SUMMARY OF ENVIRONMENTAL AND COST IMPACTS FOR FINAL

PORTLAND CEMENT NESHAP AND NSPS

AUGUST 6, 2010
Summary of Environmental and Cost

Impacts of Final Amendments to Portland

Cement NESHAP (40 CFR Part 63, subpart

LLL)

Docket Number EPA‐HQ‐OAR‐2002‐0051 

August 6, 2010 
Summary of Environmental and Cost Impacts of Final Amendments to Portland Cement NESHAP 

iii 

Table of Contents

1 I d

2 S a

ntro uction ....................................................................................................................................................... 1

ubp rt LLL Impacts Estimated for 2010 Promulgation of NESHAP Review ....................... 1

2.1  Affected Industry and Final Changes to Subpart LLL ......................................................... 1 

2.2 

2.3 

Control Options ................................................................................................................................... 3 

Air Quality Impacts ............................................................................................................................ 5 

2.3.1  Hydrogen Chloride .............................................................................................................. 5 

2.3.2  Total Hydrocarbons ............................................................................................................ 8 

2.3.3  Mercury .................................................................................................................................... 9 

2.3.4  Particulate Matter ............................................................................................................. 10

2.3.5  Secondary Impacts ........................................................................................................... 11

2.4 Water Quality Impacts ................................................................................................................... 12

2.5 Solid Waste Impacts ....................................................................................................................... 12

2.6

2.7

Energy Impacts ................................................................................................................................. 13

Cost Impacts....................................................................................................................................... 13

2.7.1 Wet Alkaline Scrubber .................................................................................................... 14

2.7.2 Activated Carbon Injection ........................................................................................... 14

2.7.3 Regenerative Thermal Oxidizers ................................................................................ 15

2.7.4 Baghouses and Membrane Bags ................................................................................. 16

2.7.5 Cost of Control for Hydrogen Chloride (HCl) ........................................................ 18

2.7.6 Cost of Control for Total Hydrocarbons (THC) .................................................... 19

2.7.7 Cost of Control for Mercury .......................................................................................... 19

2.7.8 Cost of Control for Particulate Matter ...................................................................... 20

2.8 Summary of Impacts ...................................................................................................................... 20

3 References ....................................................................................................................................................... 21

Exhibits

1 Summary of Final Changes to Subpart LLL and Type of Incremental Impacts .................... 2

2 Regulated HAP and Appropriate Add‐On Control Devices ........................................................... 3

3 Average Emissions of the MACT Floor Kilns and Corresponding Final Emission Limits 4

4 Estimated Number of Each Type of Control Added and HAP Controlled ............................... 5

5 Nationwide Baseline Emissions and Emission Reductions .......................................................... 6

6 Average SO2 Emissions (lb/ton clinker) by Kiln Type (Andover, 2008) ................................. 6

.... 11

.... 12

7 Secondary Air, Water, and Solid Waste Impact Factors ..........................................................

8 Summary of Secondary Air, Water, and Solid Waste Impacts ..............................................

9 Specific Fuel Consumption, Total Exit Gas Flows, and Sulfur Dioxide Emissions for 

Various Kiln Types (from Andover 2008b) ......................... Error! Bookmark not defined.

10 RTO Input Parameters ............................................................................................................................... 16

11 Capital and Annual RTO Costs ................................................................................................................ 17

12 PM Control Scenarios ................................................................................................................................. 18

3 Capital and Annualized Cost for Existing and New Kilns ............................................................ 19

4 Total Nationwide Impacts ........................................................................................................................ 20

1

1
Summary of Environmental and Cost Impacts of Final Amendments to Portland Cement NESHAP 

1 

1 Introduction

The EPA is finalizing amendments to the current National Emission Standards for 

Hazardous Air Pollutants (NESHAP) for the Portland cement manufacturing industry. The 

final amendments add or revise, as applicable, emission limits for mercury (Hg), total 

hydrocarbons (THC), and particulate matter (PM) from new and existing kilns located at 

major or area sources, and for hydrochloric acid (HCl) from new and existing kilns located 

at major sources.  EPA is also adopting separate standards for these pollutants which apply 

during startup and shutdown operating modes.  Finally, EPA is adopting performance 

specifications for the use of mercury continuous emission monitors (CEMS) and is 

amending the rule to update recordkeeping and testing requirements. 

These final amendments also will remove the following provisions in the current NESHAP: 

the operating limit for the average hourly recycle rate for cement kiln dust; the opacity 

limits for kilns and clinker coolers; and the 50 parts per million volume dry basis (ppmvd) 

THC emission limit for new greenfield sources.  EPA is also removing the requirement that 

cement kilns using utility boiler fly ash only use ash of a certain type.  This requirement no 

longer applies once the kiln is subject to the numerical mercury emissions limits in these 

amendments. The EPA developed these final amendments in response to the notice of 

reconsideration published on December 20, 2006 and other requirements.  

This document summarizes the environmental and cost impacts of the final amendments 

and the methodology used to estimate the impacts. The impacts in this document are based 

on an estimated 140 existing kilns and, by 2013, an estimated 16 new kilns starting 

operation. The kilns that would be affected by the final revisions do not burn hazardous 

waste. Kilns that burn hazardous waste are regulated under the hazardous waste 

combustor rule (see 40 CFR part 63 subpart EEE). Section 2 discusses the impacts of this 

NESHAP review (scheduled for promulgation in 2010), including an overview of the final 

amendments that may lead to these impacts. 

2 Subpart LLL Impacts Estimated for 2010 Promulgation of

NESHAP Review

2.1 Affected Industry and Final Changes to Subpart LLL

The Portland cement manufacturing industry is comprised of an estimated 100 plants 

capable of producing clinker and operating a total of approximately 140 existing and 16 

new kilns, excluding kilns that burn hazardous waste. Hazardous waste burning kilns and 

grinding only facilities are not affected by the final rule and are not part of this analysis. 

Although the number of kilns fluctuates year‐to‐year due to closings of older, inefficient 

kilns and new or reconstructed kiln startups, the number of existing and new 

nonhazardous waste kilns used in this analysis is 156. The four types of kilns used in the 

U.S. are wet kilns, long dry kilns, preheater kilns (PH) and precalciner kilns (PC). 

Information on type of kiln and clinker capacity is based on 2008 data from the Portland 

Cement Association (PCA 2008). 
Summary of Environmental and Cost Impacts of Final Amendments to Portland Cement NESHAP 

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Environmental impacts were estimated for each of the existing 156 kilns using emissions 

test results when available. Where emissions data were not available, average emission 

factors were calculated from the available emissions data and used to estimate kiln 

emissions. Impacts are estimated for the year 2013, when all existing sources will be 

required to come into compliance. Based on industry capacity expansion estimates (PCA, 

2009), it is projected that by 2013, 16 new kilns will come on line and clinker production 

capacity will increase by approximately 24,000,000 tons. For analysis purposes, new kilns 

are assumed to be precalciner kilns having a clinker production capacity ranging from 

approximately 700,000 to over 4,000,000 tons per year with a capacity of 1,200,000 tons 

per year considered typical. Because of their energy efficiency and higher production 

capacity, all new kilns are expected to be precalciner kilns. 

The impacts of concern are incremental impacts, specifically the impacts associated with 

final changes in the NESHAP in comparison to the current, or baseline, regulations without 

the final changes. To estimate the impacts of the final amendments, current or baseline 

emissions are first estimated. Baseline emissions are then compared to projected emissions 

under the final revisions. Emission reductions resulting from the final amendments are 

based on the addition of control devices that are considered likely to be used to comply 

with the emission limits. The final subpart LLL amendments are scheduled to be 

promulgated in 2010. Changes in requirements being finalized as part of the 2010 NESHAP 

revision that are expected to result in incremental impacts in emissions are summarized in 

Exhibit 1. 

Exhibit 1 Summary of Final Changes to Subpart LLL and Type of Incremental

Impacts

Final Rule Change Type of Incremental Impact

Addition of a mercury limit for existing kilns of 

55 lb/million (MM) tons clinker and new kilns of 

21 lb/MM tons clinker. 

Costs to install activated carbon injection system 

or wet scrubbers. Associated emissions 

reductions are also estimated. 

Addition of a THC limit for existing and new kilns of 24

ppmvd @ 7% O2 (19% O2 for raw material dryers). 

Cost to install activated carbon injection systems 

and, in some cases, regenerative thermal 

oxidizers. Emission reductions are also 

estimated. 

Addition of an alternate organic HAP limit for existing 

and new kilns of 9 ppmvd @ 7% O2 (19% O2 for raw 

material dryers). 

Cost to install activated carbon injection systems 

and, in some cases, regenerative thermal 

oxidizers. Emission reductions are also 

estimated. 

Addition of an HCl limit for existing and new kilns of 2 

ppmvd @ 7% O2. Applies only to kilns located at major 

sources. 

Cost to install wet scrubbers. Emissions 

reductions are also estimated. 

A reduction in the PM stack emission limit for existing 

kilns from 0.5 lb of PM/ton of clinker (0.3 lb/ton of feed) 

to 0.04 lb of PM/ton of clinker. For new kilns, a reduction 

to 0.01 lb/ton of clinker. Also applies to clinker coolers. 

Costs to replace standard fabric bags with more 

expensive membrane bags and, in some cases, 

replace ESP with baghouses. Emission reductions 

are also estimated. 

Addition of mercury CEMS on all existing and new kilns. Capital costs of installation and annual costs of 

operation. 

Addition of THC CEMS to all existing kilns. (Already 

required on new kilns.) 

Capital costs of installation and annual costs of 

operation. 

Addition of HCl CEMS to all existing and new kilns, unless 

controlled by a caustic scrubber. 

Capital costs of installation and annual costs of 

operation. 
Summary of Environmental and Cost Impacts of Final Amendments to Portland Cement NESHAP 

3 

Addition of PM CEMS on all existing and new kilns. Capital costs of installation and annual costs of 

operation. 

2.2 Control Options

The ndments regulate emissions of the following HAP:  final ame

 Mercury, 

 THC, a surrogate for non dioxin/furan organic HAP (or, in the alternative, organic HAP), 

 HCl, and 

 PM, a surrogate for nonvolatile metal HAP. 

Add‐on control devices considered in this analysis and their removal efficiencies for each 

HAP are summarized in Exhibit 2. 

