## 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, 2010Summary of Environmenta l and Cost Impacts of Final Amendments t o 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 R eview ....................... 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 Subpa rt LLL and Type of Incremental Impacts .................... 2

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

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

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

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

6 Average SO 2 Emissions (lb/ton clinker) b y 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 Dio xide 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 ............................................................ 1 9

4 Total Nationwide Impacts ........................................................................................................................ 20 1

1Summary of Environmenta l and Cost Impacts of Final Amendments t o Portland Cement NESHAP

1 

## 1 Introduction

The EPA is finalizing amendments to the current National Emissi on Standards for Hazardous Air Pollutants (NESHAP) for the Portland cement manuf acturing industry. The final amendments add or revise, as applicable, emission limits for mercury (Hg), total hydrocarbons (THC), and particulate matter (PM) from new and ex isting kilns located at major or area sources, and for h ydrochloric acid (HCl) from new and existing kilns located at major sources.  EPA is also ad opting separate standards for these pollutants which apply during startup and shutdown oper ating modes.  Finally, EPA is adopting performance specifications for the use of me rcury continuous emission monitors (CEMS) and is amending the rule to update reco rdkeeping and testing requireme nts.

These final amendments also will remove the following provision s in the current NESHAP: the operating limit for the average hourly recycle rate for cem ent kiln dust; the opacity limits for kilns and clinker coolers; and the 50 parts per mill ion volume dry basis (ppmvd) THC emission limit for new green field sources.  EPA is also rem oving the requirement that cement kilns using utility boiler fly ash only use ash of a cer tain type.  This requirement no longer applies once the kiln is su bject to the numerical mercur y emissions limits in these amendments. The EPA developed these final amendments in respons e to the notice of reconsideration published on D ecember 20, 2006 and other requir ements.

This document summarizes the envi ronmental and cost impacts of the final amendments and the methodology used to estimate the impacts. The impacts i n 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 revisi ons 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 disc usses the impacts of this NESHAP review (scheduled for promulgation in 2010), including a n 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 e stimated 100 plants capable of producing clinker and operating a total of approxima tely 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 clo sings of older, inefficient

kilns and new or reconstructed k iln startups, the number of exi sting 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 kil ns, preheater kilns (PH) and pr ecalciner kilns (PC). Information on type of kiln and clinker capacity is based on 20 08 data from the Portland Cement Association (PCA 2008).Summary of Environmenta l and Cost Impacts of Final Amendments t o Portland Cement NESHAP

2 Environmental impacts were estim ated for each of the existing 1 56 kilns using emissions

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

factors were calculated from the available emissions data and u sed 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 ex pansion 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 an alysis 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. Bec ause of their energy efficiency and higher production capacity, all new kilns are expected to be precalciner kilns.

The impacts of concern are incre mental impacts, specifically th e impacts associated with final changes in the NESHAP in c omparison to the current, or ba seline, regulations without the final changes. To estimate the impacts of the final amendme nts, current or baseline emissions are first estimated. Baseline emissions are then comp ared to projected emissions

under the final revisions. Emissi on reductions resulting from t he final amendments are

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

with the emission limits. The fin al 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 re sult 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 R ule Change Type of Incremental Impact Addition of a mercury limit for existing kilns of 55 lb/million (MM) tons cl inker 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% O 2 (19% O 2 for raw material dryers). Cost to install activated carbon injection systems and, in some cases, re generative thermal

oxidizers. Emission reductions are also

estimated. Addition of an alternate org anic HAP limit for existing and new kilns of 9 ppmvd @ 7% O 2 (19% O 2 for raw material dryers). Cost to install activated carbon injection systems and, in some cases, re generative thermal

oxidizers. Emission reductions are also

estimated. Addition of an HCl limit for existing and new kilns of 2 ppmvd @ 7% O 2 . 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)

n to 0.04 lb of PM/ton of clinke r. For new kilns, a reductio to 0.01 lb/ton of clinker. Als o applies to clinker coolers. Costs to replace standar d fabric bags with more expensive membrane bag s and, in some cases,

s replace ESP with baghous es. Emission reduction

are also estimated. Addition of mercury CEMS on all existing and new k ilns. 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 installa tion and annual costs of operation. Addition of HCl CEMS to all existing and new kilns, unless controlled by a caustic scrubber. Capital costs of installa tion and annual costs of operation.Summary of Environmenta l and Cost Impacts of Final Amendments t o Portland Cement NESHAP

3 Addition of PM CEMS on all existing and new kilns. Capital costs of installation a nd annual costs of operation.



### 2.2 Control Options

The ndments regulate emissions of the following HAP: final ame

 Mercury,

 rrogate for non dioxin/ furan organic HAP (or, in the a lternative, organic HAP), T HC, a su

 HCl, and

 PM, a surrogate for nonvolatile metal HAP.

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

HAP are summarized in Exhibit 2.

Exhibit 2 Regulated HAP and Appropriate Add

­ On Control Devices

HAP Control Device Remova icienc l Eff y 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 (pre crubber) ceded by wet s 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 inject ion systems will remove mercury as well as THC and organic HAP. For purposes of thi s analysis it is assumed that a n activated carbon injection (ACI) system would include a pol ishing baghouse. Most cement ki ln dust (CKD) is recycled back to the kiln. As a result, A CI systems cannot be installed upstream of the main PM

control device because the additi onal carbon that would end up in the CKD would make the CKD unsuitable for recycling bac k 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 r esult 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 red uce emissions of SO 2

. In a few instances, it may be necessary to install a regenerati ve thermal oxidizer (RTO) for the control of THC or organic HA P. To avoid fouling, plugging, and corrosion of the RTO, it is assumed that an RTO would be p receded by a wet scrubber, whi ch is the case at a cement plants that currently uses an RTO . This plant continuously oper ates the RTO and scrubber.

The RTO that has been installed on a cement kiln in the U.S. ha s used a wet scrubber upstream and is considered necessary to prevent operational pro blems with the RTO. Installing an RTO (with its upstream wet scrubber) for THC or o rganic HAP control will

also reduce emissions of HCl and SO 2 and potentially mercury.Summary of Environmenta l and Cost Impacts of Final Amendments t o Portland Cement NESHAP

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

emissions for each kiln were com pared to the average emissions of the top performing kilns used to develop the MACT floor limit, and the percent red uction that would be needed to reach the average emission lev el was calculated. Being able to reduce emissions to the average emission level, rather t han the final emission limit wi ll guarantee that the kiln can comply with the final limits mos t or all of the time. Average e missions plus a variability

factor were used to establish the final MACT floor limit for ea ch HAP. (A detailed explanation of how the MACT floors for existing and new sources were derived is contained in a separate document in the do cket.) The average emissions of the MACT floor kilns, i.e., the top 12 percent of existing ki lns, and the average emission of the best performing kiln (MACT for new sources), along wi th the corresponding final emis sion 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)

Merc ur y 32.1 lb/MM tons

cl inker 55 lb/MM tons cli nker 14 lb/MM tons clin ker 21 lb/MM tons cli nker

THC 5 .2 ppm v d@7% O 2 24 ppm v d@7% O 2 4. 7 ppm v d@7% O 2 24 ppm v d@7% O 2 Orga nic

HAP 1.8 ppmvd@7% O 2 9 ppmvd@7% O 2 1.6 ppmvd@7% O 2 9 ppmvd@7% O 2

H Cl 0.41 ppm v d@7% O 2 2 ppm v d@7% O 2 0.34 ppm v d@7% O 2 2 ppm v d@7% O 2 PM  0.02 lb/ton clinker  0.04 lb/ton clinker 0.01 lb/ton clinker 0.0 1 lb/ton clinker

Because of the variety of the HA P to be controlled, it is assum ed that most kilns will require multiple controls to comply with all of the final limits. The n umber of kilns and the types of controls assumed in this analysi s are shown in Exhibit 4. These estimates are considered conservative and likely overstate the number and types of contr ols that will be installed.

