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HomeMy WebLinkAboutDAQ-2024-0081091/23/24, 11:48 AM State of Utah Mail - Hexcel 2015 8-hr Ozone RACT Analysis https://mail.google.com/mail/u/0/?ik=539c285453&view=pt&search=all&permmsgid=msg-f:1787024201939913695&simpl=msg-f:1787024201939913…1/2 Ana Williams <anawilliams@utah.gov> Hexcel 2015 8-hr Ozone RACT Analysis Brian Mensinger <bmensinger@trinityconsultants.com>Tue, Jan 2, 2024 at 4:44 PM To: Ana Williams <anawilliams@utah.gov>, "Jon Black (jlblack@utah.gov)" <jlblack@utah.gov> Cc: "Hone, Tyson" <Tyson.Hone@hexcel.com>, "Fayol, David" <David.Fayol@hexcel.com>, Kristine Davies <KDavies@trinityconsultants.com> Ana and Jon, Attached is Hexcel Corporation (Hexcel’s) West Valley City Plant updated Reasonably Available Control Technology (RACT) analysis for the 2015 8-hour Ozone Standard and its precursors (NOx and VOCs). This submission is in response to the letter sent by the Utah Division of Air Quality (UDAQ) on May 31, 2023, which this update is required to be submitted by January 2, 2024. For the purposes of the updated RACT analysis, Hexcel has evaluated emissions in a manner consistent with approaches used for its current approval order (DAQE-AN113860035-22), prior state implementation plan (SIP) conditions, and as they were defined by the RACT analysis top-down process. Hexcel requests that UDAQ reach out to Tyson Hone (Hexcel), David Fayol (Hexcel), or Brian Mensinger (Trinity Consultants), copied on this email, before making any recommendations or final decisions on this RACT analysis to ensure its plans align with Hexcel’s long-term business plans. If you have any questions, please feel free to reach out to us. Regards, Brian Mensinger ………………………………………………………………………… Brian Mensinger Managing Consultant 4525 Wasatch Blvd, Suite 200, Salt Lake City, Utah 84124 Email: bmensinger@trinityconsultants.com Phone: 385-433-3384 Cell: (801) 946-7342 Connect with us: LinkedIn / Facebook / Twitter / YouTube / trinityconsultants.com Stay current on environmental issues. Subscribe today to receive Trinity’s free EHS Quarterly. 1/23/24, 11:48 AM State of Utah Mail - Hexcel 2015 8-hr Ozone RACT Analysis https://mail.google.com/mail/u/0/?ik=539c285453&view=pt&search=all&permmsgid=msg-f:1787024201939913695&simpl=msg-f:1787024201939913…2/2 Hexcel West Valley Ozone RACT Analysis 2024-0102 v2.0.pdf 1170K OZONE SERIOUS NONATTAINMENT RACT Analysis Hexcel Corporation- West Valley City, Utah Prepared By: TRINITY CONSULTANTS 4525 Wasatch Boulevard Suite 200 Salt Lake City, Utah 84104 (801) 272-3000 Submitted on Behalf of: Hexcel Corporation 6800 West 5400 South West Valley City, Utah 84118-0748 Project 234502.0060 January 2024 Hexcel / Ozone RACT Analysis Trinity Consultants TABLE OF CONTENTS 1. INTRODUCTION 1-1 2. FACILITY AND EMISSIONS INFORMATION 2-1 2.1 Description of the Facility ......................................................................................... 2-1 2.2 Emissions Profile ....................................................................................................... 2-1 2.3 Hexcel’s Efforts for Reduction in Emissions............................................................... 2-1 3. REASONABLY AVAILABLE CONTROL TECHNOLOGIES BACKGROUND 3-1 3.1 RACT Methodology .................................................................................................... 3-1 3.1.1 Step 1 – Identify All Reasonably Available Control Technologies................................... 3-2 3.1.2 Step 2 – Eliminate Technically Infeasible Options ....................................................... 3-2 3.1.3 Step 3 – Rank Remaining Control Technologies by Control Effectiveness ...................... 3-2 3.1.4 Step 4 – Evaluate Most Effective Controls and Document Results ................................. 3-2 3.1.5 Step 5 – Select RACT ............................................................................................... 3-3 4. RACT ANALYSIS FOR FIBER LINE EMISSIONS 4-1 4.1 RACT Analysis for NOX Emissions .............................................................................. 4-1 4.1.1 Step 1 – Identify All Reasonably Available Control Technologies................................... 4-2 4.1.2 Step 2 – Eliminate Technically Infeasible Options ....................................................... 4-5 4.1.3 Step 3 – Rank Remaining Control Technologies by Control Effectiveness ...................... 4-6 4.1.4 Step 4 – Evaluate Most Effective Controls and Document Results ................................. 4-6 4.1.5 Step 5 – Select RACT ............................................................................................... 4-7 4.2 RACT Analysis for VOC Emissions .............................................................................. 4-8 4.2.1 Step 1 - Identify All Reasonably Available Control Technologies ................................... 4-8 4.2.2 Step 2 – Eliminate Technically Infeasible Options ..................................................... 4-10 4.2.3 Step 3 – Rank Remaining Control Technologies by Control Effectiveness .................... 4-10 4.2.4 Step 4 – Evaluate Most Effective Controls and Document Results ............................... 4-10 4.2.5 Step 5 – Select RACT ............................................................................................. 4-10 4.3 RACT Analysis for Fiber Line Pilot Plant .................................................................. 4-11 5. RACT ANALYSIS FOR MATRIX 5-1 5.1.1 Step 4 – Evaluate Most Effective Controls and Document Results ................................. 5-1 5.1.2 Step 5 – Select RACT ............................................................................................... 5-1 6. BOILERS 6-1 6.1 RACT Analysis for NOX Emissions .............................................................................. 6-1 6.1.1 Step 1 – Identify All Reasonably Available Control Technologies................................... 6-1 6.1.2 Step 2 – Eliminate Technically Infeasible Options ....................................................... 6-1 6.1.3 Step 3 – Rank Remaining Control Technologies by Control Effectiveness ...................... 6-2 6.1.4 Step 4 – Evaluate Most Effective Controls and Document Results ................................. 6-3 6.1.5 Step 5 – Select RACT ............................................................................................... 6-3 6.2 RACT Analysis for VOC Emissions .............................................................................. 6-3 6.2.1 Steps 1-5 – Select RACT .......................................................................................... 6-3 7. EMERGENCY GENERATORS 7-1 7.1 RACT Analysis for NOX and VOC Emissions ................................................................ 7-1 7.1.1 Step 1 – Identify All Reasonably Available Control Technologies................................... 7-1 7.1.2 Step 2 – Eliminate Technically Infeasible Options ....................................................... 7-2 Hexcel / Ozone RACT Analysis Trinity Consultants i 7.1.3 Step 3 – Rank Remaining Control Technologies by Control Effectiveness ...................... 7-4 7.1.4 Step 4 – Evaluate Most Effective Controls and Document Results ................................. 7-4 7.1.5 Step 5 – Select RACT ............................................................................................... 7-5 8. OTHER SMALL NATURAL GAS FURNACES 8-1 8.1 RACT Analysis for NOX Emissions .............................................................................. 8-1 8.1.1 Step 1 – Identify All Reasonably Available Control Technologies................................... 8-1 8.1.2 Step 2 – Eliminate Technically Infeasible Options ....................................................... 8-1 8.1.3 Steps 3 – 5 ............................................................................................................. 8-1 8.2 RACT Analysis for VOC Emissions .............................................................................. 8-2 8.2.1 Steps 1 – 5 ............................................................................................................. 8-2 9. RACT ANALYSIS FOR LABORATORY AND R&T FACILITY 9-1 APPENDIX A. COST EFFECTIVENESS ANALYSIS A-1 APPENDIX B. SUPPORTING COST CALCULATIONS B-1 APPENDIX C. RBLC DATA C-1 Hexcel / Ozone RACT Analysis Trinity Consultants 1-1 1. INTRODUCTION On May 31, 2023, the Utah Division of Air Quality (UDAQ) sent a letter to Hexcel Corporation (Hexcel) which identified the Hexcel plant in West Valley City, Utah (West Valley City Plant) as a major stationary source within the Northern Wasatch Front (NWF) Ozone Nonattainment Area (NAA). This letter indicated that UDAQ anticipates that the U.S. Environmental Protection Agency (EPA) will reclassify the NAA as serious by February 2025. In order to prepare for the reclassification UDAQ has requested that a Reasonably Available Control Technology (RACT) analysis be submitted by January 2, 2024. Section 110 of the Clean Air Act (CAA) defines the requirements for the development of State Implementation Plans (SIPs), and Section 7511a specifies the requirements of a serious nonattainment SIP, which includes a Reasonably Available Control Technology (RACT) analysis for all major sources. The precursors to ozone are oxides of nitrogen (NOX) and volatile organic compounds (VOCs). As a result, the enclosed RACT analysis focuses on the emission sources at the West Valley City Plant that emit these pollutants. Hexcel has the potential to emit 50 tons per year (tpy) or more of NOX and VOCs classifying it as a major source subject to SIP requirements. Based on further information provided by UDAQ the following elements have been requested for each RACT analysis: ► A list of each of the NOX and VOC emission units at the facility; ► A physical description of each emission unit, including its operating characteristics; ► Estimates of the potential and actual NOX and VOC emission rate from each affected source and associated supporting documentation; ► The proposed NOX and/or VOC RACT requirement or emission limitation (as applicable); and ► Supporting documentation for the technical and economic consideration for each affected emission unit.1 Per UDAQ’s request, Hexcel is submitting this RACT analysis no later than January 2, 2024. 1 Ozone SIP Planning RACT Analysis forms provided by Ana Williams, Utah Department of Environmental Quality on January 9, 2023. Hexcel / Ozone RACT Analysis Trinity Consultants 2-1 2. FACILITY AND EMISSIONS INFORMATION 2.1 Description of the Facility Hexcel Corporation (Hexcel) owns and operates a carbon fiber and fabric pre‐impregnation (pre‐preg) manufacturing plant (West Valley City Plant) located at 6800 West 5400 South, West Valley City in Salt Lake County, Utah. The West Valley City Plant currently operates under Utah Division of Air Quality’s (UDAQ) Approval Order DAQE-AN113860035-22. The plant is an existing major source under federal Nonattainment New Source Review (NNSR), Title V, and Maximum Achievable Control Technology (MACT) programs. Hexcel is a listed source in subsection IX.H of the Utah State Implementation Plan (SIP). The plant is a minor source for Prevention of Significant Deterioration (PSD) purposes. All correspondence regarding this submission should be addressed to: Mr. Tyson Hone Site Environmental Manager P.O. Box 18748 Salt Lake City, Utah 84118 Phone: (385) 831-3472 Email: Tyson.Hone@hexcel.com 2.2 Emissions Profile Through recent permitting actions Hexcel has established the following PTE profile for NOX and VOC. A full explanation of calculation methods and inputs can be found within the permitting files. Table 2-1. Facility-wide Potential to Emit NOX VOC PTE (tpy) 197.62 174.10 Facility-wide actual emissions for NOX and VOC as recorded within UDAQ’s State and Local Emission Inventory System (SLEIS) are included in Table 2-2. Table 2-2. Facility-wide Actual Emissions NOX VOC 2022 Actuals (tpy) 195.02 148.91 2.3 Hexcel’s Efforts for Reduction in Emissions Hexcel has committed to reducing the environmental impact of its facility through SIP and New Source Review (NSR) permitting requirements. This is evidenced through the following actions: ► Ultra-low NOX burners (ULNB) with flue gas recirculation (FGR) shall be installed on Fiber Lines 3, 4, and 7 to control NOX emissions no later than December 31, 2024. Hexcel / Ozone RACT Analysis Trinity Consultants 2-2 ► De-NOX Water (De-NOX) Direct-Fired Thermal Oxidizers (DFTO) shall be installed on Fiber Lines 13, 14, 15, and 16 to control NOX emissions no later than December 31, 2024. Hexcel / Ozone RACT Analysis Trinity Consultants 3-1 3. REASONABLY AVAILABLE CONTROL TECHNOLOGIES BACKGROUND Hexcel previously submitted a Best Available Control Measures (BACM) analysis in 2017 to support the PM2.5 Serious Nonattainment SIP. Hexcel has implemented the current SIP requirements with the exception of those controls that are not required until December 31, 2024. The 2017 BACM analysis serves as a baseline for the RACT analysis documented herein. A RACT analysis has been conducted for each source addressed in Approval Order DAQE-AN113860035-22 in the following sections. Hexcel has organized the RACT analysis in accordance with EPA’s “top-down” procedures per UDAQ guidance.2 The analysis is further organized by emission unit group and addresses NOX and VOCs as ozone precursors. 3.1 RACT Methodology EPA has defined RACT as follows: The lowest emission limitation that a particular source is capable of meeting by the application of control technology that is reasonably available considering technological and economic feasibility.3 RACT for a particular source is determined on a case-by-case basis considering the technological and economic circumstances of the individual source.4 In EPA’s State Implementation Plans; General Preamble for Proposed Rulemaking on Approval of Plan Revisions for Nonattainment Areas – Supplement (on Control Techniques Guidelines), it provided a recommendation to states which says: …each [Control Technique Guideline] CTG contains recommendations to the States of what EPA calls the “presumptive norm” for RACT, based on EPA’s current evaluation of the capabilities and problems general to the industry. Where the States finds the presumptive norm applicable to an individual source or group of sources, EPA recommends that the State adopt requirements consistent with the presumptive norm level in or to include RACT limitations in the SIP.5 Hexcel has referenced the published CTG’s as well as Utah Administrative Code (UAC) for Air Quality (R307), and proposed rules which establish a current presumptive norm specific to the NWF NAA. The preamble goes on to state: …recommended controls are based on capabilities and problems which are general to the industry; they do not take into account the unique circumstances of each facility. In many cases appropriate controls would be more or less stringent. States 2 UDAQ Ozone SIP Planning RACT Analysis, obtained June 13, 2023, during an informational meeting. 3 EPA articulated its definition of RACT in a memorandum from Roger Strelow, Assistant Administrator for Air and Waste Management, to Regional Administrators, Regions I-X, on Guidance for Determining Acceptability of SIP Regulations in Non-Attainment Areas,” Section 1.a (December 9,1976). 4 Federal Register/Vol. 44. No. 181/Monday, September 17,1979/Proposed Rules – State Implementation Plan; General Preamble for Proposed Rulemaking on Approval of Plan Revisions for Nonattainment Areas – Supplement (on Control Techniques Guidelines). 5 IBID. Hexcel / Ozone RACT Analysis Trinity Consultants 3-2 are urged to judge the feasibility of imposing the recommended control on particular sources, and adjust the controls accordingly. Guidance provided by UDAQ for this RACT analysis states that this analysis is to be conducted using the “top-down” method.6 In a memorandum dated December 1, 1987, the EPA detailed its preference for a “top-down” analysis which contains five (5) steps.7 If it can be shown that the most stringent level of control is technically, environmentally, or economically infeasible for the unit in question, then the next most stringent level of control is determined and similarly evaluated. This process continues until the RACT level under consideration cannot be eliminated by any substantial or unique technical, environmental, or economic objections. Presented below are the five basic steps of a “top-down” RACT review as identified by the EPA. 3.1.1 Step 1 – Identify All Reasonably Available Control Technologies Available control technologies are identified for each emission unit in question. The following methods are used to identify potential technologies: 1) researching the RACT/BACT/LAER Clearinghouse (RBLC) database, 2) surveying regulatory agencies, 3) drawing from previous engineering experience, 4) surveying air pollution control equipment vendors, and/or 5) surveying available literature. Additionally, current CTG’s as well as UAC R307, and proposed rules were reviewed to establish a current presumptive norm specific to the NWF NAA. 3.1.2 Step 2 – Eliminate Technically Infeasible Options To ensure the presumptive norm established applies to the emission source in question a full review of available control technologies is conducted in the second step of the RACT analysis. In this step each technology is reviewed for technical feasibility and those that are clearly technically infeasible are eliminated. EPA states the following with regard to technical feasibility:8 A demonstration of technical infeasibility should be clearly documented and should show, based on physical, chemical, and engineering principles, that technical difficulties would preclude the successful use of the control option on the emissions unit under review. 3.1.3 Step 3 – Rank Remaining Control Technologies by Control Effectiveness Once technically infeasible options are removed from consideration, the remaining options are ranked based on their control effectiveness. If there is only one remaining option or if all the remaining technologies could achieve equivalent control efficiencies, ranking based on control efficiency is not required. 3.1.4 Step 4 – Evaluate Most Effective Controls and Document Results Beginning with the most effective control option in the ranking, detailed economic, energy, and environmental impact evaluations are performed. If a control option is determined to be economically 6 UDAQ Ozone SIP Planning RACT Analysis, provided January 9, 2023. 