-------
of thermal drying operations is not expected to be large, and the
inflationary impact of the standard on the price of coal will be
insignificant (one percent or less).
-------
V. Inflationary and Energy Impacts
In accordance with the Agency's interim guidelines concerning
inflationary impact statements, the five-year annualized costs have
been computed for coal preparation plants. The five-year costs and
the fifth year annualized cost of implementation of the standards
have been estimated as $18 million and $11 million, respectively. Both
of these costs are well below the screening criteria ($100 million ind
$50 million) for preparation of inflationary impact statements, indicating
a minor impact.
The increased power consumption resulting from the standards was
assessed and is simmarized in Table IV. Although there is a 24% increase
in power requirement by the control system, relative to the energy
consumption of the facility for producing product coal, the standards
of performance will result in a negligille increase in power consumption
for pollution control by coal preparation plant facilities.
-------
Table IV
Annual Power Consumption
Increases Required by Standards of Performance
for Coal Cleaning Plants5
Expected Average Total Increase in Demand Incremental Increase
Annual Growth in Due to Standard of in Power Oemand Due
New and Modified Performance Compared to to Standards of
Facilities No Afr Pollution Control, Performance Beyond
(Capacity Per KWH/YR Requirements of
Facility Typical State
Implementation Plan,
KWH/YR
9 Dryers 53 x Id6 32 x 106
17
-------
References
1. Scrubber Handbook, Volume 1, Contract CPA-70-95, A.P.T., Inc,
Riverside, California.
2. Letter, D. W. Fritz, Flex-Kleen to C. B. Sedman, EPA, May 20, 1974.
3. Coal Preparation Plant Emission Tests, Test No. 73-CCL-2 Island
Creek Coal Company, Scott Research Laboratories, Plumsteadville,
Pennsylvania.
4. Letter, 0. K. Werle, Flex-Kleen to L. G. Jones, EPA, July 8, 1975.
5. Letter, J. A. Notary, Heyl 8 Patterson to L. G. Jones, EPA.
April 25, 1972.
6. 1GCI, "Air Pollution Control Technology and Cos ;s in Nine Selected
Areas," Seotember 30, 1972.
7. Oneida Heat Dryer Stack Test, Oneida Mining Company, Contract
614-299-9229, Tra Det Laboratories, Inc., June 20, 1975.
8. Letter, Carl E, Dillion, Barnes & Tucker Company to L. G. Jones,
EPA, November 25, 1975.
18
-------
VI. Surtmary of Public Coranents and EPA Responses
Twenty-seven comnent letters were received on the proposed
standards, six from coal companies, four from Federal agencies, four
from steel companies, four from electric utility companies, three
from State and local agencies, three from coal industry associations
and three from other interested parties. The comments were carefully
considered and, where determined by the Administrator to be appropriate,
changes were made to the proposed regulations.
A surunary of these comments ar«1 EPA's responses is presented in
this section.
-------
Key to Industry Code
Industry or Organization
A State or Local Air Pollution Control Agency
B U. S. Environmental Protection Agency
C Federal Governmental Agencies other than EPA
D Coal Companies
£ Coal Company Equipment Vendors
F Coal Industry Associations
,G Iteel Companies
H Electric Utility Companies
I Chemical Companies
-------
LIST OF COMMENTATORS
Commentator
Number
Commentator
Affiliation
IA-1
IA-2
IA-3
Y-l
Y-2
Y-3
Y-4
Y-5
Y-6
Y-7
Y-8
Y-9
Y-10
Y-ll
Y-12
Y-13
Y-14
Y-15
Y-16
Y-17
Y-18
Y-19
Y-20
Eric Zausner
Stanley Ooremus
William C. Rountree
J. N. Shuoe
Philip C. Reeves
George Palmer
George P. Ferreri
J. C. Anderson
0. R. Thorpe
Don Willis
David H, Anderson
J. N. Shupe
Richard W. Bliss
0. R. Sheets
Joseph H. Mullan
Milliam R. Meyer
J. R. Brough
G. L. Barthauer
J. P. HcCluskey
Howard R. Palmer
J. LeRoy Balzer
Richard H. Silverman
Robert L. Duprey
Federal Energy Administration
United States Department of the Interior
General Counsel of the Department of Commerce
Westmoreland Coal Company
Roberts & Schaefer Company
Olin Chemicals
Environmental Health Administration
United States Steel Corporation
GPU Service Corporation
National Mines Corporation
Bethlehem Steel Corporation
Westmoreland Coal Company
American Mining Congress
Kerr-HcGee Coal Corporation
National Coal Association
Virginia Air Pollution Control Board
Inland Steel Comnany
Consolidation Coal Company
Commonwealth Edison
The Dayton Power and Light Company
Utah International, Inc.
Salt River Project
EPA-Oivision of Stationary Source Enforcement
21
-------
Public Comment Summary: Coal Preparation Plants
Comment
Number
Commentator
Number
Category
Comment
Response
tss
2
IA-1
Y-22
IA-2, Y-2Z
C,C
Conventional coal cleaning pro-
cesses used in conjunction with
flue-gas desulfurization units
should be included within the
standards. The standards for
coal preparation plants should
also be revised to Include
cleaning of coal by solvent re-
fining processes.
