United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park NC 27711
EPA-450/3-80-021b
July 1982
Air
Asphalt Roofing
Manufacturing
Industry —
Background Information
for Promulgated Standards
EIS
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EPA-450/3-80-021b
Asphalt Roofing
Manufacturing Industry —
Background Information
for Promulgated Standards
Emission Standards and Engineering Division
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air, Noise, and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
July 1982
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This report has been reviewed by the Emission Standards and Engineering Division
of the Office of Air Quality Planning and Standards, EPA, and approved for publication.
Mention of trade names or commercial products is not intended to constitute endorsement
or recommendation for use. Copies of this report are available through the Library
Services Office (MD-35), U.S. Environmental Protection Agency, Research Triangle
Park, N.C. 27711, or from National Technical Information Services, 5285 Port Royal
Road, Springfield, Virginia 22161.
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TABLE OF CONTENTS
CHAPTER 1
1.1
1.2
1.2.1
1.2.2
1.2.3
CHAPTER 2
2.1
2.2
2.3
2.4
2.5
2.6
2.7
2.8
2.9
2.10
2.11
2.12
2.13
2.14
2.15
2.16
2.17
APPENDIX A
SUMMARY
Summary of Changes Since Proposal
Summary of Impacts of the Promulgated Action ....
Environmental Impacts of the Promulgated Action .
Energy Impacts of the Promulgated Action
Cost and Economic Impacts of the Promulgated
Action
SUMMARY OF PUBLIC COMMENTS
Variations in Raw Materials
Coverage of Regulation
Alternative Control Devices
Opacity Standard for Stills
Monitoring Requirements
Fugitive Emissions From Saturator Hooding
Opacity Standard for Mineral Handling
Gradual Implementation
Asphalt Storage Tanks
Definition of Asphalt Processing
Data Base for Refining/Processing Industry
Proposed Reference Methods
Continuous Blowing Stills
Changes in Roofing Industry Market
Comments on Document
Consideration of Location
Miscellaneous
Addendum to Asphalt Roofing Manufacturing Industry
Background Information for Proposed Standards
(EPA-450/3-80-012a)
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1. SUMMARY
A priority list for regulation of new sources was promulgated on
August 21, 1979 (44 FR 49222), and included asphalt roofing. Prior to
proposal of the standards, a meeting of the National Air Pollution
Control Techniques Advisory Committee was held on December 12, 1979, to
discuss the Asphalt Roofing Manufacture standards recommended for proposal.
The meeting was open to the public, and each attendee was given an
opportunity to comment on the standards recommended for proposal. As a
result of this meeting, several changes were made to the recommended
standards.
On November 18, 1980, the Environmental Protection Agency (EPA)
proposed standards of performance for asphalt processing and asphalt
roofing manufacture (45 FR 76404) under authority of Section 111 of the
Clean Air Act. Also, on November 18, 1980, EPA published an amendment
to the priority list (45 FR 76427), which proposed adding asphalt processing
to the source category listed as asphalt roofing. Public comments were
requested on the proposed regulation and on the proposed amendment to
the priority list. No comments were received on the proposed amendment
to the priority list. Eighteen letters commenting on the proposed
regulation were received from the following groups: asphalt roofing
manufacturers; petroleum refiners; trade associations; State and Federal
government offices; one consultant to the petroleum refining industry;
and one individual. On May 26, 1981, EPA published an amendment to the
proposed regulation (46 FR 28180). This amendment clarified that the
proposed standard applied to blowing stills and asphalt storage tanks
used for the processing and storage of non-roofing asphalts as well as
roofing asphalts. Public comments were requested on the amendment.
Three letters were received from industry. Comments received on the
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proposed standards and on the amendment to the standards, along with
responses to these comments, are summarized in this document and form
the basis for the revisions that have been made to the standards between
proposal and promulgation. Four letters referring to the proposed
standard were received more than six months after the end of the public
comment period, which was too late for responses to be included in this
document. These letters are included in Docket A-79-39, Category IV-D.
Individual docket entry numbers for the four letters are IV-D-28, IV-0-29,
IV-D-30, and IV-D-33. EPA's responses, in the form of memoranda to the
docket, are included in Docket A-79-39, Category IV-B. The individual
entry numbers are IV-B-9 through IV-B-12.
1.1 SUMMARY OF CHANGES SINCE PROPOSAL
A number of changes have been made since proposal of these standards.
One of the most significant changes was made in response to comments
regarding the applicability of the proposed regulation to blowing stills
and storage tanks. An amendment to the proposal (46 FR 28180) clarified
that the proposed regulation for blowing stills and storage tanks included
blowing and storing of nonroofing asphalts. This amendment also added
the definitions for asphalt processing plants and asphalt roofing plants.
These changes required that Sections 60.470, 60.471, and 60.474 be
redrafted. The changes are presented in this document in Section 2.9,
Asphalt Storage Tanks, and Section 2.10, Definition of Asphalt Processing.
Another significant change exempts the industry from the quarterly
report requirement. Refer to Section 2.5, Monitoring Requirements, of
this document for the explanation of this change.
An exemption from the visible emissions standard was added for
saturators that become subject to the standards through modification.
Section 60.472(a)(3) was redrafted accordingly. Refer to Section 2.6,
Fugitive Emissions From Saturator Hooding, for an explanation of this
change.
In acknowledgment of comments that the opacity of blowing still
emissions may exceed zero percent when fuel oil is used to fire the
afterburner, a provision was added to the regulation [§ 60.474(k)] that
describes procedures for petitioning the Administrator to establish a
different opacity limit that would be the opacity standard for the
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blowing still when fuel oil is used to fire the afterburner.
Section 60.472 was redrafted accordingly. Refer to Section 2.4, Opacity
Standards for Stills, of this document.
Changes were made to proposed Test Method 26. Test Method 26 was
redesignated Test Method 5A. The promulgated method requires that
filter box temperature be maintained between 32° and 52°C (90° and
126°F), as opposed to a maximum of 52°C (126°F). Refer to Section 2.12,
Proposed Reference Methods, of this document. Method 5A has been further
revised to clarify that the precollector cyclone is not to be used
except under specific stack conditions. Use of the glass wool filters
has been eliminated as being unnecessary for sampling well controlled
sources. Refer to Docket No. A-79-39-IV-B-12 for an explanation of
these changes.
Another change was made to the opacity limit for storage tanks to
allow periods of emissions not to exceed 15 minutes in any 24-hour
period to allow the industry practice of cleaning lines to be continued.
Section 60.472 of the regulation was redrafted accordingly. Refer to
Section 2.9, Asphalt Storage Tanks, of this document.
1.2 SUMMARY OF IMPACTS OF THE PROMULGATED ACTION
The impacts presented in this section are based on the growth
projections furnished by the industry which are the same as those published
in the proposal (45 FR 76407). The percent particulate reduction and
the percent increases in wastewater and energy usage are the same as
those presented in the preamble to the proposed regulation. The
environmental, energy, and economic impacts of the promulgated standards
are summarized in Table 1-1.
1.2.1 Environmental Impacts of the Promulgated Action
In 1985 the uncontrolled particulate emissions from the new asphalt
processing and asphalt roofing plants will be about 7,000 Mg/yr
(7,700 tons/yr). Under a typical State Implementation Plan (SIP)
regulation, the emissions would be about 3,200 Mg/yr (3,500 tons/yr).
The emissions from plants controlled by the promulgated standard will be
about 1,200 Mg/yr (1,300 tons/yr). This is an 83 percent reduction of
uncontrolled emissions, and a reduction of about 65 percent below SIP
levels. This reduction in emissions will result in a reduction of
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TABLE 1-1. MATRIX OF ENVIRONMENTAL AND ECONOMIC IMPACTS
OF THE PROMULGATED ACTION
Impact/action
Water Solid Infla-
Air pollution waste Energy Noise Economic tionary
Proposed standard +4xx -Ixx -Ixx -Ixx 0 -Ixx -Ixx
00000 0
No standard or
delayed standards 0
Key
0
1
2
3
4
Beneficial action
Adverse impact
No impact
Negligible impact
Small impact
Moderate impact
Large impact
x Short-term impact
xx Long-term impact
xxx Irreversible impact
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ambient air concentration of participate matter in the vicinity of
asphalt roofing plants and asphalt processing units subject to the NSPS.
The promulgated standards would increase the amount of wastewater
to be treated in the fifth year by 212 to 235 mVyr (56,000 to
62,000 gal/yr). The quality of the wastewater will be the same as the
quality of the wastewater presently discharged by asphalt roofing plants.
The adverse water pollution impact would be negligible.
The only solid waste generated by the control devices used in the
asphalt processing and asphalt roofing industry is the saturated filter
media from the high velocity air filter (HVAF). This solid waste is
disposed in a landfill. The additional solid material collected under
the promulgated standards will not differ chemically or physically from
the material collected under a typical SIP regulation. The adverse
impact from landfilling, beyond the impact under a typical SIP, will be
negligible.
1.2.2 Energy Impacts of the Promulgated Action
The total increased energy consumption that will result from the
promulgated standards, including the amount attributable to SIP, would
be about 48,000 mVyr (300,000 bbl/yr) of oil in the fifth year. The
energy required in excess of that required by a typical SIP regulation
to control all new, modified, or reconstructed asphalt processing and
asphalt roofing plants will be about 1,530 m3/yr (9,600 bbl/yr) of oil
in the fifth year. Thus, the promulgated standards will have a negligible
impact on national energy consumption.
1.2.3 Cost and Economic Impact of the Promulgated Action
Compliance with the standards will result in an increase in annualized
costs in this industry of about $0.62 million by 1985. Cumulative
capital costs of complying with the promulgated standards for the industry
as a whole will amount to about $1.3 million from 1980 through 1985.
The percent product price increase for products from new and modified
plants, necessary to offset costs of compliance with the promulgated
standards, will range from 0.08 to 0.14 percent. If the industry must
absorb all the costs for compliance with the regulation, the profit
reduction would be 0.3 percent. These economic impacts are negligible.
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2. SUMMARY OF PUBLIC COMMENTS
The list of commenters and their affiliations is shown in Table 2-1
Twenty-one letters were received. A summary of the comments and the
responses to them are presented in this chapter under the following
headings:
1. Variations in Raw Materials
2. Coverage of Regulation
3. Alternative Control Devices
4. Opacity Standard for Stills
5. Monitoring Requirements
6. Fugitive Emissions From Saturator Hooding
7. Opacity Standard for Mineral Handling
8. Gradual Implementation
9. Asphalt Storage Tanks
10. Definition of Asphalt Processing
11. Data Base for Refining/Processing Industry
12. Proposed Reference Methods
13. Continuous Blowing Stills
14. Changes in Roofing Industry Market
15. Comments on Document
16. Consideration of Location
17. Miscellaneous
2.1 VARIATIONS IN RAW MATERIALS
2.1.1 Comment: D-1
The commenter suggested that coal tars and coal tar pitches be
included in the standard as raw materials since they are, and/or have
been, used in the roofing manufacturing industry. Failure to include
these raw materials would be selective and restrictive legislation.
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TABLE 2-1. LIST OF COMMENTERS ON THE PROPOSED STANDARDS
OF PERFORMANCE FOR THE ASPHALT PROCESSING AND
ASPHALT ROOFING MANUFACTURE INDUSTRY
Document number3 Commenter and affiliation
D-l Adam Paul Banner
P.O. Box 1733
Midland, Michigan 48640
D-2 Jack D. Brady, President
Anderson 2000, Inc.
P.O. Box 20769
Atlanta, Georgia 30320
D-3 Sam Harris
Engineering Technical Consultant Services, Inc.
2721 61st Street, N.W.
Oklahoma City, Oklahoma 73112
D-4, D-24 Richard D. Snyder
Executive Vice President
Asphalt Roofing Manufacturing Association
Suite 702
1800 Massachusetts Avenue, N.W.
Washington, D.C. 20036
D-5 W. R. Meyer, Executive Director
Commonwealth of Virginia State Air Pollution
Control Board
Room 1106
Ninth Street Office Building
Richmond, Virginia 23219
D-6 Thomas R. Merlino
Legal Counsel, Public Affairs
Owens-Corning Fiberglas Corporation
Fiberglas Tower
Toledo, Ohio 43659
D-7 J. R. Coupal, Jr., President
The Asphalt Institute
Asphalt Institute Building
College Park, Maryland 20740
D-8 Special Assistant to Assistant Secretary
U.S. Department of the Interior
Washington, D.C. 20240
(continued)
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TABLE 2.1 (continued)
Document number3 Commenter and affiliation
D-9 J. J. Moon, Manager
Environment and Consumer Protection
Phillips Petroleum Corporation
Bartlesville, Oklahoma 74004
D-10 M. J. Dougherty, Manager
Environmental Control
Union Oil Company of California
Union Oil Center
P.O. Box 7600
Los Angeles, California 90051
D-ll Joe Watkins, Manager of Manufacturing
Riffe Petroleum Company
P.O. Box 45860
5801 E. 41st Street
Tulsa, Oklahoma 74145
D-12 John W. Drake
Staff Environmental Engineer
Kerr-McGee Corporation
Kerr-McGee Center
Oklahoma City, Oklahoma 73125
D-13, Herb Schuyten, Manager
D-23 Environmental Programs Environmental Affairs
Chevron U.S.A., Inc.
P.O. Box 3069
San Francisco, California 94119
D-14, Richard K. Meyers, Director
D-25 Division of Environmental Affairs
Texaco, Inc.
P.O. Box 509
Beacon, New York 12508
D-15 Hugh V. Miller, Jr.
