CITY OF PH ILADELPHIA Department of Public Health

Environmental Protection Division Air Management Services

InterOffice Memo

To: File

From: Rahel Gebrekidan

Date: January 8, 2015

Subject: RACT Plan Approval Modification Su mmary for PaperWorks Industries,

Inc.



### Introduction:

The Clean Air Act (CAA) requires that mode rate (or worse) ozone nonattainment areas implement reasonably available control technolo gy (RACT) controls on all major sources of Volatile Organic Compounds (VOC) and Nitrogen Oxid es (NOx). Philadelphia County is part of the Philadelphia-Wilmington-Atlantic City mode rate ozone nonattainment area for the 1997 8- hour ozone NAAQS. This document presents the findings of a RACT evaluation for the 1997 8- hour ozone standard for this facility.



### Company Description :

PaperWorks Industries owns and operates a pa perboard manufacturing facility located at 5000 Flat Rock Road, Philadelphia, PA 19127. The facility was formerly named Jefferson Smurfit, Corporation.



### Applicability for NOx and VOC RACT:

PaperWorks Industries is a major source of NOx due to havi ng potential emissions greater than 100 tons per year, the major source threshold in Philadelphia County that is applicable to NOx RACT. The facility is therefore subject to the CAA RACT requireme nts. This facility is not a major source of VOC having potential emissions of less than 50 tons per year, the major source threshold in Philadelphia County that is appl icable to VOC RACT for the 1997 8-hour ozone NAAQS.



### 1-Hour Case-by-case RACT
AMS determined (under its former name of Jefferson Smurfit Corp.) a case-by-case RACT analysis for the 1-hour ozone standard in June, 1994. As a result, AMS issued a RACT plan approval (PA-51-1566) on Apr il 10, 1995, which was approved by EPA as a SIP revision on 10/31/2001 (66 FR 54947). NOx RACT was determined for Boiler #1, Boiler #2 and four Infrared Heaters, as described below.

1-hour RACT sources:2 1. Boiler #1: Riley boiler with a capacity of 240 MMBTU/hr, firing coal, #6 oil and natural gas.

2. Boiler #2: Riley boiler with a capacity of 225 MMBTU/hr firing coal, #6 oil and natural gas.

3. Four Infrared Heaters: Propane fueled infr ared radiation heaters that are used as dryers for millboard. Each heater has a capacity of 2.9MMBTU/hr.

The following control methods and emission limits were determined as RACT under

the 1-hour ozone standard:

1. Each boiler shall be installed with low NOx burners and overfire air.

2. Boiler #1 and Boiler #2 combined NOx emission rates shall not exceed the following: (a) 0.20 lbs/MMBTU on a 30-day rolling aver age while burning natural gas, (b) 0.30 lbs/MMBTU on a 30-day rolling average while burning No. 6 oil, (c) 0.50 lbs/MMBTU on a 30-day rolling average while burning coal, (d) Total NOx 1,018 tons/yr

3. The heaters were applicable to th e presumptive RACT requirements of 129.93(c)(1).



### Modifications to RACT Sources
In 2008, AMS issued Plan Approval No. 08179 dated 12/30/2008 to PaperWorks that authorized the replacement of existing Boilers #1 and #2 with two new 92.72 MMBTU /hr boilers at the facility (to be named Boiler #3 & #4, each 92.72 MMB TU/hr). As part of this plan approval Boiler #2, a 225 MMBTU/hr boiler, was shutdown as well as four propane-fueled infrared radiation heaters that used to be used as drye rs for millboard. Thus, these units are no longer subject to RACT.

Under the 2008 Plan Approval (No. 08179) th e following emission limits and control technologies were approved by AMS:

1. NOx emissions from Boiler #3 and Boiler #4 sh all not exceed the following: [25 Pa Code §127.1]

a. 0.025 lbs/MMBTU burning natural gas

b. 0.30 lbs/MMBTU while burning No. 6 oil.

c. The combined emissions from the boilers (inc luding Boiler #1 and Boiler #2 during the phase-in period) shall not exceed 168. 46 tons in any rollin g 12-month period.

