March 26 , 2013

MEMORANDUM

SUBJECT: Meeting N otes for the March 14 , 201 3 meeting with AF&PA and NCASI

FROM: Kelley Spence (EPA/OAR/OAQPS/SPPD/NRG)

TO: Docket EPA

- HQ

- OAR

- 2012

- 0640

This memorandum summarizes the meeting between t he American Forest and Paper Association

(AF&PA)

, National Council for Air and Stream Improvement (NCASI)

, member company

representatives, and the U.S. Environmental Protection Agency ( EPA ) on March 14 , 2013 . The purpose

of the meeting was to provide an update on the status of EPA activities on the K raft P ulp Mills New

Source Performance Standards (NSPS) review and the Pulp and Paper Combustion Sources National

Emissions Standards for Hazardous Air Pollutants ( NESHAP ) (subpart MM) residual risk and technology

review (RTR)

, and to discuss any outstanding issues

.

Meeting Attendees:

Corey Brandt

– RockTenn

Mike Curtis

– Georgia Pacific

Annabeth Reitter

– Domtar

Jeff Shumaker

– International Paper

Jim Taylor

– MeadWestvaco

Tim Hunt

– AF&PA/AWC

Ashok Jain

- NCASI

John Pinkerton

– NCASI

Amy Marshall

– URS

John Bradfield

– EPA/SPPD

Kelley Spence

– EPA/SPPD

Nick Swanson

– EPA/SPPD

Katie Hanks

– RTI

### 2 Discussion Points:

Industry representatives discussed smelt dissolving tank (SDT) and lime kiln cost methodology and

resulting cost effectiveness values. Industry estimated that SDT cost effectiveness values for PM removal

would u p to $60,000 per ton of PM removed for modified units that would not have installed new

scrubbers in the absence of the revised NSPS but would need a new scrubber to meet a lower NSPS limit

. For lime kilns, the industry representatives estimated that the cost would extend up to $20,000 per ton of

PM removed for modified lime kilns that would need to install an ESP in front of a wet scrubber in order

to meet a lower NSPS PM limit

. AF&PA provide d documentation of the costs and methodology used as a

follow

- up to the meeting (see Attachment A)

.

Monitoring for TRS on lime kilns and recovery furnaces was discussed. One issue was raised

regarding the span of 30 ppm for TRS monitors; it was suggested that values above the span are estimates

and not quantitative emission readings. Facilities do not calibrate above 30 ppm, and higher values are

considered an exceedance but not a violation. This is not currently an issue because the monitoring

allowance does not have a cap

. Oxygen correction issues during startup and shutdown for TRS correction

were also discussed

.

Scrubber and ESP combinations for pollution control on lime kilns were discussed. It was indicated

that in the combination systems, scrubbers are typically used for SO 2 control and operate at near

atmospheric pressure. The monitoring parameters for these scrubbers are generally only liquid flow rate

(or liquid supply pressure), and pressure drop is not usually monitored.

Incinerator temperature monitoring was discussed as it relates to subpart S compliance. Industry

repres entatives suggest that a 3

- hour averaging period is used to demonstrate compliance for subpart S

(the average of three 1

- hour test runs). Facilities also have received site

- specific approval to demonstrate

compliance at lower temperatures than the 1600 o F required by the subpart.

Regarding subpart MM, an EPA representative discussed the review of dioxin data and acrolein

emissions estimates in preparation for risk modeling. NCASI agreed to send dioxin/furan test data from

Technical Bulletin 973 which shows the development of dioxin/furan emission factors.

### Attachment A

AF&PA Analysis of Cost Impacts of Lowering the NSPS Subpart BB PM Emission Limits

for Smelt Tanks and Lime Kilns1 March 29, 2013 AF&PA Analysis of Cost Impacts of Lowering the NSPS Subpart BB PM Emission Limits for Smelt Tanks

and Lime Kilns

The Kraft pulping NSPS (40 CFR 60, Subpart BB) currently contains PM emission limits for the chemical

recovery sources that are also covered by pulp and paper MACT II (40 CFR 63, Subpart MM): Recovery

furnaces, lime kilns, and smelt tanks. EPA is considering lowering the Subpart BB PM emission limits for

new and modified smelt tanks and lime kilns. AF&PA has used information provided by EPA, knowledge

of industry practices, and previous control cost studies specific to the pulp and paper industry to

estimate the feasibility and impacts of lowering these limits. Our analysis indicates that it is not feasible

to lower the TRS emission limits and it is not cost effective to lower the PM emission limits.

Smelt Tank Analysis

It is important to understand that smelt tanks are regulated differently under NSPS and MACT. A smelt

tank becomes subject to the NSPS upon construction, reconstruction, or modification. The NSPS PM

limit is 0.2 lb/TBLS and the TRS limit is 0.033 lb/TBLS, and these limits apply to both new/reconstructed

and modified sources. The MACT PM limit for existing smelt tanks is 0.2 lb/TBLS and the MACT PM limit

for new smelt tanks is 0.12 lb/TBLS. However, under the MACT, the recovery furnace and its associated

smelt tank are the affected source, so if a facility replaces a smelt tank but not the associated recovery

furnace, the replacement smelt tank is not a new source under the MACT but is a new source under

NSPS BB. Due to this difference in the definition of affected source, there is a cost associated with

lowering the NSPS PM limit for modified and reconstructed smelt tanks to the level of the new source

MACT limit.

Emissions from smelt tanks are typically controlled by some type of wet scrubber. The systems used

range from simple water sprays with mesh pads to wet fan impingement scrubbers to venturi scrubbers,

and the control efficiencies vary from unit to unit. Impacts of lowering the PM limit can be examined

using various scenarios. The cost effectiveness of additional smelt tank controls will depend on the

unit’s size, existing emission rate, future NSPS limit, and performance of existing control equipment.

Modified or reconstructed units may have controls that would not need to be replaced at the current

NSPS level, but may need replacement in order to meet a lower NSPS level.

Scenario 1: A facility performs a project that is considered a modification or reconstruction and triggers

NSPS applicability for a smelt tank. The smelt tank is equipped with a scrubber that complies with a 0.2

lb/TBLS PM limit but would not comply with a lower limit such as 0.15 or 0.12 lb/TBLS. In the current

case, the scrubber would not be replaced. In a future case where the NSPS limit was lowered, the

scrubber would have to be replaced. Therefore, the cost of lowering the NSPS is the cost of a new

scrubber. The table below presents example calculations of cost effectiveness for 2 sizes of smelt tanks

and 2 levels of NSPS revision assuming the modified smelt tank’s current emissions are 0.18 lb/TBLS.

