&EPA
           United States
           Environmental Protection
           Agency
           Office of Air Quality
           Planning and Standards
           Research Triangle Park NC 27711
EPA-450/5-79-003
January 1979
           Air
Cost Analysis of
Lime-based  Flue Gas
Desulfurization Systems
for New 500-MW Utility
Boilers

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                                   EPA-450/5-79-003
    Cost Analysis of Lime-based
Flue Gas Desulfurization Systems
 for New 500-MW Utility Boilers
                      Prepared by:

                  PEDCo Environmental, Inc.
                     Chester Towers
                    11499 Chester Road
                   Cincinnati, Ohio 45246
                   Contract No. 68-02-2842
                    Assignment No. 25
                EPA Task Manager: J. Garrard Wright
                      Prepared for

              U.S. ENVIRONMENTAL PROTECTION AGENCY
                Strategies and Air Standards Division
                   Economic Analysis Branch
              Research Triangle Park, North Carolina 27711

                     January 1979

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                                  DISCLAIMER

This report  was  furnished  to the U.S.  Environmental  Protection Agency (EPA)  by
PEDCo Environmental, Inc., Cincinnati, in fulfillment of Assignment No. 25 of Contract No.
68-02-2842.  The  contents of this  report are reproduced herein  as received from the
contractor. The opinions, findings, and conclusions expressed are those of the author and not
necessarily those of the EPA.

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                            CONTENTS
Figures
Tables
Acknowledgment

1.   Introduction                                           1-1

2.   System Variables                                       2-1
     2.1  FGD System Configuration                          2-1
     2.2  Plant Variables                                   2-3
     2.3  Analysis Approach                                 2-4

3.   Cost Components                                        3-1
     3.1  Capital Costs                                     3-1
     3.2  Annualized Costs                                  3-4
     3.3  Computer Model for Costs                          3-5

4.   Results and Applications                         t      4-1
     4.1  Results                                           4-1
     4.2  Applications                                      4-22
                              111

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                            FIGURES


No.                                                         Page

2-1  Lime FGD system                                        2-2

2-2  Plant combinations for FGD cost analysis               2-6

4-1  Capital investment excluding cost of  sludge pond and   4-4
     land for a lime FGD system at a bituminous-coal-fired
     500-MW plant

4-2  Capital cost of sludge pond and land  for a lime FGD    4-5
     system at a bituminous-coal-fired 500-MW plant

4-3  Operation and maintenance cost  excluding electricity   '4-6
     and reheat for a lime FGD system at a bituminous-coal-
     fired 500-MW plant

4-4  Fixed charges for a lime FGD system at a bituminous-   4-7
     coal-fired 500-MW plant

4-5  Capacity penalty for a lime FGD system at a bitu-      4-8
     minous-coal-fired 500-MW plant

4-6  Energy penalty for a lime FGD system  at a bituminous-  4-9
     coal-fired 500-MW plant

4-7  Capital investment excluding cost of  sludge pond and   4-10
     land for a lime FGD system at a subbituminous-coal-
     fired 500-MW plant

4-8  Capital cost of sludge pond and land  for a lime FGD    4-11
     system at a subbituminous-coal-fired  500-MW plant

4-9  Operation and maintenance cost excluding electricity   4-12
     and reheat for a lime FGD system at a subb i turn i nous-
     coal-fired 500-MW plant

4-10 Fixed charges for a lime FGD system at a subbitu-      4-13
     minous-coal-fired 500-MW plant

4-11 Capacity penalty for a lime FGD system at a subbitu-   4-14
     minous-coal-fired 500-MW plant
                              IV

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                        FIGURES (CONTINUED)

No.                                                         Page

4-12 Energy penalty for a lime FGD system at a subbitu-     4-15
     minous-coal-fired 500-MW plant

4-13 Capital investment excluding cost of sludge pond and   4-16
     land for a lime FGD system at a lignite-fired 500-MW
     plant

4-14 Capital cost of sludge pond and land for a lime FGD    4-17
     system at a lignite-fired 500-MW plant

4-15 Operation and maintenance cost excluding electricity   4-18
     and reheat for a lime FGD system at a lignite-fired
     500-MW plant

4-16 Fixed charges for a lime FGD system at a lignite-fired 4-19
     500-MW plant

4-17 Capacity penalty for a lime FGD system at a lignite-   4-20
     fired 500-MW plant

4-18 Energy penalty for a lime FGD system at a lignite-     4-21
     fired 500-MW plant
                               v

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                             TABLES
No.                                                         Paqe
2-1  Assumed Coal Characteristics                            2-4

2-2  Selected Number of Scrubber Modules and Spare Capacity 2-8

2-3  Cost Bases and Rates                                   2-9

4-1  Cost-Effectiveness of a Lime  FGD System for a 500-MW   4-24
     Plant Firing Bituminous Coal  With 0.0 RSD in Long-
     Term Sulfur Content

4-2  Cost-Effectiveness of a Lime  FGD System for a 500-MW   4-?5
     Plant Firing Bituminous Coal  With 1.3 RSD in Long-
     Term Sulfur Content

4-3  Cost-Effectiveness of a Lime  FGD System for a 500-MW   4-26
     Plant Firing Bituminous Coal  With 3.0 RSD in Long-
     Term Sulfur Content

4-4  Cost-Effectiveness of a Lime  FGD System for a 500-MW   4-27
     Plant Firing Subbituminous Coal With 0.0 RSD in Long-
     Term Sulfur Content

4-5  Cost-Effectiveness of a Lime  FGD System for a 500-MW   4-2F
     Plant Firing Subbituminous Coal With 1.3 RSD in Long-
     Term Sulfur Content

4-6  Cost-Effectiveness of a Lime  FGD System for a 500-MW   4-29
     Plant Firing Subbituminous Coal With 3.0 RSD in Long-
     Term Sulfur Content

4-7  Cost-Effectiveness of a Lime  FGD System for a 500-MW   4-30
     Plant Firing Lignite With 0.0 RSD in Long-Term Sulfur
     Content

4-8  Cost-Effectiveness of a Lime  FGD System for a 500-MW   4-31
     Plant Firing Lignite With 1.3 RSD in Long-Term Sulfur
     Content

4-9  Cost-Effectiveness of a Lime  FGD System for a 500-MW   4-32
     Plant Firing Lignite With 3.0 RSD in Long-Term Sulfur
     Content

                              vi

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                          ACKNOWLEDGMENT






     This report was furnished to the U.S. EPA by PEDCo Environ-



mental, Inc., Cincinnati.  PEDCo Project Director was Mr. Donald



J. Henz, and Mr. Yatendra M. Shah was the PEDCo Task Manager.



Mr. J. Garrard Wright was the EPA Task Manager.  PEDCo appre-



ciates the contributions made to this study by Mr. Wright and Mr.



