October 25,2007 

Mary Jean Fenske, PE 

Minnesota Pollution Control Agency 

520 Lafayette Road N 

St. Paul, MN 55155-4194 

Cliffi Mining Company, Manager 

Hand Delivered 

Re: United Taconite Line 2 Revised BART Analysis for an S02 Wet Scrubber 

Dear Ms. Fenske: 

On September 7, 2006, United Taconite submitted to MPCA its Best Available Retrofit 

Technology (BART) analysis for NOx and S02 control on Line 1 and Line 2 indurating 

furnaces. United's cost estimate for S02 control on Line 2 was determined to be $3,361 

per ton of S02 removed. After subsequent review of the original BART analysis, United 

Taconite believes that three items were inaccurately estimated. Barr Engineering was 

directed to revisit these items and develop a revised BART cost estimate for installation 

of an S02 wet scrubber on Line 2. As a result, the revised cost estimate for additional 

S02 control on Line 2 is in excess of $9,700 per ton of S02 removed. The revised items 

are as follows: 

• Enhanced water treatment system- The original BART analysis only included 

water treatment costs for removal of particulates. MPCA water quality staff have 

expressed concern that taconite tailings basin seepage at United Taconite and 

other facilities may exceed water quality standards for dissolved solids and 

sulfates. To prevent increased concentrations of sulfate and other dissolved solids 

from accumulating in the tailings basin and process water, it was determined that 

a reverse osmosis water treatment system would be needed. 

• Economic cost of lost production on Line 2 during construction - The original 

BART analysis did not include costs for lost production on Line 2 during 

construction and tie-in of an additional S02 scrubber. United Taconite strongly 

believes that federal and state BART guidance documents support inclusion of 

these costs. These guidance documents specify that cost estimates should be 

based on the OAQPS Control Cost Manual which specifically includes the cost of 

lost production as a retrofit expense. 

• Project contingency cost- The original BART analysis used an unrealistically 

low contingency cost factor. EPA guidance for similar projects support a 30% 
contingency for projects at this stage of development: pre-design/initial feasibility 

review. 

To facilitate review of the modified cost estimate, the attached tables address only the 

revised items. United Taconite requests that MPCA review this material and include the 

Barr cover letter and updated tables as an addendum to the original BART analysis. 

Please reference the revised cost estimate when considering S02 control technology and 

limits for United Taconite Line 2. 

If you have any questions or need additional information, please contact me at 218-7 44-

7803 or at jdaagenes@cleveland-cliffs.com. 

Sincerely, 

Section Manager, Environmental Affairs 

Cc: 

Jack Tuomi 

David Cartella 

David Skolasinski 

Jim Mennen 
Barr Engineering Company 

4700 West 77th Street • Minneapolis, MN 55435-4803 

Phone: 952-832-2600 • Fax: 952-832-2601 • www.barr.comAn EEO Employer 

Minneapolis, MN • Hibbing, MN • Duluth, MN • Ann Arbor, Ml • Jefferson City, MO 

October 22, 2007 

Jason Aagenes 

Section Manager Environmental Affairs 

United Taconite 

P.O. Box 180 

Eveleth, MN 55734 

Re: Updates to the BART analysis for an S02 wet scrubber on Line 2 

Dear Jason: 

Several updates to the BART cost calculations submitted to MPCA on September 7, 2006 are required. 

We have revised the calculations to address those items (see the attached Tables 1, 2, 6, and 13). 

Each item is described below as well as the basis for the update. 

1. Water treatment costs should include removal of fluorides, sulfates, etc. from the blowdown water 

When scrubbers are used to remove S02 from the stack gases, the S02 is transferred into the scrubber 

water that is recycled to the process. Since the process water is recycled continually, over time 

constituents such as sulfate, fluoride, and dissolved solids have been shown to build up in the tailings 

basin. 

The Minnesota Department of Natural Resources (MDNR) has evaluated taconite water chemistry and 

has published a report on water treatment methods that can be used to increase S02 scrubbing and 

potential implications to process operations due to water chemistry. 1 That report confirmed that 

sulfate, fluoride, and other dissolved solids buildup in the recirculating scrubber will lead to increased 

concentrations over time. However, that report did not address water quality standards that are 

applicable at each plant. Currently the seepage water concentrations of sulfate, fluoride and other 

dissolved solids from some taconite basins, including United Taconite, are above water quality 

standards. Improving S02 scrubbing will accelerate buildup of sulfate and other dissolved solids. 