Note that the annual cost only reflects the annualized capital cost of a new scrubber and assumes the

operating costs would be the same to simplify the analysis.2 March 29, 2013 Scenario Throughput Current

Emission Rate Future

Emission Rate PM

reduced,

tpy Annual

Cost $/ton

1a. Small SDT,

NSPS to 0.15 40 TBLS/hr 0.18 lb/TBLS 0.15 lb/TBLS 5.26 $313,828 $59,708

1b. Small SDT,

NSPS to 0.12 40 TBLS/hr 0.18 lb/TBLS 0.12 lb/TBLS 10.51 $313,828 $29,854

1c. Large SDT,

NSPS to 0.15 70 TBLS/hr 0.18 lb/TBLS 0.15 lb/TBLS 9.20 $439,050 $47,733

1d. Large SDT,

NSPS to 0.12 70 TBLS/hr 0.18 lb/TBLS 0.12 lb/TBLS 18.40 $439,050 $23,867

Scenario 2: A facility performs a project that is considered a modification or reconstruction and triggers

NSPS applicability for a smelt tank. The current smelt tank scrubber either cannot meet the current 0.2

lb/TBLS limit, or it is in need of replacement, so the facility needs to install a new scrubber as part of the

project. The impact of reducing the NSPS limit is the difference between the cost of the scrubber that

will achieve compliance with 0.2 lb/TBLS and the cost of the scrubber that will achieve compliance with

a lower level like 0.12 lb/TBLS. For purposes of costing, we have compared the “good” and “best”

scrubbers in the September 2001 Emission Control Study prepared by BE&K Engineering for AF&PA, with

appropriate updates to 2012 dollars and scaling for size. Note that this scenario would be much less

likely to occur, as a facility would be more likely to upgrade newer equipment that already complies

with the NSPS limit rather than older equipment that does not. However, we have included this

scenario for completeness as EPA has indicated that they are examining this type of scenario.

Scenario Throughput Current NSPS

Emission Rate Future NSPS

Emission Rate PM

reduced,

tpy Annual

Cost $/ton

2a. Small SDT,

NSPS to 0.15 40 TBLS/hr 0.2 lb/TBLS 0.15 lb/TBLS 8.76 $20,204 $2,306

2b. Small SDT,

NSPS to 0.12 40 TBLS/hr 0.2 lb/TBLS 0.12 lb/TBLS 14.02 $20,204 $1,441

2c. Large SDT,

NSPS to 0.15 70 TBLS/hr 0.2 lb/TBLS 0.15 lb/TBLS 15.33 $28,394 $1,852

2d. Large SDT,

NSPS to 0.12 70 TBLS/hr 0.2 lb/TBLS 0.12 lb/TBLS 24.53 $28,394 $1,158

Scenario 3. A facility installs a new smelt tank to replace an existing smelt tank or reconstructs the

smelt tank. New source MACT is not triggered because the facility is not replacing or reconstructing the

recovery furnace. If the smelt tank needs a new scrubber as part of the project, the cost is the same as

Scenario 2 if the NSPS limit is lowered. If the smelt tank doesn't need a replacement scrubber as part of

the project, the cost is the same as Scenario 1 if the NSPS limit is lowered.3 March 29, 2013 Scenario 4. A facility constructs a new smelt tank and recovery furnace. The new smelt tank is subject

to new source MACT so changing the NSPS to new source MACT level does not have any associated cost.

Under Scenario 1, the cost of lowering the NSPS PM limit is very high, and none of the examples

evaluated show that additional control is cost effective. Scenario 2 has costs in the low thousands of

dollars per ton if a facility were to need a new smelt tank scrubber under the existing NSPS PM limit. An

examination of the ICR summary data provided by EPA to AF&PA and the data in NCASI Technical

Bulletin 884 indicates that median smelt tank PM emissions are around 0.15 lb/TBLS. Therefore, if most

units can meet the current NSPS limit of 0.2 lb/TBLS, Scenario 1 is much more likely to occur than

Scenario 2.

EPA has estimated that 6 smelt tanks will be modified over the next 10 years. If we assume

conservatively that 3 of them fall under Scenario 1 and 3 of them fall under Scenario 2, the following

table shows two example total cost and total cost effectiveness evaluations, depending on which

subsets of Scenarios 1 and 2 are selected.

Example 1 (large units

controlled to 0.12 lb/TBLS) annual cost tons

reduced $/ton

3 units under scenario 1d $1,317,150 55.2 $23,867

3 units under scenario 2d $85,181 73.6 $1,158

Total $1,402,331 128.8 $10,890

Example 2 (small units

controlled to 0.15 lb/TBLS) annual cost tons

reduced $/ton

3 units under scenario 1a $941,483 15.8 $59,708

3 units under scenario 2a $60,611 26.3 $2,306

Total $1,002,094 42.0 $23,832

In either example, the total cost effectiveness is greater than $10,000/ton, which demonstrates that

lowering the smelt tank NSPS PM limit is not cost effective.

Lime Kilns Analysis

A lime kiln becomes subject to NSPS BB upon construction, reconstruction, or modification. The NSPS

PM limit is 0.066 gr/dscf for kilns burning natural gas (or a mixture of gas and oil) and 0.13 gr/dscf for

kilns burning oil. The TRS limit is 8 ppmvd at 10% O 2 , and these limits apply to both new/reconstructed

and modified sources. The MACT PM limit for existing lime kilns is 0.064 gr/dscf and the MACT PM limit

for new lime kilns is 0.01 gr/dscf. We understand that EPA will likely eliminate the separate oil

‐ fired kiln

PM limit and establish a PM limit that is not fuel specific.

Emissions from lime kilns are controlled by either wet scrubbers, ESPs, or both. The wet scrubber

provides both PM and TRS control (and additional SO2 control if the kiln is burning NCGs or SOGs), while

the ESP provides a lower level of PM control than a wet scrubber. Kilns with both controls have the

lowest PM emissions, and an ESP is needed to achieve the MACT new source PM limit and would be4 March 29, 2013 needed for an equivalent NSPS limit. Impacts of lowering the PM limit can be examined using various

scenarios. The cost effectiveness of additional controls will depend on the unit’s size, existing emission

rate, future NSPS limit, and performance of existing control equipment. Modified or reconstructed units

may have controls that would not need to be replaced at the current NSPS level, but may need

replacement in order to meet a lower NSPS level.

Scenario 1: A facility performs a project that is considered a modification and triggers NSPS applicability

for a lime kiln. The kiln is equipped with a scrubber that complies with a 0.066 gr/dscf PM limit but

would not comply with a lower NSPS limit such as 0.02 or 0.01 gr/dscf. In the current case, the scrubber

would not be replaced because it meets the current NSPS limit. In a future case where the NSPS limit

was lowered, an ESP would have to be installed prior to the scrubber in order to meet the lower limit.

