CONTROL BOARD
IIE SPECIFIC
RULE FOR CITY OF SPRINGFIELD,
OFFICE
OF PUBLIC
0 2.208( 8)
ROM 35 ILL. ADM. CODE
ecific Rulemaking --
100 West Randolph St
TRICT
60601
a
James R. Thompson Center
100 West Randolph, Suite 11-500
nois 60601
Ret
Ily submitted,
and
Date: November 21, 2008
By:
/s/ Chri
3150 Roland Avenue
Post Office Boy 5776
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
ION CONTROL BOARD
Light and Power ("CWLP") and Springfield Metro Sanitary
T -HEARING D OCU
N
OW COME the
Petitioners, City of Springfield, Illinois, Office of
rs"), by and through their attom
T".aI I u'-rI I,
I
C I ill;II
o
rt Documen
R09-8
c fit-enced
in the Technical
ioners, including:
al supply from
l. See especially,
pages
IV-1
as Attachrnen
through I
. The Report is attached hereto
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
Sargent and Lundy, LLC, City Water Light & Power
Dallman &
Lakeside
Station Water Conservation Study
"Water
Conservation
Study"), April 2005, referenced
the TSD at page 6-5, regarding the inves
of a completely dry bottom
ash handling
system at the
CWLP Dallman Power Station. See especially, pages
3-4
onstrate anticipated
to as Attachmen
d.
Burns & McDonnell Engineering Co., Letter to Douglas
ing Boron Removal Using
"), May
18, 2007,
referenced in the TSD at page 6-10, regarding the capital
osts for removal of boron i
ate, pages 4 thro
D.
s
that CWLP supp
cotis
i I' lictlti in C O 'LP's
w a
i c'v1 gift,: I- SI I t"Im.
t
'
I
1k)\11 kit I\,
11
rI
Iir 1111ci'..',ove
mmental Cor
,Iýýtý1P(
ill d tl-,: Vl;:%
t
<G
I of Table 6-2 on page 6-1
explained at hearing and in the
of the TSD. As
dy
ý'l''dý,c.ný
2 008 Hearing, Petitioners noticed that
footnote
trator system. See, TSD
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
page
6-10 and Transcript of the Nove
of Table 6-2 of the TSD,
Water,
50-52. A corrected version
BEFORE,
Petitioners,
City
of
Springfield,
Illinois,
Office of
Public
Utilities,
ation and information
November 3, 2008 Hearing,
Order.
ld Metro Sanitary District respectfully sub
November 6, 2008 Hearing Officer
and
By:
ýAt omeys
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
OF SERVICE
I, Christine G. Zei
the undersigned,
ITTAL, upon:
James
100 Nest Randolph Street
Suite 1300
Suite
11-500
Chicago, Illinois 60601
Chicago, Illinois 60601
aettinger@elpc.org
via electronic mai
t
2008; and upon:
1021 North Grand Avenue East
F. Ettinger, Esq.
of Board
c/o Environmental Law and Policv Cent
K°,rd;on, Chief
i-mc.'ilt of Nawtal Resources
III II -Iý-),
F c ,-,tzrces Way
Jaiirc.,ý L. Thompson Center
of the
°r
IU ý .`v"w?',:ýtRand(,lrl1, Suite 11-500
lay depositing said
documents in the United States
By: /s/ Christine G. Zeman
Christine G.
Zeman
+;f)rj(Mý
1
h
eld,
Hearing, Doe Submittal
Electronic Filing - Received, Clerk's Office, November 21, 2008
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ATTACHMENT A
Phase II S02 Compliance Study Report
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
PHASE II S02 COMPLIANCE
STUDY REPORT
For
City Water Light & Power
Springfield, Illinois
Dallman and Lakeside Stations
October,
1998
98-617-4
c
h
ýO
u
a
W
BUI"I75
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October 7, 1998
Mr. Jay Bartlett
City Water Light
& Power
3 100 Stevenson Drive
Springfield, IL 62757
Phase
11 S02 Compliance Study
Project
No. 98-617-4 (G)
Final Report
Dear
Mr. Bartlett:
Attached
are fifteen copies
of
the final report for the Phase II
S02 Compliance Study in
accordance with
our contract
for professional engineering
services (City of Springfield
purchase order
SCSCA99202021). This study investigated
and evaluated Phase
II 502
compliance options for the Dallman
and Lakeside Stations.
The report was revised
to include the comments received
from City Water Light &
Power
on the draft copy of information included
in the report. Submission of
this
report
and
completion
of the presentation of
study
results
scheduled for October 8, 1998
completes our work on this
project.
We appreciate this opportunity
to provide professional engineering
services to City
Water Light
&
Power
and would like to thank you
and
your
staff
for
your assistance in
providing information
used
in the performance
of the study and preparation of the report.
Brian
E. Basel, P.E.
Project
Manager
Attachments
M INERS " ARLNIRCIS " LONSULIANIS
9400 Word Pordway
N NnsasGly,
Aim,
64114-3319
Tel 816 333
9400
fnx:3163333690
hllp//ww,hummtdcon
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* * * * * PC #1 * * * * *
City
Water
Light & Power
Springfield, Illinois
Phase II S02
Compliance
Study
Project
No. 98-617-4
INDEX AND
CERTIFICATION PAGE
REPORTINDEX
NUMBER
PART NO
PART TITLE
OF PAGES
PART I
Summary and
Conclusions
3
PART
II
Introduction
3
PART III
Compliance Options
3
PART I V
Scope of Modifications
Required
17
PART
V
Compliance Option Screening
10
APPENDIX
A
Study
Basis
and
Assumptions
9
APPENDIX
B
K-T Analysis
4
APPENDIX C
Dallman Unit 33
S02 Removal
1
APPENDIX
D
Off site PRB
Coal Unloading and Storage Options
1
APPENDIX E
Cost Estimates
20
CERTIFICATI
p 0-9
.
.......
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,
*i REGISTERED
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P ROFESSIONAL.:*
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ENGINEER
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10/5,/1
CERT.DOC
RIC-1
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.TABLE OF CONTENTS
Title
Page
LIST OF, TABLES
PART I
SUMMARY AND
CONCLUSIONS
I-1
I1
I
J
I
INTRODUCTION
COMPLIANCE
OPTIONS
II-1
III-1
PART N
SCOPE OF MODIFICATIONS
REQUIRED
IV-1
PART V
COMPLIANCE OPTION
SCREENING
K-T decision
analysis,
V-1
Economic
§tialysis
V-5
APPENDIX A
STUDY
BASIS AND ASSUMPTIONS
APPENDIX B
K-T
ANALYSIS
APPENDIX
C
DALLMAN UNIT 33 S02
REMOVAL
IMPROVEMENTS
APPENDIXE
COST ESTIMATES
APPENDIX
D
OFFSITE PRB
COAL
UNLOADING AND
STORAGE
OPTIONS
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LIST OF TABLES
r-,
l
Table
TitLe
Page
III-1
Phase
II S02 Compliance options
III-4
N-1
Potential Unit Impacts
/
Modifications
IV-8
V-1
Original K-T Analysis Matrix
Appendix B
V-la
Final
K-T Analysis Matrix
Appendix B
V-2
Unit Modification Reference
Sheet
Appendix B
V-3
Adjustment of K-T Analysis Scores
Appendix B
V-4
Economic
Analysis Summary
V-8
Phase
II S02 Compliance Options
V-4a
Option 1
Economic Analysis
Appendix E
V-4b
Option 2 Economic Analysis
Appendix E
V-4c
Option 3 Economic Analysis
Appendix E
V-4d
Option 4 Economic Analysis
Appendix E
V-4e
Option 5 Economic
Analysis
Appendix E
V-4f
Option 6 Economic Analysis
Appendix
E
V-4g
Option 7 Economic Analysis
Appendix E
V-4h
Option 8 Economic Analysis
Appendix E
V-4i
Option 9 Economic Analysis
Appendix E
V-4j
Option 10 Economic Analysis
Appendix E
V-4k
Option 11 Economic Analysis
Appendix E
V-41
Option
13 Economic Analysis
Appendix E
V-4m
Option 14 Economic Analysis
Appendix E
I
Dallman
Unit
31
&
32 FGD
System Cost Estimates
Appendix E
i
J
Potential Unit Modification Cost Estimates
Appendix E
Coal Handling Cost Estimates
Appendix E
.
J
TABLESDOC
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LIST OF FIGURES
Figure
Title
page
IV-1
Coal Handling
System Diagram
IV-3
Dallman
Two Coal Pile
IV-2
Preliminary FGD
System Flow Diagram
IV-12
Dallman
Station Units 31 & 32
IV-3
FGD System Plot Plan
-
Dallman
Units 31 & 32
IV-13
1
IV-4
Estimated Electrostatic Precipitator Performance
IV-14
1
- PRE Coal
i
I
l
J
FIGURES.DOC
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PART I
SUMMARY
AND CONCLUSIONS
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PART I
SUMMARY AND CONCLUSIONS
Bums & McDonnell performed
a study of Phase 11 SOz compliance
options as requested by City Water
Light & Power (CWLP) for
the
Dallman
and Lakeside Stations.
SUMMARY
CWLP has performed several previous
studies of options for compliance with the requirements
of
Phase
II
of the
Clean Air Act as amended in 1990. Bums
& McDonnell was contracted to provide professional
engineering
services to update and
expand the previous compliance option studies. The following
tasks
were accomplished
during this study:
" Compliance
options developed by CWLP were reviewed
and additional options were prepared
and included in the study.
" Each of the compliance options was
defined and agreed to by CWLP and Burns & McDonnell.
" A technical and economic screening
was performed of each option.
" This report
was prepared to document the activities that were
accomplished during the study.
" Three
meetings were held with
CWLP
personnel
to discuss the basis for the study, to review
the compliance options
and cost factors to use in the cost estimates, and to perform the
technical K-T
decision analysis.
A presentation of the final results of the
study
was made
to CWLP.
C ONCLUSIONS
As stated above,
both
a technical and an economic analysis were performed of potential compliance
options. Several conclusions
were made from
the
results
of these analyses.
Technical Analysis
The technical analysis of the
options
identified modifications
that might be required to the existing plant
based
on the option conditions. The modifications involve boiler and coal handling modifications that
would be required for options involving a change in the coal from the Tunis coal presently being burned in
all of the Dallman and Lakeside units. Some of the options are based on the installation of FOD systems
on Dallman
Unit
31
and
32,
or taking the Dallman Unit 33 scrubber out of service. The modifications and
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FGD system impact
on several criteria were analyzed and scored
during a "K-T" analysis meeting attended
by both
CWLP and Bums & McDonnell personnel.
The highest ranked compliance
option is Option 1 based on the technical
analysis performed. The scope of
Option 1 includes
the addition of an FGD system to Dallman
Units
31
and
32.
Tunis coal would continue
to be burned in all Dallman
and Lakeside units for this option. The Dallmmm
Unit
33
scrubber would also
remain in service. Because
the coal supply does not change, no unit or coal handling modifications
would
be required for implementation
of this option.
Economic
Analysis
An economic analysis
similar to the analyses performed by CWLP for the previous studies was done for
each
of the options identified for this study. The capital
and operation and maintenance cost of each
modification that was
might be required for each option was estimated
and a total evaluated cost
calculated.
Key Assumptions: The
economic analysis was based on the following significant assumptions, many
of which parallel those made by
CWLP
in its
previous studies. These assumptions should be clearly
understood and considered in
interpretation of the reported economic analysis results:
" The
positive bias in S02 emissions due to the discrepancy between the CEMS-reported
and fuel-
based calculated emissions was included in
determination of allowances required.
" No banking of
SO,
allowances
was permitted. This includes the previous purchase of 27,000
allowances by
CWLP, which are not specifically accounted for in this analysis.
" The
significant reduction in the number of allowances available to the Lakeside units after the year
2009 was not
specifically accounted for. The results of the evaluation are therefore most relevant
for
the
first 10 years
of Phase II.
The analysis was based on assumed capacity factors that resulted in a total annual net generation
of 2,409,000 MWh. This is somewhat higher
than
historical generation levels.
The "best estimate" price
of
PRB
coal delivered to the plant site is equivalent to $1.45/mmBtu.
The "eval;uated costs" used in the analysis do not represent CWLP's full power production costs.
Even though some options evaluated would result in violation of the current Turris coal contract,
no cost or penalty which may result from such violation or dissolution of that contract are included.
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" Unit 33 FGD
0 & M costs are considered in
the evaluation of each option, including
the "base
case".
ReSUItS:
The lowest cost
option based on the evaluated life
cycle cost was Option 2, which is identical
to
Option 1
except that Monterey coal would
be burned in the Lakeside units. Options I
and 2 include the
addition
of an FGD system to Dallman
Units 31 and 32.
Although
Option 2 is the lowest evaluated
cost option, it has the highest capital
cost
requirement
of any
option evaluated.
This would require CWLP
to take on a substantial long-term debt burden. This may
make this option less
attractive to CWLP, depending
on the current financial condition and overall
cash
flow requirements of the
utility.
CWLPI.doc
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PART
II
INTRODUCTION
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PART II
INTRODUCTION
This report presents the results of the Phase II
S02 Compliance Study conducted
by Bums & McDonnell
for City Water
Light & Power (CWLP) of Springfield, Illinois.
BACKGROUND
Phase II refers to the second phase of sulfur dioxide
emission reductions under Title I V
of the Clean Air
Act as amended in 1990 (The Act). The specific
requirements for Phase II are provided in Section 405
of the Act. CWLP's Dallman
and Lakeside generating stations are affected
sources under Section 405,
and all coal-fired units at the two generating stations
are affected units. Section 405 requires
that,
beginning January l, 2000, these units are subject
to annual emission limitations for sulfur
dioxide
(SO2). Under the provisions of Section 403 of the Act, each
unit has been assigned an allowance
of a
certain number of tons of annual
S02 emissions based on the specific emission limitations
for that unit.
Beginning in calendar year 2000, the total actual S02
emissions (as determined by the continuous
emissions monitoring systems, or CEMS) from each of the affected
coal-fired units cannot exceed the
emission limitation unless the owner holds allowances to cover the
actual emissions. The U.S. EPA has
established an allowance trading system,
and holds annual auctions that help to set
the price of S02
allowances. Several brokerage firms also track and periodically
report the market value of allowances.
For any source subject to the Phase II S02 emission limitation requirements
of The Act, there are
basically three options for compliance:
1. Limit operation so as to insure that the total actual S02
emissions fall at or below the number of
allowances held.
2. Reduce S02 emission rates so that the total actual S02 emissions fall at or below
the number of
allowances held. This is typically done by some combination of switching
to coal with lower sulfur
content or retrofitting S02 emission control
equipment.
3. Procure additional allowances to cover the anticipated difference between actual emissions and the
base
number
of allowances granted by the U.S. EPA.
Various combinations of these compliance strategies are also possible.
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CWLP has previously studied the situation with regard to
Phase II S02 compliance for
the Lakeside and
Dallman
stations. The previous CWLP studies
investigated the cost of switching
to low-sulfur Illinois
coal, the cost of retrofitting
a flue gas desulfurization (FGD)
system to Dallman Units
31 and 32, and the
cost of relying completely
on S02 allowance purchases for Phase II
compliance.
Since the
latest CWLP study was completed in
early 1996, several factors have
changed, and CWLP
determined
that it should update the study,
including expansion of the compliance options
to include
consideration
of switching to Powder River Basin (PRB)
coal. For this reason, CWLP retained
Bums &
McDonnell to complete the Phase
II S02 compliance study that is the subject
of this report.
PURPOSE
The purpose of the Phase
II S02 compliance study was to evaluate
options for compliance with the
S02
emission limitations which
will become effective for the Lakeside and Dallman generating
stations in the
year 2000. The six options covered
by the previous CWLP study in 1996 were revisited,
and four
additional options
that had been identified by CWLP for evaluation
were studied. In addition, Bums
&
McDonnell was
to identify and evaluate up to four additional
options which, in its opinion, would be
feasible additions to the range
of compliance optiuons previously identified.
The purpose of the study
was
to perform technical and economic evaluation
of all options, for the purpose of determining
the
preferred option.
Burns & McDonnell was tasked with
assessing the specific modifications required
for implementation of
the individual options at each coal-fired
generating unit at the Lakeside and Dallman
generating stations.
In doing so, our purpose was to identify the new and
modified equipment which would be necessary
to
maintain safe and reliable
operation of the plants. Bums & McDonnell has considerable
experience with
both coal
switching and FGD retrofit projects for Clean Air Act compliance,
and our goal was to bring
this experience to bear in the
assessment and evaluation of the compliance options for
CWLP.
SCOPE
The scope of the study included the following tasks:
1. An initial meeting at Dallman station with
CWLP staff to discuss the 10 options identified by CWLP
for consideration in the
study, and to clarify the scope and assumptions to be used for the study
parameters.
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2.
Identification of the four additional
options to complement those identified
by CWLP.
3. A meeting
at CWLP to finalize the list of
options to be evaluated in the study.
4.
Assessment of the equipment modifications
and additions required for,
and the operational effects of,
the implementation of each
option at each unit.
5. Performance of a Kepner-Tregoe
(K-T) decision analysis
to screen and rank each option
with regard
to its
ability to meet the needs and wants of CWLP.
Bums & McDonnell facilitated
this participative
decision analysis process at a meeting
at C WLP's Dallman station. This
allowed input from
CWLP's staff with regard to
the technical and operational factors judged
to be most important
to the
decision-making process.
6.
Preparation of cost estimates for the implementation
of each option at each unit. Estimates
prepared
included identification of expected capital costs
as well as assessment of equipment performance
and
operating cost effects.
7. Development
of an economic evaluation matrix,
in spreadsheet format, for use in the
economic
analysis of the various options.