Exhibit 2 Regulated HAP and Appropriate Add­On Control Devices

HAP Control Device Removal Efficiency

Mercury  Wet scrubber

ACI w/polishing baghouse 

80% 

90% 

THC  ACI w/polishing baghouse

RTO (preceded by wet scrubber) 

50% 

98% 

Organic HAP  ACI w/polishing baghouse

RTO (preceded by wet scrubber) 

80% 

98% 

HCl  Wet scrubber

Li n  me Injectio

99.9% 

75% 

PM   Baghouse 99.9% 

ACI  activated carbon injection 

RTO  regenerative thermal oxidizer 

As can be seen from Exhibit 2, a control device may remove more than a single HAP. For 

example, activated carbon injection systems will remove mercury as well as THC and 

organic HAP. For purposes of this analysis it is assumed that an activated carbon injection 

(ACI) system would include a polishing baghouse. Most cement kiln dust (CKD) is recycled 

back to the kiln. As a result, ACI systems cannot be installed upstream of the main PM 

control device because the additional carbon that would end up in the CKD would make the 

CKD unsuitable for recycling back to the kiln. As a result, any ACI systems would need to be 

installed after the main PM control device and would utilize a polishing baghouse to 

capture the spent carbon. An ACI polishing baghouse will also result in increased 

reductions in PM emissions. 

It is expected that most sources will install wet scrubbers to reduce emissions of HCl. 

Scrubbers will also remove oxidized species of mercury, and reduce emissions of SO2. 

In a few instances, it may be necessary to install a regenerative thermal oxidizer (RTO) for 

the control of THC or organic HAP. To avoid fouling, plugging, and corrosion of the RTO, it 

is assumed that an RTO would be preceded by a wet scrubber, which is the case at a cement 

plants that currently uses an RTO. This plant continuously operates the RTO and scrubber. 

The RTO that has been installed on a cement kiln in the U.S. has used a wet scrubber 

upstream and is considered necessary to prevent operational problems with the RTO. 

Installing an RTO (with its upstream wet scrubber) for THC or organic HAP control will 

also reduce emissions of HCl and SO2 and potentially mercury. 
Summary of Environmental and Cost Impacts of Final Amendments to Portland Cement NESHAP 

4 

To determine the type of control device needed to comply with the final standards, baseline 

emissions for each kiln were compared to the average emissions of the top performing 

kilns used to develop the MACT floor limit, and the percent reduction that would be needed 

to reach the average emission level was calculated. Being able to reduce emissions to the 

average emission level, rather than the final emission limit will guarantee that the kiln can 

comply with the final limits most or all of the time. Average emissions plus a variability 

factor were used to establish the final MACT floor limit for each HAP. (A detailed 

explanation of how the MACT floors for existing and new sources were derived is contained 

in a separate document in the docket.) The average emissions of the MACT floor kilns, i.e., 

the top 12 percent of existing kilns, and the average emission of the best performing kiln 

(MACT for new sources), along with the corresponding final emission limits, are shown in 

Exhibit 3. 

Exhibit 3 Average Emissions of the MACT Floor Kilns and Corresponding Final

Emission Limits

Existing Kilns New Kilns

HAP

Average emissi

of top 12% of k

ons

ilns

Final Limit

(includes variability

factor)

Average emission of

best performing kiln

Final Limit

(includes variability

factor)

Mercury 32.1 lb/MM tons 

clinker 

55 lb/MM tons clinker 14 lb/MM tons clinker  21 lb/MM tons clinker

THC  5.2 ppmvd@7% O2 24 ppmvd@7% O2 4.7 ppmvd@7% O2 24 ppmvd@7% O2

Organic 

HAP

1.8 ppmvd@7% O2 9 ppmvd@7% O2 1.6 ppmvd@7% O2 9 ppmvd@7% O2

HCl  0.41 ppmvd@7% O2 2 ppmvd@7% O2 0.34 ppmvd@7% O2 2 ppmvd@7% O2

PM  0.02 lb/ton clinker  0.04 lb/ton clinker 0.01 lb/ton clinker 0.01 lb/ton clinker

Because of the variety of the HAP to be controlled, it is assumed that most kilns will require 

multiple controls to comply with all of the final limits. The number of kilns and the types of 

controls assumed in this analysis are shown in Exhibit 4. These estimates are considered 

conservative and likely overstate the number and types of controls that will be installed. 

Reasons for this include the inability to accurately estimate the number of kilns that will be 

able to comply using work practices such as material substitution and wasting CKD. It is 

believed that many kilns may be able to reduce emissions by substituting lower‐mercury 

raw materials than they now use. Substitution for the principal raw material, limestone, is 

less likely than for the other additives. Limestone constitutes 75 to 80 percent of the raw 

material used to make clinker and most plants are located at their source of limestone for 

economic reasons. Purchasing limestone from other locations would usually be too costly 

due to the cost of transportation. In addition, limestone quarries are owned by the cement 

plant or its parent company and would not be available to other cement plants with 

different ownership. Other non‐limestone materials (e.g., clay, shale, sand, and iron ore or 

slag), however, are typically purchased from various offsite sources and transported to the 

plant. Plants may have access to lower‐mercury materials, although the extent to which this 

is feasible would have to be determined on a site‐specific basis. Because mercury is also 

contained in CKD that is captured in PM control devices, the practice of wasting CKD, that is 

not recycling the CKD to the kiln, can be used to reduce mercury emissions. As with raw 

material substitution, the degree to which this practice can reduce mercury emissions can 
Summary of Environmental and Cost Impacts of Final Amendments to Portland Cement NESHAP 

5 

only be determined using site‐specific analyses. Other site‐specific factors not considered 

in this analysis are likely to affect final decisions by cement plants and companies on the 

best approach of complying with the limits being finalized. 

In this analysis, it is assumed that emissions of mercury, THC, HCl (except for scrubber‐

controlled kilns), and PM will be continuously monitored using continuous emissions 

monitoring systems (CEMS). Scrubber‐controlled kilns must perform an initial 

performance test for HCl using Method 321 and continuously monitor scrubber operating 

parameters. 

Exhibit 4 Estimated Number of Each Type of Control Added and HAP Controlled

Control Device HAP C o ontr lled Total Number of Each Control

Scrubber  Mercury

HCl 

120 

ACI (with polishing baghouse)  Mercury

THC (Organic HAP) 

PM* 

146 

Lime Injection  HCl 4 

RTO  THC (Organic HAP) 10 

Membrane Bags  PM 34 

*Not the target of the control device, but co‐controlled. 

2.3 Air Quality Impacts

The impacts of the final standard on emissions of mercury, THC (a surrogate for non 

dioxin/furan organic HAP), HCl, and PM (a surrogate for nonvolatile metal HAP) were 

estimated. Impacts were estimated from a baseline level, that is, the emission levels under 

the current NESHAP. Therefore, baseline emissions were also estimated. Direct impacts on 

the targeted pollutants were estimated, as well as co‐benefits associated with the controls 

added to comply with the final standard. Secondary impacts were also estimated including 

the increase in emissions from additional electricity or fossil fuel required to power control 

devices, water quality impacts (e.g., from scrubbers), and solid waste impacts (e.g., from 

disposal of spent sorbents). 

2.3.1 Hydrogen Chloride

In developing the MACT floor for HCl, HCl emissions measurements based on EPA Methods 

321 and 26 were collected. Because Method 26 is thought to be biased low due to a 

scrubbing effect in the front half of the sampling train (see 63 FR 14182), the HCl data 

measured at 21 kilns using Method 321 was used to calculate annual emissions. For kilns 

lacking site‐specific test data, an HCl emission factor was estimated from the available 

Method 321 test data. Average baseline emissions of HCl were estimated using an average 

stack  outlet concentration of 12 ppmvd at 7 percent O2. Annual emissions were calculated 

as follows: 

X ppmvd HCl/106 volume stack gas * 100,000 dscf/ton clinker * lbmole/ft3/(0.73)(528)   

* tons clinker produced/yr * 36 lb HCl/lbmole HCl * ton/2,000 lb

Annual nationwide baseline HCl emissions from all existing kilns total about 4,900 tpy. 
Summary of Environmental and Cost Impacts of Final Amendments to Portland Cement NESHAP 

6 

For a new 1.2 million tpy kiln with HCl emissions at a concentration of 12 ppmvd, baseline 

HCl emissions would be 68 tpy. Baseline emissions for 16 new kilns would be an estimated 

1,100 tpy. 

To estimate the reduction in emissions of HCl under the final standards, the number of 

kilns that would add controls was estimated. It is estimated that 29 of the existing kilns will 

not be subject to the final standards for HCl because they are identified in the EPA’s 

National Emissions Inventory (NEI) as area sources. For these kilns, there would be no 

environmental or cost impacts as a result of the final standards for HCl. An estimated 

118 existing kilns would require scrubbers to meet the proposed HCl standards and 4 

could meet the standard using dry lime injection. Wet scrubbers are estimated to reduce 

HCl emissions by 99.9 percent. Dry lime injection is estimated to reduce HCl emissions by 

75 percent. Total nationwide emission reductions from existing kilns were estimated to be 

4,800 tpy. For a new 1.2 million tpy kiln, emission reductions were estimated at 68 tpy; by 

2013, total emission reductions from all new kilns would total about 1,100 tpy. Total 

nationwide baseline emissions and emission reductions for HCl are summarized in 

Exhibit 5. 

Exhibit 5 Nationwide Baseline Emissions and Emission Reductions

HAP Existing or new kilns Baseline emissions Emission reductions

HCl  Existing   4,907 tpy 4,755 tpy

New  1,110 tpy 1,101 tpy

THC  Existing   12,16 tp 5 y 6,453 tpy

New  793 tpy 397 tpy

Organic HAP  Existing   4,364 tpy 3,433 tpy

New  433 tpy 346 tpy

Mercury Existing   15,942 lb/yr 14,703 lb/yr 

New  2,096 lb/yr 1,886 lb/yr 

PM  Existing   10,32 p 6t y 9,489 tpy

New  2,165 tpy 1,990 tpy

As a co‐benefit of controlling HCl using wet scrubbers, emission of SO2 will also be reduced. 

Wet scrubbers used for HCl control will reduce SO2 emission by 95 percent; dry lime 

injection by 70 percent. Uncontrolled SO2 emissions vary by kiln type and location and 

emission factors for SO2 are presented in Exhibit 6. Uncontrolled SO2 emission factors and 

scrubber and lime injection control efficiencies were used to estimate SO2 emission 

reductions resulting from the control of HCl. Total nationwide SO2 reductions from existing 

kilns was estimated at 115,000 tpy. For a new 1.2 million tpy kiln equipped with a 

scrubber, SO2 emissions reductions would be about 190 tpy or 18,000 tpy for 16 new kilns 

by 2013. 

