Date: November 6, 2014 To: Jeff Telander, EPA/OAQPS/SPPD From: Thomas Holloway, RTI International 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 emission standards for hazardous air pollutants (NESHAP) on May 16, 2003 for the brick and structural clay products (BSCP) manufacturing industry. The NESHAP regulated emissions of hydrogen fluoride (HF), hydrogen chloride (HCl), and particulate matter (PM) -- a surrogate for hazardous air pollutant (HAP) metals -- from tunnel kilns located at BSCP facilities. On March 13, 2007, the D.C. Circuit Court vacated the emission standards for BSCP manufacturing due to issues associated with the methodology used to determine the minimum regulatory "floors" for new and existing units. Therefore, the EPA is proposing new standards for BSCP manufacturing, including standards for HF, HCl, chlorine (Cl2), mercury (Hg), and non-Hg HAP metals (or PM surrogate). The purpose of this memorandum is to present the methodology and assumptions used in estimating the model costs and environmental and energy impacts for the control 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 control devices (SCD), reflecting the size subcategories of the BSCP NESHAP, which are based on a kiln capacity threshold of 10 tons per hour (tph). The model costs and impacts were estimated based on a variety of model parameters -- (1) general parameters such as production rate, operating hours, gas flow rate, electricity and waste disposal unit costs, labor wage rates, and uncontrolled emissions; and (2) control-specific parameters such as control device horsepower (hp) requirements, sorbent requirements, and sorbent unit cost. This section discusses the basis for the general model parameters, which are presented in Appendix A at the end of this memorandum. The model production rates (in tph) and operating hours (in hours per year [hr/yr]) were based on data from the BSCP inventory (Holloway, 2014). The BSCP inventory is a combination of (1) industry responses to the 2008 BSCP section 114 survey; (2) responses to a survey similar to the 2008 BSCP section 114 survey that was administered 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 production rate (7.0 tph) and operating hours (7,300 hr/yr) for the small model were calculated from those tunnel 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 were calculated from those tunnel kilns 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 operating hours from industry responses to the 2008 BSCP survey (Holloway, 2014) and facility operating hours from the 2003 BSCP database for those facilities not included in the 2008 survey. Since the kiln is the center of the production process at the BSCP facility, it is reasonable 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), with 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 those cases where flow rate data were only available in units of dry standard cubic feet per minute (dscfm), those flow rates were converted to units of acfm using Equation 1 below, 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 	 where: 	Qacfm =	exhaust flow rate (acfm), 	Qdscfm =	exhaust flow rate (dscfm), 	Tstack =	stack temperature (converted from degrees Fahrenheit [°F] to degrees Rankine [°R]), 	Tstandard =	standard temperature (528°R), and 	% H2O =	moisture content (percent [%]). Unit costs for electricity ($0.073/kilowatt-hour [kWh]) and waste disposal ($40/ton waste) were based on the average of those unit costs from the 2008 BSCP survey responses (Holloway, 2014). The operator wage rate ($22.67/hr) was based on mean hourly wage data from the May 2011 Bureau of Labor Statistics for NAICS 327100 (Clay Product and Refractory Manufacturing) for an Industrial Engineering Technician (BLS, 2012). Wage rates from the Bureau of Labor Statistics were used because they were more conservative than those provided by BSCP survey respondents. The maintenance wage rate ($24.94/hr) was assumed to be 10 percent higher than the operator wage rate, similar to the ratio of maintenance to operator wage rates provided by one BSCP company in its response to the 2008 survey (Holloway, 2014). The capital recovery factor (0.0944) was calculated using Equation 2 below, assuming a 7 percent interest rate and 20-year equipment life for the control devices expected to be used to comply with the new standards for BSCP manufacturing: Equation 2 -- Capital recovery factor: 	 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 interest were HF, HCl, chlorine (Cl2), PM, HAP metals, and sulfur dioxide (SO2). The model uncontrolled emissions estimates for HF, HCl, PM, Cl2, and SO2 were based on the average of uncontrolled emissions data from BSCP stack tests (Raymond, 2014). The model uncontrolled emissions estimate for total 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 assumptions used to estimate the model costs for the new or retrofit emission control devices that BSCP facilities are expected 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 and 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 conservative estimate. The operating costs for control devices to be replaced have not been subtracted out.) Dry sorbent injection/fabric filter (DIFF). Dry sorbent injection followed by a fabric filter (DIFF) can be used to reduce emissions of both particulates and acid gases from BSCP tunnel kilns. This type of control system is already in use in the BSCP industry (Holloway, 2014) and is expected to be installed on uncontrolled kilns or retrofitted to replace less efficient kiln controls to enable facilities to comply with the new BSCP standards. The DIFF costs were estimated using the cost algorithms from the original BSCP rulemaking (Shrager, 2003), which were generated following guidelines in the OAQPS Control Cost Manual (EPA, 2002). The algorithms were updated to include more recent model parameters, including the general parameters discussed previously 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 [ft2]) Compressed air (0.9 cubic feet [ft3] of compressed air/1,000 ft3 of gas) Time to replace bags (2.25 hr/bag) Hydrated lime unit cost ($160/ton) Bag fabric cost ($8.15/ft2) Compressed air unit cost ($0.24/1,000 ft3) Bag capital recovery factor (0.244, based 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 (Holloway, 2014). The DIFF control efficiencies and stoichiometric ratios of hydrated lime were determined 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 available stack tests with control efficiency data) (Raymond, 2014). For example, the baseline HF control 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 (Holloway, 2014), average uncontrolled emissions data from stack 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 efficiencies (99.5 percent/98 percent). The model DIFF capital costs were estimated by taking DIFF capital cost data from industry responses to the 2008 BSCP survey (Holloway, 2014), escalating the costs to 2011 dollars using the Chemical Engineering Plant Cost Index (CEPCI) (CE, 2011), scaling the costs to the large and small model sizes using the six-tenths cost rule (see Equation 3 below), taking the average of the scaled costs for each model size, and rounding the results to three significant figures. Equation 3 -- Six-tenths cost rule: 	 where: 	C =	capital cost and 	Q =	capacity parameter (e.g., exhaust gas flow rate). For retrofits, the capital costs were further adjusted using a retrofit 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 assumed $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 ft3/1,000 ft3 compressed air requirements and $0.24/1,000 ft3 compressed air unit cost) Replacement bags (estimated based on 3.4 ft/min gas-to-cloth ratio, $8.15/ft2 bag fabric, and 0.244 bag capital recovery factor) Bag replacement labor (estimated based on 3.4 ft/min gas-to-cloth ratio, 28 ft2 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 administrative charges (estimated at 4% of total capital cost) Capital recovery (estimated as the product of a 0.0944 capital recovery factor and total capital cost, minus the cost of capital recovery for replacement bags and bag replacement labor) Fabric filter. Fabric filters can be used to reduce emissions of particulates from BSCP tunnel kilns at plants that already have acid gas control or have 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 control tunnel kiln emissions, although DIFF are used to control emissions from the larger tunnel kilns (Holloway, 2014). The BSCP industry has expressed the following concerns about using stand-alone fabric filters (Holloway, 2013b): Without the dry lime injection that reduces the acid gas, there will not be enough particulates in the kiln exhaust to coat the bags and get good performance from the fabric filter. The uncontrolled acid in the exhaust stream could rot the bags. The exhaust gas temperatures from BSCP 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 contacted two major fabric filter vendors -- Solios Environment and McGill AirClean -- and a major filter bag vendor -- W.L. Gore & Associates -- to determine the feasibility of using stand-alone fabric filters in the BSCP industry. A representative from one of the fabric filter vendors (Solios Environment) agreed with industry concerns that that the lack of a dust cake would negatively impact total outlet emissions and that the dust cake serves an important function 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 degrades 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 significant price premium. He indicated that Aramid, Ryton, and P-84 fabrics are generally limited to 400°F operation, but noted that these fabrics are sensitive to degradation not only by the acid gases but also the relatively high oxygen concentration 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 stand-alone baghouse to control just filterable particulate 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 bags with an expanded PTFE membrane could be used. He noted that membrane bags usually control outlet particulate 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 fiberglass, so scrubbing would be a good idea, depending on the amount of HF present. He said that acid gases in moderate concentrations usually do not cause fabric degradation if the bags are continuously operated above the acid gas dewpoints. Regarding operating temperatures 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 flue gas cooling using a dry-bottom evaporative cooler or a gas-to-air heat exchanger to reduce the gas temperature to a level where conventional fabrics could be used safely (Childress, 2013b). 