8. Performance
of "sidebar" evaluations of possible
variations in the definition of certain
options.
These limited-scope
studies included:
" Location of off-site storage for PRB coal.
" Requirement for S02 removal
efficiency improvement for the Dallman
Unit 33 FGD system.
Preparation of this
final report.
10. Presentation of the results
of the study at a meeting with C WLP.
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PART III
COMPLIANCE
OPTIONS
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PART III
COMPLIANCE OPTIONS
C WLP and
Bums
& McDonnell developed
the compliance options evaluated in this study. Ten
options
were presented by
CWLP as the basis for study. One of the initial tasks
of
this
study was to review these
ten
options and consider revisions or additions to the
base
list
of options. A maximum of four additional
options were to be added for
the study.
BASE COMPLIANCE
OPTIONS
The following ten compliance
options were identified by CWLP for this study. The
option
descriptions
define
the type of coal that would be burred in
each
unit,
changes in the operation of the Dalhnan Unit 33
scrubber and include the addition of scrubber to Dallnum Units 31 and 32.
1. Add
scrubber to Dallman Units 31 and 32, bum 100% Turris
coal in all units.
2. Add scrubber to Dallman Units 31
and
32,
bum Tunis coal in Dalhnan units and bum Exxon
Monterrey coal in Lakeside
units (6 and 7).
3. Bum Exxon Monterrey
coal
in
Lakeside units, bum Turris coal in Dallman units.
4. Burn
Exxon Monterrey coal in Dallman Units 31, 32 and Lakeside
units, bum Turris coal in
Dallman Unit 33.
5. Bum Exxon Monterrey
coal
in Dallman
Units 31 and 32, bum Turris coal in Dallman Unit 33 and
Lakeside
units.
6. Bum 100% Turris coal in all Dallman and Lakeside
units.
7. Bum 100% Powder River Basin (PRB) coal in
Dallnum units, bum Exxon Monterrey coal in
Lakeside units,
shutdown Dallnum Unit 33 scrubber.
S. Bum PRB coal in Dallman Units 31 and 32, bum Turris coal in Dalhnan Unit 33,
and bum
Exxon
Monterrey coal in Lakeside units.
9. Bum 100% PRB
coal in Dallnum units, bum Tunis coal in Lakeside units, and shutdown
Dallnum
Unit
33
scrubber.
10. Bum PRB coal in Dallman Units 31 and 32, bum Turris coal in Dallman Unit 33 and in Lakeside
units.
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ADDITIONAL OPTIONS
F
ollowing review of these ten options, Bums & McDonnell identified four additional options, which were
submitted to CWLP on September 2, 1998. The
additional options were
initially
defined as
follows:
11. Bum Exxon Monterey coal in Units 31 and 32, and in the Lakeside units, and add scrubbers to
Unit 31 and 32.
12. No new
scrubber, bum a blend of PRB and
Exxon
Monterey coals
in
Units
31
and
32,
Turns coal
in Unit 33 and Exxon Monterey coal in Lakeside.
13.
No new scrubber, bum Exxon Monterey coal in Lakeside, Turris coal in Units 31 and
32,
and a
blend of PRB and Exxon Monterey coals in Unit 33. Unit 33 scrubber remains in service.
14. No new
scrubber, bum
Turns
coal
in
Units
31
and
32
and
in Lakeside, and bum 100% PRB coal
in Unit 33. Unit 33 scrubber remains in service.
Burns & McDonnell prepared a description of the coal and FGD status, potential new coal handling
equipment that could be required, Dallnum Unit 33 FGD system modifications and boiler modifications for
each of the ten base options and the four additional options. CWLP and Bums & McDonnell subsequently
discussed
the options at a
meeting
on September It, 1998 at the
Dallnum
Station. Several
changes were
made to the additional options, based
on
input received from CWLP personnel.
FINAL
STUDY
COMPLIANCE
OPTIONS
The options agreed on by CWLP and Bums & McDonnell for further evaluation in the study are indicated
on Table III-1. Option 12 is not listed as it was eliminated during the K-T analysis o£ the options because
it was determined that blending of the PRB coal was not required, which made Option 12 the same as
Option 8. Table III-1 identifies the coal burned in each of the Dallman and
Lakeside units for each option.
Options 1 and 2 include the addition of a new FGD system to Dallnum Units
31
and
32. Figures
IV-2 and
W-3 indicate the scope of the FGD system. In addition, as
requested
by
CWLP a new ball mill would be
added to provide additional limestone grinding capacity for the new FGD, systems. Options 7 and 9 would
involve taking the Dallman Unit 33 scrubber out of service. Blanking plates would be installed
in
the
ductwork to provide a permanent bypass of the scrubber.
Modifications of the units burning alternate coals would potentially
be required to provide for acceptable
operation. Table
III-1 lists
changes
that might be needed to the coal feed systems, boiler air system, coal
grinding and storage, the boilers and the ash handling systems.
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Special coal handling features were also
assumed to be required for the options involving units burning
alternative
coals. Based on experience gained by CWLP during a test bum
of the
Exxon
Monterey coal
performed in November 1996,
the analysis includes a feed system to provide limestone to the boiler
with
the coal. The
limestone is required to control slagging due to the high ash fusion
temperatures of the
Monterey
coal. PRB coal was assumed to require the addition of dust collection systems and
enclosure of
the existing truck unloading hopper
because of high potential for dusting. Because it may not be feasible to
provide rail
delivery of
PRB
coal to the Dallman plant site, off-site coal storage was evaluated. Upgrade
of
the existing hammermill crushers for Dallman
Unit
31
and 32 may also be required to handle PRB coal.
CWLPIII.doc
HI-3
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
TABLE III -1
P HASE II SO, COMPLIANCE OPTIONS
Dallman and Lakeside Stations
O PTIONS
1
2
3
6
8
8
7
8
9
10
11
13
10
COAL
Lakeside7&e
Turns
Monterey
Monterey
Monterey
Turns
Turns
Monterey
Monterey
Turns
Turrls
Monterey
Most .. y
Turns
Dellman 31 & 32
Turris
Tuns
Turds
Monterey
Montere
Turns
PRB
PRB
PRB
FPS
PRB
Turns
PRB
Dallmen33
Turns
Tuna
Turns
Turns
-Turns
Turns
PRB
Tuns
PRB
Tuns
PRB
Pfl Rurris
PRB
FGOSYSTEM
Lakeside 7
& 9
None
None
None
None
None
None
None - -
None
None
None
None
None
None
Dallman31&32
AddFGOSystem I
Insult 3rd bell mill
AddFGDSystem
/
Install 3N ball mill
None
None
None
None
None
None
None
None
None
None
None
Dallmen33
On
On
On
On
On
On
Off/ Insbypaaamanent
O
n
0a/Insallpermanent
On
On
On
On
POTENTIAL UNIT MODIFICATIONS
Lakeside 7 & B
None
Nor.
None
None
None
None
None
None
None
None
None
None
- None
Dellman 31 & 32
None
None
None
None
None
None
Raise
coal
feeder
leveling bar; add split
dampers,
aaemate
(hot) PA source,
modulate PA volume
damper
Raise coal feeder
leveling bar; add split
dampers, alternate
(hat) PA source,
modulate PA volume
damper
R.I.. coal feeder
leveling bar; add split
dampers, alternate
(hot) PA source,
modulate
PA
Valume
damper
Raise ..I feeder
leveling bar; add split
dampers, alternate
(hot) PA source,
modulate PA volume
damper
Raise coal feeder
leveling bar; add split
dampen, alternate
(hot) PA source,
modulate PA volume
damper
None
Raise coal feeder
leveling bar; add split
dampers, akernel.
(hot) PA source,
modulate PA volume
damper
Dellman 33
None
None
None
None
None
Non.
Add electronic coal
weigh system; raise
coal
feeder leveling
bar; add mill
Insuring
end wash
noules;add
bunker ineding, add
water lan... nd
pump skid. verdilut.
with water when
pullingesh. S...rash
handling system often
with
bottom ash.
N
one
A dd
electronic
coal
weigh system; flee
coal feeder leveling
bar;
add
mill
Ineding
and
wash noules;add
bunker
InertIng, add
water lances end
pump
-kid,overdilute
with waterwhen
pulling ash. Scour ash
handling
system aRan
Win bottom ash.
N
one
A ddelactronlccoal
weigh
system; raise
coal
feeder
leveling
bar;
add mill meting
end wash noaalaa.dd
bunker ineding, add
water lances and
pump
skid, overdllute
with water when
pulling ash. Scour ash
handling
system often
Win bottom ash.
Add electronic
ccal
weigh system; reiae
coal feeder leveling
bar; add mill
loaning
end
wash noazles;add
bunker
Ineding, add
water lances and
pump skid,
ovenilute
wkhvroterwhen
pullingesh. Scouresh
handling system often
with
bottom ash.
Add alectir.nic coal
weigh system; miss
coal feeder leveling
bar; add
mill losing
and
wash nosderadd
bunker Inenlng, add
water lances and
pump
skid,
overdilute
with
weterwher
pulling ash Swuresh
handling systemoRen
with bottom ash.
C OAL HANDLING MODIFICATIONS
Limestone feed system
Lakeside 7 & 8
NIA
Add
Add
Add
N/A
N/A
Add
Add
N/A
N/A
Add
Add
N/A
Dellman
31
&
32
N/A
N/A
NIA
Add
Add
NIA
NIA
N/A -
N/A
N/A
-
-
N/A
-
NIA
N/A
Dallmen33
N/A
NIA
NIA
N/A
N/A
-NIA
N/A
N/A
N/A
N/A
N/A
N/A
N/A
PRB coal handling packs a'
Lakeside 7 & e
NIA
NIA
N/A
N/A
NIA
N/A
N/A
NIA
N/A
N/A
N/A
NIA
NIA
Dallman31&32
N/A
NIA
N/A
N/A
NIA
NIA
Add
Add
Add
Add
Add
N/A
Add
Dallmen
33
N/A
N/A
NIA
N/A
N/A
NIA
Add
NIA -
Add
WA
Add
Add
Add
Two
coal
ire operation
-
Lakeside 7&B
No
No
No
No
No
No
No
No
No
No
No
No
No
Dallmen 31 & 32
No
No
No
Yes
Yes
No
No
Yes
No
Yes
No
Yes
No
Dellman 33
No
No
No
Yes
Yes
No
No
Yes
No
Yes
No
Yes
No
Ofhstte Coal Storage
Lakeslde7&8
No
No
No
Na
No
No
No
-
No
No
No
No --
No
No
Dallmen 31 & 32
No
No
No
No
No
No
Yea
Yes
Yes
Yes
Yes
Yes
Yes
Dallmen33
No
No
No
No
No
No
Yes
No
Yes
No
Yes
No
Yes
Hemmermlf
Lekeslds 7 & 8
N/A
NIA
NIA
NIA
NIA
NIA
NIA
- N/A -
NIA
NIA
NIA
N/A
NIA
Dallmen 31 & 32
No Change
No Chan e
No
Change
No
Change
No
Charge
No
Chan e
U grade
Upgrade
Upgrade
Upgrade
U red.
No Change
U rode
Dallmen
33
NIA
N/A
NIA
N/A
N/A
N/A
N/A
N/A
NIA
NIA
N/A
N/A
N/A
I
I' (Includes dust collection system
for existing coal hdlg system enclosure of existing truck hopper end mlac, chute end conveyor upgrades)
0
b11114RAMIs
10/&80
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
PART IV
SCOPE OF MODIFICATIONS
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
PART
IV
SCOPE OF MODIFICATIONS
REQUIRED
Bums & McDonnell reviewed
the existing systems and
equipment at the Lakeside and Dallman generating
stations to determine the modifications
required for the implementation
of each
Phase
II S02 compliance
option. Bums & McDonnell
engineers who specialize in the respective
disciplines of coal handling, coal
combustion
and air pollution control provided
input to this review and assessment. Data
gathered and
observations made during visits to the plant
site
were
considered. Discussions with CWLP personnel
provided
additional insight into
the
feasibility
of the required modifications and their effects
on operation of
the coal handling
system, boilers, electrostatic
precipitators and FGD system.
The following
sections provide a discussion of the important factors
considered by each discipline in the
assessment of
the
modifications
required. The basis for the estimates
of the costs of the modifications for
each option is described.
Where the modifications would result in equipment performance degradation
or
increased
operation and maintenance
costs, the basis for the estimation of those costs is
stated.
COAL HANDLING AND STORAGE
The
coal switch options under consideration
as part of the Phase II S02 compliance planning for the
Lakeside and Dallman
stations include:
" Switching from Tunis
coal to medium sulfur Illinois coal (from the Exxon Monterey mine) for
the
cyclone boilers
at Lakeside and Dallman; and
" Switching to low
sulfur
Wyoming
Powder River Basin (PRB) coal in units 1, 2 and/or 3 at the
Dallman
station.
Because
CWLP has conducted a test bum of Monterey coal in one unit each at Lakeside and Dallman, and
because of the physical
similarity between the Turris and Monterey coals, the modifications required
to
switch to Monterey coal are well
established, and minimal in extent.
Consequently, the majority of the assessment effort was
directed at the modifications required to receive,
store, transport, unload, convey and crush the PRB coal for use
at
Dallman
station.
A
switch to
PRB
coal
was not considered by CWLP for Lakeside
due to the
impending
retirement of the units in 2011.
CWLPIV.doc
IV-
1
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
Handling PRB Coals-General
Considerations
There
are three major impacts on
coal handling operations when dealing with
Power River Basin
(PRE)
coals:
" Spontaneous combustion
" Fugitive dusting
" Higher bum rates
Spontaneous combustion
can occur with most
coals. The problem can be
significant with PRB coal.
Many utilities find they must
either bum PRB coal or compact it
in long term storage within 14
to 21 days
of
receipt,
to minimize the risk
of spontaneous combustion
depending on the weather
conditions. Putting
PRB coal into
storage requires
good stockpiling techniques.
The coal should be spread into
thin
layers
and
compacted.
Rubber tire dozers with
additional ballast can be used
to provide the required compaction
pressures. The
cost of a rubber tired
dozer was not included in
the cost estimates for this study because
of
the high cost and because
it would not be needed
often. Building the pile could
be performed using rented
equipment
or by subcontracting this work.
A
common characteristic of PRB
coals is the large amount
of fugitive dust created when it is handled. The
coal particles continually
break down with loss of moisture
and handling. Most PRB coal handling systems
use several types
of both active and passive dust
control. Dust that isn't controlled is
typically cleaned up
with
water wash down and
vacuum systems.
Because
PRB coals have a lower
BTU value than the Turris
coal currently used at Dallman, additional
coal must
be burned to provide the
same
heat
input to the boilers. At
CWLP, it is estimated that
approximately 25 percent more PRB
coal would be burned in the boilers (assuming the same
unit
ratings).
This
translates into longer operating hours for
the coal handling system.
Receiving
PRB Coal
Three alternatives were considered
for receiving rail shipments of PRB
coal
from
Wyoming. Technical
aspects
of these alternatives are discussed
below. Additional information regarding the
estimated scope and
cost of development
of the three alternatives is presented
in Appendix D.
Railcar Unloading at Dallman:
CWLP currently does not have
any
reliable
way to receive rail
delivered coal at the Dallman
and
Lakeside
power plants. The Lakeside track hopper is
abandoned and the
CWLPIV.doc
IV
- 2
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
Dallman hopper no longer has rail
sidings connected to it. The plant site is not large enough for
any type of
true unit train coal
deliveries.
With
major modifications to the existing
mil sidings, limited rail unloading could be restored at Dallman
for delivery of PRB
coals. The location of the existing Dallman track/truck hopper
on
the
east side of the
plant would only allow
short strings of
railcars
to be unloaded. Unloading railcars on the existing hopper
would
interfere with truck unloading activities used by some
of the other options (where some Turris coal is
still burned at Dallman). For
this
reason,
the cost estimates for this study were based on a new track
hopper
and storage sidings on the west side of Dallman.
See Figure N-1 for a diagram of this
arrangement.
Under
the PRB rail delivery to Dallman alternative, PRB "unit trains" would
be delivered to a Springfield
railyard and then
broken up for delivery to Dallman. It should be possible to handle strings of 10-20 cars
for delivery
at
Dallnum.
The new track hopper would have a stockout conveyor that would build a new
pile in the western part of the Dallman
coal yard.
Off-Site Rail Delivery: Two
alternatives to on-site rail delivery were identified by CWLP for
consideration during this study. The first alternative would use the existing bottom dump
unloading system
operated by Pawnee Transportation, near Pawnee, Illinois. This unloading system currently receives
and
unloads trains for Dominion Energy's Kincaid station. The system can unload
rapid-discharge
hopper
cars
at a rate
of
1200 TPH.
They generally take all day to unload a unit train. No coal thaw facilities are
currently installed. Only limited area is now
available for on-site (Pawnee) coal storage.
A second alternative would be for CWLP to develop
a
new rail
unloading/truck
loadout facility. A
tentative site, Curran, was identified southwest o£ Springfield. The
Cousin
site was visited by Burns &
McDonnell and CWLP and
appears to be an
industrial
park with
rail
sidings.
Additional property may
be
available nearby that is currently in agricultural use. A new facility could be designed to unload either
rotary
dump or rapid discharge rail cars. An unloading rate of more than 3500 TPH should allow
unloading times less than four hours, which should qualify for lower freight rates. The additional
undeveloped area near the site may be large enough for storage for up to
60
days worth of
PRB
coal. The
cost estimates for this study were based on installing a rotary rail car dump unloader at the site.
