Emission Factor Documentation for AP-42
Section 9.10.1.2
SUGARBEET PROCESSING
Final Report
For U. S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Emission Factor and Inventory Group
EPA Contract 68-D2-0159
Work Assignment No. 2-03 and 4-04
MRI Project No. 4602-03 and 4604-04
March 1997

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Emission Factor Documentation for AP-42
Section 9.10.1.2
SUGARBEET PROCESSING
Final Report
For U. S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Emission Factor and Inventory Group
Research Triangle Park, NC 27711
Attn: Mr. Dallas Safriet (MD-14)
Emission Factor and Inventory Group
EPA Contract 68-D2-0159
Work Assignment No. 2-03 and 4-04
MRI Project No. 4602-03 and 4604-04
March 1997

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NOTICE
The information in this document has been funded wholly or in part by the United States
Environmental Protection Agency under Contract No. 68-D2-0159 to Midwest Research Institute. It has
been reviewed by the Office of Air Quality Planning and Standards, U. S. Environmental Protection
Agency, and has been approved for publication. Mention of trade names or commercial products does
not constitute endorsement or recommendation for use.
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PREFACE
This report was prepared by Midwest Research Institute (MRI) for the Office of Air Quality
Planning and Standards (OAQPS), U. S. Environmental Protection Agency (EPA), under Contract
No. 68-D2-0159, Work Assignment No. 2-03 and 4-04. Mr. Dallas Safriet was the EPA work
assignment manager.
Approved for:
MIDWEST RESEARCH INSTITUTE
Roy Neulicht
Program Manager
Environmental Engineering Department
Jeff Shular
Director, Environmental Engineering
Department
March 1997
in

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TABLE OF CONTENTS
Page
1.	INTRODUCTION		1-1
2.	INDUSTRY DESCRIPTION		2-1
2.1	INDUSTRY CHARACTERIZATION		2-1
2.2	PROCESS DESCRIPTION 		2-1
2.3	EMISSIONS		2-5
2.4	EMISSION CONTROL TECHNOLOGY 		2-6
3.	GENERAL DATA REVIEW AND ANALYSIS PROCEDURES		3-1
3 .1 LITERATURE SEARCH AND SCREENING 		3-1
3.2 DATA QUALITY RATING SYSTEM 		3-2
3 .3 EMISSION FACTOR QUALITY RATING SYSTEM		3-3
4.	AP-42 SECTION DEVELOPMENT		4-1
4.1	INTRODUCTION 		4-1
4.2	REVIEW OF SPECIFIC DATA SETS 		4-1
4.2.1	Reference 1 		4-1
4.2.2	Reference 2 		4-1
4.2.3	Reference 3 		4-2
4.2.4	Reference 4 		4-2
4.2.5	Reference 5 		4-2
4.2.6	Reference 6 		4-3
4.2.7	Reference 7 		4-4
4.2.8	Reference 8 		4-4
4.2.9	Reference 9 		4-4
4.2.10	Reference 10 		4-4
4.2.11	Reference 11 		4-5
4.2.12	Reference 12 		4-5
4.2.13	Reference 13 		4-5
4.2.14	Reference 14 		4-6
4.2.15	Reference 15 		4-6
4.2.16	Reference 16 		4-7
4.2.17	Reference 17 		4-7
4.2.18	Reference 19 		4-7
4.2.19	Reference 20 		4-8
4.2.20	Reference 21 		4-8
4.2.21	Reference 22 		4-8
4.2.22	Reference 23 		4-9
4.2.23	Reference 24 		4-9
4.2.24	Reference 25 		4-9
4.2.25	Reference 26 		4-9
4.2.26	Review of FIRE, XATEF, and SPECIATE Data Base Emission Factors . . .	4-10
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TABLE OF CONTENTS (continued)
Page
4.3	DEVELOPMENT OF CANDIDATE EMISSION FACTORS 		4-10
4.3.1	Filterable PM		4-10
4.3.2	Filterable PM-10 		4-26
4.3.3	Condensible PM		4-26
4.3.4	Volatile Organic Compounds 		4-27
4.3.5	Methane		4-27
4.3.6	Carbon Monoxide 		4-27
4.3.7	Carbon Dioxide 		4-28
4.3.8	Nitrogen Oxides		4-28
4.3.9	Sulfur Dioxide		4-29
4.3.10	Acetaldehyde, Acrolein, Crotonaldehyde, Formaldehyde		4-29
4.3.11	Semivolatile Organic Compounds		4-29
4.4	SUMMARY OF DEVELOPMENT OF AP-42 SECTION 		4-30
4.4.1	Section Narrative		4-30
4.4.2	Emission Factors 		4-30
5. PROPOSED AP-42 SECTION 		5-1
APPENDICES
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LIST OF FIGURES
Figure	Page
2-1 Preprocessing and livestock feed production operations at a sugarbeet processing plant	2-2
2-2 Sugar production operations at a sugarbeet processing plant		2-3
LIST OF TABLES
Table	Page
2-1 SUGARBEET PROCESSING PLANTS BY STATE, 1996 		2-1
4-1 REFERENCE 5; TESTS CONDUCTED AND DATA RATINGS		4-3
4-2 SUMMARY OF EMISSION DATA FOR SUGARBEET PROCESSING		4-11
4-3 SUMMARY OF EMISSION FACTORS FOR SUGARBEET PROCESSING		4-20
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EMISSION FACTOR DOCUMENTATION FOR AP-42 SECTION 9.10.1.2
SUGARBEET PROCESSING
1. INTRODUCTION
The document Compilation of Air Pollutant Emission Factors (AP-42) has been published by the
U. S. Environmental Protection Agency (EPA) since 1972. Supplements to AP-42 have been routinely
published to add new emission source categories and to update existing emission factors. AP-42 is
routinely updated by EPA to respond to new emission factor needs of EPA, State and local air pollution
control programs, and industry.
An emission factor is a representative value that attempts to relate the quantity of a pollutant
released to the atmosphere with an activity associated with the release of that pollutant. Emission factors
usually are expressed as the weight of pollutant divided by the unit weight, volume, distance, or duration
of the activity that emits the pollutant. The emission factors presented in AP-42 may be appropriate to
use in a number of situations, such as making source-specific emission estimates for areawide inventories
for dispersion modeling, developing control strategies, screening sources for compliance purposes,
establishing operating permit fees, and making permit applicability determinations. The purpose of this
report is to provide background information from test reports and other information to support
preparation of AP-42 Section 9.10.1.2, Sugarbeet Processing.
This background report consists of five sections. Section 1 includes the introduction to the
report. Section 2 gives a description of the sugarbeet processing industry. It includes a characterization
of the industry, a description of the different process operations, a characterization of emission sources
and pollutants emitted, and a description of the technology used to control emissions resulting from these
sources. Section 3 is a review of emission data collection (and emission measurement) procedures. It
describes the literature search, the screening of emission data reports, and the quality rating system for
both emission data and emission factors. Section 4 details how the new AP-42 section was developed. It
includes the review of specific data sets and a description of how candidate emission factors were
developed. Section 5 presents the AP-42 Section 9.10.1.2, Sugarbeet Processing. Supporting
documentation for emission factor development is presented in the Appendices.
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2. INDUSTRY DESCRIPTION12
Sugarbeet processing is the production of sugar (sucrose) from sugarbeets. Byproducts of
sugarbeet processing include pulp and molasses. Most of the molasses produced is processed further to
remove the remaining sucrose. The pulp and most of the remaining molasses are mixed together, dried,
and sold as livestock feed. The four-digit standard industrial classification (SIC) code for sugarbeet
processing is 2063. The six-digit source classification code (SCC) for sugarbeet processing is 3-02-016;
there are 16 eight-digit SCC's.
2.1 INDUSTRY CHARACTERIZATION3
In 1995, approximately 3,916,000 short tons of beet sugar were produced at 31 plants located in
12 States. Table 2-1 shows the number of sugarbeet processing plants by State. No new sugarbeet
processing facilities have been built since the mid-1970's. In comparison to 1974, 25 fewer facilities are
currently operating. However, the 31 facilities currently operating have been modified to produce more
sugar more efficiently than the 56 facilities operating in 1974.
TABLE 2-1. SUGARBEET PROCESSING PLANTS BY STATE, 1996
State
Number of plants
California
4
Colorado
2
Idaho
3
Michigan
5
Minnesota
4
Montana
2
Nebraska
2
New Mexico3

North Dakota
3
Ohio
1
Oregon
1
Texas
1
Wyoming
3
Washington3

3State-produced small quantities of sugarbeets, but no sugarbeet processing plants are located in
the State.
2.2 PROCESS DESCRIPTION1245
Figures 2-1 and 2-2 are flow diagrams for a typical sugarbeet processing plant. Figure 2-1 shows
the preprocessing operations and the livestock feed production operations, and Figure 2-2 shows the beet
sugar production operations. Mechanically harvested sugarbeets are shipped to processing plants, where
they are typically received by high-speed conveying and screening systems. The screening systems
remove loose dirt from the beets and pinch the beet tops and leaves to facilitate separation from the beet
roots. The conveyors transport the beets to storage areas and then to the final cleaning and trash removal
operations that precede the processing operations. The beets are usually conveyed to the final cleaning
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PM EMISSIONS
GASEOUS EMISSIONS
PROCESS FLOW
AIR FLOW
9
DISINFECTANT (OPTIONAL)
WATER
MOLASSES FROM
SUGAR PRODUCTION
OPERATIONS
BEET PULP
RAW JUICE TO SUGAR
PRODUCTION
OPERATIONS
STORAGE
SHIPPING
HARVESTING
PELLETIZING
(3-02-016-12)
CONVEYING
AND
SCREENING
PELLET COOLER
(3-02-016-16)
SLICERS
LIVESTOCK FEED
STORAGE AND
SHIPPING
DIFFUSER
PULP
PRESSES
FINAL CLEANING
AND
TRASH REMOVAL
PULP DRYER
(3-02-016-01,
3-02-016-05,
3-02-016-08)
Figure 2-1. Preprocessing and livestock feed production operations at a sugarbeet processing plant.
(Source Classification Code in parentheses.)

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IO PULP
DRYER
Q.
O
LIMEKILN
(3-05-016-XX)
RAW JUICE FROM
DIFFUSER
co2
LIME
FIRST
CARBONATION
TANK
(3-02 016-21)
C02 FROM
LIMEKILN
SECOND
CARBONATION
TANK
(3-02-016-22)
PM EMISSIONS
^2^ GASEOUS EMISSIONS
	PROCESS FLOW
	* AIR FLOW
90
NJ
POWDERED SUGAR
OR FINELY MILLED
SUGAR AND 	
ISOPROPYL ALCOHOL
CRYSTALLINE
SUGAR 	
VACUUM PANS
MASSECUITE
WASH WATER
DEEP MOLASSES
DESUGARIZATION
HIGH WELTER/
FILTERS
CENTRIFUGALS
WASHING WITH
HOT WATER
HOT
WATER
EVAPORATORS
(3-02-016-41)
BOILER
(1-02-XXX-XX)
SO2
SULFUR STOVE
(3-02-016-31)
-©
TO PROCESS
HEATERS, THEN TO
ATMOSPHERE
...«Q
op
GRANULATORS
(3-02-016-58)
9
STORAGBPACKING
(3-02-016-61)
9
SUGAR DRYER
(3-02-016-51)
9
SUGAR COOLER
(3-02-016-55)
Figure 2-2. Sugar production operations at a sugarbeet processing plant.
(Source Classification Code in parentheses.)

