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Amendment to Missouri Air Permit No. 012005-008 (as amended) to
Account for Condensable Particulate Emissions
Best Available Control Technology Analysis for Total PM10
Prepared For:
Buick Resource Recycling Facility
18594 Hwy KK
Boss MO 65440
Prepared By:
Shell Engineering & Associates, Inc.
2403 West Ash
Columbia MO 65203
August 5, 2015
i
Table of Contents
Table of Contents ................................................................................................. i List of Tables ....................................................................................................... ii List of Figures ..................................................................................................... ii 1.0 Introduction .................................................................................................. 1
1.1 Overview .................................................................................................... 1
1.2 Site Location ............................................................................................... 2
1.3 Process Description ................................................................................... 3
2.0 Condensable Particulate Emission Estimates .......................................... 7
2.1 Overview .................................................................................................... 7
2.2 Main Stack.................................................................................................. 8
2.3 BSN Scrubber .......................................................................................... 11
2.4 Propane Combustion ................................................................................ 11
3.0 Best Available Control Technology .......................................................... 13
3.1 Overview .................................................................................................. 13
3.2 Identification of Potential Control Technologies........................................ 13
3.3 BACT Selection ......................................................................................... 14
3.3.1 Reverberatory Furnace (Main Stack) ................................................. 14
3.3.2 Blast Furnace ..................................................................................... 15
3.3.3 Sweat Furnace ................................................................................... 16
3.3.4 BSN Process ..................................................................................... 18
3.3.5 Propane Combustion ......................................................................... 18
4.0 Conclusion ................................................................................................. 31
Appendix A. RBLC Search Results ................................................................ 33
ii
List of Tables
Table 3-1. Reverberatory Furnace Technology Review ................................ 21
Table 3-2. Blast Furnace Technology Review ............................................... 23
Table 3-3. Dry Scrubber Annual Cost Effectiveness Detail .......................... 26
Table 3-4. Sweat Furnace Technology Review .............................................. 28
Table 3-5. BSN Process Technology Review................................................. 29
Table 3-6. Propane Combustion Technology Review (Dross and Refinery Kettle Heat Stacks) ........................................................................................... 30
Table A-1. RBLC Process Code 82.590, Lead Products and Smelting, January 2004 to Present ................................................................................... 33
Table A-2. RBLC Process Code 13.310, Boiler/Furnace <100 MMBTU/hr, Natural Gas (including propane and LPG), January 2004 to Present ........... 35
List of Figures
Figure 1-1. General Facility Location ............................................................... 5
Figure 1-2. Facility Layout ................................................................................. 6
Figure 3-1. Blast Furnace Least Cost Envelope ............................................ 25
1
1.0 Introduction
1.1 Overview
The Doe Run Company's Buick Resource Recycling Facility (BRRF) is located in
northwest Iron County, Missouri approximately 3 miles east of Boss. The facility
was issued a PSD permit in 2005 (permit no. 012005-008, project no. 2001-10-
058) by the Missouri Department of Natural Resources (MDNR). The purpose of
the permit was to eliminate the annual production limits on the individual furnaces
and increase the facility-wide production to 175,000 ton/yr (lead cast). Special
condition no. 5 to the original permit set an emission limit of 30.57 tons of
filterable and condensable particulate matter less than 10 microns (PM10) from
the installation in any rolling twelve month period.
The permit was amended in 2007 (permit no. 012005-008A, project no. 2007-06-
053). The installation total PM10 limit was replaced with a main stack only
emission limit. Special condition no. 4 to the amended permit set an emission
limit of 9.2 tons of filterable and condensable particulate matter less than 10
microns (PM10) from the main stack (EP-08) in any rolling twelve month period.
According to the permit file, the emission limit was calculated based off a
maximum annual production of 175,000 ton/yr and a controlled PM10 emission
factor of 0.105 lb-PM10/ton-Pb-Produced.
12-month Main Stack PM10 Limit (permit 012005-008A) =
175,000 (ton/yr) * 0.105 (lb-PM10/ton) / 2000 (lb/ton) =
9.2 ton-PM10/yr
The emission factor used in the calculation above is representative of only the
filterable fraction of the PM10 emissions which account for approximately 15% of
the total PM10 (filterable + condensable). Special condition no. 4 to the
amended permit specifically states that the annual emission limit is based on
summation of the filterable and condensable components; however, the emission
factor used to develop the limit includes only the filterable fraction.
2
As specified in the permit, subsequent monitoring associated with special
condition no. 4 was based on stack test derived emission factors. The stack test
method used to develop the emission factors was method 201A (filterable PM10
only). It should be noted that the use of method 201A is believed to be fully
supported by the permit and was approved in the stack test protocols.
Furthermore, MDNR personnel has reviewed the permit file and determined that
it was the permit writer's intention that the limit was specific to the filterable
fraction and did not intend for the special condition to include the condensable
particulates. This has led to confusion in subsequent permitting.
Because condensable emissions were not directly considered as part of the
review associated with permit 012005-008, the MDNR has requested a control
technology review to ensure that the condensable controls employed by the
facility are considered Best Available Control Technology (BACT). It should be
noted that at the time the permit was originally issued in January 2005, PM10
BACT limits were exclusively specified for the filterable component only.
The MDNR specifically requested a review of each emission unit permitted under
012005-008 to determine if it is a source of condensable particulate. Next,
MDNR requested that a technology review be completed for each source of
condensable particulate to determine if existing control technologies in place
constitute BACT for total PM10 or if additional technologies are required pursuant
to the PSD regulations.
The purpose of this report is to document the control technology review for
sources of condensable particulate permitted under Missouri air construction
permit no. 012005-008.
1.2 Site Location
The facility is located approximately three miles east of Boss, MO in northwest
Iron County. The facility is approximately 90 miles southwest of St. Louis and
3
125 miles east of Springfield. The UTM coordinates of the facility referenced to
the 1983 North American Datum, Zone 15 are 664.8 km east and 4167.1 km
north. The elevation in the facility ranges from approximately 1,360 to 1,440 ft-
asl.
A map showing the general location of the facility has been provided as Figure 1-
1. A map showing the facility layout has been provided as Figure 1-2.
1.3 Process Description
The BRRF's secondary lead production operation is divided into three major
areas:
1. Raw Material Preparation & Separation
2. Smelting
3. Refining
The facility receives raw material in the form of large industrial batteries, small
automotive batteries, coke, limestone, silica, glass, scrap steel, scrap lead metal
and other lead bearing materials contained in various container configurations.
Batteries are shredded and drained . The shredded batteries are then sent
through a hydro-separation process which separates out the paste and plastic
from the posts, separators, grids and sediment.
Plastic components are washed and sold to be made into new battery cases.
The remaining battery parts, except acid and plastic, go to the reverberatory or
blast furnace. These two furnaces work together to recycle the lead containing
materials into lead bullion, which, after refining, can then be used by industry
again.
4
Lead bearing scrap is sweated in two propane-fired reclamation (sweat) furnaces
to separate lead from metals with higher melting points and non-metal
contaminants. This lead bullion is tapped from the reclamation furnaces for
further processing in the refinery.
Crude lead from the blast furnace, reverberatory furnace, sweat furnaces, and
remelt scrap is refined by softening, alloying and oxidation processes. These
processes are performed in the refinery in batch type kettles in order to achieve
the degree of purity or alloy type requested by the customer. After refining,
finished lead is cast into various sizes and shapes according to customer
specifications.
After casting, the product is then stored to allow final cooling and then is loaded
and shipped to the customer.
5
Figure 1-1. General Facility Location
4000
4200
4400
200 400 600 800
No
rth
ing
(UT
M-k
m)
Easting (UTM-km)
Kansas City
Springfield
St. Louis
Buick Resource Recycling Facility, LLCBoss, MO
6
Figure 1-2. Facility Layout
4166561
4166761
4166961
4167161
664311 664511 664711 664911 665111
No
rth
ing
(UT
M-m
)
Easting (UTM-m)
Battery Bunker
Paste Storage
Ref inery
Reverberatory Furnace
Main Stack
Blast Furnace
Blast Furnace Feed Storage
Covered Storage
Change House
Administration Building
Hammermill
Hydro Separator
Warehouse
Facility Boundary (Hwy KK)
7
2.0 Condensable Particulate Emission Estimates
2.1 Overview
A summary of particulate sources included in permit 012005-008 has been
provided below.
Point No. Source Description Condensable Emissions?
(Yes/No) Comment
8
Main Stack (reverberatory furnace, blast furnace,
sweat furnaces, refinery, and building ventilation)
Yes
16 BSN Scrubber Yes
18 Crystallizer No Emission point has been
eliminated.
19 Sodium Carbonate Surge
Bin Baghouse No
Emission point has been eliminated
21 Crystallizer Boiler Yes Emission point has been
eliminated.
22-23 Dross Kettles Yes
24-28 Refinery Kettles Yes
31A Drum Shredder Feed
Hopper No
Building ventilation baghouse operating near
ambient. No process combustion source
present.
31B Drum Shredder Hygiene
Baghouse No
Building ventilation baghouse operating near
ambient. No process combustion source
present.
31C Drum Shredder Main
Baghouse No
Building ventilation baghouse operating near
ambient. No process combustion source
present.
32 Laboratory Baghouse No
33 Changehouse Boiler Yes
Condensable PM emissions not considered for BACT because source
not modified for permit 012005-008
34 Main Shop Forge Yes Emission point has been
eliminated.
71 Reverb. Furnace Hygiene
Baghouse No
Building ventilation baghouse operating near
ambient
72 Rotary (Refinery North)
Furnace Baghouse No
Building ventilation baghouse operating near
ambient
8
Point No. Source Description Condensable Emissions?
(Yes/No) Comment
73 Sweat Furnace Baghouse No Building ventilation
baghouse operating near ambient
85 Wood Boiler Yes Emission point has been
eliminated.
57 Silo No Emission point has been
eliminated.
58 Material Blender No Emission point has been
eliminated.
