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 

# SubjecttoConfidentialityClaim

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 limitfor 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 SubjecttoCOnfidentiality

# Claim

fSNCRC

## ost

## sand NO x 

## V" lSI 

## "bTt I

## mpactS 

## Summary 0 I 

### Ity

ControlOption Estimated Annualized Cost Efficiency (%)

30% Commercial SNCR $670,879 Dust Scoops SNCR $575,519 30% Baseline $0 0% NOx Emissions Rate (lbs/hr)

1,098 1,098 \,568 Gates oftheMountains Wilderness Area " Visibility Cost Improvement Effectiveness (deciviews 24 ($/deciview) hr) $1,148,766 0.584 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 letterorattachment 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 NOxVisibility Analysis

Control Option Annualized Cost Control Efficiency (%) NOx Emissions

(Ibs/hr) NOx Emissions (tons/vear) Tons Removed peryear Cost $/ton Gates ofthe Mmmtains Yellowstone National Park NOx (deciview) Deciviews (24 hr
- "')

. Cost ($/dc) NOx (deciview) Deciviews (24 hr
- "') Cost ($/dc) Commercial SNCR $670,879 30% 1,098 4,807 2,060 $326 0.976 0.584 $1,148,766 0.934 0.626 $1,071,692 Dust Scoops SNCR $575,519 30% 1,098 4,807 2,060 $279 0.976 0.584 $985,478 0.934 0.626 $919,360 Baseline $0 0% 1,568 6,868 0 1.560 0.000 1.560 0.000



# ,- ... 

# .-



# ­ co= ...­ ;;,.)



# -- "a 

# -- 

# .. as 8 ..s



# .

i ..l

# SubjecttoConfidentialityClaim
Halcim 

### us. Inc. Trident Facility Commercial Selective Non-Catalytic Reduction Factor. Cost 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 2% Administrative Charges of TCI $26,256 1% Property Taxes of TCI $13,128 1% Insurance of TCI $13,128 0.11 Capital Recovery Factor (15 yrs at 7%) $144,408 $1,312,800 Total Capital Cost Total Indirect Annual Costs. lAC TOTAL ANNUAL COST $227.538 $670.879

# .. 

# SubjecttoConfidentialityClaim Holcim US. Inc. 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 equipmentsum (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/dayx 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

# SubjecttoConfidentialityClaim