United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park, NC 27711
EPA-453/R-94-060
August 1994
Air
EPA
Rationale for New Source Performance
Standards: Starch Production Plants
ENVIRONMENTAL
PROTECTION
AGENCY
DALLAS, TEXAS
LIBRARY
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EPA-453/R-94-060
RATIONALE FOR NEW SOURCE PERFORMANCE STANDARDS:
STARCH PRODUCTION PLANTS
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
August 1994
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TABLE OP CONTENTS
Section Page
1 BACKGROUND 1
1.1 NEW SOURCE PERFORMANCE STANDARDS--GENERAL .... 1
1.2 SELECTION OF SOURCE CATEGORY 1
2 RATIONALE FOR THE PROPOSED STANDARDS 3
2.1 SOURCE CATEGORY TO BE REGULATED 3
2.2 POLLUTANT TO BE REGULATED 3
2.3 AFFECTED FACILITIES 3
2.4 SELECTION OF BEST DEMONSTRATED TECHNOLOGY .... 4
2.5 PART 70 PERMITS 6
3 PROPOSED STANDARDS 7
3.1 PARTICULATE MATTER AND VISIBLE EMISSIONS
STANDARDS 7
3.2 MONITORING AND COMPLIANCE REQUIREMENTS 12
3.2.1 STARCH DRYERS 13
3.2.2 DEXTRIN ROASTERS 14
3.2.3 STARCH TRANSFER, STORAGE, AND LOADING
FACILITIES 15
3.3 REPORTING REQUIREMENTS 16
4 SUMMARY OF COST, ENVIRONMENTAL, ENERGY, AND ECONOMIC
IMPACTS 18
4.1 COST IMPACTS 18
4.2 ENVIRONMENTAL IMPACTS 19
4.3 ENERGY IMPACTS 19
4.4 ECONOMIC IMPACTS 21
5 REFERENCES 22
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LIST OF TABLES
Table Page
1 SUMMARY OF PROPOSED NSPS REQUIREMENTS-STARCH DRYERS . 8
2 SUMMARY OF PROPOSED NSPS REQUIREMENTS-DEXTRIN ROASTERS 9
3 SUMMARY OF PROPOSED NSPS REQUIREMENTS-STARCH TRANSFER,
STORAGE, AND HANDLING FACILITIES 10
4 SUMMARY OF ENHANCED MONITORING OPTIONS 20
5 SUMMARY OF ENHANCED MONITORING ANNUAL COSTS 20
6 SUMMARY OF ENHANCED MONITORING ANNUAL COSTS-MODEL PLANT
BASIS 20
ill
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BACKGROUND
1.1 New Source Performance Standards--General.
New source performance standards (NSPS) implement section
111 of the Clean Air Act, as amended (the Act). The NSPS are
issued for categories of sources which the Administrator
determines cause, or contribute significantly to, air pollution
which may reasonably be anticipated to endanger public health or
welfare.
The NSPS apply to new stationary sources of emissions (i.e.,
sources whose construction, reconstruction, or modification
begins after a standard for them is proposed). In this instance,
the NSPS apply to new, modified, and reconstructed starch
production plants for which construction is commenced after the
date of proposal. The NSPS established under section 111 of the
Act are to reflect the application of the best technological
system of continuous emission reduction which (taking into
account the cost of achieving such reduction, and any nonair
quality health and environmental impact and energy requirements)
the Administrator determines has been adequately demonstrated.
This level of control is commonly referred to as best
demonstrated technology (BDT).
Section 111(b)(1)(B) of the Act mandates that this
regulation be reviewed 8 years from the date of promulgation of
the NSPS unless the Administrator determines that review is not
appropriate in light of readily available information on the
efficacy of the standard. The review will include an assessment
of the need for integration with other programs, the existence of
alternative methods, enforceability, improvements in emission
control technology, and reporting requirements.
1.2 Selection of Source Category.
The Environmental Protection Agency (EPA) previously
determined that starch production plants are major contributors
to air pollution that may reasonably be anticipated to endanger
public health or welfare and, thus, constitute a major source
category for the purposes of section 111. This category
("starch") was included on the priority list of major source
categories (priority list), published in 40 CFR 60.16 (January 8,
1982, as amended), for which NSPS were to be developed under
section 111.1 The inclusion of "starch" on the priority list is
not subject to comment or review at this time.
The 1990 Amendments to the Act (1990 Amendments) established
a further requirement (section lll(f)(1)) for the EPA to
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establish NSPS for those source categories appearing on the
priority list for which the EPA had not proposed standards by
November 15, 1990. A partial consent decree was lodged with the
court on July 22, 1993.2 This decree mandated that NSPS be
proposed for at least three of the unregulated categories of
major stationary sources from the priority list on or before
August 31, 1994, with the Agency having the discretion of
selecting the specific source categories.
The "starch" category was listed number 53 of 59 source
categories on the priority list and was one of 19 source
categories for which no NSPS had been developed by November 15,
1990. Starch production plants are among the source categories
selected for proposal of NSPS by August 31, 1994 pursuant to the
consent decree.
