ML12157A450

Attachment 50 to GNRO-2012/00039 Enercon. 2011 B. Evaluation of Potential Air Emissions from Coal and Natural Gas Fired

ML12157A450
Person / Time
Site:	Grand Gulf
Issue date:	05/23/2012
From:	Entergy Operations
To:	Office of Nuclear Reactor Regulation
References
GNRO-2012/00039
Download: ML12157A450 (19)

Text

Attachment 50 to GNRO-2012/00039 Attachment 50 to GNRO-2012/00039 Enercon. 2011 b.

Evaluation of Potential Air Emissions from Coal and Natural Gas Fired

CALC NO. ENTGGG084-CALC-004 E N E RC O N CALCULATION COVER SHEET REV. 0 PAGE NO. lof18 TITLE Evaluation of Potential Air Emissions from Coal and Client: Entergy Nuclear, Inc.

Natural Gas Fired Power Generation Alternatives for Grand Gulf Nuclear Station, Unit I License Renewal Project: ENTGGG084 Environmental Report ITEM COVER SHEET ITEMS YES NO Does this calculation contain any open assumptions that require confirmation? (If I YES, Identify the assumptions) X Does this calculation serve as an "Alternate Calculation"? (If YES, Identify the design 2 verified calculation.) X Design Verified Calculation No.

Does this calculation Supersede an existing Calculation? (If YES, identify the 3 superseded calculation.) X Superseded Calculation No. ,_,,

Scope of Revision:

Initial issue.

Revision Impact on Results:

N/A Study Calculation 0 Final Calculation 19 Safety Related 0 Non-Safety Related EN (PrintName And Sign)

Originator: James A. Thomas Date: 4/06/2011 Reviewer: Michelle Barnett Date: 4/27/2011 7,,

Apoe:Cr m Date: 5/1212011 Approver: Chris Byerman ,

CALC. NO. ENTGGG084-CALC-004 CALCULATION REV. 0 ENE RC 0N REVISION STATUS SHEET PAGE NO. 2 of 18 CALCULATION REVISION STATUS REVISION DATE DESCRIPTION 0 Initial Issue PAGE REVISION STATUS PAGE NO. REVISION PAGE NO. REVISION 1-18 0 ATTACHMENT REVISION STATUS ATTACHMENT NO. PAGE NO. REVISION NO.

EN ERCO CALC. NO. ENTGGG084-CALC-004 Ece-lc-Eyeproject.En~ydo CALCULATION REV. 0 DESIGN VERIFICATION PLAN AND

SUMMARY

SHEET PAGE NO. 3 of 18 Calculation Design Verification Plan:

Calculation inputs of approximate air emissions characteristics, emissions removal rates, and waste generation for coal fired electric power generation and natural gas fired electric power generation shall be verified by checking the documented input with the source references. Equations used are applicable based on references cited. Check the validity of the references for their intended use. All assumptions shall be evaluated and verified to determine if they are based on sound emissions calculation principles and practices. Calculation results shall be verified by checks of all equations for each type of fuel source (coal and natural gas). Verify the methodology, results and conclusions.

(PrintName and Sign for Approval - mark "N/A" if not required)

Approver: Chris Byerman Date:

Calculation Verification Summary:

Calculation inputs, assumptions, methodology, results, and conclusions of Revision 0 are evaluated/verified and were found to be acceptable. All comments have been incorporated.

Based on the above summary, the calculation is determined to be acceptable.

(P ntq0eay *g)

Design Verifier: Michelle Barnett (//',((I(,if_' / \i*z *... Date: 412712011 Others: Date:

CALC. NO. ENTGGG084-CALC-004 REVIEW CHECKLIST CALCULATION REV. 0 O ENE CONREVEW CECKISTPAGE NO. 4 of 18 Item Cover Sheet Items Yes No NIA 1 Design Inputs - Were the design inputs correctly selected, referenced latest revision, 0l F Z consistent with the design basis and incorporated in the calculation?

2 Assumptions - Were the assumptions reasonable and adequately described, Z Eli []

justified and/or verified, and documented?

3 Quality Assurance - Were the appropriate QA classification and requirements assigned to the calculation?

4 Codes, Standard and Regulatory Requirements - Were the applicable codes, standards, and regulatory requirements, including issue and addenda, properly Z El 11 identified and their requirements satisfied?

5 Construction and Operating Experience - Has applicable construction and operating [] 0 Z experience been considered?

6 Interfaces - Have the design interface requirements been satisfied, including l E interactions with other calculations?

