### Date: September 24, 2015

To: Sharon Nizich, EPA/OAQPS/SPPD

From: Thomas Holloway, RTI International

Subject: Methodology and Assumptions Used to Estimate the Model Costs and Impacts of BSCP Air Pollution Control Devices for the Final Rule

I. Introduction

In accordance with section 112 of the Clean Air Act (CAA), the U.S. Environmental Protection Agency (EPA) established national em ission standards for hazardous air pollutants (NESHAP) on May 16, 2003 for the brick and struct ural clay products (BSCP) manufacturing industry. The NESHAP regulated emissions of hydrogen fluoride (HF), hydrogen chloride (HCl), and particulate matter (PM)—a surrogate for ha zardous air pollutant (HAP) metals—from tunnel kilns located at BSCP faciliti es. On March 13, 2007, the D.C. Circuit Court vacated the emission standards for BSCP manufacturing due to issu es associated with the methodology used to determine the minimum regulatory “f loors” for new and existing units. 1 

### Therefore, on December 18, 2014, the EPA proposed new standa rds for BSCP manufacturing, including standards for HF, HCl, chlorine (Cl 2 

### ), mercury (Hg), and non-Hg HAP metals (or PM surrogate). The EPA provided a 90-day public comment period following proposal of the BSCP Manufacturing NESHAP, during which all affect ed parties were given the opportunity to comment on the proposed rule. The EPA has c onsidered the comments received and, as appropriate, incorporated them into the final ru le. The purpose of this memorandum is to present the methodology and assumptions used in estima ting the model costs and environmental and energy impacts for the control technologies used to meet the standards in the final rule.

II. General Model Parameters
Model costs and impacts were developed for two sizes of BSCP control devices—large control devices (LCD) and small c ontrol devices (SCD), reflecting the size subcategories of the BSCP Manufacturing NESHAP, whic h are based on a kiln capacity threshold of 10 tons per hour (tph). The model costs and impacts were estima ted based on a variety of model parameters— (1) general parameters such as production rate, operating hours, gas flow rate, electricity and waste disposal unit costs, labor wage rates, and uncontrolled em issions; and (2) control-specific parameters such as control device horsepower (hp) requirements, sorbent requirements, and

1 Sierra Club v. EPA , 479 F.3d 875 (D.C. Cir. 2007).

### 2 sorbent unit cost. This section discusses the basis for the general model parameters, which are presented in Appendix A at the end of this memorandum.
The model production rates (in tph) were based on data from the BSCP inventory (Holloway, 2014). The BSCP inventory is a comb ination of (1) industry responses to the 2008 BSCP section 114 survey; (2) res ponses to a survey si milar to the 2008 BSCP section 114 survey that was administered by the Brick Industry As sociation; and (3) indus try data from the 2003 BSCP database (from the original 2003 BSCP Manufacturing NESHAP) for plants not included in the 2008 surveys. The average kiln producti on rate (7.0 tph) for the small model was calculated from those tunnel kiln s with a kiln capacity less than 10 tph. The average kiln production rate (15 tph) for the large model was calculated from t hose tunnel kilns with a kiln capacity of 10 tph or greater. The model kiln production rates were based on a mix of permitted and design capacities, i.e. , those capacities to which th e kilns are actually limited.
The model kiln operating hours (8,760 hours pe r year [hr/yr]) for both large and small model sizes were based on data from a 2015 survey of the BSCP industry conducted by the Brick Industry Association (BIA), provided to the EP A in the BIA’s public comments on the proposed rule (Regina, 2015).
The model exhaust gas flow rates (in actual cubic feet per minute [acfm]) were based on data from BSCP stack tests (Raymond, 2014), wi th the model flow rate for the small model (23,100 acfm) calculated from stack test data for tunnel kilns with a kiln capacity less than 10 tph, and the model flow rate for the large model (38,700 acfm) calculated from stack test data for tunnel kilns with a kiln capacity of 10 tph or greater. In thos e cases where flow rate data were only available in units of dry standard cubic f eet per minute (dscfm), those flow rates were converted to units of acfm using Equation 1 be low, based on stack temperature and moisture content data from the stack test (assuming a stack pressure equivalent to standard atmospheric pressure):
Equation 1—Flow rate conversion



##   % 100 % 100

tan 

### O %H T

T Q Q

2 dard s stack dscfm acfm



###    

where:
Q acfm 

### = exhaust flow rate (acfm), Q dscfm 

### = exhaust flow rate (dscfm),
T stack 

### = stack temperature (converted from degr ees Fahrenheit [°F] to degrees Rankine [°R]),
T standard 

### = standard temperature (528°R), and
% H 2 

### O = moisture content (percent [%]).

### 3 Unit costs for electricity ($0.083/kilowatt-hour [kWh]) a nd waste disposal ($51.90/ton waste) were based on the averag e of data from the aforementioned 2015 BIA survey (Regina, 2015). The operator wage rate ($22.67/hr) was ba sed on mean hourly wage data from the May 2011 Bureau of Labor Statistics for NAICS 327100 (Clay Product and Refractory Manufacturing) for an Industrial Engineering Technician (BLS, 2012). Wage rates from the Bureau of Labor Statistics were used because they were more conservative than those provided by BSCP survey respondents. The maintenan ce wage rate ($24.94/hr) was assumed to be 10 percent higher than the operator wage rate, sim ilar to the ratio of maintenance to operator wage rates provided by one BSCP company in its response to the 2008 su rvey (Holloway, 2014).
The capital recovery factor (0.0944) was calcu lated using Equation 2 below, assuming a 7 percent interest rate and 20-year equipment life for the control de vices expected to be used to comply with the new standard s for BSCP manufacturing:
Equation 2—Capital recovery factor:



##   1 1 ) 1 (

   

 n n


### i i i CRF

where:
i = interest rate (%) and n = payment period, e.g. , equipment life (yrs).

Model uncontrolled emissions estimates (in pounds per ton [lb/ton]) were used to estimate the amount of material captured by the control devices, based on each device’s control efficiency. The pollutants of intere st were HF, HCl, chlorine (Cl 2 

### ), PM, HAP metals, and sulfur dioxide (SO 2 

### ). The model uncontrolled emissions estimates for HF, HCl, PM, Cl 2 

### , and SO 2 

### were based on the average of uncontrolled emissions data from BSCP stack tests (Raymond, 2014). The model uncontrolled emissions estimate for tota l HAP metals was assumed to be 1.1 percent of the PM estimate, based on the average ratio of metals to PM emissions in BSCP stack tests (Raymond, 2014).

III. Model Costs
This section discusses the methodology and assu mptions used to estimate the model costs for the new or retrofit emission control devices that BSCP facilities are e xpected to install in order to comply with the new standards for the BSCP industry. The cost estimates are presented in 2011 dollars, which was the latest year for whic h an annual cost index value was available for scaling costs at the time that costs were first be ing developed for the BSCP rule. The model cost tables for new and retrofit control devices are presented in Appendices B and C, respectively. (Note: The annual operating costs for repla cement control devices presented in this memorandum are a conservative estimate. The oper ating costs for control devices to be replaced have not been subtracted out.)

### 4 Dry sorbent injection/fabric filter (DIFF). Dr y sorbent injection followed by a fabric filter (DIFF) can be used to reduce emissions of bot h particulates and acid gases from BSCP tunnel kilns. This type of control system is already in use in the BSCP industry (Holloway, 2014) and is expected to be installed on uncontro lled kilns or retrofitted to repl ace less efficient kiln controls to enable facilities to comply with the new BSCP manufact uring standards.
The DIFF costs were estimated using the co st algorithms from the original BSCP manufacturing rulemaking (Shrager, 2003), which were generated follow ing guidelines in the OAQPS Control Cost Manual (EPA, 2002). The algor ithms were updated to include more recent model parameters, including the general paramete rs discussed previously and the following parameters specific to DIFF control devices:

 Control efficiency ( e.g. , 99.5% HF, 94% PM)

 Fan horsepower (150 hp [small]/190 hp [large])

 Total horsepower for other motors (30 hp)

 Stoichiometric ratio of hydrated lime (2.65 [small], 1.79 [large])

 Bag life (5 yrs)

 Gas-to-cloth ratio (3.4 feet per minute [ft/min])

 Bag area (28 square feet [ft 2 

### ])

 Compressed air (0.9 cubic feet [ft 3 

### ] of compressed air/1,000 ft 3 

### of gas)

 Time to replace bags (2.25 hr/bag)

 Hydrated lime unit cost ($160/ton)

 Bag fabric cost ($8.15/ft 2 

### )

 Compressed air unit cost ($0.363/1,000 ft 3 

### )

 Bag capital recovery factor (0.244, base d on 5-yr bag life and 7% interest)
With three exceptions, the values of the model DIFF parameters were determined based on averages of industry responses to the 2008 BSCP survey (Holloway, 2014). The compressed air unit cost was based on the average of data from the 2015 BIA survey (Regina, 2015), while the DIFF control efficiencies and stoichiometr ic ratios of hydrated lime were determined differently, as discussed below.

The control efficiencies for new and retrofit DIFF were estimated based on the average of those stack tests with better efficiencies than the baseline control efficiency (which was determined based on the average of all availabl e stack tests with cont rol efficiency data) (Raymond, 2014). For example, the baseline HF contro l efficiency for a DIFF is estimated to be 98 percent; in stack tests with HF control efficiencies better than 98 percent, the average HF control efficiency is 99.5 percent.
The stoichiometric ratio of hydrated lime for new and retrofit DIFF was estimated based on average reagent rates from industry responses to the 2008 BSCP survey (Holloway, 2014), average uncontrolled emissions data from st ack tests (Raymond, 2014), and molecular weight information for the primary pollutants and hydrated lime, scaled up from baseline using the ratio of the aforementioned control effi ciencies (99.5 per cent/98 percent).

### 5 The model DIFF capital costs were estimated by taking DIFF capital cost data from industry responses to the 2008 BSCP survey (Holloway, 2014), escalating the costs to 2011 dollars using the Chemical Engineering Plant Co st Index (CEPCI) (CE, 2011), scaling the costs to the large and small model sizes using the six-tenths cost rule (see Equation 3 below), taking the average of the scaled costs for each model size, and rounding the results to three significant figures.
Equation 3—Six-tenths cost rule:

0.6

2 1

2 1 

###        

 Q Q C C

where:
C = capital cost and Q = capacity parameter ( e.g. , exhaust gas flow rate).

