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MEMORANDUM

TO:	Tonisha Dawson, U.S. EPA/OAQPS/SPPD  -  EPA Office of Air Quality Planning and Standards

FROM:	Eastern Research Group, Inc. 

DATE:	September 2018

SUBJECT:	Clean Air Act Section 112(d)(6) Review for the Asphalt Processing and Asphalt Roofing Manufacturing Source Categories
--------------------------------------------------------------------------------

INTRODUCTION
This memorandum summarizes the results of an analysis to identify developments in practices, processes, and control technologies that have occurred since the major source National Emission Standards for Hazardous Air Pollutants (NESHAP) for the asphalt processing and asphalt roofing manufacturing source categories was promulgated at 40 CFR 63, Subpart LLLLL. This analysis is part of the U.S. Environmental Protection Agency's (EPA) review efforts in accordance with section 112(d)(6) of the Clean Air Act (CAA).
BACKGROUND FOR MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY (MACT) STANDARDS AT 40 CFR 63, SUBPART LLLLL
On April 29, 2003 (68 FR 22975), the EPA promulgated a final NESHAP for the asphalt processing and asphalt roofing manufacturing major source categories at 40 CFR 63, Subpart LLLLL. As promulgated in 2003 and further amended on May 17, 2005 (70 FR 28360), the NESHAP prescribes MACT standards for asphalt processing and asphalt roofing manufacturing facilities that are major sources of HAP.
The asphalt processing major source category includes any facility engaged in the preparation of asphalt flux at stand-alone asphalt processing facilities, petroleum refineries, and asphalt roofing facilities. Asphalt preparation, called ``blowing,'' is the oxidation of asphalt flux, achieved by bubbling air through the heated asphalt, to raise the softening point and to reduce penetration of the oxidized asphalt. An asphalt processing facility includes one or more asphalt flux blowing stills, asphalt flux storage tanks storing asphalt flux intended for processing in the blowing stills, oxidized asphalt storage tanks, and oxidized asphalt loading racks. (EPA 1992)
The asphalt roofing manufacturing major source category includes any facility consisting of one or more asphalt roofing manufacturing lines. An asphalt roofing manufacturing line includes the collection of equipment used to manufacture asphalt roofing products through a series of sequential process steps. The equipment that comprises an asphalt roofing manufacturing line varies depending on the type of substrate used (i.e., organic or inorganic) and the final product manufactured (e.g., roll roofing, laminated shingles). An asphalt roofing manufacturing line can include a saturator (including wet looper), coater, coating mixers, sealant applicators, adhesive applicators, and asphalt storage and process tanks. (EPA 1992)
The Subpart LLLLL MACT standards establish emission limits for PM and total hydrocarbons (THC) as surrogates for total organic HAP. Sources of HAP emissions regulated by 40 CFR 63, Subpart LLLLL include: each blowing still, asphalt storage tank, and asphalt loading rack at asphalt processing facilities; and each coating mixer, coater, saturator, wet looper, asphalt storage tank, and sealant and adhesive applicator at asphalt roofing manufacturing facilities. The Subpart LLLLL MACT standards also limits the opacity and visible emissions from certain saturators, coaters, and asphalt storage tanks. Although an inorganic HAP, hydrogen chloride (HCl), is also emitted from some asphalt processing facilities (those that use chlorinated catalysts in the blowing still), there are no Subpart LLLLL MACT standards for HCl emissions from blowing stills.
LIST OF FACILITIES
Appendix A provides a list of facilities located in the United States that are currently considered by the EPA to be part of the asphalt processing source category and/or asphalt roofing manufacturing source category. As of October 1, 2017, eight facilities are subject to 40 CFR 63, Subpart LLLLL. Four of the eight major sources of HAP are strictly asphalt processing facilities, and the other four operate an asphalt processing facility collocated with an asphalt roofing manufacturing facility.
CAA AUTHORITY
Section 112 of the CAA requires the EPA to establish technology-based NESHAP for listed source categories of HAP. These technology-based standards are often referred to as MACT standards (for major sources of HAP). 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.
To comply with these CAA requirements, the EPA conducted a review of the Subpart LLLLL MACT standards. For the purposes of reviewing these standards, the EPA considers a "development" in practices, processes, and control technologies to be:
Any add-on control technology or other equipment that was not identified and considered during development of the original standard.
Any improvements in add-on control technology or other equipment (that were identified and considered during development of the original standard) that could result in additional emissions reduction.
Any work practice or operational procedure that was not identified or considered during development of the original standard.
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 standard.
Any significant changes in the cost (including cost effectiveness) of applying controls (including controls the EPA considered but did not adopt during the development of the original standard).
DESCRIPTION OF EMISSION RELEASES
Blowing Stills
The Subpart LLLLL MACT standards define a blowing still to be the equipment in which air is blown through asphalt flux to change the softening point and penetration rate of the asphalt flux, creating oxidized asphalt. 
HAPs are volatilized during asphalt processing because of the oxidation reactions that occur in the blowing still. In asphalt processing, heated asphalt flux is taken from storage and charged to a heated blowing still where air is bubbled up through the flux. This process raises the softening temperature of the asphalt. The blowing process also decreases the penetration rate of the asphalt when applied to the roofing substrate. Some processing operations use a catalyst (e.g., ferric chloride, phosphoric acid) in the blowing still which promotes the oxidation of asphalt in the blowing still. The need to use catalyst is primarily driven by the type of feedstock used. Certain feedstocks require catalyst (e.g., ferric chloride, phosphoric acid) to be used to attain desired product specifications. As previously discussed in the original Subpart LLLLL MACT standards rulemaking (68 FR 22975), if a chlorinated catalyst is used in the blowing still to process asphalt, then chlorine compounds can be present in the blowing still exhaust which can oxidize and form HCl. During asphalt processing, HCl emissions can result from: (1) The conversion of ferric chloride catalyst to ferrous chloride in the blowing still, (2) HCl present in the ferric catalyst itself, (3) trace amount of HCl present in the asphalt flux, and (4) oxidation of chlorinated compounds by the blowing still thermal oxidizer.
Asphalt Loading Racks
The Subpart LLLLL MACT standards define an asphalt loading rack to be the equipment that is used to transfer oxidized asphalt from a storage tank into a tank truck, rail car, or barge.
Asphalt loading rack emissions depend on the physical and chemical characteristics of the oxidized asphalt being loaded. These characteristics include the volatility (or vapor pressure) and molecular weight of the oxidized asphalt being transferred, the temperature and pressure conditions of the transfer operation, and the volume of oxidized asphalt transferred. In addition, during the loading of oxidized asphalt into transport vehicles, volatile organic compounds (VOC) and HAP vapors present in the transport vehicle are displaced by the oxidized asphalt being loaded. The vapors in the transport vehicle include vapors generated as the oxidized asphalt is being loaded and/or vapors remaining from residual asphalt from the previous load (if present). Asphalt loading rack emissions typically occur at the loading hatch or opening of the transport vehicle. Emissions can also occur from leaks in the transport vehicle. The rate at which these VOC and HAP are emitted varies depending on which type of transport vehicle is being loaded (tank truck or railcar), whether the transport vehicle was empty before filling or refilled while still containing a heel and vapors, the physical and chemical characteristics of the oxidized asphalt being loaded, and the type of loading method used.
Asphalt Storage Tanks
The Subpart LLLLL MACT standards define an asphalt storage tank to be any tank used to store asphalt flux, oxidized asphalt, and modified asphalt, at asphalt roofing manufacturing facilities, petroleum refineries, and asphalt processing facilities. These tanks are often designed for operation at atmospheric or near-atmospheric pressure. Atmospheric storage tanks are typically cylindrical with a vertical orientation, and they are constructed with either a fixed roof or a floating roof. Some, generally small, atmospheric storage tanks are oriented horizontally. 
Emissions from fixed roof storage tanks (both vertical and horizontal vessels) occur from working losses, breathing losses, and leaks. Working losses are the combined emissions from filling and emptying the storage tank. Emissions during filling operations result from an increase in the liquid level in the storage tank. As the liquid level increases, the pressure inside the storage tank exceeds the relief pressure and vapors are expelled from the storage tank. Emissions also occur when liquid is withdrawn from the storage tank because some of the stored liquid evaporates to partially saturate the air that is drawn in. This increase in the amount of vapor causes the pressure in the tank to increase; as when filling the storage tank, when the pressure exceeds the relief pressure, the vent opens and vapors are released to the atmosphere. Factors that affect the mass of working losses include the saturation level of the pollutant in the vapor space, vapor pressure of the stored material, vapor molecular weight, total throughput, and capacity of the storage tank.
Breathing (or standing) losses are emissions caused by vapor expansion and contraction, which are the result of changes in temperature and atmospheric pressure. These emissions occur without any changes in the liquid level in the storage tank. Factors that affect the mass of breathing losses are the vapor pressure of the stored material, atmospheric conditions (e.g., daily total solar insolation, atmospheric pressure, and daily range of ambient temperatures), breather vent pressure and vacuum settings, vessel dimensions, and vapor molecular weight. If the stored liquid is maintained at a constant temperature, breathing emissions are minimized or eliminated.
Another potential source of emissions from storage tanks is leaks from various improperly closed openings such as defective pressure/vacuum vents and poorly fitting or deteriorated gaskets used to seal closure devices for openings such as access hatches. Procedures for estimating such emissions are not available. However, factors that affect the mass of these emissions are the size and number of openings, the vapor pressure of the stored material, and atmospheric conditions such as wind. Some of the breathing and working emissions may also occur through the leak openings rather than the intended vent.
Coating Mixers, Saturators (including wet loopers), Coaters, Sealant Applicators, and Adhesive (laminate) Applicators
Asphalt fumes containing HAP are released during the operation of coating mixers, saturators (including wet loopers), coaters, sealant applicators, and adhesive (laminate) applicators.
Coating asphalt is typically mixed with mineral stabilizers, such as silica or dolomite, to harden and increase the viscosity of asphalt. This mixing process occurs in the coating mixer. The Subpart LLLLL MACT standards define a coating mixer as the equipment used to mix coating asphalt and a mineral stabilizer, prior to applying the stabilized coating asphalt to the substrate.
For organic felt roofing products, asphalt is applied to the organic substrate by a saturator. The organic substrate is saturated with asphalt by being "dipped" into the saturator tank. After passing through the saturator, organic felt roofing products are normally wound through wet loopers, which allow time for increased absorption of the asphalt into the organic substrate. The Subpart LLLLL MACT standards define a saturator as the equipment in which substrate (predominantly organic felt) is filled with asphalt, and the saturator includes the wet looper. 
For fiberglass roofing products, coaters are used to apply stabilized coating asphalt or modified bitumen to both sides of the fiberglass substrate. The Subpart LLLLL MACT standards define a coater to be the equipment used to apply amended (filled or modified) asphalt to the top and bottom of the substrate (typically fiberglass mat) used to manufacture shingles and rolled roofing products. 
For fiberglass roofing products, a strip of sealant asphalt is applied by a roller partially submerged in a pan of hot sealant asphalt. Similarly, for laminated fiberglass roofing products, adhesive asphalt is applied to glue multiple single-ply shingles together. The Subpart LLLLL MACT standards define an adhesive applicator as the equipment used to apply adhesive to roofing shingles for producing laminated or dimensional roofing shingles, and a sealant applicator as the equipment used to apply a sealant strip to a roofing product.
SUMMARY OF EXISTING MACT LEVEL OF CONTROL
The Subpart LLLLL MACT floor for blowing stills, asphalt loading racks, and asphalt storage tanks at existing, new, and reconstructed asphalt processing facilities is based on a combustion device operating at or above 1,200 °F (e.g., thermal oxidizers (TOs), flares, process heaters, and boilers).
The Subpart LLLLL MACT floor for coaters, saturators, wet loopers, coating mixers, sealant and adhesive applicators, and asphalt storage tanks at new and reconstructed asphalt roofing manufacturing lines is based on a combustion device operating at or above 1,200 °F. Except for asphalt storage tanks, the Subpart LLLLL MACT floor for equipment at existing asphalt roofing manufacturing lines (coaters, saturators, wet loopers, coating mixers, and sealant and adhesive applicators) is based on a PM control device (e.g., high velocity air filters (HVAFs), electrostatic precipitators (ESPs), and fiberbed filters) meeting the PM emission limits in the New Source Performance Standards (NSPS) at 40 CFR 60, subpart UU. For asphalt storage tanks at existing asphalt roofing manufacturing lines, the Subpart LLLLL MACT floor is based on a combustion device operating at or above 1,200 °F.
Table 1 provides a summary of the basis of the Subpart LLLLL MACT floors at existing and new asphalt processing and roofing manufacturing facilities. 
Table 1. Summary of the Basis of the Subpart LLLLL MACT Floors at Existing and New Asphalt Processing and Roofing Manufacturing Facilities
                                Emission Source
                               Existing Source 
                                 Subpart LLLLL
                                  MACT Floor
                                  New Source 
                                 Subpart LLLLL
                                  MACT Floor
Blowing Stills (catalyst and non-catalyst)
               Combustion device operating at or above 1,200 °F
Asphalt Loading Racks[1]

