# South Coast Air Quality Management District Planning, Rule Development & Area Sources



# Final Staff Report
SOx RECLAIM



# Part 2 Summary of Consultants’ Analyses

November 2, 2010

Deputy Executive Officer Elaine Chang, DrPH

Assistant Deputy Executive Officer Laki Tisopulos, Ph.D., P.E.

Planning and Rules Manager
Joe Cassmassi

Author Minh Pham, M.S., P.E., Air Quality Specialist

Contributor Kevin Orellana, Air Quality Specialist

Reviewers Gary Quinn, P.E., Program Supervisor Joe Cassmassi, Planning & Rule Manager Laki Tisopulos. Ph.D., P.E., Assistant DEO William Wong, Principal De puty District Counsel

### TABLE OF CONTENTS

CHAPTER 1– REQUEST FOR PROPOS ALS & CONTRACT AWARDS ......................................................... 3

1.1 R EQUEST FOR P ROPOSAL (RFP) ..................................................................................................................... 3
1.2 C ONTRACT A WARDS

.............................................................................................................................. ........ 4

CHAPTER 2 – NEXIDEA’S ANALYSIS FOR COKE CALCINER & SULFURIC ACID PLANT .................. 7

2.1 R ECOMMENDED BARCT L EVELS .................................................................................................................. 7
2.2 C ONTROL T ECHNOLOGY & C OSTS ................................................................................................................. 8
2.3 E MISSION R EDUCTIONS & C OST E FFECTIVENESS ........................................................................................ 10
2.4 P LOT S PACE

.............................................................................................................................. ................... 11
2.5 P ROJECT T IMING

.............................................................................................................................. ............ 11

CHAPTER 3 – ETS’S ANALYSIS FOR GLASS MANUFACTURING PLANT ............................................... 12

3.1 R ECOMMENDED BARCT L EVELS ................................................................................................................ 12
3.2 C ONTROL T ECHNOLOGY & C OSTS ............................................................................................................... 13
3.3 E MISSION R EDUCTIONS & C OST E FFECTIVENESS ........................................................................................ 15
3.4 P LOT S PACE

.............................................................................................................................. ................... 15
3.5 P ROJECT T IMING

.............................................................................................................................. ............ 16

CHAPTER 4 – ETS’S ANALYSIS FOR CEMENT PLANT ................................................................................ 17

4.1 R ECOMMENDED BARCT L EVELS ................................................................................................................ 17
4.2 C ONTROL T ECHNOLOGY & C OSTS ............................................................................................................... 18
4.3 E MISSION R EDUCTIONS & C OST E FFECTIVENESS ........................................................................................ 21
4.4 P LOT S PACE

.............................................................................................................................. ................... 22
4.5 P ROJECT T IMING

.............................................................................................................................. ............ 22

CHAPTER 5 – ETS/AEC’S ANALYSIS FOR FLUID CATALYTIC CRACKING UNITS ............................. 23

5.1 R ECOMMENDED BARCT L EVELS ................................................................................................................ 23
5.2 C ONTROL T ECHNOLOGY & C OSTS ............................................................................................................... 24

5.2.1 Control Tech nology ............................................................................................................ ................. 24
5.2.2 Costs ......................................................................................................................... ........................... 27
5.3 E MISSION R EDUCTIONS & C OST E FFECTIVENESS ........................................................................................ 30
14.4 P LOT S PACE

.............................................................................................................................. ................... 31
5.5 P ROJECT T IMING

.............................................................................................................................. ............ 31

CHAPTER 6 – ETS/AEC’S ANALYSIS FOR SRU/TAIL GAS SYSTEMS ....................................................... 32

6.1 R ECOMMENDED BARCT L EVELS ................................................................................................................ 32
6.2 C ONTROL T ECHNOLOGY & C OSTS ............................................................................................................... 32
6.3 E MISSION R EDUCTIONS & C OST E FFECTIVENESS ........................................................................................ 35
6.4 P LOT S PACE

.............................................................................................................................. ................... 36
6.5 P ROJECT T IMING

.............................................................................................................................. ............ 36

CHAPTER 7 – ETS/AEC’S ANALYSIS FO R REFINERY BOILERS/HEATERS ........................................... 37

7.1 R ECOMMENDED BARCT L EVELS ................................................................................................................ 37

REFERENCES – PART 2 ........................................................................................................... ............................. 38

APPENDIX A – SUMMARY OF CONSULTANTS’ RECOMMENDED CONTROL TECHNOLOGY &
COSTS ......................................................................................................................... .............................................. 39

APPENDIX B – CONSULTANTS’ BIOGRAPHIES ......................................................................................... ... 45Final Staff Report – Part 2 Chapter 1 – Request for Proposals & Contract Awards

_____________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 3 November 2, 2010 NOTE

Final Staff Report, Part 2, includes a su mmary of ETS, Inc./AEC’s analyses and NEXIDEA’s analyses in 2008-2009 time fram e. In 2010, staff contracted Norton Engineering Consultants (NEC) to review the first set of consultants’ analyses, and conducted a cost effectiveness analysis ba sed on NEC’s recommendations, which is described in Section 12.2, Chapter 12 of th e Final Staff Report, Part 1. The nonconfidential reports of ETS, Inc./AEC, NEXIDEA and NEC are available for public information and are posted on the AQMD webs ite. The biographies of the consultants Marshall Bell, Robert Kunz, John McKenna, a nd James Norton are included in Appendix B of this Final Staff Report, Part 2.



### Chapter 1– Request for Proposals & Contract Awards

1.1 Request for Proposal (RFP)

On July 11, 2008, the Governing Board approved a release of Request for Proposal (RFP) to obtain proposals from qualifie d contractors to conduct an engineering study on existing commercially viable control technologies to further reduce SOx em issions from RECLAIM
facilities to assist staff in id entifying Best Available Retrofit Control Technologies (BARCT) to be implemented within the 2011-2014 time frame wh ich would help the Basin attain the PM2.5 ambient air quality standards by the 2015 deadline. The project consisted of three (3) modules with a total budget of $375,000.00 as shown in Table 10-1: 1, 2

1. Module 1 was to seek an engineering eval uation and cost analysis assessment on SOx reducing additives used in fluid catalytic cracking units.

2. Module 2 was to seek an engineering evaluation and cost analysis assessment on SOx control technologies for refinery fu el gas and sulfur recovery /tail gas treatment units.

3. Module 3 was to seek an engineering evalua tion and cost analysis assessment on wet/dry scrubbing technologies for seven categories of equipm ent identified in Part I of this report: 1) FCCUs, 2) refinery SRU/tail gas systems, 3) refinery heaters/boilers, 4) coke calciner, 5) sulfuric acid plant, 6) container glass melti ng furnaces, and 7) cement kilns & a coal fired
boiler located at a cemen t manufacturing facility.

1 South Coast Air Quality Management District Board Meeting July 11, 2008, Agenda # 29, Report of RFPs and RFQs Scheduled for Release in July. July 11, 2008.

2 South Coast Air Quality Management District, Request for Proposal, RFP #P2009-01, Evaluation of Emission Control Technologies for Further Reducing Sulfur Oxides Emissions from Stationary Sources in the South Coast Air Quality Management District’s RECLAIM Program. July 11, 2008.Final Staff Report – Part 2 Chapter 1 – Request for Proposals & Contract Awards

_____________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 4 November 2, 2010 Table 1-1 List of Modules and Estimated Budget for SOx RECLAIM RFP Project Modules Budget
Module 1- FCCU DeSOx Additives $36 K Module 2 – Refinery SRU/Tail Ga s and Fuel Gas Systems $124 K Module 3 – Wet/Dry Scrubbers for FCCUs, SRU/Tail Gas Systems, Boilers/Heaters $133 K
Coke Calciner $14 K Sulfuric Acid Mfg Plants (w or w/o Cesium) $24 K Container Glass Melting Furnaces $14 K Cement Plant (Kilns & Coal fired boiler) $15 K Total $360 K (+ $15 K for meetings)

The contractor was asked to complete five specific tasks for each module (or submodule):

1. Identify promising existing commercially vi able SOx control tec hnologies/manufacturers;

2. Conduct field assessment and site-s pecific engineering evaluations;

3. Perform independent costs and cost effectiveness analysis;

4. Prepare reports describing the met hodology, findings and recommendations; and

5. Attend in person and give testimony at th e AQMD Governing Board hearings for the proposed amended rule as expert witness if asked by staff.

1.2 Contract Awards

After receiving approval from the AQMD Governi ng Board in July, staff released the RFP and
conducted an extensive 1-month outreach in acco rdance with the District’s Procurement Policy
and Procedure. In add ition, since this project is highly technical in nature, staff contacted eighteen (18) highly specialized contrac ting firms/contractors recommended by vendors and manufacturers of air pollution control equipmen t and the Western State Petroleum Association (WSPA). As a result of this e ffort, within a short time frame, staff received and accepted a total of six (6) technical proposals subm itted by the contractors on August 15, 2008.

A four member panel was convened to evaluate the proposals including: one AQMD Assistant Deputy Executive Officer from Planning, Rule De velopment, and Area Sources Division; one AQMD Supervisor of the Best Available Cont rol Technology team; one AQMD Supervisor of the Refinery Team; and one representative from WSPA. The evaluation process completed in August and staff drafted a proposal to present to the Board.

At the Board meeting on September 5, 2008, the G overning Board approved staff’s proposal and awarded the contracts to two consultants, ETS, Inc. and Nexidea, Inc., to conduct the study for this project at their bidding co sts shown in Table 10-2. The tota l amount of awards provided forFinal Staff Report – Part 2 Chapter 1 – Request for Proposals & Contract Awards

_____________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 5 November 2, 2010 this project was $334,860. 3, 4, 5 Note that no contract was aw arded to any of the proposals to
conduct the Module 1 evaluation.

Table 1-2 List of Contracting Firms and Awards

Project Modules Consultant Firm Awards SRU/Tail Gas & Fuel Gas Systems ETS $123,933 Wet/dry scrubbers for FCCUs, SRU /tail gas, boilers/heaters ETS $130,107 Wet/dry scrubbers for glass melting furnaces ETS $13,910 Wet/dry scrubbers for kilns & coal fired boiler ETS $13,910 Attending meetings as requested by AQMD staff ETS $7,500 Total for ETS $289,360 Wet/dry scrubbers for coke cal ciner (module 3-B) Nexidea $14,000 Wet/dry scrubbers for sulfuric acid plants Nexidea $24,000 Attending meetings as request ed by AQMD staff Nexidea $7,500 Total for Nexidea $45,500 Total $334,860
Note: Since only one refinery voluntarily participated in the short-term testing with FCCU DeSOx additives, staff decided to conduct the analysis for Module 1 in-house.

The consultants started the projects immediat ely after receiving the awards. First, the
consultants and staff scheduled and conducted site visits at BP, Chevron, ConocoPhillips, Tesoro, Valero, ExxonMobil, California Por tland Cement Corp., Owens Brockway, and Rhodia Inc. in September - October 2008. During these site visits, the consultants gathered all necessary technical information on equipmen t and operating conditions, discussed with the facilities on operational characteristics of the equipment, observ ed the physical layout of the equipment, as well as listened to any concerns or foreseen cons traints provided by the re finery technical experts related to future prospect ive add-on control devices.

After the site visits, the consultants conducted their own independent re search, contacted the control manufacturers and vendors, gathered cost information, and performed their own independent engineering analys is on commercially available control technologies and cost effectiveness. In October 2008, the consulta nts developed the draft reports which were
distributed to the affected fac ilities and AQMD staff for comments.

3 South Coast Air Quality Management District Board Meetin g September 5, 2008, Agenda # 3, Execute Contract to Evaluate Emission Control Technologies for Further Reducing Sulfur Oxides Emissions from Stationary Sources in the SCAQMD SOx RECLAIM Program. September 5, 2008.

4 South Coast Air Quality Management District, Contr act# C09104 with Nexidea, Inc., Evaluation of Emission Control Technologies for Further Reducing Sulfur Oxides Emissions from Stationary Sources in the SCAQMD’s RECLAIM Program. September 5, 2008.

5 South Coast Air Quality Management District, Contract # C09105 with ETS, Inc., Evaluation of Emission Control Technologies for Further Reducing Sulfur Oxides Emissions from Stationary Sources in the SCAQMD’s RECLAIM Program. September 5, 2008.Final Staff Report – Part 2 Chapter 1 – Request for Proposals & Contract Awards

_____________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 6 November 2, 2010 After addressing all comments received from the facilities, as well as AQMD staff, the consultants finalized their analyses and reports for coke calciner, cement kilns, coal fired boiler, glass furnaces, and sulfuric acid plant on December 16, 2008 as planned in the contracts.

Because of the complexity associated with th e refinery systems and extensive communications
between the consultants and the re fineries, the consultants finali zed their engineering analyses for FCCUs, SRU/tail gas, and fuel gas treatment systems in Apr il 20, 2009, four months after the anticipated dates specified in the contract.

A summary of the consultants’ recommendations in these engineering studies are provided in Chapter 11 through Chapter 16.Final Staff Report – Part 2 Chapter 2 – Nexidea’s Analysis for Coke Calciner & Sulfuric Acid Plants

_____________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 7 November 2, 2010 

### Chapter 2 – Nexidea’s Analysis fo r Coke Calciner & Sulfuric Acid
Plant

Nexidea, Inc. (Marshall Bell) 6, 7 was awarded the contract to study the control technologies for a coke calciner and two sulfuric acid plants in th e District (named as Facility A, B and C in the consultant’s reports). Nexidea Inc.’s analys is and results are summarized this chapter.

2.1 Recommended BARCT Levels

Nexidea’s final conclusions in this study are summarized below:

• It is feasible and cost effective to reduce SOx emissions to a level of 5 ppmv using wet scrubbing with caustic solution from coke calci ner and sulfuric acid plants. However, the
consultant recommended the District to se t BARCT at 10 ppmv due to process control related issues. For sulfuric acid plants, the consultant recommended a BARCT level of 0.14 lbs per ton acid, and for the coke calciner, th e consultant recomme nded a BARCT level of 0.25 lbs per ton coke. Excerpts from the consultant’s study ar e presented below:

“ The results of the study show that simple caustic treating can cost effectively reduce SO2 emissions to less than 5 ppmv for the all of the units in the study; however, the recommended BARCT level is 10 ppmv due to cont rol issues at near-zero SO2 levels. It is recommended that Facility B Acid Pl ant and Facility C Calciner add a caustic scrubber to meet the 10 ppmv SO2 level. Facility A Acid Plant already uses an SO2-
selective amine to reduce SO2 to 20 ppmv. That unit can be revamped at low cost to meet a 10 ppmv SO2 level, thus addition of a causti c treater to that unit is not recommended.

Table 1 presents a summary of the key findi ngs of this study. Recommended BARCT is 10 ppmv SO2, limited by pro cess control issues.....

Table 1: Summary of Recommendations

Equipment BARCT Level Emission
Reductions Cost Effectiveness
Facilities A
and B 0.14 lbs SOx/ton acid (10 ppmv) <0.1 tpd (A) 1.1 tpd (B) $1.4K - $5.6K

Facility C 0.25 lbs SOx/ton coke (10 ppmv) 1 tpd $2.5K - $5.0K ”

6 A biography of Mr. Marshall Bell is attach ed in Appendix II-B of this report.

7 SOx RECLAIM Final Report – Wet/Dry Scrubbing Technolo gy for Sulfuric Acid Plants and Coke Calciner, Nexidea Inc., December 2008.Final Staff Report - Part 2 Chapter 2 – Nexidea’s An alysis for Coke Calciner & Sulfuric Acid Plants

_____________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 8 November 2, 2010 2.2 Control Technology & Costs

To arrive at the conclusions presented above, Ne xidea, Inc. conducted a li terature research on wet/dry scrubbing control technolo gy, both regenerative and non-re generative. The consultant contacted four (4) vendors identified in Part I of the Staff Report and listed below for basic sizing and cost information to achieve 5, 10, and 20 ppmv SOx.

• Cansolv Technologies, Inc.

• Monsanto Envirochem Systems (MECS)

• Belco Technologies

• Tri-Mer

As stated in Nexidea’s report:

“

All four companies were sent requests fo r basic sizing and cost information for gas treating facilities that can re duce SO2 emissions. Each was asked to supply designs to meet 5, 10 and 20 ppmv SO2 in the treated gas streams. Belco, Tri-Mer and MECS responded with proposals. Cansolv Technolog ies responded with a letter stating that their technology is not economic ally attractive as a polishi ng unit, and they will not bid on Facility B or coke calciner. They will s upport the necessary upgrad es to Facility A’s
Cansolv Unit to allow it to meet a 10-ppmv SO2 level .”

All four vendors responded that they could ach ieve 5 ppmv SOx if all process variables are carefully controlled and monito red. Three out of four vendor s provided sizing and cost information to achieve 5 ppmv SOx. All four vendors indicated that they could easily treat the existing gas streams from the sulfuric acid plan ts and the coke calciner to 10 ppmv, and all four vendors provided sizing and cost data for this scenario:

“Both Sulfuric Acid Plants and the Coke Calcin er start with relatively low levels of SO2 in the current discharge streams: 20 to 145 ppmv. Treating down to 10 ppmv SO2 is easy and straightforward with caustic treati ng. Belco, Tri-Mer and MECS all state that they can provide designs that will achieve SO2 levels down to 1-2 ppmv with caustic treating for Facilities B and C. Cansolv c an achieve 10 ppmv SO2 with minor upgrades to the Facility A Acid Plant, and believe that 5 ppmv is possible if all process variables are carefully controlled.”