Richard E. Jenkins, also of the EPA.
                               VII

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                             SECTION 1



                           INTRODUCTION






     This report studies the effect of sulfur dioxide (SO_)



removal levels on the cost of lime-based flue gas desulfurization



(FGD) systems for total and partial scrubbing.  The analysis is



performed for a 500-MW utility boiler firing three major types of



coal.  The results are presented as graphs for six cost compon-



ents.



     The three types of coal considered are bituminous, subbitu-



minous, and lignite.  Because these coals differ from each other



in firing characteristics, boilers using different fuels have



different FGD costs for the same SO- removal levels.



     The results of this analysis are to be used in studying the



effects of limitation levels and averaging times on SO- control



costs.  The U.S. Environmental Protection Agency (EPA)  has con-



tracted with PEDCo Environmental, Inc., to perform this analysis



in support of a program to review New Source Performance Stan-



dards for SO- emissions from coal-fired utility boilers.



     Section 2 discusses the system variables for each kind of



coal, and Section 3 describes the cost components studied.  The



results and applications of the analysis are presented in Section




4, which includes costs for model plants defined by the EPA.
                               1-1

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                            SECTION 2

                        SYSTEM VARIABLES

     This report is intended for use with various combinations

of input parameters.  To present a broad spectrum of cases, the

report follows these guidelines:

     1.   Cost components are evaluated for three types of coal
          that are representative of the coals mined in the
          United States.

     2.   To study the effect of partial scrubbing, the analysis
          includes FGD cost curves for flue gas flows from 20
          through 100 percent of the total boiler exhaust.

     3.   The analysis is applicable to SC>2 removal levels up to
          3867 ng/J (9.0 lb/106 Btu).

     The ranges of variables and FGD system assumptions are

discussed in this section.


2.1  FGD SYSTEM CONFIGURATION

     The process diagram for a typical lime FGD system is shown

in Figure 2-1.  The system does not include equipment for par-

ticulate removal.  It is assumed that the particulate concentra-

tion of flue gas entering the absorber complies with the ap-

plicable particulate emission regulations.

     The FGD system has three major process areas:  (1) slurry

preparation,  (2) SO2 scrubbing, and  (3) sludge disposal.  The

items of equipment included for each process area are as follows
                              2-1

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        nut GAS
        FROM BOILER
 I
fo
                                                                                               CLEAN GAS
                                                                                             TO ATMOSPHERE
                                                                                                                                  .COVERED
                                                                                                                                       CONVEYOR
0                                                                                              FIXATION
                                                                                              CHEMICAL
                                                                                              STORAGE
                                                                                 FIXATION
                                                                                  TANK
                                                                                          SLUDGE TO DISPOSAL POND
                                            Figure  2-1.    Lime  FGD  system.

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     (1)  Slurry preparation:
               Conveyors
               Slakers
               Storage silos
               Storage tanks
               Pumps and motors

     (2)  SO2 scrubbing:
               Absorbers
               Fans and motors
               Heat exchangers (reheaters)
               Duct work and dampers
               Slurry hold tanks
               Recycle pumps

     (3)  Sludge disposal:
              . Clarifiers
               Chemical storage equipment
               Mobile equipment
               Hold tanks
               Sludge pumps

     The stack at the plant is not considered a part of the FGD

system.  The sludge generated by the FGD is disposed of in an

onsite sludge pond.  Sludge is assumed to be pumped 1.6 km (1

mile).   Costs are for new applications only; retrofit applica-

tions are out of the scope of this report.


2.2  PLANT VARIABLES

     FGD costs are estimated for single boiler plants, elch with

a total electrical capacity of 500 MW.  Use of an FGD system,

however, causes plant generating capacity to be derated by the

amount of electricity needed to operate the system.

     Costs are presented for plants firing three types of coal:

bituminous, subbituminous, and lignite.  These coals have differ-

ent firing characteristics; those affecting the design of FGD

systems are listed in Table 2-1.  Heating value and heat rate

determine the'quantity of coal fired per hour, and the SC>2 in

                              2-3

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boiler outlet gases is proportional to this  quantity.  Thus, FGD

costs vary for coals with different heat rates and heating values


             TABLE 2-1.   ASSUMED COAL CHARACTERISTICS
  Coal type
Heating value
kJ/kg (Btu/lb)
Flue gas rate,a
  m^/s  (acfm)
   Heat rate,
kj/kwh (Btu/kWh)
Bituminous

Subbituminous

Lignite
27,920 (12,000)

24,330 (10,500)

18,380  (7,900)
713 (1,510,000)

727 (1,540,000)

763 (1,616,000)
  9500  (9000)

  9560  (9050)

  9720  (9200)
  For 500-MW plant.


     The size of handling equipment depends on total gas flow

through an FGD system.  The amount of air required for complete

combustion varies for different coals and produces different

exhaust gas flow rates.


2.3  ANALYSIS APPROACH

     To cover a broad range of cases, the report considers four

levels qf SO2 removal:  859 ng/J (2.0 lb/106 Btu) , 1718 ng/J  (4.0

lb/106 Btu), 2578 ng/J (6.0 lb/106 Btu), and 3437 ng/J  (8.0

lb/10  Btu) .  Values of each cost component are calculated for

these levels and are plotted as points on graphs.  Curves are

drawn through the points, and costs for intermediate S0~ re-

moval levels can be interpolated from the curves.

     Separate curves are drawn for nine gas flow rates, ranging

from 20 to  100 percent of the exhaust gases at increments of  10

percent.
                              2-4

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     Figure 2-2 shows the plant variables and total number of



plant combinations necessary for the analysis.



2.3.1  Module Selection



     Items of gas handling equipment in an FGD system are gener-



ally referred to as scrubbing modules.   Limitations on the



physical size of absorbers and ancillary devices force manu-



facturers of FGD equipment to limit maximum module size.   The



number of modules selected depends on the reliability require-



ments and volume of gas to be treated.   The cost of an FGD system



varies according to the number of modules it contains.  The



availability of an FGD system is a direct function of number of



scrubbing modules.  The more scrubbing modules there are, the



greater the availability of the system.  A system with four



scrubbing modules, for example, loses 25 percent of capacity if



one module is down; but a system with only two scrubbing modules



loses 50 percent capacity if one module is down.  Availability is



thus enhanced by a maximum number of functioning modules, as well



as by some spare scrubbing capacity.