10 Blast Furnace Building
Fugitives No
Building enclosed and evacuated to baghouse
near ambient
11 Dross Plant/Reverb.
Furnace Building Fugitives No
Building enclosed and evacuated to baghouse
near ambient
12 Refinery Building Fugitives No Building enclosed and
evacuated to baghouse near ambient
37 Resuspension No
74-79 Haul Roads No
13 Open Storage Fugitives No
2.2 Main Stack
The main stack (EP-8) is a source of filterable, inorganic and organic
condensable particulate matter. The primary sources routed to the main stack
are the blast furnace and the reverberatory furnace. The main stack also
receives process gases from the two sweat furnaces and refinery along with a
large volume of building ventilation air. The main stack was tested on 10/3/2012
and had a total PM10 (filterable and condensable) emission factor of 0.85 lb/ton
of lead produced. The speciation for the main stack was 8.5% filterable, 20.6%
organic CPM, and 70.9% inorganic CPM. The reverberatory furnace was tested
on 9/26-27/2012 and accounted for 13.3% of the main stack emissions. The
speciation for the reverberatory furnace was 26.9% filterable, 14.9% organic
CPM, and 58.2% inorganic CPM. The emissions from the blast furnace, sweat
furnaces, refinery and building ventilation were calculated by subtracting the
reverberatory furnace emissions from the total emissions emitted from the main
stack. The calculations have been summarized below:
9
Source Particulate Matter Type
Existing Control Device
Controlled PM10 Emission
Factor (lb/ton)
Fraction of Subtotal (%)
Reverberatory Furnace
Filterable Baghouse 0.0303 26.88
Organic Condensable
Thermal Oxidizer 0.0168 14.93
Inorganic Condensable
Dry Scrubber with Fabric Filtration
0.0656 58.18
Subtotal: 0.1128 100.00
Blast Furnace, Sweat Furnace,
Refinery, Building
Ventilation
Filterable Baghouse 0.0420 5.70
Organic Condensable
None 0.1583 21.47
Inorganic Condensable
None 0.5370 72.83
Subtotal: 0.7374 100.00
Main Stack (EP-08)
Filterable
Refer to Above
0.0723 8.51
Organic Condensable
0.1752 20.60
Inorganic Condensable
0.6027 70.89
Total: 0.85 100.00
A. Total controlled PM10 emission factor from 10/3/2012 stack test = 0.85 lb/ton (lead produced)
B. 13.3% of total PM10 assumed from reverb. furnace based on 9/2012 scrubber stack test
C. Main stack speciation from 10/3/2012 stack test (Filt 8.5%, OCPM 20.6%, ICPM 70.9%)
D. Reverb. Furnace speciation from 9/26-27/2012 dry scrubber stack test
(Filt 26.9%, OCPM 14.9%, ICPM 58.2%)
E. Blast furnace, etc. emissions calculated by difference.
The potential annual PM10 emissions from the reverberatory furnace were then
estimated using the emission factor from the stack test and a maximum annual
lead production rate of 175,000 ton lead cast/yr:
Potential Annual PM10 Emissions (Reverb) =
175,000 (ton lead cast/yr) * 0.1128 (lb/ton) / 2000 (lb/ton) =
9.87 ton/yr
The potential annual PM10 emissions from the blast furnace, sweat furnaces,
refinery, and building ventilation were then estimated using the emission factor
10
from the stack test and a maximum annual lead production rate of 175,000 ton
lead cast/yr:
Potential Annual PM10 Emissions (Blast Furnace and Sweat Furnace) =
175,000 (ton lead cast/yr) * 0.7374 (lb/ton) / 2000 (lb/ton) =
64.52 ton/yr
The blast furnace and sweat furnace emissions were then apportioned based on
the average production rates from the 2013 and 2014 calendar years:
2014
(ton/yr) 2013
(ton/yr)
2013-14 Average (ton/yr)
Fraction of Total (%)
Blast Furnace Castable Lead Production
41242 42557 41900 91.71
Sweat Furnace Castable Lead Production
5327 2244 3786 8.29
Total 46569 44801 45685 100
Potential Annual PM10 Emissions (Blast Furnace) =
64.52 (ton/yr) * 0.9171 =
59.17 ton/yr
Potential Annual PM10 Emissions (Sweat Furnace) =
64.52 (ton/yr) * 0.0829 =
5.35 ton/yr
The reverberatory furnace was stack tested as a condition of Missouri Section (5)
permit no. 062011-004 in September 2012. Due to the installation of a thermal
oxidizer, particulate baghouse, and dry scrubber with fabric filtration on the
reverberatory furnace, the blast furnace represents the largest remaining source
of PM10 emissions. Approximately 87% of the PM10 emissions from the main
stack come from the particulate baghouse used to control the process emissions
from the blast furnace. In addition to the blast furnace, the baghouse also
ventilates two sweat furnaces and provides refinery kettle and building
ventilation.
11
The main stack was tested for condensable PM again in December 2013. The
condensable PM emissions from the main stack were approximately 70% less
than the October 2012 test. The higher of the two tests was used as the basis
for the BACT economic analysis.
2.3 BSN Scrubber
The BSN scrubber (EP-16) (formerly referred to as the BDC scrubber) is a
source of PM10 due to dust and acid mist emissions from the battery breaking
process. The maximum hourly filterable PM10 emissions for the scrubber are
0.283 lb/hr, which corresponds to a potential annual emission rate of 1.24 ton/yr.
Stack test data is not available for this source and an emission factor search did
not yield any data for condensable PM. It is known that sulfuric acid mist will
cause visible opacity at concentrations above 5 ppm. Facility personnel have not
witnessed visible emissions, besides water vapor, from this source. Therefore,
condensable emissions were calculated assuming a conservative H2SO4
concentration of 5 ppmv. At a standard flow rate of 30,000 scfm and 5 ppmv
H2SO4, the ideal gas model gives an hourly emission rate of 2.29 lb/hr. This
equates to 10.03 ton/yr at 8,760 hr/yr continuous production.
The total PM10 emissions are equal to 11.27 ton/yr (1.24 filterable + 10.03
condensable).
2.4 Propane Combustion
PM10 emissions from the combustion of propane were estimated from the
source specific MHDR and an emission factor of 1.106 lb/Mgal (FIRE, SCC
10201002). Forty-six percent (46%) of the total PM10 is condensable. The
emissions for each source have been summarized below.
12
Emission Point No.
Source Description MHDR
(Mgal/hr)
Emission Factor
(lb/Mgal)
Hourly Emissions
(lb/hr)
Potential Annual
Emissions (ton/yr)
EP-22 Dross Kettles 0.0994 1.106 0.1100 0.48
EP-23 Dross Kettles 0.1492 1.106 0.1650 0.72
EP-24 Refinery Kettles 0.1271 1.106 0.1405 0.62
EP-25 Refinery Kettles 0.1271 1.106 0.1405 0.62
EP-26 Refinery Kettles 0.1271 1.106 0.1405 0.62
EP-27 Refinery Kettles 0.0994 1.106 0.1100 0.48
EP-28 Refinery Kettles 0.0928 1.106 0.1027 0.45
First the maximum hourly emissions were calculated from the MHDR and the
emission factor. A sample calculation for one of the dross kettles (EP-22) has
been provided below.
Hourly PM10 Emissions (EP-22) =
0.0994 (Mgal/hr) * 1.106 (lb/Mgal) =
0.11 lb/hr
The potential annual emissions were then calculated from the hourly emissions
assuming a conservative 8,760 hr/yr of continuous operation.
Potential Annual PM10 Emissions (EP-22) =
0.11 (lb/hr) / 2000 (lb/ton) * 8760 (hr/yr) =
0.48 ton/yr
A crystallizer boiler (EP-21) and a main shop forge (EP-34) were included in the
original analysis associated with permit 012005-008, but are no longer at the
facility.
13
3.0 Best Available Control Technology
3.1 Overview
The federal PSD program requires that all major stationary sources apply BACT
to each regulated NSR pollutant that has the potential to be emitted in significant
quantities. The facility is defined as a major stationary source in accordance with
the PSD regulations.
The original BACT analyses for permit 012005-008 was developed by IES
Engineers and followed the procedures outlined in the USEPA, "New Source
Review Workshop Manual", Office of Air Quality Planning and Standards, Draft,
October 1990. The manual describes a five step "top down" approach:
1. Identify all potential control technologies,
2. Eliminate technically infeasible options,
3. Rank remaining technologies by control effectiveness,
4. Eliminate control options based on "collateral impacts" of the control
option (for example, cost effectiveness), and
5. Select BACT.
3.2 Identification of Potential Control Technologies
Potential control technologies for PM10 have been listed and ranked by filterable
control efficiency below (total control efficiency is source specific and dependent
upon the filterable fraction).
A thermal oxidizer and dry scrubber with fabric filter were installed on the
reverberatory furnace in 2011-2012. At the time permit 012005-008 was issued
in January 2005, the scrubbing technology was not cost effective for removal of
condensable PM and the MDNR determined that the up-front desulfurization
process in place at that time was BACT.
Baghouses are considered technically feasible for condensable PM removal and
have been installed on all significant sources of PM10. Additionally, the
14
secondary lead NESHAP requires that the building containing the blast furnace,
reverberatory furnace, sweat furnaces, and refinery to be ventilated to a
baghouse at sufficient volumetric flow to achieve a negative pressure differential
on the building.
Rank (based on filterable control)
Control Technology
Assumed Control Efficiency (%)
Filterable PM ICPM OCPM
1 Baghouse 99.7 0 0
2 Dry scrubber 99 95 0
3 Wet ESP 99 88 0
4 Dry ESP 99 29 0
5 Wet scrubber 95 57 0
6 Cyclone 80 0 0
7 Thermal Oxidizer 0 0 98
8 Catalytic Oxidizer
0 0 98
A. Baghouse filterable control efficiency (99.69%) from MO air permit 012005-008, "Review of
Application for Authority to Construct and Operate", Table 7.
B. Inorganic CPM control efficiencies adapted from EPRI, "Estimating Total Sulfuric Acid
Emissions from Stationary Power Plants", March 2012.
C. Thermal oxidizer organic CPM control efficiency from Air Pollution Control Technology
Fact Sheet, Thermal Incinerator
3.3 BACT Selection
3.3.1 Reverberatory Furnace (Main Stack)
A summary of the control technologies examined for control of PM10 emissions
from the reverberatory furnace has been provided as Table 3-1.
15
The reverberatory furnace emits PM10. A thermal oxidizer and dry scrubber with
fabric filter were installed on the reverberatory furnace in 2011-2012 to reduce
SO2 emissions. The highest level control technology for PM10 is already
utilized. As stated above, the dry scrubber with fabric filter would not have been
cost effective for PM10 and MDNR permitted the former upfront feed
desulfurization as the appropriate BACT control.
3.3.2 Blast Furnace
A summary of the control technologies examined for control of PM10 emissions
from the blast furnace has been provided as Table 3-2. The least cost envelope
was plotted and provided as Figure 3-1. The least cost analysis identified four
(4) control technologies for additional analysis:
1. Dry scrubber and thermal oxidizer following existing baghouse
2. Dry scrubber following existing baghouse
3. Wet ESP following existing baghouse
4. Thermal Oxidizer following existing baghouse
An annualized cost of $21.29/scfm was calculated for the dry scrubber and
thermal oxidizer following existing baghouse. This was estimated based on the
escalated capital costs from the reverberatory furnace dry scrubber as provided
by Doe Run plus an additional $8/scfm for the thermal oxidizer which
corresponds to the low range of values reported by EPA in their Air Pollution
Technology Fact Sheet. A detail of the annual cost calculations for the dry
scrubber have has been provided as Table 3-3. The annualized cost
effectiveness for the dry scrubber and thermal oxidizer following the existing
baghouse is $75,456/ton (200,000 scfm and 56.43 ton/yr reduction ) of PM10
reduced. The dry scrubber and thermal oxidizer are not economically feasible.
An annualized cost of $13.29/scfm was calculated for the dry scrubber following
the existing baghouse. This was estimated based on the escalated capital costs
from the reverberatory furnace dry scrubber. The annualized cost effectiveness
16
for the dry scrubber and thermal oxidizer following the existing baghouse is
$60,437/ton (200,000 scfm and 43.98 ton/yr reduction ) of PM10 reduced. The
dry scrubber is not economically feasible.