Accurate process control at all load change s is critical to achieve 5 ppmv SOx outlet concentration. The consultant recommended 10 pp mv as BARCT to provide the operators some room to respond to plant load ch anges and to reduce possible scali ng of the absorber unit, usage of caustic, and load to the effluent treatment plant:

“The recommended treatment level is 10 ppmv for all three facilities. The reason for this slightly higher value is that treating to 5 ppmv is essentially treating to zero. At this extremely low level, control over caustic injection becomes difficult. Refer to Figure 1,
which shows caustic addition versus SO2 in the treated gas. Note that the caustic injection rate is given in gallons per hour. A very small change in caustic addition rateFinal Staff Report - Part 2 Chapter 2 – Nexidea’s An alysis for Coke Calciner & Sulfuric Acid Plants

_____________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 9 November 2, 2010 has a large impact on SO2 level. Even if the caustic is di luted to 20%, the injection rate is still very small, and normal load changes in the units can make constant control difficult. Belco warns that c ontrol at <5 ppmv requires an increase in the pH of the caustic solution. As the pH rises, the tenden cy towards scaling the absorber tower and its internals increases, and the composition of makeup water to the unit must be carefully watched. If the pH is raised too high, it is possible to start absorbing CO2, which can produce a hard, insoluble sodium carbonate scale in the tower. Control at <5 ppmv almost certainly will result in over-injection of caustic, which is both wasteful and adds to the treating load in the effluent treatment plant. Control at 10 ppm v gives the operator more control room to respond to plant load changes without undue a ttention to the unit.”

BELCO and Tri-Mer provided the consultant the inside battery limit (ISBL) equipment costs for caustic scrubbers, whereas MECS supplied the total installed equipment (TIC) for caustic
scrubber. It should be noted that the costs for th e caustic scrubbers were the same regardless of the SOx desired outlet concentrations (5, 10 or 20 ppmv). Cansolv supported the revamping costs of existing control at Facili ty A estimated by the contractor.

The estimated installed equipment costs provided in the consultant report were listed in the table below included 1) a 20% location factor increa se to account for the difference in labor costs
between the U.S. Gulf Coast and the Los Angeles area; and 2) a 35% contingency factor increase to account for other outside battery limit costs that might be needed for the project (e.g. utility upgrade and upgrade for effluent treating system.) added to the base costs.

“ Table 1: Estimated In stalled Equipment Costs

Facility A Facility B Facility C

B elco $3,090,131 $6,579,231 $13,302,633 Trimer $2,999,249 $13,316,664 $21,059,914 MECS $4,043,137 $7,497,015 $16,826,926 Cansolv $500,000

The vendors provided the consultant the following information to estimate the operating costs of the equipment:

• Electric power, kilo-watt

• Makeup water, gallons per minute

• Caustic solution (50% gr ade), gallons per hour

• Waste water treating, gallons per hour

• Operating/Maintenance man-power, # of people

The major differences in the operating costs for the three desired outlet SOx concentrations 5, 10, 20 ppmv were simply the costs of more caustic solution and increased effluent to the waste

water treatment.Final Staff Report - Part 2 Chapter 2 – Nexidea’s An alysis for Coke Calciner & Sulfuric Acid Plants

_____________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 10 November 2, 2010 2.3 Emission Reductions & Cost Effectiveness

The estimated emission reductions from the 2005 actual reported emissions 8 to the feasible levels (5, 10, and 20 ppmv) were presented in the tabl e below from the consultant’s final report:

“ Table 3: Estimated Emissions Reductions
TPD SO2
Reduction Facility A @ 5 ppmv 0.050 Facility A @ 10 ppmv 0.033 Facility A @ 20 ppmv NA

Facility B @ 5 ppmv 1.192 Facility B @ 10 ppmv 1.149 Facility B @ 20 ppmv 1.064

Facility C @ 5 ppmv 1.122 Facility C @ 10 ppmv 0.997 Facility C @ 20 ppmv NA”

The consultant estimated the following cost effectiveness numbers assuming a 25-year life of caustic scrubbers, 4% interest ra te, and using a cost effectivene ss equation provided by staff:

“ Table 2: Cost Effectiveness
Cansolv Tri-Mer Belco MECS Facility A @ 5 ppmv NA $16,682 $17,596 $18,675 Facility A @ 10 ppmv $5,556 $24,906 $26,273 $27,892 Facility A @ 20 ppmv NA NA NA NA

Facility B @ 5 ppmv NA $2,158 $1,594 $1,458 Facility B @ 10 ppmv NA $2,229 $1,644 $1,503 Facility B @ 20 ppmv NA $2,388 $1,77 $1,605

Facility C @ 5 ppmv NA $3,375 $2,469 $2,624 Facility C @ 10 ppmv NA $3,768 $2,749 $2,923 Facility C @ 20 ppmv NA $4,946 $3,589 $3,821

8 The consultant indicated in his report that the following existing average SOx concentrations were provided which
the consultant later used in his estimated emission reductions: “Facility A Acid Plant: 20 ppmv SOs Facility B Acid Plant: 145 ppmv SO2 Facility C Coke Calciner: 50 ppmv SO2 .....the potential reduction in SO2 fr om Facility C based on the 50 ppmv level is higher than reported... suggests that ...this study may overstate th e potential emission reduction from Facility C.”
The consultant indicated that the current levels reported to the District “..... are in the 20 - 30 ppmv range ”.Final Staff Report - Part 2 Chapter 2 – Nexidea’s An alysis for Coke Calciner & Sulfuric Acid Plants

_____________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 11 November 2, 2010 2.4 Plot Space

The spaces for caustic scrubbers and associated equipment (e.g. ID fan) provided by the vendors and estimated by the consultant were summarized below:

Facility A Facility B Facility C
BELCO 15 ft L x 20 ft W 20 ft L x 25 ft W 30 ft L x 40 ft W
Tri-Mer 18 ft L x 18 ft W 46 ft L x 28 ft W 70 ft L x 52 ft W
MECS 20 ft L x 20 ft W 25 ft L x 25 ft W 30 ft L x 30 ft W Cansolv No additional change in plot space Not available Not available

For Facility A, the consultant concluded that:

“ If the Cansolv Unit is revamped to meet a 10 ppmv treated gas SO2 concentration, the existing equipment will be reused in its curre nt location and current plot space will be sufficient. If a caustic polishing system were to be required, the new unit would have to be located some distance away from the Acid Plant. This would ma ke ducting of the gas steam very difficult, and result in a much larger ID fan, as well as a higher capital cost. ”

For Facility B, the consultant concluded that:

“ There appears to be sufficient plot s pace ..... to accommodate all three designs

. ”

For Facility C, the consultant concluded that:

“In all three designs, it appears that some exi sting equipment will have to be relocated to make room for a new scrubber system....... Ther e appears to be suffic ient plot space on the south and west sides of the cooling tower .... to accommodate the Belco and MECS designs, which use a single tower; however, space to locate the proposed Tri-Mer design is questionable.”

In addition, the consultant prov ided several suggesti ons to reduce the foot print of the Tri-Mer
scrubber should that becomes the choice for th e facilities.

2.5 Project Timing

The consultant estimated that the total project tim e needed to install the new caustic scrubbers at Facility B and Facility C was about 24 – 30 calendar months, and to revamp the existing control system at Facility A was about 12 months.Final Staff Report – Part 2 Chap ter 3 – ETS’s Analysis for Glass Manufacturing Plant

_____________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 12 November 2, 2010 

### Chapter 3 – ETS’s Analysis for Glass Manufacturing Plant

ETS, Inc. (John McKenna) 9, 10 was awarded the contract to st udy the control technologies for two container glass melting furnaces located at a container glass manufacturing facility in the District. ETS Inc.’s analysis and resu lts are summarized in this chapter.

3.1 Recommended BARCT Levels

ETS, Inc.’s final conclusion in th is study is that it is feasible and cost effective to reduce SOx emissions to a level of 5 ppmv or less using we t scrubbing with caustic solution for container glass melting furnaces. The consultant reco mmended the District to set BARCT at 0.0058 lbs/ton glass pulled (or 99% control.)

Excerpts from ETS Inc.’s study are presented below:

“ ETS has conducted a top down analysis of a lternative commercially feasible control technologies for the control of SO
x emissions from the glass plant. This analysis considered the technology which was found to be the most effective in terms of sulfur dioxide removal and which can potentially be installed or retrofit ted at O-I. Four vendors (Manufacturer A, Manufacturer B, Manufacturer C, and Manufacturer D) submitted quotes and performance claims and one vendor (Manufacturer E) submitted a description of suggested pr ocess improvements on the exi sting system with a rough budgetary equipment cost. Given the higher removal efficiency (99%), the Manufacturer A wet scrubber was selected as BARCT for the glass furnaces.

A cost-effectiveness determi nation was executed for the BARCT case and a summary of the results is provided in the following table:

Summary of Recommendations

Equipment BARCT Level BARCT
Emission Level Emission
Reductions CostEffectiveness
OwensBrockway A, B

& C CEMS 99% control ( ≤ 1 ppmv) 0.0058 lbs/ton glass pulled 0.19 tpd $ 5.0 K/ton SOx

Note: Baseline SO

x emissions used in calculations were from 2005 (SCAQMD database for the period from January 2005 – December 2005) ”

9 ETS, Inc. team in this project included Dr. John McKe nna, John Mycock, Dr. James Tu rner, Christina Clark and Jeff Smith. (AEC Engineering Inc. was a subcontractor for ETS, Inc. in the refinery study discussed in Chapter 14 – Chapter 16. AEC Engineering Inc. was not subcontracted for the analyses for glass in Chapter 12 and cement in Chapter 13.) The consultants’ biogr aphies are included in Appendix II-B of this report.

10 SOx RECLAIM Study - Final Report – Module 3-D: Wet/Dry Scrubbing Technology for Container Glass Manufacturing Plant, ETS, Inc., December 16, 2008.Final Staff Report – Part 2 Chapter 3 – ETS’s Analysis for Glass Manufacturing Plant

_____________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 13 November 2, 2010 3.2 Control Technology & Costs

To arrive at the conclusions pr esented above, ETS Inc. conducted a literature re search on wet scrubbing (non-regenerative) and dr y scrubbing control technologies . Sources for their literature research included Air Waste Management A ssociation (AWMA), McIlvaine, U.S. EPA, Industrial Clean Air Companies (ICAC), Glass Manufacturing Industry C ouncil, and the Council of Industrial Boilers Association (CIBA). ETS In c. contacted seventeen ( 17) vendors in the field of wet/dry gas scrubbing. The following five (5) vendors responded to their request for
information:

• Tri-Mer

• Monsanto Envirochem Systems (MECS)

• McGill Clean Air Technologies

• Dustex

• PPC, Industries

As stated in the ETS Inc.’s report:

“ These vendors were contacted and supplied with a request for a technical response to
the RFP shown in Table 6

. The vendors were asked to provide a Budgetary Equipment Cost and Estimated Annual Operating Cost at the following three leve ls of performance:

1) Lowest achievable level of efficiency with guarantee 2) Next lowest achievable level of efficiency with guarantee 3) Most comfortable achievabl e efficiency with guarantee...”

“Four vendors (Manufacturer A, Manufacturer B, Manufacturer C, and Manufacturer D) submitted quotes and performance claims, and one vendor (Manufacturer E) submitted a description of suggested pr ocess improvements on the exi sting system with a rough budgetary equipment cost .......”

Control Technology Effic iency SOx Outlet Conc. Manufacturer A wet scrubber with 50% NaOH 99% Less than 5 ppmv Manufacturer B wet scrubber with 25% NaOH 95% 5 ppmv Manufacturer C dry gas scrubber 90% 10 ppmv Manufacturer D wet scrubber with 20% NaOH 90% Less than 10 ppmv

After carefully reviewing the information collecte d from the literature research and submitted by the vendors, ETS Inc. concluded:

“ Given the higher removal ef ficiency (99%), the Manufacturer A Wet Scrubber was selected as BARCT for the glass furnaces...”

Regarding vendors’ cost estim ates, ETS Inc. indicated:Final Staff Report – Part 2 Chapter 3 – ETS’s Analysis for Glass Manufacturing Plant

_____________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 14 November 2, 2010 “.....they were asked to provide a budgetary cost estimate for the supply and installation of their equipment. The vendor was also reque sted to identify any utilities needed and their expected rate of usage. The vendor was also asked to identify the amount and type of waste generated by the process. If the vendor’s approach was to modify or retrofit existing hardware, he was requested to suppl y a cost estimate for those activities. For example, if the proposed approach was that of dry or wet injection upstream of the baghouse, the proposal should have included an estimate for all required equipment hardware, reagent storage vessels, reagent fe ed control instrument ation, engineering, construction and installation, etc., as well as pr e-engineering costs such as site testing activities to locate the reagent injection site to optimize system performance with respect
to SO 2 control and reagent utilization. ”

The basis for equipment costs was different from each vendor (e.g. two vendors provided total installation costs including frei ght, and the other two provided just equipment costs without installation costs and freight. ) The consultants applied their engineering knowledge and judgment to reconcile all vendors’ costs to the sa me basis. In addition, the consultants included specific costs to cover areas that had been identified by the subject facility in the District (e.g.
costs were added to cover a dditional treatment of the waste stream from the scrubber & additional ducting to the space av ailable at the facility.)

ETS Inc. included the following cate gories in estimating the capital cost:

“ Demolition and Decommissioning
Civil/Concrete
Structural Equipment Piping & Mechanical
Electrical & Controls
Misc. Direct & Indirect Costs:
Contractor overhead and misc. rentals Contractor field supervision Mobilization/Demobilization Overtime/productiv ity factor Freight/shipping
Sales Tax Commissioning and operating spares Start-up/initial fill material On-site training/star t-up assistance FEED engineering through detailed design Project management”

ETS, Inc. included the following categories in es timating the annual operating and maintenance

costs:

“ Annual Maintenance Costs
Periodic Maintenance Costs Additional Operating Costs
Utilities:Final Staff Report – Part 2 Chapter 3 – ETS’s Analysis for Glass Manufacturing Plant

_____________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 15 November 2, 2010 Natural Gas Electricity
Water
Wastewater Cooling Water Compressed Air Solid Waste Disposal ”

3.3 Emission Reductions & Cost Effectiveness

A summary of emission reductions, co st estimates, and cost effectiv eness using 25-year life for a wet gas scrubber and 4% inte rest rate estimated by ETS, Inc. is shown below:

“ 2005 Baseline Emissions 0.195 tpd
Emission Reductions 0.19 t pd (99% efficiency) Equipment Costs $1.10 million Capital Costs $1.90 million Annual Operating Costs $0.44 million Present Worth Value (25-year life) $8.80 million Cost Effectiveness Factor $4,988 per ton SOx reduced ”

ETS, Inc. did not estimate emission reductions and co st effectiveness associat ed with other levels of control (95%, 90%). ETS , Inc. indicated that:

“In considering a curve of cost-effectiven ess versus level of control there are two considerations. Firstly, will the control device capital cost vary with improved efficiency and secondly, will the operating cost increase with increasing efficiency. Since the capital cost is driven largely by the gas volume and since the volume is essentially constant there is little if any change in the capital cost over the considered range of efficiencies. With respect to operating cost versus efficiency, in the case of sodium hydroxide, while the utilization does increase with increasing efficiency, the cost of the sodium hydroxide was low enough to minimize the im pact of efficiency on cost. Thus the merit of plotting a curve of cost versu s efficiency seemed of little value.”

3.4 Plot Space

Two vendors provided overall footprint (below) and two provided dimensions for individual components of the control systems. Manufacturer A estimated a footprint of 32 ft L x 10 ft W, and Manufacturer D estimated a footprint of 20 ft L x 20 ft W. In the analysis for available space, the consultant indicated that:

“ The plant has limited space available for add itional equipment, approximately a 14’ x 20’ footprint between two existing scrubbers. In addition O-I personnel indicated that the height of any new equipment could not exc eed 30 feet above the top of the existing scrubbing vessels. A request was made of O-I to provide us with dimensional information pertaining to available space for the Manufacture r A equipment footprint. They stated thatFinal Staff Report – Part 2 Chapter 3 – ETS’s Analysis for Glass Manufacturing Plant

_____________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 16 November 2, 2010 there is space available. Ho rizontal distance is 63’ depend ing on the location of the ducting out of the pieces of equipment. This does not take into account the vertical distance which will depend on location of entry to the stream. ”

3.5 Project Timing

The consultant estimated that startup of the c ontrol equipment could occur 12 months after the project begins.Final Staff Report – Part 2 Chapter 4 – ETS’s Analysis for Cement Plant

_____________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 17 November 2, 2010 

### Chapter 4 – ETS’s Analysis for Cement Plant

ETS, Inc. (John McKenna) 11, 12 was awarded the contract to st udy the control technologies for
two cement kilns and a coal-fired boiler located at California Po rtland Cement Co. (CPCC). ETS Inc.’s analysis and results are summarized in this chapter.

4.1 Recommended BARCT Levels

ETS, Inc.’s final conclusion in th is study is that it is feasible and cost effective to reduce SOx emissions to a level of 5 ppmv or less using wet scrubbing with caustic solution for two cement
kilns and a coal-fired boiler. The consultant recommended the District to set BARCT at 0.03 lbs/ton clinker (or 95% control efficiency) for th e two cement kilns, and 95% control efficiency
for the coal fired boiler.

Excerpts from ETS Inc.’s study are presented below:

“ ETS has conducted a top down analysis of a lternative commerciall y feasible control technologies for the control of SO
x emissions from the cement plant. This analysis considered the technology which was found to be the most effective in terms of sulfur dioxide removal and which can potentially be instal led or retrofitted at CPCC. In the case of the two kilns, three vendors (Manufacturer A, Manufacturer B, and Manufacturer C) submitted quotes and performance claims. Give n the higher removal efficiency (95%), the Manufacturer B CaCO 3 Scrubber was selected as BARCT for the kilns.

