United States
                    Environmental Protection
                    Agency
Air and Energy Engineering
Research Laboratory
Research Triangle Park NC 27711
                    Research and Development
EPA/600/S7-90/008 Aug. 1990
&EPA        Project Summary
                    Verification of Simplified
                    Procedures for  Site-Specific
                    SO2 and NOX  Control  Cost
                    Estimates
                    Thomas E. Emmel and Mehdi Maibodi
                     Detailed retrofit studies were con-
                    ducted for 12 coal-fired plants in Ohio,
                    Kentucky, and the Tennessee Valley
                    Authority system.  Because detailed
                    studies are expensive and time-consum-
                    ing, the results from the 12-plant study
                    were used to develop simplified proce-
                    dures for estimating sulfur dioxide (SO?)
                    and nitrogen oxides (NOx) retrofit control
                    costs and performance for 200 SOa-emit-
                    ting coal-fired power plants in the  31-
                    state eastern region:  The simplified
                    procedures require less time, data and!
                    preparation effort.  This report docu-
                    ments the results of an evaluation to
                    verify the accuracy of the simplified pro-
                    cedures. The evaluation compared  the
                    costs for a number of plants estimated
                    using the simplified procedures to costs
                    estimated using detailed procedures, ac-
                    tual retrofit costs, and more detailed cost
                    estimates provided by utility companies.
                    Based on the evaluation, recommenda-
                    tions for changes to the simplified proce-
                    dures  were developed.   Control
                    technologies addressed in this report are
                    conventional lime/limestone flue gas
                    desulfurization, lime spray drying, fur-
                    nace sorbent injection, duct spray drying,
                    coal switching, physical coal cleaning,
                    and selective catalytic reduction.  In
                    general, it was found that the simplified
                    procedures can be used to generate  im-
                    proved  cost performance  estimates
                    based on generally available information:
                    U. S. Geological Survey photographs and
                    Energy  Information Agency Form 767
                    data.
  This Project Summary was developed
by EPA's Air and Energy Engineering Re-
search Laboratory, Research Triangle
Park, NC, to announce key findings of the
research project that is fully documented
in a separate report of the same title (see
Project Report ordering information at
back).

Introduction
  The objective of the National Acid
Precipitation Assessment Program
(NAPAP); retrofit cost project is to develop
improved (site-specific) cost estimates for
retrofitting sulfur dioxide (SOa)  and nitrogen
oxide (NOx) controls on  200 of the largest
emitting coal-fired utility power plants. This
project was conducted in the  four phases
depicted in Figure 1. In Phase I, procedures
were developed based on plant-specific in-
formation obtained from site visits (detailed
procedures).  Twelve plants in Kentucky,
Ohio, and the Tennessee Valley Authority
(TVA) system were evaluated underthis pro-
gram phase, and the procedures and results
were reviewed by a Technical Advisory
Committee and the participating utility com-
panies.
  Because detailed studies are expensive
and time consuming, the results of the 12-
plant study were used to  develop simplified
procedures for estimating SOg/NOx control
technology retrofit cost/performance for 200
SOg-emitting coal-fired power  plants in the
31-state eastern region.  In simplifying the
detailed procedures, the major  retrofit factor
"drivers" were identified and only the retrofit
difficulties associated with these drivers

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                              PHASE 1
                      Develop Detailed Procedures
                              PHASE II
              Select 12 Plants and Develop Cost/Performance
                              Estimates

                Revise Procedures and Cost Estimates and
                     Develop Simplified Procedures
                             PHASE III
                          Evaluate 50 Plants

               Verify Simplified Procedures with Plant Visits

              Modify Procedures and Evaluate Remaining 138
                               Plants
                             PHASE IV
                     Finalize Top 200 Study Report
                                                                             TECHNICAL ADVISORY COMMITTEE
                                                                              Electric Power Research Institute
                                                                              U.S. Environmental Protection Agency
                                                                              U.S. Department of Energy
                                                                              Utility Air Regulatory Group
                                                                              Tennessee Valley Authority
                                                                              National Resources Defense Council
                                                                              Vendors
                                                                                   UTILITY COMPANIES
                                  Ohio Edison
                                  American Electric Power
                                  Ohio Electric Utility
                                  Tennessee Valley Authority
                                  Kentucky Utilities
                                  Union Electric
                                  Cincinnati Gas and Electric
                                                                                     All Represented
                                                                                     Utility Companies
 Figure 1.   Top 200 plant study technical approach.
(e.g., site access and congestion) were es-
timated.  To estimate retrofit factors using
the simplified procedures, a plot plan and/or
aerial photograph were used instead of in-
formation gathered during a site visit. How-
ever, assumptions were made to streamline
these procedures.  For example,  average
underground obstructions as well as some
scope adjustments were always used (e.g.,
chimney liner,  demolition  and  relocation,
draft controls, and new rails) unless one or
more of these items were  unnecessary or
Incorrect.  After developing cost/perfor-
mance  estimates for 50 plants using the
simplified procedures, the procedures were
evaluated to verify their accuracy.  The
results  of the simplified procedures  were
compared to: results obtained by using the
detailed procedures, actual retrofit cost, and
more detailed estimates provided by par-
ticipating utility companies.To accomplish
this  objective, 6  of the 50 plants were
selected to  evaluate the simplified proce-
dures.  Additionally, for 17 boilers, detailed
cost estimates or reported actual costs for
retrofit FGD systems were available to com-
pare to the detailed and simplified procedure
results generated under this program.
  The following procedures were used to
verify the simplified procedures for the six
plants selected for site visits: 'conduct plant
visits and collect site-specific^data, develop
boiler/control-specific retrofit difficulty fac-
tors, develop boiler/plant-specific cost and
performance estimatesforthe SOa and NOx
controls selected using the detailed proce-
dures,  and compare these  results with
results  developed using simplified proce-
dures.  Utility interest in participation in the

