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MEMORANDUM

SUBJECT: Summary of Environmental and Cost Impacts of Proposed Revisions
to Portland Cement New Source Performance Standards (40 CFR Part 60,
subpart F)

FROM: Mark Bahner, RTI

Melissa Icenhour, RTI

Mike Laney, RTI

Keith Barnett, EPA

TO: Docket Number EPA-HQ-OAR-2007-0877

DATE: May 29, 2008

**I. Introduction**

To meet the requirements of section 111(b)(1)(B) of the CAA, the
Environmental Protection Agency (EPA) is currently conducting the fourth
review of the new source performance standards (NSPS) for Portland
Cement Plants (PCP). The PCP NSPS was promulgated on December 23, 1971
(40 CFR Part 60 subpart F, 36 FR 24876) and subsequently reviewed three
times (39 FR 20793, June 14, 1974; 39 FR 39874, November 12, 1974; and
53 FR 50354, December 14, 1988). Subpart F requires new, modified, or
reconstructed affected facilities at PCP to achieve emission levels that
reflect the best demonstrated system of continuous emission reduction,
considering cost, non-air quality health, environmental, and energy
impacts. These emission levels, referred to as "best demonstrated
technology (BDT)," are specified in subpart F.

The purpose of this memorandum is to document the methodology used to
estimate the environmental and cost impacts associated with this NSPS
review. The impacts in this memorandum are based on a projected number
of 20 new kilns over the five year period following promulgation.
Section II discusses the impacts of this NSPS review (scheduled for
promulgation in 2009), including an overview of the proposed amendments
resulting in impacts and the methodology used to develop the impact
estimates.

**II. Subpart F Impacts Estimated for 2009 Promulgation of NSPS Review**

A.  Affected Industry and Proposed Changes to Subpart F

The portland cement manufacturing industry is comprised of an estimated
105 cement plants capable of producing clinker and operating a total of
approximately 178 kilns (PCA, 2007). Based on industry capacity
expansion estimates (PCA, 2006), it is projected that by the fifth year
following promulgation of the amendments, 20 new kilns will come on line
and clinker production capacity will increase by approximately
24,000,000 tons.

To illustrate impacts of the proposed NSPS for cement manufacturing,
impacts are calculated for a preheater/precalciner kiln having a clinker
production capacity of 1,200,000 tons per year, which is considered
representative of new preheater/precalciner kilns. Because of their
energy efficiency and higher production capacity, all new kilns are
expected to be preheater/precalciner kilns. Impacts are also estimated
for the fifth year after promulgation, in which it is assumed that 20
new kilns, each producing 1,200,000 tons of clinker per year will have
been built.

The current subpart F NSPS review is scheduled to be promulgated in
2009. The impacts of concern for the NSPS review are incremental
impacts, specifically the difference in impacts associated with the
current NSPS and the impacts associated with any changes in NSPS
requirements resulting from the 2009 NSPS amendments. The impacts are
determined over a period of five years following promulgation of the
2009 NSPS revisions. Thus, the affected facilities of concern are those
installed from 2009 to 2013. Baseline represents the impacts associated
with application of the current NSPS. The incremental impacts of the
2009 NSPS review are determined by comparison to the baseline impacts.
Changes in requirements being proposed as part of the 2009 NSPS review
that could result in significant incremental impacts include those
summarized in Table 1.

**Table 1.** Summary of proposed changes to subpart F and type of
incremental impacts.

  -------------------------------------------- --------------------------
  **Proposed rule change**                     **Type of Incremental
                                               Impact**

  ▪ A reduction in the PM stack emission limit Costs to replace standard
  for kilns from 0.5 lb of PM/ton of clinker   fabric bags with more
  (0.3 lb/ton of feed) to 0.086 lb of PM/ton   expensive membrane bags.
  of clinker.                                  Emission reductions are
                                               also estimated.

  ▪ A reduction in the PM stack emission limit Clinker coolers are
  for clinker coolers from 0.17 lb of PM/ton   already meeting the new
  of clinker (0.1 lb/ton of feed) to 0.086 lb  limit, but the cost of bag
  of PM/ton of clinker.                        leak detectors are
                                               estimated.

  ▪ Addition of a NO~x~ limit of 1.5 lb NO~x~  Costs to install SNCR.
  /ton clinker.                                Emission reductions are
                                               also estimated.

  ▪ Addition of a SO~2~ limit of 1.33 lb       Costs to install alkaline
  SO~2~/ton clinker or 90% reduction of SO~2~  wet scrubbers. Emission
  across the control device.                   reductions are also
                                               estimated.

  ▪ Addition of bag leak detectors on all new  Capital costs of
  baghouses.                                   installation and annual
                                               costs of operation.

  ▪ Addition of continuous NO~x~ monitors on   Capital costs of
  new kilns.                                   installation and annual
                                               costs of operation.

  ▪ Addition of continuous SO~2~ monitors on   Capital costs of
  new kilns.                                   installation and annual
                                               costs of operation.

  ▪ Addition of continuous flow monitors on    Capital costs of
  new kilns.                                   installation and annual
                                               costs of operation.
  -------------------------------------------- --------------------------

The air quality impacts and costs of the final amendments for portland
cement manufacturing were calculated using the following assumptions:

-   Wet alkaline scrubbers will be installed on four new kilns for the
    control of SO~2~ emissions;

-   New kilns will be equipped with reverse air baghouses using membrane
    bags rather than fabric bags;

-   SNCR will be installed on all new kilns to control NO~x~ emissions;

-   NO~x~ monitors will be installed on all new kilns;

-   SO~2~ monitors will be installed on all new kilns; and

-   Bag leak detectors will be installed on baghouses on all new kilns
    and clinker coolers.

B.  Air Quality Impacts

The various impacts on emissions of nitrogen oxides (NO~x~), sulfur
dioxide (SO~2~) and particulate matter (PM) are calculated for different
control options. These control options will be summarized in the
discussion of air quality impacts, below. Direct air impact reductions
will be calculated, and where appropriate, indirect air impacts will be
calculated, such as the increase in emissions from additional
electricity or fossil fuel require to power control devices, water
quality impacts (e.g., from scrubbers), and solid waste impacts (e.g.,
from disposal of spent sorbents or catalysts).

[Nitrogen Oxides (NO~x~)]{.underline}

EPA recently issued an alternative control techniques (ACT) document
addressing the emissions and control of NOx from new cement kilns (EPA,
2007). Unless noted otherwise, this document is the source of the
information on NOx emissions and controls presented here.

The high temperatures and oxidizing atmospheres required for cement
manufacturing are favorable for NO~x~ formation. In cement kilns, NO~x~
emissions are formed during fuel combustion primarily by the oxidation
of molecular nitrogen present in combustion air (referred to as thermal
NO~x~) and the oxidation of nitrogen compounds in fuel (referred to as
fuel NO~x~). Many states issuing construction and operating permits for
new kilns have specified emission limits for NO~x~. In recently built
kilns, emissions of NO~x~ are typically reduced through process controls
such as burner design and staged combustion in the calciner (SCC). NO~x~
emissions from kilns using process designs such as low NO~x~ burners and
SCC average about 2.5 lb/ton of clinker (EPA, 2007). Add-on controls
used to reduce NO~x~ emissions include selective noncatalytic reduction
(SNCR) and selective catalytic reduction (SCR). In recent new source
review procedures, states have determined best available control
technology (BACT) to be SNCR in addition to well designed SCC and other
process designs such as low NO~x~ burners. In SNCR systems, ammonia,
urea or another reagent is injected in the flue-gas into an appropriate
temperature zone and at an appropriate ratio of ammonia to NO~x~. On
average, SNCR achieves approximately a 35 percent reduction in NO~x~ at
a ratio of ammonia-to-NO~x~ of about 0.5 and a reduction of 63 percent
at an ammonia-to-NO~x~ ratio of 1.0. At high ratios, some ammonia may
not react with NO~x~ and will be emitted (ammonia slip). Another NO~x~
control technology, SCR, is used in the electric utility industry to
reduce NO~x~ emissions from boilers and, to date has been used worldwide
on three cement kilns. SCR is capable of reducing NO~x~ emission by
about 80 percent. Currently, SCR is not used on any cement kilns in the
U.S.

Four options were evaluated for control of NO~x~ emissions. The first
option was to maintain the baseline of no limit and no additional
control. The other three options are given in terms of pounds of NO~x~
per ton of clinker (lb/ton clinker). The three options evaluated were
1.95 lb/ton clinker, 1.5 lb/ton clinker, and 0.5 lb/ton clinker.

In choosing these NO~x~ emission limit options, recently issued permits,
recent BACT determinations and recent emissions data for
preheater/precalciner kilns were reviewed. At three recently permitted
preheater/precalciner kilns utilizing well designed and operated process
designs including SCC, averaged NO~x~ emissions of 1.62, 1.88 and 1.97
lb/ton of clinker were measured for Titan America-Pennsuco, in Medley,
FL, Little Giant Cement in Harleyville, SC, and CEMEX in Santa Cruz, CA
(Bahner, 2008a). These kilns are not equipped with additional add-on
controls. However, based on data from equipment vendors and other
facilities with more difficult to burn raw materials, we believe that
future well-designed and operated cement kilns, which will incorporate
SCC and low-NO~x~ burners, will meet a level of 2.5 lb/ton of clinker on
average. This level is the baseline level of control that would occur
with no additional regulatory action.

The second control evaluated was 1.95 lb/ton clinker, which is a common
level established as BACT in recent permits for new sources (Bahner,
2007). As previously noted, some new facilities meet this level of
control using low-NO~x~ burners and SCC. However, we expect that, on
average, new facilities would require a SNCR removal efficiency of 22
percent SNCR to meet this level, which is well within the range
demonstrated for SNCR.

The third control level evaluated was 1.5 lb/ton clinker, and was
established based on our assessment of the best demonstrated performance
of SNCR. Data on SNCR show a performance that ranges from approximately
20 to 80 percent NO~x~ reduction. We estimate that about 50 percent
NO~x~ emission reductions represents a reasonable level of performance
of SNCR over the long term. Though new kilns on average will have
emissions of 2.5 lb/ton prior to the application of add-on controls,
there may be some situations where specific raw materials properties
will result in higher NO~x~ emissions. For this reason we assumed a
maximum baseline of 3.0 lb/ton and 50 percent emission reduction by SNCR
to establish a 1.5 lb/ton control level. Data available for Suwannee
American Cement Company, which operates with SNCR, indicated an average
NO~X~ value of 1.44 lb/ton, and a calculated 99^th^ percentile 30-day
rolling average value of 1.58 lb/ton (Bahner, 2008a).