Similarly top down analysis wa s done for the coal-fired flu idized bed boiler emission control at the cement plant. Four vendors (Manufacturer A, Manufacturer B, Manufacturer C, and Manufacturer D) submitte d quotes and performance claims. Given the 95% removal efficiency, both the Manufacturer D Ventur i Reactor & the Manufacturer
B CaCO 3 Scrubber can be considered BARCT for the coal-fired fluid ized bed boiler.

Cost-effectiveness determinations were executed for the BARCT cases and a summary of the results are provided in the following table.

11 ETS, Inc. team in this project included Dr. John McKenn a, John Mycock, Dr. James Turner, Christina Clark and Jeff Smith. (AEC Engineering Inc. was a subcontractor for ETS, Inc. in the refinery study discussed in Chapter 14 – Chapter 16. AEC Engineering Inc. was not subcontracted for the analyses for glass in Chapter 12 and cement in Chapter 13.)

12 SOx RECLAIM Study - Final Report – Module 3-E: Wet/Dry Scrubbing Technology for Cement Kilns and CoalFired Fluidized Bed Boiler, ETS, Inc., December 16, 2008.Final Staff Report – Part 2 Chapter 4 – ETS’s Analysis for Cement Plant

_____________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 18 November 2, 2010 Summary of Recommendations

Equipment BARCT Level BARCT Emission Level Emission
Reductions Cost Effectiveness
Kilns 95% control ( ≤ 2 ppmv) 0.03 lbs SO

x /ton clinker 0.25 tpd SO

x $18.9 K/ton SOx

Coal-Fired
Boiler 95% control ( ≤ 5 ppmv) --- 0.36 tpd SO

x $ 3.8 K/ton SOx

Note: Baseline SO

x emissions used in calculations were from 2005 (SCAQMD database for the period from January 2005 – December 2005) ”

4.2 Control Technology & Costs

To arrive at the conclusions presented above , ETS Inc. conducted an independent literature research on wet scrubbing (non-re generative) and dry scrubbing c ontrol technologies. Sources
for their literature research included Air Wa ste Management Association (AWMA), McIlvaine Co., U.S. EPA, Industrial Clean Air Companies (ICAC), Portland Cement Association (PCA),
and Northeast States for Coordinated Air Use Management (NESCAUM). ETS, Inc. research confirmed the information provided by staff in Pa rt I of Staff Report th at scrubbing technology had been used to control SOx for existing as we ll as new cement kilns and coal fired boilers.

After the literature research, ETS Inc. contacted and asked sixteen (16) vendors in the field of wet/dry gas scrubbing to provide a budgetary equipment cost and estimated annual operating cost at the following three levels of performance:

1) Lowest achievable level of efficiency with guarantee 2) Next lowest achievable level of efficiency with guarantee, and 3) Most comfortable achievable efficiency with guarantee

For the vendors to size and estimate the costs as sociated with the control device, ETS, Inc. provided the vendors some of the followi ng critical operational parameters:

Kilns Coal-Fired Boiler Gas Flow Rate 170,000 – 200,000 acfm 60,000 acfm
Temperature 275 o F 300 o F Inlet SOx Concentration 5 ppmv – 25 ppmv 13, 14 100 ppmv 13

Combustion fuel Coal, coke, oil, nat gas, and used tires Coal Raw feed material Limestone, silica, and clay

13 ETS, Inc. reviewed several RATA tests for th e two kilns and the cogen, and in addition

, conducted a statistical analysis on the 2005 and 2008 CEMS data for the two kiln s, and the 2001 CEMS data for the cogen, and determined that a range of SOx concentrations between 5 ppmv – 25 ppmv would reflect a reasonable range of SOx concentrations from the two kilns, and approximately 100 ppmv would reflect a reasonable range of SOx concentration from the coal-fired boiler. These ranges of concentrations were provided to the vendors for quotes
and cost estimates.

14 ETS, Inc. reported that “ In general, the vendors questioned the low SO 2 levels, stating that 200-400 ppm was more typical of long dry kiln operations . Several also indicated that before guaranteeing performance level, they would require pilot testing to confirm design in formation and to optimize operational parameters.”Final Staff Report – Part 2 Chapter 4 – ETS’s Analysis for Cement Plant

_____________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 19 November 2, 2010 The following four (4) vendors responded to ETS, Inc.’s request of information:

• Dustex

• BoldEco

• Monsanto Envirochem Systems (MECS)

• Solios Three vendors proposed SOx emission control, submitted quotes, and performance claims for the
cement kilns:

• The first vendor (Vendor C) proposed we t scrubbers using 20% NaOH solution to achieve 90% guaranteed c ontrol for the two kilns

• The second vendor (Vendor A) proposed a hybr id technology, a dry fluid bed scrubber (reaction tower) following by a pulse jet fabric filter, using hydrated lime (Ca(OH)2) as absorbent reagent to achieve 90% guaranteed reduction for SOx

• The third vendor (Vendor B) proposed two di fferent approaches for emission control:

─ a moving bed reactor where the gas is contacted and absorbed on a bed of limestone granules (CaCO3) to achieve 95% reduction ; and

─ a hybrid technology including a re actor and a polished fabric filter using hydrated lime (Ca(OH)2) as absorbent reag ent to achieve 85% reduction

Vendor Control Technology Control Efficiency SOx Outlet
Concentration A Hybrid (reactor/scrubber/pulse-jet filter) using Ca(OH)2 90% < 5 ppmv B Hybrid (reactor/scrubber/pulse-jet filter) using Ca(OH)2 85% < 5 ppmv B Dry scrubber/reactor using limestone CaCO3 95% < 5 ppmv C Wet scrubber using NaOH 90% < 10 ppmv

Four vendors proposed SOx emission control, submitted quotes, and performance claims for the
coal-fired boilers:

• The first vendor (Manufacturer C) propos ed wet scrubbers using NaOH solution to achieve 90% guaranteed control (<10 ppmv SOx)

• The second vendor (Vendor A) proposed a hybr id technology, a dry fluid bed scrubber (reaction tower) following by a pulse jet fabric filter, using hydrated lime (Ca(OH)2) as absorbent reagent to achieve 90% guaranteed reduction for SOx

• The third vendor (Vendor B) proposed two di fferent approaches for emission control:

─ a moving bed reactor where the gas is contacted and absorbed on a bed of limestone granules (CaCO3) to achieve 95% reduction ; and

─ a hybrid technology including a re actor and a polished fabric filter using hydrated lime (Ca(OH)2) as absorbent reag ent to achieve 80% reductionFinal Staff Report – Part 2 Chapter 4 – ETS’s Analysis for Cement Plant

_____________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 20 November 2, 2010 • The fourth vendor (Vendor D) proposed a dry in jection system utiliz ing a venturi reactor and sodium bicarbonate (NaHCO3) to achieve 95% removal efficiency

.

Vendor Control Technology Control Efficiency SOx Outlet
Concentration A Hybrid (reactor/scrubber/pulse-jet filter) using Ca(OH)2 90% < 5 ppmv B Hybrid (reactor/scrubber/pulse-jet filter) using Ca(OH)2 80% < 5 ppmv B Dry scrubber/reactor using limestone CaCO3 95% < 5 ppmv C Wet scrubber using NaOH 90% < 10 ppmv D Venturi reactor using NaHCO3 95% < 5ppmv

After carefully reviewing all the information coll ected from the literature research and submitted by the vendors, ETS Inc. concluded:

“Given the higher removal efficiency (95%), the Manuf acturer B Dry Scrubber was selected as BARCT for the kilns.”

“Given the 95% removal efficiency, both the Manufacturer D Venturi Reactor & the Manufacturer B Scrubber can be considered BARCT for the coal-fired fluidized bed
boiler.”

Regarding vendors’ cost estim ates, ETS Inc. indicated:

“.....they were asked to provide a budgetary cost estimate for the supply and installation of their equipment. The vendor was also reque sted to identify any utilities needed and their expected rate of usage. The vendor was also asked to identify the amount and type of waste generated by the process. If the vendor’s approach was to modify or retrofit existing hardware, he was requested to suppl y a cost estimate for those activities. For example, if the proposed approach was that of dry or wet injection upstream of the baghouse, the proposal should have included an estimate for all required equipment hardware, reagent storage vessels, reagent fe ed control instrument ation, engineering, construction and installation, etc., as well as pr e-engineering costs such as site testing activities to locate the reagent injection site to optimize system performance with respect
to SO 2 control and reagent utilization. ”

The basis for equipment costs was different from each vendor. ETS, Inc. applied their engineering knowledge and judgment to reconcil e all vendors’ costs to the same basis. Regarding the capital costs, ETS Inc. included the following categories in estimating the costs:

“ Demolition and Decommissioning
Civil/Concrete
Structural Equipment Piping & Mechanical
Electrical & Controls
Misc. Direct & Indirect Costs:
Contractor overhead and misc. rentalsFinal Staff Report – Part 2 Chapter 4 – ETS’s Analysis for Cement Plant

_____________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 21 November 2, 2010 Contractor field supervision Mobilization/Demobilization Overtime/productiv ity factor Freight/shipping
Sales Tax Commissioning and operating spares Start-up/initial fill material On-site training/star t-up assistance FEED engineering through detailed design Project management”

ETS, Inc. included the following categories in es timating the annual operating and maintenance

costs:

“ Annual Maintenance Costs
Periodic Maintenance Costs Additional Operating Costs
Utilities:
Natural Gas Electricity
Water
Wastewater Cooling Water Compressed Air Solid Waste Disposal ”

A list of assumptions used by ETS, Inc. for co st estimation was summarized by ETS, Inc. in Table 11 of the final report.

4.3 Emission Reductions & Cost Effectiveness

A summary of emission reductions, co st estimates, and cost effectiv eness using 25-year life for a wet gas scrubber and 4% inte rest rate estimated by ETS, Inc. is shown below:

Two Scrubbers for Two Kilns One Scrubber for a
Coal-Fired Boiler 2005 Baseline Emissions tpd 0.27 0.38(if operated) Emission Reductions tpd 0.25 0.36(if operated) Equipment Costs $ million 16.6 4.7 Capital Costs $ million 19.6 6.1 Annual Operating Costs $ million 1.5 0.39 Present Worth Value (25-year life) $ million 43.7 12.6 Cost Effectiveness Factor $ per ton 18,893 3,818

ETS, Inc. did not estimate emission reductions and co st effectiveness associat ed with other levels of control (90% or 80%). ETS, Inc. indicated that:Final Staff Report – Part 2 Chapter 4 – ETS’s Analysis for Cement Plant

_____________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 22 November 2, 2010 “In considering a curve of cost-effectiven ess versus level of control there are two considerations. Firstly, will the control device capital cost vary with improved efficiency and secondly, will the operating cost increase with increasing efficiency. Since the capital cost is driven largely by the gas volume and since the volume is essentially constant there is little if any change in the capital cost over the considered range of efficiencies. With respect to operating cost versus efficiency, in the case of limestone, while the utilization does increase with incr easing efficiency, the cost of the limestone was low enough to minimize the impact of effi ciency on cost. Thus th e merit of plotting a curve of cost versus efficien cy seemed of little value.”

4.4 Plot Space

The plot space needed for each hybrid dry limest one scrubber located upstream of the existing baghouse of the Portland cement kiln was estimated to be approximately 50 ft L x 40 ft W. ETS, Inc. conclusion on plot space av ailability was as follow:

“ With the exception of moving some existing co al piles, there appears to be no limitation on available space for prospect ive equipment for additional SO 2 control on the two cement kilns. If necessary, the existing baghouses could be consid ered for technology approaches (such as spray drying) requiring a fi lter collector after th e reaction vessel. In this scenario the baghouse would serve the dual purpose of particu late control and the dust cake (on the bags) would provide an additional site for the reaction of the reagent
with the SO
x .”

The plot space needed for the dry scrubber loca ted upstream of the existing baghouse of the
COGEN coal fired boiler was estimated to be approximately 10 ft L x 10 ft W. ETS, Inc. conclusion on plot space av ailability was as follow:

“...... there appears to be no limited space fo r prospective equipment for additional SO 2 removal on the COGEN. In addition, if the phy sical integrity of the existing pulse jet baghouse is sound, it could probably be utilized in conjunction w ith some of the dry or semi-dry scrubbing technologies. This c ould be accomplished by replacing any malfunctioning components such as valves, timers, dampers, etc., and replacing the existing bag set with high efficiency PTFE membrane bags .”

4.5 Project Timing

The consultant estimated that startup of the c ontrol equipment could occur 24 months after the project begins for both the cement kilns as well as the coal fired boiler.Final Staff Report – Part 2 Chapter 5 – ETS/AEC’s Analysis for Fluid Catalytic Cracking Units

_____________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 23 November 2, 2010 

### Chapter 5 – ETS/AEC’s Analysis for Fluid Catalytic Cracking Units

ETS, Inc. (John McKenna) 15,16 was awarded the contract to study the control technologies (wet/dry scrubbers) for FCCUs located at six refineries in the District. ETS , Inc. subcontracted a part of the study to AEC Engineering Inc. 17 The ETS/AEC’s analysis and results for FCCUs are summarized in this chapter.

5.1 Recommended BARCT Levels

ETS, Inc.’s final conclusion in th is study is that it is feasible and cost effective to reduce SOx emissions to a level of 5 ppmv or less using wet scrubbing with ca ustic solution for six refineries
in the District. ETS’s recommended the District to set BARCT at 5 ppmv, approximately 2.32 lbs/thousand barrels feed, or 87% co ntrol, averaging across six FCCUs in the District. ETS
Inc. estimated total emission reductions from the 2005 baseline were 3.07 t pd at an average cost effectiveness of $24.6 K per ton SOx reduced. 18,19

Excerpts from ETS Inc.’s study are presented below:

“The final estimates of SOx reductions for the Module 3A BARCT-designated measures are

tabulated below:

Module 3A Forecasted SOx Reduc tions (tons/day) by Refinery Refinery: 1 2 3 4 5 6 Total Equipment Type FCCU 0.58 0.19 0.28 0.20 0.87 0.94 3.07

The following table gives a summary of the Modu le 3A cost effectiveness ratios by refinery following implementation of the respec tive measures selected by ETS/AEC: Module 3A Cost Effectiveness ($/ton of SOx) by Refinery Refinery: 1 2 3 4 5 6 Avg. for All Equipment Type FCCU $14.4k $76.2k $36.6k $42.1k $11.6k $12.8k $24.6k

15 ETS, Inc. team in this project included John McKenna, Ph.D., Robert Kunz, Ph.D., P.E., James Turner, Ph.D., Christina Clark and Jeff Smith. The consultants’ biographi es are attached in Appendix II-B of this report.

16 SOx RECLAIM Study - Final Report – Module 3-A: Wet/Dry Scrubbing Technology for Refinery Fluid Catalytic Cracking Units (FCCUs), Refinery Boilers/Heaters, and Refinery Sulfur Recovery Units (SRUs) and Tail Gas Treatment Processes, AEC Engineering Inc./ETS, Inc., April 20, 2009.

17 AEC Engineering, Inc. team in this project included Ta v Heistand, P.E., Kristie Williams, P.E., Jason Sowards, Jesse Pikturna, Ph.D., and Britton Miller, P.E.

18 The estimated emission reductions 3.07 tpd were the reductions calculated from the 2005 baseline described in Part 1 of the Staff Report for all six FCCUs in the District. Note that this 3.07 tpd estimated reductions from
ETS/AEC was not the same as the RTC reducti ons estimated in Staff Report for FCCUs.

19 The cost effectiveness of $24.6 K is an average for five refineries. One refi nery in the District already installed and has operated a wet gas scrubber to meet the particulate emission standards in Rule 1105.1, and this gas scrubber also meet the limeit of 5 ppmv proposed by ETS/AEC.Final Staff Report – Part 2 Chapter 5 – ETS/AEC’ s Analysis for Fluid Catalytic Cracking Units

_____________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 24 November 2, 2010 5.2 Control Technology & Costs

5.2.1 Control Technology

‘ To arrive at the conclusions presented above, ETS Inc. and AEC Engineering Inc. conducted an independent literature research on wet a nd dry scrubbing technologies including nonregenerative, regenerative, and s ea water. After that, ETS/AEC contacted vendors for feasibility and cost information. As indicated by ETS/AEC:

“ Insofar as the wet and dry gas scrubbing technologies are concerned, information provided by SCAQMD was ver y helpful in identifying some of the vendors that were considered in this study. Contact was m ade with all vendors listed in the SCAQMD preliminary report and a number of vendors that were not liste d. After initial discussions with vendors, careful reviews of various re sources were conducted: literature provided by vendors; the April 2008 Pre liminary Draft Staff Report; in -house files; public domain articles and reports; and conversations with industr y experts. At that point, five different technology providers were se lected for detailed analysis of installation and operation
economics....”

