EPA 450/2-74-003
(APTD-1352c)
February 1974
BACKGROUND INFORMATION
FOR NEW SOURCE
PERFORMANCE STANDARDS:
Asphalt Concrete Plants
Petroleum Refineries
Storage Vessels
Secondary Lead Smelters and Refineries
Brass or Bronze Ingot Production Plants
Iron and Steel Plants
Sewage Treatment Plants
Volume 3, PROMULGATED STANDARDS
U.S. ENVIRONMENTAL PROTECTION AGENCY
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Copies of this report are available free of charge to Federal
employees, current contractors and grantees, and nonnrofit
organizations - as supplies permit - from the Air Pollution
Technical Information Center, Environmental Protection Agency,
Research Triangle Park, North Carolina 27711; or, for a fee,
from the National Technical Information Service, Springfield,
Virginia 22151.
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EPA 450/2-74-003
(APTD-l352c)
BACKGROUND INFORMATION
FOR NEW SOURCE
PERFORMANCE STANDARDS:
Asphalt Concrete Plants
Petroleum Refineries
Storage Vessels
Secondary Lead Smelters and Refineries
Brass or Bronze Ingot Production Plants
Iron and Steel Plants
Sewage Treatment Plants
Volume 3, PROMULGATED STANDARDS
LIBRARY
Envton. Prot Agency, WOO
Oteoo, N«w Jersey 08817
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Water Programs
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
February 1974
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This report has been reviewed by the Environmental Protection Agency and
approved for publication. Mention of trade names or commercial products
does not constitute endorsement or recommendation for use by the Agency.
Note: The first two volumes published under the title Background Informa-
tion for Proposed New Source Performance Standards (Volume 1, Main Text and
Volume 2, Appendix: Summary of Test Data) were issued under Environmental
Protection Agency publication numbers APTD-1352a and APTD-1352b, respectively.
Since their publication, EPA has adopted a new numbering system for its doc-
uments. Therefore, this documentVolume 3, Promulgated Standardswas
issued as publication number EPA-450/2-74-003 (APTD-1532c).
Publication No. EPA-450/2-74-003
(APTD-1352c)
11
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TABLE OF CONTENTS
LIST OF FIGURES v
LIST OF TABLES v
ABSTRACT vfi
CHAPTER 1. INTRODUCTION 1
CHAPTER 2. GENERAL CONSIDERATIONS 3
SUBPART A, GENERAL PROVISIONS 3
OPACITY STANDARDS 5
TEST METHODS 7
CHAPTER 3. ASPHALT CONCRETE PLANTS 9
SUMMARY OF PROMULGATED STANDARDS 9
DISCUSSION OF PROMULGATED REGULATION 9
Change in the Concentration Standard 9
Change in the Opacity Standard 13
Applicability of the Standard 14
Revisions to the Cost Estimates 14
Minor Revisions to the Regulation 15
CHAPTER 4. PETROLEUM REFINERIES 17
SUMMARY OF PROMULGATED STANDARDS , 17
Fuel Gas Combustion Systems 17
Fluid Catalytic Cracking Unit Catalyst Regenerators 17
DISCUSSION OF PROMULGATED REGULATION 19
Fuel Gas Combustion Systems 19
Flare Systems 19
Monitoring of Hydrogen Sulfide 20
Exemption of Small Refineries 20
Fluid Catalytic Cracking Unit Catalyst Regenerators 22
Change in the Opacity Standard 22
Type of Standard 24
Level of the Emission Standard , . 28
Exemption of Small Sources 34
CHAPTER 5. STORAGE VESSELS FOR PETROLEUM LIQUIDS 37
SUMMARY OF PROMULGATED STANDARD 37
DISCUSSION OF PROMULGATED REGULATION 37
Affected Facility 37
The Standard 39
Monitoring 39
Maintenance 40
CHAPTER 6. SECONDARY LEAD SMELTERS AND REFINERIES 41
SUMMARY OF PROMULGATED STANDARDS 41
DISCUSSION OF PROMULGATED REGULATION 41
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CHAPTER 7. SECONDARY BRASS AND BRONZE INGOT PRODUCTION PLANTS 43
SUMMARY OF PROMULGATED STANDARDS 43
DISCUSSION OF PROMULGATED REGULATION 43
Change in the Opacity Standards 44
CHAPTER 8. IRON AND STEEL PLANTS 47
SUMMARY OF PROMULGATED STANDARD 47
DISCUSSION OF PROMULGATED REGULATION 47
CHAPTER 9. SEWAGE TREATMENT PLANTS 49
SUMMARY OF PROMULGATED STANDARDS 49
DISCUSSION OF PROMULGATED REGULATION 49
Change of Units for the Standard 49
Change in the Opacity Standard 52
Emission Test Conditions 53
APPENDIX A. ASPHALT CONCRETE PLANT DATA SUBMITTED AFTER PROPOSAL 57
APPENDIX B. THE ECONOMIC IMPACT OF NEW SOURCE PERFORMANCE STANDARDS UPON THE
ASPHALT CONCRETE INDUSTRY 77
APPENDIX C. THE ECONOMIC IMPACT OF NEW SOURCE PERFORMANCE STANDARDS UPON
PETROLEUM REFINERIES 101
APPENDIX D. LIST OF COMMENTATORS 109
APPENDIX E. SUMMARY OF COMMENTS AND RESPONSES PERTINENT TO NEW SOURCE
PERFORMANCE STANDARDS PROPOSED IN .FEDERAL REGISTER OF JUNE 11, 1973. ... 117
APPENDIX F. ERRATA FOR VOLUME 1 141
APPENDIX G. ERRATA FOR VOLUME 2 147
IV
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LIST OF TABLES
Table
1-1. Number of Letters by Affiliation Category 2
3-1. Summary of all Emission Test Data 11
3-2. Acceptable Emission Test Data Submitted After Proposal 12
4-1. Pollution Control Costs Imposed on Petroleum Refining 23
9-1. Relationship of Operating at Less than Rated Capacity to Mass Emissions
from Impingement Scrubbers 54
9-2. Relationship of Pressure Drop to Mass Emissions from Impingement Scrubbers. ... 55
LIST OF FIGURES
Figure
3-1 Cost Comparison Between EPA Costs and NAPA Exhibit Costs 15
4-1 Fluid Catalytic Cracking Unit Catalyst Regenerator Emission Control Systems ... 26
4-2 Particulate Emissions from Fluid Catalytic Cracking Unit Catalyst Regenerators. . 30
4-3 Particulate Emissions vs. Time for Facility A 32
9-1 Particulate Emissions from Sludge Incinerators at Sewage Treatment Plants .... 51
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ABSTRACT
This volume is the third in a series on standards of performance for asphalt
concrete plants, petroleum refineries, storage vessels for petroleum liquids,
secondary lead smelters, brass and bronze ingot production plants, iron and
steel plants, and sewage treatment plants. The first two volumes gave background
information and the data base for the proposed standards. This volume presents
the promulgated standards and the rationale for any changes that were made,
with particular attention to the problems of opacity and dilution air. Major
comments received during the period for public comment are discussed where
appropriate and are summarized with Agency responses in the appendix. The
appendices also contain a list of commentators, new data for asphalt concrete
plants, revised economic analyses for asphalt concrete plants and petroleum
refineries, and errata for Volumes 1 and 2.
vn
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CHAPTER 1. INTRODUCTION
The first two volumes of this document were published in June 1973 under the
title Background Information for Proposed New Source Performance Standards
(APTD-1352a and APTD-1352b). They provided information on the derivation of the
new source performance standards proposed in the Federal Register of June 11, 1973
(38 FR 15406), as amendments to Title 40 CFR Part 60. Standards were proposed
for asphalt concrete plants, petroleum refineries, storage vessels, secondary lead
smelters, secondary brass and bronze ingot production plants, iron and steel plants,
and sewage treatment plants. Volume 1 discussed the sources and types of emissions
for each industry, the rationale for the proposed standards, and the environmental
and economic impacts of the proposed standards. Volume 2 presented summaries of the
source test data upon which the proposed standards were based.
During the public comment period following proposal, EPA received 253 letters from
various industry representatives, environmental groups, State and local agencies, and
private citizens. Table 1-1 presents a breakdown of these letters by category of
affiliation. Over 65 percent of the letters concerned the standard proposed for
asphalt concrete plants. In addition to those 253 letters, EPA received 152 letters
from 94 Congressmen, of which 142, or over 93 percent, likewise concerned the proposed
standard for the asphalt concrete industry. The comments were all carefully evaluated;
in many cases, staff engineers telephoned the commentators to clarify their comments
or to ask for elaboration on certain points. The comments received were very helpful in
pointing out problems with the proposed standards; in some cases, comments addressed
to one issue stimulated EPA personnel to rethink other aspects of the standards-
setting rationale.
In response to the comments received, and in response to new data received after
proposal, some revisions were made to the regulations covering the seven industries
cited above. This volume, which accompanies the promulgated regulations, summarizes the
promulgated standards and discusses those issues that led to any revisions. Chapter 2,
General Considerations, deals with revisions made to the General Provisions, and covers
two issues that were common to most of the seven industries. It was evident from the
many comments received concerning opacity standards and uses of dilution air that EPA
had not clearly stated its position on these subjects. Chapter 2 therefore presents
a discussion of the intent of opacity standards and a discussion of the revision in the
regulations that covers uses of dilution air.
The promulgated standards are summarized by industry in the following chapters.
Any changes in the applicable regulations are discussed, and a rationale for any
such changes is presented.
1
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TABLE 1-1. NUMBER OF LETTERS BY AFFILIATION CATEGORY
Category Number received
State and local air pollution
control agencies 12
State and local governmental
agencies 6
Federal government 4
Congress 1
Asphalt associations 24
Asphalt companies 141
Asphalt plant equipment
manufacturers 1
Petroleum refiners 26
Petroleum product
storage companies 7
Petroleum associations 7
Brass and bronze associations 1
Iron and steel plants 2
Consulting firms 12
Control equipment manufacturers 4
Miscellaneous 5
Total 25?
Asphalt concrete plant data submitted after proposal are found in Appendix A,
and Appendix B is a revised cost analysis for this industry. A revised estimate of the
economic impact of the promulgated standard for petroleum refineries is contained in
Appendix C. Appendix D presents, by number assigned, the names and affiliations of
those who wrote to EPA during the public comment period. A summary of their major
comments and EPA's responses to the comments may be seen in Appendix E. Appendices
F and 6, respectively, contain errata for Volumes 1 and 2 of this document.
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CHAPTER 2. GENERAL CONSIDERATIONS
This chapter treats those matters which bear on all, or nearly all, of the new
source performance standards.
Subpart A, General Provisions
The regulatory requirements in subpart A of 40 CFR 60 apply to all new source perfor-
mance standards. These general provisions were not reprinted in their entirety in the
Federal Register of June 11, 1973,in which this current group of new source performance
standards was proposed; only proposed changes to subpart A are to be found in that issue.
To read subpart A in its current entirety, one can refer to the Federal Register of
December 23, 1971 (page 24877), which contains the first group of new source performance
standards; to the Federal Register of October 15, 1973 (page 28564), which contains the
provisions applicable to emissions from sources during periods of startup, shutdown, and
malfunction; and to the changes in subpart A promulgated with this group of new source
performance standards. The changes to subpart A promulgated with this group of new
source standards are discussed below.
1. Two definitions are revised, those for "commenced" and "standards," to clarify
their meanings. "Commenced" relates to the definition of "new source" in section 111(a)(2)
of the Act and specifies the actions which, if taken by an owner/operator of a source on
or after the date on which a new source performance standard is proposed in the
Federal Register, cause his source to be subject to the promulgated standard. The change
removed one of the previously included actions by an owner/operator, that of entering into
a "binding agreement" to construct or modify a source. The phrase "binding agreement"
was duplicate terminology for the phrase "contractual obligation" but was being construed
incorrectly to apply to other arrangements. Deletion of the first phrase and retention
of the second phrase eliminate the problem. "Standard conditions" refers to the tempera-
ture and pressure at which all air volumes are to be calculated. The change replaces
"standard or normal" with "standard" to avoid the confusion, noted by commentators,
created by the duplicate terminology, and also fixes both the temperature and pressure
in commonly used metric units to be consistent with the national policy of converting to
the metric system.
2. Four definitions are added: "reference method," "equivalent method,"
"alternative method," and "run," which relate to the performance testing of new sources
to determine compliance with regulatory emission limitations. They are added to clarify
the terms used in changes to section 60.8, Performance Tests, discussed below.
3. The definition of "particulate matter" is added to the General Provisions
and removed from each of the regulations pertinent to new sources to avoid repeating the
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definition, and it is changed to include "as measured by an equivalent or alternative
method."
4. The section dealing with abbreviations is revised (and reprinted in its entirety)
to include new abbreviations, to agree more closely with standard usage, and to alphabe-
tize the listing.
5. The address to which all requests, reports, applications, submittals, and other
communications submitted to the Administrator pursuant to any provision of the regulation
will be sent is changed from the Office of General Enforcement in Washington, D. C., to
the Director of the Enforcement Division in the appropriate regional office of EPA, and
the addresses of all ten regional offices are included. The "in triplicate" requirement
is changed to "in duplicate."
6. Some of the wording is changed in section 60.6, Review of plans. This section
provides for EPA review of plans for construction and modification of sources upon
request by owners/operators. The change clarifies the requirement that a separate
request must be submitted for each project but not for each facility affected by a regu-
latory emission limitation. Each affected facility, however, must be identified and
appropriately described.
7. The requirement for owners/operators to maintain a file of the data and records
required by the new source performance standards is added to General Provisions and
removed from each of the regulations for new sources to avoid repetition.
8. Section 60.8, which deals with the performance testing required of new sources
to determine compliance with regulatory emission limitations, is amended (1) to require
owners/operators to give the Administrator 30 days' instead of 10 days' advance notice
of performance testing to provide the Administrator with a better opportunity to have an
observer present; (2) to specify the Administrator's authority to permit, in specific
cases, the use of minor changes to reference methods, the use of equivalent methods,
the use of alternative methods, or the waiver of the requirement for performance testing;
and (3) to specify that each performance test shall consist of three runs except where
the Administrator approves the use of two runs and that the arithmetic mean of the
results shall be used to determine compliance.
9. Section 60.12, Circumvention, is added to make it clear that owners/operators
are prohibited from using devices or techniques which conceal rather than control
emissions in order to comply with regulatory emission limitations. The proposed new
source performance standards e-ach contained provisions intended to prohibit the dilution
of gases to conceal emissions. Many commentators pointed out the inequities of these
provisions and the vagueness of the language used. Because many processes require the
addition of air in various quantities for cooling, for enhancing combustion, and for
other useful purposes, it was deemed preferable to state clearly what is, prohibited and
to use the Administrator's authority to specify the conditions under which compliance
testing is carried out in each case to ensure that the prohibited concecilment is not
used.
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Opacity Standards
It is evident from comments received that an inadequate explanation was given for
applying both an enforceable opacity standard and an enforceable concentration standard
i
to the same source and that the relationship between the concentration standard and the
opacity standard was not clearly presented. Because all but one of the regulations include
these dual standards, this subject is dealt with here from the general viewpoint. Specific
changes made to the regulations proposed are discussed in each of the chapters devoted
to the regulations for specific sources.
A discussion of the major points raised by the comments on the opacity standard
follows:
1. Several commentators felt that opacity limits should be only guidelines for
determining when to conduct the stack tests needed to determine compliance with concentration/
mass standards. Several other commentators expressed the opinion that the opacity standard
was more stringent than the concentration/mass standard.
As promulgated, the opacity standards are regulatory requirements, just like
the concentration/mass standards. It is not necessary to show that the concentration/
mass standard is being violated in order to support enforcement of the opacity standard.
Where opacity and concentration/mass standards are applicable to the same source, the
opacity standard is not more restrictive than the concentration/mass standard. The concen-
tration/mass standard is established at a level which will result in the design,
installation and operation of the best adequately demonstrated system of emission reduction
(taking costs into account) for each source. The opacity standard is established at a
level which will require proper operation and maintenance of such control systems on
a day-to-day basis, but not require the design and installation of a control system more
efficient or expensive than that required by the concentration/mass standard.
Opacity standards are a necessary supplement to concentration/mass standards. Opacity
standards help ensure that sources and emission control systems continue to be properly
maintained and operated so as to comply with concentration/mass standards. Particulate
testing by EPA method 5 and most other techniques requires an expenditure of $3,000 to
$10,000 per test including about 300 man-hours of technical and semi-technical personnel.
Furthermore, scheduling and preparation are required such that it is seldom possible to
conduct a test with less than 2 weeks notice. Therefore, method 5 particulate tests can
be conducted only on an infrequent basis.
If there were no standards other than concentration/mass standards, it would be
possible to inadequately operate or maintain pollution control equipment at all times except
during periods of performance testing. It takes "> weeks or longer to schedule
a typical stack test. If only small repairs were required, e.g., Dump or fan repair or
reolacement of fabric filter bags, such remedial action could be delayed until shortly
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before the test was conducted. For some types of equipment such as scrubbers,
the energy input (the pressure drop through the system) could be reduced when
stack tests weren't being conducted, and this could result in the release
Of significantly more particulate (ratter than normal. ""herefore, EPA has required
that operators properly maintain air pollution control equipment at all times (40 CFR
60.n(d)) and meet opacity standards at all times except during periods of startup,
shutdown, and malfunction (40 CFR 60.11 (c)), and during other periods of exemption as
specified in individual regulation:,.
Opacity of emissions is indicative of whether control equipment is properly
maintained and operated. However, it is established as an independent enforceable
standard, rather than an indicator of maintenance and operating conditions because
information concerning the latter is peculiarly within the control of the plant operator.
Furthermore, the time and expense required to prove that proper procedures have not been
followed are so great that the provisions of 40 CFR 60.11(d) by themselves (without
opacity standards) would not provide an economically sensible means of ensuring on a
day-to-day basis that emissions of pollutants are within allowable limits. Opacity
standards require nothing more than a trained observer and can be performed with no
prior notice. Normally, it is not even necessary for the observer to be admitted to
the plant to determine properly the opacity of stack emissions. Where observed
opacities are within allowable limits, it is not norma"ly necessary for enforcement
personnel to enter the plant or contact plant personnel. However, in some cases,
including times when opacity standards may not be violated, a full investigation of
operating and maintenance conditions will be desirable. Accordingly, EPA has require-
ments for both opacity limits and proper operating and maintenance procedures.
2. Some commentators suggested that the regulatory opacity limits should be
lowered to be consistent with the opacity observed at existing plants; others
felt that the opacity limits were too stringent. The regulatory opacity limits are
sufficiently close to observed opacity to ensure proper operation and maintenance
of control systems on a continuing basis but still allow some room for minor variations
from the conditions existing at tie time opacity ^eadings were made.
3. There are specified periods during which opacity standards do not apply.
Commentators questioned the rationale for these time exemptions as proposed, some
pointing out that the exemptions were not justified and some that they were inadequate.
Time exemptions further reflect the stated purpose of opacity standards by providing
relief from such standards during periods when acceptable systems of emission reduction
are judged to be incapable of meeting prescribed opacity limits. Opacity standards
do not apply to emissions during periods of startup, shutdown, and malfunction (see
Federal Register of October 15, 1973, 38 FR 28564), nor do opacity standards apply during
periods judged necessary to permit the observed excess emissions caused by soot-blowing
and unstable process conditions. Some confusion resulted from the fact that the startup-
shutdown-malfunction regulations were proposed separately (see Federal Register of
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May 2, 1973) from the regulations for this group of new sources. Although, this was
pointed out in the preamble (see Federal Register of June 11, 1973) to this group of
new source performance standards, it appears to have escaped the notice of several
commentators.
4. Other comments, along with restudy of sources and additional opacity observations,
have led to definition of specific time exemptions, where needed, to account for excess
emissions resulting from soot-blowing and process variations. These specific actions
replace the generalized approach to time exemptions, that of 2 minutes per hour, contained
in all but one of the proposed opacity standards. The intent of the 2 minutes was to
prevent the opacity standards from being unfairly stringent and reflected an arbitrary
selection of a time exemption to serve this purpose. Comments noted that observed
opacity and operating conditions did not support this approach. Some pointed out
that these exemptions were not warranted; others, that they were inadequate. The
cyclical basic oxygen steel-making process, for example, does not operate in hourly
cycles and the inappropriateness of 2 minutes per hour in this case would apply to
other cyclical processes which exist both in sources now subject to standards of performance
and sources for which standards will be developed in the future. The time exemptions now
provide for circumstances specific to the sources and, coupled with the startup-shutdown-
malfunction provisions and the higher-than-observed opacity limits, provide much better
assurance that the opacity standards are not unfairly stringent.
Test Methods
Test Methods 10 and 11 as proposed contained typographical errors in both text
and equations that are now corrected. Some wording is changed to clarify meanings and
procedures as well.
In Method 10, which is for determination of CO emissions, the term "grab sampling"
is changed to "continuous sampling" to prevent confusion. The Orsat analyzer is deleted
from the list of analytical equipment because a less complex method of analysis was
judged sufficiently sensitive. For clarification, a sentence is added to the section on
reagents requiring calibration gases .to be certified by the manufacturer. Temperature
of the silica gel is changed from 177°C (350°F) to 175°C (347°F) to be consistent with
the emphasis on metric units as the primary units. A technique for determining the
COg content of the gas has been added to both the continuous and integrated sampling
procedures. This technique may be used rather than the technique described in Method 3.
Use of the latter technique was required in the proposed Method 10.
Method 11, which is for determination of H£S emissions, is modified to require five
midget impingers rather than the proposed four. The fifth impinger contains hydrogen
peroxide to remove sulfur dioxide as an interferent. A paragraph is added specifying
the hydrogen peroxide solution to be used, and the procedure description is altered to
include procedures specific to the fifth impinger. The term "iodine number flask" is
changed to "iodine flask" to prevent confusion.
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CHAPTER 3. ASPHALT CONCRETE PLANTS
SUMMARY OF PROMULGATED STANDARDS
The promulgated standards of performance for asphalt concrete plants limit emissions
of participate matter as follows:
1. No more than 90 mg/dscm (0.04 gr/dscf).
2. Less than 20 percent opacity.
Visible emissions caused solely by the presence of uncombined water are not subject
to the opacity standard.
The opacity standard, to ensure that emissions of particulate matter are properly
collected and vented to a control system, applies to the sources specified in the
applicability section of the regulation. The concentration standard applies to emissions
of particulate matter from the control system, as evidenced by the test methods required
for determining compliance with this standard.
DISCUSSION OF PROMULGATED REGULATION
The proposed standards for asphalt concrete plants clearly generated the most public
response. Over four times as rrany comments were received on these standards as on
standards for the other six source categories. In response to the comments and new
information received, several revisions were made to the proposed standards. The major
differences between the proposed standards and the promulgated standards are:
1. The concentration standard has been changed from no more than 70 mg/Nm
(0.03 gr/dscf) to no more than 90 mg/dscm (0.04 gr/dscf).
2. The opacity standard has been changed from less than 10 percent except for 2
minutes in any 1 hour to less than 20 percent and the exemption for 2 minutes
per hour has been removed.
3. The definition of affected facility has been reworded to clarify the applic-
ability of the standard.
Change in the Concentration Standard
The preamble to the proposed standard urged all interested parties to submit
factual data during the comment period to ensure that the standard for asphalt concrete
plants would, upon promulgation, be consistent with the requirements of section 111 of
the Act. A substantial amount of information on emission tests was submitted in resoonse
to this request.
The proposed concentration standard was based on the conclusion that the best systems
of emission reduction, considering cost, are well-designed, well-operated, and well-
maintained baghouses or venturi scrubbers. The emission test data available at the
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time of proposal indicated that such systems could attain an emission level
of 70 mg/Nm3, or 0.031 gr/dscf. After considering comments on the proposed standard
and new emission test data, a thorough evaluation was made of the achievabi1it> of the
proposed standard. As a result of this evaluation, the concentration standard was changed
to 90 mg/dscm, or 0.04 gr/dscf.
Table 3-1 summarizes all of the emission data received after proposal and includes
data for plants equipped with control systems which are considered less efficient than bag-
houses or venturi scrubbers. The four plants included under "low-energy scrubber-equipped"
that had emission levels less than 0.031 gr/dscf were equipped with two or more low-
energy scrubbers in series after the primary control device(s). The information received
for the 25 plants included under "unknown control device-equipped" did not identify the
control equipment used nor the test orocedures followed to collect the data; therefore,
these data could not be used in the evaluation of the achievability of the proposed
standard. Of the test data included under "baghouse- or venturi scrubber-equipped,"
some were considered invalid because incorrect test procedures were followed or because
the control equipment was improperly operated or maintained. The data for the two plants
in the category 0.041 to 0.05 gr/dscf, the data for the plant in the category 0.051 to
0.06 gr/dscf, and the data tor the plant in the category >0.061 gr/dscf were not considered.
acceptable for the following reasons:
1. The baghouses on the two plants having emissions in the range 0.041 to 0.05 gr/
dscf had a fabric with a permeability greater than that considered to be best
demonstrated control technology (considering costs),
2. A torn bag was discovered et the conclusion of the test on the plant having
emissions in the range 0.051 to 0.06 gr/dscf, and
3. Improper test procedures that would have affected the accuracy of the test
results were used at the plant having emissions greater than 0.06 gr/dscf.
Table 3-2 summarizes the acceptable test data that were received during the comment
period and that were taken from plants equipped with either baghouses or venturi scrubbers.
As can be seen, 11 plants equipped with baqhouses and three equipped with venturi scrubbers
had emissions less than 0.031 gr/dscf; however, two baghouse-equipped plants had emissions
between 0.031 and 0.04 gr/dscf. Although a limited amount of information was provided
on these plants, the test procedures used were reported to comply with those of EPA
method 5 and the control equipment was reported to have been properly operated and
maintained.
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Table 3-2. ACCEPTABLE EMISSION TEST DATA SUBMITTED AFTER PROPOSAL
Average outlet
concentration,
gr/dscf
iO.031
0.032 to 0.04
0.041 to 0.05
0.051 to 0.06
>0.061
Total
Number of plants achieving
indicated concentration
Baghouse-equipped
11
2
0
0
0
13
Venturi
scrubber-equipped
3
0
0
0
0
3
Total
14
2
-
-
-
16
In addition to these two plants that had emissions between 0.031 and 0.04 gr/dscf,
one of the four plants EPA tested during the development of the proposed standards had
-werage emissions of slightly greater than 0.031 qr/dscf. This tends to indicate
that the nronosed standard may not be achievable in all cases at all times with a
baghouse or with a venturi scrubber.
Appendix A presents all of the; data submitted during the public comment period.
These data consist of complete or partial stack test reports. This information has been
available for public inspection since its receipt by EPA at the Office of Public Affairs,
401 M Street S.W., Washington, D. C., and the Office of Air Quality Planning and Standards,
Durham, North Carolina. The average test results for facilities 0,Q,R,S,T arid U, as
presented in Appendix A, are summarized in Table 3-2. Facility P is not included in
Table 3-2 because the test data were judged to be inaccurate due to improper test procedures
employed. Table 3-2 also includes final test results for 10 other asphalt plants; only
the final test results were submitted by the commentators offering these results. Nine of
the 12 final test results submitted by the Los Angeles County Air Pollution Control District
were considered to be from well-controlled plants and as such were included in Table 3-2;
the other three plants were controlled with baghouses equipped with fabrics other than
those considered to be required in a best system of emission reduction. A final test
result from another asphalt plant was also included in Table 3-2. This test result was
considered acceptable because telephone conversations with the plant operator indicated
that the plant was tested in conformance with EPA method 5 and the plant was equipped
with the best system of emission reduction.
Some of the major comments received from the industry were: (1) the proposed
concentration standard of 0.031 gr/dscf cannot be attained either consistently or at
all with currently available equipment; (2) the standard should be 0.06 gr/dscf;
(3) the standard should allow higher emissions when heavy fuel oil is burned; (4) the
type of aggregate used by a plant changes and affects the emissions; (5) EPA
12
-------
failed to consider the impact of the standard on mobile plants, continuous-mix plants, and
drum-mixinq plants; and (6) the EPA control cost estimates are too low. Detailed responses
to these comments and others are qiven in Appendix E. When considered as a whole, alonq
with the emission data submitted after proposal (Table 3-2), the corrments justify revisinq
the standard. The revision is merely a chanqe in EPA's judqment about what emission limit is
achievable using the best systems of emission reduction. The revision is in no way a change
in what EPA considers to be the best systems of emission reduction which, takinq into account
the cost of achievinq such reduction, have been adequately demonstrated; these are still
considered to be well-designed, -operated, and -maintained baghouses or venturi
scrubbers.
Change in the Opacity Standard
The opacity standard covering asphalt concrete plants has been revised to limit
visible emissions to less than 20 percent opacity. This revision reflects receipt
of new data, revaluation of the data collected before proposal of the regulation,
and the separate promulgation of regulations which exempt from opacity standards
any emissions generated during periods of startup, shutdown, or malfunction (see
Federal Register of October 15, 1973, 38 FR 28564).
In response to comments received on the proposed opacity standard, additional data
were obtained on visible emissions from three well-controlled plants. Two of these three
plants were equipped with baqhouses, and the third plant was equipped with a venturi
scrubber. The opacity of the emissions from these three plants was determined visually
by one or two qualified observers. The observations were made for a total of
15 hours at the three plants. No visible emissions were observed from the control
equipment on any of the plants. In addition, one plant showed no visible fugitive
emissions. Two plants, however, had short periods of visible fugitive emissions that
were typically at 10 percent opacity, but in one case up to 45 percent for 1 minute.
These fugitive emissions were observed at various points within the two plants. No
emission points were common to both plants. For example, while one plant had visible
fugitive emissions from the screening system, the other plant did not; i.e., the other
plant adequately controlled emissions from that system. Inspection of the two plants
having visible fugitive emissions, together with the fact that one plant had no visible
fugitive emissions, shows that all of the fugitive emissions observed could have been
prevented by proper design, operation, and maintenance of the asphalt plant and its
control equipment.
The proposed 2-minute time exemption was not based on observed increases in opacity,
but was an arbitrary selection of time intended to prevent uncontrollable short-term
emissions from constituting violations. The exemptions now provided by the promulgated
startup-shutdown-malfunction regulations cover circumstances specific to the source.
The data show that the promulgated opacity limit of less than 20 percent allows minor
variations and that there are no operating circumstances or process variables that
13
-------
would require exemptions in addition to those provided by the startup-shutdown-
malfunction regulations.
In the judgment of the Administrator, these data show that the promulgated opacity
limit is sufficiently close to observed opacity to ensure proper operation and aain-
tenance of the process and collection equipment, and that the limit, coupled with the
exemptions for startups, shutdowns, or malfunctions, constitutes an opacity standard
that is not more restrictive thar the concentration standard. A general discussion
of the intent of opacity standards and the issues involved in setting them is included
in Chapter 2 of this volume.
Applicability of the Standard
Section 60.90, applicability and designation of affected facility, is changed
from that proposed in order to clarify how and when the standards apply to asphalt
concrete plants. The proposed regulation was interpreted by some commentators as
requiring existing plants to meet the standards of performance for new sources when
equipment was normally replaced or modernized. The proposed regulation specified
certain equipment, e.g., transfer and storage systems, as affected facilities,
and, because of regulatory language, this could have been interpreted to mean that
a new conveyor system installed to replace a worn-out conveyor system on an existing
plant was a new source as defined in section m(a){2) of the Act. The promulgated
regulation specifies the asphalt concrete plant as the affected facility in order to
avoid this unwanted interpretation. An existing asphalt concrete plant is subject
to the promulgated new source performance standards only if a physical change to
the plant or change in the method of operating the plant causes an increase in the
amount of air pollutants emitted. Routine maintenance, repair, and replacement; relocation
of a portable plant; change of aqqrectate; and transfer of ownership are not considered
modifications which would require an existing plant to comply with the standard.
Revisions to thp Cost Fstimates
Since the standard was proposed, the cost estimates have been reexamined and
additional adjustments have been made. Many of these adjustments were prompted by
comments made during the public comment period by the National Asphalt Pavement
Association (NAPA) and others. In summary, the capital costs for baghouses have been
revised to include: (1) a dust recycling system, (2) an inflation adjustment to 1973
dollars, (3) a change in the value of recycled fines from $9/ton to $3.40/ton, and
(4) an upward adjustment in the disposal cost for dust collected from the scrubbing
systems. These changes increased the estimated cost of the control equipment by
approximately 20 percent. The revised estimates appear in Appendix B and represent
baghouses with a 6-to-l air-to-cloth ratio and venturi scrubbers with a pressure drop
of 20 inches of water.
When NAPA submitted their public comments on the proposed standard, they also
submitted cost estimates from several companies to illustrate that the industry is
14
-------
experiencing greater cost in the marketplace than had been estimated by EPA. Figure 3-1
demonstrates how EPA's adjusted cost estimates for fabric filters compare to the cost
estimates submitted by NAPA. It should be noted that all reported values are below
EPA's adjusted costs except two. The line representing EPA's original cost estimates
approximately bisects the plot of numbers submitted by NAPA. Those commenting did
not submit adequate information to conduct the same analysis for wet scrubbers.
