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Ash Grove Montana City BART Analysis update 

Curtis Lesslie 

to: 

Vanessa Hinkle, Christopher Ajayi 

01/19/201208:45 PM 

Cc: 

Bob Vantuyl, Tom Wood, Kasi Dubbs 

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From: Curtis Lesslie <curtis.lesslie@ashgrove.com> 

To: Vanessa Hinkle/R8/USEPA/US@EPA, Christopher Ajayi/R8/USEPA/US@EPA 

Cc: Bob Vantuyl <bob.vantuyl@ashgrove.com>, Tom Wood <trwood@stoel.com>, Kasi 

Dubbs <KDubbs@trinityconsultants.com> 

1 Attachment 

~"•••• ~1 W, iJill 

2012 01 17 DAA Cost per 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 of dry 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/hr on 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, I would like to emphasize that while we are providing a cost for OM and proposing a limit for S02 

emissions reflective of OM, we continue to maintain the position that no level of S02 reduction results in 

significant visibility improvement (since the visibility is dominated by NOx and not SOx). Since improvement to 

visibility impairment is one of the 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. 

I trust that this submittal will satisfy your needs in resolving this issue. 

Sincerely, 

Curtis 

Curtis Lesslie, PE 

Vice President Environmental Affairs 

Ash Grove Cement Company 

11011 Cody St., Overland Park, KS 66210 

P: (913) 319-6065 

M: (785) 550-6330 

WWV'!.ASt-lGRQVE&_Qrn 

file://C:\Documents and Settings\vhinkle\Local Settings\Temp\notes7A42A6\~web0312.htm 1/26/2012 
AGC Montana City
 

S02 Control Cost Effectiveness Analysis
 

Dry Lime Injection System
 

Direct Costs Notes 

Purchased EauiDment Costs 

Estimate based on 20 II Penta Engmeering Quole (20 II 

Quote) for AGC Montana City Hydrated Lime InjectIOn 

Dry Lime Injection System S151,000 system. 

Instrumentation TBD 

Freight SIIOOO 2011 Quote 

Subtotal, Purchased Equipment Cost (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 % of PEe) SI,620 EPA/452/B-02-001 (CCM) 

Truck Parkin' SIO,OOO 2011 Quote 

Subtotal, Direct Installation Cost S168,620 

Total Direct Cost S330,620 

Indirect Costs 

Engineering S40,000 2011 Quote 

Construction and Field Expense Incl 

Contractor Fees S23,000 2011 Quote 

Start-up S6,000 2011 Quote 

Perfonnance Test (\ % ofPEC) SI,620 001 B, CCM 

ContlOl!encies S82,OOO 2011 Quote 

Total Indirect Cost S152,620 

Total Capitallnvestmenl (Tel) S483,240 

Direct Annual 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% of operator) S2,053 CCM 

Subtotal, Operating Labor S15,741 

Maintenance 

Labor (0.5 hr/shift, 3 shifts/day, 365 dlyr, S25ihr) S13,688 estimate 

Material (5% of Tota! Direct Cost). Increased to account for high rate of 

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 of the Comercial i1me % 96.8 estimate 

Lime RequIred - Short Tons 1461 

Cost ($/short Ion) S 145.00 Slton delivered (Quote from Graymont) 

Subtotal, Lime S211,880 

Total Direct Annual Costs S257,839 

Indirect Annual Costs 

Overhead (60% ofsum of operating, 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 7 percent interest) S53,057 

Total Indirect Annual Cost S227,090 

Conclusion 

Total Annualized Cost S484,929 

Based on 20 I0 average emission rate of 147 Iblhr S02 

Pollutant Emission Rate Prior to 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 Pcr Ton or Pollutllnt Remond

.