Asphalt Storage Tanks[1]

Coating Mixers
            PM control device meeting Subpart UU NSPS requirements
Combustion device operating at or above 1,200 °F
Saturators


Wet Loopers


Coaters


Sealant and Adhesive Applicators


[1]	Control is only required for Group 1 asphalt loading racks and asphalt storage tanks. A Group 1 asphalt loading rack loads asphalt with a maximum temperature of 260 °C (500 °F) or greater and has a maximum true vapor pressure of 10.4 kiloPascals (kPa) (1.5 pounds per square inch absolute (psia)) or greater. A Group 1 asphalt storage tank has a capacity of 177 cubic meters (47,000 gallons) of asphalt or greater; and stores asphalt at a maximum temperature of 260 °C (500 °F) or greater and has a maximum true vapor pressure of 10.4 kPa (1.5 psia) or greater.
DEVELOPMENTS IN PRACTICES, PROCESSES, AND TECHNOLOGY
To identify developments in practices, processes, and control technologies since the Subpart LLLLL MACT standards were developed, the EPA consulted the following sources of data:
The EPA's RACT/BACT/LAER Clearinghouse (RBLC);
Review of subsequent regulatory development efforts; and
Facility responses to the EPA's CAA section 114 request. 

As discussed below, our review of these sources did not reveal any new developments in emissions reduction practices, processes, or control technologies for any of the emission sources at asphalt processing and asphalt roofing manufacturing facilities beyond those already required by the Subpart LLLLL MACT standards. However, in section 8.0 of this memorandum, we evaluate two HCl emission reduction options for blowing stills that use a chlorinated catalyst.
RBLC Database
The RBLC database contains information on the best emission control technologies that have been required by state, local, and territorial air pollution control agencies. The EPA established the RBLC to provide a central data base to promote the sharing of control technology information on case-by-case control technology determinations made as part of the air permitting process. The RBLC was designed to help permit applicants and permitting authorities understand past precedents in control technology decisions for different stationary source categories. The database contains more than 5,000 air pollution control technology determinations submitted by state, local, and territorial air pollution control agencies on over 200 different air pollutants and 1,000 industrial processes.
          RACT, or reasonable available control technology, applies to existing sources in areas that are not meeting a National Ambient Air Quality Standard (NAAQS). Each state, local, or territorial agency determines RACT on either a case-by-case basis for each source or on a geographic basis.
          BACT, or Best Available Control Technology, applies to each new or significantly modified major source that is constructed in a NAAQS attainment area. Each state, local, or territorial agency determines BACT on a case-by-case basis for each source.
          LAER, or lowest achievable emission rate, applies to each new or significantly modified major source that is constructed in a NAAQS nonattainment area. Each state, local, or territorial agency determines LAER on a case-by-case basis for each source.
RACT, BACT, and LAER apply to criteria pollutants only. 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 may be included in the database even if they are not related to past RACT, BACT, or LAER decisions.
The RBLC provides several options for searching the operating permit database on-line to locate applicable control technologies. Our search of the RBLC specified the "Asphalt Processing" and "Asphalt Roofing Products Manufacturing" subcategories under the Mineral Products category, with permits dating back to 2002. The search results included the following data fields:
RBLC ID;
Facility name and state;
Permit issuance date;
Process name;
Throughput;
Pollutant;
Control technology; and
Percent efficiency of control.

