United States
Environmental Protection
Agency
Industrial Environmental Research
Laboratory
Research Triangle Park NC 27711
EPA-600/2-79-025
January 1979
Research and Development
A Cost Index Format
for  BATEA Achievement
by the Iron and Steel
Industry

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                  RESEARCH REPORTING SERIES


 Research reports of the Office of Research and Development, U.S. Environmental
 Protection Agency, have been grouped into nine series. These nine broad cate-
 gories were established to facilitate further development and application of en-
 vironmental technology. Elimination of traditional grouping was  consciously
 planned to foster technology transfer and a maximum interface in related fields.
 The nine series are:

     1. Environmental Health Effects Research

     2. Environmental Protection Technology

     3. Ecological Research

     4. Environmental Monitoring

     5. Socioeconomic Environmental Studies

     6. Scientific and Technical Assessment Reports (STAR)

     7. Interagency Energy-Environment Research and Development

     8. "Special" Reports

     9. Miscellaneous Reports

 This report has been assigned to the ENVIRONMENTAL PROTECTION TECH-
 NOLOGY series. This series describes research performed to develop and dem-
 onstrate  instrumentation, equipment, and methodology to  repair or prevent en-
 vironmental degradation from point and non-point sources of pollution. This work
 provides the new or improved technology required for the control and treatment
 of pollution  sources to meet environmental quality standards.
                        EPA REVIEW NOTICE
This report has been reviewed by the U.S. Environmental Protection Agency, and
approved for publication. Approval does not signify that the contents necessarily
reflect the views and policy of the Agency, nor does mention of trade names or
commercial products constitute endorsement or recommendation for use.

This document is available to the public through the National Technical Informa-
tion Service, Springfield, Virginia 22161.

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                                    EPA-600/2-79-025

                                         January 1979
A  Cost Index  Format for BATEA
      Achievement  by the Iron
           and Steel  Industry
                         by

                  L.L Huff and J.D. Stockham

                    NT Research Institute
                    10 West 35th Street
                    Chicago, Illinois 60616
                   Contract No. 68-02-2617
                      Task No. 2-4
                  Program Element No. 1BB610
               EPA Project Officer: John S. Ruppersberger

              Industrial Environmental Research Laboratory
               Office of Energy, Minerals, and Industry
                 Research Triangle Park, NC 27711
                      Prepared for

              U.S. ENVIRONMENTAL PROTECTION AGENCY
                Office of Research and Development
                   Washington, DC 20460

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                                  ABSTRACT

     The formulation of a format for BATEA cost analysis and inclusion of per-
tinent cost data were the objectives of this study.  Such a format is to serve
as an aid to regional U.S. Environmental Protection Agency personnel who
evaluate economic appeal cases for BATEA.

     Through discussion with U.S. Environmental Protection Agency regional
personnel and review of cost engineering literature, two sample formats, one
for capital investment and one for operating costs, were developed.  These
cost analysis formats were designed specifically for application to the iron
and steel industry, although, with modification, such a format could be
utilized for other industries as well.

     General information regarding various cost components is provided as a
basis for analyzing cost estimates presented by specific iron and steel plants.

     This report was submitted in fulfillment of Contract No. 68-02-2617,
Task No. 4, by IIT Research Institute under the sponsorship of the
U.S. Environmental Protection Agency.
                                      11

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                             CONTENTS
Abstract	 ii
Figures and Tables	 iv

     1.  Introduction  ,	 1
     2.  Summary and Conclusions  	 2
     3.  Presentation  of Cost Guideline Format 	 3
            Guidelines for Cost Evaluation	 3
            Description of Capital Cost Items 	 4
              Land	 4
              Storage  Facilities  	 4
              Piping	 4
              Instrumentation 	 4
              Site Preparation  	 4
              Equipment 	 6
              Engineering Costs 	 6
              Construction Costs  	 6
              Contingency 	 9
            Description of Operating Costs  Items 	 9
              Fixed Costs 	 9
              Description of Variable Costs 	14
            Cost Information	16

References	 33
Exhibits	 34
Appendix

     A.  Comments from US-EPA Regional Personnel Regarding
           Draft Cost  Format		38
                                iii

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                             FIGURES AND TABLES
Figure                                                                   Page
   1  Piping Cost Curves	    5
   2  Pump Cost Curves	    7
   3  Aeration System Cost Curves	    8
   4  BATEA Operating Costs for By-Product Coke Process	   17
   5  BATEA Operating Costs for Iron-Making Blast Furnace	   18
   6  BATEA Operating Costs for Basic Oxygen Furnace	   19
   7  BATEA Operating Costs for Electric Arc Furnace	   20
   8  BATEA Operating Costs for Open Hearth Furnace	   21
   9  BATEA Operating Costs for Beehive Coke Plant	   22
  10  BATEA Capital Investment for  Open Hearth Furnace	   23
  11  BATEA Capital Investment for  Electric Arc (Wet) Furnace	   2^
  12  BATEA Capital Investment for  By-Product Coke	   25
  13  BATEA Capital Investment for  Sintering Strands	   26
  14  BATEA Capital Investment for  Blast Furnace	   27
  15  BATEA Capital Investment for  Basic Oxygen Furnace	   2^
  16  BATEA Capital Investment for  Electric Arc Furnace (Semi-Wet)	   29
  17  BATEA Capital Investment for  Continuous Casting	   30
  18  BATEA Capital Investment for  Vacuum Degassing	   31
Table                                                                   . !§ge.
                                                                          14
   1  Chemical Costs	
                                                                          32
   2  Treatment Technology	
                                      iv

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                                  SECTION 1

                                INTRODUCTION
     To formulate a cost index and accompanying explanatory guideline for use
by U.S. Environmental Protection Agency (EPA) regional personnel in evaluation
of Best Available Technology Economically Available (BATEA) appeal cases was
considered the primary goal of this effort.  Consultation with the regional
offices, review of the iron and steel cost literature, and analysis of avail-
able cost formats were the most important activities in the development of a
cost format.

     The actual format developed, comments by regional personnel, and a des-
cription of the limitations and utilization of such a cost format are
presented herein.  Such discussions of the format should provide a perspective
of the feasibility and applicability of the cost format as it pertains to the
iron and steel industry.

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                                  SECTION 2

                           SUMMARY AND CONCLUSIONS
     A cost index format to be utilized by the iron and steel industry in
preparation of Best Available Technology Economically Available (BATEA) appeal
cases is valuable to U.S. Environmental Protection Agency regional personnel
if it provides a consistency for presentation, backup cost data sources, and
explanations of the cost elements.

