DAQ-2024-008127

1/23/24, 12:00 PM State of Utah Mail - UMPA RACT Analysis
https://mail.google.com/mail/u/0/?ik=539c285453&view=pt&search=all&permmsgid=msg-f:1785925410297932951&simpl=msg-f:1785925410297932…1/1
Ana Williams <[e-mail]>
UMPA RACT Analysis
Melissa Armer <[e-mail]>Thu, Dec 21, 2023 at 1:39 PM
To: Ana Williams <[e-mail]>
Cc: Sarah Foran <[e-mail]>, "Kevin Garlick ([e-mail])" <[e-mail]>, "[e-mail]"
<[e-mail]>
Ana,
On behalf of UMPA, the attached RACT analysis is being submitted in response to the letter received from UDAQ on 5/31/23. Feel
free to reach out to myself, Kevin Garlick, or Jerame Blevins if you have any questions or require additional information.

Happy Holidays,
Melissa

Melissa Armer, P.E.
Managing Consultant
Trinity Consultants, Inc.
P: 208.472.8837 M: 208.870.3215
New Address: 405 S. 8th St. Ste 331, Boise, ID 83702
Email: [e-mail]

WV Serious Ozone RACT Analysis v1.0.pdf
912K
OZONE SERIOUS NONATTAINMENT SIP
RACT Analysis

Utah Municipal Power Agency

Prepared By:

405 S. 8th St. Ste 331
Boise, ID 83702
208-472-8837

December 21, 2023

Project 231301.0057

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TABLE OF CONTENTS
1. EXECUTIVE SUMMARY 1-1
2. INTRODUCTION 2-1
2.1 Description of Facility ............................................................................................... 2-1
2.2 Emission Profile ........................................................................................................ 2-2
3. REASONABLY AVAILABLE CONTROL TECHNOLOGIES BACKGROUND 3-1
3.1 RACT Methodology .................................................................................................... 3-1
3.1.1 Step 1 – Identify All Control Technologies .................................................................. 3-2
3.1.2 Step 2 – Eliminate Technically Infeasible Options ....................................................... 3-2
3.1.3 Step 3 – Rank Remaining Control Technologies by Control Effectiveness ...................... 3-2
3.1.4 Step 4 – Evaluate Most Effective Controls and Document Results ................................. 3-2
3.1.5 Step 5 – Select RACT ............................................................................................... 3-3
4. LM6000 PC SPRINT NATURAL GAS TURBINES 4-1
4.1 Turbine NOx Technologies ........................................................................................ 4-1
4.1.1 Turbine NOx Step 1 ................................................................................................. 4-1
4.1.2 Turbine NOx Step 2 ................................................................................................. 4-3
4.1.3 Turbine NOx Step 3 ................................................................................................. 4-3
4.1.4 Turbine NOx Step 4 ................................................................................................. 4-3
4.1.5 Turbine NOx Step 5 ................................................................................................. 4-5
4.2 Turbine VOC Technologies ........................................................................................ 4-5
4.2.1 Turbine VOC Step 1 ................................................................................................. 4-5
4.2.2 Turbine VOC Step 2 ................................................................................................. 4-6
4.2.3 Turbine VOC Steps 3 ............................................................................................... 4-7
4.2.4 Turbine VOC Steps 4 ............................................................................................... 4-7
4.2.5 Turbine VOC Step 5 ................................................................................................. 4-7
5. CONCLUSIONS 5-8
APPENDIX A. COST ANALYSIS REFERENCE A-1
APPENDIX B. COST CALCULATIONS B-1

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1. EXECUTIVE SUMMARY
On August 3, 2018, the U.S. Environmental Protection Agency (EPA) determined that the Northern Wasatch
Front (NWF) nonattainment area would be designated as marginal nonattainment for the 2015 8-hour ozone
National Ambient Air Quality Standard (NAAQS). The NWF nonattainment area did not achieve attainment
by the ozone standard’s attainment date on August 3, 2021. Therefore, the EPA reclassified the NWF
attainment area to moderate nonattainment on November 7, 2022. Northern Wasatch Front NAA is
required to attain the ozone standard by August 3, 2024 for moderate classification based on data from
2021, 2022, and 2023. Recent monitoring data indicates the Northern Wasatch Front NAA will not attain the
standard and will be reclassified to serious status in February of 2025.

This anticipated reclassification from moderate to serious status will trigger new control strategy
requirements for major sources in the Northern Wasatch Front NAA. Specifically, the Ozone Implementation
Rule in 83 FR 62998 requires the State Implementation Plan (SIP) to include Reasonably Available Control
Technologies (RACT) for all major stationary sources in nonattainment areas classified as moderate or
higher. The requirements for RACT in a serious ozone nonattainment area are found in Clean Air Act (CAA)
Section 182(c). A major stationary source in a serious ozone nonattainment area is defined as any
stationary source that emits or has the potential to emit 50 tons per year or more of nitrogen oxides (NOx)
or volatile organic compounds (VOCs).

The UMPA West Valley Power Plant (West Valley) has the potential to emit more than 100 tons or more per
year of NOx, thus the facility is considered a major source.1

On May 31, 2023, the Utah Division of Air Quality (UDAQ) sent a letter to Utah Municipal Power Agency
(UMPA) with the option to submit either a RACT analysis for emission units at West Valley or, submit a
Notice of Intent (NOI) application to lower the potential to emit from the facility to below 50 tons per year
of NOx and VOCs. West Valley is choosing to submit a RACT analysis.

Based on further information provided by UDAQ, the following elements have been requested for the RACT
analysis:

► A list of each of the NOx and VOC emission units at the facility;
► A physical description of each emission unit, including its operating characteristics;
► Estimates of the potential and actual NOx and VOC emission rate from each affected source and
associated supporting documentation;
► The proposed alternative NOx and/or VOC RACT requirement or emission limitation (as applicable);
► Supporting documentation for the technical and economic consideration for each affected emission unit;
and
► A schedule for completing implementation of the RACT requirement or RACT emissions limitation (as
applicable) by May of 2026, including start and completion of project and schedule for initial compliance
testing.

Per UDAQ’s request, West Valley submitted this RACT analysis no later than January 2, 2024.

1 The major source threshold was lowered to 70 tpy with the implementation of the PM2.5 Serious Nonattainment SIP

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2. INTRODUCTION
2.1 Description of Facility
The UMPA West Valley Power Plant (West Valley) is a natural gas-fired electric generating plant consisting of
five General Electric LM6000 PC SPRINT natural gas simple cycle turbines. Each turbine has a power output
rated at 43.4 MW and is equipped with water injection, evaporative spray mist inlet air cooling, Selective
Catalytic Reduction (SCR) catalyst, and CO oxidation catalyst. The primary purpose of the plant is to
produce electricity for sale via the utility power distribution system to meet the demands of the Salt Lake
Valley service area.