The fourth option evaluated was 0.5 lb/ton of clinker based on the
performance of SCR. There are currently no operating SCR systems on
cement kilns in the United States, so SCR currently is not demonstrated
in the U.S.

Table 2 shows the NOx annual reductions achieved for each option, for a
single kiln producing 1,200,000 tons per year (tpy) of clinker, and
nationwide for 20 kilns, each producing 1,200,000 tpy of clinker.
Emissions reductions are presented both cumulatively from the baseline
and incrementally compared to the next less-stringent measure. For
example, for the four emission limit options of 2.5, 1.95, 1.5 and 0.5
lb/ton of clinker, the decreases in lb/ton of clinker relative to the
next less stringent option are 0, 0.55, 0.45 and 1 lb/ton, respectively.
In contrast the total reductions (relative to the 2.5 lb/ton baseline
level) are 0, 0.55, 1, and 2 lb/ton, respectively. Table 2 also presents
both the incremental and total emission reductions for a single kiln
producing 1.2 million tpy of clinker. As an example of how these
reductions are calculated, for a 1.2 million tpy kiln emitting at 1.5
lb/ton (Option 3) versus 2.5 lb/ton (Option 1), the total reduction
would be 600 tons (i.e., 2.5 lb/ton minus 1.5 lb/ton, or 1.0 lb/ton,
times 1.2 million tpy, or 1.2 million pounds, or 600 tons). Table 2 also
has annual nationwide reductions, based on 20 new kilns operating at 1.2
million tpy each over the 5-yr period after promulgation,. Nationwide
emission reductions are calculated incrementally (i.e., compared to the
next most stringent option) and in total (compared to the baseline,
Option 1).

**Table 2. Options considered for NOx reductions from kilns.**

+-----+--------+---------+--------+---------+-------+--------+------+
| Opt | Em     |         |        | Per     |       | Annual |      |
| ion | ission |         |        | Kiln    |       | Nati   |      |
|     | Fa     |         |        | Red     |       | onwide |      |
|     | ctors, |         |        | uctions |       | Redu   |      |
|     | per    |         |        |         |       | ctions |      |
|     | ton of |         |        | (@1.2   |       |        |      |
|     | c      |         |        | million |       | (based |      |
|     | linker |         |        | tpy     |       | on 20  |      |
|     |        |         |        | kiln    |       | kilns  |      |
|     |        |         |        | prod    |       | of 1.2 |      |
|     |        |         |        | uction) |       | m      |      |
|     |        |         |        |         |       | illion |      |
|     |        |         |        |         |       | tpy    |      |
|     |        |         |        |         |       | each)  |      |
+-----+--------+---------+--------+---------+-------+--------+------+
|     | Em     | Incr    | Total  | Incr    | Total | Incre  | T    |
|     | ission | emental |        | emental |       | mental | otal |
|     | Limit  | Red     | Red    |         | Redu  |        |      |
|     |        | uction\ | uction | Re      | ction | (tons) | (t   |
|     | (l     | (       |        | duction | (     |        | ons) |
|     | b/ton) | lb/ton) | (l     |         | tons) |        |      |
|     |        |         | b/ton) | (tons)  |       |        |      |
+-----+--------+---------+--------+---------+-------+--------+------+
| 1   | 2.5    | 0       | 0      | 0       | 0     | 0      | 0    |
+-----+--------+---------+--------+---------+-------+--------+------+
| 2   | 1.95   | 0.55    | 0.55   | 330     | 330   | 6,600  | 6    |
|     |        |         |        |         |       |        | ,600 |
+-----+--------+---------+--------+---------+-------+--------+------+
| 3   | 1.5    | 0.45    | 1      | 270     | 600   | 5,400  | 12   |
|     |        |         |        |         |       |        | ,000 |
+-----+--------+---------+--------+---------+-------+--------+------+
| 4   | 0.5    | 1       | 2      | 600     | 1,200 | 12,000 | 24   |
|     |        |         |        |         |       |        | ,000 |
+-----+--------+---------+--------+---------+-------+--------+------+

[Particulate Matter (PM)]{.underline}

All new kilns are expected to use fabric filters for PM control. Fabric
filters are the most common PM control technology used for portland
cement processes. In selecting the proposed PM emission limit for new
kilns, three control options were considered that represented the
emissions limits achievable for fabric filters applied to cement kilns.
One option was the current level of 0.3 lb/ton of feed (which is
equivalent to 0.5 lb/ton of clinker).

The second option was to set a new level that was equivalent to PM
levels established as part of recent BACT determinations. These levels
range from 0.09 to 0.28 lb/ton of clinker with an average of 0.16 lb/ton
of clinker. The second option was chosen as the average value of 0.16
lb/ton of clinker. Current fabric filter designs for new
preheater/precalciner kilns routinely achieve this level (Bahner,
2008b).

The third PM control level considered was 0.086 lb/ton clinker. This is
the level equivalent to the currently proposed new source level for
cement kilns that fire hazardous waste. In order to evaluate control
device that are representative of the latest fabric filter design, 19
emission tests conducted on four portland cement kilns controlled by
fabric filters with membrane bags, where the kilns had been built in the
last 10 years, were reviewed,. Thirteen of those tests were on a cement
kiln that burns hazardous waste. No difference is expected in the
performance of a fabric filter for PM applied to a kilns that burn
hazardous waste and those that do not because PM emissions are largely
contributed by non-hazardous waste feed streams, and because fabric
filters control PM emissions generally to the same concentration
irrespective of the PM loading at the inlet. The individual test results
converted to an output basis ranged from 0.0023 to 0.10176 lb/ton of
clinker with an average of 0.0357 lb/ton. In order to account for
variability, statistical variation was analyzed by calculating a
standard deviation of the test averages, multiplying the standard
deviation by the t value for the 95th or 99th percentile, and adding
this value to the average of all the tests. A level of 0.0830 lb/ton of
clinker represented an emissions limit that will not be exceeded 95
percent of the time and a level of 0.1025 lb/ton of clinker represented
an emissions limit that will not be exceeded 99 percent of the time. The
emission test results and results of the statistical analysis are
presented in Attachment 5.

A different statistical analysis of the data from the hazardous
waste-burning cement kiln equipped with a membrane fabric filter was
performed, applying to the data a so-called universal variability factor
derived from the performance of the best performing (lowest emitting) PM
performers equipped with fabric filters across the hazardous waste
combustor source category. This variability factor quantifies both
short-term and long-term operating variability, i.e., variability
associated with the conditions of the individual compliance test and
variability associated with the performance of the control equipment
over time. (See 72 FR 54878-79, September 27, 2007.) (This approach is
more sophisticated, since it accounts for both short-term and long-term
variability, whereas variability in the individual runs comprising the
compliance tests (i.e., the 95th or 99th percentile of those data), is
more a measure of short-term variability alone, see 72 FR 54878). Using
this approach, a value of 0.0069 gr/dscf, corrected to 7 percent oxygen,
was calculated. (See 71 FR 14669, March 23, 2006.) Using a typical value
of 54,000 dry standard cubic feet (dscf) of exhaust produced per ton of
kiln feed and one ton of clinker producer per 1.65 tons of feed, 0.0069
gr/dscf is equivalent to 0.086 lb/ton of clinker. At this control level,
more expensive membrane-coated bags would be needed to replace standard
fabric bags in the fabric filter.

Table 3 shows the PM reductions that can be achieved under each option
for a single model producing 1,200,000 tons per year (tpy) of clinker,
and nationwide for twenty kilns, each producing 1,200,000 tpy of
clinker. Emissions reductions are presented both cumulatively from the
baseline if possible, and incrementally compared to the next
less-stringent measure.

**Table 3. Options considered for PM reductions from kilns.**

+------+-------+--------+---------+--------+------+----------+------+
| Op   | Emi   |        |         | Per    |      | Na       |      |
| tion | ssion |        |         | Kiln   |      | tionwide |      |
|      | Fac   |        |         | Em     |      | Emission |      |
|      | tors, |        |         | ission |      | Re       |      |
|      | per   |        |         | Red    |      | ductions |      |
|      | ton   |        |         | uction |      |          |      |
|      | of    |        |         |        |      | (based   |      |
|      | cl    |        |         | (@1.2  |      | on 20    |      |
|      | inker |        |         | m      |      | kilns of |      |
|      |       |        |         | illion |      |          |      |
|      |       |        |         | tpy    |      | 1.2      |      |
|      |       |        |         | kiln   |      | million  |      |
|      |       |        |         | produ  |      | tpy      |      |
|      |       |        |         | ction) |      | each)    |      |
+------+-------+--------+---------+--------+------+----------+------+
|      | Emi   | Incre  | Total   | Incre  | T    | Inc      | T    |
|      | ssion | mental | Re      | mental | otal | remental | otal |
|      | Limit | Red    | duction |        |      | (tpy)    |      |
|      |       | uction | (       | Red    | (    |          | (    |
|      | (lb   |        | lb/ton) | uction | tpy) |          | tpy) |
|      | /ton) | (l     |         |        |      |          |      |
|      |       | b/ton) |         | (tpy)  |      |          |      |
+------+-------+--------+---------+--------+------+----------+------+
| 1    | 0.5   | 0      | 0       | 0      | 0    | 0        | 0    |
+------+-------+--------+---------+--------+------+----------+------+
| 2    | 0.16  | 0.34   | 0.34    | 204    | 204  | 4,080    | 4    |
|      |       |        |         |        |      |          | ,080 |
+------+-------+--------+---------+--------+------+----------+------+
| 3    | 0.086 | 0.074  | 0.414   | 44.4   | 2    | 888      | 4968 |
|      |       |        |         |        | 48.4 |          |      |
+------+-------+--------+---------+--------+------+----------+------+

[Sulfur Dioxide (SO~2~)]{.underline}

Based on reviews of recent BACT determinations and permits, control
technologies that were not being used at the time of the previous NSPS
review are now being used to control SO~2~ emissions from cement kilns.
As a result, wet scrubbers and lime injection were evaluated as
potential control technologies for portland cement operations. The
proposed emission limit takes into account the inherent scrubbing
ability of the naturally alkaline raw materials used in the cement
manufacturing process.