7 Methods - Was the calculation methodology appropriate and properly applied to 0 l 13 satisfy the calculation objective?

8 Design Outputs - Was the conclusion of the calculation clearly stated, did it correspond directly with the objectives and are the results reasonable compared to 19 El EL the inputs?

9 Radiation Exposure - Has the calculation properly considered radiation exposure to El Li the public and plant personnel?

10 Acceptance Criteria - Are the acceptance criteria incorporated in the calculation sufficient to allow verification that the design requirements have been satisfactorily El El 2 accomplished?

11 Computer Software - Is a computer program or software used, and if so, are the [] El 0 requirements of CSP 3.02 met?

COMMENTS:

/ Print N ,g*ndjig7

/ I Reviewer: Michelle Barnett / Date: 4127/2011 Others: Date:

Evaluation of Potential Air Emissions from CALC. NO. ENTGGG071-CALC-004 Coal and Natural Gas Fired Power E N E RC O N Generation Alternatives for Grand Gulf REV. 0 Nuclear Station, Unit I License Renewal PAGE NO. 5 of 18 Environmental Report TABLE OF CONTENTS 1.0 PURPOSE ...................................................................................................... 6 2.0

SUMMARY

OF RESULTS AND CONCLUSIONS ........................................... 6

3.0 REFERENCES

............................................................................................... 11 4.0 ASSUM PTIO NS/DESIGN INPUTS ............................................................... 12 5.0 METHODO LOGY .......................................................................................... 14 6.0 CALCULATIO NS .............................................................................................. 15 TABLES Table I - Supercritical Coal-Fired Alternative Emission Control Characteristics 7 Table 2 - Air Emissions from Supercritical Coal-Fired Alternative 8 Table 3 - Solid Waste from Coal-Fired Alternative 9 Table 4 - Gas-Fired Alternative Emission Control Characteristics 10 Table 5 - Air Emissions from Gas-Fired Alternative 11 Table 6 - Air Emissions Calculations Supercritical Coal 16 Table 7 - Solid Waste Calculations Supercritical Coal-Fired Alternative 17 Table 8 - Air Emissions Calculations Combined-Cycle Gas-Fired Alternative 18

Evaluation of Potential Air Emissions from CALC. NO. ENTGGG071-CALC-004 Coal and Natural Gas Fired Power r :EN ERC0 N Generation Alternatives for Grand Gulf REV. 0 Nuclear Station, Unit I License Renewal PAGE NO. 6 of 18 Environmental Report 1.0 PURPOSE Supercritical Coal-Fired Power Plant Entergy has chosen to evaluate the construction of three 538 gross MWe supercritical coal-fired plants using a closed-cycle cooling system with cooling towers at an alternate site in Mississippi rather than at the Grand Gulf Nuclear Station (GGNS) with an operating life of 40 years. The air emissions and waste generated from emissions control equipment are to be determined to evaluate the environmental impacts associated with operating a supercritical coal-fired plant. A supercritical coal-fired plant emits oxides of sulfur (SOx), nitrogen oxides (NOx), particulate matter, and carbon monoxide, all of which are regulated pollutants. However, Entergy has assumed a plant design that would minimize air emissions through a combination of boiler technology and post-combustion pollutant removal. Carbon dioxide (C0 2 ) is also emitted, but control technologies are not yet established.

The purpose of the following analyses is to provide an estimate of annual air emissions and air emissions control waste generation from supercritical coal-fired power generation.

Natural Gas-Fired Power Generation Entergy has chosen to evaluate the construction of three 528 MWe natural gas-fired plants using a closed-cycle cooling system with cooling towers at the GGNS site, with an operating life of 40 years. Entergy has assumed that the plants would use combined-cycle turbines and used site-specific input as appropriate. The air emissions and waste generated from emissions control equipment are to be determined to evaluate the environmental impacts associated with operating a combined-cycle turbine plant. A combined-cycle natural gas-fired plant emits oxides of sulfur (SOx), nitrogen oxides (NOx), particulate matter, and carbon monoxide, all of which are regulated pollutants.

However, Entergy has assumed a plant design that would minimize air emissions through a combination of boiler technology and post-combustion pollutant removal.

Carbon dioxide (C02) is also emitted from natural gas-fired generation, but similar to coal, control technologies are not yet established.