     Flexibility in cost estimating is important but also a range of costs and
cost elements which are considered appropriate should be defined.

     Continued expansion and inclusion of cost data in the guideline for
treatment processes other than those designated for BATEA would be beneficial.

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                                  SECTION 3

                    PRESENTATION OF COST GUIDELINE FORMAT
     A uniform and consistent approach to cost estimation is important in
evaluating economic appeal cases for BATEA requirements.  The steel-making
industry is perhaps one of the most complex and most significant in terms of
pollution requirements.  Therefore, the age and layout of individual steel-
making facilities may lead to BATEA appeal cases.  This guideline has been
developed to aid in the evaluation of the cost elements presented by industry.

     There are two major cost categories, capital cost and operating expense.
Each is needed to present a complete characterization of the economic hardship
to be incurred.  Because each plant has unique treatment requirements for
achieving BATEA levels, it is difficult to provide cost information which can
be meaningfully applied.  Rather, by stipulating a complete and fully detailed
cost estimate from the appealing facility and comparing this to established
cost values, areas for discussion or investigation may appear.  The attached
forms, Exhibits 1 and 2, should be completed by the steel company according
to accompanying instructions.

     For both cost categories detailed, guidelines are presented in the
following section as well as a description of each unit cost item.  This
should provide the EPA reviewer with an understanding of the costs being
incurred and insight into the manipulation of the data presented by the
company.  These guidelines are .based upon the needs and concerns expressed by
regional US EPA personnel and some of their comments in Appendix A.

GUIDELINES FOR COST EVALUATION

     The capital and operating costs submitted by the appealing steel company
should be itemized in Exhibits 1 and 2.  To analyze these submitted costs, it
is helpful to have background information regarding expected ranges for cer-
tain cost components.  In the following sections data are presented to aid in
the evaluation of costs presented in the BATEA appeal process.

     The first section describes the characteristics of the capital cost
items, provides general information, cost curves, and references useful for
evaluating capital costs.  The second section presents similar data for
operating cost elements.  This information provides a general background for
understanding the costs incurred for BATEA.

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DESCRIPTION OF CAPITAL COST ITEMS

Land

     When additional pollution equipment is required, land may be needed to
layout the treatment process, especially for settling and biological activity.
In space limited facilities, a premium upon space may be stipulated in terms
of the price perceived.

Storage Facilities

     The only type of storage facilities which may be included would be for
chemicals used in pollution treatment, such as lime, activated carbon, soda,
and so forth.

Piping

     There will be piping changes required for additional equipment, redirect-
ing waste streams, and handling recirculation of treated water.  Depending
upon the plant configuration, a wide range of costs may be anticipated.  The
following descriptions of piping costs depict the range of values available:

     a)  Piping costs for process units vary from 0.9% to 8.9% of
         the equipment cost, and this does not include inter-
         connecting piping costs.1

     b)  Process piping costs may run as high as 100% of the
                                  f\
         purchased-equipment cost.

     c)  Typical cost curves for piping cost are presented in
         Figure 1.  These costs represent 1968 values and can be
         upgraded to 1977 by use of the Marshall and Swift Cost
         Index, which results in an adjustment factor of 1.47.3

Instrumentation

     Additional controls for level, flow, pH, temperature, pressure and
nutrient addition may be added as the treatment of waste streams is upgraded.

Site Preparation

     These costs include all grading and preparation work for use of land for
pollution control facilities.  Both equipment and labor costs are incorporated
into this value.


1Popper, H.  Modern Cost Engineering Techniques.  McGraw Hill Book Co.
 New York, 1970.

2Hasellparth, J.E. and J.M. Berk.  Chem. Eng., 67_ (10):158 (1960).

3Popper, H.  Modern Cost Engineering Techniques.  McGraw Hill Book Co.
 New York, 1970.  pp. 163.

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       100
                  Carbon Steel (a)
    f   10
        0.1
      1,000
                   V
           7
t  100


^.
vt
TZ
8

=   10
                2  34   6 810 14 IS 24
                 Nominal size, in,

                  Chrome/Moly (b)
           2   34   6  810 1418 24
             Nominal size, in.
                A Standard weight, sen. 40
                B Extra strong, sch. 80
                C Double extra strong, sch. 160
                                                                100
                                                                      field Erection (a)
                                                              1  V/2 2345  £30 1< IE 24
                                                                      Nominal size, in.
                                                         Includes storage, handling, cutting, fining, aligning on pipe
                                                         racks. No line welds, stress relief or X-ray.
                                                                     Yard and Offsile (b)
                                                                100
                                                                 10
                                                             |
                                                                0.1
                                                                                        -f-H
                                                                   1 1V4  2   34   6  8101418 24
                                                                          Nominal size, in.
                                                             Includes storage, handling, cutting, fitting, aligning on ptp*
                                                             racks. No line welds, stress relief or X-ray.
                                 Figure  1.   Piping  Cost  Curves.

Source:   Popper,  Herbert,  Modern Cost Engineering,  1972,  p.   163
             (Used with permission  of McGraw-Hill Book Co.)

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Equipment

     To achieve BATEA levels various pieces of pollution equipment will be
required.  Each piece can be specifically categorized by use of the detailed
list.  These equipment costs should include installation expense since instal-
lation varies with the location and nature of the additional equipment.
Specific cost information for various pieces of equipment is included in
Figures 2 and 3.

Engineering Costs

     The effort expended in development, design, and procurement of the treat-
ment facility are costs incurred by the company.  A breakdown of the elements
considered in these costs could be as follows:

                                                Percent of Cost
              Project engineering                    14.3
              Process engineering                     4.5
              Design and drafting                    26.8
              Procurement                             2.7
              Home office construction                0.8
              Office indirect and overhead           50.9
                                           TOTAL    100.00

     The relationship of engineering costs to the project cost has been
typically considered to be 10% of the equipment costs of Item 6.  There can be
a considerable variability in these values depending upon the specific project.

Construction Costs
    4,
     The costs of construction as itemized in Exhibit 1 includes labor costs
for dismantling, or removing existing structures, field labor, and overhead
costs associated with the direct field labor.  Overhead costs typically are
60% to 80% of direct labor costs, although such costs vary from project to
project, and the following is an example of the cost breakdown associated
with this item:5

                Overhead Elements                         Percent
              Fringe benefits
              Labor burden
              Field supervision
              Temporary facilities
              Construction equipment
              Small tools
              Miscellaneous
                             TOTAL CONSTRUCTION OVERHEAD   100.0
"ibid, pp. 85-86.
5Ibid, pp. 84-85.