Minor Revisions to the Regulation
The comments pointed out some minor errors and oversights in the information
presented in Volumes 1 and 2 of this document. Appropriate revisions were made and are
presented in Apoendices F and G of this volume.
Minor rewording and reorganization changes that do not affect the opacity or concen-
tration standards are included in the final regulations. To avoid repetition, the
provision covering emission-records requirements, the definition of particulate matter,
and the provision prohibiting the use of dilution air were removed from individual regu-
lations and incorporated in the General Provisions which are applicable to all sources.
The paragraph concerning dilution air has also been revised to clarify misunderstandings
evidenced by comments received during the public comment period. Other clarifications
include: (1) deletion of "normal" from the particulate concentration standard to avoid
confusion between "normal" and "standard," (2) substitution of a more specific statement
of conditions under which performance tests will be conducted, and (3) deletion of a
confusing and repetitive statement concerning the date upon which the standard becomes
applicable. Several other changes, made to clarify EPA's intent, were incorporated in
the test methods and procedures. These include a revision of the sampling time specified
for performance testing, and inclusion of an exception to the promulgated procedures to
make clear EPA's recognition that process variables may interfere with specified sampling
conditions. Because these changes in the regulations apply to nearly all of the sources
for which standards are promulgated, the rationale for changes is presented in Chapter 2,
General Corsiderations, of this volume.
15
-------
106,
o
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1.5
105
9
cc
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104
ADJUSTED EPA
ORIGINAL EPA
I
104 1.5 2 2.5 3 4 56789 Ifl5
AIR FLOW, acfm
Figure 3-1. Cost comparison between EPA costs and NAPA exhibit costs.
-------
CHAPTER 4. PETROLEUM REFINERIES
SUMMARY OF PROMULGATED STANDARDS
The promulgated standards of performance for petroleum refineries limit emissions of
sulfur dioxide from fuel gas combustion systems and limit emissions of particulate matter
and carbon monoxide from fluid catalytic cracking unit catalyst regenerators.
Fuel Gas Combustion Systems
The promulgated standard limits emissions of sulfur dioxide to the atmosphere from
the combustion of fuel gas containing hydrogen sulfide by specifying that the fuel gas
combusted shall contain no more than 230 mg/dscm (0.10 gr/dscf) hydrogen sulfide. A
fuel gas combustion system is defined as any equipment such as, but not limited to,
process heaters, boilers, and flares used to burn gases. However, the combustion of
process upset gases in flares is exempt from the standard.
Although the standard limits sulfur dioxide emissions by specifying a limit on the
hydrogen sulfide content of fuel gas combusted, compliance with the standard can be
achieved by removing sulfur dioxide from the combustion effluent gases instead of removing
hydrogen sulfide from the fuel gas before combustion. In these cases, however, it must
be shown to the Administrator's satisfaction that treatment of the combustion gases is
as effective in preventing emissions of sulfur dioxide as is removal of hydrogen sulfide
from the fuel gas.
Fuel gas is defined as any gas produced by a process unit within a petroleum refinery
and combusted as fuel. In addition, any gaseous mixture of natural gas and fuel gas is
also considered fuel gas. However, fluid coking unit coke-burner fuel gases and fluid
catalytic cracking unit catalyst regenerator fuel gases are exempt from the standard.
Fluid Catalytic Cracking Unit Catalyst Regenerators
The promulgated standards limit the rate of emission of particulate matter to the
atmosphere from fluid catalytic cracking unit catalyst regenerators to no more than
1 kilogram per 1,000 kilograms (1 kg/1,000 kg) of coke burn-off in the catalyst
regenerator. If, however, a carbon monoxide boiler is employed to burn the carbon
monoxide contained in the catalyst regenerator exhaust gases to carbon dioxide, the rate
of emission of particulate matter to the atmosphere may increase above this level when
liquid or solid auxiliary fuels are burned in the boiler. In these cases, the rate of
17
-------
emission of participate matter to the atmosphere permitted by the new source performance
standard must be calculated.
To calculate the rate of emission of particulate matter permitted by the standard
when liquid or solid auxiliary fuels are burned in a carbon monoxide boiler, the heat
input to the boiler that is attributable to these solid or liquid auxiliary fuels must
first be determined in millions of calories per hour. This heat input is multiplied by
an incremental emission factor of 0.18 gram per million calories, and then divided by
the coke burn-off rate in the catalyst regenerator expressed in kilograms per hour.
The numerical result is the increase in the rate of emission of particulate matter to the
atmosphere permitted by the new source performance standard in kilograms of particulate
matter per thousand kilograms of coke burn-off in the catalyst regenerator. This, added
to the rate of emission of particulate matter permitted when no liquid or solid auxiliary
fuels are burned in the carbon monoxide boiler (1.0 kilogram/1,000 kilograms of coke burn-
off in the catalyst regenerator), determines the total rate of emission of particulate
matter to the atmosphere from the catalyst regenerator that is permitted by the standard
when solid or liquid auxiliary fuels are burned.
The promulgated standards also limit the opacity and carbon monoxide content of the
effluent gases released to the atmosphere from the fluid catalytic cracking unit catalyst
regenerator. The opacity of the effluent gases must be less than 30 percent, except for
3 minutes in any 1 hour, and the carbon monoxide concentration in the gases discharged
to the atmosphere must be 500 ppm (0.050 percent by volume) or less. The 3-minute
period in any 1 hour during which the opacity of the gases discharged to the atmosphere
may be 30 percent or more is to permit "blowing" of the boiler tubes in the carbon
monoxide boiler to remove soot.
Some minor rewording and reorganization that do not change the standards are also
included in the promulgated regulations. To avoid repetition, the provision covering
emission-records requirements, the definition of particulate matter, and the provision
prohibiting the use of dilution air were removed from individual regulations and
incorporated in the General Provisions, which are applicable to all sources. The para-
graph concerning dilution air has also been revised to clarify misunderstandings
evidenced by comments received during the public comment period. Other clarifications
include: (1) deletion of "normal" from the particulate concentration standard to
avoid confusion between "normal" and "standard," (2) substitution of a more specific
statement of conditions under which performance tests will be conducted, and (3) deletion
of a confusing and repetitive statement concerning the date upon which the standard
becomes applicable. Several other changes, made to clarify EPA's intent, were incorpora-
ted in the test methods and procedures. These include a revision of the sampling time
specified for performance testing, and inclusion of an exception to the promulgated pro-
cedures to make clear EPA's recognition that process variables may interfere with
18
-------
specified sampling conditions. Because these changes in the regulations apply to nearly
all of the sources for which standards are promulgated, the rationale for changes is
presented in Chapter 2, General Considerations, of this volume.
DISCUSSION OF PROMULGATED REGULATION
Review and evaluation of the comments received resulted in two changes to the
standard proposed for fuel gas combustion devices:
(1) The combustion of process upset gas in flare systems is exempt from the promul-
gated standard.
(2) Hydrogen sulfide in fuel gases combusted in any number of facilities may be
monitored at one point if the fuel gases combusted in each facility are of the
same composition.
Review and evaluation of the comments received during the public comment period
resulted in three major changes to the proposed standards for fluid catalytic cracking
unit catalyst regenerators:
(1) Under the promulgated standards, the opacity of the gases discharged to
the atmosphere must be less than 30 percent, except for 3 minutes in any 1 hour. The
proposed standard would have limited the opacity of the effluent gases released to the
atmosphere to less than 20 percent, except for 3 minutes in any 1 hour.
(2) The promulgated standards limit the rate of emission of particulate matter to
the atmosphere from the catalyst regenerator in kiloqrams of particulate matter per
1,000 kilograms of coke burn-off in the catalyst regenerator. The proposed standard
would have limited the concentration of particulate matter in the gases discharged to the
atmosphere.
(3) The stringency of the standard that limits the rate of emission of particulate
matter to the atmosphere has been relaxed by about 25 percent. EPA's original intent was
to limit the rate of emission of particulate matter to the atmosphere from fluid catalytic
cracking unit catalyst regenerators to about 0.8 kilogram of particulate matter per
1,000 kilograms of coke burn-off in the catalyst regenerator. The promulgated standard,
however, limits emissions to 1.0 kilogram per 1,000 kilograms of coke burn-off.
Fuel Gas Combustion Systems
The two changes made to the proposed standard for fuel gas combustion systems do not
represent any change in EPA's original intent. It was evident from the comments received,
however, that the intent of the regulations was not clear. Therefore, explicit provisions
were incorporated into the promulgated standard to exempt the flaring of process upset
gases and to permit monitoring at one location of the hydrogen sulfide content of fuel
gas combusted in any number of combustion devices.
Flare Systems
Although petroleum refinery flare systems are frequently used to routinely dispose
of various low-value process gases produced within a refinery, they are installed
19
-------
primarily to provide a means for safely disposing of large volumes of process upset gases
suddenly and unexpectedly released from various process units. Because the frequency
of process upsets and the volumes of gases which must be disposed of are highly unpre-
dictable, it is not feasible to design or operate a gas treating facility that would
prevent sulfur dioxide emissions from flare systems in these situations. A facility
designed to remove hydrogen sulfide from all process upset gases prior to combustion
would have to be designed to handle the immediate release of gases from all process units
if each unit experienced the worst possible upset or malfunction at the same time. The
costs of such a large gas treatment facility would impose a severe and unreasonable
economic burden upon a refinery. Therefore, as noted on page 25 in Volume 1 of this
document, the intent is that "The proposed standard does not apply to extraordinary
situations, such as emergency gas releases..."
Monitoring of Hydrogen Sulfide
Within large petroleum refineries, groups of process heaters or boilers generally
have a common source of fuel gas and each process heater and boiler burns fuel gas of the
same composition. It was EPA's original intent to permit monitoring of fuel-gas hydrogen
sulfide at one location for combustion sources having a common source of fuel gas.
However, the proposed regulations did not specifically state that this was permissible,
and, as many commentators pointed out, the regulations could be construed to require
monitors on each process heater or boiler. Consequently, provisions are included in
the promulgated regulations specifically stating that the use of common-source fuel gas
monitors is acceptable.
Exemption of Small Refineries
Many commentators suggested that small petroleum refineries be exempt from the
standard for fuel gas combustion systems since compliance with the standard would impose
a severe economic penalty on small refineries. It was suggested that refineries of less
than 40,000 bbl/day capacity be exempt and that refineries be exempt where the amount of
hydrogen sulfide in the fuel qas before combustion was less than 10 tons per day.
Background information considered in proposing the sulfur dioxide standard on fuel
gas combustion devices (Volume 1 of this document) included a review of the costs
associated with converting hydrogen sulfide to elemental sulfur at small refineries.
Based on this review, EPA concluded that the proposed standard would have little or no
adverse economic impact on petroleum refineries. In light of the comments, received, EPA
reexamined this point with particular attention to the small refiner. Because this
analysis indicates that refinery growth for both small and large refineries will not be
precluded by the proposed new source performance standards for fuel gas combustion, the
standard is promulgated with no exenption for small petroleum refineries.
20
-------
EPA's analysis is presented in Appendix C. The domestic petroleum industry is
extremely complex and highly sophisticated. Thus, any analysis of the petroleum refining
industry will of necessity be based on a number of simplifying assumptions. Although the
assumptions in the economic impact statement appear reasonable, the statement should not
be viewed as definitively identifying specific costs; rather it identifies a range of
costs and approximate impact points. The analysis examines more than the economic impact
of the standard for fuel gas combustion systems. It also examines the combined economic
impact of this standard for fuel gas combustion systems, the standards for fluid
catalytic cracking units, the water quality effluent guidelines being developed for petro-
leum refineries, and EPA's regulations requiring the reduction of lead in gasoline.
Essentially, the economic impact of "pollution control" is reviewed in light of the petro-
leum import license-fee program being administered by the Oil and Gas Office of the Depart-
ment of the Interior (38 FR 9645 and 38 FR 16195).
This program is designed to encourage expansion and construction of U. S. petroleum
refining capacity and expansion of U. S. crude oil production by imposing a fee or tariff
on imported petroleum products and crude oil. Although this program is currently being
phased into practice with the full impact not to be felt until mid-1975, the central
feature of the program is to impose a fee of 214 per barrel above world price on imported
crude oil and a fee of 634 per barrel above world price on imported petroleum products
such as gasoline, fuel oils, and "unfinished" or intermediate petroleum products.
Under the conditions currently existing in the United States, which are forecast to
continue throughout the remainder of this decade and most of the next decade, and with
domestic demand for crude oil and petroleum products far outstripping domestic supply and
petroleum refining capacity, the import license-fee program will encourage domestic prices
of crude oil and petroleum products to increase to world levels plus the fee or tariff.
Thus, an incentive of 424 per barrel (634 per barrel minus 21
-------
Table 4-1 summarizes the average costs associated with the new source performance
standards on fuel gas combustion devices and fluid catalytic cracking units for
petroleum refineries of various processing capacities. The average costs associated
with the envisioned water quality effluent guidelines and the EPA regulations requiring
the reduction of lead in gasoline are also summarized.
As shown in Table 4-1, the average costs associated with new source performance
standards range from 10<£ per barrel for a 5,000-barrel-per-day refinery to 2<£ per barrel
for a 100,000-barrel-per-day refinery. The average costs associated with the envisioned
water quality effluent guidelines and the EPA regulations requiring a reduction of the
lead in gasoline range from 17<£ and 12
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catalytic cracking units has been revised to limit emissions to less than 30 percent
opacity, except for 3 minutes per hour. This revision is based on new data, revaluation
of the data collected before proposal of the regulation, and the separate promulgation of
regulations exempting from opacity standards any emissiois generated during periods of
startup, shutdown, or malfunction (see Federal Register of October 15, 1973, 38 FR 28564).
In response to comments received, additional data were obtained on visible emissions
from four well-controlled plants. All four of these plants were eguipped with electro-
static precipitators. Opacity of the emissions from the fluid catalytic cracking units
was determined by one or two qualified observers; observations were made for a total of
18-1/2 hours at the four plants.
Observations were made for 5-1/2 hours at one unit that had emissions below the
standard (1 kg/1,000 kg of coke burn-off in the catalyst regenerator). Two sootblows of
3 minutes each at 100 percent opacity were observed; also observed were many s.hort
periods of visible emissions that were not sootblows, ranging from 15 seconds to several
minutes, at 20 percent opacity or greater. These short periods totaled 30 minutes.
Operating and maintenance procedures were checked and discussed with the operator; no
normal process variations were found that would cause visible emissions in excess of the
promulgated standard at a well-controlled unit.
Observations at the other three units resulted in similar data. Except at one plant
that blows soot for 1 hour at night, no sootblows were observed to exceed 30 percent for
longer than 3 minutes. This refinery is in the orocess of changing to a system that
would take only 3 minutes per hour.
These data indicate the need for an opacity limit higher than the proposed limit of
20 percent. The data support raising the limit to less than 30 percent and retaining the
3-minute exemption per hour to account for sootblowinq. The opacity standard is therefore
promulgated at less than 30 percent opacity, except for 3 minutes in any 1 hour.
In the judgment of the Administrator, these data show that the promulgated opacity
limit of less than 30 percent opacity except for 3 minutes in any 1 hour is sufficiently
close to observed opacity to ensure proper operation anc maintenance of the process
and collection equipment, and that the limit, coupled with the exemptions for startups,
shutdowns,and malfunctions, constitutes an opacity stancard that is not more restrictive
than the process weight standard. A general discussion of the intent of opacity
standards and the issues involved in setting them is included in Chapter ? of this volume.
Type of Standard
Several commentators pointed out that the volume of gases discharged to the atmos-
phere from fluid catalytic cracking unit catalyst regenerators can vary significantly,
24
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depending upon the overall system used to control emissions of participate matter and
carbon monoxide. Consequently, the degree of control required to meet the proposed
concentration standard for particulate matter depends upon the overall emission control
system employed. For example, two identical catalyst regenerators might limit the concen-
tration of particulate matter in the gases discharged to the atmosphere to the same level,
but different emission control systems might be employed and one catalyst regenerator
would then be permitted by the proposed standard to emit significantly more particulate
matter into the atmosphere than would the other. It was concluded, therefore, that an
emission standard should be developed which would require the same degree of control of
emissions from catalyst regenerators, irrespective of the emission control system
employed.
The various emission control systems which can be used to control emissions of parti-
culate matter and carbon monoxide from fluid catalytic cracking unit catalyst regenerators
are shown in Figure 4-1. Each of these systems is currently being used within the petroleum
refining industry.
System 1 controls emissions of carbon monoxide by complete combustion of the coke
from the catalyst surface within the catalyst regenerator. This is a recent development
in the technology of fluid catalytic cracking and most fluid catalytic cracking unit
catalyst regenerators remove the coke from the catalyst surface under conditions, which
result in incomplete combustion of the coke. The exhaust gases from the regenerator,
containing little or no carbon monoxide, are then cooled from 1,300-1,500°F to 500-600°F,
passed through an electrostatic precipitator to remove particulate matter, and discharged
to the atmosphere.
In control system 2, the effluent gases from the regenerator contain from 10 to 12
percent carbon monoxide and are incinerated in a carbon monoxide boiler to generate
steam. Although the effluent gases from the regenerator are at a high temperature (1,000
to 1,200°F), additional air and auxiliary fuel must be provided to ensure the complete
combustion of carbon monoxide to carbon dioxide. Following the carbon monoxide boiler,
the gases pass through an electrostatic precipitator and are discharged to the atmosphere.
Control system 3 is the same as control system 2, except that the precipitator is
located ahead of the carbon monoxide boiler. The effluent gases from the regenerator are
cooled from 1,000-1,200°F to 500-600°F, passed through an electrostatic precipitator,
combusted in the carbon monoxide boiler, and discharged to the atmosphere. Because the
temperature of the gases entering the carbon monoxide boiler is in the range of 500 to
600°F rather than 1,000 to 1,200°F as in control system 2, more auxiliary fuel and air
must be provided to ensure combustion of carDon monoxide to carbon dioxide.
25
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CONTROL SYSTEM 1
(1300-
1500°F)
CATALYST
REGENERATOR
CATALYST
TO REACTOR
CATALYST
FROM REACTOR
-AIR
Figure 4-1. Fluid catalytic cracking unit catalyst regenerator
emission control systems.
26
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If "minimum" carbon monoxide boilers are utilized in control systems 2 and 3, the
ratio of the volumes of gases discharged to the atmosphere from control systems 1, 2, and
3 is approximately 1.0:1.05:1.30. This variation in the gas volumes is due solely to the
air and auxiliary fuel which must be provided to the carbon monoxide boilers in control
systems 2 and 3 to ensure complete combustion of carbon monoxide.
"Minimum" carbon monoxide boilers, as the term implies, use only the minimum amounts
of air and auxiliary fuel necessary to ensure combustion of carbon monoxide. In control
system 2, minimum carbon monoxide boilers are normally employed because boilers using
more than the minimum amounts increase the volume of gases to be treated in the electro-
static precipitators; this requires a larger precipitator and increases costs. In
control system 3, however, there are no economic penalties associated with increasing
the volume of gases by burning more than the minimum amounts of air and auxiliary fuel
in the boiler and, in many cases, minimum carbon monoxide boilers are not used in this
type of control system. This was confirmed in a lirited survey, made by EPA, which shows
that the ratio of the volumes of gases discharged to the atmosphere from control systems
1, 2, and 3 are frequently about 1.0:1.05:1.50 rather than 1.0:1.05:1.30. Furthermore,
contacts with the major vendors that supply carbon monoxide boilers to the petroleum
refining industry indicated that there were no technical limitations to prevent this
ratio for control system 3 from increasing significantly above 1.50.
As a result, it was concluded by EPA that the standard limiting emissions of parti-
culate matter from fluid catalytic cracking unit catalyst regenerators should be revised
to be independent of the volume of gases discharged to the atmosphere. Frequently,
a concentration emission standard can be corrected to a reference basis to compensate for
excess or dilution air introduced into effluent gases. For example, the new source per-
formance standard promulgated for municipal incinerators references all determinations of
effluent gas volumes to 12 percent carbon dioxide. In the case of fluid catalytic
cracking unit catalyst regenerators, however, a carbon dioxide reference basis is not
adequate because the variation in volume of the effluent gases is not due to excess or
dilution air, but is due to combustion of auxiliary fuel in the carbon monoxide boiler.
Other methods of adjusting the volume of gases discharged to the atmosphere to a common
reference basis were also found to be inadequate. Consequently, the concept of writing
an emission standard limiting the concentration of particulate matter in the gases dis-
charged to the atmosphere was abandoned.
A review of various means of expressing an emission standard to limit particulate
emissions from fluid catalytic cracking unit catalyst regenerators was undertaken by EPA.
The major goal was to develop an emission standard that required the same degree of control
of emissions from catalyst regenerators of the same size or capacity. Various options
considered were a standard requiring a certain control efficiency, a process weight
standard, or a standard in terms of emissions per unit of size or capacity.
27
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The data needed to develop an emission standard requiring a certain control
efficiency were not available. The data to develop a process weight standard were
available. However, the determination of the circulation rate between the fluid catalytic
cracking unit reactor and the catalyst regenerator requires either a sophisticated
laboratory analysis to determine the amount of coke on both the fresh catalyst from the
catalyst regenerator and the deactivated catalyst froir the reactor, or the development
of a material and energy balance around the catalyst regenerator. In either case, the
determination of the catalyst circulation rate is difficult.
The data for developing an emission standard to relate emissions to size or capacity
in terms of coke burn-off rate in the catalyst regenerator were also available. Although
the determination of coke burn-off rate does require some calculations, they are not
complex. Consequently, an emission standard relating particulate emissions to coke burn-
off rate in the catalyst regenerator has oeen developed and promulgated. Under the pro-
mulgated standard, the degree of control efficiency required is independent of the volume
of gases discharged to the atmosphere, and emissions are limited to the same level for
identical catalyst regenerators.
Level of the Emission Standard
A number of comments were received concerning the level of the proposed emission
standard limiting the concentration of particulate matter in the gases discharged to the
atmosphere from fluid catalytic cracking unit catalyst regenerators. Before discussing
these comments, however, it is pertinent to review some aspects of the operation of fluid
catalytic cracking units that were not discussed in Volume 1 of this document.
Quite literally, fluid catalytic cracking units are the heart of most moderate- and
high-conversion refineries. They constitute one of the major processes for converting
heavy, high molecular weight fractions of crude oil which are of low value into lighter,
more valuable products such as gasoline. As a result, fluid catalytic cracking units
operate continuously, with run lengths between major shutdowns or turnarounds in the
range of 1 to 2 years. Turnarounds are major projects and may require 3 to 6 weeks;
during turnarounds the fluid catalytic cracking unit is completely overhauled and
renovated with repair crews working 24 hours per day, 7 days a week, until the unit is
back into operation.
Essentially, the particulate matter emitted to the atmosphere from the catalyst
regenerator in a fluid catalytic cracking unit is catalyst dust which is entrained in
the effluent gases from the regenerator. To minimize this loss of catalyst, there are
two stages of internal cyclones incorporated in the regenerator vessel to remove catalyst
from the effluent gases and to recycle it to the fluidized bed of catalyst maintained in
28
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the regenerator. These cyclones are shown in Figures 4 and 5 on page 18 of Volume 1 of
this document. Because these internal cyclones operate under severe conditions, their
collection efficiencies deteriorate with time and the concentrations of catalyst dust
in the gases discharged from catalyst regenerators increase. If an electrostatic preci-
pitator is employed to control emissions, the load on this precipitator increases as a
result of this deterioration.
Precipitators function solely as air pollution control devices. The catalyst
dust recovered by precipitators is normally not returned to the catalyst regenerator since
it would most likely be reentrained in the effluent gases and would merely increase the
load on the precipitator. Thus, even with a precipitator, the loss of catalyst from the
catalyst regenerator increases as the collection efficiency of the internal cyclones
deteriorates. Normally, after 1 to 2 years of continuous operation, the loss of catalyst
makes continued operation of the fluid catalytic cracking unit uneconomical and the unit
is shut down.
Consequently, fluid catalytic cracking unit catalyst regenerators are one of the few
types of process equipment which exhibit,'with time, control equipment deterioration that
cannot be prevented by routine maintenance or proper operating practices. The repair or-
replacement of the internal cyclones within the catalyst regenerator can only be performed
when the fluid catalytic unit is shut down for an equipment turnaround.
Most of the comments received on the proposed emission standard concerned equipment
deterioration. Although most of the commentators felt that the emission standard could be
achieved on a newly renovated catalyst regenerator following a turnaround of the fluid
catalytic cracking unit, they did not feel that the standard could be achieved over the
full U to 2-year run of a fluid catalytic cracking unit. Thus, most of the commentators
recommended that the emission standard be increased from 0.022 gr/dscf to 0.044 gr/dscf.
The emission data presented in Volume 1 of this document (Figure 6, page 20) in
support of the proposed standard are presented in Figure 4-2 for the promulgated standard.
The proposed standard of 0.022 gr/dscf is equivalent to about 0.8 kilogram per 1,000
kilograms of coke burn-off, and 0.044 gr/dscf is equivalent to about 1.6 kilograms per
1,000 kilograms of coke burn-off.
The non-EPA data points presented for facilities A and E are based on emission data
supplied by the companies operating these facilities. The data for facility A that were
presented in Volume 1 of this document represented results of emission tests carried out
about every 2 weeks by company personnel during the first 7 months of operation of the
catalyst regenerator following a turnaround of the fluid catalytic cracking unit. The data
for facility E presented both in Volume 1 of this document and in Figure 4-2 represent the
results of emission tests carried out about every 2 months by company personnel during 17
months of operation of the catalyst regenerator between turnarounds of the fluid catalytic
crackina unit.
29
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Following proposal of the standard, EPA requested and was supplied additional
emission data by the company operating facility A. The non-EPA data point presented in
Figure 4-2 for facility A now represents emission data covering 20 months of operation of
the catalyst regenerator between turnarounds of the fluid catalytic cracking unit. As
with the emission data initially supplied by the company operating this facility, the
additional emission data consisted of the results of emission tests carried out about
every 2 weeks by company personnel.
Additional emission data were also obtained on another fluid catalytic cracking
unit catalyst regenerator (see the data point in Figure 4-2 for facility L). This data
point is based on the results of an emission test carried out on a fluid catalytic
cracking unit of about 55,000 bbl/day capacity, which was equipped with a carbon monoxide
boiler followed by an electrostatic precipitator. However, at the time of the test, the
fluid catalytic cracking unit had been onstream only about four months following a turn-
around. Although this is not a new fluid catalytic cracking unit, a large electrostatic
precipitator had been installed to control particulate emissions from the catalyst
regenerator since EPA's original survey of the industry during the development of the
proposed emission standard.
Although there was some consideration given during development of the proposed
standard to the effect of internal-cyclone deterioration on particulate emissions from
the catalyst regenerators, it was felt that this effect was relatively minor. The only
data available to EPA were the data on facility E, consisting of nine data points which
are so scattered that no trend in emissions over time is apparent.
Since the development of the proposed emission standard, however, the American
Petroleum Institute undertook a survey of emissions from fluid catalytic cracking units.
Although the information gathered by this survey is not adequate for the development
of a new source performance standard, the survey data do indicate that particulate
emissions from catalyst regenerators generally increase by about 35 percent during the
run (between turnarounds) of a fluid catalytic cracking unit. Although there is a great
deal of scatter in the data supplied by the company operating facility A, a least-squares
regression analysis of these data also indicates a general increase in emissions over
time (Figure 4-3).
As a result, it appears that the deterioration of internal cyclones has an adverse
effect on particulate emissions released to the atmosphere from catalyst regenerators.
Consequently, EPA concluded that the level of the proposed emission standard should be
revised for promulgation to allow for the deterioration of the process equipment which
would cause emissions to increase. The goal was then to develop an emission standard
consistent with the performance of the best system of emission control on a catalyst
regenerator over the normal run of a fluid catalytic cracking unit between turnarounds.
31
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Figure 4-3. Particulatt emission:; versus time for facility A,
32
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As discussed in Volume 1 of this document, collection efficiency for particulate
emissions is closely related to the size of the plate area of the electrostatic precipi-
tator. Facilities B and C (Figure 4-2) respectively employed precipitators with 175 and 190
square feet of plate area per 1,000 acfm of gases treated, and emissions were in the
range of 1.2 to 1.4 kilograms per 1,000 kilograms of coke burn-off. Facility E employed
a precipitator with 225 square feet of plate area per 1,000 acfm of gases treated, and
emissions were in the range of 0.5 to 0.9 kilogram per 1,000 kilograms of coke burn-off.
Facility A employed a precipitator with 250 square feet of plate area per 1,000 acfm of
gases treated, and emissions were in the range of 0.4 to 0.8 kilogram per 1,000 kilograms
of coke burn-off. Facility L employed a precipitator with 350 square feet of plate area
per 1,000 acfm of gases treated, and emissions were in the range of 0.1 to 0.2 kilogram
per 1,000 kilograms of coke burn-off. Similar data are not available on facilities F
through K.
Because these data points are not necessarily on the same basis, they cannot be used
to develop a quantitative relationship between the ratio of precipitator plate area to
the volume of gases treated or to particulate emissions from catalyst regenerators.
However, they do qualitatively confirm the basic design criteria; i.e., that as precipi-
tator plate area increases, particulate collection efficiency increases and emissions
decrease.
EPA's data shown in Figure 4-2 for facility A were obtained after the catalyst
regenerators had been onstream about 6 and 8 months, respectively, following a turnaround
of the fluid catalytic cracking unit. The data for facility L were obtained after the
catalyst regenerator had been onstream about 4 months following a turnaround. The
data supplied by the companies operating facilities A and E, however, were obtained over
the full run of the fluid catalytic cracking unit. In addition, these two companies
used the same test method to determine particulate emissions; therefore, the company-
supplied data on these two facilities can be assumed to be on the same basis.
The EPA data and the company data on facilities A and E are not on the same basis,
however, since the emission testing methods used by EPA and these two companies differ
in many respects. On the other hand, it appears from Figure 4-2 that the company data
and the EPA data are somewhat comparable because the EPA data for facility A are in the
same general range as the company data for facility A, Therefore, the EPA data indicate
that an emission standard in the range of 1.0 kilogram per 1,000 kilograms of coke burn-
off in the catalyst regenerator would appear to be consistent with the performance
of the best system of emission control, and the company data indicate that this standard
would not significantly reduce the length of a normal run for a fluid catalytic cracking
unit.
33
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Another approach to establishing a level for the promulgated standard is to statisti-
cally analyze the emission data supplied by the company operating facility A. The mean
and standard deviation of these data for the full 20-month run are 0.518 and 0.125
kilogram per 1,000 kilograms of coke burn-off in the catalyst regenerator, respectively.
Averaging the EPA data on facility A yields a value of 0.646 kilogram per 1,000 kilograms
of coke burn-off. The assumption that the data supplied by the company operating
facility A are somewhat comparable to EPA's data leads to the additional assumption that
the variance and standard deviation of the company data provide an estimate of the
variance and standard deviation which might have been observed if EPA had tested
facility A over the full 20 months between turnarounds.
Using these assumptions, an estimate can be made of what the level of an emission
standard should be to ensure that the standard does not significantly shorten the
length of a normal run for a fluid catalytic cracking unit, while also ensuring a level
of control consistent with the performance of facility A. If the value of one standard
deviation is added to the average of the EPA data for facility A, a value; of 0.771
kilogram per 1,000 kilograms of coke burn-off is yielded. Statistically, this implies
that if facility A had been tested by EPA over the full 20 months between turnarounds,
about 16 percent of the emission data would exceed 0.771 kilogram per 1,000 kilograms
of coke burn-off.
If the value of two or three standard deviations is added to the average of the
EPA data for facility A, values of 0.896 or 1.021 kilogram per 1,000 kilograms of coke
burn-off are yielded. Statistically, this implies that if facility A had been tested by
EPA over the full 20 months between turnarounds, about 2.5 percent or 0.15 percent of
the emission data would exceed 0.896 or 1.021 kilograms per 1,000 kilograms of coke
burn-off.
While the assumptions necessary to support this type of a statistical analysis are
subject to question, the exercise does tend to indicate that an emission standard of
1.0 kilogram per 1,000 kilograms of coke burn-off is consistent with the performance of
a well-controlled catalyst regenerator over the normal run length of a fluid catalytic
cracking unit.
As a result, a standard is promulgated limiting the rate of emission of particulate
matter to the atmosphere from fluid catalytic cracking unit catalyst regenerators to no
more than 1.0 kilogram per 1,000 kilograms of coke burn-off in the catalyst regenerator.
Exemption of Small Sources
A number of comments were received requesting that small fluid catalytic cracking
unit catalyst regenerators be exempted from the standards due to the economic impact that
34
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compliance would impose on small refineries.