2. Boilers #3 and #4 shall only burn natural gas and No.6 fuel oil

3. PaperWorks shall install and operate LN B and FGR on each boiler (Boilers #3).

In the 1-hour RACT approval, Boiler #1 had th e capability to burn co al. As previously mentioned, in 2008 the facility proposed replacing Boilers #1 and #2 with new boilers, #3 and

#4. In 2009 Boilers #3 and #4 were installed but were never able to properly operate while burning No. 6 fuel oil or operate up to full capacity. As a result the facility determined that the two new boilers could not fully replace the st eam production originally provided by Boilers #1 and #2 and, on August 19, 2014, the facility requeste d that Boiler #1 (240 MMBtu/hr) continue operating at limited capacity (156 MMBtu/hr) with the ability to burn coal being removed as well as limiting No. 6 fuel oil usage to emergencies only. The facility also requested that Boilers #3 and #4 be restricted from burning No. 6 fuel oil altogether. This 2014 request was incorporated into Plan Approval No. 08179A, which was issued December 19, 2014. Currently, the facility’s Title V State Op erating Permit No. V10-009 does not allow Boiler #1 to burn coal3 and includes the shutdown Boiler #2 or infrared heaters. Therefore, AMS is proposing updates to the existing SIP-approved requirements for Boiler #1, and requesting that the applicable RACT requirements for Boiler #2 and the infr ared heaters be removed from the SIP.

Plan Approval No. 08179A removes the ability of Boiler #1 to burn coal and any associated applicable requirements, redefines Boilers #3 an d #4 as “natural gas bo ilers”, and includes the following requirements:

Boiler #1 Nitrogen Oxides (NO

x ) emissions from Boiler #1 shall not exceed the following: (a) 0.30 lbs/mmbtu, 30 day rolling aver age when burning #6 oil, and (b) 0.20 lbs/mmbtu 30 day rolling average when burning natural gas, (c) 138 tons per ro lling 12-mont h period

Boiler #1 shall be equipped with Lo w NOx Burners with Overfire Air.

Boiler #1 shall only burn natura l gas and No.6 fuel oil. Boile r #1 shall burn #6 oil for no more than 168 hours per rolling 12-month perio d, solely for emergency, and to keep pipes from freezing in case of na tural gas interruption.

The maximum capacity of Boiler #1 shall be limited to 156 MMBTU/hr.

Boilers #3 and #4 Nitrogen Oxides (NO

x ) emissions from boiler No.3 & 4 each shall not exceed the following: (a) 0.025 lbs/MMBTU while burning natural gas. (b) 10.15 tons per ro lling 12-month period.

Boilers #3 & #4 shall be equipped with Low NOx Burners and Flue Gas Recirculation.

Boilers #3 & #4 shall only burn natural gas.

As discussed in detail below, AMS is proposin g to revise the existing RACT requirements consistent with the facility’s approved perm it and proposed modifications, to satisfy RACT

under the 1997 8-hour ozone standard.



### Case-by-case RACT Determination
As explained previously, PaperW orks currently operates the following air emissions sources:

 Boiler #1, at present only allowed to burn natural gas and No. 6 oil, and

 Boilers #3 and #4, each rated 92.27 MMBTU/hr and currently allowed to burn natural gas and No. 6 oil, but for which the facility ha s requested to only burn natural gas.

AMS is proposing as RACT for Boilers #1, #3, and #4 the modification to Plan Approval No. 08179 (08179A) as described below. AMS is also proposing to remove from the SIP any NOx RACT requirements for Boiler #2 and the four (4) in frared heaters, as thes e units have shut down per Title V Operating Permit No. V10-009.

Boiler #1 AMS has determined the following modificatio ns as RACT requirements for Boiler #1,4  To remove the ability of Boiler #1 to burn coal and the associated NOx emission limits;

 To limit the heat input capacity of Boiler #1 to a maximum of 156MMBTU/hr;

 To burn natural gas as a primary fuel and limit the maximum No.6 fuel oil usage to 168 hrs/year, solely for emergency purpose and to keep pipes from freezing in case of natural gas interruption and

 A total of 138 tons/year NOx for Boiler #1.

Currently, the CEM reading shows that the NOx emission for Boiler #1 ranges as high as 0.19 lbs/MMBTU while burning natura l gas and 0.28 lbs/MMBTU while burning No.6 fuel oil and

lower emission limits cannot be achieved effectivel y with the current cont rols, LNB and overfire

air.