For retrofits, the capital costs we re further adjusted using a re trofit factor of 1.4, which is in the middle of the range of retrofit factors for emission control devices, according to guidance from the OAQPS Control Cost Manual (EPA, 2002).

The model DIFF annual costs were estimated based on the aforementioned cost algorithms, and include the following cost items:

 Operating labor (assumed to be twice the maintenance labor hours at $22.67/hr)

 Supervisory labor (estimated at 15% of operating labor)

 Maintenance labor (estimated based on 1.25 hr/shift from BSCP survey responses and an assu med $24.94/hr wage rate)

 Maintenance materials (estimated at 100% of maintenance labor)

 Electricity (estimated based on hp requirements, 0.745 kW/hp, and $0.083/kWh)

 Lime (estimated based on hydrated lime makeup and $160/ton hydrated lime unit cost)

 Compressed air (estimated based on 0.9 ft 3 

### /1,000 ft 3 

### compressed air requirements and $0.363/1,000 ft 3 

### compressed air unit cost)

 Replacement bags (estimated based on 3.4 ft/min gas-to-cloth ratio, $8.15/ft 2 

### bag fabric, and 0.244 bag capital recovery factor)

 Bag replacement labor (estimated based on 3.4 ft/min gas-to-cloth ratio, 28 ft 2 

### bag area, $29.94/hr maintenance wage rate, and 0.244 bag capital recovery factor)

 Waste disposal (estimated based on waste generated and $51.90/ton waste)

 Overhead (estimated at 60% of labor and maintenance materials)

 Property taxes, insurance, and administrati ve charges (estimated at 4% of total capital cost)

### 6  Capital recovery (estimated as the pr oduct of a 0.0944 capital recovery factor and total capital cost, minus the cost of capital recovery for replacement bags and bag replacement labor)

Fabric filter. Fabric filters can be used to reduce emissions of particulates from BSCP tunnel kilns at plants th at already have acid gas control or ha ve inherently low acid gas emissions ( e.g. , due to low fluoride and chloride content in the raw materials). Stand-alone fabric filters are not currently used by the BSCP industry to cont rol tunnel kiln emissions, although DIFF are used to control emissions from the larger tunne l kilns (Holloway, 2014). The BSCP industry has expressed the following concerns about using stand- alone fabric filters (Holloway, 2013b):

 Without the dry lime injection that redu ces the acid gas, there will not be enough particulates in the kiln exha ust to coat the bags and get good performance from the fabric filter.

 The uncontrolled acid in the exha ust stream could rot the bags.

 The exhaust gas temperatures from BS CP tunnel kilns can be high (about 400°F on average, as high as 668°F).

 The use of membrane bags on low inlet loadings.
In response to these concerns, we contact ed two major fabric filter vendors—Solios Environment and McGill AirClean—and a majo r filter bag vendor—W.L. Gore & Associates— to determine the feasibility of using stand-alone fabric fi lters in the BSCP industry.
A representative from one of th e fabric filter vendors (Solio s Environment) agreed with industry concerns that th at the lack of a dust cake would nega tively impact total outlet emissions and that the dust cake serves an important functi on for acid gas neutralization. He noted that the bag choices for high-temperature applications are limited to fiberglass, with an upper temperature limit of 500°F, and that fiberglass degr ades rapidly in the presence of HF acid gas. While PTFE (Teflon) fabric also has a limit of 500°F and is impervious to most acid gases, he noted that it carries a very si gnificant price premium. He indica ted that Aramid, Ryton, and P-84 fabrics are generally limited to 400°F operation, bu t noted that these fabrics are sensitive to degradation not only by the acid gases but also the relatively high oxygen c oncentration in brick kiln gases (Hansen, 2013).
A representative from the other fabric filter vendor (McGill AirClean) stated that a brick plant should be able to use a st and-alone baghouse to control just filterable partic ulate emissions from a brick kiln. According to the vendor, if the concern is low dust load and not being able to establish a good dust cake, then ba gs with an expanded PTFE membrane could be used. He noted that membrane bags usually control outlet partic ulate emissions to very low levels and are not cost prohibitive any more. Like Solios, he stated that the base fabric for the membrane can be a woven fiberglass fabric, which is good for a 500°F continuous operating temperature. If there is HF in the gas stream, he said that this could damage the fibe rglass, so scrubbing would be a good idea, depending on the amount of HF present. He sa id that acid gases in moderate concentrations usually do not cause fabric degradation if the ba gs are continuously operated above the acid gas dewpoints. Regarding operating te mperatures above 500°F, he said there are some fabrics that are available for continuous operation at these temperatures but none with a membrane. He noted that the plant could consider fl ue gas cooling using a dry-bottom evaporative cooler or a gas-to-

### 7 air heat exchanger to reduce the gas temperature to a level wher e conventional fabrics could be used safely (Childress, 2013b).
A representative from the bag fabric vendor (W.L. Gore & Associates) noted that his company had done business with the brick industry before and that they have two kinds of bags that could be used for the industry: (1) hi gh-temperature fiberglass bags, and (2) hightemperature PTFE (Teflon) bags. Both are rated to 500°F. He indicated that a ceramic style bag would be needed for temperatures above 500°F. He could not speak to the concern regarding PM loading, but did say that there would be no problem with PM load ings as low as 1 to 2 grains per cubic foot. He noted that HF dest roys fiberglass, so PTFE bags w ould be needed if HF emissions are a concern. He noted that PTFE bags, unlike fibe rglass bags, are chemically inert, but are very expensive, about 2 to 5 times more expensive than fiberglass. He also noted that PTFE bags have high chemical and thermal resistance and would control PM but not acid gas (Holloway, 2013c).
Based on the information obtained from vendors, we stated at proposal that fabric filters can potentially be an ef fective control option, if acid gas levels (especially HF) are already inherently low or effectively controlled and exhaust gas temperatures are not too high. While some commenters on the proposal questioned whether stand-alone fabric filters were feasible for the BSCP industry, they did not provide specific data to supp ort their contention (EPA, 2015). The fabric filter costs were estimated using the DIFF cost algorithms, minus the capital cost for a dry sorbent injection system and annual cost for sorbent, and with a revised annual cost for waste disposal that excludes any acid gas control.
Activated carbon injection (AC I) and other mercury controls . Injecting activated carbon before the particulate control device ( e.g. , fabric filter) has been demonstrated to improve the removal efficiency of mercury from a variety of combustion devices ( e.g. , waste incinerators, industrial boilers, Portland cement kilns). In the absence of a national mercury standard for the BSCP industry, there are currently no BSCP plants that use ACI. However, given the effective mercury control performance achieved in thes e other industries and on similar sources ( e.g. , Portland cement kilns), we believe d it prudent to explor e this control technol ogy as an option to reduce the mercury emissions from the BSCP industry.
To obtain information on the feasibility and co st of adding an ACI system to an existing DIFF control system for BSCP kilns, we first cont acted a fabric filter ve ndor, McGill AirClean. While a representative from the vendor indicated th at his company does not have data on control of mercury emissions from BSCP kilns (all of th e company’s mercury control experience is with municipal waste incinerators), he indicated that it should not be difficult or expensive to add an ACI system to an existing DIFF control system on a BSCP kiln. He said that a simple bag dump system with a blower could be used and would re quire little additional space at the site. He also noted that the slight increase in inlet PM loading to the baghouse should not affect the performance of the baghouse (Childress, 2013a).
We then contacted an ACI vendor (Cabot Nor it Activated Carbon) to obtain information on the feasibility and cost of installing an ACI system for control of mercury emissions from BSCP kilns. A representative from the compa ny stated that he thought ACI would work well with BSCP kilns. He indicated that it would cost about $0.80 to $0.90/lb for carbon (Holloway, 2013a). He also indicated that, fo r applications using baghouses ( e.g. , a DIFF), an activated

### 8 carbon feed rate of 0.5 to 3 pounds per million act ual cubic feet (lb/MMa cf) is typical; he suggested using 2 lb/MMacf as a baseline (Thompson, 2013).

The model ACI costs for BSCP kilns were es timated based on ACI cost algorithms for a similarly-sized combustion device, specifically hazardous waste combustors (HWCs). We used the cost algorithms in the 2005 technical support document (TSD) for the HWC MACT replacement standards (EPA, 2005), using the gene ral parameters discussed in the previous section and the carbon injecti on rate (2 lb/MMacf [Thomp son, 2013]) and carbon unit cost (average of $0.85/lb [Holloway, 2013a]) from the ACI vendor. To dete rmine the purchased equipment cost (PEC), the total equipment cost from the TSD was scaled to the large and small BSCP model sizes using the six-tenths cost rule , sales tax and freight charges were added, the resulting cost was escalated to 2011 dollars, and a retrofit factor of 1.15 was applied (CE, 2011; EPA, 2005). To determine the total direct capital costs, installation costs were added to the total PEC (EPA, 2005). In addition to these direct cost s, indirect costs of engineering, construction and field expense, contractor fees, startup, performa nce test, model study, and contingencies were also estimated (EPA, 2005).

The model ACI annual costs were also es timated based on the aforementioned cost algorithms (EPA, 2005) and include the following cost items:

 Operating labor (assumed ba sed on 1 hour/day at $22.67/hour)

 Supervisory labor (estimated at 15% of operating labor)

 Maintenance labor (estimated based on 0.5 hour/shift and an assumed $29.94/hr wage rate)

 Maintenance materials (estimated at 5% of the PEC)

 Electricity (estimated based on hp re quirements, 0.9 fan efficiency, 0.745 kW/hp, and $0.083/kWh)

 Carbon (estimated based on carbon feed rate and $0.85/lb)

 Waste disposal (estimated based on waste generated and $51.90/ton waste)

 Overhead (estimated at 60% of labor and maintenance materials)

 Property taxes, insurance, and administrati ve charges (estimated at 4% of total capital cost)

 Capital recovery (estimated as the pr oduct of a 0.1098 capital recovery factor and total capital cost, assuming a 15-year equipment life and 7% interest)
In their public comments on the proposed ru le, a number of BSCP companies led by the BIA (EPA, 2015) objected to the assumption that activated carbon injectio n (ACI) systems could be used in their industry. However, the commenters did not provide specific data to demonstrate the infeasibility of the emission control, which has been demonstrated for similar sources, e.g. , Portland cement kilns. Nonetheles s, as a result of these comments, we investigated other possible technologies for limiting mercury emissions, including, but not limited to, the following:

 Halogenated carbon sorbents, such as brominated activated carbon from Albemarle Corp., which is effective in reducing both elemental and oxidized mercury (Albemarle, 2015).