Background information considered in proposing the standards for fluid catalytic
cracking unit catalyst regenerators included the economic impact of the proposed
standards. Essentially, EPA's analysis indicated that the proposed standards would have
little or no economic impact on either small (20,000 bbl/day) or large (65,000 bbl/day)
fluid catalytic cracking units. However, in light of the comments received, the
economic impact of the standards was reexamined.
This analysis of the economic impact of the promulgated standards on fluid catalytic
cracking unit catalyst regenerators also indicates that the standards should impose no
barriers to growth for small petroleum refineries. Consequently, the promulgated
standards apply equally to both small and large fluid catalytic cracking unit catalyst
regenerators.
The EPA analysis is included in Appendix C. The economic impact of only the parti-
culate emission standard is examined in this analysis. If the net impact of the carbon
monoxide standard and the particulate matter standard is considered, the cost savings
generated from steam production in the carbon monoxide boiler more than offset the costs
of both the carbon monoxide boiler and the electrostatic precipitator. Although not
specifically addressed in Volume 1, this is also the case when in situ combustion of the
carbon monoxide in the catalyst regenerator (control system 1 in Figure 4-1), rather than
a carbon monoxide boiler, is used to control carbon monoxide emissions. In this case,
the cost savings resulting from improved catalyst activity and selectivity, which lead
to improved gasoline yields, for example, are more than adequate to offset both the costs
associated with in situ combustion and the electrostatic precipitators.
The EPA analysis presented in Appendix C examines not only the economic impact of
the standard for fluid catalytic cracking unit catalyst regenerators. It also examines
the combined economic impact of this standard, the standard for fuel gas combustion
devices, the water quality effluent guidelines for petroleum refineries being developed,
and EPA's regulations requiring the reduction of lead in gasoline. Because this analysis
was discussed in the previous section concerning the promulgated standard for fuel gas
combustion systems, a discussion of the analysis will not be presented here. The
reader is referred to either Appendix C or the previous section concerning the promulgated
standards for fuel gas combustion devices.
35
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CHAPTER 5. STORAGE VESSELS FOR PETROLEUM LIQUIDS
SUMMARY OF PROMULGATED STANDARD
The promulgated standard applies to storage vessels with capacities greater than
151,412 liters (40,000 gallons) that contain crude petroleum, condensate, or finished or
intermediate products of a petroleum refinery. The standard limits hydrocarbon emissions
from any such storage vessel by requiring equipment as follows:
1. If the true vapor pressure under actual storage conditions is equal to or greater
than 78 mm Hg (1.5 psia), but not greater than 570 mm Hg (11.1 psia), the storage
vessel shall be equipped with a floating roof, a vapor recovery system, or their
equivalents.
2. If the true vapor pressure under actual storage conditions is greater than 570 mm
Hg (11.1 psia), the storage vessel shall be equipped with a vapor recovery system
or its equivalent.
DISCUSSION OF PROMULGATED REGULATION
The major revisions in the promulgated regulation may be summarized as follows:
(1) The exemption threshold for tank size was reduced from 245,000 liters (65,000
gallons) to 151,412 liters (40,000 gallons).
(2) Conservation vents are no longer required on storage vessels containing petroleum
liquids at a true vapor pressure, as stored, of less than 78 mm Hg (1.5 psia).
(3) Requirements for daily recordkeeping were deleted, and other monitoring require-
ments were simplified to reduce recordkeeping and to aid enforcement.
(4) Maintenance requirements specific to storage vessels were deleted because the
General Provisions of the regulations now require proper maintenance of all
affected facilities.
In addition, many revisions that do not change the standard are included in the
promulgated regulation. These changes, which primarily consist of clarifying detail to
prevent confusion and misinterpretation, are discussed in the following sections.
Affected Facility
The definition of a storage vessel was clarified to specifically exclude high-pressure
vessels, subsurface caverns, porous-rock reservoirs, and underground tanks if the total
volume of petroleum liquids added to or taken from underground tanks annually does not
exceed twice the volume of the tank. As commentators pointed out, these types of storage
are optimum for preventing the release of emissions to the atmosphere and need no addi-
tional control devices.
37
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The proposed definition of petroleum liquids ("crude petroleum or any derivative
thereof") was criticized by several commentators for being so broad that it could be
misconstrued. The promulgated definition includes crude petroleum, condensate, and any
finished or intermediate products of a petroleum refinery, and excludes certain specified
fuel oils. Definitions of petroleum refinery and condensate were added to accommodate
these changes in the definition of petroleum liquids.
One commentator wanted the tank size exemption increased to 320,000 liters (84,500
gallons) because this size is most commonly used for storage of diesel fuels and the
mixtures of petroleum liquids known as pipeline interfaces. EPA agrees that storage of
such low-volatility liquids should be exempt from the standard; rather than increase the
tank-size exemption, however, the Agency expanded the definition of petroleum 'liquids to
specifically exclude certain low-volatility diesel fuels. Low-volatility interfaces
(less than 78 mm Hg or 1.5 psia) are now exempt from the hydrocarbon standard because
conservation vents are no longer reqjired on vessels containing liquids at these pres-
sures.
Many commentators stated that storage of crude oil and condensate at production
facilities in the field should be exempt from the standard. EPA intended such storage
to be exempt by the selection of the minimum tank size to which the standard would apply.
Industry representatives had indicated that the exemption size proposed, 245,0(30 liters
(65,000 gallons), would exempt essentially all of the tanks in the producing field.
However, data have since been presented that indicate larger tanks are sometimes used
in these locations. The designation of the affected facility was thus revised to
explicitly exempt storage of crude petroleum or condensate at producing facilities in
the field. The exemption applies to storage between the time that the oil and conden-
sate are removed from the ground and the time that custocy of these products i'i
transferred from the well or producing operations to the transportation operations.
Producing field storage is exemnt because the low level of emissions, the relatively
small size of these tanks, and their commonly remote locations do not justify the
switch from the bolted-construction, fixed-roof tanks in common use to the welcled-
construction, floating-roof tanks that would be reguired for new sources to conply
with the standards.
The standard as originally conceived was to apply to tanks with capacities greater
than 40,000 gallons in order to be consistent with existing State and local regulations.
As previously stated, the tank-size exemption for the proposed standard was instead set
at 65,000 gallons in order to exempt storage of crude oil and condensate in the field.
Because the promulgated standard now specifically exempts such storage, the minimum
exemption size has been reduced from 65,000 gallons to 40,000 gallons. Of the total
number of storage vessels to which the standard applies, only 2 percent will be
affected by this exemption size reduction.
38
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Two definitions were added to the regulation as a result of the addition of the
exemption for storage of crude oil and condensate in the field. The definition of a
drilling and production facility lists the equipment covered by the exemption, and
custody transfer is defined to specify the point at which the exemption no longer applies.
The Standard
The proposed standard required the use of a conservation vent or its equivalent on
storage vessels containing petroleum products with a true vapor pressure at actual
storage conditions of less than 78 mm Hg (1.52 psia). Several commentators pointed out,
and EPA agrees, that certain stocks can cause serious operating problems by fouling the
conservation vents, that these vents are frequently locked open or removed in winter to
prevent freezing, and that the beneficial effects of these vents on emissions are
minimal. This requirement was deleted from the promulgated standard.
Vapor recovery systems are cited in the standard as satisfactory control devices
for emissions from petroleum liquids stored at certain specified conditions. Several
commentators objected to the definition of a vapor recovery system because the wording
("disposal system ... to prevent . . . emission to the atmosphere") could be inter-
preted as demanding 100 percent recovery. EPA recognizes that recovery efficiencies
will vary according to climate and the types and concentrations of the vapors processed,
and has deliberately not required a specific level of efficiency. Control systems
which are capable of orovidinq an equivalent amount of control of hydrocarbon emissions
mav be used in lieu of the systems specified by the standard. An example of an
equivalent control system is one which incinerates with an auxiliary fuel the hydro-
carbon emissions from the storage tank before such emissions are released into the
atmosnhere.
At the suggestion of several commentators, the definition of floating roof, another
control option specified in the standard, was extended to include covered floating
roofs and internal floating covers.
Monitoring
Over half of the comments received concerning storage vessels contained objections to
various aspects of the proposed monitoring regulation, particularly the portion that
required daily records of transfer operations, tank temperatures, and true vapor pressures.
In a large, modern petroleum refinery, which was the type of operation used as a basis for
the standard, these items could be recorded and filed with little difficulty. Many of the
commentators, however, validly argued that such files would be an unjustifiable record-
keeping burden on remote tank farms, terminals, and marketing operations; the monitoring
requirements have been revised to eliminate the requirements for daily recordkeeping.
39
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Other monitoring requirements have been relaxed as well. The proposed regulation
required owners or operators of storage vessels containing petroleum liquids at speci-
fied pressures to provide, in addition to the daily records, monthly summaries of the
types of liquids stored, quantity transferred, bulk temperatures, and true vapor pres-
sures. Under the promulgated regulation, all owners or operators of any storage vessels
subject to the standard must only maintain a file on types of liquids stored, typical
Reid vapor pressures of each, dates of storage, and dates on which the vessel is empty.
Average monthly storage temperatures and true vapor pressures are also required for
liquids at certain specified storage conditions. The simplified monitoring regulation
will aid both operators and enforcement officials by reducing paperwork without sacrific-
ing the objectives of the standard.
A definition of Reid vapor pressure was added to the regulations in accordance with
the changes in the monitoring requirements.
Maintenance
Comments received indicated that the maintenance requirements were not Feasible be-
cause they were not specific enough. In addition, a revision to the General Provisions
(subpart A, 40 CFR 60) requires all affected facilities to be operated and maintained in
a manner consistent with good air pollution control practice for minimizing emissions.
This provision will eisure good maintenance practices, which was the purpose of the
proposed maintenance requirements for storage vessels. Maintenance requirements
specific to storage vessels were thus deleted.
40
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CHAPTER 6. SECONDARY LEAD SMELTERS AND REFINERIES
SUMMARY OF PROMULGATED STANDARDS
The promulgated standards of performance for secondary lead smelters and refineries
limit emissions of participate matter from blast (cupola) and reverberatory furnaces
as follows:
1. No more than 50 mg/dscm (0.022 gr/dscf).
2. Less than 20 percent opacity.
Visible emissions from any pot furnace with a charging capacity of more than
250 kilograms (550 pounds) shall be less than 10 percent opacity. Visible emissions
caused solely by the presence of uncombined water are not subject to the opacity standards,
DISCUSSION OF PROMULGATED REGULATION
No substantial changes have been made to the proposed concentration standard for
secondary lead smelters and refineries. However, some minor rewording and reorganiza-
tion changes that do not change the standard are included in the promulgated regulations.
To avoid repetition, the provision covering emission-records requirements, the
definition of participate matter, and the provision prohibiting the use of dilution
air were removed from individual regulations and incorporated in the General Provisions,
which are applicable to all sources. The paragraph concerning dilution air has also
been revised to clarify misunderstandings evidenced by comments received durinq the
public comment period. Other clarifications include: (1) deletion of "normal" from the
participate concentration standard to avoid confusion between "normal" and "standard,"
(2) substitution of a more specific statement of conditions under which performance tests
will be conducted, and (3) deletion of a confusing and repetitive statement concerning
the date upon which the standard becomes applicable. Several other changes, made to
clarify EPA's intent, were incorporated in the test methods and procedures. These include
a revision of the sampling time specified for performance testing, and inclusion of an
exception to the promulgated procedures to make clear EPA's recognition that process
variables may interfere with specified sampling conditions.
Because these changes in the regulations apply to nearly all of the sources for which
standards are promulgated, the rationale for changes is presented in Chapter 2, General
Considerations, of this volume.
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A minor revision, the removal of the 2-minute-oer-hour exemption from the
opacity standards, has been made to the regulation for secondary lead smelters and
refineries. This revision is based on new data, revaluation of the data collected
before proposal of the regulation, and the separate promulaation of exemptions from
opacity standards durinq periods of startup, shutdown, or malfunction.
Comments were received on both the opacity limit and the time exemption
provisions of the proposed regulation. Additional data were obtained durinq 9 hours
of continuous observations at one plant that met the concentration standard of
50 mg/dscm. Two qualified observers visually determined the opacity of emissions
from one reverberatory furnace and one blast furnace vented to the same stack.
During these 9 hours, the only visible emissions were at 5 percent opacity for 90
seconds and at 20 to 100 percent opacity for 17 minutes. The emissions at 20 to
100 percent opacity were caused, respectively, by a hole in a baa and by the byoass-
inq of an entire section of the baghouse. These two circumstances are considered
malfunctions, and opacity standards do not apply durina periods of malfunction.
(See the regulations recently promulqated in the Federal Register of October 15, 1973,
38 FR 28564, which exempt from opacity standards any emissions generated durina
startups, shutdowns, or malfunctions.) The new data provide information consistent
with the summaries of source tests submitted to EPA by the Los Angeles County Air
Pollution Control District under contract no. 2PO-68-02-3326. The Los Angeles
County data, used as oart of the basis for the prooosed standard, were obtained from
four plants that met the concentration standard. Emissions from three blast furnaces
and one reverberatory furnace were observed for a total of 4 hours and no visible
emissions were detected.
The proposed 2-minute time exemption was not based on observed increases in
opacity, but was an arbitrary selection of time intended to prevent uncontrollable
short-term emissions from constituting violations. The exemptions now provided by
the promulgated startup-shutdown-malfunction reaulations cover circumstance:; specific
to the source. The data show that the promulgated opacity limit of less than 20
percent allows minor variations and that there are no operating circumstances or
process variables that would renuire exemptions in addition to those orovided by
the startup-shutdown-malfunction regulations.
In the judgment of the Administrator, these data show that the promulgated (and
proposed) opacity limit is sufficiently close to observed ooacitv to ensure proper
operation and maintenance of the process and collection enuioment, and that the
limit, coupled with the exemptions for startups, shutdowns, and malfunctions, constitutes
an opacity standard that is not more restrictive than the concentration standard. A
general discussion of the intent of opacity standards and the issues involved in
setting them is included in Chapter 2 of this volume.
42
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CHAPTER 7. SECONDARY BRASS AND BRONZE INGOT PRODUCTION PLANTS
SUMMARY OF PROMULGATED STANDARDS
The promulgated standards of performance for secondary brass or bronze ingot pro-
duction plants limit emissions of participate matter from reverberatory furnaces having
production capacities of 1,000 kg (2,205 Ib) or greater as follows:
1. No more than 50 mg/dscm (0.022 gr/dscf).
2. Less than 20 percent opacity.
Visible emissions from any electric furnace of 1,000 kg (2,205 Ib) or greater pro-
duction capacity or from any blast (cupola) furnace of 250 kg/hr (550 Ib/hr) or greater
capacity shall not exhibit 10 percent opacity or greater. Visible emissions caused
solely by the presence of uncombined water are not subject to the opacity standards.
DISCUSSION OF PROMULGATED REGULATION
No substantial changes have been made to the proposed concentration standard for
secondary brass and bronze inoot production plants. However, some minor rewording and
reorganization changes that do not change this standard are included in the promul-
gated regulations.
To avoid repetition, the provision covering emission-records requirements, the
definition of particulate matter, and the provision prohibiting the use of dilution air
were removed from individual regulations and incorporated in the General Provisions,
which are applicable to all sources. The paragraph concerning dilution air has also been
revised to clarify misunderstandings evidenced by comments received during the public
comment period. Other clarifications include: (1) deletion of "normal" from the
particulate concentration standard to avoid confusion between "normal" and "standard,"
(2) substitution of a more specific statement of conditions under which performance tests
will be conducted, and (3) deletion of a confusing and repetitive statement concerning
the date upon which the standard becomes applicable. Several other changes, made to
clarify EPA's intent, were incorporated in the test methods and procedures. These
include a revision of the sampling time specified for performance testing, and inclusion
of an exception to the promulgated procedures to make clear EPA's recognition that process
variables may interfere with specified sampling conditions.
Because these changes in the regulations apply to nearly all of the sources for
which standards are promulgated, the rationale for changes is presented in Chapter 2,
General Considerations, of this volume.
43
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Change in the Opacity Standards
The opacity standards for brass and bronze ingot production plants have been
revised to reflect new data, revaluation of the data collected before proposal of
the regulation, and the separate promulgation of regulations which exempt from
opacity standards any emissions generated during periods of startup, shutdown, or
malfunction (see Federal Register of October 15, 1973, 38 FR 28564).
In response to comments received during the public comment period, additional data
were obtained from two wel1-control led reverberatory furnaces. The first of these
furnaces, controlled by a baghouse, was source-tested during the development of the
proposed standard and found to meet tne concentration limit. The opacity of emissions
from this baghouse was determined visually by two qualified observers. Observations, made
continuously for 4 hours, showed that emissions from the baghouse varied from 0 to 10
percent opacity. All observations were made during the refining processthat portion of
the ingot production cycle judged by EPA and by plant operators to cause the greatest
amount of the most visible emissions. In addition, the particulate concentration to the
baghouse was considered to be high because a large percentage of zinc was present in the
scrap. The furnace was being used to oxidize the zinc so that it would be removed as zinc
oxide in the ventilation gases ducted to the baghouse. Thus, even under heavy load condi-
tions, this baghouse easily met the promulgated opacity standard.
The second plant was tested continuously for 5 hours, also by two qualified
observers, and similar data were obtained. Observations were made of emissions from a
baghouse controlling both a blast (cupola) furnace and a reverberatory furnace. This
baghouse was also source-tested during the development of the proposed standard, but
malfunctions invalidated the data obtained, and no judgment was made as to whether this
baghouse could meet the concentration standard. As in the plant above, emissions
varied from 0 to 10 percent opacity.
The proposed 2-minute time exemption was not based on observed increases in opacity,
but was an arbitrary selection of time intended to prevent uncontrollable short-term
emissions from constituting violations. The exemptions now provided by the promulgated
startup-shutdown-malfunction regulations cover circumstances specific to the source.
The data show that the promulgated opacity limit of less than 20 percent allows
minor variations and that there are no operating circumstances or process variables
that would require exemptions in addition to those provided by the startup-shutdown-
malfunction regulations.
44
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In the judgment of the Administrator, these data show that the promulgated opacity
limit is sufficiently close to observed opacity to ensure proper operation and main-
tenance of the process and collection equipment, and that the limit, coupled with the
exemptions for startups, shutdowns, and malfunctions, constitutes an opacity standard
that is not more restrictive than the concentration standard. A general discussion
of the intent of opacity standards and the issues involved in setting them is included
in Chapter 2 of this volume.
45
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-------
CHAPTER 8. IRON AND STEEL PLANTS
SUMMARY OF PROMULGATED STANDARD
The promulgated standard of performance for iron and steel plants limits emissions
of particulate matter from basic oxygen process furnaces to no more than 50 mg/dscm
(0.022 gr/dscf).
DISCUSSION OF PROMULGATED REGULATION
Some minor rewording and reorganization that do not change the standard are included
in the promulgated regulations. The proposed opacity standard covering iron and steel
plants has been withdrawn for further study. Comments received pointed out the inappro-
priateness of the proposed standard (10 percent opacity except for 2 minutes each
hour) for this cyclic steel-making process. The separate promulgation of regulations
(see Federal Register of October 15, 1973, 38 FR 28564) which provide exemptions from
opacity standards during periods of startup, shutdown, and malfunction added another
dimension to the problem, and the collection of new data shows variations in opacity
for reasons not yet well enough identified.
To avoid repetition, the provision covering emission-records requirements, the
definition of particulate matter, and the provision prohibiting the use of dilution
air were removed from individual regulations and incorporated in the General Provisions,
which are applicable to all sources. The requirement concerning dilution air has been
removed from this regulation and dealt with as a general provision (subpart A)
applicable to all sources to clarify misunderstandings evidenced by comments received
during the public comment period. Other clarifications include: (1) deletion of
"normal" from the particulate concentration standard to avoid confusion between
"normal" and "standard," (2) substitution of a more specific statement of conditions
under which performance tests will be conducted, and (3) deletion of a confusing and
repetitive statement concerning the date upon which the standard becomes applicable.
Several other changes, made to clarify EPA's intent, were incorporated in the test
methods and procedures. These include a revision of the sampling time specified for
performance testing, and inclusion of an exception to the promulgated procedures to
make clear EPA's recognition that process variables may interfere with specified
sampling conditions.
Because these changes in the regulations apply to nearly all of the sources for
which standards are promulgated, the rationale for these changes is presented in
Chapter 2, General Considerations, of this volume.
47
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CHAPTER 9. SEWAGE TREATMENT PLANTS
SUMMARY OF PROMULGATED STANDARDS
The promulgated standards of performance for sewage treatment plants limit
participate emissions from sludge incinerators at municipal sewage treatment
plants as follows:
1. No more than 0.65 g/kg dry sludge input (1.30 Ib/ton dry sludge input).
2. Less than 20 percent opacity.
Visible emissions caused solely by the presence of uncombined water are not
subject to the opacity standard.
DISCUSSION OF PROMULGATED REGULATION
The major changes from the proposed to the promulgated regulation are:
1. The standard is now based on units of mass rather than on the proposed
units of concentration.
2. The opacity standard was changed from the proposed limit of less than
10 percent except for 2 minutes in any 1 hour to less than 20 percent.
3. To accommodate the change of units, the section on test methods was
revised and a section on monitoring requirements was added.
Some minor rewording and reorganization changes that do not change the standard
are also included in the promulgated regulation. For example, the designation
of the affected facility was clarified and several definitions were deleted.
To avoid repetition, the provision covering emission-records requirements
and the definition of particulate matter were removed from individual regulations
and incorporated into the General Provisions, which are applicable to all sources.
Change of Units for the Standard
o
Emission limits were proposed in terms of concentration (mg/Nm ). Sludge
incineration, like most combustion processes, requires more air than is actually
used in the combustion process. This "excess air" promotes combustion, but the
amount of excess air used varies significantly from plant to plant. In addition,
gases from a multiple-hearth incinerator are often diluted with shaft cooling
air upstream of the sampling point. Both excess air and shaft cooling air
dilute the gases discharged to the atmosphere and thereby decrease particulate
concentration.
EPA studied these problems prior to proposal of the regulation and concluded
that a concentration standard would still be acceptable for the following reasons:
49
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Excess air - Sludge incineration is not self-sustaininq at the temoeratures desired
and auxiliary fuel must be used. Excess air absorbs heat, increasina auxiliary
fuel requirements. The volume of qases which must be treated bv the scrubber also
increases. Economics, then, encourages operation at the lowest feasible level of
excess air.
Shaft cooling air (multiple-hearth incinerators only) - Since shaft coolina air
bypasses the incinerator and the scrubber, economics does not limit the use of this
air as a diluent. A provision was written into the regulation to solve this problem
by requiring that the amount of such dilution be determined bv the owner or operator.
The results would then be corrected to an undiluted basis.
Comments on the proposed regulations and additional discussions with industry
experts have revealed two difficulties with this approach.
First, dilution does occur and is significant. Percent C02, an inverse function
of excess air, averaged 12.3 percent on a fluidized-bed incinerator and 10.1 percent
on a multiple-hearth incinerator during EPA tests. This means that if the two
incinerators were discharging the same quantity (pounds per hour) of narticulate
matter, the concentration of particulate matter in the gases from the multiple-hearth
incinerator would be approximately 20 percent less than the concentration in the
gases from the fluidized-bed unit because of the difference in the amount of air
dilution.
Second, the control devices normally used on sludqe incineratorswet scrubbers--
absorb some of the CO, present in the gases discharged to the atmosphere. This, as
well as the C02 contributed by auxiliary fuel, alters the gas composition and
precludes the relatively simple correction of results to a reference basis such as
12 percent 02> Determination of the amount of dilution could then prove difficult.
Gas velocity determination, the most practical alternative to COg correction, is of
use only when dilution air is added following the incinerator. It can seldom be used
to determine the amount of excess air, and its use in determining shaft cooling air
or other dilution is limited by the need for simultaneous traverses and/or unfavorable
ductwork configurations. Introduction of shaft cooling air would be prohibited prior
to the sampling site, but such regulation would not affect excess air and auxiliary
fuel variations.
Expressing the standard in mass units of grams particulate per kilogram of dry
sludge fed to the incinerator (g/kg) avoids the above problems. Data from the
incinerators tested are presented in terms of mass in Figure 9-1. The test results
shown in this figure are far different in relation to the standard and to each other
than are the results shown in terms of concentration in Volume 1 of this series
50
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&
i 3
cc
4
O-
MAXIMUM
4AVERAGE
MINIMUM
A P - PRESSURE DROP
TEST METHOD NUMBER 2 = EPA METHOD 5
2
AP=6in.
AP=4 in. H20
AP = 6 in. H20
A P =2.5 in. H20
= 18rin. HjO
PLANT, CONTROL EQUIPMENT
Figure 9-1. Particulate emissions from sludge incinerators at sewage treatment
plants.
51
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of documents. For example, the test results in terms of concentration indicate
that Plant C almost meets the proposed standard, but these same results converted
to mass units show that Plant C does not come close to meeting the promulgated
standard. Differences of this type are attributable to the various amounts of
combustion air used in the individual plants. Test results are thus unaffected
by either dilution or combustion air volume when expressed in terms of mass.
Average values of Plant A test results were used to convert the proposed standard
(70 mg/Nm or 0.03 gr/dscf) to mass units:
0.03, gr/,scf (proposed NSPS) x - ,.30Wt»
0.65 g/kg
Thus, the level of control required by the standard is unaffected; only the units have
been changed.
The new units require determination of dry sludqe feed rate (input). The promulgated
regulation details the information neected, usually only two items: liquid sludge flow
rate and dry sludge weight per unit volume of liquid sludge.
C.nange in the Opacity Standard
The opacity standard covering sewage treatment plants has been revised to
reflect new information obtained on a well -control led plant and to reflect the
recently promulgated regulations which exempt from opacity standards any emissions
generated during periods of startup, shutdown, or malfunction (see Federal Register
of October 15, 1973, 38 FR 28564).
New data were obtained from a well -control led sludge incinerator. This
incinerator was the one previously tested by EPA that met the promulgated process
weight standard. The opacity of emissions from this incinerator was determined
visually by two qualified observers during 6.25 hours of continuous observation.
The only visible emissions observed were for 45 seconds at 10 percent opacity and
for 35 minutes at 5 percent opacity.
The proposed 2-minute time exemption was not based on observed increases in
opacity, but was an arbitrary selection of time intended to prevent uncontrollable
short-term emissions from constituting violations. The exemptions now provided by
the startup-shutdown-malfunction regulations cover circumstances specific to the
source. The data show that the promulgated opacity limit of less than 20 percent
allows minor variations and that there are no operating circumstances or process
variables that would require exemptions in addition to those provided by the
startup-shutdown-mal f uncti on regul ati ons .
52
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In the judgment of the Administrator, these data show that the promulgated
opacity limit is sufficiently close to observed opacity to ensure proper operation
and maintenance of the process and collection eauipment, and that the limit, coupled
with the exemptions durinq startups, shutdowns, and malfunctions, constitutes an
opacity standard that is not more restrictive than the concentration standard. A
general discussion of the intent of opacity standards and the issues involved in
setting them is included in Chapter 2 of this volume.
Emission Test Conditions
Three of the five plants tested by EPA (Plants B, C, and E) operated at sludge
burning rates far below the design rate durinq the tests. These low burninq rates,
as one commentator pointed out, result in gas flow through a multiple-hearth
incinerator system at rates below those for which the scrubbers were desiqned. The
low gas flow rates adversely affect scrubber efficiency unless the control device,
e.g., a venturi scrubber with an adjustable throat, can compensate for changes in
flow. However, tabulation of the results from Plants B through E (all equipped
with impingement-type scrubbers) shows no relationship between mass emissions and
percent of rated capacity (Table 9-1). Instead, mass emissions from these
facilities appear strongly dependent on pressure drop across the scrubber (Table
9-2). Why, though, is there little or no effect at decreased burning capacity?
One manufacturer* suggests that, for multiple-hearth furnaces, the decrease in gas flow
rate results in less entrainment of fly ash. Therefore, the amount of particulate
matter entering the scrubber is less. The two changes cancel each other out, and the
mass emission rate remains fairly constant over a wide range of feed rates.
For flin"dized-bed incinerators, operating conditions are more rigid. Gas flow
rate must be high enough to keep the sand fluid, so it cannot be decreased at lower
feed rates. Both fluidized-bed units tested by EPA operated at nearly 100 percent
capacity during the tests, so the effect of reduced feed rates is not known, but the
necessity of maintaining a fluidized bed, in the Administrator's best judgment, precludes
operating these units at gas flow rates that would adversely affect control device
efficiency.
telephone communication with Mr. Mark Helms, Envirotech Corp., Menlo Park, CA 94025.
September 18, 1973.
53
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Table 9-1. RELATIONSHIP OF OPERATING AT LESS THAN RATED
CAPACITY TO MASS EMISSIONS FROM
IMPINGEMENT SCRUBBERS3
Plant
D
B
Eb
C
Type of
incinerator
FT uidi zed-bed
Multiple-hearth
Multiple-health
Multiple-hearth
Operation, % of
rated capacity
95
64
50
35
Mass emissions,
Ib/ton
2.77
2.09
2.80
2.21
aPlant A's scrubber is a different design (venturi), so Plant A is not
included in the table.
Plant E has a cyclonic rather than a plate scrubber, but the efficiency
is similar (Scrubber Handbook, Chapter 3).
54
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Table 9-2. RELATIONSHIP OF PRESSURE DROP TO MASS EMISSIONS
FROM IMPINGEMENT SCRUBBERS3
Plant
B
C
D
Eb
Type of
incineration
Multiple-hearth
Multiple-hearth
Fluidi zed-bed
Multiple-hearth
Pressure drop,
in. H20
6
6
4
2.5
Mass emissions,
Ib/ton
2.09
2.21
2.77
2.80
aPlant A's scrubber is a different design (venturi), so Plant A is not
included in the table.
Plant E has a cyclonic rather than a plate scrubber, but the efficiency
is similar (Scrubber Handbook, Chapter 3).
55
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APPENDIX A. ASPHALT CONCRETE PLANT DATA SUBMITTED AFTER PROPOSAL
The partial or complete stack test reports submitted in response to EPA's request for
factual data are presented in this appendix. Test reports were received for 11 wet
scrubber-equipped plants, five baghouse-equipped plants, and two venturi scrubber-
equipped plants. With one exception, stack tests of the baghouse- and venturi scrubber-
equipped plants were done using test procedures in general conformance with EPA method 5.
The test results for facility P were considered to be invalid for the reasons indicated
in Table A-2. With the exception of the data from the wet scrubber-equipped plants and
the data for facility P, all of the average outlet concentrations are summarized in
Table 3-2 in Chapter 3. The exhaust gases were analyzed at each plant after they were
discharged from the control equipment. These gases included dryer exhaust gases and
sweep air used to gather dust at such points in the system as elevators, screens, and
scavenger systems. Most of the data for the wet scrubber-equipped plants were collected
using the San Bernardino County Air Pollution Control District's test procedure.
EPA also received the final test results for 13 baghouse- or venturi scrubber-
equipped plants using valid and known testing procedures, and data showing average outlet
concentrations for 25 plants that had unknown control equipment or were tested using
unknown test procedures. The data for these 38 plants are summarized in Table 3-1;
they are not, however, included in this appendix due to a lack of information necessary
to evaluate the data.
57
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Table A-l. Asphalt Concrete Facility Oa
Run number 1 2 3 Average
Date 4/3/73 4/3/73 4/4/73
Test time, minutes 144 144 144 144
Production rate,
tons/hr 300 315 271 295
Stack Effluent
Flowrate, dscfm 36,217 36,396 36,675 36,429
Flowrate, dscf/ton 7267.6 6932.6 8119.9 7409
product
Temperature, °F 140 145 143 143
Water Vapor, Vol. % 16.7 15.4 14.2 15.4
C02, Vol. % 2.2 2.2 2.2 2.2
02, Vol. % 17.4 17.4 17.4 17.4
CO, vol. % __ _
Visible emissions,
% opacity
Particulate emissions
Probe and filter catch
qr/dscf 0.0297 0.0299 0.0413 0.0336
gr/acf 0.0287 0.0290 0.0407 0.0326
Ib/hr 9.21 9.33 12.97 10.50
Ib/ton of product 0.0308 0.0296 0.0478 0.0361
Total Catch
gr/dscf
gr/acf
Ib/hr _ _ __ _
Ib/ton of product
Oil-fired (No. 2 diesel oil), 250-tons/hr-capacity plant equipped with a cyclone and
a baghouse with a desiqn air-to-cloth ratio of 6-to-l. Plant was operating at capacity
during the test periods. Data were provided by the National Asphalt Pavement Association
in their public comment.