To demonstrate that the current controls achieve the lowest emissions rates for Boiler 1, AMS

has evaluated additional controls for technical an d economic feasibility. Therefore, in addition to existing NOx controls, other control strategies that may be considered for Boiler #1 for NOx

RACT are as follows:

 Flue Gas Recirculation (FGR)

 Selective Non-Catalytic Reduction (SNCR)

 Selective Catalytic Reduction (SCR)

A detailed analysis for each emission cont rol technology as RACT is provided below:

Flue Gas Recirculation (FGR) This is a strategy that recycles a portion of th e cooled flue gas back to the primary combustion

zone and the NOx reductions ar e estimated to be about 20%.

Selective Noncatalyt ic Reduction (SNCR) This technology relies on the use of a reagent su ch as ammonia or urea introduced into the stack gasses under optimum conditions. Reagent must be introduced into an oxygen rich stream in a tight temperature window. Too low a temperature can result in reagent being released to the atmosphere. Too high a temperature can actually result in the formation of NOx. This project would require extensive changes to the boiler and relatively larg e amounts of reagent necessary. Reductions in NOx flue gas con centrations are estimated to be about 40% for this boiler.

Selective Catalytic Reduction (SCR) This technology also relies on the intr oduction of a reducing agent, principally ammonia, into the flue gases using some form of catalyst. Like SNCR this approach is highly dependent on stream temperature. The NOx reductions are estimated to be

about 80%.

All of these NOx controls are determined technologically feasible for Boiler # 1

. A summary of control effectiveness is provided for each technologically feasible control option.

Note. The baseline NOx emission was calculated based on the following proposed RACT limitations: the heat input capacity limit, the usage of natural gas as primary fuel and No.6 oil as a backup for up to 168 hrs/year, the 0.30 lb/MMBtu NOx RACT limit for burning oil, and the 0.20 lb/MMBTU NOx RACT limit for natural gas.

Source Control Technology Baseline

NOx

Emissions (tpy) NOx

Reduction (%) NOx

Reduction (tpy) Total

Annualized

Cost Cost

Effectiveness ($/Ton)5 Boiler

#1 FGR 138 20 27.6 $282,627 $10,240.10 SNCR 138 40 55.2 $ 488,416 $8,848
SCR 138 80 110.4 $882,655 $7,795

All these controls ar e determined economically unreasonabl e when considering the proposed

enforceable restrictions as RACT. For more detailed calculations, please see Appendix.

Reducing the capacity from 240 MMBTU/hr to 156 MMBTU/hr, requiring natural gas as primary fuel, removing the ability to burn coal, and reducing No. 6 oil usage to emergencies (to prevent pipes from freezing), and a limit of 168 h ours per year all reduce NOx emissions from Boiler #1. Potential NOx emissions from Boiler #1 are reduced from 525.6 tons per year (assuming coal burning of 0.50 lbs/MMBTU, 240 MMB TU/hr, and 8,760 hrs/yr) to 138 tons per year (assuming 156 MMBtu/hr, burning natural gas at 0.2 lbs/MMBtu for 8,592 hrs/yr and burning oil at 0.3 lbs/MMBt u/hr for 168 hrs/yr).

Boiler #3 & #4 Each boiler has a heat input ra ting of 92.27 MMBTU/hr, is currently allowed to burn natural gas and No. 6 oil, and operates with LNB and FGR fo r the control of NOx emissions. These units

were installed in 2009 and were allowed to burn No.6 oil and natu ral gas per Plan Approval No. 08179 dated December 30, 2008. The following NOx emission limitations and control technology was approved per 25 Pa Code §127.1:

1. NOx emissions from each boiler sh all not exceed the following:

a. 0.025 lbs/MMBTU while burning natural gas.

b. 0.30 lbs/MMBTU while burning No. 6 oil.

2. The combined NOx emissions (including the ex isting boilers during th e phase-in period) from Boilers #1, #3, & #4 shall not exceed th e 162.46 tons per ro lling 12-month period.