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) high-temperature fiberglass bags, and (2) high-temperature 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 loadings as low as 1 to 2 grains per cubic foot. He noted that HF destroys fiberglass, so PTFE bags would be needed if HF emissions are a concern. He noted that PTFE bags, unlike fiberglass 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 exhaust gas temperatures are not too high. 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 for waste disposal that excludes any acid gas control. Activated carbon injection (ACI). Injecting activated 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, industrial 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 control performance achieved in these other industries, we believed it prudent to explore this control technology as an option to reduce the mercury emissions from the BSCP industry. To obtain information on the feasibility and cost of adding an ACI system to an existing DIFF control system for BSCP kilns, we first contacted a fabric filter vendor, McGill AirClean. While a representative from the vendor indicated that his company does not have data on control of mercury emissions from BSCP kilns (all of the 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 require 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 Norit 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 company 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, for applications using baghouses (e.g., a DIFF), an activated carbon feed rate of 0.5 to 3 pounds per million actual cubic feet (lb/MMacf) is typical; he suggested using 2 lb/MMacf as a baseline (Thompson, 2013). The model ACI costs for BSCP kilns were estimated 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 replacement standards (EPA, 2005), using the general parameters discussed in the previous section and the carbon injection rate (2 lb/MMacf [Thompson, 2013]) and carbon unit cost (average of $0.85/lb [Holloway, 2013a]) from the ACI vendor. To determine 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 costs, indirect costs of engineering, construction and field expense, contractor fees, startup, performance test, model study, and contingencies were also estimated (EPA, 2005). The model ACI annual costs were also estimated based on the aforementioned cost algorithms (EPA, 2005) and include the following cost items: Operating labor (assumed based 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 requirements, 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 administrative charges (estimated at 4% of total capital cost) Capital recovery (estimated as the product 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 installing control equipment such as a DIFF to meet the new BSCP standards, some BSCP facilities may choose to install less expensive DLA systems on one or more of their uncontrolled tunnel kilns to reduce facility emissions below the threshold for major sources of HAP -- 10 tons per year (tpy) or more of any single HAP or 25 tpy or more of any combination of HAP. By obtaining 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 major source BSCP NESHAP. Only those BSCP facilities that would be impacted under the new BSCP 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 uncontrolled tunnel kilns. Dry limestone adsorbers are designed to control HF emissions and also provide limited control of HCl and Cl2 emissions. The systems do not provide 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 (Holloway, 2014). The DLA costs were estimated using the cost algorithms from the original BSCP rulemaking (Shrager, 2003), which were generated following guidelines in the OAQPS Control Cost Manual (EPA, 2002). The algorithms were 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 tests (Raymond, 2014), while the values of the other model DLA parameters were determined based on averages of industry responses to the 2008 BSCP survey (Holloway, 2014). The model DLA capital costs were estimated by taking DLA capital cost data from industry responses to the 2008 BSCP survey (Holloway, 2014), escalating the costs to 2011 dollars using the CEPCI (CE, 2011), scaling the costs to the large and small model sizes using the six-tenths cost rule (see Equation 3), taking the average of the scaled costs for each model size, and rounding the results to three 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 assumed $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 administrative charges (estimated at 4% of total capital cost) Capital recovery (estimated as the product of a 0.0944 capital recovery factor and total capital cost) Summary. Table 1 presents the model costs for 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. 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 assumptions 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 calculations are presented in Appendix D. The model impacts tables for new and retrofit control 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, Cl2, and HAP metals) and non-HAP (PM and SO2). In most cases, we were able to determine the model emission reductions (tpy) by multiplying the model uncontrolled emission factors (lb/ton) in Appendix A by the model production rate (tph) and operating hours (hr/yr) in Appendix A and the appropriate control 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 thermal units per year [MMBtu/yr]) needed to generate this electricity was then determined by dividing the electricity requirements (kWh/yr) by the nationwide average power plant efficiency (35 percent) and multiplying by a conversion factor of 3,415 British thermal units per kilowatt hour (Btu/kWh). 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/kWh 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 efficiencies, based on the projected fuel mix for 2015 from Version 3.0 of EPA's Integrated Planning Model (IPM), which is a forecast model of the U.S. electric power sector (EPA, 2011). The projected 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 (NOX), and SO2 -- 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 generate the needed electricity. (EPA, 2011) We used a variety of information sources to obtain the emission factors used to estimate the secondary emissions. For natural gas combustion, we used emission factors (in pounds per cubic foot [lb/ft3] of natural gas) from the AP-42 chapter on natural gas combustion to estimate the secondary emissions for PM, CO, NOX, and SO2 (EPA, 1998a). We used the AP-42 conversion factor of 1,020 Btu/ft3 of natural gas to convert the 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 SO2 (EPA, 2006). We used emission factors (in lb/ton coal) from the AP-42 chapter on coal combustion to estimate the secondary emissions for NOX and CO; we specifically used the AP-42 emission factors for bituminous/subbituminous coal combustion/spreader stokers (EPA, 1998b). The NOX emission factor was based on an average of the AP-42 emission factors for spreader 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 NOX and CO from coal (EPA, 1998b). All secondary air impacts were attributed to the combustion of coal, natural gas, or "other" fuels at offsite power plants. We attributed 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. D.	Solid Waste and Wastewater Impacts We estimated the solid waste impacts by calculating the amount of material captured by the control device. The material captured by the fabric 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 control 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 stand-alone fabric filter (which captures only PM) or a DLA (which captures mostly acid gases, primarily HF). We estimated the wastewater impacts associated with using a spray dryer/ESP by calculating the amount of water usage for the spray 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 following control scenarios and are presented in the appendix tables cited below: Installation of new DIFF on uncontrolled kiln (see Table E-1) Installation of new fabric filter on uncontrolled 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 uncontrolled 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 F1) Replacement of existing DLA with a new DIFF (see Table F-2) Replacement of existing spray dryer/ESP 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 impacts associated with new controls. For DLA and spray dryer/ESP controls being replaced with a DIFF, the incremental impacts include the emission reductions, energy impacts, secondary air impacts, solid waste impacts, and wastewater impacts (spray dryer/ESP 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 associated secondary emissions, but we estimated the difference in emissions and solid waste impacts that would accompany the improved control of PM and acid gases. Because we had no control efficiency data for spray dryer/electrostatic precipitator (ESP), we used stack test data for the kilns equipped with this emission control as the baseline emissions and subtracted the baseline emissions for the DIFF to determine the incremental emissions reduction from replacing a spray dryer/ESP with a DIFF. Tables 2 through 4 present the model impacts for the DIFF, fabric filter, and ACI control installation/retrofit options and control replacement options discussed above for the small and large BSCP control devices. For additional information, 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

