Evaluation of Potential
PM2 5 Reductions by
Improving Performance of
Control Devices:
Conclusions and
RECOMMENDATIONS
draft Report
Prepared for:
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
Prepared by:
PECHAN
5528-B Hempstead Way
Springfield, VA 22151
E.H. Pechan 8f Associates, Inc.
3622 Lyckan Parkway, Suite 2002
Durham, NC 27707
703-813-6700 telephone
703-813-6729 facsimile
and
3622 Lyckan Parkway
Suite 2002
Durham, NC 27707
RTI International
3040 Cornwallis Road
Research Triangle Park, NC 27709-2194
919-493-3144 telephone
919-493-3182 facsimile
P.O. Box 1345
El Dorado, CA 95623
EPA Contract No. 68-D-00-265
Work Assignment 4-52
Pechan Report No. 05.09.011/9012-452
530-672-0441 telephone
530-672-0504 facsimile
September 30, 2005
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CONTENTS
Page
TABLES iv
FIGURES iv
ACRONYMS AND ABBREVIATIONS v
EVALUATION OF POTENTIAL PM25 REDUCTIONS 4
1. INTRODUCTION 4
2. BACKGROUND ON PM25 AMBIENT AIR CONCENTRATIONS 4
2.1 National Ambient Air Quality Standards for PM2.5 4
2.2 Composition of Ambient PM2 5 5
3. SUMMARY OF PM25 EMISSION ESTIMATES 6
4. ASSESSMENT OF DIRECT PM25 EMISSION CONTROL AS A COMPLIANCE
STRATEGY 10
4.1 Atlanta, GA 12
4.2 Birmingham, AL 12
4.3 Canton-Massillon, OH 12
4.4 Charleston, WV 12
4.5 Chattanooga, TN-GA 12
4.6 Chicago-Gary-Lake County, IL-IN 13
4.7 Cincinnati-Hamilton, OH-KY-IN 13
4.8 Cleveland-Akron-Lorain, OH 13
4.9 Columbus, OH 13
4.10 Detroit-Ann Arbor, MI 14
4.11 Huntington-Ashland, WV-KY-OH 14
4.12 Indianapolis, IN 14
4.13 Knoxville, TN 14
4.14 Louisville, KY-IN 15
4.15 St. I.ouis. Y10-II. 15
4.16 Steubenville-Weirton, OH-WV 15
5. SUMMARY OF LITERATURE REVIEW FOR IMPROVED PM25 EMISSIONS
CONTROL 15
5.1 Performance of Existing Controls 16
5.2 Improved Methods and Modifications of PM2 5 Control 20
5.3 Innovative PM2.5 Controls 23
6. CONCLUSIONS, UNCERTAINTIES, AND DATA NEEDS 26
6.1 Conclusions 26
6.2 Uncertainties 27
6.3 Data Needs and Recommendations for Future Work 29
7. REFERENCES 32
APPENDIX A. TOP PM25 POINT EMISSION SOURCES BY N ON ATT AINMENT
AREA A-l
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TABLES
Table 2-1. Annual Average Ambient PM2.5 Concentration for Highest Monitor in Each NAA....5
Table 3-1. Comparison of PM25-PRI Emissions by Source Type 7
Table 4-1. Maximum Ambient PM2.5 Concentration Reduction Achievable by Reducing Point
Source PM25-PRI Emissions 11
Table 5-1. Particle Mass Concentration at the ESP Inlet and Outlet for Biomass-Fueled
Circulating Fluid Bed Boiler 17
Table 5-2. Particle Mass Concentration for Pulse-Jet Fabric Filter in Finland 18
Table 5-3. Performance Test Results of the Unit 1 Pulse-Jet Fabric Filter 19
Table 5-4. Performance Test Results from EPA's Environmental Technology Verification
Program 22
Table 5-5. Performance Evaluation of the Indigo Agglomerator 24
Table A-l. Top PM2.5 Point Emission Sources for Atlanta, GA Nonattainment Area A-2
Table A-2. Top PM2.5 Point Emission Sources for Birmingham, AL Nonattainment Area A-3
Table A-3. Top PM2.5 Point Emission Sources for Canton-Massilon, OH Nonattainment
Area A-6
Table A-4. Top PM2.5 Point Emission Sources for Charleston, WV Nonattainment Area A-7
Table A-5. Top PM2.5 Point Emission Sources for Chattanooga, TN-GA Nonattainment
Area A-7
Table A-6. Top PM2.5 Point Emission Sources for Chicago-Gary-Lake County, IL-IN
Nonattainment Area A-8
Table A-7. Top PM2.5 Point Emission Sources for Cincinnati-Hamilton, OH-KY-IN
Nonattainment Area A-10
Table A-8. Top PM2.5 Point Emission Sources for Cleveland-Akron -Lorain, OH Nonattainment
Area A-12
Table A-9. Top PM2.5 Point Emission Sources for Columbus, OH Nonattainment Area A-13
Table A-10. Top PM2.5 Point Emission Sources for Detroit-Ann Arbor, MI Nonattainment
Area A-14
Table A-l 1. Top PM2.5 Point Emission Sources for Huntington-Ashland, WV-KY-OH
Nonattainment Area A-15
Table A-12. Top PM2.5 Point Emission Sources for Indianapolis, IN Nonattainment Area ... A-16
Table A-13. Top PM2.5 Point Emission Sources for Knoxville, TN Nonattainment Area A-17
Table A-14. Top PM2.5 Point Emission Sources for Louisville, KY-IN Nonattainment
Area A-18
Table A-15. Top PM2.5 Point Emission Sources for St. Louis, MO-IL Nonattainment Area . A-19
Table A-16. Top PM2.5 Point Emission Sources for Steuvenville-Weirton, OH-WV
Nonattainment Area A-20
FIGURES
Figure 2-1. Average Ambient PM2.5 Composition in Urban Areas 6
Figure 3-1. Breakdown of PM25-PRI Emissions According to Source Type by NAA 8
Figure 3-2. Point Source "Controlled" Emissions as a Percentage of Total PM25-PRI Emissions
from All Sources by NAA 8
Figure 3-3. Contribution of PM25-PRI Point Source Emissions by Control Status and NAA 9
Figure 3-4. Emissions of PM25-PRI versus Number of Emission Points 10
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September 30, 2005
ACRONYMS AND ABBREVIATIONS
acfm actual cubic feet per minute
BOF basic oxygen furnace
CAIR Clean Air Interstate Rule
COHPAC Compact Hybrid Particulate Collector
DSI dry sorbent injection
EGU electrical generating unit
EPA United States Environmental Protection Agency
ESP electrostatic precipitator
ETV Environmental Technology Verification
FCCU fluid catalytic cracking unit
FF fabric filter
FGD flue gas desulfurization
ft2 square feet
gr/dscf grains per dry standard cubic foot
in. H20 inches of water
kW kilowatt
lb pound
MACT maximum achievable control technology
mg/Nm3 milligrams per normal cubic meter
MMBtu million British thermal units
MW megawatt
jam micrometer
NAA nonattainment area
NAAQS National Ambient Air Quality Standard
NEI National Emissions Inventory
NOx nitrogen oxide
PM particulate matter
PPS polyphensulfide
PTFE polytetrafluoroethene
REF recovered fuel
ROPE Rapid Onset Pulsed Energization
SCA specific collection area
SIP state implementation plan
502 sulfur dioxide
503 sulfur trioxide
STN Speciated Trends Network
tpy tons per year
TSP total suspended particulates
W watts
WS wet scrubber
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EVALUATION OF POTENTIAL PM2 5 REDUCTIONS
1. INTRODUCTION
The EPA is evaluating emissions reduction strategies for implementing the 1997 PM25 National
Ambient Air Quality Standards (NAAQS) standards (PM25, is particulate matter (PM) that is less
than 2.5 micrometers in diameter). Effective April 5, 2005, EPA completed the "designation"
process in which EPA formally announced the areas of the country that are not attaining the
PM2.5 standards. States are required to develop and submit implementation plans (SIPs) to bring
these areas into attainment. The SIPs will be due to EPA in April 2008 and must provide for
attainment by April 2010 (based upon data for the 2007-2009 time period) unless EPA approves
an extension of the time period to a date which may not be later than 2014.
EPA is investigating ways to reduce direct (primary) PM25 emissions in areas that likely will not
attain the PM2 5 standards even after the Clean Air Interstate Rule (CAIR) is fully implemented.
One possible way of reducing PM2 5 emissions would be to modify existing control devices to
improve their performance in reducing the "fine" (less than 2.5 micrometers) fraction of
particulate matter. An extensive literature review was conducted to identify operational
improvements, control device upgrades, and innovative control systems that could be used to
reduce PM2 5 emissions. The PM2 5 emissions were also evaluated to estimate the contribution
controlled point sources have to the total PM2 5 emissions reported for each of the 16 non-
attainment areas (NAAs) and to estimate the degree to which improving or replacing existing
controls would reduce PM2 5 emissions.
This report summarizes the results of the literature review and the evaluation of PM2 5 emissions
for the 16 NAAs and provides conclusions and recommendations regarding emission sources and
control techniques for further evaluation in meeting ambient PM2 5 standards.
2. BACKGROUND ON PM2 5 AMBIENT AIR CONCENTRATIONS
2.1 National Ambient Air Quality Standards for PM2.s
There are two NAAQS for PM2 5. The short-term NAAQS for PM2 5 is a 24-hour limit of 65
|ig/m3. None of the ambient monitors in any of the NAAs violated this standard. There is also
an annual mean limit of 15 |ig/m3. It is this annual mean limit that is being exceeded in the
PM2.5 NAAs under consideration. Note that compliance with the long-term PM2 5 NAAQS is
based on the average of three consecutive annual averages.
We queried the AirData system to identify all ambient monitors in the counties that comprise the
16 NAAs being considered. Table 2-1 shows the results for the annual average ambient PM2 5
concentration for the highest monitor in each NAA. It can be seen that the there has been
significant progress within the NAA towards meeting the annual mean limit of 15 |ig/m3. In
2000, nine of the NAA had average ambient PM2 5 concentrations exceeding 20 |ig/m3, and all
16 of the NAAs had average ambient PM2 5 concentrations of 17.5 |ig/m3 or more. By 2004,
only one NAA had a monitor that exceeded 20 |ig/m3 (Birmingham, at 36 percent above the
NAAQS) and only two other areas with average ambient PM2 5 concentrations of 17.5 |ig/m3 or
more (Atlanta and Cleveland-Akron-Lorain). In 2004, 9 out of the 16 NAAs had highest
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monitor values that were within 10 percent of the NAAQS (i.e., 16.5 |ig/m3 or less), and 13 out
of 16 NAAs require only a 15 percent reduction in their annual average ambient air
concentration to achieve the 15 |ig/m3 NAAQS. As compliance with the long-term PM2.5
NAAQS is based on the average of three consecutive annual averages, the reductions described
above would be valid only if the values for 2005 and 2006 are essentially equal to the 2004
values. If the trend of declining PM2.5 ambient concentrations continues for 2005 and 2006, the
necessary reductions would be even less.
Table 2-1. Annual Average Ambient PM2.5 Concentration for Highest Monitor in
Each NAA
Nonattainment Area
Annual Average Ambient PM2.5 Concentrations (ng/m3) for Year:
2000
2001
2002
2003
2004
Atlanta
21.5
19.1
17.4
17.7
17.6
Birmingham
23.2
22.1
19.3
19.6
20.4
Canton-Masillon
18.7
17.8
17.3
16.8
15.6
Charleston
18.3
18.1
17.2
16.2
16.1
Chattanooga
19.0
16.7
15.1
16.5
15.7
Chicago-Gary
20.2
20.9
17.7
17.4
16.7
Cincinnati-Hamilton
20.6
23.0
17.9
17.3
16.4
Cleveland-Akron-Lorain
20.1
19.8
17.7
17.6
17.5
Columbus
18.3
17.9
16.2
16.4
15.0
Detroit-Ann Arbor
20.1
19.6
19.8
19.1
16.8
Huntington-Ashland
21.1
20.3
16.7
15.5
15.2
Indianapolis
18.9
18.6
18.4
17.5
16.7
Knoxville
20.1
17.5
16.9
16.4
15.1
Louisville
17.5
18.6
18.7
19.1
15.1
St. Louis
20.6
19.7
19.6
18.1
16.2
Steubenville-Weirton
19.2
18.9
17.6
17.7
16.6
2.2 Composition of Ambient PM2.5
Figure 2-1 shows the compositional breakdown for PM2.5 in 7 areas of the United States. All
16 of the NAAs under consideration are located in either the industrial Midwest or the Southeast.
For the industrial Midwest and Southeast, sulfates form the largest component of PM2.5, followed
by carbon and nitrates.
Although this project focuses on primary (or direct) PM2.5 emissions, a substantial portion of
ambient PM2.5 in both the industrial Midwest and the Southeast comes from secondary formation
(e.g., sulfur dioxides and nitrogen oxide emissions that combine with ammonia to form
ammonium sulfate and ammonium nitrate). Primary PM2.5 emissions represent between 33 and
50 percent of the ambient PM2.5.
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PLC HA IN
September 30, 2005
WEST
EAST
Northwest
Southern
California
©
Upper
Midwest
©
Southwest
Industrial
Midwest
0
Southeast
©
Northeast
©
Sulfates
Nitrates
,/N, Carbon
Crustal
Circle size corresponds
Note: In this report, the term "sulfates" refers to ammonium sulfate and "nitrates" refers to ammonium nitrate. "Carbon" refers to
total carbonaceous mass, which is the sum of estimated organic carbon mass and elemental carbon. "Crustal" is estimated using the
IMPROVE equation for fine soil at vista.cira.colostate.edu/impwve.
This report summarizes analysis results using the geographic areas shown in this map. The area definitions correspond to the regions
used in EPA's 1996 PM Criteria Document (uww.epa.gov/ttn/naaqs).
In this report, "East" includes three regions: the Northeast, the Industrial Midwest, and the Southeast.
Figure 2-1. Average Ambient PM2.s Composition in Urban Areas
3. SUMMARY OF PM2 5 EMISSION ESTIMATES
This section summarizes key results of the analysis of PM2.5 emissions data; the details of the
PM2.5 emissions analysis are documented in the "PM2.5 Emission Estimates" report (Pechan and
RTI, 2005). The PM2.5 emission estimates were based on the data reported in the 2002 draft
National Emissions Inventory (NEI) that EPA released for review by the state and local agencies
during February 2005. EPA will be releasing the final 2002 NEI in the fall of 2005. This
version will incorporate comments that state and local agencies provided to EPA on the draft
2002 NEI. In addition, EPA will be applying procedures to fill in missing PM25-FIL (i.e., the
filterable portion of the PM2.5 emissions) and PM-CON (i.e., the condensable portion of the
PM2.5 emissions) data and will sum the emissions for these two pollutants to obtain PM25-PRI
emissions (i.e., the total or "primary" PM2.5 emissions). Although a cursory attempt was made to
augment the reported PM2 5 data, it is important to note that the emissions reported here represent
primarily 2002 draft NEI values.
Table 3-1 presents the PM25-PRI emissions data for all 16 NAAs by source type (point,
nonpoint, onroad, and nonroad). The point source data are segregated between "controlled,"
"regulated," and "uncontrolled" point source emissions. The "controlled" classification directly
correlates with the NEI classification of controlled units; these are essentially sources with add-
on emission control devices. However, in reviewing the largest "uncontrolled" emission sources,
certain large emission sources were identified, such as coke oven doors, that are subject to work
practice or equipment standards to reduce their emissions. Although they do not have an
external air pollution control device, it is misleading to characterize these emissions as
completely uncontrolled since the current emissions from these sources has been significantly
reduced through source-specific opacity limits or work practice standards. Therefore, we
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PECHAN
September 30, 2005
subcategorized the point sources with no add-on control devices into "regulated" sources (i.e.,
sources subject to federal opacity/work practice standards) and "uncontrolled" sources (i.e.,
sources with no emission control systems).
