EPA-450/3-77-048
December 1977
                        IMPACT
           OF MODIFICATION/
            RECONSTRUCTION
     OF STEAM GENERATORS
            ON SO2 EMISSIONS
  U.S. ENVIRONMENTAL PROTECTION AGENCY
      Office of Air and Waste Management
   Office of Air Quality Planning and Standards
   Research Triangle Park, North Carolina 27711

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                                  EPA-450/3-77-048
                IMPACT OF
MODIFICATION/RECONSTRUCTION
       OF STEAM GENERATORS
           ON SO2 EMISSIONS
                       by

               M. Bornstein, P. Fennelly,
                R. Hall, and D. Roeck

                  GCA Corporation
                GCA/Technology Division
                  Burlington Road
                Bedford, Massachusetts

                Contract No. 68-02-2607
                Work Assignment No. 3
   EPA Project Officers:              Program Manager

 K.R. Durkee & K.R. Woodward            Joseph A. McSorley


                    Prepared for

            U.S. ENVIRONMENTAL PROTECTION AGENCY
             Office of Air and Waste Management
         Office of Air Quality Planning and Standards
         Research Triangle Park, North Carolina 27711

                   December 1977

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This report is issued by the Environmental Protection Agency to report
technical data of interest to a limited number of readers.  Copies are
available free of charge to Federal employees, current contractors and
grantees, and nonprofit organizations - in limited quantities - from the
Library Services Office (MD-35), Research Triangle Park, North Carolina
27711; or, for a fee, from the National Technical Information Service,
5285 Port Royal Road, Springfield, Virginia 22161.
This report was furnished to the Environmental Protection Agency by
GCA Corporation, GCA/Technology Division, Burlington Road, Bedford,
Mass., in fulfillment of Contract No. 68-02-2607, Work Assignment No. 3.
The contents of this report are reproduced herein as received from GCA
Corporation.  The opinions, findings, and conclusions expressed are
those of the authors and not necessarily those of the Environmental
Protection Agency.  Mention of company or product names is not to be
consideredjas an endorsement by the Environmental Protection Agency.
                 Publication No. EPA-450/3-77-048
                                11

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                                  ABSTRACT
     This report discusses the terms "modification" and "reconstruction" as
related to New Source Performance Standards (NSPS) for SC>2 emissions from
coal-fired boilers greater than 250 million Btu per hour input.  An analysis
of current boiler technology indicates there are few physical or operational
changes that would qualify as modifications or reconstruction in the sense of
altering SC>2 emissions from a boiler system.  This is true because SC>2 emis-
sions are a function of the sulfur content of the fuel and are not affected
by furnace and boiler design and operating parameters.  Two situations which
could be construed as modifications affecting SC>2 emissions would be conver-
sion of a wood burning facility to coal or the use coal/oil slurries in a
boiler originally designed for oil.  Neither of these are expected to be
widespread occurrences.  First, there are few wood-fired boilers in the size
range covered by NSPS and, secondly, it is doubtful there would be any incen-
tive for such units to switch from a cheap waste fuel to a more expensive
primary fuel.  Boilers using coal/oil slurries have only recently been pro-
posed and are still at an experimental stage.

     Also discussed in this report are some of the constraints that could
inhibit an existing facility from installing flue gas desulfurization
equipment.
                                     iii

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iv

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                                   CONTENTS


Abstract	iii

     1.   Introduction and Summary 	    1
     2.   Modifications of Coal-Fired Power Plants 	    2
               Modification as Covered by NSPS	    2
               "Modifications":  Their Effect on Coal-Fired Power Plants
                 and S02 Emissions	    3
     3.   Reconstruction of Coal-Fired Power Plants	    6
               Reconstruction as Covered by NSPS	    6
               Reconstruction/Coal-Fired Power Plants	    6
     4.   Constraints Preventing Application of FGD	    7
               Land Restrictions 	    7
               Constraints Caused by Equipment Configurations	    8

References	   11

Appendices

     A.   Economics of New Construction, Repair and Maintenance	   12
               New Construction	   12
               Repair and Maintenance	   12
               References	   20
     B.   List of Individuals Contacted	   21

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                                  SECTION 1

                          INTRODUCTION AND SUMMARY
     New Source Performance Standards (NSPS) were promulgated by the Environ-
mental Protection Agency (EPA) on December 23, 1971, as part of 40 CFR Part
60.  Fossil fuel-fired steam generating units larger than 73 megawatts (250 x
10^ Btu per hour) heat input were covered under subpart D.