Appendix B presents the results of the RBLC search. The search identified three facilities, and none of these facilities have more stringent emission control requirements than the Subpart LLLLL MACT standards. 
The practices, processes, and control technologies shown in Appendix B for blowing stills, asphalt storage tanks, and asphalt loading racks at asphalt processing facilities; and coating mixers, coaters, saturators, wet loopers, asphalt storage tanks, and sealant and adhesive applicators at asphalt roofing manufacturing facilities are all examples of the same types of emission reduction techniques on which the requirements of Subpart LLLLL MACT standards are based. Therefore, this search did not reveal any new developments in emissions reduction practices, processes, or control technologies for any of the emission sources at asphalt processing and asphalt roofing manufacturing facilities.
Subsequent Regulatory Development Efforts 
The EPA conducted a review of subsequent air toxic regulatory actions (i.e. those actions that took place after promulgation of 40 CFR 63, Subpart LLLLL) to determine whether any practices, processes, or control technologies could be applied to the asphalt processing and asphalt roofing manufacturing source categories. We did not identify any subsequent air toxics regulations that apply to equipment like blowing stills, coaters, sealant applicators, and adhesive (laminate) applicators. However, we did identify some subsequent air toxics regulations that apply to loading racks and/or storage tanks that are similar to asphalt process equipment (see Table 2). 
The storage vessel and/or transfer loading rack control requirements in the NESHAP identified in Table 2 (when applicable) are based on use of either a fixed roof, internal floating roof, external floating roof, enhanced fitting controls, closed vent system and control device, submerged fill pipe, vapor recovery or balance system, or routing emissions to a process or a fuel gas system. Therefore, these regulations did not reveal any new developments in emissions reduction practices, processes, or control technologies for these emission sources beyond those already required by the Subpart LLLLL MACT standards.
             Table 2. Subsequent Regulatory Development Efforts[1]
                                Source Category
                                NESHAP Subpart
                        Date of Final Rule Promulgation
         Miscellaneous Organic Chemical Production and Processes (MON)
                                  NESHAP FFFF
                                   11/10/03
                        Hazardous Organic NESHAP (HON)
                                NESHAP F, G, H
                                   12/21/06
                         Acrylic and Modacrylic Fibers
                                 NESHAP LLLLLL
                                    7/16/07
                              Petroleum Refinery
                                  NSPS J / Ja
                                    6/24/08
                               Hydrogen Fluoride
                                   NESHAP YY
                                   12/16/08
                                 Acetal Resins
                                   NESHAP YY
                                   12/16/08
                            Chemical Manufacturing
                                 NESHAP VVVVVV
                                   10/29/09
                             Chemical Preparations
                                NESHAP BBBBBBB
                                   12/30/09
                                Pharmaceuticals
                                  NESHAP GGG
                                    4/21/11
                          Group I Polymers and Resins
                                   NESHAP U
                                    4/21/11
                         Phosphoric Acid Manufacturing
                                   NESHAP AA
                                    8/19/15
                        Phosphate Fertilizer Production
                                   NESHAP BB
                                    8/19/15
                              Petroleum Refinery
                                   NESHAP CC
                                    12/1/15
                              Petroleum Refinery
                                  NESHAP UUU
                                    12/1/15
[1]	This is not meant to be a comprehensive list of all EPA regulatory actions that took place after promulgation of 40 CFR 63, Subpart LLLLL.
Section 114 Request Data Provided by Asphalt Processing and Asphalt Roofing Manufacturing Facilities
In June 2017, the EPA issued a request, pursuant to CAA section 114, to collect information from facilities that are currently considered to be part of the asphalt processing source category and/or asphalt roofing manufacturing source category. Companies completed the survey for their facilities and submitted responses to the EPA by September 30, 2017. For more information regarding the section 114 request, refer to the memorandum entitled "Data Received from Information Collection Request for the Asphalt Processing and Asphalt Roofing Manufacturing Source Categories" (ERG, 2017).
As part of the CAA 114 request, EPA requested information about process equipment, control technologies, point and fugitive emissions, and other aspects of facility operations. Specifically, with regard to the 112(d)(6) review, EPA asked each facility to:
      "...provide an operation date and a description of any developments in practices, processes, or control technologies that [the facility] implemented after the date [the facility] demonstrated initial compliance with either Subpart LLLLL or subpart AAAAAAA that resulted in an increase or decrease in HAP emissions from the emission unit." 
Furthermore, EPA asked questions about air pollution control devices and compliance methods used by each facility for their blowing stills, asphalt loading racks, asphalt storage tanks, coating mixers, saturators (including wet loopers), coaters, sealant applicators, adhesive (laminate) applicators, and mineral handling and storage facilities. 
The EPA reviewed and compared the data received from the CAA section 114 request to identify developments in practices, processes, and control technologies that have been implemented by asphalt processing and asphalt roofing manufacturing facilities. Based on this analysis, facilities did not report the use of any practices, processes, or control technologies that are above and beyond what is required of the rules. A summary of this analysis is included below.
Blowing Stills
Based on the responses EPA received from the CAA section 114 request, there are 71 blowing stills currently operating (or are in construction) at 24 asphalt processing facilities. Of these blowing stills, 25 belong to the 8 facilities that EPA identified as major sources of HAP and are therefore subject to the Subpart LLLLL MACT standards. The remaining 46 blowing stills belong to 16 facilities identified as area sources of HAP. 
All blowing stills identified from the responses to the CAA section 114 request use a combustion control device in combination with continuous monitoring and recording of the temperature in the combustion zone (this control is already required by the Subpart LLLLL). However, based on the responses EPA received from the CAA section 114 request, blowing stills that use chlorinated catalysts (e.g., ferric chloride), do not use add-on control devices to reduce HCl emissions. One facility reported that they use a caustic scrubber to control hydrogen sulfide (a non-HAP) emissions from one of their blowing stills. This facility also uses a hydrogen sulfide Continuous Emissions Monitoring System (CEMS). 
Although the installation of gas scrubbers (e.g., a packed bed scrubber) to control HCl emissions were considered but rejected in the beyond the floor analysis of the original Subpart LLLLL MACT standards rulemaking (68 FR 22975), we re-evaluate this control option in section 8.1 of this memorandum using recent data received from the CAA section 114 request. In section 8.2 of this memorandum, we also evaluate a second option to install a dry sorbent injection system with a fabric filter (DSI/FF) in lieu of a gas scrubber to reduce HCl emissions from blowing stills that use chlorinated catalysts.
Asphalt Loading Racks
Based on the responses EPA received from the CAA section 114 request, there are 54 asphalt loading racks currently operating (or are in construction) at 21 asphalt processing facilities. Of these loading racks,14 belong to 6 facilities that EPA identified as major sources of HAP and are therefore subject to the Subpart LLLLL MACT standards. The remaining 40 asphalt loading racks belong to 15 facilities identified as area sources of HAP.
These asphalt loading racks either are uncontrolled or use a combustion control device in combination with continuously monitoring and recording temperature in the combustion zone or a PM control device in combination with continuously monitoring and recording inlet gas temperature or pressure drop.
Based on these findings, we did not identify any developments in practices, processes, or control technologies that have been implemented by asphalt processing facilities for asphalt loading racks.
Asphalt Storage Tanks
Based on the CAA section 114 request, 428 of the 540 asphalt storage tanks are fixed roof tanks that vent to a combustion control device in combination with continuously monitoring and recording temperature in the combustion zone or to a PM control device in combination with continuously monitoring and recording inlet gas temperature or pressure drop. The remaining 112 asphalt storage tanks are fixed roof tanks or horizontal tanks that vent to the atmosphere (these tanks either are considered Group 2 under the Subpart LLLLL MACT standards or operate at an area source of HAP). 
Based on these findings, we did not identify any developments in practices, processes, or control technologies that have been implemented by asphalt processing facilities or asphalt roofing manufacturing facilities for asphalt storage tanks.
Coating Mixers, Saturators (including wet loopers), Coaters, Sealant Applicators, and Adhesive (laminate) Applicators
All coating mixers, saturators (including wet loopers), coaters, sealant applicators, and adhesive (laminate) applicators that were reported in the CAA section 114 request either are uncontrolled or use a combustion control device in combination with continuously monitoring and recording temperature in the combustion zone or a PM control device in combination with continuously monitoring and recording inlet gas temperature or pressure drop. Based on these findings, we did not identify any developments in practices, processes, or control technologies that have been implemented by asphalt roofing manufacturing facilities for coating mixers, saturators (including wet loopers), coaters, sealant applicators, and adhesive (laminate) applicators.
COST AND ENVIRONMENTAL IMPACTS
We estimated costs and emissions reductions for the two control options that we identified in section 7.3.1 of this memorandum. These two control options include: installing a packed bed scrubber at the outlet of the blowing still (or at the outlet of the combustion device controlling organic HAP emissions) or installing a DSI/FF system at the outlet of the blowing still, to reduce HCl emissions from blowing stills that use chlorinated catalyst.
Based on the responses EPA received from the CAA section 114 request, there are only 3 facilities that use a chlorinated catalyst (i.e., ferric chloride) in their blowing still(s). Table 3 identifies these 3 facilities, the specific blowing stills that use ferric chloride, the specific incinerators used to control organic HAP from these blowing stills, and the HCl emissions reported for these blowing stills. 
        Table 3. Facilities that Emit HCl Emissions from Blowing Stills
                                   Facility
                                     State
                               Blowing Still(s)
                                Incinerator(s)
                                HCl Emissions 
                                  (tpy) [(A)]
                               CertainTeed Corp
                                      MN
                                  113335813,
                               Blowing Still #1
                                    CE 047
                               Thermal Oxidizer
                                3.59 [(][B][)]
                            CertainTeed Corporation
                                      NC
                                   75248113,
                         Blowstills No. 1, 2, & 3
                                  Afterburner
                                (ID No. CDAFB)
                                82.79 [(][C][)]
                    Owens Corning Roofing and Asphalt, LLC
                                      OH
                               P003, P005, P011
                            JZ Thermal Incinerator
                                54.22 [(][D][)]
                                       
                                       
                                  P006, P007
                             PCC Incinerator Stack
                                       
[A]	HCl emissions are from the asphalt processing and asphalt roofing manufacturing modeling file (EPA, 2018).
[B]	Based on confidential business information about ferric chloride use (as reported by the facility in their response to the CAA section 114), another blowing still at this facility may also be emitting HCl and the facility's reported HCl emissions may be inaccurate (under-reported).
[C]	The facility reported combined HCl emissions for all three blowing stills. Based on confidential business information received in the facility's section 114 response, all three blowing stills emitted HCl in 2016.
[D] 	In this analysis, we assumed exhaust from both incinerators could be combined and passed through one HCl control device.

Packed Bed Scrubber
The cost estimate to install a packed bed scrubber for each facility identified in Table 3 is based on information from EPA's Control Cost Manual (EPA, 2002). 
The total capital investment (TCI) consists of the scrubber tower, packing, and pumps. TCI is driven primarily by gas flowrate. The TCI was updated to 2017 dollars using the Chemical Engineering Plant Cost Index (CEPCI). 
The total annual cost (TAC) for each facility includes caustic, wastewater disposal, water, electricity, maintenance, labor, capital recovery costs, overhead, administrative, property taxes, and insurance. Unit costs for labor and electricity were updated to 2017 dollars using current estimates. Current operating labor rates were estimated based on the occupational employment statistics available online from the U.S. Bureau of Labor Statistics. We used the CEPCI to convert unit costs for water, wastewater disposal, and caustic to 2017 dollars. 
The emission reduction and costs calculated for installing a packed bed scrubber at each asphalt processing facility that uses chlorinated catalysts in blowing stills are summarized in Table 4. An HCl removal efficiency of 95% was applied which is consistent with the analyses performed for the original rulemaking. Appendix C provides the detailed cost algorithms for the TCI and TAC to install a packed bed scrubber, and summarizes the other key parameters used in the analysis to assess impacts.
Table 4. Cost and Environmental Impacts for Installing a Packed Bed Scrubber at Asphalt Processing Facilities that Use Chlorinated Catalysts in Blowing Stills
                                   Facility
                                     State
                              Total Capital Cost
                                      ($)
                               Total Annual Cost
                                      ($)
                            HCl Emission Reductions
                                     (tpy)
                            HCl Cost-Effectiveness
                                    ($/ton)
                               CertainTeed Corp
                                      MN
                                   3,156,000
                                    548,000
                                      3.4
                                    161,000
                            CertainTeed Corporation
                                      NC
                                   2,375,000
                                    495,000
                                     78.7
                                     6,000
                    Owens Corning Roofing and Asphalt, LLC
                                      OH
                                   1,905,000
                                    397,000
                                     51.5
                                     8,000

