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MACT Task Force

MEMORANDUM

Date: December 5, 2013

To: Jeff Telander, EPA/SSPD

From: Susan Miller, Brick Industry Association

Subject: Review of EPA ACI Cost Model 

EPA presented estimated control costs to add activated carbon injection (ACI) to an existing fabric filter 

at the June 26, 2013 Outreach Meeting with Small Entity Representatives for the Brick MACT. BIA’s 

review of the supporting model cost spreadsheet provided by EPA entitled, “ACI costs”, revealed that 

the total capital investment estimation may be grossly underestimated. It is BIA’s estimation that the 

model unit cost is anywhere from twice to an order of magnitude higher than reported.

Per the footnote provided, the equation used to estimate the total capital investment was taken from 

March 2011 Sargent & Lundy memo used to develop costs for the Boiler MACT and referenced by EPA 

for the Brick MACT.

1

 As explained in the Sargent & Lundy memo, the equation, provided below, was 

established based on the actual anticipated activated carbon feed rate and not on boiler size. Cost data 

for several ACI systems was reviewed and a relationship was developed for the capital costs of the 

system on a carbon fee rate basis. This cost module does not include the additional cost of a particulate 

collection device.

BMC($) = 1,350,000*B*(M^0.15)

Where: BMC($) = Base ACI module including all equipment from unloading to injection

B = Retrofit Factor

M = Carbon Feed Rate (lb/hr)

For the Brick MACT evaluation, EPA assumed a carbon feed rate need of 2 lb/MM acf consistent with 

Sargent & Lundy’s model with an existing baghouse. The model costs were broken down for small and 

large kilns with average exhaust flow rates of 24,100 and 42,500 acfm, respectively. This information 

was used in EPA’s version of the equation:

 

1

IPM Model- Revisions to Cost and Performance for APC Technologies: Mercury Control Cost Development 

Methodology, Final, March 2011. Sargent & Lundy, LLC. Project 12301-009
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TCI($) = 1.05*1.15*1,350,000*(carbon feed rate/1e6*60min/hr*exhaust flow)^.15 x

(exhaust flow/2,068,502 acfm)^.6 *cost index ratio

To simplify the discussion, let’s break the equation into two parts. Let:

BMC($) Cost Module = 1.05*1.15*1,350,000*(carbon feed rate/1e6*60min/hr*exhaust flow)^.15

assuming the 1.05 and 1.15 factors account for retrofit and additional 

engineering management costs for the project

6/10 Scaling Rule = (Exhaust flow/2,068,502 acfm)^.6 

BIA takes issue with the use of both of these terms simultaneously for the following reasons:

1. If EPA is assuming the Sargent and Lundy BMC($) cost module is appropriate to use, then 

the 6/10 Scaling Rule is not necessary since the cost module is based on required carbon 

feed rate regardless of unit size. The Sargent and Lundy authors clearly determined that 

carbon feedrate was the appropriate factor.

2. If EPA deems that scaling for different flows is appropriate, then the carbon usage for 

the boiler should be used in the BMC($) Cost Module and then scaled using the 

appropriate flow rates in the 6/10 Scaling Rule.

To continue to use both of these terms is to double discount the costs and underestimate the overall 

costs. As shown in Table 1 below, the total annualized cost to install an ACI system could be 

underestimated by as much as 60% just from this one calculation. 

Table 1. Impact of EPA Costing Approach of ACI Costs

Cost

Current EPA 

Estimate

BMC Module 

Without 6/10 

Scaling (Using 

carbon feed rate 

for brick)

BMC Module 

With 6/10 

Scaling from 

boiler cost to 

brick cost

Small Kiln Large Kiln Small Kiln Large Kiln Small Kiln Large Kiln

TCI ($) $148,356 $227,030 $2,145,303 $2,335,847 $289,302 $406,606

Capital Recovery ($) $14,004 $21,430 $202,501 $220,487 $27,308 $38,381

Total Annual Cost ($/yr) $96,774 $143,535 $285,272 $342,592 $110,078 $160,485
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Estimated nationwide impacts are provided in Table 2.

Table 2. BIA Minimum Nationwide Costs Estimates

Cost

Current EPA 

Estimate

BMC Module 

Without 6/10 

Scaling (Using 

carbon feed rate 

for brick)

BMC Module 

With 6/10 

Scaling from 

boiler cost to 

brick cost

Nationwide 

Costsa

Small 

Entities 

Capital 

Investment

$13,000,000 $176,000,000 $26,000,000

Small 

Entities 

Total 

Annual 

Cost

$9,000,000 $24,000,000 $10,000,000

Total 

Industry 

Capital 

Investment

$34,000,000 $413,000,000 $64,000,000

Total 

Industry 

Annual 

Cost

$22,000,000 $58,000,000 $25,000,000

a

Nationwide costs estimated by BIA . Note that these cost estimates do not reflect the additional costs of a particulate matter 

(PM) control device such as a fabric filter (FF) for those facilities that may not have an existing FF in place or may require one for 

PM control.

BIA asserts that the costs estimated above are understated and represent minimum incremental costs 

from the addition of ACI systems. In addition to this one calculation error, EPA may be further 

underestimating the cost to install ACI systems for the brick industry. EPA is assuming that existing 

baghouses can be used for streams containing both lime and carbon particulates. To date, EPA has not 

demonstrated that existing systems can achieve the necessary mercury reductions without considerable 

upgrades or supplemental systems. For example, as discussed in the BIA memo, “Review of Activated 

Carbon Injection and the Applicability to the Brick Industry “2, collection of oxidized mercury in the form 

 

2

Review of Activated Carbon Injection and Applicability to the Brick Industry. Brick Industry Association MACT 

Task Force. December 3, 2013.
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of mercury chloride using ACI requires a specific temperature range and chlorine concentration such 

that mercury chloride is created in the exhaust of a brick kiln. BIA is aware of no information to support 

that these conditions are obtained in a brick kiln. Clearly, the costs of upgrades that may be required to 

make this technology feasible have not been considered. Also not considered is the additional disposal 

costs of a combined waste stream of lime and mercury laden carbon, which may be considerably more 

expensive than either waste product alone. All of these considerations will further increase the 

nationwide cost impacts to the industry. Furthermore, the EPA has yet to demonstrate that any ACI 

system, even with possible upgrades, will actually be able to achieve the emission reductions necessary 

to comply with the MACT. If controls do not work, then any estimate is an underestimate, as the costs 

would be infinite. 

BIA asserts that EPA has not adequately demonstrated the technical feasibility of these controls or 

reasonably estimated the costs of the controls, based on the information provided to the brick industry 

at this time. Additional evaluation is required and should be completed before EPA makes any 

regulatory decisions based on the current information.