Vice President of Manufacturing
Allied Materials Corporation
P.O. Box 589
Stroud, Oklahoma 74079
(continued)
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TABLE 2.1 (continued)
Document number Commenter and affiliation
0-16 Lecil M. Colburn
Director of Environmental Affairs
Jim Walter Corporation
P.O. Box 22601
1500 North Dale Mabry
Tampa, Florida 33622
D-17 J. G. Huddle, Coordinator
Air and Water Conservation
Amoco Oil Company
P.O. Box 6110A
200 East Randolph Drive
Chicago, Illinois 60680
D-18 Robert H. Collom, Jr.
Chief Air Protection Branch
Environmental Protection Division
Department of Natural Resources
270 Washington Street, S.W.
Atlanta, Georgia 30334
aThese designators represent docket entry numbers for
Docket OAQPS A-79-39. These docket entries are available for public
inspection at:
U.S. Environmental Protection Agency
Central Docket Section (A-130)
West Tower Lobby
Gallery 1, Waterside Mall
401 M Street, S.W.
Washington, D.C. 20460
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Before 1900, English pitches were used in the graphite industry, and
carcinoma was a problem due to arsenic in the pitch. The commenter
postulates that if unknown pitches that contain arsenic were imported
and substituted for asphalt, additional problems could occur.
Response:
At the present time, there is no indication that coal tars and coal
tar pitches of the type described by the commenter are being used in the
roofing industry. If information becomes available that indicates that
such coal tars or pitches are being used, the emissions would be evaluated,
and standards could be developed for processes using those materials.
Only very limited data are available on emissions from coal tar
saturators, and the EPA does not have data to determine what technology
would represent best demonstrated technology for control of such compounds
as arsenic, which were components of English pitches imported prior to
1900.
Failure to include coal tar saturators in the standards at this
time is not spot legislation. The Administrator may distinguish among
classes and types within categories of new sources for the purpose of
establishing standards of performance ([Section lll(b)(2)].
2.1.2 Comment: D-4
The commenter responded to the request in the Federal Register
Notice (45 FR 76414) for comments on the effects of different crude oils
and the catalytic blowing of asphalt on particulate emissions. The
commenter stated, "There is a substantial difference in the chemical
composition of today's asphalts compared to those used in EPA test
program. Not only are the asphalts not as pure, but they are being
mixed continuously. Thus it is conceivable that every roofing plant in
the U.S. is using a separate and distinct asphalt."
Response:
EPA recognized in the BID (Chapter 3, pp. 3-35 and 3-36) that the
use of asphalt fluxes from different crude oils might influence particu-
late hydrocarbon emissions from blowing stills. In the discussion of
the afterburner (control device) in Chapter 4 (pp. 4-17 to 4-22), it was
pointed out that the destruction of hydrocarbons was dependent on the
afterburner operating temperature and on the residence time of the fume
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in the afterburner. A well-designed afterburner can control the emissions
from the variety of asphalt fluxes that may be used. The preamble to
the proposed regulation contains an evaluation of the economic feasibility
of using an afterburner to control emissions from blowing stills processing
asphalt fluxes different from those processed during the test program
(45 FR 74610-11). The following was concluded in the preamble: "Because
well-designed control equipment could achieve the proposed emission
limit without adverse economic impacts, the Administrator has determined
that the proposed emission limit would apply to blowing stills processing
asphalt fluxes from any crude oil."
The commenter did not supply any new data or substantive information
which would indicate that different crude oils would affect the ability
to control particulate emissions or which would lead to reconsideration
of the above stated conclusions.
2.1.3 Comment: D-24
The commenter suggests that EPA conduct a series of new tests to
ascertain if the changes in the types of crude oils available now, which
make these oils different from those available during data gathering,
have changed the volatility, and therefore the controllability of saturator
emissions. The commenter acknowledges that EPA considered the effects
of different crude oils on blowing still emissions and now wants EPA to
consider the effects on saturator emissions.
Response
EPA recognized and discussed in the preamble the effect of changes
in currently available crude oils on the quantity of emissions from the
blowing still. Effects on saturator emissions were not discussed because
crude asphalts are not used directly in a saturator but are first processed
in a blowing still to produce saturant asphalts with specifications
established by the asphalt roofing manufacturers. In the asphalt blowing
process, volatile hydrocarbons are driven off as the asphalt is processed
to a specified softening point and penetration. The physical properties
of the blown roofing asphalt are carefully controlled to assure a
consistent product quality. Volatility differences in the crude oils
should not influence emissions from the saturator because the asphalt
has already been processed to drive off volatile hydrocarbons.
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Therefore, EPA does not feel that a series of new tests are necessary to
ascertain if the differences in currently available crude oils have
affected the controllability of saturator emissions.
2.1.4 Comment: D-24
The commenter stated that:
The asphalt roofing industry is undergoing a rapid change
in the use of felts. At this time approximately 20 percent of
the industry's production involves fiberglass "felts" in place
of the traditional paper felts. It is predicted that this
trend will continue and may result in the restriction of paper
felts to a less significant market share as soon as 1985.
As EPA is aware, when fiberglass is used to make asphalt
shingles, the saturation step using the traditional saturator
and wet looper is omitted. All of the asphalt is applied by
the coater when fiberglass is used. The effect of this change
is to make the Proposed NSPS for particulate emissions from the
saturator obsolete before it is even final.
Not only are mass figures radically different for shingles
made from fiberglass, but emissions are considerably less. EPA
should assess this change in industry practice in depth and
determine whether it mandates a serious revision or even
elimination of the standard.
Response
EPA believes that the emission reduction achievable by controlling
the saturator will be significant since 80 percent of the shingles in
today's market are saturated paper felt shingles. If the market
conditions change significantly in the near future such that saturated
paper felt shingles are only a small portion of the total production,
the Agency can evaluate the impact and make an appropriate revision.
The emission limit for the saturator is specified as kilogram (kg)
of particulate per megagram (Mg) of asphalt shingle produced and is
based on the production of shingles with a nominal weight of 106.6 kg
(235-Ib) per square. The commenter may be concerned that the standard
would be more difficult to achieve when fiberglass shingles are being
produced because there are more fiberglass shingles per ton than there are
paper felt shingles per ton. This concern is not justified. The
emissions (the numerator in the emission limit) when fiberglass shingles
are produced are considerably less than when paper felt shingles are
being produced because two out of the three emission points are not used
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in manufacturing fiberglass shingles, and the asphalt is at a lower
temperature than it would be if the other two higher temperature steps
were used. The masses are not "radically different" between fiberglass
shingles and saturated paper felt shingles. Fiberglass shingles vary in
weight per square from 93.2 kg (205-lb) to 102.3 kg (225-lb) with an
average weight per square of 100 kg (220-lb). The slight difference in
weight between fiberglass and felt shingles would make only a small
change in the denominator. This difference would be offset by the
change in the numerator (emissions). Therefore, the standard would be
achievable when fiberglass shingles are produced. EPA has decided that
the saturator standard will be promulgated as proposed.
2.2. COVERAGE OF REGULATION
2.2.1 Comment: D-1
The commenter said that all manufacturing industries using asphalt
and/or coal tars should be covered by this regulation.
Response:
In accordance with the Clean Air Act as amended in 1977, the
Administrator established a priority list that identified industries
which were potential sources of significant air pollution and for which
new source performance standards should be established. Asphalt roofing
manufacture was identified on the priority list promulgated on
August 21, 1979. A source category may include multiple plant types
that employ similar processes and control technologies. For example,
asphalt processing (blowing of asphalt) was added to the asphalt roofing
manufacturing source category because both employ the same or similar
processes. Industries that use different processes and control
technologies to manufacture asphalt products would not be included in
this source category. If emissions from such processes were determined
to be significant, standards could be promulgated for the source
category appropriate to the industry(ies).
2.3 ALTERNATIVE CONTROL DEVICES
2.3.1 Comment: D-2
The commenter stated that it would seem only reasonable for regulatory
documents to recognize reduced energy consumption devices which have
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been proven to give equivalent performance even though these devices
have not been tested by the EPA staff. A high energy air filter system
has been installed on a blowing still at a plant in California and is in
compliance with the South Coast Air Quality Management District regulations.
Response:
The proposed emission standard is based on test data from an
afterburner. However, the preamble (45 FR 76406) notes, "Other pollution
control devices are available that may achieve the level of control
required by the proposed standards. Any control technique that achieves
the emission limit outlined in the proposed standards could be used to
comply with the standards."
2.3.2 Comment: D-4. D-7
The commenters state that the opacity limit for stills could possibly
eliminate any other equipment innovations and force the industry to
utilize incinerators as the only possible control device.
Response:
As stated in Response 2.3.1 above, any control device that meets
the particulate emission limit for blowing stills may be used. However,
if the control device does not meet the opacity limit while meeting the
particulate standard during a performance test, Section 60.11(e) of the
General Provisions provides that the operator may apply for adjustment
to the opacity standard for that affected facility.
2.3.3 Comment: D-6
The commenter stated that:
With the present state of the art, asphalt manufacture
utilizes an energy-intensive process. For a roofing company,
energy constitutes approximately 50 percent of total manu-
facturing cost. Without process improvements, the energy
component will likely become a greater component of manufac-
turing cost due to energy's expected inflation rate.
There is tremendous potential for improving the efficiency
of the asphalt manufacturing process. One logical approach
would be to expand and upgrade certain existing blowing stills
while curtailing others. Under this scenario, the gross emis-
sions in pounds per hour for the expanded unit would increase,
but the emissions per ton of finished asphalt would decrease.
The end result would be a more efficient process, lower
manufacturing costs, and reduced emissions.
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EPA's proposed NSPS would be a major deterrent to the type
of progress described above. Under the requirements of the
Clean Air Act, the expansion of the one unit would be a modifi-
cation of an affected facility which subjects the source to the
NSPS. Thus, the company would be required to install an
incinerator on the upgraded and more efficient blowing still.
The capital and operating costs for an incinerator would greatly
exceed the product savings expected from the process improve-
ments. Management is reluctantly forced to continue operation
of the existing, relatively inefficient units.
EPA should declare that control equipment for asphalt
blowing stills have a favorable cost benefit relationship.
There are other types of control equipment for blowing stills
which will do a commendable job at much lower cost.
Response:
The commenter's statement that energy accounts for 50 percent of
the manufacturing costs for a roofing plant refers to the ratio of
energy cost to the total cost of production. The opacity standard
applies to the blowing still. The blowing still and the afterburner
account for only 2.5 percent of the total cost of production.
The commenter questioned the applicability of the standard if
production is curtailed from some blowing stills and expanded in others.
The upgraded still would not be considered a modified still (and therefore
not subject to the NSPS) if the controlled mass emission rate in kilograms
per hour from that still were not increased beyond the previous emission
rate. However, if the controlled mass emission rate were increased, the
expanded still would qualify as a modified still and would be covered by
the standard.
The potential for substantial savings in energy costs would be an
incentive for industry to replace process equipment, and EPA would not
want to prevent such replacement. However, in this industry, the cost
of controlling the new equipment to meet an NSPS, beyond the cost of
compliance with SIP's, is small. That is, the model plant studies show
that all the capital costs and most of the energy costs for an incinerator
would be necessary to meet the State Implementation Plan (SIP) particulate
and opacity standards. A new, modified, or reconstructed facility would
have to meet the SIP standards if the NSPS did not exist. The cost of
compliance with the NSPS above the cost of compliance with the SIP's,
for a blowing still in a medium size model plant, would be $25,200 per
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year. For a roofing plant producing 2,060,000 squares per year (medium
size model plant), the $25,200 annualized cost would increase the produc-
tion cost from $13.48 to $13.49 per square. Gross profits, at a selling
price of $15.87, would decrease by 0.3 percent if this cost were not
passed through. EPA determined that these impacts are reasonable and
would not deter management from replacing existing units with more
energy efficient units.
2.3.4 Comment: D-24
The commenter states that mist eliminator technology has gained a
firm place in the emission control equipment market for saturators.
This technology was not assessed by EPA in the preparation of the proposed
NSPS. A mist eliminator ". . . can eliminate certain drawbacks of the
other technologies in the right circumstances." The commenter believes
that EPA should assess this technology before finalizing the regulation.
Response
The mist eliminator was not tested by EPA as a control device for
saturator emissions during the source testing program and is not considered
representative of best demonstrated technology. However, this does not
preclude its use in particular circumstances. As stated in the preamble
(45 FR 76406), any control device that achieves the level of control
required by the proposed standard may be used. (See Comment 2.3.1.)
The data contained in the test report, Stationary Source Sampling Report,
dated April 1981, (Docket No. A-79-39-IV-D-024) supplied by the commenter,
show that the specific mist eliminator tested did control emissions
during the two tests at a level that just met the proposed standard.
2.4 OPACITY STANDARD FOR STILLS
2.4.1 Comment: D-2. D-24
Commenter (D-2) states, "The emissions from the blowing still are
essentially the same as those from the asphalt saturator where trace
visible emissions are allowed." Therefore, the commenter requests that
visible emissions also be allowed from the still. Another commenter
(D-24) suggests that the opacity limit for blowing stills be set at
20 percent, or the same as the opacity limit for the saturator.
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Response:
The opacity limits set for the blowing still and the saturator are
each based on the test data obtained for that particular facility. When
the blowing still control device, an afterburner, was being tested, no
visible emissions (zero opacity) were observed. The visible emissions
data in percent opacity are in the BID, Table 4-9, p. 4-46. Three
control devices [an afterburner, a high velocity air filter (HVAF), and
an electrostatic precipitator (ESP)] were tested and were determined to
represent the best demonstrated systems of continuous emission reduction
for the saturator. While all three were meeting the proposed particulate
emission limit during the tests, two of the devices exhibited visible
emissions (BID, Table 4-9, p. 4-46). The opacity of emissions from the
ESP varied from 0 to 18 percent; the opacity from the HVAF varied from 0
to 15 percent; and the opacity from the afterburner was always zero.