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RATIONALE FOR THE PROPOSED STANDARDS
2.1 Source Category to be Regulated.
The proposed standards would set emission limits for
affected facilities at starch production plants. The source
category includes those facilities processing dry starch
(including modified starches) derived from corn, wheat, potatoes,
tapioca or other vegetable source, and facilities drying starch
extracted from the wastewater at snack food production facilities
(e.g., potato chips, french fries).
Typically, starch production plants are components of larger
facilities that prepare a variety of products. For example, a
corn wet milling facility will normally produce a range of
products that can include animal feed, corn gluten, corn germ,
germ meal, corn oil, starch, and starch derivatives. Starch
derivatives can include modified specialty starches, dextrins,
dextrose, corn syrup, high fructose corn syrup, ethanol, and a
variety of sweeteners. Similar ranges of products may be derived
from wheat, potatoes, or tapioca.
The manufacture of vegetable oils (e.g., corn oil), a
process performed at some corn wet milling facilities, is also
considered to be a source category within the context of section
111 and is on the priority list. Manufacture of vegetable oils
is not, however, subject to the provisions of the NSPS for starch
production plants.
2.2 Pollutant to be Regulated.
Particulate matter (PM) is the only criteria pollutant
emitted from starch production plants. Therefore, the proposed
standards would limit emissions of PM from new, modified, and
reconstructed starch dryers, dextrin roasters, and starch
transfer, storage, and loading facilities.
2.3 Affected Facilities.
The affected facilities to be regulated are starch dryers,
dextrin roasters, and starch transfer, storage, and loading
facilities for which construction, modification, or
reconstruction is commenced after the date of proposal. The
plants processing the raw materials noted above may utilize
several different types of processing lines in the production of
starch. In covering all types of starch production, the EPA
recognized that the plants employed the same types of process
equipment to dry and handle starch. Also, the EPA recognized
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that all have the potential to emit substantial amounts of PM and
that the emission control options for each are the same.
In particular, the components of starch production plants of
interest to the EPA are starch dryers, dextrin roasters, and
starch transfer, storage, and loading facilities. A starch dryer
is the equipment used to remove uncombined (free) water from
starch slurry through direct or indirect heating. A dextrin
roaster is a reactor vessel, or a series of vessels, in which
starch is reacted, through the addition of heat and/or chemicals,
to form the modified starch "dextrin" (or "polydextrin"). Starch
transfer, storage, and loading facilities include any facility
used to blend, mix, mill, grind, screen, convey, transfer, store,
or load for shipment (into any container for shipment, including,
but not limited to, bag, truck, and rail car), dry starch. This
also includes the bag dumping of dry additives into the starch
for the purpose of producing modified starches. These components
will be affected facilities upon promulgation of NSPS.
There are several types of dryers used at starch production
plants, including ring (also known as loop) flash dryers, single-
pass (also known as one-pass) flash dryers, spray dryers, drum
dryers, and belt (also known as conveyor, tunnel, or apron)
dryers. Drum dryers having a manufacturer's rated dry starch
capacity of 907 kilograms per hour (kg/hr) (2,000 pounds per hour
[Ib/hr]) or less will not be subject to any provisions of the
standards. Similarly, starch dryers, dextrin roasters, and
starch transfer, storage, and loading facilities at snack food
production facilities will be exempt from all provisions of the
standards if the manufacturer's rated dry starch capacity of the
dryer used is 907 kg/hr (2,000 Ib/hr) or less. These exemptions
are being made due to the low level of emissions from these
facilities, and will include exemption from the notification
requirements.
2.4 Selection of Best Demonstrated Technology.
In developing NSPS, the Agency generally evaluates varying
levels of control, beginning with that level of control found
within the industry in the absence of additional Federal
regulation. This level of control is termed "baseline" and is
the level against which more stringent levels are compared. Most
facilities for which EPA has information collect PM from the
exhaust ducts or vents of the affected facilities. This is done
because the PM collected is starch, which is the final product of
the production plant. Available information shows that most
existing starch dryers are equipped with simple cyclonic
collectors, at a minimum. Newer starch dryers are equipped with
low energy wet scrubbers or fabric filters, either alone or in
combination with one or more cyclones. Waste water from the
scrubbers and collected dust from the fabric filters are returned
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to the process and not sent to disposal. Industry
representatives indicate that highly effective dust collection
systems are mandated by the highly competitive nature of the
industry.3 Thus, new plants, which must function efficiently to
compete with existing facilities, are installing either wet
scrubbers or fabric filters to reduce the amount of starch lost
in the dryer exhaust gases. For the starch production industry,
this level of control was selected as the baseline for
development of NSPS for most starch dryers.
There are two cases, however, where the dryer baseline does
not represent the level of control exhibited by wet scrubbers or
fabric filters. There are no known cases where a drum dryer or a
dryer at a snack food production facility utilizes control beyond
the product recovery cyclone. Thus, baseline for these two cases
is the level of control exhibited by the product recovery
cyclone.
Dextrin roasters and starch transfer, storage, and loading
facilities employ fabric filters to recover starch emissions in
dry form for immediate recycle to the process. This level of
control was selected as the baseline for development of NSPS for
dextrin roasters and starch transfer, storage, and loading
facilities.
