MEMORANDUM

SUBJECT:	Summary of Environmental and Cost Impacts of Proposed Revisions
to Portland Cement New Source Performance Standards (40 CFR Part 60,
subpart F)

FROM:	Mark Bahner, RTI

		Melissa Icenhour, RTI

	Mike Laney, RTI

	Keith Barnett, EPA

TO:	Docket Number EPA-HQ-OAR-2007-0877

DATE:	May 29, 2008

I. Introduction

To meet the requirements of section 111(b)(1)(B) of the CAA, the
Environmental Protection Agency (EPA) is currently conducting the fourth
review of the new source performance standards (NSPS) for Portland
Cement Plants (PCP). The PCP NSPS was promulgated on December 23, 1971
(40 CFR Part 60 subpart F, 36 FR 24876) and subsequently reviewed three
times (39 FR 20793, June 14, 1974; 39 FR 39874, November 12, 1974; and
53 FR 50354, December 14, 1988). Subpart F requires new, modified, or
reconstructed affected facilities at PCP to achieve emission levels that
reflect the best demonstrated system of continuous emission reduction,
considering cost, non-air quality health, environmental, and energy
impacts. These emission levels, referred to as “best demonstrated
technology (BDT),” are specified in subpart F. 

The purpose of this memorandum is to document the methodology used to
estimate the environmental and cost impacts associated with this NSPS
review. The impacts in this memorandum are based on a projected number
of 20 new kilns over the five year period following promulgation.
Section II discusses the impacts of this NSPS review (scheduled for
promulgation in 2009), including an overview of the proposed amendments
resulting in impacts and the methodology used to develop the impact
estimates.

II. Subpart F Impacts Estimated for 2009 Promulgation of NSPS Review

Affected Industry and Proposed Changes to Subpart F

The portland cement manufacturing industry is comprised of an estimated
105 cement plants capable of producing clinker and operating a total of
approximately 178 kilns (PCA, 2007). Based on industry capacity
expansion estimates (PCA, 2006), it is projected that by the fifth year
following promulgation of the amendments, 20 new kilns will come on line
and clinker production capacity will increase by approximately
24,000,000 tons. 

To illustrate impacts of the proposed NSPS for cement manufacturing,
impacts are calculated for a preheater/precalciner kiln having a clinker
production capacity of 1,200,000 tons per year, which is considered
representative of new preheater/precalciner kilns. Because of their
energy efficiency and higher production capacity, all new kilns are
expected to be preheater/precalciner kilns. Impacts are also estimated
for the fifth year after promulgation, in which it is assumed that 20
new kilns, each producing 1,200,000 tons of clinker per year will have
been built. 

The current subpart F NSPS review is scheduled to be promulgated in
2009. The impacts of concern for the NSPS review are incremental
impacts, specifically the difference in impacts associated with the
current NSPS and the impacts associated with any changes in NSPS
requirements resulting from the 2009 NSPS amendments. The impacts are
determined over a period of five years following promulgation of the
2009 NSPS revisions. Thus, the affected facilities of concern are those
installed from 2009 to 2013. Baseline represents the impacts associated
with application of the current NSPS. The incremental impacts of the
2009 NSPS review are determined by comparison to the baseline impacts.
Changes in requirements being proposed as part of the 2009 NSPS review
that could result in significant incremental impacts include those
summarized in Table 1. 

Table 1. Summary of proposed changes to subpart F and type of
incremental impacts.

Proposed rule change	Type of Incremental Impact

▪ A reduction in the PM stack emission limit for kilns from 0.5 lb of
PM/ton of clinker (0.3 lb/ton of feed) to 0.086 lb of PM/ton of clinker.
Costs to replace standard fabric bags with more expensive membrane bags.
Emission reductions are also estimated.

▪ A reduction in the PM stack emission limit for clinker coolers from
0.17 lb of PM/ton of clinker (0.1 lb/ton of feed) to 0.086 lb of PM/ton
of clinker.	Clinker coolers are already meeting the new limit, but the
cost of bag leak detectors are estimated.

▪ Addition of a NOx limit of 1.5 lb NOx /ton clinker.	Costs to install
SNCR. Emission reductions are also estimated.

▪ Addition of a SO2 limit of 1.33 lb SO2/ton clinker or 90% reduction
of SO2 across the control device.	Costs to install alkaline wet
scrubbers. Emission reductions are also estimated.

▪ Addition of bag leak detectors on all new baghouses.	Capital costs
of installation and annual costs of operation.

▪ Addition of continuous NOx monitors on new kilns.	Capital costs of
installation and annual costs of operation.

▪ Addition of continuous SO2 monitors on new kilns.	Capital costs of
installation and annual costs of operation.

▪ Addition of continuous flow monitors on new kilns.	Capital costs of
installation and annual costs of operation.



The air quality impacts and costs of the final amendments for portland
cement manufacturing were calculated using the following assumptions:

Wet alkaline scrubbers will be installed on four new kilns for the
control of SO2 emissions;

New kilns will be equipped with reverse air baghouses using membrane
bags rather than fabric bags;

SNCR will be installed on all new kilns to control NOx emissions;

NOx monitors will be installed on all new kilns;

SO2 monitors will be installed on all new kilns; and

Bag leak detectors will be installed on baghouses on all new kilns and
clinker coolers.

Air Quality Impacts

The various impacts on emissions of nitrogen oxides (NOx), sulfur
dioxide (SO2) and particulate matter (PM) are calculated for different
control options. These control options will be summarized in the
discussion of air quality impacts, below. Direct air impact reductions
will be calculated, and where appropriate, indirect air impacts will be
calculated, such as the increase in emissions from additional
electricity or fossil fuel require to power control devices, water
quality impacts (e.g., from scrubbers), and solid waste impacts (e.g.,
from disposal of spent sorbents or catalysts).

Nitrogen Oxides (NOx)

EPA recently issued an alternative control techniques (ACT) document
addressing the emissions and control of NOx from new cement kilns (EPA,
2007). Unless noted otherwise, this document is the source of the
information on NOx emissions and controls presented here.

The high temperatures and oxidizing atmospheres required for cement
manufacturing are favorable for NOx formation. In cement kilns, NOx
emissions are formed during fuel combustion primarily by the oxidation
of molecular nitrogen present in combustion air (referred to as thermal
NOx) and the oxidation of nitrogen compounds in fuel (referred to as
fuel NOx). Many states issuing construction and operating permits for
new kilns have specified emission limits for NOx. In recently built
kilns, emissions of NOx are typically reduced through process controls
such as burner design and staged combustion in the calciner (SCC). NOx
emissions from kilns using process designs such as low NOx burners and
SCC average about 2.5 lb/ton of clinker (EPA, 2007). Add-on controls
used to reduce NOx emissions include selective noncatalytic reduction
(SNCR) and selective catalytic reduction (SCR). In recent new source
review procedures, states have determined best available control
technology (BACT) to be SNCR in addition to well designed SCC and other
process designs such as low NOx burners. In SNCR systems, ammonia, urea
or another reagent is injected in the flue-gas into an appropriate
temperature zone and at an appropriate ratio of ammonia to NOx. On
average, SNCR achieves approximately a 35 percent reduction in NOx at a
ratio of ammonia-to-NOx of about 0.5 and a reduction of 63 percent at an
ammonia-to-NOx ratio of 1.0. At high ratios, some ammonia may not react
with NOx and will be emitted (ammonia slip). Another NOx control
technology, SCR, is used in the electric utility industry to reduce NOx
emissions from boilers and, to date has been used worldwide on three
cement kilns. SCR is capable of reducing NOx emission by about 80
percent. Currently, SCR is not used on any cement kilns in the U.S.

Four options were evaluated for control of NOx emissions. The first
option was to maintain the baseline of no limit and no additional
control. The other three options are given in terms of pounds of NOx per
ton of clinker (lb/ton clinker). The three options evaluated were 1.95
lb/ton clinker, 1.5 lb/ton clinker, and 0.5 lb/ton clinker.

