United States
 Environmental Protection
 Agency
 Industrial Environmental Research
 Laboratory
 Research Triangle Park NC 27711
 Research and Development
 EPA-600/S2-82-070  Dec. 1982
 Project Summary
 Acid  Rain  Mitigation Study:
 Volumes  I  and  II.
 J. G. Ball and W. R. Menzies
  The U.S. EPA has initiated a multi-
phased study of the acid rain problem.
As part of Phase I, Radian Corporation
investigated SO2 emissions and con-
trols  in the industrial  sector.  The
primary objective of this work was to
provide  a  consistent set  of capital
investment  and operating costs for
flue  gas desulfurization (FGD)  sys-
tems  applied to both industrial  and
electric utility boilers. Retrofit factors
and the cost of FGD systems applied
to new boilers were  addressed.  Wet
limestone scrubbing  and lime spray
drying FGD systems were evaluated.
  In conducting the work to provide a
consistent set  of capital investment
and operating costs for FGD systems
retrofitted to  existing boilers,  the
following issues were investigated:
  •  Apparent discontinuities in both
     FGD system capital investment
     and operating costs as a func-
     tion of boiler capacity in  the
     region between industrial boil-
     ers and small utility boilers.
  •  FGD retrofit factors applied to
     existing boilers based on published
     reports.
  •  Differences  between PEDCo
     Environmental, Inc.  and TVA
     cost estimates for  utility boiler
     FGD systems.
  These costing issues were examined
on the bases of design scope, costing
factors (for equipment installation,
indirect  investment, etc.), year of
costs, inherent strengths and weak-
nesses, and published data of actual
system costs. Recommendations are
made  for the cost bases to use in
further acid rain studies.
  This Project Summary was devel-
 oped by EPA '$ Industrial Environmen-
 tal Research Laboratory, Research
 Triangle Park, NC, to announce key
 findings of the research project that is
 fully documented in a separate report
 of the same title (see Project Report
 ordering information at back).

 Introduction

  There is a growing concern about the
 acidity of  precipitation  in the north-
 eastern United  States  and Canada.
 Many scientists think that acidic precip-
 itation kills aquatic and plant  life,
 damages crop-growing soil, and accel-
 erates erosion and damage to buildings.
 Although the  mechanisms producing
 acid rain are  not clearly understood,
 sulfur  dioxide (S02) and oxides of
 nitrogen (NOX) are thought to be the
 precursors of the chemicals that cause
 acid rain. Large quantities of SO2 and
 NOx are produced by various combus-
 tion and non-combustion processes in
 both the utility and industrial  sectors.
 Reducing these S02 and NOX emissions
 to the atmosphere  should reduce the
 potential for acid rain.
  Because  this concern  is increasing,
the  U.S. EPA initiated a multi-phased
study of the acid rain problem. As one
part of Phase I, Radian Corporation
 investigated SOa emissions and con-
trols in the industrial sector; Teknekron,
Inc.  made a similar study of the utility
sector. The results of these  studies
would provide  direction  for additional
phases.  The objectives of the later
phases are to investigate S02 sources in
more detail than Phase I, to investigate

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NOx sources,  and to model  source/
receptor relationships.
  In support of the Phase I  efforts,
Radian Corporation was asked to
provide a  consistent  set  of  capital
investment and operating costs for flue
gas desulfunzation (FGD) systems
applied to both industrial and  electric
utility  boilers.  Since existing S02
sources are  the primary targets for
reducing  the impacts  of  acid  rain,
retrofit factors as well as the cost for
FGD systems applied to new boilers
were addressed This report summar-
izes the results of that cost work.
  The cost estimates used as the basis
for  this study are:
  • Utility boiler FGD systems by TVA
     and PEDCo Environmental, Inc.
  • Industrial boiler FGD systems by
     Radian Corporation.
Wet limestone scrubbing and lime spray
drying  FGD systems were  evaluated.
The U S EPA has recognized that there
appear to  be discrepancies in these
published  cost estimates in  two areas:
  • Utility boiler limestone FGD sys-
     tem  costs prepared by TVA and
     PEDCo Environmental, Inc.
  • FGD system costs in the capacity
     transition from industrial boilers
     to small utility boilers.
  To achieve the primary objective of
the study  (provide a consistent set of
capital  investment and operating costs
for  FGD systems retrofitted  to existing
boilers),  the following  issues were
investigated'
  •  Apparent discontinuities  in both
     FGD  system capital investment
     and operating costs as a function
     of boiler capacity  in the region
     between industrial boilers  and
     small utility boilers.
  •  FGD retrofit factors  applied to
     existing  boilers based on  pub-
     lished reports.
  •  The  differences between PEDCo
     Environmental, Inc. and TVA cost
     estimates for  utility boiler FGD
     systems.
  The above costing  issues are exam-
ined on the  bases  of design scope,
costing factors (for equipment installa-
tion, indirect  investment, etc.), year of
costs,  inherent  strengths and  weak-
nesses, and published data of actual
system costs  Recommendations are
made  for  the  cost  bases  to use in
further acid rain studies.