Table 3-1. Comparison of PM25-PRI Emissions by Source Type
Poinl 1.missions U|)\)
Non-
Onroad
(l|>> )
Non-
Tolal
(l|)\)
Nonallaimm-nl Area Name
Add-on
Com ml
Kosiii-
laled
I neon-
1 rolled
poinl
(l|)\ )•
road
(l|>> )
Atlanta, GA
4,162
-
385
24,735
3,082
2,591
34,955
Birmingham, AL
10,309
4,070
4,034
4,205
526
514
23,658
Canton-Massillon, OH
123
1
147
1,330
143
194
1,938
Charleston, WV
1,633
-
282
1,596
195
242
3,948
Chattanooga, TN-GA
987
-
110
2,649
332
384
4,462
Chicago-Gary-Lake County, IL-IN
2,399
1,634
3,338
23,191
2,820
5,982
39,365
Cincinnati-Hamilton, OH-KY-IN
3,342
-
272
7,527
901
1,567
13,610
Cleveland-Akron-Lorain, OH
2,287
8
247
7,041
1,275
2,498
13,356
Columbus, OH
2,369
-
242
6,887
703
1,014
11,214
Detroit-Ann Arbor, MI
1,704
-
7
11,837
2,853
2,888
19,289
Huntington-Ashland, WV-KY-OH
4,488
-
333
3,092
236
1,184
9,334
Indianapolis, IN
243
80
352
9,915
682
886
12,158
Knoxville, TN
6,003
230
911
2,592
543
490
10,769
Louisville, KY-IN
4,651
-
2,548
5,209
698
865
13,970
St. Louis, MO-IL
2,008
-
4,502
16,301
1,677
2,260
26,748
Steubenville-Weirton, OH-WV
4,445
6,014
819
712
53
154
12,196
Total, all Nonattainment Areas
51,153
12,036
18,529
128,819
16,719
23,713
250,969
* Draft 2002 NEIPM25-FIL emissions for fugitive dust sources are adjusted using EPA county-level fugitive dust
transport fractions.
Figure 3-1 shows the percentages of PM25-PRI that are from controlled point sources as
compared to all other sources (including uncontrolled, nonpoint, onroad, and nonroad). For the
16 NAAs of interest, emissions of PM25-PRI that are controlled point sources average
approximately 24 percent of all PM25-PRI emissions. Figure 3-2 shows the percentage
contribution only for PM25-PRI from "controlled" point sources (i.e., point sources controlled
using an add-on PM emissions control device). Figure 3-2 simply highlights the "controlled"
point source contribution presented in Figure 3-1.
Figure 3-3 shows the percentages of total PM25-PRI point source emissions that are from
"controlled" versus "regulated" versus "uncontrolled" point sources.
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PECHAN
September 30,2005
c
o
E
c
c5
ts
tt
c
o
c
o
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V)
£
o
E
Q.
o
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c
o
o
o
£L
100%
95%
90%
85%
80% -I—
75% - -
70% - -
65% -J—
60%
55%
50%
45%
40%
35%
30%
25%
20%
15%
10%
5%
m
0%
~ Nonroad
¦ Onroad
~ Nonpoint
~ Point
~ Point
~ Point
Uncontrolled
Regulated
Controlled
O*
aP
^ J? +* 6^ °* °* •/ ^
/C^ ^>F iS" & jr- •P
#>N"
a
n
+*
c
o
o
o
£L
50
10 --
~ Point: Controlled
J=L
^ ^ ^ ^ ^ &
^ ^ J- ^ ./ J-
& ^
'X 'SSSS ' *
/ #' jr / #
&
f ^y°
*0 .fS"
C& JC?
Figure 3-2. Point Source "Controlled" Emissions as a Percentage of Total PM25-
PRI Emissions from All Sources by NAA
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PECHAN
September 30,2005
t/>
E
LU
E
Q_
i
m
CM
0
o
o
CO
o
Q_
4-
o
c
0
o
5
Q_
100%
90% j-
80% -|-
70%
60%
50% j-
40% -|-
30%
20%
10%
0%
cF
~ Uncontrolled
~ Regulated
~ Controlled
\>: . <\v! >>N'
cV .*!>
<3- «•"
^ -V"
Figure 3-3. Contribution of PM25-PRI Point Source Emissions by Control Status
and NAA
We also looked at the relative size of the sources of PM25-PRI emissions. The database
developed for this project, based on adjustments to the draft NEI described previously, contains
8,716 records. Of these, 2,822 records were associated with emission sources using add-on
control devices ("controlled" sources), 129 records were classified as "regulated" sources, and
5,765 were classified as "uncontrolled" sources. The total emissions were approximately 51,000
tpy, 12,000 tpy, and 18,000 tpy for controlled, regulated, and uncontrolled point sources,
respectively. As shown in Figure 3-4, approximately half of the controlled and uncontrolled
emissions came from the top 50 sources within that category. For "controlled" point sources, the
top 252 emission sources (top 9% of controlled sources) accounted for 90 percent of the
controlled point source emissions. For "regulated" sources, the top 28 (22% of) regulated
sources accounted for 90 percent of the regulated point source emissions. For "uncontrolled"
sources, the top 641 (11% of) uncontrolled sources accounted for 90 percent of the uncontrolled
point source emissions. These data suggest that a significant reduction in point source emissions
may be achieved by improving the PM2.5 control efficiency of a relatively small number of
emission sources.
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PECHAN
September 30, 2005
Number of emission points
Figure 3-4. Emissions of PM25-PRI versus Number of Emission Points
4. ASSESSMENT OF DIRECT PM2 5 EMISSION CONTROL AS A
COMPLIANCE STRATEGY
This section provides a preliminary assessment of the importance of direct PM2.5 point source
emission control improvements as a candidate option in developing an overall strategy to meet
the PM2.5NAAQS. For the NAAs where additional control of point sources appears to be a
reasonable candidate option to consider, the largest PM2.5 emission sources are presented to
provide insight into potential control upgrades or replacements for these sources.
Table 4-1 provides a summary of the relative potential impact that control of point sources could
make in reducing PM2.5 ambient air concentrations. For this analysis, we assumed that the
"direct PM2.5 ambient air concentration" is 40 percent of the existing ambient concentration at
the monitors with the highest concentrations (using 2004 data). This 40 percent value is based
on the typical 60 to 70 percent contribution of sulfates and nitrates to the total ambient PM2.5
concentration (see Figure 2-1). These sulfates and nitrates are considered "indirect" PM2.5 as
they are generally formed in secondary atmospheric reactions occurring subsequent to the
emission releases of sulfur dioxide (S02), nitrogen oxide (NOx), and ammonia. The percent of
the direct PM25-PRI emissions within each NAA that are from point sources (see data reported
in Table 3-1) is then used to further scale the "direct PM2.5 ambient air concentration" to estimate
the contribution that PM25-PRI point source emissions have on the total ambient PM2.5
concentration.
This final value represents the maximum reduction in the ambient PM2.5 concentration that could
be achieved by reducing PM2.5 emissions from point source. In fact, it represents an estimate of
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PECHAN
September 30, 2005
the reduction in the ambient PM2.5 concentration that may be achieved by a complete elimination
of PM2.5 point source emissions. Nonetheless, Table 4-1 provides some useful insights as to the
practical significance of improving PM2.5 point source controls for each of the NAAs: maximum
concentration reductions of less than 1 |ig/m3 were designated as low priority; reductions of 1 to
2 |ig/m3 were designated as moderate priority; and reductions of more than 2 |ig/m3 were
designated as high priority. Using this simplistic analysis, improving point source controls was
designated as a high priority option for 6 of the 16 NAAs considered in this analysis, and
improving point source controls was designated as a high or moderate priority option for 12 of
the 16 NAAs. Therefore, the identification and characterization of methods of reducing PM25-
PRI emissions at point sources (e.g., improving the performance of existing controls for PM2.5) is
important in the overall attainment strategy for many NAAs.
Table 4-1. Maximum Ambient PM2.5 Concentration Reduction Achievable by
Reducing Point Source PM25-PRI Emissions
Non;ill;iinmcnl Area Name
Anniiiil
A\er;i}»e
Ambient
I'M;,
( one. in
2004
(.uii/m')
I'M;,
C 'one.
Conlrihu-
1 ion from
direct
I'M;,
l-'m issions
Percent of
Direct
PM25-PRI
Emissions
from
Point
Sources
Miixiiiiiini
(one.
Reduction
Achic\ iihlc
from Point
Sources
(nii/in" t
Rcl;iti\c
Importance of
PM25-PRI
Conlml :is
Cnndidntc
Alliiinmenl
Option
Atlanta, GA
17.6
7.04
13.0%
0.92
low priority
Birmingham, AL
20.4
8.16
77.8%
6.35
high priority
Canton-Massillon, OH
15.6
6.24
14.0%
0.87
low priority
Charleston, WV
16.1
6.44
48.5%
3.12
high priority
Chattanooga, TN-GA
15.7
6.28
24.6%
1.54
moderate priority
Chicago-Gary-Lake County, IL-
IN
16.7
6.68
18.7%
1.25
moderate priority
Cincinnati-Hamilton, OH-KY-IN
16.4
6.56
26.6%
1.74
moderate priority
Cleveland-Akron-Lorain, OH
17.5
7
19.0%
1.33
moderate priority
Columbus, OH
15
6
23.3%
1.40
moderate priority
Detroit-Ann Arbor, MI
16.8
6.72
8.9%
0.60
low priority
Huntington-Ashland, WV-KY-
OH
15.2
6.08
51.7%
3.14
high priority
Indianapolis, IN
16.7
6.68
5.6%
0.37
low priority
Knoxville, TN
15.1
6.04
66.3%
4.01
high priority
Louisville, KY-IN
15.1
6.04
51.5%
3.11
high priority
St. Louis, MO-IL
16.2
6.48
24.3%
1.58
moderate priority
Steubenville-Weirton, OH-WV
16.6
6.64
92.5%
6.14
high priority
Appendix A provides the top point emission sources for each of the 16 NAAs. Generally,
Appendix A includes all single point emission sources with PM25-PRI emission of 100 tons per
year (tpy) or more. Some NAAs did not have any emission sources greater than 100 tpy (as
reported in the 2002 draft NEI); for these NAAs, Appendix A provides information on the
emission sources greater than 10 tpy. The remainder of this section presents a brief summary of
the conclusions of the emissions analysis for each NAA.
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4.1 Atlanta, GA
Table 5-1 shows that point sources account for only 13 percent of the direct PM25-PRI
emissions in the Atlanta NAA. As seen in Table 3-1, nonpoint sources appear to be the most
significant source of PM25-PRI emissions in the Atlanta NAA. Therefore, the ambient
concentration reduction that would result from complete elimination of point source emissions
would only reduce the ambient PM concentration by 0.92 |ig/m3, and more attainable emissions
reductions would have even less impact. Although improved point source control may be part of
the overall strategy to meet the PM25 NAAQS, it does not appear to be a priority in that overall
strategy. The highest point source emitters in this NAA are all coal-fired electric utilities.
4.2 Birmingham, AL
Table 4-1 shows that point sources contribute almost 80 percent of the total PM25-PRI emissions
in the Birmingham, AL NAA. Approximately 55 percent of the PM25-PRI point source
emissions are from controlled sources and the remaining emissions are split evenly between
regulated and uncontrolled point sources (se Table 3-1). Therefore, improved control of
controlled and regulated sources and application of controls to uncontrolled point sources all
appear to be priorities in attempting to meet the PM25 NAAQS in the Birmingham NAA. High
emission sources within this NAA are coal-fired electric utilities, primary steel plants, iron and
steel foundries, and a mineral wool plant.
4.3 Canton-Massillon, OH
Point sources account for only 14 percent of the direct PM25-PRI emissions in the Canton-
Massillon NAA; nonpoint sources dominate the PM25-PRI emissions for this NAA. Overall, the
Canton-Massillon area has the lowest PM25-PRI emissions of any of the 16 NAAs. Although
Table 4-1 designates point source PM control as a low priority strategy, given the small
incremental improvement needed in this NAA to achieve attainment, improved point source
control may still be part of the overall strategy to meet the PM25 NAAQS for this NAA. The
largest point sources for this NAA are a primary steel production facility and a bearing
manufacturing plant.
4.4 Charleston, WV
Point sources account for almost 50 percent of the direct PM25-PRI emissions in the Charleston,
WV NAA; almost all of the point source emissions are from controlled sources. Coal-fired
boilers completely dominate the PM25-PRI point source emissions for this NAA; improved
control of these sources appears to be a high priority in the overall strategy to meet the PM25
NAAQS for this NAA.
4.5 Chattanooga, TN-GA
Point sources account for approximately 25 percent of the direct PM25-PRI emissions in the
Chattanooga NAA; nonpoint sources are a little over half the PM25-PRI emissions for this NAA.
Coal-fired boilers dominate the PM25-PRI point source emissions for this NAA, although a few
residual oil-fired boilers appear on the top emitting sources list. Improved control of these
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sources appears to be a moderate priority in the overall strategy to meet the PM2.5 NAAQS for
this NAA.
4.6 Chicago-Gary-Lake County, IL-IN
Point sources account for approximately 20 percent of the direct PM25-PRI emissions while
nonpoint sources account for almost 60 percent of the PM25-PRI emissions for this NAA. For
this NAA, primary metal production (integrated iron and steel manufacturing) is the primary
industry contributing to the point source emissions; petroleum refinery sources and coal-fired
electric utilities also contribute to the overall emissions totals. Reducing point source emissions
was designated as a moderate priority for this NAA based on the analysis in Table 4-1; however,
this NAA has the third largest mass emissions from the point sources. As such, it would appear
the improved control of point sources has a place in the overall strategy to meet the PM2.5
NAAQS for this NAA.
4.7 Cincinnati-Hamilton, OH-KY-IN
Point sources account for approximately 25 percent of the direct PM25-PRI emissions; nonpoint
sources account for 55 percent of the PM25-PRI emissions for this NAA. The major point
sources in this NAA are several coal-fired electric utilities and one primary metal production
(integrated iron and steel manufacturing) plant; all of the major point sources are designated as
controlled. Improving the performance of existing controls appears to be a moderate priority for
this NAA.
4.8 Cleveland-Akron-Lorain, OH
Point sources account for approximately 20 percent of the direct PM25-PRI emissions; nonpoint
sources account for approximately 50 percent of the PM25-PRI emissions for this NAA. The
major point sources in this NAA are more diverse than in other NAAs, which makes the
implementation of improved PM2.5 control as an attainment strategy more difficult. The major
point sources for this NAA include: coal-fired and wood-fired boilers; a primary metal
production facility; two mineral products manufacturers; and a major iron foundry. It appears
that improving the performance of existing controls, especially at the two top power plants in this
NAA, appears to be a moderate priority in the overall strategy to meet the PM2.5 NAAQS for this
NAA. The iron foundry is currently in the process of replacing their wet scrubber control device
with a baghouse, which is projected to reduce the overall PM25-PRI emissions from the cupola
sources by a factor of 2 or more.
4.9 Columbus, OH
Point sources account for 23 percent of the direct PM25-PRI emissions; nonpoint sources
account for over 60 percent of the PM25-PRI emissions for this NAA. The major point sources
for this NAA include: a glass manufacturer; a fiberglass manufacturer; and a coal-fired electric
utility. The emissions from the glass manufacturer's furnace accounts for over 60 percent of the
total point source emissions for this NAA. It appears that the reported emissions for this source
may be in error. If it is not, improving the control device performance for this source would be a
relatively high priority option to consider, especially given the small incremental improvement
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needed to meet the PM2.5 NAAQS given the average ambient PM2.5 concentration for this NAA
in 2004.
4.10 Detroit-Ann Arbor, MI
Although control of point sources is designated as a low priority in for this NAA in Table 4-1,
we believe that there are significant PM emission sources that did not report PM2.5 emission in
the 2002 draft NEI; we suspect that, after the PM augmentation is completed and the final 2002
NEI is released, point sources will be a much more significant portion of the direct PM25-PRI
emissions. The major point sources currently reporting PM25-PRI in the 2002 draft NEI are
coal-fired electric utilities and a glass manufacturer. The "low priority" rating for improving the
control device performance for point sources in Table 4-1 is highly uncertain, and should be re-
evaluated when the final 2002 point source NEI becomes available.