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               100000
                                        CAPACITY  (GPM)
                                             10
                                                                      100
            g
           C-J
           i—
           en
            o
            u
            ca
                10000
                 1000
                                                                      100
             DESIGN ADJUSTMENT

         Type            Curve
         Simplex
         Duplex
         Triplex
         Diaphragm
         Slurry
         Rotary
         Gear
A
A
A.
B
B
B
B
  000
  298
  960
  000
  104
0.466
O.S90
                             REGIONAL ADJUSTMENT
Region

  1
  2
  3
  4
  S
  6
  7
  8
  9
 10
  000
  064
0.978
1.034
1.076
1.027
1.066
1.029
1.067
1.033
                           Figure 2.   Pump  Cost Curves

Source:   U.S.  Environmental Protection Agency,  Capital  and Operating Costs
          of  Pollution Control Equipment  Modules,  No. 2.

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                1000000
             o
             a

             K
             cr>
             o
             o
             m   100000
             s
                  10000
                         10.5 HOURS RETENTION TIME
                     0.1
                                             ] .0

                                         CAPACITY  (MGD)
                                                                    10.0
                                    REGIONAL ADJUSTMENT
                              Region
                               1
                               2
                               3
                               4
                               5
                               6
                               7
                               8
                               9
                              10
1.000
1.04S
0.947
1.043
1.133
  041
  066
  065
  067
                                                     1.029
                     Figure 3.   Aeration System Cost Curves

Source:   U.S. Environmental Protection Agency, Capital  and Operating Costs  of
          Pollution Control Equipment  Modules,  No. 2.

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     The specific description of  the  items  listed  in  the  overhead  is  as
follows:

     Fringe Benefits:  Employer's contribution  to  union funds  for  health  and
welfare, vacations, holidays, sick leave, retirement.  Add monies  for travel
and subsistence when required.

     Labor Burden:  Employer's mandatory contributions for Federal Social
Security (FICA), Federal Unemployment Insurance (FUE), State Unemployment
Insurance (SUI) Workmen's Compensation.

     Field Supervision:  Salaries,  fringe benefits and burden  items for super-
visory and field personnel.  Add  travel and subsistence when necessary.

     Temporary Facilities:  Buildings, roadways, parking  yards, work  areas,
scaffolding, rigging,  utilities,  fencing, and miscellaneous.

     Construction Equipment:  Equipment rental  and handling, plus  freight to
and from the jobsite.

     Small Tools:  Expendable construction  tools,  usually valued at $200  or
under.

     Miscellaneous Field Costs:   Job  cleanup, watchmen, minor  equipment
repairs, medical services, welder tests, consumable supplies, warehousing,
vendor services, job insurance such as public liability (PL), public  damage
(PD), automobile, and  all-risk.

Contingency

     The contingency fund covers  unexpected expenses and  is usually a standard
percentage of the project cost.   Such a fund should be minimized for  these
pollution projects.

DESCRIPTION OF OPERATING COST ITEMS

     These costs are defined as the incremental costs of  achieving BATEA
levels.  Operating costs include  not  only variable costs  but also  fixed costs,
such as overhead, depreciation, and cost of capital.  Guidelines for both of
these items will be described herein.

Fixed Costs

Depreciation—
     Depreciation is "an accounting procedure for  allocating outlays  for  capi-
tal assets such as buildings and  equipment  over a  reasonable and acceptable
life."6  Companies charge an annual cost for depreciation in their operating
expenses as a standard practice;  however, the method of computing  the depre-
ciation cost may vary  significantly.   Three variables, salvage value,


6Uhl, V.W., Draft, "A  Standard Procedure of Economic Evaluation for Pollution
  Control Operations,"  IERL/RTP, U.S.  EPA, November, 1977.

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equipment life, and depreciation method, determine the size of the annual
costs of depreciation.  Salvage value is the market price or usefulness
remaining in a piece of equipment at the time of replacement.  Pollution
equipment is typically considered to have a "0" salvage value after full
depreciation.  An equipment life or depreciation period of 10 to 18 years has
usually been selected for pollution control equipment; however, for integrated
steelmaking facilities considering closure, a shorter life span may be
required.  The effect of a change in the useful life can best be illustrated
for three different methods of depreciation.

                                  METHOD 1

                         STRAIGHT LINE DEPRECIATION

         Base Data

                 Value of equipment = $10,000
                 Salvage value      =     0
                 Equipment Life     =     5 years (A) or
                                         10 years (B)

         Calculation Method
              , _  "   .  .   „      equipment price - salvage value
         Annual Depreciation Cost = —*—c	rvi	j	:	*r	
                  v                         life of equipment
                                  METHOD 2

                       SUM-OF-THE-DIGITS DEPRECIATION

         Calculation Method

         Depreciation cost = ["T^TwJ * (C-S)
              in year "t"         -
         where:
                  n = equipment life in number of years
                  C = initial cost
                  S = salvage value
                                      10

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                                METHOD 3

                      DOUBLE-DECLINING DEPRECIATION

       Calculation Method
                                         1          t-1              •)
       Depreciation cost in year "t" = 2(-)(C -. S -  I  D ) or C(l - -)n
                                         n          r=l  r           n
       where:
                n - equipment life in years
                C = initial cost
                S = salvage value
              ED  = sum of the depreciation in year "1" through t-1
                    Case A:  Five Year Equipment Life

       Annual Depreciation   Annual Depreciation   Annual Depreciation
       Cost for Sum-of-      Cost for Straight-    Cost for Double-
Year   Digits Calculation    Line Calculation      Declining Depreciation
1
2
3
4
5
$3330
2670
2000
1330
670
$2000
2000
2000
2000
2000
$4000
2400
1440
860
520
                    Case B;  Ten Year Equipment Life

       Annual Depreciation   Annual Depreciation   Annual Depreciation
       Cost for Sum-of-      Cost for Straight-    Cost for Double-
Year   Digits Calculation    Line Calculation      Declining Depreciation
1
2
3
4
5
6
7
8
9
10
$1820
1640
1450
1270
1090
910
730
550
360
180
$1000
1000
1000
1000
1000
1000
1000
1000
1000
1000
$2000
1600
1280
1024
819
655
524
419
336
269
                                    11

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     There are five specific depreciation techniques which may be used by
companies in calculating the depreciation expense.  In addition to the
straight line, double-declining, and sum-of-the digits depreciation methods,
the rapid amortization and additional first year depreciation offer other
variations.  The following description of these two variations was taken from
a U.S. Technology Transfer document:7

          The Tax Reform Act of 1969 provides for the rapid amortization
     of certified pollution control facilities over a 60-month period,
     irrespective of the guideline useful life of the equipment.  This
     amortization is available under certain conditions outlined in
     Article 169 of the Internal Revenue Code (IRC).  The rapid write-
     off was provided to encourage capital investment in pollution
     control.  Significantly, a process change, even if it results in
     lower pollution, does not qualify as a pollution control device
     and cannot be rapidly amortized.