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

Table 3b. Summary of Model Energy, Solid Waste, and Wastewater Impacts for Control Replacement Options Control option Type of impact Increase in impacts1

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 pollutant1 Secondary air impacts, tpy

SCD LCD Install new DIFF Particulate matter 0.0710 0.0927

PM2.5 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

PM2.5 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

PM2.5 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

PM2.5 0.000765 0.00137

Carbon monoxide 0.00385 0.00688

Nitrogen oxides 0.0306 0.0547

Sulfur dioxide 0.0891 0.159 1 PM2.5 = PM with particles less than 2.5 micrometers in diameter.

Table 4b. Summary of Model Secondary Impacts for Control Replacement Options Control option Secondary pollutant2 Increase in secondary air impacts, tpy1

SCD LCD Replace dry limestone adsorber with new DIFF Particulate matter 0.0434 0.0379

PM2.5 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

PM2.5 -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

PM2.5 0 0

Carbon monoxide 0 0

Nitrogen oxides 0 0

Sulfur dioxide 0 0 1 A negative increase in secondary air impacts would be equivalent to a reduction in secondary air impacts. 2 PM2.5 = PM with particles less than 2.5 micrometers in diameter.

V.	References BLS (U.S. Department of Labor, Bureau of Labor Statistics). 2012. Occupational Employment Statistics: May 2011 National Industry-Specific Occupational Employment and Wage Estimates. NAICS 327100 - Clay Product and Refractory Manufacturing. Industrial Engineering Technician. March 27, 2012. Available at: http://www.bls.gov/oes/2011/may/naics4_327100.htm. 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 Holloway, RTI International. April 18, 2013. Childress, J. 2013b. "RE: From McGill AirClean Web Site." E-mail from Jerry Childress, McGill AirClean LLC, to Thomas Holloway, 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. EPA (U.S. Environmental Protection Agency). 2002. EPA Air Pollution Control Cost Manual. Sixth Edition. Office of Air Quality Planning and Standards, Research Triangle Park, NC. Publication No. EPA/452/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 Response, 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 and 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 with the Base Case and the MATS, 2015 (Thousand GWh). Publication No. EPA-452/R-11-011. December 2011. Hansen, L. 2013. "RE: Question regarding use of fabric filters for brick kilns." E-mail from Lars Hansen, Solios Environment Corp., to Thomas Holloway, RTI International. 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 Childress, McGill AirClean LLC. June 26, 2013. Holloway, T. 2013c. Telephone Contact Summary: Chris Polizzi, W.L. Gore & Associates, Inc. Contacted by Thomas Holloway, RTI International. July 16, 2013. Holloway, T. 2014. Updated BSCP Inventory Database and Documentation. Memorandum from Thomas Holloway, RTI International, to Jeff Telander, EPA/OAQPS/SPPD. November 6, 2014. Raymond, G. 2014. Test Data Used in BSCP Proposed Rule. Memorandum from Gabrielle Raymond, RTI International, to Jeff Telander, EPA/OAQPS/SPPD. November 6, 2014. Shrager, B. 2003. Final Rule: Costs for Air Pollution Control Devices on Kilns. Memorandum from Brian Shrager, RTI International, to Mary Johnson, U.S. Environmental Protection Agency. February 25, 2003. 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 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

SO2 64 64

CaF2 78 78 6

CaCl2 111 111 6

CaSO3 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

Cl2 0.00346 0.00346 2

Non-Hg HAP Metals 0.00356 0.00356 8

PM 0.324 0.324 2

SO2 3.23 3.23 2 Uncontrolled emissions, lb/hr

HF 4.16 8.91 9

HCl 0.566 1.21 9

Cl2 0.0242 0.0519 9

Non-Hg HAP Metals 0.0249 0.0534 9

PM 2.27 4.86 9

SO2 22.6 48.5 9 1. Average from section 114 survey responses. 2. Average from test data. 3. Mean hourly wage, from Bureau of Labor Statistics, May 2011 National Industry-Specific Occupational Employment and Wage Estimates, NAICS 327100, Industrial Engineering Technician. Website: http://www.bls.gov/oes/2011/may/naics4_327100.htm. Wage rates from Bureau of Labor Statistics were used because they are more conservative than those provided by section 114 survey respondents. 4. 10 percent higher than operator rate. 5. Based on equipment life of 20 years and 7 percent interest. 6. Reaction product; CaF2 = calcium fluoride; CaCl2 = calcium chloride; CaSO3 = 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  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

Cl2 89.3% 89.3% 3

Non-Hg HAP Metals 94% 94% 4

PM 94% 94% 1

SO2 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, ft2 28 28 6

Compressed air, ft3/1,000 ft3 0.9 0.9 6

Time to replace bags, hr/bag 2.25 2.25 6

Added cooling air, ft3/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, $/ft2 8.15 8.15 6

Compressed air, $/1,000 ft3 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

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 Cl2 reduction. 4. Assume same as PM. 5. Based on ratio of enhanced HF reduction and baseline SO2 reduction. 6. Average from section 114 survey responses. 7. Assume hydrated lime is 2.65/1.79 times 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. CaF2 (calcium fluoride), CaCl2 (calcium chloride), and CaSO3 (calcium sulfite). 11. Inlet lime minus reacted lime plus reaction products and PM. 12. Pollution Prevention (P2) Pays, NC Division of Pollution 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. 13. Based on equipment life of 5 years and 7 percent interest. 14. Average of costs from section 114 survey responses 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 factor 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.

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, ft2 28 28 3

Compressed air, ft3/1,000 ft3 0.9 0.9 3

Time to replace bags, hr/bag 2.25 2.25 3

Added cooling air, ft3/min 0 0 5 Calculated parameters

Waste, lb/hr 2.1 4.6 6 Cost factors

Bag fabric cost, $/ft2 8.15 8.15 3

Compressed air, $/1,000 ft3 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 section 114 survey responses. 4. Assume 2 times maintenance labor (EPA, 2002). 5. Assume none. 6. Particulate matter. 7. Pollution Prevention (P2) Pays, NC Division of Pollution 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 hospital/medical/infectious waste incinerator (HMIWI) rule. 10. Average of costs from section 114 survey responses scaled using 6/10 rule (based on acfm), 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 factor 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.