DSI/FF System
The cost estimate to install a DSI/FF system for each facility identified in Table 3 is based on a model that was used in the 2008/2009 hospital/medical/infectious waste incinerators (HMIWI) rule makings (RTI, 2009). The cost algorithms used in the 2008/2009 model were originally documented in EPA's medical waste incinerator background document (EPA, 1994). 
The TCI for each facility to install a DSI/FF system is based on a linear equation that was developed using vendor quotes and is dependent on inlet gas flow rates less than about 7,000 dry standard cubic feet per minute (dscfm). Because the exhaust flow rates associated with all the blowing stills identified in Table 3 are greater than 7,000 dscfm, we extrapolated the TCI. The TCI was then updated to 2017 dollars using the CEPCI. 
The TAC for each facility to install a DSI/FF system considers annual operating hours, the concentration of the HCl present in the blowing still exhaust streams, bag, cage and equipment life, and unit costs for labor, electricity, lime, water, compressed air, and dust disposal. Unit costs for labor, electricity, and lime were updated to 2017 dollars using current estimates. Current operating labor rates were estimated based on the occupational employment statistics available online from the U.S. Bureau of Labor Statistics. We used the CEPCI to convert unit costs for water, compressed air, and dust disposal from 2007 dollars to 2017 dollars.
The emissions reductions and costs calculated for installing a DSI/FF system at each asphalt processing facility that uses chlorinated catalysts in blowing stills are summarized in Table 5. Appendix D provides the detailed cost algorithms for the TCI and TAC to install a DSI/FF system, and summarizes the other key modeling parameters used in the analysis to assess impacts.
Table 5. Cost and Environmental Impacts for Installing a DSI/FF System at Asphalt Processing Facilities that Use Chlorinated Catalysts in Blowing Stills
                                   Facility
                                     State
                              Total Capital Cost
                                      ($)
                               Total Annual Cost
                                      ($)
                            HCl Emission Reductions
                                  (tpy) [(A)]
                            HCl Cost-Effectiveness
                                    ($/ton)
                               CertainTeed Corp
                                      MN
                                   4,569,000
                                    979,000
                                     3.23
                                    303,000
                            CertainTeed Corporation
                                      NC
                                   3,410,000
                                    758,000
                                     74.51
                                    10,000
                    Owens Corning Roofing and Asphalt, LLC
                                      OH
                                   2,740,000
                                    600,000
                                     48.79
                                    12,000
[A]	For modeling purposes, EPA estimates a DSI/FF system is expected to achieve 90% removal of HCl. https://www.eia.gov/todayinenergy/detail.php?id=5430
Nationwide Impacts
The total emissions reductions and costs calculated for applying HCl control options 1 or 2 (i.e., installing a packed bed scrubber at the outlet of the blowing still, or installing a DSI/FF system at the outlet of the blowing still) at asphalt processing facilities that use chlorinated catalysts in blowing stills are summarized in Table 6. These are nationwide impacts and represent all asphalt processing facilities that are subject to 40 CFR 63, Subpart LLLLL.
Table 6. Nationwide Cost and Environmental Impacts for HCl Control Options at Asphalt Processing Facilities that Use Chlorinated Catalysts in Blowing Stills
                                Control Option
                              Total Capital Cost
                                      ($)
                               Total Annual Cost
                                      ($)
                            HCl Emission Reductions
                                     (tpy)
                            HCl Cost-Effectiveness
                                    ($/ton)
                               Control Option 1:
                          Install Packed Bed Scrubber
                                   7,436,000
                                   1,440,000
                                      134
                                    10,800
                               Control Option 2:
                                Install DSI/FF
                                  10,719,000
                                   2,337,000
                                      127
                                    18,400
REFERENCES
EPA. 1992. Documentation for Developing the Initial Source Category List. July 1992. EPA-450/3-91-030.
EPA. 1994. Medical Waste Incinerators--Background Information for Proposed Standards and Guidelines: Model Plant Description and Cost Report for New and Existing Facilities. July 1994. EPA-453/R-94-045a.
EPA. 2002. EPA Air Pollution Control Cost Manual, Section 5.2, Chapter 1. January 2002. EPA/452/B-02-001.
EPA. 2018. Residual Risk Assessment for the Asphalt Processing and Asphalt Roofing Manufacturing Source Categories in Support of the 2018 Risk and Technology Review Proposed Rule. EPA Docket No. EPA - HQ - OAR - 2017 - 0662.
ERG. 2017. Data Received from Clean Air Act Section 114 Request for the Asphalt Processing and Asphalt Roofing Manufacturing Source Categories. EPA Docket No. EPA - HQ - OAR - 2017 - 0662. 
RTI. 2009. Revised Baseline Operating Costs for Existing HMIWI. June 2009. EPA-HQ-OAR-2006-0534-0381.

                                  Appendix A
                                       
                                       
                                       
                                       
                                       
                                       
List of Asphalt Processing and Asphalt Roofing Manufacturing Facilities Located in the United States
                                       

                                       
Table A.2 - Active Facilities[(1)] Located in the United States That are Considered to be 
Subject to 40 CFR Part 63, Subpart LLLLL
                                 Facility Name
Does this facility meet the definition of an asphalt processing facility as defined in 40 CFR 63.8698? (Yes/No)
Does this facility meet the definition of an asphalt roofing manufacturing facility as defined in 40 CFR 63.8698? (Yes/No)
Does this facility meet the definition of both an asphalt processing facility and an asphalt roofing manufacturing facility as defined in 40 CFR 63.8698? (Yes/No)
Does this facility operate a new asphalt processing facility based on the criteria specified in 40 CFR 63.8682(c)? (Yes/No)
Does this facility operate a reconstructed asphalt processing facility based on the criteria specified in 40 CFR 63.8682(d)? (Yes/No)
Does this facility operate an existing asphalt processing facility based on the criteria specified in 40 CFR 63.8682(e)? (Yes/No)
Does this facility operate a new asphalt roofing manufacturing line based on the criteria specified in 40 CFR 63.8682(c)? (Yes/No)
Does this facility operate a reconstructed asphalt roofing manufacturing line based on the criteria specified in 40 CFR 63.8682(d)? (Yes/No)
Does this facility operate an existing asphalt roofing manufacturing line based on the criteria specified in 40 CFR 63.8682(e)? (Yes/No)
CertainTeed
Oxford, NC
Yes
Yes
Yes
No
No
Yes
No
No
Yes
CertainTeed
Shakopee, MN
Yes
Yes
Yes
Yes
No
No
No
No
Yes
CVR Energy
Wynnewood, OK
Yes
No
No
Yes
No
Yes
No
No
No
Hunt, Southland
Sandersville, MS
Yes
No
No
No
No
Yes
No
No
No
Hunt Refining
Tuscaloosa, AL
Yes
No
No
No
No
Yes
No
No
No
Owens Corning
Medina, OH
Yes
Yes
Yes
No
No
Yes
No
No
Yes
Owens Corning
Minneapolis, MN
Yes
Yes
Yes
No
No
Yes
No
No
Yes
Valero
Ardmore, OK
Yes
No
No
No
No
Yes
No
No
No
(1)	As of October 2017.



                                  Appendix B
                                       
                                       
                                       
                                       
                                       
                                       
                       Results of RBLC Database Queries

Appendix B. Results of RBLC Database Queries
                                    Rblcid
                                 Facility
Name
                                     State
                             Permit
Issuance Date
                                 Process
Name
                                 Process
Type
                                 Through-
Put
                                Throughput
Unit
                                   Pollutant
                          Control Method
Description
                              Percent
Efficiency
Process Type = 90.004 (Asphalt Processing)
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
THERMAL INCINERATOR, PCC
19.2


Particulate Matter (PM)

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
THERMAL INCINERATOR, PCC
19.2


Hydrocarbons, Total

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
THERMAL INCINERATOR, PCC
19.2


Carbon Monoxide

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
THERMAL INCINERATOR, PCC
19.2


Nitrogen Oxides (NOx)

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
THERMAL INCINERATOR, PCC
19.2


Sulfur Dioxide (SO2)

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ASPHALT BLOWING STILLS/CONVERTORS (3)
90.034
18
T/h oxidized asphalt
Particulate Matter (PM)
THERMAL INCINERATOR.
95
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ASPHALT BLOWING STILLS/CONVERTORS (3)
90.034
18
T/h oxidized asphalt
Visible Emissions (VE)
VENTED TO THERMAL INCINERATOR
0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ASPHALT BLOWING STILLS/CONVERTORS (3)
90.034
18
T/h oxidized asphalt
Volatile Organic Compounds (VOC)
THERMAL INCINERATOR
95
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ASPHALT BLOWING STILLS/CONVERTORS (3)
90.034
18
T/h oxidized asphalt
Hydrogen Sulfide
THERMAL INCINERATOR
95
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ASPHALT BLOWING STILLS/CONVERTORS (3)
90.034
18
T/h oxidized asphalt
Hydrocarbons, Total
THERMAL INCINERATOR
95
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ASPHALT BLOWING STILLS/CONVERTORS (3)
90.034
18
T/h oxidized asphalt
Hydrochloric Acid

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ASPHALT BLOWING STILLS/CONVERTORS (3)
90.034
18
T/h oxidized asphalt
Carbon Monoxide
THERMAL INCINERATOR
95
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ASPHALT BLOWING STILLS/CONVERTORS (3)
90.034
18
T/h oxidized asphalt
Nitrogen Oxides (NOx)

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ASPHALT BLOWING STILLS/CONVERTORS (3)
90.034
18
T/h oxidized asphalt
Lead (Pb) / Lead Compounds

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ASPHALT BLOWING STILLS/CONVERTORS (3)
90.034
18
T/h oxidized asphalt
Sulfur Dioxide (SO2)

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ASPHALT COATER/SURGE TANK #1
90.034
15.2
t asphalt/h
Particulate Matter (PM)
FIBER BED FILTER
99
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ASPHALT COATER/SURGE TANK #1
90.034
15.2
t asphalt/h
Visible Emissions (VE)
FIBER BED FILTER
99
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ASPHALT COATER/SURGE TANK #1
90.034
15.2
t asphalt/h
Volatile Organic Compounds (VOC)

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ASPHALT COATER/SURGE TANK #1
90.034
15.2
t asphalt/h
Hydrogen Sulfide
FIBER BED FILTER
99
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ASPHALT COATER/SURGE TANK #1
90.034
15.2
t asphalt/h
Hydrocarbons, Total

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ASPHALT COATER/SURGE TANK #1
90.034
15.2
t asphalt/h
Carbon Monoxide

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ASPHALT COATER/SURGE TANK #1
90.034
15.2
t asphalt/h
Sulfur Dioxide (SO2)

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ALPHALT COATER/SURGE TANK #2
90.034
21.6
t asphalt/h
Particulate Matter (PM)
FIBER BED FILTER
99
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ALPHALT COATER/SURGE TANK #2
90.034
21.6
t asphalt/h
Visible Emissions (VE)
FIBER BED FILTER
99
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ALPHALT COATER/SURGE TANK #2
90.034
21.6
t asphalt/h
Volatile Organic Compounds (VOC)

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ALPHALT COATER/SURGE TANK #2
90.034
21.6
t asphalt/h
Hydrogen Sulfide
FIBER BED FILTER
99
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ALPHALT COATER/SURGE TANK #2
90.034
21.6
t asphalt/h
Hydrocarbons, Total