7 U.S. EPA, Office of Air and Radiation. Memorandum from J.C. Potter to the Regional Administrators. Washington, D.C. December 1, 1987. 8 U.S. EPA, New Source Review Workshop Manual (Draft): Prevention of Significant Deterioration and Nonattainment Area Permitting, October 1990. Hexcel / Ozone RACT Analysis Trinity Consultants 3-3 feasible without adverse energy or environmental impacts, it is not necessary to evaluate the remaining options with lower control effectiveness. The economic evaluation centers on the cost effectiveness of the control option. Costs of installing and operating control technologies are estimated and annualized following the methodologies outlined in the EPA’s OAQPS Control Cost Manual (CCM) and other industry resources.9 Note that the purpose of this analysis is not to determine whether controls are affordable for a particular company or industry, but whether the expenditure effectively allows the source to meet pre-established presumptive norms. 3.1.5 Step 5 – Select RACT In the final step the lowest emission limitation is proposed as RACT along with any necessary control technologies or measures needed to achieve the cited emission limit. This proposal is made based on the evaluations from the previous step. 9 Office of Air Quality Planning and Standards (OAQPS), EPA Air Pollution Control Cost Manual, Sixth Edition, EPA 452-02-001 (https://www.epa.gov/economic-and-cost-analysis-air-pollution-regulations/cost-reports-and-guidance-air-pollution), Daniel C. Mussatti & William M. Vatavuk, January 2002. Hexcel / Ozone RACT Analysis Trinity Consultants 4-1 4. RACT ANALYSIS FOR FIBER LINE EMISSIONS An understanding of Hexcel’s Carbon Fiber process is important for understanding the technical and economic feasibility of various control options. The first step in converting polyacrylonitrile (PAN) fiber into carbon fiber is the stabilization of the PAN fibers in an air oxidation process. The intent of this step is to prepare the PAN fibers for the high temperature carbonization process. The oxidation process is completed with the operation of oxidation ovens set at specified temperatures to achieve the required amount of oxidation during the fiber stabilization process. The ovens have the capability to be either electric or natural gas fired. Fiber Lines 2, 3 and 4 have electric ovens, which do not produce combustion emissions. Fiber Lines 5-7, 8, 10, 11 and 12 have natural gas-fired ovens. Fiber Lines 13-16 are hybrid ovens with the capability of using electricity or natural gas. NOX is the primary pollutant that is emitted from these sources, but VOC emissions also results from the combustion of fuel. The oxidation ovens for Fiber Lines 5-7 are indirect fired, so the combustion emissions are vented from a separate stack than the process emissions. For Fiber Lines 8 and 10-16, the ovens are direct fired; thus, the flue gas (combustion emissions) enters the oven and is combined with process emissions then vented through a single stack. The ozone precursor emissions associated with the stabilization process occurring in the oxidation ovens is VOC. Exhaust gases containing process emissions from the ovens are captured in hoods at either end of each oven or within the oven structure itself. The next downstream step in the manufacturing of carbon fiber is carbonization. This step can be split into two different phases. The first phase is tar removal which occurs when the fiber continuously passes through a low temperature furnace. The tar removal step takes place in an electric furnace at temperatures ranging from 300 – 800 degrees Celsius (°C). Ozone precursor emissions generated from the tar removal process are VOCs. The second phase of carbonization occurs at higher temperatures ranging from 1200-1450 °C. This high temperature treatment of the fiber occurs in another electric furnace, commonly referred to as the high temperature (HT) furnace. Ozone precursor emissions generated from the carbonization process are VOCs. Hexcel is currently permitted to operate 14 Fiber Lines. Add-on control device options were evaluated for each fiber line based on all stack flow directed to one control device per line. This control strategy optimizes the balance between energy efficiency and capital intensity with the same environmental benefit as adding smaller control devices to each emission unit or one large device receiving combined flow from all buildings. 4.1 RACT Analysis for NOX Emissions As described previously, the oxidation process is completed with the operation of ovens set at specified temperatures to achieve the required amount of oxidation for the fiber stabilization process. The NOX emissions from combustion in the oxidation ovens, tar removal process furnaces, and carbonization furnaces are included in the NOX RACT analysis for the Fiber Lines. Since RACT, at a minimum, must consider current regulations as well as SIP and Approval Order conditions that apply to the emission units, the minimum NOX RACT limitations are as follows:10 ► 5.50 million standard cubic feet (MMscf) of natural gas consumed per day ► 0.061 million pounds of carbon fiber produced per day 10 Requirements included in Section IX. Part H of the PM2.5 SIP. Hexcel / Ozone RACT Analysis Trinity Consultants 4-2 ► ULNB with FGR installed on Fiber Lines 3, 4, and 7 no later than December 31, 2024 ► De-NOX DFTO installed on Fiber Lines 13, 14, 15, and 16 no later than December 31, 2024 ► Emission limitations for NOX concentration: • Fiber Line 3 – 9.0 parts per million (ppm) • Fiber Line 4 – 9.0 ppm • Fiber Line 7 – 9.0 ppm ► Fiber Lines 13-16 oxidation ovens • Natural gas combustion with low NOX burners (LNB) • Controlled with Direct-fired Thermal Oxidizers (DFTOs) equipped with LNB • Controlled with dual chamber regenerative thermal oxidizers (RTOs) with LNB 4.1.1 Step 1 – Identify All Reasonably Available Control Technologies Based on the review of the U.S. EPA’s RBLC database and similar operations, Hexcel has identified the following control technologies available for controlling NOX emissions from the proposed gas streams: 1. Good Combustion Practices (GCP), 2. Use of Natural Gas Only as Fuel, 3. LNB, 4. ULNB, 5. FGR 6. De-NOX, 7. Selective Catalytic Reduction (SCR), and 8. Selective Non‐Catalytic Reduction (SNCR) The search of the RBLC database produced two carbon fiber manufacturing facilities shown in Attachment C. One facility installed LNB with FGR in combination with use of natural gas and GCP as NOX BACT for a PSD permit. The other facility found SCR to not be cost effective but installed it voluntarily on four of its eight carbon Fiber Lines as NOX control during a PSD permitting action. Additional searches of the database, for similar combustion units fired with natural gas were also conducted. The results of these searches presented in Attachment C produced the same list of control devices for NOX as shown above. Low‐NOX Burners LNB technology uses advanced burner design to reduce NOX formation through the restriction of oxygen, flame temperature, and/or residence time. There are two general types of LNB: staged fuel and staged air burners. In a stage fuel LNB, the combustion zone is separated into two regions. The first region is a lean combustion region where a fraction of the fuel is supplied with the total quantity of combustion air. Combustion in this zone takes place at substantially lower temperatures than a standard burner. In the second combustion region, the remaining fuel is injected and combusted with left over oxygen from the first region. A staged air burner begins with full fuel but only partial combustion air, and then adds the remaining combustion air in the second combustion region. These techniques reduce the formation of thermal NOX. Implementation of LNB technology has been shown to reduce NOX emissions by 50 percent compared with standard burners.11 11 AP‐42 Table 1.4‐1 – Emission Factors for Nitrogen Oxides (NOX) and Carbon Monoxide (CO) from Natural Gas Combustion. Comparison of uncontrolled emissions from a small boiler (100 lb/106 scf) to controlled Low‐NOX burner emissions from a small boiler (50 lb/106 scf). [1‐50/100 = 50%] Hexcel / Ozone RACT Analysis Trinity Consultants 4-3 Ultra-Low NOX Burners ULNB technology incorporates an LNB with an additional system such as FGR to further reduce NOX. ULNBs provide a stable flame that has several different zones. ULNB technology commonly uses internal FGR which involves recirculating the hot O2 depleted flue gas from the heater into the combustion zone using burner design features and fuel staging to reduce NOX. There are several methods for reducing NOX that can produce more than 80 percent destruction removal efficiency (DRE).12 NOX emission rates as low as 9 ppm have been achieved in practice.13 Flue Gas Recirculation As noted above, FGR is frequently used with both LNB and ULNB. FGR involves the recycling of post-combustion air into the air-fuel mixture to reduce the available oxygen and help cool the burner flame. External FGR requires the use of ductwork to route a portion of the flue gas in the stack back to the burner windbox; FGR can be either forced draft (where hot side fans are used) or induced draft. De-NOX Steam or Water System The formation of NOX results from one of three mechanisms: thermal NOX, fuel NOX, and prompt NOX. The De-NOX control system injects either steam or water into the combustion chamber to reduce the potential formation of thermal NOX by providing a small reduction in temperature within the combustion chamber. Water injection generally provides better control of NOX since it reduces the temperature in the combustion chamber more than does steam. Selective Catalytic Reduction The SCR process is based on the chemical reduction of the NOX molecule. SCR employs a metal‐based catalyst with activated sites to increase the rate of the reduction reaction. A nitrogen based reducing agent (reagent), such as ammonia or urea, is injected into the post combustion flue gas. The reagent reacts selectively with the flue gas NOX within a specific temperature range and in the presence of the catalyst and oxygen to reduce the NOX into molecular nitrogen (N2) and water vapor (H2O).14 SCR has been applied to stationary source, fossil fuel-fired, combustion units for emission control since the early 1970s. It has been applied to large, >250 million British thermal units per hour (MMBtu/hr), utility and industrial boilers, process heaters, and combined cycle gas turbines. There has been limited application of SCR to other combustion devices and processes such as simple cycle gas turbines, stationary reciprocating internal combustion engines, nitric acid plants, and steel mill annealing furnaces. SCR can be applied as a stand-alone NOX control or with other technologies such as combustion controls. The optimum operating temperature is dependent on the type of catalyst and the flue gas composition. Generally, the optimum 12 EPA Technical Bulletin “Nitrogen Oxides (NOX) Why and How are They Controlled”, EPA 456/F‐99‐006R November 1999. 13 Internet search, including: https://ww2.arb.ca.gov/sites/default/files/classic/research/apr/past/94-354.pdf; http://www.powerflame.com/index.php?option=com_content&view=article&id=110&Itemid=57; https://www.pharmaceuticalonline.com/doc/ultra-low-nox-burner-has-widened-stability-li-0004 14 Ibid. Hexcel / Ozone RACT Analysis Trinity Consultants 4-4 temperature ranges from 480-800 degrees Fahrenheit (°F).15 In practice, SCR systems operate at efficiencies in the range of 70-90 percent.16 SNCR SNCR is currently being used for NOX emission control on industrial boilers, electric utility steam generators, thermal incinerators, and municipal solid waste energy recovery facilities. Its use on utility boilers has generally been limited to units with output of less than 3,100 MMBtu. SNCR can be applied as a stand‐alone NOX control or with other technologies such as combustion controls. The SNCR system can be designed for seasonal or year‐round operations. SNCR can achieve NOX reduction efficiencies of up to 75 percent in short-term demonstrations. In typical field applications, however, it provides 30-50 percent NOX reduction. Reductions of up to 65 percent have been reported for some field applications of SNCR in tandem with combustion control equipment such as LNB.17 SNCR is based on the chemical reduction of the NOX molecule into N2 and H2O. A nitrogen based reducing agent (reagent), such as ammonia or urea, is injected into the post combustion flue gas. The reagent can react with a number of flue gas components. However, the NOX reduction reaction is favored over other chemical reaction processes for a specific temperature range and in the presence of oxygen; therefore, it is considered a selective chemical process.18 The technique requires thorough mixing of reagent into the furnace chamber with at least 0.5 seconds of residence time at a temperature above 1600 °F and below 2100 °F. Optimally, the reagent is injected into the furnace at approximately 1900 ‐ 1950 °F, which is a good tradeoff between the competing reaction of oxidation of ammonia to NOX and maximizing the residence time at a temperature which is greater than the temperature at which SNCR yields published removal efficiencies.19 The hardware associated with an SNCR installation is relatively simple and readily available. Consequently, SNCR applications tend to have low capital costs compared to LNB and SCR. Installation of SNCR equipment requires minimum downtime. Good Combustion Practices U.S. EPA’s RBLC database lists numerous operations where GCP are the accepted technology for minimizing NOX emissions. GCP reduce NOX emissions by keeping the burners maintained properly so that the burners continue to operate according to their design. The use of GCP usually includes the following components: (1) proper fuel mixing in the combustion zone; (2) high temperatures and low oxygen levels in primary zone; (3) overall excess oxygen levels high enough to complete combustion while maximizing boiler efficiency, and (4) sufficient residence time to complete 15 OAQPS, EPA Air Pollution Control Cost Manual, Sixth Edition, EPA/424/B-02-001 (https://www.epa.gov/economic-and-cost- analysis-air-pollution-regulations/cost-reports-and-guidance-air-pollution); January 2002 16 OAQPS, EPA Air Pollution Control Cost Manual, Sixth Edition, EPA/424/B-02-001 (https://www.epa.gov/economic-and-cost- analysis-air-pollution-regulations/cost-reports-and-guidance-air-pollution); January 2002 17 Ibid. 18 OAQPS, EPA Air Pollution Control Cost Manual, Sixth Edition, EPA/424/B‐02‐001 (https://www.epa.gov/economic-and-cost- analysis-air-pollution-regulations/cost-reports-and-guidance-air-pollution); January 2002 19 SNCR System – Design, Installation and Operating Experience, David L. Wojichowski, De‐NOX Technologies LLC Hexcel / Ozone RACT Analysis Trinity Consultants 4-5 combustion. GCP are accomplished through boiler design as it relates to time, temperature, and turbulence, and boiler operation as it relates to excess oxygen levels. Use of Natural Gas Only as Fuel The U.S. EPA’s RBLC database indicates restricting fuel type to natural gas will limit NOX emissions, because other fuels combusted may have higher NOX emission rates. 4.1.2 Step 2 – Eliminate Technically Infeasible Options Selective Catalytic Reduction There has been limited application of SCR to combustion devices and processes such as simple cycle gas turbines, stationary reciprocating internal combustion engines, nitric acid plants, and steel mill annealing furnaces. Results of the RBLC search for similar operations to Hexcel’s, shown in Appendix C support that this type of control technology has not been used in applications similar to Hexcel’s operations. Operation of an SCR requires installation of a baghouse to filter particulate from the exhaust prior to entering the SCR to minimize catalyst plugging or poisoning. This would make the SCR an ineffective control for the fiber line process. Currently, only Fiber Lines 13-16 are equipped with particulate control devices (baghouse/filter box). An SCR does not control emissions effectively at high temperatures, in excess of 1000 °F, as well as low temperatures, below 700 °F. In order for the baghouse to operate properly, the air stream will need to be cooled to a maximum of 450 °F. To operate the SCR after the baghouse, the air stream would be reheated to above 700 °F. This would require significant operational expense and cause additional combustion related emissions. Another drawback to the SCR system is additional ammonia emissions. Ammonia slip does not remain constant as the SCR system operates but increases as the catalyst activity decreases. Ammonia is considered as a precursor to the formation of PM2.5, for which the area is also nonattainment. For these combined reasons, SCR technology is considered to be technically infeasible for controlling NOX emissions from the Fiber Lines. SNCR Though simple in concept, it is challenging in practice to design an SNCR system that is reliable, economical, simple to control, and meets other technical, environmental, and regulatory criteria. Practical application of SNCR is limited by the system design and operating conditions.20 SNCR’s NOX control efficiency declines at temperatures below 1600 °F. Proposed particulate capture for the system will be conducted through a baghouse. In order for the baghouse to operate properly, the air stream will need to be cooled to a maximum of 450 °F. To operate the SNCR after the baghouse, the air stream would be required to be reheated to above 1600 °F. The Hexcel exhaust stream thus requires heating for effective NOX destruction, which consequently increases combustion emissions and fuel cost. Another drawback to the SNCR system is additional ammonia emissions associated with the ammonia injection process. The normalized stoichiometric ratio defines the amount of reagent needed to achieve the targeted NOX reduction in the SNCR system. Typical normalized stoichiometric ratio values require significantly more reagent to be injected in practice than required by the theoretical stoichiometric ratio. In 20 SNCR System – Design, Installation and Operating Experience, David L. Wojichowski, De‐NOX Technologies LLC Hexcel / Ozone RACT Analysis Trinity Consultants 4-6 addition, the amount of NOX removed is generally much less than the amount of uncontrolled NOX. This leaves a large portion of the injected reagent unreacted. Most of the excess reagent used in the process is destroyed through other chemical reactions. However, a small portion remains in the flue gas as ammonia slip.21 As noted in the previous section ammonia is considered as a precursor to the formation of PM2.5, for which the area is also nonattainment. Results of the RBLC search for similar operations, shown in Appendix C, further support that this type of control technology has not been used in applications similar to Hexcel operations. For these reasons, SNCR technology is considered to be technically infeasible. Other Control Technologies All other control technologies are considered technically feasible and will be carried through to Step 3 of the analysis. 