Table B-3. Model Costs to Install New DLA Parameters SCD LCD Footnotes Control efficiency, percent

HF 95% 95% 1

HCl 30% 30% 1

Cl2 42% 42% 1

Non-Hg HAP Metals 20% 20% 2

PM 20% 20% 1

SO2 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 section 114 survey responses. 4. Assume 2 times maintenance labor (EPA, 2002). 5. CaF2 (calcium fluoride), CaCl2 (calcium chloride), and CaSO3 (calcium sulfite). 6. Inlet limestone minus reacted limestone plus reaction products and PM. 7. Average of costs from section 114 survey responses scaled using 6/10 rule (based on acfm), escalated to 2011 dollars, and rounded. 8. 15 percent of operator labor. 9. 100 percent of maintenance labor. 10. Based on conversion factor 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 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

Cl2 89.3% 89.3% 3

Non-Hg HAP Metals 94% 94% 4

PM 94% 94% 1

SO2 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, ft2 28 28 6

Compressed air, ft3/1,000 ft3 0.9 0.9 6

Time to replace bags, hr/bag 2.25 2.25 6

Added cooling air, ft3/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, $/ft2 8.15 8.15 6

Compressed air, $/1,000 ft3 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

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 Cl2 reduction. 4. Assume same as PM. 5. Based on ratio of enhanced HF reduction and baseline SO2 reduction. 6. Average from section 114 survey responses. 7. Assume hydrated lime is 2.65/1.79 times 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. CaF2 (calcium fluoride), CaCl2 (calcium chloride), and CaSO3 (calcium sulfite). 11. Inlet lime minus reacted lime plus reaction products and PM. 12. Pollution Prevention (P2) Pays, NC Division of Pollution 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. 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 section 114 survey responses 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 factor 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.

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, ft2 28 28 3

Compressed air, ft3/1,000 ft3 0.9 0.9 3

Time to replace bags, hr/bag 2.25 2.25 3

Added cooling air, ft3/min 0 0 5 Calculated parameters

Waste, lb/hr 2.1 4.6 6 Cost factors

Bag fabric cost, $/ft2 8.15 8.15 3

Compressed air, $/1,000 ft3 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 section 114 survey responses. 4. Assume 2 times maintenance labor (EPA, 2002). 5. Assume none. 6. Particulate matter. 7. Pollution Prevention (P2) Pays, NC Division of Pollution 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 section 114 survey responses scaled using 6/10 rule (based on acfm), 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 factor 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.

Table C-3. Model Costs to Retrofit ACI System to Existing Control Device Parameters MACT Floor Beyond the Floor Footnotes

SCD LCD SCD LCD                                         Design and operating parameters

    Carbon injection rate (lb/MMft3) [CIR] 2 2 3 3 1   Injection blower fan power (hp) [Powerfan] 5.2 8.7 5.2 8.7 2,3

Projected equipment life (yrs) [n] 15 15 15 15 2

Interest rate (%) [i] 7 7 7 7

Calculated parameters

    Carbon feed rate (lb/hr) [CFR] 2.8 4.6 4.2 7.0 4  Cost factors

Carbon unit cost ($/lb) [CC] 0.85 0.85 0.85 0.85 5

Escalation factor [EF] 1.78 1.78 1.78 1.78 2,6,7

Capital recovery factor [CRF] 0.1098 0.1098 0.1098 0.1098 2,8

Retrofit factor [RF] 1.15 1.15 1.15 1.15 2 Direct capital costs

    Purchased equipment costs

      Total equipment [TEC] (see Note) $24,294 $34,864 $24,294 $34,864 2,9     Sales tax $729 $1,046 $729 $1,046 2,10     Freight $1,215 $1,743 $1,215 $1,743 2,11     Purchased equipment with tax and freight $26,238 $37,653 $26,238 $37,653 2,12     Purchased equipment with escalation $46,784 $67,138 $46,784 $67,138 2,13     Purchased equipment with retrofit factor [PEC] $53,802 $77,209 $53,802 $77,209 2,14   Installation cost [IC] $16,141 $23,163 $16,141 $23,163 2,15   Total direct costs [TDC] $69,942 $100,371 $69,942 $100,371 2,16 Indirect capital costs

    Engineering $10,760 $15,442 $10,760 $15,442 2,17   Construction and field expense $10,760 $15,442 $10,760 $15,442 2,17   Contractor fees $5,380 $7,721 $5,380 $7,721 2,18   Start-up $538 $772 $538 $772 2,19   Performance test $538 $772 $538 $772 2,19   Model study $1,076 $1,544 $1,076 $1,544 2,20   Contingencies $3,228 $4,633 $3,228 $4,633 2,21   Total indirect costs [TIC] $32,281 $46,325 $32,281 $46,325 2,22 Total capital cost

Total capital investment [TCI] $102,224 $146,697 $102,224 $146,697 2,23 Annual costs

    Operating labor $6,895 $7,368 $6,895 $7,368 2,24   Supervisory labor $1,034 $1,105 $1,034 $1,105 2,25   Maintenance labor $11,378 $12,157 $11,378 $12,157 2,26   Maintenance materials $2,690 $3,860 $2,690 $3,860 2,27

Electricity cost $2,298 $4,108 $2,298 $4,108 2,28

Carbon cost $17,374 $30,498 $26,061 $46,410 2,29

Solid waste disposal cost $409 $718 $613 $1,092 2,30

Overhead $13,198 $14,694 $13,198 $14,694 2,31   Administrative charges $2,044 $2,934 $2,044 $2,934 2,32   Property tax $1,022 $1,467 $1,022 $1,467 2,33   Insurance $1,022 $1,467 $1,022 $1,467 2,33   Capital recovery $11,224 $16,107 $11,224 $16,107 2,34 Total annual cost $70,589 $96,482 $79,480 $112,768 2,35 Note: 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 $0.85/lb. 6. Escalating costs from 2004 (HWC) to 2011 (BSCP) using the following factors: (HWC escalation factor, 1.1319 x 1.064) x (BSCP escalation factor, 1.4805). 7. Chemical Engineering Plant Cost Index. 8. Equal to = [i x (1 + i)n] / [(1 + i)n - 1], where i = 7 percent interest and n = 15-year equipment life. 9. Equal to 90,000 x (exhaust flow/150,000)0.7. 10. Equal to 0.03 x TEC. 11. Equal to 0.05 x TEC. 12. Equal to TEC + (sales tax) + (freight). 13. Equal to EF x (purchased equipment with tax and freight). 14. Equal to RF x (purchased equipment with escalation). 15. Equal to 0.3 x PEC. 16. Equal to PEC + IC. 17. Equal to 0.2 x PEC. 18. Equal to 0.1 x PEC. 19. Equal to 0.01 x PEC. 20. Equal to 0.02 x PEC. 21. Equal to 0.06 x PEC. 22. Equal to sum of indirect costs. 23. Equal to TDC + TIC. 24. Equal to (1 hr/d) x operating hr/yr / (24 hr/d) x operator wage rate ($/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 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 (HCelec) 3,415 Btu/kWh Heat rate