In choosing these NOx emission limit options, recently issued permits,
recent BACT determinations and recent emissions data for
preheater/precalciner kilns were reviewed. At three recently permitted
preheater/precalciner kilns utilizing well designed and operated process
designs including SCC, averaged NOx emissions of 1.62, 1.88 and 1.97
lb/ton of clinker were measured for Titan America-Pennsuco, in Medley,
FL, Little Giant Cement in Harleyville, SC, and CEMEX in Santa Cruz, CA
(Bahner, 2008a). These kilns are not equipped with additional add-on
controls. However, based on data from equipment vendors and other
facilities with more difficult to burn raw materials, we believe that
future well-designed and operated cement kilns, which will incorporate
SCC and low-NOx burners, will meet a level of 2.5 lb/ton of clinker on
average. This level is the baseline level of control that would occur
with no additional regulatory action.

The second control evaluated was 1.95 lb/ton clinker, which is a common
level established as BACT in recent permits for new sources (Bahner,
2007). As previously noted, some new facilities meet this level of
control using low-NOx burners and SCC. However, we expect that, on
average, new facilities would require a SNCR removal efficiency of 22
percent SNCR to meet this level, which is well within the range
demonstrated for SNCR. 

The third control level evaluated was 1.5 lb/ton clinker, and was
established based on our assessment of the best demonstrated performance
of SNCR. Data on SNCR show a performance that ranges from approximately
20 to 80 percent NOx reduction. We estimate that about 50 percent NOx
emission reductions represents a reasonable level of performance of SNCR
over the long term. Though new kilns on average will have emissions of
2.5 lb/ton prior to the application of add-on controls, there may be
some situations where specific raw materials properties will result in
higher NOx emissions. For this reason we assumed a maximum baseline of
3.0 lb/ton and 50 percent emission reduction by SNCR to establish a 1.5
lb/ton control level. Data available for Suwannee American Cement
Company, which operates with SNCR, indicated an average NOX value of
1.44 lb/ton, and a calculated 99th percentile 30-day rolling average
value of 1.58 lb/ton (Bahner, 2008a).

The fourth option evaluated was 0.5 lb/ton of clinker based on the
performance of SCR. There are currently no operating SCR systems on
cement kilns in the United States, so SCR currently is not demonstrated
in the U.S. 

Table 2 shows the NOx annual reductions achieved for each option, for a
single kiln producing 1,200,000 tons per year (tpy) of clinker, and
nationwide for 20 kilns, each producing 1,200,000 tpy of clinker.
Emissions reductions are presented both cumulatively from the baseline
and incrementally compared to the next less-stringent measure. For
example, for the four emission limit options of 2.5, 1.95, 1.5 and 0.5
lb/ton of clinker, the decreases in lb/ton of clinker relative to the
next less stringent option are 0, 0.55, 0.45 and 1 lb/ton, respectively.
In contrast the total reductions (relative to the 2.5 lb/ton baseline
level) are 0, 0.55, 1, and 2 lb/ton, respectively. Table 2 also presents
both the incremental and total emission reductions for a single kiln
producing 1.2 million tpy of clinker. As an example of how these
reductions are calculated, for a 1.2 million tpy kiln emitting at 1.5
lb/ton (Option 3) versus 2.5 lb/ton (Option 1), the total reduction
would be 600 tons (i.e., 2.5 lb/ton minus 1.5 lb/ton, or 1.0 lb/ton,
times 1.2 million tpy, or 1.2 million pounds, or 600 tons). Table 2 also
has annual nationwide reductions, based on 20 new kilns operating at
1.2 million tpy each over the 5-yr period after promulgation,.
Nationwide emission reductions are calculated incrementally (i.e.,
compared to the next most stringent option) and in total (compared to
the baseline, Option 1).

Table 2. Options considered for NOx reductions from kilns.

Option	Emission Factors, per ton of clinker	Per Kiln Reductions

(@1.2 million tpy kiln production)	Annual Nationwide Reductions

(based on 20 kilns of 1.2 million tpy each)

	Emission Limit

(lb/ton)	Incremental Reduction

(lb/ton)	Total

Reduction

(lb/ton)	Incremental

Reduction

(tons)	Total

Reduction (tons)	Incremental

(tons)	Total

(tons)

1	2.5	0	0	0	0	0	0

2	1.95	0.55	0.55	330	330	6,600	6,600

3	1.5	0.45	1	270	600	5,400	12,000

4	0.5	1	2	600	1,200	12,000	24,000



Particulate Matter (PM)

All new kilns are expected to use fabric filters for PM control. Fabric
filters are the most common PM control technology used for portland
cement processes. In selecting the proposed PM emission limit for new
kilns, three control options were considered that represented the
emissions limits achievable for fabric filters applied to cement kilns.
One option was the current level of 0.3 lb/ton of feed (which is
equivalent to 0.5 lb/ton of clinker). 

The second option was to set a new level that was equivalent to PM
levels established as part of recent BACT determinations. These levels
range from 0.09 to 0.28 lb/ton of clinker with an average of 0.16 lb/ton
of clinker. The second option was chosen as the average value of 0.16
lb/ton of clinker. Current fabric filter designs for new
preheater/precalciner kilns routinely achieve this level (Bahner,
2008b).

The third PM control level considered was 0.086 lb/ton clinker. This is
the level equivalent to the currently proposed new source level for
cement kilns that fire hazardous waste. In order to evaluate control
device that are representative of the latest fabric filter design, 19
emission tests conducted on four portland cement kilns controlled by
fabric filters with membrane bags, where the kilns had been built in the
last 10 years, were reviewed,.  Thirteen of those tests were on a cement
kiln that burns hazardous waste.  No difference is expected in the
performance of a fabric filter for PM applied to a kilns that burn
hazardous waste and those that do not because PM emissions are largely
contributed by non-hazardous waste feed streams, and because fabric
filters control PM emissions generally to the same concentration
irrespective of the PM loading at the inlet.  The individual test
results converted to an output basis ranged from 0.0023 to 0.10176
lb/ton of clinker with an average of 0.0357 lb/ton.  In order to account
for variability, statistical variation was analyzed by calculating a
standard deviation of the test averages, multiplying the standard
deviation by the t value for the 95th or 99th percentile, and adding
this value to the average of all the tests.  A level of 0.0830 lb/ton of
clinker represented an emissions limit that will not be exceeded 95
percent of the time and a level of 0.1025 lb/ton of clinker represented
an emissions limit that will not be exceeded 99 percent of the time. 
The emission test results and results of the statistical analysis are
presented in Attachment 5.

A different statistical analysis of the data from the hazardous
waste-burning cement kiln equipped with a membrane fabric filter was
performed, applying to the data a so-called universal variability factor
derived from the performance of the best performing (lowest emitting) PM
performers equipped with fabric filters across the hazardous waste
combustor source category.  This variability factor quantifies both
short-term and long-term operating variability, i.e., variability
associated with the conditions of the individual compliance test and
variability associated with the performance of the control equipment
over time.  (See 72 FR 54878-79, September 27, 2007.)  (This approach is
more sophisticated, since it accounts for both short-term and long-term
variability, whereas variability in the individual runs comprising the
compliance tests (i.e., the 95th or 99th percentile of those data), is
more a measure of short-term variability alone, see 72 FR 54878).  Using
this approach, a value of 0.0069 gr/dscf, corrected to 7 percent oxygen,
was calculated.  (See 71 FR 14669, March 23, 2006.)  Using a typical
value of 54,000 dry standard cubic feet (dscf) of exhaust produced per
ton of kiln feed and one ton of clinker producer per 1.65 tons of feed,
0.0069 gr/dscf is equivalent to 0.086 lb/ton of clinker. At this control
level, more expensive membrane-coated bags would be needed to replace
standard fabric bags in the fabric filter. 

Table 3 shows the PM reductions that can be achieved under each option
for a single model producing 1,200,000 tons per year (tpy) of clinker,
and nationwide for twenty kilns, each producing 1,200,000 tpy of
clinker. Emissions reductions are presented both cumulatively from the
baseline if possible, and incrementally compared to the next
less-stringent measure.



Table 3. Options considered for PM reductions from kilns.