4.11 Huntington-Ashland, WV-KY-OH
Point sources account for just over 50 percent of the direct PM25-PRI emissions for this NAA
and improved control of point source emissions appears to be a high priority option for reducing
the ambient PM concentration in this NAA. The major point sources currently reporting PM25-
PRI emissions in the 2002 draft NEI are all coal-fired electric utilities. The Kentucky portion of
the PM25 inventory, however, only includes electric utilities at this time; all other the point
sources in Kentucky report only TSP (total suspended particulates) or PMi0 (PM less than 10 |im
in diameter) data. There is one significant petroleum refinery in KY within this NAA; however,
this refinery is in the process of completing major revamps to its fluid catalytic cracking units
(FCCUs) - the major PM source at refineries) to the FCCU control systems. Therefore, even
after the PM augmentation is completed, targeted PM25-PRI emissions reductions at the major
electric utilities within this NAA appears to be a high priority attainment strategy.
4.12 Indianapolis, IN
Point sources only account for approximately 6 percent of the direct PM25-PRI emissions for
this NAA whereas nonpoint sources account for over 80 percent of this NAA's direct PM25-PRI
emissions (as reported in the 2002 draft NEI). Unless some significant point sources are absent
from PM25-PRI 2002 draft NEI, improving point source control does not appear to be a viable
PM2.5 NAAQS attainment strategy for this NAA.
4.13 Knoxville, TN
Point sources account for over 65 percent of the direct PM25-PRI emissions for this NAA and
improved control of point source emissions appears to be a high priority option for reducing the
ambient PM concentration in this NAA. The major point sources are coal-fired boilers, mostly at
electric utilities, and a primary aluminum manufacturer. Targeted PM25-PRI emissions
reductions for the major point sources within this NAA appears to be a high priority attainment
strategy.
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4.14 Louisville, KY-IN
Point sources account for over 50 percent of the direct PM25-PRI emissions for this NAA and
improved control of point source emissions appears to be a high priority option for reducing the
ambient PM concentration in this NAA. The major point sources in this NAA are two coal-fired
electric utilities and a cement manufacturer. Note: for this NAA, we performed a cursory PM
augmentation to proportion the reported TSP emissions for Kentucky to PM25-PRI. Therefore,
there is added uncertainty to these point source emission estimates. Nonetheless, targeted PM25-
PRI emissions reductions for the major point sources within this NAA appears to be a high
priority attainment strategy.
4.15 St. Louis, MO-IL
Point sources account for about 25 percent of the direct PM25-PRI emissions for this NAA;
nonpoint sources account for approximately 60 percent of the PM25-PRI emissions for this
NAA. The major point sources in this NAA are more diverse than in other NAAs, which makes
the implementation of improved PM2.5 control as an attainment strategy more difficult. The
major point sources for this NAA include: a major coal transfer station and two other mineral
product plants; coal-fired boilers (mostly at electric utilities); and three different chemical
manufacturing plants (organic acid, inorganic pigment, and paint). Note: a county-specific
transport factor was of 0.36 was applied to American Commercial Terminals (the top emission
source within this NAA) as the fugitive dust emissions from coal loading operations are not all
expected to leave the plant boundaries. The "uncontrolled" emissions reported for this facility
should be verified. If the reported emissions are realistic, capture and control of the emissions at
this facility would appear to be a high priority in the overall attainment strategy for this NAA.
4.16 Steubenville-Weirton, OH-WV
Point sources account for over 90 percent of the direct PM25-PRI emissions for this NAA;
therefore, improved control of point source emissions appears to be a high priority option for
reducing the ambient PM concentration in this NAA. One integrated iron and steel manufacturer
appears to drive the point source emissions in this NAA; other significant point sources include a
coal-fired, a second integrated iron and steel manufacturer, and a coal processing plant. Targeted
PM25-PRI emissions reductions for integrated iron and steel manufacturers within this NAA
appears to be a high priority attainment strategy.
5. SUMMARY OF LITERATURE REVIEW FOR IMPROVED PM2 5
EMISSIONS CONTROL
As discussed in Section 4, improving the control of point source PM25-PRI emissions is a high
priority option to consider for many NAAs. Therefore, it is important to understand the
emissions reductions that can be achieved by improving point source controls. To this end, a
comprehensive literature review was conducted to assess:
1) The PM2.5 control efficiency of existing particulate control devices;
2) Methods and modifications to existing control devices that improve control device
performance for PM2.5; and
3) Innovative PM2.5 emissions control systems.
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The literature review was limited to materials published in the last 7 years (1998 or more recent)
so as not to duplicate information in the EPA document "Stationary Source Control Techniques
for Fine Particulate Matter" (U.S. EPA, 1997). The literature search resulted in 217 pertinent
abstracts. All abstracts were reviewed and approximately 55 articles/reports were ordered and
reviewed. This section summarizes the information gleaned from these articles/reports.
5.1 Performance of Existing Controls
ESPs: EPA's "Stationary Source Control Techniques Guidance Document" contains the
following statements regarding the efficiencies of ESPs:
• "Electrostatic precipitators are capable of collecting greater than 99 percent of all
sizes of particulate."
• "The cumulative collection efficiency of an ESP is generally dependent on the
fractional collection efficiency of these smaller particles, especially between 0.2 to
2.0 |im in size."
• "In general, the most difficult particles (for an ESP) to collect are those with
aerodynamic diameters between 0.1 and 1.0 |im. Particles between 0.2 and 0.4 |im
usually show the most penetration.
The literature reviewed by RTI is consistent with all three of those statements.
Lillieblad et al. (2003) evaluated the particulate control efficiency of a pulse-jet fabric filter on a
coal-fired power plant in Finland. The results of this study are reviewed in Section 5.3,
"Innovative Controls," since ESPs, not pulse-jet fabric filters, are presently the predominant
means of control for utility boilers in the United States. However, Lillieblad et al. did contrast
the results of their particulate testing with the results of Porle et al. (1995) on ESPs. Lillieblad et
al characterize the results of Porle et al. as follows: "Typically, the average particle size of the
particle emissions from pulverized coal combustion with an ESP is around 2 |im, PM2.5 may be
up to 80% of the emission, and a large fraction of the particle emissions are due to
submicrometer mode particles."
Lind et al. (2003) reported the results for ESP fractional collection efficiency and trace metal
emissions tests at a 66 MW biomass-fueled bubbling fluidized-bed combustion plant. The ESP
had two fields, and operated at a flue gas temperature of 130-150°C. "The particle mass
concentration at the inlet was 510-1400 milligrams per normal cubic meter (mg/Nm3).
Particulate emission at the ESP outlet was 2.3-64 mg/Nm3. Total ESP collection efficiency was
99.2-99.8 percent. Collection efficiency had a minimum in particle size range of 0. l-2|im. In
this size range, collection efficiency was 96-97 percent." Further results from the Lind et al.
testing are presented in Table 5-1. In introducing the results of the collection efficiency testing,
Lind et al reported results from the research of others: "Typically, ESPs have a penetration
window in the particle size range of 0.1-1 |im. In pulverized coal combustion, even 10 percent of
the particles in this size range may penetrate the ESP."
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Table 5-1. Particle Mass Concentration at the ESP Inlet and Outlet for Biomass-
Fueled Circulating Fluid Bed Boiler
Location
Fuel
I'M <(K5nm
"/>
Toliil
(mg/\in3)
Inlet
no REF(1)
26
3.1
830
no REF
25
4.9
510
no REF
40
5.4
740
Avg.-no REF(2)
30
4.5
693
with REF
85
6.1
1400
with REF
62
6.2
1000
with REF
72
9.0
800
Avg.-with REF(2)
73
7.1
1067
Outlet
no REF
1.1
22
5.1
no REF
0.79
23
3.4
no REF
1.4
24
5.6
Avg.-no REF(2)
1.1
23
4.7
with REF
3.1
49
6.4
with REF
0.92
40
2.3
Avg.-with REF(2)
1.1
45
4.4
Notes: 1) REF = Recovered Fuel, consisting of 70% wood residue, 18% peat, and 12% recovered fuel.
2) Averages calculated by RTI.
Fabric Filters: Lillieblad et al. (2003) examined PM2.5 and mercury emissions from a high air-to-
cloth ratio fabric filter located after a pulverized coal-fired boiler (located in Finland). The bags
were polyphensulfide (PPS) with intrinsic Teflon (PTFE) coating. At the time of testing, the
bags had been in service for more than 31,000 hours. An inspection of the filters was performed
prior to the measurements, to check that the bags were in good condition. Results of the testing
are shown in Table 5-2.
Lillieblad et al. (2003) noted that the particle emission breakdown (i.e., at the outlet of the fabric
filter) during normal operation in PMi.o was 3-6 percent, in PM25 it was 15-20 percent, in
PM10 it was 79-88 percent; these ranges encompass the mass percentages calculated in
Table 5-2. Lillieblad et al. also noted that, "The particle size distribution at the fabric filter (FF)
outlet clearly differs from particle size distributions at an ESP outlet with a larger average
particle size and the absence of the submicrometer mode. Typically, the average particle size of
the particle emissions from pulverized coal combustion with an ESP is around 2 |im, PM25 may
be up to 80 percent of the emission, and a large fraction of the particle emissions are due to
submicrometer mode particles."
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Table 5-2. Particle Mass Concentration for Pulse-Jet Fabric Filter in Finland
II 111 III
I'M,,,
I'M;.;
I'M,,,
loliil
(mg/Nm 3. ««)'"
(mg/Nm 3. \\g)
(mg/Nm 3, wg)
(mg/Nm3, wg)
Sample 1
170
580
8,200
Sample 2
130
410
12,000
Sample 3
170
590
18,000
Sample 4
280
680
8,200
Average(2)
188
565
11,600
Mass Percentage
1.62
4.88
100
FF Outlet
pmlo
pm2,
PMio
Total
(mg/Nm3, wg)(1)
(mg/Nm3, wg)
(mg/Nm3, wg)
(mg/Nm3, wg)
Sample 1
0.74
2.6
11
13
Sample 2
0.47
2.4
12
15
Sample 3
0.61
2.1
8.6
11
Sample 4
0.54
2.5
14
15
Average
0.59
2.4
11.4
13.5
Mass Percentage
4.4
17.8
84.4
100
Removal Efficiency (%)
63.5
99.6
99.88
Notes: 1) mg/Nm3 = milligrams per normal cubic meter, wet gas.
2) Averages, mass percentages and removal efficiency are as calculated by RTI.
One potential reason that the results of Lillieblad et al. show particularly strong performance for
the collection of PM2.5 is that the fabrics were membrane-coated (with PTFE). The paper shows
a photomicrograph of the PTFE membrane, with some collected particles on the surface. The
photograph is remarkable in that the holes in the membrane (through which filtered flue gas
passes) are circular, and are reported to be only 0.4 |im in size.
Wolf et al. (2004) examined the performance of a pulse jet FF replacing hot ESPs at a pulverized
coal-fired power plant. The replacement in question was for Units 1 and 2 of the Craig Station
near Craig, Colorado; Unit 3 of the station was already equipped with a reverse air baghouse, and
was not modified. Units 1 and 2 are rated at 455 MW each, with controls initially consisting of
hot ESPs and wet flue gas desulfurization (FGD) systems. The complete modification included
construction of ductwork to bypass the ESPs (i.e., the hot ESPs were not demolished, but were
instead simply bypassed), modification of the air preheaters to handle the additional particulate
load created by bypassing the hot ESPs, installation of the pulse-jet fabric filter modules, and
upgrading of the induced draft fans to handle the additional pressure drop created by switching
from hot ESPs to pulse jet fabric filters. The wet FGD systems were retained. The entire project
scope was awarded to the overall modification contractor for 72 $/kW (kilowatt), with a breakout
price for the pulse jet fabric filters of 35 $/kW. At the time of the installation, the pulse jet fabric
filters represented the largest pulse jet installation on coal-fired utility boilers in the United
States.
The initial performance test results for Unit 1 met performance guarantees, as shown in
Table 5-3. Performance test results for Unit 2 were not available at the time of the Wolf et al.
paper. Wolf et al. report that the particulate removal performance of Unit 1 started to degrade
soon after the performance test: "On Unit 1, the opacity, which averaged 3 percent or below for
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approximately the first 6 months of operation, began to trend upward in May 2004 to
approximately 7 percent with occasional spikes to near 10 percent." At the time the paper was
written, investigations of the problems causing the opacity increase were still ongoing, but
preliminary results indicated problems with the bag cage installation and gas flow distribution
within the compartments. These problems led to multiple bag failures (holes in bags).
Table 5-3. Performance Test Results of the Unit 1 Pulse-Jet Fabric Filter
I'iinimeter
Test Results
(iiiiinintee
\ :ilue
Parliculalc Lmission Rale, Ib.MMUlu
u.uu7y
U.U15
Opacity, % (6-min. average)
3.6
5.0
Pressure Drop with all compartments on-line, in H20
5.5
6.0
Pressure Drop with one compartment off-line, in H20
6.0
6.0
Pressure Drop with two compartments off-line, in H20
5.9
7.0
Wet Scrubbers: Wet scrubbers are commonly used as particulate control systems in the primary
and secondary metals industry, as well as the petroleum refinery industry. In some applications,
wet scrubbers serve also as FGD control systems. However, wet scrubbers designed primarily
for FGD and may have only moderate PM2 5 removal efficiency. Therefore, the following
discussion on the performance of wet scrubbers pertains to wet scrubbers designed and operated
for particulate removal, e.g., high-energy venturi scrubbers.
Pressure drop and throat velocities are key operating parameters for venturi scrubbers. As seen
by the design curves used for venturi scrubbers (U.S. EPA, 1991), the control efficiency for a
given size particle is highly dependent on the venturi pressure drop. For example, assuming an
aerodynamic mean particle diameter of 0.5 |im:
• A venturi with a pressure drop of 30 inches of water (in. H20) is expected to be 90%
efficient;
• A venturi with a pressure drop of 40 in. H20 is expected to be 97% efficient; and
• A venturi with a pressure drop of 50 in. H20 is expected to be 99% efficient.
The particle removal efficiency for particles greater than 2 |im is expected to be 99.9 percent, but
then starts decline for smaller particles. While a venturi with a pressure drop of 40 in. H20 is
expected to be 97% efficient for particles with a mean particle diameter of 0.5 |im, it is only
expected to be 35% efficient for particles with a mean particle diameter of 0.1 |im. Wet
scrubbers are generally ineffective for particles with diameters less than 0.1 |im. Thus, venturi
scrubbers operating at pressure drops of more than 30 in. H20 are expected to have similar
removal of coarse PM, but can have significantly different removal efficiencies for fine PM (i.e.,
particles with diameters between 0.1 |im and 2 |im) depending on the design and operating
conditions.
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5.2 Improved Methods and Modifications of PM2.5 Control
Methods to improve existing control device performance for PM2.5 are described in this section.
In general, improvements in methods and modifications to existing controls are relatively less
expensive and produce relatively smaller emission reductions than addition of innovative
controls. Their applicability to various control devices is given in parenthesis, i.e., FF (fabric
filter), ESP (electrostatic precipitator), WS (wet scrubber).
Improved Monitoring (FF. ESP. WS). One traditional method for evaluating particulate
emissions is an opacity monitor. However, opacity monitors are frequently not capable of
evaluating performance within specific modules of a control device, and also are limited in value
for low opacity emissions. Consequently, improved continuous particulate monitoring
techniques have been developed, using techniques including the triboelectric effect (in which
particle friction produces an electrical signal), and backscattering of light (as opposed to
extinction of light, which is the effect measured by opacity monitors). These improved
monitoring techniques can diagnose problems within specific sections of control devices (e.g.
fabric filter bag leak detectors dedicated to specific fabric filter modules) and can detect
problems sooner than they can be detected with traditional opacity monitors.
Addition of Conditioning Agents (ESP. WS). Pulverized-coal-fired power plants that switch to
low-sulfur coal often experience problems with high resistivity fly ash. Operators may add
"conditioning agents" to alter the properties of the ash, including attempting to lower resistivity
and increase particulate "stickiness." Conditioning agents that are added include sulfur trioxide
(S03), ammonia, trona (hydrated sodium carbonate/bicarbonate), and various proprietary agents.