### 9  Reagents, such as Amended Silicates HgX (As-HgX TM 

### ) from Novinda, which reacts chemically with vapor-phase merc ury to create a solid compound that is effectively captured by the plant’ s PM control system (Novinda, 2015).

 Enhanced ACI technology, such as the Mer-Cure TM 

### mercury reduction system from Alstom, which uses a unique inj ection methodology designed to minimize mass transfer limitations between the vapor phase mercury and carbon sorbent (Alstom, 2014).

 New technologies, such as Mercury Capture Systems (MCS) from SCB International Materials, Inc., which th ermally desorb and chemically capture mercury (Poling et al., 2015).

 Measurement of the mercury content of the raw material for individual plant locations (Tayler, 2015); if significan t amounts of mercury are found at one location onsite, material found at anothe r onsite location with a lower mercury content could be used.
Brominated ACI and AS-HgX TM 

### are expected to be more expensive that plain ACI (Morris, 2012; Novinda, 2015). Because Mercur y Capture Systems include more complex equipment, such as thermal desorbers and gas re actors (Poling et al. 2015 ), compared to plain ACI, they also are expected to be more expensive. While co sts for the Mer-Cure TM 

### system may become less expensive than plain ACI over time (A lstom, 2014), this is a new market that will likely need time to grow. The costs to measure me rcury content of individu al plant locations and limit raw material collection accordingly are expected to be very site-specific, and a correlation between mercury content of raw materials and mercury emissions from the stack has not yet been proven. For these reasons, we decided to use ACI co sts in our cost and impacts analyses for mercury control. However, this decision is not intended to indicate that the EPA expects every BSCP manufacturing owner or operator to se lect ACI as the technology to reduce mercury emissions. Instead, the EPA expects that each ow ner or operator will evaluate the available technologies, including those listed above, and determine whic h technology would be most appropriate for the individual kiln.
Dry limestone adsorber (DLA). Instead of inst alling control equipment such as a DIFF to meet the new BSCP manufacturing standards, some BSCP facilities may choose to install less expensive DLA systems on one or more of thei r uncontrolled tunnel kiln s to reduce facility emissions below the threshold for major sources of HAP—10 tons per year (tpy) or more of any single HAP or 25 tpy or more of any combinati on of HAP. By obtaining a federally enforceable limit reducing emissions below major source thre sholds, those BSCP facilities would become synthetic area sources and w ould not be subject to the major source BSCP Manufacturing NESHAP. Only those BSCP facilities that would be impacted under the new BSCP manufacturing standards and th at could reduce their HAP emi ssions below the major source threshold using a DLA system are expected to install such controls on their uncontrolled tunnel kilns.
Dry limestone adsorbers are designed to cont rol HF emissions and also provide limited control of HCl and Cl 2 

### emissions. The systems do not provi de a mechanism for controlling PM emissions and would be expected to get only incidental PM control. This type of control system is already in use in the BSCP industry (Holloway, 2014). The DLA costs were estimated using the cost algorithms from the original BSCP manufacturing ru lemaking (Shrager, 2003), which

### 10 were generated following guidelines in th e OAQPS Control Cost Manual (EPA, 2002). The algorithms were updated to include more r ecent model parameters, including the general parameters discussed previously and the following parameters specific to DLA control devices:

 Control efficiency ( e.g. , 95% HF, 30% HCl)

 Fan horsepower (60 hp [small]/90 hp [large])

 Total horsepower for other motors (10 hp [small]/40 hp [large])

 Limestone rate (85 lb/hr [small]/120 lb/hr[large])

 Limestone unit cost ($58.17/ton)
The model DLA control efficiencies for HF, HCl, and other pollutants were estimated based on averages of data from BSCP stack tests (Raymond, 2014), the limestone unit cost was estimated based on the average of data from the 2015 BIA survey (Regina, 2015), while the values of the other model DLA parameters were determined based on averages of industry responses to the 2008 BSCP survey (Holloway, 2014).
The model DLA capital costs were estimated by taking DLA capital cost data from industry responses to the 2008 BSCP survey (Holloway, 2014), escalating the costs to 2011 dollars using the CEPCI (CE, 2011) , scaling the costs to the larg e and small model sizes using the six-tenths cost rule (see Equation 3), taking the average of the scaled costs for each model size, and rounding the results to three significant figures. These costs were then adjusted by a factor of 1.07 0.5 

### to equalize the net present value (NPV).

The model DLA annual costs were estimated based on the aforementioned cost algorithms, and include the following cost items:

 Operating labor (assumed to be twice the maintenance labor hours at $22.67/hr)

 Supervisory labor (estimated at 15% of operating labor)

 Maintenance labor (estimated based on 0.75 hr/shift from BSCP survey responses and an assu med $24.94/hr wage rate)

 Maintenance materials (estimated at 100% of maintenance labor)

 Electricity (estimated based on hp requirements, 0.745 kW/hp, and $0.083/kWh)

 Limestone (estimated based on limestone rate and $58.17/ton limestone unit cost)

 Waste disposal (estimated based on waste generated and $51.90/ton waste)

 Overhead (estimated at 60% of labor and maintenance materials)

 Property taxes, insurance, and administrati ve charges (estimated at 4% of total capital cost)

 Capital recovery (estimated as the pr oduct of a 0.0944 capital recovery factor and total capital cost)
Summary. Table 1 presents the model costs fo r the DIFF, fabric filter, ACI, and DLA control options discussed above for the small and large BSCP control devices. For additional information, see Appendix B and C at the end of this memorandum.

### 11 Table 1. Summary of Control Option Model Costs Control Option Cost parameters SCD LCD Install new DIFF Total capital investment $2,000,000 $2,730,000 Total annual cost $697,321 $871,337 Install new fabric filter Total capital investment $1,200,000 $1,500,000 Total annual cost $503,074 $579,392 Replace with DIFF Total capital investment $2,800,000 $3,820,000 Total annual cost $804,836 $1,017,826 Retrofit ACI system MACT floor Total capital investment $102,224 $146,697 Total annual cost $81,307 $105,763 Beyond the floor Total capital investment $102,224 $146,697 Total annual cost $92,050 $124,179 Install DLA Total capital investment $1,096,473 $1,489,548 Total annual cost $358,556 $459,886



### IV. Model Impacts
This section discusses the methodology and a ssumptions used to estimate the model environmental and energy impacts associated with new or retrofit emission control devices that BSCP plants are expected to install in order to comply with the new standards for the BSCP industry. The model impacts parameters and calc ulations are presented in Appendix D. The model impacts tables for new and retrofit contro l devices are presented in Appendices E and F, respectively.

A. Emission Reductions
Model emission reductions were estimated for the major pollutants emitted from BSCP tunnel kilns, including both HAP (HF, HCl, Cl 2 

### , and HAP metals) and non-HAP (PM and SO 2 

### ). In most cases, we were able to determine the model emission reductions (tpy) by multiplying the model uncontrolled emission fact ors (lb/ton) in Appendix A by the model production rate (tph) and operating hours (hr/yr) in Appendix A and the appropriate contro l efficiency (%) in Appendix D, and dividing by a conversion factor of 2,000 lb/ton.
B. Energy Impacts
To determine the annual amount of electricity (in kilowatt-hours per year [kWh/yr]) needed to power the control device, the horsepower requirements (hp) of the control device were multiplied by a conversion factor of 0.745 kW/hp and the annual operating hours (hr/yr). The annual amount of energy (in million British ther mal units per year [MMBtu/yr]) needed to generate this electricity was then determined by dividing the electric ity requirements (kWh/yr) by the nationwide average power plant efficien cy (35 percent) and multiplying by a conversion factor of 3,415 British thermal units per kilowatt hour (Btu/kWh).

### 12 The efficiency for each type of power plant was determined by dividing the heat content of electricity (3,415 Btu/kWh) by the heat rate for each type of plant (10,415 Btu/kWh for coal; 8,185 Btu/kWh for natural gas; 10,452 Btu/kW h for nuclear power; and 9,756 Btu/kWh for renewable energy). The nationwide average power plant efficiency was determined as a weighted average of these power plant effici encies, based on the projected fuel mix for 2015 from Version 3.0 of EPA’s Integrated Planning M odel (IPM), which is a forecast model of the U.S. electric power sector (EPA, 2011). The proj ected fuel mix is 53 percent coal, 22 percent natural gas/other, 17 percent nuclear, and 8 percent renewable/hydroelectric (EPA, 2011).
C. Secondary Air Emissions
Once the model energy impacts were determined, the associated model secondary air emissions were estimated. Secondary emissions typically include the criteria air pollutant emissions—PM, carbon monoxide (CO), nitrogen oxides (NO X 

### ), and SO 2 

### —that result from the generation of electricity used to operate the control devices. For purposes of this analysis, the electricity was assumed to be purchased from offsite power plants. The secondary emissions were estimated by multiplying emission factors for the pollutants by the energy impacts, assuming a specific mix of fuels to gene rate the needed el ectricity. (EPA, 2011)
We used a variety of information sources to obtain the emission factors used to estimate the secondary emissions. For natural gas combus tion, we used emission factors (in pounds per cubic foot [lb/ft 3 

### ] of natural gas) from the AP-42 chap ter on natural gas combustion to estimate the secondary emissions for PM, CO, NO X 

### , and SO 2 

### (EPA, 1998a). We used the AP-42 conversion factor of 1,020 Btu/ft 3 

### of natural gas to convert th e emission factors to pounds per million British thermal units (lb/MMBtu) to facilitate estimating the secondary emissions for these pollutants from natural gas (EPA, 1998a).
For solid fuel (coal) combustion, we used emission limits (in lb/MMBtu) from the new source performance standards (NSPS) for utility plants (40 CFR part 60, subpart Da; 2006 CFR edition) to estimate the secondary emissions for PM and SO 2 

### (EPA, 2006). We used emission factors (in lb/ton coal) from the AP-42 chapter on coal combustion to estimate the secondary emissions for NO X 

### and CO; we specifically used the AP-42 emission factors for bituminous/subbituminous coal combustion/ spreader stokers (EPA, 1998b). The NO X 

### emission factor was based on an average of the AP-42 em ission factors for spread er stoker type boilers burning bituminous (11 lb/ton) and subbituminous (8.8 lb/ton) coal. We used the AP-42 conversion factor of 13,000 Btu/lb of coal to facilitate estimating the secondary emissions for NO X 

### and CO from coal (EPA, 1998b).
All secondary air impacts were attributed to the combusti on of coal, natural gas, or “other” fuels at offsite power plants. We a ttributed no secondary air impacts to nuclear, hydroelectric, or renewable energy generation. The secondary air impacts for “other” fuels were assumed to be equivalent to those for natural gas.

