Technical Support Document Identification and Discussion of Sources of Regional Point Source NOx and S02 emissions other than EGUs Tim Smith and Doug Grano EPA/OAQPS John Robbins, Kevin Culligan and Mikhail Adamantiades EPA/CAMD January 2004 Contents 1. Introduction 2. Discussion of the Emissions Inventory. Identification of Source Categories Emitting More than 1 Percent of the Regional Stationary Source Total 3. Discussion of Control Measures for S02 Source Categories 4. Discussion of Control Measures for NOx Source Categories 1 ------- 1. Introduction The purpose of this document is to discuss the currently available information on emissions and control measures for non-EGU sources of S02 and NOx other than boilers and turbines. We conducted this analysis for a region that includes the following 30 States and the District of Columbia: AL, AR, DC, DE, FL, GA, IA, IL, IN, KS, KY, LA, MA, MD, MI, MN, MO, MS, NC, ND, NJ, NY, OH, OK, PA, SC, TN, TX, VA, WI, WV. In order to gain perspective on emissions and controls from categories other than boilers and turbines, we carried out the following steps. First, we developed a year 2010 projected emissions inventory and identified source categories with the greatest emissions of S02 and NOx. For relatively high-emitting categories, we searched for available sources of information on potentially applicable control measures and their costs. 2. Discussion of the Emissions Inventory. Identification of Source Categories Emitting More than 1 Percent of the Regional Stationary Source Total For this analysis, we used a projected year 2010 inventory [projected from a 1996 base year inventory as described in a document entitled "Air Quality Modeling Technical Support Document for the Proposed Interstate Air Quality Rule (January 2004)]." We produced a spreadsheet that includes all the point source emissions units of S02 and NOx in the 30-State plus D.C. geographic area described above. This spreadsheet is included in the docket, and is entitled "30 State plus DC 2010 combined nonEGU unit level sorted by NOx and S02 zero emitting taken out." Summaries of the inventory are shown in Table 1 (S02 summary) and Table 2 (NOx summary). In examining non-EGU categories for emission reduction opportunities, we identified categories emitting more than one percent of the overall projected S02 or NOx year 2010 emissions inventory for the geographic area of interest (30 States plus the District of Columbia). For S02, the total projected year 2010 emissions from stationary sources in this 30-State region are about 13 million tons. For NOx, the total is 6 million tons. Accordingly for S02, one percent of the inventory is 130,000 tons per year, and for NOx, one percent of the inventory is 60,000 tons per year. Tables 1 and 2 show, in bold, the source categories that meet or exceed these levels. In listing source categories for these tables, we attempted to define logical groupings of industries or equipment using the source classification codes (SCCs). 2 ------- Table 1. Projected Year 2010 Sulfur Dioxide Emissions for non-Utility Point Source in 30 States + the District of Colum bia EMISSIONS CATEGORY/ SCCs included in the category Projected Year 2010 S02 EMISSIONS (tons per year) % OF TOTAL POINT SOURCE EMISSIONS (12,625,000 tons/yr) Boilers 102XXXXX -Industrial Boilers Industrial boiler total: 1,436,000 11 103XXXXX - Commercial/Institutional Commercial/institutional total: 203,000 1.6 105XXXXX- Space Heaters Commercial/Industrial Space heater total: 1,300 < 0.1 IC engines including combustion turbines (2XXXXXXX) Engine and turbine total: 4,800 < 0.1 Industrial Processes 301XXXXX Chemical mfg (total: 322,000) 2.6 30119701 301005XX 