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phase using flumes, which use water to both move and clean the beets. Although most plants use flumes,
some plants use dry conveyors in the final cleaning stage. The disadvantage of flume conveying is that
some sugar leaches into the flume water from damaged surfaces of the beets. The flumes carry the beets
to the beet feeder, which regulates the flow of beets through the system and prevents stoppages in the
system. From the feeder, the flumes carry the beets through several cleaning devices, which may include
rock catchers, sand separators, magnetic metal separators, water spray nozzles, and trash catchers. After
cleaning, the beets are separated from the water, usually with a beet wheel, and are transported by drag
chain, chain and bucket elevator, inclined belt conveyor, or beet pump to the processing operations.
Sugarbeet processing operations comprise several steps, including diffusion, juice purification,
evaporation, crystallization, dried-pulp manufacture, and sugar recovery from molasses. Descriptions of
these operations are presented in the following paragraphs.
Prior to removal of the sucrose from the beet by diffusion, the cleaned and washed beets are
sliced into long, thin strips, called cossettes. The cossettes are conveyed to continuous diffiisers, in which
hot water is used to extract sucrose from the cossettes. In one diffuser design, the diffuser is slanted
upwards and conveys the cossettes up the slope as water is introduced at the top of the diffuser and flows
countercurrent to the cossettes. The water temperature in the diffuser is typically maintained between 50°
and 80°C (122° and 176°F). This temperature is dependant on several factors, including the
denaturization temperature of the cossettes, the thermal behavior of the beet cell wall, potential enzymatic
reactions, bacterial activity, and pressability of the beet pulp. Formalin, a 40 percent solution of
formaldehyde, was sometimes added to the diffuser water as a disinfectant but is not used at the present
time. Sulfur dioxide, chlorine, ammonium bisulfite, or commercial FDA-approved biocides are also used
as disinfectants. The sugar-enriched water that flows from the outlet of the diffuser is called raw juice
and contains between 10 and 15 percent sugar. This raw juice proceeds to the juice purification
operations. The processed cossettes, or pulp, leaving the diffuser are conveyed to the dried-pulp
manufacture operations.
In the juice purification stage, non-sucrose impurities in the raw juice are removed so that the
pure sucrose can be crystallized. First, the juice passes through screens to remove any small cossette
particles. Then the mixture is heated to 80° to 85 °C (176° to 185°F) and proceeds to the first carbonation
tank. In some processes, the juice from the screen passes through a pre-limer, a heater, and a main limer
before going to the first carbonation tank. In the first carbonation tank, milk of lime [Ca(OH)2] is added
to the mixture to adsorb or adhere to the impurities in the mixture, and carbon dioxide (C02) gas is
bubbled through the mixture to precipitate the lime as insoluble calcium carbonate crystals. Lime kilns
are used to produce the C02 and lime used in carbonation; the lime is converted to milk of lime in a lime
slaker. The small, insoluble crystals (produced during carbonation) settle out in a clarifier, after which
the juice is again treated with C02 (in the second carbonation tank) to remove the remaining lime and
impurities. The pH of the juice is lower during this second carbonation, causing large, easily filterable,
calcium carbonate crystals to form. After filtration, a small amount of sulfur dioxide (S02) is added to
the juice to inhibit reactions that lead to darkening of the juice. Most facilities purchase S02 in liquid
form, but a few facilities produce S02 by burning elemental sulfur in a sulfur stove. Following the
addition of S02, the juice (known as thin juice) proceeds to the evaporators.
The evaporation process, which increases the sucrose concentration in the juice by removing
water, is typically performed in a series of five evaporators. Steam from large boilers is used to heat the
first evaporator, and the steam from the water evaporated in the first evaporator is used to heat the second
evaporator. This transfer of heat continues through the five evaporators, and as the temperature decreases
(due to heat loss) from evaporator to evaporator, the pressure inside each evaporator is also decreased,
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allowing the juice to boil at the lower temperatures provided in each subsequent evaporator. Some steam
is released from the first three evaporators, and this steam is used as a heat source for various process
heaters throughout the plant. After evaporation, the percentage of sucrose in the "thick juice" is 50-65
percent. Crystalline sugars, produced later in the process, are added to the juice and dissolved in the high
melter. This mixture is then filtered, yielding a clear liquid known as standard liquor, which proceeds to
the crystallization operation.
Sugar is crystallized by low-temperature pan boiling. The standard liquor is boiled in vacuum
pans until it becomes supersaturated. To begin crystal formation, the liquor is either "shocked" using a
small quantity of powdered sugar or is "seeded" by adding a mixture of finely milled sugar and isopropyl
alcohol. The seed crystals are carefully grown through control of the vacuum, temperature, feed-liquor
additions, and steam. When the crystals reach the desired size, the mixture of liquor and crystals, known
as massecuite or fillmass, is discharged to the mixer. From the mixer, the massecuite is poured into high-
speed centrifugals, in which the liquid is centrifuged into the outer shell, and the crystals are left in the
inner centrifugal basket. The sugar crystals are then washed with pure hot water and are sent to the
granulator, which is a combination rotary drum dryer and cooler. Some facilities have separate sugar
dryers and coolers, which are collectively called granulators. The wash water, which contains a small
quantity of sucrose, is pumped to the vacuum pans for processing. After cooling, the sugar is screened
and then either packaged or stored in large bins for future packaging.
The liquid that was separated from the sugar crystals in the centrifugals is called syrup. This
syrup serves as feed liquor for the "second boiling" and is introduced back into the vacuum pans along
with standard liquor and recycled wash water. The process is repeated once again, resulting in the
production of molasses, which can be further desugarized using the an ion exchange process called deep
molasses desugarization. Molasses that is not desugarized can be used in the production of livestock feed
or for other purposes.
Wet pulp from the diffusion process is another product of sugarbeet processing. The pulp is first
pressed, typically in horizontal double screw presses, to reduce the moisture content from about
95 percent to about 75 percent. The water removed by the presses is collected and used as diffusion
water. After pressing, molasses is added to the pulp, which is then dried in a direct-fired horizontal
rotating drum known as a pulp dryer. The pulp dryer, which can be fired by oil, natural gas, or coal,
typically provides entrance temperatures between 482° and 927°C (900° and 1700°F). As the pulp is
dried, the gas temperature decreases and the pulp temperature increases. The exit temperature of the flue
gas is typically between 88° and 138°C (190° and 280°F). The resulting product is usually pelletized,
cooled, and sold as livestock feed.
2.3 EMISSIONS145
Particulate matter (PM), combustion products, and volatile organic compounds (VOC) are the
primary pollutants emitted from the sugarbeet processing industry. The pulp dryers, sugar granulators
and coolers, sugar conveying and sacking equipment, lime kilns and handling equipment, carbonation
tanks, sulfur stoves, evaporators, and boilers, as well as several fugitive sources are potential emission
sources. Potential emissions from boilers are addressed in AP-42 Sections 1.1 through 1.4 (Combustion)
and those from lime kilns are addressed in AP-42 Section 11.17, Lime Manufacturing. Potential sources
of PM emissions include the pulp dryer and cooler, sugar granulators, dryers, and coolers, sugar
conveying and sacking equipment, sulfur stove, and fugitive sources. Fugitive sources include unpaved
roads, coal handling, and pulp loading operations. Although most facilities purchase S02, a few facilities
still use sulfur stoves. The sulfur stove is a potential source of S02 emissions, and the pulp dryers may be
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a potential source of nitrogen oxides (NOx), S02, C02, carbon monoxide (CO), and VOC. Evaporators
may be a potential source of C02, ammonia, S02, and VOC emissions from the juice. However, only the
first three of five evaporators (in a typical five-stage system) release exhaust gases, and the gases may be
used as a heat source for various process heaters before release to the atmosphere. Emissions from
carbonation tanks are primarily water vapor but contain small quantities of ammonia (NH3), VOC, and
may also include C02 and other combustion gases from the lime kilns. There are no emission test data
available for ammonia emissions from carbonation tanks.
2.4 EMISSION CONTROL TECHNOLOGY
Particulate matter emissions from pulp dryers are typically controlled by a cyclone or multiclone
system, sometimes followed by a secondary device such as a wet scrubber or fabric filter. Wet scrubbers
also provide some degree of control of some gaseous pollutants. Particulate matter emissions from
granulators are typically controlled with wet scrubbers, and PM emissions from sugar conveying and
sacking as well as lime dust handling operations are controlled by hood systems that duct the emissions to
fabric filtration systems. Emissions from carbonation tanks and evaporators are not typically controlled.
REFERENCES FOR SECTION 2
1.	R.A. McGinnis, Beet-Sugar Technology, Third Edition, Beet Sugar Development Foundation, Fort
Collins, CO, 1982.
2.	The Beet Sugar Story, United States Beet Sugar Association, Washington, D.C., 1959.
3.	Directory of American Beet Sugar Companies, United States Beet Sugar Association,
Washington, D.C., 1997.
4.	Particulate, Aldehyde, and Semi-volatile Organic Compound (SVOC) Testing Report for the Pulp
Dryer Stacks, 1st and 2nd Carbonation Tank Vents, and the Evaporator Heater Vents, The
Amalgamated Sugar Company, Nampa, ID, May 14, 1993.
5.	Emission Performance Testing of Four Boilers, Three Dryers, and One Cooler—Holly Sugar
Corporation, Santa Maria, California, Western Environmental Services, Redondo Beach, CA,
June 1991.
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3. GENERAL DATA REVIEW AND ANALYSIS PROCEDURES
3 .1 LITERATURE SEARCH AND SCREENING
Data for this investigation were obtained from a number of sources within the Office of Air
Quality Planning and Standards (OAQPS) and from outside organizations. The AP-42 background files
located in the Emission Factor and Inventory Group (EFIG) were reviewed for information on the
industry, processes, and emissions. The Factor Information and Retrieval (FIRE), Crosswalk/Air Toxic
Emission Factor Data Base Management System (XATEF), and VOC/PM Speciation Data Base
Management System (SPECIATE) data bases were searched by SCC code for identification of the
potential pollutants emitted and emission factors for those pollutants. A general search of the Air CHIEF
CD-ROM also was conducted to supplement the information from these data bases.
Information on the industry, including number of plants, plant location, and annual production
capacities, was obtained from the Directory of American Beet Sugar Companies and other sources. The
Aerometric Information Retrieval System (AIRS) data base also was searched for data on the number of
plants, plant location, and estimated annual emissions of criteria pollutants. A number of sources of
information were investigated specifically for emission test reports and data. A search of the Test
Method Storage and Retrieval (TSAR) data base was conducted to identify test reports for sources within
the sugarbeet processing industry. However, no test reports were located using the TSAR data base. The
EPA library was searched for additional test reports. Using information obtained on plant locations,
individual facilities and State and Regional offices were contacted about the availability of test reports.
Publications lists from the Office of Research and Development (ORD) and Control Technology Center
(CTC) were also searched for reports on emissions from the sugarbeet processing industry. In addition,
representative trade associations, including the United States Beet Sugar Association and the American
Society of Beet Sugar Technologists, were contacted for assistance in obtaining information about the
industry and emissions. The trade associations suggested contacting individual sugarbeet processing
companies to request test data. All of the test reports that were located were provided by individual
companies.
To screen out unusable test reports, documents, and information from which emission factors
could not be developed, the following general criteria were used:
1.	Emission data must be from a primary reference:
a.	Source testing must be from a referenced study that does not reiterate information from
previous studies.
b.	The document must constitute the original source of test data. For example, a technical paper
was not included if the original study was contained in the previous document. If the exact source of the
data could not be determined, the document was eliminated.
2.	The referenced study should contain test results based on more than one test run. If results
from only one run are presented, the emission factors must be down rated.
3.	The report must contain sufficient data to evaluate the testing procedures and source operating
conditions (e.g., one-page reports were generally rejected).
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A final set of reference materials was compiled after a thorough review of the pertinent reports,
documents, and information according to these criteria.
3.2 DATA QUALITY RATING SYSTEM1
As part of the analysis of the emission data, the quantity and quality of the information contained
in the final set of reference documents were evaluated. The following data were excluded from
consideration:
1.	Test series averages reported in units that cannot be converted to the selected reporting units;
2.	Test series representing incompatible test methods (i.e., comparison of EPA Method 5 front
half with EPA Method 5 front and back half);
3.	Test series of controlled emissions for which the control device is not specified;
4.	Test series in which the source process is not clearly identified and described; and
5.	Test series in which it is not clear whether the emissions were measured before or after the
control device.
Test data sets that were not excluded were assigned a quality rating. The rating system used was
that specified by EFIG for preparing AP-42 sections. The data were rated as follows:
A—Multiple test runs that were performed using sound methodology and reported in enough
detail for adequate validation. These tests do not necessarily conform to the methodology specified in
EPA reference test methods, although these methods were used as a guide for the methodology actually
used.
B—Tests that were performed by a generally sound methodology but lack enough detail for
adequate validation.
C—Tests that were based on an unproven or new methodology or that lacked a significant
amount of background information.
D—Tests that were based on a generally unacceptable method but may provide an order-of-
magnitude value for the source.
The following criteria were used to evaluate source test reports for sound methodology and
adequate detail:
1.	Source operation. The manner in which the source was operated is well documented in the
report. The source was operating within typical parameters during the test.
2.	Sampling procedures. The sampling procedures conformed to a generally acceptable
methodology. If actual procedures deviated from accepted methods, the deviations are well documented.
When this occurred, an evaluation was made of the extent to which such alternative procedures could
influence the test results.
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3.	Sampling and process data. Adequate sampling and process data are documented in the
report, and any variations in the sampling and process operation are noted. If a large spread between test
results cannot be explained by information contained in the test report, the data are suspect and are given
a lower rating.
4.	Analysis and calculations. The test reports contain original raw data sheets. The
nomenclature and equations used were compared to those (if any) specified by EPA to establish
equivalency. The depth of review of the calculations was dictated by the reviewer's confidence in the
ability and conscientiousness of the tester, which in turn was based on factors such as consistency of
results and completeness of other areas of the test report.
3 .3 EMISSION FACTOR QUALITY RATING SYSTEM1
The quality of the emission factors developed from analysis of the test data was rated using the
following general criteria:
A—Excellent: Developed from A- and B-rated source test data taken from many randomly
chosen facilities in the industry population. The source category is specific enough so that variability
within the source category population may be minimized.
B—Above average: Developed only from A- or B-rated test data from a reasonable number of
facilities. Although no specific bias is evident, it is not clear if the facilities tested represent a random
sample of the industries. The source category is specific enough so that variability within the source
category population may be minimized.
C—Average: Developed only from A-, B- and/or C-rated test data from a reasonable number of
facilities. Although no specific bias is evident, it is not clear if the facilities tested represent a random
sample of the industry. In addition, the source category is specific enough so that variability within the
source category population may be minimized.
D—Below average: The emission factor was developed only from A-, B-, and/or C-rated test
data from a small number of facilities, and there is reason to suspect that these facilities do not represent a
random sample of the industry. There also may be evidence of variability within the source category
population. Limitations on the use of the emission factor are noted in the emission factor table.
E—Poor: The emission factor was developed from C- and D-rated test data, and there is reason
to suspect that the facilities tested do not represent a random sample of the industry. There also may be
evidence of variability within the source category population. Limitations on the use of these factors are
footnoted.
The use of these criteria is somewhat subjective and depends to an extent upon the individual
reviewer. Details of the rating of each candidate emission factor are provided in Section 4.
REFERENCE FOR SECTION 3
1. Technical Procedures for Developing AP-42 Emission Factors and Preparing AP-42 Sections,
EPA-454/B-93-050, Office of Air Quality Planning and Standards, U. S. Environmental Protection
Agency, Research Triangle Park, NC, October 1993.
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4. AP-42 SECTION DEVELOPMENT
4.1	INTRODUCTION
This section describes how the AP-42 section on sugarbeet processing was developed. First,
descriptions of data sets used for developing emission factors are presented, followed by a discussion of
how emission factors were developed from the data. Finally, the development of the AP-42 section on
sugarbeet processing is summarized.
4.2	REVIEW OF SPECIFIC DATA SETS
Twenty-five emission test reports were reviewed in the process of gathering data for developing
emission factors. Data from one of the reports, Reference 18, were not used for emission factor
development because the process data are presented without units. The other references are described in
the following paragraphs.
4.2.1	Reference 1
This report documents a compliance test conducted at the Minnesota Beet Sugar Cooperative in
Renville, Minnesota, on January 21, 1988. One of four stacks venting emissions from a fuel oil-fired
pulp dryer (dryer A) followed by four cyclones (one for each stack) was tested for filterable PM,
condensible PM, and carbon dioxide (C02) emissions. Particulate matter and C02 emissions were
quantified using EPA Method 5 (including front- and back-half analysis) and EPA Method 3 (with an
Orsat gas analyzer), respectively. Process data, including hourly wet beet pulp feed rates to the dryer, are
included in the report. Because only one of four stacks venting dryer emissions was tested, the measured
emissions were multiplied by four to estimate total dryer emissions. This calculation assumes that
emissions from each of the four identical stacks are similar.
The data from this report are assigned a B rating. The test methodology appears to be sound,
sufficient process data are provided, and adequate detail is included in the report. However, the
assumption that emissions from each of the four identical stacks are similar may or may not be accurate.
Pertinent test data, process data, and emission factor calculations are provided in Appendix A.
4.2.2	Reference 2
This report documents a compliance test conducted at the Minnesota Beet Sugar Cooperative in
Renville, Minnesota, on December 14, 1988. One of four stacks venting emissions from a fuel oil-fired
pulp dryer (dryer B) followed by four cyclones (one for each stack) was tested for filterable PM,
condensible PM, and C02 emissions. Particulate matter and C02 emissions were quantified using EPA
Method 5 (including front- and back-half analysis) and EPA Method 3 (with an Orsat gas analyzer),
respectively. Process data, including hourly wet beet pulp feed rates to the dryer, are included in the
report. Because only one of four stacks venting dryer emissions was tested, the measured emissions were
multiplied by four to estimate total dryer emissions. This calculation assumes that emissions from each
of the four identical stacks are similar.
The data from this report are assigned a B rating. The test methodology appears to be sound,
sufficient process data are provided, and adequate detail is included in the report. However, the
assumption that emissions from each of the four identical stacks are similar may or may not be accurate.
Pertinent test data, process data, and emission factor calculations are provided in Appendix B.
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4.2.3 Reference 3
This report documents a compliance test conducted at the Minnesota Beet Sugar Cooperative in
Renville, Minnesota, on November 18, 1986. A stack venting emissions from both the sugar dryer
(granulator) and cooler followed by two wet scrubbers (in parallel) was tested for filterable PM and C02
emissions. The scrubber water flow rate is about six gallons per minute, and the pressure drop across the
scrubber was not specified in the report. Particulate matter and C02 emissions were quantified using
EPA Methods 5 and 3 (with an Orsat gas analyzer), respectively. Because very small amounts (0.03
percent volume) of C02 were detected during all test runs, C02 emissions are assumed to be negligible.
Process data, including an average sugar production rate, are included in the report.
The data from this report are assigned a B rating. The test methodology appears to be sound,
sufficient process data are provided, and adequate detail is included in the report (except for the omission
of the scrubber pressure drop). Pertinent test data, process data, and emission factor calculations are
provided in Appendix C.
4.2.4	Reference 4
This report documents a compliance test conducted at the Minn-Dak Farmers Cooperative in
Wahpeton, North Dakota, on October 18, 1983. Two stacks venting emissions from a lignite coal-fired
pulp dryer followed by a bank of 28 cyclones were tested for filterable PM, sulfur dioxide (S02), and C02
emissions. The exhaust stream following the cyclones is split. Most of the exhaust is released through a
stack, and a portion of the exhaust is used as a heat source for the flume water heater prior to release to
the atmosphere. The two stacks tested were the main exhaust stack and the flume water heater stack,
which vent all of the emissions from the dryer. Particulate matter, S02, and C02 emissions were
quantified using EPA Methods 5 (including front- and back-half analysis), 6, and 3 (with an Orsat gas
analyzer), respectively. Process data, including wet beet pulp feed rates to the dryer (during each test
run), are included in the report.
The data from this report are assigned an A rating. The test methodology appears to be sound,
sufficient process data are provided, and adequate detail is included in the report. Pertinent test data,
process data, and emission factor calculations are provided in Appendix D.
4.2.5	Reference 5
This report documents a test conducted at the Amalgamated Sugar Company in Nampa, Idaho, on
October 14 through December 3, 1992. The purpose of the test was to satisfy the requirements of a
consent order from the Idaho Department of Health and Welfare. Three coal-fired pulp dryers (north,
central, and south dryers) were tested for filterable and condensible PM emissions, the north and central
dryers were tested for aldehyde emissions, and the north dryer was tested for semi-volatile organic
compound (SVOC) emissions. In addition, the B-side first carbonation tank and second carbonation
heater vents (venting emissions from the B-side first evaporator) were tested for SVOC emissions, and
the B-side second carbonation tank, A-side No. 2 thin juice heater vent (venting emissions from the
A-side first evaporator), and B-side second carbonation heater vent (venting emissions from the B-side
first evaporator) were tested for aldehyde emissions. Filterable PM, condensible PM, aldehyde, and
SVOC emissions were quantified using EPA Method 5, EPA Method 202, Modified EPA Method 5
(midget and standard impingers), and SW846 Method 0010, respectively. Table 4-1 shows a summary of
the testing conducted, data ratings, and important details about the testing. Pertinent test data, process
data, and emission factor calculations are provided in Appendix E.
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TABLE 4-1. REFERENCE 5; TESTS CONDUCTED AND DATA RATINGS
Source tested
Pollutant
No. of
test runs
Data
rating
Comments
North pulp dryer
Filterable PM
7
NR
Scrubber not typical
Condensible PM
7
NR
Aldehydes
6
C
Incomplete data sets included in report
SVOCa
6
C
Incomplete data sets included in report;
production rates assumed similar to rates
during aldehyde tests; some equipment
problems occurred
Central pulp dryer
Filterable PM
3
A
Sum of emissions from east and west
stacks; scrubber parameters-4-inch
pressure drop, no water sprays, low
impingement velocity
Condensible PM
3
A
Aldehydes
3
C
Incomplete data sets included in report
South pulp dryer
Filterable PM
4
B
Emission from one of two stacks were
sampled and doubled to represent both
stacks; run 5 not used because scrubber
was not operating typically; scrubber
parameters-4-inch pressure drop, water
sprays, high impingement velocity
Condensible PM
4
B
B-side first
carbonation tank
SVOC
3
B
Average process rate in 1,000 gal/hr;
samples were diluted during analysis
B-side second
carbonation tank
Aldehydes
1
D
Only one test run conducted; process rate
in 1,000 gal/hr
A-side No. 2 thin
juice heater (first
evaporator)
Aldehydes
3
C
Process rates in 1,000 gal/hr; high stack gas
moisture content and temperature caused
several problems that may have affected
results
B-side second
carbonation heater
(first evaporator)
Aldehydes
3
C
Only one set of flow data for three test
runs; process rates in 1,000 gal/hr; high
stack gas moisture content and
temperature caused several problems that
may have affected results
SVOC
4
C
Process rates in 1,000 gal/hr; high stack gas
moisture content and temperature caused
several problems that may have affected
results
"Data for a specific pollutant are rated C if three or more of the six test runs detected the pollutant. If a
specific pollutant was detected in less than three test runs, the data for that pollutant are not rated.
4.2.6 Reference 6
This report documents a compliance test conducted at the Monitor Bay Sugar Company in Bay
City, Michigan, on October 12, 1992. Two stacks, the north and south stacks, venting emissions from
natural gas-fired pulp dryer No. 3 were tested for filterable PM and C02 emissions. Each stack was
equipped with multiclones followed by a wet scrubber operating with a pressure drop of about 4 inches
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water column (in. w.c.). Particulate matter and C02 emissions were quantified using EPA Methods 5 and
3 (with an Orsat gas analyzer), respectively. Process data, including hourly wet beet pulp feed rates to
the dryer, are included in the report.
The data from this report are assigned an A rating. The test methodology appears to be sound,
sufficient process data are provided, and adequate detail is included in the report. Pertinent test data,
process data, and emission factor calculations are provided in Appendix F.
4.2.7	Reference 7
This report documents a compliance test conducted at the Monitor Bay Sugar Company in Bay
City, Michigan, on October 13, 1992. Natural gas-fired pulp dryer No. 2, followed by multiclones and a
wet scrubber operating with a pressure drop of about 4 in. w.c., was tested for filterable PM and C02
emissions. Particulate matter and C02 emissions were quantified using EPA Methods 5 and 3 (with an
Orsat gas analyzer), respectively. Process data, including hourly wet beet pulp feed rates to the dryer, are
included in the report.
The data from this report are assigned an A rating. The test methodology appears to be sound,
sufficient process data are provided, and adequate detail is included in the report. Pertinent test data,
process data, and emission factor calculations are provided in Appendix G.
4.2.8	Reference 8
This report documents a compliance test conducted at the Monitor Bay Sugar Company in Bay
City, Michigan, on October 14, 1992. Natural gas-fired pulp dryer No. 1, followed by multiclones and a
wet scrubber operating with a pressure drop of about 4 in. w.c., was tested for filterable PM and C02
emissions. Particulate matter and C02 emissions were quantified using EPA Methods 5 and 3 (with an
Orsat gas analyzer), respectively. Process data, including hourly wet beet pulp feed rates to the dryer, are
included in the report.
The data from this report are assigned an A rating. The test methodology appears to be sound,
sufficient process data are provided, and adequate detail is included in the report. Pertinent test data,
process data, and emission factor calculations are provided in Appendix H.
4.2.9	Reference 9
This report documents a compliance test conducted at the Western Sugar Company in Billings,
Montana, on December 8-9, 1988. The east natural gas-fired pulp dryer, followed by a wet scrubber, was
tested for filterable PM, condensible inorganic PM, and C02 emissions. Particulate matter emissions
were quantified using EPA Method 5 (including front- and back-half analyses) and C02 emissions were
measured using EPA Method 3 (with an Orsat gas analyzer). Process data, including an average wet beet
pulp feed rate to the dryer, are included in the report.
The data from this report are assigned a B rating. The test methodology appears to be sound and
sufficient process data are provided. However, the scrubber pressure drop is not provided in the report,
and only an average process rate is provided. Pertinent test data, process data, and emission factor
calculations are provided in Appendix I.
4.2.10	Reference 10
This report documents a compliance test conducted at the Western Sugar Company in Billings,
Montana, on January 23-25, 1990. The west natural gas-fired pulp dryer, followed by a wet scrubber,
was tested for filterable PM, condensible inorganic PM, and C02 emissions. Particulate matter emissions
were quantified using EPA Method 5 (including front- and back-half analyses) and C02 emissions were
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measured using EPA Method 3 (with an Orsat gas analyzer). Process data, including run-by-run wet beet
pulp feed rates to the dryer, are included in the report.
The data from this report are assigned a B rating. The test methodology appears to be sound and
sufficient process data are provided. However, the scrubber pressure drop is not provided in the report.
Pertinent test data, process data, and emission factor calculations are provided in Appendix J.
4.2.11	Reference 11
This report documents a compliance test conducted at the Western Sugar Company in Billings,
Montana, on January 23-25, 1991. A natural gas-fired pulp dryer, followed by a wet scrubber, was tested
for filterable PM and condensible inorganic PM emissions. Particulate matter emissions were quantified
using EPA Method 5 (including front- and back-half analyses). An average wet beet pulp feed rate to the
dryer is included in the report. The pellet cooler was also tested, but process data for the pellet cooler are
not provided in the report.
The data for emissions from the pulp dryer are assigned a C rating. The test methodology
appears to be sound and process data are provided. However, only an average process rate based on
historical data is provided, and the scrubber pressure drop in not provided in the report. Pertinent test
data, process data, and emission factor calculations are provided in Appendix K.
4.2.12	Reference 12
This report documents a compliance test conducted at the Western Sugar Company in
Scottsbluff, Nebraska, on December 12-13, 1989. A pulverized coal-fired pulp dryer, followed by a
cyclone and wet scrubber (operating with a pressure drop of about 2 in. w.c.) on each of two stacks, was
tested for filterable PM, condensible inorganic PM, and C02 emissions. Particulate matter and C02
emissions were quantified using EPA Methods 5 (including front- and back-half analyses) and 3,
respectively. Process data, including run-by-run wet beet pulp feed rates to the dryer, are included in the
report.
The data from this report are assigned an A rating. The test methodology appears to be sound,
sufficient process data are provided, and adequate detail is included in the report. Pertinent test data,
process data, and emission factor calculations are provided in Appendix L.
4.2.13	Reference 13
This report documents a compliance test conducted at Holly Sugar Corporation in Sidney,
Montana, on October 19-23, 1993. Two No. 6 fuel oil-fired pulp dryers (north and south dryers) were
tested for filterable PM, condensible inorganic PM, PM-10, S02, and C02 emissions. Emissions from the
dryers were ducted to four stacks (two for each dryer), each equipped with a dry scrubber with skimmer
fans and cyclones. Filterable PM, condensible PM, PM-10, S02, and C02 emissions were quantified
using EPA Methods 5, 202, 201A, 6, and 3 (with an Orsat gas analyzer), respectively. Process data,
including wet beet pulp feed rates to the dryer (during each test run), are included in the report. Plant
personnel indicated that half of the beet pulp processed is fed to each dryer, and the process data are
based on this estimate.
Several problems and deficiencies were encountered in this report. First, only one valid PM-10
test run (Run 1) was conducted on the north dryer (east stack), and two valid PM-10 test runs were
conducted on the north dryer (west stack). To estimate PM-10 emissions from the north dryer, the PM-10
emission rate from each of the three single stack test runs was doubled. Second, Run 1 on both south
dryer stacks was superisokinetic, and the data from this run are not used. Third, Run 3 on the south dryer
(east stack) was subisokinetic. Therefore, to estimate emissions from the south dryer for Run 3, the south
dryer (west stack) emission rates (for each pollutant) were doubled. Fourth, only one valid PM-10 test
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run (Run 2) was conducted on the south dryer (east stack), and two valid PM-10 test runs were conducted
on the south dryer (west stack). To estimate PM-10 emissions from the south dryer, the PM-10 emission
rate from each of the three single stack test runs was doubled.
The filterable PM, condensible PM, S02, and C02 data for the north dryer test are assigned an A
rating. The test methodology appears to be sound, sufficient process data are provided, and adequate
detail is included in the report. The PM-10 data for the north and south dryers are assigned a B rating
because each test run on each dryer included PM-10 measurements from only one of two stacks, and the
emission rates were doubled to represent both stacks. The filterable PM, condensible PM, S02, and C02
data for the south dryer test are assigned a B rating because only two valid test runs (Runs 2 and 4) were
conducted on the east stack, and the emission rates measured during Run 3 on the west stack were
doubled to represent both stacks. Pertinent test data, process data, and emission factor calculations are
provided in Appendix M.
4.2.14	Reference 14
This report documents a compliance test conducted at Holly Sugar Corporation in Santa Maria,
California, on June 4-14, 1991. Three fuel oil-fired pulp dryers, each followed by two cyclones (and an
air recirculation system), were tested for filterable PM, condensible inorganic PM, condensible organic
PM, C02, S02, carbon monoxide (CO), nitrogen oxide (NOx), volatile organic compounds (VOC), and
methane emissions. One of two stacks on each dryer was tested, and emissions from each stack were
multiplied by two to estimate the total emissions from each dryer. Also, a beet pulp cooler was tested for
PM emissions, but all three test runs are invalid because the isokinetic ratios were all far below 90
percent. Particulate matter emissions were quantified using EPA Method 5 (including front- and back-
half analyses). Continuous monitoring of C02, S02, CO, and NOx emissions was conducted according to
CARB Method 100, which appears to be similar to EPA-approved continuous monitoring methods for
the same pollutants. Sulfur dioxide emissions were not detected during any test run. Volatile organic
compound and methane emissions were quantified by drawing gas samples into tedlar bags and analyzing
the samples with a flame ionization detector gas chromatograph (similar to EPA Methods 18 and 25A).
The report presents concentrations of CI through C6 hydrocarbons, and VOC concentrations were
calculated on an "as carbon" basis by multiplying the individual CI through C6 concentrations by the
corresponding number of carbons (CI concentration multiplied by 1, C2 concentration multiplied by 2,
etc.) and summing the adjusted concentrations. The reported CI concentrations were assumed to be
entirely methane, and were used to determine methane emissions. Production rates are provided for each
dryer, but data needed to convert the production rates to dryer feed rates are only provided for dryer
No. 1. Because the reported production rates are the same for the three dryers, the average feed rate
calculated for dryer No. 1 is assumed to equal the feed rate for dryers 2 and 3.
The data for dryer No. 1 are assigned a B rating because only one of two stacks from the dryer
was tested. Otherwise, the test methodology appears to be sound, sufficient process data are provided,
and adequate detail is included in the report. The data for dryers 2 and 3 are assigned a C rating because
the dryer feed rates are estimated using the average feed rate for dryer No. 1 and only one of two stacks
from each dryer was tested. Pertinent test data, process data, and emission factor calculations are
provided in Appendix N.
4.2.15	Reference 15
This report documents a compliance test conducted at the Great Lakes Sugar Company in
Fremont, Ohio, on December 2, 1992. A fuel oil-fired pulp dryer, followed by a cyclone and a gas
aspiration system, was tested for filterable PM, C02, and S02 emissions. Particulate matter and C02
emissions were quantified using EPA Methods 5 and 3 (with a Fyrite gas analyzer), respectively. Sulfur
dioxide emissions were measured using a modified EPA Method 8 test, which was a Method 8 analysis
of the impingers from the Method 5 sampling train. Three test runs were conducted, but the first run was
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not valid because the isokinetic variation was not within the prescribed limits. Process data, including
run-by-run wet beet pulp feed rates to the dryer, are included in the report.
The filterable PM and S02 data from this report are assigned a B rating because only two valid
test runs were conducted. The test methodology appears to be sound, extensive process data are
provided, and adequate detail is included in the report. The C02 data from this report are assigned a C
rating because of the relative inaccuracy of Fyrite analyzers. Pertinent test data, process data, and
emission factor calculations are provided in Appendix O.
4.2.16	Reference 16
This report documents a compliance test conducted at the American Crystal Sugar Company in
East Grand Forks, Minnesota, on February 24, 1994. Three coal-fired pulp dryers (dryers A, B, and C),
each controlled by multiclones, were tested for filterable PM, condensible organic PM, C02, and NOx
emissions. In addition, a cascade impactor was used to determine the particle size distribution during a
single test run for pulp dryer B. Particulate matter, C02, and NOx emissions were quantified using EPA
Methods 5 (including front- and back-half analyses), 3 (with an Orsat gas analyzer), and 7, respectively.
Three test runs were conducted for each pollutant and dryer, but only one valid NOx test run was
conducted on dryers B and C. The NOx data for dryers B and C are not used for emission factor
development. Process data, including hourly wet beet pulp feed rates to the dryer, are included in the
report.
The data from this report are assigned an A rating. The test methodology appears to be sound,
extensive process data are provided, and adequate detail is included in the report. Pertinent test data,
process data, and emission factor calculations are provided in Appendix P.
4.2.17	Reference 17
This report documents a compliance test conducted at the American Crystal Sugar Company in
Moorhead, Minnesota, on January 21, 1992. The south coal-fired pulp dryer was tested for filterable PM
and C02 emissions both before and after the control system, which consisted of multiclones and a stack
filter system. In addition, condensible organic PM emissions were measured following the control
system. Particulate matter and C02 emissions were quantified using EPA Methods 5 (including front-
and back-half analyses) and 3 (with an Orsat gas analyzer), respectively. Three simultaneous inlet and
outlet test runs were conducted under each of four different exhaust gas recycle rates. Because the
exhaust gas recycle rates had little effect on the magnitude of PM and C02 emissions, the twelve test runs
are averaged together and considered a single test. Process data, including hourly wet beet pulp feed
rates to the dryer, are included in the report.
The data from this report are assigned an A rating. The test methodology appears to be sound,
extensive process data are provided, and adequate detail is included in the report. Pertinent test data,
process data, and emission factor calculations are provided in Appendix Q.
4.2.18	Reference 19
This report documents a compliance test conducted at the American Crystal Sugar Company in
Crookston, Minnesota, on March 11, 1993. A venturi scrubber-controlled sugar cooler was tested for
filterable PM, condensible inorganic PM, condensible organic PM, and C02 emissions at the scrubber
outlet. The scrubber operated with a pressure drop between 5 and 7 in. w.c. during testing. Particulate
matter and C02 emissions were quantified using EPA Methods 5 (including front- and back-half
analyses) and 3 (with an Orsat gas analyzer), respectively. However, C02 was not detected during any
test run. Three test runs were conducted, and process data, including run-by-run sugar cooler throughput
rates, are included in the report.
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The data from this report are assigned an A rating. The test methodology appears to be sound,
sufficient process data are provided, and adequate detail is included in the report. Pertinent test data,
process data, and emission factor calculations are provided in Appendix R.
4.2.19	Reference 20
This report documents a compliance test conducted at the American Crystal Sugar Company in
East Grand Forks, Minnesota, on November 11, 1993. Three coal-fired pulp dryers (dryers A, B, and C),
each controlled by multiclones, were tested for filterable PM, condensible organic PM, C02, S02, CO,
NOx, and VOC emissions. Also, two stacks venting pellet cooler emissions and one stack venting
emissions from a pellet loadout operation were tested for PM emissions, but process data are not provided
for these tests. Particulate matter, C02, NOx, and CO emissions were quantified using EPA Methods 5
(including front- and back-half analyses), 3 (with an Orsat gas analyzer), 7, and 10, respectively. Sulfur
dioxide samples were collected in the back half of the Method 5 sampling train and were analyzed in
accordance with the large impinger version of EPA Method 6. Volatile organic compound emissions
were quantified by drawing gas samples into tedlar bags and analyzing the samples with a flame
ionization detector calibrated against propane (similar to EPA Method 25A). The VOC data are reported
on an "as carbon" basis and were converted to an "as methane" basis using the ratio of the molecular
weights of methane and carbon. Process data, including hourly wet beet pulp feed rates to the dryer, are
only provided for dryer A.
The data for dryer A are assigned an A rating. The test methodology appears to be sound,
sufficient process data are provided, and adequate detail is included in the report. The data for the other
sources tested are not rated because the necessary process data are not provided. Pertinent test data,
process data, and emission factor calculations are provided in Appendix S.
4.2.20	Reference 21
This report documents a compliance test conducted at the American Crystal Sugar Company in
Moorehead, Minnesota, on November 14, 1990. A sugar cooler and a sugar granulator, each controlled
by a mechanical centrifugal separator with water sprays (rotoclone), were tested for filterable PM,
condensible organic PM, and C02 emissions at the rotoclone outlets. Particulate matter and C02
emissions were quantified using EPA Methods 5 (including front- and back-half analyses) and 3 (with an
Orsat gas analyzer), respectively. Because very small amounts (0.03 percent volume) of C02 were
detected during all test runs, C02 emissions are assumed to be negligible. Three test runs were
conducted, and process data, including run-by-run sugar cooler throughput rates (equivalent to sugar
granulator output rates), are included in the report.
The data from this report are assigned an A rating. The test methodology appears to be sound,
sufficient process data are provided, and adequate detail is included in the report. Pertinent test data,
process data, and emission factor calculations are provided in Appendix T.
4.2.21	Reference 22
This report documents a compliance test conducted at the American Crystal Sugar Company in
Crookston, Minnesota, on February 22, 1993. The No.l and No.2 pulp dryers, each controlled by
multiclones and a stack filter system, were tested for filterable PM, condensible organic PM, and C02
emissions. Particulate matter and C02 emissions were quantified using EPA Methods 5 (including front-
and back-half analyses) and 3 (with an Orsat gas analyzer), respectively. Five valid test runs were
conducted on dryer No. 1, and nine valid runs were conducted on dryer No. 2. Process data, including
run-by-run wet pulp feed rates to the dryers, are included in the report.
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The data from this report are assigned an A rating. The test methodology appears to be sound,
sufficient process data are provided, and adequate detail is included in the report. Pertinent test data,
process data, and emission factor calculations are provided in Appendix U.
4.2.22	Reference 23
This report documents a compliance test conducted at the Michigan Sugar Company in Caro,
Michigan, on December 14, 1989. A natural gas-fired pulp dryer, followed by multiclones, was tested for
filterable PM and C02 emissions. Hopper of multiclone is aspirated and airflow recirculated to
combustion chamber of the dryer. Particulate matter and C02 emissions were quantified using EPA
Methods 17 and 3 (with an Orsat gas analyzer), respectively. Five test runs were conducted, but Runs 1
and 3 were not valid and were not used to determine the emissions from the dryer. Process data are
included in the report, and run-by-run dryer feed rates were calculated using the process data.
The data from this report are assigned an A rating. The test methodology appears to be sound,
sufficient process data are provided, and adequate detail is included in the report. Pertinent test data,
process data, and emission factor calculations are provided in Appendix V.
4.2.23	Reference 24
This report documents a compliance test conducted at the Michigan Sugar Company in
Carrollton, Michigan, on November 14 and 16, 1989. A natural gas-fired pulp dryer, followed by
multiclones, was tested for filterable PM and C02 emissions. A side stream from the multiclone is sent
through a baghouse; the baghouse can be aspirated at two different aspiration rates. Aspiration rate is
related to PM concentration. Particulate matter and C02 emissions were quantified using EPA
Methods 17 and 3 (with an Orsat gas analyzer), respectively. Three test runs were conducted while the
dryer operated at the two aspiration rates, but one run from each test was not valid because the isokinetic
variation was not within the prescribed limits. The two aspiration rates did not appear to affect PM or
C02 emissions; therefore, data from the four valid test runs are averaged. Process data are included in the
report, and run-by-run dryer feed rates were calculated using the process data.
The data from this report are assigned an A rating. The test methodology appears to be sound,
sufficient process data are provided, and adequate detail is included in the report. Pertinent test data,
process data, and emission factor calculations are provided in Appendix W.
4.2.24	Reference 25
This report documents a compliance test conducted at the Michigan Sugar Company in Croswell,
Michigan, on November 19, 1990. A fuel oil-fired pulp dryer, followed by multiclones and a gas
aspiration system, was tested for filterable PM and C02 emissions. Particulate matter and C02 emissions
were quantified using EPA Methods 5 and 3 (with an Orsat gas analyzer), respectively. Three test runs
were conducted, process data are included in the report, and run-by-run dryer feed rates were calculated
using the process data.
The data from this report are assigned an A rating. The test methodology appears to be sound,
sufficient process data are provided, and adequate detail is included in the report. Pertinent test data,
process data, and emission factor calculations are provided in Appendix X.
4.2.25	Reference 26
This report documents a compliance test conducted at the Western Sugar Company in
Scottsbluff, Nebraska, on December 14-17, 1994. A natural gas-fired pulp dryer, followed by a wet
scrubber on each of two stacks, was tested for filterable PM, condensible inorganic PM, and C02
emissions. Particulate matter and C02 emissions were quantified using EPA Method 5 (including front-
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and back-half analyses) and 3, respectively. Process data on run-by-run wet beet pulp feed rate bases
were not available; total wet pulp feed on the test days was used.
The data from this report are assigned a B rating. The test methodology appears to be sound,
sufficient process data are provided, and adequate details is included in the report. The hourly wet pulp
feed rate was a prorated figure based on the total feed rate on the day of the test. Pertinent test data,
process data, and emission factor calculations are provided in Appendix Y.
4.2.26 Review of FIRE. XATEF. and SPECIATE Data Base Emission Factors
Emission factors for NOx, sulfur oxides (SOx) and VOC from dryers were found in the FIRE data
base. However, the type of dryer is not specified, and the basis for the emission factors, raw beets, is
incorrect because raw beets are not fed to a dryer at any point during processing operations. Therefore,
these data are not included in the AP-42 section. Emission factors for sugarbeet processing from the
SPECIATE data base are based solely on engineering judgment and are not included in the AP-42
section. Relevant data were not found in XATEF.
4.3 DEVELOPMENT OF CANDIDATE EMISSION FACTORS
Emission factors for rotary drum pulp dryers, first and second carbonation tanks, first
evaporators, sugar coolers, and sugar granulators were developed using data from the references
described in Section 4.2 of this document. Table 4-2 developed using these data. The emission factor
ratings assigned to the factors for the revised AP-42 section are based on the guidelines presented in
Section 3.3 of this report.
Emission factors were developed by grouping the data from similar combinations of source,
pollutant, and control device, discarding the inferior data sets, and averaging the emission factors derived
from each data set. In some cases, data were available from multiple tests on the same source. In such
cases, the emission factors from the tests on that source were averaged first, and the resulting factor was
then averaged with the factors from other similar sources. The following paragraphs describe how the
data presented in Table 4-2 were used to develop the emission factors presented in Table 4-3. The
emission factor units for the pulp dryers are mass of pollutant per mass of wet pulp feed, and the units for
the tanks and evaporators are mass of pollutant per volume of juice produced.
4.3.1 Filterable PM
An emission factor for uncontrolled filterable PM emissions from a coal-fired pulp dryer was
developed using A-rated data from Reference 17. The emission factor is 2.2 kg/Mg (4.4 lb/ton). This
emission factor is assigned a D rating because it was developed using data from a single test.
An emission factor for filterable PM emissions from a coal-fired pulp dryer controlled with
multiple cyclones was developed using A-rated data from eight tests conducted on seven different dryers.
The dryers are located at four facilities. The data range from 0.21 kg/Mg (0.42 lb/ton) to 0.59 kg/Mg
(1.2 lb/ton) and average 0.33 kg/Mg (0.66 lb/ton). This candidate emission factor is assigned a B rating
because it was developed using A-rated data from 4 of the 31 sugarbeet processing plants currently
operating in the United States.
An emission factor for filterable PM emissions from a coal-fired pulp dryer controlled with a wet
scrubber was developed using A- and B-rated data from three tests conducted on two different dryers.
The data range from 0.17 kg/Mg (0.34 lb/ton) to 0.36 kg/Mg (0.72 lb/ton) and average 0.25 kg/Mg
(0.49 lb/ton). This candidate emission factor is assigned a D rating because it was developed using data
from only 2 of the 31 sugarbeet processing plants currently operating in the United States.
4-10