Exhibit 6 Uncontrolled SO2 Emissions (lb/ ton clinker) by Kiln Type and State

(Andover, 2009)

State Precalciner Preheater Dry Wet

AL 0.09 0.61 13.99

AZ 1.30 0.07 8.51

AR 2.94 3.45 7.59
Summary of Environmental and Cost Impacts of Final Amendments to Portland Cement NESHAP 

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State Precalciner Preheater Dry Wet

CA 0.33 1.12 0.81 0.00

CO 0.32 0.10 1.07 4.24

CT 1.15 2.32 9.03 7.81

DE 1.15 2.32 9.03 7.81

FL 0.45 0.02

GA 0.95 2.73 11.42 12.25

ID 0.13 0.70

IL 5.58 5.77 5.88 9.50

IN 1.15 2.32 9.03 7.81

IA 1.15 2.32 9.03 7.81

KS 1.25 5.88 24.85 8.61

KY 0.19 5.04 12.53

LA 1.15 2.32 9.03 7.81

ME 0.30 0.30 11.98

MD 3.14 3.95 7.31 7.49

MA 1.15 2.32 9.03 7.81

MI 5.23 5.31 18.00

MN 1.15 2.32 9.03 7.81

MS 0.09 0.61 13.99

MO 2.18 1.51 7.02

MT 0.13 0.70

NE 1.25 5.88 24.85 8.61

NV 0.49 0.05 1.51

NH 1.15 2.32 9.03 7.81

NJ 1.15 2.32 9.03 7.81

NM 1.30 0.07 8.51

NY 0.30 0.30 11.98

NC 1.15 2.32 9.03 7.81

ND 1.15 2.32 9.03 7.81

OH 0.19 5.04 12.53

OK 1.25 5.88 24.85 8.61

OR 0.13 0.70

PA 1.15 2.32 9.03 7.81

RI 1.15 2.32 9.03 7.81

SC 0.95 2.73 11.42 12.25

SD 0.32 0.10 1.07 4.24

TN 0.95 2.73 11.42 12.25

TX 1.15 2.32 9.03 7.81

UT 0.13 0.70

VT 1.15 2.32 9.03 7.81
Summary of Environmental and Cost Impacts of Final Amendments to Portland Cement NESHAP 

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State Precalciner Preheater Dry Wet

VA 0.95 2.73 11.42 12.25

WA 0.53 3.80

WV 3.14 3.95 7.31 7.49

WI 1.15 2.32 9.03 7.81

WY 0.32 0.10 1.07 4.24

            

National Average 1.15 2.32 9.03 7.81

2.3.2 Total Hydrocarbons (Organic HAP)

Total hydrocarbons (THC) are a surrogate for non dioxin/furan organic HAP. The specific 

organic compounds that will be measured to determine compliance with the alternative to 

the THC limit are benzene, toluene, styrene, xylene (ortho‐, meta‐, and para‐), acetaldehyde, 

formaldehyde, and naphthalene.  Emissions stack tests, including both manual short‐term 

tests and long‐term continuous emissions monitoring data were used to estimate baseline 

THC and organic HAP emissions for each kiln with THC test data. To estimate emissions for 

the remaining kilns, an average THC emission factor was used that was calculated from 

available emissions test data. The average concentration of organic HAP in THC was 35 

percent. For purposes of this analysis, the emission factor excludes emissions data from a 

kiln already controlled using an RTO, as well as from 5 kilns with THC emissions that were 

uncharacteristically high and not typical of THC emissions from other kilns for which we 

had data. The emission factor used in this analysis for kilns for which data were not 

available is 21.4 ppmv at 7 percent O2. Annual emissions for a preheater or precalciner kiln 

were calculated as follows: 

X ppmv THC/106 volume stack gas * 100,000 dscf/ton clinker * lbmole/ft3/(0.73)(528)

* tons clinker produced/yr * 44 lb/lbmole propane * ton/2,000 lb

Nationwide baseline THC emissions are estimated at 12,000 tpy. Baseline THC emissions 

from a new 1.2 million tpy kiln were estimated to be 185 tpy or about 800 tpy for 16 new 

kilns. Nationwide baseline organic HAP emissions from existing kilns are estimated at 

4,000 tpy. Baseline organic HAP emissions from a new 1.2 million tpy kiln were estimated 

to be 50 tpy or about 400 tpy for 16 new kilns. 

To estimate emission reductions under the final THC limits (and alternative organic HAP 

limits), the number of kilns that would need to reduce emissions by adding controls was 

estimated. ACI systems would reduce THC emissions by an estimated 50 percent and 

organic HAP emissions by 80 percent.   For any kiln requiring higher removal efficiencies, 

an RTO preceded by a wet scrubber would be used with a removal efficiency of 98 percent. 

It is already assumed that to comply with the mercury limits, most kilns will install ACI 

systems. As a result of controls added for mercury, THC and organic HAP will also be 

controlled without additional controls.  An estimated 10 kilns would require an RTO 

preceded by a scrubber; for all other kilns, ACI systems installed to control mercury 

emissions are sufficient to control THC and organic HAP emissions.  

Total nationwide THC emission reductions from existing kilns would be an estimated 6,000 

tpy. The emission reduction in THC for each new kiln was estimated at 90 tpy or 400 tpy 
Summary of Environmental and Cost Impacts of Final Amendments to Portland Cement NESHAP 

9 

2.3.3 Mercury

Stack test emissions data are typically used to estimate baseline emissions and emission 

reductions. However, given that mercury emissions are largely determined by the 

concentration of mercury in the raw materials and fuel and are highly variable, and that 

mercury is recycled to the kiln from the raw mill (if there is an in‐line raw mill) as well as 

CKD captured in the particulate control devices, short‐term mercury stack test data 

(typically a few hours) are not necessarily indicative of long term emissions performance. 

An alternative to short term stack test data would be to use mercury continuous 

monitoring data over a longer time period. However, no cement kilns have continuous 

mercury monitors, so this option was not available. Because mercury is an element, and can 

neither be created nor destroyed in a cement kiln, all the mercury that enters a kiln has to 

leave the kiln as a stack emission with the following exceptions: 1) mercury removed by 

cement kiln dust (CKD) captured in a PM control device where the CKD is wasted (i.e., not 

recycled to the kiln), and 2) mercury captured in a wet scrubber (used to control SO2

emissions) where the mercury ends up in the gypsum produced from the de‐watered 

scrubber slurry. The available data indicate that almost no mercury leaves the kiln as part 

of the clinker. Based on these facts, EPA determined the most accurate method available to 

determine long term mercury emission performance was to obtain data on all the kiln 

mercury inputs for 30 days from a large group of kilns and assume that all mercury that 

enters the kiln is emitted with the two exceptions noted above. EPA obtained 30 days of 

daily data on kiln mercury concentrations in each individual raw material, fuel, and CKD for 

89 kilns, along with annual mass inputs and CKD wastage. These data were submitted as 

daily concentrations for the inputs, i.e. samples were taken and analyzed daily for mercury 

content. Using the daily averages, a mean concentration was calculated and multiplied by 

annual materials use to calculate an annual mercury emission. If the facility wasted CKD, 

the annual mercury that left the system in the CKD was subtracted out. If the facility had a 

wet scrubber, the average mercury removal efficiency was estimated from concurrent 

inlet/outlet testing done at the five kilns with wet scrubbers. This annual emission was 

then divided by total inputs to calculate an average emission factor in pounds of mercury 

emitted per million tons of clinker produced (lb/MM tons clinker). For the kilns for which 

feed and fuel mercury content was not collected, a mercury emission factor was calculated 

using the average of the individual emission factors for the 89 kilns for which there were 

for the 16 new kilns expected by the end of 2013. Total nationwide baseline emissions and 

emission reductions of THC as well as new kiln emission reductions are summarized in 

Exhibit 5. 

Total nationwide organic HAP emission reductions from existing kilns would be an 

estimated 5,000 tpy. The emission reduction in organic HAP for each new kiln was 

estimated at 40 tpy or 140 tpy for 9 new kilns by the end of 2013. Total nationwide 

baseline emissions and emission reductions of organic HAP as well as new kiln emission 

reductions are summarized in Exhibit 5. 

Because some kilns were assumed to install an RTO and scrubber to reduce THC or organic 

HAP, SO2 emissions would also be reduced. Total nationwide SO2 emission reductions 

associated with THC control would be about 11,000 tpy for existing kilns.  No new kilns are 

expected to add an RTO and scrubber system. 
Summary of Environmental and Cost Impacts of Final Amendments to Portland Cement NESHAP 

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2.3.4 Particulate Matter

Total particulate matter (PM) emissions are being used as a surrogate for nonvolatile metal 

HAP in the proposed amendments. Baseline emissions were derived from PM data in EPA’s 

National Emissions Inventory (NEI) for 2005. Because the PM standards in the current 

NESHAP and those being proposed are for total filterable PM and the PM data in NEI are 

PM10 filterable data, the NEI data were converted to total PM filterable emissions 

assuming that an average of 85 percent of total PM emissions is PM10 filterable. Baseline 

data and multiplied by each kiln’s clinker production to estimate annual mercury emissions 

from each kiln.  

Excluding data from two kilns considered outliers, the average mercury emissions rate is 

111 lb/MM tons clinker. Total nationwide baseline emissions from existing kilns were 

estimated at 16,000 lb/yr. For a new 1.2 MM ton/yr kiln, mercury emissions would be 

about 130 lb/yr using an emission factor of 111 lb/MM tons clinker; for 16 new kilns, 

baseline emissions would be 2,000 lb/yr.  

For purposes of this analysis, reductions in mercury emissions under the final amendments 

would occur in one of two ways: 1) as a direct result of controls added to remove mercury 

from kiln exhaust gases, or, 2) as a result of controls added to remove other HAP. Available 

controls for mercury considered in this analysis include ACI and wet scrubbers. ACI would 

a higher removal efficiency for mercury than wet scrubbers. ACI is expected to achieve a 90 

percent removal efficiency while a wet scrubber is expected to achieve a removal efficiency 

of 80 percent. Because ACI is less costly and has a higher removal efficiency, it was 

assumed that ACI would be selected over wet scrubbers. Although it was assumed that 

most kilns would also add wet scrubbers for HCl control, it was not assumed that the 

efficiency of the two controls would be additive (with the exception of two kilns). For 

purposes of this analysis, when a kiln would be equipped with both ACI and a wet scrubber, 

only the efficiency of the ACI system was applied. This is reasonable as the reduced 

mercury concentration in the exhaust gases of the ACI system make it unlikely that a 

scrubber could still achieve an 80 percent reduction. Furthermore, most of the mercury in 

the oxidized state would have been removed by the ACI system and the remaining 

elemental mercury in the exhaust stream would not be captured by the scrubber. For the 

two high mercury emitting kilns in this dataset, it was assumed that the ACI system would 

reduce mercury emissions by 90 percent and that the scrubber following the ACI system 

would get an additional 80 percent control. For a few kilns, the need to install an RTO  with 

its precleaning scrubber for THC or organic HAP control would negate the need for an 

additional ACI system for mercury. Total nationwide emissions reductions of mercury from 

existing kilns were estimated at 15,000 lb/yr. Emission reductions for a new 1.2 million tpy 

kiln that uses ACI would reduce mercury emissions by about 120 lb/yr or 1,900 lb/yr for 

16 new kilns by the end of 2013. Nationwide baseline emission and emission reductions as 

well as new kiln emission reductions are summarized in Exhibit 5. 