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study was  a major consideration in plant
selection. Table 1 presents the boiler char-
acteristics for the six plants visited to verify
and quantify the accuracy of the simplified
procedures.
Simplified Procedures
Verification Methodology
  Table 2  presents the SOa/NOx control
technologies that are being evaluated under
the NAPAP retrofit control cost study.  As
this table shows, detailed and simplified pro-
cedures were developed for the lime/lime-
stone (L/LS)  and lime spray  drying (LSD)
flue gas desulfurization (FGD) technologies.
However,  for the other technologies  only
simplified procedures were developed. The
focus of the simplified procedure verification
          Table 1.   Boiler Characteristics of the Plants Evaluated
Plant
Name
Rush Island

Sioux

Meramec



Labadie



Beckjord





Miami Fort


Boiler
Number
1
2
1
2
1
2
3
4
1
2
3
4
1
2
3
4
5
6
5
6
7
Gross Operating
Capacity (MW)S
621
621
550
550
137
137
289
359
620
620
620
620
100
100
135
162
255
449
85
175
524
Installation
Date
1976
1977
1967
1967
1953
1954
1959
1961
1970
1970
1973
1973
1952
1952
1954
1958
1962
1969
1949
1960
1975
Capacity
Factor
(%)
42
58
43
32
10
12
11
11
59
52
57
58
6
8
10
22
29
57
40
71
67
Firing
Type
Tangential
Tangential
Cyclone
Cyclone
Tangential
Tangential
Wall
Wall
Tangential
Tangential
Tangential
Tangential
Tangential
Tangential
Wall
Tangential
Tangential
Tangential
Wall
Tangential
Wall
Coal
Sulfur
(%)
1.1
1.1
1.7
1.7
1.1
1.1
1.1
1.1
2.6
2.6
2.6
2.6
1.0
1.0
1.0
1.0
2.5
2.5
1.0
1.0
3.0
          a Maximum unit design capability.
          Table 2.    Emission Control Technologies Evaluated

Development Status
Limited Near
Species Controlled Commercial Commercial
SOz A/Ox Commercial Experience Demonstration
Lime/Limestone (L/LS) flue
gas desulfurization (FGD)
Additive enhanced LfLS-FGD
Lime spray drying (LSD) FGD a
Physical coal cleaning (PCC)
Coal switching and blending (CS/B)
Low-NOx combustion (LNC)
Furnace sorbent injection
(FSI) with humidification
Duct spray drying (DSD)
Natural gas reburning (NGR) b
Selective catalytic reduction (SCR)
X X
X X
X X X
X X
X X
X X
X X
X X
XX X
X X
Type of Procedures
Detailed Simplified
X X
X X
X X
X
X
X
X
X
X
X
          a Commercial on low sulfur coals, demonstrated at pilot scale on high sulfur coals.
          b For wet bottom boilers and other boilers where LNC is not applicable.

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evaluation was twofold. First, the accuracy
of the publicly available data and the as-
sumptions used to develop the inputs to the
simplified procedures were reviewed.
These inputs were then compared to the
inputs developed using the more detailed
data obtained from the site visits.
  Second, for the FGD technologies, retrofit
factors and indirect costs were developed
using the detailed procedures.  These
retrofit factors and indirect costs were com-
pared to the simplified procedure results
developed before the site visits as well as the
simplified procedure results developed with
the site visit information. This was done so
that differences in the detailed procedures
and the simplified procedures could be clas-
sified as being due to errors in the quality of
the publicly available information or due to
the different level of detail between the two
procedures.
  Additionally, when actual  cost data or
more detailed cost estimates were available,
these costs  were compared to  the costs
estimated using the simplified and detailed
procedures.  Actual retrofit costs were ob-
tained from the Energy Information Agency
(EIA)-767 forms for seven units at six plants.
Detailed engineering cost  estimates were
obtained for 10 units at 6 plants.
  Cost estimates  developed under this
study were generated using the  Integrated
Air  Pollution  Control System  (IAPCS) cost
model. These cost estimates were made to
reflect site-specific retrofit impacts by input-
ting capital cost multipliers,  scope adder
costs, and capital cost indirect factors that
were  developed  using  the simplified and
detailed procedures.
Lime/Limestone FGD Procedures