301032XX 301023XX 301900XX 301999XX Olefin production Carbon black production Elemental sulfur production Sulfuric acid manufacturing Fuel-fired eq "Other" 1,300 50, 000 72,000 128,000 8,500 45,000 <0.1 0.4 0.6 1.0 <0.1 0.4 [all other 301'snot listed] All other 301XXXXX 15,000 0.1 302XXXXX Food and agriculture (total = 5, 100) <0.1 3 ------- EMISSIONS CATEGORY/ Projected Year 2010 % OF TOTAL SCCs included in the category S02 EMISSIONS (tons per year) POINT SOURCE EMISSIONS (12,625,000 tons/yr) 303XXXXX Primary metals (Total: 281,000) 2.2 303001XX and 303000XX Primary Aluminum 36,000 0.3 303005XX Primary copper 7, 200 <0.1 303014XX Barium Ore Processing 3,100 <0.1 303003XX By-product coke mfg 81,000 0.6 303006XX Ferroalloy 3,700 <0.1 303008XX Iron production 24,000 0.2 303009XX Steel only (not integ ir/steel) 13,000 0.1 30301OXX Primary lead 99,000 0.8 [total from those not listed] All other 303XXXXX's 14,000 0.1 304XXXXX Secondary metals (total: 40,000) 0.3 304020XX Furnace electrode mfg 15,000 0.1 304004XX Secondary lead 15,000 0.1 [total from those not listed] All other 304XXXXX's 10,000 0.1 305XXXXX Mineral products (total: 302, 000) 2.4 30500 6XX,30500 7XX, Cement-dry, wet, in process coal 192,000 1.5 39000201 39000203, 305016XX Lime - kiln, in process coal use 25,000 0.2 30501001 Coalmining cleaning matl handling 9,600 <0.1 305900XX Fuel fired eq 11,000 0.1 305014XX Glass melting furnaces 24,000 0.2 [total from those not listed] All other 305XXXXX's 40,000 0.3 306XXXXX Petroleum industry (total: 372,000) 3.0 306002XX Catalytic cracking 158,000 1.3 306009XX Flares 24,000 0.2 306008XX and 306888XX Fugitives 19,000 0.2 306099XX Incinerators 13,000 0.1 30601401 Coke Calcining 16,000 0.1 306001XX Process heaters 112,000 0.9 [total from those not listed] All other 306XXXXX's 30,000 0.3 4 ------- EMISSIONS CATEGORY/ SCCs included in the category Projected Year 2010 S02 EMISSIONS (tons per year) % OF TOTAL POINT SOURCE EMISSIONS (12,625,000 tons/yr) 307XXXXX Pulp and Paper (total: 131, 000) 1.0 30700106 30700104 and 30700110 Kraft process - Lime kiln Kraft process - Recovery furnace 6,400 102,000 <0.1 0.8 307002XX Pulp mills Sulfite process 7,200 <0.1 [total from those not listed] All other 307XXXXX's 15,000 0.1 310XXXXX Oil and gas production 93,000 0.7 399XXXX "Misc manufacturing- misc" 11,000 0.1 50XXXXXX Waste incinerators 16,000 0.1 Table 2. NOx Sources EMISSIONS CATEGORY/ SCCs included in the category Projected Year 2010 NOx EMISSIONS (tons per year) % OF TOTAL POINT SOURCE NOx (6,000,000 tons/yr) Boilers 102XXX -Industrial Boilers Industrial boiler total 770,000 13 103XXX - Commercial/Institutional Commercial/institutional total: 73,000 1.2 105XXXX- Space Heaters Commercial/Industrial Space heater total: 3,400 .1 5 ------- EMISSIONS CATEGORY/ SCCs included in the category Projected Year 2010 NOx EMISSIONS (tons per year) % OF TOTAL POINT SOURCE NOx (6,000,000 tons/yr) Internal Combustion 2XXXXXXX Total internal combustion 739,000 12 20200201,20200203,20200901, 20300102,20300202,20300702, 204003XX Combustion turbines 124,000 2.1 Remainder (assume all are IC engines) 615,000 10 Industrial processes 301XXXXX Chemical mfg (total) 184,000 301005XX 301900XX 301999XX 301003XX 301013XX Carbon black production 6,500 Fuel-fired eq 23,000 "Other" 43,000 Ammonia production 22,000 Nitric acid production 48,000 0.1 0.4 0.7 0.4 0.8 [all other 301'snot listed] All other 301XXXXX 41,500 0.7 302XXXXX Food and agriculture (total) 6,800 0.1 303XXXXX Primary metals (total) 108,000 303003XX 303900XX 303009XX 303010XX 303023XX By-product coke mfg 19,000 Fuel fired eq 7,000 Iron production 4,900 Steel only (not integ ir/steel) 24,000 Taconite 46,000 0.3 0.1 0.1 0.4 0.8 [total from those not listed] All other 303XXXXX's 7,000 0.1 304XXXXX Secondary metals 18,000 0.3 6 ------- EMISSIONS CATEGORY/ SCCs included in the category Projected Year 2010 NOx EMISSIONS (tons per year) % OF TOTAL POINT SOURCE NOx (6,000,000 tons/yr) 305XXXXX Mineral products (total:) 289,000 4.8 30500 6XX,30500 7XX, 39000201 39000203, 305016XX 30501001 Cement-dry, wet, in process coal 161,000 Lime - kiln, in process coal use 18,000 Coalmining cleaning matl handling 4,600 2.7 0.3 0.1 305014XX Glass melting furnaces 72,000 1.2 [total from those not listed] All other 305XXXXX's 33,000 0.5 306XXXXX Petroleum industry (total:) 204,000 3.4 30600401 Blowdown systems 4,600 0.1 306002XX Catalytic cracking 29,000 0.5 306009XX Flares 6,200 0.1 306001XX Process heaters 160,000 2.7 [total from those not listed] All other 306XXXXX's 4,000 0.1 307XXXXX Pulp and Paper (total) 89,000 1.5 307001XX 30700106 30700104 and 30700110 30700105 Kraft process Lime kiln Recovery furnace Smelt dissolving 18,000 47,000 9,600 o o o i^J *00 u> [total from those not listed] All other 307XXXXX's 14,000 0.2 310XXXXX Oil and gas production 57,000 1.0 390XXXXX Misc in-process fuel use 28,000 0.5 399XXXX "Misc manufacturing- misc' 11,000 0.2 50XXXXXX Waste incinerators 43,000 0.7 7 ------- 3. Discussion of Control Measures for S02 Source Categories For a number of source categories, including all of those emitting more than one percent of the point source inventory, we conducted a review to identify available controls. At this point in time, we have not developed cost estimates for these controls, and we are continuing to seek information sufficient to provide for reliable cost estimates. a. Cement Kilns For cement kilns, we identified the following potential control measures: - Fuel switching. While EPA believes it is generally infeasible for cement kilns to switch to natural gas, it may be possible to achieve relatively modest reductions in sulfur dioxide through switching to lower sulfur coal. We are seeking further information on the quantities and sulfur content of coal now used in cement kilns, to allow quantification of potential S02 reductions and their cost. - Flue gas desulfurization. We are aware of studies where others such as the Western Regional Air Partnership (WRAP) have concluded that add-on flue gas desulfurization (FGD) scrubbers are not considered cost-effective, in part due to the inherent control of S02 due to the limestone in the kiln. We are seeking any additional information relative to this category, including any engineering reviews that may have been conducted for prevention of significant deterioration (PSD) permits. b. Petroleum refinery catalytic cracking. For petroleum refinery catalytic cracking units, we note that sulfur dioxide emissions are being increasingly controlled by FGD scrubbers. Many of these FGD systems are being installed in response to settlements of refinery enforcement cases. We have not yet developed cost estimates for this category, although information maybe available to do so. At present the projected 2010 inventories on which emission reduction opportunities and reductions can be calculated do not reflect the numerous enforcement settlement agreements that are in place. Any calculations of the potential for future reduction opportunities must take this into account. c. Sulfuric acid manufacturing. For sulfuric acid manufacturing, our emission inventory source classification codes (SCCs) differentiate emissions units according to their percent recovery, as reported by the source or by the state air agency. In addition, EPA's AP-42 emission factors are related to the percent recovery The source classification codes (SCCs) for