Review of available data shows no cases where control
technology beyond the baseline is employed. Therefore the
baseline level of control was selected as BDT for most starch
dryers, as well as for dextrin roasters and starch transfer,
storage, and loading facilities. The scope of BDT for starch
production plants is sufficiently broad to include all types of
wet and dry control devices and to allow for the introduction of
other devices, beyond the traditional wet scrubber and fabric
filter, that would be able to meet the emission limit.
There is no technical reason why additional control could
not be applied to drum dryers and the dryers at snack food
production facilities. Therefore, the level of control exhibited
by wet scrubbers or fabric filters is considered to be BDT for
these dryers. (However, there are no known cases where these two
dryer types exceed the de minimis level noted above.)
Since the pollutant is also the product, source reduction
cannot be practiced in this industry (i.e., nothing can replace
the starch). However, pollution prevention is exhibited in the
industry through the total use of the scrubber and fabric filter
"waste" streams in in-process recycling and the loading of trucks
and railcars using vacuum pressure systems. No further methods
of pollution prevention appear available and none were analyzed
in developing the NSPS.
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2.5 Part 70 Permits.
Under the operating permit regulations codified at 40 CFR
70.3, any source that is a major source under the Act, or any
nonmajor source subject to a standard under sections 111 or 112
after July 21, 1992, must obtain an operating permit. Section
70.3(b) further provides that, for nonmajor sources "...the
Administrator will determine whether to exempt any or all such
applicable sources from the requirements to obtain a part 70
permit at the time that the new standard is promulgated."
Today's proposed starch production plant rule does not
exempt nonmajor affected starch facilities from permitting
requirements because the number of nonmajor sources subject to
part 70 permitting requirements is not so great as to cause a
significant administrative burden on the permitting authority.
In addition, nonmajor sources at starch production plants are not
likely to require significant additional technical assistance
from permitting authorities. The EPA believes that permitting
these nonmajor sources will enhance the implementation and
enforcement of the rule by clarifying how the rule applies to a
particular nonmajor source.
However, under the existing provisions of part 70, States
may choose to defer the obligation of all nonmajor sources to
obtain a permit until the EPA "completes a rulemaking to
determine how the program should be structured for nonmajor
sources and the appropriateness of any permanent exemptions..."
In promulgating the permits rule, the EPA committed to complete
that rulemaking within 5 years after the approval of the first
State part 70 program that defers permitting of nonmajor sources
(57 Federal Register 32250, 32259 (July 21, 1992)).
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PROPOSED STANDARDS
3.1 Particulate Matter and Visible Emissions Standards.
Section 111(b)(2) of the Act allows the Agency to
distinguish among classes, types, and sizes within categories of
new sources for the purpose of establishing NSPS. Based upon an
analysis of the available test data, it was necessary to
establish separate standards for ring flash dryers and drum
dryers, single-pass dryers, and spray and belt dryers, as well as
for dextrin roasters and the starch transfer, storage, and
loading facilities. The requirements of the proposed standards
are summarized in Tables 1, 2, and 3 for starch dryers, dextrin
roasters, and starch transfer, storage, and loading facilities.
Emission test data were solicited through the industry trade
associations, the States and local regulatory agencies, and the
individual members of the industry. In addition, four starch
production plants were surveyed to gather information. Contact
was made with the majority of the States known to contain starch
production facilities as well as with the three applicable
industry trade associations, and many of the starch production
companies themselves.
A total of 29 emission test reports or summaries comprise
the data base.4 Of these 29 reports, 19 represent tests that
were performed on flash dryers, 3 tests each on belt dryers and
drum dryers, and 1 test on a spray dryer. Results of tests on
one storage bin and two bulk loadout vents were also collected.
Only two data sets were available for visible emissions (VE)
tests on starch dryers. These data are all believed to come from
emission tests to show compliance with State and local
regulations and reflect use of the EPA Method 5 sampling train
(incorporating both front and back halves of the recovered sample
in the analyses). The tested belt dryers and the potato starch
ring and single-pass flash dryers were uncontrolled (13 tests
total). The tested belt dryers (3 tests total) were also
uncontrolled although the most recently installed belt dryers
have been controlled with either wet scrubbers or fabric filters.
All other tested processes were controlled by either wet
scrubbers or fabric filters.
Analysis of this available compliance test information leads
the EPA to conclude that the following emission levels are
achievable by starch dryers employing BDT:
(a) 45 milligrams per dry standard cubic meters (mg/dscm)
(0.02 grains per dry standard cubic feet [gr/dscf]) for
new ring (or loop) flash dryers;
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Table 1.
