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Gary A. Jack Telephone: 304.534.7409 Senior Coworate Counsel Fax: 330.315.9939
VIA EMAIL AND FEDEX OVERNIGHT
John Auville, Esquire Legal Division Public Service Commission of West Virginia 201 Brooks Street PO Box 812 Charleston, WV 25323
Re: Monongahela Power Company and The Potomac Edison Company Petition for Approval of a Generation Resource Transaction and Reiaied Relief; Case No. 12-1571-E-PC
Dear Mr. Auville:
Enclosed please find Monongahela Power Company’s and The Potomac Edison Company’s response in the above-referenced case to the following Staffs First Request for Information Nos. 4, 5,9 and 10.
Sincerely,
Senior Corporate Counsel WV State Bar No. 1855
GAJ:bsm
Enclosures
cc: Christopher Callas, Esq. (Via Email) Sandra Squire - WVPSC (Via FedEx Overnight) Monongahela Bower Company and The Potomac Edison Company Case No. 12-1571-E-PC West Virginia PSC Staff First Request for Information
The following response to Q-1.4 of the First Request for Information of the West Virginia PSC Staff received on December 21,2012 has been prepared under the supervision of the person identified below.
Name: Michael B. Delmar Title: Director, Regulated Generation and Dispatch Company: FirstEnergy Service Company Date: January 7,2013
~~
Q-1.4 Mihat is the projected date of retirement for the Harrison facility?
Response:
Mon Power's probable retirement dates for book depreciation purposes for the Harrison facilities are as follows:
Harrison Generating Unit 1 June 30,2037 Harrison Generating Unit 2 June 30,2038 Harrison Generating Unit 3 June 30,2039 Harrison Common Facilities June 30,2039 Monongahela Power Company and The Potomac Edison Company Case No. 12-1571-E-BC West Virginia PSC Staff First Request for Information
The following response to Q-1.5 of the First Request for Information of the West Virginia PSC Staff received on December 2 1,2012 has been prepared under the supeivisioii of the person identified below.
Name: Michael B. Delmar Title: Director, Regulated Generation and Dispatch Company: FirstEnergy Service Company Date: January 4,20 13
Q-1.5 What is the projected life expectancy of Console Energy's Robinson Run mine?
Response:
Consol's Robinson Run mine's reserve base is approximately 300 million recoverable tons, or approximately 50 years at the mines cui-rent rate of production. Monongahela Power Company and The Botomac Edison Company Case No. 12-1571-E-BC West Virginia PSC Staff First Request for Information
The following response to Q-1.9 of the First Request for Information of the West Virginia PSC Staff received on December 21,2012 has been prepared under the supervision of the person identified below.
Name: Michael B. Delmar Title: Director, Regulated Generation and Dispatch Company: FirstEnergy Service Company Date: January 7,2013
Q-1.9 What is the projected date of retirement for the Pleasants facility?
Response:
Mon Power's probable retirement dates for the purposes of book depreciation for the Pleasazts fzcilities zre as fc~!!ows:
Pleasants Generating Unit 1 June 30,2044 Pleasants Generating Unit 2 June 30,2045 Pleasants Gypsum Plant June 30,2045 Pleasants Common Facilities June 30,2045 Monongahela Power Company and The Potomac Edison Company Case No. 12-1571-E-PC West Virginia PSC Staff First Request for Information
The following response to Q-1.10 of the First Request for Information of the West Virginia PSC Staff received on December 21,2012 has been prepared under the supervision of the person identified below.
Name: Thomas A. Pezze Title: Director Technical Services Company: FirstEnergy Date: 1E201 3
Q-1.10 Please describe the Pleasants facility in as much detail as was provided in the direct testimony (pages 2 though 11) of h4i. Thomas ,4. Pezze for the Harrison facility.