58
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Table A-2., Asphalt Concrete Facility Pa
Run number M 1 2 Average
Date 11/15/72 11/15/72 11/15/72
Test time, minutes 90 74 62 75.3
Production rate,
tons/hr ~250 ~250 ~250 ~250
Stack Effluent
Flowrate, dscfm
Flowrate, dscf/ton
product
Temperature, °F 192 194 190 192
Water Vapor, vol. % 10.33 9.36 9.59 9.76
C02, vol. % 2.2 2.2 2.2 2.2
02, vol. % 4.64 4.64 4.64 4.64
CO, vol. % _ _ _ __
Visible emissions,
% opacity
Particulate emissions
Probe and filter catch
gr/dscf 0.091 0.084 0.098 0.0904
gr/acf
Ib/hr 30.80 28.55 32.63 31.36
Ib/ton of product
Total Catch
gr/dscf
gr/acf
Ib/hr _ _ _ _
Ib/ton of product
Oil-fired (No. 2 diesel oil), 300-tons/hr-design-capacity plant equipped with a cyclone
and a baghouse with a design air-to-cloth ratio of 6-to-l. Plant was operating at about
80 percent capacity during the test periods. Data were provided by the National Asphalt
Pavement Association in their public comment. Test results were considered unacceptable
because:
(1) the velocity head data suggest that the samples were obtained in a region of
turbulent flow, and
(2) the sampling time used at each point was not constant.
Thus, the use of only 10 sample points does not conform to the minimum criteria
specified in methods 1 and 2 and places the accuracy of the test data in serious
question.
59
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Table A-3. Asphalt Concrete Facility Qa
Run number
Date
Test time, minutes
Production rate,
tons/hr
Stack Effluent
Flowrate, dscfm
Flowrate, dscf/ton
product
Temperature, °F
Water Vapor, vol %
C02, vol. %
02, vol. %
CO, vol. %
Visible emissions,
% opacity
Particulate Emissions
Probe and filter catch
gr/dscf
gr/acf
Ib/hr
Ib/ton of product
Total Catch
gr/dscf
gr/acf
Ib/hr
Ib/ton of product
1
10/25/72
54
18,700
200
19.0
10/26/72
54
19,830
200
16.3
No Orsat available
No Orsat available
No Orsat available
0.0156
"2.50
0.0661
10.59
0.0189
3720
0.0578
9.82
Average
54
19,265
200
17.65
0.0172
2776
0.062
9.91
Oil-fired (No. 5 grade fuel oil), 100-tons/hr-design-capacity plant equipped with a
cyclone and a baghouse with a design air-to-cloth ratio of 6-to-l. Plant was operating
at capacity during the test periods. Data were provided by commentator number 97.
Plant was tested with a modified EPA train, but the modifications from recommended
procedures are considered to be minor.
60
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Table A-4. Asphalt Concrete Facility
Run number
Date
Test time, minutes
Production rate,
tons/hr
Stack Effluent
Flowrate, dscfm
Flowrate, dscf/ton
of product
Temperature, °F
Water Vapor, vol. %
C02, vol. %
02, vol. %
CO, vol. %
Visible emissions,
% opacity
Particulate emission
Probe and filter catch
gr/dscf
gr/acf
Ib/hr
Ib/ton of product
Total Catch
gr/dscf
gr/acf
Ib/hr
Ib/ton of product
1
3/21/73
100
23,464
219
14.4
2.5
16.5
0.009
0.0072
1.86
0.0476
0.0366
9.41
4/27/73
100
22,904
256
25.7
3.5
11.5
0.017
0.0124
3.28
0.0366
0.0267
7.07
3
4/27/73
110
22,904
255
25.7
3.5
11.5
Average
103
0.0203
0.0149
3.95
0.0282
0.0206
5.46
23,091
243
21.9
3.2
13.2
0.0138
0.0104
2.73
0.0404
0.0301
7.24
Gas-fired, 120-tons/hr-design-capacity plant equipped with a cyclone and a baghouse
with a design air-to-cloth ratio of 5-to-l. Plant was operating at 75 percent design
capacity during the test periods. Data were provided by a State control agency. Plant
was tested with EPA's train. Minor deviations from the recommended procedures occurred,
but these should not significantly affect the accuracy of the data.
61
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Table A-5. Asphalt Concrete Facility Sc
Run number
Date
Test time, minutes
Production rate,
tons/hr
Stack Effluent
Flowrate, dscfm
Flowrate, dscf/ton
of product
Temperature, °F
Water Vapor, Vol. %
C02, vol. %
0?, vol.
vol.
0, vol.
Visible emissions,
% opacity
Particulate emissions
Probe and filter catch
gr/dscf
gr/acf
Ib/hr
Ib/ton of product
Total catch
gr/dscf
gr/acf
Ib/hr
Ib/ton of product
1
10/30/72
50
24,500
294
35.9
3.4
14.9
0.6
0.026
0.022
5.46
0.049
0.0416
10.29
10/31/72
132
23,809
300
34.9
3.8
14.2
0.6
0.017
0.0114
3.47
0.062
0.0349
10.61
10/31/72
60
23,800
300
34.9
3.8
14.2
0.6
0.020
0.013
4.08
0.037
0.024
7.55
Average
80.7
24033
298
35.2
3.7
14.4
0.6
0.0198
.0139
4.08
0.048
0.034
9.89
Gas-fired, 240-tons/hr-design-capacity plant equipped with a baghouse. Production
during the test periods was 120 tons/hr because the aggregate was extremely wet.
Data were provided by a State control agency. Plant was tested using EPA's train.
Minor deviations from recommended procedures occurred, but these should not signifi-
cantly affect the accuracy of the data.
62
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Table A-6. Asphalt Concrete Facility Ta
Run number
Date
Test time, minutes
Production rate,
tons/hr
Stack Effluent
Flowrate, dscfm
Flowrate, dscf/ton
of product
Temperature, °F
Water Vapor, vol. %
C02, vol. %
02, vol. %
CO, vol. %
Visible emissions,
% opacity
Particulate emissions
Probe and filter catch
gr/dscf
gr/acf
Ib/hr
Ib/ton of product
Total catch
gr/dscf
gr/acf
Ib/hr
Ib/ton of product
1
6/14/73
54
24,800
110
9.7
1.8
18.5
0.013
0.0107
2.6
0.018
0.014
3.4
2
6/14/73
54
25,500
110
10.1
1.5
19.5
0.011
0.0086
2.2
0.015
0.0116
3.0
3
6/15/73
54
25,700
110
8.1
0.6
20.0
0.035
0.028
7.8
0.037
0.030
8.4
Average
54
25,333
110
9.3
1.3
19.3
0.0208
0.0167
4.4
0.0242
0.0194
5.2
aGas-fired plant equipped with a cyclone and a venturi scrubber operating at 10.5 inches
water gauge pressure drop and approximately 15 gallons of water per 1000 scfm of exhaust
gases. Production during the test periods was 130 tons/hr. Data were provided by a
State control agency. Plant was tested using EPA-recommended procedures.
63
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Table A-7. Asphalt Concrete Facility Ua
Run number
Date
Test time, minutes
Production rate,
tons/hr
Stack Effluent
Flowrate, dscfm
Flowrate, dscf/ton
product
Temperature, °F
Water Vapor, vol. %
C02, vol. %
02, vol. %
CO, vol. %
Visible emissions,
% opacity
Particulate emissions
Probe and filter catach
gr/dscf
gr/acf
Ib/hr
lb/ton of product
Total catch
gr/dscf
gr/acf
Ib/hr
Ib/ton of product
1
1/23/73
72
101.6
30,056
2
1/23/73
72
93
29,733
No Orsat available
No Orsat available
No Orsat available
0.0286
7.34
0.0722
0.0239
6.06
0.065
Average
72
97.3
29,895
17,750
96
5.67
19,183
100.1
6.48
18,435
98
6.08
0.0220
5.6
0.055
0.0179
4.5C
0.049
0.020
5772
0.053
0.0264
6.76
0.0695
Oil-fired (No. 2 diesel oil), 100-tons/hr-design-capacity plant equipped with a
cyclone and a venturi scrubber operating at 14 inches water gauge pressure drop.
Plant production during the test periods was approximately at capacity for conditions
prevalent at the time of the test. Data were provided by a local control agency.
Plant was tested using EPA train and the results are accepted as being reasonably
valid. Lack of field data precluded complete evaluation of the accuracy and
representativeness of the test data.
64
-------
Table A-8. Asphalt Concrete Facility Va
Run number
Date
Test time, minutes
Production rate,
tons/hr
Stack Effluent
Flowrate, dscfm
Flowrate, dscf/ton
of product
Temperature, °F
Water vapor, vol. %
C02, vol. %
02, vol. %
CO, vol. %
Visible emissions,
% opacity
Particulate emissions
Probe and filter catch
gr/dscf
gr/acf
Ib/hr
Ib/ton of product
Total catch
gr/dscf
gr/acf
Ib/hr
Ib/ton of product
1
8/24/73
unknown
200
27,240
8172
130
Not available
No Orsat available
No Orsat available
No Orsat available
0.0644
15.1
0.0755
Gas-fired, 360 tons/hr-design-capacity plant equipped with a cyclone and a
wet scrubber. Plant was operating at less than 50 percent of design capacity
during the test. Data were p^ov\ded by a local control agency. Test is
unacceptable because of cyclonic and turbulent flows in tne gas- strwm.
65
-------
Table A-9. Asphalt Concrete Facility Wa
Run number
Date
Test time, minutes
Production rate, tons/hr
Stack Effluent
Flowrate, dscfm
Flowrate, dscf/ton
of product
Temperature, °F
Water vapor, vol. %
C02, vol. %
02, vol. %
CO, vol. %
Visible emissions,
% opacity
Particulate emissions
Probe and filter catch
gr/dscf
gr/acf
Ib/hr
Ib/ton of product
Total catch
gr/dscf
gr/acf
Ib/hr
Ib/ton of product
1
4/13/72
60
275
32,900
7178
142
17.1
No Orsat available
No Orsat available
No Orsat available
0.0455
0.0377
13.2
0.048
aApproximately 320-tons/hr-deslgn-capacity plant equipped with a cyclone
and a; wet fan. Production during test was 275 tons/hr. Plant operating
parameters are unknown. Data were provided by a local control agency.
66
-------
Table A-10. Asphalt Concrete Facility Xa
Run number
Date
Test time, minutes
Production rate, ton/hr
Stack Effluent
Flowrate, dscfm
Flowrate, dscf/ton
of product
Temperature, °F
Water vapor, vol. %
C02, vol. %
02, vol. %
CO, vol. %
Visible emissions,
% opacity
Particulate emissions
Probe and filter catch
gr/dscf
gr/acf
Ib/hr
Ib/ton of product
Total catch
gr/dscf
gr/acf
Ib/hr
lb/ton of product
1
1/4/73
unknown
200
82,000
24,600
125
Not available
No Orsat available
No Orsat available
No Orsat available
10
0.0237
16.2
0.081
2
1/4/73
unknown
200
80,154
24,046
125
Not available
10
0.0286
19.5
0.0975
aPlant was equipped with two primary cyclones, a multiple wet scrubber, and
a wet fan. Production during test was 200 tons/hr. Data were provided by
a local control agency.
67
-------
Table A-ll. Asphalt Concrete Facility Ya
Run number
Date
Test time, minutes
Production rate, tons/hr
Stack Effluent
Flowrate, dscfm
Flowrate, dscf/ton
of product
Temperature, °F
Water vapor, vol. %
C02, vol. %
02, vol. %
CO, vol. %
Visible emissions,
% opacity
Particulate emissions
Probe and filter catch
gr/dscf
gr/acf
Ib/hr
Ib/ton of product
Total catch
gr/dscf
gr/acf
Ib/hr
Ib/ton of product
1
11/9/72
unknown
270
50,200
11,156
125
Not available
No Orsat available
No Orsat available
No Orsat available
0.0045
1.93
0.007
2
11/9/72
unknown
37,200
125
Not available
0.015
4.98
aPlant was equipped with two primary cyclones (in parallel), two multiple
wet scrubbers (in series), and a wet fan. Production during the test was
270 tons/hr. Data were provided by a local control agency.
68
-------
Table A-12. Asphalt Concrete Facility 2a
Run number
Date
Test time, minutes
Production rate, tons/hr
Stack effluent
Flowrate, dscfm
Flowrate, dscf/ton
of product
Temperature, °F
Water vapor, vol. %
C02, vol. %
02, vol. %
CO, vol. %
Visible emissions,
% opacity
Particulate emissions
Probe and filter catch
gr/dscf
gr/acf
Ib/hr
Ib/ton of product
Total catch
gr/dscf
gr/acf
Ib/hr
Ib/ton of product
1
11/16/71
unknown
100
62,175
37,305
115
1.5
17.0
0.0217
11.56
0.1156
was equipped with a large-diameter primary cyclone, three wet
scrubbers (in series), and a wet fan. Production during the test
was TOO tons/hr. Data were provided by a local control agency.
69
-------
Run number
Date
Test time, minutes
Production rate, tons/hr
Stack Effluent
Flowrate, dscfm
Flowrate, dscf/ton
of product
Temperature, °F
Water vapor, vol. %
C02, vol. %
02, vol. %
CO, vol. %
Visible emissions,
% opacity
Particulate emissions
Probe and filter catch
gr/dscf
gr/acf
Ib/hr
Ib/ton of product
Total catch
gr/dscf
gr/acf
Ib/hr
Ib/ton of product
Table A-13. Asphalt Concrete Facility AA
1
7/16/71
unknown
250
38,719
9293
135
unknown
2.5
<5
0.011
3.48
0.014
2
7/19/71
unknown
250
34,673
8322
135
unknown
3.0
<5
0.004
1.07
0.004
aPlant's design capacity is 250 tons/hr. Plant was equipped with a
cyclone, three wet scrubbers (in series), and a wet fan. Production
durino the test was at naximun capacity. Data were provided by a
local control agency.
70
-------
Table A-14. Asphalt Concrete Facility BBa
Run number
Date
Test time, minutes
Production rate, tons/hr
Stack Effluent
Flowrate, dscfm
Flowrate, dscf/ton
of product
Temperature, °F
Water vapor, vol . %
C02, vol. %
02, vol. %
CO, vol. %
Visible emissions,
% opacity
Particulate emissions
Probe and filter catch
gr/dscf
gr/acf
Ib/hr
Ib/ton of product
Total catch
gr/dscf
gr/acf
Ib/hr
Ib/ton of product
1 2 3
3/5/73 3/5/73 3/5/73
unknown unknown unknown
144 144 144
15,156 14,710 15,974
6315 6129 6656
131 138 140
23.7 29.5 24.6
No Orsat available
No Orsat available
No Orsat available
0.0324 0.0465 0.0549
^__ __ __
4.21 5.86 7.52
0.0293 0.0408 0.0523
_ _ _
_ j .__
. .L - ^^_ ,^^_
Average
-,,,
144
15,280
6367
136
25.9
0.0446
,_,
5.86
0.0408
_
-
^^_
aPlant was equipped with a skinner for primary control, a wet pre-scrubber,
a wet fan, and a wet cyclonic scrubber. Production during the test was
144 tons/hr. Data were provided by connentator nunber 11.
71
-------
Table A-15. Asphalt Facility CCa
Run Number
Date
Test time, minutes
Production rate,
tons/hr
Stack Effluent
Flowrate, dscfm
Flowrate, dscf/ton
of product
Temperature, °F
Water Vapor, Vol. %
C02, vol. %
0 , Vo. %
2
CO, vol. %
Visible emissions,
% opacity
Particulate emissions
Probe and filter catch
gr/dscf
gr/acf
Ib/hr
Ib/ton of product
Total catch
gr/dscf
gr/acf
Ib/hr
Ib/ton of product
1
4/6/72
unknown
200
29,479
8844
120
No Orsat available
No Orsat available
No Orsat available
0.047
11.8
0.059
aGas-fired, 200-tons/hr-design-capacity plant equipped with a cyclone and
three wet scrubbers installed in series. Data were provided by a local
control agency. 72
-------
Table A-16. Asphalt Concrete Facility DDa
Run number 123
Date 12/19/72 12/19/72 12/20/72
Test time, minutes 60 60 60
Production rate, tons/hr 253 253 253
Stack Effluent
Flow rate, dscfm 27,800 27,800 26,100
Flow rate, dscf/ton 6,593 6,593 6,190
of product
Temperature, °F 155 155 160
Water vapor, vol. % 32.0 30.5 32.8
COo, vol. % 4.0 4.0 4.4
02, vol. % 14.3 14.2 10.4
CO, vol. % 0.9 0.8 2.2
Visible emissions, -
% opacity
Particulate emissions
Probe and filter catch
gr/dscf 0.061 0.059 0.106
gr/acf -
Ib/hr 14.5 14.1 23.7
Ib/ton of product 0.057 0.056 0.094
Total catch
gr/dscf 0.062 0.060 0.107
gr/acf -
Ib/hr 14.8 14.3 23.9
Ib/ton of product 0.058 0.057 0.094
aGas-fired plant equipped with a cyclone, a wet cyclone, and a wet fan.
Production rate during the test period was 253 tons/hr. Data were
provided by a State control agency.
73
-------
Table A-17. Asphalt Concrete Facility EEa
Run number 1 2 3
Date 10/6/72 10/6/72 10/6/72
Test time, minutes 42.5 28 50
Production rate, tons/hr 150 150 150
Stack effluent
Flow rate, dscfm 18,420 18,420 18,420
Flow rate, dscf/ton 7,368 7,368 7,368
of product
Temperature, °F 125 125 125
Water vapor, vol. % 16.8 17.6 18.5
C02, vol. % 2.6 2.6 2.6
02, vol. % 17.0 17.0 17.0
CO, vol. % <0.1 <0.1 <0.1
Visible emissions, -
% opacity
Particulate emissions
Probe and filter catch
gr/dscf " 0.098 0.117 0.131
gr/acf -
Ib/hr 15.5 18.5 20.7
Ib/ton of product 0.103 0.123 0.138
Total catch
gr/dscf 0.099 0.122 0.134
gr/acf
Ib/hr 15.6 19.3 21.2
Ib/ton of product 0.104 0.129 0.141
Gas-fired plant equipped with a cyclone, a wet fan, and a low-energy
scrubber. Production during the test was 150 tons/hr. Data were
provided by a State control agency.
74
-------
Table A-18. Asphalt Concrete Facility FFa
Run number 1 2 3
Date 11/14/72 11/14/72 11/14/72
Test time, minutes 46.4 48.2 17.3
Production rate, tons/hr 106 106
Stack effluent
Flow rate, dscfm 15,300 15,900 15,900
Flow rate, dscf/ton 8,660 9,000
of product
Temperature, °F 112 120 120
Water vapor, vol. % 16.5 21.8 22.6
C02, vol. % 2.4 2.4 3.0
02, vol. % 16.6 16.6 16.2
CO, vol. % <0.1 <0.1 0.2
Visible emissions, -
% opacity
Particulate emissions
Probe and filter catch
gr/dscf 0.100 0.093 0.121
gr/acf -
Ib/hr 13.1 12.7 16.5
Ib/ton of product 0.124 0.120
Total catch
gr/dscf 0.103 0.100 0.124
gr/acf -
Ib/hr 13.5 13.6 16.9
Ib/ton of product 0.127 0.128
a
Gas-fired plant equipped with a cyclone and a wet scrubber. Production
during test was 106 tons/hr. Data were provided by h State control agency.
75
-------
-------
APPENDIX B. THE ECONOMIC IMPACT OF NEW SOURCE PERFORMANCE STANDARDS UPON
THE ASPHALT CONCRETE INDUSTRY
I. ECONOMIC PROFILE
A. Industry Structure
In 1970, there were ] 3^6 asphalt concrete firms operating an
Y
estimated ^,500 plants in -che United States. Approximately one-third of
the firms operated a single plant and most of the remainder operated less
than five plants.
Integration of activities varies widely from firm to firm. Table B-l
shows the percentage of firms involved in activities that are supplemental
to asphalt batching.
About 75 percent of the plants are permanently installed while
the remainder are considered portable. Permanent plants are primarily
located in urban areas wheia there is a continuing market for new
paving and resurfacing work. Portable plants are usually involved in
highway paving projects. These plants may be disassembled and relo-
cated to shorten hauling distances as highway construction proceeds.
Plant capacities generally fall within the range of 50 to 300 tons
per hour with an average capacity of 150 tons per hour. Table B-2 shows
the distribution of plant capacity in 1970.
The average plant employs four persons. The trend in recent years
has been toward the construction of larger plants with a greater degree
of automation.
B. Production
As Figure B-l shows, the production of asphalt concrete has increased
at an annual rate of 7 percent over the last ten years. Although
growth has been cyclical, it is expected that this average growth rate
will approximate 5 percent in the near future.
C. Capacity
Complete capacity data for the industry is not available. The average
plant operates only 1500 hours a year at an average operating capacity
of 50 percent. Inclement weather, inefficiencies in truck scheduling^
time consumed in relocating portable plants, and the fact that the
industry operates on a project basis are factors that contribute to
the low operating ratio in this industry.
D. Consumption
Table B-3 outlines the consumption of asphalt concrete by market
type over the last five years. With the interstate highway system
nearing completion, the percentage of the total asphalt concrete con-
sumed by this market has fallen off in recent years. It is expected,
77
-------
TABLE B-1
INTEGRATION OF COMPANY ACTIVITIES - 19701
ACTIVITY PERCENT OF COMPANIES
Places (lays) asphalt concrete 86.0%
Contractor for road construction 84.0
Contractor for other construction 54.5
Own gravel pit or quarry 46.3
Produces Portland cement concrete 18.3
Distributes Liquid Asphalt 18.1
Based on a sample of 387 of the 1846 companies operating in 1970 (Ref. 7)
78
-------
5x108
4x108
3 x 108
O
S3
i
D.
2 x 10«
1958
1972
TIME, years
Figure B-l. Asphalt concrete production, 1958-1972 (source: NATA),
79
-------
TABLE B-2
DISTRIBUTION OF PLANT CAPACITY IN 19701
CAPACITY (Tons/Hour) PERCENT OF PLANTS
less than 120 15.5%
120-239 67.2
240-299 10.6
300 or greater 6.7
100.0
1 Based on a sample of 1025 of the 4450 plants operating in 1970 (Ref. 7).
80
-------
TABLE B-3
CONSUMPTION OF ASPHALT CONCRETE BY MARKET TYPE
Market Type
Interstate Highways
State (other than Interstate)
Municipal & County
Airports
Private & Commercial
Other
TOTAL
1966
39.8
77.4
42.0
6.7
39.8
15.4
221.1
1967
30.2
73.5
49.7
6.5
49.7
6.5
216.1
1968
37.6
85.3
52.7
10.0
60.2
5.0
250.8
1969
NA
NA
NA
NA
NA
NA
NA
1970
40.4
102.6
74.7
12.4
74.7
6.2
311.0
CONSUMPTION OF ASPHALT CONCRETE BY CONSTRUCTION CATEGORY
Category 1966 1967 1968 1969 1970
New Construction 137.1 121.0 145.5 NA 158.6
Resurfacing 84.0 95.1 105.3 NA 152.4
TOTAL 221.1 216.1 250.8 NA 311.0
Source: Ref. 7
81
-------
however, that the maintenance of the interstate system will keep the
absolute consumption of asphalt concrete by this market at about its
current level.
While the interstate consumption has leveled off, growth in other
markets (especially municipal and country roads and private and com-
mercial projects) has been very strong and this trend is expected to
continue. The ratio of resurfacing work to new construction is
another significant change in market-mix that has .been occurrine in
recent years. As Table B-3 shows, resurfacing has grown from 38 per-
cent of the market in 1966 to 49 percent in 1970 and this pattern la
also expected to continue.
E, Prices
A recent ten state survey showed asphalt concrete prices at approxi-
mately $8/ton. However, there is wide variation on either side of this
figure.
F. New Units
As previously mentioned, plants constructed recently have tended to
be larger than older plants. Table B-lt shovs the capacity distribution
for a sample of new plants built since 1968. The average capacity
of these plants is 240 tons per hour. By assuming a 5 percent growth
rate and assuming that new plants will average 240 tons per hour in
capacity at the historical operating ratio, it was estimated that about
90-100 new plants will be constructed each year over the next several
years in order to meet the increased demand for asphalt concrete. In
addition, the industry estimates that some 50 new plants will be built annually.
to replace obsolete plants. Thus, approximately 150 new plants each year would
become subject to the proposed new source performance standard.
.II. CONTROL COSTS
A. Introduction
A "model" plant approach has been used to evaluate the probable
costs and economic impact that would occur as a result of the proposed
standard. Capital investment requirements and operating statements
have been approximated for plants representative of new installations
82
-------
TABLE B-ij.
DISTRIBUTION OF CAPACITY FOR NEU PLANTS2
CAPACITY (Tons/Hour) PERCENT OF PLANTS
less than 120 0
120-239 43.7
240-299 25.0
300 or greater 31.3
100.0
2
Based on a sample of 16 plants installed since 1968.
83
-------
in the industry. Costs to meet various levels of air pollution control
were then estimated to determine the economic impact. An effort was
made to determine the difference in costs and impact for a new plant
meeting the proposed standard over and above the costs and impact that
vould result from compliance with a typical state or local regulation.
B. Model Plants
Two model plants have been developed for cost and financial
analysis. The characteristics assumed for these model plants are
outlined in Table B-5.
C. Control Strategies and Costs
For each of the model plants defined above, costs were developed
for three different air pollution control systems. Control Strategy
1 consists of a fabric filter and required auxiliary equipment capa-
ble of complying with the proposed standard. Control strategy 2 con-
sists of a venturi scrubber and required auxiliary equipment (including
water treatment) also designed to comply with the proposed standard.
Control Strategy 3 consists of a multiple-centrifugal scrubber and
required auxiliary equipment capable of complying with the process
weight regulation guideline published in the Federal Register of
August 1**, 1971 (36 FR 15^96). This regulation is less stringent than
the proposed standard and is fairly representative of the type of state
and local standards to which new plants are subject in the absence of
the proposed standard.
The model plant control costs appear in Table B-6 and B-7- The
derivation of these cost estimates is outlined below:
Control Strategy 1
The cost of purchasing and installing fabric filter control systems
for the model plants were derived from a report prepared by the Indus-
trial Gas Cleaning Institute. The actual data appearing in that report
are shown in Table B-8 along with the adjustments made to the raw
data to make them applicable to the model plants being considered.
First, the Industrial Gas Cleaning Institute (IGCI) estimates include
the cost of cyclone separators. Since these devices are normally
installed for economic reasons, that cost was deducted from the IGCI
84
-------
TABLE B-5
MODEL PLANT CHARACTERISTICS
Mixer Capacity
Plant Investment (without control equipment)
Annual Hours of Operation
Average Operating Efficiency
Annual Production
Average Selling Price/ Ton Product
Annual Sales
2
Gas Conditions at Cyclone Outlet
gas volume
temperature
particulate loading
particulate loading
Model A
150 Tons/Hour
$284,000
1500 Hours
50%
112,500 Tons
$8.00/Ton
$900,009
25,000 ACFM
350°F
1500 Ib/hour
7.0 gr/ACF
Model B
300 Tons/Hour
$354,000
1500 Hours
50%
225,000 Tons
$8. 00 /Ton
$1,800,000
50,000 ACFM
350°F
3000 Ib/hour
7.0 gr/ACF
T"rom Figure B-2.
2
In each case, it was assumed that the fugitive dust sources (storage hoppers,
elevators, vibrating screen, and weigh hopper) would be vented along with
the exhaust from the rotary kiln dryer to a cyclone separator with an effi-
ciency of 75 percent. The cost of this device is not included as air pollution
control equipment since it is used to economically return material to the
process. Gas volumes were derived from Figure B-3; temperature and
particulate loadings were derived from data in reference 5-
85
-------
TABLE B-6 - MODEL A
Mixer Capacity = 150 Tons/Hour
Annual Production = 112,500 Tons
Initial Investment = $284,000
Fabric Filter A/C Ratio =6.5
Inlet Conditions
Gas Volume
Temperature
Particulate Loading
Particulate Loading
Outlet Conditions
Gas Volume
Temperature
Particulate Loading
Particulate Loading
Efficiency
Equipment Cost'
Device
Auxiliaries
Total Equipment
Installation ,
Total Installed Cost
Annual Cost
Labor
Materials
Utilities
Dust Disposal
Recovered Material
Depreciation
Interest & Property
Taxes
Total Annual Cost
i/Ton Product
i if/Ton Product
« Additional Investment
A % Over Strategy 3
Control Strategy 1
Fabric Filters
W/0 Dust Rec:
25,000 ACFM
350°F
1500 Ib/hr
7.0 GR/ACF
24,700 ACFM
340°F
2.8 Ib/hr
0.013 GR/ACF
99.8
38,600
9,000
47,600
20,400
68,000
3,800
2,000
2,500
2.8002
6,800
6,800
24,700
22.0
-------
TABLE B-T - MODEL B
Mixer Capacity = 300 Tons/Hour
Annual Capacity = 225,000 Tons
Initial Investment = $354,000
Fabric Filter A/C Ratio =6.5
Inlet Conditions
Gas Volume
Temperature
Parti cul ate Loading
Parti cul ate Loading
Outlet Conditions
Gas Volume
Temperature
Parti cul ate Loading
Parti cul ate Loading
Efficiency
Equipment Cost
Device
Auxiliaries
Total Equipment
Installation
Total Installed Cost
Annual Cost
Labor
Materials
Utilities
Dust Disposal
Recovered Material
Depreciation
Interest & Property
Taxes
Total Annual Cost
*/Ton Product
A */Ton Product
% Additional Investment
A % Over Strategy 3
Control Strategy 1
Fabric Filters
W/0 Dust Rec
50,000 ACFM
350°F
3000 Ib/hr
7.0 GR/ACF
48,200 ACFM
340 °F
5.4 Ib/hr
0.013 GR/ACF
99.8
57,900
11,600
69,500
29,200
98.700
5,000
4,000
5,000
5.6002
a, 900
9.900
39,400
17.5*
2.10
27.9%
5 1%
With Dust Rec
50,000 ACFM
350°F
3000 Ib/hr
7.0 GR/ACF
48,200 ACFM
340 °F
5.4 Ib/hr
0.013 GR/ACF
99.8
57,900
21,700
79,600
31,100
110,700
5,000
4,000
5,200
(3.800)3
11,100
11,100
32,600
14.5*
(0.9*)
31.3%
7.9%
Control
,_ Strategy 2
Venturi Scrubber
50,000 ACFM
350°F
3000 Ib/hr
7.0 GR/ACF
41 ,000 ACFM
150°F
4.6 Ib/hr
0.013 GR/ACF
99.8
19,200
29,300
48,500
47,600
96,100
3,000
800
10,100
10.1004
9,600
9,600
43T2UO
19.2*
3.8*
27.1*
4.5%
Control
Strategy 3
Multi -Centrifugal
Scrubber
50,000 ACFM
350°F
3000 Ib/hr
7.0 GR/ACF
41 ,000 ACFM
150°F
^3 Ib/hr
0.12 GR/ACF
98.3
14,500
20,700
35,200
41 ,400
76,600
3,000
800
5,300,
10, TOO4
7,700
7,700
34,600
15.4*
21.6%
2
Adjusted from 1971 to April 1973 using CE Index (141.8/132.2).
Dust disposal @ 2.5*/ton product.
1122 tons recovered/year at $3.40.
1122 tons disposed of at 4.5*/ton product.
87
-------
estimates. Secondly, the IGCI estimated costs for portable equipment
which they claim increases costs by about 10 percent over stationary
equipment. Since the model plants under consideration are stationary,
10 percent was deducted from each cost element to discount the porta-
bility aspect. The adjusted costs were then plotted against gas volume
(see Figure B-U) and installed costs of $68,000 for Model A
and $98,700 for Model B were obtained from this plot.
These estimates were compared with actual expenditures for
fabric filter control systems reported by asphalt batching plants.
The data received from the plants was updated to 1973 dollars using
Reference 1 and plotted against gas volume (see Figure B-5).
As this plot shows, the costs estimated for the model plants agree
quite cl
-------
Control Strategies 2 and 3
Purchase and installation costs for the wet scrubbing systems were
also obtained from the IGCI report . The data appearing in that report
are presented in Table B-9. This data was adjusted against
gas volume, and the installed costs of wet scrubbing systems for the
model plants are presented in Table B-10.
The capital costs of sludge ponds were estimated separately and
added to the installed costs of the wet scrubbing system in Table B-10. It
was assumed that the following storage capacities were required:
Venturi Scrubber Multi-Centrifugal Scrubber
Model A 20,000 gallons 5,000 gallons
Model B 45,000 gallons 11,000 gallons
The settling pond capital costs were estimated from two references '
and it was assumed that one-half of this cost was for equipment purchase
and one-half for installation.
Annual expenses for labor, materials, and utilities were estimated
9
from data in Control Techniques for Particulate Air Pollutants . The
following cost factors were applied:
labor: $.06/CFM-YR
Electricity: $.015/KWH
water: $.50/1000 Gallons
The power requirements assumed for the wet scrubbing systems (fans
and pumps) are as follows:
Venturi Scrubber Multi-Centrifugal Scrubber
Model A 250 H.P. 150 H.P.