The specific coal processing operations
regulated by these standards are affect*!
regardless of whether they are located in
coal liquefaction plants, power plants,
coke ovens, etc. Such operations have been ,
in use for many years and may be regarded ;
as "conventional. They have been identified I
by the Administrator as being a source of
emissions that may contribute signlficant.ly,
"to air pollution that causes or contributes
to the endangerment of public health or
welfare. Newer operations for producing
clean fuels from coal (e.g. coal liquefac-
tion, coal gasification, etc.) have r.ot
currently been so identified by tne
Administrator and are not affected by
these standards.
If environmental -impacts are not
considered with regulations the}
should be cross referenced to
other applicable regulations.
The title for subpart Y should
be revised to include the desig
,iation "new or modified" and
these terms should be defined
within the subpart to avoid
misunderstanding.
The environmental effects of the proposed
regulations were considered in volume 1
of the background document. Other ,
applicable regulations are a matter of public
record.
The requirements in Subpart Y affact all
new coal preparation plants, but may cr
may not affect facilities which undergo
physical changes. The question of what
constitutes a modification is being
addressed in proposed amendements to the
general provisions (Subpart A] of 40 CFR
Part 60. See 39 FR 36946 (October 15» 1974-)
-------
Comment
Number
Commentator
Number
Category
Comment
Response
IA-2
IA-2
ro
40
IA-3, Y-1Q, Y-2, Y-5,
Y-12
C, F, E,
G
The economic justification for
standards is unrealistic due to
the abnormally large model »
plants used in the analyses.
The data in Figure 10 of the
Background Information document
show" that the West Virginia Stats
standard applicable to thermal
dryers is 0.10 gr/dscf rather
than the 0.07 gr/dscf used in th
economic analyses. Therefore,
the incremental costs of control
are inaccurate.
Opacity is unsuitable as a
standard and should only be
used as a triggering device
for performance testing. Opacit
standards are unreliable for
use as an objective means of
evaluating emissions.
The largest economic impacts are incurred
when control of emissions from thirmal
dryers is required. Since thermal dryers
are used only in the larger, more sophis-
ticated operations, smaller plants will
typically not be subjected to this
economic impact. The economic impact on a .
small plant will be attributable to thf
necessity for controlling fugitive
emissions.
TheO.07 gr/dscf used in the economic
analyses is not intended to directly
represent the standard for any single state.
Although the background document did
reference the West Virginia standard, the i
0.07 ar/dscf emission level selected re-
presents a weighted averege of the standard;
for the major coal producing states where
the emission standards may be higher or
lower (e.g. 0,02 gr/dscf in Pennsylvania).
The use of opacity standards has previously
been considered in the EPA response to the
remand ordered fay the U.S. Court of Appeals
for the District of Columbia Circuit in
Portland Cement Associationy Ruckelshaus,
486F.2d 375 (D. CV Cir. 1973).Copies
of the remand may be obtained by writing to
Emission Standards and Engineering Division,
Environmental Protection Agency, Research
Triangle Park, North Carolina 27711, Attn:
Mr- Don R. Goodwin. On November 12, 1974,
EPA revised its reference method for deter-
mining opacity (Method 9 in Appendix A of
40 CFR Part 60) in several respects (39
FR 398 72). Among other things, the re-
vision made clear that the accuracy of the
method must be taken
-------
Comment
Number
Commentator
Number
Category
Comment
Response
IA-3
IS}
Y-l
In the absence of continuous
monitors, violations of the
participate standard cannot be
proved without performance tests
therefore the particulate stan-
dard should apply only during
performance testing.
Scrubber manufacturers will not
guarantee meeting a 0.03 gr/dscf
(0.07 g/dscm) particulate stan-
dard for Sewell Seam and other
into account for purposes of enforcement.
On May Z2, 1975 the U.S. Court of Appeals
for the District of Columbia Circuit
affirmed EPA's position with respect to
opacity and held that plume opacity may be
used "either as a measure of pollution or
as an aid in controlling emissions1,1.
Portland Cement Association v Trairu_
SI3 F.2d $06,508-0d (D.C. Cir. 1975).
Section 60.1 Ha) of the general provisions
(applicable to all subparts of 40 CFR
Part 60) provides that compliance with
mass or concentration standards specified
in Part 60 shall be determined only by
performance tests. In practical effect,
this means that the particulate standards
for coal preparation plants apply only
during initial and subsequent performance
testing, Section 60.11(e), however,re-
quires proper maintenance and operation
of affected facilities and associated
control equipment at all times, and
continuous monitoring requirements^and
opacity standards have been included in
Subpart Y as a means of assuring proper
maintenance and operation. It should be
noted that the proper maintenance and
operation requirement and the opacity
standards are independently enforceable,
and that ,,the.v, apply at all times except
as orovided in §60,11(c).