sulfuric acid manufacturing, and emission factors, for sulfuric acid manufacturing, are as follows: 8 ------- SCC Code % Recovery Emission factor, lb S02 per ton of product 3-01-023-18 93 96 3-01-023-16 94 82 3-01-023-14 95 70 3-01-023-12 96 55 3-01-023-10 97 40 3-01-023-08 98 26 3-01-023-06 99 14 3-01-023-04 99.5 7 3-01-023-01 99.7 4 We used these emissions factors and a review of emissions inventory information to obtain a preliminary estimate of the degree to which sulfuric acid manufacturing facilities could reduce their emissions by upgrading the current percent recovery sufficiently to meet the 4 lb/ton new source performance standard (NSPS). Appendix 1 shows an analysis for the potential for such reductions in an area of the eastern United States that included 28 States plus the District of Columbia. From this analysis, it appears that the potential for such reductions would appear to be about lA the current inventory. Presently, EPA notes that these estimates are somewhat uncertain. Additionally, EPA staff are not aware of any available engineering or cost analysis describing the measures and associated costs required to upgrade to the NSPS from the various possibilities for current conditions (i.e., from 93 to 99.7 percent recovery, from 97 to 99.7 percent recovery, etc). d. Industrial and Commercial Boilers There are two primary methods that industrial and commercial boilers could use to reduce emissions of S02, they could switch to lower sulfur coal or they could install post combustion emission control devices. Because EPA has limited data on the sulfur content of fuel burned by industrial and commercial boilers, EPA is unable to develop accurate estimates of the amount of emission reductions that could be obtained from switching to lower sulfur coal. The information that EPA has suggests that many of these units are not burning the lowest sulfur coal available and could therefore reduce S02 emissions by switching to lower sulfur coal. If one assumes that the 9 ------- costs that these units would incur is similar to the costs that an EGU would incur, there may be opportunities for low cost emission reductions from this sector. The costs that these units incur to switch to lower sulfur coal is dependent upon a number of factors including; cost for lower sulfur coal and cost to make any necessary modifications to the boiler needed to burn the lower sulfur coal. Because these boilers are typically owned by companies purchasing significantly less coal than the owners of EGUs, they may not be able to purchase lower sulfur coal at costs as low as the owners of EGUs. Similarly because many industrial and commercial boilers are smaller and run at lower capacity factors, the capital expenditures necessary to switch to lower sulfur coal may be higher. "Preliminary Cost Estimates for Flue Gas Conditioning Retrofits for Industrial Boilers" (located in the docket) details some of the costs an industrial boiler may incur when switching to a lower sulfur coal. EPA has similar problems making estimates about the cost of installing post combustion S02 control equipment on industrial boilers. While some industrial boilers (particularly larger boilers, that are frequently operated, that are currently burning higher sulfur coal and that have open space around them for installation of post combustion controls) may have highly cost effective emission reduction opportunities others may not. The cost of reducing S02 emissions using post combustion control equipment is highly dependant upon: the size of the boiler, the capacity factor of the unit, the sulfur content of the fuel the unit is burning and the ease (or difficulty) of installing post combustion