### 13 D. Solid Waste and Wastewater Impacts
We estimated the solid waste impacts by calcul ating the amount of material captured by the control device. The material captured by the fa bric filter includes just PM from the kiln, while the material captured by the DIFF includes:

 Reaction products from the reaction of the lime with the acid gases,

 Unreacted lime, and

 Particulate matter from the kiln.
In the absence of information, the amount of solid waste captured by a spray dryer/electrostatic precipitator (ESP) (the co ntrol system currently employed at one BSCP facility) was assumed to be the same as that captured by a DIFF, since both emission control systems include a combination of acid gas and PM controls, unlike a stan d-alone fabric filter (which captures only PM) or a DLA (which ca ptures mostly acid gases, primarily HF).
We estimated the wastewater impacts asso ciated with using a spray dryer/ESP by calculating the amount of water usage for the spra y dryer, using the equation shown in Appendix E. There are no wastewater impacts for the other control devices.
E. Model Impacts for Control Options
Model impacts were estimated for the followi ng control scenarios a nd are presented in the appendix tables cited below:

 Installation of new DIFF on unc ontrolled kiln (see Table E-1)

 Installation of new fabric filter on uncont rolled kiln (where acid gas levels and exhaust gas temperatures are low) (see Table E-2)

 Installation of fabric filter af ter an existing acid gas control ( e.g. , DLA) (see Table E-2)

 Installation of DLA on uncont rolled kiln(s) to become synthetic area source (see Table E-3)

 Installation of ACI sy stem to an existing control system ( e.g. , DIFF) (see Table F-1)

 Replacement of existing DLA with a new DIFF (see Table F-2)

 Replacement of existing spray dryer/ESP with a new DIFF (see Table F-3)

 Replacement of existing DIFF with a new, more efficient DIFF (see Table F-4)
To estimate the incremental impacts for replacement control devices, the impacts associated with baseline controls were subtracted from the impact s associated with new controls. For DLA and spray dryer/ESP controls being re placed with a DIFF, the incremental impacts include the emission reductions, energy impacts, s econdary air impacts, so lid waste impacts, and wastewater impacts (spray dryer/E SP controls only). For those cases where a facility replaces an existing DIFF with a new, more efficient DIFF to comply with the new standards, we assumed no change in energy requirements or the associ ated secondary emissions, but we estimated the difference in emissions and solid waste impact s that would accompany the improved control of PM and acid gases.

### 14 Because we had no control efficiency data for spray dryer/electrostatic precipitator (ESP), we used stack test data for the kilns equipped wi th this emission control as the baseline emissions and subtracted the baseline emissions for th e DIFF to determine the incremental emissions reduction from replacing a spra y dryer/ESP with a DIFF.
Tables 2 through 4 present the model impacts fo r the DIFF, fabric filter, and ACI control installation/retrofit options and control replacem ent options discussed above for the small and large BSCP control devices. For additional in formation, see the aforementioned tables in Appendices E and F at the end of this memorandum.

Table 2a. Summary of Model Emission Reductions for Control Installation/Retrofit Options

Control option Pollutant Emissions reductions, tpy SCD LCD Install new DIFF Hydrogen fluoride 18.13 38.85 Hydrogen chloride 2.06 4.42 Chlorine 0.09 0.20 HAP metals 0.103 0.220 Particulate matter 9.33 19.99 Sulfur dioxide 48.26 103.42 Install fabric filter HAP metals 0.103 0.220 Particulate matter 9.33 19.99 Install new DLA Hydrogen fluoride 17.61 37.73 Hydrogen chloride 0.74 1.59 Chlorine 0.04 0.10 HAP metals 0.025 0.053 Particulate matter 2.27 4.86 Sulfur dioxide 11.88 25.47 Retrofit ACI system MACT floor Mercury 0.0016 0.0035 Beyond the floor Mercury 0.0018 0.0039

### 15 Table 2b. Summary of Model Emission Reductions for Control Replacement Options

Control option Pollutant Net emissions reductions, tpy SCD LCD Replace dry limestone adsorber with new DIFF Hydrogen fluoride 0.82 1.76 Hydrogen chloride 1.32 2.83 Chlorine 0.05 0.11 HAP metals 0.081 0.173 Particulate matter 7.35 15.74 Sulfur dioxide 36.38 77.96 Replace spray dryer/ESP with new DIFF Hydrogen fluoride 20.96 41.91 Hydrogen chloride 4.72 9.38 Chlorine 0.64 1.28 HAP metals 0.00 0.00 Particulate matter 0.00 0.00 Sulfur dioxide 0.73 1.56 Replace existing DIFF with new, more efficient DIFF Hydrogen fluoride 0.27 0.59 Hydrogen chloride 0.03 0.07 Chlorine 0.001 0.003 HAP metals 0.024 0.051 Particulate matter 2.18 4.68 Sulfur dioxide 0.73 1.56

Table 3a. Summary of Model Energy and Solid Waste Impacts for Control Installation/Retrofit Options Control option Type of impact SCD LCD Install new DIFF Energy impacts, MMBtu/yr 11,544 14,109 Solid waste impacts, tpy 447 678 Install fabric filter Energy impacts, MMBtu/yr 11,544 14,109 Solid waste impacts, tpy 9.33 19.99 Install new DLA Energy impacts, MMBtu/yr 4,489 8,337 Solid waste impacts, tpy 367 513 Retrofit ACI system MACT floor Energy impacts, MMBtu/yr 371 621 Solid waste impacts, tpy 12.26 20.15 Beyond the floor Energy impacts, MMBtu/yr 371 621 Solid waste impacts, tpy 18.40 30.66

### 16 Table 3b. Summary of Model Energy, Solid Waste, and Wastewater Impacts for Control Replacement Options

Control option Type of impact Increase in impacts 1 SCD LCD Replace dry limestone adsorber with new DIFF Energy impacts, MMBtu/yr 7,055 5,772 Solid waste impacts, tpy 80.10 165 Replace spray dryer/ESP with new DIFF Energy impacts, MMBtu/yr -9,299 -27,577 Solid waste impacts, tpy 8.66 14.43 Wastewater impacts, gpy -2,281 -4,563 Replace existing DIFF with new, more efficient DIFF Energy impacts, MMBtu/yr 0 0 Solid waste impacts, tpy 8.66 14.43

1 A negative increase in impacts would be equivalent to a reduction in impacts.

Table 4a. Summary of Model Secondary Impacts for Control Installation/Retrofit Options

Control option Secondary pollutant 1 Secondary air impacts, tpy SCD LCD Install new DIFF Particulate matter 0.09 0.10 PM 2.5 0.029 0.035 Carbon monoxide 0.14 0.18 Nitrogen oxides 1.14 1.39 Sulfur dioxide 3.33 4.06 Install fabric filter Particulate matter 0.09 0.10 PM 2.5 0.029 0.035 Carbon monoxide 0.14 0.18 Nitrogen oxides 1.14 1.39 Sulfur dioxide 3.33 4.06 Install new DLA Particulate matter 0.03 0.06 PM 2.5 0.011 0.021 Carbon monoxide 0.06 0.10 Nitrogen oxides 0.44 0.82 Sulfur dioxide 1.29 2.40 Retrofit ACI system (MACT floor/beyond the floor) Particulate matter 0.003 0.005 PM 2.5 0.0009 0.0015 Carbon monoxide 0.005 0.008 Nitrogen oxides 0.04 0.06 Sulfur dioxide 0.11 0.18

1 PM 2.5 = PM with particles less than 2.5 micrometers in diameter.

### 17 Table 4b. Summary of Model Secondary Impacts for Control Replacement Options

Control option Secondary pollutant 2 Increase in secondary air impacts, tpy 1 SCD LCD Replace dry limestone adsorber with new DIFF Particulate matter 0.05 0.04 PM 2.5 0.017 0.014 Carbon monoxide 0.09 0.07 Nitrogen oxides 0.70 0.57 Sulfur dioxide 2.03 1.66 Replace spray dryer/ESP with new DIFF Particulate matter -0.07 -0.20 PM 2.5 -0.023 -0.068 Carbon monoxide -0.12 -0.34 Nitrogen oxides -0.92 -2.73 Sulfur dioxide -2.68 -7.94 Replace existing DIFF with new, more efficient DIFF Particulate matter 0 0 PM 2.5 0 0 Carbon monoxide 0 0 Nitrogen oxides 0 0 Sulfur dioxide 0 0

1 A negative increase in secondary air impacts would be e quivalent to a reduction in secondary air impacts.

2 PM 2.5 = PM with particles less than 2.5 micrometers in diameter.



### V. References
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. Accessed September 14, 2015.

Alstom. 2014 . Mer-Cure TM 

### : Mercury reduction system . Boiler Service Solutions. 2014. Available at: http://www.alstom.com/Global/Power/ Resources/Documents/Brochures/aqcsmer-cure-mercury-reduction- system.pdf?epslanguage=en-GB . Accessed September 14, 2015.
BLS (U.S. Department of Labor, Bu reau of Labor Statistics). 2012. Occupational Employment Statistics: May 2011 National Industry-Speci fic Occupational Employment and Wage Estimates . NAICS 327100 - Clay Product and Re fractory Manufacturing. Industrial Engineering Technician. March 27, 2012. Available at: http://www.bls.gov/oes/2011/may/naics4_327100.htm . Docket Item No. EPA-HQ-OAR2013-0291-0069.
CE (Chemical Engineering). 2011. Plant Cost Index.
Childress, J. 2013a. “RE: From McGill AirClean Web Site.” E-mail from Jerry Childress, McGill AirClean LLC, to Thomas Holloway, RTI International. April 18, 2013. Docket Item No. EPA-HQ-OAR-2013-0291-0224.

