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5.2. ERMUSR 08-09-20115• Elk River.; Municipal Utilities 13069 Orono Parkway • P.O. Box 430 Elk River, MN 55330-0430 UTILITIES COMMISSION MEETING Phone: 763.441.2020 Fax: 763.441.8099 TO: FROM: Elk River Municipal Utilities Commission Troy Adams, P.E. -Utilities Director John Dietz -Chair Daryl Thompson -Vice Chair Al Nadeau -Trustee MEETING DATE: AGENDA ITEM NUMBER: Au ust 9, 2011 5,2 SUBJECT: Study of NESHAP-RICE regulations and their im act on the ERMU Power Plant BACKGROUND: Under the current administration, the Environmental Protection Agency (EPA) has imposed National Emissions Standazds for Hazazdous Air Pollutants for Reciprocating Internal Combustion Engines (NESHAP-RICE) which will impact Elk River Municipal Utilities and the operation of our diesel Power Plant. These new regulations would require ERMU to install emission upgrades by 5/3/2013 to our 4 diesel engines to continue to operate under our current contract with Great River Energy (GRE). DISCUSSION: These regulations are designed to reduce pollutants related to the generation of electricity from reciprocating internal combustion engines. Because of the broad approach to regulating these pollutants, the impact of these rules affects utilities differently. The ERMU Power Plant is for all practical purposes an "emergency backup" facility for GRE. The engines are maintained and exercised but only run a few hours a yeaz. Because of their limited run time, these engines do not contribute significant pollution. There is an exemption in the rules for emergency facilities, but ERMU would not qualify for this exemption as long as we are receiving compensation. The revenue associated with our contract has nothing to do with pollution and should not be within the jurisdiction of the EPA to regulate. There has been much outcry from Midwest utilities dealing with similar concerns of these rules. Subsequently, these rules aze currently being reconsidered by the EPA. The Congress may also be eliminating funding for the EPA. The Iowa Association of Municipal Utilities (IAMU), Minnesota Municipal Utilities Association (MMUA), American Public Power Association (APPA), and Central Municipal Power Agency (CMMPA) have provided support for utilities for the EPA to impose "reasonable" regulations for electric generation from reciprocating internal combustion engines. Senator Amy Klobuchar has also recently submitted written concerns to the EPA regazding these rules. There is no scheduled date for the EPA's reconsideration of these rules. A study has been conducted to determine ERMU's options. This study is attached for Commission review. Staff has also received a budgetary quote from a very reputable company to bring the ERMU Power Plant into compliance. The cost estimates used in the study were much higher than the quote. The study indicated total plant upgrade costs to be approximately $500,000. The quote came in for less than $175,000 to retrofit the 4 engines. The 2011 Uniform Rating of Generating Equipment (URGE) test for the power plant will result in $352,968 in compensation from GRE over the next year under the current contract. Not a114 engines would need to be retrofitted. One of the engines could run on natural gas. There aze options. The payback would be relatively short regazdless of which option the Utilities chooses. The Utilities 2011 budget included $100,000 to begin retrofitting these engines knowing that additional costs would be incurred in 2012. At this point, this 2011 capital expenditure would be delayed unti12012. The 2012 budget will include in the capital projects this carried over $100,000 plus an additional amount required to bring a114 engines into compliance with this rule. At this time it would be premature to begin any work until after the EPA has ruled on the comments submitted. ACTION REQUESTED: No action requested. STUDY OF NESHAP-RICE REGULATIONS FOR ELK RIVER MUNICIPAL UTILITIES ELK RIVER, MINNESOTA PROJECT N344 2011 UTILITIES PLUS ENERGY SERVICES, INC. 18940 York St. NW ELK RIVER, MN 55330 Phone: 763.441.1200 Fax: 763.441.7500 www.utilsplus.com July, toll Utilities Plus Energy Services Inc. Ells River Utilities Commission 13069 Orono Pazkway P.O. Box 430 Elk River, MN 55330-0430 RE: Elk River Municipal Utilities NESHAP-RICE Emissions Study Elk River, Minnesota Project N344 Commissioners: 18940 York St. N"' Elk River, MN 5` Phone: 763-441-1'tvv Fax: 763-041-7500 The Diesel Emissions Study for Ells River Municipal Utilities (ERMU) is herewith submitted. We wish to thank the Commission for the opportunity to prepaze this Study. The existing facilities and operation of the Municipal Electric Utility aze reviewed. New Emissions Regulations from the Environmental Protection Agency (EPA) aze discussed. Options, including "No Change" are presented for addressing the new regulations. Cost estimates and construction times are included. I wish to thank Mr. Troy Adams and Mr. Wade Lovelette, for their assistance in gathering data. Sincerely Robert E. Pahngttist, P.E. Minnesota