The technologies and vendors that ETS/AEC concen trated for further analysis (e.g. costs) for
FCCUs were:

• BELCO (non-regenerative wet gas scrubber)

• MECS (non-regenerative wet gas scrubber)

• Hamon (dry scrubber)

• Alstom (sea water scrubber)

Regarding BELCO technology, ETS/AEC stated that:

“ BELCO (DuPont) has more than 65 EDV wet sc rubbing systems in refineries, at least 61 of which are in FCCU applications and 156 EDV 20 wet scrubbing systems in other applications. BELCO also has examples of EDV applications for SRU/TGTU and refinery boilers and heaters (DuPont Power Point Presenta tion, 2008). In a lette r sent to ETS from Nick Confuerto, Vice President, Technology , Sales & Marketing of BELCO, it was confirmed that the guaranteed SOx outlet co ncentration based on the refinery-specific information provided would be 5 ppmv. Th e EDV utilizes a Purge Treatment System to

decrease the COD 21 and suspended solid content of the effluent. A clarifier is used to collect the solids and then they ar e filter-pressed and disposed. The oxidation is facilitated

20 EDV ® is a trademark wet gas scrubber manufactured and supplied by BELCO (Dupont).

21 COD stands for Chemical Oxygen Demand, a commonly us ed measurement for water quality. It measures the capacity of water to consume oxygen during the decomposition of organic matter and the oxidation of inorganic chemicals such as ammonia and nitrite. It is an indirect measurement of the organic compounds (microorganisms) that survive in the waste water samples.Final Staff Report – Part 2 Chapter 5 – ETS/AEC’ s Analysis for Fluid Catalytic Cracking Units

_____________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 25 November 2, 2010 in a tower with air forced through the effluent to convert all sulfites to sulfates. After these two steps the effluent is safely discha rged to the waste water treatment plant. ”

Regarding MECS technology, ETS/AEC stated that:

“.... MECS developed their DynaWave technol ogy in the 1970s and has over 300 installations worldwide (Kixmiller, 2008). Sp ecific examples are two Sinclair oil refineries in Wyoming. According to a published paper titled, “DynaWave Wet Gas Scrubbing: A New Alternative for Claus Unit Tail Gas Cle an-Up”, written by Steven F. Meyer, Ed Juno, Nick Watts, and Cristina Kulczycki, each re finery installed a DynaWave scrubber for SRU/TGTU stack treatment. The results of stack testing was a 99.99% sulfur removal. The DynaWave mitigates the effluent COD by inj ecting air into the sump of the vessel in order to oxidize the sulfites. The sump is also designed to allow adequate retention time for the oxidation to take place. As a result, the effluent water can be discharged directly to the wastewater treatment plant, provided the COD levels are continuously monitored and maintained within an acceptable range. According to the paper, the COD at the Casper, WY refinery ranged between 50 and 150 mg/l .”

Regarding dry scrubbing technology provided by Hamon, ETS/AEC stated that:

“ The dry scrubbing technology eval uated in this study is Ham on’s. It was evaluated for both FCCU and heater and boiler applications. According to information on its website, Hamon FGD technologies are installed in twenty countries and treat over 65,000 MW of power generation capacity. Hamon also has a long standing relations hip with refineries

world wide with over 100 ESP installations on FCCUs. There is no example of a dry scrubber installation in a refinery. However, the level of experience in FGD and general refinery applications is adequate to describe th e technology as field demonstrated. In an email sent to AEC, a Hamon Research employee quoted a 90+% removal efficiency for streams with 300-400 ppmv SOx. Because flue gases in the South C oast refineries are typically below this range, the removal percentage is expected to be below 90% in most cases. Typically, it is governed by the SOx out let concentration, which is not forecasted to fall below 10 ppmv on a guaranteed basis. Hen ce, the removal percentage for Hamon’s dry gas scrubber is application-specific in these refineries and generally will be below 90%. One additional consideration for all type s of dry scrubbers is the issue of solids handling. The effluent gas will have considerable particulate matter that must be removed. Therefore it is necessary to install some type of an ESP or baghouse downstream from the scrubber. The solids handling equipment will need to collect both dry particulate matter from the scrubber and particulate from the FCC. This introduces additional complexity with respect to available plot space and capital expenditure. ”

After several months of technical analysis a nd couple weeks visiting th e refineries, ETS/AEC concluded that wet gas scrubbing was an aged-old technology which should be very familiar to
all six refineries in the District:Final Staff Report – Part 2 Chapter 5 – ETS/AEC’ s Analysis for Fluid Catalytic Cracking Units

_____________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 26 November 2, 2010 “One WGS vendor, Belco Technologies Corpor ation (BELCO), has provided a lengthy application list..., with contracts awarded on as many as sixty-one (61) FCCU units and two (2) fluid cokers. Total FCCU capacity treated by BELCO sc rubbers is noted as 3,228,700 bbl/day. The concept of using a WGS on an FCCU should be familiar to four (4) of the six (6) refining co mpanies operating the Los Angeles, CA area since they are listed as customers employing BELCO WGS technology on the FCCUs at their other refineries...........

Another vendor of WGS technol ogy, Exxon (Now ExxonMobil) , has also developed WGS technology. It is used in their own refiner ies and at others under license...... As of 1999, they cite a total of fourteen (1 4) such installations. One of the Exxon papers .... pictures a number of FCCU scrubbers located in tight spots because the requ ired plot space was not otherwise available, including a phot ograph of a creative solution in which the
scrubber is mounted on stilts above a road.”

Regarding vendors’ guarantee, ETS/AEC indicat ed that BELCO and MECS were willing to provide guarantee on 5 ppmv:

“BELCO has provided numerous wet gas scrubbers for FCCUs in the United States and on a worldwide basis. Based on that experie nce, BELCO has given a guarantee of 5 ppm
SO 2 from a wet scrubber if installed on any of the FCCUs in the District. MECS DynaWave, with at least three installations on FCCU regenerator flue gas, will also guarantee 5 ppmv SO 2 . BELCO has indicated that most of their units operate in the near zero ppm range, with the most recent performan ce test from one of these at a fraction of a ppm (corrected to 0% O 2 )....”

In addition, ETS/AEC cited one full-scale installation that th ey were aware of:

“.... The study team is aware of another full-scale wet gas scrubber operating on an FCCU in a petroleum refinery at an SO 2 emission level of 5 ppm v or less on a long-term
basis.”

To be conservative in their BARCT recommen dation, ETS/AEC recommended BARCT to be set at 5 ppmv. The vendors and ETS/AEC did not r ecommend lower levels just to avoid CEMS measurement uncertainty:

..... the recommended BARCT level for fluid catalytic cracking unit (FCCU) SOx emissions is 5 ppmv on a dry basis. This is derived from an achievable concentration when employing wet gas scrubbing (WGS), a pr oven technology demonstrated in practice on this type of emission source. It is believed that a lower outlet concentration is indeed possible. However, a lower concentration may not be reliably measurable because of
unavoidable accumulated error in the sour ce test reference methods and/or the permissible tolerance in continuous emission monitoring system (CEMS) measurements.”

“...After careful consideration of the vari ous scrubbing approaches and review of the technical responses and guarantee statements offered by the suppliers of theseFinal Staff Report – Part 2 Chapter 5 – ETS/AEC’ s Analysis for Fluid Catalytic Cracking Units

_____________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 27 November 2, 2010 technologies, it is the recommendation of the ETS team that non-regenerative wet scrubbing be considered on a purely technical basis as BARCT for the FCCUs, Refinery Boiler/Heaters, and SRU/TGTU processes und er study in Module 3A, with an overall BARCT level of 5 ppmv.”

5.2.2 Costs

To gather budgetary quotes from vendors on costs and sizing information, ETS/AEC provided the vendors important critical information (e.g. gas flow rate, inlet SOx concentration, flue gas temperature) for a generic scenario. ETS/AEC adjusted the vendors’ quotes information to match each refinery specific conditions. ETS/AEC claimed that their approach would ultimately generate cost information within +/- 40% range of the expected actual costs. As ETS/AEC
stated that:

“ The methodology and techniques utilized during this project in the sizing of equipment for a new application ..... are exa ctly those used in any engin eering endeavor. First, of course, we obtained a full understanding of how the existing system is configured and operates; those things are known by mean s of the site visit, underlying industry knowledge, interviews of refinery personnel, refinery-submitted data and drawings, etc. The second step was to conceptualize how th e equipment under cons ideration is to be installed. This step also includes identifying the performance parameters to be achieved. In doing so, we quantified the expected range s of service and efficiency, so that an appropriate over-design allowan ce could be applied (the purpose of which is to ensure that the performance objectives will reliabl y be met even if the underlying process is running at one extreme or another of its no rmal range). Next, all the pertinent information was communicated to the equipment representative, usually for pricing determination, but sometimes also to confirm the sizing exercise. In all cases, evaluating specific technology options required eventual coordination with the manufacturer or licensor to get verification of critical assumptions and/or conclusions.

Since the study encompassed multiple facilities and systems with widely different process flows and arrangements, and because, fu rthermore, there were several optional technologies looked at for each installati on, the total collection of potential measures was extraordinarily large. Thus, it was im possible—in the timeframe available—to address every one of the individual cases with a full set of vendor inquiries. Instead, the team made use of generic, but representa tive budgetary quotations and published cost studies for the various technologies. Each such “reference point” (i .e., package cost and performance data for a prescribed process ope rating condition) was then used as a basis for extrapolation to other locations and desi gn conditions. For a specific application, the key sizing criterion (typically the process throughput—e.g., SCFM of gas) is determined or calculated from the relevant operational data. Then, to generate the probable capital purchase cost ($PC), that criterion value (V) is divided by the comparable numerical capacity (Cr) from th e “reference point” package. Using the baseline capital cost ($BCr) for that “reference point”, the desired capital cost is mathematically calculated via a co nventional power cu rve relationship:Final Staff Report – Part 2 Chapter 5 – ETS/AEC’ s Analysis for Fluid Catalytic Cracking Units

_____________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 28 November 2, 2010 $PC = $BCr x (V/Cr) ^ n where n is an appropriate exponent between .5 and 1.0

This approach is commonly used in engineer ing studies, and has b een widely described in reference books such as Marks Standard Handbook for Mechanical Engineers and Perry’s Chemical Engineers’ Handbook . For our studies, the exponent value, n, was normally assigned a value between 0.6 and 0.7, a range that historic ally has given good estimates for industria l equipment packages.

In so far as the pertinent sizing criteria were concerned, they were compared to nameplate duties for other, si milar units for rough verifica tion purposes. Also, input was sought directly from the manufacturers’ re presentatives, as well as public domain literature and published case studies. In the end, the checking procedures employed by the team members helped us to achieve r ough, budgetary purchase costs, knowing that any loss in precision in arri ving at those costs would be adequately covered by the very broad overall cost ranges (i.e., +/- 40%) expected for the ultimate results.”

Regarding estimates for capital costs, ETS/AEC indicated that:

“

AEC worked as closely as possible with th e technology suppliers to gather the direct capital cost estimates for this project. (Where available, too, we compiled net installation costs which had been reported by the manufacturers for “reference points”, as described in the preceding section. Thos e “turn-key” costs were used to check the built-up cost estimates assembled by the projec t team.) Also, we t ook advantage of our relevant and extensive corporate knowledge base for similar projects. Every valid method was employed to give the best possi ble output. (In additi on, as mentioned in Section A, above, indirect costs for impacts to utilities and infrastructure were estimated and included.)....

... Owing to the fact that all the cost estimating tasks were conducted in a very preliminary, conceptual fashi on, the overall accuracy of the capital cost determinations is no better than +/- 40%. Considerable engi neering study would be required to refine the cost estimates and arrive at narrower accuracy ranges .”

Regarding annual operating costs, ETS/AEC explained their approach as follows:

“ Unit rates for the principal cost -incurring utilities were requested from the refineries at the outset of the study. In several cases, explic it values were provided in response to the requests; those values were used as reporte d to us. For all other instances, generic estimates—obtained from other work by AEC at various U.S. refineries—of the unit rates
were utilized...Final Staff Report – Part 2 Chapter 5 – ETS/AEC’ s Analysis for Fluid Catalytic Cracking Units

_____________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 29 November 2, 2010 ...The majority of the suggest ed control technologies or upgrades include the need not only for additional utilities but also raw materials, such as a scrubbing agent or catalyst. Costs for those items were estimated through consultation with a tech nology supplier or in-house expert. The appropriate third party resource or corporate engineer(s) based the quantity determinations on the specific charac teristics of the technology under study. Once a quantity was determined, a local mate rial cost was obtained for use in the

calculations...

...Early in the project, AEC had requested fr om the refineries the average hourly costs for various labor classifications on typical capital projects. When plant-specific values were not provided, we used ge neric labor rates that are inte nded to reflect average fullyburdened costs for jobs insi de a South Coast refinery

...The computation of chemical (such as Na OH) quantities used by the various measures, and the amounts of waste products generated by them, were very straightforward. In almost all instances, the manufacturers’ l iterature provided guidelines and/or explicit case studies. That information was used via direct “scale-up” multipliers, based on the key parameter(s) involved...”

ETS/AEC applied their engineer ing knowledge and judgment to r econcile all vendors’ costs to the same basis. Regarding the capital costs, ETS Inc. included the following categories in estimating the costs:

“ Demolition and decommissioning

Civil/concrete

Structure Equipment Piping and Mechanical

Electrical and controls

Miscellaneous indirect costs include: Contractor overhead, typically 8 % of direct field labor (DFL) Contractor field supervision, typically 12 % of DFL Mobilization/demobilization, typically 10 % of DFL Overtime/productivity factor , typically 12 % of DFL Freight and shipping, typica lly 8 %, of materials Sales tax, typically 7 % of materials Commissioning and operating spares, typically 5 % of materials Startup/initial fill material, typically 2 % of materials On-site training/startup assi stance, depends on project Front-end engineering design, depends on project size Project management, depends on project sizeFinal Staff Report – Part 2 Chapter 5 – ETS/AEC’ s Analysis for Fluid Catalytic Cracking Units

_____________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 30 November 2, 2010 Design development allowance, 10% of total Contingency, 25-40% applied against th e bottom-line capita l cost estimate ”

ETS, Inc. included the following categories in es timating the annual operating and maintenance

costs:

“ Annual Maintenance Costs
Periodic Maintenance Costs Additional Operating Costs
Utilities:
Natural Gas Electricity
Water
Wastewater Cooling Water Compressed Air Solid Waste Disposal ”

A list of assumptions used by ETS/AEC for cost estimation was summarized in Table 4-1 of the ETS/AEC’s final report for Module 3-A.

5.3 Emission Reductions & Cost Effectiveness

A summary of emission reductions, cost estimates, and cost effectiveness assuming 90% control (5ppmv), 25-year life for a wet gas scrubber, and 4% interest rate estimated by ETS/AEC is
shown below:

SOx Reductions (tons/day) for FCCUs by Refinery (5 ppmv) Refinery: 1 2 3 4 5 6 Total Equipment FCCU 0.58 0.19 0.28 0.20 0.87 0.94 3.07

Cost Effectiveness ($/ton of SOx) for FCCUs by Refinery (5 ppmv) Refinery: 1 2 3 4 5 6 Avg. for All Equipment FCCU $14.4k $76.2k $36.6k $42.1k $11.6k $12.8k $24.6k

In addition, ETS/AEC provided an estimate for the following emission reductions and cost
effectiveness associated with the most stringent, but feasible leve l of control (98%) in Table A-3 and A-4 of their final report:

SOx Reductions (tons/day) for FCCUs by Refinery (98%) Refinery: 1 2 3 4 5 6 Total Equipment FCCU 0.60 0.30 0.35 0.24 0.94 1.01 3.45

Cost Effectiveness ($/ton of SO x) for FCCUs by Refinery (98%) Refinery: 1 2 3 4 5 6 Avg. for All Equipment FCCU $14.0k $48.0k $29.5k $35.2k $10.7k $11.9k $21.5kFinal Staff Report – Part 2 Chapter 5 – ETS/AEC’ s Analysis for Fluid Catalytic Cracking Units

_____________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 31 November 2, 2010 Regarding the average cost effec tiveness, ETS/AEC indicated that:

“ One refinery has already installed a wet gas scrubber on its FCCU regenerator.... the cost effectiveness ratio for this refinery wa s not included in any of the average cost effectiveness calculations. ”

14.4 Plot Space

ETS/AEC conducted an analysis for plot space at the refineries to accommodate the wet gas scrubber and its associated equipment (e.g. addi tional fan, waste water handling system, plume mitigation system), presented their analysis in the confidential portion of the report, and concluded that space was available at all five refineries for additional control:

“ Wet gas scrubber equipment footprints and space requirements for the FCCUs and the SRU/TGTUs are shown in the confidential app endices for each refinery where measures have been selected. These specifications have been compared with the plot plans provided by the respective refineries, and wh ere applicable, are pres ented in the costing
workbooks .”

5.5 Project Timing

AEC/ETS estimated that startup of the control equipment could occur within 3 calendar years after the project begins:

“ETS believes that it is conceivable that ....emission reduction ..... can be achieved from the refineries implementing the commercially available measures described in this project within a construction time frame of approximately 3 calendar years or less following the completion of st udy designs and engineering.”Final Staff Report – Part 2 Chapter 6 – ETS/AEC’s Analysis for Sulfur Recovery Unit/Tail Gas Systems

_____________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 32 November 2, 2010 

### Chapter 6 – ETS/AEC’s Analysis for SRU/Tail Gas Systems

6.1 Recommended BARCT Levels

Through the data provided to ETS/A EC by the refineries, there was one refinery regularly vented the flue gas to the atmosphere, and the remaining refineries trea ted or incinerated the tail gas from their SRU/TG systems. Because of this distinction in the refinery’s operations, ETS

divided their recommendations for SRU/TG into two areas: the first recommendation is for the uncombusted tail gas:

“For uncombusted tail gas, the limits of Subpart J (Ja), namely 10 ppm H2S and 300 ppm reduced sulfur species (total of H2S, COS, and CS2), should con tinue to apply. Refineries should be encouraged to reduce emissions so as to be able to ven t rather than having to combust SRU / TGTU tail gas.”

The ETS’s second recommendation for the combusted tail gas is as follows:

“For combusted / incinerated tail gas, 5 ppmv SOx @ 0% O2 should be defined as the overall BARCT level for all refineries, based on scrubbed flue gas, but permissible to achieve by whatever means possible. A level of 10 ppmv would allow a greater number of refineries to meet the overall BARCT level by the gas treatment methods of Module 2 without having to install a wet gas scrubber (Module 3A)”

6.2 Control Technology & Costs

To arrive at the conclusions presented above, ETS Inc. and AEC Engineering Inc. conducted an independent literature research on wet a nd dry scrubbing technologies including nonregenerative and regenerative for Module 3A; and numerous technologies for Module 2 including expansion of Claus pro cess, sub-dewpoint process, se lective oxidation catalyst, TG-10 additives, and additional sulfur capture at the sulfur pit. After the literature search, ETS/AEC contacted vendors for feasibility and cost information.