     Module selection for this analysis is based on reducing



system cost while providing for redundancy.  The largest scrubber



size assumed is 218 m /s  (462,000 acfm) of flue gas at 155°C



(310°F).  This size is equivalent to 150 MW of electrical capac-



ity for subbituminous coal.  Based on this size limitation, the



total costs for different numbers of modules are compared for
                              2-5

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                             4 SO, REMOVAL LEVELS

                            859 ng/J  (2 lb/106 Btu)
                           1718 ng/J  (4 lb/106 Btu)
                           2578 ng/J  (6 lb/106 Btu)
                           3437 ng/J  (8 lb/106 Btu)
                             9 GAS FLOW RATES

                           (percent of exhaust gas)

                    20, 30, 40, 50, 60, 70, 80, 90, and 100
                             TOTAL COMBINATIONS

    (Number of coal types) x (Number of SOg removal levels) x (Number of gas flow rates)

                               3 x 4 x 9 = 108
Figure  2-2.    Plant  combinations for  FGD cost analysis.
                                     2-6

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each scrubbing case.  Table 2-2 shows the number of modules



selected for the cases analyzed.  Each case includes one spare



scrubbing module.



     The cost bases and rate data used for the analysis are



presented in Table 2-3.
                              2-7

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                          TABLE 2-2.
SELECTED NUMBER OF  SCRUBBER MODULES
     AND SPARE CAPACITY
Gas flow
through FGD
system, % of
total exhaust
100
90
80
70
60
50
40
30
20
Bituminous coal
Total
number of
scrubber
modules
5
4
4
4
3
3
3
3
3
Spare
modules
1
1
1
1
1
1
1
1
J-
1
Spare
scrubbing
capacity,
%
25
33
33
33
50
50
50
50
50
Subbituminous coal
Total
number of
scrubber
modules
5
4
4
4
3
3
3
3
3
Spare
modules
1
1
1
1
1
1
1
1
1
Spare
scrubbing
capacity,
%
25
33
33
33
50
50 '
50
50
50
Lignite
Total
number of
scrubber
modules
5
5
4
4
4
3
3
3
3
Spare
modules
1
1
1
1
1
1
1
1
1
Spare
scrubbing
capacity,
%
25
25
33
33
33
50
50
50
50
N)
I
00

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                TABLE 2-3.  COST BASES AND RATES
Escalation factor for capital cost'

Electricity rate, mills/kWh

Reheat/steam rate,  $/GJ  ($/106Btu)

Labor rate, $/man-hour
Capital recovery factor for annualizing
 capital investment, % of capital cost

Insurance, taxes, and general administrative
 expenses, % of capital cost
              2
Land rate, $/m   ($/acre)

Lime rate, $/Mg  ($/ton)

Fixation chemicals, $/Mg ($/ton)
    1.156

    25.00

 1.18 (1.25)

    10.00


    11.70


     4.30

 0.49 (2000)

38.60 (35.00)

22.00 (20.00)
  The base year for computer model costs is 1976; the
  escalation factor is used to update the costs to 1978.
                               2-9

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                            SECTION 3




                         COST COMPONENTS






     The cost of an FGD system is estimated as capital cost and



annualized cost.  The capital cost represents the initial invest-



ment necessary to install and commission the. system.  The annual-



ized cost represents the cost of operating and maintaining the



system and the charges needed to recover the capital investment,



which are referred to as fixed costs or fixed charges.






3.1  CAPITAL COSTS



     Capital costs consist of direct and indirect costs incurred



up to the successful commissioning date of the facility.  Direct



costs include the costs of various items of equipment and the



labor and material required for installing these items and inter-



connecting the system.  Indirect costs are expenditures for the



overall facility that cannot be attributed to specific equipment;



they include such items as freight and spares.



3.1.1  Direct Costs



     The "bought-out" cost of the equipment and the cost of in-



stalling it are considered direct costs.  A bought-out cost of an



equipment item is the purchase price paid to the equipment




supplier on a free-on-board (f.o.b.) basis; this does not include




the freight charges.  Installation costs cover the interconnection





                              3-1

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of the system, which involves  piping,  electrical,  and the other

work needed to commission it.   Also attributed to  installation

are the costs of foundations,  supporting structures,  enclosures,

ducting, control panels, instrumentation,  insulation, painting,

and similar items.  Costs for  interconnecting various items of

FGD equipment include site development,  construction of access

roads and walkways, and the establishment of rail, barge, or

truck facilities.  Finally, the cost of  administrative facilities

is considered a direct cost.

     Various procedures are available for estimating direct costs.

The PEDCo computer model uses  the installation factor technique

to estimate total direct costs.  The bought-out cost of each item

of equipment is multiplied by  an individual installation factor

to obtain the installed cost.   This installed cost includes a

proportional cost for interconnecting the equipment into the

system.  The installation factors are based on the complexity of

the equipment and the cost of  the material and labor required.

The installed costs of all the equipment are added together to

obtain the total direct cost of the facility.

3.1.2  Indirect Costs

     The indirect costs of an  FGD system include the following:

     Interest:  covers interest accrued  on borrowed capital
     during construction.

     Engineering costs:  include administrative, process, proj-
     ect, and general costs;  design and  related functions for
     specifications; bid analysis; special studies; cost anal-
     ysis; accounting; reports; purchasing; procurement; travel
     expenses; living expenses; expediting; inspection;  safety;
                              3-2

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     communications;  modeling;  pilot plant studies;  royalty
     payments during  construction;  training of plant personnel;
     field engineering;  safety  engineering; and consultant serv-
     ices .

     Field overhead;   includes  the  cost of securing  permits and
     right-of-way sections, and the cost of insurance for the
     equipment and personnel on site.

     Freight:  includes  delivery costs on FGD process and related
     equipment shipped f.o.b. point of origin.

     Offsite expenditures;   include expenditures for powerhouse
     modifications, interruption to power generation, and service
     facilities added to the existing plant facilities.

     Taxes:   include  sales, franchise, property, and excise
     taxes.

