1 January 2 6 , 2011

To: Bansari Saha , I C F I n t e r n a t i o n a l

From: Jim Staudt , A n d o v e r T e c h n o l o g y P a r t n e r s

Re: DSI and Fabric Filter System Installation Labor Estimate

DSI

A dry sorbent injection system (DSI) has many of the same components as an activated carbon injection (ACI) system. The principal difference is that a DSI system generally injects a higher quantity of materials

. In Engineering and Economic Factors Affecting Installation of Control Technologie s for Multipollutant Strategies ( EPA

- 600/R

- 02/073, October 2002) , the following estimates were developed for installatio n of an ACI system for a 500 MW boiler with a full load activated carbon injection rate of 815 lb/hr.

Labor Element s - ACI Manhours Off site Engineering and On Site Testing 1600 Installation, Except Silo 1200 Erection of Silo 2000 Total 4800 Engineering and Economic Factors Affecting Installation of Control Technologies for Multipollutant Strategies ( EPA

- 600/R

- 02/073, October 2002)

Thus, for a facility that injects at full load 815 lb/hour of activated carbon, the one

- time labor needed for these labor elements totals about 4800 manhours. This does not include the labor associated with manufacturing the various components of the syst em
– steel, piping, blowers,
etc. It also does not include the sales, general, and administrative effort of the company that is supplying and installing the hardware, or some of the costs of general facilities or utilities needed for the ACI system. As a result, this estimate is a conservatively low estimate of the

one

- time jobs created by the installation of an ACI system. Also, this estimate does not account for the recurring jobs created by the need to operate and maintain the ACI system and to supply it with carbon each year. For a DSI system, you would have many of the same cost elements as ACI , however, the material rate would be much higher, resulting in larger equipment. The engineering and testing element would not change dramatically. Although the sizing of an ACI system is largely associated with the gas flowrate, to maintain a prescribed sorbent injection concentration measured in lb/million actual cubic feet of flue gas, the material flowrate for a DSI system is a2 function of the gas flowrat e and the sulfur content of the fuel. This is because testing by Solvay has shown a relationship between HCl capture and SO 2 capture. 1

A cru de method of extrapolating the labor needed for su ch a DSI system from the estimates for an ACI system is to scale the labor elements to the material flow. Certainly, as the flowrates go up, the sizing of the equipment and effort needed to install it will increase. The off

- site engineering and on

- site testing will likely increase somewhat from the larger size equipment
, but not to the degree of the installation labor. If the installa tion labor increases in proportion to the flowrate and the off

- s ite engineering stays roughly the same , for that 500 MW bituminous coal unit injecting 80,000 lb/hr of Trona the labor would be 1600 +(80,000/12,700)*(1200+2000) = 21,760 manhours, or about 43 .5 manhours per MW. This, of course, is a rough estimate, but should be good for a start. Also, in estimating job benefit it should be conservatively low since it does not incorporate the benefit of jobs produced from manufacture of steel, pipe, blowers, valves, controllers, etc., or the sales, general and administrative jobs produced from suppliers. Assuming an NSR of 2.0 for the sorbent injection rate (this is conservatively high), the injection rate of Trona for a 500 MW plant would be roughly 12,700 lb/hr at full load for a boiler firing PRB coal and roughly 80,000 lb/hr of Trona (sodium bicarbonate injection rate would be less) for a boiler firing 1.5% sulfur bituminous coal with a high chlorine content of 0.38% b y weight. The particular bituminous coal example is chosen because it is the most likely type of facility to have the need for DSI under a MACT scenario because PRB coals have very low chlorine content and because boilers using high sulfur bituminous coal s are likely to be scrubbed.

Fabric Filter

To develop a rough estimate the manhours for a fabric filter, I recommend that we estimate the
amounts based upon information on SCR’s in EPA

- 600/R

- 02/073 . My opinion is that a fabric filter, like an SCR
, entails mostly erection of steel without the amount of process equipment (pumps, limestone preparation, etc.) or need for special alloys that are the case for a wet scrubber. An SCR can b e somewhat more complex than a fabric filter and may require less structural steel because of the need for boiler integration that causes the SCR to frequently be installed at elevations

- ; however, that would be addressed by the somewhat lower cost of the fabric filter.

From EPA

- 600/R

- 02/073, t otal labor man

- hours of construction and engineering labor for an SCR are about 365,000 man

- hours for a single 500 MW e unit , or about 730 manhours per MW.
E stimate s developed by the Utility Air Regulatory Group 2

1 Davidson, Heidi, “ Dry Sorbent Injection for Multi

- pollutant Control Case Study”, CIBO IECT VIII, Portland, ME, August 2

– 5, 2010 suggest possibly higher numbers, but nevertheless a wide range of estimates for labor demand due to the wide range of complexity of SCR projects. Fabric filter retro fits will also range in cost depending upon the amount of ductwork that is necessary.

2 Cichanowicz, J.E., Hein, M., Marchetti, J., “Analysis of CAIR Compliance Schedule: A Response to ICAC Estimates,” July 26, 2004.3 CUE Cost was used to estimate the capital cost of SCR and Fabric Filters. For a 500 MW plant, an SCR was estimated to be $153/KW in 2009 dollars escalating with the Chemical Engineering Plant Cost Index . For the same boiler, a fabric filter retrofit was esti mated to be $87/KW, or about 57% of the cost of the SCR. Using the ratio of the capital cost as a gauge of the relative use of labor (both technologies involve a great deal of erected structural steel and steel plate)
, the labor demand for a fabric filter can be estimated to be roughly 416 manhours per MW. This, of course
, is a rough estimate and may be well off for a particular application depending upon the amount of ductwork needed for the fabric filter. In estimating job benefit of a fabric filter installation it should be conservatively low since it does not incorporate the benefit of jobs produced from manufacture of steel, pipe, blowers, valves, controllers, etc., or the sales, general and administrative jobs at the fabric filter suppliers.