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Re: DAA Cost Analysis 

Curtis Lesslie 

to: 

Vanessa Hinkle 

12/20/2011 06:53 AM 

Cc: 

Christopher Ajayi, Bob Vantuyl, Jeff Briggs, Tom Wood 

Hide Details 

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

To: Vanessa Hinkle/R8/USEPA/US@EPA 

Cc: Christopher Ajayi/R8/USEPA/US@EPA, Bob Vantuyl <bob.vantuyl@ashgrove.com>, 

Jeff Briggs <jeff.briggs@ashgrove.com>, Tom Wood <trwood@stoel.com> 

History: This message has been forwarded. 

1 Attachment 

~,!" '.1. DAA Cost Estimate.pdf 

Vanessa: 

Attached is a cost estimate from PENTA Engineering for DAA installation at our Montana City plant, 

prepared in response to your request. Keep in mind that this is a budgetary estimate and that there is a 

much larger project underlying this effort - that is, we must replace the existing ESP with a baghouse as 

part of our Portland Cement NESHAP compliance efforts. As currently envisioned, the DAA system 

would be placed ahead of the new baghouse. As you may know, the court decision for the PC NESHAP 

rule was 12/2/11. The court remanded the rule back to EPA for reconsideration due to impermissible 

overlap of the floors for NESHAP with CISWl sources. The compliance date was not stayed, but 

further appeals to the court are due by 1/15/12 and may result in a stay. 

As it currently stands, we have secured a I year extension of the compliance date for PM at the Montana 

City plant and plan to complete installation and operation of the new baghouse by 9/9/14. This date may 

file://C:\Documents and Settings\vhinkle\Local Settings\Temp\notes7A42A6\~web2765.htm 2/1/2012 
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change if the remand or further appeals push back the compliance date. A significant amount of 

uncertainty will continue until all appeals and reconsideration efforts are completed. 

I hope this cost estimate meets your needs, as many of our consultants and technical staff have taken 

vacation through the end of the year, but let me know if you have any further questions. 

Thanks, 

Curtis 

Curtis Lesslie, PE 

Vice President Environmental Affairs 

Ash Grove Cement Company 

11011 Cody St., Overland Park, KS 66210 

P: (913) 319-6065 

M: (785) 550-6330 

~.ASHGROVE.com

On Thu, Dec 15,2011 at 5:26 PM, <HLIJkl~.VCllle~~~'-@j2amail.epa.gov> wrote: 

Hi Curtis - I got your message. Thanks for doing this. 

Vanessa Hinkle
 

Environmental Scientist
 

EPA Region 8
 

1595 Wynkoop
 

Denver, CO 80202-1129
 

(303) 312-6561 

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

To: Vanessa Hinkle/R8IUSEPAfUS@EPA
 

Cc: Christopher Ajayi/R8IUSEPAfUS@EPA
 

Date: 12/15/2011 02:10 PM
 

Subject: Re: DAA Cost Analysis
 

We have a bunch of irons in the fire with all the recent court and
 

rulemaking activities related to our industry, but let me see what I can
 

scare up to a cost estimate. Since we had agreed to install it
 

regardless of the cost, it may take me a couple of days to get that
 

together for you.
 

Let me check around and get back to you. 

file://C:\Documents and Settings\vhinkle\Local Settings\Temp\notes7A42A6\-web2765.htm 2/1/2012 
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Curtis Lesslie, PE 

Vice President Environmental Affairs 

Ash Grove Cement Company 

11011 Cody St., Overland Park, KS 66210 

P: (913) 319-6065 

M: (785) 550-6330 

'iYY/W.ASHGROVE.com 

On Thu, Dec 15,2011 at 1:54 PM, <Hinkle.Vgnessa@epatnail.epa.gov>wrote: 

Hi Curtis, 

If we consider DAA as a technically feasible option, we need to
 

consider
 

the cost of DAA. It is important to compare the potential control
 

efficiencies and costs of every technology to be able to justify our
 

decision. We can't leave this information out, especially if it is the
 

chosen technology. Will you provide us with a cost estimate?
 

Vanessa Hinkle
 

Environmental Scientist
 

EPA Region 8
 

1595 Wynkoop
 

Denver, CO 80202-1129
 

(303) 312-6561 

From: Curtis Lesslie <curtis.lesslie@~~hgrove.com>
 

To: Vanessa Hinkle/R8IUSEPA/US@EPA
 

Date: 12/09/2011 08:18 AM
 

Subject: DAA Cost Analysis
 

Good morning Vanessa: 

I received your voice mail from yesterday afternoon. Since I will be 

meetings again most of today and am travelling next Monday and
 

Tuesday,
 

I am providing this e-mail response to more quickly address your
 

question.
 

You asked for a cost analysis for the DAA system proposed in our most 

file://C:\Documents and Settings\vhink1e\Local Settings\Temp\notes7A42A6\~web2765.htm 2/1/2012 

III 
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recent BART submittal. As noted on page 14 of the submittal dated 

October 11, 2011, it is noted that since we have proposed installation 

of DAA, we did not prepare or provide a cost analysis for that 

technology. 

I hope this adequately answers your question. Please let me know if 

there are additional questions. 