Thus, the opacity standards were based on demonstrated performance
during emission testing, zero percent for the blowing still and 20 percent
for the saturator, to allow any of the three saturator control devices
to be used.
Any control device that achieves the particulate emission limit may
be used to comply with the standards. If the control device does not
meet the opacity limit while meeting the particulate emission limit
during a performance test, the operator may petition the Administrator
to make appropriate adjustments to the opacity standard [Section 60.11(e)
of the General Provisions].
2.4.2 Comment: D-3. D-12. D-15
Three commenters state that the zero opacity limit for the blowing
still is too stringent and suggest a 10 percent opacity limit. With the
zero limit, there would be no flexibility for incinerator operation.
Excessive energy would be needed to fire the incinerator and preclude
any excursions above the proposed limit. The zero percent opacity would
require perfect operation of an incinerator or ESP and would require
excessive maintenance and use of energy.
Response:
The opacity limit was based on test data (BID, Table 4-9, p. 4-46).
Every opacity reading was zero during the 22-hour test, and the
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participate emissions from the tested afterburner were consistently below
the proposed emission limit. The participate standard and the opacity
standard were based on this afterburner, which was selected as
representative of the best demonstrated system of continuous emission
reduction.
Reference Method 9 states, "Opacity shall be determined as an
average of 24 consecutive observations recorded at 15-second inter-
vals . . . . For each set of 24 observations, calculate the average by
summing the opacity of the 24 observations and dividing this sum by 24."
The method allows for excursions in opacity. If the sum of the
24 observations is less than 10 percent, the average opacity would be
less than 0.5 percent, which would round to zero percent.
The amount of energy required to operate the afterburner was
conservatively estimated since the heating value of the hydrocarbon in
the fume was not taken into account. The cost of the required energy
consumption was determined to be reasonable, as discussed in the preamble
(45 FR 76410-11).
2.4.3 Comment: D-4, D-7
Two commenters state that the zero percent opacity requirement is
most unreasonable, especially at startup and shutdown periods, and locks
the industry into using afterburners as the only control device.
Response:
Section 60.11(c) of the General Provisions states that the opacity
standards set forth in this part shall apply at all times except during
periods of startup, shutdown, and malfunction. The cost and economic
impact of afterburners were examined as discussed in the Federal Register
(45 FR 76410-11). The impacts were judged to be reasonable. However,
the industry is free to use any technology that meets the particulate
emissions standard, as discussed in Response 2.3.1.
2.4.4 Comment: D-4. D-7, D-13
Two commenters (D-4, D-7) state that if plants use fuel oil instead
of gas to fire the afterburner, the chances for zero opacity with current
control devices are slim. "In the EPA test program, only one blow still
was tested and it used an incinerator fired with natural gas."
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Another commenter (D-13) stated:
While adjustments are made in the emissions rates for
afterburners, depending on fuel type and catalyst application
during blowing, no adjustments were made in the opacity limit.
Thus, this visual limit could effectively override the specified
emissions requirements.
Response:
EPA recognizes that if fuel oil is used to fire the afterburner, a
blowing still may be in compliance with the particulate standard but not
be able to meet the zero opacity standard. Therefore, a provision has
been added to the regulation that describes procedures to be followed if
an owner or operator wants to petition the Administrator to establish a
different opacity standard for the blowing still when fuel oil is used
to fire the afterburner. The procedures are in accordance with
Section 60.11(e) of the General Provisions. When natural gas is used to
fire the afterburner, the zero percent opacity limit will apply.
2.4.5 Comment: D-13
The commenter stated:
The requirement for zero percent opacity for blowing stills
is an excessively stringent requirement. Opacity limits
for the rest of the refinery operations have been set at
20 percent. The zero percent opacity does not allow for
the +5 percent limitation in opacity measurement.
Response:
The proposed standard is based on the best demonstrated system of
continuous emission reduction for asphalt blowing stills. As discussed
in Response 2.4.2, the opacity limit for the blowing still can be consist-
ently achieved at a reasonable cost. The blowing still process is a
different operation from other refinery processes and, as such, would
not be expected to have the same opacity limit.
Opacity in Method 9 is an average of 24 readings taken at 15-second
intervals for a 6-minute period. For example, under Method 9 one reading
of 10 percent or two readings of 5 percent in each 6-minute period could
occur without exceeding zero percent opacity because the average of all
readings would be below 0.5 percent, which would round to zero. The
positive observational error associated with an average of 25 readings
has been established (40 CFR 60, Appendix A, Method 9). The accuracy of
the method is taken into account by enforcement agencies when determining
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possible violations of opacity standards. All Method 9 opacity readings
taken during the 22-hour test to develop this standard were zero percent.
2.4.6 Comment: D-13
The commenter states that opacity measurements are visual
measurements of sources which are already controlled under other rules
and the visual limit could effectively override the specified emissions
requirements.
Response:
Opacity limits have been proposed to aid enforcement and operating
personnel in determining that the emission control devices are properly
maintained and operated. The use of opacity standards for this purpose
is supported by Section 302(1) of the Clean Air Act, which provides
for any requirement relating to the operation or maintenance of a source
to assure continuous emission reduction. The use of opacity standards is
further supported by Portland Cement Association v. Train, 513, F.2d 506,
508 (D.C. Cir. 1975). If a control device for a blowing still meets
the emission limit during a performance test but exceeds the zero percent
opacity, the owner/operator may petition the Administrator to make an
adjustment to the opacity standard following the provisions of
Section 60.11 of the General Provisions, and a new opacity standard may
be established for that particular facility. Once an opacity standard
for an affected facility is established, exceeding that opacity would
constitute a violation of that standard; and such a violation could also
be considered in a determination of proper operation and maintenance.
2.5 MONITORING REQUIREMENTS
2.5.1 Comment: D-4. D-7. D-13. D-15
Three commenters (D-4, D-7. D-15) stated that the requirement for
continuous recording of the operating temperature and maintenance of the
temperature records for 2 years would either make excessive demands on
personnel or would require additional personnel. Another commenter
(D-13) stated that the recordkeeping requirements are not necessary due
to the quarterly reporting requirements.
Response:
EPA reviewed the recordkeeping and reporting requirements to
determine if their purpose (ensuring proper operation and maintenance of
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the control device) could be achieved with fewer recordkeeping and/or
reporting requirements.
The temperature of the control device would be recorded automatically
by an instrument onto a permanent, hard copy disc or card. Such automatic
recording and subsequent storage of the cards for 2 years should not
place an excessive demand on personnel, so the recordkeeping requirements
are not being changed. Without this requirement, the owner/operator and
the enforcement agency would have difficulty determining if proper
operation and maintenance of the control device were being conducted.
The records of constant temperature monitoring, together with the
opacity standards being promulgated, should provide enforcement agencies
with sufficient means of ensuring that the control devices are properly
maintained and operated on a continuous basis without the necessity for
quarterly reports. Therefore, in an effort to reduce reporting costs,
the Administrator has decided to remove the requirements for quarterly
reports from the proposed regulation.
2.5.2 Comment: D-3. D-4, D-7. D-12, D-15
Two commenters (D-3, D-12) stated that constant temperature
monitoring and routine reporting of the temperature profile would not be
of value to the enforcement agency in determining if the emission standard
has been met, and, therefore, this requirement should be eliminated.
Two commenters (D-4, D-7) disagree with the statement: "If the
average temperature over any 6-hour period of operation was below that
measured for incinerators or above that measured for HVAF's or ESP's, by
definition excess emissions would have occurred." The commenters state
that weather and operating conditions will have a major bearing on any
test. An increase in emissions, if it occurred, would not necessarily
be over the allowable limit.
Three commenters (D-3, D-12, D-15) stated that the standard requires
testing and thereafter fixing incinerator operating parameters on a
worst-case scenario. There should be some provision made to compensate
for variations in feed material which affect blowing temperature, time,
and emissions, and for continuous blowing.
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Response:
The constant temperature monitoring requirement is based on
Section 302(1) of the Act, which provides:
The term "standard of performance" means a requirement
of continuous emission reduction including any requirement
relating to the operation or maintenance of a source to assure
continuous emission reduction. [Emphasis added.]
EPA believes that changes in temperature from those measured during a
performance test are good indicators for an owner/operator to use to
ensure good operation and maintenance. Exceeding the temperature measured
during the performance test for an HVAF or ESP or not maintaining at
least the temperature measured during the performance test for an after-
burner could indicate a violation of the requirement to properly operate
and maintain the control equipment as stated in Section 60.11(d) of the
General Provisions. This Section states:
At all times, including periods of startup, shutdown,
and malfunction, owners and operators shall to the extent
practicable, maintain and operate any affected facility
including associated air pollution control equipment in a
manner consistent with good air pollution practice for
minimizing emissions. Determination of whether acceptable
operating and maintenance procedures are being used will be
based on information available to the Administrator, which
may include, but is not limited to, monitoring results,
opacity observations, review of operating and maintenance
procedures, and inspection of the source.
Although periods of temperature excursions or reductions (depending
on the control device) as determined by temperature measurements would
not of themselves constitute a violation of the numerical emission
limits, they may indicate to an enforcement agency the need to conduct a
performance test. The results of the performance test would be used to
determine compliance with the numerical emission limits in accordance
with Section 60.11(a) of the General Provisions.
EPA acknowledges that the operating temperature of the control
device is one of several parameters that determine the amount of
particulate emitted and that the correlation between operating temperature
and emissions is not absolute. However, it would be burdensome for the
owner or operator to keep records of all parameters that influence
emissions and then enter values for these parameters into a formula in
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order to calculate emissions. Instead, EPA believes that the best way
to demonstrate proper operation and maintenance is to monitor only
temperature, which is critical to the destruction or collection of
particulate hydrocarbons.
For afterburners, temperature, hydrocarbon concentration, and
exposure time at temperature all influence destruction efficiency. The
emission data collected during the testing program (BID Chapter 4) and
other data (Docket No. A-79-39-II-I-025) used in the analyses show that
if the residence time is constant, the afterburner operating temperature
is critical to the efficiency of hydrocarbon destruction. For HVAF's
and ESP's, the collection efficiency increases as the operating temperature
decreases (BID Chapter 4).
Maintaining the operating temperature at the level which was recorded
during a performance test when the numerical emission was met ensures
that the control device is being operated and maintained properly.
However, since EPA recognizes that the ambient temperature may affect
emissions from the HVAF and ESP, a provision was made in the proposed
regulation to allow plant owners or operators the option of repeating
the performance test if such changes are made and thereby establish a
new temperature value (45 FR 76413). Maintenance of this temperature
would be required, and failure to maintain the temperature, averaged
over a 6-hour period, could be considered in the determination of proper
operation and maintenance of the control device.
2.5.3 Comment: D-12
The commenter stated that no provisions are made for exceptions
that would justify deviations from those incinerator operating parameters
established during the compliance test. An example of such exceptional
conditions is a refinery where the incinerator is not dedicated to the
affected blowing still (i.e., existing or nonaffected process using the
incinerator) or when the affected blowing still is down and the incinerator
remains in a cutback operational state.
Response:
The rationale for the selection and usefulness of temperature
monitoring requirements is explained in Response 2.5.2. Compliance with
the opacity and particulate standards and with the temperature monitoring
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requirement is required only when the affected facility is operating.
EPA does not anticipate more than one blowing still at a time operating
and discharging exhaust gases to an incinerator. While an existing
(nonaffected) blowing still is operating and being controlled by the
incinerator, compliance is not required.
2.5.4 Comment: D-13
The commenter states that normal operating procedures require
monitoring of the various operating parameters on a routine basis. This
is done to maintain efficiency of the overall process. If an upset does
occur, continuous monitoring will not stop this. Routine monitoring
will note this and respond quickly. Furthermore, under refinery prac-
tices, all critical process data are recorded for use in maintaining
efficient operations. Therefore, continuous monitoring does not appear
to be cost effective, nor does it contribute to the overall efficiency
of operations.
Response:
As stated in Response 2.5.2, the control device operating temperature
is used to ensure proper operation and maintenance of the control device.
The continuous monitoring requirement is not meant to replace routine
monitoring of the process and control equipment by operating personnel.
It has been determined that the operating temperature of the afterburner
is critical to efficient destruction of hydrocarbon emissions. It has
also been determined that the cost of the monitoring requirement (now
without quarterly reporting) is reasonable (Docket No. A-79-39-IV-A-022).
2.6 FUGITIVE EMISSIONS FROM SATURATOR HOODING
2.6.1 Comment: D-4, D-6. D-7. D-17
Two commenters (D-4, D-7) stated opposition to the fugitive emission
standard for saturators which limits the time that visible emission from
the saturator capture system are allowed. They pointed out that the
fugitive standard is not based on a scientific analysis of what is being
emitted but on a judgment made by an observer.
Another commenter (D-6) said:
The technical deficiencies of monitoring indoor fugitive
emissions will be difficult to hurdle in any enforcement
proceeding. Will the results vary with the lighting, building
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temperature and observer position? Will the court be willing
to ignore de minimi's emissions from crevices of the equipment?
Another commenter (D-17) stated that the standard should be changed
to no emissions in excess of zero percent opacity because heat waves can
make emissions visible even though no particulate or other pollutant is
present.
Response:
The proposed standard is based on the proposed Reference Method 22,
which requires a determination of the presence or absence of visible
emissions, not a measurement of opacity or quantity of emissions. The
scientific basis for this method and the development of this method were
discussed in the Federal Register (45 FR 76413 and 76422). Method 22 was
developed during the testing and data gathering program for this standard
and for other standards specifically to overcome the technical
deficiencies of monitoring the presence of visible emissions indoors and
outdoors. Method 22 requires observer training on the procedures for
determining the presence of visible emissions. This training consists
of the observer learning the information in the documents, referenced in
Method 22, on the effects of background contrast, ambient lighting,
observer position relative to lighting, the presence of uncombined water
on the visibility of emissions, and the difference between heat waves
and emissions. De minimi's emissions from the crevices of saturator
hooding should not be observed if the hooding is properly designed,
installed, and operated. If the hooding is not properly designed or
operated and de minimi's emissions occur, these would be observed as
fugitive emissions in violation of the standard if they occur more than
20 percent of the time. For the above reasons, and as previously explained
in the preamble, EPA believes that the fugitive emission standard as
stated is reasonable and accurate; therefore, no change is being made.
