### From: Telander, Jeff <Telander.Jeff@epa.gov> Sent: Monday, October 06, 2014 4:04 PM To: Frey, Nathan J. Cc: Barnett, Keith Subject: Your request re Brick

Nathan,
As you requested, the attached file describes the methodology and assumptions used to estimate the model costs and impacts of BSCP air pollution control devices. We are currently drafting the document which discusses the engineering costs and expect to have that draft available to send to you in the next couple of days.

Jeff

Jeff Telander Sector Policies and Programs Division Office of Air Quality Planning and Standards (D243-02) RTP, NC 27711 919 - 541-5427 919 - 541-5450 (FAX)
Overnight mail address: US EPA Mail Code D243-02 109 TW Alexander Drive RTP, NC 27709

<< BSCP_Model_Costs_Memo_7-9-14.docx >>

### Date: July 9, 2014

To: Jeff Telander, EPA/OAQPS/SPPD

From: Thomas Holloway

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

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, the EPA is proposing new standards for BSCP manufacturing, incl uding standards for HF, HCl, chlorine (Cl 2 

### ), mercury (Hg), and non-Hg HAP metals (o r PM surrogate). The purpose of this memorandum is to present the methodology and assu mptions used in estimating the model costs and environmental and energy impacts for the co ntrol technologies used to meet these new standards.

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 NESHAP, which are based on a kiln capac ity threshold of 10 tons per hour (tph). The model costs and impacts were estimated based on a variety of model pa rameters—(1) general parameters such as production rate, operating hours , gas flow rate, electric ity and waste disposal unit costs, labor wage rates, and uncontrolled em issions; and (2) control-sp ecific parameters such as control device horsepower (hp) requirements, sorbent requirements, and sorbent unit cost. This section discusses the basis for the gene ral model parameters, wh ich are presented in Appendix A at the end of this memorandum.

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

### 2 The model production rates (in tph) and operati ng hours (in hours per year [hr/yr]) were based on data from the BSCP inventory (Sroka, 2014). The BSCP inventory is a combination of (1) industry responses to the 2008 BSCP section 114 survey; (2) res ponses to a survey similar to the 2008 BSCP section 114 survey that was admini stered by the Brick Industry Association; and (3) industry data from the 2003 BSCP database (from the original 2003 BSCP NESHAP) for plants not included in the 2008 surveys. The average kiln pr oduction rate (7.0 tph) and operating hours (7,300 hr/yr) for the small model were calc ulated from those tunn el kilns with a kiln capacity less than 10 tph. The average kiln production rate (15 tph) and operating hours (7,800 hr/yr) for the large model we re calculated from those tunnel ki lns 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 the kilns are actually limited. The model kiln operating hours were based on a mix of actual kiln oper ating hours from industry responses to the 2008 BSCP survey (Sroka, 2014) and facility operati ng hours from the 2003 BSCP database for those facilities not included in the 2008 su rvey. Since the kiln is the center of the production process at the BSCP facility, it is reasona ble to assume facility operating hours would be the same as kiln operating hours.
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 ($0.073/kilowatt-hour [kWh]) a nd waste disposal ($40/ton waste) were based on the average of those un it costs from the 2008 BSCP survey responses (Sroka, 2014). The operator wage rate ($22.67/hr) was based on mean hourly wage data from the May 2011 Bureau of Labor Statistics fo r NAICS 327100 (Clay Product and Refractory Manufacturing) for an Industrial Engineering Technician (BLS, 2011). 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 (Sroka, 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. The model cost tables for new a nd retrofit control devices are presented in Appendices B and C, respectively. (Note: The annual operating costs for replacement control devices presented in this memorandum are a c onservative estimate. The operating costs for control devices to be replaced have not been subtracted out.)
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

### 4 kilns. This type of control system is already in use in the BSCP industry (Sroka, 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 standards.
The DIFF costs were estimated using the co st algorithms from the original BSCP rulemaking (Shrager, 2003), which were genera ted following guidelines in the OAQPS Control Cost Manual (EPA, 2002). The algorithms we re updated to include more recent model parameters, including the genera l parameters discussed previous ly 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 ($0.24/1,000 ft 3 