          As originally legislated, the eligibility period for rapid
     amortization would have expired January 1, 1975.  However, addi-
     tional legislation extended that period for 1 year.  Further
     extensions are currently being considered.

          The rapid amortization applies to the first 15 years of
     equipment life.  The portion of the asset value with a useful life
     of over 15 years can be depreciated by any method under Article 167
     and depreciation can be taken immediately on that portion.  The
     rapid amortization can begin the month after installation and con-
     tinue for a full 60 months, or it can begin in the next fiscal
     year.  For the intervening months until the next fiscal year
     begins, a traditional depreciation method can be used.

          An additional first year depreciation (Section 179, IRC)
     amount of 20 percent of a maximum asset value of $10,000 or a
     maximum deduction of $2,000 can be taken in the first year of an
     asset purchase.  The "bonus" first year depreciation can be taken
     if a taxpayer elects to take the rapid amortization or any other
     method of depreciation.

     The difference in depreciation techniques is important in estimating
cash flows and annual costs to the company.  With the double-declining and
sum-of-the digits depreciation techniques, the first year depreciation costs
for Case A are 100% and 66% greater, respectively.  In Case B, the longer
equipment life increases the difference in depreciation method with the
double-declining and sum-of-the digits depreciation methods resulting in 100%
and 82% greater costs than straight line depreciation in the second year.
Thus, in reviewing the annual operating costs, the depreciation method,
salvage life, and average equipment life should be specified.
7U.S. Environmental Protection Agency.  Choosing Optimum Financial Strategies,
 Technology Transfer.  June, 1976.  p. 6.

                                      12

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Cost of Capital and Method of Financing —
     The method of financing pollution control equipment affects the cost at
which the monies can be utilized  (cost of  capital) .   The choice of using
retained earnings, long-term bonds,  or a stock issue is  associated with
different interest rates, and thus  there can be some variation in the cost of
capital used for pollution control.   The steel industry  presently finances
capital expenditures through a  combination of internal and  external tools;
however, in the last ten years  only 5 percent of the total  financing require-
ment has been external to the company.  This means retained earnings and
depreciation have been primary  sources of  capital.8   The capital requirements
of pollution control and modernization will cause a  greater use of external
financing through bond and stock  issues  according to the US EPA draft economic
impact report.  The average industry capital costs associated  with yields on
common stock and interest rate  on long-term bonds are 3.5 percent* and 9 per-
cent respectively.  If the profitability of the steel industry does not
improve and especially for individual plants even higher rates may be required
to attract investors.  Thus, in evaluating the cost  of capital for an indivi-
dual plant, there will be a range of values, depending upon the method of
financing and profitability of  the firm.  Acceptable rates  of  return for
manufacturing facilities are approximately 15% and 8% for support facilities.

     Computation of the annual  capital expense associated with the pollution
control capital expenditures depends upon  the cost of capital  (interest rate)
and number of years for the investment recovery. The capital  formula for
calculating capital and interest  recovery  in equal,  annual  payments is the
following :
           where i = interest rate on project (8% to  15%  would be
                                               acceptable range)
                 n = number of years
                 C = capital investment

      The average interest rate "i" is a combination  of the  external  financing
 methods utilized to obtain the required capital.


 *This is the historical real rate of return the steel industry has achieved:
  however,  the average manufacturing rate of return is 7%.  To externally
  finance pollution expenses a return of 7% is necessary.

 8Temple, Barker, Sloane, Inc.  Draft, Economic Analysis  of  Proposed  and
  Interim Final Effluent Guidelines for Integrated Iron and  Steel  Industry.
  March, 1976.
                                      13

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Description of Variable Costs

Chemicals—
     Several types of chemicals may be used to treat wastewaters satisfac-
torily.  Lime, chlorine, and soda are the ones most commonly used.  The
appealing company will provide the quantity and type of chemical required.
In Chemical Marketing Reports the prices of bulk chemicals are printed weekly.
In Table 1 the present prices and coding system is provided.  For specific
cost information it is best to contact manufacturers for a direct quote.  A
listing of manufacturers is contained in the Chemical Week's 1978 Buyer's
Guide.


	TABLE 1.  CHEMICAL COSTS9	

           Chemical       Units     Price        Qualification


         Chlorine          ton     $135.00    f.o.b., tanks

         Lime  (pebble)     ton       25.00    bulk of 50,000 Ibs.,
                                              f.o.b.

         Soda  ash          ton       57.00    58%, paper bags, c.l.

         Soda  caustic      ton      140.00    liquid, 50%, f.o.b.,
                                              76% Na20 basis


         c.l.  (car lot)
         f.o.b.  (free on board)
Labor—
     Additional labor may be required to operate pollution control facilities
and handle analytical requirements.  Both maintenance and operating labor have
been aggregated, although different labor rates are likely.

     The labor rates utilized by A.D. Little were based on 1972 costs of
$7.10 per hour or  1975 costs of $10.20 per hour.  In terms of  1977 dollars,
this value is now  $12.00 per hour in the iron and steel industry.

Maintenance—
     Maintenance costs are composed of labor and material expenses.  Mainte-
nance requirements for pollution control equipment can be estimated based upon
previous experience, as a percentage of plant investment, or as a percentage
of labor requirements.  Below are examples of the range of values used in
estimating maintenance costs.