Parameter
Emission
limit
Monitoring
Reporting
Test
methods
and
procedures
Summary of Proposed NSPS Requirements-Starch Dryers
li]
Particulate matter:
Ring flash dryer
Single-pass flash dryer
Spray, drum, or belt dryer
0.02 gr/dscf
0.01 gr/dscf
0.005 gr/dscf
Wet control device:
Continuous measurement and recording of
pressure drop across, and liquid flow rate to, the
control device with semiannual calibration
Failure to continuously monitor and record the
pressure drop and liquid flow rate, and exceedances
of the operating limits will be violations of the PM
standard
Dry control device or uncontrolled:
Method 9 opacity observation for 1 18-minute
period per week during period of dryer operation
Exceedance of 3% opacity will be a violation of
the PM standard
All control devices:
Implementation of inspection and logging
procedure to include some or all of (1) daily check
to ensure that dust is being removed from the
system; (2) weekly inspection for proper cleaner
functioning and cycling; (3) monthly inspection for
wear, material buildup, and corrosion; (4) logging
of broken bags by location in order to identify
installation or operational problems; and (5)
monthly inspection of pressure drop and liquid flow
rate devices (as appropriate)
Failure to inspect and log will be a violation
of the PM standard
Wet control device:
Quarterly reports of exceedances (<90% of
either pressure drop or liquid flow rate established
during initial PM compliance test)
Dry control device or uncontrolled:
Quarterly reports of exceedances (>3% opacity)
Wet control device:
Method 5 for PM standard
Dry control device or uncontrolled:
Method 5 for PM standard
Method 9 for opacity standard
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Table 2. Summary of Proposed NSPS Requirements-Dextrin Roasters
Parameter Requirement
Emission
limit
Monitoring
Reporting
Test
methods
Particulate matter: None
Opacity: 0%
Method 9 opacity observation for 1 18-minute
period per week during period of roaster operation
Exceedance of opacity standard will be a
violation of the VE standard
All dry control devices (e.g., fabric filters):
Implementation of inspection and logging
procedure to include (1) daily check to ensure that
dust is being removed from the system; (2) weekly
inspection for proper cleaner functioning and
cycling; (3) monthly inspection for wear, material
buildup, and corrosion; (4) logging of broken bags
by location in order to identify installation or
operational problems
Failure to inspect and log will be a violation
of the VE standard
Dry control device or uncontrolled:
Quarterly reports of exceedances (>0% opacity)
Dry control device or uncontrolled:
Method 9 for opacity standard
procedures
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Table 3.
Emission
limit
Monitoring
Summary of Proposed NSPS Requirements -Starch Transfer,
Storage, and Handling Facilities
Reci i r
Reporting
Test
methods
procedures
Particulate matter: ....... None
Opacity: ........... 0%
Visible Emissions . No visible emissions
Method 9 opacity observation of stack or vent
for 1 18 -minute period per week during period of
facility operation
Exceedance of opacity standard will be a
violation of the VE standard
Method 22 opacity observation of affected
facility for 1 18 -minute period per week
Exceedance of the no visible emission standard
will be a violation of the VE standard
All dry control devices (e.g., fabric filters):
Implementation of inspection and logging
procedure to include (1) daily check to ensure that
dust is being removed from the system; (2) weekly
inspection for proper cleaner functioning and
cycling; (3) monthly inspection for wear, material
buildup, and corrosion; (4) logging of broken bags
by location in order to identify installation or
operational problems
Failure to inspect and log will be a violation
of the VE standard
Dry control device or uncontrolled:
Quarterly reports of exceedances (>0% opacity)
Affected facility:
Quarterly reports of exceedances (any visible
emissions)
Dry control device or uncontrolled:
Method 9 for opacity standard
Affected facility:
Method 22 for visible emission standard
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(b) 25 mg/dscm (0.01 gr/dscf) for new single-pass (or one-
pass) flash dryers; and
(c) 10 mg/dscm (0.005 gr/dscf) for new spray dryers, drum
dryers, and new belt (or conveyor, tunnel, or apron)
dryers.5
In addition, VE from the stacks of new starch dryers with dry
control devices can be limited to 3 percent opacity, or less,
based on a 6-minute average.
The available data indicate that ring flash dryers utilized
on potato starch may meet the NSPS without the use of wet
scrubbers or fabric filters. The NSPS would not require the
installation of any control device; rather, it merely requires
that the emission level be achieved by any means chosen by the
owner or operator.
The starch transfer, storage, and loading facilities visited
during development of the standard were all controlled by fabric
filters. Although emission test data were received for these
sources, the EPA believes that, due to the low level of
emissions, these sources are difficult to test because the
exhaust streams are intermittent with low flow rates. The EPA
has elected to limit VE from the stacks or vents of new starch
transfer, storage, and loading facilities to 0 percent opacity,
based on a 6-minute average, while visible fugitive emissions
from such facilities would be limited to no VE.
No emission test data were obtained for dextrin roasters.
However, the fabric filters utilized on roasters are similar in
nature to those used on starch transfer, storage, and loading
facilities. In addition, dextrin roasting is also done in a
batch mode, or series of batch modes, with low emission levels
and intermittent exhaust streams with low flow rates. Therefore,
for the reasons noted above, the EPA has elected to limit VE from
the stacks of new dextrin roasters to 0 percent opacity, based on
a 6-minute average.
The available data indicate that drum dryers and single-pass
flash dryers used in the process of extracting starch from the
wastewater at snack food production facilities have the potential
to emit less than 1 ton of PM per year. This level of emissions,
coupled with the costs of adding emission controls noted later
for these two dryer types, result in cost effectiveness values of
approximately $27,000 per ton of PM removed for drum dryers and
$43,000 per ton for the snack food dryers. Therefore, as these
values are considered unreasonable, drum dryers having dry starch
capacities of 907 kg/hr (2,000 Ib/hr) or less are not being made
subject to the provisions of this rule. Similarly, starch dryers
used in the process of extracting starch from the wastewater
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generated at snack food production facilities are not subject to
the provisions of this rule, providing the dryer dry starch
capacity is 907 kg/hr (2,000 Ib/hr) or less. In addition,
dextrin roasters, and starch transfer, storage, and loading
facilities used in the process of extracting starch from the
wastewater generated at snack food production facilities are not
subject to the provisions of this rule, providing the dryer dry
starch capacity is 454 kg/hr (1,000 Ib/hr) or less.