### )

 Bag capital recovery factor (0.244, base d on 5-yr bag life and 7% interest)
With two exceptions, the values of the model DIFF parameters were determined based on averages of industry responses to the 2008 BSCP survey (Sroka, 2014). The DIFF control efficiencies and stoichiometric ratios of hydrated lime were dete rmined 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 (Sroka, 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).
The model DIFF capital costs were estimated by taking DIFF capital cost data from industry responses to the 2008 BSCP survey (Sr oka, 2014), escalating the costs to 2011 dollars using the Chemical Engineering Plant Cost Inde x (CEPCI) (CE, 2011), sca ling the costs to the large and small model sizes using the six-tenths cost rule (see Equation 3 below), taking the

### 5 average of the scaled costs for each model size, and rounding the result s 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 $0.073/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 $0.24/1,000 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 $40/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, minus the cost of capital recovery for replacement bags and bag replacement labor)

### 6 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 (Sroka, 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 indicat ed 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-toair heat exchanger to reduce the gas temperature to a level wher e conventional fabrics could be used safely (Childress, 2013b).

### 7 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 believe fabric filters can potentially be an effective control option, if acid gas levels (especially HF ) are already inherently low or effectively controlled and exhaus t gas temperatures are not too hi gh. 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 fo r waste disposal that excludes any acid gas control.
Activated carbon injectio n (ACI). Injecting activ ated 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, industr ial boilers, 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 contro l performance achieved in these other industries, we be lieved it prudent to expl ore this control tech nology 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 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

### 8 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 $0.073/kWh)

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

 Waste disposal (estimated based on waste generated and $40/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)
Dry limestone adsorber (DLA). Instead of inst alling control equipment such as a DIFF to meet the new BSCP standards, some BSCP fac ilities may choose to install less expensive DLA systems on one or more of their uncontrolled tunn el kilns to reduce facility emissions below the threshold for major sources of HAP—10 tons per y ear (tpy) or more of any single HAP or 25 tpy or more of any combination of HAP. By obt aining a federally enforceable limit reducing emissions below major source thresholds, those BSCP facilities would become synthetic area sources and would not be subject to the ma jor source BSCP NESHAP. Only those BSCP facilities that would be impacted under the new BS CP standards and that could reduce their HAP emissions below the major source threshold using a DLA system are expected to install such controls on their uncon trolled 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 (Sroka, 2014). The DLA costs were estimated using the cost algorithms from the original BSCP ru lemaking (Shrager, 2003), which were generated following guidelines in the OAQPS Control Co st Manual (EPA, 2002). The algorithms were

### 9 updated to include more recent 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 ($40/ton)
The model DLA control efficiencies for HF, HCl, and other pollutants were estimated based on averages of data from BSCP stack te sts (Raymond, 2014), while the values of the other model DLA parameters were determined based on averages of industry responses to the 2008 BSCP survey (Sroka, 2014).
The model DLA capital costs were estimated by taking DLA capital cost data from industry responses to the 2008 BSCP survey (Sr oka, 2014), escalating the costs to 2011 dollars using the CEPCI (CE, 2011), scaling the costs to the large and small mo del sizes using the sixtenths cost rule (see Equation 3), taking the aver age of the scaled costs for each model size, and rounding the results to th ree significant figures.

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 $0.073/kWh)

 Limestone (estimated based on limestone rate and $40/ton limestone unit cost)

 Waste disposal (estimated based on waste generated and $40/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.

### 10 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 $613,297 $797,096 Install new fabric filter Total capital investment $1,200,000 $1,500,000 Total annual cost $437,845 $526,006 Replace with DIFF Total capital investment $2,800,000 $3,820,000 Total annual cost $720,811 $943,585 Retrofit fabric filter Total capital investment $1,680,000 $2,100,000 Total annual cost $502,354 $606,642 Retrofit ACI system MACT floor Total capital investment $102,224 $146,697 Total annual cost $70,589 $96,482 Beyond the floor Total capital investment $102,224 $146,697 Total annual cost $79,480 $112,768 Install DLA Total capital investment $1,060,000 $1,440,000 Total annual cost $306,593 $405,045



### 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).

### 11 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.

### 12 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)

 Retrofit of fabric filter after 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)

 Retrofit of ACI system 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/E SP 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.

