EPA-R2-72-100
November 1972            ENVIRONMENTAL PRSTICTBO,! TFKMaBns,ii
Applicability
of SO2-Control Processes
to Power Plants
                                 Office of Restareh amd
                                 U.S. Environmental Protection A;
                                 Washington. D.C. 194SS

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                                       EPA-R2-72-100
          Applicability

of  SO2-Control Processes

        to  Power Plants
                    by
             M. W. Kellogg Company
              Piscataway, N.  J.
         Contract No. CPA 70-68, Task 11

           Program Element No.  1A2013
        Project Officer:  0. A. McSorley
           Control Systems Division
      National Environmental Research Center
       Research Triangle Park, N. C. 27711
                Prepared for
        Office of Research and Monitoring
       U.S. Environmental Protection Agency
            Washington, D. C. 20460

                November 1972

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This report has been reviewed by the Environmental Protection Agency
and approved for publication.  Approval does not signify that the
contents necessarily reflect the views and policies of the Agency,
nor does mention of trade names or commercial products constitute
endorsement or recommendation for use.
                                    ii

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          MWKLG-RED-72-1274




APPLICABILITY OF S02-CONTROL PROCESSES




           TO POWER PLANTS
         TASK #11 FINAL REPORT
        CONTRACT NO. CPA  70-68
             Submitted to






   ENVIRONMENTAL PROTECTION AGENCY




        OFFICE OF AIR PROGRAMS




       CONTROL SYSTEMS DIVISION
                  by




      THE M. W. KELLOGG COMPANY




  RESEARCH  & ENGINEERING DEVELOPMENT




            HOUSTON,  TEXAS

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RESEARCH AND ENGINEERING DEVELOPMENT
             APPLICABILITY OF S02~CONTROL PROCESSES

                        TO POWER PLANTS
                      TASK #11 FINAL REPORT




                          Submitted to


                ENVIRONMENTAL PROTECTION AGENCY

                     OFFICE OF AIR PROGRAMS

                  DIVISION OF CONTROL SYSTEMS

                     Contract No. CPA 70-68
                        Approved:
                                   Manager
                                   Chemical Engineering  Development
                                   Director    //
                                   Research ana  Development

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      THEM..W. KELLOGG  COMPANY
    A DIVISION OF PULLMAN INCORPORATED

    RESEARCH & ENGINEERING DEVELOPMENT
              iKELLOCCl
                            PAGE (JO.
                            REPORT NO. RED-72-1274
                                  v           	
             APPLICABILITY OF SO^-CONTROL PROCESSES

                         TO POWER PLANTS
                       TASK #11 FINAL REPORT

               EPA-OAP-DCS CONTRACT NO. CPA 70-68


                         OCTOBER 15, 1972
Staff:


Period Covered:

L. 0. No:

Distribution:
M. J. Cambon, L.  D.  Fraley,  J.  J. O'Donnell
and A. G. Sliger

December 1971 to  April 1972

4092-11

                              Copy No.
Office of Air Programs        1-100
L. C. Axelrod                   101
M. J. Cambon                    102
A. B. Cassidy                   103
C. W. Crady                     104
J. B. Dwyer                     105
L. D. Fraley                    106
J. A. Finneran                  107
S. E. Handman                   108
A. N. Holmberg                  109
R. H. Multhaup                  110
J. J. O'Donnell                 111
C. E. Scholer                   112
W. C. Schreiner                 113
A. G. Sliger                    114
M. J. Wall                      115
R. I. D.  (4)                    119
Power Companies  Studied       120-133
                           Authors:

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                           ABSTRACT

In this and a previous similar study completed in early 1971,
14 different power systems were evaluated having a total oil-
and coal-fired generating capacity of 88,520 megawatts of which
79% had adequate space for retrofitting scrubbers.  The results
are summarized below:
No. of Plants
Present Study
Previous Study

62
41*
103
Generating
Capacity ,MW
61,270
27,250
88,520
Capacity with Space
for Scrubbers
MW
53,822
15,890
69,712
"88"
58
79
*Not reevaluated in present study.

Most of the systems and plants covered by the 1971 study also
were included in this more detailed study.  However, limitations
on both funds and time available for the study dictated selections
of systems with readily available data and the largest number
of plants which naturally resulted in large systems being studied.
Thus, while both studies covered a total of 49% of the capacity,
this comprises only 15% of the plants, basis 1970 oil- and coal-
fired plants.

To obtain an indication of installation costs, a qualitative
retrofit complexity factor was estimated for each boiler unit
studied by considering such items as space availability, site
assessibility, and degree of plant modification.  The complexity
factor relates the cost of retrofitting a control system to the
cost of the same system installed on a new power plant.  Thus,
a control unit on a new power plant would have a complexity factor
of 1.0 while a factor of 3.0 was assigned to a very difficult
retrofit installation.  Any unit without adequate space for
retrofitting a scrubber was rated above 3.0.  The estimated
complexity factors were distributed evenly from 1.5 to 3.0
over the surveyed capacity, but there were trends toward lower

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factors in the larger, newer units.  The average complexity
factor for units older than 20 years and smaller than 100 MW
was 3.0; the average for units younger than 10 years and larger
than 500 MW was 2.0.

The distribution of relative operating costs  (levelized to an
average annual basis) over generating capacity was calculated
by assuming that investment is proportional to the complexity
factor and by incorporating the effect of the unit load factor.
On this basis it was found that 50% of the generating capacity
can be retrofitted at a relative cost per kilowatt-hr of 1.7
to 2.4-fold the cost of installing the same control units on
new power plants operating at full load.

Several other applicability factors were included in this study,
but the data obtained were insufficient to permit any general
conclusions to be reached.  These factors include:
      • Available space for regeneration facilities
      • Available land for waste disposal
      • Present technique and costs of fly ash disposal
      • Availability and cost of utilities, clean fuels
        and other materials.

A final point to be noted is that while many utilities have
scrubber space available, they are presently switching to low
sulfur fuel and many have made long term commitments with the
fuel supplier.  Essentially all of the utilities contacted
stated that they would prefer low sulfur fuel to stack gas
clean-up if such fuel is available.
                               11

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              TABLE OF CONTENTS
Preface 	  1





Introduction  	  3






Acknowledgements  	  5






Summary & Conclusions 	  6





Basis of Evaluation	10






Discussion of Results   	 24
                       111

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                        LIST OF TABLES


Table No.                                             Page No.

1.  Space Requirements - Wet Limestone - 167 MW          17


2.  Space Requirements - Limestone Slurry - 167 MW       18


3.  Space Requirements - Magnesium Oxide  - 167 MW       19


4.  Space Requirements - Ammonia Scrubbing - 167 MW      20


5.  Space Requirements - Sodium Scrubbing - Wellman-     21
    Lord - 167 MW

6.  Space Requirements - Stone & Webster/Ionics -        22
    167 MW

7.  Data Requested in Applicability Study                23


8.  Summary of Power Plant Data                          42-61


9.  Regeneration Process Areas                           62
                                IV

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                       LIST OF FIGURES




Figure No.                                                          Page No,


   1           Wet Limestone & Lime Slurry - 167 MW                   17


   2           Limestone, Lime and MgO - Alternate Arrangement -      18
               - 167 MW.

   3           Magnesium Oxide - 167 MW                               19


   4           Ammonia Scrubbing - Bohna Regeneration;                20
               Sodium Scrubbing — Wellman-Lord;
               Sodium Scrubbing — Stone & Webster/Ionics - 167 MW


   5           Ammonia Scrubbing — Bohna Regeneration;               21
               Sodium Scrubbing — Wellman-Lord;
               Sodium Scrubbing — Stone & Webster/Ionics-
               Alternate Arrangement - 167 MW


   6           Relative Installed Cost of Retrofit S02-Control        22
               Units                  "*"
               Distribution over Generating Capacity


   7           Relative Contribution of Capital Cost to Incremental   23
               Annualized Unit Production Cost
               Distribution over Generating Capacity

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                         I.  PREFACE

     The work described herein in general represents an effort
to determine the extent to which S02~control units can be installed
in existing oil- and coal-fired power plants.  Ideally, a
detailed evaluation should be made of all the major factors
influencing the installation of the control unit with plants
selected to provide a completely representative cross section
of the power industry.  However, the calendar time and man-hours
allocated to perform the work coupled with the need to obtain
certain minimum results limited the degree of detailed evaluations
that could be made.  Also limiting the degrees of freedom was
the requirement that a maximum of nine different companies could
be contacted since the proper clearances to contact more than
this would have extended the calendar time beyond the specified
limit.  Consequently, the need to obtain a maximum amount of
data in a limited time from only a few companies resulted in
the selection of large utilities as the source of information.
Before the work was started, the concurrence of the EPA task
officer was obtained for both the list of utility companies to
be studied and the questionnaire that wo-uTd be used.

     Since the larger utilities generally have the largest and
newest plants compared to the overall national average, the
results do not represent a true cross section of the power in-
dustry.  On the other hand, the majority of the power generated
in this country is produced by a relatively few power plants,
percentage wise, so the results should correlate well with over-
all generating capacity.

     The geographical locations of the plants were selected to
provide data from each section of the contiguous U.S. with both
urban and rural sites covered.  Primary emphasis was on space
availability but cost also was considered indirectly by assuming
                                 -1-

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that control units costing more than about $75/KW would not be
used.  Instead, it is expected for this situation that some
alternative, such as low sulfur fuel, would be found.