As discussed in Section II of this
supplement to the background document, EPA
conducted emission tests at a plant pro-
cessing Sewell Seam coal as a result of
-------
Comment
Number
Commentator
Number
Category
Cooent
Response
Y-l
rv
tn
10
Y-l
11
Y-l, Y-9, Y-14
D,D,G
similar coals. One manufacturer
contacted will not in one case
guarantee below 0.04 gr/dscf
(0.09 g/dscm).
Power companies do not have the
capability of supplying the larg
power requirements needed to
achieve the 0.03 gr/dscf stan-
dard in areas where the coal '
fields are located.
Some companies may not be able
to procure capital investment
for new facilities badly needed
to meet current energy needs
due to the uncertainty of
achieving a 0.03 gr/scf
standard.
The marginal improvement in
emission controls of a 0.03 gr/
scf standard versus a 0.05 gr/
scf standard is not justified
due to the increased costs,
energy consumption, and re-
this commentator's assertions. In view of
the data obtained in these tests, the
scrubber manufacturer in question has
indicate'., it will guarantee 0.07 g/dscm
(0.03 gr/dscf} for Sewell and other
similar coals (Reference #3).
Public utility companies are typically
! obligated by law to provide adequate ser-
vice in return for a franchise to operate
a monopoly in assigned service areas.
This obligation extends to new as well as
existing customers. There may be some
practical reasons (e.g. financing, time
needed for new construction, etc.) why
service cannot be extended immediately
upon request, but these factors must be
weighed by the owner or operator of a coal
preparation plant along with the multitude
of other considerations in planning the
location and design of a new facility.
The scrubber manufacturer's guarantee
and technical support should provide the
assurance needed to attract capital in-
vestment .
As discussed in Section IV of this supple-
ment to the background document, EPA's
analysis indicates that the economic impact
of an 0.03 gr/dscf (0.07 g/dscm) standard
would be only 5 cents per ton of coal in
excess of the average control required by
-------
Comment
Number
Commentator
Number
Ca I'egory
Comment
Response
12
Y-l, Y-9
ro
en
D,D
suiting pollutants generated by
the power company.
The technical data used to
justify the 0.03 gr/scf standard
is in error. Pocahontas Seam
coal is not the ("ost difficult
to control. There is no consis-
tent connection between friabil-
ity and control difficulty.
Sewcll Seam and other coals not
tested by EPA are much more
difficult to control. The
error of this premise regarding
Pocahontas coal has been
verified by vendors of thermal
dryers and venturi scrubber
equipment. Pocahontas cos! was
found to be among the easiest
coals to control.
EPA has no iata to show that
the 0.03 gr/cscf standard is
achievable when coal bther than
Pocahontas Seam coal is dried.
state standards, even if a 50 inch pressure
drop were necessary to meet the standard.
This is less than the cost savings attri-
butable l:o coal drying and is almost
inconsequential when compared to the sale
price of coal (10 to 20 dollars per ton).
Although the energy requirement will
increase by about"24 percent, the net re-
duction in emissions to the atmosphere
will be about 23 percent even with
consideration given to the increase in
emissions at a new coal-fired power plant
(Reference #3).
As discussed in Volume 1 of the background
document, Pocahontas coal has historically
been considered to present the most diffi-
cult situation with respect to emission
controls. Recent test data developed by
EPA by tests at the commentator's facility
have demonstrated that Sewell coal is
equally, but no more, difficult to control
than Pocahontas, (See Section II of this
supplement to the background document).
By no means is Pocahontas coal considered
among the easiest to control. No data
have been developed to date that would
indicate that there are more difficult
control problems than are posed by
Pocahontas or Sew°ll coals.
As discussed in Sections II and IV of this
supplement to the background document, EPA's
test data (including that obtained at the
commentator's plant) indicate that, thp 0.03
gr/dscf standard is achievable at reasona- I
ble cost with Sewell Seam or Pocahontas |
coaIs. ;
-------
Comment
Number
Commentator
Number
Category
Comment
Response
Y-1
14
Y-1
Y-1, Y-9
0, D
No sieve analysis results of the
feed to thermal dryers tested
by EPA are available. Conse-
quently, there are no data to
show the achievability of an
0.03 gr/scf limit for coal feeds
with high fines content.
We have installed and operated
a venturi scrubber of the type
identified by EPA's tests as
examples of best control tech-
nology at a location where
Sewell Seam coal is mined and
thermally dried. Test results
have averaged 0.04 gr/scf, above
the 0.03 gr/scf limit proposed
by EPA.
Without relief from the 0.03
gr/scf limit proposed, coal
companies will not be able to
recover the finar sizes of coal
due to the inability to thermal!
dry. Discarding this coal (as
The EPA test measurements were conducted
in a manner that would detect significant
differences in emissions due to high fines
content in the dryer feed. Tests at dryers
D, and at the commentator's facility
were conducted with maximum input of fines
to the dryer. Tests at dryer C were con-
ducted with only partial input of fines.
The emission standard is principally based
upon the former tests and other recently
developed data (see Section II of this
supplement to the background document)
rather than the lower results obtained at
dryer C. The standard therefore reflects
any effect upon control equipment
efficiency due to high fines content in the
dryer feed. I
For the 29 inch scrubber pressure drop
used at this facility, these results
(0.04 gr/dscf) are consistent with EPA
data which show that the standard will be
achieved by operating the scrubber in the
40 to 45 inch water gage pressure drop
range. See Section II of this supplement
to the background document.