### 18 Childress, J. 2013b. “RE: From McGill AirClean Web Site.” E-mail from Jerry Childress, McGill AirClean LLC, to Thomas Holloway, RTI International. June 27, 2013. Docket Item No. EPA-HQ-OAR-2013-0291-0219.
EPA (U.S. Environmental Protection Agency). 1998a. Compilation of Air Pollutant Emission Factors. Volume 1: Stationary Point and Area Sources . AP-42, Section 1.4: Natural Gas Combustion. July 1998. Docket Item No. EPA-HQ-OAR-2013-0291-0001.
EPA (U.S. Environmental Protection Agency). 1998b. Compilation of Air Pollutant Emission Factors. Volume 1: Stationary Point and Area Sources . AP-42, Section 1.1: Bituminous and Subbituminous Coal Combustion. Septembe r 1998. Docket Item No. EPA-HQ-OAR-2013- 0291-0002.
EPA (U.S. Environmental Protection Agency). 2002. EPA Air Pollution Control Cost Manual

. Sixth Edition. Office of Air Qu ality Planning and Standards, Research Triangle Park, NC. Publication No. EPA/452/B-02-001. January 2002. Docket Item No. EPA-HQ-OAR-2013- 0291-0011.
EPA (U.S. Environmental Protection Agency). 2005. Technical Support Document for the HWC MACT Replacement Standards, Volume V: Emissions Estimates and Engineering Costs

. Office of Solid Waste and Emergency Respons e, Washington, DC. September 2005. Docket Item No. EPA-HQ-OAR-2013-0291-0025.
EPA (U.S. Environmental Protection Agency). 2006. “Subpart Da—Standards of Performance for Electric Utility Steam Generating Units for Which Construction is Commenced After September 18, 1978.” Code of Federal Regulations , Title 40, Part 60. Published by Office of the Federal Register, National Archives a nd Records Administration. As of July 1, 2006.
EPA (U.S. Environmental Protection Agency). 2011. Regulatory Impact Analysis for the Final Mercury and Air Toxics Standards . Table 3-6: Generation Mix w ith the Base Case and the MATS, 2015 (Thousand GWh). Publicat ion No. EPA-452/R-11-011. December 2011. Docket Item No. EPA-HQ-OAR-2013-0291-0067.
EPA (U.S. Environmental Protection Agen cy). 2015. National Emission Standards for Hazardous Air Pollutants for Brick and Structur al Clay Products Manufacturing: Background Information for Final Rule; Summary of Public Comments and Responses. September 2015.
Hansen, L. 2013. “RE: Question regard ing use of fabric filters for brick kilns.” E-mail from Lars Hansen, Solios Environment Corp., to Thom as Holloway, RTI Intern ational. July 2, 2013. Docket Item No. EPA-HQ-OAR-2013-0291-0218.
Holloway, T. 2009. Revised Baseline Operating Costs for Existing HMIWI . Memorandum from Thomas Holloway, RTI International, to Ketan Patel, OAQPS/SPPD/NRCG. June 19, 2009.
Holloway, T. 2013a. Telephone Contact Summary: Jeff Thompson, Cabot Norit Activated Carbon . Contacted by Thomas Holloway, RTI Inte rnational. May 16, 2013. Docket Item No. EPA-HQ-OAR-2013-0291-0221.

### 19 Holloway, T. 2013b. “RE: From McGill AirClean Web Site.” E-mail from Thomas Holloway, RTI International, to Jerry Childress, McG ill AirClean LLC. June 26, 2013. Docket Item No. EPA-HQ-OAR-2013-0291-0219.
Holloway, T. 2013c. Telephone Contact Summary: Chris Poli zzi, W.L. Gore & Associates, Inc. Contacted by Thomas Holloway, RTI Interna tional. July 16, 2013. Docket Item No. EPAHQ-OAR-2013-0291-0217.
Holloway, T. 2014. Updated Inventory Database and Docume ntation for Brick and Structural Clay Products Proposed Rule . Memorandum from Thomas Hollo way, RTI International, to Jeff Telander, EPA/OAQPS/ SPPD. November 6, 2014. Docket Item No. EPA-HQ-OAR2013-0291-0125.
Morris, L. 2012. “Solutions for Controlling Mercury.” Power Engineering . Volume 116, Issue 4. April 1, 2012. Available at: http://www.power-eng.com/artic les/print/volume-116/issue4/features/solutions-fo r-controlling-mercury.html . Accessed September 14, 2015.

Novinda. 2015. What is Amended Silicates TM 

### ? Available at: http://www.novinda.com/producttechnologies/mercury-remova l/what-is-amended-silicates/ . Accessed September 14, 2015.
Poling, C. et al. 2015. A Novel Approach for Mercury Capture . Presentation by Christopher L. Poling, Melissa Harrison, and Paul Longo, SCB International Materials, Inc., to U.S. Environmental Protection Agency. 2015.
Raymond, G. 2014. Test Data Used in BSCP Proposed Rule . Memorandum from Gabrielle Raymond, RTI International, to Jeff Te lander, EPA/OAQPS/SPPD. November 6, 2014. Docket Item No. EPA-HQ-OAR-2013-0291-0121.
Regina, P. 2015. “RE: Docket no. EPA-HQ-OAR- 2013-0291 Brick and Structural Clay Products Manufacturing.” Letter from Paul Regina, The Br ick Industry Associati on, to Environmental Protection Agency, EPA Docket Center. Ma rch 19, 2015. Docket Item No. EPA-HQ-OAR2013-0291-0542.
Shrager, B. 2003. Final Rule: Costs for Air Poll ution Control Devices on Kilns . Memorandum from Brian Shrager, RTI International, to Mary Johnson, U.S. Environmental Protection Agency. February 25, 2003.
Tayler, G. 2015. “RE: Docket no. EPA-HQ-OAR- 2013-0291 Brick and Structural Clay Products Manufacturing.” Letter from Dr. Garth Tayler, Acme Brick Co., to Environmental Protection Agency, EPA Docket Center. March 14, 2015. Docket Item No. EPA-HQ-OAR-2013-0291- 0516.
Thompson, J. 2013. “FW: Cabot Norit Activated Carbon–question.” E-mail from Jeff Thompson, Cabot Norit Activated Carbon, to Thomas Holloway, RTI International. May 31, 2013. Docket Item No. EPA-HQ-OAR-2013-0291-0220.

### Appendix A

Model Parameters

### A-2 Table A-1. General Parameters for BSCP Model Control Devices
Parameters SCD LCD Footnotes Process parameters Production rate, ton/hr 7.0 15.0 1 Operating hours, hr/yr 8,760 8,760 2 Exhaust flow, acfm 23,100 38,700 3 Unit costs Electricity cost, $/kwh 0.083 0.083 1 Waste disposal cost, $/ton 51.90 51.90 2 Operator wage rate, $/hr 22.67 22.67 4 Maintenance wage rate, $/hr 24.94 24.94 5 Capital recovery factor--system 0.0944 0.0944 6 Molecular weights HF 20 20 HCl 36.5 36.5 SO 2 64 64 CaF 2 78 78 7 CaCl 2 111 111 7 CaSO 3 120 120 7 Ca(OH) 2 74 74 8 Uncontrolled emissions, lb/ton HF 0.594 0.594 3 HCl 0.0808 0.0808 3 Cl 2 0.00346 0.00346 3 Non-Hg HAP Metals 0.00356 0.00356 9 PM 0.324 0.324 3 SO 2 3.23 3.23 3 Uncontrolled emissions, lb/hr HF 4.16 8.91 10 HCl 0.566 1.21 10 Cl 2 0.0242 0.0519 10 Non-Hg HAP Metals 0.0249 0.0534 10 PM 2.27 4.86 10 SO 2 22.6 48.5 10 1. Average from section 114 survey responses. 2. Average from 2015 BIA survey data. 3. Average from test data. 4. Mean hourly wage, from Bureau of Labor Statistics, May 2011 Nati onal Industry-Specific Occupational

Employment and Wage Estimates, NAICS 327100, Industrial Engineering Technician. Website: http://www.bls.gov/oes/2011/may/naics4_327100.htm . Wage rates from Bureau of Labor Statistics were used because they are more conservative than those provided by section 114 survey respondents. 5. 10 percent higher than operator rate. 6. Based on equipment life of 20 years and 7 percent interest. 7. Reaction product; CaF 2 = calcium fluoride; CaCl 2 = calcium chloride; CaSO 3 = calcium sulfite. 8. Hydrated lime. 9. Assume 1.1 percent of PM. 10. Calculated from lb/ton times production rate.

