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 1595Wynkoop Street Denver, CO 80202-1129
VIACERTIFIED US MAIL#7009 0820 0000 3084 0016


## RE: BART

- 

## LowNOxBURNER



## 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 ourtelephone 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 updatesto 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 perdeciview 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 equipmentcosts 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 Contractorfees Start-up Performance test Contingencies Total IndirectCosts (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 DIRECTANNUAL COSTS

Operating Labor Operator 540 man hrs per year" $22.00/hr $11,880 "Note: 0.5 hrs/shiftx 3shifts/dayx 360 days/yr Supervisor 15% ofoperator $22.00/hr $1,782 Maintenance Labor 540 man hrs peryearb $22.00/hr $11,880 bNote: 0.5 hrs/shiftx 3 shifts/dayx 360 days/yr Material 100% ofmaintenance labor $11,880 Utilities (Assumed) Electricity (1% ofcapital cost) $49,582
Total DirectAnnual Costs (DAC) $87,004
INDIRECTANNUAL COSTS (lC) Overhead (60% oftotal operating & maintenance costs) $15,325 Administrative charges 2% ofTCI $99,164 PropertyTaxes 1% ofTCI $49,582 Insurance 1% ofTCI $49,582 Capital recoveryfactor (15 yrs al 7%) .110ofTCI $545,403 Total IndirectAnnual Costs $759,057
TOTALANNUAL COST $846,061 Holcim, Inc. BART Analysis

## Table4-4: SummaryofRemainingNOx ControlTechnologyEfficiency

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 ProcessAlterations (Install fixed inletto cooler) 3% 1,521 6662 206 Baseline 0% 1,568 6868 0



## Table4-5: SummaryofNOx CostImpacts

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 inletto cooler) $448,250 3% 1,521 6662 206 $2,176 Baseline $0 0% 1,568 6868 0


# -­

Table4-6: SummaryofNOxVisibilityImpacts3

Control Option Estimated Annualized Cost Efficiency (%) NOx Emissions

t1bs/hr) Gates ofthe 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 ProcessAlterations (Install fixed inletto 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 ofthe Mountains are calculated using the equation: y 

### =O.0112x + 0.248 derived from using the bestfittrendline ofthe average 98th percentile modeling values.

Holcim, Inc. BARTAnalysis