4.1.3 Step 3 – Rank Remaining Control Technologies by Control Effectiveness Based on the information provided in the previous section, feasible technologies for control of NOX from the Fiber Lines are the following, with most effective control first and least effective control last. 1. De-NOX, 2. ULNB, 3. LNB, 4. GCP, and 5. Use of Natural Gas Only as Fuel. Emissions associated with implementation of the LNB technology were calculated assuming 50 percent control efficiency.22 Emissions associated with implementation of the ULNB technology were calculated assuming 68 percent control efficiency.23 De-NOX emission reduction can range from 60-80 percent.24 For the purposes of calculating emission reductions from De-NOX was assumed to be 70 percent. No control efficiency was estimated for either GCP or use of natural gas only as fuel. 4.1.4 Step 4 – Evaluate Most Effective Controls and Document Results GCP and use of natural gas only as fuel are existing conditions for all fiber line combustion units. Therefore, no additional analysis was completed for these two control technologies. In addition, Attachment A contains information on which combustion units are already equipped with either LNB/De-NOX or ULNB technology. 21 OAQPS, EPA Air Pollution Control Cost Manual, Sixth Edition, EPA/424/B‐02‐001 (https://www.epa.gov/economic-and-cost- analysis-air-pollution-regulations/cost-reports-and-guidance-air-pollution); January 2002 22 AP‐42 Table 1.4‐1 – Emission Factors for Nitrogen Oxides (NOX) and Carbon Monoxide (CO) from Natural Gas Combustion. Comparison of uncontrolled emissions from a small boiler (100 lb/106 scf) to controlled Low‐NOX burner emissions from a small boiler (50 lb/106 scf). [1‐50/100 = 50%] 23 AP‐42 Table 1.4‐1 – Emission Factors for Nitrogen Oxides (NOX) and Carbon Monoxide (CO) from Natural Gas Combustion. Comparison of uncontrolled emissions from a small boiler (100 lb/106 scf) to controlled Ultra‐Low‐NOX burner emissions from a small boiler (32 lb/106 scf). [1‐32/100 = 68%] 24 EPA CAM Technical Guidance Document, Section B.17. Water or Steam Injection (https://www3.epa.gov/ttnchie1/mkb/documents/B_17a.pdf), April 2002. Hexcel / Ozone RACT Analysis Trinity Consultants 4-7 For any combustion units that are already equipped with either of these technologies as an existing or future required condition, no additional analysis has been completed. Annualized costs associated with implementing the LNB, De-NOX, and ULNB technologies on Fiber Lines 2-7, 8, 10, 11 and 12 were calculated and are summarized in Attachment A for each of the Fiber Lines. Supporting cost calculations are provided in Attachment B. The control costs range from $57,585 - $909,334 per ton of NOX removed, which is considered not cost effective. It is also important to note that retrofit of burners on existing units in Fiber Lines 2, 5-8, 10, 11, and 12 to incorporate NOX control technology would require many expensive operational adjustments to the ovens, including: ► Demolition of existing operations; ► Redesign of hoods; ► Burner box (Ductwork, ID‐fan, and stack) redesign; ► Air flow adjustments; ► Gas line input retrofit; and ► Installation of pressure regulators. A retrofit factor of 1.4 was included in the cost of installing the control based on documentation provided in the OAQPS manual, however this likely does not represent the true additional costs associated with retrofitting the older lines to incorporate newer burners. Because proper oxidation is essential to the carbon stabilization process, redesign of the oven burner operations would initiate a complete redesign of the Fiber Line process to achieve consistent production levels. This redesign of the Fiber Lines would require significant loss in production for Hexcel. Costs associated with lost production have been included in the total costs associated with the installation of LNB for the older lines. However, they have conservatively not been included in the total costs associated with the installation of other NOX controls for the older lines. For these reasons, this proposed technology is considered to be cost prohibitive for controlling NOX emissions from Fiber Lines 2, 5-8, 10, 11, and 12. 4.1.5 Step 5 – Select RACT Based on the RACT analysis detailed in Steps 1-4, GCP and use of natural gas as fuel is determined to be NOX RACT for Fiber Lines 2, 5-8, 10, 11, and 12. As previously discussed, Fiber Lines 3, 4, and 7 are required to implement ULNBs as BACT and Fiber Lines 13, 14, 15, and 16 are required to implement DeNOX water as BACT in the PM2.5 Serious nonattainment SIP, so these lines are considered implementing RACT for NOx. As a result, the following annual and short-term limits NOX limits are considered RACT for Fiber Lines 2, 5, 6, 8, and 10-12:25 ► 69.05 tpy ► 15.77 lbs/hr 25 Includes Fiber Line Pilot Plant emissions based on the analysis in Section 4.3. Hexcel / Ozone RACT Analysis Trinity Consultants 4-8 4.2 RACT Analysis for VOC Emissions 4.2.1 Step 1 - Identify All Reasonably Available Control Technologies Based on the review of U.S. EPA’s RBLC database and similar operations, Hexcel has identified the following control technologies that could be applicable for controlling VOC emissions from the Fiber Lines: 1. GCP 2. Use of Natural Gas Only as Fuel 3. Open Flare 4. Incinerator/DFTO 5. RTO The search of the RBLC database produced two carbon fiber manufacturing facilities. Results of this search are presented in Attachment C. The permit for the first facility subject to SIP and operating permit conditions required installation of a wet scrubber to control VOCs and acrylonitrile from Fiber Lines and storage tanks. Note that the storage tanks for this facility were subject to NSPS Kb – Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced After July 23, 1984. Hexcel does not use any acrylonitrile in its fiber line process and does not have any tanks that trigger NSPS Kb. The permit for the second facility subject to BACT for PSD did not have any control required for VOCs from the carbon fiber process. Additional searches of the database, for similar combustion units fired with natural gas were also conducted. The results of these searches for VOC are also presented in Attachment C. Good Combustion Practices U.S. EPA’s RBLC database lists numerous operations where GCP are the accepted technology for minimizing VOC emissions. GCP reduce VOC emissions by keeping the burners operating according to their design and combust VOC as completely as possible while maintaining other emissions, such as NOX, to a minimum. Use of Natural Gas Only as Fuel Restricting fuel type to natural gas limits VOC emissions, because other fuel options, such as diesel or coal, generate more VOC emissions per heat output. VOC emissions from natural gas combustion are lower than emissions from any other readily available fuel. Open Flare Flaring is a volatile combustion control process for organic compound in which the VOCs are piped to a remote, usually elevated, location and burned in an open flame in the open air using a specially designed burner tip, auxiliary fuel, and steam or air to promote mixing for nearly complete (> 98 percent) VOC destruction. Completeness of combustion in a flare is governed by flame temperature, residence time in the combustion zone, turbulent mixing of the components to complete the oxidation reaction, and available oxygen for free radical formation.26 26 OAQPS, EPA Air Pollution Control Cost Manual, Sixth Edition, EPA 452‐02‐001, Daniel C. Mussatti & William M. Vatavuk, January 2002. Section 3 VOC Controls, Section 3.2 VOC Destruction Controls, Chapter 1 Flares, p. 1‐3. Hexcel / Ozone RACT Analysis Trinity Consultants 4-9 Flares can be used to control almost any high concentration VOC stream, and can handle fluctuations in VOC concentration, flow rate, heating value, and inert content. Flaring is appropriate for continuous, batch, and variable flow vent stream applications.27 Incinerator/DFTO Incineration and DFTO use similar technology and have similar requirements; therefore, they have been combined and collectively referred to as “incineration” for the purposes of the RACT analysis. A major advantage of incineration is that virtually any gaseous organic stream can be incinerated safely and cleanly, provided proper engineering design is used. An incinerator system includes a combustion chamber in which the VOC‐containing waste stream is burned. Since the inlet waste gas stream temperature is generally much lower than that required for combustion, energy must be supplied to the incinerator to raise the waste gas temperature. Seldom, however, is the energy released by the combustion of the total organics (VOCs and others) in the waste gas stream sufficient to raise its own temperature to the desired levels, so that auxiliary fuel (e.g., natural gas) must be added. The heart of the thermal incinerator is a nozzle‐stabilized flame maintained by a combination of auxiliary fuel, waste gas compounds, and supplemental air added when necessary. Upon passing through the flame, the waste gas is heated from its inlet temperature to its ignition temperature. The ignition temperature varies for different compounds and is usually determined empirically. It is the temperature at which the combustion reaction rate (and consequently the energy production rate) exceeds the rate of heat losses, thereby raising the temperature of the gases to some higher value. Thus, any organic/air mixture will ignite if its temperature is raised to a sufficiently high level. The organic‐containing mixture ignites at some temperature between the preheat temperature and the reaction temperature. That is, ignition occurs at some point during the heating of a waste stream as it passes through the nozzle‐stabilized flame regardless of its concentration. The mixture continues to react as it flows through the combustion chamber. The required level of VOC control of the waste gas that must be achieved within the time that it spends in the thermal combustion chamber dictates the reactor temperature. The shorter the residence time, the higher the reactor temperature must be. Once the unit is designed and built, the residence time is not easily changed, so that the required reaction temperature becomes a function of the particular gaseous species and the desired level of control.28 Regenerative Thermal Oxidizer A flameless natural gas injection (NGI) dual chambered RTO system uses a bed of ceramic material to absorb heat from the exhaust gas, and then uses the captured heat to preheat the incoming process gas 27 OAQPS, EPA Air Pollution Control Cost Manual, Sixth Edition, EPA 452‐02‐001, Daniel C. Mussatti & William M. Vatavuk, January 2002. Section 3 VOC Controls, Section 3.2 VOC Destruction Controls, Chapter 1 Flares, p. 1‐5. 28 OAQPS, EPA Air Pollution Control Cost Manual, Sixth Edition, EPA 452‐02‐001, Daniel C. Mussatti & William M. Vatavuk, January 2002. Section 3 VOC Controls, Section 3.2 VOC Destruction Controls, Chapter 2 Incinerators, p. 2‐6. Hexcel / Ozone RACT Analysis Trinity Consultants 4-10 stream. Emissions associated with implementation of the RTO technology were calculated assuming 98 percent control efficiency.29 RTOs are suited to applications with low VOC concentrations but high waste stream flow rates. This is due to their high thermal energy recovery. The basic operation of an RTO consists of passing a hot gas stream over a heat sink material in one direction and recovering that heat by passing a cold gas stream through that same heat sink material in an alternate cycle. They are used to destroy air toxics and VOCs that are discharged in industrial process exhausts. Once the proposed process is at steady state, the RTO is fueled by both natural gas and other combustible gases (HCN, VOC) that off gas from the process. 4.2.2 Step 2 – Eliminate Technically Infeasible Options None of the identified technologies are considered technically infeasible. However, since the Hexcel Facility is near a populated area, a typical open flare system would not be a technology that should be implemented due to the noise and open flame associated with such a system. For this reason, and the fact that there are other VOC control technologies available, use of a flare will not be carried through to Step 3. 4.2.3 Step 3 – Rank Remaining Control Technologies by Control Effectiveness Based on the information provided in the previous section, feasible technologies for control of VOC from the Fiber Lines are the following, with most effective control first and least effective control last. 1. Incinerator/DFTO 2. RTO 3. GCP 4. Use of Natural Gas Only as Fue,l 4.2.4 Step 4 – Evaluate Most Effective Controls and Document Results All of the Fiber Lines are currently equipped with either an incinerator or DFTO, so these controls will not be discussed further in this analysis. In addition, GCP and use of natural gas only as fuel are existing conditions for all of the Fiber Lines, so they will also not be discussed further in this analysis. In addition, Fiber Lines 13-16 are already equipped with an RTO. Annualized costs associated with implementing the RTO on Fiber Lines 2, 5-7, 8, 10, 11, and 12 were calculated and are summarized in Attachment A for each of the Fiber Lines. Supporting cost calculations are provided in Attachment B. The control costs range from $54,696 - $2,323,628 per ton of VOC removed, which is considered not cost effective. 4.2.5 Step 5 – Select RACT Based on the RACT analysis detailed in Steps 1-4, GCP and use of natural gas as fuel is determined to be VOC RACT for Fiber Lines 2-8 and 10-12. As Fiber Lines 13, 14, 15, and 16 have RTOs installed this is considered BACT. As a result, this analysis includes the following annual and short term- VOC limits are considered RACT for Fiber Lines 2, 5, 6, 8, and 10-12:30 29 OAQPS, EPA Air Pollution Control Cost Manual, Sixth Edition, EPA 452‐02‐001, Daniel C. Mussatti & William M. Vatavuk, January 2002. Section 3 VOC Controls, Section 3.2 VOC Destruction Controls, Chapter 2 Incinerators, p. 2‐7. 30 Includes Fiber Line Pilot Plant emissions based on analysis in Section 4.3. Hexcel / Ozone RACT Analysis Trinity Consultants 4-11 ► 124.46 tpy ► 28.42 lbs/hr 4.3 RACT Analysis for Fiber Line Pilot Plant In addition to the Fiber Line manufacturing operation, Hexcel also has a Fiber Line Pilot Plant, which is essentially a small-scale research facility for the carbon fiber process. The discussions of available controls and control feasibility (i.e., RACT Steps 1-3) provided for the main Fiber Line operations also apply to the Pilot Plant operations. Attachment A presents the emissions associated with the existing process operation, and the emissions once each control technology under evaluation is applied. The supporting detailed calculations are provided in Attachment B. Annualized costs associated with implementing proposed control technologies for the Pilot Plant are summarized in Attachment A. Supporting cost calculations are provided in Attachment B. For NOX, the annualized cost of LNB is $53,738 and ULNB is $39,514 which is not considered cost effective. In addition, the potential emissions from this operation are very low, resulting in an emissions reduction of approximately half a ton of NOX from either LNB or ULNB. In addition, the cost analysis is based on potential emissions. Since the Pilot Plant is only a research facility, actual emissions are considerably lower than potential emissions; therefore, the emissions reduction from adding NOX control would be negligible. Actual emissions fluctuate, but 12-month total NOX emissions based on December 2022 data were 0.02 tpy, which is less than 5 percent of potential emissions. Therefore, RACT for NOX is determined to be GCP and use of only natural gas fuel. The annualized cost of adding an RTO for VOC control is $2,506,691 per ton, which is not considered cost effective. In addition, the amount of actual VOC emissions that would be controlled from this process is very low. Therefore, RACT for VOC is determined to be GCP. Hexcel / Ozone RACT Analysis Trinity Consultants 5-1 5. RACT ANALYSIS FOR MATRIX The Prepreg and Matrix operations consists of two distinct phases, the mixing of the solvated resin and the application of the mixed resin to the woven graphite cloth/fabric. The production of the solvated resin consists of mixing specified resins with measured amounts of methyl ethyl ketone (MEK) and/or acetone. The MEK/acetone carrier allows the resin to distribute evenly over and into the fabric weave (impregnate). The application of this resin into woven graphite fabric consists of a piece of machinery (solvent coater) with a series of drive rollers, a dip bath, and a heated tower. The solvent coater assembly essentially impregnates the woven graphite fabric with a specified amount of solvated resin. Hexcel has recently upgraded the control technology associated with the Matrix Tower 1, Tower 3, and Tower 4 incinerators. These upgrades include installation of a more efficient incinerator for Tower 1 and RTOs for Towers 3 and 4 in place of the previously existing incinerators, all of which have combustion related emissions. The incinerator associated with Tower 1 does not have a limit on NOX. The RTOs on Towers 3 and 4 are equipped with LNB (maximum rating – 30 ppm NOX) on the main burners and duct trim burners. The discussion in Sections 1-3 regarding the available control technologies, technical feasibility of control methods, and ranking of control methods for the Fiber Lines is also relevant to the Matrix operations. Therefore, these Steps 1-3 will not be repeated here. VOC emissions from resin handling and mixing and the pre-preg process as well as Towers 3 and 4 all vent to RTO s which, based on previous steps in this analysis, is considered RACT. Therefore, these operations are not included in the evaluation for VOC emissions from the Matrix operations. Therefore, only VOC emissions from Tower 1 are included in the analysis. 