CWLPIV.doc
IV-3
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
',POND;
ILJI
ý
i
I
N EW
i
U
NLOADING
C ONVEYOR--ý~ý
T RANSFER
HOUSE NO.1
LAKE
NEW
TRUCK/TRACK HOPPER
SC
UN
RUBBER
T
J10L _
U33T
-1 -
- TRUCK
HOPPER
L IMESTONE
ý
H ANDLING
ý ý`J
ý
Eý
3 0" TRIPPER
CONVEYORS C1& C2
33
3 0" PLANT
CONVEYORS B1&
B2
3 0" RECLAIM
CONVEYORS
Al & A2
r CONVEYOR
TUNNEL (TYP)
r
RAIL/TRUCK
H
OPPERS
"4 & °5
4 2" STOCKOUT
CONVEYOR
E
NEW RADIAL STACKER
TRANSFER
HOUSE NO.2
TRANSFER
HOUSE
NO.3
B ASE OF
COAL STOCK
PILE
AT MAXIMUM HEIGHT
(APPROX.23,600 TONS)
3 0" RECLAIM
CONVEYOR D
Burns
0
McDonnell
C ITY LIGHT WATER
& POWER
CITY OF SPRINGFIELD,
ILLINOIS
V.Y.DALLMAN POWER
PLANT
UNITS 31,
32 & 33
COAL HANDLING SYSTEM
DALLMAN 2 - COAL PILE
FIGURE IV-1
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
60-Day PRB Coal
Storage
D
ue to the uncertainty of PRB coal deliveries, CWL&P
directed that this study include storage of a 60-day
supply
of coal for the options using PRB
coal.
This
reserve supply could be stored on-site
or at either of
the two off site coal receiving
terminals (Pawnee Transportation
or Curran). Under the maximum PRB
bum rate
options (Nos. 7,9,11 & 14), approximately 238,000 tons would need
to be
in long
term storage.
Costs for this long-term
coal storage are presented in Part V
and
in Appendix
D.
The Pawnee Transportation
unloading site does not appear to include land for long term storage of coal. If
additional land is available, it would have
to be developed for PRB coal storage. This would include
a
prepared
pile base, coal pile runoff with treatment facility
and possibly a pile watering system for fugitive
dust control.
The proposed
Contain site would require all the same features listed above for
the
Pawnee Transportation
site in
addition to a milcar unloader and rail. It is anticipated
that the
60
days pile and its runoff pond
could be developed inside
the proposed rail loop.
For storage at the Dallman plant
site, part of the 60-day supply at maximum bum rate could be stored in
the existing
coal yard. It is estimated that approximately 150,000
to
175,000
tons could be stored in the
existing Dallman
coal yard located south o£ the plant. A potential location for additional storage
could be
developed across the plant's discharge canal. This
area
would need
to be cleared and developed similar to
the other
offsite storage areas. The PRB coal would be reclaimed by a wheel loader into trucks for
delivery
to Dallman as required. A conveyor reclaim
system could be considered in the future.
H ammer
Mill Upgrades
It is generally
recommended that cyclone boilers using PRB fuels use a 97.5% passing 4-mesh coal size.
This is usually
a
finer grind
than
is
used with bituminous coals. The existing Pennsylvania Crusher
reversible
hammer mills can be adjusted for the finer grind, however there are usually higher horsepower
requirements
(horsepower
per
ton per hour) to obtain this operation. The finer grind requirements will
shorten hammer and cage life. Pennsylvania Crusher has developed a "fine grind kit" for retrofitting older
hammer mills crushing PRB coals. The new cage
system
is
designed to prolong cage/screen bar
life
when
making the finer grinds. Grinding PRB coal may fimit the crusher capacity when fine grinding. Typical
grinds
with bituminous coals use approximately 11/2 to 2 horsepower per ton per hour. When fine grinding
CWLPIV.doc
IV - 4
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
PRB coals, this will
climb to the 3.4 horsepower per
ton
per hour
range. In some cases, the
original
hammier mill design (generally
shaft size) may allow the use of
a
larger
motor. In other cases, a complete
hammer mill and motor replacement is required.
The
existing hammer mills have 500 HP
motors and are rated m 225 TPH,
which is very close to the 2
horsepower
per ton per hour "rule." It is
possible that the switch to a finer grind
of
PRB
coal will reduce
the hammer mill capacity. To offset this,
the
feed
rate to the mill could be reduced to obtain
the
higher
horsepower per ton ratios needed.
This would increase the time required
to
fill
the bunkers. If maintaining
the
current throughput is desired, the spare mill
could be operated to maintain capacity while achieving
the
finer grind.
The only upgrade included in the cost estimates for this
study was the addition of a fine grind
kit for
each crusher.
Dust Collection
B
ums & McDonnell recommends dust collection systems
be
installed
as part of any new coal handling
system. Dust
collection is even mom; important
when dealing with PRB coals, due to their tendency to
break down faster than most
other coals. This study includes the cost of dust
collection addition for the
options burning PRB coal,
Two
of the most critical areas at Dallm m
are the crusher house and the tripper bay. The crusher house
does not have any active dust collection
and it is understood has been a continuous source of fugitive
emissions. The
tripper bay does have existing
dust collection systems but they are frequently out of
service. The indoor
location of the existing collectors is no longer
desirable due to the problem of a
deflagration release
inside the powerhouse structures.
E nclosure Of Truck Dumping
Operations
The existing truck dumping operations
at both Lakeside and Dallman are done in the open. Then; are no
buildings around
these areas. At Dallman, trucks can dump in the truck hopper for stockout on Conveyor
E or directly onto the storage
pile.
At Lakeside,
trucks dump directly onto the storage area.
The Turris coal is
partially
washed
and
is not
a large dust problem when first received. Should PRB coals
be received, this could change substantially due to the
generally
higher silt content found in PRB
coals. An
enclosure probably would be required to maintain current fugitive dust emission levels, and was included in
CWLPIV.doc
IV
- 5
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
the study cost estimates. Dust
collection and/or wet suppression is
often used to further reduce
unloading
emissions.
Coal Handling
Washdown and
Vacuum Systems
Any dust inside the coal handling
system that the active dust control systems
do
not
capture will eventually
have
to be cleaned up. Most coal handling
systems are equipped with at least
a partial water wash down
system.
A typical
system will have a header pipe
along the conveyor with hose stations at
approximately 100 feet
intervals. Hoses
are usually
11/2
inch diameter, though some
plants use fire hoses. "Start at the top, wash
to the bottom" is
the usual procedure. Water systems all have
me big drawback in northern climates -
freezing.
For this reason, many PRE
coal users also install a vacuum
system along the conveyors and
inside buildings.
One vacuum
system that works well for many
users is a rigid vacuum pipe in conveyors and buildings
with
vacuum hose
stations at 50-100ft intervals and
on each floor in buildings. Rather than use dedicated
vacuum producers
at each building, many
utilities use a truck or trailer mounted vacuum producer.
This
can be driven or towed
to the required building or conveyor, The
vacuum systems are not as neat or as
easy to use as water wash
down, but they solve the freezing problems in
the winter.
Limestone
Addition for Monterey
Coal
Previous
CWLP test bums with the low
sulfur
Monterey
coal demonstrated the need for the addition
of
11/2% by weight of limestone
to blend in the coal for use in any of the cyclone boilers (Lakeside and
Dallnran 31/32). A storage silo
and
feed
system would be needed for this purpose. At Lakeside, this would
be done by relocating
the existing unused sorbent silo to
a
location near
the coal conveyors. A new weigh
feeder would
meter the already crushed limestone onto
the coal belts prior to the crushing. This would
allow for some blending
of the limestone into the coal prior to bunkering. Limestone
would be delivered by
bulk tanker and unloaded pneumatically directly into the limestone
silo.
CWLPIV.doc
IV
- 6
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
Handling Two Coals at Dallman
M
any of the S02 compliance options involving fuel
switching (4,5,8,10, & 13) would use
two types of coal
for fueling the Dallman
Station. Any of these options will present
a
number
of challenges to the existing
coal handling system including:
" There is
only one unloading hopper and stockout
conveyor, the E-belt.
" The two main reclaim hoppers
are located under the main stock pile
" The
only
"remote"
reclaim hopper ("D") is on the
extreme east end of the coal yard and has only
limited stockpile capacity over and
around
it.
" The existing
coal yard is long and narrow. Its growth is limited
by the Springfield Lake and the
plant structure.
The first requirement for a two-coal
receiving scenario would be to build a second truck dump hopper
and
a
new
stockout conveyor. The second
unloading/stockout system could be built in the southwest comer of
the
coal yard. Coal trucks could be routed
around the west side of Dallman m reduce traffic on the east
side. Having
two separate unloading and stockout locations would
allow simultaneous delivery of two
types of
coal.
Reclaim from the second
stockpile
has
a number of alternatives. The least expensive approach, based on
capital required, would be to doze coal from
the second pile to the "D" reclaim hopper. This would be a
long distance for everyday
dozing. A coal scraper or a Raygo carry dozer may be more practical than a
conventional dozer with a coal blade.
A more automated system would
add a reclaim
hopper
and conveyor to transport the coal back to the' D"
reclaim hopper. Both above ground and below ground
conveying systems could be used to tie into the
existing IA/B
or
D
conveyors. The reclaim hoppers could be arranged similar to the existing layout with
both under pile and outside of pile hoppers. The reclaimed coal could be discharged onto a small
radial
stacker that would discharge into the "D" reclaim hopper. The radial stacker could be swung out of the
way when not in use. This
system was included in the cost estimates for this study. Figure IV-1 provides
a diagram showing the equipment which would be required to implement the scheme for handling two coals
at the Dallman station.
CWLPIV.doc
IV - 7
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
COMBUSTION
SYSTEMS AND EQUIPMENT
F or purposes
of this study, the combustion systems
and equipment at the Lakeside and Dallman stations
were reviewed to determine the extent
of
modifications
required to accommodate the coal
switches being
considered
as options for Pbase II SOr
compliance. A total of 13 areas of concern were identified for
evaluation
o£ the adequacy of the existing equipment
and systems. In each area, the existing equipment
capacities
were reviewed. Calcuhdions were performed
to determine the relative need for equipment
upgrades or replacement.
The results of this assessment
are displayed in Table IV-l. The table shows the determination of
modifications
required, if any, for each
boiler
under
the condition dictated by each of the 14 compliance
options described in Part III. Note that because there is no
coal switch for any unit under Options 1 and 6,
them will be no need to make any modifications.
Similarly, some options involve coal switches for two or
more of the five
boilers, but no change in the coal burned for the mmauting boilers.
The following
sections describe the considerations involved in the assessment
of equipment adequacy and
the need for modifications in each
of
the
areas of concern shown on the tabulation. They are presented in
the same order as displayed
on Table IV-1.
Forced Draft Fans
FD
Fm capacity is primarily
determined
by the
quantity of
heat
release, or carbon burned. Switching to a
coal with a higher or lower heating value
(HHV) will change the coal flow as required to maintain a
constant carbon input, but will not-in itself-change
air
flow. Air flow is matched
to carbon input.
However, switching
to a coal with a higher moisture content will deteriorate boiler efficiency, requiring
additional
carbon input (fuel flow) and a proportional increase in air flow. The only fuel in this study
which would
affect the
FD Fan
capacity is the switch to PRB coal. The increased moisture introduced into
the furnace by the switch to PRB coalmill
deteriorate boiler efficiency approximately one percent and thus
increase FD Fan capacity requirement
by approximately this same amount. Thus, no change
in FD
Fan
capacity or head is required. The degradation in unit heat rate due to the increased moisture content of the
coal is addressed in the economic analysis presented in Part V.
CWLPIV.doc
IV - 8
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
TABLE
IV-1
POTENTIAL UNIT IMPACTS I MODIFICATIONS
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Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
Induced Draft Fan
Capacity or Head (Unit 33 only)
T
he ID Fan capacity is influenced by the same parameters
discussed above for FD Fan capacity. In
addition,
the
increase
in fuel moisture mentioned above will result in an increase in flue
gas volume because
of the additional moisture. For PRB
coal this increase is estimated to require a two percent increase in
capacity. This should not require any modification to the existing fans.
C oal Feeder Capacity
A ll five units
use coal feeders manufactured by the Stock Equipment Company. The Monterey coal is
similar to the Turris
coal, and thus will not require a change in feeder capacity. However, the PRB coal
heating
value is quite low (8,375 Bm/Ib compared to 10,500Btu/Ib for Turns coal), requiring a significant
increase
in coal mass feed rate. The coal feeders for Units 31 and 32 have already been converted to
employ an electronic weigh system. With the electronic weigh system, the leveling bar can simply be raised
to increase
the capacity of the coal feeder. On unit 33, however, the feeder control system has not been
upgraded. Thus,
to accommodate PRB coal a modification will be required to increase the leveling bar
position. Conversion to the electronic weigh system for
all
four feeders has also been assumed.
Bowl Mill Capacity
The
boiler for Unit 33 utilizes pulverized coal combustion. Coal pulverization is achieved with four bowl-
type
pulverizers, Currently, on Turris coal, one mill is available as a spare, even at full load operation.
The effective mill capacity is affected by the coal grindability, moisture, and feed size. The combination of
these factors indicate
that the mill capacity is entirely adequate for all coals except
PRB
coal.
For PRB
coal, calculations indicate that all four mills must be operated to attain the firing rates necessary for full
load
operation.
This
mode of operation will decrease the reliability of the combustion system
for
Unit
33.
Consequently, Bums & McDonnell identified Option 13, which allows blending of PRB coal and Turns
coal as required to maintain full load on only three mills.
Exhauster Capacity and Head
C onversion to PRB coal would significantly affect the requirement for the exhausters which
serve
each
bowl mill. The exhauster capacity requirements for Unit 33 are affected by the change in required coal
flow,
the change
in primary
air to
fuel ratio,
and the
change in mill exit temperature. Head is affected by
the resultant change in coal pipe velocity. At maximum mill coal capacity the expected increase in air-to-
fuel ratio, accounting for the expected decrease in mill exit temperature, is calculated to result in a change
CWLPIV.doc
IV - 9
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
in coal pipe velocity from 5,000 feet
per minute to 5,560 feet
per minute. This corresponds
to a 24 percent
increase
in head requirements. For
purposes of this study, Bums
& McDonnell has assumed
that the
capacity
of the four existing exhausters
can be upgraded via mechanical modifications
to provide
the
additional flow and head. Any additional capacity
increase requirement will necessitate
placing an
additional mill
and exhauster in service. If
CWLP proceeds with a PRB coal
conversion for Unit 33, a test
bum of PRB coal
would be recommended to confirm
the adequacy of this assumption.
Coal Pipe
Size
The Unit 33 pulverized
coal pipes are 18 inches outside diameter,
and adequately large to convey the PRB
coal
to the furnace. The coal pipe
velocity, assuming an initial design maximum
velocity of 5,000 feet per
minute, is estimated to increase
to 5,560 feet per minute. This
should be within acceptable operating limits.
M ill
Inerting and Mill Wash
Experience has shown
that inerting systems should be added to coal pulverizers
in association with
conversion to PRB coal, for
consideration of prevention of fire and
explosion. Mill inerting and mill wash
nozzles both
are assumed to be required for
each option involving use of PRB coal in
Unit
33.
Cyclone
Modifications
F iring PRB
coal in a cyclone-fired furnace requires
special precautions and techniques. The cyclone
modifications for
Units 31 and 32 include the addition
of split dampers, the ducting of primary air to a
hotter
source, and remote modulation of the PA
volume damper. The split damper restricts
secondary air
flow at the burner
end of the cyclone hr an attempt to retain
the coal and slag in the system as long as
possible. The hotter primary air will help
to prevent cooling of the fire at the burner
end of the cyclone.
Modulation of the primary
air dampers helps maintain the proper secondary
to primary air ratio at all
cyclone loads.
Cyclone Slag Fluxing Agent
P revious tests by CWLP have indicated
that limestone fluxing agent is required to bum Monterey coal in
Units 31
and
32.
The costs of this modification are included
under the coal handling system evaluation.
CWLPIV.doc
IV - 10
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
Bunkerlnertlng
One of the characteristics
of PRE coal is its
tendency to spontaneously combust,
and the most likely place
for
this to happen is in the
coal storage bunkers. A
COr inciting system
can be retrofit to each bunker
to
quench
a
fire
if one should
arise.
Furnace
Cleaning
PRB
coal contains an unusually
high percentage
of calcium, magnesium, and
sodium in the ash. These
minerals deposit on the furnace
water walls in a white film,
and reflect a large portion
of the radiant heat
energy.
Normal air
or steam soctblowers are not
effective at removing this
reflective coating. Water
lances,
however,
are effective in removing
these deposits. For
Unit 33 Bums & McDonnell
estimates the
requirement
for an addition of 10 water lances
and one pump skid. For
Units 31 and 32, five water lances
and one pump
skid have been included in
the modifications required.
Ash Handling System
Operation
T
he alkaline chemical
constituents of PRB coal
ash make it susceptible to formation
of cementitious
deposits in
wet ash handling
systems. In some cases PRB
coal conversions have required
the conversion to
dry ash handling. However,
with the configuration
of the existing ash
sluice system at Dallman, it should
be possible
to avoid problems by proper
operation and sequencing
of the system. Use of increased water
to
ash ratios in the
sluice system will minimize
the chance for hard deposits
to form in the pipelines. Periodic
cycling of the system to
sluice 100 percent bottom
ash will
provide
a scouring action
on the pipe which
should also prevent
the buildup of scale in the lines.
No physical modifications
to the system will be
required
to accomplish
this operational sequencing. Therefore,
no costs have been
assigned to the ash
system as part of the cost
estimates for the PRB coal
switching options.