     Spare parts:  represent costs  of items stocked  to permit 100
     percent process  availability;  such items include pumps,
     valves, controls, special  piping and fittings,  instruments,
     spray nozzles, and  similar equipment.

     Shakedown;  includes costs associated with system startup.

     Contractor's fee and expenses;  include costs for field
     labor payroll, supervision field office, administrative
     personnel, construction offices,  temporary roadways, rail-
     road trackage, maintenance and welding shops, parking lot,
     communications,  temporary  piping, electrical, sanitary
     facilities, rental  equipment,  unloading and storage of
     materials, travel expenses, permits, licenses,  taxes, in-
     surance, overhead,  legal liabilities, field testing of
     equipment, and labor relations.

     Con tingency cost s;   include costs resulting from malfunc-
     tions,  equipment design alterations, and similar unforeseen
     sources.

     Land cost;  includes only  the  cost of the land  required for
     sludge disposal.  The cost of  land for installing FGD equip-
     ment is accounted for in the installation factors.

     All indirect cost components,  except land cost, are obtained

by multiplying the direct costs by  an indirect cost  factor.  The

land cost is based on land rate and the disposal area required.
                              3-3

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3.2  ANNUALIZED COSTS

     The annualized operating  costs  of  an FGD  system consist of

the following:

     Raw materials:  include costs of lime  for the FGD system and
     fixation chemicals.

     Utilities:  include  costs of water for slurries, cooling,
     and cleaning;  electricity for pumps, fans,  valves,  lighting
     controls,  conveyors,  and  mixers; fuel  for reheating flue
     gases;  and steam for processing.

     Operating labor:  includes costs of supervision and skilled
     and unskilled  labor  to operate, monitor,  and control the FGD
     process.

     Maintenance and repairs;   include  costs of manpower and
     materials to keep the unit operating efficiently.  The
     function of maintenance is both preventive and corrective,
     to keep outages to a minimum.

     Overhead:   represents business  expenses that are not charged
     directly to a  particular  part of a process, but are allo-
     cated to it.  Overhead costs  include administrative, safety,
     engineering, legal,  and medical services; payroll;  employee
     benefits;  recreation; and public relations.

     The capital investment in an  FGD system is generally trans-

lated into annual fixed charges.  These charges, along with the

annual operating cost, represent the total  revenue requirement or

annualized cost of  a system.   The  annual fixed charges are cal-

culated under four  cost components:  depreciation, taxes, insur-

ance, and capital costs.   The  values for these components are

obtained as follows:

     Depreciation;   calculated by  using a  sinking-fund method
     over the life  period of  the FGD system.

     Taxes;  calculated by multiplying  the  total capital cost by
     the input tax  rate.   The  tax  rate  varies  for different
     plants.
                              3-4

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     Insurance;  calculated by multiplying the total capital cost
     by the insurance rate.

     Capital charges;  calculated by multiplying the total
     capital cost by the input interest rate.  Capital charges
     represent the interest paid per year for the use of capital,
     and they vary according to interest rates.

     The total annual fixed charges are obtained by adding the

values of the above four components.  The annualized cost or

total annual revenue required is the sum of the annual operating

costs and the total annual fixed charges.  Table 2-3, presented

at the end of Section 2, shows the cost bases and rates used in

this analysis.


3.3  COMPUTER MODEL FOR COSTS

     The costs for lime FGD systems were calculated using the

computer model developed by PEDCo.  This model is structured to

provide capital and annualized costs for different FGD variables.

The input for the model consists of the rate data, coal data, gas

flow rates, rates of allowable S02, and other related data.  The

base year for the model is 1976; a provision exists for adjusting

the capital costs by an escalation factor to the year of FGD

startup.
                              3-5

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                            SECTION 4



                    RESULTS AND APPLICATIONS






4.1  RESULTS



4.1.1  Cost Components



     The coal fired in a utility boiler varies in sulfur content.



An FGD system designed for a long-term average sulfur content in



the coal would allow excessive emissions of S02 during short-term



peaks of sulfur content.  To meet S0_ control regulations con-



sistently, an FGD system must be designed for these peaks and



thus be larger than would be required for a long averaging time.



     To analyze the effect of averaging time, this report sub-



divides the FGD costs generated by the computer model into six



components.  Of the six cost components, three are dependent on



averaging time:  (1) capital cost of system equipment, (2) fixed



charges of total capital investment, and (3) capacity penalty.



The components independent of averaging time are:  (1) capital



investment for sludge pond and land and (2) energy penalty.  The



operation and maintenance costs are made up of components de-



pendent on averaging time and components independent of averaging



time.  Costs of raw materials used by the FGD system are in-



dependefit of the averaging time, whereas maintenance costs, which
                              4-1

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are a function of capital investment,  are dependent on it.   TUB



importance of these components  in cost analysis is explained



below.



4.1.1.1  Capital Cost of System Equipment--



     The FGD system must be large enough to  accommodate sulfur



content peaks in the coal.   Such a system operates at a slightly



reduced load when sulfur content is lower than the peaks, and



brings a higher capital investment than a system designed for



long-term average sulfur content.



4.1.1.2  Fixed Charges—



     The high capital investment for systems designed for short



averaging times also brings high annual capital charges, because



these charges are proportional  to the capital investment.



4.1.1.3  Capacity Penalty—



     The capacity penalty represents an instantaneous derating in



boiler capacity by the amount required to operate the FGD system.



The derating depends upon the maximum power  to be reserved for



the system during sulfur peaks.  This study  treats the capacity



penalty as a percentage of total generating  capacity.



4.1.1.4  Capital Investment for Sludge Pond  and Land—



     The total sludge generated by the FGD system depends on the



long-term sulfur content of coal and is independent of short-term



sulfur peaks.  The capital investment for sludge pond and land



therefore always varies according to the long-term sulfur con-




tent of the coal.
                              4-2

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4.1.1.5  Operation and Maintenance Costs—

     The cost components for operation and maintenance include

costs of lime, fixation chemicals, and labor.  Reheat and elec-

tricity are not included.  The operating costs are independent of

the averaging time, and maintenance costs are dependent on it.

4.1.1.6  Energy Penalty—

     The energy penalty is represented as the percentage of

total generating capacity.  The energy used by the FGD system

does not depend on averaging time.

4.1.2  Graphs for Cost Components

     Graphs are presented for six cost components of lime FGD

systems at plants firing each of the three types of coal.