Emissions of SO2 would also be reduced where wet scrubbers are installed for the control 

of mercury. In this analysis, only two kilns installed scrubbers for mercury, which was done 

in combination with ACI to get a higher mercury removal efficiency. Emissions of SO2

would be reduced by about 1,400 tpy.  
Summary of Environmental and Cost Impacts of Final Amendments to Portland Cement NESHAP 

11 

emissions already account for the existing PM control devices in use. Using clinker 

production for each kiln, a PM emission factor in pounds of PM per ton of clinker was 

calculated. For the kilns for which NEI data were not available, the average of the NEI data 

was used to derive an emission factor. The average PM emissions rate based on the NEI is 

0.34 lb/ton of clinker. Total baseline emissions of PM for existing kilns were estimated at 

10,000 tpy. At 0.34 lb PM/ton of clinker, PM emissions from a new 1.2 million tpy kiln 

would be about 200 tpy; emissions from the 16 new kilns would be 2,000 tpy. 

For this analysis, it was assumed that the required reductions in PM emissions would be 

accomplished by either replacement of existing standard fabric bags with membrane bags 

or replacement of existing ESP’s that are not meeting the target PM level with a baghouse 

with membrane bags. Another scenario that would adequately reduce PM emissions occurs 

when an ACI system (for THC/organic HAP or mercury control), including a polishing 

baghouse, is installed in series with an existing PM control device. It is estimated that under 

these scenarios, PM removal efficiency would be at least 99.9 percent or higher. Assuming 

that emissions were reduced down to the average of the top performing kilns (0.02 lb/ton 

clinker) in order to assure compliance with the proposed PM emission limit of 0.04 lb/ton 

clinker, the reduction in PM emissions from existing kilns were estimated at 9,500 tpy. 

Assuming a reduction down to the proposed PM limit for new kilns, 0.01 lb/ton clinker, the 

reduction in PM emissions from a new kiln would be about 200 tpy and about 2,000 tpy for 

all new kilns. Baseline emissions and emission reductions for existing and new kilns are 

summarized in Exhibit 5. 

2.3.5 Secondary Impacts

Secondary air quality impacts would result from the increased electrical and fuel demands 

of control equipment required to comply with the proposed amendments. The addition of 

add‐on controls, such as scrubbers and RTO’s, will increase electricity and natural gas 

demands. The secondary impacts in this analysis include the impacts of additional 

electricity and natural gas consumption and the pollution associated with the generation of 

the electricity and the combustion of the natural gas. Factors used to estimate secondary 

air and other impacts are summarized in Exhibit 7. 

Exhibit 7 Secondary Air, Water, and Solid Waste Impact Factors

Secondary Impact Factor

Scrubber power demand (Andover 2008, p. 27) 3 kwh/ton clinker

RTO power demand (calculated using EPA Cost Manual) 30.9 kwh/DSCFM

RTO natural gas demand (calculated using EPA Cost Manual) 0.73 MMBtu/DSCFM

ACI power demand w/polishing baghouse (Docket item II‐B‐67, Docket A‐92‐53) 6 kwh/ton clinker

Scrubber makeup water (Andover 2/26/2010, p. 4) 60 gal/ton clinker

Solid waste generated from ACI (Docket item II‐B‐67, Docket A‐92‐53) 3 lb/ton clinker

The following emission factors were used to estimate increased emissions of NOx, CO, SO2, 

PM10, and CO2 from the increased electricity and natural gas demand (Docket item IV‐B‐25, 

Docket A 94‐ ‐ 52): 

NOx

NOx

CO 

‐ 

‐ 

‐ 

0.00446 lb/kWhr 

0.1 lb/MMBtu natu

0.00231 lb/kWhr  

ral gas
Summary of Environmental and Cost Impacts of Final Amendments to Portland Cement NESHAP 

12 

SO2

1

‐  0.00765 lb/kWhr 

PM

O2

0 ‐ 

‐ 

2.25(10‐4) lb/kWhr 

C 2.1 lb/kWhr 

CO2  ‐  117 lb/MMBtu natural gas (EIA – Natural Gas Issues and Trends, 1998) 

Increases in secondary emissions resulting from the increased electrical demand of an 

alkaline scrubber and ACI, and the increased electrical and natural gas demands of an RTO 

for existing and new kilns are summarized in Exhibits 8 and 9. 

Exhibit 8 Summary of Increased Electricity and Natural Gas Demand

Scrubber

electricity demand

(MMkwh/yr)

Lime injection

electricity

de

(MMkwh/hr)

mand

RTO electricity

dem nd a

(MMkwh /yr)

RTO natural gas

demand

( ) MMBtu/yr

ACI electricity

de d man

(MMkwh/ yr)

Total electricity

demand

(MMkwh/ yr)

Existing kilns  2   21 0   .1 44 1,04 ,118 1 515  780

New kilns 

  Per kiln  4  0  0 0 7  11

  All new kilns  57  0.2  0 0 141  199

T

in

otal impacts 

 2013  279  0.3  4450  1,041,118  656  979 

Exhibit 9 Summary of Secondary Air, Water, and Solid Waste Impacts

NOx

(tpy)

CO

(tpy)

SO2

(tpy) PM10 (tpy)

CO2

(tpy)

Make­up water

(M r) Mg l/y a

ACI solid waste

(tpy)

Existing kilns  1   ,740 901  2 5 ,98 88 88 5 0,26 4,   423 1 2 28,76

New kilns 

  Per kiln  24  12  41 1 378 72  1,800

  All new kilns  444  230  761 22 208,900 1,149  35,322

T

2

otal impacts in 

013  2,184  1,131  3,746  110  1,089,165  5,572  164,084 

2.4 Water Quality Impacts

The use of alkaline scrubbers will result in increased consumption of water (for makeup 

water and production of the scrubber slurry). Additional makeup water demands for 

scrubbers are estimated to be 60 gal/ton of clinker (Andover 2010). Total additional 

makeup water for existing kilns would be an estimated 4.4 billion gal/yr. For a new 1.2 

million tpy kiln, the additional water requirement is estimated at 72,000,000 gallons per 

year. Total additional water consumption in 2013 would be 5.6 billion gal/yr. No water 

quality impacts are associated with the use of baghouse, RTO or ACI systems.  

2.5 Solid Waste Impacts

Additional solids would be generated as a result of the addition of scrubbers. 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.  

Solids will be generated as a result of installation of ACI systems. An estimated 3 lb solid 

waste per ton of clinker would be generated (Docket item II‐B‐67, Docket A‐92‐53). The 

amount generated by a new 1.2 million tpy kiln was estimated to be 1,800 tpy. In 2013, 

total solid waste from existing and new kilns will be about 164,000 tpy.  
Summary of Environmental and Cost Impacts of Final Amendments to Portland Cement NESHAP 

13 

2.7 Cost Impacts

The costs of the final amendments were estimated based on the type of control device that 

was assumed to be necessary to comply with the final emission standards. The approach 

used to determine the type of control needed was described earlier. In summary, based on 

a kiln’s baseline emissions of mercury, THC, HCl, and PM, and the removal efficiency 

necessary to comply with the final emission limit for each HAP, an appropriate control 

device was identified. In assigning control devices to kilns where more than one control 

device was considered appropriate, it was assumed that the least costly control would be 

installed. For example, if a kiln could use a scrubber or ACI to meet the final mercury limit, 

it was assumed that ACI would be selected over a scrubber because an ACI system would 

be less costly to install and operate. ACI also is expected to achieve a higher removal 

efficiency than a scrubber for mercury. In some instances, a more expensive technology 

was considered appropriate because the selected control reduced emissions of multiple 

pollutants. For example, even though ACI would be less costly than a scrubber for 

controlling mercury, if the kiln also needed to reduce HCl emissions, it was assumed that a 

scrubber would be applied to control HCl as well as mercury because ACI would not control 

HCl. However, for many kilns, this analysis assumes that multiple controls will be needed in 

order to adequately control all HAP. For example, ACI would be necessary to meet the 

limits for THC and/or mercury. For the same kiln, a scrubber would also be required to 

reduce HCl emissions. This approach and the resulting cost estimates are considered very 

conservative in that it is not possible to consider what other alternatives, in lieu of multiple 

add‐on controls, may be available to cement plants to comply with the final emission limits. 

Because individual cement manufacturing plants may implement process or other changes 

to reduce emissions, the costs of the final amendments likely overstate the costs that 

actually will be incurred by individual cement plants. For example, some plants may be able 

to reduce mercury emissions by substituting raw materials having lower mercury 

concentrations or by increasing the amount of cement kiln dust (CKD) wasted instead of 

recycled (mercury can accumulate in CKD), thereby avoiding the need for add‐on controls 

for mercury. The feasibility of using these and other work practices at cement plants would 

have to be determined on a site‐specific basis and cannot be assumed to be applicable at all 

cement plants. In addition to the costs associated with add‐on controls, the final standard 

also requires continuous monitoring to ensure compliance with the emission limits. For 

this analysis, it was assumed that the cost of continuous monitoring for mercury, THC, HCl 

(except where controlled by a scrubber), and PM would be incurred for each kiln. Kilns 

The additional solid waste generated from baghouses in the form of CKD is typically 

considered product and is returned to the kiln or mixed with the cement. No solid waste 

impacts are anticipated with the use of an RTO system. 

2.6 Energy Impacts  

Additional electricity demand would result from the addition of scrubbers, RTO’s, and ACI 

on existing and new kilns. A summary of the total additional energy demand for existing 

and new kilns is presented in Exhibit 8. Total electricity demand for existing and new kilns 

in 2013 would be an estimated 979 million kwh/yr; total natural gas demand is estimated 

to be 1,041,118 MMBtu/yr.  
Summary of Environmental and Cost Impacts of Final Amendments to Portland Cement NESHAP 

14 

controlled by a scrubber would conduct an initial and periodic Method 321 test for HCl. The 

total cost of compliance for each kiln includes the cost of monitoring. 

2.7.1 Wet Alkaline Scrubber

Cost estimates for wet alkaline scrubbers were based on recent work by Andover (2008a, 

2009, 2010). The report describes the development of scrubber costs that are primarily a 

function of the type of kiln (wet, dry, preheater, precalciner) and the kiln’s capacity. Site‐

specific information was available on the type of kiln and its clinker production capacity for 

all kilns in the U.S.; consequently, the cost algorithms could be used to develop site‐specific

estimates of scrubber costs. 