Summary of  Results
  The  results of the investigations of
each issue are summarized  below.
 Utility and Industrial Boiler
 FGD System Costs

  Significant discontinuities in both the
FGD system  capital investment and
operating cost areas as a function of
boiler capacity have been observed in
the capacity transition from industrial to
small utility boiler systems. This study
attempts to determine the causes of
these discontinuities and to provide a
consistent  set of  costs (capital and
operating) for both  types  of  FGD
systems applied to new boilers. Cost
estimates by TVA (for utility boilers) and
Radian Corporation  (for  industrial
boilers) were used for this analysis
since these estimates are current and
well-documented. In order to properly
compare the TVA and Radian estimates,
the costs were adjusted to the same
economic and technical bases, which
include:
  •  Identical design scope.
  •  Same year of construction basis.
  •  Same indirect investment algo-
     rithm basis.
  •  Same unit cost  basis  for labor,
     raw materials, utilities, etc.
In addition,  major components  of
industrial  boiler  FGD  systems  are
usually shop-fabricated whereas utility
systems are field-erected. The capital
and  operating  costs developed after
accounting for the differences de-
scribed above were compared to deter-
mine if the discontinuities were real or
a result of  inaccuracies  in one or both
sets  of cost data.
  Wet limestone  scrubbing  and lime
spray drying FGD systems are the only
processes evaluated in this study. For
electric utility plants, wet  lime and
limestone systems dominate the oper-
ating units; wet lime/limestone scrub-
bing and lime spray drying processes
are the prevalent systems being planned
for future facilities. For industrial
boilers, dual  alkali and  sodium (once-
through) systems  dominate  operating
and  planned units, although  spray
drying systems are beginning to be
applied. The dual alkali is more typical of
the FGD system that will be applied to
large industrial boilers  Sodium (once-
through) will  most likely be  applied to
small boilers where the high TDS (total
dissolved solids)  liquid  waste can be
easily  disposed of (such as on  steam
generators used  in oil  field injection
where the liquid waste can be disposed
of by well  injection or  in evaporation
ponds)
  To simplify the basis of this and other
studies, only the wet lime/limestone
FGD costs are recommended for use in
developing cost  impacts of FGD con-
trol  for  acid ram mitigation. The
reasons for this recommendation are:

   •  The capital and operating costsfor
     wet limestone and dual alkali FGD
     systems are comparable for  in-
     dustrial boiler FGD  applications
     over the capacity range  of 30 -
     200 x  106 Btu/hr.  boiler heat
     input.
   •  Due to the large amounts of data
     on  existing utility  boiler FGD
     systems, the cost estimates  for
     limestone systems should  be
     more accurate than for lime spray
     dryer systems. In addition, the
     cost estimates supplied by TVA for
     utility  boiler  spray  dryer FGD
     systems were preliminary and
     had not been finalized prior  to
     completing this report.

Only the costs for wet limestone FGD
systems are presented and discussed in
this summary. However, the analysis of
spray drying in the report points out the
major factors that affect the costs for
these systems.
  The  capital and annual first year
operating and  maintenance  (O&M)*
costs for FGD systems applied to new
industrial boilers are derived from  the
cost data developed by Radian Corpora-
tion. These costs are for limestone FGD
systems, however,  Radian found that
dual alkali and  limestone FGD  costs
were comparable (within 10 percent)for
the capacity range evaluated. These
cost data are part of the background
information document  which was
developed to  support new  source
performance standards for industrial
boilers.  Table 1   presents a complete
breakdown of the capital investment
costs (1980 dollars) for FGD systems
applied to new industrial boilers ranging
in capacity from  30 to 200 million Btu
per hour. Table 2 shows the first year
O&M costs for those same FGD systems
These costs are recommended for use in
the acid rain study.
  TVA  has  performed a  similar cost
analysis for  limestone FGD systems
applied to new  utility boilers Their
costing  work is  part  of  an on-going
•Includes raw materials, labor, maintenance,
 utilities, solid waste disposal (if applicable), and
 overhead  Does not include capital-related costs
 such as depreciation, income taxes, interest, and
 return-on equity