EPA's tests included facilities where all
fines produced are dried. EPA projects
that facilities drying certain difficult
to control coals can achieve the 0.031 gr/
dscf limit by using venturi scrubber con-
-------
Comment
Number
Commentator
Number
Category
Comment
Response
16
00 17
Y-l, Y-10, Y-12, Y-15
Y-2
D.F.F.D
much as 15 tons per hour in a
typical plant) is an unjustified
waste of national resources.
No data are available to evalu-
ate the degree of control
achievable with western coals.
Extension of the termal dryer
standard to these coals is with-
out foundation.
The use of diluent gases to
achieve the emission standards
should not be permitted.
Revision of §60,12 is needed to
be consistent witn the exclu-
sion of this requirement pro-
vided in the subpart. The
purpose of this exclusion needs
explanation.
trol equipment that is operated at a
pressure loss of 40-45 inches water gage,
(See Section II of this supplement to the
background document). Lower pressure
losses will give satisfactory results with
many other type coals. In either case,
thermal drying and recovery of fines will
not be precluded.
Because the drying characteristics and the
emission control levels achievable with
subbitunrinous and lignite coals typically
found in the west are not currently known,
the thermal dryer standard has been revised
to apply only to drying of bituminous *uels
Section 60.254 (c) as proposed was based on
the need for thermal dryers to add diluent
gases for temperature control. The
possibility that addition of diluent gases
will be used to evade the standard is un-
likely in view of the high operating and
capital cost that would be incurred in
doing so. However, this paragraph has
been deleted from the regulations because
it is redundant. Section 60.12 prohibits
use of dilution air only when its purpose
is to defeat emission standards. Dilution
air for legitimate process needs is not
prohibited.
-------
Comment
Number
Commentator
Number
Category
Cor.ii-cnt
Response
Y-2, Y-l
19
Y-3
20
21
Y-22
Y-4
22
Y-4
E,D
C
A
Coal preparation plants are not
a significant water pollution
hazard. New plants use closed
circuit systems.
Plants with capacities of 1000
tons/day or smaller should be
exempted from the regulations.
Proposed standards appear to be
attainable.
More explanation is needed with
regard to procedures acceptable
for satisfying the requirements
of §60.254(d) when baghouses are
used.
The revisions to Method 9 were
not proposed, therefore, pro-
viding no opportunity for input
from State agencies.
New coal preparation plants are expected
to use closed fluid systems and thereby
present no significant water hazard.
This is true, however, only if plant is
well designed to handle waste water and
overflows.
The intent of the proposed standards was
to control coal preparation of significance
with respect to emissions. Therefore,
EPA has exempted coal preparation plants
processing 200 tons/day or less coal from
compliance with these standards.
The standards have been fully evaluated
by EPA and are attainable. ;
Baghouses must have a ducting arrangement
in order that Reference Method 5 may be
applied.
Certain revisions to Method 9 were pro-
posed on September 11, 1974 (39 FR 32852).
After consideration of comments, these
revisions were promulgated on Novsin'-er 12,
1974 (39 FR 39872), together wit'i certain
other revisions determined to be appro-
priate on the basis of EPA's response to
the remand in Portland Cement Association
y: Ruckelsnaus^ 486F.2d 375 (D.C. Cir.
1973)" Conuients were invited on the
-------
Comment
Number
Commentator
Number
Category
Comment
Response
23
Y-5, Y-1'0, Y-5a
24
OJ
o
25
Y-5, Y-10
Y-5, Y-7, Y-8, Y-5a,
Y-23
Y-5, Y-10
27
Y-6
G. F,
G
G, F
G, D,
G, G,
F
G, F
The definition for "surface
moisture" is inconsistent with
tfiat recognized by the industry
or ASTM. The definition should
be revised in terms of an air
drying procedure for determina-
tions.
Product moisture content does
not relate to dryer emissions
in any consistent manner.
Product Moisture content is
usually sampled after recombin-
ing with other product from the
preparation plant. Sampling of
product directly from the dry<=r
is not a usual practice.
Exhaust temperature of the
flue gases is the best source
of information regarding the
performance of the dryer.
An allowance for water vapor
is necessary in the procedures
latter revisions on April 22, 1975
(40 FR 17778), and after consideration of
the comments received EPA concluded that
no further revision of Method 9 was
appropriate (40 FR 41834, September 9,
1975).
Since determining surface moisture, using
air drying or other techniques, is
cumbersome and does not seem justified
with regard to the monitoring benefit in
addition to application of the opacity
standard, this provision has been deleted
from the regulations.
See response to comment 23.
See response to comment 23.
Flue gas exhaust temperature is a good
indication of normal operating conditions
The temperature usually does not fluctuat
except during start-up, shutdown, and
malfunction conditions.