AIR
POLLUTION CONTROL
EQUIPMENT
The Phase
II S02 compliance options identified
for this study, as described
in Part III, include several
which include the retrofit
of
flue
gas desulfurization (FGD)
systems to Dalhnmm Units 31 and 32. In
addition,
options 7 and 9 are based on
shutting off the existing FGD system for
Unit 33 in conjunction with
a switch to PRB
coal. Finally, all the options that include
coal switching to PRB coal have
the potential to
adversely
affect the performance of the
existing electrostatic precipitators (ESPs). To
assess the
modifications required for
each of these options, Burns & McDonnell
reviewed available information on the
CWLPIV.doc
IV-
11
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
existing FGD system and ESPs,
and consulted with CWLP personnel.
The results of that assessment
are
described
below for each
topic.
Retrofit
FGD Systems for Units 31 ti 32
In order to take
advantage of the existence
of the FGD system on Unit 33,
the
FGD
process for application
to Units 31 and 32 would
be the same, namely the
wet limestone process with forced
oxidation to produce a
gypsum byproduct. The use
of an
identical
process allows the sharing
of some common equipment
and
systems. In the case
of the vacuum filters, the systems installed
for Unit 33 have sufficient
capacity to
allow for the additional requirements
of the FGD systems for
Units 31 and 32 without modification.
For
limestone grinding, the existing
Unit 33 systems will require upgrading
to increase capacity so that the
combined
needs of the scrubbing
systems for the three boilers
can be met without compromising system
reliability.
The addition of a third wet
grinding mill equal in capacity
to the existing Unit 33 mills has been
assumed as the basis for the study.
Figure N-2 shows
the conceptual flow diagram for
the retrofit FGD systems, and indicates
the interfaces
with the
existing systems for Unit 33. Based on preferences
as dictated by CWLP for this study,
each
boiler will be
provided with a separate S02
absorber. A possible arrangement of the
absorbers and
auxiliary equipment is shown
on
Figure
N-3. The retrofit FGD
systems are assumed to utilize the existing
chimney liners. Costs for
alloy "wallpapering" of the liners have been included in the
cost estimate.
Details
of the cost estimate, indicating
the scope assumed for the FGD retrofit,
are tabulated in Appendix
E.
Shutting
Off the Unit
33 FGD
System
Options 7
and 9 are based on the assumption
that the Unit 33 FGD system can be shut off if the
boiler
is
switched to bum 100 percent
PRB coal. With regard to this, it is
assumed that blanking plates will be
installed in the
ductwork to isolate the FGD system flow path from
the main flue gas flow path. It is
assumed that the FGD system
would be "abandoned in place". No cost for
demolition of the FGD
absorbers or related equipment is included.
A consequence of shutting off the FGD
system is that the current location of the opacity monitors
would
no longer be workable. It is assumed
that the scope of Options 7 and 9 include relocation of the opacity
monitor to the stack.
C WLPIV.doc
IV
- 12
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
Existing
Disposal
;
Return
Water Tank ý._.
Disposal
Hydroclones
Existing j
Wet Well 1
Tank
By-product
Transfer
Pumps
Slurry
Bleed
Pumps
By-product
Storage
Tank
Compressors
Oxidation
Air
F
igure
IV-2-Preliminary
FGD System
Flow
Diagram
,"1295
Dallman Station Units 31 & 32
Reagent
Feed
Existing
-r.
ýTank
Reagent
Feed
Pumps
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
REAMGN -ANN
Q
NEW
AIISGRSE
Q. UNIT
32
L UNIT
31
F igure IV-3-FGD
System
Plot Plan
Dallman
Units 31 &
32
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
Impact of Fuel Switching on Precipitator
Performance
A graphical approach was used
to estimate the performance o£ the Dallman
unit's electrostatic precipitators
while
the boilers are firing PRB coal. This
approach used the data generated by two computer programs
as
input.
The first program was
rum
to
estunate the ash resistivity of the PRB coal fly ash. This program
(RESIST)
uses the elemental composition of the
ash, the ultimate fuel analysis and dam describing the
operating
conditions at the precipitator inlet to calculate three resistivity factors. The
combination of these
resistivity factors
yields the bulk resistivity of the ash. A value
of
1x10"
Ohm-cm was selected as a
representative resistivity
value for these fuels. A second program, developed for the United
States
Environmental Protection Agency
(USEPA) and (mown as ESPMV3, was used to generate a series of
curves
showing the relationship of removal efficiency to Specific Collection Area
(SCA) and ash
resistivity.
The performance of the precipitators was estimated by superimposing
the design SCA values to a
point on the SCA/Resistivity plot. Refer to Figure
IV-0.
This
point is located where the estimated ash
resistivity line
(1x10" Ohm-cm) intersects the line rising vertically from the X-axis representing the
design
SCA. The
removal efficiency is read from the Y-axis. The results of the analysis showed that both units
(SCA approximately 290)
in good condition could be expected to have a removal efficiency of
approximately 99% on
ash with a bulk ash resistivity of IxlO" Ohmcm. A removal percentage of near
99% will be required to maintain
particulate emissions below 0.1 Ib/MBtu as required by the emission
limits
applied to these units. It should be noted
that the design SCA should be considered as marginal for
opacity
and particulate emissions compliance on PRB coal. Factors
such as
increased
gas
flow,
elevated
precipitator inlet temperature, ash particle size and fly ash /
bottom ash split have significant influence on
precipitator performance.
If conversion to PRB coal is to proceed, it is strongly recommended that an
extended test bum be performed
to confirm the suitability of these precipitators under the 100% PRB firing
operating conditions. In order to achieve continuous compliance under all operating conditions, it may be
necessary
to add
flue
gas conditioning to each unit.
CWLPIV.doc
IV - 13
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
Figure NJ
Estlmat-A BIoarostetle Precipitator Perfomonce - PRB
Cwl
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4WneCgIMbi.YrINU
CWLPIV.doc
IV - 14
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
PART
V
COMPLIANCE
OPTION SCREENING
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
PART
V
COMPLIANCE
OPTION SCREENING
F ollowing identification
and agreement on the
compliance options for this study, Bums
& McDonnell
performed
a screening of each option to determine the relative
suitability of each option to meet
CWLP's
Phase
11
compliance
requirements. CWLP's
previous Phase II compliance studies identified
the technical
advantages and disadvantages
of particular options and estimated
the compliance costs for each option
and
for each unit. As described
in Part II, costs were estimated for each of the compliance
options. In addition,
a benefit / risk evaluation
of each option was done and a Kepner-Tregoe
(K-T) analysis was performed
to
determine the
preferred option according
to CWLP's assessment of each
options
relative
fulfillment of
identified
significant criteria.
K-T DECISION
ANALYSIS
A K-T analysis of the Phase
II S02, compliance options was
used to compare the ability of each option
to
meet CWLP's required
and desired technical objectives. From
a technical standpoint, the K-T analysis
provides a systematic
approach to decision making and problem
analysis. The relative costs of the options
were not considered when the K-T
analysis was performed.
Bums
& McDonnell prepared a suggested
list of technical criteria for the K-T
analysis.
These
criteria
were discussed with CWLP and the K-T analysis
performed during a meeting at the Dalko n Station
on
September
22, 1998.
" Musts" Criteria
T
echnical objectives for the compliance
options were defined either as "Musts" or as "Wants".
The
"Must" criteria were
those aspects the option has to meet
to be considered viable. If an option didn't meet
all of the "Must" criteria were
established during the study, it was eliminated from further
consideration.
Based
on input received from CWLP, Bums
&
McDonnell
included the following "Must" criteria on the
K-T chart
used to perform the analysis: "Maintain
space
for NO.
controls to be added at a later date".
CWLP believes that some type of NO.
controls my have to be added to the units because of future
regulatory
mandate and desires to maintain
the
flexibility
to be able to do this with minimal impact to the
existing plant. Additional
criteria discussed, but not included in the analysis were the requirement
for the
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
option to meet
the terms of the
existing Turris coal contract, meeting the
SOa allowance cap for
the plant
and providing and
maimaining safe operating
conditions at the plant.
Although it does
appear that some of
the options would not
meet the Turns
coal contract, CWLP directed
that this not be considered
a
requirement
for this study. It was
discussed that utilities that have changed
coal supplies may have
faced a
contract issue with
their original supplier
to
make
the change. The coal
contract and the allowance
cap
were
also noted to be related
to economics and therefore
would not be suitable to be
considered in the K-T
analysis. Safety
was not specifically listed
as a technical criteria because it was agreed
that this
requirement
would be included
to any option that is implemented.
" Wants" Criteria
T
echnical criteria
that were deemed to be
desirable but not mandatory were identified
and classified as
"Wants".
Each of the "Wants"
was assigned a numerical weight
to reflect its relative importance
as
compared
to the other "Wants" criteria. Each
option was then scored on its ability
to meet each "Want"
criteria. The optionjudged
to meet the
criteria the best was given a score
of 10 with the other options
scored
relative to the best
option. A weighted score for
each option was then calculated for
each criteria by
multiplying
the weight
of the option by the judged score. The weighted
scores were then added for each
option to
arrive at the overall option
score. The highest overall
score identified the best option on the
basis
of technical merit.
The
following "Wants"
criteria were suggested
by
Bums
& McDonnell and were
based on input received
from
CWLP and Bums & McDonnell's
experience:
"Minimize reliance
on S02 allowance market" - This criteria
provided a measure of the
dependence on the external
allowance market for each
option. If an option does not meet the
allowance quantity received
by CWLP for the plant,
one alternative would be to purchase
allowances
to cover the extra emissions. This
could be costly depending on the market
or
could restrict additional growth
at the site.
"Minimize PRB
coal handling problems at Dallman" -
Because several of the options involve
multiple coal
sources, this criteria was included
to access the increased difficulty that could
be
encountered
as compared to the current operation
at the plant with only one coal source.
"Ease of operation" -
This criteria was included in the
analysis to indicate the impact of
changes on the
overall ease of operating the plant given
the potential modifications that night
be required for
a particular option.
"Reduction
of air toxics to aid in meeting future regulatory
requirements" - Future emission
regulations may contain requirements
to limit the emission of air toxics such
as
mercury
and
CWLPV.doc
V-2
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* * * * * PC #1 * * * * *
arsenic. The impact
of the quality of the coal source and the potential for removal
of a certain
percentage of these emissions
was accessed by thejudging of this
criteria.
" "Minimize congestion
on the plant site" - This criteria was included
to measure the relative
congestion
that might be added to the site from modifications
required by each option.
"Minimize vehicle traffic"
- With some of the changed coal source options considered,
a
result would be a higher
coal bum rate and therefore more trucks required to come on the
site
and deliver coal. This
criteria was used m assess this impact on the plant.
"Minimal impact on boiler reliability" - Because
changing the coal burned in the boiler could
have an impact on the reliability
of the boiler and related auxiliary equipment, this criteria was
included. Some existing
equipment might operate successfully with a switch in the fuel used,
but because
of the
fuel
change experience a shorter life or increased maintenance.
Following
discussion of the "Wants", it was decided
to change the wording of the second item to read
"Minimize
coal handling problems" to reflect
the global coal handling issues including the transportation,
transloading and off site storage of PRB coal. The
remaining "Wants" were agreed to and used to perform
the K-T analysis.
K-T Analysis
Results
F ollowing agreement
on the "Must" and "Wants" criteria to be used for the K-T
analysis, the evaluation of
each option was performed
by CWLP and Bums & McDonnell.
The options added to investigate
blends of coals, Option 12 and 13, were reviewed. These options had
initially
been added to reflect the possibility that blending may be required to
allow
PRB
coal to be burned.
After
further review it was determined that PRB can probably be burned m the cyclone boilers without
blending. If
the coal is not blended Option 12 becomes the same as Option 8. It was
therefore agreed that
Option 12 would be eliminated from
further consideration in the study.
The "Must"
criteria were reviewed for each option. It was agreed that all of the options met the criteria for
maintaining space for NO, controls
to be added at a later date. The "Wants" criteria were then reviewed to
determine a weight to assign
to each one
for
use
in
scoring of the options. The "Wants" weights were
determined by a consensus of the CWLP personnel attending the analysis meeting and are as listed below:
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* * * * * PC #1 * * * * *
WANTS CRITERIA
WEIGHT
Minimize
reliance on S02 allowance
market
40
Minimize PRB coal handling
problems at Dallm m
20
Ease of operation
7
Reduction
of air toxics to aid in meeting future
1
regulatory requirements
Minimize
congestion on the plant
site
1
Minimize vehicle
traffic
1
Minimal
impact on boiler reliability
30
TOTAL OF WEIGHTS
100
The
"Wants" criteria scores agreed to
by consensus of the group perfomdng the K-T
analysis are indicated
on Table V- I that is
included in Appendix B of this report.
It was decided during the K-T analysis meeting
that
the criteria "Minimize reliance on S02
allowance market" would be adjusted following the meeting
based on the calculated
allowances required for each option. The
effect on the K-T analysis due to this
adjustment is indicated on Table
V-la -Final K-T Analysis Matrix, included in Appendix
B. The details
of the adjustment made
are shown on Table V-3. Table V-2 was
used during the analysis to identify the
scope of unit modifications
that would be expected for each option.
The highest scoring option based
on the analysis of the "Wants" criteria for both the original
and
final
K-T
analysis was Option 1. Option 2 was
the
next highest
scoring option.
Option 2
and 11 received the highest score for the
"Minimize
reliance
on S02 allowance market"because
they both result in
excess allowances. Option 6 received the low score
for this criteria due to the high
number of allowances
that would have to be purchased to operate under
the conditions of this option.
For the "Minimize coal handling problems"
criteria, Options I and 6 received a score of 10 because only
one type of coal would have to be handled on the plant site
and
no
off site storage or handling of coal is
required. Options 7, 9, 11, and 13 received
the lowest scores because they involve several types of coal
being
burned
in
the units.
CWLPV.doc
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* * * * * PC #1 * * * * *
Option 6 received the
highest score for "Ease
of operation". This option reflects
the current conditions
and
operation
of the Dallman and Lakeside
units. Options 8
and 13 received the lowest
score because multiple
types
of coal are burned,
unit modifications would
be
required,
and coal handling changes
would be
required.
The "Reduction
of air toxics to
aid
in
meeting future regulatory requirements"
criteria was scored the
highest
for options 1
and 2 because they involve
the addition of FGD systems
to Dallman Units 31 and 32.
Options 7
and 9 received the lowest
scores for this criteria,
due to the condition that the Dallman
Unit 33
FGD
system is shut down.
Option 9 received
the highest score for
the "Minimize congestion on the
plant site" criteria, because
the
Dalhnan
Unit 33 FGD system
would be shut down. Option 13
received the lowest score for
this criteria
because
of the use of three types
o£ coal.
The highest scoring
option for the "Minimize
vehicle traffic" criteria
was Option 6, which is the current
operating
scenario and involves
only one type of coal.
Options I1 and
14
received
the
lowest
scores
because PRB coal is burned in
the Dallman units, which
would involve more truck deliveries. The
Dallman
Unit 33 scrubber is operating
for these options also,
which would involve limestone
deliveries.
Option 6 also received the highest score for
the "Minimal impact on boiler reliability".
It was estimated
that no
unit modifications
would be required for this option, while
the next highest option, option I would
involve some
changes due to the addition
of
FGD
systems to Dalkmut Units 31
and 32. The lowest scoring
option for
this criteria is Option 11 because the type of coal
burned would change for all units.
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
ECONOMIC ANALYSIS
F ollowing the completion
of the K-T analysis, development
of capital and
operating costs for each option
were
developed. The costs were input
to spreadsheets developed
to allow rapid assessment
of the effect of
changes in the value of key assumption parameters
on the "Total Evaluated
Cost" of each option. The
summary
spreadsheet results
are displayed on Table V-0. The
details for each option are presented
in
Tables V-0a through
V-0m, corresponding
to the 13 options that remained
after the K-T analysis.
Interpretation
of Results
A s shown
on the "Economic Analysis
Summary" sheets, the values in the
outlined "data entry boxes"
represent
the inputs for
the key variables on which
that particular printout is based. The key variables
are:
Allowance price
(Range evaluated was $100
to $300)
CEMS bias factor (This is
the effective ratio of total annual S02
emissions reported to the U.S.
EPA by the continuous
emission monitoring system to the
apparent value based on the fuel analysis
and the Unit 33 removal
efficiency. Based
on
1996
data, this ratio is 1.137 composite for the five
coal-fired units.
The data for 1997 is similar.)
" Unit 33 S02 removal
efficiency. (Base assumption for
the study is
90%).
Other
"variables" for which text
entry boxes have been included
on the summary spreadsheet include the
unit capacity factors
and the delivered price
of PRB coal. These were incorporated into
the electronic
version
of these spreadsheets to facilitate
sensitivity analyses. However, it
should be noted that, at
CWLP's direction,
the basis for this study was
a
80%
capacity factor for Dalhnan 3, 70% for
Dallman I
and 2 , and 50% for
the Lakeside units. As displayed
on the tables, this represents a total net generation
of
2,409,000
MWh for the coal-fired units. Also,
the $24.25/ton price for PRB coal (equivalent
to $1.45 per
million Btu) represents
the best estimate available
at this time of the actual price CWLP would pay to
purchase and ship PRB coal from Wyoming,
transload it to trucks at Pawnee
Transportation, and truck it
to the plant site. Other
assumptions used in the study are listed in Appendix
A.
The
result of the economic analysis for each option is
expressed as "Total Evaluated Cost", expressed as
$/MWb.
It should be noted, however, that this is
not equivalent to the true power production cost. A lack
of valid
data on fixed O & M costs for the plant prevented
the analysis of complete production costs.
The economic
analysis was done on a "zero banking of
allowances" basis. This means that any shortfall in
allowances compared to annual
CEMS-biased emissions was made up by purchasing
the
necessary
CWLPV.doc
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Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
allowances at the indicated
price. Similarly, any surplus of allowances
was converted to cash
by assuming
they would
be sold at the indicated
price.