9Chemical Marketing Reporter, November 14, 1977.
                                      14

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Maintenance Cost Estimation Techniques

a)  Total maintenance cost may be  3.5%  of  plant  investment.10

b)  Maintenance material cost may  be  4% of plant investment.11

c)  Total maintenance cost may be  between  4%  and 8%  of  plant
    investment depending upon plant conditions.12

d)  Total maintenance cost may be  0.5%  of  plant  investment
                                                                13
Supervision —
     A portion of the costs of supervision may be included in the incremental
operating costs of pollution control equipment.  This may be estimated by
typical costs through experience or calculation rules.  The following examples
depict the range of costs which would be appropriate.

     1)  Supervision costs equal 10% of all labor costs. **

     2)  For quick estimates and in the absence of other infor-
         mation, supervision can be assumed to average between
         10 and 25% of the operating labor.  Higher figures are
         for complex processes or a multiplicity of small units.15

Utilities—
     To operate pollution control facilities will require electricity, steam,
water, air, and fuel.  For each region these costs will vary depending upon
the source of power and fuel type.  In the monthly publication by the
U.S. Department of Commerce, Survey of Current Business , wholesale price indi-
ces for electricity, coal, oil, and natural gas are printed for each month.
These indices can be used to update regional cost information on fuel costs.

     To determine regional utility prices the Federal Power Commission pub-
lishes the prices of natural gas, oil and coal as purchased by the electric
generating industry.  (These prices must be closely watched since contract
prices represent low, long term rates and would serve as a minimum value while
spot market prices represent current fuel prices.)  The FPC publication No. 22
contains this fuel information.  Industrial power costs can be obtained from
the FPC publication Typical Electric Bill Rates for any region in the United
States.

10U.S. Environmental Protection Agency.  Draft Development for Effluent
  Guideline Limitations for the Iron and Steel Industry.

11 Arthur D. Little.  Steel and the Environment:  A Cost Impact Analysis.
  May, 1975.
12Popper, H.  Modern Cost Engineering Techniques.  McGraw Hill Book Company,
  New York.  1970, p. 243.
13Tihansky, D. "Polution Control in Steelmaking:  Fact or Fiction?"  January,
  1971.
" Arthur D. Little.  Ibid.

15Popper, H.  Ibid., p.  249.

                                      15

-------
     In addition to the charge for gas, oil, and power consumed by pollution
control facilities, there can be an allocation charge for the portion of
capital costs associated with production of utility services.  For example,
if there were an on-site generator which serviced the manufacturing  facility,
a portion of the capital cost could be allocated to the pollution control
project.

Overhead—
     Overhead may be defined in various ways depending upon plant/company
cost accounting techniques.  There are direct and indirect overhead  expenses.
Direct overhead may include plant supervision (this is considered a  separate
item in the cost format) as well as the fringe benefits associated with
employees.  These include insurance costs, sick days, vacation, and  pension
expenses.  These fringe benefits could also be incorporated into the labor
costs.16  Indirect overhead includes auxiliary services, such as secretaries
(plant office expenses), guards, cafeteria, accounting, purchasing,  and plant
engineering (plant engineering is a separate item).  Indirect overhead varies
from 40% to 60% of the sum of direct labor, repair labor, and direct overhead
labor costs.17

Waste Disposal—
     Solid wastes may be generated during wastewater treatment.  These
materials can be either hauled away to landfill, or stored on-site.  The costs
for landfill disposal depend upon the waste content, percent solids, and pH of
the 'material.

COST INFORMATION

     In addition to the general discussion of each cost element, specific cost
information is included as a reference guide.  In the Arthur D. Little,
Incorporated report, Steel and the Environment:   A Cost Impact Analysis,
capital and operating cost data were formulated based upon the steel industry
input.  Cost curves derived from these data represent the most definitive and
complete information available regarding BAT expenses.  Where US-EPA cost
estimates are available, these have also been included to provide a basis for
comparison.

     Table 2 summarizes the treatment technology upon which cost estimates
were formulated.  In Figure 4 through Figure 9 the BAT operating costs for
various plant sizes are derived, and in Figure 10 through Figure 18  the BAT
capital cost curves are illustrated.   These 1.5 curves are based upon 1972
dollar values, and to update these costs to 1977 dollars, the construction
and operating cost indices can be used, which are taken from Chemical
Engineering magazine.


16Popper, H.  Modern Cost Engineering Techniques.  McGraw Hill Book  Company,
  New York.  1970, p.  243.

17Ibid., p. 242-244.
                                     16

-------
    CO
    o
    u

    00
    d
    •H
    4-1
    CO
    l-i
    0)
    n)

    c
$1,000,000
        $300,000
        $200,000
       1000
            2000
10,000
                               tons/day
        Figure 4.  BATEA Operating Costs for Byproduct Coke Process


Source:  Arthur D. Little, Steel and the Environment:  A Cost  Impact  Analysis

         May, 1975.  (Table B-9.)
                                      17

-------
   to
   o
   00


   4J
   Cfl

   (!)

   O

   rH
   fl
   3


   I
        ?1,000,000
        $200,000
        1000
2000
3000
10,000
                                      tons/day
        Figure 5.   BATEA Operating Costs for Iron-Making Blast Furnace


Source:  Arthur D. Little, Steel  and  the  Environment:   A Cojst Impact Analysis,

         May, 1975. (Table B-9. )
                                      18

-------
                 200
                300
Source:
                        tons/day

 Figure 6.  BATEA Operating Costs  for Basic Oxygen Furnace

Arthur D. Little, Steel and the Environment:  A Cost  Impact Analysis,
May, 1975.(Table B-9.)
                                     19

-------
  CO
  •u
  CO

  3

  00
  c
  ct)
  (-1
  (U
  rH
  CO
  3
     $100,000
                                      1000




                                   tons/day



         Figure 7.  BATEA Operating Costs for Electric Arc Furnace



Source:  Arthur D. Little,  Steel  and the Environment:  A Cost Impact Analysis,

         May, 1975.  (Table B-9. )
                                       20

-------
     o
     o
     o
      «\
     o
     o
     m
     o
     o
     o
      •4
     O
     o
     o
     o
     o
      ft
     o
     o
     CM
     O
     O
     O
                $100,000
       1000
10,000
                                   tons/day
        Figure 8.  BATEA Operating Costs for Open Hearth Furnace



Source:  Arthur D. Little, Steel and the Environment:  A Cost Impact Analysis,

         May, 1975. (Table B-9.)
                                     21

-------
  w.
  8
  n)
  M
  0)
  PH
  O
    $100,000
   200
300   400
1000

 tons/day
2000
3000  4000
        Figure 9.  BATEA Operating Costs for Beehive Coke Plant C


Source:  Arthur D. Little, Steel and the Environment:  A Cost Impact Analysis,
         May, 1975. (Table B-9.)
                                      22

-------
10,000,000
 5,000,000
  100 000
1
	 	 1- -H
i
H

i
i
i


1
i

i '
1
	 j





















i


l





















* !
i

i
i j
i




















! i
\
!















i 	 i
! 1 i
! ! 1 ! i


; !983- Y- 24, 349 X










0.57

.J
__1 	


1977-.Y-18.730X0-53


O MEETS PRESENT
• DOES NOT MEET


REGULATIONS.
PRESENT

REGULATIONS.
X-1 EPA ESTIMATE - 1977
X-2 EPA ESTIMATE -1983
       1,000
5,000        10,000
      X-TONS PER DAY
50.000
100,000
                 Figure  10.   BATEA Capital Investment  for
                              Open-Hearth Furnace  (1972 Basis).