-------
TABLE 4-2. SUMMARY OF EMISSION DAI
rAFO]
R SUGARBEET PROCESSING3
Source
Control device
Pollutant
No. of
test
runs
Data
rating
Emission factor
range, kg/Mg (lb/ton)
Average emission
factor, kg/Mg
(lb/ton)
Ref.
No.
Oil-fired pulp dryer
Cyclone
Filterable PM
3
B
0.61-0.69 (1.2-1.4)
0.64 (1.3)
1
Oil-fired pulp dryer
Cyclone
Condensible inorganic PM
3
B
0.0092-0.017 (0.018-0.035)
0.014 (0.027)
1
Oil-fired pulp dryer
Cyclone
Condensible organic PM
3
B
0.015 0.018 (0.029-0.036)
0.016 (0.032)
1
Oil-fired pulp dryer
Cyclone
co2
3
B
150-190 (300-370)
170 (330)
1
Oil-fired pulp dryer
Cyclone
Filterable PM
3
B
0.33-1.4 (0.66-2.8)
0.72 (1.4)
2
Oil-fired pulp dryer
Cyclone
Condensible inorganic PM
3
B
0.027-0.050 (0.055 0.10)
0.040 (0.079)
2
Oil-fired pulp dryer
Cyclone
Condensible organic PM
3
B
0.020-0.063 (0.040-0.093)
0.043 (0.086)
2
Oil-fired pulp dryer
Cyclone
co2
3
B
190-360 (370-730)
270 (550)
2
Sugar dryer and cooler
Wet scrubber
Filterable PM
3
B
0.015 0.019 (0.029-0.039)
0.018 (0.035)
3
Sugar dryer and cooler
Wet scrubber
co2
3
B
ND
Negligible
3
Coal-fired pulp dryer
Multiple cyclones
Filterable PM
3
A
0.48-0.66 (0.97-1.3)
0.59 (1.2)
4
Coal-fired pulp dryer
Multiple cyclones
so2
3
A
0.66-0.69 (1.3-1.4)
0.68 (1.4)
4
Coal-fired pulp dryer
Multiple cyclones
co2
3
A
220-250 (430-500)
230 (460)
4
Coal-fired pulp dryer
Wet scrubber
Filterable PM
3
A
0.18-0.23 (0.36-0.46)
0.21 (0.42)
5
Coal-fired pulp dryer
Wet scrubber
Condensible PM
3
A
0.18-0.33 (0.37-0.66)
0.23 (0.47)
5
Coal-fired pulp dryer
Wet scrubber
Filterable PM
4
B
0.12-0.23 (0.23-0.47)
0.17 (0.34)
5
Coal-fired pulp dryer
Wet scrubber
Condensible PM
4
B
0.11-0.25 (0.22-0.50)
0.17 (0.33)
5
Coal-fired pulp dryer
Wet scrubber
Formaldehyde
6
C
ND
0.0042 (0.0083)
5
Coal-fired pulp dryer
Wet scrubber
Acetaldehyde
6
C
ND
0.0065 (0.013)
5
Coal-fired pulp dryer
Wet scrubber
Acrolein
6
C
ND
0.0030 (0.0060)
5
Coal-fired pulp dryer
Wet scrubber
Crotonaldehyde
6
C
ND
0.0012 (0.0024)
5
Coal-fired pulp dryer
Wet scrubber
Benzoic acid
6
C
ND
0.0014 (0.0028)
5
Coal-fired pulp dryer
Wet scrubber
Benzaldehyde
6
C
ND
0.00070 (0.0014)
5
Coal-fired pulp dryer
Wet scrubber
Bis (2 -ethylhexyl) phthalate
6
C
ND
0.00075 (0.0015)
5
Coal-fired pulp dryer
Wet scrubber
Phenol
3
C
ND
0.00016 (0.00032)
5
Coal-fired pulp dryer
Wet scrubber
2-nitrophenol
5
C
ND
9.0x10 5 (0.00018)
5