The surnmary
sheet provides
an
indication
of the total tonnage of each type of
coal burned at the plant
based on the specified
input data and assumptions.
While this data allows CWLP
to make a rapid
determination of the extent
to which a given option is in
compliance with the terms of
CWLP's coal supply
contract with the Turris
Coal Company, the reader is
advised that no costs or penalties which may result
from
violation o£ this contract
have been included in the economic
analysis presented here.
Finally,
note that the
"Modification O & M" cost is not
zero for Option 6, which is the base case
representing
the current situation. The
"modification cost" reflects
the projected operation and
maintenance costs for
the Unit 33 FGD system.
it was necessary to include this
factor
in
the economic
analysis of
each option because the existing
FGD system plays a major role in
the total SO, emissions from
the Lakeside/Dallman
complex, and because
some options include the shutdown
of this
FGD
system.
Therefore,
to provide a valid comparison,
all cases, including the base
case or "Status Quo", must include
the FGD 0 & M cost.
Trends
Observed
R
eview of the tabulated results indicates
that the FGD retrofit options (Option 1
and
2)
are among the
lowest-cost
options on a $/MWIr
"total evaluated cost" basis. However, these
same two options represent
by far the most
capital-intensive options.
The "status quo"
case (Option 6), which has zero
capital cost but maximum allowance expenditure, is
seen
to be the lowest cost
option on a "total evaluated cost"
basis only for cases in which the allowance price is
near $100,
the bottom of the range established for
this study.
Options 11, 13,
and 14, in which the Unit 33
scrubber is still operated after that unit has switched
to
PRB
coal, represent some of the highest
"evaluated cost" options.
C WLPV.doc
V-7
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
Table V1 [100]
Economic Analysis Summery
Phase II S02 Compliance
Options
t he Malysls
Displayed Bebw b Booed 417:
Nbea.N.&
700 SOm
CEMSBýFxbra
1.1x7
wfb4FbesedePýS02ý
UnR33FGDmmwalaf
9079 rNarauswhereR'sinurvke
MS
.1prim(deyuaredbfpl"ay
24 .25f21an.a
1A48L7ABWQ8375BUb
Unft Capaily
Fý Usld Are:
e o.t
M D%
7 0.094
50.0%
50.0'%
CMUfD.b1= sx
B ook U M tftam 2x99):
D aemon=" ý
L abake=12yms
ReeuMnginaetýe
209,000MVJn
DaHman 3
MR.. 2
Daanan7
Uý 718
WR 617
s ot Mme
F YNCOSt CaR7al Carryiw ý
TýIFý, Capidl ý ý
AmuaIT. .ýIBYmad 7
Emu Bala2ke M.1 Cost
Cbý 0 6M a Mo&M C a4
Eapalduro Ta1sIEwIU ebdC4M
Turns
FRB
T. Tons
$
9
SMNYh
1
yTdWb
1 7 09%7 wommaoz
1 14705
0
0 17055 4 28023
2
4959=
2 737802 4.400477 15455
14.8 46281 X951
1492
2
W D-D1&D2 1 149779
0 1694.10 8070 2922
29698799 24593000 2742755 4432
42 38 74785 15.013
42
36032
19%
3
IalwerwowDrceora
1
1149778
0 1894.10 47782
29699769
000 71083 2069077
32 702 1352 2
35
733
4.78
4
" a
o7aD2
875
0 807
79781
32078220 5315
487
2987029 69
70551 14.74 708858 38 19409
15.04
5
4w1NTUmsRtaaeeib
. Tu
0 09%4
0 518498 26
1447 31 937
5793= 45274.9 2
34887945
74.40 1M7378 38135
75.00
fi 7 DTiTU' ynwDýoarmea
1
314705
0
0 6 169
7 0 28923
0
0 2
697 377 61
1 3.18 3,M -ýI %489107 14.72
7 w
t Rte
- RA' p6
0 1495
169410 15375
2
39 193
9SM M 5n
992532
41&59
17.29
M8271 41,M
5M
17.93
8
Rte
Turns
8 95028
043
169410 13122
1 34797
100n.472
9S
3=,W7 38404
1594 103018
3B 7986 15.99
8
7.4eT, FGDar
184
14&5630
0 22760
10888 69169
9112870 794484
870788 408 155 18% 7006781
4.i 7846 17.39
10 T uma
t sa R m m soz
8 08
843393
0 20 7
qt 33427269
1083048 844
3 0
37 822 75.80 841
38427
15.85
it
- Tw7gDlwDOn
0 748630
169410 8460 2832 69848193 9 105870
7!18858 3559
b 379
18.69
63 41069118 18.20
13
3 x71aPWAF667u4c6eq
D3 6 80741
823959 169410
69013
921 34.077%9 10473758 910
3,097
38 087 7591 289208
4078740 7892
1 4
9ýMMDOn
164,926
14&5630
0 is
4.7 39169903
9012670 765706 3 27
9 34.89232
7 9.05 475 W 43
7825
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
Table Vd [200]
Economic
Analysis Summary
Phase II
SO, Compliance Options
The
Anslysls Displayed Below is Based on:
Unit capacity Facbrs Used 144:
Allowance Prim of
200
36on
Dalhan
3
CEMSBiesFaoorof
1.1370mýllwluel-basedeýecEeE60semissiom:
Dyynan2
Un9MFGDrenwval4f
9096 Meoaseaxinrsittsineaves
Del61Mn1
PRB.1once ("haMdbMaplans a
24 .26Shel,w
1.448S/MBWa63MBono
Ulmade718
lalewdo 6n
80.096
70.096
79,096
W.W6
5 9.02
C
ostofDebt=6%
Bade Lire (frnm 2000}.
Dolman=20yeas
Lakeske=12 yens
Resulting in W Generation W
2.409.000 MMI
-
302 glmanm
FWCost Capital Caning Modifae5on TakdFuel.Capkal M.rca
A n mW7wcC0aIBanied 7
Enised Balmlw Mortal
C og Dtarpe
0 8M
aMOBM COM B
mendium
7delEwIu MedWM
D esui "
Tome
Me
M ode
Tons
Tars
$
$
LMWh
3
3a4aah
1 t maTUmrFC41on9tam
1 314705
0
0
17
49Q 2 8,923-509 2 445000) 2131662 44W477 35455699 14.72 892
36.4 48;1.12 15.13
2
lal=siaewOm0lam 1149779
0 169410
8670 2422 290 9.7 99 2454300 2142755 4432 42 38ý 274,M 15A8 4844 35790 1B
14.88
3
IakaBe-wofa0ielrtn
1149778
0 169410 41782
29889789
93000 11093
2 ,859.811 3 2580702 13.52 5"S.061 W A18,763 15.99
4
3 ý
m om
645
0 887
19181
W.078. 220
5 15000
467, 301 2 028 95 10 1 14.74 1417716 36928
15.33
5
' 4.TUýatIsYaade
8 09
0 518498 26568 1447 31
931 5193000 452749 2935
34 7
14.40 2 757 37582702 15.60
6 1 maTo rowunuoatý uo 1,31 4,M
&
0 49166 70
28= .%G
0
0 2838017 31761556 13.10 7415101 3917607 1626
7
MB
-FC9M
0 1/65630 1410
15,375
2
39946193 9205,670 805577 9M.532 41654= 1729
656ý11
42
1080.9 1756
8
o as
TUne os 8 45028
W ,M
119410 13122 1 34197558 10923472
85343 352067 3B40e968 1591 208038 3861104 16.03
kit ' 7 ý7un's MFG9 ar
1 61
1 4%630
0 22760 10 381W
911270
784484 870788 408%1% 18.95 2133582 42 737 17.81
10 Tunis is&Moae maw
-
809
-
643
0
20, 507
11 33421 69 10830472
944
320303 37585 2 15.60 1683077 3 9 &96 1 6.30
r<71 ' 7 ýmFGU 9n
0
-
145830
168,410 9460 2632 39 193 9105870 798858 3 328 N= 79 18.39
B 1 43775 18
18.17
13
3wManAPBertuni6lmd
660741 623
189410
39 3 (2M l 31 71
10413750 910903 3097
38080087 15.81 5384145 43484
12
18.04
1
14
IOOanne.rMWF000n
16,1.9261 1.465.6301
01
16,8451
(4753)1 39169.9031 90126701 785766 3527583 434&9232 1&W 950.580 44433,812
1844
4 On eFlpf Wlnn
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
Table Vd [300]
Economic
Analysis Summary
Phase II S02 Compliance Options
T he Analysis Displayed Below is Based on:
Unit Capacity Factors Used Are:
Mw arwe Pdse al
300
call. 3
CEMS&mFadmW
1.137
aslhetueFEasadaXIacwd502amiý
Dagman2
I1nh33FGDremosalo1
10%10rlhecass5ehemftisinaerv'se
DsllnanI
pRB.1price (delywedmlhepi"of
242s$dun,or
1.*186IMBM4gM7sRo4h
lahesId.7M
u Yed6e&7
60.D%
70.0%
70.0%
5 0.0%
50.0%
CoatalDebt=6%
Boob Use (from 20)0(:
Dalman=Myeers
laAeade ý 72 years
Resold" InýOenem6on0
2,408,000MYYf1
802 N ýnee F
.elCost
Capkal Cwryuq M Odf xon T oblFuel,Capial Ný
Mm1sITOiwCmleurned T
EmNed Balanm
Annual
Cost
Charge OdM
a rgOdM COC E2mmnddwe TaMlEValu amdCOM
Deswi i
Turns
lone
Ib
TOrn
T an
$
$
SIMWh
S
3 TN4h
1 1 0]%TuýRD-m.02
1 ,31 4, A6
0
0 17055 4 28923509 24450000 2131851 4 4%477
3
5455849
14.72 1488 36" .493 15.31
2
ýmp9.ota02
1749779
0 1 69410 9 670 2422 29%9799 24543000 2142755 4432.242
36ý 274, 71)6
1596
71 35 79
14.76
3
2 aam41.'6.mDiradlt
1 149779
0 1%410 41782
29%97%
930% 11%3 2 871
32580702 13.52 8907091 4148779] 1722
4
- 3wae
mac2
6 45028
0 887
19181
32078
5,31 5, 0 00
467 1
2,967,M9 25, 5 10,551 14.74 2126574 37637125
15.82
5
' 4xeaT.rswUrmM
8 09
0 518498 26
1447 31, M ,931 5193000 452749 2
265 34687
14.40 4342735 X0300% 1820
6 l maT 'ý6.M.emt
1 314705
0
0 49168 707 28823
0
0 2838047
31767
73.78 77122%2 1280408 17.80
7
Plm m.2a3FDDa1
0 14%630 1%410 15375
29,946,1M 9;205,M 605577 902532 41,65,1,3D2 1729 951812 428%113 17.70
8
F m m szT unh
6 e5029 N 3999 1 %410 13122 1 34197558
10=472
955343
3-M,067 384%9% 1594 309051 38714
16.07
9 ' 7.Tmrs moon
16, 1, 926 14%%0
0 22760 10 51%
8112670 794484 870768 40%5155
1895 3 ý200,= 4 4
1828
10 T -is 1S& - Fma m &M
8 09
-
643
0 20507
4 1 33127
70830472 8412% 3220
37
822 15.80 2 4 15 4 0110137 1 8.85
11
' 7 ý03MD an
0 14%630 1%410 9480 2632 5 193
8105670 798%8 3. 559 ,320 44 3 78 18.%
%1 43 12
18.06
13 ' 3ýýmarrunoa.W m
--
6 %741
M
169 410 3
013
929
1 )
34 071%9 10413758 970903 3%7 380%087 15b7 8076 17 46158265
19.16
1 14 1gam9xahmMDOn
164.928 1.4%.%0
0 16.845 (4.7537 39.1%.903 901267f1 7%.7% 352755f 43.463rn 1arc, 14JSaM 44913.7M t.ne
ý. m reo rs On ýý..
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
APPENDIX A
STUDY BASIS AND ASSUMPTIONS
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
APPENDIX
A
STUDY
BASIS
AND ASSUMPTIONS
Unit Ratings
D3 D2 Dl L7/8
L6/7
Net ratings MW
175
75 75 30
30
Capacity factor,%
80 70 70
50 50
Heat
rate (Btu/kWh) on Turris 11045
11452 11596 13199 13159
Heat
rate (Btu/kWh)
on Monterey n/a 11484 11628 13235
13195
Heat
Rate (Btu/kWh) on PRB 11230 11643
11790
n/a
n/a
P
ower usage
S tation service
(excl. FGD), %
7.0
7.0
7.0 n/a n/a
increase in
above due to PRB
35
35
35 n/a
n/a
Power cost for
sox power is equal to fuel cost for
the
respective unit, in $/mmBtu
S O, emission
factor = 95% of potential emission
based on
%S and HHV
CEM
Bias Factor = 1.317
(used only to determine allowance requirements)
FGD Assumptions
U nit 31/32
FGD capital cost =
Unit 31/32
fixed FGD O&M =
Unit 33 fixed FGD O&M
cost =
Unit 31/32
FGD aux power =
Unit
31/32
aux power cost =
Unit 33 FGD
aux power =
Unit 33
aux power cost =
Limestone Utilization =
Limestone Purity
(% CaCO,) _
Limestone cost=
Gypsum
Purity (%CaSO,"2H2O)=
Gypsum
Moisture,
% _
Gypsum
sale price =
$ 163/kW(net)
$6.825/kW-yr
$12.00/kW-yr
2.0% of gross M W generation for
the unit
fuel cost for the
respective
unit, $/mmBtu
2.5% of gross
MW generation for the unit
fuel cost for the respective
unit, $/mmBtu
95.0%
9 5.4%
$12.16/ton
95%
13%
$3.00/ton
B lanking plate cost for Options
7 & 9
Relocation
of COMS (Options 7 & 9)
$ 50,000
$50,000
CWLPAPPA.doc
A - 1
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
Coal Assumptions
HHV for Turris (Btu/Ib)
%S for Turris
Price for
Tunis (delivered)
HHV for Monterey
(Btu/Ib)
%
S for Monterey
Price for Monterey
(delivered)
HHV for PRB (Btu/16)
%S for
PRB
Price for PRB (delivered)
B lend % for
option 13 (PRB/Turris)
10,500
3.1%
$22.00/ton
10,250
1.0
$26.00/ton
8,375
0.37
$ 24.25/ton (includes
$3.0 transload plus truck haul)
80°/u/20%
(mass
basis)
Fluxing limestone blend ratio for Monterey
=
Fluxing limestone delivered
cost=
E conomic Assumptions
Book life, Dallman
Book life, Lakeside
Cost of money
Tax rate
Inflation
A lowance
Price Range
( one allowance =
1 ton SO,)
1 .5% of coal feed rate,
mass basis
$12.50/ton
20 years (year 2000 is
year No. 1)
12 years (year
2000 is year No. 1)
6.00%
0.0%
Not
included
$ 100 to
$300 each
C WLPAPPA.doc
A-2
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
CITY WATER,
LIGHT AND POWER
ENVIRONMENTAL EMISSIONS WORKSHEET
1 997 ACTUAL GENERATION
DATA, CEM AND ESTIMATED EMISSIONS DATA
New Emissions
Factors
_
AL - O
-UNlrs
c
TION B I
s
D alinvn
am
an
man
W as
a
-nI
ry Reyno
s
. e -
I
7EM
UNITS
3
-
2
1
Gm 7/Bk 8 Gen 8/Bk 7 TOTAL
UNITS
GT
GT
GT
TOTAL TOTAL
an'vxINeIRalirgr--
-
-MW
-
-- 775
75 --- 75
---
'- 30 --- --
70 - -'-395 --MW 1B
5 --115
148
533
Fadoc::
%
70.8%
64.7%
61.816 49.2%
48.7%
64.3% %
1.22% 0.71%
4.35%
3.60%
47.46%
NNGenerMen
MWH- 7,084,642
420,828
_406,412
_129,419 _127,872
2,1 ,173 MWH
1,923 ý
43,81 48,834 2,215,907
oNBum-
TansCoal_
-572,005
229,759 225,001
-_-
81,422
90,187 1,199,384 Gaham08
_202,211
114,725 038135 750,571 2, 7,516
ml Bum
-- --
---
985 3]0
_-.330
401
HealR6le
1RWH
11,04
11,452
11,596 1,3199
13,169
71,466 BTUMWH 14,514 77,008 12
,4
65 12,640
71 ,497
11ea "
M
M
BTU 11968,374 4,809,889
_4,709,239
1,7K 297 1,679,755
_
24,872_354 MMfu
27, 905 15,763
- -
545,793 599,461
25,481,815
IHeal cameM
STUAD
10462
10,467
18,465
1
0,472
10,473
10,465
.uNSUBUrCOnled-__
.__
%
- --
3,13% 7.73X
---3,17%
,
317%
_
3 .13%
__
_
1313%
%
0,24
0.25
3.70
_
0.01
reS02EMSeionRole"
_..-
-
RAmcoal
- -
118.90
-
11894
--
11894
---
_
116.90
__
11990 -- 116.80 41000Gal. 0.0335
_
0.0335 -
--0035 --
ObarMp Elficie,.
%
_ _84.7%
0.0%
_
0.0%
0.0%
-
0.0%
40.7%
- --
% -
0.0%
_
0. --
-
- OX
_
Ne1 S02 E.NSbn Rate
RAon
coal
18.24 178.84
118.94
118.94
116.90
70.48 R/1000 Gal. 0.0335 0.0335
-0.077
E.
Rat.
BAmcwl
144
33.8
33.9
33.8
_
33.9
_ _ _
2Q5 il%1060Ga1. 0.0050 0.008
_O.OAO
EmisaiwRale Mlmýl
0 .7704
0.1541
0.1501
0.1541
0.1511
0.4508 i7f00DGal,
0,0004 0.
0.000
Emi.bnRM.
