­~

­­.
­~

c
Docket
No.
O~~­
2002­
0052
*
Item
NO.
1143­
127
I*

$
n
G
UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
RESEARCH
TRIANGLE
PARK,
NC
2771
1
4*\""
D
%+..

ww
5
%
.4i
PRO&
8
OFFICE
OF
AIR
QUALNY
PLANNING
AND
STANDARDS
MEMORANDUM
SUBJECT:
Cost
Inputs
for
Econ
ime
Industry
NESHAP
'
+

James
Crowder,
Group
Leader
8
bA
Minerals
and
Inorganic
Chemic
s
Group
Ron
Evans,
Group
Leader
Innovative
Strategies
and
Economics
Group
This
memorandum
provides
the
costs
of
air
pollution
controls
(
that
may
be
needed
to
comply
with
emission
limits
being
considered)
and
testing
and
monitoring
requirements
being
considered
for
the
subject
regulation.
These
costs
are
for
the
control
of
HAP
w
and
existing
lime
kilns,
lime
coolers,
and
mat
1
costs
have
been
estimatedxor
kil
for
the
kiln,
cooler,
and
MHO
are
HAP
metals,
using
PM
flect
updated
thinking
on
rule
requirements
based
on
el's
recommendations
and
a
comment
received
fro
Two
EIAs
need
to
be
conducted,
for
the
two
regulatory
options
under
consider
assuming
that
PM
continuous
emission
monitoring
systems
(
CEMS)
will
be
required,
other
option
that
PM
CEMS
will
not
be
required.

Please
find
attached
the
following
items:

es
applicable
to
the
cost
and
economic
analysis.

grading
existing
kilns'
baghouses
(
replace
bags)
sts
for
each
PM
control
option
for
model
kilns
and
cooler:
I
I
I
Upgrading
existing
kilns'
ESP
(
new
ESP
field)
Upgrading
existing
kilns'
wet
scrubbers
(
replace
with
new
venturi
wet
scrubber)
Upgrading
existing
uncontrolled
kilns
with
a
new
baghouse
Ne&
baghouse
for
a
new
kiln
0
I
I
0
MHO
conti­
oi
costs
­

Table
of
testing
and
monitoring
costs
for
kilns
Testing
and
monitoring
costs
for
materials
handling
sources
Table
matching
each
lime
plant's
kiln(
s)
to
model
kilns
RqcledlRecyclable
Prlnted
with
Vegetable
Oil
Based
Ink
on
100%
Recycled
Paper
(
40%
Postconsumer)
General
Notes
for
Cost
and
Economic
Analysis
0
Costs
are
in
1000'
s
of
first
quarter1
997
dollars.
TCI
=
total
capital
investment
DAC
=
direct
annual
cost
IAC
=
indirect
annual
cost
TAC
=
total
annual
cost
=
D
Cost
recovery
based
on
7
perc
Costs
for
kilns
are
provided
on
a
model
basis,
and
only
for
those
models
Since
the
draft
revised
rule
includes
a
provision
for
bubbling
of
PM
emissions
from
the
0
0
0
0
C
+
cost
recovery
0
0
corresponding
actual
kilns
i
kilns
and
coolers,
this
will
allow
some
plants
to
avoid
installation
of
new,
or
upgrading
of
existing,
PM
controls
that
may
have
been
required
without
the
bubbling
provision.
To
account
for
this
lesser
impact,
the
cost
of
cooler
PM
controls
(
which
%
without
the
bubbling
provision)
are
zero.
0
0
MHO
control
costs
are
lump
sum
for
the
whole
plant.
We
assume
70
percent
of
plants
are
major
sources,
but
we
do
not
know
which
plants
are
,
except
the
costs
to
measure
HC1
lete
list
of
all
plants
in
the
U.
S.
0
major.
A
random
assignment
of
major
vs.
area
status
based
on
this
70%
probability
is
recommended.

0
orne
by
every
plant.