-------
TABLE 4-2. (continued)
Source
Control device
Pollutant
No.
of
test
runs
Data
rating
Emission factor
range, kg/Mg (lb/ton)
Average emission
factor, kg/Mg
(lb/ton)
Ref.
No.
Coal-fired pulp dryer
Wet scrubber
4-nitrophenol
4
C
ND
7.0x10 5 (0.00014)
5
Coal-fired pulp dryer
Wet scrubber
4-methylphenol
5
C
ND
6.5x10 5 (0.00013)
5
Coal-fired pulp dryer
Wet scrubber
Naphthalene
6
C
ND
5.5x10 5 (0.00011)
5
Coal-fired pulp dryer
Wet scrubber
Di-n-butylphthalate
4
C
ND
2.6x10 5 (5.2x10 5)
5
Coal-fired pulp dryer
Wet scrubber
Benzyl alcohol
5
C
ND
3.6x10 5 (7.1x10 5)
5
Coal-fired pulp dryer
Wet scrubber
2, 4-dinitrophenol
2
NR
ND
2.6x10 5 (5.1x10 5)
5
Coal-fired pulp dryer
Wet scrubber
2-methylphenol
5
C
ND
1.7x10 5 (3.4x10 5)
5
Coal-fired pulp dryer
Wet scrubber
Nitrobenzene
4
C
ND
9.5x10 6 (1.9x10 5)
5
Coal-fired pulp dryer
Wet scrubber
2,4-dimethylphenol
4
C
ND
1.3x10 5 (2.5x10 5)
5
Coal-fired pulp dryer
Wet scrubber
2-methylnaphthalene
5
C
ND
8.5x10 6 (1.7x10 5)
5
Coal-fired pulp dryer
Wet scrubber
4,6-Dinitro-2-methylphenol
1
NR
ND
7.5x10 6 (1.5x10 5)
5
Coal-fired pulp dryer
Wet scrubber
Dibenzofuran
5
C
ND
5.5x10 6 (1.1x10 5)
5
Coal-fired pulp dryer
Wet scrubber
Phenanthrene
5
C
ND
6.0x10 6 (1.2x10 5)
5
Coal-fired pulp dryer
Wet scrubber
Diethylphthalate
3
C
ND
4.9x10 6 (9.8x10 6)
5
Coal-fired pulp dryer
Wet scrubber
Acenaphthylene
4
C
ND
8.5x10 7 (1.7x10 6)
5
Coal-fired pulp dryer
Wet scrubber
Butylbenzylphthalate
1
NR
ND
5.5x10 6 (1.1x10 5)
5
Coal-fired pulp dryer
Wet scrubber
Fluoranthene
1
NR
ND
3.0x10 6 (6.0x10 6)
5
Coal-fired pulp dryer
Wet scrubber
Anthracene
1
NR
ND
2.5x10 6 (5.0x10 6)
5
Coal-fired pulp dryer
Wet scrubber
Formaldehyde
3
C
ND
0.0030 (0.0059)
5
Coal-fired pulp dryer
Wet scrubber
Acetaldehyde
3
C
ND
0.0080 (0.016)
5
Coal-fired pulp dryer
Wet scrubber
Acrolein
3
C
ND
0.0046 (0.0092)
5
Coal-fired pulp dryer
Wet scrubber
Crotonaldehyde
3
C
ND
0.00080 (0.0016)
5
First carbonation tankb
None
Benzaldehyde
3
B
9.5x10 5-1.2xl04
1.1x104
5
First carbonation tankb
None
Bis (2 -ethylhexyl) phthalate
3
B
9.6x10 6-1.8xl0 5
1.2x10 5
5
First carbonation tankb
None
Benzoic acid
3
B
6.2x10 6-1.2xl0 5
8.4x106
5