5.1.1 Step 4 – Evaluate Most Effective Controls and Document Results The emissions used in the cost evaluation includes both NOX and VOC from combustion. Annualized costs associated with implementing proposed control technologies for the Matrix operation were calculated and are summarized in Attachment A. Supporting cost calculations are provided in Attachment B. For LNB, the cost analysis only includes NOX emissions from Tower 1, since Towers 3 and 4 are already equipped with LNB. The control cost is $111,169 per ton of NOX removed, which is considered not cost effective. For ULNB, the cost analysis includes NOX emissions from all three towers. The control cost is $68,037 per ton of NOX removed, which is not considered cost effective. For the RTO, the cost analysis includes only VOC emissions from Tower 1 since Towers 3 and 4 are already controlled by RTOs which is considered the highest level of control. The control cost is $120,602 per ton of VOC removed for Tower 1, which is considered not cost effective. 5.1.2 Step 5 – Select RACT Based on the analysis in Steps 1-4, RACT for both NOX and VOC for the Matrix operation is determined to be GCP and operation of all incinerators and burners with natural gas fuel, consistent with the Fiber Line RACT determinations. In addition, the following annual and short term- limits for NOX and VOC from Tower 1 is considered RACT: Hexcel / Ozone RACT Analysis Trinity Consultants 5-2 ► NOX • 6.15 tpy • 1.40 lbs/hr ► VOC • 4.00 tpy • 0.91 lbs/hr Hexcel / Ozone RACT Analysis Trinity Consultants 6-1 6. BOILERS Hexcel utilizes two natural gas boilers which have a maximum firing rate of 25 MMBtu/hr to support the manufacturing process. These units have a maximum NOX emission rate of 9 ppm. 6.1 RACT Analysis for NOX Emissions The NOX that will be formed during combustion is from two (2) major mechanisms: thermal NOX and fuel NOX. Since natural gas is relatively free of fuel-bound nitrogen, the contribution of this second mechanism to the formation of NOX emissions in natural gas-fired equipment is minimal, leaving thermal NOX as the main source of NOX emissions. Thermal NOX formation is a function of residence time, oxygen level, and flame temperature, and can be minimized by controlling these elements in the design of the combustion equipment. 6.1.1 Step 1 – Identify All Reasonably Available Control Technologies Hexcel reviewed a variety of sources including, but not limited to, the RBLC database, U.S. EPA fact sheets, and proposed UDAQ rules to identify potentially applicable control technologies. The technologies identified as possible NOX reduction are: 1. LNB, 2. ULNB, 3. FGR, 4. SCR, and 5. GCP. The control efficiencies associated with the listed technologies, along with technical and economic feasibility, are compared to the presumptive norm established in proposed UDAQ rule R307-316, NOX Emission Controls for Natural-Gas Fired Boilers greater than 5 MMBtu/hr, which requires the following: ► NOX Emission Rate of 9 ppmv; and ► Operate and Maintain (O&M) in accordance with manufacturer's instruction. 6.1.2 Step 2 – Eliminate Technically Infeasible Options To demonstrate a complete analysis, Hexcel has evaluated the following technologies including both replacement burners and add-on controls. Low NOX Burners LNB technology uses advanced burner design to reduce NOX formation through the restriction of oxygen, flame temperature, and/or residence time. There are two (2) general types of LNB: staged fuel and staged air burners. In a stage fuel LNB, the combustion zone is separated into two (2) regions. The first region is a lean combustion region where a fraction of the fuel is supplied with the total quantity of combustion air. Combustion in this zone takes place at substantially lower temperatures than a standard burner. In the second combustion region, the remaining fuel is injected and combusted with left over oxygen from the first region. A staged air burner begins with full fuel but only partial combustion air, and then adds the remaining combustion air in the second combustion region. These techniques reduce the formation of thermal NOX. This technology is listed in the RBLC search as a technically feasible control technology. Hexcel / Ozone RACT Analysis Trinity Consultants 6-2 Ultra-Low NOX Burners ULNB technology uses internal FGR which involves recirculating the hot O2 depleted flue gas from the heater into the combustion zone using burner design features and fuel staging to reduce NOX. An ULNB is most commonly using an internal induced draft to reach the desired emission limitations. This technology is listed in the RBLC search as a technically feasible control technology. An ULNB can achieve an emission rate of approximately 9 ppm or 0.011 pounds per million British thermal units (lb/MMBtu) when used in conjunction with FGR. Flue Gas Recirculation FGR is frequently used with both LNB and ULNB burners. FGR involves the recycling of post-combustion air into the air-fuel mixture to reduce the available oxygen and help cool the burner flame. External FGR requires the use of ductwork to route a portion of the flue gas in the stack back to the burner windbox; FGR can be either forced draft (where hot side fans are used) or induced draft. This technology is listed in the RBLC search as technically feasible and is paired with LNB for the BACT determined control technology. Selective Catalytic Reduction SCR has been applied to stationary source, fossil fuel-fired, combustion units for emission control since the early 1970s. It has been applied to utility and industrial boilers, process heaters, and combined cycle gas turbines. SCR can be applied as a stand-alone NOX control or with other technologies such as combustion controls. The reagent reacts selectively with the flue gas NOX within a specific temperature range and in the presence of the catalyst and oxygen to reduce the NOX into molecular nitrogen (N2) and water vapor (H2O).31 The optimum operating temperature is dependent on the type of catalyst and the flue gas composition. Generally, the optimum temperature ranges from 480°F to 800°F.32 In practice, SCR systems operate at efficiencies in the range of 70 to 90 percent.33 SCR is listed in the RBLC search as technically feasible. In some cases, this control technology is listed in combination with LNB and FGR. Good Combustion Practices The use of GCP usually includes the following components: (1) proper fuel mixing in the combustion zone; (2) high temperatures and low oxygen levels in primary zone; (3) Overall excess oxygen levels high enough to complete combustion while maximizing boiler efficiency, and (4) sufficient residence time to complete combustion. GCP are accomplished through boiler design as it relates to time, temperature, and turbulence, and boiler operation as it relates to excess oxygen levels. 6.1.3 Step 3 – Rank Remaining Control Technologies by Control Effectiveness Based on an RBLC search the following technologies are currently being used for boilers between 0 MMBtu/hr and 25 MMBtu/hr. These are ranked based on which technology can achieve the lowest emission rate. 31 Ibid. 32 OAQPS, EPA Air Pollution Control Cost Manual, Sixth Edition, EPA/424/B-02-001 (http://www.epa.gov/ttn/catc/dir1/c_allchs.pdf); January 2002 33 OAQPS, EPA Air Pollution Control Cost Manual, Sixth Edition, EPA/424/B-02-001 (http://www.epa.gov/ttn/catc/dir1/c_allchs.pdf); January 2002 Hexcel / Ozone RACT Analysis Trinity Consultants 6-3 1. LNB + SCR = 5 ppm or less 2. ULNB = 9 ppm or 0.011 lb/MMBtu 3. LNB = 30 ppm or 0.036 lb/MMBtu 4. FGR = 42 ppm or 0.05 lb/MMBtu 6.1.4 Step 4 – Evaluate Most Effective Controls and Document Results An SCR may be installed on each boiler to further lower the emission rate. Hexcel conducted a cost analysis following the method described in U.S. EPA Cost Control Manual Section 4 Chapter 2 Selective Catalytic Reduction Costs. Key to this analysis is the reduction removal efficiency and interest rate. For this analysis, Hexcel has used a reduction rate equivalent to a decreased emission rate of 5 ppm NOX.34 Since the actual nominal interest rate for a project of this type is not readily available to Hexcel, additional resources were reviewed to determine appropriate nominal interest rates for this industry sector and project type. One such resource was the Office of Management and Budget (OMB). For economic evaluations of the impact of federal regulations, the OMB uses an interest rate of 7 percent.35 A nominal interest rate of 7 percent has been referenced in U.S. EPA’s Cost Manual and has been commonly relied upon for control technology analyses for several decades as a representative average over time. Based on a 5 ppm NOX emission rate and 7 percent interest rate the cost per ton removed is $239,731. Calculations are shown in Appendix A and are based on U.S. EPA Cost Control Manual Section 4 Chapter 2 Selective Catalytic Reduction Costs and Section 1 Chapter 2 Cost Estimation: Concepts and Methodology. The cost per ton of NOX removed is beyond acceptable cost control effectiveness levels and therefore, Hexcel has determined that this technology is not cost effective for these units. 6.1.5 Step 5 – Select RACT The presumptive norm for the units in question is 9 ppm and O&M in accordance with manufacturer’s instructions. Hexcel meets the 9 ppm emission rate and completes O&M in accordance with manufacturer recommendations; however, the addition of SCR is not cost effective. As a result, Hexcel proposes that an emission rate of 9 ppm and appropriate O&M meet RACT. 6.2 RACT Analysis for VOC Emissions 6.2.1 Steps 1-5 – Select RACT Hexcel reviewed a variety of sources including, but not limited to, the RBLC database, U.S. EPA fact sheets, and proposed UDAQ rules to identify potentially applicable control technologies. The only control method identified was GCP. GCP for VOCs includes adequate fuel residence times, proper fuel-air mixing, and temperature control. As it is imperative for process controls, Hexcel will maintain combustion optimal to its process. Since all control methods identified are in use, Hexcel proposes RACT for the boilers is GCP and the use of clean burning fuel. 34 This emissions rate is representative of LAER. 35 OMB Circular A-4, https://obamawhitehouse.archives.gov/omb/circulars_a004_a-4/ Hexcel / Ozone RACT Analysis Trinity Consultants 7-1 7. EMERGENCY GENERATORS Diesel-fired engines are classified as compression ignition (CI) internal combustion engines (ICE). The primary pollutants in the exhaust gases include NOX and VOC. The diesel-fired engines installed at the Hexcel West Valley City Plant are for emergency use only (except for readiness testing and maintenance) and will use diesel fuel meeting the requirements of 40 CFR 1090.305 for non-road diesel fuel (i.e., a maximum sulfur content of 15 ppm and either a minimum cetane index of 40 or a maximum aromatic content of 35 percent by volume). Hexcel has multiple diesel-fired emergency generators permitted in Approval Order DAQE-AN113860035-22. ► Hexcel has small diesel-fired emergency generator engines that are each rated less than 600 HP and having a combined total capacity of up to 2,806 HP. ► Hexcel also has large diesel-fired emergency generator engines that are each rated greater than 600 HP and have a combined total capacity of up to 12,732 HP. U.S. EPA’s RBLC was queried to identify controls for other similar-sized emergency generator engines. The RBLC shows that most diesel-fired emergency generator engines have RACT emission limits or permitted emission limits under other regulatory programs at the promulgated 40 CFR Part 60 Subpart IIII Standards of Performance for Stationary Compression Ignition Internal Combustion Engines (NSPS Subpart IIII) emissions standards. The purpose and use of the engine are important considerations if an engine goes beyond NSPS Subpart IIII standards. Presented below are the five steps of the top-down RACT review for diesel-fired emergency generator engines. 7.1 RACT Analysis for NOX and VOC Emissions 7.1.1 Step 1 – Identify All Reasonably Available Control Technologies The least stringent emission rate allowable for RACT is any applicable limit under either NSPS – Part 60 or National Emission Standards for Hazardous Air Pollutants (NESHAP – Part 63). Emission limits for diesel-fired engines are limited by U.S. EPA’s Tier program established in 40 CFR 1039 and are referenced by NSPS Subpart IIII.36 Under these regulations U.S. EPA requires manufacturers to reduce the emissions from engines produced after certain dates in a tiered fashion, based on the size and model year. In general, the higher the tier rating, the lower the emissions produced. The engines evaluated under this RACT analysis are rated for emergency use only. Per NSPS Subpart IIII section 60.4202, U.S. EPA only requires emergency use engines to meet Tier 2 or Tier 3 standards based on the size of the unit.37 U.S. EPA established Tier 3 standards for all units rated between 50 BHP and 750 BHP and Tier 2 standards for all units rated above 750 BHP. It is the manufacturer’s responsibility to ensure that these units meet the established emission limitations or Tier rating. In order to ensure these emission limitations are met, manufacturers often incorporate design elements, such as turbochargers, aftercoolers, positive crankcase ventilation, and high-pressure fuel 36 Non-Emergency regulated per 40 CFR 60.4201, Emergency regulated by 40 CFR 60.4202, and General Requirements regulated per 40 CFR 60.4203. 37 Emergency engines are regulated in 40 CFR 60.4202 which sites only 40 CFR 1039.104, 1039.105, and 1039.15. Tier 4 final and Tier 4 interiem standards are given in 40 CFR 1039.101 and 1039.102, respectively, which are not referenced. Hexcel / Ozone RACT Analysis Trinity Consultants 7-2 injection. The incorporation of these design elements allows the units to meet minimum RACT standards and are therefore not further considered in this analysis. In order to identify additional control technologies applied to emergency use engines the following sources were reviewed: ► U.S. EPA’s RBLC Database for Diesel Generators (process types 17.110 Large Internal Combustion Engines [>500 HP] burning Fuel Oil and 17.210 Small Internal Combustion Engines [<500 HP] burning Fuel Oil);38 ► U.S. EPA’s Air Pollution Control Technology Fact Sheets; ► South Coast Air Quality Management District Example Permits; ► Texas Commission of Environmental Quality’s BACT Combustion Workbook; and ► Bay Area Air Quality Management District Nonroad BACT Assessments.39 The following control methods have been identified as potentially feasible for control of emissions from emergency generator engines: ► Limited Hours of Operation; ► GCP; ► Exhaust Gas Recirculation (EGR); ► Diesel Oxidation Catalyst (DOC); and ► SCR. 7.1.2 Step 2 – Eliminate Technically Infeasible Options Limited Hours of Operation One of the options to control the emissions of all pollutants released from emergency generator engines is to limit the hours of operation for the equipment. Due to the designation of this equipment as emergency equipment, only 100 hours of operation for maintenance and testing are permitted per NSPS Subpart IIII.40 Therefore, limiting hours of operation is considered technically feasible. Good Combustion Practices GCP refers to the operation of engines at high combustion efficiency, which reduces the products of incomplete combustion, such as VOC and CO. Emergency generator engines are designed to achieve high combustion efficiency when maintained and operated according to the manufacturer’s written instructions. GCP are considered technically feasible. Exhaust Gas Recirculation 38 Database accessed January 20, 2023. 39 BAAQMD presumes Tier 4 retrofit or Tier 4 compliant to meet BACT, which is defined as “The most stringent levels of control” and does not meet the presumptive norm established as RACT. https://www.baaqmd.gov/~/media/files/engineering/backup-diesel-generators/bact-webinar-presentation- pdf.pdf?la=en&rev=b12528d5cc11499c8e7e4a4aaa19b2eb 40 40 CFR 60.4211(f)(2) Hexcel / Ozone RACT Analysis Trinity Consultants 7-3 NOX reduction can be achieved through recirculating exhaust into the engine. EPA tests have demonstrated NOX reduction up to 50 percent if the engine timing is retarded, but test results are accompanied by an increase in particulates.41 Computer based control schemes can assist in NOX reduction with associated timing retardation, but EGR can also result in heat rejection, reduced power density, and lower fuel economy. Exhaust gas recirculation is considered technically infeasible. Diesel Oxidation Catalyst A DOC utilizes a catalyst such as platinum or palladium to oxidize VOC emissions in the engine’s exhaust to carbon dioxide (CO2) and water. Use of a DOC can result in approximately 90 percent reduction in VOC emissions.42 In addition to controlling VOC, a DOC also has the potential to reduce PM emissions by 30 percent (based on the concentration of soluble organics).43 However, the full reduction potential requires a minimum operating temperature of 150 ºC (300 ºF).44 Similarly U.S. EPA recommends if an engine emits extremely high levels of PM and/or idles for long periods of time, an exhaust backpressure monitoring and operator notification system may be installed to notify the operator when maintenance is needed.45 For this reason, DOC control efficiencies are expected to be relatively low during the first 20 - 30 minutes after engine start up, in fact U.S. EPA considered this method of aftertreatment to be generally unsuitable for backup use.46 Since operation of emergency engines typically only includes short duration runs and Hexcel does not require the engine to be brought to full load for monthly maintenance and testing, The engines are brought to full load during annual testing. DOC is considered technically ineffective for maintenance and testing.47 DOC is typically installed by manufacturers on prime engines and thus is considered technically infeasible for emergency operation. Selective Catalytic Reduction SCR systems introduce a liquid reducing agent such as ammonia or urea into an engine’s flue-gas stream prior to a catalyst. The catalyst reduces the temperature needed to initiate the reaction between the reducing agent and NOX to form nitrogen and water. Additional variations including non-selective catalytic reduction (NSCR) and selective non-catalytic reduction (SNCR) may be used but are not considered standard industry practice and are not listed in the RBLC, thus SCR remains the focus of this technical analysis. 