1 

TECHNICAL MEMORANDUM 

TO: Tina Ndoh, U.S. EPA/OAQPS/SPPD - Minerals and Manufacturing Group

FROM: Eastern Research Group, Inc. 

DATE: June 9, 2015 

SUBJECT: Control Costs and Emissions Reductions for Phosphoric Acid and Phosphate Fertilizer 

Production Source Categories – Final Rule 

The U.S. Environmental Protection Agency (EPA), under section 112 of the Clean Air Act 

(CAA), is required to establish maximum achievable control technology (MACT) standards for 

phosphoric acid manufacturing plants (40 CFR part 63, subpart AA) and phosphate fertilizer 

production plants (40 CFR part 63, subpart BB) source categories. This memorandum documents the 

control costs and emissions reductions associated with the finalized subparts AA and BB. The 

following is an outline of the memorandum: 

1.0 Introduction 

2.0 Control Costs for Oxidation Reactors 

3.0 Testing and Monitoring Costs 

4.0 Total Cost 

 5.0 References 

 Attachment A: Venturi Scrubber Analysis 

 Attachment B: BLDS Cost Analysis 

1.0 INTRODUCTION 

As part of the risk and technology review required under section 112 of the Clean Air Act 

certain revisions were made to subparts AA and BB that will impose additional costs. EPA determined 

that clarification of the applicability requirements regarding oxidation reactors at SPA process lines 

was necessary. As a result of the clarification, it was assumed that one facility may need to install a 

new venturi scrubber. This memorandum describes the methodologies for estimating costs and the 

associated emissions reductions as a result of facilities complying with the proposed emission limits 
2 

and clarifications. Cost estimates for the revised testing and monitoring requirements included in the 

proposed rule are also provided. 

The following assumptions were applied throughout this analysis. For equipment installations, 

an equipment life of 15 or 20 years and a 7 percent discount rate was used to calculate capital recovery 

factors (CRF). All facilities were assumed to have adequate space to install additional emissions 

control equipment, and installation would not cause a production loss and could be completed during a 

routine maintenance outage. All costs are presented in 2013 dollars. For the cost analyses, only 

currently operating sources were considered as no new facilities are anticipated to be built in the near 

future. 

2.0 CONTROL COSTS FOR OXIDATION REACTORS 

The superphosphoric acid (SPA) process line definition was revised to specify that emissions 

from oxidation reactors must be included when determining compliance with the total fluoride 

emission limit. Some facilities were not previously including emissions from these emission sources, 

as was the intention of subpart AA. The cost impact and emissions reduction associated with the 

subpart AA oxidation reactor applicability clarification was thus evaluated. At proposal, an HF 

emission limit was evaluated for this analysis; however, as discussed in the final preamble, HF 

emission limits were not finalized and the original total fluoride emission limit was maintained for 

SPA process lines. 

Oxidation reactors are used to remove organics by mixing SPA with nitric acid, ammonium 

nitrate, or potassium permanganate. Oxidation is used in the production of SPA at four facilities. The 

inclusion of emissions from oxidation reactors was evaluated to determine if facilities currently using 

oxidation would meet the total fluoride limit for SPA process lines. Based on the available total 

fluoride data, three of the facilities were below the total fluoride limit when the emissions associated 

with oxidation reactors were added to emissions of applicable equipment (e.g., evaporators) at SPA 

lines. In one instance, a facility already ducts oxidation reactor emissions through a common SPA 

emission point and thus oxidation reactor emissions would have been included in past performance 

tests. However, the oxidation reactor at PCS Aurora is not controlled and when the oxidation reactor 

emissions are combined with emissions from the SPA emissions, the total fluoride limit may be 

exceeded. 

PCS Aurora’s SPA process line was examined to determine their potential control options. The 

oxidation reactor at PCS Aurora was not tested as part of the 2010 section 114 information collection 

request, so specific total fluoride data were not available. Therefore, the facility may not need to 
3 

control emissions, may be able to route the emissions to existing absorbers at SPA process lines, or a 

new absorber may be necessary. PCS Aurora provided initial comments on their oxidation reactor (see 

docket item EPA-HQ-OAR-2012-0522-0037) and then elaborated on these comments after the 

comment period ended for the proposed rule (see docket item EPA-HQ-OAR-2012-0522-0051). PCS 

Aurora stated it may be necessary to install a new venturi scrubber to control the oxidation reactor 

emissions in order to comply with the SPA total fluoride emission limit. They stated a new scrubber 

may be necessary due to logistical complications and concerns about inadequate capacity of other 

existing absorbers at their SPA units. PCS Aurora estimated the venturi scrubber would incur capital 

costs of approximately $270,500, based on prior absorber purchases for their facility. In order to 

estimate annual costs for the venturi scrubber, we used algorithms from the EPA Air Pollution Control 

Cost Manual1, see Attachment A for details. When applying the algorithms, we implemented certain 

modifications in order to reflect costs that we believe are more appropriate. The algorithm 

modifications focus on how many hours the facility would spend on operation and maintenance 

activities. The EPA Air Pollution Control Cost Manual recommends that operator activities take 

2 hours per shift and maintenance activities take one hour per shift. PCS Aurora currently operates 

numerous scrubbers at their facility and, therefore, we do not believe that these time commitments are 

appropriate. We reduced each of the hours by half; we assumed operation activities take one hour per 

shift and maintenance activities take 30 minutes per shift. Because we do not have emissions data for 

the oxidation reactor at PCS Aurora, we are not able to estimate the emissions reduction associated 

with the installation of a venturi scrubber. Table 2-1 presents the capital and annual costs associated 

with installing a new venturi scrubber for the oxidation reactor at PCS Aurora. 