Reasons for this include the ina bility to accurately estimate the number of kilns that will be able to comply using work practi ces such as material substituti on and wasting CKD. It is believed that many kilns may be able to reduce emissions by sub stituting lower‐mercury raw materials than they now use. Substitution for the principal raw material, limestone, is less likely than for the other a dditives. Limestone constitutes 75 to 80 percent of the raw

material used to make clinker an d most plants are located at th eir source of limestone for economic reasons. Purchasing limestone from other locations wou ld usually be too costly due to the cost of transportatio n. In addition, limestone quarr ies are owned by the cement plant or its parent company and would not be available to other cement plants with different ownership. Other non‐l imestone materials (e.g., clay, shale, sand, and iron ore or slag), however, are typically purchased from various offsite so urces and transported to the plant. Plants may have access to lower‐mercury materials, altho ugh the extent to which this

is feasible would have to be det ermined on a site‐specific basi s. Because mercury is also contained in CKD that is capture d in PM control devices, the pr actice of wasting CKD, that is not recycling the CKD to the kiln, can be used to reduce mercur y emissions. As with raw material substitution, the degree to which this practice can re duce mercury emissions canSummary of Environmenta l and Cost Impacts of Final Amendments t o Portland Cement NESHAP

5 only be determined using site‐sp ecific analyses. Other site‐spe cific 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). Scru bber‐controlled kilns must perfo rm an initial performance test for HCl using M ethod 321 and continuously moni tor scrubber operating

arameters. p

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

Con ice trol Dev HAP lled C o

ontr Total Number Each Control of

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 nonvola tile metal HAP) were estimated. Impacts were estimated from a baseline level, that i s, 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 s tandard. 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 soli d 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 b iased low due to a scrubbing effect in the front half of the sampling train (see 6 3 FR 14182), the HCl data measured at 21 kilns using Method 321 was used to calculate ann ual emissions. For kilns lacking site‐specific test data, an HCl emission factor was est imated from the available Method 321 test data. Average baseline emissions of HCl were es timated using an average stack  outlet concentration of 12 ppmvd at 7 percent O 2 . Annual emissions were calculated

as follows:

X ppmvd HCl/10 6 volume stack gas * 100,000 dscf/ton clinker * lbmole/ft 3 /(0.73)(528)

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

Annual nationwide baseline HCl e missions from all existing kilns total about 4,900 tpy.Summary of Environmenta l and Cost Impacts of Final Amendments t o Portland Cement NESHAP

6 For a new 1.2 million tpy kiln wi th HCl emissions at a concentr ation of 12 ppmvd, baseline HCl emissions would be 68 tpy. B aseline emissions for 16 new ki lns would be an estimated 1,100 tpy.

To estimate the reduction in emi ssions of HCl under the final s tandards, the number of

kilns that would add controls was estimated. It is estimated th at 29 of the existing kilns will not be subject to the final stan dards 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 standard s for HCl. An estimated 118 existing kilns would require scrubbers to meet the proposed HCl standards and 4 could meet the standard using dr y 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 fr om all new kilns would total about 1,100 tpy. Total

nationwide baseline emissions and emission reductions for HCl a re summarized in

Exhibit 5.

Exhibit 5 Nationwide Baseline Emissions and Emission Reductions

HAP Exis ting or new kilns Baselin e emissions Emissio n reductions

HCl Existing 4,907 t p y 4,755 tp y
New 1,110 tp y 1,101 tp y
THC Existing 12,16 tp 5 y 6,453 tp y
New 793 tp y 397 tp y Organic H AP Existing 4,364 tp y 3,433 tp y
New 433 tp y 346 tp y
Mer cur y Existing 15,942 lb/ y r 14,703 lb/ y r
New 2,096 lb/y r 1,886 lb/y r
P M Existing 10,32 p 6t y 9,489 tp y
New 2,165 tp y 1,990 tp y

As a co‐benefit of controlling HCl using wet scrubbers, emissio n of SO 2 will also be reduced.

Wet scrubbers used for HCl control will reduce SO 2 emission by 95 percent; dry lime injection by 70 percent. Uncontrolled SO 2 emissions vary by kiln type and location and emission factors for SO2 are pre sented in Exhibit 6. Uncontroll ed SO2 emission factors and scrubber and lime injection contr ol efficiencies were used to e stimate SO2 emission reductions resulting from the control of HCl. Total nationwide SO 2 reductions from existing kilns was estimated at 115,000 tp y. For a new 1.2 million tpy k iln equipped with a scrubber, SO 2 emissions reductions would be about 190 tpy or 18,000 tpy for 16 new kilns by 2013.

Exhibit 6 Uncontrolled SO 2 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 7.59Summary of Environmenta l and Cost Impacts of Final Amendments t o Portland Cement NESHAP

7 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 7.81Summary of Environmenta l and Cost Impacts of Final Amendments t o Portland Cement NESHAP

8 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 s urrogate for non dioxin/furan o rganic HAP. The specific organic compounds that will be m easured to determine compliance with the alternative to the THC limit are benzene, toluene, styrene, xylene (ortho‐, me ta‐, and para‐), acetaldehyde, formaldehyde, and naphthalene.  E missions stack tests, includin g both manual short‐term tests and long‐term continuous e missions monitoring data were u sed to estimate baseline THC and organic HAP emissions fo r each kiln with THC test data. To estimate emissions for the remaining kilns, an average THC emission factor was used th at was calculated from

available emissions test data. T he average concentration of org anic HAP in THC was 35 percent. For purposes of this analysis, the emission factor exc ludes emissions data from a kiln already controlled using an RTO, as well as from 5 kilns w ith THC emissions that were uncharacteristically high and no t typical of THC emissions from other kilns for which we

had data. The emission factor us ed in this analysis for kilns f or which data were not available is 21.4 ppmv at 7 percent O 2 . Annual emissions for a preheater or precalciner kiln

were calculated as follows:

X ppmv THC/10 6 volume stack gas * 100,000 dscf/ton clinker * lbmole/ft 3 /(0.73)(528)

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

Nationwide baseline THC emission s 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 em issions from a new 1.2 millio n 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 tha t would need to reduce emission s by adding controls was estimated. ACI systems would reduce THC emissions by an estimat ed 50 percent and organic HAP emissions by 80 perc ent.   For any kiln requiring h igher removal efficiencies, an RTO preceded by a wet scrubbe r would be used with a removal efficiency of 98 percent. It is already assumed that to co mply with the mercury limits, m ost kilns will install ACI systems. As a result of controls added for mercury, THC and org anic HAP will also be

controlled without additional c ontrols.  An estimated 10 kilns would require an RTO preceded by a scrubber; for all ot her kilns, ACI systems instal led to control mercury

emissions are sufficient to cont rol THC and organic HAP emissio ns.