3.2 Monitoring and Compliance Requirements.
The EPA is proposing that sources subject to NSPS be
required to demonstrate continuous compliance with the NSPS by
passing an initial performance test using EPA Method 5 for PM,
Method 9 for VE, and Method 22 for visible fugitive emissions;
and by continuously monitoring control device operating
parameters and weekly observations of the opacity using both
Methods 9 and 22.6 These requirements are meant to fulfill the
mandate of section 114(a)(3) of the Act, as amended, commonly
referred to as "enhanced monitoring" which is required for major
stationary sources and may be required for other sources. The
enhanced monitoring protocol data would be used to determine
compliance for purposes of a compliance certification submitted
pursuant to the 40 CFR part 70 operating permit regulations. The
records of the measurements and observations required would be
retained by the facility for at least 5 years.
Each owner or operator of an affected starch dryer, dextrin
roaster, or transfer, storage, and loading facility would be
required to institute an inspection and logging procedure for all
dry control devices (e.g., fabric filters) that are used to
control process or fugitive PM emissions. Failure to perform the
required inspections and logging will constitute a violation of
the PM and opacity standards. The inspection and logging
procedure must, at a minimum, include the following:
1. Daily check to ensure that dust is being removed from
the system;
2. Weekly inspection for proper cleaner functioning and
cycling;
3. Monthly inspection of the control device, fans, and all
moving parts for wear, material buildup, and corrosion; and
4. Logging of broken bags by location in order to identify
installation or equipment problems.
Each owner or operator of an affected starch dryer would be
required to institute a similar inspection and logging procedure
for all wet control devices (e.g., wet scrubbers) that are used
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to control process PM emissions. Failure to perform the required
inspections and logging will constitute a violation of the PM
standards. The inspection and logging procedure must, at a
minimum, include the following:
1. Monthly inspection of the control device, fans, and all
moving parts for wear, material buildup, and corrosion; and
2. Monthly inspection of the device for the continuous
measurement of the pressure loss of the gas stream through the
wet control device and of the device for the continuous
measurement of the liquid flow rate through the wet control
device for plugging and proper operation.
It should be noted that many starch production plants
already undertake monitoring similar to that being proposed to
comply with local and State regulatory requirements. This
existing monitoring ranges from regular emission tests to the
installation of monitoring devices and the recording of control
device pressure drops, and the like to the observation of exhaust
gas opacity. Thus, the monitoring requirements being proposed
may not cause the facility to do anything different than that
already being done at many facilities.
3.2.1 Starch dryers. For starch dryers, demonstration
of compliance would be made by an initial performance test using
EPA Reference Method 5. This would be followed by weekly
recording of VE (using Method 9) for uncontrolled and dry-
controlled dryers and control device operating parameters, such
as pressure drop and wet control device liquid flow rate, for
wet-controlled dryers.
During the initial performance test of a starch dryer, EPA
Method 5 would be used to determine compliance with the PM
standard. The sampling time and sampling volume for each test
run would be at least 2 hours and 1.70 dry standard cubic meters
(dscm) (60 dry standard cubic feet [dscf]).
Dryers utilizing wet control devices would be required to
have installed, calibrated, maintained, and operated two devices
for the continuous measurement of the pressure loss of the gas
stream through the wet control device and the liquid flow rate to
the wet control device. The pressure loss monitoring device must
be certified by the manufacturer to be accurate within +/- 250
pascals (+/-1 inch water gauge pressure) and must be calibrated
on a semiannual basis in accordance with the manufacturer's
instructions. The device monitoring the scrubbing liquid flow
rate to the wet control device must be certified by the
manufacturer to be accurate within +/- 5 percent of design liquid
flow rate and must be calibrated on a semiannual basis in
accordance with the manufacturer's instructions. Failure to
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continuously record the pressure loss and liquid flow rate would
constitute a violation of the PM standard.
During the initial performance test of a wet control device,
the owner or operator would use these monitoring devices to
determine the average change in pressure of the gas stream across
the wet control device and the average flowrate of the wet
control device liquid during each of the PM runs. The arithmetic
average of the three runs would be used as the baseline average
values against which subsequent readings were compared for
compliance purposes. This arithmetic average would constitute
the demonstrated compliance parameter level (DCPL) for the wet
control device.
For continuous compliance of the PM standards, the exhaust
gas stream(s) from uncontrolled starch dryers and from starch
dryers utilizing dry control devices would be observed one time
per week for 18 consecutive minutes using EPA Method 9 and the
procedures in section 60.II.7 These observations would be
recorded weekly. An "exceedance" of the PM NSPS (failure to
comply with the requirements) for starch dryers utilizing dry
control devices would be each VE in excess of 3 percent opacity.
