TECHNICAL MEMORANDUM

TO : Tina Ndoh , U

. S

. EPA/OAQPS/SPPD

- Minerals and Manufacturing Group

FROM : Eastern Research Group, Inc.

DATE : June 2 , 2014

SUBJECT : Control Cost s and Emission s Reductions for Phosphoric Acid and Phosphate Fertilizer Production Source Categories

The U.S. Environmental Protection Agency (EPA), under section 112 of the Clean Air Act (CAA), is required to establish maximum achievable control technology (MACT) stand ards for phosphoric acid manufacturing plants (40 CFR part 63, subpart AA) and phosphate fertilizer production plants (40 CFR part 63, subpart BB) source categories. This memorandum documents
the control costs and emissions reduction s associated with propo sed subpart s AA and BB . The following is an outline of the memorandum:
1.0 Introduction
2.0 Control Costs for Proposed Limits
2.1 Beyond

- the

- Floor Mercury Limit for Phosphate Rock Calciners
2.2 Hydrogen Fluoride Limit Applicability for Oxidation Reactors
, Defluorination Processes , and Clarifiers
3.0 Testing and Monitoring Costs
4 .0 References

1.0 INTRODUCTION As part of the risk and technology review required under section 112 of the Clean Air Act, MACT and beyond

- the

- floor ( BTF ) limits were calculated for m ercury (Hg) from phosphate rock calciners regulated under subpart AA. 1 It was determined that the one facility currently operating phosphate rock calciners would likely be required to install controls in order to comply
with the calculated limits. EPA also determined that clarification of the applicability requirements for subp art AA and BB was necessary

. As a result of the clarifications, it was assumed that one facility would be required to route previously uncontrolled emissions to an existing control device. This memorandum describe s the methodologies for estimating costs an d
the associated emissions reductions as a result of facilities complying with the proposed emission

1limits and clarifications

. C ost estimates for the revised testing and monitoring requirements included in the proposed rule are also provided

. The followi ng assumptions were applied throughout this analysis . For all cost estimates
, an annual operating time of 8,760 hours was used to determine the maximum cost a facility
would incur. For most equipment installations, an e quipment life of 20 years and a 7 per cent discount rate was used to calculate capital recovery factors ( C RF )

. All facilities were assumed to have adequate space to install additional emissions control equipment
, and installation would not cause a production loss and could be completed during a routine maintenance outage

. All costs

are presented in 201 3 dollars. For the cost analyses, only currently operating sources were
considered as n o new facilities are anticipated to be built in the near future.

2.0 CONTROL COSTS FOR PROPOSED LIMITS

2.1 Beyond

- the

- Floor Mercury Limit for Phosphate Rock Calciners
A BTF limit for Hg is proposed for phosphate rock calciners. I n order to meet this BTF limit, three methods of control were evaluated : install ation of a fixed

- bed (FB) carbon adsorption system , installation of an activated carbon injection (ACI) system prior to an existing wet electrostatic precipitator (WESP) , and installation of ACI followed by a fabric filter to collect the
carbon. Two variations on the application of ACI were evaluated for th e phosphate rock calciners because the moisture content of the stack gas (approximately 30 percent ) may be too high to effectively use a fabric filter. Fabric filters are known to plug excessively when used in a high moisture application. Carbon adsorpti on in a FB with pelletized carbon was chosen for this particular application based on information available from industrial applications

. 2
, 3 Because a WESP is currently installed after each of the six phosphate rock calciners, the option to use ACI ahead of
the WESP was also evaluated. Although there are no known applications with this combination of controls, there is control effectiveness information available for ACI followed by an electrostatic precipitator, 2
, 4 therefore
, this may be a potential control option for the calciners. F or this analysis
, w e assumed the currently installed WESP s ha ve the capacity to capture the additional particulate created by the ACI, however data are not available to support this assumption. Additionally, i nstallatio n of a fabric filter after ACI was evaluated so that a representative range of control and cost options were considered

.