MPCA water quality staff are concerned that taconite tailings basin seepage water may cause 

exceedences of water quality standards in downstream receiving waters. MPCA expects that treatment 

of the process water will be applied as necessary to meet water quality standards in the downstream 

receiving waters. 

United Taconite scrubber water blowdown treatment design would need to reflect that some lakes 

downstream from the tailings basin are subject to the state's most restrictive sulfate water quality 

standards (i.e. those for wild rice). Such design also must address the potential for methyl mercury 

1 John Engesser, MDNR, Evaluation of Minnesota Taconite Wet Scrubbers at Minntac, Keewatin Taconite, 

Hibbing Taconite, and United Taconite, March 16, 2007 e-mail correspondence to Mary Jean Fenske. 
Mr. 1 ason Aagenes 

October 22, 2007 

2 

formation from sulfates particularly as the facility is located in the St. Louis River Basin, and the St. 

Louis River currently does not meet water quality standards for mercury. 

We developed a feasibility-level cost estimate for treating the scrubber blowdown of 552 gallons per 

minute. We assumed that the treatment level required would be the sulfate wild rice standard of 10 

mg/1. The only proven water treatment technology that can provide this level of treatment is reverse 

osmosis. The cost of reverse osmosis treatment would be $33/gallon. The cost estimate is provided in 

Table 13. 

The water treatment cost was determined to be $33 p~allon. We included this number in the BART 

calculations in Table 2, the tab named Utility Chern$ Data. 

2. The economic cost of lost production on Line 2 during construction should be included 

The cost of lost production is a real cost that the facility will incur if add-on controls are required, so 

those costs must be included in the calculations. The federal and state BART guidance supports 

including those costs. The guidance directs that, cost estimates should be based on the OAQPS 

Control Cost Manuae. One of the purposes of the Manual is to provide a consistent methodology for 

all air pollution control costing. 3 Since it was intended to apply very broadly, the OAQPS manual 

directly addresses cost considerations if a retrofit is required. 

Chapter 2 of the OAQPS Manual is dedicated to the concepts and methodology for estimating the cost 

of installing air pollution controls. According to the Manual, "The net revenue (i.e., gross revenue 

minus the direct costs of generating it) lost during this unanticipated shutdown period is a bonafide 

retrofit expense."4 Therefore, including the cost of lost production is appropriate when considering a 

retrofit such as in a BART analysis. 

The federal BART guidance cites the OAQPS Guidance as a preferred tool for evaluating retrofit cost 

calculations5

• The guidance is clear that other additional methods may be used to supplement 

calculations based on the OAQPS Cost Control Manual, but does not support omitting any cost 

elements. 

"We believe that the Control Cost Manual provides a good reference tool for cost 

calculations, but if there are elements or sources that are not addressed by the Control 

Cost Manual or there are additional cost methods that could be used, we believe that 

these could serve as useful supplemental information."6 

2 MPCA, Guidance For Facilities Conducting A BART Analysis, Attachment 2, March 2006, page 10. 

3 U.S. EPA, OAQPS, EPA Air Pollution Control Cost Manual, Sixth Edition, EPA/452/B-02--001, January 2002. 

Page 1-4. 

4 U.S. EPA, OAQPS, EPA Air Pollution Control Cost Manual, Sixth Edition, EPA/452/B-02--001, January 2002. 

Page 2-30. 

5 Notably, the BART guidance does not cite EPA's New Source Review Workshop Manual as the recommended 

tool for BART cost calculations. The focus of the NSR Workshop Manual is narrow: the PSD portion of the 

NSR Program which addresses only new and modified major sources. [U.S. EPA, New Source Review Workshop 

Manual, Draft October 1990, Page 1]. The NSR Workshop Manual recommends only that "lost production costs 

are not included in the cost estimate for a new or modified source."[U.S. EPA, New Source Review Workshop 

Manual, Draft October 1990, Page b.l1]. Line 2 is neither "new" nor "modified" within the meaning of that 

guidance; it is under consideration here only as a retrofit source. 

6 2005 Federal Register 39127. 
Mr. 1 ason Aagenes 

October 22, 2007 

3 

The shutdown time required will be dependent on the site specific circumstances and overall project 

design. A specific plan would be required for minimizing downtime as part of the project design. 