     Conclusions based on the results of this study should
consider the limitations of the study, the major ones being
those cited above.  Within these limitations, however, the results
should be quite useful in providing a reasonably accurate picture
of the applicability of SO^-control units to existing power plants
                                  — 2 —

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                       II.  INTRODUCTION

     This report covers work which was performed under Contract
No. CPA 70-68, Environmental Protection Agency, Office of Air
Programs.  The task specifications were delineated by OAP in Task
No. 11 Contract Task Specification Request, dated November 17, 1971,
and supplemented by an OAP letter dated December 20, 1971, which
transmitted additional input data to be used in the study.

     Task Order No. 11, in short, specifies that a survey be made
of the power utility industry to ascertain the degree to which S0~-
control processes can be installed (as retrofit units) in existing
and new power plants.  Space considerations were of primary concern
but other factors also were to be considered, such as general
mode of transportation, disposal of waste materials, availability
of utilities, etc.  A previous Kellogg study of very limited effort
had considered space limitations only and the present study was to
include and expand this earlier study.  The purpose of the study
is to provide OAP with more specific information than presently
available as to the application to existing plants of the SO^-
control processes now receiving OAP support, thereby insuring that
research and development funds are channeled into areas where maximum
benefits will result.

     To provide a basis for determining space requirements, EPA
specified six different processes as the basis for this study, viz.:

                 • Limestone slurry scrubbing
                 • Lime slurry scrubbing
                 • Magnesium oxide scrubbing with regeneration
                 • Ammonia scrubbing - Bohna regeneration
                 • Sodium scrubbing  - Wellman-Lord  (Wellman-Power Gas, Inc,
                 • Sodium scrubbing  - Stone and Webster/Ionics
                                -3-

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Since all of these processes employ wet scrubbing to remove the
S02 from the flue gas, essentially the same size scrubber could
be used in all cases.  Further, to minimize space requirements,
it was decided to include a dust removal section in the bottom of
the wet scrubber rather than having a separate fly ash control
system.  Information for the fly ash scrubbing section of the tower
was obtained from an equipment vendor who has many commercial in-
stallations for similar service and will guarantee greater than 99%
efficiency.  The additional space for the dust scrubbing step is
small so whether or not there is existing dust control equipment
in the plants studied has no effect on the overall results.

     Cost estimates of installation the S02-control systems were
desired but even very rough estimates would have required more time
and effort than were available so this parameter was not studied.
To provide  a general idea of the cost of retrofitting, however,
a complexity factor  (largely subjective) was estimated for each
unit studied; this factor gives the ratio of a retrofit cost
to that of a new plant.  The complexity factor was estimated in each
case by evaluating the effort required to retrofit a control system
considering qualitatively the modifications needed such as moving
parking lots and/or buildings; relocating solids storage piles,
railroad tracks and roads; structural alterations needed; accessibility
of scrubber site, etc.  The values assigned to the complexity factors
range from 1.5 to 3.0, based on very limited input information for
units actually being installed.  Thus, a very difficult retrofit
might cost three-fold as much as units installed on a new plant.
                                -4-

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                    Ill.   ACKNOWLEDGEMENTS
    The cooperation and assistance of the many persons within
the power utility industry who helped assemble the data
reported herein is gratefully acknowledged.  The individuals
are too numerous to list here so the following tabulation
comprises those companies that provided assistance, information
and working space to the Kellogg personnel performing this
evaluation.

       • Arizona Public Service Corporation
       • Boston Edison Company
       • Commonwealth Edison Company
       • Consolidated Edison Company of New York, Inc.
       • Detroit Edison Company
       • Duke Power Company
       • Georgia Power Company
       • Monogahela and Western Pennsylvania Power Company
       • Pennsylvania Power and Light Company
       • Philadelphia Electric Company
       • Public Service Company of Indiana, Inc.
       • Public Service Electric and Gas Company  (New Jersey)
       • Ohio Edison Company
       • Tennessee Valley Authority
                          -5-

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                  IV-  SUMMARY AND CONCLUSIONS

     A total of 14 different power systems were studied in this
and the previous similar study completed in early 1971.  The
1971 study considered only space limitations whereas the present
study expanded the variables studied to include waste disposal,
availability of utilities and raw materials, mode of trans-
portation, etc.  A complete listing of the criteria used in
the evaluation is included in Section IV of this report -- Basis
of Evaluation.

     The 14 systems studied had a total of 103 plants of which
62 plants were included in the present study.  The total gen-
erating capacity of the plants studied and the capacity which
can be retrofitted with control units are as follows:
                                            **Capacity For
                           Generating      Retrofit Scrubbers
No. of Plants             Capacity, MW       MW           %_
Present Study:      62      61,270         53,822         88
Previous Study:*    41      27,250         15,890         58
TOTAL              103      88,520         69,712         79

 *Not re-evaluated in present study
**Based on criteria established for this study, viz., primarily
  space availability and cost factors not exceeding about $75/KW
  for the retrofit control unit.

     The above results indicate that the majority of existing
power plants studied can be equipped with an S02~control unit.
Therefore,the  major .conclusion  arising  from  this  study  is that
based on  the  criteria established  and assuming  a  representative
sampling  was  obtained, SO2~control units  can be installed in
existing  power plants which account for nearly  80%  of  the present
generating  capacity  in the contiguous U.S.

     The  following tabulation serves to put  the present study
in  perspective.
                               -6-

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 Generation           *Installed Capacity,MW      Percent  Studied
   Method               19701972'        1970     1972
 Oil  and Coal          182,191'       212,943         49        42
 Total  Thermal         265,5843       308,613         33        29

 *Contiguous U.S.

     The  above  values show  that a large fraction of the  total
 U.S. generating capacity was  studied  and  implies that results
 should be representative  of the entire country.   If, however,
 instead of  capacity the number of plants  is  considered,  the
 percentage  studied drops  from 49 to 15, basis  1970 oil-  and
 coal-fired  plants.   This  indicates that a high number of large
 size plants were included in  this study and  therefore conclusions
 reached based on the present  data should  differentiate between
 capacity  and number of plants, the former being more significant.

     To provide an indication of the  cost involved for each unit
 where  a control unit can  be installed, a  complexity factor has
 been derived.   This factor  shows the  cost of a retrofit  control
 unit relative to the cost of  an identical unit installed in
 a new  power plant and ranges  from 1.5 to  3.0.   Since specific
 cost estimates  were not part  of this  study,  the factor is strictly
 qualitative and was derived by estimating the  difficulty of in-
 stalling  the control unit considering such items as space
 availability, site accessibility and  degree  of modification re-
 quired to the site, buildings, structures and  equipment.   The
 range  was selected based  on the few values reported in the lit-
 erature for the wet limestone scrubbing process for new  and retrofit
 units. New complete plant  installation fall in the range of
 $20-25/KW while retrofit  units can cost as much as $60-70/KW for
 very difficult  installations  (i.e., limited  space and poor acces-
 sibility) .  The complexity  factors are shown in Table 8  for each
 unit studied.

1"Steam-Electric Plant Factors/1970 Edition", Twenty-First Edition,
  February 1972  National Coal  Association
2Based  on  data in FPC News,  Vol. 5, No. 12, 3/24/71
Calculated  assuming nuclear comprises 2%  of  total thermal capacity
                                — 7—

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     To further illustrate these cost data, the generating capacity
which can be retrofitted with control units has been subdivided
as a function of the complexity factors and the results are sum-
marized in the following tabulation:

                    Retrofit Generating                *Cumulative
Complexity Factor      Capacity,MW	    *Percent       Percent
     1.0                  1,037              1.17          1.17
     1.5                 26,853             30.34         31.51
     2.0                  9,333             10.54         42.05
     2.5                 16,012             18.10         60.15
     3.0                 16,477             18.61         78.76
                         69,712             78.76
*Based on total capacity studied — 88,520 MW

     Based on these data it is concluded that about 42% of the
generating capacity studied can be retrofitted with SO2-control
units at a complexity factor of 2.0 (~$50/KW) or less.  The
data are presented graphically in Figure 6 in Section VI of this
report.

     To provide an indication of the increase in power production
costs owing to the installation of S02~control units, the com-
plexity factor was used in conjunction with the load  factor to
calculate operating costs.  The results of this calculation in-
dicate that about 50% of the generating capacity studied could
be retrofitted at relative incremental unit power costs of 3.5 or
less which corresponds to an actual incremental power cost of
about 2.0 mills/kwh, based on capital costs only.  Other costs
would add an additional 0.5-1.5 mills/kwh so that the total
incremental power costs attributable to S02-control would be
2.5-3.5 mills/kwh.

     A discussion and example of the method of calculating the
incremental power costs owing to the SO2-control units is included
in Section VI of this report.
                           -8-

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     One objective of the survey was to ascertain if adequate
utilities (primarily steam and/or power) are available to operate
the control units, especially during peak power demand periods,
once they are installed.  In general, this information was not
available in specific form; rather, the utilities stated that while
the control units could be operated, the overall power grid would
be affected and provisions for these contol units would have to
be included in plans for future expansion.  In some cases power
for the control units would have to be purchased during peak
periods while in others, adequate reserves are available to
supply the additional 1-3% needed.

     Specific information generally was unavailable, (i.e., not
known) regarding raw material supplies, potential by-product markets,
future levels of SO -control expected, or quantities of waste
material (e.g., CaSO.) that could be discharged into local water
streams.  It appears that separate, extensive studies would be
required for each of these variables to develop this information
and further, some items are not known at the present time, i.e.,
water quality restrictions and future SO- levels allowable.

     Since water quality data generally are not known, space
requirements only were considered in determining waste disposal
facilities.  In some cases, no on-site space is available and
present practice is to pay outside contractors to haul the solid
waste  (i.e., fly ash) away.  To dispose of the wet scrubbing waste
material in this manner can cost up to $7/ton, including the necessary
drying equipment.  In other cases, costs as low as $0.40/ton are
realized when disposal areas are nearby and no pretreatment is
necessary.  Considering the wide range of costs involved, no meaning-
ful general conclusions can be drawn regarding waste disposal costs.