2To comply with the BTF limit, Hg emissions from t he six phosphate rock calciners would
need to be reduced by 86 percent . The associated emissions reductions and cost effectiveness were calculated based on the control technologies achieving an 86 percent reduction

. The full
BTF cost calculation methodology is presented in a separate memorandum
, 1 a summary is provide d in Tab le 2.1

.

Table 2.1. Costs and emissions reduction for complying with the BTF Hg limit for phosphate rock calciners.

BTF Scenario Total Capital Investment (TCI) Total Annual Cost (TAC) Hg Emissions Reduction

( lbs /yr) a Cost Effectiveness

($/lb of Hg R emoved) FB Carbon Adsorption $ 4, 9 00 ,000 $ 1,200,000 145 $ 8,0 00 ACI (using e xisting WESP ) $ 6,500,000 $ 1,800,000 145 $ 12,100 ACI with Fabric Filter $ 16,5 00,000 $ 2,5 00,000 145 $ 17,1 00 Notes: (a) Mercury reductions are based upon test results using US EPA Method 30B.

2.2 Hydrogen Fluoride Limit Applicability for Oxidation Reactors
, Defluorination Processes
, and Clarifiers
Wet

- process phosphoric acid ( WPPA ) and superphosphoric acid ( SPA ) process line
definitions were revised to specify that emissions from oxidation reactors
, d efluorination

processes , and clarifiers must be included when determining compliance with hydrogen fluoride (HF) limits

. Some facilities were not previously includin g emissions from these emission sources, as was the intention of subpart AA. The cost impact and emissions reduction associated with the subpart AA applicability clarifications w ere evaluated. Oxidation reactors are used to remove organics by mixing SPA wi th nitric acid, ammonium nitrate, or potassium permanganate. Oxidation is used in the production of SPA at
four facilities. The inclusion of emissions from oxidation reactors was evaluated to determine if facilities currently using oxidation would meet the proposed HF limit for SPA process lines.
Based on the available HF data, three of the facilit ies were below the HF limit when the emissions associated with oxidation reactors were added to emissions of applicable equipment (e.g., evaporators) at SPA lines. In certain instances, facilities already duct oxidation reactor emissions through a common SPA emission point and thus oxidation reactor emissions would have been included in past performance tests. However, the oxidation reactor at Agrium Nu

3West (EP

- 541) is not controlled and according to HF data in 2014, the combined emissions from the SPA emission point (EP

- 522) a nd EP

- 541 would exceed the HF limit. Agrium Nu

- West’s SPA process line was examined to determine their potential control options. One option would be to install a new wet scrubber to control emissions from the oxidation reactor (EP

- 541). However, t he volu metric flow rate for EP

- 541 varies from about 600

to 1,300 acfm and EP

- 522
, which is currently controlled by a wet scrubber
, has a volumetric
flow rate of 6,500 to 9,500 acfm. Therefore, a second option is to duct the oxidation reactor
emissions to the exi sting wet scrubber for EP

- 522. The combined volumetric flow rate would not change significantly and it is expected the existing wet scrubber would be able to control emissions from both emission points without modification. The Agrium Nu

- West SPA plot plan
was reviewed to determine if EP

- 522 and EP

- 541 were in close enough proximity to make this a practical option. Each emission point was identified on the plot plan and, using Google Earth, it was estimated that approximately 400 feet of ductwork would be n ecessary. This distance and the arrangement of the emission points suggested this option was feasible. To duct the oxidation reactor emissions to the existing wet scrubber, costs were estimated for ductwork, a blower, and electricity. Ductwork costs were e stimated using algorithms from the
EPA Air Pollution Control Cost Manua l , see Attachment A for details

. 6 The cost to move the gas exhaust using a blower was estimated from data available in Plant Design and Economics for Chemical Engineers

. Using the max imum flow rate of 1,300 acfm, a purchased cost of $13,000 (in $2002) was extrapolated for a turbo blower with 3 psi max discharge. 7 Electricity costs were calculated using equation 2.10 in the EPA Air Pollution Control Cost Manua l
, 8 presented as equation 1

.

