## Date: November 6 , 2014

To: Jeff Telander, EPA/OAQPS/SPPD From: Thomas Holloway , RTI International Subject: Methodology

and Assumptions Used to Estimate the Model Costs and I mpacts of BSC P Air Pollution Control Devices
**I. I**  **ntroduction** In accordance with section 112 of the Clean Air Act (CAA), the U.S. Environmental Protection Agency

(EPA) established national emission standards for hazardous air pollutants (NESHAP) on May

16, 2003 for the brick and structural clay products (BSCP) manufacturing industry . The NESHAP regulated emissions of hydrogen fluoride (HF) , hydrogen chloride (HCl), and particulate matter (PM)

—a surrogate for hazardous air pollutant (HAP) metals

—from tunnel kilns located at BSCP facilities . On March 13, 2007, the D.C. Circuit Court vacated the emission standards for BSCP manufacturing due to issues associated with the methodology used to determine the minimum regulatory “floors” for new and existing units. 1 

## Therefore, the EPA is proposing new standards for BSCP manufacturing , including standards for HF, HCl, chlorine (Cl 2 

## ), mercury

(Hg), and non - Hg HAP metals (or PM surrogate) . The purpose of this memorandum is to present the methodology and assumptions used in esti mating the model costs and environmental and energy impacts for the control technologies used to meet these new standards . **II. General M**  **odel Parameters** M odel costs and impacts were developed for two sizes of BSCP control devices

—large control devices (LCD) and small control devices (SCD ) , reflecting the size subcategories of the BSCP NESHAP , which are based on a kiln capacity threshold of 10 tons per hour (tph) . The model costs and impacts were estimated based on a variety of model parameters

—(1) general parameters such as production rate, operating hours, gas flow rate, electricity and waste disposal unit costs, labor wage rates, and uncontrolled emissions ; and (2) control - specific parameters such as control device horsepower (hp ) requirements , sorbent requirements, and sorbent unit cost . This section discusses the basis for the general model parameters , which are presented in Appendix A at the end of this memo randum .

1 

### Sierra Club v. EPA , 479 F.3d 875 (D.C. Cir. 2007) .

## 2

The model production rate s (in tph) and operating hours (in hours per ye ar [hr/y r]) were based on data from the BSCP inventory (Holloway, 2014) . The BSCP inventory is a combination of (1) industry

responses to the 2008 BSCP section 114 survey; (2) responses to a survey similar to the 2008 BSCP section 114 survey that was administered by the Brick Industry

Association; and ( 3 ) industry

data from the 2003 BSCP database (from the original 2003 BSCP NESHAP) for plants not included in the 2008 surveys . The average kiln production rate (7.0 tph) and operating hours (7,300 hr/yr) for the small model were calculated from those tunnel kilns with a kiln capacity less than 10 tph . The average kiln production rate (15 tph) and operating hours (7,800 hr/y

r) for the large model were calculated from those tunnel kilns with a kiln capacity of 10 tph or greater. The model kiln production rates were based on a mix of permitted and design capacities, i.e. , those capacities to which the kilns are actually limited. The model kiln operating hours were based on a mix of actual kiln operating hours from industry responses to the 2008 BSCP survey (Holloway, 2014 ) and facility operating hours from the 2003 BSCP database for those facilities not included in the 2008 survey . Since the kiln is the center of the production process at the BSCP facility, it is reasonable to assume facility operating hours would be the same as kiln operating hours. The model exhaust gas flow rate s (in actual cubic feet per minute [ acfm]) were based on data from BSCP stack tests (Ray mond , 2014 ) , with the model flow rate for the small model (23,100 acfm) calculated from stack test data for tunnel kilns with a kiln capacity less than 10 tph , and the model flow rate for the large model (38,700 acfm) calculated from stack test data for tunnel kilns with a kiln capacity of 10 tph or greater. In those cases where flow rate data were only available in units of dry

standard cubic feet per minute (dscfm), those flow rates were converted to units of acfm using Equation 1 below, based on stack temperature and moisture content data from the stack test (assuming a stack pressure equivalent to standard atmospheric pressure): Equation 1

—

Flow rate conversion 

#   % 100 % 100 tan 

## O

%H T T Q Q 2 dard s stack dscfm acfm



## 

   where: Q acfm 

## = exhaust flow rate (acfm) , Q dscfm 

## = exhaust flow rate (dscfm), T stack 

## = stack temperature (converted from degrees Fahrenheit [ °F ] to degrees Rankine [ °R] ), T standard 

## = standard temperature (528°R), and % H2 

## O = moisture content (percent [ % ] ). Unit costs for electricity ($0.073/kilowatt-hour [kWh]) and waste disposal ($40/ton waste) were based on the average of thos e unit cost s from the 2008 BSCP survey responses (Holloway, 2014 ) . The operator wage rate ($22.67/hr) was based on mean hourly wage data from

## 3

the May 2011 Bureau of Labor Statistics for NAICS 327100 (Clay Product and Refractory Manufacturing) for an Industrial Engineering Technician (BLS , 201 2 ) . Wage rates from the Bureau of Labor Statistics were used because they were more conservative than those provided by BSCP survey

respondents. The maintenance wage rate ($24.94/hr) was assumed to be 10 percent higher than the operator wage rate , similar to the ratio of maintenance to operator wage rates provided b y one BSCP company in its response to the 200 8 survey (Holloway, 2014 ) . The capital recovery

factor (0.0944) was c alculated using Equation 2 below , assuming a 7 percent interest rate and 20 - ye ar equipment life for the control devices expected to be used to comply with the new standards for BSCP manufacturing : Equation 2

— Capital recovery factor: 

#   1 1 ) 1 (

     n n 

## i i i CRF where: i = interest rate (%) and

n = pay ment period , e.g. , equipment life (y rs). Model uncontrolled emissions estimates (in pounds per ton [ lb/ton]) were used to estimate the amount of material captured b y the control devices, based on each device’s control efficiency . The pollutants of interest were HF, HCl, chlorine ( Cl 2 

## ), PM, HAP metals, and sulfur dioxide ( SO 2 

## ) . The model uncontrolled emissions estimates for HF, HCl, PM, Cl 2 

## , and SO 2 

## were based on the average of uncontrolled emissions data from BSCP stack tests (Ray mond , 2014 ) . The model uncontrolled emissions estimate for total HAP metals was assumed to be 1.1 percent of the PM estimate, based on the average ratio of metals to PM emi ssions in BSCP stack tests (Ray mond , 2014 ) . **III. Model Costs**  This section discusses the methodology and assumptions used to estimate the model costs for the new or retrofit emission control devices that BSCP facilities are expected to install in order to c ompl y with the new standards for the BSCP industry. The cost estimates are presented in 2011 dollars. The model cost tables for new and retrofit control device s are presented in Appendices B and C, respectively. (Note: The annual operating costs for replac ement control devices presented in this memorandum are a conservative estimate . The operating costs for control devices to be replaced have not been subtracted out. ) Dry sorbent injection/fabric filter (DIFF) . Dry sorbent injection followed by a fabric filter (DIFF) can be used to reduce emissions of both particulates and acid gases from BSCP tunnel kilns. This ty

pe of control system is already in use in the BSCP industry (Holloway, 2014 ) and is expected to be installed on uncontrolled kilns or retrofitted to replace less efficient kiln controls to enable facilities to comply with the new BSCP standards .

## 4

The DIFF costs were estimated using the cost algorithms from the original BSCP rulemaking ( Shrager, 2003) , which were generated following guidelines in the OAQPS Control Cost Manual (EPA , 2002) . The algorithms were updated to include more recent model parameters, including the general parameters discussed previously and the following parameters specific to DIFF control devices:

 Control efficiency

( e.g. , 99 .5% HF, 94% PM)  Fan horsepower (150 hp [small]/190 hp [large])  Total horsepower for other motors (30 hp)  Stoichiometric ratio of hydrated lime (2.65 [small], 1.79 [large])  Bag life (5 yrs)  Gas -to - cloth ratio (3.4 feet per minute [ft/min])  Bag area (28 square feet [ft2 

## ])  Compressed air (0.9 cubic feet [ft3 

## ] of compressed air/1,000 ft3 

## of gas)  Time to replace bags (2.25 hr/bag)  Hydrated lime unit cost ($160/ton)  Bag fabric cost ($8.15/ft2 

## )  Compressed air unit cost ($0.24/1,000 ft3 

## )  Bag capital recovery

factor (0.244, based on 5 - yr bag life and 7% interest) With two exceptions, the values of the model DIFF parameters were determined based on averages of industry

responses to the 2008 BSCP survey (Holloway, 2014 ) . The DIFF control efficiencies and stoichiometric ratios of hydrated lime were determined differently, as discussed below. The control efficiencies for new and retrofit DIFF were estimated based on the average of those stack tests with better efficiencies than the baseline control efficiency (which was determined based on the average of all available stack tests with control efficiency data) (Ray mond , 2014 ) . For example, the baseline HF control efficiency for a DIFF is estimated to be 98 percent; in stack tests with HF control efficiencies better than 98 percent, the average HF control efficiency

is 99.5 percent. The stoichiometric ratio of hydrated lime for new and retrofit DIFF was estimated based on average reagent rates from industry responses to the 2008 BSCP survey (Holloway, 2014 ) , average uncontrol led emissions data from stack tests (Ray mond , 2014 ) , and molecular weight information for the primary pollutants and hydrated lime, scaled up from baseline using the ratio of the aforementioned control efficiencies (99.5 percent/98 percent). The model DIFF capital costs were estimated by taking DIFF capital cost data from industry responses to the 2008 BSCP survey (Holloway, 2014 ) , escalating the costs to 2011 dollars using the Chemical Engineering Plant Cost Index (CEPCI) (C E , 2011) , scaling the costs to the large and small model sizes using the six -tenths cost rule (see Equation 3 below), taking the average of the scaled costs for each model size, and rounding the results to three significant figures.

