November
29,
2004
MEMORANDUM
From:
William
H.
Maxwell
CG/
ESD
(
C439­
01)

To:
Utility
MACT
Project
Files
Subject:
Municipal
Waste
Combustor
(
MWC)
mercury
cost­
effectiveness
calculations
The
attached
e­
mail
detailing
cost­
effectiveness
calculations
for
mercury
control
at
MWC
facilities
is
provided
for
information
purposes.
MWC
regulations
were
required
under
the
provisions
of
section
129
of
the
Clean
Air
Act,
as
amended.
EPA
has
now
completed
the
required
5­
year
review
of
the
MWC
regulations
and
have
assurance
that
all
of
the
units
have
made
the
necessary
retrofits
and
are,
in
fact,
in
compliance
with
the
standard.
Walt
Stevenson/
RTP/
USEPA/
US
10/
07/
2004
03:
14
PM
To:
Fred
Porter/
RTP/
USEPA/
US@
EPA
cc:
RobertJ
Wayland/
RTP/
USEPA/
US@
EPA,
Bill
Maxwell/
RTP/
USEPA/
US@
EPA
Subject:
Fw:
MWC
mercury
control
cost­
effectiveness
calcs.

Fred
Listed
below
is
the
C/
E
level
for
Hg
control
at
large
MWCs.
The
C/
E
is
about
$
1,000/
lb
Hg
removed.
The
note
speaks
for
itself
­­
but
I
would
add
two
comments.
The
C/
E
levels
in
the
earlier
1994
Nebel
memo
of
300
to
500
$/
lb
principally
reflect
the
fact
that
uncontrolled
Hg
levels
were
about
0.650
mg/
dscm
in
1990
and
have
now
been
reduced
to
0.175
mg/
dscm
as
a
result
of
Hg
reduction
in
the
waste
stream
by
various
recycling/
separation
programs
and
the
removal
of
Hg
from
household
batteries.
There's
less
Hg
in
the
waste
and
the
C/
E
increases.
Also
note
the
calculations
assign
all
costs
to
Hg
control.
Remember,
ACI
not
only
achieves
90+
%
Hg
reduction
it
also
achieves
+
75%
dioxin
emission
polishing
.
Some
of
the
cost
of
ACI
should
assigned
to
dioxin
control,
Let
me
know
if
you
have
any
questions.

Walt
­­­­­
Forwarded
by
Walt
Stevenson/
RTP/
USEPA/
US
on
10/
07/
2004
02:
55
PM
­­­­­

Jason
Huckaby
<
Jason.
Huckaby@
erg.
com>
10/
07/
2004
01:
54
PM
To:
Walt
Stevenson/
RTP/
USEPA/
US@
EPA
cc:
Kelly
Martin
<
Kelly.
Martin@
erg.
com>,
Ruth
Mead
<
Ruth.
Mead@
erg.
com>
Subject:
MWC
mercury
control
cost­
effectiveness
calcs.

Walt,

Per
the
methodology
discussed
earlier
today,
$
1057/
lb
mercury
(
2002
dollars)
is
the
calculated
cost­
effectiveness
for
carbon
injection
at
large
MWCs.

The
calculations
used
to
derive
this
are
as
follows:

­
Average
LMWC
performance
is
.014
mg/
dscm
with
92
percent
reduction.
­
Uncontrolled
mercury
concentration
=
.014/(
1­.
92)
=
0.175
mg/
dscm
­
F­
factor:
4560
dscm/
ton
MSW
fired
­
lb
mercury
removed
per
ton
MSW
fired
=
(.
175­.
014)*
4560/(
1000*
453.6)
=
1.6185E­
3
lb/
ton
MSW
­$/
ton
MSW
for
carbon
injection
in
1987
is
$
1.52/
Mg
*
(
Mg/
1.1023
ton)
=
$
1.38/
ton
MSW
in
1987
­
Multiply
1987
by
1.111
to
get
to
1990
dollars,
and
then
multiply
by
1.106
to
get
to
2002
dollars:
$
1.38*
1.111*
1.106=
$
1.70/
ton
MSW
fired
Putting
it
all
together:
$
1.70/
1.6185E­
3
=
$
1057/
lb
mercury
removed
As
a
comparison
to
earlier
MWC
cost
effectiveness
costs:
Docket
Item
A­
90­
45,
II­
B­
33
(
June
21,
1994)
Kris
Nebel
to
Walt
Stevenson.
"
Incremental
Mercury
Control
Costs
for
Large
Existing
MWC's"
presents
some
cost
effectiveness
values
between
$
206
and
$
453
per
pound
mercury,
depending
on
the
expected
level
of
mercury
control
and
whether
or
not
the
unit
was
equipped
with
a
SD/
ESP
or
SD/
FF.
Assuming
the
memo
is
using
1990
dollars,
adjusting
these
values
to
2002
dollars
yields
a
range
between
$
228
and
$
501/
lb
mercury
removed.
I
will
be
out
of
the
office
between
2:
00
and
3:
30,
but
will
be
around
the
rest
of
the
afternoon.
Let
me
know
if
you
have
any
questions
or
comments.

Jason
Jason
M.
Huckaby
Chemical
Engineer
ERG
1600
Perimeter
Park
Dr.
Morrisville,
NC
27560
(
919)
468­
7826,
FAX
(
919)
468­
7801
Jason.
Huckaby@
erg.
com