For starch dryers utilizing wet control devices, continuous
compliance would be determined by comparing the continuous wet
control device pressure drop and liquid flow rate readings with
the arithmetic averages determined during the most recent PM
performance test. Each wet control device pressure drop or
liquid flow rate that was less than 90 percent of the value
recorded during the most recent PM performance test that
demonstrated compliance with the PM standard would be considered
an exceedance of the PM standard. Written reports of exceedances
would be submitted to the appropriate regulatory agency (State,
local, or Federal Regional office) quarterly.
3.2.2 Dextrin roasters. For dextrin roasters,
demonstration of compliance with the NSPS would be made by an
initial performance test using EPA Method 9 followed by weekly
observations of VE using Method 9.
During the initial performance test of a dextrin roaster
stack, EPA Method 9 and the procedures in section 60.11 would be
used to determine compliance with the VE standards.7 The
performance test for VE would be conducted such that the duration
of the test coincides with the length of a complete operational
batch cycle and is of at least one hour duration, even if more
than one batch cycle must be covered.
For continuous compliance, the stacks from a dextrin roaster
would be observed one time per week for 18 consecutive minutes
using EPA Method 9 and the procedures in section 60.11 for the
determination of compliance with the VE standards. These
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observations would be recorded weekly. An exceedance of the NSPS
would be each VE in excess of 0 percent opacity.
Written reports of exceedances would be submitted to the
appropriate regulatory agency (State, local, or Federal Regional
office) quarterly. In adopting this approach, the EPA believes
that the intent of the Act will be achieved at minimal cost
(i.e., no manual test for PM will be required on dextrin
roasters).
3.2.3 Starch transfer, storage, and loading
facilities. For starch transfer, storage, and loading
facilities, demonstration of compliance with the NSPS would be
made by an initial performance test using EPA Methods 9 and 22
followed by weekly observations of VE using Methods 9 and 22.
During the initial performance test of a starch transfer,
storage, or loading facility stack or vent, EPA Method 9 and the
procedures in section 60.11 would be used to determine compliance
with the VE standards.7 The performance test for VE would be
conducted such that the duration of the test coincides with the
length of a complete operational batch cycle and is of at least
one hour duration, even if more than one batch cycle must be
covered.
For starch transfer, storage, or loading facilities that are
enclosed in a building, the NSPS requires that there be no
visible fugitive emissions. The initial performance test would
be conducted while all affected facilities inside the building
were operating. The performance test, using EPA Method 22, for
each affected facility would be at least one hour in duration,
with each emission point exhibiting visible fugitive emissions
being directly observed. More than one operational batch cycle
may need to be observed.
For continuous compliance, the stacks and vents from a
starch transfer, storage, or loading facility would be observed
one time per week for 18 consecutive minutes using EPA Method 9
and the procedures in section 60.11 for the determination of
compliance with the VE standards. These observations would be
recorded weekly. An exceedance of the NSPS would be each VE in
excess of 0 percent opacity.
For continuous compliance of the visible fugitive emissions
standard for starch transfer, storage, or loading facilities,
observations would be made one time per week to determine
compliance with the visible fugitive emission standard. Each
observation would be for 18 consecutive minutes and cover any
affected facility emission point exhibiting visible fugitive
emissions. These observations would be recorded weekly.
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Exceedances would be considered as each observation of visible
fugitive emissions.
Written reports of exceedances would be submitted to the
appropriate regulatory agency (State, local, or Federal Regional
office) quarterly. In adopting this approach, the EPA believes
that the intent of the Act will be achieved at minimal cost
(i.e., no manual test for PM will be required on starch transfer,
storage, and loading facilities).
3.3 Reporting Requirements.
The records and measurements noted above would be required
to be retained by the owner or operator for at least 5 years.
Reports of the initial performance tests, and the recordings made
during the tests, would be reported to the Administrator and
retained by the owner or operator for at least 5 years.
Maintenance of the records for 5 years is being required to be
consistent with the requirements of 40 CFR part 70.
The EPA requires that sources report deviations of standards
on at least a quarterly basis. This frequency of reporting
provides benefits to both the enforcement authority and the
regulated community. By requiring sources to report deviations
on a quarterly basis, the enforcement authority is able to
identify potential violations in a timely manner. Since
penalties are calculated per day per violation, the timely
identification of violations reduces a source's liability. In
addition, identifying potential violations on a quarterly basis
allows the EPA to use efficient enforcement tools, such as the
Administrative enforcement process. Administrative enforcement
can be used where penalties are less than $200,000 and violations
are less than 1 year old. Less frequent reporting would prevent
the Agency from identifying violations in a timely manner and may
preclude the use of Administrative enforcement due to the one
year deadline.
Each quarterly monitoring report would include the
following:
1. A summary of the number and duration of deviations or
exceedances occurring during the reporting period, classified by
reason, including known causes for which a Federally-approved or
promulgated exemption from an emission limitation or standard may
apply.
2. Identification of the data availability achieved during
the reporting period, including a summary of the number and total
duration of incidents that monitoring was not performed in
accordance with the mandate of the NSPS or produced data that did
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not meet minimum data accuracy and precision requirements,
classified by reason.