Comments on the gas flowrate and the capital cost estimating approach used for proposal 

underestimated kiln gas flowrates and kiln capital costs. As a result, the approach for 

estimating gas flowrates and capital cost estimates for wet scrubbers was revised (Andover 

2010). 

A gas flowrate of 100,000 dscf/ton of clinker was used to estimate theDSCFM = 

69*0.00304*TPY clinker 

 After determining the volumetric flowrate for each kiln, the capital cost (CC in 2005 

dollars) for each kiln is calculated from (Andover, 2008a; Andover, 2010a; Barnett, Laney, 

2010): 

CC  =  14,398 (DSCFM)0.6

Fixed costs (FC) include labor (operating, supervisory, and maintenance), maintenance 

ma eplace , t xes, insurance, etc. and were estimated from (Andover, 

200

terials, r ment parts a

8a): 

FC  =  38  *  TPY0.6  +  0.04  *  CC

Variable costs (VC) include consumption of limestone, power, and water plus a credit for 

rec  an ere estima 08 dov ndover, 

20

overy of gypsum d w ted from (Andover, 20 a; An er, 2009; A

10a; Andover, 2010b): 

VC  = (0.000844  *  TPY  *  COSTKWH)  +  (‐0.041  *  TPY  *  SO2)  +  (TPY  *  0.025) 

W

OS

here: 

C TKWH  =  $0.0724/kWhr, and 

SO2  =  lb SO2 per ton of clinker, from Exhibit 6.

Total annualized cost (TAC) includes fixed annual costs, variable annual costs, and capital 

recovery nt interest rate, 20‐year lifetime, and a capital recovery factor 

of 0.0944 AC  from: 

 (based on a 7 perce

). T  is estimated

TAC = FC  +  VC  +  0.0944  *  CC

2.7.2 Dry Lime Injection

he cost of dry lime injection systems were based on recent work by Andover (2008a, 

009, 2010). Capital costs were estimated as: 

T

2
Summary of Environmental and Cost Impacts of Final Amendments to Portland Cement NESHAP 

15 

CC  =  44 * TPY0.6

ixed costs include the cost of maintenance and taxes, insurance and overhead and is  

st

F

e imated as follows: 

FC  =  $59,200 + 0.04  *  CC

V iable cos ar t is the cost of lime plus power and is estimated using the following: 

VC = (0.05* COSTKWH * TPY) + (0.3 * TPY * SO2)

Where:

COSTKWH  =  $0.0724/kWhr, and 

SO2  =  lb SO2 per ton of clinker, from Exhibit 6.

Total annualized cost (TAC) includes fixed annual costs, variable annual costs, and capital 

recovery (based on a 7 percent interest rate, 20‐year lifetime, and a capital recovery factor 

of 0.0944 AC ). T  is estimated from: 

TAC = FC  +  VC  +  0.0944  *  CC

2.7.3 Activated Carbon Injection

The control costs of using ACI system and polishing baghouse to control mercury emissions 

and THC emissions from cement kilns were estimated using costs that were originally 

developed for electric utility boilers.  Following proposal, ACI costs were revised to reflect 

additional information on kiln exhaust gas flow rates and cost for activated carbon was 

updated. Using exhaust gas flow rates as the common factor, control costs for electric 

utilities were scaled to derive control costs for Portland cement kilns. Two electric utility 

boiler units of different capacities and exhaust gas airflows that were comparable to 

exhaust gas flow rates for cement kilns were used. Capital and annual cost factors ($/ton of 

clinker) were developed using the boiler costs and gas flow data for the different size 

boilers. The revised capital cost factors ranged from $1.93 to $3.20/ton of clinker; the 

average is $2.56/ton of clinker. The total annualized costs ranged from $0.82 to $1.00/ton 

of clinker; the average is $0.91/ton of clinker. The method used to calculate the total capital 

and total annualized costs are described previously (Docket item OAR‐2002‐0051‐1891). 

2.7.4 Regenerative Thermal Oxidizers

Costs for an RTO are based on costs of an RTO installed and currently operating on an 

existing kiln and the EPA Air Pollution Control Cost Manual. To estimate capital cost for 

existing kilns and model new kilns, the total capital cost of the operating RTO was scaled 

based on exhaust gas flow rates for each existing kiln and the model new kiln. Input 

parameters and annual cost inputs used in estimating costs are shown in Exhibit 10. The 

capital and annual cost for this kiln are shown in Exhibit 11. 
Summary of Environmental and Cost Impacts of Final Amendments to Portland Cement NESHAP 

Allowing for economies of scale in capital cost, total capital costs (TCI) were calculated 

using the following cost function: 

ual costs were calculated as a function of e

TAC  =  14,177  +  8.3  *  DSCFM  +  0.1824  *  TCI

Ann  fix d and variable costs as follows: 

2.7.4 Baghouses and Membrane Bags

The costs of a reverse air baghouse and standard fabric bags were calculated for a kiln with 

a kiln exhaust gas flow rate of 185,550 DSCFM using the EPA Air Pollution Control Cost 

Manual. The total costs for a baghouse using standard fabric bags on a kiln with an exhaust 

gas flow rate was estimated to be $5.7 million capital cost and $2 million annual cost. To 

scale these costs for kilns with different exhaust gas flow rates, the following cost functions 

were used to estimate total capital costs (TCIstd) and total annual cost (TACstd) for a 

baghouse with standard fabric bags: 

Exhibit 10 RTO Input Parameters

16 

Input Parameters

Gas flow rate (scfm)  502,312 

Reference temperature (°F)  77 

Inlet gas temperature (°F) 150 

Inlet gas density (lb/scf)  0.0739 

Primary heat recovery (fraction) 0.95 

Waste gas heat content (Btu/scf) 5   17.00

Waste gas heat content (Btu/lb)  6995.83 

Gas heat capacity (Btu/lb‐°F)  0.255 

Combustion temperature (°F)  1500 

Heat loss (fraction)  0.01 

Exit temperature (°F)  218 

Fuel heat of combustion (Btu/lb)  21,502 

Fuel density (lb/ft3)  0.0408 

Design Parameters

Auxiliary fuel requirement (lb/min)  31.323 

Auxiliary fuel requirement (scfm)  767.7 

Total gas flow rate (scfm)  503,080 

Annual Cost Inputs

Operating factor (hr/yr)  7,920 

Operating labor rate ($/hr)  12.96 

Maintenance labor rate ($/hr)  14.26 

Operating labor factor (hr/sh)  0.50 

Maintenance labor factor (hr/wk)  1.00 

Electricity price ($/kWh)  0.050 

Natural gas price ($/1000scf)  9.30 
Summary of Environmental and Cost Impacts of Final Amendments to Portland Cement NESHAP 

Annual interest rate (fraction)  0.07 

Control system life (years)  15 

Capital recovery factor  0.1098 

Taxes, insurance, admin. factor  0.04 

Pressure drop (in. w.c.)  20.0 

The costs of a reverse air baghouse and membrane bags were calculated for a kiln with a 

kiln exhaust gas flow rate of 185,550 DSCFM using the EPA Air Pollution Control Cost 

Manual. Membrane bags are more costly than standard fabric bags. The total costs for a 

baghouse using membrane bags on a kiln with an exhaust gas flow rate of 185,550 DSCFM 

were estimated to be $7.1 million capital cost, and $230,000 annual cost. To scale these 

costs for kilns with different exhaust gas flow rates, the following cost functions were used 

to estimate total capital costs (TCImb) and total annual cost (TACmb) for a baghouse with 

membrane bags: 

TACMB  =  226,966  +  5.65  *  DSCFM  +  0.1344  *  TCI

Exhibit 11 Capital and Annual RTO C

17 

osts

Capital Costs ($)

DIRECT COSTS 

  P ed equipment cost (PEC) urchas 16,000,000

  Direct installation costs 

    Foundation and support (8% of PEC) 1,280,000 

    Enclosure building  0 

    Site preparation (15% of PEC) 2,400,000 

  Total direct installation (DIC)  3,680,000 

  TOTAL DIRECT COST (DC)  19,680,000

I T   NDIREC  COSTS

  I ion  nstallat

    Engineering (10% of PEC) 1,600,000 

    Construction & field expense (5% of PEC) 800,000 

    Contractor fee (10% of PEC) 1,600,000 

    Contingencies (10% of PEC) 1,600,000 

  TOTAL INDIRECT COST (IC)  5,600,000 

TOTAL CAPITAL INVESTMENT (TCI = DC + IC) 25,280,000

Annual Costs ($/yr)

Operating labor  6,415

Supervisory labor  962 

Maintenance labor  742 

Maintenance materials  742 

Natural gas  3,392,816 

Electricity 776,956 

Overhead (0.6 of labor and maintenance materials) 5,316 

Taxes, insurance, administrative  1,011,200 

Capital recovery 2,775,608 
Summary of Environmental and Cost Impacts of Final Amendments to Portland Cement NESHAP 

18 

TOTAL ANNUAL COST  7,970,758 

For purposes of this analysis, if an existing baghouse needed to increase efficiency to 

comply with the final PM emission limit, it was assumed that standard fabric bags would be 

replaced with membrane bags. The incremental costs between a baghouse with standard 

bags and a baghouse with membrane bags was used to estimate the additional cost of 

replacing standard bags with membrane bags. Where it was considered necessary to 

replace an existing ESP with a baghouse, it was assumed that the cost would be that of a 

baghouse with membrane bags. If the existing PM control was a fabric filter and an ACI is 

assumed be added for other HAP, then the kiln would be equipped with two baghouses in 

series and no additional PM control was assumed to be necessary. If the existing PM control 

was an ESP and the plant would add ACI, it was assumed that the polishing baghouse would 

be equipped with membrane bags. If the existing PM control was an ESP and no controls 

would be added that would also control PM (e.g., ACI), then it was assumed that the ESP 

would be replaced with a baghouse equipped with membrane bags. Where baseline 

emissions of a kiln were below the average PM emission level of the top 5 baghouses (see 

xhibit 3), no additional control was considered necessary. The various baseline and 

otential control scenarios are summarized in Exhibit 12.  

E

p

Exhibit 12 PM Control Scenarios

Baseline PM Controla ACI System Added for

Mercury or THCb

Additional Control Needed

for PM

Baghouse  Yes None

Baghouse  No Membrane bags added to 

existing baghouse 

ESP  Yes Membrane bags installed in 

polishing baghouse 

ESP  No ESP r

with m

eplaced with baghouse 

embrane bags 

Baseline is at or below 0.01 lb/ton clinker 

(average of  top 5 kilns) 

Yes or No None

a  If information was not available on the type of PM control in use for a kiln, the PM control was assumed to be a baghouse. 

b  It is assumed that a polishing baghouse is an integral part of an ACI system. 

