Gazette photo by Lawrence Pierce of the Kanawha River Plant in Glasgow, W.Va.

There’s been a fair amount of hand-wringing about the planned closure by American Electric Power’s Appalachian Power subsidiary of the Kanawha River, Philip Sporn and Kammer power plants (see especially Daily Mail stories here and here).  Several years after the company’s decisions were announced, all this consternation led staff over at the state Public Service Commission to ask the PSC to investigate the closures.

Lawyers for Appalachian Power responded initially by pointing out that they have actually already provided the commission with a great deal of information on the matter as part of several previous cases.  That wasn’t good enough for the PSC, and commissioners ordered the power company to provide more details.  Appalachian lawyers did that yesterday, providing this 90-page filing.

Among the more interesting parts of Appalachian’s response:

— Almost all of the operating employees of the Disposition Units have been reassigned or have retired or taken severance.

— Compliance with the MATS Rules would require significant construction work. It might be possible for Disposition Units to meet the requirements of the MATS Rule by constructing Selective Catalytic Reduction (“SCR”) and Flue Gas Desulfurization (“FGD) systems … The installation of SCR and FGD systems would require installation of material handling systems, wastewater treatment systems, Absorber vessels, new ductwork, new stack exhausts, and numerous other systems. APCo has not undertaken any design work for SCR or FGD systems for the Disposition Units because the costs were deemed to be prohibitive, in light of the age and condition of the units.

— Because of the time for the construction of such systems, any Disposition Units at which it was decided to construct these systems could not be returned to service for a minimum of approximately five ( 5 ) years from the date such construction projects were begun.

— The Company has not performed any detailed cost estimates because the order of magnitude of the costs was so tremendous that APCo deemed it imprudent, given the age and condition of the Disposition Units, to have its customers bear such costs, particularly over the comparatively short anticipated lives of any of  the conversion or retrofit projects discussed above.

Citing previous testimony to the PSC, Appalachian lawyers also explained:

APCo looked at three alternatives for Kanawha River Units 1 and 2 and Sporn Units 1 and 3 and concluded that retrofitting these units with environmental
controls was not economical. Specifically, for the Kanawha River units, which are of a similar design to the Clinch River units, two options were considered that would allow the units to operate for an additional ten years. These options ranged in cost from $914kW to $2,407kW. Another option was considered that would have extended the Kanawha River units’ lives for five years, and this was estimated to cost $486/kW. These initial capital costs are significantly greater than the Clinch River gas conversion cost of $134kW, so they were not subjected to further evaluation.

 To put these costs in perspective, the estimated cost of a new combined cycle gas fired plant is approximately $lOOOkW and comes with the added benefits of a thirty-year life span, greater efficiency, and the ability to provide both capacity and base load energy. In addition, it should also be noted that installation of SCR and FGD systems on any Disposition Units would he proportionally more expensive (on a dollars per kilowatt installed basis) than was the installation of SCR and FGD systems on APCo’s supercritical units (Amos Units 1, 2, and 3 and Mountaineer). Although the Disposition Units are smaller, much of the same equipment would need to he installed at a Disposition Unit. Also, since these generating units are older, their designs are less accommodating to the addition of new equipment.

And the kicker:

The Companies’ engineers do not regard any such projects as having useful lives in excess of ten (10) years.