Although SO3 conditioning can improve total particulate collection for ESPs, it can also lead to
increased emission of very fine particulate, resulting in a "blue plume" (Bayless et al., 2000).
Therefore, other conditioning agents are currently under evaluation. Ritzenthaler and Maziuk
(2004) report the results of an evaluation of trona injection at Unit 2 of the General James M.
Gavin Plant in Cheshire, OH. Injection of Trona (dry sorbent injection, or DSI) between the air
heater outlet and the inlet of the ESP resulted in removal of SO3. Removal rates ranged from a
low of 63 percent at approximately 1 ton per hour to a high of 86 percent at a rate of
approximately 5 tons per hour DSI. Similarly, additives can be injected in wet scrubbing
solution to help condense and remove aerosol component in the exhaust gas.
ESP Upgrades (ESP). The general label of ESP upgrades includes replacement of weighted-wire
electrodes with rigid discharge electrodes, and addition of advanced electronic controls,
including pulsed energization. The corona discharge electrodes in ESPs have traditionally been
weighted wires hung between the collecting plates. The problem with weighted wires is that the
wire can snap, causing the discharge wire to short into the grounded collecting plate. Many ESP
users and rebuilders have avoided this problem by going to rigid (non-wire) discharge electrodes.
These electrodes avoid the shorting problem that can occur with weighted-wire electrodes.
Another potential upgrade for ESPs is the conversion of antiquated electrical controls to modern
electronic controls, including the possibility of pulsed energization. Traditionally, the amount of
particulate charging that can be achieved by an ESP is limited, due to the problems of sparking
and back-corona that occur, particularly with high resistivity fly ash. Modern computerized
controls can reduce these problems; one technique is to substitute the steady voltage of
traditional ESPs with voltage pulses (pulsed energization). Pulsed energization allows for higher
voltages (improved particle charging) while minimizing the problems of back-corona and
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sparking. One proprietary version of pulsed energization is ROPE (Rapid Onset Pulsed
Energization). A pilot plant employing this technology was installed at the Miller Plant, and
reported to result in a threefold reduction in particulate penetration (Southern Company, 2004).
ESP upgrades may also include increasing the size of the precipitator (i.e., adding an additional
collection cell, either in series or in parallel). Increasing the size of the precipitator increases
treatment time: the longer a particle spends in the precipitator, the greater its chance of being
collected, other things being equal. Precipitator size also is related to the specific collection area
(SCA), the ratio of the surface area of the collection electrodes to the gas flow. Higher collection
areas tend to lead to better removal efficiencies. Modern ESPs in the U.S. have collection areas
in the range of 200-800 square feet (ft2)/1000 per actual cubic feet per minute (acfm). In order to
achieve collection efficiencies of 99.5%, specific collection areas of 350-400 ft2/1000 acfm are
typically used. Some older precipitators on utility boilers are small, with specific collection
areas below 200 ft2/1000 acfm and correspondingly short treatment times. Expansion of these
precipitators, or their replacement with larger precipitators, can lead to greatly enhanced
performance (Institute of Clean Air Companies, 2004). However, space limitations at many
plants limit the ability to significantly increase precipitator size.
Improved Filter Fabrics (FF). In the last decade, there has been increasing use of membrane-
coated fabrics (e.g., Teflon, or PTFE) in fabric filters. The membranes on these fabrics have
very small holes through which air flows. This type of filtration changes the method of filtration
from filtration caused by the deposited dust layer to filtration caused by the membrane itself.
Due to the very small holes (as small as 0.4 micrometers in diameter), penetration of PM2.5 can
be significantly reduced, as long as the membrane remains intact. Lillieblad et al. (2003)
examined PM25 and mercury emissions from a high air-to-cloth ratio fabric filter located after a
pulverized coal-fired boiler (located in Finland). The bags were polyphensulfide (PPS) with
intrinsic Teflon (PTFE) coating. At the time of testing, the bags had been in service for more
than 31,000 hours. An inspection of the filters was performed prior to the measurements, to
check that the bags were in good condition. The plant burned exclusively Polish coals. Results
of the testing indicated an overall particulate collection efficiency of 99.88 percent, a PM25
collection efficiency of 99.6 percent, and a PMi.o collection efficiency of 63.5 percent.
EPA's Environmental Technology Verification (ETV) Program has been evaluating the
performance of advanced filter materials. The materials are all tested under the same conditions
unless different test conditions are requested. The controlled conditions include flow rate, air-to-
cloth ratio, temperature, type and concentration of inlet dust, number of conditioning cycles, etc.
Although these test are performed in laboratory-type conditions and may not represent actual
performance of these materials in industrial settings, these test conditions offer excellent
comparability between the performance of different filter materials. Table 5-4 provides a
summary of the fabric filter ETV tests that have been conducted to date.
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Table 5-4. Performance Test Results from EPA's Environmental Technology
Verification Program
ISI>
P.\l-> >
(»r/dscf)
($>r/dscf)
Comment
Reference1
3.0E-05
1.4E-05
Mltr's test conditions
ETV Albany Int'l
1.0E-05
6.5E-06
ETV std test
ETV Air Purator
1.2E-04
1.1E-04
ETV std test
ETV BASF Corp
9.0E-07
9.0E-07
ETV std test
ETV BHA Group, QG061
1.7E-05
3.0E-06
ETV std test
ETV BHA Group, QP131
7.0E-06
4.5E-06
ETV std test
ETV BWF America
1.8E-04
1.6E-04
ETV std test
ETV Inspec Fibres
3.1E-05
8.3E-06
ETV std test
ETV Menardi-Criswell
3.0E-05
1.9E-05
ETV std test
ETV Polymer Group
3.2E-05
8.2E-06
Mftr's test conditions
ETV Polymer Group
8.2E-06
4.1E-06
ETV std test
ETV Standard Filter Corp
1.0E-05
2.3E-06
ETV std test
ETV Tetratec PTFE Technol., Tetratex 6212
5.2E-05
2.2E-05
ETV std test
ETV Tetratec PTFE Technol., Tetratex 8005
9.6E-06
5.9E-06
ETV std test
ETV W.L. Gore & Assoc., L4347
5.0E-06
2.1E-06
ETV std test
ETV W.L. Gore & Assoc., L4427
1 All test and summary reports referenced here are available at: http://www.epa. gov/etv/verifications/vcenter5-
2.html
Increased Scrubber Pressure Drop (WS). There are several old venturi scrubbers (30 to 50 years
old) applied to basic oxygen furnaces (BOFs) at integrated iron and steel plants and to cupolas at
iron foundries. During the development of the maximum achievable control technology
(MACT) standards for these source categories, we identified plants with scrubbers operating at
pressure drops of 25 to 30 inches of water or achieving PM control levels on the order of 0.05
grains per dry standard cubic foot (gr/dscf) and higher. For example, the venturi scrubbers at
Ispat-Inland (Lake County, IN) and AK Steel (Middletown, OH) were evaluated, and the MACT
analysis indicated they would have to be upgraded or replaced to meet the MACT standard when
it becomes effective in 2006. The higher pressure drop scrubbers are expected to reduce PM
emissions by about 50 percent. During a performance test of a cupola wet scrubber at an iron
foundry, the performance of the wet scrubber improved by from 95 percent to 99 percent as the
pressure drop increased from 33 to 42 in. H20 (U.S. EPA, 1999). Nonetheless, the MACT
standard for cupolas at iron foundries will likely force facilities with wet scrubbers to install a
baghouses when it becomes effective in 2007. That is, this foundry source, the performance
achieved by well-designed baghouses surpassed the performance of venturi scrubbers, even those
operating at high pressure drops (up to 60 in. H20).
Reduce Temperature of the Exhaust Gas Inlet to the Control Device (ESP. FF. WS). In general,
particulate control systems are ineffective at removing gaseous-phase components of the gas
stream. Most of the significant PM2.5 point source emissions occur from combustion processes
or other sources operated at high temperatures. As discussed in Section 2, exhaust gas
temperature is the primary factor influencing the state of PM-CON from stationary sources.
Reducing the temperature of the exhaust gas prior to the PM control device increases the amount
of "condensable" PM that is in particulate form within the control device. That is, at lower
temperatures, the ratio of PM2.5-FIL to PM-CON increases, and the overall PM2.5 removal
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efficiency of the control system goes up since the control systems can now effectively reduce the
"condensed" PM. The temperature of the exhaust gases can be reduced through the use of heat
recovery or other gas cooling technologies.
5.3 Innovative PM2.5 Controls
This section describes innovative control systems identified during the literature review. In
general, addition of an innovative control system will be more expensive, but yield higher PM2.5
emissions reductions than the methods identified to improve existing control device
performance.
Advanced Hybrid Collector (ESP). The Advanced Hybrid™ filter combines electrostatic
precipitation with fabric filtration. The internal geometry contains alternating rows of ESP
components (discharge electrodes and perforated collector plates) and filter bags. Particulate-
laden flue gas enters the ESP sections, and significant amounts are precipitated on the perforated
collection plates. The perforated plates also allow flue gas to be drawn through the plates to be
collected on the filter bags. The filter bags have a Gore-Tex® membrane coating, and are pulse-
cleaned (Gebert et al., 2004). An full-scale Advanced Hybrid™ collector was recently installed
on at the Big Stone Plant near Milbank, South Dakota. The goal of the project is a particulate
capture efficiency of over 99.99%. This can be compared to the original ESP, which had a
particulate capture efficiency of 99.5% (University of North Dakota Energy and Environmental
Research Center, 2004).
COHPAC (ESP). The COHPAC ("Compact Hybrid Particulate Collector") is a pulse jet filter
module operated at a very high filtration velocity (air-to-cloth ratio), installed downstream of an
ESP. The function of a COHPAC is as a "polishing filter," collecting the particulate (especially
fine particulate) that escapes an ESP. A full-scale COHPAC system has been installed at the
Gaston power plant near Birmingham, AL (Southern Company, 2004).
Indigo Particle Agglomerator (ESP). The Indigo Agglomerator was developed in Australia to
reduce visible emissions from coal fired boilers. The Indigo Agglomerator contains two
sections, a bipolar charger followed by a mixing section. The bipolar charger has alternate
passages with positive or negative charging. That is, the even passages may be positive and the
odd passages negative, or vice versa. This can be contrasted with a conventional coal fired boiler
precipitator, which has only negative charging electrodes. Following the charging sections, a
mixing process takes place, where the negatively charged particles from a negative passage are
mixed with the positively charged particles from a positive passage. The close proximity of
particles with opposite charges causes them to electrostatically attache to each other. These
agglomerates enter the precipitator, where they are easily collected due to their larger size.
Crynack et al (2004) reported on the reductions in fine particulate (PM2.5) emissions achieved
when an Indigo Agglomerator was installed at the Watson plant, a 250 MW coal fired power
plant in Mississippi. The agglomerator was installed on one of two identical, parallel
precipitators, such that the results could be compared between a precipitator with the
agglomerator and one without. Both precipitators had three mechanical zones and six electrical
zones.
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The agglomerator performance was tested with two coals, a western coal from Colorado, and an
Eastern coal from Illinois. Both coals showed significant fine particulate emission reductions
with the Indigo Agglomerator. Crynack et al. reported a "300 percent reduction" (presumably
indicating a factor of 3 reduction or, in other words, a two-thirds reduction) in the emission of
fine particles less than 5 |im in diameter, a two-thirds reduction in opacity, and a one-third
reduction in total particulate mass emission. Crynack et al. also reported that, without the
agglomerator, particle penetration peaked at 15 percent for 1 |im particles; this was reduced to 3
percent with the agglomerator. Finally, for particles with a size less than 2.5 |im, emissions were
reduced by 75 percent with both coals. Further test results are show in Table 5-5.
Table 5-5. Performance Evaluation of the Indigo Agglomerator
(Crynack et al., 2004)
Measurement
Wesl l.lk( oal.4/r/03
Wesl llk(oal. 4/1/04
Emerald Coal, 4/13/03
A Pass
BPass
%
Reduc-
tion
A Pass
BPass
11/
VO
Reduc-
tion
A Pass
BPass
%
Reduc-
tion
Opacil.y %
15
4
73.3%
20.2
7.25
64.1
13.25
2.3
82.6%
Mass Emission
Grains/acf
0.012
0.0066
45.0%
0.02369
0.0159
32.9%
0.0137
0.0082
40.1%
mg/m3
27.5
15.1
45.1%
54.3
36.3
33.1%
31.3
18.8
39.9%
lb/MMBTU
0.0382
0.0231
39.5%
0.0735
0.0475
35.4%
0.045
0.026
42.2%
Gas Flow
Acfm
408,718
450,700
-10.3%
433,093
395,412
8.7%
443,609
406,455
8.4%
m3/min, actual
11,575
12,764
-10.3%
12,265
11,198
8.7%
12,563
11,511
8.4%
Gas
Temperature
Degrees F.
276
273
1.1%
280
264
5.7%
269
260.5
3.2%
Degrees C.
135
134
0.7%
138
129
6.5%
132
127
3.8%
Wet ESP (ESP. WS. FF). As discussed previously, one significant barrier to improved ESP
performance is that increasing energy levels can lead to excessive sparking and back-corona.
This is particularly problematic with high-resistivity fly ash, as occurs with low-sulfur coals.
Another problem with ESPs is that operating at lower temperatures, which can improve
collection of condensable particulate matter, can result in condensation on the ESP collection
plates, causing corrosion. One method of avoiding these problems is a wet ESP, which bathes
the collection plates in liquid.
Farber et al. (2004) report that, for electrical utility power plants, a wet ESP is typically installed
between a wet FGD absorber and the stack, for removing remaining flyash as well as condensed
sulfuric acid. These wet ESPs may be mounted at grade for horizontal flow or on top of the
absorber for vertical flow. Utility applications include the AES Deepwater cogeneration plant in
Houston since 1986, Xcel Energy's Sherbourne County Station, and an installation on top of an
FGD absorber at New Brunswick Power's Coleson Cove plant in 2002. Also, Wisconsin Energy
selected wet ESPs for their 1000 MW Elm Road project. Farber et al. (2004) state that an
advantage of wet ESPs is increased power level (2 W/acfm, versus 0.1 to 0.5 W/acfm for a dry
ESP). They note that wet ESPs can "very effectively capture sulfuric acid aerosols (90%+)."
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Wet Membrane ESP (ESP). The wet membrane ESP attempts to avoid problems of water
channeling and resulting dry spots than can occur with wet ESPs, and avoiding the higher-cost
metals that must be employed to avoid corrosion in a traditional wet ESP. The membranes are
made from materials that transport flushing liquid by capillary action effectively removing
collected material without spraying (Southern Environmental Corporation, 2004).
Horizontal Baghouse (FF). During the development of the iron and steel foundry MACT, two
different facilities operated a cupola controlled with a baghouse with a horizontally supported
bags (referred to as a horizontal baghouse). As the bag material in this type of baghouse does
not need to be as thick and strong as a vertical baghouse simply to support the weight of the bag
and collected dust. The thinner bags, low operating temperature, and low air-to-cloth ratios of
these horizontal baghouses allowed for easier pulse-cleaning. Each of these horizontal
baghouses exhibited lower outlet PM concentrations by more than a factor of 2 compared to the
best-performing vertical baghouse system.
Tube-Slot Venturi Scrubber (WS). Reither, et al. (2001) provide interesting data for a tube-slot
venturi scrubber. Two systems are described: one with a variable tube position (analogous to a
variable throat venturi) and one with hybrid spray nozzles (spray nozzles that pulse scrubbing
liquid and pressurized air). The hybrid spray nozzles provide improved particle wetting without
the need for atomization of the spray in the venturi throat. A graph of the particle removal
efficiencies by particle size diameter is reported; the efficiencies reported appear to be equivalent
to a venturi scrubber operating at a pressure drop of 60 in. H20, but the reported pressure drop of
system was approximately 1 in. H20. Reither et al. also provide data that shows 99 percent S02
scrubbing efficiency when using a diluted sodium hydroxide scrubbing solution. Although this
system may not be able to achieve the same filterable PM removal efficiency of a fabric filter
system, this system appears to have distinct advantages in situations where both PM and S02
need to be controlled.