## 5

Equation 3

—

Six
- tenths cost rule: 0.6 2 1 2 1 

##          Q Q C C

where: C = capital cost and

Q = capacity

parameter ( e.g. , exhaust gas flow rate). For retrofits, the capital costs were further adjusted using a retrofit factor of 1.4, which is in the middle of the range of retrofit factors for emission control device s, according to guidance from the OAQPS Control Cost Manual (EPA , 2002) . The model DIFF annual costs were estimated based on the aforementioned cost algorithms, and include the following cost items:

 Operating labor (assumed to be twice the maintenance labor hours at $22.67/hr)  Supervisory

labor (estimated at 15% of operating labor)  Maintenance labor (estimated based on 1.25 hr/shift from BSCP survey responses and an assumed $24.94/hr wage rate)  Maintenance materials (estimated at 100% of maintenance labor)  Electricity

(estimated based on hp requirements, 0.745 kW/hp, and $0.073/kWh)  Lime (estimated based on hydrated lime makeup and $160/ton hydrated lime unit cost)  Compressed air (estimated based on 0.9 ft3 

## /1,000 ft3 

## compressed air requirements and $0.24/1,0 00 ft3 

## compressed air unit cost)  Replacement bags (estimated based on 3.4 ft/min gas -to - cloth ratio, $8.15/ft2 

## bag fabric, and 0.244 bag capital recovery factor)  Bag replacement labor (estimated based on 3.4 ft/min gas -to - cloth ratio, 28 ft2 

## bag area, $29.94/hr maintenance wage rate, and 0.244 bag capital recovery factor)  Waste disposal (estimated based on waste generated and $40/ton waste)  Overhead (estimated at 60% of labor and maintenance materials)  Property

taxes, insurance, and administrative charges (estimated at 4 % of total capital cost)  Capital recovery

(estimated as the product of a 0.0944 capital recovery factor and total capital cost, minus the cost of capital recovery for replacement bags and bag replacement labor) Fabric filter . Fabric filters can be used to reduce emissions of particulates from BSCP tunnel kilns at plants that already have acid gas control or have inherently low acid gas emissions ( e.g. , due to low fluoride and chloride content in the raw materials). Stand- alone fabric filters are

## 6

not currently used b y the BSCP industry to control tunnel kiln emissions, although DIFF are used to control emissions from the larger tunnel kilns (Holloway, 2014 ) . The BSCP industry has expressed the following concerns about using stand- alone fabric filters (Holloway, 2013 b ) :

 Without the dry

lime injection that reduces the acid gas, there will not be enough particulates in the kiln exhaust to coat the bags and get good performance from the fabric filter.  The uncontrolled acid in the exha ust stream could rot the bags .  The exhaust gas temperatures from BSCP tunnel kilns can be high (about 400°F on average, as high as 668°F).  The use of membrane bags on low inlet loadings. In response to these concerns, we contacted two major fabric filter vendors

— Solios Environment and McGill AirClean

—and a major filter bag vendor

—W.L. Gore & Associates

— to determine the feasibility of using stand- alone fabric filters in the BSCP industry . A representative from one of the fabric filter vendors (Solios Environment) agreed with industry concerns that that the lack of a dust cake would negatively impact total outlet emissions and that the dust cake serves an important function for acid gas neutralization. He noted that the bag choices for high-temperature applications are limited to fiberglass, with an upper temperature limit of 500°F, and that fiberglass degrades rapidly in the presence of HF acid gas. While PTFE (Teflon) fabric also has a limit of 500°F and is impervious to most acid gases, he noted that it carries a very significant price premium. He indicated that Aramid, Ry ton, and P - 84 fabrics are generally

limited to 400°F operation, but noted that these fabrics are sensitive to degradation not only b y the acid gases but also the relatively high oxygen concentration in brick kiln gases (Hansen , 2013 ) . A representative from the other fabric filter vendor (McGill AirClean) stated that a brick plant should be able to use a stand- alone baghouse to control just filterable particulate emissions from a brick kiln. According to the vendor, if the concern is low dust load and not being able to establish a good dust cake, then bags with an expanded PTFE membrane could be used. He noted that membrane bags usually control outlet particulate emissions to very low levels and are not cost prohibitive any

more. Like Solios, he stated that the base fabric for the membrane can be a woven fiberglass fabric, which is good for a 500°F continuous operating temperature. If there is HF in the gas stream, he said that this could damage the fiberglass, so scrubbing would be a good idea, depending on the amount of HF present. He said that acid gases in moderate concentrations usually do not cause fabric degradation if the bags are continuousl y operated above the acid gas dewpoints. Regarding operating temperatures above 500°F, he said there are some fabrics that are available for continuous operation at these temperatures but none with a membrane. He noted that the plant could consider flue gas cooling using a dry-bottom evaporative cooler or a gas -to air heat exchanger to reduce the gas temperature to a level where conventional fabrics could be used safel y ( Childress , 2013 b ) . A representative from the bag fabric vendor (W.L. Gore & Associates) noted that his company had done business with the brick industry before and that they

have two kinds of bags that could be used for the industry : (1) high-temperature fiberglass bags, and (2) high temperature PTFE (Teflon) bags. Both are rated to 500 ° F. He indicated that a ceramic styl e bag

## 7

would be needed for temperatures above 500 ° F. He could not speak to the concern regarding PM loading, but did say

that there would be no problem with PM loadings as low as 1 to 2 grains per cubic foot. He noted that HF destro ysfiberglass, so PTF E bags would be needed if HF emissions are a concern. He noted that PTFE bags, unlike fiberglass bags, are chemically inert, but are very expensive, about 2 to 5 times more expensive than fiberglass. He also noted that PTFE bags have high chemical and ther

mal resistance and would control PM but not acid gas (Holloway, 2013 c ) . Based on the information obtained from vendors, we believe fabric filters can potentially be an effective control option, if acid gas levels (especially HF) are already inherently low or effectively controlled and exhaust gas temperatures are not too high. The fabric filter costs were estimated using the DIFF cost algorithms, minus the capital cost for a dry sorbent injection system and annual cost for sorbent, and with a revised annual cost for waste disposal that excludes any

acid gas control. Activated carbon injection (ACI) . Injecting activated carbon before the particulate control device ( e.g. , fabric filter) has been demonstrated to improve the removal efficiency of mercury from a variety

of combustion devices ( e.g. , waste incinerators, industrial boilers, cement kilns). In the absence of a national mercury standard for the BSCP industry, there are currently no BSCP plants that use ACI. However, given the effective mercury control p erformance achieved in these other industries, we believed it prudent to explore this control technology as an option to reduce the mercury

emissions from the BSCP industry . To obtain information on the feasibility and cost of adding an ACI s ystem to an ex isting DIFF control s ystem for BSCP kilns, we first contacted a fabric filter vendor, McGill AirClean. While a representative from the vendor indicated that his company does not have data on control of mercury

emissions from BSCP kilns (all of the company ’ s mercury control experience is with municipal waste incinerators), he indicated that it should not be difficult or expensive to add an ACIs ystem to an existing DIFF control s ystem on a BSCP kiln. He said that a simple bag dump system with a blower could be used and would require little additional space at the site. He also noted that the slight increase in inlet PM loading to the baghouse should not affect the performance of the baghouse ( Childress , 2013 a) . We then contacted an ACIvendor (Cabot Norit Activated Carbon) to obtain information on the feasibility

and cost of installing an ACI s ys tem for control of mercury emissions from BSCP kilns. A representative from the company stated that he thought ACI would work well with BSCP kilns. He indicated that it would cost about $0.80 to $0.90/lb for carbon (Holloway, 2013 a) . He also indicated that, for applications using baghouses ( e.g. , a DIFF), an activated carbon feed rate of 0.5 to 3 pounds per million actual cubic feet (lb/MMacf) is ty pical; he suggested using 2 lb/MMacf as a baseline ( Thompson , 2013) . The model ACI costs for BSCP kilns were estimated based on ACI cost algorithms for a similarly- sized combustion device, specifically hazardous waste combustors (HWCs). We used the cost algorithms in the 2005 technical support document (TSD) for the HWC MACT replacement standards (EPA , 2005) , using the general parameters discussed in the previous section and the carbon injection rate (2 lb/MMacf [ Thompson , 2013] ) and carbon unit cost (average of $0.85/lb [Holl oway, 2013 a] ) from the ACIvendor. To determine the purchased equipment cost (PEC), the total equipment cost from the TSD was scaled to the large and small

## 8

BSCP model sizes using the six -tenths cost rule, sales tax and freight charges were added, the resulting cost was escalated to 2011 dollars, and a retrofit factor of 1.15 was applied (CE, 2011 ; EPA , 2005) . To determine the total direct capital costs, installation costs were added to the total PEC (EPA , 2005) . Inaddition to these direct costs, indirect c osts of engineering, construction and field expense, contractor fees, startup, performance test, model study, and contingencies were also estimated (EPA , 2005) . The model ACI annual costs were also estimated based on the aforementioned cost algorithms (EPA , 2005) and include the following cost items:

 Operating labor (assumed based on 1 hour/day at $22.67/hour)  Supervisory

labor (estimated at 15% of operating labor)  Maintenance labor (estimated based on 0.5 hour/shift and an assumed $29.94/hr wage rate)  Maintenance materials (estimated at 5% of the PEC)  Electricity

(estimated based on hp requirements, 0.9 fan efficiency, 0.745 kW/hp, and $0.073/kWh)  Carbon (estimated based on carbon feed rate and $0.85/lb)  Waste disposal (estimated based on waste generated and $40/ton waste)  Overhead (estimated at 60% of labor and maintenance materials)  Property

taxes, insurance, and administrative charges (estimated at 4 % of total capital cost)  Capital recovery

(estimated as the product of a 0.1098 capital recovery factor and total capital cost, assuming a 15 - ye ar equipment life and 7% interest) Dry limestone adsorber (DLA) . Instead of installing control equipment such as a DIFF to meet the new BSCP standards, some BSCP facilities may choose to install less expensive DLA systems on one or more of their uncontrolled tunnel kilns to reduce facility emissions below the threshold for major sources of HAP

— 10 tons per year (tpy) or more of any single HAP or 25 tpy or more of any combination of HAP. By obtaining a federall y enforcea ble limit reducing emissions below major source thresholds, those BSCP facilities would become sy nthetic area sources and would not be subject to the major source BSCP NESHAP . Only those BSCP facilities that would be impacted under the new BSCP standards and that could reduce their HAP emissions below the major source threshold using a DLA s ystem are expected to install such controls on their uncontrolled tunnel kilns. Dry limestone adsorbers are designed to control HF emissions and also provide limited control of HCl and Cl 2 