The plant is located in Salt Lake County and is a Phase II Acid Rain source and a major source of NOx and
CO. All correspondence regarding this submission should be addressed to:

Mr. Kevin Garlick
UMPA SVP Generation
Utah Municipal Power Agency
696 West 100 South
Spanish Fork, UT 84660
Phone: [phone]
Email: [e-mail]

Mr. Jerame Blevins
Plant Manager
UMPA West Valley Power Plant
5935 W 4700 S
West Valley City, UT 84118
Phone: [phone]
Email: [e-mail]

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2.2 Emission Profile
The facility’s Title V Operating Permit number is #3500527004 and was last renewed on July 12, 2019. The
West Valley facility has established the following Potential to Emit (PTE) profile. A full explanation of
calculation methods and inputs can be found within the permitting files.
Table 2-1 West Valley Potential to Emit
Unit Group Potential Annual Emissions Estimate (tpy)
NOx VOC Individual Turbines 32.41 3.67 Total Facility Wide PTE 162.06 18.33

The facility’s 2017 baseline actual emissions are shown in Table 2-1.
Table 2-2 West Valley 2017 Baseline Actual Emissions
Unit Group Actual Annual Emissions Estimate (tpy)
NOx VOC Total Facility Wide Actual 22.71 1.47

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3. REASONABLY AVAILABLE CONTROL TECHNOLOGIES BACKGROUND
West Valley previously submitted a Best Available Control Measures (BACM) analysis in 2017 to support the
PM2.5 Serious Nonattainment SIP. The 2017 BACM analysis and the facility’s current SIP requirements as
documented in UDAQ’s Serious Non-Attainment SIP have been achieved by the facility. In January 2023,
West Valley submitted a RACT analysis to support the ozone moderate nonattainment SIP. An updated
RACT analysis has been conducted for the five natural gas turbines addressed in Title V permit
#3500527004 in the following sections. UMPA has organized the RACT analysis by emission unit group and
addressed NOx and VOC precursor in this analysis in accordance with U.S. EPA’s “top-down” procedures per
UDAQ guidance.2
3.1 RACT Methodology
EPA has defined RACT as follows:
The lowest emission limitation that a particular source is capable of meeting by the
application of control technology that is reasonably available considering
technological and economic feasibility.3

RACT for a particular source is determined on a case-by-case basis considering the
technological and economic circumstances of the individual source.4
In EPA’s State Implementation Plans; General Preamble for Proposed Rulemaking on Approval of Plan
Revisions for Nonattainment Areas – Supplement (on Control Techniques Guidelines), they provided a
recommendation to states which says:
…each [Control Technology Guideline] CTG contains recommendations to the States
of what EPA calls the “presumptive norm” for RACT, based on EPA’s current
evaluation of the capabilities and problems general to the industry. Where the
States finds the presumptive norm applicable to an individual source or group of
sources, EPA recommends that the State adopt requirements consistent with the
presumptive norm level in or to include RACT limitations in the SIP.5
UMPA has referenced the published CTG’s as well as Utah Administrative Code (UAC) for Air Quality (R307),
and proposed rules which establish a current presumptive norm specific to the Northern Wasatch Front
Ozone Nonattainment Area. The preamble goes on to state:
…recommended controls are based on capabilities and problems which are general
to the industry; they do not take into account the unique circumstances of each

2 UDAQ Ozone SIP Planning RACT Analysis, provided 1/9/23
3 EPA articulated its definition of RACT in a memorandum from Roger Strelow, Assistant Administrator for Air and Waste
Management, to Regional Administrators, Regions I-X, on Guidance for determining Acceptability of SIP Regulations in Non-
Attainment Areas,” Section 1.a (December 9,1976)
4 Federal Register/Vol. 44. No. 181/Monday, September 17,1979/Proposed Rules – State Implementation Plan; General
Preamble for Proposed Rulemaking on Approval of Plan Revisions for Nonattainment Areas – Supplement (on Control
Techniques Guidelines)
5 IBID

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facility. In many cases appropriate controls would be more or less stringent. States
are urged to judge the feasibility of imposing the recommended control on particular
sources and adjust the controls accordingly.
Guidance provided by UDAQ for this RACT analysis states that this analysis is to be conducted using “top-
down” method.6 In a memorandum dated December 1, 1987, the United States Environmental Protection
Agency (U.S. EPA) detailed its preference for a “top-down” analysis which contains five (5) steps.7 If it can
be shown that the most stringent level of control is technically, environmentally, or economically infeasible
for the unit in question, then the next most stringent level of control is determined and similarly evaluated.
This process continues until the RACT level under consideration cannot be eliminated by any substantial or
unique technical, environmental, or economic objections. Presented below are the five basic steps of a top-
down RACT review as identified by the U.S. EPA.
3.1.1 Step 1 – Identify All Control Technologies
Available control technologies are identified for each emission unit in question. The following methods are
used to identify potential technologies: 1) researching the RACT/BACT/LAER Clearinghouse (RBLC)
database, 2) surveying regulatory agencies, 3) drawing from previous engineering experience, 4) surveying
air pollution control equipment vendors, and/or 5) surveying available literature. Additionally current CTG’s
and UAC for Air Quality (R307), as well as proposed rules, were reviewed to establish a current presumptive
norm specific to the Northern Wasatch Front Ozone Nonattainment Area.
3.1.2 Step 2 – Eliminate Technically Infeasible Options
To ensure the presumptive norm established applies to the emission source in question, a full review of
available control technologies is conducted in the second step of the RACT analysis. In this step, each
technology is reviewed for technical feasibility, and those that are clearly technically infeasible are
eliminated. U.S. EPA states the following with regard to technical feasibility:8
A demonstration of technical infeasibility should be clearly documented and should
show, based on physical, chemical, and engineering principles, that technical
difficulties would preclude the successful use of the control option on the emissions
unit under review.
3.1.3 Step 3 – Rank Remaining Control Technologies by Control Effectiveness
Once technically infeasible options are removed from consideration, the remaining options are ranked based
on their control effectiveness. If there is only one remaining option, or if all remaining technologies could
achieve equivalent control efficiencies, ranking based on control efficiency is not required.
3.1.4 Step 4 – Evaluate Most Effective Controls and Document Results
Beginning with the most effective control option in the ranking, detailed economic, energy, and
environmental impact evaluations are performed. If a control option is determined to be economically
6 UDAQ Ozone SIP Planning RACT Analysis, provided 1/9/23. Email from Sarah Foran UDAQ provided 8/14/23 “we are recommending that you follow the same process you provided in the last submission”. 7 U.S. EPA, Office of Air and Radiation. Memorandum from J.C. Potter to the Regional Administrators. Washington, D.C. December 1, 1987. 8 U.S. EPA, New Source Review Workshop Manual (Draft): Prevention of Significant Deterioration and Nonattainment Area Permitting, October 1990.