2.6.2 Comment: D-4. D-6. D-16
Commenter D-4 asks if EPA has jurisdiction over equipment within
the plant when the Clean Air Act (CAA) limits EPA authority to "ambient
air," a term which has been defined as measuring the atmosphere external
to buildings.
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Commenter D-6 stated that EPA is now asserting jurisdiction to
control emissions inside a building, which is clearly the domain of
OSHA.
Commenter D-16 stated that EPA is not responsible for workplace
environment; Congress specifically restricted its authority to the
ambient atmosphere. Therefore, the portions of the proposed subject
standard regarding inplant fugitive emissions must be deleted in their
entirety.
Response:
The Clean Air Act gives EPA the authority to regulate emissions
from stationary sources. Section 111(3) defines a stationary source as
"any building, structure, facility, or installation which emits or may
emit any air pollutant." Any emissions that escape from the saturator
and are not captured by the hood or enclosure would be emitted to the
outside through doors, windows, and roof vents. Observation of these
diffused emissions from outside the building would be extremely difficult.
Therefore, the standard requires that the fugitive emissions be observed
indoors at the source of the emissions.
2.6.3 Comment: D-4. D-15
Commenter D-15 stated that the fugitive emission standard is too
stringent. "These emissions occur on an intermittent basis, they vary
according to asphalt temperature and quality, and would require control
equipment which are all high maintenance or operating cost items."
Commenter D-4 did not believe that control of fugitive emissions to
the extent required by the standard has been adequately demonstrated as
required by the Clean Air Act.
Response:
Section 111 of the Clean Air Act requires that standards of
performance reflect "the degree of emission limitation achievable through
application of the best technological system of continuous emission
reduction which (taking into consideration the cost of achieving such
emissions reduction . . .) the Administrator determines has been ade-
quately demonstrated . . . ." The assessment of the various systems of
capturing emissions from asphalt saturators is discussed in the BID
(Chapter 4) and in the preamble (45 FR 76411-12). These discussions
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present test data which show that the total enclosure is currently the
most effective capture system for saturator emissions and that the perform-
ance of this system has been adequately demonstrated. A properly designed
and operated system would be able to achieve the proposed emission
standards over the full range of operating conditions (asphalt temperature
and quality) that occur in a saturator. EPA therefore believes that the
proposed standard is consistent with the Clean Air Act requirements and is
supported by the data.
Enclosures of the type required to meet the visible emissions standard
are being installed around new saturators as standard industry practice.
One of the major reasons why full enclosures are being installed instead of
canopy hoods is that a full enclosure significantly reduces the air flow to
the control device, and therefore, the control device can be sized smaller.
The capital and annualized costs of a saturator control system with a full
enclosure hood are lower than the capital and annualized costs of a
saturator control system with a canopy hood (Docket No. A-79-39-IV-B-14).
Enclosures are also being installed as standard practice because their
presence reduces the extent of damages that might occur in the event of
fire (fires frequently occur in asphalt saturators) (Docket No. A-79-39-
IV-E-12. When the enclosure is part of the facility construction, the
enclosure/saturator "fit," or configuration, can be designed and built to
minimize any technical difficulties. However, EPA recognizes that
installing an enclosure around an existing saturator could present tech-
nical problems that may result, in some cases, in unreasonably high design
and installation costs. At this time, there is not enough information
available about the cost of retrofitting enclosures for the Agency to be
certain that the costs would be reasonable in all cases. Consequently,
existing saturators that become subject to the standards through modifica-
tion are exempted from the visible emissions standard. This exemption does
not apply to saturators that become subject to the standards through
reconstruction. The five reconstructed saturators that have been projected
by industry are those that will be rebuilt as a result of extensive fire
damage (Docket No. A-79-39-II-E-13). Because at least 50 percent of the
saturator will be rebuilt (a facility is determined to be reconstructed only
if the costs are equal to or exceed 50 percent of the costs to build an
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entirely new facility), the physical constraints that may be associated
with an entire, existing saturator would not be present. The enclosure
could be designed and installed as part of the saturator construction.
The costs are not expected to be different from the costs for an enclosure
on a new facility. Therefore, reconstructed saturators are not exempt
from the visible emissions standard.
2.7 OPACITY STANDARD FOR MINERAL HANDLING
2.7.1 Comment: D-5. D-24
Commenter (D-5) stated that the opacity standard of 1 percent in
Section 60.472(d) is totally unenforceable. According to the preamble,
this standard was based on observations of visible emissions from the
affected facility, using Reference Method 9, that gave readings equal to
or less than 1 percent. The commenter does not think that it is possible
for any human being to make such observations to the accuracy required
to come up with such readings. Another commenter (D-24) states that
determining 1 percent opacity is impractical and could not be met by
industry. The commenter recommends that the opacity be set at 10 percent.
Response:
Opacity determination for compliance does not depend on a single
reading. Method 9 states that an opacity reading is the average of
24 readings taken at 15-second intervals for 6 consecutive minutes. The
15-second readings shall be entered to the nearest 5 percent opacity.
For example, it is possible to meet this requirement and still record
opacities greater than zero, as long as the sum total of the 24 opacity
readings is less than 35 percent. This would result in an average
opacity reading of 1.4 percent, rounded off to 1 percent. The 1 percent
opacity limit is enforceable and is clearly supported by the data reported
in EPA 450/ 3-80-021a (see pp. 4-54, and C-54 through C-58). Therefore,
the regulation is not being changed.
2.8 GRADUAL IMPLEMENTATION
2.8.1 Comment: D-4, D-7
Two commenters recommend that more consideration be given in the
standards to permit greater flexibility for companies to meet the stan-
dards. It seems to the commenters that the purpose of such standards
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should be to reduce emissions with "state-of-the-art" equipment to a
feasible level and not to try to move to ground zero in one step. A
gradual implementation will assure quick and reachable solutions within
cost parameters that are possible.
Response:
EPA has developed the standards in accordance with the mandate of the
Clean Air Act (CAA). The standards "reflect the degree of emission limita-
tion achievable through application of the best adequately demonstrated
technological system of continuous emission reduction, taking into con-
sideration the cost of achieving such emission reduction, any nonair
quality health and environmental impacts, and energy requirements"
[BID, p. 2-2, and Section 111(a) of the CAA]. The control devices on which
the standard is based are used in the industry and are described in
Chapter 4 of the BID. The emission limit for each affected facility has
been set so that there is a margin between that limit and the highest limit
achieved by the control devices tested for that facility. Since new source
performance standards apply only to new sources or to those that are changed
substantially enough to meet the criteria for modification or reconstruc-
tion, nationwide implementation will be gradual. The costs of purchase,
installation, operation, and maintenance were evaluated for the control
devices on which the emission limits are based. These costs and the
associated economic impacts have been determined to be reasonable.
2.9 ASPHALT STORAGE TANKS
2.9.1 Comment: D-9, D-10
Commenter D-9 states that the definition might be misinterpreted to
include tanks located at a refinery that did not process asphalt. The
commenter suggested that the definition be rewritten to exclude asphalt
tanks at refineries where blowing is not conducted.
Commenter D-10 states that the proposed NSPS and proposed amendment
to the priority list would effect all new, modified, or reconstructed
asphalt tankage, not just roofing asphalt tankage at asphalt roofing
manufacturing/processing facilities. The commenter questions if EPA's
BID adequately addressed the environmental and economic impact of
controlling tankage for asphalts other than roofing asphalts. There is
a definite implied assumption that the asphalt tankage proposed for
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control are at major facilities such as asphalt roofing manufacturing
plants, asphalt processing plants, or oil refineries.
Response:
All asphalt storage tanks at petroleum refineries, asphalt processing
plants and asphalt roofing plants are subject to the standard. Asphalt
storage tanks at refineries with blowing stills are no different from
asphalt storage tanks at refineries without blowing stills. The, same
control technologies are applicable to storage tanks at refineries,
whether or not a blowing still is present. There is no reason to exclude
storage tanks at refineries that currently do not have blowing stills.
The control cost per installation is the same whether the tank stores
roofing or nonroofing asphalt. EPA analyzed the economic impacts of the
standards and determined that the impacts were reasonable. Storage
tanks at any of these three locations are included in the standards.
Information from a refiner without a blowing still indicates that
uncontrolled asphalt storage tanks where asphalt is stored at temperatures
below 149°C (300°F) exhibit a zero percent opacity (Docket No. A-79-39-
IV-D-011). Therefore, if asphalt is stored at a relatively low temperature,
the tanks may meet the proposed standard without controls.
2.9.2 Comment: D-3. D-12
The commenters stated that the zero opacity creates a safety hazard
because the mist eliminator required to meet the proposed standard will
plug due to the coating of asphalt. This plugging would cause a reduction
of the flow of equalizing air through the tank vent and could result in
explosion or implosion during filling or draining operations. The risk
incurred is not justified by the miniscule reduction in air pollution
occasioned by the application of mist eliminators. The zero opacity
standard for asphalt storage tanks should be removed from the regulation.
Response:
The zero opacity standard for storage tanks is being promulgated
because technology to achieve the zero opacity at a reasonable cost has
been demonstrated and will reduce emissions from asphalt storage tanks
by about 90 Mg/yr (99 tons/yr). The data on which this standard is
based are presented in the BID, Chapter 4, Table 4-9, and in Appendix C,
pp. C-4 and C-53. A mist eliminator would require periodic maintenance
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and cleaning to ensure proper operation. A properly designed mist
eliminator will not be unsafe if the required routine maintenance and
cleaning procedures are followed. Any control device that can meet the
zero opacity standard for storage tanks can be used.
2.9.3 Comment: D-13
The commenter stated that the need for emission controls from
asphalt storage tanks is questionable. The cost effectiveness of mist
eliminators on storage tanks ranges from $1,225 to $1,804 per ton of
collected pollutant (BID, Table 8-46). This requirement should be
deleted. The cost is significant for removal of only 1 percent of the
emissions from a model facility.
Response:
The cost of pollution control for each of five regulatory options
are discussed in Chapter 8 of the BID. The Administrator considered the
capital costs, annualized costs, cost per ton of particulate collected
($1,225 to $l,804/ton) and the economic impacts of the cost on profit,
product prices, plant closings, unemployment, and exports and determined
that all the costs are reasonable for the particulate removal of 90 Mg/yr
(99 tons/yr) and will not inhibit industry growth. No new information
has been presented to change this assessment.
2.9.4 Comment: D-14. D-25
The commenter stated, in two separate comment letters, that the zero
opacity rule for vent emissions from asphalt storage tanks is considered
unreasonable, since no substantive evidence is presented to support the
technical feasibility or availability of economically reasonable control
equipment within the refining/processing industry. The commenter did
not find test data from storage tanks or even the mention of a mist
eliminator. He expected mist eliminators in continuous service to clog
with baked-on oil and asphalt the same way EPA test equipment did when
Method 5 was used contributing to high maintenance and replacement
costs.
Response:
Mist eliminators are described on page 4-14 of the BID. On page
4-46, Table 4-9 of the BID, opacity data from asphalt storage tanks that
are controlled by a mist eliminator are summarized. In Appendix C on
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pages C-4 and C-53 (Table C-23), the complete data are presented. These
data show that the proposed standard can be achieved by the use of mist
eliminators. The mist eliminator would require periodic maintenance and
cleaning for proper operation. Maintenance costs were calculated and
included in the annualized costs for the model plants. These costs were
considered in the Administrator's determination that the cost of achieving
the standards in the proposed regulation is reasonable for asphalt
processing plants, petroleum refineries, and asphalt roofing plants (see
also Response 2.11.1).
2.9.5 Comment: D-17
The commenter states that the opacity limit on emissions from
asphalt storage tanks should be relaxed to permit visible emissions for
periods not to exceed 15 minutes in any 24-hour period. This would
allow continuation of the necessary industry practice of blowing transfer
lines to clear high softening point asphalt from the lines before it
solidifies. Often large transfer lines in refineries are thousands of
feet long, terminate at remote locations, and must be quickly cleared of
asphalt to avoid plugging. At remote locations the only practical
method of clearing the line is to blow the line back to the tank using
nitrogen or air.
Response:
The opacity standard for asphalt storage tanks has been changed to
allow the blowing back of the transfer lines. The promulgated standard
allows emissions for not more than 15 consecutive minutes in any 24-hour
period when the transfer lines are blown for clearing. However, the
control device must not be bypassed during this 15-minute period, as
stated in the regulation.
2.9.6 Comment: D-10. D-ll
The commenters state that the proposed NSPS should only address
roofing asphalt because of the lack of information in the BID and preamble
on other types of asphalt. There is no information on emulsified asphalt,
cutback asphalt, and paving asphalt. Facilities handling these commodities
are totally different operations from those which process and handle
roofing asphalt. Furthermore, the physical properties and emission
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characteristics of emulsified asphalt, cutback asphalt, and paving
asphalt are very different from roofing asphalt.
Commenter D-ll states that opacity observation tests were conducted
by untrained observers on asphalt stored at 136° to 138°C (275° to
280°F) using the visual inspection method of taking 24 observations of
15 seconds each within a 6-minute period. The observers recorded zero
percent opacity for all readings. He requested that EPA exempt asphalt
storage tanks, which can comply with the zero opacity limit without
control equipment.