ElectroCore Particulate Separator (ESP) (LSR Technologies, 2002). An Advanced ElectroCore
particulate separator was designed and tested at Unit 4 of the E.C. Gaston Power plant. The
testing was conducted on a 6000 acfm slipstream from the outlet of the plant's hot side ESP.
The unit was burning low sulfur coal. The following performance was reported, based on
measurements with a P5A particulate monitoring device: With the optimum voltage applied to
the electrode, the ElectroCore unit achieved a maximum efficiency of 96.38 percent, and a
minimum outlet loading of 0.0021 gr/dscf, while operating with a specific separating area (SSA)
of 100 square feet per thousand acfm, according to measurements made by a P5A particulate
monitoring device. The minimum outlet loading corresponds to 0.00575 lbm/MMBtu, or less
than one fifth of the current New Source Performance Standard of 0.03 lbm/MMBtu. The highest
collection efficiency for the upstream ESP was 99.75 percent, so the two systems combined
achieved a collection efficiency of 99.991 percent of the particulate matter from the uncontrolled
boiler. However, measurements made with EPA Method 5 showed the Electrocore to be
approximately 85 percent efficient, versus the 95 percent measured using the P5A monitor.
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6. CONCLUSIONS, UNCERTAINTIES, AND DATA NEEDS
6.1 Conclusions
¦ Point source PM2.5 emissions significantly contribute to the overall PM2.5 balance in
many of the 16 NAAs.
As seen in Figure 3-1, point source emissions account for more than one-third of the PM25
emissions for 6 of the 16 NAAs. Furthermore, as seen in Table 4-1, if point source PM2.5
emissions can be reduced, these emission reductions could significantly contribute to the overall
attainment strategy for these and other NAAs.
¦ The performance of existing control systems for PM2.5 can be improved through
modifications, upgrades, and/or innovative control strategies.
Section 5 of this report discusses control improvements, upgrades, and innovative control
systems for PM. The potential emission reductions from the application of these systems were
estimated to reduce the controlled PM25-PRI emissions by up to 60 percent. The performance
enhancements with respect to PM25-FIL could exceed 90%; the performance enhancements with
respect to PM-CON are highly uncertain, but were estimated to range between 0 and 60 percent
(Pechan and RTI, 2005).
¦ For most NAAs, a limited number of large emission sources dominate the PM2.5
point source inventory.
As seen in Figure 3-4 and in the data provided in Appendix A, a relatively small number of point
sources account for the majority of the PM2 5 point source inventory. Within a given NAA, the
majority of emissions are typically released from the top 10 or so sources. Across all NAAs, the
top 10 percent of point sources (controlled, regulated, and uncontrolled) account for
approximately 90 percent of the PM25 point source emissions.
¦ Improving the control performance for PM2.5 point sources appears to be a high or
moderate priority option in the overall attainment strategy for many of the NAAs.
This conclusion is supported by the first two conclusions. Furthermore, as the point source
emissions within each NAA are typically dominated by a few large sources, an enhanced point
source control strategy can focus on a relatively few sources or industry sectors, thereby easing
the implementation of such a strategy.
¦ When selecting the most-effective PM control strategy, it is important to consider all
aspects that might impact ambient PM2.5 concentrations.
This project focused on direct PM2.5 emissions. It is relatively easy to conclude that a FF control
system will perform better than a WS for PM25-FIL. However, it is generally easier to cool the
gas stream in a wet versus a dry system so that the WS may perform better than a FF (especially
high-temperature FFs) for PM-CON. Additionally, a particulate WS is expected to be more-
effective in reducing S02 emissions than a FF, and the importance of these S02 emissions as a
precursor to ambient PM2 5 should be considered in the control device selection process. Finally,
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secondary impacts should also be considered as they may impact the ambient PM2.5
concentration. For example, a high-energy particulate WS is expected to consume much more
electricity than a FF system. This higher energy consumption may lead to higher PM2.5 and SO2
emissions depending on the type of electric utilities supplying power to the grid used by the point
sources within a given NAA. All of these factors must be considered in identifying the most
effective PM2.5 control system. Therefore, there is not a one-size-fits-all solution to the "best"
PM2.5 control system. The most effective control system will be dependent on the relative ratio
of PM25-FIL and PM-CON, the amount of PM2.5 precursors in the emission stream, and possibly
the emissions associated with electricity consumption for the local grid.
6.2 Uncertainties
¦ Uncertainty due to 2002 NEI being in draft form
This project used the draft 2002 NEI dated February 2005. As part of this project, an attempt
was made to augment the draft PM2.5 data in the NEI (Pechan and RTI, 2005). However, within
the project constraints, it was not possible to augment the PM2.5 draft completely. For example,
when only PM25-FIL data were reported, the PM25-PRI emissions were calculated using one of
three "default" PM25-FIL to PM25-PRI augmentation factors (specifically: 1, 2, or 5). When the
NEI is finalized, point source-specific and control device-specific ratios will be used in the
augmentation process. Additionally, some PM2.5 emission sources may be missing in the draft
NEI when the PM emissions were only reported as TSP or PM10-PRI. We augmented missing
PM25-PRI data for Louisville, KY, but we expect other emission sources are missing from the
current PM2.5 inventory. For example, PM2.5 emissions data appear to be missing for two steel
mills in Detroit, MI. It is likely that such missing data will be added by the PM augmentation
process that will be conducted on the point source NEI during October and November 2005.
¦ Uncertainties related to the PM augmentation factors
Even after the 2002 NEI is finalized, there will still be considerable uncertainty in the PM2.5
emission inventory. This is because the primary test method currently employed to measure PM
emissions from stationary sources is EPA Method 5, which measures TSP. The test method is
designed to measure total filterable particulates ("front-half' PM catch). EPA Method 202 can
be used to measure the condensable ("back-half' catch), but only a few states currently require
EPA Method 202 testing. Consequently, one PM augmentation factor is used to estimate the
fraction of TSP that is less than 2.5 |im in diameter and another PM augmentation factor is used
to estimate PM-CON. There is some uncertainty associated with the size-distribution factors, but
due to the more limited number of source test data available for PM-CON and the variability in
PM-CON emissions, there is considerable uncertainty in the PM augmentation factors.
Additionally, there is a concern that EPA Method 202 may overestimate the PM-CON due to the
adsorption of SO2. Therefore, even after the detailed PM augmentation is completed, there is
still inherent uncertainty in the PM2.5 because essentially no point sources currently directly
measure their PM2.5 emissions.
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¦ Uncertainty due to possibility that data reported as primary PM2i5 is actually
filterable PM2.5
A significant portion of the PM2.5 data reported in the 2002 draft NEI are reported as PM25-PRI
with no estimate of PM25-FIL or PM-CON. As discussed above, past experience in reviewing
the sources of data used for reporting emissions in the NEI suggest that most of the directly
reported PM25-PRI emissions are based on Method 5 source test data and application of AP-42
size fraction factors and actually reflect only PM25-FIL data. Based on a cursory uncertainty
analysis, the misreporting of PM2.5 data as PM25-PRI when the data actually represent PM25-
FIL could result in a significant underestimation of the actual PM25-PRI emissions. Across all
16 NAAs, the cursory uncertainty analysis suggests that actual PM2.5 emissions could be higher
than those reported in this report by more than a factor of two; for specific NAAs, actual PM2.5
emissions could be higher by a factor of 4 or more (Pechan and RTI, 2005).
¦ Uncertainty due to inconsistent reporting of PM2i5 point source emissions between
NAAs
The size of the emission sources that each NAA includes in its point versus nonpoint source
inventory may vary between NAAs. For example, some state and local agencies include in their
point source inventories emissions for sources that emit at or above the reporting thresholds
specified in the Consolidated Emissions Reporting Rule. Emissions for point sources that emit
less than the reporting thresholds may be summed to the county-level and included in their
nonpoint inventory submittal to EPA which are then included in the nonpoint NEI. Other NAAs
may include all permitted sources in their point source inventory including sources that emit
below the Consolidated Emissions Reporting Rule emissions thresholds. Given the required
reporting thresholds, it is possible a significant mass of PM2.5 point source emissions may
currently be included in the nonpoint inventory. As a result, the importance of improved point
source PM2.5 control as a candidate compliance option may be understated for these NAAs.
¦ Uncertainty due to inaccurate reporting of control device information
In reviewing the draft NEI we suspect that the control information reported for some NAAs is
not reported or is reported incorrectly. For example, several coal-fired electric utility boilers
were reported as "uncontrolled" where, in fact, we believe all coal-fired electric utility boilers
will have some form of PM control. Also, several foundry sources that are known to have a
control device were reported as "uncontrolled." If "uncontrolled" emission factors were applied
to estimate the emissions from these sources, then the reported emissions for these could be
significantly overstated. Additionally, certain large emission sources were identified, such as
coke oven doors, that are subject to work practice or equipment standards to reduce their
emissions. Although they do not have an external air pollution control device, it is misleading to
characterize these emissions as completely uncontrolled since the current emissions from these
sources has been significantly reduced through source-specific opacity limits or work practice
standards. Again, the emissions from these sources may be over-estimated if "uncontrolled"
emission factors are used for these sources.
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¦ Uncertainty in the PM2.5 emission estimates for coal-fired electric utility boilers
This project was based on point source PM2.5 emissions from the draft 2002 NEI. However, The
Mcllvaine Company has published its own estimates of PM2.5 emissions from coal-fired electric
utility boilers. Mcllvaine has estimated nationwide fly ash (filterable) PM2.5 emissions from
coal-fired electric utility boilers are between 3 and 17 times higher than those in the (1999) NEI
(Mcllvaine, undated). Coal-fired electric utility boilers are significant sources of PM2.5 in nearly
all the NAAs investigated for this project. Therefore, uncertainties in the PM2.5 emission
estimates for this source category greatly impact the overall PM2.5 emissions inventory.
Although it appears that Mcllvaine's emission estimates for electric utilities focuses on the
filterable PM2.5 emission, condensable PM emissions are generally calculated based on the
filterable PM emission estimates. Therefore, if Mcllvaine's emission estimates for filterable
PM2.5 emissions are accurate, this also suggests that the current PM-CON estimates may be
understated in the NEI.
¦ Uncertainty in the fraction of PM2.5 ambient concentrations attributable to local
direct PM25-PRI emissions.
There are two factors contributing to this uncertainty: one is the so-called "regional"
contribution of PM2.5 and the other is the contribution of secondary PM2.5 for the specific
locations monitoring locations that exceed the PM2.5 NAAQS. For the purposes of evaluating
the relative significance of the point sources, it was assumed that 40% of the ambient PM2.5
concentration was attributable to local direct PM25-PRI emissions. This factor was based on the
regional average the percent of ambient PM that was not sulfate or nitrate PM. However, the
relative composition of PM in the specific NAAs may differ from these regional averages.
Additionally, transport distances PM2.5 can be significant. Therefore, some of the non-sulfate,
non-nitrate PM is likely attributable to PM sources outside of the NAA. Some articles were
found that reported "regional" contribution to "local" PM levels, but the methods used to
develop the "regional" contributions were not well documented and appeared to exaggerate the
regional contribution (if these regional contributions were accurate, then there should be more
NAAs). Nonetheless, the approach used in this report likely overestimates the ambient PM2.5
concentration reductions that can be achieved by control of "local" PM sources. Based on the
literature reviewed during this research, "regional" contribution to the carbon component of
particulates is estimated to be 50 percent (U.S. EPA, 2004)
6.3 Data Needs and Recommendations for Future Work
¦ Update and verify the results of this analysis after finalization of the 2002 NEI
Some of the uncertainties discussed in Section 6.2 are expected to be reduced after the PM
augmentation of the 2002 draft NEI is completed. It would be relatively straight-forward, at that
point, to re-analyze the augmented data to verify the primary findings of this report.
¦ Verify/audit data reported in the NEI
As discussed under the uncertainties, incorrect reporting of PM25-FIL data as PM25-PRI can
result in a significantly underestimation of the actual PM25-PRI emissions. Furthermore, some
sources appeared to have unexpectedly high emissions, while PM2.5 data appeared to be missing
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for some relatively large sources. Although the PM augmentation performed to finalize the 2002
inventory is expected to fill-in "missing" PM2.5 data, it will not necessarily verify correct
reporting. It is recommended that a sample of sources that currently only report PM25-PRI data
be evaluated to determine the sources of these emission estimates and to ascertain if the reported
data are estimates of PM25-PRI or PM25-FIL emissions. Furthermore, suspect data points, such
as those reported for American Commercial Terminals in St. Louis and Techneglas, Inc. in
Columbus, should be reviewed for accuracy and realism.
We also recommend that the criteria that the NAAs use for determining what they included in
their point and nonpoint inventories be evaluated to determine if there are inconsistencies
between NAAs based on the reporting thresholds. This information will help to improve
evaluation of the importance of PM2.5 point sources in the total PM2.5 emission inventory.
To address uncertainties related to non-reported or incorrectly reported control information, we
recommend that the control information reported in the final 2002 NEI be verified with each
NAA. An evaluation of the emissions reported for selected controlled sources that are currently
reported as "unknown" or "uncontrolled" will be useful to determine if the emission factors used
overstate the emissions expected for the controlled emission source. It may be necessary to add
codes to identify work practice or additional control practices to the list of control device codes
used in the NEI. The inclusion of codes that identify control methods not currently included in
the list of approved control codes for the NEI will improve understanding of the basis of the
reported emissions and the accuracy of the analyses for determining where real reductions can be
achieved for direct emissions of PM2 5.
¦ Project the 2002 PM2i5 emission estimates forward in time
The analysis for this project was based on emissions as reported in the draft 2002 NEI.
However, it is known that some plants have already installed additional controls that are not
reflected in the draft 2002 NEI emissions data. For example, in the Birmingham, AL, NAA,
Alabama Power's Gaston Plant Unit 3 has already installed a COHPAC (Compact Hybrid
Particulate Collector); COHPAC is one of the innovative controls examined in this report. Other
coal-fired utility boilers will be installing various controls to meet CAIR and the Mercury Rule
in the near future. Recent standards have also been promulgated that will reduce the PM
emissions from coke ovens, iron and steel foundries, and petroleum refineries. The impact of
these regulations on the PM2.5 emissions inventory should be evaluated to better inform decision-
makers who are attempting to develop attainment strategies.
¦ Perform detailed evaluations of potential PM2.5 control improvement options for
major PM2.5 sources
As described in Section 6.1, the identification of the "best" control system for overall PM2.5
requires a relatively detailed assessment that is source-specific. Given the relative importance of
electric utilities and integrated iron and steel plants in the PM2.5 emission inventories for the 16
NAAs, specific PM2.5 control strategies should be pursued for these sources. By focusing on
selected industry sectors, more accurate evaluations could be performed of the emissions
reductions that could be achieved. Additionally, specific upgrades or control systems can be
recommended based on the existing control devices for key individual sources. This information
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September 30, 2005
would be highly useful for state and local agencies developing specific attainment strategies and
it would greatly improve the accuracy of estimated emission reductions for scenario modeling.
¦ Review/revise PM2.5 emission estimates and PM augmentation factors for electric
utilities
Due to the significance of this industry category in the PM2.5 emission inventory, the emission
estimates for coal-fired electric utilities needs to be as accurate as possible. Underestimates of
the PM2.5 emissions from these sources by a factor of 3 to 17, as reported by Mcllvaine, could
have huge implications regarding potential attainment strategies. The first step in resolving this
discrepancy is to solicit additional information about Mcllvaines emission estimates in an
attempt to understand the reasons for the large differences in estimated emissions. Mcllvaine's
emission estimates for each electric utility in the NEI could be compared with the emissions
reported in the 2002 NEI. Most of the data reported in the NEI for electric utilities is based on
source test data; these test data can be reviewed and compared to Mcllvaine's estimates to assess
the relative accuracy of his approach. However, some of the uncertainty may lie in the PM
augmentation factors used to estimate PM25-PRI emissions from Method 5 (TSP) source test
data. Therefore, an additional task would be to perform specific PM2.5 emissions testing at a
number of coal-fired electric utilities to determine which emission estimating approach is most
accurate for PM25-PRI. Alternatively, continuous PM monitoring techniques may be used to
assess the variability in PM emissions from these sources over one year to assess the accuracy of
using annual source test data (typically representing only 3 to 6 hours of operation) to project
annual emissions. Finally, the results of this evaluation can be used to update the emission
factors and PM augmentation factors currently reported in AP-42 (U.S. EPA, 1995).