     A final point to be noted is that while many utilities have
scrubber space available, they are presently switching to low
sulfur fuel and many have made long term committments with the
fuel supplier.  Essentially all of the utilities contacted stated
that they would prefer low sulfur fuel to stack gas clean-up if
such  fuel is available.
                               -9-

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                      V.  BASIS OF EVALUATION

     Space requirements for both scrubbing and regeneration
facilities were based on six different processes specified by
OAP as follows:

          • Limestone slurry scrubbing
          • Lime slurry scrubbing
          • Magnesium oxide scrubbing with regeneration
          • Ammonia scrubbing - Bohna regeneration
          • Sodium scrubbing - Wellman-Lord  (Wellman-Power Gas, Inc.)
          • Sodium scrubbing - Stone and Webster/Ionics

     Based on both in-house data and information supplied by OAP,
MWK prepared equipment layouts for the scrubbing section of each
process.  Space requirements for the appropriate regeneration
sections were tabulated based on the limited information available
at the time.  Layouts and regeneration requirements, most of which
were obtained from OAP, are shown in the following pages, Tables
1-6, and Figures 1-5.  Note that the layouts show only the major
pieces of equipment that have to be located adjacent to the power-
house/stack since the smaller items (e.g., pumps) have only
relatively small space requirements and should present no installation
problems.  Also, items such as structures, instruments, etc.,
likewise are not shown since they do not influence the layout to
any great extent with respect to the present objective.  The
scrubbing equipment layouts are felt to be well established
whereas the regeneration requirements are approximate.  However,
since the scrubbing space is the most critical requirement,  (the
regeneration section does not necessarily have to be adjacent to
the power house/stack,) the lack of detailed data for regeneration
area requirements does not adversely affect the study.

     The evaluation procedure comprised personal visits to the
selected power utilities, and, using the pilot plans and space

                            -10-

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requirements shown, plot plans of the individual power stations
were examined to determine if space were available in which the
control units could be installed.  The plot plans also were used
to estimate the degree of modification to the power plant needed
to install the control unit from which the complexity factor was
derived.  Other data needed for the survey were requested from
the power plant personnel.  The information related to plant
operation generally, but not always, was readily available but
the other data, e.g., water quality requirements, raw material
availability, by-product markets, etc., were, in most cases,
not known.

     The specific items for which data were requested are shown
in Table 7.
                               -11-

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                       Figure 1
        Wet Limestone & Lime  Slurry - 167 MW
/—.DUCT Qx\&'
                                                     Co L. t_e.CT i N C=T
                                                     DUCT
                                        TR.UCK A.ec.e_s>2. TO
                         -12-

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                      Figure 2





Limestone, Lime and MgO - Alternate Arrangement -  167 MW
                                       0
                    ?aOW E.RHOUSE.
                     -13-

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           Figure  3
Magnesium Oxide  -  167  MW
                                  RE.HEATE.R
          -14-

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                     Figure 4





     Ammonia Scrubbing - Bohna Regeneration;



        Sodium Scrubbing — Wellman-Lord;



Sodium Scrubbing — Stone and Webster/Ionics - 167MW
              POWE. IR HOUSE.
                                  \ O
                  -15-

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                             Figure 5





              Ammonia Scrubbing...— Bohna Regeneration;




                 Sodium Scrubbing — Wellman-Lord;




Sodium Scrubbing -- Stone & Webster/Ionics - Alternate Arrangement -167MW
                                             ifl
                                              i
                          -16-

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                                TABLE 1
       Space Requirements
       Wet Limestone - 167MW


     In addition to the equipment shown in Figures 1 & 2, space is required
     for tha following items:
            ITEM
                                          SPACE REQUIRED FOR
167MW
333MW
666MW
1000MW
Limestone Receiving Hopper

Storage  Silo (s)


Limestone Grinding Section
Disposal Area - TPY
          "   - Million cu.ft,
                per year
   11      "   - Acre ft. yr.
15'x 20'
20'x 20
20'x 30'
1-18'  dia  1-25'  dia  2-25'  dia  2-23'  dia
 x50'      x50'      x50'      xSG1
35'x 35
40'x 35'
40'x 70'
      2
     45
      4
     90
      8
    180
50'x 7
   xSO'H     x60'H     x60'H     x 6G

100,000    200,000    400,000    600,000
     12
    270
                                 -17-

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                              TABLE 2
       Space Requirements
       Lime Slurry - 167MW

    In addition to the equipment shown in Figures 1 & 2, space is
    required for the following items:
            ITEM
                                          SPACE REQUIRED FOR
                167MW
           333MW
           666MW
           1000MW
Lime Storage Silo(s)
   Assume lime is received
   in trucks, and can be
   pneumatically conveyed.
                1-16' dia  1-22' dia  2-22' dia  2-26' dia
                 x 50'      x 50'      x 50'      x 60'
Disposal Area -
TPY
Million cu.ft.
per yr.
Acre ft.per yr.
85,000
     1.5

    40
170,000
      3

     75
330,000
      7

    150
500,000
     10

    230
                                 -18-

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                                    TABLE 3
        Space Requirements
        Magnesium Oxide - 167MW

      In addition to the equipment shown in Figures 2 & 3,  space is
      required for the following items:
             ITEM
                                           SPACE REQUIRED FOR
167MW
 333MW
666MW
1000MW
Thickeners

Calcining Area
1-95'dia  2-95'dia    4-95' dia  4-113'dia

30'x 200' 30'x 250'   60'x 250'  60'x 300'
Drying Area

Filter & Centrifuge Bldg.
40'x 200' 40'x 250

25'x 25'  25'x 40'
            75'x 250'   75'x 300

            30'x 40'    30'x 50'
Coke Hopper - Truck
Coke Silo
Misc; MgO receiving, slurrying
      spray tower
15'x 15'
12'dia
 x 20'
12'dia
 x 30'
25'x 25'  25'x 25
15'x 15'
16'dia
 x 40'

25'x 25'
15'x 15'
16'dia
 x 50'

25'x 25'
Spray Drying Bldg.

Acid Plant
Acid Storage Tanks
30'x 30'  40'x 40'

75'x 100' 100'x 100'
2-40'dia  4-40' dia
 x 35'     x 35'
            50'x 50'    50'x 50'

            100'x 125'  100'x 150'
            8-40'dia    12-40'dia
             x 35'       x 35'
                                  -,19-

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                                 TABLE 4
           Space Requirements
           Ammonia Scrubbing - 167MW

        In addition to the equipment shown in Figures 4 & 5, space is
        required for the following items:
            ITEM
167MW
                                          SPACE REQUIRED FOR
333MW
666MW
 1000MW
Limestone Hopper
Limestone Silos

Limestone Mill Bldg.
15'x 15'
1-18'dia
 x 50'
30'x 30'
15'x 15'
1-22'dia
 x 60'
30'x 30'
15'x 15'
2-22'dia
 x 60'
30'x 40'
15'x 15'
2-24'dia
 x 70'
30'x 50'
Bohna Plant

Acid Plant

Acidifier/Stripper &
 Crystallizer Area
75'x 50'   75'x 70'   75'x 140'  75'x 175'

75'x 100'  100'x 100' 100'x 125' 100'x 150'

30'x 40'   30'x 40'   40'x 40'   40'x 50'
Settling Tank

Sulfate Reactor/Settler

Acid Storage
10'dia
10'dia
2-40'dia
x 35'
13'dia
10'dia
4-40'dia
x 35'
18 'dia
12 'dia
8-40'dia
x 45'
22'dia
12 'dia
12-40'dia
x 35'
                                 -20-

-------
                                  TABLE 5
       Space Requirements
       Sodium Scrubbing-Wellman-Lord - 167MW
    In addition to the equipment shown in Figures 4 & 5, space is
    required for the following items:
                                          SPACE REQUIRED FOR
            ITEM                167MW      333MW      666MW      1000MW
Evaporator-Centrifuge Bldg.     50'x 50'   50'x 60'   50'x 75'   50'x 100'

Crystallization Area            50'x 100'  75'x 100'  100'x 100' 100'x 125'



Acid Plant                      75'x 100'  100'x 100' 100'x 125' 100'x 150'

Acid Storage                    2-40'dia   4-40'dia   8-40'dia   12-40'dia
                                 x 35'      x 35'      x 35'       x 35'
                                 -21-

-------
                                  TABLE 6

          Space Requirements
          Sodium Scrubbing-Stone & Webster/Ionics -_167MW

     In addition to the equipment shown in Figures 4 & 5, space is
     required for the following items:
                                          SPACE REQUIRED FOR
            ITEM
167MW
333MW
666MW
1000MW
Acid Plant

Regeneration

Electrolytic Cell Bldg,

Acid Storage
75'x 100'  100'x 100' 100'x 125' 100'x 150'

50'x 50'   50'x 60'   50'x:75'   50'x 100'

50'x 60'   50'x 120'  100'x 120' 100'x 180'

2-40'dia   4-40'dia   8-40'dia   12-40'dia
 x 35'      x 35'      x 35'       x 35'
                                 -22-

-------
                         TABLE 7

            DATA REQUESTED IN APPLICABILITY STUDY
1.  General mode of transportation:  truck,  rail,  barge.
2.  Availability of raw materials:
    a.   limestone: distance to supply,  mode of transport
        or delivered cost.
    b.   special sources of  hydrated lime, lime, NH_,
        NaOH, Na2C03-
3.  Disposal of waste materials:
    a.   dissolved solids:   how much sulfate could be
        tolerated?
    b.   slurried solids: distance to settling pond?
    c.   dry solids:  distance and transport to disposal
        or cost of disposal?
4.  Special local markets  for sulfur products:  Na-SO.,
    S,  acid, others?  Quantify size of market.
5.  Availability of utilities:
    a.   clean fuel for reheat or regeneration
    b.   steam, low pressure and high pressure
    c.   power:  regular and offpeak
    d.   water: any special  problems
6.  Required level of control anticipated by the utility.
7.  Age of plant - lifetime left - will requirement of
    control costs shutdown  the plant - load factor -
    reliability factor?
8.  Space:
    a.   for scrubber?  At what cost?
    b.   for regeneration?  distance from plant?
                      -23-

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                   VI.   DISCUSSION OF RESULTS


General

     The utilities cooperating in this and the previous (1971)

study are listed in Section II of this report.  Many of the systems

studied in 1971 were not revisited this time for one or more of

the following reasons:   (Note these comments do not apply to the

14 utilities listed in Section II).