Eight weeks and possibly longer could be expected assuming foundations and other structural 

modifications would be required, fans will be replaced and commissioned, and work will be completed 

with tight space constraints and working conditions. 

Due to the numerous unknowns at this feasibility phase, we updated the BART calculations to include 

the cost of eight weeks of lost production downtime at the rate provided by United Taconite. This 

revision is shown on Table 6. 

3. A cost contingency of 30% is appropriate and should be used in the BART analysis 

As a project progresses through the design process, the estimates of project costs become progressively 

more accurate. The feasibility phase occurs prior to the conceptual design phase, where a contingency 

of 30% is appropriate. Since the feasibility phase occurs earlier in the project and fewer project details 

have been defined, use of a 30% contingency is a low estimate of project contingencies. 

EPA provides guidance for cost estimates for the power industry in the Coal Utility Environmental 

Cost (CUECost) manual7

• It references that these types of cost estimates provide an accuracy of plus 

or minus 30%. For these reasons, we updated the contingency to 30% on Table 6. 

Conclusion 

The net impact of these changes is reflected on Table 1 for the Wet Scrubber on Line 2. We did not 

update the calculations for any other technologies or Line 1. The resulting cost per ton of S02 removed 

for Line 2 is greater than $9,700. 

Please let us know if you have any questions. 

Sincerely, 

n-r~L George P. Pruchnofski, P .E. 

Vice President 

Beth T. Havlik, P.E. 

Vice President 

P:\Mpls\23 MN\69\2369A59 UTAC BART\Communications\Utac BART Report Update 10-22-0?.doc 

7 U.S. EPA, Coal Utility Environmental Cost (CUECost) Workbook User's Manual, Version 1.0, page B-13. 
Cleveland Cliffs Incorporated: United Taconite 

BART Report - <Appendix A> Emission Control Cost Analysis 

<Table 1 >: Cost Summary 

NOx Control Cost Summary 

1751.5 $44,591,384 

1598.3 $70,838,846 

7975.8 $72,298,312 

S02 Control Cost Summary 

Wet Walled Electrostatic Precipitator (WWESP) 

Line 1 Pellet Induration I 80% I 2.8 11.1 

Line 2 Pellet Induration I 80% I 549.9 2199.7 

Wet Scrubber (Additional) 

Line 1 Pellet Induration 5.5 8.3 

Line 2 Pellet Induration 1099.9 1649.8 

$22,183,231 $33,856,894 

$36,202,334 

$27,741,768 

$70,537,972 

P:\Mpls\23 MN\69\2369A59 UTAC BART\WorkFiles\UTAC control cost ss\United Taconite Control Costs (2007-10-17) 

Cost Summary 

$12,665 

$21,183 

$4,539 

$2,501,963 

$32.066 
Cleveland Cliffs Incorporated: United Taconite 

BART Report - <Appendix A> Emission Control Cost Analysis 

<Table 2>: -Summary of Utility, Chemical and Supply Costs 

Operating Unit: Line 1 Pellet Induration 

EU040 

Study Year 2006 

Emission Unit Number 

Stack/Vent Number 

Operating Unit: 

Emission Unit Number 

Stack/Vent Number 

I Line 1 furnace mmbtu 

Line 2 furnace mmbtu 

Item 

Operating Labor 

Maintenance Labor 

Electricity 

Natural Gas 

Water 

Cooling Water 

IAi 

rvvater 

Chemicals & Supplies 

Lime 

Ammonia {29% aqua.) 

Caustic 

SCR Catalyst 

Other 

Sales Tax 

Interest Rate 

Operating Information 

Annual Op. Hrs EU040 

Annual Op. Hrs EU042 

Utilization Rate 

Equipment Life 

Standardized Flow Rate 

SV046 SV048 & 049 

SV046 

Line 2 Pellet Induration 

EU042 

sv 048 & 049 

190 

400 

Unit Cost 

45.31 47.22 

0.04 

12.81 

2.07 

0.28 0.32 

a:too 

88.98 

0.12 

484.56 

141.00 

$/hr 

$/hr 

$/kwh 

$/mscf $/mgal $/mgal $/mscf 

$/mgal 

$/ton 

$/lb 

$/ton $/ft3 

6.5%% 

7.00%% 

6599 Hours 

8688 Hours 

93% 

201yrs 

Units 

308,345 scfm@ 32° F 

615,086 scfm @32° F 

Reference 

Cost 

0.23 0.25 

88.98 

0.101 

280 

Year 

2006 2006 2006 

2006 2006 

1999 1998 

2007 

2006 

2000 2003 

Data Source 

Site Specific- United Taconite. Site Specific- United Taconite. Site Specific- United Taconite. 