Response:
See Staff-Set 1-Q- 1.10 Attachment. Description of Pleasants Power Station
Pleasants is a two-unit. supercritical coal power plant located on the south bank of the Ohio River, 15 miles east of Parkersburg, West Virginia on Route 2. It is jointly owned by AE Supply (92.3196) and Mon Power (7.699'0). Pleasants encompasses 152 acres of a 1,267-acre site and currently staffs approxirxately 200 full-time employees to operate and maintain the facility. Unit 1 began commercial operation in 1979 and Unit 2 followed in 1980. Pleasants has a net generating capacity of 1,300 MW, and each unit is rated for 650 MW. The PJM sunmier Instalied Capacity ("ICAP") obligation is 1.278
Mv\'.
Pleasants can receive coal by barge, rail car and highway truck. Currently. coal is delivered primarily by barge and originates from Ohio and Illinois basin coal mines.
Ezch of Peastiits' wits is equipped with Wet Flue Gas Desulfurization
("WFGD"), more commonly known 2s a "scrubber." as ell as Selective Catalytic
Reduction ("SCR") and Electrostatic Precipitators ("ESP") facilities to control SOX,NOx
and particulate matter.
PRIMARY COMJ'ONENTS OF PLEAS4NTS POWER STATION.
The major components of Pleasants are (i) turbines, (ii) generators, (iii) boilers.
(iv) cooling towers, and (v) stacks or chimneys.
Turbines
Each unit at Pleasants has a turbine train consisting of four turbine elements: (a)
one single flow high pressure C'HP'') turbine, (ii) one dual flow intei-niediate pressure
("IP") turbine. and (iii) two dual flow low pressure ("L?.') turbines. which are coupled together in series. These turbines were manufactured by Allk Chalmers Power Systems, nom’ Siemens Power (“Siemens”).
Genera tors
Both of the generators at Pleasants were also manufactured by AlIis Chalmers
Power Systems, now Siemens. The generators are hydrogen-cooled and are rated at 760
mega volt amps (“MVA”): have a 0.9 power factor, and produce 26.000 volts and 60
hertz. The 26,000 volts supplied by each generator is increased to 500 kilovolts (*‘KV*’)
by the generator step-up transformer (“GSU”) before being transmitted across the electric
grid.
Bo ilem
Each unit has a Foster Wheeler coal-fired supercritical boiler with a single reheat.
Tt.llle boilcrj* are rated st 5,035,000 %S~II ef stem at 3,550 po-mds per square inch gauge
(‘*PSIG‘) and 1.01 0 degrees Fahrenheit. Each boiler is equipped with twenty-four
pulverized coal burners, six coal silos, twelve coal feeders and six Foster Wheeler ball
mill coal pulverizers. Natural gas is used to light-off the boilers and establish a coal
flame. The combustion air is mainly heated by Ljungstrum regenerative air heaters.
Each unit is equipped with 2 primaiy and two secondary air heaters. The 2A primary air
heater is a heat pipe design rather than a regenerative air heater. The combustion air is
raised to a range of 420 to 650 degrees Fahrenheit. The boilers are of balanced draft
design, requiring both forced and induced draft fans to move air and the products of
combustion through the boiler. Coal is transported from the pulverizers to the burners by
primary air fans.
Cooling Towers Pleasants is equipped with two cooling towers. Each hyperbolic cooling tower is constructed from reinforced concrete and is 430 feet high and 360 feet in diameter.
Circulating water is pumped to the turbine condensers from the cooling towers at a rate of
270,000 gallons per minute to cool and condense the turbine exhaust steam. These circulating water systems are closed loop; however, losses from cooling tower evaporazion and blow down OCCUT and are replaced with water from the Ohio River.
Water evaporates from the cooling towers at a rate of approximately 5,400 gallons per minute.
Stnclm/Chimneys
There are three stacks at Pleasants, two of which have not been in use since the station went to 100% scrubbing in 2008. Each original stack is 1,000 feet high. The r,ewer stack is constmcted sf reinforced concrete with E base diameter of 73 feet The concrete stack acts as a structural shell that contains two 29-foot diameter chimney flues, one for each unit. The chimney flues are constructed of fiberglass. All flue gas from the combustion process exits the plant through the new chimney and is monitored for reporting purposes by emissions monitors.