-------
TABLE 4-2. (continued)
Source
Control device
Pollutant
No.
of
test
runs
Data
rating
Emission factor
range, kg/Mg (lb/ton)
Average emission
factor, kg/Mg
(lb/ton)
Ref.
No.
First carbonation tankb
None
2, 4-dinitrophenol
3
B
NP-l.lxlO 5
NP
5
First carbonation tankb
None
Naphthalene
3
B
1.5x10 6-2.4xl0 6
2.0x106
5
First carbonation tankb
None
Phenanthrene
3
B
1.3x10 6-l.4x10 6
1.4x106
5
First carbonation tankb
None
Phenol
3
B
1.1x10 6-l.4x10 6
1.3x106
5
First carbonation tankb
None
4-methylphenol
3
B
5.2x10 7-8.7xl0 7
6.6x10 7
5
First carbonation tankb
None
2-methylnaphthalene
3
B
2.8x10 7-6.4xl0 7
5.1x10 7
5
First carbonation tankb
None
Acenaphthene
3
B
NP-1.5xl06
NP
5
Second carbonation
tankb
None
Formaldehyde
1
D
ND
1.6x10 5
5
Second carbonation
tankb
None
Acetaldehyde
1
D
ND
0.0043
5
Second carbonation
tankb
None
Acrolein
1
D
ND
2.4x10"
5
Second carbonation
tankb
None
Crotonaldehyde
1
D
ND
3.0x10 5
5
First evaporator0
None
Formaldehyde
3
C
2.5x10 7-2.8xl06
1.3x106
5
First evaporator0
None
Acetaldehyde
3
C
6.2x10 5-1.4xl0 4
1.1x104
5
First evaporator0
None
Acrolein
3
C
6.5x10 8-2.6xl0 7
1.5x10 7
5
First evaporator0
None
Crotonaldehyde
3
C
9.8x10 8-3.0xl0 7
1.9x10 7
5
First evaporator0
None
Formaldehyde
3
C
6.9x10 8-1.5xl0 7
1.0x10 7
5
First evaporator0
None
Acetaldehyde
3
C
l.:ixl() 3.3x10
2.4x10 5
5
First evaporator0
None
Acrolein
3
C
5.6x10 7-7.9xl0 7
6.8x10 7
5
First evaporator0
None
Crotonaldehyde
3
C
6.9x10 8-1.2xl0 7
9.5x108
5
First evaporator0
None
Benzaldehyde
4
C
9.3x10 7-3.5xl0 6
2.2x106
5
First evaporator0
None
Bis (2 -ethylhexyl) phthalate
4
C
8.0x10 8-8.2xl0 7
3.7x10 7
5
First evaporator0
None
Benzyl alcohol
4
C
6.4x10 8-2.5xl0 7
1.8x10 7
5
First evaporator0
None
Naphthalene
4
C
NP-5.2xlO 8
2.5x108
5

-------
TABLE 4-2. (continued)
Source
Control device
Pollutant
No.
of
test
runs
Data
rating
Emission factor
range, kg/Mg (lb/ton)
Average emission
factor, kg/Mg
(lb/ton)
Ref.
No.
First evaporator0
None
Benzoic acid
4
C
NP-5.0xl0 8
NP
5
First evaporator0
None
Phenol
4
C
NP-3.3xlO 8
1.2x108
5
First evaporator0
None
Diethylphthalate
4
C
NP-4.6xlO 8
NP
5
First evaporator0
None
Pyridine
4
C
1.4x10 8-4.6xl0 8
3.4x108
5
First evaporator0
None
Dibenzofuran
4
C
NP-1.7xlO 9
NP
5
First evaporator0
None
Di-n-butylphthalate
4
C
NP-3.1xlO 9
1.1x109
5
Natural gas-fired pulp
dryer
Multiple cyclones and
wet scrubber
Filterable PM
3
A
0.13-0.16 (0.27-0.32)
0.15 (0.30)
6
Natural gas-fired pulp
dryer
Multiple cyclones and
wet scrubber
co2
3
A
61-73 (120-150)
68 (140)
6
Natural gas-fired pulp
dryer
Multiple cyclones and
wet scrubber
Filterable PM
3
A
0.078-0.091 (0.16-0.18)
0.082 (0.16)
7
Natural gas-fired pulp
dryer
Multiple cyclones and
wet scrubber
co2
3
A
33-41 (67-82)
37 (73)
7
Natural gas-fired pulp
dryer
Multiple cyclones and
wet scrubber
Filterable PM
3
A
0.070-0.090 (0.14-0.18)
0.078 (0.16)
8
Natural gas-fired pulp
dryer
Multiple cyclones and
wet scrubber
co2
3
A
39-56 (78-110)
45 (90)
8
Natural gas-fired pulp
dryer
Wet scrubber
Filterable PM
3
B
0.030-0.047 (0.060-0.093)
0.038 (0.075)
9
Natural gas-fired pulp
dryer
Wet scrubber
Condensible inorganic PM
3
B
0.0074-0.0081 (0.015 0.016)
0.0077 (0.015)
9
Natural gas-fired pulp
dryer
Wet scrubber
co2
3
B
28-30 (57-61)
29 (58)
9
Natural gas-fired pulp
dryer
Wet scrubber
Filterable PM
3
B
0.039-0.067 (0.078-0.13)
0.055 (0.11)
10
Natural gas-fired pulp
dryer
Wet scrubber
Condensible inorganic PM
3
B
0.0054-0.019 (0.011-0.038)
0.014 (0.027)
10
Natural gas-fired pulp
dryer
Wet scrubber
co2
3
B
68-95 (140-190)
78 (160)
10

-------
TABLE 4-2. (continued)
Source
Control device
Pollutant
No.
of
test
runs
Data
rating
Emission factor
range, kg/Mg (lb/ton)
Average emission
factor, kg/Mg
(lb/ton)
Ref.
No.
Natural gas-fired pulp
dryer
Wet scrubber
Filterable PM
3
C
0.19-0.25 (0.37-0.49)
0.22 (0.43)
11
Natural gas-fired pulp
dryer
Wet scrubber
Condensible inorganic PM
3
C
0.10-0.13 (0.20-0.27)
0.12 (0.23)
11
Coal-fired pulp dryer
Cyclone and wet
scrubber
Filterable PM
3
A
0.30-0.40 (0.61-0.81)
0.36 (0.72)
12
Coal-fired pulp dryer
Cyclone and wet
scrubber
Condensible inorganic PM
3
A
0.022-0.029 (0.043-0.057)
0.025 (0.050)
12
Coal-fired pulp dryer
Cyclone and wet
scrubber
co2
3
A
120-140 (250-270)
130 (260)
12
Oil-fired pulp dryer
Dry scrubber and
cyclone
Filterable PM
3
A
0.32-0.45 (0.63-0.91)
0.38 (0.77)
13
Oil-fired pulp dryer
Dry scrubber and
cyclone
Condensible inorganic PM
3
A
0.093 0.21 (0.19-0.42)
0.15 (0.29)
13
Oil-fired pulp dryer
Dry scrubber and
cyclone
Filterable PM-10
3
B
0.20-0.27 (0.40-0.54)
0.23 (0.47)
13
Oil-fired pulp dryer
Dry scrubber and
cyclone
co2
3
A
180-220 (360-440)
190 (390)
13
Oil-fired pulp dryer
Dry scrubber and
cyclone
so2
3
A
0.23-0.47 (0.47-0.95)
0.31 (0.63)
13
Oil-fired pulp dryer
Dry scrubber and
cyclone
Filterable PM
3
B
0.69-0.89 (1.4-1.8)
0.76 (1.5)
13
Oil-fired pulp dryer
Dry scrubber and
cyclone
Condensible inorganic PM
3
B
0.19-0.40 (0.38-0.80)
0.27 (0.55)
13
Oil-fired pulp dryer
Dry scrubber and
cyclone
Filterable PM-10
3
B
0.48-0.74 (0.97-1.5)
0.59 (1.2)
13
Oil-fired pulp dryer
Dry scrubber and
cyclone
co2
3
B
260-310 (530-620)
290 (570)
13
Oil-fired pulp dryer
Dry scrubber and
cyclone
so2
3
B
0.57-0.62 (1.1-1.2)
0.60 (1.2)
13
Oil-fired pulp dryer
Dual cyclones
Filterable PM
3
B
0.58-1.1 (1.2-2.2)
0.79 (1.6)
14
Oil-fired pulp dryer
Dual cyclones
Condensible inorganic PM
3
B
0.059-0.24 (0.12-0.47)
0.13 (0.26)
14

-------
TABLE 4-2. (continued)
Source
Control device
Pollutant
No.
of
test
runs
Data
rating
Emission factor
range, kg/Mg (lb/ton)
Average emission
factor, kg/Mg
(lb/ton)
Ref.
No.
Oil-fired pulp dryer
Dual cyclones
Condensible organic PM
3
B
0-0.16 (0-0.32)
0.054 (0.11)
14
Oil-fired pulp dryer
Dual cyclones
co2
3
B
170-180 (340-360)
180 (350)
14
Oil-fired pulp dryer
Dual cyclones
so2
3
B
NP
NP
14
Oil-fired pulp dryer
Dual cyclones
CO
3
B
0.30-0.83 (0.61-1.7)
0.51 (1.01)
14
Oil-fired pulp dryer
Dual cyclones
NOx
3
B
0.28-0.33 (0.56-0.67)
0.30 (0.60)
14
Oil-fired pulp dryer
Dual cyclones
VOC as methane
3
B
0.049-0.065 (0.098-0.13)
0.055 (0.11)
14
Oil-fired pulp dryer
Dual cyclones
Methane
3
B
0.0070-0.024 (0.014-0.048)
0.014 (0.028)
14
Oil-fired pulp dryer
Dual cyclones
Filterable PM
3
C
0.31-0.46 (0.63-0.91)
0.39 (0.78)
14
Oil-fired pulp dryer
Dual cyclones
Condensible inorganic PM
3
C
0.052 0.16 (0.10-0.33)
0.11 (0.23)
14
Oil-fired pulp dryer
Dual cyclones
Condensible organic PM
3
C
0.0019-0.0036
(0.0038-0.0072)
0.0029 (0.0057)
14
Oil-fired pulp dryer
Dual cyclones
co2
3
C
83-170 (170-340)
130 (260)
14
Oil-fired pulp dryer
Dual cyclones
so2
3
C
NP
NP
14
Oil-fired pulp dryer
Dual cyclones
CO
3
C
0.44-0.47 (0.88-0.94)
0.46 (0.92)
14
Oil-fired pulp dryer
Dual cyclones
NOx
3
C
0.17-0.19 (0.35-0.39)
0.18 (0.37)
14
Oil-fired pulp dryer
Dual cyclones
VOC as methane
3
C
0.086-0.092 (0.17-0.18)
0.089 (0.18)
14
Oil-fired pulp dryer
Dual cyclones
Methane
3
C
0.0085-0.038 (0.017-0.077)
0.020 (0.040)
14
Oil-fired pulp dryer
Dual cyclones
Filterable PM
3
C
0.56-0.76 (1.1-1.5)
0.64 (1.3)
14
Oil-fired pulp dryer
Dual cyclones
Condensible inorganic PM
3
C
0.021-0.030 (0.042-0.059)
0.026 (0.052)
14
Oil-fired pulp dryer
Dual cyclones
Condensible organic PM
3
C
0.0022-0.0046
(0.0043-0.0093)
0.0034 (0.0068)
14
Oil-fired pulp dryer
Dual cyclones
co2
3
C
120-170 (240-340)
140 (280)
14
Oil-fired pulp dryer
Dual cyclones
so2
3
C
NP
NP
14
Oil-fired pulp dryer
Dual cyclones
CO
3
C
0.43-0.46 (0.86-0.92)
0.45 (0.89)
14
Oil-fired pulp dryer
Dual cyclones
NO,
3
C
0.19-0.20 (0.38-0.41)
0.20 (0.39)
14
Oil-fired pulp dryer
Dual cyclones
VOC as methane
3
C
0.084-0.10 (0.17-0.21)
0.091 (0.18)
14

