p.1 

OAR Box 1490 

Prepped by Charmelle Mathews 

Document Number: 

23) IV-B-25 

Docket Number: 

A-94-52 

Printed 8/4/2008 11:51:46 AM Sheet 23 of 273 
P.2 

MEMORANDUM 

TO: Docket 94-52, Reinforced Plastic Composites NESHAP 

FROM: Keith Barnett, Environmental Protection Agency 

DATE: January 6, 2003 

SUBJECT: Criteria Pollutant and Green House Gas emissions from Capture and Control. 

Comments were received from the Composites Fabricators Association on the proposed rule 

stating that 95 percent capture and control did not represent "best control" form the Reinforced 

Plastics Composites Industry. This memo provides supporting documentation to our responses to 

these comments. 

Note that in estimating average industry impacts we have used estimates developed for the 

proposed rule for the above-the-floor control option of 95 percent control. This was done 

because the above-the-floor option provided the best indication ofthe incremental impacts of 95 

precent capture and control compared to pollution prevention. We did not calculate similar 

impacts for the final rule because the above-the-floor requirements for open molding were 

removed. Even though we did make some changes to the costing analysis between proposal and 

promulgation, the analysis here of emissions of criteria pollutants and greenhouse gases on a per 

ton of styrene controlled basis will still be accurate. 

Criteria Pollutant Emissions 

In their comments, the CFA choose Aker Plastics as the most representative facility to calculate 

criteria pollutant emissions impacts. (See attachment 1, which is taken from the CFA comments). 

Aker is the only facility in the data base with a rotary concentrator/oxidizer. However, Aker also 

has very high air flows relative to styrene emissions. In fact. Aker air flows are more that twice 

those of A.R.E. which has similar uncontrolled emissions. 

We believe that American Standard, which is also a concentrator/oxidizer system, would be a 

better example, especially considering that the capture and control requirements for open molding 

are only for new facilities. If criteria pollutant emissions from American Standard are considered, 

the emission rate is: 

(1.27+1.04+1.96+0.06Y69 = 0.63 tons of criteria pollutants generated per ton of 

styrene emissions reduction. 

At proposal, we estimated criteria pollutant emission of 38 tpy of sulfur oxides (SOx), 69 tpy of 

nitrogen oxides (NOx), 125 tpy of carbon monoxide (CO), and 1.5 tpy of particulate matter (PM) 

emissions. The incremental styrene emissions reduction resulting from add-on controls that 

created these emissions was 6117.7 tpy of HAP. Therefore, the overall ration of criteria 

pollutants to additional emissions reductions is 
P.3 

(38+69+125+1.5)/6117.7 = 0.038 tons of criteria pollutants generated per ton of 

styrene emissions reduction. 

Greenhouse Gases 

The greenhouse gas estimates were based on emission factors in the CFA comments. The 

estimates were inflated for two reasons: 

In the case studies, the HAP emission reductions were assumed to be 74 to 84 percent 

depending on the specific facility. The rule requires a 95 percent reduction. This biases 

the lb greenhouse gas number per lb of HAP reduction high. 

Comparing the air flows in some ofthe case studies with currently operating facilities, it 

appears that many ofthe air flows for Level 2 control level are higher than necessary. 

This increases natural gas use and therefore green house gas emissions. 

Looking at Exhibit 2 in attachment 1, data for thee operating facilities with add-on controls are 

shown. These are A.R.E., Aker, and American Standard. The actual greenhouse gas emission 

rates are 65.9 (for a thermal oxidizer with no concenrtator), 43.1 for Aker, and 16.9 for American 

Standard. Aker plastics has very high airflows relative to the amount of emissions. For this 

reason, we believe that American Standard would be more representative of a well designed air 

handling system for a new facility. 

Using the estimates developed at proposal, the above the floor 95 percent capture and control 

requirement results in additional emission reductions of 6117.7 tons of HAP. The incremental gas 

use was 159 million standard cubic feet per year of natural gas, and 10 million kilowatt hours of 

electricity. Using the CFA emission factors the total greenhouse gas emissions would be 

approximately 

1.23 lb C02 per CF m x 159 million = 196 million lbs/year = 97,785 tons per year. 

1.325 lb C02 per kw-hr x 10 million = 13.25 million lbs/year = 6,625 tons per year. 

Total = 104,410 tons per year (the contribution form nitrogen oxides is small compared to carbon 

dioxide) 

104,410/6118 = 17 tons of greenhouses gas per ton of additional HAP einission reduction, which 

compares closely with the number for American Standard. 