The calculations are based on U.S. Department of Energy (DOE) information for the most recent use of coal and natural gas consumed for electric power generation in Mississippi, and U.S. Environmental Protection Agency (EPA) air emissions and emissions removal information from Air Pollutant Emission Factors.Vol.1, Stationary Point Sources and Area Sources.

2.0

SUMMARY

OF RESULTS AND CONCLUSIONS Supercritical Coal-Fired Power Plant A supercritical coal-fired plant emits oxides of sulfur (SOx), nitrogen oxides (NOx),

particulate matter, and carbon monoxide all of which are regulated pollutants. However, a plant design has been assumed that would minimize air emissions through a combination of boiler technology and post-combustion pollutant removal. Tables 1 and

Evaluation of Potential Air Emissions from CALC. NO. ENTGGG071-CALC-004 Coal and Natural Gas Fired Power E N E RC O N Generation Alternatives for Grand Gulf REV. 0 Nuclear Station, Unit I License Renewal PAGE NO. 7 of 18 Environmental Report Table 2 present the basic supercritical coal-fired alternative emission control characteristics and emission estimates. Emission control technology and percent control assumptions were based on alternatives that the EPA has identified as being available for minimizing emissions [EPA 1998]. Although the EPA regulations have not been finalized for carbon dioxide, carbon dioxide emissions are also estimated.

Table I Supercritical Coal-Fired Alternative Emission Control Characteristics Characteristic Basis Total size = 1,614 MWe ISO rating gross/ Size set to gas-fired alternative. Chosen as 1,524 MWe ISO rating neta comparable to GGNS unit.

Unit size = 538 MWe ISO rating gross / 508 Based on approximately 6 percent onsite power MWe ISO rating neta usage Number of units = 3 Boiler type = pulverized coal, tangentially Minimizes nitrogen oxide emissions [EPA 1998, fired, dry-bottom, NSPS Table 1.1-3]

Fuel type = combination bituminous, Typical for coal used in Mississippi [DOE 2010a, subbituminous, lignite Table 4]

Fuel heating value = 8,541 Btu/Ib 2009 value for coal used in Mississippi [DOE 2010a, Table 15]

Fuel ash content by weight = 11.27% 2009 value for coal used in Mississippi [DOE 201 Oa, Table 15]

Fuel sulfur content by weight = 0.53% 2009 value for coal used in Mississippi [DOE 2010a, Table 15]

Uncontrolled SOx emission = 38S Typical for pulverized coal, tangentially fired, dry-Uncontrolled NOx emission = 10 lb/ton bottom, NSPS [EPA 1998, Table 1.1-3]

Uncontrolled CO emission = 0.5 lb/ton Heat rate = 10,414 Btu/kWh Average operating heat rate for coal [DOE 2011, Table 5.3]

Capacity factor = 0.85 Typical for newer large coal-fired units NO, control = low NO. burners, overfire air Best available and widely demonstrated for and selective catalytic reduction (95% minimizing NOx emissions [EPA 1998, Table 1.1-reduction) 2]

Particulate Material, filterable (PMf) = 10 Typical for pulverized coal, tangentially fired, dry-lb/ton of ash bottom, [EPA 1998, Table 1.1-4]

Particulate Material (less than 10 microns)

PM 10 = 2.3 lb/ton of ash Particulate control = fabric filters (baghouse - Best available for minimizing particulate 99.8% removal efficiency) emissions [EPA 1998, pp. 1.1-6 and 1.1-7; Table 1.1-6]

SO, control = Wet scrubber - lime (95% Best available for minimizing SOx emissions removal efficiency) [EPA 1998, Table 1.1-1]

CO 2 emission - average of bituminous and Based on DOE 2010b lignite coal = 210 Ib/MMBtu Btu = British thermal unit ISO rating = International Standards Organization rating at standard atmospheric conditions of 59°F, 60% relative humidity, and 14.696 pounds of atmospheric pressure per square inch

Evaluation of Potential Air Emissions from CALC. NO. ENTGGG071-CALC-004 Coal and Natural Gas Fired Power E N ERC O N Generation Alternatives for Grand Gulf REV. 0 Nuclear Station, Unit I License Renewal PAGE NO. 8 of 18 Environmental Report kWh = kilowatt-hour NSPS = New Source Performance Standard lb = pound MW = megawatt NOx = nitrogen oxides SOx = oxides of sulfur

a. The difference between "net" and "gross" is electricity consumed by auxiliary equipment and environmental control devices [DOE 2002, page 109].