     The limit on emissions of sulfur dioxide from affected coal-fired facil-
ities is 520 nanograms per joule (1.2 Ib per million Btu) heat input, which is
equivalent to about a 75 percent reduction in S02 emissions from plants burn-
ing 3 percent sulfur coal.  This emission limitation is effective for any
facility firing coal which is greater than the stated size and which began
construction after the date of proposal of the standard (August 17, 1971) or
for any existing facility which is significantly modified or reconstructed
after that date.

     On October 15, 1974, EPA proposed amendments to these regulations with
respect to modification, notification, and reconstruction.  These amendments
were adopted and became effective on the date they were published - December
16, 1975.

     It is the purpose of this study to identify and asess possible and
typical changes to steam generators that are affected by the amendments to
NSPS dealing with modifications and reconstruction.  A further objective is
to assess constraints which might hinder the application of flue gas desul-
furization to modified facilities.             '

     Few physical or operational changes have been identified which would
qualify as modifications or reconstruction of an existing boiler.  This is
true primarily because S02 emissions are a function of the sulfur content of
the fuel and are not affected by furnace and boiler design and operating
parameters.

     Certain obvious constraints attributable to cost, land and water avail-
ability, and the configuration of equipment at an existing facility tend to
hinder the installation of flue gas desulfurization systems to control S02
emissions from coal-fired boilers.  Many of these constraints are site related
and must be considered on an individual basis.

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                                 SECTION 2

                  MODIFICATIONS OF COAL-FIRED POWER PLANTS
MODIFICATION AS COVERED BY NSPS

     In certain situations, modifications of already existing industrial opera-
tions can cause these facilities to be regulated by New Source Performance
Standards.  Situations in which this can occur are delineated in Paragraph 60.14
of Part 60 of Chapter I, Title 40 of the Code of Federal Regulations (CFR).
Specifically the amended regulations state:

     §60.14 Modification

     •    60.14(a)—Except as provided under paragraphs (d), (e), and (f)
          of this section, any physical or operational change to an
          existing facility which results in an increase in the emission
          rate to the atmosphere of any pollutant to which a standard
          applies shall be considered a modification within the mean-
          ing of Section 111 of the Act.  Upon modification, an existing
          facility shall become an affected facility for each pollutant
          to which a standard applies and for which there is an increase
          in the emission rate to the atmosphere.

     As indicated above, there are certain exceptions to the rule for describing
source modifications with respect to New Source Performance Standards.  These
are summarized below:

     •    60.14(d)—(Simply stated, this exception indicates that physical
          or operational changes are allowed for one facility within a source,
          with a corresponding increase in emissions from that facility,
          provided that the overall emissions from the source do not in-
          crease.  If the owner can demonstrate that the overall emissions
          have not increased, then a "Modification" is deemed not to have
          occurred.  The burden of proof is on the operator.)

     •    60.14(e)—The following shall not, by themselves be considered
          modifications:

          —    Routine maintenance, repair, and replacement

          —    An increase in production without an increase in
               capital expenditure

          —    An increase in the hours of operation

                                      2

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          —    Use of an alternative fuel or raw material for which the
               facility was designed to use

          —    The addition of air pollution control equipment

          —    Relocation or change in ownership

     Relative to an increase in production, a capital expenditure is defined as
an expenditure for a physical or operational change which exceeds the product
of the applicable "annual asset guideline repair allowance percentage" (AAGRAP)
(as specified in the Internal Revenue Service Publication 534) and the existing
facility's "basis," as defined by Section 1023 of the Internal Revenue Code.
For the purposes of 60.14(e)(2), the total amount of expenditures necessary to
increase the facility's operating rate must not be reduced by any excluded
additions as given in Publication 534.  The tabulation of annual asset guideline
repair allowance (AAGRAP) percentages at the end of Publication 534 shows values
for three categories that could be applicable to coal-fired boilers.  The first
lists an AAGRAP of 5 percent for an electric utility steam production plant
producing electricity for sale.  The second shows an AAGRAP of 2.5 percent for
central steam production and distribution for sale.  The third category is for
steam and electric generation systems for use by the taxpayer in his industrial
manufacturing process or plant activity and a value of 2.5 percent is given.
Further information concerning the economics of boiler operations is provided
in Appendix A.

     •    60.14(f)~ Special provisions set forth under an applicable
          support of this part shall supercede any conflicting provision
          of this section.

"MODIFICATIONS":  THEIR EFFECT ON COAL-FIRED POWER PLANTS AND S02 EMISSIONS

     Changes which could be deemed modifications break down into two cate-
gories— physical and operational.  The physical boundaries of the facility are
currently defined as the coal reduction equipment on the front end of the
boiler, through the boiler and its accessories; e.g., air preheaters, economizers,
ash hoppers, etc., up to the stack.  (If control equipment is installed the
system  terminates before the control devices.)  The essential feature in the
case of either physical or operational changes is that the activity must result
in an increase in emissions.  In power plants, S02 emissions are related only
to the  amount of sulfur contained in the fuel.  In general, 90 percent or more
of the  sulfur in the fuel is emitted as S02 although high alkali fuels; i.e.,
lignites and many low rank coals, do retain more sulfur in the ash.

