ML073100989
| ML073100989 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 09/19/2007 |
| From: | Joseph Kelly John J. Kelly Consulting |
| To: | Bo Pham NRC/NRR/ADRO/DLR |
| References | |
| 72FR45075 | |
| Download: ML073100989 (34) | |
Text
IndianPointEIS -
Page 1 From:
"John Kelly" <jlejskelly@verizon.net>
To:
<IndianPointEIS@nrc.gov>
Date:
Wed, Sep 19, 2007 3:35 PM Gentlemen:
At the Indian Point Environmental Scoping Meeting today, I made a statement referencing a study of the impact on air pollution that would be caused by shutdown of the Indian Point plants. I gave a copy of the study to an NRC representative at the meeting and I have attached an electronic copy to this email for your information. Thank you.
John J Kelly John J Kelly John J Kelly Consulting Inc.
5 Parkwood Drive Garnerville, New York 10923-1013 Phone: 845 947 2095 Cell:845 519 7067 email: jlejskelly@verizon.net
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Creation Date Wed, Sep 19, 2007 3:34 PM From:
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Entergy Nuclear Indian Point 2, LLC and Entergy Nuclear Indian Point 3, LLC Village of Buchanan, New York Emissions Avoidance Study Prepared for Entergy Nuclear Northeast Prepared by TRC Environmental Corporation Lyndhurst, New Jersey Revised August 2002
C:\\temp\\Final Revised Indian Point Emissions Avoidance Report (rev 8.05.02).doc i
TABLE OF CONTENTS Section Page EXECUTIVE
SUMMARY
.......................................................................................................ES-1 1.0 Introduction......................................................................................................................1-1 2.0 Development of Generation Fuel Mix.............................................................................2-1 3.0 Emission Calculations......................................................................................................3-1 4.0 Replacement by Existing Sources....................................................................................4-1 5.0 Replacement by Existing Hudson Valley and New York City Sources..........................5-1 6.0 Costs for NOx Allowances...............................................................................................6-1 7.0 Potential Effects and Health Hazards from Studied Pollutants.......................................7-1 LIST OF APPENDICES Appendix A Emission Avoidance Calculations
Emissions Avoidance Study Entergy Nuclear Indian Point Units 2 and 3 C:\\temp\\Final Revised Indian Point Emissions Avoidance Report (rev 8.05.02).doc ES-1 EXECUTIVE
SUMMARY
In evaluating the impact of decommissioning Entergy Nuclear Indian Point 2, LLC and Entergy Nuclear Indian Point 3, LLC, the potential emissions increases associated with replacement electricity generation sources need to be evaluated. TRC evaluated several different scenarios to determine the impact on the air quality in New York State and the local area. Replacement sources examined included existing fossil generating stations located in the entire state of New York, the Hudson Valley and New York City. To provide context for interpreting the projected emissions increases, the increases for each replacement scenario are expressed as percent increases relative to regional and statewide emissions, and the health and welfare effects associated with each pollutant and the groups most susceptible to them have been tabulated.
When evaluating the emission increase from sources located throughout the state, it was necessary to develop a generation fuel mix. This consisted of the anticipated mix of coal, gas, oil etc. expected for the replacement generation sources during the years 2002 through 2005.
Data from the current New York State Energy Plan, dated December 2001, serves as the basis for the existing and projected future generation fuel mix applied in the analysis Indian Point Units 2 and 3 have an average net maximum capacity of 983.7 and 989 Megawatts (MW), respectively, based on information provided to the Independent System Operator (ISO).
Based on a 90% capacity factor, the annual generating capacity of these two units is 15,552,767 Megawatt-hours (MWh), which represents approximately 10% of the states total generation.
The first set of calculations presented assumes that the demand is met by increased operation of existing New York State fossil stations, so that a generation mix of coal, oil and natural gas in the years 2002 through 2005 replaces the generating capacity of Units 2 and 3. To establish a baseline, emissions estimates for the existing units are based on a combination of data from the US Environmental Protection Agency (EPA) utility Emissions & Generation Resource Integrated Database 2000 (EGRID2000), Version 2.0 and the US EPA Document AP-42 emission factors for stationary sources. When more than one emission factor was available, the lower emission factor was chosen. This approach represents a conservative estimate of the potential increase.
Since it is reasonable to assume that the majority of lost output would be made up by increased generation of units nearest to the New York City / Westchester load pocket, replacement by the four large fossil power stations in the Hudson Valley (Bowline Point, Lovett, Danskammer and Roseton) and the existing units in New York City was also studied. For each of these plants,
Emissions Avoidance Study Entergy Nuclear Indian Point Units 2 and 3 C:\\temp\\Final Revised Indian Point Emissions Avoidance Report (rev 8.05.02).doc ES-2 baseline emissions and generation were obtained from the EGRID2000 database. Data for the most recent year included in this database (1998) was utilized in this study.
The first task in this set of calculations assumed replacement by the four large plants in the Hudson Valley: Bowline Point, Lovett, Danskammer, and Roseton. These plants utilize boilers that are fired with coal, No. 6 residual oil and natural gas. These plants currently operate at capacity factors ranging from 32% to 58%. These four stations would need to operate at over 90% capacity factor in order to make up the lost generation from Indian Point 2 and 3. It has been determined that these plants are already operating more during the ozone season (May through September) based on the EGRID2000 data; thus the increased demand during the ozone season cannot be met by these four stations alone.
The next situation that was evaluated was the replacement by the 14 existing power plants in the five boroughs of New York City. The replacement demand is approximately 33% of the available generation from the New York City plants. In order to determine the generation and emissions increases, it was assumed that the total fuel and plant mix from these plants would remain constant, except for the plants that could not meet this increase. Since the current generation for all of these facilities combined is roughly equal to that of Indian Point 2 and 3, the emission rates in New York City would nearly double in order to make up the lost generation.
The final scenario of replacement by existing sources that was evaluated was the replacement by a combination of the four Hudson Valley plants and the plants located in New York City. For the purposes of this evaluation, it was assumed that half of the make-up generation would come from the four Hudson Valley Plants and the other half would come from the plants in New York City, with the increase determined by assuming that the total fuel and plant mix from these two sets of plants would remain constant, except for the plants that could not meet this increase.
The increases from each of the above-described scenarios were compared to the current emissions from the power generation industry in New York. The results are presented in the table below:
Emissions Avoidance Study Entergy Nuclear Indian Point Units 2 and 3 C:\\temp\\Final Revised Indian Point Emissions Avoidance Report (rev 8.05.02).doc ES-3 Replacement Generation Sources CO2 SO2 NOx PM-10 CO VOC New York State: 2002 Generation Mix 20.20%
23.81%
21.58%
22.69%
17.76%
17.28%
New York State: 2003 Generation Mix 20.12%
23.54%
21.42%
22.51%
17.80%
17.34%
New York State: 2004 Generation Mix 19.41%
21.10%
20.03%
21.11%
9.28%
18.36%
New York State: 2005 Generation Mix 21.05%
20.06%
20.66%
22.14%
11.66%
23.44%
Hudson Valley Power Plants 21.08%
18.77%
20.80%
52.59%
74.31%
56.97%
New York City Power Plants 18.10%
2.52%
15.02%
9.28%
17.24%
16.83%
Hudson Valley and New York City 19.83%
11.32%
18.89%
28.49%
42.02%
34.63%
Note: Total increase is compared to utility source emissions only in New York. Baseline data obtained from USEPAs EGRID2000 database (1998)
In addition to evaluating the increase in emissions, TRC prepared a matrix summarizing the potential effects and health hazards from these pollutants. Currently, Westchester County is classified as a non-attainment area for ozone. Ozone can cause lung irritation, permanent lung damage, aggravated asthma, reduced lung capacity, pneumonia and bronchitis. Persons that are most susceptible to the negative effects of ozone are those with respiratory illnesses, outdoor workers, and children. Ozone also increases the susceptibility of plants to disease, thus reducing crop and forest yields.
The entire state of New York is located in the Ozone Transport Region (OTR), which requires that new sources of NOx and VOC be subject to Lowest Achievable Emission Rates (LAER) and emissions offsets. In essence, this massive increase in generation by existing sources is comparable to constructing one large new source without subjecting it to these current applicable regulations since the majority of these existing sources were constructed prior to the new source review requirements and were not subject to LAER and offset requirements. The increase in NOx and VOC, the precursors to ozone, would constitute a significant setback in the areas efforts to meet progress goals toward ozone attainment status in the near future. In order to reach attainment, the area needs to further reduce emissions in the area as opposed to unnecessarily increasing these emission rates.
The attached matrix outlines the effects of all criteria pollutants and the groups that are most greatly impacted by them. As shown with carbon monoxide and ozone, these pollutants affect all people, regardless of age and current health, in addition to the vegetation in the area.