Table 2 Air Emissions from Supercritical Coal-Fired Alternative Annual coal consumption 7,326,650 tons of coal per year SOx 3,689 tons SOx per year NOx 1,832 tons NO, per year CO 1,832 tons CO per year PMf 826 tons PMf per year PM 10 190 tons PM 10 per year CO 2 13,141,153 tons CO 2 per year (assuming 210 lb/C0 2/MMBtu)

SOx = oxides of sulfur NO, = nitrogen oxides CO = carbon monoxide PMf = filterable particulate matter PM10 = particulates having diameter less than 10 microns CO 2 = carbon dioxide

Evaluation of Potential Air Emissions from CALC. NO. ENTGGG071-CALC-004 Coal and Natural Gas Fired Power ENERCON Generation Alternatives for Grand Gulf REV. 0 Nuclear Station, Unit I License Renewal PAGE NO. 9 of 18 Environmental Report Table 3 Solid Waste from Coal-Fired Alternative Annual SO, generated a 77,542 tons of SO, per year Annual SO, removed 73,665 tons of SO, per year Annual ash generated 824,062 tons of ash per year Annual lime consumption b 67,864 tons of CaO per year Calcium sulfate c 197,666 tons of CaSO 4 .2H 2O per year Annual scrubber waste d 201,059 tons of scrubber waste per year Total volume of scrubber waste e 111,082,320 ft3 of scrubber waste Total volume of ash f 659,249,600 ft3 of ash Total volume of solid waste 770,331,920 ft3 of solid waste Waste pile area (acres) 589 acres of solid waste 30 feet high Based on annual coal consumption of 7,326,650 tons per year (Table 2)

a. Calculations assume 100% combustion of coal.

b. Lime consumption is based on total SO 2 generated.

c. Calcium sulfate generation is based on total S02 removed.

d. Total scrubber waste includes scrubbing media carryover

e. Density of CaSO,4 2H 20 is 144.8 lb/ft3.

f. Density of coal bottom ash is 100 lb/ft3 [FHA 2000].

S = sulfur SO 2 = sulfur dioxide SOx = oxides of sulfur CaO = calcium oxide (lime)

CaSO,4 2H 2O = calcium sulfate dehydrate Combined-Cycle Natural-Gas Power Plant Table 3 presents the basic gas-fired alternative characteristics and Table 4 presents emission estimates. Emission control technology and percent control assumptions were based on alternatives that the EPA has identified as being available for minimizing emissions [EPA 2000].

Evaluation of Potential Air Emissions from CALC. NO. ENTGGG071-CALC-004 Coal and Natural Gas Fired Power PA E N E R C O N Generation Alternatives for Grand Gulf REV. 0 Nuclear Station, Unit 1 License Renewal PAGE NO. 10 of 18 Environmental Report Table 4 Gas-Fired Alternative Emission Control Characteristics Characteristic Basis Total size = 1,584 MWe ISO rating gross/ 1,524 Manufacturer's standard size gas-fired combined cycle MWe ISO rating neta plant Individual unit size = 528 MWe ISO rating Based on approximately 4 percent onsite power usage gross/ 508 MWe ISO rating neta Number of units = 3 Fuel type = natural gas Fuel heating value = 1,025 Btu/ft3 2009 value for gas used in Mississippi [DOE 2011, Table 3.7]

Fuel sulfur content = 0.0034 Ib/MMBtu Used when sulfur content is not available [EPA 2000, Table 3.1-2a]

NOx control = selective catalytic reduction Best available for minimizing NOx emissions [EPA (SCR) with steam/water injection 2000, Table 3.1]

Fuel NOx content = 0.099 lb/MMBtu Natural gas-fired turbine, Lean-premix [EPA 2000, Table 3.1-1]

Fuel CO content = 0.015 Ib/MMBtu Natural gas-fired turbine, Lean-premix [EPA 2000, Table 3.1-1]

CO 2 emission rate - gas turbine, lean premix = [DOE 2010b]

117 Ib/MMBtu Heat rate = 7,543 Btu/kWh Typical for combined cycle gas-fired turbines [DOE 2011, Table 5.4]

Uncontrolled filterable particulates = 0.0019 [EPA 2000, Table 3.1-2a]

Ib/MMBtu Uncontrolled total particulate matter = 0.0066 [EPA 2000, Table 3.1-2a]

Ib/MMBtu Capacity factor = 0.85 Typical for large gas-fired base load units.