The five technologies and vendors that ETS/AEC c oncentrated for further analysis (e.g. costs) for SRU/TG systems were:

• Lurgi (sub-dewpoint H ydroSulfreen process)

• EmeraChem Power LLC (selec tive oxidation catalyst)

• Gas Spec (TG-10 additive)

• Cansolv & BELCO (regenera tive wet gas scrubber)

• Tri-Mer (non-regenerative wet gas scrubber)

For Lurgi Hydrosulfreen process, ETS/AEC stated that:Final Staff Report – Part 2 Chapter 6 – ETS/AEC’s Analysis for Sulfur Recovery Unit/Tail Gas Systems

_____________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 33 November 2, 2010 “ The HydroSulfreen process is an improvement on Lurgi’s Sulfreen process. It adds a hydrolysis step to this process. Ther e are over 45 Sulfreen processes in operation worldwide. In August of 2000, there we re four HydroSulfreen plants licensed.

The HydroSulfreen® process is ty pically used for treatment of tail gas from refineries. The effluent from an existing Cl aus plant is first treated in a hydrolysis reactor, where species such as SOx, CS 2 , and COS are hydrolyzed to form H 2 S. The effluent from the hydrolysis reactor is typically sent to the Sulfreen® process, which operates at temperatures lower than the dew point of sulfur. Operating the converters at these temperatures increases the conversion to el emental sulfur, thereby increasing the overall efficiency of the unit. ”

ETS/AEC estimated that the costs of conversion from normal Claus unit to HydroSulfreen were high and the cost effectiveness was in a range of $37,000 - $600,000 per ton of SOx reduced. This technology was not recommended by ETS /AEC at the final selection stage.

Regarding EmeraChem Power LLC’s catalyst ox idation process, ETS/AEC stated that:

“ EmeraChem ESx catalyst can capture mu ltiple sulfur species, including SO 2 , SO 3 , and

H

2 S. In addition to sulfur capture, the cata lyst will destroy CO, VOC, and Particulate Matter (PM 10 ). These units are typically used to treat combustion exhaust gases from
incinerators, heaters, turbines and boilers.

EmeraChem does not appear to have its ESx technology installed as a stand-alone SOx control technology at any refinery......EmeraCh em has provided assurances that their technology works to reduce pollution in exhaust gases across many types of unit operations, including refinery processes, ga s turbines, boilers, process heaters, and diesel engines.”

EmeraChem platinum catalysts can be used to treat tail gas that has or has not been incinerated. The tail gas that has not been incinerated must be heated to the temperatures where the ESx catalyst is active (minimum at 600 o F). ETS/AEC estimated that the cost effectiveness for Emerachem catalysts was in a range of $10,000 - $60,000 per ton of SOx reduced.

EmeraChem provided ETS/AEC a letter specifically stated the following performance guarantee:

“ EMx System Emission Concentration:

Parameter Percent Removal NOx at Catalyst Outlet (E Mx) < 2.0 ppmvd 92% guaranteed CO at Catalyst Outlet < 3.0 ppmvd 98% guaranteed SO2 at System Outlet 3.85 ppmvd 98% guaranteed H2S at System Outlet 0 ppmvd 98% guaranteedFinal Staff Report – Part 2 Chapter 6 – ETS/AEC’s Analysis for Sulfur Recovery Unit/Tail Gas Systems

_____________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 34 November 2, 2010 The catalyst warranty period is 5 years. Ex pected life of the catalysts is 10-15 years.”

Regarding TG-10 additives, ETS/AEC stated that:

“ TG-10 can be added to tail gas treating amine systems. TG-10 is a proprietary amine mixture offered by INEOS Gas/Spec. It has been designed to be hi ghly selective for H 2 S. INEOS Gas/Spec has published data, compar ing the capabilities of TG-10 and MDEA in actual tail gas plants.......For m any reasons similar to thos e in fuel gas treating, the effectiveness ratios for TG-10 c an appear to be quite attractive. ”

ETS/AEC estimated that the cost effectiven ess for TG-10 additives was between $2,000 and $3,000 per ton of SOx reduced, however the potential of emission reductions was quite small 0.04 tpd - 0.07 tpd, and most of the refineries alr eady used TG-10 in some fashion. Therefore, this measure was not recommended by ETS /AEC at the final selection stage.

Regarding Cansolv and BELCO regenerative we t gas scrubbing technology, ETS/AEC stated
that:

“ Regenerative wet gas scrubbing was studied as a potential measure to reduce emissions from the SRU/TGTUs. Two manufacture rs were considered for RWGS: BELCO’s

Labsorb and Cansolv. Cansolv was chos en, in particular for SRU/TGTU stack treatment, because they had more experience with SRU/TG TU incinerator stack gas scrubbing.”

Regarding Tri-Mer non-regenerative wet gas scrubber, ETS/AEC stated that:

“ Non-regenerative wet gas scrubbing of the sulf ur plant tail gas was also studied (TriMer’s Cloud Chamber Technology). These un its are typically less expensive to install than a regenerative system, but they consum e large volumes of water and produce waste water. However, they are very e ffective at reducing SOx emissions.”

Tri-Mer provided ETS/AEC a guaranteed letter sp ecifically stated the inlet parameters (gas volume and temperature) provide d to Tri-Mer and the following statement of guarantee:

“With regard to the specifications provided to Tri-Mer by ETS Inc., based on the design conditions, Tri-Mer will guarantee ≤ 330 ppmv inlet SO2 to ≤ 1.

0 ppmv outlet for SO2.”

ETS/AEC indicated with confidence:

“Guaranteed outlet SOx concentrations of 5 ppmv after scrubbing c an be achieved, in the worst case at 95% SOx removal efficien cy; in most cases, the required scrubbingFinal Staff Report – Part 2 Chapter 6 – ETS/AEC’s Analysis for Sulfur Recovery Unit/Tail Gas Systems

_____________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 35 November 2, 2010 efficiency for a 5-ppmv SOx ou tlet is considerably less. BELCO has demonstrated experience in scrubbing the SOx from incine rated sulfur plant tail gas as well.

Besides wet scrubbing technology, ET S/AEC also indicated that flue gas treating techniques (e.g. EmeraChem) can possibly bring down the SOx to a level of 5 ppmv – 10 ppmv:

“.......it has been found possible in this st udy also to reduce SRU ppm SOx to the atmosphere by the gas treating techniques in vestigated. Those results are all below 10 ppmv, and in many cases below 5 ppmv”

To gather budgetary quotes from vendors on costs and sizing information, ETS/AEC provided the vendors important critical information (e.g. gas flow rate, inlet SOx concentration, flue gas temperature) for a generic scenario. ETS/AEC adjusted the vendors’ quotes information to match each refinery specific conditions. ETS/AEC claimed that their approach would ultimately generate cost information within +/- 40% range of the expected actual costs. Please refer to section 14.2 for further information on ETS/AEC’s approach.

6.3 Emission Reductions & Cost Effectiveness

For three refineries (Refiner y #1, #3 and #4), ETS/AEC recomme nded to implement the control technologies described in Module 2 report. For these three refi neries, ETS/AEC estimated the following emission reductions (estimat ed from the 2005 actual emission s) and cost effectiveness:

SOx Reductions (tons/day) for SRU/TG by Refinery Refinery: 1 3 4 Total Equipment SRU/TG 0.13 0.15 0.04 0.31

Cost Effectiveness ($/ton of SOx) for SRU/TG by Refinery Refinery: 1 3 4 Avg. for All Equipment SRU/TG $22.4k $12.9k $54.7k $21.9k

For the remaining three refineries (Ref inery #2, #5 and #6), ETS/AEC recommended to implement wet gas scrubbers described in Modul e 3A report. For these three refineries,

ETS/AEC’s recommendations for the emission reductions (estimated from the 2005 actual emissions) and cost effectiveness are as follows: SOx Reductions (tons/day) for SRU/TG by Refinery Refinery: 2 5 6 Total Equipment SRU/TG 0.17 0.06 0.29 0.52

Cost Effectiveness ($/ton of SOx) for SRU/TG by Refinery Refinery: 2 5 6 Avg. for All Equipment SRU/TG $39.0k $123.2k $36.3k $46.8kFinal Staff Report – Part 2 Chapter 6 – ETS/AEC’s Analysis for Sulfur Recovery Unit/Tail Gas Systems

_____________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 36 November 2, 2010 The overall estimates for emission reductions (e stimated from the 2005 actual emission levels) and average cost effectiveness for six SRU/TG systems are as follows:

SOx Reductions (tons/day) for SRU/TG by Refinery Refinery: 1 2 3 4 5 6 Total Equipment SRU/TG 0.13 0.17 0.15 0.04 0.06 0.29 0.83

Cost Effectiveness ($/ton of SOx) for SRU/TG by Refinery Refinery: 1 2 3 4 5 6 Avg. for All Equipment SRU/TG $22.4k $39.0k $12.9k $54.7k $123k $36.3k $37.4k

6.4 Plot Space

With plot space information estimated directly by the vendors, ETS/AEC conducted an analysis for plot space at the refineries to accommodate the wet gas scrubber and it s associated equipment (e.g. additional fan, waste water handling system, pl ume mitigation system). Their analysis was included in the confidential portion of the repor ts. ETS/AEC concluded that space was available at all refineries for this type of control:

“ Wet gas scrubber equipment footprints and space requirements for the FCCUs and the SRU/TGTUs are shown in the confidential app endices for each refinery where measures have been selected. These specifications have been compared with the plot plans provided by the respective refineries, and wh ere applicable, are pres ented in the costing
workbooks .”

6.5 Project Timing

AEC/ETS estimated that startup of the control equipment could occur within 3 calendar years after the project begins:

“ETS believes that it is conceivable that ....emission reduction ..... can be achieved from the refineries implementing the commercially available measures described in this project within a construction time frame of approximately 3 calendar years or less following the completion of st udy designs and engineering.”Final Staff Report – Part 2 Chapte r 7 – ETS/AEC’s Analysis for Refinery Boilers/Heaters

_____________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 37 November 2, 2010 

### Chapter 7 – ETS/AEC’s Analysis for Refinery Boilers/Heaters

7.1 Recommended BARCT Levels

For refinery boilers/heaters, ETS/AEC studied th e technologies for pre-treatment of fuel gas prior to combustion in Module 2, and the technologies for post- treatment of flue gas after
combustion in Module 3A.

Regarding the pre-treatment of fuel gas prior to combustion, ETS/AEC stated that:

“the present value of 40 ppmv total sulfur in re finery fuel gas be re tained as the Best Available Retrofit Control Technology (BARCT) level”, and

Regarding the post-treatment of flue gas from boilers/heaters after co mbustion, ETS/AEC stated
that:

“ For the heaters and boilers, post-combustion em ission control is often expensive due to the combination of the relatively low concentr ations of SOx in flue gases and the division of the fuel gas stream among a number of he aters and boilers. Pre-combustion control, studied in Module 2, has been found to be more suitable for the major ity of situations.”

ETS/AEC’s conclusions on emission reductions (e stimated from the 2005 actual emissions) and cost effectiveness for pre-treatment of fuel gas for boilers/heaters are:

“ The measures recommended by AEC are the me asures that gave the largest expected SOx reduction potential while also featuring th e most reasonable cost effectiveness. The

total overall emissions reduction is approximately 0.89 tons per day SOx.

The overall cost effectiveness for refinery fuel gas, averaged over the commercially available measures that AEC recommended for th e refineries in this study, is estimated to be $16,823 per ton SOx reduced. The study team estimates that any given cost effectiveness number has an exp ected range someplace with in the band of -10% to

+50%. ”

Since ETS/AEC does not recommend a new BARCT level for boilers/heaters, staff will not describe this portion of ETS/AEC analysis in details, however a summary is included in Appendix II-A of this report.Final Staff Report – Part 2 References – Part II

_____________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 38 November 2, 2010 

### References – Part 2

AQMD, 2008-1. South Coast Air Quality Management Di strict – Board Meeting July 11, 2008, Agenda # 29: Report of RFPs and RFQs Scheduled for Release in July. 

### July 11, 2008.

AQMD, 2008-2. South Coast Air Quality Management Di strict – Request for Proposal, RFP

#P2009-01. 

### Evaluation of Emission Control Technologies for Further Reducing Sulfur Oxides Emissions from Stationary Sources in the South Coast Ai r Quality Management District’s RECLAIM Program. July 11, 2008.

AQMD, 2008-3. South Coast Air Quality Management Di strict – Board Meeting September 5, 2008, Agenda # 3: 

### Execute Contract to Evaluate Em ission Control Technologies for Further Reducing Sulfur Oxides Emissions from Stationary Sources in the SCAQMD SOx RECLAIM Program. September 5, 2008.

AQMD, 2008-4. South Coast Air Quality Management Di strict – Contract# C09104 – Contract with Nexidea, Inc. – 

### Evaluation of Emission Control Technologies for Further Reducing Sulfur Oxides Emissions from Stationary S ources in the SCAQMD’s RECLAIM Program. September 5, 2008.

AQMD, 2008-5. South Coast Air Quality Management Di strict – Contract# C09105 – Contract with ETS, Inc. – 

### Evaluation of Emission Control Techno logies for Further Reducing Sulfur Oxides Emissions from Stationary Sources in the SCAQMD’s RECLAIM Program. September 5, 2008.

NEXIDEA, 2008. SOx RECLAIM Final Report – Wet/Dry Scrubbing Technology for Sulfuric
Acid Plants and Coke Calciner. Nexidea, Inc. - December 2008.

ETS, 2008-1. SOx RECLAIM Study - Final Report – Modul e 2: Refinery Fuel Gas Treatment and Sulfur Recovery/Tail Gas Units. AEC Engineering Inc./ETS, Inc. April 20, 2009.

ETS, 2008-2. SOx RECLAIM Study - Final Report – Module 3-A: Wet/Dry Scrubbing Technology for Refinery Fluid Cata lytic Cracking Units (FCCUs), refinery Boilers/Heaters, and Refinery Sulfur Recovery Units (SRUs) and Tail Gas Treatment Processes. AEC Engineering Inc./ETS, Inc. April 20, 2009.

ETS, 2008-3. SOx RECLAIM Study - Final Report – Module 3-D: Wet/Dry Scrubbing Technology for Container Glass Manufacturing Plant. ETS, Inc. December 16, 2008.

ETS, 2008-4. SOx RECLAIM Study - Final Report – Module 3-E: Wet/Dry Scrubbing Technology for Cement Kilns and Coal -Fired Fluidized Bed Boiler. ETS, Inc. December 16,
2008.