An annualized cost of $12/scfm was used for the wet ESP, which was estimated
based on the low range of values reported by EPA in their Air Pollution
Technology Fact Sheet. The annualized cost effectiveness for the wet ESP
following the existing baghouse is $58,594/ton (200,000 scfm and 40.96 ton/yr
reduction ) of PM10 reduced. The wet ESP is not economically feasible.
An annualized cost of $8/scfm was used for thermal oxidizer, which was
estimated based on the low range of values reported by EPA in their Air Pollution
Technology Fact Sheet.. The annualized cost effectiveness for the thermal
oxidizer following the existing baghouse is $128,514/ton (200,000 scfm and
12.45 ton/yr reduction ) of PM10 reduced. The thermal oxidizer is not
economically feasible.
A Baghouse was selected as BACT for the control of PM10 emitted from the
blast furnace.
3.3.3 Sweat Furnace
A summary of the control technologies examined for control of PM10 emissions
from the sweat furnace has been provided as Table 3-4. Four (4) control
technologies were analyzed:
1. Dry scrubber following existing baghouse and thermal oxidizer
2. Wet ESP following existing baghouse and thermal oxidizer
3. Wet scrubber following existing baghouse and thermal oxidizer
4. Dry ESP following existing baghouse and thermal oxidizer
An annualized cost of $13.29/scfm was calculated for the dry scrubber following
the existing baghouse and thermal oxidizer. This was estimated based on the
17
escalated capital costs from the reverberatory furnace dry scrubber as provided
by Doe Run. A detail of the annual cost calculations for the dry scrubber have
has been provided as Table 3-3. The annualized cost effectiveness for the dry
scrubber following the existing baghouse and thermal oxidizer is $66,952/ton
(20,000 scfm and 3.97 ton/yr reduction ) of PM10 reduced. The dry scrubber is
not economically feasible.
An annualized cost of $12/scfm was used for the wet ESP, which was estimated
based on the low range of values reported by EPA in their Air Pollution
Technology Fact Sheet. The annualized cost effectiveness for the wet ESP
following the existing baghouse and thermal oxidizer is $64,865/ton (20,000 scfm
and 3.70 ton/yr reduction ) of PM10 reduced. The wet ESP is not economically
feasible.
An annualized cost of $17/scfm was used for the wet scrubber, which was
estimated based on the low range of values reported by EPA in their Air Pollution
Technology Fact Sheet. The annualized cost effectiveness for the wet scrubber
following the existing baghouse and thermal oxidizer is $139,918/ton (20,000
scfm and 2.43 ton/yr reduction ) of PM10 reduced. The wet scrubber is not
economically feasible.
An annualized cost of $9/scfm was used for the dry ESP, which was estimated
based on the low range of values reported by EPA in their Air Pollution
Technology Fact Sheet. The annualized cost effectiveness for the dry ESP
following the existing baghouse and thermal oxidizer is $128,571/ton (20,000
scfm and 1.40 ton/yr reduction ) of PM10 reduced. The dry ESP is not
economically feasible.
A Baghouse and thermal oxidizer was selected as BACT for the control of PM10
emitted from the sweat furnaces.
18
3.3.4 BSN Process
A summary of the control technologies examined for control of PM10 emissions
from the BSN process has been provided as Table 3-5.
The BSN scrubber provides PM10 control associated with acid mist and dust
emissions from the battery breaking and separation processes. It is technically
feasible to add a wet ESP following the existing wet scrubber. An annualized cost
of $9.00/scfm was used for the wet ESP, which corresponds to the low range of
values reported by EPA in their Air Pollution Technology Fact Sheet. The
annualized cost effectiveness for the wet ESP is $27,163/ton (30,000 scfm and
9.94 ton/yr reduction) of PM10 reduced. The wet ESP is not economically
feasible.
Fabric filters (baghouses), dry scrubbing, and dry ESPs would not be technically
feasible due to the high acid loadings from the battery breaking and separation
process. A thermal oxidizer was not evaluated due to the low level of organic
emissions anticipated from this process.
A wet scrubber was selected as BACT for the BSN process. A wet scrubber is
currently used to control emissions from the BSN process.
3.3.5 Propane Combustion
A summary of the control technologies examined for control of PM10 emissions
from propane combustion has been provided as Table 3-6. Six (6) control
technologies were analyzed:
1. Dry scrubber
2. Wet ESP
3. Dry ESP
4. Wet Scrubber
5. Baghouse
19
6. Thermal Oxidizer
An annualized cost of $13.29/scfm was calculated for the dry scrubber. This was
estimated based on the escalated capital costs from the reverberatory furnace
dry scrubber as provided by Doe Run. A detail of the annual cost calculations for
the dry scrubber have has been provided as Table 3-3. The annualized cost
effectiveness for the dry scrubber is $60,220/ton (13.5 MMBTU/hr, 2,900 scfm
and 0.64 ton/yr reduction) of PM10 reduced. The dry scrubber is not
economically feasible.
An annualized cost of $12/scfm was used for the wet ESP, which was estimated
based on the low range of values reported by EPA in their Air Pollution
Technology Fact Sheet. The annualized cost effectiveness for the wet ESP is
$56,129/ton (13.5 MMBTU/hr, 2900 scfm and 0.62 ton/yr reduction) of PM10
reduced. The wet ESP is not economically feasible.
An annualized cost of $9/scfm was used for the dry ESP, which was estimated
based on the low range of values reported by EPA in their Air Pollution
Technology Fact Sheet. The annualized cost effectiveness for the dry ESP is
$56,739/ton (13.5 MMBTU/hr, 2900 scfm and 0.46 ton/yr reduction) of PM10
reduced. The dry ESP is not economically feasible.
An annualized cost of $17/scfm was used for the wet scrubber, which was
estimated based on the low range of values reported by EPA in their Air Pollution
Technology Fact Sheet. The annualized cost effectiveness for the wet scrubber
is $94,808/ton (13.5 MMBTU/hr, 2900 scfm and 0.52 ton/yr reduction) of PM10
reduced. The wet scrubber is not economically feasible.
An annualized cost of $6/scfm was used for the baghouse, which was estimated
based on the low range of values reported by EPA in their Air Pollution
Technology Fact Sheet. The annualized cost effectiveness for the baghouse is
20
$44,615/ton (13.5 MMBTU/hr, 2900 scfm and 0.39 ton/yr reduction) of PM10
reduced. The baghouse is not economically feasible.
An annualized cost of $8/scfm was used for the thermal oxidizer, which was
estimated based on the low range of values reported by EPA in their Air Pollution
Technology Fact Sheet. The annualized cost effectiveness for the thermal
oxidizer is $386,667/ton (13.5 MMBTU/hr, 2900 scfm and 0.06 ton/yr reduction)
of PM10 reduced. The thermal oxidizer is not economically feasible.
For small propane burners of the sizes analyzed, no documented case could be
found where add-on controls have been installed.
Based on the information presented above, good combustion practices were
selected as BACT.
21
Table 3-1. Reverberatory Furnace Technology Review
Rank (Based on
Overall Control)
Control Technology
Assumed Control Efficiency (%) Unitized Annualized
Cost ($/scfm-yr)
Total Annualized Cost ($/yr)
Emission Reduction
(ton/yr) Filterable PM
ICPM OCPM Overall
1
Dry scrubber and thermal oxidizer following existing
baghouse
90 95 98 94.10
2
Wet ESP and thermal oxidizer following existing
baghouse
90 88 98 90.03
3 Dry scrubber
following existing baghouse
90 95 0 79.47
4 Wet ESP following existing baghouse
90 88 0 75.40
5
Wet scrubber and thermal oxidizer following existing
baghouse
70 57 98 66.62
6
Dry ESP and thermal oxidizer following existing
baghouse
90 29 98 55.70
7 Wet scrubber
following existing baghouse
70 57 0 51.98
22
8 Dry ESP following existing baghouse
90 29 0 41.07
9 Thermal Oxidizer following existing
baghouse 0 0 98 14.64
10 Existing Baghouse Base control
A. Inorganic CPM control efficiencies adapted from EPRI, "Estimating Total Sulfuric Acid Emissions from Stationary
Power Plants", March 2012.
B. Thermal oxidizer organic CPM control efficiency from Air Pollution Control Technology Fact Sheet, Thermal Incinerator
C. Low range of filterable control used due to following existing high efficiency baghouse (low loading)
D. Unitized annualized costs from associated Air Pollution Control Technology Fact Sheets, except dry scrubbing
E. Dry scrubber annualized cost escalated from cost data for reverb. Furnace dry scrubber
23
Table 3-2. Blast Furnace Technology Review
Rank Control
Technology
Assumed Control Efficiency (%) Unitized Annualized
Cost ($/scfm-yr)
Cost of PM10
Removed ($/ton)
Emission Reduction
(ton/yr) Filterable PM
ICPM OCPM Overall
1
Dry scrubber and thermal oxidizer following existing
baghouse
90 95 98 95.36 21.29 75456 56.43
2
Wet ESP and thermal oxidizer following existing
baghouse
90 88 98 90.26 20 74892 53.41
3 Dry scrubber
following existing baghouse
90 95 0 74.32 13.29 60437 43.98
4 Wet ESP following existing baghouse
90 88 0 69.22 12 58594 40.96
5
Wet scrubber and thermal oxidizer following existing
baghouse
70 57 98 66.54 25 126968 39.38
6
Dry ESP and thermal oxidizer following existing
baghouse
90 29 98 47.29 17 121515 27.98
7 Wet scrubber
following existing baghouse
70 57 0 45.50 17 126253 26.93
24
8 Dry ESP following existing baghouse
90 29 0 26.25 9 115905 15.53
9 Thermal Oxidizer following existing
baghouse 0 0 98 21.04 8 128514 12.45
10 Existing Baghouse Base control
A. Inorganic CPM control efficiencies adapted from EPRI, "Estimating Total Sulfuric Acid Emissions from Stationary
Power Plants", March 2012.
B. Thermal oxidizer organic CPM control efficiency from Air Pollution Control Technology Fact Sheet, Thermal Incinerator
C. Low range of filterable control used due to following existing high efficiency baghouse (low loading)
D. Unitized annualized costs from associated Air Pollution Control Technology Fact Sheets, except dry scrubbing
E. Dry scrubber annualized cost escalated from cost data for reverb. Furnace dry scrubber
25
Figure 3-1. Blast Furnace Least Cost Envelope
0
1000000
2000000
3000000
4000000
5000000
6000000
0.00 10.00 20.00 30.00 40.00 50.00 60.00
Tota
l An
nu
aliz
ed
Co
st (
$/
yr)
Emission Reduction (ton/yr)
Least Cost Envelope
Inferior Controls
1
3
9
4
26
Table 3-3. Dry Scrubber Annual Cost Effectiveness Detail
Cost Item Cost
DIRECT ANNUAL COSTS
Operating Labor
Operator 2 hr/day 30.00 $/hr $21,900
Supervisor 15 % of operator $3,285
Operating Materials -
Maintenance
Labor 2 hr/day 30.00 $/hr $21,900
Material 100 of maint. labor $21,900
Bag Replacement
591 Bags 79.50 $/Bag CRF = 0.4021 $18,890
Utilities
Propane Mgal/yr $/Mgal $0
Electricity 4,918,840 kW-hr/yr 0.05 $/kW-hr $245,942
Lime 488 ton/yr 100.00 $/ton $48,800
INDIRECT ANNUAL COSTS, IC
Overhead 60 % of sum of operating labor and mtrl and $41,391
maintenance labor and materials.