¦ Review/revise PM2.5 emission factors for integrated iron and steel plants
Due to the significance of this industry category in the PM2.5 emission inventory for certain
NAAs, the emission estimates for integrated iron and steel plants needs to be as accurate as
possible. Certain large emission sources were identified, such as coke oven doors, that are
subject to work practice or equipment standards to reduce their emissions, but are characterized
as "uncontrolled" in the NEI. This leads to questions regarding the emission factors used to
estimate the emissions from these sources: do they adequately reflect current practices? The
AP-42 emission factors for this industry have not been updated for almost 20 years (U.S. EPA,
1995). The "Iron and Steel Production" section of AP-42 needs to be updated to reflect current
industry practices and emissions.
¦ Evaluate performance of particulate controls on condensable PM2.5
An initial review of literature indicated that essentially no testing has been done to measure
PM-CON at the inlet and outlet of ESPs and FFs, although limited data do exist for PM-CON at
the outlet of control devices. Given the variability observed in PM-CON emissions for similar
sources, it is difficult to assess the performance of different control systems on PM-CON.
Additionally, current information suggests that PM-CON probably represents a substantial
majority of primary PM2.5 emissions for many combustion sources, such as coal-fired utility
boilers. Therefore, a research program that conducts physical measurements of the collection
efficiency of ESPs and FFs for PM-CON from coal-fired utility boilers, primary metal sources,
and cement kilns would be very valuable. Alternatively, it may be possible to estimate PM-CON
Pechan Report No. 05.09.011/9012-452
31
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PECHAN
September 30, 2005
collection efficiency for control devices on the basis of outlet measurements alone (if more PM-
CON test data were identified or PM-CON testing was more widely required).
On a similar note, one specific research program related to PM-CON that would be valuable is
an assessment of the efficiency of activated carbon injection as a PM-CON control technique.
Activated carbon injection is currently being evaluated as a means to control mercury from coal-
fired electric utilities. This practice may well be effective in reducing certain types of
condensable matter. If this technique is effective in reducing PM-CON, the co-benefit of this
control alternative may increase its utilization.
¦ Evaluate PM2.5 speciation data for the 16 NAAs
To reduce uncertainties and inaccuracies with the current projection of the importance of point
source emissions in the ambient PM2.5 concentration, NAA-specific data can be compiled from
the Speciated Trends Network (STN). These data are easily obtained and can be used to provide
a more accurate assessment of the secondary PM fraction of ambient PM2.5 for each NAA.
Additionally, the detailed compositional analysis can be evaluated using source apportionment
techniques to provide further insight regarding the importance of "local" versus "regional"
contribution to the overall ambient PM2.5 concentration for each NAA. This effort would require
substantially more effort, but would help to answer pertinent and pressing questions currently
being considered by various state, local, and regional organizations.
7. REFERENCES
Bayless, David J., Ashikur R. Khan, Srinivas Tanneer, and Rajkumar Birru, 2000. "An
Alternative to S03 Injection for Fly Ash Conditioning. Journal of the Air and Waste
Management Association, Volume 50, February 2000.
Crynack, Robert, Rodney Truce, Wallis Harrison, 2004. "Reducing Fine Particulate Emissions
from U.S. Coals Using the Indigo Agglomerator." Paper Number 04-A-42-AWMA,
presented at the 2004 Air &Waste Management Association (AWMA) Combined Power
Plant Control Mega Symposium.
Farber, Paul S., Daniel L. Maimer, William DePriest, 2004. "Condensible Particulate Matter:
Sources and Control in Coal-Fired Power Plants." Paper Number 17, presented at the
2004 Air &Waste Management Association (AWMA) Combined Power Plant Control
Mega Symposium.
Gebert, Richard, Craig Rinschler, Dwight Davis, Ulrich Leibacher, Peter Studer, Walter Eckert,
William Swanson, Jeffrey Endrizzi, Thomas Hrdlicka, Stanley J. Miller, Michael L.
Jones, Ye Zhuang, and Michael Collings, 2004. "Commercialization of the Advanced
Hybrid™ Filter Technology." Available at:
http://www.netl.doe.gov/publications/proceedings/02/air q3/Gerbert.pdf.
Accessed August 26, 2005.
Institute of Clean Air Companies, 2004. "Control Technology Information." Available at:
http://www.icac.eom/controls.html#esp. Accessed September 25, 2005.
Pechan Report No. 05.09.011/9012-452
32
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PECHAN
September 30, 2005
Lillieblad, L. and P. Wieslander, 2003. "PM2.5 and Mercury Emissions From a High Ratio
Fabric Filter After a Pulverized Coal Fired Boiler." Paper #200 at 2003 Air & Waste
Management Association Combined Power Plant Control Mega Symposium. Available
at: http://www.icac.com/controlhg/MEGA03 200.pdf. Accessed August 26, 2005.
Lind, Tertaliisa, Jouni Hokkinen, Jorma K. Jokiniemi, Sanna Saarikosi and Risto Hillamo, 2003.
"Electrostatic Precipitator Collection Efficiency and Trace Element Emissions from Co-
Combustion of Biomass and Recovered Fuel in Fluidized-Bed Combustion."
Environmental Science and Technology. 2003, 37, 2842-2846.
LSR Technologies, 2002. "Integrated System to Control Primary PM 2.5 From Electric Power
Plants." Available at:
http://www.netl.doe.gov/coal/E&WR/pm/pubs/LSR%20Final%20Report.pdf. Accessed
September 29, 2005.
Mcllvaine, undated. "Escalating Payment Plan for Particulate Needed Now." Available at:
http://www.mcilvainecompanv.com/NAtoAPC/escalating payment plan for part.htm.
Accessed September 29, 2005.
Pechan, E.H and Associates, and RTI, International, 2005. "Evaluation of Potential PM2.5
Reductions by Improving Performance of Control Devices:
PM2.5 Emission Estimates." Final Report, September 2005. Prepared for U.S.
Environmental Protection Agency, Research Triangle Park, NC.
Porle, K., N. Klippel, O. Riccius, E.I. Kauppinen, and T. Lind, 1995. "Full Scale ESP
Performance After PC-Boilers Firing Low Sulfur Coals." In Proceedings of EPRI/DOE
International Conference on Managing Hazardous and Particulate Air Pollutants, August
15-17, 1995, Toronto, Canada.
Ritzenthaler, Douglas P. and John Maziuk, 2004. "Successful Mitigation of SO3 Emissions
While Simultaneously Enhancing ESP Operation at the General James M. Gavin Plant in
Cheshire, Ohio by Employing Dry Sorbent Injection of Trona Upstream of the ESP."
Paper #8 at the 2004 A&WMA/EPA/DOE/EPRI Combined Power Plant Air Pollutant
Control Symposium in Washington DC, August 30 - September 2, 2004.
Reither, K., G.-G Borger., U. Listner, and M. Schweitzer, 2001. "Separation of finest dusts in
venturi scrubber with hybrid nozzles." Chemical Engineering and Technology, v 24, n 3,
March, 2001, p 238-241.
Southern Company, 2004. "Emission Control Systems." Available at:
http://www.southerncompanv.com/gapower/about/pdf/Air%20Qualitv.pdf. Accessed
August 26, 2005.
Southern Environmental Corporation, 2004. "Membrane WESP: A Lower Cost Way to Reduce
PM2.5, SO3 & Hg+2 Emissions." Available at:
http://www.southernenvironmental.com/ pdf/12 Dec MEMRANE WESP REPORT 4t
hRev.pdf. Accessed August 26, 2005.
Pechan Report No. 05.09.011/9012-452
33
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PECHAN
September 30, 2005
University of North Dakota Energy and Environmental Research Center, 2004. "Advanced
Hybrid Filter." Available at:
http://www.undeerc.org/commercialization/proiects/hybrid.asp. Accessed August 26,
2005.
U.S. EPA, 1991. Handbook: Control Technologies for Hazardous Air Pollutants, U.S.
Environmental Protection Agency, Office of Research and Development, Washington,
DC. EPA/625/6-91/014. June, 1991.
U.S. Environmental Protection Agency. 1995. Compilation of Air Pollutant Emission Factors,
Office of Air Quality Planning and Standards, AP-42, vol. 1, 5th ed.. Research Triangle
Park, NC. January, 1995.
U.S. EPA, 1997. Stationary Source Control Techniques for Fine Particulate Matter, U.S.
Environmental Protection Agency, Office of Air Quality Planning and Standards,
Research Triangle Park, NC. EPA-452-R-97-001. 1997.
U.S. EPA, 1999. Iron and Steel Foundries Manual Emissions Testing of Cupola Wet Scrubber at
General Motors Corp., Saginaw, Michigan." U.S. Environmental Protection Agency,
Office of Air Quality Planning and Standards, Research Triangle Park, NC. EPA-454/R-
99-025A and EPA-454/R-99-025B. July 1999.
U.S. EPA, 2004. The Particle Pollution Report: Current Understanding of Air Quality and
Emissions through 2003. Office of Air Quality Planning and Standards, Research
Triangle Park, NC. EPA 454-R-04-002. December, 2004.
Wolf, Don, Fred Campbell, and Dana Gregory, 2004. "Pulse Jet Fabric Filter Retrofit and
Results at Craig Station Units 1 & 2." Paper #88 at 2004 Air & Waste Management
Association Combined Power Plant Control Symposium in Washington DC, August 30 -
September 2, 2004.
Pechan Report No. 05.09.011/9012-452
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PECHAN September 30, 2005
APPENDIX A. TOP PM2 5 POINT EMISSION SOURCES BY
N ON ATTAINMENT AREA
Pechan Report No. 05.09.011/9012-452
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September 30, 2005
Table A-1. Top P
VI2.5 Point Emission Sources for Atlanta, GA Nonattainment Area
Facility Name
see
see L2
SCC L3
SCC L4
PM25-PRI
Emissions
(tpv)
Control
Classification
Georgia Power Company,
Bowen Steam-Electric
Generating Plant
10100212
Electric
Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Tangential) (Bituminous
Coal)
806
Controlled
Georgia Power Company,
Bowen Steam-Electric
Generating Plant
10100212
Electric
Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Tangential) (Bituminous
Coal)
732
Controlled
Georgia Power Company,
Bowen Steam-Electric
Generating Plant
10100212
Electric
Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Tangential) (Bituminous
Coal)
508
Controlled
Georgia Power Company,
Branch Steam-Electric
Generating Plant
10100212
Electric
Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Tangential) (Bituminous
Coal)
384
Controlled
Georgia Power Company,
Branch Steam-Electric
Generating Plant
10100212
Electric
Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Tangential) (Bituminous
Coal)
376
Controlled
Georgia Power Company,
Wansley Steam-Electric
Generating Plant
10100212
Electric
Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Tangential) (Bituminous
Coal)
272
Controlled
Georgia Power Company,
Bowen Steam-Electric
Generating Plant
10100212
Electric
Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Tangential) (Bituminous
Coal)
211
Controlled
Georgia Power Company,
Wansley Steam-Electric
Generating Plant
10100212
Electric
Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Tangential) (Bituminous
Coal)
195
Controlled
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September 30, 2005
Table A-2. Top PM2.5 Point Emission Sources for Birmingham, AL Nonattainment Area
Alabama Power Company
(Miller Power Plant)
10100202
Electric
Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Bituminous Coal)
1,320
Controlled
Drummond Company, Inc.
30300303
Primary Metal
Production
By-product Coke
Manufacturing
Oven Pushing
1,225
Regulated
Alabama Power Company
(Miller Power Plant)
10100202
Electric
Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Bituminous Coal)
850
Controlled
United States Steel Corporation-
Fairfield Pipe Mil
30300999
Primary Metal
Production
Steel Manufacturing (See
3-03-015 for Integrated
Iron & Steel MACT)
Other Not Classified
809
Uncontrolled
Alabama Power Company
10100212
Electric
Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Tangential) (Bituminous
Coal)
554
Controlled
Alabama Power Company
(Miller Power Plant)
10100202
Electric
Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Bituminous Coal)
428
Controlled
Sloss Industries Corporation -
Coke/Utilities/Btf
30300306
Primary Metal
Production
By-product Coke
Manufacturing
Oven Underfiring
362
Regulated
Sloss Industries Corporation -
Coke/Utilities/Btf
30300306
Primary Metal
Production
By-product Coke
Manufacturing
Oven Underfiring
362
Regulated
United States Steel Corporation -
Fairfield Works
30300825
Primary Metal
Production
Iron Production (See 3-03-
015 for Integrated Iron &
Steel MACT)
Cast House
333
Controlled
Nucor Steel Birmingham,Inc.
30300904
Primary Metal
Production
Steel Manufacturing (See
3-03-015 for Integrated
Iron & Steel MACT)
Electric Arc Furnace: Alloy
Steel (Stack)
318
Regulated
United States Steel Corporation -
Fairfield Works
30300999
Primary Metal
Production
Steel Manufacturing (See
3-03-015 for Integrated
Iron & Steel MACT)
Other Not Classified
311
Controlled
American Cast Iron Pipe
Company
30400301
Secondary Metal
Production
Grey Iron Foundries
Cupola
306
Controlled
U. S. Pipe & Foundry Company
Inc.(No. B'ham Plant)
30400301
Secondary Metal
Production
Grey Iron Foundries
Cupola
305
Controlled
United States Steel Corporation -
Fairfield Works
30300999
Primary Metal
Production
Steel Manufacturing (See
3-03-015 for Integrated
Iron & Steel MACT)
Other Not Classified
279
Controlled
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September 30, 2005
Table A-2. Top PM2.s Point Emission Sources for Birmingham, AL Nonattainment Area
United States Steel Corporation -
Fairfield Works
30300999
Primary Metal
Production
Steel Manufacturing (See
3-03-015 for Integrated
Iron & Steel MACT)
Other Not Classified
279
Controlled
Alabama Power Company
10100201
Electric
Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Wet Bottom
(Bituminous Coal)
274
Controlled
Alabama Power Company
(Miller Power Plant)
10100202
Electric
Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Bituminous Coal)
271
Controlled
United States Steel Corporation -
Fairfield Works
30300922
Primary Metal
Production
Steel Manufacturing (See
3-03-015 for Integrated
Iron & Steel MACT)
Continuous Casting
252
Regulated
U. S. Pipe & Foundry
Company,Inc. (Bessemer Plant)
30400301
Secondary Metal
Production
Grey Iron Foundries
Cupola
248
Controlled
Drummond Company, Inc.
30300306
Primary Metal
Production
By-product Coke
Manufacturing
Oven Underfiring
240
Regulated
Smi Steel, Inc.
30300933
Primary Metal
Production
Steel Manufacturing (See
3-03-015 for Integrated
Iron & Steel MACT)
Reheat Furnaces
229
Regulated
Smi Steel, Inc.
30300908
Primary Metal
Production
Steel Manufacturing (See
3-03-015 for Integrated
Iron & Steel MACT)
Electric Arc Furnace: Carbon
Steel (Stack)
215
Controlled
United States Steel Corporation -
Fairfield Works
30300899
Primary Metal
Production
Iron Production (See 3-03-
015 for Integrated Iron &
Steel MACT)
See Comment **
197
Regulated
American Cast Iron Pipe
Company
30300920
Primary Metal
Production
Steel Manufacturing (See
3-03-015 for Integrated
Iron & Steel MACT)
Hot Metal Desulfurization
153
Controlled
Drummond Company, Inc.
30300303
Primary Metal
Production
By-product Coke
Manufacturing
Oven Pushing
148
Controlled
Sloss Industries Corporation -
Coke/Utilities/Btf
30300303
Primary Metal
Production
By-product Coke
Manufacturing
Oven Pushing
144
Regulated
Alabama Power Company
10100202
Electric
Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Bituminous Coal)
143
Controlled
Lehigh Cement Company
30500606
Mineral Products
Cement Manufacturing
(Dry Process)
Kilns
140
Controlled
Drummond Company, Inc.