3. Boiler #3 and 4 shall only burn natural gas and No.6 fuel oil.

4. PaperWorks shall install and operate LNB and FGR on Boilers #3 and #4.

However, as previously mentioned, the facility requested to modify plan approval No.08179 to remove the ability to burn No.6 fuel oil on these boilers and redefined the boilers as “natural gas boilers ” as of August 19, 2014. As part of the modification to Plan Approval No. 08179 (08179A, issued December 19, 2014), AMS is proposing to remove the emission limits for No.6

fuel oil and thus redefine the boilers as ‘nat ural gas boilers“, as pr oposed by PaperWorks.

AMS determined the existing natural gas emi ssion limit and NOx control technology (LNB and FGR) approved in Plan Approval No. 08179 dated December 30, 2008, as well as the modification to this plan a pproval (Plan Approval No. 08179A dated December 19, 2014) to

redefine the boilers as “nat ural gas boilers” shall be NOx RACT for the 1997 8-hour ozone standard. The following emission limits shall be NOx RACT for Boilers #3 and #4:

NOx emissions from Boiler #3 sh all not exceed the following; (a) 0.025 lbs/MMBTU while burning natural gas (b) 10.15 tons per ro lling 12-month period for each boiler

To demonstrate that the current controls achieve the lowest emissions rates for Boilers 3-4, AMS

has evaluated additional controls for technical an d economic feasibility. In addition to existing controls, other control strategies that may be considered for Boilers #3 and #4 for NOx RACT

are as follows:

 Selective Non-Catalytic Reduction (SNCR)6  Selective Catalytic Reduction (SCR)

A detailed analysis for each emissi on control technology is provided below:

Selective Non-Catalytic Reduction Selective non-catalytic reducti on (SNCR) is a technology wher eby an ammonia or ammonia based fluid (reducing agent) is injected into the exhaust air st ream. Once the mixture comes in contact with the catalyst surf ace, a reduction reaction occurs, breaking down the NOx (NO or

NO 2 ) and NH 3 into N 2 and H 2 O. Reductions in NOx flue gas con centrations are estimated to be between 20% and 50% for boilers, depending on the reducing chemical used and effective control of optimal operating conditions (exhaust gas temperature). SNCR systems require relatively high gas operating temperatures. Stead y temperatures in the range of 1,600 to 2,000°F are required to operate an SNCR system ef fectively. Selective non catalytic reduction is considered technically feasible

.

Selective Catalytic Reduction Selective catalytic reduction (SCR) is a tec hnology whereby an ammonia or ammonia-based fluid (reducing agent) is injected into the exha ust air stream upstream of a catalyst. Once the mixture comes in contact with the catalyst surface, a reduction reacti on occurs, breaking down the NOx (NO or NO 2 ) and NH 3 into N 2 and H 2 O. NOx emission reduction from Selective catalytic reduction is esti mated to be 80%. SCR is considered technically feasible.

A summary of control effectiveness is provided fo r each technologically feasible control option.

Note: For purposes of cost calculations in this evaluation the baseline emissions are based on the following proposed RACT limitations: the allowable maximum emission limits of 10.15 tons per rolling 12 month period.

Source Control Technology Baseline NOx Emissions (tpy) NOx

Reduction (%) NOx

Reduction (tpy) Total

Annualized

Cost Cost

Effectiveness ($/Ton) Boiler #3 SCR 10.15 80 8.12 $186,102 $22,919 SNCR 10.15 40 4.06 $202,909 $49,978

All these controls are determined economically unreasonable . For more detailed calculations, please see Appendix.

Conclusion and Recommendation; AMS has determined the following emission limits, control tec hnology, monitoring and recordkeeping requirements shall be NOx RACT for boiler #3 & #4 for the 1997 8-hour ozone

standard:

1. NOx emissions from each boiler shall not exceed the following: [25 Pa Code §127.1]

a. 0.025 lbs/MMBTU while burning natural gas.

b. 10.15 tons per ro lling 12-month peri od for each boiler

2. Each boiler shall be equipped with LNB and FGR

3. Each boiler shall only burn natural gas

4. Testing requirement

a. Paperwork shall conduct a NOx performance te st on boiler #3 & #4 ev ery five years.

