Asphalt Roofing Manufacturing Industry: Background Information for Proposed Standards Draft EIS


                          Background Information
                                 and Draft
                      Environmental Impact Statement
          for Standards of Performance for New Stationary Sources
             Asphalt Processing and Asphalt Roofing Manufacture

                      Type of Action:  Administrative

                               Prepared by:
                                                          5*-
Ddn R. GoodwVn
Director, Emission Standards and Engineering Division
Environmental Protection Agency
Research Triangle Park, N. C.  27711

                               Approved by:
 (Date)
                                                              - 30 -
David G. Hawkins
Assistant Administrator for Air, Noise, and Radiation
Environmental Protection Agency
Washington, D. C.  20460

Draft Statement Submitted to EPA's .
Office of Federal Activities for Review on
This document may be reviewed at:

Central Docket Section
Room 2902, Waterside Mall
Environmental Protection Agency
401 M Street, S.W.
Washington, D. C.  20460

Additional copies may be obtained at:

Environmental Protection Agency Library (MD-35)
Research Triangle Park, N. C.  27711

National Technical Information Service
5285 Port Royal Road
Springfield, Virginia  22161
 (Date)
iTulyy mo
 (Date)

-------

-------
                            EPA-450/3-80-021a
     Asphalt Roofing
              ing Industry —
for Proposed  Standards
    Emission Standards and Engineering Division
    U.S. ENVIRONMENTAL PROTECTION AGENCY
       Office of Air, Noise, and Radiation
    Office of Air Quality Planning and Standards
    Research Triangle Park, North Carolina 27711
              June 1980

-------
This report has been reviewed by the Emission Standards and Engineering
Division of the Office of Air Quality Planning and Standards, EPA, and
approved for publication.  Mention of trade names or commercial products
is not intended to constitute endorsement or recommendation for use.  Copies
of this report are available through the Library Services Office (MD-35) ,
U.S. Environmental Protection Agency,  Research Triangle Park, N.C. 27711,
or from National Technical Information Services, 5285 Port Royal Road,
Springfield,  Virginia 22161.
                      Publication No. EPA-450/3-80-021a
                                      11

-------
                            TABLE OF CONTENTS


                                                                 Page

List of Figures	,	v

List of Tables	viii

CHAPTER 1   SUMMARY	  1-1

      1.1   Regulatory Alternatives ...... 	  1-1

      1.2   Environmental Impact  ...	  1-2

      1.3   Economic Impact	1-2

CHAPTER 2   INTRODUCTION		    2-1

      2.1   Background and Authority for the Standards  ....  2-1

      2.2   Selection of Categories of Stationary Sources .  . .  2-5

      2.3   Procedure for Development of Standards of
            Performance	2-6

      2.4   Consideration of Costs	 2-9

      2.5   Consideration of Environmental Impacts   ...... 2-10

      2.6   Impact on Existing Sources   	 2-11

      2.7   Revision of Standards of Performance   .  .  .  .  .  .  .2-11

CHAPTER 3   THE ASPHALT ROOFING MANUFACTURING INDUSTRY  ....  3-1

     3.1    General	3-1

     3.2    Processes and Their Emissions 	  3-8

     3.3    Baseline Emissions  	  3-39

     3.4    References for Chapter 3  .  . .	3-47

CHAPTER 4   EMISSION CONTROL TECHNIQUES   	  ......  4-1

     4.1    Introduction	  4-1

     4.2    Process and Equipment Controls	  4-1

     4.3    Control Systems ..;......	  4-5

-------
                      TABLE OF CONTENTS (continued)
                                                                 Page
     4.4
     4.5
CHAPTER 5
     5.1
     5.2
     5.3
CHAPTER 6
     6.1
     6.2
     6.3
     6.4
CHAPTER 7
     7.1
     7.2
     7.3
     7.4
     7.5
     7.6
     7.7
 CHAPTER 8
      8.1
      8.2
      8.3
      8.4
Performance of Emission Control  Systems 	   4-28
References for Chapter 4	4-55
MODIFICATION AND RECONSTRUCTION 	   5-1
40 CFR Part 60 Provisions for Modification
and Reconstruction  .	5~2
Applicability to Asphalt Roofing Plants 	   5-3
Summary 	
MODEL PLANTS AND REGULATORY ALTERNATIVES
Purpose    	•	
5-4
6-1
6-1
Model Plants	6"1
Regulatory Alternatives  	  6~16
References for Chapter 6	6~23
ENVIRONMENTAL IMPACT   	  7~1
Air Pollution Impact   	  7-1
Water Pollution Impact  	  7~27
Solid Waste  Disposal   	  7~27
 Energy Impact 	  7"28
 Other Environmental Impacts 	  7"30
 Other Environmental Concerns  	  7~32
 References for Chapter 7	7~33
 ECONOMIC IMPACT   	    8"1
 Industry Characterization   	    8-1
 Cost Analysis of Regulatory Alternatives  	    8-56
 Other Cost Considerations   	    8-123
 Economic Impact Assessment  	    8-123
                                    IV

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                      TABLE OF CONTENTS (concluded)


                                                                  Page

     8.5    Socio-Economic Impact Assessment.	   8-141

     8.6    References for Chapter 8	   8-144

APPENDIX A  EVOLUTION OF THE PROPOSED STANDARD  ... 	   A-1

     A-l    Chronology	   A--]

APPENDIX B  INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS  ...   B-l

APPENDIX C  SUMMARY OF TEST DATA	     c-1

     C.I    Introduction	   C-1

     C.2    Emission Test Program for Manufacture of Asphalt
            Roofing	   C-1

     C.3    Emission Test Program for Selected Non-Metallic
            Mineral Processes .  .  .  .	 .   c-4

APPENDIX D  EMISSION MEASUREMENT AND CONTINUOUS MONITORING  . .   D-l

     D.I    Emission Measurement Methods  .  .  .  .  .  . .  .  .  . .   D-l

     D.2    Continuous Monitoring	   D-3

     D. 3    Performance Test Methods	   D-4

-------
                             LIST OF FIGURES
Figure 1-1

Figure 3-1
Figure 3-2

Figure 3-3

Figure 3-4

Figure 3-5
Figure 3-6

Figure 3-7
Figure 3-8
Figure 3-9
Figure 3-10
Figure 3-11
Figure 3-12
Figure 3-13
Figure 3-14
Figure 3-15

 Figure  3-16
 Figure  4-1

 Figure 4-2
Matrix of Environmental and Economic Impacts
for Regulatory Alternatives 	
Processing Chart for Asphalt Roofing Products from
Raw Materials to Finished Roofing 	
Location of Asphalt Roofing Manufacturing
Facilities Within the United States 	
Typical Flow Diagram for Production of Asphalt-
Saturated Felt	
Typical Flow Sheet for Manufacturing Shingles
and Rolls 	
Block Diagram, Asphalt  Roofing  Line
Surfacing  Section  of Typical Asphalt  Roofing
Manufacturing  Line 	
 Alternative Method  for  Applying  Parting Agent  .  .
 Asphalt  Delivery  Systems	
 In-Plant Asphalt  Transfers   	
 Mineral  Products  Delivery 	
 Pneumatic Conveying Systems 	
 Block Diagram of In-plant Transfers and
 Temporary Storage 	
 In-plant Transfer of Bagged Mineral  Products
 Air-Blowing of Asphalt  	
 Design Features of Vertical Still  Equipped with
 a Cyclone Oil Recovery System .  .  	
 Design Features of Horizontal Still
 Total Enclosure of Saturator, Wet Looper,
 and Coater	
 Typical Rotary Drum High Velocity Air
 Filter Installation 	
                                                                 Page
1-3

3-2

3"-7

3-9

3-10
3-11

3-14
3-16
3-20
3-21
3-24
3-25

3-27
3-28
3-31

3-33
3-34

4-7

4-9
                                    VI

-------
                       LIST OF FIGURES (continued)
Figure 4-3



Figure 4-4

Figure 4-5


Figure 4-6


Figure 4-7


Figure 4-8


Figure 4-9



Figure 4-10


Figure 4-11

Figure 4-12


Figure 4-13


Figure 4-14


Figure 4-15


Figure 6-1

Figure 6-2

Figure 6-3

Figure 6-4

Figure 6-5
HVAF Filter Media Filtration Efficiency as a
Function of Filter Face Velocity for Different
Filter Media    	
Typical Mini-HVAF
Schematic of Retaining Screens and Fiber Packing
of a Mist Eliminator
Page



4-11

4-13


4-15
Typical Mist Eliminator Element to Control
Emissions from Asphalt Storage Tank 	   4-16

Steps Required for Successful Incineration of
Combustible Dilute Fumes in a Thermal Afterburner   4-19
Coupled Effects of Time and Temperature on Rate
of Pollutant Oxidation  .  .  .	
Typical Effect of Operating Temperature on
Effectiveness of Thermal Afterburner (Snf) for
Destruction of Hydrocarbons and CarbonMonoxide

Schematic of a Two-Pass Modular Electrostatic
Precipitator. ....... 	 .
4-20
4-21
4-24
Modular Electrostatic Precipitator  	   4-25

Particulate Emissions from Asphalt Roofing Processes
When Various Control Devices are Used (EPA Tests)   4-42
Extrapolation of Efficiency Versus Temperature
Curve for the Afterburners at Plant B 	
4-49
Particulate Emissions from an Afterburner
Controlling an Asphalt Blowing Still  	    4-51

Particulate Emissions from Crushed Stone
Facilities	    4-53

Configuration 1 for Small Plant .........    6-4

Configuration 2 for Small Plant".	    6-5

Configuration 1 for Medium Plant   	   6-6

Configuration 2 for Medium Plant   	   6-7

Configuration 1 for Large Plant  	   6-8

-------
LIST OF FIGURES (concluded)

Figure 6-6
Figure 6-7
Figure 8-1

Figure 8-2

Figure 8-3

Figure 8-4
Figure 8-5
Figure 8-6
Figure C-l

Figure C-2
Figure C-3
^
Figure C-4
Figure C-5
Figure C-6
Figure C-7

Figure C-8

Figure C-9

Configuration 2 for Large Plant 	
Regulatory Alternatives and Controlled Facilities
Processing Chart for Asphalt Roofing Products:
From Raw Materials to Finished Roofing 	
106.6-kg (235-lb), 3-Tab, Self-Seal Strip
Shingle 	
Location of Asphalt Roofing Manufacturing
Facilities Within the United States 	
Shipping Trends in Roofing Manufacturing 	
Stability in Asphalt Roofing Production 	
Relationship Between Price and Production ....
Schematic of Ducting Arrangement and Test
Points (TP)— Plant A 	
Block Diagram Showing Relative Locations of
Process Components and Sample Points — Plant B . .
Schematic of Emission Sources Controlled by
HVAF Including Test Point (TP) . 	 	
HVAF Stack Outlet— Plant C 	
HVAF Inlet Duct (Fugitive)— Plant C 	
Satu'rator Spray/Dip (Fugitive)— Plant C 	
Saturator Strike-In and Coater (Fugitive)—
Plant C 	
Block Diagram Showing Sampling Location--
Plant D 	
Block Diagram Showing Relative Locations of
Process Comoonents and Sample Points — Plant E . .
Page
6-9
6-17

8-3
8-t |—
-15

8-20
8-35
8-127
8-128

C-7
C-16

C-27
C-28
C-29
C-30
CO T
"0 1
CO O
-oo
C-42

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                              LIST OF TABLES

                                                                 Page

Table 3-1   Emission Sources  and Variables Affecting Emissions
            in an Asphalt Roofing Plant	 .  3-35

Table 3-2   Uncontrolled Emissions from  Asphalt Roofing Plants
            From Test Data	  3-37

Table 3-3   Summary of Emission Regulations and Location of
            Asphalt Roofing Plants by State ..........  3-40

Table 3-4   Baseline Particulate Emissions for Various Size
            Model Plants According to State Implementation
            Plans (SIP's)	•	3.46

Table 4-1   Asphalt Roofing Plant Emission Sources and Add-On
            Control Devices ......  	 ......  4-2

Table 4-2   Asphalt Parameters  ......	    4-4

Table 4-3   Storage and Operating Temperatures  	  4-6

Table 4-4   EPA Test Data at Asphalt Roofing Plant A (Metric) .  4-29

Table 4-4a  EPA Test Data at Asphalt Roofing Plant A (English)   4-30

Table 4-5   EPA Test Data at Asphalt Roofing Plant B (Metric) .   4-31

Table 4-5a  EPA Test Data at Asphalt Roofing Plant B (English)   4-33

Table 4-6   EPA Test Data at Asphalt Roofing
            Plants C and D (Metric)	   4-35

Table 4-6a  EPA Test Data at Asphalt Roofing
            Plants C and D (English)		4-37

Table 4-7_  EPA Test Data at Asphalt Roofing Plant E (Metric) .   4-39

Table 4-7a  EPA Test Data at Asphalt Roofing Plant E (English)   4-40

Table 4-8   Summary of Fugitive Emissions Data from
            Capture Systems	4-43

Table 4-9   Summary of Visible Emission Tests - Control  Device
            Stack Outlet  .	 .	4-46

Table 4-10  Visible Emissions from Minerals Handling and
            Storage Facilities  ................   4-54
                                   IX

-------
                       .LIST OF TABLES (continued)
Table 6-1   Model Plant Production Rates and Operating
Table 6-2
Table 6-3
Table 6-4
Table 6-5
Table 6-6
Table 6-7
Table 6-8
Table 6-9
Table 7-1
Table 7-2
Table 7-3
Table 7-4
Table 7-5
Table 7-6
Table 7-7
Paramp1*pr^ 	 	 	
Rlnu/i nn ^ti 1 1 Parampfpr<; for Model PI ants ....
Raw Materials and Utility Requirements
•fnr Mnripl Plants 	
Baseline Model Plant Control System -
Altprnativp 1 ( Small") 	
Baseline Model Plant Control System -
AT tovnatn \/p 1 fMprHuni^ 	
Baseline Model Plant Control System -
Altpynati VP 1 (\ arnp^ 	 	
Model Plant Control Systems for
Poniil a-hnyv AT tpynal" i UP<; 9 tf) *i f Sinai 1^ ....
Model Plant Control Systems for
Regulatory Alternatives 2 to 5 (Medium) 	
Model Plant Control Systems for
Dannl atnv»\/ AT tpvnat 1 \/P«; ? tn R (\ arOP.^ 	
Annual Mass Particulate Emissions from Baseline
Model Plants With and Without Blowing Still
f AT •hpv*na1~i VP 1^ 	
Annual Mass Particulate Emissions from Small Plants
•fny Rpnnl atnrv Altprnatives 2 Throuah 5 	
Annual Mass Particulate Emissions from Medium Plants
•fnv» Rpnnl atnrv A~l tprnati ves 2 Throuah 5 . . . . *.
Annual Mass Particulate Emissions from Large Plants
•fnv Rprml atnrv A~l tprnati ves 2 Throuoh 5 	
Summary of SO and CO Emissions from Afterburners
Used to Control a Saturator and a Blowing Still . .
Stack and Building Coordinates
anri nimpn<;inn<; CAT 1 Plant Sizes) 	
Stack Exit Temperature, Exit Velocities, and
Particulate Emission Rates for Medium Plants
(Metric") 	
6-2
6-3
6-12
6-13
6-14
6-15
6-20
6-21
6-22
7-2
7-4
7-5
7-6
7-7
7-9
7-10

-------
                        LIST OF  TABLES  (continued)
                                                                  Paqe
Table 7-7a   Stack  Exit  Temperature,  Exit  Velocities,  and
             Particulate Emission  Rates  for  Medium  Plants
             (English)	7-11

Table 7-8    Regulatory  Alternatives  Applicable  to  the Twelve
             Hypothetical Asphalt  Roofing  Plants  	   7-12

Table 7-9    Calculated  Maximum 24-Hour  Average  Ground-Level
             Particulate Concentrations  for  the  Individual
             Stacks at Medium Asphalt Roofing Plants . 	   7-14

Table 7-10   Maximum 24-Hour Average  Concentrations at the Plant
             Boundary for the Combined Stacks of  the Medium
             Asphalt Roofing Plants (Metric) . .  .  . . . . . .  .   7-15

Table 7-10a  Maximum 24-Hour Average  Concentrations at the Plant
             Boundary for the Combined Stacks of  the Medium
             Asp'halt Roofing Plants (English)	7-19

Table 7-11   Maximum 24-Hour Average  Particulate  Concentrations
             Calculated  for Medium Configuration  Cl Asphalt
             Roofing Plants (Regulatory Alternative 1) Located
             in the Pittsburgh and Oklahoma City  Areas .....   7-23

Table 7-12   Maximum 24-Hour Average  Particulate  Concentrations
             Calculated  for the Combined Stacks of the Medium-
             Size Asphalt Roofing Plants .  .  .  .	7-25

Table 7-13   Summary of  Annual Total  Particulate  Emissions from
             Model Plant Configurations 1 and 2 (All Sizes) Under
             the Various Regulatory Alternatives  and the Percent
             Reduction in Emissions from the Baseline Model Plant
             for the Various Alternatives	   7-26

Table 7-14   Electricity Increase Over Baseline Electrical
             Demand for  Regulatory Alternatives 2, 3, 4,  and 5 .  7-29

Table 7-15  Annual  Energy Requirement for Afterburners and
             Percent Fuel Increase from Baseline Model  Plant
             for the Various Regulatory Alternatives ......  7-31

Table 8-1   ASTM Specifications for Roll Roofing
            Saturants (Metric).	8-4

Table 8-la  ASTM Specifications for Roll Roofing
            Saturants (English)	     8-5

Table 8-2   ASTM Specifications for Shingle Saturants (Metric).  8-6

-------
                      • LIST OF TABLES (continued)
                                                                 Page
Table 8-2a  ASTM Specifications for Shingle Saturants (English)  8-7
Table 8-3   ASTM Specifications for Coating Asphalts (Metric) .  8-8
Table 8-3a  ASTM Specifications for Coating Asphalts (English).  8-9
Table 8-4   Typical Asphalt Roofing Products (Metric) 	  8-11
Table 8-4a  Typical Asphalt Roofing Products (English)	  8-12
Table 8-5   Typical Roofing Compositions (Metric) 	  8-13
Table 8-5a  Typical Roofing Compositions (English)	8-14
Table 8-6   Asphalt Roofing Manufacturers  	  8-17
Table 8-7   Quantities of Asphalt Roofing  Product Shipments
            in 1977, by Region	8-22
Table 8-8   Annual U.S. Production, Consumption, Imports,
            Exports, and Stock of Asphalt,  1969-1977
            (Thousands of m3  of Asphalt)	8-24
Table 8-8a  Annual U.S. Production, Consumption, Imports,
            Exports, and Stock of Asphalt  1969-1977
            (Thousands of Barrels of Asphalt)  	  8-25
Table 8-9   U.S.  Distribution of Asphalt Production
            Capacity, by State	  8-27
Table 8-10  U.S.  Asphalt Production Capacity,  by Company.  .  .  .  8-29
Table 8-11  Annual Production of Asphalt and Tar Roofing
            and  Siding Products  (in Megagrams)	8-31
Table 8-11 a Annual Production of Asphalt and Tar Roofing
            and  Siding Products  (in Tons)	8-32
Table 8-12  Quantities of  Asphalt  Roofing  Product
            Shipments  by Region,  1970-1977	8-33
Table 8-13  Annual Production of Asphalt and Tar Roofing
            and  Siding Products  as  a  Percent of Total
            Annual Production,  1970-1977  	  8-34
Table 8-14   Estimated  Annual  Employment in the Asphalt
             Roofing  and  Siding  Products Industry,  1969-1976 .  .  8-36

-------
                       LIST OF TABLES.(cpntinued)
                                                                 Page

Table 8-15  Producer Price Index for Asphalt Roofing and
            Price of'Asphalt Roofing Strip Shingles, 1969-1978   8-39

Table'8-16  Manufacturers' Prices of Standard Asphalt
            Shingles to Distributor 	  8-40

Table 8-17  Values and Quantities of Product Shipments in the
            Asphalt and Tar Roofing and Siding Products
            Industry, 1969-1976 .  .  .  .	8-41

Table 8-18  Value of Product Shipments in the Asphalt
            Roofing Industry, 1969-1976	  8-43

Table 8-19  Purchase Prices of Various Roofing Asphalts
            from 1974 to 1979	8-44

Table 8-20  Producer Price Indices and Percent Increases
            for Selected Products in the Pulp, Paper, and
            Allied Products Industry,  1970-1978 	  8-45

Table 8-21  Annual Production and Percent Annual  Production
            Changes from Year to Year in Asphalt Roofing and
            Siding Products,  1969-1977 (Metric) ....;...  8-47

Table 8-21 a Annual Production and Percent Annual  Production
            Changes from Year to Year in Asphalt Roofing
            and Siding Products, 1969-1977 (English)  	  8-48

Table 8-22  Estimated Annual  Expenditures for New Plant
            and Equipment by  the Asphalt Roofing and
            Siding Industry,  1969-1976.	  8-50

Table 8-23  Estimated Annual  Expenditures for New Plant
            and Equipment by  the Asphalt Roofing and Siding
            Industry,  Adjusted to 1957-1959 Dollars,
            for 1969-1976	  8-51

Table 8-24  Estimated End-of-Year Gross  Book Value of
            Assets in the Asphalt Roofing Industry,
            1969-1976	  8-52

Table 8-25  Estimated End-of-Year Gross  Book Value of
            Depreciable Assets in the Asphalt Roofing and Siding
            Industry,  Adjusted to 1957-1959 Dollars,
            1969-1976	8-54

Table 8-26  Chemical  Engineering Plant Cost Indices and
            Subcomponents for October 1973 and November 1978.  .  8-58

-------
                       LIST OF TABLES (continued)
                                                                 Page
Table 8-27  Estimated Capital Investment Costs of New Asphalt
            Roofing Facilities Without Pollution
            Control Equipment 	  8-60

Table 8-28  Estimated Total Annualized Costs for New Asphalt
            Roofing Plants Without Pollution Control Equipment.  8-63

Table 8-29  Annual Raw Material Costs for Asphalt
            Roofing Plants (Metric)  ;	  8-64

Table 8-29a Annual Raw Material Costs for Asphalt
            Roofing Plants (English)	8-65

Table 8-30  Annual Utility Requirements and Costs for Model
            Asphalt Roofing  Plants Without Pollution Control
            Equipment (Metric)	8-68

Table 8-30a Annual Utility Requirements and Costs for Model
            Asphalt Roofing  Plants Without Pollution Control
            Equipment (English)	  8-69

Table 8-31  Annualized Costs and  Unit Product  Costs of  New
            Model  Asphalt  Roofing Plants Without Pollution
            Control Systems  	  8-71

Table 8-32  Pollution Control  Systems and Operating
            Characteristics  for  Baseline Asphalt Roofing  Model
            Plants (Metric)  	  8-74

Table 8-32a Pollution Control  Systems and Operating
            Characteristics  for  Baseline Asphalt Roofing  Model
            Plants (English)	8-75

Table 8-33  Pollution Control  Systems and Operating
            Characteristics  for  Regulatory Alternatives 2 to 5
             (Metric)	8-76

Table 8-33a Pollution Control  Systems and Operating
            Characteristics  for  Regulatory Alternatives 2 to 5
             (English)	8-77

Table 8-34 Uncontrolled Particulate Emissions from  Each
            Operation  at the Model Asphalt  Roofing  Plants
             on an Annual Basis	8-83

Table 8-35  Uncontrolled Particulate Emissions, Control
             Emissions,  and Particulate  Pollutants  Collected for
             Each Model  Asphalt Roofing  Plant Operation and
             Pollution Control Device	8-85
                                    xiv

-------
                        LIST OF TABLES (continued)


 Table 8-36  Control  Efficiencies of the Pollution Control
             Devices  Used in the Model Asphalt Roofing Plants
 Page


 8-87
 Table 8-37   Capital  Investment Costs  of Pollution Control
             Systems  for the Baseline  Model  Asphalt Roofing
         •    Plants	......._	   8-88

 Table 8-38   Capital  Investment Costs  of Pollution Control
             Systems  for Model  Asphalt Roofing Plants  for
             Regulatory  Alternatives 2 and 3	8-89

 Table 8-39   Capital  Investment Costs  of Pollution Control
             Systems  for Model  Asphalt Roofing Plants  for
             Regulatory  Alternatives 4 and 5	8-90

 Table 8-40   Capital  Cost Increase  from Baseline  for Pollution
             Control  Systems  ..........  	   8-96

 Table 8-41   Total Annualized Cost  of  Pollution Control Systems
             for Model Asphalt  Roofing Plants  for  the  Five
             Regulatory  Alternatives Without Recovery  Credits. .   8-98

 Table 8-42   Annual Labor and Supervision Cost Increase from
             Baseline for Model Asphalt  Roofing Plant
             Pollution Control  Devices	   8-99
Table 8-43  Annual Utility Requirements and Cost Increase from
            Baseline for Individual Pollution Control Devices
            Used in Model Asphalt Roofing Plants (Metric) , .

Table 8-43a Annual Utility Requirements and Cost Increase from
            Baseline for Individual Pollution Control Devices
            Used in Model Asphalt Roofing Plants (English). . .

Table 8-44  Increase in Annual Variable and Fixed Operating
            Costs from Baseline of Individual Pollution Control
            Devices fgr the Model Asphalt Roofing Plants  . . .

Table 8-45  Increase in Annualized Costs of Pollution Control
            Systems for Alternatives 2 to 5 Compared to the
            Baseline Pollution Control Systems  	
Table 8-46  Cost Effectiveness of Pollution Control Devices
            Used in Model Asphalt Roofing Plants .   .  .  .  .
Table 8-47  Cost Effectiveness of Pollution Control Systems
            for Model Asphalt Roofing Plants  ........
8-101



8-102



8-104



8-106


8-108


8-109
                                   xv

-------
                       LIST OF TABLES (continued)
                                                                 Page
Table 8-48  Total Capital Investment Costs of a Small, New
            Asphalt Roofing Plant With A Pollution Control
            System	
Table 8-49



Table 8-50



Table 8-51


Table 8-52


Table 8-53


Table 8-54


Table 8-55


Table 8-56


Table 8-57

Table 8-58

Table 8-59

Table C-l

Table C-2


Table C-2a


Table  C-3


Table  C-3a
Total Capital Investment Costs of a Medium, New
Asphalt Roofing Plant With a Pollution Control
System. .  .  . '.	'	

Total Capital Investment Costs of a Large, New
Asphalt Roofing Plant With a Pollution Control
System  	

Total Annualized Costs for a Small, New Asphalt
Roofing Plant With a Pollution Control System . .  .

Total Annualized Costs for a Medium, New Asphalt
Roofing Plant With a Pollution Control System . .  .

Total Annualized Costs for a Large, New Asphalt
Roofing Plant With a Pollution Control System . .  .

Unit Product Costs of a Small, New Asphalt
Roofing Plant With a Pollution Control System . .  .

Unit Product Costs of a Medium, New Asphalt
Roofing Plant With a Pollution Control System  . .  .

Unit Product Costs of a Large, New Asphalt
Roofing Plant With a Pollution Control System  . . .
 DCF for Small  Plant 	

 DCF for Medium Plant  	

 DCF for Large  Plant	

 Visible Emission Composite Summaries—Plant A ...

 Particulate and Gaseous Hydrocarbon Concentrations
 and Emission Data Summary—Plant A (Metric) ....

 Particulate and Gaseous Hydrocarbon Concentrations
 and Emission Data Summary—Plant A (English)  .  .  .

 Particulate Polycyclic Organic Matter Concentration
 and Emission Data Summary—Plant A (Metric) ....

 Particulate Polycyclic Organic Matter Concentration
 and Emission Data Summary—Plant A (English)  .  .  .
8-112



8-113



8-114


8-115


8-116


8-117


8-119


8-120


8-121

8-135

8-136

8-137

C-8


C-12


C-13


C-14


 C-15
                                    xvi

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 Table C-4

 Table C-5




 Table C-5a



 Table C-6

 Table C-6a

 Table C-7

 Table C-8

 Table C-9

 Table C-10


 Table C-ll


 Table C-lla


 Table  C-12


 Table  C-13


 Table  C-14


Table  C-15

Table  C-16



Table  C-17

Table  C-18
            LIST OF TABLES (continued)


 Summary of Visible Emission  Data—Plant B  .  .

 Summary of Particulate  and Gaseous  Hydrocarbon
 Concentration  and  Emission Rates—Plant B
 (Metric)	

 Summary of Particulate  and Gaseous  Hydrocarbon
 Concentration  and  Emission Rates—Plant B
 (English)  	

 Summary of Pom Data—Plant B  (Metric)  	

 Summary of Pom Data—Plant B  (Metric)  	

 Aldehyde Results—Plant B	

 CO Emissions and Emission  Rates—Plant  B
N0v Results—Plant B
  X.
Particulate Emission Tests Summary:  Performance
of HVAF Control Device—Plant C	
Polycyclic Organic Matter (POM) Emission Tests
Summary—Plant C (Metric) 	
Polycyclic Organic Matter (POM) Emission Tests
Summary—Plant C  (English)	 .  .
Total Hydrocarbon Emission Tests Summary--PI ant C
(Metric) (English)  	
Flame lonization Detector (FID) Data Summary--
Plant C—HVAF Inlet	
Flame lonization Detector (FID) Data Summary-
Plant C—HVAF Outlet	
Summary of Visible Emission Data—Plant D .  .  .  .

Particulate and Gaseous Hydrocarbon Results  of
Shingle Line Saturator HVAF Filter System
Plant D 	

Summary of Visible Emission Data—Plant E .  .
Performance Summary of Emission Reduction System
for Blowing Stills Saturate Blows—Plant E
(Metric)	  .
 Page

 C-17



 C-18



 C-20

 C-22

 C-23

 C-24

 C-25

 C-26


 C-32


 C-33


 C-34


 C-35


 C-36


 C-37

 C-39



 C-41

C-43



C-44
                                  xvi

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                       LIST OF TABLES (continued)
Table C-18a Performance Summary of Emission Reduction System
            for Blowing Stills, Saturate Blows—Plant E
            (English) 	
Table C-19  Performance Summary of Emission Reduction System
            for Blowing Stills, Coating Blows—Plant E
            (Metric)  	
Table C-19a Performance Summary of Emission Reduction System
            for Blowing Stills, Coating Blows—Plant E
            (English)  	
C-45
C-46
C-47
Table C-20  Summary of POM Data—Plant E (Metric)	C-48
Table C-20a Summary of POM Data—Plant E (English)	C-49
Table C-21  S02  and NO   Readings by  Continuous Monitoring
            Analysis—Plant  E	c~50
Table C-22  Aldehyde  Results—Plant  E  (Metric)	C-51
Table C-22a Aldehyde  Results—Plant  E  (English)  	  C-51
Table C-23  Summary of Visible Emission  Data—Plant  F  	  C-53
Table C-24  Summary of Visible Emissions—Plant  G	C-54
Table C-25  Summary of Visible Emissions—Plant  H	C-55
Table C-26   Summary of Visible Emissions—Plant  J	C-56
 Table  C-27   Summary  of Visible Emissions—Plant  K	C-57
 Table C-28  Summary  of Visible Emissions—Plant  L	C-58
                                    xvm

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                                1.   SUMMARY
 1.1   REGULATORY ALTERNATIVES
      Standards  of performance for  new  stationary sources are developed
 under Section 111 of the Clean Air Act (42 U.S.C. 1857C-6) as amended.
 Section  111  requires the establishment of  standards  of performance for
 new  stationary  sources which ". .  . may contribute significantly  to  air
 pollution  which  causes  or  contributes to  the endangerment of public
 health or  welfare."  The Act requires  standards  of performance for such
 sources  to ".  .  .  reflect  the  degree  of  emission limitation and the
 percentage  reduction achievable through application  of the best techno-
 logical  system  of  continuous emission reduction which  (taking  into
 consideration the cost of achieving such  emission reduction,  any  non-air
 quality  health  and  environmental  impact,  and energy requirements) the
 Administrator determines  has been adequately demonstrated."   The  stan-
 dards apply  only to stationary  sources, the construction  or modification
 of which starts after regulations are  proposed in the Federal Register.
      Five  regulatory alternatives  were studied.   The first alternative
 would not require promulgation of an NSPS.  Asphalt roofing manufacturing
 (ARM) facilities  would continue to be  regulated by State Implementation
 Plans (SIP's).  Alternatives 2, 3, 4, and 5 would apply well-designed and
 operated particulate control  technology to  different  combinations  of  the
 four  major  affected facilities  which may be  located  in ARM plants, oil
 refineries, or  asphalt processing  plants.   Alternative 2 would require
 control of  the  saturator and the asphalt  storage  tanks.  Alternative 3
would require control  of the, blowing still in addition to the saturator
and storage tanks.  Control  of the mineral  handling and storage facilities,
the  saturator,  and the asphalt storage tanks would  be required under
Alternative 4.  Alternative  5 would require control of all four facilities.
                                   1-1

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1.2  ENVIRONMENTAL IMPACT
     The beneficial  and adverse environmental  impacts  associated  with
each alternative are summarized in this section and in Figure 1-1.
     It  is  projected that  over the next  5 years  three  new asphalt
roofing plants with blowing stills will be built.   Regulatory Alternative 1
would  have  no impact on energy, water,  solid waste,  or noise.  There
would  be an adverse impact on air quality.  Emissions would increase by
684 megagrams (754 tons) in the fifth year.
     A beneficial  air impact would result  from adoption of Regulatory
Alternatives 2,  3,  4,  and  5.   The  projected decrease  in annual  emissions
below  baseline  (Alternative 1) for  the fifth year for Alternatives  2
through  5 is  listed  below.
     1.  Alternative 2  - 226 Mg/yr (249  tons/yr)
     2.  Alternative 3  - 524 Mg/yr (578  tons/yr)
     3.  Alternative 4  - 237 Mg/yr (261  tons/yr)
     4.  Alternative 5  - 535 Mg/yr (590  tons/yr)
     The projected increase in energy  above the  baseline in the  fifth
year  after promulgation would be  0.2  percent (1.1 bbl of oil/day)  for
Alternatives 2 and 4 and 3.0 percent (16 bbl of oil/day)  for Alternatives 3
and 5.  Alternatives 2 through 5 would have a negligible impact on water
 and solid waste and no impact  on  noise.
 1.3  ECONOMIC IMPACT
      Capital and  annualized  costs were estimated for  the  Regulatory
 Alternatives.   In each case,  cost figures  were developed for three model
 plant sizes  with and  without blowing  stills  (Section 8.2).   A brief
 summary of the economic impacts associated with each  regulatory alterna-
 tive  is presented in this section and in Figure 1-1.
       The capital cost increase from baseline for Regulatory Alternatives 2
 and 3 would be $215,000,  and for  Regulatory Alternatives 4 and  5  the
 increase would be $305,000.   The annualized cost increase  from baseline
 (Alternative 1) for Regulatory Alternative 2 is $81,000; for  Regulatory
 Alternative  3,  $160,000;  for  Regulatory Alternative  4, $109,000;  and for
 Regulatory Alternative 5, $188,000.    The cost to manufacture asphalt
 roofing would  be  increased if any one of  Regulatory Alternatives  2,  3, 4,
                                     1-2

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Administrative
action
Alternative
1
Alternative
2
Alternative
3
Alternative
4
Alternative
5
)elayed
Air
impact
-3**
+2**
-3**
+2**
+3**
+1*
Water
impact
0
_]**
_]**
_ ]**
-I**
-1*
Solid
waste
impact
0
_•]**
_] **
_1**
_1**
-1*
Energy
impact
0
_]**
_1 **
_-]**
_•]*;*:
-1*
Noise
impact
0
0
0
0
0
0
Economic
impact
0
_1**
_]**
_ i **
-I**
-1*
Key:  + Beneficial impact.
     - Adverse impact.
     0 No impact.
     1 Negligible impact.
     2 Small impact.
                                      3 Moderate impact.
                                      4 Large impact.
                                      * Short term impact.
                                     ** Long term impact.
                                    *** Irreversible impact.
Figure 1-1.   Matrix of environmental and economic
       impacts for regulatory alternatives
                       1-3

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or 5 were adopted.  The average price increase for ARM products would be
0.2 percent for Alternatives 2 and  4 and 0.3 percent for Alternatives 3
and 5.  The  estimated cost increase for a roof on a new, typical  three-
bedroom house would be $3 for Regulatory Alternatives 3 or 5.
                                     1-4

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                             2.   INTRODUCTION

2.1  BACKGROUND AND AUTHORITY FOR STANDARDS
     Before standards of performance are proposed as a Federal regulation,
air pollution  control methods  available to the affected  industry and the
associated costs  of installing and  maintaining the  control  equipment are
examined in detail.  Various levels of control based on different technolo-
gies and degrees  of efficiency are  expressed as  regulatory  alternatives.
Each of these alternatives is studied by EPA as a prospective basis for a
standard.  The alternatives are investigated in terms of their impacts on
the economics and well-being of the industry, the impacts on the national
economy, and the  impacts  on the  environment.  This  document  summarizes
the information obtained through  these studies so that interested persons
will be  able to see  the information considered by EPA in the  development
of the proposed- standard.
     Standards of  performance  for new stationary sources are  established
under  Section  111  of the  Clean Air Act (42 U.S.C.  7411)  as  amended,
hereinafter referred to as the Act.   Section 111 directs the Administrator
to establish standards of  performance for  any  category of new stationary
source of air pollution which ".  . . causes, or contributes significantly
to,  air pollution  which may reasonably be  anticipated to endanger public
health or welfare."
     The Act requires that standards of performance for stationary sources
reflect "...  the degree  of emission reduction achievable which (taking
into consideration the cost of achieving such emission reduction, and any
non-air quality health and environmental impacts,  and energy requirements)
the Administrator  determines has  been  adequately demonstrated for that
category of sources."  The standards  apply only to stationary sources,
                                   2-1

-------
the construction or modification of which commences after regulations are
proposed by publication in the Federal Register.
     The 1977  amendments  to  the Act  altered or  added  numerous provisions
that  apply to the  process of establishing  standards of performance.
     1.   EPA is required to list the  categories  of  major stationary
sources that have  not already been  listed and  regulated under standards
of performance.  Regulations must be promulgated for these new categories
on the following schedule:
     a.  25  percent of the listed categories by August 7, 1980.
     b.  75  percent of the listed categories by August 7, 1981.
     c.   100 percent  of the  listed categories by August 7, 1982.
A  governor of a State may apply  to the Administrator to add a category
not  on the  list or may apply to the Administrator to have a standard of
performance  revised.
      2.   EPA is required to review  the standards of performance  every
4 years and, if  appropriate, revise  them.
      3.   EPA  is authorized  to promulgate a standard based  on design,
equipment, work practice, or operational  procedures when  a standard based
on emission  levels is not feasible.
      4.   The terra  "standards of performance"  is redefined, and a new term
 "technological system of continuous emission  reduction"  is  defined.  The
 new definitions clarify  that  the  control system must be continuous  and
may include a low- or non-polluting process or operation.
      5.   The  time  between the proposal and promulgation of  a standard
 under Section 111  of the Act may be extended to 6 months.
      Standards of performance, by themselves, do not guarantee protection
 of health or welfare because they are not designed to achieve any specific
 air quality levels.   Rather,  they are designed to reflect the degree of
 emission  limitation achievable through application of the best adequately
 demonstrated  technological  system  of continuous  emission  reduction,
 taking into consideration the  cost  of  achieving  such emission  reduction,
 any  non-air  quality health  and  environmental  impacts,  and  energy
 requirements.
      Congress  had several  reasons  for  including  these requirements.
 First, standards with a  degree of uniformity are needed to avoid  situations
                                     2-2

-------
where  some  States may attract industries by relaxing standards relative
to  other  States.   Second, stringent standards enhance the potential for
long-term growth.   Third, stringent standards  may help  achieve long-term
cost savings  by avoiding the need  for  more expensive retrofitting when
pollution ceilings  may be reduced  in the future.  Fourth, certain types
of  standards for coal burning sources can adversely affect the coal market
by  driving  up  the  price of low-sulfur  coal  or effectively excluding
certain coals  from the reserve base because  their untreated pollution
potentials are  high.  Congress does not intend that new source performance
standards contribute  to  these  problems.   Fifth, the standard-setting
process should  create incentives for improved technology.
     Promulgation of  standards  of performance does not prevent State or
local  agencies  from adopting more  stringent emission limitations  for the
same sources.   States  are free under Section 116  of the Act  to  establish
even more stringent  emission  limits  than  those established  under
Section 111  or  those necessary to attain or maintain the National  Ambient
Air Quality Standards  (NAAQS)  under Section 110.   Thus, new sources may
in  some cases be  subject  to limitations more stringent than  standards of
performance under Section 111, and prospective owners  and operators of
new sources  should  be aware of this possibility  in planning for  such
facilities.
     A similar  situation  may arise when a major emitting facility is to
be  constructed  in a geographic  area that falls under the prevention of
significant deterioration of air quality provisions of  Part C of the Act.
These  provisions  require,  among  other  things,  that major  emitting
facilities to be  constructed in  such areas are to  be  subject to  best
available  control  technology.   The term Best Available  Control  Technology
(BACT), as defined in the Act,  means
          ...  an emission limitation  based on the maximum degree
          of reduction of each  pollutant subject to regulation under
          this Act emitted from,  or which results from,  any major
          emitting facility, which the  permitting authority,  on a
          case-by-case basis,  taking into account energy,
          environmental, and economic impacts and other  costs,
          determines is achievable for  such facility through
          application of production processes and available methods,
          systems, and techniques, including fuel  cleaning or
                                   2-3

-------
          treatment or innovative fuel  combustion techniques  for
          control  of each such pollutant.   In no event shall
          application of "best available control technology"  result
          in emissions of any pollutants which will  exceed the
          emissions allowed by any applicable standard established
          pursuant to Sections 111 or 112 of this Act.
          (Section 169(3))
     Although standards  of  performance  are normally structured in terms
of numerical emission  limits,where feasible, alternative approaches are
sometimes necessary.   In some cases physical  measurement of emissions
from  a new  source  may be  impractical  or  exorbitantly expensive.
Section lll(h) provides that the Administrator may promulgate a design or
equipment standard  in  those cases where it is not feasible to prescribe
or  enforce  a  standard  of  performance.   For  example,  emissions  of
hydrocarbons from storage  vessels  for petroleum liquids are  greatest
during tank  filling.   The nature of the  emissions,  high concentrations
for short periods during filling  and low concentrations for longer periods
during storage, and the  configuration of storage tanks make direct emission
measurement impractical.  Therefore, a more practical approach to standards
of  performance for  storage vessels has been  equipment  specification.
      In addition,  Section lll(i) authorizes the Administrator  to  grant
waivers of  compliance to permit  a  source  to use innovative continuous
emission  control   technology.   In  order  to  grant  the  waiver, the
Administrator  must  find:  (1)  a  substantial  likelihood that the technology
will  produce greater emission  reductions than  the standards require or an
equivalent  reduction at  lower economic energy  or  environmental  cost;
(2) the  proposed system  has  not been adequately demonstrated; (3) the
technology  will  not cause  or  contribute  to an unreasonable risk to the
public health, welfare, or safety;  (4)  the governor of the State where
the source  is located  consents;  and (5)  the waiver  will  not  prevent  the
attainment  or maintenance  of  any ambient standard.   A waiver may  have
conditions  attached to  assure the  source  will  not  prevent  attainment of
any NAAQS.   Any  such  condition  will  have the force of  a  performance
standard.   Finally, waivers have definite end dates  and  may be terminated
earlier if the conditions  are not met or if the system  fails to  perform
                                    2-4

-------
as  expected.   In such a case,  the  source may be given up to 3 years to
meet the standards with a mandatory progress  schedule.
2.2  SELECTION OF CATEGORIES OF STATIONARY SOURCES
     Section 111 of  the  Act directs the Adminstrator to  list categories
of stationary sources.  The Administrator "... shall include a category
of  sources  in  such list if in  his  judgment it causes, or  contributes
significantly to,  air pollution which may reasonably  be  anticipated to
endanger public health or welfare."  Proposal and promulgation of standards
of performance are to follow.
     Since  passage  of the  Clean  Air  Amendments of 1970, considerable
attention has been  given  to the  development  of  a system for assigning
priorities to various source categories.  The approach specifies areas of
interest by considering the broad strategy of the Agency for implementing
the Clean Air Act.  Often,  these  "areas"  are  actually pollutants emitted
by stationary sources.  Source  categories that emit these pollutants  are
evaluated and ranked by a process involving such factors as (1) the level
of  emission  control   (if  any)  already  required  by  State  regulations,
(2) estimated levels  of control that might be required from  standards of
performance  for  the  source category,  (3) projections of growth and
replacement of existing facilities  for the source category, and (4) the
estimated incremental amount of air pollution that could  be  prevented in
a preselected  future year by standards of  performance for the source
category.    Sources  for which  new source performance  standards were
promulgated or under  development  during 1977, or earlier, were selected
on these criteria.
     The Act amendments of August 1977 establish specific criteria to be
used in determining priorities  for  all major source categories not yet
listed by EPA.   These are (1)  the quantity of air  pollutant emissions
that each such category will  emit,  or will  be designed to emit;  (2) the
extent to which  each such pollutant may  reasonably be anticipated to
endanger public health or welfare;  and (3)  the mobility and competitive
nature of each  such  category  of  sources  and the consequent need  for
nationally applicable new source standards of performance.
                                   2-5

-------
     The Administrator is  to  promulgate standards for these categories
according to the schedule referred to earlier.
     In some cases it may not be feasible immediately to develop a standard
for a  source  category with a high priority.   This  might happen when a
program of  research  is needed to develop control techniques or because
techniques  for  sampling  and measuring emissions may require refinement.
In  the developing of  standards,  differences  in  the  time required to
complete the necessary investigation for different source categories must
also be considered.  For example, substantially more time may be necessary
if  numerous pollutants must be investigated from a single source category.
Further, even late in  the  development process  the schedule for completion
of  a  standard may change.  For example,  inablility to obtain emission
data  from well-controlled  sources  in time  to pursue the development
process  in a  systematic fashion may  force a  change  in scheduling.
Nevertheless,  priority ranking  is,  and will  continue to be,  used to
establish the order  in which  projects are initiated and  resources  assigned.
     After  the source category has  been chosen,  the types of facilities
within the source  category to which the standard  will  apply must be
determined.   A  source category may have  several facilities that cause air
pollution,  and emissions  from  some  of these  facilities  may  vary from
insignificant to very expensive to control.   Economic  studies  of the
source category and of  applicable control  technology may show that air
pollution control  is  better  served  by applying  standards to  the more
severe pollution sources.   For this  reason,  and because there  is  no
adequately demonstrated  system  for controlling emissions from  certain
facilities, standards often  do  not  apply to all  facilities  at  a source.
For the same reasons, the standards may not apply  to all air  pollutants
emitted.   Thus, although  a source category may be selected to be covered
by a  standard  of performance,  not all  pollutants or  facilities  within
that source category may be covered  by the  standards.
2.3  PROCEDURE FOR DEVELOPMENT OF STANDARDS OF PERFORMANCE
      Standards of performance must  (1) realistically  reflect best demon-
 strated control practice;  (2) adequately consider  the cost, the non-air
quality health and  environmental impacts,  and the energy requirements of
                                    2-6

-------
such control;  (3)  be  applicable  to  existing  sources  that  are modified  or
reconstructed as well as new installations; and (4) meet these conditions
for all  variations of operating conditions being considered anywhere in
the country.
     The objective of a program for developing standards is to identify
the best technological  system  of continuous emission reduction that has
been adequately  demonstrated.   The  standard-setting process  involves
three  principal  phases  of activity:   (1) information  gathering,
(2) analysis of  the information,  and (3) development of the standard of
performance.
     During  the  information-gathering  phase,  industries  are  queried
through a  telephone survey, letters of inquiry, and plant visits by EPA
representatives.    Information  is  also  gathered from many other sources,
and a  literature search is  conducted.   From  the knowledge acquired  about
the industry,  EPA selects  certain  plants  at which emission tests  are
conducted to provide reliable data that characterize the pollutant emissions
from well-controlled existing facilities.
     In the second phase of a project,  the information about the industry
and the  pollutants emitted  is  used in analytical  studies.  Hypothetical
"model  plants" are defined  to  provide a common basis for analysis.   The
model  plant  definitions,  national  pollutant  emission data, and existing
State regulations  governing emissions  from the source category are then
used  in establishing  "regulatory  alternatives."   These  regulatory
alternatives are essentially different levels of emission control.
     EPA conducts  studies  to  determine the  impact of each regulatory
alternative on the economics of the industry and on the national economy,
on the  environment, and on energy  consumption.  From several  possibly
applicable alternatives, EPA selects the single most plausible regulatory
alternative as the basis for a standard of  performance  for the source
category under study.
     In the third phase of a project, the selected regulatory alternative
is translated  into a  standard  of performance, which,  in turn,  is written
in the form of a Federal regulation.  The Federal  regulation, when applied
to newly constructed plants, will limit emissions to the levels indicated
in the selected regulatory alternative.
                                   2-7

-------
     As early  as is  practical  in each  standard-setting  project,  EPA
representatives discuss the  possibilities  of a standard and the form it
might take with  members of the  National  Air  Pollution Control Techniques
Advisory Committee.   Industry representatives and other interested parties
also participate in these meetings.
     The  information acquired  in the project  is summarized  in  the
Background Information  Document  (BID).  The BID, the standard, and  a
preamble explaining  the  standard are widely  circulated to  the  industry
being  considered for control,  environmental groups, other  government
agencies, and offices within EPA.  Through this extensive review process,
the points of  view of expert reviewers  are  taken into  consideration  as
changes are made to the documentation.
     A  "proposal  package"  is assembled  and  sent  through  the offices  of
EPA Assistant Administrators for  concurrence  before the proposed standard
is officially endorsed by the EPA Administrator.  After being approved by
the  EPA Administrator, the  preamble and  the proposed regulation are
published in the Federal Register.
     As  a part  of  the Federal  Register announcement of the proposed
regulation,  the  public is  invited to participate  in  the standard-setting
process.   EPA  invites written  comments  on the proposal and  also holds a
public  hearing  to discuss  the proposed standard with interested parties.
All  public  comments are summarized and incorporated  into  a second volume
of the  BID.  All  information reviewed and  generated  in  studies  in  support
of  the standard of performance is available to the  public  in a "docket"
on  file in Washington,  D.C.
     Comments  from  the public are  evaluated, and  the  standard  of
performance  may  be  altered  in response to  the comments.
     The  significant comments and EPA's  position  on  the issues  raised are
 included  in  the  "preamble"  of a promulgation package, which also  contains
the  draft of the final  regulation.   The regulation  is  then subjected to
 another round of review and refinement  until it is  approved by the EPA
Administrator.   After  the  Administrator signs the  regulation,  it  is
 published as a "final rule"  in  the Federal  Register.
                                    2-8

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2.4  CONSIDERATION OF COSTS
     Section  317  of  the Act requires an economic  impact assessment with
respect  to  any standard of performance established under Section 111 of
the  Act.   The assessment is required to contain an analysis of: (1) the
costs  of compliance  with the regulation,  including  the extent to which
the  cost of compliance varies  depending  on the effective date of  the
regulation and the development  of less expensive or more efficient methods
of compliance;  (2) the  potential  inflationary or  recessionary  effects of
the  regulation; (3) the effects the regulation might have on small business
with respect to competition; (4) the effects of the regulation on consumer
costs; and  (5)  the  effects of  the regulation on energy use.  Section 317
also  requires  that the economic  impact  assessment be as extensive as
practicable.
     The  economic impact of  a  proposed standard  upon  an  industry  is
usually  addressed both  in absolute terms  and in  terms  of the  control
costs  that  would  be  incurred as  a  result of compliance with  typical,
existing State control regulations.   An incremental approach is necessary
because  both  new  and existing plants would  be  required to  comply with
State  regulations in  the  absence of a Federal  standard of performance.
This approach  requires  a  detailed analysis of  the economic impact from
the  cost  differential that  would exist between a  proposed  standard of
performance and the typical  State standard.
     Air  pollutant emissions  may cause  water pollution problems, and
captured potential air pollutants may pose a solid waste disposal  problem.
The  total environmental impact  of an emission source must, therefore, be
analyzed and the costs determined whenever possible.
     A thorough study of  the  profitability and price-setting mechanisms
of the industry is essential to the analysis so that an  accurate estimate
of potential adverse  economic impacts can be made for proposed standards.
It is  also essential to  know  the capital  requirements  for  pollution
control  systems already placed  on plants so that the additional capital
requirements  necessitated by  these  Federal standards can be  placed  in
proper perspective.   Finally, it  is necessary to assess the availability
                                   2-9

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of capital to provide the additional control equipment needed to meet the
standards of performance.
2.5  CONSIDERATION OF ENVIRONMENTAL IMPACTS
     Section 102(2)(C) of the National Environmental Policy Act (NEPA) of
1969 requires  Federal  agencies  to prepare detailed environmental impact
statements on  proposals  for legislation and other major Federal actions
significantly  affecting  the  quality  of the  human environment.  The
objective of  NEPA is to  build into  the  decisionmaking process  of Federal
agencies a careful consideration of all environmental aspects of proposed
actions.
     In  a number of legal  challenges to standards of performance  for
various  industries,  the  United  States Court of Appeals for the District
of  Columbia  Circuit has  held that  environmental  impact  statements  need
not  be  prepared by  the  Agency for  proposed actions under Section 111 of
the  Clean Air  Act.   Essentially, the  Court  of Appeals  has determined that
the  best system of emission reduction requires  the Administrator to take
into account  counter-productive  environmental  effects  of  a  proposed
standard,  as well as  economic  costs  to the industry.  On  this basis,
therefore,  the Court established a narrow  exemption  from NEPA for  EPA
determination  under  Section 111.
      In addition to these judicial  determinations, the Energy Supply and
Environmental  Coordination Act (ESECA) of  1974 (PL-93-319)  specifically
exempted proposed actions  under  the Clean  Air Act from NEPA  requirements.
According to Section 7(c)(l), "No  action  taken under the Clean Air Act
shall  be deemed a major  Federal  action  significantly  affecting the  quality
of the human environment within  the meaning of  the National  Environmental
Policy Act  of 1969." (15 U.S.C.  793(c)(l))
      Nevertheless,   the  Agency  has concluded that the preparation of
environmental  impact statements could have beneficial effects on certain
regulatory  actions.   Consequently,  although not legally  required to do  so
by  section 102(2)(C) of NEPA,  EPA  has  adopted a  policy  requiring  that
environmental  impact statements be prepared for various  regulatory actions,
 including standards of  performance developed  under  Section  111  of the
                                    2-10

-------
 Act.   This  voluntary  preparation of  environmental  impact statements,
 however,  in  no  way legally subjects the Agency  to  NEPA requirements.
      To  implement this policy, a  separate  Section in this document  is
 devoted  solely  to  an  analysis of the  potential  environmental  impacts
 associated  with  the proposed standards.  Both adverse  and beneficial
 impacts  in  such areas as  air and  water pollution, increased  solid waste
 disposal, and increased energy consumption are discussed.
 2.6   IMPACT  ON EXISTING SOURCES
      Section 111  of the Act defines  a new source  as ". .  .  any stationary
 source,  the  construction  or  modification  of which is commenced  ..."
 after the proposed standards are published.  An existing source  is
 redefined as a new source if  "modified" or  "reconstructed"  as defined in
 amendments  to the general provisions of Subpart  A of 40 CFR Part  60,
 which were  promulgated in the Federal  Register  on  December  16, 1975
 (40 FR 58416).
      Promulgation of a standard of performance requires States to establish
 standards of performance  for  existing  sources  in  the  same industry  under
 Section 111  (d) of the Act if  the standard for new sources limits emissions
 of a  designated pollutant  (i.e., a pollutant for which air quality criteria
 have  not  been issued under Section 108  or which has not  been  listed as a
 hazardous pollutant under Section  112).   If a State  does not act,  EPA
must  establish  such standards.  General provisions outlining procedures
 for control  of existing sources under Section lll(d)  were promulgated on
 November 17,  1975, as  Subpart B of 40 CFR Part 60 (40 FR 53340).
2.7   REVISION OF STANDARDS OF PERFORMANCE
     Congress was aware that the level  of air pollution control  achievable
by any industry  may improve  with technological advances.  Accordingly,
Section 111  of the  Act  provides  that the Administrator ". .  .  shall,  at
 least every  4 years,  review  and,  if  appropriate,  revise . . ." the
standards.   Revisions  are  made to  assure that the standards continue  to
reflect the  best systems  that become  available  in the  future.   Such-
revisions will not  be  retroactive  but  will  apply to  stationary sources
constructed  or  modified  after the proposal  of  the revised standards.
                                   2-11

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             3.0  THE ASPHALT ROOFING MANUFACTURING INDUSTRY

 3.1   GENERAL
      The  asphalt roofing and siding manufacturing industry,  henceforth
 called  the  asphalt  roofing  industry for  simplicity,  encompasses  ancillary
 production  activities as well as  the production of asphalt roofing and
 siding  products.  The raw materials used and the processing steps  necessary
 to  transform those  raw  materials  into finished products are  shown in
 Figure  3-1.
      Cellulose-fibers such  as those from rags, paper, and wood are  processed
 into  a  dry felt.   Felt can  also  be made  from  asbestos.   The felt is then
 saturated and sold  as saturated felt,  or saturated and coated with  asphalt
 and surfaced with selected  mineral  aggregates appropriate to the finished
 product (roll  roofing or shingles).  A fiber  glass mat  is sometimes used
 in place  of the dry  felt,  in which case the  asphalt saturation  step is
 bypassed.
      Coal  tar was  used extensively for roofing products  at  one time,  but
 it has  now  largely  been  supplanted by asphalt.   One  of  the  few remaining
 products  is  a  tar-saturated felt used primarily for pipeline wrapping.
 Tar-saturated felt  production is  included as a part of the industry
 because it is processed like asphalt saturated felt'.
     The  saturant and coating asphalts used in the production of asphalt
 roofing are  a processed asphalt  flux, which is  usually a blend of crude
 oil residuum from the refining process.  Air blown asphalts  are also used
 in the  installation of built-up roofs  and for the  repair of leaky  roofs.
     Products produced on an asphalt  roofing  line are:   (1) saturated
 felts; (2) roll  roofing and sidings; and (3) roofing and siding shingles.
 Roofing shingles  accounted  for about  80 percent of the total tonnage
produced in 1978.1
                                  3-1

-------
       PRIMARY
                           SECONDARY

RAW
MATERIALS
RAGS

PAPER

ASBESTOS

WOOD
FIBER
FIBER GLASS
MAT

ASPHALT
FLUX

MINERAL
STAB'ILIZ'ER

FINE
SURFACING
COLORED
GRANULES

\

k



t
\

\
\



INTER-
MEDIATE
PRODUCTS
**• DRY
< FELT \

— | /
SATURANT '
ASPHALT

\ COATING
ASPHALT
\~ J
\
»'/
STABILIZED
COATING
ASPHALT

f
\
r/
/
/
h
'
FINISHED
PRODUCTS
^ SATURATED
y FELT
fl
	 	 	 1 * . 	