### Appendix B

Installation Model Costs

### B-2 Table B-1. Model Costs to Install New DIFF
Parameters SCD LCD Footnotes Control efficiency, percent HF 99.5% 99.5% 1 HCl 83.3% 83.3% 2 Cl 2 89.3% 89.3% 3 Non-Hg HAP Metals 94% 94% 4 PM 94% 94% 1 SO 2 48.7% 48.7% 5 Design and operating parameters Fan hp 150 190 6 Total hp for other motors 30 30 6 Hydrated lime, fraction of stoichiometric amount 2.65 1.79 7 Operator labor, hr/shift 2.5 2.5 8 Maintenance labor, hr/shift 1.25 1.25 6 Bag life, yr 5 5 6 Gas-to-cloth ratio (gross), ft/min 3.4 3.4 6 Bag area, ft 2 28 28 6 Compressed air, ft 3 /1,000 ft 3 0.9 0.9 6 Time to replace bags, hr/bag 2.25 2.25 6 Added cooling air, ft 3 /min 0 0 9 Calculated parameters Hydrated lime makeup, lb/hr 91.4 132.0 Reaction products, lb/hr 29.4 63.1 10 Reacted lime, lb/hr 20.9 44.7 Particulate matter, lb/hr 2.1 4.6 Waste, lb/hr 102.1 154.9 11 Cost factors Hydrated lime, $/ton 160 160 6 Bag fabric cost, $/ft 2 8.15 8.15 6 Compressed air, $/1,000 ft 3 0.363 0.363 12 Capital recovery factor--bags 0.244 0.244 13 Capital costs Total capital investment 2,000,000 2,730,000 14 Annual costs Operating labor 62,059 62,059 Supervisory labor 9,309 9,309 15 Maintenance labor 34,133 34,133 Maintenance materials 34,133 34,133 16 Electricity 97,501 119,168 17 Lime 64,018 92,471 Compressed air 3,967 6,645 Annualized replacement bags 13,505 22,625 Annualized bag replacement labor 3,320 5,563 18 Cage replacement 19

### B-3 Parameters SCD LCD Footnotes Waste disposal 23,199 35,209 Overhead 83,780 83,780 20 Administrative charges 40,000 54,600 21 Property taxes 20,000 27,300 22 Insurance 20,000 27,300 22 Capital recovery 188,399 257,044 Total annual cost, $/yr 697,321 871,337 1. Average from test data with better efficiency than baseline. 2. Based on ratio of enhanced HF reduction and baseline HCl reduction. 3. Based on ratio of enhanced HF reduction and baseline Cl 2 reduction. 4. Assume same as PM. 5. Based on ratio of enhanced HF reduction and baseline SO 2 reduction. 6. Average from section 114 survey responses. 7. Assume hydrated lime is 2.64/1.78 ti mes the stoichiometric amount needed to get additional control re baseline

(from 98% to 99.5%). 8. Assume 2 times maintenance labor (EPA, 2002). 9. Assume none. 10. CaF 2 (calcium fluoride), CaCl 2 (calcium chloride), and CaSO 3 (calcium sulfite). 11. Inlet lime minus reacted lime plus reaction products and PM. 12. Average from 2015 BIA survey data. 13. Based on equipment life of 5 years and 7 percent interest. 14. Average of costs from section 114 survey responses scaled using 6/10 rule (based on acfm), escalated to 2011

dollars, and rounded. 15. 15 percent of operator labor. 16. 100 percent of maintenance labor. 17. Based on conversion fa ctor of 0.745 kW/hp. 18. Performed by maintenance personnel. 19. Maybe no need to replace. 20. 60 percent of labor and maintenance materials. 21. 2 percent of TCI. 22. 1 percent of TCI.

### B-4 Table B-2. Model Costs to Install New Fabric Filter
Parameters SCD LCD Footnotes Control efficiency, percent Non-Hg HAP Metals 94% 94% 1 PM 94% 94% 2 Design and operating parameters Fan hp 150 190 3 Total hp for other motors 30 30 3 Operator labor, hr/shift 2.5 2.5 4 Maintenance labor, hr/shift 1.25 1.25 3 Bag life, yr 5 5 3 Gas-to-cloth ratio (gross), ft/min 3.4 3.4 3 Bag area, ft 2 28 28 3 Compressed air, ft 3 /1,000 ft 3 0.9 0.9 3 Time to replace bags, hr/bag 2.25 2.25 3 Added cooling air, ft 3 /min 0 0 5 Calculated parameters Waste, lb/hr 2.1 4.6 6 Cost factors Bag fabric cost, $/ft 2 8.15 8.15 3 Compressed air, $/1,000 ft 3 0.363 0.363 7 Capital recovery factor--bags 0.244 0.244 8 Cost of dry injection system 800,907 1,230,278 9 Capital costs Total capital investment 1,200,000 1,500,000 10 Annual costs Operating labor 62,059 62,059 Supervisory labor 9,309 9,309 11 Maintenance labor 34,133 34,133 Maintenance materials 34,133 34,133 12 Electricity 97,501 119,168 13 Compressed air 3,967 6,645 Annualized replacement bags 13,505 22,625 Annualized bag replacement labor 3,320 5,563 14 Cage replacement 0 0 15 Waste disposal 484 1,038 Overhead 83,780 83,780 16 Administrative charges 24,000 30,000 17 Property taxes 12,000 15,000 18 Insurance 12,000 15,000 18 Capital recovery 112,884 140,940 Total annual cost, $/yr 503,074 579,392
1. Assume same as PM. 2. Average from test data with better efficiency than baseline. 3. Average from section 114 survey responses. 4. Assume 2 times maintenance labor (EPA, 2002).

### B-5 5. Assume none. 6. Particulate matter. 7. Average from 2015 BIA survey data . 8. Based on equipment life of 5 years and 7 percent interest. 9. Based on cost equations in the June 19, 2009 memorandum Revised Baseline Operating Costs for Existing

HMIWI , in Docket ID No. EPA-HQ-OAR-2006-0534 for the hospi tal/medical/infectious wa ste incinerator (HMIWI) rule. 10. Average of costs from section 114 survey responses scaled using 6/10 rule (based on acfm), subtracted cost of

dry injection system, escalated to 2011 dollars, and rounded. 11. 15 percent of operator labor. 12. 100 percent of maintenance labor. 13. Based on conversion fa ctor of 0.745 kW/hp. 14. Performed by maintenance personnel. 15. Maybe no need to replace. 16. 60 percent of labor and maintenance materials. 17. 2 percent of TCI. 18. 1 percent of TCI.

### B-6 Table B-3. Model Costs to Install New DLA
Parameters SCD LCD Footnotes Control efficiency, percent HF 95% 95% 1 HCl 30% 30% 1 Cl 2 42% 42% 1 Non-Hg HAP Metals 20% 20% 2 PM 20% 20% 1 SO 2 12% 12% 1 Design and operating parameters Fan hp 60 90 3 Total hp for other motors 10 40 3 Limestone, lb/hr 85 120 3 Operator labor, hr/shift 1.5 1.5 4 Maintenance labor, hr/shift 0.75 0.75 3 Calculated parameters Reaction products, lb/hr 13.2 28.3 5 Reacted limestone, lb/hr 14.5 31.1 Particulate matter, lb/hr 0.07 0.07 Waste, lb/hr 83.7 117.2 6 Cost factors Limestone, $/ton 58.17 58.17 7 Factor to equalize NPV 1.034408 1.034408 8 Capital costs Total capital investment 1,096,473 1,489,548 9 Annual costs Operating labor 37,235 37,235 Supervisory labor 5,585 5,585 10 Maintenance labor 20,480 20,480 Maintenance materials 20,480 20,480 11 Electricity 37,917 70,418 12 Limestone 21,657 30,574 Waste disposal 19,035 26,644 13 Overhead 50,268 50,268 14 Administrative charges 21,200 28,800 15 Property taxes 10,600 14,400 16 Insurance 10,600 14,400 16 Capital recovery 103,499 140,603 Total annual cost, $/yr 358,556 459,886 1. Average from test data. 2. Assume same as PM. 3. Average from section 114 survey responses. 4. Assume 2 times maintenance labor (EPA, 2002). 5. CaF 2 (calcium fluoride), CaCl 2 (calcium chloride), and CaSO 3 (calcium sulfite). 6. Inlet limestone minus reacted limestone plus reaction products and PM. 7. Average from 2015 BIA survey data.

### B-7 8. Factor to equalize the net present value (NPV) = 1.07 0.5 = 1.034408 9. Average of costs from section 114 survey responses sca led using 6/10 rule (based on acfm), escalated to 2011

dollars, and rounded, then multiplied by the NPV factor. 10. 15 percent of operator labor. 11. 100 percent of maintenance labor. 12. Based on conversion fa ctor of 0.745 kW/hp. 13. Some facilities have minimal waste disposal costs. 14. 60 percent of labor and maintenance materials. 15. 2 percent of TCI. 16. 1 percent of TCI.

### Appendix C
Retrofit/Replacement Model Costs

### C-2 Table C-1. Model Costs to Replace Existing Control Device with DIFF
Parameters SCD LCD Footnotes Control efficiency, percent HF 99.5% 99.5% 1 HCl 83.3% 83.3% 2 Cl 2 89.3% 89.3% 3 Non-Hg HAP Metals 94% 94% 4 PM 94% 94% 1 SO 2 48.7% 48.7% 5 Design and operating parameters Fan hp 150 190 6 Total hp for other motors 30 30 6 Hydrated lime, fraction of stoichiometric amount 2.65 1.79 7 Operator labor, hr/shift 2.5 2.5 8 Maintenance labor, hr/shift 1.25 1.25 6 Bag life, yr 5 5 6 Gas-to-cloth ratio (gross), ft/min 3.4 3.4 6 Bag area, ft 2 28 28 6 Compressed air, ft 3 /1,000 ft 3 0.9 0.9 6 Time to replace bags, hr/bag 2.25 2.25 6 Added cooling air, ft 3 /min 0 0 9 Calculated parameters Hydrated lime makeup, lb/hr 91.4 132.0 Reaction products, lb/hr 29.4 63.1 10 Reacted lime, lb/hr 20.9 44.7 Particulate matter, lb/hr 2.1 4.6 Waste, lb/hr 102.1 154.9 11 Cost factors Hydrated lime, $/ton 160 160 6 Bag fabric cost, $/ft 2 8.15 8.15 6 Compressed air, $/1,000 ft 3 0.363 0.363 12 Capital recovery factor--bags 0.244 0.244 13 Retrofit factor 1.4 1.4 14 Capital costs Total capital investment 2,800,000 3,820,000 15 Annual costs Operating labor 62,059 62,059 Supervisory labor 9,309 9,309 16 Maintenance labor 34,133 34,133 Maintenance materials 34,133 34,133 17 Electricity 97,501 119,168 18 Lime 64,018 92,471 Compressed air 3,967 6,645 Annualized replacement bags 13,505 22,625 Annualized bag replacement labor 3,320 5,563 19

### C-3 Parameters SCD LCD Footnotes Cage replacement 0 0 20 Waste disposal 23,199 35,209 Overhead 83,780 83,780 21 Administrative charges 56,000 76,400 22 Property taxes 28,000 38,200 23 Insurance 28,000 38,200 23 Capital recovery 263,913 359,932 Total annual cost, $/yr 804,836 1,017,826 1. Average from test data with better efficiency than baseline. 2. Based on ratio of enhanced HF reduction and baseline HCl reduction. 3. Based on ratio of enhanced HF reduction and baseline Cl 2 reduction. 4. Assume same as PM. 5. Based on ratio of enhanced HF reduction and baseline SO 2 reduction. 6. Average from section 114 survey responses. 7. Assume hydrated lime is 2.65/1.79 ti mes the stoichiometric amount needed to get additional control re baseline