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ALPHALT COATER/SURGE TANK #2
90.034
21.6
t asphalt/h
Carbon Monoxide

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ALPHALT COATER/SURGE TANK #2
90.034
21.6
t asphalt/h
Sulfur Dioxide (SO2)

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ASPHALT FILLER MIXER #1
90.034
15.2
t asphalt coat/h
Particulate Matter (PM)
BAGHOUSE
99
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ASPHALT FILLER MIXER #1
90.034
15.2
t asphalt coat/h
Visible Emissions (VE)
BAGHOUSE
99
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ASPHALT FILLER MIXER #1
90.034
15.2
t asphalt coat/h
Volatile Organic Compounds (VOC)

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ASPHALT FILLER MIXER #1
90.034
15.2
t asphalt coat/h
Carbon Monoxide

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
GROUP 1 ASPHALT LOADING RACK #3
90.034
432000
GAL asphalt/D
Particulate Matter (PM)
REGENERATIVE THERMAL OXIDIZER
95
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
GROUP 1 ASPHALT LOADING RACK #3
90.034
432000
GAL asphalt/D
Visible Emissions (VE)

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
GROUP 1 ASPHALT LOADING RACK #3
90.034
432000
GAL asphalt/D
Volatile Organic Compounds (VOC)
REGENERATIVE THERMAL INCINERATOR OPERATED WITH ELECTRICITY
95
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
GROUP 1 ASPHALT LOADING RACK #3
90.034
432000
GAL asphalt/D
Hydrogen Sulfide
REGENERATIVE THERMAL INCINERATOR OPERATED BY ELECTRICITY
95
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
GROUP 1 ASPHALT LOADING RACK #3
90.034
432000
GAL asphalt/D
Hydrocarbons, Total
REGENERATIVE THERMAL INCINERATOR OPERATED BY ELECTRICITY
95
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
GROUP 1 ASPHALT LOADING RACK #3
90.034
432000
GAL asphalt/D
Carbon Monoxide
REGENERATIVE THERMAL INCINERATOR OPERATED WITH ELECTRICITY
95
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
GROUP 1 ASPHALT LOADING RACK #3
90.034
432000
GAL asphalt/D
Sulfur Dioxide (SO2)

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
GROUP 2 ASPHALT LOADING RACK #4
90.034
864000
GAL asphalt/D
Particulate Matter (PM)
THERMAL INCINERATOR
95
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
GROUP 2 ASPHALT LOADING RACK #4
90.034
864000
GAL asphalt/D
Visible Emissions (VE)

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
GROUP 2 ASPHALT LOADING RACK #4
90.034
864000
GAL asphalt/D
Volatile Organic Compounds (VOC)
THERMAL INCINERATOR
0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
GROUP 2 ASPHALT LOADING RACK #4
90.034
864000
GAL asphalt/D
Hydrogen Sulfide
THERMAL INCINERATOR
95
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
GROUP 2 ASPHALT LOADING RACK #4
90.034
864000
GAL asphalt/D
Carbon Monoxide
THERMAL INCINERATOR
95
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
GROUP 2 ASPHALT LOADING RACK #4
90.034
864000
GAL asphalt/D
Sulfur Dioxide (SO2)

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
COOLING SECTION (2)
90.034
101
t shingles/h
Particulate Matter (PM)

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
COOLING SECTION (2)
90.034
101
t shingles/h
Visible Emissions (VE)

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
COOLING SECTION (2)
90.034
101
t shingles/h
Volatile Organic Compounds (VOC)

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
OXIDIZED ASPHALT FIXED ROOF STORAGE TANKS (3)
90.004
60000
gal tank
Particulate Matter (PM)
FIXED ROOF TANK
95
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
OXIDIZED ASPHALT FIXED ROOF STORAGE TANKS (3)
90.004
60000
gal tank
Visible Emissions (VE)
FIXED ROOF TANK
0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
OXIDIZED ASPHALT FIXED ROOF STORAGE TANKS (3)
90.004
60000
gal tank
Volatile Organic Compounds (VOC)
THERMAL INCINERATOR
95
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
OXIDIZED ASPHALT FIXED ROOF STORAGE TANKS (3)
90.004
60000
gal tank
Hydrogen Sulfide
FIXED ROOF TANK
95
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
OXIDIZED ASPHALT FIXED ROOF STORAGE TANKS (3)
90.004
60000
gal tank
Carbon Monoxide
THERMAL INCINERATOR
95
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
OXIDIZED ASPHALT FIXED ROOF STORAGE TANKS (3)
90.004
60000
gal tank
Sulfur Dioxide (SO2)

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
THERMAL INCINERATOR,  JZ
19.2


Particulate Matter (PM)

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
THERMAL INCINERATOR,  JZ
19.2


Hydrocarbons, Total

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
THERMAL INCINERATOR,  JZ
19.2


Carbon Monoxide

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
THERMAL INCINERATOR,  JZ
19.2


Nitrogen Oxides (NOx)

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
THERMAL INCINERATOR,  JZ
19.2


Sulfur Dioxide (SO2)

0
Process Type = 90.034 (Asphalt Roofing Products Manufacturing)
IN-0191
BUILDING MATERIALS MANUFACTURING CORPORATION
IN
07/07/2014 &nbsp;ACT
ASPHALT SHINGLE MACHINE
90.034
657000
T/YR SHINGLE
Volatile Organic Compounds (VOC)
COALESCING FILTER
95
IN-0191
BUILDING MATERIALS MANUFACTURING CORPORATION
IN
07/07/2014 &nbsp;ACT
BLOW STILL
90.034
262800
T/YR SHINGLE
Volatile Organic Compounds (VOC)
THERMAL OXIDIZER
95
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
THERMAL INCINERATOR, PCC
19.2


Particulate Matter (PM)

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
THERMAL INCINERATOR, PCC
19.2


Hydrocarbons, Total

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
THERMAL INCINERATOR, PCC
19.2


Carbon Monoxide

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
THERMAL INCINERATOR, PCC
19.2


Nitrogen Oxides (NOx)

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
THERMAL INCINERATOR, PCC
19.2


Sulfur Dioxide (SO2)

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ASPHALT BLOWING STILLS/CONVERTORS (3)
90.034
18
T/h oxidized asphalt
Particulate Matter (PM)
THERMAL INCINERATOR.
95
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ASPHALT BLOWING STILLS/CONVERTORS (3)
90.034
18
T/h oxidized asphalt
Visible Emissions (VE)
VENTED TO THERMAL INCINERATOR
0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ASPHALT BLOWING STILLS/CONVERTORS (3)
90.034
18
T/h oxidized asphalt
Volatile Organic Compounds (VOC)
THERMAL INCINERATOR
95
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ASPHALT BLOWING STILLS/CONVERTORS (3)
90.034
18
T/h oxidized asphalt
Hydrogen Sulfide
THERMAL INCINERATOR
95
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ASPHALT BLOWING STILLS/CONVERTORS (3)
90.034
18
T/h oxidized asphalt
Hydrocarbons, Total
THERMAL INCINERATOR
95
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ASPHALT BLOWING STILLS/CONVERTORS (3)
90.034
18
T/h oxidized asphalt
Hydrochloric Acid

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ASPHALT BLOWING STILLS/CONVERTORS (3)
90.034
18
T/h oxidized asphalt
Carbon Monoxide
THERMAL INCINERATOR
95
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ASPHALT BLOWING STILLS/CONVERTORS (3)
90.034
18
T/h oxidized asphalt
Nitrogen Oxides (NOx)

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ASPHALT BLOWING STILLS/CONVERTORS (3)
90.034
18
T/h oxidized asphalt
Lead (Pb) / Lead Compounds

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ASPHALT BLOWING STILLS/CONVERTORS (3)
90.034
18
T/h oxidized asphalt
Sulfur Dioxide (SO2)

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ASPHALT COATER/SURGE TANK #1
90.034
15.2
t asphalt/h
Particulate Matter (PM)
FIBER BED FILTER
99
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ASPHALT COATER/SURGE TANK #1
90.034
15.2
t asphalt/h
Visible Emissions (VE)
FIBER BED FILTER
99
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ASPHALT COATER/SURGE TANK #1
90.034
15.2
t asphalt/h
Volatile Organic Compounds (VOC)

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ASPHALT COATER/SURGE TANK #1
90.034
15.2
t asphalt/h
Hydrogen Sulfide
FIBER BED FILTER
99
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ASPHALT COATER/SURGE TANK #1
90.034
15.2
t asphalt/h
Hydrocarbons, Total

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ASPHALT COATER/SURGE TANK #1
90.034
15.2
t asphalt/h
Carbon Monoxide

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ASPHALT COATER/SURGE TANK #1
90.034
15.2
t asphalt/h
Sulfur Dioxide (SO2)

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ALPHALT COATER/SURGE TANK #2
90.034
21.6
t asphalt/h
Particulate Matter (PM)
FIBER BED FILTER
99
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ALPHALT COATER/SURGE TANK #2
90.034
21.6
t asphalt/h
Visible Emissions (VE)
FIBER BED FILTER
99
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ALPHALT COATER/SURGE TANK #2
90.034
21.6
t asphalt/h
Volatile Organic Compounds (VOC)

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ALPHALT COATER/SURGE TANK #2
90.034
21.6
t asphalt/h
Hydrogen Sulfide
FIBER BED FILTER
99
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ALPHALT COATER/SURGE TANK #2
90.034
21.6
t asphalt/h
Hydrocarbons, Total

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ALPHALT COATER/SURGE TANK #2
90.034
21.6
t asphalt/h
Carbon Monoxide

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ALPHALT COATER/SURGE TANK #2
90.034
21.6
t asphalt/h
Sulfur Dioxide (SO2)

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ASPHALT FILLER MIXER #1
90.034
15.2
t asphalt coat/h
Particulate Matter (PM)
BAGHOUSE
99
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ASPHALT FILLER MIXER #1
90.034
15.2
t asphalt coat/h
Visible Emissions (VE)
BAGHOUSE
99
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ASPHALT FILLER MIXER #1
90.034
15.2
t asphalt coat/h
Volatile Organic Compounds (VOC)