Comparison of Simplified and
Detailed Procedure Results
  For L/LS and LSD-FGD, retrofit factors and
cost estimates were developed using both
the simplified  and detailed procedures
based on the detailed information collected
during the site visits. The retrofit factors and
cost estimates were then compared to those
previously developed  using  the simplified
procedures and based on EIA-767 data and
plant plot plans or aerial photographs.
  The  percent differences  between the
simplified and detailed procedures based on
the data obtained from the  site visits are
small.  The difference for L/LS-FG5D varied
between -6 and +5% with an average  of
2.7%.  The difference for LSD-FGD varied
between <1 and 5%  with an average  of
1.9%. These differences are due to simplify-
ing assumptions made when developing the
simplified procedures.
  The differences between the detailed pro-
cedures  based on site visit  data and the
simplified procedures  based on publicly
available data were also determined.  The
difference for L/LS-FGD varied from -9  to
+16% with an average of 8.8%.  The dif-
ference for LSD-FGD varied from  -24  to
+17% with an average of 9.8%.
  The difference between the simplified and
detailed procedure results is due to proce-
dural differences and errors in assumptions
due to having less detailed  and incorrect
data. The procedural differences result from
simplifying the detailed procedures by using
average factors for flue gas duct distance,
underground obstruction difficulties, and
scope  adder costs. The  incorrect data
resulted in changing the need for wet to dry
ash  handling at the four Missouri  plants.
Additionally, the absorber locations for one
of the Missouri plants, Meramec units 1-4,
were changed. Duct work distance and ab-
sorber/flue gas handling area access/con-
gestion changes were also made at Labadie
and  Rush Island when more detailed infor-
mation was available. A comparison of the
simplified  procedure results, developed
before and refined after the site visits for the
two Ohio plants, revealed no significant dif-
ferences.
  Based on these results, it was concluded
that the  use of EIA-767 form data and U.S.
Geological Survey (USGS) photographs
can  be  used to accurately determine  the
retrofit difficulty  for  FGD.  However,  ex-
perience is needed to accurately evaluate
these sources of information.  Additionally,
communications with the plantgenerally can
be very  helpful in confirming the best loca-
tion of the  FGD process areas and retrofit
difficulty issues.

Comparison to Other Cpst
Estimates
  Capital cost estimates using the simplified
procedures were developed and compared
to estimates developed by architectural and
engineering (A&E) firms for six plants.
These cost estimates were obtained through
the data collection effort for the program.
Table 3 summarizes the results of this com-
parison. As can be seen, the simplified pro-
cedure results compare well with the A&E
estimates. The difference varied from -12 to
+20%, well within the ±30% accuracy of the
Electric  Power Research Institute (EPRI)
FGD cost estimating guidelines.
                        Table 3.  Comparison of Capital Cost Estimatese
Plant and Unit
Asbury 1
Sibley3
Thomas Hill 1
Thomas Hill 2
New Madrid 1
New Madrid 2
Beckjord 5 + 6
Miami Fort 6
Miami Fort 7
A&E Estimate Simplified Procedure
($/kW) Estimate ($/kW)
274
199
363
282
259
215
203
276
210
264
222
355
297
221
229
202
283
169
Absolute b
Difference (%)
4
12
2
5
15
7
<1
3
20
                          In 1987 dollars.
                          (A&E estimate - simplified procedure estimate)/A&E estimate x 100.