-------
TABLE 4-2. (continued)
Source
Control device
Pollutant
No.
of
test
runs
Data
rating
Emission factor
range, kg/Mg (lb/ton)
Average emission
factor, kg/Mg
(lb/ton)
Ref.
No.
Oil-fired pulp dryer
Dual cyclones
Methane
3
C
0.013-0.020 (0.026-0.041)
0.017 (0.034)
14
Oil-fired pulp dryer
Multiple cyclones;
aspiration
Filterable PM
2
B
0.24-0.30 (0.49-0.61)
0.27 (0.55)
15
Oil-fired pulp dryer
Multiple cyclones;
aspiration
co2
2
C
200-230 (400-460)
220 (430)
15
Oil-fired pulp dryer
Multiple cyclones;
aspiration
so2
2
B
0.64-0.65 (1.3-1.3)
0.65 (1.3)
15
Coal-fired pulp dryerd
Multiple cyclones
Filterable PM
3
A
0.21-0.25 (0.41-0.49)
0.22 (0.44)
16
Coal-fired pulp dryerd
Multiple cyclones
Condensible organic PM
3
A
0.027-0.030 (0.054-0.060)
0.028 (0.056)
16
Coal-fired pulp dryerd
Multiple cyclones
co2
3
A
160-180 (320-360)
170 (340)
16
Coal-fired pulp dryerd
Multiple cyclones
NOx
3
A
0.25-0.33 (0.50-0.66)
0.28 (0.57)
16
Coal-fired pulp dryer
Multiple cyclones
Filterable PM
3
A
0.33-0.48 (0.65-0.96)
0.38 (0.76)
16
Coal-fired pulp dryer
Multiple cyclones
Condensible organic PM
3
A
0.016-0.027 (0.032-0.053)
0.021 (0.041)
16
Coal-fired pulp dryer
Multiple cyclones
co2
3
A
210-280 (410-560)
230 (460)
16
Coal-fired pulp dryer
Multiple cyclones
Filterable PM
3
A
0.26-0.33 (0.53-0.67)
0.28 (0.57)
16
Coal-fired pulp dryer
Multiple cyclones
Condensible organic PM
3
A
0.019-0.021 (0.037-0.041)
0.019 (0.039)
16
Coal-fired pulp dryer
Multiple cyclones
co2
3
A
180-210 (350-420)
200 (390)
16
Coal-fired pulp dryer
None
Filterable PM
12
A
1.9-2.6 (3.9-5.1)
2.2 (4.4)
17
Coal-fired pulp dryer
None
co2
12
A
170-240 (350-490)
150 (310)
17
Coal-fired pulp dryer
Multiple cyclones and
stack filter system
Filterable PM
12
A
0.25-0.35 (0.50-0.70)
0.31 (0.61)
17
Coal-fired pulp dryer
Multiple cyclones and
stack iilter system
Condensible organic PM
12
A
0.037-0.086 (0.073-0.17)
0.052 (0.10)
17
Coal-fired pulp dryer
Multiple cyclones and
stack filter system
co2
12
A
130-180 (250-350)
150 (300)
17
Sugar cooler
Venturi scrubber
Filterable PM
3
A
0.028-0.040 (0.056-0.080)
0.032 (0.065)
19
Sugar cooler
Venturi scrubber
Condensible organic PM
3
A
0.0013-0.0026
(0.0026-0.0051)
0.0021 (0.0042)
19

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TABLE 4-2. (continued)
Source
Control device
Pollutant
No.
of
test
runs
Data
rating
Emission factor
range, kg/Mg (lb/ton)
Average emission
factor, kg/Mg
(lb/ton)
Ref.
No.
Sugar cooler
Venturi scrubber
Condensible inorganic PM
3
A
0.0012-0.0035
(0.0024-0.0070)
0.0024 (0.0047)
19
Coal-fired pulp dryer6
Multiple cyclones
Filterable PM
3
A
0.23-0.33 (0.45-0.66)
0.28 (0.57)
20
Coal-fired pulp dryer6
Multiple cyclones
Condensible organic PM
3
A
0.027-0.031 (0.053-0.062)
0.029 (0.058)
20
Coal-fired pulp dryer6
Multiple cyclones
co2
3
A
180-210 (350-420)
200 (390)
20
Coal-fired pulp dryer6
Multiple cyclones
so2
3
A
0.085-0.10 (0.17-0.21)
0.092 (0.18)
20
Coal-fired pulp dryer6
Multiple cyclones
NOx
3
A
0.34-0.39 (0.67-0.78)
0.37 (0.74)
20
Coal-fired pulp dryer6
Multiple cyclones
VOC as methane
3
A
0.54-0.65 (1.1-1.3)
0.59 (1.2)
20
Coal-fired pulp dryer6
Multiple cyclones
CO
3
A
1.0-1.2 (2.1-2.4)
1.1 (2.3)
20
Sugar cooler
Rotoclone
Filterable PM
3
A
0.061-0.074 (0.12-0.15)
0.066 (0.13)
21
Sugar cooler
Rotoclone
Condensible organic PM
3
A
0.0019-0.0025
(0.0037-0.0051)
0.0022 (0.0043)
21
Sugar granulator
Rotoclone
Filterable PM
3
A
0.017-0.046 (0.034-0.092)
0.032 (0.064)
21
Sugar granulator
Rotoclone
Condensible organic PM
3
A
0.0015 0.0021
(0.0030-0.0041)
0.0018 (0.0037)
21
Coal-fired pulp dryer
Multiple cyclones and
stack filter system
Filterable PM
5
A
0.21-0.29 (0.42-0.58)
0.26 (0.52)
22
Coal-fired pulp dryer
Multiple cyclones and
stack filter system
Condensible organic PM
5
A
0.066-0.096 (0.13-0.19)
0.086 (0.17)
22
Coal-fired pulp dryer
Multiple cyclones and
stack filter system
co2
5
A
230-260 (470-520)
240 (490)
22
Coal-fired pulp dryer
Multiple cyclones and
stack filter system
Filterable PM
9
A
0.17-0.24 (0.34-0.48)
0.21 (0.42)
22
Coal-fired pulp dryer
Multiple cyclones and
stack filter system
Condensible organic PM
9
A
0.040-0.059 (0.081-0.12)
0.047 (0.095)
22
Coal-fired pulp dryer
Multiple cyclones and
stack filter system
co2
9
A
120-160 (240-320)
140 (280)
22
Natural gas-fired pulp
dryer
Multiple cyclones and
gas recirculation
Filterable PM
3
A
0.29-0.44 (0.58-0.87)
0.38 (0.77)
23

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TABLE 4-2. (continued)
Source
Control device
Pollutant
No.
of
test
runs
Data
rating
Emission factor
range, kg/Mg (lb/ton)
Average emission
factor, kg/Mg
(lb/ton)
Ref.
No.
Natural gas-fired pulp
dryer
Multiple cyclones and
gas recirculation
co2
3
A
65-100 (130-210)
80 (160)
23
Natural gas-fired pulp
dryer
Multiple cyclones and
gas recirculation
Filterable PM
4
A
0.18-0.43 (0.36-0.85)
0.30 (0.60)
24
Natural gas-fired pulp
dryer
Multiple cyclones and
gas recirculation
co2
4
A
87-180 (170-360)
120 (230)
24
Oil-fired pulp dryer
Multiple cyclones and
fuel gas aspiration
Filterable PM
3
A
0.30-0.34 (0.61-0.67)
0.32 (0.65)
25
Oil-fired pulp dryer
Multiple cyclones and
fuel gas aspiration
co2
3
A
180-210 (350-410)
190 (380)
25
Natural gas-fired pulp
dryer
Wet scrubber
Filterable PM
3
B
0.16-0.21 (0.32-0.42)
0.18 (0.36)
26
Natural gas-fired pulp
dryer
Wet scrubber
Condensible inorganic PM
3
B
0.0029-0.0087 (0.0058-
0.017)
0.0052 (0.011)
26
Natural gas-fired pulp
dryer
Wet scrubber
co2
3
B
135-237 (270-474)
170 (340)
26
aEmission factor units are kg (lb) of pollutant per Mg (ton) of pressed wet pulp to the dryer, unless noted. ND = no data available. NP = pollutant not
detected.
NR = not rated.
'Emission factor units are lb per 1,000 gallons of raw juice produced.
cEmission factor units are lb per 1,000 gallons of thin juice produced.
dDryer is the same unit for which data are reported in Reference 20.
eDryer is the same as one of the units for which data are reported in Reference 16.

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TABLE 4-3. SUMMARY OF EMISSION FACTORS FOR SUGARBEET PROCESSING3
Source
Control device
Pollutant
No.
of
tests
Emissio
n factor
rating
Emission factor
range, kg/Mg (lb/ton)
Average emission
factor, kg/Mg (lb/ton)
Ref. Nos.
Coal-fired pulp dryer
None
Filterable PM
1
D
NA
2.2 (4.4)
17
Coal-fired pulp dryer
Multiple cyclones
Filterable PM
8
B
0.21-0.59 (0.42-1.2)
0.33 (0.66)
4,16,17,20,22
Coal-fired pulp dryer
Wet scrubberb
Filterable PM
3
D
0.17-0.36 (0.34-0.72)
0.25 (0.49)
5,12
Natural gas-fired pulp
dryer
Multiple cyclones
Filterable PM
2
D
0.30-0.38 (0.60-0.77)
0.34 (0.69)
23,24
Natural gas-fired pulp
dryer
Wet scrubber'
Filterable PM
6
D
0.038-0.18 (0.075-0.36)
0.097 (0.19)
6-10,26
Oil-fired pulp dryer
Cyclone
Filterable PM
3
C
0.64-0.79 (1.3-1.6)
0.72 (1.4)
1,2,14
Oil-fired pulp dryer
Dry scrubber and
cyclone
Filterable PM
2
D
0.38-0.76 (0.77-1.5)
0.57 (1.1)
13
Oil-fired pulp dryer
Multiple cyclones
Filterable PM
2
D
0.27-0.32 (0.55-0.65)
0.30 (0.60)
15,25
Sugar cooler
Rotoclone
Filterable PM
1
D
NA
0.066 (0.13)
21
Sugar cooler
Venturi scrubber
Filterable PM
1
D
NA
0.032 (0.065)
19
Sugar granulator
Rotoclone
Filterable PM
1
D
NA
0.032 (0.064)
21
Sugar dryer and cooler
Wet scrubber
Filterable PM
1
NR
NA
0.018 (0.035)
3
Oil-fired pulp dryer
Dry scrubber and
cyclone
Filterable PM-10
2
D
0.23-0.59 (0.47-1.2)
0.41 (0.83)
13
Coal-fired pulp dryer
Wet scrubber15
Condensible inorganic
PM
1
D
NA
0.025 (0.050)
12
Natural gas-fired pulp
dryer
Wet scrubber
Condensible inorganic
PM
3
D
0.0052-0.014
(0.011 0.027)
0.009 (0.018)
9,10,26
Oil-fired pulp dryer
Cyclone
Condensible inorganic
PM
3
C
0.014 0.27 (0.027-0.55)
0.12 (0.24)
1,2,13, 14
Sugar cooler
Venturi scrubber
Condensible inorganic
PM
1
D
NA
0.0024 (0.0047)
19
Coal-fired pulp dryer
Multiple cyclones
Condensible organic PM
7
C
0.019-0.086 (0.039-
0.17)
0.042 (0.084)
16,17, 20,22
Oil-fired pulp dryer
Cyclone
Condensible organic PM
3
C
0.016-0.054
(0.032-0.11)
0.038 (0.076)
1,2,14

-------
TA]
BLE 4-3.
continued)
Source
Control device
Pollutant
No. of
tests
Emission
factor
rating
Emission factor
range, kg/Mg (lb/ton)
Average emission
factor, kg/Mg (lb/ton)
Ref. Nos.
Coal-fired pulp dryer
Wet scrubber
Condensible PM
2
D
0.17-0.23 (0.33-0.47)
0.20 (0.40)
5
Coal-fired pulp dryer
C
VOC as methane
1
D
NA
0.59 (1.2)
20
Oil-fired pulp dryer
C
VOC as methane
1
D
NA
0.055 (0.11)
14
Oil-fired pulp dryer
c
Methane
1
D
NA
0.014 (0.028)
14
Coal-fired pulp dryer
c
CO
1
D
NA
1.1 (2.3)
20
Oil-fired pulp dryer
c
CO
1
D
NA
0.51 (1.0)
14
Coal-fired pulp dryer
c
co2
10
B
130-240 (260-490)
180 (370)
4,12,16,17,
20,22
Natural gas-fired pulp
dryer
c
co2
8
C
29-170 (58-340)
78 (156)
6 10,23,24,26
Oil-fired pulp dryer
c
co2
6
C
170-290 (330-570)
210 (430)
1,2,13,14,25
Sugar dryer and cooler
c
co2
1
NR
NA
Negligible
3
Coal-fired pulp dryer
c
NOx
2
D
0.28-0.37 (0.57-0.74)
0.33 (0.66)
16,20
Oil-fired pulp dryer
c
NOx
1
D
NA
0.30 (0.60)
14
Coal-fired pulp dryer
c
so2
2
D
0.092-0.68 (0.18-1.4)
0.40 (0.79)
4,20
Oil-fired pulp dryer
c
so2
3
D
0.31-0.65 (0.63-1.3)
0.52 (1.0)
13,15
Coal-fired pulp dryer
Wet scrubber
Acetaldehyde
2
E
0.0065-0.0080
(0.013 0.016)
0.0073 (0.015)
5
Coal-fired pulp dryer
Wet scrubber
Acrolein
2
E
0.0030-0.0046
(0.0060-0.0092)
0.0038 (0.0076)
5
Coal-fired pulp dryer
Wet scrubber
Crotonaldehyde
2
E
0.00080-0.0012
(0.0016-0.0024)
0.0010 (0.0020)
5
Coal-fired pulp dryer
Wet scrubber
Formaldehyde
2
E
0.0030-0.0042
(0.0059-0.0083)
0.0036 (0.0071)
5
Second carbonation tankd
None
Acetaldehyde
1
E
NA
0.0043
5
Second carbonation tankd
None
Acrolein
1
E
NA
2.4x10"
5
Second carbonation tankd
None
Crotonaldehyde
1
E
NA
3.0x10 5
5