   Coal (HRcoal) 10,415 Btu/kWh    Natural gas (HRgas) 8,185 Btu/kWh    Nuclear power (HRnuclear) 10,452 Btu/kWh    Renewable energy (HRrenew) 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 (Ecoal) 33% % = HCelec / HRcoal * 100 Natural gas/other (Egas) 42% % = HCelec / HRgas* 100 Nuclear (Enuclear) 33% % = HCelec / HRnuclear * 100 Renewable/hydroelectric (Erenew) 35% % = HCelec / HRrenew * 100 Average (Eavg) 35% % = (Ecoal x % coal) + (Egas x % gas/other) + (Enuclear x % nuclear) + (Erenew 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 (HCelec) x (MMBtu/1E6 Btu) / Eavg Secondary emissions Emission factors, natural gas

Particulate matter/PM2.5   1.9 lb/MM ft3 natural gas

0.00186275 lb/MMBtu natural gas Carbon monoxide 84 lb/MM ft3 natural gas

0.0824 lb/MMBtu natural gas Nitrogen oxide 100 lb/MM ft3 natural gas

0.0980 lb/MMBtu natural gas Sulfur dioxide 0.6 lb/MM ft3 natural gas

0.00059 lb/MMBtu natural gas Emission factors, solid fuel

Particulate matter 0.03 lb/MMBtu solid, liquid, gaseous fuel PM2.5 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 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 for 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, deterministic linear programming model of the U.S. electric power sector that provides forecasts of least-cost capacity expansion, electricity dispatch, and emission control strategies for meeting energy demand and environmental, transmission, dispatch, and reliability constraints. 3. For natural gas, used PM, CO, NOX, and SO2 emission factors from AP-42 chapter on natural gas combustion. Assumed 1,020 Btu/ft3 of natural gas in estimating PM, CO, NOX, and SO2 secondary emissions. Also assumed that 100% of PM is PM2.5, 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 SO2 emission limits for solid fuel-fired boilers from 2006 CFR edition of NSPS for electric utility plants (40 CFR part 60, subpart Da) and used NOX and CO emission factors from AP-42 chapter on coal combustion (bituminous/subbituminous coal). The NOX emission factor was based on average of NOX 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 NOX and CO secondary emissions. According to AP-42, the percentage of PM that is PM2.5 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 Table E-1. Model Impacts of Installing New DIFF Parameters SCD LCD Control efficiency

HF 99.5% 99.5%

HCl 83.3% 83.3%

Cl2 89.3% 89.3%

Non-Hg HAP metals 94% 94%

PM 94% 94%

SO2 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

Cl2 0.0789 0.181

Non-Hg HAP metals 0.0855 0.196

PM 7.78 17.8

SO2 40.2 92.1 Energy impacts, MMBtu/yr 9,620 12,563 Secondary air impacts, tpy

Particulate matter 0.0710 0.0927

PM2.5 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

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

PM2.5 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

Table E-3. Model Impacts of Installing New DLA Parameters SCD LCD Control efficiency

HF 95% 95%

HCl 30% 30%

Cl2 42% 42%

Non-Hg HAP metals 20% 20%

PM 20% 20%

SO2 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

Cl2 0.0371 0.0850

Non-Hg HAP metals 0.0182 0.0417

PM 1.65 3.79

SO2 9.90 22.7 Energy impacts, MMBtu/yr 3,741 7,424 Secondary air impacts, tpy

Particulate matter 0.0276 0.0548

PM2.5 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 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

PM2.5 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

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%

Cl2 42% 89.3%

42% 89.3%

Non-Hg HAP metals 20% 94%

20% 94%

PM 20% 94%

20% 94%

SO2 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

Cl2 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

SO2 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

PM2.5 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

Table F-3. Model Impacts of Replacing Spray Dryer/ESP with New DIFF Parameters SCD LCD

SD/ESP1 DIFF Increm.2 SD/ESP1 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

Cl2 -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

SO2 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

PM2.5 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 efficiency information for SD/ESP. 2 A negative increase in impacts would be equivalent to a reduction in impacts.

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%

Cl2 88% 89.3%

88% 89.3%

Non-Hg HAP metals 72% 94%

72% 94%

PM 72% 94%

72% 94%

SO2 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

Cl2 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

SO2 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

PM2.5 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


[Federal Register Volume 76, Number 216 (Tuesday, November 8, 2011)]
[Notices]
[Pages 69299-69300]
[FR Doc No: 2011-28900]

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SECURITIES AND EXCHANGE COMMISSION

Submission for OMB Review; Comment Request

Upon Written Request, Copies Available From: Securities and Exchange
Commission, Office of Investor

Education and Advocacy, Washington, DC 20549-0213.

Extension:
    Rule 17a-7; SEC File No. 270-238; OMB Control No. 3235-0214.

    Notice is hereby given that, pursuant to the Paperwork Reduction
Act of 1995 (44 U.S.C. 3501-3520), the Securities and Exchange
Commission (``Commission'') has submitted to the Office of Management
and Budget a request for extension of the previously approved
collection of information described below.
    Rule 17a-7 (17 CFR 270.17a-7) (the ``rule'') under the Investment
Company Act of 1940 (15 U.S.C. 80a-1 et seq.) (the ``Act'') is entitled
``Exemption of certain purchase or sale transactions between an
investment company and certain affiliated persons thereof.'' It
provides an exemption from section 17(a) of the Act for purchases and
sales of securities between registered investment companies
(``funds''), that are affiliated persons (``first-tier affiliates'') or
affiliated persons of affiliated persons (``second-tier affiliates''),
or between a fund and a first- or second-tier affiliate other than
another fund, when the affiliation arises solely because of a common
investment adviser, director, or officer. Rule 17a-7 requires funds to
keep various records in connection with purchase or sale transactions
effected in reliance on the rule. The rule requires the fund's board of
directors to establish procedures reasonably designed to ensure that
the rule's conditions have been satisfied. The board is also required
to determine, at least on a quarterly basis, that all affiliated
transactions effected during the preceding quarter in reliance on the
rule were made in compliance with these established procedures. If a
fund enters into a purchase or sale transaction with an affiliated
person, the rule requires the fund to compile and maintain written
records of the transaction.\1\ The Commission's examination staff uses
these records to evaluate for compliance with the rule.
---------------------------------------------------------------------------

    \1\ The written records are required to set forth a description
of the security purchased or sold, the identity of the person on the
other side of the transaction, and the information or materials upon
which the board of directors' determination that the transaction was
in compliance with the procedures was made.
---------------------------------------------------------------------------

    While most funds do not commonly engage in transactions covered by
rule 17a-7, the Commission staff estimates that nearly all funds have
adopted procedures for complying with the rule.\2\ Of the approximately
3,318 currently active funds, the staff estimates that virtually all
have already adopted procedures for compliance with rule 17a-7. This is
a one-time burden, and the staff therefore does not estimate an ongoing
burden related to the policies and procedures requirement of the rule
for funds.\3\ The staff estimates that there are approximately 150 new
funds that register each year, and that each of these funds adopts the
relevant policies and procedures. The staff estimates that it takes
approximately 4 hours to develop and adopt these policies and
procedures. Therefore, the total annual burden related to developing
and adopting these policies and procedures would be approximately 600
hours.\4\
---------------------------------------------------------------------------