     There are very few situations which would cause an existing facility to
become  affected through the "modification" provision.  The obvious example of
fuel switching (oil or gas to coal) which would lead generally to substantial
increases in sulfur emissions is not likely to occur because of the high cost
of the many physical changes required to connect the facility, the increased
land requirements, other problems associated with the storage and handling
of coal and ash and the considerable downrating of the facility, typically
40 to 50 percent1 which occurs.  As an example, connection of a 300,000 Ib/hr

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oil/gas unit for spreader stoker operations would require the facility ope-
rator to:^

     •    Modify the furnace to accommodate a spreader and dual fire
          air system

     •    Provide space for the dropped furnace rotor, an ash hopper
          and ash removal system

     •    Add superheater surfaces

     •    Add additional sootblower and associated piping, etc.

     •    Add hoppers for fly ash collection and reinjection

     •    Modify the air heater and install an economizer

     •    Install a dust collector ahead of the regenerative a.c. heater

     •    Install new foundations, support timer etc. as required

     •    Modify combustion and safety controls

     •    Add an induced-draft fan for balanced draft operation

     •    Modify furnace backstays and add duct work stiffeners for
          balanced draft operations

     The above modifications will take about 18 to 24 months and will result
in a downrating of the unit to between 150,000 to 175,000 Ib/hr.  The connec-
tion to pulverized coal firing would require even more extensive modifications
and would take about 24 to 30 months.

     Numerous literature references indicate that conversion of oil or gas units
to coal is basically impractical.1~4  in addition to literature sources, contacts
with utility operators and individuals associated with combustion oriented
organizations (see Appendix B), confirmed that conversions, except for the case
of units designed primarily to burn coal, would be costly and impractical.  These
individuals were also unable to identify practical physical or operational
changes that would cause a facility to become affected by the "modification"
provision.  Changes such as the conversion of a stoker unit to a slag-tap or
cyclone furnace would increase emissions by approximately 5 to 10 percent but
are unlikely to occur because of the unfavorable economics associated with such
conversions.

     A boiler designed originally for gas firing may be almost impossible to
convert economically to coal firing.3  Furthermore, it should be noted that a
conversion to coal carried out because of energy considerations is exempt from
NSPS.  A more practical conversion would be the conversion from a wood burning
facility to coal.  Although some modification of equipment (e.g., fuel feed
and replacement of burners) would usually be required, the change could be
accomplished relatively inexpensively.  Based on EPA S02 emission factors, the

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conversion would increase S02 emissions and would be covered by the "modifica-
tion" provision.  However, very few conversions of this type seem likely to
occur since wood burning units were planned to take advantage of a cheap,
available fuel which might otherwise be considered waste.

     One development,  the combustion of coal suspended in oil in conventional
oil-fired boilers, may be of interest as a "modification."  If this development
proves successful, the boiler could be considered coal-fired.  If used in this
fashion, such a boiler would result in an increase in S02 emissions.

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                                  SECTION 3

                   RECONSTRUCTION OF COAL-FIRED POWER PLANTS
RECONSTRUCTION AS COVERED BY NSPS

     As stated in §60.15, Title 40 of Code of Federal Regulations (CFR), "Re-
construction" means the replacement of components of an existing facility to
such an extent that the fixed capital costs of the new components exceeds
50 percent of the fixed capital costs required to construct a comparable en-
tirely new facility.  For the "reconstruction" criteria to apply, it is also
necessary that it is technically and economically feasible to meet the NSPS
standards for the pollutant in question.

RECONSTRUCTION/COAL-FIRED POWER PLANTS

     Conceivably, a switch from natural gas (or oil), to coal may classify as
a "reconstruction" since such an action may well exceed 50 percent of the
cost of a comparible facility.  If the cost did not exceed 50 percent the
changes would constitute a "modification" (provided the conversion to coal was
not required for energy considerations), because of increased SOo emissions.

     Approximately 50 to 80 boilers^ will be required by the Federal Energy
Administration to convert back to coal.  While switches from oil or gas to
coal which are federally mandated have been defined as not subject to NSPS
a certain number of voluntary conversions may occur.  State legislation, such
as the Texas Railroad Commissions' Ruling No. 600, may also force facilities to
convert to coal.  This ruling was passed in December 1975 and amended in March
of 1976; it specifies that gas utilities must limit new natural gas sales to
3 million cubic feet per day to any company wishing to use that premium fuel
in boilers.  For those companies already operating above the 3 million limit,
gas deliveries are to be cut by January 1, 1981 to 90 percent of the highest
consumption attained in 1974 or 1975.  Given this impetus, Texas firms are
beginning the switch away from natural gas.6

     Voluntary conversion will be few in number because of the high cost of
boiler modification as discussed previously.  For the most part changes will
occur because of fear of shortages in natural gas and oil supplies.