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Comparison of IAPCS Cost
Estimates to Actual Installed
Costs
  A review of the Flue Gas Desulfurization
Information System identified 11 retrofit FGD
systems that came on-line after 1980. For
seven of these units, actual costs reported
in EIA-767 forms  and aerial  photographs
were available and were used to compare
the simplified procedure cost estimates to
actual reported costs.  For  these seven
units, FGD system cost estimates have been
developed using the IAPCS cost model with
retrofit factors developed from the simplified
or detailed procedures for the following
units: Paradise 1  and 2, Widows Creek 7,
Mill Creek 1 and 2, and Four Corners 4 and
5. Table 4 summarizes the results of this
effort with the actual costs being escalated
to the same year dollars as the cost es-
timates (January 1988).
  The cost estimates  developed for Four
Corners, Paradise, and Mill Creek, unit 1,
compare well with the reported actual costs.
However,  the cost  estimates for  the Mill
Creek, unit 2 and Widows Creek, unit 7, differ
significantly. At least two reasons are pos-
sible to account for the differences:
1. Mill Creek units 1 and 2 share a common
   feed  and waste handling facility, as do
   Widows Creek units 7 and 8.
2. The Mill Creek and Widows Creek units
   were not current state-of-the-technology
   designs and have undergone significant
   design changes since start-up.
  All of these factors would reduce the ac-
tual cost compared to  the estimates
developed based on  current new source
performance standard (NSPS)  design.
However, despite these differences,  the
reported costs for Mill  Creek 2 and Widows
Creek 7 appear to be very low. Note that the
most recent FGD system actual costs com-
pare favorably to the IAPCS estimates and
that the cost of the more recent units ranges
from $180 to $300/kW.   Additional com-
parisons should be made for the other four
units at the Cromby,  Eddystone,  and
Mitchell plants if sufficient data are obtained
to conduct the evaluation.

Lime Spray Drying (LSD) FGD
With Reuse of Electrostatic
Precipitators (ESPs)
  As part of the  simplified procedure
methodology for LSD-FGD, it is assumed
that the existing ESP will be used for particu-
late  control  if the specific collection  area
(SCA) is greater than 225 sq ft of plate  area
per 1000 acfm (28 actual m3/min) of flue gas.
This was the case for all  of the  Missouri
plants  and for several of  the Ohio units.
However, for many of these units,  reusing
the ESP would result in very difficult and
lengthy flue gas duct runs from the outlet of
the air heater to the spray dryer absorbers
and  back again to the ESP inlet. For units
that have space immediately adjacent to the
air heater and ESP, this option is more prac-
tical.  Table 5  presents the ESP SCA and
comments on  applicability of this technol-
ogy for the six plants visited.

Coal Switching (CS) and
Physical Coal Cleaning (PCC)
  To estimate the cost of CS, the simplified
procedures  used one of the two low sulfur
base coals  contained in the IAPCS  cost
model.  One of the coals is a low sulfur West
Virginia bituminous coal  and the other is a
Montana subbituminous coal. The currently
used coal characteristics and cost are input
to the model, and the model estimates the
cost of CS based on the user specifying the
fuel  price differential between the current
coal and the future price of one of the two
low  sulfur base coals.  Future coal price
differentials of $5 and $15/ton were input to
the model to span the range of possible low
sulfur coal prices over high sulfur coals.
  IAPCS cost estimates also include the
cost of ESP upgrades and changes in waste
disposal costs due to differences in coal ash
content.  The model does not evaluate the
impact of CS on the following boiler operat-
ing parameters:  pulverizer capacity, slag-
ging,  fouling, erosion,  and flue gas flow
rates. Also, costs for additional coal receiv-
ing, storage, and handling facilities are not
included.   These factors are  discussed
qualitatively for each plant and boiler situa-
tion.
  Under this effort,  the primary objective
was to obtain additional information from the
six plants visited to better identify and quan-
tify boiler and plant parameters that would be
negatively impacted by CS.  Table 6 sum-
marizes the results of this effort. As can be
seen, the only major issue identified was
switching  to a subbituminous coal at the
Sioux plant. The low sulfur subbituminous
IAPCS base coal option was chosen be-
cause the plant currently uses a low sulfur
subbituminous coal.  The procedure
methodology assumes that the base coal
should  be similar to the  low sulfur coals
currently being used by the plant. However,
completely switching a boiler designed to
fire a bituminous coal  to a subbituminous
coal would result in a major unit derating.
  Currently, the CS methodology does not
quantitatively address capital costs as-
sociated with coal  receiving, storage, and
handling facilities that  may be  required to
blend coals on-site or to bring coal in by a
different transportation method.   For the
Labadie plant, the cost  to upgrade its
facilities to blend coals was on the order of
$22.5 million (1987 dollars).  However, the
cost of upgrading facilities would typically be
much less than a $5/ton impact on the coal
fuel price differential.
   Based on the six plant evaluation of the
simplified procedures,  a more careful ap-
proach  should be made in evaluating CS to
subbituminous coals on  boilers designed
for firing  bituminous  coals. In general,
                        Tab/e 4.  Comparison of Retrofit Factors and Estimated and Reported Costs
Plant and Unit
Paradise 1 or 2
Four Corners 4 a
Four Corners 5 a
Mill Creek 1
Mill Creek 2
Widows Creek 7
Retrofit IAPCS Estimated b
Factor Cost($/kW)
1.35
1.66
1.66
1.26
1.26
1.24
182
316
316
180
180
170
Reported Actual
Cost ($/kW)
184
303
303
173
75
140
Absolute °
Difference (%)
1
4
4
4
140
21
                         a Cost of fabric filters are also included in the FGD cost.
                         b Includes allowance for funds during construction.
                         0 (Actual cost- estimatedcost)/actual costx 100.