Sulfur dioxide from a cement kiln comes from the oxidation of sulfur
from two sources. The first is sulfur in the fuel, which mixes with lime
in the kiln and preheater with little or no SO~2~ emitted into the
atmosphere from this source. The other source of SO~2~ is the raw
materials, which may be oxidized to SO~2~ in the kiln system when mixed
with sufficient oxygen.

For most portland cement plants, the levels of sulfur in raw materials
are sufficiently low and most of the SO~2~ generated is removed by the
natural scrubbing action of the kiln raw feed. In instances where the
sulfur content of raw materials is higher, uncontrolled SO~2~ emissions
can be significant. In those situations, add-on controls may be
necessary to prevent high SO~2~ emissions.

The first type of SO~2~ control equipment considered is alkaline
scrubbers. They are capable of achieving a 90 to 95 percent reduction in
SO~2~ emissions on cement kilns (Bahner and Laney, 2008). The difference
between SO~2~ emissions before and after the scrubber at the Lehigh
Cement plant in Davenport, Iowa was approximately 96 percent (Bahner,
2008c; Bahner and Laney, 2008).

The second type of SO~2~ control equipment is lime injection, which
consists of injecting lime into a duct downstream of the preheater, or
in some cases injecting lime into the first two preheater stages to
remove SO~2~. At some facilities lime injection is only used when
increases on SO~2~ emission above a specified level are detected, such
as when the raw mill is down. Dry lime systems typically achieve an
emission reduction of approximately 70 percent (NESCAUM, 2005), although
there are systems that can achieve 90 percent. (Bahner and Laney, 2008).

Four options were evaluated for control of SO~2~ emissions. The first
option was to maintain the baseline of no SO~2~ emission limit, and the
other three options include an emission limit of SO~2~ in pounds per ton
of clinker (lb/ton clinker). Air quality impacts under each of the
control options depend on the sulfur content of the raw materials. Raw
materials containing high levels of sulfur are likely to result in high
SO2 emissions unless controls are applied.

High uncontrolled SO2 emissions associated with high sulfur raw
materials were based on examples where facilities have applied wet
scrubbers for SO~2~ control and were assumed to emit uncontrolled SO~2~
at a level of 13 lb/ton. Uncontrolled SO~2~ emissions of 1.3 lb/ton of
clinker (0.8 lb/ton of feed) represent a moderate emission level. The
moderate uncontrolled SO~2~ emission level was based on the averages of
18 data points for tested NSPS facilities and was assumed to represent
moderate raw material sulfur levels (Heath, 1996). Low uncontrolled SO2
emissions from low sulfur raw materials are based on examples from
Florida where kilns emit uncontrolled SO~2~ at levels of 0.2 lb/ton
clinker or less (Bahner, 2008c).

The first control option was no additional control of SO~2~ other than
the inherent control achieved by the kiln and raw mill. State BACT
determinations usually identify inherent SO~2~ removal as BACT. The
second option selected was 1.33 lb/ton clinker which represents a recent
BACT determination level of a facility (TXI, Midlothian, TX) with high
sulfur raw materials that applied an alkaline wet scrubber for SO~2~
control (FL DEP, 2005). The third option evaluated was 0.4 lb/ton
clinker, which is based on the average of SO~2~ permit limits from
recent BACT determinations which ranged from 0.06 to 1.33 lb/ton of
clinker (Bahner, 2007). The fourth option evaluated was 0.2 lb/ton
clinker which is typically specified in Florida for kilns with low
sulfur raw materials and is one of the lowest levels from recent BACT
determinations.

The proposed SO~2~ emission limit for new kilns is 1.33 lb/ton of
clinker, or alternatively, demonstration of a 90 percent SO~2~ emissions
reduction measured across the control device, such as an alkaline
scrubber as BDT. Option 1 would have allowed kilns with high sulfur raw
materials, several of which are currently controlled with wet scrubbers,
to emit significant amounts of SO~2.~

Table 4 shows the SO~2~ reductions that can be achieved by a wet
scrubber that gets a SO2 emission reduction of 95 percent under option 1
and 2 for high sulfur kiln input materials. The emission reduction is
the same under options 3 and 4.

**Table 4. Options considered for SO~2~ reductions for kilns with
high-sulfur inputs.**

+-------+-------------+-----------+--------------------+--------------+
| O     | Emission    | Control   | Annual Emissions   | Annual       |
| ption | Limit       |           | (@1.2 million tpy  | Reductions   |
|       |             |           | kiln production)   | (tons)       |
|       | (lb/ton     |           |                    |              |
|       | clinker)    |           | (tons)             |              |
+-------+-------------+-----------+--------------------+--------------+
| 1     | Baseline    | None      | 7,800              | 0            |
|       | (13)        |           |                    |              |
+-------+-------------+-----------+--------------------+--------------+
| 2     | 1.33        | Wet       | 390                | 7,410        |
|       |             | scrubber  |                    |              |
+-------+-------------+-----------+--------------------+--------------+

Table 5 shows the SO~2~ reductions that can be achieved by option for
medium sulfur kiln input materials. For option 2, no additional control
is necessary because the uncontrolled emission level is below the SO2
limit of 1.33 lb/ton. Under option 3, a less costly lime injection
system that gets 70 percent removal is capable of meeting the limit of
0.4 lb/ton. A wet scrubber would be required under option 4.

**Table 5. Options considered for SO~2~ reductions for kilns with
medium-sulfur inputs.**

+-----+----------+---------------------+------------+--------+--------+
| Opt | Emission | Control             | Annual     | Redu   | Em     |
| ion | Limit    |                     | Emissions  | ctions | ission |
|     |          |                     |            | (tons) | Level  |
|     | (lb/ton  |                     | (@1.2      |        | After  |
|     | clinker) |                     | million    |        | C      |
|     |          |                     | tpy kiln   |        | ontrol |
|     |          |                     | p          |        |        |
|     |          |                     | roduction) |        | (      |
|     |          |                     |            |        | lb/ton |
|     |          |                     | (tons)     |        | cl     |
|     |          |                     |            |        | inker) |
+-----+----------+---------------------+------------+--------+--------+
| 1   | Baseline | None                | 780        | 0      | 1.3    |
|     | (1.3)    |                     |            |        |        |
+-----+----------+---------------------+------------+--------+--------+
| 2   | 1.33     | No reduction        | 780        | 0      | 1.3    |
|     |          | necessary           |            |        |        |
+-----+----------+---------------------+------------+--------+--------+
| 3   | 0.4      | Dry lime scrubber   | 234        | 546    | 0.39   |
|     |          | (DLS) (70%)         |            |        |        |
+-----+----------+---------------------+------------+--------+--------+
| 4   | 0.2      | Wet scrubber (WS)   | 39         | 741    | 0.065  |
|     |          | (95%)               |            |        |        |
+-----+----------+---------------------+------------+--------+--------+

For kilns with uncontrolled emissions (due to low sulfur input
materials, combined with the natural scrubbing effect of alkali
materials in the kiln) below 0.2 lb/ton, no controls for SO~2~ will be
necessary. The baseline SO~2~ emissions from a kiln producing 1.2
million tons per year would be 120 tpy (i.e., 1.2 million tons per year
times 0.2 lb/ton).

It is estimated that, nationwide, four kilns will be using high-sulfur
raw materials in the five years following promulgation. The emission
reductions in the fifth year will be 7,410 tpy times 4 kilns = 29,640
tpy.

[VOC and CO]{.underline}

Emissions of CO and unburned hydrocarbons (VOC/THC) are due to
incomplete oxidation. Methods to address these pollutants include more
complete oxidation either in the burner area (e.g. with higher levels
and better placement of the introduction of excess air) or by more
complete oxidation in a downstream control device, such as a
regenerative thermal oxidizer (RTO, where the "regenerative" portion of
the description refers to recovery of heat that would otherwise be lost
in the oxidation process). The VOC/THC from raw materials can be
significant if there are substantial organics in the raw material. The
only control technology identified to reduce CO emission is an RTO
(which also would concurrently reduce any VOC emissions). Activated
carbon injection (ACI) into a particulate control device can be used to
control VOC/THC (but not CO).

The proposed amendments will not contain limits for CO or VOC emissions
from cement kilns. VOC emission from new cement kilns will mainly result
from organics in the raw materials. Organic constituents in the raw
material can be driven off in the kiln preheater prior to reaching a
temperature zone that would result in combustion. New cement kilns are
currently subject to a 20 ppmv total hydrocarbon (THC) emissions limit
by the Portland Cement NESHAP. Because most of the THC are also VOC, the
THC limit also limits VOC, and serves as the baseline for the NSPS
analysis. This limit is based on the best performance of the
regenerative thermal oxidizer add-on control, which is the most
effective VOC emission control available for this source category.
Therefore we determined that no additional regulation of VOC emissions
is feasible.

Emissions of CO can come from two sources, unburned fuel from the
precalciner and CO evolved from the raw materials by the same mechanism
as the THC emissions. Unburned fuel represents an economic loss to the
facility. Therefore, new precalciners are designed to combust fuel as
efficiently as possible, and CO emissions from fuel combustion are
minimized, regardless of any potential emission limit.

As is the case for VOC, facilities with moderate or high levels of
organic materials in the feed would emit THC at levels high enough that
THC control would be required under the Portland Cement NESHAP.
Therefore, the THC limit in the Portland Cement NESHAP also serves as
the baseline of the CO analysis. As previously noted, the THC limit is
based on the best performance of the regenerative thermal oxidizer
add-on control, which is also the most effective CO emission control
available for this source category. Therefore we determined that no
additional regulation of CO emissions is feasible.