41 U.S. EPA Control of Heavy-Duty Diesel NOx Emissions by Exhaust gas recirculation, Office of Mobile Source Air Pollution Emissions Control Technology Division, August 1985 42 U.S. EPA, Alternative Control Techniques Document: Stationary Diesel Engines, March 5, 2010, p. 41. (https://www.epa.gov/sites/production/files/2014-02/documents/3_2010_diesel_eng_alternativecontrol.pdf) 43 Response to Public Comments on Notice of Reconsideration of National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines and New Source Performance Standards for Stationary Internal Combustion Engines, EPA Docket EPA-HQ-OAR-2008-0708, June 16, 2014 44 U.S. EPA’s Technical Bulletin for Diesel Oxidation Catalyst Installation, Operation, and Maintenance, EPA-420-F-10-030 published in May 2010. 45 Ibid. 46 Response to Public Comments on Notice of Reconsideration of Nation,al Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines and New Source Performance Standards for Stationary Internal Combustion Engines, EPA Docket EPA-HQ-OAR-2008-0708, Page 85, June 16, 2014 47 Annual testing requires the engines being brought to full load, but this is a small percentage of the overall maintenance and testing operation time. Hexcel / Ozone RACT Analysis Trinity Consultants 7-4 For SCR systems to function effectively, exhaust temperatures must be high enough (480 °F to 800 °F) to enable catalyst activation, which will be accounted for in operation.48 For this reason, SCR control efficiencies are expected to be relatively low during the first 20 - 30 minutes after engine start up. Since operation of emergency engines typically only includes short duration runs for maintenance and testing, SCR is considered technically ineffective for maintenance and testing on a small engine. Furthermore, for emergency engines under 600 HP, the use of an SCR is generally considered experimental. Due to the low emission reduction potential on an emergency unit of this size these controls are not standard practice for manufacturers.49 This leads to compromised equipment design and high potential for failure. Based on the technical considerations presented above a SCR is considered technically feasible for emergency operation of units with a power rating greater than 600 HP. 7.1.3 Step 3 – Rank Remaining Control Technologies by Control Effectiveness Effective control technologies for diesel engines are listed in the following table: Table 7-1. Ranked Emergency Engine Controls Control Technically Feasible under 600 HP? (Yes/No) Technically Feasible above 600 HP? (Yes/No) Limited Hours of Operation Yes Yes GCP Yes Yes EGR No No DOC No No SCR No Yes All emergency engines installed after 2006 at Hexcel meet the NSPS standards. For generators that were installed prior to 2006, they met the EPA tier rating required at the time of installation. Additionally, all units proposed will operate for limited hours, using good combustion practices, and fueled by ultra-low sulfur diesel. The table below presents a summary of the proposed power rating and proposed technologies for each generator addressed in application. 7.1.4 Step 4 – Evaluate Most Effective Controls and Document Results As SCR control technology is technically feasible for emergency operation of units over 600 HP, Hexcel has conducted a cost analysis using the similar size generators (rated at 728 HP) as a baseline. Because of the negligible difference in engine size, the cost analysis is expected to be representative of all engines over 600 HP. SCR This cost analysis focused on NOX as the reduction potential for this pollutant is greater than all other criteria pollutants. Based on correspondence with a reputable manufacturer the approximate cost of add-on 48 EPA Air Pollution Control Technology Fact Sheet for Selective Catalytic Reduction (SCR), EPA-452/F-03-032 49 Call conducted with engine manufacturer on April 13, 2022 Hexcel / Ozone RACT Analysis Trinity Consultants 7-5 SCR controls is $159,500. After considering economic factors and other annual costs the calculated cost per ton removed is $72,070 per ton removed. Hexcel believes that this is not cost effective and was not further considered. A full cost analysis is included in Appendix C. 7.1.5 Step 5 – Select RACT Hexcel is proposing to install all technically and economically feasible controls which generally include engine design consistent with NSPS IIII, limited hours of operation, GCP and use of ULSD. Emission rates reflecting this RACT are included in the calculations contained in Appendix A. Hexcel / Ozone RACT Analysis Trinity Consultants 8-1 8. OTHER SMALL NATURAL GAS FURNACES There are several small muffle, rooftop, and other furnaces utilized to maintain appropriate temperatures within manufacturing spaces. As these units are < 5 MMBtu/hr and are direct fired add on controls are not technically feasible and have not been considered. 8.1 RACT Analysis for NOX Emissions 8.1.1 Step 1 – Identify All Reasonably Available Control Technologies Hexcel reviewed a variety of sources including, but not limited to, the RBLC database, U.S. EPA fact sheets, and proposed UDAQ rules to identify potentially applicable control technologies. The technologies identified as possible NOX reduction are: 1. LNB, 2. ULNB, and 3. GCP. No presumptive norm has been previously established for these units. 8.1.2 Step 2 – Eliminate Technically Infeasible Options To demonstrate a complete analysis, Hexcel has evaluated the following technologies. Low NOX Burners LNB technology uses advanced burner design to reduce NOX formation through the restriction of oxygen, flame temperature, and/or residence time. These techniques reduce the formation of thermal NOX. This technology is listed in some of the reviewed resources as a BACT limit. Ultra-low NOX Burners ULNB technology uses internal FGR which involves recirculating the hot O2 depleted flue gas from the heater into the combustion zone using burner design features and fuel staging to reduce NOX. This technology is listed in some of the reviewed resources as a BACT limit. Good Combustion Practices GCP are accomplished through furnace design as it relates to time, temperature, oxygen levels, and turbulence. Operation and maintenance in accordance with manufacturer recommendations is also considered a good combustion practice. 8.1.3 Steps 3 – 5 Based on an RBLC and other resources reviewed, the only commonly utilized control method for units similar to those installed at Hexcel is GCP and using natural gas. As a result, Hexcel proposes the implementation of GCP as RACT. If installed after 2006, all natural gas combustion sources are required to be low NOx burners in accordance with R307-401-4(3). Due to the size of most these units (<5 MMBtu), low emissions rates, and retrofit requirements, replacing burners with a ULNB is not cost effective. In addition, consideration needs to be given that installing a ULNB is not a typical configuration or design for HVAC units Hexcel / Ozone RACT Analysis Trinity Consultants 8-2 and would be very difficult to retrofit. For the larger units (>5 MMBtu) a cost analysis is included in Attachment A with supporting documentation included in Appendix B. The cost per ton removed for an SCR is $137,580 and for ULNB is $138,743 for the largest HVAC units. The cost per ton of NOX removed increases as the HVAC unit size decreases. As a result, additional controls for smaller HVAC units are considered not cost effective. 8.2 RACT Analysis for VOC Emissions 8.2.1 Steps 1 – 5 Hexcel reviewed a variety of sources including, but not limited to, the RBLC database, U.S. EPA fact sheets, and proposed UDAQ rules to identify potentially applicable control technologies. The only control method identified was GCP. GCP for VOCs include adequate fuel residence times, proper fuel-air mixing, and temperature control. As it is imperative for process controls, Hexcel will maintain combustion optimal to its process. Since all control methods identified are in use, Hexcel proposes RACT for the small gas furnaces is GCP and the use of clean burning fuel. Hexcel / Ozone RACT Analysis Trinity Consultants 9-1 9. RACT ANALYSIS FOR LABORATORY AND R&T FACILITY In 2023 Hexcel finished construction and put into operation a new laboratory and Research &Technology (R&T) facility at the West Valley City Plant. As a part of the Approval Order that was issued in October 2022, Hexcel submitted a BACT analysis with its Notice of Intent (NOI) air permit application. None of the control technologies or cost estimates have changed substantially since the time of application submittal. Therefore, Hexcel is not submitting a RACT analysis for the new R&T Facility at this time. Hexcel / Ozone RACT Analysis Trinity Consultants A-1 APPENDIX A. COST EFFECTIVENESS ANALYSIS Hexcel - Cost Analysis for Fiber Lines Site Name: Hexcel Corporation Salt Lake City Operations Site Location:West Valley City, UT Owner Name:Hexcel Corporation Component Description:Fiber Line 2 NOX VOC Good Combustion Practices Good Combustion Practices Natural Gas Natural Gas LNB Existing Incineration/ Flares ULNB with FGR Thermal Oxidization SCR SNCR NOX VOC 0.50 0.13 0.50 0.13 0.50 0.13 0.25 0.13 0.16 2.63E-03 NA1 NA1 NOX VOC -$ -$ -$ -$ NOX VOC -$ -$ -$ -$ NOX VOC $227,333.4 -$ 0.250 909,334$ -$ NOX VOC 227,333$ 299,218$ 0.340 0.13 668,628$ 2,323,628$ 1 -Not technically feasible Table A-1. Ozone RACT Summary - Fiber Line 2 Option 3 Cost/Benefit Analysis Summary Option 4 Cost/Benefit Analysis Summary Controlled Emissions Table (tpy): Emission Reduction (tpy) Annualized Cost ($) Cost Effectiveness ($/ton) Emission Reduction (tpy) Annualized Cost ($) RACT option 3 RACT option 2 RACT option 1 Existing Allowable Emissions RACT option 6 Cost Effectiveness ($/ton) Annualized Cost ($) Emission Reduction (tpy) Option 2 Cost/Benefit Analysis Summary RACT Option Analysis Option 1 Cost/Benefit Analysis Summary RACT option 6 RACT option 5 RACT option 4 RACT option 5 RACT option 4 RACT option 3 RACT option 2 RACT option 1 Cost Effectiveness ($/ton) Emission Reduction (tpy) Annualized Cost ($) Cost Effectiveness ($/ton) Hexcel | West Valley City Plant Page 1 of 23 Trinity Consultants Hexcel - Cost Analysis for Fiber Lines Site Name: Hexcel Corporation Salt Lake City Operations Site Location:West Valley City, UT Owner Name:Hexcel Corporation Component Description:Fiber Line 3 NOX VOC Good Combustion Practices Good Combustion Practices Natural Gas Natural Gas SCR Existing Incineration/ Flares SNCR Thermal Oxidization NOX VOC NA 4.68 NA1 4.68 NA2 4.68 NA3 4.68 NA3 0.09 NOX VOC -$ -$ -$ -$ NOX VOC -$ -$ -$ -$ NOX VOC -$ -$ -$ -$ NOX VOC -$ 665,091$ 4.58 -$ 145,080$ 1 -Considered technically feasible and cost effective 2 -Lower control efficiency than existing or future requirement 3 -Not technically feasible Table A-2. Ozone RACT Summary - Fiber Line 3 RACT Option Analysis Controlled Emissions Table (tpy): RACT option 4 RACT option 3 RACT option 2 RACT option 1 Annualized Cost ($) Existing Allowable Emissions Option 2 Cost/Benefit Analysis Summary RACT option 4 RACT option 3 RACT option 2 RACT option 1 Option 1 Cost/Benefit Analysis Summary Cost Effectiveness ($/ton) Emission Reduction (tpy) Annualized Cost ($) Cost Effectiveness ($/ton) Emission Reduction (tpy) Annualized Cost ($) Cost Effectiveness ($/ton) Cost Effectiveness ($/ton) Emission Reduction (tpy) Option 3 Cost/Benefit Analysis Summary Option 4 Cost/Benefit Analysis Summary Emission Reduction (tpy) Annualized Cost ($) Hexcel | West Valley City Plant Page 2 of 23 Trinity Consultants Hexcel - Cost Analysis for Fiber Lines Site Name: Hexcel Corporation Salt Lake City Operations Site Location:West Valley City, UT Owner Name:Hexcel Corporation Component Description:Fiber Line 4 NOX VOC Good Combustion Practices Good Combustion Practices Natural Gas Natural Gas SCR Existing Incineration/ Flares SNCR Thermal Oxidization NOX VOC NA 6.90 NA1 6.90 NA2 6.90 NA3 6.90 NA3 0.14 NOX VOC -$ -$ NOX VOC -$ -$ -$ -$ NOX VOC -$ -$ -$ -$ NOX VOC -$ 709,563$ 6.76 -$ 105,007$ 1 -Considered technically feasible and cost effective 2 -Lower control efficiency than existing or future requirement 3 -Not technically feasible Table A-3. Ozone RACT Summary - Fiber Line 4 RACT Option Analysis Controlled Emissions Table (tpy): RACT option 1 RACT option 2 RACT option 3 RACT option 4 Existing Allowable Emissions Option 3 Cost/Benefit Analysis Summary Option 4 Cost/Benefit Analysis Summary Annualized Cost ($) Emission Reduction (tpy) Cost Effectiveness ($/ton) Annualized Cost ($) Emission Reduction (tons) Cost Effectiveness ($/ton) Annualized Cost ($) Emission Reduction (tpy) Cost Effectiveness ($/ton) Cost Effectiveness ($/ton) RACT option 1 RACT option 2 RACT option 3 RACT option 4 Option 1 Cost/Benefit Analysis Summary Option 2 Cost/Benefit Analysis Summary Annualized Cost ($) Emission Reduction (tpy) Hexcel | West Valley City Plant Page 3 of 23 Trinity Consultants Hexcel - Cost Analysis for Fiber Lines Site Name: Hexcel Corporation Salt Lake City Operations Site Location:West Valley City, UT Owner Name:Hexcel Corporation Component Description:Fiber Line 5 NOX VOC Good Combustion Practices Good Combustion Practices Natural Gas Natural Gas LNB Existing Incineration/ Flares ULNB with FGR Thermal Oxidization SCR SNCR NOX VOC 21.21 5.34 NA1 5.34 NA1 5.34 10.61 5.34 6.79 0.11 NA2 NA2 NOX VOC -$ -$ -$ -$ NOX VOC -$ -$ -$ -$ NOX VOC $830,713.6 -$ 10.61 78,316$ -$ NOX VOC 830,714$ 774,563$ 14.43 5.23 57,585$ 148,081$ 1 -Considered technically feasible and cost effective 2 -Not technically feasible Table A-4. Ozone RACT Summary - Fiber Line 5 RACT Option Analysis Controlled Emissions Table (tpy): RACT option 1 RACT option 2 RACT option 3 RACT option 4 RACT option 5 RACT option 6 Emission Reduction (tpy) Cost Effectiveness ($/ton) Option 2 Cost/Benefit Analysis Summary Existing Allowable Emissions RACT option 1 RACT option 2 RACT option 3 Annualized Cost ($) Emission Reduction (tpy) Cost Effectiveness ($/ton) Annualized Cost ($) Annualized Cost ($) Emission Reduction (tpy) Cost Effectiveness ($/ton) RACT option 4 RACT option 5 RACT option 6 Annualized Cost ($) Option 1 Cost/Benefit Analysis Summary Option 3 Cost/Benefit Analysis Summary Option 4 Cost/Benefit Analysis Summary Emission Reduction (tpy) Cost Effectiveness ($/ton) Hexcel | West Valley City Plant Page 4 of 23 Trinity Consultants Hexcel - Cost Analysis for Fiber Lines Site Name: Hexcel Corporation Salt Lake City Operations Site Location:West Valley City, UT Owner Name:Hexcel Corporation Component Description:Fiber Line 6 NOX VOC Good Combustion Practices Good Combustion Practices Natural Gas Natural Gas LNB Existing Incineration/ Flares ULNB with FGR Thermal Oxidization SCR SNCR NOX VOC 14.10 12.09 NA1 12.09 NA1 12.09 7.05 12.09 4.51 0.24 NA2 NA2 NOX VOC -$ -$ -$ -$ NOX VOC -$ -$ -$ -$ NOX VOC 1,278,364$ -$ 7.05 181,391$ -$ NOX VOC 1,278,364$ 666,053$ 9.58 11.85 133,376$ 56,215$ 1 -Considered technically feasible and cost effective 2 -Not technically feasible Table A-5. Ozone RACT Summary - Fiber Line 6 RACT Option Analysis Controlled Emissions Table (tpy): RACT option 1 RACT option 2 RACT option 3 RACT option 4 RACT option 5 RACT option 6 Emission Reduction (tpy) Cost Effectiveness ($/ton) Option 2 Cost/Benefit Analysis Summary Existing Allowable Emissions RACT option 1 RACT option 2 RACT option 3 Annualized Cost ($) Emission Reduction (tpy) Cost Effectiveness ($/ton) Annualized Cost ($) Annualized Cost ($) Emission Reduction (tpy) Cost Effectiveness ($/ton) RACT option 4 RACT option 5 RACT option 6 Annualized Cost ($) Option 1 Cost/Benefit Analysis Summary Option 3 Cost/Benefit Analysis Summary Option 4 Cost/Benefit Analysis Summary Emission Reduction (tpy) Cost Effectiveness ($/ton) Hexcel | West Valley City Plant Page 5 of 23 Trinity Consultants Hexcel - Cost Analysis for Fiber Lines Site Name: Hexcel Corporation Salt Lake City Operations Site Location:West Valley City, UT Owner Name:Hexcel Corporation Component Description:Fiber Line 7 NOX VOC Good Combustion Practices Good Combustion Practices Natural Gas Natural Gas SCR Existing Incineration/ Flares SNCR Thermal Oxidization NOX VOC NA 6.01 NA1 6.01 NA2 6.01 NA3 6.01 NA3 0.12 NOX VOC -$ -$ -$ -$ NOX VOC -$ -$ -$ -$ NOX VOC -$ -$ -$ -$ NOX VOC -$ 843,724$ 5.89 -$ 143,344$ 1 -Considered technically feasible and cost effective 2 -Lower control efficiency than existing or future requirement 3 -Not technically feasible Table A-6. Ozone RACT Summary - Fiber Line 7 RACT Option Analysis Controlled Emissions Table (tpy): RACT option 1 RACT option 2 RACT option 3 RACT option 4 Existing Allowable Emissions Option 3 Cost/Benefit Analysis Summary Option 4 Cost/Benefit Analysis Summary Annualized Cost ($) Emission Reduction (tpy) Cost Effectiveness ($/ton) Annualized Cost ($) Emission Reduction (tpy) Cost Effectiveness ($/ton) Annualized Cost ($) Emission Reduction (tpy) Cost Effectiveness ($/ton) Cost Effectiveness ($/ton) RACT option 1 RACT option 2 RACT option 3 RACT option 4 Option 1 Cost/Benefit Analysis Summary Option 2 Cost/Benefit Analysis Summary Annualized Cost ($) Emission Reduction (tpy) Hexcel | West Valley City Plant Page 6 of 23 Trinity Consultants Hexcel - Cost Analysis for Fiber Lines Site Name: Hexcel Corporation Salt Lake City Operations Site Location:West Valley City, UT Owner Name:Hexcel Corporation Component Description:Fiber Line 8 NOX VOC Good Combustion Practices Good Combustion Practices Natural Gas Natural Gas LNB Existing Incineration/ Flares ULNB with FGR Thermal Oxidization SCR SNCR NOX VOC 8.10 24.73 NA1 24.73 NA1 24.73 4.05 24.73 2.59 0.49 NA2 NA2 NOX VOC -$ -$ -$ -$ NOX VOC -$ -$ -$ -$ NOX VOC $1,396,720.1 -$ 4.05 344,909$ -$ NOX VOC 1,396,720$ 1,455,122$ 