Emissions Avoidance Study Entergy Nuclear Indian Point Units 2 and 3 C:\\temp\\Final Revised Indian Point Emissions Avoidance Report (rev 8.05.02).doc ES-4 Regulatory Impacts and Effects of Major Air Pollutants Pollutant NAAQS Attainment Status for New York State Basis for NAAQS Most Susceptible Population Groups Additional Impacts SO2 Attainment Temporary breathing difficulty Respiratory illness Aggravates existing Heart Disease Asthmatics, Children, Elderly, Persons with Heart or Lung Disease Precursor to acid rain formation Visibility impairment from Sulfate Particles (PM-2.5)
Aesthetics damage due to accelerated building decay Acidification of lakes due to Atmospheric Deposition Soil degradation due to Atmospheric Deposition NOx Attainment Damage to lung tissue Respiratory illnesses - Bronchitis Reduction in lung function Children, Asthmatics, Outdoor Workers Precursor to ground-level Ozone (Smog)
Precursor to acid rain formation Water quality deterioration (Oxygen depletion)
Visibility impairment PM-10 Attainment for all Counties with exception of New York County Aggravated Asthma Chronic Bronchitis Decreased lung function Premature Death Persons with Heart Disease or Influenza, Asthmatics, Children, Elderly Major cause of reduced visibility (Haze)
Aesthetics damage due to stains from soot Acidification of lakes due to Atmospheric Deposition Soil degradation due to Atmospheric Deposition CO Attainment with exception of Metropolitan New York City (recently redesignated as attainment by USEPA, but New York State redesignation pending)
Cardiovascular effects Vision problems Reduced ability to work and learn Death (extremely high levels)
Persons with Heart or Lung Disease Ozone Attainment for all counties with exceptions of New York State Metropolitan Areas and Long Island, but entire state is located within northeast Ozone Transport Region Lung irritation (wheezing, coughing)
Permanent lung damage Aggravated Asthma Reduced lung capacity Pneumonia and Bronchitis Persons with respiratory illnesses, Children, Outdoor workers Increases susceptibility of plants to disease Reduces crop and forest yields Aesthetics damage due to damage to leaves and trees Damages rubber and fabrics Reduced visibility VOC Not Applicable Not Applicable Not Applicable Precursor to ground-level Ozone (Smog)
Damage to plants CO2 Not Applicable Not Applicable Not Applicable Contributes to Global Warming
Emissions Avoidance Study Entergy Nuclear Indian Point Units 2 and 3 C:\\temp\\Final Revised Indian Point Emissions Avoidance Report (rev 8.05.02).doc 1-1
1.0 INTRODUCTION
TRC Environmental Corporation (TRC) was retained by Entergy Nuclear Operations, Inc.
(Entergy Nuclear) to perform an assessment of the potential increase in emissions of criteria pollutants from non-nuclear generating assets within New York State in the event that the Indian Point 2 and 3 are decommissioned. The assessment assumed that additional non-nuclear generation would be required within the State of New York to replace the electric generating output of Indian Point Units 2 and 3 and evaluated increase in annual potential emissions for the period of 2002 through 2005.
The evaluation performed by TRC included the following activities:
- Development of a generation fuel mix (i.e., coal, gas, oil, etc.) assumption for use in developing the avoided emissions calculations. TRC utilized data from the current New York State Energy Plan, dated December 2001, as the basis for the existing and projected future generation fuel mix applied in the analysis.
- Estimation of projected criteria pollutant emissions for the non-nuclear generating assets which would be required to replace the electric generating output of Entergy Nuclears Indian Point Units 2 and 3 in the event that the Indian Point Nuclear Generating Station is decommissioned. The emission calculations are based on a projected 90% capacity factor for Units 2 and 3 through the study period of 2002 to 2005. Indian Point Units 2 and 3 have an average net maximum capacity, as reported to the Independent System Operator, of 983.7 Megawatts (MW) and 989 MW, respectively. The annual generating capacity of these two units is 15,548,036 Megawatt-hours (MWh) per year at a 90%
capacity factor, representing approximately 10% of the states total generation.
Calculations of replacement generation emissions were based upon the generation fuel mix discussed above, assuming that the lost generation would be made up by a mix of existing in-state fossil (coal/oil/gas) fired units. Emissions estimates for the existing units were based on a combination of data from a US Environmental Protection Agency (EPA) utility emissions database and the US EPA Document AP-42 emission factors for stationary sources. Replacement by the sources located in the Hudson Valley and New York City was also evaluated as an option.
- Preparation of a matrix of regulatory impacts and effects of major air pollutants.
- Evaluation of additional costs for NOx allowances.
TRCs findings relative to the above activities are summarized on the following pages.
Emissions Avoidance Study Entergy Nuclear Indian Point Units 2 and 3 C:\\temp\\Final Revised Indian Point Emissions Avoidance Report (rev 8.05.02).doc 2-1 2.0 DEVELOPMENT OF GENERATION FUEL MIX For the purpose of this study, the future fuel mix information was obtained from the New York State Energy Plan, dated December 2001. This plan provides future estimates of generation by fuel type for the years 2002 through 2020. The fuel types listed include natural gas, oil, coal, nuclear and hydro, as well as other and net imports. The projected Gigawatt-hours (GWh) listed in the plan for 2002 through 2005 were used in this study and are summarized below:
Projected Generation - GWh Generation Fuel 2002 2003 2004 2005 Natural Gas 24,706 25,628 34,115 54,902 Oil 24,774 24,509 19,212 9,384 Coal 29,380 29,295 28,030 17,934 Nuclear 32,563 32,559 32,662 32,558 Hydro 29,109 29,090 29,111 29,011 Other 2,866 3,004 3,150 3,283 Net Imports 18,799 19,463 18,747 19,731 TOTAL 162,197 163,548 165,027 166,803 Source: New York State Energy Plan, Table 9 - Reference Resource Case - Generation by Fuel Type for the New York Electricity System, December 2001 Projected Generation - Percent of Total Generation Fuel 2002 2003 2004 2005 Natural Gas 15.2%
15.7%
20.7%
33.0%
Oil 15.3%
15.0%
11.6%
5.6%
Coal 18.1%
17.9%
17.0%
10.8%
Nuclear 20.1%
19.9%
19.8%
19.6%
Hydro 17.9%
17.8%
17.6%
17.4%
Other 1.8%
1.8%
1.9%
2.0%
Net Imports 11.6%
11.9%
11.4%
11.6%
TOTAL 100%
100%
100%
100%
Source: New York State Energy Plan, Table 9 - Reference Resource Case - Generation by Fuel Type for the New York Electricity System, December 2001
Emissions Avoidance Study Entergy Nuclear Indian Point Units 2 and 3 C:\\temp\\Final Revised Indian Point Emissions Avoidance Report (rev 8.05.02).doc 3-1 3.0 EMISSION CALCULATIONS Using the projected generation mix provided above, criteria emissions were calculated for non-nuclear electricity generation, which would be required in the event that Entergys Indian Point Nuclear Generating Station is decommissioned. As stated, all calculations for Units 2 & 3 at Indian Point are based on a 90% capacity factor. As provided by Elise N. Zoli, Esq. of Goodwin Procter, LLP, Entergys Counsel, Units 2 and 3 have an average net maximum capacity of 983.7 MW and 989 MW.
Operating at a 90% capacity factor, Units 2 and 3 are capable of generating 15,548,036 MWh annually. This accounts for approximately 10% of the states total generation. If Indian Point Nuclear Generating Station were to be decommissioned, there are numerous ways that the lost generation from Units 2 and 3 could be replaced. The first possibility that was examined was the replacement of Units 2 and 3 by the existing generation mix. This case yields the highest increase in emissions since it assumes older fossil fuel fired facilities, approximately 40% of which are coal, are used to replace the generating capacity of Units 2 and 3. The existing sources that are in the generation fuel mix include natural gas, oil, coal, nuclear, hydro and other. For the purpose of this study, it was assumed that Units 2 and 3 would be replaced by natural gas, oil and coal fired facilities only. This unit mix would likely be used to replace lost generation if Indian Point 2 and 3 were not available during a low-to moderate-demand period (during mild weather). Nuclear, hydro and other were not included in the calculations. Hydro was not included because it is not possible to increase the capacity of existing hydropower sources.
Emissions were not calculated for other sources, which account for less than 2% of the states total capacity. The type of other sources is unknown; therefore it was not possible to develop emission factors for these sources.
Replacement by the four large fossil fuel power stations in the Hudson Valley: Bowline Point, Lovett, Danskammer and Roseton, and replacement by existing units in New York City were also studied. It is likely that the majority of the replacement generation would come from these sources. Three combinations of these plants were examined. The first possible scenario assumed that the Hudson Valley plants were the sole replacement source. The second scenario assumed that the New York City plants would replace all the lost generation. Finally, it was assumed that the Hudson Valley plants would account for half of the required generation and the New York City plants would account for the other half.
Emissions Avoidance Study Entergy Nuclear Indian Point Units 2 and 3 C:\\temp\\Final Revised Indian Point Emissions Avoidance Report (rev 8.05.02).doc 4-1 4.0 REPLACEMENT BY EXISTING SOURCES Emission factors were obtained from the U.S. EPAs Emissions & Generation Resource Integrated Database 2000 (EGRID2000), Version 2.0. The most recent year included in this database is 1998; therefore, this data was utilized in this study. Data provided included total net generation, total state electricity usage, net imports, total CO2, NOx and SO2 emissions, and emission factors in pounds of pollutant per MWh separated by fuel type. For the remaining criteria pollutants (CO, VOC, and PM-10), emission factors were obtained from the U.S. EPAs AP-42 document. For coal-fired units, emission factors for dry-bottom pulverized bituminous coal boilers equipped with electrostatic precipitators were used. PM-10 emissions include both filterable and condensable particulates, assuming that the coal has an ash content of 10%. The majority of emission factors for coal were given in pounds of pollutant per ton of coal. Based on an assumed heating value of 12,000 Btu/lb for the coal, these factors were then converted to pound per million Btu, which was then converted to pound per MWh based on the heat rate that was obtained from the data for the other pollutants listed in the EGRID2000 database.