Option	Emission Factors, per ton of clinker	Per Kiln Emission Reduction

(@1.2 million tpy kiln production)

	Nationwide Emission Reductions

(based on 20 kilns of

1.2 million tpy each)

	Emission Limit

(lb/ton)	Incremental Reduction

(lb/ton)	Total Reduction (lb/ton)	Incremental

Reduction

(tpy)	Total

(tpy)	Incremental (tpy)	Total

(tpy)

1	0.5	0	0	0	0	0	0

2	0.16	0.34	0.34	204	204	4,080	4,080

3	0.086	0.074	0.414	44.4	248.4	888	4968



Sulfur Dioxide (SO2)

Based on reviews of recent BACT determinations and permits, control
technologies that were not being used at the time of the previous NSPS
review are now being used to control SO2 emissions from cement kilns. As
a result, wet scrubbers and lime injection were evaluated as potential
control technologies for portland cement operations. The proposed
emission limit takes into account the inherent scrubbing ability of the
naturally alkaline raw materials used in the cement manufacturing
process. 

Sulfur dioxide from a cement kiln comes from the oxidation of sulfur
from two sources. The first is sulfur in the fuel, which mixes with lime
in the kiln and preheater with little or no SO2 emitted into the
atmosphere from this source. The other source of SO2 is the raw
materials, which may be oxidized to SO2 in the kiln system when mixed
with sufficient oxygen.

For most portland cement plants, the levels of sulfur in raw materials
are sufficiently low and most of the SO2 generated is removed by the
natural scrubbing action of the kiln raw feed. In instances where the
sulfur content of raw materials is higher, uncontrolled SO2 emissions
can be significant. In those situations, add-on controls may be
necessary to prevent high SO2 emissions.

The first type of SO2 control equipment considered is alkaline
scrubbers. They are capable of achieving a 90 to 95 percent reduction in
SO2 emissions on cement kilns (Bahner and Laney, 2008). The difference
between SO2 emissions before and after the scrubber at the Lehigh Cement
plant in Davenport, Iowa was approximately 96 percent (Bahner, 2008c;
Bahner and Laney, 2008).

The second type of SO2 control equipment is lime injection, which
consists of injecting lime into a duct downstream of the preheater, or
in some cases injecting lime into the first two preheater stages to
remove SO2. At some facilities lime injection is only used when
increases on SO2 emission above a specified level are detected, such as
when the raw mill is down. Dry lime systems typically achieve an
emission reduction of approximately 70 percent (NESCAUM, 2005), although
there are systems that can achieve 90 percent. (Bahner and Laney, 2008).

Four options were evaluated for control of SO2 emissions. The first
option was to maintain the baseline of no SO2 emission limit, and the
other three options include an emission limit of SO2 in pounds per ton
of clinker (lb/ton clinker). Air quality impacts under each of the
control options depend on the sulfur content of the raw materials. Raw
materials containing high levels of sulfur are likely to result in high
SO2 emissions unless controls are applied.

High uncontrolled SO2 emissions associated with high sulfur raw
materials were based on examples where facilities have applied wet
scrubbers for SO2 control and were assumed to emit uncontrolled SO2 at a
level of 13 lb/ton. Uncontrolled SO2 emissions of 1.3 lb/ton of clinker
(0.8 lb/ton of feed) represent a moderate emission level. The moderate
uncontrolled SO2 emission level was based on the averages of 18 data
points for tested NSPS facilities and was assumed to represent moderate
raw material sulfur levels (Heath, 1996). Low uncontrolled SO2 emissions
from low sulfur raw materials are based on examples from Florida where
kilns emit uncontrolled SO2 at levels of 0.2 lb/ton clinker or less
(Bahner, 2008c).

The first control option was no additional control of SO2 other than the
inherent control achieved by the kiln and raw mill. State BACT
determinations usually identify inherent SO2 removal as BACT. The second
option selected was 1.33 lb/ton clinker which represents a recent BACT
determination level of a facility (TXI, Midlothian, TX) with high sulfur
raw materials that applied an alkaline wet scrubber for SO2 control (FL
DEP, 2005). The third option evaluated was 0.4 lb/ton clinker, which is
based on the average of SO2 permit limits from recent BACT
determinations which ranged from 0.06 to 1.33 lb/ton of clinker (Bahner,
2007). The fourth option evaluated was 0.2 lb/ton clinker which is
typically specified in Florida for kilns with low sulfur raw materials
and is one of the lowest levels from recent BACT determinations.

The proposed SO2 emission limit for new kilns is 1.33 lb/ton of clinker,
or alternatively, demonstration of a 90 percent SO2 emissions reduction
measured across the control device, such as an alkaline scrubber as BDT.
Option 1 would have allowed kilns with high sulfur raw materials,
several of which are currently controlled with wet scrubbers, to emit
significant amounts of SO2.

Table 4 shows the SO2 reductions that can be achieved by a wet scrubber
that gets a SO2 emission reduction of 95 percent under option 1 and 2
for high sulfur kiln input materials. The emission reduction is the same
under options 3 and 4.

Table 4. Options considered for SO2 reductions for kilns with
high-sulfur inputs.

Option	Emission Limit

(lb/ton clinker)	Control	Annual Emissions (@1.2 million tpy kiln
production)

(tons)	Annual Reductions (tons)

1	Baseline (13)	None	7,800	0

2	1.33	Wet scrubber	390	7,410



Table 5 shows the SO2 reductions that can be achieved by option for
medium sulfur kiln input materials. For option 2, no additional control
is necessary because the uncontrolled emission level is below the SO2
limit of 1.33 lb/ton. Under option 3, a less costly lime injection
system that gets 70 percent removal is capable of meeting the limit of
0.4 lb/ton. A wet scrubber would be required under option 4.



Table 5. Options considered for SO2 reductions for kilns with
medium-sulfur inputs.

Option	Emission Limit

(lb/ton clinker)	Control	Annual Emissions 

(@1.2 million tpy kiln production)

(tons)	Reductions (tons)	Emission Level After Control

(lb/ton clinker)

1	Baseline (1.3)	None	780	0	1.3

2	1.33	No reduction necessary	780	0	1.3

3	0.4	Dry lime scrubber (DLS) (70%)	234	546	0.39

4	0.2	Wet scrubber (WS) (95%)	39	741	0.065



For kilns with uncontrolled emissions (due to low sulfur input
materials, combined with the natural scrubbing effect of alkali
materials in the kiln) below 0.2 lb/ton, no controls for SO2 will be
necessary. The baseline SO2 emissions from a kiln producing 1.2 million
tons per year would be 120 tpy (i.e., 1.2 million tons per year times
0.2 lb/ton).

It is estimated that, nationwide, four kilns will be using high-sulfur
raw materials in the five years following promulgation. The emission
reductions in the fifth year will be 7,410 tpy times 4 kilns = 29,640
tpy. 

VOC and CO

Emissions of CO and unburned hydrocarbons (VOC/THC) are due to
incomplete oxidation. Methods to address these pollutants include more
complete oxidation either in the burner area (e.g. with higher levels
and better placement of the introduction of excess air) or by more
complete oxidation in a downstream control device, such as a
regenerative thermal oxidizer (RTO, where the “regenerative” portion
of the description refers to recovery of heat that would otherwise be
lost in the oxidation process). The VOC/THC from raw materials can be
significant if there are substantial organics in the raw material. The
only control technology identified to reduce CO emission is an RTO
(which also would concurrently reduce any VOC emissions). Activated
carbon injection (ACI) into a particulate control device can be used to
control VOC/THC (but not CO).

The proposed amendments will not contain limits for CO or VOC emissions
from cement kilns. VOC emission from new cement kilns will mainly result
from organics in the raw materials. Organic constituents in the raw
material can be driven off in the kiln preheater prior to reaching a
temperature zone that would result in combustion. New cement kilns are
currently subject to a 20 ppmv total hydrocarbon (THC) emissions limit
by the Portland Cement NESHAP.  Because most of the THC are also VOC,
the THC limit also limits VOC, and serves as the baseline for the NSPS
analysis.  This limit is based on the best performance of the
regenerative thermal oxidizer add-on control, which is the most
effective VOC emission control available for this source category. 
Therefore we determined that no additional regulation of VOC emissions
is feasible.  

 

Emissions of CO can come from two sources, unburned fuel from the
precalciner and CO evolved from the raw materials by the same mechanism
as the THC emissions. Unburned fuel represents an economic loss to the
facility. Therefore, new precalciners are designed to combust fuel as
efficiently as possible, and CO emissions from fuel combustion are
minimized, regardless of any potential emission limit.