Source:   Arthur D. Little,  Steel and the Environment:   A  Cost  Impact Analysis
          May, 1975. (Used with permission of American Iron and Steel Institut

                                       23

-------
IU,UUU,UUU
5000,000
<*
e
0
•w
H
Z
UJ
«j> 1,000,000
>
z
_j
a.
0 500,000
i
>
100,000














o

X
















xj
X















X1
X















x
•/"
^
/*















X
X1















X
x
























1
,-T
J>
X

'

h














/*

>













1983-
•X
x^^
_yX >"
^ S ~.
/ *^

§












X^i-

1
1











>
/-
)77















f























































































1983: Y- 8966 X0-66
1977: Y=5856X°'69
O MEETS PRESENT REGULATIONS.
• DOES NOT MEET PRESENT
REGULATIONS.
X-1 EPA ESTIMATE - 1977
*-Z EPA ESTIMATE -1983
100 300 IjOOO 5,000 10,0
                                   X-TONS PER DAY
         Figure 11.  BATEA Capital Investment  for  Electric Arc
                     Furnace - Wet  Process

Source:   Arthur D. Little, Steel and the Environment:   A Cost Impact Analysis
         May,  1975. (Used with permission of American Iron and Steel Institute.)
                                     24

-------
100,000,000
 50000,000
f
I
10,000000
U 9,000,000
  1.000000
                          ALT U'
                       ,-2 ALT i'
                         i ALTH.
                         1ALT I
         IjOOO                     5,000       10,000
                                      X-TONS PER DAY
         ALT. I-PHYSICAL/CHEMICAL TREATMENT
         ALT. U- BIOLOGICAL TREATMENT
                                                            1983 ALT I
                                                             1983 ALT n
                                                           1977 ALT I

                                                           1977 ALTH
                                                         ALT

                                                           n fl983: Y=55,523X°-6°
                                                             IJ977: Y-40,040X0-60

                                                               {1983: Y = 83,285X°-60
                                                               1977: Y=49,450X
                                                                             0'58
                                                        O MEETS PRESENT REGULATIONS.
                                                        • DOES NOT MEET PRESENT
                                                          REGULATIONS.
                                                        X-1  EPA ESTIMATE - I9T7
                                                        X-2 EPA ESTIMATE-1983
                                                                  50,000
100,000
  Source:
    fcT
                   Figure 12.   BATEA Capital  Investment for
                                By-Product Coke  (1972 Basis).

          Arthur  D.  Little,  Steel and the Environment:  A Cost  Impact Analysis
          May,  1975. (Used with permission of American Iron and Steel Institute.)
                                        25

-------
  10,000,000
   5JOOO.OOO
                                                         1983= Y- 8909X0 62

                                                         1977=Y = 6551X0'64
                                                        O MEETS PRESENT REGULATIONS
                                                        • DOES NOT MEET PRESENT
                                                          REGULATIONS.
                                                            EPA  ESTIMATE - 1977
                                                            EPA  ESTIMATE -1983
    100,000
         too
                                 500         1,000
                                      X-TONS PER  DAY
5,000
10,000
                    Figure 13.  BATEA  Capital Investment  for
                                 Sintering Strands (1972 Basis).

Source:   Arthur D. Little,  Steel and  the Environment:  A Cost Impact Analysis,
          May,  1975. (Used with permission of American Iron and Steel institute.)
                                        26

-------
  100,000,000
   50POO.OOO
 «/> 10,000,000

 >
 a.
 <
 o 5,000,000
   1,000,000














X

r















X
^
^



•












/
/
















198V
X^-1977

































































































,







































1983: Y= 33,207 X065
1977: Y-25.795X0-66
O MEETS PRESENT REGULATIONS.
• DOES NOT MEET PRESENT
REGULATIONS.
X-1 EPA ESTIMATE - t97T
X-2 EPA ESTIMATE -1»§3

5,000 . 10,000 500 100,000
X-TOHS PER DAY
                  Figure 14.  BATEA Capital Investment for

                              Blast Furnace,  Iron (1972 Basis).


Source:  Arthur  D.  Little, Steel and  the  Environment:  A Cost Impact Analysis,

         May,  1975. (Used with permission of American Iron and Steel Institute.,)
                                        27

-------
  10,000,000
   5000,000
                                                          1983: Y-12.833X0-58
                                                          1977.  Y=6607 »0-60
                                                         O MCETS PRESENT REGULATIONS.
                                                         • DOCS NOT MEET PRESENT
                                                          REGULATIONS.
                                                            EPA ESTIMATE - l»77
                                                            EPA ESTIMATE -1M3
    100,000
         I flOO
5,000
     10,000
X-TONS PER DAY
50,000
100,000
                   Figure 15.  BATEA Capital Investment for
                                Basic Oxygen Furnace (1972 Basis).

Source:   Arthur D. Little,  Steel and the Environment:  A Cost  Impact Analysis,
  Q     May,  1975. (Used with permission American Iron and Steel Institute.)

                                         28

-------
   5^00,000
 O

 o
 i
 •>
 bl
 U  500,000
  i
 x
    100,000

















too
















*^
















X""















^
















**
















**
















**
















^
















*








^m^m*^^—****mtlil**mmmmmmmmmmmm



-I,-


.-f^
r^ 7
19776
1983
O



-

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_.***
f^^
>








Y-24
VhMHMMI—m—





^









,089





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mtmtt^f















36















^i^m















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•M








O MEETS PRESENT REGULATIONS.
• DOES NOT MEET PRESENT
REGULATIONS.
X-1 EPA ESTIMATE - (977
X-Z EPA ESTIMATE -19«

SOOt 1.000 9.000 10,000
                                     X-TONS PEA MT
              Figure 16.  BATEA Capital  Investment for Electric Arc
                          Furnace  - Semi-Wet Process (1972 Basis).