Total nationwide THC emission red uctions from existing kilns wo uld be an estimated 6,000 tpy. The emission reduction in THC for each new kiln was estima ted at 90 tpy or 400 tpySummary of Environmenta l and Cost Impacts of Final Amendments t o Portland Cement NESHAP

9 

### 2.3.3 Mercury

Stack test emissions data are typ ically used to estimate baseli ne emissions and emission reductions. However, given that mercury emissions are largely d etermined 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 mer cury stack test data (typically a few hours) are not necessarily indicative of long term emissions performance.

An alternative to short term sta ck test data would be to use me rcury continuous monitoring data over a longer ti me period. However, no cement k ilns have continuous mercury monitors, so this option was not available. Because mer cury is an element, and can neither be created nor destroyed in a cement kiln, all the merc ury that enters a kiln has to leave the kiln as a stack emission with the following exception s: 1) mercury removed by cement kiln dust (CKD) captured in a PM control device where th e CKD is wasted (i.e., not recycled to the kiln), and 2) me rcury captured in a wet scrubbe r (used to control SO 2 emissions) where the mercury en ds up in the gypsum produced fro m the de‐watered scrubber slurry. The available da ta indicate that almost no mer cury leaves the kiln as part

of the clinker. Based on these f acts, EPA determined the most accurate method available to determine long term mercury emis sion performance was to obtain data on all the kiln mercury inputs for 30 days from a large group of kilns and assu me 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 ra w material, fuel, and CKD for 89 kilns, along with annual mass inputs and CKD wastage. These data were submitted as daily concentrations for the inp uts, i.e. samples were taken an d analyzed daily for mercury content. Using the daily average s, a mean concentration was cal culated and multiplied by

annual materials use to calculat e an annual mercury emission. I f the facility wasted CKD, the annual mercury that left the system in the CKD was subtract ed out. If the facility had a wet scrubber, the average mercury removal efficiency was estima ted 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 f actor in pounds of mercury emitted per million tons of clink er produced (lb/MM tons clinke r). For the kilns for which feed and fuel mercury content was not collected, a mercury emis sion 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 b y the end of 2013. Total nationw ide baseline emissions and

emission reductions of THC as we ll as new kiln emission reducti ons are summarized in

Exhibit 5.

Total nationwide organic HAP emi ssion 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 20 13. Total nationwide

baseline emissions and emission r eductions of organic HAP as we ll 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, SO 2 emissions would also be reduced. Total nationwide SO 2 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 Environmenta l and Cost Impacts of Final Amendments t o Portland Cement NESHAP

10 

### 2.3.4 Particulate Matter

Total particulate matter (PM) emissions are being used as a sur rogate 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 dat a were converted to total PM filterable emissions assuming that an average of 85 p ercent of total PM emissions is PM10 filterable. Baseline data and multiplied by each kiln’ s clinker production to estima te 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 nati onwide baseline emissions fro m existing kilns were estimated at 16,000 lb/yr. For a new 1.2 MM ton/yr kiln, mercur y emissions would be about 130 lb/yr using an emission factor of 111 lb/MM tons clin ker; 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 contro ls added to remove mercury from kiln exhaust gases, or, 2) as a result of controls added t o remove other HAP. Available controls for mercury considered in this analysis include ACI an d wet scrubbers. ACI would a higher removal efficiency for m ercury 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 le ss costly and has a higher remo val efficiency, it was assumed that ACI would be selected over wet scrubbers. Although it was assumed that

most kilns would also add wet sc rubbers for HCl control, it was not assumed that the efficiency of the two controls w ould be additive (with the exce ption of two kilns). For purposes of this analysis, when a kiln would be equipped with b oth ACI and a wet scrubber, only the efficiency of the ACI system was applied. This is reas onable as the reduced mercury concentration in the exhaust gases of the ACI system ma ke it unlikely that a scrubber could still achieve an 80 percent reduction. Furthermo re, most of the mercury in the oxidized state would have been removed by the ACI system an d the remaining elemental mercury in the exhaust stream would not be captured b y 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 pe rcent and that the scrubber fo llowing the ACI system would get an additional 80 percent control. For a few kilns, th e need to install an RTO  with its precleaning scrubber for THC or organic HAP control would n egate the need for an additional ACI system for mercury. Total nationwide emissions r eductions of mercury from existing kilns were estimated at 15,000 lb/yr. Emission reducti ons 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. N ationwide baseline emission a nd emission reductions as

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

Emissions of SO 2 would also be reduced where wet scrubbers are installed for th e control of mercury. In this analysis, on ly two kilns installed scrubber s for mercury, which was done in combination with ACI to get a higher mercury removal efficie ncy. Emissions of SO 2 would be reduced by about 1,400 tpy.Summary of Environmenta l and Cost Impacts of Final Amendments t o Portland Cement NESHAP

11 emissions already account for the existing PM control devices i n use. Using clinker production for each kiln, a PM e mission 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 bas eline emissions of PM for exis ting kilns were estimated at 10,000 tpy. At 0.34 lb PM/ton of c linker, PM emissions from a n ew 1.2 million tpy kiln would be about 200 tpy; emissions from the 16 new kilns would b e 2,000 tpy.

For this analysis, it was assumed that the required reductions in PM emissions would be accomplished by either replacemen t of existing standard fabric bags with membrane bags or replacement of existing ESP’s that are not meeting the targe t PM level with a baghouse with membrane bags. Another scenario that would adequately redu ce PM emissions occurs when an ACI system (for THC/orga nic HAP or mercury control), in cluding a polishing baghouse, is installed in series w ith an existing PM control de vice. 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 perf orming kilns (0.02 lb/ton clinker) in order to assure compliance with the proposed PM emi ssion 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 kiln s, 0.01 lb/ton clinker, the reduction in PM emissions from a new kiln would be about 200 tp y and about 2,000 tpy for

all new kilns. Baseline emissions and emission reductions for e xisting and new kilns are

summarized in Exhibit 5.