(from 98% to 99.5%). 8. Assume 2 times maintenance labor (EPA, 2002). 9. Assume none. 10. CaF 2 (calcium fluoride), CaCl 2 (calcium chloride), and CaSO 3 (calcium sulfite). 11. Inlet lime minus reacted lime plus reaction products and PM. 12. Average from 2015 BIA survey data . 13. Based on equipment life of 5 years and 7 percent interest. 14. Average for various control devices (EPA, 2002). 15. Average of costs from section 114 survey responses scaled using 6/10 rule (based on acfm), escalated to 2011

dollars, multiplied by retrofit cost factor, and rounded. 16. 15 percent of operator labor. 17. 100 percent of maintenance labor. 18. Based on conversion fa ctor of 0.745 kW/hp. 19. Performed by maintenance personnel. 20. Maybe no need to replace. 21. 60 percent of labor and maintenance materials. 22. 2 percent of TCI. 23. 1 percent of TCI.C-4Table C-2. Model Costs to Retrofit ACI System to Existing Control DeviceParametersMACT FloorBeyond the FloorFootnotesSCDLCDSCDLCDDesign and operating parametersCarbon injection rate (lb/MMft3) [CIR] 2 2 3 3 1Injection blower fan power (hp) [Powerfan] 5.2 8.7 5.2 8.7 2,3Projected equipment life (yrs) [n] 15 15 15 15 2Interest rate (%) [i] 7 7 7 7Calculated parametersCarbon feed rate (lb/hr) [CFR] 2.8 4.6 4.2 7.0 4Cost factorsCarbon unit cost ($/lb) [CC] 0.85 0.85 0.85 0.85 5Escalation factor [EF] 1.78 1.78 1.78 1.78 2,6,7Capital recovery factor [CRF] 0.1098 0.1098 0.1098 0.1098 2,8Retrofit factor [RF] 1.15 1.15 1.15 1.15 2Direct capital costsPurchased equipment costsTotal equipment [TEC] (see Note) 24,294 34,864 24,294 34,864 2,9Sales tax 729 1,046 729 1,046 2,10Freight 1,215 1,743 1,215 1,743 2,11Purchased equipment with tax and freight 26,238 37,653 26,238 37,653 2,12Purchased equipment with escalation 46,784 67,138 46,784 67,138 2,13Purchased equipment with retrofit factor [PEC] 53,802 77,209 53,802 77,209 2,14Installation cost [IC] 16,141 23,163 16,141 23,163 2,15Total direct costs [TDC] 69,942 100,371 69,942 100,371 2,16Indirect capital costsEngineering 10,760 15,442 10,760 15,442 2,17Construction and field expense 10,760 15,442 10,760 15,442 2,17Contractor fees 5,380 7,721 5,380 7,721 2,18Start-up 538 772 538 772 2,19Performance test 538 772 538 772 2,19Model study 1,076 1,544 1,076 1,544 2,20Contingencies 3,228 4,633 3,228 4,633 2,21C-5ParametersMACT FloorBeyond the FloorFootnotesSCDLCDSCDLCDTotal indirect costs [TIC] 32,281 46,325 32,281 46,325 2,22Total capital costTotal capital investment [TCI] 102,224 146,697 102,224 146,697 2,23Annual costsOperating labor 8,275 8,275 8,275 8,275 2,24Supervisory labor 1,241 1,241 1,241 1,241 2,25Maintenance labor 13,653 13,653 13,653 13,653 2,26Maintenance materials 2,690 3,860 2,690 3,860 2,27Electricity cost 3,135 5,245 3,135 5,245 2,28Carbon cost 20,849 34,252 31,273 52,122 2,29Solid waste disposal cost 637 1,046 955 1,591 2,30Overhead 15,515 16,218 15,515 16,218 2,31Administrative charges 2,044 2,934 2,044 2,934 2,32Property tax 1,022 1,467 1,022 1,467 2,33Insurance 1,022 1,467 1,022 1,467 2,33Capital recovery 11,224 16,107 11,224 16,107 2,34Total annual cost 81,307 105,763 92,050 124,179 2,35Note: Total equipment includes storage silo, feed bin, gravimetric feeders, pneumatic conveyor, and injection ports.Footnotes:1. Thompson, 2013. Suggested carbon concentration of 2 lb/MMft3.2. EPA, 2005, Appendix J.3. Scaled HWC hp estimate using ratio of exhaust flow rates: (15 hp) x Q / (66,870.6 acfm).4. Equal to CIR / 1E6 x exhaust flow x (60 min/hr).5. Holloway, 2013a. Indicated carbon price would be $0.80 to $0.90/lb.Used average of $0.85/lb.6. Escalating costs from 2004 (HWC) to 2011 (BSCP) using the following factors: (HWC escalation factor, 1.1319 x 1.064) x (BSCPescalation factor, 1.4805).7. Chemical Engineering Plant Cost Index.8. Equal to = [i x (1 + i)n] / [(1 + i)n- 1], where i = 7 percent interest and n = 15-year equipment life.9. Equal to 90,000 x (exhaust flow/150,000)0.7.10. Equal to 0.03 x TEC.11. Equal to 0.05 x TEC.C-612. Equal to TEC + (sales tax) + (freight).13. Equal to EF x (purchased equipment with tax and freight).14. Equal to RF x (purchased equipment with escalation).15. Equal to 0.3 x PEC.16. Equal to PEC + IC.17. Equal to 0.2 x PEC.18. Equal to 0.1 x PEC.19. Equal to 0.01 x PEC.20. Equal to 0.02 x PEC.21. Equal to 0.06 x PEC.22. Equal to sum of indirect costs.23. Equal to TDC + TIC.24. Equal to (1 hr/d) x operating hr/yr/ (24 hr/d) x operator wage rate ($/hr).25. Equal to 0.15 x (operator labor cost).26. Equal to (0.5 hr/shift) x (3 shifts/d) x operating hr/yr / (24 hr/d) x maintenance wage rate ($/hr).27. Equal to 0.05 x PEC.28. Equal to Powerfan/ (1.34 hp/kW) / (0.9 Efficiencyfan) x operating hr/yr x electricity unit cost ($/kWh).29. Equal to CFR x operating hr/yr x carbon unit cost ($/lb).30. Equal to CFR x operating hr/yr / (2000 lb/ton) x waste disposal unit cost ($/ton).31. Equal to 0.6 x (operating labor cost + maintenance cost).32. Equal to 0.02 x TCI.33. Equal to 0.01 x TCI.34. Equal to CRF x TCI.35. Equal to sum of annual costs.

### Appendix D
Model Impacts Equations

### D-2 Table D-1. Equations Used to Estimate Model Energy and Secondary Impacts
Parameters Value Notes, units, and equations Energy impacts Heat factors Heat content of electricity (HC elec ) 3,415 Btu/kWh

Heat rate Coal (HR coal ) 10,415 Btu/kWh Natural gas (HR gas ) 8,185 Btu/kWh Nuclear power (HR nuclear ) 10,452 Btu/kWh Renewable energy (HR renew ) 9,756 Btu/kWh Percent of generation Coal (% coal) 48% Used for solid fuel Oil/natural gas (% gas) 18% Used for natural gas Nuclear (% nuclear) 20% No secondary emissions estimated Hydroelectric (% hydro) 7% No secondary emissions estimated Renewable (% renew) 6% No secondary emissions estimated Other (% other) 1% Used for natural gas (assumed equivalent) Power plant efficiency (E) Coal (E coal ) 33% % = HC elec / HR coal * 100 Natural gas/other (E gas ) 42% % = HC elec / HR gas * 100 Nuclear (E nuclear ) 33% % = HC elec / HR nuclear * 100 Renewable/hydroelectric (E renew ) 35% % = HC elec / HR renew * 100
Average (E avg ) 35% % = (E coal x % coal) + (E gas x % gas/other) + (E nuclear x % nuclear) + (E renew x % renew/hydro) Energy impacts calculations Electricity requirements model-specific kWh/yr = total hp x (0.745 kW/hp) x operating hr/yr Energy impacts model-specific MMBtu/yr = (kWh/yr) x (HC elec ) x (MMBtu/1E 6 Btu) / E avg Secondary emissions Emission factors, natural gas Particulate matter/PM 2.5 1.9 lb/MM ft 3 natural gas 0.00186275 lb/MMBtu natural gas Carbon monoxide 84 lb/MM ft 3 natural gas 0.0824 lb/MMBtu natural gas Nitrogen oxide 100 lb/MM ft 3 natural gas 0.0980 lb/MMBtu natural gas Sulfur dioxide 0.6 lb/MM ft 3 natural gas 0.00059 lb/MMBtu natural gas Emission factors, solid fuel Particulate matter 0.03 lb/MMBtu solid, liquid, gaseous fuel PM 2.5 0.00957 lb/MMBtu solid, liquid, gaseous fuel Carbon monoxide 0.19 lb/MMBtu bituminous coal Nitrogen oxide 0.38 lb/MMBtu solid fuel Sulfur dioxide 1.2 lb/MMBtu solid fuel

### D-3 Parameters Value Notes, units, and equations Secondary emissions calculation Secondary emissions, for each pollutant model-specific lb/yr = MMBtu/yr x [(lb/MMBtu natural gas) x (% gas/other) + (lb/MMBtu solid fuel) x (% coal)] Solid waste and wastewater impacts Solid waste impacts model-specific tpy = waste (lb/hr) x operating hr/yr / (2,000 lb/ton) Wastewater impacts model-specific gpy = water usage (gpd) x operating hr/yr / (24 hr/d) 1. gpy = gallons per year; gpd = gallons per day. 2. Assume electricity generated using the above mix (from IPM Version 3.0 fo r the year 2015), as determined from

Table 3-6 of Regulatory Impacts Analysis for the final Mercury and Air Toxics Standards. IPM = EPA Integrated Planning Model, which is a multi-regional, dynamic, determi nistic linear programming model of the U.S. electric power sector that provides forecasts of least-cost capacity expansion, elec tricity dispatch, and emission control strategies for meeting energy demand and environmenta l, transmission, dispatch, and reliability constraints. 3. For natural gas, used PM, CO, NO X , and SO 2 emission factors from AP-42 chapter on natural gas combustion.

