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Re: DAA CostAnalysis Curtis Lesslie to: Vanessa Hinkle 12/20/2011 06:53 AM Cc: Christopher Ajayi, Bob Vantuyl, JeffBriggs, TomWood 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>, JeffBriggs <jeff.briggs@ashgrove.com>, Tom Wood <trwood@stoel.com>

History: This message has been forwarded.

1Attachment**~,!"** 

# '.1. DAA Cost Estimate.pdf


### Vanessa:
Attached is a cost estimate from PENTA Engineering for DAA installation at our Montana City plant, preparedin response to yourrequest. Keep inmind that this is abudgetary estimate and thatthere is a much largerprojectunderlying this effort

- that is, we mustreplacethe existing ESP with abaghouse as part ofour Portland CementNESHAP compliance efforts. As currently envisioned, the DAA system would be placed ahead ofthe new baghouse. As youmay know, the court decision for the PC NESHAP rule was 12/2/11. The courtremandedthe rule back to EPA for reconsideration due to impermissible overlap ofthe 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 yearextension ofthe compliance date for PM at the Montana City plant and planto complete installation and operation ofthe newbaghouseby 9/9/14. This date may

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change ifthe remand orfurther appeals push backthe compliance date. A significant amount of uncertainty will continue until all appeals and reconsiderationefforts are completed.
I hope this cost estimate meets yourneeds, as many ofour consultants and technical staffhave taken vacationthrough the end ofthe year, but let me know ifyouhave any further questions. Thanks,
Curtis

Curtis Lesslie, PE Vice President EnvironmentalAffairs
Ash Grove Cement Company 11011 Cody St., Overland Park, KS 66210
P: (913) 319-6065 M: (785) 550-6330**~.ASHGROVE.com**



### OnThu, Dec 15,2011 at 5:26 PM,**<HLIJkl~.VCllle~~~'-@j2amail.epa.gov>** 

### wrote: Hi Curtis - I gotyour 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: DAACostAnalysis

We have a bunch ofirons inthe fire with all the recent court and rulemaking activities related to our industry, but letme see whatI can scare up to a costestimate. Since we had agreedto install it regardless ofthe cost, it

### may take me a couple ofdays to getthat together for you.
Let me check around and getbackto you.

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Curtis Lesslie, PE Vice PresidentEnvironmental Affairs
Ash Grove Cement Company 11011 

### Cody St., Overland Park, KS 66210
P: (913) 319-6065 M: (785) 550-6330 'iYY/W.ASHGROVE.com

OnThu, Dec 15,2011 at 1:54 PM, <Hinkle.Vgnessa@epatnail.epa.gov>wrote: Hi Curtis,
Ifwe consider DAA as atechnically feasible option, we needto consider the cost ofDAA. It

### is importantto compare the potential control efficiencies and costs ofevery technology to be able tojustify our decision. We can't leave this information out, especially ifit is the chosentechnology. Will youprovide us with a cost estimate?
VanessaHinkle 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 receivedyourvoice mail from yesterday afternoon. Since I will be meetings againmostoftoday and am travelling next Monday and Tuesday, I am providing this e-mail response to more quickly address your question.
You asked for acost analysis for the DAA systemproposed in ourmost

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recent BART submittal. As noted on page 14 ofthe submittal dated October 11, 2011, it is notedthat since we have proposed installation ofDAA, we did not prepare orprovide a cost analysis for that technology.
Ihope 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

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## Conceptfor 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 forthe 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 forthe installation of a Dry Hydrated Lime Injection System for Flue Gas Desulfurization at the Ash Grove Cement Montana City Plant. The scope ofthis 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 ofthe 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 allowfree flow of limefor filling ofthe Loss-In-Weight Feeder. Discharge ofthe 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 airforthe 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 EngineeringASH 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 $ INSTALL 1,000

200 3,000
1,300 12,500

900 1,000

800 3,000 4,500

800 1,800 2,000 1,800 2,500

300 500 800 25,000 10,000 74,000 TOTAL $ 3,000 $ 700 $ 15,000
$ 6,300 $ 62,500 $ 4,400 $ 5,000 $ 3,800 $ 15,000 $ 22,500 $ 3,800 $ 8,800 $ 10,000 $ 8,800 $ 12,500 $ 1,300 $ 2,500 $ 3,800 $ 25,000 $ 10,000 $ 225,000

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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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