5. Monitoring and record keeping requirements:

a. PaperWorks shall monitor and record m onthly fuel usage for each boiler, and calculate monthly NOx emission for each boiler per rolling 12-month period.7 In addition, AMS has determined the following emission limits, control technology, monitoring and recordkeeping requirements shall be NOx RACT for boiler #1 for the 1997 8-hour ozone

standard:

1. Boiler #1 shall be operated with low NOx burners and overfire air while burning natural gas and No.6 oil.

2. NOx emissions from Boiler #1 sh all not exceed the following: (a) 0.20 lbs/MMBTU on 30-day rolling aver age while burning natural gas, (b) 0.30 lbs/MMBTU on 30-day rolling av erage while burning No. 6 oil, (c) A total of 138 tons/yea r NOx from Boiler #1.

3. Remove the ability of Boiler #1 to bu rn coal and the associated emission limits from the SIP-approved 1-hour RACT.

4. Limit the capacity of Boiler #1 to a maximum of 156 MMBTU/hr

5. Boiler #1 shall only burn natural ga s during normal operation and limit the maximum No.6 fuel oil usage to 168 hrs/ye ar, solely for emergency purpose and to keep pipes from freezing in cas e of natural gas interruption.

6. Monitoring and record keeping requirement (a) Daily and monthly natural gas usage, (b) Daily and monthly No.6 oil usage for Boiler #1 (c) NOx in lbs/MMBTU on a 30-day rolli ng average basis when burning #6 oil, and natural gas, respectively. (d) NOx emission calculation per rolling twel ve month period calculated monthly (e) Records of average hourly h eat input for Boiler #1. (f) Operating hours of the boiler while burn ing No.6 fuel oil, and Records of the reason for burning fuel oil each time.

As noted above, the proposed modifications to the SIP-approved RACT requirements for Boiler #1 will result in additional potential NOx emissions reductions than those achieved under the 1- hour ozone RACT. Thus, the proposed SIP revisi on is in compliance with the anti-backsliding requirements of CAA Section 110(l).

1 / 9 / 1 5

Edward Wiener, Chief of Source Registration Date8 Appendix

Summary of Cost-Effectiveness Calculations The following were calculated in order to eval uate the cost effectiveness of each emission control technology:

‐ Total Capital Investment (TCI) ($)

‐ Annualized Capital Investment or Capital Recovery ($/yr)

‐ Total Annual Cost (TAC) ($/yr)

‐ Baseline NOx Emissions (tons/yr)

‐ NOx Emission Reduction (tons/yr)

‐ Cost Effectiveness ($/ton)

Capital Recovery To convert from P (present Value) to A(Annual amount), A=P(A/P,i%,n),

1 ) 1 ( ) 1 (

  



n n

i i i CRF

Where i= Annual interest Rate; n= control system life;

Annualized Capital Invest ment cost = TCI x CRF

‐ For Boiler #1: i=10% interest and n=15 yrs

CRF=0.1315

‐ For Boilers #3 and #4: i= 10% interest and n=20 yrs

CRF=0.1175

Cost of the Catalyst in SCR

The annual cost is given by the sinking fund factor , the amount of money the facility will need to set aside each year to be able to replace the cataly st at the end of its life, based on the lifespan of the catalyst and the interest rate. The catalyst life is 5 years.

Sinking Fund Factor (SFF) = Convert from F (Futur e) to A(Annual amount), A=F(A/F,i%,n),



### 1 ) 1 (



 

n 

### i i SFF

Where i= Annual interest Rate (1 0%); n= catalyst system life; For i=10% and n=5 yrs ; SFF=0.1638

Catalyst Annual Cost = SFF x Catalyst Cost

Cost of the Ammonia in SCR and SNCR (Based on EPA Cost Manual)9 2NH 3 + 2NO + 1⁄2 O 2 2N 2 + 3H 2 O

Ammonia cost =(17/30 * 1.05 *2 mole of A mmonia/2 mole of NO *NOx emission (tpy)
*$410/ton

NH 3 = Ammonia (1.05 is assuming 5% ammonia slip)

NO = Nitric Oxide

O 2 = Oxygen

H 2 O = Water

Ammonia cost =(17/30 * 1.05 *2 mo le of Ammonia/2 mole of NO *NOx emission (tpy)
*$410/ton10 Table 1- Detailed Calculations for FGR-Boiler #1

Total Capital Cost

Total Capital Investment Cost (TCI) $838,695 TCI from 1-hour RACT proposal plus inflation adjustment. Original TCI includesequipment cost estimates from vendorsupplied estimates for similar units.