control equipment at the unit. "Preliminary S02 Control Cost Estimates for Industrial Boilers", (located in the docket) details potential costs for post combustion S02 controls depending upon the size and capacity factor of the boiler and the sulfur content of the fuel burned by the boiler. It attempts to include the costs of such difficulty in retrofitting post combustion control devices but may not include all costs associated with such difficulty. Furthermore, EPA does not have a good understanding of the costs and operational effects of integrating post combustion S02 and NOx control technologies for these particular sources. Industrial boiler backend equipment configurations and flue gas temperatures exiting Industrial boilers are different than those generally present with EGUs. These features may also vary greatly among industrial boilers themselves, making it difficult to determine feasibility of some of these technologies and apply one single set of design criteria to them. 4. Discussion of Control Measures for NOx Source Categories As noted in table 2, [in addition to boilers and combustion turbines] there are four source categories exceeding one percent of the regionwide stationary source inventory for NOx —cement kilns, internal combustion (IC) engines, process heaters, and glass manufacturing. Unlike S02, EPA has developed more robust cost estimates for NOx controls. These estimates were discussed in EPA's NOx SIP Call rule, and they reflect in part a number of Available Control Techniques (ACT) documents developed under section 183(c) of the Clean Air Act. As shown in the following table, EPA determined the cost effectiveness of available controls for these source categories (for additional information, see the Regulatory Impact Analysis for the NOx SIP Call, Volume 1, Section 7, September 1998). 10 ------- Source category $/ton NOx reduced (ozone season 1990$) cement kilns 1,500 glass manufacturing 2,020 process heaters 2,900 stationary IC engines 1,200 The emissions budgets for EPA's NOx SIP Call rule (63 FR 57417) reflect highly cost- effective emission reductions for large cement kilns and IC engines, in addition to those for large industrial boilers and turbines. In the NOx SIP Call rule, "large" cement kilns and IC engines means sources emitting greater than one ton NOx per day (ozone season average). That is, in States covered by the NOx SIP Call rule, the required NOx budgets were calculated, in part, assuming emission reductions at large sources in these 4 source categories. At the time of the NOx SIP Call, we did not determine that highly cost effective NOx emission reductions were available from large process heaters or glass manufacturing, as their estimated cost per ton exceeded our "highly cost effective" definition of $2000 per ton (1990S). We describe below three possible approaches for obtaining NOx reductions beyond those calculated in the NOx SIP Call rule with respect to non-EGU point sources. (Non-EGU boilers and turbines are discussed later in this section.) 1. Extend the NOx SIP Call level of control to States not covered by the NOx SIP Call rule but covered by the IAQR. Under this approach, the affected statewide NOx budgets would reflect emissions reductions at large cement kilns and IC engines. This approach would affect the following States: AR, FL, IA, KS, LA, MN, MS, ND, OK, TX, & WI. We estimate the NOx emission reduction would be up to about 77,000 tons per year.1 2. Calculate emission reductions at cement kilns and IC engines which are larger than 100 tons per year. Under this approach, additional NOx emission reductions would be obtained by reducing the NOx SIP Call cutoff for IC engines and cement kilns