Model B 400 H.P. 250 H.P.
It was assumed that both plants would operate 1500 hours per year
and that make-up water would amount to 10 percent of the recirculation
rate (15 gallons/1000 CF for venturi scrubbers; 5 gal/1000 CF for multi-
centrifugal scrubbers).
Periodic dredging of the settling pond and final disposal of the
material collected by the scrubber is required when wet scrubbing
systems are used. Industry sources state, this cost runs about 4.5
-------
Annual depreciation, interest, and property taxes were estimated
under the same assumptions described for the fabric filter calculations.
The annual control costs per ton of product were calculated to be
$.22 f°r Model A, Control Strategy 2; $.18 for Model A, Control
Strategy 3; $.19 for Model B, Control Strategy 2; and $.15 for Model
B, Control Strategy 3.
D. Discussion
Some conclusions may be drawn from the costs estimates appearing
in Tables B-6 and B-7. Either the fabric filter or the venturi scrubber
will enable a new plant to comply with the proposed standard and
neither the capital costs nor the annualized costs for these devices
appear to be signficantly different. Therefore, local conditions at
the individual plant site will probably dictate the choice of control method.
The costs of a fabric filter system should be compared to the costs
of a multiple-centrifugal scrubbing system (capable of achieving a
typical state or local regulation) in order to measure the incremental
costs that the proposed standard would impose upon a new plant. As
Table B-6 shows, a fabric filter system for the smaller plant would
necessitate 10 percent additional capital investment over a medium
efficiency scrubber. On an annualized basis, however, the incremental
cost amounts to only 3 cents per ton of product which is not
significant.
The incremental investment required for the larger plant (Table B-7)
is 8 percent and the annual costs are slightly less for the fabric
filter than for the medium-efficiency scrubber. Capital and annualized
costs apparently increase more rapidly for the scrubber than for the
fabric filter as plant capacity is increased. This suggests that large
90
-------
plants might find it economical to install fabric filters rather
than scrubbers just to meet existing state and local regulations.
Indeed, among the larger plants installed in recent years, the
fabric filter has been by far the most common control system selected.
It is important to note again that new plants are expected to be, on
the average, much larger than the average existing plants and many
of these would undoubtedly install fabri . filter collectors even in
the absence of the proposed standard.
III. ECONOMIC IMPACT
The economic impact can be measured bv considering the incremental
cost of meeting the proposed standard compared to the costs incurred in
the absence of the proposed standard. Since EPA has promulgated ambient
air quality standards for particulates, each state has established
emission standards for this pollutant and any new plant must comply.
Most state standards can be met by using a low-energy scrubber as detailed
under Control Strategy 3 in Tables B-6 and B-7. The difference in jost
between this strategy and Control Strategies 1 or 2 represents the
incremental cost of control. Since many states have tighter regulations,
the low-energy scrubber problem reflects the "worst case" situation.
On an annualized cost basis, it appears that the fabric filter is
the lesser-cost device for both plant sizes. The key element is that
the fabric filter collects the particulate material in a useful form
while the material collected by the scrubber must be disposed of at the
operator's expense. Thus, it may be assumed that most new plants would
favor a fabric filter control system when selecting a control system to
comply with the performance standard. This assumption is further
substantiated by the trend of control equipment installed since 1968.
Information was supplied by industry which showed that about 3 percent
of the collectors installed in 1968 were fabric filters, while about
65 percent of the collectors installed in 1972 were fabric filters.
-------
The installation of a fabric filter on the smaller plant necessitates
an increase in capital investment of 28 percent over the base-plant
investment. However, the incremental investment required to equip the
plant with a fabric filter rather than a low-energy scrubber (to comply
with most state standards) is about 10 percent. Similarly for the larger
plant, the additional capital investment required by the fabric filter
over the base-plant investment is 31 percent, while the incremental
investment over equipping the plant with a low-energy scrubber is 8 percent,
It is not possible to say that, in all situations, the proposed
standard will not create any additional financing problems. It is our
judgment, though, that the incremental investment required by the
proposed standard is in general not anticipated to create any serious
additional financing problems for new asphalt concrete plants.
The Economics of Clean Air, 1972, concluded that asphalt concrete
plants meeting state emission standards should be able to increase prices
to cover the added cost of pollution control. Since the annual control
cost for a new plant meeting the proposed standard closely approximates
the cost for an existing plant meeting a typical state standard, our
judgment was that a new plant would not be placed at a competitive
disadvantage.
These judgments have been reinforced by the industry association's
public comments that were submitted to EPA on July 2^, 1973. On page ^9
of their comments they stated:
The National Asphalt Pavement Association, as it has indicated
on many occasions to EPA, submits that the legitimate goal of
protecting the environment and reducing emissions will be achieved
by the imposition of a . 06 standard rather than the .031 standard.
It is submitted by the industry that this will result in an
improvement of the emission levels by 99-8%, and is consistent
with the goal which has been stated, of 99-7$ *>y the Environmental
Protection Agency. Further, it is submitted that the reduction
is achievable at a reasonable cost without unduly endangering the
existence of the industry or forcing the use of other alternative
products. Thus, it is submitted that it is important that the
standard be .06 and not .031.
92
-------
,It is important that it be recognized that if the standard is
.06, the equipment which will be required to be purchased will
be either a venturi scrubber with a minimum 20-inch pressure
drop or a baghouse with a 6-to-l air-to-cloth ratio. It is
submitted that there will be a significant improvement in the
environment with an .06 standard. The . 06 standard will further
require that the plants be kept in good operating repair and
condition or they will fail to meet the . 06 standard. A .06
standard will avoid the problems of the size and shape of the
particulates and also other problems which cannot be answered
at the present time.
NAPA's conclusion is that the cost for a venturi scrubber with a
20-inch pressure drop or a baghouse with a 6-to-l air-to-cloth ratio
is reasonable. It is EPA's contention this equipment will achieve our
proposed standard. Thus, NAPA's conclusion that cost for this type of
equipment is reasonable reinforces our Judgment that the cost to meet
the proposed standard is reasonable.
93
-------
TABLE B-8
ESTIMATED CAPITAL COSTS AND ADJUSTMENTS FOR FABRIC FILTERS
(Source: Ref. 5)
Gas Cleaning Device Cost (IGCI Report.)
Adjustment for cyclone
Adjustment for portability
Adjusted Gas Cleaning Device Cost
Auxiliaries Cost (IGCI report)
Adjustment for portability
Adjusted Auxiliaries Cost
Installation Cost (IGCI report)
Adjustment for portability
Adjusted Installation Cost
TOTAL COST
C.E. Plant Cost Index (141.8/132,2)
TOTAL ADJUSTED COST
Plant
30,600 ACFM
$49,901
(4,800)
(4,510)
$40,591
$10,046
(1,005)
$ 9,041
$23,687
(2,369)
$21,318
$70,950
1.073
$76,129
Size
42,900 ACFM
$61,160
(6,600)
(5,456)
$49,104
$11,544
(1,154)
$10,390
$28,485
(2,849)
$25,636
$85,130
1.073
$91,344
94
-------
TABLE B-9
ESTIMATES CAPITAL COSTS OF WET SCRUBBERS
(Source: Ref. 5)
Control Strategy 2
Gas Cleaning Device Cost
Auxiliaries Cost
Installation Cost
Total Cost
CE Index (141.8/132.2)
(Scale Exponent Is 0.75)
Control Strategy 3
Gas Cleaning Device Cost
Auxiliaries Cost
Installation Cost
Total Cost
CE Inde» (141.8/132.2)
Total Adjusted Cost
(Scale Exponent is 0.65)
TABLE B-10
SLANT SIZE
30,600 ACFM
$12,181
13,062
27,360
$52,603
xl.073
$56,443
$ 9,975
11,013
26J.57
$47,145
xl.073
$50,587
42,900 ACFM
$15,930
18,210
33,571
$67,711
xl.073
$72,654
$12,229
14,539
31,934
$58,702
xl.073
$62,987
ESTIMATED CAPITAL COSTS OF WET SCRUBBERS
(ADJUSTED TO EPA MODEL PLANT SIZE)
PLANT SIZE
25.000 ACFM 50.000 ACFM
Control Strategy 2
Gas Cleaning Device Cost
Auxiliaries Cost
Installation Cost
Sludge Pond Cost Plus Inst.
Total
Control Strategy 3
Gas Cleaning Device Cost
Auxiliaries Cost
Installation Cost
Sludge Pond Cost Plus Inst.
Total
$11,200
'12,000
25,200
8.900
$57,300
$ 9,300
10,100
24,400
3,900
47,700
$19,200
22,000
40,400
14.500
$96,100
$14,500
17,500
38,300
6.300
76,600
95
-------
5 x 105,
4 x 1(4
o
MODEL B
i
5
2 x10H
MODEL A
0 = PLANTS VISITED DURING STUDY
102
4 x 10* 5 x 10*
2 x 102 3 x 102
PLANT CAPACITY, tons/hour
figure B-2, Base,plant investment versus plant capacity
(aajusted to April^i973 dollars).
96
-------
105
o
5x104
14 x 10*
f
>
= 3x104
2x10*
10*
102
0 = PLANTS VISITED DURING STUDY
2x102
3 x 102 4 x 102 5 x ifl2
103
CAPACITY, tons/hour
Figure 3-3. Gas volume versus plant capacity. (Source: Asphalt
concrete plants visited during study.)
97
-------
2xl05
105
5xl04
2xl04
MODEL B
MODEL A
0 = PLANTS VISITED DURING STUDY
104
2x10*
5x104
105
GAS VOLUME, acfm
Figure B-l*. Estimated capital costs of fabric filters
versus gaa volume. (Source: Adjusted data from IGCI report.)
98
-------
2x105
0 = PLANTS VISITED DURING STUDY
o
o
1 105
5 x 10*
°!
10
15
20
25
30
50
60 70
90 100
GAS VOLUME, 1000 acfm
Figure B-5. Reported capital costs of fabric filters versus
gas volume. (Source: Asphalt "batching plants visited during
study; costs adjusted to 1973 dollars ty index in Her. l.J
99
-------
REFERENCES
1. "Chemical Engineering", CE Plant Cost Index.
2. Environmental Engineering, "Background Information for the Establish-
ment of National Standards of Performance for New Sources", 1971.
3. Bituminous Construction Handbook, 1970, Barber, Greene Company.
4. GCA Corporation, Handbook of Fabric Filter Technology, 1970.
5. Industrial Gas Cleaning Institute, Air Pollution Control Technology
and Costs in Nine Selected Areas, Special Interim Report, 1971.
6. Journal of the Air Pollution Control Association, "Air Pollution Control
Practices for Hot-mix Asphalt Paving Batch Plants", 1969.
7. National Asphalt Paving Association; Hot Mix Asphalt-Plant and Production
Facts; 1966, 1967, 1968, and 1970.
8. National Asphalt Paving Association, private communication.
9. National Air Pollution Control Administration, Control Techniques for
Particulate Air Pollutants, 1969.
10. United States Internal Revenue Service, private communication.
11. Popper, Herbert, Ed. Modern Cost-Engineering Techniques, 1970,
McGraw-Hill.
TOO
-------
APPENDIX C. THE ECONOMIC IMPACT OF NEW SOURCE PERFORMANCE
STANDARDS UPON PETROLEUM REFINERIES
I. INTRODUCTION
The proposed new source performance standards pertaining to both
petroleum refinery fluid catalytic cracking units and the burning of
gaseous refinery fuels generate control costs that are higher on a per-
barrel basis for the smaller refineries than for the larger refineries.
This disparity in per-barrel control costs raises the question of the
degree of economic impact upon the smaller refiners relative to the
larger refiners. The complexity of the situation is compounded by the
fact that new and modified refineries will also be subject to costs for
controlling water pollution and costs to remove lead from gasoline as well
as the costs for controlling air pollutants. These environmental cost
pressures, coupled with potential domestic shortages of petroleum products,
necessitated a study of the economic impact of projected pollution abate-
ment requirements upon the domestic petroleum refining industry, with
particular emphasis being given to the small refiner. It should be noted
that normal economies of scale in the refining industry appear to preclude
any new small refineries. Modifications, however, to existing small
refineries are always a possibility. Since control costs for new large
refineries do not appear to be large enough to adversely impact upon con-
struction of new large refineries, this analysis should mainly be interpreted
in light of the effects of the proposed new source performance standards
upon modified small refineries.
II. CONTROL COSTS - NEW SOURCE PERFORMANCE STANDARDS ONLY
Annualized control costs, on a per-barrel basis, for compliance with the
proposed new source performance standards will vary inversely with refinery
size. This is due to the fact that total control costs for control of the
fluid catalytic cracking unit and the refinery fuel gas hydrogen sulfide
emissions do not decrease as rapidly as the decrease in refinery size. Table
C-l illustrates this situation.
TABLE C-l. PETROLEUM REFINERY CONTROL COSTS
(New Source Performance Standards Only)
Capital Costs Annualized Costs
Refinery
Size
5,000 BCD
10,000
50,000
100,000
Fuel
Gas
$560M
590
900
1200
Cat.
Cracker
0*
350
785
1150
Total
$560M
940
1685
2350
Fuel
Gas
$185M
200
365
530
Cat.
Cracker
0*
67
147
213
Total
$185M
267
512
743
104/bb'
7t
3t
2
-------
The basic assumptions underlying Table C-l are as follows:
1. Capital costs represent installed equipment.
2. Annualized costs include operating and maintenance costs plus
capital charges at 15.7 percent of capital.
3. The fuel gas control system consists of an amine treating unit
and a 3-stage Claus sulfur plant.
4. The catalytic cracker control system consists of an electrostatic
precipitator. The precipitator is designed for 300 square feet
of collection plate area per thousand actual cubic feet of gas
per minute.
5. The catalytic cracking unit is sized at 30 percent of the total
refinery size.
6. Annualized costs do not include any credits for recovered material.
7. The sulfur content of the crude oil being processed is 0.5 percent.
8. The percentage of sulfur in the crude oil that reverts to the fuel
gas is 45 percent.
Table C-l shows that annualized control costs for a 5,000 barrel
per calendar day (BCD) refinery amount to 10£ per barrel of finished
product whereas the annualized control costs for a 100,000 BCD refinery are
2<£ per barrel of finished product. The smaller refiner, therefore, is
experiencing an 8£/bbl cost penalty relative to the larger refiner.
It should be noted that Table C-l does not take into account
those production situations in which a refiner would remove the hydrogen
sulfide from the fuel gas even in the absence of emission control regula-
tions. In cases like this the cost of hydrogen sulfide removal would
not be considered an emission control cost and the impact of the regulations
upon the refiner would be decreased considerably.
III. CONTROL COSTS - TOTAL CONTROL REQUIREMENTS
The costs for control of air pollutant emissions from new source
petroleum refineries are not the only environmental costs being incurred
in the petroleum industry. In addition, the domestic refining industry
is facing costs for control of water pollution and costs for removing
lead from gasoline. These costs will also tend to impact more severely
upon the small refiner than the larger refiner. Table C-2 presents an
estimate of the per-barrel annualized costs for control of air and water
emissions and for removing lead from gasoline.
102
-------
TABLE C-2. ANNUALIZED CONTROL COSTS
(Total Environmental Requirements)
Refinery Size Air Water Lead Total
5,000 BCD 10*/bbl 17 12 39
-------
3. Lead removal costs based upon conversion of 50 percent of the crude
oil input to gasoline. Higher conversion factors would increase
the cost impact of the lead removal regulation whereas lower conver-
sions would lessen the overall economic burden.
IV. ECONOMIC IMPACT - TOTAL CONTROL REQUIREMENTS
The profit margins of small domestic refiners are believed to vary
widely due to numerous factors such as location relative to both crude
supplies and finished product markets, individual operating economies,
and specialized markets. A gross estimate of average small refiner
profitability is approximately l/2
-------
The purpose of the fee system, as quoted in the Federal Register
referred to above, is "to discourage the importation into the United States
of petroleum and petroleum products in such quantities or under such cir-
cumstances as to threaten to impair the national security; to create conditions
favorable, in the long range, to domestic production needed for projected
national security requirements; to increase the capacity of domestic refineries
and petrochemical plants to meet such requirements; and to encourage Invest-
ment, exploration, and development necessary to assure such growth." Encourage-
ment of domestic production was deemed necessary due to the increasing trend
in this country to import petroleum products. A projection of domestic supply
and demand that was prepared prior to the announcement of the Import License
Fee System by the National Petroleum Council is presented in Table C-4.
TABLE C-4. U.S. PETROLEUM SUPPLY AND DEMAND
(Thousands of Barrels/Day)
1973 1975 1980 1985
Total U.S. Product Demand 17,600 19,800 22,500
Product Output-/ 12,725 13,257 15,115
Excess Demand 4,875 6,543 7,435
% of Total Demand 28% 33% 33%
- Output at 96-97% of total domestic refinery capacity.
It is believed that the Import License Fee System will spur domestic
refinery construction but that the United States will still be a net importer
of petroleum products at least through 1985. The impact of the fee system
on domestic prices will be to increase finished product prices by 63^/bbl
in 1975, assuming that price controls are no longer in effect at that
time. The reasoning behind this conclusion is based upon the shortage of
domestic refining capacity that is projected to exist through 1985. A
producer who imports finished products would be expected to raise his
prices to cover the import fee. Since all refiners are operating essentially
at capacity there is no incentive for a competing refiner to keep his prices
low relative to the producer that imports petroleum products since he will
not generate any additional sales by doing so. This means that domestic
prices will rise by an amount equal to the import fee, or 63<£/bbl. Note
that this mechanism will occur only in the case where domestic refineries
are being utilized essentially at capacity.
105
-------
The same type of mechanism may also occur in the area of crude supplies,
with crude prices rising by the amount of the import fee, or 21£/bbl. This
means that domestic refining profits would increase by a net amount of
42tf/bbl. It is altogether possible, however, that domestic crude prices,
particularly for the smaller, inland refiners who are in close proximity
to adequate crude supplies, will not be increased by 21
-------
unit burned refinery fuel gas it would be subject to the proposed new
source performance standards and their attendant costs. These costs could
be large enough to make the modification uneconomic. If additional output
was obtained as a result of the modification, however, this output could be
sold at a net premium of 42-63<£/bbl under the situation created by the Import
License Fee System. Since compliance costs resulting from the new source
performance standards are less than this amount there appears to be no
barrier to refinery modifications due to the proposed new source performance
standards, even for small refiners, as long as additional output is obtained.
Returning to the situation where no additional output is obtained, it
is still highly possible that there would be enough flexibility in the
refinery fuel supplies so that a fuel other than refinery fuel gas could
be burned in the new process unit. In this situation the new source per-
formance standard would not apply and no adverse economic impact would be
experienced by the refiner. It seems that this situation could easily be
the case for those refineries that modify their facilities in order to
produce unleaded gasoline.
107
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-------
APPENDIX D. LIST OF COMMENTATORS
Comment number
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
Commentator
Rosenstern
Deemer
Spaeth
Gilliland
Sheehan
Not a comment
Wainer
Scares
Feldman
Moore
Todd
Holland
Fleischman
Plummer
Nespeco
Simmons
Simmons
Madison
Bury
Vanderlinden
Moore
Schofield
Hilton
Kelley
Phillip
Males
Broce
Anthony
Busch
Yocum
Valentine
Smith
Kirkby
Dickinson
Johnson
Affiliation
Koppers Co., Inc.
McCarter Corp.
Bulk Terminals Co.
Ideal Cement Co.
American Lung Association
(determined after numbering)
Wainer Brothers, Inc.
White's Mines, Inc.
Lake-River Terminals
Moore Brothers Construction
Percy Todd Mfg., Co.
Holland Construction
County Asphalt Co.
E.D. Plummer Sons
National Oil Fuel Inst.
Flatiron Paving
Eastern Industries
Lehman-Roberts Co.
Midwest Asphalt Corp.
Midstate Contractors, Inc.
Associated General Contractors
Gen. Am. Transportation Corp.
Gulf Asphalt Corp.
MacDougaId-Warren, Inc.
Songamo Construction
Henley-Lundgren Co.
Broce Construction Co.
Washita Construction Co.
Ready Mix Sand & Gravel
Hinkle Contracting
Peter Kiewit Sons Co.
Pike Industries
S.E. Johnson Co.
Rust Engineering Co.
Rohm and Haas Co.
109
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APPENDIX D. LIST OF COMMENTATORS (continued)
Comment number Commentator Affiliation
36 Strain Strain Brothers, Inc.
37 Donovan M.F. Roach Co.
38 Hamn Texas Asphalt Pavement Assn.
39 Fry Miami Asphalt Corp.
40 Babler Babler Bros., Inc.
41 MacRitchie A.S. Langenderfer
42 Stricklin Hadley Construction Co.
43 Chleboski Allegheny County Health Dept.
44 Heldenfels Heldenfels Bros.
45 Brooks Brooks Construction Co,,
46 Berry L.A. Reynolds, Co.
47 Docter Maclair Asphalt Co.
48 Lemon Lemon Construction Co.
49 Kersey Derby Refining Co.
50 Teglia Paving Mix & Construction Co._
51 Masters Industrial Asphalt
52 Snyder Buffalo Slag Co.
53 Azzarelli Azzarelli Construction Co.
54 Brooks Brooks and McConnell
55 Richardson Macasphalt Corp.
56 Not a comment (determined after numbering)
57 Kowalik Gulf Oil Co.
58 Duininck Duininck Bros. & Gilchrist
59 Gibb Interstate Amiesite Corp.
60 Masters Industrial Asphalt
61 Decker Rein, Schultz, & Dahl
62 Levine Alabama Dept. of Public Health
63 Smith Entropy Environmentalists, Inc.
64 Carter Carter Co., Inc.
65 Mathis Mago Construction Co.
66 Martinez-Lazaro Puerto Rico Asphalt Co.
67 Acquaviva O'Keefe Asphalt Products
68 Darnell Washington Asphalt Co.
69 Vosti Reed and Graham, Inc.
70 Skogsberg North American Car Corp.
71 Chavez Assn. de Pavimentos Asfalticos
72 Schultz Sherwin Corp.
73 Rath Rason Asphalt, Inc.
110
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APPENDIX D. LIST OF COMMENTATORS (continued)
Comment number
74
75
76
77
78
79
80
81
82
83
84
85
86
87
88
89
90
91
92
93
94
95
96
97
98
99
100
101
102
103
104
105
106
107
108
109
Commentator
Echstenkamper
Childress
Fehsenfeld
O'SulUvan
Eaton
Dlckson
Ashmore
Chavez
Yarbrough
Phelan
Frampton
Waller
Knott
McCarthy
Chadbourne
Eccles
Mims
Clark
Bennett
Kuhn
Huelsen
Buschman
Sloan
Vickers
Weers
Robins
Smith, Reed
Barcklay
Farrel1
Brower
O'Kane
Kowalik
Minor
Bartus
Moore
Keller
Affiliation
Plant Mix Asphalt Industry
Quapaw Company
Crystal Flash Petroleum
N.Y. Bituminous Concrete Producer
Dixie Asphalt Co.
Lige Dlckson Co.
Ashmore Mfg., Co.
Betteroads Asphalt Corp.
University Asphalt Co.
California Asphalt Pavement Assn.
Empire Construction, Inc.
Cornell Construction Co.
Johnson County Asphalt, Inc.
McCarthy Improvement Co.
E.M. Chadbourne, Inc.
Gibbons & Reed Co.
J.F. Cleckley & Co.
Manufacturing Chemists Assn.
Rissler & McMurry
Columbus Bituminous Concrete Corp.
American Foundrymen's Society
Texas Mid-Continent Oil & Gas Assn.
Sloan Construction Co.
Florida Asphalt Paving Co.
Westinghouse Electric Corp.
Georgia Office of Planning and
Budget
Jimar Paving Co.
Washington State Assn. of County
Engrs.
Fitzgerald Bros. Construction Co.
Brower Construction Co.
Stahl Construction Co.
Gulf Oil Co.
Asphalt Paving Assn. of Washington
Bar-Coat Blacktop Co.
Texas Eastern Transmission Corp.
Oklahoma Asphalt Pavement Assn.
Ill
-------
APPENDIX D. LIST OF COMMENTATORS (continued)
Comment number
Commentator
no
in
112
113
114
115
116
117
118
119
120
121
122
123
124
125
126
127
128
129
130
131
132
133
134
135
136
137
138
139
140
141
142
143
144
145
Crim
Pond
Keating
Lunche
Anony.
Fitzgerald
Ruffer
Huddleston
Bowen
Anony.
Lance
Fulton
Yeargain
Boles
Thelen
Rihm
Arps
Ross
Smith, Robert L
Maudlin
Derr
Best
Appl eby
Cromwel 1
Haddock
Cellini
Cellini
Keller
Denton
Brenholts
Hoene
Swenson
Silverman
Mills
Moore
Virgalitte
Affiliation
Crim Engineering (later revised;
see 206)
Asphalt Products Corp.
P.J. Keating Co.
Los Angeles County APCD
Conn. Bituminous Concrete Producers
Georgia Asphalt Pavement Assn.
Alabama Asphalt Pavement: Assn.
Oregon Asphalt Pavement Assn.
Mississippi Asphalt Pavement Assn.
Michigan Asphalt Pavement Assn.
Asphalt Contractors Assn. of Fla.
Inc.
Flexible Pavements Inc.
Louisiana Asphalt Pavement Assn.
Tennessee Asphalt Pavement Assn.
Wisconsin Asphalt Pavement Assn.
N.Y. State Dept. of Environmental
Conservation
Tri County Asphalt Corp,
Carolina Asphalt Pavement Assn.
Warren Bros. Co.
Brass & Bronze Ingot Institute
Wendel Kent & Co., Inc.
A.I.Ch.E., So. Texas Section
Dover Equip. & Machine Co.
HEW, NIH
Crowell Constructors, Inc.
111. Asphalt Pavement Assn.
111. Asphalt Pavement Assn.
Ok. Asphalt Pavement Assn.
Warren Bros. Co.
Hercules Inc.
Minn. Asphalt Pavement Assn.
Crown Central Petroleum Corp.
Salt River Project
Exxon Co.
Road Builders Inc. of Tenn.
The Standard Slag Co.
112
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APPENDIX D. LIST OF COMMENTATORS (continued)
Comment number
146
147
148
149
150
151
152
153
154
155
156
157
158
159
160
161
162
163
164
165
166
167
168
169
170
171
172
173
174
175
176
177
178
179
180
181
182
Commentator
Heath
Michels
Chapman
Maloney
Ferreri
Funk
Funk
Sprinkel
Babson
Kramer
Gray
Eidemiller
Brook
Anony.
Anony.
Anony.
Banks
Hall man
Harrison
Hanagan
Scott
Doyle
Mull ins
Smith & Brock
Proctor
Mathews
Whalen
Perkins
Ballard
Bury
Coppoc
Bell
Sebastian
Showers
Talbert
Haxby
Ambrosius
Affiliation
Precipitation Assn. of Am., Inc.
Eaton Asphalt Paving Co.
Beckman Instruments, Inc.
Fed. Highway Assn., Dept. of
Transportation
Md., Envirn. Health Administration
Cold River Hot Mix Corp.
Vermont Paving Corp.
Vernon Asphalt Material Corp.
So. Carolina Asphalt Pavement Assn.
Fay, Spofford & Thorndike Inc.
National Asphalt Pavement Assn.
Adam Eidemiller
Wellsboro Asphalt Co.
Burlington Asphalt Corp.
Precipitation Assn. of Am., Inc.
Mix Design Methods, Inc.
Banks Construction Co.
UOP Process Division
Western Oil and Gas Assn.
New Mexico Oil & Gas Assn.
Union Oil Co. of Calif.
Peter Kiewit Sons' Co.
Mullins Bros. Paving Contrs., Inc.
Astec Industries, Inc.
Rea Construction Co.
Couch Construction Co.
Asphalt Materials & Paving Co., Inc.
N. Mexico Envirn. Improvement Agency
Phillips Petroleum Co.
Bury & Carlson, Inc.
Texaco, Inc.
JoB Construction Co.
Envirotech Corp.
Arizona Rock Products Assn.
Agway, Inc.
Shell Oil Co.
Mid-Continent Oil & Gas Assn.,
Ark.-La. Div.
113
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APPENDIX D. LIST OF COMMENTATORS (continued)
Comment number
183
184
185
186
187
188
189
190
191
192
193
194
195
196
197
198
199
200
201
202
203
204
205
206
207
208
209
210
211
212
213
214
215
216
217
218
Commentator
Massey
Gammelgard
Reeves
Leo
Dick
Keller
Oddinger
Parker
Mayes
Goder
Plaks
Bumford
Edwards
Lindstrom
Sterling
Hayes
Bui ley
Gartrell
Valentinetti
McCullough
Shepard
Weston
Reynolds
Crim
Barden
Palmer
Hampton
Williams
Crosby
Anderson
Christy
Hale
Hagerman
Schwellenbach
Christy
Eidemiller
Affiliation
Delaware Asphalt Pavement Assn.
Am. Petroleum Institute
Reeves Construction Co.
Ward Pavements, Inc.
Trumbell Corp.
Bergan Asphalt Corp.
South State Inc.
Pan Am. Construction Co.
Am. Petrofina Co of Texas
Joseph Goder Incinerators
EPA, Metallurgical Processes Section
N.H. Air Pollution Control Comm.
Collier, Shannon, Rill and Edwards
Ala. Dept. of Public Health
Wayne Co. Dept. of Health, Mich.
National Asphalt Pavement Assn.
Wash. State Highway Comm., Dept.
of Highways
TVA, Dir. Envirn. Planning
Vermont, Agency of Environ.
Conservation
Mt. Hope Materials Corp.
Shepard Construction Co., Inc.
Roy F. Weston, Inc.
Atlantic Richfield Co.
Crim Engineering
Texas Air Control Board
Construction Industry Mariu. Assn.
Rocky Mtn. Oil and Gas Assn.
Mid-Continent Oil & Gas Assn.,
Miss.-Ala. Div
Ward Pavements Inc.
Bethlehem Steel Corp.
N.J. Asphalt Pavement Assn.
unknown
unknown
unknown
unknown
Adam Eidemiller, Inc.
114
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APPENDIX D. LIST OF COMMENTATORS (continued)
Comment number
219
220
221
222
223
224
225
226
227
228
229
230
231
232
233
234
235
236
237
238
239
240
241
242
243
244
245
246
247
248
249
250
251
252
253
254
255
Commentator
Rost
Brewer
Graves
Anony.
Anony.
Anony.
Bartholomew
Barrett
Babson
Kukish
Sachse
Gi 11 i am
Brugman
Clarke
Nelson
Kshatriya
Castro
Tantzen
Robinson
LaFave
Ladd
Gray, J. Earle
Fleischhauer
Montgomery
Smith, Robert L
Esola
Ruth
Cady
Hovey
Haino
Bumford
Cramer
Tenney
Jones, Robert
Reynolds
Storlazzi
Smith
Affiliation
Burkholder Pavement Inc.
The Brewer Co. of Fla., Inc.
Pennzoil
National Bituminous Inc.
Allegheny Contracting Industries,
Inc.
Gal low Asphalt Co.
Burrell Construction and Supply Co.
Arawak Paving Co. Inc.
So. Carolina Asphalt Pavement Assn.
Edison Asphalt Co.
Granite Material Corp.
Scott Industries, Inc.
U.S. Oil & Refining Co.
Rohm & Haas Co.
E.D. Etnyre & Co.
Aqua Systems Corp.
Ponce Asphalt, Inc.
Graver Tank & Mfg. Co.
Mallinckrodt Chemical Works
Chicago Bridge & Iron Co.
Getty Oil Co.
Getty Oil Co.
Gietz-Melahn Asphalt Co.
U.S. Congress (Miss.)
Warren Bros. Co. (addendum to 128)
Union Paving Co.
East Kentucky Paving Co.
Allied Chemical Corp.
N.Y. Division of Air Resources
Golden Eagle Construction Co.
N.H. Air Pollution Control Comm.
Standard Oil of Calif.
Buell Envirotech
Donohue & Assoc., Inc.
Atlantic Richfield Co.
EPA, Region I
Entropy Environmentalists, Inc.
115
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-------
APPENDIX E. SUMMARY OF COMMENTS AND RESPONSES PERTINENT TO NEU SOURCE PERFORMANCE
STANDARDS (40 CFR 60) PROPOSED IN FEDERAL REGISTER OF JUNE 11, 1973 (38 FR 15406)
Comment
no.
1-1
Commentator
no.
7, 13, 21, 3V,
41, 44, 47, 54,
57, 67, 69, 73,
74, £0, 82, 84,
Comment
Response
Subpart I. Asphalt Concrete Plants
The asphalt Industry is not a
"significant contributor" to
air pollution in the United
States that endangers or
86, 87, 96, 109, may tend to endanger
117, 127, 147, public health or welfare.
153, 156, 172
186, 211, 245
1-2
110
A joint industry-governnent
task force should be estab-
lished for a state of the art
study of control technology
for asphalt batch plants.