0
Extrapolation
of
costs
and
*
In
addition,
if
ofthe
economic
impacts
to
the
entire
industry
needs
to
be
consi
plants
listed
in
Table
7
are
small
businesses,
please
use
the
costs
we
provide
you
(
in
a
separate
memo).

sugar
production;
this
is
reflected
in
the
list
of
plants.

example,
the
percentage
of
existing
kilns
with
a
certain
PM
control
device
needing
an
upgrade
(
i.
e.,
not
meeting
the
emission
limit
and
thus
having
to
incur
the
cost
of
upgrading
their
air
pollution
control)
is
indicated.
We
do
not
know
which
plants
are
meeting
the
emission
limits,
so
these
costs
should
be
assigned
randomly
based
on
the
percentages
indicated.
The
exception
to
this
is
the
small
businesses,
for
which
costs
have
already
been
assigned,
based
on
the
assumption
that
all
are
major
except
1
company.
However,
the
small
businesses
need
to
be
included
when
determining
how
many
kilns
incur
a
cost
based
on
the
aforementioned
percentages.
We
will
provide
you
the
costs
to
small
businesses
in
a
separate
memo.

(
1)
HCl
testing
for
area
source
status
determination
(
incurred
by
every
plant;
depends
on
#
of
kilns
­
see
Table
6)
;,
and
if
the
lime
plant
is
a
major
source,
the
following
costs
also
0
The
NESHAP
will
not
affect
lime
plants
associated
with
pulp/
paper
production
or
beet
Additional
notes
particular
to
a
control
option
are
also
provided
in
the
tables
below.
For
0
0
In
summary,
total
cost
to
a
lime
plant
equals
cost
of:

apply:
3
(
2)
kiln
PM
control
(
depends
on
control
device,
if
meeting
emission
limit
­
see
Tables
1
through
5)
(
3)
MHO
control
(
costs
are
per
plant
­
see
top
of
page
7)
(
4)
kiln
testing
and
monitoring
(
costs
are
per
kiln;
all
kilns
incur
costs
­
see
Table
6)
(
5)
MHO
testing
and
monitoring
(
per
plant
­
see
page
8)

Table
1
:
Upgrading;
Existing;
Kilns
FF
with
New
Bags
Notes:
29
%
of
kilns
with
baghouses
are
not
expected
to
meet
the
PM
emission
limit,
and
thus
would
incur
these
costs.
Reference:
11­
B­
66
*
*

I
4
Table
2.
New
FF
on
Existing
Uncontrolled
Kiln
These
costs
would
apply
also
to
kilns
with
just
cyclones
or
gravel
beds.
All
kilns
that
are
uncontrolled
(
or
with
cyclone
or
gravel
bed)
would
incur
these
costs.
Reference:
11­
B­
70
­
(
1
0
a
9
.
e
c
a
5
Table
3.
Upgrading
Wet
Scrubbers
on
Existing.
Kilns
with
New
Venturi
Scrubber
cost
DAC
IAC
.
TAC
recovery
28
75
11
113
32
88
11
13
1
57
220
16
293
73
312
19
403
33
102
12
146
55
207
15
278
75
326
19
42Q
39
129
13
180
19
36
9
64
6
Table
4.
Additional
Field
for
ESP
Notes:

e
33
%
of
kilns
with
ESPs
are
not
expected
to
meet
the
PM
emission
limi
and
thus
would
incur
these
costs.

e
Reference:
11­
B­
67
Table
5.
New
Baghouse
on
New
Kiln
Notes:

e
1
kiln
of
model
size
N
and
1
kiln
of
model
size
P
are
expected
to
be
built
after
the
first
5
2
kilns
of
model
size
Q
and
2
kilns
of
model
size
R
are
expected
to
be
built
after
the
first
For
models
N,
P,
and
Q,
the
costs
are
incremental
compared
to
the
costs
that
would
be
years
following
the
compliance
date.

5
years
following
the
compliance
date.

incurred
in
complying
with
the
NSPS
for
lime
kilns.
Model
R
represents
a
double
shaft
vertical
kiln
and
these
costs
are
whole,
since
the
NSPS
applies
only
to
vertical
kilns.
Negative
DAC
represents
a
savings
due
to
reduced
electricity
consumption
because
of
a
larger
baghouse
with
less
pressure
drop.
e
e
e
Reference:
11­
B­
6
­
L
%
I
1
1
­
i
?