    \2\ Unless stated otherwise, these estimates are based on
conversations with the examination and inspections staff of the
Commission and fund representatives.
    \3\ Based on our reviews and conversations with fund
representatives, we understand that funds rarely, if ever, need to
make changes to these policies and procedures once adopted, and
therefore we do not estimate a paperwork burden for such updates.
    \4\ This estimate is based on the following calculations: (4
hours x 150 new funds = 600 hours).
---------------------------------------------------------------------------

    Of the 3,318 existing funds, the staff assumes that approximately
25%, (or 830) enter into transactions affected by rule 17a-7 each year
(either by the fund directly or through one of the fund's series), and
that the same percentage (25%, or 38 funds) of the estimated 150 funds
that newly register each year will also enter into these transactions,
for a total of 868 \5\ companies that are affected by the recordkeeping
requirements of rule 17a-7. These funds must keep records of each of
these transactions, and the board of directors must quarterly determine
that all relevant transactions were made in compliance with the
company's policies and procedures. The rule generally imposes a minimal
burden of collecting and storing records already generated for other
purposes.\6\ The staff estimates that the burden related to making
these records and for the board to review all transactions would be 3
hours annually for each respondent, (2 hours spent by compliance
attorneys and 1 hour spent by the board of directors) \7\ or 2,604
total hours each year.\8\
---------------------------------------------------------------------------

    \5\ This estimate is based on the following calculation: (830 +
38 = 868).
    \6\ Commission staff believes that rule 17a-7 does not impose
any costs associated with record preservation in addition to the
costs that funds already incur to comply with the record
preservation requirements of rule 31a-2 under the Act. Rule 31a-2
requires companies to preserve certain records for specified periods
of time.
    \7\ The staff estimates that funds that rely on rule 17a-7
annually enter into an average of 8 rule 17a-7 transactions each
year. The staff estimates that the compliance attorneys of the
companies spend approximately 15 minutes per transaction on this
recordkeeping, and the board of directors spends a total of 1 hour
annually in determining that all transactions made that year were
done in compliance with the company's policies and procedures.
    \8\ This estimate is based on the following calculation: (3
hours x 868 companies = 2,604 hours).
---------------------------------------------------------------------------

    Based on these estimates, the staff estimates the combined total
annual burden hours associated with rule 17a-7 is 3,204 hours.\9\ The
staff also estimates that there are approximately 1,018 respondents and
7,094 total responses.\10\
---------------------------------------------------------------------------

    \9\ This estimate is based on the following calculation: (600
hours + 2,604 hours = 3,204 total hours).
    \10\ This estimate is based on the following calculations: (150
newly registered funds + 868 funds that engage in rule 17a-7
transactions = 1,018); (868 funds that engage in rule 17a-7
transactions x 8 times per year = 6,944); (6944 + 150 = 7,094
responses).
---------------------------------------------------------------------------

    The estimates of burden hours are made solely for the purposes of
the Paperwork Reduction Act, and are not derived from a comprehensive
or even a representative survey or study of the costs of Commission
rules. The collection of information required by rule 17a-7 is
necessary to obtain the benefits of the rule. Responses will not be
kept confidential. An agency may not conduct or sponsor, and a person
is not required to respond to, a collection of information unless it
displays a currently valid control number.
    The public may view the background documentation for this
information collection at the following Web site, http://www.reginfo.gov. Comments should be directed to: (i) Desk Officer for
the Securities and Exchange Commission, Office of Information and
Regulatory Affairs, Office of Management and Budget, Room 10102, New
Executive Office Building, Washington, DC 20503, or by sending an email
to<EMAIL_ADDRESS>and (ii) Thomas Bayer, Director/Chief
Information Officer, Securities and Exchange Commission, c/o Remi
Pavlik-Simon, 6432 General Green Way, Alexandria, VA 22312 or send an
email to<EMAIL_ADDRESS>Comments must be submitted to OMB
within 30 days of this notice.

    Dated: November 3, 2011.
Kevin M. O'Neill,
Deputy Secretary.
[FR Doc. 2011-28900 Filed 11-7-11; 8:45 am]
BILLING CODE 8011-01-P


[Federal Register Volume 79, Number 200 (Thursday, October 16, 2014)]
[Proposed Rules]
[Pages 62070-62072]
[FR Doc No: 2014-24556]

=======================================================================
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DEPARTMENT OF TRANSPORTATION

Federal Aviation Administration

14 CFR Part 39

[Docket No. FAA-2014-0751; Directorate Identifier 2013-NM-188-AD]
RIN 2120-AA64

Airworthiness Directives; Kidde Graviner

AGENCY: Federal Aviation Administration (FAA), DOT.

ACTION: Notice of proposed rulemaking (NPRM).

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SUMMARY: We propose to adopt a new airworthiness directive (AD) for
certain Kidde Graviner hand-operated fire extinguishers as installed
on, but not limited to, various transport and small airplanes. This
proposed AD was prompted by a report that a fire extinguisher failed to
operate when the activation lever was pressed. This proposed AD would
require modifying the affected fire extinguishers. We are proposing
this AD to prevent fire extinguishers from failing to operate in the
event of a fire, which could jeopardize occupants' safety and
continuation of safe flight and landing.

DATES: We must receive comments on this proposed AD by December 1,
2014.

ADDRESSES: You may send comments by any of the following methods:
     Federal eRulemaking Portal: Go to http://www.regulations.gov. Follow the instructions for submitting comments.
     Fax:<PHONE_NUMBER>.
     Mail: U.S. Department of Transportation, Docket
Operations, M-30, West Building Ground Floor, Room W12-140, 1200 New
Jersey Avenue SE., Washington, DC 20590.
     Hand Delivery: U.S. Department of Transportation, Docket
Operations, M-30, West Building Ground Floor, Room W12-140, 1200 New
Jersey Avenue SE., Washington, DC, between 9 a.m. and 5 p.m., Monday
through Friday, except Federal holidays.
    For service information identified in this proposed AD, contact
Kidde

Graviner Limited, Mathisen Way, Colnbrook, Slough, Berkshire, SL3 0HB,
United Kingdom; telephone +44 (0) 1753 583245; fax +44 (0) 1753 685040.
You may view this referenced service information at the FAA, Transport
Airplane Directorate, 1601 Lind Avenue SW., Renton, WA. For information
on the availability of this material at the FAA, call<PHONE_NUMBER>.

Examining the AD Docket

    You may examine the AD docket on the Internet at http://www.regulations.gov by searching for and locating Docket No. FAA-2014-
0751; or in person at the Docket Management Facility between 9 a.m. and
5 p.m., Monday through Friday, except Federal holidays. The AD docket
contains this proposed AD, the regulatory evaluation, any comments
received, and other information. The street address for the Docket
Operations office (telephone<PHONE_NUMBER>) is in the ADDRESSES
section. Comments will be available in the AD docket shortly after
receipt.