Btu = British thermal unit ft3 = cubic foot ISO rating = International Standards Organization rating at standard atmospheric conditions of 59°F, 60%

relative humidity, and 14.696 pounds of atmospheric pressure per square inch kWh = kilowatt-hour MM = million MW = megawatt NOx = nitrogen oxides SCR = selective catalytic reduction

Evaluation of Potential Air Emissions from CALC. NO. ENTGGG071-CALC-004 Coal and Natural Gas Fired Power Fi J E N E R C O N Generation Alternatives for Grand Gulf REV. 0 Nuclear Station, Unit I License Renewal PAGE NO. 11 of 18 Environmental Report Table 5 Air Emissions from Gas-Fired Alternative Annual gas consumption 86,795,748,246 ft 3 per year Annual Btu input 88,965,642 MMBtu per year sox 151 tons SO, per year NO, 4,404 tons NO, per year CO 667 tons CO per year PMf 85 tons filterable particulate matter per year PMT 294 tons total particulate matter per year C02 5,204,490 tons C02 per year (assuming 117 lb CO 2/MMBtu)

SOx = oxides of sulfur NO, = nitrogen oxides CO = carbon monoxide PMf = total filterable particulates PMT = total particulates C02 = carbon dioxide

3.0 REFERENCES

DOE (United States Department of Energy). 2002. Energy Information Administration, "Electric Power Annual 2000, Volume I1," DOE/EIA-0348(00)/2. November 2002.

DOE (United States Department of Energy). 2010a. Cost and Quality of Fuels for Electric Plants 2009, DOE/EIA-0191(2010). December 2010.

DOE (United States Department of Energy). 2010b. Energy Information Administration, Independent Statistics and Analysis, Frequently Asked Questions - Environment.

Last Reviewed January 2010. Accessed at http://tonto.eia.doe.gov/ask/environmentfaqs.asp DOE (United States Department of Energy). 2011. Electric Power Annual 2009, DOE/EIA-0348 (2009). January 2011.

EPA (United States Environmental Protection Agency). 1998. Air Pollutant Emission Factors.Vol.1, Stationary Point Sources and Area Sources. Section 1.1,

Evaluation of Potential Air Emissions from CALC. NO. ENTGGG071-CALC-004 Coal and Natural Gas Fired Power J E NERC0 N Generation Alternatives for Grand Gulf REV. 0 Nuclear Station, Unit I License Renewal PAGE NO. 12 of 18 Environmental Report Bituminous and Subbituminous Coal Combustion. AP-42. September 1998.

Accessed at http://www.epa.,gov/ttn/ chief/ap42/ch01/final/cO1sOl.pdf.

EPA (United States Environmental Protection Agency). 2000. Air Pollutant Emission Factors.Vol.1, Stationary Point Sources and Area Sources, Section 3.1, Stationary Gas Turbines for Electricity Generation, AP-42. April 2000. Accessed at http:l/www.epa..qovlttnlchief/ap42/chO3/final/cO3sO1 .pdf.

FHA (Federal Highway Administration). 2000. User Guidelines for Waste and Byproduct Materials in Pavement Construction, Coal Bottom Ash/Boiler Slag. Accessed at http://tfhrc.gov/hnr20/recycle/waste/cbabsl .htm.

4.0 ASSUMPTIONS/DESIGN INPUTS 4.1 SUPERCRITICAL COAL-FIRED EMISSIONS ESTIMATES Based on input from Entergy, the net MWe size of the supercritical coal-fired plant to be evaluated is 1,524 MWe. It is assumed that the plant would be built in Mississippi, and would use coal typical of that currently used for electricity generation in Mississippi.

However, since bituminous and lignite coal is used almost equally, the average input values for the type of coal, fuel heating value, ash content, and sulfur content are used (see Table 1) for Mississippi coal listed in the most recent DOE reference available

[DOE 2011]. Assumptions for gaseous effluents are as follows:

• Plant generating size is 1,524 MWe net ISO

• Plant would use pulverized coal, tangentially fired, dry-bottom, required to meet New Source Performance Standards;

• Fuel type might be either bituminous, subbituminous, or lignite, since all of these are used in Mississippi based on DOE report;

" Average heating value for coal used Mississippi is 8,541 Btu/Ib [DOE 2010, Table 15];

• Average sulfur content by weight for coal used in Mississippi is 0.53% [DOE 2010, Table 15]