### 13 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 15.1 34.6 Hydrogen chloride 1.72 3.94 Chlorine 0.0789 0.181 HAP metals 0.0855 0.196 Particulate matter 7.78 17.8 Sulfur dioxide 40.2 92.1 Install/retrofit fabric filter HAP metals 0.0855 0.196 Particulate matter 7.78 17.8 Install new DLA Hydrogen fluoride 14.4 33.0 Hydrogen chloride 0.620 1.42 Chlorine 0.0371 0.0850 HAP metals 0.0182 0.0417 Particulate matter 1.65 3.79 Sulfur dioxide 9.90 22.7 Retrofit ACI system MACT floor Mercury 0.00136 0.00311 Beyond the floor Mercury 0.00152 0.00347

### 14 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 0.683 1.56 Hydrogen chloride 1.10 2.52 Chlorine 0.0418 0.0958 HAP metals 0.0673 0.154 Particulate matter 6.12 14.0 Sulfur dioxide 30.3 69.4 Replace spray dryer/ESP with new DIFF Hydrogen fluoride 17.5 37.3 Hydrogen chloride 3.93 8.35 Chlorine 0.534 1.14 HAP metals 0.00 0.00 Particulate matter 0.00 0.00 Sulfur dioxide 0.606 1.39 Replace existing DIFF with new, more efficient DIFF Hydrogen fluoride 0.228 0.521 Hydrogen chloride 0.0259 0.0594 Chlorine 0.00119 0.00272 HAP metals 0.0200 0.0458 Particulate matter 1.82 4.17 Sulfur dioxide 0.606 1.39



### 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 9,620 12,563 Solid waste impacts, tpy 372 604 Install/retrofit fabric filter Energy impacts, MMBtu/yr 9,620 12,563 Solid waste impacts, tpy 7.78 17.8 Install new DLA Energy impacts, MMBtu/yr 3,741 7,424 Solid waste impacts, tpy 306 457 Retrofit ACI system MACT floor Energy impacts, MMBtu/yr 309 553 Solid waste impacts, tpy 10.2 17.9 Beyond the floor Energy impacts, MMBtu/yr 309 553 Solid waste impacts, tpy 15.3 27.3

### 15 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 5,879 5,139 Solid waste impacts, tpy 66.8 147 Replace spray dryer/ESP with new DIFF Energy impacts, MMBtu/yr -7,749 -24,555 Solid waste impacts, tpy 7.22 12.9 Wastewater impacts, gpy -1,901 -4,063 Replace existing DIFF with new, more efficient DIFF Energy impacts, MMBtu/yr 0 0 Solid waste impacts, tpy 7.22 12.9

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 0.0710 0.0927 PM 2.5 0.0238 0.0311 Carbon monoxide 0.120 0.156 Nitrogen oxides 0.951 1.24 Sulfur dioxide 2.77 3.62 Install/retrofit fabric filter Particulate matter 0.0710 0.0927 PM 2.5 0.0238 0.0311 Carbon monoxide 0.120 0.156 Nitrogen oxides 0.951 1.24 Sulfur dioxide 2.77 3.62 Install new DLA Particulate matter 0.0276 0.0548 PM 2.5 0.00925 0.0184 Carbon monoxide 0.0465 0.0923 Nitrogen oxides 0.370 0.734 Sulfur dioxide 1.08 2.14 Retrofit ACI system (MACT floor/beyond the floor) Particulate matter 0.00228 0.00408 PM 2.5 0.000765 0.00137 Carbon monoxide 0.00385 0.00688 Nitrogen oxides 0.0306 0.0547 Sulfur dioxide 0.0891 0.159

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

### 16 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 0.0434 0.0379 PM 2.5 0.0145 0.0127 Carbon monoxide 0.0731 0.0639 Nitrogen oxides 0.581 0.508 Sulfur dioxide 1.69 1.48 Replace spray dryer/ESP with new DIFF Particulate matter -0.0572 -0.181 PM 2.5 -0.0192 -0.0607 Carbon monoxide -0.0964 -0.305 Nitrogen oxides -0.766 -2.43 Sulfur dioxide -2.23 -7.07 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
BLS (U.S. Department of Labor, Bu reau of Labor Statistics). 2011. 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.
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 Hollo way, RTI International. April 18, 2013.
Childress, J. 2013b. “RE: From McGill AirClean Web Site.” E-mail from Jerry Childress, McGill AirClean LLC, to Thomas Hollo way, RTI International. June 27, 2013.
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.
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. September 1998.