Site Specific- United Taconite. 

Site Specific- United Taconite. 

EPA Air Pollution Control Cost Manual, 6th 

ed. Section 3.1 Ch 1. 

EPA Air Pollution Control Cost Manual 6th Ed 

2002, Section 6 Chapter 1 . 

site Uf\lted Ta®nlte, 

EPA Air Pollution Control Cost Manual 6th Ed 

2002, Section 5 Chapter 2, page 2-50. 

United Taconite 

Cormetech, Inc. 

EPA Air Pollution Control Cost Manual 

Introduction, Chapter 2, section 2.4.2. 

BART spreadsheet. BART spreadsheet. 

Calculated. Calculated. 

P:\Mpls\23 MN\69\2369A59 UTAC BART\WorkFiles\UTAC control cost ss\United Taconite Control Costs (2007-10-17) 

Utility Chem$ Data 

Notes 

Construction Labor Rate. 

Purchased Cost. 

$12.02/MMBtu@ 1066 Btu/scf. 

Purchased Cost. 

Ch 1 Carbon Absorbers, 1999 $0.15- $

3% inflation. 

Example problem; Dried & Filtered, Ch 

inflation. 

cost to install and opwate reverse osm

Annual costs for a retrofit SCR system e

adjusted for 3% inflation. 

2006 cost 

Social (discount) rate used as a default

Maximum hours of operation 2004-2005 Maximum hours of operation 2004-2005 
Item Unit Cost 

Temperature 

SV046 129 

sv 048 & 049 121 

Moisture Content 

DegF 

Deg F 

Units 

Reference 

Cost Year Data Source 

BART spreadsheet. BART spreadsheet. 

Y:\23\69\948 United Taconite Post EERP 

SV046 13.8% 2005 Testing\Data\Waste Gas Stack. 

sv 048 & 049 13.8% 2005 Y:\23\69\872 United Tac\Data. 

Actual Flow Rate 

SV046 369,137 acfm BART spreadsheet. 

sv 048 & 049 726,000 acfm BART spreadsheet. 

Standardized Flow Rate 

SV046 330,907 scfm @68° F Calculated. 

sv 048 & 049 660,092 scfm@ 68° F Calculated. 

Dry Std Flow Rate 

SV046 285,110 dscfm @68° F Calculated. 

sv 048 & 049 568,896 dscfm@ 68° F Calculated. 

Max Emis Actual Emissions lb/hr ton/year 

Pollutant Lb/Hr Ton/year ('04&'05 Max) ppmv ppmv lb/mmbtu 

Nitrous Oxides (NOx) 

SV046 651.3 2,151.2 319 240.2 

sv 048 & 049 375.2 1,633.3 92 91.4 

SV 048 & 049 with NG only 2021.0 8,164.5 495 457.0 

Sulfur Dioxides (S02) 

SV046 4.2 13.9 1 1.1 

sv 048 & 049 632.2 2,749.7 111 110.5 

P:\Mpls\23 MN\69\2369A59 UTAC BART\WorkFiles\UTAC control cost ss\United Taconite Control Costs (2007-10-17) 

Utility Chern$ Data 

3.428070175 8.279997057 

Notes 

Weighted average. 

Average from test results in : Line 1 WG 

Weighted average from test results in: SV

Y:\23\69\872 United Tac\Data\SV048 2A

2005 plus 1 0% 

2004 plus 10% 

2004 plus 1 0% 

2004 plus 1 0% 
L 

Cleveland Cliffs Incorporated: United Taconite 

BART Report - <Appendix A> Emission Control Cost Analysis 

<Table 6>: SOx Control ·Wet Scrubber 

Operating Unit: 

n Unit Number 

ed Utilization Rate 

Expected Annual Hours of Operation 

Annual Interest Rate 

Expected Equipment Life 

CONTROL EQUIPMENT COSTS 

Capital Costs 

Direct Capital Costs (1) 