Registration 8358 CITY OF ELK RIVER ELK RIVER UTILITIES COMMISSION COMMISSIONERS Name Appointment Term Expires John Dietz Allan Nadeau Council Representative Citizen Representative 02-28-13 02-28-14 Daryl Thompson Citizen Representative 02-29-12 INTRODUCTION In 1916, Elk River Power and Light Company, a private power company, began providing electrical service to Elk River Consumers. Subsequently, the Village of Elk River purchased the company, and Elk River Municipal Utilities (ERMU) began serving Elk River in 1947. In 1947, in a new municipal power plant, ERMU installed two new identical Worthington S-DD-6 diesel engine electrical generating units, each rated 550 KW (Units 1 & 2). In 1961, ERMU installed, in the municipal power plant, Unit 3, which is a 3000 KW Cooper- Bessemer engine. In 1973, ERMU installed, in the municipal power plant, Unit 4, which is a 5000 KW Worthington engine-generator. ERMU is one of 129 public power utilities in Minnesota. Nationally, 2015 such utilities are in the U.S., with Minnesota having the third largest number of any state (Nebraska has 153 and Iowa has 136). From the time it was first formed, until the Arab oil embargo of 1973, ERMU generated its electrical requirements with diesel engines, using fuel oil and natural gas, and with hydroelectric capacity (which has since been removed). Fuel oil had stabilized at 10 cents per gallon for many prior years and natural gas was comparably priced. Nationally, electrical load growth had grown at 7% per year, which calculates to a compounded doubling every ten years. Electrical rates to consumers had stayed at low levels. In 1973, fuel oil prices increased from 10 cents per gallon to 80 cents per gallon and natural gas went up a comparable amount. It immediately became too expensive for municipals to generate their own power. Municipal electric utilities wondered whether they could continue in business, and public officials seriously considered selling their municipal electric utilities. At that time, some private potential buyers stated that the municipals would need to make big investments in coal-fired plants in order to stay in business. A few municipals did sell, but most did not. Almost all municipal electric utilities have installed an interconnection with an outside power source, as has ERMU. These municipals purchase wholesale electrical power from private and public power producers, and then add the cost of service before selling to the municipal consumers at a retail rate. When U.S. municipals were generating full-time, the U.S. manufactured diesels included Nordberg, Enterprise, Cooper-Bessemer, Worthington, and Fairbanks-Morse, all of whom made slower speed, heavy-duty engines suitable for continuous duty service. When the municipals cut back on their local generation, fewer heavy-duty diesels were installed, and the first four above companies went out of the municipal diesel business. Fairbanks-Morse stayed in the business, because they were able to continue making municipal-type diesels for the military, as well as, diesels for domestic use. The local diesels continue to be valuable to the municipals, which include ERMU, who have interconnected with an outside power source and purchase most of their electrical requirements. The diesels are valuable by being able to provide local power during an outage on the interconnection and because the cost of purchased power is reduced by having the diesels. Municipals can install diesel generation and pay for it by capacity credits or lower cost energy charges from the interconnected power company, and/or by the value of having standby power. ERMU's diesels have value for the consumers of the electric system. The diesels can provide power during an interruption of the interconnection and they save money in wholesale power costs. When ERMU was generating 100% of its local requirements, there were no permits required for installing diesels; no fuel oil spill protection; and no concern about hazardous materials such as asbestos and chromate in jacket water. Today, regulations for these items are in place and are striving for a cleaner environment. ERMU is currently operating its diesels within its permit from the Minnesota Pollution Control Agency (MPCA). The new NESHAP-RICE regulations are more stringent than the present regulations, governing the running of the diesel engines. Under the proposed regulations, without new emissions controls, ERMU would not be able to receive capacity credits for its diesels. However, the Environmental Protection Agency (EPA) is reviewing the proposed rules to determine whether changes will be made which would allow ERMU to continue receiving capacity credits, without installing additional emissions control equipment. NESHAP-RICE National Emissions Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines (NESHAP-RICE) have been formulated, but are currently being re- considered, in response to public comments. The Iowa Association of Municipal Utilities (IAMU), Minnesota Municipal Utilities Association (MMUA), and Central