30300304
Primary Metal
Production
By-product Coke
Manufacturing
Quenching
124
Regulated
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September 30, 2005
Table A-2. Top PM2.s Point Emission Sources for Birmingham, AL Nonattainment Area
Facility Name
see
see L2
SCC L3
SCC L4
PM25-PRI
Emissions
(tpv)
Control
Classification
Drummond Company, Inc.
30300304
Primary Metal
Production
By-product Coke
Manufacturing
Quenching
124
Regulated
Mcwane Cast Iron Pipe Co.
30400301
Secondary Metal
Production
Grey Iron Foundries
Cupola
111
Controlled
United States Steel Corporation -
Fairfield Works
30300824
Primary Metal
Production
Iron Production (See 3-03-
015 for Integrated Iron &
Steel MACT)
Blast Heating Stoves
108
Regulated
United States Steel Corporation -
Fairfield Works
30300823
Primary Metal
Production
Iron Production (See 3-03-
015 for Integrated Iron &
Steel MACT)
Charge Materials:
T ransfer/Handling
108
Controlled
Drummond Company, Inc.
30300303
Primary Metal
Production
By-product Coke
Manufacturing
Oven Pushing
105
Controlled
Drummond Company, Inc.
30300303
Primary Metal
Production
By-product Coke
Manufacturing
Oven Pushing
105
Controlled
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PECHAN
September 30, 2005
Table A-3. Top PM2.5 Point Emission Sources for Canton-Massilon, OH Nonattainment Area
Facility Name
see
see L2
SCC L3
SCC L4
PM25-PRI
Emissions
(tpv)
Control
Classification
The Timken Company - Steel
Plants
30300999
Primary Metal
Production
Steel Manufacturing (See
3-03-015 for Integrated
Iron & Steel MACT)
Other Not Classified
34
Controlled
Republic Engineered Products
Lie
30300904
Primary Metal
Production
Steel Manufacturing (See
3-03-015 for Integrated
Iron & Steel MACT)
Electric Arc Furnace: Alloy
Steel (Stack)
28
Controlled
The Timken Company - Steel
Plants
30300999
Primary Metal
Production
Steel Manufacturing (See
3-03-015 for Integrated
Iron & Steel MACT)
Other Not Classified
23
Uncontrolled
The Timken Company - Bearing
Plants
39999999
Miscellaneous
Manufacturing
Industries
Miscellaneous Industrial
Processes
See Comment **
20
Uncontrolled
The Timken Company - Bearing
Plants
39999999
Miscellaneous
Manufacturing
Industries
Miscellaneous Industrial
Processes
See Comment **
16
Uncontrolled
Marathon Ashland Petroleum
LLC, Canton Refinery
30600201
Petroleum
Industry
Catalytic Cracking Units
Fluid Catalytic Cracking Unit
15
Controlled
The Timken Company - Bearing
Plants
39999999
Miscellaneous
Manufacturing
Industries
Miscellaneous Industrial
Processes
See Comment **
12
Uncontrolled
The Timken Company - Bearing
Plants
39999999
Miscellaneous
Manufacturing
Industries
Miscellaneous Industrial
Processes
See Comment **
11
Uncontrolled
The Timken Company - Steel
Plants
30300999
Primary Metal
Production
Steel Manufacturing (See
3-03-015 for Integrated
Iron & Steel MACT)
Other Not Classified
11
Controlled
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September 30, 2005
Table A-4. Top PM2.5 Point Emission Sources for Charleston, WV Nonattainment Area
Facility Name
see
see L2
SCC L3
SCC L4
PM25-PRI
Emissions
(tpv)
Control
Classification
Appalachian Power - John E
Amos Plant
10100202
Electric
Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Bituminous Coal)
527
Controlled
Appalachian Power - John E
Amos Plant
10100202
Electric
Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Bituminous Coal)
281
Controlled
Appalachian Power - John E
Amos Plant
10100202
Electric
Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Bituminous Coal)
276
Controlled
Appalachian Power - Kanawha
River Plant
10100202
Electric
Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Bituminous Coal)
243
Controlled
Appalachian Power - Kanawha
River Plant
10100202
Electric
Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Bituminous Coal)
235
Controlled
Union Carbide (Dow) So.
Charleston Plant
10200202
Industrial
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
60
Controlled
Table A-5. Top PM2.5
3oint Emission Sources for Chattanooga, TN-GA Nonattainment Area
Facility Name
SCC
SCC L2
SCC L3
SCC L4
PM25-PRI
Emissions
(tpv)
Control
Classification
TVA
10100202
Electric
Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Bituminous Coal)
428
Controlled
TVA
10100202
Electric
Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Bituminous Coal)
297
Controlled
TVA
10100202
Electric
Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Bituminous Coal)
49
Controlled
E. I. du Pont de Nemours and
Company
10200204
Industrial
Bituminous/Subbituminous
Coal
Spreader Stoker
39
Uncontrolled
Smurfit-Stone Stevenson
10200401
Industrial
Residual Oil
Grade 6 Oil
23
Controlled
Smurfit-Stone Stevenson
10200401
Industrial
Residual Oil
Grade 6 Oil
22
Controlled
Pechan Report No. 05.09.011/9012-452
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September 30, 2005
Table A-6. Top PM2.5 Point Emission Sources for Chicago-Gary-Lake County, IL-IN Nonattainment Area
Ispat Inland Inc.
30300999
Primary Metal
Production
Steel Manufacturing (See
3-03-015 for Integrated
Iron & Steel MACT)
Other Not Classified
1,000
Uncontrolled
Bethlehem Steel Corp. - Burns
Harbor
30300308
Primary Metal
Production
By-product Coke
Manufacturing
Oven/Door Leaks
261
Regulated
Bethlehem Steel Corp. - Burns
Harbor
30300308
Primary Metal
Production
By-product Coke
Manufacturing
Oven/Door Leaks
259
Regulated
U S Steel Co Gary Works
30300306
Primary Metal
Production
By-product Coke
Manufacturing
Oven Underfiring
234
Regulated
U S Steel Co Gary Works
30300306
Primary Metal
Production
By-product Coke
Manufacturing
Oven Underfiring
217
Regulated
BP Products North America Inc,
Whiting R
30600201
Petroleum
Industry
Catalytic Cracking Units
Fluid Catalytic Cracking Unit
168
Controlled
State Line Energy LLC
10100223
Electric
Generation
Bituminous/Subbituminous
Coal
Cyclone Furnace
(Subbituminous Coal)
144
Controlled
Bethlehem Steel Corp. - Burns
Harbor
30300825
Primary Metal
Production
Iron Production (See 3-03-
015 for Integrated Iron &
Steel MACT)
Cast House
143
Regulated
U S Steel Co Gary Works
30300999
Primary Metal
Production
Steel Manufacturing (See
3-03-015 for Integrated
Iron & Steel MACT)
Other Not Classified
140
Controlled
Cokenergy Inc.
30300315
Primary Metal
Production
By-product Coke
Manufacturing
Gas By-product Plant
138
Controlled
U S Steel Co Gary Works
30300817
Primary Metal
Production
Iron Production (See 3-03-
015 for Integrated Iron &
Steel MACT)
Cooler
124
Regulated
BP Products North America Inc,
Whiting R
10200401
Industrial
Residual Oil
Grade 6 Oil
115
Uncontrolled
U S Steel Co Gary Works
30300999
Primary Metal
Production
Steel Manufacturing (See
3-03-015 for Integrated
Iron & Steel MACT)
Other Not Classified
114
Controlled
BP Products North America Inc,
Whiting R
30600701
Petroleum
Industry
Cooling Towers
Cooling Towers
104
Uncontrolled
BP Products North America Inc,
Whiting R
30600201
Petroleum
Industry
Catalytic Cracking Units
Fluid Catalytic Cracking Unit
101
Controlled
Pechan Report No. 05.09.011/9012-452
A-8
-------
PECHAN
September 30, 2005
Table A-6. Top PM2.s Point Emission Sources for Chicago-Gary-Lake County, IL-IN Nonattainment Area
Facility Name
see
see L2
SCC L3
SCC L4
PM25-PRI
Emissions
(tpv)
Control
Classification
U S Steel Co Gary Works
30300306
Primary Metal
Production
By-product Coke
Manufacturing
Oven Underfiring
98
Regulated
Nipsco - Bailly Station
10100203
Electric
Generation
Bituminous/Subbituminous
Coal
Cyclone Furnace
(Bituminous Coal)
97
Controlled
ISG Indiana Harbor Inc.
30300917
Primary Metal
Production
Steel Manufacturing (See
3-03-015 for Integrated
Iron & Steel MACT)
Tapping: BOF
97
Regulated
U S Steel Co Gary Works
30300306
Primary Metal
Production
By-product Coke
Manufacturing
Oven Underfiring
95
Regulated
Bethlehem Steel Corp. - Burns
Harbor
30390004
Primary Metal
Production
Fuel Fired Equipment
Process Gas: Process Heaters
93
Uncontrolled
Pechan Report No. 05.09.011/9012-452
A-9
-------
PECHAN
September 30, 2005
Table A-7. Top Pl\
H2.5 Point Emission Sources for Cincinnati-Hamilton, OH-KY-IN Nona!
tainmenl
Area
East Bend
10100202
Electric
Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Bituminous Coal)
501
Controlled
Cinergy Corp Miami Fort Station
10100202
Electric
Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Bituminous Coal)
423
Controlled
Cinergy Corp Miami Fort Station
10100202
Electric
Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Bituminous Coal)
187
Controlled
AK Steel Corporation
30300813
Primary Metal
Production
Iron Production (See 3-03-
015 for Integrated Iron &
Steel MACT)
Windbox
153
Controlled
Cinergy CG&E WC Beckjord
Station
10100212
Electric
Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Tangential) (Bituminous
Coal)
153
Controlled
Cincinnati Gas & Electric Co.,
Wm. H. Zimmer
10100202
Electric
Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Bituminous Coal)
131
Controlled
AK Steel Corporation
30300306
Primary Metal
Production
By-product Coke
Manufacturing
Oven Underfiring
130
Controlled
Cincinnati Machine Div. Unova
I.A.S.
10200204
Industrial
Bituminous/Subbituminous
Coal
Spreader Stoker
115
Controlled
Cinergy CG&E WC Beckjord
Station
10100212
Electric
Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Tangential) (Bituminous
Coal)
97
Controlled
Cinergy CG&E WC Beckjord
Station
10100202
Electric
Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Bituminous Coal)
88
Controlled
Cinergy CG&E WC Beckjord
Station
10100212
Electric
Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Tangential) (Bituminous
Coal)
78
Controlled
Cincinnati Machine Div. Unova
I.A.S.
10200204
Industrial
Bituminous/Subbituminous
Coal
Spreader Stoker
77
Controlled
AK Steel Corporation
30300825
Primary Metal
Production
Iron Production (See 3-03-
015 for Integrated Iron &
Steel MACT)
Cast House
74
Controlled
Cinergy CG&E WC Beckjord
Station
10100212
Electric
Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Tangential) (Bituminous
Coal)
72
Controlled
Pechan Report No. 05.09.011/9012-452
A-10
-------
PECHAN
September 30, 2005
Table A-7. Top Pl\
/12.5 Point Emission Sources for Cincinnati-Hamilton, OH-KY-IN Nona!
tainmenl
Area
Facility Name
see
see L2
SCC L3
SCC L4
PM25-PRI
Emissions
(tpv)
Control
Classification
AK Steel Corporation
30300917
Primary Metal
Production
Steel Manufacturing (See
3-03-015 for Integrated
Iron & Steel MACT)
Tapping: BOF
72
Controlled
AK Steel Corporation
30300917
Primary Metal
Production
Steel Manufacturing (See
3-03-015 for Integrated
Iron & Steel MACT)
Tapping: BOF
70
Controlled
Pechan Report No. 05.09.011/9012-452
A-ll
-------
PECHAN
September 30, 2005
Table A-8. Top PM2.5 Point Emission Sources for Cleveland-Akron -Lorain, OH Nonattainment Area
Facility Name
see
see L2
SCC L3
see L4
PM25-PRI
Emissions
(tpv)
Control
Classification
Akron Thermal Energy
Corporation
10200204
Industrial
Bituminous/Subbituminous
Coal
Spreader Stoker
549
Controlled
Akron Thermal Energy
Corporation
10200903
Industrial
Wood/Bark Waste
Wood-fired Boiler - Wet
Wood (>=20% moisture)
390
Controlled
Avon Lake Power Plant
10100202
Electric Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Bituminous Coal)
208
Controlled
Akron Thermal Energy
Corporation
10200903
Industrial
Wood/Bark Waste
Wood-fired Boiler - Wet
Wood (>=20% moisture)
150
Controlled
Republic Engineered Products,
Inc
30300999
Primary Metal
Production
Steel Manufacturing (See
3-03-015 for Integrated
Iron & Steel MACT)
Other Not Classified
48
Controlled
Owens Corning, Medina Plant
30599999
Mineral Products
Other Not Defined
Specify in Comments Field
39
Controlled
Ford Motor Company, Cleveland
Casting Plant
30400340
Secondary Metal
Production
Grey Iron Foundries
Grinding/Cleaning
32
Controlled
Ford Motor Company, Cleveland
Casting Plant
30400301
Secondary Metal
Production
Grey Iron Foundries
Cupola
29
Controlled
Ford Motor Company, Cleveland
Casting Plant
30400301
Secondary Metal
Production
Grey Iron Foundries
Cupola
29
Controlled
Republic Engineered Products,
Inc
30300822
Primary Metal
Production
Iron Production (See 3-03-
015 for Integrated Iron &
Steel MACT)
Raw Material Stockpile: Ore,
Pellets, Limestone, Coke,
Sinter
26
Uncontrolled
Elkem Metals Company
30500401
Mineral Products
Calcium Carbide
Electric Furnace: Hoods and
Main Stack
26
Controlled
Oberlin College
10300207
Commercial/Institutional
Bituminous/Subbituminous
Coal
Overfeed Stoker (Bituminous
Coal)
25
Controlled
ISG Cleveland Inc.
39000797
In-process Fuel Use
Process Gas
General
25
Controlled
Ford Motor Company, Cleveland
Casting Plant
30400301
Secondary Metal
Production
Grey Iron Foundries
Cupola
24
Controlled
Elkem Metals Company
30500401
Mineral Products
Calcium Carbide
Electric Furnace: Hoods and
Main Stack
23
Controlled
ISG Cleveland Inc.
10200704
Industrial
Process Gas
Blast Furnace Gas
23
Uncontrolled
Elkem Metals Company
30501603
Mineral Products
Lime Manufacture
Calcining: Vertical Kiln
23
Controlled
ISG Cleveland Inc.
10200704
Industrial
Process Gas
Blast Furnace Gas
21
Controlled
Avon Lake Power Plant
10100202
Electric Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Bituminous Coal)
21
Controlled
Pechan Report No. 05.09.011/9012-452
A-12
-------
PECHAN
September 30, 2005
Table A-9. Top PM2.5 Point Emission Sources for Columbus, OH Nonattainment Area
Facility Name
see
see L2
SCC L3
SCC L4
PM25-PRI
Emissions
(tpv)
Control
Classification
Techneglas, Inc.