### 2.3.5 Secondary Impacts

Secondary air quality impacts wo uld result from the increased e lectrical and fuel demands of control equipment required to comply with the proposed amend ments. The addition of add‐on controls, such as scrubbe rs and RTO’s, will increase ele ctricity and natural gas demands. The secondary impacts in this analysis include the imp acts of additional electricity and natural gas cons umption and the pollution assoc iated with the generation of the electricity and the combusti on 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 usi ng EPA Cost Manual) 30.9 kwh/DSC FM RTO natural gas demand (calculated using EPA Cost Manual) 0.73 M MBtu/DSCF M ACI power demand w/polishing bag house (Docket item II‐B‐67, Doc ke t A‐92‐53) 6 kwh/ton clink er
S crubber makeup water (Andover 2 /26/2010, p. 4) 60 gal/ton clink er Solid waste generated from ACI ( Docket item II‐B‐67, Docket A‐9 2‐53) 3 lb/ton clinker

The following emission factors were used to estimate increased emissions of NO
x , CO, SO 2 , PM 10 , and CO 2 from the increased electricity and natural gas demand (Docket item IV‐B‐25,

cket A 94‐ Do

‐ 52):

NO

x NO

x CO ‐

‐

‐ 0.00446 lb/kWhr 0.1 lb/MMBtu natu 0.00231 lb/kWhr ral gasSummary of Environmenta l and Cost Impacts of Final Amendments t o Portland Cement NESHAP

12 SO 2

1 ‐ 0.00765 lb/k Whr

PM

O 2 0 ‐

‐ 2.25(10‐4) lb/kWhr 2.1 lb/kWhr C

CO 2 ‐  117 lb/MMBtu natural gas (EIA – Natural Gas Issues and Trends, 1998)

Increases in secondary emissions resulting from the increased e lectrical demand of an alkaline scrubber and ACI, and the increased electrical and nat ural 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

electric emand ity d (MMkwh/yr) Lime injection electricity

de (MMkwh/hr) mand RTO electricity

dem nd a wh (MMk /yr) RTO natural gas demand MMBtu/yr ( ) ACI electricity

de d

man (MMkwh/ yr) Total electricity

de mand (MMkwh/ yr) Existing k il ns 2 21 0 .1 4 4 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

NO x (tpy) CO (tpy ) SO 2 (tpy) PM 1 py) 0 (t CO2 (tpy) Make ater

­ up w (M r)

Mg l/y

a A CI ste solid wa (tpy)
Existing k il ns 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 consumpt ion of water (for makeup water and production of the scru bber slurry). Additional makeup water demands for scrubbers are estimated to be 60 gal/ton of clinker (Andover 20 10). Total additional makeup water for existing kilns would be an estimated 4.4 billi on 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 c onsumption in 2013 would be 5.6 billion gal/yr. No water quality impacts are associated w ith the use of baghouse, RTO or ACI systems.



### 2.5 Solid Waste Impacts

Additional solids would be gener ated as a result of the addition of scrubbers. However, the

waste from the scrubber contains synthetic gypsum and is typica lly dewatered and returned to the process where it is mixed with clinker in the f inish 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 sys tems. An estimated 3 lb solid waste per ton of clinker would b e generated (Docket item II‐B‐6 7, 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 Environmenta l and Cost Impacts of Final Amendments t o 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 s tandards. The approach used to determine the type of control needed was described earl ier. In summary, based on

a kiln’s baseline emissions of m ercury, THC, HCl, and PM, and t he removal efficiency necessary to comply with the fin al emission limit for each HAP, an appropriate control device was identified. In assignin g control devices to kilns wh ere more than one control device was considered appropriat e, it was assumed that the leas t costly control would be installed. For example, if a kil n could use a scrubber or ACI t o meet the final mercury limit,

it was assumed that ACI would be selected over a scrubber becau se 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 mo re expensive technology was considered appropriate because the selected control reduced emissions of multiple pollutants. For example, even tho ugh ACI would be less costly t han a scrubber for controlling mercury, if the kiln also needed to reduce HCl emis sions, it was assumed that a scrubber would be applied to control HCl as well as mercury bec ause ACI would not control HCl. However, for many kilns, this analysis assumes that multip le 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. F or the same kiln, a scrubber would also be required to reduce HCl emissions. This approa ch and the resulting cost esti mates are considered very conservative in that it is not p ossible to consider what other alternatives, in lieu of multiple add‐on controls, may be availabl e to cement plants to comply wi th the final emission limits. Because individual cement manufacturing plants may implement pr ocess or other changes to reduce emissions, the costs o f the final amendments likely o verstate the costs that actually will be incurred by ind ividual cement plants. For exam ple, some plants may be able to reduce mercury emissions by substituting raw materials havin g 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 prac tices at cement plants would

have to be determined on a site‐ specific basis and cannot be as sumed to be applicable at all cement plants. In addition to th e costs associated with add‐on controls, the final standard also requires continuous monitor ing to ensure compliance with t he emission limits. For this analysis, it was assumed that the cost of continuous monit oring for mercury, THC, HCl (except where controlled by a scrubber), and PM would be incurr ed for each kiln. Kilns The additional solid waste gener ated from baghouses in the form of CKD is typically considered product and is return ed to the kiln or mixed with th e cement. No solid waste impacts are anticipated with the use of an RTO system.



### 2.6 Energy Impacts

Additional electricity demand wo uld result from the addition of scrubbers, RTO’s, and ACI on existing and new kilns. A su mmary of the total additional en ergy demand for existing and new kilns is presented in Ex hibit 8. Total electricity dema nd 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 Environmenta l and Cost Impacts of Final Amendments t o Portland Cement NESHAP

14 controlled by a scrubber would co nduct an initial and periodic Method 321 test for HCl. The total cost of compliance for eac h kiln includes the cost of mon itoring.



### 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 c osts that are primarily a function of the type of kiln (we t, 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.; consequen tly, the cost algorithms could be used to develop site‐specific

estimates of scrubber costs.

Comments on the gas flowrate and the capital cost estimating ap proach used for proposal underestimated kiln gas flowrates and kiln capital costs. As a result, the approach for estimating gas flowrates and cap ital cost estimates for wet scr ubbers 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 volumetri c flowrate for each kiln, the c apital cost (CC in 2005 dollars) for each kiln is calcula ted from (Andover, 2008a; Ando ver, 2010a; Barnett, Laney,

20 10):

CC =  14,398 ( DSCFM ) 0.6

Fixed costs (FC) include labor ( operating, supervisory, and mai ntenance), maintenance ma eplace , t xes, insurance, etc. and were e stimated from (Andover,

200 terials, r ment parts a

8a):

FC =  38  * TPY 0.6 +  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):

000844  * TPY * COSTKWH )  +  (‐0.041  * TPY * SO 2 )  +  ( TPY *  0.025) VC = (0.

W

OS

here:

TKWH C = $0.0724/kWhr, and

SO 2 =  lb SO 2 per ton of clinker, from Exhibit 6.

Total annualized cost (TAC) includes fixed annual costs, variab le 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 wor k by Andover (2008a, 009, 2010). Capital costs were estimated as: T

2Summary of Environmenta l and Cost Impacts of Final Amendments t o Portland Cement NESHAP

15 CC =  44 * TPY 0.6

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

st F

e imated as follows:

C =  $59,200 + 0.04  * CC F

ar t is the cost of lim e plus power and is estimated u sing the following: V iable cos

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

Where:

TKWH COS = $0.0724/kWhr, and

SO 2 =  lb SO 2 per ton of clinker, from Exhibit 6.