As is the case for VOC, facilities with moderate or high levels of
organic materials in the feed would emit THC at levels high enough that
THC control would be required under the Portland Cement NESHAP.
Therefore, the THC limit in the Portland Cement NESHAP also serves as
the baseline of the CO analysis.  As previously noted, the THC limit is
based on the best performance of the regenerative thermal oxidizer
add-on control, which is also the most effective CO emission control
available for this source category.  Therefore we determined that no
additional regulation of CO emissions is feasible.  

Secondary Impacts

Secondary air quality impacts will result from the increased electrical
demands of control equipment required to comply with the final
amendments. The secondary impacts in this memorandum will include
impacts of additional electricity consumption and the pollution from
that consumption, water pollution, and solid waste impacts. The addition
of add-on controls, such as scrubbers, will increase electricity
demands. The electricity demand for pumping the reagent in an SNCR
system are negligible. The additional electricity usage by an alkaline
scrubber for a 1.2 million ton per year plant are as follows (see input
parameters for wet scrubber in cost section):

Scrubber	-	12,075,355 kWh/yr 

The emission factors used to estimate increased emissions of NOx, CO,
SO2, and PM10 from the increased electricity demand are as follows
(Docket item IV-B-25, Docket A-94-52):

NOx	-	0.00446 lb/kWhr

CO	-	0.00231 lb/kWhr 

SO2	-	0.00765 lb/kWhr

PM10	-	2.25(10-4) lb/kWhr

Increases in secondary emissions resulting from the increased electrical
demand of an alkaline scrubber for a new 1,200,000 ton/yr kiln are
summarized in Table 6.

Table 6. Secondary emissions for a 1,200,000 tpy kiln.

Control	Increased Electrical Demand

(kWh/yr)	Increased Emissions (tons/yr) for 1.2M Ton/Yr Kiln



NOx	CO	SO2	PM10

Wet Scrubber	12,075,355	26.9	13.9	46.2	1.4



The total nationwide increase in emissions from the increased electrical
demands of scrubbers installed on four new kilns for the fifth year
following promulgation are presented in Table 7.

Table 7. Nationwide secondary emissions.

Controls and number of systems	Increased Electrical Demand

(kWh/yr)	Nationwide Increased Emissions (tons/yr)



NOx	CO	SO2	PM10

Scrubbers (on 4 kilns)	48,301,420	108	56	185	5



Water Quality Impacts

The use of alkaline scrubbers will result in increased consumption of
water (for makeup water and production of the scrubber slurry). For a
new 1,200,000 ton/yr kiln, the additional water requirement is estimated
at 97,000,000 gallons per year (see input parameters for wet scrubber in
cost section). No water quality impacts are associated with the use of
SNCR systems. Based on the use of scrubbers on a total of four new kilns
over the 5-year period following promulgation, total water requirements
at the end of the fifth year will be approximately 388 million gallons. 

D. Solid Waste Impacts

Additional solid waste will result from the disposal of scrubber slurry.
For a new 1,200,000 ton/yr kiln, the additional solid waste generated as
a result of the addition of the scrubber is estimated at 84,101 tons per
year (Docket item II-B-67, Docket No. A-92-53). However, the waste from
the scrubber contains synthetic gypsum and is typically dewatered and
returned to the process where it is mixed with clinker in the finish
mill. The result is that the waste is not disposed of in a landfill. No
solid waste impacts are anticipated with the use of an SNCR system. The
total additional solid waste generated at the end of the fifth year
following promulgation of the amendments will be an estimated 336,000
tons from the scrubber slurry of four scrubbers. 

The additional solid waste generated from baghouses, in the form of
cement kiln dust, as a result of the more stringent PM requirement will
be 44.4 tons/yr for a 1,200,000 ton/yr kiln. This material is typically
considered product and is returned to the kiln or mixed with the cement.

E. Energy Impacts 

The use of alkaline scrubbers on new kilns will increase electricity
consumption. The additional electricity required for an alkaline
scrubber added onto a new 1,200,000 ton/yr kiln is estimated at
12,075,355 kWh/yr.  For the 5-year period following promulgation, the
additional electricity demand associated with the installation of
scrubbers on four new kilns will be 48,301,420 kWh. 

Cost Impacts

NOx Emissions

Four options were evaluated for control of NOx emissions. The first
option was to maintain the baseline of no NOx limits. The other three
options are given in terms of pounds of NOx per ton of clinker (lb/ton
clinker). The three options evaluated were 1.95 lb/ton clinker, 1.5
lb/ton clinker, and 0.5 lb/ton clinker.

Costs were evaluated for all four options. Costs for SNCR and SCR were
derived from Alternative Control Techniques Document Update – NOx
Emissions from New Cement Kilns (EPA, 2007). Capital costs for SNCR
systems ranged from $0.78 to $2.88 per ton of clinker produced. An
average of $1.76 per ton of clinker was used to estimate capital costs.
For the 1.95 lb/ton NOx option, an operating cost of $0.51 per ton of
clinker was used to calculate annual costs. For the higher removal
efficiency necessary to meet the 1.5 lb/ton NOx limit, more reagent
would be required to meet the limit resulting in higher operating costs.
An average annual cost of $1.01 per ton of clinker was used to estimate
annual costs to meet the Option 3 limit of 1.5 lb of NOx /ton of
clinker. The average capital costs for SCR were determined to be $4.57
per ton of clinker while an average of $2.50 per ton of clinker was used
to estimate annual operating costs for SCR.

The results of this analyses showed that the overall annualized cost of
control for both the 1.95 and the 1.5 levels were approximately $2,000
per ton of NOx reduction. Given the similarity of costs, Option 3 (1.5
lb/ton clinker) was chosen as BDT.

Assuming a kiln with a clinker capacity of 1,200,000 tons, the capital
cost of the SNCR is $2,112,000 and the annual operating cost is
$1,212,000. 

Under the proposed amendments, compliance with the emission limits for
NOx will be determined using continuous emissions monitoring systems.
Continuous flow rate monitors will also be required to determine
compliance. The capital/startup costs for NOx and flow rate CEMS are
$140,951 and $35,780, respectively. Annual operations and maintenance
costs for NOx and flow rate CEMS are $41,809 and $13,864, respectively.
All costs are derived from the CEMS Cost Model and include a capital
recovery factor of 0.1424 (equipment life of 10 years and a yearly
interest rate of 7%). Attachment 2 is the output file from the CEMS Cost
Model for NOx CEMS. Attachment 3 is the output file from the CEMS cost
Model for flow rate CEMS.

Including the cost of CEMS, the annual operating and maintenance cost
per kiln is $1,267,673 and the total capital cost per kiln is $2,288,731
for SNCR. Assuming that 20 new kilns will install SNCR to comply with
the NOx emission limit, the total annualized cost is an estimated $25.4
million. Total capital cost over the 5-year period following
promulgation is an estimated $45.8 million.

Table 8 shows the costs and potential reductions associated with each of
the four options for NOx control.

Table 8. Costs and cost effectiveness of NOx emission limits for
1,200,000 ton/yr kiln.

Option	1

(Baseline)	2

(1.95 lb/ton clinker)	3

(1.5 lb/ton clinker)	4

(0.5 lb/ton clinker)

Capital cost, $million	0	2.3	2.3	5.7

Annualized cost, $million/yr	0	0.7	1.3	3.1

Total NOx reduction (tpy)	0	330	600	1,200

Total C/E ($/ton NOx)	0	2,023	2,113	2,546



Particulate Matter (PM) Emissions

The costs of reverse air baghouses and standard fabric bags (for Options
1 and 2) were derived from the EPA Air Pollution Control Cost Manual.
The capital costs of non-membrane bags and a baghouse are estimated to
be $4.78 per ton of clinker and annual operating costs are estimated to
be $1.67 per ton of clinker. The total costs for a baghouse using
standard fabric bags on a kiln with a capacity of 1,200,000 tons of
clinker is estimated to be $5,731,163 for capital cost and $2,004,710
for annual cost. 