Minnesota Municipal Power Agency CMMPA) have forwarded comments on these proposed rules to the Environmental Protection Agency (EPA). The date for an EPA ruling on these comments is unknown. The new regulations state that by 8/31/2010, an Initial Notification to the EPA was required, regarding the affected sources. Information required: manufacturer, model #, serial #, KW rating, facility name, facility address, manufacture date, This notice required a listing of all owned diesel-generators, including the application: emergency only, peak shaving, available capacity, storm avoidance, etc.; and engine/generator and installation date. ERMU did provide the requested information to the EPA on time. The engine/generators not affected are emergency-only or newer than 6/12/2006 (which are required to meet the NESHAP standards.) The units affected are stationary diesel engine electrical generating units, greater than 500 hp, used for non-emergencies, and older than 6/12/2006, that do not meet NESHAP emission limitations. All four of ERMU's engines, at the power plant, do not meet the new emissions limitations. The proposed new standards state that if a unit is designated an emergency unit without new emissions controls, the unit could run: (a) 100 hours/year for readiness testing; (b) no limits on hour during outages on the interconnection; 4 (c) 50 hours/year for non-emergencies, but the 50 hours cannot generate income, and the 50 hours must count towards the above 100 hours; or (d) a maximum of 15 hours per year, which would count towards the above 100 hours, as part of an Emergency Demand Response EDR) program. This would be in a situation such as when a grid failure was imminent, but had not yet occurred. ERMU could not continue its present programs of credits on wholesale power purchases, under the proposed regulations. The IAMU, MMUA, and CMMPA have asked that the 15 hours be increased to 100 hours, which would be a three-year rolling average, and which would be beyond the 100 hours for readiness testing, including the right for municipals to negotiate with their power suppliers for financial accreditation, for these emergency units. If EPA agrees to the revised 100 hours, or even to 60 hours, then ERMU could continue to receive capacity credits without installing emissions controls. If the unit is to be used for its present operation then, under the presently proposed rules, the engine must be tested for emissions levels. The system must be retrofitted with a Direct Oxidation Catalyst (DOC) silencer, which can be installed in place of the existing exhaust silencer, or must re-use the existing exhaust silencer with an in-line DOC. The new system must include installation of a closed crankcase ventilation system, or a filtered open crankcase ventilation system, to prevent or diminish oil mist in the atmosphere. An emissions monitoring system must be installed, and emissions records must be kept at the job site. An approved maintenance system must be implemented for each new system. Approved low sulfur fuel oil must be used in the retrofitted engine. After the conversions are completed, testing needs to be done to assure that CO emissions are reduced by 70°~, or the CO level is reduced to 23 ppmvd (parts per million by volume, dry basis) or less. Continuous emissions monitoring is then on-going. The EPA requires that all units be compliant with NESHAP by 5/3/2013. VALUE OF ERMU MUNICIPAL GENERATION Elk River Municipal Utilities (ERMU) has four diesel engine electrical generating units at its municipal power plant. These are all subject to the new emissions regulations. These diesels have been very valuable to ERMU over the years. From 1947 until the late 1970's, the diesels and hydroelectric capacity generated much of the electrical requirements of ERMU's electrical consumers. After the diesels became standby units, they continued to have value by being available during an outage on the interconnection, and by allowing lower cost wholesale power to be purchased. ERMU obtains essentially all of its electrical energy from the landfill gas-to-electric plant, and wholesale power from Great River Energy (GRE). In recent years, GRE asked ERMU to run the diesels on only one occasion. ERMU tests all four engines once a month, running Units 1 and 2 for 15 minutes each, and Units 3 and 4 for 90 minutes each. An annual URGE test is conducted on all four units to determine the diesel capacity for which GRE pays ERMU. On May 25, 2010, the four Units had a total URGE-tested rating of 10,680 KW. This rating included the following: Unit 1 648 KW Unit 2 640 KW Unit 3 3536 KW Unit 4 5856 KW Total 30, 680 KW During the URGE test, the four engines each ran for an hour. GRE paid for the cost of labor, as well as, for fuel oil, maintenance and overhead. GRE paid $3,268.88, for running the URGE tests, and GRE paid $2.75/KW/month for the tested capacity. GRE paid (10,680 KW)($2.75/KW/month)(12 months) _ $352,440 for the capacity, plus 7 $3,268.88 for running the URGE tests, for a total payment from GRE to ERMU of $355,708.88. In addition to being a financial benefit to ERMU, the diesels are part of a plan to provide power to critical parts of the ERMU load, should an outage on the interconnection occur. Although the diesels can carry only a portion of the current peak demand of 53,000 KW, they can provide electrical service to crucial loads, which can be isolated to the diesels. 