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feasible without adverse energy or environmental impacts, it is not necessary to evaluate the remaining
options with lower control effectiveness.

The economic evaluation centers on the cost effectiveness of the control option. Costs of installing and
operating control technologies are estimated and annualized following the methodologies outlined in the
U.S. EPA’s OAQPS Control Cost Manual (CCM) and other industry resources.9 Note that the analysis is not
whether controls are affordable, but whether the expenditure effectively allows the source to meet pre-
established presumptive norms.
3.1.5 Step 5 – Select RACT
In the final step, one pollutant-specific control option is proposed as RACT for each emission unit under
review based on evaluations from the previous step.

9 Office of Air Quality Planning and Standards (OAQPS), EPA Air Pollution Control Cost Manual, Sixth Edition, EPA 452-02-001
(http://www.epa.gov/ttn/catc/products.html#cccinfo), Daniel C. Mussatti & William M. Vatavuk, January 2002.

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4. LM6000 PC SPRINT NATURAL GAS TURBINES
The West Valley Power Plant consists of five GE LM6000 PC SPRINT natural gas simple cycle turbines. Each
turbine has a power output rated at 43.4 MW and is equipped with water injection, evaporative spray mist
inlet air cooling, Selective Catalytic Reduction (SCR) catalyst, and CO oxidation catalyst. Each gas turbine
has a design heat input rate of 404.15 MMBtu/hr at full load operation utilizing the higher heating value of
the natural gas fuel supply. The plant is designed to operate as a peaking facility.

The following sections detail potential controls and operating conditions necessary to achieve the required
emissions for each pollutant. The review will detail controls as they apply to normal operations. Startup and
shutdown operations manage emission rates by minimizing the duration of startup and shutdown.
Therefore, during a startup, West Valley will bring the turbine to the minimum load necessary to achieve
compliance with the applicable NOX emission limits as quickly as possible, consistent with the equipment
manufacturers’ recommendations and safe operating practices. During a shutdown, once the turbine
reaches a load that is below the minimum load necessary to maintain compliance with the applicable NOX
emission limits, reduce the turbine load to zero as quickly as possible, consistent with the equipment
manufacturers’ recommendations and safe operating practices.
4.1 Turbine NOx Technologies
The NOX will be formed during combustion by two major mechanisms: thermal NOX and fuel NOX. Since
natural gas is relatively free of fuel-bound nitrogen, the contribution of this second mechanism to the
formation of NOX emissions in natural gas-fired equipment is minimal and thermal NOX is the chief source of
NOX emissions. Thermal NOX formation is a function of residence time, oxygen level, and flame temperature,
and can be minimized by controlling these elements in the design of the combustion equipment.
The turbines are permitted for an emission rate of 5 ppm NOX at 15% O2 based on a 30 day rolling average
under steady state operation, and 37 pounds per hour (lbs/hr) total emissions of NOx for all five turbines
based on 30 day rolling average.10
4.1.1 Turbine NOx Step 1
Potential control technologies were identified through the review of the following:

► South Coast Air Quality Management District (SCAQMD) LAER/BACT Determinations;
► Bay Area Air Quality Management District (BAAQMD) BACT/TBACT Workbook;
► San Joaquin Valley Air Pollution Control District (SJVAPCD) BACT Clearinghouse;
► EPA’s RBLC Database for Combined Cycle Turbines (16.210);11
► EPA Alternative Control Techniques Document – NOX Emissions from Stationary Gas Turbines; and
► TCEQ BACT Requirements.

To demonstrate a complete analysis, UMPA has evaluated the following technologies for NOX.
A search was conducted by querying all sources within the RBLC database in which the “Process Type Code”
contained the number “15.110” (Large Natural Gas Combustion Turbines > 25 MW). The most closely
related processes were as follows:
10 Title V Operating Permit #3500527004 Condition II.B.2.e and II.B.2.f.
11 RBLC search run on December 15, 2023

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Table 4-11 – NOX Turbine Controls and Emission Rates from RBLC 12
RBLC ID Company/Facilit
y Name
Date
Permit
Issued
Throughput Control Method Emission
Limit
Case-by-
Case TN- 0187 Tennessee Valley Authority 8/31/22 465.8 MMBtu/hr SCR and DLN 5.0 ppm BACT-PSD AK-0088 Alaska Gasoline Development 7/7/22 384 MMBtu/hr SCR, DLN and good combustion 2.0 ppm BACT-PSD LA-0383 Lake Charles LNG 9/3/20 Low NOx burners and SCR 3.1 ppm BACT-PSD LA-0331 Venture Global Calcasieu 9/21/18 263 MMBtu/hr SCR, fuel gas and good combustion 25 ppmv BACT-PSD MI-0426 DTE Gas Company 3/24/17 10,504 Hp Dry ultra-low NOx burners 15 ppm BACT-PSD NJ-0086 Bayonne Energy 8/26/16 2,143,980 MMBtu/hr SCR, water injection, low NOx fuel 2.5 ppm LAER AK-0083 Agrium U.S. 1/6/15 37.6 MMBtu/hr SCR 7 ppm BACT-PSD MI-0410 Consumers Energy Co. 7/25/13 171 MMBtu/hr Dry ultra-low NOx burners 0.09 lb/MMBtu BACT-PSD TX-0685 Guadalupe Power 10/4/13 190 MW Dry ultra-low NOx burners 9 ppm BACT-PSD OK-0153 Semgas LP 3/1/13 9,443 Hp Dry ultra-low NOx burners 15 ppm BACT-PSD
Control technologies included in this table are those that have been shown in practice for use in one of the
previously listed databases. The technologies identified as possible NOX reduction technologies for large
combustion turbines are shown in the table below.
Table 4-22 – NOX Turbine Control Technologies
Pollutant Control Technologies NOX Dry Low NOX Combustors/Low NOX Burner Selective Catalytic Reduction (SCR) Water/Steam Injection Natural Gas Usage and Good Combustion Practices
Control technologies included in this table are those
that have been shown in practice for use in one of the
previously listed databases.

UDAQ has not established state specific emission limits for combined cycle turbines. As a result, the UMPA
proposes the presumptive norm is consistent with NSPS Subpart GG, which establishes NOx emission limits.