Monitoring costs were based on the use of PM CEMS. Costs were estimated using the CEMS 

Cost Model. The capital/startup cost for PM CEMS is $172,527. Annual operations and 

maintenance costs for PM CEMS are $58,211. 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%). 

2.7.6 Cost of Control for Hydrogen Chloride (HCl)

The cost of complying with the final HCl emission standards were estimated as the costs of 

installing and operating add‐on control equipment and the cost of installing and operating 

continuous emission monitoring equipment. Only kilns that are major sources would be 

required to comply with the final standard for HCl. An estimated 111 kilns were estimated 

to be major sources based on data from EPA’s NEI and would be subject to the HCl 

standards. It was assumed that wet scrubbers or dry lime injection systems would be 
Summary of Environmental and Cost Impacts of Final Amendments to Portland Cement NESHAP 

19 

installed to control HCl emissions. Kilns identified as area sources from EPA’s NEI and kilns 

that, based on test data, will comply with the final limit without further control, were 

assumed to not add a scrubber for HCl. Total capital and annual costs for major sources 

include the cost of HCl CEMS at $144,000 first time or capital cost and about $43,000 per 

year annual cost. The annual cost for scrubbers also includes a credit of $120 per ton for 

the scrubber sludge that would be recovered as gypsum and used in the process. Total 

nationwide capital cost for existing kilns was estimated at approximately $1,581 million 

with annual cost for existing kilns of $220 million per year.  

Total capital cost for a new 1.2 million tpy kiln, including the cost of CEMS, is $25.1 million 

per kiln. Annualized cost including the gypsum credit and monitoring is $3.6 million per 

year per kiln. Capital and annualized costs for existing and new kilns are presented in 

Exhibit 13. 

Exhibit 13 Capital and Annualized Cost for Existing and New Kilns

HAP Existing or new kilns Capital Cost Annualized Cost

HCl  Existing   $1,582 million $220 million/yr

New   $324 million $48 million/yr

THC (Organic HAP)  Existing   $277 million $57 million/yr

New   $2.2 million $0.7 million/yr

Mercury Existing $277 million $91 million/yr

New   $62 million $22 million/yr

PM  Existing   $54 million $15 million/yr

New   $2.8 million $0.9 million/yr

2.7.7 Cost of Control for Total Hydrocarbons (Organic HAP)

Under the final amendments, an estimated 124 existing kilns would need to install ACI 

systems to comply with the final limits for THC or organic HAP. Another 10 kilns are 

expected to install RTO systems preceded by a wet scrubber and an estimated that 6 kilns 

would meet the THC or organic HAP limits without any additional controls although these 

kilns may install ACI or scrubber for mercury control. All kilns would be required to 

continuously monitor THC emissions. The capital cost for THC CEMS was estimated at 

$137,000; annualized cost is an estimated at $42,000 per year. Total nationwide capital 

cost for controls and monitoring for existing kilns was estimated at $277 million with 

annualized costs of $56 million per year. 

Of the estimated 16 new kilns expected to come on line, it is estimated that all  will comply 

by installing an ACI system to comply with the final limits. The capital and annualized costs 

of ACI for a new 1.2 million tpy kiln would be $3.2 million and $1.1 million per year, 

respectively. Capital and annualized cost for existing and new kilns are presented in 

Exhibit 13. 

2.7.8 Cost of Control for Mercury

The cost for complying with the final mercury standards were estimated as the cost of 

installing and operating add‐on control equipment and the cost of installing and operating 

CEMS for mercury. All but 15 kilns would incur costs to control mercury emissions.  It was 

estimated that 123 kilns would install ACI systems and that 2 kilns, because of higher than 

average mercury emissions, would install both ACI and wet scrubbers for mercury control. 
Summary of Environmental and Cost Impacts of Final Amendments to Portland Cement NESHAP 

20 

Total nationwide capital cost was estimated at $277 million; total nationwide annualized 

cost was estimated at $91 million per year. 

Assuming that a new kiln would install ACI for mercury control, a new 1.2 million tpy kiln 

would incur a capital cost of $3.2 million and an annualized cost of $1.1 million per year. 

Capital and annualized costs for existing and new kilns are presented in Exhibit 13. 

2.7.9 Cost of Control for Particulate Matter

It was estimated that existing baghouses on 25 kilns would be retrofitted to replace 

standard fabric filters with membrane bags. Total nationwide capital cost for controls and 

monitoring for existing kilns was estimated at $54 million with annualized cost of $15 

million per year. These costs include the addition of PM CEMS. 

Additional costs for new kilns would be incurred under the final amendments assuming 

that membrane bags rather than standard fabric bags would be installed in a new 

baghouse. For a 1.2 million tpy kiln, capital cost would be an estimated $1.8 million; 

annualized cost would be $350,000 per year. Capital and annualized costs for existing and 

new kilns are presented in Exhibit 13. 

2.8 Summary of Impacts

Nationwide impacts in the  year 2013 f are summarized in Exhibit 14. The costs include the 

osts that will be incurred by existing kilns and by the 16 new kilns that will be operation 

y the end of 2013. 

c

b

Exhibit 14 Total Nationwide Impacts

HAP Capital Cost Annualized Cost Emissions Reduction

Existing Kilns

Mercury  $277 million $91 million/yr 14,703 lb/yr mercury

1,387 tpy SO2 

THC (Organic HAP)  $277 million $57million/yr 3,433 tpy organic HAP

6,453tpy THC

11,158 typ SO2 

HCl  $1,582 million $220million/yr 4,755 tpy HCl

102,669 tpy SO2 

PM (Metal HAP)  $54 million $15 million/yr 95 tpy metal HAP

9,489 tpy PM 

Total Existing  $2.19 billion $382.4 million/yr HAP 8,290 tpy*

All 135,918 tpy

New Kilns

Total New  $391 million $72.4 million 1,886 lb/yr Hg

346 tpy organic HAP 

397 tpy THC 

1,101 tpy HCl 

1,990 tpy PM 

17,704 tpy SO2

HAP 1,468 tpy*

All 21,193 tpy 

Total, Year 2013 $2.58 billion $455 million/yr HAP 9,758 tpy

All 157,111 tpy
Summary of Environmental and Cost Impacts of Final Amendments to Portland Cement NESHAP 

21 

*Assumed that metal HAP is 1% of PM. 

3 References

Andover, 2008a. Memorandum. J. Staudt, Andover Technology Partners, Costs and 

Performance of Controls, prepared for EPA, September 23, 2008. 

Andover, 2008b. Memorandum. J. Staudt, Andover Technology Partners, NOx, SO2 and CO2 

emissions from cement kilns (Emissions Memo), prepared for EPA, September 23, 2008. 

Andover, 2009.  Memorandum. J. Staudt, Andover Technology Partners, Costs and 

Performance of Controls – revised from comments, prepared for EPA, March 10, 2009. 

Andover, 2010a.  Memorandum. J. Staudt, Andover Technology Partners, Wet Scrubber 

Cost Algorithm, prepared for EPA, February 26, 2010. 

Andover, 2010b.  Memorandum. J. Staudt, Andover Technology Partners, Electrical Load for 

Wet Scrubbers, prepared for EPA, May 6, 2010. 

Barnett, K. and M. Laney, 2010. Memorandum. Capital Costs for Wet Scrubbers, August 6, 

2010. 

CEMS Cost Model. July 2006. 

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.  

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. 

Portland Cement Association. 2009. Capacity Report. October 19, 2009. 

 Cement Association. 2008. U.S. and Canadian Portland Cement Industry; Plant 

ion Summary December 31, 2008

Portland

Informat . 

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. 
Summary of Environmental and Cost Impacts 

of Final Revisions to Portland Cement New 

Source Performance Standards 

(40 CFR Part 60, subpart F) 

Docket Number EPA-HQ-OAR-2007-0877 

August 6, 2010 
Table of Contents 

1 Introduction ............................................................................................................................. 4 

2 Subpart F Impacts Estimated for 2010 Promulgation of NSPS Review ................................. 4 

2.1 Affected Industry and Final Changes to Subpart F .......................................................... 4 

2.2 Air Quality Impacts .......................................................................................................... 5 

2.2.1 Nitrogen Oxides (NOx) ............................................................................................. 5 

2.2.2 Particulate Matter (PM) ............................................................................................ 8 

2.2.3 Sulfur Dioxide (SO2)................................................................................................. 8 

2.2.4 VOC and CO ............................................................................................................. 9 

2.2.5 Secondary Impacts .................................................................................................. 10 

2.3 Water Quality Impacts ................................................................................................... 10 

2.4 Solid Waste Impacts ....................................................................................................... 10 

2.5 Energy Impacts ............................................................................................................... 10 

2.6 Cost Impacts ................................................................................................................... 11 

2.6.1 NOx Emissions ........................................................................................................ 11 

2.6.2 Particulate Matter (PM) Emissions ......................................................................... 12 

2.6.3 SO2 Emissions ......................................................................................................... 12 

2.7 Summary of Impacts ...................................................................................................... 12 

3 References ............................................................................................................................. 15 

Exhibits 

1 Summary of Final Changes to Subpart F and Type of Incremental Impacts ......................... 5

2 Options Considered for NOx Reductions from Kilns ............................................................ 7

3 Options Considered for PM Reductions from Kilns [DELETE] ........ Error! Bookmark not 

defined.

3 Options Considered for SO2 Reductions for Kilns with High-Sulfur Inputs ................ Error! 

Bookmark not defined.

4 Options Considered for SO2 Reductions for Kilns with Medium-Sulfur Inputs .......... Error! 

Bookmark not defined.

5 Secondary Emissions for a 1,200,000 tpy Kiln ..................... Error! Bookmark not defined.

6 Nationwide Secondary Emissions ......................................... Error! Bookmark not defined.

7 Costs and Cost Effectiveness of NOx Emission Limits for 1,200,000 tpy Kiln .................. 11

9 Wet Alkaline Scrubber Input Parameters for New Kiln Model [DELETE] ................. Error! 

Bookmark not defined.

10 Wet Alkaline Scrubber Capital and Annual Costs for New Kiln Model[DELETE] .... Error! 

Bookmark not defined.

10 (continued) [DELETE] ......................................................... Error! Bookmark not defined.

11 Lime Injection Input Parameters for New Kiln Model[DELETE] ..... Error! Bookmark not 

defined.

12 Lime Injection Capital and Annual Costs for New Kiln Model[DELETE] ................. Error! 

Bookmark not defined.

ii 
iii

13 Costs of SO2 Emission Limits for 1,200,000 tpy Kiln *[DELETE] ... Error! Bookmark not 

defined.