For oil and natural gas, emission factors for external combustion (boilers) and internal combustion (i.c.engines and combustion turbines) were examined, since it is unknown what the breakdown of sources is. The lowest emission factor for each pollutant was chosen to yield a conservative (low) estimate of displaced emissions. It should be noted that the range in emission factors varied mostly with fuel type, as opposed to combustion source type. After evaluating the various emission factors, those for combustion turbines were used to yield a lower increase in annual emissions. These emission factors were given in pounds of pollutant per million Btu.
Based on the data provided in EGRID2000, the emission factors were converted to pounds per MWh. A summary of the estimated additional emissions related to the replacement of Indian Point by existing sources applied to the projected future generation mix is presented in the following table:
Additional Annual Emissions with Replacement Power from Generation Fuel Mix Pollutant 2002 2003 2004 2005 CO2 (tons) 13,941,742 13,888,209 13,396,046 14,527,670 SO2 (tons) 75,665 74,794 67,048 63,747 NOx (tons) 23,140 22,971 21,480 22,152 PM-10 (tons) 1,890 1,875 1,758 1,844 CO (tons) 1,145 1,148 1,201 1,508 VOC (tons) 145 146 155 197
Emissions Avoidance Study Entergy Nuclear Indian Point Units 2 and 3 C:\\temp\\Final Revised Indian Point Emissions Avoidance Report (rev 8.05.02).doc 5-1 5.0 REPLACEMENT BY EXISTING HUDSON VALLEY AND NEW YORK CITY SOURCES The next section of the evaluation assumed that the four large plants in the Hudson Valley, and the plants in New York City would replace the generation from Indian Point, as opposed to statewide facility-type replacement. For each of these subgroups, baseline emissions were obtained from EGRID2000. The most recent year included in this database is 1998; therefore, this data was utilized in this study. Data provided included total net generation separated by fuel type, total CO2, NOx and SO2 emissions, and emission factors in pounds of pollutant per MWh separated by fuel type.
The first task assumed replacement by the four large plants in the Hudson Valley: Bowline Point, Lovett, Danskammer, and Roseton. These plants utilize boilers that are fired with No. 6 residual oil and natural gas. Lovett and Danskammer also have the ability to fire coal, and PM-10 emission factors while burning coal were obtained from the facilities Title V permits. For the remaining criteria pollutants (CO, VOC, and PM-10), emission factors were obtained from the U.S. EPAs AP-42 document for external combustion sources. A combined emission factor for each of the pollutants was developed for each facility based on the source of generation (coal/oil/gas).
Based on the data provided in EGRID2000, it is known that these plants currently operate at capacity factors ranging from 32% to 58%. When evaluating the available generation, it was assumed that each of these plants could operate at a 90% capacity factor. Assuming a 100%
capacity factor is not realistic and does not allow for necessary shutdowns required for maintenance to ensure the equipment is functioning properly. Based on the generation from 1998 provided in EGRID2000, and the total generation based on a 90% capacity factor, the combined available generation from these four plants is 15,374,598 MWh. This is only 99% of Indian Points current generation of 15,552,767. Therefore, more than just these four plants would be required to meet the increased demand that would result from Indian Point Units 2 and 3 being decommissioned. The following tables summarize the total emission increases from increasing the operating capacity to 90% for each of these plants.
Emissions Avoidance Study Entergy Nuclear Indian Point Units 2 and 3 C:\\temp\\Final Revised Indian Point Emissions Avoidance Report (rev 8.05.02).doc 5-2 Additional Annual Emissions with Replacement Power from Hudson Valley Plants Plant Annual CO2 (tons)
Annual SO2 (tons)
Annual NOx (tons)
Annual PM-10 (tons)
Annual CO (tons)
Annual VOC (tons)
Annual Hg (pounds)
Bowline Point 5,266,203 3,919 7,619 1,114 2,699 217 0
Lovett 1,600,331 6,606 3,237 212 292 26 26 Danskammer 1,620,126 7,651 3,536 229 207 22 70 Roseton 6,062,113 41,468 7,913 2,825 1,596 215 0
Total 14,548,772 59,644 22,305 4,380 4,794 480 96 Facility Specific Percent Emissions Increase from Replacement Power from Hudson Valley Plants Plant Annual CO2 Annual SO2 Annual NOx Annual PM-10 Annual CO Annual VOC Annual Hg Bowline Point 178%
179%
178%
178%
178%
178%
0%
Lovett 71%
71%
71%
71%
71%
71%
71%
Danskammer 55%
55%
55%
55%
55%
55%
55%
Roseton 168%
168%
168%
168%
168%
168%
0%
Total 123%
119%
112%
145%
147%
147%
58%
As shown in the second table, the increase in the NOx emissions during the ozone season (May -
September) is not as great as the annual increase. This shows that these plants are already operating more during this season. In addition to the annual average availability of these plants being only 99% of the Indian Point demand, the increased replacement demand during the ozone season will not be able to be met by these four plants alone.
The next situation that was evaluated was the replacement by the 14 existing power plants in the five boroughs of New York City. It should be noted that the recently installed NYPA peaker turbines have not been included in this analysis, since they were installed after the most recent version of EGRID2000 was updated (1998 emissions data.
Similar to the Hudson Valley plants, emissions data was obtained from EGRID2000 for CO2, SO2 and NOx. Emission factors for PM, CO, and VOC were obtained from U.S. EPAs AP-42.
Emission factors for external combustion (boilers) and internal combustion (i.c. engines and combustion turbines) were examined, since facility specific emission rates are not provided by EGRID2000. The lowest emission factor for each pollutant was chosen to yield a conservative (low) estimate of displaced emissions. It should be noted that the range in emission factors varied mostly with fuel type, as opposed to combustion source type. After evaluating the various emission factors, those for combustion turbines were used to yield a lower increase in annual
Emissions Avoidance Study Entergy Nuclear Indian Point Units 2 and 3 C:\\temp\\Final Revised Indian Point Emissions Avoidance Report (rev 8.05.02).doc 5-3 emissions. These emission factors were given in pounds of pollutant per million Btu. Based on the data provided in EGRID2000, the emission factors were converted to pounds per MWh.
The available generation from the New York City plants was again determined based on a capacity factor of 90%. The replacement demand, 15,552,767 MWh, is approximately 33% of the available generation from these plants. In order to determine how much each plant would need to increase its generation to meet the demand of Units 2 and 3 at Indian Point, it was assumed that the total fuel and plant mix from these plants would remain constant, except for the plants that could not meet this increase. The Bronx Zoo, Brooklyn Navy Yard and the JFK International Airport Cogeneration facilities were increased to their maximum generation at 90%
capacity factor while the remainder of the facilities kept the same mix. The following table provides the increased emissions.
Additional Annual Emissions with Replacement Power from New York City Plants Plant Annual CO2 (tons)
Annual SO2 (tons)
Annual NOx (tons)
Annual PM-10 (tons)
Annual CO (tons)
Annual VOC (tons)
Bronx Zoo 3,833 1
3 0.2 0.4 0.1 Ravenswood 3,290,850 1,204 3,808 195.5 340.2 46.2 Charles Poletti 2,467,169 4,069 3,650 178.1 80.0 10.5 JFK Cogen 173,088 0
114 9.9 22.4 3.0 Far Rockaway 256,091 2
232 14.2 32.3 4.4 Astoria 3,773,229 1,785 4,947 225.8 370.6 51.1 Arthur Kill 1,021,253 7
925 56.9 129.2 17.7 East River 436,741 508 783 29.0 27.1 3.8 Waterside 277,744 3
167 15.0 34.0 5.0 Hudson Ave 1,832 4
10 0.1 0.0 0.0 Brooklyn Navy Yard 437,418 4
34 24.1 54.1 7.1 Warbasse Cogen 69,560 10 45 4.1 8.0 1.1 Gowanus 176,550 344 976 13.3 3.6 0.5 Narrows 108,814 81 412 6.9 9.8 1.4 Total 12,494,172 8,020 16,107 773 1,112 142 Once the increase in emissions was calculated, the percent increase from current generation was also calculated. Since the current generation for all of these facilities combined is 16,887,894 MWh, just slightly over the generation of Indian Points Units 2 and 3, all of the emission rates are nearly double what they are currently. The results are summarized in the tables below.