5.51 24.23 253,610$ 60,050$ 1 -Considered technically feasible and cost effective 2 -Not technically feasible Table A-7. Ozone RACT Summary - Fiber Line 8 RACT Option Analysis Controlled Emissions Table (tpy): RACT option 1 RACT option 2 RACT option 3 RACT option 4 RACT option 5 RACT option 5 Emission Reduction (tpy) Cost Effectiveness ($/ton) Option 2 Cost/Benefit Analysis Summary Existing Allowable Emissions RACT option 1 RACT option 2 RACT option 3 Annualized Cost ($) Emission Reduction (tpy) Cost Effectiveness ($/ton) Annualized Cost ($) Annualized Cost ($) Emission Reduction (tpy) Cost Effectiveness ($/ton) RACT option 4 RACT option 5 RACT option 6 Annualized Cost ($) Option 1 Cost/Benefit Analysis Summary Option 3 Cost/Benefit Analysis Summary Option 4 Cost/Benefit Analysis Summary Emission Reduction (tpy) Cost Effectiveness ($/ton) Hexcel | West Valley City Plant Page 7 of 23 Trinity Consultants Hexcel - Cost Analysis for Fiber Lines Site Name: Hexcel Corporation Salt Lake City Operations Site Location:West Valley City, UT Owner Name:Hexcel Corporation Component Description:Fibler Line 10 NOX VOC Good Combustion Practices Good Combustion Practices Natural Gas Natural Gas LNB Existing Incineration/ Flares ULNB with FGR Thermal Oxidization SCR SNCR NOX VOC 8.10 24.44 NA1 24.44 NA1 24.44 4.05 24.44 2.59 0.49 NA2 NA2 NOX VOC -$ -$ -$ -$ NOX VOC -$ -$ -$ -$ NOX VOC $2,626,585.1 -$ 4.05 648,615$ -$ NOX VOC 2,626,585$ 1,455,122$ 5.51 23.95 476,923$ 60,764$ 1 -Considered technically feasible and cost effective 2 -Not technically feasible Table A-8. Ozone RACT Summary - Fiber Line 10 RACT Option Analysis Controlled Emissions Table (tpy): RACT option 1 RACT option 4 RACT option 3 RACT option 2 Emission Reduction (tpy) Annualized Cost ($) Option 2 Cost/Benefit Analysis Summary Cost Effectiveness ($/ton) Option 3 Cost/Benefit Analysis Summary Option 4 Cost/Benefit Analysis Summary Emission Reduction (tpy) Annualized Cost ($) Cost Effectiveness ($/ton) Cost Effectiveness ($/ton) Emission Reduction (tpy) Annualized Cost ($) Cost Effectiveness ($/ton) RACT option 5 RACT option 5 RACT option 4 RACT option 3 RACT option 2 RACT option 1 Existing Allowable Emissions Option 1 Cost/Benefit Analysis Summary RACT option 6 RACT option 5 Emission Reduction (tpy) Annualized Cost ($) Hexcel | West Valley City Plant Page 8 of 23 Trinity Consultants Hexcel - Cost Analysis for Fiber Lines Site Name: Hexcel Corporation Salt Lake City Operations Site Location:West Valley City, UT Owner Name:Hexcel Corporation Component Description:Fiber Line 11 NOX VOC Good Combustion Practices Good Combustion Practices Natural Gas Natural Gas LNB Existing Incineration/ Flares ULNB with FGR Thermal Oxidization SCR SNCR NOX VOC 8.10 24.92 NA1 24.92 NA1 24.92 4.05 24.92 2.59 0.50 NA2 NA2 NOX VOC -$ -$ -$ -$ NOX VOC -$ -$ -$ -$ NOX VOC 2,626,819$ -$ 4.05 648,673$ -$ NOX VOC 2,626,819$ 1,335,525$ 5.51 24.42 476,965$ 54,696$ 1 -Considered technically feasible and cost effective 2 -Not technically feasible Table A-9. Ozone RACT Summary - Fiber Line 11 RACT Option Analysis Controlled Emissions Table (tpy): RACT option 1 RACT option 2 RACT option 3 RACT option 4 RACT option 5 RACT option 5 Emission Reduction (tpy) Cost Effectiveness ($/ton) Option 2 Cost/Benefit Analysis Summary Existing Allowable Emissions RACT option 1 RACT option 2 RACT option 3 Emission Reduction (tpy) Cost Effectiveness ($/ton) Annualized Cost ($) Annualized Cost ($) Emission Reduction (tpy) Cost Effectiveness ($/ton) RACT option 4 RACT option 5 RACT option 6 Annualized Cost ($) Option 1 Cost/Benefit Analysis Summary Option 3 Cost/Benefit Analysis Summary Option 4 Cost/Benefit Analysis Summary Emission Reduction (tpy) Cost Effectiveness ($/ton) Annualized Cost ($) Hexcel | West Valley City Plant Page 9 of 23 Trinity Consultants Hexcel - Cost Analysis for Fiber Lines Site Name: Hexcel Corporation Salt Lake City Operations Site Location:West Valley City, UT Owner Name:Hexcel Corporation Component Description:Fiber Line 12 NOX VOC Good Combustion Practices Good Combustion Practices Natural Gas Natural Gas LNB Existing Incineration/ Flares ULNB with FGR Thermal Oxidization SCR SNCR NOX VOC 8.10 24.50 NA1 24.50 NA1 24.50 4.05 24.50 2.59 0.49 NA2 NA2 NOX VOC -$ -$ NOX VOC -$ -$ -$ -$ NOX VOC 2,626,819$ -$ 4.05 648,673$ -$ NOX VOC 2,626,819$ 1,335,525$ 5.51 24.01 476,965$ 55,613$ 1 -Considered technically feasible and cost effective 2 -Not technically feasible RACT option 5 RACT option 5 Annualized Cost ($) Emission Reduction (tpy) Cost Effectiveness ($/ton) RACT option 5 Existing Allowable Emissions RACT option 1 RACT option 6 Table A-10. Ozone RACT Summary - Fiber Line 12 Option 1 Cost/Benefit Analysis Summary RACT Option Analysis Controlled Emissions Table (tpy): RACT option 1 RACT option 2 RACT option 3 RACT option 4 RACT option 2 RACT option 3 RACT option 4 Annualized Cost ($) Emission Reduction (tpy) Cost Effectiveness ($/ton) Annualized Cost ($) Emission Reduction (tpy) Cost Effectiveness ($/ton) Option 2 Cost/Benefit Analysis Summary Option 3 Cost/Benefit Analysis Summary Option 4 Cost/Benefit Analysis Summary Annualized Cost ($) Emission Reduction (tpy) Cost Effectiveness ($/ton) Hexcel | West Valley City Plant Page 10 of 23 Trinity Consultants Hexcel - Cost Analysis for Pilot Fiber Line Site Name: Hexcel Corporation Salt Lake City Operations Site Location:West Valley City, UT Owner Name:Hexcel Corporation Site Location:Pilot Fiber Line NOX VOC Good Combustion Practices Good Combustion Practices Natural Gas Natural Gas Low NOx Burner Existing Incineration/ Flares Ultra Low NOx Burner with Flue Gas Recirculation Thermal Oxidization Selective Catalytic Reduction Selective Non- Catalytic Reduction NOX VOC 0.85 0.20 0.85 0.20 0.85 0.20 0.42 0.20 0.27 4.04E-03 NA1 NA1 NOX VOC -$ -$ -$ -$ NOX VOC -$ -$ -$ -$ NOX VOC $22,751.6 -$ 0.42 53,738$ -$ NOX VOC $22,751.6 $495,619 0.58 0.20 39,514$ 2,506,691$ 1 -Not technically feasible Table A-11. Ozone RACT Summary - Pilot Fiber Line RACT Option Analysis Controlled Emissions Table (tpy): RACT option 1 RACT option 2 RACT option 3 RACT option 4 RACT option 5 RACT option 5 Emission Reduction (tons) Cost Effectiveness ($/ton) Option 2 Cost/Benefit Analysis Summary Existing Allowable Emissions RACT option 1 RACT option 2 RACT option 3 Annualized Cost ($) Emission Reduction (tons) Cost Effectiveness ($/ton) Annualized Cost ($) Annualized Cost ($) Emission Reduction (tons) Cost Effectiveness ($/ton) RACT option 4 RACT option 5 RACT option 6 Annualized Cost ($) Option 1 Cost/Benefit Analysis Summary Option 3 Cost/Benefit Analysis Summary Option 4 Cost/Benefit Analysis Summary Emission Reduction (tons) Cost Effectiveness ($/ton) Hexcel | West Valley City Plant Page 11 of 23 Trinity Consultants Hexcel - Cost Analysis for Matrix Operations Site Name:Hexcel Corporation Salt Lake City Operations Site Location:West Valley City, UT Owner Name:Hexcel Corporation Component Description:Matrix Operations NOX VOC Good Combustion Practices Good Combustion Practices Natural Gas Natural Gas Low NOx Burner Existing Incineration/ Flares Ultra Low NOx Burner with Flue Gas Recirculation Thermal Oxidization Selective Catalytic Reduction Selective Non-Catalytic Reduction NOX VOC 6.15 4.00 6.15 4.00 6.15 4.00 1.36 4.00 3.94 0.08 NA1 NA1 NOX VOC -$ -$ -$ -$ NOX VOC -$ -$ -$ -$ NOX VOC 150,634$ -$ 1.36 111,169$ -$ NOX VOC 150,634$ 472,758$ 2.21 3.92 68,037$ 120,602$ 1 -Not technically feasible 2 -Only includes emissions from Tower 1, since Towers 3 and 4 already have LNB 3 -Includes emissions from Towers 1, 3, and 4 Table A-12. Ozone RACT Summary - Matrix Operations Option 1 Cost/Benefit Analysis Summary RACT option 1 RACT option 2 RACT option 4 RACT option 5 RACT option 5 Existing Allowable Emissions RACT Option Analysis RACT option 1 RACT option 2 Option 2 Cost/Benefit Analysis Summary Option 3 Cost/Benefit Analysis Summary Option 4 Cost/Benefit Analysis Summary Emission Reduction (tons) Cost Effectiveness ($/ton) Annualized Cost ($) Emission Reduction (tons) Cost Effectiveness ($/ton) Annualized Cost ($) Emission Reduction (tons) Cost Effectiveness ($/ton) Annualized Cost ($) Emission Reduction (tons) Cost Effectiveness ($/ton) Controlled Emissions Table (tpy): RACT option 32 RACT option 43 RACT option 5 RACT option 6 Annualized Cost ($) RACT option 3 Hexcel | West Valley City Plant Page 12 of 23 Trinity Consultants Hexcel - Cost Analysis for Boilers Table A-13. RACT Control Cost Evaluation for SCR Addition to Boiler - General Information Parameter Value Notes Heat Input 25.0 MMBTU/hr per unit Current Emission Rate 1.20 TPY, per unit Estimated Removal Efficiency 0.44 Assumes the estimated removal efficiency is based on a 9 ppm to 5 ppm reductions in emissions. Estimated Emission Rate 0.67 Estimated Ammonia Usage 0.22 lb/hr, Calculated using EPA Cost Control Manual Section 4 Chapter 2 Selective Catalytic Reduction Costs equation 2.35 Cost of Ammonia Reagent 0.27 $/lb, quote from Thatcher ($1.38/gallon for 19% ammonia) Cost of Catalyst 227.00 $/ft3, U.S. Environmental Protection Agency (EPA). Documentation for EPA’s Power Sector Modeling Platform v6 Using the Integrated Planning Model. Office of Air and Radiation. May 2018. Available at: https://www.epa.gov/airmarkets/documentation-epas-power-sector-modeling-platform-v6. Operator ($/hour)$28.50 Utah Department of Workforce Services, Occupational Wages by Region, Median Annual Wage for Installation/Maintenance/Repair, Machinery cited $59,300. Assumed a standard working year contains 2,080 hours. Equipment Life Expectancy (Years)25 EPA Cost Control Manual Section 4 Chapter 2 Selective Catalytic Reduction Costs average life expectancy for industrial boilers Interest Rate (%)7.00%OMB Circular A-4, https://obamawhitehouse.archives.gov/omb/circulars_a004_a-4/ Process Information Labor Costs Economic Factors Hexcel | West Valley City Plant Page 13 of 23 Trinity Consultants Hexcel - Cost Analysis for Boilers Table A-14. RACT Control Cost Evaluation for SCR Addition to Boiler - Capital Investment Parameter Value Notes Total Increase in Capital Investment ($)$468,000 Cost estimate based on communication with CECO Environmental December 2023, several sizes and costs were provided and a linear interpolation was applied. Direct Installation Costs $140,400 U.S. EPA's Alternative Control Techniques Document -- NOx Emissions from Industrial/Commercial/Institutional (ICI) Boilers, Section 6.1.1.2 Direct Installation Costs Indirect Installation Costs $154,440 U.S. EPA's Alternative Control Techniques Document -- NOx Emissions from Industrial/Commercial/Institutional (ICI) Boilers, Section 6.1.1.3 Indirect Installation Costs Contingency $117,000 This cost was added as the total equipment cost was obtained anonymously and a minimum equipment cost was provided. Freight $23,400 U.S. EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and Methodology, Table 2.4 Sales Tax $14,040 U.S. EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and Methodology, Table 2.4 Instrumentation $46,800 U.S. EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and Methodology, Table 2.4 Capital Recovery Factor (CRF)0.0858 EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and Methodology, Equation 2.8a Capital Recovery Cost (CRC)$40,159 EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and Methodology, Equation 2.8 Hexcel | West Valley City Plant Page 14 of 23 Trinity Consultants Hexcel - Cost Analysis for Boilers Table A-15. RACT Control Cost Evaluation for SCR Addition to Boiler - Annual Operating, Insurance, Tax, and Other Costs Parameter Value Notes Operating Labor $35,369 EPA Cost Control Manual Section 4 Chapter 2 Selective Catalytic Reduction Costs estimates 4 hours per day of Operating and Supervisory Labor. The estimate presented utilizes Section 1, Chapter 2's assumption tat 15% of operating labor is supervisory labor Supervisory Labor $6,242 Assumed to be 15% of operating Labor, EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and Methodology, Section 2.6.5.2 Maintenance Labor and Materials $2,340 EPA Cost Control Manual Section 4 Chapter 2 Selective Catalytic Reduction Costs estimates maintenance costs to be 0.5 percent of the total capital investment. Annual Reagent Costs $118 EPA Cost Control Manual Section 4 Chapter 2 Selective Catalytic Reduction Costs equation 2.58, assumed 2,000 hours of operation consistent with the reduced heat load Annual Electricity Costs $0 EPA Cost Control Manual Section 4 Chapter 2 Selective Catalytic Reduction Costs does not provide an equation for industrial, natural gas fired units. Estimated to be negligible for units of this size fired on natural gas. Annual Catalyst Costs $6,810 Catalyst size calculated based on information provided in EPA's Air Pollution Control Technology Fact Sheet for SCR (EPA-452/F-03-032). Assumed Catalyst life of 5 years. Total Direct Operating Costs $50,878 Sum of Direct Operating Costs on an Annual Basis Overhead $26,370 Assumed to be 60% of the total Direct Operating Costs, U.S. EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and Methodology, Section 2.6.5.7 Property Tax $4,680 Assumed to be 1% of the Total Capital Investment, U.S. EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and Methodology, Section 2.6.5.8 Increase in Insurance $4,680 Assumed to be 1% of the Total Capital Investment, U.S. EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and Methodology, Section 2.6.5.8 Administrative Charges $1,089 EPA Cost Control Manual Section 4, Chapter 2, Equation 2.69. Total Insurance, Tax, and Other Annual Costs $36,819 Sum of Insurance, Tax, and Other Annual Costs Table 16. RACT Control Cost Evaluation for SCR Addition to Boiler - Total Annual Cost & Cost per Ton Removed Parameter Value Notes Total Annual Cost $127,857 Sum of Capital Recovery Cost, Total Direct Operating Costs, Insurance, Tax and Other Annual Costs. NOX Removed (tpy)0.53 Cost per Ton of NOX Removed ($/ton)$239,731 NOX Cost Per Ton Removed Direct Operating Costs Insurance, Tax, and Other Annual Costs Hexcel | West Valley City Plant Page 15 of 23 Trinity Consultants Hexcel - Cost Analysis for Diesel Engines Table A-17. Control Cost Evaluation for SCR on an Emergency Use Diesel Engine - General Information Parameter Value Notes Duty (kW)1751 Mid-range generator size for units over 600hp Duty (bhp)2348 Approximate conversation from kW to hp is 1.341 hp/kW Tier II Emission NOx Rate (g/kW-hr)6.4 U.S. EPA Office of Transportation and Air Quality (U.S. EPA-420-B-16-022) published March 2016, Emission rate for NMHC+NOx was the published form, NMHC is anticipated to be a minor component of the emission factor. Tier II Emissions NOX (tpy)1.24 Total emission rate based on a maximum of 100 hr per year. Tier IV Emission NOx Rate (g/kW-hr)4.00 U.S. EPA Office of Transportation and Air Quality (U.S. EPA-420-B-16-022) published March 2016, Interim Standard used as it is in the same form as the Tier II published standard, NMHC is anticipated to be a minor component of the emission factor. Tier IV Final Emissions NOX (tpy)0.77 Controlled emissions provided by Tier IV Final Nonroad Compression-Ignition Engines: Exhaust Emission Standards for NOX. Equipment Life Expectancy (Years)15 Exemption to replacement engine provisions codified in 40 CFR 60.4210(i) Interest Rate (%)7.00%OMB Circular A-4, https://obamawhitehouse.archives.gov/omb/circulars_a004_a-4/ Table A-18. Control Cost Evaluation for SCR on an Emergency Use Diesel Engine - Capital Investment Parameter Value Notes Total Capital Investment ($)$159,500 Cost estimate based on estimates from several vendors, sizes, and costs were provided and a linear interpolation was applied. Cost in 2023 dollars. Capital Recovery Factor (CRF)0.1098 U.S. EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and Methodology, Equation 2.8a Capital Recovery Cost (CRC)$17,512 U.S. EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and Methodology, Equation 2.8 Process Information Economic Factors Hexcel | West Valley City Plant Page 16 of 23 Trinity Consultants Hexcel - Cost Analysis for Diesel Engines Table A-19. Control Cost Evaluation for SCR on an Emergency Use Diesel Engine - Annual Operating Costs Parameter Value Notes Operating Labor, Maintenance, Brake Specific Fuel Consumption, and Catalyst Maintenance $4 $/hp, U.S. EPA Alternative Control Techniques Document: Stationary Diesel Engines (U.S. EPA Contract No. EP-D-07-019) Published March 5, 2010, Cost values are cited to be from 2005 and have been lowered to match a run time of 100 hours. Inflation Factor 1.69 Based on U.S. Bureau of Labor Statistics CPI Inflation Calculator from January of 2003 to October of 2023. https://www.bls.gov/data/inflation_calculator.htm Total Direct Operating Costs $15,873 Table A-20. BACT Control Cost Evaluation for SCR on an Emergency Use Diesel Engine - Annual Operating, Insurance, Tax, and Other Costs Parameter Value Notes Total Annual Cost $33,386 Sum of Capital Recovery Cost, Total Direct Operating Costs, Insurance, Tax and Other Annual Costs. NOX Removed (tpy)0.46 Cost per Ton of NOX Removed ($/ton)$72,070 Direct Operating Costs NOX Cost Per Ton Removed Hexcel | West Valley City Plant Page 17 of 23 Trinity Consultants Hexcel - Cost Analysis for HVAC Units Table A-21. RACT Control Cost Evaluation for SCR Addition to HVAC Unit - General Information Parameter Value Notes Heat Input 2.3 MMBTU/hr per unit, based on the largest HVAC unit Current Emission Rate 1.00 TPY, per unit Estimated Removal Efficiency 0.89 Assumes the estimated removal efficiency is based on a 80 ppm to 9 ppm reductions in emissions. Estimated Emission Rate 0.11 Estimated Ammonia Usage 0.04 lb/hr, Calculated using EPA Cost Control Manual Section 4 Chapter 2 Selective Catalytic Reduction Costs equation 2.35 Cost of Ammonia Reagent 0.27 $/lb, quote from Thatcher ($1.38/gallon for 19% ammonia) Cost of Catalyst 227.00 $/ft3, U.S. Environmental Protection Agency (EPA). Documentation for EPA’s Power Sector Modeling Platform v6 Using the Integrated Planning Model. Office of Air and Radiation. May 2018. Available at: https://www.epa.gov/airmarkets/documentation-epas-power-sector- modeling-platform-v6. Operator ($/hour)$28.50 Utah Department of Workforce Services, Occupational Wages by Region, Median Annual Wage for Installation/Maintenance/Repair, Machinery cited $59,300. Assumed a standard working year contains 2,080 hours. Equipment Life Expectancy (Year 25 EPA Cost Control