[Secondary Impacts]{.underline}

Secondary air quality impacts will result from the increased electrical
demands of control equipment required to comply with the final
amendments. The secondary impacts in this memorandum will include
impacts of additional electricity consumption and the pollution from
that consumption, water pollution, and solid waste impacts. The addition
of add-on controls, such as scrubbers, will increase electricity
demands. The electricity demand for pumping the reagent in an SNCR
system are negligible. The additional electricity usage by an alkaline
scrubber for a 1.2 million ton per year plant are as follows (see input
parameters for wet scrubber in cost section):

Scrubber - 12,075,355 kWh/yr

The emission factors used to estimate increased emissions of NO~x~, CO,
SO~2~, and PM~10~ from the increased electricity demand are as follows
(Docket item IV-B-25, Docket A-94-52):

NOx - 0.00446 lb/kWhr

CO - 0.00231 lb/kWhr

SO~2~ - 0.00765 lb/kWhr

PM10 - 2.25(10-4) lb/kWhr

Increases in secondary emissions resulting from the increased electrical
demand of an alkaline scrubber for a new 1,200,000 ton/yr kiln are
summarized in Table 6.

**Table 6. Secondary emissions for a 1,200,000 tpy kiln.**

+-----------+-----------+---------+-----------+-----------+-----------+
| Control   | Increased | In      |           |           |           |
|           | E         | creased |           |           |           |
|           | lectrical | Em      |           |           |           |
|           | Demand    | issions |           |           |           |
|           |           | (t      |           |           |           |
|           | (kWh/yr)  | ons/yr) |           |           |           |
|           |           | for     |           |           |           |
|           |           | 1.2M    |           |           |           |
|           |           | Ton/Yr  |           |           |           |
|           |           | Kiln    |           |           |           |
+-----------+-----------+---------+-----------+-----------+-----------+
|           |           | NO~x~   | CO        | SO~2~     | PM~10~    |
+-----------+-----------+---------+-----------+-----------+-----------+
| Wet       | 1         | 26.9    | 13.9      | 46.2      | 1.4       |
| Scrubber  | 2,075,355 |         |           |           |           |
+-----------+-----------+---------+-----------+-----------+-----------+

The total nationwide increase in emissions from the increased electrical
demands of scrubbers installed on four new kilns for the fifth year
following promulgation are presented in Table 7.

**Table 7. Nationwide secondary emissions.**

+--------------+-----------+----------+---------+---------+---------+
| Controls and | Increased | Na       |         |         |         |
| number of    | E         | tionwide |         |         |         |
| systems      | lectrical | I        |         |         |         |
|              | Demand    | ncreased |         |         |         |
|              |           | E        |         |         |         |
|              | (kWh/yr)  | missions |         |         |         |
|              |           | (        |         |         |         |
|              |           | tons/yr) |         |         |         |
+--------------+-----------+----------+---------+---------+---------+
|              |           | NO~x~    | CO      | SO~2~   | PM~10~  |
+--------------+-----------+----------+---------+---------+---------+
| Scrubbers    | 4         | 108      | 56      | 185     | 5       |
| (on 4 kilns) | 8,301,420 |          |         |         |         |
+--------------+-----------+----------+---------+---------+---------+

C.  Water Quality Impacts

The use of alkaline scrubbers will result in increased consumption of
water (for makeup water and production of the scrubber slurry). For a
new 1,200,000 ton/yr kiln, the additional water requirement is estimated
at 97,000,000 gallons per year (see input parameters for wet scrubber in
cost section). No water quality impacts are associated with the use of
SNCR systems. Based on the use of scrubbers on a total of four new kilns
over the 5-year period following promulgation, total water requirements
at the end of the fifth year will be approximately 388 million gallons.

D. Solid Waste Impacts

Additional solid waste will result from the disposal of scrubber slurry.
For a new 1,200,000 ton/yr kiln, the additional solid waste generated as
a result of the addition of the scrubber is estimated at 84,101 tons per
year (Docket item II-B-67, Docket No. A-92-53). However, the waste from
the scrubber contains synthetic gypsum and is typically dewatered and
returned to the process where it is mixed with clinker in the finish
mill. The result is that the waste is not disposed of in a landfill. No
solid waste impacts are anticipated with the use of an SNCR system. The
total additional solid waste generated at the end of the fifth year
following promulgation of the amendments will be an estimated 336,000
tons from the scrubber slurry of four scrubbers.

The additional solid waste generated from baghouses, in the form of
cement kiln dust, as a result of the more stringent PM requirement will
be 44.4 tons/yr for a 1,200,000 ton/yr kiln. This material is typically
considered product and is returned to the kiln or mixed with the cement.

E. Energy Impacts

The use of alkaline scrubbers on new kilns will increase electricity
consumption. The additional electricity required for an alkaline
scrubber added onto a new 1,200,000 ton/yr kiln is estimated at
12,075,355 kWh/yr. For the 5-year period following promulgation, the
additional electricity demand associated with the installation of
scrubbers on four new kilns will be 48,301,420 kWh.

F.  Cost Impacts

[NO~x~ Emissions]{.underline}

Four options were evaluated for control of NO~x~ emissions. The first
option was to maintain the baseline of no NOx limits. The other three
options are given in terms of pounds of NO~x~ per ton of clinker (lb/ton
clinker). The three options evaluated were 1.95 lb/ton clinker, 1.5
lb/ton clinker, and 0.5 lb/ton clinker.

Costs were evaluated for all four options. Costs for SNCR and SCR were
derived from *Alternative Control Techniques Document Update -- NO~x~
Emissions from New Cement* Kilns (EPA, 2007). Capital costs for SNCR
systems ranged from \$0.78 to \$2.88 per ton of clinker produced. An
average of \$1.76 per ton of clinker was used to estimate capital costs.
For the 1.95 lb/ton NOx option, an operating cost of \$0.51 per ton of
clinker was used to calculate annual costs. For the higher removal
efficiency necessary to meet the 1.5 lb/ton NOx limit, more reagent
would be required to meet the limit resulting in higher operating costs.
An average annual cost of \$1.01 per ton of clinker was used to estimate
annual costs to meet the Option 3 limit of 1.5 lb of NOx /ton of
clinker. The average capital costs for SCR were determined to be \$4.57
per ton of clinker while an average of \$2.50 per ton of clinker was
used to estimate annual operating costs for SCR.

The results of this analyses showed that the overall annualized cost of
control for both the 1.95 and the 1.5 levels were approximately \$2,000
per ton of NO~x~ reduction. Given the similarity of costs, Option 3 (1.5
lb/ton clinker) was chosen as BDT.

Assuming a kiln with a clinker capacity of 1,200,000 tons, the capital
cost of the SNCR is \$2,112,000 and the annual operating cost is
\$1,212,000.

Under the proposed amendments, compliance with the emission limits for
NO~x~ will be determined using continuous emissions monitoring systems.
Continuous flow rate monitors will also be required to determine
compliance. The capital/startup costs for NO~x~ and flow rate CEMS are
\$140,951 and \$35,780, respectively. Annual operations and maintenance
costs for NO~x~ and flow rate CEMS are \$41,809 and \$13,864,
respectively. All costs are derived from the CEMS Cost Model and include
a capital recovery factor of 0.1424 (equipment life of 10 years and a
yearly interest rate of 7%). Attachment 2 is the output file from the
CEMS Cost Model for NO~x~ CEMS. Attachment 3 is the output file from the
CEMS cost Model for flow rate CEMS.

Including the cost of CEMS, the annual operating and maintenance cost
per kiln is \$1,267,673 and the total capital cost per kiln is
\$2,288,731 for SNCR. Assuming that 20 new kilns will install SNCR to
comply with the NO~x~ emission limit, the total annualized cost is an
estimated \$25.4 million. Total capital cost over the 5-year period
following promulgation is an estimated \$45.8 million.

Table 8 shows the costs and potential reductions associated with each of
the four options for NO~x~ control.

**Table 8. Costs and cost effectiveness of NO~x~ emission limits for
1,200,000 ton/yr kiln.**

+----------------------+-------+-----------+-------------+-----------+
| **Option**           | **1** | **2**     | **3**       | **4**     |
|                      |       |           |             |           |
|                      | **(B  | **(1.95   | **(1.5      | **(0.5    |
|                      | aseli | lb/ton    | lb/ton      | lb/ton    |
|                      | ne)** | c         | clinker)**  | c         |
|                      |       | linker)** |             | linker)** |
+----------------------+-------+-----------+-------------+-----------+
| Capital cost,        | 0     | 2.3       | 2.3         | 5.7       |
| \$million            |       |           |             |           |
+----------------------+-------+-----------+-------------+-----------+
| Annualized cost,     | 0     | 0.7       | 1.3         | 3.1       |
| \$million/yr         |       |           |             |           |
+----------------------+-------+-----------+-------------+-----------+
| Total NO~x~          | 0     | 330       | 600         | 1,200     |
| reduction (tpy)      |       |           |             |           |
+----------------------+-------+-----------+-------------+-----------+
| Total C/E (\$/ton    | 0     | 2,023     | 2,113       | 2,546     |
| NO~x~)               |       |           |             |           |
+----------------------+-------+-----------+-------------+-----------+

[Particulate Matter (PM) Emissions]{.underline}

The costs of reverse air baghouses and standard fabric bags (for Options
1 and 2) were derived from the EPA Air Pollution Control Cost Manual.
The capital costs of non-membrane bags and a baghouse are estimated to
be \$4.78 per ton of clinker and annual operating costs are estimated to
be \$1.67 per ton of clinker. The total costs for a baghouse using
standard fabric bags on a kiln with a capacity of 1,200,000 tons of
clinker is estimated to be \$5,731,163 for capital cost and \$2,004,710
for annual cost.

The costs of reverse air baghouses and membrane bags (for Option 3) were
also derived from the EPA Air Pollution Control Cost Manual. The capital
costs of membrane bags and a reverse air baghouse are estimated to be
\$5.89 per ton of clinker and annual operating costs are estimated to be
\$1.82 per ton of clinker. The total cost for a baghouse with membrane
bags on a kiln with a capacity of 1,200,000 tons of clinker is estimated
to be \$7,065,703 for capital cost and \$2,180,919 for annual costs.

Because it is assumed that all options would use a reverse air baghouse,
the incremental cost of using membrane bags is the difference between
the cost of Options 1 and 2 and Option 3. Therefore, the incremental
costs are estimated as \$1,334,540 for capital cost and \$176,209 for
annual costs.