12 RBLC search run on December 15, 2023.

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4.1.2 Turbine NOx Step 2
Selective Catalytic Reduction
The most recent NOx BACT listings for simple-cycle combustion turbines in this size range are summarized
in Table 4-1. The most stringent NOx limit in these recent BACT determinations is a 2.0-2.5 ppmvd
averaged over a 1-hour period, excluding startups and shutdowns. This level is achieved using water
injection and/or dry low NOx combustors along with SCR. The existing LM6000 gas turbines located at the
West Valley Power Plant are equipped with water injection, evaporative spray mist inlet air cooling, and SCR
catalyst, and achieved NOx emissions of 5 ppmvd @ 15% O2, which is comparable to the levels for current-
generation water-injected gas turbines with SCR control, but higher than the most stringent limits.

SCR refers to the process in which NOx is reduced by ammonia over a heterogeneous catalyst in the
presence of oxygen. The process is termed selective because ammonia preferentially reacts with NOx rather
than oxygen, although oxygen enhances the reaction and is a necessary component of the process. The
overall reactions can be written:

4NO + 4NH3 + O2  4N2 + 6H2O (Equation 1)
2NO2 + 4NH3 + O2  3N2 + 6H2O (Equation 2)

SCR can be applied as a stand-alone NOX control or with other technologies such as combustion controls.
The SCR process requires a reactor, a catalyst, and an ammonia storage and injection system. The
effectiveness of an SCR system is dependent on a variety of factors, including the inlet NOx concentration,
the exhaust temperature, the ammonia injection rate, and the type of catalyst. According to EPA, the
optimum temperature range over which SCR is effective is dependent on the type of catalyst and the flue
gas composition. In general, the optimum temperature range is between 480 and 800˚F.13 SCR units
typically achieve 70 - 90% NOx reduction.14 However, if the upstream NOX concentration is already low, as
is the case with these units, it is difficult to achieve these control efficiencies.
4.1.3 Turbine NOx Step 3
SCR, in combination with combustion controls, is capable of achieving a NOx emission level of 2.5 ppmvd @
15% O2. It is the remaining control technology that will be evaluated in Step 4.
4.1.4 Turbine NOx Step 4
SCR has been achieved in practice at combustion turbine installations throughout the country. There are
simple-cycle gas turbine projects that limit NOx emissions between 2.5 - 7 ppmvd using SCR technology, as
shown in Table 6-1. An evaluation of the achievement of 2.5 ppmvd in comparison to the current West
Valley turbines NOx level of 5 ppmvd is summarized below.

Feasibility and Cost Impact: NOx emissions from the LM6000 PC SPRINT natural gas turbines are
generally guaranteed at 25 ppmvd. Achieving a controlled NOx limit of 2.5 ppm would require SCR
technology to achieve reductions of 90 percent. UMPA reached out to two vendors to determine the
changes that would be required to the existing SCR systems and the associated costs. Vendors indicated
that each control system is complex and is designed to a specific emission limit. There are numerous factors
that interrelate when evaluating an existing system and determining the modifications necessary to achieve

13 L.M. Campdell, D.K. Stone, and G.S. Shareef, Sourcebook: NOx Control Technology Data, EPA/600/S2-91/029, 1991.
14 OAQPS, EPA Air Pollution Control Cost Manual, Sixth Edition, EPA/424/B-02-001
(http://www.epa.gov/ttn/catc/dir1/c_allchs.pdf); January 2002

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the emissions reductions being evaluated in this analysis. Vendors indicated that a detailed and
comprehensive technical analysis of the existing turbines and existing SCR system would be needed to
definitively determine the changes necessary. However, for this analysis they were able to provide
information on the expected changes that would be required.

It is expected that the required changes will include some combination of catalyst replacement, catalyst
design modification, and ammonia injection/vaporization system re-design to reduce NOx emissions from 5
ppmvd to 2.5 ppmvd.

The vendor who currently services the West Valley turbines is SISU. SISU provided a quote of $578,000 per
turbine, which included the capital costs associated with the installation, startup, and equipment costs of
modifying the existing SCR/oxidation catalyst to achieve a 90% reduction in NOx emissions. Another vendor,
Safety Power America Inc., provided a quote of $830,000 per turbine15 to replace the existing catalyst and
retune the existing ammonia injection grid to achieve 90% reduction in NOx. The range is dependent on the
type and amount of catalyst that may be needed, as well as any redesign that may be necessary for the
existing system. For this analysis, West Valley is using the lower of the two quotes, $578,000.

The annualized costs are outlined in Table 4-4 below. Included in Appendix A is supporting documentation
received from vendors which was used to develop the costs. Table 4-5 below outlines the estimated cost per
ton of pollutant removed to reduce NOx emissions from 5 ppm to 2.5 ppm.

Since the West Valley turbines are peaking units, they do not operate continuously as a base load unit
would operate. Therefore, the annual tons of NOx emissions removed are based on the baseline actual
operating hours from 2017. Table 4-3 summarizes the operating hours per turbine from 2017. The baseline
actual operating hours used in the cost assessment is the maximum operating hours for any of the turbines,
which is 1,217 hours per year per turbine. This results in the most conservative cost estimate.
Table 4-33 – 2017 Actual Operating Hours
Turbine 2017 Actual
(hr/yr)
Turbine 1 821
Turbine 2 1,146
Turbine 3 1,217
Turbine 4 1,157
Turbine 5 965

15 Original quote provided 4/26/2017. Updated quote provided 1/17/2023 and on 10/27/2023 follow-up communication
recommended an additional increase of 10-15% above the estimate provided on 1/17/2023.

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Table 4-44 – SCR Modification Estimated Cost
Cost Per Turbine Cost Per Turbine
Capital cost to replace existing catalyst including installation (DCC) $578,000
Equipment life expectancy a 5 years
Interest Rate b 7%
Capital Recovery Factor c (CRF) 0.2439
Annual Cost d (AC) $140,969
a. Assumed catalyst life of each unit is 5 years based on SISU quote
b. EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and Methodology. Section 2.5.2
c. EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and Methodology, Equation 2.8a
d. EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and Methodology, Equation 2.8
Table 4-55 – SCR Modification Emissions Reduction Cost per Turbine
Current SCR
System
SCR Modification NOx Reduction
(ton/yr)
Annual Cost of SCR
Modification
$ Per Ton NOX
Removed 5 ppm (7.4 lb/hr) 4.50 tpy 2.5 ppm (3.7 lb/hr) 2.25 tpy 2.25 tpy $140,969 $62,653

Conclusion: SCR technology capable of achieving NOx levels of 2.5 ppmvd is considered to be achievable at
the West Valley facility. However, since the West Valley turbines are peaking units and do not operate
continuously, the cost associated with achieving this level of NOx reduction is economically infeasible.
4.1.5 Turbine NOx Step 5
RACT is proposed to be water injection, evaporative spray mist inlet air cooling, and SCR catalyst, and
achieve NOx emissions at 5 ppmvd @ 15% O2, which is comparable to the levels for current-generation
water-injected gas turbines with SCR control, but higher than the most stringent limits.
4.2 Turbine VOC Technologies
4.2.1 Turbine VOC Step 1
UMPA has reviewed the following sources to ensure all available control technologies have been identified:
► EPA’s RBLC Database for Natural Gas External Combustion Units (process type 15.110);16
► EPA’s Air Pollution Technology Fact Sheets;
► SCAQMD LAER/BACT Determinations;
► SJVAPCD BACT Clearinghouse;
► BAAQMD BACT/TBACT Workbook; and
► Permits available online.