EPA believes a cross reference is un-
necessary since the general provisions
-------
Comment
Number
Commentator
Number
Category
Comment
Response
28
Y-7
Y-8, Y-23
30
Y-8
31
Y-8, Y-16, Y-19, Y-23
G, F
6, H,
H, F
for determining opacity of
emissions. Section 60.11(b)
should be referenced by
Section 60.252.
specified in Subpart A apply to all other
subparts of Part 60.
Monitoring of a source's oper- Monitoring is needed to assure proper
actions is not needed since they(maintenance and operation of the facility
and associated control equipment after
the initial performance tests. Without
some means of monitoring, degradation in
emission control performance between
performance tests could easi y qo unde-
tected.
Q V* W ( W* I t* I ^ > I V »* t I*. !«»*- W w r w
are required to comply with
applicable standards.
Sampling of coal from open
storage piles will not produce
accurate moisture analyses.
The moisture of coal at the
surface of the pile will be
different than the coal moisture
at the interior of the pile.
We interpret Method 9 to
apply only to stack emissions.
Application of opacity to
fugitive emissions is subjec-
tive and impractical.
Fugitive emissions from coal
open storage piles are dependem
Control of open storage piles is not
required by these regulations. See
response to comment 31.
Method 9 applies to fugitive emissions as
well as stack emissions. The applica-
bility of Method 9 to fugitive emissions
is discussed further in the "Reevaluation
of Standards of Performance for Asphalt
Concrete Plants", published on April 22,
1975 (40 FR 17778). See also responses
to comnents 6 and 47.
Section 60.251 (h.) has been revised to make
clear that open storage piles are not
-------
Comment
Number
Commentator
Number
Category
Comment
Response
32
Y-11, Y-18
CO
33
34
35
Y-ll
Y-11
Y-12, Y-14, Y-15
0,0
F, G,
D
upon so many variables; the
effects of which are not re-
flected in the 20 percent opaci-
ty limitation proposed. Other
than water sorays, control
methods are not available to
prevent dusting on windy days.
Opacity standards should not be
applied to controlling emissions
from open storage piles. We
suggest equipment standards to
require sprays and enclosures
for fugitive emission control.
These standards should be
confined to operations within
a coal preparation plant and
not extended to similar facili-
ties at other locations.
Hi-Vol samplers and meteorolo-
gical stations should be used
in lieu of monitoring require-
ments.
Daily sampling of dryer product
is too frequent.
Applying opacity standards to
sources where emissions contain
large volumes of water is
unrealistic and unenforceable.
considered "coal storage systems" for
purposes of these regulations and are
therefore not subject to the fugitive
emission standard. It may be necefary
to control fugitive emissions'from ^pen
storage piles to meet State standards,
however.
The intent of the coal preparation plant
regulations is not only to control emissions
from coal preparation plants but also to
control any coal processing and conveying
equipment, coal storage system, or roal
transfer and loading system which dis-
charges particulate emissions into the
atmosphere, regardless of its location.
Hi-Vol samplers and meteorological stations
measure ambient air quality and, therefore,
are inadequate for the monitoring of control
practices at particular sources.
This requirement has been deleted from
these regulations.
Through observations it has been determined
that steam plumes can be distinguished from
particle emissions. Special attention is
given to steam plumes, attached and ;
-------
Comment
Number
Commentator
Number
Category
Comment
Response
Y-12, Y-15
37
Y-12, Y-14, Y-15
OJ
38
Y-13
39
Y-14, Y-18
F, D
F, G,
0
G, D
Opacity standards should not be
applied to coal handling equip-
ment because such emissions are
beyond the control capabilities
of the owner or operator.
Section 60.253 regarding
monitoring requirements is poor-
ly conceived. Other variables
not considered are important.
The 0.03 gr/dscf standard is
achievable. The 30 percent
opacity limit for dryers seems
too high and inconsistent with
the proposed particulate
standard.
The regulations should provide
exemptions for periods of
startups, shutdowns, and
malfunctions.
detached, in Method 9 as revised on
November 12, 1974 (39 FR 39872), to Insure
valid results for opacity readings.
As discussed in Volume 1 of the background
document, many types of particulate
emission control are available to the
owner or operator, thus no problem should
be encountered in complying with opacity
standards.
In addition to continuous monitoring of
pressure loss across the scrubber and
dryer gas stream temperature at the exit,
section 60.253 has been revised to include
the continuous monitoring of water flow
into the scrubber.
As discussed in Section III of this
supplement to the background document, the
opacity standard for thermal dryers has
been revised to take into account recent
amendments to Method 9. EPA believes the
revised standard (20%) is appropriate in
terms of the observed data base and the
purpose of the standard.
Sections 60.8(e) and 60.11(c) of the general
provisions applicable to all subparts of
40 CFR Part 60, as amended on October 15,
1973 (38 FR 28564), in effect provide
-------
Number
Commentator
Number
Category
Comment
Response
40
^
f*
41
Y-14
Y-16, Y-17, Y-18
G
H, H
D
-
The t
flow
fcrmc
rt 1 1 1 Y*l
qui rt
strai
gas <
be 31
flow
incl
for
meth
The
lati
Powe
sere
Jryi
dryi
to t
ther
prop
The requirement that cyclonic
flow be eliminated during per-
formance testing should be re-
quired unless it can be demon-
strated that the particles in th<
gas stream are large enough to
be stratified due to cyclonic
flow. Provisions should be
included within the regulations
for approval of alternate test
The applicability of the regu-
lation needs clarification.