SMOOTH
ROLL
y ROOFING

<^ SURFACED
•. PRODUCTS







,>- SURFACED
ROLLS

*- SIDINGS
STRIP
*~ SHINGLES

^ iMnivintiAl
SHINGLES

Figure 3-1.  Processing chart.for asphalt roofing products  from
             raw materials to "finished roofing.
                             3-2

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      Saturated  felts,  used as under!ayment  for  shingles,  for sheathing
paper,  for  laminations  in  the construction of built-up  roofs  and for pipe
wrapping,  consist of  a felt impregnated with an asphalt or coal tar
saturant.
      Roll  roofing and  shingles  are prepared  by adding a  coating  of
stabilized  asphalt to  a felt web which has  first been impregnated with  a
saturant asphalt.  Alternatively, a  fiber glass mat web is  used, in which
case  the stabilized coating  is used  both to  saturate  and to coat the web.
To  make shingles, mineral  granules  are added, a  strip of sealer asphalt
may  be applied,  and the web is cut into shingles.   The most popular
shingle is  a nominal 106.6 kg (235 Ib), 3-tab, self-sealing strip shingle.
Self-seal shingles accounted for about 97 percent of  all shingle production
in 1978.1
3.1.1   Processed  Asphalt Products
      Most of the  asphalt produced by, or for, the asphalt roofing industry
is used in  the manufacture of roofing line products.  About 10 percent of
the asphalt is  used to make insulated  sidings.   Much of  the  usefulness
and  durability  of asphalt  roofing   products can  be  attributed to  the
waterproofing characteristics of the asphalt.
      The asphalt  used  for  saturants and coatings is prepared by blowing
air through a hot asphalt  flux to raise the  temperature at  which it will
soften.  The stabilized coating asphalt is then prepared by mixing coating
asphalt and a mineral   stabilizer  in approximately equal proportions.
      Saturant and coating asphalts are normally classified as intermediate
products because they are used in the manufacture of roofing line products.
Saturant and coating asphalts are, however,  end products for some companies
since they are not always produced at roofing plants.   Much of the saturant
and coating asphalt used by asphalt roofing plants is prepared at refineries
or by asphalt.processors.  Fifty-nine petroleum firms with 106 refineries
                                     o
report a capacity to produce asphalt.    There are several small  companies
which buy asphalt flux  to  produce saturants  and coatings for  the asphalt
roofing industry.
3.1.2  Market Size and  Description
     The market for asphalt  roofing products is  focused on residential
construction, with new  construction and replacement sharing the resources
                                   3-3

-------
attracted to the market.  An  important feature of the domestic market is
its local nature.   It is estimated that virtually  all  of the sales of
asphalt roofing and siding  products occur within 483 km (300 mi) of the
production  facility.   There  are  no data available to demonstrate the
existence of a foreign market.
     Ten major producers dominate the industry in a market with virtually
inelastic demand,  which would  be  expected  since  the substitutes for
asphalt roofing are higher priced and constitute about 20 percent of sales.
The entire  industry can  be viewed as a "subset" of a larger industry, that
is, housing.
     The  constituents which  traditionally determine market growth are
demand,  product cost,  availability,  and  competition from  market  sub-
stitutes.   Until  recently,  the asphalt  processing  and  roofing industry
differed  from the  norm in that  its  only  growth determinant  was the demand
for  roofing products.  This  may  change  as supply  shortages drive prices
up, and the search for viable substitutes  is intensified.
     "Housing  starts" and the  renovation  of existing structures are the
two  primary determinants of  the  demand  for roofing products, and they
have  a complementary relationship  in that declines in one are associated
with  increases in the other.  When housing starts  dropped sharply in
 1974,  sales volume of  roofing and siding material did not  decline a
corresponding  amount because of  the  strength of the renovation market.
      During the past  10 years, the compound annual growth rate of  the
 asphalt roofing products market  has  been 2.5 percent.     Projections  of
 the trend  for  the next 5-year period suggest continued growth at a rate
                     4
 of 1.5 to 2 percent.
      The price and availability  of asphalt roofing products  is closely
 intertwined with the cost and availability of the materials used in their
 manufacture.  As  noted earlier,  these materials are asphalt, felt, and
 mineral products  (granules, parting agents, and stabilizers).
 3.1.3  Raw Materials
      Asphalt is the most expensive component of asphalt roofing products.
 About 90 percent  of all asphalt used is extracted from crude oil; therefore,
 the roofing industry  is heavily dependent on the petroleum industry.  The
 asphalt  derived  from crude oil has only  one substitute, the "native" or
                                     3-4

-------
 "natural" asphalt which  is  mined from fissures or  pools  close to the
 earth's surface.
      Asphalt is the residual  "heavy  bottom"  of crude petroleum.   Prices
 and availabilities for asphalt  are thus  directly-tied to the price and
 availability of crude  oil.   Disruption of asphalt  supplies resulting  from
 the interruption  of petroleum imports increases prices.  The  industry
 expects asphalt shortages to continue.
      Felts  are  produced from sawdust,  rags, waste paper, wood fibers,  and
 asbestos.   In contrast with  the  volatile and even dramatic  fluctuations
 of  asphalt  supplies, the  effects  of felt  supplies on the roofing  industry
 have  been steadily unfavorable.   The  shortage of wood pulp has  increased
 the demand  for wastepaper and recycled paper,  thus  limiting the  amount
 available for lower-priced paper  products  such  as organic  felt  for roofing
 products.   A fiber-glass-based asphalt shingle is  now being manufactured
 by  several  roofing manufacturers.  At the present time, it  accounts for
 over 5  percent  of  the  sales  in a  typical market.5
     Granules,  parting agents,  and  stabilizers for  the  surfacing of
 roofing products  accounted  for  about  16  percent of  the total  cost of
 materials  in 1979.    The  roofing and  siding  industry consumes only  a
 small fraction  of  domestic production, while  the supply of basic  granule
 material  (primarily sand  and gravel)  is virtually  limitless.  Because  of
 other uses for  sand and gravel, however, there are some "regional  shortages"
 in  urban areas where asphalt  roofing and siding manufacturing is primarily
 located.
 3.1.4   Product Substitutes
     The  substitutes  in  the  market  for  asphalt roofing,  i.e., cedar
 shingles, slate, tile, and other new materials, have found only limited
 application  in  the roofing market in  recent  years.   Increased  asphalt
 roofing prices  during  the past several years, however, have caused some
 acceleration  in the search  for  substitutes.     In the commercial  and
 industrial built-up roofing market there is some competition from  various
 plastic materials  which are  lighter  and have  shorter application  times,
 but these products have made  no  significant inroads  into the residential
market.                           ,    .
                                   3-5

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3.1.5  Industry Size- and Growth Rate
     The Asphalt  Roofing Manufacturers Association  (ARMA)  furnished  a
list  of  117 asphalt roofing manufacturing plants in  the  United States
compared to 235 listed in the 1977 census of manufacturers under Standard
Industrial  Classification  (SIC)  Code 2952 (Asphalt Felts and Coating).
The name and location of one asphalt roofing plant, not on the ARMA list,
was  obtained from  a manufacturer  of electrostatic  precipitators.   The
information was verified  by  calling the  plant owner.   SIC Code 2952
includes  firms  engaged in the manufacture of  products  such as roofing
cements  and coatings, tarpaper  and pitch roofing,  as well  as  asphalt
roofing  and siding.  The ARMA list,  on the other hand, is  restricted  to
those firms which  produce  shingles  or roll goods as their primary product.
      The  118 asphalt roofing  and  siding  manufacturing plants shown in
Figure 3-2 are owned  by 31 companies and are located  in  30 states.
Geographical  locations are plotted  in Figure  3-2.   About 35 percent of
the plants are concentrated in four states (California, Texas, Illinois,
and New Jersey),  mostly in urban areas.
      The companies which comprise the asphalt  roofing and siding  industry
 vary greatly in size and diversity.  The  larger firms often produce their
 own felts, about  one-third of the companies process their own asphalt,
 and one firm owns its own refinery for asphalt production.   Six firms  are
 publicly  held  and listed  on  either the  New York, the American,  or  a
 regional stock exchange.
      Asphalt roofing production and capacity figures are not disclosed by
 individual  firms,  but  aggregate figures  can be compared by  region.   In
 1977 the regional  sales of asphalt roofing products totalled 93.9 million
 squares,  and  sales  were  distributed  as follows:   Northeast region
 17.9 percent;  North Central region 32.5 percent; South region 34.1 percent;
 and  West  region  15.5 percent.8  Estimates  of production  at  53 plants
 showed a  range of 7,257 to 408,195 Mg (8,000 to 450,000 tons) per year.
      The production of  asphalt  roofing and siding is so thoroughly inter-
 locked  with the  production  of asphalt  that  a description of asphalt
 roofing  must include asphalt processing.  This interlocked  relationship
 has  two major aspects.   First, the pronounced-dependence  of  the  roofing
 industry on asphalt as an  irreplaceable input links the two  industries.
                                     3-6

-------
Secondly, part  of the production  process  itself,  namely oxidizing or
"blowing" the asphalt, can  be done either at  a  roofing plant or at a
refinery.  As a  result,  regulations for control  of asphalt blowing would
have economic effects on both industries.   It is necessary,  therefore,  to
describe the production  of  roofing asphalt within the petroleum industry
for a complete description of the  roofing and siding industry.
     The large-scale  disruptions  in petroleum  production  and  prices make
projection  of the  growth  in asphalt production  since 1978 almost
impossible.9  Since January 1, 1979, the price of crude oil  has increased
drastically.  Between April  1976  and January 1979, the price of asphalt
has increased 27 percent to reflect the rise in  crude prices.
3.2  PROCESSES AND THEIR EMISSIONS
3.2.1   Processes
     The processes  which contribute  to  emissions  from asphalt roofing
manufacturing can be  placed in three  broad categories.  These are:
     1.  the roofing  manufacturing line;
     2.   the  delivery, transfer,  and  storage  of materials  used in the
manufacture of roofing products;  and
     3.  the processing  (blowing)  of  asphalt to  place it  in a form suitable
for use in  roofing products.
     3.2.1.1   Roofing and Siding  Manufacturing  Line.    The  sequence of
events  in the  manufacture  of asphalt roofing and siding products is
illustrated in the flow diagrams  of Figures 3-3 and 3-4 and by the block
diagram of Figure 3-5.  Figure 3-4 also  indicates  some of  the  ancillary
activities  necessary to the  line  operation.   Each of the line activities
 is described  below.
      3.2.1.1.1   Dry looper.   A roll  of felt  is installed on the felt reel
 and unwound onto the dry floating looper.   The dry floating looper provides
 a reservoir of  felt  material to match the intermittent operation of the
 felt roller to  the  continuous operation of the line.   Felt  is unwound
 from the roll at  a faster rate than  is  required  by  the line,  with the
 excess being stored  in  the dry looper.   The flow of  felt to the line  is
 kept constant by  raising  the top set of  rollers  and increasing looper
 capacity.  The opposite action occurs when a new roll is being put on  the
                                    3-8

-------
   OJ
 TANK
 TRUCK     fUUF
   10COM1ROL
   EQUIPMNT    CAS
              BURNER
     ROTARY KILN
                                  CONTROL   CONVEYOR
                                  EQUIPMENT
                                    ASPHALT
                                    SATURATOR
                                                                                            VENT TO
                                                                                            CONTROL
                                                                                            EQUIPMENT
    DRY
  FLOATING
  LOOPER
                                                                         GRANULES
                                                                         APPLICATOR SAND
                                                                                  APPLICATOR
               VENT TO
               CONTROL
               EQUIPMENT
FINISH FLOATING
   LOOPER
                tan'J-J-1 f HEATING
                                            ROLLS TO STORAGE
                 Tm-rrf. HEATING
                                                         SHINGLE STACKLR



           a*WATERSPRAY USED ALSO. THIS IS FOLLOWED BY "SEAL-OOWN"STRIP APPLICATION.
Figure  3-4.   Typical  flow sheet  for manufacturing  shingles  and  rolls.
                                                                                                12
                                              3-10

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felt reel and spliced  in, and the felt  supply ceases temporarily.  There
are no significant emissions generated in this processing step.
     3.2.1.1.2  Saturator.  Following the dry looper, the felt enters the
saturator where moisture is driven out and the felt fibers and intervening
spaces are filled with "saturant" asphalt.  The saturator also contains a
looper arrangement which is almost totally submerged in a tank of asphalt
maintained at a temperature of 232° to 260°C (450° to 500°F).  The asphalt
absorbed increases the sheet or web weight by about 150 percent.  At some
plants the  felt is sprayed on one  side with asphalt to  drive  out  the
moisture prior  to dipping.   This approach  reportedly  results in higher
emissions than  does use of the dip process alone.    The saturator  is  a
significant  emission source of organic  particulate.
      3.2.1.1.3   Wet looper.  The  saturated felt  then  passes  through
drying-in drums  and onto  the wet looper,  sometimes called the hot looper.
The drying-in drums  press  surface saturant into  the  felt.   Sometimes
additional  saturant is also added  at this  point.  The  amount of absorp-
tion depends on the viscosity of  the asphalt  and  the  length of time the
asphalt  remains fluid.  The wet looper increases absorption by providing
time for the saturant asphalt  to penetrate  the felt.
      Emissions  from the wet looper consist of organic  particulate.  The
wet looper  is  a  significant  emission  source of  organic particulate.
      3.2.1.1.4  Coater.   If saturated  felt is being produced,  the  sheet
 bypasses the next  two steps  (coating and surfacing) and passes directly
 to the cool-down  section.   For  surfaced roofing products,  however, the
 saturated felt is carried to the coater where a stabilized  asphalt coating
 is applied to both top and bottom surfaces.
      Stabilized coating  contains  a harder, more viscous coating asphalt
 which has  a higher softening point  than saturant asphalt and  a mineral
 stabilizer.  The  coating asphalt  and  mineral  stabilizer are mixed in
 approximately equal proportions.   The  mineral stabilizer may consist of
 finely  divided lime, silica,  slate dust,  dolomite,  or other  mineral
 materials.  The softening  point of  saturant asphalts varies from 40° to
 74°C  (104° to  165°F) whereas the  softening  point  of coating  asphalt
 varies from 99° to 116°C (210° to  240°F).
                                    3-12

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     The weight of  the finished product is controlled by the  amount of
coating used.  The  coater  rollers can be moved closer together to  reduce
the amount of  coating applied to the felt, or separated to increase it.
Many modern  plants  are equipped with automatic  scales which  weigh the
sheets in the  process of manufacture and  warn the coater operator when
the product is running under or over specifications.
     The coater  is  a  significant  emissions source,  releasing asphalt
fumes containing organic particulate.
     3.2.1.1.5  Coater-mixer.  The function of the coater-mixer,  which is
usually positioned over the line at the coater,  is to mix coating asphalt
and a mineral stabilizer in approximately equal  proportions.   The stabilized
asphalt is then piped down to the coating pan.   The  asphalt is piped in
at about 232°  to  260°C (450° to 500°F), and  the mineral stabilizer is
delivered by screw  conveyor.  There  is  often a preheater immediately
ahead of the coater-mixer  to dry and preheat the material before  it is
fed into the coater-mixer.   This eliminates moisture problems and also
helps to maintain the temperature above 160°C (320°F) in the coater-mixer.
The emissions from the preheater are vented to a baghouse at some plants.
The coater-mixer is  usually covered or enclosed,  with an exhaust pipe for
the air displaced by (or carried with) the incoming materials.
     Emissions from the  coater-mixer include  both organic and inorganic
particulate,  but  are  expected to be primarily inorganic.  The emissions
from the coater-mixer are  not as significant as the emissions from the
saturator and coater.
     3.2.1.1.6  Mineral surfacing.   The  next  step in the production of
coated roofing products  is the application of mineral  surfacing.   The
surfacing section of  the  roofing  line usually  consists of a multi-
compartmented granule hopper, two parting agent hoppers, and two large press
rollers (see Figure 3-6).  The hoppers are fed through flexible hoses from
one or more machine bins above the line.   These machine bins provide tempo-
rary storage and are sometimes called surge bins.  The granule hopper drops
colored granules from its various compartments onto the top surface of the
moving sheet of coated felt in the sequence necessary to produce the desired
color pattern  on  the  roofing.  This  step is bypassed for smooth-surfaced
products.  Potential  emission sources are the machine bin, the  granule
                                  3-13

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COATED
 SHEET*.
         Figure 3-6.  Surfacing section of  typical  asphalt
                   roofing manufacturing line.
                                  3-14

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hopper, and the  hopper/sheet  interface.  At those plants visited, emissions
from  the  granule surfacing operation appeared to be minimal,  even though
no  attempt was made at  control.   Granules are usually dyed  or  oiled,
which could account for  the low level of observed emissions.
     Parting  agents  such as talc and sand (or some combination thereof)
are applied to the top and back surfaces of the coated sheet  from parting
agent hoppers.   These  hoppers are usually of an open-topped, slot-type
design, slightly longer  than  the  sheet  is  wide,  with  a  screw  arrangement
for distributing the parting  agent  uniformly  throughout  its length.  The
first hopper  is positioned between the granule hopper and the first large
press roller, and 0.2 to 0.3 m (8 to 12 in.)  above the sheet.   It drops a
generous amount of parting agent onto the top surface of the  coated sheet
and slightly  over each edge.  Collectors are  often placed at  the edges of
the sheet to pick up this overspray, which is then recycled to the parting
agent machine bin  by open screw conveyor and bucket elevator.  Emission
sources are the  machine  bin (which  is usually covered), the open  hopper,
the hopper/sheet  interface, and the  roofing sheet.  The last  two  sources
are the most  significant.   If excess material  is  recycled, the equipment
involved  (screw  conveyor, bucket elevator, etc.) is also a  potential
emission source.  The second  parting agent hopper is  located  between the
rollers and dusts the back  side of the sheet  and  is usually identical to
the top side  hopper with similar emission  sources.  Because of the steep
angle of the  sheet  at  this point, the  average fall  distance  from the
hopper to the sheet is  usually somewhat greater than on the top side,  and
more of the material  falls off the sheet.
     Talc or  sand is usually applied to both sides  when  smooth roll
roofing is  being made.   When manufacturing mineral-surfaced  products,
granules of the  proper color  combinations are added  as described above
from hoppers  and the back is  coated with talc or  sand.  Consequently, in
the manufacture  of  mineral-surfaced products, the coating of the back
side with the finely divided  talc or sand would  be a greater source of
dust than that from mineral  surfacing.
     Another  method sometimes used  to apply  backing  agent to the back
side of the sheet  is  shown in Figure 3-7.  In this technique, a hinged
trough holds  the backing material against the sheet,  which picks up only
                                  3-15

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                      LINE STOPPED    LINE RUNNING
                         HOPPER
                         FILLING  I
                                I     SHEET RUNNING
                                                       HINGED
Figure 3-7.   Alternative  method  for applying  parting agent.
                              3-16

-------
what  will  stick to it.  When  the line is not  operating, the trough  is
tipped  back so that no parting  agent will  escape past  its  lower lip.
Emissions  observed when this application technique  is used  appear to be
considerably  lower in magnitude than with the gravity dusting technique.
      3.2.1.1.7  Product cooling  and  seal-down strip  application.
Immediately after  application of the  surfacing  material, the sheet passes
through a cool-down section.  Here the sheet is cooled rapidly by passing
it  around  water-cooled rollers  in an abbreviated looper arrangement.
Usually, water is  also sprayed on the surfaces  of the sheet  to speed this
cooling process.   Emissions from this section were  not measured in this
program but, where water sprays  are used, are expected to be mostly water '
vapor  with some  mineral   particulate.   These  emissions  are usually
expelled to the  atmosphere with the aid of large, wall- or  roof-mounted
fans.
     The asphalt seal-down strip is usually applied to the self-sealing
coated roofings  in this section  by a roller partially submerged  in a pan
of  hot  sealant asphalt.   This  pan  is  usually covered  and  fugitive
emissions appeared to  be  minimal at the plants surveyed.  Some products
are also texturized at this point by  passing the  sheet over  an embossing
roll which forms a pattern  in the surface of the sheet.
     3-2.1.1.8   Finish or cooling looper.   The  cooling process  is
completed  in  the  next  section,  the finish (or cooling) looper.   The
purpose of  this section is twofold;  first, it allows the product to cool
and dry off gradually,  and, secondly, the finish  looper provides line
storage to match the continuous operation of the line to the intermittent
operation of  the roll  winder.   It also allows time for quick repairs or
adjustments to  the shingle  cutter  and  stacker during continuous line
operation or, conversely,  allows cutting and packaging to continue when
the line is down  for repair.  Usually this section  is enclosed to keep
the final cooling  process  from progressing too rapidly.  Sometimes, in
cold weather, heated  air  is also used to retard cooling.  The sheet is
relatively cool at this point;  therefore, emissions  are not expected to
be significant.
     3.2.1.1.9  Cutting and packaging.  Sheet destined for roll goods is
wound on a mandrel, cut to the proper length,  and packaged.   When shingles
                                  3-17

-------
are being  made,  the material  from  the finish looper is  fed  into the
shingle cutting machine.  After the shingles have been cut, they are moved
by roller conveyor to automatic packaging equipment or, in some plants, are
manually packaged.  They are then stacked on pallets and transferred by fork
lift to  storage  areas  or waiting  trucks.   Emissions from  the  cutting  and
packaging  operations  were not  measured but  are  not  expected  to be
significant.
     3.2.1.1.10   Process variations.   There are exceptions to the above
process  procedures.  For example:
     1.   When fiber glass  is used  for the web instead  of felt,  the
saturating  and drying-in operations  are bypassed.   (These  steps are
superfluous because the porous construction of the fiber  glass mat permits
it  to  be  completely   permeated  by  the  filled  coating   asphalt.)
     2.   The  coating  and surfacing  step is bypassed  for  saturated felt.
     3.   No seal-down  strip is applied for standard shingles  or for roll
goods.
     4.   Additional  steps,  which may be conducted off-line,  are required
for some specialty shingles.
     3.2.1.2   Materials Delivery. Transfer, and Storage
     3.2.1.2.1   Asphalt supply.  The  asphaltic material  used  to make
roofing  grades of asphalt  known  as  "saturant" and "coating asphalt" is
obtained from the petroleum industry.  It is a product of the fractional
distillation  of crude  oil  that  occurs toward the end of  the distilling
process  and is commonly known as  asphalt flux.   Asphalt flux  is  sometimes
blown  by the  oil  refiner  or asphalt processor to meet the roofing manu-
facturer's specifications.   Many roofing manufacturers, however, purchase
the flux and  carry out their own blowing.
      Asphalt  fumes,  composed  of  gaseous  HC and organic particulate,  can
be released during asphalt transfer and storage.
      Asphalt  is normally delivered  to the asphalt roofing plant in bulk
by pipeline,  tanker truck,  or rail car.  Bulk asphalts are delivered  in
 liquid form at temperatures of 93° to 204°C (200° to  400°F),  depending on
 the type of  asphalt  and  local practice.  Coating asphalts,  however,  can
 also be delivered in solid form.
                                   3-18

-------
     Several  tanker unloading  techniques  are  used.   The most common
method  is  to couple a flexible  pipe  to the tanker and pump the asphalt
directly into the appropriate storage tanks  (see Figure 3-8).  The tanker
cover  is  partially open during  the  transfer.   Since this  is  a  closed
system, the  only potential sources of  emissions  are the  tanker and  the
storage tanks.   The magnitude of  the emissions from the tanker  is  at
least  partially dependent  on  how far  the cover  is  opened.   Another
unloading  procedure,  of  which there are numerous  variations,  is to pump
the  hot asphalt into a large open funnel  which is connected to  a surge
tank (see  Figure 3-8).  From there, asphalt  is pumped into storage tanks.
Emission sources are the tanker, the interface between the tanker and the
surge tank,  the surge tank, and the  storage tanks.   The  emissions from
these sources are organic particulate.  The quantity of emissions depends
on the asphalt temperature and on  the asphalt characteristics.
     Asphalt  flux  is usually  stored at 51° to 79°C (124°  to 174°F),
although storage temperatures of up to 232°C (450°F) have been noted. The
temperature  is  usually maintained  with  steam coils  in the  tanks  at  the
lower temperatures.   [Oil-  or gas-fired preheaters are used to maintain
the asphalt flux at temperatures above 93°C (200°F).]
     Saturant and coating  asphalt  are normally stored at 204° to 260°C
(400° to 500°F).  Temperatures are maintained by heating the tanks directly
or by cycling the  asphalt through external  heat exchangers,  usually  of
the closed tube type.
     Asphalt is transferred within the plant by closed pipeline.   Barring
leaks,  the only potential  emission sources  are the end-points.   These
end-points are  the  storage  tanks,  the asphalt heaters (if not  the closed
tube type),  the  blowing stills,  the coater-mixers,  and the  saturator  and
coater pans (see Figure 3-9).
     Coating asphalt  delivered  in solid form  is  stored  in  open-ended
cardboard  tubes  or  metal  cans until needed  for use.  The quantity of
emissions   (outgassing),  if any,  depends on  ambient  temperature  and  on
the asphalt characteristics.  Coating asphalt received in  solid form must
be melted and heated to operating temperature prior to transfer.   This is
usually accomplished  in  open kettles  which discharge fumes into the
building.   Remelted  filled coating asphalt is piped directly from the
                                  3-19

-------
                  TANKER-FLEXIBLE PIPE
              (SOLID-COUPLED) DELIVERY SYSTEM
                 ASPHALT
                 FUMES
               TANKER- OPEN FUNNEL DELIVERY SYSTEM

                 ASPHALT
                  FUMES
Figure  3-8.   Asphalt  delivery  systems.
                        3-20

-------
             ALTERNATIVE COATER SUPPLY TECHNIQUES
          COATERiS
      n	PAN  l
                                 SOLID
                               ASPHALT
                               UNFILLED
Figure 3-9.   In-plant asphalt  transfers.
                       3-21

-------
kettle to the coater- pan while unfilled coating asphalt is transferred to
the coater-mixer and  then  to the coater pan.   For  filled asphalt, the
emission sources are the kettle and the coater pan.   For unfilled asphalt,
there is one additional emission source, the coater-mixer.
     In  the  case of asphalt prepared  for  shipment  elsewhere,  emission
sources  vary with  the type of product  and the manner of shipment.  As
with in-plant transfers, potential sources of emissions are from end-points
of pipeline  transfers of flux, saturant,  and  unfilled  coating  asphalt.
These are  the  sending and receiving storage  tanks.   Tanker trucks and
rail cars are loaded by direct coupling to the transfer tanks and loaded
with the tanker manhole covers open.  Emission sources are the transfer
tanks and  the  tanker.  The methods used for preparing solid asphalt and
asphalt  emulsions for delivery are not included in this program.
     3.2.1.2.2   Mineral  products  supply.   The supply of mineral  products
to the surfacing area of the roofing line  and to the coater-mixer involves
the unloading,  storage,  and transfer of the following products:
     1.  granules;
     2.  parting agent  (talc or sand); and
     3.  mineral stabilizer  (limestone, traprock, dolomite, slate).
     Granules  are  generally procured in an  oiled  or coated (painted or
dyed) state  and are essentially dust-free.  Granule  sizes vary,  depending
on  the  product being produced, but  a  typical specification allows only
                                     14
2 percent  to be smaller than 420  jjm.
     Sand  is a sharp silica or  similar fine material  which is normally
procured free  of  dirt, loam, and  other foreign material.   A  typical
specification  requires  that  100  percent pass through  a U.S.  Standard
No. 8  screen (230 urn),* 20 to 40 percent  pass through a No.  100 screen
                                                                      14
(149 urn),  and  0 to 5 percent  pass  through a No. 200 screen (74 urn).
     Talc  can  be micaceous or  foliated and is generally purchased  free  of
dirt and any foreign  material.  The  average particle size is quite  small,
  The number in parentheses  indicates  the size of the  openings  in the
  screen;  in this  case,  230 urn.
                                   3-22

-------
with a typical specification requiring that 30 to 36 percent pass through
a 200-mesh (74-um) screen.
     Mineral stabilizer  is  a fine, inorganic material such as dolomite,
micaceous materials,  slate,  limestone,  or trap rock.  It  can also be a
mixture of several of these materials since material captured in baghouses
is  recycled  at many  plants  for  use as stabilizer.  One specification
requires that  at  least 60 percent  of  the  mineral  stabilizer pass through
                          14
a 200-mesh (74-um) screen.
     3.2.1.2.3  Unloading and storage.  Rock granules are normally delivered
in  bulk  by  hopper rail car or truck and dumped  onto an underground belt
conveyor (see Figure  3-10).   They are then transported by bucket elevator,
belt conveyor,  or gravity feed pipe  to the  appropriate  silo or  storage
bin.   Potential  sources  of fugitive  emissions  are the  vehicle hopper/
conveyor bin interface,  any above-ground belt  conveyors,  all  material
transfer points,  and the  silos  or storage  bins  if not  covered.   The
underground  conveyors, being fully enclosed, are  not emission sources.
Most plants  do not enclose or ventilate these sources to control  emissions.
If  granules  are procured and maintained  dust-free,  emissions should be
minimal during these  operations.
     Granules are unloaded pneumatically  at  some plants (see Figure 3-11).
In  this  technique,  material  is transported  from  the truck (or rail car)
to  the silo  while it is  entrained  in  a column of  air.  Both negative and
positive pressure systems are used, although the positive pressure system
is  more common.  Pneumatic  transfer can generate more  dust  from the
granules.   However,   since it  is a closed system,  the  only source of
fugitive emissions  is the  discharge into the  silo.  Some  rarely used
specialty granules  are  delivered in  bags rather than in bulk.  The bags
are stacked  on pallets  for delivery,  transfer, and storage and  pose no
emission problems unless  a bag is  improperly closed or is broken.
     Sand is usually shipped in bulk and handled in the same manner as
granules.  (See Figures 3-10 and 3-11.)   Because of the generally smaller
grain  size,  the transfer of sand  can generate  more emissions than the
transfer of  granules.
     Talc is delivered  in bags or  in  bulk.   Bulk  delivery  is  more  common
and is usually by hopper rail cars  or trucks.   Talc may be transferred
                                   3-23

-------
                 SCREW OR BELT
                   CONVEYER
                                           BUCKET
                                          ELEVATOR
HOPPER BOTTOM RAILROAD CAR UNLOADING
GRAIN INTO A SHALLOW HOPPER BY THE
CHOKED-FEED METHOD (KOPPEL BULK
TERMINAL, LONG BEACH, CALIFORNIA).
                    Figure 3-10.   Mineral products delivery.

                                          3-24
                                                              16

-------
   a. NEGATIVE PRESSURE
     CONVEYING SYSTEM
      "FlPfl
                   HARROW BLADE
                  CENTRIFUGAL rAH
CLOTH
FILTER
                                           CYCLONE\   /
                                           PRODUCT \ /
                                          COLLECTOHW

                                                     ' AIRLOCK
                                  <^A1
                                                .
                             IStOHAGErTSILO
          CAR
 b. POSITIVE DISCHARGE
    CONVEYING SYSTEMS
  POSITIVE
DISPLACEMENT
  BLOWER
                  FIXED
                  HOPPER
ROTARY-VANE-'
  FEEDER
                         CYCLONE
                         PRODUCT
                        COLLECTOR
          POSITIVE
        DISPLACEMENT
          BLOWER
                                                   	. CLOTH
                                                  J	   I FILTER
                                         CYCLONE
                                         PRODUCT
                                        COLLECTOR
   Figure 3-11.   Pneumatic  conveying systems.**
                              3-25

-------
pneumatically to  the storage  silo,  usually with  a  positive pressure
system (see  Figure 3-11).   A screw conveyor may be used to transfer the
talc from the trucks to storage.  The ..silo is usually enclosed and vented
to a fabric filter.   Another common approach is to dump the talc from the
vehicle  hopper  onto an  underground belt or screw conveyor through a
sleeve  connecting the  vehicle hopper  and  the conveyor  hopper (see
Figure 3-10).   The  material is then transferred  to  a bucket elevator,
raised to the top of the silo,  and piped by gravity feed or airslide into
a covered silo.  Fugitive emission sources are the sleeve interfaces with
the  hopper  and conveyor bin,  any  open  portions  of the conveyor system,
and  material transfer points.  The  only other emission source  is  the
exhaust  from the talc silo.   Bagged material  is delivered on pallets,
usually  by  boxcar.   The loaded pallets  are  transferred by fork lift to
storage  areas.   Fugitive emission  sources are torn, broken,  or  inadequately
sealed bags.
     Mineral  stabilizer is delivered in bulk and transferred in the same
manner  as talc, often by the same conveying equipment.  Emission sources
are  the  same as those  for  talc.
     3.2.1.2.4  In-plant transfers and temporary storage.   The movements
of asphalt  and mineral  products in a roofing plant are illustrated  in the
simplified  block diagram of Figure 3-12.  The  techniques used to accomplish
these  transfers are reviewed in the following  paragraphs.
     Asphalts are transferred  from  one point  to another in the roofing
plant  by pipeline;  therefore,  the only sources  of emissions are the end
points  (flux  tanks, in-process tanks, asphalt  heaters,  saturator  pan,
 coater-mixer, coater,  etc.) which are  discussed elsewhere.
      Granules  are  sometimes transferred from  storage bins  to bucket
 elevator hoppers with shovels or  a front-end loader.  When specialty
 granules are received  and stored in bags,  the bags are emptied into the
 bucket  elevator  hopper  (see Figure  3-13).   A much more  common  technique,
 however, is to use a belt conveyor to load the bucket elevator.  Granules
 are dumped  onto the conveyor belt by gravity, raised by bucket elevator,
 and fed by gravity through flexible pipes  into  machine bins.   Machine
 bins,  located  over the  roofing line  (or  machine),  provide temporary
 storage for the particular granule colors  needed for the  roofing product
                                   3-26

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     BAGHOUSE
  BAGGED GRANULES.,
  SAND. TALC OR MICA

BUCKET ELEVATOR
Figure 3-13.  In-plant  transfer of bagged mineral products.
                              3-28
-------
being  manufactured.   Some compartments of the machine bin are also  used
for the parting agent  (usually talc).  The potential emission sources are
the silo/bin  unloading point, the conveying system, the bucket elevator
hopper, the  bucket elevator, and the  machine  bins.   Fugitive emissions
from these sources should be  minor if  the granules are procured oiled (or
dyed)  and dust-free.
     In-plant  transfers  of  sand, sometimes used as a parting agent, are
usually conducted  in the same manner as granules.  The potential emission
sources are also the same, but the magnitude of the emissions will probably
be higher as  a consequence of the generally  smaller grain size of the
sand.
     Talc, the most  commonly used parting agent, may also  be  transferred
within the plant by open belt conveyor and bucket elevator.  A more usual
approach, however,  is  the use of gravity, air slides, screw  conveyors,
and sometimes  bucket elevators.   Another approach, not yet very common
for in-plant  transfers,  is  pneumatic conveying.   When talc is received
and stored in bags,  the bags are emptied into a bucket elevator hopper
(see Figure 3-13).   Potential emission sources and emissions depend on
the transfer  system  used.   When  bagged talc is  used,  both the dumping
process and the empty bags are potential  emission sources.   Other potential
emission sources  are the belt conveyor, the  bucket elevator, and the
machine bin.    With pneumatic transfer, air slides, and screw conveyors,
the only potential  sources  of emissions are the silo, the machine bin,
and (with positive-pressure systems)  line leaks.
     Mineral   stabilizer can  be transported  using the same techniques as
used with talc.  However, like talc, mineral stabilizer is more commonly
moved  by  gravity,  air  slides,  screw  conveyors, and  sometimes  bucket
elevators.   With a gravity  feed  system, fugitive  emission  sources  are
line leaks and any open transfer points.  Bucket  elevators and their
transfer points are  sources  of fugitive emissions, as are  the  storage
silo and the  coater-mixer.   These are discussed elsewhere in this chapter.
Air slides and screw conveyors  are closed systems  and are not,  of them-
selves, emission sources.
     3.2.1.2.5  Asphalt processing.   Asphalt  flux is the  bottoms  from the
petroleum refining process.   It can  consist of the residuums from  a
                                  3-29
-------
single crude or  from' a blend of many crudes.  A number of products are
produced for the asphalt roofing industry, as detailed in Section 3.1.
The principal products, however, are the "saturant" asphalt and "coating"
asphalt used in  the production of asphalt roofing and siding.  One differ-
ence  between these  two  asphalts is their softening point.   Saturants
usually have a softening point  between 40°  and  74°C (104° and 165°F),
while  coating asphalts  soften  at  about  tlO°C (230°F).   In addition,
flexibility  at  lower  temperatures  and penetration  into  the web  are
important parameters.
      Asphalt is  blown  with  air  in asphalt  blowing stills (see Figure  3-14).
A blowing still  is  a tank fitted near its  base with  a sparger (air lines  in
a spider arrangement).   The purpose of the sparger is to increase contact
between the  air  and the  asphalt.  Air is  forced through holes in the  sparger
into  a tank  of hot  [204° to 243°C (400° to 470°F)] asphalt flux.  This air
rises through the asphalt,  participating  in  an exothermic  oxidation reaction.
Oxidizing the asphalt has the effect of raising  its  softening temperature,
reducing penetration,  and modifying other characteristics.   Sometimes cata-
 lysts are  added  to  assist in this transformation.18   The time required for
 air blowing of asphalt depends on a number of factors.  These factors  include
 the characteristics of the  asphalt  flux,  the characteristics desired  for the
 finished product, the reaction temperature,  the  type of still used, the  air
 injection rate,  and the efficiency  with which the air entering the still is
 dispersed throughout the asphalt.   Blowing times may vary  in duration from
 30 minutes to 12 hours.
      Asphalt  flux  characteristics  depend on the source of the crude  and
 the method  used to refine  it.  The type of flux used will  vary from plant
 to plant but  should stay fairly constant at any one plant.  The softening
 point of  the principal  products of the  blowing process  (saturant and
  coating asphalts)  varies from one  location to another.
      Asphalt  blowing  is a  highly  temperature-dependent process,  as  the
  rate  of  oxidation  increases rapidly with  increases  in temperature.
  Asphalt is  preheated to 204°  to 243°C (400°  to 470°F) before blowing is
  initiated to  assure that the oxidation process will start at an acceptable
  rate.   Conversion  does  take place at lower temperatures but is much
  slower.18   Due  to the  exothermic  nature of  the  reaction,  the  asphalt
                                    3-30
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temperature rises  as. blowing proceeds.  This,  in turn,  further  increases
the reaction  rate.   Asphalt temperature is normally kept at about 260°C
(500°F) during blowing by spraying water onto the surface of the asphalt,
although external cooling may also be used to remove the heat of reaction.
The heat  of  reaction  during  air  blowing  is  relatively low for some
crudes, and auxiliary  cooling  may not be required.  The allowable upper
limit to  the  reaction  temperature is dictated by safety considerations,
with the  maximum temperature  of the asphalt  usually  kept at least 28°C
(50°F) below  the flash point of the,asphalt being  blown.  The design and
location  of the  sparger  in the  still  governs how much of the  asphalt
surface area  is physically contacted by the injected air, and the vertical
height of the still  determines the time span of this contact.   Vertical
stills, because  of their greater  head (asphalt height) require less air
flow for  the  same amount of asphalt-air contact  (see Figures  3-15 and
3-16).  Both  vertical  and horizontal  stills  are still  in use,  but where
new design is involved,  a  vertical type  is  preferred  by the industry
because of the increased asphalt-air contact  and  consequent reduction in.
               iq
blowing times.     Asphalt losses from vertical stills  are also reported
                                              1 g
to be less than those  from  horizontal stills.     All recent blowing still
installations  have been  of the vertical type.  Asphalt blowing can be
either a  batch process or  a continuous operation.  These operations are
described  in  more detail in Reference 18.   All stills  at roofing plants
are believed  to use  the  batch process, as do  most of the asphalt processing
plants, but the ratio  among refineries is unknown.
     The  emissions from  the blowing still are  primarily organic parti-
culate with a fairly high concentration  of gaseous hydrocarbon  (6,000 to
7,000 ppm) and polycyclic organic  matter [112,308 ug/Nm3 (0.00007 lb/ft3)].
The blowing still has  the highest total  emissions  of  any of the emission
sources in an asphalt  roofing plant.
3.2.2  Process Emissions
     As was discussed in Section  3.2.1, there  are  a considerable number
of emission sources  in a typical asphalt roofing and siding manufacturing
plant.   Emissions result  from  asphalt handling  and  storage,   asphalt
processing, various  roofing line operations,  and mineral products handling
and storage.  The  potentially significant sources are listed in  Table 3-1,
                                   3-32
-------
KNOCK OUT BOX/

OR          FUMES
CYCLONE     V
                                        :STEAM BLANKET.vv--'-
                                        i^s^DSsissiS^
WATER VALVE

    WATER
                                                            AIR COMPRESSOR
                   STILL
    Figure 3-15.  Design features  of vertical still equipped
              with a cyclone oil  recovery system.
                            3-33
-------
  VALVE 0-QP




WATER
                                                        AIR COMPRESSOR
         Figure 3-16.   Design features of horizontal still.
                                3-34
-------
 which also catalogs some  of  the parameters which are believed to affect
 both the  magnitude  and type of emissions  from  those activities which
 involve the processing, storage,  or use of asphalt.
      There are many variables which  could potentially affect emissions
 from asphalt roofing manufacturing operations.  For example, particulate
 emissions  from roofing lines (asphalt  fumes  from the saturator, wet
 looper,  and coater)  may increase  on a kilogram-per-megagram-shingle  basis,
 with increases in line  speed.   No  test data are available  to  confirm or
 disprove this statement.  Also,  a number of industry representatives are
 of  the  opinion that spray or spray/dip saturators create more fumes  than
 do  dip  saturators, other  factors being equal.   The test data suggest a
 similar  conclusion since the one spray/dip  saturator  tested generated  5
 to  10 times as much particulate  emission on a  kilogram-per-hour basis as
 the  dip  saturators tested.  It is also  hypothesized that:
     1.   uncontrolled  emissions  are higher for asphalts  derived from the
 more volatile West Coast or Middle  East  crudes than from the midcontinent
 crudes;
     2.  vertical stills emit fewer fumes than horizontal units;
     3.  uncontrolled emissions from  roofing lines are lower when saturants
 and coatings are used which have higher  than normal softening points; and
     4.    uncontrolled  emissions  of asphalt particulate increase with
 increases in the moisture content of  the felt.
     No  one  to  our knowledge has yet attempted  to  isolate  and quantify
the effects  of  these variables on  uncontrolled  emission rates.   Plants
were tested, however, in different parts of the country and with different
types of saturators, so the range of  data  collected should  encompass  the
effect of many of these variables.  A summary of the test data for uncon-
trolled emissions is presented in Table 3-2.
     The sampling  and  analysis techniques  developed (and used) for this
series of  tests on sources of asphalt fumes are somewhat different from
the methods used by other investigators (see Appendix D for test method).
As a result,  data  from other sources could  not  be correlated to data
developed from this program.
     3.2.2.1    Emissions  from Asphalt  Handling  and Storage.     The
uncontrolled emissions from one asphalt surge tank and five 114-m3
                                  3-35
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-------
(30,000-gal) asphalt storage  tanks  were measured at one roofing plant.
Hot asphalt was being unloaded from trucks, recirculated to the saturator,
and pumped to the coater-mixer while the tests were conducted.   The range
of uncontrolled  emissions was  from 0.64 kg/h (1.4 Ib/h) to 1.63  kg/h
(3.6 Ib/h).  The  average  emission rate for the three tests was 1.0 kg/h
(2.2 Ib/h).
     3.2.2.2    Emissions  from Blowing  Stills.    One  blowing  still
installation was  tested  during this program.  The uncontrolled emission
rate was  measured during three saturant asphalt blows and three coating
asphalt blows.   The  range of uncontrolled emissions during the saturant
blows  was from  57.61  kg/h  (127 Ib/h)  to  102.97 kg/h  (227 Ib/h).   The
average emission rate for  the three  saturant  blow tests  was 80  kg/h
(176 Ib/h).  The rate  of uncontrolled  emissions from  the  coating  blows
varied  from 95.71 kg/h   (211 Ib/h)  to 103.87 kg/h  (229 Ib/h).    The
average for the  three coating blows  was 98.6 kg/h  (217  Ib/h).   The
average  uncontrolled  emission rate for  all  six  runs  was 89.4 kg/h
(197 Ib/h).
     3.2.2.3   Emissions  from Roofing  Line Operations.   Emission   tests
were  conducted at four  asphalt roofing plants where emissions from  a
varied grouping  of sources were measured.
     At Plant  A the  emissions  from  the dip  saturator,  wet looper, and
coater were measured.   The uncontrolled  emissions varied  from 4.99 kg/h
(11  Ib/h) to 7.98 kg/h (17.6 Ib/h), and  the  average of the four  tests
was  6.62  kg/h  (14.6  Ib/h).
     At  Plant B the emissions  from  the dip  saturator, wet  looper, and
coater were measured.   The uncontrolled  emissions ranged  from 8.89 kg/h
 (19.6  Ib/h) to  15.15  kg/h  (33.4 Ib/h), with an average emission  rate
of 12.5 kg/h  (27.5 Ib/h).
     There were three tests  conducted to determine the emissions  from  a
spray-dip saturator, wet looper, coater, and eight asphalt storage tanks
at Plant C.  The data from one of the  tests cannot be used because of an
accidental  bumping of the stack  wall  with the  sampling probe  during  the
test.   The uncontrolled  emission rates for the two tests were 31.52 kg/h
 (69.5 Ib/h) and 28.39  kg/h (62.6 Ib/h).
                                   3-38
-------
      The uncontrolled  emissions  from  a  dip  saturator  and wet  looper were
 measured at  Plant  D.   There were three tests, and  the  emissions  ranged
 from 4.99  kg/h  (11 Ib/h) to  10.16  kg/h (22.4 Ib/h).   The average for
 the three tests was 6.93 kg/h (15.3 Ib/h).
      3.2.2.4  Emissions from Mineral Handling and Storage.   Particulates
 may be emitted from any of  the mineral  handling and transfer operations,
 but most of  the  particulate emissions usually occur  at transfer points
 and use points.   No tests were conducted during this program to determine
 the emissions  from mineral transfer and  storage  operations  (screw
 conveyors,  belt  conveyors,   air  slides, bucket  elevators,  pneumatic
 conveyors,  and  silos).   Uncontrolled emissions from the  conveying,
 screening,  and handling  of  crushed  stone  have been  estimated to be
 1  kg/Mg (2  Ib/ton)  of  inorganic particulate.20
 3.3 BASELINE EMISSIONS
 3.3.1   Introduction
     The  baseline emission level  is  the  level  of control that  is achieved
 by the  industry in  the  absence of a  new  source performance standard.  The
 opacity and particulate emission regulations  for  the  States which have
 roofing plants  are  summarized in Table  3-3.   A  number of regional and
 State agencies were contacted to  ascertain if  the regulations were applied
 on  a plant basis or  on an  emission source  basis.   The typical State
 considers that  a  plant is one source, so the  regulation applies to the
 plant.   Based on  the average particulate weight permitted, a small roofing
 plant producing  27.2 Mg/h (30 tons/h) of product  is allowed emissions
 of  18.14  kg/h  (40 Ib/h).   This is equivalent to  0.67 kg/Mg (1.33 Ib/ton)
 if  expressed  as  an  emissions to product ratio.   The typical  opacity
 regulation  is 20 percent.
     If the State regulations are compared with the actual  uncontrolled
 emissions at plants  tested (Table 3-2), it is noted that the uncontrolled
 emissions from three of the  roofing  plants without stills would meet the
mass emissions standards of most States.   Emissions from the fourth plant
would not meet the  mass emission  standards of  most States.  Uncontrolled
emissions from blowing  stills exceed the mass  emissions  standards of all
States.
                                  3-39
-------
TABLE 3-3.  SUMMARY OF EMISSION REGULATIONS AND LOCATION OF
               ASPHALT ROOFING PLANTS BY STATE
State
A1 abama
Arkansas
California
Colorado
Connecticut
Florida
Georgia
Illinois
Indiana
Kansas
Louisiana
Plant No. of
size plants
L
M 6
S
L
M 5
S
14
L
M 2
S
L
M 1
S
L
M 4
S
L
M 6
S
L
M 10
S
L
M 3
S
L
M 2
S
L
M 3
S
Parti cul ate
kg/h
15.68
15.12
13.53
15.66
15.10
13.43

13.43
13.43
13.43
15.66
15.10
13.43
15.66
15.10
13.43
21.97
21.00
18.14
11.35
8.60
7.08
21.97
21.00
18.14
21.97
21.00
18.14
21.97
21.00
18.14
. . b
emissions
Ib/h
34.57
33.30
29.83
34.52
33.28
29.60
c
29.60
29.60
29.60
34.52
33.28
29.60
34.52
33.28
29.60
48.44
46.30
40.00
25.03
19.08
15.60
48.44
46.30
40.00
48.44
46.30
40.00
48.44
46.30
40.00
Visible emissions
Percent opacity
20
20 (new)
40 (existing)
d
20
20
20
20 (on dusts)
(nuisance control)
30
40
20 (new)
40 (existing)
20
                             3-40
-------
TABLE 3-3.  SUMMARY OF EMISSION REGULATIONS AND LOCATION OF
            '  ASPHALT ROOFING PLANTS BY STATE
                         (continued)
State
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
New Jersey
New Mexico
North Carolina
Ohio
Plant
size
L
M
S
L
M
S
L
M
S
L
M
S
L
M
S
L
M
S
L
M
S
L
M
S
L
M
S
L
M
S
No. of Parti cu late
plants kg/h
22.11
3 21.08
18.14
21.62
3 20.34
18.14
21.97
1 21.00
18.14
29.97
5 21.00
18.14
21.97
1 21.00
18.14
21.97
5 21.00
18.14
0.45
6 0.45
0.23
21.97
1 21.00
18.14
21.97
3 21.00
• 18.14
21.97
6 21.00
18.14
emissions
Ib/h
48.75
46.37
40.00
47.67
44.84
40.00
48.44
46.30
40.00
48.44
46.30
40.00
48.44
46.30
40.00
48.44
46.30
40.00
1.00
1.00
.50
48.44
46.30
40.00
48.44
46.30
40.00
48.44
46.30
40.00
Visible emissions
Percent opacity
No visible
20
40
20 (new)
60 (existing)
40
20 (new)
40 (existing)
20
20
20 (new)
40 (existing)
20
                           3-41
-------
       TABLE 3-3.  SUMMARY OF EMISSION  REGULATIONS AND  LOCATION OF
                    ASPHALT  ROOFING  PLANTS BY STATE
                                (continued)
Plant
State size
Oklahoma
Oregon
Pennsylvania
South Carolina
Tennessee
Texas
Utah
Washington
West Virginia
L
M
S
L
M
S

L
M
S
L
M
S
L
M
S



No. of Particulate emissions
plants kg/h
21.97
3 21.00
18.14
21.97
4 21.00
18.14
4 e
21.97
1 21.00
18.14
15.66
2 15.10
13.43
39.13
10 33.72
30.57
1
2
1
Ib/h
48.44
46.30
40.00
48.44
46.30
40.00

48.44
46.30
40.00
34.52
33.30
29.60
86.26
74.35
67.40
85%
Control
g
g
Visible emissions
Percent opacity
20
20 (new)
40 (existing)
f
20 (new)
40 (existing)
20
20
20 (new)
40 (existing)
20 (new)
40 (existing)
20
Production rates for typical plants operating 4,000 hours per year are:

          Large                    Medi urn                   Small
     Mg/yr     tons/yr
     281,201   310,000
Mg/yr     tons/yr
219,518   242,000
Mg/yr     tons/yr
109,759   121,000
                                   3-42
-------
        TABLE 3-3.  SUMMARY OF EMISSION REGULATIONS AND LOCATION OF
                     ASPHALT ROOFING PLANTS BY STATE21
                                (concluded)
  State
Plant  No.  of  Participate emissions13
size    plants  kg/h       Ib/h
Visible emissions
Percent opacity
 Emissions allowed by typical process weight tables:
               Small
                    Medium
  Hourly  kg/h
          18.14

  Annual  Mg/yr
          72.56
     Ib/h
     40.00

   tons/yr
     80
kg/h
21.00
Mg/yr
84.00
Ib/h
46.30
tons/yr
92.60
kg/h
21.97

Mg/yr
87.88
 Ib/h
 48.44

tons/yr
 96.88
 Regulation is by county or Air Pollution District.  Bay Area = 18.14 kg/h
d(40 Ib/h).  Los Angeles Pollution Control District = .08 gr/DSCF.
620 percent for Los Angeles Pollution Control District and Bay Area.
 In Pennsylvania the regulation is based on DSCFM of gas emitted.   For
fthe Asphalt Roofing Industry, emissions should not exceed .04 gr/DSCF.
 20 percent for a period or periods aggregating more than 3 minutes in
 any one hour.
9These two states did not include a general process curve in their 1972
 standard for particulate.
                                   3-43
-------
     It appears that  most States enforce the  regulations by relying on
opacity readings and nuisance complaints.  Although an opacity regulation
is convenient  from  an  enforcement point  of view, opacity measurements do
not appear to reflect the degree of control being achieved.   The emissions
data collected from control devices during the tests do not show a direct
correlation between particulate emissions and opacity readings.  According
to the "Afterburner Systems Study," hydrocarbon emissions are not visible
at temperatures above 427°C (800°F), but there is virtually no destruction
of hydrocarbons below 538°C (1000°F).22  Therefore, it is possible that
an afterburner operating between these temperatures could operate with a
zero opacity  and  yet remove little or no particulates or gaseous hydro-
carbons.
     Conversely,  a high opacity reading  is  usually indicative of high
mass  emissions.   Therefore, many  States measure particulate emissions
only  if opacity readings indicate that  such a measurement is warranted.
When a  State  agency does  decide  to test  for particulates, the test method
normally  used is  the EPA Method 5  (which employs a heated probe).     The
heated  probe  lowers the particulate catch because some of the fume  is in
a gaseous state at test temperature.   Therefore, the test method used by
most  States is not adequate to determine if particulate emissions  are at
an acceptable level.   As a result,  the common practice in the  roofing
industry  is to apply  only the  controls  necessary to meet opacity require-
ments.  This  limit is  usually  attained through the  use  of afterburners to
control  blowing  stills.   High  velocity  air  filters, electrostatic
precipitators, or afterburners are  commonly  used to control emissions from
the  saturator coater and asphalt storage tanks.
3.3.2  Definition of Baseline
      Project  personnel surveyed 13 plants with  blowing stills.  Many of
the  afterburners controlling  the stills appeared  to be homemade or had
 insufficient  temperatures and  residence times.  One still was found which
was  controlled by  an afterburner that had the potential for high removal
 efficiency  as  determined by  visible  emission  readings,   design
 configuration, and operating temperature.   This  still  was tested,  and the
 uncontrolled emissions are included  in Table 3-2.   Saturators,  coaters,
 and storage  tanks  were surveyed at 20 plants.   Four of these plants were
                                   3-44
-------
tested because they were found to use better designed and operated control
devices.  The  uncontrolled emissions are reported  in Table 3-2.   Other
less efficient devices  on  stills, saturators,  coaters,  and  storage tanks
were reportedly  satisfactory for State  and local  agency requirements,
primarily enforced  solely  by opacity.  As noted  earlier, a  plant without
a still  and  without controls will meet SIP's.  Due to a lack of data to
show otherwise,  it  is assumed that  all  plants are meeting the SIP's;
therefore, baseline conditions  are  defined  for small, medium, and large
plants as shown  in  Table 3-4.   In some cases,  actual plants are probably
exceeding the mass emissions while others are somewhat lower.
                                  3-45
-------
  TABLE 3-4.   BASELINE PARTICULATE EMISSIONS FOR VARIOUS SIZE MODEL PLANTS
                 ACCORDING TO STATE IMPLEMENTATION PLANS (SIP's)
                          Production rate
Plant size
Mg/yr
tons/yr
Particulate emissions
HkgTFiTbTiT
Large

Medium

Small
281,201      310,000       21.97

219,518      242,000       21.00

109,759      121,000       18.14
                             48.44

                             46.30

                             40.00
                                  3-46
-------
3.4  REFERENCES FOR CHAPTER 3
 1.  Asphalt  and Tar Roofing  and  Siding Products.  U.S. Department of
     Commerce.   Washington,  D.C.   Series  M-29A.   Yearly Summaries for
     1967-1976 and 1978.
                                       *

 2.  Asphalt  Roofing  Manufacturers Association.   Manufacture,  Selection,
     and  Application  of Asphalt Roofing and Siding Products.   Twelfth
     Edition.  New York, N.Y.  1974.  p. 3.