.
a
.
­
t
E
4
7
Materials
Handling;
Operations
Control
Costs
A
lump
sum
of
$
78,400
capital
cost
and
$
68,600
total
annual
cost
per
major
source
plant.
Reference:
Memo
fiom
Mike
Laney,
RTI.
Estimated
Costs
of
Controlling
Materials
e
Handling
Operations
at
Lime
Manufacturing
Facilities
Table
6.
Kiln
Testing;
and
MonitorinP
Costs
PM
control
device5
OM
and
M
plans,
plus
costs
for
misc.
notifications
Notes:
testing
and
monitoring
costs
would
only
be
incurred
at
major
sources,
except
that
the
M.

Costs
above
are
per
kiln,
except
as
noted.
Costs
for
testing
additional
kilns
at
same
plant
320
tests
would
be
incurred
by
every
plant
are
noted
below.
Add
$
5000
(
one­
time
cost)
and
$
1250
(
annualized
cost)
for
each
additional
kiln
tested
at
same
location.
Add
$
3
100
(
one­
time
cost)
and
$
775
(
annualized
cost)
for
each
additional
kiln
tested
at
same
location.
One
time
costs
are
annualized
over
a
5­
year
period,
7%
interest
rate.
The
rule
applies
only
to
kilns
with
baghouses,
and
BLD
are
an
option
for
ESPs,
but
for
the
purposes
of
costing,
assume
all
kilns
will
use
BLD
e
1.

2.

3.
4.
­

>
­
x
.
be
c
B
8
5.
Assume
55
percent
of
currently
existing
kilns
with
baghouses
or
scrubbers
will
have
a
multi­
stack
(
assume
10
compartment)
contr
the
single
stack
BLD.
Assume
34
percent
of
existing
kilns
with
ESPs
will
have
multi­
stack
configuration
and
wil
6.
For
the
start­
up,
shutdown,
ction
plan,
and
the
operations,
maintenance,
and
monitoring
plan,
and
other
evice
and
will
incur
these
costs
in
lieu
of
costs
in
lieu
of
single
stack
BLD.

ments.
Costs
are
per
plant.

7.
Important
Notes
Reparding
PM
CEMS:
A
separate
EIA
will
need
to
be
conducted
to
model
the
impact
of
the
costs
of
PM
CEMS.
The
PM
CEMS
costs
will
be
u
required
in
the
regulation,
then
BLDs
will
not
be
required.
The
exception
to
this
is
that
kilns
with
multi­
stack
PM
control
devices
will
not
be
required
to
use
PM
CEMS,
so
these
kilns
will
always
incur
the
co
Note
Total
Capital
cost
(
Beta
Gage
type)
PM
CEMS
=
$
170,000
Annual
Cost
(
Beta
Gage
type)
PM
CEMS
=
$
15,000
Capital
Cost
feed
rate
monitor
=
$
22,000
Annual
Cost
feed
rate
monitor
=
$
6,000
Materials
Handling
Operations
Testing,
and
Monitoring
which
is
$
3,750
annualized
over
5
years.
instead
of
the
BLD
costs,
i.
e.,
if
PM
CEMS
are
D
for
a
multi­
stack
PM
control
device.
(
See
d
rate
monitoring
as
well,
i.
e.,

I
.
Assume
all
major
source
plants
incur
$
15,000
in
one­
time
costs
for
PM
tests
on
MHOS,

Costs
are
based
on
two
PM
tests.
One
time
costs
are
thus
1
*
10,000
+
(
1
*
5000)
.
=
$
15,000;
annualized
costs
are
*
2500
+
(
1
*
1250)
=
$
3,750.

.
assume
95
percent
of
major
source
plants
i
$
5,600
in
monitoring
costs,
randomly
assigned.
.
Based
on
$
5,300
*
(
138.8/
131.3))
annual
monitoring
costs.
See
attached
Appendix
A
for
information
on
how
these
costs
were
derived.
(
The
factor
138.8/
13
1.3
is
used
to
convert
ts
from
1993
dollars
to
1997
dollars.)

assume
5
percent
of
major
source
plants
incur
$
12,600
in
annual
monitoring
costs
(
randomly
assigned,
except
assume
all
small
businesses
incur
these
costs).
