Chapter 6 - Appendix A Fatal Flaw Analysis

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Chapter 6 - Appendix A Fatal Flaw Analysis Option Description Meramec Repowering - Unit 3 Boiler Replacement and STG Rebuild Meramec Repowering - Unit 4 Boiler Replacement and STG Rebuild Meramec Repowering - Oxyfuel Boiler Replacement Meramec Repowering - CFB Boiler Replacement Greenfield - USCPC Greenfield - Oxyfuel with CCC Greenfield - IGCC Greenfield - Subcritical CFB Greenfield - Supercritical CFB Greenfield - Pressurized Circulating Fluidized Bed (CFB) Greenfield - Pressurized Bubbling Fluidized Bed (BFB) Greenfield - USCPC with Amine-Based Post-Combustion CCC Greenfield - Subcritical CFB with Amine-Based Post-Combustion CCC Greenfield - IGCC with Pre-Combustion CCC Efficiency Improvements to Existing Plants Duct Draft Reductions Efficiency Improvements to Existing Plants Condenser Back-pressure Reductions Greenfield - CCCT Amine-Based Post-Combustion CCC Greenfield - 2-on-1 501F CCCT Mexico - One GE LM6000 Sprint SCCT (5% CF) Mexico - One GE LM6000 Sprint SCCT (10% CF) Raccoon Creek - One GE 7EA SCCT (5% CF) Raccoon Creek - One GE 7EA SCCT (10% CF) Meramec Repowering - Unit 3 Boiler NG Conversion Meramec Repowering - Unit 4 Boiler NG Conversion Meramec Repowering - Unit 3 & Unit 4 STGs in Separate CCCT Conversions Meramec Repowering - Unit 3 & Unit 4 STGs in a Shared CCCT Conversion Greenfield - Molten Carbonate Fuel Cell Greenfield - Natural Fueled Rankine Cycle Greenfield - Twelve Wartsila 20V34SG Simple Cycle Reciprocating Engines Greenfield - Two 501F SCCTs (5% CF) Greenfield - Two 501F SCCTs (10% CF) Greenfield 2-on-1 Wartsila 20V34SG Combined Cycle Reciprocating Engine Greenfield GE 7EA Cheng Cycle Fatal Flaw 2014 Integrated Resource Plan Page 1

Chapter 6 Appendix A A high-level fatal flaw analysis was conducted as part of the first stage of the supplyside selection analysis. Options that did not pass the high-level fatal flaw analysis consist of those options that could not be reasonably developed or implemented by ; options that passed were considered preliminary candidate resource options. 1 In general for the coal & natural gas options, the Greenfield options were selected to represent the technology because additional studies would need to be implemented for specific locations. For example, the Greenfield-USCPC passed and the Rush Island- USCPC did not pass the first stage of the high-level fatal flaw analysis. Note: The Meramec coal and gas options were eliminated from the analysis and will be evaluated as part of the integration analysis. Below are details for several options that did not pass the high-level fatal flaw analysis. This fatal flaw analysis did not take into account potential carbon dioxide (CO 2 ) regulations that might result from the White House Climate Action Plan. The President directed the EPA to propose rules for modified, reconstructed and existing power plants no later than June 1, 2014 with finalization of the rule no later than June 1, 2015. The EPA published proposed rules on June 2, 2014 in response to the President s directive. The EPA is taking comments on the proposed rule for existing sources until December 1, 2014. EPA continues to indicate it plans to finalize the existing source rule by June 1, 2015. Meramec Repowering Unit 3 Boiler NG Conversion (Option A08.1) This option is not feasible because it is likely that the unit would have a low capacity factor (i.e., cycling service) which would potentially cause equipment/operational issues due to the age of the plant. The following scope of work applies to the Meramec Unit 3 and 4 options in which the boilers would be converted to burn natural gas: 1. Burner replacement. 2. Reheater modifications. 3. Superheater modifications. 4. Desuperheater spray modifications. 5. Air heater modifications. 6. Boiler controls modifications. 1 4 CSR 240-22.040(2); 4 CSR 240-22.040(2)(C); 4 CSR 240-22.040(2)(C)2 Page 2 2014 Integrated Resource Plan

Additional work may include: Installation of new natural gas supply regulating stations, piping, and valves in the boiler house Primary air isolation modifications Meramec Repowering Unit 4 Boiler NG Conversion (Option A08.2) This option is not feasible for the same reasons that Option A08.1 is not feasible. Meramec Repowering Unit 3 & Unit 4 STGs in Separate CCCT Conversions (Option A10) This option is not feasible because of the age of the turbine and heat cycle equipment and transmission limitations. The electrical output from the current units is roughly 850 MW. If the Unit 3 and 4 steam turbine generators (STGs) were converted for use in separate combined cycles, the Unit 3 block would produce an estimated net output of 600 to 700 MW, and the Unit 4 block would produce an estimated net output of 800 to 900 MW, for a total net plant output of approximately 1,500 MW. Such an increase in net plant output would likely require major upgrades to the three 138 kv transmission lines tied to Meramec. For the purposes of this study, only the conversion of the Unit 4 STG (Option A09) in a combined cycle was evaluated. If the preliminary characteristics for the Unit 4 STG conversion in a combined cycle option seem promising, then further study could be performed to evaluate the potential for conversion of the Unit 3 STG or Unit 3 and 4 STGs in combined cycles. Meramec Repowering Unit 3 & Unit 4 STGs in a Shared CCCT Conversion (Option A11) This option is not feasible for the same reasons that Option A10 is not feasible. Greenfield Natural -Fueled Rankine Cycle (Option A14) This technology is considered obsolete. Past generation planning efforts have shown this option to be noncompetitive compared with other technologies. Black & Veatch is not aware of any new projects that were developed with this technology in the recent past. Meramec Repowering Unit 3 Boiler Replacement and STG Rebuild (Option B02.1) This option is not feasible because of the scope of additional pollution control equipment anticipated to be needed to meet air emission limitations for particulate matter (PM), sulfur dioxide (SO 2 ) and nitrogen oxide (NO x ). The following scope of work applies to 2014 Integrated Resource Plan Page 3