to 100 tons/year (from 365 tons/year or 1 ton/day). Sources of this size will generally be subject to NOx control in ozone nonattainment areas under the RACT requirements of the Clean Air Act. This approach would affect the following States: AR, FL, IA, KS, LA, MN, MS, ND, OK, TX, & WI. In addition, this calculation would affect units emitting between 100-365 tons/year in following NOx SIP Call states: AL, GA, IL, IN, KY, MI, MO, NC, 1 IC engines emitting greater than 364 tons/year in the 11 states total emissions of 76,066. A 90% reduction gives a 68,459 ton/year reduction. Cement kilns emitting more than 364 tons/year in the 11 states account for 27,035 tons/year. A 30% control level results in a reduction of 8,111 tons/year. These estimates assume the units are currently uncontrolled. 11 ------- OH, SC, TN, VA, & WV. We estimate the emission reduction to be up to about 252,000 tons per year in the 11 States.2 In addition, in the NOx SIP Call States (not including OTC States which have already implemented NOx RACT) we estimate another 50,000 tons/year.3 3. Apply RACT controls in all States covered by the IAQR. Under this approach, reductions could be obtained by applying NOx RACT statewide for all NOx sources greater than 100 tons per year. This RACT requirement maybe separate or in addition to requirements of options 1 or 2 above and is similar to RACT requirements already being implemented in the Northeast Ozone Transport Region. Opportunities for reductions in emissions at glass manufacturing and process heaters are modest because the inventory of NOx emissions is relatively small. We estimate a potential emissions reduction from large units in these 2 categories to be about 33,000 tons/year.4 Industrial and Commercial Boilers: There are two primary methods that industrial and commercial boilers could use to reduce emissions of NOx: they could install combustion controls (e.g., low-NOx burners) or they could install post combustion emission control devices. EPA has developed estimates of the cost of Nox reduction technologies for these sources. "Preliminary Nox Control Cost Estimates for Industrial Boilers" (located in the docket) details these costs. As with S02 controls, there are a number of uncertainties associated with the estimates for this sector. First, because EPA does not possess actual capacity factor data for all of the sources in this sector, EPA had to assume capacity factors in order to estimate costs. Such estimates are difficult to accurately estimate for this particular sector due to the wide variety of operating characteristics of these sources. For example, capacity factors for this sector can range from near zero (standby units) up to 100% as well as anywhere in between these extremes. In 2 1,267 IC engines emitting greater than 100 tons/year in the 11 states total emissions of 270,068. A 90% reduction gives a 243,061 ton/year reduction. 32 cement kilns emitting more than 100 tons/year in the 11 states account for 28,585 tons/year. A 30% control level results in a reduction of 8,576 tons/year. These estimates assume the units are currently uncontrolled. 3 283 IC engines emitting between 100-365 tons/year have total emissions of 54,506. A 90% reduction gives a 49,055 ton/year reduction. 8 cement kilns emitting between 100-365 tons/year account for 1,615 tons/year. A 30% control level results in a reduction of 484 tons/year. These estimates assume the units are currently uncontrolled. 