A search was conducted by querying all sources within the RBLC database in which the “Process Type Code”
contained the number “15.110” (Large Natural Gas Combustion Turbines > 25 MW). The sources with VOC
limits and most closely related processes were as follows:

16 Database accessed January 25, 2022.

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Table 4-66 – VOC Turbine Controls and Emission Rates from RBLC 17
RBLC ID Company/Facility
Name
Date
Permit
Issued
Throughput Control Method Emission
Limit
Case-by-
Case AK-0088 Alaska Gasoline Development 7/7/22 384 MMBtu/hr Oxidation catalyst and good combustion 2.0 ppm BACT-PSD LA-0331 Venture Global Calcasieu 9/21/18 927 MMBtu/hr Proper Equipment Design and Good Combustion Practices. 1.4 ppmv BACT-PSD
NJ-0086 Bayonne Energy 8/26/16 2,143,980 MMBtu/hr Oxidation catalyst and good combustion 2.0 ppm Other TX-0794 Brazos Electric 4/7/16 171 MW Premixing of fuel and air enhances combustion efficiency 5.4 lb/hr BACT-PSD
TX-0764 Nacogdoches Power 10/14/15 232 MW Limited hours; good combustion 2.0 ppm BACT-PSD KS-0036 Westar Energy 3/18/13 405 MMBtu/hr Good combustion 5.8 lb/hr BACT-PSD

The technologies identified as possible VOC reduction technologies for large turbines are shown in the table
below.
Table 4-77 – VOC Turbine Control Technologies
Pollutant Control Technologies VOCs Catalytic Oxidation Good Combustion Practices

4.2.2 Turbine VOC Step 2
No presumptive norm has been established for VOC emissions from combustion sources due to the low
emission rate of the units. The existing LM6000 gas turbines located at the West Valley Power Plant are
equipped with water injection, evaporative spray mist inlet air cooling, SCR catalyst, and CO oxidation
catalyst and are estimated to achieve VOC emissions at 2 ppmvd @ 15% O2, which is equivalent to the
control limits identified above.
Catalytic Oxidation
Catalytic oxidation allows complete oxidation to take place at a faster rate and a lower temperature than is
possible with thermal oxidation. Oxidation efficiency depends on exhaust flow rate and composition.
Residence time required for oxidation to take place at the active sites of the catalyst may not be achieved if
exhaust flow rates exceed design specifications.
Good Combustion Practices
Good combustion practices refer to the operation of engines at high combustion efficiency which reduces
the products of incomplete combustion. The turbine installed has been designed to achieve maximum

17 Up-to-date RBLC search run on December 15, 2023.

Utah Municipal Power Agency / Serious Nonattainment Ozone RACT
Trinity Consultants 4-7
combustion efficiency. UMPA follows all instructions given in the operation and maintenance manuals that
detail the required methods to achieve the highest levels of combustion efficiency.
4.2.3 Turbine VOC Steps 3
Oxidation catalyst, in combination with good combustion practices, is capable of achieving a VOC emission
level of 2.0 ppmvd @ 15% O2. It is the remaining control technology that will be evaluated in Step 4.
4.2.4 Turbine VOC Steps 4
The existing LM6000 gas turbines located at the West Valley plant are equipped with water injection,
evaporative spray mist inlet air cooling, SCR catalyst, and CO oxidation catalyst, and are estimated to
achieve VOC emissions at 2 ppmvd @ 15% O2.
4.2.5 Turbine VOC Step 5
RACT is proposed to be oxidation catalyst, in combination with good combustion practices which achieve
VOC emissions of 2 ppmvd @ 15% O2. This limit is comparable to the levels for current-generation water-
injected gas turbines with oxidation catalyst in combination with good combustion practices.

Utah Municipal Power Agency / Serious Nonattainment Ozone RACT
Trinity Consultants 5-8
5. CONCLUSIONS
Based on the information presented and reviewed above, the following conclusions were determined
regarding feasibility and RACT selections:

The LM600 turbines operated at West Valley already employ stringent emissions control technologies to
control and minimize NOx and VOC emissions. SCR technology capable of achieving NOx levels of 2.5
ppmvd is considered to be technically feasible at the West Valley facility. However, since the West Valley
turbines are peaking units and do not operate continuously, the cost associated with achieving this level of
NOx reduction is economically infeasible.

West Valley operates as a peaking facility to provide electric power as required by UMPA member cities and
their customers. These peaking units provide power to the grid to supplement the power supply during
peak-load periods. The facility provides critical operations power and is committed to keeping its operations
reliable and in good working order. The facility follows strict maintenance procedures, which include
scheduled preventative maintenance outages. Any future upgrades would need to be planned well in
advance to ensure continued operation and limit power supply disruptions.

Based on discussions with SCR vendors, ongoing supply chain challenges are an additional consideration
which affect the economic feasibility and the timing of the upgrades evaluated. Some vendors indicated that
due to the transition from coal fired units to natural gas units, there are limited companies to supply and
fabricate the materials needed for the upgrade. As these demands increase, the cost and availability
associated with the catalyst and ammonia injection grid is also anticipated to continue to increase in the
future.

Utah Municipal Power Agency / Serious Nonattainment Ozone RACT
Trinity Consultants A-1
APPENDIX A. COST ANALYSIS REFERENCE

5801 East 41st Street, Tulsa, Oklahoma 74135

November 10, 2023

Attention: Mr. Jerame Blevins
Cc: Stephen Rogers
West Valley Power
5935 West 4700 South
West Valley City, UT 84118
Direct: 801-967-1200

Reference: SCR & Frame Replacement for Combustion Turbine Generators in Simple Cycle Service
BACT Design Basis
Sisu Budgetary Proposal F23-103 Rev.1

Dear Mr. Blevins:

Thank you for inquiring Sisu Energy & Environmental for this project. This proposal would include the
scope of supply detailed herein for one (1) SCR Catalyst and frame replacement for the GE LM6000PC at
the West Valley Power Plant. Our offered scope includes the removal of the old catalyst and frame and
installation of the new catalyst and frame. Further modifications from frame to module supports will
include SCR module tie braces, floor pillow seals and flow blocking baffles upstream and downstream of
SCR Catalyst. The new catalyst utilizes the current generally accepted NOx and NH3 slip standards for Best
Available Control Technology (BACT) for CTG’s in simple cycle operation.