η θ

* 6356 * * * * * 746

. 0
e p s P Q yCost Electricit ∆

= (Eqn. 1)

Where: Q = Gas flow rate (acfm) Δ P = Pressure drop (inches of water)

s = Specific gravity of gas (1,000) θ = Operating hours (8,760) p e = electricity cost (0.0682 $/kW

- hr) η = Efficiency (0.6)

4The pressure drop through the ductwork (Δ P) was estimated as part of the ductwork cost methodology, and equaled 0.36 pounds per square inch (psi) . For purposes of estimating electricity cost, the pressure drop was multipl i ed by 2 to provide ample margin

. T he costs for ductwork, the blower, and electricity are summarized in Table 2.2.

Table 2. 2

. Oxidation reactor c osts and emissions reduction for installing ductwork to an existing wet scrubber

. Item Total Capital Investment (TCI) Total Annual Cost ( TAC ) Ductwork $ 5,000 $470 Blower $18,6 00 $1, 800 Electricity for Blower N/A $3 50 Total $23,6 00 $2, 620

Emissions reductions for the Agrium Nu

- West SPA process line were also determined. The emissions data for the SPA process line at Agrium Nu

- West are presented in Table 2. 3 . In order to meet the proposed HF limit of 0.011 pounds of HF per ton of feed, expressed as phosphorus pentoxide ( lb/ton P 2 O 5 feed ) , HF emissions for EP

- 541 would need to be reduced by
55 percent

. Based on information provided by Agr ium Nu

- West, t he existing wet scrubber for
EP

- 522 achieves a fluoride removal efficiency greater than 90 percent , so reducing emissions by
55 percent would be technically feasible.

Table 2. 3

. Agrium Nu

- West SPA process line emissions data.

Facility EP HF Emissions

(lb/yr) HF Emission Rate (lb/ton P 2 O 5 feed) % Reduction to Meet HF Limit HF Emissions Reduction

(lb/yr)

Agrium Nu

- West SPA (EP

- 522) 1,093 0.0037 0% 0 SPA (EP

- 541) 4,826 0.0162 55% 2,6 60
Combined 5,919 0.0199 2,6 60

At least two facilities defluorinate phosphoric acid using diatomaceous earth. The inclusion of emissions from phosphoric acid defluorination processes were evaluated to determine if facilities currently using defluorination processes would meet the proposed HF limit for their pr ocess lines. Based on the HF data available, in each instance the facility ’s process line
emissions were below the HF limit when the emissions associated with defluorination processes

5were added to emissions of applicable equipment. Therefore, no additiona l control costs were estimated for defluorination processes. Several phosphoric acid manufacturing facilities employ clarifiers as an additional separation step. The clarifiers are typically intertwined with the flow of phosphoric acid as it is

concentrat ed with evaporators. All facilities include emissions from clarifiers in the emission points they currently test for compliance , except for two facilities. Based on the HF data available, the two facilities would meet the proposed HF limit when emissions f rom clarifier s were included in their process line emissions. Therefore, no additional control costs were
estimated for inclusion of clarifier emissions

.

3.0 TESTING AND MONITORING COSTS The proposed subparts AA and BB require that facilities comply with an HF emission
limit instead of a TF emission limit. As a result, the increase in testing costs for Method 320 ($15,000) versus Method 13B ($ 7,000 ) was calculated. Method 320 will cost facilities an additional $ 8 ,000 for each emission point tested.
WPPA and SPA process line definition s were clarified to specify that emissions from
oxidation reactors
, defluorination processes , and clarifiers must be included when determining compliance. There are eight known emission points for oxidation reactor s , defluorinati on
proce ss e s , and clarifier s that would incur an additional cost. The full Method 320 cost of $15,000
was included for these eight emission points. A mercury limit was proposed in subpart AA for phosphate rock calciners. Costs were
estimated to perform ann ual Hg testing for the six phosphate rock calciners in operation. It was also assumed that one of the phosphate rock calciners would perform semi

- annual Hg tests to
determine carbon bed life. The cost estimates reflect the cost to perform Method 30B ($6,40 0 per
test ) for Hg . The annual testing costs by emission source for HF and Hg are show n in Table 3. 1

.