         • The utility was uncooperative and either
           could not or would not provide the necessary
           time and information needed for the study.

         • Systems had a very low percentage of units
           with space available for control units.

         • Systems had only a few plants — systems with
           a large number of plants were chosen when-
           ever possible to maximize the total capacity
           surveyed.

         • Systems did not have the necessary data readily
           available such as plot plans, drawings, etc.

In selecting a list of utilities to contact with requests for

data, several requirements had to be met, viz.;


         • In each study, a maximum of 9 different
           companies could be approached without
           approval of the contracting officer; this
           approval has to be requested in writing
           including copies of the survey plan and
           questionnaire forms (Article XV, Contract
           CPA 70-68).   Since approval of the Bureau
           of Budget is eventually required and
           usually takes 4-6 weeks minimum, the
           project officer specified that this not
           be done since the time involved would delay
           the results beyond the date needed.
                               -24-

-------
          • The data needed for this study generally are not
            available from smaller utilities since they
            usually do not have large engineering staffs.
            Thus larger utilities were indicated as the source
            of material.
          • To achieve a maximum amount of data, utilities
            with a large number of plants were desirable
            which again dictated large utilities.
          • A sampling from different geographical areas
            was desired.

In meeting the above requirements, the sampling obtained was by
necessity heavily weighted toward large utilities which in turn
resulted in a high percentage of large size, relatively new power
plants.  Thus while about 42 percent of the 1972 generating
capacity (basis oil- and coal-fired plants) was studied, only
about 15 percent of the number of plants were involved.  The
results of this study may not, therefore, be truly representative
of the entire utility industry but the scope of the task essentially
precluded any other approach.  Within the limitations imposed
by the task "ground rules" the results are valid and should be
quite useful in ascertaining the applicability of SO2~control
processes on a retrofit basis.
                                         t»
     The specific data that could be quantified from the material
collected during the survey are tabulated in Table 8;  the Utilities
that were surveyed are identified as systems 1 through 10.  Each
plant within a utility system is identified by an alphabet letter.

     Table 8 summarizes the space available for installation of any
given process.  This information was collected in each Utility's
engineering office from plot plans, aerial photographs and
interviews with responsible engineers.  Particular attention was
paid to the availability of space for scrubbers.  Area for re-
generation was estimated in a less refined manner.  The processes
which fit were determined by matching the areas for various
processes tabulated in Table 9 against those available at the
plants.
                               -25-

-------
     The complexity factor is a subjective estimate by one of
the four investigators on this survey as to the difficulty, i.e.,
cost, of installing a stack gas cleanup system on the power generating
units within a given plant.  Since the emphasis primarily was on
the scrubber part of a system, the complexity factor mainly
reflects the difficulty in installing a scrubber.  It was found
that the scrubber design is approximately the same for all pro-
cesses.  The complexity factor was estimated to vary from "1",
the cost of installation in a new plant (~25$/kw), to "3", which
was considered to be the most difficult case (=75$/kw).

     Table 8 also contains a summary of plant data and operating
characteristics.  Units which were investigated range in size from
19-1150 MW, and in age from 0-50 years.  Some of the items listed
in the table are self-explanatory; the others are discussed below.

Load Factor and Availability

     Load factor is defined as the actual power produced during
a year divided by the maximum power that could have been pro-
duced  (based on the unit running continuously for a year at name-
plate rating), expressed as a percentage.  Availability is defined
as the percentage of time during a year that the unit was available
for use, whether or not it was actually running.

     Load factors varied considerably, but more than half of the
reported values are less than 70%.  This tends to indicate that
for most plants, sufficient steam and power capacity is available
the majority of time for use in running a control process. Only
during limited peak periods would power and steam be generally
unavailable, resulting in the need to either purchase power or
reduce plant capacity in order to satisfy the demands of the
control process.

     Information on availability was difficult to obtain.  From
the values reported, however, availability seems to be maintained
at a high level.
                               -26-

-------
Complexity Factor

     In evaluating the applicability of S02-control processes
to existing power plants, some indication of cost was desirable
but specific cost estimates obviously were beyond the scope of
the task.  It was decided, therefore, to determine qualitatively,
to the extent possible, the effort required to install a control
unit.  Items to be considered included space availability, site
accessibility and degree of modification required to the site,
buildings, structures and equipment.

     In order to reduce the above variables to a common basis,
it was decided to refer the cost of all retrofits to that of a
new installation by means of a multiplying factor.  Further, this
factor is always greater than one since a retrofit will undoubtably
cost more than a new installation.  On this basis, a complexity
factor has been estimated for each power plant studied where a
control unit can be installed.

     Since reported costs for installing new wet limestone
scrubbing units fall in the range of $20-25/KW while retrofits
can cost as much as $60-70/KW for very difficult installations,
a complexity factor range of 1.0 to 3.0 was selected.  Although
this range is based on the wet limestone scrubbing process it
is assumed to apply also to other systems since the gas scrubbing
section is similar for all processes and comprises the largest
share of the cost.  In essence then, the complexity factor indicates
how much more a retrofit will cost compared to an identical
installation on a new plant.

     To reduce the data to a more useable form, the generating
capacity for each complexity factor has been determined and is
shown below:
                               -27-

-------
                      Retrofit Generating               *Cumulative
Complexity Factor     	Capacity,MW	    *Percent     Percent
       1.0                 1,037
       1.5                26,853
       2.0                 9,333
       2.5                16,012
       3.0                16,477
1.17
30.34
10.54
18.10
18.61
1.17
31.51
42.05
60.15
78.76
                          69,712              78.76
*Based on total capacity surveyed — 88,520 MW

The above results show that based on the criteria established for
this evaluation, about 42% of the generating capacity studied can
be retrofitted with S02-control units at a complexity factor
of 2.0 (~$50/kw) or less.  The data are presented graphically
in Figure 6.

     An independent statistical evaluation of the complexity
factors has been made by EPA and a copy of the results of their
evaluation is shown in Appendix A of this report.

Power Costs

     In addition to the data on the capital investment required
for installing SO^-control units, information on increases in
power production costs is also needed.  To provide an indication
of this increase the complexity factor was divided by the load
factor, thus converting relative capital investments to costs
per unit of power production.  Since capital charges generally
comprise more than half of the total operating costs of a control
unit, the incremental cost of producing power will be approximately
proportional to incremental investment.  The results of this operation
are shown graphically in Figure 7 as a function of generating
capacity.  From Figure 7 it is seen that about 50% of the generating
capacity studied could be retrofitted at relative incremental
unit power costs of 3.5 or less which corresponds to an actual
incremental power cost of about 2.0 mills/kwh, based on capital
costs only.  Other costs will add an additional 0.5-1.5 mills/kwh
so that the total incremental power costs become 2.5-3.5 mills/kwh.

                               -28-

-------
     The actual incremental power costs were calculated using
the following assumptions:

   • Annual capital charges (cost of money, depreciation,
     etc.) and maintenance costs will equal 20% of invest-
     ment.
   • A complexity factor of 1.0  (i.e., new plant) is equiv-
     alent to a $25/kw investment.
The following example illustrates the calculation involved:

   Complexity Factor = 1.0; Invest = $25/kw; Load Factor = 0.5

25$_  x 0 2   $     v innn mi3-ls  *   Vr      „  1   _ -, •, .mills
25kw  X 0.2($) (yr)  X 1000   £—  X
Thus a complexity factor/load factor (CF/LF) ratio of 2.0 (i.e.,
1.0/0.5) results in a unit cost of 1.14 mills/kwh based on capital
costs only; total costs would be 0.5-1.5 mills greater than this
value.  Note that the CF/LF ratio is independent of the actual
values of each; that is, a complexity factor of 2 and a load
factor of 0.5 produces the same results as does a combination of
4 and 1 for complexity and load factors respectively.

     The above information is valid for general use but it
should not be used for specific cases since no two power plants
will have the same distribution of operating costs.  Exact costs
for a specific case can be determined only by using the pertinent
factors that apply to that installation.  The information presented
herein is felt to be valuable, however, in that it shows approximate
ranges of incremental costs that will result from installing SO2~
control units on power plants.
                                -29-

-------
                    FIGURE
           RELATIVE INSTALLED  COST OF
          RETROFIT S02- CONTROL  UNITS
     DISTRIBUTION  OVER GENERATING CAPACITY
O
s
<
O
CD
LJ
CD
   100
   90-


   80-


   70-
o:
LJ  60-
   50-
LU
O  40 H
or
LJ
Q_
LU  30H
>

<  20 H
    10 -
             CORRESPONDS
            TO NEW PLANT
                 I
                 1.0
                (25)
                      I
                      1.5
2.0
(50)
2.5
3.0
(75)
3.5
               RELATIVE INSTALLED COST
         AND (APPROXIMATE ACTUAL COST, $/KW)
                 -30-

-------
(00
                            FIGURE ,7

            RELATIVE CONTRUBITION OF CAPITAL COST  TO

         INCREMENTAL  ANNUALIZED UNIT PRODUCTION  COST

            DISTRIBUTION OVER  GENERATING CAPACITY
90-




80-




70-




60-




50-




40 -




30-




20 -




10-

O


I
cr
UJ
z.
UJ
o
UJ
o
oc
UJ
a.