Purchased Equipment (A} Purchased Equipment Total (B) 

Installation - Standard Costs 

Installation - Site Specific Costs 

Installation Total 

Total Direct Capital Cost, DC 

Total Indirect Capital Costs, IC 

Total Capital Investment (TCI) = DC + IC 

Operating Costs 

Line 2 Pellet Induration 

EU 042 

93% 

8,6881Hours 

7.0% 

201yrs 

I 

I 

StackNent Number 

Standardized Flow Rate 

Temperature 

Moisture Content 

Actual Flow Rate 

Standardized Flow Rate 

Drv Std Flow Rate 

22% of control device cost (A) 

85% of purchased equip cost (B) 

42% of purchased equip cost (B) 

sv 048 &049 

615,086lscfm 

1211Deg F 

13.8% 

726,000iacfm 

660,092!scfm@ 68° 

5 

Total Annual Direct Operating Costs Labor, supervision, materials, replacement parts, utilities, etc. 

Total Annual Indirect OperatinQ Costs Sum indirect oper costs + capital recovery cost 

Total Annual Cost (Annualized Capital Cost+ Operating Cost' 

Emission Control Cost Calculation 

Pollutant 

Nitrous Oxides (NOx 

T/Yr 

1,633.3 

Actual 

Emissions 

% 

0% 

Con 

$/Ton Rem 

NA 

Sulfur Dioxide 2,749.7 60% 1,649.81 9,788 

Notes & Assumptions 

1 Original estimate from STS Consultants. Use 0.6 Power law factor to adjust price to stack flow rate from bid basis of 500,000 acfm. 

2 Liquid/Gas ratio 38 LIG = Gal/1 ,000 acf. 

3 Water Makeup Rate/Wastewater Discharge = 2.0% of circulating water rate. 

4 EVaporation rate calculated from steam table in Basic Principles and Calculations in Chemical Engineering Third Edition. 

5 CUECost Workbook Version 1.0, USEPA Document Page 2. 

P:\Mpls\23 MN\69\2369A59 UTAC BART\WorkFiles\UTAC control cost ss\United Taconite Control Costs (2007-10-17) 

EU042 Wet Scrubber 

5,101,881 

6,198,786 

5,268,968 

33,072,587 

5,268,968 

11,467,753 

2,603,490 

55,586,576 

10,291,311 

5,857,573 

16,148,884 
Cleveland Cliffs Incorporated: United Taconite 

BART Report • <Appendix A> Emission Control Cost Analysis 

<Table 6>: SOx Control -Wet Scrubber 

CAPITAL COSTS 

Direct Capital Costs 

Purchased Equipment (A) (1) 

Purchased Equipment Costs (A) - Absorber + packing + auxiliary equipment, EC 

Instrumentation 10% of control device cost (A) 

MN Sales Taxes 7% of control device cost (A) 

Freight 5% of control device cost (A) 

Purchased Equipment Total (B) 22% 

Installation 

Foundations & supports 

Handling & erection 

Electrical Piping 

Insulation 

Painting 

Installation Subtotal Standard Expenses 

Total Direct Capital Cost, DC 

Indirect Capital Costs 

Engineering, supervision 

Construction & field expenses 

Contractor fees 

Start-up 

Performance test 

Model Studies 

Contingencies 

Total Indirect Capital Costs, IC 

Total Capital Investment (TCI) = DC+ IC 

Retrofit multipliefi 

Sitework and foundations 

Structural steel 

Total Site Specific Costs 

Total Capital Investment (TCI) Retrofit Installed 

12% of purchased equip cost (B) 

40% of purchased equip cost (B) 

1% of purchased equip cost (B) 

30% of purchased equip cost (B) 

1% of purchased equip cost (B) 

1% of purchased equip cost (B) 

85% 

5% of purchased equip cost (B) 

0% of purchased equip cost (B) 

5% of purchased equip cost (B) 

1% of purchased equip cost (B) 

1% of purchased equip cost (B) 

NA of purchased equip cost (B) 

30% of purchased equip cost (B) 

42% of purchased equip cost (B) 

60% ofTCI 

Site Specific Site Specific 

P:\Mpls\23 MN\69\2369A59 UTAC BART\WorkFiles\UTAC control cost ss\United Taconite Control Costs (2007-10-17) 