TESORO, 2009.Final Staff Report – Part 2 Appendix A: Summary of Consultants’ Recommended Control Technology & Costs________________________________________________________________________________________________________________________________________Proposed Amended Regulation XX Part II - 39 November 2, 2010Appendix A – Summary of Consultants’Recommended Control Technology & CostsTypeRefinery 1 Refinery 2 Refinery 3 Refinery 4 Refinery 5 Refinery 6Control TechnologyNumber of Vendors ProvidedQuotes & Vendor's Names3 Vendors:BELCO, Hamon,MECS3 Vendors:BELCO, Hamon,MECS4 Vendors:Belco, Hamon,MECS, Alstom3 Vendors:BELCO, Hamon,MECS3 Vendors:BELCO, Hamon,MECSVendor Guarantee/Quote #1 BELCO <5ppmvBELCO<5ppmvBELCO<5ppmvBELCO<5ppmvBELCO<5ppmvVendor Guarantee/Quote #2MECS5ppmvMECS5ppmvMECS5ppmvMECS5ppmvMECS5ppmvInlet Parameters Provided forCosts & SizingFlow: 93 Kscfm;Temp:400-600FSOx: 54.8 ppmvFlow: 225 KscfmTemp: 560 oFSOx: 11.5 ppmvFlow: 145 KscfmTemp: 539 oFSOx: 20.7 ppmvFlow:101 KscfmTemp: 500 oFSOx: 20.6 ppmvFlow: 65 KscfmTemp: 539 oFSOx: 21.8 ppmvFlow:158 KscfmTemp: 545 oFSOt: 54.7 ppmvVendor for costs/sizing (note 1) BELCO BELCO BELCO BELCO BELCO BELCOPlot Space Estimated 35' L x 45' W 40' L x 50' W 40' L x 50' W 35' L x 45' W 30' L x 40' W 40' L x 50' WEquipment Cost ($ million)21 39 29 24 34147Capital Cost ($ million)60 101 78 66 90395Present Worth Value ($ million)76 133 95 78 110493Fluid Catalytic Cracking Units Total Costs for FCCUsWGSFinal Staff Report – Part 2 Appendix A: Summary of Consultants’ Recommended Control Technology & Costs________________________________________________________________________________________________________________________________________Proposed Amended Regulation XX Part II - 40 November 2, 2010Appendix A (Continued)TypeRefinery 1 Refinery 2 Refinery 3 Refinery 4 Refinery 5 Refinery 6Control Technology Emerachem WGS Emerachem Emerachem WGS WGSNumber of Vendors ProvidedQuotes & Vendor's Names2 Vendors: Lurgi,Emerachem3 Vendors: Lurgi,Cansolv, Tri-Mer4 Vendors: Lurgi,Cansolv,Emerachem, TriMer2 Vendors: Lurgi,Emerachem3 Vendors: Lurgi,Cansolv, Tri-Mer4 Vendors: Lurgi,Cansolv, GasSpec, Tri-MerVendor Guarantee/Quote #1Emerachem:3.85 ppmvd (95%)Emerachem:3.85 ppmvd (95%)Emerachem:3.85 ppmvd (95%)Vendor Guarantee/Quote #2Tri-Mer:≤1.0 ppmvTri-Mer:≤1.0 ppmvTri-Mer:≤1.0 ppmvTri-Mer:≤1.0 ppmvInlet Parameters Provided forCosts & SizingFlow: 109.8 Klb/hrTemp: 600-700 oFSOx: xx ppmvdFlow:180.6 KacfmTemp: 1000 oFSOx: xx ppmvFlow: 109.8 Klb/hrTemp: 600-700 oFSOx: xx ppmvdFlow: 109.8 Klb/hrTemp: 600-700 oFSOx: xx ppmvdFlow: 48.5 KacfmTemp: 1000 oFSOx: xx ppmvFlow: 117.9KacfmTemp: 1000 oFSOx: xx ppmvVendor for costs/sizing (note 1) Emerachem Tri-Mer Emerachem Emerachem Tri-Mer Tri-MerPlot Space Estimated 25' L x 100' W 88.5' L x 67' W 25' L x 100' W 25' L x 100' W29.5' L x 67' W (2units required)59' L x 67' W (2units required)Equipment Cost ($ million)4 14 5 4 15 2061Capital Cost ($ million)13 38 13 11 39 51164Present Worth Value ($ million)26 60 17 19 64 97282Sulfur Recovery Units/Tail Gas Total Costs for SRU/TGFinal Staff Report – Part 2 Appendix A – Summary of Consultants’ Recommended Control Technology & Costs__________________________________________________________________________________________________________________________________Proposed Amended Regulation XX Part II - 41 November 2, 2010Appendix A (Continued)TypeRefinery 1 Refinery 2 Refinery 3Control Technology FGT FGT FGTNumber of Vendors ProvidedQuotes & Vendor's Names2 Vendors: Shell Sulfinol, Gas Spec 2 Vendors: Shell Sulfinol, UOP 1 Vendor: Shell SulfinolVendor Guarantee/Quote #1 Sulfinol: 59% total SOx removal Sulfinol: 0.2% total SOx removalSulfinol removal of non-H2S sulfur:85%, 56%Total SOx reductionVendor Guarantee/Quote #2UOP Merox removal of non-H2S ethyland methyl-mercaptans: 93% ethylmercaptan, 80% methly-mercaptan;91%Total SOx reductionInlet Parameters Provided forCosts & SizingFlow: 821,000 scfh, Temp: notavailable, SOx inlet: 42.48 ppmvFlow: 3 MMscfd, Temp: not available,SOx inlet (total mercaptans): 300 ppmvFlow: 9.6 MMscfd for H2S absorber #5and 20.2 MMscfd for H2S absorber #6,Temp: 100 oF, SOx inlet (combined): 5ppmv for H2S and 20 ppmv for nonH2S speciesVendor for costs/sizing (note 1) Gas Spec UOP ShellPlot Space Estimated Small plot space required UOP: 40' L x 150' W Small plot space requiredEquipment Cost ($ million)0.2 5 5Capital Cost ($ million)0.5 16 12Present Worth Value ($ million)1.4 20 15Refinery Boilers/HeatersFinal Staff Report – Part 2 Appendix A – Summary of Consultants’ Recommended Control Technology & Costs__________________________________________________________________________________________________________________________________Proposed Amended Regulation XX Part II - 42 November 2, 2010Appendix A (Continued)TypeRefinery 4 Refinery 5 Refinery 6Control Technology FGT FGT FGTNumber of Vendors ProvidedQuotes & Vendor's Names2 Vendors: Shell Sulfinol, UOP 2 Vendors: Shell Sulfinol, UOP 2 Vendors: Shell, UOPVendor Guarantee/Quote #1Sulfinol: 97% or 5 ppmv, 54%TotalSOx reductionSulfinol removal for Wilmington: 85%removal for non-H2S sulfur in fuel gas ,68.4%Total SOx reductionSulfinol removal: 88%Mercaptans,31%COS, 11%Total SOx reductionVendor Guarantee/Quote #2UOP Merox: 47.6% total SOxreductionUOP Merox removal of Carson non-H2Sethyl- and methyl-mercaptans (191.4 ppmvof total): 93% ethyl-mercaptan, 80% methlymercaptan; 90%Total SOx reductionUOP Merox: 7.8% total SOxreductionInlet Parameters Provided forCosts & SizingFlow: 19,059 MMscf/yr,Temp: 100 oF,SOx inlet: 146 ppmvLocation A--> Flow:14 MMscfd, Temp:100oF, SOx: 50 ppmv. Location B--> Flow:20MMscfd, Temp:not available, SOx: 200 ppmvFlow: 42.4 MMscfd, Temp: 100 oF,SOx: not availableVendor for costs/sizing (note 1) Shell Shell + UOP ShellPlot Space Estimated Small plot space requiredShell:small plot space required for LocationA. UOP: 40' Lx150' W for Location BSmall plot space requiredEquipment Cost ($ million)5 21 944Capital Cost ($ million)13 53 23116Present Worth Value ($ million)16 64 21136Refinery Boilers/Heaters Total Costs for B/HFinal Staff Report – Part 2 Appendix A – Summary of Consultants’ Recommended Control Technology & Costs__________________________________________________________________________________________________________________________________Proposed Amended Regulation XX Part II - 43 November 2, 2010Appendix A (Continued)TypeFac C Fac A Fac A Fac BControl Technology WGS Equip Modification WGS WGSNumber of Vendors ProvidedQuotes & Vendor's Names4 Vendors: BELCO, TriMer, MECS, Cansolv4 Vendors: BELCO, Tri-Mer, MECS, Cansolv4 Vendors: BELCO, Tri-Mer, MECS, Cansolv4 Vendors: BELCO, Tri-Mer, MECS, CansolvVendor Guarantee/Quote #1MECS: <10 ppmv,expected <5 ppmvMECS: <10 ppmv,expected <5 ppmvMECS: <10 ppmv,expected <5 ppmvMECS: <10 ppmv,expected <5 ppmvVendor Guarantee/Quote #2BELCO: <10 ppmv,<5ppmv is achievablewith existing scrubbersBELCO: <10 ppmv,<5ppmv is achievable withexisting scrubbersBELCO: <10 ppmv,<5ppmv is achievablewith existing scrubbersBELCO: <10 ppmv,<5ppmv is achievablewith existingscrubbersInlet Parameters Provided forCosts & SizingFlow: 205,000 acfmTemp: 405 oFSOx inlet: 50 ppmvFlow: 27,383 acfmTemp: 86 oFSOx inlet: 20 ppmvFlow: 27,383 acfmTemp: 86 oFSOx inlet: 20 ppmvFlow: 70,000 acfmTemp: 134 oFSOx inlet: 145 ppmvVendor for costs/sizing (note 1) BELCO (Note 2) Cansolv (Note 3) BELCO (Note 4) BELCO (Note 4)Plot Space Estimated 30' L x 40' W No plot space needed 15' L x 20' W 20' L x 25' WEquipment Cost ($ million) 8.28.20.5 2.3 4.97.2Capital Cost ($ million) 13.313.30.5 3.1 6.69.7Present Worth Value ($ million) 25.325.31.7 8.0 17.325.3Coke Calciner Sulfuric Acid Plant

Total Costs for Calciner Total Costs for SAPFinal Staff Report – Part 2 Appendix A – Summary of Consultants’ Recommended Control Technology & Costs__________________________________________________________________________________________________________________________________Proposed Amended Regulation XX Part II - 44 November 2, 2010Appendix A (Continued)TypeControl Technology WGS Limestone Absorber DGS or Limestone AbsorberNumber of Vendors ProvidedQuotes & Vendor's Names4 Vendors: Tri-Mer (NWGS),MECS (NWGS), McGill(NWGS), Dustex (DGS), PPC(Process Mod)3 Vendors: MECS (NWGS),BoldEco (Limestone Absorber),BoldEco (Hybrid DGS +Baghouse), Dustex (Hybrid DGS +Baghouse)4 Vendors: MECS (NWGS),BoldEco (Limestone Absorber),BoldEco (HybridDGS+Baghouse), Dustex(Hybrid DGS+Baghouse), SoliosVendor Guarantee/Quote #1 MECS: 90% (<10 ppmv) MECS: 90% (<10 ppmv) MECS: 90% (<10 ppmv)Vendor Guarantee/Quote #2 McGill: 95% (5 ppmv)BoldEco Limestone Absorber:95% (<2 ppmv)BoldEco LimestoneAbsorber: 95% (5 ppmv)Inlet Parameters Provided forCosts & SizingFlow: 30,000 - 60,000 acfmTemp: 650 - 675 oFSOx inlet: 100 ppmvFlow: 170,000 - 203,000 acfmTemp: 275 oFSOx inlet: 25 ppmvFlow: 60,000 acfmTemp: 275 oFSOx inlet: 100 ppmvVendor for costs/sizing (note 1) Tri-Mer BoldEco BoldEcoPlot Space Estimated 32' L x 10' W 50' L x 40' WSolios:10' Diax71' HBoldeco:35' Diax35' HEquipment Cost ($ million) 1.11.116.6 4.721.3 290Capital Cost ($ million) 1.91.919.6 6.125.7 726Present Worth Value ($ million) 8.88.843.7 12.656.3 1,027 TOTAL COSTS

Total Costs for Cement

Total Costs for GlassCement PlantGlass PlantFinal Staff Report – Part 2 Appe ndix B – Consultants’ Biographies

_______________________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 45 November 2, 2010 

### Appendix B – Consultants’ Biographies

This section includes the biographies of the consu ltants. Staff will add more in a near future.Final Staff Report – Part 2 Appe ndix B – Consultants’ Biographies

___________________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 46 November 2, 2010 MARSHALL A. (BUD) BELL

PRESIDENT CARSON INDUSTRIAL STEAM COMPANY
1639 THIRD STREET
MANHATTAN BEA CH, CA 90266
310-376-4144 HOME

310-376-7194 FAX
310-951-8972 CELL
mbbells@earthlink.net

EDUCATION

1966 BS CHEMICAL ENGINEER ING-CLEMSON UNIVERSITY

1968 MS CHEMICAL ENGINEERING- GEORGIA TECH

1994 EXECUTIVE MBA-CLAREMONT GRADUATE UNIVERSITY

Mr. Bell has a very strong background in refining and power technologies, and in plant operations and management. He has 41 years of refining and power experience, covering ac tivities ranging from research and development to refi nery operations and maintenance work; and has held the position of General Manager of Refining for a prototype hea vy crude refinery. During his tenure as General Manager, the refinery achieved reco rd levels of profitability, safety and environmental compliance. Mr. Bell provided much of the strategic planning for Conoco/Phillip’s Wilmington Refinery, and helped develop and bring to the market se veral new refining technologies. He is currently President of Carson Industrial Steam Company, and is developing a la rge residual oil-fired cogeneration complex in
southern California. Mr. Bell recen tly completed a three-year assignment as Owner’s Engineer on a world-scale gasification pr oject in North America.

EXPERIENCE

Mr. Bell’s most recent job in refining was as Process Manage r for Conoco/Phillips Petroleum Company's Wilmington, California re finery. While in this position, Mr. Bell worked as part of a project team assessing the techni cal and economic merits of build ing an 8,000 TPD IGCC plant at the refinery. He helped set the design basis, evaluated potential gasificat ion technologies and assisted in developing the plant layout and coke handling syst ems. He also advised the development team on ways to maximize project returns, and on ways of meeting the very stringent air emission standards. During his tenure at this refinery, Mr. Bell helped develop, design and build the most sophisticated flue gas SO2 removal system in the refining industr y. He also developed a nove l approach to cracking jet fuel at low pressure to produce Ca lifornia-grade gasoline and isobutane.

Mr. Bell was previously Technology Manager for Petroleum Refining for Bl ack & Veatch Pritchard (BVPI) in Overland Park, Kansas. In this role, he was responsible fo r all aspects of petroleum refining and petrochemical technologies

. He assisted the Power Division in assessing the viability of severalFinal Staff Report – Part 2 Appe ndix B – Consultants’ Biographies

___________________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 47 November 2, 2010 direct-fired and IGCC power proj ects, and spent considerable ti me with the Power Group doing business development, both in the U.S. and overseas. Mr. Bell was involved in the training of engineers from major oil companies in the basics of power production using various technologies.

After leaving Conoco/Phillips, Mr. Bell began deve lopment of a 600 MWeq petroleum coke-fired cogeneration project in the Los A ngeles basin. The project will bur n petroleum coke in an ultrasupercritical steam boiler to generate power and pr ocess steam, while meeting the most stringent air quality standards in the world. The project will have the capability of removing 90 per cent of the CO2 in the boiler flue gas at le ss than $50 per tonne cost.

Mr. Bell also recently completed a three-year as signment as Owner’s Engineer on a world-scale gasification project for a fertiliz er plant in North America. The plant will gasify up to 15,000 TPD of coal or pet coke to make syngas for an IGCC unit, plus hydrogen for an ammonia/urea complex. Mr. Bell created the physical and economic model of the facility, as well as a pro forma model for various feedstocks and product offtakes. He provided novel wa ys of reducing capital a nd operating costs for the project, while increas ing plant throughput.

Prior to joining BVPI, Mr. Bell wa s Product Line Manager for Refini ng for Brown and Root Braun in Alhambra, California. In this po sition, he was responsible for the basic designs of refining and petrochemical units, and the proper execution of pr ocess designs on refini ng projects. Mr. Bell’s previous assignment with Brown and Root Braun was as Chief Process Engineer, where he supervised approximately 75 Process Engineers on numerous re fining, petrochemical, ammonia and ethylene studies and projects.

Prior to joining Brown a nd Root, Mr. Bell was Gene ral Manager of Refining for Ultramar Refining Company’s 75,000 BPD heavy crude re finery in Wilmington, Californi a. Under his guidance, the refinery established the best refi nery environmental record in the Los Angeles basin, and one of the best safety records in the refi ning industry. Mr. Bell also held Op erations Manager and Technical Manager position with Champlin Petroleum Compa ny, the predecessor to Ultramar at the Wilmington plant.

Prior to joining Champlin, Mr. Bell held a number of engineering and management positions with Chevron in their Richmond and El Segundo, Californi a facilities, and was i nvolved with two major expansions of both refineries.

Mr. Bell’s first industrial job was as a Technical Services and Oper ations Engineer with Shell Chemical Company in Martinez, California.Final Staff Report – Part 2 Appe ndix B – Consultants’ Biographies

___________________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 48 November 2, 2010 

## R OBERT 

## G. K UNZ 

## , P H 

## .D.

504 A LANBROOK C OURT H ILLSBOROUGH

, NC 27278-7733 R ESIDENCE : (919) 245-1560
O FFICE : (919) 245-1569
E- MAIL : KUNZRG @ AOL

. COM



### OBJECTIVE Continuing participation in tre nd-setting environmental control activities utilizing prove n strengths in planning, organization, analysis, and formulation of strategy to re duce costs, develop technology, and prevent downtime.



### BACKGROUND
SUMMARY Professional with over 40 years experi ence and a consistent track record of completing projects on spec, on time, and on budget. Areas of accomplishments include leadership, negotiation skills, problem solving, and the ability to correla te diverse facts. Excellent
communicator with the talent to in struct, train, and mentor others.

Earned both Ph.D. and M.B.A. degr ees. Published technical author including book, journal articles, presentations, and one patent. Experienced team leader. Skills range from management to research and development, with awards received in both areas.

Expertise in petroleum refining and chemical / gas plants:

• Air emission control and testing

• Cooling water treatment and corrosion control

• Processes including flui d catalytic cracking

• Wastewater treatment

• Noise generation, control, and measurement

• Environmental permitting



### SELECTED ACCOMPLISHMENTS

• Designed, built, and operated a pioneering pilot SO 2 and particulate flue-gas scrubber on fluid catalytic cracker (FCC) regenerator, allowi ng installation of full-scale scrubber at oil refinery to meet new air quality regulations.

• Led a team to respond quickly to pinpoint sour ce of excessive particulate emissions from electrostatic precipitator treating cat cracker regenerator flue ga s and others at California oil refinery.Final Staff Report – Part 2 Appe ndix B – Consultants’ Biographies

___________________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 49 November 2, 2010 • Co-authored U.S. patent while serving on elite task force to identify high-cost and missing technology necessary to comply w ith increasingly stringent environmental regulations in the refining industry.

• Over a 15-yr period, managed e ngineering group and supervised a team of environmental professionals responsible for negotiating enviro nmental approvals needed for construction of new plants / projects. No capital project was ever delayed by failure to obtain permits in a timely manner.

• Served as member of "SWAT" team in disc retionary siting of ne w $20M - $30M industrial gas plants to identify any fatal flaws whic h might prevent, delay, or jeopardize plant construction or unduly increase the cost.

• Supported sales of hydrogen gas to petroleum industry by providing expertise in environmental regulatory compliance.

• Developed a correlation to predict hydrogen re former furnace NOx emissions (later extended to ethylene plants). Presented results at industry conferences and in the technical literature.

• Secured permits for and field-tested sele ctive catalytic reducti on (SCR) units, a postcombustion NOx control technique, located at / adjacent to several re fineries / chemical plants. Published findings in Journal of the Air & Wast e Management Association.

• Developed procedure for forecasting SCR catalyst life to prevent untimely shutdown of operations, presented at a petr oleum industry conference and published in the literature ( Environmental Progress ).

• Presented technical paper on the successful application of SCR to FCC units at multiple locations. This presentation at a petroleum industry conference was co-authored by the SCR system manufacturer and a repres entative of a U.S refinery.