Source:  Arthur D. Little,  Steel and the Environment:   A Cost Impact Analysis,
         May, 1975. (Used with permission of American Iron and Steel Institute.)
                                      29

-------
   10,000,000
    5000,000
                                                          1983'. Y=26,490X
                                                          1977: Y= 23,335 X
                                                          O MEETS PRESENT REGULATIONS.
                                                          • DOES NOT MEET PRESENT
                                                            REGULATIONS.
                                                          X-1  EPA ESTIMATE - 1977
                                                          X-Z  EPA ESTIMATE-1983
     100,000
          100
                                  500         1000
                                        X-TONS PER DAY
5,000
10,000
                    Figure 17.  BATEA Capital  Investment for
                                Continuous Casting (1972 Basis).

Source:   Arthur D. Little, Steel  and the Environment:  A Cost  Impact Analysis,
  ^     May, 1975. (Used with permission of American Iron and Steel Institute.)
                                        30

-------
  10,000,000
                               500
     1000
X-TONS PER DAT
                                                                 5000
                                                                          10,000
                  Figure  18.  BATEA Capital  Investment  for
                              Vacuum Degassing  (1972  Basis).

Source:  Arthur D. Little,  Steel  and the  Environment:   A Cost  Impact Analysis,
  (c}    May, 1975. (Used with permission of American Iron and Steel Institute.)
                                      31

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                    TABLE 2.  TREATMENT TECHNOLOGY*
     Process
  In-plant Change
   End-of-pipe Treatment
Coke-making
 By-product
 Beehive

Burden Preparation
 Sintering
Blast Furnace
 Iron
Ferro
 Manganese
Steelmaking
 BOF-semi-wet

 BOF-wet

 Open Hearth
 Electric arc-wet
 Vacuum Degassing
 Continuous Casting
                       Alkaline Chlorination
                       pressure filtration,
                       Carbon Adsorption
                       pH neutralization
        none
        none
                       none
Treat blowdown to activated
alumina
Recycle water within   Treatment of blowdown and
plant after cleanup    sludges
Recycle water within   Treatment of blowdown and
plant after cleanup    sludges
Same as BPT
Blowdown treatment

Blowdown treatment with
anaerobic nitrification
pH neutralization

Blowdown treatment pH
neutralization

Blowdown treatment
anerobic denitrification
pH neutralization

Blowdown filtration
*These processes are the basis of the cost estimates shown in Figure 4
 through Figure 18.
                                  32

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                                 REFERENCES
1.  US-EPA Development Document for Effluent Guidelines for the Iron
    and Steel Industry, PB 238837, NTIS.

2.  Arthur D. Little, Steel and the Environment:  A Cost Impact Analysis,
    May, 1975.

3.  Popper, Herbert, Editor, Modern Cost Engineering Techniques,
    McGraw Hill Book Company, New York, 1970.

4.  US-EPA, Choosing Optimum Financial Strategies, Technology Transfer
    Seminar Publication, June, 1976.

5.  Jelen, F.C. Editor, Cost and Optimization Engineering,
    McGraw Hill Book Company, New York, 1970.

6.  Chemical Marketing Reporter, November 14, 1977.

7.  Chemical Engineering, vol. 84, no. 20. November, 1977.

8.  U.S. Department of Commerce, Survey of Current Business, published
    monthly-

9.  Temple, Barker, Sloane, draft copy, Economic Analysis of Proposed
    and Interim Final Effluent Guidelines for Integrated Iron and Steel
    Industry, March, 1976.
                                      33

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                                  EXHIBIT 1
                       BAT CAPITAL COST SPECIFICATION
 1.  Process Category:
 2.  Process Subcategory:
 3.  Process Capacity:
 4.  Design Basis:

5.
6.
CAPITAL COST ITEM
Land
Site Preparation
IN-PROCESS
COST

END-OF-PIPE
COST

TOTAL COST

      Grading
      Sewers
      Roads-Walks
      Foundations
      Structures Supporting
       Equipment
 7.   Equipment
      Pumps
      Tanks-storage
      Tanks-treatment
      Filters
      Compressor Fans and
       Blowers
      Conveying Equipment
 8.   Instrumentation
 9.   Piping
10.   Insulation
11.   Electrical equipment
12.   Construction expense-
      a.  Dismantling; demolition
      b.  New construction
13.   Engineering Services
14.   Insurance
15.   Taxes
16.   Contingency
17.   Total Capital Cost
                                     34

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                                  EXHIBIT 2
                      BAT OPERATING COST SPECIFICATION
1.  Process Category:
2.  Process Subcategory:
    Process Capacity:
    Treatment Design:
    VARIABLE COSTS
3.
4.
5.
  a) Chemicals
  b) Labor
  c) Maintenance
  d) Supervision
  e) Utilities
     electricity
     air
     water
     steam
  f) Overhead
  g) Waste Disposal
6.  FIXED COSTS
  a) Cost of Capital
     Interest rate
  b) Depreciation
     average equipment life
     salvage value
     method of depreciation
  c) Taxes
  d) Insurance
7.  CREDITS
UNIT COST
                                                UNITS
                                                          TOTAL ANNUAL COST
8.  TOTAL ANNUAL COST
                                     35

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     INSTRUCTIONS FOR COMPLETING EXHIBIT 1 and EXHIBIT 2

     The forms attached are to be completed by the appealing company for each
process category which may be affected under the appeal.
                            EXHIBIT 1 INSTRUCTION

 1. and 2.  Name the process category and subcategory for which the costs
     have been estimated.

 3.  Specify the total process capacity in ton per day for which waste
     treatment is required.  This capacity should represent the maximum
     monthly level achieved in the last five years.

 4.  Specify the treatment technology and design basis for the costs pre-
     sented.  Include flow rates, detention times, and a flow sheet of the
     proposed system.

 5. thru 13.  Capital cost items are broken down into typical elements of
     estimation.  For cases where in-process changes are required in addition
     to the effluent treatment, these values should be segregated into the
     appropriate columns.

 7. thru 11.  Indicate equipment and instrument costs based upon installed
     cost estimates with minimum auxiliary supports.