 3.  Cantrell, A.   Annual  Refining  Survey.   The Oil and Gas  Journal.
     p. 108-146.   March 20, 1978.

 4.  Tight Money  Crimps  House-Building Market.  The News and  Observer.
     Raleigh, N.C.  p. IV-9.   February 25, 1979.

 5.  Telecon.  North  Carolina  Distributor  of Roofing Products  with
     Ante!, D. C., MRI/NC.   March 7, 1979.   Prices  of asphalt roofing
     shingles.

 6.  Telecon.  Merz,  S. , Celotex Corporation, with Cooper, R., MRI/NC.
     March 8, 1979.   Dry materials prices.

 7.  Asphalt Roofing Manufacturers Association.  List of Plants:  Asphalt
     and  Tarred  Roofing Manufacturers.   New York, N.Y.   May 12, 1978.
     4 p.

 8.  Asphalt and Tar Roofing and Siding Products:  1977.   U.S.  Department
     of Commerce, Washington, D.C.   M-29A(77)-1.  June 1978.  3 p.

 9.  GAO  Predicts Higher  Oil  Costs, More Inflation.   The News  and
     Observer.  Raleigh, N.C.   p. 3.   March 8, 1979.

10.  Telecon.  Lambert,  D., Exxon Corporation, with Ante!, D.  C., MRI/NC.
     March 8, 1979.   Prices of asphalt.

11.  Daniel son, J. A.   Air Pollution Engineering Manual.   2nd Ed.  Los
     Angeles Air  Pollution Control  District.   PB-225 132.   May  1973.
     p. 379.

12.  Reference 11, p.  380.

13.  Reference 11, p.  382.

14.  Letter and attachments from Hambrick, M. M., Celotex Corporation, to
     Goodwin, D.   R. ,  EPA/ESED.   May  30,  1975.   Information  on plants at
     Goldsboro, N.C.;  Los Angeles,  Calif.; and Cincinnati, Ohio.
                                  3-47
-------
15.  Letter from Angarano, J. A., The Flintkote Company, to Goodwin,
     D. R., EPA/ESED.  July 17, 1975.  p. 4.  Information concerning air
     pollution control for plants at Ennis, Tex., and Los Angeles, Calif.

16.  Reference 11, p. 336.and 354.

17.  Reference 11, p. 363.

18.  Corbett, L. W.  Manufacture of Petroleum Asphalt.  In:  Bituminous
     Materials; Asphalts, Tars, and Pitches, Vol. 2, Part 1, Hoiberg,
     A. J. (ed.).  New York, Interscience Publishers, 1965.  p. 99-103.

19.  Letter from Merz, S. A., Celotex Corporation, to Ananth, K. P.,
     MRI/KC.  February 4, 1975.  Process operations at Goldsboro, N.C.
     plant.

20.  U.S.  Environmental Protection Agency.  Compilation of Air Pollutant
     Emission Factors.  AP-42.  Research Triangle Park, N.C.  April 1973.
     p. 8.20-1.

21.  Analysis of  Final State-Implementation Plans - Rules and
     Regulations.  U.S. Environmental Protection Agency.  Research
     Triangle Park,  N.C.  APTD-1334.  July  1972.  p. 29-31, 51-52.

22.  Afterburner  Systems  Study.  U.S. Environmental Protection Agency.
     Research Triangle Park, N.C.  EPA-R2-72-062.  August 1972.   p. 18a
     and  19.

23.  U.S.  Environmental Protection Agency.  Part 60:  Standards   of
     Performance  for New  Stationary  Sources.   Method 5:  Determination of
     Particulate  Emissions  from Stationary  Sources.  40 CFR 60.
     Washington,  D.C.  Government Printing  Office.  August 18, 1977.
                                   3-48
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                    4.  EMISSION CONTROL TECHNIQUES
4.1  INTRODUCTION
     Techniques used  to  minimize emissions from asphalt blowing stills,
asphalt  saturators,  wet  loopers, and coaters  fit  into two categories,
that is, process controls and add-on emission controls.  Both process and
add-on  controls  are  discussed  in  the following sections,  as  are the
control  strategies  for each of these categories.  Emission sources and
add-on control devices are summarized in Table 4-1.
4.2  PROCESS AND EQUIPMENT CONTROLS
     Process selection and  control  of process parameters reportedly can
be used  to  minimize uncontrolled emissions from asphalt blowing stills,
asphalt  saturators, wet loopers,  and coaters.  Process controls  include
the use of the following:
     1.  dip  saturators,  rather than  spray or  spray-dip  saturators;
     2.  vertical  stills,  rather than horizontal  stills;
     3.  asphalts that inherently produce low emissions;
     4.  higher flash point asphalts;
     5.  reduced temperatures in the asphalt saturant pan;
     6.  reduced asphalt storage temperatures;  and
     7.  lower asphalt blowing temperatures.
     Literature searches were  conducted,  and the industry  was  surveyed;
but no  data were supplied or located which  would quantify the effects of
these process controls, either individually or collectively,  during the
development phase  of this  program.   However,  such  controls  (1) seem
reasonable from an engineering standpoint, (2) reflect opinions expressed
by  people  in  the  industry,  and  (3) are  supported  by published
            1  p
information. '   In consideration  of these variables and their effects,
the emissions testing program  included several types of control devices,
 The wet looper is also called a "hot looper" or the "striking-in" section.
                                   4-1
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        TABLE 4-1.  ASPHALT ROOFING PLANT EMISSION SOURCES
                         AND ADD-ON CONTROL DEVICES
Emission sources
Control devices
A. Saturator, wet looper (hot
   looper), and coatera
B. Coater-mixer

C. Asphalt blowing still

D. Asphalt storage tanks0

E. Mineral surfacing and
   granule application

F. Granule and mineral
   delivery,  storage, and
   transfer
Afterburner
High velocity air filter
Electrostatic precipitator

High velocity air filter

Afterburner

Mist eliminator

Baghouse


Baghouse(s)
aThese  sources  usually  share  a  common  enclosure,  and  emissions
•are ducted to  a  common control  device.
"Emissions  from the  coater-mixer are controlled,  at some  plants,
  by routing fumes to the control  device  used for  sources
  listed in  A, above.     ""                         .
GSome plants control emissions  from storage tanks with the same
  device used for  processes listed in A and then use a mist
  eliminator during periods when the roofing line  is not operating
  (e.g., weekends).  Asphalt delivery can be accomplished  via a
  closed system  which vents emissions to  the same  control  device
  as that used for the tanks.
                               4-2
-------
 plants in different parts  of the country using different asphalts, and
 dip saturators as well  as spray-dip saturators.
 4.2.1   Saturators
      Dip  saturators have been selected  for most new  asphalt  roofing
 line installations in  recent years,  and this trend is  expected  to  continue.
 The most  common technique for increasing line speeds  in existing installa-
 tions,  however, is to add saturant sprays.  This practice is expected to
 increase  uncontrolled  emissions considerably, since spray-dip saturators
 appear to generate more  particulate emissions than do  dip  saturators.
 Data collected during the test program  appears to  support this  conclusion
 but are not  sufficient  to quantify the  effect (see Chapter 3, Table 3-2).
 4.2.2   Asphalt Blowing  Stills
     Recent  asphalt  blowing  still  installations  have been  almost
 exclusively  of the vertical type because  of their higher efficiency and
 lower  emissions.    Vertical  stills  occupy  less  space and require no
 heating during oxidizing  [if  the temperature of the incoming  flux is
 above 204°C  (400°F)].   Vertical stills will,  therefore,  probably be used in
 all  new  installations  equipped  with stills  and  for most  retrofit
 situations.
 4.2.3   Asphalt  Softening  and Flash Points
     It  is  reported that asphalt fluxes  with lower  flash  points  and
 softening points  tend  to  have higher emissions.2  These asphalt fluxes
 generally have  been  less  severely cracked and contain  more  low-boiling
 fractions.  Many  of  these light ends can be expected to boil off during
 blowing.  The  reported  ranges of softening and flash points for asphalt
 fluxes, saturants, and  coatings currently in use in the asphalt roofing
manufacturing  industry  are listed in Table  4-2.   Limiting  the  minimum
 softening and  flash  points of asphalt flux  should reduce the amount of
 fumes generated during  blowing since  less  blowing  is required to produce
a  saturant  or  coating  asphalt.   Catalysts are often  used  in coating
asphalts to  reduce blowing  times.  Their effect on emissions is  unknown.
     Saturant  and  coating asphalts  with  high softening points  should
reduce  emissions  from felt saturation and coating operations.   However,
producing the  higher softening asphalt flux  requires more blowing, which
increases uncontrolled  emissions  from the blowing  operation.   Whether
                                   4-3
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                      TABLE 4-2.   ASPHALT PARAMETERS4
Parameter
                  Asphalt flux
                          Asphalt
                          saturant
 Asphalt coating
Softening
  point

Flash
  point
 26-49     (79-110)    40-71  (104-158)    99-118   (210-244)
221-349    (430-660)    >246    (>475)
>246
(>475)
                                  4-4
-------
 overall  plant emissions are decreased depends on the relative effective-
 ness of  the  emission control  equipment on the blowing  still  and the
 saturator and coater,  respectively.   Typically,  the afterburner controlling
 emissions from  a  blowing still is more  effective  in,reducing gaseous
 hydrocarbons  than the particulate control  devices  which may be used on
 the  saturator.
 4-2.4 Storage and Use Temperatures
      As  the  temperature  of an  asphalt  is  raised above  its  softening
 point, emissions from  that  asphalt can be expected  to increase.
      Emissions can be minimized by keeping storage  and  use temperatures
 as  low as possible.   Table 4-3 lists the  range of  temperatures  noted
 during surveys and tests conducted for the  study.
 4.3   CONTROL  SYSTEMS
      The  control  systems  used in this industry  include various types  of
 hoods, total  enclosure capture  systems, and  add-on control  devices.
 4.3.1  Capture Systems
      Capture  of  emissions  from asphalt blowing  stills,  asphalt storage
 tanks, asphalt truck  unloading, the coater-mixer, and from mineral* and
 granule unloading,  storage  and transfer  systems is  (or  can  be) accom-
 plished by  the use of closed  systems.   Uncontrolled emissions  from the
 mineral surfacing  and  granule  application areas  may  be captured by hoods
 or by total enclosure of the application  area.
      Emissions from the  saturator,  wet  looper,  and  coater are usually
 collected by  a single  enclosure  as shown  in Figure 4-1,  by a  canopy type
 hood, or  by an enclosure  and hood combination (saturator and wet looper
 enclosed and  coater hooded).   The doors  shown in Figure 4-1  allow the
operators access  as required for maintenance and repair.   This particular
 system is  designed with two-stage fans  to  provide  additional exhaust
ventilation during periods  when the  doors  are open.  The ventilation
requirements to  obtain complete  pickup will  vary depending on the  extent
to which   openings in the enclosures  are  minimized and on  safety
considerations.
 This classification includes mineral stabilizer, talc, and sand.
                                  4-5
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     Safety considerations dictate that the concentration of combustible
pollutants at the fume source and in the capture system be kept below the
lower flammability  limit.  The resulting fume streams,  since  they will
not support combustion unaided, are classified as "dilute."
     Fugitive  emissions  from  both  open and  closed  asphalt unloading
systems were monitored during the testing program.
4.3.2  Control Devices for Organic and Inorganic Particulates
     Several  types  of control  devices are used  in  this industry for
control  of pollutants.   The devices  include  high velocity air filters
(HVAF),  mist  eliminators,  afterburners,  electrostatic precipitators
(ESP),  scrubbers,  and fabric filters.  The devices  for which  emissions
data were available are discussed in detail  in the following paragraphs.
     4.3.2.1   High  Velocity Air  Filter  (HVAF).  HVAF's  are  used in asphalt
roofing  plants to  collect particulate  hydrocarbons  emitted  from the
saturator,  wet looper,  and  coater,  and are  sometimes  used to collect
particulate hydrocarbons emitted from the  coater-mixer  and  asphalt storage
tanks.   A typical  rotary  drum high  velocity  air filter installation is
shown  in  Figure 4-2.   Its basic  components  are a cooling  section,  a
motor-driven fan, a rotating drum filter section, and a mist eliminator.
      HVAF units  are filtration devices  and do not remove gas phase organic
compounds contained in  the exhausts  from saturators,  wet loopers, coaters,
and asphalt storage tanks.  Thus,  for effective capture of hydrocarbon
emissions, the gases entering the HVAF unit  must be cooled to about 32°
to 49°C (90° to 120°F).   The cooling may be accomplished by either  dilution
 air, water sprays,  or a shell  and tube heat exchanger.J
      Dilution air  cooling requires a larger  fan, fan motor, and a larger
 control  device to  handle the  increased air  volume.  Cooling  by  direct
 contact water spray is simple and requires less energy and smaller equip-
 ment.   It does produce an oil-water mixture which must be settled so that
 the oil  can be used for  fuel  or recycled to the oil  refinery and  the
 water can  be recycled  to the spray  cooler.   With a  shell  and tube  heat
 exchanger,  the  fan, fan  motor, and particle capture  device  would be
 smaller  than  that  required for air cooling,  and the oil-water separator
 would  not be required.   Condensed oil  could be  drained from  the cooler
 and  used directly  for  fuel  or for  recycle.   However, shell  and tube
                                    4-8
-------
Figure 4-2.   Typical rotary drum high velocity air filter installation.
                                   4-9
-------
capital costs would-be higher, and the shell side of the exchanger would
require solvent cleaning  several  times  a year.   The waste solvent would
create a waste disposal problem.   A fan would be required to overcome the
additional pressure drop.
      Preceding and  condensation minimizes the  amount of organic vapors
which would  otherwise pass  through the filter and condense  in the atmos-
phere  to  produce a  visible plume.    The  'quantity of gaseous organic
emissions  and the extent  of preceding needed to prevent  a  visible plume
are somewhat dependent upon the particular crude and the degree of refining
of the crude from which the asphalt is produced.   Data are not available
to define  the relative quantities of  organic emissions produced by different
crudes  or the  relationship between  the  temperature of the pollutant
stream and the physical state of the  various pollutants.
     As the exhaust gases pass through the HVAF  filter media, particulates
impact  on the glass  fibers  and are  separated  from  the  gas  stream.   The
filter  media is supported by a screen and a perforated  drum retainer,  as
shown  in  Figure 4-2.   The  filter media is a 2.54-cm (1-in.) thick fiber
glass  mat having a density  of  0.20  kg/m2 (0.66 oz/ft2).  The fibers  are
random  and have a diameter  of about  4 urn.7  High filter  face velocities
are necessary to attain high collection efficiency,  as shown in Figure  4-3.
Experience with systems  operating at asphalt  roofing plants has shown
that  the  system should be  designed  so  that the gases pass through  the
filter media at a face velocity  of  between  7.62 and 8.64 m/s (1,500 and
1,700  ft/min),  which produces a pressure drop of about 6,966 Pa (28 in.)
of water.8  The fan  horsepower required for a system capable of handling
18.9  m3/s (40,000  acfm) is  usually  in the range of 223,700 to  261,000  W
 (300  to 350  hp).9
      The  inorganic particulates and  the  more  viscous organic compounds
collect on the filter mat  and eventually begin to plug it.  The micron
 and submicron size liquid  particles  attach themselves  to the fibers of
the filter media and migrate to the  discharge side of the mat where they
 again enter the high velocity air stream as larger, liquid o'il  droplets.
 Periodically,  the filter media  is  advanced to expose a small  surface  of
 new material to the  exhaust flow.  Automatic advance of the filter  media
 may be  accomplished at  either  a predetermined time interval  or  at a
                                   4-10
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         VELOCITY-METERS PER SECOND
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Figure 4-3.   HVAF  filter media  filtration  efficiency  as  a function  of

       filter face velocity for different  filter media.1"
                                    4-11
-------
predetermined pressure  drop across the  filter  media.   With the time-
operated advance,  if  new material  is advanced while the process is shut
down, a  large filter  area may be "uncaked" and  the pressure drop will be
low, resulting  in decreased collection  efficiency.   Some  HVAF systems
incorporate a pressure-actuated advance  system  which  operates  by sensing
pressure at the  mat and advancing the filter  at a given rate  until a
preset lower pressure is reached at the mat.
     Large oil droplets  entering  the high velocity air stream from the
filter of  the  HVAF unit pass through a fan and are collected on a mesh-
type mist  eliminator  (see Figure 4-2).   The filter media  is  a 15.2-cm
(6-in.)  thick mat (packing) of stainless steel  fibers  retained between
stainless  steel  grids.   The face velocity of  the gas stream  is 1.8 to
2.4 m/s  (6 to 8  ft/s) and the pressure drop  is  gl.27  cm (0.5  in.).  When
the  pressure  drop increases to 2.54  cm  (1.0 in.),  cleaning of the mist
eliminator is  necessary.11   Cleaning of the mist eliminator  is usually
performed  annually although at a few installations it  may be  done every
         12
6  months.
     A  smaller  version  of the high  velocity air filter is  shown in
Figure 4-4.   This type  of  unit  is  typically installed  for application
where  the emissions  are intermittent,  where  the gas  flows  are  low
[0-2.36  m3/s  (0-5000  acfm)],  and  where capital  costs  might be minimized.
Emissions  from the coater-mixer contain  both organic  and inorganic parti-
culate  and would interfere with afterburner operation.  As  a result,
mini-HVAF'S are  sometimes used  to  control  emissions from the  coater-mixer
at asphalt roofing plants where an  afterburner is used  to  control  emissions
 from the  saturator and  coater.   The basic operation  and characteristics
 of the mini-HVAF are essentially the same as those detailed above  for  the
 HVAF unit, except that  the filter media is sandwiched  between  two quick-
 release flanges,  and periodically  it is changed manually.   The need for
 regular manual  filter changes is a disadvantage of the unit.
      Among the  advantages  of  HVAF units in the asphalt roofing industry
 are:  ease of  operation,  low maintenance, and no fuel  costs.  The major
 disadvantages are:   a lack of control  of gaseous  emissions,  the  large
 pressure  drops  required, and the disposal and  handling problems associated
 with the  used  mats.   The saturated  mats can become a  secondary emission
                                   4-12
-------
                                   OUTLET
  FILTER
CARTRIDGE
                                                          MIST ELIMINATOR
         QUICK RELEASE CLAMPS
                                                        MIST ELIMINATOR
                                                             DRAIN
                                                                 INDUCED
                                                                DRAFT FAN
                                                                   MOUNTING
                                                                     SKID
                   Figure 4-4.  Typical mini-HVAF.13
                                   4-13
-------
source unless proper  care  is taken to minimize outgassing.  Outgassing
can occur while the saturated mat is being accumulated on the HVAF takeup
reel  (windup  assembly),  during temporary storage, during transport for
disposal, or during disposal.
     4.3.2.2  Mist Eliminators.   Mist  eliminators are used  in  numerous
industrial  applications  to remove both liquid mists  and  soluble  solids
from  gas  streams.   Mist eliminators cann6t be subjected to  high concen-
trations  of inorganic particulate  matter because the collection media
soon  becomes plugged.   Thus,  where high concentrations of inorganic
particulate are  present  in the exhaust stream, a  cleanable or replaceable
type  prefilter is needed  to  remove the  bulk of the particulates.    In
asphalt  roofing  plants, mist  eliminators are  used to control  emissions
from  asphalt storage  tanks.
      A typical mist  eliminator  consists  of a packed fiber bed retained
 between  two  screens  as  shown in Figure  4-5.  The  screens  can  be con-
 centric  cylindrical  screens or parallel  flat screens.  Chemically resistant
 glass fibers, synthetic fibers,  stainless steel  fibers, and other fiber
 materials  can be  used as  packing, depending upon the composition of the
 effluent stream.  Gases containing mist  particles flow into the fiber bed
 where the mist particles  are  collected on the fibers by inertia! impaction,
 direct interception, and  Brownian movement.  The collected  liquid particles
 coalesce  into  liquid films which  are moved through  the.fiber  bed by the
 drag  of  the gases.   The collected  liquid drains  by gravity  off the down-
 stream  face of the  fiber bed to a separate storage vessel  (as shown in
 Figure 4-6).
       The oil collected by a mist eliminator can be disposed of in a
 number  of  ways.   Some plants use it as fuel  for their boilers  while
 others  recycle the  oil  back to the saturator  or  the storage tanks.
       The  effectiveness of mist eliminators depends on particle size,
  particulate loading, liquid viscosity,  fiber dimensions, bed density,  and
  gas  velocity through the  bed.  Particle size is  one of the most important
  considerations involved  in  the design  and construction of mist elimina-
  tors.  A  wide  range of  particle sizes may be handled.  Larger particles
  may  be  collected  by a  cyclone or  mesh  pad.  The mist  eliminator can then
  be designed to remove the smaller particles with high efficiency.  A wide

                                    4-14
-------
      WIRES
                                        SEPARATED
                                         MLST TO
                                    '0 COLLECTION
                                          POINT
Figure 4-5.   Schematic of retaining screens and fiber packing
              of a mist eliminator.11*
                            4-15
-------
                                                CLEAN GAS TO
                                                ATMOSPHERE
   MIST-L^DEN
   GAS IN
                    COLLECTED.
                         LIQUID
Figure  4-6.
Typical  mist eliminator element to control emissions
   from  asphalt storage tank.11*
                              4-16
-------
 range of pollutants, particulate loading, and gas volumes can be handled
 with high efficiency by mist eliminators.  This device can handle a wide
 range of viscosities (up to 5,000 cp) as long as the collected particles
 can  be made  to  drain from the bed.
      Among  the  advantages of the mist eliminator are a moderate pressure
 drop (less  than half that of the HVAF), a relatively infrequent cleaning
 cycle,  and  no  fuel  costs.   The disadvantages include  an  inability to
 control  gases  and odors and  the  secondary  pollution impact of the pre-
 filter cleaning or disposal process.
      4.3.2.3 Afterburners.   An afterburner, as  discussed  in this document,
 means  any exhaust gas incinerator used  to control emissions of participate
 matter.  Afterburners are typically used to control combustible pollutants
 present  in   concentrations  too  dilute  to support combustion unaided.
 Afterburners are  used in asphalt  roofing manufacturing plants  to  control
 emissions of gaseous hydrocarbons  and organic  particulates  from the
 saturator, wet  looper, coater, asphalt  storage tanks, and asphalt blowing
 stills.  For asphalt blowing  stills, only afterburners or some other type
 of combustion device are known to be  used  as  the final  control device.
     Afterburners are classified  as  either thermal  (i.e., direct flame)
 or catalytic.   The  primary  advantage of catalytic  afterburners is  that
 they  use much  less  supplemental fuel than  an  equivalent thermal  after-
 burner.  Catalytic afterburners  are  not used or recommended for control
 of hydrocarbon emissions from asphalt roofing plants because the catalyst
 is subject to  rapid  poisoning and plugging due  to  constituents of the
 fumes from asphalt processes.
     Thermal afterburners destroy combustible pollutants through oxidation
 to C02 and  water.   Temperatures  of 650° to  760°C  (1200°  to 1400°F),
maintained for  0.1 to 0.3 seconds of  fume residence time,  are sufficient
 to obtain  nearly complete oxidation  of most  combustible pollutants.15
Destruction  of  most  hydrocarbons occurs  rapidly at  593° to 649°C
 (1100° to 1200°F), but  destruction  of  some organic  compounds,  such as
methane, and the  oxidation  of CO to C02 requires longer residence times
and higher temperatures.   Temperatures of 760° to 816°C (1400° to 1500°F)
may  be required if  the  methane content  of the  hydrocarbon  is over
 1000 ppm.     Large  droplets  (50 to 100 urn)  require  longer residence
                                   4-17
-------
times at the  above temperatures;  however, these large droplets are also
easily removed in simple cyclones and knockout vessels.
     The steps involved in dilute fume incineration are shown schematically
in Figure 4-7.   As shown  in  the figure, part  of the fume  stream  is  some-
times bypassed around the  fuel  combustion process to  preclude flame
quenching  and combustion  instability.  In the  case of  exhaust streams
containing  emissions from asphalt  blowing,   it is common to use only
outside air in the combustion of fuel, since  burner fouling is a problem.
For other asphalt  roofing processes,  burner fouling seems to be less of a
problem, and  the fume stream is often used as a major source of combustion
air.  The  fume not  used for combustion must  then be  mixed with  the hot
combustion  products  to  give a uniform temperature to all fume flowing
through the afterburner.  This mixing should  be done as rapidly as possible
without causing  flame quenching so that  sufficient residence time can be
provided at the  required temperature.  Temperature and residence time are
somewhat  interchangeable;  a higher temperature allows  use of a shorter
residence  time and vice versa.   This is  illustrated  in  Figure 4-8, which
indicates  that,  for a  0.1-second  residence  time, the  efficiency of
pollutant  oxidation varies  from 90  percent  at 666°C (1231°F) to  100
percent at 725°C (1337°F).   For a  1.0-second  residence  time,  the  efficiency
varies from 90 percent  at 623°C  (1153°F)  to 100 percent  at 666°C  (1231°F).
      The  typical effect of operating temperature on  the effectiveness of
thermal  afterburner destruction of  hydrocarbons  is shown in Figure 4-9.
The  figure shows  that  the  efficiency of hydrocarbon destruction varies
from about 90 percent to  almost  100 percent  over a temperature  range of
about 677° to 760°C (1250°  to  1400°F).   For a given level of pollutant
destruction  for  different afterburner designs,  the  major factor that
influences the residence time  required  at a  given operating temperature
 [above  about 538°C  (1000°F)] is the  effectiveness with which the fume is
mixed with the  combustion  products.   If hydrocarbons are present in the
 exhaust gas  of any  afterburner operating at  a  nominal combustion chamber
 temperature  above 760°C  (1400°F)  [or above 649°C (1200°F) for all but a
 few hydrocarbons],  it  is  due  to poor mixing and nonuniform treatment of
 the fume stream  or too short residence time of the  fume at temperature.
                                   4-18
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 Figure  4-9.  Typical effect of operating temperature on effectiveness  of
thermal  afterburner for destruction of hydrocarbons  and carbon monoxide.15
                                      4-21
-------
Typically, afterburners are  designed with average residence times which
vary from  0.1  to 0.5 seconds, but the amount of  time required to  raise
the cold  fume  up to the desired  temperature often exceeds  this  average
residence time.  Also, not all portions of the fume are in the combustion
chamber an equal amount of time;  some portions are swept out very quickly
while  others are retained for  an appreciable  time.   The variation  in
residence  time,  which is a  function of  flow patterns  in  the combustion
chamber,  can appreciably affect  afterburner performance,   in  practice,
operating personnel  compensate for  deficiencies  in design  by  increasing
the  operating temperature of the thermal afterburners  during the startup
phase  until  a  temperature  is reached which  produces the desired  pollutant
destruction.
      Little maintenance is  required on  most thermal  afterburners.  The
main operating problems involve  safety  controls, erosion or cracking of
 refractory linings,  heat  exchanger fouling, or  mechanical  failure  and
 bearing failure in the fans.
      The major distinguishing feature of thermal  afterburners, as compared
 to noncombustion control techniques for hydrocarbons,  is the use of fuel.
 Because exhaust gases from the afterburner are typically at 649° to 816°C
 (1200° to  1500°F),  many asphalt roofing plants  use heat exchangers to
 recover  the waste  heat.   This recovered waste heat may be used for many
 of the plant processes.
      Thermal  afterburners,  like  all  combustion sources, have the potential
 for generating  secondary pollutants due to oxidation of nitrogen, sulfur,
 and metals  in the fume  or fuel.  Thermal afterburners, in  comparison with
 power plant  boilers  and  industrial furnaces,  should have  lower NQX
 emissions because of their  lower operating temperatures.   The low operating
 temperatures  and dilution  of  combustion products by  excess air and fume
 results  i n a NO  eff1uent  concentrati on of 5  to 15 ppm  when control1i ng
 saturator emissions.16   Emissions of  SO,,  depend on the  sulfur  content of
 the fuel burned and on the sulfur  content of the fume because almost 100
 percent of this sulfur will be converted to S02.
       4.3.2.4  Electrostatic Precipitators  (ESP).  Low voltage electrostatic
  precipitators  (ESP)  can  be used  to control  inorganic and hydrocarbon
  particulate  mass  emissions from  asphalt  saturators, wet  loopers,  and

                                     4-22
-------
 coaters.   Initial  applications  of  ESP  for  control  of  emissions  from  these
 sources  resulted in high maintenance costs due to the design of the  ESP.
 Common  problems included  the  need for frequent shutdown to  clean the
 sticky  asphalt  from the  ESP components,  failure of  power  packs  which
 cause  shutdown  of  entire ESP  units,  and  ionizer wire breakage.1   To
 overcome  these problems,  one manufacturer  introduced a modular electro-
 static .precipitator.   The modular electrostatic precipitator concept  is
 illustrated  in Figures 4-10 and 4-11.   The  basic  building  block  of  the
 modular  ESP  incorporates  a prefilter,  ionizer,  collecting  cell,  after-
 filter,  and  a  solid-state power pack in  a self-contained  unit.   The
 collecting components  slide out for  easy cleaning.  The contaminated air
 stream first passes through the mechanical  prefilter, which consists of a
 fiber glass  mat or a continuous self-cleaning  metallic filter,  to remove
 the  larger participates.   A single large prefilter is generally used in
 the  roofing  industry  rather than the modular type shown in Figures 4-10
 and 4-11.  The contaminated stream next passes through an ionizer section
 where it  is  subjected  to an intense electrostatic field (12,000 volts)
 resulting in an  electrical charge being imparted to the particles.   The
 ionized particles  are  then collected on oppositely charged  plates in the
 collecting cell.   The  function  of the afterfilter is  to  aid in air
 distribution and to prevent reentrainment  of  any  particulate draining
 off the collecting cells.   The liquids  collected on the plates and after-
 filter are drained  to  a sump and recovered.  In this  design each  module
 has its own  power  supply;  therefore, a power  pack  failure  will affect
only one module.   Modules  can  be removed  individually for  cleaning  or
 servicing without  shutting  down the  ESP.   Because the individual  module
components can be  submerged in  a detergent or solvent bath  for washing,
the potential  exists  for  more  effective   cleaning; thus,  the design
efficiency can  be maintained.
     The variables  which  affect the collection  efficiency  of the low
voltage ESP are particle size,  particle resistivity,  area  of the collecting
electrodes,  gas temperature, and gas  velocity.20
     The larger particles  are easier  to collect.   High resistivity particles
can form an  insulating layer on the surface of the collecting electrode.
If this happens, the particles  will  leave  the  electrode and reenter  the
                                  4-23
-------
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-------
         DETAIL OF TYPICAL MODULE
                                       AFTER-FILTER
                         COLLECTING
                         COMPONENTS
CLEANED EXHAUST

      I
BYPASS STACK
 FIRE DAMPER
                                                               EXHAUST'FAN
                  VOLUME CONTROL
                     DAMPER
              MODULE (ONE-STAGE ESP)


           TWO-PASS'MODULAR
            ELECTROSTATIC
            PRECIPITATOR
                                              PREFILTEM
                 FUME-LADEH AIR
      Figure 4-11.   Modular  electrostatic precipitator.
                                                                   18.19
                                   4-25
-------
gas stream.   The area  of  the collecting  electrodes  is used  in  the
calculations to  determine  the  size and to predict the efficiency  of the
ESP. .In organic liquid particulate, the fume temperature determines the
percentage of the fume present as a particulate to be collected.   The  gas
flow is critical;  if the gas velocity exceeds the design gas  velocity,
some particles  could be reintroduced in the gas stream.  The effects  of
these  variables are  discussed in  detail  'in the references.        One
advantage of the modular ESP is that, to some extent, the above variables
can be compensated for by adding more modules in series or in parallel.
For example,  the modular ESP shown  in  Figure  4-11  is a two-pass  system
since  the  gas must pass through two modules in series.  Each module,  in
turn,  is  a  two-stage precipitator  because  the  fumes are ionized  and
collected  sequentially (these operations  are performed simultaneously in
a  single-stage  precipitator).18  Three-pass  systems are  sometimes used to
control emissions  from sources in  the asphalt  roofing industry.
     In order to increase the efficiency  of the ESP, precooling  of the
gas is recommended.   Precooling can be accomplished  by the  use of  dilu-
tion  air,  a prechamber using water sprays, or  a shell and tube heat
exchanger.   The advantages and  disadvantages  of  these three methods  are
discussed in detail in Section 4.3.2.1.
     Advantages of the ESP  are  its low power  consumption and  low system
pressure  drop.   Power requirements of  the ESP  are about 100 W  maximum per
 0.472  m3/s  (1,000  acf/min)  of  exhaust flow at a pressure drop of 50 to
 150 Pa (0.2  in to 0.6 in.)  of water.18  A typical  modular  ESP installed
 at an  asphalt  roofing plant  requires 22.4 kW (30 fan  hp)  to provide
       ?^
 draft/"5
      Disadvantages of the modular  ESP include lack of control of gaseous
 emissions; the problems associated with the handling and cleaning  of the
 collecting components, disposal  of the single-use prefilter, and cleaning
 of the reusable filter now in use at some installations.  According to an
 industry source, a major disadvantage in the use of  an ESP control  system
 is the lack of expertise by plant engineering and maintenance personnel
 for installation and maintenance of the units.
                                    4-26
-------
       4-3-2-5  Fabric Filters.   The  handling  of sand,  talc,  mineral
  stabilizer (filler), granules,  and mica causes emissions  of  inorganic
  particulates during  receiving,  storage,  transfer,  and  application
.  operations.   Emissions  from those  operations  involving  granules may be
  minimized  by purchase of granules  which have  been washed and oiled (or
  dyed).   Emissions  involving  the  other materials  are  controlled by transfer
  within  closed systems,  capture  of  emissions at  the area of application
  (via  hoods or enclosures),  and  the venting of these emissions to fabric
  filter  collectors.
      Although tests  of  baghouses collecting these  emissions  at  asphalt
  roofing plants  were not performed, it  is well  documented  that  fabric
  filters  used  in other operations collecting dust from like materials have
  collection efficiencies in excess of  99 percent.25  Outlet grain loadings,
  recorded  during emission tests  at  several  crushed stone  facilities
  processing  and  handling a  variety of  types  of rock seldom exceeded
  2.28x10"  kg/m  (0.01 gr/DSCF),  and visible  emissions  from the baghouse
  stack were consistently zero.26
      There  are  three basic  designs  used  in fabric filter baghouse
  construction:  the open  pressure,  the closed pressure,  and the  closed
  suction baghouse.   The fans  for both the open and closed pressure bag-
 houses are  located on the dirty  gas side of the  system.  The fan for the
 closed suction baghouse is located  on the discharge or clean side of the
 baghouse.  There are  two  major bag shapes,  the  envelope and the tube,  and
 they are constructed of woven  cloth or  felted  cloth.   Several  materials
 are used:  wool,  cotton,  synthetics, and fiber  glass.
      There are several methods  of  cleaning filter  cloths in a  baghouse.
 Fabric flexing and reverse air  flow through  the  bag are  the two  general
 methods  of  bag  cleaning.  Manual shaking,  mechanical shaking, and  air
 shaking  are the three methods considered as fabric flexing.  Air shaking
 can be accomplished four ways:   air bubbling,  jet pulsing, reverse air
 flexing, and sonic vibration.  Reverse  air flow is divided  into three
 methods:   repressuring cleaning, atmospheric cleaning, and reverse  jet
 cleaning.   Typical air to cloth  ratios  in conventional  baghouses vary
 from 0.5 to 1.0  m3/s/m2 (1.0  to  2.0  ft3/min/ft2)  for fumes.   -~
                                  4-27
-------
4.4  PERFORMANCE OF EMISSION CONTROL SYSTEMS
     Data from tests performed  by  local  agencies or plant owners cannot,
in general, be correlated with the data from EPA test methods for asphalt
roofing plants.   Also,  process  data, test methods, and  sample analysis
methods are not generally described  in local agency or plant owner reports.
However,  in this  section,  discussion concerning performance  of  control
systems is  based  on those  tests performed as  a part of this  study  and  on
tests conducted by  an industry  source using EPA Test Method 26.
     Tables 4-4,  4-5,  4-6,  and 4-7  present a summary  of emission data
obtained  during this study by measurement of  emissions at asphalt  roofing
plants  using  various control systems.  Analysis of the data in Tables  4-4,
4-5,  and  4-6  shows that the average particulate inlet loadings  for the
saturators  at plants  A,  B, C,  and D were 0.238, 0.327,  1.57,  and
0.16  kg/Mg  of shingle  (0.475, 0.653, 3.143 and 0.32 Ib/ton)  respectively,
while the average  production rates  were 27.8, 37.0, 19.1,  and 43.3  Mg/h
 (30.7,  40.8,   21.0, and 47.7 tons/h) respectively.  Plant A  has  a dip
 saturator which is enclosed along with  the wet looper  and  coater in  a
 boxlike structure  with removable doors.  Emissions are ducted  to two
 electrostatic precipitators for  control.   Plant B has  a dip  saturator
 which,  along with  the  wet  looper and coater,  is  surrounded  by  a  large
 enclosure with sliding doors.   One surge tank and six  asphalt  storage
 tanks are vented to  one  afterburner with part of the  emissions  from the
 above enclosure; another afterburner  controls the rest  of  the emissions
 from the  saturator,  wet looper,  and coater.   Plant C has  a spray-dip
 saturator enclosed along with  the wet  looper  and coater; the enclosure
 has vertical  sliding doors.  The  emissions from this enclosure are ducted
 to a HVAF for  control.   Plant D  has a dip  saturator and wet  looper
 enclosed by  a hood with an opening extending to  about  6 feet above the
 floor.   The  emissions from the coater  are  ducted to  another HVAF  for
 control  and  were not sampled.   Plants  A,  C,  and  D would be  expected  to
 generate similar quantities  of pollutants; Plant B might be expected to
 have higher  emissions  since the surge tank and storage  tank emissions are
 ducted together with the asphalt  line emissions.
      No  mini-HVAF  units  were tested.   However, comparable  efficiencies
 should be  achievable with the  mini-HVAF under similar operating procedures.
                                    4-28
-------
    or 4~4- EPA TEST DATA AT ASPHALT ROOFING PLANT A (METRIC)
SOURCE:   SATURATOR; CONTROL:  ELECTROSTATIC PRECIPITATOR (ESP)
Measurement parameter
Parti cul ate
g/Nm3
« / ^
g/nr
I /i
kg/h
kg/Mg shingle
kg/Mg felt
Gaseous hydrocarbon
g/Nm3
kg/h
kg/Mg shingle
kg/Mg felt
Combined parti cul ate and
hydrocarbon (HC)
g/Nm3
1 /L.
kg/h
kg/Mg shingle
kg/Mg felt
Polycyclic orqanic matter (POM)
g/Nm3
kg/h
Control eff. %— parti cul ate
HC
Combined parti cul ate + HC
POM
Volume flow rates:
NrnVs
O i
m3/s
Fume temp.--°C
Control device temp. — °C
Line speed parti cul ate runs— m/s
Felt width— cm
Shingle production rate— Mg/h
Felt usage rate— Mg/h
Inlet Outlet 1

0.1494 0.0117
0.1300 0.0101
6.7585 0.2585
0.2380 0.0190
2.0270 0.1580

0.0279 0.0304
1.2383 0.6713
0.0450 0.0480
0.3800 0.4100


0.1785 0.0412
7.8562 0.9299
0.2800 0.0670
2.40 0.5700

13.0700
5.8513
92.20
Neg.
76.30


12.33 6.12
14.14 7.14
52 58
52
1.77
91.44
27.85
3.27
1 Outlet 2

0.0089
0.0076
0.1814
0.0130
- o.mo

0.0332
0.6849
0.0490
0.4200


0.0421
0.8663
0.0620
0.5300

::
94.50
Neg.
77.90


5.72
6.64
57





Total outlet

0.0103
0.0089
0.4399
0.0160
0.1350

0.0318
1 . 3562
0.0485
0.4150


0.0416
1.7962
0.0645
0.5500

6.3600
2.6853
93.35
Neg.
77.10
54.10

1 1 . 84
13.78
58 (Avg.)





                           4-29
-------
TABLE 4-4a.  EPA TEST DATA AT ASPHALT ROOFING PLANT A (ENGLISH)
                     SOURCE:  SATURATOR
         CONTROL:  ELECTROSTATIC PRECIPITATOR (ESP)
Measurement parameter Inlet
Particulate
gr/DSCF 0.0653
gr/acf 0.0568
lb/h 14.5900
Ib/ton shingle 0.4750
Ib/ton felt 4.0530
Gaseous' hydrocarbon
gr/DSCF 0.0122
lb/h 2.7300
Ib/ton shingle 0.0890
Ib/ton felt 0.7580
Combined parti cul ate and
hydrocarbon (HC)
gr/DSCF 0.0780
lb/h 17.3200
Ib/ton shingle 0.5640
Ib/ton felt 4.8110
Polycyclic organic matter (POM)
gr/DSCFxlO-6 5.71
Ib/hxlO-3 12.90
Control eff. %-- particulate
HC
Combined particulate + HC
POM
Volume flow rates DSCFM 26,131
acfm 29,959
Fume temp. — °F 126
Control device temp.— °F
Line speed particulate runs — ft/mi n
Felt width-- in.
Shingle production rate— tons/h
Felt usage rate— tons/h
Outlet 1

0.0051
0.0044
0.5700
0.0370
0.3160

0.0133
1 . 4800
0.0960
0.8220


0.0180
2.0500
0.1340
1.1380

—

92.20
Neg.
76.30
— —
12,975
15,120
136
126
348
36

3.60
Outlet 2 Total outlet

0.0039
0.0033
0.4000
0.0260
0.2220

0.0145
1.5100
0.0980
0.8380


0.0184
1.9100
0.1240
1.0620

—

94.50
Neg.
77.90
— —
12,114
14,074
135



30.70


0.0045
0.0039
0.9700
0.0320
0.2690

0.0139
2.9900
0.0970
0.8310


0.0182
3.9600
0.1290
1.1000

2.78
5f\ O
.92
93.35
Neg.
77.10
r* A "i f\
54. 10
25,089
29,194
136





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-------
     TABLE 4-6.  EPA TEST DATA AT ASPHALT ROOFING PLANTS C AND D (METRIC)
             SOURCE:  PLANT C - SATURATOR AND STORAGE TANKS
                           PLANT D - SATURATOR
                   CONTROL:  HIGH VELOCITY AIR FILTER
Measurement parameter
                                         Plant C
  Inlet
                                                Outlet
                         Plant  D
  Inlet
  Outlet
Parti cul ate
     9/m3
     kg/h
     kg/Mg  shingle
     kg/Mg  felt

Gaseous hydrocarbon
 0.9565
 0.8146
29.94
 1.5700
                                               0.0160
                                               0.0137
                                               0.50
                                               0.0270
                                                         0.1442    0.0297
 6.93
 0.1600
 1.2500
  1.53
  0.0350
  0.2800
     kg/h
     kg/Mg shingle
     kg/Mg felt

Combined parti cul ate and
  hydrocarbon (HC)

     9/Nrn3
     kg/h
     kg/Mg shingle
     kg/Mg felt

Polycyclic organic matter (POM)

     g/NmsxlO-3
     kg/hxlO-3

Sulfur dioxide (SO?)

     g/Nmsx!0-3
     kg/h

Control Eff.  %~particulate
                HC
Combined particulate + HC
                       POM
Volume flow rates:
     Nm3/s
     ms/s
 0.0778
 2.42
 0.1300
 1.0343
32.36
 1.7000
 1.226
40.05
                                               0.0915
                                               3.02
                                               0.1600
 8.71
10.21
                                               0.1075
                                               3.52
                                               0.1800
                                               0.103
                                               3.58
                                              14.370
                                              0.485

                                              98.30
                                              Meg.
                                              89.10
                                              80.40

                                              9.29
                                              10.66
           2.05
           0.047
           0.370
           3.57
           0.087
           0.640
13.27
77.90
   a .
60.70C


13.89
                                 4-35
-------
    TABLE 4-6   EPA TEST DATA AT ASPHALT  ROOFING  PLANTS C AND D  (METRIC)
            SOURCE:  PLANT C -  SATURATOR  AND STORAGE TANKS
                             PLANT  D  -  SATURATOR
                   CONTROL:  HIGH VELOCITY AIR  FILTER
                              (concluded)
Measurement parameter
Fume temp.— °C
Control device temp.— °C
Line speed parti cul ate runs— m/s
Felt width— cm
Shingle production rate— Mg/h
Felt usage rate— Mg/h
Plant C
Inlet Outlet
61 52
43
1.16
91.44
19.05
Plant D
Inlet Outlet
69 74
69
2.00
121.90
43.27
5.53
aSince gaseous HC was not measured at the control device inlet  its ability
 to control gaseous HC could not be estimated.  Overall control efficiency
 was estimated using the assumption that gaseous HC would neither increase
 nor decrease across the control device.
                                   4-36
-------
      TABLE 4-6a.   EPA TEST DATA AT ASPHALT ROOFING PLANTS C AND D (ENGLISH)
              SOURCE:   PLANT C - SATURATOR AND STORAGE TANKS
                               PLANT D - SATURATOR
                    CONTROL:   HIGH VELOCITY AIR FILTER
 Measurement parameter
                                          Plant C
                         Plant D
  Inlet
 Outlet   Inlet
                                                                    Outlet
 Particulate
      gr/DSCF
      gr/acf
      Ib/h
      Ib/ton shingle
      Ib/ton felt

 Gaseous  hydrocarbon

     gr/DSCF
     Ib/h
     Ib/ton shingle
     Ib/ton felt

 Combined particulate and
  hydrocarbon (HC)

     gr/DSCF
     Ib/h
     Ib/ton  shingle
     Ib/ton  felt

 Polycyclic  organic matter (POM)

     gr/DSCFx 10-6
     Ib/hxlO-3

Sulfur dioxide (SO?)

     gr/DSCFxlO-3
     Ib/h

Control eff. %--particulate
                HC
Combined particulate + HC
                 POM
Volume flow rates
     DSCFM
     acfm
   0.418
   0.356
  66.000
   3.143
   0.034
   5.340
   0.254
   0.452
  71.340
   3.397
 536.00
.  88.30
0.007
0.006
1.110
0.053
—
0.063
—
15.270
0.320
2.503
0.013
—
3.370
0.071
0.552
  0.040
  6.650
  0.317
 18,462
 21,636
 0.047
 7.760
 0.370
44. 90
 7.89
 6.28
 1.07

98.30
 Neg
89.10
80.40


19,681
22,596
           4.510
           0.095
           0.739
           7.880
           0.165
           1.292
                               77.90
                                 a  .
                               60.70C
28,118    29,437
                                 4-37
-------
  TABLE 4-6a.  EPA TEST DATA AT ASPHALT ROOFING PLANTS C AND D (ENGLISH)
            SOURCE:  PLANT C - SATURATOR AND STORAGE TANKS
                        PLANT D - SATURATOR
                  CONTROL:  HIGH VELOCITY AIR FILTER
                             (concluded)
Plant C
Measurement parameter Inlet
Fume temp.~°C 142
Control device temp. — °F
Line speed parti cul ate runs — ft/mi n
Felt width—in.
Shingle production rate— -tons/h
Felt usage rate— tons/h
Outlet
126
109
251
36
21.00
Plant D
Inlet
156
•156
395
/I O
4o
47
6
Outlet
166



.70
.10
aSince gaseous HC was not measured at the control  device inlet, its ability
 to control  gaseous HC could not be estimated.   Overall control efficiency
 was estimated using the assumption that gaseous HC would neither increase
 nor decrease across the control device.
                                  4-38
-------
TABLE 4-7.  EPA TEST DATA AT ASPHALT ROOFING PLANT
                  SOURCE:  BLOWING STILLS
                   CONTROL:   AFTERBURNER
E (METRIC)
Measurement parameter
Participate
g/Nm3
g/m3
kg/h
kg/Mg asphalt
Gaseous hydrocarbon
g/Nm3
kg/h
kg/Mg asphalt
Combined parti cul ate and
hydrocarbon (HC)
g/Nm3
kg/h
kg/Mg asphalt
Polycyclic organic matter (POM)
g/NmsxlO-3
kg/h
Aldehydes
g/Nm3
kg/h
Control eff. %— particulate
HC
Combined particulate + HC
POM
Aldehydes + HC
Volume flow rates:
NrnVs
m3/s
Fume temp. — °C
Saturant
Inlet
27.87
10.47
80.01
3.30
5.180
16.03
0.662

33.071
96.04
3.962

—
—
0.90
2.31
199
asphalt
Outlet
0.364
0.185
5.58
0.230
0.021
0.29
0.012

0.385
5.87
0.242

—
93.40
98.30
94.20
4.21
8.15
199
Coating
Inlet
33.41
13.52
98.61
12.21
4.391
14.03
1.740

37.80
112.64
13.95
113.75
396.68

1.041
0.35
—
0.91
2.28
216
asphalt
Outlet
0.210
0.117
3.27
0.405
0.043
0.68
0.085

0.253
3.95
0.490
0.075
1.16

0.009
0.01
96.70
95.20
96.50
99.90
99.10
4.29
8.10
196
Combustion temp.—°C
                                  816
  816
                          4-39
-------
TABLE 4-7a.
EPA TEST DATA AT ASPHALT ROOFING PLANT E (ENGLISH)
     SOURCE:  BLOWING STILLS
      CONTROL:  'AFTERBURNER

Measurement parameter
Parti cul ate
gr/dscf
gr/acf
Ib/h
Ib/ton asphalt
Gaseous hydrocarbon
gr/dscf
Ib/h
Ib/ton asphalt
Combined parti cul ate and
hydrocarbon (HC)
gr/dscf
Ib/h
Ib/ton asphalt
Polycyclic organic matter (POM)
gr/dscf xlO-6
Ib/hxlO-3
Al dehydes
gr/dscf
Ib/h
Control eff. %— parti cul ate
HC
Combined parti cul ate + HC
POM

Aldehydes + HC
Volume flow rates:
DSCFM
acfm
Fume temp.~°F
Combustion temp.— °F
Saturant
Inlet

12.180
4.577
176.400
6.607

2.264
35.330
1.323


14.454
211.730
7.930

—

—
—
—


~
1,916
4,904
390
asphalt
Outlet

0.159
0.081
12.300
0.461

0.009
0.650
0.024


0.168
12.950
0.485

—

—
93.40
98.30
94.20



8,928
17,265
390
1500
Coati ncL
Inlet

14.600
5.907
217.400
24.427

1.919
30.940
3.476


16.519
248. 340
27.903

49,708
815

0.455
0.780
—
__



1,937
4,826
420
asphalt
Outlet

0.096
0.051
7.200
0.809

0.019
1.510
0.170


0.115
8.710
0.979

32.76
2.55

0.004
0.024
96.70
95.20
96.50
99.50
99 10


9,089
17,169
385
1500
                            4-40
-------
      Four emission tests were conducted at plant A on the ESP controlling
 emissions from  the saturator  and coater.  The  results are depicted
 graphically in Figure 4-12.   During  the first emission test, a visible
 plume was observed from the outlet stacks of the ESP.  This plume varied
 in opacity  from  5 to  15  percent.   After the first  emission test  was
 completed,  the ESP was cleaned and minor maintenance performed.   A  visible
 plume was  not observed during  the last  three  emission tests.  The
 collection  efficiency for the  first  test was  88.3  percent.   The  average
 collection  efficiency for  the  last three tests was  95.7 percent.
      At Plant B  the  emissions  from  the  two afterburners  controlling
 emissions  from the saturator  and  coater were  measured.  The results of
 the  tests are displayed for each  afterburner  and for both afterburners
 combined  in Figure 4-12.  The afterburners  were operated at different
 temperatures.  The afterburner operating at  538°C (1000°F)  had an average
 collection  efficiency of 77.7 percent,  and  the afterburner  operating at
 649°C (1200°F) had an average  efficiency of 95.2 percent.   The  emissions
 from  the afterburner operating  at 538°C  (1000°F)  were:    1.04 kg/h
 (2.3  Ib/h),  1.32  kg/h  (2.9 Ib/h),  and  1.36 kg/h (3.0  Ib/h),  for an average
 of 1.22 kg/h (2.7  Ib/h).  The  emissions  from the afterburner operating  at
 649°C (1200°F) were:    0.36 kg/h  (0.8 Ib/h), 0.41  kg/h (0.9 Ib/h),  and
 0.68  kg/h (1.5 Ib/h), for an average of  0.5  kg/h (1.1  Ib/h).
      Discussion  on the performance of capture and  control  options  are
 contained in the following paragraphs.
 4-4.1 Performance of Capture Systems
      The performance  of capture systems varies greatly depending on  the
 construction and operation of the system.  Canopy enclosures used for the
 saturator, wet looper,  and coater  generally  achieve  poor capture whereas
 the total-enclosure hoods achieve very good  emission capture when properly
 operated.   Closed systems can provide very good capture of emissions from
mineral products  handling  and  storage and from asphalt truck unloading.
     4.4.1.1   Capture  Systems  for Collecting Fumes  from the Saturator.
Wet Looper,  and Coater.  Data  in Table 4-8 show that emissions  from the
hooded enclosures  were  generally  visible almost 100 percent of  the  time
and ranged up to 20 percent opacity.  Fugitive  emissions from the
                                  4-41
-------


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Avg. shinglt
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-(.10)
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 production rate.


         Figure 4-12.  Particulate emissions from asphalt roofing  43
       processes when various control devices are used  (EPA tests).

