CITY OF PHILADELPHIA

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 Summary for PaperWorks Industries, 

Inc. 

Introduction: 

The Clean Air Act (CAA) requires that moderate (or worse) ozone nonattainment areas 

implement reasonably available control technology (RACT) controls on all major sources of 

Volatile Organic Compounds (VOC) and Nitrogen Oxides (NOx). Philadelphia County is part of 

the Philadelphia-Wilmington-Atlantic City moderate 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 paperboard 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 having 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 requirements. 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 applicable 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 April 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 infrared 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 average 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 the 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 MMBTU/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 dryers for millboard. Thus, these units are no longer 

subject to RACT. 

Under the 2008 Plan Approval (No. 08179) the following emission limits and control 

technologies were approved by AMS: 

1. NOx emissions from Boiler #3 and Boiler #4 shall 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 (including Boiler #1 and Boiler #2 during the 

phase-in period) shall not exceed 168.46 tons in any rolling 12-month period. 

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

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

In the 1-hour RACT approval, Boiler #1 had the capability to burn coal. 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 steam production originally provided by Boilers #1 

and #2 and, on August 19, 2014, the facility requested 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 Operating Permit No. V10-009 does not allow Boiler #1 to burn coal 
3 

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 infrared 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 and #4 as “natural gas boilers”, and includes the 

following requirements: 

Boiler #1

Nitrogen Oxides (NOx) emissions from Boiler #1 shall not exceed the following: 

(a) 0.30 lbs/mmbtu, 30 day rolling average when burning #6 oil, and 

(b) 0.20 lbs/mmbtu 30 day rolling average when burning natural gas, 

(c) 138 tons per rolling 12-month period 

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

Boiler #1 shall only burn natural gas and No.6 fuel oil. Boiler #1 shall burn #6 oil for no 

more than 168 hours per rolling 12-month period, solely for emergency, and to keep pipes 

from freezing in case of natural gas interruption. 

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

Boilers #3 and #4

Nitrogen Oxides (NOx) 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 rolling 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 proposing to revise the existing RACT requirements 

consistent with the facility’s approved permit and proposed modifications, to satisfy RACT 

under the 1997 8-hour ozone standard. 

Case-by-case RACT Determination

As explained previously, PaperWorks 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 has 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) infrared heaters, as these units have shut down 

per Title V Operating Permit No. V10-009. 

Boiler #1 

AMS has determined the following modifications 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 natural gas and 0.28 lbs/MMBTU while burning No.6 fuel oil and 

lower emission limits cannot be achieved effectively with the current controls, 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 and 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 control technology as RACT is provided below: 

Flue Gas Recirculation (FGR) 

This is a strategy that recycles a portion of the cooled flue gas back to the primary combustion 

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

Selective Noncatalytic Reduction (SNCR) 

This technology relies on the use of a reagent such 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 large amounts of reagent necessary. 

Reductions in NOx flue gas concentrations are estimated to be about 40% for this boiler. 

Selective Catalytic Reduction (SCR) 

This technology also relies on the introduction 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 are determined economically unreasonable 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 hours 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 MMBTU/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/MMBtu/hr for 168 hrs/yr). 

Boiler #3 & #4 

Each boiler has a heat input rating of 92.27 MMBTU/hr, is currently allowed to burn natural gas 

and No. 6 oil, and operates with LNB and FGR for the control of NOx emissions. These units 

were installed in 2009 and were allowed to burn No.6 oil and natural 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 shall 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 existing boilers during the phase-in period) 

from Boilers #1, #3, & #4 shall not exceed the 162.46 tons per rolling 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 ‘natural gas boilers“, as proposed by PaperWorks. 

AMS determined the existing natural gas emission 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 approval (Plan Approval No. 08179A dated December 19, 2014) to 

redefine the boilers as “natural 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 shall not exceed the following; 

(a) 0.025 lbs/MMBTU while burning natural gas 

(b) 10.15 tons per rolling 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 and 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 emission control technology is provided below: 

Selective Non-Catalytic Reduction 

Selective non-catalytic reduction (SNCR) is a technology whereby an ammonia or ammonia 

based fluid (reducing agent) is injected into the exhaust air stream. Once the mixture comes in 

contact with the catalyst surface, a reduction reaction occurs, breaking down the NOx (NO or 

NO2) and NH3 into N2 and H2O. Reductions in NOx flue gas concentrations 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. Steady temperatures in the range of 1,600 to 2,000°F 

are required to operate an SNCR system effectively. Selective non catalytic reduction is 

considered technically feasible.

Selective Catalytic Reduction 

Selective catalytic reduction (SCR) is a technology whereby an ammonia or ammonia-based 

fluid (reducing agent) is injected into the exhaust air stream upstream of a catalyst. Once the 

mixture comes in contact with the catalyst surface, a reduction reaction occurs, breaking down 

the NOx (NO or NO2) and NH3 into N2 and H2O. NOx emission reduction from Selective 

catalytic reduction is estimated to be 80%. SCR is considered technically feasible. 

A summary of control effectiveness is provided for 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 technology, 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 rolling 12-month period 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 test on boiler #3 & #4 every five years. 