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           Table 5.   Summary of LSD-FGD ESP Reuse Applicability

           Plant Name    Unit    ESPSCAa                     Comments
                                                                                                     Applicability
          Stoux        1 and 2     268

          Labadle      land 4     319


          Labadle      2 and 3     319
          Rush Island   1 and 2
          Meramec


          Moramoc
1-3
                                  279
        492-522
                                  545
Marginal SCA; space available on one side;
reasonable accessibility to existing flue gas ducting.

Good ESP performance; space available on one side;
access to existing flue gas ducting is difficult.
Good ESP performance; space not available at sides or
behind chimney; access to existing flue gas ducting
is very difficult.

Good ESP performance but marginal SCA; reasonable
access to existing flue gas ducting; space available on
one side and behind chimney.

Good ESP performance and SCA; long duct runs and difficult
access to existing flue gas ducting because space is only
available on far side of unit 4 for absorbers.

Good ESP performance and SCA; moderate duct runs and
accessibility to existing flue gas ducting; space
available for absorbers at one side of unit.
                                                                           Marginal due to SCA

                                                                           Moderate


                                                                           Marginal due to SCA



                                                                           Mariginal due to SCA
                                                                           Marginal (good, if   [
                                                                           absorbers are located
                                                                           where original ESPs are)

                                                                           Good             :
Beckjord


Miami Fort


1-4
5
6
5
6
7
205-244
247
646
354
205
275
Marginal ESPs; very poor access for ducting.
Same as above.
Good candidate; easy access.
Poor access for duct runs.
Very small ESP SCA.
Marginal ESP SCA; space available on both sides.
Poor
Poor
Good
Marginal
Poor
Marginal due to SCA
          ' Electrostatic precipitator (ESP) specific collection area (SCA) in terms of square feet of area per 1000 acfm.
                          Table 6.  Summary Of Coal Switching Issues
                          Plant Name
                    Units
                                                                Coal Switching and Blending Issues
                          Sioux                1-2         Minor boiler derate up to 40% SB3, major derate >50%
                                                         SB.

                          Labadie              1-4         Switch coal may reduce severe slagging problems at
                                                         high load but will increase ash disposal costs. Switching
                                                         could also increase slagging problems and cause unit
                                                         derates.

                          Rush Island          1-2         Low SOz emission reduction potential. Noon-site
                                                         facilities for blending.

                          Meramec            1-4         Low SOa emission reduction potential. No on-site
                                                         facilites for blending.

                          Beckjord             1-6         Low sulfur coal on units 1-4. No on-site blending
                                                         facilities for units 5-6.

                          Miami Fort           5-7         Compliance coal on unit 8. No on-site blending facilities
                                                         for units 5-7.


                          * SB = subbituminous.
boilers designed for bituminous coals
should continue to burn the same percent-
age of bituminous coal as currently is being
fired.
  Due to the lack of coal washability data, it
has not been possible to evaluate quantita-
tively  the cost of deep PCC.  As such, the
costs generated  under this study are very
qualitative. However, no feedback has been
given to date regarding the costs and per-
                    cent removals projected with the current
                    methodology.

                    Selective Catalytic Reduction
                    (SCR)
                      Based on the information obtained during
                    the plant visit, the  assumptions used to
                    develop  the retrofit factors and scope ad-
                    ders for  SCR  were reviewed for accuracy.
                    The most important parameters that will im-
                    pact the cost of retrofitting SCR are: reactor
                                             access and congestion, flue gas duct length
                                             to and from the reactor, and demolition costs
                                             of existing equipment and general facilities
                                             percentage.These parameters are impacted
                                             by the location chosen for the SCR reactor.
                                               Table 7 summarizes the changes made to
                                             access/congestion difficulty, scope adder
                                             costs, and general facilities percentages due
                                             to the site visits for the four Missouri plants.
                                             The major problem with the simplified proce-
                                             dures identified by this analysis is selecting

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the correct location based on the informa-
tion on hand.  For the Meramec and Labadie
plants, inaccuracies in the available plot plan
or the poor resolution  of the aerial
photograph resulted in incorrectly locating
the reactors.  For the  two Ohio plants, no
changes to the reactor locations, duct run
lengths,  and access/congestion difficulty
were needed for Miami Fort.  However, for
Beckjord units 1-4, the reactor location was
changed, resulting in significant increases in
duct length.
  One option used in the study for several
plants has been to call the plant and discuss
potential equipment locations.  This has
been done several times when it was ap-
parent that the  quality  of the aerial
photograph or plot plan was poor. General-
ly, plant personnel have been cooperative.
In the future, it may be desirable to contact
every plant after reviewing the available data.