Power plants have coal handling.
screening, crushing and thermal
Drying operations. The thermal
drying operation has no emission
to the atmosphere and should
therefore be excluded from the
proposed standards.
exemptions whe»*e emissions unavoidably
exceed applicable standards during periods
of start-up, shutdown, or malfunction.
It should be noted, however, that §60.11(d^
requires proper maintenance and operation
of affected facilities and associated con-
trol equipment during such periods.
Although only small particles are not
removed by a venturi scrubber, EPA tests
have shown that the particles in typical
stack effluent gases a 3 relatively large;
probably due to agglomeration in the
saturated effluent environment. If other
types of control equipment are used that
do not produce these unfavorable test
conditions, application for approval of
alternative methods can be made. See
40 CFR 60.8 (b), as revised on March 8,
1974 (39 FR 9314).
When the standard was proposed it was
thought that no thermal dryers existed
other than "mine-mouth". Through several
comments it is now known that thermal
dryers do exist other than at mines and
that many are closed systems. Although
the standards do apply to all facilities
regardless of location, they are not
applicable to systems that are entirely
closed so that there is r,o direct emission
to the atmosphere.
-------
Comment
Number
42
Commentator
Number
Category
Comment
Response
Y-16
43
Y-17
to
44
Y-17
45
Y-18
46
Y-18
State standards for control of
fugitive emissions from open
storage piles contain provisions
that exempt the source during
periods of adverse weather con-
ditions. Similar provisions are
needed for these regulations.
The monitoring requirements
appear to be excessively costly
in view of their minimal faene -
fit.
Continuous monitors are too
expensive and are not adaptable
to monitoring of fugitive
emissions from coal handling
equipment.
Reference Method 9 should be
cited as the procedure for
determining opacity of emis-
sions.
An exemption of three minutes
TP) hour should be added to
See response to comment 31
Under section 60,253 continuous monitoring
svstems are required only on thermal dryers.
EPA believes the monitoring requirements
are necessary in view of the potential for
large amounts of particulate emissions
should the dryer and the air pollution
coiitrol equipment not be properly operated.
As discussed in the preamble to the final
regulations, the cost of the monitoring
instruments is minor when compared to the
total costs of thermal dryers.
Continuous monitoring of fugitive emissions
from coal handling equipment is not
required.
Section 60.11{b) of the general provisions
applicable to all subparts of 40 CFR
Part 60 specifies Method 9 as the procedure
for determining opacity of visible
emissions.
In view of the revision of visible emission
observation procedures on November 12, 1974
-------
Comment
Number
Commentator
Number
Category
Comment
Response
47
48
49
Y-18
Y-21
Y-21
opacity standards.
The opacity standards should not
apply when the opacity is due to
other sources.
Baghouse controls used on small
6 ton/hour thermal dryers can
achieve compliance with a 0.02
gr/dscf standard.
Under some conditions, emissions
as low as 0.005 gr/dscf are
achievable using venturi
scrubber controls.
(see 39 FR 39872), and the provisions for
start-ups, shutdowns and malfunctions
promulgated on October 15, 1973 (see
38 FR 28B64), an exemption of three
minutes per hour for opacity standards is
unnecessary.
According to Method 9 the observer's line
of sight should not include more than one
plume (or source) at a time. This applies
not only to sources fr->n» other processes
besides coal preparation, but to sources
from other parts of the coal preparation
process.
Emission controls used on small pilot
scale and sand dryers have not been
demonstrated to be applicable to commer-
cial size coal dryers. Although 0.02
gr/dscf is achievable at 35-40 inches water
gage pressure drop for several coals, it is
not universally achievable for all coals,
especially Pocahontas and Sewell types.
Considering all technical and economic
factors, 0.03 gr/dscf is achievable at
reasonable costs with commercially sized
drying equipment. Although lower emission
levels can always be achieved by exagger-
ated application of control techniques, the
extreme conditions needed are not practical
for commercial operations.
-------
Appendix A
37
-------
Visible Emissions: Six minute opacity averages
Plant: Coal Dumping and Ship loading Operations
Plant Address: Lambert's Point (Norfolk)» Virginia
Date; March 26, 1975
Time: 8:30 a.m. - 11:30 a.m.: Dumping Operations
1:00 p.m. - 4:30 p.m.: Ship Loading Operations
%
Observers: John Brown and John Davis
Type of Discharge: Fugitive Emissions
Type of Control: Water Sprays
Background; Bl le Sky
Dumping Operations;
J. Davis - north dumper
J. Brovw - south dumper
38
-------
Coal Dumping
March 26, 1975
Period Brown Davis
(six irinuU averages) (percent opacity) (percent opacity) Conments
0.2
0.0
*
4.2
2.5
1.7
1 -
2
3
4
5
6
7
8
9,
10
11
12
13
14
15
16
17
18
19
20
21
22
23
0
0
0
2.3
6.7
5.4
1.0
1.9
0.6
1.7
2.1
1.0
2.9
0.8
0.6
1.5
0.0
0.8
4.6
0.2
1.5
2.5
0.6
3.1
process problems,
north dumper shut dr.