Table 2-1. PCS Aurora oxidation reactor costs for installing a venturi scrubber. 

Item Total Capital Investment (TCI) Total Annual Cost (TAC) 

Venturi Scrubber $270,500 $95,000 

3.0 TESTING AND MONITORING COSTS 

The SPA process line definition was clarified to specify that emissions from oxidation reactors 

must be included when determining compliance. There are three known emission points for oxidation 

reactors that would incur an additional cost. One facility already includes their oxidation reactor 

emissions in compliance tests, so additional costs are not necessary for this facility. The Method 13B 

cost of $5,600 was included for these three emission points. 
4 

The final rule includes a total fluoride emission limit for phosphate rock calciners. A work 

practice standard was proposed for phosphate rock calciners, based on below detection level (BDL) HF 

data, but total fluoride emissions were above the detection level. Therefore, an emission limit was 

calculated and finalized for total fluoride. Each of the six phosphate rock calciners must perform 

annual total fluoride compliance tests using Method 13B; a cost of $5,600 was included for each 

phosphate rock calciner. 

A mercury limit was finalized in subpart AA for phosphate rock calciners. Each of the six 

phosphate rock calciners must perform annual Hg compliance tests using Method 30B; a cost of 

$8,000 was included for each phosphate rock calciner. The method 30B cost was increased from 

proposal ($5,600) due to industry comments which suggested that $5,600 per Method 30B was too low 

(see the final preamble for additional Method 30B cost discussion). The annual testing costs by 

emission source for total fluoride and Hg are shown in Table 3-1. 

Table 3-1. Summary of testing costs to perform 

Methods 13B (for total fluoride) and 30B (for Hg). 

Emission Source 

Total Annual 

Cost (TAC) 

($/yr) 

Phosphate Rock Calciners – Method 30B $48,000 

Phosphate Rock Calciners – Method 13B $33,600 

Oxidation Reactors – Method 13B $16,800 

TOTAL $98,400 

Control device monitoring costs were also evaluated. The proposed rule included a requirement 

that a bag leak detection system (BLDS) must be installed on fabric filters, however we did not include 

costs for this requirement. We are including BLDS costs for the final rule. When conducting the 

technology review, we identified three facilities that use fabric filters on their phosphate fertilizer 

process lines. These facilities are Simplot Don-Pocatello (P-1, EP-103), Agrium Nu-West (Gran, EP6), and Mississippi Phosphates (P-2, EP-1). Attachment B provides the detailed BLDS cost analysis. 

For a single fabric filter capital costs were estimated at $25,200 and annual costs were estimated at 

$9,900. Table 3-2 presents the capital and annual costs to install BLDS at the three facilities. Details on 

BLDS costs are provided in Attachment B. 
5 

Table 3-2. Summary of capital and annual costs to install BLDS on 

fabric filters located at three phosphate fertilizer process lines. 

Item Total Capital 

Cost (TCI) 

Total Annual 

Cost (TAC) 

($/yr) 

BLDS $75,600 $29,700 

Performance evaluations of control device monitoring equipment are a requirement for all 

facilities. An annual labor cost for completing the calibration requirements for scrubbers were 

estimated at seven hours per facility; this labor is included Table 3-3. Recordkeeping and reporting 

costs were developed based on rule requirements. This includes report preparation and recordkeeping 

of monitoring and test data. Changes are proposed for the monitoring section of subparts AA and BB 

that require development of a monitoring plan. Subpart AA also proposes the development of a 

gypsum dewatering stack and cooling pond management plan. Recordkeeping and reporting annual 

costs will be the highest in the first year as initial costs will be incurred for reading the rule and 

developing the monitoring and management plans, and all subsequent years will have a lower annual 

cost. The annual costs for recordkeeping and reporting are included in Table 3-3. See the Supporting 

Statement and burden tables for details on calculating testing, monitoring, recordkeeping, and 

reporting costs.2

 

Table 3-3. Summary of annual recordkeeping and reporting costs. 

Annual costs are presented for the first year of compliance and subsequent years. 

Cost for First Year of 

Compliance 

Annual Cost for 

Subsequent Years 

($/yr) 

$162,800 $70,600 

4.0 TOTAL COST 

The total cost to comply with subparts AA and BB for phosphoric acid manufacturing and 

phosphate fertilizer production plants is the sum of the costs presented in sections two and three. This 

includes venturi scrubber capital and annual costs, BLDS capital and annual costs, and annual testing 

and monitoring costs. The total capital and annual costs are presented in Table 4-1. Note that for 

testing and monitoring costs, the annual cost for subsequent years is included in this value, rather than 

the first year of compliance cost. 
6 

Table 4-1. Total capital and annual costs to comply with subparts AA and BB. 