                                    4-42
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saturator, wet looper,  and  coater enclosures  at plants tested  are
summarized in  Table 4-8,  and detailed data are reported in Appendix C.
Fugitive  emissions  from the canopy hood capture  system were  generally
less than 20 percent opacity while those from the enclosures were generally
less than 10 percent opacity.   At plants tested, the flow rates used for
ventilation varied  from about 7.08 Nm3/s  [15,000  dry  standard  cubic  feet
per minute  (DSCFM)]  for a full enclosure  to  about 14.16 Nm /s (30,000
DSCFM) for a hood.  Since the  7.08 Nm3/s (15,000  DSCFM) was measured with
one door of the enclosure open (see Figure 4-1),  it is  probable that all
emissions from the saturator,  wet  looper,  and coater  can be captured with
exhaust  ventilation rates of 4.7 Nm3/s  (10,000  DSCFM).
     Fugitive  emissions from the three total-enclosure hoods  varied from
0  to 10 percent opacity.   For the best  hood observed, there were  no
visible  emissions when all  but one  of the  hood doors were  closed.
Emissions were  light  but constant when  more than one door was  open.
     4.4.1.2  Capture  Systems for  Other  Emission Sources.  As discussed
in Section 4.3.1, the systems used for the  capture  of emissions from
asphalt blowing  stills,  asphalt  storage  and transfer  systems, and  the
coater-mixer are primarily closed  systems.  Similarly,  closed  systems can
be used to capture emissions  from mineral products delivery,  storage and
transfer, and asphalt truck unloading.   If properly installed  and maintained,
 closed  systems provide 100  percent capture of all potential  emissions.
 Visible emissions were tested at  one asphalt roofing plant while asphalt
 was being  unloaded.   The results  of  the emission testing showed that the
 capture  system for asphalt unloading was performing  effectively and
 visible emissions were not  observed.
      Tests were  not  performed on systems designed to  capture emissions
 from mineral  surfacing and  granule application areas.  The development by
 the industry  of capture systems  for  inorganic particulate  has received
 less attention than those for asphalt  fume.  None of the systems currently
 in  use  appear to perform adequately.   However, the mineral  surfacing and
 granule application  areas  are located inside  the plant building and do
 not appear  to discharge any material to the  atmosphere. ,
                                    4-44
-------
4.4.2   Performance of High Velocity Air  Filter  (HVAF) Systems
     Two  HVAF units were  tested. The  HVAF at  Facility C  controlled
emissions  from a "spray and  dip" type saturator, coater, wet looper,  and
storage  tanks for an  asphalt roofing  plant operating  at  an  average
production rate  of 19.1 Mg/h  (21  tons/h) of  shingles.  The  control system
incorporated water sprays to  precool  the inlet gases to  the HVAF to about
49°C (120°F)  and an  automated system, based on  pressure  drop,  to  advance
the filter mat.  This system  operated with an average particulate removal
efficiency of  98.3 percent based  on an average inlet loading of
29.95 kg/h (66.0 Ib/h)  and  an outlet loading of 0.50 kg/h  (1.11  Ib/h).
Controlled emissions averaged 0.026  kg/Mg  (0.053 Ib/ton) of product, as
shown for  Plant  C in Figure  4-12.  Visible  emissions from  the stack  of
the control  device varied  from   0 to 5  percent opacity, as shown in
Table 4-9.
     The second-  HVAF unit controlled  emissions  from a dip saturator   for
an asphalt  roofing plant operating   at an  average production  rate of
43.3 Mg/h (47.7  tons/h) of shingles  (Plant D).   No precooling was used,
and the average temperature of the inlet gases to the HVAF was about 69°C
(156°F).  The  filter mat  was advanced by a timer.  This system operated
with an average  particulate  removal efficiency of 78 percent based on an
average inlet  loading of  6.94 kg/h (15.3 Ib/h)  and an outlet loading of
1.54 kg/h  (3.4 Ib/h).    Controlled  emissions  averaged   0.035  kg/Mg
(0.07 Ib/ton)  of product, as shown for Plant D  in Figure 4-12.  Visible
emissions from the  stack of  the  control device  were  about 15  percent
opacity as shown in Table 4-9.
     There are several  possible  reasons why  the  HVAF unit at Plant D  had
a lower particulate  removal  efficiency than the  HVAF unit  at  Plant C.
These reasons are discussed below.
     1.   The timed advancement of the filter mat  at Plant D could result
in reduced efficiency.  As explained  in Section 4.3.2.1, advancement of
too much filter material or advancement of  the filter too frequently will
result in decreased  collection efficiency  due to excessive exposure  of
"uncaked" filter media  and the  resulting low pressure drop across  the
filter.   This  condition can  also  occur if filter  advance  continues while
                                  4-45
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 the roofing line is shut off to repair a felt break.  It should be noted
 that there were  several  line stoppages during  the  tests  cited above.
      2.   The  operating temperature  of  the  control  device  at Plant C  was
 about 55.5°C  (132°F)  compared with an operating  temperature of about
 71.7°C  (161°F) for Plant D.   This  could  bias the measured  particulate
 removal  efficiency of the HVAF  at  Plant  D  towards the low side because
 some of the hydrocarbons which  are  particulates at 55.5°C (132°F), and
 are measured as a particulate  by the EPA method, would be  gases  at 71.7°C
 (161°F)  and would  thus  pass  through  the HVAF.  The  greater visible
 emissions  from Plant D,  as  compared with  Plant C,  also support the argu-
 ment that more gaseous emissions were  present in  the  exhaust stream  of
 Plant D.   Gaseous emissions  that pass  through  a HVAF  could condense  to
 form a  visible plume upon coming in contact with the cooler ambient air.
 In  these  tests,  the test samples were  cooled to 38°C (100°F)  before  the
 particulate mass  fraction was  collected.  Therefore, part  of the gaseous
 hydrocarbon will  be condensed,  and  the  measured mass of  particulate will
 be  higher.  The  effect of this  is that the data indicate the  efficiency
 of  removing hydrocarbons  that are condensible  at  38°C  (100°F) and not
 just  the efficiency of removing  the  particulate matter.
      Table 4-6 shows  only 0.04  kg/h (0.088 Ib/h)  of POM emissions and
 2.42  kg/h  (5.34 Ib/h)  of gaseous HC emissions  from the wet  looper,
 saturator, and storage tank compared  to  29.9 kg/h  (66 Ib/h)  of  total
particulate emissions.   The HVAF achieves  a 91.9 percent reduction of POM
emissions and no reduction of gaseous hydrocarbons.
4.4.3  Performance of Afterburners
     Thermal  afterburners are  used   in this industry primarily for the
control  of  pollutants  from asphalt  blowing  stills,  although in a  few
cases they have been  used  to control the  pollutants from saturators and
other roofing  line  processes.   When properly designed, constructed, and
operated, thermal  afterburners  give  good  performance in the  control  of
organic particulates, gaseous hydrocarbons,  and POM's from sources within
the asphalt roofing industry.
     4.4.3.1   Afterburners  Applied to the  Saturator, Wet Looper,  Coater,
and Storage Tanks.  Emission  measurement  tests  were performed on  one
asphalt plant where two identical afterburners were  operated  in parallel
                                  4-47
-------
to control  the emissions from the  saturator,  wet looper, coater, and
storage tanks.  The  emissions data for these parallel afterburners were
combined  to  reflect total process  emissions.   These data, Plant B  in
Figure 4-12, reflect an  average  controlled  particulate  emission  level of
0.0465  kg/Mg  (0.093 Ib/ton)  of  product.   Visible  emissions  from the
afterburners were  less  than  one percent opacity  as  shown in  Table 4-9.
The  individual  afterburners  operated at particulate  removal efficiencies
of 77.7  percent and 95.2 percent.  This difference  is attributed to the
fact that the afterburner with  the  lower  efficiency was operated at a
temperature of 538°C (1000°F),  compared with an operating temperature of
649°C (1200°F) for the  other.  As discussed in Section  4.3.2.3 and shown
in Figures 4-8 and 4-9,  a temperature difference  as  small  as  56°C (101°F)
easily accounts for  a variation  in  efficiencies as large  as that observed.
      If  one assumes  that both afterburners  are operated  at 649°C (1200°F)
and  therefore achieve control efficiencies  of 95.2  percent,  the average
emission level  of  0.046  kg/Mg (0.1  Ib/ton)  (total from  both afterburners)
shown in Figure 4-12 would  be reduced to  0.021 kg/Mg (0.042 Ib/ton) of
product.   Furthermore,  if one combines  the known data for operation of
these specific afterburners  at  temperatures  of 538°C and 649°C (1000°F
and   1200°F) with  the information  (see Section  4.3.2.3)  that almost
 100  percent of organic particulate  and gaseous hydrocarbon can  be
destroyed at temperatures of 704°C to 816°C (1300°F to 1500°F), then an
efficiency versus  temperature  curve  can  be  constructed  as  shown in
 Figure 4-13.    Based  on  this curve,  if  Plant  B were operated at 704°C
 (1300°F), the  removal  efficiency  would be 98 percent,  and  controlled
 emissions from Plant B  would be 0.0086 kg/Mg (0.017 Ib/ton)  of product.
 The  data in  Table 4-5  show  that the  concentration  of HC  and POM in the
 fume  from the saturator is  small when  compared  to  the concentration of
 particulate.    The  uncontrolled  emissions  from the saturator and storage
 tanks  contain 0.012 kg/h (0.027  Ib/h)  of POM  compared to  0.62 kg/h
 (1.36 Ib/h)  of  gaseous hydrocarbon and  5.49 kg/h (12.9 Ib/h)  of
 particulate.
       4.4.3.2   Afterburners  Applied to Blowing Stills.   Emission measure-
 ments were performed  on an  afterburner used  to  control emissions from a
 blowing  still with the afterburner  operating at about 816°C (1500°F).
                                   4-48
-------
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                               4-49
-------
Measured efficiencies of the afterburner were 95 percent and 96.7 percent
for  the  saturant and coating blows,  respectively.   The fume from the
coating blows  had  a higher concentration of particulate and HC than the
fume from the saturant blows.  The efficiency of HC destructions directly
                                                                  Outlet
                                                              15
related to concentration,  all  other factors being equivalent.
particulate emissions were  0.243 kg/m3  (2.02 lb/1,000 gal) of saturant
asphalt charged  to the  still  and  0.405 kg/m3  (3.38 lb/1,000  gal)  of
coating asphalt.   These  emission data are  summarized  in  Table 4-7  and
Figure 4-14.   No  visible emissions were observed from the afterburner
(Table 4-9)  for  either  the  saturant or the coating  blowing  cycles.
     This  afterburner  demonstrated a 98.2 and 95.0 percent reduction of
the  gaseous  hydrocarbon  emissions  for the  saturant  and coating blows,
respectively,  and a 99.7  percent reduction of  ROM's for the coating
blows.  The  incomplete destruction  of particulate and  gaseous  hydrocarbons
at the afterburner temperature  of 816°C (1500°F) was  probably  due  to
inadequate mixing of fume and combustion  products  or to  bypassing  some
fume around  the hot reaction zone, as discussed in Section 4.3.2.3.   The
residence  time at combustion temperature  may  also have been inadequate
for complete combustion both of the gaseous hydrocarbons and the large
droplets  usually  formed  during the rapid cooling of  the gases  by dilution
air.
4.4.4  Performance of  Electrostatic Precipitators
      Two  modular ESP's at one asphalt roofing plant were  tested. The two
 ESP's were  installed  in parallel to control the combined emissions from
 the saturator,  coater,  and wet looper.   The ESP.'s  operated  at inlet
 temperatures of  51.1°C  (124°F), 57.2°C  (135°F), and  48.3°C (119°F)  and
 achieved  particulate  removal efficiencies  of 96.6 percent, 93.6 percent,
 and 96.8  percent,  respectively.   The controlled particulate emissions
 from both ESP's,  when combined, averaged  0.016 kg/Mg (0.032  Ib/ton)  of
 product as  shown for  Plant A  in Figure 4-12.   Visible emissions from the
 ESP's were  generally  less than  10 percent opacity as shown  in Table 4-9.
 As  stated in Section  4.3.2.4, this efficiency  could be further increased
 by  the use  of additional series  modules.   The potential efficiency of
 these units could have been increased by cooling the inlet  fume below
 50°C  (122°F)  so  additional hydrocarbons  would  have been in particulate
                                    4-50
-------
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form, removable by the ESP.   As with the high velocity air filter systems
discussed earlier, preceding  of the inlet air stream  to  30°C to 49°C
(90°F to 120°F) via air dilution or water sprays is necessary to condense
a substantial  portion  of the gaseous hydrocarbons to particulates which
can be removed by the ESP.
4.4.5  Performance of Fabric Filters
     Fabric  filters  used to control emissions  from  talc and limestone
handling and storage equipment at asphalt roofing plants were not tested.
As discussed in Section 4.3.2.5, these devices are used to control clay (C)
and  limestone  (L)  emissions in the crushed stone industry as summarized
in  Figure  4-15.   In the  applications in  the crushed stone industry,
collection  efficiencies  exceed  99 percent,  and  outlet loadings  are
consistently  less than  2.3 x  10"5 kg/m3 .(0.01 gr/DSCF).  As  shown  in
Table 4-10,  visible  emissions  are consistently zero.   The material  being
controlled,  the  processes,  conveying, and  storage are  the same  for both
industries;  thus,  similar  emission  levels  can be  attained for the
applications  in the  asphalt roofing industry.
4.4.6   Performance of  Mist  Eliminators on  Storage Tanks
     Mist  eliminators  were  discussed in Section 4.3.2.2.   Visible emissions
from a mist eliminator used to control  emissions from storage tanks were
zero percent opacity as  shown  in Table 4-9.   Particulate mass loadings
from mist  eliminators  were  not measured.
                                   4-52
-------





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28
                                  4-53
-------
                   TABLE 4-10.  VISIBLE EMISSIONS FROM MINERALS
                          HANDLING AND STORAGE FACILITIES
Plant
  H
  J
  K
   Facility
Conveyor transfer
point
Finishing screens
Finishing screens
Finishing screens
and bins
Bagging operation
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Baghouse
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Baghouse
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                                      observations
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40

40
40
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                                 4-54
-------
 4.5   REFERENCES FOR CHAPTER 4
  1.   United  Air Specialists,  Inc.   The Control  of Asphalt and Coal Tar
      Fumes.   Form 9-374.   Cincinnati,  Ohio.   1974.   p.  2.

  2.   Corbett,  L.  W.   Reaction Variables in the  Air-Blowing of Asphalt.
      Industrial  Engineering Chemistry  Process Design and Development
      14(2):181-187.   April  1975.

  3.   Air  Pollution Engineering Manual  (Second Edition).   U.S.
      Environmental  Protection Agency.   Research Triangle Park,  N.C.
      AP-40.   May 1973.  p.  687.

  4.   Barth,  E.  J.   Asphalt-Science  and Technology.   New York,  Gordon and
      Breach,  1962.  p. 331-428.

  5.   Andersen  2000, Inc.  HEAF Air  Pollution  Control  Equipment
      Engineering Manual with  Operating and Maintenance  Instructions.   TR
      No.  75-900011.   Atlanta,  Ga.   April  1976.   p.  14.

  6.   Reference  5,  Figure 7.

  7.   Reference  5,  p.  21.

  8.   Reference  5,  p.  10, 11.

  9.   Reference  5,  Table IV.

10.   High-Energy  Air  Filter for Reducing  Industrial  Effluents.   Filtration
      Engineering.  May 1970.

11.   Reference 5, p.  53.

12.   Letter from  Brady, J.  D., Andersen 2000, Inc.,  to Noble,  E. A.,
      EPA/ISB.  January 21,  1976.  Cleaning procedures for  HEAF  units.

13.   Reference 5,  Figure 1.

14.  Monsanto Enviro-Chem Systems,  Inc.   Brink  Fact Guide  for the
      Elimination  of Mists and  Soluble  Solids.   Undated.

15.  Afterburner  Systems Study.  U.S.  Environmental  Protection  Agency.
      Research Triangle Park, N.C.   EPA-R2-72-062.  August  1972.  p.  6  7
      16a-23,  69-72.

16.   EPA Air Pollution Emission Test.  Final  Report for  Plant B.   p. 19.

17.  United Air Specialists, Inc.   Smog-Hog is  a Glutton for Dirty Air!
     Cincinnati, Ohio.  1 p.
                                   4-55
-------
18.   United Air Specialists.  Smog-Hog:  Beat the High Cost of Process
     Smoke Control!   M-6A.  Cincinnait, Ohio.  1972.  4 p.

19.   United Air Specialists.  Smog-Hog Air Pollution Control System.
     Figure 8-174.  Cincinnati, Ohio.  1 p.

20.   A Manual of Electrostatic Precipitator Technology.  Parts I and II.
     National Air Pollution Control Administration.  Cincinnati, Ohio.
     APTD-0610.  August 1970.

21.   Control Techniques for Particulate Air  Pollutants.  U.S. Department
     of Health, Education, and Welfare.  Washington, D.C.   AP-51.
     January 1969.  215 p.

22.   Schmeider, G. G. et  al.  Selecting and  Specifying Electrostatic
     Precipitators.  Chemical Engineering.   82(11):94-108.  May  26, 1975.

23.   Particulate  and Gaseous  Emissions from  the  Asphalt  Roofing  Process
     Saturator at the Celotex Roofing Plant,  Fairfield,  Alabama.   U.S.
     Environmental Protection Agency.   Research  Triangle Park, N.C.
     76 ARM 13.   p. 44.

24.  Memo from Shea, E.  P., MRI/NC,  to Noble,  E.  A.,  EPA/ISB.
     April  23, 1979.  Minutes of April 4,  1979 meeting with
     representatives of  Owens-Corning Fiberglas.

25   Non-Metallic Mineral Processing Plants  -  Background Information  for
     Proposed  Emission Standards.   Draft  EIS.  U.S. Environmental
     Protection  Agency.   Research  Triangle Park, N.C.  March 1979.
     p. 4-21.

26.  Reference 25, p. 4-40.

27.  EPA  Visible Emission Tests.   Final Reports  for Plants A, B, C, D, E,
     and  F.

 28.   Reference 25,  p.  4-35.
                                     4-56
-------
                    5.   MODIFICATION  AND  RECONSTRUCTION

      In  accordance with Section 111  of  the  Clean Air Act, as amended,
 standards  of performance shall be established  for new sources within a
 stationary  source category which "... may contribute significantly to
 air  pollution .  .  .  ."  Standards  of performance apply to "affected
 facilities,"  the  construction or modification  of which  started after the
 proposal of  said  standards.
     On  December 16,  1975,  the  Agency promulgated amendments  to the
 general  provisions  of 40 CFR Part 60, including additions and revisions
 to clarify  modification and the addition of a reconstruction provision.
 Under  the  provisions  of 40 CFR 60.14 and 60.15,  an "existing  facility"
 may  become  subject to  standards  of  performance if deemed modified  or
 reconstructed.  An  "existing  facility" defined in 40 CFR 60.2(aa) is an
 apparatus of  the  type for which  a standard of performance  is promulgated
 and  the  construction  or modification of which was commenced before  the
 date of proposal of that standard.  The following discussion examines the
 applicability  of  these  provisions  to  asphalt  roofing manufacturing
 facilities (saturators,  asphalt storage tanks,  blowing stills,  and mineral
 handling and  storage) and  details conditions under which these existing
 facilities could  become subject  to  standards  of  performance.   It is
 important to  stress that standards  of  performance apply  to  affected
 facilities, which,  combined with existing and other facilities, comprise
a stationary source.  The addition of an affected facility to  a stationary
source  through any  mechanism,  new  construction, modification,  or
reconstruction, does  not make the entire stationary  source subject  to
standards of performance,  only the added affected facility.
                                  5-1
-------
5.1  40 CFR PART 60 PROVISIONS FOR MODIFICATION AND RECONSTRUCTION
5.1.1  Modification
     It Is  important  that these provisions be fully understood prior to
investigating their applicability.
     Section 60.14 defines modification as follows:

          Except as provided  under paragraphs  (e) and (f) of this
     section, any physical or operational change to an existing
     facility which results in  an increase in  the emission rate to
     the atmosphere of any pollutant to which  a standard applies
     shall  be considered  a modification within the meaning of
     Section 111 of the Act.  Upon modification, an existing facility
     shall  become an  affected facility for each pollutant to which a
     standard applies and for which there  is an increase in the
     emission rate to the atmosphere.
     Paragraph  (e)  lists  certain physical or  operational  changes which
 will not be considered as  modifications,  irrespective of any change in
 the emission  rate.   These changes include:
      1.   the  maintenance, repair, and replacement determined to be routine;
      2.   an increase in  production  rate accomplished without a capital
 expenditure;
      3.   an increase in the  hours of operation;
      4.   the use of  an alternative fuel or raw material if, prior to the
 standard,  the  existing  facility was  designed  to  accommodate  that
 alternative fuel or  raw material;
      5.  the addition  or use  of an air pollution control device that is
 environmentally beneficial.
      Paragraph (b) clarifies what constitutes an increase in emissions in
 kilograms  per hour and the methods for determining the increase, including
 the use of emission factors,  material  balances, continuous monitoring
 systems,  and manual  emission  tests.   Paragraph  (c)  affirms that the
 addition  of  an affected  facility to  a stationary  source does  not make  any
 other facility within that  source  subject  to standards of performance.
 Paragraph (f)  simply provides  for superseding any conflicting provisions.
                                     5-2
-------
 5.1.2  Reconstruction
      "Reconstruction" means  the replacement of components  of an existing
 facility to such an extent that:
      1.  the  fixed  capital cost of the  new components  exceeds 50 percent
 of the fixed capital cost that would be required to construct a comparable
 entirely new facility; and
      2.  it  is technologically  and economically feasible  to meet the
 applicable performance standard.
      The purpose of these provisions is to ensure that an owner or operator
 does not perpetuate an  existing facility by replacing all  but vestigial
 components, such as support  structures, frames, and housing,  rather than
 totally replacing it in  order to avoid subjugation to applicable standards
 of performance.
      The enforcement  division  of  the appropriate  EPA regional office
 should  be  contacted whenever a source has  questions  regarding modifi-
 cations and reconstruction.   Their  judgment will  supersede any general
 examples  that  are given  in this document.
 5.2  APPLICABILITY TO  ASPHALT ROOFING PLANTS
 5.2.1   Modification
      Physical  and  operational changes to  an asphalt roofing  plant which
 might be  considered modifications are:
      1.   extension of  the saturator  capacity through the  use  of  additional
 sprays  or dips; and
     2.   replacement of  a component with  one of a different  design or
 capacity to increase the line speed  of the plant.
 5.2.2   Reconstruction
     There  are  few  possible  changes that  are likely  to be  made  to an
 asphalt roofing plant which would be defined  as reconstruction.  Generally,
 asphalt roofing plants have  a  long  lifetime.  Many existing plants have
 been  operating  for over  50 years.   Due to  the  flammability  and high
 operating temperatures  of the asphalt, the potential for fire is signifi-
 cant.  It is possible that a fire could damage an asphalt roofing
plant to  such  an extent that the provisions for reconstruction would
apply to the repairs necessary to resume production.
                                   5-3
-------
5.3  SUMMARY
     According  to  40 CFR  Part 60 provisions  for  modifications  and
reconstructions, as  applied to  asphalt roofing plants,  few,  if  any,
facilities  are  expected to  become affected facilities  by virtue of
modification or reconstruction after proposal of new standards.  Relatively
unchanging  technologies for production and the extended lifetime of
asphalt roofing plants  substantiate this position.
                                     5-4
-------
                  6.   MODEL PLANTS AND REGULATORY ALTERNATIVES

 6.1   PURPOSE
      The purpose of  Chapter 6 is to define model  plants and the regulatory
 alternatives for the Asphalt  Roofing  and Siding Manufacturing Industry.
 The  environmental, economic,  and energy impacts  associated with the model
 plants  and  the  regulatory alternatives are presented  in Chapters 7 and 8.
 6.2   MODEL  PLANTS
      The production  of  asphalt roofing and siding varies widely from
 plant to plant.  Plant production is determined by plant capacity and by
 operating time.   Plant-capacity, in turn, depends on  the number of lines
 in a plant,  the felt width, and  the  line  speed.   In this report,  as shown
 in  Table 6-1,  the parameters  of operating time, felt  width,  and line
 speed are considered to be fixed with  the  number of  lines  in  a  plant as
 the  only production variable.   The data  for  plants with  stills are
 presented in Table 6-2.
      Several model  plant  configurations  were  developed.   Three plant
 sizes (small, medium, and  large) were chosen as representative of probable
 future  plants based  on review of current  installations and the mix of
 products manufactured.   The small plant has one  roofing line,  the medium
 sized plant  has two  roofing lines,  and the large plant has two  roofing
 lines plus  one   saturated  felt line.   For  each  size  of plant, small,
 medium  and  large, one configuration includes  an  asphalt blowing still
while the second configuration does not,  resulting in  a total of six
model plants.
     Figures 6-1  through  6-6  illustrate the model plant configurations,
one  for  each of the six  model  plants.   Figures 6-1 and  6-2  are for small
plants,  6-3  and 6-4 for  medium plants,  and  6-5 and 6-6  for  large  plants.
Development   of  model  plant  configurations  utilized  data  from source
                                   6-1
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tests,  from  industry responses to  EPA requests for information, from
plant  visits,  and from an  in-depth study of process control options.
     The emissions from the saturator, wet looper, and coater are controlled
by  any one of  three control devices.  The  control  devices used are:
(1) high  velocity air filters  (HVAF); (2) electrostatic precipitators
(ESP);  and (3) afterburners  (A/B).   The term  "afterburners"  includes
thermal  oxidizers,  waste heat  boilers,  incinerators,  and  afterburners
with  waste heat recovery.  Emissions  from asphalt  storage tanks can be
controlled by  a mist eliminator or routed through  one of the saturator
and coater control  devices.  It was  assumed that it will be cheaper to
use a mist eliminator to control  storage tank emissions when the roofing
line  is not operating than  to  operate the saturator and coater control
device full time.  The only device  utilized  for controlling the  emissions
from  blowing stills  is the  afterburner.
      It was assumed  for  model plant configuration development that  emissions
controlled by  HVAF's and ESP's will  be cooled to 40°C (104°F) prior to
control.
       The model plant layouts utilize individual baghouses for each talc
and mineral stabilizer emission source.   This represents a "worst-case"
cost impact.   It may be  more cost  effective, however,  to combine these  as
follows:
      Small plants:                                           ^
            1.   combine  mineral  stabilizer  surge bin  (13),  mineral
                stabilizer dryer (14), and mineral stabilizer silo (15); and
            2.   combine parting agent machine bin (18) and parting agent
                silo (19).
      Medium and large plants:
            1.   combine mineral  stabilizer surge bins (13] and 132), mineral
                stabilizer dryer (14) and  mineral stabilizer silo (15); and
            2.   combine  parting agent machine  bins (181  and 182) and
                parting agent silo  (19).
  ^Numbers in parentheses refer to the codes used in the legends for
  Figures 6-1 through 6-6.
                                   6-10
-------
 Control  of emissions from  the  mineral  surfacing application area is  not
 considered in the model  plants  for two  reasons:   (1)  the emissions appeared
 to  be contained within  the plant building;  and (2) there was no system
 observed that captured the  emissions from this area in  a  satisfactory
 manner.
      The raw material requirements and  the  utilities usage for each of
 the  model  plant sizes (small, medium,  and large) are shown in Table 6-3.
 The  data in the table were obtained by  compiling information supplied by
 asphalt  roofing companies  in response to  EPA  requests for information  and
 then  converting  the data to  fit  the model plants.  Utility  requirements
 (water,  gas, oil,  electricity)  for operation of the emission  control
 systems  are  also  included  in Table  6-3.
 6-1.1  Baseline Model Plant Control Systems
      The baseline model  plant control systems are shown in Table 6-4  for
 small plants;  in  Table  6-5 for  medium plants; and in  Table 6-6  for large
 plants.  The facilities  being controlled  are  the  saturator and coater,
 blowing  still,  and mineral  handling and  storage.   The  control  devices
 include a  high velocity air  filter, an electrostatic precipitator, and  an
                                                        "ft
 afterburner  for the saturator and coater;  an afterburner  for the blowing
 still; and a cyclone for the mineral handling and storage.  Since the
 typical  asphalt  roofing plant  does not have  a  control  device  on the
 asphalt storage tanks, the asphalt storage tanks are shown with no control
 device in Tables 6-4, 6-5, and 6-6.
     Asphalt  roofing  plants presently meet typical  state standards of
20 percent opacity, but  it  is not known  if the plants meet  typical  state
mass  emissions  requirements.  The  baseline  model plant was  developed
 using data  from plant emission  tests,  from industry-supplied data, from
plant site  visits,  and from the State Implementation  Plans  (SIP's).  The
emission data  in  Tables  6-4, 6-5, and 6-6 for the saturator and coater,
asphalt  storage  tanks,  and  blowing stills were  based  on  SIP's  and
calculated for the model  plant size.
 The afterburner is preceded by a cyclone that is considered
 to be a piece of process control equipment.
                                   6-11
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-------
6.3  REGULATORY ALTERNATIVES
     The purpose of  this  section is to list the regulatory alternatives
or possible courses  of action that  EPA could take to control particulate
emissions from asphalt roofing and siding manufacturing plants.  Possible
regulatory alternatives are as follows:
     1.   No  new source performance  standard  (NSPS)  for this industry.
     2.   New  source  performance standard to control the  emissions  from
the  saturator, wet  looper,  and coater  and  asphalt storage  tanks.
     3.   New  source  performance standard to control the  emissions  from
the  saturator,  wet looper, and  coater,  asphalt storage tanks, and the
blowing still.
     4.   New  source  performance standard to  control  emissions from the
saturator, wet looper, and coater,  asphalt storage tanks, and materials
handling.
     5.   New source performance standard to  control  emissions from the
saturator, wet looper, and coater, asphalt storage tanks, blowing still,
and  materials handling.
     Figure  6-7 is a matrix  displaying  the five regulatory  alternatives
with each facility to  be  controlled.
     There is only one viable control technique for blowing stills.  For
the  saturator and coater three  types of control equipment are used, and,
based  on the  data contained  in Chapter 4 and Appendix C, all  are judged
to be  similar in  their control  capability.   For that reason, the regulatory
 alternatives presented in  Figure  6-7 are different from most recommen-
 dations  in  that  only one  level of NSPS control is proposed  for each
 emission source,  other than baseline.  All  but one of the emission sources
 considered for control will, in the absence of  an NSPS,  be  controlled  by
 State and local agencies and essentially the same control devices will be
 used.   The differences are:
      1.  The capture  device  for the saturator  is  a full  enclosure  rather
 than the hood typically used.
      2.  The efficiencies of the HVAF and ESP are increased by reducing
 the fume inlet temperature  (the  HVAF  and  ESP are particulate  control
 devices  and  reducing the  fume temperature converts more  of  the gaseous HC
 to a particulate).

                                     6-16
-------
Regulatory
alternatives
1
2
3
4
5
Saturator

•
•
•
•
Asphalt
storage

•
•
•
•
Blowing
stills


•

•
Minerals
handling
and storage



' •
•
Figure 6-7.  Regulatory alternatives and controlled facilities.
                             6-17
-------
     3.  The efficiency of the afterburner is increased by increasing the
combustion temperature and the residence time at temperature.
     Total  plant emissions will  vary with  each  alternative because
different quantities  of  particulate are emitted by the various emission
sources.
6.3.1  Regulatory Alternative 1
     This alternative assumes no NSPS  would be set if emissions from
asphalt  roofing  plants are determined to be insignificant  now and are
expected to remain  so in the future, or if  existing State standards are
adequate and consistent.   The asphalt roofing industry was  ranked number
45 out of 59 source categories prioritized for  NSPS development by EPA in
44 FR  163 on August 21,  1979.5  In  the absence  of an NSPS, typical plants
in the industry would utilize control  systems  as  shown in Tables 6-4,
6-5,  and 6-6.  The States  control  emissions from asphalt roofing plants
by monitoring opacity and odor complaints.   The baseline plants would meet
opacity  requirements, but  it is  not known  if the  plants would meet the
particulate standards.   Tables 6-4, 6-5, and 6-6 list  the emission sources,
control  systems, control parameters, operating temperatures, exhaust gas
characteristics, and emissions for baseline asphalt roofing plants.   The
mass emissions  listed in Tables 6-4, 6-5,   and 6-6 were obtained from
State Implementation Plans and were calculated to conform to model plant
sizes.  The energy and other utility requirements  for  operation of  control
equipment listed in  Tables 6-4,  6-5,  and 6-6 are  included  in Table  6-3.
6.3.2  Regulatory Alternative 2
      This alternative assumes control of three emission sources:  saturators,
 coaters, and asphalt storage tanks.  Three  types of  control  equipment
 (afterburner, ESP,  and HVAF) have  been demonstrated  to be capable of
 achieving equivalent reduction in  particulate  emissions from saturators,
 coaters, and asphalt storage tanks.  The baseline control system must be
 upgraded to meet the requirements of this  regulatory alternative.  The
 necessary changes are:
      1.  a  better capture  system;
      2.  preceding  of the fume before the  HVAF or the ESP; and
      3.  higher operating temperature and  longer residence  time  in the
 afterburner.
                                    6-18
-------
The  control  systems containing  these  equipment types are described  in
Table 6-7 for small plants; in Table 6-8 for medium plants; and in Table 6-9
for  large  plants.   Mist eliminators are shown  for control  of emissions
from the  asphalt storage tanks  when the roofing line is  not  operating.
The energy requirements and the  costs  of these  control systems will vary.
6.3.3  Regulatory Alternative 3
     The facilities  to be  controlled under this alternative are  the  same
as for Alternative 2 except that blowing stills are included.   The after-
burner is  the only  device  used  to  control  particulate emissions  from  the
blowing still.   The control systems for the four facilities are  shown in
Tables 6-7,  6-8, and  6-9.   The  operating  conditions  for  these control
systems are also shown in the tables.
6.3.4  Regulatory Alternative 4
     This regulatory alternative is the same as Alternative 2 except  that
control is recommended for materials handling.   Tables 6-7, 6-8, and  6-9
show the facilities to be controlled, the recommended control  system, and
the operating conditions under  Regulatory  Alternative 4.    Controls are
specified in Tables 6-7, 6-8, and  6-9  for  the saturator,  coater, asphalt
storage tanks,  and materials handling.
6.3.5  Regulatory Alternative 5
     All  facilities are recommended for control  in this alternative.   The
controlled facilities  (the saturator and  coater, asphalt  storage tanks,
blowing stills,  and materials  handling) are displayed in Tables 6-7,  6-8,
and 6-9.   The control  systems  for these facilities are also displayed and
the operating conditions are specified.
                                   6-19
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6.4  REFERENCES FOR CHAPTER 6
 1.


 2.


 3.


 4.
Memo  from  Shea,  E.  P.,  MRI/NC  to  4654-L Project File.   May 30  1979
Calculations  for data  in  Table 6-1.                       -x   >      •

Memo  from  Shea,  E.  P.,  MRI/NC  to  4654-L Project File.   May  31   1979
Calculations  for data  in  Table 6-2.

Memo  from  Shea,  E.  P.,  MRI/NC  to  4654-L Project File.   June  1   1979
Calculations  for data  in  Table 6-3.                           '

Non-Metallic  Mineral  Processing Plants - Background Information for
Proposed Emission Standards.   Draft EIS.  U.S.  Environmental
Protection Agency.  Research Triangle  Park, N.C.  March 1979.

U.S.  Environmental  Protection  Agency.   Priority List and  Additions
to  the  List  of Categories of  Stationary  Sources.   40  CFR Part  60
Washington, D.C.  Office  of  the Federal Register.   August 21  1979
                                 6-23
-------
-------
                        7.  ENVIRONMENTAL IMPACT

      An assessment of the environmental and  energy  impacts  of  regulatory
 alternatives for the asphalt  roofing manufacturing  industry is presented
 in this chapter.   Beneficial  and adverse impacts on  air,  water,  solid
 waste, energy,  and noise are reviewed.
 7.1   AIR POLLUTION IMPACT
      In order to determine  the  impact  of regulatory alternatives  on air
 quality, the emissions  from  a baseline  model  plant equipped with emission
 control systems that  allow it  to meet general State particulate  and
 opacity standards  were  compared  with  the  emission  reductions from  the six
 model  plants representing the  various regulatory alternatives.  An  exami-
 nation of the  emission sources  (Chapter  3)  from the asphalt  roofing
 industry shows  that the  major  air pollutant is  particulate  emissions  from
 the  saturator,  coater,  asphalt  storage,  blowing  still,  and materials
 handling and storage.   The impact  on air  quality  of controlling these
 emission sources through one  of  the  various  regulatory alternatives
 presented  in Figure 6-7,  Chapter  6, is  assessed in the following subsection.
 7-1.1   Particulate  Emissions from  the Model Plants
     As  explained  in  Chapter 6,  three  model  plant sizes  (small, medium,
 and  large)  and  two configurations for each plant  size were  used.
 Configuration 1 represents a model plant equipped with a blowing still;
 Configuration 2 depicts a plant without a blowing still.   Each regulatory
 alternative  was  applied  to  each  model  plant configuration, the total
 annual  baseline particulate  emissions  were calculated from  Tables  6-4,
 6-5,  6-6,  and the  results were  tabulated  in  Table 7-1.   Alternative 1
 applies  only to the baseline model  plant (Table 7-1) whose  emissions  are
 used for comparison with the  reduced emissions from  the other model
plants under the various regulatory alternatives.
                                  7-1
-------
 TABLE 7-1   ANNUAL MASS PARTICULATE EMISSIONS FROM BASELINE MODEL PLANTS
              WITH AND WITHOUT BLOWING STILL (ALTERNATIVE 1)
                                                       Mg/yr
              Tons/yr
Total annual particulate emissions from:

   Small baseline plant with blowing still
   Small baseline plant without blowing still

Total annual particulate emissions from:

   Medium baseline plant with blowing still
   Medium baseline plant without blowing still

Total annual particulate emissions from:

   Large baseline plant with blowing still
   Large baseline plant without blowing still
158
 74
257
 89
303
 94
174
 82
283
 98
334
104
                                   7-2
-------
       Particulate  emissions from the baseline model plants are summarized
  in  Table 7-1.  Table  7-2 presents the participate  emissions  from the
  small  plant for  the two configurations and  various  regulatory alter-
  natives, while Tables  7-3  and 7-4  show  the particulate emissions  from  the
  medium  and  large  plants, respectively.   An  emission limit was  assumed in
  order to calculate the data shown  in Tables 7-2, 7-3, and  7-4.
  7.1.2   Secondary Air Pollutants
      The only  secondary  air  pollutants resulting from  the  regulatory
  alternatives are  those  associated with the  use of an afterburner to
  control  emissions  from the saturator,  coater,  and the blowing stills.
  Emissions of  SO,,,  CO,  and N0x occur  with  the  use of afterburners.
 Table 7-5 presents data on these  secondary pollutants obtained by EPA
 from source tests  of afterburner performance on a saturator and a blowing
 still.''^
 7.1.3  Dispersion  Analysis
      Ground-level  pollutant concentrations at specific locations downwind
 from a medium  asphalt roofing plant have been estimated using atmospheric
 dispersion  modeling.    A description of the  Industrial  Source Complex
 (ISC) model used  and  the  results  are  contained  in a report  by  the
 H.  E.  Cramer Company  and are summarized in the following subsections.3'4
      7-1-3-1  Model Description  and Input Data.   Estimates  of the  24-hour
 average  ground-level  concentration and  the annual  average ground-level
 concentration were  made for a network  of  receptors at various  downwind
 distances from a medium model plant.
      The model  used accounts for aerodynamic  downwash and a large number
 of  sources  and  receptors and requires input data on  sources, receptors,
 and  meteorology.   The  annual  average ground-level  concentrations are
 below  the National  Ambient  Air Quality Standards (NAAQS)  for  all
 configurations and  regulatory alternatives  and are not included in this
 discussion.
     7-1-3.1.1  Source data.  The source configuration for  a medium model
plant was assumed  to  consist of five stacks that correspond to the five
major emission sources.   Two sets  of operating conditions  (baseline and
controlled), representing two levels of particulate emission control,
were considered in  the  model calculations for each stack.  The data for
                                  7-3
-------
 TABLE 7-2.   ANNUAL MASS PARTICULATE EMISSIONS FROM SMALL PLANTS
             FOR REGULATORY ALTERNATIVES 2 THROUGH 5
                                                     Mg/yr    tons/yr
Total annual measured particulate emissions from
     model plant Configuration 1:
               A.  Alternative 2                       90

               B.  Alternative 4                       89

Total annual measured particulate emissions from
     model plant Configuration 1:

               A.  Alternative 3                       29

               B.  Alternative 5                       28

Total annual measured particulate emissions from
     model plant Configuration 2:

               A.  Alternatives 2 and  3                  6

               B.  Alternatives 4 and  5                  5
99

98




32

31




 7

 6
                                   7-4
-------
  TABLE 7-3.   ANNUAL MASS PARTICULATE EMISSIONS FROM MEDIUM PLANTS
                FOR REGULATORY ALTERNATIVES 2 THROUGH 5
                                                      Mg/yr     tons/yr
Total annual measured particulate emissions  from
     model plant Configuration  1:
               A.  Alternative 2

               .B.  Alternative 4

Total annual measured particulate emissions from
     model plant Configuration 1:

               A.  Alternative 3

               B.  Alternative 5

Total annual measured particulate emissions from
     model plant Configuration 2:

               A.  Alternatives 2 and 3

               B.  Alternatives 4 and 5
181

178
 60

 56
 14

 10
200

196
 66

 62
 15

 11
                                  7-5
-------
 TABLE 7-4.   ANNUAL MASS PARTICULATE EMISSIONS FROM LARGE PLANTS
               FOR REGULATORY ALTERNATIVES 2 THROUGH 5
                                                     Mg/yr    tons/yr
Total annual measured particulate emissions from
     model plant Configuration 1:

               A.  Alternative 2                       225       248

               B.  Alternative 4                       223       246

Total annual measured particulate emissions from
     model plant Configuration 1:

               A.  Alternative 3                        74        82

               B.  Alternative 5  ,                      71        78

Total annual measured particulate emissions from
     model plant Configuration 2:

               A.  Alternatives  2 and  3                 '16        18

               B.  Alternatives  4 and  5                 13        14
                                  7-6
-------
       TABLE 7-5.  SUMMARY OF S02 AND CO EMISSIONS FROM AFTERBURNERS
              USED TO CONTROL A SATURATOR AND A BLOWING STILL
        Source
                                            SO,
                        CO
                                        kg/h   (Ib/h)    kg/h    (Ib/h)
Afterburner outlet on
  saturator (Plant B)

Afterburner outlet on      Saturant
  blowing still (Plant E)  Coating
   NDC
5.5   (12.1)
6.5   (14.3)
16.49  (36.27)
13.0   (28.7)
32.3   (71.3)
 Not detected.
                                 7-7
-------
the  baseline and  controlled  operating  conditions are  presented in
Tables 7-6 and 7-7.
     Twelve  model  plants  [three plant sizes (small,  medium,  and  large)
each with  four configurations]  were  used to characterize the  asphalt
roofing industry.  The configurations are:
     1.   Cl  - a  high velocity  air filter  (HVAF)  or an electrostatic
precipitator (ESP) is used to  control saturator and coater emissions, and
an  afterburner  (A/B) is  used to control  asphalt blowing still emissions;
     2.   C2  -  an A/B is  used  to control  saturator and coater emissions,
and an A/B is used to control  asphalt blowing still emissions;
     3.   C3  -  same  as configuration Cl,  except without asphalt blowing
stills; and
     4.   C4  -  same  as configuration C2,  except without asphalt blowing
stills.
     The  model plants are assumed  to be  in  operation  from 0700  to 2300 local
standard  time on  Monday  through Friday, 50 weeks per year.   With  the
exception of mineral products delivery and the blowing stills, emissions
from the stacks  are assumed to be continuous  during their  respective
operating periods.   The  storage tank mist eliminator  is  assumed to  operate
whenever  the plant is not in operation.
      Five regulatory alternatives were  considered  for each  of the four
configurations  of asphalt roofing plants.   As  shown  in Table 7-8,  these
alternatives indicate either  baseline or controlled particulate emission
levels for the various  stacks within  each plant.
      7.1.3.1.2  Meteorological data.   Meteorological  data  required  by the
model  include hourly values  (for an  entire  year) of:
      1.   ambient temperature;
      2.   wind speed;
      3.   wind direction (nearest 10  degrees);  and
      4.   stability class.
 Daily morning and afternoon mixing height data are also required.
      In this study, 1964 climatological data for Pittsburgh, Pennsylvania,
 and Oklahoma  City,  Oklahoma, were used  for comparison purposes.  Both
 data  sets   are  reasonably  consistent  with meteorological   conditions
 representing maximum impact for short stacks.
                                  7-8
-------
          TABLE 7-6.  STACK AND BUILDING COORDINATES AND DIMENSIONS
                              (ALL PLANT SIZES)


                                 (METRIC)
Stack
number
1
2
(HVAF or ESP)
2 (A/B)
3
4
5
Stack
coordinates
X(m)
0
-34
-34
-25
• 25
30
Y(m)
0
-5
-5
-30
-18
8
Stack
height
(m)
6.1
7.6
8.5
9.1
12.8
7.6
Stack
diameter
(m)
0.30
0.91
1 . 22
1.25
0.45
0.43/0.493
Building
dimensions
Height
6.7
6.7
6,7
10.1
12.2
6.7
(m)
Length Width
137
137
137
137
137
137
31
31
31
31
31
31
(ENGLISH)
Stack
number
1
2
(HVAF or ESP)
2 (A/B)
3
4
5
Stack
coordinates
X(ft)
0
-in
-111
-82
82
98
Y(ft)
0
-16.4
-16.4
-98.4
-59
26
Stack
height
(ft)
20
25
28
30
42
25
Stack
diameter
(ft)
1.0
3.0
4.0
4.1
1.5
1.4/1.63
Building
dimensions
Height
22
22
22
33
40
22
Length
450
450
450
450
450
450
(ft)
Width
102
102
102
102
102
102
The first diameter is for small plants; the second is for medium and
large plants.
                                  7-9
-------
        TABLE 7-7.  STACK  EXIT TEMPERATURE, EXIT VELOCITIES, AND
             PARTICULATE EMISSION  RATES  FOR MEDIUM  PLANTS

                                 (METRIC)
Stack
Stack exit
temperature (°K)
number Baseline
1
2
(HVAF
or ESP)
2
(A/B)
3
(Saturant)
3
(Coating)
4
5
344
366
622
472
472
Ambient
Ambient
Controlled
344
311
472
472
472
Ambient
Ambient
Stack
velocity
Baseline
5.83
9.40
8.90
3.65
3.65
6.54
7.00
exit
(m/s)
Controlled
5.83
8.04
6.75
3.65
3.65
6.54
7.00
Parti cul ate
rate3
emission
(Q/s)
Baseline Controlled
0.52
0.68
1.42
10.33
12.71
0.13
0.17
0.010
0.194
0.194
1.850
2.300
0.013
0.017
Instantaneous rates, valid only during periods when equipment is
 operating.
                                  7-10
-------
         TABLE 7-7a.   STACK EXIT TEMPERATURE,  EXIT VELOCITIES,  AND
              PARTICULATE EMISSION RATES FOR MEDIUM PLANTS


                                 (ENGLISH)
Stack exit
Stack temperature (°R)
number Baseline Controlled
1 651 651
2 690 592
(HVAF
or ESP)
2 1,152 882
(A/B)
3 882 882
(Saturant)
3 882 882
(Coating)
4 Ambient Ambient
5 Ambient Ambient
Stack exit Particulate emission
velocity (ft/s) ratea(lb/h)
Baseline Controlled Baseline Controlled
19.11 19.11 4.13 0.079
30.82 26.36 5.40 1.54

29.18 22.13 11,28 1.54
. 12.0 12.0 82.05 14.7
12.0 12.0 101 18.27
21.44 21.44 1.03 0.103
23.0 23.0 1.35 0.135
Instantaneous rates, valid only during periods when equipment is
operating.
                                  7-11
-------
TABLE 7-8   REGULATORY ALTERNATIVES APPLICABLE TO THE TWELVE HYPOTHETICAL
                          ASPHALT ROOFING PLANTS
                                   Emission levels
Regul atory
alternative
Stack
No. 1
Stack
No. 2
Stack
No. 3
Stack
No. 4
Stack
No. 5
     1
     2
     3
     4
     5
Baseline
Controlled
Controlled
Control 1ed
Control1ed
Baseline
Controlled
Controlled
Controlled
Controlled
Baseline     Baseline    Baseline
Baseline     Baseline    Baseline
Controlled   Baseline    Baseline
Baseline     Controlled  Controlled
Controlled   Controlled  Controlled
                                    7-12
-------
      Climatological data  from 1964 were  used  because these  data are
 complete on  an hour-by-hour  basis.   These data are  considered  to be
 meteorologically representative.   The model rejects days  with questionable
 wind directions (which are often associated with light winds).
      7-1.3.1.3  Receptor data.  The model  calculates concentration impacts
 for receptors at specified radial  distances from the source.   Preliminary
 calculations  indicated that maximum  24-hour average ground-level  parti-
 culate concentrations  occured  at downwind  distances of less than  300 meters,
 For modeling purposes, the maximum concentrations  were assumed to occur
 at the property boundary.
      Stack  No.  1 is at the approximate .center  of the  emission  points of
 the model  asphalt roofing plants.   Receptor rings were centered on stack
 No.  1  at distances of 0.34 km (115 ft)  (the property  boundary) and 2 km
 (1.2 mi).   Each ring has receptors at 10 degree intervals for a total of
 36 receptors  per ring.  All receptors were assumed to be  at  the  same
 elevation as  plant  grade.  The only terrain effects  included in the model
 calculations  were  those implicitly contained in the meteorological data.
      7-1-3-2  Twenty-Four  Hour Maximum Concentration Impacts.   The maximum
 24-hour  average ground-level   particulate  concentrations  calculated for
 each  stack  are listed in  Table 7-9 for both  the  baseline and controlled
 emission levels.   The  maximum  24-hour average  ground-level  particulate
 concentrations  which occur at  the  assumed plant boundary (centered  on
 stack  No.  1)  for the  combined emissions  from  medium asphalt  roofing
 plants  are  given in Table  7-10.  The 24-hour average ground-level  parti-
 culate concentration data  are  given for each  regulatory alternative,  each
 stack,  and  for  each  plant configuration.    The modeled concentration
 impacts  can be compared to the National  Ambient Air  Quality Standard
 (NAAQS):
Averaging time
24-hour maximum (not to
be exceeded more than once
per year)
Standard type
   Primary
  Secondary
Particulate concentration
  ng/m3         gr/dscf
   260
   150
1.14xlO-4
0.66xlO-4
     Table 7-11  compares  the  maximum  24-hour average  ground-level
particulate concentrations calculated for the same model  plant located in
                                 7-13
-------
  TABLE 7-9.  CALCULATED MAXIMUM 24-HOUR AVERAGE GROUND-LEVEL
          PARTICULATE  CONCENTRATIONS  FOR THE  INDIVIDUAL
            STACKS  AT  MEDIUM  ASPHALT  ROOFING  PLANTS
                         (METRIC)
 Stack number
                                 Concentration (pg/m )
Baseline
                                   Plant boundary
                                                      Controlled
     1
     2
(HVAF or ESP)
     2
   (A/B)
 40.7
 15.7

  6.67
0.783
7.09

2.32
3
4
5
220 39.6
4.47
7.01
0.447
0.701
(ENGLISH)
Stack number
1
2
(HVAF or ESP)
2
(A/B)
3
4
5
Concentration (Ib/ft
Plant boundary
Baseline
254. 4x1 O"9
98.1X10"11
41. 7x1 O"11
13.8xlO"9
27. 9x1 O"11
43. 8x1 O"11
3)
Controlled
4.9X10"11
44.3X10"11
14.5X10"11
2.5xlO"9
2.8X10-11
4.4X10"11
                               7-14
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TABLE 7-11.   MAXIMUM 24-HOUR AVERAGE PARTICULATE CONCENTRATIONS
              CALCULATED FOR MEDIUM CONFIGURATION C1
        ASPHALT ROOFING PLANTS (REGULATORY ALTERNATIVE 1)
        LOCATED IN THE PITTSBURGH AND OKLAHOMA CITY AREAS

                           (METRIC)
Stack Concentration
"umber Oklahoma City
1 7.47
2 13.1
3 210
4 1.11
5 1.04
All stacks 233
(Mg/m3)
Pittsburgh
0.706
15.1
220
1.71
1.64
239
(ENGLISH)
Stack Concentration
number Oklahoma City
1 46.7xlO~1]
2 81.9X10"11
3 13.1xlO"9
4 6.9X10-11
5 6.5xlO"]1
All stacks 14.6xlO~9
(lb/ft3)
Pittsburgh
4.4X10"11
94. 4x1 O'11
13.8xlO~9
10.7xlO~]1
lO.SxlO"11
15.0xlo"9
                             7-23
-------
the Pittsburgh and Oklahoma City areas.  The maximum 24-hour concentrations
for the two locations are essentially the same because the climatological
conditions were similar for both areas.
     The  maximum  24-hour average particulate concentrations calculated
for the combined stacks of the medium asphalt roofing plants are presented
in Table 7-12 for each regulatory alternative and each plant configuration.
The maximum concentrations- for configurations Cl and C2 are significantly
higher than the corresponding concentrations for configurations C3 and C4
because  the latter  configurations  do  not include blowing stills.  The
results  of the dispersion  modeling indicate that  the  24-hour maximum
concentration  (260  pg/m3) is not exceeded under any of  the control modes,
Regulatory Alternatives 1 through  5.   The  secondary 24-hour  maximum
ambient  air concentration  (150 M9/m3)  would be exceeded by plants controlled
under Regulatory  Alternatives  1, 2, and  4.  The  24-hour  maximum  ambient
air concentration for a plant controlled under  Regulatory Alternative 3
would be  49.1 ug/m3 (S.lxlO9  lb/ft3) and for Regulatory Alternative  5
would be  46 pg/m3   (2.9xl09 lb/ft3).  Regulatory  Alternative  1  is  the
baseline condition (no NSPS),  and Alternatives  2  through  5  show decreases
 in particulate emissions from  the baseline level.   Configuration  Cl  shows
 a decrease in emissions of 4.2  percent for Alternative 2, 80 percent for
 Alternative 3, 5.5 percent for Alternative 4,  and  81  percent  for
 Alternative 5.   Configuration   C2  shows   a  decrease  in  emissions  of
 1.4 percent for Alternative 2,  80  percent for Alternative 3,  2.7 percent
 for  Alternative ^ and  82  percent for Alternative 5.  These results are
 based on  calculations for asphalt  roofing plants assumed to be located in
 the  Pittsburgh, Pennsylvania urban  area.
 7.1.4  Incremental  Impact of Regulatory  Alternatives
      Table 7-13 presents a summary of the annual total particulate emissions
 from the model plants under the various  regulatory alternatives  and also
 shows the percent particulate  emissions  reduction achieved through the
 regulatory alternatives.   It  is readily  apparent that blowing stills  are
 the  largest  source of particulate air pollution  in  the  asphalt  roofing
 industry. Table 7-13 shows that by adding  a mist  eliminator  to the asphalt
 storage  tanks and by improving  saturator and coater control systems
  (Alternative  2,  Configuration 1),  the particulate  emission reduction  from

                                   7-24
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-------
 the baseline  values  averages about 15 percent.  On  the other hand, by
 controlling the  blowing  still  emissions  (Alternative 3,  Configuration  1)
 the average  reduction in  emissions from the  baseline  case is nearly
 88 percent.
      Improvement in emissions control from Alternatives 2 and 3 (Configu-
 ration 2) to  Alternatives 4  and 5 (Configuration 2) is due to equipping
 the materials handling and storage  facility with a baghouse.  For Alter-
 native 5, the most stringent of the regulatory alternatives, the reduction
 in emissions  from the baseline averaged over 90 percent.
 7.2 WATER POLLUTION  IMPACT
     The model plant  designs  under the regulatory alternatives are  equipped
 with a water  spray injection system for cooling the gas streams prior to
 the control device.
     Cooling  of  the  gas  stream is accomplished  by  evaporation  of  the
 water.   About 80 percent of the water is evaporated and the remainder is
 recirculated.   The water-oil  mixture  is  discharged  into a sump and the
 oil  is skimmed off and reclaimed  for use as fuel.   The water from  the
 sump is pumped to the recirculation  tank where fresh water is added to
 replace the water lost by evaporation.  Approximately one percent of the
 recirculated water will have  to  be disposed of  in the  plant's  waste  water
 treatment  system.  The increased quantity of waste water  generated by,the
 adoption  of the  regulatory alternative will  have a  very small  impact.
 7.3  SOLID WASTE  DISPOSAL
     The  type  of  solid waste most  commonly  generated by the control
 devices  is  the particulate  emissions that are  removed by the ESP or  HVAF
 and  baghouse.   The ESP and HVAF  remove solid asphalt particles and liquid
 asphalt  droplets;  the baghouse removes dust particles from the material
 handling and storage  area.   These materials are generally recycled  into
 the  appropriate phase of  the  manufacturing process.   The filter  elements
 from the  HVAF  units  must  be  replaced  when they are  saturated.   Current
practice is to dispose of spent filters in a landfill.  There will  be a
small  increase in waste  filter elements caused by the regulatory alter-
natives.   The  increase in  filter  material to  be disposed cannot be
quantified.  However,  the  impact on  solid waste disposal will be small.
                                 7-27
-------
     The afterburners,  operating at  a  temperature of 760°C (1400°F),
incinerate the particulate hydrocarbon (asphalt) emissions.  Assuming that
the heating value and ash production is similar to No. 6 high sulfur fuel
oil, the quantity of ash generated from a large roofing plant with after-
burners on  its  saturator,  coaters, and blowing  stills  is  approximately
0.2 Mg/yr  (0.24  ton/yr).5   This  ash  is  emitted  as  particulate and is not
collected  as  a  solid waste.  There  should  be  no impact on solid waste
disposal.
7.4  ENERGY IMPACT
     The energy  impact of alternative control  systems and standards can
be assessed by determining  the additional energy consumption requirements
for  the model plants above the  baseline  plant.  The  increases  in energy
requirements  for Regulatory  Alternatives 2 through  5  result from  the
addition of a mist  eliminator with a 5- to  10-hp fan  to  the  asphalt  storage
tanks,  the addition of  a cooling system with two water  pumps  (10  hp) to the
ESP  and HVAF, the increase  of afterburner operating temperatures  from  482°
to  760°C  (900°  to 1400°F),  and the substitution of a  fabric  filter  (baghouse)
for the cyclone in  the material  handling  and storage  area.
7.4.1   Incremental  Impact for Regulatory  Alternatives
     Table 7-14 shows the  electricity  requirements,  over  and above the
baseline electrical demand,  that  are created  by implementing any of the
various regulatory  alternatives.  The  electricity increase  from Alter-
 native 2 to  Alternative 4 and from Alternative  3 to Alternative 5 is due
 to the replacement of the cyclone with a baghouse in  the material  handling
 and storage  area.   The regulatory  alternatives have no impact on the
 electrical requirements  for afterburners.  The  electrical  increases
 created by the regulatory  alternatives constitute only a small  energy
 impact.   For example, the elctricity  requirement of a large  baseline
 roofing plant with ESP is  2.79xl013 J/yr  (7.75xl06 kWh/yr)  (Table 6-3).
 The electrical  increase created by implementing Regulatory Alternatives 4
 or  5  is  0.558x1O10 J/yr  (O.lSxlO6 kWh/yr), which  is  a  2 percent  increase
 over the  baseline  demand.
      For  those  plants that choose to use afterburners  on  their saturator
 and coater and  for those plants with blowing stills, the increase in fuel

                                   7-28
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requirements produced by the increase in afterburner operating temperature
is substantial.  Table 7-15  shows  the annual fuel  requirements for the
different regulatory  alternatives  and plant configurations.  For Alter-
natives 2 and 4, Configuration 1 (unregulated blowing stills), increasing
the operating  temperature  of the afterburner controlling the  saturator
and coater,  increases the  afterburner fuel  requirement  over 49 percent
for a  large plant.   When operating  temperatures  are  increased on both
afterburners  (Alternatives  3 and  5,  Configuration 1),  the afterburner
fuel requirement increases from the  baseline operation by over 60 percent
for a  large plant.
     The  liquid hydrocarbon  particulate  emissions have a  significant
heating value [39,564 J/m3 (142,000 Btu/gal)].   When the blowing  still
afterburner  operating temperature  is increased,  the  large volume of
particulates  incinerated will  supply part  of the  heat required.
     Assuming there  will  be an addition  of three medium plants with
stills,  and  afterburners  controlling the  saturators, the  increase  in
energy from the baseline for Regulatory  Alternative  5  in 1984 will  be:
     1.   natural  gas  -  28.5x1O12 J/yr (2.7xl05  therms/yr);
     2.   oil  - 2,217  m3/yr (14,000 barrels/yr).
This energy increase  is the equivalent of 11,000 m3/yr  (69,000 barrels/yr)
of oil for three medium plants.
     The  1984 increase in  energy for plants using the ESP  or  HVAF  control
device on the saturator and coater will  be:
     1.   natural gas  - 6.4xl012 J/yr (4.9xl05 therms/yr);
      2.   fuel oil - 498 m3/yr (3,100 barrels/yr);
      3.   electricity - 1.26xl012 J/yr (3.7xl05 kWh/yr).
 This  is  equivalent  to  609  m3/yr  (4,320 barrels/yr)  of oil  for  three
 medium plants.
 7.5  OTHER ENVIRONMENTAL IMPACTS
 7.5.1   Noise Impact
      The only  noise-producing additions  that would be made under any of
 the alternatives are the  addition of a  small  water  pump in the ESP or
 HVAF  precooler and the addition of  a  small  fan in the mist eliminator
 system on the  asphalt storage tanks.
                                   7-30
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                                                                     7-31
-------
     It is  not  expected that these changes to  the  baseline plant will
provide any  significant additional  noise to the existing levels in the
plants.
7.6  OTHER ENVIRONMENTAL CONCERNS
7.6.1  Irreversible and Irretrievable Commitment of Resources
     One  option of the regulatory  alternatives  entails  an  increase in
operating  temperature  of afterburners  which  increases  their fuel
consumption,  and this  option  must be viewed  as the irreversible and
irretrievable  commitment of a resource.  It  should  be  noted that no
alternative  control  system for blowing  stills,  other than afterburners,
was  considered.
                                  7-32
-------
7.7  REFERENCES FOR CHAPTER 7

 1.  Particulate and Gaseous  Emissions  from  the  Asphalt Roofing Process
     Saturator at the  CertainTeed  Products Plant, Shakopee, Minnesota.