EU042 Wet Scrubber 

5,101,881 

510,188 331,622 

255,094 

6,198,786 

743,854 

2,479,514 

61,988 

1,859,636 

61,988 61,988 

5,268,968 

11,467,753 

309,939 

0 

309,939 

61,988 61,988 

NA 

1,859,636 

2,603,490 

14,071,243 

8,442,746 

1,400,000 

4,800,000 

26,872,587 

33,072,587 

65,586,57tl 
Cleveland Cliffs Incorporated: United Taconite 

BART Report • <Appendix A> Emission Control Cost Analysis 

<Table 6>: SOx Control ·Wet Scrubber 

OPERATING COSTS 

Direct Annual Operating Costs, DC 

Operating Labor 

Operator Supervisor 

Maintenance 

37.00 $/Hr, 0.5 hr/8 hr shift, Annual Operating Hours 

15% 15% of Operator Costs 

Maintenance Labor 40.00 $/Hr, 0.5 hr/8 hr shift, Annual Operating Hours 

Maintenance Materials 100% of maintenance labor costs 

Utilities, Supplies, Replacements & Waste Management 

Electricity 0.04 $/kwh, 1,493 kW-hr, annual operating hours, 93% utilization 

Water 2.07 $/kgal, 681 gpm, annual operating hours, 93% utilization 

WW Treat Neutralization 33.00 $/kgal, 552 gpm, annual operating hours, 93% utilization 

Lime 88.98 $/ton, 6081b/hr, annual operating hours, 93% utilization 

Total Annual Direct Operating Costs 

Indirect Operating Costs 

Overhead 

Administration (2% total capital costs) 

Property tax (1% total capital costs) 

Insurance (1% total capital costs) 

Capital Recovery 

Total Annual Indirect Operating Costs 

60% of total labor and material costs 

2% of total capital costs (TCI) 

1% of total capital costs (TCI) 

1% of total capital costs (TCI) 

0.0944 for a 20- year equipment life and a 7% interest rate 

Sum indirect oper costs + capital recovery cost 

Total Annual Cost (Annualized Capital Cost+ Operating Cost) 

See Summary page for notes and assumptions 

P:\Mpls\23 MN\69\2369A59 UTAC BART\WorkFiles\UTAC control cost ss\United Taconite Control Costs {2007-10-17) 

EU042 Wet Scrubber 

Annual Cost % of Annual Cost 

24,603 0% 

3,690 0% 

25,640 0% 25,640 0% 

482,525 3% 

683,595 4% 

55% 

218,719 1% 

10,291,311 64% 

47,744 0% 

281,425 2% 

140,712 1% 140,712 1% 

$,246,980 32% 

5,857,573 36% 

16,148,884 100% 
Cleveland Cliffs Incorporated: United Taconite 

BART Report - <Appendix A> Emission Control Cost Analysis 

<Table 6>: SOx Control -Wet Scrubber 

Capital Recovery Factors 

Primary Installation 

Interest Rate 

Equipment Life 

CRF 

Replacement Catalyst: 

Equipment Life 

CRF 

7.00% 

20 years 

0.0944 

20 years 

0.0000 

o $tfe 

0 ft3 

0 Cost adjusted for freight & sales tax 

Rep part cost per unit 

Amount Required 

Packing Cost 

Installation Labor 

Total Installed Cost 

Annualized Cost 

0 Assume Labor 15% of catalyst cost (basis labor for baghouse replacement) 

0 Zero out if no replacement parts needed 

Replacement Parts & Equipment: 

Equipment Life 

CRF 

Rep part cost per unit 

Amount Required 

Total Rep Parts Cost 

Installation Labor 

Total Installed Cost 

Annualized Cost 

Electrical Use Blower, Scrubber 

Circ Pump 

H20WWDisch 

Other 

Total 

Flow acfm 

726,000 

Flow 

27,588 gpm 

681 gpm 

Reagent Use & Other Operating Costs 

0 

3 

0.3811 

0.00 $each 

0 Number 0 Cost adjusted for freight & sales tax 0 10 min per bag (13 hr total) Labor at $29.65/hr 

0 Zero out if no replacement parts needed 

0 

lJ. PIn H20 Efficiency Hp 

8.55 0.7 

LiquidSPGR lJ. Pf!H20 Efficiency Hp 

1 60 0.7 

1 60 0.7 

kW 

1,037.5 

kW 

444.5 

11.0 

1493.0 

OAQPS list replacement times from 5- 20 min per bag. 