6Table 3. 1 . Summary of testing costs to perform Methods 320 and 30B

.
Emission Source Total Annual Cost ( TAC ) ($/yr) Phosphate Rock Calciners $ 44,800 Oxidation Reactor s , Defluorination Units , and Clarifier s $ 120,000
Incremental Method 320 Cost $6 24 ,000 TOTAL $7 88 ,800

Control device monitoring costs were also evaluated. Costs were estimated for monitoring to comply with the proposed Hg limits for phosphate rock calciners in subpart AA ; costs related to phosphate rock calciners were developed for the case where a FB carbon adsorption system was installed. The FB carbon adsorption beds do not require parametric monitoring; however the life of the bed must be established with semi

- annual testing for three bed change

- outs on one representative bed. Therefore, stack testing will be required on one of
the calciners two times a year for at least the first three years. This cost is included in the

summary c osts in Table 3. 1

. No capital or annual costs for parametric monitoring of Hg control equipment were estimated

. Additionally, no parametric monitoring costs were estimated due to
inclusion of oxidation reactors
, defluorination processes , and clarifiers when complying with HF
limits. Performance evaluations of control device monitoring equipment are a proposed requirement for all facilities. An annual labor cost for completing the calibration requirements
for scrubbers were estimated at seven hours per facility; this labor is included Table 3.2. Recordkeeping and reporting costs were developed based on rule requirements. This includes report preparation and recordkeeping of monitoring and test data. Changes are proposed for the monitoring section of sub parts AA and BB that require development of a monitoring plan. Subpart AA also proposes the development of a gypsum dewatering stack and cooling pond management plan. Recordkeeping and reporting annual costs will be the highest in the first year
as initial costs will be incurred for reading the rule and developing the monitoring and management plan s , and all subsequent years will have a lower annual cost. The annual costs for recordkeeping and reporting are presented in Table 3.2. See the Supporting Stateme nt and burden tables for details on calculating testing, monitoring, recordkeeping, and reporting costs. 5

7Table 3. 2 . Summary of annual recordkeeping and reporting costs

. Annual costs are presented for the first year of compliance and subsequent years.
Cost for First Year of Compliance Annual Cost for Subsequent Years ($/yr) $ 165
, 0 00 $ 6 6 , 200

84.0 REFERENCES

1. Eastern Research Group, Inc. “ Beyond

- the

- Floor Analysis for Phosphate Rock Calciners

at Phosphoric Acid Manufacturing Plants

. ” Docket ID: EPA

- HQ

- OAR

- 2012

- 0522

. May
2014

. 2. EPA. “ Mercury Study Report to Congress, Volume III: An Evaluation of Mercury Control Technologies and Costs (EPA

- 452/R

- 97

- 010). ” December 1997.
3. Parsons Infrastructure and Technology Group Inc; prepared for U.S. DOE, National Energy Technology Laboratory. “ The Cost of Mercury Removal in an IGCC Plant. ” September 2002.
4. Jones, A., Hoffmann , J., Smith, D., Feeley III, T., Murphy, J.; prepared for U.S. DOE, Office of Fossil Energy, National Energy Technology Laboratory. “ DOE/NETL’ s Phase II Mercury Control Technology Field Testing Program, Updated Economic Analysis of Activated Carbon Injection. ” May 2007.
5. Eastern Research Group, Inc. “ Supporting Statement for Phosphoric Acid and Phosphate
Fertilizers NESHAPs. ” Docket ID: EPA

- HQ

- OAR

- 2012

- 0522

. September 2014

. 6. U.S. Environmental Protection Agency. “ EPA Control Cost Manual. Section 2 : Generic Equipment and Devices, Chapter 1: Hoods, Ductwork, and Stacks
, ” December 1995

. Publication Number EPA/452/B

- 02

- 001.
7. Peters, Timmerhaus, and West. Plant Design and Economics for Chemical Engineers

. Fifth Edition. Figure 12

- 32, page 533. 2003.
8. U.S. Environmental Protection Agency. “ EPA Control Cost Manual. Section 1 : Introduction, Chapter 2 : Cost Estimation Concepts and Methodology ”

. Janua ry 2002

. Publication Number EPA/452/B

- 02

- 001.