Therefore, the cost of lowering the NSPS is the cost of a new ESP. The table below presents example

calculations of cost effectiveness for 2 sizes of kilns and 2 levels of NSPS revision assuming the modified

kiln’s current emissions are 90% of the current NSPS limit, or 0.0594 gr/dscf.

Scenario Throughput Current

Emissions Future NSPS tpy

reduced ESP

Annual

Cost $/ton

1a. Small LK, NSPS to 0.02 20,000 dscfm 0.0594 gr/dscf 0.02 gr/dscf 29.58 $581,551 $19,658

1b. Small LK, NSPS to 0.01 20,000 dscfm 0.0594 gr/dscf 0.01 gr/dscf 37.09 $581,551 $15,678

1c. Large LK, NSPS to 0.02 40,000 dscfm 0.0594 gr/dscf 0.02 gr/dscf 59.17 $905,559 $15,305

1d. Large LK, NSPS to 0.01 40,000 dscfm 0.0594 gr/dscf 0.01 gr/dscf 74.18 $905,559 $12,207

Scenario 2: A facility performs a project that is considered a modification and triggers NSPS applicability

for a lime kiln. The current lime kiln scrubber either cannot meet the current 0.064 gr/dscf limit, or it is

in need of replacement, so the facility needs to install a new scrubber as part of the project. The impact

of reducing the NSPS limit is the difference between the cost of the scrubber that will achieve

compliance with 0.064 gr/dscf and the cost of the scrubber PLUS the cost of an ESP that will achieve

compliance with a lower level like 0.01 gr/dscf. We have assumed that both the scrubber and the ESP

are necessary because the scrubber controls TRS and SO 2 from the kiln and the ESP is needed to get

additional PM control beyond what the scrubber can achieve. The incremental cost can be represented

by the ESP annual cost. Note that this scenario would be less likely to occur, as a facility would be

more likely to upgrade newer equipment that already complies with the NSPS limit rather than older

equipment that does not. However, we have included this scenario for completeness as EPA has

indicated they are evaluating this type of scenario.5 March 29, 2013 Scenario Throughput Current NSPS Future NSPS tpy

reduced ESP

Annual

Cost $/ton

2a. Small LK, NSPS to 0.02

20,000 dscfm 0.066 gr/dscf 0.02 gr/dscf 34.54 $581,551 $16,837

2b. Small LK, NSPS to 0.01

20,000 dscfm 0.066 gr/dscf 0.01 gr/dscf 42.05 $581,551 $13,831

2c. Large LK, NSPS to 0.02

40,000 dscfm 0.066 gr/dscf 0.02 gr/dscf 69.08 $905,559 $13,109

2d. Large LK, NSPS to 0.01

40,000 dscfm 0.066 gr/dscf 0.01 gr/dscf 84.10 $905,559 $10,768

Scenario 3. A facility performs a project that is considered a modification and triggers NSPS applicability

for a lime kiln. The kiln is equipped with an ESP or an ESP/scrubber combination that complies with a

0.064 gr/dscf PM limit but would not meet a lower limit such as 0.02 or 0.01 gr/dscf. In the current

case, the controls would not be replaced. In a future case where the NSPS limit was lowered, the ESP

may have to be upgraded (if space is available for an upgrade). Therefore, the cost of lowering the NSPS

is the cost the ESP upgrade. The table below presents example calculations of cost effectiveness for 2

sizes of kilns and 2 levels of NSPS revision. Based on a review of the ICR data provided by EPA, it appears

that lime kilns equipped with ESPs have emission rates of 0.025 gr/dscf or less, so we have used that

emission rate as the current emission level.

Scenario Throughput Current

Emissions Future NSPS tpy

reduced ESP

Annual

Cost $/ton

3a. Small LK, NSPS to 0.02

20,000 dscfm 0.025 gr/dscf 0.02 gr/dscf 3.75 $161,952 $43,138

3b. Small LK, NSPS to 0.01

20,000 dscfm 0.025 gr/dscf 0.01 gr/dscf 11.26 $161,952 $14,379

3c. Large LK, NSPS to 0.02

40,000 dscfm 0.025 gr/dscf 0.02 gr/dscf 7.51 $253,828 $33,805

3d. Large LK, NSPS to 0.01

40,000 dscfm 0.025 gr/dscf 0.01 gr/dscf 22.53 $253,828 $11,268

Scenario 4. A facility installs a new lime kiln to replace an existing lime kiln. The facility also triggers

new source MACT so changing the NSPS limit to the new source MACT level does not have any

associated cost.

Under all scenarios, the cost of lowering the NSPS PM limit for modified units is very high, and none of

the examples evaluated show that additional control is cost effective. An examination of the ICR

summary data provided by EPA to AF&PA indicates that lime kilns equipped only with scrubbers are not

likely to meet an NSPS limit of 0.02 gr/dscf or less, but may meet 0.066 gr/dscf. Therefore, if most units

can meet the current NSPS limit, Scenario 1 is much more likely to occur than Scenario 2.6 March 29, 2013 EPA has estimated that 2 lime kilns will be modified over the next 10 years. The following table shows

example total cost and total cost effectiveness evaluations, depending on which subsets of the 3

Scenarios are selected.

Cost Scenario annual cost tons

reduced $/ton

1 under scenario 1d $905,559 74.18 $12,207

1 under scenario 2d $905,559 84.10 $10,768

Total $1,811,118 158.3 $11,442

Cost Scenario annual cost tons

reduced $/ton

1 under scenario 1b $581,551 37.09 $15,678

1 under scenario 2b $581,551 42.05 $13,831

Total $1,163,102 79.1 $14,697

Cost Scenario annual cost tons

reduced $/ton

1 under scenario 2b $581,551 42.05 $13,831

1 under scenario 3d $253,828 22.53 $11,268

Total $835,379 64.6 $12,937

Summary

The following table shows the ranges of cost estimates we developed under the various scenarios

evaluated for smelt tanks and lime kilns.