Total Annual Costs

Direct Annual Cost (DAC)

Electricity Cost 1 $70,080 100kw @ $0.08/kwh, 8760 hrs/yr

Operator 1 $16,425 0.5hr/shift, 3 shift/day, $30/hr

Supervisor 1 $2,463.75 15% of Operator

Maintenance 1 $19,162.50 0.5hr/shift, 3 shift/day, $35/hr

Material 1 $19,162.50 100% of Maintenance

Total Direct Annual Cost $127,294

Indirect Annual Cost (IAC)

Overhead 1 $11,498 60% of maintenance- 1

Administrative Charge 1 $16,774 2% of TCI- 1

Property Taxes 1 $8,387 1% of TCI- 1

Insurance 1 $8,387 1% of TCI- 1

Capital Recovery $110,288 CRF * TCI; 15 yrs @10% (1-hour RACT Proposal); CRF= 0.1315

Total Indirect Annual Cost $155,334

Total Annual Costs $282,627

Baseline Emissions (TPY) 138 Based on permit limit

NOx Emission Reduction (TPY) 63.07 Assuming 20% NOx reduction.

Cost Effectiveness ($/ton NOx removed) $4,48111 Table 2- Detailed Calculat ions for SNCR- Boiler#1

Total Capital Cost

Total Capital Investment Cost (TCI) $1,904,000 TCI from 1-hour RACT proposal plus inflation adjustment. Original TCI includesequipment cost estimates from vendorsupplied estimates for similar units.

Total Annual Costs

Direct Annual Cost Based on EPA cost Manual

Electricity Cost 1 $70,080 100kw @ $0.08/kwh, 8760 hrs/yr
Operator 1 $16,425 0.5hr/shift, 3 shift/day, $30/hr

Supervisor 1 $2,463.75 15% of Operator

Maintenance 1 $19,162.50 0.5hr/shift, 3 shift/day, $35/hr

Material 1 $19,162.50 100% of Maintenance

Total Direct Annual Cost $127,294

Indirect Annual Cost

Overhead 1 $11,498 60% of maintenance 1

Administrative Charge 1 $38,080 2% of TCI 1

Property Taxes 1 $19,040 1% of TCI 1

Insurance 1 $19,040 1% of TCI 1

Capital Recovery $250,376 CRF * TCI; 15 yrs @10% -1-hour RACT Proposal; CRF= 0.1315 Total Indirect Annual Cost $360,961

Total Annual Costs $488,416

Baseline Emissions (TPY) 138 Based on permit limit

NOx Emission Reduction (TPY) 55.2 Assuming 40% NOx reduction.

Cost Effectiveness ($/ton NOx removed) $8,84812 Table 3- Detailed Calculations for SCR- Boiler #1

Total Capital Cost

Total Capital Investment Cost (TCI) $3,825,000 TCI from 1-hour RACT proposal plus inflation adjustment. Original TCI includesequipment cost estimates from vendorsupplied estimates for similar units

Direct Annual Cost Based on EPA cost manual

Electricity Cost 1 $70,080 100kw @ $0.08/kwh, 8760 hrs/yr

Maintenance 1 $57,375.0 0.015*TCI

Total Catalyst replacement Cost 1 $31,122 SFF x Catalyst Catalyst Cost= $190,000; Cost; SFF=0.1638

Ammonia Cost $33,665 Ammonia cost =(17/30 * 1.05 *2 mole of

Ammonia/2 mole of NO *NOx emission (tpy)(138 tons) *$410/ton= Total Direct Annual Cost $192,242

Indirect Annual Cost

Overhead 1 $34,425 60% of maintenance 1

Administrative Charge 1 $76,500 2% of TCI 1

Property Taxes 1 $38,250 1% of TCI 1

Insurance 1 $38,250 1% of TCI 1

Capital recovery 1 $502,988 CRF * TCI; 15 yrs @10% -1-hour RACT Proposal; CRF= 0.1315 1

Total Indirect Annual Cost $690,413

Total Annual Costs $882,655

Baseline Emissions (TPY) 138 Based on permit limit

NOx Emission Reduction (TPY) 110.4 Assuming 80% NOx reduction.