     EPA*76-ARM-12?ntMay ^ection Agency'  Research Triangle Park, N.C.


 2.  Particulate and Gaseous  Emissions  from  the  Asphalt Roofing  Process
     Blowing Still  at  the  Elk  Roofing Plant,  Stephens,  Arkansas

     EPA-76-A^lTXP^t10n  ^^   ReS6arCh Tn'an9le PSrk' N'C-
 3.   Dispersion  Model  Analysis of the Air Quality Impact of Particulate
     Anln^°nSpfr°m  W3!*  R?ofin9  Plants-   U-S-  Environmental  Protection
     Agency.   Research  Triangle  Park,  N.C.   EPA 68-02-3323.   February 1980.

 4.   Industrial  Source  Complex  (ISC)  Dispersion  Model Users  Guide
     II.S   hm/1 V>nnmalrt- = l  D „, ^ 4-,-, ~ 4--•	n	  ^      ,  _  .   _      viiv^v.
Chem1cal
                                                        '  Handbook.   4th  ed.
                                 7-33
-------
-------
                              8.  ECONOMIC IMPACT

      This chapter contains three sections:  (1) industry characterization;
 (2) cost analysis of regulatory alternatives; and (3) other cost consider-
 ations.   The  first section  describes  the asphalt  roofing industry's
 products, production  plants, production  output,  industry employment,
 product markets  and sales,  product prices,  and historical and future
 trends of various  aspects  of the industry.   The second section analyzes
 the capital  and  annual  operating costs and  cost effectiveness of  parti-
 culate pollution control devices installed in new facilities  and modified/
 reconstructed  facilities  for six configurations  of  three model plant
 sizes  for each  of the  five  regulatory options.   The third  section
 summarizes  the costs of other  environmental  regulatory requirements on
 facilities  in  the industry and discusses the impacts of standards  on the
 budgets  and resources of  various regulatory and  enforcement  agencies.
 8.1  INDUSTRY  CHARACTERIZATION
     The  asphalt roofing industry began in this country in 1893 and has
 grown  until  it now supplies  over 80 percent  of the roofing applied in
 this country.   The industry is  comprised of  a group  of 118 manufacturing
 plants  scattered throughout  the United States.   These plants  produce
 asphalt roofing  and siding shingles,  asphalt  roofing  and  siding rolls,
 and saturated  felts.  There are  also 42 plants that blow asphalt and sell
 saturant  and coating asphalt to asphalt  roofing  plants;  17  of these
 blowing still  installations are  at oil  refineries.
8.1.1  General  Profile
     The description of  the industry presented  in  this  section  discusses
the following characteristics of the industry:  (1) products,  (2) produc-
tion plants,  (3) asphalt and product production, (4) industry employment,
(5) product markets, (6) product prices, and (7) historical and future
trends.  Each of these topics  is discussed  below.

                                8-1
-------
     8.1.1.1  Raw Materials and Products.  The  basic raw materials and
intermediate products  used  in the asphalt roofing  industry  to produce
roofing and siding  products  are:   (1) dry felts and fiber  glass  mats,
(2) asphalt, (3) mineral  stabilizers, and (4)  fine  and coarse mineral
surfacings.  Figure 8-1  shows  these raw  materials and  intermediate
products and their relationship to the finished products.
     Dry felt  is  made from various  combinations of rags, paper fibers,
wood  fibers,  and other cellulose  fibers  which  are  blended to  form  an
acceptable  felt for  roofing  products.   The  felt  is made from fibers
prepared  by various  pulping  methods similar to papermaking processes.
Fiber  glass mats are produced from thin glass fibers bonded with  plastic
binders.   Some roofing plants produce  their  own dry felt,  while  others
purchase  the dry  felt or  fiber  glass  mats from other manufacturers.
      Asphalt is used to preserve,  waterproof, and  increase  the durability
and usefulness of  roofing  and  siding products.  The asphalt used in the
 industry  is divided  into  saturant and  coating asphalt  and  is produced
 from asphalt flux,  a product of the fractional  distillation of crude oil.
 Some roofing manufacturers produce their own saturant and coating asphalts
 from the flux  while  others purchase the prepared asphalt from  refineries
 or asphalt processors.   The  asphalt is prepared by blowing air  through
 the hot  flux   to raise the temperature at which it will  soften.  The
 softening point of saturant  asphalt is between 40.55°C (105°F) and 74°C
 (165°F) and runs as  high as  127°C (260°F) for coating asphalt.   Tables 8-1
 through 8-3a  list the ASTM  specifications  for roll roofing saturants,
 shingle saturants, and coating asphalt, respectively.
      Coating  asphalt  is  usually  stabilized by adding finely divided
 minerals to make the asphalt more shatter- and shock-proof  in  cold weather
 and  more  resistant to weathering.   Typical  mineral stabilizers  include
 talc,  silica,  dolomite, slate dust, trap rock, and micaceous  materials.
       Fine  mineral  surfacing materials,  primarily  talc and  sand,  are
 dusted:   (1)  on the  back  of shingles  to prevent them  from  sticking  to
 each  other;  (2) on  the  back of  mineral-surfaced  roll  roofing to prevent
 the convolutions of  the roll from  sticking together; and (3) on surfaces
 of smooth roll roofing  to prevent sticking.  These materials adhere to
 the product during storage and handling.

                                  8-2
-------
            PRIMARY
            PROCESSING
           SECONDARY
           PROCESSING
    RAW
 MATERIALS
   RAGS
   PAPER
 ASBESTOS
   WOOD
   FIBER
FIBER GLASS
    MAT
 ASPHALT
  FLUX
 MINERAL
STABILIZER
   FINE
SURFACING
 COLORED
 GRANULES
  INTER-
 MEDIATE
PRODUCTS
t
 FINISHED
PRODUCTS
                    SATURATED
                       FELT
                     SMOOTH
                      ROLL
                     ROOFING
                    SURFACED
                    PRODUCTS
         SURFACED
          ROLLS
                                                                 SIDINGS
                                                                 STRIP
                                                                SHINGLES
                                                               INDIVIDUAL
                                                                SHINGLES
    Figure 8-1.  Processing chart for asphalt roofing  products
           from raw materials to finished  roofing."    products'
                                   8-3
-------
TABLE 8-1.  ASTM SPECIFICATIONS FOR ROLL ROOFING SATURANTS (METRIC)'
             Characteristics
    ASTM
 Specifications
Specific gravity at 15.55°C
Softening point (R and B) °C
Penetration at
   0°C,  200 g, 60 s
   25°C, 100 g,  5 s
Flash point  (C.O.C.)  °C
Loss in 5 h  at  162.8°C  (50g)
Loss in penetration after heating
 Soluble in  carbon  tetrachloride
 Viscosity,  Saybolt Furol, at
   121°C
   149°C
   177°C
   204°C
 Foam test, seconds for first clear spot
 Compatibility with coating at 54°C for 72 h
 Oliensis heterogeneity, test for 24 h
 0.99 -  1.035
40.55 » 46.1

    30 up
   90 - 150
   232 up
  Below 1%
  Below 20%
  Over 99%

  Under 350
  Under 100
  Under   40

  Under 300
   Under  1.5  mm
   Negative
                                  8-4
-------
TABLE 8-la.  ASTM SPECIFICATIONS FOR ROLL ROOFING SATURANTS (ENGLISH)3
             Characteristics
    ASTM
Specifications
Specific gravity at 60°F
Softening point (R and B) °F
Penetration at
  32°F, 0.44 Ib, 60 s
  77°F, 0.22 15, 5 s
Flash point (C.O.C.) °F
Loss in 5 h at 325°F (0.11  Ib)
Loss in penetration after heating
Soluble in carbon tetrachloride
Viscosity, Saybolt Furol, at
  250°F
  300 °F
  350°F
  400 °F
Foam test, seconds for first clear spot
Compatibility with coating  at 130°F for 72 h
Oliensis heterogeneity, test for 24 h
0.99 - 1.035
 105 - 115

   30 up
  90 - 150
  450 up
 Below 1%
 Below 20%
 Over 99%

 Under 350
 Under 100
 Under  40

 Under 300
 Under 0.55 in.
 Negative
                                8-5
-------
 TABLE 8-2.   ASTM SPECIFICATIONS FOR SHINGLE  SATURANTS  (METRIC)'
           Characteristics
    ASTM
Specifications
Specific gravity at 15.55°C
Softening point (R and B) °C
Penetration at
  0°C, 200 g, 60 s
  25°C, TOO g, 5 s
  46°C, 50 g, 5 s
Ductility at 25°C
Flash point (C.O.C.) °C
Loss in 5 h at 163°C (50g)
Loss in penetration after heating
Soluble in carbon tetrachloride
Viscosity at
  177°C
  204°C
  232°C
 Foam test,  seconds  for first clear spot
 Compatibility with  coating  at 54°C for 72 h
 Oliensis  heterogeneity,  test for 24 h
 1.0 - 1.04
  63 - 74

   10 up
  25 - 40
 Under 115
 10 cm up
  246 up
 Under 0.5%
 Under 20%
 Over 99%

 Under 140 Furol
 Under   60 Furol
 Under   30 Furol
 Under 300
 Under 0.3 mm
    Negative
                                   8-6
-------
  TABLE 8-2a.   ASTM SPECIFICATIONS FOR SHINGLE  SATURANTS  (ENGLISH)3
            Characteristics
    ASTM
Specifications
 Specific  gravity  at  60°F
 Softening point (R and  B)  °F
 Penetration  at
   32°F, 0.44 Ib,  60  s
   77°F, 0.22 Ib,  5 s
   115°F,  0.11. Ib, 5  s
 Ductility at 77°F
 Flash point  (C.O.C.) °F
 Loss in 5 h  at 325°F (0.11 Ib)
 Loss in penetration after heating
 Soluble in carbon tetrachloride
 Viscosity at
 350°F
 400°F
 450° F
 Foam test, seconds for first clear spot
Compatibility with coating at 130°F for 72 h
Oliensis  heterogeneity,  test for 24 h
 1.0 - 1.04
 145 - 165

   10 up
  25 - 40
 Under 115
  3.94 in.
  475 up
 Under 0.5%
 Under 20%
 Over 99%

 Under 140  Furol
 Under  60  Furol
 Under  30  Furol
 Under 300
 Under 0.012 in.
  Negative
                                 8-7
-------
   TABLE 8-3.   ASTM  SPECIFICATIONS  FOR  COATING ASPHALTS (METRIC)'
           Characteristics
    ASTM
Specifications
Specific gravity at 15.55°C
Softening point (R and B) °C
Penetration at
  0°C, 200 g, 60 s
  25°C, TOO g, 5 s
  46°C, 50 g, 5 s
Ductility at 25°C
Flash point (C.O.C.) °C
Loss  in 5 h at  163°C (50g)
Loss  in penetration after  heating
Impact at 4.4°C (cm)
Pliability  at 4.4°C
Soluble  in  carbon tetrachloride, %
Stain test,  54°C, 5  days
Viscosity,  Stormer 100 g,  100 rev/s at
  191°C
  204°C
  218°C
  232°C
 Compatibility with coating at 54°C for 72 h
   Roll saturant
   Shingle saturant
 1.005 - 1.045
   102 - 116

     10 up
    18 - 22
   Under 45
   Over 2.5 cm
   Over 246
   Under 0.5%
   Under 20%
   Over 5.08  cm
    Under 3-1/2
     Under  1.5 mm
     Under  3  mm
                                  8-8
-------
        TABLE 8-3a.   ASTM SPECIFICATIONS  FOR  COATING ASPHALTS  (ENGLISH):
          Characteristics
    ASTM
specifications
 Specific  gravity at 60°F
 Softening point (R and B) °F
 Penetration at:
  32°F, 0.44  Ib, 60 s
  77°F, 0.22  Ib, 5 s
  115°F,  0.11 lb, 5 s
 Ductility at  77°F
 Flash point (C.O.C.) °F
 Loss in 5 h at 325°F (0.11 Ib)
 Loss in penetration after heating
 Impact at 40°F (in.)
 Pliability at 40°F
 Soluble in carbon tetrachloride, %
 Stain test,  130°F,  5 days
Viscosity, storraer 0.22 Ib.,  100 rev/s at:
  375°F
  400°F
  425°F
  450°F
Compatibility with  saturants  at 130°F for 72 h
  Roll  saturant
  Shingle saturant
1.005 - 1.045
  215 - 240

   10 up
   18 - 22
 Under 45
 Over 1.0  in.
 Over 475°F
 Under 0.05%
 Under 20%
 Over 2 in.
Under 3-1/2
Under 0.059 in.
Under 0.118 in.
                                 8-9
-------
     Coarse minerals  or granules are  applied to surfaced products to
protect the asphalt  coating,  increase fire resistance, and impart color
to the product.   The granules typically used  for mineral  surfacing are
natural rock  granules,  rock granules colored  by a  ceramic process,  or
naturally colored slate.
     The asphalt  roofing industry produces three basic groups  of  roofing
and  siding products:   (1)  saturated felts, (2) roll  roofing  and  roll
siding, and  (3) roofing and siding  shingles.   Products which are  typical
of these three  groups are shown and  described  in Tables 8-4  and 8-4a, and
typical compositions of these products are given in Tables 8-5 and 8-5a.
     Saturated  felts may be  impregnated with  either saturant  asphalt or
coal  tar.   Currently about 95 percent of  saturated felts are produced
with  asphalt and about  5 percent are  produced with coal  tar.  Asphalt
saturated  felts  are used as underlayment  for shingles,  for sheathing
paper,  and for laminations in the construction of built-up roofs.  These
products  are made in different weights,  the most common  being No.  15,
which  weighs approximately 6.8 kg  (15 Ib)  per square, and No.  30, which
weighs about 13.6 kg (30 Ib) per square.*  Coal tar saturated felts  are
 used for  pipe wrapping.
      Roll  roofing is prepared by adding a stabilized coating of  asphalt
 to a dry  felt which has first been  impregnated with a saturant asphalt or
 by adding a  stabilized  coating  asphalt to a  fiber  glass  mat, in which
 case the  stabilized coating  is  used to both  saturate and coat the mat.
 Roll roofings  can  be surfaced with mineral  granules  to  produce  a wide
 range of  colors.   Some styles are  furnished  in split rolls designed to
 give an edge pattern when applied  to  the roof.  Mineral-surfaced rolls
 are also embossed to simulate brick or stone  for use  as sidings.
      Shingles  are made  by  adding a  coating of stabilized  asphalt to a dry
 felt web  which has  first been impregnated with  a saturant asphalt,  or to
 a fiber  glass  mat.   Mineral granules  are then  added, a  strip of sealer
 asphalt may  be applied, and  the  web is cut into shingles.   The most popular
 shingle is a nominal 106.6-kg (235-lb), 3-tab,  self-sealing strip shingle.
 This  shingle is  shown  in Figure  8-2.
  *A square (sq) is the amount of material which, when applied, will  cover
  9'.29 m2  (100 ft2)  of surface.
                                  8-10
-------
  TABL£ 8-4.   TYPICAL ASPHALT ROOFING PRODUCTS (METRIC)
PRODUCT 1
1
WUnnfKT
ffl
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3
2




2

4


2



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square

S
80
80

86
80




80

226


113



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square
CO
6
.91
.91

.91
.41




.41

1


.41



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41




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E
t£
a
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Q.
H
_, ,_ JJ?J?i: 5*4 '® ®^^ *JP '^ 8 COLUMNS ARRANGED TO SHOW IMPORTAWT rHWAQA^-recs»c.-f-,^« ^^
THE PRODUCT, AS FOLLOWS' ^ *-*-^ w v»nv^¥v iiwr-un i MM i unARACTERiSTICS OF
COLUMN 1 - NAME OF PRODUCT
COLUMN 2 - APPROXIMATE SHJPP.NG WEIGHT °P°NE SQUARE OF PRODUCT. A SQUARE
 COLUMN 3  - APPROXIMATE AREA OF ONE SQUARE
' COLUMN 4  - NUMBER OF PACKAGES REQUIRED TO COVER ONE SQUARE
 COLUMN 5  - NUMBER OF SHINGLES REQUIRED TO COVER ONE SQUARE
 COLUMNS 6&7- LENGTH AND WIDTH OF ONE PACKAGE OR ONE SHINGLE
 C°LUMN 8  - AMOUNT OF OVERLAP FROM ONE COURSE TO THE NEXT (SEE F.GURE BELOW)
.Z//Z2
77/T/77/V777&7/
                              77/77777
                                s-n
-------
    TABLE 8-4a.   TYPICAL  ASPHALT ROOFING PRODUCTS'(ENGLISH)
PRODUCT
i
i
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1
    TABLE 8-4B IS SET UP IN 8 COLUMNS ARRANGED TO SHOW IMPORTANT CHARACTERISTICS OF
THE PRODUCT. AS FOLLOWS:1*
    COLUMN 1  - NAME OF PRODUCT
    COLUMN 2  - APPROXIMATE SHIPPING WEIGHT OF ONE SQUARE OF PRODUCT, A SQUARE
    COLUMN 2   ^{^THE AMOUNT OF MATERIAL WHICH. WHEN JNSTALLED, WILL COVER
               100 SQUARE FEET OF SURFACE
    COLUMN 3  - APPROXIMATE AREA OF ONE SQUARE
    COLUMN 4  - NUMBER OF PACKAGES REQUIRED ™ COVER ONE SOUARE
    COLUMN 5  - NUMBER OF SHINGLES REQUIRED TO COVER ONE SQUARE
    COLUMNS 6&7- LENGTH AND WIDTH OF ONE PACKAGE OR ONE SHINGLE
    COLUMN 8  - AMOUNT OF OVERLAP FROM ONE COURSE TO THE NEXT (SEE FIGURE BELOW)

Mil
mm*.
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31.44 cm
{36 in.)

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                   , GRANULE SURFACING^
                ^PARTING AGENT SURFACING^
                   SHINGLE CROSS-SECTION
Figure 8-2.   106.6-kg (235-lb), 3-tab self-seal  strip shingle.'
                                       8-15
-------
     In addition to the basic products given above,  a variety of specialty
asphalt coatings  and cements are made  from asphalt by adding special
ingredients, by  mixing with suitable solvents, or  by emulsifying  with
water.                                                  8
     Asphalt coatings and cements can be categorized as:
     1.  plastic asphalt cements;
     2.  lap cements;
     3.  quick-setting asphalt adhesives;
     4.  roof coatings;
     5.  asphalt water emulsions; and
     6.  asphalt primers.
 Few roofing plants make these specialty  products  and details of their
 preparation were  not investigated in this  study.
      8.1.1.2    Production  Plants.   The individual  asphalt roofing manu-
 facturing  plants  are described with the information available with respect
 to the following characteristics:    (1) location and ownership,  (2) plant
 age, and (3)  plant production capacity.
      8.1.1.2.1   Plant location and ownership.  The Asphalt Roofing Manu-
 facturers Association (ARMA) provided the name and location  of  117 asphalt
 roofing manufacturing plants in the United States.  They reported that
 109 were members of the association in 1978.  The name and location of the
 asphalt  roofing plant  not  a  member  of  ARMA was  obtained from a
 manufacturer of electrostatic precipitators.  The information was verified
 by  calling the  plant owner.  These plants were owned by 31  companies  and
 were scattered throughout the country.  Table 8-6 lists the locations and
 company ownership of the 118 asphalt roofing plants  in the United States.
 Figure 8-3 shows the plant  locations.
      About 30 percent of  the plants are  located in  three states (Calif-
 ornia,  Texas,  and Illinois), and most of the plants are  located in  urban
 areas.   The companies  which own  the  plants  vary  greatly in size and
 diversity of products.   Some of the companies  produce their own felts,
 about  one-third of the companies  process their  own asphalt,  and one
 company owns its own asphalt refinery.   Ten of the  firms  are  publicly
 owned  and listed on the New York,  American, or regional  stock exchanges.
                                  8-16
-------
                  TABLE 8-6.   ASPHALT ROOFING MANUFACTURERS9
Company and headquarters
location
Allied Materials Corporation
Stroud, Oklahoma
Asphalt Products Industries9
Auburn, Washington
Bear Brand Roofing, Inc.
Bearden, Arkansas
Big Chief Roofing Company
Ardmore, Oklahoma
Bird and Sons, Inc.
No. of
plants
1
1
1
1
9
Plant locations
Stroud, OK
Auburn, WA
Bearden, AR
Ardmore, OK
Charleston, SC: Chicago, IL;
  East Wai pole, Massachusetts
The Celotex Corporation
  Tampa, Florida
13
CertainTeed Corporation           10
  Valley Forge, Pennsylvania
Congo!eum-Nair, Inc.               1
  Cedarhusrt, Maryland

Consolidated Fiberglass            1
  Bakersfield, California

Daingerfield Manufacturing Company 1
  Daingerfield, Texas
Delta Roofing Mills
  Slidell, Louisiana
 1
 Franklin, OH; Martinez, CA;
 Norwood, MA; Perth Amboy, NJ;
 Portland, OR; Shreveport, LA;
 Wilmington, CA

 San Antonio, TX; Camden, AR;
 Houston, TX; Cincinnati, OH;
 Memphis, TN; Perth Amboy, NJ;
 Goldsboro, NC; Chester, WV;
 Chicago, IL; Wilmington, IL;
 Philadelphia, PA; Birmingham,
 AL; Los Angeles, CA

Avery, OH; Chicago Hgts., IL;
 Kansas City, MO; Dallas, TX;
 Oxford, NC; Richmond, CA;
 Shakopee, NM; Savannah, GA;
Tacoma, WA; York, PA

 Cedarhurst, MD
Bakersfield, CA


Daingerfield, TX


Slidell, LA
                                  8-17
-------
                 TABLE 8-6.   ASPHALT ROOFING MANUFACTURERS'
                              (continued)
Company and headquarters
        location
No. of
plants
Plant locations
Elk Corporation
  Stephens, Arkansas

The Flintkote Company
  Stamford, Connecticut
G A F Corporation
  New York, New York
Gate Roofing Company
  Green Cove Springs,  Florida

Georgia Pacific
  Portland, Oregon

Globe  Industries, Inc.
  Chicago,  Illinois

Johns-Manville Corporation
  Denver,  Colorado
 Koppers Company
   Pittsburgh,  Pennsylvania

 Lunday-Thagard Oil  Company
   South Gate,  California

 Herbert Malarkey Roofing Company
   Portland, Oregon

 Masonite Corporation
   Meridian, Mississippi
  2       Stephens, AR; Tuscaloosa,  AL
  7       Peachtree City, GA; Jersey
          City, NJ; Ennis, TX; Chicago
          Hgts., IL; Los Angeles, CA;
          St. Paul, NM; Portland, OR

 13       Baltimore, MD; Dallas, TX;
          Denver, CO; Erie, PA;
          Joliet, IL; Kansas City, MO;
          Millis, MA; Minneapolis, MN;
          Mobile, AL; Mount Vernon, IL;
          Savannah, GA; Tampa, FL;
          South Bound Brook, NJ

  1       Green Cove Springs, Fl
   3       Hampton, GA; Franklin, OH;
          Quakertown, PA

   1       Whiting, IN
   7        Fort Worth, TX; Marrero, LA;
           Manville,  NJ;  Savannah, GA;
           Pittsburg, CA; Waukegan, IL;
           Los Angeles, CA

   3        Chicago,  IL; Woodward, AL;
           Youngstown, OH

   1        South  Gate, CA
   1        Portland,  OR
   2       Meridian,  MS;  Little Rock,  AR
                                   8-18
-------
                 TABLE 8-6.  ASPHALT ROOFING MANUFACTURERS9
                                 (concluded)
Company and Headquarters
        lodation
No. of
plants
                                                  Plant locations
Nical, Inc.
  Hollister, California

Owens-Corning Fiberglas
  Corporation, Toledo, Ohio
   2       Albuquerque,  NM; Hollister, CA
  26       Atlanta,  GA; Brookville,  IN;
           Compton,  CA; Denver,  CO;
           Detroit,  MI; Hazelwood, MO;
           Houston,  TX; Irving,  TX;
           Kansas  City, KS;  Medina,  OH;
           Kearney,  NJ; Lubbock,  TX;
           Memphis,  TN; Ft.  Lauderdale,
           FL;  Jacksonville,  FL;
           Minneapolis, MN;
           Morehead  City,  NC;  North
           Kansas  City, MO;  Oklahoma
           City, OK;  Portland, OR;
           San  Leandro,  CA;  Santa Clara,
           CA;  Summit,  IL; Waltham, MA;
           Woods Cross,  UT; Jessup, MD
Prairie States Roofing
Joliet, Illinois
Richards Oil Company
Savage, Minnesota
Tamko Asphalt Products, Inc.
Joplin, Missouri
TARCO
North Little Rock, Arkansas
Tilo Company, Inc.
Stratford, Connecticut
United States Gypsum Company
Chicago, Illinois
Warrior Roofing
Tuscalosa, Alabama
1
1
3
1
1
1
1
Joliet, IL
Savage, MN
Joplin, MO; Phillipsburg, KS;
Tuscaloosa, AL
North Little Rock, AK
Stratford, CT
South Gate, CA
Tuscalosa, AL
Company name not furnished by the Association; company name and location
obtained from a manufacturer of electrostatic precipitators.  Verified
by calling plant owner.
                                 8-19
-------
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      8-1-1-2.2  Plant age.   No data are  available  on  the  age of  individual
 plants in the asphalt roofing and siding products  industry.  Data published
 by the Department of Commerce,  Bureau  of the  Census,  provide some insight
 into the  approximate  ages of  plants  in the industry.  The Census of
 Manufacturers  reports  in  1954,  1958, 1963,  1967, and  1972  showed that the
 asphalt and tar roofing and siding products industry  was  composed of  the
 following number of  plants:
                          Year
                          1954
                          1958
                          1963
                          1967
                          1972
                          1977
No. of plants
      116
      109
      113
      100
      102
      110
     These  data show that the number of plants in the industry declined

between  1954 and 1967.   The number of plants increased from 100 in 1967

to  110  in 1977.  During the 24-year  period  1954  through  1977  the  least
number of plants in operation in the census years was 100.

     Since there are no data for years between the censuses and no infor-

mation on  the number of new plants built  or plant closures, the age of
the  110  plants  in  operation  in 1977 can only be estimated.  If we  assume
that during  periods  of  decline (1954  through 1958 and 1963 through 1967)
no  new  plants were built, and assume  that during periods of  increase

(1958 through 1963 and 1967 through 1977)  about 2 percent of the existing
plants were  closed  and  were replaced by new plants,  and  attribute the

actual increase  in  the  number  of plants to new plant construction, then
the 110  plants  existing in 1977 would have the following estimated ages:
                         Age
                    Over 20 years
                    10 to 20 years
                    Under 10 years
No.  of plants
     90
      5
     15
     8-1.1.2.3  Plant production capacities.  Asphalt roofing production
capacity figures are  not  disclosed for the industry or  for  individual

plants.  Table 8-7 shows the shipments, by region,  for  individual  products
in 1977 and  the  number of plants in each region.   The  table  can also be
used to show the relative capacities of plants in  each  region for produc-
tion of specific products.   It is important to note that  the data in

Table  8-7  are  aggregate data,  and no  information  can  be deduced from
                                8-21
-------





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-------
 these data for  individual  plants.   For example, a  region  may have two
 large plants which  tend  to distort the data to indicate that plants in
 that region are larger than plants in another region, while the opposite
 may be the actual  case.
      The data in Table 8-7 indicate that 12 percent of the plants are in
 the Northeast;  26 percent in the North Central region; 40 percent in the
 South;  and 22 percent in the West.   The Northeast produced 18 percent of
 the asphalt roofing products in  1977;  the  North Central  region  produced
 32 percent;  the  South produced  34 percent;  and  the West produced
 16 percent.   The South and North Central regions have larger  production
 capacities than  do the other two  regions,  and the  ratio of production
 quantities to the number of plants  is  highest for  the Northeast region
 and lowest for the West.
      Half  of  the production of individual  shingles  occurs  in  the North
 Central  region -and another  33 percent occurs in the  West.   Strip shingles
 are produced  primarily  (70.7 percent)  in  the North Central and South
 regions. Smooth-surfaced  and mineral-surfaced  roll  roofing  and cap sheet
 comprise  from 18 to 30 percent of the U.S. total  production  in each
 region.
      8.1.1.3  Asphalt  and Asphalt Product Production.  The  production of
 asphalt  roofing  products  depends  upon the manufacture  of  asphalt flux at
 petroleum  refineries and  the  processing of the  flux into saturant and
 coating  asphalt  by  the  petroleum refineries, asphalt processors, or
 asphalt roofing manufacturing plants.  Since the asphalt roofing industry
 is  dependent  on  the petroleum  refining  industry for this  primary  raw
 material, a brief discussion of the asphalt production industry is included
 in  this  section.   Following the discussion on asphalt production, the
 production  of  products in  the  asphalt  roofing industry is presented.
     8-1.1.3.1  Asphalt  production.   The production of asphalt  in the
United States increased from 21,573,000 m3  (135,691,000 barrels) in 1969
to  26,691,000m3 (167,884,000 barrels)  in   1973;  then declined to
22,211,000 m3 (139,706,000 barrels) by  1976; and rose to 24,493,000 m3
 (154,058,000 barrels) in 1977 as  shown  in  Tables 8-8  and 8-8a.   These
increases and decreases in asphalt production were in direct response to
the U.S. consumption of asphalt each year,  since exports were negligible
                                8-23
-------
TABLE 8-8.  ANNUAL U.S. PRODUCTION, CONSUMPTION, IMPORTS, EXPORTS,
            AND STOCK OF ASPHALT, 1969-197716»17
                (Thousands of m3 of asphalt)
Year
1977
1976
1975
1974
1973
1972
1971
1970
1969
U.S.
production
24,493
22,211
22,887
26,112
26,691
24,690
24,967
23,317
21 ,573
Imports
238
621
788
1,789
1,342
1,473
1,147
986
757
U.S.
consumption
24,808
23,333
23,432
26,826
29,031
26,040
25,204
24,401
22,781
Exports
35
42
51
65
54
53
49
57
74
End-of-year
stock
2,968
3,080
3,624
3,398
2,389
3,440
3,371
2,509
2,664
                               8-24
-------
TABLE 8-8a.   ANNUAL U.S.  PRODUCTION, CONSUMPTION, IMPORTS,  EXPORTS
            AND STOCK OF ASPHALT, 1969-197716.17
              (Thousands of barrels of asphalt)
Year
1977
1976
1975
1974
1973
1972
1971
1970
1969
U.S.
production
154,058
139,706
143,957
164,237
167,884
155,294
157,039
146,658
135,691
Imports
1 ,498
3,905
4,956
11,252
8,444
9,263
7,216
6,201
4,761
U.S.
consumption
156,039
146,763
147,384
168,733
182,602
163,788
158,526
153,477
143,290
Exports
223
267
320
410
340
333
306
356
464
End-of-year
stock
18,669
19,375
22,794
21,370
15,024
21,638
21,202
15,779
16,753
                             8-25
-------
and imports varied  to  meet short-term demand which domestic production
failed to provide.
     Most asphalt is produced  at petroleum refineries  as  a residual
product of the refining processes.  The refineries can adjust the process
to obtain larger  or smaller quantities of asphalt as needed.  The residual
product  is  used in  coking operations,  in  the production  of  residual fuel
oils  and as refinery fuel, as  well  as for the manufacture of asphalt.
      The demand for asphalt depends predominantly on  the paving market
and on the  asphalt  roofing industry  to a  lesser extent.   In recent years,
80 percent  of asphalt was  used to pave roads, 15 percent was  used  in
asphalt  roofing, and  5  percent was  used for miscellaneous purposes.
Asphalt  consumption increased  by about 780,000 Mg/yr  (860,000 tons/yr) in
the  1960's- 698,000 Mg/yr (770,000 tons/yr) for paving;  and 62,000 Mg/yr
                                      14
 (68,000  tons/yr) for asphalt roofing.
      During the  early 1970's,  asphalt consumption continued to increase,
 reaching the highest  level in 1973.  The price  of crude oil  and asphalt
 rose dramatically  in  1974 due to the oil embargo of  the Organization  of
 Petroleum Exporting Countries  (OPEC)  and the demand for asphalt fell for
 that year,  for  1975, and for  1976.  The  fall  in consumption can be
 explained  by  the facts that  consumer funds  for home construction and
 government funds for road construction remained almost constant while the
 price of asphalt rose dramatically.
      The capacity to produce asphalt was available at 104 of the nation's
 285  refineries  as  of January  1, 1978, and the reported capacity for the
 industry was  122,890 m3 per stream day  (772,957  barrels per stream day),
 as  shown in Table 8-9.    These  104  refineries are owned by 58 companies;
 the  20  largest firms  in  terms  of asphalt production capacity are shown  in
 Table 8-10.  The largest,  the  Exxon Corporation,  controls  13.2  percent  of
 the  asphalt production capacity  in  the  U.S.; the five  largest  companies
 control 48.6 percent of the asphalt capacity; and the 20 largest control
 80.5 percent of the production capacity.
      8.1.1.3.2  Asphalt Product Production.   Shipments  of  all  asphalt and
 tar roofing and siding  products totaled 8.6 million  Mg  (9.5 million tons)
  in  1977, the  most recent year for which data are available.  The total
                                  8-26
-------
TABLE 8-9.   U.S.  DISTRIBUTION OF ASPHALT
     PRODUCTION CAPACITY, BY STATEa 15
No. of
State refineries
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Delaware
Florida
Georgia
Hawai i
Illinois
Indiana
Kansas
Kentucky
Louisiana
Maryland
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
6
4
1
4
40
3
1
1
2
2
12
7
11
4
23
2
6
3
5
1
7
1
1
1
4
8
2
1
3
Refineries
producing
asphalt
3
1
1
3
13
1
0
0
2
1
5
4
5
2
5
2
1
2
3
1
4
0
0
0
2
1
2
0
0
Asphalt
m3 per
stream day
2,067
48
238
1,351
12,218
525
0
0
2,067
207
8,236
9,285
2,830
3,736
9,523
3,450
1,375
7,790
1,517
1,033
3,863
0
0
0
12,401
111
2,862
0
0
J3 reduction
capacity
Percent
Barrels per of crude
stream day capacity
13,000
300
1,500
8,500
76,850
3,300
0
0
13,000
1,300
51,800
58,400
17,800
23,500
59,900
21,700
8,650
49,000
9,540
6,500
24,300
0
0
0
78,000
700
18,000
0
0
11.2
0.3
23.7
13.2
3.1
4.8
0.0
0.0
59.1
1.2
4.2
9.5
3.8
13.6
2.8
69.5
5.7
21.8
2.8
6.1
14.7
0.0
0.0
0.0
11.5
0.6
16.4
0.0
0.0
                8-27
-------
                 TABLE 8-9.   U.S.  DISTRIBUTION OF  ASPHALT
                      PRODUCTION CAPACITY,  BY STATE   15
                               (concluded)
No. of
State refineries
Ohio
Oklahoma
Oregon
Pennsylvania
Tennessee
Texas
Utah
Virginia
Washington
West Virginia
Wisconsin
Wyoming
Total
7
12
1
10
1
53
9
1
8
3
1
13
285
Refineries
produci ng
asphalt
6
8
1
3
1
11
1
0
2
0
1
6
104
Asphalt
ms per
stream day
5,406
5,247
1,367
6,677
1,272
10,223
350
0
1,113
0
2,146
. 2,356
122,890
production capacity
Barrels per
stream day
34,000
33,000
8,600
42,000
8,000
64,300
2,200
0
7,000
0
13,500
14,817
772,957
Percent
of crude
capacity
5.5
5.8
58.4
5.0
17.9
1.3
1.3
0.0
1.8
0.0
28.8
7.5
avg. 4.4
aData for January 1, 1978.
                                    8-28
-------
      TABLE 8-10.   U.S.  ASPHALT PRODUCTION CAPACITY,  BY COMPANY3 15

1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.

Company
Exxon Company
Amoco Oil Company
Chevron USA, Inc.
Ashland Petroleum Company
Shell Oil Company
Koch Refining Company
Marathon Oil Company
Atlantic Richfield Company
Douglas Oil Company
Sun Oil Company
Mobil Oil Corporation
Vickers Petroleum Corporation
Murphy Oil Corporation
Texaco, Inc.
Continental Oil Company
Union Oil Company (CA)
Energy Cooperative, Inc.
Hunt Oil Company
Southland Oil Company
Gulf Oil Company
Total
m3 per
stream day
16,200
12,460
11,270
10,800
8,970
5,560
4,560
3,970
3,470
3,240
2,460
2,380
2,150
2,100
1,720
1,690
1,650
1,590
1,510
1,410
99,180
Barrels per
stream day
101,900
78,400
70,900
67,900
56,400
35,000
28,700
25,000
21 ,800
20,400
15,500
15,000
13,500
13,200
10,800
10,600
10,400
10,000
9,500
8,900
623,800
% of total
U.S. capacity
13.2
10.1
9.2
8.8
7.3
4.5
3.7
3.2
2.8
2.6
2.0
1.9
1.7
1.7
1.4
1.4
1.3
1.3
1.2
1.2
80.5
Data for January 1, 1978.
                                 8-29
-------
shipment was 90.3 percent asphalt roofing products, 9.6 percent saturated
felts, and  0.1  percent  asphalt  and insulated siding products.  Total
production in 1977  represented an increase of 1.8 percent of the total
production in 1976.
     Tables 8-11 through 8-13 and Figure 8-4 show the production data for
the asphalt and tar roofing and siding industry for the years 1963 through
1977.  Tables 8-11  through 8-lla give the  annual  production of asphalt
and tar  roofing and siding products  for  1969 to 1977 in megagrams and
tons,  respectively.   Table 8-12 shows the  quantities of asphalt roofing
shipments in sales  squares, by region, for  1970 through 1977.  Table 8-13
shows  the annual production of asphalt and  tar roofing and siding products
as  a  percent of total  annual production  of asphalt products for 1970 to
1977.   Figure  8-4 shows the total shipments in teragrams  for the  asphalt
roofing  industry for  1963  through 1977.
      Production of asphalt and tar roofing and siding products increased
27  percent  from 1970  to 1973,  then declined in  1974  and 1975,  and recovered
in  1976 and 1977 to the 1972 level of production and to within 4 percent.
of  the peak 1973 production level.   In  1970 the  Northeast  region accounted
for 19 percent  of  total  U.S.  production;  the  North  Central  region,
 31  percent; the South region,  36 percent; and the West region,  14 percent.
 In  1977 the percentage of U.S.  production in the Northeast  region had
 decreased to  18 percent;  the North  Central  region  had  increased to
 32 percent; the South  region  had decreased to 34 percent; and the West
 region had increased to 16 percent.
      The period  1971  to 1977  showed some  marked  changes in the product
 mix of  the  industry  as shown  in  Table 8-13.  The  most significant  change
 was the shift from standard (or regular) shingles to self-sealing shingles.
 The share of the total  industry market for self-sealing shingles increased
 from  51.7  to  74.9 percent while the market  share for regular shingles
 decreased  from 20.2  to only 2.5 percent.  Individual  shingles, smooth-
 surfaced  and  mineral-surfaced roll  roofing  and  cap  sheet,  asphalt and
 insulated  sidings, and saturated felts  all  declined  in their shares  of
 the market.
       8.T.I.4   Industry Employment.   Table  8-14  shows the data on employment
 in the  asphalt felts and  coating industry, which  includes the asphalt and

                                  8-30
-------

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             TABLE 8-14.  ESTIMATED ANNUAL EMPLOYMENT IN THE
         ASPHALT ROOFING AND SIDING PRODUCTS INDUSTRY, 1969-1976
Asphalt felts
and coatina industry

Year
1969
1970
1971
1972
1973
1974
1975
1976

No. of all
empl oyees
13,800
14,200
14,400
15,600
16,700
17,300
16,600
18,900
No. of
production
workers
9,900
10,200
10,400
11,500
12,600
12,800
12,200
13,700
Asphalt roofing and
sidinq products industry

No. of all
employees
10,900
11,200
11,400
12,300a
13,200
13,700
13,100
14,900
. No. of
production
workers
8,600
8,800
9,000
9,700a
10,400
10,800
10,400
11,800
aThese data from the 1972 Census of Manufacturers  show that
 79 percent of all  employees in the asphalt felts  and coating
 industry work in the asphalt roofing and siding products
 industry and that 79 percent of the employees  in  the latter
 industry are production workers.   The data for the other  years
 were developed from these ratios.
                                   8-36
-------
  tar roofing and siding products industry.  The asphalt felts and coating
  industry is engaged  in  manufacturing  roofing coatings and cements,  in
  addition to  asphalt  roofing  and  siding  products.
       Estimated  data  on  employment in  the  asphalt roofing and  siding
  products industry are  also  included in  Table 8-14.   The  data were
  calculated by  assuming that 79 percent of  the employees  in the asphalt
  felts  and coating  industry  were employed  in  the asphalt roofing and
  siding  industry.   This percentage is based on historical data  from  the
  Census of Manufacturers (1954, 1958, 1963, 1967, and 1972).10
      Table 8-14  shows that employment  in the  asphalt  roofing industry
  increased from 10,900 employees  in  1969 to  14,900  employees in  1976, and
 the number of  production  workers increased from 8,600  in 1969 to ll',800
 in  1976.   Between 1969 and  1976  the  industry employment increased by
 37 percent.
      8-1.1.5   Product Markets.   The discussion of asphalt roofing product
 markets which follows  is  divided into  the following topics:   (1) market
 location, (2) product substitution,  and  (3)  imports and exports.
      8-1'1-5-1  Market locations.   Most  asphalt roofing products are  sold
 within 483 km (300 mi) of  the  production  facility, so  the  location  of
 the  markets would approximate the location of  the  production plants shown
 in Figure 8-3.  The market locations for specific  products would approxi-
 mate the regional shipments of products shown  in Table 8-7.  This table
 shows  that half of the individual shingles are sold in  the North Central
 region,  and  one-third are  sold in  the  West; that  70 percent of strip
 shingles  are  sold  in  the  North  Central region and the South;  that
 30 percent of smooth-surfaced roll  roofing and cap  sheet is sold in the
 North  Central  region,  29 percent  in the South,  21  percent in the West,
 and  20 percent  in the  Northeast;  and that  30 percent of mineral-surfaced
 roll roofing  and  cap  sheet is sold  in the  South, 29 percent  in the North
 Central  region,  23 percent in the West, and 18 percent in the  North-
 east.  '"
     8'1-1-5-2  Product substitution.   At present,  asphalt roofing, products
provide^over  80 percent  of the  roofing products purchased in the United
States.    Cedar shingles, slate,  and tile  have found limited application
in the  roofing  markets  in recent years.  The  physical  properties  of

                                8-37
-------
asphalt roofing products  make  them durable and economical  in  the  long
run.  Recent price increases in asphalt roofing products have caused some
acceleration in the  searches for substitutes by consumers and producers
of  roofing  products.   In  the commercial and industrial built-up roofing
market, there  is  some competition from various plastic materials which
are  lighter and have shorter application times, but these products have
made no significant inroads  into the residential market.
     8.1.1.5.3   Imports and exports.   The  U.S.  Department of Commerce
U.S. General Imports  and  U.S.  General  Exports  publications for 1973 and
1977 do  not report any imports or exports of asphalt roofing products  or
roofing  products  of any type.18'19  We assume, therefore,  that the U.S.
domestic  market for  asphalt roofing products is  supplied  entirely  by
domestic  manufacturers and  that domestic  manufacturers  do not export
asphalt  roofing products.
     8.1.1.6  Product prices.   The  producer prices of asphalt roofing
products  tripled between 1969 and 1978.  This is reflected in Table 8-15
which  shows that the producer price index  (1967=100) for asphalt roofing
products  rose  from 102.8  in 1969 to  305.2 in December 1978 and shows that
the producer price of asphalt  roofing  strip shingle rose  from $6.44/sq in
 1969 to  $16.69/sq in January 1978.   More  recent data on producers'  prices
 of standard asphalt shingle  to  a large southeastern  building supply
 company  show that the  price of this product rose from $12.67/sq  in 1974
 to $17.01/sq in February 1979, an increase of 34 percent over the 5-year
 period as shown in Table 8-16.
      Manufacturers'  shipments of  asphalt roofing products, as shown  in
 Table 8-17, rose  from  84,430,000  sq to 93,759,000  sq, or  11 percent,  and
 saturated felt shipments fell  from 834,532 Mg (920,000 tons) to 778,292 Mg
 (858,000 tons), or 6.7 percent, from 1969  to 1976.  At the same time,  the
 value of asphalt roofing  product shipments rose from $406,800,000 to
 $1,327,900,000, or 226 percent.
      These  dramatic  price  increases are  attributable primarily to  rising
 material costs.   Data from the 1976 Annual Survey of Manufacturers show
 that  60  percent  of the value of  product shipments in the asphalt  felts
 and coatings  industry is due  to  material  costs, 15 percent  is due to
 salaries,  wages,  and  benefits,  and  25 percent is due to  value  added;
                                  8-38
-------
Producer price index
for asphalt roofing
Year (1969=100)
1969
1970
1971
1972
1973
1974
1975
1976
1977
1978 (Jan.)
1978 (Dec.)
102.8
102.7
125.5
131.2
135.5
196.0
225.9
238.1
253.0
277.4
305.2
Producer price of asphalt
roofing strip shingles
($ per square)
6.44
N/Aa
7.34
7.75
8.30
11.56
13.24
14.04
14.95
16.69
N/Aa
N/A = not available.
                                  8-39
-------
TABLE 8-16.  MANUFACTURERS' PRICES OF STANDARD ASPHALT
              SHINGLES TO DISTRIBUTOR23
Year
1974
1975
1976
1977
1978
1/2/79
2/1/79
Price per square3
12.57
13.16
13.98
13.98
15.87
16.51
17.01
Precent increase
—
4.7
6.2
0.0
13.5
4.0
3.0
aA square is the amount of roofing material when applied
 will cover 9.29 m2 (100 ft2) of surface.
                          8-40
-------
     •      8"17'  VALUES AND QUANTITIES OF PRODUCT SHIPMENTS IN THF
     ASPHALT AND TAR ROOFING AND SIDING PRODUCTS INDUSTRY, 1969-1 ™I«fie

Year
1969
1970
1971
1972
1973
1974
1975
1976
Value
of product
shipments3
($ millions)
406.8
464.6
638.5
690.6
828.4
1,052.0
1,139.6
1,327.9
Quantities of shipments
Asphalt
roofing
(thousands
of squares)
84,430
83,180
93,246
97,163
102,861
94,852
95,828
93,759


Saturated felts
(.thousands
of Mg)
835
769
831
826
864
855
672
778
(thousands)
/of tons)
920
848
916
911
952
943
741
858
          £? Pr°ducJ.shipments data also includes the value of siding

 60 ofl souIJJS i W?Q7? al n0t ShOWn"  S1dl"ng products amounted-to
Rv iS?fi  ?h     ™. J971 *nd were not reported in the following years.
By 1976, the quantity shipped is estimated to be 200,000 squares.
                                  8-41
-------
approximately 75 to  80  percent  of these product shipments are shipments
from the  asphalt and tar roofing and  siding industry,  as  shown  in
Table 8-18.  The relationship  of the materials, labor and supervision,
and value added costs to the product value in the asphalt roofing industry
are about the same for  both industries.
     The price  of  asphalt rose dramatically  in  early  1974 when the price
of crude oil increased  from $3.01/barrel in October 1973 to $11.65/barrel
in December  1973 as  a result of  the  OPEC oil  embargo  and  has continued to
increase  steadily  as   the price of crude oil  continues to  rise.
Table  8-19 shows that  from  October 1974 until January  1979  the price
increase  in  saturant asphalt for the asphalt roofing  industry was 41 percent.
The  Government  Accounting Office predicts  a  crude  oil price  of $16/barrel
by the end  of  1979, and  spot prices  are  ranging up to  $28/barrel  in
mid-1979.
      Roofing felts  have  increased in  price  in  the 1970's primarily  from
 price increases  in wood  pulp,  wastepaper,   other paper  products, and
 asphalt.   Wood pulp and  wastepaper  product prices increased dramatically
 in 1973 and 1974  as shown in Table 8-20,  the same years asphalt roofing
 showed dramatic price  increases.
      Granules, parting agents,  and stabilizers  for  the surfacing  of
 roofing  products  accounted for about  16  percent  of  the total  cost of
 materials in  1979 and do not have  an appreciable effect on the price of
 asphalt  roofing products.  The average price  of  mineral products pur-
 chased from several suppliers  by a large roofing manufacturing plant in
 March of 1979 was  $44.10 to  $47.40/Mg ($40 to $43/ton) for tab slate;
 $25.36/Mg ($23/ton) for  head  lap; $17.64/Mg  ^le/ton^for filler; $41.89/Mg
  ($38/ton) for  talc; and  $11.02/Mg ($10/ton)  for sand.
 8.1.2 Historical  and  Future  Trends
       Historical  trends  for the past  10 years  and future trends for the
  next 5 years  are described  for the  following aspects  of  the  asphalt
  roofing industry:  (1) annual changes in  production, (2) industry expansion
  through  new  plants and  additions  to existing plants,  (3) geographic
  concentration, (4) effects of  imports and substitute products  on growth,
  (5) changes in  plant sizes,  and  (6) production capacity  utilization.
                                  8-42
-------
TABLE 8-18.   VALUE OF PRODUCT SHIPMENTS IN THE
     ASPHALT ROOFING INDUSTRY, 1969-197616
Value of product shipments (m-?n-jnns nf rin-nnr->i
Year
1969
1970
1971
1972
1973
1974
1975
1976
hto this in<
°SIC 29523 •
»
Aspnait felts
and coatings
(SIC 2952)a
589.9
.626.4
825.9
902.2
1,058.5
1,357.0
1,462.8
1,699.7
Jus try by the U.S. C<
is the code for this
Asphalt and tar roofing
and siding products
(SIC 29523)°
406.8
464.6
638.5
690.6
828.4
1,052.0
1,139.6
1,327.9
snsus Bureau.
segment of the industry.
SIC 29523
percent of
SIC 2952
69 0
74 2
77 3
76 5
78 3
77 5
77 9
78.1
signed
                    8-43
-------

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8-44
-------
     fTTrm o         AN° PERCENT INCREASES FOR SELECTED
PRODUCTS IN THE PULP, PAPER, AND ALLIED PRODUCTS INDUSTRY
	 	 	 — 	 .-
Pulp, paper, and
Year
1970
1972
1973
1974
1975
1976
1977
1978
(Jan. )
allied
Index
108.2
113.4
122.1
151.7
170.4
179.4
186.4
189.6

jroducts
Percent
increase
—
4.8
7.7
24.2
12.3
5.3
3.9
1.7

Wood DU!D
Index
109.6
111.5
128.3
217.8
283.4
286.0
281.1
263.3

Percent
increase
__
1.7
15.1
69.8
30.1
0.9
1.7
6.3

Wastepaper
Percent
Index increase
125.0
133.6
197.4
265.5
110.2
184.9
187.2
201.7