8 Cost and Environmental Impacts of Final Amendments for a 1,200,000 tpy Kiln ............. 13

9 Nationwide Cost and Environmental Impacts of Final Amendments ................................. 14
1 Introduction 

To meet the requirements of section 111(b)(1)(B) of the CAA, the Environmental Protection 

Agency (EPA) is conducting the fourth review of the new source performance standards (NSPS) 

for Portland Cement Plants (PCP). The 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 7 new kilns by the year 2013. Section 2 

discusses the impacts of this NSPS review, including an overview of the final amendments 

resulting in impacts and the methodology used to develop the impact estimates. 

2 Subpart F Impacts Estimated for 2010 Promulgation of NSPS 

Review 

2.1 Affected Industry and Final Changes to Subpart F 

The Portland cement manufacturing industry is comprised of an estimated 100 cement plants 

capable of producing clinker and operating a total of approximately 140 kilns (PCA, 2008). 

Based on industry capacity expansion estimates (PCA, 2009), it is projected that by the fifth year 

following promulgation of the amendments, 7 new kilns will come on line and clinker 

production capacity will increase by approximately 10,550,000 tons. 

To illustrate impacts of the final NSPS, 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 year 2013, in which it is assumed that 7 new kilns will have been built. 

The current subpart F NSPS review is scheduled to be promulgated in 2010. 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 2010 NSPS amendments. The impacts are determined for the 

year 2013, 3 years after promulgation of the 2010 NSPS revisions. Baseline represents the 

impacts associated with application of the current NSPS. The incremental impacts of the 2010 

NSPS review are determined by comparison to the baseline impacts. Changes in requirements 

being proposed as part of the 2010 NSPS review that could result in significant incremental 

impacts include those summarized in Exhibit 1. 

4
Exhibit 1 Summary of Final Changes to Subpart F and Type of Incremental Impacts 

Final Rule Change Type of Incremental Impact 

▪ A reduction in the PM stack emission limit for kilns from 0.5 lb of 

PM/ton of clinker (0.3 lb/ton of feed) to 0.01 lb of PM/ton of clinker. 

This revision is the result of amendments to the NESHAP for portland 

cement. 

Because this revision is the result of 

amendments to the NESHAP for portland 

cement, no impacts are associated with 

this change to the NSPS. 

▪ A reduction in the PM stack emission limit for clinker coolers from 

0.17 lb of PM/ton of clinker (0.1 lb/ton of feed) to 0.01 lb of PM/ton of 

clinker. This revision is the result of amendments to the NESHAP for 

portland cement. 

Because this revision is the result of 

amendments to the NESHAP for portland 

cement, no impacts are associated with 

the final NSPS. 

▪ Addition of a NOx limit of 1.5 lb NOx /ton clinker. Costs to install SNCR. Emission 

reductions are also estimated. 

▪ Addition of a SO2 limit of 0.4 lb SO2/ton clinker, or 90% reduction of 

SO2 across the control device. 

Because amendments to the NESHAP for 

portland cement will require scrubbers for 

the control of HCl, which will also 

control SO2 emissions, no impacts are 

associated with this change to the NSPS. 

▪ Addition of PM CEMS on all new baghouses. Capital costs of installation and annual 

costs of operation. 

▪ Addition of continuous NOx monitors on new kilns. Capital costs of installation and annual 

costs of operation. 

▪ Addition of continuous SO2 monitors on new kilns. Capital costs of installation and annual 

costs of operation. 

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

costs of operation. 

The air quality impacts and costs of the final amendments to the NSPS for Portland cement 

manufacturing were calculated using the following assumptions: 

• Wet alkaline scrubbers installed on all new kilns for the control HCl emissions under the 

NESHAP for portland cement will also reduce emissions of SO2 from new kilns subject 

to the NSPS by 95 percent; 

• New kilns will be subject to the new source PM requirements under the NESHAP and 

will be equipped with baghouses using membrane bags rather than fabric bags; 

• SNCR will be installed on all new kilns to control NOx emissions; 

• NOx monitors will be installed to monitor emissions from all new kilns; 

• SO2 monitors will be installed to monitor emissions from all new kilns; and 

• PM CEMS will be installed to monitor emissions from all new kilns and clinker coolers. 

2.2 Air Quality Impacts 

2.2.1 Nitrogen Oxides (NOx) 

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 NOx formation. In cement kilns, NOx emissions are formed during fuel combustion 

primarily by the oxidation of molecular nitrogen present in combustion air (referred to as thermal 

5
NOx) and the oxidation of nitrogen compounds in fuel (referred to as fuel NOx). Many states 

issuing construction and operating permits for new kilns have specified emission limits for NOx. 

In recently built kilns, emissions of NOx are typically reduced through process controls such as 

burner design and staged combustion in the calciner (SCC). NOx emissions from kilns using 

process designs such as low NOx burners and SCC average about 2.5 lb/ton of clinker (EPA, 

2007). This level of uncontrolled NOx emissions was supported by additional information that 

was submitted in comments on the proposed limits (see the response-to-comment document in 

the docket). Add-on controls that have been used to reduce NOx 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 NOx burners. In 

SNCR systems, ammonia, urea or another reagent is injected into the flue-gas in an appropriate 

temperature zone and at an appropriate ratio of ammonia to NOx. On average, SNCR achieves 

approximately a 35 percent reduction in NOx at a ratio of ammonia-to-NOx of about 0.5 and a 

reduction of 63 percent at an ammonia-to-NOx ratio of 1.0. Additional information submitted 

following proposal (see the response-to-comment document in the docket) showed SNCR 

removal efficiencies ranging from 25 percent (no ammonia molar ratio given) to over 90 percent 

(ammonia molar ratio of 1.0 to 1.2) with an average efficiency of 60 percent. For this analysis, a 

removal efficiency of 50 percent was used. At high ratios, some ammonia may not react with 

NOx and will be emitted (ammonia slip). Another NOx control technology, SCR, is used in the 

electric utility industry to reduce NOx emissions from boilers and, to date has been used 

worldwide on three cement kilns. SCR is capable of reducing NOx emission by about 80 percent. 

Currently, SCR is not used on any cement kilns in the U.S. although a cement manufacturer is 

currently a consent decree to install SCR on one kiln. 

Four options were evaluated for control of NOx 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 NOx 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 NOx 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, average NOx 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 NOx 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 NOx burners and SCC. However, we expect that, on 

6
average, new facilities would require a NOx removal efficiency of 22 percent 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 90 percent NOx reduction. We estimate that about 50 

percent NOx 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 NOx 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 

NOX value of 1.44 lb/ton, and a calculated 99th 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. 

Exhibit 2 shows the annual NOx reductions achieved for each option, for a single kiln producing 

1,200,000 tons per year (tpy) of clinker, and nationwide for 7 kilns, based on the projected 

clinker capacity for each new kiln. 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 emissions reductions (relative to the 2.5 lb/ton baseline level) are 0, 0.55, 1, 

and 2 lb/ton, respectively. Exhibit 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). Exhibit 2 also presents annual 

nationwide reductions, based on 7 new kilns in the year 2013. Nationwide emission reductions 

are calculated incrementally (i.e., compared to the next less stringent option) and in total 

(compared to the baseline, Option 1). 

Exhibit 2 Options Considered for NOx Reductions from Kilns 

Option 

Emission Factors, per ton of clinker 

Per Kiln Reductions 

(@1.2 million tpy kiln 

production) 

Annual Nationwide 

Reductions 

(based on 7 new kilns) 

Emission 

Limit 

(lb/ton) 

Incremental 

Reduction 

(lb/ton) 

Total 

Reduction 

(lb/ton) 

Incremental 

Reduction 

(tons) 

Total 

Reduction 

(tons) 

Incremental 

(tons) 

Total 

(tons) 

1 2.5 0 0 0 0 0 0 

2 1.95 0.55 0.55 330 330 2,901 2,901 

3 1.5 0.45 1 270 600 2,373 5,275 

4 0.5 1 2 600 1,200 5,275 10,550 

7
2.2.2 Particulate Matter (PM) 

We proposed a PM emissions limit of 0.086 lb PM/ton clinker based on fabric filters using 

membrane bags. This specific level was chosen because it is representative of the performance 

of this technology and was equivalent to the new source limit contained in the Hazardous Waste 

Combustor (HWC) NESHAP for cement kilns burning hazardous waste. This rationale is no 

longer applicable, since EPA is reassessing the PM limit in the HWC NESHAP. (See USEPA 

Motion for Voluntary Remand in # 05-1441, (D.C. Circuit, August 29, 2008).) 

As discussed in the summary of environmental and cost impacts of the NESHAP, EPA is setting 

a PM limit under the Portland Cement NESHAP of 0.01 lb PM/ton clinker for new sources based 

on a 30-day rolling average. We project that new cement kilns meeting the 0.01 lb PM/ton 

clinker limit will be using the same technology which formed the basis of the proposed Portland 

Cement NSPS PM limit, namely fabric filters and membrane bags. It should also be noted that 

we estimate that many new facilities will need to install fabric filters in series as part of mercury 

controls under the NESHAP. This means that a new kiln will install PM controls required to 

meet the 0.01 lb PM/ton limit under the NESHAP in any case, so establishing the same limit for 

PM in the NSPS not only is technically justified, but has no additional cost. EPA also assessed 

the costs of installing and operating fabric filters with membrane bags at proposal, and found this 

to be a cost-effective control technology in any case (73 FR at 34077). The technology would 

now be evaluated as more cost-effective than at proposal, since greater PM reductions will result 

from its use. Therefore, we are establishing an NSPS PM limit of 0.01 lb PM/ton clinker in this 

final NSPS, averaged over 30 days (rolling average) and measured with a CEMS. For reasons 

previously discussed, we are setting the same limit for clinker coolers. 

The control of PM emissions under the NSPS will be accomplished by baghouses and membrane 

bags installed for PM (as a surrogate for nonvolatile metal HAP) control under the NESHAP so 

that no impacts are attributable to the NSPS. A discussion of the PM control costs environmental 

impacts is presented in the summary of environmental and cost impacts for the NESHAP. 

2.2.3 Sulfur Dioxide (SO2) 

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 SO2 emissions 

from cement kilns. As a result, wet scrubbers and lime injection were evaluated as potential 

control technologies for Portland cement operations. The final 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 SO2 emitted 

into the atmosphere from this source. The other source of SO2 is the raw materials, which may be 

oxidized to SO2 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 SO2 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 SO2 emissions can be 

significant. In those situations, add-on controls may be necessary to prevent high SO2 emissions. 