FOR FURTHER INFORMATION CONTACT: Caspar Wang, Aerospace Engineer,
Boston Aircraft Certification Office (ACO), FAA, Engine & Propeller
Directorate, 12 New England Executive Park, Burlington, MA 01803;
phone:<PHONE_NUMBER>; fax:<PHONE_NUMBER>; email<EMAIL_ADDRESS>
SUPPLEMENTARY INFORMATION:

Comments Invited

    We invite you to send any written relevant data, views, or
arguments about this proposed AD. Send your comments to an address
listed under the ADDRESSES section. Include ``Docket No. FAA-2014-0751;
Directorate Identifier 2013-NM-188-AD'' at the beginning of your
comments. We specifically invite comments on the overall regulatory,
economic, environmental, and energy aspects of this proposed AD. We
will consider all comments received by the closing date and may amend
this proposed AD based on those comments.
    We will post all comments we receive, without change, to http://www.regulations.gov, including any personal information you provide. We
will also post a report summarizing each substantive verbal contact we
receive about this proposed AD.

Discussion

    The European Aviation Safety Agency (EASA), which is the Technical
Agent for the Member States of the European Community, has issued EASA
Airworthiness Directive 2012-0037, dated March 9, 2012 (referred to
after this as the Mandatory Continuing Airworthiness Information, or
``the MCAI''), to correct an unsafe condition for certain Kidde
Graviner hand-operated fire extinguishers as installed on, but not
limited to, various transport and small airplanes. The MCAI states:

    An instance occurred where an operator tried to use the fire
extinguisher, but the extinguisher failed to operate when the
activation lever was pressed.
    This condition, if not detected and corrected, could lead, in
case of need to use the device to extinguish a fire on an aircraft,
to jeopardize the occupants' safety as well as the flight
continuation and safe landing.
    The part manufacturer Kidde Graviner has introduced a design
change to remove the root cause of the possible failure.
    This AD requires to modify all potentially defective fire
extinguishers [including applying adhesive to the gland nut].

    You may examine the MCAI in the AD docket on the Internet at http://www.regulations.gov by searching for and locating it in Docket No.
FAA-2014-0751.

Relevant Service Information

    Kidde Graviner has issued Alert Service Bulletin A26-081, Revision
1, dated January 31, 2012. The actions described in this service
information are intended to correct the unsafe condition identified in
the MCAI.

FAA's Determination and Requirements of This Proposed AD

    This product has been approved by the aviation authority of another
country, and is approved for operation in the United States. Pursuant
to our bilateral agreement with the State of Design Authority, we have
been notified of the unsafe condition described in the MCAI and service
information referenced above. We are proposing this AD because we
evaluated all pertinent information and determined an unsafe condition
exists and is likely to exist or develop on other products of the same
type design.

Costs of Compliance

    We estimate that this proposed AD affects 400 appliances installed
on, but not limited to, various transport and small airplanes of U.S.
registry.
    We also estimate that it would take about 25 work-hours per product
to comply with the basic requirements of this proposed AD. The average
labor rate is $85 per work-hour. Based on these figures, we estimate
the cost of this proposed AD on U.S. operators to be up to $850,000, or
$2,125 per appliance.

Authority for This Rulemaking

    Title 49 of the United States Code specifies the FAA's authority to
issue rules on aviation safety. Subtitle I, section 106, describes the
authority of the FAA Administrator. ``Subtitle VII: Aviation
Programs,'' describes in more detail the scope of the Agency's
authority.
    We are issuing this rulemaking under the authority described in
``Subtitle VII, Part A, Subpart III, Section 44701: General
requirements.'' Under that section, Congress charges the FAA with
promoting safe flight of civil aircraft in air commerce by prescribing
regulations for practices, methods, and procedures the Administrator
finds necessary for safety in air commerce. This regulation is within
the scope of that authority because it addresses an unsafe condition
that is likely to exist or develop on products identified in this
rulemaking action.

Regulatory Findings

    We determined that this proposed AD would not have federalism
implications under Executive Order 13132. This proposed AD would not
have a substantial direct effect on the States, on the relationship
between the national Government and the States, or on the distribution
of power and responsibilities among the various levels of government.
    For the reasons discussed above, I certify this proposed
regulation:
    1. Is not a ``significant regulatory action'' under Executive Order
12866;
    2. Is not a ``significant rule'' under the DOT Regulatory Policies
and Procedures (44 FR 11034, February 26, 1979);
    3. Will not affect intrastate aviation in Alaska; and
    4. Will not have a significant economic impact, positive or
negative, on a substantial number of small entities under the criteria
of the Regulatory Flexibility Act.

List of Subjects in 14 CFR Part 39

    Air transportation, Aircraft, Aviation safety, Incorporation by
reference, Safety.

The Proposed Amendment

    Accordingly, under the authority delegated to me by the
Administrator, the FAA proposes to amend 14 CFR part 39 as follows:

PART 39--AIRWORTHINESS DIRECTIVES

0
1. The authority citation for part 39 continues to read as follows:

    Authority:  49 U.S.C. 106(g), 40113, 44701.

Sec.  39.13  [Amended]

0
2. The FAA amends Sec.  39.13 by adding the following new airworthiness
directive (AD):

Kidde Graviner: Docket No. FAA-2014-0751; Directorate Identifier
2013-NM-188-AD.

(a) Comments Due Date

    We must receive comments by December 1, 2014.

(b) Affected ADs

    None.

(c) Applicability

    This AD applies to Kidde Graviner hand-operated fire
extinguishers having part numbers 56412-001 (34H), 56411-001 (35H),
and 56412-002 (38H). These fire extinguishers may be installed on,
but not limited to, various transport and small airplanes,
certificated in any category, specified in paragraphs (c)(1),
(c)(2), (c)(3), (c)(4), (c)(5), and (c)(6) of this AD.
    (1) BAE Systems (Operations) Limited Model ATP airplanes.
    (2) BAE Systems (Operations) Limited Model 4101 airplanes.
    (3) EADS CASA (Type Certificate previously held by
Construcciones Aeronauticas, S.A.) Model C-212-CB, C-212-CC, C-212-
CD, C-212-CE, C-212-CF, C-212-DE, and C-212-DF airplanes.
    (4) Fokker Services B.V. Model F.27 Mark 050, 100, 200, 300,
400, 500, 600, and 700 airplanes.
    (5) Short Brothers PLC Model SD3-60 SHERPA, SD3-SHERPA, SD3-30,
and SD3-60 airplanes.
    (6) SHORT BROTHERS & HARLAND LTD SC-7 Series 2 and SC-7 Series 3
airplanes.

(d) Subject

    Air Transport Association (ATA) of America Code 26, Fire
Protection.

(e) Reason

    This AD was prompted by a report that a fire extinguisher failed
to operate when the activation lever was pressed. We are issuing
this AD to prevent fire extinguishers from failing to operate in the
event of a fire, which could jeopardize occupants' safety and
continuation of safe flight and landing.

(f) Compliance

    Comply with this AD within the compliance times specified,
unless already done.

(g) Modification

    Within 6 months after the effective date of this AD, modify all
Kidde Graviner hand-operated fire extinguishers having part numbers
56412-001 (34H), 56411-001 (35H), and 56412-002 (38H), in accordance
with the Accomplishment Instructions of Kidde Graviner Alert Service
Bulletin A26-081, Revision 1, dated January 31, 2012.

