Holcim (US) Inc. Phone 406 285 3241 

4070 Trident Road Fax 406 285 3100 

July 22, 2008 Three Forks, MT 59752 www.holcim.com/us 

Laurel Dygowski OCNKE§~j.!ti-o)/j Regional Haze Coordinator 

Air Quality Planning and Management Unit 

US EPA - Region 8 

1595 Wynkoop Street 

Denver, CO 80202-1129 Subject to Confidentiality Claim 

Dear Ms. Dygowski: 

RE: Holcim SNCR Cost Estimates for BART Analysis 

As previously requested by EPA Region VIII, as part of our BART analysis, 

Holcim US, Inc. (Holcim) has assembled cost estimates for two types of selective 

non-catalytic reduction (SNCR) systems for NOx control at the Trident facility. 

Holcim has previously committed in a January 25, 2008 BART submittal to 

installing and testing an SNCR system on the kiln as a trial system. 

Holcim would install, operate and test the new SNCR system for a period of time 

(one year for example), analyze the actual NOx reductions achieved from that 

system, and then propose a new BART-derived limit for NOx for the kiln. 

Holcim has received a quote on a commercially available SNCR system for NOx 

control. This system functions by injecting an aqueous urea solution into the mid 

kiln area while the kiln is in operation. The NOx control efficiency for this system 

is estimated at 30% for the purpose of this analysis. 

Holcim has also assembled a cost estimate for a SNCR system which would 

utilize a solid, pelletized form of urea. The urea would be inserted mid-kiln 

through the existing dust scoops mechanism which is also used to recycle 

cement kiln dust. The NOx control efficiency for this system is also estimated at 

30% for the purpose of this analysis. 

Holcim has prepared annualized cost estimates for the SNCR systems in the 

format similar to those previously submitted in our BART analysis. The 

annualized costs are based on a 15 year life and 7% interest. The table below 

summarizes the annualized costs, visibility impacts and cost effectiveness in 

dollars per de.ci.v.iew o~t. two analyzed systems. 

, )} 

/\/("'~. 6' ) <,,~" '. ~r '\ \j)\) \' (.(..()\~~t\C:'\~;} n
 

G· ../' r-;.~ , . .v\ 

I

\ \ 

" " ~..I" • r-o \\..~~. Ii \!~ '\~ \V
 \~.'~~'" \f\\' 1\ \;\} \J \
 
--

~1ttt;,,\

"- Holcim Subject to COnfidentiality Claim 

Summary 0	 fSNCRCostsand NO x V"lSI"bTt I Ity I mpactS

Control Option 

Estimated 

Annualized 

Cost 

Efficiency 

(%) 

Commercial SNCR $670,879 30%

Dust Scoops SNCR $575,519 30% 

Baseline $0 0% 

NOx Emissions
 

Rate
 

(lbs/hr)
 

1,098
 

1,098
 

\,568
 

Gates of the Mountains Wilderness Area " 

Visibility Cost Improvement Effectiveness (deciviews 24 ($/deciview) hr) 

0.584 $1,148,766

0.584 $985,478 

0 

Visibility 

Impact 

(deciview) 

0.976 

0.976 

1.560 

A more detailed cost analysis for the two SNCR systems is contained in the 

attached spreadsheets. Please note Holcim considers the cost data 

contained in this letter and attachment CONFIDENTIAL and requests that 

EPA not distribute or publish the letter or attachment pages. 

Because SNCR is temperature dependent, Holcim would start the trial process 

by installing the necessary equipment to determine the location of the proper 

temperature zone within the kiln. This would be accomplished by installing a 

series of thermocouples on the kiln during the planned annual outage in 2009. 

Holcim would continue by procuring and installing the necessary equipment 

during the following planned annual outage to test the more cost effective SNCR 

system. 

Holcim hopes this information is helpful in the analysis. Please let us know if you 

have any questions on this information. I can be reached at 406-285-3985. 

Eric Ervin 

Plant Manger 

cc:	 Greg Gannon - Holcim 

Hector Ybanez - Holcim 

Chris Hiltunen - Bison Engineering 

Attachments 
Holcim US, Inc. 

Trident Facility 

SNCR Cost Summary and NOx Visibility Analysis 

Control Option Annualized Cost 

Control 

Efficiency 

(%) 

NOx 

Emissions 

(Ibs/hr) 

NOx 

Emissions 

(tons/vear) 

Tons 

Removed 

per year Cost $/ton 

Gates of the Mmmtains 

NOx 

(deciview) 

Deciviews 

(24 hr - "') . 

