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through retirement or other We estimate ERC costs for VOCs and NOx, which are precursors to ozone and for which both the CC and CT plants will be considered major sources. To estimate the number of ERCs needed, we started with two recently permitted plants, the Bayonne Energy Center gas CT and the York Energy Center gas CC facilities. Both air peiinits specify a potential to emit (PTE), or the maxiinum potential emissions limit for the year.25 We then developed an estimate of PTE for each reference plant by scaling based on each plant’s heatrate, emissions rate, and total MW rating as suinmarized in Table 26. Recently Permitted Plants Bayonne (CT) York Energy Center (CC) Reference Technology GasCTNo SCR Gas CT w/ SCR cas CC Capacity Heat Rate NOx (Mw) ( h t d k Wi) (ppni) 512 9,519 2.5 1,100 7,727 2.0 392 10,036 9.0 390 10,094 2.0 656 6.722 2.0 Table 26 Total Potential to Emit Sotiires nrid Notes: See Bayonne Pennits Obtained (201I), pg. I51 for capacity, pg. 158 for emission rates, and pg. 76 for PTE See York Energy Center Permits Obtained (2005)for capacity, emissions rates, and potential to emit See Ventyx (2011) for heat rate infonnation See CH2M H1L.L Engineers, Inc. (2011) for reference technology specifications. We used locational cost estimates for ERCs provided by CH2M HILL to deteiinine the total compliancecostsasshowninTable27andTable28. IneachcasethetotalERCsthatmustbe procured is also multiplied by a location-specific offset ratio, reflecting the requirement to procure offsets in excess of PTE at a rate that depends on the severity of ozone Nonattainment as reported previously in Table 12. Because Dominion is in Attainment, we do not estimate ERC costs for that location. 24 See EPA (201le) 25 See Bayonne Permits Obtained (2011) and York Energy Center Permits Obtained (2005). 23 Emission Rates Potential to Emit VOC NOx VOC (ppiil) (tPY) (tPY) 2.5 109.5 36.8 2.0 460.2 46.2 7.0 318.2 8.3.2 5.0 70.8 59.5 5.0 238.8 59.9PDF Image | THE APPLICATION OF KENTUCKY POWER
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