Total Cost Estimated

Number

Modified Min total

annual cost Max total

annual cost Min total

capital cost Max total

capital cost Min

$/ton Max $/ton

Lime Kilns 2 $1,163,102 $1,811,118 $1,886,972 $8,664,456 $10,768 $19,658

Smelt Tanks 6 $121,222 $2,634,300 $16,495,143 $23,992,982 $1,158 $59,708cost Methodologies and Costs for Reduction of PM and TRS from Kraft NSPS Sources - March 29, 2013

Source Typical

Control:

0.044 gr/dscf recovery furnaces 0.015 gr/dscf ESP

0.2 lb/TBLS smelt tanks 0.12 lb/TBLS scrubber

0.066 gr/dscf lime kilns burning gas 0.01 gr/dscf ESP or

scrubber

0.13 gr/dscf lime kilns burning oil and no gas 0.01 gr/dscf ESP or

scrubber

Current NSPS TRS limits: Typical Control:

5 ppmvd @ 10%O2 digesters, BSW, evaps, stripper combustion

5 ppmvd @ 8%O2 recovery furnaces NDCE, combustion air upgrades

0.033 lb/TBLS smelt tanks scrubber

8 ppmvd @ 10%O2 lime kilns mud washing, scrubber

PM/TRS Source Control Improvement for Lower

Emissions Level of Control

Improvement Typical Capital

Cost Annualized

Capital Cost Typical

Annual O/M

Cost/

Increase Total Annual

Cost Cost Notes Impacts/Limitations

TRS digesters, BSW,

evaps, stripper none NA NA NA NA NA NA

TRS/PM recovery furnaces install additional combustion air level moderate $5,000,000 $548,973 $0 $548,973 Mill specific BART cost

estimate. May not be able to add

another air level depending

on size of furnace. Air

changes affect balance

between NOx and CO

emissions, SO2. Load

burners firing fossil fuel may

also be necessary to achieve

a limit less than 5 ppm

continuously.

PM recovery furnaces upgrade ESP moderate $3,000,000 $329,384 $65,000 $394,384 2003 NERA study May not have space to

improve existing ESP,

depending on location. May

need replacement (see

below)

PM recovery furnaces improve combustion air system and

upgrade ESP moderate to

significant $8,000,000 $878,357 $65,000 $943,357 May need both

improvements to reach a

lower PM limit As stated above, may not be

feasible.

PM recovery furnaces replace ESP significant $20,000,000 $2,195,892 $65,000 $2,260,892 company cost of recent

project If existing ESP is on top of

recovery boiler building,

must move to ground if

need bigger unit. Major

ductwork changes required.

May need new fan.

TRS/PM smelt tanks scrubber improvement (e.g.,

micromist scrubber) moderate $500,000 $54,897 $150,000 $204,897 Envirocare rough cost

estimate

TRS/PM smelt tanks vent to recovery furnace basically

eliminates

emissions $5,000,000 $548,973 $0 $548,973 Mill project cost creates maintenance issues

with fan, may be difficult to

implement with an existing

unit due to furnace size and

current air levels

TRS lime kilns improve mud washing, no

condensate use in causticizing, adjust

excess O2 moderate $2,000,000 $219,589 $0 $219,589 Piping cost for similar

condensate project in 2009

at a mill. may not be able to achieve

level lower than current

NSPS

PM lime kilns add ESP in advance of scrubber if not

present significant $5,000,000 $548,973 $77,000 $625,973 2003 NERA study both technologies (ESP and

scrubber) would be

necessary to meet lower

PM limits

Note - scrubbers only improve H2S and MMC emissions, so TRS improvement depends on speciation profile.

Capital Recovery Factor Calcuation for Annualized Costs:

Interest Equipment

Rate Life, yrs CRF

7.00% 15 0.110 APCD

7.00% 10 0.142 CEMS

CEMS Costs (source- EPA CEMS cost model)

System Typical Initial

Cost Annualized

Capital Cost Typical

Annual O/M

Cost/

Increase Total Annual

Cost Notes

TRS CEMS NA NA $12,540 $12,540 per system

per year

COMS $47,175 $6,717 $13,458 $20,175 per system

per year

PM CEMS $148,524 $21,146 $33,125 $54,271 per system

per year

PM CEMS $94,069 $13,393 $26,697 $40,090 per system

per year

PM CEMS $133,684 $19,034 $28,697 $47,731 per system

per year Require PM CEMS (beta gauge)

Require PM CEMS (light scattering/in situ)

Require PM CEMS (light scattering/extractive) Current NSPS PM limits: Current new source MACT limits:

Cost of adding annual RATA, reporting, annual QA and O/M

review and update (change to compliance monitoring

requirements/Appendix F) Possible Regulatory Change

Install COMS on lime kilnscost per ton

Incremental costs for PM reductions for NSPS sources

Rough Recovery Furnace Cost Estimates

Source Control Improvement for

Lower Emissions Level of Control

Improvement Capital Cost Total Annual

Cost Current NSPS

(gr/dscf or

lb/TBLS) or

lower current

emission

level Alternate

NSPS for

modified

(based on

data) Tons PM

reduction

from current $/ton Alternate

NSPS = MACT

new Tons PM

reduction

from current $/ton Cost Reference

recovery furnaces upgrade ESP - smaller unit moderate $3,000,000 $394,384 75,000 dscfm 0.044 0.03 39.42 $10,004.66 2003 NERA study

recovery furnaces upgrade ESP/combustion

air - larger unit moderate $8,000,000 $943,357 175,000 dscfm 0.044 0.03 91.98 $10,256.11 plus mill BART

cost estimate for

recovery furnaces replace ESP - smaller unit significant $12,029,399 $1,320,763 75,000 dscfm 0.044 0.03 39.42 $33,504.90 0.015 81.66 $16,174.78 company cost of

recent project

adjusted for size

recovery furnaces replace ESP - larger unit significant $20,000,000 $2,260,892 175,000 dscfm 0.044 0.03 91.98 $24,580.26 0.015 190.53 $11,866.33 company cost of

recent project

adjusted for size

Smelt Tank Analysis

Scenario 1. You do a project that triggers NSPS for your smelt tank (modify/reconstruct). You already have a scrubber that complies with 0.2 lb/TBLS but not with 0.15 or 0.12, so you have to install a new

scrubber because the NSPS has gotten more stringent (this assumes that you would NOT replace your scrubber if NSPS was 0.2).

Note that the example analysis below assumes a current emission level of 0.18 lb/TBLS and provides costs for 2 sizes of SDT and 2 levels of revised NSPS.

tpy reduced Annual Cost $/ton

(Capital only)

1a. Small SDT, NSPS to 0.15 40 TBLS/hr 0.18 lb/TBLS 0.15 lb/TBLS 5.26 $313,828 $59,708

1b. Small SDT, NSPS to 0.12 40 TBLS/hr 0.18 lb/TBLS 0.12 lb/TBLS 10.51 $313,828 $29,854

1c. Large SDT, NSPS to 0.15 70 TBLS/hr 0.18 lb/TBLS 0.15 lb/TBLS 9.20 $439,050 $47,733

1d. Large SDT, NSPS to 0.12 70 TBLS/hr 0.18 lb/TBLS 0.12 lb/TBLS 18.40 $439,050 $23,867

Scenario 2. You do a project that triggers NSPS for your smelt tank (modify/reconstruct). Your current control device either cannot meet the current 0.2 lb/TBLS limit, or it is in need of replacement

so you need to install a new scrubber. Therefore, the cost of reducing the NSPS limit is the delta between the cost of the scrubber that will get you to 0.2 and the cost of the

scrubber that will get you to a lower NSPS level.