30501404
Mineral Products
Glass Manufacture
Pressed and Blown Glass:
Melting Furnace
1,600
Controlled
Conesville Power Plant
10100212
Electric Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Tangential) (Bituminous
Coal)
193
Controlled
Owens Corning
30501204
Mineral Products
Fiberglass Manufacturing
Forming: Rotary Spun
(Wool-type Fiber)
65
Controlled
Owens Corning
30501204
Mineral Products
Fiberglass Manufacturing
Forming: Rotary Spun
(Wool-type Fiber)
62
Controlled
Owens Corning
30501204
Mineral Products
Fiberglass Manufacturing
Forming: Rotary Spun
(Wool-type Fiber)
56
Controlled
Conesville Power Plant
10100212
Electric Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Tangential) (Bituminous
Coal)
48
Controlled
Conesville Power Plant
10100212
Electric Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Tangential) (Bituminous
Coal)
44
Controlled
Stone Container Corp.-
Coshocton
10200905
Industrial
Wood/Bark Waste
Wood/Bark-fired Boiler (<
50,000 Lb Steam) **
35
Controlled
Owens Corning
30501205
Mineral Products
Fiberglass Manufacturing
Curing Oven: Rotary Spun
(Wool-type Fiber)
35
Uncontrolled
Owens Corning
30501204
Mineral Products
Fiberglass Manufacturing
Forming: Rotary Spun
(Wool-type Fiber)
30
Controlled
Owens Corning
30501204
Mineral Products
Fiberglass Manufacturing
Forming: Rotary Spun
(Wool-type Fiber)
27
Controlled
Owens Corning
30501204
Mineral Products
Fiberglass Manufacturing
Forming: Rotary Spun
(Wool-type Fiber)
21
Controlled
Owens Corning
30590003
Mineral Products
Fuel Fired Equipment
Natural Gas: Process Heaters
21
Uncontrolled
Owens Corning
30590003
Mineral Products
Fuel Fired Equipment
Natural Gas: Process Heaters
18
Uncontrolled
Pechan Report No. 05.09.011/9012-452
A-13
-------
PECHAN
September 30, 2005
Table A-10. Top PM2.s Point Emission Sources for Detroit-Ann Arbor, Ml Nonattainment Area
Facility Name
see
see L2
SCC L3
SCC L4
PM25-PRI
Emissions
(tpv)
Control
Classification
Belle ki\ or
loloo"'
Llccinc Generation
Bi luniino u;>. S ub bi luniino us>
Coal
Pul\ cn/cd Coal. Din Bolloni
(Subbituminous Coal)
442
Controlled
Belle River
10100222
Electric Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Subbituminous Coal)
263
Controlled
J.R. Whiting Co
10100202
Electric Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Bituminous Coal)
212
Controlled
J.R. Whiting Co
10100202
Electric Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Bituminous Coal)
174
Controlled
J.R. Whiting Co
10100202
Electric Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Bituminous Coal)
162
Controlled
Guardian Industries
30501403
Mineral Products
Glass Manufacture
Flat Glass: Melting Furnace
64
Controlled
Guardian Industries
30501403
Mineral Products
Glass Manufacture
Flat Glass: Melting Furnace
60
Controlled
Cargill Salt
10100204
Electric Generation
Bituminous/Subbituminous
Coal
Spreader Stoker (Bituminous
Coal)
49
Controlled
Detroit Edison Greenwood
Energy Center
10100401
Electric Generation
Residual Oil
Grade 6 Oil: Normal Firing
28
Controlled
Hayes Lemmerz International
Inc
30400103
Secondary Metal
Production
Aluminum
Smelting
Furnace/Reverberatory
26
Controlled
Pechan Report No. 05.09.011/9012-452
A-14
-------
PECHAN
September 30, 2005
Table A-11. Top
PM2.5 Point Emission Sources for Huntington-Ash
and, WV-KY-OH Nonatl
ainment Area
Big Sandy
10100202
Elecli'ic Generation
B i Uuiiiiio us/ S ub bi luiiiiiio us
Coal
Pulverized Coal. Dry BoUom
(Bituminous Coal)
1,405
Controlled
Big Sandy
10100202
Electric Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Bituminous Coal)
534
Controlled
Appalachian Power -
Mountaineer Plant
10100202
Electric Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Bituminous Coal)
531
Controlled
Dp&L, J.M. Stuart Generating
Station
10100202
Electric Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Bituminous Coal)
356
Controlled
Dp&L, J.M. Stuart Generating
Station
10100202
Electric Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Bituminous Coal)
296
Controlled
Appalachian Power Co.-Philip
Sporn Plant
10100202
Electric Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Bituminous Coal)
129
Controlled
Dp&L, J.M. Stuart Generating
Station
10100202
Electric Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Bituminous Coal)
123
Controlled
Ohio Valley Electric Corp.,
Kyger Creek Station
10100201
Electric Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Wet Bottom
(Bituminous Coal)
113
Controlled
Ohio Valley Electric Corp.,
Kyger Creek Station
10100201
Electric Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Wet Bottom
(Bituminous Coal)
113
Controlled
Ohio Valley Electric Corp.,
Kyger Creek Station
10100201
Electric Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Wet Bottom
(Bituminous Coal)
110
Controlled
Dp&L, J.M. Stuart Generating
Station
10100202
Electric Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Bituminous Coal)
108
Controlled
Gavin Power Plant
10100202
Electric Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Bituminous Coal)
102
Controlled
Pechan Report No. 05.09.011/9012-452
A-15
-------
PECHAN
September 30, 2005
Table A-
2. Top PM2.5 Point Emission Sources for Indianapolis, IN Nonattainment Area
Facility Name
see
see L2
SCC L3
SCC L4
PM25-PRI
Emissions
(tpv)
Control
Classification
Hydraulic Press Brick Co.
30500908
Mineral Products
Clay and Fly Ash Sintering
Sintered Clay/Shale Product
Crushing/Screening
38
Controlled
Citizens Gas & Coke
30300303
Primary Metal
Production
By-product Coke
Manufacturing
Oven Pushing
28
Regulated
Citizens Gas & Coke
30300306
Primary Metal
Production
By-product Coke
Manufacturing
Oven Underfiring
22
Regulated
Ipl Harding Street Station
10100212
Electric Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Tangential) (Bituminous
Coal)
18
Controlled
National Starch & Chemical
Corporation
30290003
Food and Agriculture
Fuel Fired Equipment
Natural Gas: Process Heaters
15
Controlled
Hanson Aggregates Midwest,
Inc-Stone
30504020
Mineral Products
Mining and Quarrying of
Nonmetallic Minerals
Loading
15
Uncontrolled
International Truck And Engine
Corp.
30400325
Secondary Metal
Production
Grey Iron Foundries
Castings Cooling
14
Uncontrolled
Milestone Contractors, L.P.
10101302
Electric Generation
Liquid Waste
Waste Oil
13
Uncontrolled
Hydraulic Press Brick Co.
30500915
Mineral Products
Clay and Fly Ash Sintering
Rotary Kiln
13
Uncontrolled
Rieth-Riley Asphalt Plant #326
10301302
Commercial/Institutional
Liquid Waste
Waste Oil
12
Uncontrolled
National Starch & Chemical
Corporation
30290003
Food and Agriculture
Fuel Fired Equipment
Natural Gas: Process Heaters
12
Controlled
Ipalco-Pritchard Station
10100212
Electric Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Tangential) (Bituminous
Coal)
11
Controlled
Rieth-Riley Asphalt Plant #325
10301302
Commercial/Institutional
Liquid Waste
Waste Oil
10
Uncontrolled
Hydraulic Press Brick Co.
30500909
Mineral Products
Clay and Fly Ash Sintering
Expanded Shale Clinker
Cooling
10
Uncontrolled
Pechan Report No. 05.09.011/9012-452
A-16
-------
PECHAN
September 30, 2005
Table A-13. Top PM2.5 Point Emission Sources for Knoxville, TN Nonattainment Area
TVA Bull Run Fossil Plant
10100212
Electric Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Tangential) (Bituminous
Coal)
1,872
Controlled
TVA Kingston Fossil Plant
10100202
Electric Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Bituminous Coal)
441
Controlled
TVA Kingston Fossil Plant
10100202
Electric Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Bituminous Coal)
428
Controlled
TVA Kingston Fossil Plant
10100202
Electric Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Bituminous Coal)
417
Controlled
TVA Kingston Fossil Plant
10100202
Electric Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Bituminous Coal)
400
Controlled
TVA Kingston Fossil Plant
10100202
Electric Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Bituminous Coal)
360
Controlled
TVA Kingston Fossil Plant
10100202
Electric Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Bituminous Coal)
305
Controlled
TVA Kingston Fossil Plant
10100202
Electric Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Bituminous Coal)
291
Controlled
TVA Kingston Fossil Plant
10100202
Electric Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Bituminous Coal)
290
Controlled
TVA Kingston Fossil Plant
10100202
Electric Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Bituminous Coal)
286
Controlled
Aluminum Company Of
America - South Plant
30300104
Primary Metal
Production
Aluminum Ore (Electro-
reduction)
Materials Handling
134
Controlled
Aluminum Company Of
America - South Plant
30300104
Primary Metal
Production
Aluminum Ore (Electro-
reduction)
Materials Handling
134
Controlled
Aluminum Company Of
America - South Plant
30300104
Primary Metal
Production
Aluminum Ore (Electro-
reduction)
Materials Handling
129
Regulated
A.E. Staley Manufacturing
Company
10200204
Industrial
Bituminous/Subbituminous
Coal
Spreader Stoker
110
Controlled
Pechan Report No. 05.09.011/9012-452
A-17
-------
PECHAN
September 30, 2005
Table A-14. Top P
M2.5 Point Emission Sources for Louisvil
e, KY-IN Nonattainmen
Area
Lou Gab & LIcc. Cane Run
iuiuu:u:
LLvinc Geiieiuiion
Ui lumino Ub. S ub bi lumino Ub
Coal
Pul\ en/ed Coal. Dr\ Bolloni
(Bituminous Coal)
"99
Controlled
Kosmos Cement Co
30500699
Mineral Products
Cement Manufacturing
(Dry Process)
Other Not Classified
784
Controlled
Kosmos Cement Co
30500699
Mineral Products
Cement Manufacturing
(Dry Process)
Other Not Classified
762
Uncontrolled
Lou Gas & Elec, Mill Creek
10100212
Electric Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Tangential,Bituminous Coal)
548
Controlled
Lou Gas & Elec, Mill Creek
10100212
Electric Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Tangential,Bituminous Coal)
365
Controlled
Kosmos Cement Co
30500606
Mineral Products
Cement Manufacturing
(Dry Process)
Kilns
340
Controlled
Kosmos Cement Co
30500699
Mineral Products
Cement Manufacturing
(Dry Process)
Other Not Classified
334
Uncontrolled
Lou Gas & Elec, Cane Run
10100212
Electric Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Tangential,Bituminous Coal)
308
Controlled
Kosmos Cement Co
30500699
Mineral Products
Cement Manufacturing
(Dry Process)
Other Not Classified
252
Uncontrolled
Lou Gas & Elec, Mill Creek
10100212
Electric Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Tangential,Bituminous Coal)
227
Controlled
Lou Gas & Elec, Mill Creek
10100212
Electric Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Tangential,Bituminous Coal)
227
Controlled
Kosmos Cement Co
30500699
Mineral Products
Cement Manufacturing
(Dry Process)
Other Not Classified
191
Uncontrolled
Kosmos Cement Co
30500614
Mineral Products
Cement Manufacturing
(Dry Process)
Clinker Cooler
160
Controlled
Kosmos Cement Co
30500699
Mineral Products
Cement Manufacturing
(Dry Process)
Other Not Classified
133
Uncontrolled
Lou Gas & Elec, Cane Run
10100202
Electric Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Bituminous Coal)
124
Uncontrolled
Kosmos Cement Co
30500699
Mineral Products
Cement Manufacturing
(Dry Process)
Other Not Classified
114
Uncontrolled
Pechan Report No. 05.09.011/9012-452
A-18
-------
PECHAN
September 30, 2005
Table A-1
5. Top PM2.5 Point Emission Sources for St. Louis, MO-IL Nonattainmenl
Area
Facility Name
see
see L2
SCC L3
SCC L4
PM25-PRI
Emissions
(tpv)
Control
Classification
American Commercial
Terminals
30501011
Mineral Products
Coal Mining, Cleaning,
and Material Handling
(See 305310)
Coal Transfer
1,052
Uncontrolled
Amerenue-Meramec Plant
10100226
Electric Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
Tangential (Subbituminous
Coal)
754
Controlled
Pace Construction Co-
Chesterfield
30500260
Mineral Products
Asphalt Concrete
Drum Mix Plant: Rotary
Drum Dryer / Mixer, #2 Oil-
Fired, Counterflow
494
Uncontrolled
Dial Corp-Dial Corp
30113210
Chemical Manufacturing
Organic Acid
Manufacturing
Acetic Acid via Acetaldehyde
426
Uncontrolled
Dynegy Midwest Generation Inc
10100202
Electric Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Bituminous Coal)
350
Controlled
Dynegy Midwest Generation Inc
10100203
Electric Generation
Bituminous/Subbituminous
Coal
Cyclone Furnace
(Bituminous Coal)
348
Controlled
Dynegy Midwest Generation Inc
10100203
Electric Generation
Bituminous/Subbituminous
Coal
Cyclone Furnace
(Bituminous Coal)
341
Controlled
Elementis Specialties Inc
30103553
Chemical Manufacturing
Inorganic Pigments
Pigment Dryer
184
Uncontrolled
Elementis Specialties Inc
30103553
Chemical Manufacturing
Inorganic Pigments
Pigment Dryer
184
Uncontrolled
Masterchem Industires Inc-
Imperial
30101401
Chemical Manufacturing
Paint Manufacture
General Mixing and Handling
117
Uncontrolled
U. S. Silica Company-Pacific
30502511
Mineral Products
Construction Sand and
Gravel
Screening
113
Uncontrolled
Anheuser-Busch Inc-St. Louis
10200202
Industrial
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
102
Controlled
Pechan Report No. 05.09.011/9012-452
A-19
-------
PECHAN
September 30, 2005
Table A-16. Top PM2.5 Point Emission Sources for Steuvenville-M
Facility Name
see
see L2
SCC L3
SCC L4
PM25-PRI
Emissions
(tpv)
Control
Classification
Weirton Steel Corporation
30300913
Primary Metal Prod'n
Steel Manufacturing*
Basic Oxygen Furnace: Open
Hood-Stack
2,133
Controlled
Weirton Steel Corporation
30300824
Primary Metal Prod'n
Iron Production*
Blast Heating Stoves
1,873
Regulated
Weirton Steel Corporation
30300913
Primary Metal Prod'n
Steel Manufacturing*
Basic Oxygen Furnace: Open
Hood-Stack
1,485
Controlled
Weirton Steel Corporation
30300824
Primary Metal Prod'n
Iron Production*
Blast Heating Stoves
1,479
Regulated
Weirton Steel Corporation
30300917
Primary Metal Prod'n
Steel Manufacturing *
Tapping: BOF
1,383
Regulated
Weirton Steel Corporation
30300825
Primary Metal Prod'n
Iron Production*
Cast House
320
Regulated
Weirton Steel Corporation
30390024
Primary Metal Prod'n
Fuel Fired Equipment
Process Gas: Flares
245
Regulated
Weirton Steel Corporation
30300841
Primary Metal Prod'n
Iron Production*
Flue Dust Unloading
215
Regulated
Weirton Steel Corporation
30390024
Primary Metal Prod'n
Fuel Fired Equipment
Process Gas: Flares
138
Regulated
Cardinal Power Plant (Cardinal
Operating Company)
10100202
Electric Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Bituminous Coal)
112
Controlled
Weirton Steel Corporation
30300917
Primary Metal Prod'n
Steel Manufacturing*
Tapping: BOF
96
Regulated
Cardinal Power Plant (Cardinal
Operating Company)
10100202
Electric Generation
Bituminous/Subbituminous
Coal
Pulverized Coal: Dry Bottom
(Bituminous Coal)
91
Controlled
Wheeling-Pittsburgh Steel
Corporation - Steubenvil
30300999
Primary Metal
Production
Steel Manufacturing*
Other Not Classified
85
Controlled
Wheeling-Pittsburgh Steel
Corporation
30300306
Primary Metal
Production
By-product Coke
Manufacturing
Oven Underfiring
82
Regulated
W. H. Sammis Plant
30501040
Mineral Products
Coal Mining, Cleaning,
and Material Handling
Truck Unloading: End Dump
-Coal
80
Uncontrolled
Wheeling-Pittsburgh Steel
Corporation
30300308
Primary Metal
Production
By-product Coke
Manufacturing
Oven/Door Leaks
63
Regulated
Wheeling-Pittsburgh Steel
Corporation
30300303
Primary Metal
Production
By-product Coke
Manufacturing
Oven Pushing
53
Controlled
Wheeling-Pittsburgh Steel
Corporation
30102318
Chemical Manufacturing
Sulfuric Acid (Contact
Process)
Absorber/@ 93.0%
Conversion
52
Uncontrolled
Weirton Steel Corporation
30300915
Primary Metal
Production
Steel Manufacturing*
Hot Metal (Iron) Transfer to
Steelmaking Furnace
51
Controlled
eirton, OH-WV Nonattainment Area
•'See 3-03-015 for Integrated Iron & Steel MACT
Pechan Report No. 05.09.011/9012-452
A-20
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