• Directed multi-location environmental site assessment for $65M acquisition, which was completed on schedule and at less than 50% of budget, allowing timely acquisition of new product line.

• Formulated the "Kunz Equation," which correlate s system pH from alkalinity measurements in over 100 cooling towers to allow indepe ndent cooling water calculations, used as objective criteria to ev aluate vendor proposals. These procedures were published in Chemical Engineering magazine and are now taught in college classrooms.

• Received Harrison Prescott Eddy Medal, a pres tigious award given annually by the Water Pollution Control Federation, for noteworthy research in wastewater treatment.Final Staff Report – Part 2 Appe ndix B – Consultants’ Biographies

___________________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 50 November 2, 2010 

### PROFESSIONAL EXPERIENCE

RGK ENVIRONMENTAL CONSULTING, L.L.C., Hillsborough, NC 2003-Present Independent Consultant / Author

CORMETECH, INC. ENVI RONMENTAL TECHNOLOGIES , Durham, NC 2001-2003 Technical Project Manager

AIR PRODUCTS AND CHEMICALS, INC. , Allentown, PA 1974-2000 Senior Engineer / Manager / Senior Engineering Associate

ESSO RESEARCH AND ENGINEERING COMPANY , Florham Park, NJ 1968-1974

Engineer / Project Engineer

MILITARY SERVICE

Lieutenant, United States Air Force - Honorably separated from Active Duty and transferred to
Retired Reserve.

Received Certificate of Outstanding Achievem ent from United States 17th Air Force for Communications Cost Reduction and Manageme nt Improvement Programs at conclusion of final assignment.



### EDUCATION

Ph.D., Chemical Engineering, Renssel aer Polytechnic Institute, Troy, NY M.B.A.., Executive Program, Temple University, Philadelphia, PA M.S., Environmental Engineering, Newark College of Engineering, Newark, NJ B.Ch.E. (with honors), Chemical Engineering, Manhattan College, Bronx, NY

Additional college courses in Psychology, Economics, Accounting, and Marketing



### PROFESSIONAL LICENCES

Registered Professional Engineer NJ, PA, AL, TX, LA Former Certified Community Noi se Measurement Specialist, NJ



### PROFESSIONAL ASSOCIATIONS

American Institute of Chemical Engineers (AIChE) American Chemical Society (ACS) Air & Waste Management Association (A&WMA) Sigma Xi - The Scientific Research SocietyFinal Staff Report – Part 2 Appe ndix B – Consultants’ Biographies

___________________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 51 November 2, 2010 

### JOHN D. MCKENNA
ETS, Inc. 1401 Municipal Road Roanoke,VA 24012
540-265-0004 ext 293 jmck@etsi-inc.co m



### EDUCATION B.S.Ch.E. - Manhattan College - 1961 M.S.Ch.E. - New Jersey Institute of Technology - 1968 M.B.A. - Rider University - 1974 Ph.D. - Walden University - 1991

Doctoral Thesis Topic: A Study of Factors Unde rlying Growth for Industrial Firms During Their Early Years After Startup

Master Thesis Topic: The Effect of Nitrilotriacetic Acid Upon th e Biodegradability of Synthetic Detergents

Certified On-line Trainer - Walden University - 2000



### EXPERIENCE

Dr. McKenna has over forty years of technical and business manageme nt experience. His background includes a wide range of entreprene urial activities including the start- up of six environmental firms, one of which he took public. His direct experience incl udes corporate acquisitions and mergers as well as
the invention and commercialization of a flue gas desulphurization (FGD) system. In light of the weak USA market conditions, an office wa s established in Taiwan and ther eby the initial FGD system sales were achieved. In 1996, ETS International Inc. was listed in “The Nations Fastest Growing Technology Companies,” having recorded a 5-year reve nue growth of 542%. In addition to business and technical management experience, he has also been providing international training for over 30 years. Currently he is a principa l of ETS Inc. He has taught onlin e business and environmental courses for the University of Phoenix.

2002-2007 Co-chair Southampton Corp A private venture capital firm specia lizing in the environmental industry.

2002-2006 University of Phoenix Teaching on-line: Management, Marketing, Environmental Ethics, Environmental ScienceFinal Staff Report – Part 2 Appe ndix B – Consultants’ Biographies

___________________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 52 November 2, 2010 1999-present Principal ETS Inc. A provider of environmental training, testing, troubleshooting and testimony.

Chairman/President, ETS International, Inc. Responsible for general management and long range planning functions. Program Manager – FGD (LEC) – Full Scale Commercial Systems.

President, ETS, Inc., June 1979 to June 1988. Responsible for general management a nd R&D strategic planning/priorities Program Manager – Pilot Plant FGD (LEC) Semi-Dry System.

President, January l, 1978 to June 1979. Enviro-Systems & Research, Inc. and Environmenta l Testing Services, Inc. Director '72-'82.

Vice President, Enviro-Systems & Research. Directed all application engineering, research a nd development related to air and water pollution
control. Concentration of effort on fabric filters, mechanical collector s and scrubbers for a wide variety of industrial applications . Program manager for m illion dollar EPA contract.

1968-72 Research Cottrell, Projects Director of Environmental Systems Division. Supervised the development of RC's wet limestone scrubber for SO 2 removal FGD Pilot Plant and first RC full scale FGD system at Arizona Public Service. Responsible for execution of all projects and laboratory activities for both air and water pollu tion control, including in-house research and development and industrial and EPA R&D contracts. Supervised technical services which encompassed stack and stream sampling, laboratory analytical determinations, bench analysis, pilot plant fabrication and research. Major R&D efforts, oriented to particulate control and SO 2 removal. Consulting included comprehensive polluti on control studies for complete industrial plants.

1967-68 Princeton Chemical Re search, Project Leader. Assigned to execute industrial and government contracts for water and air pollution control, including a
NAPCA contract concerned with SO 2 control by catalytic reduction.

1964-67 Eldib Engineering & Resear ch, Inc., Technical Assist ant to the President. Senior Engineer for pollution control problem solvi ng. Investigated industria l wastewater, municipal sewage and industrial air pollution problems.Final Staff Report – Part 2 Appe ndix B – Consultants’ Biographies

___________________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 53 November 2, 2010 

### PROFESSIONAL ACTIVITIES

Air and Waste Management Associati on Technical Council – AE Chair 2002-2005 Virginia Environmental Business C ouncil – Board of Directors 2000-2004 Air and Waste Management Association Technical Program – Chairman, Speci alty Conference Fabric
Filter VII 1994 Air and Waste Management Association South At lantic Section – Board of Directors 1993-1996 Virginia State Advisory Board of Air Pollution – 1992 Vice Chair, 1993 Chair Advisory Board Member: Wiley Se ries in Chemical Engineering Air and Waste Management Association Technical Program – Chairman, Speci alty Conference Fabric
Filter VI 1992 Technical Program Committee, Scientific Evaluatio n of the National Acid Precipitation Assessment Program's (NAPAP), Final Report – 1991 Technical Advisory Committee, Ohio Air Qu ality Development Authority (OAQDA) – 1991 Air and Waste Management Association Emissi on Control Technology - Division Chairman, 1988-
1991 Air and Waste Management Association Technical Program – Chairman, Speci alty Conference Fabric
Filter V 1990 NSF Consultant for the College Faculty Workshop Program-Grant EPA Fabric Filter Workshop Lecturer
Scientific Reviewer for EPA Publications
AIChE - Central VA Section – Chairman 1980-84
APCA Lecturer "Particulate C ontrol Device Cost Optimization"
Member of National Association of Environmental Professionals EPA Course 413 Lecturer, "Fabric F ilters and Selection and Cost of Control Equipment." – Presented at Rutgers University, March 18-19, 1987.



### LISTINGS AND AWARDS Distinguished Alumni Medal for Outstanding Achi evement - New Jersey Institute of Technology

Manhattan College School of E ngineering Centennial Award - Ou tstanding Engineering Graduate

New York Xi, Chapter of Tau Beta Pi, National Honor Society of Engineering - Eminent Engineer

Fellow -- American Institute of Chemical Engineers Fellow – Air and Waste Management Association. Who's Who in Engineering Who's Who Environmental Registry Who's Who in Finance and Industry Who's Who in Technology Today
Who's Who in the World Who's Who in Science and Engineering Appointed by VA Governor G. Allen 97-01 World Trade Alliance of the Blue RidgeFinal Staff Report – Part 2 Appe ndix B – Consultants’ Biographies

___________________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 54 November 2, 2010 

### COMMUNITY ACTIVITIES

Chairman, Roanoke Catholic School Board, 1984-1986 Roanoke Memorial Hospital Pastoral Care Visitor 1988-1992



### TRAINING COURSES DELIVERED

Domestic
Fine Particle Emission Measurement & Control
Toxic Air Pollutants - Prevention and Control Particulate Emission Control Cost Optimization
Introduction to Air Pollution Control
Introduction to Water Pollution Control
Incineration Regulatory and Permitting Policies
Particulate Emission Control
Gaseous Emission Control Baghouse Operation and Maintenance Project Costs and Financing Project Management Public Involvement in Large-Scale Development Pr ojects with Significant Environmental Impacts - AED/USAID for Russian Group Pollutant Release and Transfer Registers Program - AED/USAID for Ukrainian Group

Foreign Developing and Implementing Emission Inventories - Saudi Arabia/SABIC Energy and the Environment - Univ. of La Laguna - Canary Islands Baghouse Technology - National Taiwan University - Taipei, Taiwan Air Pollution Technology Workshop - Floreanopolis, Brazil - IIE/USAEP
Methods of Effective Environmen tal PR - AED/USAID Kazakhstan National Park Management Capaci ty Building - AED/USAID Armenia



### PROJECT MANAGEMEN T EXPERIENCE

John D. McKenna has gained comprehensive technical project management e xperience over the past 40

years.

In 1967-1968, while at Princeton Chemical Resear ch, Dr. McKenna was the Program Manager of a research project funded by the National Air Pollu tion Control Agency (NAPCA) to evaluate SO 2 control by cataly tic reduction.Final Staff Report – Part 2 Appe ndix B – Consultants’ Biographies

___________________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 55 November 2, 2010 While at Research Cottrell, du ring 1968-1972, he was the Program Manager on an EPA/HEW project which dealt with the design, insta llation, operation and testing of a wet scrubbing pilot plant for SO 2 control. Managed pilot wet scrubber FGD testing at AEP (Tidd Station) and RC’s first full scale SO 2 FGD system at Arizona Public Service (Cholla Station).

During this time, he was also the technical mana ger of a program funded by Research Cottrell to acquire and develop the RC/Bacho system for SO 2 removal.

In 1973, Dr. McKenna was the Program Manager of EPA 68-02-1093. The purpose of this ETS contract was to conduct a preliminary techno-economic ev aluation of the applicatio n of fabric filters to
coal-fired industrial boilers. The success of this project led to a larger s cale demonstration program (EPA 68-02-2148) and a subsequent follow on pr ogram (EPA 68-02-3674) both managed by Dr.
McKenna.

In 1976, he managed a program to install, operate and te st a fabric filter pilot pl ant on the slipstream of a refuse-fired boiler. The study, EPA R804223, was initia ted to determine if a fa bric filter was a viable control alternative for this application.

In 1981, Dr. McKenna managed an ETS contract recei ved from EPA Region 5 (EPA task order 116) to execute an air pollution c ontrol engineering study. The purpose of this study was to settle a dispute between a federal agency and state government. In this effort, ETS technical personnel successfully executed 12 major tasks both w ithin budget and on schedule.

In 1982, he managed a major ETS environmental engi neering contract funded by the Government of Mexico. The program objectives were to design a nd specify a continuous ambient monitoring network for a developing industrial port and surrounding reside ntial towns on the west coast of Mexico. Not only did the program involve the ma nagement of ETS technical personn el, but also the coordination of activities between ETS and several consulting s ubcontractors, Mexican au thorities and various Mexican industrial representatives.

In 1983, ETS received a contract (EPA 68-02-3649) to ch aracterize the performance of fabric filters on three large utility boilers. This program not only demonstrated the field testing and other technical capabilities of ETS, but also Dr. McKenna's pr ogram management abilities since two major subcontractors were involved (RTI and TRC) and field teams of over 20 engi neers, scientists and
technicians were mobilized.

In 1985, he was the ETS manager in a program in wh ich ETS was subcontractor to Malcolm Pirnie. The program was funded by the Power Authority of the State of New York (PASNY). The purpose
was to evaluate the techno-economic feasibility of applying fabric filtration and dry scrubbing to control MSW emissions. The major outputs of the study included capital and operating costs estimates and recommended design specifications for the subject control techniques.

Dr. McKenna has managed an ETS program funded by the Ohio Coal Development Office. The program initiated in 1987, evaluates an approach to control acid rain precursors. In this program, he has been responsible for the coordination of all ac tivities between ETS and th e prime contractor, Ohio University.Final Staff Report – Part 2 Appe ndix B – Consultants’ Biographies

___________________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 56 November 2, 2010 In the 1990s managed EPA Contract No. 68D 20029, "Source Testing and Method Evaluation for Stationary Source Emissions."

From 1998 to present via an ETS subcontract from RT I, he has been the manager of the Air Pollution Control Technology (APCT) Business and Marketi ng Planning activity for EPA’s Environmental Technology Verification Program (E PA Coop. Agreement CR826152-01-0). He has also provided the coordination and technical support of the APCT’s Baghouse Filtra tion Products (BFP) Verification Program. This activity includes the preparation of generic protocols and test Q/A plans, review and
coordination of recommended modifi cations to existing generic prot ocols and test Q/A plans, and continued review and commentary of the BFP verification process.

In 2008-2009 Dr. McKenna managed an ETS contract received from the South Coast Air Quality Management District (SCAQMD) for the evaluati on of emission control technologies for further reducing sulfur oxide emissions fr om stationary sources in the SCAQMD’s RECLAIM program. The purpose was to identify the Best Available Retrof it Control Technologies (BARCT) that could be implemented within the 2011-2014 timeframe to help South Coast Basin attain the PM2.5 ambient air quality standards. The industrie s covered included refineries, cem ent manufacturing, and container glass manufacturing.



### PUBLICATIONS – TEXTBOOKS

McKenna, John D.; Turner, James H.; "Fabric Filte r - Baghouses I Theory, Design, and Selection ." Published in 1989, ETS, Inc., Roanoke, VA.

Mycock, John C.; McKenna, John D.; Theodore, L.; "Handbook of Air Pollution Control Engineering and Technology " Published by Lewis Publishers, 1995.

McKenna, John D.; Turner, James H.; McKenna, Jame s P., “Fine Particle (2.5 Microns) Emission Regulations, Measurement and Control ” Published by John Wile y & Sons Inc., 2008



### PUBLICATIONS – TEXTBOOK CHAPTERS

McKenna, John D.; Greiner, Gary P.; "Air Polluti on Control Equipment: Operation and Maintenance "; Chapter 8: "Baghouses" - Publis hed in 1982, Prentice Hall, Englew ood Cliff, NJ. Ed. Theodore &
Buonicore.

Turner, J.H.; McKenna, J.D.; "Control of Particles by Filters", Chapter in Air Pollution Technology
Handbook , Seymour Calvert, ed. Jo hn Wiley & Sons, Inc., 1984.

Turner, J.H.; Lawless, P.A.; Yamamoto, T.; Coy, D.W.; Greiner, G.P.; McKenna, J.D.; Vatavuk, W.M; "Electrostatic Precipitators," Chapte r 3 in Air Pollution Engineering Manual , Van Nostrand Reinhold, New York, NY, Ed. by Buonicore, A.J. and Davis, W.T., 1992.Final Staff Report – Part 2 Appe ndix B – Consultants’ Biographies

___________________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 57 November 2, 2010 McKenna, J.D.; Furlong, D.A.; "Fabric Filters," Chapter 3 in Air Pollution Engineering Manual , Van Nostrand Reinhold, New York, NY, Ed. by B uonicore, A.J. and Davis, W.T., 1992.

Mc Kenna, John D. “Air Pollution Mana gement of Stationary Sources” Section 25 in Perry’s Chemical Engineer’s Handbook , Seventh Edition, Mc Graw-Hill, NYC, 1997



### PUBLICATIONS – ARTICLES AND PRESENTATIONS

McKenna, J.D.; Eldib, I.A.; New Markets for Chemicals and Equipment to Combat Pollution

. Presented at Farleigh Dickinson University Summer Conference, "The Demands of Pollution Control Legislation", August 22-26, 1966. Cite d in C&EN 44, 37 (Sept. 4, 1966).

M.S. Thesis: The Effect of Nitrilotriacetic Acid Upon the Biodegradability of Linear Alkylbenzene
Sulfonate (1968).

McKenna, J.D.; Evaluation of a Two-Stage Particul ate Scrubber and Gas Absorber Applied to Power
Plant Flue Gas . Presented at the NAPCA Internati onal Symposium on Wet Limestone Scrubbing, Pensacola, FL, March 16-20, 1970.

McKenna, J.D.; Atkins, R.S.; The RC/BAHCO System for Removal of Sulfur Oxides and Fly Ash
from Flue Gases , Power Engineering, May 1972, pp. 50-52. Presented at the

Second International Lime-Lime-Stone-Wet Scr ubbing Symposium, New Or leans, LA, Nov. 8-12,
1971.

McKenna, J.D.; The International Competitivene ss of the U.S. Air Pollution Control Industry

. Presented at the Internationa l Air Pollution Control and Nois e Abatement Exhibition, Jonkoping, Sweden, September 1971.

Gleason, R.J.; McKenna, J.D.; Scrubbing of Sulf ur Dioxide From a Power Plant Flue Gas . Presented at the 69th National Meeting of the American Institute of Chemical Engineers, Cincinnati, OH, May 16-19, 1971.