Bag leak detectors are used to monitor changes in particulate matter
emission rates within baghouses. A change in emission rate usually
indicates a bag leak or another type of failure within the baghouse.
Costs were estimated using the CEMS Cost Model, assuming that each
baghouse has 5 compartments and there is a separate sensor in each
compartment. It was assumed that the same bag leak detector could be
used for the clinker cooler baghouse as for the kiln baghouse, so the
costs were estimated using 10 sensors. The capital/startup cost for bag
leak detector CEMS is \$93,719. Annual operations and maintenance costs
for bag leak detector CEMS are \$34,748. All costs are derived from the
CEMS Cost Model and include a capital recovery factor of 0.1424
(equipment life of 10 years and a yearly interest rate of 7%).
Attachment 4 is the output file from the CEMS Cost Model for bag leak
detectors.

Including the cost of the bag leak detector, the annual operating and
maintenance cost per kiln is \$210,957 and the total capital cost per
kiln is \$1,428,253 for reverse air baghouses equipped with membrane
bags and a bag leak detector for each kiln/clinker cooler combination.
Assuming that 20 new kilns and clinker coolers will install reverse air
baghouses to comply with the PM emission limit, the total annualized
incremental cost is an estimated \$4.2 million. Total capital
incremental cost over the 5-year period following promulgation is an
estimated \$28.6 million.

The incremental PM reductions between baseline and Option 3 are
estimated to be 44 tons per year. This equals a cost effectiveness of
approximately \$3,900 per ton of PM reduction. The incremental fine PM
reductions (PM less than 2.5 microns in diameter) between baseline and
Option 3 are estimated to be 20 tons per year. This equates to a cost
effectiveness of approximately \$9,000 per ton of fine PM reduction.

[SO~2~ Emissions]{.underline}

Four options were evaluated for control of SO~2~ emissions. The first
option was to maintain the current limit and the other three options
include an emission rate of SO~2~ in pounds per ton of clinker (lb/ton
clinker). Control costs and cost reductions for the three emission rates
were evaluated based on varying levels of sulfur in the raw materials.
Low uncontrolled SO~2~ emissions from low sulfur raw materials were
based on examples from Florida where kilns emit uncontrolled SO~2~ at
levels of 0.2 lb/ton clinker or less. High uncontrolled SO~2~ emissions
associated with high sulfur raw materials were based on examples where
facilities had applied wet scrubbers for SO~2~ control and were assumed
to emit uncontrolled SO~2~ at a level of 13 lb/ton. Uncontrolled SO~2~
emissions of 1.3 lb/ton represent a moderate emission level. Moderate
uncontrolled SO~2~ emissions were based on the averages of 18 data
points for tested NSPS facilities and were assumed to represent moderate
raw material sulfur levels.

The first control option considered was no additional control of SO~2~
other than the inherent control achieved by the kiln and raw mill. State
BACT determinations usually identify inherent SO~2~ removal as BACT. The
second option evaluated was an SO~2~ limit of 1.33 lb/ton clinker which
represents a recent BACT determination level of a facility with high
sulfur raw materials that applied an alkaline wet scrubber for SO~2~
control. The third option evaluated was a limit of 0.4 lb/ton clinker,
which is based on the average of SO~2~ permit limits from recent BACT
determinations, ranging from 0.06 to 1.33 lb/ton of clinker. The fourth
option evaluated was 0.2 lb/ton clinker which is representative of
permit limits specified in Florida for kilns with low sulfur raw
materials and is one of the lowest levels from recent BACT
determinations.

Under the proposed amendments, the SO~2~ emission limit for new kilns
will be 1.33 lb/ton of clinker, or alternatively, demonstration of a 90
percent SO~2~ emissions reduction measured across the control device,
such as an alkaline scrubber as BDT. Option 1 was rejected because this
would allow kilns with high sulfur raw materials, several of which are
currently controlled with wet scrubbers, to emit significant amounts of
SO~2~. Controlling the high sulfur kilns to a level of 1.33 lb/ton
results in a cost per ton of SO~2~ removed of less than \$1000 per ton
of SO~2~ removal.

Options 3 and 4 were rejected because they would have resulted in cement
kilns using moderate sulfur content raw materials installing add-on
controls at a cost of over \$6,000 per ton of SO~2~ reduction. Also,
Options 3 and 4 would not be likely to achieve any significant
additional SO~2~ emission reductions over Option 2 for high sulfur kilns
because Option 2 already represents at least a 90 percent emission
reduction control for high sulfur raw materials.

Costs for the use of wet alkaline scrubbers on kilns are based on
detailed cement industry estimates of retrofitting an existing 804,000
ton per year preheater/precalciner kiln with a wet alkaline scrubber
(Zephyr, 2002). The industry cost estimates incorporated costing
procedures from the EPA Air Pollution Control Cost Manual. To adapt the
industry costs to our new 1,200,000 ton per year kiln, costs were scaled
up to account for the difference in exhaust gas flow rates and modified
to reflect installation on a new kiln rather than a retrofit. Costs were
also updated using Chemical Engineering cost index and a credit applied
for the use of the gypsum produced by the scrubber. Scrubbers produce a
slurry containing synthetic gypsum, which can be reused in the
production of portland cement. A scrubber on a 1.2 million ton/yr kiln
is estimated to produce 84,101 ton/yr of gypsum (Docket Item II-B-67,
Docket no. A-92-53). Using current estimates from the United States
Geological Survey (USGS), the price of gypsum was estimated at \$8.26
per ton. Actual costs to purchase gypsum for the production of cement
are probably higher primarily due to transportation costs. Assuming that
all synthetic gypsum can be reused in the production process, each
scrubber has a credit for recycled gypsum of \$694,674 per year.

Input parameters and annual cost inputs used in estimating costs are
shown in Table 9. Total capital investment for a wet alkaline scrubber
installed on a 1,200,000 ton/yr kiln is approximately \$28,101,000 and
total annual cost, including annualized capital (using 7% interest and a
20-year equipment life), operating costs, and the recycled gypsum credit
is approximately \$4,913,000. Capital and annual cost for a wet alkaline
scrubber on a 1,200,000 ton/yr kiln are shown in Table 10.

Under the proposed amendments, compliance with the emission limits for
SO~2~ will be determined using continuous emissions monitoring systems.
Continuous flow rate monitors will also be required to determine
compliance. The capital/startup costs for SO~2~ and flow rate CEMS are
\$143,135 and \$35,780, respectively. Annual operations and maintenance
costs for SO~2~ and flow rate CEMS are \$42,326 and \$13,864,
respectively. All costs are derived from the CEMS Cost Model and include
a capital recovery factor of 0.1424 (equipment life of 10 years and a
yearly interest rate of 7%). Attachment 1 is the output file from the
CEMS Cost Model for SO~2~ CEMS. Attachment 3 is the output file from the
CEMS cost Model for flow rate CEMS.

Including the cost of CEMS, the annual operating and maintenance cost
per kiln is \$4,969,000 and the total capital cost per kiln is
\$28,280,000 for alkaline scrubbers. Assuming that four new kilns will
install an alkaline scrubber to comply with the SO~2~ emission limit,
the total annualized cost of scrubbers is an estimated \$19.9 million.
Total capital cost over the 5-year period following promulgation is an
estimated \$113 million.

The cost of the alkaline wet scrubber is only dependent on the size of
the kiln so the costs are identical for any control option that would
require the use of alkaline scrubbers, assuming that the scrubber was
operated at its highest efficiency.

The amount of SO~2~ reduction is based on the alkaline scrubber having a
removal efficiency of 95% and baseline emissions of 7,800 tons for raw
materials with high sulfur content (and high uncontrolled SO~2~
emissions) and 780 tons for raw materials with moderate sulfur content
(and moderate uncontrolled SO~2~ emissions). It is estimated that
alkaline wet scrubbers will result in reductions of 7,410 tpy SO~2~ for
kilns using raw materials with high sulfur content and 741 tpy SO~2~ for
raw materials with moderate sulfur content. The resulting cost
effectiveness is approximately \$670 per ton of SO~2~ removed for raw
materials with high sulfur content and \$6,700 per ton of SO~2~ removed
for raw materials with moderate sulfur content.

Because lime injection may be used to reduce SO2 emissions in certain
instances, costs were estimated for a lime injection system for a
1,200,000 ton/yr kiln. Costs are derived from the same source as the wet
scrubber costs (Zephyr 2002). Input parameters and annual cost inputs
used in estimating costs are shown in Table 11. Total capital investment
for lime injection installed on a 1,200,000 ton/yr kiln is approximately
\$6,997,000 and total annual cost, including annualized capital (using
7% interest) and operating costs is approximately \$3,168,000. These
costs are shown in Table 12.

Including the cost of CEMS, the annual operating and maintenance cost
per kiln is \$3,224,000 and the total capital cost per kiln is
\$7,176,000 for lime injection.

The amount of SO~2~ reduction is based on lime injection having a
removal efficiency of 70% and baseline emissions of 780 tons for raw
materials with moderate sulfur content. It is estimated that alkaline
wet scrubbers will result in reductions of 540 tpy SO~2~ for raw
materials with moderate sulfur content. The resulting cost effectiveness
is \$5,970 per ton of SO~2~ removed for raw materials with moderate
sulfur content.

Table 13 shows the costs and potential reductions associated with each
of the four options for SO~2~ control.