4 Emissions in the 30 State area from glass manufacturing and process heaters above 364 tons/year are estimated to be 48,297 and 62,477 tons/year, respectively. Assuming a 30% control level, the emission reduction would be about 33,000 tons/year. 12 ------- comparison, utility boilers typically operate with high capacity factors. Second, similar to post-combustion S02 controls, space constraints have the potential of complicating or making installation of SCR technology infeasible. Third, EPA's current inventories of industrial boilers in the SIP call region do not reflect all the NOx control technologies planned as a result of the SIP call. As a result, the NOx emission rates used to develop cost estimates for these sources are not based on full implementation of the SIP call. Last, EPA does not have a good understanding of the costs and operational effects of integrating post combustion S02 andNOx control technologies for these particular sources. Industrial boiler backend equipment configurations and flue gas temperatures exiting industrial boilers are different than those generally present with EGUs. These features may also vary greatly among industrial boilers themselves, making it difficult to determine feasibility of some of these technologies and apply one single set of design criteria to them. 13 ------- Appendix 1. Preliminary Estimates of Potential S02 Reductions from Sulfuric Acid Manufacturing POINT S02 FIPSST PLANTID ID see SIC ANN 48 0031 097 30102201 General 2911 1,032 17 1217 005 30102201 General 2819 119 37 0071 014 30102301 Absorber/@ 9 9.9% Conversion 2874 3,053 12 0059 042 30102301 Absorber/@ 99.9% Conversion 2874 1,745 12 0055 004 30102301 Absorber/@ 9 9.9% Conversion 2874 1,705 12 0059 044 30102301 Absorber/@ 9 9.9% Conversion 2874 1,691 37 0071 011 30102301 Absorber/@ 9 9.9% Conversion 2874 1,682 12 0055 005 30102301 Absorber/@ 99.9% Conversion 2874 1,677 12 0053 005 30102301 Absorber/@ 9 9.9% Conversion 2874 1,543 12 0046 032 30102301 Absorber/@ 9 9.9% Conversion 2874 1,541 12 0059 004 30102301 Absorber/@ 9 9.9% Conversion 2874 1,529 12 0046 033 30102301 Absorber/@ 99.9% Conversion 2874 1,512 12 0059 003 30102301 Absorber/@ 9 9.9% Conversion 2874 1,508 37 0071 012 30102301 Absorber/@ 9 9.9% Conversion 2874 1,502 12 0005 007 30102301 Absorber/@ 9 9.9% Conversion 2874 1,499 12 0008 005 30102301 Absorber/@ 99.9% Conversion 2874 1,484 12 0046 012 30102301 Absorber/@ 9 9.9% Conversion 2874 1,478 12 0059 002 30102301 Absorber/@ 9 9.9% Conversion 2874 1,474 12 0008 006 30102301 Absorber/@ 9 9.9% Conversion 2874 1,413 12 0005 003 30102301 Absorber/@ 99.9% Conversion 2874 1,405 22 0004 008 30102301 Absorber/@ 9 9.9% Conversion 2874 1,330 12 0005 004 30102301 Absorber/@ 9 9.9% Conversion 2874 1,263 12 0002 022 30102301 Absorber/@ 9 9.9% Conversion 2874 1,214 12 0048 002 30102301 Absorber/@ 99.9% Conversion 2874 1,129 12 0053 004 30102301 Absorber/@ 9 9.9% Conversion 2874 1,008 48 0010 002 30102301 Absorber/@ 9 9.9% Conversion 2819 1,004 12 0002 021 30102301 Absorber/@ 9 9.9% Conversion 2874 999 12 0051 017 30102301 Absorber/@ 9 9.9% Conversion 2874 905 12 0051 016 30102301 Absorber/@ 9 9.9% Conversion 2874 859 12 0053 003 30102301 Absorber/@ 9 9.9% Conversion 2874 769 37 0071 013 30102301 Absorber/@ 9 9.9% Conversion 2874 685 Subgrouping Available controls Annual S02 14 ------- 12 0057 005 30102301 Absorber/@ 99.9% Conversion 48 0001 277 30102301 Absorber/@ 99.9% Conversion 17 0104 120 30102301 Absorber/@ 99.9% Conversion 42 0032 614 30102301 Absorber/@ 99.9% Conversion 22 0005 042 30102301 Absorber/@ 99.9% Conversion 22 0016 01M 30102301 Absorber/@ 99.9% Conversion 22 0005 0Z3 30102301 Absorber/@ 99.9% Conversion 12 0005 008 30102301 Absorber/@ 99.9% Conversion 22 0016 05E 30102301 Absorber/@ 99.9% Conversion 48 0001 278 30102301 Absorber/@ 99.9% Conversion 18 0242 003 30102304 Absorber/@ 99.5% Conversion 12 0005 003 30102304 Absorber/@ 99.5% Conversion 12 0005 002 30102304 