(h) Credit for Previous Actions

    This paragraph provides credit for actions required by paragraph
(g) of this AD, if those actions were performed before the effective
date of this AD using Kidde Graviner Alert Service Bulletin A26-081,
dated August 23, 2011, which is not incorporated by reference in
this AD.

(i) Parts Installation Prohibition

    As of the effective date of this AD, no person may install any
Kidde Graviner hand-operated fire extinguisher having part number
56412-001 (34H), 56411-001 (35H), or 56412-002 (38H) on any airplane
unless the fire extinguisher has been modified as specified in
paragraph (g) of this AD.

(j) Other FAA AD Provision

    The following provision for Alternative Methods of Compliances
(AMOCs) also applies to this AD: The manager of the office having
certificate responsibility for the affected product has the
authority to approve AMOCs for this AD, if requested using the
procedures found in 14 CFR 39.19. In accordance with 14 CFR 39.19,
send your request to your principal inspector or local Flight
Standards District Office, as appropriate. The Manager, Boston
Aircraft Certification Office (ACO), FAA, will coordinate requests
for approval of AMOCs with the manager of the appropriate office for
the affected product. Send information to ATTN: Caspar Wang,
Aerospace Engineer, Boston Aircraft Certification Office (ACO), FAA,
Engine & Propeller Directorate, 12 New England Executive Park,
Burlington, MA 01803; phone:<PHONE_NUMBER>; fax:<PHONE_NUMBER>; email:
<EMAIL_ADDRESS>Before using any approved AMOC, notify your
appropriate principal inspector, or lacking a principal inspector,
the manager of the local flight standards district office/
certificate holding district office. The AMOC approval letter must
specifically reference this AD.

(k) Related Information

    (1) Refer to Mandatory Continuing Airworthiness Information
(MCAI) European Aviation Safety Agency (EASA) Airworthiness
Directive 2012-0037, dated March 9, 2012, for related information.
This MCAI may be found in the AD docket on the Internet at http://www.regulations.gov by searching for and locating it in Docket No.
FAA-2014-0751.
    (2) For service information identified in this AD, contact Kidde
Graviner Limited, Mathisen Way, Colnbrook, Slough, Berkshire, SL3
0HB, United Kingdom; telephone +44 (0) 1753 583245; fax +44 (0) 1753
685040. You may view this service information at the FAA, Transport
Airplane Directorate, 1601 Lind Avenue SW., Renton, WA. For
information on the availability of this material at the FAA, call
425-227-1221.

    Issued in Renton, Washington, on September 23, 2014.
Michael Kaszycki,
Acting Manager, Transport Airplane Directorate, Aircraft Certification
Service.
[FR Doc. 2014-24556 Filed 10-15-14; 8:45 am]
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[Federal Register Volume 85, Number 162 (Thursday, August 20, 2020)]
[Notices]
[Pages 51449-51450]
[FR Doc No: 2020-18244]

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DEPARTMENT OF HEALTH AND HUMAN SERVICES

Food and Drug Administration

[Docket No. FDA-2019-N-6063]

Agency Information Collection Activities; Submission for Office
of Management and Budget Review; Comment Request; Customer/Partner
Service Surveys

AGENCY: Food and Drug Administration, Health and Human Services (HHS).

ACTION: Notice.

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

SUMMARY: The Food and Drug Administration (FDA) is announcing that a
proposed collection of information has been submitted to the Office of
Management and Budget (OMB) for review and clearance under the
Paperwork Reduction Act of 1995.

DATES: Submit written comments (including recommendations) on the
collection of information by September 21, 2020.

ADDRESSES: To ensure that comments on the information collection are
received, OMB recommends that written comments be submitted to https://www.reginfo.gov/public/do/PRAMain. Find this particular information
collection by selecting ``Currently under Review--Open for Public
Comments'' or by using the search function. The OMB control number for
this information collection is 0910-0360. Also include the FDA docket
number found in brackets in the heading of this document.

FOR FURTHER INFORMATION CONTACT: Ila S. Mizrachi, Office of Operations,
Food and Drug Administration, Three White Flint North, 10:00 a.m.-12:00
p.m., 11601 Landsdown St., North Bethesda, MD 20852,<PHONE_NUMBER>,
<EMAIL_ADDRESS>
SUPPLEMENTARY INFORMATION: In compliance with 44 U.S.C. 3507, FDA has
submitted the following proposed collection of information to OMB for
review and clearance.

Customer/Partner Service Surveys

OMB Control Number 0910-0360--Extension

    Under section 1003 of the Federal Food, Drug, and Cosmetic Act (21
U.S.C. 393), FDA is authorized to conduct research and public
information programs about regulated products and responsibilities of
the Agency. Executive Order 12862, entitled ``Setting Customer Service
Standard,'' directs Federal Agencies that ``provide significant
services directly to the public'' to ``survey customers to determine
the kind and quality of services they want and their level of
satisfaction with existing services.'' FDA is seeking extension of an
existing OMB clearance to conduct a series of surveys to implement
Executive Order 12862. Participation in the surveys is voluntary. This
request covers customer/partner service surveys of regulated entities,
such as food processors; cosmetic, drug, biologic, and medical device
manufacturers; consumers; and health professionals. The request also
covers ``partner'' (State and local governments) customer service
surveys.
    FDA will use the information from these surveys to identify
strengths and weaknesses in service to customers/partners and to make
improvements. The surveys will measure timeliness, appropriateness and
accuracy of information, courtesy, and problem resolution in the
context of individual programs.
    FDA estimates conducting 15 customer/partner service surveys per
year, each requiring an average of 15 minutes for review and
completion. We estimate respondents to these surveys to be between 100
and 20,000 customers. Some of these surveys will be repeats of earlier
surveys for purposes of monitoring customer/partner service and
developing long-term data.
    Respondents to this collection of information cover a broad range
of stakeholders who have specific characteristics related to certain
products or services regulated by FDA.
    In the Federal Register of January 21, 2020 (85 FR 3389), we
published a 60-day notice requesting public comment on the proposed
collection of information. No comments were received.
    FDA estimates the burden of this collection of information as
follows:

                                                     Table 1--Estimated Annual Reporting Burden \1\
--------------------------------------------------------------------------------------------------------------------------------------------------------
                                                                                Number of
                           Type of survey                               Number of      responses per     Total annual   Average  burden    Total hours
                                                                       respondents       respondent       responses      per  response
--------------------------------------------------------------------------------------------------------------------------------------------------------
Mail, telephone, web-based.........................................          55,000                1           55,000         0.25 (15           13,750
                                                                                minutes)
--------------------------------------------------------------------------------------------------------------------------------------------------------
\1\ There are no capital costs or operating and maintenance costs associated with this collection of information.

    Based on a review of the information collection since our last
request for OMB approval, we have made no adjustments to our burden
estimate.

    Dated: August 14, 2020.
Lowell J. Schiller,
Principal Associate Commissioner for Policy.
[FR Doc. 2020-18244 Filed 8-19-20; 8:45 am]
BILLING CODE 4164-01-P