## emissions. The systems do not provide a mechanism for controlling PM emissions and would be expected to get only incidental PM control. This ty pe of control s ystem is already in use in the BSCP industry (Holloway, 2014 ) . The DLA costs were estimated using the cost algorithms from the original BSCP rulemaking ( Shrager, 2003), which were generated following guidelines in the OAQPS Control Cost Manual (EPA , 2002) . The algorithms were updated to include more recent model parameters, including the general parameters discussed previously

and the following parameters specific to DLA control devices:

## 9  Control efficiency

( e.g. , 95% HF, 30% HCl)  Fan horsepower (60 hp [small]/90 hp [large])  Total horsepower for other motors (1 0 hp [small]/40 hp [large] )  Lime stone rate ( 8 5 lb/hr [small] /120 lb/hr [large])  Lime stone unit cost ($ 4 0/ton) The model DLA control efficiencies for HF, HCl, and other pollutants were estimated based on averages of data from BSCP stack tests (Ray mond , 2014 ), while the values of the other model D LA parameters were determined based on averages of industry responses to the 2008 BSCP survey (Holloway, 2014 ) . The model D LA capital costs were estimated by taking D LA capital cost data from industry respon ses to the 2008 BSCP survey (Hol loway, 2014 ), escalating the costs to 2011 dollars using the CEPCI (CE , 2011), scaling the costs to the large and small model sizes using the six -tenths cost rule (see Equation 3), taking the average of the scaled costs for each model size, and rounding the results to three significant figures. The model D LA annual costs were estimated based on the aforementioned cost algorithms, and include the following cost items:

 Operating labor (assumed to be twice the maintenance labor hours at $22.67/hr)  Supervisory labor (estimated at 15% of operating labor)  Maintenance labor (estimated based on 0.75 hr/shift from BSCP survey responses and an assumed $24.94/hr wage rate)  Maintenance materials (estimated at 100% of maintenance labor)  Electricity

(estimated based on hp requirements, 0.745 kW/hp, and $0.073/kWh)  Lime stone (estimated based on lime stone rate and $ 4 0/ton lime stone unit cost)  Waste disposal (estimated based on waste generated and $40/ton waste)  Overhead (estimated at 60% of labor and maintenance materials)  Property

taxes, insurance, and administrative charges (estimated at 4 % of total capital cost)  Capital recovery

(estimated as the product of a 0.0944 capital recovery factor and total capital cost) Summary . Table 1 presents the model costs for the DIFF, fabric filter, ACI , and DLA control options discussed above for the small and large BSCP control devices. For additional information, see Appendix B and C at the end of this memorandum.

## 10 **Table 1. Summary**

**o f**  **Control Option Model Costs**  **Control Option Cost p**  **arameters SCD**  **LCD** Install new DIFF Total capital investment $ 2,000,000 $ 2,730,000 Total annual cost $ 613,29 7 $ 797,0 96 Install new fabric filter Total capital investment $ 1,200,000 $ 1,500,000 Total annual cost $ 437,8 45 $ 52 6,006 Replace with DIFF Total capital investment $ 2,800,000 $ 3,820,000 Total annual cost $ 720,8 11 $ 943,5 85 Retrofit fabric filter Total capital investment $ 1,680,000 $ 2,100,000 Total annual cost $ 502,35 4 $ 606,6 42 Retrofit ACI system MACT floor Total capital investment $102,224 $146,697 Total annual cost $70,589 $96,482 Beyond the floor Total capital investment $102,224 $146,697 Total annual cost $79,480 $112,768 Install DLA Total capital investment $1,060,000 $1,440,000 Total annual cost $306,593 $405,045 

## IV. **Model Impacts** This section discusses the methodology and assumptions used to estimate the model environmental and energy impacts associated with new or retrofit emission control devices that BSCP plants are expected to install in order to comply with the new standards for the BSCP industry . The model impacts parameters and calculations are presented in Appendix D . The model impacts tables for new and retrofit control device s are presented in Appendices E and F, respectively. A. Emission Red

uctions Model emission reductions were estimated for the major pollutants emitted from BSCP tunnel kilns, including both HAP (HF, HCl, Cl 2 

## , and HAP metals) and non- HAP (PM and SO 2 

## ). In most cases, we were able to determine the model emission reductions (tpy) b y multiplying the model uncontrolled emission factors (lb/ton) in Appendix A by the model production rate (tph) and operating hours (hr/yr) in Appendix A and the appropriate control efficiency (%) in Appendix D, and dividing b y a conversion factor of 2 ,000 lb/ton. B. Energy

Impacts To determine the annual amount of electricity (in kilowatt-hours per ye ar [kWh/y r]) needed to power the control device, the horsepower requirements (hp) of the control device were multiplied by

a conversion factor of 0.745 kW/hp and the annual operating hours (hr/yr). The annual amount of energy

(in million British thermal units per year [MMBtu/y r]) needed to generate this electricity was then determined b y dividing the electricity requirements (kWh/y

r) by the nationwide average power plant efficiency (35 percent) and multiplying by a conversion factor of 3,415 British thermal units per kilowatt hour (Btu/kWh) .

## 11

The efficiency

for each ty

pe of power plant was determined by dividing the heat content of electricity (3,415 Btu/kWh) by the heat rate for each type of plant ( 10,415 Btu/kWh for coal; 8,185 Btu/kWh for natural gas; 10,452 Btu/kWh for nuclear power; and 9,756 Btu/kWh for renewable energy). The nationwide average power plant efficiency was determined as a weighted average of these power plant efficiencies, based on the projected fuel mix for 2015 from Version 3.0 of EPA’s Integrated Planning Model (IPM) , which is a forecast model of the U.S. electric power sector (EPA , 2011) . The projected fuel mix is 53 percent coal, 22 percent natural gas/other, 17 percent nuclear, and 8 percent renewable/hydroelectric (EPA , 2011) . C. Secondary

Air Emissions Once the model energy

impacts were determined, the associated model secondary air emissions were estimated. Secondary emissions typically

include the criteria air pollutant emissions

—PM, carbon monoxide (CO), nitrogen oxides (NO X

## ), and SO 2

## —that result from the generation of electricity

used to operate the control devices. For purposes of this analysis, the electricity was assumed to be purchased from offsite power plants. The secondary emissions were estimated b y multiplying emission factors for the pollutants by the energy impacts, assuming a specific mix of fuels to generate the needed electricity. (EPA , 2011) We used a variety of information sources to obtain the emission factors used to estimate the secondary

emissions . For natural gas combustion , we used emission factors (in pounds per cubic foot [lb/ft3 

## ] of natural gas) from the AP - 42 chapter on natural gas combustion to estimate the secondary

emissions for PM, CO, NO X 

## , and SO 2 

## (EPA , 1998a) . We used the AP - 42 conversion factor of 1,020 Btu/ft3 

## of natural gas to convert the emission factors to pounds per million British thermal units (lb/MMBtu) to facilitate estimating the secondary emissions for these pollutants from natural gas (EPA , 1998a) . For solid fuel (coal) combustion, we used emission limits (in lb/MMBtu) from the new source performance standards (NSPS) for utility plants (40 CFR part 60, subpart Da ; 2006 CFR edition) to estimate the secondary emissions for PM and SO 2 

## (EPA , 2006 ) . We used emis sion factors (in lb/ton coal) from the AP - 42 chapter on coal combustion to estimate the secondary emissions for NO X 

## and CO ; we specifically used the AP - 42 emission factors for bituminous/subbituminous coal combustion/spreader stokers (EPA , 1998b) . The NO X 

## emission factor was based on an average of the AP - 4 2 emission factors for spreader stoker ty pe boilers burning bituminous ( 11 lb/ton) and subbituminous ( 8.8 lb/ton) coal. We used the AP - 42 conversion factor of 13,000 Btu/lb of coal to facilitate estimating the secondary emissions for NO X 

## and CO from coal (EPA , 1998b) . All secondary

air impacts were attributed to the combustion of coal, natural gas, or “other” fuels at offsite power plants. We attributed no secondary air impacts to nuclear, hydroelectric, or renewable energy generation. The secondary air impacts for “other” fuels were assumed to be equivalent to those for natural gas.

## 12

D. Solid Waste and Wastewater Impacts We estimated the solid waste impacts b y calculating the amount of material captured b y the control device. The material captured b y the f abric filter includes just PM from the kiln, while the material captured by the DIFF includes:
 Reaction products from the reaction of the lime with the acid gases ,  Unreacted lime, and  Particulate matter from the kiln. In the absence of information, the amount of solid waste captured b y a spray dryer/electrostatic precipitator (ESP) (the control system currently emplo yed at one BSCP facility) was assumed to be the same as that captured by a DIFF, since both emission control systems include a combination of acid gas and PM controls, unlike a stand- alone fabric filter (which captures only PM) or a DLA (which captures mostly acid gases, primarily HF). We e stimated the wastewater impacts associated with using a spray dryer/ESP by calculating the amount of water u sage for the spray dryer, using the equation shown in Appendix E. There are no wastewater impacts for the other control devices. E. Model Impacts for Control Options Model impacts were estimated for the following control scenarios and are presented in the appendix tables cited below:

 Installation of new DIFF on uncontrolled kiln (see Table E - 1)  Installation of new fabric filter on uncontrolled kiln (where acid gas levels and exhaust gas temperatures are low) (see Table E - 2)  Retrofit of fabric filter after an existing acid gas control ( e.g. , DLA) (see Table E - 2)  Installation of DLA on uncontrolled kiln(s) to become sy nthetic area source (see Table E - 3)  Retrofit of ACI s ystem to an existing control system ( e.g. , DIFF) (see Table F - 1 )  Replacement of existing DLA with a new DIFF (see Table F - 2)  Replacement of existing spray dryer/ESP with a new DIFF (see Table F - 3)  Replacement of existing DIFF with a new, more efficient DIFF (see Table F - 4) To estimate the incremental impacts for replacement control devices, the impacts associated with baseline controls were subtracted from the impacts associated with new controls. For DLA and spray

dryer/ESP controls being replaced with a DIFF, the incremental impacts include the emission reductions, energy impacts, secondary

air impacts, solid waste impacts, and wastewater impacts (spray dryer/ESP controls only). For those cases where a facility replaces an existing DIFF with a new, more efficient DIFF to comply with the new standards , we assumed no change in energy

requirement s or the associated secondary emissions, but we estimated the difference in emissions and solid waste impacts that would accompany the improved control of PM and acid gases.