Administrative Charges 2 % of TCI $283,863
Property Taxes 1 % of TCI $141,931
Insurance 1 % of TCI $141,931
Capital Recovery TCI $ 14,193,148 CRF = 0.1175 $1,667,122
TOTAL ANNUAL COST 13.29 $/scfm $2,658,856
A. Adapted from EPA Air Pollution Control Cost Manual (APCCM)
27
B. Design Parameters
Standard Flow = 200000 scfm
Actual Flow = 221591 acfm
Stack Temperature = 125 F
C. Capital Cost
Reverb. Scrubber TCI 7,300,000 $ (June 2011) @ 75000 acfm
Dry Scrubber TCI 13,983,544 $ (June 2011), TCI=TCIBase * (Flow/FlowBase)0.6
Escalated based on Fabricated structural metal mfg PPI
Jun-11 PPI 140.1 Unitless; US Bureau of Labor Statistics
Feb-14 PPI 142.2 Unitless; US Bureau of Labor Statistics (most recent)
Dry Scrubber TCI 14,193,148 $ (Current)
D. Electricity consumption
PF = 0.000181*Q*∆P*Θ
PF = Fan Power (kW-hr/yr) = 4918840 kW-hr/yr
Q =actual volumetric flow (acfm) = 221591 acfm
∆P = Pressure drop (in. H2O) = 14 in H2O, for dry scrubber
Θ = Annual operation (hr/yr) = 8760 hr/yr
E. Capital recovery factor
Dry Scrubber
Lifetime 20 years
Interest 10 %
CRF 0.1175
Bags
Lifetime 3 years
Interest 10 %
CRF 0.4021
28
Table 3-4. Sweat Furnace Technology Review
Rank Control
Technology
Assumed Control Efficiency (%) Unitized Annualized
Cost ($/scfm-yr)
Cost of PM10
Removed ($/ton)
Emission Reduction
(ton/yr) Filterable PM
ICPM OCPM Overall
1
Dry scrubber following existing
baghouse and thermal oxidizer
90 95 0 74.32 13.29 66952 3.97
2
Wet ESP following existing baghouse
and thermal oxidizer
90 88 0 69.22 12 64865 3.70
3
Wet scrubber following existing
baghouse and thermal oxidizer
70 57 0 45.50 17 139918 2.43
4
Dry ESP following existing baghouse
and thermal oxidizer
90 29 0 26.25 9 128571 1.40
5 Existing Baghouse
and Thermal Oxidizer
Base control
A. Inorganic CPM control efficiencies adapted from EPRI, "Estimating Total Sulfuric Acid Emissions from Stationary
Power Plants", March 2012.
B. Low range of filterable control used due to following existing high efficiency baghouse (low loading)
C. Unitized annualized costs from associated Air Pollution Control Technology Fact Sheets, except dry scrubbing
D. Dry scrubber annualized cost escalated from cost data for reverb. Furnace dry scrubber
29
Table 3-5. BSN Process Technology Review
Rank Control
Technology
Assumed Control Efficiency (%) Unitized Annualized
Cost ($/scfm-yr)
Cost of PM10
Removed ($/ton)
Emission Reduction
(ton/yr) Filterable PM
ICPM OCPM Overall
1 Wet ESP following
existing wet scrubber
90 88 0 88.22 9 27163 9.94
2 Existing wet
scrubber Base control
A. Inorganic CPM control efficiencies adapted from EPRI, "Estimating Total Sulfuric Acid Emissions from Stationary
Power Plants", March 2012.
B. Low range of filterable control used due to following existing scrubber (low loading)
C. Unitized annualized costs from associated Air Pollution Control Technology Fact Sheets
30
Table 3-6. Propane Combustion Technology Review (Dross and Refinery Kettle Heat Stacks)
Rank Control
Technology
Assumed Control Efficiency (%) Unitized Annualized
Cost ($/scfm-yr)
Cost of PM10
Removed ($/ton)
Emission Reduction
(ton/yr) Filterable PM10
Inorganic CPM
Organic CPM
Overall
1 Dry scrubber 99 95 0 88.48 13.29 60220 0.64
2 Wet ESP 99 88 0 85.92 12 56129 0.62
3 Dry ESP 99 29 0 64.32 9 56739 0.46
4 Wet scrubber 95 57 0 72.40 17 94808 0.52
5 Baghouse 99.7 0 0 54.09 6 44615 0.39
6 Thermal Oxidizer 0 0 98 8.97 8 386667 0.06
A. Inorganic CPM control efficiencies adapted from EPRI, "Estimating Total Sulfuric Acid Emissions from Stationary
Power Plants", March 2012.
B. Thermal oxidizer organic CPM control efficiency from Air Pollution Control Technology Fact Sheet, Thermal Incinerator
C. Low range of filterable control used due to following existing high efficiency baghouse (low loading)
D. Unitized annualized costs from associated Air Pollution Control Technology Fact Sheets, except dry scrubbing
E. Dry scrubber annualized cost escalated from cost data for reverb. Furnace dry scrubber
F. CPM assumed 80% inorganic and 20% organic
31
4.0 Conclusion
The Doe Run Company's Buick Resource Recycling Facility (BRRF) is located in
northwest Iron County, Missouri approximately 3 miles east of Boss. The facility
was issued a PSD permit in 2005 (permit no. 012005-008, project no. 2001-10-
058) by the Missouri Department of Natural Resources (MDNR).
Since condensable emissions were not directly considered as part of the review
associated with permit 012005-008, the MDNR has requested a control
technology review for total PM10 (including condensable).
Each source permitted under 012005-008 was analyzed to determine if it was a
source of condensable PM. An estimate of the CPM was then made for each
applicable source and added to the associated filterable emissions.
A control technology review was then completed for each source according to the
five step BACT "top down" approach:
1. Identify all potential control technologies,
2. Eliminate technically infeasible options,
3. Rank remaining technologies by control effectiveness,
4. Eliminate control options based on "collateral impacts" of the control
option (for example, cost effectiveness), and
5. Select BACT.
A summary of the pollution controls or work practices that are in place that meet
or exceed BACT are provided below.
Point No. Source Description Pollution Control in Place
EP-8 Reverberatory Furnace Thermal Oxidizer and Dry Scrubber with Fabric Filter
EP-8 Blast Furnace Baghouses
EP-8 Sweat Furnaces Baghouse and Thermal
Oxidizer
EP-16 BSN Process Wet Scrubber
32
Point No. Source Description Pollution Control in Place
EP-22 to 23 Dross Kettles Good Combustion
Practices
EP-24 to 28 Refinery Kettles Good Combustion
Practices
The controls and operational requirements listed above are federally enforceable
as set forth in construction permit conditions or other federally enforceable
regulations or documents (i.e., SIP Consent Judgments). As such, no additional
permit conditions are needed in addition to the Amendment for Missouri Air
Permit No. 062011-004 Special Condition 2.F as set forth in the January 13,
2014 submittal to the agency.
33
Appendix A. RBLC Search Results
Table A-1. RBLC Process Code 82.590, Lead Products and Smelting, January 2004 to Present
RBLC ID Facility Name State Permit
No.
Permit Issue Date
Process Name Pollutant Test
Method BACT Limit
FL-0320 EFT LEAD-ACID
BATTERY RECYCLING FACILITY
FL
PSD-FL-404
(0570057-020-AC)
9/22/2009 Battery breaking area
Particulate matter,
total (TPM)
Method 5 and 29
0.005 gr/dscf
FL-0320 EFT LEAD-ACID
BATTERY RECYCLING FACILITY
FL
PSD-FL-404
(0570057-020-AC)
9/22/2009 Lead Smelting
Particulate matter,
total (TPM)
Method 5 0.005 gr/dscf
FL-0320 EFT LEAD-ACID
BATTERY RECYCLING FACILITY
FL
PSD-FL-404
(0570057-020-AC)
9/22/2009 Furnace Tapping,
Charging and Lead Refining
Particulate matter,
total (TPM)
Method 5
0.005 gr/dscf
and 2.68 lb/hr
FL-0320 EFT LEAD-ACID
BATTERY RECYCLING FACILITY
FL
PSD-FL-404
(0570057-020-AC)
9/22/2009 Soda Ash Silos
Particulate matter,
total (TPM)
Method 5 0.005 gr/dscf
FL-0320 EFT LEAD-ACID
BATTERY RECYCLING FACILITY
FL
PSD-FL-404
(0570057-020-AC)
9/22/2009 Building ventilation
Particulate matter,
total (TPM)
Method 5
0.005 gr/dscf
and 36.6 lb/hr
FL-0320 EFT LEAD-ACID
BATTERY RECYCLING FACILITY
FL
PSD-FL-404
(0570057-020-AC)
9/22/2009 Plastic Pellet Silo
Particulate matter,
total (TPM)
Method 5 0.001 gr/dscf
34
RBLC ID Facility Name State Permit
No.