Sorbent Injection Technologies
  Based on the information obtained during
the plant visit, the assumptions used to
develop the retrofit factors and scope ad-
ders for the sorbent injection technologies
    were reviewed for accuracy.  The most im-
    portant parameters that will impact the cost
    and performance of the sorbent  injection
    technologies are:

    • paniculate  control device size, perfor-
      mance, and  difficulty of upgrade (ac-
      cess/congestion associated with adding
      plate area);

    • the need to convert a wet ash handling
      system to a dry handling system; and

    • sufficient flue gas residence time between
      the  air heater  and particulate control
      device to allow for  duct  spray drying
      (DSD), droplet  drying  (2 seconds of
      straight duct run), or humidification with
      furnace sorbent injection (FSI).

      The impact  of superheat and economizer
    gas lane pluggage for FSI was not evaluated
    under this program because of the limited
    commercial demonstration data and boiler
    information.
      Table 8 summarizes the results of the
    changes made to the simplified  procedure
    inputs after the site visits.  In general,, the
overall qualitative determination of the ap-
plicability of the sorbent  injection tech-
nologies was the same before and after the
site visit, the major differences being Be-
ckjord,  units 1-5, and Miami Fort, unit 6.
These units have small ESP SCAs,  and the
ducting configuration for units 1 -5 was incor-
rectly interpreted.   As a result, because
these units  have  a very  short flue  gas
residence time between the air heater and
the ESP  inlet and small  ESPs, the ap-
plicability  of any of the  sorbent injection
technologies is questionable.
  With regard to factors that directly impact
the cost estimates, the access/congestion
difficulty factor changed for 7 of the 21 units
and the wet to dry ash conversion assump-
tion changed for 12 of the 21 units.  As
discussed previously, the error in the ash
conversion  assumption was due  to  a
misunderstanding.  The EIA-767 forms ac-
curately indicate that the Missouri units cur-
rently use  wet ash handling/disposal
systems.
  Based on these findings, it appears that
the errors in the procedure methodology are
related to incorrectly  interpreting the data
                         TaWe 7.  Summary of Changes Made to SCR Retrofit
                        Plant Name
    Units
                                                                    Reason for Changes
                        Sioux               1-2        Scope adder cost changes due to longer duct run.

                        Labadie             1-4        Change in location of reactor resulted in changes to
                                                      access/congestion, general facilities, and duct run
                                                      lengths for all Labadie units.

                        Rush Island          1-2        No major changes were made to the SCR retrofit
                                                      compared to the results obtained prior to the site visit.

                        Meramec            1-4        Changes in location' of reactors resulted in. significant
                                                      changes in access/congestion and duct rurr lengths for
                                                      all Meramec units.
                         Table 8.  Summary of Changes or Sorbent Injection Technologies

                                                    Applicability Before Visit         Applicability After Visit

                         Plant Name
Unit
                                                                  DSD
                                                                                FSI
                                                      DSD
Sioux
Labadie
Rush Island
Meramec
Beckjord
Miami Fort
1-2
1-4
1-2
1-2
3-4
1-5
6
5
6
7
Good
Good
Good
Good
Good
Good
Good
Good
Good
Good
Good
Good
Good
Good
Good
Poor
Good
Good
Poor
Poor
Good
Good
Good
Good
Poor
Poor
Very good
Poor
Poor
Good
Good
Poor to good b
Moderate
Good
Poor
Poor
Good
Poor
Poor
Poor
                          Does not consider superheat/economizer gas line pluggage due to insufficient data.
                          Part of flue gas bypassed old ESPs resulting in adequate residence time for 50% of gas flow.

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available. It appears that the publicly avail-
able  data are  sufficient to  accurately
evaluate the retrofit difficulty of the sorbent
Injection data for most plants.  However, as
mentioned earlier, contacting the plant to
verify the accuracy of these  data and to
confirm the accuracy of basic assumptions
should reduce the  potential for incorrectly
Interpreting available data. This is particular-
ly true for small, older units because of the
resolution of the photograph and the
likelihood that unusual ESP flue gas con-
figurations exist due to the retrofit of addi-
tional ESP plate area. The Beckjord units 1 -5
and Miami Fort unit 6 are good examples of
the problem associated with unusual flue
gas configurations due to the retrofit of ad-
ditional ESP  plate area.   Additionally, a
Department of Energy database containing
duct and flue gas information upstream of
the ESP has  been made available to this
study.

