## ..Bob Vantuyl" To Laurel Dygowski/P2/R8/USEPAlUS@EPA <bob.vantuyl@ashgrove.com 

# > cc


# 0V23/2009 09:46AM bcc Subject Ash Grove Cement Montana City Low NOx 

## Burner cost effectiveness



# LaurelAs detailed in the BARTAnalysis submittal and subsequent correspondence, Ash Grove Cement Company (Ash Grove) is proposing to install a combination ofSelective Non-Catalytic Reduction (SNCR) and a Low NOx Burner (L1'JB) to control NOx emissions from the wet process kiln system atthe Montana City Plant. Individually, the LNB and SNCR technologies are capable ofachieving 15% and 35% reduction in NOx emissions on wet kiln systems, respectively. The level ofcontrol achieved by utilizing more than one control technology is nottypically additive. However, Ash Grove believes they can achieve, and is committed to achieving the proposed 50% reduction in NOx emissions though the use of LNB and SNCR, when installed in combination.

As discussed with the United States Environmental Protection Agency (USEPA) in prior correspondence, an economic analysis has been prepared for the installation and operation of LNB on the Montana City Plant's wet kiln system. The analysis, included in this email, presents the estimated capital and operating costs for the LNB system and the estimated level of NOx control thatwould be achieved. The analysis also incorporates the LNB optimization trial and an annual burner replacementthatwill be necessary to maximize and maintain the amount of NOx control. As presented, the LNB system would achieve a NOx emissions control level ofapproximately 15% at a costof$700 perton removed.



# Robert V. VantuylJr. Corporate EnvironmentalManager Ash Grove CementCompany 11011 Cody OverlandPark, KS 66210 913-319-6063

2009 01·23 Montana LNB 

# cost effectiveness.pdfCostof Low NOx Burner CAPITAL COST DirectCapital Cost (DCC) Total Cost Unitcost K>reencast 94 Plus castable refractory 13,695**456~** RA-42 Footed double hook castable anchorwith 5,5 in overall height 1,158 38E RA-42 Footed double hook castable anchor with 4.5 in overall height 1,032 344 RA-42 Footed double hook castable anchor with 5.0 in overall height 1,449 483 RA-49 Flexi anchorwith 4.5 in overall height 2,862 954 Pre-fire castable 3,150 105C

ransport 5,250 

## 17& 12' sonotube x 30" diameter 1,512 504 Ceramic blanket 600 20 Misefittings 600 20 Welding rod 1,950 65 RA253MA pipe 14.75x0.375AWx 96" 16,170 539 Super 22H tube 15" ad x 14" 12,699 4233 15"ad x 14" id mech tubing 2.625 87 15"VicJGrub weld on stub 1,500 50 Production labor 2,400 80 Maintenance labor 7,500 250 Weld new pipejoints for new pipe 1,950 650 Total Purchased EquipmentCost (PEC): 78,102 Sales lax & freight (8% of PEC) 6,248 ACT Direct Installation 10,500 Total DCC: 94,850 IndirectCapitalCost(ICC) Engineering, supervision 10,000 Burner pipe replacementcosts (3 times, to check each) LNS Optimization Trial K>as consumption during burner pipe change 33,714 Lost production during kiln feed off period 72,000 Lost production dUring ramp uptime to full production 24,000

onstruction & Field Expense (10% of DCC) 9,485 ACT ontractor Fees (7% of DCC) 6,640 ACT ontingencies (20% ofPEC) 15,620 ACT Total ICC: 171,459 otal Capital Cost 266,309 DCC 

### +ICC Capital Recovery Factor (7%, 5yrs) 24.39% ACT otal Annualized Capital Cost 64,953 OPERATING COST DirectOperating Cost (DOC) IAnnual burnerpipe replacementcost(1 time/yr) Gas consumption during bumer pipe change 11,238 Lost production during kiln feed off period 24,000 Lost production during ramp up time tofull production 8,000 Operating labor 15,000 1/4 man-year@ $60,000Iyear Supervision (@ 15% of operating iabor) 2,250 ACT Maintenance labor 16,250 1/4man-year@ $65,000/year Maintenance materials (100% maintlabor) 16,250 ACT

Total DOC: 92,988 IndirectOperating Cost (IOC) Payroll Overhead (60% oper. Labor & sup. maint labor& materials) 29,850 ACT Property tax (1% TCC) 2,663 ACT Insurance (1% TCC) 2,663 ACT !Administration (2% TCC) 5,326 ACT TotaIIOC: 40,502 otal Annual Operating Cost 133,490 TOTAL COST otal Annual Cost (Capital & Operating) 198,443 Sase NOx Emissions (tonslyr) 1,891 NOx Emissionswith Low NOx bumer (tonslyr) 1,607 otal NOx Removed (tons/year) 284 otal Costlton NOx Removed 700 NOx Removal Rate 15%