"AOn.l
0.
0.5
0.5
0.5
_
OS
0.5 9HOWGal. 0.0803
OW 02
0.000
EmesbnRate
RRaný11
007
0.07
007
007
_
0.07
_
0.07 %/t0WGaL 0.0003
0.0002
0.000
EmaWnRale
Mancaal
0.0108 00106
0.0106
- _
0.0106
0.0108
0.0108 i/1MGa1, 0.000000 0.000000
0,000000
10Er111esbnRal"'
#46.N
0.004770
-
0.001040
0.001049
---- -
O.W1UC9
_0:001079
-
00028_40
.
XO Gai.
_
0.0 003
_ _
0000-2
--
-0.000
_
7 Emiaaim Pale
IMm coal
4,371
4,250
4 ,249
_
0,252
_
4,252
_.1760
XA%1000
M
Gal . 27.906 72B
----22 -968
awS02EmissionRate
R/MM9TI1
5.6805
5.6819
5.6828
56790
5.6786
_5.6829
XIMMBTU 02-424 0,2424
2424 0.0178
9502EmmabnRMe llMFIBTU
O.B717
58818
5.6926
.
567!10 -_5.6788
_
33677 I'Y%MMB7U
_0342
__0808
6043
N
---
ubn-ale
w/M M MB7U
B7U
0.8882
1.81-46
1.6149
18139
1.6137
1A66l9 YJMMETU
0.076 0.020 Oa25
0 698
PalbulaMEmkeionRale AIMMBTU
0.0396
0.0074
0.0074
0 0074
0,0074
_
0.0215 AVMM9U
0.003
0.
0.037
0081
_
EmlasbnRak
iIMMBTU
00239
0.0239
0.0239
00239
0.0239
0.0239 R/MMBTU
0.002
0.007
0249
0.016
Emission
Raw
R MMSTU
0.0033
0.00331 -0 .0633
0.0033 0.0033
0.0033 A/M BTU
0.063 OOD7
0021
_
0.017
FankMonRatRate
RIMCBTU 0.000507
0.000507 0.000507 0.000507 0.000507
_
07 X/MMBm 0.000003
0.000002 0.000051 0.000059
tOEmise nRNe
R/MMBTU O.W0228 0.000050
0.000050
00050 0.000050
0.000136
i/M BTU
0,002
0.001
0. 7
O D293
EmiubnRale
i/MMBTU
208.5
203.0
20.0 [::::!
07,0
-__2070
- 20 0. 7
X/MMBTU 168.W0
-
786.000 168_000,
_
166.000-
CALCULA TED EMISM
_
_
_ _
_
_
-s_
_
ONS
ý aPmal O alman
_
Amen
Lxkesl8e -
Lakeside
__
ý OwIUnil
aGay Reynolds Inlextate
G D
POLLUTANT
UNITS
3
2
1
Gen 7/Blr 8 Gen WBIr 7 TOTAL
UNITS
GT
GT
GT
TOTAL TOTAL
-
ms
,
16.53
13.66177 13380_.81
_I,Bd
.1
4,769_.
4
,
Tam
D.
.5
2.
3. U =47I411
yam
Tom
4,11814
3,-BB2.93
1
3,802.571
7,37603
1,355.33 14576.933
Tans
9.8780 55600 34.03
49.4950 14,586.33
ankWales
Tom
220.3
17.33 L_-837
6_78
_
_
267.77
TarcK
0.86301
__
8_0660 70.1 0 X3880
_
303_16
U VIOTAL
1
ar
1 /3 W6 i9 6 23Td7 6T3b-B2 -56695.7
Ta 15
117
. 370
7 O -463230
__
08 :737 - 5677420
Tons
143.00
5744
5625
20.36
2005
_297.10
Tme
0.6790
r
0.3810
679500
69.0130
396.11
Tnna
20,02
_B,W __798
2.85
ý 5
781
47.59 Tan
96880 D.3 0
58250 6.9010
48.49
Tans
3.03
122
119
ý
0T
61 Tom O.00B 0.000
0 0140 00153
B5
PM70
Tons
1.36
0.12
0.12
0.04 0.04
1,69
Tax
0.5380 03040 10.1810
11.0230
12.71
Tom
12
734.82 488183.43
477987.78 173087.65 7 495.13 2545088.59
Tons
2378.12
1308.33 45300.78 48925.2487
2590413.87
acs
.72 1
, 2
1
,10
2 .1
1,15 57 .15
,63
1131.1 0 175. f3
7
7.N
" Based m coal sum any.
Karl
"Nlnx
"" Based
m
9.54%
aserape coal ash canlenl
OBr2B199
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
SUMMARY
OF CWLP ALLOWANCE ALLOCATIONS
2000-2009 2010 thereafter
Dallman3
5,169
5,208
Dallman 2
1,569
1,570
Dallman
1
1,377
1,388
Lakeside 7
2,539
633
Lakeside 8
1,438
326
TOTAL
12,092
9,125
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
ITEM
Heat Input (OEM)
Heat Input (Unit Efficiency)
Difference
P
ercent Difference
1996 CEM vs
UNIT EFFICIENCY DATA
UNITS
Dall3man I Dall an
Dallman
Genkesidet3 I,
MMBTU 13,899,898
MMBTU
11,804,067
MMBTU
2,095,831
%
17.76%
5,338,498
4,992,489
346,009
6.93%a
15,16o.7
14 178.1
5,192,4411
952,9421
S02 (CEM)
Tons
6,187.4
S02
(With
Plant
heat input)
--
Tons
5.254.5
S02 Difference
--
Tons I
-
932.91
982.6
616,316
13.47%
14,130.6
12,453.4
1,677.2
G nk61Blre7
11.
TOTAL
11
TOTAL t
I
2 ,186,656 26,617,493
1,085,690 2,038,632 23,411,313
148,024 3,206,180
7.26%
13.70%
6,044.1 I 41,522.8
5,634.9 36,521.2
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
W317 D
MICAL STEAM
COAL
-QUALITY
DATA
Mine
4
Property Nave
U.S. Coal
District
T rrrr;J'
/ 1/ 144=
E lkhart Mining At"
Nf&ntlc Property
Prorlaate Analysis.
Moisture
':Volatile
"71xed Carbon
I7U/Lb.
Sulphur
Ultimate Analysis
Moisture
Carbon
Hydrogen
Nitrogen
Chlorine
Sulphur
.
Ash
Oxygen (Diff)
10
Sean Name
Until
Core
Data
Washed (g)
Riv'(A)
8 1.70 SP. CR.
(Dry)
..
(Dry)
1 4.632
39.362
ý '
4 6.23%
1
2,108
4 .202
6 8.03%
4.862
1.21%
0.091
4 .20%
1 3.332
8,282
A
sh
Mineral Analysis'
SSD2
A1203
F e203
T102
Ct0
MgO
Na20 --- -
N 20
P 205
S03
Undetermined
32.122
1 0.232
, 23.582
0 .351
1
4.812
0 .44%
- 1.082
1 .372
1 .122
1 3.62%
1 .292
r
tsion Temperatures of
Ash
/nq F
C ounty
Lease
State
Illinois
12.592
39.571
46.84; '
1 2,656
3.72%
6
9:582
5.071
1 .362
0.221
3 722
11.592
8.52%
4 5.712
11
12.612
19.00%
01781 i
8 .411
071%
1.222
1 .55% '
0.132
9 .7 2
1 .26%
1111nois No.
5
?rejected Washed
Product (C)
Washed
! 1.71 SP.
CR.
"As Eecelued"
7 F,7
f, 7'r
/.5-I/
0.75
''.at
9 . /.y
R aw
Washed 8 1.70 SP.
CR.
(Reducing)
(OxidfzinS) Teed-Fl-g) (Oxidizing)
sat[zu
Deforeetlon
1923'P
2160'£
1940'£
2200'£
8enlspherlPl
-
(H"1/2N)
2064'£
2318'£
2220'r
2360'£
yield
.2150'£
2414'£
2664'F
r
2560'£
Criodabllity
-
56.5
T250
.
2180'£
sa...+
yiý13
..
1 8.6
2
8.6
Z 6 .9 - 10.'7
- 2
10,450
2 .702
b ý<
are,
g
.4.. R--ýL.
J P.4
s
G F=r
y . ý
3
t p
3 .03.
S .v3
Sulphur
Ton- (Raw, Dry) t
Organic
1.94
Pyritic
2.20
$02
0.06
Total
4.20
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
Typical Coal Quality
Avmge-As Reocivcd
Basis
M ine:
CABALLO
l ocation:
Campbell County, Wyoming,
near Gillette
Type of
Coal:
Subbitummour:crashed run-of-mine
Loading
Capability:
Burlington Nonhem Railroad
Chicago & North Western
Transportation Company
ProxlmateAOalysis,wl%
Total Moisture
29,90
Ash
Elements, wl% as
Oxide
A sh
531
Phosphorus
Pentoxide,
Pros
0.93
Volatile Maner
3136
Silicon
Dioxide
Sio,
3453
Fired Carbon
33.43
Ferric
Oxide,
Fe:O,
5.02
Sulfur
37
Aluminum
Oxide.
ALO,
17.98
Gmss Calorific Value
Tiunium Dioxide.
Tio.
115
Btdib
8
450
Calcium
Oxide,
cad
20.91.
Kcal&g
4,694
Magnesium Oxide,
Mg0
3.75
SulfurTrioxide.
s o,
1 254
U ltimate
Analysis,
wt%
Potassium Oxide.
K,0
0.41
Total Moisture
29_90
Sodium Oxide.
NýO
158
Carbon
4852
Other
1.10
Hydrogen
3.40
Sulfur Forms, wt%
Nitrogen
0.71
Pyritic
0,06
Cldorine
0.02
Sulfate
0.01
Sulfur
0.37
Organic
030
Ash
531
Oxygen
11.79
Other Quality
Factors
Ash
Fusion
Equilibrium,
Moisture,
ý%
28.4
Temperature
'F
°C
Hardgmxe Grindability
Index, HGI
60
Reducing
HOI Moisture, wt%
21.8
Initial Deformation
2135
1170
Base to Acid
Ratio
059
Softening. H.W
2165
1285
Pounds
SO,
per
Million Btu
0.88
Hemispherical, H='h
W 2280
1195
Size
2 inches
x 0
Fluid
2230
1220
Oxidizing
Initial
Deformation
2185
1195
Sofiening,H-W
2210
1210
Hemispherical,
H - t/2 W
2220
1215
Fluid
2295
1255
Etoron Coal and
Monorails Company-Housto4 Team, USA-May 1,
1990
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
Typical, Coal Quality
Avenge-As Received Basis
Mme:
RAWHIDE
Imfon:
Campbell County, Wyoming,
near Gillette
Type of Coal:
Subbimminous; crushed
nunaf-m'u3e
Loading Capability: Burling= Northern Railroad
Proximate Analysis, an%
Total Moisture
30.00
Ash Elements, wt%
as Oxide
Ash
5.15
Phosphorus
Pentoxide,
PtO'
0.67
Volatile Maw
3121
Silicon Dioxide
Siot
31.11
Fixed Carbon
3354
Ferric Oxide,
Fe.03
5.75
Sulfur
36
Aluminum Oxide,
A1303
14.14
Gross Calmific Value
Titanium Dioxide,
T30,
1.00
B tu/lb
8300
Calcium
Oxide.
GO
24.12
Kc"g
4,611
Magnesium Oxide,
Mg0
5.45
S ulfur T rio xide,
5 03
14.18
U ltimate Analysis, wr%
Potassium Oxide,
KO
023
Total Moisture
30.00
Sodium Oxide,
N&0
133
Carbon
48.07
Other
2.02
Hydrogen
329
Nitrogen
0.69
Sulfur
Fonns,wl%
Chlorine
0.01
Pyritic
0.07
Sulfur
036
Sulfate
0,02
Ash
5.15
Organic
027
Oxygen
12.44
Other Quality Factors
Ash Fusion Temperature
"F
"C
Equilibrium Moisture, wr%
29.7
Reducing
Hadgrove Grindability Index, HGI
59
Initial Defomation
2160
1185
HGI Mosture,
w[%
215
Softening. H-W
2190
1200
BasemAcid Ratio
0.79
Hemispherical. H =v2 W 2205
1210
Pounds 503 per Million Bm
0.87
Fluid
2225
1220
Sire
2 inches x 0
Oxidizing
Initial Deformation
2 205
1210
Softening. H=
w
2225
1220
H e rmsphencal,H=
3h
w
2240
1230
Fluid
2265
1240
Exxon
Gal and
Mmmb
Company-Houston,
Tezax, U.SA.-Mxy
1. 19M
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
9611-00048-2
z d
Aa
11/13/96
,._ .tiara
1 1/08/96
to .1
1/08/ 96
:.'
d
S ands'
C LIENT
sr..;!aG
BY
CITY
WATER,
LIGHT AND POWER
DALLMAN POWER PLANT
ROOM 211, MUNICIPAL BLDG.
SPRINGPIELD, IL
62101
ATTN: GREGO FINIGAN
marks''VALL24AN POWER PLANT - MONTEREY
COAL
DRY BASIS MERCURY 0.07 UG/G
OXIFAT-M
ANALYSIS
Moisture
133302
Ash
133174
volatile
133175
Fixed
Carbon
133172
BTU
131989
'IF-BTU
131989
al Sulfur 134239
ILFUR FORMS
Pyritic
132492
Sulfate
132492
Organic
132492
Total
Sulfu=
134239
IT ER
SOLUBLE
Na20
ASME1974
,X20
ASME1974
Chlorine
ASME1974
L kalies
as Na20 ASM137
7SION TEMP.
O%
ASR
137857
. W
-1/2
W
tuid
As
Received
E ar+a
as++r
++r+r
a+rrr
a
'
Fi
RDARD
LAS
C) TORIES,INC.
Fzeebu+g , IL 62343-0039
D
ate:
12/20/96
' Sample ID: 961104802
Weight S
Dry
(,WLP
As
Dry
Basis
ZIP:
ULT-%=
ANALYSIS
Received
Basis
++aa+
t
Moisture
133302
+++++
... *.
10.83
1I"12
t
Carbon
135373 +++++
71.57
37.39
t Byd---ogea
D5373 +++++
4.72
51.78
t Nitrogen
D5373
+++++
1.53
12475
(7.353 t Chlorine
132361 ++++ý
0.12
1 3990
190,'i3t
Sulfur
D4233 +++++
1.1E
t++++
1.18 1.Z0
t
Ash
133174 +++++
10.83
..
t Oxygen (Diff.)
133176
+++++
10.0°
++++.
+++++
M-YBRAL
ANALYSIS
133662 t 19mited
Basis
aaa++
++rat
Phos. Pentamide,
P205
0.2'
t+art
+aar+
Silica,
5102
54.9-1
++a++
1.18 %,to
Ferric
Oxide,
FeZ03
5.3=
Alumina,
A1201
19.3E
Titania. Ti02
1.1-
tan+r
tttar
Lime.
C20
3.4(
t++++
att++
Magnesia,
Mg0
1.2(
++t+a
+r++a
Sulfur Trioxide,
S03
3.3:
Potasaium Oxide, X20
2.4'
*t+ra
**++t
Sodium Oxide,
Na20
1.5E
Barium. Oxide,
Boo
0.0:
R educing
Oxidizing
Strontium
ode,
Bra
0.0!
2150
2380
Mn^ganese
Dioxide,
M02
0.0'
2170
2400
Undetermined
0.8ý
2200
2423
Type of
Ash
AS,'4-1974
Eitumnon:
2260
2515
silica
value
AS[131974
77.4
3INDABTLITY INDEX
13409
++++t
O
aaa++
t Moist.
.MM INDEX UNCONDITIONED
taa+r
O
... **
t
Hoist-
=-M SWILLING LNDEX
13720
+++++
rparent Specific Gravity of Coal MedXC7113 +a++r
T250
Deg
H&W
262
Base/Acid
Ratio ASMR1974
0.2'
l b Ash/m.
BTU
`at+
lb 502/MM,
BTU
Fouling Index
A83S1974
Slaggiag Index
ASM1974
1 .8
a rat
_ ilibrium Moistuae
131412
++++"
Respectfully
Submittal,
4,
x icbarl
L. H:L ilb,"^
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
APPENDIX B
K-T ANALYSIS
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
TABLE V-1
ORIGINAL K-T ANALYSIS
MATRIX
O PTIONS
1
2
3
4
5
6
7
8
9
10
11
13
14
C
oal
L akeside
Units
Dallman 31 & 32
Turris
Turns
Monterey
Turns
Monterey
Turns
Monterey
Monterey
Turns
Monterey
Turris
Turns
Monterey
PRB
Monterey
PRB
Turns
PRB
Turns
PRB
Monterey
PRB
_Monterey
Turns
Turns
PRB
Dallman 33
Turns
Turns
Turns
Turns
Turns
Turns
PRB
Turns
PRB
Turris
PRB
PRB/Turris
PRB
Off-site Storage
No
No
No
No
No
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
FGD System
D
allman 31 & 32
Add
Add
D allman 33
On
On
On
On
On
On
Off
On
Off
On
On
On
On
P o tential
Unit Modifications
N
o
ne
Add
limestone
feed system
(LS 7&8)
Add
limestone
feed
system
(LS 7&8)
Add
limestone
feed system
(LS
7&8)
(Dallman
31/32
Add
limestone
feed system
(Dallman
31/32)
None
Add
limestone
feed system
(LS 7&8)
+
Mod. 1 & 2
Add
limestone
feed
system
(LS 7&8)
+
Mod.