### 17 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/45 2/B-02-001. January 2002.
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 Re sponse, Washington, DC. September 2005.
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.
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.
Holloway, T. 2013a. Telephone Contact Summary: Jeff Thompson, Cabot Norit Activated Carbon . Contacted by Thomas Holloway, RTI International. May 16, 2013.
Holloway, T. 2013b. “RE: From McGill AirClean Web Site.” E-mail from Thomas Holloway, RTI International, to Jerry Childre ss, McGill AirClean LLC. June 26, 2013.
Holloway, T. 2013c. Telephone Contact Summary: Chris Poli zzi, W.L. Gore & Associates, Inc. Contacted by Thomas Holloway, RTI International. July 16, 2013.
Raymond, G. 2014. Test Data Used in BSCP Proposed Rule . Memorandum from Gabrielle Raymond, RTI International, to Jeff Te lander, EPA/OAQPS/SPPD. Date TBD.
Shrager, B. 2003. Final Rule: Costs for Air Poll ution Control Devices on Kilns . Memorandum from Brian Shrager, Research Triangle Inst itute, to Mary Johnson, U.S. Environmental Protection Agency. February 25, 2003.
Sroka, K. 2014. Updated BSCP Inventory Database and Documentation . Memorandum from Kristin Sroka, RTI International, to Je ff Telander, EPA/OAQ PS/SPPD. Date TBD.
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.

### 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 7,300 7,800 1 Exhaust flow, acfm 23,100 38,700 2 Unit costs Electricity cost, $/kwh 0.073 0.073 1 Waste disposal cost, $/ton 40 40 1 Operator wage rate, $/hr 22.67 22.67 3 Maintenance wage rate, $/hr 24.94 24.94 4 Capital recovery factor--system 0.0944 0.0944 5 Molecular weights HF 20 20 HCl 36.5 36.5 SO 2 64 64 CaF 2 78 78 6 CaCl 2 111 111 6 CaSO 3 120 120 6 Ca(OH) 2 74 74 7 Uncontrolled emissions, lb/ton HF 0.594 0.594 2 HCl 0.081 0.081 2 Cl 2 0.00346 0.00346 2 Non-Hg HAP Metals 0.00356 0.00356 8 PM 0.324 0.324 2 SO 2 3.23 3.23 2 Uncontrolled emissions, lb/hr HF 4.16 8.91 9 HCl 0.566 1.21 9 Cl 2 0.0242 0.0519 9 Non-Hg HAP Metals 0.0249 0.0534 9 PM 2.27 4.86 9 SO 2 22.6 48.5 9 1. Average from ICR responses. 2. Average from test data. 3. 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 /current/oessrci.htm . Wage rates from Bureau of Labor Statistics were used because they are more conservative than those provided by ICR respondents. 4. 10 percent higher than operator rate. 5. Based on equipment life of 20 years and 7 percent interest. 6. Reaction product; CaF 2 = calcium fluoride; CaCl 2 = calcium chloride; CaSO 3 = calcium sulfite. 7. Hydrated lime. 8. Assume 1.1 percent of PM. 9. 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 0.24 0.24 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 51,716 55,258 Supervisory labor 7,757 8,289 15 Maintenance labor 28,444 30,392 Maintenance materials 28,444 30,392 16 Electricity 71,462 93,325 17 Lime 53,348 82,337 Compressed air 2,185 3,912 Annualized replacement bags 13,505 22,625 Annualized bag replacement labor 3,320 5,563 18 Cage replacement 0 0 19

### B-3 Parameters SCD LCD Footnotes Waste disposal 14,900 24,162 Overhead 69,817 74,598 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 613,297 797,096 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 ICR 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. Pollution Prevention (P2) Pays, NC Division of Pollution Prevention and En vironmental Assistance. Determine the

Cost of Compressed Air for Your Plant. Energy Tips - Compressed Air, Compressed Air Tip Sheet #1. August 2004. Web site: http://www.p2pays.org/ref/40/39536.pdf

. 13. Based on equipment life of 5 years and 7 percent interest. 14. Average of costs from ICR res ponses 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 0.24 0.24 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 51,716 55,258 Supervisory labor 7,757 8,289 11 Maintenance labor 28,444 30,392 Maintenance materials 28,444 30,392 12 Electricity 71,462 93,325 13 Compressed air 2,185 3,912 Annualized replacement bags 13,505 22,625 Annualized bag replacement labor 3,320 5,563 14 Cage replacement 0 0 15 Waste disposal 311 712 Overhead 69,817 74,598 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 437,845 526,006
1. Assume same as PM. 2. Average from test data with better efficiency than baseline. 3. Average from ICR responses. 4. Assume 2 times maintenance labor (EPA, 2002).