## 13

Because we had no control efficiency data for spray

dryer/electrostatic precipitator (ESP), we used stack test data for the kilns equipped with this emission control as the baseline emissions and subtracted the baseline emissions for the DIFF to determine the incremental emissions reduction from replacing a spray dryer/ESP with a DIFF. Tables 2 through 4 present the model impacts for the DIFF, fabric filter, and ACI control installation/retrofit options and control replacement options discussed above for the small and large BSCP control devices. For additional information, see the aforementioned tables in Appendices E and F at the end of this memorandum. **Table 2a. Summary**

**of Model Emission Reductions for Control Installation/Retrofit**

**Options Control option**  **Pollutant Emissions reductions, tpy**  **SCD LCD**  Install new DIFF Hydrogen fluoride 15. 1 34. 6 Hydrogen chloride 1.7 2 3.9 4 Chlorine 0.07 89 0.18 1 HAP metals 0.08 55 0.19 6 Particulate matter 7. 78 17. 8 Sulfur dioxide 40.2 92.1 Install/retrofit fabric filter HAP metals 0.08 55 0.19 6 Particulate matter 7. 78 17. 8 Install new DLA Hydrogen fluoride 14.4 33.0 Hydrogen chloride 0.620 1.42 Chlorine 0.0371 0.0850 HAP metals 0.0182 0.0417 Particulate matter 1.65 3.79 Sulfur dioxide 9.90 22.7 Retrofit ACI system MACT floor Mercury 0.001 36 0.003 11 Beyond the floor Mercury 0.00152 0.00347

## 14

**Table 2b. Summary**

**of Model Emission Reductions for Control Replacement Options Control option**  **Pollutant Net e**  **missions reductions, tpy SCD**  **LCD** Replac e d ry l imestone a dsorber with n ew DIFF Hydrogen fluoride 0.6 83 1.5 6 Hydrogen chloride 1. 10 2. 52 Chlorine 0.041 8 0.0958 HAP metals 0.067 3 0.15 4 Particulate matter 6. 12 1 4.0 Sulfur dioxide 30.3 69.4 Replac e s pray dryer/ESP with n ew DIFF Hydrogen fluoride 17.5 37.3 Hydrogen chloride 3.93 8.3 5 Chlorine 0.534 1.14 HAP metals 0.00 0.00 Particulate matter 0.00 0.00 Sulfur dioxide 0.606 1.39 Replac e e xisting DIFF with n ew, more e fficient DIFF Hydrogen fluoride 0.2 28 0.52 1 Hydrogen chloride 0.025 9 0.05 94 Chlorine 0.00119 0.0027 2 HAP metals 0.0 200 0.045 8 Particulate matter 1.8 2 4.1 7 Sulfur dioxide 0.606 1.39 

### Table 3a. Summary

**of Model Energy**

**and Solid Waste Impacts for Control Installation/Retrofit Options**  **Control option Ty**  **pe of impact SCD**  **LCD** Install new DIFF Energy impacts, MMBtu/yr 9,620 12,563 Solid waste impacts, tpy 372 604 Install/retrofit fabric filter Energy impacts, MMBtu/yr 9,620 12,563 Solid waste impacts, tpy 7. 78 17. 8 Install new DLA Energy impacts, MMBtu/yr 3,741 7,424 Solid waste impacts, tpy 306 457 Retrofit ACI system MACT floor Energy impacts, MMBtu/yr 309 553 Solid waste impacts, tpy 10.2 17.9 Beyond the floor Energy impacts, MMBtu/yr 309 553 Solid waste impacts, tpy 15.3 27.3

## 15

**Table 3b. Summary**  **of Model Energy , Solid Waste,**  **and Waste water Impacts**  **for Control Replacement Options**  **Control option Ty**  **pe of impact Increase in impacts**  **1** 

### SCD **LCD** Replac e d ry l imestone a dsorber with n ew DIFF Energy impacts, MMBtu/yr 5,879 5,139 Solid waste impacts, tpy 66.8 147 Replac e s pray d ryer/ESP wi th n ew DIFF Energy impacts, MMBtu/yr - 7,749 - 24,555 Solid waste impacts, tpy 7.22 12.9 Wa stewater impacts, gpy - 1,901 -4,063 Replac e e xisting DIFF with new, m ore e fficient DIFF Energy impacts, MMBtu/yr 0 0 Solid waste impacts, tpy 7.22 12.9 1 A negative increase in impacts would be equivalent to a reduction in impacts. 

### Table 4a. Summary

**of Model Secondary**

**Impacts for Control Installation/Retrofit Options Control option**  **Secondary pollutant 1**  

### Secondary air impacts, tpy **SCD LCD**  Install new DIFF Particulate matter 0.0710 0.0927 PM 2.5 0.0238 0.0311 Carbon monoxide 0.120 0.156 Nitrogen oxides 0.951 1.24 Sulfur dioxide 2.77 3.62 Install/retrofit fabric filter Particulate matter 0.0710 0.0927 PM 2.5 0.0238 0.0311 Carbon monoxide 0.120 0.156 Nitrogen oxides 0.951 1.24 Sulfur dioxide 2.77 3.62 Install new DLA Particulate matter 0.0276 0.0548 PM 2.5 0.00925 0.0184 Carbon monoxide 0.0465 0.0923 Nitrogen oxides 0.370 0.734 Sulfur dioxide 1.08 2.14 Retrofit ACI system (MACT floor/beyond the floor) Particulate matter 0.00228 0.00408 PM 2.5 0.000765 0.00137 Carbon monoxide 0.00385 0.00688 Nitrogen oxides 0.0306 0.0547 Sulfur dioxide 0.0891 0.159 1 PM 2.5 = PM with p articles less than 2.5 micrometers in diameter
.

## 16

**Table 4b. Summary of Model Secondary Impacts**  **for Control Replacement Options Control option**  **Secondary pollutant 2**  

### Increase in s **econdary air impacts, tpy**  **1** 

### SCD **LCD** Replac e d ry l imestone adsorber with n ew DIFF Particulate matter 0.0434 0.0379 PM 2.5 0.0145 0.0127 Carbon monoxide 0.0731 0.0639 Nitrogen oxides 0.581 0.508 Sulfur dioxide 1.69 1.48 Replac e s pray dryer/ESP with n ew DIFF Particulate matter - 0.0572 - 0.181 PM 2.5 - 0.0192 - 0.0607 Carbon monoxide - 0.0964 - 0.305 Nitrogen oxides - 0.766 - 2.43 Sulfur dioxide - 2.23 - 7.07 Replac e existing DIFF with n ew, m ore e fficient DIFF Particulate matter 0 0 PM 2.5 0 0 Carbon monoxide 0 0 Nitrogen oxides 0 0 Sulfur dioxide 0 0 1 A negative increase in secondary air impacts would be equivalent to a reduction in secondary air impacts. 2 PM 2.5 = PM with p articles less than 2.5 micrometers in diameter
. 

## V. **References** BL S (U.S. Department of Labor, Bureau of Labor Statistics) . 201 2 . Occupational Employment Statistics : May 2011 National Industry
-Specific Occupational Employment and W age Estimates . NAICS 327100 - Clay Product and Refractory

Manufacturing . Industrial Engineering Technician . March 27, 2012. Available at: http://www.bls.gov/oes/2011/may /naics4_327100.htm . CE ( Chemical Engineering). 2011. Plant Cost Index. Childress, J. 2013 a . “RE: From McGill AirClean Web Site. ” E -mail from Jerry Childress, McGill AirClean LLC, to Thomas Holloway, RTI International . April 18, 2013. Childress, J. 2013b. “RE: From McGill AirClean Web Site.” E -mail from Jerry Childress, McGill AirClean LLC, to Thomas Holloway, RTI International. June 27, 2013. EPA (U .S. Environmental Protection Agency) . 1998a. Compilation of Air Pollutant Emission Factors. Volume 1: Stationary Point and Area Sources . AP - 42, Section 1.4: Natural Gas C ombustion . July

1998. EPA (U.S. Environmental Protection Agency) . 1998b. Compilation o f Air Pollutant Emission Factors. Volume 1: Stationary Point and Area Sources . AP - 42 , Section 1.1: Bituminous and S ubbituminous Coal Combustion. September 1998.

## 17

EPA (U.S. Environmental Protection Agency) . 2002. EPA Air Pollution Control Cost Manual . Sixth Edition. Office of Air Quality Planning and Standards, Research Triangle Park, NC. Publication No. EPA/452/B - 02 - 001 . January 2002. EPA (U.S. Environmental Protection Agency) . 2005. Technical Support Document for the HWC MACT Replacement Standards, Volume V : Emissions Estimates and Engineering Costs . Office of Solid Waste and Emergency Response, Washington, DC. September 2005. EPA (U.S. Environmental Protection Agency) . 2006. “Subpart Da

— Standards of Performance for Electric Utility

Steam Generating Units for Which Construction is Commenced After September 18, 1978 .” Code of Federal Regulations , Title 40, Part 60. Published by Office of the Federal Register, National Archives and Records Administration. As of July 1, 2006. EPA (U.S. Environmental Protection Agency) . 2011. Regulatory Impact Analysis for the Final Mercury and Air Toxics Standards . Table 3 - 6: Generation Mix with the Base Case and the MATS, 2015 (Thousand GWh). Publication No. EPA - 452/R- 11 - 011 . December 2011. Hansen, L. 2013. “RE: Question regarding use of fabric filters for brick kilns. ” E -mail from Lars Hansen, Solios Environment Corp., to Thomas Holloway, RTI International . July 2, 2013. Holloway, T. 2013a. Telephone Contact Summary: Jeff Thompson, Cabot Norit Activated Carbon . Contacted by

Thomas Holloway, RTI International. May 16, 2013. Holloway, T. 2013 b . “RE: From McGill AirClean Web Site. ” E -mail from Thomas Holloway, RTIInternational, to J erry Childress, McGill AirClean LLC. June 26, 2013. Holloway, T. 2013 c . Telephone Contact Summary : C hris Polizzi, W

.L. Gore &Associates, Inc. Contacted by

Thomas Holloway, RTI International. July 16, 2013. Holloway, T . 2014. Updated BSCP Inventory Database and Documentation . Memorandum from Thomas Holloway, RTI International, to J eff Telander, EPA/OAQPS/SPPD . November 6, 2014. Ray mond, G. 2014. Test Data Used in BSCP Proposed Rule . Memorandum from Gabrielle Ray mond, RTI International, to Jeff Telander, EPA/OAQPS/SPPD . November 6, 2014. Shrager, B. 2003. Final Rule: Costs for Air Pollution Contro l Devices on Kilns . Memorandum from Brian Shrager, RTI International , to M ary Johnson, U.S. Environmental Protection Agency . February

25, 2003. Thompson, J. 2013. “FW: Cabot Norit Activated Carbon

–question. ” E -mail from J eff Thompson, Cabot Norit Activated Carbon, to Thomas Holloway, RTI International . May 31, 2013.