Permit Issue Date
Process Name Pollutant Test
Method BACT Limit
FL-0320 EFT LEAD-ACID
BATTERY RECYCLING FACILITY
FL
PSD-FL-404
(0570057-020-AC)
9/22/2009 Emergency Generator
Particulate matter,
total (TPM)
Mfg. Certification
0.12 g/hp-hr
35
Table A-2. RBLC Process Code 13.310, Boiler/Furnace <100 MMBTU/hr, Natural Gas (including propane and LPG),
January 2004 to Present
RBLC ID State Permit No. Permit
Issue Date Process Name Pollutant Control Technology
RBLC Limit
AK-0071 AK AQ0164CPT01 12/20/2010 Sigma Thermal Auxiliary Heater
(1) TPM
Good Combustion Practices
7.6 LB/MMSCF
AK-0071 AK AQ0164CPT01 12/20/2010 Sigma Thermal Auxiliary Heater
(1) TPM10
Good Combustion Practices
7.6 LB/MMSCF
AK-0071 AK AQ0164CPT01 12/20/2010 Sigma Thermal Auxiliary Heater
(1) TPM2.5
Good Combustion Practices
7.6 LB/MMSCF
AL-0191 AL 209-0090-
X001,X002,X003 03/23/2004 BOILERS, NATURAL GAS, (3) FPM10 CLEAN FUEL 0.38 LB/H
AL-0230 AL 503-0095-X001
THRU X026 08/17/2007
NATURAL GAS-FIRED BATCH ANNEALING FURNACES (LA63,
LA64) FPM10
0.0076 LB/MMBTU
AL-0230 AL 503-0095-X001
THRU X026 08/17/2007
NATURAL GAS-FIRED PASSIVE ANNEALING
FURNACE (LO41) FPM10
0.0076 LB/MMBTU
AL-0230 AL 503-0095-X001
THRU X026 08/17/2007
3 NATURAL GAS-FIRED BOILERS WITH ULNB &
EGR (537-539) FPM10
0.0076 LB/MMBTU
AL-0230 AL 503-0095-X001
THRU X026 08/17/2007
NATURAL GAS-FIRED BATCH ANNEALING FURNACE (535)
FPM10 0.0076
LB/MMBTU
AL-0231 AL 712-0037 06/12/2007 VACUUM DEGASSER BOILER PM 0.0076
LB/MMBTU
AL-0231 AL 712-0037 06/12/2007 GALVANIZING LINE FURNACE PM 0.0076
LB/MMBTU
AR-0076 AR 1113-AOP-R0 02/17/2004 BOILER, HOT WATER, (2) SN-
PBCDF-05, -06 FPM10 NATURAL GAS ONLY. 0.1 LB/H
36
RBLC ID State Permit No. Permit
Issue Date Process Name Pollutant Control Technology
RBLC Limit
AR-0076 AR 1113-AOP-R0 02/17/2004 BOILER, PROCESS STEAM, (2)
SN-PBCDF-03, -04 FPM10 NATURAL GAS ONLY. 0.3 LB/H
AR-0076 AR 1113-AOP-R0 02/17/2004 BOILER, LABORATORY SN-
PBCDF-16 FPM10 NATURAL GAS ONLY. 0.1 LB/H
AR-0077 AR 2062-AOP-R0 07/22/2004 BOILERS FPM10 NATURAL GAS
COMBUSTION ONLY 0.0076
LB/MMBTU
AR-0086 AR 883-AOP-R4 06/11/2004 VTD BOILER FPM10 GOOD COMBUSTION
PRACTICE 0.4 LB/H
AR-0090 AR 1139-AOP-R6 04/03/2006 PICKLE LINE BOILERS, SN-52 FPM10 GOOD COMBUSTION
PRACTICE 0.3 LB/H
AZ-0047 AZ 1001653 12/01/2004 AUXILIARY BOILER FPM10 0.0033
LB/MMBTU
CA-1191 CA SE 07-02 03/11/2010 AUXILIARY BOILER TPM
OPERATIONAL RESTRICTION OF 500
HR/YR, USE PUC QUALITY NATURAL
GAS
0.2 GRAINS PER 100
DSCF
CA-1191 CA SE 07-02 03/11/2010 AUXILIARY BOILER TPM2.5 OPERATIONAL
RESTRICTION OF 500 HR/YR
0.2 GRAINS PER 100
DSCF
CA-1192 CA SJ 08-01 06/21/2011 AUXILIARY BOILER TPM
USE PUC QUALITY NATURAL GAS,
OPERATIONAL LIMIT OF 46,675 MMBTU/YR
0.0034 GR/DSCF
CA-1192 CA SJ 08-01 06/21/2011 AUXILIARY BOILER TPM10
USE PUC QUALITY NATURAL GAS,
OPERATIONAL LIMIT OF 46,675 MMBTU/YR
0.0034 GR/DSCF
37
RBLC ID State Permit No. Permit
Issue Date Process Name Pollutant Control Technology
RBLC Limit
FL-0286 FL PSD-FL-354 AND 0990646-001-AC
01/10/2007 TWO 99.8 MMBTU/H GAS-
FUELED AUXILIARY BOILERS FPM10
2 GS/100 SCF GAS
FL-0335 FL 1210468-001-
AC(PSD-FL-417) 09/05/2012
Four(4) Natural Gas Boilers - 46 MMBtu/hour
TPM Good Combustion
Practice 2 GR OF
S/100 SCF
FL-0335 FL 1210468-001-
AC(PSD-FL-417) 09/05/2012
Four(4) Natural Gas Boilers - 46 MMBtu/hour
TPM10 Good Combustion
Practice 2 GR OF
S/100 SCF
FL-0335 FL 1210468-001-
AC(PSD-FL-417) 09/05/2012
Four(4) Natural Gas Boilers - 46 MMBtu/hour
TPM2.5 Good Combustion
Practice 2 GR OF
S/100 SCF
IA-0088 IA 57-01-080 06/29/2007 INDIRECT-FIRED DDGS
DRYER PM
0.015 GR/DSCF
IA-0088 IA 57-01-080 06/29/2007 INDIRECT-FIRED DDGS
DRYER FPM10
0.015 GR/DSCF
*IA-0106 IA PN 13-037 07/12/2013 Startup Heater TPM good operating
practices and use of natural gas
0.0024 LB/MMBTU
*IA-0106 IA PN 13-037 07/12/2013 Startup Heater TPM10 good operating
practices & use of natural gas
0.0024 LB/MMBTU
*IA-0106 IA PN 13-037 07/12/2013 Startup Heater TPM2.5 good operating
practices & use of natural gas
0.0024 LB/MMBTU
IN-0121 IN 145-23127-00001 09/01/2006 602B FURNACE FPM BAGHOUSE 0.45 LB/T GLASS PULLED
IN-0121 IN 145-23127-00001 09/01/2006 602B FURNACE FPM10 BAGHOUSE 0.45 LB/T GLASS PULLED
38
RBLC ID State Permit No. Permit
Issue Date Process Name Pollutant Control Technology
RBLC Limit
*IN-0158 IN 141-31003-00579 12/03/2012 TWO (2) NATURAL GAS
AUXILIARY BOILERS FPM
GOOD COMBUSTION PRACTICES AND
FUEL SPECIFICATIONS
0.0075 LB/MMBTU
*IN-0158 IN 141-31003-00579 12/03/2012 TWO (2) NATURAL GAS
AUXILIARY BOILERS FPM10
GOOD COMBUSTION PRACTICES AND
FUEL SPECIFICATIONS
0.0075 LB/MMBTU
*IN-0158 IN 141-31003-00579 12/03/2012 TWO (2) NATURAL GAS
AUXILIARY BOILERS FPM2.5
GOOD COMBUSTION PRACTICES AND
FUEL SPECIFICATIONS
0.0075 LB/MMBTU
LA-0192 LA PSD-LA-704 06/06/2005 FUEL GAS HEATERS (3) FPM10
USE OF LOW SULFUR PIPELINE NATURAL
GAS AND GOOD COMBUSTION PRACTICES
0.14 LB/H
LA-0203 LA PSD-LA-710 06/13/2005 AUXILIARY THERMAL OIL
HEATER FPM10
USE OF NATURAL GAS AS FUEL AND
GOOD COMBUSTION PRACTICES
0.59 LB/H
LA-0204 LA PSD-LA-709(M-1) 02/27/2009 CRACKING FURNACES A-D FPM10
GOOD COMBUSTION PRACTICES AND USE OF NATURAL GAS AS
FUEL
0.007 LB/MMBTU
LA-0229 LA PSD-LA-731 07/10/2008 EQT122-EQT125 - FOUR VCM
CRACKING FURNACES TPM10
GOOD COMBUSTION PRACTICES AND CLEAN BURNING
FUELS
0.007 LB/MMBTU
LA-0231 LA PSD-LA-742 06/22/2009 SHIFT REACTOR STARTUP
HEATER TPM10
GOOD DESIGN AND PROPER OPERATION
0.25 LB/H
LA-0231 LA PSD-LA-742 06/22/2009 GASIFIER STARTUP
PREHEATER BURNERS (5) TPM10
GOOD DESIGN AND PROPER OPERATION
0.03 LB/H
39
RBLC ID State Permit No. Permit
Issue Date Process Name Pollutant Control Technology
RBLC Limit
LA-0231 LA PSD-LA-742 06/22/2009 METHANATION STARTUP
HEATERS TPM10
GOOD DESIGN AND PROPER OPERATION
0.42 LB/H
LA-0240 LA PSD-LA-747/1280-
00141-V0 06/14/2010 Boilers TPM10
Good equipment design and proper combustion
practices,
fueled by natural gas/alcohol
0.1 LB/H
LA-0240 LA PSD-LA-747/1280-
00141-V0 06/14/2010 Boilers TPM
Good equipment design and proper combustion
practices,
fueled by natural gas/alcohol
0.13 LB/H
LA-0244 LA PSD-LA-291(M3) 11/29/2010 EQT0027 - PACOL CHARGE
HEATER H-201 TPM10 0.86 LB/H
LA-0244 LA PSD-LA-291(M3) 11/29/2010 EQT0028 - PACOL STARTUP
HEATER H-202 TPM10 No additional Control 0.21 LB/H
LA-0246 LA PSD-LA-619(M6) 12/31/2010 EQT0323 - Boiler 401F TPM10
Proper design and operation, good
combustion practices and gaseous fuels
0.74 LB/H
*LA-0272
LA PSD-LA-768 03/27/2013 AMMONIA START-UP HEATER
(102-B) TPM10
GOOD COMBUSTION PRACTICES: PROPER DESIGN OF BURNER
AND FIREBOX COMPONENTS;
MAINTAINING THE PROPER AIR-TO-FUEL
RATIO, RESIDENCE TIME, AND
COMBUSTION ZONE TEMPERATURE.
0.53 LB/H
40
RBLC ID State Permit No. Permit
Issue Date Process Name Pollutant Control Technology
RBLC Limit
*LA-0272
LA PSD-LA-768 03/27/2013 AMMONIA START-UP HEATER
(102-B) TPM2.5
GOOD COMBUSTION PRACTICES: PROPER DESIGN OF BURNER
AND FIREBOX COMPONENTS;
MAINTAINING THE PROPER AIR-TO-FUEL
RATIO, RESIDENCE TIME, AND
COMBUSTION ZONE TEMPERATURE.
0.53 LB/H
MD-0035 MD 009-5-0049 08/12/2005 VAPORIZATION HEATER PM 0.001
LB/MMBTU
MD-0036 MD CPCN 9055 03/10/2006 FUEL GAS PROCESS HEATER FPM10
USE OF LNG QUALITY, LOW
SULFUR NATURAL GAS
0.0074 LB/MMBTU
MD-0040 MD CPCN CASE NO.
9129 11/12/2008 BOILER PM
0.005 LB/MMBTU
MD-0040 MD CPCN CASE NO.
9129 11/12/2008 BOILER FPM10
0.005 LB/MMBTU
MD-0040 MD CPCN CASE NO.
9129 11/12/2008 BOILER FPM2.5
0.005 LB/MMBTU
MD-0040 MD CPCN CASE NO.
9129 11/12/2008 HEATER PM
0.007 LB/MMBTU
MD-0040 MD CPCN CASE NO.
9129 11/12/2008 HEATER FPM10
0.007 LB/MMBTU
MD-0040 MD CPCN CASE NO.