### B-5 5. Assume none. 6. Particulate matter. 7. Pollution Prevention (P2) Pays, NC Division of Polluti on Prevention and Environmental Assistance. Determine the

Cost of Compressed Air for Your Plant. Energy Tips - Compressed Air, Compressed Air Tip Sheet #1. August 2004. Web site: http://www.p2pays.org/ref/40/39536.pdf

. 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 ICR respons es scaled using 6/10 rule (based on acf m), 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 13.1 28.0 5 Reacted limestone, lb/hr 14.4 30.8 Particulate matter, lb/hr 0.1 0.1 Waste, lb/hr 83.8 117.3 6 Cost factors Limestone, $/ton 40 40 3 Capital costs Total capital investment 1,060,000 1,440,000 7 Annual costs Operating labor 31,030 33,155 Supervisory labor 4,654 4,973 8 Maintenance labor 17,066 18,235 Maintenance materials 17,066 18,235 9 Electricity 27,791 55,146 10 Limestone 12,410 18,720 Waste disposal 12,230 18,295 11 Overhead 41,890 44,759 12 Administrative charges 21,200 28,800 13 Property taxes 10,600 14,400 14 Insurance 10,600 14,400 14 Capital recovery 100,057 135,926 Total annual cost, $/yr 306,593 405,045 1. Average from test data. 2. Assume same as PM. 3. Average from ICR 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 of costs from ICR responses scaled using 6/ 10 rule (based on acfm), escalated to 2011 dollars, and

rounded.

### B-7 8. 15 percent of operator labor. 9. 100 percent of maintenance labor. 10. Based on conversion fa ctor of 0.745 kW/hp. 11. Some facilities have minimal waste disposal costs. 12. 60 percent of labor and maintenance materials. 13. 2 percent of TCI. 14. 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 0.24 0.24 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 51,716 55,258 Supervisory labor 7,757 8,289 16 Maintenance labor 28,444 30,392 Maintenance materials 28,444 30,392 17 Electricity 71,462 93,325 18 Lime 53,348 82,337 Compressed air 2,185 3,912 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 14,900 24,162 Overhead 69,817 74,598 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 720,811 943,585 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 ICR 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. Pollution Prevention (P2) Pays, NC Division of Pollution Prevention and En vironmental Assistance. Determine the

Cost of Compressed Air for Your Plant. Energy Tips - Compressed Air, Compressed Air Tip Sheet #1. August 2004. Web site: http://www.p2pays.org/ref/40/39536.pdf

. 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 ICR res ponses 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-4 Table C-2. Model Costs to Retrofit Fabric Filter to Existing Control Device
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 0.24 0.24 7 Capital recovery factor--bags 0.244 0.244 8 Cost of dry injection system 800,907 1,230,278 9 Retrofit factor 1.4 1.4 10 Capital costs Total capital investment 1,680,000 2,100,000 11 Annual costs Operating labor 51,716 55,258 Supervisory labor 7,757 8,289 12 Maintenance labor 28,444 30,392 Maintenance materials 28,444 30,392 13 Electricity 71,462 93,325 14 Compressed air 2,185 3,912 Annualized replacement bags 13,505 22,625 Annualized bag replacement labor 3,320 5,563 15 Cage replacement 0 0 16 Waste disposal 311 712 Overhead 69,817 74,598 17 Administrative charges 33,600 42,000 18 Property taxes 16,800 21,000 19 Insurance 16,800 21,000 19 Capital recovery 158,193 197,576 Total annual cost, $/yr 502,354 606,642
1. Assume same as PM. 2. Average from test data with better efficiency than baseline. 3. Average from ICR responses.