Response:
Storage tanks containing cutback asphalts (asphalts mixed with
solvents to reduce viscosity and thereby facilitate low temperature
applications) and emulsified asphalts (asphalts finely dispersed in
water with an emulsifying agent) are excluded from these standards.
However, blowing and/or storage of roofing asphalts and other asphalts,
whether used for paving or other nonroofing purposes, are included in
the standards. These asphalts are essentially the same as roofing
asphalts and the same equipment is used for oxidizing or storing either
type of asphalt. If the applicability of the standards depended on the
eventual use of the product, a still or storage tank could be subject to
the regulation on one day (while blowing or storing roofing asphalt) but
not subject to the regulation on another day (while blowing or storing
nonroofing asphalt). Even if the same still or storage tank were not
used for more than one type of asphalt, there could be one unit devoted
to roofing asphalts and subject to the regulation while another identical
unit devoted to nonroofing asphalts would not be subject to the regulation.
Furthermore, to meet the increased demand for roofing asphalt, a
manufacturer could increase capacity by constructing new stills or
storage tanks but then limit the use of the new facilities to nonroofing
asphalts while devoting a larger number of existing facilities to roofing
asphalts (46 FR 28180).
The processes and control technologies are the same, and the emission
limits remain achievable, whether the asphalt is to be used for roofing
or nonroofing purposes. Therefore, blowing stills and storage tanks for
paving and other nonroofing asphalts are included in the standards. The
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definition of "asphalt storage tanks" was changed with the amendment to
the proposed standards (46 FR 28180) to specifically exempt cutback and
emulsified asphalts.
As stated in the preamble to the amendment (46 FR 28180), storage
tanks that store asphalt at low temperatures may exhibit zero percent
opacity without controls. These storage tanks would, therefore, meet
the standard, and the operator would not have to install a control
device as long as the zero percent opacity is maintained.
2.10 DEFINITION OF ASPHALT PROCESSING
2.10.1 Comment: D-12
The commenter states that the definition of asphalt processing is
ambiguous and uncertain. The use of the term "asphalt processing plants"
in the definition of the term "asphalt processing" creates an uncertainty
that should be eliminated. The following is suggested: ". . . asphalt
processing means the storage and air blowing of roofing asphalt at
refineries and asphalt roofing manufacturing plants . . . ."
Response:
Blowing stills are located at plants which are neither a petroleum
refinery nor an asphalt roofing plant. To include these plants, the
term "asphalt processing plant" was used and is now defined in the
standard. Asphalt may be blown for purposes other than production of
asphalt roofing. The definition is not intended to specify the end use
of the blown asphalt.
2.10.2 Comment: D-3
The commenter said that the definition of asphalt processing is
ambiguous and should be clarified. The production of paving asphalts or
roofing fluxes from vacuum tower bottoms, where no blowing is required,
would be exempt from these regulations under the proposed definition.
Response:
The actual production of asphalt products from vacuum tower bottoms,
where no blowing is required, is not included in the regulation. Storage
tanks containing these asphalts are included in the regulation.
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2.11 DATA BASE FOR REFINING/PROCESSING INDUSTRY
2.11.1 Comment: D-14.D-25
The commenter stated in two separate comment letters, that the data
base for the refining/processing industry should be strengthened before
final regulatory action is taken. Many of the processes, control devices,
and test procedures discussed have little or no relevance to the refining/
processing industry, primarily because the major emphasis of the NSPS
appears to be on the roofing industry. The associated technical feasibi-
lity and cost-effective analysis are considered inadequate to support
the recommended regulations for the refining/processing industry.
The use of HVAF's is considered to be impractical for refining/
processing because of plugging, and the filter replacement frequency
would make such a system manpower intensive. Afterburners and electro-
static precipitators require extensive collection systems, including
vapor holding tanks to reduce peak loading of the control facilities
during tank-charging operations. It does not appear that the cost of
these facilities have been considered.
Response:
The only affected facilities at petroleum refineries and asphalt
processing plants would be the blowing still and the asphalt storage
tanks. The control devices that were tested and shown to be effective
in controlling emissions from these processes are afterburners for the
blowing still and mist eliminators for the storage tanks. These facilities
and the production processes are the same as those used in the roofing
industry. There is no technical reason why these controls could not be
used at a refinery as well as at a roofing plant. However, the operator
may use any alternate control device of his choice as long as it can
achieve the emission limit.
EPA analyzed the impacts of the costs of complying with the NSPS at
petroleum refineries (Docket No. A-79-39-IV-B-6 and IV-B-7). The costs
of collecting and controlling the emissions from asphalt storage tanks
and blowing stills were used in the impact analysis. Two model plants
were developed: (1) a small size model plant producing 194,040 Mg/yr
(215,360 tons/yr) of blown asphalt and (2) a large size model plant
producing 251,034 Mg/yr (277,500 tons/yr) of blown asphalt. The results of
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the analysis show that if all control costs were passed through, the
percent price increase would be 0.5 percent for the small size model plant
and 0.4 percent for the large size model plant. The return on investment
(ROI) for the baseline (SIP control) plants would be about 22 percent for
both plants. If the costs were absorbed by the petroleum refineries, the
ROI would decrease from 22 percent to 16.4 percent for the small plant and
from 22 percent to about 16.7 percent for the large plant. EPA believes
that these cost impacts are reasonable.
EPA expects the petroleum industry to be able to pass through
pollution control costs to the wholesale and retail markets. Since 1972
the wholesale prices of gasoline, distillate, and residual oil have
increased at an annual rate of greater than 19 percent. Not all of this
was due to increased costs for crude oil since profit margins rose
28 percent annually from 1978 to 1980.
2.12 PROPOSED REFERENCE METHODS
2.12.1 Comment: D-16
The commenter expressed particular concern about EPA's assessment of
the impact of the proposed Method 5A (formerly Method 26) test procedures
on existing facilities which may become subject to the standard through
modification or reconstruction and stated that:
The available test data on control systems on asphalt
roofing facilities is based on Method 5 or locally established
test procedures. No correlation of results obtained using
Method 26 versus those obtained using Method 5 or any other
procedure was attempted. This makes the evaluation of existing
operations relative to the proposed NSPS impossible.
USEPA must realize that since the proposed mass emission
requirements are based on a small number of tests conducted at
selected plants using Method 26, there can be at best only a
small degree of confidence that the proposed emission rates
will be within the performance capabilities of a variety of
control systems serving facilities having an even greater
variety of new material and process variables. A correlation
of a new test method to past performance test procedures must
be made by USEPA before the environmental impact of the NSPS
can be determined. . . . USEPA should withhold promulgation of
this standard and application of Method 26 until adequate
correlation testing is conducted and the results made available.
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Response:
During method development testing, it was determined that EPA
Reference Method 5 was not adequate for measuring emissions from the
affected facilities in the asphalt processing and asphalt roofing industry.
As discussed in the BID (Appendix D), there were two major problems in
using Method 5 for measuring emissions from asphalt. These problems
were: (1) the solvent used for cleaning the test equipment would not
recover all of the material collected, and (2) the collection temperature
specified in Method 5, 121°C (250°F), is higher than the temperature
required to condense and collect the asphalt hydrocarbon particulate.
EPA developed Method 5A specifically for particulate emissions from the
asphalt processing and the asphalt roofing industry. The solvent used
in Method 5A is different, and the filtration temperature specified in
Method 5A is 42°±10°C (108°±18°F). Because the amount of particulate
collected varies with filtration temperature and the amount analyzed is
affected by recovery efficiency, data from Method 5 cannot be correlated
with data from Method 5A.
Test data from Method 5 were not used to establish the allowable
emission level nor to assess control equipment performance. The standards
are based solely on data from Method 5A. There is no need for EPA to
measure emissions using Method 5.
Section 111 of the Clean Air Act requires that the standard reflect
the degree of emission reduction achievable through the application of
the best system of continuous emission reduction which (taking into
consideration the cost of achieving such emission reduction and any
nonair quality health and environmental impact and energy requirements)
the Administrator determines has been adequately demonstrated. Based on
a survey of the industry, EPA believes that the high volume air filter
(HVAF), the electrostatic precipitator (ESP), and the afterburner (A/B)
represent the best demonstrated systems of continuous emission reduction.
Emission tests were conducted at asphalt facilities in different
geographical areas. All three of the control devices (HVAF, ESP, and
A/B) were tested. The variations in materials, processes, and control
equipment that might affect the achievability of the standard have been
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discussed in the preamble (45 FR 76404) and the BID (Chapters 3, 4, 6,
and 8) and were considered in setting the emission limits. The proposed
standard for participate emissions was set at a level which was demon-
strated to be achievable by each of the control devices tested.
2.12.2 Comment: D-24
The commenter provided test data (Stationary Source Sampling Report,
dated April 1981, Docket No. A-79-39-IV-D-024) showing a comparison
between saturator emissions measured using Method 5 and Method 5A. The
commenter believes the differences indicate a need to reexamine the
interrelation between the proposed standard and Test Method 5A. The
commenter suggests a new series of tests be conducted.
Response
EPA has reviewed the test report submitted which shows an emission
level of 0.0132 Ib/ton using Method 5 and 0.0822 Ib/ton using Method 5A.
These results demonstrate EPA's evaluation that Method 5 does not ade-
quately collect and measure asphalt hydrocarbon particulates (see
Comment 2.12.1). The standard is based on results of tests conducted
using Method 5A. The standard was set at a level which was higher than
each of the levels measured during the test program and is achievable
using Method 5A. For these reasons, EPA does not believe that additional
testing is required.
2.12.3 Comment: D-24
The commenter has conducted a saturator emission test at a modern
facility (new) using a mist eliminator as the control technology. The
results of the first three test runs yielded an average emission rate of
0.0822 Ib/ton when test Method 5A was used. On the following day, the
emissions from three test runs (Method 5A) averaged 0.061 Ib/ton. The
commenter believes that the results of these tests provide strong confirm-
atory evidence that the proposed NSPS for saturator particulate emissions
will be very difficult to meet with Reference Test Method 5A.
Response
The saturator emission tests show that the tested facility just met
the proposed emission limit. The standard is stated to the nearest
hundredth Ib/ton. For the first test the 0.0822 Ib/ton (0.0411 kg/Mg)
rounds down to 0.08 Ib/ton (0.04 kg/Mg). Both 0.08 and 0.061 Ib/ton
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meet the emission limit of 0.08 Ib/ton. Although the facility met the
proposed limit, it should be noted that (1) the control device used, a
mist eliminator, was not selected as representative of best demonstrated
technology and (2) the gas stream was not cooled prior to entering the
mist eliminator. The level of the standard is based on best demonstrated
technology, which includes HVAF's, ESP's, and afterburners. When HVAF's
or ESP's are used, the gas stream must be cooled before it enters the
control device to ensure vapor condensation. When afterburners are
used, the combustion temperature must be high enough to destroy hydrocarbon
particulates. If best demonstrated technology is used, the standard
will be achievable using Test Method 5A.
2.12.4 Comment: D-13
The commenter asks what temperature range is permissible for filter
operation (Section 2.1.4). The temperature cannot exceed 52°C
(Section 4.1.5); however, there are restrictions such as those in Method 5.
If the air stream is water saturated, then the filter can become saturated
at 52°C.
Response:
The proposed version of Method 5A did not specify a minimum
temperature or a range of operating temperatures. Because the collection
temperature directly affects the amount of particulate collected, EPA
has decided to specify a range of filter and probe temperatures including
an upper and lower limit for operation.
The probe and filter operating temperature specifications have been
revised to 42°±10°C (108°±18°F). The results of EPA's emission tests
show that this range of temperatures can be maintained by commercially
available source sampling equipment. Maintaining this temperature range
will minimize the effect of temperature changes on the amount of
particulate collected.
Section 2.1.3 of Method 5A specifies the use of a precollector
cyclone only if the sample gas stream is moisture saturated. The intent
is to maintain the precollector cyclone at approximately the same
temperature as the filter and thereby collect moisture droplets before
the sample reaches the filter. The filter is thus protected from moisture
saturation and should remain dry through the test run.
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2.12.5 Comment: D-13
The commenter asks if the cyclone is maintained by ambient temperature
(Section 4.1.3).
Response:
As noted above, the precollector cyclone is maintained at the
temperature of the filter in order to collect moisture droplets condensed
at that temperature and to protect the filter from moisture saturation.
2.12.6 Comment: D-13
The commenter asks if the desiccation requirement of Method 5A will
be sufficient to rapidly achieve constant weight.
Response:
The EPA determined from its test program that for control system
outlet samples, the criteria for constant weight defined in Method 5A,
Section 4.3.1 was met for all samples between the 24- and 48-hour weighings
following the solvent drying period. About one in three samples from
control device inlet locations took as long as an additional 24 hours
(total 72 hours) to reach constant weight following the solvent drying
period. The solvent drying period duration depends on the amount of
solvent in the sample. The EPA laboratory tests have shown that the
solvent drying time can be decreased substantially by heating the sample
to 100°F without any significant sample loss. This procedure has been
added to Method 5A. The Agency feels that these sample drying and
desiccation time requirements are not excessive.
2.12.7 Comment: D-13
The commenter says that Method 22, "Visual Determination of Fugitive
Emissions from Material Processing Sources," requires a subjective judg-
ment. This method does not require a trained observer. Therefore, the
criteria for a visual determination depends solely on the observer. The
observer should be trained regarding the effects on visibility of emis-
sions caused by background contrast; ambient lighting; and observer
position relative to lighting, wind, and condensing water vapor; however,
the method does not require training. EPA used Method 9 to develop the
data base for the standard. EPA proposed opacity standards. Compliance
is then determined by a subjective pass/fail technique. The emission
frequency could depend on the observer's visual acuity. The requirements
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for positioning of the observer (5.1) coupled with the interference
determination (5.4.3) make this method totally subjective. Has EPA
validated this method with a panel of 10 people?