12.  Construction costs incurred, such as dismantling fixtures to prepare
     the site, demolition, or repair work should include labor and material
     charges.

13.  Engineering services include costs for research and development, pilot
     plant work, consulting fees, and other costs for designing and directing
     the installation of treatment facilities.  Cost items would be supplies,
     labor, administrative, and overhead expenses.
                                                                     .'
14.  Insurance costs associated with the project addition should be included.

15.  Taxes incurred on a one-time basis are itemized here.

16.  A contingency fund for the pollution project can be specified but should
     not exceed 10% of the total project cost.

17.  The total capital cost is the sum of items 4 through 15.
                                      36

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                           EXHIBIT  2  INSTRUCTIONS
1. and 2.  Name the process category,  subcategory  for  which costs  have been
    estimated.

3.  Specify process capacity in  tons per  day  for which waste treatment is
    required.  This capacity should represent the  maximum monthly  average
    in the last five year period.

4.  Specify the treatment technology and  design basis  for the costs presented.
    Include flow rates, detention  times,  and  a flow sheet of the proposed
    system.

5.  Variable costs of operating  the BAT pollution  facilities are itemized in
    a) through g) .  Please list  the unit  cost, total units  required, and
    total annual cost for each of  these items.

6.  Fixed costs of operating pollution control equipment  costs of items a)
    through d) .  The cost of capital a) and depreciation  expense b) may be
    combined into one amortization rate if desired.

    6a.  List the interest rate  utilized  in determining the cost of
         capital and the financing method which is considered for
         obtaining funds.

    6b.  Please specify the depreciation  method, the average number
         of years for equipment  life,  and salvage  value used in
         calculating the depreciation  expense.

    6c.  List the incremental taxes increase  associated with this
         project.

    6d.  List the incremental insurance costs associated  with this
         project.

7.  Costs  savings due to reduced chemical usage or other  expenses  should be
    entered as a credit to pollution control  costs.

8.  Add  items 5 and  6 and subtract the value  of item 7 to determine the
    total  annual cost.
                                      37

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                                 Appendix A

     COMMENTS FROM US-EPA REGIONAL PERSONNEL REGARDING DRAFT COST FORMAT
Aspect of Format

1. Type of Cost
   Information
   Presented
                         Comment
2. Nature of Cost
   Format
3. Specific Cost
   Elements
Region V - The most useful cost information would be
general cost curves for various production levels or
plant sizes.  These costs should also be presented on a
per unit production basis if possible.

Region III - With the proposed 301C regulation implemented,
cost verification would not be required.  It is important,
however, to develop cost curves associated with BATEA
treatment processes and treatment processes not specified
as BATEA by the US-EPA.  The BATEA treatment processes do
not necessarily represent the most cost-effective way of
achieving BATEA effluent levelsN and perhaps other methods
and their costs could be presented.

Region V - It is good to specify the format for cost
elements and to identify as particularly as possible the
cost elements included5.  Separation of in-plant versus
end-of-pipe costs is vital.

Region III - A format for the cost presentation is useful
if all cost elements are broken down and identified.
Verification of costs will not be a major regional respon-
sibility but understanding and analyzing elements is
important.

Region V - Presentation of specific equipment cost data
would be useful.  Designate the installed versus purchase
price of equipment.  Specific inclusion of site prepara-
tion such as dismantling of existing equipment is an
important cost.  It is important to have reference for
verifying or obtaining additional cost information.

Region III - Equipment costs are valuable but also the
cost presentation must be viewed in terms of the economic
analysis.  Discussion of financing, depreciation, and
interest rates are important to the actual use of such a
format.  Inclusion of cost credits in the format is
important.
                                      38

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                                TECHNICAL REPORT DATA
                          (Please read Instructions on the reverse before completing)
 . REPORT NO.
 EPA-600/2-79-025
2.
                           3. RECIPIENT'S ACCESSION NO.
      AND SUBTITLE
A Cost Index Format for BATEA Achievement by the
   Iron and Steel Industry
                           5. REPORT DATE
                            January 1979
                           6. PERFORMING ORGANIZATION CODE
 AUTHOR(S)
L.L. Huff and J.D. Stockham
                           8. PERFORMING ORGANIZATION REPORT NO
9. PERFORMING ORGANIZATION NAME AND ADDRESS
IJT Research Institute
10 West 35th Street
Chicago,  Illinois  60616
                           10. PROGRAM ELEMENT NO.
                           1BB610
                           11. CONTRACT/GRANT NO.

                           68-02-2617, Task 2-4
12. SPONSORING AGENCY NAME AND ADDRESS
 EPA, Office of Research and Development
 Industrial Environmental Research Laboratory
 Research Triangle Park, NC  27711
                           13. TYPE OF REPORT AND PERIOD COVERED
                           Task Final; 8/77 - 1/78
                           14. SPONSORING AGENCY CODE
                             EPA/600/13
15.SUPPLEMENTARY NOTES JERL-RTP project officer is John S. Ruppersberger, Mail Drop
62,919/541-2733.
 16. ABSTRACT
          The report describes a study to develop a format for Best Available Tech-
 nology Economically Achievable (BATEA) cost analysis, including pertinent cost
 data.  The format is to aid Regional U.S. EPA personnel in evaluating economic
 appeal cases for BATEA. Through discussion with U.S. EPA Regional personnel anc
 a review of cost engineering literature, two sample formats were developed: one
 for capital investment; the other for operating costs.  The cost analysis formats were
 designed specifically for application to the iron and steel industry; although, with
 modification, they could be used for other industries  as well.  General information
 regarding various cost components  is provided as a basis for analyzing cost esti-
 mates presented by specific iron and steel plants.
17.
                             KEY WORDS AND DOCUMENT ANALYSIS
                DESCRIPTORS
                                          b.lDENTIFIERS/OPEN ENDED TERMS
                                       c.  COSATI Field/Group
 Pollution
 Iron and Steel Industry
 Cost Analysis
 Cost Engineering
 Capitalized Costs
 Operating Costs
                Pollution Control
                Stationary Sources
                BATEA
13B
11F
14A

05A
18. DISTRIBUTION STATEMENT

 Unlimited
               19. SECURITY CLASS (This Report)
               Unclassified      	
                                                                   21. NO. OF PAGES
     43
               20. SECURITY CLASS (Thispage)
               Unclassified
                                        22. PRICE
EPA Form 2220-1 (9-73)
                                      39

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