Note - it is much more likely that a mill will upgrade new equipment than old equipment that does not currently meet NSPS. Incremental

tpy reduced Annual Cost $/ton

2a. Small SDT, NSPS to 0.15 40 TBLS/hr 0.2 lb/TBLS 0.15 lb/TBLS 8.76 $20,204 $2,306

2b. Small SDT, NSPS to 0.12 40 TBLS/hr 0.2 lb/TBLS 0.12 lb/TBLS 14.02 $20,204 $1,441

2c. Large SDT, NSPS to 0.15 70 TBLS/hr 0.2 lb/TBLS 0.15 lb/TBLS 15.33 $28,394 $1,852

2d. Large SDT, NSPS to 0.12 70 TBLS/hr 0.2 lb/TBLS 0.12 lb/TBLS 24.53 $28,394 $1,158

Scenario 3. You install a new smelt tank to replace an existing smelt tank. You do not trigger new source MACT because you are not replacing or reconstructing the recovery furnace.

If you need a new scrubber as part of the project, the cost is same as Scenario 2. If you don't need a replacement scrubber as part of the project, the cost is same as Scenario 1 if the NSPS limit is lowered.

Scenario 4. You construct a new smelt tank and recovery furnace. You are subject to new source MACT so changing the NSPS to new source MACT level does not have any associated cost. Throughput Current NSPS Future NSPS Typical Production or Flow

ESP upgrade not likely to get to 0.015 from

0.044

ESP upgrade not likely to get to 0.015 from

0.044

Throughput Current Emissions Future Emissionscost per ton

Lime Kiln Analysis

Scenario 1. You do a project that triggers NSPS for your lime kiln (modification). You have a scrubber that complies with 0.066 but not with 0.02 or 0.01, so you have to install a new

ESP in front of the scrubber because the NSPS has gotten more stringent (this assumes that you would NOT replace/add controls if NSPS was 0.066).

Note that the example analysis below assumes a current emission level of 0.0594 gr/dscf (90% of standard) and provides costs for 2 sizes of LK and 2 levels of revised NSPS.

ESP

tpy reduced Annual Cost $/ton

1a. Small LK, NSPS to 0.02 20,000 dscfm 0.0594 gr/dscf 0.02 gr/dscf 29.58 $581,551 $19,658

1b. Small LK, NSPS to 0.01 20,000 dscfm 0.0594 gr/dscf 0.01 gr/dscf 37.09 $581,551 $15,678

1c. Large LK, NSPS to 0.02 40,000 dscfm 0.0594 gr/dscf 0.02 gr/dscf 59.17 $905,559 $15,305

1d. Large LK, NSPS to 0.01 40,000 dscfm 0.0594 gr/dscf 0.01 gr/dscf 74.18 $905,559 $12,207

Scenario 2. You do a project that triggers NSPS for your lime kiln (modification). Your current control device either cannot meet the current 0.066 gr/dscf limit, or it is in need of replacement

so you need to install a new ESP and scrubber. Therefore, the cost of reducing the NSPS limit is the delta between the cost of the scrubber that will get you to 0.066 and the cost of the

ESP and scrubber that will get you to a lower NSPS level.

Note - it is much more likely that a mill will upgrade new equipment than old equipment that does not currently meet NSPS.

ESP

tpy reduced Annual Cost $/ton

2a. Small LK, NSPS to 0.02 20,000 dscfm 0.066 gr/dscf 0.02 gr/dscf 34.54 $581,551 $16,837

2b. Small LK, NSPS to 0.01 20,000 dscfm 0.066 gr/dscf 0.01 gr/dscf 42.05 $581,551 $13,831

2c. Large LK, NSPS to 0.02 40,000 dscfm 0.066 gr/dscf 0.02 gr/dscf 69.08 $905,559 $13,109

2d. Large LK, NSPS to 0.01 40,000 dscfm 0.066 gr/dscf 0.01 gr/dscf 84.10 $905,559 $10,768

Scenario 3. You do a project that triggers NSPS for the kiln, and the kiln is equipped with an ESP or ESP/scrubber combination. The controls meet 0.066 but will not meet a

lower limit. Therefore, if space allows, an ESP upgrade would be needed. The cost of reducing the NSPS limit is the cost of the upgrade.

Based on ICR data that EPA has shared with AF&PA, it appears that lime kilns equipped with ESPs achieve PM levels of 0.025 gr/dscf or lower.

ESP upgrade

tpy reduced Annual Cost $/ton

3a. Small LK, NSPS to 0.02 20,000 dscfm 0.025 gr/dscf 0.02 gr/dscf 3.75 $161,952 $43,138

3b. Small LK, NSPS to 0.01 20,000 dscfm 0.025 gr/dscf 0.01 gr/dscf 11.26 $161,952 $14,379

3c. Large LK, NSPS to 0.02 40,000 dscfm 0.025 gr/dscf 0.02 gr/dscf 7.51 $253,828 $33,805

3d. Large LK, NSPS to 0.01 40,000 dscfm 0.025 gr/dscf 0.01 gr/dscf 22.53 $253,828 $11,268

Scenario 4. You install a new lime kiln to replace an existing lime kiln. You also trigger new source MACT so changing the NSPS to new source MACT level does not have any associated cost. Throughput Current Emissions Future NSPS Throughput Current Emissions Future NSPS

Throughput Current NSPS Future NSPScost per ton

Summary

Unit Estimated Number

Modified Min total annual

cost Max total

annual cost Min total

capital cost Max total

capital cost Min $/ton Max $/ton

Recovery Furnaces 4 $1,577,535 $9,043,569.98 $12,000,000 $80,000,000 $10,005 $33,505

Lime Kilns 2 $1,163,102 $1,811,118 $1,886,972 $8,664,456 $10,768 $19,658

Smelt Tanks 6 $121,222 $2,634,300 $16,495,143 $23,992,982 $1,158 $59,708

Total 12 $2,861,860 $13,488,988 $30,382,114 $112,657,438

Example Costs for Modified Units:

annual cost tons reduced $/ton

Smelt Tanks 3 for scenario 1d $1,317,150 55.2 $23,867

3 for scenario 2d $85,181 73.6 $1,158

Total $1,402,331 128.8 $10,890

annual cost tons reduced $/ton

3 for scenario 1a $941,483 15.8 $59,708

3 for scenario 2a $60,611 26.3 $2,306

Total $1,002,094 42.0 $23,832

annual cost tons reduced $/ton

Lime Kilns 1 for scenario 1d $905,559 74.18 $12,207

1 for scenario 2d $905,559 84.10 $10,768

Total $1,811,118 158.3 $11,442

annual cost tons reduced $/ton

1 for scenario 1b $581,551 37.09 $15,678

1 for scenario 2b $581,551 42.05 $13,831

Total $1,163,102 79.1 $14,697

annual cost tons reduced $/ton

1 for scenario 2b $581,551 42.05 $13,831

1 for scenario 3d $253,828 22.53 $11,268

Total $835,379 64.6 $12,9370.2 Scrubber Cost small Cost Estimate for Installation of a Scrubber on Small Smelt Tank to Meet 0.2 lb/TBLS