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
ASPHALT FILLER MIXER #1
90.034
15.2
t asphalt coat/h
Carbon Monoxide

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
GROUP 1 ASPHALT LOADING RACK #3
90.034
432000
GAL asphalt/D
Particulate Matter (PM)
REGENERATIVE THERMAL OXIDIZER
95
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
GROUP 1 ASPHALT LOADING RACK #3
90.034
432000
GAL asphalt/D
Visible Emissions (VE)

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
GROUP 1 ASPHALT LOADING RACK #3
90.034
432000
GAL asphalt/D
Volatile Organic Compounds (VOC)
REGENERATIVE THERMAL INCINERATOR OPERATED WITH ELECTRICITY
95
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
GROUP 1 ASPHALT LOADING RACK #3
90.034
432000
GAL asphalt/D
Hydrogen Sulfide
REGENERATIVE THERMAL INCINERATOR OPERATED BY ELECTRICITY
95
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
GROUP 1 ASPHALT LOADING RACK #3
90.034
432000
GAL asphalt/D
Hydrocarbons, Total
REGENERATIVE THERMAL INCINERATOR OPERATED BY ELECTRICITY
95
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
GROUP 1 ASPHALT LOADING RACK #3
90.034
432000
GAL asphalt/D
Carbon Monoxide
REGENERATIVE THERMAL INCINERATOR OPERATED WITH ELECTRICITY
95
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
GROUP 1 ASPHALT LOADING RACK #3
90.034
432000
GAL asphalt/D
Sulfur Dioxide (SO2)

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
GROUP 2 ASPHALT LOADING RACK #4
90.034
864000
GAL asphalt/D
Particulate Matter (PM)
THERMAL INCINERATOR
95
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
GROUP 2 ASPHALT LOADING RACK #4
90.034
864000
GAL asphalt/D
Visible Emissions (VE)

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
GROUP 2 ASPHALT LOADING RACK #4
90.034
864000
GAL asphalt/D
Volatile Organic Compounds (VOC)
THERMAL INCINERATOR
0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
GROUP 2 ASPHALT LOADING RACK #4
90.034
864000
GAL asphalt/D
Hydrogen Sulfide
THERMAL INCINERATOR
95
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
GROUP 2 ASPHALT LOADING RACK #4
90.034
864000
GAL asphalt/D
Carbon Monoxide
THERMAL INCINERATOR
95
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
GROUP 2 ASPHALT LOADING RACK #4
90.034
864000
GAL asphalt/D
Sulfur Dioxide (SO2)

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
COOLING SECTION (2)
90.034
101
t shingles/h
Particulate Matter (PM)

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
COOLING SECTION (2)
90.034
101
t shingles/h
Visible Emissions (VE)

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
COOLING SECTION (2)
90.034
101
t shingles/h
Volatile Organic Compounds (VOC)

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
OXIDIZED ASPHALT FIXED ROOF STORAGE TANKS (3)
90.004
60000
gal tank
Particulate Matter (PM)
FIXED ROOF TANK
95
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
OXIDIZED ASPHALT FIXED ROOF STORAGE TANKS (3)
90.004
60000
gal tank
Visible Emissions (VE)
FIXED ROOF TANK
0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
OXIDIZED ASPHALT FIXED ROOF STORAGE TANKS (3)
90.004
60000
gal tank
Volatile Organic Compounds (VOC)
THERMAL INCINERATOR
95
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
OXIDIZED ASPHALT FIXED ROOF STORAGE TANKS (3)
90.004
60000
gal tank
Hydrogen Sulfide
FIXED ROOF TANK
95
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
OXIDIZED ASPHALT FIXED ROOF STORAGE TANKS (3)
90.004
60000
gal tank
Carbon Monoxide
THERMAL INCINERATOR
95
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
OXIDIZED ASPHALT FIXED ROOF STORAGE TANKS (3)
90.004
60000
gal tank
Sulfur Dioxide (SO2)

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
THERMAL INCINERATOR,  JZ
19.2


Particulate Matter (PM)

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
THERMAL INCINERATOR,  JZ
19.2


Hydrocarbons, Total

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
THERMAL INCINERATOR,  JZ
19.2


Carbon Monoxide

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
THERMAL INCINERATOR,  JZ
19.2


Nitrogen Oxides (NOx)

0
OH-0288
OWENS CORNING MEDINA
OH
06/14/2004 &nbsp;ACT
THERMAL INCINERATOR,  JZ
19.2


Sulfur Dioxide (SO2)

0


                                  Appendix C
                                       
                                       
                                       
                                       
                                       
                                       
       Detailed Cost Algorithms for TCI And TAC of Packed Bed Scrubbers
                                       
                                   Parameter
                               Equation Variable
                                   Equation
                                 Calculations
STREAM AND INPUT DATA
 
                                       
                                       
                                       
                                       
Facility Name
 
                                       
                               CertainTeed Corp
                            CertainTeed Corporation
              Owens Corning Roofing and Asphalt, LLC (1652050040)
                              TOTAL FOR INDUSTRY
Emission Point
 
 
                      113335813 (CE 047 Thermal Oxidizer)
                     75248113 (Afterburner (ID No. CDAFB))
Combined Stacks from P003, P011, P005 (JZ Thermal Incinerator) and P006, P007 (PCC Thermal Incinerator)
 
State
 
 
                                      MN
                                      NC
                                      OH
 
Flowrate (acfm)
AQtot
Facility-specific, based on modeling file
                                            58,500 
                                           40,000 
                                                     29,300 
 
Flowrate (acfm) (Per Scrubber)
AQ
=AQtot / #Scr
                                            58,500 
                                           40,000 
                                                     29,300 
 
Operating Hrs
H
Avg. of survey responses
                                              2,565 
                                            2,565 
                                                       2,565 
 
Percent HCl Reduction Required
%Ctrl
 
                                                                           95.0
                                                                           95.0
                                                                           95.0
 
Temp (F)
Tf
Facility-specific, based on modeling file
                                                                            800
                                                                            800
                                                                            630
 
Temp (K)
T
=(Tf + 459.67) * 5/9
                                                                            700
                                                                            700
                                                                            605
 
Inlet HCl Loading (lb/hr)
In HCltot
Facility-specific, based on modeling file
                                                                            2.8
                                                                           64.6
                                                                           42.3
 
Inlet HCl Loading (lb/hr) (Per Scrubber)
In HClscr
= In HCltot / #Scr
                                                                            2.8
                                                                           64.6
                                                                           42.3
 
Inlet HCl Loading (mole fraction)
In HClm
= (In HClscr / 60 / MWhcl) / (AQ * Dens / MWg)
                                                                       0.000020
                                                                        0.00068
                                                                        0.00061
 
CAPITAL COST CALCULATIONS
 
                                       
                                       
                                       
                                       
Scrubber Diameter Exponent (S1)
SDC
= (-0.915 - SQRT(-1.144359 - (1.188 * (LOG10((mm * Fp * ((ui / 2.42) ^ 0.2) * MWR^2  * ap^2) / (12960000 * f^2 * 32.2)))))) / (-0.594)
                                                                          -1.32
                                                                          -1.32
                                                                          -1.32
 
Ds (Scrubber Diameter)
Ds
= SQRT((240 * Dg * AQ * 10^SDC) / (MWR * Dl * ap * PI * SQRT((Dg / Dl))))
                                                                           14.1
                                                                           11.7
                                                                           10.0
 
Hpack (Packing Constant)
Hpack
= LN((In HClm / ((In HClm * (100 - %Ctrl)) / (100-In HClm * %Ctrl)))) * (((x * (HpackA ^ BBB)) / (HpackB ^ g)) * (ui^g) / (ug^BBB) * SQRT(HpackC) + ((1 / AFT) * (t * (HpackD ^ bb) * SQRT(HpackE))))
                                                                           34.3
                                                                           34.3
                                                                           34.3
 
Number of Packed Scrubbers
#Scr
Max flowrate per scrubber is 74,800 acfm
                          1 
                       1 
                                            1 
 
Hpack - A
HpackA
= (240 *  Dg * AQ) / (PI * Ds^2)
                1,582.6 
             1,582.6 
                                  1,582.6 
 
Hpack - B
HpackB
= MWR * D * ap
                   2,271 
                2,271 
                                     2,271 
 
Hpack C
HpackC
= ug / (Dg * Dfg)
                     0.86 
                  0.86 
                                       0.86 
 
Hpack D
HpackD
= (MWR * Dl * ap) / ui
                   1,052 
                1,052 
                                     1,052 
 
Hpack E
HpackE
= ui / (Dl * Dfl)
                   338.4 
                338.4 
                                     338.4 
 
TCI - Pack
TCIp
= #Scr * 0.649 * Cp * Hpack * PI * Ds^2 * (1.0506 * 109.4 / 100) * (2017 CEPCI / 389.5)
 $            469,047 
 $         320,650 
 $                              234,880 
 
TCI - Pump
TCIpump
= #Scr * 0.0312 * MWR * ap * PI * Ds^2 * CFpump * m * (1.0506 * 109.4 / 100) * (2017 CEPCI / 389.5)
 $              28,780 
 $           19,679 
 $                                14,415 
 
TCI - Tower
TCItower
= #Scr * ((417.956 * m * PI * Ds * Hpack) + (453.7808 * m * PI * Ds^2) + (838.8974 * m * PI * Ds)) * (1.0506 * 109.4 / 100) * (2017 CEPCI / 389.5)
 $         1,607,816 
 $      1,260,905 
 $                           1,038,858 
 
TCI (scrubber)
TCIscrub
= (TCItower + TCIpump + TCIp) * (Retrofit Factor of 1.4)
 $         2,947,900 
 $      2,241,728 
 $                           1,803,414 
 
Number of Ductlines
ND
Calculate such that max flowrate per ductline is 154,042 acfm
                          1 
                       1 
                                            1 
                                       
Duct Diameter (ft)
Dd
= 1.128 x (AQ / ut)^0.5
                                                                           4.98
                                                                           4.12
                                                                           3.53
 