EPA Cost Con! Manual 6th ed Section 5.2 Chapter 1 Eq 1.48 

EPA Cost Cont Manual 6th ed Section 5.2 Chapter 1 Eq 1.4f 

EPA Cost Cont Manual 6th ed Section 5.2 Chapter 1 Eq 1.49 

Caustic Use 632.17 lb/hr S02 2.50 lb NaOH/Ib S02 1580.42 lb/hr Caustic 

Lime Use Liquid/Gas ratio2 

632.17 lb/hr S02 0.96 lb Lime/lb S02 

38.0 • LIG = Gal/1 ,000 acf 

Circulating Water Rate 27,588 gpm 

Water Makeup Rate/WW Disch3 2.0% of circulating water rate + evap. loss 

Evaporation Loss4 

Slowdown = makeup - evap 

129 gpm 

552 gpm 

608.46 lb/hr lime, lime addition at 1.1 times the stoichiometric ratio 

681 gpm 

P:\Mpls\23 MN\69\2369A59 UTAC BART\WorkFiles\UTAC control cost ss\United Taconite Control Costs (2007-10-17) EU042 Wet Scrubber 
Cleveland Cliffs Incorporated: United Taconite 

BART Report • <Appendix A> Emission Control Cost Analysis 

<Table 6>: SOx Control -Wet Scrubber 

Operating Cost Calculations Annual hours of operation: 

Item 

Operating Labor 

Unit 

Cost$ 

Unit of 

Measure 

Utilization Rate: 

Use 

Rate 

Unit of 

Measure 

Op Labor 45.31 $/Hr 0.5 hr/8 hr shift 

Supervisor 15% of Op. 

Maintenance 

Maint Labor 47.22 $/Hr 0.5 hr/8 hr shift 

Maint Mtls 100 %of Maintenance Labor 

Utilities, Supplies, Replacements & Waste Management 

Electricity 0.040 $/kwh 1493.0 kW-hr 

Water 

WW Treat Neutralizatior 

Lime 

2.07 $/kgal 

33.00 $/kgal 

89.0 $/ton 

681.2 gpm 

551.8 gpm 

608.5 lb/hr 

Annual 

Use* 

543 

NA 

543 

NA 

12,063,123 

330,239 

267,482 

2,458 

8,688 

93% 

Annual 

Cost 

Comments 

24,603 $/Hr, 0.5 hr/8 hr shift, Annual Operating Hours 

3,690 15% of Operator Costs 

25,640 $/Hr, 0.5 hr/8 hr shift, Annual Operating Hours 25,640 100% of Maintenance Labor 

482,525 $/kwh, 1,493 kW-hr, annual operating hours, 93% utilization 

683,595 $/kgal, 681 gpm, annual operating hours, 93% utilization 

8,826,899 $/kgal, 552 gpm, annual operating hours, 93% utilization 

218,719 $/ton, 6081b/hr, annual operating hours, 93% utilization 

*annual use rate is in same units of measurement as the unit cost factor 

See Summary page for notes and assumptions 

P:\Mpls\23 MN\69\2369A59 UTAC BART\Workfiles\UTAC control cost ss\United Taconite Control Costs (2007-10-17) 

EU042 Wet Scrubber 
Table 13 

Cost Estimate for Reverse Osmosis System 

United Taconite Line 2 Scrubber Slowdown, 552 gpm 

Prepared By Barr Engineering Company 

Item 

Capital Costs 

Treatment 

Stage 1 Precipitation/Solids Management 

Solids Contact Tank 

Clarifier 

Soda Ash Softening Tank 

Clarifier 

Sludge Storage Tanks Sludge Dewatering Equipment 

Stage 2 Reverse Osmosis 

Ultrafiltration (pre-treatment) Reverse Osmosis 

Stage 3 Brine Management 

Soda Ash Softening Tank 

Clarifier 

Brine Evaporator 

Brine Crystallizer 

Treatment Process Accoutrements 

Concrete foundations 

Treatment Buildings 

Piping, Sch.40, 10" 

Piping, Sch.40, 4" 

Valves and Fittings 

Installation labor 

Electrical Service Installation and Controls (20% of 

Treatment Equipment Cost) 