Figures 4-1 through 4-6 are for bituminous-coal-fired units;

Figures 4-7 through 4-12, for subbituminous-coal-fired ones;  and

Figures 4-13 through 4-18, for lignite-fired ones.  The six cost

components are:

     (1)  Capital investment excluding sludge pond and land.

     (2)  Capital cost of sludge pond and land.

     (3)  Operation and maintenance costs excluding electricity
          and reheat.

     (4)  Fixed charges.

     (5)  Capacity penalty.

     (6)  Energy penalty.

The graphs for components 1 through 4 have x-axes showing the

amount of SO» removed.  The graphs for components 5 and 6 have
                              4-3

-------
                1.0
                      2.0    3.0
                                 4.0
                                       5.0    6.0    7.0    8.0    9.0
                                       GAS FLOW THROUGH FGD =100%
                                                                20
                                                                10
                                                              9.0
                              S02 REMOVED, lb/10D Btu
                             (1 lb/106 Btu = 429.6 ng/J)


 Figure 4-1.   Capital investment excluding cost of  sludge pc.nd
and  land for  a lime  FGD system at  a bituminous-coal-fired 500-MW plant
                                  4-4

-------
              1.0    2.0    3.0
                               4.0    5.0     6.0    7.0    8.0
                                                              10.0
                                                              9.0
                                      GAS FLOW THROUGH FGD zlQO%3
                                      • ; : . 1   't * T I • t • T i I - I . . i l^V ^
                            S02 REMOVED, lb/10  Btu


                           (1 lb/106 Btu = 429.6 ng/J)
Figure 4-2.   Capital  cost of sludge pond and  land  for a  lime
      FGD  system at a  bituminous-coal-fired  500-MW  plant.
                                   4-5

-------
                1.0
                                                            9.0
                                                             5.0
                                                             4.5
                                      5.0    6.0    7.0    8.
                                                             1.0
                                                             0.5
                                                            9.0
                           S02 REMOVED, lb/10  Btu

                         (1 lb/106 Btu = 429.6 ng/J)
Figure  4-3.  Operation and  maintenance cost  excluding electricity
            and  reheat for a lime FGD system  at a
              bituminous-coal-fired  500-MW plant.
                                 4-6

-------
                                                     9.0
                    S02 REMOVED, lb/10b Btu

                   (1 lb/106 Btu = 429.6 ng/J)
Figure 4-4.  Fixed charges for  a lime FGD system  at a
          bituminous-coal-fired  500-MW plant.
                            4-7

-------
    3.0
            10    20     30     40     50    60     70     80     90     100
    2.5
    2.0
    1.5
                                                                 3.0
                                                                 2.5
                                                                 2.0
                                                                 1.5
                            i
    1.0
                                                                  1.0
             a—F
    0.5
                                                                  0.5
           10     20     30     40     50     60

                             GAS FLOW THROUGH FGD,
70     80     90     100
Figure 4-5.   Capacity  penalty for  a lime FGD  system at a
             bituminous-coal-fired 500-MW plant.
                                4-8

-------
          10    20    30    40
                                   50
60     70
   5.0
   4.5
   4.0
   3.5
   3.0
  #2.5
  i2.0
            80     90     100
                         5.0
                                                                  4.5
                                                                  4.0
                                                                  3.5
                                                                  3.0
                                                                  2.5
                                                                  2.0
                                                                  1.5
                                                                  1.0
                                                                  0.5
      !! Ill' ! I
                                                          m
                 nun!
                                      f i±a
  1.5
  1.0
  0.5
                        LrfTi i
          10    20    30    40     50     60

                            GAS FLOW THROUGH FGD,%
      70
            80    90   100
Figure  4-6.   Energy  penalty  for  a lime FGD system  at a
            bituminous-coal-fired  500-MW plant.
                                 4-9

-------
             1.0    2.0
                        3.0
                                                         9.0
                                                           20
                                                           10
                                   5.0    6.0   7.0    8.0
                                                         9.0
                          S02 REMOVED, lb/10° Btu
                         (1 lb/106 Btu = 429.6 ng/J)

Figure 4-7.  Capital investment excluding  cost of  sludge
         pond and land for  a lime FGD system at a
          subbituminous-coal-fired 500-MW plant.
                              4-10

-------
         io. o
         9.0
         8.0
         7-°
                 1.0    2.0    3.0    4.0     5.0     6.0	7.0    8.0    9.0
       _" 5.0


                                          1 GAS HOW
                                                 IHRUUIiH mi) - 1 00%
                                                     _:
                                                           ::
                                                       '90%
                                                         i
                                                        =30% :
                                                        f

                                                                    10.0
                                                                    <) 0
                                                                    8.0
                                                                    7.0
                                                                    6.0
5.0
                                                                    4.0
                                                                    3.0
                                                                    2.0
                                                                    1.0
                 1.0    2.0    3.0    4.0     5.0    6.0    7.0    8.0    9.0
                              SO, REMOVED, lb/10 Btu
                            (1 lb/106 Btu = 429.6 ng/J)
Figure  4-8.   Capital cost  of sludge pond and land  for  a lime
   FGD  system at a  subbituminous-coal-fired  500-MW  plant.
                                   4-11

-------
            5.0
                  1.0
                                                               0.5
                                        5.0    6.0    7.0    8.0    9.0
                             S02 REMOVED, lb/10b Btu

                            0 lb/106 Btu = 429.6 ng/J)
Figure  4-9.
Operation and maintenance cost excluding electricity
 and  reheat for a  lime FGD  system at  a
subbituminous-coal-fired 500-MW plant.
                                  4-12

-------
      5.0
     4.5 •
             1.0   2.0    3.0    4.0    5.0    6.0    7.0    8.0    9.
                                                            0.5
                                                      0    9.0
                        S02 REMOVED, lb/106 Btu

                       (1 lb/106 Btu • 429.6 ng/0)
Figure 4-10.  Fixed charges  for a  lime FGD system at  a
          subbituminous-coal-fired 500-MW  plant.
                               4-13

-------
     3.0
            10    20    30     40    50    60     70     80     90    100
    2.5
    2.0
    1.5
                                                                 3.0
                                                                 2.5
                                                                 2.0
                                                                 1.5
    1.0
                                                                 1 .0
                                                                 0.?
    0.5
           10
                 20
                       30
  40