## Appendix A **Model Parameters**

## A - 2 **Table A -**  **1. General**  **Parameters for BSCP Model Control**  **Devices Parameters**  **SCD LCD**  **Footnotes** Process parameters Production rate, ton/hr 7.0 15.0 1 Operating hours, hr/yr 7,300 7,800 1 Exhaust flow, acfm 23,100 38,700 2 Unit costs Electricity cost, $/kwh 0.073 0.073 1 Wa ste disposal cost, $/ton 40 40 1 Operator wage rate, $/hr 22.67 22.67 3 Maintenance wage rate, $/hr 24.94 24.94 4 Capital recovery factor-- system 0.0944 0.0944 5 Molecular weights HF 20 20 HCl 36.5 36.5 SO 2 64 64 CaF 2 78 78 6 CaCl 2 111 111 6 CaSO 3 120 120 6 Ca(OH) 2 74 74 7 Uncontrolled emissions, lb/ton HF 0. 594 0. 594 2 HCl 0.08 1 0.08 1 2 Cl 2 0.00346 0.00346 2 Non - Hg HAP Metals 0.0035 6 0.0035 6 8 PM 0.32 4 0.32 4 2 SO 2 3.23 3.23 2 Uncontrolled emissions, lb/hr HF 4. 16 8.91 9 HCl 0.56 6 1.2 1 9 Cl 2 0.024 2 0.05 19 9 Non - Hg HAP Metals 0.02 49 0.05 34 9 PM 2.2 7 4.8 6 9 SO 2 22.6 48.5 9 1. Average from section 114 survey responses . 2. Average from test data
. 3. M ean hourly wage, from Bureau of Labor Statistics, May 2011 National Industry- Specific Occupational Employment and Wa ge Estimates, NAICS 327100, Industrial Engineering Technician. W ebsite: http://www.bls.gov/oes/2011/may/naics4_327100.htm
. Wa ge rates from Bureau of Labor Statistics were used because they are more conservative than those provided by section 114 survey respondents. 4. 10 percent higher than operator rate
. 5. Based on equipment l ife of 20 years and 7 percent interest. 6. Reaction product ; CaF 2 = calcium fluoride ; CaCl 2 = calcium chloride ; CaSO 3 = calcium sulfite
. 7. Hydrated lime
. 8. Assume 1.1 percent of PM
. 9. Calculated from lb/ton times production rate
.

## Appendix B **Installation Model Costs** 

## B - 2 **Table B -**  **1. Model Costs to Install New**  **DIFF Parameters**  **SCD LCD**  **Footnotes** Control efficiency, percent HF 99.5% 99.5% 1 HCl 83 .3 % 83 .3 % 2 Cl 2 89 .3 % 89 .3 % 3 Non - Hg HAP Metals 94% 94% 4 PM 94% 94% 1 SO 2 4 8.7 % 4 8.7 % 5 Design and operating parameters Fan hp 150 190 6 Total hp for other motors 30 30 6 Hydrated lime, fraction of stoichiometric amount 2.65 1.79 7 Operator labor, hr/shift 2.5 2.5 8 Maintenance labor, hr/shift 1.25 1.25 6 Bag life, yr 5 5 6 Gas -to - cloth ratio (gross), ft/min 3.4 3.4 6 Bag area, ft2 28 28 6 Compressed air, ft 3/1,000 ft 3 0.9 0.9 6 Time to replace bags, hr/bag 2.25 2.25 6 Added cooling air, ft 3/min 0 0 9 Calculated parameters Hydrated lime makeup, lb/hr 91.4 132.0 Reaction products, lb/hr 29. 4 63. 1 10 Reacted lime, lb/hr 20.9 44. 7 Particulate matter, lb/hr 2.1 4. 6 Wa ste, lb/hr 102. 1 154. 9 11 Cost factors Hydrated lime, $/ton 160 160 6 Bag fabric cost, $/ft2 8.15 8.15 6 Compressed air, $/1,000 ft 3 0.24 0.24 12 Capital recovery factor-- bags 0.244 0.244 13 Capital costs Total capital investment 2,000,000 2,730,000 14 Annual costs Operating labor 51,716 55,258 Supervisory labor 7,757 8,289 15 Maintenance labor 28,444 30,392 Maintenance materials 28,444 30,392 16 Electricity 71,462 93,325 17 Lime 53,348 82,337 Compressed air 2,185 3,912 Annualized replacement bags 13,505 22,625 Annualized bag replacement labor 3,320 5,563 18 Cage replacement 0 0 19

## B - 3 **Parameters SCD**  **LCD Footnotes**  Wa ste disposal 14, 900 24,1 62 Overhead 69,817 74,598 20 Administrative charges 40,000 54,600 21 Property taxes 20,000 27,300 22 Insurance 20,000 27,300 22 Capital recovery 188,399 257,044 Total annual cost, $/yr 613,29 7 797,0 96 1. Average from test data with better efficiency than baseline
. 2. Based on ratio of enhanced HF reduction and baseline HCl reduction
. 3. Based on ratio of enhanced HF reduction and baseline Cl 2 reduction
. 4. Assume same as PM
. 5. Based on ratio of enhanced HF reduction and baseline SO 2 reduction
. 6. Average from section 114 survey responses . 7. Assume hydrated lime is 2.65/1.79 times the stoichiometric amount needed to get additional control re baseline (from 98% to 99.5%)
. 8. Assume 2 times maintenance labor ( EPA, 2002 )
. 9. Assume none
. 10. CaF 2 (c alcium fluoride ), CaCl 2 (calcium chloride ), and CaSO 3 (c alcium sulfite ). 11. Inlet lime minus reacted lime plus reaction products and PM
. 12. Pollution Preventi on (P2) Pays, NC Division of Pollution Prevention and Environmental Assistance. Determine the Cost of Compressed Air for Your Plant. Energy Tips - Compressed Air, Compressed Air Tip Sheet #1. August 2004. We b site: http://www.p2pays.org/ref/40/39536.pdf
. 13. Based on equipment life of 5 years and 7 percent interest
. 14. Average of costs from section 114 survey responses scaled using 6/10 rule (based on acfm), escalated to 2011 dollars, and rounded
. 15. 15 percent of operator labor
. 16. 100 percent of maintenance labor
. 17. Based on conversion factor of 0.745 kW /hp
. 18. Performed by maintenance personnel
. 19. Maybe no need to replace
. 20. 60 percent of labor and maintenance materials
. 21. 2 percent of TCI
. 22. 1 percent of TCI
.

## B - 4 **Table B**  **- 2. Model Costs to Install Ne** **w Fabric Filter Parameters**  **SCD LCD**  **Footnotes** Control efficiency, percent Non - Hg HAP Metals 94% 94% 1 PM 94% 94% 2 Design and operating parameters Fan hp 150 190 3 Total hp for other motors 30 30 3 Operator labor, hr/shift 2.5 2.5 4 Maintenance labor, hr/shift 1.25 1.25 3 Bag life, yr 5 5 3 Gas -to - cloth ratio (gross), ft/min 3.4 3.4 3 Bag area, ft2 28 28 3 Compressed air, ft 3/1,000 ft 3 0.9 0.9 3 Time to replace bags, hr/bag 2.25 2.25 3 Added cooling air, ft 3/min 0 0 5 Calculated parameters Wa ste, lb/hr 2.1 4. 6 6 Cost factors Bag fabric cost, $/ft2 8.15 8.15 3 Compressed air, $/1,000 ft 3 0.24 0.24 7 Capital recovery factor-- bags 0.244 0.244 8 Cost of dry injection system 800,907 1,230,278 9 Capital costs Total capital investment 1,200,000 1,500,000 10 Annual costs Operating labor 51,716 55,258 Supervisory labor 7,757 8,289 11 Maintenance labor 28,444 30,392 Maintenance materials 28,444 30,392 12 Electricity 71,462 93,325 13 Compressed air 2,185 3,912 Annualized replacement bags 13,505 22,625 Annualized bag replacement labor 3,320 5,563 14 Cage replacement 0 0 15 Wa ste disposal 3 11 7 12 Overhead 69,817 74,598 16 Administrative charges 24,000 30,000 17 Property taxes 12,000 15,000 18 Insurance 12,000 15,000 18 Capital recovery 112,884 140,940 Total annual cost, $/yr 437,8 45 52 6,006 1. Assume same as PM
. 2. Average from test data with better efficiency than baseline
. 3. Average from section 114 survey responses . 4. Assume 2 times maintenance labor ( EPA, 2002 )
.

## B - 5

5. Assume none
. 6. Particulate matter
. 7. Pollution Prevention (P2) Pays, NC Division of Pollution Prevention and Environm ental Assistance. Determine the Cost of Compressed Air for Your Plant. Energy Tips - Compressed Air, Compressed Air Tip Sheet #1. August 2004. We b site: http://www.p2pays.org/ref/40/39536.pdf
. 8. Based on equipment life of 5 years and 7 percent interest
. 9. Based on cost equations in the June 19, 2009 memorandum Revised Baseline Oper ating Costs for Existing HM IWI , in Docket ID No. EPA- HQ - OAR- 2006 - 0534 for the hospital/medical/infectious waste incinerato r ( HMIW I ) rule
. 10. Average of costs from section 114 survey responses scaled using 6/10 rule (based on acfm), subtracted cost of dry injection system, escalated to 2011 dollars, and rounded
. 11. 15 percent of operator labor
. 12. 100 percent of maintenance labor
. 13. Based on conversion factor of 0.745 kW /hp
. 14. Performed by maintenance personnel
. 15. Maybe no need to replace
. 16. 60 percent of labor and maintenance materials
. 17. 2 percent of TCI
. 18. 1 percent of TCI
.

