THE APPLICATION OF KENTUCKY POWER

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on di~ti1late.l~Most recently built CCs installed with 7FA or non-7FA turbines have also been fitted with Selective Catalytic Reduction (“SCR”) controls. Table 11 Number of Turbines with NOx Control Equipment in PJM Units Installed Since 2002 Single Fuel All Turbine 7FA Models Turbines Dual Fuel All Turbine 7FA Models Turbines (COlillf) (COliIlt) (COliIlt) (COlillt) Gas CT Dry LowNOx Burners Selective Catalytic Reduction Water Injection Total Gas CC Dry Low NOx Burners Selective Catalytic Reduction WaterInjection 0 0 9 9 Total 18 11 13 10 Soirrcesatid Notes Ventyx (2011). The data in Table 11 indicate that 7FAs in simply cycle mode have not installed SCRs. However, this does not prove that SCRs will be infeasible or unneeded in 2015 as environmental regulationscontinuetotighten. Manyrecently-builtnon-7FACTshavebeenfittedwithanSCR. Although no recently-built 7FA CTs have been fitted with SCRs, one earlier unit was fitted with this technology, however, it is not located in PJM.16 There are two reasons that few SCRs have been required on 7FAs in simple-cycle configuration. First, the 7FA has a relatively lower emissions rate than most other turbines even without an SCR because of its diy low-NOx buining technology. The 7FA.05 NOx emissions rate is 9 ppm without an SCR (2 ppm with an SCR), while many emissions standards have been developed based on the maximum allowed emissions rates of 25 pprri for gas CTs.” Second, the temperature of 7FA turbine exhaust is very high, which requires the exhaust to be diluted through tempering air fans to avoid damaging the SCR equipment. Adding a hot SCR to a 7FA in simple-cycle configuration incurs a higher cost than adding a typical SCR to a turbine with a lower exhaust temperature. Despite the higher costs, CH2M HILL has confirmed with three potential suppliers of hot SCR controls that they have received inquiries and budget requests for hot SCRs on large F-class turbines for projects currently under development in the Confirmed based on guidance from CH2M HIL.L, and GE representatives. The Rowan plant in Salisbury, North Carolina built in 2001, see Ventyx (2011). See for example, New Jersey State Department of Environmental Protection (201l),pg. 29, as well as the Ozone Transport Commission (2010), pg. 4,both stipulate a maximum CT emissions rate of 25 ppm” l5 16 39 7 16 0 20 1 55 7 23 17 1 0 24 17 24 17 17 11 18 11 10 10 13 10 13

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