Roberts, R.M.; et al; Systems Evaluation of Refuse as a Low Sulfur Fuel , November 1971, EPA
Contract CPA 22-69-22.

McKenna, J.D.; Coy, D.W.; Techno-Economic Selecti on in Times of Changing Costs and Performance Requirements . Published in the Proceedi ngs of the Fifth Annual Northeast Regional Anti-Pollution Conference, University of Rhode Island, July 1972.

McKenna, J.D.; Applying Fabric Filtration to Coal-Fired Industrial Boilers . Environmental Protection Technology Series, July 1974,
EPA-650/2-74-058.Final Staff Report – Part 2 Appe ndix B – Consultants’ Biographies

___________________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 58 November 2, 2010 McKenna, J.D.; Mycock, J.C.; Lipscomb, W.O.; Perf ormance and Cost Comparisons Between Fabric Filters and Alternate Particulate Control Techniques . Presented at the symposium on the "Use of
Fabric Filters for the Control of Submicron Particulates", 4/8/74, Boston, MA. Sponsored by the Environmental Protection Agen cy and GCA Corporation.

McKenna, J.D.; Weisberg, R.; A Pilot Scale Investigati on of Fabric Filtration as Applied to Coal Fired
Industrial Boilers . Published in the Proceedings of the F ourth Annual Industrial Air Pollution Control Conference, University of Tennessee, March 28, 1974, Knoxville, TN.

McKenna, J.D.; The Application of Fabric Filt er Dust Collectors to Coal-Fired Boilers . Presented at
the Fourth Annual Environmental Engineering & Science Conference, Louisville, KY, March 4, 1974.

Theodore, L.; et al; Selected Problems in Design of Air Pollution Equipment . National Science Foundation, August 1975, NTIS PB 246- 363 (Contributing consultant).

McKenna, J.D.; Mycock, J.C.; Lipscomb, W.O.; Appl ying Fabric Filtration to Coal-Fired Industrial Boilers: A Pilot Scale Investigation . EPA Technical Services, August 1975, EPA 650/2-74-058a.

McKenna, J.D.; and Brandt, K.D.; Demonstration of a High Velocity Fabric Filtration System Used to Control Fly Ash Emissions . Presented at The Third Symposiu m on Fabric Filters for Particle Collection, Tucson, AZ, December 1977.

McKenna, J.D.; Greiner, G.P.; Brandt, K.D.; Applyi ng High Velocity Fabric Filters to Coal-Fired
Industrial Boilers . Presented at the Symposiu m on the Transfer and Utiliza tion of Particulate Control Technology, sponsored by the U.S. Environmental Pr otection Agency at the University of Denver, Denver, CO, July 24-28, 1978.

McKenna, J.D.; Mycock, J.C.; Miller, R.L.; Brandt, K.D.; Applying Fabric Filtration to Refuse-Fired Boilers: A Pilot-Scale Investigation . EPA Contract No. R804223, May 1978, Office of Energy, Minerals and Industry, U.S. Environmenta l Protection Agency, EPA-600/7-78-078.

McKenna, J.D.; Mycock, J.C.; Brandt, K.D.; Szala y, J.F.; Assessment of a High Velocity Fabric Filtration System used to Control Fly Ash Emissions . Annual Report for Contract No. 68-02-2148 for the U.S. Environmental Protection Agency, April 1979.

Richardson, J.W.; McKenna, J.D.; Mycock, J.C.; An Ev aluation of Full Scale Fa bric Filters on Utility
Boilers

. Presented at the Fourth Symposium on the Tr ansfer and Utilization of Particulate Control Technology, Houston, TX, October 11-15, 1982.

Beachler D.S.; Richardson, J.W.; McKenna, J.D.; Mycock, J.C.; ETS, Inc., and Harmon, D., EPA - Emission Reduction Performance and Operating Characteristics of a Baghouse Installed on a
Coal-Fired Power Plant , August 1984, EPA Contract 68-02-3649.

McKenna, J.D., Ross, J.M., Foster, J.M., Gibson, R.A., Continued Assessment of a High-Velocity Fabric Filtration System Used to Control Fly Ash Emissions , EPA-600/7-84-037, March 1984.Final Staff Report – Part 2 Appe ndix B – Consultants’ Biographies

___________________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 59 November 2, 2010 McKenna, J.D., Ross, J.M.; What One Small E nvironmental Firm Requires of Its Chemists . Presented at the 62nd Annual Meeting of Am erican Institute of Chemists , Hollywood, Florida, April 1985.

Richardson, J.W., McKenna, J.D., Mycock, J.C., Eval uation of Full Scale Fabric Filters on Utility Boilers: SPS Harrington Station Unit 3 , NTIS PB85-235513/WEP, July 1985.

Richardson, J.W., McKenna, J.D., Mycock, J.C., Eval uation of Full Scale Fabric Filters on Utility
Boilers: PP and L Brunner Island Station Unit 1 , NTIS PB85-235521/WEP, July 1985.

Mycock, J.C., McKenna, J.D., Richardson, J. W., Baghouse Troubleshooti ng - A Case History

. Presented at the Professional De velopment Conference - Developm ents in Filtration Technology, Clemson University, May 14-15, 1986.

Greiner, G.P., Smith, J.K., Ross, J.M., McKenna, J. D., Demonstration, Opera tion, and Testing of a
Fabric Filter on an Industrial Boil er for an Extended Period of Time , EPA-600/7-86-030, September,
1986.

McKenna, J.D., Haley, L.H., Industrial Fabric Filte r Bag Test Methods: Usefulness and Limitations

. Presented at the ASTM Symposium on Gas and Li quid Filtration, Philadelphi a, PA, October 20-22,
1986.

McKenna, J.D., Furlong, D.A., Baghouses As App lied to Municipal Solid Waste Incinerators

. Presented at Filtration Technology Conf erence in Clemson, SC, April 15-16, 1987.

Kapner, M., Schwarz, S., McKenna, J., An Evalua tion of Alternate Emission Control Systems for Refuse-to-Energy Plants . Presented at the 80th Annual Meeti ng of APCA, New York, NY, June 21-26,
1987.

Turner, J.H.; Viner, A.S.; Jenkins, R.E.; Vatavuk, W. M.; McKenna, J.D.; Sizing and Costing of Fabric
Filters , JAPCA September, 1987 issue, Volume 37, Number 9, Page 1105.

Turner, J.H.; Lawless, P.A.; Yamamoto, T.; Coy, D.W.; Greiner, G.P.; McKenna, J.D.; Vatavuk, W.M.; Sizing and Costing of El ectrostatic Precipitators , JAPCA April, 1988 issue, Volume 38, Number 4.

McKenna, J.D.; Toxic Particulate Control . Presented at the EPA Workshop on Hazardous and Toxic Air Pollutant Control Technologies and Permitting Issues, Raleigh, NC, March 22-23, 1988 and San Francisco, CA, April 12-13, 1988.

Bahner, Mark A. and John D. McKenna; Inlet-Pr echarged Limestone Emission Control (LEC)

. Presented at the American Filtration Society Annual Meeting - Fine Particle Filtration & Separation, Minneapolis, MN, April 22-24, 1991.

Prudich, M.E.; Reddy S. N.; McKenna, J.D.; Appell, K.W.; A Pilot Demonstration of the Moving-Bed Limestone Emission control (LEC) Process . Paper presented at the 1991 EPRI/EPA/DOE SO 2 Control Symposium, Washington, DC, Decem ber 306, 1991. Also presented at the 85th Annual Meeting and Exhibition of the AWMA, Kansas City, MO, June 21-26, 1992.Final Staff Report – Part 2 Appe ndix B – Consultants’ Biographies

___________________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 60 November 2, 2010 McKenna, J.D.; Energy and the Environment . Presented to graduate students at LaLaguna University, Tenerife Island, Spain, November 8, 9, 10, 1993.

Prudich, M.D.; Appell, K.W.; McKenna, J.D.; Pilot-Sc ale Limestone Emission Co ntrol (LEC) Process: A Development Project . Final Report - March 1994.

McKenna, J.D.; Mycock, J.C.; Fabric Filter Baghouse Seminar . Presented at National Taiwan University, Taipei, Taiwa n, R.O.C., October 12, 13, 14, 1994.

Mc Kenna, J.D.: ETS, Inc. 1 st International Cleanabl e Filter Symposium: Status of EPA’s Baghouse
Filtration Products / Environmental Technol ogy Verification Program. Chiba-Ken, Japan. The
Association of Powder Process Indus try and Engineering, Japan (APPIE) November 15, 2000.

Mc Kenna, J.D. :ETS, Inc. 2 nd International Cleanable Filter Sy mposium: Baghouse Filtration Products Verification Status Report. Osaka, Japan. The Association of Powder Process Industry and Engineering, Japan (APPIE) October 29, 2001.

Mc Kenna, J.D.; Mycock, J.C.; Practical Implic ations of ETV for Fi ne Particle Control, The Air & Waste Association Annual Meeting June 23, 2004

McKenna, J. D.: A New Tool for Improving Control of Fine Particle Emissions. Institute of Electrical and Electronics Engineers, Roanoke Va . September 21, 2006

McKenna, J. D.: Filter Media Selection for Coal Fired Plants, McIlvaine Company Hot Topic Hour October 16, 2008



### WORKSHOPS

Drexel University, 2001 Olin Workshop On The Environment, Philadelphia, PA “Environmental Technology for Particulate Emission Control”

Rheinhold Environmental 2002 ESP/FF Roundtable & E xpo, Dallas, TX “Fabric Filter Application &
Selection”

PETROBRAS 2007 Seminar on Atmospheric Emissi ons, Rio de Janeiro, Brazil “Air Shed Management PM10/PM2.5/0zone”Final Staff Report – Part 2 Appe ndix B – Consultants’ Biographies

___________________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 61 November 2, 2010 

## James P. Norton, P.E.

Mr. Norton is a Principal Engineer and President of Norton Engineering Cons ultants, Inc. (NEC), which he founded in 1993. He has 30+ years experi ence in the petroleu m process, specialty chemicals, lubricants, energy and environmental fields.

Mr. Norton has had a broad range of experien ce in petroleum refining and petrochemicals including:

• Fired heaters, boilers, CO boilers, incinerato rs, burners, and other solids, liquid and gas fueled combustion equipment and ancillary systems,

• Process development for reactiv e extrusion, polymer processi ng, and selective non-catalytic NOx reduction processes,

• Polymer Processing specialist (synthetic rubber and silanes),

• Process Design – solution polymerization plan ts, synthetic rubber dewatering and drying facilities, direct polymer devolatilization sy stems, reactive extrusi on systems for polymer modification, lube blending, lubricant addi tive manufacturing, environmental control systems (SOx, NOx, PM, HAPs), fired heater s, steam generators, heat exchangers, pneumatic conveying systems, wet gas scrubbi ng systems, water treating facilities, offsites/utilities, steam boilers, wast e heat recovery facilities, etc.

• Planning – lube blending, lubrican t additives, flue gas desulfur ization and particulate control systems, environmental control facilities for polymer manufacturing plants, water slurry polymer finishing, direct de volatilization of solution poly mers, solvent recovery and purification systems, delayed coker debottlen ecking, fluid coker, and flexicoker projects.



## Selected Career Highlights

1993 to Present: Norton Engineering Consultants, Inc., Boonton, NJ

• Refinery steam system optimization and boiler upgrade project planning, design and execution support (HOVENSA – 2008)

• Refinery boiler house ULNB conversion, economizer replacement and flue gas recirculation system design (Sunoco – 2008)

• Replacement Atmospheric and Vacuum Crude Heater designs (CO Heaters on FCCU) (Valero – 2007-08)

• Naptha Hydrotreater and Ca talytic Reformer Heater UNL B Conversion Project Design (ConocoPhillips 2007-08).

• CO Boiler upgrade design and field s upervision (ConocoPhillips – 2007 - 2009).

• Crude Unit Heater SIS System Design & Start-up (ConocoPhillips – 2007-08).Final Staff Report – Part 2 Appe ndix B – Consultants’ Biographies

___________________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 62 November 2, 2010 • FCCU/FCU Emissions Control Proj ect consulting (Valero – 2001-2007).

• FCC CO Boiler evaluation for in stallation of emissions contro l facilities (ConocoPhillips – 2007).

• FCCU wet gas scrubbing system troubleshooting (ConocoPhillips – 2007).

• FCCU wet gas scrubbing project de sign review (ConocoPhillips – 2007).

• FCCU wet scrubbing system project assistance (cold-eyes reviews) (ConocoPhillips – 2007).

• NHT fired reboiler design and design of retrof it SIS system for NHT pre-heater furnace (Valero - 2006)

• Troubleshooting – LABSORB Regenerative Scrubbing System (Valero – 2006)

• Consulting – FCCU scrubber expansi ons (Various Clients - 2002, 2006, 2007)

• Lead Investigator for US DOE Advanced Fi red Heater Developmen t Project (2001 – 2005)

• Assessment of commercial technologies for the direct devolatilization of solution polymers (EP/EPDM) (2004-05)

• Solution polymer blending and devolatilizati on facilities for toll processor (2003)

• Jet Ejector Venturi Wet Gas Scrubbing System Design including assess ment of regenerator overhead circuit including flue gas expander and back pressuring existing CO Boiler – EM R&S (2000-2001)

• Flue Gas Desulfurization Technol ogy Evaluation – EM R&S (1999)

• Wet Gas Scrubbing System Designs – ExxonMobil Licensees (1996, 1997, 2001, 2004)

• FCCU Regenerator O/H Modificat ions for Electrostatic Precipitator Installation On-the-Run – Ultramar Diamond Shamrock (Quebec, 1996)

• Turnaround support and operations consulting for combined FCCU and FCU CC Boiler

• Boiler fired petroleum coke, wa ste CO gas from the FCCU and FCU and had supplemental RFG capability. (Alberta - 1994)

• Lubricant Additives Plant (solution polymeri zation facility) – Process Design and Planning (Infineum France SA, 1999 – 2000)

• Start-up support for SRP section of c lient’s synthetic rubber plant (1995).

• Dispersants Plant - Process, Environmen tal Control and Offsites Design (ECC, 1995 – 1996)

• Lubricants Blending Plant Operations Consultin g and Design Services (EUSA, Continuing)

• Hazardous Material Control Sy stems Development and Implementation (Lockheed Martin Aerospace, 1994 – 1996)

• Boiler Emissions Control Technology Selec tion (SOx & PM) for Bitumen Fired Steam Generators – IOR (2001)

• Reactive Extrusion Process Development - ExxonMobil Chemical / Dow Corning (1999 - 2000)

• CO Heater Encon & SCR NOx Control Study – Exxon Benicia Refinery (1992).

• SNCR DeNOx Utility Boiler Design – E xxon Research & Engineering (1993-94)

• ExxonMobil WGS Licensing Support & Pr ocess Development (1996 -2005)Final Staff Report – Part 2 Appe ndix B – Consultants’ Biographies

___________________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 63 November 2, 2010 1990 – 1993 Martech Industries, Inc.

• Process Development for Continuous Poly mer Dissolving Process – Exxon Chemical Polymers Group.

• Operations and Maintenance Consul ting – Exxon, Bayonne Lubricants Plant

• Selective Non-catalytic NOx Reduction Facilit ies Design – Exxon Research & Engineering.

• Lead Designer – Steam Plant Upgrade Project – Exxon, Pittsburgh PA

• Various Process Planning Activities for client ’s worldwide petroleum and petrochemical operations (Exxon Chemical & Exxon Res & Engr).

1984 – 1990 Exxon Chemical Company, Polymers Group

• Elastomer Extrusion Specialist

• Elastomer drying and direct devolatiliz ation process development engineer

• Elastomers manufacturing support

• Process designer & planner for solution and sl urry elastomer manuf acturing facilities – primary focus on product finishing and stripping areas of plant.

1978 – 1984 Exxon Research & Engineering Co.

• CO Boiler Specialist – Design, Trouble shooting & Operations Consulting

• Steam Cracker & Steam Reformed Design

• Fired Heater, Steam Generato r and Incinerator Designs

• Technology Commercialization – Ma terials of Construction, Burn ers, Air Preheat Systems,
Advanced Fired heater and Boiler Cont rols, Energy Conservation Strategies.

• Plant Automation including Artificial In telligence Systems Design and Testing

• Synthetic Fuels Planning, Process Development and Design

• Start-up Support and Plant Troubleshooting.

• Hydrocracker Heater Rebuild.

• Delayed Coking Heat er Troubleshooting

• Delayed Coker Operations Consu lting and Cycle Time Optimization

Process Simulation Tools

• PRO II (Proprietary and Commer cial Thermodynamic Packages)

• HYSYS (Continuous and Batch Simulations)

• HEXTRAN

• Proprietary Plant and Process Evaluation ToolsFinal Staff Report – Part 2 Appe ndix B – Consultants’ Biographies

___________________________________________________________________________________________________ Proposed Amended Regulation XX Part II - 64 November 2, 2010 Education

• Bachelor of Mechanical Engineerin g, Manhattan Colle ge, Bronx NY, 1978

• Master of Mechanical Engineeri ng, Manhattan College, Bronx NY, 1981

Professional Accreditation

• Licensed Professional Engineer – State of New Jersey – GE28615 (1983)

Patents & Publications

• US Patent (1984) Steam Generating Solids Cooler for Spent Shale, Hot Catalyst and Fluid
Coke.

• US Patent (1988) Method for Agglomera ting and Dewatering Polymeric Materials

• US Patent (1991) Centrifugal Solids C ooler for Pneumatic Conveying Systems

• Patent Pending (2007) – Advanced Fired Heater

• Patent Pending (2007) – Zero Plugging Slu rry Distribution Headers and Onstream Descaling System