SCR CATALYST

SISU Energy & Environmental will provide (8) replacement Cormetech SCR modules per unit. The new
SCR Catalyst modules are sized in accordance with the original gas path design, and performance is
confirmed per the attached Sisu Table 2 SCR Data Sheet.

SCOPE OF WORK- (New BACT Design SCR Catalyst)

The scope of work will include the new Cormetech “Pleated Design” SCR Catalyst that carries the upgraded
performance criteria for 2.5 ppmvd @ 15% O2 with and NH3 slip of 5 ppmvd @15% O2 (currently installed
design is 5.0 ppmvd @ 15% O2 with and NH3 slip of 10 ppmvd @15% O2. The operating life and emissions
reduction offers operating cost savings while providing a very nominal increase in backpressure, as well
as increased catalyst volume sufficient to meet the (future) higher performance NOx reduction.

5801 East 41st Street, Tulsa, Oklahoma 74135 Page 2 of 7
SCR CATALYST GUARANTEES

Guaranteed Parameter Design
End of Life NH3 Slip ≥ 5 ppmvdc
Pressure Drop ≤3.7inH2O
Outlet NOx ≤2.5 ppmvdc
Life Earlier of 25,000 hours from
gas in or 63 months from
contracted delivery

SCR Inlet Distribution Conditions
Design
Flue Gas Velocity Maldistribution 15.0 %RMS
normal
Flue Gas Temperature Maldistribution 25 ± °F
NH3 to NOx Molar Ratio Maldistribution 15.0 %RMS
normal

Design Conditions
Performance Case
Fuel Gas, Natural
Flow Rate 946,440 lb/hr
Temperature 798 °F
Elevation 4308 FASL
Flue Gas Composition
Nitrogen 72.9 vol%
Oxygen 13.3 vol%
Carbon Dioxide 3.2 vol%
Water 9.7 vol%
Argon 0.9 vol%
Inlet NOx 25.0 ppmvdc
NO2:NOx ratio ≤ 0.50
• Corrected concentrations are corrected to 15% oxygen unless otherwise noted.

BACKPRESSURE ANALYSIS
The background data provided by you for the Haldor-Topsoe NOx Catalyst as currently installed indicated
a total NOx Catalyst pressure drop of 3.2 inches w.c. (reference Section 2.1, Table 3 of the H-T quotation
08-6420-R1). As a comparison, the original Engelhard Catalyst had a guaranteed maximum of 4.1 inches

5801 East 41st Street, Tulsa, Oklahoma 74135 Page 3 of 7
w.c. per the Table A Performance Data that included in the same H-T proposal. The maximum guaranteed
pressure drop for the new Cormetech Catalyst is 3.3 inches w.c. expected, 3.7 inches w.c. guaranteed.
Therefore, based on a typical power reduction of nominally 45 kW per 1.0 inches of additional
backpressure, the expected power production loss would be on the order of 9 kW or less.

AMMONIA CONSUMPTION ANALYSIS
In addition, the expected maximum end-of-life 19% aqueous ammonia flow rate would be reduced as
follows:
CURRENT DESIGN BASIS
5.0 ppmvd @ 15% O2 with and NH3 slip of 10 ppmvd @15% O2 101 lb/hr
BACT DESIGN BASIS
2.5 ppmvd @ 15% O2 with and NH3 slip of 5 ppmvd @15% O2 97 lb/hr

Technical Data
Like-in-kind Design NOx, Pressure
Drop
Number of Units 1
Reactor Layer Module Arrangement 2x4
Estimated Reactor Cross-Section (WxL) 18.50 x 25.75 ft
Flow Direction Horizontal
Module Steel Chrome-Moly
Steel
Number of Modules Per Unit 8.0
Number of Layers 1
Module Width 107.625 inches
Module Length 77.00 inches
Module Depth 27.625 inches
Module Weight 2600 lb

5801 East 41st Street, Tulsa, Oklahoma 74135 Page 4 of 7
SCR CATALYST FRAME REPLACEMENT
The old frame and a portion of liner plates and studs will be removed from the unit. New liner plates and
studs will have to be replaced where the existing frame was located. The new frame will consist of a
complete replacement of the frame with side-wall welded slide supports for the new floating design that
will grow with the SCR catalyst modules. A new top seal plate will be installed on the downstream side of
the catalyst modules. The SCR modules will be installed with wall baffles and roof baffles on the upstream
and downstream side blocking flue gas in the torturous paths.

INSTALLATION & REMOVAL SCR CATALYST MODULES & NEW FRAME DESIGN
The Removal and Install of new SCR Catalyst frame will consist of the following scope:
• Mobilization at Site
• Perform JHA (Job Hazard Analysis) and LOTO (Lock Out Tag Out) upon access to site
• Perform safety / sniff test / check air quality to gain safe access inside unit
• All scaffolding and setup/teardown, as required
• Removal of SCR hatch door at top of unit
• Removal of existing SCR Catalyst and frame
• Install new studs and liner plates
• Installation of new frame with enhanced modifications on the downstream side of the SCR
Catalyst Modules
• Installation of new SCR frame attachment design and sealing mechanism at casing wall.
• Leveling existing floor pedestals to support SCR Catalyst modules.
• Installation of floor pillow seals.
• Installation of new SCR Catalyst Modules
• Installation of module tie braces
• Installation of flow blocking baffles upstream and downstream of SCR.
• Final inspection and clean up
• De-mobilization from Site

Estimated duration for the scope of work is 10 days working 10 hour shifts

SUPPLIED BY PLANT

• Lock out – Tag out
• Staging Area for Work Performed
• Sanitary Facilities
• Trash Disposal Containers for steel and insulation removed from the unit
• Utility Hook-up Including Electrical
• Disposal of original SCR Catalyst modules

5801 East 41st Street, Tulsa, Oklahoma 74135 Page 5 of 7
Note* It is possible that there will be an option to recycle the old SCR catalyst. Sisu will need to pull
an SCR catalyst sample and send it in for an evaluation to determine if the SCR qualifies for catalyst
reuse and can be recycled to create raw material for catalyst manufacturing.

