jones and Associates, Laguna Hills, California, a consulting 

engineering firm performing the engineering of the Cimarron Project, and are based 

on the nature of the CCl Power Purchase Agreement and vendor quotations recently 

received for similar equipment. Water development costs were provided by CCL 

The report summarizing this evaluation is attached. 

Costs are presented as incremental increases which will result if steam 

injection levels are increased from that which will control NOx emissions from 100 to 

75 ppm, from 75 to 42 ppm and from 100 ppm to 42 ppm. They are summarized in 

Table 2. It may be seen from Table 2 that the largest operating cost component is 

that which results from increasing fuel requirements. This increase is required to 

maintain power output as steam injection is increased. Capitol and operating costs 

also increase as j_ result of the increased water consumption. Annual incremental 

increases of water consumption from 100 ppm steam injection levels to 75 and 42 

ppm levels are 7.3 million and 23.6 million gallons per year, respectively. Larger 

processing equipment is necessary to process these higher volumes of water. 

Significant increases in costs will be realized if the 42 ppm steam injection NOx 

control level is necessary. CCl has rights to a limited supply of water. The 

additional capitol cost for this control level is due to the procurement of additional 

water sources, which are groundwater wells. These costs will involve the purchase 

of additional land, upgrading existing wells on this new land and the installation of 

additional pumps and piping. This additional capitol cost is estimated at 

approximately $1 million. 

These costs are annualized over the 15 year lifetime of the project. Financing is 

available for 15 years at 12 percent. Operating costs were assumed to escalate at a 

rate of five percent per year. A discount rate of 15 percent was assumed as well. 

Incremental annual costs and total costs over the 15 year life of the project are 

summarized in Table 1. Supporting calculations are attached. 
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• _-

* 

Ms. Cathy Rhodes 

March 23,1989 

Page 3 

h 

TABLE 1 

INCREMENTAL ANNUAL AND TOTAL COSTS 

Steam Injection Level 

Cost Basis 100-75 ppm 75-42 ppm 100-42 ppm 

Annual $247,100/yr 

Total 

(15 years) $3,706,500 

$891,700/yr 

$13,375,500 

$l,138,800/yr 

$17,082,000 

TABLE 2 

.INCREMENTAL COSTS OF STEAM INJECTION 

(Present Value Dollars) 

Cost Impact Component 

Operating Costs 

Fuel 

Water Treatment Chemicals 

Boiler Feedwater Chemicals 

Raw Water 

Operating Cost Total ($/yr) 

Capitol Costs . 

Water Treatment Equipment 

Piping 

Pump and Desuperheater 

Capacity 

Installation Labor 

— Land, wells, pumps and 

piping 

Capitol Cost Total 

100-75 ppm 

$120,000 

26,194 

5,613 

8,160 

$159,967 

$63,750 

3,000 

4,000 

17,500 

$88,250 

75-42 ppm 100-42 ppm 

-

$200,000 $320,000 

75,499 101,693 

16,178 • 21,791 

23,520 31,680 

$315,197 $475,164 

$183,750 $275,500 

9,000 12,000 

6,000 10,000 

' 50,000 67,500 

1,000,000- 1,000,000 

$1,248,750 $1,337,000 
P.5 

Ms. Cathy Rhodes 

March 23,1989 AIR SCIENCES INC. 

Page 4 

It may be seen from Table 1 that the incremental annual cost for increasing 

steam injection from the 100 ppm level to a 75 ppm level is $247,100. The resulting 

incremental annual reduction in NOx emission for this case is 234 tons. Therefore, 

the cost of increasing steam injection to control NOx emissions to 75 ppm is $1,060 

per additional ton NOx controlled. 

Likewise, the incremental annual cost for further increasing steam injection 

from 75 to 42 ppm levels may be seen to be $891,700. The net reduction in NOx 

emissions from the 75 ppm steam injection level to the 42 ppm steam injection level 

is 308 tons per year. Therefore, the incremental cost of increasing steam injection 

from 75 to 42 ppm levels over and above the 75 ppm incremental cost is $2,895 per 

additional ton NOx controlled. 

TABLE ^ 

ANNUAL COST PER TON NOx REMOVAL 

100-75 ppm 75-42 ppm 

$l,060/ton $2,895/ton 

Please contact me if you have any questions regarding this information. We 

believe that this information, and the additional report copies submitted earlier, 

complete the information requirements for the CCl permit application. Please 

advise Air Sciences of any additional needs if they exist. 

Sincerely, 

Cc_c^ hcFc^s_r 

Gary W. McFaddin 

Project Manager 

GWM:cmf 

cc: Ms. Elizabeth Sumerlin - CCl 

12687 West Cedar Drive. Lakewood. Colorado 80228 303/988 2960 
P.6 

LEVEL 1 VISIBILITY RESULTS 

CIMARRON CHEMICAL COGENERATION PROJECT 

1 r-

.8 

Ci 

and 

C2 

.6 -

.5 -

.4 

.3 

.2 -

.1 -

l 

4 6 8 10 12 14 16 18 20 

Downwind Distance (km)