Total Capital Cost Total Annual Cost 

$346,000 $294,000 

5.0 REFERENCES 

1. U.S. Environmental Protection Agency. “EPA Control Cost Manual, Sixth Edition. Section 6: 

Particulate Matter Controls, Chapter 2: Wet Scrubbers for Particulate Matter,” July 2002. 

Publication Number EPA/452/B-02-001. 

2. Eastern Research Group, Inc. “Supporting Statement for Phosphoric Acid and Phosphate 

Fertilizers NESHAPs.” Docket ID: EPA-HQ-OAR-2012-0522. May 2015. 
Attachment A 

Venturi Scrubber Annual Cost Calculation 
Attachment A: Venturi Scrubber Annual Cost Calculation

Parameter Value Note

INPUTS

Facility Name PCS Aurora

Emission Point ID Oxidation Reactor

Gas Flowrate (acfm) 500 Estimate

Operating Hrs 3552 From 2010 section 114 survey

Operating Days 177 From 2010 section 114 survey

Electricity Cost ($/kW) 0.063 EIA, Table 5.6.B. (a)

HPfan (fan horsepower) 4 From Table 2.3. (b)

Hppump (pump horsepower) 0.25 From Table 2.3. (b)

TOTAL CAPITAL

Venturi Scrubber TCI $270,500 Provided by PCS

DIRECT ANNUAL COSTS

Electricity $709 Eqn. 2.45 (b)

Operating Labor - Operator $19,648 Table 2.9 (b, c) - Used 1 hr operating labor/shift

Operating Labor - Supervisor $2,947 Table 2.9 (b)

Maintenance - Labor $9,824 Table 2.9 (b, c) - Used .5 hr maint. labor/shift

Maintenance - Materials $9,824 Table 2.9 (b)

INDIRECT ANNUAL COSTS

Administrative Charges $5,410 Table 2.9 (b)

Property Tax $2,705 Table 2.9 (b)

Insurance $2,705 Table 2.9 (b)

Overhead $11,789 Table 2.9 (b)

Capital Recovery $29,701 Table 2.9 (b) 15-year life, 7% interest

TOTAL ANNUAL COST $95,262

Notes:

a. EIA, Table 5.6.B. Average Retail Price of Electricity to Ultimate Customers by End-Use Sector. Selected value for 

Industrial Sector in North Carolina. http://www.eia.gov/electricity/monthly/epm_table_grapher.cfm?t=epmt_5_6_b

b. Available in the EPA Control Cost Manual, Sixth Edition - Section 5: SO2 and Acid Gas Controls, 5.2: PostCombustion Controls, Chapter 2: Wet Scrubbers for Particulate Matter

c. Wage rate = $55.20 per year, calculated as a loaded wage rate. Loaded wage rate = 110% of $26.43. Industrial 

engineering technician (Occupation code 17-3026). http://www.bls.gov/oes/2013/may/naics4_325300.htm
Attachment B 

Bag Leak Detection System Monitoring Costs 
Attachment B: Bag Leak Detection System Monitoring Costs

Parameters/Costs Equation Value

1. Cost index

 a. 2013 CEPCI 567.3

 b. 2006 CEPCI 499.6

 c. 1997 CEPCI 386.5

2. Capital recovery factor, 20-yr equipment life, 

7% interest (CRF)

= [i x (1 + i)a

] / [(1 + i)a - 1], where i = interest rate, 

a = equipment life

0.09439

1. Planning = 700 * (2013 CEPCI / 2006 CEPCI) $800

2. Select type of equipment = 3900 * (2013 CEPCI / 2006 CEPCI) $4,400

3. Provide support facilities = 400 * (2013 CEPCI / 2006 CEPCI) $500

4. Purchased equipment cost (PEC) = 12200 * (2013 CEPCI / 2006 CEPCI) $13,900

5. Install and check equipment = 4200 * (2013 CEPCI / 2006 CEPCI) $4,800

6. Perf. spec. tests (certif.) $0

7. Prepare QA/QC plan = 700 * (2013 CEPCI / 2006 CEPCI) $800

8. Total capital cost = Planning + selecting equipment + support 

facilities + PEC + installation + perf. spec. tests + 

QA/QC plan

$25,200

1. Operation & maintenance = Day-to-day activities + annual RATA + CGA + 

annual QA + O&M review and update = 5000 * 

(2013 CEPCI / 2006 CEPCI)

$6,000

2. Recordkeeping and reporting = $1,000 x (525.4/386.5) $1,500

3. Capital recovery = CRF x TCI $2,400

4. Total annual cost = Operating labor + maintenance materials + 

recordkeeping and reporting + overhead + 

property taxes, insurance, and administration + 

capital recovery

$9,900

Sources:

A. Parameters

B. Total Capital Investment, $ (TCI)

C. Annual Costs, $/yr

1. Hospital/Medical/Infectious Waste Incinerators (HMIWI) [EPA-HQ-OAR-2006-0534] Testing and Monitoring Options 

and Costs Memo (IV-B-66).