1

MEMORANDUM

Date: August 7 , 2014

Subject: National Impacts Associated with the Final NESHAP for Existing Amino and Phenolic

Resins Continuous Process Vents

From: Nick Parsons, EPA/OAQPS/SPPD/RCG

To: EPA Docket File (EPA

- HQ

- OAR

- 2012

– 0133 )

______________________________________________________________________________

The purpose of this memorandum is to present information on the nationwide costs of the con trol technology required for reducing hazardous air pollutants (HAP) emissions from unregulated existing process vents identified in the Amino and Phenolic Resins (APR) Production source

category.

1.0 Background

On January 20, 2000, the EPA finalized National Emissions Standards for Hazardous Air Pollutants (NESHAP) for the APR source category based on the requirements of section 112(d) of the Clean Air Act (CAA) to c ontrol HAP emissions from both new and existing sources. The EPA proposed amendments t o the source category on January 9, 2014, based on residual risk and technology reviews. At the time of the 2014 proposal, the presence of uncontrolled continuous

process vents at two facilities in the APR source category (Georgia Pacific in Crossett, AR, and

Tembec in Toledo, OH) had been identified

. Following the January 2014 proposal, the EPA received information that there are additional facilities with uncontrolled process vents in the APR source category. The facilities identified that have continuous process vents are shown in

Table 1. The four facilities listed in the below table have a total of seven continuous process vents combined.

Table 1. Existing APR Facilities with Uncontrolled Continuous Process Vents

Facility Location Control Device

Georgia Pacific Crossett, Arkansas No HAP Control Georgia Pacific Conway, North Carolina No HAP Control Georgia Pacific Taylorsville, Mississippi No HAP Control

Tembec Toledo, Ohio No HAP Control2

As discussed in the memorandum entitled “MACT Floor and Beyond

- the

- Floor for Existing Unregulated Emission Sources in the Amino and Phenolic Resins Production S ource Category” available from the rulemaking docket (EPA

- HQ

- OAR

- 2012

- 0133), the MACT floor for existing APR process vents was established at 0.95 kilograms of HAP per megagram ( 1.9 lb of HAP /ton )

of resin produced

. The urea formaldehyde concentrate (UFC) process vent at Georgia Pacific’s Crossett facility was not included in the MACT floor. The main reason for excluding the UFC process vent from the MACT floor analysis is because reliable and accurate emissions information are not available. Also, the UFC process vent is significantly different than the other spray dryer process vents and is a non

- dr yer production unit subject to another regulation when producing formaldehyde. Further, the UFC process vents and several other process vents are simultaneously controlled by a regenerative thermal oxidizer. These factors were also reasons for

not includin g the UFC process vent in the MACT floor analysis, and more details on this decision can be found in the MACT floor memorandum. As mentioned, the MACT floor was

established at 0.95 kg HAP/Mg ( 1.9 lb of HAP/ton ) of resin produced. Four of the seven process vents will be able to meet t he standard without any additional controls. The other three process

vents will need to have HAP controls installed in order to meet the standard . Carbon adsorbers are highly effective at reducing HAP emissions

, and it is expected that this technology will be used to reduce HAP emissions from uncontrolled process vents in order to meet the final standard for existing sources

.

2.0 National Impacts

The final standard for existing process vents will require s ources to meet a standard of 0.95 kg HAP/Mg ( 1.9 lb of HAP/ton ) of resin produced . As discussed, three process vents will

necessitate controls in order to meet this standard , each located at one of the three Georgia

Pacific facilities . It is expected that a carbon adsorber will be used to meet the standard for existing sources, which is capable of achieving a HAP reduction of at least 95 percent. Based on uncontrolled levels, the three process vents will have to reduce their HAP emissions by 78

, 82,

and 86 percent in order to meet the standard

.

In order to estimate the impacts associated with the final standard, cost methodologies from EPA’s Air Pollution Control Cost Manual (CCM) were used. Also, it was assumed that the process vents would operate on a co ntinuous basis for 8,760 hours per year (hrs/yr). Costs were scaled up to 201 3 prices using the Chemical Engineering Plant Cost Index where appropriate. The control costs were estimated per facility and also as a combined cost of each option for the

entire source category (i.e., national impact)

. The methodology for estimating the capital and annual control costs of a carbon adsorber and necessary duct work was conducted a ccording to

the CCM

.

Emissions data representing total HAP emissions over a period of 5 years were received from Georgia Pacific. 1 In order to estimate the emissions reductions that would be achieved under the

final standard , the total baseline emissions for each facility were calculated by averaging the total

HAP emissions over the 5

- yr period. Additional information and assumptions used to estimate

1 Email from Paul Vasquez, Georgia Pacific to Nick Parsons, EPA. Response to EPA Additional Questions. Appendix B. June 12, 2014.3

the costs are presented in Appendix A

. To prevent repetition, the cost calculations are presented for Spray Dryer F only, but the methodology presented is the same for the other dryers.