The costs of reverse air baghouses and membrane bags (for Option 3) were
also derived from the EPA Air Pollution Control Cost Manual. The capital
costs of membrane bags and a reverse air baghouse are estimated to be
$5.89 per ton of clinker and annual operating costs are estimated to be
$1.82 per ton of clinker. The total cost for a baghouse with membrane
bags on a kiln with a capacity of 1,200,000 tons of clinker is estimated
to be $7,065,703 for capital cost and $2,180,919 for annual costs.

Because it is assumed that all options would use a reverse air baghouse,
the incremental cost of using membrane bags is the difference between
the cost of Options 1 and 2 and Option 3. Therefore, the incremental
costs are estimated as $1,334,540 for capital cost and $176,209 for
annual costs.

Bag leak detectors are used to monitor changes in particulate matter
emission rates within baghouses. A change in emission rate usually
indicates a bag leak or another type of failure within the baghouse.
Costs were estimated using the CEMS Cost Model, assuming that each
baghouse has 5 compartments and there is a separate sensor in each
compartment. It was assumed that the same bag leak detector could be
used for the clinker cooler baghouse as for the kiln baghouse, so the
costs were estimated using 10 sensors. The capital/startup cost for bag
leak detector CEMS is $93,719. Annual operations and maintenance costs
for bag leak detector CEMS are $34,748. All costs are derived from the
CEMS Cost Model and include a capital recovery factor of 0.1424
(equipment life of 10 years and a yearly interest rate of 7%).
Attachment 4 is the output file from the CEMS Cost Model for bag leak
detectors.

Including the cost of the bag leak detector, the annual operating and
maintenance cost per kiln is $210,957 and the total capital cost per
kiln is $1,428,253 for reverse air baghouses equipped with membrane bags
and a bag leak detector for each kiln/clinker cooler combination.
Assuming that 20 new kilns and clinker coolers will install reverse air
baghouses to comply with the PM emission limit, the total annualized
incremental cost is an estimated $4.2 million. Total capital incremental
cost over the 5-year period following promulgation is an estimated $28.6
million. 

The incremental PM reductions between baseline and Option 3 are
estimated to be 44 tons per year. This equals a cost effectiveness of
approximately $3,900 per ton of PM reduction. The incremental fine PM
reductions (PM less than 2.5 microns in diameter) between baseline and
Option 3 are estimated to be 20 tons per year. This equates to a cost
effectiveness of approximately $9,000 per ton of fine PM reduction. 

SO2 Emissions

Four options were evaluated for control of SO2 emissions. The first
option was to maintain the current limit and the other three options
include an emission rate of SO2 in pounds per ton of clinker (lb/ton
clinker). Control costs and cost reductions for the three emission rates
were evaluated based on varying levels of sulfur in the raw materials.
Low uncontrolled SO2 emissions from low sulfur raw materials were based
on examples from Florida where kilns emit uncontrolled SO2 at levels of
0.2 lb/ton clinker or less. High uncontrolled SO2 emissions associated
with high sulfur raw materials were based on examples where facilities
had applied wet scrubbers for SO2 control and were assumed to emit
uncontrolled SO2 at a level of 13 lb/ton. Uncontrolled SO2 emissions of
1.3 lb/ton represent a moderate emission level. Moderate uncontrolled
SO2 emissions were based on the averages of 18 data points for tested
NSPS facilities and were assumed to represent moderate raw material
sulfur levels.

The first control option considered was no additional control of SO2
other than the inherent control achieved by the kiln and raw mill. State
BACT determinations usually identify inherent SO2 removal as BACT. The
second option evaluated was an SO2 limit of 1.33 lb/ton clinker which
represents a recent BACT determination level of a facility with high
sulfur raw materials that applied an alkaline wet scrubber for SO2
control. The third option evaluated was a limit of 0.4 lb/ton clinker,
which is based on the average of SO2 permit limits from recent BACT
determinations, ranging from 0.06 to 1.33 lb/ton of clinker. The fourth
option evaluated was 0.2 lb/ton clinker which is representative of
permit limits specified in Florida for kilns with low sulfur raw
materials and is one of the lowest levels from recent BACT
determinations.

Under the proposed amendments, the SO2 emission limit for new kilns will
be 1.33 lb/ton of clinker, or alternatively, demonstration of a 90
percent SO2 emissions reduction measured across the control device, such
as an alkaline scrubber as BDT. Option 1 was rejected because this would
allow kilns with high sulfur raw materials, several of which are
currently controlled with wet scrubbers, to emit significant amounts of
SO2. Controlling the high sulfur kilns to a level of 1.33 lb/ton results
in a cost per ton of SO2 removed of less than $1000 per ton of SO2
removal.

Options 3 and 4 were rejected because they would have resulted in cement
kilns using moderate sulfur content raw materials installing add-on
controls at a cost of over $6,000 per ton of SO2 reduction. Also,
Options 3 and 4 would not be likely to achieve any significant
additional SO2 emission reductions over Option 2 for high sulfur kilns
because Option 2 already represents at least a 90 percent emission
reduction control for high sulfur raw materials.

Costs for the use of wet alkaline scrubbers on kilns are based on
detailed cement industry estimates of retrofitting an existing 804,000
ton per year preheater/precalciner kiln with a wet alkaline scrubber
(Zephyr, 2002). The industry cost estimates incorporated costing
procedures from the EPA Air Pollution Control Cost Manual. To adapt the
industry costs to our new 1,200,000 ton per year kiln, costs were scaled
up to account for the difference in exhaust gas flow rates and modified
to reflect installation on a new kiln rather than a retrofit. Costs were
also updated using Chemical Engineering cost index and a credit applied
for the use of the gypsum produced by the scrubber. Scrubbers produce a
slurry containing synthetic gypsum, which can be reused in the
production of portland cement. A scrubber on a 1.2 million ton/yr kiln
is estimated to produce 84,101 ton/yr of gypsum (Docket Item II-B-67,
Docket no. A-92-53). Using current estimates from the United States
Geological Survey (USGS), the price of gypsum was estimated at $8.26 per
ton. Actual costs to purchase gypsum for the production of cement are
probably higher primarily due to transportation costs. Assuming that all
synthetic gypsum can be reused in the production process, each scrubber
has a credit for recycled gypsum of $694,674 per year. 

Input parameters and annual cost inputs used in estimating costs are
shown in Table 9. Total capital investment for a wet alkaline scrubber
installed on a 1,200,000 ton/yr kiln is approximately $28,101,000 and
total annual cost, including annualized capital (using 7% interest and a
20-year equipment life), operating costs, and the recycled gypsum credit
is approximately $4,913,000. Capital and annual cost for a wet alkaline
scrubber on a 1,200,000 ton/yr kiln are shown in Table 10.

Under the proposed amendments, compliance with the emission limits for
SO2 will be determined using continuous emissions monitoring systems.
Continuous flow rate monitors will also be required to determine
compliance. The capital/startup costs for SO2 and flow rate CEMS are
$143,135 and $35,780, respectively. Annual operations and maintenance
costs for SO2 and flow rate CEMS are $42,326 and $13,864, respectively.
All costs are derived from the CEMS Cost Model and include a capital
recovery factor of 0.1424 (equipment life of 10 years and a yearly
interest rate of 7%). Attachment 1 is the output file from the CEMS Cost
Model for SO2 CEMS. Attachment 3 is the output file from the CEMS cost
Model for flow rate CEMS.

Including the cost of CEMS, the annual operating and maintenance cost
per kiln is $4,969,000 and the total capital cost per kiln is
$28,280,000 for alkaline scrubbers. Assuming that four new kilns will
install an alkaline scrubber to comply with the SO2 emission limit, the
total annualized cost of scrubbers is an estimated $19.9 million. Total
capital cost over the 5-year period following promulgation is an
estimated $113 million.

The cost of the alkaline wet scrubber is only dependent on the size of
the kiln so the costs are identical for any control option that would
require the use of alkaline scrubbers, assuming that the scrubber was
operated at its highest efficiency.

The amount of SO2 reduction is based on the alkaline scrubber having a
removal efficiency of 95% and baseline emissions of 7,800 tons for raw
materials with high sulfur content (and high uncontrolled SO2 emissions)
and 780 tons for raw materials with moderate sulfur content (and
moderate uncontrolled SO2 emissions). It is estimated that alkaline wet
scrubbers will result in reductions of 7,410 tpy SO2 for kilns using raw
materials with high sulfur content and 741 tpy SO2 for raw materials
with moderate sulfur content. The resulting cost effectiveness is
approximately $670 per ton of SO2 removed for raw materials with high
sulfur content and $6,700 per ton of SO2 removed for raw materials with
moderate sulfur content.