9129 11/12/2008 HEATER FPM2.5
0.007 LB/MMBTU
MN-0053 MN 13100071-001 07/15/2004 BOILER, NATURAL GAS (1) PM CLEAN FUEL AND
GOOD COMBUSTION. 0.008
LB/MMBTU
41
RBLC ID State Permit No. Permit
Issue Date Process Name Pollutant Control Technology
RBLC Limit
MN-0070 MN 06100067-001 09/07/2007 SMALL BOILERS &
HEATERS(<100 MMBTU/H) FPM10
0.0025 GR/DSCF
NJ-0079 NJ 18940 -
BOP110003 07/25/2012
Commercial/Institutional size boilers less than 100 MMBtu/hr
FPM use of Natural gas 0.17 LB/H
NJ-0079 NJ 18940 -
BOP110003 07/25/2012
Commercial/Institutional size boilers less than 100 MMBtu/hr
TPM10 0.46 LB/H
NJ-0079 NJ 18940 -
BOP110003 07/25/2012
Commercial/Institutional size boilers less than 100 MMBtu/hr
TPM2.5 Use of Natural gas 0.46 LB/H
NJ-0080 NJ 08857/BOP110001 11/01/2012 Boiler less than 100 MMBtu/hr FPM use of natural gas a
clean fuel 0.22 LB/H
NJ-0080 NJ 08857/BOP110001 11/01/2012 Boiler less than 100 MMBtu/hr FPM10 use of natural gas a
clean fuel 0.33 LB/H
NJ-0080 NJ 08857/BOP110001 11/01/2012 Boiler less than 100 MMBtu/hr FPM2.5 use of natural gas a
clean fuel 0.33 LB/H
NV-0037 NV 15347 05/14/2004 AUXILIARY BOILER FPM10 RESTRICTION OF OPERATION TO NATURAL GAS
0.5 LB/H
NV-0044 NV 257 01/04/2007 COMMERCIAL/INSTITUTIONAL-
SIZE BOILERS FPM10
USE OF NATURAL GAS AS THE ONLY
FUEL
0.0075 LB/MMBTU
NV-0046 NV 468 05/16/2006 COMMERCIAL/INSTITUTIONAL
BOILER FPM10
GOOD COMBUSTION PRACTICE
0.0078 LB/MMBTU
NV-0047 NV 114 02/26/2008 BOILERS/HEATERS - NATURAL GAS-FIRED
FPM10 FLUE GAS
RECIRCULATION 0.0077
LB/MMBTU
NV-0048 NV 468 05/16/2006 COMMERCIAL/INSTITUTIONAL-
SIZE BOILER (<100 MMBTU/H)
FPM10 NATURAL GAS IS THE ONLY FUEL USED BY
THE UNIT.
0.0078 LB/MMBTU
42
RBLC ID State Permit No. Permit
Issue Date Process Name Pollutant Control Technology
RBLC Limit
NV-0049 NV 257 08/20/2009 BOILER - UNIT FL01 FPM10
FLUE GAS RECIRCULATION AND
OPERATING IN ACCORDANCE WITH
THE MANUFACTURER'S
SPECIFICATION
0.0075 LB/MMBTU
NV-0049 NV 257 08/20/2009 SMALL INTERNAL
COMBUSTION ENGINE (<600 HP) - UNIT FL12
FPM10 THE UNIT IS
EQUIPPED WITH A TURBOCHARGER.
0.0022 LB/HP-H
NV-0049 NV 257 08/20/2009 BOILER - UNIT BA01 FPM10
OPERATING IN ACCORDANCE WITH
THE MANUFACTURER'S
SPECIFICATION
0.0077 LB/MMBTU
NV-0049 NV 257 08/20/2009 BOILER - UNIT BA03 FPM10
OPERATING IN ACCORDANCE WITH
THE MANUFACTURER'S
SPECIFICATION
0.0076 LB/MMBTU
NV-0049 NV 257 08/20/2009 BOILER - UNIT CP01 FPM10
OPERATING IN ACCORDANCE WITH
THE MANUFACTURER'S
SPECIFICATION
0.0076 LB/MMBTU
NV-0049 NV 257 08/20/2009 BOILER - UNIT CP03 FPM10
OPERATING IN ACCORDANCE WITH
THE MANUFACTURER'S
SPECIFICATION
0.0075 LB/MMBTU
43
RBLC ID State Permit No. Permit
Issue Date Process Name Pollutant Control Technology
RBLC Limit
NV-0049 NV 257 08/20/2009 BOILER - UNIT CP26 FPM10
OPERATING IN ACCORDANCE WITH
THE MANUFACTURER'S
SPECIFICATION
0.0075 LB/MMBTU
NV-0050 NV 825 11/30/2009 WATER HEATERS - UNITS NY037 AND NY038 AT NEW
YORK - NEW YORK FPM10
LIMITING THE FUEL TO NATURAL GAS ONLY AND GOOD
COMBUSTION PRACTICES
0.0075 LB/MMBTU
NY-0095 NY PSD-NY-0001 05/10/2006 AUXILIARY BOILER FPM10 LOW SULFUR FUEL 0.0033
LB/MMBTU
OH-0252 OH 07-00503 12/28/2004 BOILERS (2) FPM10 0.31 LB/H
OH-0276 OH 13-04176 06/10/2004 BOILER FOR VACUUM
OXYGEN DEGASSER VESSEL FPM10 0.21 LB/H
OH-0309 OH 04-01358 05/03/2007 BOILER (2), NATURAL GAS PM 0.04 LB/H
OH-0309 OH 04-01358 05/03/2007 BOILER (2), NATURAL GAS FPM10 0.15 LB/H
OH-0323 OH 03-17392 06/05/2008 BOILER PM 0.02
LB/MMBTU
OH-0323 OH 03-17392 06/05/2008 BOILER FPM10 0.094 LB/H
*OH-0350
OH P0109191 07/18/2012 Steam Boiler TPM10 0.48 LB/H
*OH-0352
OH P0110840 06/18/2013 Auxiliary Boiler TPM10 Clean burning fuel, only
burning natural gas 0.79 LB/H
*OH-0355
OH P0112127 05/07/2013 4 Indirect-Fired Air Preheaters TPM10 0.007
LB/MMBTU
OK-0097 OK 2000-306-C M-1
PSD 02/03/2004
BOILERS, NATURAL GAS, STEAM GENERATORS
FPM10 CLEAN FUELS 0.63 LB/H
OK-0097 OK 2000-306-C M-1
PSD 02/03/2004 HEATERS/OXIDIZERS PM
EXCLUSIVE USE OF COMMERCIAL
NATURAL 0.12 LB/H
44
RBLC ID State Permit No. Permit
Issue Date Process Name Pollutant Control Technology
RBLC Limit
GAS OR PROPANE.
OK-0128 OK 2003-106-C(M-1)
PSD 09/08/2008
Ladle pre-heater and refractory drying
TPM10 natural gas fuel 0.0076
LB/MMBTU
OK-0129 OK 2007-115-C(M-
1)PSD 01/23/2009
FUEL GAS HEATER (H2O BATH)
TPM10 0.1 LB/H
OK-0134 OK 2008-100-C PSD 02/23/2009 Nitric Acid Preheaters No. 1 (EU
401, EUG 4) TPM Natural gas combustion 0.15 LB/H
OK-0134 OK 2008-100-C PSD 02/23/2009 Nitric Acid Preheaters No. 1 (EU
401, EUG 4) TPM10 Natural gas combustion 0.15 LB/H
OK-0135 OK 2008-100-C PSD 02/23/2009 NITRIC ACID PREHEATERS #1,
#3, AND #4 TPM 0.15 LB/H
OK-0135 OK 2008-100-C PSD 02/23/2009 NITRIC ACID PREHEATERS #1,
#3, AND #4 TPM10 0.15 LB/H
OK-0135 OK 2008-100-C PSD 02/23/2009 BOILERS #1 AND #2 TPM 0.6 LB/H
OK-0135 OK 2008-100-C PSD 02/23/2009 BOILERS #1 AND #2 TPM10 0.5 LB/H
OR-0048 OR 25-0016-ST-02 12/29/2010 NATURAL GAS-FIRED BOILER FPM10 CLEAN FUEL 2.5
LB/MMCF
PA-0262 PA 06-05007D 10/01/2007 ESR FURNACES (6 UNITS) FPM 12 LB/H
*PA-0291
PA 37-337A 04/23/2013 AUXILIARY BOILER TPM 0.005
LB/MMBTU
SC-0111 SC 1680-0046-CU 12/22/2009 FACE PRIMARY DRYER FPM10
GOOD COMBUSTION PRACTICES AND
NATURAL GAS AS FUEL
SC-0111 SC 1680-0046-CU 12/22/2009 CORE PRIMARY DRYER FPM10 GOOD COMBUSTION
PRACTICES AND NATURAL GAS AS
45
RBLC ID State Permit No. Permit
Issue Date Process Name Pollutant Control Technology
RBLC Limit
FUEL
SC-0112 SC 0420-0060-DO 05/05/2008 VACUUM DEGASSER BOILER FPM10
GOOD COMBUSTION PRACTICES PER
MANUFACTURER'S GUIDANCE
0.0076 LB/MMBTU
SC-0112 SC 0420-0060-DO 05/05/2008 TUNNEL FURNACE BURNERS FPM10
NATURAL GAS COMBUSTION WITH GOOD COMBUSTION
PRACTICES PER MANUFACTURER'S
GUIDANCE
0.0076 LB/MMBTU
SC-0114 SC 0160-0020-CB 11/25/2008 PROPANE VAPORIZERS (ID15) TPM
TUNE-UPS AND INSPECTIONS WILL BE PERFORMED AS OUTLINED IN THE
GOOD MANAGEMENT PRACTICE PLAN
0.04 LB/H
SC-0114 SC 0160-0020-CB 11/25/2008 PROPANE VAPORIZERS (ID15) FPM10
TUNE-UPS AND INSPECTIONS WILL BE PERFORMED AS OUTLINED IN THE
GOOD MANAGEMENT PRACTICE PLAN.
0.04 LB/H
SC-0114 SC 0160-0020-CB 11/25/2008 NATURAL GAS SPACE
HEATERS - 14 UNITS (ID 18) TPM 0.15 LB/H
SC-0114 SC 0160-0020-CB 11/25/2008 NATURAL GAS SPACE
HEATERS - 14 UNITS (ID 18) FPM10 0.15 LB/H
46
RBLC ID State Permit No. Permit
Issue Date Process Name Pollutant Control Technology
RBLC Limit
SC-0114 SC 0160-0020-CB 11/25/2008 75 MILLION BTU/HR BACKUP
THERMAL OIL HEATER TPM 0.54 LB/H
SC-0114 SC 0160-0020-CB 11/25/2008 75 MILLION BTU/HR BACKUP
THERMAL OIL HEATER FPM10 0.54 LB/H
SC-0115 SC 0680-0046-CB 02/10/2009 75 MILLION BTU/HR BACKUP
THERMAL OIL HEATER TPM
GOOD COMBUSTION PRACTICES WILL BE USED AS CONTROL FOR PM EMISSIONS.
0.54 LB/H
SC-0115 SC 0680-0046-CB 02/10/2009 75 MILLION BTU/HR BACKUP
THERMAL OIL HEATER FPM10
GOOD COMBUSTION PRACTICES WILL BE USED AS CONTROL
FOR PM10 EMISSIONS.
0.54 LB/H
SC-0115 SC 0680-0046-CB 02/10/2009 PROPANE VAPORIZERS (ID
14) TPM 0.04 LB/H
SC-0115 SC 0680-0046-CB 02/10/2009 PROPANE VAPORIZERS (ID
14) FPM10
TUNE-UPS AND INSPECTIONS WILL BE PERFORMED AS OUTLINED IN THE
GOOD MANAGEMENT PRACTICE PLAN.