8 COST OF UPGRADES One contractor estimated that the complete cost of all systems, including crankcase ventilation equipment, and engine exhaust gas equipment, as well as, monitoring controls, would be in the range of $50/KW to $55/KW, for a typical diesel generator set. This Contractor has installed emissions controls on aFairbanks-Morse OP at Vinton, IA, and on another engine at Winterset, Iowa. The EPA estimates that total costs will be $50/KW. IAMU says this will be the lower end of the range, and for slower speed equipment could be $100/KW. MMUA says Minnesota municipals have seen costs of $80,000 to $120,000/unit. MMUA says some engine run too slow and too cool, so that additional fuel would be needed to activate the catalyst. Caterpillar has a budgetary price for Caterpillar equipment that is in the range of $30/KW. Emissions control equipment have been installed on 24 Caterpillar engines at Mount Pleasant, Iowa; and two Caterpillars at Bellevue, Iowa. Emissions controls are being installed on Caterpillar equipment at Brooklyn, Iowa, and Montezuma, Iowa. The Southern Minnesota Municipal Power Agency is having emissions controls installed on all their diesels. Many municipals are waiting for further clarification from the EPA before making a decision on emissions controls. Whether the cost is worthwhile, especially for the older equipment, depends on how much value the units are to ERMU, the exhaust temperatures, and the years of remaining useful life. Also, for ERMU, a critical item is whether ERMU can continue to receive capacity credits from GRE, without installing emissions controls. PROJECT COMPLETION TIME The estimated project completion time for emissions controls, from notice to proceed by the Elk River Utilities Commission, until project completion, is six months, broken down as follows: Prepare plans and specifications. Receive Bids, award Contract 2 months Delivery of equipment Install equipment, test system TOTAL 3 months 1 month 6 months 10 OPTIONS FOR ERMU Option I - No Change Under the NESHAP-RICE Regulations, as currently proposed, Elk River Municipal Utilities (ERMU) could continue its present operation until May 3, 2013. After that date, ERMU's diesels will be subject to the new regulations, which allow up to 100 hours/year far maintenance and readiness testing, but not for financial benefit, such as peak shaving, if part of an Emergency Demand Response (EDR) program. The current version of the regulations allow the non-complying unit to be designated as an Emergency Unit, to allow operating 15 hours per year, during defined emergency times, but the 15 hours must count towards the above mentioned 100 hours. The IAMU, MMUA, and CMMPA have filed comments tothe-Environmental Protection Agency (EPA) requesting that the Emergency Units be allowed to operate, beyond readiness testing, up to 100 hours per year, while allowing financial credits from the designated unit, for diesels subject to an EDR program. It is unknown what the EPA's response will be or how soon a decision will be made on this request. One industry observer speculated that the EPA might finalize on 60 hours within the next year, although at least one State (Delaware) is asking that this be reduced to 0 hours. If all of ERMU's diesels become Emergency Units, they could be run if there was an outage on the interconnection. However, under the proposed regulations, ERMU could not continue to receive capacity credits without emissions controls. If EPA revises the present regulations to requested levels of 100 hours, or even 60 hours, then ERMU could continue its present operation, without emissions controls, even it were in an EDR program. In order to become Emergency Units, the ERMU diesels would need to adopt certain maintenance features, discussed later in this Study. 11 Option 2 -Install Emissions Controls on Units 3 & 4 Option 2 could be adopted if EPA kept to its present regulations. Emissions controls could be placed on the Cooper-Bessemer engine and the large Worthington engine. The two smaller Worthington engines could be designated Emergency Units To place emissions controls on Units 3 & 4 would require a cost of $400,000. In 2010, the two units provided capacity credits of $309,936, plus reimbursements for fuel and labor for URGE tests. If ERMU were faced with the choice of putting on the emissions controls, or losing the engine credits, the choice should be to install the emissions controls because the payback would be about 15 months. The emissions controls on each Unit would include a combination direct oxidation catalyst and exhaust silencer to take the place of the existing exhaust silencer. The new system must include a closed crankcase