Total annualized cost (TAC) includes fixed annual costs, variab le annual costs, and capital recovery (based on a 7 percent interest rate, 20‐year lifetime, and a capital recovery factor

of 0.0944 AC from: ). T  is estimated

TAC = FC + VC +  0.0944  * CC



### 2.7.3 Activated Carbon Injection

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

and THC emissions from cement ki lns were estimated using costs that were originally developed for electric utility b oilers.  Following proposal, AC I 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, con trol costs for electric

utilities were scaled to derive control costs for Portland ceme nt kilns. Two electric utility boiler units of different capaci ties and exhaust gas airflows t hat were comparable to exhaust gas flow rates for cemen t kilns were used. Capital and annual cost factors ($/ton of clinker) were developed using the boiler costs and gas flow dat a 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 use d to calculate the total capital

and total annualized costs are d escribed previously (Docket ite m OAR‐2002‐0051‐1891).



### 2.7.4 Regenerative Thermal Oxidizers

Costs for an RTO are based on co sts of an RTO installed and cur rently 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 t he operating RTO was scaled based on exhaust gas flow rates for each existing kiln and the model new kiln. Input parameters and annual cost input s used in estimating costs are shown in Exhibit 10. The capital and annual cost for this kiln are shown in Exhibit 11.Summary of Environmenta l and Cost Impacts of Final Amendments t o 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 variabl e costs as follows:



### 2.7.4 Baghouses and Membrane Bags

The costs of a reverse air baghouse and standard fabric bags we re 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 ba ghouse using standard fabric ba gs 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 rat es, the following cost functions were used to estimate total capital costs (TCI std ) and total annual cost (TAC std ) for a baghouse with standard fabric bags:

Exhibit 10 RTO Input Parameters

16 Input Parameters Gas flow rate (sc f m) 502,312 Reference temperature (° F ) 77 Inlet gas temperature (°F) 150 Inlet gas dens ity (lb/scf) 0.0739 Primary heat recovery (fraction) 0.95 Waste gas heat content (Btu/s cf) 5 17.00 Waste gas heat content (Btu/lb ) 6995.83 Gas heat capacity (B tu/lb‐°F) 0 .255 Combustion temperat ure (°F) 1 500 Heat loss (fraction) 0.01 Exit temperature (°F) 218 Fuel heat of combustion (Bt u/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 ($/hr) 1 2.96 Maintenance labor rate ($/hr) 1 4.26 Operating labor factor (hr /sh) 0.50 Maintenance labor factor (hr/w k) 1.00 Electricity price ($/kWh) 0 .050 Natural gas price ($/1000scf) 9.30Summary of Environmenta l and Cost Impacts of Final Amendments t o Portland Cement NESHAP

Annual interest rate (fra ctio n) 0.07 Control system life (years) 15 Capital recovery factor 0.1098

T axes, insurance, admin . factor 0.04 Pressure drop (in. w.c.) 20.0

The costs of a reverse air bagho use and membrane bags were calc ulated 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 c ostly 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 milli on capital cost, and $230,000 an nual cost. To scale these

costs for kilns with different e xhaust gas flow rates, the foll owing cost functions were used to estimate total capital costs (TCI mb ) and total annual cost (TAC mb ) for a baghouse with membrane bags:

T

AC MB =  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% o f PEC) 1,280,000 Enclosure building 0 Site preparation (1 5% of PEC) 2,400,000

Total dire ct installation (DI C) 3 ,680,000

TOTAL DIRE CT COST (DC) 1 9,680,000

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

Maintenanc e labor 742

Maintenan c e materials 742 Natural gas 3,392, 81 6

Electricit y 776,956 Overhead (0.6 of labor and maint enance materials) 5,316

T axes, insurance, administrative 1 ,011,200

C apital recover y 2 ,775,608Summary of Environmenta l and Cost Impacts of Final Amendments t o Portland Cement NESHAP

18 TOTAL ANNUAL COST 7,970,758

For purposes of this analysis, if an existing baghouse needed t o increase efficiency to comply with the final PM emission limit, it was assumed that st andard fabric bags would be replaced with membrane bags. The incremental costs between a ba ghouse with standard bags and a baghouse with membrane bags was used to estimate the additional cost of replacing standard bags with mem brane bags. Where it was considered necessary to replace an existing ESP with a b aghouse, it was assumed that th e cost would be that of a baghouse with membrane bags. If the existing PM control was a f abric filter and an ACI is assumed be added for other HAP, t hen the kiln would be equipped with two baghouses in

series and no additional PM cont rol was assumed to be necessary . If the existing PM control was an ESP and the plant would a dd 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 co ntrol PM (e.g., ACI), then it was assumed that the ESP would be replaced with a baghous e 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 Control a AC I System Added for Mercury or THC b Add itional Control Needed

for PM Baghouse Yes None Bagh ouse 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 belo w 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 o f an ACI system. Monitoring costs were based on t he 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 derive d from the CEMS Cost Model and include a capital recovery factor of 0.1424 (equipmen t 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 f inal HCl emission standards wer e estimated as the costs of installing and operating add‐on control equipment and the cost of installing and operating continuous emission monitoring eq uipment. Only kilns that are m ajor 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 s ubject to the HCl standards. It was assumed that wet scrubbers or dry lime inject ion systems would beSummary of Environmenta l and Cost Impacts of Final Amendments t o Portland Cement NESHAP

19 installed to control HCl emission s. Kilns identified as area so urces from EPA’s NEI and kilns that, based on test data, will co mply with the final limit with out further control, were

assumed to not add a scrubber fo r 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 app roximately $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 annua lized costs for existing and ne w kilns are presented in

Exhibit 13.

Exhibit 13 Capital and Annualized Cost for Existing and New Kilns

HAP Exis ting or new kilns Capita l Cost Annualize d Cost

HCl Existing $ 1,582 millio n $ 220 million/y r
New $ 324 million $ 48 million/yr THC (Org anic HAP) Existing $ 277 million $ 57 million/yr

New $ 2.2 million $ 0.7 million/yr

Mer cur y E x i s t i n g $ 277 millio n $ 91 million/yr

New $ 62 million $ 22 million/yr

PM Existi ng $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 e stimated 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 HA P limits without any additional controls although these kilns may install ACI or scrubbe r for mercury control. All kiln s would be required to continuously monitor THC emissions. The capital cost for THC CE MS 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 estimat ed at $277 million with annualized costs of $56 million per year.

Of the estimated 16 new kilns ex pected to come on line, it is e stimated that all  will comply by installing an ACI system to comply with the final limits. Th e 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 annual ized 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 es timated as the cost of installing and operating add‐on control equipment and the cost of installing and operating CEMS for mercury. All but 15 kiln s would incur costs to control mercury emissions.  It was estimated that 123 kilns would install ACI systems and that 2 k ilns, because of higher than average mercury emissions, would install both ACI and wet scrubbers for mercury control.Summary of Environmenta l and Cost Impacts of Final Amendments t o Portland Cement NESHAP

20 Total nationwide capital cost was estimated at $277 million; to tal nationwide annualized cost was estimated at $91 million per year.