1
M
odification
12
(DaIII&man
31/32,33)
M
o
dification
1 (Dallman
31/32)
Add
limestone
f eed system
(LS 7&8)
+
Mod. 1 & 2
Add
limestone
f
eed system
(LS 7&8)
+
Mod. 2
Modification
1
&
2
( Dallman
Units
31/32,
33)
M USTS
M aintain space
for NOx
controls to be added at a later
d
YES
YES
YES
YES
YES
YES
YES
YES
YES
YES
YES
YES
YES
WANTS
Wgt Score
W t'd
Score
S core
W t'd
Score
S core
W t'd
Score
S core
W t'd
Score
S
core
W t'd
Score
Score
Wfd
Score
Score
W t'd
Score
S
core
Wt'd
Score
S core
W t'd
Score
Score
W
t'd
Score
Score
W t'd
Score
S core
W
fd
Score
S
core
W
fd
Score
Minimize
reliance on S02
allowance
market
4 0
9 360 10 400 3 120 5 200 4
160 2 80
8 320 7
280 7 280
9 360 10 400 6
240 8 320
Minimize
coal
handling
problems
20
10
200 9 180 9 180 7 140 11
8
11
1 60 10 200 2
40
3
60
2
40
4
80
2
40
4
80
2
40
Ease of operation
7
9
63
8
56
9 63
6
42
6 42 10 70
4
28
2
14
5
35
4 28
3
21
2
14
4
28
R eduction of air toxics to aid
in meeting future regulatory
requirements.
1
10
10
10 10
5
55
5
5
5
5
5
0
0
5 5
0 0 55
5 5 5
5
5
5
Minimize congestion on the
plant
site
1
5
5
4
4
6
65
5
6
6
7
78
8
4
4
1
0
1 0
5
5
7
7
3
3
9 9
M inimize
vehicle traffic
1
8
8
8
8
9
9
9
9
9
9
10 10
7
76
6
7
76
6
55
6
65
5
M inimal impact on boiler
reliability
30
9
2 70 7
210 8 240 7 210
8 2 40 1 0 3 00 2
60
5 150
3
90
6 180 1
30
5 150 2
60
TOTAL -WANTS SCORE 100
916
868
623
611
622
672
463
519
462
664
508
498
467
kttbiRA.xls
10/6/98
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
TABLE V-1a
FINAL K-T ANALYSIS MATRIX
OPTIONS
1
2
3
4
5
6
7
8
9
10
11
13
14
C oal
Lakeside Units
Dallman 31 & 32
Turns
Turris
M onterey
Turns
Monterey
Turns
Monterey
Monterey
Tunis
Monterey
Turns
Turns
Monterey
PRB
Monterey
PRB
Turns
PRB
Turns
PRB
Monterey
PRB
Monterey
Turns
Turns
PRB
Dallman 33
Turns
Turris
Turns
Tunis
Turns
Turns
PRB
Turris
PRB
Turns
PRB
PRB/Turns
PRB
Off-site Storage
No
No
No
No
No
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
FGD System
Dallman 31 & 32
Add
Add
Dallman 33
On
On
On
On
On
On
Off
On
Off
On
On
On
On
P otential
Unit
Modifications
(see attached
table for
description of
Mod. 1 & 2)
N
one
A dd
limestone
feed
system
(LS 7&8)
Add
limestone
feed
system
(LS 7&8)
Add
limestone
feed
system
(LS 7&B)
(Dallman
1/3
Add
limestone
feed
system
(Dallman
31/32)
N one
A dd
limestone
feed
system
(LS 7&8)
+
Mod. 1
&
2
A dd
limestone
feed
system
(LS 7&8)
+
Mod. 1
Modification
1&2
(
Dallman
31/32, 33)
Modification
1 (Dallman
3 1/32)
Add
limestone
feed
system
( LS
7&8)
+
Mod. 1 & 2
Add
limestone
feed system
(LS 7&8)
+
Mod. 2
M odification
1 & 2
(Dallman
U nits 31/32,
33)
M USTS
=#
M aintain space for NOx controls
to be added
at a later date
YES
YES
YES
YES
YES
YES
YES
YES
YES
YES
YES
YES
YES
WANTS
Wgt Score
W Cd
Score
S
core
Wt'd
Score
Score
Wt'd
Score
Score
Wt'd
Score
Score
W
t'd
Score
Score
W t'd
Score
S
core
Wt'd
Score
S
core
Wt'd
Score
Score
Score
W t'd
Score
S
core
Wt'd
Score
S core
W
t'd
Score
Score
W t'd
Score
r
Minimize reliance on S02
allowance market`
4 0
8 320 10 400 2
80
8 320 6 240
0
0
9 360 9 360 7 2
8
7 280 10 400
3 120 8 320
Minimize
coal
handling
problems
20 10 200 9 180 9 180 7 140 8 160 10
200 2
40 3
60 2
40
4
80 2
40 4
80 2
40
E ase of operation
7
9 63 8
56
9 63 6
42 6
42 10
70 4
28 2
14
5
35
4
28
3
21
2
14
4
28
R eduction of air toxics to aid in
meeting future regulatory
requirements.
1
1 0 10 1 0
10
5
5
5
5
5
5
5
5
0
0
5
50
0
5
5
5
55
5
5
5
M inimize congestion on the
plant
site
1
5
5
4
4
6
6
5
5
6
6
7
7
8
8 4 4 10 10
5 5 7
7
3
3
9
9
M inimize vehicle traffic
1
8
8
8
8
9
9
9
9
99
10
10
7
7
6
6
77
6
6
5
5
66
5
5
M inimal
impact
on
boiler
reliability
TOTAL -WANTS SCORE 106
30
- -
9
876
270
ý
868
210
9
583
240 7 2
731
10 8
702
2 40 1 0 300
592
2
503
80
5
599
1
50 3
462
90 8 1
584
80 1
508
30 5
378
150 2
467
60
'Revised based on calculated allowance purchase requirements
kttablef.xls
10/6/98
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
TABLE V-2
UNIT
MODIFICATION REFERENCE
SHEET
Concern
If
General
Description of Coneem
Potential
Modification
Modification
1
Modification 2
Dallman
31132
Dallman 33
1 FD Fen Capacity
or Head Increase in
moisture decreases boiler
No Change
No Change
e fficiency, Increasing both fuel and air
(1% cap. Incr)
(1% cap. Incr.)
requirement.
Moisture also increases
flue as volume.
2
ID Fan Capacity or Head
Same as FD Fan, plus an additional
rue
No Change
(Unit 33 only)
concern about Increasing
flue gas
(2% cap. Incr.)
temperature with PRB If furnace is not
adequately
cleaned.
3 Coal Feeder Capacity
Any reduction in HHV and/or boiler
Raise leveling bar.
Add electronic
efficiency
will require an increase in
weigh system &
coal feed rate.
raise leveling
bar.
4 Coal Mill
Capacity
Same basis as Coal
feeder.
Ma
No Change
Unit 33 onl
3 mfs nor MCR
5 Exhauster Capacity
Same basis as coal Coal
Feeder. In
n/a
No Change
or Head
addition,
PRB coal requires higher
(3
mgls for MCR-
(Unit 33 only)
PA/Fuel
ratio, increasing both capacity
3 for Opt 13)
and head
re uirements.
M axhead incr. of 24%.
8 Coal Pipe Size
The increase in PA flow (See Exhausters
n/a
No Change
(Unit 33
only)
increases coal pipe velocity.
( uelocityIncreases
Normally t for a maximum of 5000f m.
to 55801 m.
7 Mill meting
PRB
coal requires mill inerting.
n/a
Add mill inerting.
Unit 33 onl
8 Mill Wash Nozzles
FIRS coal requires mill washing
on
n/a
Add mill wash
Unit 33 only)
shutdown.
nozzles.
9 Cyclone Modifications
PRB coal in a cyclone requires certain
Add split dampers,
n/a
(Units 31/32 only)
cyclone modifications
for successful
alternate (hot) PA
firing.
source, & modulate
PA volume damper.
1 0 Cyclone
Slag Fluxing Age Monterey coal requires
the addition of
No Change
n/a
Units 7/8 & 31/32
only)
limestone
as a fluxing silent in 31/32.
11 Bunker Inerling
PRB
met requires bunker inerting.
Add bunker inerting.
Add bunker inerting.
12 Furnace Cleaning
PRB coal requires watedances to clean
-Add watedences &
Add wat ed a nces &
f umacewalerwalls.
um skid.
um skid.
1 3 Ash
Handling System
PRB coal ash solidifies when
m oistened
'
Overdilute with
Overdilute with
jWet conveying systems require special
water when pulling
water when pulling
E
a
h. Scourwith
ash. Scourwith
:L
bottom ash often.
bottom ash often.
unsmodaAs
Revision 2
Page I
tw5W
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
Table V-3
Adjustment
of K-T Analysis
Scores
for Reliance
on S02 Allowance
Market
Option Allowance
Normalized
Scaled "Best =
10" Rounded
Score from
Purchase
Basis
Score 9/22/98
Meeting
1
4963
7596
1.91
8.09
8
9
2
-2422
211 0.05
9.95
10
10
3
29690
32323
8.14
1.86
2
3
4
7089
9722
2.45
7.55
8
5
5
14474
17107
4.31
5.69
6
4
6
37076
39709
10.00
0.00
0
2
7
3283
5916
1.49
8.51
9
8
8
1030
3663
0.92
9.08
9
7
9
10668
13301 3.35
6.65
7
7
10
8415
11048
2.78
7.22
7
9
11
-2632
1 0.00
10.00
10
10
13
26921
29554
7.44
2.56
3
6
14
4753
7386
1.86
8.14
8
8
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
APPENDIX C
DALLMAN
UNIT 33 SOz REMOVAL IMPROVEMENTS
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
APPENDIX C
DALLMAN UNIT 33
SO,
REMOVAL IMPROVEMENTS
The basis for this study is
the assumption that the Dallman Unit 33 FGD system
can consistently achieve
90% S02 removal efficiency. However, it is desirable
to obtain higher removal efficiency after the
onset
of Phase l[ on January 1, 2000. This appendix briefly
addresses the alternatives for increasing the
removal efficiency performance
to 95%.
Options Available
There are
several
principal
means of improving the removal efficiency
of a wet limestone FGD system:
1. Increase the gas flow
through the absorber (decrease the percent bypass)
2. Increase the liquid flow
to the absorber (upgrade or add pumps) to increase the L/G ratio
3. Increase
the gas/liquid contact by modifying the spray headers
and/or the trays
4. Increase the liquid phase
alkalinity by raising the operating pH or by adding organic acid.
Considerations for Dallman
Unit 33
I mplementation of any of the first
three alternatives listed above would result in an increase
in the
pressure drop across the absorber
towers. Review of data from recent FGD operator log sheets indicates
that the booster fans typically operate up to their
maximum capability at full load conditions. The
indicated position
of the fan inlet dampers commonly reaches 99 to 100%
on a typical day. This
indicates that the fans
or motors would need to be modified to handle the
increased power demand that
would occur under the higher
LP
operation.
Review of the booster fan curves and the fan
motor data indicates that the fans are designed for two
speed operation
but are now fitted with single speed motors operating
at the "low" design speed for the
fan. The cost to change out the motors
to ones capable of the higher speed, higher power operation
is
estimated to be $120,000 per fan,
or
$240,000
total. This capital cost would be accompanied
by a
constant
higher power consumption due to the increased absorber OP.
For about half this capital cost,
and
with
no accompanying LP increase, an organic acid
addition system
could be added to enhance the liquid phase alkalinity and easily
achieve 95% removal efficiency. The
additive could be used only when needed. Experience at other FGD systems
producing wallboard grade
gypsum
shows that the additive usage is compatible with this application.
Acceptance of this technique
for efficiency enhancement
by the utility industry and the gypsum wallboard industry leads Bums
&
McDonnell to recommend it as
the preferred alternative for use at Dallman Unit 33.
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
APPENDIX D
OFFSITE PRB COAL UNLOADING AND
STORAGE OPTIONS
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
PRB
UNIT
OPTIONS
DESCRIPTION
Pawnee Transportation
Clear site
Prepare pile base
Runoff collection
system
Treatment bldg & equip.
Runoff
pond
Improve access
road
Improve site security
TOTAL
33
IJ
Curran
Site
Site
prep
Rail loop
Rotary dumper
Coal storage silos
Truck
loadoutpackages
3
Truck scale
Access roads
Office/break building
Tools/machinery
uostanontswncngear,
MCC, utilities
(Pawnee cost items)
TOTAL
Dallman Storage
Clear site
Prepare pile base
Runoff collection system
Treatment bldg & equip.
Runoff
pond
Improve access road
Improve site security
Site prep
New rail sidings
Rotary dumper unloader
Switch engine
TOTAL
coalhdRB.xls
0
(Clear site for s
system,
trealrL
J
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
COST ESTIMATE
PRB
Coal Storage Alternatives
Options 7,8,9,10,11,13,14
DALLMAN
LAKESIDE
TOTAL
UNIT
33
32
31
8
7
OPTIONS 7,9,11,13,14
7,8,9,10,11,14
NON E
DESCRIPTION
Pawnee Transportation
Clear site
$100,000
Prepare pile base
$100,000
Runoff collection
system
$10,000
Treatment bldg & equip.
$50,000
Runoff pond
$20,000
Improve access road
- $ 0
Improve site security
$0
TOTAL
$280,000
Curran Site
rope 0acre -
$5000/acre
$450,000
Site prep
$220,000
Rail loop
$ 1,700;000
Rotary dumper
$10,000,000
Coal storage silos
$3,500,000
Truck loadout packages 3
$300,000
Truck scale
$120,000
Access roads
$50,000
Office/break building
$150,000
Tools/machinery
$50,000
u s on swi c gear,
MCC, utilities
$200,000
(Pawnee cost items)
(Clear site for truck loading, prepare
coal pile base, runoff collection
$280,000
system, treatment bldg, runoff pond)
TOTAL
$17,020,000
Dallman Storage
Clear site
$100,000
Prepare pile base
$100,000
Runoff collection system
$10,000
Treatment bldg & equip.
$50,000
Runoff pond
$20,000
Improve access road
$30,000
Improve site security
$60,000
Site prep
$100,000
New rail sidings
$800,000
Rotary dumper unloader
$10,000,000
Switch engine
$400,000
TOTAL
I
$11,670,000
coalhdRB.xls
Page 1 of 1
10/04/98
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
APPENDIX E
COST ESTIMATES
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
f
.,
S
`ire
kvp
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
MA
am
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
FGD System Cost Estimate
Dallman
Units 31 & 32
T OTAL INSTALLED
Ite-
-
COST (1998$)
1 . Absorber Module
3 17LMN Shell
$1,840,500
Inlet Nozzles (C27B)
$215,250
Mist Eliminators (FRP)
$209,500
M.E. Spray Headers (317LMN)
$135,000
Recycle Spray Headers (317LMN)
$350,300
Foundations
$77,900
2 .
Absorber Outlet Elbows (GS.)
$189,000
3. Absorber Outlet Elbows & Ducts (C27B Wallpaper)
$505,000
4. AbsorberAghators
$307,000
5. Pumps
R
eagent
Feed Pumps
$32,000
Recycle
Pumps
$1,200,000
Slurry Bleed Pumps
$24,000
By-product
Transfer pumps
$54,000
Return
Water Pumps
$28,000
Mist Eliminator Wash Pumps
$32,000
Absorber Area
Sump Pumps
$72,000
8. Tanks
M.E. Wash
Tank
$38,000
By-product
Transfer Tank
$40,000
7. Recycle Pump Suction Valves
$282,500
8. Vertical Agitators
$28,000
9. Piping
R eagent Feed Piping (FRP)
$130,000
Recycle Piping (FRP)
$800,000
Slurry Bleed Piping (FRP)
$30,000
M ist Eliminator Wash Piping (FRP)
$15,000
B y-product Transfer Piping (FRP)
$85,000
Return
Water Piping (FRP)
$75,000
Sump Pump Piping (FRP)
$25,000
Compressed Air Piping (C.S.)
$75,000
Fire Protection Water Piping
$80,000
Oxidation Air Piping
$185,000
10. Valves for Above Systems
$375,000
11. By-product Hydroclones
$80,000
1 2. Booster Fans
$1,000,000
F en foundations
1 3. Oxidation Air Compressors
14. Elevator
1 5. Instruments & Controls
18. Electrical (10%)
1 7. Civil
1 8. Chimney
E
xisting stack
liner lining
Column modIAcadons
19.