## B - 6 **Table B -**  **3. Model Costs to Install New** **DLA Parameters**  **SCD LCD**  **Footnotes** Control efficiency, percent HF 95% 95 % 1 HCl 3 0 % 30 % 1 Cl 2 42 % 42 % 1 Non - Hg HAP Metals 20 % 20 % 2 PM 20 % 20 % 1 SO 2 12 % 12 % 1 Design and operating parameters Fan hp 6 0 90 3 Total hp for other motors 1 0 4 0 3 L ime stone, lb/hr 8 5 1 20 3 Operator labor, hr/shift 1 .5 1 .5 4 Maintenance labor, hr/shift 0.7 5 0.7 5 3 Calculated parameters Reaction products, lb/hr 13.1 28.0 5 Reacted lime stone , lb/hr 14.4 30.8 Particulate matter, lb/hr 0.1 0.1 Wa ste, lb/hr 83.8 117.3 6 Cost factors L ime stone , $/ton 4 0 4 0 3 Capital costs Total capital investment 1 ,0 6 0,000 1 , 44 0,000 7 Annual costs Operating labor 31,030 33,155 Supervisory labor 4,654 4,973 8 Maintenance labor 17,066 18,235 Maintenance materials 17,066 18,235 9 Electricity 27,791 55,146 10 Lime stone 12,410 18,720 Wa ste disposal 12,230 18,295 11 Overhead 41,890 44,759 12 Administrative charges 21,200 28,800 13 Property taxes 10,600 14,400 14 Insurance 10,600 14,400 14 Capital recovery 100,057 135,926 Total annual cost, $/yr 306,593 405,045 1. Average from test data
. 2 . Assume same as PM
. 3 . Average from section 114 survey responses . 4 . Assume 2 times maintenance labor ( EPA, 2002 )
. 5
. CaF 2 (c alcium fluoride ), CaCl 2 (c alcium chloride ), and CaSO 3 (c alcium sulfite )
. 6 . Inlet lime stone minus reacted lime stone plus reaction products and PM
. 7 . Average of costs from section 114 survey responses scaled using 6/10 rule (based on acfm), escalated to 2011 dollars, and rounded
.

## B - 7

8 . 15 percent of operator labor
. 9 . 100 percent of maintenance labor
. 1 0 . Based on conversion factor of 0.745 kW /hp
. 11. Some facilities have minimal waste disposal costs. 12 . 60 percent of labor and maintenance materials
. 13 . 2 percent of TCI
. 14 . 1 percent of TCI
.

## Appendix **C Retrofit** **/Replacement Model Costs** 

## C - 2 **Table C**  **- 1. Model Costs to**  **Replace Existing Control Device with**  **DIFF**

**Parameters SCD**  **LCD Footnotes**  Control efficiency, percent HF 99.5% 99.5% 1 HCl 83 .3 % 83 .3 % 2 Cl 2 89 .3 % 89 .3 % 3 Non - Hg HAP Metals 94% 94% 4 PM 94% 94% 1 SO 2 4 8.7 % 4 8.7 % 5 Design and operating parameters Fan hp 150 190 6 Total hp for other motors 30 30 6 Hydrated lime, fraction of stoichiometric amount 2.65 1.79 7 Operator labor, hr/shift 2.5 2.5 8 Maintenance labor, hr/shift 1.25 1.25 6 Bag life, yr 5 5 6 Gas -to - cloth ratio (gross), ft/min 3.4 3.4 6 Bag area, ft2 28 28 6 Compressed air, ft 3/1,000 ft 3 0.9 0.9 6 Time to replace bags, hr/bag 2.25 2.25 6 Added cooling air, ft 3/min 0 0 9 Calculated parameters Hydrated lime makeup, lb/hr 91.4 132.0 Reaction products, lb/hr 29. 4 63. 1 10 Reacted lime, lb/hr 20.9 44. 7 Particulate matter, lb/hr 2.1 4. 6 Wa ste, lb/hr 102. 1 154. 9 11 Cost factors Hydrated lime, $/ton 160 160 6 Bag fabric cost, $/ft2 8.15 8.15 6 Compressed air, $/1,000 ft 3 0.24 0.24 12 Capital recovery factor-- bags 0.244 0.244 13 Retrofit factor 1.4 1.4 14 Capital costs Total capital investment 2,800,000 3,820,000 15 Annual costs Operating labor 51,716 55,258 Supervisory labor 7,757 8,289 16 Maintenance labor 28,444 30,392 Maintenance materials 28,444 30,392 17 Electricity 71,462 93,325 18 Lime 53,348 82,337 Compressed air 2,185 3,912 Annualized replacement bags 13,505 22,625 Annualized bag replacement labor 3,320 5,563 19

## C - 3 **Parameters SCD**  **LCD Footnotes**  Cage replacement 0 0 20 Wa ste disposal 14, 900 24,1 62 Overhead 69,817 74,598 21 Administrative charges 56,000 76,400 22 Property taxes 28,000 38,200 23 Insurance 28,000 38,200 23 Capital recovery 263,913 359,932 Total annual cost, $/yr 720,8 11 943,5 85 1. Average from test data with better efficiency than baseline
. 2. Based on ratio of enhanced HF reduction and baseline HCl reduction
. 3. Based on ratio of enhanced HF reduction and baseline Cl 2 reduction
. 4. Assume same as PM
. 5. Based on ratio of enhanced H F reduction and baseline SO 2 reduction
. 6. Average from section 114 survey responses . 7. Assume hydrated lime is 2.65/1.79 times the stoichiometric amount needed to get additional control re baseline (from 98% to 99.5%)
. 8. Assume 2 times maintenance labor ( EPA, 2002 )
. 9. Assume none. 10. CaF 2 (c alcium fluoride ), CaCl 2 (calcium chloride ), and CaSO 3 (c alcium sulfite )
. 11. Inlet lime minus reacted lime plus reaction products and PM
. 12. Pollution Prevention (P2) Pays, NC Division of Pollution Prevention and Environmental Assistance. Determine the Cost of Compressed Air for Your Plant. Energy Tips - Compressed Air, Compressed Air Tip Sheet #1. August 2004. We b site : http://www.p2pays.org/ref/40/39536.pdf
. 13. Based on equipment life of 5 years and 7 percent interest
. 14. Average for various control devices ( EPA, 2002 )
. 15. Average of costs from section 114 survey responses scaled using 6/10 rule (based on acfm), escalated to 2011 dollars, multiplied by retrofit cost factor, and rounded
. 16. 15 percent of operator labor
. 17. 100 percent of maintenance labor
. 18. Based on conversion factor of 0.745 kW /hp
. 19. Perfor med by maintenance personnel
. 20. Maybe no need to replace
. 21. 60 percent of labor and maintenance materials
. 22. 2 percent of TCI
. 23. 1 percent of TCI
.

## C - 4 **Table C**  **- 2. Model Costs to Retrofit Fabric Filter**  **to Existing Control Device**

**Parameters SCD**  **LCD Footn**  **otes** Control efficiency, percent Non - Hg HAP Metals 94% 94% 1 PM 94% 94% 2 Design and operating parameters Fan hp 150 190 3 Total hp for other motors 30 30 3 Operator labor, hr/shift 2.5 2.5 4 Maintenance labor, hr/shift 1.25 1.25 3 Bag life, yr 5 5 3 Gas -to - cloth ratio (gross), ft/min 3.4 3.4 3 Bag area, ft2 28 28 3 Compressed air, ft 3/1,000 ft 3 0.9 0.9 3 Time to replace bags, hr/bag 2.25 2.25 3 Added cooling air, ft 3/min 0 0 5 Calculated parameters Wa ste, lb/hr 2.1 4. 6 6 Cost factors Bag fabric cost, $/ft2 8.15 8.15 3 Compressed air, $/1,000 ft 3 0.24 0.24 7 Capital recovery factor-- bags 0.244 0.244 8 Cost of dry injection system 800,907 1,230,278 9 Retrofit factor 1.4 1.4 10 Capital costs Total capital investment 1,680,000 2,100,000 11 Annual costs Operating labor 51,716 55,258 Supervisory labor 7,757 8,289 12 Maintenance labor 28,444 30,392 Maintenance materials 28,444 30,392 13 Electricity 71,462 93,325 14 Compressed air 2,185 3,912 Annualized replacement bags 13,505 22,625 Annualized bag replacement labor 3,320 5,563 15 Cage replacement 0 0 16 Wa ste disposal 3 11 7 12 Overhead 69,817 74,598 17 Administrative charges 33,600 42,000 18 Property taxes 16,800 21,000 19 Insurance 16,800 21,000 19 Capital recovery 158,193 197,576 Total annual cost, $/yr 502,35 4 606,6 42 1. Assume same as PM
. 2. Average from test data with better efficiency than baseline
. 3. Average from section 114 survey responses .

## C - 5

4. Assume 2 times maintenance labor ( EPA, 2002 )
. 5. Assume none
. 6. Particulate matter
. 7. Pollution Prevention (P2) Pays, NC Division of Pollution Prevention and Environmental Assistance. Determine the Cost of C ompressed Air for Your Plant. Energy Tips - Compressed Air, Compressed Air Tip Sheet #1. August 2004. We b site: http://www.p2pays.org/ref/40/39536.pdf
. 8. Based on equipment life of 5 years and 7 percent interest
. 9. Based on cost equations in the June 19, 2009 memorandum Revised Baseline Operating Costs for Existing HM IWI , in Docket ID No. EPA- HQ - OAR- 2006 - 0534 for the HMIW I rule
. 10. Average for various control devices ( EPA, 2002 )
. 11. Average of costs from section 114 survey respo nses scaled using 6/10 rule (based on acfm), subtracted cost of dry injection system, escalated to 2011 dollars, multiplied by retrofit cost factor, and rounded
. 12. 15 percent of operator labor
. 13. 100 percent of maintenance labor
. 14. Based on conversio n factor of 0.745 kW /hp
. 15. Performed by maintenance personnel
. 16. Maybe no need to replace
. 17. 60 percent of labor and maintenance materials
. 18. 2 percent of TCI
. 19. 1 percent of TCI
.