UJ
           1.0

          (0.57)
               2.0

              (1.14)
 3.0

(1.71)
 4.0

(2.28)
 5.0

(2.85)
 6.0

(3.42)
  7.0

(3.99)
                   COMPLEXITY  FACTOR/LOAD FACTOR

                          AND (MILLS/KWH)
                           -Sir-

-------
Method of Transportation

Fuel is delivered to power plants by a variety of methods,
including truck, rail, barge, tanker, pipeline, and conveyor.
In general, receiving facilities are adequate to handle
shipments of raw materials needed for a control process and
represent no hindrance to the installation of such a process.

Power plants located in urban or highly-populated areas
commonly have little available outside area for bulk storage
of raw materials.  However, since many of these plants are
coal-to-oil conversions, the storage areas and handling
facilities  (reclaimers, conveyors, etc.) originally used
for coal could be used for raw materials.  Plants in suburban
or rural areas usually have adequate open area readily available
for these purposes.

Disposal of Waste Materials

The two most common methods used for disposal of ash are:

       1)  Sluicing to settling pond.
       2)  Transfer to intermediate holdup area  (pond,
           silo, etc.) from which the ash is hauled to off-
           site disposal by contractor.

The first method is commonly employed at power plants in
rural areas, where space availability is not restricted.
The latter method is frequently used at urban sites, where
space is at a premium.

Non-regenerative control processes produce large quantities
of solid waste materials.  Plants which now contract for  ash
                            -32-

-------
disposal could dispose of process wastes similarly.  Plants
with adequate pond area could possibly use this for process
waste disposal, but potential water pollution problems
caused by seepage of soluble salts (particularly sulfates)
into the water table or by discharge of pond effluent to
nearby rivers or streams could restrict their use.

Water quality standards vary not only from state to state,
but also within a state, depending upon the specific body
of water being considered.  In most cases, the standards
have not been defined in detail and limits on dissolved
solids, especially sulfates, have not been set.  This makes
it difficult to determine whether or not ponding would be
a permissible disposal method.  Virtually all standards
restrict completely the dumping of solids into streams, rivers,
etc., and direct discharge of solids wastes cannot be considered.

Clean Fuel Availability

In virtually all cases, a clean fuel  (i.e., a "0"% S fuel)
of some type is available for use in the control process.
However, natural gas is generally not available at reasonable
cost during the winter months, when the demand is great for
use in home heating.  As a result, those plants which indicated
only natural gas as an available clean fuel would have to
stockpile gas during the summer months, purchase gas at premiums
rates during the winter months, or develop a source of supply
for other types of clean fuel.

Possible Plant Shutdowns

In only one case did a utility indicate a definite plant
shutdown if controls were imposed.  However, this should not
be taken to mean that control processes would be installed
on all other plants to curtail S02 emissions.  Rather, many
                            -33-

-------
  companies stated that plants would be converted to low-sulfur
  fuels, if available.  Several plants have already been con-
  verted and have long-term commitments for low-sulfur fuel,
  although what is meant by "long-term" is not clear.

Some items were identified and investigated during the survey
but could not be quantified for inclusion in Table 8.
These are discussed separately under the individual item headings,
                               -34-

-------
Availability of Utilities

The power companies have not investigated the problem of
supplying steam, power or water to an air pollution control
system.  Therefore, quantification of these items is not
possible but some of the aspects of supplying these can be
discussed.

Steam and power, of course, are produced in the power plants
and are available in just about any quantity desired.  A penalty
occurs because the steam or power used decreases the plant
power output.  The amount of power that can be taken from a
particular plant must be evaluated on a system basis considering
the power available at peak loads from other plants and even
other grids.  It is unlikely that all plants in a system will
install pollution control equipment simultaneously? also
the process of installing it will last several years.  If this
is the case, the Utility can factor the increased demand for
in-plant power into the planned growth rate of power production
for the Utility as a whole.

At the present time the natural source of cooling water and
process water to Utilities does not appear to be limited.
However, water treatment facilities will have to be added to
accommodate any sizeable increase in water flow over present
quantities.  Also, the presently ill-defined thermal pollution
standards and cooling water effluent standards will have to
be complied with.
                              -35-

-------
Required Level of Pollution Control
Anticipated by Utility	

At the time of the survey the required level of pollution control
was in a state of flux.  Negotiations were at a high level of
activity between the Utilities and the State pollution control
organizations.  Some aspects of the situation can be discussed.

In presenting their case as to what is presently technically
feasible, the Utilities are expressing a willingness to use,
or in many cases are already in the process of utilizing, low-
sulfur fuel (generally oil), 99.9+% efficient electrostatic
precipitators and 800-1000 ft. stacks.  The State organizations,
in manuevering to minimize the impact of the power plants on
the total environment, have expressed the position, directly
or indirectly, that air pollution cannot be reduced at the ex-
pense of increasing water pollution.  The controls for the
immediate future will come out of these discussions.

If the States determine that the immediately available technology
will not meet the local environmental requirements, then Utilities
are faced with adapting new technology to power generation to
meet future pollution laws.  This is superimposed on the vast
power plant expansion now in progress.  Nearly all utilities
have more power production on the drawing boards or in con-
struction than they have in operation.  The new plants have
provisions for pollution control which will probably be state-
of-art at the time of construction.  The argument that appears
to come through in discussions with the Utilities is that the
increase in power production is their prime goal, economically
                    t
and socially, and they don't feel this can be done with un-
proven equipment.  Present scrubber technology is placed in
this category and they fear that large scale utilization of
scrubbers would jeopardize not only future but present power
                              -36-

-------
producing capacity.  Coal gasification, either pipeline gas or
onsite low-Btu gas, is looked upon as a competitor to scrubbing.
Also, the utilities seem open to new techniques for burning
coal.  Future pollution controls will depend as much on the
vagarities of technological development as on any discussion
that can presently be held.
                              -37-

-------
Availability of Raw Materials

     Most of the utilities contacted during this study could
furnish no information on raw materials availability, poten-
tial suppliers, distance to source of supply, or cost unless
they had considered a particular process for a prototype
installation or for planning purposes.  This type of information
is difficult to get for a particular power plant site and would re-
quire considerable effort, beyond the scope of this study, to
obtain.

     In .general,raw material availability should not be a problem.
The absorbent materials used in the typical processes con-
sidered are:

         • Limestone
         • Lime  (or hydrated lime)
         • Magnesium oxide
         • Ammonia
         • Caustic  (sodium hydroxide)
         • Soda ash (sodium carbonate)

These are common chemicals which are produced in substantial
quantities and should be readily obtainable in most areas where
they might be needed by power plants.  For example, results of one
recent study  (Availability of Limestones and Dolomites, Task #1
Final Report, Contract No. CPA 70-68) prepared for EPA by the M. W.
Kellogg Company show that limestone is generally available throughout
the U.S. but in some locations transportation costs will be high,
as discussed below.

     In addition, materials which would otherwise be considered as
waste products could be used as absorbents, e.g., calcium carbide sludge
In some cases,  the raw-materials,  although available,  could be costly.
                                -38-

-------
This is the case, for example, for limestone in the Northeast.
For many plants in this area, particularly for coastal plants,
an adequate source of limestone is not nearby, and transpor-
tation charges could greatly increase the cost of this
material to utilities.
                           -39-

-------
Potential Markets for Sulfur Products
    A variety of products can be recovered from S0~-control
processes, primarily elemental sulfur, sulfuric acid, and
liquid sulfur dioxide.  Other products, chiefly sulfites and
sulfates, can also be obtained.  Most of the utilities sur-
veyed had little or no information on potential markets for
any of these products.  This information could best be obtained
by a market study for each plant.

    From discussions with the utility  companies, some gener-
alizations can be made.  The composition and purity of pro-
ducts from control processes is not normally known.  Conse-
quently, their compatibility with specifications for raw
materials of potential users cannot be determined.  In other
words, it is not known whether these materials would be salable.
Also, the willingness of potential users to switch from normal
raw material suppliers to power plants as a source is question-
able.

    Markets must be nearby, within about 50 miles.  Utilities
could not afford to ship products any considerable distance.
Power companies generally do not want to get into the chemical
business and would therefore prefer  to sell all of the product
to a single user through long-term contract if possible.  Other-
wise they might have to set up a sales and marketing organization,

    In investigating a potential market, consideration must be
given to the amount of material produced.  If power plants
                           -40-

-------
installed control processes on a large scale, it may well be
that the additional quantities of sulfur products would glut the
market.  For example, converting the estimated SO2 emissions
from all U. S. power plants in 1969 to an equivalent amount of
sulfuric acid would approximately double the supply of acid.
Although it is unlikely that this type of situation would occur
on such a large scale, it is quite possible for it to happen in
small areas.
                           -41-

-------
System      1
MWe       5950
                                            TABLE  8
                                    SUMMARY  OF POWER PLANT DATA

Plant/
Size
MW

A/400


1
i
B/2204



C/330



D/410



E/791




i
Unit
Size
MW

2-110

1-180

2-400

2-702

2-80

1-170

3-40

2-145

2-401'

2-70'

1-571

Age
Yrs

21

14

7

3

23

17

30

19

32

,24

0

Fuel
4
Coal
15%Ash
1%S

"coal
15%Ash
1%S

Coal
15%Ash
1%S

"coal
15%Ash
1%S

Coal
15%Ash
1%S


Load Factor/
Availability/
Percent

94/88

92/93

93/93

107/75

85/95

94/93

74/88

90/96

80/95

90/88


AREA AVAILABILITY
Scrubber
Area,

10,000

5,000

30,000

40,000

10,000

5,000

15,000

10,000

10,000

10,000

15,000
Regeneration
Area, ft2
Dist. From
Scrubber ,ft

Unlimited

@ 2500

Unlimited

@. 2500

Unlimited

@ 2500

Unlimited

@ 2500

Unlimited

@ 2500


Waste Disposal
Area

5 yrs



7 yrs



7 yrs



5 yrs



10 yrs




Dist.