6.8
47.8
34.4
58.5
67.8
1.2
7.7

                       8-45
-------
     8.1.2.1   Annual  Changes  in  Production  and  Product Mix.   The total
production of the asphalt roofing and siding industry rose from
7,267,064 Mg (8,011,324 tons) in 1969 to 8,586,134 Mg (9,465,477 tons)  in
1977, or  18.2  percent.   In 1970, 1974, and 1975 the total production of
the industry decreased relative to the previous years while total production
increased in other years.  Tables 8-21 and 8-21 a show the annual production
quantities  and annual percentage  changes  in total production for the
industry from  1969 to 1977 in megagrams and tons, respectively.
     Tables 8-21  and 8-21 a also show  the  annual  percentage changes  in
asphalt  roofing products, asphalt and insulated siding,  and saturated
felts.  Asphalt roofing production increased from 6,381,989 Mg
(7,035,595  tons)  in  1969 to  7,749,776 Mg (8,543,464 tons) in  1977, or  an
increase  of 21.4 percent; decreases  in production were experienced in
1970,  1974, and 1975, while  increases were experienced in 1971, 1972,
1973,  1976, and 1977.  Asphalt and insulated siding production decreased
from 50,837 Mg (56,043 tons) in 1969  to 9,733  Mg  (10,730 tons)  in 1977,
or a decrease of 81  percent;  decreases in production were experienced
every year except  1973.   Saturated  fel t  product production showed a
slight decline from  834,248 Mg (919,687 tons)  in  1969 to 826,625 Mg
(911,283  tons) in 1977,  or  a  decrease of 0.8 percent;  decreases  in
production  were experienced in 1970, 1972, 1974, and 1975, and increases
were experienced  in  1971, 1973,  1976,  and  1977.
      The trend of the past  10 years in asphalt products is expected to
continue for  the next 5  years.   Annual production of all products will
probably show years  of  increases  and decreases with a net  increase of
 about 4 to 8  percent over the 5-year period. . Asphalt roofing products
will continue to dominate the asphalt roofing and  siding  industry  and
 constitute about 90  percent  of  the  production output of the industry  as
 they  have  for the  past  10  years.  Saturated  felts will continue to
 constitute about 10  percent  of  the production output and siding products
 will remain at less than 0.5 percent of the production output.
      Within the asphalt roofing product output sector, self-sealing  strip
 shingles will  account for about 75 percent of output; roll roofing and
 cap sheet will account for about 10 percent of output; and standard strip
 shingles and  individual  shingles  will  each account  for about 2.5 percent
                                 8-46
-------
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 of output.  These ratios of output have been almost constant for the past
 5 years (see Table 8-13)  and  are not expected to  change  to any extent
 over the next 5 years.
      8-1-2-2  Industry Expansion by New Plants and Additions to Existing
 P1ants-   Tne Annual  Survey  of Manufacturers  and  Census of Manufacturers
 reported data on the total  annual  expenditures for new structures  and
 additions  to plants  and  total  annual  expenditures for new machinery and
 equipment  for the asphalt felts  and coatings industry as  shown in Table
 8-22.   Approximately 75 percent  of  these  expenditures were made by the
 asphalt  and tar roofing and siding industry as reported in the Census of
 Manufacturers  (1972,  1967,  1963, 1958,  and  1954).   In order to obtain
 approximate annual expenditures  by  the  asphalt roofing and siding  industry
 for  the years 1969 to  1977, the expenditures  of  the  asphalt coatings
 industry were multiplied  by  0.75.   These data are  also shown  in Table 8-22.
     The expenditures in Table 8-22 are based on  current dollars  for the
 year  reported and do not reflect comparable  expenditures  since  price
 inflation  has  not been considered.   Table 8-23 reflects adjustments to
 the  estimated  annual  expenditures for  new plants  and  equipment by  the
 asphalt  roofing  and  siding industry to  constant 1957-59 dollars by using
 the  Chemical  Engineering (CE)  plant cost  indices  for  buildings and  for
 equipment,  machinery, and supports.   These   figures show  that annual
 expenditures for  new  structures  and additions  to  plants were less than
 $4 million  dollars  each year  (in 1957-1959  dollars)  and  that annual
 expenditures for  new  machinery and  equipment were less than $16 million
 dollars  (in  1957-59 dollars) for  the  industry which had about 100 plants
 operating each year.   An average of $56,000  (in 1957-1959  dollars)  was
 spent per  operating plant in 1969 for new structures and equipment,  and
this expenditure  increased to  $194,000  (in 1957-1959  dollars)  in 1976.
     Table 8-24  shows the end-of-year gross  book  value of depreciable
assets in  the  asphalt  felts and coatings industry and the estimated
values for the asphalt and tar  roofing and siding  products  industry.   The
Census of Manufacturers showed that  in  the census  years of 1954, 1958,
1963, 1967, and 1972  about 75 percent of the  end-of-year gross book value
in the asphalt felts  and coatings industry was attributed to the asphalt
roofing industry.   The estimated  values  for asphalt roofing in Table  8-24
                                8-49
-------
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             8-52
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 were obtained by multiplying the values for felts and coatings by 0.75.10
 Table 8-25 shows the estimated end-of-year gross book value of depreciable
 assets  in  the  asphalt  roofing  industry adjusted to  1957-59  dollars  using
 the CE plant cost indices for buildings and for equipment, machinery, and
 supports.
      The Annual Survey of Manufacturers  data shown  in  Tables 8-24 and
 8-25 include all fixed depreciable assets on the books  of establishments
 at the end of  the  year.16  The values shown (book value) represent the
 actual  cost of assets at the time they were acquired, including all  costs
 incurred^n making the  assets usable (such as transportation and instal-
 lation).     Thus,  the values shown  in Tables  8-24 and 8-25 do  not reflect
 depreciation  of the buildings  and equipment as  do usual  book values.   The
 annual  increase in end-of-year book  value  shown in  Tables 8-24 and  8-25
 indicate the increase  in new plants and additions to existing plants and
 indicate  the increase  in new machinery and equipment for new plants,
 additional  capacities  at existing  plants, and  replacement equipment.'
     Based  on the  historical  data presented  in this document,  it  is
 assumed  that the capacity of the asphalt roofing industry  should  increase
 at  a rate of about  2 percent a year for the next 5 years.   At  least half
 of  this   increased  capacity  can be met by the  expansion  of existing
 facilities.  Several companies have indicated that they  will increase the
 productive capacity of  their plants by adding a  line  to  make roll roofing.
 As  a result,  it is  assumed that three new medium plants  will be built  in
 the next  5 years.  However,  the increase in production may be achieved by
 adding new lines to existing plants.
     8-1.2.3  Geographic Concentration.   Figure 8-3   shows  the current
 location  of asphalt  roofing  production plants in the United States.   It
was estimated previously  that 95 of these 118 plants  were in operation in
 1967.  An estimated  15  new  plants built since 1967 have been located in
States which had one or more plants in  the past.  This estimate  is based
upon reported  shipments  of  products  by States in  the Census  of
Manufacturers reports for 1967 and 1972.10
     Table 8-12 shows that  in  1970  the Northeast region accounted  for
19 percent of total  U.S. production  of asphalt roofing and siding products;
the North Central region, 31 percent;  the  South region,  36 percent;  and
                                8-53
-------
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-------
  the  West  region,  14 percent;  and in  1977  the  Northeast region  had  declined
  to  18 percent of U.S.  production; the North Central region had increased
  to 32 percent;  the  South  region  had  decreased to  34 percent; and the West
  region had increased to  16 percent.  Over  the next 5 years the concen-
  tration of production  in  the  regions is not expected  to change more than
  3 percent  either way in each  region.
       8'1-2-4     Effects  of Imports  and Substitute  Products on Growth.
 There  are  no  reported  imports of roofing  products into the United  States
 arid  there  are no indications  that imports  will  have  any effect on the
 U.S.  asphalt  roofing market growth over the next 5 years.18
      The asphalt roofing  industry currently has about an 80 percent share
 of the roofing market in the United States and competes with cedar shingles,
 tile,  slate,  and plastic  products.17 Over  the next 5 years the share of
 the total   roofing market  that the asphalt roofing industry will maintain
 will  depend upon its price relative to other products,  consumer preferences,
 and new substitute  product competition. The  price  of asphalt roofing
 products has  risen dramatically  in the last 10 years;  thus the incentive
 to  search  for cheaper  substitutes,  such as  plastics,  has  increased.  It
 is  unlikely that an acceptable substitute  for asphalt roofing will be
 found over  the next  5 years, but  this possibility  exists.
      Dramatic  increases in crude  oil  prices and,  therefore, increases  in
 asphalt prices  are  a real possibility  in  the near term.   If  asphalt
 prices continue to rise in relationship to the price of other materials,
 such  as cedar,  a  significant  shift in consumer preferences  for  other  '
 products could occur.   Predicting a shift in preference involves too many
 unknowns to make a reasonable estimate  of  what may occur  in the short
 term.   However,  it is important to note that the asphalt roofing industry
 could  be adversely affected by any substantial price changes in petroleum
 products.
     8'1-2-5   Changes in Plant Sizes.  The  size of  individual plants is
 not reported by the asphalt roofing industry, government publications,  or
 any other known  sources.   Increases in production over the next 5 years
may be made by additions  to existing plants,  building new plants, or
 increasing utilization  of  existing  capacity.   Since any or all  of these
                                8-55
-------
possibilities may  occur,  it is impossible to  predict how plant sizes
(unknown at present) will  change in the next 5 years.
     8.1.2.6  Production Capacity Utilization.   The historical and current
total  production capacity  of  the  asphalt  roofing industry  and  the
capacities  of individual  plants  are not reported  by the U.S.  Census
Bureau  in  the  Census of Manufacturers  or  in  the Annual  Survey of
Manufacturers.   Based on information  obtained from plant  surveys  and
supplied  by plants,  it is estimated that the  newer asphalt  roofing  plant
lines  operate at 70  percent  of their  design  line speed of  3.048 m/s
(600 ft/min); and  the typical  plant operates two  shifts  per  day, 5 days
per  week, and 50 weeks per  year.   It has been estimated that the  typical
plant  would have a 20 percent down-time  and  a 9 percent average  waste.
8.2  COST ANALYSIS OF REGULATORY ALTERNATIVES
     In this section, the estimated capital  investment costs, annualized
costs,  and unit product costs to construct and operate new model  asphalt
roofing  plants  are presented for  small,  medium, and large plants,  both
with and  without blowing  stills,  as previously defined in Chapter 6.  The
estimated  capital  investment  costs,  annualized  costs,  and cost
effectiveness of pollution control systems for  each new facility are
determined  and  compared  for each  regulatory alternative.    Costs  for
 retrofitting the pollution control systems  to modified/reconstructed
 facilities that may  make those changes  identified  in  Chapter 5, and thus
 qualify as possible modified or reconstructed sources subject to  standards,
 are not  determined,  since  the likelihood that any  existing facility will
 make those changes is extremely remote.
      Capital investment costs represent the total  investment required to
 construct  new facilities and install pollution control systems and include
 direct  costs,   indirect  costs,   contractor's  fees,  and contingency.
 Annualized costs represent the variable, fixed, and overhead costs required
 to operate the plants, and represent the fixed and variable  costs required
 to  operate the pollution control  systems.  Unit  product costs for each
 plant are  the annualized cost of the plant divided by  the  annual production.
 Cost  effectiveness   is the annualized  cost  of each pollution control
 system divided  by the quantity of  particulate pollutants collected annually.
                                  8-56
-------
       The  cost analysis  of the  new model asphalt  roofing  plants and
 pollution  control  systems  for  the  five  regulatory alternatives  is divided
 into  three sections:   (1) costs of  new  facilities without pollution
 control;  (2)  costs of pollution control  for  the  five regulatory alter-
 natives;  and  (3) cost  summary.   All  costs are given  in  November 1978
 dollars.
 8'2-]  Costs of New Facilities Without Pollution Control
      The  capital  investment costs, annualized  costs,  and unit product
 costs  for  new model  asphalt roofing  plants  are determined for  small,
 medium, and large plants, both with and without blow stills, as previously
 defined in Chapter 6.   The costs presented in  this section are  for new
 facilities with no pollution  control  equipment and represent the costs
 that are required  to  construct and operate each facility without regard
 to the regulatory  alternatives.  Section  8.2.2  presents the costs  of the
 pollution  control   equipment under  each  regulatory alternative  and those
 costs must be added  to  the costs given  in this  section to determine  the
 total  costs of a new  facility.   Total costs  are presented  in  the cost
 summary in Section  8.2.3.
      8-2'1-1   Capital  Investment Costs.   The capital investment costs of
 constructing  new asphalt roofing facilities calculated in this  analysis
 are  detailed estimates based upon a contractor's bid to construct a small
 plant  in October 1973.28  The method of  estimating the  capital investment
 costs  is commonly  referred  to  as the detailed-item estimation method  and
 usually  has an accuracy  of  about +5 percent.   However,  the costs are  up-
 dated  using cost indices, and this  introduces some  error into current
 cost  estimates so  that  the accuracy  of the estimates  given is  about
 +10 percent.
     The method  used  to  estimate the  cost of  the  small plant involved
 using  the  contractor's October  1973 cost proposal  and  updating  all the
costs  to November 1978 dollars  using the Chemical Engineering (CE) Plant
Cost indices and subcomponents  are shown in Table 8-26.28  The costs  of
the medium  and large  plants are  estimated from  the  small plant  costs
taking into account the additional equipment and building requirements of
these plants.  The  small plant has  one roofing machine,  the medium plant
                                8-57
-------
         TABLE  8-26    CHEMICAL  ENGINEERING PLANT COST INDICES AND
             SUBCOMPONENTS  FOR OCTOBER  1973 AND NOVEMBER 197829
                                     Cost  Indices
                                 October
                                  1973
            November
              1978
             Ratio of 1978
            to  1973  indices
Chemical engineering plant
  cost index

  Construction labor
  Buildings
  Engineering and supervision
  Equipment, machinery,
    and supports

    Fabricated equipment
    Process machinery
    Pipe, valves, and fittings
    Process instruments

    Pumps and compressors
    Electrical equipment
    Structural support and
       miscellaneous
146.7
161.7
150.9
130.7
143.5
143.7
139.6
153.9
148.1

140.8
105.3
141.5
                                                224.7
190.3
217.8
165.4
247.6
244.1
235.8
278.1
221.7

266.6
173.5
258.0
                                1.53
1.18
1.44
1.27
1.73
1.70
1.69
1.81
1.50

1.89
1.65
1.82
                                    8-58
-------
 has  two  roofing machines, and the  large  plant has two roofing machines
 and  one saturated felt  line.
      Table 8-27  shows the estimated  capital  investment costs for each
 plant, both  with and without blowing  stills,  excluding pollution  control
 equipment.  The  cost for plants without blowing stills is $8,946,000 for
 the  small plant,  $14,501,000 for the medium  plant,  and $16,953,000  for
 the  large plant; and the cost of plants with blowing stills is $9,110,000
 for  the, small  plant, $14,831,000 for the medium plant, and $17,338,000
 for the large plant.  The capital investment costs for the blowing stills
 are $160,000 for  small  plants,  $320,000 for medium plants, and $370,000
 for  large plants.   These costs  include the  purchase  costs,  indirect
 costs,  and the  installed  cost of the blowing  still, preheater,  pumps,
 compressor,  piping,  and electrical  equipment.   All costs in Table 8-27
 are determined  from  the  information  given  in the contractor's  October 1973
 cost proposal.
      A  description of each capital investment  cost  item shown  in Table 8-27
 is  given  in  Sections 8.2.1.1.1. to 8.2.1.1.4.
      8-2-1.1.1   Direct cost items.    Sitework  includes  rough  grading;
 roads on the  plant property;  paved parking in  the loading  dock  and office
 building  areas; 213 m (700 ft) of railroad  track;  366 m  (1,200 ft)  of
 2.1-m (7-ft) high,  aluminum-coated  fence  and  two sliding gates;  stone
 grading;  fill  and compacting; excavation and  backfill;  drainage system;
 and dewatering.
      The  manufacturing and warehouse  building is  constructed  of  pre-
 fabricated, 26-gauge, prepainted metal roof  and sidings  on a 0.2-m (8-in.),
 reinforced concrete  floor in  the manufacturing  section and a 0.15 m
 (6 in.) reinforced concrete floor in the warehouse section.  The building
 includes a high bay  section  over the  roofing  machine(s),  machine  room,
 utility and  electric room, warehouse,  office,  locker room, pump house,
 and machine  shop.   Also  included in  the  building  cost are concrete  '
 foundations  for the   silo  area and  still yard;  heating units  for  the
warehouse; steam unit heaters; air conditioning for office area; plumbing
 fixtures;   dock  levelers;  and partitions,  light,  heating,  and air
conditioning for the  office.   The  cost of land is excluded in this  analysis.
                                8-59
-------
TABLE 8-27.  ESTIMATED CAPITAL INVESTMENT COSTS OF NEW ASPHALT
    ROOFING FACILITIES WITHOUT POLLUTION CONTROL EQUIPMENT

Capital cost
Capital investment item Small plant
Plants without blowina stills
Direct costs
Sitework
Buildings
Fired heaters
Heat exchangers
Process and storage tanks
Pumps and compressors
Fire protection system
Electrical equipment
Instruments and controls
Piping, ductwork, and insulation
Materials handling systems
Roofing machine(s)
Miscellaneous structural steel
Miscellaneous equipment
Total direct cost (D)
Indirect costs
Engineering and supervision
Construction overhead
Total indirect cost
Contractor's fee (~5% D)
Contingency (~5% D)
Working capital (-10% D)
Total investment cost
Plants with Blowing Stills
Investment cost without stills
Blowing stills
Increased working capital
Total investment cost
225,000
1,350,000
290,000
30,000
645,000
150,000
195,000
560,000
80,000
890,000
315,000
1,310,000
160,000
100,000
6,300,000
300,000
200,000
500,000
300,000
300,000
1,546,000
8,946,000
8,946,000
160,000
4,000
9,110,000
("November 1978
Medium plant
245,000
2,150,000
435,000
50,000
965,000
300,000
235,000
675,000
120,000
1,400,000
475,000
2,620,000
240,000
120,000
10,030,000
350,000
320-, 000
670,000
500,000
500,000
2,801,000
14,501,000
14,501,000
320,000
10,000
14,831,000
dollars)
Large plant
270,000
2,700,000
540,000
60,000
1,035,000
335,000
255,000
700,000
135,000
1,580,000
480,000
3,060,000
260,000
150,000
11,560,000
370,000
360,000
730,000
580,000
600,000
3,483,000
16,953,000
16,953,000
370,000
15,000
17,338,000
                               8-60
-------
      8-2.1.1.2   Indirect cost  items.   Costs  for construction design and
 engineering,  drafting,  purchasing, accounting,  cost engineering,  and
 travel  are included  in engineering  and  supervision of  the plant
 construction.
      Items  such  as temporary  construction  facilities,  tools, rentals,
 travel, living expenses, taxes, and insurance are included in construction
 overhead.   This  cost  item  is estimated at about 3 percent of the total
 direct costs for each plant.
      8-2.1.1.3   Contractor's fee.   The contractor's  fee will vary  for
 different contractors,  and is  estimated to  be  about 5 percent  of the
 total  direct costs of each  plant.
      8.2.1.1.4  Contingency.  The contingency factor is added to  compensate
 for work  stoppages,  weather  problems, and other unpredictable events;
 design changes during construction; underestimation errors; and expenses
 not specifically listed which  are  likely  to occur.   In this analysis a
 contingency factor of about 5 percent of the total  direct costs  for each
 plant  is added to the  total capital  investment cost.
     8-2-l-2  Annualized Costs.  The  annualized costs  for  each  model
 plant  will  be  the sum  of variable costs, fixed costs,  arid plant overhead.
 The following  list shows the operating cost  items considered in this
 study:
          Variable costs
          Raw  materials
          Operating labor
          Supervision  and clerical labor
          Maintenance  labor and materials
          Operating supplies
          Process utilities
          Laboratory services
          Payroll charges
     The annualized  cost (in November 1978 dollars)  for  plants  with
blowing  stills  is $14,645,600 for small plants, $26,580,400  for  medium
plants, and $34,221,400 for large plants.   The annualized cost for plants
without  blowing stills is $14,722,500  for small  plants, $26,737,400 for
Fixed costs
Capital recovery
Taxes and insurance
General  and administrative
Plant Overhead
                                8-61
-------
medium plants,"and  $34,445,100 for large plants.   These costs are shown
in Table 8-28 and are based on plants operating 16 hours/day, 250 days/year.
The inputs used to determine these costs are shown below.
     8.2.1.2.1  Variable costs.   Variable  costs include raw  materials,
operating  labor,  supervision  and clerical  labor, maintenance  labor and
materials,  operating supplies, process utilities, laboratory  services,
and payroll charges.
     Asphalt,  dry felt, filler,  talc,  and granules  are the  basic raw
materials  used in asphalt roofing plants.  The quantities of each material
used annually by each model plant were previously given  in Table 6-3, and
the  prices (in November 1978  dollars), which  were previously given in
section 8.1.5, are:
      1.
      2.
      3.
      4.
                                          30
         blown asphalt - $97/Mg ($88/ton);
         asphalt flux - $92.60/Mg ($84/ton);
         dry felt - $235.92/Mg ($214/ton);31
         filler - $17.64/Mg ($16/ton);32
30
                                     32
                                        and
                                         32
     5.  talc - $41.90/Mg ($38/ton);'
     6.  granules - $44.10/Mg ($40/ton).
Tables 8-29 and 8-29a show the annual quantities and costs of raw materials
used by each model plant.
     A roofing  shingle  line  or  saturated  felt  line  requires  14 operators
per shift for operations; materials handling requires three operators per
shift; warehousing requires three  operators per shift;  shipping and
receiving  requires two  operators per day;  blowing stills require two
operators  per shift; and  miscellaneous  operating  labor  requires two
operators  per shift.   Each plant operates two  shifts  per  day.  The small
plant  operates the blowing  still one shift, and the medium and  large
plants operate  the blowing stills two shifts.  The  saturated felt line at
the large  plant is operated  on  only  one shift.
     The  total  operating  labor required for each  model  plant without
blowing  stills is:  small  plant, 46 people; medium  plant, 74 people;  and
large  plant,  88 people.  Total  operating labor  for plants with  blowing
stills is:  small plant, 48 people;  medium plant,  78 people;  and large
plant, 92  people.
                                 8-62
-------
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     Wages for  production  workers in the paving and  roofing  materials
industry (SIC 295) in November 1978 were $6.86/h.33   At this wage rate,
the annual operating labor cost for each model plant is:
     ANNUAL OPERATING LABOR HOURS AND COSTS (NOVEMBER 1978 DOLLARS)
  Model plant size
  Small
  Medi urn
  Large
Without blowing stills
Labor hours    Cost  ($)
 92,000        631,100
148,000      1,015,300
176,000      1,207,400
With blowing stills
Labor hours  Cost ($)
  96,000      658,600
  156,000   1,070,200
 184,000   1,262,200
     Each  plant requires a plant manager and plant superintendent.  The
small  and  medium plants require four  foremen  each,  and the large  plant
requires six foremen.   The small plant  requires  five clerical  workers,
the medium plant requires  six,  and the large plant requires seven.
     The salaries of each person are assumed to be  $40,000 for  the plant
manager,  $30,000 for the  superintendent,  $22,000 for the foremen, and
$12,000  for the clerical workers.   At these salaries, the cost  of  super-
vision and  clerical  labor for each plant  is:  small  plant,  $218,000;
medium plant,  $230,000;  and large plant, $286,000.
     An  asphalt roofing plant  requires  constant  maintenance  and repair
operations.   Four shifts  of maintenance workers  are used, and a  small
plant  requires 5 workers per shift,  or 20  workers;  a medium plant  requires
6 workers  per  shift, or 24 workers; and a  large plant requires  7 workers
per shift, or 28 workers.
      The wage  rate  of  maintenance  workers is assumed  to  be  10 percent
 more than the  production  workers,  or $7.55/h.  At this  wage rate, the
 annual maintenance labor cost for each model plant size is:   small plant,
 $302,000;  medium plant, $362,400;  and large plant,  $422,800.
      The materials required for annual maintenance and repairs  are assumed
 to be about 3 percent of the  direct  capital  investment costs  of  each
 plant, or $190,000  for  the  small plants,  $300,000 for  the medium  plants,
 and $370,000  for the large plants without blowing  stills; and $195,000
 for the small  plants,  $310,000 for the medium plants,  and $380,000 for
 the large plants with blowing  stills.
                                 8-66
-------
      The total annual maintenance labor and material costs for each plant
 are:   small  plant without  blowing  stills,  $492,000; small plant with
 blowing stills, $497,000; medium plant without  blowing  stills, $662,400;
 medium plant with  blowing  stills,  $672,400; large plant without blowing
 stills, $792,800;  and large plant with blowing stills, $802,800.
      Miscellaneous operating supplies, such as  charts,  lubricants, small
 tools,  and similar items, which are neither raw materials nor maintenance
 and repair materials, are  required  in the plant operation.  The annual
 cost of these  supplies  is  estimated to  be 10  percent of the maintenance
 labor and materials  cost,  or about $49,200 and $49,700 for the small
 plants,  $66,200 and $67,200  for the  medium plants,  and $79,300 and $80,300
 for the large  plants, without and  with  blowing stills, respectively.
      The process utilities, energy  and water  usage,  of  the model plants
 with an electrostatic precipitator  (ESP)  on the saturator, afterburner
 with heat  recovery  and cyclone  on the  blowing  stills,  and cyclones on  the
 materials  handling operations  were  shown previously in  Table 6-3.   In
 Tables  8-30  and 8-30a the annual  utility requirements and annual  cost  of
 water,  natural  gas, No.  2 fuel oil,  and  electricity are shown for each
 plant size,  both with and without blowing stills,  for model plants with
 no  pollution  control  devices.  The  data  in  this table were derived by
 subtracting  the energy requirements for the baseline pollution control
 equipment  from  the  figures shown in Table 6-3.  It was  assumed that the
 afterburners  are fired with  No.  2 fuel oil  and the  asphalt blowing still
 preheaters are  fired with natural gas.
     No  laboratory  services  are normally required at an  asphalt roofing
 plant.  However, an allowance of $10,000 for small plants and $20,000 for
 medium and  large plants  is made for contract  laboratory services which
 may be required periodically for quality control.
     Payroll charges are assumed to be about 20 percent of the wages  paid
 to all employees, or about $235,700 for small plants with blowing stills;
 $230,200 for  small  plants without blowing stills;  $332,500 for medium
plants with blowing stills;  $321,500 for medium plants  without blowing
 stills;  $394,200 for  large  plants  with blowing stills; and $383,200  for
plants without blowing stills.
                                8-67
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     8.2.1.2.2  Fixed costs.  Fixed costs include capital recovery of the
total capital investment cost, taxes, insurance, and general and adminis-
trative expenses.
     Interest is assumed to be 10 percent annually, and the total capital
investment cost is recovered over a 10-year period.  The capital recovery
factor (n=10, i=0.10) is 0.16275.  Therefore, the annual capital recovery
costs are:
                  ANNUAL CAPITAL RECOVERY COST  ($)

                              Small plant    Medium plant    Large plant
PI ant wi thout blowi ng sti11s   1,456,200      2,360,000     2,759,100
Plant with blowing stills      1,482,700        2,413,700      2,821,800
     The  annual  cost of taxes and  insurance is assumed to be 2 percent
of  the total  capital  investment cost  for  each plant.   This cost  for
plants  without blowing stills is $178,900 for small plants, $290,000 for
medium  plants,  and $339,100 for  large  plants; and  for plants  with blowing
stills  is $182,200  for  small plants, $296,600  for  medium plants, and
$346,800  for large plants.
     General and administrative expenses are assumed to be 2 percent of
the total capital investment cost  for each plant and  are equal  to the
costs  of  taxes and  insurance given  above.
     8.2.1.2.3  Plant overhead.   Plant overhead is a charge to the costs
 of the manufacturing facility which are not chargeable to  any particular
 operation.   Overhead includes such  cost items as medical services, general
 engineering and  contracting to others, plant  utilities,  plant guards,
 janitors, cafeterias,  administrative offices, accounting, and purchasing.
 Overhead costs will  vary from company to company and are usually calculated
 as a percentage of direct labor cost or a percentage of installed capital
 investment  for  the  entire facility.   Plant overhead is  estimated to be
 10 percent  of the direct capital investment cost for each plant.
      8.2.1.3  Unit  Product Costs.  Table 8-31  shows the annualized cost
 of  each  plant,  quantities of asphalt roofing shingles produced annually
 by  each  plant,  and the  unit cost of  the  products.  The small plants
 produce  109,759 Mg  (121,000  tons)  of  product annually,  the medium plants
                                 8-70
-------
              TABLE 8-31.  ANNUALIZED COSTS AND UNIT PRODUCT
                 COSTS OF NEW MODEL ASPHALT ROOFING PLANTS
                     WITHOUT POLLUTION CONTROL SYSTEMS
Plant
size and
description
Annualized
   cost
    $
 Annual production    Unit costs of
of roofing shingles  roofing shingles*
   Sales squares      $/sales squares
Small
  With blow stills
  Without blow "stills

Medi urn
  With blow stills
  Without blow stills

Large
  With blow stills
  Without blow stills
14,645,600
14,722,500
27,580,400
27,737,400
34,221,400
34,445,100
     1,030,000
     1,030,000
     2,060,000
     2,060,000
     2,640,000
     2,640,000
14.22
14.29
13.38
13.46
12.96
13.05
 November 1978 dollars.
                                  8-71
-------
produce 219,518 Mg  (242,000 tons) of  product  annually,  and the large
plants produce  281,201 Mg  (310,000 tons)  of product annually.  About
97 percent (on a weight basis)  of the  product  manufactured  by  each plant
is assumed to be asphalt roofing  strip shingles and 3 percent is saturated
felt.  For the purpose of determining  the  unit product costs,  all of  the
production at each plant is assumed to be asphalt roofing strip shingles.
     An asphalt roofing strip shingle  sales  square weighs 106.6 kg (235 Ib).
A  small  plant produces 1,030,000 sales squares per year; a medium plant
produces  2,060,000  sales squares per  year;  and a large  plant produces
2,640,000 sales  squares per year.38   The  unit product costs  for each
plant  are determined  by dividing the annualized cost by  the annual
production of sales  squares.
8.2.2    Costs of Pollution Control for the Five Regulatory Alternatives
     The  capital  investment costs, annualized costs, and cost effective-
ness of particulate pollution control  systems for the model  asphalt
roofing  plants  are  determined  for six basic types  of devices:  electro-
static precipitators (ESP), high velocity  air  filers (HVAF),  afterburners
with heat recovery  (A/B  W/HR), cyclones (CYC), mist eliminators (M/E),
 and fabric filters  (F/F).  Capital investment costs include the purchase
 cost  of  the basic  control  equipment and  auxiliary  equipment,  the
 installation cost,  foundations and supports, ductwork,  stacks, electrical,
 piping,  insulation, painting,  pumps,  contractor's  fee,  contingency,  and
 other indirect costs.   Annual!zed costs are the sum of  variable  costs
 (operating labor, supervision, maintenance  labor, maintenance  and repair
 materials, process  utilities,  and payroll  charges) and fixed costs  (capital
 recovery, taxes,  insurance and  general  and  administrative  expenses).
 Cost  effectiveness  is the annualized cost  of the control system divided
 by  the quantity of  pollutants  collected annually by the system.
      The discussion which  follows is  divided  into the following sections:
 (1) description  of  the  pollution control  systems  for each  regulatory
 alternative, (2) description of  the individual pollution control devices,
 (3) annual  particulate emissions from model  asphalt roofing plants  and
 the control systems,  (4)  capital  investment costs;  (5) capital investment
 cost  comparisons,   (6) annualized  costs,  (7) annualized operating cost
                                  8-72
-------
 comparisons,  (8) cost  effectiveness,  and  (9) cost  effectiveness
 comparisons.
      8-2-2-1  Description of the Pollution Control Systems for Each
 Regulatory Alternative.  The pollution  control  systems required  for  each
 regulatory alternative were discussed in Chapter 6 and shown in Tables 6-4
 and 6-5 and  in  Figures 6-1  to 6-6.  The  information presented in those
 tables and  figures  is used in this  chapter  to describe more specific
 systems for  each  model  plant and regulatory alternative.  The costs of
 the pollution control systems and the individual pollution control  devices
 presented in this chapter  are  based upon the  descriptions  given here.
      Tables  8-32 and 8-32a show the pollution control  systems and operating
 characteristics  for  baseline model  asphalt roofing plants,  and Tables 8-33
 and 8-33a show the pollution control  systems  and operating characteristics
 for the model asphalt roofing plants  for Regulatory Alternatives  2  through
 5.   Each  model  plant size  (small, medium,  and large)  has  two  configurations:
 Configuration 1  for  plants with blowing stills and Configuration 2 for
 plants  without blowing stills.   Five basic operations are  considered at
 each plant for each  control  system under  each  regulatory alternative as
 follows:   (1) saturator, wet looper,  and coater,  (2) filler surge bin and
 storage,  (3) parting agent  bin and storage, (4) asphalt storage,  and
 (5)  blowing  stills.   The saturator,  wet  looper, and coater operation  may
 be  controlled by one ESP,  one HVAF,  or one A/B  W/HR in small  plants;  two
 ESP's,  two HVAF's, or two A/B's W/HR in medium plants; and three ESP's,
 three HVAF's, or three A/B's W/HR in large plants.
     The filler surge bin and storage operation and the parting agent bin
 and  storage operation may each be controlled by either one cyclone or one
 fabric  filter, or  each  operation may  be  controlled  by a separate  control
 device.  The  emissions from both the filler surge bin and storage operation
 may  be  controlled by the  same  device,   and the  parting agent bin and
 storage operation  may be controlled  by  the  same device.   The asphalt
 storage operation may be uncontrolled, controlled by the saturator control
 device  during plant  operations, and controlled  by a mist  eliminator when
 the plant is   not operating.   The blowing stills are controlled by one A/B
W/HR.
                                8-73
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     The  specific  pollution  control  devices  and their  operating
characteristics shown  in  Tables  8-32  through 8-33a are discussed below
for each operation.
     8.2.2.1.1   Saturator,  wet  looper,  and coater  operation.   The  ESP,
HVAF, or  A/B  W/HR in small  plants operates at 4.93 Mm /s (10,450 scfra);
the control devices in medium plants  operate at  5.07  Mm /s  (10,750  scfm)
and 4.72 Nm3/s (10,000  scfm), respectively; and the three control devices
in  large  plants  operate  at  5.14 Nm3/s  (10,900  scfm),  4.72 Nm3/s
(10,000 scfm), and 4.72 Nm3/s  (10,000 scfm), respectively.   Each ESP or
HVAF baseline control  device has an inlet  gas temperature of 93°C (200°F),
and each  ESP  or HVAF for  Alternatives 2 through  5  has water sprays  in the
fume duct to  reduce the  inlet gas temperature from 93°C (200°F) to 38°C
(100°F) to condense gaseous hydrocarbons.   Each baseline  (Alternative  1)
afterburner with  heat  recovery  has  an operating  temperature  of 482°C
(900°F),  and  each afterburner with heat recovery is operated at a higher
temperature of 760°C (1400°F) for  Alternatives 2 through 5.
     8.2.2.1.2   Filler surge bin and storage operation.   Each plant has
cyclones  for  Alternatives 1, 2,  and 3,  and each plant has  fabric filters
for  Alternatives  4 and 5.   These devices operate at 0.33 Nm /s  (700 scfm)
and  0.71  Nm3/s (1,500  scfm) in  small plants; and  0.66 Nm /s  1,400  scfm)
and  0.71  Nm3/s (1,500  scfm) in  medium  and large plants.   For the  cost
estimate, these  have  been  combined  to  give devices  with air flows of
 1.04 Nm3/s (2,200 scfm)  in small  plants and 1.37  Nm /s  (2,900 scfm)  in
                            They  all  have  inlet  gas  streams at ambient
medium and  large  plants.
temperatures.
     8.2.2.1.3  Parting agent bin and storage operation.  Each plant has
two cyclones  for  Alternatives  1, 2, and  3,  and each plant has fabric
filters  for Alternatives 4 and  5.   Each  of these devices operates at
0.33 Nm3/s  (700 scfm)  in  small  plants and  at 0.33 Nm /s  (700 scfm) and
0.66 Nm3/s  (1,400 scfm) in medium and large plants.   For the cost estimate,
                                                O
these  devices were  combined to yield a 0.66 Nm /s (1,400 scfm) in small
plants and  0.99  Nm3/s  (2,100  scfm)  in medium and  large  plants.  They all
have inlet  gas streams at ambient temperatures.
     8.2.2.1.4  Asphalt  storage  operation.   The baseline  (Alternative  1)
plants have no controls on the asphalt storage  operation.  Each plant has
                                 8-78
-------
 one mist  eliminator on the asphalt storage operation for Alternatives 2
 through  5.   The  small  plants have a  0.21  Nm3/s  (450 scfm) unit, the
 medium have  a  0.35 Nm3/s (750 scfm) unit,  and  the  large plants have a
 0.425 Nm /s  (900  scfm)  unit.   All  mist eliminators  have  inlet  gas  stream
 temperatures of 54°C (130°F).
      8-2-2-]-5  Blowing still  operation.  All plants with blowing  stills
 (Configuration 1) are controlled by an A/B W/HR.  The afterburner operates
 at 2.8 Nm /s (6,000  scfm)  in  small and medium  plants and  at 3.3 Nm3/s
 (7,000 scfm) in large plants.   Each A/B W/HR for Alternatives 1, 2, and 4
 has an operating temperature  of  482°C (900°F), and each A/B  W/HR is
 operated  at a higher temperature of 760°C (1400°F) for Alternatives 3 and
 5.   The afterburner  operates  2,084 h/yr in  small  plants, 3,888 h/yr in
 medium plants,  and 3,872 h/yr  in large  plants.
     8-2-2.2   Description of the  Individual Pollution Control  Devices.
 All  of the individual  particulate  pollution control  devices used  by  the
 model  asphalt roofing plants  for  the  five regulatory alternatives were
 described  in Chapter 4.  A  brief description of  each device is given
 below.   Supporting  information and  calculations  are  given in  the
 reference.
     8.2.2.2.1   ESP.   All  ESP's are modular, low  voltage, multiple-pass
 units  equipped  with a fan,  liquid pump  and piping, and stack.  Each unit
 has  an assumed  drift velocity of  0.04 m/s  (7  ft/min)  and an  assumed
 pressure drop of 500 Pa (2 in. of  H,,0)  for  the  ductwork and  ESP system.
     8'2-2-2-2   ESP with cooling systems.  All ESP's with cooling systems
 are  as  previously described  except that they now include  a water pump,  a
 recirculating water storage tank, water  sprays installed in the fume duct
 to cool the  fume,  a  sump for  oil-water separation,  and the  associated
 piping.
     8.2.2.2.3   HVAF.   The  HVAF units  previously described in Chapter 4
 are equipped  with  a glass fiber mat filter,  fans  and motors, a 20-ft
 stack,  ductwork, and necessary controls.  Each unit has an assumed pressure
 drop of 6,200 Pa (25  in.  of H£0) for the  ductwork and filter system.40
The assumed power  requirements for each unit are 95 kW (127 hp), 100 kW
 (134 hp),  105 kW (141  hp), and  108 kW (144 hp),  respectively.
                                8-79
-------
     8.2.2.2.4   HVAF with  cooling systems.   All  HVAF's with  cooling
systems are  the same  as the HVAF's  given  above,  with cooling systems
identical  in  size  and  water flow to those  for ESP's of the same size.
The power requirements  for the  HVAF's with  cooling  systems  are increased
because of the  water pump  and are assumed to be:  97 kW (130  hp)  for  the
4.72 Nm3/s  (10,000 scfm)  unit;  103 kW  (138 hp)  for  the  4.93 Mm /s
(10,450 scfm)  unit;  108 kW  (144  hp)  for the  5.07  Nm /s (10,750  scfm)
unit; and 111 kW (148 hp)  for the 5.14 Nm3/s (10,900 scfm)  unit.
     8.2.2.2.5   Afterburner with heat recovery.  All  afterburners are
equipped with a counterflow shell and tube  heat exchanger and are designed
to  operate  at an  incinerator outlet temperature  of up  to 815°C (1500°F)
with  a  0.3-  to 0.5-second  residence time.  They  are designed to  operate
on  No.  2  fuel oil  at  an efficiency of 98 percent, and the  heat exchanger
recovers 50  percent of  the heat.  The pressure drop through the system  is
2,000 Pa (8  in.  of H20) for the ductwork, heat exchanger, and  incinerator.
The units  all  have an  incinerator,  burners,  stack, controls, fan, fan
motor,  and  necessary  auxiliary equipment.40   Each  of  the  two smaller
units  has  power requirements of 15 kW (20 hp)   for the fan motor  and fuel
pump; and each  of  the  three larger units has power  requirements of 22.4 kW
 (30 hp) for  the fan motor  and  fuel  pump.
      8.2.2.2.6   Cyclone.  The  cyclones  are  single-chamber  units constructed
 of 10-gauge carbon steel  and  have a support,   hopper,  scroll, fan,  fan
 motor,  and ductwork as auxiliary equipment.   The  air  flow through  the
 units is 18.3  m/s (3,600  ft/min)  and the pressure  drop is about 500 Pa
 (2 in.  of H?0).41 The  power requirements for  the fan motors  are  assumed
 to be  1.5 kW (2 hp) for the small  unit; 2.2 kW (3  hp)  for  the next three
 units;  and 15 kW (20  hp) for the two large units, respectively.
      8.2.2.2.7  Mist eliminators.  These units are fiber mist eliminators
 consisting  of  a packed bed of fibers  retained between two concentric
 screens.   Mist particles  are  collected on the fibers and become part of
 the liquid  film which  wets the fibers.  The collected  liquid  drains  down
 to the bottom  of  the  unit and  is recovered.42 The pressure  drop through
 each unit is about 2,500  Pa (10 in.  of  H20).   The  power requirements for
 the fan motor  for each unit are  2.2  kW (3 hp) and 3  kW (4 hp)  for  the
 respective units.
                                 8-80
-------
      8-2-2-2.8  Fabric filters.   The  fabric filters are constructed  of
 carbon steel with  dacron polyester bags.  The collector has a pulse-jet
 type cleaning mechanism  and  a  screw conveyor  system.   The  fan  is  located
 at the outlet side of the unit so that the compartmented fabric filters
 operate at negative pressure.  The maximum air-to-cloth ratio is 5.0, and
 the pressure drop is 2,500 Pa (10 in.  of H20) through the system.42   The
 power requirements for the fan motors  are 3.7 kW (5 hp), 5.6 kW (7.5 hp),
 5.6 kW (7.5 hp), and 7.5 kW (10 hp) for the respective units.
      8-2-2.3    Annual Particulate Emissions From Model Asphalt Roofing
 Plants and the Control Systems.    This  section  is  concerned with  the
 particulate emissions from five separate asphalt roofing plant  operations:
 (1) the saturator,  wet  looper, and coater;  (2) filler surge  bin  and
 storage silos;   (3)  parting  agent bin  and storage silos;  (4)  asphalt
 storage tanks;  and (5) blowing stills.   The uncontrolled  emissions,
 emissions  from  installed control  systems,  and the quantities of parti -
 culate  pollutants  collected from  each  operation  for  each plant size and
 configuration for  the  five  regulatory alternatives  and  for  plants with  no
 controls are discussed in this section.  First,  the quantities  of parti-
 culates that would  be  emitted annually  from model plants with no controls
 are determined.   Next,  the  quantities  of  particulates that would  be
 emitted annually from the various control devices  and  the  efficiency of
 the devices  are  discussed.  Then the quantities of  particulate pollutants
 that are collected by  each device  and each system installed  in each  model
 plant size, with and without blowing stills, are given  for each regulatory
 alternative.   Finally, the efficiencies of the  control devices  are
 discussed.
     8-2.2.3.1   Uncontrolled emissions.   The  uncontrolled emissions  from
 each plant are   derived  from  information  contained in Chapter 3 and
 Chapter 6.   The  particulate  loading of the exhaust gases from the hoods
 and ductwork on the filler surge bin and storage operations is calculated
 from data  in Table 6-4 that show  that  the uncontrolled operation emits
5.13 kg/h  (11.3  Ib/h)  at  a small plant,  which  has an  exhaust gas rate of
 1.04 Mm /s   (2,200  scfm),  and  the  particulate  loading from  the  parting
agent bin  and storage  operation is assumed to be  the same as from the
filler operations.   The particulate loading of the exhaust gases from the
                                8-81
-------
asphalt storage operation  is  calculated from data in Table 6-4 that the
uncontrolled operation emits 5.13 kg/h (11.3 Ib/h) at a small plant which
has an  exhaust  gas rate of 0.21 Nm3/s (450 scfm).  The calculations are
shown below.
     1.  Filler and parting agent operations:
          Particulate loading =  (5.13 kg/h)(h/60 min )(min/1.04 Nm )
                  (1,000 g/kg) =  82.5 g/Nm3  (0.60 gr/scf)
     2.  Asphalt  storage operations:                              ^
          Particulate loading =  (0.75 kg/h) (h/60 min)(min/0.21 Nm )
                  (1,000 g/kg) =  59.4 g/Nm3  (0.43  gr/scf)
     Given  the particulate  loading,  the annual uncontrolled  emissions
 from  each operation for each plant size can be calculated.  The annual
 particulate emissions from the  saturator  and coater operation are taken
 from the emissions test data and calculated to model  plant sizes.
     Table  8-34 shows the annual uncontrolled particulate emissions from
 each  operation for each size plant.
      8.2.2.3.2  Emissions from baseline control systems.   The quantities.
 of particulates  emitted from the control  systems are taken in part  from
 Table 6-4,  which shows:
      1.  the ESP, HVAF, and A/B on the  saturator, wet looper, and coater
 operation emit 16.67 kg/h (36.75 Ib/h);
      2.  the A/B W/HR  operating at 482°C  (900°F) on the  blowing stills
 emits  37.19 kg/h (82 Ib/h)  during the saturant  blow  and  45.76 kg/h
 (100.8 Ib/h) during the coating blow; and
      3.  the cyclones  on the material  handling  systems  emit 0.54 kg/h
 (1.2 Ib/h).
      All the control  devices  on  the  small plant operate  4,000 h/yr,
 except the mist eliminator, which operates  4,800 h/yr, and the A/B W/HR
 on the blowing  stills, which  operates  2,000 h/yr.   The plant produces
 109,759 Mg (121,000 tons) of product each year.  The test data indicate
 that  the  average control  efficiency for  all three  control  devices  is
 93.3  percent.   Therefore, the  emissions from  the control  devices can  be
                                  8-82
-------





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calculated in a manner similar to those shown below for the ESP with heat
exchanger:
     ESP with cooling system emissions = 65.89 (100-93.3) =
                         4.39 Mg/yr (4.84 tons/yr)
     The  annual  control  emissions  calculated for  each  control  device  are
shown  in  Table 8-35,  which also shows the annual uncontrolled emissions
for  each  operation and the amount  of  pollutants  collected annually by
each control device.
     8.2.2.3.3   Pollutants collected.  The amount of pollutants collected
annually  by each control device is  shown  in Table 8-35.   The amount  of
pollutant was  determined by subtracting the  quantity of control emissions
in Mg/yr (ton/yr)  from the uncontrolled emissions in Mg/yr (ton/yr).
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type of device used on each operation are shown in Table 8-36.  The test
data showed that the average  control  efficiency  for all  three saturator
control  devices was between 92 and 94  percent.  Cyclones  have an  efficiency
of 80 percent, the fabric filters an assumed efficiency of 98.4 percent,
 and the mist  eliminator efficiency is assumed to be  98.0 percent.  The
 A/B W/HR system on the  blowing stills has an efficiency of 77.7  percent
 at  an  operating temperature  of  482°C (900°F) and an efficiency  of
 93.9 percent at an operating temperature of 760°C (1400°F).
      8.2.2.4  Capital Investment Costs.  The capital  investment costs of
 the pollution  control  systems defined in the previous two  sections  are
 given for  each model  plant in Tables 8-37  to 8-39.   The  costs given in
 these tables  include  the  cost of purchasing and installing the control
 equipment,  auxiliary equipment,  foundations and  supports, ductwork,
 stacks,  electrical systems, piping, insulation, painting, instrumentation,
 indirect costs  such as  engineering and construction overhead, contractor's
 fees,  and  contingencies.   All costs are  for  new equipment installed at
 the time the  plant  is built  and  are  given in November 1978 dollars.
      The capital  investment  costs estimated in  this  analysis are based
 upon  limited  specifications  for the equipment since  no detailed  specifi-
 cations  are available.  All  costs  are derived from  previous  estimates
 reported in the literature and have been updated for inflation using the
 Chemical  Engineering (CE) fabricated  equipment  cost index.  Since  the
                                  8-84
-------
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                                            8-90
-------
 pollution control equipment is not defined by detailed specifications and
 since the costs are adjusted for inflation with a broad index, the probable
 accuracy of the estimated costs is +30 percent.
      The total capital investment costs shown in the tables were derived
 by determining the costs  of individual control  systems for each operation.
 The methods and  assumptions  used  to arrive at  these costs are discussed
 below.
      8.2.2.4.1   ESP.   The cost (in December 1975 dollars)  of an uninstalled
 ESP without auxiliary equipment can  be  estimated  from the  following
 equation:
      Purchase  cost =  $75,000  + $27.56  (net plate area,  m2),  or
      Purchase  cost =  $75,000  + $2.56 (net  plate  area,  ft2).41
 The cost of auxiliary equipment,  including fans,  damper,  ductwork, fan
 motor,  and miscellaneous  items, adds  about 20  percent to  the basic ESP
 cost.   '     Installation  costs  vary  between 50 percent  and 150 percent of
 the basic  ESP  and  auxiliary  equipment cost;  in  this analysis  an instal-
 lation  cost  of  75 percent is  assumed.40'41
      The  cost  of  the ESP  system  must be  adjusted  from December 1975
 dollars  to November 1978  dollars.   This is  done by using  the CE fabri-
 cated equipment cost  index, which rose from 196.4  in December 1975 to
 244.1 in November  1978.41'43
      The installed capital  equipment cost  (C) for  each ESP system (in
 November 1978 dollars  rounded to the nearest $1,000) is:
      1.   4.72 Nm3/s (10,000 scfm) ESP  system:
         C = [$75,000+($2.56)(8,200)](1.2)(1.75)(244.1/196.4) = $251,000
      2.   4.93 Nm3/s (10,450 scfm) ESP  system:
         C = [$75,000+($2.56)(8,500)](1.2)(1.75)(244.1/196.4) = $253,000
      3.   5.07 Nm3/s (10,750 scfm) ESP system:
         C = [$75,000+($2.56)(8,800)](1.2)(1,75)(244.1/196.4) = $255,000
     4.   5.14 Nm3/s (10,900 scfm) ESP system:
         C = [$75,000+($2.56)(9,000)](1.2)O.75)(244.1/196.4) = $256,000
     8.2.2.4.2  ESP with  cooling systems.   The  cost  of an ESP with a
cooling system  increases  the  above ESP system costs by the cost of the
cooling system.   The  installed cost of a  cooling system,  including the
purchase cost,  handling and setting, steel, concrete, electrical, piping,
                                8-91
-------
paint,  insulation,  and indirect costs, was obtained  from  suppliers  of
this equipment.  The  updated costs (rounded to the nearest $1,000) for
                                       40 43 44
cooling systems (HE) for each unit are:  '  '
     1.  4.72 Nm3/s (10,000 scfm) ESP system:
         Cooling system installed cost = $20,300
     2.  4.93 Nm3/s (10,450 scfm) ESP system:
         Cooling system installed cost = $21,200
     3.  5.07 Nm3/s (10,750 scfm) ESP system:
     4.
Cooling system installed cost = $21,800
5.14 Nm3/s (10,900 scfm) ESP system:
         Cooling system installed cost = $22,000
     The total  installed  capital investment cost for ESP's with cooling
systems  is  $271,300,  $274,200, $276,800 and $278,000 for the respective
systems.
     8.2.2.4.3   HVAF.   The installed cost of  an  HVAF system,  including
the  purchase cost  of the HVAF and  auxiliary  equipment,  installation,
engineering,  foundations,  ductwork,  stack, electrical, insulation, painting,
piping,  and indirect  costs,  is taken from Air  Pollution Control Technology
and  Costs:   Seven  Selected Emission  Sources.    The approximate cost (in
1974 dollars) of the  HVAF systems is $45,500/Nm3/s  ($15/scfm) for systems
in the size range  of  4.72 to 5.04 Nm3/s  (10,000 to  10,900 scfm).
     The 1974  cost is adjusted to  November 1978 dollars with the  CE
fabricated  equipment cost index, which  rose from 170.1 in  1974 to 244.1
in November 1978.41'43 Thus, the capital  investment cost (C) of the HVAF
systems (rounded to the nearest $1,000)  is:
      1.   4.72 Nm3/s (10,000 scfm) HVAF system:
          C  = ($15)(10,000)(244.1/170.1)  =  $215,000
      2.   4.93 Nm3/s (10,450 scfm) HVAF system:
          C  = ($15)(10,450)(244.1/170.1)  =  $225,000
      3.   5.07 Nm3/s (10,750 scfm) HVAF system:
          C  = ($15)(10,750)(244.1/170.1)  =  $231,000
      4.  5.14 Nm3/s (10,900 scfm)  HVAF system:
          C  = ($15)(10,900)(244.1/170.1)  = $235,000
      8.2:2.4.4  HVAF  with cooling system.   The  cost of an HVAF with a
 direct water spray cooling system  increases the HVAF system costs shown
                                 8-92
-------
 above by the cost of the cooling system,  and their costs are identical  to
 those used on the  ESP's.   The capital investment cost  (C) of each HVAF
 with  cooling system (rounded to the nearest $1,000)  is:
      1.   4.72 Mm /s (10,000 scfm) HVAF with cooling system:
          C = $215,000 + $20,300  =$235,300
      2.   4.93 Nm3/s (10,450 scfm) HVAF with cooling system:
          C = $225,000 + $21,200  = $246,200
      3.   5.07 Nm3/s (10,750 scfm) HVAF with cooling system:
          C = $231,000 + $21,800  = $252,800
      4.   5.14 Nm3/s (10,900 scfm) HVAF with cooling system:
          C = $235,000 + $22,000  = $257,000
      8-2.2.4.5   Afterburner with heat recovery.   The cost of an A/B W/HR
 is taken  from Air Pollution Control  Technology and  Costs:  Seven Selected
 Emission  Sources and  Capital  and Operating  Costs of Selected Air Pollution
 Control Systems.  '     The  capital investment costs of  the A/B W/HR and
 auxiliary  equipment is about $17,000/Nm3/s  ($8/scfm) in  1974 dollars.40
 Installation, ductwork, piping,  electrical,  insulation,  painting, supports,
 foundation,  stack,  and  indirect costs range  between 25 percent and
 100 percent  of the  basic equipment cost and are  assumed  to be 75 percent
 in this analysis.41
     The  cost of the A/B W/HR system must be adjusted from 1974 dollars
to November 1978 dollars.  This  is done by using the CE fabricated equipment
cost index, which rose from 170.1 in 1974 to 244.1 in November 1978.41'43
     The  installed  capital  cost  (C) of each A/B W/HR system (in Novem-
ber 1978 dollars rounded to the nearest $1,000) is:
     1.  2.83 Nm3/s  (6,000 scfm)  A/B W/HR:
         C = ($8)(6,000)(1.75)(244.1/170.1)  = $121,000
     2.  3.30 Nm3/s  (7,000 scfm)  A/B W/HR:
         C = ($8)(7,000)(1.75)(244.1/170.1)  = $141,000
     3.  4.72 Nm3/s  (10,000 scfm) A/B W/HR:
         C = ($8)(10,000)(1.75)(244.1/170.1) = $201,000
     4.  4.93 Nm3/s  (10,450 scfm) A/B W/HR:
     5.
C =. ($8)(10,450)(1.75)(244.1/170.1) = $210,000
5.07 Nm3/s (10,750 scfm) A/B W/HR:
C = ($8)(10,750)(1.75X244.1/170.1) = $216,000
                                8-93
-------
     6.   5.14 Nm3/s (10,900 scfm) A/B W/HR:
         C = ($8)(10,900)(1.75)(244.1/170.1) = $218,000
     8.2.2.4.6  Cyclones.   The capital  investment cost of  cyclones  is
taken  from  Capital and Operating Costs of Pollution Control  Equipment
Modules - Vol. II - Data Manual and Capital and Operating Costs of Selected
Air Pollution Control System!?1'44  The 1972 installed capital investment
cost of  each system, including purchase cost  of  cyclone  and  auxiliary
equipment,  installation,  ductwork,  piping,  supports,  instrumentation,
electrical,  insulation,  paint, and indirect costs,  is:   $4,800  for  the
0.66 Nm3/s  (1,400  scfm)  system;  $7,000 for the 0.99 Mm /s  (2,100 scfm)
system;  $7,200 for  the 1.04 Nm3/s  (2,200 scfm) system; and $9,600 for the
1.37 Nm3/s  (2,900  scfm)  system.44  These costs (adjusted for  inflation)
aqree  with  those  given  in Capital and Operating  Costs of Selected Air
                           41
Pollution Control  Systems.
     The capital  investment  cost (C)  of  each system (rounded to the
nearest  $100) adjusted from  1972  dollars  to November 1978 dollars with
the CE fabricated  equipment cost index is:
      1.   0.66 Nm3/s (1,400 scfm) cyclone:
          C = ($4,800)(244.1/136.3) = $8,600
      2.   0.99 Nm3/s (2,100 scfm) cyclone:
          C = ($7,000)(1.79) = $12,500
      3.   1.04 Nm3/s (2,200 scfm) cyclone:
          C = ($7,200X1.79) = $12,900
      4.   1.37 Nm3/s (2,900 scfm) cyclone:
          C  = ($9,600X1.79) = $17,200
      8.2.2.4.7  Mist eliminators.   The capital  investment cost  of  mist
 eliminators is  taken  from a  1977  EPA  report.45   The  estimated capital
 investment  cost for each system, in May  1977  dollars,  is:   $17,100 for
 the 0.21 Nm3/s  (450 scfm) system; $25,500 for the  0.35  Nm /s (750  scfm)
 system;  and $30,600 for  the  0.425 Nm3/s (900  scfm)  system.
       These  capital investment costs are adjusted using the CE fabricated
 equipment  cost index,  which rose from 211.9  in  May  1977 to 244.1  in
                                       43 46
 November 1978,  or about 15.2 percent.
                                  8-94
-------
      The capital  investment cost (C) of  the  mist eliminator system is:
      1.  0.21 Nm3/s (450 scfm) M/E:
          C = ($17,100X1.152) = $19,700
      2.  0.35 Nm3/s (750 scfm) M/E:
          C = ($25,500)(.1.152) = $29,400
      3.  0.425 Nm3/s (900 scfm) M/E:
          C = ($30,600)(1.152) = $35,300
      8-2-2.4.8  Fabric filters.  The  capital  investment cost of fabric
 filter systems  is taken from  Non-metallic Minerals Industries Control
 Equipment Costs.     The capital investment cost of fabric filter systems
 (in December 1976 dollars)  including the collector, auxiliaries, instal-
 lation,  foundation,  stack,   piping,  ductwork,  insulation,  painting,
 electrical,  and indirect costs  is:   $20,000 for the 0.66 Nm3/s (1,400 scfm)
 system;3$23,800 for the 0.99 Nm3/s  (2,100 scfm)  system; $24,300 for the
 1.04 Nm /s  (2,200  scfm)  system;  and $27,300 for the 1.37 Nm3/s (2,900 scfm)
 system.
      The  costs  are adjusted  from December 1976 dollars  to November  1978
 dollars with the  CE  fabricated equipment cost index, which  rose from
 208.3 in  December  1976 to 244.1  in  November 1978,  or about
 17.2  percent.   '    The  November 1978  capital  investment cost  (C) of  each
 fabric  filter system (rounded to the nearest $100)  is:
      1.   0.66 Nm3/s (1,400 scfm) fabric filter:
          C = ($20,000)(1.172) = $23,400
      2.   0.99 Nm3/s (2,100 scfm) fabric filter:
          C = ($23,800X1.172) = $27,900
      3.   1.04 Nm3/s (2,200 scfm) fabric filter:
          C = ($24,300X1.172) = $28,500
     4.   1.37 Nm3/s (2,900 scfm) fabric filter:
         C = ($27,300X1.172) = $32,000
     8-2-2.5   Capital  cost  increase from  baseline.   The  capital cost
increase from the baseline for control systems for Alternatives 2 to 5 at
a given plant,  with  or without blowing stills,  is  given in Table 8-40.
For a small  plant  with an ESP or HVAF, the capital cost increase of the
pollution control  system is  $40,900  for Alternatives 2 and 3 and $71,300
for Alternatives 4 and 5;  for a medium plant,  the capital cost increase
                                8-95
-------
     TABLE 8-40.  CAPITAL COST INCREASE FROM BASELINE
               FOR POLLUTION CONTROL SYSTEMS
Plant
size
Small
Medium
Large
Saturator
control device
ESPa or HVAFb
A/B W/HRC
ESP or HVAF
A/B W/HR
ESP or HVAF
A/B W/HR
Regulatory
alternatives
2 and 3
40,900
19,700
71,500
29,400
97,900
35,300
Regulatory
alternatives
4 and 5
7,1,300
50,100
101,700
59,600
128,100
65,500
aESP = electrostatic precipitator with cooling system.
bHVAF = high velocity air filter with cooling system.
CA/B W/HR = afterburner with heat recovery.
                               8-96
-------
  is  $71,500 for Alternatives 2 and 3 and $101,700  for Alternatives 4 and
  5;  and for  a large plant,  the  capital  cost increase  is  $97,900  for
  Alternatives  2  and 3 and  $128,100  for Alternatives 4 and 5.  When  an
  A/B W/HR  is  used to control the  saturator,  wet looper,  and  coater,  the
  capital cost  increase for a smal-1 plant is $19,700 for Alternatives 2 and
  3 and  $50,100 for Alternatives 4 and 5; for a medium plant,  the capital
  cost  increase is $29,400  for  Alternatives 2 and  3 and  $59,600 for
  Alternatives 4  and  5;  for a large plant,  the  increase  is $35,300 for
 Alternatives 2 and 3 and $65,500 for Alternatives 4 and 5.
      8'2'2-6  Annualized  Cost.   The annualized costs  for the pollution
 control systems  are the sum of variable costs and  fixed costs.  Variable
 costs include operating labor,  supervision,  maintenance labor, payroll
 charges,  maintenance and repair materials, and process utilities.  Fixed
 costs  include capital   recovery,  taxes,  insurance,  and  general  and
 administrative expenses.
      Table 8-41  shows the  total  annualized  cost  for each pollution  control
 system for each  plant  size and configuration for  the  five regulatory
 alternatives.
      The  inputs  used to determine the annual ized  cost  of the control
 systems are discussed below.
      8'2-2-6-1   Variable costs.   The variable  costs include  labor and
 supervision,  maintenance and repair  materials,  and process  utilities.
      Each  pollution  control  device requires an  operator to periodically
 check  the  instruments,  controls,  and the unit for  proper  operation, and
 requires maintenance  labor to maintain and  service the  equipment.  The
 increase  from baseline  in  the amount of  time required to  operate  and
 maintain  the  control  devices and  the associated labor  and supervision
 costs are shown in Table 8-42.
     The amount  of operating labor required for each device is based on
 the assumptions  that the ESP, HVAF, cyclone, mist eliminator,  and fabric
 filter require 0.5 hour  of operating labor per  day (0.25  h/shift), and
 that  the  afterburner with  heat  recovery system requires 2 hours of
 operating  labor  per  day (1 h/shift).   The amount of maintenance  labor
 required for  each  device is based  on the assumptions that  the ESP, HVAF,
afterburner with  heat recovery, mist eliminator, fabric filter, and heat
                                8-97
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exchanger systems require 4 hours maintenance per week, and the cyclones
require 2 hours .maintenance  per week.  These assumptions .are  based on
information  given  in Air Pollution Control Technology and Costs:   Seven
                          40
Selected Emission Sources.
     The costs  shown in Table 8-42  are based on  operating  labor wages  of
$6.86/h and  maintenance labor wages of $7.50/h.33   Supervision costs are
10 percent of operating labor, and  payroll charges  are 20  percent of the
sum  of operating labor,  supervision,  and maintenance  labor wages.
     The  annual cost  of maintenance  and  repair materials, operating
supplies, and replacement parts is  estimated to  be  3  percent of the total
capital  investment  cost of  the  ESP, HVAF, and afterburner with  heat
recovery  systems and  5 percent  of the cyclone, mist  eliminator,  and
                        40 44
fabric  filter systems.    '
      Tables  8-43 and 8-43a show  the annual process utility requirements
 and utility  costs  for  each  pollution control device  used  in  the model
 asphalt roofing plants.  The utility requirements  are calculated from  the
 information given in Section 8.2.2.2 for each device.  The annual utility
 costs are  based on  a cost  of $0.106/m3   ($0.30/100 ft )  for water;
 $137.40/m3  ($0.52/gal) for  No.  2   fuel  oil;  and  $11.39/gigajoules*
 ($0.041/kWh) for electricity.
      The fuel  requirements  for the  afterburners with  heat recovery are
 not reduced for the heating value  of the  hydrocarbons in  the  gas stream.
 This is considered a recovery credit and  is discussed  in Section 8.2.2.6.3.
      8.2.2.6.2   Fixed costs.   Fixed costs  include  capital  recovery,
 taxes,'insurance,  and general and  administrative  cost for each system.
      The total  capital investment  cost of each system is  recovered over
 its depreciable life, which  is  assumed to be 20 years for each control
 device.   (This assumption is  generally valid  for  all  devices except  the
 afterburner with  heat  recovery, which  has a life  of about 10 years.  To
 simplify  calculations, a 20-year  life  is assumed for all the devices.)
  Interest  is assumed to be  10 percent.   Therefore, the capital recovery
  ^Gigajoule is a billion joules.
                                  8-100
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 factor (n=20,  1=10)  is 0.11746.41  This  factor, multiplied  by  the  capital
 investment  cost for  each pollution  control device, gives  the capital
 recovery cost.
      The annual cost of taxes and insurance is assumed to be 2 percent of
 the total capital  investment cost for each control device.  General and
 administrative costs also are assumed to be 2 percent of the total capital
 investment cost.
      The annualized  cost  for each control device  is shown  in Table 8-44.
 These costs  are used to  determine the  annualized cost for each plant
 shown previously in Table 8-41.
      8-2.2.6.3  Recovery credits.  The  materials  collected by the ESP,
•ESP with heat  exchanger,  HVAF,  HVAF  with heat exchanger,  and  the mist
 eliminator on  the  asphalt storage tanks are liquid hydrocarbons.   The
 afterburners with  heat  recovery on the  saturator operation incinerate
 liquid hydrocarbons.   The cyclones and fabric filters collect filler and
 parting  agent for recycle.  The afterburner with heat recovery operating
 at  760°C  (1400°F) on the  blowing still  incinerates liquid  hydrocarbons.
 It  is  assumed that  all of  the liquid  hydrocarbons  collected  have  the  same
 dollar and heat  value as No. 6  fuel  oil which costs about $79.30/m3
 ($0.30/gal)  in  November  1978 dollars  and  has  a  heating   value of
41.8 gigajoules/m3  (150,000 Btu/gal).49'50  The filler has a value  of
$17.64/Mg  ($16/ton) and the parting agent has a value of $41.90/Mg  ($38/ton).
The  liquid hydrocarbons burned  in the afterburner with heat  recovery
systems  have   an  assumed heating  value   of  3.96 gigajoules/m3
(142,000 Btu/gal), which  is  the heating  value of  No. 2 fuel oil.  The
dollar value  of No.  2 fuel oil is $137.40/m3  ($0.52/gal).   The dollar
value  of^ No. 2 and No. 6  fuel  oil  is based on a  specific  gravity of
903 kg/m  (7.54 Ib/gal) for No.  2 fuel oil and 960  kg/m3 (8.0 Ib/gal) for
No.  6 fuel oil.     The heat recovery system is used to generate steam or
to preheat asphalt.   The heat released  in burning  the liquid hydrocarbon
replaces an equivalent quantity of heat from burning No. 2 fuel  oil.  The
particulates from the saturator are assumed to be 100 percent combustible,
and those  from  the  blowing still  cyclone  are assumed to  be 50 percent
combustible.
                                8-103
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       Recovery credits are not  considered  in any of the annualized costs
  reported in this  document because there are not enough data on  the amount
  of product that is  being recovered.
       8'2'2-7  Annualized Cost Comparisons.   The annualized  costs  of  the
  baseline (Regulatory  Alternative 1) pollution  control  systems  are lower
  than  those of  the  other four regulatory alternatives.  The annualized
  costs  for Alternatives 2 to  5  increase by the annualized  cost  of the
  cooling  systems on  the  ESP and  HEAP  and by the cost  of the additional
  fuel  required to operate the A/B W/HR  at  a higher temperature  on the
  saturator, wet  looper, and coater operation; and increase by!the annualized
  cost of  the mist eliminator on the asphalt storage tanks.  Alternatives 3
  and 5  incur an increase in cost  for  the net fuel  required  to raise the
 operating temperature of the A/B W/HR from 482°C (900°F) to 760°C (1400°F).
 Alternatives 4 and 5 incur an additional annualized cost for using fabric
 filters  on  the  material  handling systems instead of cyclones,  since the
 annualized cost of fabric filters is greater than the cyclones.
      Table 8-45 shows  the increase in  the annualized costs  of the pollution
 control  systems for each plant size and  configuration  for Alternatives 2
 to 5 as  compared to the  baseline pollution control systems and shows the
 percentage increase  in annualized costs  compared to the baseline annualized
 costs  without  recovery  credits.   The increase  in  annualized costs is
 least  for Alternative 3  followed  by Alternatives  2,  5, and 4 (in  that
 order)  for plants with blowing stills  and is less for Alternatives 2 and
 3 than  for Alternatives 4 and  5  for plants without  blowing stills.
     Comparison  of the three alternative control devices on  the  baseline
 saturator,  wet looper, and coater operation in Table 8-42 shows  that the
 ESP  is  the  least expensive to  operate, followed  by  the  HVAF  and A/B  W/HR.
 The  ESP costs $6,700 less to  operate  than  the HVAF and $72,400  less to
 operate  than the A/B W/HR at  small plants;  costs  $12,700 and $142,800
 less than the respective  devices  at  medium  plants;  and  costs $18,800 and
 $212,600  less than the respective devices at  large plants.  Comparing the
 three  alternative  devices on  the saturator,  wet  looper, and coater
 operation  for  Alternatives 2 to  5  shows  that  the ESP with cooling system
 costs $6,900 less to  operate  than the  HVAF with cooling system  and
$108,000  less  to operate  than  the A/B W/HR at  the  small  plants; costs
                                8-105
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  $12,800 and $213,800  less  than the respective devices at medium plants-
  and costs $18,300 and $317,600 less than the respective devices at large
  plants.
       Comparison of the two alternative devices on the materials handling
  operations shows  that the cyclones are less expensive to  operate than the
  fabric filters.   The  annualized cost differences  between  the  two types of
  devices  are $9,000 at small plants and $9,400 at  medium and large  plants
  These  cost  differences  account   for  the   cost  differences   between
  Alternatives 2  and  4 and for  the  cost  differences between Alternatives 3
  and 5.
      Comparison of  the annualized costs of the A/B  W/HR  on the blowing
  stUls at  the two operating temperatures shows that the higher temperature
  760°C  (1400°F)  operation costs more than  the lower  temperature 482°C
  (900°F)  operation.  The  annual  cost difference is $13,100 at the  small
 and medium plants and $20,600 at the large plants.  These cost differences
 account for the cost differences between Alternatives 2 and 3  and between
 Alternatives 4 and 5.
      8'2'2-8  Cost Effectiveness.   The cost effectiveness of  a device or
 system is  simply  the  annualized cost of the device or system  divided  by
 the amount of pollutants  collected in  megagrams (tons) per year   The
 lower  the cost effectiveness  in dollars per megagram (dollars per  ton)
 the more  cost effective is the device or system.
     Table  8-46  shows  the  cost effectiveness of  each  individual  pollution
 control  device  considered in  this  analysis.   Table 8-47 shows the cost
 effectiveness  from baseline of each control  system for each plant size
 and configuration  for  Regulatory Alternatives 3 and 5.  The cost  effective-
 ness of individual control devices and  control  systems used on the  model
 asphalt roofing plants are compared in the following two sections.
     8'2-2-8-1     Cost effectiveness comparisons of individual  control
 devices.  An examination  of  Table  8-46  shows that  the  cost effectiveness
 of  the devices used on the saturator, wet looper, and  coater operation  is
 about $958/Mg  ($869/ton)  for  the   ESP with  cooling system,  $l,070/Mg
 ($971/ton)  for the HVAF with cooling system, and $2,650/Mg ($2,400/ton)
 for the A/B W/HR operating at  760°C (1400°F).  The cost effectiveness of
the devices used on  the material handling systems  ranges  from $259/Mg