CLARIFICATIONS
• A SISU Project Superintendent will be required on site to oversee all work being performed, and
to provide guidance for duration of the project.
• If technical services are required during start-up, additional charges will be per the attached Sisu
Field Service Rates Sheet.
• Sisu’s installation service does not include removal of debris or replaced equipment or materials
from the plant site. Sisu will clean the work area and dispose materials and debris as directed
within the plant area.
• Materials shipped to site may require the Plant to unload the trucks if the installation crew has
not yet mobilized.
• Downtime or delays in the project thru no fault of SISU Energy & Environmental will be deemed
as extra work and be fully reimbursable at cost +15%.

BUDGET PRICING

Pricing Description Qty. Price
(1) One New Pleated Design SCR Catalyst & Frame with Turnkey
Installation
1 $578,000.00
(5) Five New Pleated Design SCR Catalyst & Frame with Turnkey
installation and consecutive install and one mobilization
5 $2,548,000.00

DELIVERY
FCA Jobsite Pre-Pay & Add

PROPOSAL VALIDITY
Proposal is valid until December 31st, 2023. Pricing will need to be reevaluated at the first of
the year in 2024.

5801 East 41st Street, Tulsa, Oklahoma 74135 Page 6 of 7
TERMS OF PAYMENT

40% Due upon receipt of order
30% Due Upon start of SCR Catalyst Production
10% Due Upon Notification of Readiness to Ship Catalyst
– based on agreed Delivery Date
Balance Due upon completion of installation

All Payments are Due Net 30 Days.

CANCELLATION CHARGES

5% Upon Notification to Proceed
15% Upon Submittal of Approval Drawings
55% Upon Procurement of Materials
75% Upon Start of Manufacturing

ACCEPTANCE BY BUYER:
Buyer shall accept the SCR Catalyst performance based upon satisfactory completion of a mutually
acceptable performance test to be performed within thirty (30) days of installation. If Buyer waives
acceptance testing or does not hold acceptance tests within the time limits set forth herein, then payment
shall be made as if acceptance testing had demonstrated the attainment of guaranteed performance.

WARRANTY AND GUARANTEE:
Mechanical Warranty: Twelve (12) months from date of startup or eighteen (18) months
from date of delivery, whichever is earlier.
Performance Guarantee: 25,000 hours of operation, or 63 months from contracted
delivery, whichever occurs first.
DOCUMENT / MATERIAL DELIVERY SCHEDULE
Drawings for Approval 2-4 weeks after order with full notice to proceed, with complete
engineering specifications and receipt of all engineering details.
Catalyst Modules 11 months after full notice to proceed, or as may be required to
support project schedule – to be confirmed at time of order

5801 East 41st Street, Tulsa, Oklahoma 74135 Page 7 of 7

We appreciate the opportunity to be of service and look forward to working with you on this project.
Please contact me at the number below if you have any questions or require additional information.

Best regards,

Charles Lockhart

Director of Field Service Operations
Sisu Energy & Environmental LLC
Direct: 918-859-1972
[e-mail]

From:David Taylor
To:Melissa Armer
Cc:Shane Minor
Subject:RE: West Valley BACT analysis
Date:Friday, October 27, 2023 12:27:11 PM
Attachments:image001.png
image002.png
Melissa,

All the information provided last year is continuing to impact the stationary catalyst business, I
would budget an increase of ~10-15% higher than the information provided last year. Please see my
original comments below:

“Catalyst Material: $710,000. (+ ~27%) – Much of the raw materials increased for catalyst over the
past year, and many new projects are currently being build (LNG compression/power
turbines/chemical plants) and existing coal units that were meant to shut are accounting for a larger
slice then expected of domestic catalyst production.   

Catalyst installation and retuning of the Ammonia Injection Grid: $120,000 (+ ~29%)  - Some of these
new SCR projects are limiting the production slots of the companies that fabricate and install AIG
systems, and of course higher labor costs.
Total Cost Per 40MW Turbine =  $830,000 USD.”

David Taylor
Vice-President Sales,
Safety Power America Inc.,
Houston, TX

+1 281.435.4833
[e-mail]
www.safetypower.com

From: Shane Minor <[e-mail]> 
Sent: Friday, October 27, 2023 12:17 PM
To: David Taylor <[e-mail]>
Subject: Fwd: West Valley BACT analysis

CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you
recognize the sender and know the content is safe.
David can you look at Melissa's request below and let me know your thoughts?  Happy to take a call
if we need to.  

Get Outlook for iOS
Shane Minor
Wheeler Power Systems
[phone]
From: Melissa Armer <[e-mail]>
Sent: Friday, October 27, 2023 11:03:32 AM
To: Shane Minor <[e-mail]>
Cc: [e-mail] <[e-mail]>; Kevin Garlick <[e-mail]>
Subject: West Valley BACT analysis

This message is from an EXTERNAL SENDER - be CAUTIOUS, particularly with links and
attachments.
Hi Shane,
UMPA West Valley is required by UDAQ to complete another updated air pollution control technology
analysis, similar to what was completed earlier this year. Below is our correspondence and the budget
proposal that you provided earlier this year. We are requesting that you provide an updated budget
proposal for the same upgrade that would reflect any budgetary changes. Below is a summary of the
proposed upgrade.

We would like a quote to install all new catalyst and new frames for each unit designed to meet current
BACT limits of 2.5 ppm NOx and 5.0 ppm ammonia slip.

Please include in your quote the following:
Additional ammonia consumption rate
Capital cost
Delivery, engineering, labor, installation, and startup costs

If you are able to provide the updated proposal by November 10th that would allow us enough time to
incorporate the proposal into our updated analysis. Let me know if you have any questions or would like
to have a call to discuss.

Melissa Armer, P.E.
Managing ConsultantTrinity Consultants, Inc.
P: 208.472.8837 M: 208.870.3215
New Address: 405 S. 8th St. Ste 331, Boise, ID 83702
Email: [e-mail]
From: Shane Minor <[e-mail]> 
Sent: Tuesday, January 17, 2023 8:50 AM
To: Melissa Armer <[e-mail]>
Subject: Fwd: West Valley BACT analysis

Hi Melissa, see below. Remember that these are factory list prices not sell prices.  Thanks!

Get Outlook for iOS
Shane Minor
Wheeler Power Systems
[phone]
From: David Taylor <[e-mail]>
Sent: Tuesday, January 17, 2023 7:43:13 AM
To: Shane Minor <[e-mail]>
Cc: David Stelzer <[e-mail]>
Subject: RE: West Valley BACT analysis

Shane,

David Stelzer forwarded me your e-mail about the updated pricing. I joined Safety Power in October
of last year, and I’m based out of Houston Texas, but up in Toronto for meetings this week. It’s a bit
early now with the time difference, but I’ll call later today to introduce myself. I also previously
worked on SCR systems for gas turbines and other industries, so I can lend some insight into the
updated numbers with come context.