**Table 9. Wet alkaline scrubber input parameters for new kiln model.**

  ---------------------------------------------------------- ------------
  INPUT PARAMETERS:                                          

                                                             

  \-- Clinker production rate, tons/yr                       1,200,000

  \-- Process operating hours, hr/yr                         7,920

  \-- Inlet waste gas temperature (^o^F):                    400

  \-- Inlet waste gas pressure (atm.):                       1

  \-- Pollutant in waste gas:                                SO2

  \-- pollutant emissions, lb/yr                             14,475,811

  \-- pollutant concentration, ppmv                          905

  \-- pollutant molecular weight                             64

  \-- Waste gas molecular weight (lb/lb-mole):               28.85

  \-- Solvent molecular weight (lb/lb-mole):                 18

  \-- Inlet waste gas flowrate (acfm):                       330,276.91

  \-- Scrubber gas pressure drop (in. water):                17

  \--Additional system pressure drop (FF and ducts), in.     10
  water                                                      

  \-- Liquid pressure drop for pump (ft of H2O):             60

  \-- Slurry flow rate, gpm                                  19,817

  \-- Outlet gas temperature, F                              140

  \-- Makeup water flow, gpm                                 105

  \-- Limestone consumption, tons/hr                         5.4060

  \-- Estimated control efficiency, percent                  95

  \-- Electricity consumption, kw                            

  scrubber and system fans                                   1105.0

                                                             

  limestone preparation                                      162.2

  cooler vent air to stack                                   257.4

                                                             

                                                             

  ANNUAL COST INPUTS:                                        

  Operating factor (hr/yr):                                  7,920

  Operating labor rate (\$/hr):                              22.5

  Maintenance labor rate (\$/hr):                            24.75

  Operating labor factor (hr/sh):                            2.5

  Maintenance labor factor (hr/sh):                          2.5

  Electricity price (\$/kWhr):                               0.062

  Limestone, \$/ton                                          5

  Solvent (water) price (\$/1000 gal):                       0.2

  Overhead rate (fraction):                                  0.6

  Annual interest rate (fraction):                           0.07

  Control system life (years):                               20

  Capital recovery factor (system):                          0.0944

  Taxes, insurance, admin. factor:                           0.04

  Credit for gypsum (\$/ton)                                 8.26

  Gypsum recycled (tons/yr)                                  84,101
  ---------------------------------------------------------- ------------

**Table 10. Wet alkaline scrubber capital and annual costs for new kiln
model.**

  ----------------------------------------------------------- ----------------
  **CAPITAL COSTS:**                                          

  Equipment costs, \$                                         

  \-- Limestone handling, milling, and emission control       1,079,519

  \-- Scrubber with fans                                      5,721,834

  \-- Scrubber stack                                          985,427

  \-- Bypass, preheater, and cooler vent ductwork; cooler     1,909,821

  vent fan and damper                                         

  \-- Sludge handling and material disposal system            279,734

  \-- Building and building permit                            1,227,015

  \-- Contingency (20% of equipment costs)                    2,240,670

  \-- Total (base)                                            7,081,087

  Chemical Engineering Plant Cost Index September 2002        400.9

  Chemical Engineering Plant Cost Index September 2007        528.2

  \' (escalated)                                              9,329,584

  Instrumentation (10% of equipment cost)                     932,958

  Sales tax (5% of equipment cost)                            466,479

  Freight (5% of equipment cost)                              466,479

  Purchased Equipment Cost (PEC):                             11,195,501

  Direct installation costs, \$                               

  \-- Foundation and supports (12% of PEC)                    1,343,460

  \-- Handling and erection (60% of PEC)                      6,717,300

  \-- Electrical (10% of PEC)                                 1,119,550

  \-- Piping (30% of PEC)                                     3,358,650

  \-- Insulation and Ductwork (2% of PEC)                     223,910

  \-- Painting (2% of PEC)                                    223,910

  \-- Total                                                   12,986,781

  Site preparation cost, \$                                   200,000

  **Indirect installation costs, \$**                         

  \-- Engineering (20% of PEC)                                2,239,100

  \-- Construction and field expenses (5% of PEC)             559,775

  \-- Contractor fees (5% of PEC)                             559,775

  \-- Start-up (1% of PEC)                                    111,955

  \-- Performance test (1% of PEC)                            111,955

  \-- Contingencies (3% of PEC)                               335,865

  \-- Total                                                   3,918,425

  Total Capital Investment (\$):                              **28,100,706**
  ----------------------------------------------------------- ----------------

**Table 10 (continued)**

  --------------------------------------------------------------------------------------------------- ---------------
  **ANNUAL COSTS:**                                                                                   

  Operating labor                                                                                     55,688

  Supervisory labor                                                                                   8,353

  Maintenance labor                                                                                   61,256

  Maintenance materials                                                                               61,256

  Replacement parts (5% of PEC)                                                                       559,775

  Electricity (fan and pumps)                                                                         669,016

  Electricity (limestone preparation)                                                                 79,656

  Limestone                                                                                           214,079

  Solvent (makeup water)                                                                              9,950

  Overhead                                                                                            111,932

  Taxes, insurance, administrative                                                                    1,124,028

  Capital recovery                                                                                    2,652,508

  \-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\--   

  Total Annual Cost                                                                                   5,607,497

  Credit for recycled gypsum                                                                          694,674

  Total Annual Cost w/ gypsum credit                                                                  **4,912,823**
  --------------------------------------------------------------------------------------------------- ---------------

**Table 11. Lime injection input parameters for new kiln model.**

  ----------------------------------------------------- -----------------
  INPUT PARAMETERS:                                     

                                                        

  \-- Clinker production rate, tons/yr                  1,200,000

  \-- Process operating hours, hr/yr                    7,920

  \-- Pollutant in waste gas:                           SO2

  \-- pollutant emissions, lb/yr                        14,475,811

  \-- pollutant molecular weight                        64

  \-- Solvent molecular weight (lb/lb-mole):            18

  \-- Liquid pressure drop for pump (ft of H2O):        60

  \-- Makeup water flow, gal/yr                         97,383,410

  \-- Slurry flow rate, gpm                             4,099

  \-- Slaked lime consumption, tons/yr                  25,057

  \-- Estimated control efficiency, percent             60

  \-- Electricity consumption, kw                       66.0

                                                        

  ANNUAL COST INPUTS:                                   

                                                        

  Operating factor (hr/yr):                             7,920

  Operating labor rate (\$/hr):                         22.5

  Maintenance labor rate (\$/hr):                       24.75

  Operating labor factor (hr/sh):                       2.5

  Maintenance labor factor (hr/sh):                     2

  Electricity price (\$/kWhr):                          0.062

  Slaked lime, \$/ton                                   65

  Solvent (water) price (\$/1000 gal):                  0.2

  Overhead rate (fraction):                             0.6

  Annual interest rate (fraction):                      0.07

  Control system life (years):                          15

  Capital recovery factor (system):                     0.1098

  Taxes, insurance, admin. factor:                      0.04
  ----------------------------------------------------- -----------------

**Table 12. Lime injection capital and annual costs for new kiln
model.**

  --------------------------------------------------------------------------------------------------- ---------------
  CAPITAL COSTS:                                                                                      

  Equipment costs, \$                                                                                 

  \-- Limestone handling system (main and bypass)                                                     1,271,519

  \-- Injection system (main and bypass)                                                              762,911

  \-- Building permit                                                                                 190,728

  \-- Contingency (20% of equipment costs)                                                            445,032

  \-- Total (base)                                                                                    2,670,189

  Chemical Engineering Plant Cost Index September 2002                                                400.9

  Chemical Engineering Plant Cost Index September 2007                                                528.2

  \' (escalated)                                                                                      3,518,069

  Instrumentation (10% of equipment cost)                                                             351,807

  Sales tax (5% of equipment cost)                                                                    175,903

  Freight (5% of equipment cost)                                                                      175,903

  Purchased Equipment Cost (PEC):                                                                     4,221,683

  Direct installation costs, \$                                                                       

  \-- Foundation and supports (8% of PEC)                                                             337,735

  \-- Handling and erection (14% of PEC)                                                              591,036

  \-- Electrical (4% of PEC)                                                                          168,867

  \-- Piping (2% of PEC)                                                                              84,434

  \-- Insulation and Ductwork (1% of PEC)                                                             42,217

  \-- Painting (1% of PEC)                                                                            42,217

  \-- Total                                                                                           1,266,505

  Site preparation cost, \$                                                                           200,000

  Indirect installation costs, \$                                                                     

  \-- Engineering (10% of PEC)                                                                        422,168

  \-- Construction and field expenses (5% of PEC)                                                     211,084

  \-- Contractor fees (10% of PEC)                                                                    422,168

  \-- Start-up (2% of PEC)                                                                            84,434

  \-- Performance test (1% of PEC)                                                                    42,217

  \-- Contingencies (3% of PEC)                                                                       126,650

  \-- Total                                                                                           1,308,722

                                                                                                      

  Total Capital Investment (\$):                                                                      **6,996,909**

                                                                                                      

  ANNUAL COSTS:                                                                                       

  Operating labor                                                                                     55,688

  Supervisory labor                                                                                   8,353

  Maintenance labor                                                                                   49,005

  Maintenance materials                                                                               49,005

  Replacement parts (5% of PEC)                                                                       211,084

  Electricity (pumps)                                                                                 1,622

  Slaked lime                                                                                         1,628,678

  Solvent (makeup water)                                                                              19,477

  Overhead                                                                                            97,230

  Taxes, insurance, administrative                                                                    279,876

  Capital recovery                                                                                    768,223

  \-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\-\--   

  Total Annual Cost                                                                                   **3,168,241**
  --------------------------------------------------------------------------------------------------- ---------------

**Table 13. Costs of SO~2~ emission limits for 1,200,000 ton/yr
kiln.\***

+--------------+-------+-------------+---------------+---------------+
| **Option**   | **1** | **2**       | **3**         | **4**         |
|              |       |             |               |               |
|              | **(B  | **(1.33     | **(0.4 lb/ton | **(0.2 lb/ton |
|              | aseli | lb/ton      | clinker)**    | clinker)**    |
|              | ne)** | clinker)**  |               |               |
+--------------+-------+-------------+---------------+---------------+
| **Capital    | 0     | \           | \$28,280,000  | \$28,280,000  |
| cost**       |       | $28,280,000 | (WS)          | (WS)          |
|              |       | (WS)        |               |               |
| High sulfur  |       |             | \$7,176,000   | \$28,280,000  |
|              |       | 0           | (DLS)         | (WS)          |
| Moderate     |       |             |               |               |
| sulfur       |       | 0           | 0             | 0             |
|              |       |             |               |               |
| Low sulfur   |       |             |               |               |
+--------------+-------+-------------+---------------+---------------+
| **Annualized | 0     | \$4,969,000 | \$4,969,000   | \$4,969,000   |
| cost**       |       |             |               |               |
|              |       | 0           | \$3,224,000   | \$4,969,000   |
| High sulfur  |       |             |               |               |
|              |       | 0           | 0             | 0             |
| Moderate     |       |             |               |               |
| sulfur       |       |             |               |               |
|              |       |             |               |               |
| Low sulfur   |       |             |               |               |
+--------------+-------+-------------+---------------+---------------+
| **Total      | 0     | 7,410 tpy   | 7,410 tpy     | 7,410 tpy     |
| SO~2~        |       |             |               |               |
| reduction**  |       | 0           | 540 tpy       | 741 tpy       |
|              |       |             |               |               |
| High sulfur  |       | 0           | 0             | 0             |
|              |       |             |               |               |
| Moderate     |       |             |               |               |
| sulfur       |       |             |               |               |
|              |       |             |               |               |
| Low sulfur   |       |             |               |               |
+--------------+-------+-------------+---------------+---------------+
| **Total Cost | 0     | 663 \$/ton  | 671 \$/ton    | 671 \$/ton    |
| Eff          |       | SO~2~       | SO~2~         | SO~2~         |
| ectiveness** |       |             |               |               |
|              |       | 0           | 5,970 \$/ton  | 6,706 \$/ton  |
| High sulfur  |       |             | SO~2~         | SO~2~         |
|              |       | 0           |               |               |
| Moderate     |       |             | 0             | 0             |
| sulfur       |       |             |               |               |
|              |       |             |               |               |
| Low sulfur   |       |             |               |               |
+--------------+-------+-------------+---------------+---------------+

\* Costs include monitoring costs.