Component Cost

Cost Reference

BEK scrubber cost - 2001 study $2,817,358 2001 AFPA BEK Study Scaled to 2012

Includes capital and engineering and contingency using CE Plant index and current labor rates

Base unit size: 2 mm lb BLS/day

Actual unit size: 1.92 mm lb BLS/day

TOTAL CAPITAL INVESTMENT $2,749,190 Total Adjusted Installed Cost

Annual Cost Cost Factor/ Component Cost

Equation Cost-a Reference

Direct Annual Costs, DC

Maintenance Labor and Materials 2% of TCI $54,984 [2]

Operating Labor 1.5 hr/day [2]

27.20 $ /hr $14,892 [3]

365 day/yr

Utilities

Water Usage 0.09 $/1000 gallons 100 gallons/hr $79 [4]

Electricity 77.48 kw/Mmlb BLS $3,654 [2]

$0.067 $/kWh [5]

Total DC $73,609

Indirect Annual Costs, IC

Overhead 60% of DC without Utilities $41,925 [1]

Administrative charges 2% TCI $54,984 [1]

Property Taxes 1% TCI $27,492 [1]

Insurance 1% TCI $27,492 [1]

Capital Recovery Costs = CRF*TCI

Capital Recovery (CR) = capital recovery factor (CRF)* total capital investment (TCI)

Capital Recovery Factor = i ( 1+ i) ^ n / ((1+i)^ n-1) ; i= interest rate , n= years

Capital Recovery Factor = 0.1098

Capital Recovery = (CR) is 0.1993 *TCI(assuming a 15 yr life @ 7%) $301,846

Total IC $453,739 [1]

Total Annual Cost $527,348 [1]

References:

[1]OAQPS Control Cost Manual, sixth edition, EPA 452-02-001, chapter 1, December 1995

[2] BE&K 2001 study for AF&PA

[3] Latest labor rate from the US Bureau of Labor and Statistics

[4] Estimated makeup water usage rate. Negligible impact on overall cost estimate.

[5] US Energy Information Administration0.12 Scrubber Cost small Cost Estimate for Installation of a Scrubber on Small Smelt Tank to Meet 0.12 lb/TBLS

Component Cost

Cost Reference

BEK scrubber cost - 2001 study $2,929,189 2001 AFPA BEK Study Scaled to 2012

Includes capital and engineering and contingency using CE Plant index and current labor rates

Base unit size: 2 mm lb BLS/day

Actual unit size: 1.92 mm lb BLS/day

TOTAL CAPITAL INVESTMENT $2,858,315 Total Adjusted Installed Cost

Annual Cost Cost Factor/ Component Cost

Equation Cost-a Reference

Direct Annual Costs, DC

Maintenance Labor and Materials 2% of TCI $57,166 [2]

Operating Labor 1.5 hr/day [2]

27.20 $ /hr $14,892 [3]

365 day/yr

Utilities

Water Usage 0.09 $/1000 gallons 100 gallons/hr $79 [4]

Electricity 85.22 kw/Mmlb BLS $4,019 [2]

$0.067 $/kWh [5]

Total DC $76,157

Indirect Annual Costs, IC

Overhead 60% of DC without Utilities $43,235 [1]

Administrative charges 2% TCI $57,166 [1]

Property Taxes 1% TCI $28,583 [1]

Insurance 1% TCI $28,583 [1]

Capital Recovery Costs = CRF*TCI

Capital Recovery (CR) = capital recovery factor (CRF)* total capital investment (TCI)

Capital Recovery Factor = i ( 1+ i) ^ n / ((1+i)^ n-1) ; i= interest rate , n= years

Capital Recovery Factor = 0.1098

Capital Recovery = (CR) is 0.1993 *TCI(assuming a 15 yr life @ 7%) $313,828

Total IC $471,395 [1]

Total Annual Cost $547,552 [1]

References:

[1]OAQPS Control Cost Manual, sixth edition, EPA 452-02-001, chapter 1, December 1995

[2] BE&K 2001 study for AF&PA

[3] Latest labor rate from the US Bureau of Labor and Statistics

[4] Estimated makeup water usage rate. Negligible impact on overall cost estimate.

[5] US Energy Information Administration0.2 Scrubber Cost large Cost Estimate for Installation of a Scrubber on Large Smelt Tank to Meet 0.2 lb/TBLS

Component Cost

Cost Reference

BEK scrubber cost - 2001 study $2,817,358 2001 AFPA BEK Study Scaled to 2012

Includes capital and engineering and contingency using CE Plant index and current labor rates

Base unit size: 2 mm lb BLS/day

Actual unit size: 3.36 mm lb BLS/day

TOTAL CAPITAL INVESTMENT $3,846,163 Total Adjusted Installed Cost

Annual Cost Cost Factor/ Component Cost

Equation Cost-a Reference

Direct Annual Costs, DC

Maintenance Labor and Materials 2% of TCI $76,923 [2]

Operating Labor 1.5 hr/day [2]

27.20 $ /hr $14,892 [3]

365 day/yr

Utilities

Water Usage 0.09 $/1000 gallons 100 gallons/hr $79 [4]

Electricity 77.48 kw/Mmlb BLS $6,395 [2]

$0.067 $/kWh [5]

Total DC $98,289

Indirect Annual Costs, IC

Overhead 60% of DC without Utilities $55,089 [1]

Administrative charges 2% TCI $76,923 [1]

Property Taxes 1% TCI $38,462 [1]

Insurance 1% TCI $38,462 [1]

Capital Recovery Costs = CRF*TCI

Capital Recovery (CR) = capital recovery factor (CRF)* total capital investment (TCI)

Capital Recovery Factor = i ( 1+ i) ^ n / ((1+i)^ n-1) ; i= interest rate , n= years

Capital Recovery Factor = 0.1098

Capital Recovery = (CR) is 0.1993 *TCI(assuming a 15 yr life @ 7%) $422,288

Total IC $631,224 [1]

Total Annual Cost $729,512 [1]

References:

[1]OAQPS Control Cost Manual, sixth edition, EPA 452-02-001, chapter 1, December 1995

[2] BE&K 2001 study for AF&PA

[3] Latest labor rate from the US Bureau of Labor and Statistics

[4] Estimated makeup water usage rate. Negligible impact on overall cost estimate.