GAS FLOW
  50     60

THROUGH FGD,5£
                                              70
                                                    80
                                                          90     100
Figure 4-11.   Capacity penalty for  a lime  FGD  system at  a
           subbituminous-coal-fired 500-MW plant.
                                4-14

-------
          10     20
  5.0
  4.5
  4.0
  3.5
  3.0
  2.5
  2.0
  1.5
  1.0
  0.5
30     40     50     60     70     80     90    100
                                        ill. 15.0
                                                                 4.5
                                                                 4.0
                                                                 3.5
                                                                 3.0
                                                                 2.5
                                                                 2.0
                                                                 1.5
                                                                 1.0
                                                                 0.5
                                               m
                                       i
          10     20     30     40     50     60
                            GAS FLOW THROUGH FGD, %
                        70     80     90     100
Figure  4-12.   Energy penalty for a lime FGD system  at a
          subbituminous-coal-fired 500-MW plant.
                                4-15

-------
                 1.0    2.0
4.0    5.0    6.0    7.0    8.0    9.0
                                                                 130
           10
                                                                 30
                                                                 20
                                                                 10
                 1.0    2.0    3.0     4.0    5.0    6.0    7.0    8.0    9.0

                               S02 REMOVED, lb/106 Btu

                              (1 lb/106 Btu •= 429.6 ng/J)
Figure 4-13.   Capital investment excluding  cost of sludge pond
and  land for a lime FGD  system  at a  lignite-fired 500-MW plant.

                                   4-16

-------
     lO.O
     g.O
     8.0
     7.0
     6.0
   . 5.0
             1.0    2.0    3.0    4.0    5.0    6.0    7.0    8.0
     •> n


                                     GAS FLOW THROUGH hGU
                                                             SI 10.0
             1.0     2.0    3.0    4.0    5.0    6.0     7.0    8.0    9.0
                           S02 REMOVED, lb/10 Btu

                          (1 lb/106 Btu •= 429.6 ng/J)
Figure  4-14.   Capital cost of sludge  pond and land for
   a lime FGD system at  a lignite-fired 500-MW plant.
                                  4-17

-------
             1.0    2.0
                                                   8.0    9.0
                                                           5.0
                                                           4.5
                                                            .5
                                   5.0   6.0    7.0    8.0   9.0
                        S02 REMOVED, lb/10° Btu

                       (1 lb/106 Btu •= 429.6 ng/J)
    Figure 4-15.   Operation and  maintenance cost
excluding electricity and reheat for a  lime FGD  system
           at  a  lignite-fired 500-MW plant.
                             4-18

-------
      5.0
      0.5
                                                             1.0
                                                             0.5
                               4.0    5.0    6.0    7.0    8.0   9.0
                        S02 REMOVED, lb/10 Btu

                       (1 lb/106 Btu = 429.6 ng/J)
Figure 4-16.  Fixed charges  for a  lime  FGD system  at a
                lignite-fired  500-MW plant.
                              4-19

-------
        10     20
30    40    :50    60
                                           70     80
                                                       90     100
3.0
                                                              3.0
                                                  ffl-
2.5
                                                              2.5
2.0
                                                              2.0
                                    3
1.5
                                                              1.5
1.0
                                                              1.0
                                                   ; ; •
0.5
                                                              0.5
                                              tottr
                                                   ! ! I i i ! I i
        10     20     30    40    50     60

                         GAS FLOW THROUGH FGD,  *
                        70
                             80
                                   90    100
     Figure 4-17.   Capacity penalty  for a  lime  FGD
       system at a lignite-fired 500-MW plant.
                             4-20

-------
        10    20     30
                          40
       50   '  60     70     80     90     100
                                       5.C
5.0
4.5
4.0
3.5
3.0
2.5
2.0
1.5
1.0
0.5
                                                                4.5
                                                                3.5
                                                                3.0
                                                                2.5
                                                                2.0
                                                                1.5
                                                                1.0
                                                                0.5

        10     20     30
 40     50     60

GAS FLOW THROUGH FGD, !
70     80     90     100
 Figure 4-18.   Energy penalty for a  lime  FGD  system
            at a  lignite-fired 500-MW  plant.
                              4-21

-------
x-axes showing the percentage of gas flow through the FGD system.

because the capacity and energy penalties are insensitive to .SO9

removal levels.
4.2  APPLICATIONS

     Figures 4-1 through 4-18 were used to calculate the costs of

various model plant scenarios.  In evaluating the effects of

averaging time on the scenarios, it was assumed that an averaging

time could be treated as a relative standard deviation (RSD) of

the long-term sulfur content of coal and that each RSD amounted

to an average increase in sulfur content of 15 percent.  Model

plant costs are presented for three RSD values:  0.0, 1.3, and

3.0.  The values for SO_ removal factor, percentage of gas flow

through the FGD system, and amount of SO- removed are obtained

with the following equations:

                               U  - U*
     (1)  SO- removal factor =  —^	
                                   R

          TT      ,long-term sulfur    ~   ,,       T-,<-^\ n t
          U_   =[   Z  4.  .c    n    x2x(l + nx RSD)]
           R      content of coal

          U = Allowable S0~ emissions

     (2)  Percentage of gas flow through the FGD system
                SO- removal factor
                      0785
x 100
*
  In these equations, U and U  should have the same units  (either
  ng/J or lb/10^ Btu).

  n = number of RSD's (i.e., 0.0, 1.3, or 3.0); and RSD =  0.15
  (15 percent).


                              4-22

-------
     (3)   Amount of SO0 removed by FGD system = U  - U
                      ^             '             K




The model plant scenarios are presented in Tables 4-1 through



4-9.
                              4-23

-------
           TABLE 4-1.  COST-EFFECTIVENESS OF A LIME FGD
         SYSTEM FOR A 500-MW PLANT FIRING BITUMINOUS COAL
             WITH 0.0 RSD IN LONG-TERM SULFUR CONTENT9
                             Controlled SO,, emission level
                               344 ng/J
                            (0.8 lb/106 Btu)
                    50% control
Capital cost of FGD sys-
  tem, $/kW

Increment of capital cost
  above cost of base
  plant, %b

Annualized cost of FGD
  system, mills/kwh

Increment of annualized
  cost above the oper-
  ating cost of the base
  plant, %c

Annual SO2 emissions,
  Mg/yr  (tons/yr)

SO~ removal efficiency, %

Annualized cost of S02
  removal, $/Mg  ($/ton)
    110.75



     14.55


      6.44
    69.76



     9.17


     3.76
     25.75


9,300 (10,250)

     84.00


375.39 (340.55)
     15.05


29,060  (32,030)

     50.00


368.68  (334.47)
a Sulfur content of bituminous coal = 1074 ng/J  (2.5  lb/106  Btu)

  Base plant capital cost = $761/kW.