Response:
The commenter is concerned about the ability of an observer to detect
a visible fugitive emission with precision and about the effects of condi-
tions around the observation site on the reported values. The determination
of the presence of a fugitive visible emission is objective. EPA
comparisons of paired observers during method development testing showed
that there was a small degree of imprecision in the results. The degree of
imprecision and the variables associated with Method 22 measurements were
considered in setting the level of the standard, and a safety margin was
included. Therefore, even with the small degree of imprecision in the
method, the standard has been determined to be achievable. Validation of
the method by a panel of 10 people is not considered necessary.
EPA agrees that training of a Method 22 observer regarding positioning,
lighting, potential interferences (e.g., condensing water vapor), and
correct documentation procedures is necessary and states this in Method 22
(Section 1). There is a distinction between training and certification.
EPA sees no need for observer certification for Method 22 observations.
A Method 22 observer does not need the ability to determine plume opacity,
only the ability to detect the presence of visible fugitive emissions and
to time the duration of these emissions. One suitable source for this type
of training is the lecture portion of the visible emission schools provided
by EPA and other organizations around the country. Other sources include
the written material provided by EPA discussing visible emission determina-
tions. Two such documents have been added to Method 22 as references, and
Method 22 requires the observer to know this material prior to the field
test.
2.12.8 Comment D-13
The commenter asks what quality assurance will be required for
Method 22.
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Response:
EPA feels that strict adherence to the procedures In Method 22 is
sufficient quality assurance for the determination of the duration of
visible fugitive emissions.
2.12.9 Comment D-6
The commenter says that the technical deficiencies of monitoring
indoor fugitive emissions will be difficult to handle in any enforcement
proceeding and wonders if the results will vary with the lighting, building
temperature, and observer position.
Response:
Refer to Response 2.12.5 for a complete response to this comment. In
brief, the potential technical problems, such as poor lighting, low contrast
backgrounds, and other conditions affecting the detection of visible emis-
sions, are addressed in Method 22. Training of the observer for awareness
of these potential problems is necessary as stated in the method
(Section 1). EPA is aware of these potential problems and has prepared the
regulation and the method accordingly.
2.12.10 Comment D-18
The commenter states:
Review of the proposed standard and of the Background
Information Document (BID) for the visible emission standard
[60.472(a)(3)] does not indicate the fugitive emissions from
asphalt saturator capture systems cause a significant air
quality impact, sufficient to warrant a separate standard.
Method 22 for visible emission evaluation would require a
significant amount of time for a regulatory agency to conduct.
This time could better be spent on the emission points causing
the most air quality impact. We do not believe that the effect
on manpower and other resources required to enforce this standard
have been sufficiently addressed. Also, observation of emissions
in a building may not adequately relate to emissions which
reach the outside air.
We suggest that § 60.472(a)(3) and Method 22 not be required.
As an alternative, we suggest that EPA give consideration to
modifying this regulation so as to require each new, modified,
or reconstructed saturator to be equipped with a totally enclosed
hood system. Such an equipment standard should preclude the
need for § 60.472(a)(3) and Method 22, and the questionable use
of visible emission evaluations which may not have any signi-
ficant air quality impact.
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Response:
Emissions from the saturator cannot be controlled by the control
device unless they are captured and delivered to the control device.
Emissions that are not captured may escape the building and contribute
to ambient air pollution. The fugitive emission standard (which requires
manpower and resources to enforce) is necessary to ensure effective
capture of the emissions. EPA believes that this requirement is reason-
able. The Clean Air Act Section lll(b) states that "if, in the judgment
of the Administrator, it is not feasible to prescribe or enforce a
standard of performance, he may instead promulgate an equipment standard."
It is feasible to prescribe and enforce a standard of performance for
the fugitive emissions from the saturator enclosure because the presence
or absence of emissions can be observed. Therefore, establishment of an
equipment standard would not be allowed by Section lll(h) of the Clean
Air Act.
2.13 CONTINUOUS BLOWING STILLS
2.13.1 Comment: D-17
The commenter recommends that continuous blowing stills be exempted
from the standard until tests confirm the applicability of the standard
to continuous stills. It is not clear that the particulate emissions
limits specified in Section 60.472 for emissions from blowing stills
(based on measurement of emissions from a single batch still) should
reasonably apply to large continuous blowing stills, such as those
commonly used in refineries for the production of paving asphalt.
Hydrocarbon emissions from a blowing still depend upon the composition
of the charge to the still and the length of time that the charge has
been in the still. In batch operations, low boiling oils are stripped
from the flux early in the run. In continuous oxidizers, flux is
continually charged to the blowing still, and blown flux continually
withdrawn. Since fresh charge is continuously added, low boiling oils
are present in the emissions throughout the entire run, not only at the
start of the run.
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Response:
The commenter was contacted for information on continuous blowing
and data on the emissions. The data furnished by the commenter (Docket
No. A-79-39-IV-D-021) indicate that the uncontrolled emissions from the
continuous blowing still would be about 1.65 kg/Mg (3.3 Ib/ton) of
asphalt charged. The uncontrolled emissions from the tested batch still
were 13.5 kg/Mg (27 Ib/ton) of asphalt charged. The air flow in the
continuous still was 0.5 m3/Mg (16 SCF/ton) of asphalt; the air flow in
the tested batch still was 1.3 mVMg (42 SCF/ton) of asphalt. The
commenter states that the mass rate of emissions from a continuous still
would be constant while the emission rate from the batch still would be
subject to peaks. EPA believes the emissions from the continuous still
will be easier and less expensive to control than emissions from a batch
still. A smaller afterburner could be used to control the fume from the
continuous still because the air flow is much smaller and the afterburner
does not have to be sized for peak emissions. Because of the lower mass
emission rate per unit of asphalt production, the afterburner would only
need to attain an efficiency of about 65 percent to meet the emission
limit. Low boiling oils are emitted throughout the blowing process.
The owner/operator of a batch blowing still would have to run the
performance test during peaks as well as valleys since he is required to
measure the emissions from an entire batch. Emissions during a 90-minute
period of a continuous blow would not yield any higher emissions on a
kg/Mg (Ib/ton) basis than a batch operation averaged over the batch.
EPA believes that the afterburner will capture the low boiling oils and
that the standard is achievable. Therefore, continuous blowing stills
have not been exempted from meeting the standard. The owner/operator
may run the performance test either during a 90-minute portion of the
continuous blow cycle or during batch operation of the blowing still.
2.14 CHANGES IN ROOFING INDUSTRY MARKET
2.14.1 Comment: D-4
The commmenter states that in selection of source for control, the
following statement appears: "Declines in construction of new homes
have generally been offset by increasing strength in the replacement
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market; thus, there has been a stable demand for roofing products." The
commenter states that this has not been the case in 1980; there has been
a 20 to 25 percent reduction in volume due to drops in the market for
new and replacement roofs.
Response:
The commenter takes exception to the statement that the asphalt
roofing market is stabilized by the replacement market, pointing out
that the sales volume in both markets was down 20 to 25 percent in 1980.
EPA's purpose in making the statement was to point out that the roofing
market is not dramaticaly affected by the very volatile new-housing
market. The data available to EPA during the development of the proposed
standards indicated that new housing starts varied greatly from year to
year during the 1970 to 1977 period. Over this period, housing starts
varied from plus 42 percent to minus 34 percent. However, asphalt
roofing shipments varied only from plus 12 percent to minus 8 percent
due to the stabilizing effect of the replacement market.
The statement in the preamble referred to by the commenter was
based on data from 1963 through 1977. These data show that when applied
over a period of years the statement is correct. Growth projections are
not based on a single years' production. The 1980 Bureau of Census data
on housing construction starts and roofing sales have not yet been
published.
2.15 COMMENTS ON DOCUMENT
The following comments on the background information document,
"Asphalt Roofing Manufacturing Industry-Background Information for
Proposed Standards," EPA-450/3-80-021a, June 1980, are as received from
Commenter D-4 and concurred with by Commenter D-7. Commenter D-4 provided
additional comments in a second letter (D-24). Appendix A, "Addendum to
the Asphalt Roofing Manufacturing Industry-Background Information for
Proposed Standards" contains the corrections and clarifications of the
BID that have resulted in part from these comments.
2.15.1 Comments on Chapter 3--Asphalt Roofing Manufacturing Industry
2.15.1.1 Comment. "On the Chart, Figure 3-1, p. 3-2, it shows
asbestos as a raw material for making dry felt. This is incorrect. We
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recommend removal of asbestos from raw materials and add a new box under
intermediate products entitled 'Asbestos Paper or Dry Felt.'"
Response:
Figure 3-1, p. 3-2, was taken from the Asphalt Roofing Manufacturers
Association publication "Manufacture Selection and Application of Asphalt
Roofing and Siding Products—Twelfth Edition." Asbestos is shown as a
possible raw material for felt. Roofing felts are made from fibrous
materials. Any fibrous material or combination of fibrous material may
be used to produce felts. However, as suggested by the commenter, the
use of asbestos as a raw material for roofing felts is declining.
2.15.1.2 Comment. "Throughout the text, reference is made to
felts being produced from 'asbestos.' Again, this statement is incorrect.
In all cases, it should read 'asbestos ply1 or 'asbestos paper1 as an
intermediate product, not as a substance used in producing dry felt."
Response:
As shown in Appendix A, the word "asbestos" is being changed to
read "asbestos paper" throughout the BID.
2.15.1.3 Comment. "In Figure 3-4, p. 3-10, there are two errors.
A typical roofing plant does not enclose the coater with the saturator
and, to our knowledge, a 'rotary kiln' is no longer used in the industry."
Response:
Figure 3-4, p. 3-10, was taken from the second edition of "Air
Pollution Engineering Manual." Many coaters are hooded with the emissions
ducted to the same control device used for emissions from the saturator.
Some of the newer enclosures installed in the industry do cover the
coater as well as the saturator. Therefore, we do not consider this to
be an error. The corrected figure in Appendix A shows that the mineral
particles for coating stabilizer are dried before being introduced into
the coating asphalts without specifying the type of drying equipment
used to dry the material.
2.15.2 Comment on Chapter 4--Emissions Control Techniques
"On p. 4-12, last paragraph, it is stated, 'The major disadvantages
(HVAF units) are: a lack of control of gaseous emissions, the large
pressure drops required . . . .' We believe the latter should read 'the
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large pressure drops requiring higher energy consumption . . .' would
help clarify the point."
Response:
The addendum in Appendix A reads as recommended in this comment to
clarify the BID statement.
2.15.3 Comment on Chapter 5--Modification and Reconstruction
In paragraph 5.3, on page 5-4, the statement is made that
"few, if any, facilities are expected to become affected facili-
ties by virtue of modification or reconstruction after proposal
of new standards." This simply is not correct. Based on
information given to the EPA earlier (December 12, 1979, meeting
of National Air Pollution Control Techniques Advisory Committee,
and on July 8, 1980, EPA Office of Air Quality Planning and
Standards), we estimate that at least 35 of our 118 plants, and
probably more, over the next 5 years will be required to comply
due to either modification or reconstruction. The economic
impact on the industry will be substantially greater than
estimated by the EPA. A comment made later by the same commenter
suggested that a reassessment of the impacts should be made.
Response:
The original EPA estimate was based on growth projections made by
examining the history of the industry and the expected growth in housing
construction. The information supplied by ARMA on new construction,
modification, and reconstruction was considered prior to proposal and is
contained in Docket No. A-79-39-II-E-013. The industry projections are as
follows: 5 new medium size plants will be built; 5 small plants will be
expanded to become 5 medium plants; 5 saturators will be reconstructed
to replace ones destroyed by fire; and 20 saturators will be modified by
increasing production from each one by 20 percent. EPA calculated the
environmental, economic, and energy impacts based en the industry projec-
tion. These impacts are presented in the Federal Register (45 FR 74607-8)
and were considered in evaluating the regulatory alternatives. The
Administrator has determined that the economic and energy impacts are
reasonable for both the original EPA estimate and the industry growth
projections. No reassessment is required. It should be noted that
compliance costs for the modified and reconstructed facilities will be
considerably lower than the commenter anticipates due to the exemption
of modified saturators from the visible emission standard.
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2.15.4 Comment on Chapter 7--Environmenta1 Impact
The entire Section from 7.1.3.1.1, beginning on p. 7-3
through p. 7-24, is new and, although we had verbal knowledge
of the Section, the industry has had little opportunity to
review it in any detail. Until we have had a chance to study
the Dispersion Analysis, the source data, etc., we cannot
comment on the accuracy of the information or the impact it
will have on industry plants.
Response:
Copies of the BID were sent to industry on November 24, 1980, in
time for response to the information contained in the dispersion analysis.
Since the dispersion analysis is not critical to the selection of the
regulatory alternatives or the emission limits but rather reflects the
impact of the regulation on the ambient air quality, EPA believes the
comment period provided is sufficient.
2.15.5 Comments on Chapter 8--Economic Impact, Industry Characterization
2.15.5.1 Comment. "Figure 8-1, on p. 8-3, also incorrectly describes
the processing chart with reference to 'asbestos.'"
Response:
Figure 8-1, p. 8-3, was taken from the Asphalt Roofing Manufacturers
Association publication "Manufacture Selection and Application of Asphalt
Roofing and Siding Products—Twelfth Edition." See Response 2.15.1.1.
2.15.5.2 Comment.
On p. 8-38, the paragraph 8.1.1.5.3, Imports and Exports,
states that 'The U.S. Department of Commerce publications for
1973 and 1977 do not report any imports or exports of asphalt
roofing products or roofing products of any type.' This is no
longer correct. In fact, the imports from Canada and Mexico of
asphalt roofing materials are increasing substantially each and
every month. (Please note data supplied for the record.) The
U.S. producer is attempting to compete with less than fair
value imports from Canada that have cost this industry an
estimated $64 million in sales in the last 5 years. The infor-
mation in the EPA 'backgrounder' needs to be updated.