Assuming that a new kiln would i nstall ACI for mercury control, a new 1.2 million tpy kiln would incur a capital cost of $3 .2 million and an annualized co st of $1.1 million per year. Capital and annualized costs for existing and new kilns are pre sented in Exhibit 13.



### 2.7.9 Cost of Control for Particulate Matter

It was estimated that existing b aghouses on 25 kilns would be r etrofitted to replace standard fabric filters with membrane bags. Total nationwide ca pital cost for controls and monitoring for existing kilns was estimated at $54 million with annualized cost of $15 million per year. These costs inc lude the addition of PM CEMS.

Additional costs for new kilns w ould be incurred under the fina l amendments assuming that membrane bags rather than standard fabric bags would be in stalled 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 annuali zed costs for existing and new kilns are presented in Exhibit 13.



### 2.8 Summary of Impacts

Nationwide impacts in the  yea r 2013 f are summarized in Exhibi t 14. The costs include the

osts that will be incurred by e xisting 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 C ost Annualized Cost Emissions Reducti on Existing K ilns
Mercury $277 million $91 mil lion/yr 14,703 lb/yr mercury 1,387 tpy SO2 THC (Organic HAP) $277 million $57m illion/yr 3,433 tpy organ ic HAP 6,453tpy THC 11,158 typ SO2

HCl $1,582 mill ion $220mil lion/y r 4,755 tpy HCl

O2 102,669 tpy S PM (Metal HAP ) $54 million $15 m illion/yr 95 tpy metal HA P 9,489 tpy PM Total Existing $2.19 billion $ 382.4 million/yr HAP 8,290 tpy* All 135,918 tpy

New Kiln s
Total New $391 million $72.4 million 1,886 lb/yr H g ic HAP 346 tpy organ 397 tpy THC 1,101 tpy HCl

,990 tpy PM 1 17,704 tpy SO2

HAP 1,468 tpy* All 21,193 tpy Total, Year 2013 $2.58 billion $455 million/yr HAP 9,758 tp y All 157,111 tpySummary of Environmenta l and Cost Impacts of Final Amendments t o Portland Cement NESHAP

21 *Assumed that metal HAP is 1% of PM.



## 3 References

Andover, 2008a. Memorandum. J. Sta udt, Andover Technology Partners, Costs and Performance of Controls, prepare d for EPA, September 23, 2008.

Andover, 2008b. Memorandum. J. Sta udt, Andover Technology Partn ers, NOx, SO2 and CO2

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

Andover, 2009.  Memorandum. J. St audt, Andover Technology Partn ers, Costs and

Performance of Controls – revise d from comments, prepared for E PA, March 10, 2009.

Andover, 2010a.  Memorandum. J. St audt, Andover Technology Part ners, Wet Scrubber Cost Algorithm, prepared f or EPA, February 26, 2010.

or Andover, 2010b.  Memorandum. J. St audt, Andover Technology Part ners, Electrical Load f Wet Scrubbers, prepared for EPA, May 6, 2010.

Barnett, K. and M. Laney, 2010. M emorandum. Capital Costs for W et Scrubbers, August 6,

2010.

CEMS Cost Model. July 2006.

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

Laney, M., D. Green and K Barne tt 2006. Summary of Environmental and Cost Impacts of Final Amendments to Portland Cement NESHAP, December 8, 2006, D ocket item EPA‐HQ‐

OAR‐2002‐0051‐1891.

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

Cement Association. 200 8. 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 Quali ty Planning and Standards.

PA Air Pollution Control Cost Manual, Sixth Edition, EPA/452/B ‐02‐001. January 2002. E

## 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 (NO

x ) ............................................................................................. 5

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

2.2.3 Sulfur Dioxide (SO 2 ) ................................................................................................. 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 NO

x Emissions ........................................................................................................ 11

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

2.6.3 SO 2 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 NO

x Reductions from Kilns ............................................................ 7

3 Options Considered for PM Reductions from Kilns [DELETE]

........ Error! Bookmark not

defined.

3 Options Considered for SO 2 Reductions for Kilns with High-Sulfur Inputs

................ Error!

Bookmark not defined.

4 Options Considered for SO 2 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 NO

x Emission Limits for 1,200,000 tpy Kiln .................. 11

9 Wet Alkaline Scrubber Input Parame ters for New Kiln Model [DELETE]

................. Error!

Bookmark not defined.

10 Wet Alkaline Scrubber Capital and A nnual 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.

iiiii 13 Costs of SO 2 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 Environmenta l 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 N SPS 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 reconstr ucted affected facilities at PCP to achieve emission levels that reflect the best demonstrated system of con tinuous emission reduction, co nsidering cost, non-air quality health, environmental, and energy impact s. 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 w ith 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, in cluding an overview of the final amendments resulting in impacts and the methodology used to develop the impact estimates.



## 2 Subpart F Impacts Estimated fo r 2010 Promulgation of NSPS

Review

2.1 Affected Industry and Final Changes to Subpart F

The Portland cement manufacturing industry is co mprised of an estimated 100 cement plants capable of producing clinker and operating a total of approximately 140 kilns (PCA, 2008). Based on industry capacity expansio n estimates (PCA, 2009), it is proj ected 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 ki lns. Impacts are also estimated for the year 2013, in which it is assu med that 7 new kilns will have been built.

The current subpart F NSPS review is schedule d to be promulgated in 2010. The impacts of

concern for the NSPS review are incremental im pacts, specifically, the difference in impacts

associated with the current NSPS and the im pacts 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 applic ation of the current NSPS. The incremental impacts of the 2010 NSPS review are determined by comparison to th e baseline impacts. Changes in requirements being proposed as part of the 2010 NSPS review that could result in si gnificant incremental impacts include those su mmarized in Exhibit 1.

4Exhibit 1 Summary of Final Changes to Subpa rt 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 NO

x limit of 1.5 lb NO

x /ton clinker. Costs to install SNCR. Emission

reductions are also estimated.

▪ Addition of a SO 2 limit of 0.4 lb SO 2 /ton clinker, or 90% reduction of

SO 2 across the control device. Because amendments to the NESHAP for portland cement will re quire 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 NO

x monitors on new kilns. Capital costs of installation and annual costs of operation.

▪ Addition of continuous SO 2 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 fina l amendments to the NSPS for Portland cement manufacturing were calculated us ing 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 memb rane bags rather than fabric bags;

• SNCR will be installed on a ll new kilns to control NO

x emissions;

• NO

x monitors will be installed to mon itor emissions from all new kilns;

• SO 2 monitors will be insta lled 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 (NO

x 

### )

EPA recently issued an alternat ive control techniques (ACT) document addressing the emissions

and control of NO

x from new cement kilns (EPA, 2007). Un less noted otherwise, this document

is the source of the information on NO

x emissions and controls presented here.

