 


DATE:	April 2, 2017

SUBJECT:	Technology Review for the Friction Materials Manufacturing Facilities Source Category  -  Proposed Rule

FROM:	Korbin Smith, Environmental Protection Agency
	David Bullock, RTI International
	

TO:	Docket EPA-HQ-OAR-2017-0358

I.	BACKGROUND 
Requirements of Section 112(d)(6) of the CAA
Section 112 of the Clean Air Act (CAA) requires the EPA to establish technology-based standards for sources of HAP. These technology-based standards are often referred to as maximum achievable control technology, or MACT, standards. Section 112 also contains provisions requiring the EPA to periodically review these standards. Specifically, paragraph 112(d)(6) states:
      (6) REVIEW AND REVISION.  -  The Administrator shall review, and revise as necessary (taking into account developments in practices, processes, and control technologies), emissions standards promulgated under this section no less often than every 8 years.
      
Description of the Friction Materials Manufacturing Facilities Source Category and Requirements of the Current NESHAP
The current National Emissions Standards for Hazardous Air Pollutants (NESHAP) for the Friction Materials Manufacturing Facilities source category were promulgated on October 18, 2002 (67 FR 64506) as 40 CFR part 63, subpart QQQQQ.[1] The NESHAP applies to affected sources of HAP at friction materials manufacturing facilities that are major sources of HAP. A friction materials manufacturing facility is defined as a facility that manufactures friction materials using a solvent-based process. The affected source covered by this subpart is each new, reconstructed, or existing solvent mixer at a friction materials manufacturing facility. 
A solvent mixer is defined as a mixer used in the friction materials manufacturing process in which HAP solvent is used as one of the ingredients in at least one batch during a semiannual reporting period. Emission limits were promulgated for HAP solvents. A HAP solvent is defined as a solvent that contains 10 percent or more of any one HAP, as listed in section 112(b) of the CAA, or any combination of HAP that is added to a solvent mixer. HAP solvents are emitted from the solvent mixer and from downstream processes (e.g., hot presses, post bake ovens, saturators, and dryers).
We identified two friction materials manufacturing facilities that are subject to the NESHAP. Control devices currently in use at these two facilities to reduce HAP emissions from affected sources include a solvent recovery (condenser) system and a permanent total enclosure with an incinerator. 
II.	DEVELOPMENTS IN PRACTICES, PROCESSES, AND CONTROL TECHNOLOGIES
For the purposes of this technology review, a "development" was considered to be a(n): 
 Any add-on control technology or other equipment that was not identified and considered during development of the original MACT standards;
 Any improvements in practices, processes, or add-on control technology (that were identified and considered during development of the original MACT standards) that could result in significant additional emissions reduction;
 Any work practice or operational procedure that was not identified or considered during development of the original MACT standards;
 Any process change or pollution prevention alternative that could be broadly applied to the industry and that was not identified or considered during development of the original MACT standards;
 Any significant changes in the cost (including cost-effectiveness) of applying controls (including controls the EPA considered during the development of the original MACT standards).