Catalyst Material: $710,000. (+ ~27%) – Much of the raw materials increased for catalyst over the
past year, and many new projects are currently being build (LNG compression/power
turbines/chemical plants) and existing coal units that were meant to shut are accounting for a larger
slice then expected of domestic catalyst production.   

Catalyst installation and retuning of the Ammonia Injection Grid: $120,000 (+ ~29%)  - Some of these
new SCR projects are limiting the production slots of the companies that fabricate and install AIG
systems, and of course higher labor costs.
Total Cost Per 40MW Turbine =  $830,000 USD.

I hope this information was helpful, I’ll call later today.

David Taylor
Vice-President Sales,
Safety Power America Inc.,
Houston, TX

+1 281.435.4833
[e-mail]
www.safetypower.com

From: Shane Minor <[e-mail]> 
Sent: January 16, 2023 1:29 PM
To: David Stelzer <[e-mail]>
Subject: FW: West Valley BACT analysis

CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you
recognize the sender and know the content is safe.
Hi David,

You helped with this before, see below.  Can you review Melissa’s narrative below and provide
budgetary escalations?

Thanks,

Shane

Shane Minor | Govt. Util, Int. Sales | Wheeler Machinery Co.
4901 West 2100 South, Salt Lake City, UT 84120
Office: 801.978.1533 | Mobile: [phone]
[e-mail] | www.wheelercat.com
Built to Listen. Built to Deliver.How can we better serve you? Please share your feedback.

From: Melissa Armer <[e-mail]> 
Sent: Thursday, January 12, 2023 11:09 AM
To: Shane Minor <[e-mail]>
Cc: Jerame Blevins <[e-mail]>
Subject: West Valley BACT analysis

Hi Shane,
Hope all is well with you. As you may be aware, UDAQ is completing an updated controls analysis for
existing sources in the Northern Wasatch Front (NWF) ozone NAA. UDAQ is providing sources with an
opportunity to provide updated cost and emissions information since the information in 2017 may be
outdated.

We are requesting updated quotes from vendors to install all new catalyst and new frames for each unit
designed to meet current BACT limits of 2.5 ppm NOx and 5.0 ppm ammonia slip. In 2017 you helped us
get a quote from Safety Power, is Bob Stelzer still someone we can contact to get an updated quote?
(see emails below).

Let us know if you are able to help facilitate a call with Safety Power to discuss and get an updated
quote. We are on a tight schedule as we need to submit our updated analysis to UDAQ by January 31st.

Thanks,
Melissa

Melissa Armer, P.E.
Managing Consultant
Trinity Consultants, Inc.
P: 208.472.8837 M: 208.870.3215
702 W. Idaho St., Suite 1100, Boise, ID 83702
Email: [e-mail]

From: Shane Minor <[e-mail]> 
Sent: Wednesday, April 26, 2017 6:28 PM
To: Melissa Armer <[e-mail]>

Utah Municipal Power Agency / Serious Nonattainment Ozone RACT
Trinity Consultants B-1
APPENDIX B. COST CALCULATIONS
West Valley Power Plant Cost Analysis for West Valley Turbines 2023_v0.01
RACT Control Cost Evaluation for SCR Addition to Existing Unit - General Information
Parameter Value NotesEquipment Life Expectancy (Years)5 SISU quoteInterest Rate (%)7.00%EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and Methodology. Section 2.5.2
RACT Control Cost Evaluation for SCR Addition to Existing Unit - Capital Investment
Parameter Value NotesTotal Increase in Capital Investment ($)$578,000 Received two quotes: SISU and Safety Power America Inc. Utilized the lowest cost for analysis.Capital Recovery Factor (CRF)0.2439 EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and Methodology, Equation 2.8aCapital Recovery Cost (CRC)$140,969 EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and Methodology, Equation 2.8
RACT Control Cost Evaluation for NG Turbine- Annual Costs- Average Operating Hours
Parameter Value NotesTotal Annual Cost $140,969 Sum of Capital Recovery Cost2017 Average Turbine Operating Hours 1,061 Average turbine operating hoursCurrent SCR System (7.4 lb/hr) (tpy)3.93SCR Modification (3.7 lb/hr) (tpy)1.96NOX Removed (tpy)1.97Cost per Ton of NOX Removed ($/ton)$71,558
RACT Control Cost Evaluation for NG Turbine- Annual Costs- Maximum Operating Hours
Parameter Value NotesTotal Annual Cost $140,969 Sum of Capital Recovery Cost2017 Maximum Turbine Operating Hours 1,217 Maximum turbine operating hoursCurrent SCR System (7.4 lb/hr) (tpy)4.50SCR Modification (3.7 lb/hr) (tpy)2.25NOX Removed (tpy)2.25Cost per Ton of NOX Removed ($/ton)$62,653
NOX Cost Per Ton Removed
Economic Factors
NOX Cost Per Ton Removed
SCR Cost Evaluation
West Valley Power Plant Cost Analysis for West Valley Turbines 2023_v0.01
2017 Emissions from ECMPS Client Tool
Turbine 1
Qtr MMBtu lb/MMBtu NOx tons144,882 0.03 0.67217,239 0.033 0.28398,538 0.031 1.53463,350 0.038 1.20
3.69
Turbine 2
Qtr MMBtu lb/MMBtu NOx tons155,854 0.031 0.87296,132 0.026 1.25397,918 0.029 1.42456,461 0.037 1.04
4.58
Turbine 3
Qtr MMBtu lb/MMBtu NOx tons169,231 0.03 1.04298,843 0.028 1.38391,707 0.036 1.65446,744 0.04 0.93
5.01
Turbine 4
Qtr MMBtu lb/MMBtu NOx tons164,498 0.035 1.132102,556 0.03 1.54392,538 0.033 1.53450,047 0.036 0.90
5.09
Turbine 5
Qtr MMBtu lb/MMBtu NOx tons148,993 0.038 0.93280,273 0.029 1.16384,722 0.034 1.44442,375 0.038 0.81
4.34
Facility-wide Total (tpy):22.71
Turbine
2017 Actual
(hr/yr)Turbine 1 821Turbine 2 1,146Turbine 3 1,217Turbine 4 1,157Turbine 5 965
Average Operating Hrs:1,061
Max Operating Hrs:1,217
Total ton/yr
Total ton/yr
Total ton/yr
Total ton/yr
Total ton/yr
NOx Emissions