Assumed 1,020 Btu/ft 3 of natural gas in estimating PM, CO, NO X , and SO 2 secondary emissions. Also assumed that 100% of PM is PM 2.5 , based on statement in AP-42 that PM from natural gas combustion is estimated to be less than 1 micron in size. 4. For solid fuel, used PM and SO 2 emission limits for solid fuel-fired boilers from 2006 CFR edition of NSPS for

electric utility plants (40 CFR pa rt 60, subpart Da) and used NO X and CO emission factors from AP-42 chapter on coal combustion (bituminous/subbituminous coal). The NO X emission factor was based on average of NO X emission factors for PC dry-bottom wall-fired NSPS boilers burning bituminous (12 lb/ton) and subbituminous (7.4 lb/ton) coal. Assumed 13,000 Btu/ lb of coal in estimating NO X and CO secondary emissions. According to AP-42, the percentage of PM that is PM 2.5 for dry-bottom coal-fired boilers is 29% with ESP, 53% with FF, and 6% if uncontrolled. Assumed 84% of utility boilers controlled with ESP and 14% with FF, leaving 2% uncontrolled, based on information from EPA document on control of emissions from coal-fired utility boilers.

### Appendix E
Installation Model Impacts

### E-2 Table E-1. Model Impacts of Installing New DIFF

Parameters SCD LCD Control efficiency HF 99.5% 99.5% HCl 83.3% 83.3% Cl 2 89.3% 89.3% Non-Hg HAP metals 94% 94% PM 94% 94% SO 2 48.7% 48.7% Parameters Fan hp 150 190 Total hp for other motors 30 30 Waste, lb/hr 102.1 154.9 Emissions reductions, tpy HF 18.13 38.85 HCl 2.06 4.42 Cl 2 0.09 0.20 Non-Hg HAP metals 0.1026 0.220 PM 9.33 19.99 SO 2 48.26 103.42 Energy impacts, MMBtu/yr 11,544 14,109 Secondary air impacts, tpy Particulate matter 0.09 0.10 PM 2.5 0.029 0.035 Carbon monoxide 0.14 0.18 Nitrogen oxides 1.14 1.39 Sulfur dioxide 3.33 4.06 Solid waste impacts, tpy 447 678

### E-3 Table E-2. Model Impacts of Installing Fabric Filter
Parameters SCD LCD Control efficiency Non-Hg HAP metals 94% 94% PM 94% 94% Parameters Fan hp 150 190 Total hp for other motors 30 30 Waste, lb/hr 2.1 4.6 Emissions reductions, tpy Non-Hg HAP metals 0.10 0.22 PM 9.33 19.99 Energy impacts, MMBtu/yr 11,544 14,109 Secondary air impacts, tpy Particulate matter 0.09 0.10 PM 2.5 0.029 0.035 Carbon monoxide 0.14 0.18 Nitrogen oxides 1.14 1.39 Sulfur dioxide 3.33 4.06 Solid waste impacts, tpy 9.33 19.99

### E-4 Table E-3. Model Impacts of Installing New DLA
Parameters SCD LCD Control efficiency HF 95% 95% HCl 30% 30% Cl 2 42% 42% Non-Hg HAP metals 20% 20% PM 20% 20% SO 2 12% 12% Parameters Fan hp 60 90 Total hp for other motors 10 40 Waste, lb/hr 83.7 117.2 Emissions reductions, tpy HF 17.61 37.73 HCl 0.74 1.59 Cl 2 0.04 0.10 Non-Hg HAP metals 0.025 0.053 PM 2.27 4.86 SO 2 11.88 25.47 Energy impacts, MMBtu/yr 4,489 8,337 Secondary air impacts, tpy Particulate matter 0.03 0.06 PM 2.5 0.011 0.021 Carbon monoxide 0.06 0.10 Nitrogen oxides 0.44 0.82 Sulfur dioxide 1.29 2.40 Solid waste impacts, tpy 367 513

### Appendix F
Retrofit/Replacement Model Impacts

### F-2 Table F-1. Model Impacts of Retrofitting ACI System to Existing Control Device

Parameters MACT Floor Beyond the Floor SCD LCD SCD LCD Parameters Injection blower fan power, hp 5.2 8.7 5.2 8.7 Carbon feed rate, lb/hr 2.8 4.6 4.2 7.0 Mercury emissions reduction, tpy 0.00163 0.00349 0.00182 0.00390 Energy impacts, MMBtu/yr 371 621 371 621 Secondary air impacts, tpy Particulate matter 0.0027 0.0046 0.0027 0.0046 PM 2.5 0.0009 0.0015 0.0009 0.0015 Carbon monoxide 0.0046 0.0077 0.0046 0.0077 Nitrogen oxides 0.0367 0.0614 0.0367 0.0614 Sulfur dioxide 0.1069 0.1789 0.1069 0.1789 Solid waste impacts, tpy 12.26 20.15 18.40 30.66

### F-3 Table F-2. Model Impacts of Replacing Dry Limestone Adsorber with New DIFF

Parameters SCD LCD DLA DIFF Increm. DLA DIFF Increm. Control efficiency HF 95% 99.5% 95% 99.5% HCl 30% 83.3% 30% 83.3% Cl 2 42% 89.3% 42% 89.3% Non-Hg HAP metals 20% 94% 20% 94% PM 20% 94% 20% 94% SO 2 12% 48.7% 12% 48.7% Parameters Fan hp 60 150 90 190 Total hp for other motors 10 30 40 30 Waste, lb/hr 83.8 102.1 117.3 154.9 Emissions reductions, tpy HF 17.31 18.13 0.82 37.09 38.85 1.76 HCl 0.74 2.06 1.32 1.59 4.42 2.83 Cl 2 0.04 0.0947 0.05 0.10 0.203 0.11 Non-Hg HAP metals 0.022 0.1026 0.081 0.047 0.220 0.173 PM 1.99 9.33 7.35 4.25 19.99 15.74 SO 2 11.88 48.26 36.38 25.47 103.42 77.96 Energy impacts, MMBtu/yr 4,489 11,544 7,055 8,337 14,109 5,772 Secondary air impacts, tpy Particulate matter 0.03 0.09 0.05 0.06 0.10 0.04 PM 2.5 0.011 0.029 0.017 0.021 0.035 0.014 Carbon monoxide 0.06 0.14 0.09 0.10 0.18 0.07 Nitrogen oxides 0.44 1.14 0.70 0.82 1.39 0.57 Sulfur dioxide 1.29 3.33 2.03 2.40 4.06 1.66 Solid waste impacts, tpy 367 447 80.10 514 678 165

### F-4 Table F-3. Model Impacts of Replacing Spray Dryer/ESP with New DIFF

Parameters SCD LCD SD/ESP 1 DIFF Increm. 2 SD/ESP 1 DIFF Increm. 2 Parameters Fan hp 125 250 Total hp for other motors 200 400 Water usage, gpd 6.25 12.5 Emissions reductions, tpy HF -2.83 18.13 20.96 -3.06 38.85 41.91 HCl -2.65 2.06 4.72 -4.95 4.42 9.38 Cl 2 -0.55 0.09 0.64 -1.08 0.20 1.28 Non-Hg HAP metals 0.103 0.103 0.00 0.220 0.220 0.00 PM 9.33 9.33 0.00 19.99 19.99 0.00 SO 2 47.54 48.26 0.73 101.86 103.42 1.56 Energy impacts, MMBtu/yr 20,843 11,544 -9,299 41,686 14,109 -27,577 Secondary air impacts, tpy Particulate matter 0.15 0.09 -0.07 0.31 0.10 -0.20 PM 2.5 0.052 0.029 -0.023 0.103 0.035 -0.068 Carbon monoxide 0.26 0.14 -0.12 0.52 0.18 -0.34 Nitrogen oxides 2.06 1.14 -0.92 4.12 1.39 -2.73 Sulfur dioxide 6.00 3.33 -2.68 12.01 4.06 -7.94 Solid waste impacts, tpy 438 447 8.66 664 678 14.43 Wastewater impacts, gpy 2,281 0 -2,281 4,563 0 -4,563

1 The negative emission reduction estimates for the SD/ESP are a result of the small dataset for kilns with this type of

control and the lack of control e fficiency information for SD/ESP.

2 A negative increase in impacts would be equivalent to a reduction in impacts.

### F-5 Table F-4. Model Impacts of Replacing Existing DIFF with New, More Efficient DIFF

Parameters SCD LCD Existing

DIFF New DIFF Increm. Existing DIFF New DIFF Increm. Control efficiency HF 98% 99.5% 98% 99.5% HCl 82% 83.3% 82% 83.3% Cl 2 88% 89.3% 88% 89.3% Non-Hg HAP metals 72% 94% 72% 94% PM 72% 94% 72% 94% SO 2 48% 48.7% 48% 48.7% Parameters Fan hp 150 150 190 190 Total hp for other motors 30 30 30 30 Waste, lb/hr 100.1 102.1 151.6 154.9 Emissions reductions, tpy HF 17.86 18.13 0.27 38.26 38.85 0.59 HCl 2.03 2.06 0.03 4.36 4.42 0.07 Cl 2 0.09 0.09 0.00 0.20 0.20 0.00 Non-Hg HAP metals 0.079 0.103 0.024 0.168 0.220 0.051 PM 7.15 9.33 2.18 15.31 19.99 4.68 SO 2 47.54 48.26 0.73 101.86 103.42 1.56 Energy impacts, MMBtu/yr 11,544 11,544 0 14,109 14,109 0 Secondary air impacts, tpy Particulate matter 0.09 0.09 0 0.10 0.10 0 PM 2.5 0.029 0.029 0 0.035 0.035 0 Carbon monoxide 0.14 0.14 0 0.18 0.18 0 Nitrogen oxides 1.14 1.14 0 1.39 1.39 0 Sulfur dioxide 3.33 3.33 0 4.06 4.06 0 Solid waste impacts, tpy 438 447 8.66 664 678 14.43