NA



NA



•NA -



NA



2500
feet



Method

Sluice



Sluice



Sluice



Sluice



Sluice





Clean
Fuel
Avail.

Dump Nat .
Gas*
#2 Pipe-
"line
Dump Nat .
Gas
#2 Pipe-
line
Dump Nat .
Gas
#2 Pipe-
line
Dump Nat .
Gas
#2 Pipe-
line
Dump . Nat
Gas
£2 Pipe-
line


Complexity
Factor

• 2.5

2.5

2.5

2.5

2.5

2.5

2.5

3.0
>
2.5

2.5

1.5

-------
System
MWe
                                             TABLE   8

                                    SUMMARY OF POWER PLANT DATA
5950
"" ••• 	
Plant/
Size
MW
F/1285




G/530




i
Unit
Size
MW
2-180

2-305

1-315
2-115

2-150



Age
Yrs
15

12

11
20

18

\

Fuel
Coal"
15%Ash
1%S


Coal"*
15%Ash
1%S


Load Factor/
S.vailabilityf
Percent
95/95

93/93

97/90
88/89

95/90


AREA AVAILABILITY
Scrubber
Area,
ft2'
10,000

16,000

10,000
10,000

10,000


Regeneration
Area, ft2
Dist. From
Scrubber , f t
Unlimited

@ 2500


Unlimited

@ 2500


Waste Disposal
Area
10 yrs




5 yrs "


•

Dist.
NA




NA




Method
Sluice




Sluice





Clean
Fuel
Avail.
Dump Nat .
Gas
#2 Pipe-
line

Dump Nat.
Gas
#2 Pipe-
line
-

Complexity
Factor
2.5

2.5

2.5
2.0

2.0



-------
                                      SUMI4ARY OF POWER PLANT DATA
System
MWe
          4289

Plant/
Size
MW
A/229




5
B-480


•

5
C-360



5D-225




\Jnit
Size
MW
1-87



1-142

'2-90



1-300
2-180



1-80




1-145
}
i
1


t


Age
Yrs
27





22




13



20

-










Fuel
Coal6
7-25%
Ash
4%S

6
Coal
7-25%
Ash
4%S

Coal7
7-25%
Ash
4%S
Coal8
7-25%
Ash
4%S


Load Factor/
Availability!
Percent
43/NA





64/NA




68/NA



75/NA





i
j

AREA AVAILABILITY
[Regeneration
Scrubber ATP>S . -f-t-2
Area.
ft2'
5,000



5,000

10,000



10,000
20,000



5,000




Dist. From
Scrubber , f t
Unlimited
@ 2500




40,000 @
1500



80,000 @
2000

.m
Unlimited
@ 2500



5,000 j
1
;
i








Waste Disposal
Area
127 acr<





83 acr<




216
acres


200
acres








Dist.
5 3 mi





j 3 mi


-

3 mi



3 mi









Method
Truck
to Dump



Truck
to Dump




Truck t<
Dump


Truck
to Dump








i
1

Clean
Fuel
Avail .
#2 8 90C/
MMBtu

•

#2 8
9 0<= /MMBtu




) #2 8
90<:/MMBt\


#2 8
9 0« /MMBtu











Complexity
Factor
2.5



2.5
3.0




3.0
2.5



2.5












-------
                                   SUMMARY  OF  POWER PLANT DATA
System     2
MWe      4289


1
&






Plant/
Size
MW
E-245


F-1100

G-1650


1




i
Unit
Size
MW
1-59

1-186
2-550

3-550



^



Age
Yrs
22


4

2







Fuel
Coal8
7-25%
Ash
4%S

Coal6
7-25%
Ash
4%S
Coal6
7-25%
Ash
4%S





	 i
Load Factor/
Availability,
Percent
67/NA


72/NA

68/NA







AREA AVAILABILITY
Scrubber
Area,
5,000

5,000
20,000

45,000




Regeneration
Area, ft2
Dist. From
Scrubber , f t
Unlimited @
2500


Unlimited @
2500

40,000 @
1500




i
!


Waste Disposal
Area
NA


NA

223
acres






Dist.
<1 mi


NA

3 mi






i
i
Method
Sluice
to pond


Truck tc
Dump

Truck
to Dump






Clean
Fuel
Avail.
#2 @.
90
-------
                                    SUMMARY OF POWER PLANT DATA
System    3
MWe     2458

Plant/
Size
MW
A-531
B-886
i
C-640
i
Unit
Size
MW
1-531
4-100
1-125
1-361
4-160
Age
Yrs
1
18-21
u-
14
Fuel
Coal"
12.7%
Ash
2.3%S
Coal"
9.8%
Ash
2.5%S
Coal
9.8%
Ash
3.3%S
Load Factor/
Availability,
Percent
NA
68/79
79/NA
61/NA
68/81
	
AREA AVAILABILITY
[Regeneration
Scrubber Area/ft2
Area, JDist. From
ft2 |Scrubber,ft
Unlimited
None
None
80,000
None
135,000
@ 600
Unlimited @
1300

Waste Disposal
Area
265
acres
59
acres
45
acres
Dist .
ad j .
2000
feet
ad j .
Method
Sluice
Sluice
Sluice

Clean
Fuel
Avail.
#2 oil
82<=/MMBtu
#2 oil
82C/MMBtu
#2 oil
82<=/MMBtu
Complexity
Factor
1.5
1.5
i

-------
                                     SUM14ARY OF POWER  PLANT DATA
System
MWe
          6620

Plant/
Size
MW

5A-1932









,
1
r




B-908












i !
Unit i
Size
MW

2-176





2-180


1-336


1-346

1-538

1-284




1-275



1-349



Age
Yrs

18





18


12


12

3

16




16



14

Fuel
i i
Load Factor/
Availability
Percent

Coal &| 62/NA
Gas



i i
Coal &
Gas
i i
Coal &
(lac
\JCL O
1 1
Coal &
Gas
Coal

i i
Coal &
Gas,


i i
Coal &
Gas

1 1
Coal &
iGas

i





62/NA


85/NA


85/NA

90/NA

85/NA




85/NA



85/NA



AREA AVAILABILITY
[Regeneration
Scrubber! Arpa.f-h^
Area
ft2

]


I
> 6,000
I
J
J

1
1
V15,400
J

5,000

None




None


Dist. From
Scrubber ,ft

195,000 @
1400














600,000 @
, 1500






i
2400 i
1






Waste Disposal
Area

462
acres














60
acres











Dist.

5 mi















10 mi











:
1
Method

Trucked
by
Contrac-
tor
Offsite











Trucked
by
Contrac-
tor
Offsite







Clean
Fuel
Avail .

#6-LO S
Oil-

4












#6-LO S
Oil



#2 Oil
8 82«/
MMBtu







Complexity
Factor

3.0





3.0


3.0


3.0

3.0

__




--



3.0




-------
                                    SUMMARY  OF  POWER PLANT DATA
System
MWe
          6620

Plant/
Size
MW
5
C-1143







i
i

D7-1622













Unit
Size
MW

6-50




1-145



1-126
1-542
2-811









Age
Yrs

48




21



21
4
1














Fuel

Coal
12%
Ash
2.9%S







Coal"
13.7%
Ash
4%S

<










Load Factor/
Availability
Percent

NA




60/NA



60/NA
90/NA
90/NA








AREA AVAILABILITY
Scrubber
Area,
ft2

None




None



None
20,000
60,000








Regeneration
Area , ft
Dist. From
Scrubber ,ft

105,000 @
2100









Unlimited




•



i

i





Waste Disposal
Area

60
acres









25
years












Dist.

5 mi









*
1. 5mi













Method

Trucked
by
Contrac
tor
Offsite






Sluice












_- — — . — ,

Clean
Fuel
Avail .

#6-LO S
Oil-

•

#2 Oil
6 82
-------
                                      SUM14ARY OF POWER PLANT DATA
System
MWs
          7419

Plant/
Size
MW
A- 800

1 0
B-240
C-1539
i
if


D-490
i


i
i
Unit
Size
MW
3-100
1-500
4-60
1-250

1-319
1-481
1-490
2-245



Age
Yrs
18

12
7

5
4
3
9



Fuel
Coal
15%Ash
3%S

Coal*
15%Ash
3%S
Coal
15% Ash
3%S



»
^Coal
15%Ash
3%S



Load Factor/
Availability,
Percent
NA

NA
NA




NA



AREA AVAILABILITY
Scrubber
Area ,
18,000
20,000
None
6,500

8,000
12,500
12,500
12,500
Regeneration
A>-ea,ft2
Dist. From
Scrubber , f t
Unlimited @
2500


200,000 @
2000




120,000 @
2000
i




Waste Disposal
Area
NA

NA
NA




NA



Dist.