Economic and Financial
Assumptions
  At the outset of the NAPAP Task Group I
effort, a decision was made to use economic
and financial data consistent with accepted
            industry practices.  The accepted standard
            for the electric utility industry is published in
            the  EPRI's Technical  Assessment
            Guidelines (TAG). The EPRI TAG provides
            the economic factors and financial data on
            which the cost estimating procedures used
            in the electric utility industry  are  based.
            Table  9 presents  the  1986 TAG values.
            Retrofitting a plant with SO2 and/or NOx
            control technologies with' possibly more
            stringent control limits could cause addition-
            al costs for compliance that are not reflected
            in this study.
                         Table 9.  1986 EPRI TAG Values - Capital and Financial Structure
                         Type of Security
                                                     Percent of total
                                                                                  Current Dollar0
                                Cost
                                                                                               Return
                         Debt (Bonds)
                         Preferred
                         Common stock

                         Discount rate, $/yr
              50
              15
              35
11.0
11.5
15.3
5.5
1.7
5.3
                                                    12.5
                         Inflation rate:
                         Federal and state income tax rate:
                         Investment tax credit:
                         Property taxes and insurance:
                         Book life
                                 6.0%/yr
                                38.0%
                                 0.0%
                                 2.0%/yr
                                30 yr
                         Item
              Unit Cost Data
            January 1985 value
                                                                                       Units
                         Operating labor
                         Water (river)
                         Lime
                         Limestone
                         Land  6,500 $/acre

                         Disposal Charges

                         Sludge
                         Dry, granular solids
                         Gypsum disposal -

                         By-Product Credits

                         Sulfuric acid
                         Sulfur
                         Ammonia (anhydrous)

                         Special Items	

                         Electric power (in plant)
                         Steam (in plant)
                          0-70 psia b
                          70-250 psia
                          250-2400 psia
                  19.70
                   0.60
                  65
                  15
                   9.25
                   8.0
                   4.75
                  50
                  75
                 150
                   5.0

                   2.85
                   3.50
                   5.30
          $/person hour
          $/1,OOOgalb
          $/ton "
          $/ton
          $/ton (dry basis)
          $/ton
          $/ton
          $/ton
          $/long ton
          $/ton
           0/kWh

          $/1000lbl
          $/1000lb
          $/1000lb
                                                        Levelization Factors
                         O&M
                         Carrying charges, %
                                            1.75
                                           17.5
                         8 For constant dollars, inflation rate is set to zero.
                         b 1 acre = 4047 mz; 1 gal. = 3.79 L; 11b = 0.45 kg; 1 long ton = 1.02 metric tons;
                           psia = psig + 14.7 (1 psi = 6.89 kPa; 1 aim = 101.3 kPa); 1 ton= 0.907 metric ton.

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  The economic and financial assumptions
of the EPRI TAG, as applied in this stage, are:
1.  Cost-estimating premises adhere to the
   cost methodology described in the 1986
   EPRI TAG.
2.  The indirect capital cost factors were as-
   signed to each technology in accordance
   with the EPRI TAG.  These values were
   varied in accordance with site-specific
   conditions and are presented in Table 10.
3.  Allowance for funds during construction
   (AFDC) is estimated by adjusting the total
   plant cost by an allowance factor (AF)
   that is a function of the idealized con-
   struction  period  and  economic
   parameters.
4.  For annual operating costs, the unit costs
   for consumables per the EPRI TAG are
   summarized in Table 9.
5.  Total annual maintenance costs are es-
   timated per the 1986 EPRI TAG as a per-
   centage of installed capital cost depend-
   ing on the nature of the processing con-
   ditions and the type of design. The factors
   assigned to the various technologies are
   summarized in Table 11.
6.  Economic premises for existing electric
   power generating plants were updated by
   EPRI and released as a supplement is-
   sued May 1,  1983.  Revised schedules
   were published for book life, tax life,  and
   levelization factors. For power plants in
   operation before January 1,1979, Internal
   Revenue Service (IRS) Code Section 169
   allows  5-year tax depreciation of new
   identifiable  pollution control  facilities
   completed or acquired after December
   31, 1982. This depreciation schedule is
   applied on a straight-line basis.  Book life
   of retrofitted equipment  is equal to the
   years of remaining life of the power plant
   rounded off to the nearest 5-year incre-
   ment. All of these items are identical in
   the 1986 TAG.
                       7. The financial and economic  premises
                         significantly influence the levelization fac-
                         tors calculated for operating and main-
                         tenance (O&M) and carrying charges.
                         Using the 1986 guidelines recommended
                         by EPRI-a  12.5%  discount rate (or
                         weighted cost of capital), 6.0% inflation
                         rate (long-term average), 30-year book
                         life (existing facility), and 20-year tax life
                         (straight-line depreciation)-the leveliza-
                         tion factors computed for O&M and capi-
                         tal carrying  charges are 1.75 and 0.175
                         for current dollars and 1.0 and 0.105 for
                         constant dollars, respectively.
                       8. All costs are presented in  current and
                         constant dollars (in  the current  dollars,
                         the effect of escalation due to inflation is
                         accounted for) and reflect June 1988 dol-
                         lars.  Capital costs are escalated using
                         Chemical Engineering indices.  Current
                         dollar costs account for inflation;  con-
                         stant dollar costs do not.
Table 10. Nominal Indirect Cost Schedule
Indirect Component a PCC LNC
General facilities, %
Engineering and home
office fees, %
Project contingency, %
Process contingency, %
Sales tax, %
Royalty allowance, %
Preproduction cost0
Inventory capital d
Initial catalyst e
Idealized construction period, yrf
0
0
0
0
0
0
c
d
0
0
10
10
30
10
0
0
c
d
0
1
FSI
10
10
30
20
0
0
c
d
0
1
NGR
10
10
30
10
0
0
c
d
0
1
SCR
10
10
30
20
0
0.5
c
d
0
1
LSD
10
10
30
4.3
0
0
c
d
0
3
DSD
10
10
30
30
0
0
c
d
0
1
ESP
10
10
30
0
0
0
c
d
0
1
FFb
10
10
30
0
0
0
c
d
0
1
FGD
10
10
30
T.4
0
0
c
d
0
3
          a Applied to process capital except as noted.
          bFF = fabric filter.
          ° 1 month of fixed operating cost.
           1 month of variable operating cost.
           2 percent of total plant investment
           60-day supply of consumables.
          e SCR catalyst costs are estimated based on unit size and desired NOX removal efficiency.
          1 Used for estimating allowance for funds during construction (AFDC).
          Table 11.  Maintenance Cost Factors