The estimated emiss ion s reductions and capi tal and annual costs for carbon adsorbers are shown

in Table 2

. As Table 2 shows, the total national capital cost for this rule for existing APR process vents is $3. 6 million, with a total nati onal annual control cost of $ 862

, 000 per year.

Table 2. National Impacts for Existing Uncontrolled APR Continuous Process Vents

Process Vent Baseline

Emissions (tpy) Emissions

Reductions (tpy) Capital

Cost Annual

Cost Cost

Effectiveness ($/ton HAP ) Spray Dryer D 64 50 $1,224,348 $285,929 $5,700 Spray Dryer E 24 20 $1,146,777 $282,219 $14,200 Spray Dryer F 76 65 $1,248,739 $294,077 $4,500

Total 164 135 $3,619,865 $862,224 $6,400 *Minor discrepancies are due to rounding.

3 .0 Beyond

- the

- Floor

The M ACT floor was established at 0.95 kg HAP/Mg ( 1.9 lb of HAP/ton ) of resin produced and is expected to be met using a carbon adsorber at 95 percent efficiency. The beyond

- the

- floor ( BTF ) control option identified for spray dryers i n the APR source category t hat would be more stringent than the MACT floor is a thermal oxidizer that achieves a 98 percent emission

reduction. The continuous process vents for Spray Dryers A

- F we re all included in this BTF analysis. The methodology for estimating the capital and an nual control costs of a thermal oxidizer and necessary duct work was performed according to the CCM . Due to the magnitude in the process vent flowrate for the spray dryers ( 56,000 to 66,000 cubic feet per minute (ft 3 /min) )

, a regenerative thermal oxidizer (RTO) system was assumed as opposed to a recuperative thermal oxidizer (RCO), because the cost correlations range for an RTO is 10,000 to 100,000 ft 3 /min. The range for an RCO is 500 to 50,000 ft 3 /min. The estimated reductions, costs, and cost

effectivenes s associated with the BTF option is presented in Table 3.

Table 3 . Cost Effectiveness of BTF Option for APR Spray Dryers 1

Process Vent Baseline

Emissions (tpy) Emissions

Reductions (tpy) Capital

Cost Annual

Cost Cost

Effectiveness ($/ton HAP) Spray Dryers A

- C 19.8 19.4 $2.2 million $773,000/yr $40,000 Spray Dryer D 63.9 62.7 $2.2 million $784,000/yr $12,500 Spray Dryer E 24.3 23.8 $2.1 million $723,000/yr $30,000 Spray Dryer F 76 74.5 $2.3 million $822,000/yr $11,000

Total 184.0 180.5 $8.8 million $3.1 million/yr $17 ,000

1 Some discrepancies are due to rounding.4

The incremental cost effectiveness associated with requiring an RTO instead of a carbon adsorber on the spray dryers is presented in Table 4. As the table shows, the incremental cost effectiveness of requiring an RTO instead of a carbon adsorber on Spray Dryers A

- C is 800,000/ton HAP. For Spray Dryers D

- F the incremental cost effectiveness associated with using an RTO instead of a carbon adsorber ranges from approximately $40,000 to $115,000.

Table 4

. Incremental Cost Effectiveness of BTF Option for APR Spray Dryers 1

Process Vent Emissions

Reductions (tpy) Annual

Cost Incremental

Cost

Effectiveness ($/ton HAP) 2 Carbon

Adsorber RTO Carbon

Adsorber RTO

Spray Dryers A

- C 18.8 19.4 $294,000/yr $773,000/yr $800,000
Spray Dryer D 49.9 62.7 $286,000/yr $784,000/yr $39,000 Spray Dryer E 19.9 23.8 $282,000/yr $723,000/yr $114,000 Spray Dryer F 65.4 74.5 $294,000/yr $822,000/yr $58,000

Total 15 4.0 180.5 $1.2 million/yr $3.1 million/yr $74,000

1 Some discrepancies are due to rounding.

2 For Spray Dryers A

- C the incremental cost effectiveness is the $/ton of HAP reduced associated with increasing the control efficiency from 95 to 98%. For Spray Dryers D

- F it is the difference

between 78/82/86% to 98%.5 

### Appendix A

- 1
Summary of Process Vent Emission Rates6 

### Appendix A

- 2

Calculation of Carbon Adsorber Costs

– Spray Dryer F (page 1)7 

### Appendix A

- 2

Calculation of Carbon Adsorber Costs

– Spray Dryer F (page 2)8 

### Appendix A

- 2

Calculation of Carbon Adsorber Costs

– Spray Dryer F (page 3)9 

### Appendix A

- 3

Calculation of Duct Costs

– Spray Dryer F10 

### Appendix A

- 4

Calculation of Thermal Oxidizer Costs

– Spray Dryer F