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                                  SECTION 4

                   CONSTRAINTS PREVENTING APPLICATION OF FGD
     An objective of this program is to identify and assess the constraints
which might prevent the application of FGD to a modified facility.  Generally,
difficulties regarding the installation of FGD are technically solvable al-
though the cost impact will be increased.  Section 3 of the Clean Air Act spec-
ifies that cost must be considered in promulgating new source performance stan-
dards as quoted below:

          "A standard for emission of air pollutants which reflects the
          degree of emission limitation achievable through the application
          of the best system of emission reduction which (taking into
          account the cost of achieving such reduction) the. Administrator
          determines has been adequately demonstrated."

     Therefore, potential constraints are identified and discussed in relation-
ship to their potential cost impacts.

     The capital investment required for a FGD system applied to an existing
plant will typically be 10 to 20 percent higher than at a new plant.7'8  How-
ever, in specific instances difficulties can be much more severe than the
typical case, potentially increasing capital investments 60 percent.?  An ad-
ditional and important factor is that existing plants will tend to have shorter
life expectancies.  A new plant can be expected to last 30 years while an
existing plant may only last 10 years and operate at lower loads during that
period.  Annual FGD costs in terms of mills/kWh for the existing plant in the
above example operating at the same  load as  the new plant, should be  two  to
three times as high as the new plant.8

LAND RESTRICTIONS

     Land availability can be a major constraint.   Space in the immediate
vicinity of the flue gas ducting is required for the scrubber modules, fans,
pumps and associated ducting.  For a typical 500 MW plant about 17,000 to
34,000 ft2 will be needed.8  While the amount of land required for the scrubbers
is not large, the location is critical— it must be in close proximity to the
boilers where space is often limited.  Additional land (4 to 8 acres) is re-
quired for raw material (i.e., lime/limestone), receiving, storage and pre-
paration, access roads, and a process control building.

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     Land for each of the three requirements (scrubber modules, raw material
storage and handling, and sludge disposal) can be constraints on the installa-
tion of FDG systems.  The actual land area required for the scrubber modules
is not large and will seldom create problems that are not solvable.  Longer
duct runs, staking and elevating equipment, and other engineering modifications
can usually be successfully employed to meet space limitations.  Raw material
storage and handling requires more land but more options for location are avail-
able.  In addition) the amount of limestone required is much less than the
amount of coal and the storage area is also relatively smaller.  For example,
at a plant using a 3.5 percent sulfur coal, the quantity of limestone required
would be 5 to 10 percent of the coal quantity.   A coal-fired power plant should
be able to locate space for limestone storage.

     The disposal of sludge generated by a nonregenerative scrubbing system is
responsible for significant land requirement.  A new 500 MW plant burning 3.5
percent sulfur coal would require 130 acres for disposal of sludge over a 30-
year period.   The same plant would also require 75 acres for disposal of
fly ash.8  At some existing sites the availability of land may be a serious
constraint.

     An additional problem is that some land will not be suitable because of
environmental considerations.  Offsite disposal may be an option as evidenced
by the practice at the Bruce Mansfield station, where sludge is pumped 7 miles
for disposal.   A situation could, however, arise at an existing plant where
the cost of sludge disposal would be prohibitive.  If onsite land is unavail-
able, expansion may be impossible (within reasonable economic limits) because
the surrounding land is already developed and pipe lines through developed
areas may also be prohibitively expensive.  The use of a regenerative system
could eliminate or minimize any sludge disposal problem.  However, for systems
producing sulfuric acid, markets must be available or storage problems will
be serious.  On the other hand, sulfur can be easily stored in outdoor piles
if markets are not available.

CONSTRAINTS CAUSED BY EQUIPMENT CONFIGURATIONS

     During the design and construction of a new plant FGD equipment will be
included as an integral part of the plant.  Flue gas at a specified temperature
and maximum dust loading will be specified and  included in the design.  Space
for FGD will be provided and the location of particulate removal equipment,
FGD system, fans and the stack will be provided so that extensive ducting and
other problems are avoided.