2_ 
Not included in totals. Styrene degrades into 

CO, in the air in the absence of add-on control 

exhibits 

CURRENT OXIDIZER INSTALLATIONS 

•MISSIONS AND RESOURCE USAOE 

Plant 

ARE 

Anwncsn Sid* 

AkarPtaetfca 

Exhautf 

Flow Rata 

CFM 

88.888 

27.726 

180.000 

Mat VOC 

Cone. 

ppnw 

61.8 

02.4 

38.2 

VOC 

R#wJCiion 

% 

93.0% 

88.4% 

88.0% 

VOC 

Bumed 

TPY 

226 

68 

288 

Electricity 

Uaaoa 

Kwh/yr 

2.866,667 

480,000 

3,369,600 

Natural Oaa 

Uaaoa 

MMCF 

21.33 

1.33 

16.40 

zn 

i 

^2" * «i*w 

C02 Eirlmtarm 

r Primary* 

3.38 

1Mb atyrene 

TPY 

771 

233 

974 

123 

Ib/CFgaa, 

TPY 

13,082 

818 

10,057 

S*m*w« 

1.382 

' Ibaftwhr, 

TRT 

1.736 

324 

2.276 

Narrow 

TPY 

14.818 

1,142 

12,335 

NaO Emiaatana(C02 Eojutvatanta] 

PHmerv 

71.88 

IMUMCFa 

TPY 

62 

19 

76 

71.88 

IMUMCFa 

TPY 

0.8 

0.0 

0.6 

Secondarv a 

6.70E-03 

Ihflmftr. 

TPY 

7 

1 

10 

IsM 

TPY 

70 

20 

80 

Grand 

Totals 

T/T 

14,888 65.9 

1,162 16.9 

12,423 43.1 

u Plant 

A M T PMMOCS 

Greenhous* Qasee 

T^aW l —•- «.-•... -

TPY 

12423 

T/TReduced 

43.14 

^ > 

COS primary an*laalai i factor calculated aeaurrtng al carbon la converted ta CQ2. Secondary am»wlon factor from Rrf. 18 

N20 prinwy airtaakin fader (C02 equMent) : 0.1 kg-TJ (Raf. 20) x 2 2 Ibe/kg x 1084 TJAMCFx 310 C02/NOx aouhnfanoa (Raf. 19) 

N20 aacondary errisaton factor. ((27,000 mtoneAyr Raf. 21) x 2207)/(3240E9 lovhr/yr Ref 22)) x 310 CO2/N:S.70E-03 

At ARE, only half tha VOC burnad la atyrene. Al American Standard and Akar, all VOC burned le atyrene 

Ptant 

ARE 

AS 

Akar 

NOx 

6 

TPY 

. 024 

020 

. 1.43 

Sacondarv at 

0.00446 

Ib/Kwhr 

TPY 

8.72 

1.07 

7.61 

IsM 

TPY 

14.96 

127 

' 8.94 

CO 

Prirrarv a 

20 

atack ppm. 

TFY 

22.61 

0.48 

16.96 

8aoondarv«t 

0.00231 

IbtvUu 

TPY 

2.96 

0.65 

3.89 

Total 

TPY 

25.47 

1.04 

20.65 

GQ2 

Primarv at 

0.6 

Iba/MMCF, 

TPY 

0.00640 

0.00040 

0.00492 

8fC9n*|rya} 

161.98 

Ibe/MMCF, 

TPY 

1.94 

0.12 

1.49 

0.00766 

Ibe/kwtir, 

TPY 

8.82 

1.84 

12.80 

IHM 

TPY 

11.77 

1.96 

14.39 

PM10 

Prtnwy# 

2.6 

IIVMMCF 

TPY 

0.0267 

0.0017 

0.0208 

Sacondarv at 

228E-04 

IMcM-hr 

TPY 

029 

0.05 

0.38 

JsM 

TPY 

0.32 

0.06 

0.40 

7> 

0 

v 

fa 

Plant 

Akar 

NOx 

TPY 

8J 

Crltsria Pollutant Kinlsslons 

CO 

TPY 

JOJ 

802 

TPY 

144 

PMIO 

TPY 

OA 

TOTAL 

TPY 

444 

T/T Reded 

0.16 

At Akar only, NOx and CO emtalone cefcubted mtng -Back taat coneantra<lenaof3.7ppfmNOxand72 ppnwCO. 

NOx and CO airfaalana ataawhere ara baaad upon vender-reported RTO axhau** caneantnflona far modam RTO*e property operated. Mnary 80 2 and PM10 

aritariena ara baaad upon AP^2 anteion factora fty amd gaa-firad ln ^ 

daaUIUfBtfen, aaaaun ^ 90% of 8CQ producad fa racydad 8aex*i*^ 

i*»y beEara, a^jnirtB 30% tharn^«f»d*mqf. 8aoondary «lad ^ 

dMded by 3240E9 total MAIira powar purehaaad amuafy (Raf 22) 

J**