The high temperatures and oxi dizing atmospheres required for cement manufacturing are

favorable for NO

x formation. In cement kilns, NO

x emissions are formed during fuel combustion primarily by the oxidation of molecular nitrogen present in com bustion air (referred to as thermal

5NO

x ) and the oxidation of nitrogen compounds in fuel (referred to as fuel NO

x ). Many states issuing construction and operating permits for ne w kilns have specified emission limits for NO

x . In recently built kilns, emissions of NO

x are typically reduced through process controls such as burner design and staged combustion in the calciner (SCC). NO

x emissions from kilns using process designs such as low NO

x burners and SCC average about 2.5 lb/ton of clinker (EPA, 2007). This level of uncontrolled NO

x emissions was supported by ad ditional 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 NO

x emissions include selective noncatalytic reduction (SNCR) a nd selective catalytic reducti on (SCR). In recent new source review procedures, states have determined be st available control t echnology (BACT) to be SNCR in addition to well-designed SCC a nd other process designs such as low NO

x burners. In SNCR systems, ammonia, urea or another reagent is injected into the flue-gas in an appropriate temperature zone and at an appr opriate ratio of ammonia to NO

x . On average, SNCR achieves approximately a 35 percent reduction in NO

x at a ratio of ammonia-to-NO

x of about 0.5 and a reduction of 63 percent at an ammonia-to-NO

x ratio of 1.0. Additional information submitted following proposal (see the response-to-comme nt document in the docket) showed SNCR removal efficiencies ranging from 25 percent (n o ammonia molar ratio give n) 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

NO

x and will be emitted (ammonia slip). Another NO

x control technology, SCR, is used in the electric utility industry to reduce NO

x emissions from boilers and, to date has been used worldwide on three cement kilns. SCR is capable of reducing NO

x emission by about 80 percent. Currently, SCR is not used on any cement kilns in the U.S. although a cement manufacturer is currently a consent decree to install SCR on one kiln.

Four options were evaluated for control of NO

x emissions. The first option was to maintain the

baseline of no limit and no additional control. Th e other three options are given in terms of pounds of NO

x per ton of clinker (lb/t on clinker). The three options evaluated were 1.95 lb/ton clinker, 1.5 lb/ton clinker, and 0.5 lb/ton clinker.

In choosing these NO

x emission limit options, recently issued permits, recent BACT determinations and recent emissions data for preh eater/precalciner kilns we re reviewed. At three recently permitted preheater/precalciner kilns utilizing well designed and operated process designs including SCC, average NO

x emissions of 1.62, 1.88 and 1.97 lb/ton of clinker were measured for Titan America-Pennsuco, in Medley, FL, Little Giant Cement in Harleyville, SC, and CEMEX in Santa Cruz, CA (Bahner, 2008a). These kilns are not eq uipped with additional add-on controls. However, based on data from eq uipment vendors and other facilities with more difficult to burn raw materials, we believe that future well-designed and operated cement kilns, which will incorporate SCC and low NO

x burners, will meet a level of 2.5 lb/ton of clinker on average. This level is the baseline level of cont rol that would occur with no additional regulatory

action.

The second control evaluated was 1.95 lb/ton clinker, which is a common level established as BACT in recent permits for new sources (Bahner, 2007). As previously noted, some new facilities meet this level of control using low NO

x burners and SCC. However, we expect that, on

6average, new facilities would require a NO

x removal efficiency of 22 pe rcent to meet this level,

which is well within the ra nge demonstrated for SNCR.

The third control level evalua ted was 1.5 lb/ton clinker, and was established based on our assessment of the best demonstrated performa nce of SNCR. Data on SN CR show a performance that ranges from approximately 20 to 90 percent NO

x reduction. We estimate that about 50 percent NO

x emission reductions represents a reasonabl e level of performan ce of SNCR over the long term. Though new kilns on average will have em issions of 2.5 lb/ton prio r to the application of add-on controls, there may be some situatio ns where specific raw materials properties will result in higher NO

x emissions. For this reason we assumed a maximum baseline of 3.0 lb/ton and 50 percent emission reduction by SNCR to establ ish a 1.5 lb/ton control level. Data available for Suwannee American Cement Company, which operates with SNCR, i ndicated an average

NO X value of 1.44 lb/ton, and a calculated 99 th percentile 30-day ro lling 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 k ilns in the United States, so SCR currently is

not demonstrated in the U.S.

Exhibit 2 shows the annual NO

x reductions achieved for each op tion, for a single kiln producing 1,200,000 tons per year (tpy) of clinker, and na tionwide for 7 kilns, based on the projected clinker capacity for each new kiln. Emissions reductions are presented both cumulatively from the baseline and incrementally comp ared 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 d ecreases 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 pr esents 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 re duction 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 NO

x 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 ne w source limit contained in the Hazardous Waste Combustor (HWC) NESHAP for cement kilns burni ng hazardous waste. This rationale is no longer applicable, since EPA is reassessing th e 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 a nd 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 me mbrane 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 ne w 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 justifie d, 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 w ill be accomplished by baghouses and membrane bags installed for PM (as a surrogate for nonvol atile 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 envi ronmental and cost impacts for the NESHAP.



### 2.2.3 Sulfur Dioxide (SO 2 

### )

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

Sulfur dioxide from a cement kiln comes from th e oxidation of sulfur from two sources. The first is sulfur in the fuel, which mixes with lime in the kiln and preheater with little or no SO 2 emitted into the atmosphere from this source. The other source of SO 2 is the raw materi als, which may be

oxidized to SO 2 in the kiln system when mixed with sufficient oxygen.

For most Portland cement plants, the levels of su lfur in raw materials are sufficiently low and

most of the SO 2 generated is removed by the natural sc rubbing action of the kiln raw feed. In

instances where the sulfur content of raw materials is higher, uncontrolled SO 2 emissions can be significant. In those situations, add-on c ontrols may be necessary to prevent high SO 2 emissions.

8The first type of SO 2 control equipment considered is al kaline scrubbers. They are capable of achieving a 90 to 95 percent reduction in SO 2 emissions on cement kilns (Bahner and Laney, 2008). The difference between SO 2 emissions before and after the scrubber at the Lehigh Cement plant in Davenport, Iowa was approximately 96 percent (Bahner, 2008c; Bahner and Laney, 2008).

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

Four options were evaluated for control of SO 2 emissions for proposal. The first option was to

maintain the baseline of no SO 2 emission limit. The other three op tions 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 effectiven ess 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 lik ely that all new kilns will have to install a we t 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 SO 2 emissions under the NSPS will be accomplished by wet scrubbers installed for HCl control under the NESHAP so that no imp acts 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 ceme nt 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 an alysis. 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 mech anism as the THC emissions. Unburned fuel represents an economic loss to the facility. Therefore, new precal ciners are designed to combust fuel as efficiently as possible, and CO emissi ons from fuel combustion are minimized, regardless of any potential emission limit.