SOLID WASTE CONTROL AT PLEASANTS
Pleasants includes an on-site solid waste landfill that is lined with clay and/or an approved alternative liner and also has a 274 acre wet impoundment on McElroy's run,
Solid waste that is generated from the WFGD system and fly ashlbottom ash is disposed at this site. The total disposal area is I. 115 acres. At Peasants' current rate of generation, there is sufficient volume to operate a landfill for approximately 11 years, with the potential for fui-ther expansion if needed. Changes in environmental and dam safety regulations could force the closure of the McElroy's Run impoundment in 5 years. This would reduce the available landfill space by at least 3 years. Since the impoundment can also be used for storm water management closing it could have a substantial impact on station operations. Closure costs of the Mcelroy's Run impoundment could be significant.
Should it be required that the impoundment be completely dewatered and the material removed and placed on a lined landfill the cost could be significant.
B. Environmental Controls at Pleasants
As indicated previously. Pleasants has WFGD (scrubbers), SCR and ESP controls. These are described in more detail below.
J$TL?7GD/S(yZ&y
Both units at Pleasants were built with WFGD controls, or scrubbers. during original construction. These scmbbers were manufactured by B&W. Each unit has 4 dedicated absorbers per unit and utilizes a wet lime WFGD process fed by magnesium enhanced lime, which is delivered to the station by barge. Originally these units were designed to bypass 10% of the flue gas to maintain stack exit temperatures but they were converted to 100% scrubbing in 2008.
In the wet lime process, as flue gas leaves the electrostatic precipitators, it enters the WFGD absorbers. Once in the WFGD absorber, SO:! is removed from the flue gas by direct contact with a continuous spray of slaked lime. Slaking is the process of mixing the lime with water to form magnesium hydroxide and calcium hydroxide. The magnesium hydroxide and calcium hydroxide react with the SO? in the flue gas to remove the SO,. This process results in a byproduct, which is pumped to a thickener and allowed to settle before being dewatered and mixed with lime, forming a product with cementitious properties which may be easily and appropriately disposed of in a landfill.
This WFGD process is a negative water balance, zero discharge process and does not have an outfall associated with the National Pollutant Discharge Elimination System
(“NPDES”) permit.
SCR
The Pleasants units were retrofitted with SCR controls in 2003. The SCR process adds anmonia to the flue gas as it passes through a catalyst; ammonia reduces the NOx to molecular nitrogen. The catalyst is comprised of a series of layers inside a box-shaped reactor. As flue gas exits the boiler, it fiows downward through the reactor to minimize ash acc2pAz!ati=r,=E the cataiyst. Liq-&d urea is cse.1 2s the r&j&g awntL?------2nd is tli-icl& to the site.
The plant also recently added a sodium based system to reduce stack opacity. This system uses Soda Ash (Sodium Carbonate).
ESPs
Electric Static Precipitators are installed and control particulate matter within all
applicable requirements.
C. Peasants’ Compliance with Emissions Standards
CLEAN AIR ACT (‘C4A”) COMPLIANCE
Since the U.S. Environmental Protection Agency (“EPA”) passed the CAA.
Pleasants has been required to meet opacity, particulate matter (“PM.’), SO2 and NOx emissions standards. Utilizing the ESP, WFGD and SCR environmental control systems already discussed, as well as participation in cap and trade programs, Pleasants is currentiy in compiiance with the CAA’ s emission requirements. The facility currently is cur-rently operating under Title V permit #R30-0730G005-2008 that was issued on April
23, 2008 (current pennit expires on April 23, 2013), and a Title V renewal was submiEed on October 18, 2012. A renewal application for Peasants’ Acid Rain Permit and NOx
Averaging Plan was submitted on June 29. 2012 and new permits were received on
November 1,2012. (Revised Acid Rain Peimit expires December 31,2017).