                                8-107
-------
         TABLE 8-46
         TABLh a  4b.
COST EFFECTIVENESS  OF  POLLUTION CONTROL DEVICES
         .___	.  . n n. . A i  -r- r\s\r\r~T M/"* n| A M~TC
^^ — .^— ^— — —
Control
device
ESP/HEb
HVAF/HE6
A/B H/HRd
A/B W/HR
CYCe
F/Ff
H/E9
•n •'
_ —
-
Operating
characteristics
.. - . 	 7 — E~T nr TOFT
till •*/ S
4.93
4.93
2.83
2.83
2.83
2.83
3.30
3.30
4.93
0.66
0.99
1.04
1.37
0.66
0.99
1.04
1.37
0.21
0.35
0.425
V sc i in;
..
(10,450)
(10,450)
(6,000)
(6,000)
(6,000)
(6,000)
(7,000)
(7,000)
(10,450)
(1,400)
(2,100)
(2,200)
(2,900)
(1,400)
(2,100)
(2,200)
(2,900)
(450)
(750)
(900)
38 (100)
38 (100)
482 (MO)?
760 (1400)"
482 (900)J.
760 (1400)J
482 (9001
760 (1400)
760 (1400)
Ambient
Ambient
Ambient
Ambient
Ambient
Ambient
Ambient
Ambient
54 (130)
54 (130)
54 (130)
. 	
Cost
Annualized
cost ($)
.
58,900
65,800
26,840
34,900
69,200
93,400
79,200
103,100
163,000
3,600
4,500
4,800
5,600
7,900
8,900
9,300
10,200
7,000
8,800
9,300
	 —
	 	
effectiveness in $/Mq ($/ton)
Pollutants
collected
Mg (tons)
--
61.50
61.50
293.7
355.3
612.8
699.4
733.8
886.0
61.50
10.45
15.62
16.43
21.65
12.85
19.28
20.20
26.63
3.52
5.90
6.90
	 • 	
(67.79)
(67.79)
(324.0)
(391.5)
(675.6)
(771.1)
(808.9)
(977.0)
(67.79)
(11.52)
(17.22)
(18.11)
(23.87)
(14.17)
(21.25)
(22.27)
(29.35)
(3.88)
(6.50)
(7.61)


tost
effectiveness3
J/Mg $/ton
958
1,070
91
98
113
134
108
116
2,650
344
288
292
259
615
462
460
383
1,988
1,492
1,348

869
971
83
89
102
121
98
106
2,400
313
261
265
235
558
419
418
348
1,804
1,354
1,222

^Cost effcctivenBSS is the annual ized  cost OT tne PL. .
 pollutants collected  annually (4,000  h/yr operation).
bESP/HE " electrostatic precipitator with cooling system
CHVAF/HE = high velocity air filter with cooling system.
dA/B H/HR - afterburner with heat recovery.
5VE * «ist eliminator.
fF/F « fabric filter.
                                 ?M/E = mist eliminator.
                                 .Data based on  2,000 h/yr operation.
                                 JData based on  4,000 h/yr operation.
                                             8-108
-------

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8-109
-------
($235/ton) to "$344 ($313/ton)  for  cyclones, and ranges  from  $383/Mg
($348/ton) to $615/Mg ($558/ton) for fabric filters.   The cost effective-
ness of  the  mist eliminator on the  asphalt  storage  tanks ranges from
$l,348/Mg ($1,222/ton) to  $l,988/Mg  ($1,804/ton).   The A/B W/HR on the
blowing stills has a cost effectiveness which ranges from $91/Mg ($83/ton)
to $134/Mg  ($121/ton)  when operating at 482°C  (900°F),  and  ranges from
$98/Mg ($89/ton)  to  $116/Mg ($106/ton) when  operating  at 760°C  (1400°F).
     These data indicate that the most cost  effective device for controlling
the  saturator, wet  looper,  and  coater  operation  under  Regulatory
Alternatives  2 to  5  is the  ESP  with  cooling  system.   The HVAF with cooling
system  costs  about  $112/Mg ($102/ton)  more  than the  ESP  with  cooling
system.   The A/B W/HR operating at  760°C  (1400°F) costs  about  $l,692/Mg
($l,531/ton)  more than  the ESP with heat exchanger.  The A/B  W/HR  is
about  two times as  expensive  on a  dollar-per-megagram (dollars-per-ton)
basis  as the  other  two  devices installed on the saturator,  wet looper,
and coater operation.
     The data given in Table  8-46  also indicate the cyclones  on the
filler surge  bin  and  storage  operation, and the parting  agent bin  and
 storage operation,  are more cost effective  than the fabric filters.   The
 fabric filters cost about $300/Mg  ($270/ton) to $480/Mg ($435/ton)  more
 than the cyclones.  This  indicates that Alternatives 4  and  5,  which use
 the fabric  filters, are less  cost  effective than Alternatives  2 and 3,
 which use the cyclones.
      8.2.2.8.2  Cost effectiveness  comparisons of regulatory alternatives.
 The data in Table 8-47 indicate that the most cost effective regulatory
 alternative  is No.  3 and that  Alternatives  3 and 5 are more cost effective
 than Alternatives 2 and 4.
 8.2.3   Cost  Summary
      The capital investment  costs,  annualized costs, and unit product
 costs for  new model asphalt roofing plants  with pollution control systems
 are given for small, medium,  and  large plants, both with  and without
 blowing stills, for the  five  regulatory  alternatives.   These costs are
 derived from the information presented  in the previous two  sections
  (8.2.1  and 8.2.2).
                                  8-110
-------
       The  capital  investment costs  represent the  total  investment  required
  to  construct  new  model  asphalt  roofing  plants  and  install  a  new pollution
  control  system,  and include direct  costs,  indirect costs, contractor's
  fee,  and  contingency.   Tables 8-48 to 8-50  show  the total  capital  invest-
  ment  cost for each regulatory  alternative  and plant configuration (with
  or  without blowing stills)  for small,  medium,  and  large plants,
  respectively.   The  small plants cost $9,178,000  to $9,577,000; the medium
  plants  cost  $14,948,000  to $15,589,000; and  the  large  plants cost
  $17,603,000 to $18,388,000.  The pollution  control  systems cost $232,000
  to $467,000 for small plants, $447,000 to $758,000 for medium plants,' and
 $650,000  to $1,050,000  for large plants.  The pollution control systems
  represent 2.5 to  4.9 percent of the total  capital  investment cost of
 small  plants,  3.0 to 4.9 percent of the  total capital  investment cost of
 medium plants, and  3.7  to  5.7 percent  of the total capital  investment
 cost of large  plants.
      The  annualized  costs  represent  the variable,  fixed,  and  overhead
 costs  required to  operate  the plants  and represent  the  variable and fixed
 costs  required to operate the pollution control systems.  Tables 8-51  to
 8-53 show the  total annualized  cost  for each regulatory alternative and
 plant  configuration for small,  medium,  and  large plants,  respectively.
 The  annualized cost for small plants is  $14,761,000 to $14,920,000; for
 medium plants  is  $27,773,000 to $28,118,000; and for  large  plants' is
 $34,477,000  to $34,983,000.  The pollution  control  systems cost $64,000
 to $261,000 per year to  operate  at small  plants,  $121,000 to $435,000 per
 year to  operate  at medium  plants, and $175,000 to  $650,000 per year to
 operate  at large  plants.  The annualized costs of the  pollution control
 systems  represent  0.4 to 1.7 percent of the total  annualized  cost of
 small  plants,  0.4  to 1.5 percent of the total annualized cost of medium
 plants,  and  0.5  to  1.8 percent  of the total annualized cost of large
 plants.
     The unit  product  costs represent the annualized cost  of the plant
plus the annualized  cost of the pollution control system divided by the
annual  production  of roofing shingle  sales  square at each  plant.   The
small plants produce 1,030,000 roofing shingle  sales squares annually;
the medium plants  produce 2,060,000  sales squares  annually;  and the large

                                8-111
-------


















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plants produce'2,640,000 sales squares annually.  Tables 8-54 to 8-56 show
the  unit product costs  for each  plant  configuration and regulatory
alternative  for  small, medium,  and large  plants,  respectively.  The  cost
of a roofing shingle sales square  at small plants is $14.33 to $14.47; at
medium  plants  is $13.48 to $13.64; and  at  large plants  is  $13.06 to
$13.25.  The unit product cost  increase attributed to the annualized cost
of the  pollution control system at small plants is $0.06 to $0.25; at
medium  plants  is $0.06  to  $0.21;  and  at  large  plants is $0.07 to $0.25.
The  cost increases  attributable to the pollution control system operations
represent a cost  increase in  the total  unit product cost  of  0.4 to
1.7  percent at small  plants;  0.4 to 1.6 percent at  medium plants;  and 0.5
to  1.6  percent at large  plants.
8.3  OTHER COST CONSIDERATIONS
      This section  summarizes  the  cost currently being imposed upon the
 asphalt roofing and  siding manufacturing industry (ARM) as a result of
 (1) the Water Pollution Control Act (WPCA); (2) the Resource Conservation
 and Recovery  Act  (RCRA);  and (3) the Occupational  Safety  and Health
 Administration (OSHA).
      The  impact of the alternative regulatory  options  on  the  resource
 requirements  of State,  regional,  and local  regulatory and enforcement
 agencies  is also assessed  in this section.
 8.3.1   Water  Pollution  Control Act
      The  Development  Document  for Proposed  Effluent  Limitation Guidelines
 and New Source  Performance Standards  for the ARM industry was published
 by  EPA in 1974.51   At that time,  the cost to the industry to comply with
 best  available technology economically  acceptable  (BATEA)  was estimated
 to  be  $0.18/Mg ($0.16/ton) of product (1973 dollars).   Standards  based on
 these  guidelines  have  not yet been finalized.  Thus, the ARM industry  is
  not currently subject  to  specific provisions under the Water Pollution
  Control Act.
       The ARM industry has minimized waste water discharge in recent years
  by recirculating  cooling water,   substituting  cooling  rolls for  direct
                                  8-118
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contact cooling spray, and by recirculating cooling water used in emission
control systems.
     In the absence of specific performance standards for water emissions,
there  should  be no  cost  impact  that would  inhibit  the  industry's ability
to bear  the  increased costs associated with  air pollution  regulations.
8.3.2  Resource Conservation and Recovery Act
     The  Resource Conservation and Recovery Act  (RCRA) requires all
sources  of hazardous solid wastes  (1) to record quantities of hazardous
waste  generated;  (2) to label  all  containers used  in storage, transport,
or disposal;  (3)  to use  appropriate containers; (4)  to  furnish information
on chemical  composition  of such waste to handlers; (5)  to use a  system to
assure proper disposition of wastes generated; and (6) to submit reports
to  the Administrator  detailing quantities  of wastes generated  and  the
disposition of those wastes.   It  is not known if the ARM industry is a
 source of  hazardous waste.  Asphalt rooffng plants  presently  employ
 conservation techniques such as recycling paper and waste wood materials
 in the manufacture  of felt, reusing reclaimed oil as fuel or feed stock,
 and recovering waste heat  from  afterburners for use in other plant
 operations.  Therefore,  if the ARM industry becomes  subject to the
 provisions of  the  RCRA, only minimal costs may be incurred due to waste
 produced  from  additional  control  equipment  required to meet  the proposed
 alternative  regulatory  options.
 8.3.3  Occupational Safety and Health Administration Act
       Several  asphalt roofing plants were visited during the course of
 this  program.   It  was the opinion  of personnel at plants visited that the
 impact  of OSHA regulations on the industry is  minimal.  One particular
 plant had recently been  inspected by  OSHA  personnel  with no resulting
 violations.55   Several  OSHA offices have been contacted to  ascertain if
 there were any compliance problems in  the  ARM industry plants.  There
 were  no reported problems and no  reported violations.
       The control  equipment  required under  the  alternative regulatory
  options  should  result in minimal  OSHA-related compliance costs  (i.e.,
  electrical, plumbing, and similar equipment).   The ARM industry's ability
  to comply with any one of the alternative regulatory options would there-
  fore not be greatly  affected  by the economic impact of OSHA regulations.

                                  8-122
-------
  8'3-4  Resource Requirements Imposed on State. Regional, and Local
         Agencies
       The State  Implementation  Plans which  have been approved  by EPA
  require that a company make an  application and receive a permit  to construct
  before it is allowed to begin construction.56'57  The application for the
  construction permit must list  all  emission  sources,  the control system
  for  the emission sources,  the  nature of  the  emission (particulate,  CO),
  and  all  pertinent drawings.
       After construction  is  completed, the  States require  that the  company
  apply for and  receive  a  permit  to operate  before operation can be  started
  The  application  for operation must  contain pertinent  emission test data.
  Certain  local  and regional  agencies also require construction and operating
  permits  before construction of  a  new plant is started.58 However,  since
  no more than one new  asphalt roofing manufacturing plant per year  is
 estimated to be constructed  in the United  States through 1985,  the
 promulgation of  standards  for  this  industry  should  not impose  major
 resource requirements on State,  regional,  and local agencies.
 8.4  ECONOMIC IMPACT ASSESSMENT
 8-4.1  Introduction  and Summary
      8.4.1.1   Introduction.   This  section  will assess  the economic impact
 of the potential NSPS on asphalt roofing manufacturing plants.   Economic
 profile information  on the  industry presented in Section 8.1  will be a
 principal  input to this assessment.   The impact on individual  new plants
 will  be assessed by  using model  plants  that represent small,  medium, and
 large members  of the  industry.   Various financial  analysis techniques
 will  be applied to the model  plants.  These findings  will be  assessed,
 based on  the  industry profile, to determine industrywide  impacts.
      As  noted in previous chapters the fundamental manufacturing processes
 for which the  NSPS  is being  developed  is the asphalt saturator  and
 blowing  still  operations  of roofing material manufacture.  This process
 is  generally  similar throughout the  118 asphalt  roofing manufacturing
 plants.  While  the process is similar,  there is considerable difference
 in plant  size attributable to  the number of plant production lines.   For
the purpose of  this  study, small plants have  been  designated  as  those
                                8-123
-------
with one  roofing  line; medium plants, those typically having two roofing
lines; and large plants, those with two roofing lines plus an integrated
saturated felt line.  Saturated felt, an organic material frequently made
from recycled wastepaper and saturated with asphalt, is basic feedstock
for roofing manufacturing plants.
     8.4.1.2  Summary.   A discounted cash flow analysis demonstrates that
an  investment  in a new asphalt roofing manufacturing plant will  remain  a
profitable investment after  the addition of controls required by Regulatory
Alternative 5,  the most stringent alternative.   The investment is  profi-
table  for all three model plant sizes:  small, medium, and large.
      If  this additional  contrdl  cost is completely passed through  to
customers, it will  raise the price of  the product  by 0.1  percent,  a  minor
increase.   If the  control   cost  must  be completely  absorbed  by  the
manufacturers,  the profit margins  of  the  manufacturers  are such that a
reduction in profit margin  equivalent  to  0.1  percent of the price will
not have a major economic impact.
      The Alternative 5  controls  will  add,  at most, 0.7 percent to  the
total initial  investment required for a model  plant.   The additional
 0.7 percent is a minor  increase  and will  not restrict  capital  availa-
 bility for the new plant.
      Overall,  the  most  stringent alternative will  not have a significant
 economic impact on the asphalt roofing industry.
 8.4.2  Ownership.  Location, and Concentration Characteristics
      Ownership characteristics range  from  single plant,  privately  held
 operations to  large,  publicly held corporations  that own as many as 26
 roofing plants.  The publicly held companies are  diversified corporations
 within which the manufacture  of  shingles may  represent  one of  as  many  as
 10 distinct business  segments.   The various business  segments  may or may
 not  be  related  to asphalt  roofing,  such as building materials,  metal
 products, photography,  sugar operations, etc.
       In  the above companies,  the sales contribution from the asphalt
 roofing  products  line  ranges  from less than 10 percent to more than
 80 percent of  a  company's total  sales.
       The seven  largest members  of the  industry own 85  of the total
 118  plants  in  the  industry, or  77 percent.   The plants are distributed
                                  8-124
-------
  across the country, approximately  conforming to the population distri-
  bution.
       There is  a gradual  move underway in the industry toward consolidation
  of ownership through both  vertical  and horizontal  integration.60   Evidence
  of vertical  integration is provided by the fact that the manufacture and
  distribution of shingles was previously two distinct business activities
  carried on by  separate companies, but over  the  past  few years, corporations
  have  been increasingly  combining  the manufacture and distribution  of
  shingles  into  a  single line  of business.
      Evidence  of horizontal  integration  is  supplied  by the fact that from
  1969  to  1978  there  have been at least  eight mergers or acquisitions
 between companies in the industry.60
 8-4.3  Pricing Mechanism
      Transportation costs are an important element in the pricing mechanism
 of the asphalt roofing industry.   Manufacturers ship on a freight-equalized
 basls, i.e.,  the customer pays no more in freight than it would cost from
 the nearest supplier.    A customer pays only the freight costs from the
 closest available source of  supply,  regardless of the location of the
 shipping  or producing plant  for  a  particular order.   If a manufacturer
 ships  a greater distance,  that manufacturer  absorbs the additional  freight.
     Price shifts by one  manufacturer  of  asphalt and  tar  roofing products
 are readily communicated  throughout  the industry and  result in  an "evening
 up"  of  all  manufacturers' prices  within a short  time.
     Since  producers  of  asphalt  roofing  products generally sell their
 products  f.o.b. producer's plant with freight  costs to  the customer
 equalized  from  the competitive producing  or  shipping  point nearest  to the
 customer,  the producer  must often absorb a  portion of the translation
 cost of shipments.  Therefore, a producer located considerably farther
 away from  a given area than other producers selling  in that area cannot
profitably  sell  in that location  at  a  competitive price.  Transportation
costs become prohibitive  beyond a radius  of  approximately 300 miles from
the  manufacturer  when  another  manufacturer  is  located nearer  to  the
customer.
     8.4.3.1  Sup^Ty..   In  general  terms, the  supply and demand relationship
in the  asphalt  roofing industry can  best be summarized as  stable.
                                8-125
-------
      In spite "of  the integral  relationship between the asphalt roofing
manufacturing  industry  and the building  industry,  the asphalt roofing
industry is  not  a  highly cyclical industry as is the building industry.
Figure 8-5 illustrates this stability.  Production of asphalt roofing has
only varied  by +7.7 percent per year (as shown in Table 8-21 a) over the
years since  1973,  while over the same period of time new housing starts
have fluctuated  by as much as +34.3  percent in  a single year.     Produc-
tion of asphalt  roofing for 1977  is  3.7 percent below the peak production
of  1973.  The  reason  asphalt  roofing is not a highly cyclical industry  is
that there  are two segments in  the total  market.   One  segment is  the new
construction market and the  other segment  is  the reroofing market  for
existing  structures.   The reroofing segment of the market comprises from
50  to  70 percent of  the  total  market,  depending  on the activity  for new
construction.60   Since reroofing is  an appreciable amount of the total
market  and is stable,  it dampens swings  in asphalt roofing production.
Entry  into the  industry  is  relatively  easy for several reasons:   there
are no major patent  obstacles,  high technology is not involved,  and the
capital  requirements are  not excessive by manufacturing standards.  In
spite  of the ease of entry into the industry, the industry does not have
a history of excess expansions  of capacity that lead to oversupply problems.
      8.4.3.2  Demand.  On the other side  of the supply and demand equation,
the industry  has  inelastic  demand over a wide range.   The industry has
 experienced rapidly  rising  costs,  the  major cause of which  has been
 rising  asphalt  prices,  which  rose  41.8 percent  from 1974 to  1979.
 Figure 8-6 illustrates that production (demand) has increased at the same
 time that  prices have increased  sharply.   This  demonstrates inelastic
 demand.  An examination  of  published  statements by  industry members,
 actions by  industry  members, statements by industry observers, and industry
 profits and prices indicate  that producers have been able to pass through
 cost increases  and maintain  acceptable profits.   '
      There  are several  reasons  for the  industry's  inelastic demand.
 First,  a roof  is an  indispensable part of a building.   Second,  the
 competitive product (wood  shingles) costs about  60 percent more  than
 asphalt  shingles.   Third,  in  the volatile new housing segment  of the
 market, the cost  of  the  shingles, as sold  by the  manufacturer, represents
                                  8-126
-------
   Cumulative % of new housing starts from 1969 base.


                   asphalt roofin9 production
        70      71       72      73       74      75      76     77

        Figure 8-5.  Stability in Asphalt Roofing Production.

Sources:  Statistical Abstract of the United States 1977
          Section 8.1.                                  '
                          8-127
-------
a       Cumulative % of Asphalt Roofing Producer Price Index
       from  1969 base
ITTl  Cumulative % of Asphalt Roofing Production from
»-LU  1969  base

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       Figure 8-6.  Relationship Between Price and Production
                       Source:  Section 8.1
                                  8-128
-------
 less than one percent of the cost of a new house, so that small increases
 in the price of shingles produce very small increases in total new housing
 costs.
      The trend line for the production of asphalt roofing shows a 2 percent
 annual  growth rate  from  1969 to 1977.63  This growth rate is  likely to
 continue over the  next  5 years  for two reasons.  First,  the  reroofing
 market (additions,  alterations,  and repairs)  has been growing  over recent
 years and should continue  to generate firm demand for asphalt shingles.
 Second,  demand for  the new  housing sector of  the roofing market should  be
 high.   The population demographics are favorable for the housing market,
 particularly in  the important 25-  to  34-year-old age  group.  Also,  housing
 has  gained increased popularity  as  an inflation  hedge.
      To  date,  the changes in  capacity that have  been  announced by  industry
 indicate that supply should remain in line with demand.   Therefore, over
 the  next 5 years the  relationship  between supply and demand  should be
 sufficiently balanced to permit manufacturers to  pass through cost in-
 creases  and maintain profits, as they  have been able to do in the past
 when  supply  and  demand has  been  in  balance.
      8-4-3-3   New Developments.   A change  that  is  taking place in the
 industry  is  the  increased popularity  of fiber glass,  mat-based shingles.
 As  fiber glass,  mat-based  shingles increase  their market  share,  more
 companies  are  beginning  to  change  from the production of felt to  fiber
 glass.   The  market  share  of fiber  glass,  mat-based shingles has grown as
 follows:
               1975       1976       1977      1978 (est.)
               3.29%     4.45%     8.0%        12.0%
 By 1980  ARMA expects fiber  glass shingles  to  account for 20 percent of
 the market.  By  the early 1980's,   industry members expect fiber glass
 shingles  to  account  for  50 percent of the market,   as  discussed  in
 Section 8.1.
     Two reasons for the popularity of fiber glass mat shingles are their
 increased durability, 20 years of life versus  15 years for organic shingles,
and their  improved  fire rating, Class A (the highest)  versus Class C for
organic shingles.64
                                8-129
-------
     Fiber glass mat shingles are currently about 5 percent more expensive
than organic  mat shingles;  however,  fiber glass mat" shingles  require
approximately 12 percent  less  asphalt to produce, so that  in  the near
future,  as  the  cost of asphalt  continues  to rise, the 5 percent cost
                                C. d C.C.
difference should be eliminated.  '
     The only difference  in the manufacturing process between producing
fiber glass mat shingles  and organic mat shingles  is that the fiber glass
mat  shingles  bypass the  saturating step in  the  production  process.   In
this study  the  NSPS incremental costs and costs of production  are those
of the organic mat  operations.  This  results  in  a  conservative  finding of
NSPS impacts on fiber glass  operations.
8.4.4  Methodology
     This  section  will  describe the methodology  used to measure the
economic impact of  the  NSPS  on the  asphalt roofing manufacturing  industry.
The  principal economic impact that will  be  assessed is  the  effect  of
incremental  costs of NSPS control  on the profitability of new grassroots
plants.
     In  the analysis which  follows,  each  model  asphalt  roofing manufac-
turing plant will  be evaluated as  if it stands  alone, i.e.,  the  firm is
not associated  with any other business  activity  nor  is it associated  with
any larger parent  company.   This  assumption has the effect of isolating
the control  cost without any assistance from other business activities  or
firms.
      Since each  State  Implementation  Plan  (SIP) contains particulate
 emission control  standards, any new plant would have to  meet SIP standards
 in the  absence of  a NSPS.   Therefore,  incremental NSPS control costs are
 the control costs  over and above those baseline  costs required to meet
 the various SIP standards.
      Economic impact is  evaluated  on model  plants whose description is
 based on representative  characteristics of  new roofing  plants,  such as
 production capabilities, asset size, and other financial measures.   The
 model plants provide  an indication of the  degree of impact on all new
 plants  in  the  industry by incorporating into the  model  the major charac-
 teristics prevailing  in  various size segments  of the roofing industry.
                                 8-130
-------
 They do  not  represent any particular existing  plant,  as  any  individual
 plant will differ in one or more of the above characteristecs.
      The primary  analytical  technique employed in determining whether a
 capital  investment  should be  accepted  is discounted  cash  flow (DCF)
 analysis.  Additionally,  internal  rate  of return and  playback  will  be
 calculated.   DCF measures the discounted cash inflows over the life of an
 investment and compares  them  to the discounted cash outflows including
 the initial  investment,   If  the sum of the  discounted cash inflows  is
 equal  to, or greater  than,  the sum of the discounted cash outflows,  the
 investment provides a  return  equal  to,  or greater than, the firm's'cost
 of capital and  the investment should be  accepted.   If the  sum  of the  dis-
 counted cash  inflows  is less  than  the sum  of  the discounted  cash outflows,
 the investment  provides a return less than the  firm's  cost of  capital  and'
 the investment  should  be  rejected.
     Cash flow  is used because  it  is cash that is required to  meet  a
 firm's  obligations regardless  of how bright that firm's  financial picture
 may be  "on paper."  Essentially, determining  cash  inflow involves calcu-
 lating  net earnings and adding depreciation,  which is a  non-cash  expense.
     All  cash flows must  be discounted to  the present by use of an appro-
 priate  discount factor  to enable comparison.  The discount factor accounts
 for  the time  value of  money,  i.e.,  $1  today is  worth  more  than $1  a year
 from today.   In addition,  the  discount factor includes  a return  (profit)
 to  the  firm as  compensation for  bearing  the risk that  is inherent in  the
 investment.
8-4.5  Critical  Elements of the DCF
     Calculations developed by  the  DCF method depend on the validity  of
the elements  that comprise the DCF equation.   These elements  are:
     1.   project life;
     2.   depreciation;
     3.   hours of annual operation;
     4.   revenue and cost of  manufacture;
     5.   control costs;
     6.   control  cost  passthrough  versus control cost  absorption;  and
     7.   discount factor.
                                8-131
-------
     The project life of the investment is taken as 10 years, the useful
life of most  of  the major pieces of production  equipment  found in  the
plants.  Some of the equipment should last longer and the building should
have a useful life of approximately 20 years.   To the extent that buildings
and  equipment have a useful life longer  than  10 years  and no salvage
value is included in the calculations, the 10-year choice is conservative.
     Annual operation is assumed at 4,000 hours based on:  16 hours/day x
5 days/week x 50 weeks/year = 4,000 hours/year.
     Annual  revenue  and cost of manufacture are assumed constant in the
calculations.  This assumption, made  for simplicity of presentation,
essentially assumes a constant profit margin over the project life.   This
is  consistent with historical performance  in  that manufacturers, with
minor  variations,  have  typically  been able to  maintain their profit
margins.   Sensitivity  analysis was performed  in  order  to  determine the
effect of a possible decline in profit margins sustained over the entire
10 year life of the project that could  result  from  price competition
and/or an increase  in costs.   The sensitivity  analysis evaluated  the
effect of a  10 percent decrease  in profit margins.   If  the profit margins
increase  rather  than decrease,  the plant's  financial position improves
accordingly  and  NSPS controls  become  proportionately less  costly.
      Control  costs  are as shown previously  and  represent Regulatory
Alternative  5.
      Depreciation is calculated using the straight-line method.   Depreciation
 could also be calculated  using  one  of several accelerated methods that
would have the  effect of  increasing paper expenses  but decreasing tax
 payments   and  consequently increasing  cash  flow in  the early years.
 Straight-line is  used  because  it results in  the most  conservative dis-
 counted cash flow projections.
      In the  DCF  analysis  it is assumed  that  the control  cost will be
 completely absorbed by the manufacturer with no cost passthrough in the
 form of higher prices.  This represents a worst-case assumption.
      A 10 percent discount factor is used.   With a typical capital  struc-
 ture  of  30  percent debt financing,  70 percent  equity  financing, and a
 50 percent tax rate, the 10 percent discount  factor  represents a 10 percent
                                 8-132
-------


Equity
Debt
Capital
structure
70% X
30% X
Capital
costs
12%
10%
  cost of debt and a 12 percent cost of equity, which is realistic for this
  industry.
                                       Tax rate

                                          N/A*   =8.4
                                     X    50%    = 1.5
                                                   9.9 = 10% discount factor
       In  order  to  guard  against  the  possibility that a 10  percent  discount
  factor is  too  low,  sensitivity  analysis  was  performed using 15  percent  as
  a  discount factor,  which would represent an  increase in the  cost  of
  equity from 12 percent  to  19.3  percent.
            Capital        Capital
          structure         costs      Tax rate

  Equity      70%     X      19.3%         N/A*   =13.5
 Debt        30%     X      10.0%         50%    =_L5
                                                  15% discount factor
 8.4.6  Data Sources
      The  following  list provides the data sources for  various aspects of
 the analysis:
      1.   average  selling price - Section  8.1
          costs  -  Section 8.2
          debt to  equity  ratio -  annual  reports
          costs  of  debt capital - annual reports
          costs  of  equity capital  - annual reports
          alternative control  options  -  Section  8.2
          sizes  and operating  hours -  Section  8.2
          depreciation schedules  - Section 8.2  and Internal  Revenue Code
          investment  tax  credit -  Internal Revenue Code
          plant  investment - Section 8.2
       Plant Investment
     2.
     3.
     4.
     5.
     6.
     7.
     8.
     9.
    10.
8.4.7
.131
 .131
   .131
     For  each  of the three  model  plant sizes, the capital  investment
costs  represent  the total  investment  required to construct new model
*Not applicable.
                                8-133
-------
asphalt roofing plants with a blowing still and to install a new baseline
pollution control  system,  plus  one  of the  air pollution control alterna-
tives.  These  capital investment costs  include  direct costs,  indirect
costs, working  capital,  contractor's fee,  and contingency.  A detailed
description of the costs was presented in Section 8.2.
8.4.8  Discounted Cash Flow Analysis
     Tables 8-57,  8-58,  and  8-59 show the DCF analysis for each  of  the
three  model  plants.   All dollars are constant end-of-1978  dollars.  All
cash  flows occur at the  end of  each year.  State  income tax is not included
because each  State has  its own particular rate,  which would complicate
the presentation;  Texas, which  is  an  important  producer  State,  has no
State income tax,  and some States permit Federal  income tax deducibility.
Even  if State taxes were included despite  all these  drawbacks, the results
would be  affected  insignificantly.
      1.   Row 1,  revenue  of these tables, is  calculated by multiplying  the
number of squares  that the plant produces  by the  average  selling  price of
one  square.   The  average selling price of  one  square is  taken to  be
$16.51.   Annual  operating time  is considered to  be 16 hours/day  x
250 days/year = 4,000 hours/year.   The revenue is assumed to be constant
for each  year.
      2.   Row 2, cost of  manufacture, represents  annualized costs  (exclud-
 ing  interest, which  is  considered  in the discount  factor)  as  shown in
Table 8-28 in Section 8.2.  Cost of manufacture  includes  baseline control
 costs that would  be  required by SIP's  irrespective  of an NSPS.   Costs
 vary  according to plant size.   Costs per square (the number of shingles
 to cover 100 square feet) for each plant (with blowing still) are:
           a.  small  plant:  $14.27 minus $0.56 interest = $13.71
           b.  medium plant:   $13.42 minus $0.45 interest = $12.97
           c.  large plant:  $13.00 minus $0.41 interest = $12.59
 Annual operating  time is the  same 4,000  hours as  noted  above.   Cost  of
 manufacture is assumed  to be constant for each year.
       3.  Row 3, control costs,  is the incremental cost for most stringent
 control  option.
       4.   Row 4,. earnings before tax,  is  revenue minus  costs (cost of
 manufacture and control costs).
                                  8-134
-------
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                                        8-137
-------
     5.  Row 5,  tax liability,  is  calculated by multiplying earnings
before tax by  the marginal  Federal  corporate  income tax rate, which is
currently 46 percent.
     6.  Row 6,  investment tax credit  (ITC),  considers  the 10 percent
investment tax credit,  which acts to reduce  the tax liability of the
plant  (total direct investment  plus blowing still plus baseline controls
less building) by 10 percent.
     7.  Row 7 is the control  investment tax  credit for NSPS  controls.
     8.  Row 8,  net earnings after tax, represents  earnings before  tax
minus  tax liability plus investment tax credit.  For example:
                    Net earnings before tax      $100
                     Less tax  liability            -46
                     Plus investment tax credit   +10
                                                  $64
     9.   Row  9, depreciation,  is an  non-cash expense  and, as such, is
added  to net earnings after tax for the purpose  of determining cash  flow.
Depreciation is  calculated  using the  straight-line method.
     10.   Row  10,  control  depreciation,  represents depreciation of  the
most stringent  regulatory  control  option and is  calculated  using the
straight-line  method for 20 years, which  is conservative.
     11.   Row  11, net cash  flow,  is  the result  of adding  net  earnings
after  tax  and  depreciation.
     12.   Row  12, discount  factor, shows the present value of a dollar of
future cash flow for each future year.   The discount factor used  is
 10 percent, which represents the weighted average  cost of  capital.
     13.   Row 13 is the discounted cash  flows.   After the  annual  cash inflows
 are discounted, they are summed to  derive the present  value of the cash  in-
 flows  over the life of the project.   The discounted  cash  inflows  are then
 compared to the sum of the discounted  cash outflows.   The difference  is
 the net present value (NPV).
 8.4.9  Fi ndi ngs
      8.4.9.1   Control Affordability
       1.   DCF  - The results  of the discounted cash  flow analysis from
 Tables 8-59,  8-60, and 8-61  show  that all three model plants  have a
 positive NPV.   The small plant has an NPV of $5,211,000; the medium plant
                                 8-138
-------
                                                                          66
 has an NPV of $17,072,000; and the  large plant has an NPV of $25,609 000
 The pomwe NPV means  that after  including the 10 percent required  "
 return, the  investment yields an  additional  amount over  the project  life
 expressed in today's dollars.
      2.   IRR -  A second  financial test shows that the internal rate of
 return for each  of  the model plant sizes  is  21  percent  for the small
 P  ant, 31 percent for  the medium plant, and  37  percent  for the large
 plant.                                                               a
     3.   Paybacks -  Additionally, the  cash  flow projections for  the
 small, med.um, and large  model plants  indicate. a  payback  period  of  4 years
 3 years,  and  2-1/2 years, respectively,  an  attractive payback  period  for
 most manufacturing operations.   A  less-than-5-year payback  also  meets  an
 investment criterion explicitly published by one member of the industry !
     Since the above  tests indicate that each of the three model plants
 remains a profitable  investment after  the addition of the most stHngent
 regulatory control option  in  the absence of cost passthrough,  it can  be
assumed that  this addition will not exert a signifies economic impact
     Several  secondary indicators also sustain this finding-
      '   $ens        analysis for the DCF -  This  was performed  on  the
 nr ..                                                            on
 prom marg1n  for the  small  plant by  reducing  the profit margin by
  4 « "*  r6CalCUlating the  NPV'   ^ NPV  remained  positive by
    258,000.   An additional  sensitivity analysis was performed by changing
 the discount  factor  from 10 to 15 percent  and recalculating the NPV
 Here  again,  the NPV remained positive by $2,572,000 for the small p!ant
 cont   :   VC6nt ™CreaS* *"^""LBTlce - The  most  stringent  regulatory
 control  opt.on will add a maximum of $0.021  to a selling price of $16 51
 per square,  or approximately 0.1 percent.   This  can be  compared  to cost
 push  once increases  of 39.3 percent, or $3.26 per square in 1974  or
 more  recently an average annual increase of 9 percent from 1975-1977
     3"   P°ntrol  cost  passthrouoh  ys.  ahcnT+^n  -  In  tne DCF   n  .g
 assumed that  the control  cost will  have  to be completely absorbed by the
manufacturer with no cost passthrough in the form of higher prices   This
represents a worst-case assumption because the demand is inelastic over a
constable range.  The  industry has an approximate after-tax profit on
sales  of  5.7 percent.    To  the  extent that control costs could be either
                                8-139
-------
partially or completely passed through, the financial performance of the
model plants would improve.
     In addition to these quantitative indicators, some additional  insight
into industrial  viability  can be  gained by examining the actions of com-
panies in the industry.  Large, sophisticated firms perceive the industry
as  attractive  to new  investment,  and several  entrenched firms in the
industry  are extending  their  operations.  Several  examples include:
     1.   Georgia Pacific  opened  its first roofing plant in  Franklin,
Ohio,  in  1978.   Construction was  also begun  on a new roofing plant at
Quakertown,  Pennsylvania,  and  plans were announced  for  a third roofing
plant  to  be  located  near Atlanta,  Georgia.
     2.   GAP Corporation  is building a new roofing plant  in Fontana,
California,  that will  go into operation in 1980;  it will be  the company's
fourteenth  roofing plant.
     3.   CertainTeed Corporation  opened  a new  roofing plant in Oxford,
North  Carolina,  in March of 1978.
     4.   Owens-Corning  Fiberglas  Corporation  purchased Lloyd A. Fry
Company and Trumball  Asphalt Company for approximately $180,000,000 in
 cash in 1977.
      8.4.9.2  Capital Availability for Control Systems.  The necessary
 capital is likely to be available to companies  for the purchase of control
 equipment.
      The total  capital  required to meet NSPS  for a small  model plant
 would add $71,000 to  an initial  investment of $9,506,000,  a 0.7 percent
 increase.   The  figure for medium and  large  plants is 0.7 percent and
 0.5 percent, respectively.  This  increase  in the initial  investment is
 not likely  to  seriously alter the  capital availability situation for a
 company which otherwise can obtain  the necessary capital.
      The majority of  the companies  that are entering the industry for the
 first  time  or  expanding an existing position  in the industry are major,
 publicly held  corporations that provide  improved access to the financial
 markets  as  well as  considerable internal financial  strength and  business
 sophistication.  These publicly  held companies have debt-to-equity ratios
 of approximately 30  percent, which is  indicative of reserve  borrowing
 power.
                                  8-140
-------
       Finally, a  variety  of special pollution control financing arrange-
  ments are available  to new asphalt roofing manufacturing p!ants, such as
  low  interest  bank loans, SBA loans, and  Industrial  Development Bonds
  These sources of  funds generally provide loan rates and repayment terms
  more favorable than general industrial  borrowing.
       8'4-10    Affected Facilities in Other Inr.t^nc    An   integrated
  asphalt  roofing plant includes  an  asphalt blowing operation.   There  are
  approximately 24 plants  where  the asphalt blowing  operation,  although
  Physically adjacent to the  roofing  plant,  was  a  separate corporate  entity
  These units  have  since been purchased by one company and are thus considered
  integrated roofing plants.   Blowing stills are also  installed in petroleum
  refines and,  in very rare occasions,  as production units  without ties
  to either a  refinery  or a roofing plant.  Control costs for new stills in
  refineries will have  no more economic impact than those in roofing plants
  The  control  equipment is  the same,  and any captured pollutants can be
  recycled to the refining process.
      The installation  of  a  new blowing still   in an  asphalt  processing
 plant should  result in the  same increase in annualized costs as for the
 refinery or roofing plant.  The control  equipment would be  the  same as is
 presently used.  The  increase in fuel usage required under NSPS would be
 one cubic meter of oil  for  each 488 megagrams  of asphalt processed  (one
 barrel of oil  for  each 85.5  tons  of  asphalt processed).
 8.5  SOCIO-ECONOMIC IMPACT ASSESSMENT
      The  purpose of Section  8.5  is to address those tests of macroeconomic
 impact as presented in Executive Order 12044 and,  more  generally,  to
 assess any  other significant macroeconomic impacts that may result'  from
 the NSPS.
      The  economic  impact assessment is concerned only with the costs or
 negative  impacts of the NSPS.  The  NSPS will also result in benefits or
 positive  impacts, such as cleaner air and improved health for the popula-
 tion,  potential  increases  in worker  productivity, increased business for
 the pollution control manufacturing  industry, and so forth.   However, the
NSPS benefits  will  not be discussed here.
                                8-141
-------
8.5.1  Executive Order 12044
     Executive Order 12044 provides  several  criteria  for a determination
of major economic impact.  Those criteria are:
     1.  Additional annualized costs of compliance that, including capital
charges  (interest  and  depreciation), will total $100 million (a) within
any  one  of the first 5 years  of  implementation (normally in the fifth
year for NSPS),  or (b)  if applicable,  within any calendar year  up  to the
date by which the law  requires  attainment  of the relevant pollution
standard.
      2.   Total additional  cost of production of any major industry product
or service will  exceed  5 percent of the selling price of the  product.
      3.   Net national  energy consumption will increase by the equivalent
of 25,000 barrels  of oil per day.
      4.   Additional annual  demand will  increase or  annual  supply will
 decrease by more than  3 percent for any of the following materials by the
 attainment date,  if applicable,  or within  5 years  of implementation:
 plate steel,  tubular  steel,  stainless  steel,  scrap  steel, aluminum,
 copper, manganese,  magnesium,  zinc, ethylene,  ethylene glycol, liquified
 petroleum  gases,  ammonia,  urea,  plastics,  synthetic rubber, or pulp.
      The  asphalt  roofing NSPS will not  trigger any  of the above four
 criteria.
      1.   The  NSPS will not add  to  the annual i zed costs for a new medium
 plant.   There are three new medium plants projected  to be built over the
 next  5  years  (annualized costs  for a  small and large plant are $22,000
 and $38,000,  respectively).  This is compared to a  $100 million trigger.
       2.   The  NSPS will add a maximum of 0.1 percent to the  selling  price
 of the  product.   This potential  increase  is far below the 5 percent
 trigger.
       3.   The NSPS will lead  to an  increase in oil  consumption  of
  124 barrels per  day.   This 124-barrels-per-day increase compares  to  a
  25,000-barrels-per-day increase for use as  a trigger.
       4.  The NSPS will  result  in no perceptible change in demand or
  supply.  Executive Order 12044  states that a change of 3 percent or more
  should be used .as a trigger.
                                  8-142
-------
     Additionally,  both  the small dollar cost  of  the NSPS controls  and
the mherent economics of the industry, such as its geographical diversi-
ficatnon,  lack of  an  import or  export  market, et al., preclude  the
possibmty of significant macroeconomic impacts, either on a regional  or
on a national  basis.   The NSPS will not  aggravate national inflation
abrupt  regional  or national employment  patterns,  or change the U S '
balance of payments position.
                              8-143
-------
8.6  REFERENCES FOR CHAPTER 8

 1   Asphalt  Roofing  Manufacturers Association.  Manufacture, Selection
     and Application of  Asphalt Roofing and Siding Products.   10th  ed.
     New York, N.Y.  1970.  p. 5.

 2.  Ref. 1,  p. 3.
 3   Barth,  E.  J.   Asphalt-Science and Technology.   New York, Gordon and
     Breach,  1962.  p. 425-427.

 4.  Ref. 1,  p. 13, 14.
  5   Letter  and  attachment  from  Quaranta, J. ,  Certai nTeed  Products
     Corporation,  to  Noble,   E.  A.,  EPA/ESED.  September 8,  1975.
     Supplemental  information for 114 response.

  6.   Letter and attachments from Hambrick, M.  M. , Celotex, to I Goodwin, .  D.
      R   EPA/ESED.  May  30,  1975.   Information on plants at Goldsboro,
      N.C.  Los Angeles, Calif, and Cincinnati,  Ohio.

  7.   Ref.  1, p.  41 a.

  8.   Ref.  1, p.  15.
  9.   Asphalt Roofing Manufacturers Association   List of Plants:  Asphalt
      and Tarred Roofing  Manufacturers.  New York,  N.Y.  May  M,  IS/B.  * p.
11
 10.  U.S. Census of Manufactures.  Volume  II   US            ^
      Washington,  D.C.   Census  for 1954,  1958,  1963, 1967, and
               and Tar  Roofing and Siding Products.  U.S.  Department of

       1973,  and 1975.
  "•
       1976 and 1977.
  14.  Evans, J. V.   Asphalt.   ^  . Ki>k-0thmer Encyclopedia  of  Chemical
       Technology, Volume  3,  3rd editnon, Mark, H. F. , et al . (ed.).  New
       York, John Wiley & Sons, 1978.

  15   Cantrell,  A.   Annual  Refining  Survey.   The Oil and  Gas Journal.
       76(12): 108-146.  March 20, 1978.
                                   8-144
-------
 16.




 17.

 18.




 19.




 20.



 21.



 22.




 23.


 24.


 25.



 26.


 27.

 28.




29.


30.


31.
 Annual Survey of Manufactures:  Industry Profiles.   U.S.  Department
 of Commerce.  Washington, D.C.  M(AS). Surveys  for  1969,  1970,  1971,
 and 1976.

 Ref.l, p. 1.                                 •'....


 U.S.  General Imports:  Schedule A Commodity Groupings by World Area
   5'cTe?cn^ent °f  Commerce-   Washington,  D.C.  FT  ISO/Annual 1973*
 and FT ISO/Annual  1977.  October 1974 and July  1978.

 U.S.  Exports:  Schedule  B  Commodity Groupings  by World Area   U S
 Department of Commerce.  Washington, D.C.   FT 450/Annual 1973 and FT
 450/Annual 1977.   June 1974 and June 1978.

 Handbook of Labor  Statistics  1977.    U.S.  Department  of  Labor
 Washington,  D.C.   Bulletin 1966.   1977.

 Monthly Labor Review.  U.S.  Department of  Labor.   Washington, D.C.
 Volume 102,  Number 2.  February 1979.

 Statistical  Abstract of the  United States,   U.S. Bureau  of Census

                                 1970' 19?1> 1972> 1973> 1974> 1975,
 MOT/MP     North Carolina Asphalt Roofing Distributor with Ante!,  D.,
 MRI/NC.   March  7,  1979.   Prices  of asphalt roofing shingles.

 Cantrell,  A.    Annual  Refining Survey.  The Oil  and Gas Journal
 p. 97-123.  March  28,  1977.


 Telecon.   Merz, S.,  Celotex Corporation,  with  Cooper,  R.  MRI/NC
 March 8,  1979.   Prices of dry materials for asphalt roofing plants.

 Telecon.   Lambert, D., Exxon Corporation,  with  Ante!,  D., MRI/NC
 March 8,  1979.   Prices of asphalt.

 Economic  Indicators.   Chemical Engineering.  86(6):7.  March  12,  1979.

 Franzblau and Fitzsimmons, Inc.   Revised Proposal  for Asphalt Roofing
 Plant.   Submitted  to  the Flintkote Company.   Proposal   No   245
 Kearny, N.J.  October  19, 1973.

 Economic  Indicators.   Chemical  Engineering.   86(4):7.    February
 Ib-jl.?/.?.                                   >


Telecon.    Lambert,  D. ,   Exxon  Company, with Ante!, D. , MRI/NC
March 8, 1979.  Prices of asphalt.

Telecon.   Clarke,  S., CertainTeed Corporation,  with Ante!,  D
MRI/NC.   March 30,  1979.   Felt costs.   '" -
                           8-145
-------
32.  Telecon.  Merz,  S.,  Celotex Corporation, with  Cooper,  R. ,  MRI/NC.
     March  8,  1979.  Dry  materials  price for asphalt  roofing plants.

33.  Employment and Earnings,  February 1979.  U.S.  Department of  Labor.
     Washington, D.C.  Vol.. 26, No. 2.  February 1979.

34   Telecon.  Representative  of Kansas City, Missouri, Water Department
     with  Kelso,  G., MRI/KC.   April  19,  1979.  Cost of water  in Kansas
     City,  Mo.

35.  Retail  Prices  and  Indexes of Fuels and  Utilities,  Residential  Usage.
     U.S.  Department of Labor.  Washington,  D.C.    June 1978.

36.  Monthly Labor Review.  U.S.  Department of  Labor.   Washington, D.C.
     Vol.  102, No.  3.   March  1979.

37.  Survey of  Current  Business.   U.S.  Department  of  Commerce.
     Washington,  D.C.   Vol.  59,  No.  3.   March 1979.

38  Asphalt Roofing Manufacturers'  Association.   Manufacture,  Selection,
     and Application of Asphalt  Roofing  and Siding Products.   12th ed.
     New York,  N.Y.  1974.

39.  Calculations for Chapter 8,  Section 8.2.2.2.

40  Air Pollution Control Technology and Costs:   Seven Selected Emission
     Sources.   U.S. Environmental Protection Agency.   Research Triangle
     Park, N.C.   PB-245 065.   December 1974.

41  Capital and Operating Costs of Selected Air Pollution Control Systems.
      U S. Environmental Protection Agency.   Research Triangle Park, N.C.
      EPA-450/376014.  May 1976.

 42.   Perry, R. H., and C.  H.  Chilton.  Chemical Engineers'  Handbook.  5th
      ed.  New York, McGraw-Hill  Book Company, 1973.