     At an existing plant, equipment locations  and configurations can present
problems.   For instance, it is not uncommon at  existing plants to have the
stack located on the roof of the building.  Many steam electric plants in
operation prior to 1971 have roof-mounted stacks in order to take advantage
of building elevations of 100 to 200 feet.  Some examples are facilities at

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Sunbury, Pennsylvania and some older units at Mystic and Salem, Massachusetts.
Even the modern Canal Plant at Sandwich, Massachusetts has a roof mounted
stack.  This may require long runs of ducting to ground level and back to the
stack or construction of a new stack.  Another typical problem is the location
of the particulate control device (usually an electrostatic precipitator) in
relationship to the stack and other equipment.  If the electrostatic precipi-
tator is very close to the stack, it may be difficult to install new ducting
between the ESP and the stack without disturbing the flow patterns and decreas-
ing efficiency.

     Figure 1 is a drawing of a boiler that exemplifies some of the equipment
configuration problems.   The application of FGD to the boiler in Figure 1 is
technically feasible but the cost will be higher than application to a new
plant.   Devitt, et al.10 have estimated that typical capital cost increases
for long duct runs will  range from A to 7 percent, tight space will range from
1 to 18 percent and a new stack from 6 to 20 percent.

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         STACK IwiflM *48O'
   211
202' 9|
                                                     APPROXIMATE  SCALE:
                                                         I in =35 ft
 Figure 1.  Diagram of a boiler  exhibiting some  retrofit problems.
                                   10

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                                  REFERENCES
 1.   Schweiger, R.   Industrial Boilers,  What's  Happening  Today.   Power.
     p.516, February 1977.

 2.   Should you Convert to  Coal.   Power,  p. 38.   July 1976.

 3.   Bell, A.W. and B.P. Breen.  Converting Gas Boilers to Oil and Coal.
     Chemical Engineering.   April 26, 1976.  p. 93.

 4.   Bogot, A. and  R.  C. Sarreiz.  Principal Aspects of Converting Steam
     Generators Back to Coal Firing.   Combustion.   March 1976.

 5.   Coal/Oil Burned in Oil Burner.  Coal Age.   p. 24.  October 1976.

 6.   Conversion to  Coal Firing Picks  up  Steam.   Chemical Enginnering.
     February 14, 1977.  p. 40.

 7.   Ponder, T. C., L. V. Yerino, V.  Katari, Y. Shah, and T. W. Devitt.   Sim-
     plified Procedures for Estimating Flue Gas Desulfurization System Costs.
     PEDCo-Environmental Specialists, Inc.  EPA-600/2-76-150, U.S. Environmental
     Protection Agency, June 1976.

 8.   McGlamery, G.  G., R. L. Torstrick,  W. J. Broadfoot,  J. P. Simpson,
     L.  J. Henson,  S.  V. Tomlinson, and  J. F. Young.  Detailed Cost Estimates
     for Advanced Effluent  Desulfurization Process.   Tennessee Valley Authority.
     EPA-600/2-75-006, U.S. Environmental Protection Agency, January 1975.

 9.   Summary Report—Flue Gas Desulfurization Systems—November-December 1976.
     PEDCo-Environmental Specialists, Inc.  Prepared for U.S. Environmental
     Protection Agency, Contract  No.  68-02-1321,  Task Order No. 28.  January
     1977.

10.   Devitt, T. W., L. V. Yerino, T.  C.  Ponder, and C. J. Chatlynne.  Estimating
     Costs of Flue  Gas Desulfurization Systems for Utility Boilers.  J Air
     Pollut Control Assoc.   Volume 26, Number 3,  March 1976.
                                      11

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                                 APPENDIX A

            ECONOMICS OF NEW CONSTRUCTION, REPAIR AND MAINTENANCE
     This section is for the purpose of establishing the costs involved for
construction of new power plants and for routine repair and maintenance.  New
construction costs will serve as a guide in assessing the fixed capital cost
required for new facilities.  This is applicable in determining whether or
not an existing facility has been reconstructed to the extent that it will
become an affected facility under NSPS.

     The types of repair and maintenance to be enumerated and their relative
costs can be used in determining what types of repair and maintenance acti-
vities are routinely performed at an electric plant so that they can be dis-
tinguished from "modifications" as defined in the NSPS.

NEW CONSTRUCTION

     The cost of construction of new coal-fired power plants is projected to
increase dramatically in the next several decades.  In 1967, the cost of
constructing a new coal-fired plant was approximately $115 per kilowatt (kW).
The cost of putting a 1000 megawatt (MW) coal plant on line in mid 1975 was
about $200 million or $200 per kW.  The projection for 1980 is $450 per kW
and for 1990 is $950 per kW.1'2  An example of the breakdown of the costs in-
volved for the various system components is given in Table A-l for a 1000 MW
coal-fired facility going on line in July 1969.  The total direct cost in-
curred would be approximately 117 million dollars.  In addition to this cost,
there would be another 10 million dollars for indirect costs, 8 million for
contingency, 39 million for escalation, and 21 million in interest to make a
total of 195 million dollars.  The same total costs for a comparable nuclear
facility would be about 239 million dollars for the same start-up date.

