Holcim (US) Inc. Phone 406 285 3241 

4070 Trident Road Fax 4062853100 

Three Forks, MT 59752 www.holcim.com/us 

t'Holcim 

June 9,2009 

US EPA - Region 8 

Air Quality Planning Unit 

Attn: Laurel Dygowski 

1595 Wynkoop Street 

Denver, CO 80202-1129 

VIA CERTIFIED US MAIL #7009 0820 0000 3084 0016 

RE:	 BART - Low NOx BURNER 

Dear Ms. Dygowski: 

As requested by EPA, Holcim (US) - Trident Plant is submitting additional information regarding 

the estimated costs for the low NOx burner control technology provided in our original BART 

Analysis dated July 6, 2007. 

As discussed in our telephone conversation on June 3, 2009, this low NOx burner cost analysis 

considers modification requirements to the firing system necessary to employ such a burner. 

As noted in EPA's document "NOx Control Technologies for Cement Industry" (September 19, 

2000), a low NOx burner would require low primary air and, thus, conversion of Trident's firing 

system from a direct to an indirect system. This modification would require several changes 

including but not limited to installation of a baghouse, additional explosion prevention, 

pulverized coal storage and dosing equipment in addition to the low NOx burner. Accordingly, 

the annualized costs included in the original submittal were nearly half of what is currently 

estimated. The original annualized costs were estimated to be $498,065 compared to the 

detail as shown in the attached table of $846,061. Also, attached are updates to Tables 4-4,4­

5 and 4-6 that were included in the original BART Analysis. The incremental increase in 

annualized costs for the low-NOx burner correlates to a cost per deciview increase from the 

original estimate of $1,136,097 to $1,929,884. As a subsequent consideration for BART, 

Trident provided details in the July 22, 2008 submittal regarding the estimated costs for 

selective non-catalytic reduction (SNCR). As detailed in the SNCR submittal the cost 

effectiveness per deciview utilizing eXisting dust scoops is estimated at $985,478. 

If you have any questions or comments, please contact myself (406-285-4977) or Eric Ervin 

(406-285-3985). 

Sincerely, 

~~jManager cc:	 Eric Ervin, Plant Manager, Holcim (US) Inc., Trident Plant 

Bison Engineering - Chris Hiltunen 

Strength. Performance. Passion. 
Low NOx Burner Cost Analysis 

Holcim Inc. 

Trident Facility 

BART Analysis 

Low NOx Burner 

Reference: costs are per similar modifications at a Holcim (US) plant 

Cost Item Factor I 

DIRECT COSTS 

Purchased equipment costs 

Material costs: 

Burner: 

Mechanical 

Sales Tax 

Freight 

0.03(Mechanical cost) 

(A) 

Indirect Firing Modification: 

Mechanical 

Electrical 

Sales Tax 

Freight 

Purchased equipment cost (PEC) 

0.03(Mechanical cost) 

(B) 

(C) 

DIRECT INSTALLATION COSTS 

Foundations & supports 

Handling & erection 

Piping 

Insulation for ductwork 

Painting 

Direct installation costs (01) 

Retrofit Installation: 

0.25(C) 

0.15(C) 

0.10(C) 

0.04(C) 

0.06(C) 

(01 x 1.5) 

Total Direct Costs (DC) 

INDIRECT INSTALLATION COSTS (IIC) 

Engineering 

Construction and Field Expenses 

Contractor fees 

Start-up 

Performance test 

Contingencies 

Total Indirect Costs (IIC) 

Total Capital Investment =DC + IIC 

Retrofit Installation: 

0.10(C) 

0.10(C) 

0.10(C) 

0.01(C) 

0.01(C) 

0.05(C) 

(IIC x 1.5) 

$80,000 

$2,400 

$1,500 

$83,900 

$1,722,700 

$175,000 

$51,681 

$50,000 

$1,999,381 

$2,083,281 

$520,820 

$312,492 

$208,328 

$83,331 

$20,833 

$1,145,805 

$1,718,707 

$3,801,988 

$208,328 

$208,328 

$208,328 

$20,833 

$20,833 

$104,164 

$770,814 

$1,156,221 

$4,958,209 

I Cost Item Low NOx I 

Burner Cost 

DIRECT ANNUAL COSTS 

Operating Labor 

Operator 540 man hrs per year" $22.00/hr $11,880 

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

Supervisor 15% of operator $22.00/hr $1,782 

Maintenance 

Labor 540 man hrs per yearb $22.00/hr $11,880 

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

Material 100% of maintenance labor $11,880 

Utilities (Assumed) 

Electricity (1 % of capital cost) $49,582 

Total Direct Annual Costs (DAC) $87,004 

INDIRECT ANNUAL COSTS (lC) 

Overhead (60% of total operating & maintenance costs) $15,325 

Administrative charges 2% ofTCI $99,164 

Property Taxes 1% ofTCI $49,582 

Insurance 1% ofTCI $49,582 

Capital recovery factor (15 yrs al 7%) .110ofTCI $545,403 

Total Indirect Annual Costs $759,057 

TOTAL ANNUAL COST $846,061 

Holcim, Inc. 

BART Analysis 
Table 4-4: Summary of Remaining NOx Control Technology Efficiency 

Control Option 

Efficiency 

(%) 

NUX 

Emissions 

(Ibs/hr) 

NUX 

Emissions 

(tpy) 

Tons 

Removed 

Mid-Kiln Injection of Fuel 30% 1,098 4807 2060 

Low-NOx Burner 17% 1,301 5700 1168 

Process Alterations 

(Install fixed inlet to cooler) 3% 1,521 6662 206 

Baseline 0% 1,568 6868 0 

Table 4-5: Summary of NOx Cost Impacts 

Control Option 

t:sllmalea 

Annualized 

Cost 

Efficiency 

(%) 

NUX 

Emissions 

(Ibs/hr) 

NUX 

Emissions 

(tpy) 

Tons 

Removed 

Cost 

($/ton) 

Mid-Kiln Injection of Fuel $473,738 30% 1,098 4,807 2060 $230 

Low-NOx Burner $846,061 17% 1,301 5700 1168 $725 

Process Alterations 

(Install fixed inlet to cooler) $448,250 3% 1,521 6662 206 $2,176 

Baseline $0 0% 1,568 6868 0 -­

Table 4-6: Summary of NOx Visibility Impacts3 

Control Option 

Estimated 

Annualized 

Cost 

Efficiency 

(%) 

NOx 

Emissions 

t1bs/hr) 

Gates of the Mountains 

NOx Impact 

(deciview) 

Declvlews (24 

hr - h) 

Cost 

($/dc) 

Mid-Kiln Injection of Fuel $473,738 30% 1,098 0.976 0.584 $811,195 

Low-NOx Burner $846,061 17% 1,301 1.122 0.438 $1,929,884 

Process Alterations 

(Install fixed inlet to cooler) $448,250 3% 1,521 1.278 0.282 $1,591,797 

Baseline $0 0% 1,568 1.560 0 -­

aOeciviews at each % reduction for the Gates of the Mountains are calculated using the equation: 

y = O.0112x + 0.248 derived from using the best fit trendline of the average 98th percentile modeling values. 

Holcim, Inc. 

BART Analysis