Because lime injection may be used to reduce SO2 emissions in certain
instances, costs were estimated for a lime injection system for a
1,200,000 ton/yr kiln. Costs are derived from the same source as the wet
scrubber costs (Zephyr 2002). Input parameters and annual cost inputs
used in estimating costs are shown in Table 11. Total capital investment
for lime injection installed on a 1,200,000 ton/yr kiln is approximately
$6,997,000 and total annual cost, including annualized capital (using 7%
interest) and operating costs is approximately $3,168,000. These costs
are shown in Table 12.

Including the cost of CEMS, the annual operating and maintenance cost
per kiln is $3,224,000 and the total capital cost per kiln is $7,176,000
for lime injection.

The amount of SO2 reduction is based on lime injection having a removal
efficiency of 70% and baseline emissions of 780 tons for raw materials
with moderate sulfur content. It is estimated that alkaline wet
scrubbers will result in reductions of 540 tpy SO2 for raw materials
with moderate sulfur content. The resulting cost effectiveness is $5,970
per ton of SO2 removed for raw materials with moderate sulfur content.

Table 13 shows the costs and potential reductions associated with each
of the four options for SO2 control.

Table 9. Wet alkaline scrubber input parameters for new kiln model.

INPUT PARAMETERS:





-- Clinker production rate, tons/yr	1,200,000

-- Process operating hours, hr/yr	7,920

-- Inlet waste gas temperature (oF):	400

-- Inlet waste gas pressure (atm.):	1

-- Pollutant in waste gas:	SO2

-- pollutant emissions, lb/yr	14,475,811

-- pollutant concentration, ppmv	905

-- pollutant molecular weight	64

-- Waste gas molecular weight (lb/lb-mole):	28.85

-- Solvent molecular weight (lb/lb-mole):	18

-- Inlet waste gas flowrate (acfm):	330,276.91

-- Scrubber gas pressure drop (in. water):	17

--Additional system pressure drop (FF and ducts), in. water	10

-- Liquid pressure drop for pump (ft of H2O):	60

-- Slurry flow rate, gpm	19,817

-- Outlet gas temperature, F	140

-- Makeup water flow, gpm	105

-- Limestone consumption, tons/hr	5.4060

-- Estimated control efficiency, percent	95

-- Electricity consumption, kw

	       scrubber and system fans	1105.0



	       limestone preparation	162.2

       cooler vent air to stack	257.4







ANNUAL COST INPUTS:

	Operating factor (hr/yr):	7,920

Operating labor rate ($/hr):	22.5

Maintenance labor rate ($/hr):	24.75

Operating labor factor (hr/sh):	2.5

Maintenance labor factor (hr/sh):	2.5

Electricity price ($/kWhr):	0.062

Limestone, $/ton	5

Solvent (water) price ($/1000 gal):	0.2

Overhead rate (fraction):	0.6

Annual interest rate (fraction):	0.07

Control system life (years):	20

Capital recovery factor (system):	0.0944

Taxes, insurance, admin. factor:	0.04

Credit for gypsum ($/ton)	8.26

Gypsum recycled (tons/yr)	84,101



Table 10. Wet alkaline scrubber capital and annual costs for new kiln
model.

CAPITAL COSTS:

Equipment costs, $

	-- Limestone handling, milling, and emission control	1,079,519

-- Scrubber with fans	5,721,834

-- Scrubber stack	985,427

-- Bypass, preheater, and cooler vent ductwork; cooler	1,909,821

      vent fan and damper

	-- Sludge handling and material disposal system	279,734

-- Building and building permit	1,227,015

-- Contingency (20% of equipment costs)	2,240,670

-- Total (base)	7,081,087

            Chemical Engineering Plant Cost Index September 2002	400.9

            Chemical Engineering Plant Cost Index September 2007	528.2

     '   (escalated)	9,329,584

     Instrumentation (10% of equipment cost)	932,958

     Sales tax (5% of equipment cost)	466,479

     Freight (5% of equipment cost)	466,479

Purchased Equipment Cost (PEC):	11,195,501

Direct installation costs, $

	-- Foundation and supports (12% of PEC)	1,343,460

-- Handling and erection (60% of PEC)	6,717,300

-- Electrical (10% of PEC)	1,119,550

-- Piping (30% of PEC)	3,358,650

-- Insulation and Ductwork (2% of PEC)	223,910

-- Painting (2% of PEC)	223,910

-- Total	12,986,781

Site preparation cost, $	200,000

Indirect installation costs, $

-- Engineering (20% of PEC)	2,239,100

-- Construction and field expenses (5% of PEC)	559,775

-- Contractor fees (5% of PEC)	559,775

-- Start-up (1% of PEC)	111,955

-- Performance test (1% of PEC)	111,955

-- Contingencies (3% of PEC)	335,865

-- Total	3,918,425

Total Capital Investment ($):	28,100,706



Table 10 (continued)

ANNUAL COSTS:

	Operating labor	55,688

Supervisory labor	8,353

Maintenance labor	61,256

Maintenance materials	61,256

Replacement parts (5% of PEC)	559,775

Electricity (fan and pumps)	669,016

Electricity (limestone preparation)	79,656

Limestone	214,079

Solvent (makeup water)	9,950

Overhead	111,932

Taxes, insurance, administrative	1,124,028

Capital recovery	2,652,508

-------------------------------------------------

	Total Annual Cost	5,607,497

Credit for recycled gypsum	694,674

Total Annual Cost w/ gypsum credit	4,912,823



Table 11. Lime injection input parameters for new kiln model.

INPUT PARAMETERS:



	-- Clinker production rate, tons/yr	1,200,000

-- Process operating hours, hr/yr	7,920

-- Pollutant in waste gas:	SO2

-- pollutant emissions, lb/yr	14,475,811

-- pollutant molecular weight	64

-- Solvent molecular weight (lb/lb-mole):	18

-- Liquid pressure drop for pump (ft of H2O):	60

-- Makeup water flow, gal/yr	97,383,410

-- Slurry flow rate, gpm	4,099

-- Slaked lime consumption, tons/yr	25,057

-- Estimated control efficiency, percent	60

-- Electricity consumption, kw	66.0



	ANNUAL COST INPUTS:



	Operating factor (hr/yr):	7,920

Operating labor rate ($/hr):	22.5

Maintenance labor rate ($/hr):	24.75

Operating labor factor (hr/sh):	2.5

Maintenance labor factor (hr/sh):	2

Electricity price ($/kWhr):	0.062

Slaked lime, $/ton	65

Solvent (water) price ($/1000 gal):	0.2

Overhead rate (fraction):	0.6

Annual interest rate (fraction):	0.07

Control system life (years):	15

Capital recovery factor (system):	0.1098

Taxes, insurance, admin. factor:	0.04



Table 12. Lime injection capital and annual costs for new kiln model.