WS = alkaline wet scrubber

DLS = lime injection

G. Summary of Impacts

Environmental and cost impacts for the proposed amendments on a model
plant basis are summarized in Table 14. Nationwide impacts in the 5^th^
year following promulgation are summarized in Table 15.

**Table 14**. Cost and environmental impacts of proposed amendments for
a 1,200,000 ton/yr kiln.

  ----------- ------------ ----------- ----------- ------------- ------------ ---------- ----------- ----------- ----------- -----------
  Pollutant   Cost (\$)\*              Emission    Secondary                                                                 
                                       Reduction   Impacts                                                                   
                                       (tpy)                                                                                 

              Capital      Annual                  Increase in   Increase in  Increase   Increase in Increase in Increase in Increase in
                                                   electricity   water usage  in solid   emissions   emissions   emissions   emissions
                                                   demand        (gpy)        waste      of NOx      of CO (tpy) of SO2      of PM10
                                                   (kWh/yr)                   (tpy)      (tpy)                   (tpy)       (tpy)

  NOx         2,289,000    1,268,000   600         Negligible    0            0          0           0           0           0

  PM          1,428,000    211,000     44.4        Negligible    0            44.4       0           0           0           0

  SO2         28,280,000   4,969,000   7,410       12,075,355    97,000,000   84,101     26.9        13.9        46.2        1.4
  ----------- ------------ ----------- ----------- ------------- ------------ ---------- ----------- ----------- ----------- -----------

\*Includes monitoring costs.

**Table 15**. Nationwide cost and environmental impacts of proposed
amendments.

  ----------- ------------- ------------ ----------- ------------- ------------- ----------- ----------- ----------- ----------- -----------
  Pollutant   Cost (\$)\*                Emission    Secondary                                                                   
                                         Reduction   Impacts                                                                     
                                         (tpy)                                                                                   

              Capital       Annual                   Increase in   Increase in   Increase in Increase in Increase in Increase in Increase in
                                                     electricity   water usage   solid waste emissions   emissions   emissions   emissions
                                                     demand        (gpy)         (tpy)       of NOx      of CO (tpy) of SO2      of PM10
                                                     (kWh/yr)                                (tpy)                   (tpy)       (tpy)

  NOx         45,800,000    25,400,000   12,000      Negligible    0             0           0           0           0           0

  PM          28,600,000    4,200,000    890         Negligible    0             890         0           0           0           0

  SO2         113,000,000   19,900,000   29,640      48,301,000    388,000,000   336,400     108         56          185         5

  TOTAL       187,400,000   49,500,000   []{.mark}   []{.mark}     []{.mark}     []{.mark}   []{.mark}   []{.mark}   []{.mark}   []{.mark}
  ----------- ------------- ------------ ----------- ------------- ------------- ----------- ----------- ----------- ----------- -----------

\*Includes monitoring cost.

H. References

Bahner, M. 2007. Review of Three BACT Analyses. October 10, 2007.

Bahner, M. 2008a. Review and Analysis of NO~x~ Data for Four Cement
Kilns. April 1, 2008.

Bahner, M. 2008b. Analysis of Particulate Matter Test Results: 2003
Survey, and Florida Kilns. March 31, 2008.

Bahner, M. 2008c. Summary of Cement Kiln Wet Scrubber and Lime Injection
Design and Performance Data. May 2, 2008.

M. Bahner, and M. Laney 2008. Summary of Cement Kiln Wet Scrubber and
Lime Injection Design and Performance Data, May 2, 2008.

CEMS Cost Model. CEMS.XLS. <http://www.epa.gov/ttn/emc/cem.html>.
Accessed March, 2008.

Heath, E. 1996. Summary of Inputs of Control Options on Model Kilns and
Clinker Cooler. Docket Item II-B-67, Docket A-92-53. April 19, 1996.

Florida Department of Environmental Protection (FL DEP). 2005. Technical
Evaluation Preliminary Determination Draft BACT Determinations Sumter
Cement Company, Sumter County, Florida, New Portland Cement Plant. DEP
File No. 1190041-001-AC (PSD-FL-358). Available at:
<http://www.dep.state.fl.us/air/permitting/construction/sumter/TEPD358.pdf>.

Laney, M., D. Green and K Barnett 2006. Summary of Environmental and
Cost Impacts of Final Amendments to Portland Cement NESHAP, December 8,
2006, Docket item EPA-HQ-OAR-2002-0051-1891.

Northeast States for Coordinated Air Use Management (NESCAUM) in
Partnership with the Mid-Atlantic/Northeast Visibility Union. 2005.
Assessment of Control Technology Options for BART-Eligible Sources.
Steam Electric Boilers, Industrial Boilers, Cement Plants and Paper and
Pulp Facilities. March 2005.

Portland Cement Association. 2006. Capacity Expansion Estimates. October
13, 2006.

Portland Cement Association. 2007. U.S. and Canadian Portland Cement
Industry Plant Information Summary December 31, 2006.

U.S. Environmental Protection Agency (EPA), 2007. Alternative Control
Technologies Document Update - NOx Emissions from New Cement Kilns,
November 2007.

US EPA. *EPA Air Pollution Cost Control Manual: Sixth Edition: Section
6: Particulate Matter Controls: Chapter 1: Baghouses and Filters*.
Document Number EPA/452/B-02-001. December 1998.

U. S. Environmental Protection Agency 2002. Office of Air Quality
Planning and Standards. EPA Air Pollution Control Cost Manual, Sixth
Edition, EPA/452/B-02-001. January 2002.

U. S. Environmental Protection Agency, Office of Atmospheric Programs.
Output-Based Regulations: A Handbook for Air Regulators. August, 2004.

United States Geological Survey. *USGS 2006 Minerals Yearbook*. Gypsum.
Nov. 2007.

Zephyr Environmental Corporation. PSD Application for Lehigh Mason City.
September 2002.

**Attachment 1**

**SO~2~ Monitor Cost**

**Output from the EPA CEMS Cost Model**

**Attachment 1**

  ----------------------------------- -------- -------- --------- ---------
  Summary of CEMS                                                 

                                                                  

  [Analyzers]{.underline}                      BEFORE   AFTER     

  CO                                           0        0         

  SO2                                          0        1         

  NOX                                          0        0         

  HCl                                          0        0         

  Mercury (and CO2/O2)                         0        0         

  CO2                                          0        0         

  O2                                           0        0         

  THC                                          0        0         

                                                                  

  [Monitors]{.underline}                                          

  OPACITY                                      0        0         

  FLOW                                         0        0         

  PM (beta gauge)                              0        0         

  PM (light scattering; insitu)                0        0         

  PM (light scattering; extractive)            0        0         

                                                                  

  [Bag leak detector]{.underline}                                 

  Number of fabric filters to be               0        0         
  monitored=                                                      

  Number of sensors=                           0        0         

                                                                  

  Summary of Costs                                                

                                                                  

  First Costs                         Labor    Test     ODCs      Total

  Planning                            2,534    0        352       2,886

  Select Equipment                    10,941   0        3,067     14,008

  Support Facilities                  0        0        19,065    19,065

  Purchase CEMS Hardware              0        0        64,978    64,978

  Install and Check CEMS              4,818    0        11,979    16,797

  Performance Specification Tests     2,129    7,526    503       10,157

  QA/QC Plan                          2,570    11,981   692       15,244

                                      22,993   19,507   100,635   143,135

                                                                  

  Annual Costs                                                    

  Day-to-Day Activities               5,532    0        1,000     6,532

  Annual RATA                         885      7,156    0         8,041

  PM Monitor RCA                      0        0        0         0

  PM Monitor RRA                      0        0        0         0

  Cylinder Gas Audits (ACA/SVA for    1,284    0        1,069     2,353
  PM)                                                             

  Recordkeeping and Reporting         1,253    0        160       1,413

  Annual QA & O&M Review and Update   2,074    0        1,530     3,604

  Capital Recovery                    3,274    2,778    14,330    20,382

                                                                  

  Total w/o capital recovery          11,029   7,156    3,759     21,944

  Total with capital recovery         14,303   9,934    18,089    42,326
  ----------------------------------- -------- -------- --------- ---------

**Attachment 2**

**NO~x~ Monitor Cost**

**Output from the EPA CEMS Cost Model**

**Attachment 2**

  ----------------------------------- -------- -------- --------- ---------
  Summary of CEMS                                                 

                                                                  

  [Analyzers]{.underline}                      BEFORE   AFTER     

  CO                                           0        0         

  SO2                                          0        0         

  NOX                                          0        1         

  HCl                                          0        0         

  Mercury (and CO2/O2)                         0        0         

  CO2                                          0        0         

  O2                                           0        0         

  THC                                          0        0         

                                                                  