### C-5 4. Assume 2 times maintenance labor (EPA, 2002). 5. Assume none. 6. Particulate matter. 7. Pollution Prevention (P2) Pays, NC Division of Polluti on Prevention and Environmental Assistance. Determine the

Cost of Compressed Air for Your Plant. Energy Tips - Compressed Air, Compressed Air Tip Sheet #1. August 2004. Web site: http://www.p2pays.org/ref/40/39536.pdf

. 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 HMIWI rule. 10. Average for various control devices (EPA, 2002). 11. Average of costs from ICR respons es scaled using 6/10 rule (based on acf m), subtracted cost of dry injection

system, escalated to 2011 dollars, multiplied by retrofit cost factor, and rounded. 12. 15 percent of operator labor. 13. 100 percent of maintenance labor. 14. Based on conversion fa ctor of 0.745 kW/hp. 15. Performed by maintenance personnel. 16. Maybe no need to replace. 17. 60 percent of labor and maintenance materials. 18. 2 percent of TCI. 19. 1 percent of TCI.C-6Table C-3. 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-7ParametersMACT 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 $6,895 $7,368 $6,895 $7,368 2,24Supervisory labor $1,034 $1,105 $1,034 $1,105 2,25Maintenance labor $11,378 $12,157 $11,378 $12,157 2,26Maintenance materials $2,690 $3,860 $2,690 $3,860 2,27Electricity cost $2,298 $4,108 $2,298 $4,108 2,28Carbon cost $17,374 $30,498 $26,061 $46,410 2,29Solid waste disposal cost $409 $718 $613 $1,092 2,30Overhead $13,198 $14,694 $13,198 $14,694 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 $70,589 $96,482 $79,480 $112,768 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 $0.85/lb.6. Escalating costs from 2004 (HWC) to 2011 (BSCP) using the following factors: (HWC escalation factor, 1.1319 x 1.064) x (BSCPescalation factor, 1.4805).7. Chemical Engineering Plant Cost Index.8. Equal to = [i x (1 + i)n] / [(1 + i)n- 1], where i = 7 percent interest and n = 15-year equipment life.9. Equal to 90,000 x (exhaust flow/150,000)0.7.10. Equal to 0.03 x TEC.11. Equal to 0.05 x TEC.C-812. Equal to TEC + (sales tax) + (freight).13. Equal to EF x (purchased equipment with tax and freight).14. Equal to RF x (purchased equipment with escalation).15. Equal to 0.3 x PEC.16. Equal to PEC + IC.17. Equal to 0.2 x PEC.18. Equal to 0.1 x PEC.19. Equal to 0.01 x PEC.20. Equal to 0.02 x PEC.21. Equal to 0.06 x PEC.22. Equal to sum of indirect costs.23. Equal to TDC + TIC.24. Equal to (1 hr/d) x operating hr/yr/ (24 hr/d) x operator wage rate ($/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 15.1 34.6 HCl 1.72 3.94 Cl 2 0.0789 0.181 Non-Hg HAP metals 0.0855 0.196 PM 7.78 17.8 SO 2 40.2 92.1 Energy impacts, MMBtu/yr 9,620 12,563 Secondary air impacts, tpy Particulate matter 0.0710 0.0927 PM 2.5 0.0238 0.0311 Carbon monoxide 0.120 0.156 Nitrogen oxides 0.951 1.24 Sulfur dioxide 2.77 3.62 Solid waste impacts, tpy 372 604

### E-3 Table E-2. Model Impacts of Installing/Retrofitting 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 0.0855 0.196 PM 7.78 17.8 Energy impacts, MMBtu/yr 9,620 12,563 Secondary air impacts, tpy Particulate matter 0.0710 0.0927 PM 2.5 0.0238 0.0311 Carbon monoxide 0.120 0.156 Nitrogen oxides 0.951 1.24 Sulfur dioxide 2.77 3.62 Solid waste impacts, tpy 7.78 17.8

### 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 83.8 117.3 Emissions reductions, tpy HF 14.4 33.0 HCl 0.620 1.42 Cl 2 0.0371 0.0850 Non-Hg HAP metals 0.0182 0.0417 PM 1.65 3.79 SO 2 9.90 22.7 Energy impacts, MMBtu/yr 3,741 7,424 Secondary air impacts, tpy Particulate matter 0.0276 0.0548 PM 2.5 0.00925 0.0184 Carbon monoxide 0.0465 0.0923 Nitrogen oxides 0.370 0.734 Sulfur dioxide 1.08 2.14 Solid waste impacts, tpy 306 457