5. Monitoring and record keeping requirements: 

a. PaperWorks shall monitor and record monthly 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 shall not exceed the following: 

(a) 0.20 lbs/MMBTU on 30-day rolling average while burning natural gas, 

(b) 0.30 lbs/MMBTU on 30-day rolling average while burning No. 6 oil, 

(c) A total of 138 tons/year NOx from Boiler #1. 

3. Remove the ability of Boiler #1 to burn 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 gas during normal operation 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. 

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 rolling average basis when burning #6 oil, 

and natural gas, respectively. 

(d) NOx emission calculation per rolling twelve month period calculated monthly 

(e) Records of average hourly heat input for Boiler #1. 

(f) Operating hours of the boiler while burning 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 revision is in compliance with the anti-backsliding 

requirements of CAA Section 110(l). 

1/9/15

Edward Wiener, Chief of Source Registration Date 
8 

Appendix

Summary of Cost-Effectiveness Calculations

The following were calculated in order to evaluate 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 Investment 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 catalyst 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 (Future) to A(Annual amount), A=F(A/F,i%,n), 

(1 ) 1  n i

i SFF 

Where i= Annual interest Rate (10%); 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 

2NH3 + 2NO + 1⁄2 O2 2N2 + 3H2O 

Ammonia cost =(17/30 * 1.05 *2 mole of Ammonia/2 mole of NO *NOx emission (tpy) 

*$410/ton 

NH3 = Ammonia (1.05 is assuming 5% ammonia slip) 

NO = Nitric Oxide 

O2 = Oxygen 

H2O = Water 

Ammonia cost =(17/30 * 1.05 *2 mole of Ammonia/2 mole of NO *NOx emission (tpy) 

*$410/ton 
10 

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 includes 

equipment cost estimates from vendorsupplied estimates for similar units. 

 

Total Annual Costs 

Direct Annual Cost (DAC) 

Electricity Cost1 $70,080 100kw @ $0.08/kwh, 8760 hrs/yr 

Operator1 $16,425 0.5hr/shift, 3 shift/day, $30/hr 

Supervisor1 $2,463.75 15% of Operator 

Maintenance1 $19,162.50 0.5hr/shift, 3 shift/day, $35/hr 

Material1 $19,162.50 100% of Maintenance 

Total Direct Annual Cost $127,294 

 

Indirect Annual Cost (IAC) 

Overhead1 $11,498 60% of maintenance-1

Administrative Charge1 $16,774 2% of TCI-1

Property Taxes1 $8,387 1% of TCI-1

Insurance1 $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) 

$4,481 
11 

Table 2- Detailed Calculations 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 includes 

equipment cost estimates from vendorsupplied estimates for similar units. 

 

Total Annual Costs

Direct Annual Cost Based on EPA cost Manual 

Electricity Cost1 $70,080 100kw @ $0.08/kwh, 8760 hrs/yr 

Operator1 $16,425 0.5hr/shift, 3 shift/day, $30/hr 

Supervisor1 $2,463.75 15% of Operator 

Maintenance1 $19,162.50 0.5hr/shift, 3 shift/day, $35/hr 

Material1 $19,162.50 100% of Maintenance 

Total Direct Annual Cost $127,294 

 

Indirect Annual Cost 

Overhead1 $11,498 60% of maintenance1

Administrative Charge1 $38,080 2% of TCI1

Property Taxes1 $19,040 1% of TCI1

Insurance1 $19,040 1% of TCI1

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) 

$8,848 
12 

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 includes 

equipment cost estimates from vendorsupplied estimates for similar units 

 

Direct Annual Cost Based on EPA cost manual 

Electricity Cost1 $70,080 100kw @ $0.08/kwh, 8760 hrs/yr 

Maintenance1 $57,375.0 0.015*TCI 

Total Catalyst replacement Cost1 $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 

Overhead1 $34,425 60% of maintenance1

Administrative Charge1 $76,500 2% of TCI1

Property Taxes1 $38,250 1% of TCI1

Insurance1 $38,250 1% of TCI1

Capital recovery1 $502,988 CRF * TCI; 15 yrs @10% -1-hour RACT 

Proposal; CRF= 0.13151

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) 

$7,795 
13 

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=0.011751

Annual Costs 

Direct Annual Cost Based EPA Cost Control Manual 

Electricity Cost1 $5,606 8kw @ $0.08/kwh, 8760 hrs/yr 

Ammonia Cost1 $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 maintenance1

Administrative Charge1 $16,500 2% of TCI1

Property Taxes $8,250 1% of TCI1

Insurance $8,250 1% of TCI1

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) 

$22,919 
14 

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)* QB*(2375 

MMBTU/hr/QB)^0.577*(0.66+0.85ɳNOx) 

Where QB is max. potential heat input rate; 

ɳNOx 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 Cost1 $701 1kw @ $0.08/kwh, 8760 hrs/yr 

Maintenance1 $17,469 1.5% TCI 

Ammonia1 $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 maintenance1

Administrative Charge1 $16,879 2% of TCI1

Property Taxes $8,439 1% of TCI1

Insurance $8,439 1% of TCI1

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, 6th Edition, Jan 2002, Appendix A.2.3