Method
Sluice
to
Pond

Sluice
to
Pond
Sluice
to
Pond




Sluice
to
Pond



Clean
Fuel
Avail .
#2
90
-------
                                    SUMMARY OF POWER PLANT DATA
System
MWe
         7419

Plant/
Size
MW
E-1250
i
ji
D
1
F-3100





i
Unit
Size
MW
3-100
2-125
2-350
2-700
2-850




Age
Yrs
22
15
0
1
0




Fuel
Coal"*
15%Ash
3%S

Coal"*
15%Ash
3%S




i - i
Load Factor/
Availability,
Percent
NA

NA


i
AREA AVAILABILITY
Regeneration
Scrubber Area, ft2
Area, pist. From
ft2 Scrubber, ft
>20,000
20,000
45,000
45,000


j


Unlimited @
2500

Unlimited @
2500





Waste Disposal
Area
NA

NA





Dist.








Method
Sluice
to
Pond

Sluice
to
3ond






Clean
Fuel
Avail.
#2
90<:/MMBtU
• •
#2
90<=/MMBtu





Complexity
Factor
1.5
1.5
1.5
1.5
1.5





-------
                                    SUMMARY OF POWER PLANT  DATA
.System
MWe

Plant/
Size
MW

A-1980
.


i
i

B-1396




C-823




5
D-1700



Unit
Size
MW

5-141


1-150
1-550
1-575

2-200


2-223
1-550
1-223


3-200


4-175


5-200
Age
Yrs

20


20
8
11

17


17

17


16


18


17
Fuel
7
Coal




i i
Coal




*
Coal




8
Coal



Load Factor/
Availability,
Percent

55/NA





56/NA




57/NA





64/NA



AREA AVAILABILITY
t
v



j
]




j

•>




Scrubber
Area,
^
)
/ Roof
r Mount
1
*. 20,000



• 80,000

40,000
,

" 80,000


> 30,000
Regeneration
Area, ft2
Dist. From
Scrubber , f t

87,500 @
150




Unlimited @
1700



490,000 @
1400




72,000 @
1000


Waste Disposal
Area

270
acre




495
acres



166
acres




335
acres


Dist.

600
feet



,
1200*
feet



800
feet


' i

400'
feet


Method

Sluice





Sluice




Sluice





Sluice




Clean
Fuel
Avail.

.

,








'

•







Complexity
Factor

3.0


3.0
1.5
1.5

2.0


2.0
2.0
1.5


1.5


1.5


1.5

-------
                                   SUMMARY OF POWER PLANT  DATA
System
MWe
         13891

Plant/
Size
MW
E-1486



i
01
I
F-1256


G-950


Wit
Size
MW
4-125

2-147


4-173

2-300

2-328
1-950



Age
Yrs
20-
21
19-
20

13-
14
16

13
7

-

Fuel
Coal1 '






Coal


Coal"*

*
Load Factor/
Availability
Percent
52/NA






64/NA


63/NA


AREA AVAILABILITY
Scrubber
Area ,
Roof
Mount
Roof
Mount



10,000

10,000
30,000

•
Regeneration
Area , f t2
Dist. From
Scrubber ,ft
700,000 @
2000





270,000 @
1000

210,000
@ 1500

Waste Disposal
Area
211
acres





473
acres
*
157
acres

Dist.
2400






.1500


1600


Method
Sluice






Sluice


Sluice



1 5 •=• -^
Fuel
Avail.
*











•

Complexity
Factor
3

3


3

2

2
1.5



-------
                                    SUMMARY  OF  POWER PLANT DATA
System    g
MWe      13891

P T 3T-V +• /
r1 .LC.U ~/
Size
MW
H/1750
J-2550

Hi
f


'i .
Unit
Size
MW
10-17!
2-700
1-115C



Age
Yrs
; 16-
19
Q




Fuel
Coal1 J
1 6
Coal




Load Factor/
Availability^
Percent
71/NA
61/NA




AREA AVAILABILITY
[Regeneration
. Scrubberi Area, ft2
Area, Dist. From
ft2 Scrubber, ft
180,000
50,000
40,000


..
600,000 @
1500
100,000 @
900
100,000 @
700



Waste Disposal
Area
145
acres
386
acres




Dist .
2400
feet
1000
feet

•


Method
Sluice
Sluice





1 5
Clean
Fuel
Avail .


• '



Complexity
Factor
1.5
1.5
1.5


!
1
i
I

-------
                                   SUMMARY OF POWER  PLANT  DATA
System    7
MWe      9678

il i
P'ant/ i Un-i t
Size Size Age
MW MW Yrs F
T
A-572 1-198 19 C



1
I
1-374 13


i
/B-2087 4-75 NA C


i


1 jl-107 18
1-360 12

J2-660 7
i
1 j
AREA AVAILABILITY
Regeneration
Lead Factor/ Scrubber' Area,fr^
Availability,
uel Percent
9
oal 87/NA

Area,
ft2

3000


i
i


87/NA

Unlimited
i
j
oal NA

i

None




1
52/NA
None
64/NA None
i i
70/NA 45,000

I i 1 7
! C-1232 2-616 4 Coal 45/NA
i
s


Unlimited


! D-1120 2-55 28 \Coal* 30/NA JNone

2-105 26
11-800 1

; j
i
40/NA JNone
NA 120,000


pi st. From
Scrubber , f t

200,000 <§
1000







100,000 @
600









240,000 @
500

350,000 @
Waste Disposal
— — 	 — i • 	
Area Dist.
i
i - -

NA








NA










10
Years

NA

i








,










2000
feet

(
1500
;



•
i 	 - -
]
i

Method

:ontrac-
tor
)ffsite






:ontrac-
tor ;
Land
Fill







Land
Fill

lontract-
or
)ffsite

Clean
Fuel
Avail .

Nat. Gas
#2 Oil
80-100C/
MMBtu
















— • -• —





i
i
i ' i
i i

Complexity
Factor

3-0





2.0


_ _



i

j
1

1.5

1.5


—


3.0



-------
                                     SUM14ARY OF POWER PLANT DATA
System
MWe
          9678

1
Plant/
Size
MW
E-692
F-1042
i

G-1269


-
i



Unit
Size
MW
4-173
5-48
1-121
1-326
1-355
1-188
1-184
1-299
1-598




Age
Yrs
17-
20
NA
NA
14
9
17
17
15
o



Fuel
oil9
Coal

Goaf






i
Load Factor/
Availability/
Percent
56-65/NA
32/NA
64/NA
75/NA
71/NA
62/NA
54/NA
78/NA
61/NA


AREA AVAILABILITY
Regeneration
Scrubber Area, ft2
Area, pist. From
ft2 Scrubber, ft
27,500
None
None
Unlimited
Unlimited
Has
Scrubber
4500
5000
16,000


1


180,000 @
900
110,000 @
400

200,000 @
1400

'





Waste Disposal
Area
NA
~0

NA







Dist .











Method
Contrac-
tor
Offsite
Contrac-
tor

:ontrac-
tor







Clean
Fuel
Avail .
•
--









Complexity
Factor
2.0
2.5
2.5
—
3.0
3.0
3.0





-------
                                    SUMMARY OF POWER PLANT DATA
System    7
MWe     9678

Plant/
Size
MW
H-980




J-684

i
Ul
i


i
'Unit
Size
MW
1-225

1-170
1-225
1-360
1-99

1-225

1-360

Age
Yrs
24

23
16
10
44

14

11
\
Fuel
Coal




9
Gas

Coal

Coal

Load Factor/
Availability
Percent
39/NA

65/NA
76/NA
NA
14/NA

57/NA

63/NA

AREA AVAILABILITY
Scrubber
Area,
ft2
None

None
4000
None


1
>30,000
J

Regeneration
Area, ft2
Dist. From
Scrubber , f t
60,000 @
500
62,000


50,000 @
400




Waste Disposal
Area
0




NA


•


Dist.
.




(
«•




Method
lontract-
or
Dffsite


lontract-
or
Dffsite




Clean
Fuel
Avail.
:

-







*
Complexly
Factor


	
3.0
	


2.5

2 .0


-------
                                   SUMMARY OF  POWER PLANT DATA
System
MWe      6251
8

Plant/
Size
MW
A/1650



B-653


C- 599

i
i


Unit
Size
MW
4-125
1-350

2-400
2-327


1-300


1-219

1-80

Age
Yrs
21-
24
10


11


15




0
-
Fuel
^ • -i1 9
Oil



9
Coal


1 8
Oil




*
Load Factor/
Availability/
Percent
55/90



75/78


75/91


75/80


AREA AVAILABILITY
Scrubber
Area,
29,000
13,500

22,000
46,000


•»

>25,000


50,000
Regeneration
Area , ft
Dist. From
Scrubber ,f t

400,000 @
1200

190,000 @
1500




180,000 @
800

Waste Disposal
Area
0.25
years



1.5
years

0





Dist.
1300
feet



1200
feet
*
__





Method
Contrac-
tor
Offsite


Contrac-
tor
Offsite
None
Offsite





Clean
Fuel
Avail.
Nat. Gas.
.


Nat. Gas
#2 Oil

Nat. Gas
#2 Oil



•

Complexity
Factor
2.5
2.0

1.0
1.5


2.0


2.0

2.0

-------
                                   SUMMARY OF POWER  PLANT  DATA
System
MWe
6251

pi ant/
Size
MW
D-619



E-1115



i
5

F-503



G-650


i
Unit
Size
MW
2-148



1-425





1-690
2-140


1-223
2-325



Age
Yrs
20






4



30


17
13

11

Fuel
oil9


9
Oil,
Coal





Oil9



oil18


L d F ctor/
Availability,
Percent
57/86



80/80






50/81



75/75


AREA AVAILABILITY
Scrubber
Area,
ft2
12,500



8,500





11,000
)
/
^40,000
1
20,000


Regeneration
Area ft
Dist. From
Scrubber , f t
94,000 @
450


170,000 @
1000





100,000 <§
600


200,000 @
• 400

Waste Disposal
Area
0



0.4
years





1.2
years-


1.3
years

Dist.