-------
Coal Dumping
March 26, 1975
Period Brown Davis
(six minute averages) (percent^ opacity) (percent opacity) Comnents
24
25
26
27
28
29
30
0.4
2.1
0.4
2.5
1.9
1.0
1.9
-------
Ship Loading
March 26, 1975
Period Brovm Davis
(six minute averages) (percent opacity) (fercent opacity)
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.2
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
uo
0.0
0.0
0.0
0.0
0.4
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
ao
ao
2.7
41
-------
Ship Loading
March 26. 1975
Period Brown Davis
(six minute averages) (percent opacity) (percent opacity)
24 - -
25 0.0 0,0
26 3'5
27 1'9
28 °'6
29 0.0
30 °-°
42
-------
St^cU -nth V-iln'.c^d lid
Hi";'.: Cr-?l !Jr--\->'.<.v-l-.on (air t, jle-3)
Co.TpaiV.'t Florence IMning Company
Plert ,-:-d-c-s>: Se.:r»-a, Pennsylvania
Date: Jciurry 31, 1975
Ti-s: 10:-'.1 a.P. 1" Il:f5 a.rr,.
Pb;-£-;;:: Jclnt Y/,:.T- cr.ri <}. C. I'.cCcrd
j,.,,., ^f -!.-.,_ r _. c:«--.£« -.,>=. "
Yyce or Co.urol: C^cic..;
Stack Difr.ster: 3,9 feet
L'£r''rrc,r'.*d; ; cCcrJ - C"*"^y sil---- ".-Si I '-"it;! *-0 f'Src.:
Yfit^s black 5?.2.c iv,; vntii n,J p.-rc
ant clcud cov:
cloud cov;
43
-------
1
2
3
4
r
7
a
0
1 «J
1
2
3
4
r
5
6
7
3
9
i:-
0.0
o.o
0.0
0.0
0.0
0.0
0.0
o.c
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
o.c
B.S
5.0 1 ntinuitj
shutdo.;,;,
relay s.-itch
check
4.0
5.2
6.0
2.2
0.8
0.2
0.2
0.6
0.0
0.3
1.0
0.0
0.0
0.3
0.0
0.0
0.0
0.3 3 r;i!iyV
c'l'_ ,,f
-------
Visible Emissions: Six Minute Opacity Average
Type of Plant: Coal Preparation
Plant Address: Vansant, Virginia
Date: 2/5/74 and 2/7/74
Observers: Sedman and Meyer
Type of Discharge: Stack and 3aghoc?se
Type of Control: Scrubber Dryer, Baghouse, Rotoclone
Background:
Dryer Scrubber
9:37 - sky, blue with 0 percent cloud cover
11:00 - sky, blue with 60 percent cloud cover
11:10 - sky, blue with 20 percent cloud cover
11:30 - sky, blue with 30 percent cloud cover
12:09 - sky, blue with 0 percent cloud cover
1:10 - sky, blue with 40 percent cloud cover
1:35 - sky, blue vvith 60 percent cloud cover
2:54 - sky, blue with 0 percent cloud cover
Coal Transfer Baghouse
12:10 - hillside, brown with 40 percent cloud cover
12:48 - hillside, brown with 0 percent cloud cover
1:10 - nillside, bro,;n v:itii 4C ^ririt coud cover
45
-------
Loadout Rotoclone Stack
12:10 - hillside with 40 percent to 60 percent cloud cover
12:43 - hillside with 0 percent cloud cover
1:14 - hillside with 40 percent to 60 percent cloud cover
Rotary Breaker Baghouse
side of building, gray metal with 100 percent cloud cover
46
-------
Dryer Scrubber
Stack Diameter - 7 ft,
2/5/74
Period Sed,!.an Meyer
(6 min. average) (percent opacity) (percent opacity) Comments
I
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
2.5
0.8
0.0
2.1
4,6
5.4
3.8
0.4
1,3
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0,0
0.0
0.0
0.0
0.0
2.5
1.2
0.8
1,2
3,3
3.5
2.9
0,5
1.3
0.4
0.0
0,0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
47
-------
Dryer Scrubber
Stack Diameter - 7 ft.
2/5/74
Period Sedman Meyer
(6 min. average) (percent opacity) (percent opacity) Comments
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
2.1
0.4
10.0
-
20.9
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
C.O
0.0
0.0
0.0
0.0
0.0
0.0
2.5 production ci
0.4
10.0 shutdov.n - 4
break - 2 ho
21.9 start--,:; - ~
-------
Coal Transfer Baghouse
Stack Diameter -2.5 ft.
2/5/74
(6 rr.in. average)
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
(percent opacity)
0.0
3.6
0.0
0.0
4.6
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
, mytrj
(percent o
0.0
0.0
0.0
0.0
4.4
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
49
-------
Load Out Rotoclone Stack
Stack Diameter - 2.5 ft.