Emissions Avoidance Study Entergy Nuclear Indian Point Units 2 and 3 C:\\temp\\Final Revised Indian Point Emissions Avoidance Report (rev 8.05.02).doc 5-4 Facility Specific Percent Emissions Increase from Replacement Power from New York City Plants Plant Annual CO2 Annual SO2 Annual NOx Annual PM-10 Annual CO Annual VOC Bronx Zoo 39%
39%
39%
39%
39%
39%
Ravenswood 106%
106%
106%
106%
106%
106%
Charles Poletti 106%
106%
106%
106%
106%
106%
JFK Cogen 68%
0%
68%
68%
68%
68%
Far Rockaway 106%
159%
106%
106%
106%
106%
Astoria 106%
106%
106%
106%
106%
106%
Arthur Kill 106%
134%
106%
106%
106%
106%
East River 106%
106%
106%
106%
106%
106%
Waterside 106%
96%
106%
106%
106%
106%
Hudson Ave 105%
105%
105%
106%
106%
106%
Brooklyn Navy Yard 47%
64%
46%
47%
47%
47%
Warbasse Cogen 106%
107%
106%
106%
106%
106%
Gowanus 106%
106%
106%
106%
106%
106%
Narrows 106%
106%
106%
106%
106%
106%
Total 101%
106%
105%
101%
99%
93%
The final replacement scenario that was evaluated was the replacement by a combination of the four Hudson Valley plants and the plants located in New York City. For the purposes of this evaluation, it was assumed that half of the make-up generation, 7,776,383 MWh, would come from the four Hudson Valley Plants and the other half would come from the plants in New York City. As in the evaluation of the emission increase from the New York City plants only, the increase of each of the plants was determined by assuming that the total fuel and plant mix from these two sets of plants would remain constant, except for the plants that could not meet this increase. The Bronx Zoo, Brooklyn Navy Yard and Danskammer were increased to their maximum generation at 90% capacity factor while the remainder of the facilities kept the same mix. The following table provides the increased emissions:
Emissions Avoidance Study Entergy Nuclear Indian Point Units 2 and 3 C:\\temp\\Final Revised Indian Point Emissions Avoidance Report (rev 8.05.02).doc 5-5 Additional Annual Emissions with Replacement Power from Hudson Valley and New York City Plants Plant Annual CO2 (tons)
Annual SO2 (tons)
Annual NOx (tons)
Annual PM-10 (tons)
Annual CO (tons)
Annual VOC (tons)
Annual Hg (pounds)
Bowline Point 2,005,749 1,493 2,902 424 1,028 83 0
Lovett 1,532,411 6,326 3,100 203 279 25 25 Danskammer 1,620,126 7,651 3,536 229 207 22 70 Roseton 2,451,486 16,769 3,200 1,142 646 87 0
Bronx Zoo 3,833 1
3 0.2 0.4 0.1 Ravenswood 1,526,271 558 1,766 90.7 157.8 21.4 Charles Poletti 1,144,254 1,887 1,693 82.6 37.1 49 JFK Cogen 125,849 0
83 7.2 16.3 2.2 Far Rockaway 118,773 1
108 6.6 15.0 2.1 Astoria 1,749,995 828 2,294 104.7 171.9 23.7 Arthur Kill 473,649 3
429 26.4 59.9 8.2 East River 202,557 235 363 13.5 12.6 1.8 Waterside 128,816 1
78 7.0 15.8 2.3 Hudson Ave 850 2
5 0.1 0.0 0.0 Brooklyn Navy Yard 437,418 4
34 24.1 54.1 7.1 Warbasse Cogen 32,262 4
21 1.9 3.7 0.5 Gowanus 81,883 160 453 6.2 1.7 0.2 Narrows 50,467 38 191 3.2 4.5 0.6 Total 13,686,648 35,961 20,258 2,373 2,710 292 94 Again, once these emissions were calculated, the percent increase for each of these plants and the combined increase was calculated. The results are presented in the following table.
Emissions Avoidance Study Entergy Nuclear Indian Point Units 2 and 3 C:\\temp\\Final Revised Indian Point Emissions Avoidance Report (rev 8.05.02).doc 5-6 Facility Specific Percent Emissions Increase from Replacement Power from Hudson Valley and New York City Plants Plant Annual CO2 (tons)
Annual SO2 (tons)
Annual NOx (tons)
Annual PM-10 (tons)
Annual CO (tons)
Annual VOC (tons)
Annual Hg (pounds)
Bowline Point 68%
68%
68%
68%
68%
68%
0%
Lovett 68%
68%
68%
68%
68%
68%
68%
Danskammer 55%
55%
55%
55%
55%
55%
55%
Roseton 68%
68%
68%
68%
68%
68%
0%
Bronx Zoo 39%
39%
39%
39%
39%
39%
Ravenswood 49%
49%
49%
49%
49%
49%
Charles Poletti 49%
49%
49%
49%
49%
49%
JFK Cogen 50%
0%
50%
49%
49%
49%
Far Rockaway 49%
74%
49%
49%
49%
49%
Astoria 49%
49%
49%
49%
49%
49%
Arthur Kill 49%
62%
49%
49%
49%
49%
East River 49%
49%
49%
49%
49%
49%
Waterside 49%
44%
49%
49%
49%
49%
Hudson Ave 49%
49%
49%
49%
49%
49%
Brooklyn Navy Yard 47%
64%
46%
47%
47%
47%
Warbasse Cogen 49%
50%
49%
49%
49%
49%
Gowanus 49%
49%
49%
49%
49%
49%
Narrows 49%
49%
49%
49%
49%
49%
Total 57%
62%
57%
58%
63%
62%
58%
Emissions Avoidance Study Entergy Nuclear Indian Point Units 2 and 3 C:\\temp\\Final Revised Indian Point Emissions Avoidance Report (rev 8.05.02).doc 6-1 6.0 COSTS FOR NOx ALLOWANCES Lastly, the increased costs for NOx allowances associated with additional ozone season (May -
September) NOx emissions were evaluated. The March 2001 New York Independent System Operator report provided estimated costs for one ton of NOx in the years 2001, 2003 and 2005.
Costs for the years 2002 and 2004 were graphically interpolated. Based on the scenarios presented above, the following table shows the additional ozone season emissions and total costs for the NOx emissions in the next four years.
It should be noted that it is likely that there is not enough generation available from the Hudson Valley plants during the ozone season to meet the lost generation of Indian Point Units 2 and 3.
Data obtained from the EGRID database indicates that the ozone season NOx emissions are nearly half of the annual emissions in some cases. Some of the New York City plants may not be able to meet the demand either. However, a combination of these plants would be available during that time and the ozone season NOx emissions presented in the table below are based on a fraction of the annual emissions. These ozone season emissions are reasonable estimates provided the required generation was replaced by sources similar to those in the Hudson Valley and New York City.
Projected NOx Allowance Costs Replacement Source NOx tons 2002 Cost 2003 Cost 2004 Cost 2005 Cost 2002 Fuel Mix 9,725
$21,881,250 2003 Fuel Mix 9,657
$28,584,720 2004 Fuel Mix 9,062
$28,001,580 2005 Fuel Mix 9,411
$29,832,870 Hudson Valley 5,613
$12,629,250
$16,614,480
$17,344,170
$17,793,210 New York City 3,580
$8,055,000
$10,596,800
$11,062,200
$11,348,600 Hudson Valley &
NYC 4,846
$10,903,500
$14,344,160
$14,974,140
$15,361,820
Emissions Avoidance Study Entergy Nuclear Indian Point Units 2 and 3 C:\\temp\\Final Revised Indian Point Emissions Avoidance Report (rev 8.05.02).doc 7-1 7.0 POTENTIAL EFFECTS AND HEALTH HAZARDS FROM STUDIED POLLUTANTS In addition to evaluating the increase in emissions, TRC prepared a matrix summarizing the potential effects and health hazards from these pollutants. Currently, Westchester County is classified as a non-attainment area for ozone. High levels of ozone can cause lung irritation, permanent lung damage, aggravated asthma, reduced lung capacity, pneumonia and bronchitis.
Persons that are most susceptible to the negative effects of ozone are those with respiratory illnesses, outdoor worker, and children. Ozone also increases the susceptibility of plants to disease, thus reducing crop and forest yields.
The entire state of New York is located in the Ozone Transport Region (OTR), which requires that new sources of NOx and VOC be subject to Lowest Achievable Emission Rates (LAER) and emissions offsets. These regulations are subject to facilities constructed after August 9, 1984. In essence, this massive increase in generation by existing sources is comparable to constructing one large new source without subjecting it to these current applicable regulations. The increase in NOx and VOC, the precursors to ozone, will likely mean that the area will not reach attainment status in the near future. In order to reach attainment, the area needs to further reduce emissions in the area as opposed to unnecessarily increasing these emission rates.
The matrix outlines the effects of all criteria pollutants and the groups that are most greatly impacted by them. As shown with carbon monoxide and ozone, these pollutants affect all people, regardless of age and current health, in addition to the vegetation in the area.
Emissions Avoidance Study Entergy Nuclear Indian Point Units 2 and 3 C:\\temp\\Final Revised Indian Point Emissions Avoidance Report (rev 8.05.02).doc 7-2 Regulatory Impacts and Effects of Major Air Pollutants Pollutant NAAQS Attainment Status for New York State Basis for NAAQS Most Susceptible Population Groups Additional Impacts SO2 Attainment Temporary breathing difficulty Respiratory illness Aggravates existing Heart Disease Asthmatics, Children, Elderly, Persons with Heart or Lung Disease Precursor to acid rain formation Visibility impairment from Sulfate Particles (PM-2.5)
Aesthetics damage due to accelerated building decay Acidification of lakes due to Atmospheric Deposition Soil degradation due to Atmospheric Deposition NOx Attainment Damage to lung tissue Respiratory illnesses - Bronchitis Reduction in lung function Children, Asthmatics, Outdoor Workers Precursor to ground-level Ozone (Smog)
Precursor to acid rain formation Water quality deterioration (Oxygen depletion)
Visibility impairment PM-10 Attainment for all Counties with exception of New York County Aggravated Asthma Chronic Bronchitis Decreased lung function Premature Death Persons with Heart Disease or Influenza, Asthmatics, Children, Elderly Major cause of reduced visibility (Haze)
Aesthetics damage due to stains from soot Acidification of lakes due to Atmospheric Deposition Soil degradation due to Atmospheric Deposition CO Attainment with exception of Metropolitan New York City Cardiovascular effects Vision problems Reduced ability to work and learn Death (extremely high levels)
Persons with Heart or Lung Disease Ozone Attainment for all counties with exceptions of New York State Metropolitan Areas and Long Island Lung irritation (wheezing, coughing)
Permanent lung damage Aggravated Asthma Reduced lung capacity Pneumonia and Bronchitis Persons with respiratory illnesses, Children, Outdoor workers Increases susceptibility of plants to disease Reduces crop and forest yields Aesthetics damage due to damage to leaves and trees Damages rubber and fabrics Reduced visibility VOC Not Applicable Not Applicable Not Applicable Precursor to ground-level Ozone (Smog)
Damage to plants CO2 Not Applicable Not Applicable Not Applicable Contributes to Global Warming
APPENDIX A EMISSION AVOIDANCE CALCULATIONS
Entergy - Indian Point Emission Avoidance Study Gneration Fuel Mix Data - from Table 9 from New York State Energy Plan Generation Fuel In GWh 2002 2003 2004 2005 Natural Gas 24,706 25,628 34,115 54,902 Oil 24,774 24,509 19,212 9,384 Coal 29,380 29,295 28,030 17,934 Nuclear 32,563 32,559 32,662 32,558 Hydro 29,109 29,090 29,111 29,011 Other 2,866 3,004 3,150 3,283 Net Imports 18,799 19,463 18,747 19,731 TOTAL - calc 162,197 163,548 165,027 166,803 TOTAL - given 162,207 163,549 165,028 166,442 Note: Total provided in source table does not correspond to the arithmetic total of GWh produced for each of the fuels. The calculated total was used in the calculation of the percentages in the following table.