1400
feet





1400
feet


700
feet

Method
Contrac-
tor
Offsite

Contrac-
tor
Dffsite




Contrac-
tor
Offsite

Contrac-
tor
Offsite

Clean
Fuel
Avail .
Nat. Gas
#2 Oil
•

Sat. Gas






None



Nat. Gas



Complexity
Factor
2.0



2.5





1.5
2.5


2.5
2. 0



-------
                                        SUMMARY OF POWER PLANT DATA
    System

    MWe
             1990

Plant/
Size
MW
5
A-154



B-7605



C-1219







D-458


Unit
Size
MW

6-22


3-6
2-380



3-50



2-156
1-156


3-90



Age
Yrs

50


30
5-7





11-
lS

0


18-
23


Fuel
1 8
Oil



oil18


1 8
Oil






1 2
Oil


Load Factor/
Availability
Percent

45/95



69/90



75/90



55/90



60/90


AREA AVAILABILITY
Scrubber
Area,
_


9600
)
7200



NA



34,000
Now
Installed

20,000


Regeneration
Area , ft
Dist. From
Scrubber , f t

@ 180



120,000 @
500


204,000 @
1200





«
720,000 @
1500

Waste Disposal
Area

0



0



0

•





0


Dist.

	



	 .


• „
	







	

i
Method

Contrac-
tor
Offsite

Contrac-
tor
Offsite

Contrac-
tor
Offsite





Contrac-
tor
Offsite

Clean
Fuel
Avail.

#2 pil

-

#2 Oil



#2 Oil







#2 Oil



Complexity
Factor
2
3.0


3.0
3.0







3.0
	
!

3.0


I
Ul

-------
                                    SUMMARY  OF  POWER  PLANT DATA
System
MWe
10
          2718








1
Plant/
Size
MW

A-2175




Ch
o
1









B-115


C-230


D-198

Unit
Size
MW

2-175



3-225


2-800
1-115


2-115


2-99


Age
Yrs

10



8


1.5
10


12


- 17


Fuel
i
Coal
22%Ash
.65%S





Coal
9% Ash
.5%S
Gas
or Oi]
*
Gas3
or Oi]
Load Factor/
Availability/
Percent
7
88/NA



88/NA


74/NA
95/NA


43/NA


35/NA

AREA AVAILABILITY
Scrubber
Area,
^
1
/
(
> 75,000
J


135,000
15,000


90,000


20,000

Regeneration
Area, ft2
Dist. From
Scrubber , ft

Unlimited @
1,000






30,000 @
100

100,000 @
500

Unlimited @
600
Waste Disposal
Area

1048
acres





•
240
acres

160
acres

Unlimit
ed
Dist.

2 mi







1 mi


NA


r NA

Method

Sluice







Sluice


__ _


_ _


Clean
Fuel
Avail.

Nat* Gas
40C/MMBtu
•





Nat. Gas
60
-------
                             FOOTNOTES
 1.  Excludes small units and those being retired.

 2.  Controls may shut down Plant A.

 3.  Truck, Rail and pipeline transportation available.

 4.  Rail transportation available.

 5.  Cannot accommodate process #3.

 6.  Truck and barge transportation available.

 7.  Truck, rail and barge transportation available.

 8.  Truck and rail transportation available.

 9.  Barge transportation available.

10.  Cannot accommodate any process.

11.  Rail and barge transportation available.

12.  Tanker transportation available.

13.  Controls will shut down plant.

14.  Information not available but availability believed to be
     high.

15.  Information not available but clean fuel believed to be
     generally unavailable.

16.  Truck transportation available.

17.  Conveyor from mine mough.

18.  Pipeline transportation available.

19.  Barge and pipeline transportation available.
                               -61-

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                            TABLE  9


                   REGENERATION PROCESS AREAS*
                              (FT2)


                                                                   (6)
3,100
5,000
6,900
8,900
10,800
12,700
1,300
2,500
3,800
5,000
6,300
7,500
45,800
66,900
88,000
109,200
130,300
151,400
21,200
29,300
37,300
45,400
53,400
61,500
21,300
28,900
36,400
44,000
51,500
59,100
18,700
28,000
37,400
46,700
56,100
65,400
  No. of    Approx.
Scrubbers _ MW      Limestone  Lime    MgO     NH3     W-L

     1        167
     2   >    333
     3        500
     4        667
     5        835
     6       1000
   One scrubber is needed for each 167 MW
   *Areas are derived from Tabulations listed in Section IV
    Basis of Evaluation.
    Process

    (1)  Limestone slurry scrubbing.
    (2)  Lime slurry scrubbing.
    (3)  Magnesium oxide scrubbing with regeneration.
    (4)  Ammonia scrubbing — Bohna regeneration
    (5)  Sodium scrubbing — Welman-Lord  (Wellman-Power Gas, Inc.)
    (6)  Sodium scrubbing — Stone and Webster/Ionics
                                 -62-

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APPENDIX  A
       -63-

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     EPA STATISTICAL ANALYSIS OF KELLOGG APPLICABILITY SURVEY
     The Kellogg data have been evaluated to determine the rep-
resentativeness of the sample and to determine trends in the mag-
nitude of the complexity factor.  The survey sample is heavily
weighed toward the larger, newer plants.  Boiler unit size is
strongly correlated with unit age.  There is good evidence that
newer, larger units are easier to retrofit than older, smaller
units.

     Mitre Corporation has prepared a distribution of new and
existing power plants over size and age from FPC data.  The plant
size distribution for existing  (1970) coal and oil-fired utilities
is compared to the Kellogg sample in Figure 1.  Kellogg covered
essentially all of the plant capacity over 1000 MW but only 6%
of that under 400 MW.  60% of the plants in the Kellogg sample
are larger than 1200 MW, but 50% of the actual plants are larger
than 700 MW.

     Figure 2 illustrates the distribution of complexity factor
versus number o-f  units (not plants) for six combinations of age
and size intervals.  The data presented include 90% of the units
surveyed by Kellogg.  Essentially all of the units over 500 MW
were built in the last ten years.  Most of the surveyed units
under 100 MW are over 20 years old. Very few units were surveyed
in the following blocks:

             1)  0-99 MW, 0-19 years
             2)  100-199 MW, 0-9 years
             3)  200-499 MW, 20 + years
             4)  500 + MW, 10 + years
There are very few existing, large, but old units as  in blocks-
3 and 4, but the Kellogg trend of looking at large systems and
plants probably prevented a representative sample of  existing,
                               -64-

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small, but new units as in blocks 1 and 2.  These units would be
more prevalent in smaller systems and plants.  The block covering
200-499, 0-9 years has a smaller sample size than any other of
the blocks presented, and its results are questionable.

     There appears to be strong trends of complexity factor with
unit size and age as illustrated in this summary table:

            Table 2:  Average Block Complexity Factors
                            Age (Years)

                             0-9          10-19          20 +
       0-99                   -             -             3.05
size  (MW) 100-199             -           2.37            2.79
     200-499                 2.32         2.16
     500 +                   2.05

Age appears to be most important in older units and size in younger
units, though differentiation of age and size is very difficult
since they correlate so well for this sample.  More data on the
newer, smaller units would permit a better understanding of size
effects on complexity factor.

     Evaluation of the complexity factor was done on unit size
and age, not plant size and age.  We have no readily available
distribution of actual boiler units on the basis of unit size and
age.  However, the Kellogg sample will probably be more represen-
tative on the basis of unit data that on the basis of plant data.
Nevertheless, the distribution of complexity factors over actual
boiler unit population will not be the same as Kellogg's distribution
and all-inclusive conclusions should await an analysis on the
basis of actual unit data on size and age.
                               -65-

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                              Figure 1:   Distribution of Sample Over Plant  Size
                                         Mitre Census and Kellogg Survey

                                         Total Mitre Census MW = 264,715
                                         Total Kellogg Survey MW = 56,57.1
50-
40.
30_
-P
•H
u
20.
(0
u_

•H
n3
-P
     4J
     fi
     (U
              	i
                                                                                         -I-
           Census Survey
             0-500
                                Census Survey
                                500-1000
Census Survey
 1000-1400
Census Survey
  -  1400
                                                    Plant Size  (MW)

                                                       -66-

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   Unit size:  0-iGO HW
   Unit age :  ?0 + vrs.
Sample size :  47 units
Average complexity:  3.05
  60

  40 \

  20
                                       tompiexity  factor
                              100 - 200 MW
                               10 - 19 yrs.
                               57 units
                             • 2.37 average
     1.0   1.5
2.0
      3.0   >3.0
1.0    1.5
2.0    2.5
3.0
      100 -  200 MW
        20 + yrs.
        40   units
      2.79   average
                               200 - 499 MW

                                 0-9 yrs.
                                17   units
                               2.32  average
  60

  40


  20
    1.0   1.5
2.0
2.5    3.0   >3.0    1.0    1.5
               2.0    2.5
                                                                                        to
                                                                      c
 3.0   >3.0
      200 - 499 MW
      10 - 19 yrs.
      46   units .
     2.16  average
                               500 + MW
                               0-9 yrs.
                               33 units
                               2.05 average
     1.0     1.5
        2.5    3.0
               3.0
                                                               2.0     2.5
                                                           3.0   -3.0
                                        Complexity factor

                     Figure 2:  Distributions of Complexity Factor

                                          -67-

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