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Table 1.     Industrial Boiler Limestone FGD System Capital Investment
Boiler Heat Input
Capacity, 706 Btu/hr
Direct Investment
Raw Materials Handling
SOz Scrubbing
Fans
Solids Separation
Utilities & Service
Total Direct Investment (TDI)
Indirect Investment
Engineering
Construction & Field Expense
Construction Fees
Start-up
Performance Test
Total Indirect Investment (Til)
Contingencies
Total Turnkey Investment (TTI)
Land
Working Capital
Total Cap. Investment (TCI}
1978$
TCI x 1.21 = 7350$
TCI (1980$) 103$/106 Btu/hr
Capital Investment*, 103 $
30

59
149
20
160
23
-477

98
41
41
8
4
-192
121
~724
0.6
52

777
940
31.3
75

99
244
40
189
34
~~665

98
61
61
12
6
238
169
1073
0.8
72

1.086
1,314
17.5
150

147
368
69
227
49
~860

98
86
86
17
9
296
231
1357
1
106

1.494
1,808
12.1
200

171
401
76
275
55
~sn

98
98
98
19
10
~32~3
260
T$6J
1
126

1.688
2.042
10.2
program to develop detailed and accu-
rate costs for utility-sized FGD systems.
Table 3 presents the capital investment
costs; Table 4 shows the first year
annual O&M costs. These costs are also
recommended for use in the acid ram
study.
   The industrial and utility boiler FGD
system capital investments, shown in
Tables  1 and 3,  respectively, should
exhibit  some  discontinuity  in the
capacity transition from large industrial
boilers to small utility boilers due to:

1.  Design scope

         Utility Boiler
*Bases given in Tables 2.1.2-4 and 2.1.2-5 of full report.
 Includes spare absorber
 modules, stack gas reheat,
 and on-site sludge
 disposal pond

    Industrial Boiler
 Does not include spare
 absorbers, stack gas
 reheat, or an on-site
 pond


 2.  Method of installation
Table 2.    Industrial Boiler Limestone FGD System First Year Operating
            and Maintenance Costs
Boiler Heat Input
Capacity. 106 Btu/hr
Direct Costs
Raw Material
Limestone
Conversion Costs
Operating Labor
Supervision
Utilities
Process Water
Power
Maintenance Labor & Materials
Solid Waste Disposal
TOTAL DIRECT COSTS
Indirect Costs
Payroll Overhead
Plant Overhead
G&A
TOTAL INDIRECT COSTS
Total First Year O&M, 1978$
1981 $ (1978$ x 1.285)
$/10* Btu{1978$)
$/10e Btu (1981$)
Annual
30


10

105
21

0.2
7
33
28
~2~04~

38
40
31
~JOS
313
402
1.99
2.56
O&M Cost,* 103
75


24

105
21

0.7
18
48
71
~~2~55

38
44
43
-J75
413
531
1.05
1.35
$/yr (1978$)
150


49

105
21

1
36
68
143
~32~3~

38
48
60
-TUB
569
731
0.72
0.33

200


65

105
21

2
42
78
190
~W5

38
50
68
~T56
659
847
0.63
0.81
                                                                                   Utility Boiler
                                                                                  Field-erection
                                                                                   Industrial Boiler
                                                                                  Shop-fabrication of
                                                                                  major components
                                                                                   .   Indirect investment plus
                                                                                      other capital
                                                                                      requirements

                                                                                    Utility Boiler
a eases given in Tables 2.1.2-4, 2.1.2-5, and 2.1.3-3 of full report.
                                                                                  —1.0 times direct
                                                                                  investment

                                                                                   Industrial Boiler

                                                                                  ~0.75 times direct
                                                                                  investment
  The analyses performed in this report
illustrate that the three items listed above
account for most of the discontinuity in
the capital investment costs.
  As with the capital investment costs,
the industrial and utility boiler  annual
O&M costs presented in Tables 2 and 4,
respectively,  are  also likely to  exhibit
some discontinuity due to:

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Table 3. Utility Boiler Limestone FGD System Capital Investment (1980$)
Capital Investment* JO3 $
Utility Boiler Capacity M We
Boiler Heat Input* (106 Btu/hr)
Direct Investment
Raw Materials Handling
SOt Scrubbing
Waste Disposal
Total Direct Investment (TDI)
Indirect Investment (II)
Engr. Design & Supv. plus
Architectural & Engr. (A&E}
Construction Expenses
Contractor Fees
Contingency
Fixed Investment (TDI + II)
Other Capital Requirements
Start-up & Modifications
Interest During Construction
Land
Working Capital
Total Capital Investment fTCIf
$/kWe
103$/10* Btu/hr*
WO
1,OOO
1,738
9,399
5,073
16,149
1,453
2,584
807
4,199
25, 192
1,938
3,779
634
820
32.363
323.6
32.4
250
2,500
1,875
16,070
8,859
26,805
2,412
4,289
1.340
6.969
41.816
3.217
6,272
1.247
1.388
53.932
215.7
21.6
500
5,000
3,844
26.764
14,058
44,666
4.020
7,147
2,233
11,613
69,679
5,360
10.452
2,107
2,349
89.947
179.9
18.0
1,000
10,000
4,541
53,272
22.743
80,556
7.250
12,889
4.028
20.945
125.667
9.667
18,850
3.573
4,270
162,027
162.0
16.2
1. Design scope
Utility Boiler
Stack gas reheat steam
used; sludge disposed
of in pond on-site
Industrial Boiler
No stack gas reheat
steam used; sludge
disposed of by outside
contractor at $15/ton
2. Unit costs for raw materials, labor,
utilities, etc.
Utility Boiler
See Table 2.1.3-1 in
full report
Industrial Boiler
See Table 2.1.3-3 in
full report
3 Ppnantw ntili7atinn fa^trvr
"Bases given in Tables 2.1.2-1 and 2.1.2-2 of full report.
"Assumes 10,000 Btu/kWh.
CTCI = TDI + 11 + Other Capital Requirements.
Table 4.     Utility Boiler Limestone FGD System First Year Operating
           and Maintenance Costs (1981$)

                                       Annual OSMCosf, JO3 $/yr
Boiler Capacity MWe
Boiler Heat Inpuf (10* Btu/hr)
Direct Costs
Raw Material
Limestone
Conversion Costs
Operating Labor & Supervision
Utilities
Process Water
Electricity
Steam
Maintenance Labor & Materials
Analyses
TOTAL DIRECT COSTS
Indirect Costs
Overheads
Plant & Administrative
Total First year O&M Costs0
Mil/s/kWh
$/10BBtu"
WO
1,000


174

172

3
264
166
1.109
52
1.940


800
2.740
5.79
0.58
250
2,500


436

260

9
604
414
1,785
52
' 3,560


1.258
4.818
4.07
0.41
500
5.000


872

356

18
1,201
829
2,970
78
6.324


2.042
8,366
3.53
0.35
1,000
10,000


1.744

486

38
2.343
1.657
5,428
104
1 1.800


3.611
15.411
3.26
0.33
a Bases given in Tables 2.1.2-1, 2.1.2-2, and 2.1.3-1 of full report.
b Assumes 10,000 Btu/kWh.
0 Direct plus indirect costs.
d Based on boiler heat input.
Utility Boiler
0~54

Industrial Boiler
060


In addition to these factors, O&M costs
that are estimated  based on capital
investment (such as maintenance and
sometimes overhead)  will be signifi-
cantly  different for  the two  systems
because of factors which cause discon-
tinuities in the capital  investment (see
previous discussion  on capital invest-
ment).  The analyses performed illus-
trate that  the  items identified above
account  for most of the cost  discon-
tinuity

  The discontinuities are shown graph-
ically by  plotting the data presented in
Tables  1  through 4. Figure 1 is a plot of
the capital  investment costs and Figure
2 is a plot  of the first year O&M costs.
Also shown on these graphs is a plot of
the normalized cost values which result
from elimination  of the differences in
design scope,  installation and indirect
investment algorithms, capacity utiliza-
tion factors, and  unit costs mentioned
above   The final normalized  curves
eliminate most  of the discontinuities in
both sets  of data. The rationale for
developing the normalized  curve is