TCI - Duct - SS
TCIduct
= #Scr * ND * (1.458 * ((0.39 * ((Dd / ND)^2) * 3.14159 * L) + (74.2 * L * Ne_Ld * EXP(0.8016 * (Dd / ND))) + (23 * EXP(0.6804 * (Dd / ND))) + (af * (Df^b)))) * (2017 CEPCI / 389.5) * (Retrofit factor of 1.4)
                             $            184,207 
                               $         109,318 
                    $                                77,980 
                                       
Total Monitoring Cost
TCImon
Parametric monitor capital cost, default applied to all facilities
                             $              24,100 
                              $           24,100 
                    $                                24,100 
                                       
TCI (Total)
 
= TCIscrub + TCIduct + TCImon
                               $      3,156,208
                                 $   2,375,146
 $                      1,905,494 
                                 $   7,436,848
ANNUAL COST CALCULATIONS
 
                                       
                                       
                                       
                                       
Cost of Caustic
Ccaus
= #Scr * (0.03 * AQ * Dg * (In HClm - (In HClm * (100 - %Ctrl) / (100 - In HClm * %Ctrl))) * _SR1 * MWc * H * CFc / MWg)
 $                 2,938 
 $           67,731 
 $                                44,353 
 
Cost of WW disposal
Cdis
= #Scr * (7.194 * D7 * Dg * (In HClm -(In HClm * (100 - %Ctrl) / (100 - In HClm * %Ctrl))) * _SR2 * MWs * (1 / BF) * H * CFww / MWg)
 $                    159 
 $             3,654 
 $                                  2,393 
 
Cost of solvent (water)
Csolv
= #Scr * (Cdis * (CFwt / CFww))
 $                      17 
 $                402 
 $                                     263 
 
Cost of labor and supervisor
Clab
= #Scr * (0.07188 * H * CFlab)
 $               14,690 
 $           14,690 
 $                                14,690 
 
Cost of maintenance
Cmain
= #Scr * (0.125 * H * CFmain)
 $               25,545 
 $           25,545 
 $                                25,545 
 
Electricity Amount (Fan)
ElecFan
= (0.000117 * AQ * H * (((Hpack * (AQ^2) * cpc * Dg * (10^(j * MWR * Dl * ap / 3600))) / (225* PI^2 * Ds^4)) + (0.136 * (( 1 / Dd)^1.18) *((ut / 1000)^1.8) * (L / 100) + (L) * (Ne_Ld) * k * ((ut / 4016)^2)))) / ef
 $             788,106 
 $         541,961 
 $                              399,334 
 
Electricity Amount (Pump)
ElecPump
= (0.00000585 * H * PI * Ds^2 * MWR * ap * Pp) / Ep
 $               29,447 
 $           20,135 
 $                                14,748 
 
Electricity Cost (Total)
ElecTot
 = #Scr * CFelec * (ElecFan + ElecPump)
 $          56,492.90 
 $           38,841 
 $                                28,613 
 
Variable Costs
Var
= CCaus + Cdis + Csolv + Clab + Cmain + ElecTot
 $               99,843 
 $         150,863 
 $                              115,858 
 
Capital Recovery
CapRec
= (TCIscrub * ((I*((1 + I) ^ n)) / (((1 + I) ^ n) - 1)))
 $             279,228 
 $         212,339 
 $                              170,821 
 
Overhead Cost
Ovrhd
= 0.6 * (Clab + Cmain)
 $          24,141.09 
 $           24,141 
 $                                24,141 
 
Administrative Cost
Admin
= 0.02 * TCIscrub
 $               58,958 
 $           44,835 
 $                                36,068 
 
Property Tax
Tax
= 0.01 * TCIscrub
 $               29,479 
 $           22,417 
 $                                18,034 
 
Insurance
Ins
= 0.01 * TCIscrub
 $               29,479 
 $           22,417 
 $                                18,034 
 
Fixed Costs
Fix
= CapRec + Ovrhd + Admin + Tax + Ins
 $             421,286 
 $         326,149 
 $                              267,099 
 
TAC (scrubber)
TACscr
= Var + Fix
 $             521,128 
 $         477,012 
 $                              382,957 
 
CRF duct
CRFduct
 
                                             0.079
                                           0.079
                                                      0.079
 
Duct - Capital Recovery
DuctCR
= TCIduct * CRFduct
 $               14,470 
 $             8,587 
 $                                  6,125 
                                       
Duct - Administrative Cost
DuctAdmin
= TCIduct * 0.02
 $                 3,684 
 $             2,186 
 $                                  1,560 
                                       
Duct - Property Tax
DuctTax
= TCIduct * 0.01
 $                 1,842 
 $             1,093 
 $                                     780 
                                       
Duct - Insurance
DuctIns
= TCIduct * 0.01
 $                 1,842 
 $             1,093 
 $                                     780 
                                       
TAC - Duct
TACduc
= DuctCR + DuctAdmin + DuctTax + DuctIns
 $               21,838 
 $           12,960 
 $                                  9,245 
 
Annual Monitoring Cost
TACmon
Parametric monitor annual cost, default applied to all facilities
 $                 5,200 
 $             5,200 
 $                                  5,200 
 
TAC (Total)
TAC
= TACscr + TACduc + TACmon
 $          548,166 
 $       495,172 
 $                          397,401 
                                 $  1,440,739
EMISSION REDUCTIONS AND COST-EFFECTIVENESS
                                       
                                       
                                       
Lbs of HCl Removed per Yr
 
= H * In HDlscr * (%Ctrl / 100)
                    6,824 
             157,303 
                                 103,009 
                                        267,136
Dollars per Ton of HCl Removed
 
 
 $          160,650 
 $           6,296 
 $                             7,716 
                                $       10,787
                                       
                           PACKED SCRUBBER DEFAULTS
Variable
COMMON DEFAULTS - PACKED SCRUBBER
 
I
I = interest rate

 
                                                                         0.0475
2017 CEPCI
2017 CEPCI

 
                                                                          567.5
Dg
Dg = density of gas, lb/ft3
 
                                                                         0.0709
Ne_Ld
Ne/LD = # of elbows per length of duct
                                                                           0.02
L
L = length of ductwork
 
                                                                            500
MWR
MWR = minimum wetting rate, ft2/hr
                                                                            1.3
ut
ut = gas transport velocity, ft/min
                                                                           3000
Dl
Dl = density of liquid, lb/ft3

                                                                           62.4
ap
a = packing constant, ft2/ft3
 
                                                                             28
Variable
DEFAULTS- TOTAL ANNUAL COST -- PACKED SCRUBBER 
n
n = life of equipment, yrs
 
                                                                             15
SR1
SR1 = moles caustic/moles pollutant
                                                                            0.5
MWc
MWc = caustic molec wt, lb/lb-mole
                                                                             62
CFc
Cfc = cost factor for caustic, $/ton
                                                                            450
MWg
MWg = gas molecular weight, lb/lb-mole
                                                                             29
Dens
gas density, lb/ft3

 
                                                                         0.0315
MWhcl
HCl molecular weight, lb/lbmol
 
                                                                          36.46
SR2
SR2 = moles salt/moles HCl
 
                                                                              1
MWs
MWs = salt molecular weight, lb/lb-mole
                                                                           58.5
BF
BF = fraction of waste stream treated
                                                                            0.1
CFww
CFww  = cost factor for ww disposal, $/gal
                                                                         0.0054
CFwt
CFwt = cost factor for water, $/gal
                                                                       0.000591
CFlab
CFlab = cost factor for labor, $/hr
                                                                          79.67
CFmain
CFmain = cost factor for maintenance, $/hr
                                                                          79.67
 Variable
DEFAULTS - ELECTRICITY - PACKED SCRUBBER
CFelec
CFelec = cost factor for electricy, $/kw-hr
                                                                        0.06910
Pp
Pp = pressure of pump, ft of H20
                                                                             60
Ep
Ep = efficiency of pump

                                                                            0.7
cpc
cpc = packing constant

                                                                           0.24
j
j = packing constant


                                                                           0.17
k
k = friction loss factor for elbow

                                                                           0.35
ef
ef = efficiency of fan
 
 
                                                                            0.7
 Variable
DEFAULTS - DUCTWORK - PACKED SCRUBBER
af
af = fan coefficient


                                                                           22.1
b
b = fan exponent


                                                                           1.55
Df
Df = fan diameter, inches

                                                                           36.5
n_duct
n_duct = life of equipment, yrs
 
                                                                             20
Variable
DEFAULTS -TCI - PACKED SCRUBBER
                                       
m
m = factor to convert from FRP to other material
                                                                              1
mm
mm = ratio of solvent density to water density
                                                                              1
Fp
Fp = packing factor


                                                                             65
ui
ui = viscosity of liquid, lb/ft-hr

                                                                           2.16
f
f = flooding factor


                                                                            0.7
ug
ug = viscosity of gas, lb/ft-hr

                                                                          0.044
Dfg
Dfg = diffusivity of pollutant in gas, ft2/hr
                                                                          0.725
Dfl
Dfl = diffusivity of pollutant in liquid, ft2/hr
                                                                       0.000102
AFT
AFT = absorption factor

                                                                             17
x
x = packing constant


                                                                           3.82
t
t = packing constant


                                                                         0.0125
g
g = packing constant


                                                                           0.45
BBB
BBB = packing constant

                                                                           0.41
bb
b = packing constant


                                                                           0.22
Cp
Cp = packing cost factor, $/ft3

                                                                             20
CFpump
CFpump = cost factor for pump, $/gpm
 
 
 
                                                                          24.06
                                       
                                  Appendix D
                                       
                                       
                                       
                                       
                                       
                                       
          Detailed Cost Algorithms for TCI And TAC of DSI/FF Systems


                               Parameters/Costs 
                                   Equation
                                     Value
A. Parameters
 
 
 
 
 
1. Facility name and location
 
 
                                CertainTeed, MN
                                CertainTeed, NC
                               Owens Corning, OH
2. Annual operating hours, hr/yr (H)
 
Average for all blowing stills in entire source category.
                                     2565
                                     2565
                                     2565
3. Exhaust gas flow rate
 
 
                                       