Generation Fuel In Percent of Total 2002 2003 2004 2005 Natural Gas 15.2%
15.7%
20.7%
33.0%
Oil 15.3%
15.0%
11.6%
5.6%
Coal 18.1%
17.9%
17.0%
10.8%
Nuclear 20.1%
19.9%
19.8%
19.6%
Hydro 17.9%
17.8%
17.6%
17.4%
Other 1.8%
1.8%
1.9%
2.0%
Net Imports 11.6%
11.9%
11.4%
11.6%
TOTAL 100.0%
100.0%
100.0%
100.0%
Note: Above Information Obtained from Table 9 from the New York State Energy Plan Generation Fuel In Percent of Total 2002 2003 2004 2005 Natural Gas 15.2%
15.7%
20.7%
32.9%
Oil 15.3%
15.0%
11.6%
5.6%
Coal 18.1%
17.9%
17.0%
10.8%
Nuclear 20.1%
19.9%
19.8%
19.5%
Hydro 17.9%
17.8%
17.6%
17.4%
Other 1.8%
1.8%
1.9%
2.0%
Net Imports 11.6%
11.9%
11.4%
11.8%
TOTAL 100.0%
100.0%
100.0%
100.0%
Note: Above Percentages Calculated from given Generation Fuel Mix TRC Environmental Corp.
Generation Mix Page 1 of 1
Entergy - Indian Point Emission Avoidance Study r
d A
1998 Data - E-Grid Capacity 38,519 MW Heat Input 933,615,646 MMBtu Generation 144,795,255 (MWh)
Fuel Fuel Mix %
MWh Indian Point - Units 2 & 3 Coal 17.0%
24,401,936 MWh 15,552,767 Oil 10.4%
14,939,368
% of Total 10.8%
Gas 29.7%
42,689,444 Nuclear 21.8%
31,313,708 Other Fossil 0.4%
587,139 Biomass 1.3%
1,803,829 Hydro 19.5%
28,065,751 TOTAL 100.0%
143,801,175 FOSSIL COAL OIL G
output input output input output input output Pollutant tons lbs/MWh lbs/MMBtu lbs/MWh lbs/MMBtu lbs/MWh lbs/MMBtu lbs/MWh Annual CO2 69,010,726 1658.57 151.68 2295.74 202.42 1753.03 150.88 1234.69 Annual SO2 317,766 7.57 0.69 19.06 1.68 7.94 0.68 0.43 Annual NOx 107,232 2.56 0.23 4.87 0.43 2.55 0.22 1.15 Ozone NOx 50,339 2.52 0.21 4.88 0.41 2.54 0.21 1.23 PM-10*
0.48 0.042 0.14 0.012 0.069 CO*
0.23 0.020 0.038 0.0033 0.16 VOC*
0.028 0.0024 0.005 0.00041 0.022 Annual Hg 1,156 0.014 0.0012 0.044 0.0039
- Emissions are based on AP-42 emission Factors. Particulate emissions include condensables and filterables. Output-based facto 10, CO and VOC are calculated based on heat rate for each fuel type derived from the above data. Natural gas and oil factors base comparing combustion turbine and boiler factors and selecting the lower factor.
TRC Environmental Corp.
Baseline Data Page 1 of 2
Entergy - Indian Point Emission Avoidance Study r
d AS input lbs/MMBtu 118.36 0.04 0.11 0.11 0.0066 0.015 0.0021 s for PM-on TRC Environmental Corp.
Baseline Data Page 2 of 2
Entergy - Indian Point Emission Avoidance Study Generation Fuel In Percent of Total 2002 2003 2004 2005 Natural Gas 15.2%
15.7%
20.7%
32.9%
Oil 15.3%
15.0%
11.6%
5.6%
Coal 18.1%
17.9%
17.0%
10.8%
Nuclear 20.1%
19.9%
19.8%
19.5%
Hydro 17.9%
17.8%
17.6%
17.4%
Other 1.8%
1.8%
1.9%
2.0%
Net Imports 11.6%
11.9%
11.4%
11.8%
TOTAL 100.0%
100.0%
100.0%
100.0%
Note: Above Percentages Calculated from given Generation Fuel Mix Emission Factors Obtained from E-Grid - 1998 data (and AP-42 for PM-10, CO and VOC)
COAL OIL GAS output input output input output input Pollutant tons lbs/MWh lbs/MMBtu lbs/MWh lbs/MMBtu lbs/MWh lbs/MMBtu Annual CO2 69,010,726 2295.74 202.42 1753.03 150.88 1234.69 118.36 Annual SO2 317,766 19.06 1.68 7.94 0.68 0.43 0.040 Annual NOx 107,232 4.87 0.43 2.55 0.22 1.15 0.11 Ozone NOx 50,339 4.88 0.41 2.54 0.21 1.23 0.11 PM-10*
NA 0.48 0.042 0.14 0.012 0.069 0.0066 CO*
NA 0.23 0.020 0.038 0.003 0.16 0.015 VOC*
NA 0.028 0.0024 0.0048 0.00041 0.022 0.0021 Annual Hg 1,156 0.044 0.0039 0
0 0
0 Assume Replacement by existing Natural Gas, Oil and Coal fired sources.
2002 Generation Fuel Mix Unit #2 Unit #3 Total Net Output (MW) 983.7 989 1972.7 Capacity Factor (%)
90%
90%
90%
12-month Net Generation (MWh) 7,755,491 7,797,276 15,552,767 Annual CO2 (tons) 6,952,142 6,989,599 13,941,742 Annual SO2 (tons) 37,731 37,934 75,665 Annual NOx (tons) 11,539 11,601 23,140 Ozone NOx (tons) 4,849 4,876 9,725 PM-10 942 947 1,890 CO 571 574 1,145 VOC 73 73 145 Annual Hg (tons) 64 64 128 2003 Generation Fuel Mix Unit #2 Unit #3 Total Net Output (MW) 983.7 989 1972.7 Capacity Factor (%)
90%
90%
90%
12-month Net Generation (MWh) 7,755,491 7,797,276 15,552,767 Annual CO2 (tons) 6,925,448 6,962,761 13,888,209 Annual SO2 (tons) 37,297 37,497 74,794 Annual NOx (tons) 11,455 11,516 22,971 Ozone NOx (tons) 4,815 4,841 9,657 PM-10 935 940 1,875 CO 573 576 1,148 VOC 73 73 146 Annual Hg (tons) 63 63 126 2004 Generation Fuel Mix Unit #2 Unit #3 Total Net Output (MW) 983.7 989 1972.7 Capacity Factor (%)
90%
90%
90%
12-month Net Generation (MWh) 7,755,491 7,797,276 15,552,767 Annual CO2 (tons) 6,680,028 6,716,018 13,396,046 Annual SO2 (tons) 33,434 33,614 67,048 Annual NOx (tons) 10,711 10,769 21,480 Ozone NOx (tons) 4,519 4,543 9,062 PM-10 877 881 1,758 CO 599 602 1,201 VOC 77 78 155 Annual Hg (tons) 59 59 118 2005 Generation Fuel Mix Unit #2 Unit #3 Total Net Output (MW) 983.7 989 1972.7 Capacity Factor (%)
90%
90%
90%
12-month Net Generation (MWh) 7,755,491 7,797,276 15,552,767 Annual CO2 (tons) 7,244,319 7,283,350 14,527,670 Annual SO2 (tons) 31,788 31,959 63,747 Annual NOx (tons) 11,046 11,106 22,152 Ozone NOx (tons) 4,693 4,718 9,411 PM-10 919 924 1,844 CO 752 756 1,508 VOC 98 99 197 Annual Hg (tons) 63 63 126 TRC Environmental Corp.