  [Monitors]{.underline}                                          

  OPACITY                                      0        0         

  FLOW                                         0        0         

  PM (beta gauge)                              0        0         

  PM (light scattering; insitu)                0        0         

  PM (light scattering; extractive)            0        0         

                                                                  

  [Bag leak detector]{.underline}                                 

  Number of fabric filters to be               0        0         
  monitored=                                                      

  Number of sensors=                           0        0         

                                                                  

  Summary of Costs                                                

                                                                  

  First Costs                         Labor    Test     ODCs      Total

  Planning                            2,534    0        352       2,886

  Select Equipment                    10,941   0        3,067     14,008

  Support Facilities                  0        0        19,065    19,065

  Purchase CEMS Hardware              0        0        62,794    62,794

  Install and Check CEMS              4,818    0        11,979    16,797

  Performance Specification Tests     2,129    7,526    502.5     10,157

  QA/QC Plan                          2,570    11,981   692       15,244

                                      22,993   19,507   98,451    140,951

                                                                  

  Annual Costs                                                    

  Day-to-Day Activities               5,532    0        1,000     6,532

  Annual RATA                         885      7,156    0         8,041

  PM Monitor RCA                      0        0        0         0

  PM Monitor RRA                      0        0        0         0

  Cylinder Gas Audits (ACA/SVA for    1,284    0        1,069     2,353
  PM)                                                             

  Recordkeeping and Reporting         1,253    0        160       1,413

  Annual QA & O&M Review and Update   2,074    0        1,324     3,398

  Capital Recovery                    3,274    2,778    14,019    20,071

                                                                  

  Total w/o capital recovery          11,029   7,156    3,553     21,738

  Total with capital recovery         14,303   9,934    17,572    41,809
  ----------------------------------- -------- -------- --------- ---------

**Attachment 3**

**Flow Rate Monitor Cost**

**Output from the EPA CEMS Cost Model**

**Attachment 3**

  ----------------------------------- --------------------- --------------------- --------------------- ----------------------
  Summary of CEMS                                                                                       

                                                                                                        

  [Analyzers]{.underline}                                   BEFORE                AFTER                 

  CO                                                        0                     0                     

  SO2                                                       0                     0                     

  NOX                                                       0                     0                     

  HCl                                                       0                     0                     

  Mercury (and CO2/O2)                                      0                     0                     

  CO2                                                       0                     0                     

  O2                                                        0                     0                     

  THC                                                       0                     0                     

                                                                                                        

  [Monitors]{.underline}                                                                                

  OPACITY                                                   0                     0                     

  FLOW                                                      0                     1                     

  PM (beta gauge)                                           0                     0                     

  PM (light scattering; insitu)                             0                     0                     

  PM (light scattering; extractive)                         0                     0                     

                                                                                                        

  [Bag leak detector]{.underline}                                                                       

  Number of fabric filters to be                            0                     0                     
  monitored=                                                                                            

  Number of sensors=                                        0                     0                     

                                                                                                        

  Summary of Costs                                                                                      

                                                                                                        

  First Costs                         Labor                 Test                  ODCs                  Total

  Planning                            806                   0                     0                     806

  Select Equipment                    1,709                 0                     293                   2,002

  Support Facilities                  0                     0                     1,000                 1,000

  Purchase CEMS Hardware              0                     0                     19,080                19,080

  Install and Check CEMS              1,037                 0                     690                   1,727

  Performance Specification Tests     77                    440                   0                     517

  QA/QC Plan                          [2,306]{.underline}   [7,650]{.underline}   [692]{.underline}     [10,647]{.underline}

                                      5,934                 8,090                 21,755                35,780

                                                                                                        

  Annual Costs                                                                                          

  Day-to-Day Activities               691                   0                     0                     691

  Annual RATA                         0                     0                     0                     0

  PM Monitor RCA                      0                     0                     0                     0

  PM Monitor RRA                      0                     0                     0                     0

  Cylinder Gas Audits (ACA/SVA for    0                     0                     0                     0
  PM)                                                                                                   

  Recordkeeping and Reporting         5,448                 0                     40                    5,488

  Annual QA & O&M Review and Update   1,409                 0                     1,180                 2,589

  Capital Recovery                    [845]{.underline}     [1,152]{.underline}   [3,098]{.underline}   [5,095]{.underline}

                                                                                                        

  Total w/o capital recovery          7,548                 0                     1,220                 8,768

  Total with capital recovery         8,394                 1,152                 4,318                 13,864
  ----------------------------------- --------------------- --------------------- --------------------- ----------------------

**Attachment 4**

**Bag Leak Detector Cost**

**Output from the EPA CEMS Cost Model**

**Attachment 4**

  ----------------------------------- --------------------- ----------------- ---------------------- ----------------------
  Summary of CEMS                                                                                    

  [Analyzers]{.underline}                                   BEFORE            AFTER                  

  CO                                                        0                 0                      

  SO2                                                       0                 0                      

  NOX                                                       0                 0                      

  HCl                                                       0                 0                      

  Mercury (and CO2/O2)                                      0                 0                      

  CO2                                                       0                 0                      

  O2                                                        0                 0                      

  THC                                                       0                 0                      

                                                                                                     

  [Monitors]{.underline}                                                                             

  OPACITY                                                   0                 0                      

  FLOW                                                      0                 0                      

  PM (beta gauge)                                           0                 0                      

  PM (light scattering; insitu)                             0                 0                      

  PM (light scattering; extractive)                         0                 0                      

                                                                                                     

  [Bag leak detector]{.underline}                                                                    

  Number of fabric filters to be                            0                 2                      
  monitored=                                                                                         

  Number of sensors=                                        0                 10                     

                                                                                                     

  Summary of Costs                                                                                   

                                                                                                     

  First Costs                         Labor                 Test              ODCs                   Total

  Planning                            1,711                 0                 352                    2,063

  Select Equipment                    6,346                 0                 643                    6,989

  Support Facilities                  0                     0                 3,950                  3,950

  Purchase CEMS Hardware              0                     0                 66,568                 66,568

  Install and Check CEMS              484                   0                 12,927                 13,411

  Performance Specification Tests     0                     0                 0                      0

  QA/QC Plan                          [739]{.underline}     [0]{.underline}   [0]{.underline}        [739]{.underline}

                                      9,279                 0                 84,440                 93,719

                                                                                                     

  Annual Costs                                                                                       

  Day-to-Day Activities               2,822                 0                 0                      2,822

  Annual RATA                         0                     0                 0                      0

  PM Monitor RCA                      0                     0                 0                      0

  PM Monitor RRA                      0                     0                 0                      0

  Cylinder Gas Audits (ACA/SVA for    0                     0                 0                      0
  PM)                                                                                                

  Recordkeeping and Reporting         946                   0                 0                      946

  Annual QA & O&M Review and Update   384                   0                 17,250                 17,634

  Capital Recovery                    [1,321]{.underline}   [0]{.underline}   [12,024]{.underline}   [13,346]{.underline}

                                                                                                     

  Total w/o capital recovery          4,152                 0                 17,250                 21,402

  Total with capital recovery         5,473                 0                 29,274                 34,748
  ----------------------------------- --------------------- ----------------- ---------------------- ----------------------

**Attachment 5**

**Statistical Analyses of Cement Kiln PM Data**

**PH/PC Kilns built since 1997-Fabric Filters with Membrane Bags**

**Attachment 5**

  -------------------- ----------------- ----------- ------------ -------------
  Statistical Analyses                                            
  of Cement Kiln PM                                               
  Data                                                            

  PH/PC Kilns built                                               
  since 1997-Fabric                                               
  Filters with                                                    
  Membrane Bags                                                   

                                         PM          Conversion   PM Emissions
                                         Emissions   Factor       

  Facility Name        Emissions Point   (gr.dscf)                lb/ton
                                                                  clinker

  Ash Grove, Chanute   Kiln, December 4, 0.0051      12.72        0.0649
                       2003                                       

  Ash Grove, Chanute   Kiln, December 5, 0.00072     12.72        0.0092
                       2003                                       

  Ash Grove, Chanute   Kiln, September   0.0022      12.72        0.0280
                       8, 2004                                    

  Ash Grove, Chanute   Kiln, September   0.0007      12.72        0.0089
                       9, 2004                                    

  Ash Grove, Chanute   Kiln, November    0.0074      12.72        0.0941
                       15, 2005                                   

  Ash Grove, Chanute   Kiln, November    0.008       12.72        0.1018
                       15, 2005                                   

  Ash Grove, Chanute   Kiln, November    0.0026      12.72        0.0331
                       15, 2005                                   

  Ash Grove, Chanute   Kiln, November    0.0042      12.72        0.0534
                       16, 2005                                   

  Ash Grove, Chanute   Kiln, November    0.0031      12.72        0.0394
                       16, 2005                                   

  Ash Grove, Chanute   Kiln, November    0.0032      12.72        0.0407
                       16, 2005                                   

  Ash Grove, Chanute   Kiln, November    0.0025      12.72        0.0318
                       17, 2005                                   

  Ash Grove, Chanute   kiln, November    0.001       12.72        0.0127
                       17, 2005                                   

  Ash Grove, Chanute   Kiln, November    0.0016      12.72        0.0204
                       17, 2005                                   

  Lehigh Cement, Union Kiln (Mill On)                             0.0023
  Bridge, MD                                                      

  Lehigh Cement, Union Kiln (Mill Off)                            0.0045
  Bridge, MD                                                      

  Lafarge Cement,      Kiln (Mill On)                             0.0046
  Sugar Creek, MO                                                 

  Lafarge Cement,      Kiln (Mill Off)                            0.0317
  Sugar Creek, MO                                                 

  Holcim, Devil\'s     Kiln, Mill On                              0.0391
  Slide, UT            (October 2002)                             

  Holcim, Devil\'s     Kiln, Mill Off                             0.0584
  Slide, UT            (October 2002)                             

                                                                  

                                                     Minumim      0.0023

                                                     Maximum      0.10176

                                                     Average      0.035732126

                                                     Standard     0.028721542
                                                     Deviation    

                                                     99th         0.102538433
                                                     Percertile   

                                                     95th         0.082979063
                                                     Percentile   

                                                     Median       0.0318
  -------------------- ----------------- ----------- ------------ -------------