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Ash Grove MontanaCity BARTAnalysis update Curtis Lesslie to: Vanessa Hinkle, ChristopherAjayi 01/19/201208:45 PM Cc: Bob Vantuyl, TomWood, Kasi Dubbs Hide Details From: Curtis Lesslie <curtis.lesslie@ashgrove.com> To: Vanessa Hinkle/R8/USEPA/US@EPA, ChristopherAjayi/R8/USEPA/US@EPA Cc: Bob Vantuyl <bob.vantuyl@ashgrove.com>, Tom Wood <trwood@stoel.com>, Kasi Dubbs <KDubbs@trinityconsultants.com>

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## iJill 2012 01 17 DAA Costper ton.x1sx
Vanessa and Chris:

As agreed during our phone discussion on December 29, 2011, Ash Grove is providing additional information related to the cost ofdry adsorbent addition 

### (OM) for our Montana City plant as a supplement to our previously submitted BART analysies. The attached spreadsheet provides the cost on a dollar per ton of 802 reduced. The analysis is consistent with what we talked about on December 29. More specifically, the analysis is based on the following: 1) A 2:1 molar ratio of lime injection to 802 emissions 2) An estimate that a 2:1 molar ratio will achieve 30% control (the 3D-day average baseline rate is 147 Ib/hr, thus the proposed limit is 103 Ib/hron a 30-day rolling basis) Please note that the control efficiency of 30% estimated for a 2: 1 molar ratio is higher than the control efficiency that was used to determine the 24-hour average emission rate for 

### OM as presented in the modeling report that was submitted to you on October 25, 2011. The 24-hour average baseline emission rate is 395 Ib/hr and the controlled rate using 20% control is 316 Ib/hr. In our phone discussion on December 29, you indicated that


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revised modeling reflecting 30% control rather than 20% was unnecessary since it is clear that S02 emissions have little impact on visibility. Also, Iwould like to emphasize that while we are providing a cost for OMand proposing a limit for S02 emissions reflective of OM, we continue to maintain the position that no level ofS02 reduction results in significant visibility improvement (since the visibility is dominated by NOx and not SOx). Since improvement to visibility impairment is one ofthe statutory factors that must be considered in determining what qualifies as BART, we maintain that no S02 reductions are needed to satisfy BART. Thus, any requirement to reduce S02 emissions using OM should be considered an innovative control technology that Ash Grove is voluntarily agreeing to install. Further no reductions beyond what can be achieved using OM should be required, since further reductions would not satisfy the BART criteria.



### Itrustthat this submittal will satisfy your needs in resolving this issue.

Sincerely, Curtis

Curtis Lesslie, PE Vice President EnvironmentalAffairs Ash Grove Cement Company 11011 Cody St., Overland Park, KS 66210 P: (913) 319-6065 M: (785) 550-6330 

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### 1/26/2012AGC Montana City S02ControlCost Effectiveness Analysis Dry Lime Injection System DirectCosts Notes PurchasedEauiDmentCosts Estimate based on 20II Penta Engmeering Quole(20II Quote) for AGC Montana City Hydrated Lime InjectIOn Dry Lime Injection System S151,000 system. Instrumentation TBD Freight SIIOOO 2011 Quote Subtotal, Purchased EquipmentCost (PEC) S162,000 B DIrect Installation Costs Civil Structural (incl. mat'l) S17,000 2011 Quote Foundation lncl Supports Incl Handling and Erection S74,000 2011 Quote Electrical S46,000 2011 Quote Piping Incl Insulation for Ductwork S20,000 2011 Quote 0.01 B, from CONTROL COST MANUALPainting (I% ofPEe) SI,620 EPA/452/B-02-001 (CCM) Truck Parkin' SIO,OOO 2011 Quote Subtotal, DirectInstallation Cost S168,620 Total DirectCost S330,620 IndirectCosts Engineering S40,000 2011 Quote Construction and Field Expense Incl ContractorFees S23,000 2011 Quote Start-up S6,000 2011 Quote PerfonnanceTest (\%ofPEC) SI,620 001 B, CCM ContlOl!encies S82,OOO 2011 Quote Total IndirectCost S152,620

Total Capitallnvestmenl (Tel) S483,240 DirectAnnual Costs Hours per Year 95% Annual Run Time 8,322 Operating Labor Operator (0.5 hr/shift, 3 shifts/day, 365 dlyr, S25ihr) S13,688 estimate Supervisor(15% ofoperator) S2,053 CCM Subtotal, OperatingLabor S15,741 Maintenance Labor(0.5 hr/shift, 3 shifts/day, 365 dlyr, S25ihr) S13,688 estimate Material (5%ofTota! Direct Cost). Increased to account for high rateof damcw:ed bags that is exoected. S 16531 AGC engineering estimate Subtotal. Maintenance S30,219 Lime Hydrated lime/Sulfur Dioxide molar ratiO, min. Ca/S 20 AGC Engmeenng Estimate MWofCa(OH)2 74 MWofS02 64 Purity ofthe Comercial i1me % 96.8 estimate Lime RequIred

- ShortTons 1461 Cost ($/short Ion) S 145.00 Slton delivered (Quote from Graymont) Subtotal, Lime S211,880 Total Direct Annual Costs S257,839 IndirectAnnual Costs Overhead (60% ofsum ofoperating, supervisor, maintenance labor & materials) S154,703 Administrative (2%Tel) S9,665 CCM Property Tax (I% TCI) S4,832 CCM Insurance (1%Tel) S4,832 CCM Canita! Recoverv (IS year life 7percent interest) S53,057 Total IndirectAnnual Cost S227,090 Conclusion
Total Annualized Cost S484,929 Based on 20I0 average emission rate of 147 Iblhr S02 Pollutant Emission Rate Priorto Scrubber (tons SOl/yr) 612 (with process controls implemented), 95%uptime
Pollutant Removed (tons SOllyr)

- 30% removal, 95% uptime 174 30% removal, Assumes 95%control equipment uptime Cost PcrTon orPollutllnt Remond 

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