REPAIR AND MAINTENANCE

     Repair and maintenance of coal-fired boilers can result in significant
costs to power plant operators.  While there is a difference between the two
terms, they are most often considered together in available cost information.
The National Boiler Inspection Code does, however, distinguish between repair
and maintenance and as an example defines repairs as the following items:

     1.   Replacement of sections of boiler tubes, provided the remaining
         part of the tube is not less than 75 percent of its original
         thickness.

     2.   Seal welding of tubes.

                                      12

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       TABLE A-l.  DIRECT CAPITAL COSTS FOR
                   CONSTRUCTION OF A 1000 MW
                   COAL-FIRED PLANT - JULY,
                   1969 START-UP1


        Direct costs only           Cost - 106 dollars


Boiler                                      24

Boiler erection                              8

Boiler structural steel                      3

Draft system                                 3

Ash handling system                          5

Coal handling including chimneys             7
  and high-efficiency ESP

Turbine-generating unit                     20

Turbine-generator erection                   2

Heater cycle and condensing system          18

Accessory and auxiliary electrical          10
  equipment

Miscellaneous power plant equipment          5

Instrumentation                              1

Other structures                             7

Site improvement                             4


  Total                                    117
                         13

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      3.  Building-up of certain corroded surfaces.

      4.  Repairs of cracked ligaments of drums or headers within certain
         definite  limits.

      In order  to obtain information on the maintenance costs incurred by vari-
 ous  power plants,  a survey was made of 20 different coal-fired units greater
 than 73 MW  (250 x  106  Btu).  This  information is presented in Tables A-2 and
 A-3  and was  obtained from the 25th annual supplement of "Steam-Electric Plant
 Construction Cost  and  Annual Production Expenses" put out by the Federal Power
 Commission  in  April 1974.3  The data are for the year 1972.

      Table  A-2 gives data for coal boilers firing only coal and shows that on
 the  average, boiler maintenance is about 65 percent of total plant mainte-
 nance.  Whereas the percentage of  total maintenance attributed to the boiler
 is nearly the  same in  all cases, the cost per megawatt is highly variable.
 A low figure of $800 per MW was obtained at a Missouri plant while a high
 value of $2,834 per MW was obtained for a plant in Florida.  As can be seen
 from the data  in the first two columns, the cost of fuel is greater that 75
 percent of  the total production expenses in almost every case.

      The data  presented in Table A-3 is for coal boilers firing some combina-
 tion of coal plus oil  and/or gas.  Again, the average percent of plant main-
 tenance associated with the boiler is 65 percent.  Also, the cost of boiler
 maintenance  per megawatt varies along the same lines as those boilers firing
 only  coal except that one higher value was obtained.  The range was from
 $950  per MW  to $3,828 per MW.   In  terms of absolute dollars spent on boiler
 maintenance, the data show values  ranging from $160,000 to $4 million for
 all  the boilers surveyed.

      The types of maintenance that will usually require substantial amounts
 of time are  boiler cleaning,  repair or replacement of various parts, generator
 stator or rotor repair, and recoating or welding of eroded or damaged hydro-
 turbine runner blades.

      Some national figures  are available relative to dollars spent on repair
 and maintenance in the different regions of the country.   For example,  elec-
 tric  utilities in New England (investor-owned)  spent $61 million in 1974 for
 maintenance  and repair of generating equipment.   The figure for the entire
 contiguous United States was  $1.1  billion.6

     Some specific maintenance items are available for cyclone and pulverized
 coal-fired boilers.  For a  cyclone, the principal items requiring maintenance
 are the coal crusher and the  cyclone furnace boiler.  The crusher will usually
 require replacement of hammers and grid bars at  yearly or less frequent in-
 tervals,  depending on the coal used.  The burner should be checked carefully.

     Pulverizers will usually require only minor repairs  which can be accom-
 plished at the annual outage  or overhaul.   Burner parts subject to abrasion
may require replacement at  more frequent intervals.   Regardless of the main-
 tenance work performed  annually,  the unit should have a complete overhaul
every 5 years.