  Base plant annualized operating cost = 25.0 mills/kWh.
                               4-24

-------
    TABLE 4-2.  COST-EFFECTIVENESS OF A LIME FGD SYSTEM FOR A
            500-MW PLANT FIRING BITUMINOUS COAL WITH
              1.3 RSD IN LONG-TERM SULFUR CONTENT3
                                       Controlled S02 emission
                                            level of 50%
Capital cost of FGD system, $/kW

Increment of capital cost above
  cost of base plant, %^

Annualized cost of FGD system,
  mills/KWh

Increment of annual cost above
  the operating cost of the
  base plant, %c

Annual SO2 emissions, Mg/yr (tons/yr)

S0~ removal efficiency, %

Annualized cost of SO2 removal,
   $/Mg  ($/ton)
     70.10

      9.21


      3.77


     15.09



29,060 (32,030)

     50.00

369.61 (335.31)
a Sulfur content of bituminous coal = 1074 ng/J (2.5 lb/106 Btu)

  Base plant capital cost = $761/kW.

0 Base plant annualized operating cost = 25.0 mills/kWh.
                               4-25

-------
    TABLE 4-3.  COST-EFFECTIVENESS OF A LIME FGD SYSTEM FOR A
            500-MW PLANT FIRING BITUMINOUS COAL WITH
              3.0 RSD IN LONG-TERM SULFUR CONTENT*1
                                       Controlled SO2 emission
                                            level of 50%
Capital cost of FGD system,  $/kW

Increment of capital cost above
  cost of base plant, %k

Annualized cost of FGD system,
  mills/KWh

Increment of annual cost above
  the operating cost of the
  base plant, %c

Annual SO- emissions, Mg/yr  (tons/yr)

SO2 removal efficiency, %

Annualized cost of S00 removal,
  $/Mg ($/ton)       2
     70.56

      9.27


      3.79


     15.14



29,060 (32,030)

     50.00

370.88 (336.46)
  Sulfur content of bituminous coal = 1074 ng/J  (2.5 lb/10  Btu)

  Base plant capital cost = $761/kW.

  Base plant annualized operating cost = 25.0 mills/kwh.
                               4-26

-------
          TABLE 4-4.  COST-EFFECTIVENESS OF A LIME FGD SYSTEM FOR A 500-MW PLANT
            FIRING SUBBITUMINOUS COAL WITH 0.0 RSD IN LONG-TERM SULFUR CONTENT3
                                                Controlled S02 emission level
                                       215 ng/J
                                    (0.5 lb/106 Btu)
                      344 ng/J
                  (0.8 lb/106 Btu)
                     50%  control
Capital cost of FGD system, $/kW

Increment of capital cost above
  cost of base plant, %"

Annualized cost of FGD system,
  mills/kWh

Increment of annualized cost
  above the operating cost of
  the base plant, %c

Annual S02 emissions,
  Mg/yr (tons/yr)

S0~ removal efficiency, %

Annualized cost of S02 removal,
$/Mg ($/ton)
     88.34


     10.79

      4.68


     18.71



  5840 (6440)


     69.88

982.30 (891.14)
      69.79


       8.52

       3.61


      14.44



  9350 (10,310)


      51.81

1022.86 (927.94)
      68.29


       8.34

       3.49


      13.98



  9700  (10,690)


      50.00

1025.44 (930.29)
a Sulfur content of subbituminous coal = 356 ng/J  (0.83 lb/106 Btu).

  Base plant capital cost =  $819/kW.
^
  Base plant annualized operating cost = 25.0 mills/kWh.

-------
                TABLE 4-5.  COST-EFFECTIVENESS OF A LIME FGD SYSTEM FOR A 500-MW PLANT
                 FIRING SUBBITUMINOUS COAL WITH 1.3 RSD IN LONG-TERM SULFUR CONTENT3
                                                      Controlled S02 emission level
                                             215 ng/J
                                         (0.5 lb/106 Btu)
                                                          344 ng/J
                                                       (0.8 lb/106 Btu)
                                        50% control
I
NJ
00
Capital cost of FGD system, $/kW

Increment of capital cost above
  cost of base plant, %b

Annualized cost of FGD system,
  mills/kWh

Increment of annualized cost
  above the operating cost of
  the base plant, %c

Annual S02 emissions,
  Mg/yr (tons/yr)

SO2 removal efficiency, %

Annualized cost of S02 removal,
$/Mg ($/ton)
      94.95

      11.59


       4.88


      19.51



   5840 (6440)


      69.88

1024.45 (929.38)
      76.67

       9.36


       3.76


      15.06



   9350 (10,310)


      51.81

1066.29 (967.34)
      68.37

       8.35


       3.50


      13.98



  9700 (10,690)


      50.00

1026.11 (930.89)
      a Sulfur content of subbituminous coal = 356 ng/J (0.83 lb/10  Btu).
      r_
        Base plant capital cost = $819/kW.
      r-i
        Base plant annualized operating cost = 25.0 mills/kWh.

-------
       TABLE 4-6.  COST-EFFECTIVENESS OF A LIME FGD SYSTEM
          FOR A 500-MW PLANT FIRING SUBBITUMINOUS COAL
            WITH 3.0 RSD IN LONG-TERM SULFUR CONTENT3
                             Controlled SO« emission level
                               344 ng/J
                             (0.8 lb/106 Btu)
                      50% control
Capital cost of FGD sys-
  tem, $/kW

Increment of capital cost
  above cost of base
  plant, %b

Annualized cost of FGD
  system, mills/kwh

Increment of annualized
  cost above the oper-
  ating cost of the base
  plant, %c

Annual SO2 emissions,
  Mg/yr  (tons/yr)

S02 removal efficiency, %

Annualized cost of SO2
  removal, $/Mg  ($/ton)
       85.67



       10.46


        4.12
      68.47



       8.36


       3.50
       16.48


   9350 (10,310)

       51.81


1166.70 (1058.43)
      14.00


  9700 (10,690)

       50.00


1026.94 (931.64)
  Sulfur content of subbituminous coal = 356 ng/J  (0.83 lb/10- Btu)

  Base plant capital cost = $819/kW.