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     50-
 §
 So ro-
        -
 re i
 S.
                              Normalized Capital
                               Investment Curve
                                          Limestone FGD System
                                          3.35-3.5% Sulfur Coal
                                          90% S02 Removal

                                            Utility FGD Systems
                                         Capital Investment Costs
                                                 (Table 3)
Industrial FGD Systems
Capital Investment Costs
       (Table 1)
       • Cost Data from Tables 1 and 3
      — Resulting curve when industrial and
         utility cost are adjusted to same basis.
         This includes:
         (1) Design scope
         (2) Indirect investment algorithms
         (3) Method of installation
            (shop-fabricated or field-erected}
        10
50
                  100
              500    1000
                                                                 5000 10000
                              Boiler Heat Input, 106Btu/hr
                        i
                        5
                    i
                   10
              50    100
For Utility Boilers, MWe

    Boiler Capacity
                                            500  1000
   NOTE: Utility boiler FGD  unit  investment estimates are provided  for boiler
   capacities of 100-500 MWe and are expressed as dollars per 1O6 Btu/hr of capacity
   assuming a plant heat rate of 10,000 Btu/kWh. Industrial boiler FGD system
   estimates are also expressed as dollars per 106 Btu/hr of boiler capacity. The utility
   and industrial boiler investment and capacity  scales are interchangeable if the
   same 10,000 Btu/kWh conversion factor is assumed. This is a close approximation
   of the heat rate for most utility plants.

 Figure  1.    Capital investment for industrial and utility boiler wet limestone FGD
             systems.
discussed in detail in Section  2 of the
full report
  However,  due to the  environmental
regulations and economy of scale, the
design scope is likely to be considerably
different for industrial and utility boiler
FGD systems as discussed previously.
Many  components of industrial  boiler
FGD  units  are  likely  to  be shop-
fabricated; whereas,  utility systems are
field-erected. In addition, unit costs for
raw materials, utilities, and solid waste
disposal  are likely to be considerably
different due to  volume or quantity
considerations. Different capacity utili-
zation  factors may   also be expected
The factors affecting  capital investment
and, therefore, certain O&M costs (such
as maintenance and overhead), are also
important. Therefore, discontinuities in
                             the capital investment and O&M curves
                             similar to those shown in Figures 1 and
                             2 should be expected.
                               In summary, the annual O&M  and
                             capital  investment  cost  estimates  for
                             wet limestone FGD systems presented
                             in this study* should be  considered as
                             valid consistent data  Therefore, it  is
                             recommended that the cost data shown
                             in Tables 1 through 4  be used in later
                             acid  ram studies as the basis for
                             assessing cost impacts for FGD  con-
                             trols.** Of course,  adjustment to the
                             bases  (such  as design scope, start-up
                             date, and site-specific unit costs for raw
                             *For FGD systems applied to new industrial and
                             utility boilers
                             "Retrofit factors will have to be used to adjust
                             these costs to reflect the costs of applying FGD
                             systems to existing boilers
materials, utilities, etc.) may be required
by a particular reader.  The data in this
report is documented so that  these
adjustments can be made, if desired.

FGD System  Retrofit Factor
Evaluation

  A retrofit factor is defined as the ratio
of the capital  investment or operating
cost  for  installing  a process  in  an
existing plant to the capital investment
or operating cost for the same process in
a new installation. This factor is often
applied to new  installation costs to
estimate the costs of putting the sqme
basic equipment into an existing facility.
  Retrofit factors were only evaluated
for utility boilers because there was no
published information on retrofit factors
for industrial boilers. Therefore, there is
no  retrofit factor recommendation for
industrial boiler  FGD systems.