-------
TABLE 4-3. (continued)
Source
Control device
Pollutant
No. of
tests
Emission
factor
rating
Emission factor
range, kg/Mg (lb/ton)
Average emission
factor, kg/Mg (lb/ton)
Ref. Nos.
Second carbonation tankd
None
Formaldehyde
1
E
NA
1.6x10 5
5
First evaporator6
None
Acetaldehyde
2
E
2.4x10 5-l.lxl0 4
6.7x10 5
5
First evaporator0
None
Acrolein
2
E
1.5x10 7-6.8xl0 7
4.2x10 7
5
First evaporator6
None
Crotonaldehyde
2
E
9.5x10 8-1.9xl0 7
1.4x10 7
5
First evaporator0
None
Formaldehyde
2
E
1.0x10 7-1.3xl06
7.0x10 7
5
Coal-fired pulp dryer
Wet scrubber
2 -methylnaphthalene
1
E
NA
8.5x10 6 (1.7x10 5)
5
Coal-fired pulp dryer
Wet scrubber
2-nitrophenol
1
E
NA
9.0x10 5 (0.00018)
5
Coal-fired pulp dryer
Wet scrubber
2-methylphenol
1
E
NA
1.7x10 5 (3.4x10 5)
5
Coal-fired pulp dryer
Wet scrubber
2,4-dimethylphenol
1
E
NA
1.3x10 5 (2.5x10 5)
5
Coal-fired pulp dryer
Wet scrubber
4-methylphenol
1
E
NA
6.5x10 5 (0.00013)
5
Coal-fired pulp dryer
Wet scrubber
4-nitrophenol
1
E
NA
7.0x10 5 (0.00014)
5
Coal-fired pulp dryer
Wet scrubber
Acenaphthylene
1
E
NA
8.5x10 7 (1.7x10 6)
5
Coal-fired pulp dryer
Wet scrubber
Benzaldehyde
1
E
NA
0.00070 (0.0014)
5
Coal-fired pulp dryer
Wet scrubber
Benzoic acid
1
E
NA
0.0014 (0.0028)
5
Coal-fired pulp dryer
Wet scrubber
Benzyl alcohol
1
E
NA
3.6x10 5 (7.1x10 5)
5
Coal-fired pulp dryer
Wet scrubber
Bis (2-
ethylhexyl) phthalate
1
E
NA
0.00075 (0.0015)
5
Coal-fired pulp dryer
Wet scrubber
Di-n-butylphthalate
1
E
NA
2.6x10 5 (5.2x10 5)
5
Coal-fired pulp dryer
Wet scrubber
Dibenzofuran
1
E
NA
5.5x10 6 (1.1x10 5)
5
Coal-fired pulp dryer
Wet scrubber
Diethylphthalate
1
E
NA
4.9x10 6 (9.8x10 6)
5
Coal-fired pulp dryer
Wet scrubber
Naphthalene
1
E
NA
5.5x10 5 (0.00011)
5
Coal-fired pulp dryer
Wet scrubber
Nitrobenzene
1
E
NA
9.5x10 6 (1.9x10 5)
5
Coal-fired pulp dryer
Wet scrubber
Phenanthrene
1
E
NA
6.0x10 6 (1.2x10 5)
5
Coal-fired pulp dryer
Wet scrubber
Phenol
1
E
NA
0.00016 (0.00032)
5

-------
TABLE 4-3. (continuedO
Source
Control device
Pollutant
No. of
tests
Emission
factor
rating
Emission factor
range, kg/Mg (lb/ton)
Average emission
factor, kg/Mg (lb/ton)
Ref. Nos.
First carbonation tankd
None
2-methylnaphthalene
1
D
NA
5.1x10 7
5
First carbonation tankd
None
2, 4-dinitrophenol
1
D
NA
NP
5
First carbonation tankd
None
4-methylphenol
1
D
NA
6.6x10 7
5
First carbonation tankd
None
Acenaphthene
1
D
NA
NP
5
First carbonation tankd
None
Benzaldehyde
1
D
NA
1.1x10 4
5
First carbonation tankd
None
Benzoic acid
1
D
NA
8.4x10 6
5
First carbonation tankd
None
Benzyl alcohol
1
D
NA
5.0x10 6
5
First carbonation tankd
None
Bis (2-
ethylhexyl) phthalate
1
D
NA
1.2x10 5
5
First carbonation tankd
None
Naphthalene
1
D
NA
2.0x10 6
5
First carbonation tankd
None
Phenanthrene
1
D
NA
1.4x10 6
5
First carbonation tankd
None
Phenol
1
D
NA
1.3x10 6
5
First evaporator0
None
4-methylphenol
1
E
NA
NP
5
First evaporator6
None
Benzaldehyde
1
E
NA
2.2x10 6
5
First evaporator0
None
Benzoic acid
1
E
NA
NP
5
First evaporator6
None
Benzyl alcohol
1
E
NA
1.8x10 7
5
First evaporator0
None
Bis (2-
ethylhexyl) phthalate
1
E
NA
3.7x10 7
5
First evaporator0
None
Di-n-butylphthalate
1
E
NA
1.1x10 9
5
First evaporator0
None
Dibenzofuran
1
E
NA
NP
5
First evaporator0
None
Diethylphthalate
1
E
NA
NP
5
First evaporator0
None
Isophorone
1
E
NA
NP
5
First evaporator0
None
Naphthalene
1
E
NA
2.5x10 8
5
First evaporator0
None
Phenanthrene
1
E
NA
1.6x10 8
5
First evaporator0
None
Phenol
1
E
NA
1.2x10 8
5

-------
TABLE 4-3. (continued)
Source
Control device
Pollutant
No. of
tests
Emission
factor
rating
Emission factor
range, kg/Mg (lb/ton)
Average emission
factor, kg/Mg (lb/ton)
Ref. Nos.
First evaporator6
None
Pyridine
1
E
NA
3.4x10 8
5
aEmission factor units are kg (lb) of pollutant per Mg (ton) of pressed wet pulp to the dryer, unless noted. NA = not applicable. NP = pollutant not detected.
NR = not rated.
'Emission factor includes data for dryers controlled by a cyclone or multiple cyclones, followed by a wet scrubber.
cBecause the control devices typically used to control beet pulp dryer emissions are not specifically designed to control gaseous emissions, this emission factor is
assumed to be applicable to dryers controlled by a cyclone, multiple cyclones, a wet scrubber, a venturi scrubber, or any combination of these control devices.
dEmission factor units are lb per 1,000 gallons of raw juice produced.
eEmission factor units are lb per 1,000 gallons of thin juice produced.
I
NJ