  Base plant annualized operation cost = 25.0 mills/kWh.
                               4-29

-------
 I
CO
o
                   TABLE  4-7.   COST-EFFECTIVENESS OF A  LIME  FGD  SYSTEM FOR A  500-MW
                     PLANT FIRING  LIGNITE WITH  0.0 RSD IN LONG-TERM SULFUR  CONTENT3

Capital cost of FGD system, S/kW
Increment of capital cost above
cost of base plant, %b
Annualized cost of FGD system,
raills/kWh
Increment of annualized cost
above the operating cost of
the base plant, %c
Annual SO2 emissions,
Mg/yr (tons/yr)
S02 removal efficiency, %
Annualized cost of SO2 removal,
$/Mg ($/ton)
Controlled SO. emission level
86 ng/J
(0.2 lb/106 Btu)
108.63
13.26
5.77
23.09
2380 (2620)
83.33
1383.23 (1254.87)
215 ng/J
(0.5 lb/106 Btu)
78.50
9.58
4.03
16.12
5940 (6550)
58.33
1379.43 (1251.42)
344 ng/J
(0.8 lb/106 Btu)
53.70
6.56
2.73
10.92
9500 (10,480)
33.33
1634.84 (1483.13)
50% control
69.72
8.51
3.57
14.29
7130 (7860)
50.00
1426.43 (1294.06)
              Sulfur content of lignite = 258 ng/J  (0.6 lb/106 Btu).
              Base plant capital cost = $819/kW.
              Base plant annualized operating cost  = 25.0 mills/kwh.

-------
                TABLE 4-8.   COST-EFFECTIVENESS OF A LIME FGD SYSTEM FOR A 500-MW PLANT
                        FIRING LIGNITE WITH 1.3 RSD IN LONG-TERM SULFUR CONTENT3
                                                      Controlled S02 emission level
                                             215 ng/J
                                         (0.5 lb/106 Btu)
                                                          344 ng/J
                                                       (0.8 lb/106 Btu)
                                         50% control
i
OJ
Capital cost of FGD system, $/kW

Increment of capital cost above
  cost of base plant, %b

Annualized cost of FGD system,
  mills/kWh

Increment of annualized cost
  above the operating cost of
  the base plant, %c

Annual S02 emissions,
  Mg/yr (tons/yr)

S02 removal efficiency, %

Annualized cost of S02 removal,
$/Mg ($/ton)
      85.60

      10.45


       4.29


      17.17



   5940 (6550)


      58.33

1469.55 (1333.18)
      68.89

       8.41


       3.36


      13.42



   9500 (10,480)


      33.33

2010.36 (1823.80)
      70.01

       8.55


       3.58


      14.32



   7130 (7860)


      50.00

1429.70 (1297.02)
      a Sulfur  content of lignite = 258 ng/J (0.6 lb/106 Btu).

      b Base  plant capital cost = $819/kW.
      £
        Base  plant annualized operating cost =  25.0 mills/kWh.

-------
       TABLE 4-9.  COST-EFFECTIVENESS OF A LIME FGD SYSTEM
              FOR A 500-MW PLANT FIRING LIGNITE WITH
                3.0 RSD IN LONG-TERM SULFUR CONTENT9
                             Controlled SO- emission level
                               344 ng/J
                            (0.8 lb/106 Btu)
                     50% control
Capital cost of FGD sys-
  tem, $/kW

Increment of capital cost
  above cost of base
  plant, %"

Annualized cost of FGD
  system, mills/kwh

Increment of annual!zed
  cost above the oper-
  ating cost of the base
  plant, %c

Annual SO2 emissions,
  Mg/yr  (toris/yr)

S02 removal efficiency, %

Annualized cost of SO2
  removal, $/Mg  ($/ton)
      73.09



       8.92


       3.53
    70.21



     8.57


     3.59
      14.14


  9500 (10,480)

      33.33


2117.00 (1920.55)
    14.34


 7130 (7860)

    50.00


1431.93 (1299.05)
  Sulfur content of lignite = 258 ng/J  (0.6 lb/10  Btu).

  Base plant capital cost = $819/kW.

  Base plant annualized operating cost = 25.0 mills/kWh.
                               4-32

-------
                                   TECHNICAL REPORT DATA
                            (Please read Instructions on the reverse before completing)
1. REPORT NO.
   EPA-450/5-79-003
                                                            3. RECIPIENT'S ACCESSION-NO.
4. TITLE AND SUBTITLE
   Cost Analysis of Lime-Based Flue  Gas  Desulfurization
   Systems for  New 500-MW Utility Boilers
             6. PERFORMING ORGANIZATION CODE
             5. REPORT DATE
                 Issued  1/79
7. AUTHOR(S)
   Yatendra M.  Shah
                                                            8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
   PEDCo Environmental,  Inc.
   11499 Chester  Road
   Cincinnati,  Ohio 4
                                                            10. PROGRAM ELEMENT NO.
             11. CONTRACT/GRANT NO.
                68-02-2842
12. SPONSORING AGENCY NAME AND ADDRESS
   U.S. Environmental Protection Agency
   Office of Air Quality Planning  and Standards
   Research Triangle Park, NC 27711
             13. TYPE OF REPORT AND PERIOD COVERED
                Final
             14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT

   Cost curves  for the calculation  of capital investment,  operating and maintenance
   cost, capacity, and energy penalties are presented. These curves apply  only to
   500-MW coal-fired utility boilers  controlled by  lime  based flue gas desulfurization
   systems.   Costs can be determined  for bituminous,  sub-bituminous, and  lignite coals
   with sulfur  contents ranging  up  to about 4.5%.   The cost of FGD treatment of 20 -
   100 percent  of the gas flow in  10  percent increments  and in a broad range of sulfur
   removal efficiencies can also be calculated.
17.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                              b.lDENTIFIERS/OPEN ENDED TERMS
                           c. COSATl Field/Group
   Air Pollution
   Cost Comparison
   Electric  Utilities
   Sulfur Oxides
 Air Pollution Control
 Stationary Sources
 Coal-Fired Boilers
 Emission Standards
13B
18. DISTRIBUTION STATEMENT

   Unlimited
19. SECURITY CLASS (ThisReport)
    Unclassified
                                                                          21. NO. OF PAGES
   55
20. SECURITY CLASS (Thispage)
    Unclassified
                           22. PRICE
EPA Form 2220-1 (9-73)

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