## C - 6 **Table C -**  **3. Model Costs to Retrofit AC**  **I Sy** **stem to Existing Control Device**  **Parameters MA** **CT Floor Beyond the Floor**  **Foot notes**  **SCD LCD**  **SCD LCD**  Design and operating parameters Carbon injection rate (lb/MMft 3 ) [CIR] 2 2 3 3 1 Injection blower fan power (hp) [Power fan ] 5.2 8.7 5.2 8.7 2,3 Projected equipment life (yrs) [n] 15 15 15 15 2 Interest rate (%) [i] 7 7 7 7 Calculated parameters Carbon feed rate (lb/hr) [CFR] 2.8 4.6 4.2 7.0 4 Cost factors Carbon unit cost ($/lb) [CC] 0.85 0.85 0.85 0.85 5 Escalation factor [EF] 1.78 1.78 1.78 1.78 2, 6,7 Capital recovery factor [CRF] 0.1098 0.1098 0.1098 0.1098 2,8 Retrofit factor [RF] 1.15 1.15 1.15 1.15 2 Direct capital costs Purchased equipment costs Total equipment [TEC] (see Note) $24,294 $34,864 $24,294 $34,864 2 ,9 Sales tax $729 $1,046 $729 $1,046 2 ,10 Freight $1,215 $1,743 $1,215 $1,743 2 ,11 Purchased equipment with tax and freight $26,238 $37,653 $26,238 $37,653 2 ,12 Purchased equipment with escalation $46,784 $67,138 $46,784 $67,138 2 ,13 Purchased equipment with retrofit factor [PEC] $53,802 $77,209 $53,802 $77,209 2 ,14 Installation cost [IC] $16,141 $23,163 $16,141 $23,163 2 ,15 Total direct costs [TDC] $69,942 $100,371 $69,942 $100,371 2 ,16 Indirect capital costs Engineering $10,760 $15,442 $10,760 $15,442 2 ,17 Construction and field expense $10,760 $15,442 $10,760 $15,442 2 ,17 Contractor fees $5,380 $7,721 $5,380 $7,721 2 ,18 Start- up $538 $772 $538 $772 2 ,19 Performance test $538 $772 $538 $772 2 ,19 Model study $1,076 $1,544 $1,076 $1,544 2 ,20 Contingencies $3,228 $4,633 $3,228 $4,633 2 ,21

## C - 7 **Parameters MA** **CT Floor Beyond the Floor**  **Foot notes**  **SCD LCD**  **SCD LCD**  Total indirect costs [TIC] $32,281 $46,325 $32,281 $46,325 2 ,22 Total capital cost Total capital investment [TCI] $102,224 $146,697 $102,224 $146,697 2 ,23 Annual costs Operating labor $6,895 $7,368 $6,895 $7,368 2 ,24 Supervisory labor $1,034 $1,105 $1,034 $1,105 2 ,25 Maintenance labor $11,378 $12,157 $11,378 $12,157 2 ,26 Maintenance materials $2,690 $3,860 $2,690 $3,860 2 ,27 Electricity cost $2,298 $4,108 $2,298 $4,108 2 ,28 Carbon cost $17,374 $30,498 $26,061 $46,410 2 ,29 Solid waste disposal cost $409 $718 $613 $1,092 2 ,30 Overhead $13,198 $14,694 $13,198 $14,694 2 ,31 Administrative charges $2,044 $2,934 $2,044 $2,934 2 ,32 Property tax $1,022 $1,467 $1,022 $1,467 2 ,33 Insurance $1,022 $1,467 $1,022 $1,467 2 ,33 Capital recovery $11,224 $16,107 $11,224 $16,107 2 ,34 Total annual cost $70,589 $96,482 $79,480 $112,768 2 ,35 Note : Total equipment includes storage silo, feed bin, gravimetric feeders, pneumatic conveyor, and injection ports. Footnotes : 1. Thompson , 2013. Suggested carbon concentration of 2 lb/MMft 3

. 2. EPA, 2005, Appendix J. 3. Scaled H WChp estimate using ratio of exhaust flow rates: (15 hp) x Q / (66,870.6 acfm)
. 4. Equal to CIR / 1E6 x exhaust flow x (60 min/hr)
. 5. Holloway , 2013 a . Indicated carbon price would be $0.80 to $0.90/lb. Used average of $0.85/ lb. 6. Escalating costs from 2004 (H WC ) to 2011 (BSCP) using the following factors: (H WCescalation factor, 1.1319 x 1.064) x (BS CP escalation factor, 1.4805)
. 7. Chemical Engineering Plant Cost Index
. 8. Equal to = [i x (1 + i) n ] / [(1 + i) n - 1], where i = 7 percent interest and n = 15 -year equipment life
. 9. Equal to 90,000 x (exhaust flow/150,000) 0.7

. 10. Equal to 0.03 x TEC
. 11. Equal to 0.05 x TEC
.

## C - 8

12. Equal to TEC + (sales tax) + (freight)
. 13. Equal to EF x (purchased equipment with ta x and freight)
. 14. Equal to RF x (purchased equipment with escalation)
. 15. Equal to 0.3 x PEC
. 16. Equal to PEC + IC
. 17. Equal to 0.2 x PEC
. 18. Equal to 0.1 x PEC
. 19. Equal to 0.01 x PEC
. 20. Equal to 0.02 x PEC
. 21. Equal to 0.06 x PEC
. 22. Equal to sum of indirect costs
. 23. Equal to TDC + TIC
. 24. Equal to (1 hr/d) x operating hr/yr / (24 hr/d) x operator wage rate ($/hr)
. 25. Equal to 0.15 x (operator labor cost)
. 26. Equal to (0.5 hr/shift) x (3 shifts/d) x operating hr/yr / (24 hr/d) x maintenance wage rate ($/hr)
. 27. Equal to 0.05 x PEC
. 28. Equal to Power fan / (1.34 hp/kW ) / (0.9 Efficiencyfan ) x operating hr/yr x electricity unit cost ($/kW h)
. 29. Equal to CFR x operating hr/yr x carbon unit cost ($/lb)
. 30. Equal to CFR x operating hr/yr / (2000 lb/ton) x waste disposal unit cost ($/ton)
. 31. Equal to 0.6 x (operating labor cost + maintenance cost)
. 32. Equal to 0.02 x TCI
. 33. Equal to 0.01 x TCI
. 34. Equal to CRF x TCI
. 35. Equal to sum of annual costs
.

## Appendix **D Model Impacts Equations** 

## D - 2

**Table D**  **- 1.**  **Equations Used to Estimate Model**  **Energy and**  **Secondary Impacts**  **Parameters Value**  **Notes, units, and equations Energy impacts**  Heat factors Heat content of electricity (HC elec ) 3,415 Btu/kW h Heat rate Coal (HR coal ) 10,415 Btu/kW h Natural gas (HR gas ) 8,185 Btu/kW h Nuclear power (HR nuclear ) 10,452 Btu/kW h Renewable energy (HR renew ) 9,756 Btu/kW h Percent of generation Coal (% coal) 48% Used for solid fuel Oil/natural gas (% gas) 18% Used for natural gas Nuclear (% nuclear) 20% No secondary emissions estimated Hydroelectric (% hydro) 7% No secondary emissions estimated Renewable (% renew) 6% No secondary emissions estimated Other (% other) 1% Used for natural gas (assumed equivalent) Power plant efficiency (E) Coal (E coal ) 33% % = HC elec / HR coal * 100 Natural gas/other (E gas ) 42% % = HC elec / HR gas * 100 Nuclear (E nuclear ) 33% % = HC elec / HR nuclear * 100 Renewable/hydroelectric (E renew ) 35% % = HC elec / HR renew * 100 Average (E avg ) 35% % = (E coal x % coal) + (E gas x % gas/other) + (E nuclear x % nuclear) + (E renew x % renew/hydro) Energy impacts calculations Electricity requirements model - specific kW h/yr = total hp x (0.745 kW/hp) x operating hr/yr Energy impacts model - specific MMBtu/yr = (kW h/yr) x (HC elec ) x (MMBtu/1E 6 Btu) / E avg 

### Secondary emissions Emission factors, natural gas Particulate matter/PM 2.5 1.9 lb/MM ft 3 natural gas 0.00186275 lb/MMBtu natural gas Carbon monoxide 84 lb/MM ft 3 natural gas 0.0824 lb/MMBtu natural gas Nitrogen oxide 100 lb/MM ft 3 natural gas 0.0980 lb/MMBtu natural gas Sulfur dioxide 0.6 lb/MM ft 3 natural gas 0.00059 lb/MMBtu natural gas Emission factors, solid fuel Particulate matter 0.03 lb/MMBtu solid, liquid, gaseous fuel PM 2.5 0.00957 lb/MMBtu solid, liquid, gaseous fuel Carbon monoxide 0.19 lb/MMBtu bituminous coal Nitrogen oxide 0.38 lb/MMBtu solid fuel Sulfur dioxide 1.2 lb/MMBtu solid fuel

## D - 3 **Parameters Value**  **Notes, units, and equations** Secondary emissions calculation Secondary emissions, for each pollutant model - specific lb/yr = MMBtu/yr x [(lb/MMBtu natural gas) x (% gas/other) + (lb/MMBtu solid fuel) x (% coal)] 

### Solid waste and wastewater impacts Solid waste impacts model - specific tpy = waste (lb/hr) x operating hr/yr / (2,000 lb/ton) Wa stewater impacts model - specific gpy = water usage (gpd) x operating hr/yr / (24 hr/d) 1. gpy = gallons per year; gpd = gallons per day. 2 . Assume electricity generated using the above mix (from IPM Version 3.0 for the year 2015), as determined from Table 3 - 6 of Regulatory I mpacts A nalysis for the final M ercury and Air Toxics Standards . IPM = EPA Integrated Planning Model, which is a multi - regional, dynamic, deterministic linear programming model of the U.S. electric power sector that provides forecas ts of least- cost c apacity expansion, electricity dispatch, and emission control strategies for meeting energy demand and environm ental, transmission, dispatch, and reliability constraints. 3 . For natural gas, used PM, CO, NO X , and SO 2 emission factors from AP -42 chapter on natural gas combustion
. Assumed 1,020 Btu/ft 3 of natural gas in estimating PM, CO, NO X , and SO 2 secondary emissions. Also assumed that 100% of PM is PM 2.5 , based on statement in AP -42 that PM from natural gas combustion is estimated to be less than 1 micron in size. 4 . For solid fuel, used PM and SO 2 emission limits for solid fuel -fired boilers from 2006 CFR edition of NSPS for electric utility plants (40 CFR part 60, subpart Da) and used NO X and CO emission factors from AP -42 chapter on coal combustion (bituminous/subbituminous coal) . The NO X emission factor was based on average of NO X emission factors for PC dry- bottom wall -fired NSPS boilers burning bituminous (12 lb/ton) and subbituminous (7.4 lb/ton) coal. Assumed 13,000 Btu/lb of coal in estimating NO X and CO secondary emissions. According to AP -42, the percentage of PM that is PM 2.5 for dry- bottom coal -fired boilers is 29% with ESP, 53% with FF, and 6% if uncontrolled. Assumed 84% of utility boilers controlled with ESP and 14% with FF, leaving 2% uncontrolled, based on information from EPA document on control of emissions from coal -fired utility boilers.