Response:
The data supplied in the comment letter are duly reported above.
These imports amount to less than 1 percent of the total industry sales
for this period and will not substantially impact the economic evaluation
for the standard.
2-43
-------
2.15.5.3 Comment.
On p. 8-53, under paragraph 3, we again emphasize that the
economic impact on our industry will be substantially greater
than estimated by EPA. Even the EPA figures bear out our
conviction in reporting 'At least half of this increased capa-
city can be met by the expansion of existing facilities.
Several companies have indicated that they will increase the
productive capacity of their plants by adding a line to make
roll roofing.1 If we keep up with the demands of the market
place, reconstruction and modification will be necessary and,
in turn, the number of plants needing to meet the proposed
standards will be greater than EPA predicts. Industry estimates
that it would spend approximately $22,000,000 for capital costs
to comply, which is much more than the $300,000 suggested by
the EPA. A comment made later by the same commenter suggested
that reassessment of the impacts should be made.
Response:
The calculations for the initial environmental, economic, and
energy impacts were based on the 1977 production of this industry and a
projected growth rate of 1 to 2 percent per year in the 5 years following
proposal of the standard. This growth was calculated to result in the
production of an additional 720,000 tons of roofing by the industry, or
the equivalent of three medium size model plants. The environmental,
economic, and energy impacts were calculated for the construction of
three new plants. The cost figures presented in the BID are the additional
costs required to upgrade the plants from baseline (SIP control) to NSPS
(Alternative 5). At the December 12, 1979, NAPCTAC meeting, industry
representatives claimed that 55 plants would be affected by new construc-
tion, modification, or reconstruction. Industry stated that the capital
cost would be $22 million (January 1980 dollars). This figure was based
on the assumption that each of the 55 plants would spend $400,000 to
comply with NSPS. Industry assumed that a modification or reconstruction
to any facility would result in all facilities in the plant becoming
subject to the NSPS, so that every plant would spend the amount required
to control all facilities to the NSPS level. However, only the recons-
tructed or modified facility would become subject to the NSPS, and thus
the compliance cost for a plant with a modified or reconstructed facility
would be considerably less than the $400,000 figure predicted by industry.
The compliance costs for a modified saturator would average $8,500 in
2-44
-------
annualized costs and $20,300 in capital costs for the additional cooling
systems that would be necessary to meet the NSPS. EPA's cost data
indicate that an average new plant could spend $100,000 (November 1978
dollars) to bring all affected facilities into compliance with the NSPS.
During a meeting with EPA on July 8, 1980, and in a subsequent
telephone conversation with EPA (Docket No. A-79-39-II-E-013), the
asphalt roofing manufacturing industry representatives presented growth
projections which were lower than their original estimates (see response
to Comment 2.15.3). The capital cost required to move from the typical
SIP to NSPS control using industry's new growth projection would be
$1,300,000 (November 1978). The economic impact was calculated using
the later industry estimates for the number of affected facilities and
was determined to be reasonable. The calculated costs were presented in
the preamble to the proposed regulation.
2.15.5.4 Comment.
On p. 8-100, top of page, reference is made to 'heat
exchanger systems (and others) require 4 hours maintenance per
week, and the cyclones require 2 hours maintenance per week.'
Our experience has shown that required maintenance time is much
greater than mentioned. Thus, the variable costs, with the
addition of pollution control devices, will once again be
substantial and not as a minor item as the backgrounder suggests.
Response:
The maintenance requirements for the heat exchangers mentioned on
p. 8-100 of the BID are the requirements over and above the requirements
needed to meet SIP's. Therefore, the total maintenance of these devices
will require more time than is shown on p. 8-100. The variable costs in
the BID are the additional costs required to move from SIP control to
NSPS control.
2.15.5.5 Comment. "On p. 8-122, paragraph 8.3.3, the statement,
'It was the opinion of personnel at plants visited that the impact of
OSHA regulations on the industry is minimal.1 We would question this
general statement."
Response:
This statement refers to verbal opinions of plant personnel in the
last quarter of 1978 and the first quarter of 1979 during several plant
visits. These statements were confirmed in writing. The sentence has
2-45
-------
been changed as shown in Appendix A to state "... at several plants
visited . . . ."
2.15.5.6 Comment.
The following statement appears on p. 8-124, paragraph
8.4.1.2, Summary: 'If this additional control cost is com-
pletely passed through to customers, it will raise the price of
the product by 0.1%, a minor increase. If the control cost
must be completely absorbed by the manufacturers, the profit
margins of the manufacturers are such that a reduction in
profit margin equivalent to 0.1% of the price will not have a
major economic impact.1 As expressed earlier in this letter,
the industry volume in 1980 will be down 20-25% and is not
expected to rise significantly in 1981. Excessive imports of
Canadian shingles; the rising cost of asphalt, labor; continued
increases in state and Federal taxes; transportation costs;
growth of competitive products; growing capacity . . .all
influence the 'pass through' of costs to customers. Further
cost 'pass through' considerations have vanished. Any suggestion
that the manufacturer can swallow more reduction in profit
margin is unjustified, and to do so would have a major, not
minor, impact on company survival.
Response:
The new source performance standard will only affect new, modified,
or reconstructed facilities in this industry. The cost impacts calculated
refer only to the cost associated with compliance to the NSPS.
EPA agrees that business activity is currently depressed. The
influx of cheaper Canadian shingles is understandably of concern.
However, since the volume of imported Canadian shingles amounts to less
than one percent of domestic sales, EPA believes that the effect of
Canadian shingles on the overall U.S. market is small. As the business
climate improves, companies will consider capacity expansions. If, for
instance, a company requires a 15 percent return on investment before
considering a capital expenditure, it will be necessary to increase the
"hurdle" rate to 15.1 or 15.2 percent. EPA feels that this increase
will not deter a company from building a new plant, a new shingle line,
or a new still, especially since new equipment is usually more efficient
and cheaper to run than old equipment.
Finally, the year-to-year price increases since 1969 (BID, p. 8-39)
have varied from 5.6 to 39 percent, which shows a proven history of
successful cost pass through over the long term and indicates that
2-46
-------
0.1 percent increase due to pollution control costs would not inhibit
industry growth.
2.16 CONSIDERATION OF LOCATION
2.16.1 Comment: D-15
Some consideration should be given to the location of the
asphalt processing facility and the air quality existing in
that area. A dispersion modeling study of the area may indicate
that National Ambient Air Quality Standards (NAAQS) could be
met even with emissions exceeding the proposed standards of
performance for the asphalt processing industry. Climatological
data for only two locations in the United States would not be
fair evaluation of air quality where some remote asphalt plants
are located.
Response:
The achievement of specific NAAQS is not the specific objective of
Section 111 of the Clean Air Act. The overall objective of Section 111
is to improve existing air quality as older industrial sources of air
pollution are replaced with new industrial sources and to prevent new
pollution problems from arising.
2.17 MISCELLANEOUS
2.17.1 Comment: D-4
"The blowing still emission limit in 45 FR 76404 reads, 'Blowing
still particulate emissions would be limited to 0.60 kg/Mg
(1.28 Ib/ton) . . .'and should read '. . . (1.20 Ib/ton).'"
Response:
The commenter is correct; a typographical error was made. The
number should be ". . . (1.20 Ib/ton)," as was shown in 45 FR 76409.
2.17.2 Comment D-24
The commenter states that there are three changes in Section 60.474(b)
that are possible mistakes. In the second sentence, the word "each" has
been substituted for the word "the," and the weight value "125 Ib" has
been substituted for "235 Ib." In the last sentence, the word "saturant"
has been omitted. The substitution of the word "each" for "the" might
prevent a roofing company from using one control device to control
emissions from two saturator lines. The commenter suggests that
Section 60.474(b) be written as in the original proposal.
2-47
-------
Response
The weight value given in the second sentence should have read
"235 1b." This error has been corrected in the standards being
promulgated. The substitution of the word "each" for the word "the" was
an error and has been corrected. The word "saturant" and the definition of
saturant blow have been omitted to clarify that the performance test may be
run while blown products other than coating and saturant asphalts are being
produced.
2.17.3 Comment: D-24
The commenter makes the following requests of EPA: postpone the
implementation of the standards until not earlier than June 30, 1982;
seek information and invite assistance from ARMA and others in the
course of the requested testing, revision, and assessment of Method 5A;
and repropose on or after February 28, 1982, revised new source performance
standards for asphalt processing and asphalt roofing manufacture based
on the requested testing, revision, and assessment.
Response
No information has been furnished to support postponing the
implementation of the standards. EPA does not see the necessity to
conduct a new series of emission tests using Test Method 5A. The advice
and assistance of ARMA and others in the industry was solicited and
relied upon throughout the decision-making process. EPA does not believe
there is any reason to postpone promulgation.
2.17.4 Comment D-23
The commenter states that his earlier comments (comment letter D-13)
are still applicable. (This second letter (D-23) was received during
the public comment period following publication of the proposed amendment).
Response
No response needed.
2.17.5 Comment: D-8
The commenter states he has reviewed the proposed rulemaking on new
source performance standards for asphalt processing and asphalt roofing
manufacture and has no comments.
Response:
No response needed.
2-48
-------
APPENDIX A. ADDENDUM TO ASPHALT ROOFING MANUFACTURING
INDUSTRY BACKGROUND INFORMATION FOR PROPOSED STANDARDS
(EPA 450/3-80-021 a)
On page 3-1 of the Background Information Document, the statement,
"Felt can also be made from asbestos," has been changed to read, "A product
called asbestos paper may also be produced." On page 3-5 the word
"asbestos" has been removed from the sentence reading "Felts are produced
from saw dust . . . asbestos."
Figure 3-4 has been changed to remove the rotary kiln for drying
mineral dust and to substitute a mineral dryer for this process.
On page 4-12 the sentence "The major disadvantages are: . . . the
large pressure drops required ..." has been changed to read: "The
major disadvantages are: . . . the large pressure drops requiring higher
energy consumption . . . ."
On page 5-4 the sentence, "According to 40 CFR Part 60 ... few, if
any facilities are expected to become affected facilities by virtue of
modification or reconstruction ..." has been changed to read:
"... several facilities are expected to become affected facilities
because of modifications to increase production and reconstruction to
replace staturators destroyed by fire."
On page 7-30 the number "... (4,320 barrels/yr) . . . "should be
changed to ". . . (3,800 barrels/yr) . . . ."
Tables 8-34 amd 8-35 have been changed to correct the emissions from
asphalt storage tanks. Table 8-45 has been changed to correct the
annualized costs for the medium-sized plant.
On page 8-122 the sentence, "It was the opinion of personnel at
plants visited that the impact of OSHA regulations on the industry is
minimal," has been changed to read: "It was the opinion of personnel at
several plants visited . . . ."
A-l
-------
Tables C-3 and C-3a have been changed to correct the total concentra-
tion and total emission rates. Table C-19a has been changed to correct
the Ib/ton of particulate at the A/B inlet of run No. 4.
A-2
-------
UNO
1RUCK
TANK
TRUCK
A
i*vr.*tu
nfAirn
*W«TER9HAY USEO ALSO. THIS IS FOLLOWED IY "SIAL-OOVnT STHIP ArfllCATION.
Figure 3-4. Typical flow sheet for manufacturing shingles and rolls.12
A-3
-------
TABLE 8-34. UNCONTROLLED PARTICULATE EMISSIONS FROM EACH OPERATION
AT THE MODEL ASPHALT ROOFING PLANTS ON AN ANNUAL BASIS
Uncontrolled emissions
Plant operation
Saturator, wet
looper, and
coater
Filler surge bin
and storage
Parting agent bin
and storage
Asphalt storage
tanks
Blowing stills
Small
Mg/yr
65.89
20.53
13.06
4.40
378.00
plant
(tons/yr)
(72.63)
(22.63)
(14.40)
(4.85)
(417.00)
Medium
Mg/yr
130.82
27.06
19.60
8.90
746.00
plant
(tons/yr)
(144.22)
(29.83)
(21.60)
(9.80)
(822.40)
Large
Mg/yr
194.81
27.06
19.60
11.08
944.00
plant
(tons/yr)
(214.77)
(29.83)
(21.60)
(12.21)
(1,041.00)
Totals
481.88 (531.51)
932.38 (1,027.85) 1,168.00 (1,288.01)
-------
TABLE 8-35. UNCONTROLLED PARTICULATE EMISSIONS, CONTROL EMISSIONS, AND PARTICIPATE POLLUTANTS
COLLECTED FOR EACH MODEL ASPHALT ROOFING PLANT OPERATION AND POLLUTION CONTROL DEVICE
en
operation
and size
Saturator. wet
looper, and
coater
Small
Medium
Large
Filler surge
bin and storage
Small
Medium and
Large
Parting agent b1
and storage
Small
Medium
Large
Asphalt storage
Smal 1
Medium
Large
Description of control system
Devlce(s)
ESP/HE"
HVAF/HE"
A/B W/HRC
ESP/HE
HVAF/HE
A/B W/HR
ESP/HE
HVAF/HE
A/B W/HR
CYCd
F/Fe
CYC
F/F
In
CYC
F/F
CYC
F/F
M/Ef
M/E
M/E
NmVs
4.93
4.93
4.93
9.79
9.79
9.79
14.58
14.58
14.58
1.04
1.04
1.37
1.37
0.66
0.66
0.99
0.99
0.21
0.35
0.425
(scfm)
(10,450)
(10,450)
(10,450)
(20,750)
(20,750)
(20,750)
(30,900)
(30,900)
(30,900)
(2,200)
(2,200)
(2,900)
(2,900)
(1,400)
(1.400)
(2,100)
(2,100)
(450)
(740)
(900)
"C (DF)
38 (100)
38 (100)
760 (1400)
38 (100)
38 (100)
760 (1400)
38 (100)
38 (100)
760 (1400)
Ambient
Ambient
Ambient
Ambient
Ambient
Ambient
Ambient
Ambient
54 (130)
54 (130)
54 (130)
Uncontrolled
emissions
Mg/yr
65.89
65.89
65.89
130.82
130.82
130.82
194.82'
194.82
194.82
20.53
20.53
27.06
27.06
13.06
13.06
19.60
19.60
4.40
8.90
11.08
(tons/yr)
(72.63)
(72.63)
(72.63)
(144.22)
(144.22)
(144.22)
(214.77)
(214.77)
(214.77)
(22.63)
(22.63)
(29.83)
(29.83)
(14.40)
(14.40)
(21.60)
(21.60)
(4.85)
(9.80)
(12.21)
Controlled
emissions
Mg/yr
4.