Cost Effectiveness ($/ton NOx removed) $7,79513 Table 4- Detailed Calculations for SCR- Boilers #3 each (92.72 MMBTU/hr)

Total Capital Cost

Total Capital Investment Cost (TCI) $824,997 Based EPA Cost Control Manual of $6000/MMBTU/Hr. (Section 4, chapter 2, page 149) Escalated 1997 US $ using the

Marshall and swift Index. Capital Recovery $96, 937 CRF * TCI; n=20 yrs, i=10%;

CFR=0.01175 1

Annual Costs

Direct Annual Cost Based EPA Cost Control Manual

Electricity Cost 1 $5,606 8kw @ $0.08/kwh, 8760 hrs/yr

Ammonia Cost 1 $2,476 Ammonia cost =(17/30 * 1.05 *2 mole of

Ammonia/2 mole of NO *NOx emission (tpy)(10.15 tons) *$410/ton Catalyst cost $172,667 $122487 total catalyst in 1999 and $172,667

in 2014 cost Catalyst Replacement Cost $28,283 0.1638 SFF x Catalyst Cost SFF=0.1638, for n=5 yrs and i=10%

SFF=0.1638; Total Direct Annual Cost $185,737

Indirect Annual Cost

Overhead $11,498 60% of maintenance 1

Administrative Charge 1 $16,500 2% of TCI 1

Property Taxes $8,250 1% of TCI 1

Insurance $8,250 1% of TCI 1

Total Indirect Annual Cost $137,362

Total Annual Costs $186,102

Baseline NOx Emissions (TPY) 10.15 Based on permit limit

NOx Emission Reduction (TPY) 8.12 Based on 80% reduction

Cost Effectiveness ($/ton NOx removed) $22,91914 Table 5- Detailed Calculations for SNCR Boilers #3 and #4, each (92.72 MMBTU/hr)

Total Capital Costs

Direct Capital Cost (DCC) 1

( SNCR system equipment, instrumentation, sales tax and freight. It also includes direct installation costs such as auxiliary equipment (e.g., ductwork, compressor), foundations and supports, handling and erection, electrical, piping, insulation and painting) $843,925 Based EPA Cost Control Manual, Pages 1- 31, 1-32, Table-1.4. (($950/MMBTU)* Q B *(2375 MMBTU/hr/Q B )^0.577*(0.66+0.85 ɳ NOx ) Where Q B is max. potential heat input rate;

ɳ

NOx is the NOx removal efficiency.

Indirect Capital Cost (ICC) 1

( includes costs such as; construction and contractor fees, startup and testing, inventory capital, and any process and project) $168,785 0.2 *(DC)

Contingency $151,907 0.15*ICC*DCC

Total Capital Investment Cost (TCI) $1,164,617

Total Annual Costs

Direct Annual Cost (DAC)

Electricity Cost 1 $701 1kw @ $0.08/kwh, 8760 hrs/yr

Maintenance 1 $17,469 1.5% TCI

Ammonia 1 $2,476 Ammonia cost =(17/30 * 1.05 *2 mole of

Ammonia/2 mole of NO *NOx emission (tpy)(10.15 tons) *$410/ton Total Direct Annual Cost $20,646

Indirect Annual Cost (IAC)

Overhead $10,481.40 60% of maintenance 1

Administrative Charge 1 $16,879 2% of TCI 1

Property Taxes $8,439 1% of TCI 1

Insurance $8,439 1% of TCI 1

Capital Recovery $136,842 CRF * TCI; n=20 yrs, i=10% 1

CRF=0.1175

Total Indirect Annual Cost $182,246

Total Annual Costs (TAC) $202,909 TAC = DAC + IAC

Baseline NOx Emissions (TPY) 10.15 Based on permit limit

NOx Emission Reduction (TPY) 4.1 Based on 40% reduction

Cost Effectiveness ($/ton NOx removed) $49,978

REFERENCES: 1- EPA Cost Manual, 6 th Edition, Jan 2002, Appendix A.2.3