3. All records that the source is required to maintain as
described in section 60.760 that pertain to the periods during
which a deviation resulting from a known cause for which no
Federally-approved or promulgated exemption applies. In
addition, the following must be reported:
a. the magnitude of each deviation,
b. the reason for each deviation,
c. a description of the corrective action taken for
each deviation, including action taken to minimize each deviation
and action taken to prevent recurrence, and
d. all quality assurance activities performed under
section 60.763 of the NSPS.
4. Identification of the compliance status as of the last
day of the reporting period and whether compliance was continuous
or intermittent during the reporting period.
5. The most recently established DCPLs (for wet control
devices).
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4 SUMMARY OP COST, ENVIRONMENTAL, ENERGY, AND ECONOMIC IMPACTS
Currently, there are 47 known facilities, owned by 17
companies, that produce starch (and modified starches) in the
U.S.8 Of these facilities, 20 produce starch from corn, 3
produce starch from wheat, 21 produce starch from potatoes, 1
produces starch from tapioca, and 2 produce starch from other
vegetable sources. This number also includes those facilities
that extract and dry starch from their wastewater (primarily
snack food producers). These facilities are concentrated in the
midwestern U.S. but are found across the country.
Based on analysis of historic trends, the EPA projects the
construction of three new starch production plants within the 3
years following proposal of the NSPS. In addition, expansion at
several existing plants may also be expected. To analyze the
impacts of this growth, the EPA developed eight model "plants" to
represent the various sizes of process units expected.9 Three of
these are new plants and five represent expansions at existing
facilities. The new facilities would also include such ancillary
processes as mills, storage bins, and loading systems, which have
been included in the model plants. These model plants are not
meant to replicate any specific facility but to be representative
of the facilities that could be built.
4.1 Cost Impacts.
Even though new facilities are expected to install BDT even
in the absence of NSPS because starch, the pollutant, is of value
to the plant, the costs of controls on some model facilities that
in the past have been uncontrolled have been estimated (but
without factoring in any recovery credits) .10 As noted above,
certain dryers in some applications may not require the
installation of wet or dry control devices to meet the NSPS.
Thus, the control equipment costs below are presented for
information only as it is not expected that the NSPS will cause
the facilities to incur any additional control costs, beyond
those of compliance monitoring.
Costs for both fabric filters and wet scrubbers were
estimated. However, as the costs of the wet scrubbers were
lower, they are reported here. Capital costs for installing a
wet scrubber on model starch dryers are estimated to range from
approximately $37,100 to $264,700. Estimated annual costs
(including, but not limited to, operation, maintenance, and
monitoring) for these scrubbers range from $16,600 to $125,100.
Capital costs for installing a fabric filter on model starch
transfer, storage, and loading facilities are estimated to range
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from approximately $127,000 to $142,200. Estimated annual costs
for these fabric filters range from $21,600 to $40,600.
In addition, even though new facilities are expected to
monitor the performance of the installed control devices even in
the absence of NSPS, the costs of compliance have been estimated,
including those of the initial performance test as well as those
of enhanced monitoring.11 The cost of the initial performance
test is estimated to be approximately $6,000. Instrument costs
for the two recording devices required on starch dryers utilizing
wet control devices are projected to be approximately $1,500.
Annual costs for the required observations using Methods 9 and 22
are estimated to be approximately $25,000 for the first year, and
$22,500 for each succeeding year.
Annual costs for enhanced monitoring were estimated for
three general "levels" of monitoring.12 The three levels are
presented in Table 4. The resulting enhanced monitoring costs
for each model affected facility are summarized in Table 5 and in
Table 6 for each model plant. Based on the high cost of
continuous opacity monitoring (COM) and daily manual monitoring
relative to the total cost of control, weekly monitoring using
Methods 9 and 22 was selected to serve as the enhanced monitoring
program for the starch NSPS.
4.2 Environmental Impacts.
The primary environmental impacts resulting from the
proposed PM standards are reductions in the quantity of PM
emitted from those facilities subject to NSPS. The emissions
reductions that will result will occur because of the improved
operation and maintenance that results from enhanced monitoring.
Available information is insufficient to allow for the
quantification of the projected PM reductions.
There are no solid or liquid waste impacts associated with
the proposed standards. This is because all PM recovered by
control devices as well as all water used in wet scrubbers is
typically recycled back into plant processes at affected
facilities.
4.3 Energy Impacts.
There are no additional energy requirements associated with
the proposed NSPS. No additional or different controls other
than those that would have been used in the absence of an NSPS
are expected to be used that would alter the existing energy
requirements.
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Table 4. Summary of Enhanced Monitoring Options
Level 1
Level 2
Level 3
Dryer- dry
control
COM
Daily Method 9
observations
Weekly Method 9
observations
Dryer-wet
control
Continuous
monitoring of
cp and liquid
flow rate
None
None
Transfer,
storage, and
loading -dry
control
COM; daily
Method 22
observations
Daily Method 9
and Method 22
observations
Weekly Method 9
and Method 22
observations
Table 5. Summary of Enhanced Monitoring Annual Costs (percent of
total annual costs)
Level 1
Level 2
Level 3
Dryer-dry
control
$16,500
(37.2%)
$22,500
(50.7%)
$3,420
(7.7%)
Dryer -wet
control
0
0
0
Transfer,
storage, and
loading -dry
control
$38,400
(48.6 - 64.0%)
$44,400
(52.2 - 67.3%)
$6,540
(13.9 - 23.2%)
Table 6. Summary of Enhanced Monitoring Annual Costs--Model
Plant Basis (percent of total annual costs)
Level 1
Level 2
Level 3
Plant with dry
control on dryer
$71,400
(38.1%)
$44,400
(27.6%)
$6,540
(5.3%)
Plant with wet
control on dryer
$38,400 - 104,400
(17.6 - 49.6%)
$44,400 - 66,300
(19.8 - 53.2%)
$6,540 - 9,660
(3.5 - 14.3%)
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4.4 Economic Impacts.