[5] US Energy Information Administration0.12 Scrubber Cost large Cost Estimate for Installation of a Scrubber on Large Smelt Tank to Meet 0.12 lb/TBLS

Component Cost

Cost Reference

BEK scrubber cost - 2001 study $2,929,189 2001 AFPA BEK Study Scaled to 2012

Includes capital and engineering and contingency using CE Plant index and current labor rates

Base unit size: 2 mm lb BLS/day

Actual unit size: 3.36 mm lb BLS/day

TOTAL CAPITAL INVESTMENT $3,998,830 Total Adjusted Installed Cost

Annual Cost Cost Factor/ Component Cost

Equation Cost-a Reference

Direct Annual Costs, DC

Maintenance Labor and Materials 2% of TCI $79,977 [2]

Operating Labor 1.5 hr/day [2]

27.20 $ /hr $14,892 [3]

365 day/yr

Utilities

Water Usage 0.09 $/1000 gallons 100 gallons/hr $79 [4]

Electricity 85.22 kw/Mmlb BLS $7,034 [2]

$0.067 $/kWh [5]

Total DC $101,982

Indirect Annual Costs, IC

Overhead 60% of DC without Utilities $56,921 [1]

Administrative charges 2% TCI $79,977 [1]

Property Taxes 1% TCI $39,988 [1]

Insurance 1% TCI $39,988 [1]

Capital Recovery Costs = CRF*TCI

Capital Recovery (CR) = capital recovery factor (CRF)* total capital investment (TCI)

Capital Recovery Factor = i ( 1+ i) ^ n / ((1+i)^ n-1) ; i= interest rate , n= years

Capital Recovery Factor = 0.1098

Capital Recovery = (CR) is 0.1993 *TCI(assuming a 15 yr life @ 7%) $439,050

Total IC $655,924 [1]

Total Annual Cost $757,906 [1]

References:

[1]OAQPS Control Cost Manual, sixth edition, EPA 452-02-001, chapter 1, December 1995

[2] BE&K 2001 study for AF&PA

[3] Latest labor rate from the US Bureau of Labor and Statistics

[4] Estimated makeup water usage rate. Negligible impact on overall cost estimate.

[5] US Energy Information AdministrationLK ESP Large Cost Estimate for Installation of an ESP on Large Lime Kiln to Meet 0.01 to 0.02 gr/dscf

Component Cost

Cost Reference

BEK ESP cost - 2001 study Base Size, TCaO/day 540 $4,332,228 2001 AFPA BEK Study Scaled to 2012

Includes capital and engineering and contingency using CE Plant index and current labor rates

TOTAL CAPITAL INVESTMENT $4,332,228 Total Adjusted Installed Cost

Annual Cost Cost Factor/ Component Cost

Equation Cost-a Reference

Direct Annual Costs, DC

Maintenance Labor and Materials 3% of TCI $129,967 [2]

Operating Labor 2.25 hr/day [2]

27.20 $ /hr $22,338 [3]

365 day/yr

Utilities

Electricity 0.97451 kw/tpd CaO $12,927 [2]

$0.067 $/kWh [5]

Total DC $165,232

Indirect Annual Costs, IC

Overhead 60% of DC without Utilities $91,383 [1]

Administrative charges 2% TCI $86,645 [1]

Property Taxes 1% TCI $43,322 [1]

Insurance 1% TCI $43,322 [1]

Capital Recovery Costs = CRF*TCI

Capital Recovery (CR) = capital recovery factor (CRF)* total capital investment (TCI)

Capital Recovery Factor = i ( 1+ i) ^ n / ((1+i)^ n-1) ; i= interest rate , n= years

Capital Recovery Factor = 0.1098

Capital Recovery = (CR) is 0.1993 *TCI(assuming a 15 yr life @ 7%) $475,655

Total IC $740,327 [1]

Total Annual Cost $905,559 [1]

References:

[1]OAQPS Control Cost Manual, sixth edition, EPA 452-02-001, chapter 1, December 1995

[2] BE&K 2001 study for AF&PA

[3] Latest labor rate from the US Bureau of Labor and Statistics

[4] Estimated makeup water usage rate. Negligible impact on overall cost estimate.

[5] US Energy Information AdministrationLK ESP Small Cost Estimate for Installation of an ESP on Small Lime Kiln to Meet 0.01 to 0.02 gr/dscf

Component Cost

Cost Reference

BEK ESP cost - 2001 study Base Size, TCaO/day 540 $4,332,228 2001 AFPA BEK Study Scaled to 2012

Includes capital and engineering and contingency using CE Plant index and current labor rates

Small Kiln Size, TCaO/day 250

TOTAL CAPITAL INVESTMENT $2,729,223 Total Adjusted Installed Cost

Annual Cost Cost Factor/ Component Cost

Equation Cost-a Reference

Direct Annual Costs, DC

Maintenance Labor and Materials 3% of TCI $81,877 [2]

Operating Labor 2.25 hr/day [2]

27.20 $ /hr $22,338 [3]

365 day/yr

Utilities

Electricity 0.97451 kw/tpd CaO $5,985 [2]

$0.067 $/kWh [5]

Total DC $110,199

Indirect Annual Costs, IC

Overhead 60% of DC without Utilities $62,529 [1]

Administrative charges 2% TCI $54,584 [1]

Property Taxes 1% TCI $27,292 [1]

Insurance 1% TCI $27,292 [1]

Capital Recovery Costs = CRF*TCI

Capital Recovery (CR) = capital recovery factor (CRF)* total capital investment (TCI)

Capital Recovery Factor = i ( 1+ i) ^ n / ((1+i)^ n-1) ; i= interest rate , n= years

Capital Recovery Factor = 0.1098

Capital Recovery = (CR) is 0.1993 *TCI(assuming a 15 yr life @ 7%) $299,654

Total IC $471,352 [1]

Total Annual Cost $581,551 [1]

References:

[1]OAQPS Control Cost Manual, sixth edition, EPA 452-02-001, chapter 1, December 1995

[2] BE&K 2001 study for AF&PA

[3] Latest labor rate from the US Bureau of Labor and Statistics

[4] Estimated makeup water usage rate. Negligible impact on overall cost estimate.