Emissions - Current EF's Page 1 of 1
Entergy - Indian Point Emission Avoidance Study Coal Generaton (MWh)
Oil Generation (MWh)
Gas Generation (MWh)
Total Generation (MWh)
Capacity (MW)
Capacity Factor Heat Rate (Btu/kWh)
Bowline Point 0
1,018,218 2,503,152 3,521,370 1,242 0.324 12,880 Lovett 1,618,392 86 454,188 2,072,666 449.1 0.527 11,745 Danskammer 2,514,449 264 220,461 2,735,174 537.4 0.581 10,891 Roseton 0
3,228,349 429,265 3,657,614 1,242 0.336 12,592 Annual CO2 (tons) Annual SO2 (tons) Annual NOx (tons)
Ozone Season NOx (tons)
Annual Hg (lbs)
Bowline Point 2,957,361 2,193 4,273 2,358 0
Lovett 2,259,440 9,324 4,570 2,096 36.2 Danskammer 2,950,904 13,938 6,444 2,811 127.2 Roseton 3,614,561 24,729 4,714 2,181 0
CO2 Rate (lbs/MWh)
CO2 Rate (lbs/MMBtu)
SO2 Rate (lbs/MWh)
SO2 Rate (lbs/MMBtu)
Annual NOx Rate (lbs/MWh)
Annual NOx Rate (lbs/MMBtu)
Ozone Season NOx Rate (lbs/MWh)
Ozone Season NOx Rate (lbs/MMBtu)
Hg Rate (lbs/GWh)
Hg Rate (lbs/Bbtu)
Bowline Point 1,679.66 130.41 1.25 0.10 2.43 0.19 2.48 0.19 0
0 Lovett 2,180.23 185.63 9.00 0.77 4.41 0.38 4.29 0.36 0.0175 0.0015 Danskammer 2,157.74 198.11 10.19 0.94 4.71 0.43 4.57 0.42 0.0465 0.0043 Roseton 1,976.46 156.96 13.52 1.07 2.58 0.20 2.58 0.20 0
0 PM Rate (lbs/MWh)
PM Rate (lbs/MMBtu)
CO Rate (lbs/MWh)
CO Rate (lbs/MMBtu)
VOC Rate (lbs/MWh)
VOC Rate (lbs/MMBtu)
Bowline Point 0.36 0.028 0.86 0.069 0.069 0.0054 Lovett 0.289 0.025 0.40 0.034 0.036 0.0031 Danskammer 0.31 0.028 0.28 0.025 0.029 0.0027 Roseton 0.92 0.073 0.520 0.0412 0.0700 0.00542 COAL NO. 6 OIL GAS input input input Pollutant lbs/MMBtu lbs/MMBtu lbs/MMBtu PM-10*
0.042 0.082 0.0054 CO*
0.020 0.036 0.082 VOC*
0.0024 0.0054 0.0054 Annual Hg 0.0039
- Emissions are based on AP-42 emission Factors. Particulate emissions include condensables and filterables. Output-based factors for PM-10, CO TRC Environmental Corp.
HV Emission Factors Page 1 of 1
Entergy - Indian Point Emission Avoidance Study Indian Point Generating Capacity Unit 2 (MW) 983.7 Unit 3 (MW) 989 Total (MW) 1972.7 Capacity Factor 90%
12-month Net Generation (MWh) 15,552,767 Current Emissions Current Generation (MWh)
Available Generation (MWh)*
Annual CO2 (tons)
Annual SO2 (tons)
Annual NOx (tons)
Ozone Season NOx (tons)
Annual Hg (lbs)
Annual PM-10 (tons)
Annual CO (tons)
Annual VOC (tons)
Bowline Point 3,521,370 6,270,558 2,957,361 2,193 4,273 2,358 0
626 1,516 122 Lovett 2,072,666 1,468,038 2,259,440 9,324 4,570 2,096 36 300 412 37 Danskammer 2,735,174 1,501,688 2,950,904 13,938 6,444 2,811 127 417 377 40 Roseton 3,657,614 6,134,314 3,614,561 24,729 4,714 2,181 0
1,684 952 128 TOTAL 11,986,824 15,374,598 11,782,266 50,184 20,002 9,447 163 3,027 3,256 327
- Assuming a 90% capacity factor for necessary shutdowns.
Replace Emissions - Scenario 1 Percent Replaced Increased Generation (MWh)
Annual CO2 (tons)
Annual SO2 (tons)
Annual NOx (tons)
Ozone Season NOx (tons)
Annual Hg (lbs)
Annual PM-10 (tons)
Annual CO (tons)
Annual VOC (tons)
Bowline Point 40.3%
6,270,558 5,266,203 3,919 7,619 1,960 0
1,114 2,699 217 Lovett 9.4%
1,468,038 1,600,331 6,606 3,237 794 26 212 292 26 Danskammer 9.7%
1,501,688 1,620,126 7,651 3,536 865 70 229 207 22 Roseton 39.4%
6,134,314 6,062,113 41,468 7,913 1,995 0
2,825 1,596 215 TOTAL 99%
15,374,598 14,548,772 59,644 22,305 5,613 96 4,380 4,794 480 Increased Emissions - Scenario 1 Annual CO2 (tons)
Annual SO2 (tons)
Annual NOx (tons)
Ozone Season NOx (tons)
Annual Hg (lbs)
Annual PM-10 (tons)
Annual CO (tons)
Annual VOC (tons)
Bowline Point 178%
179%
178%
83%
0%
178%
178%
178%
Lovett 71%
71%
71%
38%
71%
71%
71%
71%
Danskammer 55%
55%
55%
31%
55%
55%
55%
55%
Roseton 168%
168%
168%
91%
0%
168%
168%
168%
TOTAL 123%
119%
112%
59%
58%
145%
147%
147%
TRC Environmental Corp.
HV Emission Calcs Page 1 of 1
Entergy - Indian Point Emission Avoidance Study Oil Generation (MWh)
Gas Generation (MWh)
Total Generation (MWh)
Capacity (MW)
Capacity Factor Heat Rate (Btu/kWh)
Bronx Zoo 1,957 19,529 21,486 3.80 0.648 7,553 Ravenswood 620,133 3,102,402 3,722,535 2,310 0.184 13,210 Charles Poletti 2,247,830 390,380 2,638,210 883.0 0.341 11,373 JFK Cogen 0
569,591 569,591 121.1 0.537 7,684 Far Rockaway 0
359,190 359,190 100.0 0.410 11,317 Astoria 863,747 3,398,031 4,261,778 1,150.6 0.423 12,991 Arthur Kill 0
1,237,781 1,237,781 928.0 0.152 13,129 East River 259,283 231,769 491,052 356.3 0.157 11,795 Waterside 1,074 507,733 508,807 199.8 0.291 8,427 Hudson Ave 2,547 0
2,547 48.9 0.006 8,590 Brooklyn Navy Yard 12,742 1,788,404 1,801,146 336.6 0.611 8,500 Warbasse Cogen 6,868 60,780 67,648 37.8 0.204 16,064 Gowanus 114,743 0
114,743 688.0 0.019 18,182 Narrows 26,377 65,003 91,380 393.1 0.027 17,404 Annual CO2 (tons)
Annual SO2 (tons)
Annual NOx (tons)
Ozone Season NOx (tons)
Annual Hg (lbs)
Bronx Zoo 9,720 2
8 3
0 Ravenswood 3,104,337 1,140 3,586 2,602 0
Charles Poletti 2,327,340 3,835 3,446 1,695 0.0 JFK Cogen 253,407 0
167 69 0.0 Far Rockaway 241,576 1
220 97 0.0 Astoria 3,559,363 1,676 4,676 2,191 0.0 Arthur Kill 963,372 5
874 829 0.0 East River 411,987 480 738 334 0.0 Waterside 262,004 3
158 62 0.0 Hudson Ave 1,747 3
10 4
0.0 Brooklyn Navy Yard 924,051 7
73 26 0.0 Warbasse Cogen 65,618 9
42 18 0.0 Gowanus 166,544 324 921 384 0.0 Narrows 102,647 77 388 162 0.0 CO2 Rate (lbs/MWh)
CO2 Rate (lbs/MMBtu)
SO2 Rate (lbs/MWh)
SO2 Rate (lbs/MMBtu)
Annual NOx Rate (lbs/MWh)
Annual NOx Rate (lbs/MMBtu)
Ozone Season NOx Rate (lbs/MWh)
Ozone Season NOx Rate (lbs/MMBtu)
Bronx Zoo 904.75 119.79 0.17 0.02 0.76 0.10 0.76 0.10 Ravenswood 1,667.86 126.26 0.61 0.05 1.93 0.15 1.97 0.15 Charles Poletti 1,764.33 155.13 2.91 0.26 2.61 0.23 2.59 0.23 JFK Cogen 898.78 115.80 0.00 0.00 0.59 0.08 0.59 0.08 Far Rockaway 1,345.12 118.86 0.01 0.00 1.22 0.11 1.11 0.10 Astoria 1,670.37 128.58 0.79 0.06 2.19 0.17 2.04 0.16 Arthur Kill 1,556.61 118.56 0.01 0.00 1.41 0.11 1.51 0.11 East River 1,677.98 142.26 1.95 0.17 3.01 0.25 2.29 0.26 Waterside 1,029.87 122.22 0.01 0.00 0.62 0.07 0.61 0.07 Hudson Ave 1,357.06 159.65 2.64 0.31 7.50 0.88 3.75 0.88 Brooklyn Navy Yard 1,026.07 120.71 0.01 0.00 0.08 0.01 0.07 0.01 Warbasse Cogen 1,939.98 120.76 0.27 0.02 1.25 0.08 1.25 0.08 Gowanus 2,902.90 159.65 5.66 0.31 16.05 0.88 8.87 0.88 Narrows 2,246.60 129.08 1.68 0.10 8.50 0.49 4.44 0.49 PM Rate (lbs/MWh)
PM Rate (lbs/MMBtu)
CO Rate (lbs/MWh)
CO Rate (lbs/MMBtu)
VOC Rate (lbs/MWh)
VOC Rate (lbs/MMBtu)
Bronx Zoo 0.05 0.007 0.11 0.014 0.015 0.0019 Ravenswood 0.10 0.007 0.17 0.013 0.023 0.0018 Charles Poletti 0.13 0.011 0.06 0.005 0.007 0.0007 JFK Cogen 0.05 0.007 0.12 0.015 0.015 0.0021 Far Rockaway 0.07 0.007 0.17 0.015 0.023 0.0021 Astoria 0.10 0.008 0.16 0.013 0.023 0.0018 Arthur Kill 0.09 0.007 0.20 0.015 0.027 0.0021 East River 0.11 0.009 0.10 0.009 0.015 0.0012 Waterside 0.06 0.007 0.13 0.015 0.019 0.0021 Hudson Ave 0.10 0.012 0.03 0.003 0.003 0.0004 Brooklyn Navy Yard 0.06 0.007 0.13 0.015 0.017 0.0021 Warbasse Cogen 0.11 0.007 0.22 0.014 0.030 0.0019 Gowanus 0.22 0.012 0.06 0.003 0.007 0.0004 Narrows 0.14 0.008 0.20 0.012 0.028 0.0016 NO. 2 OIL GAS input input Pollutant lbs/MMBtu lbs/MMBtu PM-10*
0.012 0.0066 CO*
0.0033 0.015 VOC*
0.00041 0.0021
- Emissions are based on AP-42 emission Factors. Particulate emissions include condensables and filterables. Output-based factors for PM-TRC Environmental Corp.