In analyzing the national cost impacts of the standards, the
costs resulting from the implementation of the proposed standards
have been considered in this rulemaking. On a national basis,
the proposed standards would not increase the capital cost for
starch production plants because new plants would in all
likelihood install controls equivalent to BDT under the NSPS even
if the NSPS were not promulgated. The only additional costs
expected to result from the standards would, therefore, be for
the enhanced recordkeeping and reporting.
The proposed standards do not add requirements for
installation of emissions controls beyond what is being achieved
today. Rather, they would codify the level of emissions control
already being achieved by newer facilities. The only additional
requirements being proposed are for testing, monitoring, and
reporting (i.e., "enhanced monitoring"). Because the level of
control being used as the basis of the standards is unchanged
from current industry practices and the cost of complying with
the standards is small, the cost of the proposed standards have
been determined to be unsubstantial. The EPA has not subjected
the proposed NSPS to a rigorous quantitative analysis of economic
impacts because costs (capital and annual) are minimal and,
without further detailed information, emissions reductions cannot
be quantified.
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5 REFERENCES
1. 40 Code of Federal Regulations Part 60, Section 60.16.
Office of the Federal Register, U.S. Government Printing
Office. Washington, B.C. July 1, 1991. pp. 234-235.
2. Memorandum and attachment from Robert J. Martineau, EPA:OGC,
to Michael H. Shapiro, EPArOAR. July 28, 1993. Partial
consent decree in Sierra Club v. Browner (deadline
litigation).
3. Memorandum from Mary-Jo Caldwell, MRI, to William Maxwell,
EPA/ISB. April 8, 1994. Report of December 10, 1993 visit
to CornProducts, a unit of CPC International, Incorporated.
4. Memorandum from Bob Snyder, MRI, to William Maxwell,
EPA/ISB. April 4, 1994. Data summary--starch manufacturing
test data and information.
5. Reference 4.
6. Reference 1. pp. 742-766, 856-862, 1030-1034.
7. Reference 1. pp. 227-229.
8. Starch Manufacturing; A Profile. Final Report. Prepared
for the U.S. Environmental Protection Agency, Research
Triangle Park, NC. March 1994.
9. Memorandum from David Randall, MRI, to William Maxwell,
EPA/ISB. May 16, 1994. Model plants--starch manufacturing
industry.
10. Memorandum from David Randall, MRI, to William Maxwell,
EPA/ISB. May 18, 1994. Control option costs--starch
manufacturing industry.
11. Memorandum from Terry Harrison, EPA/EMB, to William H.
Maxwell, EPA/ISB. April 5, 1994. Performance testing and
enhanced monitoring costs for the starch industry.
12. Memorandum from William H. Maxwell, EPA/ISB, to Kenneth R.
Durkee, EPA/ISB. June 22, 1994. Documentation of enhanced
monitoring costs for the starch NSPS.
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TECHNICAL REPORT DATA
(Please read Instructions on reverse before completing)
j 1. REPORT NO. 2.
] EPA-453/R-94-060
4. TITLE AND SUBTITLE
Rationale for New Source Performance Standards: Starch
Production Plants
7. AUTHOR(S)
9. PERFORMING ORGANIZATION NAME AND ADDRESS
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
MD-13
Research Triangle Park, NC 27711
\1. SPONSORING AGENCY NAME AND ADDRESS
Director
Office of Air Quality Planning and Standards
Office of Air and Radiation
U.S. Environmental Protection Agency
(Research Triangle Park, NC 27711
3. RECIPIENT'S ACCESSION NO.
5. REPORT DATE
August 1994
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO.
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
13. TYPE OF REPORT AND PERIOD COVERED
14. SPONSORING AGENCY CODE
EPA/200/04
15. SUPPLEMENTARY NOTES
16. ABSTRACT
Rationale for the new source performance standards for starch dryers, dextrin roasters, and starch
transfer, storage, and loading facilities at starch production plants under the provisions of section 111 of
the Clean Air Act, as amended.
17. KEY WORDS AND DOCUMENT ANALYSIS
a. DESCRIPTORS
Air pollution
Paniculate matter
Starch
Air pollution control
18. DISTRIBUTION STATEMENT
Release Unlimited
b. IDENTIFIERS/OPEN ENDED TERMS c. COSATI Field/Group
Air Pollution control
19. SECURITY CLASS (Report) 21. NO. OF PAGES
Unclassified 22
20. SECURITY CLASS (Page) 22. PRICE
Unclassified
EPA Form 2220-1 (Rev. 4-77) . PREVIOUS EDITION IS OBSOLETE
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