ventilation system, or filtered open crankcase system. An emissions monitoring system must be installed with ongoing emissions records kept at the job site. Approved low sulfur fuel oil must be used in the diesel. After the conversions are completed, testing needs to be done to reduce emissions by 70%, or to 23 ppmvd. All units must be compliant with NESHAP by 5/3/2013. Option 3 -Install Emissions Controls on Units 1 & 2 Under Option 3, the same package of emissions controls that are described above for Units 3 & 4 would be installed for Units i & 2. Because Units 1 & 2 are slower in speed and are smaller, the cost/KW of emissions controls would be higher. To install emissions controls on Units 1 & 2 would require a total expenditure of $110,000. In 2010, Units 1 & 2 provided capacity credits of $42,504, plus reimbursement for fuel and 12 labor for URGE tests. The payback for the emissions controls would be 2.6 years. It appears that, if necessary to obtain capacity credits, the installation of emissions controls on Units 1 & 2 would be desirable. However, the age of 64 years for the two smaller Worthington engines should be taken into account. 13 EMERGENCY UNITS The four ERMU diesels can continue to operate as Non-Emergency Units until 5/3/2013. At that time, they must either have emissions controls installed, which would allow them to continue their present operation, or be designated Emergency Units, so that emissions controls would not be required. The URGE rating of the four diesels in 2010, was 10,680 KW. ERMU's system demand is 53,000 KW, so the diesels do not cover a substantial part of the peak demand. However, they are used to cover certain critical loads, which can be isolated to the diesels during an emergency. If new emissions controls are not installed, the four units would need to be designated by 5/3/2013 as Emergency Units. Under the currently proposed rules, the units then could be run a maximum of 15 hours per year, such as when a grid failure was imminent but had not yet occurred. They could run a limited number of additional hours for testing purposes. The EPA is considering whether to extend the limited hours of running from 15 hours up to 100 hours. Under the present GRE contract, ERMU will not continue to receive capacity credits at the 15 hour level. ERMU can receive credits without installing emissions controls on the diesels, if the EPA changes the allowable hours to at least 60, plus 100 hours for readiness testing, and the EPA allows capacity credits to be paid. If the EPA does not extend the 15 hours to 60-100 hours, ERMU could install emissions controls on one or more of the diesels to obtain capacity credits. If ERMU designates the four diesels as Emergency Units, ERMU must keep records of the hours of operation. For the Emergency Units, the new regulations require that the following maintenance procedures be followed: 14 1. Change oil and filter every 500 hours of operation, or annually, whichever comes first. EPA might accept periodic oil analysis, and change-out as necessary, instead. 2. Inspect air cleaner every 1,000 hours of operation, or annually, whichever comes first and replace as necessary. 3. Inspect all hoses and belts every 500 hours of operation, or annually, whichever comes first and replace as necessary. 4. Install hour meter and keep on-site records of hours of operation. These could be examined at the site by EPA, but would not need to be submitted to EPA. 5. Keep on-site records of maintenance performed. Whether or not emissions controls are installed on any of the diesels, ERMU should notify the MPCA of the designation of the diesels under the new emissions regulations. 15 CONCLUSIONS 1. In 1916, a private power company, Elk River Power and Light Company, began serving Elk River consumers. The village of Elk River purchased the company, and Elk River Municipal Utilities (ERMU) began serving Elk River in 1947. 2. Elk River Municipal Utilities (ERMU) currently owns four diesel engine electrical generating units, all installed in the municipal power plant. 3. In the past, ERMU generated much of its electrical requirements using hydroelectric capacity (since removed) and the diesel units. 4. The diesels are now relegated to standby service. ERMU obtains essentially all its electrical requirements from the landfill gas-to-electric plant, and wholesale from Great River Energy (GRE). 5. Although the diesels do not run much, they are valuable to ERMU. The diesels allow ERMU to carry critical ERMU loads during outages on the interconnection, and the diesels allow ERMU to receive capacity credits on wholesale power purchases. 6. ERMU runs the diesels under an Operating Permit from the Minnesota Pollution Control Agency. 7. The Environmental Protection Agency (EPA) has formulated new Emissions Regulations for stationary diesel engine electrical generating units, such as those owned by ERMU. These standards are National Emissions Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines (NESHAP-RICE). 