[5] US Energy Information AdministrationLK ESP upgrade Large Cost Estimate for Upgrade of an ESP on Large Lime Kiln to Meet 0.01 to 0.02 gr/dscf

Component Cost

Cost Reference

BEK ESP cost - 2001 study Base Size, TCaO/day 540 $1,497,641 2001 AFPA BEK Study Scaled to 2012

Includes capital and engineering and contingency using CE Plant index and current labor rates

TOTAL CAPITAL INVESTMENT $1,497,641 Total Adjusted Installed Cost

Annual Cost Cost Factor/ Component Cost

Equation Cost-a Reference

Direct Annual Costs, DC

Maintenance Labor and Materials 1% of TCI $14,976 [2]

Operating Labor 2.25 hr/day [2]

27.20 $ /hr [3]

365 day/yr

Utilities

Electricity 0.41667 kw/tpd CaO $5,527 [2]

$0.067 $/kWh [5]

Total DC $20,503

Indirect Annual Costs, IC

Overhead 60% of DC without Utilities $8,986 [1]

Administrative charges 2% TCI $29,953 [1]

Property Taxes 1% TCI $14,976 [1]

Insurance 1% TCI $14,976 [1]

Capital Recovery Costs = CRF*TCI

Capital Recovery (CR) = capital recovery factor (CRF)* total capital investment (TCI)

Capital Recovery Factor = i ( 1+ i) ^ n / ((1+i)^ n-1) ; i= interest rate , n= years

Capital Recovery Factor = 0.1098

Capital Recovery = (CR) is 0.1993 *TCI(assuming a 15 yr life @ 7%) $164,433

Total IC $233,324 [1]

Total Annual Cost $253,828 [1]

References:

[1]OAQPS Control Cost Manual, sixth edition, EPA 452-02-001, chapter 1, December 1995

[2] BE&K 2001 study for AF&PA

[3] Latest labor rate from the US Bureau of Labor and Statistics

[4] Estimated makeup water usage rate. Negligible impact on overall cost estimate.

[5] US Energy Information AdministrationLK ESP upgrade small Cost Estimate for Upgrade of an ESP on Small Lime Kiln to Meet 0.01 to 0.02 gr/dscf

Component Cost

Cost Reference

BEK ESP cost - 2001 study Base Size, TCaO/day 540 $1,497,641 2001 AFPA BEK Study Scaled to 2012

Includes capital and engineering and contingency using CE Plant index and current labor rates

Small Kiln Size, TCaO/day 250

TOTAL CAPITAL INVESTMENT $943,486 Total Adjusted Installed Cost

Annual Cost Cost Factor/ Component Cost

Equation Cost-a Reference

Direct Annual Costs, DC

Maintenance Labor and Materials 1% of TCI $9,435 [2]

Operating Labor 2.25 hr/day [2]

27.20 $ /hr [3]

365 day/yr

Utilities

Electricity 0.41667 kw/tpd CaO $5,527 [2]

$0.067 $/kWh [5]

Total DC $14,962

Indirect Annual Costs, IC

Overhead 60% of DC without Utilities $5,661 [1]

Administrative charges 2% TCI $18,870 [1]

Property Taxes 1% TCI $9,435 [1]

Insurance 1% TCI $9,435 [1]

Capital Recovery Costs = CRF*TCI

Capital Recovery (CR) = capital recovery factor (CRF)* total capital investment (TCI)

Capital Recovery Factor = i ( 1+ i) ^ n / ((1+i)^ n-1) ; i= interest rate , n= years

Capital Recovery Factor = 0.1098

Capital Recovery = (CR) is 0.1993 *TCI(assuming a 15 yr life @ 7%) $103,590

Total IC $146,990 [1]

Total Annual Cost $161,952 [1]

References:

[1]OAQPS Control Cost Manual, sixth edition, EPA 452-02-001, chapter 1, December 1995

[2] BE&K 2001 study for AF&PA

[3] Latest labor rate from the US Bureau of Labor and Statistics

[4] Estimated makeup water usage rate. Negligible impact on overall cost estimate.

[5] US Energy Information AdministrationBEK data

BE&K Data - updated to 2012 cost 0.15 0.2 0.05 0.05 Annual Operating and Maintenance Costs and Assumptions

No. Good /

Best Pollutant Equipment Size Technology limit Labor hours Labor $/hr Labor Materials Sub-contracts Equipment Total Directs Costs Engineering Subtotal Contingency of

direct costs +

engineering Owner's Cost %

of direct costs Con-struction

Manage-ment %

of direct costs Total Size of

base

unit Feed rate Materials

Consumables

(fabric filters,

SCR media,

etc.) at design Maintenan

ce labor &

materials,

% of TIC Energy,

kw/feed rate

at design rate units Man power hr/dy

15 Good PM Smelt

Dissolving

tank 3.7x 106 lb

BLS/day 0.2 lb/ton BLS 16,177 63.68 $ 1,030,098 $ 358,624 $ 13,500 $ 501,399 $ 1,903,620 $ 285,543 $ 2,189,164 $ 437,833 $ 95,181 $ 95,181 $ 2,817,358 $ 2 Mmlb

BLS/day

- $ 2.00% 77.47584 kw/Mm lb

BLS 1.50

16 Best PM Smelt

Dissolving

tank 3.7x 106 lb

BLS/day 0.12 lb/ton BLS 16,177 63.68 $ 1,030,098 $ 358,624 $ 13,500 $ 576,961 $ 1,979,182 $ 296,877 $ 2,276,059 $ 455,212 $ 98,959 $ 98,959 $ 2,929,189 $ 2 Mmlb

BLS/day

- $ 2.00% 85.22343 kw/Mm lb

BLS 1.50

No. Good /

Best Pollutant Equipment Size Technology limit Labor

hours Labor $/hr Labor Materials Sub-contracts Equipment Total Directs Costs Engineering Subtotal Contingency of

direct costs +

engineering Owner's Cost %

of direct costs Con-struction

Manage-ment %

of direct costs Total Size of

base

unit Feed rate Materials

Consumables

(fabric filters,

SCR media,

etc.) at design Maintenan

ce labor &

materials,

% of TIC Energy,

kw/feed rate at

design rate units Manpower hr/dy

18 Best PM Lime Kilns 240 tons

CaO/day 0.01 gr/dscf @

10%oxy 6,633 63.68 $ 422,367 $ 103,531 $ 526,600 $ 1,874,683 $ 2,927,181 $ 439,077 $ 3,366,258 $ 673,252 $ 146,359 $ 146,359 $ 4,332,228 $ 540 TPD CaO

- $ 3.00% 0.97451 kw/tpd CaO 2.25

60 Best PM Lime Kilns 240 tons

CaO/day Add single field

to upgrade ESP

to Best

technology

- 63.68 $

- $

- $ 536,000 $ 475,919 $ 1,011,919 $ 151,788 $ 1,163,707 $ 232,741 $ 50,596 $ 50,596 $ 1,497,641 $ 540 TPD CaO

- $ 1.00% 0.41667 kw/tpd CaO 2.25

Capital costs for smelt tanks and lime kilns updated using ratio of 577.4 Sept 2012 CE cost index to 2001 value of 394.3

Labor rates updated using ratio of US Bureau of Labor and Statistics current rate of $27.20/hr to $25.04 in BEK report