                                      14

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     As has been mentioned previously in this report, 862 emissions vary
directly with the amount and percent sulfur of the fuel burned.   For this
reason, maintenance of coal-fired boilers - whether routine or not - should
have little or no effect on total S02 emissions.
                                      15

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                   TABLE A-2.   MAINTENANCE  COSTS  FOR  BOILERS FIRING ONLY  COAL DURING 19723
                                                              1972  production expenses
   Power plant
location and  size
                                           Cost, S x 10
                                           Cost of
                                            boiler
                                         maintenance
                                                                                                             Percent
                          A]             A2                B              C
                    Total product     Total product    Total cost       Total cost                   „,.     ._,.  _ ,,.    ,,,.,  „/„ v , nn
                                                      ,    ,           ,   .  .,       per megawatt  B/Ai  x  100  B/Ao x 100  C/B x 100
                       expenses         expenses       for plant        for boiler          g
                   (including fuel)   (excluding fuel)  maintenance maintenance only
1.  Alabama Power Co.     36.2
    Barry Plant
    Bucks,  AL
    1770.8 MW

2.  Alabama Power Co.     23.6
    Gorgas Plant
    Gorgas, AL
    1545.7 MW

3.  Colorado-Ute           3.1
    Elec.  Assoc. Inc.
    Hayden Plant
    Hayden, CO
    163.2 MW

4.  Tampa Elec. Co.       10.0
    Big Bend Plant
    Tampa,  FL
    445.5 MW

5.  Tampa Elec. Co.       28.4
    F.J.Gannon Plant
    Tampa,  FL
    1270.4 MW
6.1
4.3
0.8
1.7
7.2
               3.7
               2.1
               0.38
               0.9
               5.3
                              2.7
                              1.4
                              0.16
0.6
                              3.6
               1,525
                                               906
                 980
1,347
               2,834
                                                           10.2        60.6       73.0
                                                           8.9        48.8       66.7
                                                          12.2        47.5       42.1
                                                           9.0        52.9       66.7
                                                           18.7        73.6       67.9

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           TABLE A-2  (continued).   MAINTENANCE  COSTS  FOR  BOILERS  FIRING  ONLY COAL  DURING  19723
                                                              1972 production expenses

                                           Cost, $ * 10~e
   Power plant	•	
Cost,  $  *  10  °                                   ,                Percent
                                          Cost or
location and  size        A.               A2                B              C           boiler
                   Total product      Total product    Total cost      Total cost                  .,,,    , nn  „/,,     ,nn  _,,,   ,,.,,
                                                      ,    .          ,     .,       per megawatt  B/Ai x 100  B/A2  x  100  C/B * 100
                      expenses          expenses       for plant       for boiler          K
                   (including fuel)    (excluding fuel)  maintenance  maintenance only
6.  Central Illinois      11.6             2.0             0.96          0.71            910          8.3        48.0       74.0
    Light Co.
    E.D.Edwards  Plant
    Bartonville,  IL
    779.8 MW

7.  Central Illinois       5.34            1.55            0.68          0.5            2,784         12.7        43.9       73.5
    Public Service Co.
    Grand Tower  Plant
    Grand Tower,  IL
    179.6 MW

8.  Empire District        3.9             0.6             0.25          0.17            800          6.4        41.7       68.0
    Elec. Co.
    Asbury Plant
    Asbury, MO
    212.8 MW

9.  Minnesota Power        3.7             0.9             0.52          0.32           2,756         14.1        57.8       61.5
    and Light
    Aurora Plant
    Aurora, MN
    116.1 MW

10.  Basin Electric         3.76            1.05            0.54          0.33           1,375         14.4        51.4       61.1
    Power Cooperative
    Leland Olds,  ND
    240 MW

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                TABLE  A-3.   MAINTENANCE  COSTS FOR  BOILERS  FIRING  COAL PLUS OIL AND/OR GAS  DURING  19723
                                                                      1972 production expenses
            Power plant
         location and size
                                                    Cost, $ x 10
                                                                                                                     Percent
                   	    Cost of
                          A              A                B              C            boiler     	

                    Total product     Total'product    Total cost      Total cost     ^'"megawatt  B/A,  x  100  B/A, x 100  C/B  x  100
                       expenses          expenses       for plant      for boiler          s
                   (including fuel)  (excluding fuel)  maintenance  maintenance only
00
1.  Duke Power Co.        59.3
    Marshall Plant
    Terrell, NC
    2000 MW

2.  Potomac Electric      22.9
    Power Co.
    Chalk Point Plant
    Chalk Point. MD
    728  MW
                                                   4.0
                                                   4.6
                                                                  2.6
                                                                  3.4
                                                                                 1.9
                                                                                 1.95
                                                                                                 950
              2,679
                                                                                                             4.4        65.0       73.1
                            14.8        73.9       57.4
         3.  Appalachian           17.1
            Power Co.
            Clinch River
            Plant, Carbo, VA
            713 MW

         4.  Detroit Edison        58.8
            St. Clair Plant
            E. China Twp.,Ml
            1905 MW

         5.  Indiana &             22.4
            Michigan Elec. Co.
            Tanners Creek
            Plant
            Lawrenceburg, IN
            1100 MW
                                          2.3
                                          7.4
                                          6.0
                                                         1.2
                                                         4.9
                                                         4.1
                                                                        0.7
4.1
2.8
                982
2,152
2,545
                                                                                                     7.0        52.2       58.3
                                                                                                     8.3        66.2       83.7
                                                                                                    18.3        68.3       68.3