Manual Section 4 Chapter 2 Selective Catalytic Reduction Costs (Indirect annual costs, page 79) average life expectancy for industrial process units Interest Rate (%)7.00%U.S. EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and Methodology Process Information Labor Costs Economic Factors Hexcel | West Valley City Plant Page 18 of 23 Trinity Consultants Hexcel - Cost Analysis for HVAC Units Table A-22. RACT Control Cost Evaluation for SCR Addition to HVAC Unit - Capital Investment Parameter Value Notes Total Increase in Capital Investment ($)418,312$ Cost estimate based on communication with CECO Environmental December 2023, several sizes and costs were provided and a linear interpolation was applied. Direct Installation Costs $125,494 U.S. EPA's Alternative Control Techniques Document -- NOx Emissions from Industrial/Commercial/Institutional (ICI) Boilers, Section 6.1.1.2 Direct Installation Costs Indirect Installation Costs $138,043 U.S. EPA's Alternative Control Techniques Document -- NOx Emissions from Industrial/Commercial/Institutional (ICI) Boilers, Section 6.1.1.3 Indirect Installation Costs Contingency $104,578 This cost was added as the total equipment cost was obtained anonymously and a minimum equipment cost was provided. Freight $20,916 U.S. EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and Methodology, Table 2.4 Sales Tax $12,549 U.S. EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and Methodology, Table 2.4 Instrumentation $41,831 U.S. EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and Methodology, Table 2.4 Capital Recovery Factor (CRF)0.0858 EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and Methodology, Equation 2.8a Capital Recovery Cost (CRC)$35,896 EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and Methodology, Equation 2.8 Hexcel | West Valley City Plant Page 19 of 23 Trinity Consultants Hexcel - Cost Analysis for HVAC Units Table A-23. RACT Control Cost Evaluation for SCR Addition to HVAC Unit - Annual Operating, Insurance, Tax, and Other Costs Parameter Value Notes Operating Labor $35,369 EPA Cost Control Manual Section 4 Chapter 2 Selective Catalytic Reduction Costs estimates 4 hours per day of Operating and Supervisory Labor. The estimate presented utilizes Section 1, Chapter 2's assumption tat 15% of operating labor is supervisory labor Supervisory Labor $6,242 Assumed to be 15% of operating Labor, EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and Methodology, Section 2.6.5.2 Maintenance Labor and Materials $2,092 EPA Cost Control Manual Section 4 Chapter 2 Selective Catalytic Reduction Costs estimates maintenance costs to be 0.5 percent of the total capital investment. Annual Reagent Costs $22 EPA Cost Control Manual Section 4 Chapter 2 Selective Catalytic Reduction Costs equation 2.58, assumed 2,000 hours of operation consistent with the reduced heat load Annual Electricity Costs $0 EPA Cost Control Manual Section 4 Chapter 2 Selective Catalytic Reduction Costs does not provide an equation for industrial, natural gas fired units. Estimated to be negligible for units of this size fired on natural gas. Annual Catalyst Costs $6,810 Catalyst size calculated based on information provided in EPA's Air Pollution Control Technology Fact Sheet for SCR (EPA-452/F-03-032). Assumed Catalyst life of 5 years. Total Direct Operating Costs $50,534 Sum of Direct Operating Costs on an Annual Basis Overhead $26,221 Assumed to be 60% of the total Direct Operating Costs, U.S. EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and Methodology, Section 2.6.5.7 Property Tax $4,183 Assumed to be 1% of the Total Capital Investment, U.S. EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and Methodology, Section 2.6.5.8 Increase in Insurance $4,183 Assumed to be 1% of the Total Capital Investment, U.S. EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and Methodology, Section 2.6.5.8 Administrative Charges $1,086 EPA Cost Control Manual Section 4, Chapter 2, Equation 2.69. Total Insurance, Tax, and Other Annual Costs $35,673 Sum of Insurance, Tax, and Other Annual Costs Table A-24. RACT Control Cost Evaluation for SCR Addition to HVAC Unit - Total Annual Cost & Cost per Ton Removed Parameter Value Notes Total Annual Cost $122,103 Sum of Capital Recovery Cost, Total Direct Operating Costs, Insurance, Tax and Other Annual Costs. NOX Removed (tpy)0.89 Cost per Ton of NOX Removed ($/ton)$137,580 NOX Cost Per Ton Removed Direct Operating Costs Insurance, Tax, and Other Annual Costs Hexcel | West Valley City Plant Page 20 of 23 Trinity Consultants Hexcel - Cost Analysis for HVAC Units Table A-25. RACT Control Cost Evaluation for HVAC LNB Replacement - General Information Parameter Value Notes Heat Input 2.3 MMBTU/hr per unit, based on the largest HVAC unit Current Emission Rate 1.00 TPY, per unit, Using lb/MMBtu Reduction Efficiency 75%Estimated using the EPA's Technical Bulletin, Nitrogen Oxides, Why and How They are Controlled (EPA456/F-99-006R). Estimated Emission Rate 0.25 TPY, per unit Operator ($/hour)$28.50 Utah Department of Workforce Services, Occupational Wages by Region, Median Annual Wage for Installation/Maintenance/Repair, Machinery cited $59,300. Assumed a standard working year contains 2,080 hours. Maintenance ($/hour)$28.50 Utah Department of Workforce Services, Occupational Wages by Region, Median Annual Wage for Installation/Maintenance/Repair, Machinery cited $59,300. Assumed a standard working year contains 2,080 hours. Equipment Life Expectancy (Years)10 Alternative Control Techniques Document -- NOX Emissions from Industrial/Commercial/Institutional (ICI) Boilers, Section 6.1.3 Total Annualized Cost and Cost Effectiveness Interest Rate (%)7.00%U.S. EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and Methodology Process Information Labor Costs Economic Factors Hexcel | West Valley City Plant Page 21 of 23 Trinity Consultants Hexcel - Cost Analysis for HVAC Units Table A-26. RACT Control Cost Evaluation for HVAC LNB Replacement - Capital Investment Parameter Value Notes Total Equipment Cost $66,000 Cost estimate based on communication with Holbrook Servco December 2023, several sizes and costs were provided and a linear interpolation was applied. Direct Installation Costs $68,400 Cost estimate based on communication with Holbrook Servco December 2023, several sizes and costs were provided and a linear interpolation was applied. Contingency $13,680 This cost was added as the total equipment cost was obtained anonymously and based on a linear correlation between equipment sizes. 20% of the direct and indirect capital costs was recommended by U.S. EPA's Alternative Control Techniques Document -- NOX Emissions from Industrial/Commercial/Institutional (ICI) Boilers, Section 6.1.1.4 Contingencies. Freight $3,300 EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and Methodology, Table 2.4 Sales Tax $1,980 EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and Methodology, Table 2.4 Instrumentation $6,600 EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and Methodology, Table 2.4 Total Increase in Capital Investment ($)$159,960 Sum of total equipment, direct installation, indirect installation, contingency, freight, sales tax, and instrumentation costs. Capital Recovery Factor (CRF)0.1424 EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and Methodology, Equation 2.8a Capital Recovery Cost (CRC)$22,775 EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and Methodology, Equation 2.8 Hexcel | West Valley City Plant Page 22 of 23 Trinity Consultants Hexcel - Cost Analysis for HVAC Units Table A-27. RACT Control Cost Evaluation for HVAC LNB Replacement - Annual Operating, Insurance, Tax, and Other Costs Parameter Value Notes Operating Labor $15,604 Assumed 0.5 hours per 8-hour shift Supervisory Labor $2,341 Assumed to be 15% of operating Labor, EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and Methodology, Section 2.6.5.2 Maintenance Labor $15,604 Assumed 0.5 hours per 8-hour shift Maintenance Materials $15,604 Assumed the same as Maintenance Labor per EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and Methodology, Section 2.6.5.3 Total Direct Operating Costs $49,152 Sum of Direct Operating Costs on an Annual Basis Overhead $29,491 Assumed to be 60% of the total Direct Operating Costs, EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and Methodology, Section 2.6.5.7 Administrative Charges $1,320 Assumed to be 2% of the Total Capital Investment, EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and Methodology, Section 2.6.5.8 Property Tax $660 Assumed to be 1% of the Total Capital Investment, EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and Methodology, Section 2.6.5.8 Increase in Insurance $660 Assumed to be 1% of the Total Capital Investment, EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and Methodology, Section 2.6.5.8 Total Insurance, Tax, and Other Annual Costs $32,131 Sum of Insurance, Tax, and Other Annual Costs Table A-28. RACT Control Cost Evaluation for HVAC LNB Replacement - Annual Operating, Insurance, Tax, and Other Costs Parameter Value Notes Total Annual Cost $104,058 Sum of Capital Recovery Cost, Total Direct Operating Costs, Insurance, Tax and Other Annual Costs. NOX Removed (tpy)0.75 Cost per Ton of NOX Removed ($/ton)$138,743 1. While this cost analysis sites the EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and Methodology, the cost estimates used for a retrofit are consistent in Alternative Control Techniques Document -- NOx Emissions from Industrial/Commercial/Institutional (ICI) Boilers, Section 6.1.2 Annual Operations and Maintenance (O&M) Costs Direct Operating Costs Insurance, Tax, and Other Annual Costs1 NOX Cost Per Ton Removed Hexcel | West Valley City Plant Page 23 of 23 Trinity Consultants Hexcel / Ozone RACT Analysis Trinity Consultants B-1 APPENDIX B. SUPPORTING COST CALCULATIONS LNB Annualized Cost Estimate for NOX Control Table B-1. Vendor Estimated Low NOX Burner Costs Table B-2. Hexcel Burner Countb Capacity Basic Equipment Costb Total Installed Costa $/MMBtu Hexcel Line No. Equipment <=750,000 BTU/hr Equipment > 0.75 MMBtu/hr and <=2.7 MMBtu/hr Equipment > 2.7 MMBTU and <=13 MMBtu/hr 750,000 BTU/hr $33,374 $87,270 $116,360 2 1 0 0 2.7 MMBtu/hr $40,552 $95,644 $35,424 5 0 9 0 13 MMBtu/hr $71,112 $132,596 $10,200 6 1 8 0 8 1 8 0 10 1 8 0 11 1 8 0 12 1 8 0 PILOT 1 0 0 Matrix 0 0 1 bFiber Lines 3, 4, and 7 will have ULNB installed by December 31, 2014 and Fiber Lines 13-16 are designed with both LNB and a DeNOx water system, which provides the lowest emission rate available for all lines. Therefore these Fiber Lines are not part of this assessment. a Cost estimate based on communication with Holbrook Servco December 2023, several sizes and costs were provided and a linear interpolation was applied. Hexcel | West Valley City Plant Page 1 of 7 Trinity Consultants LNB Annualized Cost Estimate for NOX Control Table B-3. Annualized LNB Cost Per Hexcel Line 2 5 6 8 10 11 12 Direct Costs Purchased equipment costs Total Purchased Equipment Cost (Burners)PECd $2,187,301 $33,374 $364,969 $357,791 $357,791 $357,791 $357,791 $357,791 $33,374 $280,086 Installation Costs Total Direct Installation Cost DICd $3,022,883 $53,896 $495,828 $494,632 $494,632 $494,632 $494,632 $494,632 $53,896 $292,241 Total Direct Costs (TDC)PEC + DIC $5,210,184 $87,270 $860,798 $852,423 $852,423 $852,423 $852,423 $852,423 $87,270 $572,326 Indirect Installation Costs Engineering 0.10 PEC $218,730 $3,337 $36,497 $35,779 $35,779 $35,779 $35,779 $35,779 $3,337 $28,009 Construction & field expenses 0.10 PEC $218,730 $3,337 $36,497 $35,779 $35,779 $35,779 $35,779 $35,779 $3,337 $28,009 Contractor fees 0.10 PEC $218,730 $3,337 $36,497 $35,779 $35,779 $35,779 $35,779 $35,779 $3,337 $28,009 Start-up 0.01 PEC $21,873 $334 $3,650 $3,578 $3,578 $3,578 $3,578 $3,578 $334 $2,801 Performance test 0.01 PEC $21,873 $334 $3,650 $3,578 $3,578 $3,578 $3,578 $3,578 $334 $2,801 Contingencies 0.03 PEC $65,619 $1,001 $10,949 $10,734 $10,734 $10,734 $10,734 $10,734 $1,001 $8,403 Total Indirect Costs, IC 0.35 PEC $765,555 $11,681 $127,739 $125,227 $125,227 $125,227 $125,227 $125,227 $11,681 $98,030 TOTAL CAPITAL INVESTMENTe (DC + IC) * 1.4 (retrofit factor)$8,366,035 $138,531 $1,383,952 $1,368,710 $1,368,710 $1,368,710 $1,368,710 $1,368,710 $138,531 $938,499 Annual Cost Summary Total Direct Annual Cost Operation/Maintenance Costf DAC $101,382 $1,843 $16,590 $16,590 $16,590 $16,590 $16,590 $16,590 $1,843 $1,843 Profit Loss Revenue Lost per 24-hour down timeh $/24 hours NA $9,700 $28,690 $50,075 $55,900 $114,465 $114,465 $114,465 NA NA Days Required for Retrofith days lost 21 21 21 21 21 21 21 Total Profit Lost PL = $/hr*hours lost NA $203,700 $602,490 $1,051,575 $1,173,900 $2,403,765 $2,403,765 $2,403,765 NA NA Indirect Annual Costs Labor Ratiog 0.9136 0.4060 0.4916 0.0928 0.0928 0.1163 0.1163 0.1163 0.1163 Overhead 60% of sum of operating and maintenance labor $14,107 $1,010 $4,041 $4,893 $924 $924 $1,157 $1,157 $129 $129 Administrative charges 2% of TCI $167,321 $2,771 $27,679 $27,374 $27,374 $27,374 $27,374 $27,374 $2,771 $18,770 Property tax 1% of TCI $83,660 $1,385 $13,840 $13,687 $13,687 $13,687 $13,687 $13,687 $1,385 $9,385 Insurance 1% of TCI $83,660 $1,385 $13,840 $13,687 $13,687 $13,687 $13,687 $13,687 $1,385 $9,385 Capital recovery factor 15 Years, 7% Interest 0.11 0.11 0.11 0.11 0.11 0.11 0.11 0.11 0.11 Capital Recoveryi CRF*TCI $920,264 $15,238 $152,235 $150,558 $150,558 $150,558 $150,558 $150,558 $15,238 $103,235 Total Indirect Annual Costs Total $1,269,012 $21,790 $211,634 $210,200 $206,230 $206,230 $206,464 $206,464 $20,908 $140,903 TOTAL ANNUAL COST $11,613,354 $227,333 $830,714 $1,278,364 $1,396,720 $2,626,585 $2,626,819 $2,626,819 $22,752 $142,747 Maximum estimated 1993 Capital Cost ($/MMBtu)$8,300 Maximum estimated 1993 Operational Cost ($/MMBtu)$1,500 Estimated 2011 Operational Cost ($/MMBtu)$1,843 = $11,538/$8,300 * $2,085 (mid-range (for 13 MMBtu/hr burner) estimated 2011 $/MMBtu was used for the calculation) g Ratio of operation and Maintenance labor costs to total operation and maintenance costs from scrubber operations h Lost Revenue and days required for retrofit estimated by Hexcel 12/19/11. i Office of Air Quality Planning and Standards (OAQPS), EPA Air Pollution Control Cost Manual, Sixth Edition, Sec 6, Chpt 2, Table 2.9, EPA 452-B-02-001 (http://www.epa.gov/ttn/catc/products.html#cccinfo), Mussatti and Hemmer, July 2002. f. EPA Technical Bulletin, Nitrogen Oxides (NOx) Why and How They Are Controlled, EPA/456/F-99-006R (http://epa.gov/ttn/catc/dir1/fnoxdoc.pdf), November 1999. Operational costs obtained from Table 14 - Costs of NOx Controls, multiplied by a ratio of 2011 capital costs to 1993 capital costs, to estimate 2011 operational costs. d. Email correspondence between Chris Paul (Western Combustion Engineering) and John Falcetti (Trinity) on November 28, 2011. e Retrofit factors are not mentioned for Low NOX burners in the OAQPS Manual. Thus, the retrofit factor for a venturi scrubber is applied. Retrofit factor based on average of 1.3 - 1.5, provided in OAQPS Manual, Section 6, Chapter 2, Page 2-49. c Unless otherwise noted, equations are taken from U.S. Environmental Protection Agency, EPA Air Pollution Control Cost manual, Sixth Edition. EPA/452/B-02-001, January 2002. PILOT MatrixHexcel Line No.Parameter Equationc Total Value Hexcel | West Valley City Plant Page 2 of 7 Trinity Consultants ULNB Annualized Cost Estimate for NOX Control Table B-4. Vendor Estimated ULNB Costs Table B-5. Hexcel Burner Countb Capacity Basic Equipment Costb Total Installed Costa $/MMBtu Hexcel Line No. Equipment <=750,000 BTU/hr Equipment > 0.75 MMBtu/hr and <=2.7 MMBtu/hr Equipment > 2.7 MMBTU and <=13 MMBtu/hr 750,000 BTU/hr $33,374 $87,270 $116,360 2 1 0 0 2.7 MMBtu/hr $40,552 $95,644 $35,424 5 0 9 0 13 MMBtu/hr $71,112 $132,596 $10,200 6 1 8 0 8 1 8 0 10 1 8 0 11 1 8 0 12 1 8 0 PILOT 1 0 0 Matrix 2 0 3 b Fiber Lines 3, 4, and 7 will have ULNB installed by December 31, 2014 and Fiber Lines 13-16 are designed with both LNB and a DeNOx water system, which provides the lowest emission rate available for all lines. Therefore these Fiber Lines are not part of this assessment. a Cost estimate based on communication with Holbrook Servco December 2023, several sizes and costs were provided and a linear interpolation was applied. Hexcel | West Valley City Plant Page 3 of 7 Trinity Consultants ULNB Annualized Cost Estimate for NOX Control Table B-6. Annualized ULNB Cost Per Hexcel Line 2 5 6 8 10 11 12 Direct Costs Purchased equipment costs Total Purchased Equipment Cost (Burners)PECd $2,187,301 $33,374 $364,969 $357,791 $357,791 $357,791 $357,791 $357,791 $33,374 $280,086 Installation Costs Total Direct Installation Cost DICd $3,022,883 $53,896 $495,828 $494,632 $494,632 $494,632 $494,632 $494,632 $53,896 $292,241 Total Direct Costs (TDC)PEC + DIC $5,210,184 $87,270 $860,798 $852,423 $852,423 $852,423 $852,423 $852,423 $87,270 $572,326 Indirect Installation Costs Engineering 0.10 PEC $218,730 $3,337 $36,497 $35,779 $35,779 $35,779 $35,779 $35,779 $3,337 $28,009 Construction & field expenses 0.10 PEC $218,730 $3,337 $36,497 $35,779 $35,779 $35,779 $35,779 $35,779 $3,337 $28,009 Contractor fees 0.10 PEC $218,730 $3,337 $36,497 $35,779 $35,779 $35,779 $35,779 $35,779 $3,337 $28,009 Start-up 0.01 PEC $21,873 $334 $3,650 $3,578 $3,578 $3,578 $3,578 $3,578 $334 $2,801 Performance test 0.01 PEC $21,873 $334 $3,650 $3,578 $3,578 $3,578 $3,578 $3,578 $334 $2,801 Contingencies 0.03 PEC $65,619 $1,001 $10,949 $10,734 $10,734 $10,734 $10,734 $10,734 $1,001 $8,403 Total Indirect Costs, IC 0.35 PEC $765,555 $11,681 $127,739 $125,227 $125,227 $125,227 $125,227 $125,227 $11,681 $98,030 TOTAL CAPITAL INVESTMENTe (DC + IC) * 1.4 (retrofit factor)$8,366,035 $138,531 $1,383,952 $1,368,710 $1,368,710 $1,368,710 $1,368,710 $1,368,710 $138,531 $938,499 Annual Cost Summary Total Direct Annual Cost Operation/Maintenance Costf DAC $101,382 $1,843 $16,590 $16,590 $16,590 $16,590 $16,590 $16,590 $1,843 $9,217 Profit Loss Revenue Lost per 24-hour down timeh $/24 hours NA $9,700 $28,690 $50,075 $55,900 $114,465 $114,465 $114,465 NA NA Days Required for Retrofith days lost 21 21 21 21 21 21 21 Total Profit Lost PL = $/hr*hours lost NA $203,700 $602,490 $1,051,575 $1,173,900 $2,403,765 $2,403,765 $2,403,765 NA NA Indirect Annual Costs Labor Ratiog 0.9136 0.4060 0.4916 