LS $135,000 LS $1,650,000 LS $135,000 

LS $1,650,000 LS $900,000 

LS $3,000,000 

LS $1,352,000 LS $800,000 

LS $50,000 LS $100,000 LS $3,500,000 

LS $4,000,000 

Sub-total for Treatment Equipment 

CY $150 1,000 

SF $100 12,000 

LF $25 1,200 

LF $10 1,200 LS $20,000 1 

HR $50 5,000 

LS $3,454,400 

Sub-total for Pumping/Piping ,Electrical, and Controls 

Sub-Total: Capital Costs 

Contingency (30 percent of captial costs) 

Sub-Total: Capital Costs+ Contingency 

Engineering & Administration 

Pilot Testing 

Treatment Design (15% of Total Capital Cost) 

Construction Management 

Full Scale Technical Assistance and Start-Up 

Sub-total: Engineering & Administration 

TOTAL: Capital Engineering & Administration 

LS LS 

MO 

LS 

$500,000 

$3,358,000 

$35,000 

$55,000 

1 

1 

4 

1 

$135,000 30 min. HRT, Liquid:Solid = 1:1 

$1,650,000 EPA, 1976, adjusted to July 2007 

$135,000 30 min. HRT 

$1,650,000 EPA, 1976, adjusted to July 2007 

$900,000 7 days' storage@ $1 per gallon, 

$3,000,000 EPA, 1976, adjusted to July 2007, 

$1,352,000 0.8 MGD@ $1.69 per gpd 

$800,000 0.8 MGD@ $1.00pergpd 

$50,000 

$100,000 

Basis 

for Cost Estimate 

$3,500,000 Vendor quote, 100 gpm brine flow rate, 80 percent volum

$4,000,000 Vendor quote, falling film dryer, dry to solid crystals 

$17,272,000 

$150,000 Means, Previous Project Experience 

$1 ,200,000 Means, Previous Project Experience 

$30,000 Means, Previous Project Experience $12,000 Means, Previous Project Experience 

$20,000 Previous Project Experience 

$250,000 Assume 10 person Crew for 12 Weeks 

$3,454,400 Previous Project Experience $5,116,400 

$22,388,000 

$6,716,400 

$29,104,400 

$500,000 Previous 

$3,358,000 Previous 

$140,000 Previous 

---,...,..;$;.;;5;;:;5.:.:;,0;.;0.;..0 Previous 

$4,053,000 

$33157 400 

Experience Experience Experience ( Approx 100 Hrs/month) 

Experience 
Operating Costs 

Project Management 

Operating Labor (assumes 2 person years) 

Pumping 0 & M 

Ultrafiltration Unit O&M 

Reverse Osmosis O&M 

Electrical Costs-Pumps (-200 HP average over the year) 

Energy Costs-Evaporators 

Chemical Usage-Soda Ash 

Chemical Usage-Sulfuric Acid 

Sludge Landfilling (Including Trucking) Salt Landfilling (including trucking) 

TOTAL: Operating Costs 

LS 

HR 

LS 

1000 GAL 

1000 GAL 

KW-HR 

gallon 

Ton Ton 

Ton Ton 

$10,000 1 

$50 4,000 

$10,000 1 

$0.50 435,197 

$1.20 435,197 

$0.04 1,307,000 

$0.07 55,188,000 

$269 346 $100 353 

$35 37,823 $35 12,632 

$10,000 

$200,000 

$10,000 

$217,600 $522,200 

$52,300 

$3,863,200 

$93,000 

$35,300 

$1,323,809 

$442,105 

$6,327,409 

Capital Recovery 

Previous Project Experience Previous Project Experience Previous Project Experience ( Approx 200 Hrs/month) 

Vendor Estimate Vendor Estimate 

$0.04 per KWH, 200 HP average annual usage 

Vendor Estimate 

CaS04 and CaC03 20 percent solids, nonhazardous loc

95 percent salt solids, Na2S04, nonhazardous, local tra

I Capital Recovery - --- $3,13o;OOOJCRF = 0.0944,20 years@ 7 percent interesl 

Operating Cost $6,327,0001 

Total Anllual Cost (Annualized Capital Cost +-Operating Cost $9,5gooo1 

,- Total ---·--- $331 

References: 

EPA Areawide Assement Procedures Manual: Performance and Cost, EPA, 1976