2/5/74
Period Sedman Meyer
(6 min. average) (percent opacity) (percent opacity) Comments
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
-------
(6 min. average)
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
(percent opacity)
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
Rotary Breaker Baghouse
Duct Diameter - 1.8 ft.
2/7/74
Meyer
(percent opacity) Comments
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
-------
Visible Emissions: Six Minute Opacity Average
Type of Plant: Coal Preparation
Company flame: Island Creek
Plant Address: Jewell Valley, Virginia
Date: 2/6/74
Observers: Sedman and Meyer
Type of Discharge: Stack
Type of Control: Scrubber Dryer, Baghouse, Rotoclone Stack
Background: Scrubber Dryer - Sky, gray with 100 percent cloud cover
Coal Transfer Baghouse - Hillside, brown with 100"percent
cloud cover
Coal Transfer Rotoclone Stack - Sky, uray v/i th 100 percent
cloud cover
52
-------
Period
. average)
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
(percent opacity)
35.00
35.00
35.00
0.2
8.3
0.0
0.0
0.0
4.6
0.0
0.0
0.0
17,1
6.4
27.7
0.0
0.0
0.0
8.4
1 IC^UI
(percent opacity)
35.00 -
35.00
35.00 '
0.4
6.9
0.4
0.0
1.7
4.6
0,0
0,0
0.0
15.8
6.4
27.0
0.0
0.0
0.0
9.2
Scrubber Dryer
Stack Diameter - 7 ft.
2/6/74
Comments
- start-up - 18 min.
upset - 6 min.
upset - 3 min.
shutdown - 2 min,*
start-up - 8 min.
shutdown - 4 min.
* 15 minute break between shutdown and start-up
53
-------
Coal Transfer Baghouse
Stack Diameter
2/6/74
F-oriod
Meyer
. average)
1
2
3
4
5
6
7
8
9
10
11
12
13
(percent opacity)
0.0
0.0
0,0
0.0
0.0
20.0
19.4
11.5
0.0
1Z.3
0.0
0.0
1.3
{percent 01
0.0
0.0
0.0
0,0
0.0
19.8
20.8
12.1
0.0
12.3
0.0
0.0
1.9
start-up - 6 min.*
shutdown - 2 min.
* 20 minute shutdown and break before start-up
54
-------
Coal Transfer Rotodone Stack
Stack Diameter - 2.5 ft.
2/6/74
Period
"eyer
. average)
1
2
3
4
5
6
7
8
9
10
11
12
13
14
(percent cp^ci ty)
0.0
0.0
0.0
0.0
0.0
18.1
37.9
4.8
0.0
13.3
0.0
0.0
12.5
(percent of
0.0
0.0
0.0
0.0
0.0
15.8
19.H
8.5
0.0
15.2
0.0
0.0
18.3
start-up - 6 min.*
shutdown - 2 min.
* 15 minute siiUtcL.
55
-------
Appendix 8
56
-------
Facilities
J. Fl u i d-bedthermaldryer. The plant operation is approximately
200 tons per hour of cleaned coal. All of the filter cake is fed to
the dryer. A venturi-type scrubber is used to control participate
emission (AP of 43 inches w.g.). The coal processed is lower kittanning.
K. Fluld-bed thermal dryer. The dryer was designed to process 340
tons per hour of 1/4-inch x 0 cleaned bituminous coal (wet has"''-} and
to discharge it at a rate of 312 tons per hour dried to a surface
moisture of 4 percent (wet basis). The plant operation averages 400
tons per hour. All of the filter cake was fed to the dryer. The dryer
is controlled by a multiclone bank followed by a flooded disk venturi
scrubber (&P of 32 inches w.g.).
57
-------
TECHNICAL REPORT DATA
(fleait read Iiainiclions on the reverie before completing)
l. REPORT NO.
EPA-450/2-74-021-C
3_ RECIPIENT'S ACCESS1OWNO.
». TITLE AND SUBTITLE
Background Information for Standards of Performance:
Coal Preparation Plants
Volume 3: Supplemental Information
6. PERFORMING ORGANIZATION CODE
7. AUTHOH(S)
s. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
U.S. Environmental Protection Agency
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
IS. SUPPLEMENTARY NOTES
16. ABSTRACT
This report is issued in connection with final promulgation of regulations for
standards of performance fcr new and modified coal preparation plants. This
document supplements information presented in too earlier background documents
(EPA-450/2-74-021 a and b). This report contains a revaluation of the standard
for thermal dryers, a summary of undated control costs, a discussion of the in-
flationary effects of these control costs, ajid a projection of the annual power
consumption increases required by the standards. It also contains a discussion
of changes in the opacity standards for coal preparation plants.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
Standards of performance
Coal preparation plants
; Control costs
b.IDENTlFIERS/OPE.J ENDED TEHMS c. COSATI I;ldd/C>i lup
PRICES SUUECT TO CHANGE
18 DISTRIBUTION STATEMENT
Unlimited
19 SECURITY CLASS (Tills Kcporli
Unclassified
Of PAfiiS
2O_ SECURITY CLASS I'tlu'lpage>
Unclassified
77, PRICE
f-
-------