                                       PCC
    LNC
                                                        FSI
NGR
                                                                        SCR
LSD
                                                                                        DSD
                                                                                                 ESP
                                                                                                          FF
                                                                                                                 FGD
          EPRI schedule
          (percent of total process capital).

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Conclusions
  Based on the six-plant evaluation effort to
verify the accuracy of the simplified proce-
dures, the following changes to the proce-
dures were made:
1.  After receiving the publicly available infor-
   matlon,  identifying  the equipment
   layouts,  and selecting inputs to  the
   simplified procedures to develop retrofit
   factors and scope adder costs, the plant
   was contacted to confirm the accuracy of
   the data and assumptions.
2.  To continue to verify the accuracy of the
   procedures and  cost estimates
   generated, the plant evaluation and cost
   estimates were  made available to  the
   plant for review and comments.  Ap-
   propriate comments and comparative
   cost estimates were incorporated into the
   report.  Additionally,  where actual costs
   of retrofit are available, these costs were
   compared to estimates generated using
   the simplified procedures.
3.  Evaluation of retrofitting LSD-FGD  was
   eliminated for units that have marginally
   sized ESPs (SCA  = 225-300 sq ft/1000
   acfm)  and do not  have space for plate
   area addition.
4.  Evaluation of PCC was eliminated except
   for mine mouth plants with moderate to
   high sulfur coal, because the emission
   reductions that are achievable are  low,
   and insufficient data are available to ac-
   curately estimate  deep coal cleaning
   costs.
5.  Because the current CS methodology as-
   sumes total switching to a low sulfur coal,
   units designed to  fire bituminous coals
   were not switched to a subbituminous
   coal unless the plant indicates that this is
   a reasonable option and the cost of unit
   derating is included in the cost of CS.
6. Hot side SCR was evaluated for units that
   have space near the boiler.
7. Evaluation of retrofitting FSI and DSD
   technologies were eliminated for units
   that have marginally sized ESPs  (SCA =
   225-300 sq ft/1000 acfm) ^and do not have
   space available for plate area addition
   and  sufficient  space  between the air
   heater and particulate control device to
   allow  for  DSD  droplet drying or
   humidification with FSI.
  Making these changes to the simplified
procedures improves  the accuracy of the
cost estimates, ensure continued feedback
from industry regarding the accuracy of the
procedures/estimates, and  eliminates the
evaluation of technologies that are not likely
to be used, that have limited SOa reduction
potential, or those for which insufficient data
are available to accurately develop cost and
performance estimates.
       T. Emme/ and M. Maibodi are with Radian Corporation, Research Triangle Park, NC
             27709.
       Norman Kaplan Is the EPA Project Officer (see below).
       The complete report, entitled "Verification of Simplified Procedures for Site-Specific
             S02 and NOx Control Cost Estimates," (Order No. PB 90-187 261/AS; Cost:
             $23.00, subject to change) will be available only from:
                 National Technical Information Service
                 5285 Port Royal Road
                 Springfield, VA 22161
                 Telephone: 703-487-4650

       The EPA Project Officer can be contacted at:
                 Air and Energy Engineering Research Laboratory
                 U.S. Environmental Protection Agency
                 Research Triangle Park, NC 27711
                                                             10

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