 43.   Economic Indicators.  Chemical Engineering.  86:(7):7.  March 26, 1979.

 44   Capital and Operating Costs of Pollution Control  Equipment Modules -
      Vol   II - Data Manual.   U.S.  Environmental  Protection  Agency.
      Washington, D.C.  EPA-R573023b.   July  1973.

 45   Development  of Cost Chapter for  Control Techniques  Document (CID)
      for Asphalt  Roofing Industries.   U.S.  Environmental  Protection
      Agency.   Research  Triangle Park,  N.C.   Contract No.  68022842.
      November 1977.  15  p.

 46.  Economic Indicators.  Chemical  Engineering.   85:(15):7.  July 17,  1978.
                                  8-146
-------
 47.
 48.
 50-
Nonmetallic Minerals Industries

68021473.  February 1977.

Economic   Indicators.     Chemical
February 13, 1978.
»,-••-•  • .- -~--'j|
Control Equipment Costs.    U.S.
Research Triangle Park, N.C.   EPA-


   Engineering.    85:(4):7.
                                                           l Handbook-  4th
 51.   Development Document  for Proposed Effluent  Limitations  Guidelines
      and New  Source Performance  Standards  for the Paving  and  Roofing
      F?Aeria/?7i"Sra 3rd AsP|?f1t^  U-s- Environmental Protection Agency.
      EPA 440/174/049, Group II.  December 1974.

 52.   Memo  from  Shea,  E.  P.,  MRI/NC,  to  Noble,  E.   A.,  EPA/ISB.
      March  29, 1979.  Report  on trip  to CertainTeed plant, Oxford, N.C.

 53.   Memo  from" Shea,  E.  P.,  MRI/NC,  to  Noble,  E.   A.   EPA/ISB
      April  3,  1979.   Report on trip to Flintkote plant, Peachtree, Ga.

 54'   9f°iQf-7rQ°m  I*1-63'  E-  P"  MRI/NC>  to Noble, E.  A.,  EPA/ISB.  April
      ^,  iy/y.   Minutes of meeting with representatives of OwensCorning.

 55.   Memo from Shea, E   P.,  MRI/NC,  to 4654L Project File.   May 15, 1979.
      OSHA inspection of Flintkote  plant, Peachtree,  Ga.

 56.   Texas  Clean Air Act.  -Regulation 6, Control of  Air Pollution by
      Marm6tS197°r  NeW  Construct1on  or Modification.  Section  131.08.

 57.
     7 OTIC -m'   „---••::	•'- Code-   Tlt1e 7» Chapter 27, Subchapter 6,
     7 2716.10.   Permit to Construct  and Certificate to  Operate    New
     Jersey State Department of  Environmental  Protection.   March 1,  1976.

58.  Regulation 2   Division ;T3, Permits.   Bay Area Air  Pollution  Control
     District.  February 1975.   p. 5859.

59.  1978 Annual  Reports  for Bird & Son,  Inc.; CertainTeed Corporation;
     Mintkote,  Inc.;   GAF  Corporation;  Georgia-Pacific  Corporation-
     Johns-Manville,  Inc.;   Koppers  Company;  Masonite  Corporation-
     Corporati'on"9  F1berglas  CorP°ration;  u-s- Gypsum;  and Jim Walter


60.  Initial Decision  in  the  Matter of Jim Walter, a Corporation.   In:
     United States of America before the Federal Trade Commission, Docket
                May 6% 1976.
                                8-147
-------
61.  1977 Statistical  Abstract of the  United States.   U.S. Bureau of
     Census.  Washington, D.C.  September 1977.

62.  1978 Annual Report:  GAP Corporation.

63   Goldfarb, J.  Prospects for the Residential Roofing Market.  Merrill
     Lynch Pierce Fenner and Smith, Inc.  [Presented at 1979 Papermaker s
     Conference of the Technical Association  of the Pulp and Paper Industry
     (TAPPI)].  Boston.  April  10, 1979.

64  Fiber  Glass Shingles  Grab Bigger Share of the  Roofing  Market
     Professional  Builder Apartment Business.   Vol.  II.   August 1979.

65  Telecon.  Taylor, M.  R., JACA with Cotts,  R. CertainTeed.   May 3, 1979.
     Concerning  the  Company's plans for the  use of  fiber glass.

66.  1978 Annual  Report:   Koppers Company,  Inc.
                                  8-148
-------
             APPENDIX  A.   EVOLUTION OF THE PROPOSED STANDARD

      In  June 1974,  the United  States  Environmental  Protection  Agency
 initiated  a  screening study  of the asphalt roofing manufacturing  (ARM)
 industry.  Based  upon the  results  of  the  screening  study  conducted  in
 July  1974, a study  to develop  the  Background  Information  Document was
 initiated  for the ARM category.
      In  July 1974 a literature survey was  begun, and  state  and regional  air
 pollution  control agencies and the industry were canvassed  by  telephone  and
 mail  to  obtain information on  plant operations and  to determine which
 plants,  if any, appeared to  be well controlled.  Plant visits  were  then
 scheduled  to those  plants which appeared,  from the  survey information, to
 be the best  controlled.  The purpose  of the plant visits was to obtain
 information  on process details, quantitites of emissions, and  emission
 control  equipment. The feasibility  of conducting future emission testing
 was also determined during the plant  visits.
     Significant events relating to the evolution of the Background
 Information Document  for ARM are itemized  in the chronology below.
A.I  CHRONOLOGY
     The important events which have occurred in the development of the
 Background Information Document for Asphalt Roofing Manufacturing are
depicted below in chronological order.
                                   A-l
-------
      Date

May 31, 1974


July 16, 1974

July 17, 1974
August  14, 1974


August  14, 1974


 October 24,  1974


 October 25,  1974


 November 5,  1974


 November 5,  1974


 November 6, 1974


 November 8, 1974


 November 11,  1974


  November 11,  1974


  November 12,  1974


  November 25,  1974


  November 26, 19-74
               Activity

Project start date.   Contract  awarded
to MRI.
Literature and telephone surveys initiated.

Letters requesting information mailed  to Texas
Air Control Board; LAAPCD; Bird and Son, Inc.;
Maryland Division of Air Quality; CertainTeed;
Johns-Manville; Commercial Testing and Engineer-
ing; and Valentine, Fisher, and Tomlinson.

Plant  visit to GAP asphalt roofing plant,
Kansas  City, Missouri.

Plant  visit to CertainTeed asphalt roofing
plant,  Kansas  City, Missouri.

Plant  visit  to Celotex  asphalt  roofing  plant,
Goldsboro, North  Carolina.

 Plant  visit  to Johns-Manville asphalt roofing
 plant, Savannah,  Georgia.

 Plant visit  to Lloyd  A. Fry  asphalt roofing
 plant, Portland,  Oregon.

 Plant visit  to Bird and Son  asphalt roofing
 plant, Portland,  Oregon.

 Plant visit to Malarkey asphalt roofing
 plant, Portland, Oregon.

 Plant visit to Bird and  Son asphalt  roofing
 plant, Portland, Oregon.

 Plant visit to Flintkote asphalt roofing
 plant, Los Angeles,  California.

 Plant visit to Celotex asphalt roofing  plant,
  Los Angeles,  California.

  Plant visit to Johns-Manville  asphalt  roofing
  plant, Los Angeles,  California.

  Plant visit to Johns-Manville  asphalt  roofing
  plant, Uaukegan, Illinois.

  Plant visit to  CertainTeed  asphalt roofing
  plant, Chicago  Heights, Illinois.
                                      A-2
-------
       Date

 November 27, 1974
 December 17, 1974
 March 10-13, 1975
 April  9, 1975
 April  22,  1975
 May 1,  1975



 May 6,  1975


 May 13,  1975


 May 14,  1975


 May 15,  1975


 May 15,  1975


 May 28,  1975


 June 3,  1975


June 4 & 5, 1975


June 12 & 13,  1975


June 17, 1975
               Activity

 Plant visit to Lloyd A. Fry asphalt roofing
 plant; Summit, Illinois.

 Plant visit to Celotex asphalt roofing
 plant, Cincinnati, Ohio.

 Emission test at Celotex asphalt roofing
 plant, Goldsboro, North Carolina.

 Preliminary model plants submitted to
 Economics Analysis Branch (EAB).

 Section 114 letters mailed to  CertainTeed-
 Lloyd A.Fry;  GAF; Bird and Son;  Celotex;
 Flintkote;  Johns-Manville;  Trumbull;  and
 Douglas Oil.

 Pretest survey of Johns-Manville asphalt  roofing
 plant,  Waukegan,  Illinois.

 Pretest survey of CertainTeed  asphalt  roofing
 plant,  Chicago Heights,  Illinois.

 Plant visit .to Bird and  Son asphalt roofing
 plant,  Portland,  Oregon.

 Plant visit to Bird and  Son asphalt roofing
 plant, Wilmington,  California.

 Pretest survey of Celotex asphalt roofing
 plant, Los  Angeles,  California.

 Pretest survey of Johns-Manville asphalt
 roofing plant,  Los  Angeles, California.

 Plant visit to CertainTeed asphalt roofing
 plant, Shakopee,  Minnesota.

 Pretest survey to  Elk Roofing asphalt roofing
 plant, Stephens, Arkansas.

 Pretest survey to Celotex asphalt roofing
 plant, Fairfield, Alabama.

 Emission test at Celotex asphalt roofing
plant, Cincinnati, Ohio.

 Pretest survey of CertainTeed asphalt
 roofing plant, Shakopee,  Minnesota.
                                    A-3
-------
      Date

July 22 & 23, 1975



August 8, 1975


August 18-27, 1975


September 9-13,  1975


September 16-19, 1975


October 6-10,  1975


October 20-24,  1975


 February 1, 1977


 March 1, 1977,  and

 March 17,  1977


 March 31,  1977


 April  1, 1977


 April  1,  1977


 April  5, 1977


  April  5, 1977


  April  6, 1977
                Activity

Visible emission test conducted at
CertainTeed asphalt roofing plant,
Chicago Heights, Illinois.

Plant visit to Celotex asphalt roofing
plant, Fairfield, Alabama.

Emission tests on asphalt blowing operation
at  Elk Roofing,  Stephens, Arkansas.

Emission test at CertainTeed asphalt roofing
plant, Shakopee, Minnesota.

Emission test at Johns-Manville  asphalt
roofing plant, Waukegan,  Illinois.

Emission test at Celotex  asphalt roofing
plant,  Fairfield,  Alabama.

 Emission  test  at Celotex  asphalt roofing
 plant,  Los Angeles, California.

 Effort begun to locate additional well-
 controlled blowing stills for testing.

 Section 114 letters requesting additional
 information on asphalt blowing mailed to GAF;
 Chevron, USA; Exxon; Jim Walters; Global  Oil;
 Douglas Oil; and Trumbull Oil.

 Plant visit to  Lundy-Thagard Oil asphalt
 blowing operation, Southgate, California.

 Plant visit to  Douglas Oil asphalt blowing
 operation, Paramount,  California.

 Plant visit to  Hirt  Combustion  Engineers,
 Montebello, California.

  Plant  visit to  Trumbull  Asphalt asphalt
  blowing  operation, Martinez,  California.

  Plant visit to Global  Oil  asphalt blowing
  operation, Pittsburgh, California.

  Plant visit to Chevron,  USA,  Asphalt
  Division, asphalt blowing operation,
  Portland, Oregon.
                                      A-4
-------
        Date

 April,  1977



 April,  1978



 December 13, 1978


 January 18,  1979


 January 18,  1979


 March 19,  1979


 March 23,  1979


 March 27,  1979


 April  4, 1979



 May 1,  1979


 November 15,  1979

 December 12,  1979


January 10, 1980
                  Activity

  Report.  Impact  of  NSPS  on  1985  National  Emissions
  from  Stationary Sources; The  Research Council of
  New England.

  Report.  Priorities for  NSPS  under the
  Clean Air Act Amendments of 1977-
  Argonne National Laboratory.     '

  Plant visit to  Celotex asphalt roofing
 plant, Goldsboro, North Carolina.

 Plant visit to GAP asphalt roofing
 plant, Kansas City, Missouri.

 Plant visit to CertainTeed asphalt roofing
 plant, Kansas City, Missouri.

 Plant  visit to CertainTeed asphalt roofina
 plant, Oxford,  North Carolina.

 Section 114 letters sent to CertainTeed
 and Flintkote.

 Plant  visit to  Flintkote  asphalt roofing
 plant,  Peachtree City, Georgia.

 Meeting with  Owens-Corning  Fiberglas Corporation
 to  discuss  status of plants recently acquired from
 Lloyd  A. Fry, Inc.

 Section 114 letter  to Owens-Corning Fiberqlas
 Corporation.

 EPA Working Group.

 National Air Pollution Control
 Technical Advisory Committee (NAPCTAC).

 Meeting with Asphalt Roofing Manufacturers
Association (ARMA) and industry representatives.
February 21, 1980       EPA Steering Committee meeting (consent agenda).
                                   A-5
-------
-------
                                 APPENDIX  B
                INIJEX TO ENVIRONMENTAL  IMPACT  CONSIDERATIONS

     This appendix consists of a  reference system, cross-indexed with
the October 21, 1974 FEDERAL REGISTER  (39 FR  37419) containing the Agency
guidelines concerning the preparation of Environmental Impact Statements.
This index can be used to identify sections of the document which contain
data and information germane to any portion of the FEDERAL REGISTER
guidelines.
                                   B-l
-------
                                Appendix B


                CROSS-INDEXED REFERENCE SYSTEM TO HIGHLIGHT
               ENVIRONMENTAL IMPACT PORTIONS OF THE DOCUMENT
Agency Guidelines for Preparing
Regulatory Action Environmental
Impact Statements (39 FR 37419)
	_____^	:	—	

 1.  Background  and Description
     of  Regulatory Alternatives

     Summary of  Regulatory
     Alternatives

     Statutory Basis  for the
     Regulatory  Alternatives

     Relationship to  Other
     Regulatory  Agency Actions
      Industry Affected by the
      Regulatory Alternatives
      Specific  Processes  Affected
      by  the  Regulatory
      Alternatives
     Location Within the Background
          Information Document
The regulatory alternatives are
summarized in Chapter 1, Section 1.1.

The statutory basis for the regulatory
alternatives is summarized in Chapter 2.

The relationships between the
regulatory alternatives and other
regulatory agency actions are
summarized in  Chapter 8, Section 8.3.

A discussion of the  industry
affected by  the alternatives  is
presented in Chapter 3,  Section 3.1.
Further details covering the
business and economic.nature  of,the
 industry are presented in Chapter 8,
 Section 8.1.

 The specific processes and facilities
 affected by the regulatory alternatives
 are summarized in Chapter 1,
 Section 1.1.  A detailed technical
 discussion of the processes
 affected by the regulatory alternatives
 is presented  in Chapter 3,
 Section  3.2.
                                     B-2
-------
                                 Appendix  B


                CROSS-INDEXED REFERENCE SYSTEM TO HIGHLIGHT
               ENVIRONMENTAL IMPACT  PORTIONS  OF THE DOCUMENT
                                 (continued)
Agency Guidelines for Preparing
Regulatory Action Environmental
Impact Statements (39 FR 37419)
                                    Location Within the Background
                                         Information Document
2.
Control Techniques and Regulatory
Alternatives
 3.
     Control  Techniques
     Regulatory  Alternatives
 Environmental  Impact  of the
 Regulatory  Alternatives

 Primary  Impacts  Directly
 Attributable to  the
 Alternatives
    Secondary or Induced
    Impacts
                               The alternative control techniques
                               are discussed in Chapter 4,
                               Sections 4.2 and 4.3.

                               The various regulatory alternatives
                               including "no additional  regulatory
                               action" are defined in Chapter 6,
                               Section 6.2.   A summary of the
                               major alternatives  considered is
                               included in Chapter 1, Section 1.3.
 The  primary  impacts  on mass
 emissions and ambient air  quality
 due  to  the alternative control
 systems are  discussed in Chapter 7,
 sections 7.1, 7.2, 7.3, 7.4, and
 7.5.  A matrix summarizing the
 environmental and economic impacts
 of the regulatory alternatives
 is included  in Chapter 1.

 Secondary impacts for the various
 regulatory alternatives are
discussed in Chapter 7,  Sections 7.1,
 7.2, 7.3, 7.4, and 7.5.
                                  B-3
-------
                                Appendix  B


                CROSS-INDEXED REFERENCE SYSTEM TO HIGHLIGHT
               ENVIRONMENTAL IMPACT PORTIONS OF THE DOCUMENT
                                (concluded)
Agency Guidelines for Preparing
Regulatory Action Environmental
Impact Statements (39 FR 37419)

 4.  Other Considerations
     Location Within the Background
          Information Document


A summary of the potential  adverse
environmental impacts associated
with the regulatory alternatives is
included in Chapter 1, Section 1.2
and Chapter 7.  Potential socio-
economic and  inflationary impacts
are discussed in Chapter 8,
Section 8.5.  Irreversible and
irretrievable commitments of
resources are discussed  in
Chapter 7, Section  7.6.
                                     B-4
-------
                     APPENDIX  C.   SUMMARY  OF  TEST  DATA

 C.I  INTRODUCTION
      The  asphalt roofing manufacturing  industry was  surveyed by EPA
 personnel to  identify those plants and facilities  at  which to conduct
 tests to evaluate techniques for controlling particulate emissions related
 to processes in the asphalt roofing industry.  Several  plants were selected
 and tested  for organic particulate emissions.  Since many  of the mineral
 handling and  storage  operations  for  limestone,  traprock,  and mica at
 asphalt roofing  plants  are similar  to the  screening,  conveying,  and
 storage of mineral  products  at non-metallic mineral  processing plants   it
 was decided to transfer selected control technology for inorganic parti-
 culate  from this industry to the asphalt roofing manufacturing industry
 This  appendix contains emission test  data obtained  from asphalt  roofing
 Plants  and  selected  emission test  data obtained from non-metallic mineral
 processing plants.

 C.2 EMISSION TEST PROGRAM FOR  MANUFACTURE  OF ASPHALT ROOFING
     A  source testing  program was  undertaken  by EPA  personnel to evaluate
 techniques  for  controlling particulate emissions  related to processes  in
 the  asphalt  roofing manufacturing industry.   Plant process facilities
 tested  included asphalt  storage tanks, blowing stills,  saturators, and
 coaters.  These  tests  included sampling and analyses of particulate
 polycyclic organic matter (POM), hydrocarbons (HC),  SO,,,  NOX, aldehydes,
 and CO.  In  this  appendix,  the facilities  tested  and  the test methods'
 used are identified.   The results  of emission tests  and  visible emission
observations, as well  as the characteristics  of exhaust  gas  streams, are
summarized in Tables C-l to C-23 and Figures  C-l to C-9.  The individual
sections of the processing equipment which  are controlled and the  type  of
                                C-l
-------
control device,  or devices, for each  plant  tested are also discussed
later in this appendix.
     Particulate sampling was  conducted  using the  EPA Test Method 26 for
asphalt roofing  plants.  Outlet gaseous hydrocarbon measurements were
made using a flame-ionization  detector (FID) by monitoring the gas sampled
in  the  EPA Method 26  train  at a point between  the filter and  the first
impinger.   Continuous  measurements of NOX and  S02 concentration levels
were made using a Dynascience* electrochemical S02  analyzer.  Total POM
was measured utilizing the EPA Method 26 train  in conjunction  with  a POM
collection column developed by Battelle Columbus  Laboratory (BCL).  EPA
Reference Method 3 was  used for Orsat analysis.   Analysis of  C0£ and 02
was by Orsat; CO  concentration was  determined  by  Nondispersive  Infrared
 (NDIR)  measurements.   Determinations of aldehyde concentration were made
 utilizing the Los Angeles  Wet Chemistry Method.
     Visible emission observations  were made at the exhaust of each of
 the control  devices   in accordance  with procedures  recommended in EPA
 Reference Method  9 for visual determination of the opacity of emissions
 from stationary sources.
      Fugitive emissions were  read at the points specified in the tables
 and figures.  An  attempt  was made to quantify the fugitive emissions by
 recording the duration and intensity of the emissions from the sources.
 C.2.1    Description  of Asphalt Roofing Manufacturing Facilities Tested
      C.2.1.1   Facility A.    Facility  A was  operating  the  shingle
 manufacturing  line at  a  production  rate  of  27.85 Mg/h (30.7 tons/h)
 during  the emission  tests.  Emission  sources  sampled on  the shingle
 manufacturing line included:   dip-type  saturator, drying-in drum section,
 wet looper, and coater.  All of these sources  were ducted  via a manifold
 to two modular  electrostatic  precipitators  (ESP).
       Visible emissions were  observed at the exhaust of each of the two
  ESP stacks.  Fugitive  emissions  were observed at the  saturator section,
  at the drying-in drum section, and at the  coating section  of  the production
  Mention of a specific company or product does not constitute endorsement
  by the United States Environmental Protection Agency.
                                  C-2
-------
  line.   Participates,  HC,  and POM were measured at the inlet and outlet of
  the ESP's.
      The  results of the  emission  tests  at Facility A are  contained in
  Figure  C-l  and  in  Tables  C-l  to  C-3a.
      C.2.1.2  Facility B.  The production  rate of the shingle manufacturing
  line at Facility B was 37.0  Mg/h  (40.8  tons/h) during the  emission  test
  program.   Emission sources sampled on the shingle manufacturing  line  at
  Facility B  included the dip-type saturator, drying-in section, and coater
  All  of  the sources were  controlled  by two afterburner units.  One  of
  these units  (Unit  2)  also controlled  emissions from  a surge tank  and six
  asphalt storage tanks.
      Visible emissions  were   recorded  for  each of the two  afterburner
 outlet  stacks,  and fugitive  emissions escaping the  capture hoods were
 recorded for the saturator area of the asphalt production line.   Emissions
 were measured for particulates,  HC, gas composition,  NO,,  SO,,  aldehydes
 and POM.                                               x     2
      Results of the emission tests at Facility B are given  in Figure C-2
 and in Tables C-4 to C-9.
      C.2.1.3  Facility C.   The  shingle production rate at  Facility C
 during the  emission tests  was  26.31 Mg/h  (29.0  tons/h).  Emission  sources
 tested were the  spray-dip  saturator,  drying-in section, wet looper,  and
 the  coater.   All of these  sources were controlled  by  a high  velocity air
 filtration  (HVAF) unit.   The  same  HVAF unit  also  controlled emissions
 from  the main asphalt  storage tank and  seven  process storage tanks.
     Visible emissions were observed and recorded  at the  filter outlet
 stack discharge.   Fugitive emissions  were observed around the saturator
 capture  hoods and around the  HVAF inlet ductwork.   Half of the saturator
 readings were made  at  the   spray-dip portion and the  other  half at the
 strike-in/coater section.
     Other tests made at the inlet and outlet of the filter unit included
particulate, gaseous hydrocarbon,  POM,  and SO
     The results  of the emission tests at  Facility  C are  given  in
Figures  C-3 to C-7 and  in Tables C-10 to C-14.
                                C-3
-------
     C.2.1.4  Facility D.  The  shingle manufacturing line at Facility D
was operating at a production rate of 43.27 Mg/h (47.7 tons/h) during the
emission tests.   The emission sources sampled were the dip-type saturator,
the drying-in section,  and the  wet looper.   Emissions  from  these  sources
were controlled by an HVAF.
     The visible  emissions were recorded at the asphalt truck unloading
area and  at the HVAF outlet stack.  Fugitive emissions were recorded at
each end of the saturator  capture  hoods.  Emission tests were also conducted
to determine particulate and gaseous hydrocarbon levels.
     The  results  of the emission  tests  at  Facility D are  contained in
Figure  C-8 and  in Tables C-15 and  C-16.
     C.2.1.5   Facility E.   The emission sources sampled at Facility E
were two  asphalt  blowing (or  oxidation)  stills  with  a  blowing  capacity  of
36.34  m3  (9,600 gal) each.  The blowing durations  were 1-1/2 hours for
saturant  blows  and  4-1/2 hours  for coating  blows.   Each still  was equipped
with  a knock-out chamber, and  one afterburner was used for controlling
 emissions from the  stills.
      Visible emission observations were recorded at the afterburner stack
 by two observers.   Emissions  were also measured for  particulates,  HC,
 NOX,  S02, aldehydes, and POM.
      The  results  of the  emission testing  program  at Facility  E are
 contained  in Figures C-9 and in Tables C-17 to C-22a.
      C.2.1.6  Facility F.   Emission tests were conducted at Facility F to
 determine  the  opacity  of  stack emissions  from the  mist  eliminator  that
 controlled emissions  from the  asphalt storage  systems.   Two main storage
 tanks, one flux  tank,  and four work  tanks were ducted to  the same  mist
 eliminator.
      Visible emission  tests  were  made of the exhaust  stack effluent from
 the mist  eliminator.   The results are contained in Table C-23.
 C.3   EMISSION  TEST PROGRAM FOR SELECTED  NON-METALLIC MINERAL PROCESSES
       A source  testing program  was  undertaken  by  EPA to evaluate
 techniques available  for controlling particulate  emissions  from non-
 metallic mineral plant process facilities, including  screens  and material
  handling operations,  especially  conveyor transfer points.   This appendix
  describes the  facilities  tested (their operating conditions and
                                  C-4
-------
  characteristics of exhaust gas streams) and summarizes the results of the
  particulate emission tests and visible emission observations.
       Five baghouse  collectors  controlling process  facilities at five
  crushed stone installations (two  limestone,  one mica,  and two traprock)
  were  tested using EPA Reference Method 5,  except as  noted in  the facility
  descriptions,  for determination  of particulate matter  from  stationary
  sources.  The  results are  summarized  in Tables  C-24  to  C-32.
       Fugitive  and visible emission observations were made  in  accordance
  with  procedures  recommended in EPA Reference Method 9  for  visual  deter-
  mination  of the opacity of emissions  from stationary  sources.   Visible
  emission observations were made at the exhaust  of each  control device and
  fugitive emission observations at hoods and collection points for process
  facilities.   The  data are  presented in terms  of percent of  time  equal to
 or greater than a given opacity.
 C'3'1    Description  of Selected Non-Metallic Mineral Process Facilities
        Tested
      C.3.1.1  Facility G.  The production  unit  sampled  at Facility G was
 the conveyor  transfer point at  the  tail  of an  overland conveyor for
 crushed limestone.   The  conveyor had a 227-kg/s  (900-tons/h)  capacity
 using  a 76.2-cm (30-inch)  belt  at a speed of 3.6 m/s  (700 ft/s).   The
 transfer point was enclosed,  and emissions  were  vented  to a small baghouse
 unit  for collection.   Three particulate sampling tests were conducted.
 Visible emission observations were made at  the baghouse  outlet  and at  the
 transfer point.  The  results are  given  in Table  C-24.
     C.3.1.2  Facility H.  At Facility H  the production units sampled
 were two three-deck vibrating screens.  These screens, used  for the final
 sizing  of  limestone,  were operated at  a rate of 31.5 kg/s (125 tons/h).
 Particulate  emissions  collected from the top of  both  screens, at  the feed
 to  both screens,  and at  both the  head and tail   of a shuttle  conveyor
 between  the  screens were vented to  a  mechanical shaker-type baghouse.
 The results are given  in Table C-25.
     C.3.1.3  Facility J.  The finishing screen  for traprock at Facility J
was totally  enclosed  and  was operated  at a  rate  of 63 kg/s  (250 tons/h).
 Emissions collected from the top of the screen enclosure, from all screen
                                C-5
-------
discharge points, and  from several  conveyor transfer points were vented
to a fabric filter.   The results are given in Table C-26.
     C.3.1.4  Facility K.  Five screens used for final sizing of traprock,
and eight storage bins were tested at Facility K.  This facility processed
traprock at  a rate  of  94.5 kg/s  (375  tons/h).   All  screens  and  bins were
totally enclosed, and  emissions  were  vented to  a jet pulse-type baghouse
for collection.  The results are given in Table  C-27.
     C.3.1.5   Facility L.   The bagging operation used to package ground
mica was sampled at Facility L.  Particulate emissions were controlled by
a  baghouse.   Fugitive  emission  observations were made  at  the  capture
point.  The  results are  given  in Table C-28.
                                  C-6
-------
TP ]
                                       Electrostatic
                                       Precipitator

                                        Module 2
                                      Electrostatic
                                      Precipitator

                                        Module 1
IV
   TP2
       Figure  C-l.   Schematic  of ducting arrangement
               and test points  (TP)—Plant A.
                              C-7
-------
  TABLE C-l.  VISIBLE EMISSIONS COMPOSITE SUMMARIES-PLANT A

                        OCTOBER 7,  1975
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                                C-8
-------
      TABLE C-l.
VISIBLE EMISSIONS COMPOSITE SUMMARIES-PLANT A
          OCTOBER 8, 1975
            (continued)
                                 TIME—HOURS

                      SATURATOR HOOD, OBSERVERS 1 AND 2
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                                C-9
-------
    TABLE C-l   VISIBLE EMISSIONS COMPOSITE SUMMARIES-PLANT A
                          OCTOBER 9, 1975
                             (continued)
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                                  C-10
-------
      TABLE  C-l.   VISIBLE EMISSIONS COMPOSITE SUMMARIES—PLANT A

                             OCTOBER 9, 1975

                               (concluded)
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-------
       TABLE  C-3.   PARTICULATE  POLYCYCLIC ORGANIC MATTER CONCENTRATION
                         AND EMISSION DATA  SUMMARY—PLANT A
                                     (OCTOBER  9, 1975)    '
                                          (METRIC)
Sampling location
Volume of gas sampled—Urn3
Percent moisture by volume
Average stack temperature— -°C
Stack volumetric flow rate--
Inlet
(TP-1)
2.25
2.1
58.3
12.47
(Sampled stack)
Outlet (TP-3)
2.81
2.2
58.9
5.67
Outlet (TP-2)3
estimated value
—
2.2
58.9
6.07
Combined total
flow conditions
for outlet stacks
. —
2.2
58.9
11.74
  NmVsc                  -

Stack volumetric flow rate—  14.45


Percent isokinetic          106.7
                                          6.57
                                         99.7
                                                          7.05
                                                                              13.62
Particulate— POM
Sampling location
Comoonent
Anthracene/Phenanthrene
Methyl anthracenes
Fluroanthene
Pyrene
Methyl pyrene/Fl uoranthene
Benzo(c)phenanthrene

Chrysene/Benz(a)anthracene
Methyl chrysenes
Benzo fluoranthenes
Benz(a)pyrene )
Benz(e)pyrene )
Totals
Collection efficiency, percent
PP.
Inlet

51.2
181.8
0.950
7.40
4.00
0.350

8.30
21.8
5.30
13.5

294.6
~
Concentration
kq/msx!0-9
Outlet

44.8
102.2
6.25
2.90
20.9
Not
detected
0.700
0.350
0.350
0.900

179.4

Inlet

22.70
80.55
0.41
3.27
1.78
0.156

3.68
9.66
2.36
6.00

(13.07)
—
Outlet

15.90
36.16
2.22
1.03
7.41
NDe

0.25
0.12
0.12
0.32

(6.36)

Emission rate kq/sxlO-7
Outlet
Inlet (TP-2+TP-3)3

2.83
10.04
0.05
0.40
0.23
0.02

0.45
1.21
0.29
0.74

16.25
54.1

1.86
4.25
0.26
0.12
0.87
ND

0.029
0.015
0.015
0.04

7.46

aAverage Nm3 at TP-2 outlet stack during four particulate tests was 6.6 percent higher than flow
 from TP-3 stack.  m3/s was 6.9 percent higher.  These values were used to estimate total  outlet
Jlow.
i I IUW.
 Kormal cubic meters at 21.1°C, 101.7xl03 Pa.
^Normal cubic meters per second at 21.1°C, 101.7xl03  Pa.
 Actual cubic meters per second.
,ND=No data.
•tiw—nu ua ia.
 Benz(a)pyrene  and Benz(e)pyrene analysis combined and reported as one  value.
                                        C-14
-------
          TABLE C-3a.
PARTICULATE  POLYCYCLIC ORGANIC  MATTER CONCENTRATION
  AND EMISSION DATA SUMMARY—PLANT  A
             (OCTOBER 9,  1975)
                  (ENGLISH)
	 ; 	 	 	 _j 	 ', •
Sampling location
Volume of gas sampled— DSCFb
Percent moisture by volume
Average stack temperature— °F
Stack volumetric flow rate—
DSCFMC
Stack volumetric flow rate—
acfm
Percent isokinetic
Inlet
(TP-1)
79.48
2.1
137
26,416
30,625
106.7
(Sampled stack)
Outlet CTP-3)
	 	 	 . 	
99.30
2.2
138
12,009
13,914
99.7
Outlet (TP-2)a
estimated value

__
2.2
138
12,858
14,946

Combined total
flow conditions
for outlet stacks


2.2
138
24,867
28,860

Participate— POM
Sampling location
Component
Anthracene/Phenanthrene
Methyl anthracenes
Fluroanthene
Pyrene
Methyl pyrene/Fluoranthene
Benzo(c)phenanthrene

Chrysene/Benz(a)anthracene
Methyl chrysenes
Benzo fluoranthenes
Benz(a)pyrenef )
Benz(e)pyrene [
Totals
up
Inlet

51.2
181.8
0.950
7.40
4.00
0.350

8.30
21.8
5.30
13.5
294.6
Outlet

44.8
102.2
6.25
2.90
20.9
Not
detected
0.700
0.350
0.350
0.900
179.4
Concentration
(qr/DSCFxlO-6)
inlet Outlet

9.92
35.2
0.18
1.43
0.78
0.068

1.61
4.22
1.03
2.62
5.71xlO-6

6.95
15.8
0.97
0.45
3.24
NDe

0.11
0.054
0.054
0.14
2. 78x1 O-6
Collection efficiency, percent
Emission rate
(Ib/hxlO-3)
Outlet
Inlet (TP-2+TP-3)3

2.25
7.97
0.04
0.32
0. 18
0.015

0.36
0.96
0.23
0.59
12.9x10-3
54.

1.48
q 07
o. j /
n 71
U. £. \
0.096
0. 69
ND

0.023
0.012
0.012
0.030
5.92x10-3
1
 flow.
                         W3S
          _ four particulate tests was 6.6 percent higher than
       percent higher.  These values were used to estimate total outlet
C0ry standard cubic feet at 70°F,  29.92 in. Hg
dDry standard cubic feet per minute at 70°F  29 92 in  Ha
 Actual cubic feet per minute.                    '
fND=No data.
 Benz(a)Pyrene and Benz(e)Pyrene analysis  combined and  reported as one value.
                                        C-15
-------
                          'TP4
                          Outlet
'TP2
Outlet
                    Afterburner
            TP5
                                            Afterburner
                               lTP6
                                Recovery
                                oil  drain
                           TP3
                           Inlet
  (g)TP6
   j  Recovery
   i  oil drain
  nlet
                 Saturator and  Coater Enclosure
Figure C-2.   Block diagram showing relative locations
  of process components and sample points—Plant B.
                         C-16
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                 TABLE C-9.   NO  RESULTS—PLANT B
Sampl i ng
location
TP-1, inlet
TP-2, outlet
TP-2, outlet
TP-2, outlet
TP-3, inlet
TP-4, outlet
Time
Date
9-12-75
9-12-75
9-12-75
9-12-75
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9-12-75
of sampling
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 cell analyzer.
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     TABLE C-ll.
POLYCYCLIC ORGANIC MATTER (POM) EMISSION TESTS SUMMARY-
                  PLANT C
           (HAVF CONTROL DEVICE)

                 (METRIC)
Run number
Date
Volume of gas sampled— Nmsa






Percent moisture by volume
Average stack temperature— °C
Stack volumetric flow rate—
Nm3/sC
Stack volumetric flow rate—
ms/s
Percent isokinetic
Polycyclic organic matter
Component
Anthracene/Phenanthrene
Methyl anthracenes
Fluoranthene
Pyrene
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Benzo(c)phenanthrene
Cyrysene/Benz(a)anthracene
Methyl cyrysenes
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Benz(e)pyrene
Perylene
3-Methy 1 chol anthrene
TOTALS i—
% POM reduction =91.1








Inlet
CEL-5P
10/23/75
1.68
1.26
53.9
9.06
10.34

95.8
Concentration
kq/Nm3x!0-9
In
254
668
1 3
48,
125
12
25
72
0.
0.
0.
2.
3.
-------
  TABLE  C-lla.
POLYCYCLIC ORGANIC MATTER (POM)  EMISSION TESTS SUMMARY-
                 PLANT C
          (HAVF CONTROL DEVICE)

                (ENGLISH)
Run number
Date
Inlet
CEL-5P
10/23/75
Outlet
CEL-6P
10/23/75
Volume of gas sampled—DSCF
Percent moisture by volume
Average stack temperature—°F
Stack volumetric flow rate—
  DSCFMC
Stack volumetric flow rate—
  acfm
Percent isokinetic
                        59.167
                         1.26
                       129
                     19,200

                     21,900

                        95.8
   125.605
     0.09°
   125
20,500

23,100

    92.1
                                Concentration
                                      Emission  rate
                                             _3
Polycyclic organic matter
Component
Anthracene/Phenanthrene
Methyl anthracenes
Fluoranthene
Pyrene
Methyl pyrene/Fluoranthene
Benzo(c)phenanthrene
Cyrysene/Benz(a)anthracene
Methyl cyrysenes
Benzo fluoranthenes
Benz(a)pyrene
Benz(e)pyrene
Perylene
3-Methyl chol anthrene
TOTALS
% POM reduction =91.1
g
r/DSC
Inlet
111
292
6.
21
54.
5.
11.
31.
0.
0.
0.
1.
1.
536

Fxlf
}_b

II
b/nxiu
Outlet inlet
15.
00
3
6
22
1
6
274
0183
0313
19
57


21.
0.
0.
6.
Not
0.
0.
0.
Not
Not


2
0
307
786
95
detected
203
227
0921
0.123s
detected
detected
44.

9

18.
48.
0.
3.
8.
0.
1.
5.
0.
0.
0.
0.
0.
88.

3
987
51
98
859
82
20
0451
00301
00515
196
258
3

\-°


Outlet
2.
.
0.
0.
1.
Not
0.
0.
0.
0.
Not
Not
/.

67
CO
by
0539
138


22
detected
0357
0399
0162
021 6e
detected
detected
89



 ®Dry standard cubic feet at 68°F, 29.92 in.  Hg.
 bSilica gel observed to be saturated during cleanup at end of run.
 ^Dry standard cubic feet per minute at 68°F, 29.92 in. Hg.
  Actual cubic feet per minute.
 eBenz(a)pyrene and Benz(e)pyrene combined and reported as one value.
                                  C-34
-------
TABLE C-12.
TOTAL HYDROCARBON EMISSION TESTS SUMMARY-PLANT C
        (HVAF CONTROL DEVICE)

              (METRIC)  -
Average total hydrocarbon concentration
Date
10/21/75
10/22/75
10/24/75
inlet Outlet Inlet
91 133
120 125
131 134
0.062
0.082
0.089
111 A 1 U
Outlet
0.091
0.086
0.095

gr/uSGF
inlet Outlet
0.0272
0.0359
0.0387
0.0396
0.0375
0.0413
.(ENGLISH)
Date
10/21/75
10/22/75
10/24/75


Inlet
53.80
70.18
77.74
Average total
Jcg/sxlO-3
Outlet
82.91
79.76
88.70
hydrocarbon

Inlet
4.27
5.57
6.17
emission rate
Ib/h


Outlet
6.58
6.33
7.04

                         C-35
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C-37
-------
                                                     SP-2
                                                  v  OUTLET
                            SP-1
                           INLET
NO. 1 SHINGLE
    LINE
 SATURATOR
                                              DEMISTER
                                          HVAF.
                                                 X  SP-3
       Figure C-8.   Block  diagram  showing
          sampling  locations—Plant D.
                       C-38
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                                                       C-40
-------
         TABLE C-16.  PARTICULATE  AND GASEOUS HYDROCARBON  RESULTS  OF
                  SHINGLE LINE SATURATOR HVAF FILTER SYSTEM
                                    PLANT D
Run 1
SPI-1 SP2-1
Particulate Results3
Front half train, 240.6 39.0
TCE wash — mg
Front half train, 4.0 2.8
acetone wash — mg
Pref liter, TCE wash— mg 1.1

Glass fiber filter 322.4 31 2
catch— mg
Total front half— mg . 568.1 73.0
Concentration— kg/Nm3xlO-3 0.213 0 027
Concentration— gr/DSCF 0.093 0.012
Particulate emission rate:
kg/sxlO-< 28 3 35
kg/Mg — 1_
Ib/h 22.4 2 9
Ib/ton — .I

Collection efficiency— % 87.1

Gaseous hydrocarbon results
Minimum value — ppm — 38 o

Maximum value— ppm — 74 3

Weighted average value--ppm -- 53.3

Concentration--kg/Nm3xlO-3 — ' 0.039
Concentration—gr/DSCF — 0.017
Hydrocarbon emission rate:
kg/sxlO-11 — 5.4
Ib/h — 4'27
Production rates
-
a, , . , . . . _
	 	 	 	 - - - 	
Run 2 R,,71 " '.
SP1-2 SP2-2 SFF3 	 SP-TT Average 	
"^ Jr£ j iP"~ 1 ^P— 7
" " ' • 	 ^—
29'2 49'9 27.1 27.^7 98.97 38.87
19 1 Q •, «
K9 " 1-0 2.53 1.90
09 — n it • -
O-4 — 0.80
264.0 39.9 sTi.s 50 5 2gg 3Q 4Q ^
296.0 91.7 340.7 ;79.2 401.60 81.30
0-105 0.034 0.117 0.030 0.145 0.030
0-046 0.015 0.051 ,0.013 0.0633 n.0133

"if 4'7 15-6 4.4 19.2 4.2
n o i~i i? /i '"-,~~ °-16 °-035
"•° 3'7 12-4 3.5 15.27 3.37
0.320 0.071
,_
bfa-4 71.8 77.9


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76.4 - 67.4 ._ 727
c •
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0.043 - 0.039 - 0.041
O-019 " 0.017 - 0.018

" 6'° " 5.7 - 5.7
4.50 — 4.57

43.3 Mg/h (47.7 tons/hi

Weights are minus blanks.
                                   C-41
-------
                                                \
                                                /
TP-2
                                               HEAT

                                            EXCHANGER
                                           AFTERBURNER
                                                         RECOVERY
                                                           OIL
                               s\

                                TP-1
Figure C-9.   Block diagram  showing  relative locations
 of process  components  and  sample points—Plant E.
                        C-42
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             TABLE C-21.   S02  AND NOx READINGS BY CONTINUOUS
                       MONITORING ANALYSIS—PLANT Ed
                                     Inlet
                       Outlet
                              Sulfur dioxide
Saturant blow:
         Run
         Range, ppm
         Mean, ppm

Coating blow:
         Run
         Range, ppm
         Mean, ppm
   B-llDr
<400-730C
     fl
   B-ll'
<400-920C
   NAd
  B-10e
  0-350
   141
  B-10
 46-330
  166
                              Nitrogen oxides^
Saturant blow:
         Run
         Range, ppm
         Mean, ppm
   B-9
 0-1,600
   902
  B-12
245-500
   391
Coating blow:
Run
Range, ppm
Mean, ppm
B-9
60-1,900
814
B-12f
50-435
260
 aS02  data  are  from  EnviroMetrics  analyzer;  NOX  data  are  from DynaScience
 .analyzer.
 bData taken  during  a portion  of a coating blow  representing last
  10 minutes  of saturant blow.
 Calibration gas  cylinders  empty  at end of  run  and,  thus,  analyzer
 .calibration could  not be verified.
  Mean values not  available  as complete blow was not  sampled.
 eData taken  during  saturant blow  proceeding coating  blow for which  B-10
 -particulate samples were collected.
 TThis coating  blow  did not  appear normal as flow was stopped during the
  process.
 9No S02 scrubber  was used ahead of the analyzer used to  make the  NOX
  measurements. Thus, they  may contain a contribution due to the  S02,
  as well as  NOX-
                               C-50
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                                            C-53
-------
          TABLE C-24.   SUMMARY OF VISIBLE EMISSIONS—PLANT G
Date:     6/11/74
Type of plant:  Crushed stone—conveyor transfer point
Type of discharge:  Stack
Distance from observer to discharge point:  18.3 m (60 ft)
Location of discharge:  Baghouse
Height of observation point:  Ground-level
Height of point of discharge:  2.44 m (8 ft)
Direction of  observer from discharge point:  North
Description of background:  Grey apparatus
Description  of  sky:
Wind  direction:
Wind  velocity:
Color of plume:
Detached plume:
Duration of observation:
    Clear
    Westerly
    0 to 4.47 m/s  (0  to  10  mi/h)
    None
    No
    240 minutes

Summary of Average Opacity
           Time	
 Set number
  Start
                                         End
                               Sum
                                                            Opacity
Average
 1 through 30              10:40         1:40            0           0
 31 through 40              1:45         4:45            0           0
 Readings were 0 percent opacity during all periods of observation.
                                  C-54
-------
           TABLE C-25.  SUMMARY OF VISIBLE EMISSIONS-PLANT H
 Date:     11/21/74
 Type of plant:  Crushed stone—finishing screens
 Type of discharge:   Stack
 Distance from observer to discharge point:   61  m (200 ft)
 Location of discharge:   Baghouse
 Height of observation point:   15.2 m (50 ft)
 Height of point of  discharge:   12.2 m (40 ft)
 Direction of observer from discharge point:  Northwest
 Description  of background:  Dark woods
 Description  of  sky:
 Wind direction:
 Wind velocity:
 Color of plume:
 Detached plume:
 Duration of observation:
  Overcast
  Easterly
  4.47 to 13.4 m/s (10 to 30 mi/h)
  White
  No
  240 minutes
Set number
                        Summary of Average Opacity
                          	      Time
Start
                                        End
                             Sum
Opacity	
      Average
1 through 40              12:10         4:10            0           0
Readings were 0 percent opacity during all  periods of observation.
                                C-55
-------
          TABLE C-26.   SUMMARY OF VISIBLE EMISSIONS—PLANT J

Date:     9/18/74
Type of plant:  Crushed stone—finishing screens
Type of discharge:  Stack
Distance from observer to discharge point:  91.44 m (300 ft)
Location of discharge:  Baghouse
Height of observation point:  12.2 m (40 ft)
Height of point of discharge:  17.76 m (55 ft)
Direction of  observer from discharge point:  North
Description of background:  Trees
Description of sky:
Wind direction:
Wind velocity:
Color of plume:
Detached plume:
Duration of observation:
  Clear
  Northerly
  2.235 to 4.47 m/s (5 to 10  mi/h)
  None
  No
  240 minutes
                         Summary  of Average  Opacity
                                    Time
 Set number
Start
End
                                                        Sum
                                 Opacity
Average
 1  through 40              8:10          12:30            0           0
 Readings were 0 percent opacity during all  periods  of observation.
                                  C-56
-------
           TABLE C-27.   SUMMARY OF VISIBLE EMISSIONS—PLANT K
 Date:      11/16/74-11/19/74
 Type of plant:   Crushed stone—finishing screens and bins
 Type of discharge:   Stack
 Distance from observer to discharge  point:   36.58 m (120  ft)
 Location of discharge:   Baghouse
 Height  of observation  point:   Ground-Level
 Height  of point  of  discharge:   0.15  m  (0.5  ft)
 Direction of observer  from  discharge point:  South
 Description  of background:  Hillside
Description of sky:
Wind direction:
Wind velocity:
Color of plume:
Detached plume:
Duration of observation:
    Clear
    Westerly
    0.894 to 4.47 m/s (2 to 10 mi/h)
    None
    No
    11/19/74:  120 minutes; 11/19/74: 60 minutes

Summary of Average Opacity
           Time
Set number
11/18/74:

11/19/74
1
1 1
21
through
through
through
10
20
30
Start
12:
1:
9:
50
50
05
End
1:
2:
10:
50
00
05
Sum
0
o
0
Average
0
n
0
Readings were 0 percent opacity during all  periods of observation.
                                 C-57
-------
          TABLE C-28.'  SUMMARY OF VISIBLE EMISSIONS—PLANT L
Date:     9/30/76

Type of plant:  Mica

Type of discharge:  Fugitive

Distance from observer to discharge point:  2.13 m (7 ft)

Location of discharge:  Bagging operation

Height of observation point:  Ground-level

Height of point of discharge:  0.91 m (3 ft)

Direction of observer from discharge point:  N/A

Description of background:  Indoors
Description of sky:

Wind direction:

Wind velocity:

Color of plume:

Detached plume:

Duration of observation:
     Opacity,
     percent

       5
      10
      15
      20
      25
N/A

N/A

N/A

N/A

N/A

1 hour


  Summary of Data
                 Total time equal to or
                 greater than given opacity
                     Min.             Sec.
                      0
                      0
                      0
                      0
                      0
0
0
0
0
0
                                 C-58
-------
                    APPENDIX  D.   EMISSION  MEASUREMENT AND
                           CONTINUOUS  MONITORING

  D.I   EMISSION MEASUREMENT METHODS
       Particulate pollutants  in  the fonn  of organic  solids and oils are
  generated in the manufacture of asphalt  roofing products.  Reference
  Method 26 was developed to measure these emissions  using Reference
  Method 5 as a base, and then making modifications suitable for collecting
  the singular type of particulate emission.
      Method development tests and emission measurements were conducted at
 seven asphalt roofing plants.  These studies resulted not only in
 obtaining measurements of particulate  emissions,  but also in developing a
 particulate sampling procedure,  Reference Method  26, for isokinetic
 collection of representative particulate  samples  and determination  of the
 particulate emission concentration.  Reference Method 26 is  basically a
 modification of  Reference  Method 5.  The  major differences between  the
 two  methods  include:
      1.    Change in filtration temperature from 120°C to 40°C  (248°F  to
 104°F).
      The  physical state of organic matter is a  function  of temperature.
 Therefore, it is necessary to select a filtration temperature that
 provides  a consistent basis  for  evaluating the  different  control systems
 and  the emissions from different plants.  The 40°C (104°F) upper limit
 was  selected to  be  consistent with the optimum  operating  temperature of
 40°C  (104°F) for the collection systems,  i.e. filtration and electro-
 static precipitation.
     2.   Use of a precollector filter to reduce the oil droplet loading
on the primary filter.
     This change was necessary to prevent oil  from seeping through the
glass-fiber filter mat during periods of high droplet concentrations.   A

                                   D-l
-------
procedure to avoid the necessity of quantitatively removing the oil from
the precollector was added to the method.  This procedure involves
weighing the precollector system before and after sampling to obtain the
mass collected by difference.  Use of this precollector is optional in
Reference Method 26 and is intended for use when sampling emissions from
the blowing still control device.
     3.   Change in cleanup  reagent from acetone to 1,1,1-trichloroethane.
     Sample cleanup and recovery procedures were also developed and
tested during the method development program.  Various solvents were
used, e.g., acetone, chloroform, hexane, 1,1,1-trichloroethane,- diethyl
ether, methylene chloride, and trichloroethylene.  The chlorinated hydro-
carbons  proved to be the most effective  solvents.  Chloroform and  methylene
chloride were rejected  as  unsafe due to  the  toxic  chemical exposure
criteria established by OSHA.  The  solvent,  1,1,1-trichloroethane  (TCE)
was  decided  upon because  it  was most effective in  dissolving  the  baked-on
oil  and  tars and, due to  its lower  vapor pressure, was potentially less
toxic  than  the  other solvents.
     4.    Change  in analytical  procedure to  minimize  sample  loss  through
evaporation.
      In  the laboratory  the cleanup  reagent presented  some problems.   The
low vapor  pressure  of TCE caused an increase in  the time necessary to
evaporate  the  samples at ambient temperature to a final  weight.   Experi-
ments  were conducted to quantify the  loss  of light hydrocarbons  by
condensing the vapors from the evaporation process and analyzing them by
 gas chromatography.  Results showed that the hydrocarbon loss for outlet
 sample fractions was minimal.
      A continuous weight loss was recorded for the samples over a period
 of several  weeks after removal  of the  condenser.  The weight loss was
 most significant for inlet samples.  The outlet samples also continued to
 lose weight, but to a lesser degree.   Consequently,  the criterion of
 "constant weight" was defined as "a less than 10 percent or 2 mg  (which-
 ever is greater) mass change between two sequential  weighings twenty-four
 hours apart."  Most samples weighed in this manner reached a constant
 weight  between-the 24 to 48 hour weighings.
                                    D-2
-------
       5.    Collection and analytical  procedure for condensed water.
       In  cases  where moisture contents  of the stack gases were above
  10 percent,  condensation in the filtration section of the sample train
  occurred.  These  conditions did not  happen when  sampling saturator line
  emissions, but did  occur during the  blowing still  tests.  By cooling the
  sample gas to  40°C  (104°F)  in  the  probe  and precollector cyclone,  the
  moisture was trapped  in  the cyclone  collection flask.   In  the analyses,
  the oil was extracted from  the  water phase  using a separatory funnel and
  TCE.  The remaining water fraction was evaporated  at  100°C  (212°F),
  desiccated, and weighed.
  D-l.l  Other Emission Test  Procedures
      Previous  investigators used test methods which differed  from  the EPA
 approach.  These methods, e.g., LAAPCD and conventional  Method 5 including
  impinger analysis, measured both filterable and condensible hydrocarbons
 as particulate:  The gaseous hydrocarbons were measured by flame ioni-
 zation analysis; the sample gas, however, was taken directly from the
 stack.   The gases  were neither filtered nor cooled to 40°C (104°F).  In
 some cases  the  data gave similar emission rates.   In other cases, large
 differences occurred.   Since EPA did  not conduct  comparative tests, it
 cannot be determined if these differences were due to process operating
 conditions  or to differences in the test methods.
      Visible  emissions were  measured  by Method 9.  Fugitive emissions
 were measured by Method  22.

 D.2 CONTINUOUS MONITORING
     The  transmissometer  is  not ideally  suited to the  measurement of
 opacity in the  effluent gas  stream  from an  asphalt  roofing  plant.   The
 effects of variable  stack gas temperatures  can cause the  readings of the
 transmissometer to lack any  correlation with  Reference Method  9 measure-
ments.  For example, by increasing  the stack  temperature, the  oil droplets
 that cause the  visible emissions will  be converted into a gas  which would
not be detected  by the transmissometer but which .will  recondense and  be
visible in the atmosphere.   Depending  on stack temperature at the
measurement point,  the transmissometer may be a useful tool for monitoring
operation and  maintenance.

                                   D-3
-------
D.3  PERFORMANCE TEST METHODS
     Performance Test Method 26, which is recommended for the measurement
of participate emissions from asphalt roofing processes, is essentially
a modification of Reference Method 5.  Changes were made in the sample
filtration temperature and in the cleanup and analysis.  The procedure is
sufficiently similar to Method 5 so that test personnel experienced with
Method 5 should have little difficulty with Method 26.
     The asphalt roofing industry has two major processes, each with
peculiar problems which hamper the performance of the emission test.  The
asphalt saturator line is a continuous process, subject to numerous line
speed fluctuations and stoppages, thus making coordination of testing
with the process essential.  Extra care must be used to maintain the
sample intergrity during these times.
     The blowing still facility is a batch process.  The process may last
several hours.  Emissions, flow rates, moisture contents, and temperatures
are a function of time.  Careful attention is required to ensure that the
sample collected is representative of the emission and the process as
defined in the regulation.
     Sampling costs for a test consisting of three Method 26 runs is
estimated to be about $8,000 to $12,000.  If in-plant personnel are used
to conduct the tests, the costs will be somewhat less.
     Method 9 is recommended for measurement of opacity from stacks and
similarly confined emission sources.  Method 22 is recommended for ths
determination of the frequency of visible fugitive emissions produced
during material processing, handling, and transfer operations.
                                   D-4
-------
                                    TECHNICAL REPORT DATA
                            (Mease read Instructions on the reverse before completing!
 1. REPORT NO.
  EPA-450/3-80-021a
                                                            3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
  Asphalt Roofing Manufacturing  Industry -
  Background Information for  Proposed Standards
              5. REPORT DATE

                June 1980
              6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
                                                            8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
  Office of Air Quality  Planning and Standards
  U.S.  Environmental Protection Agency
  Research Triangle Park, North Carolina  27711
              10. PROGRAM ELEMENT NO.
              11. CONTRACT/GRANT NO.
                 68-02-3059
 12. SPONSORING AGENCY NAME AND ADDRESS
  DAA for Air Quality Planning and Standards
  Office of Air, Noise, and  Radiation
  U.S.  Environmental Protection Agency
  Research Triangle Park,  North Carolina  27711
              13. TYPE OF REPORT AND PERIOD COVERED
                 Final
              14. SPONSORING AGENCY CODE

                 EPA/200/04
15. SUPPLEMENTARY NOTES
  This report discusses the  proposed new source performance standards and
  the resulting environmental  and economic impacts.
16. ABSTRACT
  Standards of Performance for the control of emissions,from the asphalt roofing
  manufacturing industry are being proposed under  Section 111 of the Clean Air  Act.
  These standards would  apply only to saturators,  blowing stills, storage tanks, and
  mineral handling and storage operations in asphalt roofing plants, and blowing stills
  and storage tanks in oil refineries and asphalt  processing plants.  This document
  contains background information and environmental  and economic impact assessments of
  the regulatory alternatives considered in developing proposed standards.
 7.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS  C. COSATI Field/Group
  Air Pollution
  Pollution Control
  Standards of Performance
  Asphalt Roofing Manufacturing
  New Source Performance  Standards
  Particulates
  Air Pollution Control
     13b
 8. DISTR BUTION STATEMENT
  Unlimited
19. SECURITY CLASS (ThisReport)
  Unclassified
21. NO. OF PAGES
     398
                                               20. SECURITY CLASS (This page)

                                                 Unclassified
                                                                          22. PRICE
EPA Form 2220 — 1 (Rev. 4—77)   PREVIOUS EDITION is OBSOLETE
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