Chapter 6 Appendix A the Meramec Unit 3 and 4 options in which the boilers would be replaced and the STG sets would be refurbished: 1. Boiler - New waterwalls. 2. Boiler - Major superheater and reheater retrofits. 3. Steam piping modifications (main steam, cold reheat, and hot reheat). 4. Feedwater system modifications. 5. Hot well pump overhaul. 6. DA replacement (excluding DA storage tank). 7. One feedwater heater replacement. 8. Condenser retubing. 9. Induced draft fan motor and rotor modifications. 10. Water cannon replacement. 11. Unit-specific bottom ash system. 12. Fly ash collection system. 13. Significant structural steel modifications. 14. Demolition. 15. STG intermediate pressure (IP) retrofit. 16. STG high pressure (HP) stator rewind and rotor replacement. 17. STG low pressure (LP) stator rewind and rotor replacement. 18. STG static excitation retrofit. Meramec Repowering Unit 4 Boiler Replacement and STG Rebuild (Option B02.2) This option is not feasible for the same reasons that Option B02.1 is not feasible. [Note: The LP and HP rotors were re-wound in 2013]. Meramec Unit 3 & 4 Boiler Replacement with Oxyfuel Boilers (Option B04) This option is not feasible because of the scope of additional pollutions control equipment anticipated to be needed to meet air emission limitations for PM, SO 2 and NO x. In addition, if traditional cryogenic air separation units (ASUs) are used, it is likely that space requirements will likely require modification and relocation of existing equipment. Space available around the Unit 3 and 4 boilers is inadequate for siting a cryogenic ASU. On the basis of previous Black & Veatch estimates, the increased auxiliary loading due to the ASUs would reduce the net plant output by approximately 25 percent and would reduce plant efficiency in excess of 10 percentage points. Taking a longer-term outlook, if Ion Transport Membranes (ITMs) become commercially available for air separation, the space requirements would be reduced, and depending on the configuration, plant output could actually increase by about 20%. However, cost would still be very high. Levelized cost of electricity for a greenfield oxy-combustion plant using ITM technology is upwards of $140/MWh (in 2009 dollars) based on an Page 4 2014 Integrated Resource Plan

Electric Power Research Institute (EPRI) report entitled Plant-Wide Performance and Cost Analysis of Ion Transport Membrane Based Oxy-Combustion Power Generation Systems, Product #1022301). Retrofit costs are unknown and would require considerable front-end engineering to determine. Meramec Unit 3 & 4 Boiler Replacement with CFB Boilers (Option B06) This option is not feasible because of the scope of additional pollutions control equipment anticipated to be needed to meet air emission limitations for PM, SO 2 and NO x. Replacing existing pulverized coal (PC) boilers with new circulating fluidized bed (CFB) boiler would require extensive demolition and modification to the existing units and would most likely result in a reduction in net capacity. A brief summary of issues is listed below: CFB boilers have a lower thermal efficiency than PC boilers. Based on previous Black & Veatch estimates, plant efficiency with CFB boilers is typically between 1.0 and 1.5 percentage points lower than that of PC fired facilities. A CFB boiler is larger than the existing PC boiler. The cost to modify the existing structure to accommodate CFB boilers would be prohibitive. Existing coal preparation equipment would have to be replaced and/or modified. New limestone handling and preparation equipment would be required, which would be expensive to site. Greenfield Pressurized Circulating Fluidized Bed (Option B13) At its current developmental status, this technology is not competitive compared with other technologies presented in this effort. No significant development advances have been substantiated in recent years. Limited success with pressurized fluidized bed combustion (PFBC) technology was realized with American Electric Power s Tidd Unit 1, which concluded operations in 1991. More recent pressurized fluidized bed (PFB) projects are currently in operation in Japan, such as Chugoku Electric Power Company s Ohsaki plant, Kyushu Electric Power s Karita plant, and Hokkaido Electric Power Company s Tomatouatsuma plant. Other commercial plants in operation in Europe include Fortum s Vartan plant and E.ON s Escatron plant. A number of operational and performance issues have been experienced with the greatest frequency of incidences occurring in the hot gas cleanup from the PFB to the gas turbine and gas turbine blade deposition, erosion and corrosion due to particulate carry-over in the hot gas path. Due to a relative lack of performance and cost sharing, Black & Veatch is unable to comment on the performance and cost of these projects. In the United States, recent efforts exploring Advanced PFBC, where the gas turbine is driven partially by hot gases from a pressurized circulating fluidized bed and partially 2014 Integrated Resource Plan Page 5

Chapter 6 Appendix A from a topping combustor that receives syngas from a fluidized bed carbonizer (often referred to as a gasifier), have resulted in little progress. In 1990, pilot scale component testing of Advanced PFBC components and systems integration began at the Wilsonville Power Systems Design Facility (PSDF). In 2000, after 170 hours of operation on coal, Foster Wheeler, the major equipment supplier, pulled out of the project and further testing was cancelled. No significant efforts have succeeded this work. Greenfield Pressurized Bubbling Fluidized Bed (Option B14) Similar to Option B13, Option B14 has not been proven competitive. Page 6 2014 Integrated Resource Plan

Compliance References 4 CSR 240-22.040(2)... 2 4 CSR 240-22.040(2)(C)... 2 4 CSR 240-22.040(2)(C)2... 2 2014 Integrated Resource Plan Page 7