9

## Attachment AA-1: Ductwork Cost AlgorithmParameter/CostVariableEquation/Value1. Ductwork Inputsa. Exhaust Flowrate (acfm) FL Value specific to facilityb. ut (ft/min) ut 3500c. Number of 90 Degree ElbowsElb90 5d. k Value for 90 Degree Elbows k90 0.33e. Number of 45 Degree Elbows Elb45 5f. k Value for 45 Degree Elbowsk45 0.165g. Material Factor, Galvanized Carbon Steel a1 0.322h. Material Factor, Galvanized Carbon Steel b1 1.22i. Material Factor, Galvanized Carbon Steel a2 30.4j. Material Factor, Galvanized Carbon Steel b2 0.0594k. Material Factor, Galvanized Carbon Steel a3 45.5l. Material Factor, Galvanized Carbon Steel b3 0.0597m. Number of Dampers Damp 4n. Length of Duct (ft) LDuct 400o. Exhaust Flowrate (acfm) FL Value specific to facilityp. Capital Recovery Factor (20 yrs, 7%) CRF= (0.07*(1+0.07)^20)/((1+0.07)^20-1) = 0.094392. Cost Index Values (CEPCI)a. 1998 CEPCI 98CEPCI 389.5b. 2013 CEPCI 13CEPCI567.33. Ductwork Capital Costa. Duct Diameter (ft)Diam_ft =1.128 * (FL / ut)^0.5b. Duct Diamter (in) Diam_in = Diam_ft * 12c. Friction Losses (in H2O) Fd= 0.136 * (1 / Diam_ft)^1.18 * (ut / 1000)^1.8 * Lduct / 100d. Velocity Pressure (in H2O) VP = (ut / 4016)^2e. Friction Loss from Elbows (in H2O) Fc = Elb90 * k90 * VP + Elb45 * k45 * VPf. Total Friction, Static Pressure Ft = Fd + Fcg. Straight Duct Cost, Galvanized CostStrDu = a1 * (Diam_in^b1) * LDucth. Elbow Cost CostElb = a2 * exp(b2 * Diam_in) * (Elb90 + Elb45)i. Damper Cost CostDamp = a3 * exp(b3 * Diam_in) * Dampj. Material Duct Cost CostMat = CostStrDu + CostElb +CostDampk. Total Material Duct Cost CostTotMat = CostMat * V#l. Duct Installation Cost CostInstDu = 0.375 * CostTotMatm. Total Material and Installation CostDuct = (CostTotMat + CostInstDu) * (13CEPCI / 98CEPCI)4. Ductwork Annual Costa. Annual Cost CostDuctAn = CostDuct * CRFA-2: Ductworks Costs for SPA Process Line EmissionsFacilityEmissionPointFlow Rate(ft3/min)Number ofductsDuct diam.(ft)Duct diam.(in)Length ofDuct (ft)Frictionlosses, Fd(in H2O)velocitypressure,VP (in H2O)Fc, frictionloss fromelbows (inH2O)TotalFriction(=StaticPressure) =Fd+FcAgrium Nu-West SPA, EP-541 1,300 1 0.69 8.25 400 8.07 0.76 1.88 9.95FacilityEmissionPointTotalStraight ductcost,galvanizedTotalElbowcostTotalDampercostTotalDuctworkMaterialCostDuctInstallation CostMaterial +Installationcost(TOTAL)2013Material +Installationcost(TOTAL)2013 AnnualCostAgrium Nu-West SPA, EP-541 $1,690 $496 $298 $2,484 $932 $3,416 $4,975 $470DUCTWORK COSTSDUCTWORK COSTS