We investigated developments in practices, processes, and control technologies through discussions with industry representatives, and included questions related to the technology review in the site visit request letters that were sent to both companies thought to be subject to the NESHAP. We also conducted a review of EPA's Technology Transfer Network (TTN) Clean Air Technology Center  -  RACT/BACT/LAER Clearinghouse (RBLC) database. The results of these analyses are presented in the following sections.
 Permanent Total Enclosure and Incinerator (PTEI)
One facility controls HAP emissions from the solvent mixer by capturing HAP emissions with a permanent total enclosure and routing the emissions to a boiler/incinerator for destruction. The specific capture and control system installed at this friction materials manufacturing facility was constructed in 2002, and therefore did not exist at proposal, and was not identified prior to promulgation of the current NESHAP in October 2002.
Emission control systems including a permanent total enclosure and incinerator are already accommodated under the provisions for alternative compliance requirements at §63.9570. Emissions testing showed the destruction efficiency for HAP was >99%. Therefore, the overall control efficiency (i.e., the product of capture efficiency and HAP destruction efficiency) is >99%, which exceeds the overall control efficiency of 70% reduction criteria of 40 CFR §63.9500(a). 
Using the most recent EPA Air Pollution Control Cost Manual.[2] A cost estimation was calculated for installing a PTEI in the remaining major source facility not using this technology. To remain consistent throughout the cost estimate, mean values were used when ranges were available. For additional information on the calculated costs see the memo "Permanent Total Enclosure and Incinerator Cost Memo" in docket: EPA-HQ-OAR-2017-0358. The total capital investment (TCI) would be $1,660,627, and the total annual cost would be $848,155. 
The installation of a PTEI at the remaining major source facility was calculated to reduce the amount of HAP emitted by 228 tons (using a destruction efficiency of 98%). This results in cost per ton of HAP emissions reduction of $3,720 based on this analysis. 
 This is a development in practices, processes, or control technologies for the friction materials manufacturing source category under section 112(d)(6), and may be included among technologies achieving emission reductions in the NESHAP.
 Non-Solvent Process and Product Reformulation
One facility is currently in the process of converting their friction material production from a HAP solvent, to a non-HAP solvent process. This process change reformulates the product recipes to allow the use of a non-solvent mixer. Using a non-solvent mixer eliminates the use of HAP solvents and their associated emissions.
The above facility provided information on the total capital investment for purchasing and installing the non-solvent mixer. The mixer and downstream material processing equipment's estimated total capital investment was $2,073,430. Annual cost of operation is approximately $125,000 for electrical cost, and $75,000 for maintenance. Due to the remaining facility already achieving >99% destruction efficiency, a detailed cost analysis was not deemed necessary, as the cost per ton of HAP reduction would be excessive.  
Opportunities for process changes to reduce HAP emissions from friction materials manufacturing can vary widely and are influenced by the specific product being manufactured and the required product performance specifications. Therefore, a specific process change that may be used successfully to reduce HAP emissions at one facility may not work for another facility.
Although the use of a non-solvent mixer is not specifically identified in the current NESHAP, process changes such as converting to a process that does not require the use of HAP solvents are accommodated via the solvent substitution provisions of the rule. In fact, the solvent substitution provisions were included to encourage these types of process changes. 
This process change was not specifically identified in the current NESHAP, thus is considered to be a new development in practices, processes, or control technologies for the Friction Materials Manufacturing source category under section 112(d)(6), and could be used to update the technology in the NESHAP.
RACT/BACT/LAER Clearinghouse Search
Under EPA's "New Source Review" (NSR) program, if a company is planning to build a new plant or modify an existing plant such that air pollution emissions will increase by a large amount, then the company must obtain an NSR permit. The NSR permit is a construction permit which requires the company to minimize air pollution emissions by changing the process to prevent air pollution and/or installing air pollution control equipment.[3]
The terms "RACT," "BACT," and "LAER" are acronyms for different program requirements under the NSR program. RACT, or Reasonably Available Control Technology, is required on existing sources in areas that are not meeting national ambient air quality standards (i.e., non-attainment areas). BACT, or Best Available Control Technology, is required on major new or modified sources in clean areas (i.e., attainment areas). LAER, or Lowest Achievable Emission Rate, is required on major new or modified sources in non-attainment areas. BACT and LAER (and sometimes RACT) are determined on a case-by-case basis, usually by State or local permitting agencies.[3]
The EPA established the RACT/BACT/LAER Clearinghouse, or RBLC, to provide a central data base of air pollution technology information (including past RACT, BACT, and LAER decisions contained in NSR permits) to promote the sharing of information among permitting agencies and to aid in future case-by-case determinations. However, data in the RBLC are not limited to sources subject to RACT, BACT, and LAER requirements. Noteworthy prevention and control technology decisions and information are included even if they are not related to past RACT, BACT, or LAER decisions.[3]
The RBLC permit data base contains over 5,000 determinations that can help you identify appropriate technologies to mitigate most air pollutant emission streams. The RBLC permit data base was designed to help permit applicants and reviewers make pollution prevention and control technology decisions for stationary air pollution sources, and includes data submitted by several U.S. territories and all 50 States on over 200 different air pollutants and 1,000 industrial processes.[3]
The RBLC provides several options for searching the permit database on-line to locate applicable control technologies. Searches of the RBLC database were conducted in January 2017. The permit dates for the searches used the NESHAP part 63 subpart QQQQQ proposal date (October 4, 2001) through December 31, 2016. 
There is no specific "process type" code in the RBLC for friction materials manufacturing, therefore we searched for process names containing relevant key words. The search for process names including the term "friction" yielded no results. The search for process names including the term "mix" (intended to identify determinations for solvent mixers) yielded 32 facilities and 40 processes with determinations during the period 2001  -  2016. Most of the identified facilities fall into three general industry types: iron and steel, tire and rubber, and petroleum. None of the identified processes were solvent mixers (or similar), therefore none of these determinations are relevant to QQQQQ.
The search for process names including the term "solvent" (intended to identify determinations for solvent recovery systems) yielded 26 facilities and 27 processes with determinations during the period 2001  -  2016. Most of the identified facilities fall into three general industry types: automotive, chemical, and food and agriculture (e.g., oil seed processing). The search results included no friction materials manufacturing facilities, no solvent mixers, and no determinations for HAP solvents from similar processes. Although the search identified no directly comparable manufacturing processes and no relevant determinations for HAP solvents, the VOC control determinations for the identified processes included condensers, absorbers, combustion (e.g., thermal oxidizer, boiler, flare), and pollution prevention techniques (e.g., work practices, operating practices, or design practices). These emission reduction alternatives were identified at proposal of the NESHAP or (in the case of combustion controls) during information collection efforts for the technology review for QQQQQ.
There is no new information from the RBLC search for the technology review.

References

       National Emission Standards for Hazardous Air Pollutants for Friction Materials Manufacturing Facilities. See Federal Register Notice 67FR64506, dated October 18, 2002. 
       United States Environmental Protection Agency. (2002, January). EPA Air Pollution Control Cost Manual Sixth Edition. Retrieved from https://www3.epa.gov/ttn/ecas/docs/c_allchs.pdf
       U.S. EPA. RACT/BACT/LAER Clearinghouse. Available at: https://www3.epa.gov/ttn/catc/rblc/htm/welcome_eg.html
      