0.04 LB/H
SC-0115 SC 0680-0046-CB 02/10/2009 NATURAL GAS SPACE
HEATERS - 14 UNITS (ID 17) TPM 0.15 LB/H
SC-0115 SC 0680-0046-CB 02/10/2009 NATURAL GAS SPACE
HEATERS - 14 UNITS (ID 17) FPM10 0.15 LB/H
*SC-0149
SC 1860-0128-CA 01/03/2013 NATURAL GAS BOILER EU004 PM 0.005
LB/MMBTU
47
RBLC ID State Permit No. Permit
Issue Date Process Name Pollutant Control Technology
RBLC Limit
*SC-0149
SC 1860-0128-CA 01/03/2013 NATURAL GAS BOILER EU004 FPM 0.002
LB/MMBTU
*SC-0149
SC 1860-0128-CA 01/03/2013 NATURAL GAS BOILER EU004 FPM10 0.005
LB/MMBTU
*SC-0149
SC 1860-0128-CA 01/03/2013 NATURAL GAS BOILER EU004 FPM2.5 0.005
LB/MMBTU
*SC-0149
SC 1860-0128-CA 01/03/2013 NATURAL GAS BOILER EU005 PM 0.005
LB/MMBTU
*SC-0149
SC 1860-0128-CA 01/03/2013 NATURAL GAS BOILER EU005 FPM 0.002
LB/MMBTU
*SC-0149
SC 1860-0128-CA 01/03/2013 NATURAL GAS BOILER EU005 FPM10 0.005
LB/MMBTU
*SC-0149
SC 1860-0128-CA 01/03/2013 NATURAL GAS BOILER EU005 FPM2.5 0.005
LB/MMBTU
*SC-0149
SC 1860-0128-CA 01/03/2013 NATURAL GAS BOILER EU006 FPM10 0.005
LB/MMBTU
*SC-0149
SC 1860-0128-CA 01/03/2013 NATURAL GAS BOILER EU006 PM 0.005
LB/MMBTU
*SC-0149
SC 1860-0128-CA 01/03/2013 NATURAL GAS BOILER EU006 FPM 0.002
LB/MMBTU
*SC-0149
SC 1860-0128-CA 01/03/2013 NATURAL GAS BOILER EU006 FPM2.5 0.005
LB/MMBTU
TX-0501 TX PSD-TX 55M3
AND 6051 07/11/2006
TURBINE EXHAUST DUCT BURNER (3)
FPM10 0.25 LB/H
TX-0501 TX PSD-TX 55M3
AND 6051 07/11/2006 POWER STEAM BOILER FPM10 0.64 LB/H
WI-0207 WI 03-DCF-184 01/21/2004 BOILER, S52/B52, 11 MMBTU/H PM NATURAL GAS /
PROPANE; GOOD COMBUSTION
0.0075 LB/MMBTU
48
RBLC ID State Permit No. Permit
Issue Date Process Name Pollutant Control Technology
RBLC Limit
CONTROL
WI-0207 WI 03-DCF-184 01/21/2004 BOILER, S53 / B53, 34
MMBTU/H PM
NATURAL GAS / PROPANE; GOOD
COMBUSTION CONTROL
0.0075 LB/MMBTU
WI-0207 WI 03-DCF-184 01/21/2004 BOILER, S50/B50, 60 MMBTU/H PM
NATURAL GAS/ PROPANE; GOOD
COMBUSTION CONTROL
0.0075 LB/MMBTU
WI-0207 WI 03-DCF-184 01/21/2004 BOILER, S51/B51, 80 MMBTU/H PM NATURAL GAS, GOOD
COMBUSTION CONTROL
0.0075 LB/MMBTU
WI-0223 WI 03-RV-370 06/17/2004 THERMAL OIL HEATER, GTS
ENERGY, S31, B31 PM
USE OF NATURAL GAS / DISTILLATE OIL, W/ RESTRICTION ON
OIL USAGE
0.84 LB/H
WI-0223 WI 03-RV-370 06/17/2004 THERMAL OIL HEATER, GTS
ENERGY, S32, B32 PM
USE OF NATURAL GAS / DISTILLATE OIL, W/ RESTRICTION ON
OIL USAGE
1 LB/H
WI-0226 WI 04-RV-128 08/27/2004 NATURAL GAS FIRED BOILER FPM10 NATURAL GAS 0.8 LB/H
WI-0227 WI 04-RV-175 10/13/2004 NATURAL GAS FIRED AUXILLIARY BOILER
FPM10 NATURAL GAS FUEL, GOOD COMBUSTION
PRACTICES 0.74 LB/H
WI-0227 WI 04-RV-175 10/13/2004 GAS HEATER (P06, S06) FPM10 NATURAL GAS FUEL 0.08 LB/H
WI-0228 WI 04-RV-248 10/19/2004 B63, S63; B64, S64 - NATURAL GAS STATION HEATER 1 AND
2 FPM10 NATURAL GAS FUEL 0.006 LB/H
49
RBLC ID State Permit No. Permit
Issue Date Process Name Pollutant Control Technology
RBLC Limit
WI-0228 WI 04-RV-248 10/19/2004 B63, S63; B64, S64 - NATURAL GAS STATION HEATER 1 AND
2 PM NATURAL GAS 0.01 LB/H
WV-0021
WV R14-0021 06/09/2004 BOILER, NATURAL GAS, 39.00
MMBTU PM 0.32 PPH
-- DRAFT --
Amendment to Missouri Air Permit No. 012005-008 (as amended) to
Account for Condensable Particulate Emissions
Wet Scrubber Cost Analysis for the Control of PM10 Emissions from the
Blast Furnace
Prepared For:
Buick Resource Recycling Facility
18594 Hwy KK
Boss MO 65440
Prepared By:
Shell Engineering & Associates, Inc.
2403 West Ash
Columbia MO 65203
November 4, 2015
1
1.0 Introduction
The Buick Resource Recycling Facility (BRRF) was issued a PSD permit in 2005
(permit no. 012005-008, project no. 2001-10-058) by the Missouri Department of
Natural Resources (MDNR). Because condensable emissions were not directly
considered as part of the review associated with permit 012005-008, the MDNR
has requested a control technology review to ensure that the condensable
controls employed by the facility are considered Best Available Control
Technology (BACT). It should be noted that at the time the permit was originally
issued in January 2005, PM10 BACT limits were exclusively specified for the
filterable component only.
The MDNR specifically requested a review of each emission unit permitted under
012005-008 to determine if it is a source of condensable particulate. Next,
MDNR requested that a technology review be completed for each source of
condensable particulate to determine if existing control technologies in place
constitute BACT for total PM10 or if additional technologies are required pursuant
to the PSD regulations.
A BACT analysis was submitted on August 15, 2015. As part of the review
procedure, the MDNR has requested a detailed review of the cost associated
with the installation of a wet scrubber on the blast furnace for the control of total
PM10.
2
2.0 Emission Estimates
The main stack (EP-8) is a source of filterable, inorganic and organic
condensable particulate matter. The primary sources routed to the main stack
are the blast furnace and the reverberatory furnace. The main stack also
receives process gases from the two sweat furnaces and refinery along with a
large volume of building ventilation air. The main stack was tested on 10/3/2012
and had a total PM10 (filterable and condensable) emission factor of 0.85 lb/ton
of lead produced. The speciation for the main stack was 8.5% filterable, 20.6%
organic CPM, and 70.9% inorganic CPM. The reverberatory furnace was tested
on 9/26-27/2012 and accounted for 13.3% of the main stack emissions. The
speciation for the reverberatory furnace was 26.9% filterable, 14.9% organic
CPM, and 58.2% inorganic CPM. The emissions from the blast furnace, sweat
furnaces, refinery and building ventilation were calculated by subtracting the
reverberatory furnace emissions from the total emissions emitted from the main
stack. The calculations have been summarized below:
Source Particulate Matter Type
Existing Control Device
Controlled PM10 Emission
Factor (lb/ton)
Fraction of Subtotal (%)
Reverberatory Furnace
Filterable Baghouse 0.0303 26.88
Organic Condensable
Thermal Oxidizer 0.0168 14.93
Inorganic Condensable
Dry Scrubber with Fabric Filtration
0.0656 58.18
Subtotal: 0.1128 100.00
Blast Furnace, Sweat Furnace,
Refinery, Building
Ventilation
Filterable Baghouse 0.0420 5.70
Organic Condensable
None 0.1583 21.47
Inorganic Condensable
None 0.5370 72.83
Subtotal: 0.7374 100.00
Main Stack (EP-08)
Filterable
Refer to Above
0.0723 8.51
Organic Condensable
0.1752 20.60
Inorganic Condensable
0.6027 70.89
Total: 0.85 100.00
A. Total controlled PM10 emission factor from 10/3/2012 stack test = 0.85 lb/ton (lead produced)
3
B. 13.3% of total PM10 assumed from reverb. furnace based on 9/2012 scrubber stack test
C. Main stack speciation from 10/3/2012 stack test (Filt 8.5%, OCPM 20.6%, ICPM 70.9%)
D. Reverb. Furnace speciation from 9/26-27/2012 dry scrubber stack test
(Filt 26.9%, OCPM 14.9%, ICPM 58.2%)
E. Blast furnace, etc. emissions calculated by difference.
The potential annual PM10 emissions from the blast furnace, sweat furnaces,
refinery, and building ventilation were then estimated using the emission factor
from the stack test and a maximum annual lead production rate of 175,000 ton
lead cast/yr:
Potential Annual PM10 Emissions (Blast Furnace and Sweat Furnace) =
175,000 (ton lead cast/yr) * 0.7374 (lb/ton) / 2000 (lb/ton) =
64.52 ton/yr
The blast furnace emissions were then separated based on the average
production rates from the 2013 and 2014 calendar years:
2014
(ton/yr) 2013
(ton/yr)
2013-14 Average (ton/yr)
Fraction of Total (%)
Blast Furnace Castable Lead Production
41242 42557 41900 91.71
Sweat Furnace Castable Lead Production
5327 2244 3786 8.29
Total 46569 44801 45685 100
Potential Annual PM10 Emissions (Blast Furnace) =
64.52 (ton/yr) * 0.9171 =
59.17 ton/yr
4
3.0 Wet Scrubber Annual Cost Effectiveness
An annualized cost of $829,716 ($4.15/scfm) was calculated for the installation of
a wet scrubber on the blast furnace following the existing baghouse. This was
estimated based on the escalated capital costs and procedures documented in
the EPA Air Pollution Control Cost Manual (APCCM). A detail of the annual cost
calculations for the wet scrubber has been provided as Table 3-1. The assumed
control efficiencies for filterable PM10 and inorganic CPM were 70% and 57%,
respectively. A low filterable control efficiency was used due to the fact that the
scrubber would be following an existing high efficiency baghouse. The inorganic
control efficiency was adapted from an Electric Power Research Institute (EPRI)
document titled "Estimating Total Sulfuric Acid Emissions from Stationary Power
Plants". The control efficiency for the emissions of organic condensable PM was
assumed insignificant. The total PM10 control efficiency was then calculated to
be 45.5%, which corresponds to a reduction of 26.92 ton/yr. The annualized cost
effectiveness for the wet scrubber following the existing baghouse is $30,822/ton
of PM10 reduced. The installation of a wet scrubber following the existing
baghouse is not economically feasible.