-------
An emission factor for filterable PM emissions from a natural gas-fired pulp dryer controlled
with multiple cyclones and gas recirculation systems was developed using A-rated data from two tests
conducted at two facilities. Different aspiration rates were used at each facility. The data range from
0.30 kg/Mg (0.60 lb/ton) to 0.38 kg/Mg (0.77 lb/ton) and average 0.34 kg/Mg (0.69 lb/ton). This
candidate emission factor is assigned a D rating because it was developed using data from only 2 of the
31 sugarbeet processing plants currently operating in the United States.
An emission factor for filterable PM emissions from a natural gas-fired pulp dryer controlled
with a wet scrubber was developed using A- and B-rated data from six tests conducted on six different
dryers. The dryers are located at three facilities. The data range from 0.038 kg/Mg (0.075 lb/ton) to
0.18 kg/Mg (0.36 lb/ton) and average 0.097 kg/Mg (0.19 lb/ton). This candidate emission factor is
assigned a D rating because it was developed using data from only 3 of the 31 sugarbeet processing
plants currently operating in the United States.
An emission factor for filterable PM emissions from a fuel oil-fired pulp dryer controlled with a
cyclone was developed using B-rated data from three tests conducted at three facilities. The data range
from 0.64 kg/Mg (1.3 lb/ton) to 0.79 kg/Mg (1.6 lb/ton) and average 0.72 kg/Mg (1.4 lb/ton). This
candidate emission factor is assigned a C rating because it was developed using data from 3 of the 31
sugarbeet processing plants currently operating in the United States.
An emission factor for filterable PM emissions from a fuel oil-fired pulp dryer controlled with a
dry scrubber followed by a cyclone was developed using A- and B-rated data from tests conducted on
two dryers located at the same facility. The data range from 0.38 kg/Mg (0.77 lb/ton) to 0.76 kg/Mg
(1.5 lb/ton) and average 0.57 kg/Mg (1.1 lb/ton). This candidate emission factor is assigned a D rating
because it was developed using data from only 1 of the 31 sugarbeet processing plants currently operating
in the United States.
An emission factor for filterable PM emissions from a fuel oil-fired pulp dryer controlled with
multiple cyclones was developed using A- and B-rated data from two tests conducted at different
facilities. The data range from 0.27 kg/Mg (0.55 lb/ton) to 0.32 kg/Mg (0.65 lb/ton) and average
0.30 kg/Mg (0.60 lb/ton). This candidate emission factor is assigned a D rating because it was developed
using data from only 2 of the 31 sugarbeet processing plants currently operating in the United States.
An emission factor for filterable PM emissions from a sugar cooler controlled with a mechanical
centrigual separator with water sprays was developed using A-rated data from a single test. The emission
factor is 0.066 kg/Mg (0.13 lb/ton). This emission factor is assigned a D rating because it was developed
using data from only a single test.
An emission factor for filterable PM emissions from a sugar cooler controlled with a venturi
scrubber was developed using A-rated data from a single test. The emission factor is 0.032 kg/Mg
(0.065 lb/ton). This emission factor is assigned a D rating because it was developed using data from only
a single test.
An emission factor for filterable PM emissions from a sugar granulator controlled with a
mechanical centrigual separator with water sprays was developed using A-rated data from a single test.
The emission factor is 0.032 kg/Mg (0.064 lb/ton). This emission factor is assigned a D rating because it
was developed using data from only a single test.
An emission factor for filterable PM emissions from a sugar granulator and cooler controlled
with a wet scrubber was developed using B-rated data from a single test. The data are not used for
emission factor development because the emission source is a combined source and data are available for
the individual sources.
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4.3.2 Filterable PM-10
An emission factor for filterable PM-10 emissions from a fuel oil-fired pulp dryer controlled with
a dry scrubber followed by a cyclone was developed using B-rated data from tests conducted on two
dryers located at the same facility. The data range from 0.23 kg/Mg (0.47 lb/ton) to 0.59 kg/Mg
(1.2 lb/ton) and average 0.41 kg/Mg (0.83 lb/ton). This candidate emission factor is assigned a D rating
because it was developed using data from only 1 of the 31 sugarbeet processing plants currently operating
in the United States.
4.3.3 Condensible PM
An emission factor for condensible inorganic PM emissions from a coal-fired pulp dryer
controlled with a wet scrubber was developed using A-rated data from a single test. The emission factor
is 0.025 kg/Mg (0.050 lb/ton). This emission factor is assigned a D rating because it was developed
using data from only a single test.
An emission factor for condensible inorganic PM emissions from a natural gas-fired pulp dryer
controlled with a wet scrubber was developed using B-rated data from tests conducted on three dryers
located at two facilities. The data range from 0.0052 kg/Mg (0.011 lb/ton) to 0.014 kg/Mg (0.027 lb/ton)
and average 0.009 kg/Mg (0.018 lb/ton). This candidate emission factor is assigned a D rating because it
was developed using data from only 2 of the 31 sugarbeet processing plants currently operating in the
United States.
An emission factor for condensible inorganic PM emissions from a fuel oil-fired pulp dryer
controlled with a cyclone was developed using B-rated data from five tests conducted at four facilities.
Two of the dryers were equipped with a dry scrubber and a cyclone, but the condensible inorganic PM
emissions from these two dryers were greater than the emissions from the cyclone-controlled dryers.
Therefore, the dry scrubber was assumed to have no effect on condensible inorganic PM emissions, and
the data were combined. The data range from 0.014 kg/Mg (0.027 lb/ton) to 0.27 kg/Mg (0.55 lb/ton)
and average 0.12 kg/Mg (0.24 lb/ton). This candidate emission factor is assigned a C rating because it
was developed using data from 4 of the 31 sugarbeet processing plants currently operating in the United
States.
An emission factor for condensible inorganic PM emissions from a sugar cooler controlled with a
venturi scrubber was developed using A-rated data from a single test. The emission factor is
0.0024 kg/Mg (0.0047 lb/ton). This emission factor is assigned a D rating because it was developed
using data from only a single test.
An emission factor for condensible organic PM emissions from a coal-fired pulp dryer controlled
with multiple cyclones was developed using A-rated data from seven tests conducted on seven different
dryers. The dryers are located at three facilities. The data range from 0.019 kg/Mg (0.039 lb/ton) to
0.086 kg/Mg (0.17 lb/ton) and average 0.042 kg/Mg (0.084 lb/ton). This candidate emission factor is
assigned a C rating because it was developed using data from 3 of the 31 sugarbeet processing plants
currently operating in the United States.
An emission factor for condensible organic PM emissions from a fuel oil-fired pulp dryer
controlled with a cyclone was developed using B-rated data from three tests conducted at three facilities.
The data range from 0.016 kg/Mg (0.032 lb/ton) to 0.054 kg/Mg (0.11 lb/ton) and average 0.038 kg/Mg
(0.076 lb/ton). This candidate emission factor is assigned a C rating because it was developed using data
from 3 of the 31 sugarbeet processing plants currently operating in the United States.
An emission factor for condensible organic PM emissions from a sugar cooler controlled with a
mechanical centrigual separator with water sprays was developed using A-rated data from a single test.
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The emission factor is 0.0022 kg/Mg (0.0043 lb/ton). This emission factor is assigned a D rating because
it was developed using data from only a single test.
An emission factor for condensible organic PM emissions from a sugar cooler controlled with a
venturi scrubber was developed using A-rated data from a single test. The emission factor is
0.0021 kg/Mg (0.0042 lb/ton). This emission factor is assigned a D rating because it was developed
using data from only a single test.
An emission factor for condensible organic PM emissions from a sugar granulator controlled
with a mechanical centrigual separator with water sprays was developed using A-rated data from a single
test. The emission factor is 0.0018 kg/Mg (0.0037 lb/ton). This emission factor is assigned a D rating
because it was developed using data from only a single test.
An emission factor for total condensible PM emissions from a coal-fired pulp dryer controlled
with a wet scrubber was developed using A- and B-rated data from two tests conducted on different
dryers located at the same facility. The data range from 0.17 kg/Mg (0.33 lb/ton) to 0.23 kg/Mg
(0.47 lb/ton) and average 0.20 kg/Mg (0.40 lb/ton). This candidate emission factor is assigned a D rating
because it was developed using data from only 2 of the 31 sugarbeet processing plants currently operating
in the United States.
4.3.4	Volatile Organic Compounds
An emission factor for VOC emissions from a coal-fired pulp dryer was developed using A-rated
data from a single test. The emission factor is 0.59 kg/Mg (1.2 lb/ton). Because the control devices
typically used to control beet pulp dryer emissions are not designed to control VOC emissions, this
emission factor is assumed to be applicable to coal-fired dryers controlled by a cyclone, multiple
cyclones, a wet scrubber, a venturi scrubber, or any combination of these control devices. This emission
factor is assigned a D rating because it was developed using data from only a single test.
An emission factor for VOC emissions from a fuel oil-fired pulp dryer was developed using
B-rated data from a single test. The emission factor is 0.055 kg/Mg (0.11 lb/ton). Because the control
devices typically used to control beet pulp dryer emissions are not designed to control VOC emissions,
this emission factor is assumed to be applicable to fuel oil-fired dryers controlled by a cyclone, multiple
cyclones, a wet scrubber, a venturi scrubber, or any combination of these control devices. This emission
factor is assigned a D rating because it was developed using data from only a single test.
4.3.5	Methane
An emission factor for methane emissions from a fuel oil-fired pulp dryer was developed using
B-rated data from a single test. The emission factor is 0.014 kg/Mg (0.028 lb/ton). Because the control
devices typically used to control beet pulp dryer emissions are not designed to control methane emissions,
this emission factor is assumed to be applicable to fuel oil-fired dryers controlled by a cyclone, multiple
cyclones, a wet scrubber, a venturi scrubber, or any combination of these control devices. This emission
factor is assigned a D rating because it was developed using data from only a single test.
4.3.6	Carbon Monoxide
An emission factor for CO emissions from a coal-fired pulp dryer was developed using A-rated
data from a single test. The emission factor is 1.1 kg/Mg (2.3 lb/ton). Because the control devices
typically used to control beet pulp dryer emissions are not designed to control CO emissions, this
emission factor is assumed to be applicable to coal-fired dryers controlled by a cyclone, multiple
cyclones, a wet scrubber, a venturi scrubber, or any combination of these control devices. This emission
factor is assigned a D rating because it was developed using data from only a single test.
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An emission factor for CO emissions from a fuel oil-fired pulp dryer was developed using
B-rated data from a single test. The emission factor is 0.51 kg/Mg (1.0 lb/ton). Because the control
devices typically used to control beet pulp dryer emissions are not designed to control CO emissions, this
emission factor is assumed to be applicable to fuel oil-fired dryers controlled by a cyclone, multiple
cyclones, a wet scrubber, a venturi scrubber, or any combination of these control devices. This emission
factor is assigned a D rating because it was developed using data from a single test.
4.3.7	Carbon Dioxide
An emission factor for C02 emissions from a coal-fired pulp dryer was developed using A-rated
data from ten tests conducted on nine different dryers. The dryers are located at five facilities. The data
range from 130 kg/Mg (260 lb/ton) to 240 kg/Mg (490 lb/ton) and average 180 kg/Mg (370 lb/ton).
Because the control devices typically used to control beet pulp dryer emissions are not designed to
control C02 emissions, this emission factor is assumed to be applicable to coal-fired dryers controlled by
a cyclone, multiple cyclones, a wet scrubber, a venturi scrubber, or any combination of these control
devices. This candidate emission factor is assigned a B rating because it was developed using A-rated
data from 5 of the 31 sugarbeet processing plants currently operating in the United States.
An emission factor for C02 emissions from a natural gas-fired pulp dryer was developed using A-
and B-rated data from eight tests conducted on eight different dryers. The dryers are located at five
facilities. The data range from 29 kg/Mg (58 lb/ton) to 170 kg/Mg (340 lb/ton) and average 78 kg/Mg
(156 lb/ton). Because the control devices typically used to control beet pulp dryer emissions are not
designed to control C02 emissions, this emission factor is assumed to be applicable to natural gas-fired
dryers controlled by a cyclone, multiple cyclones, a wet scrubber, a venturi scrubber, or any combination
of these control devices. This candidate emission factor is assigned a C rating because it was developed
using A- and B-rated data from 5 of the 31 sugarbeet processing plants currently operating in the United
States.
An emission factor for C02 emissions from a fuel oil-fired pulp dryer was developed using A-
and B-rated data from six tests conducted on six different dryers. The dryers are located at four facilities.
The data range from 170 kg/Mg (330 lb/ton) to 290 kg/Mg (570 lb/ton) and average 210 kg/Mg
(430 lb/ton). Because the control devices typically used to control beet pulp dryer emissions are not
designed to control C02 emissions, this emission factor is assumed to be applicable to fuel oil-fired
dryers controlled by a cyclone, multiple cyclones, a wet scrubber, a venturi scrubber, or any combination
of these control devices. This candidate emission factor is assigned a C rating because it was developed
using A- and B-rated data from 4 of the 31 sugarbeet processing plants currently operating in the United
States.
Carbon dioxide emissions from a sugar granulator and cooler were measured during one test and
were negligible during all of the test runs.
4.3.8	Nitrogen Oxides
An emission factor for NOx emissions from a coal-fired pulp dryer was developed using A-rated
data from two tests conducted on the same dryer. The data range from 0.28 kg/Mg (0.57 lb/ton) to
0.37 kg/Mg (0.74 lb/ton) and average 0.33 kg/Mg (0.66 lb/ton). Because the control devices typically
used to control beet pulp dryer emissions are not designed to control NOx emissions, this emission factor
is assumed to be applicable to coal-fired dryers controlled by a cyclone, multiple cyclones, a wet
scrubber, a venturi scrubber, or any combination of these control devices. This emission factor is
assigned a D rating because it was developed using data from only a single facility.
An emission factor for NOx emissions from a fuel oil-fired pulp dryer was developed using
B-rated data from a single test. The emission factor is 0.30 kg/Mg (0.60 lb/ton). Because the control
devices typically used to control beet pulp dryer emissions are not designed to control NOx emissions,
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this emission factor is assumed to be applicable to fuel oil-fired dryers controlled by a cyclone, multiple
cyclones, a wet scrubber, a venturi scrubber, or any combination of these control devices. This emission
factor is assigned a D rating because it was developed using data from only a single test.
4.3.9	Sulfur Dioxide
An emission factor for S02 emissions from a coal-fired pulp dryer was developed using A-rated
data from two tests conducted at different facilities. The data range from 0.092 kg/Mg (0.18 lb/ton) to
0.68 kg/Mg (1.4 lb/ton) and average 0.40 kg/Mg (0.79 lb/ton). Because the control devices typically used
to control beet pulp dryer emissions are not specifically designed to control S02 emissions, this emission
factor is assumed to be applicable to coal-fired dryers controlled by a cyclone, multiple cyclones, a wet
scrubber, a venturi scrubber, or any combination of these control devices. Wet scrubbers on coal-fired
boilers at beet sugar facilities may show up to 50 to 70 percent efficiency for S02 control; wet scrubbers
on coal-fired dryers may also achieve some level of S02 control. This emission factor is assigned a D
rating because it was developed using data from only 2 of the 31 sugarbeet processing plants currently
operating in the United States..
An emission factor for S02 emissions from a fuel oil-fired pulp dryer was developed using A-and
B-rated data from three tests conducted on three different dryers. The dryers are located at two facilities.
One other test included S02 measurements, but S02 emissions were not detected; the data from this
additional test are not used for emission factor development because the other three tests document levels
of S02 that are well above the detection limit of the test method. The data range from 0.31 kg/Mg
(0.63 lb/ton) to 0.65 kg/Mg (1.3 lb/ton) and average 0.52 kg/Mg (1.0 lb/ton). Because the control devices
typically used to control beet pulp dryer emissions are not designed to control S02 emissions, this
emission factor is assumed to be applicable to fuel oil-fired dryers controlled by a cyclone, multiple
cyclones, a wet scrubber, a venturi scrubber, or any combination of these control devices. This emission
factor is assigned a D rating because it was developed using data from only 2 of the 31 sugarbeet
processing plants currently operating in the United States.
4.3.10	Acetaldehvde. Acrolein. Crotonaldehvde. Formaldehyde
Emission factors for acetaldehyde, acrolein, crotonaldehyde, and formaldehyde emissions from a
coal-fired pulp dryer controlled with a wet scrubber were developed using C-rated data from two tests
conducted on two dryers located at the same facility. These emission factors are assigned an E rating
because they are based on C-rated data.
Emission factors for acetaldehyde, acrolein, crotonaldehyde, and formaldehyde emissions from a
second carbonation tank were developed using C-rated data from a single test. These emission factors are
assigned an E rating because they are based on C-rated data. The units for these emission factors are
pounds of pollutant per 1,000 gallons of raw juice produced.
Emission factors for acetaldehyde, acrolein, crotonaldehyde, and formaldehyde emissions from a
first evaporator were developed using C-rated data from two tests. These emission factors are assigned
an E rating because they are based on C-rated data. The units for these emission factors are pounds of
pollutant per 1,000 gallons of thin juice produced.
4.3.11	Semivolatile Organic Compounds
Emission factors for speciated SVOC emissions from a coal-fired pulp dryer controlled with a
wet scrubber were developed using C-rated data from a single test. These emission factors are assigned
an E rating because they are based on C-rated data.
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Emission factors for speciated SVOC emissions from a first carbonation tank were developed
using B-rated data from a single test. These emission factors are assigned a D rating because they are
based on data from only a single test.
Emission factors for speciated SVOC emissions from a first evaporator were developed using
C-rated data from a single test. These emission factors are assigned an E rating because they are based on
C-rated data.
4.4 SUMMARY OF DEVELOPMENT OF AP-42 SECTION
4.4.1	Section Narrative
A process description was written using the most recent available references, and a process flow
diagram was developed from the process description. In addition, emissions from sugarbeet processing
operations and types of emission control systems currently in use are discussed.
4.4.2	Emission Factors
The emission factors discussed in section 4.3 of this report are presented in the proposed AP-42
Section 9.10.1.2, Sugarbeet Processing.
REFERENCES FOR SECTION 4
1.	Results of a Source Emission Compliance Test at Southern Minnesota Beet Sugar Cooperative,
Renville, Minnesota, MMT Environmental, Inc., St. Paul, MN, January 21, 1988.
2.	Results of an Emission Compliance Test on the North Dryer #2 at Southern Minnesota Beet Sugar
Cooperative, Renville, Minnesota, MMT Environmental, Inc., St. Paul, MN, December 14, 1988.
3.	Results of the November 18, 1986, Particulate Emission Compliance Test on the Combined
Discharge Stack of the Sugar Dryer and Sugar Cooler at the Southern Minnesota Sugar
Cooperative Plant in Renville, Minnesota, Interpoll, Inc., Circle Pines, MN, December 8, 1986.
4.	Results of a Source Emission Compliance Test at Minn-Dak Farmers Cooperative, Wahpeton,
North Dakota, MMT Environmental, Inc., St. Paul, MN, November 1, 1983.
5.	Particulate, Aldehyde, and Semi-volatile Organic Compound (SVOC) Testing Report for the Pulp
Dryer Stacks, 1st and 2nd Carbonation Tank Vents, and the Evaporator Heater Vents, The
Amalgamated Sugar Company, Nampa, Idaho, May 14, 1993.
6.	Particulate Emission Testing Performed for Monitor Bay Sugar Company, Bay City, Michigan, on
the Pulp Dryer 3 Exhaust, Network Environmental, Inc., Grand Rapids, MI, October 12, 1992.
7.	Particulate Emission Testing Performed for Monitor Bay Sugar Company, Bay City, Michigan, on
the Pulp Dryer 2 Exhaust, Network Environmental, Inc., Grand Rapids, MI, October 13, 1992.
8.	Particulate Emission Testing Performed for Monitor Bay Sugar Company, Bay City, Michigan, on
the Pulp Dryer 1 Exhaust, Network Environmental, Inc., Grand Rapids, MI, October 14, 1992.
9.	Emissions Survey Conducted at Western Sugar Company's Billings, Montana Production Facility,
American Environmental Testing Company, Inc., December 1988.
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10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
EPA Method 5 Particulate Emissions Tests Conducted on Western Sugar's Boiler and Pulp Dryer
Stacks Located in Billings, Montana, American Environmental Testing Company, Inc., January
1990.
Western Sugar—Final Report. Emissions Testing and Analysis at Billings, Montana, Refinery,
Radian Corporation, Denver, CO, March 26, 1991.
Report on Compliance Testing Performed at Western Sugar Company Pulp Dryer, Scottsbluff, NE,
Clean Air Engineering, Palatine, IL, January 12, 1990.
Emission Measurement Test Report of C.E. Boilers, Union Boilers, and Pulp Dryers—Permit
Compliance for S02, Particulate, and PM-10 with Back-Half Emissions—Holly Sugar Corporation,
Montana Division, The Emission Measurement Group, Inc., Englewood, CO, November 16, 1993.
Emission Performance Testing of Four Boilers, Three Dryers, and One Cooler—Holly Sugar
Corporation, Santa Maria, California, Western Environmental Services, Redondo Beach, CA, June
1991.
Report to Great Lakes Sugar Company on Stack Particulate Samples Collected on the Pulp Drier at
Fremont, Ohio, Affiliated Environmental Services, Inc., Sandusky, OH, December 8, 1992.
Results of the February 22-24, 1994, Air Emission Compliance Testing of Process Sources at the
American Crystal Sugar East Grand Forks Plant, Interpoll Laboratories, Inc., Circle Pines, MN,
March 21, 1994.
Results of the January 28-31, 1992, Particulate Emission Tests, South Pulp Dryer—American
Crystal Sugar Company, Moorehead, Minnesota, Bay West, Inc., St. Paul, MN, March 26, 1992.
Results of the December 1 & 2, 1992, State Air Emission Compliance Testing on the Pulp Dryers at
the American Crystal Sugar Drayton Plant, Interpoll Laboratories, Inc., Circle Pines, MN, January
7, 1993.
Results of a Source Emission Compliance Test on the Sugar Cooler Stack at American Crystal
Sugar Company, Crookston, Minnesota, March 11, 1993, Twin City Testing Corporation, St. Paul,
MN, April 16, 1993.
Results of the November 9-11, 1993, Air Emission Testing of Process Sources at the American
Crystal Sugar East Grand Forks Plant, Interpoll Laboratories, Inc., Circle Pines, MN, December 3,
1993.
Results of the November 14 and 15, 1990, State Particulate Emission Compliance Test on the Sugar
Cooler and Sugar Granulator at the ACS Moorehead Plant, Interpoll Laboratories, Inc., Circle
Pines, MN, December 11, 1990.
UnitNos. 1 and 2 Pulp Dryer Stacks Emission Testing Results for the February 22-26, 1993,
Testing of Particulate Conducted at the American Crystal Sugar Company, Crookston, Minnesota,
Bay West, Inc., St. Paul, MN, April 15, 1993.
Particulate Emission Study for Michigan Sugar Company, Caro, Michigan, Swanson
Environmental, Inc., Farmington Hills, MI, December 14, 1989.
Particulate Emission Study for Michigan Sugar Company, Carrollton, Michigan, Swanson
Environmental, Inc., Farmington Hills, MI, November 1989.
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25.	Particulate Emission Study—Michigan Sugar Company, Croswell, Michigan, Swanson
Environmental, Inc., Farmington Hills, MI, November 19, 1990.
26.	Emissions Survey Conducted at Western Sugar Company, Scottsbluff, Nebraska, American
Environmental Testing, Inc., Spanish Fork, UT, January 10, 1995.
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