8. Although the NESHAP-RICE standards have been formulated, they are currently being reconsidered in response to public comments. It is anticipated that new Emissions Standards will be finalized perhaps within the next year. However, it is not known if the allowable hours of operation for Emergency Units will be increased. 16 10. All engines built after 6/12/2006 must be built to include the new standards. None of ERMU's diesels comply with the new standards. 11. The new regulations state that by 8/3/2010 an Initial Notification to the EPA was required regarding the affected sources. ERMU did meet this requirement. 12. The new regulations state that if the diesel is not upgraded to meet the new standards, it can be designated an Emergency Unit, and can run up to 100 hours/year for readiness testing, but only 15 hours (which is part of the 100 hours) for defined emergency running. It can run 50 hours/year for non- emergencies, but 50 hours must be part of the 100 hours, and the unit can receive no financial accreditation for the running. The Emergency Unit can run for unlimited hours during an outage on the interconnection. 13. If the ERMU diesels are to continue to be able to operate the number of hours permitted by the current MPCA permit, emissions controls must be placed on whichever diesels are selected to operate that way. The given diesel must be retrofitted with a direct oxidation catalyst (DOC), which can be placed in line with the existing exhaust silencer, or the exhaust silencer can be replaced with a combination exhaust silencer and DOC. The new system must include installation of a closed crankcase ventilation system or filtered open crankcase system. An emissions monitoring system must be installed with ongoing emissions records kept at the job site. Approved low sulfur fuel oil must be used in the diesel. After the conversion is complete, testing needs to be done to assure emissions are reduced by 70%, or to 23 ppmvd. All units must be compliant with NESHAP by 5/3/2013. 14. In 2010, the diesels allowed ERMU to receive a $352,440 in capacity credits plus fuel, labor, maintenance, and overhead costs for URGE tests 15. Under the proposed rules, municipals in an Emergency Demand Response (EDR) program could not run their diesels for the EDR, more than 15 hours per year, and could not receive capacity credits for this capability. 17 16. The Minnesota Municipal Utilities Association, Iowa Association of Municipal Utilities, and Central Minnesota Municipal Power Agency have asked EPA to allow operation of the diesels without emissions controls for up to 100 hours/year, beyond the 100 hours for readiness running. Also, they have asked EPA to allow the diesels to continue to be used for financial gain to the municipal and to make the 100 hours athree-year rolling average. There is no assurance as to when EPA will rule on this request or how they will rule. 17. If the EPA agrees to the 100 hours/year or even 60 hours/year for EDR running, and EPA allows income from capacity credits, ERMU could designate the four diesels as Emergency Generators, and continue to obtain capacity credits. 18. If emissions controls are installed, the diesel(s) could run up to the hours/year allowed by the MPCA Permit. If they are designated as Emergency Units, they would be limited to far fewer hours of running per year. 19. The cost to install emissions controls on Units 3 & 4 is about $50/KW, equal to a total of $400,000. The cost of emissions controls on the Units 1 & 2 is approximately $100/KW, equal to a total of $110,000. 20. Emissions controls could be installed in six months after authorization to proceed from the Elk River Utilities Commission. 21. Option 1 is to not install emissions controls. The four diesels would be designated Emergency Units. Under the presently proposed regulations, ERMU would receive no capacity credits for the Emergency Units. However, if the EPA extends the hours of operation from 15 to 60 or 100 hours per year, plus 100 hours per year operation for readiness testing, plus allowing the units to be used for financial gain, ERMU could continue to receive capacity credits without installing emissions controls. 22. Option 2 is to install emissions controls on Units 3 & 4, if the EPA kept to its present regulations. The cost would be $400,000, and the completion time six months. In 2010, Units 3 & 4 provided capacity credits of $309,936, so the simple payback would be about 15 months. 18 APPENDIX PHOTOS OF EQUIPMENT 1. Unit 1. Worthington Model SDD-6, 550 KW, 360 RPM, Electric Machinery generator, installed in 1947. 2. Unit 2. Worthington, Model SDD-6, 550 KW, 360 RPM, Electric Machinery generator, installed in 1947. 3. Unit 3. Cooper-Bessemer, Model LSV-I6-GDt, 3000 KW, 327 RPM, Electric Machinery generator, installed in 1961. 4. Unit 4. Worthington, Model SWCGO-16, 5000 KW, 514 RPM. Electric Machinery generator, installed in 1973. 5. Exhaust Silencers. Units I & 2 tailpipes are on the left, with exhaust silencers located in the brick housing. Unit 3 silencer is next in line. 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