CAPITAL COSTS:

Equipment costs, $

-- Limestone handling system (main and bypass)	1,271,519

-- Injection system (main and bypass)	762,911

-- Building permit	190,728

-- Contingency (20% of equipment costs)	445,032

-- Total (base)	2,670,189

            Chemical Engineering Plant Cost Index September 2002	400.9

            Chemical Engineering Plant Cost Index September 2007	528.2

     '   (escalated)	3,518,069

     Instrumentation (10% of equipment cost)	351,807

     Sales tax (5% of equipment cost)	175,903

     Freight (5% of equipment cost)	175,903

Purchased Equipment Cost (PEC):	4,221,683

Direct installation costs, $

-- Foundation and supports (8% of PEC)	337,735

-- Handling and erection (14% of PEC)	591,036

-- Electrical (4% of PEC)	168,867

-- Piping (2% of PEC)	84,434

-- Insulation and Ductwork (1% of PEC)	42,217

-- Painting (1% of PEC)	42,217

-- Total	1,266,505

Site preparation cost, $	200,000

Indirect installation costs, $

-- Engineering (10% of PEC)	422,168

-- Construction and field expenses (5% of PEC)	211,084

-- Contractor fees (10% of PEC)	422,168

-- Start-up (2% of PEC)	84,434

-- Performance test (1% of PEC)	42,217

-- Contingencies (3% of PEC)	126,650

-- Total	1,308,722



	Total Capital Investment ($):	6,996,909



	ANNUAL COSTS:

Operating labor	55,688

Supervisory labor	8,353

Maintenance labor	49,005

Maintenance materials	49,005

Replacement parts (5% of PEC)	211,084

Electricity (pumps)	1,622

Slaked lime	1,628,678

Solvent (makeup water)	19,477

Overhead	97,230

Taxes, insurance, administrative	279,876

Capital recovery	768,223

-------------------------------------------------

	Total Annual Cost	3,168,241

Table 13. Costs of SO2 emission limits for 1,200,000 ton/yr kiln.*

Option	1 

(Baseline)	2

(1.33 lb/ton clinker)	3

(0.4 lb/ton clinker)	4

(0.2 lb/ton clinker)

Capital cost

   	High sulfur

   	Moderate sulfur

   	Low sulfur	

0	

$28,280,000 (WS)

0

0          	

$28,280,000 (WS) 

$7,176,000 (DLS)

0	

$28,280,000 (WS)

$28,280,000 (WS)

0

Annualized cost

   	High sulfur

   	Moderate sulfur

   	Low sulfur	

0	

$4,969,000

0

0	

$4,969,000 

$3,224,000

0	

$4,969,000

$4,969,000

0

Total SO2 reduction 

	High sulfur

 	Moderate sulfur

 	Low sulfur	

0	

7,410 tpy

0

0	

7,410 tpy

540 tpy

0	

7,410 tpy

741 tpy

0

Total Cost Effectiveness 

	High sulfur

	Moderate sulfur

	Low sulfur 	

0	

663 $/ton SO2

0

0	

671 $/ton SO2

5,970 $/ton SO2

0	

671 $/ton SO2

6,706 $/ton SO2

0

* Costs include monitoring costs.

WS = alkaline wet scrubber

DLS = lime injection

G. Summary of Impacts

Environmental and cost impacts for the proposed amendments on a model
plant basis are summarized in Table 14. Nationwide impacts in the 5th
year following promulgation are summarized in Table 15.



Table 14. Cost and environmental impacts of proposed amendments for a
1,200,000 ton/yr kiln.

Pollutant	Cost ($)*	Emission Reduction (tpy)	Secondary Impacts

	Capital	Annual

Increase in electricity demand (kWh/yr)	Increase in water usage (gpy)
Increase in solid waste (tpy)	Increase in emissions of NOx (tpy)
Increase in emissions of CO (tpy)	Increase in emissions of SO2 (tpy)
Increase in emissions of PM10 (tpy)

NOx	2,289,000	1,268,000	600	Negligible	0	0	0	0	0	0

PM	1,428,000	211,000	44.4	Negligible	0	44.4	0	0	0	0

SO2	28,280,000	4,969,000	7,410	12,075,355	97,000,000	84,101	26.9	13.9
46.2	1.4

*Includes monitoring costs.

Table 15. Nationwide cost and environmental impacts of proposed
amendments.

Pollutant	Cost ($)*	Emission Reduction (tpy)	Secondary Impacts

	Capital	Annual

Increase in electricity demand (kWh/yr)	Increase in water usage (gpy)
Increase in solid waste (tpy)	Increase in emissions of NOx (tpy)
Increase in emissions of CO (tpy)	Increase in emissions of SO2 (tpy)
Increase in emissions of PM10 (tpy)

NOx	45,800,000	25,400,000	12,000	Negligible	0	0	0	0	0	0

PM	28,600,000	4,200,000	890	Negligible	0	890	0	0	0	0

SO2	113,000,000	19,900,000	29,640	48,301,000	388,000,000	336,400	108	56
185	5

TOTAL	187,400,000	49,500,000









*Includes monitoring cost.H. References

Bahner, M. 2007. Review of Three BACT Analyses. October 10, 2007. 

Bahner, M. 2008a. Review and Analysis of NOx Data for Four Cement Kilns.
April 1, 2008.

Bahner, M. 2008b. Analysis of Particulate Matter Test Results:  2003
Survey, and Florida Kilns. March 31, 2008.

Bahner, M. 2008c. Summary of Cement Kiln Wet Scrubber and Lime Injection
Design and Performance Data. May 2, 2008.

M. Bahner, and M. Laney 2008. Summary of Cement Kiln Wet Scrubber and
Lime Injection Design and Performance Data, May 2, 2008.

CEMS Cost Model. CEMS.XLS.   HYPERLINK
"http://www.epa.gov/ttn/emc/cem.html" 
http://www.epa.gov/ttn/emc/cem.html . Accessed March, 2008.

Heath, E. 1996. Summary of Inputs of Control Options on Model Kilns and
Clinker Cooler. Docket Item II-B-67, Docket A-92-53. April 19, 1996. 

Florida Department of Environmental Protection (FL DEP). 2005. Technical
Evaluation Preliminary Determination Draft BACT Determinations Sumter
Cement Company, Sumter County, Florida, New Portland Cement Plant. DEP
File No. 1190041-001-AC (PSD-FL-358). Available at:   HYPERLINK
"http://www.dep.state.fl.us/air/permitting/construction/sumter/TEPD358.p
df" 
http://www.dep.state.fl.us/air/permitting/construction/sumter/TEPD358.pd
f . 

Laney, M., D. Green and K Barnett 2006. Summary of Environmental and
Cost Impacts of Final Amendments to Portland Cement NESHAP, December 8,
2006, Docket item EPA-HQ-OAR-2002-0051-1891.

Northeast States for Coordinated Air Use Management (NESCAUM) in
Partnership with the Mid-Atlantic/Northeast Visibility Union. 2005.
Assessment of Control Technology Options for BART-Eligible Sources.
Steam Electric Boilers, Industrial Boilers, Cement Plants and Paper and
Pulp Facilities. March 2005.

Portland Cement Association. 2006. Capacity Expansion Estimates. October
13, 2006.

Portland Cement Association. 2007. U.S. and Canadian Portland Cement
Industry Plant Information Summary December 31, 2006.

U.S. Environmental Protection Agency (EPA), 2007. Alternative Control
Technologies Document Update - NOx Emissions from New Cement Kilns,
November 2007.

US EPA. EPA Air Pollution Cost Control Manual: Sixth Edition: Section 6:
Particulate Matter Controls: Chapter 1: Baghouses and Filters. Document
Number EPA/452/B-02-001. December 1998.

U. S. Environmental Protection Agency 2002. Office of Air Quality
Planning and Standards. EPA Air Pollution Control Cost Manual, Sixth
Edition, EPA/452/B-02-001. January 2002.

U. S. Environmental Protection Agency, Office of Atmospheric Programs.
Output-Based Regulations: A Handbook for Air Regulators. August, 2004.

United States Geological Survey. USGS 2006 Minerals Yearbook. Gypsum.
Nov. 2007.

Zephyr Environmental Corporation. PSD Application for Lehigh Mason City.
September 2002.