4.
4.
8.
8.
8.
11.
11.
11.
4.
0.
5.
0.
2.
0.
3.
0.
0.
0.
0.
39
39
39
78
78
78
25
25
25
10
33
41
44
61
21
97
32
09
18
22
(tons/yr)
(4.84)
(4.84)
(4.84)
(9.68)
(9.68)
(9.68)
(12.40)
(12.40)
(12.40)
(4.52)
(0.36)
(5.96)
(0.48)
(2.88)
(0.23)
(4.38)
(0.35)
(0.10)
(0.20)
(0.24)
Pollutants
collected
Mg/yr
61.50
61.50
61.50
122.04
122.04
122.04
183.57
183.57
183.57
16.43
20.20
21.65
26.63
10.45
12.85
15.62
19.29
4.31
8.72
10.86
(tons/yr)
(67.79)
(67.79)
(67.79)
(134.54)
(134.54)
(134.54)
(202.37)
(202.37)
(202.37)
(18.11)
(22.27)
(23.87)
(29.35)
(11.52)
(14.17)
(17.22)
(21.25)
(4.75)
(9.60)
(11.97)
?ESP/HE c electrostatic precipitator with cooling system.
DHVAF/HE = high velocity air filter with cooling system.
JJA/B W/HR = afterburner with heat recovery.
CYC = cyclone.
,F/F = fabric filter.
'M/E = mist eliminator.
-------
TABLE 8-45.
INCREASE IN ANNUALIZED COSTS OF POLLUTION CONTROL SYSTEMS FOR ALTERNATIVES
2 TO 5 COMPARED TO THE BASELINE POLLUTION CONTROL SYSTEMS
a\
Plant
size
Small
Medium
Large
Plant
configu-
ration
1
1
1
2
2
2
1
1
1
2
2
2
1
1
1
2
2
2
Saturator
control
device
ESPC.
HVAF0
A/B W/HRe
ESP
HVAF
A/B W/HR
ESP
HVAF
A/B/ W/HR
ESP
HVAF
A/B W/HR
ESP
HVAF
A/B W/HR
ESP
HVAF
A/B W/HR
Increase in annual ized
Al
16
16
51
16
16
51
27
27
98
27
27
98
36
35
141
36
35
141
ternative 2
$
,200
,400
,800
,200
,400
,800
,000
,100
,000
,000
,100
,000
,300
,800
,300
,300
,800
,300
%
14.1
13.5
27.6
25.3
23.4
38.0
15.0
14.0
30.2
22.4
20.3
37.2
14.2
13.0
30.2
20.1
18.5
36.5
Alternative 3
$
29,300
29,500
64,900
16,200
16,400
51 ,800
52,200
52,300
123,200
27,000
27,100
98,000
66,900
66,400
171,900
36,300
35,800
141,300
%
25.4
24.2
34.6
25.3
23.4
38.0
29.0
27.0
38.0
22.4
20.3
37.2
26.2
24.2
36.7
20.1
18.5
36.5
costs (November 1978 dollars) '
Alternative 4
$
25,200
25,400
60,800
25,200
25,400
60,800
36,400
36,500
107,400
36,400
36,500
107,400
45,700
45,200
150,700
45,700
45,200
150,700
%
21.9
20.9
32.4
39.4
36.0
44.6
20.2
18.8
33.1
33.2
29.5
42.2
17.9
16.5
32.2
26.1
23.3
38.9
Alternative 5
$
38,300
38,500
73,900
25,200
25,400
60,800
61,600
61,700
132,600
36,400
36,500
107,400
76,300
75,800
181,300
45,700
45,200
150,700
%
33.3
31.6
39.4
39.4
36.0
44.6
34.2
31.8
40.9
33.2
29.5
42.2
29.8
27.6
38.7
26.1
23.3
38.9
.Net annualized costs are the sum of annual variable and fixed operating costs less recovery credits.
The increase in annualized cost as a percentage of the total baseline annualized cost.
.ESP = electrostatic precipitator.
°HVAF = high velocity air filter.
A/B W/HR = afterburner with heat recovery.
-------
TABLE C-3. PARTICULATE POLYCYCLIC ORGANIC MATTER CONCENTRATION
AND EMISSION DATA SUMMARY-PLANT A
(OCTOBER 9, 1975)
(METRIC)
Combined total
Inlet (Sampled stack) Outlet (TP-2) flow conditions
Sampling location (TP-1) Outlet (TP-3) estimated value for outlet stacks
Volume of gas sampled— Mm*6 2.25
Percent moisture by volume 2.1
Average stack temperature—'C 58.3
Stack volumetric flow rate— 12.47
Nm3/sc
Stack jjolumetric flow rate— 14.45
nrVs
Percent 1 sold net ic 106.7
Parti culate--POM uq
Sampling location Inlet
Component
Anthracene/Phenanthrene 51.2
Methyl anthracenes 181.8
Fluroanthene 0.950
Pyrene 7.40
Methyl pyrene/Fluoranthene 4.00
Benzo(c)phenanthrene 0.350
Chrysene/Benz(a)anthracene 8.30
Methyl chrysenes 21.8
Benzo fluoranthenes 5.30
Benz(a)pyrene )
Benz(e)pyrene )
Totals 294.6
Collection efficiency, percent
2.81
2.2
58.9
5.67
6.57
99.7
—
2.2
58.9
6.07
7.05
—
Concentration
kq/n^xlO-9
Outlet
44.8
102.2
6.25
2.90
20.9
Not
detected
0.700
0.350
0.350
0.900
179.4
Inlet
22.70
80.55
0.41
3.27
1.78
0.156
3.68
9.66
2.36
6.00
(13.07)
—
Outlet
15.90
36.16
2.22
1.03
7.41
N0e
0.25
0.12
0.12
0.32
(6.36)
—
2.2
58.9
11.74
13.62
—
Emission rate kq/sxlO-7
Inlet
2.83
10.04
0.05
0.40
0.23
0.02
0.45
1.21
0.29
0.74
16.25
Outlet
(TP-2*TP-3)a
1.86
4.25
0.26
0.12
0.87
NO
0.029
0.015
0.015
0.04
7.46
54.1
aAverage Nm3 at TP-2 outlet stack during four particulate tests was 6.6 percent higher than flow
from TP-3 stack. nrVs was 6.9 percent higher. These values were used to estimate total outlet
sflow.
"Normal cubic meters at 21.1°C, 101.7x10* Pa.
^Normal cubic meters per second at 21.1°C, 101.7x10* Pa.
Actual cubic meters per second.
*NO=No data.
8enz(a)pyrene and Benz(e)pyrene analysis combined and reported as one value.
A-7
-------
TABLE C-3a.
PARTICULATE POLYCYCLIC ORGANIC MATTER CONCENTRATION
AND EMISSION DATA SUMMARY—PLANT A
(OCTOBER 9, 1975)
(ENGLISH)
Sampling location
Volume of gas sampled — OSCF
Percent moisture by volume
Average stack temperature~°F
Stack volumetric flow rate —
OSCFMC
Stack volumetric flow rate —
acfma
Percent isokinetic
Inlet
(TP-1)
79.48
2.1
137
26,416
30.625
106.7
(Sampled stack)
Outlet (TP-3)
99.30
2.2
138
12.009
13,914
99.7
Outlet (TP-2)a
estimated value
~
2.2
138
12,858
14.946
—
Combined total
flow conditions
for outlet stacks
2.2
138
24.867
28.860
Particulate— POM
Sampling location
Component
Anthracene/Phenanthrene
Methyl anthracenes
Fluroanthene
Pyrene
Methyl pyrene/Fluoranthene
Benzo( c )phenanthrene
Chrysene/Benz( a )anthracene
Methyl chrysenes
Benzo fluoranthenes
Benz(a)pyrene J
Benz(e)pyrene )
Totals
ug
Inlet
51.2
181.8
0.950
7.40
4.00
0.350
8.30
21.8
5.30
13.5
294.6
Concentration
(qr/OSCFxlO-8)
Outlet
44.8
102.2
6.25
2.90
20.9
Not
detected
0.700
0.350
0.350
0.900
179.4
Inlet
9.92
35.2
0.18
1.43
0.78
0.068
1.61
4.22
1.03
2.62
5.71xlO-s
Outlet
6.95
15.8
0.97
0.45
3.24
N0e
0.11
0.054
0.054
0.14
2.78xlO-8
Collection efficiency, percent
Emission rate
(1b/hxlO-3)
Outlet
Inlet (TP-2+TP-3)3
2.25
7.97
0.04
0.32
0.18
0.015
0.36
0.96
0.23
0.59
12.9xlO-3
54.
1.48
3.37
0.21
0.096
0.69
NO
0.023
0.012
0.012
0.030
5.92xlO-3
1
'Average OSCFM at TP-2 outlet stack during four partlculate tests was 6.6 percent higher than
flow from TP-3 stack, acfm was 6.9 percent higher. These values were used to estimate total outlet
flow.
°0ry standard cubic feet at 70°F. 29.92 In. Hg.
*jDry standard cubic feet per minute at 70°F. 29.92 In. Hg.
Actual cubic feet per minute.
;NO=NO data.
8enz(a)pyrene and Benz(e)pyrene analysis combined and reported as one value.
A-8
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TABLE C-19a. PERFORMANCE SUMMARY OF EMISSION REDUCTION SYSTEM
FOR BLOWING STILLS COATING BLOWS—PLANT E
(ENGLISH)
vo
Run niMber 3
Date 8-21-75
Stack conditions
Sample location A/B inlet A/B outlet
Saaple number B-5 B-6
Volumtric flow rate— OSCFM 1,838 9.045
Stack temperature- -°F 419 391
Moisture-- vol. % 33.6 15.6
Production rates
Particulates--probe, upstrea*
iapingers, pref liter, filter,
gr/OSCF IS. 06 0.123
Ib/h 210.8 9.0
Ib/ton
Afterburner efficiency, percent
This run 95.7
Average, three runs
Gaseous hydrocarbons
pp« as CM, 6.420 69.2
gr/OSCf 1.894 0.020
Ib/h 28.83 1.57
Afterburner efficiency, percent
This run 94.6
Average, three runs
4 5
8-22-75 8-24-75 Average
A/B inlet A/B outlet A/B inlet A/B outlet A/B inlet A/B outlet
B-7 B-8 B-9 B-10
1.943 9,549 1.881 8.524 1.887 9.039
*30 382 411 382 420 385
33.9 15.0 34.9 16.5 34.1 15.7
8.9 tons/h
15.42 0.066 14.41 0.099 14.60 0 096
2^3 5.4 212.1 7.1 217.4 72
24.42 0.81
97.6 96.7
96.7
7.066 103.3 6,100 21.7 6.506 64 7
2.084 0.030 1.799 0.066 1.919 fl'oi9
33." 2.49 28.75 0.46 30.44 lisi
92.6 98.4
95.2
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TECHNICAL REPORT DATA
(Please read instructions on the reverse before completing)
1. REPORT NO.
EPA-450/3-80-021 b
2.
4. TITLE AND SUBTITLE
Asphalt Roofing Manufacturing Industry - B<
Information for Promulgated Standards of Pe
7. AUTHOR(S)
3. RECIPIENT'S ACCESSION NO.
6. REPORT DATE
ickqround July 1982
jrformance 6- PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Office of Air Quality Planning and Standarc
U. S. Environmental Protection Agency
Research Triangle Park, North Carolina 2T>
12. SPONSORING AGENCY NAME AND ADDRESS
Director for the Office of Air Qual . Plann
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 271
10. PROGRAM ELEMENT NO.
Is
11. CONTRACT/GRANT NO.
M1 68-02-3059
13. TYPE OF REPORT AND PERIOD COVERED
ina & Stds. Final
14. SPONSORING AGENCY CODE
HI EPA/200/04
16. SUPPLEMENTARY NOTES
16. ABSTRACT
Standards of performance for the control of emissions from asphalt processing
and asphalt roofing manufacture are being promulgated under Section 111 of the
Clean Air Act. This document contains: (1) a summary of all the public comments
made on the proposed standards and the Administrator's responses to the comments,
(2) a summary of the changes made to the standards since proposal, and (3) the
final environmental impact statement, which summarizes the impacts of the
standards.
17.
KEY WORDS AND DOCUMENT ANALYSIS
a. DESCRIPTORS
Air Pollution
Pollution Control
Standards of Performance
New Source Performance Standards
Asphalt Processing
Asphalt Roofing Manufacture
Particulates
18. DISTRIBUTION STATEMENT
Unlimited
b.lOENTIFIERS/OPEN ENDED TERMS
Air Pollution Control
19. SECURITY CLASS (This Report)
Unclassified
20. SECURITY CLASS (Tilts page)
Unclassified
c. COSATI Field/Group
13 b
21. NO. OF PAGES
65
22. PRICE
EPA Form 2220-1 (R««. 4-77) PREVIOUS COITION is OBSOLETE
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EPA Farm 2220-1 (R«». 4-77) (R«v»r««)
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