EPA can't objectively assess
the situation.
1-3
82, 86, 153,
156, 186
There should be a public
hearing for the asphalt
Industry.
The Clean Air Act, as amended, directs the Administrator to
promulgate new source performance standards for sources which
he determines may contribute significantly to air pollution,
but it does not provide him with specific criteria or guide-
lines to determine what is significant. Therefore, to make
such a determination, the Administrator must rely upon
judgement. In the case of paniculate matter - a pollutant
for which national ambient air quality standards have been
promulgated - the Administrator considers all sources to con-
tribute to the endangerment of public health or welfare.
The presence of particulate rratter in the air is the result
of numerous diverse mobile and/or stationary sources. Because
ambient concentrations of particulate matter depend upon a
number of factors such as distribution of sources, topography,
height of which the pollutant is emitted, and meteorological
conditions, a source may be considered significant in one
location and not in another. This makes it meaningless to
develop a firm definition of "significant source" that could
be applied nationwide.
The Act provides the Administator of EPA a variety of regula-
tory authorities which may be used singly or in combination
to achieve the purposes of the Act. For particulate matter,
the Administrator has determined that comprehensive air
quality manaoenent strategy is needed to protect public
health and welfare and to enhance the quality of our air
resources. This air quality management strategy is based on
the adoption and enforcement of State implementation plans
approved by the Administrator and on new source performance
standards promulgated by the Adrimstrator. State implementa-
tion plans are designed to achieve and maintain national
ambient air quality standards as required under section 110
of the Act, and new source performance standards are designed
to facilitate the maintenance or national ambient air quality
standards and enhance the nation's air resources as required
under section 111 of the Act. Ideally, the Administrator
should issue new source performance standards for all sources
of particulate matter at one time. This would provide the
maximum degree of enhancement of the nation's air resources.
Clearly, EPA has neither the resources nor information to
establish standards of performance for all sources of parti-
culate matter at one time; therefore, a selection process is
used which helps establish priorities for standard settina.
In this selection process EPA examines uncontrolled emission
rates, proximity to urban areas, stringency of State/local
regulations, number of plants, and growth rates. A comparative
analysis of some 80 sources of particulate matter showed
asphalt concrete plants to be ranked within the first ?0
source categories.
Such a task force is not necessary because the industry
already has had considerable opportunity to present its views
on, and information pertinent to, the proposed standard.
Prior to proposal of the standard, EPA and the National
Asphalt Pavement Association had over 14 meetings to review
progress of the study. The standard was reviewed and approved
by the National Air Pollution Control Techniques Advisory
Committee (NAPCTAC). Review by NAPCTAC provides for input
of opinions from industry, citizens groups, state and local
air pollution control agencies, and members of the academic
community during the standard setting process. This review
provides for an unbiased assessment of the state of the art
of control technology.
Section 111 of the Act provides for informal rule making
wherein all interested parties have full opportunity to
comment upon the proposed standard and its technical basis.
The Agency reviews the comments received and explains in final
rulemaking its reasons for relyino upon or rejecting then.
It is EPA's view that the Act coes not require more. Prior
to proposal of the standard, EPA and the National Asphalt
Pavement Association had over 14 meetings to review progress
of the study. Throughout the entire study, NAPA was kept
117
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APPENDIX E (continued). SUMMARY OF COMMENTS AND RESPONSES PERTINENT TO NEW SOURCE
PERFORMANCE STANDARDS (40 CFR 60) PROPOSED IN FEDERAL REGISTER
OF JUNE 11 , 1973 (38 FR 15406)
Comment Response
Comment Commentator
no. no.
1-4
1-5
1-6
1-7
1-8
1-9
1-10
1-11
156, 169
29, 32, 190
156
55, 71, 78, 80
85, 90, 96,
128, 162, 177,
243
145
44, 52, 93,
106, 109, 118,
153, 201
The asphalt industry was not
provided an opportunity to
participate In the stancard
setting process.
Environmental impact of the
proposed standard was net fully
considered.
EPA did not file an
environmental impact statement
as required by the Naticnal
Environmental Policy
Act (NFPA).
Request, a study on health
effect?, and nuisance value
associated with asphalt
participate emissions.
informed of the progress. At the request of the asphalt
industry, the House Subcommittee on Environmental Problems
Affpctinq Small Business conducted a hearing on October 1,1973.
EPA net with asphalt industry representatives over 14 times
prior to proposing the standard. By submittinj comments
on the proposed standard to EPA during the comment period,
the asphalt industry is again participating in the
standard setting process.
The effects on air, land, and water of the proposed standard
were considered ind are discussed in Volume 1 of this
document.
EPA is not required by NEPA to file an environmental impact
statement. See the court's opinion in Portland Cement
Association v. Wil liam D. Ruckelshaus.
Part^culate emissions from
asphalt plants are not
harmful and are similar
to those from an unpavei road.
Percent reduction in er ssions
is higher for asphalt p arts
than for other industries
covered by a proposed standard.
s tandard.
The standard is more
restrictive than required
to maintain ambient air
quality standards.
1-12
93
Such a study specifically for asphalt particulate emissions is
not appropriate Dr necessary at this time. A health and
we! fare study for particulate matter was published by EPA in
January 1959 Particulate natter was one of the pollutants
for which a national ambient air quality standard was
promulgated. Details are contained in Air Cuality Criteria
for Particulate Batter (AP-49)
All particulate matter, regardless of whether it is
fron an unp<,ved road or an asphalt plant, is considered by
EPA to have an adverse effect on health and welfare as
evidenced bv the fact that a national arrbiert air quality
standard was promulgated fe** it.
The standards reflect perforrance that the best systeir of
enis'irn reduction will attain for a particulate industry.
Industry (haracteristies and control system performance
vary fror1 industry to industry. In the case of asphalt
plants, the particulate emissions are such that high
col'ectior rrficiencies are attainable. EPA is not
ream red to oresent affirmative justification for different
sta"da-ds in di'ferent industries. See the court's opinion in
Portland Cement Association v. Willian D. Ruckelshaus.
Tne objective o1 standards promulgated unde'" section 111 of
*~he £ct is to prevent new air pollution problems frofr, develop-
inc by reauinnci affected sources to use the best systems of
emission reduction available at a cost and at a time that is
reasonable. These standards are not intended to be related
to ambient air Quality. Attainment and maintenance of
national ambient air quality standards is covered by State
implementation plans as provided for under section 110 of
the Act.
It is not pract cal or meaningful to make general deter-
minations of changes in ambient air quality that might
be caused by new or modified sources. EPA does not know
whe'e sucli sources will be built, and many specific factors,
such as topography, meteorological conditions, proximity of
other pollution sources, and quantities emitted from all
sources, will have great impact on air quality in specific
1ocdtions.
EPA has no legal authority over what State and local agencies
do in this regard. As set forth under section 116 of the Act
and 40 CFP 60.10, the promulgation of new source performance
standards does lot prevent State or local jurisdictions from
adopting more stringent emission limitations for these same
sources. In heavily polluted areas, more restrictive
standards may be necessary in order to achieve national
ambient air quality standards. The preamble to the proposed
standards (38 FR 15406) clearly states that the costs of
meeting the standards are considered reasonable for new
and modified sources, it is not implied that the same costs
apoly to retrofitting existing sources.
EPft should study the e'ficacy of £f> did study the efficacv of State regulations. See
State and local agencies
will adopt the standarc for
both new and existing sources.
118
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APPENDIX E (continued). SUMMARY OF COMMENTS AND RESPONSES PERTINENT TO NEW SOURCE
PERFORMANCE STANDARDS (40 CFR 60) PROPOSED IN FEDERAL REGISTER
OF JUNE 11, 1973 (38 FR 15406)
Comment Commentator
no. no.
1-13
I-I4
1-15
1-16
1-17
1-18
1-19
1-20
90, 96, 111
7, 14, 16, 20,
23, 26, 27, 28,
32, 38, 48,
61 , 64, 65, 71 ,
106, 110, 111,
132, 134, 153,
171 , 186, ?11
72, 92, 96, 156
197
10, 14, 16, 25,
45, 47, 50, 51,
57, 65, 75, 81,
83, 128, 134,
153, T777T85,
201, 203, 235
201
156, 243
156
Comment
Response
existing State regulations apoli- Volume 1 of the background document.
cable to asphalt plants.
EPA should publish the names
of the manufacturers who
claim their equipment
will meet the proposed
standard and should
publish the warranties
on the equipment.
Manufacturers' guarantees do
not protect a plant operator
from economic losses due to
lost production and to
administrative and legal
costs - i.e., manufacturers
will not give unconditional
guarantees.
The letters containing baghouse warranties are on file in the
Emission Standards and Engineering Division of EPA, Durham,
N. C. and are available for inspection.
The guarantees will not provide full damages when equipment
fails to meet the standard, but they do reflect a degree of
confidence in the equipment. If the equipment fails to meet
the standard, the manufacturer would incur some liability,
and if he knowingly made fraudulent representations as to
efficiency of the control device he would be liable for all
damages incurred as a result of his representations. Manu-
facturers would presumably not take such risks without a
reasonable degree of confidence in their product.
It is true that EPA did not test any portable plants; however,
except for the mobility features, the design parameters of
portable and stationary asphalt plants are basically the same.
Therefore, there is no justification for not including portable
plants under the standard Portable control systems are
available having the same features and performance as do
stationary control systems.
From the definition of affected The standard does not apply to exposed raw aggregate storage
facilities it is unclear if the piles. The revision to the proposed applicability section
standard applies to raw aggregate of the standard should help clarify this.
storage piles which are exposed
and susceptible to wind carry-
off of particulate matter
The standard should not apply
to portable plants because
EPA did not test any portable
plants.
Normal replacement or moderni-
zation of facilities would
require all 4800 existing
asphalt plants to meet the
standard.
As "modification" is defined under 40 CFR 60.2(h), normal
replacement or modernization of a plant, which does not
result in an increase in emissions, is not a modification
and would not subject a plant to the standard. Only those
rhanoes which increase emissions would bring an existing
plant under the standard. The applicability section of the
proposed standard was revised to clarify the designation of
affected facility.
No. Relocation of a portable plant, in itself, would not be
considered a modification under section 111 of the Act.
When a portable plant is
relocated, would it be
considered "modified"
and thus subject to the standard7
Does transfer of ownershio place
an asphalt plant under the
proposed standard7
EPA surveyed 64 reportedly well- Our review of asphalt plants, with industry and State/local
No Transfer of ownership, in itself, does not constitute a
modification under section 111 of the Act.
controlled plants and rejected
60 of these. The method of
selection of plants for emission
testing is subject to question
1-21
control officials, led to field visits of about 64 plants.
All plants were not equally controlled. For instance, a plant
with a low-pressure scrubber (which has a low collection
efficiency for particulates) may have been an outstanding
example of control for fugitive emissions and therefore
support the visible emission standard. In addition, due to
weather or n-echanical failure, several plants were not
operating when visited. Selection of plants for possible
stack testing was narrowed to 12 plants. Those plants
eliminated were iudged on the non-inclusive basis of available
emission data, conversations with plant operators/owners
regarding control equipment problems and plant operation, and
visible emissions ranging from 20 to 60 percent opacity.
Five of the 12 plants were scheduled for test, but only four
were tested because the fifth shut down for the winter. The
other seven of the original 12 were not tested due tot
(1) lack of suitable stacks for testing, (2) plant shutdowns
for the winter, or (3) one installation used a fabric filter
with an air-to-cloth ratio of 1.76-to-l rather than the 6-to-l
normally used by the industry and a different fabric than
normally used by the asphalt industry.
10, 19, 38, 59, EPA failed to take the National The data were taken into consideration and were reported in
119
-------
APPENDIX E (continued). SUMMARY OF COMMENTS AND RESPONSES PERTINENT TO NEW SOURCE
PERFORMANCE STANDARDS (40 CFR 60) PROPOSED IN FEDERAL REGISTER
OF JUNE 11, 1973 (38 FR 15406)
Comment Commentator
no. no.
1-22
1-23
1-24
1-25
1-26
1-27
1-28
1-29
1-30
Comment
83, 84
13, 17, 19, 20,
23, 26, 42, 51,
59, 60, 80, 83,
85, 86, 96, 104.
122, 130, 132,
145, 162, 175,
179, 183, 186,
211, 227
83, 110, 156
47, 62, 132,
169
156
Asphalt Pavement Association
test data into consideration
when setting the standard.
EPA has not shown data from a
sufficient number of sources
to draw statistically valid
conclusions about process
variability and emission
concentration levels from a
well-designed and operated
plant and its collection system.
Response
EPA did not consider the results
of EPA Contract ^68-02-0076 in
the standard setting process.
EPA tests used for establishing
the standard were not conducted
at the plant's design capacity.
EPA failed to discuss the inpact
of the standard on nobile
plants, continuous-nix plants,
jnd drum-mixing plants.
59, 168
113
166
99, 200
12, 13, 14, 17,
18, 19, 21, 23,
Startups and shutdowns increase
emissions.
The proposed standard
(0.031 gr/dscf) can in met by
asphalt plants in the Los
Angeles County Air Pollution
Control listrict.
Our facilities will meet the
proposed standard.
Volumes 1 and 7 of this document.Performance test results
from two of the four plants tested were not used because of
dust buildup in the clean side of the collectors and because
the baghouses were operated with pressure drops outside the
recommended range. This information was provided by the
baghouse manufacturer's representative who inspected the
baghouses before the tests were conducted.
Because the Act requires [FA to determine the "degree of
emission limitation achievable through the application
of the best system of emission reduction which (taking into
account the cost of achieving such reduction) the Administrator
determines has been adequately demonstrated," the data base
upon which the standards ate justified wi" I always necessarily
be limited. There is no requirement that EPA test all
existing plants and base the standard on this information.
Even though EFA was only able to test 4 p'ants, additional
data were submitted to the Agency by industry and State/
local air pollution control agencies for considerat'on.
Since these acditional data are not the sole justification Tor
the proposed standard, extensive verification, beyond calcu-
lations and procedural practices checks, is not required.
The test results from the 45 asphalt plants which were
summarized in the contract report to EPA were considered in
the development of the proposed standard, but were not used
because the purpose of the contract was to obtain data for
establishing emission factors for different types of control
equipment, as typically installed, operated, and maintained.
This information is used to estimate emissions and calculate
ambient air quality trends. The fabric filter collectors
tested under this contract were not representative of best
control technology.
Ihree of the '"our plants tested by EPA were certified by
the operators to be operating at capacity. The fourth
was operating at 80 to 9C percent of capacity.
EPA has discussed these three categories with NAPA on several
occasions and v-ith equipment manufacturers, the Federal
Highway Admin stration, and control agencies. Specifically,
EPA bel'eves < h?t
(1) The desi(jn parameters of portable apj stationary bag-
houses are basically the same e
-------
APPENDIX E (continued). SUMMARY OF COMMENTS AND RESPONSES PERTINENT TO NEW SOURCE
PERFORMANCE STANDARDS (40 CFR 60) PROPOSED IN FEDERAL REGISTER
OF JUNE 11, 1973 (38 FR 15406)
Comment
no.
1-31
1-32
1-33
1-34
1-35
Commentator
no.
Comment
47, 51, 52, 53, 54,
57, 58, 59, 66, 67,
69, 71, 77, 79. 80,
81, 82, 83, 84, 85,
86, 88, 90, 97, 102,
104, 109, 112, 114,
115, 116, 117, 118,
119, 120. 123, 124,
127, 135, 136, 137, 144,
145, 146, 151, 152,
153, 154, 156, 157,
158, 159, 161, 162,
167, 168, 170, 171,
172, 375, 177, 183,
185, 186, 187, 188,
189, 190, 198, 199,
202, 208, 211, 213,
215, 216, 217, 218,
219, 220, 222, 223,
224, 225, 226, 228, 229,
230, 241, 242, 244,
246, 248
Response
42, 68, 82, 85
97, 101, 102,
126, 128, 135,
137, '56, 198,
207
38, 51, 59, 82,
83
18, 65, 84, 86,
92
24, 67, 168
57, 60, 83, 113,
113A, 150, 153,
204, 208
The standard for participate
matter should be: (1) 0.06 gr/
dscf, (2) 0.05 gr/dscf cr
greater, or (3) between
0.10 and 0.20 gr/dscf.
The standard should be based
on process weight.
The proposed standard
(0.031 gr/dscf) cannot be
achieved when fuel oils are used
in the dryer. Some allowance fn
particulate generated by fjir;rc
heavier grade petroieur;
products should be incorporated
in the standard.
There are no visible emissions
from our baghouse but we don't
know if it cap meet the prcrcsed
0.031 gr/dscf standard
The proposed standard of 0.031 gr/dscf was changed to 0.04 gr/
dscf for final promulgation. See Chapter 3 of this volume for
an explanation of why the change was made.
[n developing the proposed standard, process weight was
considered as a basis but rejected. The reasons why the De-
posed standard was based on concentratior are aiven on page 2,
Vo'u-Te 1 of this document.
The [ir-pusf-d standard of 0.031 gr/dscf was changed to 0.04 gr/
r
-------
APPENDIX E (continued). SUMMARY OF COMMENTS AND RESPONSES PERTINENT TO NEW SOURCE
PERFORMANCE STANDARDS (40 CFR 60) PROPOSED IN FEDERAL REGISTER
OF JUNE 11, 1973 (38 FR 15406)
.omment
no.
Commentator
no.
1-36
1-37
1-38
156, 169
156
Comment
2, 7, 8, 32,
36, 40, 54, 57,
61, 64, 65, 69,
83, 89, 100,
101, 106, 110,
132, 169, 199,
241, 245
EPA misquoted the results of
Rylarider report on correlation
between particle size and
capture efficiency of a
fabric filter.
Particulate emissions from
cement plants have smeller
fines content than do
emissions from asphalt plants,
yet both plants use sinilar
control equipment. The new
source performance standards
permit higher levels c*
emissions for cement plants
than for asphalt plants in
apparent recognition cf this.
No consideration was Given to
the effect of the aggregate
particle shape (e.g., spheres,
needles) on the efficiency of
the collector. The ptoposed
standard can only be echieved
when using dry, coarse1
aggregate mix
Response
EPA did not misquote the Rylander study, as shown by
Mr. Rylander's letter of July 17, 1973 to Mr. Fred Kloiber of
NAPA in which he states "From our bench model filter tests we
could not obtain a correlation between particle size and
capture efficacy of a fabric filter."
EPA is not required to present justification for different
standards for different industries. The essential question is
whether or not the standard can be met by the affected industry
and this is decided on the basis of information concerning
that industry alone. See Portland Cement Association v.
Hi11iam_D. Ruckelshaus. Control equipment used for the two
industries is similar only in that baghouses are employed.
The cement industry commonly uses baghouses with different
design, with an air-to-cloth ratio of 2:1, and with a different
fabric filter.
The effects of aggregate variations on baghouse performance
have been investigated by EPA and by the asphalt industry.
It. is recognized that aggregate characteristics that affect
particle size, shape, and lubricity vary among geographic
locations. Pa-ticulate matter which is spherical in shape,
has an average fineness below 5 microns, and is slippery and
smooth will decrease the performance of a baghouse; however,
available information indicates that aggregates used by
asphalt plants do not produce particulate matter of this size
and shape. EPA tests were conducted at plants having aggregate
mixtures with fines (-200 mesh) ranging from 2 to 7 percent
by weight. In general, the amount of fines in aggregate is
approximately 5 percent. T'i?r2 may be somt aggregates >: f wnich
EPA is not awa--e that would have a size, shape, and lubricity
that would affect control efficiency. The proposed standard
of 0 031 qr/ds:f was changed to 0.04 gr/dscf for final
oro'rul qation. See Chapter 3 of this volume for an explanation
c^ whv the chfnqe was made.
1-39
1-40
1-41
1-42
59 The moisture consent c,r the
incominq aggreqate arc1 the
driec aqqregate should be
described in Volume 1 or 2
of the background document
because it affects collector
efficiency.
20, 40, 41, 47, The standard should teke into
67, 81, 106 account the effect of ambient
hunidity on the ability to
control particulate emissions.
197 Does the emissions records
requirement, section fO.93,
mean that records of opacity
measurements must be tept7
145 Clarify section 60.94;d)(l)
so it is understood that only
the front half of the EPA train
is used in determining compli-
ance, not the entire ".rain.
1-43
1-44
197
197
A stack is required in order to
use method 5 as required by
section 60.94(d). OOPS this
preclude the use of a
pressurized baphouse7
This information was omitted because it is not considered
relevant to the standard. The moisture content of the
incominq aggregate determines the dryer capacity. In genera1,
dryers are des'qned for aggregates with i oercent "cisture.
When the moisture exceeds 5 percent, dryer capacity is
de-reese'J. Aqtireqates will drain to a moisture content of
apDrcxirately I' percent; therefore, 8 percent is the maximum
roisture content 'found in the incoming aggregate.
',(> relationship exists between ambient humidity and control of
emission';, provided the temperature cf the gases in the bag-
house is tept above the dew point.
This is not necessary because method 5, which is referenced as
the test method under 60.94(d',(l), does net require measure-
ment of anything except the particulate matter collected in
the probe and filter, the particulate matter collected in the
wet impinqers is not determined. The impinofrs are optional
in the sampling train and can be replaced by an equivalent
condenser.
No. Pressurized baghouses may be used with a stack so that
method 5 can be used. As provided under section 60.8(b), the
Administrator may approve an alternative method or waive the
performance test requirement if the owner or operator can
demonstrate compliance by some other means.
A larqe proportion of oarticulate The method was changed in response to comments received when
emissions from asphalt plants the first group of standards was proposed The rationale for
is collected in method 5 changing the method is still considered to be valid. L'nti I
iinpingers. The full EPA train more information is received which indicates the need for use
should be used as the test method of the full train catch, method 5 will consist of the frcnt
because any fraction not half only (probe and filter catches only)
collected in the impingers will
contribute to measured ambient
122
-------
APPENDIX E (continued). SUMMARY OF COMMENTS AND RESPONSES PERTINENT TO NEW SOURCE
PERFORMANCE STANDARDS (40 CFR 60) PROPOSED IN FEDERAL REGISTER
OF JUNE 11, 1973 (38 FR 15406)
Comment Commentator
no. no. Comment Response
1-45
1-46
208
1-47
63, 83, 156,
169
levels of suspended participate.
A 0.03 gr/dscf, EPA method
5 is unreliable and its
reproducibility is on the
order oft 100 oorcent.
Precision and accuracy of method
5 have not been established.
1-48
1-49
In the emission tests, EPA
failed to follow method 5
in the following ways:
(a) Sample time was less than
5 minutes at each point.
(b) Sample time was less than
60 minutes.
(c) Three repetitions were not
performed in all tests of plants.
(d) Dimensions of the stack and
numbers of tests points on the
traverse were not given in
in the reports.
(e) Samples were not within
the range 90 to 100 percent
isokinetic.
(f) Dilution air was not
determined.
11, 19, 82, 225
19, 32, 46, 85,
144, 153, 241
EPA should conduct a
comparative cost-benefit
study for an 0.06 gr/dsrf
standard and the proposed
standard (0.031 gr/dscf)
Asphalt plants cannot afford
the control costs reauired
by the proposed standard.
Preliminary analyses indicate that method 5 is reproducible
within a factor of jMO percent. This is considered adequate
for testing stack emissions. Preliminary data are available
in EPA files in Durham, North Carolina.
It is true that the precision and accuracy of this method have
not been definitely established; however, preliminary data
based on field tests are available that indicate an inter-
laboratory precision (reproducibiiity) of +_ 10 percent.
Error analysis of the testing eguipment variables indicates
that the method has an intralaboratory precision
(repeatability) of +^ 6 percent. Studies of method accuracy
are hampered ay tuie~"lack of a facility for generating known
concentrations of particulate matter. Such a generator is
under construction and accuracy studies are expected to be
completed in 1^74
All of these points are true, however, the deviations from
method 5 are so minor that the test results are still
considered valid. It must be pointed out that method 5
plays a dual role (1) it serves as the method for data
gathering durinq the development of a standard of performance
and (2) it serves as the method for determining
compliance (druina a performance test) of new or
modified sources covered by a performance standard
Testing during the standard development process is done
primarily on sources that were retrofitted with control
eguipment and that are not necess-.nly designed to
facilitate testing. In addition, EPA data-gathering
tests are conducted during the norm?! production run of
a process, thus, testing duration is controlled by the
operation schedule of the plant This is unlike testing
which would he performed during a performance test.
The obiectwe of method 5 is to set forth a uniform
procedure for determining particulate emissions with
maximum accuracy and orecision under a variety of conditions.
'here are procedures m the method which, subject to
engineering uidqrent, can he considered flexible in
certain rases witnout sacrificing the reliability of the
fest results Methcd - is beinq revised to clarify this
noint. Deviations from the specified procedures are
however, subject to approval by the Administrator.
The data concerning dimensions of stacks and numbers of
test points are available in FPA files in Durham,
North Carolina A review of these data indicates that the
number of traverse points used conforms to "ethod 1. The
failure to include these data in the test reports was an
oversiqnt.
The results included in the test reports weie reviewed
and some calculation errors were found Correction rf the
errors indicated that all of the samples had been obtained
within the range of 90 to 100 percent isotinetic flow
conditions.
"Dilution air" is considered to be air which is added to
a gas stream for the purpose of dilutinr the concentration
of partirulate matter in order to comply with an applicable
standard. Dilution air was not added during any test.
The percent excess air was calculated frorr the Orsat
analysis, and the results are reported in the test reports
on those plants tested by F°A
A cost benefit analysis, showing the benefit to ambient air
conditions as measured against the cost of the pollution
control devices required to meet a standard is not a
reguirement in considering costs. See Portland Cement
Association v. William D. Ruckelshaus.
The proposed standard (0.031 gr/dscf) was changed to
0.04 qr/dscf for final promulgation. It is our judgment
that the incremental investment required by the final
standard will generally net create any serious additions!
financing problems for new asphalt ccncretr nlants
The February 1972 Economics of Clean Air concluded that
asphalt concrete pTants meeting State enssion standards
123
-------
APPENDIX E (continued). SUMMARY OF COMMENTS AND RESPONSES PERTINENT TO NEW SOURCE
PERFORMANCE STANDARDS (40 CFR 60) PROPOSED IN FEDERAL REGISTER
OF JUNE 11, 1973 (38 FR 15406)
Comment
no.
Commentator
no.
Comment
Response
1-50
7, 12, 14, 16,
18, 23, 25, 26,
27, 28, 29, 30,
33, 50, 54, 57,
65, 67, 69, 72,
75, 81, 89, 107,
112, 121, 128,
140, 145. 147,
153. 168, 185,
198, 230, 235
The small operator cannot afford
to install control equipment
and will be forced out of
business.
should be able to Increase prices to cover the added
cost of pollution control. Because the annual cost
for a new plant meeting the final standard closely
approximates the cost for an existing plant meeting a
typical State standard, our judgment is that a new
plant will not be placed at a competitive disadvantage.
These judgments have been reinforced by NAPA's public
comments that were submitted to EPA on July 24, 1973. On
paqe 49 of thei- comments they stated:
"The National Asphalt Pavement Association, as it
has indicated on many occasions to EPA, submits that
the legitimate goal of protecting the environment and
reducing emissions will be achieved by the imposition of
a .06 standard rather than the .031 standard. It is
submitted by the industry that this will result in an
improvement of the emission levels by 99.8?;, and is
consistent with the goal which has been stated, of 99.7%
by the Environmental Protection Agency. Further, it is
submitted that the reduction is achievable at a
reasonable cost without unduly endangering the existence
of the industry or forcing the use of other alternative
products. Thus, it is submitted that it is important
that the standard be .06 and not .031."
"It is important that it be recognized that if the
standard is .06, the equipment which will be required to
be purchased will be either a venturi scrubber with a
minimum 20-inch pressure drop or a baghouse with a 6 to 1
air-to-cloth ratio. It is submitted that there will be a
significant improvement in the environment with an .06
standard. The .06 standard will further require that the
plants be kept in good operating repair and condition or
they will fail to meet the .06 standard. A .06 standard
will avoid the problems of the size and shape of
the particulates and also other problems which cannot
be answered at the present time."
NAPA's conclusion is that the cost for a venturi scrubber
with a 20-inch pressure drop or a baghouse with a 6:1
air-to-cloth ratio is reasonable. It is EPA's contention
that this equipment will achieve the final standard
(0.04 qr/dscf) Thus, NAPA's conclusion that cost for this
type of equipment is reasonable reinforces our judgment that
the cost to meet the final standard is reasonable.
The costs of Ue standard to an owner or operator are
considered reasonable for all sues of plants; there is no
economic penalty to small plants. The standard does not
apply to existing plants. If a small operator Hor^-- j.omment
modify an existing plant or build a new plant, no_
will add about 6 to 10 percent to the cost of a piant
designed to comply with State regulations. See response to
comment 1-49 regarding reasonableness of the costs.
1-51
1-52
39, 41, 84, 102 EPA stated that 30 to 40 percent This estimate, from the February 1972 Economics of Clean Air.
of small operators would be applies to costs for complying with State Implementation Plans,
forced out of business. not with the proposed new source performance standard.
10, 21 , 41, 57,
65, 74, 84, 89,
100, 101, 120,
145, 156, 170,
220
The standard will stifle growth
of the asphalt industry and
development of new and better
equipment.
As indicated ir the preceding comments, costs are reasonable.
It is therefore difficult to see why normal growth and
development should not occur.
1-53 25, 31, 33, 65, The proposed standard will in- The. standard will increase the cost of asphalt concrete
74, 88, 89, 92, crease highway construction about $0.02/ton over the cost of meeting normal State
96, 101, 149, costs. regulations, which is $0.20/ton more than costs for asphalt
172, 199 concrete produced in uncontrolled plants. Two cents per ton
amounts to 1/4 of 1 percent of the price o* an $8.00 ton of
asphalt. Since asphalt concrete represents only 20 to 40
percent of highway construction costs, the effect on highway
construction should be miniscule.
1-54 145 Costs for control of bjrticulate The Act does not require that control cost?, be the same for
emissions are greater for all industries affected by new source performance standards.
124
-------
APPENDIX E (continued). SUMMARY OF COMMENTS AND RESPONSES PERTINENT TO NEW SOURCE
PERFORMANCE STANDARDS (40 CFR 60) PROPOSED IN FEDERAL REGISTER
OF JUNE 11, 1973 (38 FR 15406)
Comment Response
Comment
no.
1-55
1-56
1-57
1-58
1-59
1-60
1-61
1-62
1-63
1-64
Commentator
no.
156
156
asphalt plants than for the
other Group II industries.
EPA has miscalculated the eco-
nomic cost of the proposed
standard since the number of
plants becoming subject to the
standard will increase sub-
stantially, even assuming no
new plants will be needed to
meet increased demand. NAPA
claims that 480 plants will
require replacement each year.
EPA has erroneously estimated
that the annual growth rate
for the asphalt concrete
industry is 10 percent.
25, 84, 87, 109, EPA has ignored the projected
146, 170, 203 power requirement involved.
17, 26, 83,
220, 245
145
106, 156
10, 13, 17, 24,
28, 33, 39, 53,
55, 61, 73, 78,
84, 106, 1?2,
126, 132, 134,
177, 183, 220,
245
61
No control cost estimates are
provided for retrofitted,
modified plants.
Control costs will increase the
cost of new or modified
equipment by 24 percent.
Estimated control costs per ton
of asphalt are incorrect because
costs are based on an on-stream
time of 50 percent and on a 100
percent capacity production.
NAPA claims that 1972 annual
production was 25 percent of the
total installed capacity.
EPA control cost estimates are
too low. A more typical figure
to bring an installation into
compliance is $80,000 to
$600,000 - an added cost to the
product of $0.36/ton.
Control cost estimates do not
include lost income due to
lost production during
installation and adjustment
of a control unit.
Cost estimates for a low-
pressure venturi scrubber
are too high. Costs will
more likely be around $10,000.
156
To consistently achieve the
proposed standard (0.031 gr/
dscf), a baghouse must have
125
EPA's cost analysis is based on a "model plant;" costs are
calculated for this design and size plant. The total number
of plants subject to the standard is not pertinent if cost
per plant does not increase substantially. If indeed 480
plants will be subject each year to the standard, then this
is all the more reason for need of a standard.
The 10 percent growth figure was based on production figures
for 4 years. During the last 10 years the rate was only 6.6
percent. The rate for the last 3 years was 2.2 percent. EPA
has revised the growth rate figure to 5 percent on the
assumptions that: (1) the 2.2 percent figure is abnormally
low and (2) a slowdown of interstate highway construction will
probably make the 6.6 percent figure too high.
The power requirement was considered in the economic analysis
of the standard.