THE CLEAN AIR INTERSTATE RULE (“CAIR”) REQUIREMENTS. AND
PLEASANTS COMPLIANCE
The EPA’s Clean Air Interstate Rule requires reductions of NOx and SO2 .. em:ss:ocs in two phases (2009i20!0 and 20151, dtimate!y czipping SO: erxissions in
affected states to 2.5 million tons annually and NOx emissions to 1.3 million tons
annually. Like the CAA, CAIR allows trading of NOx and SO: emissions allowances
within defined geographical areas to achieve compiiance. Peasants‘ SO2 allowances fi-om
the CAA Acid Rain Program are also used to satisfy the CAIR SO2 requirements at a 2: 1
surrender ratio for 201 0 - 20 14 and a 3 : 1 surrender ratio for 201 5 and beyond. Pleasants
also receives annual and ozone season NOx allocations under the CAIR program and can
purchase additional NOx allowances if required.
THE CROSS STATE AIR POLLUTION RULE (TSAPR“)
CSAPR, which would have replaced the CAIR de,required further reductions in
SO2 and NOx that generating units are permitted to emit by establishing emission caps for
each pollutant by state. CSAPR was designed as a cap and trade program, similar to the CAIR program. but with limits on interstate trading. CSAPR was vacated by the U.S.
Court of Appeals for the District of Columbia Circuit on August 21, 2012; however, the
EPA and three other parties filed petitions for rehearing on October 5, 2012. Since
Pleasants is equipped with scrubbers and SCR. no additional enlissions controls will be required for compliance with CSAPR if enacted.
PLEASANT'S COWLIANCE WITH THE MERCURY AIR TOXICS STANDARD
("MATS") RULE
The MATS rule was finalized by the EPA on December 21, 2011 and will take
effect on April 16, 201 5. IVL4TS will establish more stringent emission standards for PM. mercury, and hydrochloric acid ("HCI") and impose new work practice standards and
monitoring, recordkeeping and reporting requirements. Pleasants is currently in
cmnphnce with the ==re stringent mercq' limits with the clirrent he1 blends Other
modifications must be made to Pleasants to achieve full compliance with the M4TS
rule's standards by April 10.2015.
. ~~- ~.~_ - ~~ First, to achieve the more stringent PM standards, the existing ESP transfoniier -
rectifier sets will be retrofitted with high frequency transformer rectifiers. This will
increase the efficiency of Peasants' ESP process. Once this upgrade is complete. the
units will be tested to determine if they meet the new PM limit. In addition to these
efforts, any needed repairs to duct work to reduce air-in leakage and improve precipitator
performance will be made.
Second, instead of adding equipment to control HC1 at Pleasants. SO2 will be
controlled as a surrogate for HC1 using Peasants. existing WFGD systems. Currently, the
Pleasants SO2 emission rates are marginally within the neu7 limit. In order to ensure compliance, some additional equipment is expected to be added to the WFGD system, and that is under current review and analysis. Activated Carbon Injectiori may also be required. Collectively, these improvements are estimated to cost up to $68.4 million in capital and cost of removal plus up to $1 1 million per year in additional operating expenses.
PLEASANTS COMPLIANCE WITH GREENHOUSE GAS REQUIREMENTS
Pleasants is in full compliance with the EPA's greenhouse gas ("GHG") emissions collection and reporting rules and has continuous CO? monitoring systems in place to compile information submitted in annual reports. Re: Monongahela Power Company and The Potomac Edison Company Petition for Approval of a Generation Resource Transaction and Related Relief; Case No. 12-1571-E-PC
CERTIFICATE OF SERVICE
I hereby certify that on this 10‘ day of January, 2013, a copy of the foregoing
Monongahela Power Company’s and The Potomac Edison Company’s response to Staff’s First
Request for Infurmation was sent by U.S. Mail, First Class, to:
William V. DePaulo, Esq. Patrick K. Maroney, Esq. 179 Summers Street, Suite 232 Counsel, Utility Workers Union of America Charleston, WV 25301 Maroney, Williams, Weaver, & Pancake, PLLC 608 Virginia Street East Jackie Roberts Charleston, WV 25301 Depcty Consllrr?er A-d?Or,ate Public Service Commission of West Virginia 700 Union Building Scott J. Rubin, Esq. 723 Kanawha Boulevard, East 333 Oak Lane Charleston, WV 25301 Bloomsburg, PA 17815