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  TABLE A-3  (continued).   MAINTENANCE COSTS FOR BOILERS FIRING COAL PLUS  OIL AND/OR GAS DURING 19723
                                                             1972 production expenses
   Power plant
location and size
                                           Cost, $ * 10 6
                                                            Cost of
                                                             boiler
                                                          maintenance
                                                                                   Percent
                          AI             A2                B               C
                    Total product     Total product    Total cost      Total cost     —^.--^..—.^^
                                           v           ,   ,         ,   ,  .,       per megawatt  B/Ai  *  100  B/A? x 100  C/B  *  100
                       expenses        expenses        for  plant      for boiler          s
                    (including fuel)   (excluding fuel)   maintenance  maintenance  only
6.  Public Service Co.    17.9
    of Colorado
    Cherokee  Plant
    Denver, CO
    801.3 MW
                 2.7
                                 1.4
                                               0.77
                                                               961
                                                                            7.8
                                                                                      51.9       55.0
7.  Northern  States
    Power Co.
    Black Dog Plant
    Minneapolis, MN
    486.7 MW
14.2
                 3.8
                                2.5
                                               0.86
              1,767
                                                                           17.6
                                                                                      65.8       34.4
8.  Montana Power Co.      2.05
    J.E.Corette Plant
    Billings, MT
    172.8 MW
                 0.48
                                0.27
0.2
1,157
                                                                           13.2
                                                                                      56.3       74.1
9.  Oaaha  Public
    Power  District
    North  Omaha Plant
    Onaha, NE
    600 MW
15.2
                 2.5
                                 1.4
0.9
1,500
                             9.2
56,0       64.3
10.  Nevada Power Co.       7.8
    Reid  Gardner Plant
    Moapa, NV
    227.3 MW
                 1.75
                                 1.1
                                               0.87
              3,828
                                                                           14.1
                                                                                      62.9       79.1

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                                 REFERENCES
1.   Power Engineering.  August, 1974.

2.   Vierath, D. R. and W. W. Walkley.  Costs of Meeting Clean Air Requirements.
     Power Engineering.  September, 1976.

3.   Steam-Electric Plant Construction Cost and Annual Production Expenses -
     1972.  Federal Power Commission.  April, 1974.

4.   Rowsome, Frank H.  The Role of System Reliability Prediction in Power
     Plant Design.  Power Engineering.  February 1977.

5.   Federal Power Commission News Release No. 22083.  January 22, 1976.

6.   Maintenance-Repair Costs to Top $3 Billion.  Electrical World 183(6).
     March 15, 1975.
                                      20

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                                  APPENDIX B

                        LIST OF INDIVIDUALS CONTACTED


W. H. Axtman, Executive Director, American Boiler Manufacturers Association,
     Arlington, Virginia

S. Baruch, Edison Electric Institute, New York, New York

L. Davis, Station Superintendent, Public Service Company of New Hampshire,
     Concord, New Hampshire

E. M. Diehl, Bituminous Coal Research Inc., Monroeville, Pennsylvania

F. Gottlieb, Boston Edison Company, Boston, Massachusetts

W. McKinney, Supervisor of Environmental Research, TVA, Chattanooga, Tennessee

J. Taylor, Arizona Public Service Company, Phoenix, Arizona
                                       21

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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO. 2.
EPA-450/3-77-048
4. TITLE AND SUBTITLE
IMPACT OF MODIFICATION/RECONSTRUCTION OF
STEAM GENERATORS ON S02 EMISSIONS
7. AUTHOR(S)
Mark I. Bornstein; Paul F. Fennelly; Robert R. Hall
Douglas Roeck.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
GCA Corporation; GCA/Technology Division
Burlington Road
Bedford, Massachusetts 01730
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
3. RECIPIENT'S ACCESSION-NO.
5. REPORT DATE
December 1977
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT
L' GCA-TR-77-21-G
NO.
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-02-2607,
Work Assignment No. 3
13. TYPE OF REPORT AND PERIOD COVERED
Final Report
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
17. KEY WORDS AND DOCUMENT ANALYSIS
a. DESCRIPTORS b.lDENTIFI

18. DISTRIBUTION STATEMENT 19. SECURT
Di Qt-f 1* Huh i nn Tin 1 i mi <-o<4 	 UIliiMfl
UNCLA
ERS/OPEN ENDED TERMS C. COSATI Field/Group

fY CLASS (THIS Report) 21 . NO. OF PAGES
SSIFIED 29
FY CLASS (This page) 22. PRICE
SSIFIED


EPA Form 2220-1 (9-73)
                                                             23

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