Attachment 1

SO2 Monitor Cost

Output from the EPA CEMS Cost Model

Attachment 1

Summary of CEMS











Analyzers

BEFORE	AFTER

	   CO

0	0

	   SO2

0	1

	   NOX

0	0

	   HCl

0	0

	   Mercury (and CO2/O2)

0	0

	   CO2

0	0

	   O2

0	0

	   THC

0	0







	Monitors





   OPACITY

0	0

	   FLOW

0	0

	   PM (beta gauge)

0	0

	   PM (light scattering; insitu)

0	0

	   PM (light scattering; extractive)

0	0







	Bag leak detector





   Number of fabric filters to be monitored=

0	0

	   Number of sensors=

0	0







	Summary of Costs











First Costs	Labor	Test	ODCs	Total

    Planning	2,534	0	352	2,886

    Select Equipment	10,941	0	3,067	14,008

    Support Facilities	0	0	19,065	19,065

    Purchase CEMS Hardware	0	0	64,978	64,978

    Install and Check CEMS	4,818	0	11,979	16,797

    Performance Specification Tests	2,129	7,526	503	10,157

    QA/QC Plan	2,570	11,981	692	15,244

	22,993	19,507	100,635	143,135







Annual Costs





    Day-to-Day Activities	5,532	0	1,000	6,532

    Annual RATA	885	7,156	0	8,041

    PM Monitor RCA	0	0	0	0

    PM Monitor RRA	0	0	0	0

    Cylinder Gas Audits (ACA/SVA for PM)	1,284	0	1,069	2,353

    Recordkeeping and Reporting	1,253	0	160	1,413

    Annual QA & O&M Review and Update	2,074	0	1,530	3,604

    Capital Recovery	3,274	2,778	14,330	20,382







    Total w/o capital recovery	11,029	7,156	3,759	21,944

    Total with capital recovery	14,303	9,934	18,089	42,326



Attachment 2

NOx Monitor Cost

Output from the EPA CEMS Cost Model

Attachment 2

Summary of CEMS











Analyzers

BEFORE	AFTER

	   CO

0	0

	   SO2

0	0

	   NOX

0	1

	   HCl

0	0

	   Mercury (and CO2/O2)

0	0

	   CO2

0	0

	   O2

0	0

	   THC

0	0







	Monitors





   OPACITY

0	0

	   FLOW

0	0

	   PM (beta gauge)

0	0

	   PM (light scattering; insitu)

0	0

	   PM (light scattering; extractive)

0	0







	Bag leak detector





   Number of fabric filters to be monitored=

0	0

	   Number of sensors=

0	0







	Summary of Costs











First Costs	Labor	Test	ODCs	Total

    Planning	2,534	0	352	2,886

    Select Equipment	10,941	0	3,067	14,008

    Support Facilities	0	0	19,065	19,065

    Purchase CEMS Hardware	0	0	62,794	62,794

    Install and Check CEMS	4,818	0	11,979	16,797

    Performance Specification Tests	2,129	7,526	502.5	10,157

    QA/QC Plan	2,570	11,981	692	15,244

	22,993	19,507	98,451	140,951







Annual Costs





    Day-to-Day Activities	5,532	0	1,000	6,532

    Annual RATA	885	7,156	0	8,041

    PM Monitor RCA	0	0	0	0

    PM Monitor RRA	0	0	0	0

    Cylinder Gas Audits (ACA/SVA for PM)	1,284	0	1,069	2,353

    Recordkeeping and Reporting	1,253	0	160	1,413

    Annual QA & O&M Review and Update	2,074	0	1,324	3,398

    Capital Recovery	3,274	2,778	14,019	20,071







    Total w/o capital recovery	11,029	7,156	3,553	21,738

    Total with capital recovery	14,303	9,934	17,572	41,809



Attachment 3

Flow Rate Monitor Cost

Output from the EPA CEMS Cost Model

Attachment 3

Summary of CEMS











Analyzers

BEFORE	AFTER

	   CO

0	0

	   SO2

0	0

	   NOX

0	0

	   HCl

0	0

	   Mercury (and CO2/O2)

0	0

	   CO2

0	0

	   O2

0	0

	   THC

0	0







	Monitors





   OPACITY

0	0

	   FLOW

0	1

	   PM (beta gauge)

0	0

	   PM (light scattering; insitu)

0	0

	   PM (light scattering; extractive)

0	0







	Bag leak detector





   Number of fabric filters to be monitored=

0	0

	   Number of sensors=

0	0







	Summary of Costs











First Costs	Labor	Test	ODCs	Total

    Planning	806	0	0	806

    Select Equipment	1,709	0	293	2,002

    Support Facilities	0	0	1,000	1,000

    Purchase CEMS Hardware	0	0	19,080	19,080

    Install and Check CEMS	1,037	0	690	1,727

    Performance Specification Tests	77	440	0	517

    QA/QC Plan	2,306	7,650	692	10,647

	5,934	8,090	21,755	35,780







Annual Costs





    Day-to-Day Activities	691	0	0	691

    Annual RATA	0	0	0	0

    PM Monitor RCA	0	0	0	0

    PM Monitor RRA	0	0	0	0

    Cylinder Gas Audits (ACA/SVA for PM)	0	0	0	0

    Recordkeeping and Reporting	5,448	0	40	5,488

    Annual QA & O&M Review and Update	1,409	0	1,180	2,589

    Capital Recovery	845	1,152	3,098	5,095







    Total w/o capital recovery	7,548	0	1,220	8,768

    Total with capital recovery	8,394	1,152	4,318	13,864



Attachment 4

Bag Leak Detector Cost

Output from the EPA CEMS Cost Model

Attachment 4

Summary of CEMS





Analyzers

BEFORE	AFTER

	   CO

0	0

	   SO2

0	0

	   NOX

0	0

	   HCl

0	0

	   Mercury (and CO2/O2)

0	0

	   CO2

0	0

	   O2

0	0

	   THC

0	0







	Monitors





   OPACITY

0	0

	   FLOW

0	0

	   PM (beta gauge)

0	0

	   PM (light scattering; insitu)

0	0

	   PM (light scattering; extractive)

0	0







	Bag leak detector





   Number of fabric filters to be monitored=

0	2

	   Number of sensors=

0	10







	Summary of Costs











First Costs	Labor	Test	ODCs	Total

    Planning	1,711	0	352	2,063

    Select Equipment	6,346	0	643	6,989

    Support Facilities	0	0	3,950	3,950

    Purchase CEMS Hardware	0	0	66,568	66,568

    Install and Check CEMS	484	0	12,927	13,411

    Performance Specification Tests	0	0	0	0

    QA/QC Plan	739	0	0	739

	9,279	0	84,440	93,719







Annual Costs





    Day-to-Day Activities	2,822	0	0	2,822

    Annual RATA	0	0	0	0

    PM Monitor RCA	0	0	0	0

    PM Monitor RRA	0	0	0	0

    Cylinder Gas Audits (ACA/SVA for PM)	0	0	0	0

    Recordkeeping and Reporting	946	0	0	946

    Annual QA & O&M Review and Update	384	0	17,250	17,634

    Capital Recovery	1,321	0	12,024	13,346







    Total w/o capital recovery	4,152	0	17,250	21,402

    Total with capital recovery	5,473	0	29,274	34,748



Attachment 5

Statistical Analyses of Cement Kiln PM Data 

PH/PC Kilns built since 1997-Fabric Filters with Membrane Bags

Attachment 5

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Kiln, December 5, 2003	0.00072	12.72	0.0092

Ash Grove, Chanute	Kiln, September 8, 2004	0.0022	12.72	0.0280

Ash Grove, Chanute	Kiln, September 9, 2004	0.0007	12.72	0.0089

Ash Grove, Chanute	Kiln, November 15, 2005	0.0074	12.72	0.0941

Ash Grove, Chanute	Kiln, November 15, 2005	0.008	12.72	0.1018

Ash Grove, Chanute	Kiln, November 15, 2005	0.0026	12.72	0.0331

Ash Grove, Chanute	Kiln, November 16, 2005	0.0042	12.72	0.0534

Ash Grove, Chanute	Kiln, November 16, 2005	0.0031	12.72	0.0394

Ash Grove, Chanute	Kiln, November 16, 2005	0.0032	12.72	0.0407

Ash Grove, Chanute	Kiln, November 17, 2005	0.0025	12.72	0.0318

Ash Grove, Chanute	kiln, November 17, 2005	0.001	12.72	0.0127

Ash Grove, Chanute	Kiln, November 17, 2005	0.0016	12.72	0.0204

Lehigh Cement, Union Bridge, MD	Kiln (Mill On)

	0.0023

Lehigh Cement, Union Bridge, MD	Kiln (Mill Off)

	0.0045

Lafarge Cement, Sugar Creek, MO	Kiln (Mill On)

	0.0046

Lafarge Cement, Sugar Creek, MO	Kiln (Mill Off)

	0.0317

Holcim, Devil's Slide, UT	Kiln, Mill On (October 2002)

	0.0391

Holcim, Devil's Slide, UT	Kiln, Mill Off (October 2002)

	0.0584









	Minumim	0.0023



	Maximum	0.10176



	Average	0.035732126



	Standard Deviation	0.028721542



	99th Percertile	0.102538433



	95th Percentile	0.082979063



	Median	0.0318



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May 29, 2008

May 14, 2008