Cost 

($/dc) 

N

(dec

Commercial SNCR $670,879 30% 1,098 4,807 2,060 $326 0.976 0.584 $1,148,766 0.9

Dust Scoops SNCR $575,519 30% 1,098 4,807 2,060 $279 0.976 0.584 $985,478 0.9

Baseline $0 0% 1,568 6,868 0 1.560 0.000 1.5

...
 ,-

.-­

co= ...­

;;,.) 

--

"a

--..
 


 as
 

8
 

..s .
 

i 

..l 
Subject to Confidentiality Claim 

Halcim us. Inc. 

Trident Facility 

Commercial Selective Non-Catalytic Reduction 

Cost Factor. Item 

DIRECT COSTS 

Purchased equipment costs 

SNCR License Fees 200,000 

SNCR Equipment 200,000 

Variable Frequency Drive Modifications 20,000 

Non-quoted Mechanical Equipment (mixing tanks, pumps, etc.) 266,000 

Electrical Equipment 70,000 

Purchased equipment sum (A) 756.000 

Freight 0.05(Al 37,800 

Purchased equipment cost. PEC (B) = 793.800 

IDRECT1Ns.IALLATION COSTS 

Foundations & supports - civil work 25,000 

Handling & erection 200.000 

Mid Kiln Injection Port Installation 35,000 

Direct installation costs (C) 260.000 

Total Direct Costs. DC (B+C) 1.053.800 

INDIRECT INSTALLATION COSTS IIC 

Engineering 110.000 

Commissioning 40.000 

Tech Support and Training 40.000 

Contingencies 69.000 

Total Indirect Costs. IIC 259.000 

Total CaDitallnvestment = DC + IIC $1.312.800 

Cost Item 

DIRECT ANNUAL COSTS 

Operating Labor 

Operator 540 man hrs $30.00 /hr $16.200 

Note: 0.5 hrs/shift x 3 shifts/day x 360 days/yr 

Supervisor 15 % of operator $2,430 

Maintenance 

Labor 540 man hrs $30.00 /hr $16.200 

Note: 0.5 hrs/shift x 3 shifts/day x 360 days/yr 

Material 100% of rnaint. labor $16,200 

Utilities (Assumed) 

Electricity (1 % of Capital Cost) $13,128 

Reagent $379,183 

Total Direct Annual Costs. DAC $443.341 

INDIRECT ANNUAL COSTS 

Overhead (60% of total operating & maintenance costs) $30,618 

Administrative Charges 2% of TCI $26,256 

Property Taxes 1% of TCI $13,128 

Insurance 1% of TCI $13,128 

Capital Recovery Factor (15 yrs at 7 %) 0.11 $144,408 

Total Capital Cost $1,312,800

Total Indirect Annual Costs. lAC 

TOTAL ANNUAL COST 

$227.538 

$670.879 
.. 

Holcim US. Inc.
 Subject to Confidentiality Claim

Trident Facility
 

Dust Scoops Selective Non-Catalytic Reduction System 

Cost Item Fa,etar 

DIRECT COSTS 

Purchased equipment costs 

Mechanical Equipment 266,000 

Electrical Equipment 70,000 

Purchased equipment sum (A) 336,000 

INDIRECT INSTALLATION COSTS IIC 

Engineering 110,000 

Contingencies 29000 

Total Indirect Costs, IIC 139.000 

Total Ca itaI Investment = DC + IIC 

Cost Item 

Operating Labor
 

Operator
 

Supervisor
 

Maintenance
 

Labor
 

Material 100% of maint. labor, 

Utilities (Assumed)
 

Electricity! 1% of Capital CO$t)
 

540 man hrs 

Note: 0.5 hrs/shift x 3 shifts/day x 

540 man hrs $30.00 

Note: 0.5 hrs/shift x 3 shifts/day x 360 dayslyr 

15% of operator 

Reagent 

Total Direct Annual Costs, DAC 

2% of TCI 

1 % of TCI 

1 % of TCI 

0.11 

$716.800 

INDIRECT ANNUAL COSTS 

Overhead (60% of total operating & maintenance costs) 

Administrative Charges 

Property Taxes 

Insurance 

Capital Recovery Factor (15 yrs at 7%) 

Total Capital Cost 

Total Indirect Annual Costs, lAC 

TOTAL ANNUAL COST 

$379,183 

$437,381 

$30,618 

$14,336 

$7,168 

$7,168 

$78,848 

$138,138 

$575,519 
Subject to Confidentiality Claim