8
The first type of SO2 control equipment considered is alkaline scrubbers. They are capable of 

achieving a 90 to 95 percent reduction in SO2 emissions on cement kilns (Bahner and Laney, 

2008). The difference between SO2 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 SO2 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 SO2. At some facilities lime injection is only used when increases in SO2

emissions 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 SO2 emissions for proposal. The first option was to 

maintain the baseline of no SO2 emission limit. The other three options were limits of 1.33 lb/ton 

of clinker, 0.4 lb/ton of clinker, and 0.2 lb/ton of clinker. At proposal, EPA chose the higher limit 

because the 0.4 lb SO2/ton limit would have resulted in new kilns with moderate sulfur content 

raw materials experiencing a cost effectiveness per ton of SO2 removed of $6,000. However, 

EPA has changed their decision and is setting the SO2 limit for new kilns at 0.4 lb/ton of clinker. 

The reason for the change is that as a result of the NESHAP requirement to meet a HCl 

emissions level of 2 ppmvd, it is likely that all new kilns will have to install a wet scrubbers for 

HCl control. Hence, the cost of meeting the 0.4 lb/ton clinker limit in the NSPS is minimal, only 

the cost of the SO2 CEMS. 

The control of SO2 emissions under the NSPS will be accomplished by wet scrubbers installed 

for HCl control under the NESHAP so that no impacts are attributable to the NSPS. A discussion 

of the control costs (for HCl) is presented in the summary of environmental and cost impacts for 

the NESHAP. 

2.2.4 VOC and CO 

 EPA is not establishing limits for CO or volatile organic compound (VOC) emissions 

from cement kilns. VOC emissions from new cement kilns will mainly result from organics in 

the raw materials. Organic constituents in the raw materials can be driven off in the kiln 

preheater prior to reaching the temperature zone that would result in combustion. All new 

cement kilns will be subject to a continuous 24 ppmvd THC emissions limit by the portland 

cement NESHAP. Because most of the THC are also VOC, the THC limit also directly limits 

VOC, and serves as the baseline for the NSPS analysis. This limit is also the new source limit 

based on the best performing source. Therefore we determined that no additional regulation of 

VOC emissions is necessary or 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. 

9
Emissions of CO evolved from raw materials can be significant if there are substantial levels of 

organics in the raw material. As noted at proposal, the only control technology identified that 

reduces CO emissions is an RTO (which also would concurrently reduce any VOC emissions). 

However, we believe application of an RTO as BDT for CO would result in significant cost and 

adverse energy impacts. Therefore, it was determined that no additional regulation of CO 

emissions was feasible. It should also be noted that in no cases have add-on controls for CO (or 

VOC) been required as BACT under new source review. 

2.2.5 Secondary Impacts 

Secondary air quality impacts result from the increased electrical demands of control equipment 

required to comply with the final amendments. For SNCR systems for the control of NOx, the 

electricity demand for pumping the reagent is negligible. The addition of add-on controls, such 

as scrubbers, will increase electricity demands. However, as discussed above, because of 

requirements under the final NESHAP for the control of HCl that will also control SO2, no 

additional controls are required under the NSPS and impacts from scrubbers are not attributable 

to the final NSPS. (See the environmental and cost impacts under the NESHAP for a discussion 

of the secondary impacts of scrubbers.) 

2.3 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 would be an estimated 72,000,000 gallons per year. However, because the 

requirements of the final NESHAP will require scrubbers to control HCl, which will also control 

SO2, no additional requirements are needed under the NSPS. There are no water quality impacts 

associated with the use of SNCR systems. See the discussion of water quality impacts under the 

See the discussion in the environmental and cost impacts 

2.4 Solid Waste Impacts 

There are no solid waste impacts under the final NSPS. The slurry that is created in the scrubber 

contains synthetic gypsum and is typically dewatered and returned to the process where it is 

mixed with clinker in the finish mill. No solid waste impacts are anticipated with the use of an 

SNCR system. The additional solid waste generated from baghouses, in the form of cement kiln 

dust is typically considered product and is returned to the kiln or mixed with the cement. 

Furthermore, the control of PM emissions under the NSPS will be accomplished by baghouses 

and membrane bags installed for PM control under the NESHAP so that no impacts are 

attributable to the NSPS. A discussion of the solid waste impacts is presented in the summary of 

environmental and cost impacts for the NESHAP. 

2.5 Energy Impacts 

The energy demands for pumping reagent in SNCR are negligible. The use of alkaline scrubbers 

on new kilns will increase electricity consumption, although the increase in demand is not 

attributable to the NSPS. There are no significant energy impacts associated with the final NSPS. 

10
2.6 Cost Impacts 

2.6.1 NOx Emissions 

Four options were evaluated for control of NOx emissions. The first option was to maintain the 

baseline of no NOx limits. The other three options are given in terms of pounds of NOx 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 – NOx 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 analysis 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 NOx 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 final amendments, compliance with the emission limits for NOx will be determined 

using continuous emissions monitoring systems. Continuous flow rate monitors will also be 

required to determine compliance. The capital/startup costs for NOx and flow rate CEMS are 

$140,951 and $35,780, respectively. Annual operations and maintenance costs for NOx 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 NOx 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 7 new kilns will install 

SNCR to comply with the NOx emission limit, the total annualized cost is an estimated $11 

million. Total capital cost in 2013 is an estimated $19.8 million. 

Exhibit 3 shows the costs and potential reductions associated with each of the four options for 

NOx control. 

Exhibit 3 Costs and Cost Effectiveness of NOx Emission Limits for 1,200,000 tpy Kiln 

Option 1 2 3 4 

11
12

(Baseline) (1.95 lb/ton 

clinker) 

(1.5 lb/ton 

clinker) 

(0.5 lb/ton 

clinker) 

Capital cost, $million 0 2.3 2.3 5.7 

Annualized cost, $million/yr 0 0.7 1.3 3.1 

Total NOx reduction (tpy) 0 330 600 1,200 

Total C/E ($/ton NOx) 0 2,023 2,113 2,546 

2.6.2 Particulate Matter (PM) Emissions 

The control of PM emissions under the NSPS will be accomplished by baghouses and membrane 

bags installed for PM (as a surrogate for nonvolatile metal HAP) control under the NESHAP so 

that no control costs are attributable to the NSPS. A discussion of the PM control costs is 

presented in the summary of environmental and cost impacts for the NESHAP. 

Under the final amendments, compliance with the emission limits for PM will be demonstrated 

using continuous emissions monitoring systems (PM CEMS) installed for demonstrating 

compliance with the PM (nonvolatile metal HAP) limits under the NESHAP so that no 

monitoring costs are attributable to the NSPS. 

2.6.3 SO2 Emissions 

The control of SO2 emissions under the NSPS will be accomplished by wet scrubbers installed 

for HCl control under the NESHAP so that no control costs are attributable to the NSPS. A 

discussion of the control costs (for HCl) is presented in the summary of environmental and cost 

impacts for the NESHAP. 

Under the final amendments, compliance with the emission limits for SO2 will be determined 

using continuous emissions monitoring systems. Continuous flow rate monitors will also be 

required to determine compliance. The capital/startup costs for SO2 and flow rate CEMS are 

$143,135 and $35,780, respectively. Annual operations and maintenance costs for SO2 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 SO2 CEMS. 

Attachment 3 is the output file from the CEMS cost Model for flow rate CEMS. 

Assuming that seven new kilns will install SO2 CEMS and continuous flow rate monitors to 

demonstrate compliance with the SO2 emissions limit, the total annualized monitoring cost is 

estimated to be $400,000. Total capital cost over the 5-year period following promulgation is an 

estimated $1.3 million. 

2.7 Summary of Impacts 

Environmental and cost impacts for the final amendments for a 1.2 million tpy kiln are 

summarized in Exhibit 4. Nationwide impacts in the year 2013 are summarized in Exhibit 5. 
Exhibit 4 Cost and Environmental Impacts of Final Amendments for a 1,200,000 tpy Kiln * 

Pollutant Cost ($) ** Emission 

Reduction 

(tpy) 

Secondary Impacts 

Capital Annual Increase 

in 

electricity 

demand 

(kWh/yr) 

Increase 

in water 

usage 

(gpy) 

Increase 

in solid 

waste 

(tpy) 

Increase 

in 

emissions 

of NOx

(tpy) 

Increase 

in 

emissions 

of CO 

(tpy) 

NOx 2,289,000 1,292,000 600 Negligible 0 0 0 0 

PM 0 0 0 0 0 0 0 0 

SO2 0 0 0 0 0 0 0 0 

 *Emission reductions and secondary impacts for PM and SO2 are attributed to the Portland Cement NESHAP. 

**Includes monitoring costs. 

13
14

Exhibit 5 Nationwide Cost and Environmental Impacts of Final Amendments * 

Pollutant Cost ($) ** Emission 

Reduction 

(tpy) 

Secondary Impacts 

Capital Annual Increase 

in 

electricity 

demand 

(kWh/yr) 

Increase 

in water 

usage 

(gpy) 

Increase 

in solid 

waste 

(tpy) 

Increase 

in 

emissions 

of NOx

(tpy) 

Increase 

in 

emissions 

of CO 

(tpy) 

NOx 19,805,000 11,045,000 5,275 Negligible 0 0 0 0 

PM 0 0 0 0 0 0 0 0 

SO2 0 0 0 0 0 0 0 0 

TOTAL 19,805,000 11,045,000

* Emission reductions and secondary impacts for PM and SO2 are attributed to the Portland Cement NESHAP. **Includes monitoring cost.
3 References 

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

Bahner, M. 2008a. Review and Analysis of NOx 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-OAR2002-0051-1891. 

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. 2009. Capacity Expansion Estimates. October 19, 2009. 

Portland Cement Association. 2008. U.S. and Canadian Portland Cement Industry Plant 

Information Summary December 31, 2008. 

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. 

15
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. 

16
Attachment 1 

SO2 Monitor Cost 

Output from the EPA CEMS Cost Model 

17
Attachment 1 

Summary of CEMS 

Analyzers 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

 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

 Number of fabric filters to be monitored= 0 0 

 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 PM) 1,284 0 1,069 2,353 

 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 

18
Attachment 2 

NOx Monitor Cost 

Output from the EPA CEMS Cost Model 

19
Attachment 2 

Summary of CEMS 

Analyzers 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

 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

 Number of fabric filters to be monitored= 0 0 

 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 PM) 1,284 0 1,069 2,353 

 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 

20
Attachment 3 

Flow Rate Monitor Cost 

Output from the EPA CEMS Cost Model 

21
22

Attachment 3 

Summary of CEMS 

Analyzers 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

 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

 Number of fabric filters to be monitored= 0 0 

 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 7,650 692 10,647

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 PM) 0 0 0 0 

 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 1,152 3,098 5,095

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

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