Absorber building
Building foundations
20. Ductwork
Foundations
Demolition of existing
21. Dampers
22. Pipe rack to 33 FGD system
2 3. Ball Mill w/ball charge, Weigh feeder
E ngineering (S%)
Contingency (20%)
$ 42,000
$330,000
$100,000
$1,000,000
$1,800,000
$500,000
$ 1,975,000
$100,000
$850,000
$278,500
$1,228,900
$150,800
$183,900
$540,000
$ 227,700
$ 1,387,500
TOTAL
$19,071,250
$ 1,525,700
$3,814,250
GRAND
TOTAL
$24,411,200
fgdCOST.XLS
$/KW
$103
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
COST ESTIMATE
SUMMARY
Unit
Modifications
UNIT
TOTAL
OPTION 1
Dallman
33
$0
Dallman 32
$0
Dallman 31
$0
Lakeside 8
$0
Lakeside 7
$0
OPTION 2
Dallman 33
$0
Dallman 32
$0
Dallman
31
$0
Lakeside 8
$0
Lakeside 7
$0
OPTION 3
Dallman 33
$0
Dallman 32
$0
Dallman 31
$0
Lakeside 8
$0
Lakeside 7
$0
OPTION 4
Dallman 33
$0
Dallman 32
$0
Dallman 31
$0
Lakeside
8
$0
Lakeside
7
$0
OPTION
5
Dallman 33
$0
Dallman
32
$0
Dallman
31
$0
Lakeside
8
$0
Lakeside 7
$0
OPTION 6
Dallman 33
$0
Dallman 32
$0
Dallman 31
$0
Lakeside 8
$0
Lakeside
7
$0
OPTION 7
Dallman 33
$410,000
Dallman 32
$365,000
Dallman 31
$365,000
Lakeside
8
$0
Lakeside 7
$0
unitmRA.xls
Page 1 oft
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
COST ESTIMATE SUMMARY
U nit Modifications
UNIT
TOTAL
OPTION 8
Dallman 33
$0
Dallman 32
$365,000
Dallman 31
$365,000
Lakeside 8
$0
Lakeside 7
$0
OPTION 9
Dallman 33
$410,000
Dallman 32
$365,000
Dallman 31
$365,000
Lakeside
8
$0
Lakeside 7
$0
OPTION 10
Dallman 33
$0
Dallman 32
$365,000
Dallman 31
$365,000
Lakeside 8
$0
Lakeside 7
$0
OPTION 11
Dallman 33
$410,000
Dallman 32
$365,000
Dallman 31
$365,000
Lakeside 8
$0
Lakeside
7
$0
OPTION 13
Dallman 33
$410,000
Dallman
32
$0
Dallman 31
$0
Lakeside 8
$0
Lakeside 7
$0
OPTION 14
Dallman 33
$410,000
Dallman 32
$365,000
Dallman 31
$365,000
Lakeside 8
$0
Lakeside 7
$0
unitooRA.xls
Page 2 of 2
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
COST ESTIMATE
UNIT
MODIFICATIONS
Options 7,8,9,10,11,13,14
DALLMAN
LAKESIDE
TOTAL
UNIT
33
32
31
8
+-T-
OPTIONS
7,9,11,13,14
7,8,9,10,11,14
NONE
DESCRIPTION
MOD 2
MOD 1
MOD 1
Modification 1
Raise coal feeder leveling bar
$15,000
$15,000
$30,000
Cyclone
Split dampers
$5,000
$5,000
$10,000
Alternate (hot) PA source
$25,000
$25,000
$50,000
Modulating PA volume damper
$20,000
$20,000
$40,000
Add coal bunker inerting
$100,000
$100,000
$200,000
Furnace - add waterlances and pump
skid
$200,000
$200,000
$400,000
Modification 2
Add electronic coal feeder weigh
system & raise feeder leveling bar
$80,000
$80,00 0
Upgrade exhausters (4)
$60,000
_ _
Add mill inerting
$200,000
$200,000
Add mill wash nozzles
$70,000
$70,T66-
Add coal bunker inerting
$240,000
$240,000
Furnace - add walerlances and pump
skid
$800,000
$800,000
$0
$0
$0
TOTALS $410,000
$365,000
$365,000
$1,080,000
Option
7,9,11,14
8,10
13
Dallman 33
$410,000
$0
$410,000
Dallman 32
$365,000
$365,000
$0
Dellman 31
$365,000
$365,000
$0
Lakeside 8
$0
$0
$0
Lakeside
7
$0
$0
$0
10/4/98
unitmRA.xls
Page
1 of 1
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
COST
ESTIMATE SUMMARY
Coal
Handling Modifications
UNIT
I
I
LAddltlone
plies;
Handling
U grade
Storage
TOTAL
OPTION 1
Dallman 33
$0
Dallman 32
$0
Dallman 31
$0
Lakeside 8
$0
Lakeside 7
$0
OPTION 2
Dallman 33
$0
$0
Dallman 32
$0
$0
Dallman 31
$0
$0
Lakeside 8
$46,500
$46,500
Lakeside 7
$46,500
$46,500
OPTION
3
Dallman 33
$0
$0
Dallman 32
$0
$0
Dallman 31
$0
$0
Lakeside
8
$46,500
$46,500
Lakeside
7
$46,500
$46,500
OPTION 4
Dallman 33
$0
$2,550,000
$2,550,000
Dallman 32
$46,500
$1,275,000
$1,321,500
Dallman 31
$46,500
$1,275,000
$1,321,500
Lakeside
8
$61,000
$0
$61,000
Lakeside 7
$61,000
$0
$61,000
OPTION 5
Dallman
33
$0
$2,550,000
$2,550,000
Dallman 32
$46,500
$1,275,000
$1,321,500
Dallman 31
$46,500
$1,275,000
$1,321,500
Lakeside 8
$0
$0
$0
Lakeside 7
$0
$0
$0
OPTION 6
Dallman
33
$0
Dallman 32
$0
Dallman 31
$0
Lakeside 8
$0
Lakeside 7
$0
OPTION 7
Dallman 33
$0
$1,116,500
$0
$2,965,531
$4,082,031
Dallman 32
$0
$558,250
$120,000
$1,210,020
$1,888,270
Dallman31
$0
$558,250
$120,000
$1,224,119
$1,902,369
10/04/98
coalhdRB.xls
Page 1 of 2
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
COST ESTIMATE SUMMARY
Coal Handling Modifications
UNIT
TOTAL
I
LAdditlone
Plies
al
Handling'
U
p_$ade
Storage
Lakeside 8
$46,500
$ 0
$0
$0
$46,500
L akeside 7
$46,500
$0
$0
$0
$46,500
OPTION 8
Dallman
33
$0
$2,550,000
$0
$0
$0
$2,550,000
Dallman
32
$0
$1,275,000
$1,116,500
$120,000 $1,256,687
$3,768,187
Dallman
31
$0
$1,275,000 $1,116,500
$120,000
$1,270,785
$3,782,285
Lakeside
8
$46,500
$0
$0
$0
$0
$46,500
Lakeside
7
$46,500
$0
$0
$0
$0
$46,500
OPTION
9
Dallman 33
$1,116,500
$0
$2,965,531
$4,082,031
Dallman 32
$558,250
$120,000 $1,210,020
$1,888,270
Dallman 31
$558,250
$120,000 $1,224,119
$1,902,369
Lakeside 8
$0
$0
$0
$0
Lakeside 7
$0
$0
$0
$0
OPTION 10
Dallman 33
$2,550,000
$0
$0
$0
$2,550,000
Dallman 32
$1,275,000
$1,116,500
$120,000 $1,256,687
$3,768,187
Dallman 31
$1,275,000
$1,116,500
$120,000
$1,270,785
$3,782,285
Lakeside 8
$0
$0
$0
$0
$0
Lakeside 7
$0
$0
$0
$0
$0
OPTION
11
Dallman 33
$0
$1,116,500
$0
$2,965,531
$4,082,031
Dallman 32
$0
$558,250
$120,000 $1,210,020
$1,888,270
Dallman31
$0
$558,250
$120,000 $1,224,119
$1,902,369
Lakeside 8
$46,500
$0
$0
$0
$46,500
Lakeside 7
$46,500
$0
$0
$0
$46,500
OPTION 13
Dallman 33
$0
$2,550,000
$2,233,000
$2,577,758
$7,360,758
Dallman 32
$0
$1,275,000
$0
$0
$1,275,000
Dallman 31
$0
$1,275,000
$0
$0
$1,275,000
Lakeside 8
$46,500
$0
$0
$0
$46,500
Lakeside 7
$46,500
$0
$0
$0
$46,500
OPTION 14
Dallman 33
$1,116,500
$0
$2,965,531
$4,082,031
Dallman 32
$558,250
$120,000 $1,210,020
$1,888,270
Dallman31
$558,250
$120,000 $1,224,119
$1,902,369
Lakeside 8
$0
$0
$0
$0
Lakeside 7
$0
$0
$0
$0
10/04/98
coalhdRB.xls
Page 2 of 2
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
COST
ESTIMATE
LIMESTONE ADDITION
SYSTEM
Options 2,3,5,7,8,11,13
DALLMAN
LAKESIDE
TOTAL
UNIT
33
32
31
8
-77
7
OPTIONS
NONE
5
2,3,7 ,8, 11,13
DESCRIPTION
Relocate LS silo
$10,500
$10,500
$10,500
$10,500
-
$21,000
Silo foundation
$5,000
$5,000
$5,000
$5,000
$10,000
Weigh feeder
$13,000
$13,000 $13,000
$13,000
$26,000
Field wiring
$9,000
$9,000
$9,000
$9,000
$18,000
Programming
$3,000
$3,000
$3,000
$3,000
$6,000
Misc.chutes
$4,000
$4,000
$4,000
$4,000
$6,000
Civil work - truck
access
$2,000
$2,000
$2,000
$2,000
$4,000
TOTALS
$0
$46,500
$46,500 $46,500
$46,500
$93,000
Option
5
2,3,7,8,11,13
Dallman 33
$0
$0
Dallman 32
$46,500
$0
Dallman 31
$46,500
$0
Lakeside 8
$0
$46,500
Lakeside 7
$0
- $46,500
N ote: Cost estimates on this table ere for limestone
addition to either Dallmen 31 8 32 or Lakeside 7 8 8
I
1 0/04/98
CoalhdRB.xls
Page 1 of 1
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
COST ESTIMATE
LIMESTONE
ADDITION SYSTEM
Option
4
DALLMAN
LAKESIDE
TOTAL
UNIT
33
32
31
S
7
--
OPTIONS
NONE
4
4
-
DESCRIPTION
TiTi
-
Relocate
LS silo
$10,500
$10,500
$21,000
Silo foundation
$5,000
$5,000
$10,000
Weigh feeder
$13,000
$13,000
$26,000
Field wiring
$9,000
$9,000
$18,000
Programming
$3,000
$3,000
$6,000
Misc. chutes
$4,000
$4,000
$8,000
Civil work - truck
access
$2,000
$2,000
$4,000
Add new
silo
(erected) for
Lakeside
$30,000
$30,000
$60,000
Field wiring (LS)
$9,000
$9,000
$18,000
Programing (LS)
$3,000
$3,000
$6,000
Misc. Chutes
$4,000
$4,000
$8,000
Civil
$2,000
$2,000
$4,000
New
weigh feeder
$13,000
$13,000
$26,000
TOTALS
$46,500 $46,500
$61,000
$61,000
$215,000
Dallman 33
$0
Dallman 32
$46,500
Dallman 31
$46,500
Lakeside 8
$61,000
Lakeside 7
$61,000
I
(Note: Cost
estimates on this table are for limestone addition to both Dallman Units 31 332 and
I
Lakeside
Units 7 d e
1 0/04/98
coalhdRB.xls
Page 1 of 1
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
COST ESTIMATE
Two Coal Piles
Options 4,5,8,10,13
DALLMAN
LAKESIDE
TOTAL
UNIT
33
32
31
8
7
OPTIONS
4,
5, 8, 10, 13
NONE
Cost
Split
50%
25%
25%
DESCRIPTION
Truck Hopper
Foundation
ITunnel
$200,000
$100,000
$100,000
$400,000
Platework/Steel
$40,000
$20,000
$20,000
$80,000
Feeders (2)
$20,000
$10,000
$10,000
$40,000
Building
$40,000
$20,000
$20,000
$80,000
Dust Collection
$160,000
$80,000
$80,000
$320,000
Sump Pumps
$7,500
$3,750
1 1
$ 3,750
$15,000
Unloading
conveyor
$100,000
$50,000
$50,000
- $200,000
Transfer
Tower #1
$60,000
$30,000
$30,000
$120,000
New driveway for
unloading hopper
$50,000
$25,000
$25,000
$100,000
Dust Collection (off
Transfer House (3)
$150,000
$75,000
$75,000
$300,000
StockoutConveyor
wttelechute
$437,500
$218,750
$218,750
$875,000
Wet suppression system
$60,000
$30,000
$30,000
$120,000
ec a m Hopper
Foundation&Tunnel
$250,000
$125,000
$125,000
$500,000
Platework/Steel
$40,000
$20,000
$20,000
$80,000
Feeders
(2)
$20,000
$10,000
$10,000
$40,000
Dust collection system
$100,000
$50,000
$50,000
$200,000
Sump pumps
$7,500
$3,750
$3,750
$15,000
Reclaim
conveyor
no.1
$112,500
$56,250
$56,250
$225,000
Outside Reclaim Hopper
Foundation &Tunnel
$75,000
$37,500
$37,500
$150,000
Platework/Steel
$20,000
$10,000
$10,000
$40,000
Feeder
$10,000
$5,000
$5,000
$20,000
Dust collection
(ductwork)
$2,500
$1,250
$1,250
$5,000
Sump pumps
$7,500
$3,750
$3,750
$15,000
Reclaim conveyor
no.2
$40,000
$20,000
$20,000
$80,000
Transfer tower
no.2
$60,000 - $30,000
$30,000
$120,000
Relaim conveyor no. 3
$150,000
$75,000 - - $75,000
-
-$300,000
Transfer tower no.3
$75,000
$37,500
$37,500
$150,000
Radial stacker
$75,000
$37,500
$37,500
$150,000
10/04/98
coalhdRB.xls
Page 1 of 2
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
COST ESTIMATE
Two Coal Piles
Options
4,5,8,10,13
Misc.chute work
$40,000
$20,000
$20,000
$80,000,
Field wiring
$125,000
$62,500
$62,500
$250,000
MCC
$15,000
$7,500
$7,500
- $30,000
TOTALS $2,550,000
$1,275,000 $1,275,000
$0
$0
$5,100,000
Dallman
33
$2,550,000
Dallman 32
$1,275,000
I)allman
31
$1,275,000
Lakeside 8
-
$0
Lakeside
7
$0
10/04/98
coa1hdRB.xls
Page 2 of 2
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
COST ESTIMATE
PRB Coal Handling - Dallman
DALLMAN
LAKESIDE
TOTAL
UNIT
33
32
31
8
7
OPTIONS
7, 8, 9, 10, 11, 13 , 1 4
N ONE
Cost
Split (for3 unit
cases 50%
25%
25%
DESCRIPTION
Dust Control Upgrade -
Existin coal hdlg
sys
collection
$160,000
$80,000
$80,000
$320,000
Yard
reclaim hopper
dust
collection
$132,500
$66,250
$66,250
$265,000
Crusher house dust
collection
$212,500
$106,250
$106,250
$425,000
Tripper bay dust
collection
$225,000
$112,500
$112,500
$450,000
Wet suppression for
stockout
$60,000
$30,000
$30,000
$120,000
Foundations
$12,500
$6,250
$6,250
$25,000
Support decks
$20,000
$10,000
$10,000
$40,000
Field Wring
$75,000
$37,500
$37,500
$150,000
Programming
$3,000
$1,500
$1,500
- $6,000
Compressed air piping
$6,000
$3,000
$3,000
$12,000
MCC
-
$10,000
$5,000
$5,000
M
$ 20,000
Fire protection
connections (5)
$5,000
$2,500
$2,500
$10,000
Truck hopper enclosure I
1
F oundations
$20,000
$10,000
$10,000
$40,000
Structural steel / siding
$100,000
$50,000
$50,000
$200,000
Mlac
conveyor system
upgrades
Conveyor leg
replacement
$35,000
$17,500
$17,500
$70,000
Chute replacement
$40,000
$20,000
$20,000
$80,000
TOTALS $1,116,500 $558,250
$558,250
$0
$0
$2,233,000
Option 7, 9, 11, 14
8, 10
13
Dallman
33
$1,116,500
$0
$2,233,000
Dallman32
$558,250
$1,116,500
$0
Dallman31
$558,250
$1,116,500
$0
ýLakeside 8
$0
$0
$0
Lakeside 7
$0
$0
$0
O ptions 7 8 9 10 11 13 14
1 0/04/98
coalhdRB.xls
Page 1 of
1
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
COST ESTIMATE
Crusher
Upgrade -Dallman
Units
3132
Options 7,8,9,10,11,14
DALURAN
LAKESIDE
TOTAL
UNIT
33
32
31
8
77777 1:::
7
i
OPTIONS NONE
7,
8, 9, 10, 11, 14
N ONE
Cost Split
50"/u
50%
DESCRIPTION
Fine grind kits (2)
$120,000
$120,000
$240,000
TOTALS
$0
$120,000
$120,000
$0
$0
$240,000
Option 7-11,14
Dallman
33
$0
Dallman
32
$120,000
Dallman
31
-
$120,000
Lakeside
8
$0
Lakeside 7
$0
10/04/98
coalhdRB.xls
Page 1 of 1
Electronic Filing - Received, Clerk's Office, November 21, 2008
* * * * * PC #1 * * * * *
COST ESTIMATE
Off-site Storage
- PRB Coal
Options 7,8,9,10,11,13,14
DALLMAN
LAKESIDE
TOTAL
UNIT
33
32
31
S
7
N ONE
Coy! Split
33%
33%
33%
DESCRIPTION
Pawnee Transportation
Clear site
$100,000
Prepare pile base
$100,000
Runoff collection system
$10,000
Treatment
bldg & equip.
$50,000
Runoff pond
-
$20,000
Improve
access road
$0
Improve
site security
$0
TOTALS $93,333
$93,333
$93,333
$0
$0
$280,000
Dallman
31 & 32 only
$140,000
$140,000
PRB Coal burned
Tons/yr
Tons/day
60 days coal $/ton
coal 80 pile cost
Dallman 33
822,237
2,253
135,162
$21.25
$2,872,198
Dallman 32
319,679
876
52,550
$21.25
$1,116,887
Dallman
31
323,715
887
53,213
$21.25
$1,130,785
Dallman 33 (80%
blend)
657,790
1,802
108,130
$21.25
$2,297,758
O ption 7, 9, 11, 14
- -- 6,-10 -
13
Dallman 33
$2,965,531
$0
$2,577,758
Dallman
32
$1,210,020 $1,256,687
$0
Dallman
31
$1,224,119 $1,270,785
$0
ýLakeside
8
$0
1
$
0
$0
jtakeside7
$0
$0
$0
Iý
10/04/98
coalhdRB.xls
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Electronic Filing - Received, Clerk's Office, November 21, 2008
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