• Average ash content by weight for coal used in Mississippi is 11.27 percent [DOE 2010, Table 15]

" Average heat rate for coal is 10,414 Btu/kWh [DOE 2011, Table 5.3];

• Capacity factor for supercritical coal-fired baseload plant is 0.85;

• SO, emission factor is based on use of bituminous coal use, since the EPA emissions factors are given only for bituminous and sub-bituminous coal; bituminous coal is more representative than sub-bituminous based on use in Mississippi; for pulverized coal, tangentially fired, bituminuous coal use, meeting NSPS standards SO, is 38S lb/ton [EPA 1998, Table 1.1-3];

• Molecular weight of Sulfur is 32.1; molecular weight of SO 2 is 64.1 (sulfur = 32.1 and oxygen = 16)

• Uncontrolled NOx emission is based on use of bituminous coal use, since the EPA emissions factors are given only for bituminous and sub-bituminous coal; bituminous coal is more representative than sub-bituminous based on use in Mississippi; 10 lb/ton[EPA 1998, Table 1.1-3];

Evaluation of Potential Air Emissions from CALC. NO. ENTGGG071-CALC-004 Coal and Natural Gas Fired Power E N E RC O N Generation Alternatives for Grand Gulf REV. 0 Nuclear Station, Unit I License Renewal PAGE NO. 13 of 18 Environmental Report

• Uncontrolled CO emission is based on use of bituminous coal use, since the EPA emissions factors are given only for bituminous and sub-bituminous coal; bituminous coal is more representative than sub-bituminous based on use in Mississippi; 0.5 lb/ton [EPA 1998, Table 1.1-3];

" CO 2 emission based on average of bituminous (205 lb/MMBtu) and lignite coal (215 lb/MMBtu) is 210 lb/MMBtu [DOE 2010b];

" Uncontrolled filterable particulate material (PMf) emission is based on use of bituminous coal use, since the EPA emissions factors are given only for bituminous and sub-bituminous coal; bituminous coal is more representative than sub-bituminous based on use in Mississippi; 10 lb/ton [EPA 1998, Table 1.1-4];

• Uncontrolled filterable particulate material less than or equal to 10 microns emission is based on use of bituminous coal use, since the EPA emissions factors are given only for bituminous and sub-bituminous coal; bituminous coal is more representative than sub-bituminous based on use in Mississippi; 2.3 lb/ton

[EPA 1998, Table 1.1-4];

• After combustion, 95% of NO, would be removed based on low NOx burner, overfire air, and selective catalytic reduction [EPA 1998, Table 1.1-2];

• After combustion, 95% of SO, would be removed based on wet scrubbing with lime [EPA 1998, Table 1.1-1];

" After combustion, 99.8% of ash would be removed based on baghouse removal efficiency and disposed of at either an onsite or offsite landfill [EPA 1998, Section 1.4.1.1 and Table 1.1-6]

• ISO rating = International Standards Organization rating at standard atmospheric conditions of 59 0 F, 60% relative humidity, and 14.696 pounds of atmospheric pressure per square inch 4.2 COMBINED-CYCLE NATURAL GAS EMISSIONS Based on input from Entergy, the net MWe size of the supercritical coal-fired plant to be evaluated is 1,524 MWe. It is assumed that the plant would be built in Mississippi, and would use natural gas. Assumptions for gaseous emissions are as follows:

• Plant generating size is 1,524 MWe net ISO

• Fuel type is natural gas;

• Average heating value for natural gas is 1,025 Btu/cubic foot [DOE 2011, Table 3.7];

• Fuel sulfur content - where sulfur content is not available - is 0.0034 lb/MMBtu

[EPA 2000, Table 3.1-2a]

• Average heat rate for combined-cycle natural gas is 7,543 Btu/kWh [DOE 2011, Table 5.4];

• Capacity factor is assumed as a baseload plant is 0.85;

• NO, emission factor based on gas turbine, lean premix is 0.099 lb/MMBtu [EPA 2000, Table 3.1];

• CO emission factor based on gas turbine, lean premix is 0.015 Ib/MMBtu [EPA 2000, Table 3.1];

C002 emission based on natural gas is 117 lb/MMBtu [DOE 2010b];

Evaluation of Potential Air Emissions from CALC. NO. ENTGGG071-CALC-004 Coal and Natural Gas Fired Power E N E RC O N Generation Alternatives for Grand Gulf REV. 0 Nuclear Station, Unit I License Renewal PAGE NO. 14 of 18 Environmental Report Total Particulate Matter (PM) uncontrolled emissions from natural gas is 0.0066 lb/MMBtu [EPA 2000, Table 3.1-2a];

5.0 METHODOLOGY ENERCON reviewed readily available emissions calculations to determine the annual emissions for supercritical coal-fired and combined-cycle natural gas-fired power plants used in previous Appendix E Applicant's Environmental Report for license renewal.