Absorber/@ 99.5% Conversion 47 0004 017 30102304 Absorber/@ 99.5% Conversion 48 0029 009 30102304 Absorber/@ 99.5% Conversion 28 0044 01 30102304 Absorber/@ 99.5% Conversion 29 0001 045 30102304 Absorber/@ 99.5% Conversion 17 0100 002 30102306 Absorber/@ 99.0% Conversion 47 0004 021 30102306 Absorber/@ 99.0% Conversion 12 0052 006 30102306 Absorber/@ 99.0% Conversion 28 0044 02 30102306 Absorber/@ 99.0% Conversion 22 0007 001 30102308 Absorber/@ 98.0% Conversion 22 0028 001 30102308 Absorber/@ 98.0% Conversion 22 0033 002 30102308 Absorber/@ 98.0% Conversion 48 0037 011 30102308 Absorber/@ 98.0% Conversion 22 0004 005 30102308 Absorber/@ 98.0% Conversion 48 0037 008 30102308 Absorber/@ 98.0% Conversion 22 0004 007 30102308 Absorber/@ 98.0% Conversion 22 0004 006 30102308 Absorber/@ 98.0% Conversion 22 0033 003 30102308 Absorber/@ 98.0% Conversion 39 5054 001 30102308 Absorber/@ 98.0% Conversion 21 0001 001 30102308 Absorber/@ 98.0% Conversion 12 0008 004 30102308 Absorber/@ 38.0% Conversion 2874 510 2911 204 2911 167 3339 153 2911 86 2911 70 2911 16 2874 4 2911 2 2911 0 42,970 99.9% conv None 2819 1,339 2874 900 2874 805 3331 778 2874 625 2874 127 2879 108 4,681 99.5% conv 3/7=42% reduction 2006 to get to NSPS of 4/ lb/ton 3339 2,820 3331 478 2874 345 2874 216 3,859 99.0% conv 10/14=71% 2756 2819 10,665 2819 9,613 2819 7,827 2819 7,579 2874 5,357 2819 4,555 2874 3,474 2874 3,244 2819 2,742 2819 2,491 2819 2,305 2874 1,401 15 ------- 51 0078 002 30102308 Absorber/@ 98.0% Conversion 10 0032 011 30102308 Absorber/@ 98.0% Conversion 10 0032 028 30102308 Absorber/@ 98.0% Conversion 13 0077 004 30102308 Absorber/@ 98.0% Conversion 13 0008 001 30102308 Absorber/@ 98.0% Conversion 13 0077 003 30102308 Absorber/@ 98.0% Conversion 40 1468 001 30102308 Absorber/@ 98.0% Conversion 55 0083 P01 30102308 Absorber/@ 98.0% Conversion 39 5001 005 30102308 Absorber/@ 98.0% Conversion 01 5009 004 30102310 Absorber/@ 97.0% Conversion 22 0004 057 30102310 Absorber/@ 97.0% Conversion 39 5048 003 30102310 Absorber/@ 97.0% Conversion 51 0026 14A 30102314 Absorber/@ 95.0% Conversion 22 0005 017 30102318 Absorber/@ 93.0% Conversion 22 0005 016 30102318 Absorber/@ 93.0% Conversion 54 0002 021 30102318 Absorber/@ 93.0% Conversion 39 5048 004 30102318 Absorber/@ 93.0% Conversion 42 0035 107 30102318 Absorber/@ 93.0% Conversion 48 0038 001 30102319 Concentrator 22 0006 002 30102319 Concentrator 48 0038 004 30102321 Storage Tank Vent 22 0033 013 30102321 Storage Tank Vent 48 0011 139 30102322 Process Equipment Leaks 22 0004 034 30102322 Process Equipment Leaks 22 0005 041 30102322 Process Equipment Leaks 48 0038 008 30102322 Process Equipment Leaks 22 0003 007 30102399 Other Not Classi fied 47 0092 003 30102399 Other Not Classi fied 10 0032 027 30102399 Other Not Classi fied 10 0032 029 30102399 Other Not Classi fied 10 0032 036 30102399 Other Not Classi fied 10 0032 074 30102399 Other Not Classi fied 24 0109 034 30102399 Other Not Classi fied 22 0005 025 30102399 Other Not Classi fied 2819 1,157 2819 739 2819 483 2873 471 2819 454 2873 328 2819 234 2869 127 2819 10 65,256 98% conv 22/26 reduction 55217 2819 2,386 2819 828 2819 357 3,571 97% conv 36/40 reduction 3214 2869 670 670 95% conv 66/70 reduction= 632 4911 1,614 4911 1,529 3312 225 2819 194 2816 27 3,589 93% conv 92/96 reduction= 3440 2819 391 2873 9 2819 7 2819 1 2869 160 2874 7 4911 4 2819 1 2819 625 3339 597 2819 107 2819 20 2819 6 2819 5 2816 3 4911 1 16 ------- 0005 026 30102399 Other Not Classi fied 4911 0032 031 30102399 Other Not Classi fied 2819 1 1 The current TOTAL 126,543 tons could possibly be reduced by 67265 tons to a level of 59,279 tons if all plants met the 4 lb/ton NSPS level 17 ------- 18 ------- |