## Appendix **E Installation**  **Model Impacts**

## E - 2 **Table E -**  **1. Model Impacts of**  **Installing Ne w**  **DIFF Parameters**  **SCD LCD**  Control efficiency HF 99.5% 99.5% H Cl 83 .3 % 83 .3 % C l 2 89 .3 % 89 .3 % Non - Hg HAP metals 94% 94% PM 94% 94% SO 2 4 8.7 % 4 8.7 % P arameters Fan hp 150 190 Total hp for other motors 30 30 Wa ste, lb/hr 102. 1 154. 9 Emissions reductions, tpy HF 15.1 34.6 HCl 1.7 2 3.9 4 Cl 2 0.0789 0.18 1 Non - Hg HAP metals 0.08 55 0.19 6 PM 7. 78 17. 8 SO 2 40.2 92.1 Energy impacts, MMBtu/yr 9,620 12,563 Secondary air impacts, tpy Particulate matter 0.0710 0.0927 PM 2.5 0.0238 0.0311 Carbon monoxide 0.120 0.156 Nitrogen oxides 0.951 1.24 Sulfur dioxide 2.77 3.62 Solid waste impacts, tpy 372 604

## E - 3 **Table E**  **- 2**  **. Model Impacts of Installing**  **/Retrofitting Fabric Filter** 

**Parameters SCD**  **LCD** Control efficiency Non - Hg HAP metals 94% 94% PM 94% 94% P arameters Fan hp 150 190 Total hp for other motors 30 30 Wa ste, lb/hr 2.1 4. 6 Emissions reductions, tpy Non - Hg HAP metals 0.0855 0.196 PM 7.78 17.8 Energy impacts, MMBtu/yr 9,620 12,563 Secondary air impacts, tpy Particulate matter 0.0710 0.0927 PM 2.5 0.0238 0.0311 Carbon monoxide 0.120 0.156 Nitrogen oxides 0.951 1.24 Sulfur dioxide 2.77 3.62 Solid waste impacts, tpy 7. 78 17. 8

## E - 4 **Table E -**  **3 . Model Impacts**  **of Installing Ne** **w DLA Parameters**  **SCD LCD**  Control efficiency HF 95% 95% HCl 30% 30% Cl 2 42% 42% Non - Hg HAP metals 20% 20% PM 20% 20% SO 2 12% 12% P arameters Fan hp 6 0 90 Total hp for other motors 1 0 4 0 Wa ste, lb/hr 83.8 117.3 Emissions reductions, tpy HF 14.4 33.0 HCl 0.620 1.42 Cl 2 0.0371 0.0850 Non - Hg HAP metals 0.0182 0.0417 PM 1.65 3.79 SO 2 9.90 22.7 Energy impacts, MMBtu/yr 3,741 7,424 Secondary air impacts, tpy Particulate matter 0.0276 0.0548 PM 2.5 0.00925 0.0184 Carbon monoxide 0.0465 0.0923 Nitrogen oxides 0.370 0.734 Sulfur dioxide 1.08 2.14 Solid waste impacts, tpy 306 457

## Appendix **F Retrofit** **/Replacement Model Impacts** 

## F - 2

**Table F -**  **1 .**  **Model Impacts of Retrofitting ACI System to Existing Control Device** 

**Parameters MA** **CT Floor Beyond the Floor**  **SCD LCD**  **SCD LCD**  Parameters Injection blower fan power, hp 5.2 8.7 5.2 8.7 Carbon feed rate, lb/hr 2.8 4.6 4.2 7.0 Mercury emissions reduction, tpy 0.001 36 0.003 11 0.00152 0.00347 Energy impacts, MMBtu/yr 309 553 309 553 Secondary air impacts, tpy Particulate matter 0.00228 0.00408 0.00228 0.00408 PM 2.5 0.000765 0.00137 0.000765 0.00137 Carbon monoxide 0.0038 5 0.00688 0.0038 5 0.00688 Nitrogen oxides 0.0306 0.0547 0.0306 0.0547 Sulfur dioxide 0.0891 0.159 0.0891 0.159 Solid waste impacts, tpy 10.2 17.9 15.3 27.3

## F - 3

**Table F**  **- 2**  **. Model Impacts of Replacing**  **Dry Limestone A dsorber**  **with New DIFF Parameters**  **SCD LCD**  **DLA DIFF**  **Increm. DLA**  **DIFF Increm.**  Control efficiency HF 95% 99.5% 95% 99.5% HCl 30% 83.3% 30% 83.3% Cl 2 42% 89.3% 42% 89.3% Non - Hg HAP metals 20% 94% 20% 94% PM 20% 94% 20% 94% SO 2 12% 48.7% 12% 48.7% P arameters Fan hp 60 150 90 190 Total hp for other motors 10 30 40 30 Wa ste, lb/hr 83. 8 102.1 117 .3 154.9 Emissions reductions, tpy HF 14. 4 15. 1 0.6 83 33. 0 34. 6 1.5 6 HCl 0.6 20 1.7 2 1. 10 1.4 2 3.9 4 2. 52 Cl 2 0.0371 0.07 89 0.041 8 0.0850 0.181 0.0958 Non - Hg HAP metals 0.018 2 0.08 55 0.067 3 0.041 7 0.19 6 0.15 4 PM 1.6 5 7. 78 6. 12 3.7 9 17. 8 1 4.0 SO 2 9.90 40.2 30.3 22.7 92.1 69.4 Energy impacts, MMBtu/yr 3,741 9,620 5,879 7,424 12,563 5,139 Secondary air impacts, tpy Particulate matter 0.0276 0.0710 0.0434 0.0548 0.0927 0.0379 PM 2.5 0.00925 0.0238 0.0145 0.0184 0.0311 0.0127 Carbon monoxide 0.0465 0.120 0.0731 0.0923 0.156 0.0639 Nitrogen oxides 0.370 0.951 0.581 0.734 1.242 0.508 Sulfur dioxide 1.08 2.77 1.69 2.14 3.62 1.48 Solid waste impacts, tpy 306 372 66.8 457 604 147

## F - 4 **Table F**  **- 3**  **. Model Impacts of Replacing**  **Spray Dry** **er/ESP with New**  **DIFF Parameters**  **SCD LCD**  **SD/ESP 1**  

### DIFF **Increm. 2**  

### SD/ESP **1** 

### DIFF **Increm .**  **2** Parameters Fan hp 125 250 Total hp for other motors 200 400 Water usage, gpd 6.25 12.5 Emissions reductions, tpy HF - 2.36 15. 1 17.5 - 2.72 34. 6 37.3 HCl - 2.21 1.7 2 3.93 -4.41 3.9 4 8.3 5 Cl 2 - 0.455 0.07 89 0.534 - 0.958 0.181 1.14 Non - Hg HAP metals 0.0855 0.08 55 0.00 0.196 0.19 6 0.00 PM 7.78 7. 78 0.00 17.8 17. 8 0.00 SO 2 39.6 40.2 0.606 90.7 92.1 1.39 Energy impacts, MMBtu/yr 17,369 9,620 - 7,749 37,118 12,563 - 24,555 Secondary air impacts, tpy Particulate matter 0.128 0.0710 - 0.0572 0.274 0.0927 - 0.181 PM 2.5 0.0430 0.0238 - 0.0192 0.0918 0.0311 - 0.0607 Carbon monoxide 0.216 0.120 - 0.0964 0.462 0.156 - 0.305 Nitrogen oxides 1.72 0.951 - 0.766 3.67 1.242 - 2.43 Sulfur dioxide 5.00 2.77 - 2.23 10.7 3.62 - 7.07 Solid waste impacts, tpy 365 372 7.22 591 604 12.9 Wa stewater impacts, gpy 1,901 0 - 1,901 4,063 0 -4,063 1 The n egative emission reduction estimates for the SD/ESP are a result of the small dataset for kilns with this type of control and the lack of control efficiency information for SD/ESP
. 2 A negative increase in impacts would be equivalent to a reduction in impacts.

## F - 5

**Table F -** **4 . Model Impacts**  **of Replacing Existing DIFF with New,**  **More Efficient DIFF**
**Parameters SCD**  **LCD Existin**  **g DIFF**  **New**

**DIFF Increm.**  **Existing DIFF**  **New**

**DIFF Increm.**  Control efficiency HF 98% 99.5% 98% 99.5% HCl 82% 83.3% 82% 83.3% Cl 2 88% 89.3% 88% 89.3% Non - Hg HAP metals 72% 94% 72% 94% PM 72% 94% 72% 94% SO 2 48% 48.7% 48% 48.7% P arameters Fan hp 15 0 150 1 90 190 Total hp for other motors 3 0 30 3 0 30 Wa ste, lb/hr 100.1 102.1 151.6 154.9 Emissions reductions, tpy HF 14.9 15. 1 0.2 28 34.0 34. 6 0.52 1 HCl 1.69 1.7 2 0.025 9 3.88 3.9 4 0.05 94 Cl 2 0.0778 0.07 89 0.00119 0.178 0.181 0.0027 2 Non - Hg HAP metals 0.0655 0.08 55 0.0 200 0.150 0.19 6 0.045 8 PM 5.96 7. 78 1.8 2 13.6 17. 8 4.1 7 SO 2 39.6 40.2 0.606 90.7 92.1 1.39 Energy impacts, MMBtu/yr 9,620 9,620 0 12,563 12,563 0 Secondary air impacts, tpy Particulate matter 0.0710 0.0710 0 0.0927 0.0927 0 PM 2.5 0.0238 0.0238 0 0.0311 0.0311 0 Carbon monoxide 0.120 0.120 0 0.156 0.156 0 Nitrogen oxides 0.951 0.951 0 1.242 1.242 0 Sulfur dioxide 2.77 2.77 0 3.62 3.62 0 Solid waste impacts, tpy 365 372 7.22 591 604 12.9