Capital Investment
  Retrofit factor studies performed by
TVA, PEDCo Environmental, Inc.,  M.W.
Kellogg,  and Radian Corporation were
examined. Retrofit factors ranging from
0 9 to 3.0 were found  in these studies.
Space availability was identified as the
principal factor affecting the  capital
investment associated with retrofitting
FGD systems.
  For a preliminary evaluation, a retrofit
factor of  1 2 is recommended for
"average" retrofits for  boilers less than
10 yearsold and with capacities greater
than 200 MW. A retrofit factor range of
1.1 to 1.4 is also recommended. The
lower end of  the range is applicable
when installation of the FGD system is
relatively uninvolved  and when avail-
able  space for FGD  equipment  is
adequate. Retrofit factors in the upper
range nearer 1.4 would be used when
'retrofitting is complex
  The retrofit  factor  1.2 is recom-
mended for use in a preliminary evalua-
tion of FGDsystem retrofit costs for util-
ity boilers. The reader should note that:
  (1) Retrofit of FGD systems to some
      boilers will be infeasible.
  (2)  Retrofit factors greater than 1.4
      are possible.
Only  a site-specific  evaluation of the
factors  associated with  retrofit can
accurately quantify the costs.


Annualized Costs
  No retrofit factor for annualized costs
is recommended. Increased annualized
costs for retrofits compared to new

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      5-
 8  5
 o  (Q
 <*
 o
 2
 C

      5-
Industrial FGD Systems
 First year O&M Costs
       (Table 2)
  •  Cost Data from Tables 2 and 4
	Resulting curve when industrial and
     utility costs are adjusted to same basis.
     This includes:
     (1) Design scope
     (2) Indirect investment algorithms
     (3) Unit cost for labor and materials
     (4) Capacity utilization factor
     (5) Method of installation
       (shop-fabrication or field-erected)
                                 Normalized O&M
                                    Cost Curve
                                                     Utility FGD Systems
                                                    First Year O&M Costs
                                                          (Table 4)
        10
           50                         1000
                  Boiler Heat Input, 10eBtu/hr
                            5000 10000
        1
                  10             50    100
                    For Utility Boilers MWe
                                                                 500  1000
                                   Boiler Capacity
 NOTE: Utility boiler FGD  unit annual O&M estimates are provided for boiler
 capacities of 100 -500 MWe and are expressed as$/10eBtu assuming a plant heat
 rate of 10,000 Btu/kWh. Industrial boiler FGD system estimates are provided for
 boiler heat input capacities of 30-200 x 10s Btu/hr and are expressed as$/106 Btu.
 The utility and industrial boiler capacity scales are interchangeable if the same
 10,000 Btu/kWh conversion fact or is assumed. This is a close approximation of the
 heat rate for most utility plants.

Figure 2.    First year O&M costs for industrial and utility wet limestone  FGD
             systems.
systems are primarily associated with
the higher capital  investment. There-
fore an annualized cost retrofit factor
would be a strong function of the capital
investment  retrofit  factor,  the load
factor of the boiler, and the remaining
useful  life of the boiler.
                               The results of the study show that
                             capital investment and O&M costs for a
                             lime wet scrubbing system prepared by
                             both  organizations  are  very similar
                             when all bases (economical and tech-
                             nical) are made identical.
TVA and PEDCo Environ-
mental. Inc. FGD System
Cost Comparison
  Both TVA and PEDCo have developed
cost estimating procedures for utility
boiler FGD  systems.  In  the past,
estimates  from the  two organizations
have shown  significant differences.
Cost estimates by TVA and PEDCo were
evaluated  to  determine whether  the
differences are real or a function of such
factors as design scope, indirect invest-
ment algorithms, unit  cost  for raw
materials,  utilities, and other economic
parameters.
                                                                                    •USGPO:1982-659-095-567

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       J. G. Ball and W. R. Menzies are with Radian Corporation, Austin, TX 78766.
       P. P. Turner is the EPA Project Officer (see below).
       The complete report consists of two volumes, entitled "Acid Rain Mitigation
         Study:"
           "Volume I. FGD Cost Estimates (Technical Report)," (Order No. PB 83-101
           329; Cost: $16.00, subject to change)
           "Volume II. FGD Cost Estimates (Appendices)," (Order No. PB 83-117 366;
           Cost: $20.50, subject to change)
       The above reports will be available only from:
               National Technical Information Service
               5285 Port Royal Road
               Springfield, VA22161
               Telephone: 703-487-4650
       The EPA Project Officer can be contacted at:
               Industrial Environmental Research Laboratory
               U.S. Environmental Protection Agency
               Research Triangle Park. NC 27711
United States
Environmental Protection
Agency
Center for Environmental Research
Information
Cincinnati OH 45268
Postage and
Fees Paid
Environmental
Protection
Agency
EPA 335
Official Business
Penalty for Private Use $300
                                        AGENCY

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