NYC Emission Factors Page 1 of 1
Entergy - Indian Point Emission Avoidance Study Indian Point Generating Capacity Unit 2 (MW) 983.7 Unit 3 (MW) 989 Total (MW) 1972.7 Capacity Factor 90%
12-month Net Generation (MWh) 15,552,767 Current Emissions Current Generation (MWh)
Available Generation (MWh)
Annual CO2 (tons)
Annual SO2 (tons)
Annual NOx (tons)
Ozone Season NOx (tons)
Annual PM-10 (tons)
Annual CO (tons)
Annual VOC (tons)
Bronx Zoo 21,486 8,473 9,720 2
8 3
0.6 1.1 0.2 Ravenswood 3,722,535 14,485,563 3,104,337 1,140 3,586 2,602 184.4 320.9 43.5 Charles Poletti 2,638,210 4,323,362 2,327,340 3,835 3,446 1,695 168.0 75.5 9.9 JFK Cogen 569,591 385,161 253,407 0
167 69 14.6 33.2 4.4 Far Rockaway 359,190 429,210 241,576 1
220 97 13.4 30.5 4.2 Astoria 4,261,778 4,809,552 3,559,363 1,676 4,676 2,191 213.0 349.6 48.2 Arthur Kill 1,237,781 6,078,571 963,372 5
874 829 53.6 121.9 16.7 East River 491,052 2,318,017 411,987 480 738 334 27.4 25.5 3.6 Waterside 508,807 1,066,416 262,004 3
158 62 14.2 32.1 4.7 Hudson Ave 2,547 382,981 1,747 3
10 4
0.1 0.0 0.0 Brooklyn Navy Yard 1,801,146 852,608 924,051 7
73 26 50.8 114.2 15.0 Warbasse Cogen 67,648 230,367 65,618 9
42 18 3.9 7.5 1.0 Gowanus 114,743 5,309,449 166,544 324 921 384 12.5 3.4 0.4 Narrows 91,380 3,007,820 102,647 77 388 162 6.5 9.2 1.3 TOTAL 15,887,894 43,687,552 12,393,712 7,561 15,307 8,476 763 1,125 153 Replaced Emissions Percent Replaced Increased Generation (MWh)
Annual CO2 (tons)
Annual SO2 (tons)
Annual NOx (tons)
Ozone Season NOx (tons)
Annual PM-10 (tons)
Annual CO (tons)
Annual VOC (tons)
Bronx Zoo 0.054%
8,473 3,833 1
3 1
0.2 0.4 0.1 Ravenswood 25.4%
3,946,194 3,290,850 1,204 3,808 980 195.5 340.2 46.2 Charles Poletti 18.0%
2,796,720 2,467,169 4,069 3,650 913 178.1 80.0 10.5 JFK Cogen 2.5%
385,161 173,088 0
114 29 9.9 22.4 3.0 Far Rockaway 2.4%
380,771 256,091 2
232 53 14.2 32.3 4.4 Astoria 29.0%
4,517,836 3,773,229 1,785 4,947 1,162 225.8 370.6 51.1 Arthur Kill 8.4%
1,312,150 1,021,253 7
925 250 56.9 129.2 17.7 East River 3.3%
520,556 436,741 508 783 150 29.0 27.1 3.8 Waterside 3.5%
539,377 277,744 3
167 41 15.0 34.0 5.0 Hudson Ave 0.017%
2,700 1,832 4
10 1
0.1 0.0 0.0 Brooklyn Navy Yard 5.5%
852,608 437,418 4
34 8
24.1 54.1 7.1 Warbasse Cogen 0.46%
71,712 69,560 10 45 11 4.1 8.0 1.1 Gowanus 0.78%
121,637 176,550 344 976 136 13.3 3.6 0.5 Narrows 0.62%
96,870 108,814 81 412 54 6.9 9.8 1.4 TOTAL 100%
15,552,767 12,494,172 8,020 16,107 3,580 773 1,112 142 Increased Emissions Annual CO2 (tons)
Annual SO2 (tons)
Annual NOx (tons)
Ozone Season NOx (tons)
Annual PM-10 (tons)
Annual CO (tons)
Annual VOC (tons)
Bronx Zoo 39%
39%
39%
24%
39%
39%
39%
Ravenswood 106%
106%
106%
38%
106%
106%
106%
Charles Poletti 106%
106%
106%
54%
106%
106%
106%
JFK Cogen 68%
0%
68%
41%
68%
68%
68%
Far Rockaway 106%
159%
106%
55%
106%
106%
106%
Astoria 106%
106%
106%
53%
106%
106%
106%
Arthur Kill 106%
134%
106%
30%
106%
106%
106%
East River 106%
106%
106%
45%
106%
106%
106%
Waterside 106%
96%
106%
67%
106%
106%
106%
Hudson Ave 105%
105%
105%
32%
106%
106%
106%
Brooklyn Navy Yard 47%
64%
46%
29%
47%
47%
47%
Warbasse Cogen 106%
107%
106%
64%
106%
106%
106%
Gowanus 106%
106%
106%
35%
106%
106%
106%
Narrows 106%
106%
106%
33%
106%
106%
106%
TOTAL 101%
106%
105%
42%
101%
99%
93%
TRC Environmental Corp.