5
Table 3-1. Wet Scrubber Annual Cost Detail
Cost Item Cost
DIRECT ANNUAL COSTS
Operating Labor
Operator 6 hr/day 30.00 $/hr $65,700
Supervisor 15 % of operator $9,855
Operating Materials -
Maintenance
Labor 2 hr/day 30.00 $/hr $21,900
Material 100 of maint. labor $21,900
Utilities
Propane Mgal/yr $/Mgal $0
Electricity 9,963,556 kW-hr/yr 0.05 $/kW-hr $498,178
INDIRECT ANNUAL COSTS, IC
Overhead 60 % of sum of operating labor and mtrl and $71,613
maintenance labor and materials.
Administrative Charges 2 % of TCI $18,768
Property Taxes 1 % of TCI $9,384
Insurance 1 % of TCI $9,384
Capital Recovery TCI $ 938,417 CRF = 0.1098 $103,033
TOTAL ANNUAL COST 4.15 $/scfm $829,716
A. Adapted from EPA Air Pollution Control Cost Manual (APCCM)
B. Design Parameters
Standard Flow = 200000 scfm
Actual Flow = 221591 acfm
Stack Temperature = 125 F
C. Capital Cost
6
Venturi Scrubber Cost 139,530 $(2002) (APPCM, Section 6, Table 2.6)
Venturi Scrubber EC 265,107 $(2002), 1.9 factor to account for fans, pumps, and other instrumentation
Cost Escalation Factor 1.32 current/2002,http://www.bls.gov/data/inflation_calculator.htm
Venturi Scrubber EC 349,942 $(Current), $(2002) * cost escalation factor
Venturi Scrubber PEC 377,937 $(Current) EC*1.08
Venturi Scrubber TCI 938,417 $(Current) PEC*1.91*1.3, 1.3 factor for retrofit
D. Electricity consumption
Pressure Drop 25 in H2O
Fan HP Requirment 1453 HP, Pressure drop * actual flow / 6356 / 0.6
Total HP Requirement 1525 HP, 1.05 * fan HP, fan + pump Electricity Consumption 9963556 kW-hr/yr
E. Capital recovery factor
Venturi Scrubber
Lifetime 15 years
Interest 7 %
CRF 0.1098
The special conditions listed in this permit were included based on the authority granted the
Missouri Air Pollution Control Program by the Missouri Air Conservation Law (specifically
643.075) and by the Missouri Rules listed in Title 10, Division 10 of the Code of State
Regulations (specifically 10 CSR 10-6.060). For specific details regarding conditions, see 10
CSR 10-6.060(12)(A)10. “Conditions required by permitting authority.”
Buick Resources Recycling Facility, LLC Iron County, S14, T34N, R2W
1. Superseding Condition The conditions of this permit supersede the 4.515 lb/hr PM10 BACT limit for EP-
08 found in Table 1 of PSD permit 012005-008C (Project 2009-11-022) previously issued by the Air Pollution Control Program. The conditions of this permit also supersede the 24.2 ton per 12-month PM10 limit for EP-08 found in special condition 2.F of permit 062011-004 (Project 2011-02-043) previously issued by the Air Pollution Control Program.
2. Buick Resources Recycling Facility, LLC shall emit less than 19.16 lb/hr of PM10 from the blast furnace and sweat furnaces combined. Buick Resources Recycling Facility, LLC shall obtain the PM10 emission rate of the blast furnace and sweat furnaces by conducting performance testing after the Process Baghouse (CD-38), but prior to the introduction of air from the Dry Lime Scrubber System (CD-35-37).
3. Buick Resources Recycling Facility, LLC shall emit less than 2.94 lb/hr of PM10
from the reverberatory furnace and afterburner. Buick Resources Recycling Facility, LLC shall obtain the PM10 emission rate of the reverberatory furnace and afterburner by conducting performance testing after the Dry Scrubber (CD-37).
4. Buick Resources Recycling Facility, LLC shall emit less than 100.64 tons of PM10 from the main stack in any rolling 12-month period.
5. Performance Testing A. Buick Resources Recycling Facility, LLC shall demonstrate compliance
with Special Conditions 2 and 3 by conducting performance testing once every five(5) years on the Process Baghouse (CD-38) and Dry Scrubber (CD-37). The applicable test methods and procedures shall be in accordance with promulgated EPA test methods. Selected test methods shall be proposed and submitted to the Air Pollution Control Program’s Stack Testing Unit for review and approval. Initial testing shall occur no later than 180 days after the issuance date of this amendment. Testing shall consist of three 1-hour test runs. Buick Resources Recycling Facility, LLC shall not operate the scrubber bypass during the testing event.
B. The dates on which performance tests are conducted shall be pre-arranged with the Air Pollution Control Program a minimum of 30 days prior to the proposed test dates so that this Program may arrange a pretest meeting, if necessary, and assure that the test dates are acceptable for an observer to be present. A completed Proposed Test Plan form (copy enclosed) may serve the purpose of notification and shall be approved by the Air Pollution Control Program prior to conducting the required emission testing.
C. Two copies of a written report of the performance test results shall be
submitted to the Director of the Air Pollution Control Program within 30 days after completion of any required testing and receipt of analysis. The report shall include legible copies of the raw data sheets, analytical instrument laboratory data, and complete sample calculations from the required EPA test method for at least one sample run.
6. Recordkeeping and Reporting Requirements
A. Buick Resources Recycling Facility, LLC shall maintain all records required by this permit for not less than five years and shall make them available immediately to any Missouri Department of Natural Resources’ personnel upon request.
B. Buick Resources Recycling Facility, LLC shall report to the Air Pollution
Control Program’s Compliance/Enforcement Section, P.O. Box 176, Jefferson City, MO 65102, no later than ten days after the end of the month during which records indicate an exceedance of an emission limitation imposed by this permit.
Basis From the 2012 stack test, the emission factor for total PM10 was 0.85 lb/ton. At 175,000 ton/yr
lead production and assuming a 1.3 safety factor this would give a lb/hr emission rate for the
main stack of 22.1 lb/hr (175000*0.85*1.3/8760).
The 2012 stack test on the dry scrubber and main stack gave a split of 13.3% of the emissions
from the reverb. furnace.
Reverb emission rate = 2.94 lb/hr (22.1*0.133)
Blast furnace emission rate = 19.16 lb/hr (22.1-2.94)
A ton/yr 12-month emission rate could then be calculated from the 22.1 lb/hr main stack
emission rate when the dry scrubber was operating and 32.76 lb/hr emission rate from December
2011 before the dry scrubber was installed (this is equivalent to the emission levels when the
facility is by-passing the scrubber and adding soda ash to the feed to control SO2
emissions). This would give a 12-month emission rate of 100.64 ton/yr.
(22.1*8040 + 32.76*720)/2000=100.64 ton/yr
8040+720=8760 hours per year, or 365 day/yr * 24 hr/dy
1
Hess, Alana
From: Lanzafame, Jim <[email protected]>
Sent: Wednesday, February 15, 2017 12:20 PM
To: Hess, Alana
Subject: RE: Partial response to recent PM10 discussions
Joseph,
Give me a call when you can. Suggest we “complete” the cost analysis for all kettle heat stacks (indicated 1 kettle heat
stack was 0.32 t/yr.).
Jim L.
Senior Environmental Technical Engineer
Office, 573-626-3406
Cell, 636-575-2797
From: Hess, Alana [mailto:[email protected]] Sent: Wednesday, February 15, 2017 12:11 PM To: Lanzafame, Jim Cc: Crocker, Margaret; Joseph Stolle ([email protected]) Subject: RE: Partial response to recent PM10 discussions
Jim,
If all of the kettles combustion emissions were combined and routed to one scrubber, the overall cost ($/ton) would be
less. Please submit a cost analysis for this scenario.
Thanks,
Alana L. Hess, PE
Environmental Engineer III
Missouri Department of Natural Resources
Phone: (573) 526-0189
Fax: (573) 751-2706
E-mail: [email protected]
Mailing Address:
Air Pollution Control Program – Permits Section
Attn: Alana Hess
2
P.O. Box 176
Jefferson City, MO 65102
From: Lanzafame, Jim [mailto:[email protected]] Sent: Friday, February 10, 2017 4:11 PM To: Hess, Alana Cc: Crocker, Margaret; Joseph Stolle ([email protected]) Subject: Partial response to recent PM10 discussions
Alana,
Attached are our responses to those items we promised for today 02/10. We will continue to provide information on
the previously submitted anticipated schedule. Expect next submittals 02/17.
TASK
Decide whether limit should be based on feed or castable lead units
completed __02/10_____________
RESPONSE
BRRF is planning to submit alternate emission limits based on tons of material fed to the furnaces.
TASK
Consultant’s review of BACT equipment listed in Ms. Hess’s email and explanation of why they are not feasible.
completed _02/10______________
RESPONSE
BRRF’s consultant has provided the following response.
On Thursday, January 26, 2017 the MDNR provided a list of potential BACT controls for primary PM10 emitted from the
dross and refinery kettle heat stacks. The list of potential BACT controls included an evaluation of a wet scrubber assuming an unitized annual operating cost of $2/scfm (fiber-bed scrubber, 1995 dollars). The total annual operating cost was then calculated by converting from 1995 to 2017 dollars and assuming a standard flow rate of 1,000 scfm. Unit Annualized Operating Cost = $2/scfm (1995 dollars) Unit Annualized Operating Cost = $3.15/scfm (2017 dollars) calculated using the US inflation calculator Total Annual Operating Cost = $3,150/year (2017 dollars) The emission reduction associated with a wet scrubber is 0.32 ton/yr. (primary PM10), which corresponds to an MDNR calculated cost effectiveness of $9894.51 (calculated difference is believed to be due to rounding). The MDNR stated that this is within the feasibility range.
The BACT analysis provided by Doe Run in August 2015 utilized a wet scrubber unit annual operating cost of $17/scfm,
which is believed to be on the extreme low end of the range for the size of scrubbers being analyzed. A $3,150 annual
operating cost is not realistic and would not even come close to covering the operating labor and maintenance
costs. The operating maintenance and labor costs have been provided below (the low end of the range for only a part-
time operator and labor hours per day were used):
Wet Scrubber Annual Labor and Maintenance Costs
Cost Item Cost
3
DIRECT ANNUAL COSTS
Operating Labor
Operator 4 hr/day 30.00 $/hr $43,800
Supervisor 15 % of operator $6,570
Maintenance
Labor 2 hr/day 30.00 $/hr $21,900
Material 100 of maintenance. labor $21,900
Total $94,170
Considering only the part-time operating labor and maintenance costs gives a cost effectiveness of $294,281/ton
($94170/0.32 tons) is calculated, which is not cost effective. Use of just a full-time operator would increase the cost by a
factor of roughly 2.8. For an emission source this small, and given the information provided above, we do not believe
that a wet scrubber is cost effective for the control of PM10 emissions from the propane burners associated with the
dross and refinery kettles.
BRRF would welcome the opportunity to discuss its response to your question.
No need to reply.
Jim L.
Senior Environmental Technical Engineer
Office, 573-626-3406
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