Cost estimates for retrofitting were not considered necessary
because the cost to control a modified plant would not be
higher than to control a new plant. Sources are considered
"modified" under the Act only when modification results in
increased emissions. Costs will ordinarily be lower for
retrofitting modified plants than for installing control
equipment in new plants because modified plants often have
much of th° necessary ductwork, electrical switchgear. qivn in
Chapter 3 of this volume of the background document. A
-------
APPENDIX F (continued). SUMMARY OF COMMENTS AND RESPONSES PERTINENT TO NEW SOURCE
- STANDARDS (40 CFR 60) PROPOSED IN FEDERAL REGISTER
OF JUNE 11, 1973 (38 FR 15406)
Comment
(10.
Commentator
no.
1-65
1-66
156
61
1-67
1-68
Comment
Response
an air-to-cloth ratio lower
than 6:1. Costs to achieve the
0.031 gr/dscf standard using a
4:1 rather than a 6 1
air-to-cloth ratio increase
by 40 percent.
EPVs cost estimate of $9.00/ton
for mineral filler is incorrect;
it should be around S3.39/ton.
57
30, 57, 90, 96.
Ill , 162
baghouse with a 6:1 air-to-cloth ratio should meet the
0.04 gr/dscf standard if it is properly designed, installed,
operated, and maintained.
Some States won't allow the use
of collected fines in asphalt
concrete.
The $9.00 value was based on information from trip reports.
Valid information from the National Crushed Stone Association
supports the $3.39/ton figure. EPA calculations have been
adjusted to reflect the lower value.
Although this may be true for certain types of asphalt
concrete, it is not considered a significant problem. This
situation is considered in the economic analysis; however,
it does not increase costs to the extent that they become
unreasonable. For a fabric filter without recycle equipment,
investment costs would be 10 to 15 percent lower, but
operating costs would be $0.02 to $0.03 per ton higher.
Manpower costs caused by the No monitoring equipment is required and record keeping is
monitoring and record-keeping limited to filing the original test data. Therefore, there
requirements were not considered, are no manpcwer costs.
Do not want to buy the expensive Because there are no continuous monitoring equipment require-
equipment required for monitoring ments and because performance tests may be conducted by a
and testing. consulting firm or control equipment vendor, there need be
no testing equipment costs.
126
-------
APPENDIX E (continued). SUMMARY OF COMMENTS AND RESPONSES PERTINENT TO NEW SOURCE
PERFORMANCE STANDARDS (40 CFR 60)PROPOSED IN FEDERAL REGISTER
OF JUNE 11, 1973 (38 FR 15406")
Commentator
no.
Comment
Response
Subpart J. Petroleum Refineries
J-l
0-2
J-3
J-4
J-5
J-6
J-7
J-9
197
105, 125, 131, 163,
164, 173, 181, 182,
184, 205, 209, 210,
239, 240
131, 163, 197
125, 131, 141, 163,
181, 205
128, 141
105, 143, 184, 239
105, 143, 163, 176, 182,
184, 239
49, 174, 184, 221
J-10
105, 163, 174, 191,
195
113, 131, 141, 163,
182
Fluid coking units should be listed as an
affected facility.
The definition of "petroleum refinery"
used in the regulation could be interpreted
as including crude oil production
facilities, gas plants, and natural
gasoline plants. The definition should
be revised to apply only to petroleum
refineries.
The definition of "petroleum" used in the
regulation excludes the petroleum extracted
from shale, tar sands, and coal. Shouldn't
such petroleum be included?
The definition of "hydrocarbon" is too
broad and ambiguous.
The definition of "process gas" should
have included the non-hydrocarbon gases
produced by various process units in a
refinery
"Fuel gas" should be defined only as
gas burned in heaters and boilers to
avoid having H,>S standard apply to
stack gases from fluid catalytic
cracking catalyst regenerators (FCCCR) and
fluid coking unit coke burners
(FCUCB).
The definition of "waste gas disposal
system" should clearly indicate that
emergency flare systems are not included
so that the H2S standard does not apply
to the emergency flare systems.
In the economic analysis, the credit
for the useful energy derived from
a CO boiler should not be used to
reduce the debit for the installation
and use of an electrostatic preeip-
itator (ESP),
The costs of am me treaters and Claus
plant tail-gas scrubbers should be
included in the economic analysis for
H2$ control Small refineries cannot
afford such equipment and should be
exempt from the H~C standards.
The cost to control a small fluid
catalytic cracking unit (FCCU) would
be prohibitive. Some provision should
be made to exempt small FCCUs, or the
standard should be relaxed.
The facilities to which the standards
apply should be specifically identified
in the regulation.
No data concerning emissions from such units have yet
been collected by EPA nor have the systems for emission
control yet been studied.
Agree. The definition has been made more specific to
prevent misinterpretation.
Yes. The definition has been changed to clearly include
petroleum extracted from shale, tar sands, and coal
This definition is no longer required and has been deleted
from thp ornmul natpH r*»nitlatinns
The definition has been revised to include all gases
produced by process units in a refinery except fuel
gas and process upset gas.
Agree The definition of "fuel gas" has been changed to
include only those, gases generated by a refinery orocess unit
and combusted as a fuel. Roth the FCCCR stack gases and
the FCUC6 stack gases are exempt from the H?S standard.
The HjS standard applies to flare systems as well as process
heaters an^ boilers. H0wp.vpr, the standard is not appli-
cable to flare systems when the flare is used as a safety
device under emergency conditions. The standard has bpen
to clarify this distinction.
A CO boiler credit was not used to offset ESP costs.
See pp. 22-23 of Volu"10 1 of this document for separate
analyses of the costs. On the basis of these separate
analyses, the costs for compliance were judged to be
reasonable.
EPA agrees that arnine treater costs should be included,
particularly as related to small refineries which might
not otherwise install such equipment This cost analysis
has now been completed and small-unit costs are considered
reasonable. See Chapter 4 and Appendix C of this volume
for details of the analysis. The costs of Claus plant tail-
gas scrubbing are not included in the economic analysis
because such scrubbing is not needed to comply with the
standard.
EPA has analyzed small-unit costs and found them to be
reasonable. See Chapter 4 and Appendix C of this document
for details of the analysis
The regulation has been revised to identify clearly the
specific affected facilities.
127
-------
APPENDIX E (continued). SUMMARY OF COMMENTS AND RESPONSES PERTINENT TO NEW SOURCE
PERFORMANCE STANDARDS (40 CFR 60) PROPOSED IN FEDERAL REGISTER
OF JUNE 11, 1973 (38 FR 15406)
Comment
no.
Commentator
no.
197
__ Cement
The participate emission standard appears
to be unduly restrictive when compared
with the OUL.B '. stant'erd for power plants
Response
Regulations on burning of 5ulfur-contain-
ing fuel in refineries should not be more
restrictive than regulations on burning of
sulfur-containing fuel in other facilities
such as Gro^p I utility boilers
Boilers cf less thai' 250 million Btu/hr,u>
heat inp^t ehould be exempt from the
standard to be consistent with tie Grouc 1
st'indar d for pcwe- j, ' ,ants 3nd tc edjc e
See response to J-12.
See response to J-12. Many refinery boilers smaller
than 250 million BtuAour heat input should and can
comply with the standards.
S, 163, 239
J-18
J-19
J-20
184
J-21
I Ob, 163, 181,
239
205, 251, 253
The regulation does not specify a standard
basis to which concentration of $02
should be calcjlated if compliance
testing of the combustion gases is
per rot 'ned Cm invention of the stardard
T- thus pos:ib-' Lv jse of °-,;&$s an
Although it nay be feasible to attain
particulate emission concentrations oc
0 02? gr/dscf when the control equipment
is new, it is very difficult to attain
thl? continually over life of equipment.
rhe standard ,',, A] _> be "^ised to ^ 34
Continual compliance with the proposed
piirticulate regulation is not possible,
the regulation should be revised to
require average emission concentrations
of 0 022 gr/dscf but permit 'naxniiu1"
OMssion concentrations of 0 044 gi/Jicf
The 3-minute/hour exemption period
allowed in the opacity standard for
soot blowing is too short Industry
experience shows 5 minutes is more
reasonable
With participate emission concentrations
of 0.022 gr/dscf, the plume should not
be visible. Opacity standard should oe no
viiHile emissions ruther than 20 rercerit
Vendors refuse to guarantee opacity of
emissions. Industry data show that to
reg
missions. Industry data show that to
;onsistently meet a 20 percent opacity
/egulation, grain loadings must be less
than 0.01 gr/dscf, much less than Q 022
gr/dscf Thus opacity should be used a^>
a guide to determine when a source test
is necessary to check compliance.
Where the precipitator precedes the carbon
monoxide boiler, the proposed particulate
matter regulation permits dilution by the
carbon monoxide boiler flue gases. Where
the precipitator follows the carbon
monoxide boiler, such dilution is not
possible. Thus, the regulation is
lenient if the boiler follows the
precipitator
A paragraph added to the General Provisions (subpart A,
40 CFR 60) prohibits the use of dilution air and other
ciicumvention techniques to achieve compliance with any
new source performance standard The petroleum refinery
standard has been changed to require that an owner or
operator who elects to control SQ2 emissions by methods
other than removal of H2S before the gas is burned must
demonstrate to the satisfaction of the Administrator
that equivalent control is achieved.
Long-term data gathered by EPA on particulate emissions
from precipitators operating on fluid catalytic cracking
units in the petroleum industry and in other applications
in other industries indicate that, with good maintenance,
precipita tors will continue to operate at a high
efficiency, meeting or exceeding design conditions and
specifications for the life of the equipment. Detailed.
discussions with the major vendors serving the petrojeum
refinery industry confirm this. See Chapter 4 of this
volume for an additional discussion of this point.
See response to J-16.
See the discussion of opacity stardards in Chapters 2 and
a af this document (Volume 3).
See the discussion of opacity standards in Chapters 2 and
4 of this document (Volume 3).
See the discussion of opacity standards in Chapters 2 and
4 of this document (Volume 3).
Agree. Under the proposed regulations two identical
fluid catalytic cracking unit catalyst regenerators
could discharge different volumes of gases to the
atmosphere, depending on the placement of the CO boiler
with respect to the electrostatic precipitator. The
promulgated regulations are based on coke burn-off
rate in the catalyst regenerator; thus particulate
emissions do not depend on the volume of gases dis-
charged to the atmosphere, so placement of the CO
boiler with respect to the electrostatic precipitator
ha1, no effect on particulate emissions
128
-------
APPENDIX E (continued). SUMMARY OF COMMENTS AND RESPONSES PERTINENT TO NEW SOURCE
PERFORMANCE STANDARDS (40 CFR 60) PROPOSED IN FEDERAL REGISTER
OF JUNE 11, 1973 (38 FR 15406)
Comment
no.
J-22
Commentator
no.
J-23
J-25
105
105, 176, 182, 184
131
Comment
Why are allowances given for incremental
increases in participate emissions if
liquid or solid fuel is burned in the
carbon monoxide boiler7
Just as an allowance is made for
incremental increases in particulate
emissions if liquid or solid fuel is
burned in carbon monoxide boilers,
the standard should include an allow-
ance for the burning of gaseous fuel.
Regulations should be revised to state
specifically what monitoring require-
ments are necessary on what affected
faci1ities.
Monitoring requirements should apply only
if emissions are above some specified
level.
Monitoring of firebox temperature is not
necessary.
Response __
All the fluid catalytic cracking catalyst regenerators
tested and studied by EPA were burning natural gas
in the CO boiler. However, during certain months of
the year natural gas is not available and liquid fuels
must be used instead. Since the combustion of liquid
(or solid} fuels will increase participate emissions,
an allowance for liquid or solid fuel is included in
the regulation, based on the Group I utility boiler
standards.
Units tested by EPA were burning gaseous auxiliary fuel,
so the standard takes this into account.
Agree. The regulations have been so revised.
Monitoring instruments are necessary to ensure proper
operation and maintenance of emission control systems.
Monitoring of both firebox temperature and oxygen
content of gases is necessary to ensure oxidation of
J-27
J-28
176, 182
113, 163, 166, 176,
184
Requiring the maintenance of separate
records and files for pollution control
information is unreasonable The use of
operating unit log sheets would be
adequate.
The regulations need to be revised to
specifically state whether H?S is to be
monitored at each heater, boiler, and flare
system or for the fuel gas system as a
whole.
Operating umt log sheets record spot values at wide
intervals. These data are not adequate to ensure
proper operation and maintenance of the emission control
system.
The regulations have been revised to permit the monitor-
ing of H^S in the fuel gas system as a whole
J-29
113
J-30
J-3J
797, 163, 204
J-32
143, 163, 166, 174
There is no need to monitor the fuel gas
system continuously The control room
instrumentation will indicate if am me
scrubbing units are operating normally.
Release of gases to the atmosphere
should not be permitted if such gases
contain hydrogen sulfide (H2S) in
concentrations greater than 230 mg per
dry cubic meter at standard conditions
Incineration of such gases should be
required Unburned H2$ should be monitored
in stack gases.
There is no need to keep a daily record
of the production rate for the fluid
catalytic cracking umt.
The standard is based on blended fuel qas streams since
this is a common refinery oractice However, blended fuel
gas streams commonly contain HzS in considerably greater
concentrations than 230 mg/dscm, and the purchase of
large volumes of natural gas for blending with refinery
fuel gas merely to reduce the HgS concentration of al!
fuel gases to below 230 mg/dscm is not likely to be a
practical alternative to treating the fuel gas to
remove H~S
The parameters monitored in control rooms to determine
proper operation do not reflect the hydrogen sulfide
concentration nor do they indicate how well it is
control led
Hie standard applies to emissions for sulfur dioxide
(S02), not H2S, and restricting the release of HoS to
the atmosphere does not control SO? emissions. Because
H2$ released to the atmosphere would cause a stench,
common practice in most refineries is to flare gases
containing H2S. However, $02 is formed when H£S is
burned, so the most effective way to control SO? emissions
is to remove substantial amounts of H?S from gases before
they are burned, as the regulation requires.
Agree This requirement has been removed from the
regulation.
129
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APPENDIX E (continued). SUMMARY OF COMMENTS AND RESPONSES PERTINENT TO NEW SOURCE
PERFORMANCE STANDARDS (40 CFR 60) PROPOSED IN FEDERAL REGISTER
OF JUNE 11, 1973 (38 FR 15406)
Comment
no.
Commentator
no.
Comment
Response
Subpart K. Storage Vessels for Petroleum Liquids
95, 105, 131, 143, 164,
165, 166, 176, 181 , 182,
184, 195, 210, 239, 240
K-2
K-5
K-9
108
34, 95, 105, 108, 131,
164, 166, 167, 181,
184, 209, 238, 240
35, 91, 95, 131, 232
105, 184, 236
35, 125, 143, 184
15, 105, 125, 139,
142, 143, 163, 231 ,
239
3, 9, 22, 70
Exempt storage of crude oil and condensate
at producing facilities in the field
from the standard. Reasons given
included1 (1) the larqe cost differential
in switching from the bolted-construction,
fixed-roof tanks in common use to the
welded, floatinq-roof tanks needed for
compliance with the standard; (2) the very
small emissions of those hydrocarbons
which contribute to the formation of
photochemical oxidants; (3) the relatively
small size of these tanks and their com-
monly remote locations; and (4) the under-
standing that EPA did not intend to make
the standard apply to such tanks.
Increase tank size exemption to 320,000
liters (84,500 gallons) as this is the
most common size used in storage of
diesel fuel and pi peline interfaces,
which are normally of low volatility
Increase size of aV\_ storaqe tank exemp-
tions to 50,000 barrels (2,000,000 gallons)
as this is the most economical size
The definition of "storaae vessel" is too
broad It includes subsurface caverns,
porous rock reservoirs, and high-pressure
tanks capable of operating at pressures
sufficiently high to prevent emissions to
the atmosphere. These types of storaqe
are optimum for preventing the release of
emissions to the atmosphere and require
no additional control devices
The definition of "letroleum liquid" is
too broad. It can be considered as
encompassing any products made from
petroleum, including petrochemicals, and
these products were not studied by EPA.
The definition of "floating roof" does
not include covered floating roofs and
internal floating covers, which are
surely acceptable as control devices
The definition of "vapor recovery system"
can be interpreted to demand complete,
100 percent recover/ an impractical
demand.
The standard should not require conser-
vation vents on storaqe vessels when
the true vapor pressure of the petroleum
liquid stored is 78 mm Hg or less
because (1) such vents become fouled
when some heavy liqjids are stored and
when ice forms on the vents during cold
weather, and (2) the beneficial effect
on emissions is minimal.
The proposed standard duplicates state
rules and regulations and is not
needed. It should be dropped where
existing state plans are in effect.
It was EPA's intent to exempt such storage vessels. The
regulation has been amended to clarify this. The exemp-
tion applies to storage between the time that the oil
and condensate are removed from the around and the
time that custody of these products is transferred from
the well or producing operations to the transportation
operations.
Diesel fuels are exempt from the standard. Interfaces
of low volatility, i.e., less than 1.5 psia true vapor
pressure, are exempt.
EPA's economic data do not support this contention.
The data indicate that the exemption threshold is
reasonable.
Agree The reaulation has been amended to exclude such
storage.
The definition has been amended tc clarify applicability.
Agree These devices are acceptable. The definition
has been amended to include such cevices.
TMs was not EPA's intent The use of the word "prevent"
is not meant to imply total stoppage, and this is made
clear in the preamble to the promulgated regulations.
Acree. Regulation is amended to exclude the require-
ment for conservation vents.
The intent of new source performance standards under
section 111 of the Clean Air Act is to require
nationwide the best adequately demonstrated, economically
reasonable system of emission controls. Tnere is
nc provision for exempting facilities located in states
where good state regulations require similar control of
emissions.
130
-------
APPENDIX E (continued). SUMMARY OF COMMENTS AND RESPONSES PERTINENT TO NEW SOURCE
PERFORMANCE STANDARDS (40 CFR 60) PROPOSED IN FEDERAL REGISTER
OF JUNE 11, 1973 (38 FR 15406)
Comment Commentator
_ no. _ no_. _ _ Comment
K-10 3, 9, 22, 35, 70, 95, The monitoring requirements impose a The regulation has been amended to reduce the monitoring
105, 108, 142, 143, heavy expenditure of manpower and requirements The requirements were based on the
150, 163, 166, 176, money to collect, record, and retain inforrndtion-qatnerinq facilities which were known to
181, 182, 184, 197, information that is not really needed. exist at modern refineries, and the comments and EPA's
210, 231, 237, 239,' For example- (1) recording daily tank subsequent follow-up clearly showed that the operators
240 temperatures for the thousands of of remote tank farms, terminals, and marketing operations
tanks in remote tank farms, terminals, would have been unjustifiably burdened.
and marketing operations is impractical
and not needed, (2) most products are
manufactured to specifications and
have typical vapor pressures over
reasonably narrow ranges These can be
used instead of the required daily
sampling and analysis to determine true
vapor pressures, and (3) surely there
is no intent to demand constant
compliance and surveillance.
K-ll 105, 113, 176, 184, The storage vessel maintenance require- The maintenance requirements have been removed from the
197, 238, 239 ments are not workable because- (1) the regulation The intent was to ensure that good
colors and types of paints to be used maintenance practices were employed, and the requirements
on tanks are not specified, (2) some were not sufficiently explicit for this purpose. <\
localities require paints that blend recently ouolished chanqe to subpart A (40 CFR 60),
with the location, (3) the desired General Provisions, requires that all facilities
condition of the seal is not specified, subject to new source performance standards must be,
and (4) it is not reasonable to require to the extent practicable, operated and maintained
that sampling ports on floatinq-roof in a manner consistent with aood air pollution control
tanks be qas-tiqht practice for minimizing emissions This will achieve
the purpose for which the proposed storage vessel
maintenance requi rements were i n tended
Subpart L Secondary Lead_ Smelters
L-l 204 The term "reverberator/ furnace" should The intent was to show the types of reverberates >
not be used to define a rrverberatorv furnaces that were covered by thi^ reaulation The
furnace definition has been revised to clarify this intent
1-2 204 "Pot furnace" and "cupola" should be The terrs r^re intended to convev thp same rreaninns
defined as those Generally accepted in the industry, and
no defmifons were considered necessary
L-3 62, 113, 196, 204 The opacity standards should be changed
for the followinn reasons (1) there
is no basis for the ?-minute'hour
exemption, (2) an upper limit should
be established for the exemption period,
and (3) the opacity standard cannot be
met by smelters that meet the concen-
tration standard.
L-4 196 Why is the particulate standard for Test data serye as a guideline for setting standards,
secondary lead blast and reverheratory but other factors must be considered as well, the
furnaces 0.02 gr/dscf when the data application of engineering judgment is an important
support a limit of 0 01 ar/dstf7 part Of standard development. In this particular
case, the following facts influenced the choice of
the number for the standard' (1) desinners and manu-
facturers of control equipment will Guarantee concen-
trations between 0 015 and 0 020 qr/dscf, and (2) FPA
did not want to exclude the use of scrubbers as an
applicable control device. The test data indicate that
3 high-pressure-drop scrubber cannot consistently
reduce participate emissions to 0 01 gr/dscf but that
it should be able to achieve 0 02 gr/dscf.
L-5 62 EPA should have proposed standards to Ambient, air quality is protected under section 110 of
control SOp emissions because these the Clean ^^r Act New source performance standards
emissions may result in violation of are promulnated under section 111 of the Pet to prevent
ambient air quality standards. future problems from developino by requiring the use
of the best system of adeouately demonstrated control
that is economically feasible Time and money dictate
that some pollutants must be dealt with before others
Durina EPA's study of secondary lead smelters and
refineries, it appeared sensible tn defer standards
for control of SO;? emiss">ons until standards for more
siamficant emissions haJ been set.
131
-------
APPENDIX E (continued). SUMMARY OF COMMENTS AND RESPONSES PERTINENT TO NEW SOURCE
PERFORMANCE STANDARDS (40 CFR 60) PROPOSED IN FEDERAL REGISTER
OF JUNE 11, 1973 (38 FR 15406)
Commentator
no.
113
Comment
The size below which pot furnaces are
exempt from the standard (550 pounds
charqina capacity) should be
increased. Owners of such very small
pot furnaces, i.e., less than one
cubic foot of capacity, should not
be bothered with conducting the
performance tests and submitting the
information required by EPA.
Emissions from bypasses should be
controlled.
Response
The only standard applicable to aot furnaces is the
opacity standard. The owner of a pot furnace is not
required to conduct the stack tests required of
owners of blast (cupola) or reverberatory furnaces.
Such emissions are prohibited by a revision to subpart A
of the General Provisions {40 CR 60), which requires
that all facilities subject to new source performance
standards must be, to the extent practicable, operated
and maintained in a manner consistent with good air
oollution control practice for minimizinq emissions.
62, 196
Fugitive dust emissions should be
controlled.
See response to L-7.
L-9 62
L-10 62, 196
New secondary lead smelters should
be required to locate in areas where
exposure of humans and domestic
animals to lead fallout will be
minimized.
The proposed standard should also
apply to existing smelters.
Section 110 of the Clean Air Act requires the states to
provide Implementation plans that, include a procedure
for reviewing the locations of new sources and preventing
their construction if attainment or maintenance of ambient
air quality standards will be prevented thereby.
This standard is promulgated under section 111 of the
Clean Air Act, which applies only to new or modified
sources. Existing stationary sources are requlated
by implementation plans under section 110; these plans
are formulated and enforced by the states but must
be approved by EPA.
Suhnart n Sec on d .^ry Rrajs and Bronze Ingot Proouction Plants
M-l 129
The brass and bronze ingot Industry
is not a significant source of air
pollution, no new source performance
standard should be promulgated for
this industry.
As with all sources for which new source performance
standards have been or will be specified, secondary
brass and bronze ingot production plant emissions
were considered first in the uncontrolled state.
Certainly, uncontrolled, these plants would be signifi-
cant sources of air pollution. The plants which operate
today control emissions to various degrees. State and
"ocal regulations vary in the limitations imposed on
such emissions. No sinqle standard is accepted
nationally. The best system of emission control is
riot found or required in all locations. The intent of
new source performance standards is to ensure
that future plants, and existing plants if they are
substantially modified, apply, as required by section 111
of the Clean Air Act, "... the best system of
emission reduction which (taking into account the cost
of achievina such reduction) the Administrator determines
has been adequately demonstrated." Thus, a new or
modified significant source of air pollution must
apply the best system of emission control regardless
of its location.
129, 150, 204
The visible emission standard should be
changed because (1) condensed water
vapor miaht be mistaken for emissions
of participate matter; (2) baahouses
result in "no visible emissions" rather
than in "less than 10 percent opacity",
(3) there is no basis for the 2-minute/
hour exemption; (4) there should be
a maximum opacity allowed during
exemptions, and (5) some normal opera-
tions last longer than 2 minutes and
result in emissions above the standard.
See the discussion of opacity standards in Chapters 2 and
7 of this document fYolunw 3).
132
-------
APPENDIX E (continued). SUMMARY OF COMMENTS AND RESPONSES PERTINENT TO NEW SOURCE
PERFORMANCE STANDARDS (40 CFR 60) PROPOSED IN FEDERAL REGISTER
OF JUNE 11, 1973 (38 FR 15406)
Comment
_no.
M-3
M-4
mentator
no.
204
129
M-6 204
M-7 129
M-fl 129
M-9 129
M-10 129
The term "reverberatory furnace" should
not be used to define a reverberatory
furnace. The definitions of electric
and blast furnaces should also be revised.
It is not clear if the performance test
is to be conducted while the affected
facility is operating at the maximum
production rate or while the control
device is operating at its maximum
rate; conditions at a plant may differ
since several affected facilities are
sometimes vented to the same control
device.
EPA data were collected primarily from
systems where a single furnace was
controlled by the baqhouse; it would
be much more difficult to comply with
the standard for systems ducting more
than one furnace to a single control
device. The present level of the
standard (0.022 qr/dscf) will probably
preclude the use of the latter control
system
Uhat is the basis for exempting
small furnaces {less than 1,000 ka/heat
or 250 kg/hour) from the standard'
The tonnage figures shown m the
test data summaries are not
comparable, some are based on
charge material while others are
based on metal produced
The test data on facility H show
a variation of from 4100 scfm
to 8000 scfm. The preliminary
facility description states that
two furnaces were in operation
during the test. This fact is
guestioned based on such wide
variations of the emission rates;
perhaps only one furnace was in
operation during part of the testing.
The cost of achieving a collection
efficiency in excess of 99 percent,
which is reguired to meet the
proposed emission level, is not
justified.
The investment costs presented in
the background document are low,
possibly due to the omission of
costs for flues, ducts, and
installation
Cadmium may be emitted from these
plants and the test method may not
measure it. Cadmium emissions should
be controlled because inhaling
cadmium can lead to ill health.
The intent ot the definition or reverberatory furnace
was to identify the types of reverberatory furnaces
covered by this reoulation, the definition has been
revised to clarify this intent. The definitions of
electric and blast furnaces are considered adequate.
The intent is to test emissions while the air pollution
control device is controlling emissions from the
number of furnaces that it would normally control,
these furnaces would then be required to operate at
their maximum production rates Where only some of
these furnaces are affected facilities (i e , new or
modified furnaces), then the Administrator's repre-
sentative at the test will determine representative
conditions. Recent changes to the General Provisions
(subpart A) make it clear that the conditions for
performance tcstinc shall be specified by the Administrate
All the tests to support the standard were conducted
under "normal" operation of the control device except
for the tests of facility F, which was operating one
furnace rather than the normal three of five furnaces
ducted to the same control device. It is true; that
the test data used as a basis for the emission limits
(A-j, B, and D} were collected with only one furnace
in operation, however, this is "normal" for these
plants At Plant A, only one furnace was ducted to the
control device; at Plant B, a sinale large (100 ton)
reverberatory furnace and two small (3/4 ton each)
electric furnaces were ducted to the control device,
but only the large furnace normally operates so it
was tested by itself, at Plant D, two reverberatory
furnaces were ducted to a single baghouse with seven
filter compartments, but normal plant procedure when
operating only one furnace was to use only four of the
seven compartments and this was the arranaement during
the test. The economic analysis assumed a single
furnace/control device system and showed no unduly
adverse economic impact on the industry. The multiple
furnace/single control device system was mentioned
only as a possible alternative, no evaluation as to the
feasibility, either economically or technologically,
was made.
Small furnaces are normally operated only intermittently
to produce specialty alloys and have lower emissions
dunnci production than do the larger furnaces Emissions
are not significant, and a baqhouse is not economically
justifiable on the basis of the data
True. These data were presented for information only
and were not a part of the basis for the emission
1 imitation
Two furnaces were in operation The control system
consisted of 3 baqhouses one venting the flue qases
from both furnaces, one venting the charging door
hoods, and one venting other emission points The six
test results represent two runs on each of the three
baghouse stacks The variations are from the different
baghouses
No supporting data accompanied this comment. EPA
analysis shows that the cost of achieving the emission
level is not sufficient to result in an unduly adverse
economic impact upon the industry
The investment costs presented did include these costs,
but the data were collected before 1971. It is possible
that the costs today could be 10 to 15 percent higher
due to general inflation
The proposed standard is not intpnded to L>ntrol cadmium
emissions. The effects of cadmium on health and
methods for controlling cadmium emissions are currently
being studied by EPA
-------
APPENDIX E (continued). SUMMARY OF COMMENTS AND RESPONSES PERTINENT TO MEW SOURCE
PERFORMANCE STANDARDS (40 CFR 60) PROPOSED IN FEDERAL REGISTER
OF JUNE 11, 1973 (38 FR 15406)
Commentdtor
no.
129
Commant
The NSPS requires that testing be
conducted in an undiluted gas strean
or that the amount of dilution be
determined by the source This is
not justified for the following
reasons: (1) EPA tests were conducted
in diluted qas streams with no attempt
to correct results for sucn dilution,
(2) dilution is necessary to cool
the furnace qases to safe operatinq
temperatures prior to the baqhouse,
(3) determining the amount of dilution
would be extremely difficult and
expensive since there are many points
in the process where the air induced
might be considered a diluent,
(4) from the EPA data presented,
it can be shown that the amount of
dilution air used t-1 cool the
furnace gases will vary widely as
a result of operator preference The
concentration standard proposed
(0 022 gr/dscf) will encourage the use
of more dilution, a standard of O.Ob
gr'dscf would allow trt source to L,V>
less dilution air and consequently
rmaht result in less m?ss emission
of oartirulates
Response
The intent of requiring that tests for compliance with
tie standard be based on measurements of undiluted qases
wss to show that dilution could not be used for the
purpose of complying with the standard Since such a
prohibition applies to all standards, this point is
made in an addition to subpart A, General Provisions,
which applies to all standards. Another recent change
to the General Provisions also makes it clear that the
conditions for performance testing shall be specified by
the Administrator, and the use of air to dilute for the
purpose of compliance will be disallowed in such
specifications. See the discussion of dilution air in
Chapter 2, General Considerations
197, 150, 43
197, 212
The visible emission standard should
apply to the rooftop or secondary
emissions as well e designed to
achieve emission concentrations con-
siderably lower than the limit
proposed (0 022 qr/hcf)
The visible emission standard should
be changed for the following reason*
(1) the opacity limitation is too
1enient It should snecify a zero nercent
limit, and (2} the background document
does not demonstrate that the 10
percent opacity limit is achievable,
nor does it take intn account the
economic or environmental impact of
the opacity limit as opposed to the
concentration limit
Secondary emissions result during tapping, charging, and
het metal transfer operations Technology for control
of these emissions was neither observed nor known to
e>ist at any BOPF shop in the wor'd, and an engineering
assessment determined that the development of an emission
standard was not technically feasible.
See the discussion of opacity standards In Chapters 2 ano
8 of this document (Volume 3).
See the discussion of opacity
8 of this document (Volume 3)
standards in Chapters 2 and
134
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Comment
no.
APPENDIX E (continued). SUMMARY OF COMMENTS AND RESPONSES PERTINENT TO NEW SOURCE
PERFORMANCE STANDARDS (40 CFR 60) PROPOSED IN FEDERAL REGISTER
OF JUNE 11, 1973 (38 FR 15406)
Commentator
no.
Comment
The concentration standard set for
particulate matter emissions is
liberal in comparison to the
Allegheny County regulation.
The standard should be more explicit
:n its definition of dilution air.
As presently worded, it is not clear
whether or not combustion air is
considered to be dilution air.
Wording of the standard does not
limit applicability only to
emissions from the control device.
Response
The form of the Allegheny County regulation does not
support direct comparison with the new source performance
standard. Allegheny County's regulation is a mass
emission limitation applicable to many types of industrial
sources, and it is based on a formula dependent upon
empirical relationships developed locally. The emission
limitation varies with charging rates. This approach
to regulating emissions has considerable merit and can
be applied well to defined local conditions. It is not
practical to apply on a national scale to new sources.