### 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 0.00136 0.00311 0.00152 0.00347 Energy impacts, MMBtu/yr 309 553 309 553 Secondary air impacts, tpy Particulate matter 0.00228 0.00408 0.00228 0.00408 PM 2.5 0.000765 0.00137 0.000765 0.00137 Carbon monoxide 0.00385 0.00688 0.00385 0.00688 Nitrogen oxides 0.0306 0.0547 0.0306 0.0547 Sulfur dioxide 0.0891 0.159 0.0891 0.159 Solid waste impacts, tpy 10.2 17.9 15.3 27.3

### 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 14.4 15.1 0.683 33.0 34.6 1.56 HCl 0.620 1.72 1.10 1.42 3.94 2.52 Cl 2 0.0371 0.0789 0.0418 0.0850 0.181 0.0958 Non-Hg HAP metals 0.0182 0.0855 0.0673 0.0417 0.196 0.154 PM 1.65 7.78 6.12 3.79 17.8 14.0 SO 2 9.90 40.2 30.3 22.7 92.1 69.4 Energy impacts, MMBtu/yr 3,741 9,620 5,879 7,424 12,563 5,139 Secondary air impacts, tpy Particulate matter 0.0276 0.0710 0.0434 0.0548 0.0927 0.0379 PM 2.5 0.00925 0.0238 0.0145 0.0184 0.0311 0.0127 Carbon monoxide 0.0465 0.120 0.0731 0.0923 0.156 0.0639 Nitrogen oxides 0.370 0.951 0.581 0.734 1.242 0.508 Sulfur dioxide 1.08 2.77 1.69 2.14 3.62 1.48 Solid waste impacts, tpy 306 372 66.8 457 604 147

### 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 -2.36 15.1 17.5 -2.72 34.6 37.3 HCl -2.21 1.72 3.93 -4.41 3.94 8.35 Cl 2 -0.455 0.0789 0.534 -0.958 0.181 1.14 Non-Hg HAP metals 0.0855 0.0855 0.00 0.196 0.196 0.00 PM 7.78 7.78 0.00 17.8 17.8 0.00 SO 2 39.6 40.2 0.606 90.7 92.1 1.39 Energy impacts, MMBtu/yr 17,369 9,620 -7,749 37,118 12,563 -24,555 Secondary air impacts, tpy Particulate matter 0.128 0.0710 -0.0572 0.274 0.0927 -0.181 PM 2.5 0.0430 0.0238 -0.0192 0.0918 0.0311 -0.0607 Carbon monoxide 0.216 0.120 -0.0964 0.462 0.156 -0.305 Nitrogen oxides 1.72 0.951 -0.766 3.67 1.242 -2.43 Sulfur dioxide 5.00 2.77 -2.23 10.7 3.62 -7.07 Solid waste impacts, tpy 365 372 7.22 591 604 12.9 Wastewater impacts, gpy 1,901 0 -1,901 4,063 0 -4,063

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 14.9 15.1 0.228 34.0 34.6 0.521 HCl 1.69 1.72 0.0259 3.88 3.94 0.0594 Cl 2 0.0778 0.0789 0.00119 0.178 0.181 0.00272 Non-Hg HAP metals 0.0655 0.0855 0.0200 0.150 0.196 0.0458 PM 5.96 7.78 1.82 13.6 17.8 4.17 SO 2 39.6 40.2 0.606 90.7 92.1 1.39 Energy impacts, MMBtu/yr 9,620 9,620 0 12,563 12,563 0 Secondary air impacts, tpy Particulate matter 0.0710 0.0710 0 0.0927 0.0927 0 PM 2.5 0.0238 0.0238 0 0.0311 0.0311 0 Carbon monoxide 0.120 0.120 0 0.156 0.156 0 Nitrogen oxides 0.951 0.951 0 1.242 1.242 0 Sulfur dioxide 2.77 2.77 0 3.62 3.62 0 Solid waste impacts, tpy 365 372 7.22 591 604 12.9