..Bob Vantuyl" To Laurel Dygowski/P2/R8/USEPAlUS@EPA 

<bob.vantuyl@ashgrove.com 

> cc 

0V23/2009 09:46 AM bcc 

Subject	 Ash Grove Cement Montana City Low NOx Burner cost 

effectiveness 

LaurelAs detailed in the BART Analysis submittal and subsequent correspondence, Ash Grove Cement 

Company (Ash Grove) is proposing to install a combination of Selective Non-Catalytic Reduction (SNCR) 

and a Low NOx Burner (L1'JB) to control NOx emissions from the wet process kiln system at the Montana 

City Plant. Individually, the LNB and SNCR technologies are capable of achieving 15% and 35% 

reduction in NOx emissions on wet kiln systems, respectively. The level of control achieved by utilizing 

more than one control technology is not typically 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 that would be achieved. The analysis 

also incorporates the LNB optimization trial and an annual burner replacement that will be necessary to 

maximize and maintain the amount of NOx control. As presented, the LNB system would achieve a NOx 

emissions control level of approximately 15% at a cost of $700 per ton removed. 

Robert V. Vantuyl Jr. 

Corporate Environmental Manager 

Ash Grove Cement Company 

11011 Cody 

Overland Park, KS 66210 

913-319-6063 

2009 01·23 Montana LNB cost effectiveness. pdf 
Cost of Low NOx Burner 

CAPITAL COST 

Direct Capital Cost (DCC) Total Cost Unit cost 

K>reencast 94 Plus castable refractory 13,695 456~

RA-42 Footed double hook castable anchor with 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 anchor with 4.5 in overall height 2,862 954 

Pre-fire castable 3,150 105C 

ran sport 5,250 17& 

12' sonotube x 30" di ameter 1,512 504 

Ceramic blanket 600 20 

Mise fittings 600 20 

Welding rod 1,950 65 

RA253MA pipe 14.75 x 0.375AW x 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 pipe joints for new pipe 1,950 650 

Total Purchased Equipment Cost (PEC): 78,102 

Sales lax & freight (8% of PEC) 6,248 ACT 

Direct Installation 10,500 

Total DCC: 94,850 

Indirect Capital Cost (ICC) 

Engineering, supervision 10,000 

Burner pipe replacement costs (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 up time to full production 24,000 

onstruction & Field Expense (10% of DCC) 9,485 ACT 

ontractor Fees (7% of DCC) 6,640 ACT 

ontingencies (20% of PEC) 15,620 ACT 

Total ICC: 171,459 

otal Capital Cost 266,309 DCC + ICC 

Capital Recovery Factor (7%, 5 yrs) 24.39% ACT 

otal Annualized Capital Cost 64,953 

OPERATING COST 

Direct Operating Cost (DOC) 

IAnnual burner pipe replacement cost (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 to full 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 1/4 man-year@ $65,000/year 

Maintenance materials (100% maintlabor) 16,250 ACT 

Total DOC: 92,988 

Indirect Operating 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 Em issions (tonslyr) 1,891 

NOx Emissions with Low NOx bumer (tonslyr) 1,607 

otal NOx Removed (tons/year) 284 

otal Costlton NOx Removed 700 

NOx Removal Rate 15%