Equations are as provided below.

Evaluation of Potential Air Emissions from CALC. NO. ENTGGG071-CALC-004 Coal and Natural Gas Fired Power E N E RC O N Generation Alternatives for Grand Gulf REV. 0 Nuclear Station, Unit I License Renewal PAGE NO. 15 of 18 Environmental Report 6.0 CALCULATIONS The following is an assessment of the annual emissions (and, for coal, emissions control waste generation) for a supercritical coal-fired power plant and a combined-cycle gas-fired power plant to be built in Mississippi, assuming the plants are constructed and the input parameters are as specified in Section 4.1 and 4.2, respectively. The calculations presented in the equations listed below were selected to provide the emissions quantities desired, and were selected as being used by the nuclear industry in other license renewal Environmental Report applications (see NPPD Cooper ER, and South Texas Project license renewal applications at the NRC website @

http://www.nrc.gov/reactors/operating/licensing/renewal/applications/south-texas-proj/south-texas-project-enviro. pdf)

Information presented in Section 4.1 was readily available for coal type, Btu per pound, sulfur content percent by weight, NO, and CO for coal currently used in Mississippi.

Emission factors were selected from EPA's AP-42 guidance to be representative of the type of coal most likely to be used in Mississippi (bituminous or lignite), based on current use cited by DOE, and to be representative of the most efficient type of coal plant that would minimize emissions.

Information presented in Section 4.2 was established from readily available information on natural gas, for Btu, sulfur content percent by weight, NO, and CO for natural gas.

Emission factors were selected from EPA's AP-42 guidance to be representative of the emissions representative of the most efficient type of natural gas plant that would minimize emissions, as further discussed in Section 4.2.

Evaluation of Potential Air Emissions from CALC. NO. ENTGGG071-CALC-004 Coal and Natural Gas Fired Power E N E RCO N Generation Alternatives for Grand Gulf REV. 0 Nuclear Station, Unit I License Renewal PAGE NO. 16 of 18 Environmental Report 6.1 COAL EMISSIONS AND WASTE GENERATION EQUATIONS Table 6 Air Emissions from Supercritical Coal-Fired Alternative Parameter Calculation Result Annual coal 538 MW 10,414 Btu 1,000 kW lb 24 hr 365 day ton 7,326,650 consumption 3 units x x M- x x-- -- 0.85 tons of coal unit M x hr MW 8,541 Btu day yr 2,000 lb per year Sox a, b 7,326,650 tons 0.53 % x 38 lb ton 3,689 tons x x -- x (100 - 95)/100 SO, per year yr ton 2,000 lb NOx b.c 7,326,650 tons 10 lb ton 1,832 tons x- x- x (100 - 95)/100 NOx per year yr ton 2,000 lb CO b 7,326,650tons 0.5 lb ton 1,832 tons x- x CO per year yr ton 2,000 lb CO 2 7,326,650 tons 210 lb MMBtu 8,541 Btu 13,141,153 x- x x tons C02 per yr MMBtu 1,000,000 Btu lb year PMf d 7,326,650 tons 11.27% x 10 lb ton 826 tons PMf x x x (100 - 99.8)/100 peryear yr ton 2.000 lb PM 10 d 7,326,650 tons 11.27% x 2.3 lb ton 190 tons x x -- x (100 - 99.8)/100 PM1o per yr ton 2,000 lb year CO = carbon monoxide NO, = nitrogen oxides PM 10= particulates having diameter less than 10 microns SOx = oxides of sulfur TSP = total suspended particulates

a. EPA 1998, Table 1.1-1

b. EPA 1998, Table 1.1-3

c. EPA 1998, Table 1.1-2

d. EPA 1998, Table 1.1-4

Evaluation of Potential Air Emissions from CALC. NO. ENTGGG071-CALC-004 Coal and Natural Gas Fired Power ENE RCO N Generation Alternatives for Grand Gulf REV. 0 Nuclear Station, Unit I License Renewal PAGE NO. 17 of 18 Environmental Report Table 7 Solid Waste from Supercritical Coal-Fired Alternative Parameter Calculation Result Annual SO. 7,326,650 tons Coal 0.53 tons S 64.1 tons So 2 77,542 tons of SOx per generated a generated 'yr _