NYC Emission Calcs Page 1 of 1
Entergy - Indian Point Emission Avoidance Study Indian Point Generating Capacity Unit 2 (MW) 983.7 Unit 3 (MW) 989 Total (MW) 1972.7 Capacity Factor 90%
12-month Net Generation (MWh) 15,552,767 Current Emissions Current Generation (MWh)
Available Generation (MWh)*
Annual CO2 (tons)
Annual SO2 (tons)
Annual NOx (tons)
Ozone Season NOx (tons)
Annual Hg (lbs)
Annual PM-10 (tons)
Annual CO (tons)
Annual VOC (tons)
Bowline Point 3,521,370 6,270,558 2,957,361 2,193 4,273 2,358 0
626 1,516 122 Lovett 2,072,666 1,468,038 2,259,440 9,324 4,570 2,096 36 300 412 37 Danskammer 2,735,174 1,501,688 2,950,904 13,938 6,444 2,811 127 417 377 40 Roseton 3,657,614 6,134,314 3,614,561 24,729 4,714 2,181 0
1,684 952 128 TOTAL 11,986,824 15,374,598 11,782,266 50,184 20,002 9,447 163 3,027 3,256 327 Current Generation (MWh)
Available Generation (MWh)
Annual CO2 (tons)
Annual SO2 (tons)
Annual NOx (tons)
Ozone Season NOx (tons)
Annual PM-10 (tons)
Annual CO (tons)
Annual VOC (tons)
Bronx Zoo 21,486 8,473 9,720 2
8 3
0.6 1.1 0.2 Ravenswood 3,722,535 14,485,563 3,104,337 1,140 3,586 2,602 184.4 320.9 43.5 Charles Poletti 2,638,210 4,323,362 2,327,340 3,835 3,446 1,695 168.0 75.5 9.9 JFK Cogen 569,591 385,161 253,407 0
167 69 14.6 33.2 4.4 Far Rockaway 359,190 429,210 241,576 1
220 97 13.4 30.5 4.2 Astoria 4,261,778 4,809,552 3,559,363 1,676 4,676 2,191 213.0 349.6 48.2 Arthur Kill 1,237,781 6,078,571 963,372 5
874 829 53.6 121.9 16.7 East River 491,052 2,318,017 411,987 480 738 334 27.4 25.5 3.6 Waterside 508,807 1,066,416 262,004 3
158 62 14.2 32.1 4.7 Hudson Ave 2,547 382,981 1,747 3
10 4
0.1 0.0 0.0 Brooklyn Navy Yard 1,801,146 852,608 924,051 7
73 26 50.8 114.2 15.0 Warbasse Cogen 67,648 230,367 65,618 9
42 18 3.9 7.5 1.0 Gowanus 114,743 5,309,449 166,544 324 921 384 12.5 3.4 0.4 Narrows 91,380 3,007,820 102,647 77 388 162 6.5 9.2 1.3 TOTAL 15,887,894 43,687,552 12,393,712 7,561 15,307 8,476 763 1,125 153 Current Generation (MWh)
Available Generation (MWh)*
Annual CO2 (tons)
Annual SO2 (tons)
Annual NOx (tons)
Ozone Season NOx (tons)
Annual Hg (lbs)
Annual PM-10 (tons)
Annual CO (tons)
Annual VOC (tons)
TOTAL 27,874,718 59,062,150 24,175,978 57,745 35,309 17,922 163 3,790 4,380 480 Replaced Emissions - half replacement by Hudson Valley Plants, half from NYC plants Percent Replaced Increased Generation (MWh)
Annual CO2 (tons)
Annual SO2 (tons)
Annual NOx (tons)
Ozone Season NOx (tons)
Annual Hg (lbs)
Annual PM-10 (tons)
Annual CO (tons)
Annual VOC (tons)
Bowline Point 15.4%
2,388,279 2,005,749 1,493 2,902 746 0
424 1,028 83 Lovett 9.0%
1,405,733 1,532,411 6,326 3,100 760 25 203 279 25 Danskammer 9.7%
1,501,688 1,620,126 7,651 3,536 865 70 229 207 22 Roseton 16.0%
2,480,683 2,451,486 16,769 3,200 807 0
1,142 646 87 TOTAL 50.0%
7,776,383 7,609,771 32,239 12,738 3,178 94 1,999 2,159 217 Percent Replaced Increased Generation (MWh)
Annual CO2 (tons)
Annual SO2 (tons)
Annual NOx (tons)
Ozone Season NOx (tons)
Annual PM-10 (tons)
Annual CO (tons)
Annual VOC (tons)
Bronx Zoo 0.054%
8,473 3,833 1
3 1
0.2 0.4 0.1 Ravenswood 11.8%
1,830,215 1,526,271 558 1,766 454 90.7 157.8 21.4 Charles Poletti 8.3%
1,297,098 1,144,254 1,887 1,693 423 82.6 37.1 4.9 JFK Cogen 1.8%
280,044 125,849 0
83 21 7.2 16.3 2.2 Far Rockaway 1.1%
176,599 118,773 1
108 25 6.6 15.0 2.1 Astoria 13.5%
2,095,338 1,749,995 828 2,294 539 104.7 171.9 23.7 Arthur Kill 3.9%
608,565 473,649 3
429 116 26.4 59.9 8.2 East River 1.6%
241,430 202,557 235 363 70 13.5 12.6 1.8 Waterside 1.6%
250,159 128,816 1
78 19 7.0 15.8 2.3 Hudson Ave 0.008%
1,252 850 2
5 1
0.1 0.0 0.0 Brooklyn Navy Yard 5.5%
852,608 437,418 4
34 8
24.1 54.1 7.1 Warbasse Cogen 0.21%
33,260 32,262 4
21 5
1.9 3.7 0.5 Gowanus 0.36%
56,414 81,883 160 453 63 6.2 1.7 0.2 Narrows 0.29%
44,928 50,467 38 191 25 3.2 4.5 0.6 TOTAL 50%
7,776,383 6,076,877 3,722 7,520 1,668 374 551 75 Percent Replaced Increased Generation (MWh)
Annual CO2 (tons)
Annual SO2 (tons)
Annual NOx (tons)
Ozone Season NOx (tons)
Annual Hg (lbs)
Annual PM-10 (tons)
Annual CO (tons)
Annual VOC (tons)
TOTAL 100%
15,552,767 13,686,648 35,961 20,258 4,846 94 2,373 2,710 292 Increased Emissions Annual CO2 (tons)
Annual SO2 (tons)
Annual NOx (tons)
Ozone Season NOx (tons)
Annual Hg (lbs)
Annual PM-10 (tons)
Annual CO (tons)
Annual VOC (tons)
Bowline Point 68%
68%
68%
32%
0%
68%
68%
68%
Lovett 68%
68%
68%
36%
68%
68%
68%
68%
Danskammer 55%
55%
55%
31%
55%
55%
55%
55%
Roseton 68%
68%
68%
37%
0%
68%
68%
68%
Bronx Zoo 39%
39%
39%
24%
39%
39%
39%
Ravenswood 49%
49%
49%
17%
49%
49%
49%
Charles Poletti 49%
49%
49%
25%
49%
49%
49%
JFK Cogen 50%
0%
50%
30%
49%
49%
49%
Far Rockaway 49%
74%
49%
26%
49%
49%
49%
Astoria 49%
49%
49%
25%
49%
49%
49%
Arthur Kill 49%
62%
49%
14%
49%
49%
49%
East River 49%
49%
49%
21%
49%
49%
49%
Waterside 49%
44%
49%
31%
49%
49%
49%
Hudson Ave 49%
49%
49%
15%
49%
49%
49%
Brooklyn Navy Yard 47%
64%
46%
29%
47%
47%
47%
Warbasse Cogen 49%
50%
49%
30%
49%
49%
49%
Gowanus 49%
49%
49%
16%
49%
49%
49%
Narrows 49%
49%
49%
16%
49%
49%
49%
TOTAL 57%
62%
57%
27%
58%
58%
63%
62%
TRC Environmental Corp.
HV&NYC Emission Calcs Page 1 of 1
Entergy - Indian Point Emission Avoidance Study Baseline Statewide Emissions and Calculated Increases Under Different Generation Replacement Source Assumptions Source CO2 SO2 NOx PM-10 CO VOC NY Statewide - All Sources(a) 248,241,000 688,000 723,000 767,000 3,337,000 753,000 NY Statewide - Utilities Only(b) 69,010,726 317,766 107,232 8,328 6,450 842 2002 Generation Mix 13,941,742 75,665 23,140 1,890 1,145 145 2003 Generation Mix 13,888,209 74,794 22,971 1,875 1,148 146 2004 Generation Mix 13,396,046 67,048 21,480 1,758 599 155 2005 Generation Mix 14,527,670 63,747 22,152 1,844 752 197 Hudson Valley 14,548,772 59,644 22,305 4,380 4,794 480 New York City 12,494,172 8,020 16,107 773 1,112 142 Hudson Valley and New York City 13,686,648 35,961 20,258 2,373 2,710 292 (a) based on USEPA Emission Trends Report (baseline year = 1998)
(b) based on USEPA's E-GRID database (baseline year = 1998)
Percent Increase in NY Statewide Emissions from All Sources Source CO2 SO2 NOx PM-10 CO VOC 2002 Generation Mix 5.62%
11.00%
3.20%
0.25%
0.03%
0.02%
2003 Generation Mix 5.59%
10.87%
3.18%
0.24%
0.03%
0.02%
2004 Generation Mix 5.40%
9.75%
2.97%
0.23%
0.02%
0.02%
2005 Generation Mix 5.85%
9.27%
3.06%
0.24%
0.02%
0.03%
Hudson Valley 5.86%
8.67%
3.09%
0.57%
0.14%
0.06%
New York City 5.03%
1.17%
2.23%
0.10%
0.03%
0.02%
Hudson Valley and New York City 5.51%
5.23%
2.80%
0.31%
0.08%
0.04%
Percent Increase in NY Statewide Utility Emissions Source CO2 SO2 NOx PM-10 CO VOC 2002 Generation Mix 20.20%
23.81%
21.58%
22.69%
17.76%
17.28%
2003 Generation Mix 20.12%
23.54%
21.42%
22.51%
17.80%
17.34%
2004 Generation Mix 19.41%
21.10%
20.03%
21.11%
9.28%
18.36%
2005 Generation Mix 21.05%
20.06%
20.66%
22.14%
11.66%
23.44%
Hudson Valley 21.08%
18.77%
20.80%
52.59%
74.31%
56.97%
New York City 18.10%
2.52%
15.02%
9.28%
17.24%
16.83%
Hudson Valley and New York City 19.83%
11.32%
18.89%
28.49%
42.02%
34.63%
TRC Environmental Corp.
Statewide increases Page 1 of 1
Entergy - Indian Point Emission Avoidance Study Emission Prices - $/ton 2001 841 2002 2250 2003 2960 2004 3090 2005 3170 2001, 2003 and 2005 were obtained from NYISO document Bold and Italic - graphically interpolated Replacement Source Ozone NOx (tons) 2002 Cost 2003 Cost 2004 Cost 2005 Cost 2002 Generation Fuel Mix 9,725
$21,881,250 2003 Generation Fuel Mix 9,657
$28,584,720 2004 Generation Fuel Mix 9,062
$28,001,580 2005 Generation Fuel Mix 9,411
$29,832,870 Hudson Valley Plants*
5,613
$12,629,250
$16,614,480
$17,344,170
$17,793,210 New York City Plants*
3,580
$8,055,000
$10,596,800
$11,062,200
$11,348,600 Hudson Valley & NYC Plants*
4,846
$10,903,500
$14,344,160
$14,974,140
$15,361,820
- NOTE: It is unclear whether the necessary generation is available during the ozone season from these sources. These ozone season emissions are based on assuming that the generation is available, and the mix of the plants is the same on an annual basis.
TRC Environmental Corp.
Costs of NOx Allowances Page 1 of 1
Entergy - Indian Point Emissions Avoidance Study TRC Environmental Corp.
NOx Cost Estimation Page 1 of 1 NOx Allowance Cost Estimation
$0
$500
$1,000
$1,500
$2,000
$2,500
$3,000
$3,500 2000 2001 2002 2003 2004 2005 2006 Year Cost per Ton of NOx