9Emissions of CO evolved from raw materials can be significant if there are substantial levels of organics in the raw material. As noted at pr oposal, the only control t echnology identified that reduces CO emissions is an RTO (which also would concurrently reduce any VOC emissions). However, we believe application of an RTO as BD T for CO would result in significant cost and adverse energy impacts. Therefore, it was de termined that no additi onal 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 unde r new source review.



### 2.2.5 Secondary Impacts

Secondary air quality impacts result from the in creased 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 ne gligible. 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 c ontrol 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 wi ll result in increased consump tion 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 scr ubbers 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 envi ronmental and cost impacts



### 2.4 Solid Waste Impacts

There are no solid waste impacts under the final NSPS. The slurry th at 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 retu rned 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 so lid 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 ar e negligible. The use of alkaline scrubbers on new kilns will increase electricity consum ption, although the increase in demand is not attributable to the NSPS. There are no significan t energy impacts associated with the final NSPS.

10

### 2.6 Cost Impacts

2.6.1 NO

x 

### Emissions

Four options were evaluated for control of NO

x emissions. The first option was to maintain the

baseline of no NOx limits. The other three options are given in terms of pounds of NO

x per ton of clinker (lb/ton clinker). Th e three options evaluated were 1.95 lb/ton cli nker, 1.5 lb/ton clinker, and 0.5 lb/ton clinker.

Costs were evaluated for all four options. Costs for SNCR and SCR were derived from Alternative Control Techniques Document Update – NO

x Emissions from New Cement Kilns (EPA, 2007). Capital costs for SNCR systems ranged from $0.78 to $2.88 per ton of clinker produced. An average of $1.76 per ton of clinker was used to estimate cap ital costs. For the 1.95

lb/ton NO

x 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 hi gher 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

NO

x /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 clin ker was used to estimate annual operating costs

for SCR.

The results of this analysis showed that the ov erall annualized cost of control for both the 1.95 and the 1.5 levels were approximately $2,000 per ton of NO

x reduction. Given the similarity of costs, Option 3 (1.5 lb/ton c linker) was chosen as BDT.

Assuming a kiln with a clinke r capacity of 1,200,000 tons, the capit al cost of the SNCR is $2,112,000 and the annual operating cost is $1,212,000.

Under the final amendments, complian ce with the emission limits for NO

x will be determined using continuous emissions monitoring systems. Continuous flow rate monitors will also be required to determine compliance. The capital/startup costs for NO

x and flow rate CEMS are $140,951 and $35,780, respectively. Annual operati ons and maintenance costs for NO

x and flow rate CEMS are $41,809 and $13,864, respectively. All costs are derived from the CEMS Cost Model and include a capital reco very factor of 0.1424 (equipment life of 10 years and a yearly interest rate of 7%). Attach ment 2 is the output file from the CEMS Cost Model for NO

x CEMS. Attachment 3 is the output file from th e CEMS cost Model for flow rate CEMS.

Including the cost of CEMS, the annual opera ting and maintenance cost per kiln is $1,267,673 and the total capital cost per kiln is $2,288,731 fo r SNCR. Assuming that 7 new kilns will install SNCR to comply with the NO

x emission limit, the total annuali zed 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

NO

x control.

Exhibit 3 Costs and Cost Effectiveness of NO

x Emission Limits for 1,200,000 tpy Kiln

Option 1 2 3 4

1112 (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 NO

x reduction (tpy) 0 330 600 1,200 Total C/E ($/ton NO

x ) 0 2,023 2,113 2,546



### 2.6.2 Particulate Matter (PM) Emissions

The control of PM emissions under the NSPS w ill be accomplished by baghouses and membrane bags installed for PM (as a surrogate for nonvol atile metal HAP) control under the NESHAP so

that no control costs are attribut able 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, comp liance with the emission limits for PM will be demonstrated using continuous emissions monitoring system s (PM CEMS) installed for demonstrating compliance with the PM ( nonvolatile metal HAP) limits under the NESHAP so that no monitoring costs are attri butable to the NSPS.



### 2.6.3 SO 2 

### Emissions

The control of SO 2 emissions under the NSPS will be accomplished by wet scrubbers installed

for HCl control under the NESHAP so that no co ntrol costs are attribut able to the NSPS. A discussion of the control costs (for HCl) is pres ented in the summary of environmental and cost impacts for the NESHAP.

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

Assuming that seven new kilns will install SO 2 CEMS and continuous flow rate monitors to demonstrate compliance with the SO 2 emissions limit, the total annualized monitoring cost is estimated to be $400,000. Total capital cost over th e 5-year period following promulgation is an
estimated $1.3 million.

2.7 Summary of Impacts

Environmental and cost impacts for the fina l 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 Impactsof Final Amendments for a 1,200,000 tpy Kiln *PollutantCost ($) **EmissionReduction(tpy)Secondary ImpactsCapitalAnnualIncreaseinelectricitydemand(kWh/yr)Increasein waterusage(gpy)Increasein solidwaste(tpy)Increaseinemissionsof NOx(tpy)Increaseinemissionsof CO(tpy)Increaseinemissionsof SO2(tpy)Increaseinemissionsof PM10(tpy)NOx2,289,0001,292,000600Negligible000000PM0000000000SO20000000000*Emission reductions and secondary impacts for PM and SO2are attributed to thePortland Cement NESHAP.**Includes monitoring costs.1314Exhibit 5 Nationwide Cost and Environmental Impacts of Final Amendments *PollutantCost ($) **EmissionReduction(tpy)Secondary ImpactsCapitalAnnualIncreaseinelectricitydemand(kWh/yr)Increasein waterusage(gpy)Increasein solidwaste(tpy)Increaseinemissionsof NOx(tpy)Increaseinemissionsof CO(tpy)Increaseinemissionsof SO2(tpy)Increaseinemissionsof PM10(tpy)NOx19,805,00011,045,0005,275Negligible000000PM0000000000SO20000000000TOTAL19,805,00011,045,000* Emission reductions and secondary impacts for PM and SO2are 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 NO

x Data for Four Cement Kilns. April 1, 2008.

Bahner, M. 2008b. Analysis of Part iculate 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 Ceme nt 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 Pr otection (FL DEP). 2005. Technical Evaluation Preliminary Determination Draft BACT Determ inations 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/perm itting/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 Mana gement (NESCAUM) in Partnership with the

Mid-Atlantic/Northeast Visibi lity Union. 2005. Assessment of Control Technology Options for BART-Eligible Sources. Steam Electric Boilers, I ndustrial 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 (E PA), 2007. Alternative Control Technologies Document Update - NOx Emissions from New Cement Kilns, November 2007.

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

1998.

15U. S. Environmental Protection Agency 2002. O ffice 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, Offi ce of Atmospheric Programs. Output-Based Regulations: A Handbook for Ai r Regulators. August, 2004.

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

Zephyr Environmental Corporation. PSD Appli cation for Lehigh Mason City. September 2002.

16

## Attachment 1

SO2 Monitor Cost Output from the EPA CEMS Cost Model

17Attachment 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

NO

x 

## Monitor Cost Output from the EPA CEMS Cost Model

19Attachment 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

2122 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