100 tons Coal x__year_

32.1 tons S year Annual SOx 77,542 tons So 2 73,665 tons of SO. per removed x (95/100) year yr Annual ash 7,326,650 tons Coal 11.27 tons ash 824,062 tons of ash per generated x x (99.8/100) year yr 100 tons Coal Annual lime 77,542 tons SO2 56.1 tons CaO 67,864 tons of CaO per consumption y yr x 64.1 tons SO year Calcium sulfate c 73,665 tons SO2 172 tons CaSO 4 *2H 2 0 197,666 tons of yr x 64.1 tons SO CaSO 4-2H 2O per year Annual scrubber 67,864 tons CaO (100-95) 201,059 tons of scrubber waste d yr x 100 + 197,666 tons CaSO 4 e2H 2 0 waste per year Total volume of 201,059 tons 2,000 lb ft3 111,082,320 ft3 of scrubber waste x 40 yr x- x scrubber waste yr ton 144.8 lb Total volume of 824,062 tons 2,000 lb ft3 659,249,600 ft3 of ash ashf x 40 yrx yr ton 100 lb 3 3 Total volume of 111,082,320 ft + 659,249,600 ft 770,331,920 ft3 of solid solid waste waste Waste pile area 770,331,920 ft3 acre 589 acres of solid waste (acres) 30 ft x 43,560 ft2 30 feet high Based on annual coal consumption of 7,326,650 tons per year

a. Calculations assume 100% combustion of coal and both gaseous and non-gaseous SO,.

b. Lime consumption is based on total SO 2 generated.

c. Calcium sulfate generation is based on total SO 2 removed.

d. Total scrubber waste includes scrubbing media carryover

e. Density of CaSO 4 '2H 2O is 144.8 lb/ft3.

f. Density of coal bottom ash is 100 lb/ft3 [FHA 2000].

S = sulfur (molecular weight = 32.1)

SO 2 = sulfur dioxide (molecular weight = 64.1)

SOx = oxides of sulfur CaO = calcium oxide (lime) (molecular weight = 56.1)

CaSO 4'2H 20 = calcium sulfate dehydrate

Evaluation of Potential Air Emissions from CALC. NO. ENTGGG071-CALC-004 Coal and Natural Gas Fired Power EE N E R C O N Generation Alternatives for Grand Gulf REV. 0 Nuclear Station, Unit 1 License Renewal PAGE NO. 18 of 18 Environmental Report 6.2 COMBINED-CYCLE GAS-FIRED POWER GENERATION EQUATIONS Table 8 Air Emissions from Combined-Cycle Gas-Fired Alternative Parameter Calculation Result 3

Annual gas 528 MW 7,543 Btu 1,000 kW ft 24 hr 365 day 86,795,748,246 consumption 3x x- xx 0.85 x - - x ft3 per year unit kW x hr MW 1,025 Btu day yr Annual Btu 86,795,748,246 ft3 1,025 Btu MMBtu 88,965,642 input 106 MMBtu per year yr ft lBtu 1

SOx 0.0034

_ lb x ton

- x 88,965,642 MMBtu 151 tons SO, per year MMBtu 2,000 lb yr NOx 2 0.099 lb ton 88,965,642 MMBtu 4,404 tons NO, x - x per year MMBtu 2,000 lb yr 2

CO 0.015 lb ton 88,965,642 MMBtu 667 tons CO per x x year MMBtu 2,000 lb yr CO 2 117 lb ton 88.965,642 MMBtu 5,204,490 tons x _X CO 2 per year MMBtu 2,000 lb yr PMf 1 0.0019 lb ton 88,965,642 MMBtu 85 tons filterable x x particulate MMBtu 2,000 lb yr matter per year PMT 1 0.0066 lb ton 88,965,642 MMBtu 294 tons total

_x x particulate MMBtu 2,000 lb yr matter per year

References:

1. EPA 2000, Table 3.1-2a;

2. EPA 2000, Table 3.1.1 CO = carbon monoxide NO, = oxides of nitrogen PM10 = particulates having diameter less than 10 microns SO. = oxides of sulfur TSP = total suspended particulates