                                       
                                       
 
a. acfm
From modeling file.
                                     58500
                                     40000
                                     29300
 
b. dscfm (Q)
Assume moisture content of 15.52%. 
=Flowrate (acfm) / ((460°R+T1)/528°R) x (1-moisture content (0.1552))
                                     25836
                                     17666
                                     12940
4. HCl concentration
 
 
                                       
                                       
                                       
 
a. tpy
From modeling file.
                                     3.59
                                     82.79
                                     54.22
 
b. ppmvd
= [tpy HCL] / [(1/1000000) x 1 lb-mol/385.3 ft3 x 36.46 lb/lbmol x Q x 60 min/hr x H x 1 ton/2000 lbs]
                                      19
                                      644
                                      575
5. PM concentration, gr/dscf (PM)
 
Assume 0.1 gr/dscf.
                                      0.1
                                      0.1
                                      0.1
6. Water vapor in gas from blowing still (assume 15.5% by weight)
 
 
                                       
                                       
                                       
 
a. lb/min 
= Q / (385 ft3/lb-mol) x (29 lb Air/lb-mol) x moisture content (0.1552)
                                     301.6
                                     206.3
                                     151.1
 
b. scfm 
= (lb/min) / (18 lb Water/lb-mol) x (385 ft3/lb-mol)
                                     6112
                                     4179
                                     3061
7. Enthalpy change in quench
 
 
                                       
                                       
                                       
 
Temperature into quench, °F (T1)
Assume 550°F at blowing still outlet.
                                      550
                                      550
                                      550
 
Temperature out of quench, °F (T2)
Assume cooldown to 300°F.
                                      300
                                      300
                                      300
 
a. Dry gas from blowing still, Btu/lb air 
= [7.010 x (T2 - 77°F) - 7.554 x (T1 - 77°F)] / (29 lb/lb-mol)
                                      69
                                      69
                                      69
 
b. Water vapor from blowing still, Btu/lb water vapor 
= [8.154 x (T2 - 77°F) - 9.215 x (T1 - 77°F)] / (18 lb/lb-mol)
                                      141
                                      141
                                      141
 
c. Total gas stream, Btu/yr 
= [(Btu/lb air) x Q / (385 ft3/lb-mol) x (29 lb/lb-mol) x (60 min/hr) x H] +
[(Btu/lb water vapor) x Q x (0.00753 lb water vapor/ft3) x (60 min/hr) x H]
                                   2.50E+10
                                   1.71E+10
                                   1.25E+10
 
d. Cooling water
 
                                       
                                       
                                       
 
                                       i. Heat of vaporization at 77°F, Btu/lb
 
                                     1050
                                     1050
                                     1050
 
                                            ii. Sensible heat for vapor, Btu/lb
 
                                      85
                                      85
                                      85
 
                                                       iii. Total, Btu/lb water
 
                                     1135
                                     1135
                                     1135
8. Cooling water evaporated, lb/yr
 
 
                                       
                                       
                                       
 
a. lb/yr 
= [enthalpy change (total gas stream, Btu/yr)] / [enthalpy change (cooling water, Btu/lb)]
                                   2.20E+07
                                   1.51E+07
                                   1.10E+07
 
b. scfm
= [cooling water evaporated (lb/yr)] / (18 lb/lb-mol) x (385 ft3/lb-mol) / (H * 60 min/hr)
                                     3059
                                     2092
                                     1532
9. Actual gas flow into fabric filter, acfm (AQ)
 
=[Q + (water vapor in gas from blowing still, scfm) + 
(water vapor added in quench, i.e., cooling water evaporated, scfm)] x [(T2 + 460°F)/528°R]
                                     50389
                                     34454
                                     25238
10. Operating labor rate, $/hr (LR)
 
See "Wages" tab.
                                    $43.01
                                    $43.01
                                    $43.01
11. Electricity cost, $/kWh (EC)
 
https://www.eia.gov/electricity/data/browser/#/topic/7?agg=2,0,1&geo=g&freq=M
                                    $0.0682
                                    $0.0682
                                    $0.0682
12. Lime cost, $/ton (LC)
 
https://www.indexmundi.com/en/commodities/minerals/lime/lime_t5.html
                                    $110.60
                                    $110.60
                                    $110.60
13. Water cost, $/1,000 gal (WC)
 
=0.2 x (CI2/CI4)
                                     $0.24
                                     $0.24
                                     $0.24
14. Compressed air cost, $/1,000 ft3 (CAC)
 
=0.24 x (CI2/CI3)
                                     $0.31
                                     $0.31
                                     $0.31
15. Dust disposal cost, $/ton (DDC)
 
=34.29 x (CI2/CI4)
                                    $41.56
                                    $41.56
                                    $41.56
16. Capital recovery factors (CRF) 
 
Equation in EPA Air Pollution Control Cost Manual (EPA, 2002)
= [i x (1 + i)[a]] / [(1 + i)[a] - 1], where i = interest rate, a = equipment life
                                       
                                       
                                       
a. Bag CRF, 2-yr life, 7% interest
 
Assumed bag life of 2 years and used current bank prime loan rate (5%) as the interest rate.
                                    0.53780
                                    0.53780
                                    0.53780
b. Cage CRF, 4-yr life, 7% interest
 
Assumed bag life of 4 years and used current bank prime loan rate (5%) as the interest rate.
                                    0.28201
                                    0.28201
                                    0.28201
c. Equipment CRF, 20-yr life, 7% interest
 
Assumed bag life of 20 years and used current bank prime loan rate (5%) as the interest rate.
                                    0.08024
                                    0.08024
                                    0.08024
17. Cost index
 
The cost index is not used for costs related to labor, electricity, or lime.
                                       
                                       
                                       
 
a. 2017 (CI2)
 
                                     567.5
                                     567.5
                                     567.5
 
b. 1989 (CI1)
 
                                     357.5
                                     357.5
                                     357.5
 
c. 2004 (CI3)
 
                                     444.2
                                     444.2
                                     444.2
 
d. 2005 (CI4)
 
                                     468.2
                                     468.2
                                     468.2
 
 
 
                                       
                                       
                                       
B. Total Capital Investment 
 
= (63.8 x Q + 407,498) x (1.4 retrofit cost factor) x (CI2/CI1)
                                  $4,568,816
                                  $3,410,368
                                  $2,740,346
 
 
 
                                       
                                       
                                       
C. Direct Annual Operating Costs, $/yr
 
 
                                       
                                       
                                       
1. Electricity 
 
=(0.746 kW/hp) x hp (0.0079 x Q + 3.51) x H x EC
                                  $27,093.50
                                  $18,670.33
                                  $13,798.54
2. Makeup lime 
 
= (2.4E-7 lb/dscf x HCl x Q) x (1 ton/2,000 lb) x (60 min/hr) x H x LC
                                   $1,007.53
                                  $23,223.72
                                  $15,207.93
3. Evaporative cooler water 
 
= (0.1007 x Q + 23.1506) gal/min x (60 min/hr) x H x WC
                                    $97,927
                                    $67,232
                                    $49,478
4. Operating labor 
 
= (1 hr/shift) x (1 shift/8 hr) x H x LR
                                    $13,789
                                    $13,789
                                    $13,789
5. Supervisory labor 
 
= 0.15 x (operating labor)
                                    $2,068
                                    $2,068
                                    $2,068
6. Maintenance labor 
 
= (0.5 hr/shift) x (1 shift/8 hr) x H x (LR x 1.1)
                                    $7,584
                                    $7,584
                                    $7,584
7. Maintenance materials 
 
= 0.02 x TCI
                                    $91,376
                                    $68,207
                                    $54,807
8. Compressed air 
 
= AQ x (2 ft3 air/1,000 ft3 filtered) x (60 min/hr) x H x CAC
                                    $4,756
                                    $3,252
                                    $2,382
9. Dust disposal 
 
= [(PM gr/dscf x Q x 60 min/hr x 1 lb/7,000 gr) + (HCl x Q x 60 min/hr x 2.86E-7 lb/dscf)] x 
(1 ton/2,000 lb) x H x DDC
                                    $1,632
                                    $11,207
                                    $7,402
10. Bag replacement
 
 
                                       
                                       
                                       
 
a. Bag cost 
= AQ x ($2.5/ft2) x (CI2/CI1) x (1.08 taxes and freight ratio)/(3.5 ft/min G/C ratio)
                                    $61,705
                                    $42,191
                                    $30,905
 
b. Bag replacement labor cost 
= AQ x (0.15 hr/bag)/(18 ft2 bag area)/(3.5 ft/min G/C ratio) x LR
                                    $5,160
                                    $3,528
                                    $2,584
 
c. Bag replacement cost 
= Bag CRF x [(total bag cost) + (bag replacement labor cost)]
                                  $35,960.26
                                  $24,588.21
                                  $18,010.87
11. Cage replacement
 
 
                                       
                                       
                                       
 
a. Number of bags 
= AQ/(3.5 ft/min G/C ratio)/(18 ft2 bag area)
                                      800
                                      547
                                      401
 
b. Cage replacement labor cost 
= bag replacement labor cost
                                    $5,160
                                    $3,528
                                    $2,584
 
c. Cage replacement cost 
= Cage CRF x [single-cage cost (4.941+ 0.163 x 18 ft2 bag area) x (number of bags) x 
(CI2/CI1) + (cage replacement labor cost)] 
                                    $7,980
                                    $5,456
                                    $3,997
 
 
 
                                       
                                       
                                       
D. Indirect Annual Costs, $/yr
 
 
                                       
                                       
                                       
1. Overhead 
 
= 0.6 x (labor + maintenance materials)
                                    $68,891
                                    $54,990
                                    $46,949
2. Property taxes, insurance, and administration
 
= 0.04 x TCI
                                   $182,753
                                   $136,415
                                   $109,614
3. Capital recovery 
 
= Equipment CRF x (TCI - bag replacement cost - cage replacement cost)
                                   $363,088
                                   $271,246
                                   $218,127
 
 
 
                                       
                                       
                                       
E. Total Annual Cost
 
 
                                       
                                       
                                       
1. $/yr 
 
= Direct Annual Costs + Indirect Annual Costs
                                   $978,729
                                   $757,723
                                   $599,689