Thanks, 

Curtis 

Curtis Lesslie, PE 

Vice President Environmental Affairs 

Ash Grove Cement Company 

11011 Cody St., Overland Park, KS 66210 

P: (913) 319-6065 

M: (785) 550-6330 

www.ASHGROVE.cQm 

file://C:\Documents and Settings\vhinkle\Local Settings\Temp\notes7A42A6\~web2765.htm 2/1/2012 
Concept for Montana City Lime Injection 

Background 

The AGC plant at Montana City has a single wet process kiln producing about 900 tid 

clinker. The USEPA recently passed final PC NESHAP regulations for the Portland 

Cement Manufacturing industry. The Montana City plant must reduce emissions of PM 

to meet the NESHAP. Ash Grove is currently proceeding with a project to locate a 

baghouse to allow the existing wet process kiln to meet the final NESHAP regulations. 

Additionally, the S02 emissions at the Montana City plant are currently approximately 6.5 

to 8.5 pounds per ton (Ib/t). AGC has requested PENTA develop this brief CAPEX 

study to evaluate the installation of a Dry Hydrated Lime Injection System for Flue Gas 

Desulfurization. 

Concept for Dry Hydrated Lime Injection System 

PENTA has developed the following concept for the installation of a Dry Hydrated Lime 

Injection System for Flue Gas Desulfurization at the Ash Grove Cement Montana City 

Plant. The scope of this study includes truck unloading, sorbent storage, metering, 

conveying and injection. 

Trucks pneumatically unload dry hydrated lime into a storage bin. The truck connects to 

a 4" line and blows lime to a receiver mounted on top of the storage bin. Conveying air 

is vented via a bin vent dust collector. 

The 40 ton storage bin's level is continuously measured using radar level indication. The 

bin bottom is fluidized to allow free flow of lime for filling of the Loss-In-Weight Feeder. 

Discharge of the storage bin is controlled by an actuated butterfly valve and is assisted 

by an air activated discharge system. 

The Loss-In-Weight Feeder meters dry lime via a variable speed rotary airlock. The dry 

lime is then discharged to a blow-through rotary airlock which introduces the lime into 

the pneumatic conveying line. The Loss-In-Weight Feeder and discharge chute are 

vented through a cartridge filter. 

Conveying air for the pneumatic transport is dried to reduce line buildup and pressurized 

by a positive displacement blower. Lime is transported to a distribution splitter where the 

stream is separated to multiple injection lances. Sorbent is then injected into process 

ducts to treat the gases being conveyed from the existing wet process kiln (kiln feed 

end) to the new baghouse. The lime injection rate is expected to be approximately 

300Ibs/hr. 

PEI~TA ENGINEERING CO., LLC 

Gerald L. Yo ng Timothy E. Dudash 

Vice-pre . ent Process/Mechanical Engineer 

Process/Enviro ntal Engineering 
ASH GROVE CEMENT 

MONTANA CITY, MT 

PENTA PROJECT No. 20101021 

MECHANICAL EQUIPMENT COST ESTIMATE 

HYDRATED LIME INJECTION 

EQUIP. No. DESCRIPTION DESIGN UNITS COMMENTS 

20.TH010 TRUCK UNLOADING $ 

20.RC110 RECEIVER 1,000 cfm $ 

20.BF120 FABRIC FILTER 1,600 cfm bin vent $ 

20.FN125 FAN 1,600 cfm 

20.L1105 CONTINUOUS LEVEL INDICATOR $ 

20.B1100 BIN 3,500 cult 40ton storage (25Ib/cuft) $ 

20.SG130 MAINTENANCE SLIDE GATE $ 

20.SG140 AREATED SILO DISCHARGE $ 

20.BF145 BUTIERFLY VALVE $ 

20.AE150 AERATION SYSTEM $ 

20.LF200 LOSS IN WEIGHT FEEDER $ 

20.BF205 CARTRIDGE DUST FILTER $ 

20.RF210 ROTARY FEEDER $ 

20.RF220 BLOW-THROUGH ROTARY FEEDER vented chute $ 

20.BL300 BLOWER $ 

20.DY310 DRYER $ 

20KG335 KNIFE GATE 1 EA $ 

20.DS340 DISTRIBUTION SPLITIER ASSEMBLY 1 EA $ 

20.IL400 INJECTION LANCES 6 EA $ 

2.5"pipe 150 It to process duct 

4"pipe 100 It from truck 

Total $ 

COST 

2,000 $ 

500 $ 

12,000 $ 

incl in 20.BF120 

5,000 $ 

50,000 $ 

3,500 $ 

4,000 $ 

3,000 $ 

12,000 $ 

18,000 $ 

3,000 $ 

7,000 $ 

8,000 $ 

7,000 $ 

10,000 $ 

1,000 $ 

2,000 $ 

3,000 $ 

inc! in install $ 

inc! in install $ 

151,000 $ 

INSTA

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vapltal (josts 

eqUipment 

Freiaht 

Installation of Eauipment 

Insulation 

Truck Parkina 

Foundation and Structure 

Demolition Allowance 

ELECTRICAL 

Sub-Total 

Contingency 

Ena + GM 

Contractor Services 

Commissionina 

Geotech 

Permits 

Taxes 

TOTAL 

ASH GROVE . 1I11 Y, MT
 

LIME INJECTION SYSTEM
 

PENTA PROJECT No. 20101021
 

MECHANICAL EQUIPMENT COST ESTIMATE 

luuanmy 

7% 

30% 

25% 

unit lunlll"'nce nce 

:ti lol,UUU 

:ti 11,000 

$ 74,000 

20,000 

10,000 

17,000 

- 46,000 

329,000 

82,000 

40,000 

23,000 

6,000 

Not Incl 

Not Inc! 

Not Inc! 

:ti 48u,000 

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