The intent of requi^nq that tests for compliance with
the standard be based on measurements of undiluted gases
was to show that dilution could not be used for the
purpose of complying with the standard. Since this
prohibition applies to all standards, this point
is made in a chaiqp to suboart A, General Provisions,
which applies to all standards. In addition, another
recent change to the General Provisions makes it clear
that the conditions for performance testing shall be
specified by the Administrator, and the use of air to
dilute for the purpose of compliance will be disallowed
in such specifications. See the d1s.cus.s1on of dilution
air in Chapter 2, General Considerations
The standard is intended to apply only to emissions from
the control device The test method requires that
emissions be sampled in either a stack or a duct. The
outlet of the control device is the only logical location
at which to samolf1.
Subpart 0 Sewage Treatment Plants
155
178
192
£1! tests should have been conducted
while the units were operating at
full capacity because reduced guanti-
ties of gas passing through the
scrubber affect collection efficiency
Low feed rates make results from
Plants B, C, and E questionable.
Test results show decomposition of
chlorine-containing compounds in
sludge during incineration This
is not discussed in the background
report on environmental impact.
Impact of standard on ambient air
quality is not discussed.
Low sludge feed rates in multiple-hearth incinerators do
result in decreased qas flow rate through the scrubber.
Impinqenent scrubber efficiency would be reduced under these
conditions, >>ut a venturi scrubber can be designed with an
adjustable throat that maintains collection efficiency
through a wide ranae of nas flow rates Reduced scrubber
efficiency does not, however, mean that emissions must
increase at lower sludne burninq rates. For example, for
the three nlants with impingement scrubbers (Plants B, C,
and D) and the one riant with a cyclonic scrubber {Plant r)»
emissions in Ib/ton of dry sludge varied not with percent
of design feed rate but rather with amount of pressure drop
A designer of multiple-hearth units suggested that the
effect of decreased gas flow throuoh the scrubber is compen-
sated for by reduced turbulence in^the incinerator, which
results In less fly-ash entralnment and lower inlet grain
loading
At the facilities tested, chlorine emissions (as HCT) were
minor for example, effluent qases at one of the facilities
tested (Plant A) contained less than 10 ppm Cl. This
amounts to less fian 0 056 pound of chlorine per hour and
will have little, if any, effect on the environment.
It is not practical or meaningful to make general determina-
tions of changes in ambient air quality that might be
caused by new or modified sources EPA does not know
where such sources will be built, and many specific factors,
suci as topoaraphy, meteorological conditions, proximity
of other pollution sources, and guantities emitted from
dl? sources, will have great impact on air quality in
'cific locations
spe
192
Technology 15 not really demonstrated
to be available
It seems remarkable to note that the
annual cost per person is 50 percent
more where an incinerator must meet
the new source performance standard
instead of "typical local standard."
Telling us that the proposed new
standard costs $0.04 per year more
per person without stating that this
is 50 percent more is hardly "truth
in advertising "
One plant tested (Plant A), a typical facility except
for the more effective scrubber, easily met the
new source performance standard.
As EPA data show, the cost of meetina the local standard
is 8 cents per person per year and the cost of meeting
EPA's standard is 12 cents per person per year. True,
the additional 4 cents is a cost increase of 50 percent,
but the actual amount remains insignificant Percent
figures are often misleading In this case, expressing
the increase in terms of 4 cents per person per year
portrays the economic impact of the standard more
clearly than does a percentage.
135
-------
APPENDIX E (continued). SUMMARY OF COMMENTS AND RESPONSES PERTINENT TO NEW SOURCE
PERFORMANCE STANDARDS (40 CFR 60) PROPOSED IN FEDERAL REGISTER
OF JUNE 11. 1973 (38 FR 15406)
0-6
0-7
155
197
0-9
0-10
Comment
Cost figures do not take into account
(1) additional space required for
a venturi scrubber, and (2) addition
of an aftercooler.
The standard should also regulate
participate emissions from scum-
burning and ash-handlinq activities.
It is not clear from the defimticr
of sewaqe whether or not tie standard
is applicable to sludge incinerators
in industrial so^np tr'Mtr"1"*1 nlarts
An odor regulation is needed in addi-
tion to the particulate emission
regulation. Multiple-hearth and
some fluidized-bed incinerators emit
odors because exhaust qases are not
adequately exposed to hiqh temperatures
Data in the January 1973 EPA Task Force
Report on sewaqe sludge incinerators
show that even we!1-controlled incin-
erators cannot meet the proposed
standard.
Response
Venturi scrubbers, normally installed vertically,
require no additional floor space; floor space required
by the extra pumps is not considered significant. An
aftercooler is not considered necessarv to meet the
standard.
11, '/as not considered necessary to specify that the
standard applied to scum burninq. Scum is usually incin-
erated alonq with sludqe because it has a higher Btu
content than sludqe. Incineration of scum actually de-
creases the auxiliary fuel required per pound of material
fod to the incinerator. At the well-controlled plants
visited, ash-handling activities did not qenerate any
visible particulate emissions.
Tdf reoulations have beer revised to clanf" that only
municipal sewaqe sludqe incinerators are affected by
the standard
EFA assessed odors at both multiple-hearth and fluidized-
bed incinerators. The absence of any odor problems
indicates that the exhaust qases are adequately exposed
tc hiqh temperatures.
The Task Force Report contained preliminary test results,
some of which chanqed as calculations were checked. The
ccrrected results, which were published in Volume 2 of
tHs document show that sewage sludge incinerators ca"
meet the standard.
0-11
0-12
)78
113
0-13
155
0-H
0-15
155
155
The regulations include combustion
air as dilution air. Treatment of
EPA data in the background documents
makes it obvious that EPA did not
intend this. The regulations should
be revised to allow combustion air
to be added to the incinerator.
The concentration standard needs a
reference basis such as a correction
to 12 percent C02-
Is EPA sayinq that only venturi
scrubbers can meet the standard7
EPA states on page 60 of the back-
ground document that control
equipment manufacturers will
guarantee 0.03 grain per dry
standard cubic foot. What are the
manufacturers' names'
How does the Massachusetts regula-
tion {0.05 grain per dry standard
cubic foot at 12 percent C0;>}
compare to EPA's regulation (0.031
grain per dry standard cubic foot}?
The regulations have been revised to (1) express the
standard in pounds particulate per' ton of dry sludqe
fed to the incinerator, and (2) delete the require-
ments concerning dilution air. This permits combustion
air or dilution air to be added without invalidatinq
the test because the test results in pounds per ton
sludqe are not affected by dilution
Acree, because the amounts of combustion air and coolino
air admitted to the system vary from plant to plant,
EFA considered usinq C02 content as a reference basis,
hi,t the scrubbers used to control participate also
absorb some of the C02- Mass emission units of pounds
perticulate per ton dry sludqe were finally selected
as the best approach to establishing a common reference
basis because dilution of the exhaust gas does not
aifect actual mass emissions.
Nc, but venturi scrubbers seem to be the most economical
choice. Impinaement scrubbers tested by EPA did not
meet the standard but, in our best, judqment, would do so
if used in conjunction with an oxyqen meter that
automatically reaulates fuel burninq rate. In our best
judgment, electrostatic precipitators could also orovide
mere than adequate control. There1 are no EPA test data
or either of these control systems because dun no the
test proqram there were no existing plants usinq them.
EPA has removed this statement from the background
document. Some manufacturers stated to EPA that their
systems could meet the standard, but have provided no
specific, written guarantees. Because one of the
incinerators tested by EPA meets the standard, lack
of guarantees does not imply inability to meet the
standard.
EF'A took C0£ data from all incinerate s tested, but
found that the percentage of CO? varied from plant to
plant and from test to test. Tn1;. variation, sometimes
significant, precludes any direct comparison of the
two standards.
136
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APPENDIX E (continued). SUMMARY OF COMMENTS AND RESPONSES PERTINENT TO NEW SOURCE
PERFORMANCE STANDARDS (40 CFR 60) PROPOSED IN FEDERAL REGISTER
OF JUNE 11, 1973 (38 FR 15406)
Comment
no.
Commentator
no.
TM-1 94, 204
TM-2
TM-3
143, 176,
182, 222
221
TM-4
TM-5
TM-6
TM-7
TM-8
TH-9
125
251
250
239
174, 234
129
Comment
nesponse
Test Methods
Delete use of "alternative test Commentators have misinterpreted the Intent of allowing
methods."
The regulations for
individual affected
facilities should specify
that the use of alternative
or equivalent test methods
is allowed.
The General Provisions
concerning performance tests
should be changed to: (1) in-
clude industry-accepted test
methods as equivalent,
(2) revjse the wording asso-
ciated with alternative method
from "adequate for indicating"
to "reasonably indicate," and
(3) require EPA to publish
alternative test methods in the
Federal Register.
alternative methods. The misinterpretation is due in
part to the wording in the Preamble to the proposed Group II
standards, where two examples of alternative methods were
given. These examples imply that a wide range of alternatives
is possible with use of suitable correction factors. In
actuality, correction factors may be difficult to obtain
without inordinate amounts of testing.
The intent of allowing alternative methods was to reduce the
complexity and cost of source testing where such reductions
would not significantly increase the chances of violating the
standard. Determination of the acceptability of a proposed
alternative method would be made by the Administrator after
an intensive review of the proposed method, the source, the
control system, the operator, and comparative data.
Agreed. The appropriate section of each subpart has been
revised to indicate that equivalent or alternative methods
are allowed.
(1) Industry-accepted methods should not be accepted without
due evaluation by EPA. A source may use equipment or
procedures that have been found to yield invalid results;
some mechanism for checking these procedures must be
available.
(2) The word change does not seem to alter the meaning or
intent of the proposed regulation.
(3) This procedure has been considered by EPA. However, a
multiplicity of alternative methods may be proposed, and
publishing of all may well prove too voluminous to be
reasonable. Instead, EPA now plans to publish on a
periodic basis in the FEDERAL REGISTER a list of sources
for which alternative methods have been approved. Further
information could then be obtained upon request. No
specific references to these procedures are deemed neces-
sary in the regulations.
Iodine number flasks should not The term "iodine number flask" is confusing; nomenclature has
be used because sampling errors been changed to "iodine flask" for clarity.
are greater than with plain
flasks.
Normal cubic meter generally
refers to a cubic meter at 0°C
and 760 mm Hg, but EPA has
defined normal conditions
as 21.1°C and 760 mm Hg.
The definition of particulate
matter implies a return to
the entire train; i.e.,
front half and back half, for
these regulations.
When a specific test method
is cited, reference to its
location in the FEDERAL
REGISTER should be included.
Typographical and other errors
in Methods 10 and 11.
Dilution air should be
allowed.
137
"Normal cubic meter" has been changed to "dry cubic meter at
standard conditions" (dscm), with standard conditions defined
as 20°C and 760 mm Hg.
This was not the intent, and EPA feels that we did not so
imply.
Referencing one specific FEDERAL REGISTER publication would not
be prudent. Test methods quite often undergo changes for
clarification and simplification, and reference to any specific
version would hamper adoption of new or better procedures.
Corrected.
The intent of requiring that tests for compliance with the
standard be based on measurements of undiluted gases was to
show that dilution could not be used for the purpose of comply-
ing with the standard. Since such a prohibition applies to all
-------
APPENDIX E (continued). SUMMARY OF COMMENTS AND RESPONSES PERTINENT TO NEW SOURCE
PERFORMANCE STANDARDS (40 CFR 60) PROPOSED IN FEDERAL REGISTER
OF JUNE 11, 1973 (38 FR 15406)
Comment
no.
Commentator
no.
TM-10
133
TM-H
255
163
TM-13
TM-14
125, 247
148
TM-15
TM-16
197
166
Comment
Minimum training should be
required for test personnel.
Permissible isokinetii, varia-
tion should be + 20 percent.
Method 10:
(1) IIlustrations and
descriptions of sampl'no
devices and trains arv
inadequate
(2) Use of the qrab-s.inpl ing
train is not clea
(3) Purging provision jic-
inadequate.
(4) The sampling tram can
be dangerous if tne
sample inlet 1ine is
blocked during calibra-
tion
(5} Orsat analysis could be
eliminated by usincj
solid absorbers for ,1,0
and
Method 10 is not specific
enough as to when initial
zero and span checks ,hould
be made.
Method 10
(1) Much better performance
specifications are attain-
able with his equipment, and
(2) the H20 and C02 traps
could be eliminated with
such equipment.
For method 10, calibration
gases should be chemically
calibrated.
The sample time speci ried
in subpart J, Petroleun
Refineries, does not agree
with that given in method
11
Response^
standards, this xnnt is made in a change to subpart A,
General Provisions, which applies tc all standards In
addition, anothe" recent change to the Genera Provisions
makes it clear tiat the conditions for performance testing
shall be specified by the Administrator; the use of air to
dilute for the pjrpose of roinpl lance ^il" be d'sallowed in
such speciI cations
The comment has mer^t but wojld oe jery difficult to irnplenent.
Sampling capability is greatly deperdent upon experience, much
le^s so on education Further, published procedures are very
detailed, so that operator judgment is held to a minimum
Finally, a test :eam will typically consist oi at least a
leader and an operator, with larger testi, requiring propor-
tionately larger teams, the more people invoUed, the less the
inexperience of one person will affect the results. This is
in contrast, for example, with an opacity reacer who typically
works alone and .herefore is required to update his skills
periodically
This recommendation is based on theoretical wctk by the
coimentatoi This approach was initially use: (36 FR 15704)
and then criariyed (36 FR 24876} to the present method. The
original method was based on attempts to ensure concentration
results within +_ 10 percent. However, evaluation of data frori
hundreds of test<> showed that + 10 percent isckinetic can be
maintained virtually all of the tine Concentration results
ar^- trus witMr. - £ percent
The .oMment wcis naat after ovaluatiur of EPA ddta indicated
th it the Cf'A requirement of * 10 nor cent iSfkinetiL had not
been net i r Suir-t i ns tan^es Ret - U il ati i n o1 tiiose spec i f i c
test insults showed that tne original reports were in error
ar.'l J at *- 1J pet cent had in fact been achieved
,is oeen
change:1
', 3 ) 1 ML' pur ; i n q t fj'jL i r events are tne sa" e as ' r ose def i nco in
3 ard h i . e been jsed sue :essf i 1 1 y t,, r nary years .
, ^(ut he possiMl.ty of this happeriny is very
so Ji nq ! /
The tt'St i _UiG'3 'pecities ttuit the^e opyfdtioi , art? to Le
performed ooth bffore and after the test
Item (1) of the loi.ient ir_ probably true, however, the purport
of definin] ['erfnr ance specifications is not to retiect best
available ins ti unentation, but rather to establish iinninum
acceptabl e p&rf orn>a nee cri ten a Item (2) is probably rot
true at thd observed stact concentrations.
LPA consid-rs t"e chemical methuns iecommendec ro be less
accurate t'ian those employed by the ranuTactur ers Calibra-
tion c erti f icatu>n by the r.idnufactur er is now specified in the
regulation
True, Subpart
method 11
has
138
-------
APPENDIX E (continued). SUMMARY OF COMMENTS AND RESPONSES PERTINENT TO NEW SOURCE
PERFORMANCE STANDARDS (40 CFR 60) PROPOSED IN FEDERAL REGISTER
OF JUNE 11. 1973 (38 FR 15406)
Comment
no.
TM-17
Commentator
no.
163
212, 247
TM-19
143, 166,
176, 182
Comment
Method 11 :
(1) The midget sampling
train is not efficient.
(2) Universal Oil Products
(UOP) method 212-72
should be used instead
of method 11.
Recommend use of Inter-
society Committee (1C)
Method 701 in place of
method II because with
method 11 the sampling
time is too long and inter-
ference can bias the results
Morn toring instruments
do not need zero adjust-
ment and calibration
every 24 hours, as
required for emission
monitoring in suhpart J,
Petroleum Refineries.
The regulation should
instead require that
these operations be
performed only as often
as necessary or thut the
instrument be kept in
proper operating condition
to meet allowable tolerance^
Response
(1) EPA has performed tests to evaluate collection efficiency,
and 100 percent efficiency was obtained in tests using
about 500 ppiii H?S
(2) An evaluation of the proposed method indicates that it pay
well be acceptable, although it may be more cumbersome and
difficult to use than method 11. The commentator has the
option of submitting his method to EPA as an equivalent or
alternative method.
The 1C method may well be equivalent and may be approved as
such upon presentation of data. However, method 11 was used
for the EPA tests and it must continue to be the reference
method, or all tests will have to be repeated.
EPA evaluations indicate that S02 is the only major potential
interferent at this source. Therefore, method 11 was modified
by adding a fifth impinger to remove any SO;?. The effect of
this change was verified in a series of laboratory tests.
This requirement may not be strictly applicable or necessat y
for all instruments. However, assurance is needed that zero
and calibration are being maintained on at least a daily basis
The procedures for this vary with the type of instrument
involved In some cases zero and calibration may be automatic
or may be inherent in the instrument, in some cases, zero and
calibration can be performed manually with minimal effort,
and in sone cases zero and calibration checks are more diffi-
cult lo date, EPA has not evaluated ot utilized instruments
in this application, and we are therefore not able to provide
a .'lor P definitive calibration specification, or to provide for
any exceptions A program is ^urreni. ly being undertaken to
obtain needed information On the oasis of this, further
gjidance or a revision in the zero and calibration requirement
will be pt0;ided
139
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-------
Page
no.
2
4
5
5
9
9
9
10
10
10
Paragraph
no. a
3
Table 1
2
3
Figure 1
Figure 1
2
Figure 2
Figure 2
APPENDIX F. ERRATA FOR
BACKGROUND INFORMATION FOR PROPOSED
NEW SOURCE PERFORMANCE STANDARDS:
VOLUME 1, MAIN TEXT (APTD-1352a)
Line
no.
Correction
INTRODUCTION
Last word of line should be "no" instead
of "not"
The first number in the second column
(Allowable emission rate) should be
"0.30" instead of "0.03"
Change "all" to "these"
Change "all" to "these"
ASPHALT CONCRETE PLANTS
1-3
The number "0.03" should be "0.031"
Caption should read: "Partially
controlled hot-mix asphalt concrete
plant."
The label "HOT SCREENS" should be "HOT
AGGREGATE SCREENS"
Delete the first sentence and replace
it with the following: "The proposed
standard requires that emissions from
a plant with only a cyclone dust
collector be reduced by about 99.7
percent. The proposed standard can be
met by using fabric filters or medium-
energy venturi scrubbers, normally
preceded by a cyclone or multiple
cyclone, to collect dust from the
dryer (Figure 2)."
The label "HOT SCREENS" should be "HOT
AGGREGATE SCREENS"
The duct leading from PRIMARY DUST
COLLECTOR TO BAGHOUSE should not have
a duct leading from it to
FILLER FINES STORAGE
a
A partial paragraph beginning a page is designated paragraph no. 1.
141
-------
Page
no.
10
11
11
11
11
12
12
12
12
12
12
13
13
Paragraph
no
4
1
1
2
3
4
5
6
8
8
8
1
1
Line
no.
1
3
4
2
1
7
2
3-5
7
9
10
6
7
13
13
13
13
5
5
Correction
Change "(0.031 dscf)" to "(0.031
gr/dscf)"
Change "Eight" to "Seven"
Add the following as the last
sentence of the paragraph: "One
plant scheduled for testing closed
for the winter before the arrival
of the EPA test crew."
Change "Nine" to "Eight"
Delete the parenthetical material:
"(three samples per test)"
Change reference number from "5" to
The number "0.030" should be "0.020"
Delete lines 3-5 ("The replacement...
change in fuels.")
Change reference numbers from "1, 5-9"
to "1, 6, 8, 9, 10"
Change "such" to "so"
Change line to read: "from baghouses
are nearly the same over the wide
variety of aggregate feedstocks
typically used by asphalt concrete
plants.5. 8-13 This is further"
Change "...aggregate was used..." to
"...aggregate fines were used..."
Delete the phrase "of only 4.5:1."
and insert in its place the following:
"of more than 50 times less than the
proposed standard."
Change "collection, maintenance, and
operation" to "collector maintenance
and operation"
Change "...require installation and
proper maintenance. .." to "...require
proper installation, operation, and
maintenance. . ."
Change "10" to "about 6.6"
Change the period after "years to
a comma and insert the following:
"and new plants have been installed
at the rate of 250 to 260 per year.'6"
142
-------
Page Paragraph Line
no. no. no. Correction
13 5 3 Change "increase" to "increased"
13 56 Insert reference number "16" at end
of paragraph.
14 2 3 Delete the phrase "for either size
plant" and Insert in Us place "for
a given size plant"
14 52 Change "...new plant should..." to
"...new plants should..."
15 - - Insert reference 16 as follows:
"16. A Systems Analysis of the
Production and Laydown of Hot Mix
Asphalt Pavement. Texas Engineering
Experimental Station, Texas A&M
University, College Station, Texas.
1970 study funded by NAPA. p. 41."
15-16 - - Change reference numbers 16 through
22 to reference numbers 17 through 23.
PETROLEUM REFINERIES, FLUID
CATALYTIC CRACKING UNITS
19 5 1 Change "three" to "four"
19 5 3 Change "average" to "averaged"
19 5 3 Change "three" to "two"
21 2 1 Change "three" to "four"
PETROLEUM REFINERIES, BURNING
OF GASEOUS FUELS
25 1 4 Insert a period after "releases"
and delete "or to the burning of
liquid or solid fuels in the same
heaters and boilers."
26 33 The number "13" should be "10"
27 1 6 The number "13" should be "10"
27 3 7-8 Insert a period after "disposal"
and delete "by Incineration or
landfill."
28 1 4 Change "discernable" to "discernible"
28 1 5 The number "13" should be "10"
STORAGE VESSELS FOR
PETROLEUM LIQUIDS
No corrections
143
-------
Page
no.
Paragraph
no.
45
45
45
45
45
45
45
45
45
46
46
46
2
2
2
5
5
6
6
Figure 21
Figure 21
Line
no.
SECONDARY LEAD SMELTERS
AND REFINERIES
No corrections
SECONDARY BRASS OR BRONZE
INGOT PRODUCTION PLANTS
Correction
After "...(cupola) furnaces." insert
the following two sentences: "Figure
21 shows two types (stationary and
rotary) of reverberatory furnaces
operating at the same plant since this
arrangement is typical in medium-to-
large plants; the stationary type can
be designed to produce much larger
batches of metal, but the rotary type
is more economical when the demand is
for smaller quantities of a particular
alloy of brass or bronze. Blast furnaces
(cupolas) are normally found only at the
larger plants where it becomes practical
to recover metal from the slag of the
reverberatory furnaces; electric furnaces
are alternatives to rotary-type
reverberatory furnaces."
Change "blast" to "reverberatory"
Change "reverberatory" to "blast"
Change "less" to "more"
Delete parenthetical material:
"(Figure 21)"
Change "Emissions from electric
furnaces are..." to "The composition
of emissions from electric furnaces
is..."
Delete the words "process and"
Change "...scrubber has..." to "...
scrubber or electrostatic precipitator
has..."
Change "scrubbing" to "this control"
The label "REVERBATORY FURNACE"
should be "STATIONARY FURNACE"
The caption should read: "Controlled
secondary brass and bronze reverbera-
tory furnaces."
Change "plant" to "control equipment"
144
-------
Page Paragraph Line
no. no. no. Correction
46 6 1 Change "...at each plant. The tests..."
to "...at each plant where the tests..."
47 1 3 Change "tests" to "individual sample
results"
47 22 Delete the number "0.0125" and insert
in its place the numbers "0.012, 0.013,"
so that the line reads: "0.002, 0.005,
0.010, 0.012, 0.013, 0.014, and 0.017
gr/dscf..."
47 3 2-3 Delete last sentence of paragraph
("No visible...by EPA.") and replace
it with the following: "Plants E
and F, which were previously tested
by EPA, were observed to have no
visible emissions."
47 4 1 Between "gr/dscf" and semicolon,
insert the following phrase: "using
test code method 4"
47 44 Delete "is similar." and insert "and
composition of emissions are similar,
and the uncontrolled emission rate
is less from an equivalent-size
electric furnace. During an EPA
inspection of an electric furnace
facility, the facility was operating
with no visible emissions."
IRON AND STEEL PLANTS
50 8 1 Delete "that are specifically for"
and replace with "applicable to"
50 82 Delete "0.1 to 0.2...0.090 gr/scf"
and replace with "0.01 to 0.09 gr/scf."
50 83 Change "77" to "17"
50 84 Change "Section" to "section"
SEWAGE TREATMENT PLANTS
57 1 3 Insert "municipal" between "all"
and "sewage"
59 23 Change "previsous" to "previous"
145
-------
-------
APPENDIX G. ERRATA FOR
BACKGROUND INFORMATION FOR PROPOSED
Page No.
NEW SOURCE PERFORMANCE STANDARDS:
VOLUME 2, APPENDIX: SUMMARIES OF TEST DATA (APTD- 13525)
Correction
HOT MIX ASPHALT CONCRETE PLANTS
Change indicated numbers in
Table A-l. ASPHALT CONCRETE
Run number 1
Stack Effluent
Flowrate, dscfm 17,
Flowrate, dscf/ton
product 9,
Particulate emissions
Probe and filter catch
Ib/hr 0.
Ib/ton of product 0.
Total catch
Ib/hr 4.
Ib/ton of product 0.
Table A-3. ASPHALT CONCRETE
Run number 1
Stack effluent
Flowrate, dscfm 22,
Flowrate, dscf/ton
product 6,
tables as follows:
FACILITY A1
2 3
* * *
333 17,122 17,548
285.5 11,543 10,743.6
* * *
* * *
85 1.11 1.01
0135 0.018 0.016
* * *
05 2.78 2.76
065 0.044 0.044
* * *
FACILITY B
2 3
* * *
375 22,392 23,907
613 6,785 6,078
* * *
Average
17,344
10,432
0.99
0.016
3.21
0.051
Average
22,891
6,469
Particulate emissions
Probe and filter catch
147
-------
Page No.
(continued)
Correction
11
15
Ib/hr 1.53 1.92 1.32
Ib/ton of product 0.007 0.01 0.006
Total catch
* * *
Ib/hr 19.31 10.54 3.42
Ib/ton of product 0.095 0.053 0.014
* * *
Table A-5. ASPHALT CONCRETE FACILITY D
Run number 1 2 Average
* * *
Stack effluent
Flowrate, dscfm 25,213 25,361 25,287
Flowrate, dscf/ton
product 6,845 6,503 6,465
* * *
Partlculate emissions
Probe and filter catch
* * *
Ib/hr 2.61 4.88 3.75
Ib/ton of product 0.012 0.021 0.016
Total catch
* * *
Ib/hr 11.1 27.84 19.4
Ib/ton of product 0.05 0.119 0.085
* * *
Table A-9. ASPHALT CONCRETE FACILITY H]
Run number 1 2 3
* * *
Stack effluent
Flowrate, dscfm 30,002 29,887 27,969
Flowrate, dscf/ton
product 10,228 9,291 9,871
* * *
1.59
0.007
11.09
0.052
Averagi
29,286
9,762
Particulate emissions
Probe and filter catch
148
-------
Page No. Correction
15 Ib/hr 7.98 8.70 6.99 7.89
(continued) Ib/ton of product 0.045 0.045 0.041 0.044
Total catch
Ib/hr 12.75 27.79 13.29 17.94
Ib/ton of product 0.072 0.144 0.078 0.100
PETROLEUM REFINERIES
FLUID CATALYTIC CRACKING UNITS
23 Facility C: Delete last sentence ("During ...unit.") and replace
it with the following: "The electrostatic precipitator consisted
of two identical parallel precipitators vented to separate stacks.
During the test, a malfunction occurred in one precipitator,
invalidating the particulate test results obtained on stack B.
Data analyses are thus based on particulate test results obtained
on stack A."
23 Facility D: On line 5 after "occurred" and before the comma,
insert the phrase "in the carbon monoxide boiler"
28 Table A-19: Delete reference to footnote b on "Particulate
emissions" and add reference to footnote b to the particulate
emission numbers listed under stack B. That section of the
table then reads as follows:
Particulate emissions
Probe and filter catch
gr/dscf 0.0380 0.1066? 0.0369 0.0589? 0.0352 0.0450? 0.0367 0.0702?
gr/acf 0.0182 0.0499? 0.0167 0.0282?, 0.0169 0.0213° 0.0173 0.0331?
Ib/hr 29.7 85.5° 27.8 49.0° 27.4 36.5° 28.3 57.0D
Total catch
gr/dscf 0.2366 0.2092u 0.2159 0.1776? 0.2088 0.1775? 0.2204 0.1881?
gr/acf 0.1136 0.0979? 0.0978 0.0851? 0.1006 0.0840? 0.1040 0.0890?
Ib/hr 184.8 167.8D 162.5 148.0° 162.7 143.8 170.0 153.2°
28 Footnote b: Add the phrase "for stack B." to the end of the
footnote.
29 Table A-20: Add footnote reference to title as follows: "CATALYTIC
CRACKING FACILITY D, SUMMARY OF RESULTS3"
29 Add footnote below table as follows: '^Malfunction of test
equipment invalidated particulate test results."
SECONDARY LEAD SMELTERS AND REFINERIES,
BLAST AND REVERBERATORY FURNACES
33 Table A-22: The numbers in the category "Visible emissions, %
opacity" for run number 2 should be "10 to 20" instead of "10
to 70"
149
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Page No. Correotlon
SECONDARY BRASS AND BRONZE REFINING
42 Facility B: Add the following sentence to the end of the
description: "Baghouse also controls emissions from two small
(1500 Ib) electric furnaces, but they are not normally used
and were not used during the tests."
42 Facility D: Add the following sentences to the end of the
description: "Two furnaces are ducted to the baghouse, but
only one was in operation during the test. Only four of the
seven baghouse compartments are normally used when a single
furnace is operating and this procedure was followed during
the tests."
43 Facility E: Add the following sentence to the end of the
description: "Baghouse also controls emissions from two other
gas-fired 100-ton reverberatory furnaces that were not operating
during the tests."
43 Facility F: Add the following sentences to the end of the
description: "Baghouse also controls emissions from four other
rotary furnaces that were not operating during the tests.
Typically, three of the five furnaces operate at once."
43 Facility I: Add the following sentence to the end of the
description: "Baghouse also controls emissions from three other
rotary furnaces that were not operating during the tests."
44, 46 Tables A-31 and A-33: The numerical entries for the side heading
"Visible emissions, % opacity" should be 0 instead of <10.
46, 47, 48 Tables A-33, A-34, and A-35: Delete the side heading "Excess
air at sampling point, %" and its numerical entries.
48 Table A-35: The numerical entries for the side heading "Emissions.
% opacity" should be 0 instead of <10 for runs 2 and 3.
49 In footnote a, "analysed" should be changed to "analyzed"
51 Table A-38: Add to the end of the table title a superscript
"a"; then add footnote a at the bottom of the table as follows:
"a Tested using Code Method 4."
IRON AND STEEL MILLS
No corrections
SEWAGE TREATMENT PLANTS
No corrections
150
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing]
1 REPOR F NO
EPA-450/2-74-003
3. RECIPIENT'S ACCESSION>NO.
4 TITLE AND SUBTITLE
BACKGROUND INFORMATION FOR NEW SOURCE PERFORMANCE
STANDARDS: Asphalt Concrete Plants, Petroleum Re-
fineries, Storage Vessels, Secondary Lead Smelters
and Refineries, Brass and Bronze Ingot Production
Plants, Iron and Steel Plants, and Sewage Treat-
ment Plants. Volume 3, PROMULGATED STANDARDS.
5. REPORT DATE
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO.
9 PERFORMING OR"ANIZATION NAME AND ADDRESS
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Research Triangle Park, N.C. 27711
February 1974
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
13. TYPE OF REPORT AND PERIOD COVERED
14. SPONSORING AGENCY CODE
15 SUPPLEMENTARY NOTfcS
16 ABSTRACT
This volume is the third in a series on standards of performance for asphalt
concrete plants, petroleum refineries, storage vessels for petroleum liquids,
secondary lead smelters, brass and bronze ingot production plants, iron and steel
plants, and sewage treatment plants. The first two volumes gave background
information and the data base for the proposed standards. This volume presents
the promulgated standards and the rationale for any changes that were made, with
particular attention to the problems of opacity and dilution air. Major comments
received during the period for public comment are discussed where appropriate
and are summarized with Agency responses in the appendix. The appendix also
contains a list of commentators, new data for asphalt concrete plants, revised
economic analyses for asphalt concrete plants and petroleum refineries, and
errata for Volumes 1 and 2.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
Air pollution
Pollution control
Performance standards
Asphalt concrete
plants
Petroleum refineries
Lead smelters and
refineries-
Brass ingot
production
Bronze ingot
production
Steel production
Sewage treatment
DISl RIBUriON ST A IF ME NT
Unlimited
b.lDENTIFIERS/OPEN ENDED TERMS
Air pollution control
19. SECURITY CLASS (This Report)
Unclassified
20 SECURITY CLASS (Thispage)
Unclassified
- FA FJi-n :it<> 1 (9-73)
c. COS AT I Field/Group
21. NO. OF PAGES
158
22. PRICE
151
U.S. GOVERNMENT PRINTING OFFICE) 1074747-793/35B
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