0.0928 0.0928 0.1163 0.1163 0.1163 0.1163 Overhead 60% of sum of operating and maintenance labor $14,107 $1,010 $4,041 $4,893 $924 $924 $1,157 $1,157 $129 $643 Administrative charges 2% of TCI $167,321 $2,771 $27,679 $27,374 $27,374 $27,374 $27,374 $27,374 $2,771 $18,770 Property tax 1% of TCI $83,660 $1,385 $13,840 $13,687 $13,687 $13,687 $13,687 $13,687 $1,385 $9,385 Insurance 1% of TCI $83,660 $1,385 $13,840 $13,687 $13,687 $13,687 $13,687 $13,687 $1,385 $9,385 Capital recovery factor 15 Years, 7% Interest 0.11 0.11 0.11 0.11 0.11 0.11 0.11 0.11 0.11 Capital Recoveryi CRF*TCI $920,264 $15,238 $152,235 $150,558 $150,558 $150,558 $150,558 $150,558 $15,238 $103,235 Total Indirect Annual Costs Total $1,269,012 $21,790 $211,634 $210,200 $206,230 $206,230 $206,464 $206,464 $20,908 $141,418 TOTAL ANNUAL COST $11,613,354 $227,333 $830,714 $1,278,364 $1,396,720 $2,626,585 $2,626,819 $2,626,819 $22,752 $150,634 Maximum estimated 1993 Capital Cost ($/MMBtu)$8,300 Maximum estimated 1993 Operational Cost ($/MMBtu)$1,500 Estimated 2011 Operational Cost ($/MMBtu)$1,843 = $11,538/$8,300 * $2,085 (mid-range (for 13 MMBtu/hr burner) estimated 2011 $/MMBtu was used for the calculation) g Ratio of operation and Maintenance labor costs to total operation and maintenance costs from scrubber operations h Lost Revenue and days required for retrofit estimated by Hexcel 12/19/11. i Office of Air Quality Planning and Standards (OAQPS), EPA Air Pollution Control Cost Manual, Sixth Edition, Sec 6, Chpt 2, Table 2.9, EPA 452-B-02-001 (http://www.epa.gov/ttn/catc/products.html#cccinfo), Mussatti and Hemmer, July 2002. f. EPA Technical Bulletin, Nitrogen Oxides (NOx) Why and How They Are Controlled, EPA/456/F-99-006R (http://epa.gov/ttn/catc/dir1/fnoxdoc.pdf), November 1999. Operational costs obtained from Table 14 - Costs of NOx Controls, multiplied by a ratio of 2011 capital costs to 1993 capital costs, to estimate 2011 operational costs. c Unless otherwise noted, equations are taken from U.S. Environmental Protection Agency, EPA Air Pollution Control Cost manual, Sixth Edition. EPA/452/B-02-001, January 2002. d. Email correspondence between Chris Paul (Western Combustion Engineering) and John Falcetti (Trinity) on November 28, 2011. e Retrofit factors are not mentioned for Low NOX burners in the OAQPS Manual. Thus, the retrofit factor for a venturi scrubber is applied. Retrofit factor based on average of 1.3 - 1.5, provided in OAQPS Manual, Section 6, Chapter 2, Page 2-49. PILOT MatrixHexcel Line No.Parameter Equationc Total Value Hexcel | West Valley City Plant Page 4 of 7 Trinity Consultants Regenerative Thermal Oxidizer (RTO) Annualized Cost Estimate Table B-7. Vendor Estimated Regenerative Thermal Oxidizer Cost Table B-8. Hexcel Exhaust Flow Rate Flow Rate (scfm)Basic Equipment Costa Hexcel Line No. Averageb Flow Rate (scfm) Averageb Flow Rate (acfm) VOC Emission Rate (lb/hr) 50,000 $1,191,950 2 254 750 0.01 40,000 $1,018,025 3 16,321 23,000 0.91 30,000 $944,100 4 18,866 21,200 0.80 20,000 $709,013 5 23,980 35,350 0.67 10,000 $580,000 6 19,790 28,100 0.91 7 30,557 9,900 1.82 8 53,724 85,800 7.18 10 53,724 85,800 7.18 11 47,678 72,750 8.83 12 47,678 72,750 8.83 PILOT 6,776 8,150 0.05 Matrix 2,589 10,000 0.07 b The average flow rate shown is the sum of flow rates per Hexcel line for point sources with non-negligible VOC emission rates. Point sources with negligible VOC emission rates were considered not technically feasible to control with an RTO. a The installed cost of an RTO is based on a cost estimate from Catalytic Products in December 2023. Hexcel | West Valley City Plant Page 5 of 7 Trinity Consultants Regenerative Thermal Oxidizer (RTO) Annualized Cost Estimate Table B-9. Annualized Regenerative Thermal Oxidizer Cost Per Hexcel Line 2 3 4 5 6 7 8 10 11 12 Direct Costs Purchased equipment costs Basic Equipment, RTO, BE Interpolated from Table 1 $432,634 $678,933 $717,936 $796,341 $732,109 $897,150 $1,252,279 $1,252,279 $1,159,611 $1,159,611 $532,614 $468,437 Ductworkd $300/linear ft x 450 ft, vendor estimate for 25,000 acfm not estimated not estimated not estimated not estimated not estimated not estimated $135,000 $135,000 $135,000 $135,000 $135,000 $135,000 Instrumentation 0.10 BE $43,263 $67,893 $71,794 $79,634 $73,211 $89,715 $125,228 $125,228 $115,961 $115,961 $53,261 $46,844 Sales taxes 0.03 BE $12,979 $20,368 $21,538 $23,890 $21,963 $26,914 $37,568 $37,568 $34,788 $34,788 $15,978 $14,053 Freight 0.05 BE $21,632 $33,947 $35,897 $39,817 $36,605 $44,857 $62,614 $62,614 $57,981 $57,981 $26,631 $23,422 Purchased Equipment Cost, PEC PEC = 1.18 BE $510,508 $801,141 $847,165 $939,683 $863,889 $1,058,637 $1,612,689 $1,612,689 $1,503,341 $1,503,341 $763,484 $687,755 b Direct Installation Costs, DIC 0.3 PEC $153,152.30 $240,342.30 $254,149.42 $281,904.85 $259,166.60 $317,591.05 $483,806.84 $483,806.84 $451,002.25 $451,002.25 $229,045.28 $206,326.65 Total Direct Costs, DC PEC + DIC $663,659.99 $1,041,483.31 $1,101,314.16 $1,221,587.70 $1,123,055.28 $1,376,227.89 $2,096,496.31 $2,096,496.31 $1,954,343.08 $1,954,343.08 $992,529.56 $894,082.13 Indirect Installation Costs Engineering 0.10 PEC $51,051 $80,114 $84,716 $93,968 $86,389 $105,864 $161,269 $161,269 $150,334 $150,334 $76,348 $68,776 Construction & field expenses 0.05 PEC $25,525 $40,057 $42,358 $46,984 $43,194 $52,932 $80,634 $80,634 $75,167 $75,167 $38,174 $34,388 Contractor fees 0.10 PEC $51,051 $80,114 $84,716 $93,968 $86,389 $105,864 $161,269 $161,269 $150,334 $150,334 $76,348 $68,776 Start-up 0.02 PEC $10,210 $16,023 $16,943 $18,794 $17,278 $21,173 $32,254 $32,254 $30,067 $30,067 $15,270 $13,755 Performance test 0.01 PEC $5,105 $8,011 $8,472 $9,397 $8,639 $10,586 $16,127 $16,127 $15,033 $15,033 $7,635 $6,878 Contingencies 0.03 PEC $15,315 $24,034 $25,415 $28,190 $25,917 $31,759 $48,381 $48,381 $45,100 $45,100 $22,905 $20,633 Total Indirect Costs, IC 0.31 PEC $158,257 $248,354 $262,621 $291,302 $267,805 $328,177 $499,934 $499,934 $466,036 $466,036 $236,680 $213,204 TOTAL CAPITAL INVESTMENTe (DC + IC) * 1.25 retrofit factor $1,027,397 $1,612,296 $1,704,919 $1,891,112 $1,738,576 $2,130,507 $3,245,538 $3,245,538 $3,025,473 $3,025,473 $1,536,512 $1,384,108 Direct Annual Costs Operating Labor Operator 2hr/shift* 3 shift/day*360 days/yr * $23.50/hr $50,760 $50,760 $50,760 $50,760 $50,760 $50,760 $50,760 $50,760 $50,760 $50,760 $50,760 $50,760 Supervisor 15% of operator $7,614 $7,614 $7,614 $7,614 $7,614 $7,614 $7,614 $7,614 $7,614 $7,614 $7,614 $7,614 Maintenance Labor 1hr/shift* 3 shift/day*360 days/yr * $29.00/hr $31,320 $31,320 $31,320 $31,320 $31,320 $31,320 $31,320 $31,320 $31,320 $31,320 $31,320 $31,320 Operating Materials Natural Gasf RTO Natural Gas Consumption Calculations $1,598 $279,736 $310,314 $347,386 $261,756 $380,638 $824,781 $824,781 $738,193 $738,193 $121,631 $121,631 Electricity Fan Assume no combustion air needed NA NA NA NA NA NA NA NA NA NA NA NA Total Direct Annual Cost Total $91,292 $369,430 $400,008 $437,080 $351,450 $470,332 $914,475 $914,475 $827,887 $827,887 $211,325 $211,325 Indirect Annual Costs Overhead 60% of sum of operating and maintenance labor $53,816 $53,816 $53,816 $53,816 $53,816 $53,816 $53,816 $53,816 $53,816 $53,816 $53,816 $53,816 Administrative charges 2% of TCI $20,548 $32,246 $34,098 $37,822 $34,772 $42,610 $64,911 $64,911 $60,509 $60,509 $30,730 $27,682 Property tax 1% of TCI $10,274 $16,123 $17,049 $18,911 $17,386 $21,305 $32,455 $32,455 $30,255 $30,255 $15,365 $13,841 Insurance 1% of TCI $10,274 $16,123 $17,049 $18,911 $17,386 $21,305 $32,455 $32,455 $30,255 $30,255 $15,365 $13,841 Capital recovery factor 15 Years, 7% Interest 0.11 0.11 0.11 0.11 0.11 0.11 0.11 0.11 0.11 0.11 0.11 0.11 Capital Recoveryf CRF*TCI $113,014 $177,353 $187,541 $208,022 $191,243 $234,356 $357,009 $357,009 $332,802 $332,802 $169,016 $152,252 Total Indirect Annual Costs Total $207,926 $295,661 $309,554 $337,483 $314,603 $373,393 $540,647 $540,647 $507,638 $507,638 $284,293 $261,433 TOTAL ANNUAL COST $299,218 $665,091 $709,563 $774,563 $666,053 $843,724 $1,455,122 $1,455,122 $1,335,525 $1,335,525 $495,619 $472,758 f Office of Air Quality Planning and Standards (OAQPS), EPA Air Pollution Control Cost Manual, Sixth Edition, Sec 6, Chpt 2, Table 2.9, EPA 452-B-02-001 (http://www.epa.gov/ttn/catc/products.html#cccinfo), Mussatti and Hemmer, July 2002. e Retrofit factors are not mentioned for RTOs in the OAQPS Manual. Thus, the retrofit factor for a venturi scrubber is applied. Retrofit factor based on average of 1.3 - 1.5, provided in OAQPS Manual, Section 6, Chapter 2, Page 2-49. c Unless otherwise noted, equations were taken from U.S. Environmental Protection Agency, EPA Air Pollution Control Cost manual, Sixth Edition. EPA/452/B-02-001, January 2002. d The ductwork cost including supports was e-mailed from Southern Environmental, Inc. to L. Mintzer (Trinity) on 11/7/11 for a 25,000 acfm collector. The ductwork cost estimate of$300/linear foot x 450 feet = $135,000 was conservatively added to the basic equipment cost only for flows greater than 20,000 scfm. PILOT MatrixEquationcParameterHexcel Line No. Hexcel | West Valley City Plant Page 6 of 7 Trinity Consultants RTO Natural Gas Consumption and Emission Reductions Table B-10. Natural Gas Usage Parameters 2 3 4 5 6 7 8 10 11 12 Waste Gas, Qwi, scfm 254 16,321 18,866 23,980 19,790 30,557 53,724 53,724 47,678 47,678 6,776 2,589 VOC (as propane) Emission Concentration a, volume fraction 6.89E-06 8.16E-06 6.21E-06 4.06E-06 6.72E-06 8.67E-06 1.95E-05 1.95E-05 2.70E-05 2.70E-05 9.90E-07 4.21E-06 VOC Concentration in Waste Gas, ppm VOC 6.9 8.2 6.2 4.1 6.7 8.7 19.5 19.5 27.0 27.0 1.0 4.2 This line shows negligible contribution of VOC to heating value CO Emission Concentration, volume fraction CO Emission Concentration, ppm Process Gas Exhaust Temperature, F 1100 239 294 450 550 611 381 381 371 371 175 700 Auxiliary Fuel Requirement, Qaf, scf/yr 157,299 27,533,092 30,542,739 34,191,526 25,763,393 37,464,336 81,179,248 81,179,248 72,656,796 72,656,796 11,971,604 2,889,369 Assumed negligible heat contribution from VOC Fuel Costc, $/yr $1,598 $279,736 $310,314 $347,386 $261,756 $380,638 $824,781 $824,781 $738,193 $738,193 $121,631 $29,356 VOC Process Emissions, tpy 0.05 4.01 3.53 2.93 4.00 7.96 31.47 31.47 38.67 38.67 0.20 0.33 VOC Emissions from Auxiliary Fuel Combustion, tpy 0.00 0.08 0.08 0.09 0.07 0.10 0.22 0.22 0.20 0.20 0.03 0.01 AP-42 Table 1.4-2 VOC Emissions Reduction d, tpy 0.05 3.85 3.37 2.78 3.85 7.70 30.61 30.61 37.70 37.70 0.16 0.31 Calculated as heater emissions minus emissions from auxiliary fuel combustion. b c It is assumed that oxygen in the exhaust is sufficient for combusting VOC, and an additional air blower, and subsequent electricity cost is not required. d Emission reduction = Process Emissions x 98% destruction efficiency - VOC emissions from Auxiliary Fuel Combustion. 98% destruction efficiency is provided on page 2-7 of OAQPS Section 3.2 for an incinerator operating at 1600 deg F. e According to vendor's information, RTO provides 90% CO destruction efficiency or 10 ppmv CO outlet concentration, whichever is less stringent (per McGill AirClean 04/29/05). This calculation is based on 90% control efficiency. Comments a Hexcel Line No.Parameter PILOT Matrix Hexcel | West Valley City Plant Page 7 of 7 Trinity Consultants Hexcel / Ozone RACT Analysis Trinity Consultants C-1 APPENDIX C. RBLC DATA RBLCID Facility/Agency Name State Permit/Document Issued Process Name Control Method Averaging Time Case-by-Case LA-0377 TOKAI ADDIS FACILITY LA 05/27/2020 &nbsp;ACT 1-19 Burner 1 12 MW Low NOx Burners and good combustion practices.0.08 LB/MMBTU NA BACT-PSD AR-0140 BIG RIVER STEEL LLC AR 09/18/2013 &nbsp;ACT BOILERS SN-26 AND 27, GALVANIZING LINE 24.5 MMBTU/H LOW NOX BURNERS COMBUSTION OF CLEAN FUEL GOOD COMBUSTION PRACTICES 0.035 LB/MMBTU NA BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 &nbsp;ACT EUFLTOS1 in FGTOH 10.2 MMBTU/H Good design and combustion practices, low NOx burners.0.05 LB/MMBTU TEST PROTOCOL SHALL SPECIFY BACT-PSD MI-0424 HOLLAND BOARD OF PUBLIC WORKS - EAST 5TH STREET MI 12/05/2016 &nbsp;ACT EUFUELHTR (Fuel pre-heater)3.7 MMBTU/H Good combustion practices.0.55 LB/H TEST PROTOCOL WILL SPECIFY AVG TIME.BACT-PSD MI-0435 BELLE RIVER COMBINED CYCLE POWER PLANT MI 07/16/2018 &nbsp;ACT EUFUELHTR2: Natural gas fired fuel heater 3.8 MMBTU/H Low NOx burner 0.14 LB/H HOURLY BACT-PSD MI-0420 DTE GAS COMPANY--MILFORD COMPRESSOR STATION MI 06/03/2016 &nbsp;ACT FGAUXBOILERS 6 MMBTU/H Ultra low NOx burners and good combustion practices.14 PPMVOL AT 15%O2; TEST PROTOCOL BACT-PSD MI-0426 DTE GAS COMPANY - MILFORD COMPRESSOR STATION MI 03/24/2017 &nbsp;ACT FGAUXBOILERS (6 auxiliary boilers EUAUXBOIL2A, EUAUXBOIL3A, EUAUXBOIL2B, EUAUXBOIL3B, EUAUXBOIL2C, EUAUXBOIL3C)3 MMBTU/H Ultra-low NOx burners and good combustion practices.20 PPM AT 3% O EACH 3 MMBTU/H BOILER BACT-PSD MI-0440 MICHIGAN STATE UNIVERSITY MI 05/22/2019 &nbsp;ACT FGFUELHEATERS 25 MMBTU/H Low NOx burners and good combustion practices.0.05 LB/MMBTU HOURLY; EACH HEATER BACT-PSD MI-0442 THOMAS TOWNSHIP ENERGY, LLC MI 08/21/2019 &nbsp;ACT FGPREHEAT 7 MMBTU/H Good combustion practices and low NOx burners 0.036 LB/MMBTU HOURLY; EACH UNIT BACT-PSD MI-0412 HOLLAND BOARD OF PUBLIC WORKS - EAST 5TH STREET MI 12/04/2013 &nbsp;ACT Fuel pre-heater (EUFUELHTR)3.7 MMBTU/H Good combustion practices.0.55 LB/H TEST PROTOCOL BACT-PSD AR-0140 BIG RIVER STEEL LLC AR 09/18/2013 &nbsp;ACT FURNACES SN-40 AND SN-42, DECARBURIZING LINE 22 MMBTU/H LOW NOX BURNERS SCR COMBUSTION OF CLEAN FUEL GOOD COMBUSTION PRACTICES 0.1 LB/MMBTU NA BACT-PSD KY-0115 NUCOR STEEL GALLATIN, LLC KY 04/19/2021 &nbsp;ACT Galvanizing Line #2 Alkali Cleaning Section Heater (EP 21-07B)23 MMBtu/hr The permittee must develop a Good Combustion and Operating Practices (GCOP) Plan. This unit is also required to be equipped with low-NOx burners (0.07 lb/MMBtu). 50 LB/MMSCF NA BACT-PSD KY-0115 NUCOR STEEL GALLATIN, LLC KY 04/19/2021 &nbsp;ACT Galvanizing Line #2 Annealing Furnaces (15) (EP 21-15)4.8 MMBtu/hr, each The permittee must develop a Good Combustion and Operating Practices (GCOP) Plan. This unit is equipped with low-NOx burners. 50 LB/MMSCF NA BACT-PSD KY-0115 NUCOR STEEL GALLATIN, LLC KY 04/19/2021 &nbsp;ACT Galvanizing Line #2 Zinc Pot Preheater (EP 21-09)3 MMBtu/hr The permittee must develop a Good Combustion and Operating Practices (GCOP) Plan. This unit is equipped with a low-NOx burner. 70 LB/MMSCF NA BACT-PSD TX-0680 SONORA GAS PLANT TX 06/14/2013 &nbsp;ACT Heater 10 MMBTU/H low-NOx burners 0.01 LB/MMBTU NA BACT-PSD TX-0656 GAS TO GASOLINE PLANT TX 05/16/2014 &nbsp;ACT heaters (5)24.3 MMBTU/H ultra low NOx burners 0.036 LB/MMBTU NA BACT-PSD OK-0153 ROSE VALLEY PLANT OK 03/01/2013 &nbsp;ACT HOT OIL HEATER 17.4 MMBTUH LOW-NOx BURNERS.0.045 LB/MMBTU 3-HR BACT-PSD WI-0291 GRAYMONT WESTERN LIME-EDEN WI 01/28/2019 &nbsp;ACT P05 Natural Gas Fired Line Heater 1.5 mmBTU/hr Good Combustion Practices 0.1 LB/MMBTU NA BACT-PSD KY-0115 NUCOR STEEL GALLATIN, LLC KY 04/19/2021 &nbsp;ACT Pickle Line #2 – Boiler #1 &amp; #2 (EP 21- 04 &amp; EP 21-05)18 MMBtu/hr, each The permittee must develop a Good Combustion and Operating Practices (GCOP) Plan. Equipped with low-NOx burners. 50 LB/MMSCF EACH BACT-PSD OK-0156 NORTHSTAR AGRI IND ENID OK 07/31/2013 &nbsp;ACT Refinery Boiler 5 MMBTUH Good Combustion 0.0075 LB/MMBTU 3-HOUR AVG N/A OK-0153 ROSE VALLEY PLANT OK 03/01/2013 &nbsp;ACT REGENERATION HEATERS 5.61 MMBTUH LOW-NOx BURNERS 0.045 LB/MMBTU 3-HR BACT-PSD AR-0171 NUCOR STEEL ARKANSAS AR 02/14/2019 &nbsp;ACT SN-233 Galvanizing Line Boilers 15 MMBTU/hr each Low Nox Burners 0.1 LB/MMBTU 3-HR BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 &nbsp;ACT Thermal oil system for thermally fused lamination lines (EUFLTOS1 in FGTOH)10.2 MMBTU/H Good design and combustion practices, low NOx burners 0.05 LB/MMBTU HOURLY BACT-PSD FL-0356 OKEECHOBEE CLEAN ENERGY CENTER FL 03/09/2016 &nbsp;ACT Two natural gas heaters 10 MMBtu/hr Must have NOx emission design value less than 0.1 lb/MMBtu 0.1 LB/MMBTU NA BACT-PSD FL-0363 DANIA BEACH ENERGY CENTER FL 12/04/2017 &nbsp;ACT Two natural gas heaters 9.9 MMBtu/hr Manufacturer certification 0.1 LB/MMBTU DESIGN VALUE BACT-PSD Throughput Emission Limit RBLCID Facility/Agency Name State Permit/Document Issued Process Name Control Method Averaging Time Case-by-Case WI-0291 GRAYMONT WESTERN LIME-EDEN WI 01/28/2019 &nbsp;ACT P05 Natural Gas Fired Line Heater 1.5 mmBTU/hr Good Combustion Practices 0.1 LB/MMBTU NA BACT-PSD KY-0115 NUCOR STEEL GALLATIN, LLC KY 04/19/2021 &nbsp;ACT Galvanizing Line #2 Zinc Pot Preheater (EP 21-09)3 MMBtu/hr The permittee must develop a Good Combustion and Operating Practices (GCOP) Plan. This unit is equipped with a low-NOx burner. 70 LB/MMSCF NA BACT-PSD OK-0156 NORTHSTAR AGRI IND ENID OK 07/31/2013 &nbsp;ACT Refinery Boiler 5 MMBTUH Good Combustion 0.0075 LB/MMBTU 3-HOUR AVG N/A MI-0442 THOMAS TOWNSHIP ENERGY, LLC MI 08/21/2019 &nbsp;ACT FGPREHEAT 7 MMBTU/H Good combustion practices and low NOx burners 0.036 LB/MMBTU HOURLY; EACH UNIT BACT-PSD FL-0363 DANIA BEACH ENERGY CENTER FL 12/04/2017 &nbsp;ACT Two natural gas heaters 9.9 MMBtu/hr Manufacturer certification 0.1 LB/MMBTU DESIGN VALUE BACT-PSD TX-0680 SONORA GAS PLANT TX 06/14/2013 &nbsp;ACT Heater 10 MMBTU/H low-NOx burners 0.01 LB/MMBTU NA BACT-PSD LA-0377 TOKAI ADDIS FACILITY LA 05/27/2020 &nbsp;ACT 1-19 Burner 1 12 MW Low NOx Burners and good combustion practices.0.08 LB/MMBTU NA BACT-PSD WI-0306 WPL- RIVERSIDE ENERGY CENTER WI 02/28/2020 &nbsp;ACT Temporary Boiler (B98A)14.67 MMBTU/H Low NOx burners, flue gas recirculation, shall be operated for no more than 500 hours, and shall combust only pipeline quality natural gas. 0.04 LB/MMBTU AVG. OVER ANY CONSECUTIVE 3-HR PERIOD BACT-PSD AR-0171 NUCOR STEEL ARKANSAS AR 02/14/2019 &nbsp;ACT SN-233 Galvanizing Line Boilers 15 MMBTU/hr each Low Nox Burners 0.1 LB/MMBTU 3-HR BACT-PSD KY-0110 NUCOR STEEL BRANDENBURG KY 07/23/2020 &nbsp;ACT EP 03-05 - Steckel Mill Coiling Furnaces #1 &amp; #2 17.5 MMBtu/hr, each Low-Nox Burner (Designed to maintain 0.08 lb/MMBtu); and a Good Combustion and Operating Practices (GCOP) Plan.81.6 LB/MMSCF NA BACT-PSD MI-0435 BELLE RIVER COMBINED CYCLE POWER PLANT MI 07/16/2018 &nbsp;ACT EUFUELHTR1: Natural gas fired fuel heater 20.8 MMBTU/H Low NOx burner 0.75 LB/H HOURLY BACT-PSD KY-0115 NUCOR STEEL GALLATIN, LLC KY 04/19/2021 &nbsp;ACT Galvanizing Line #2 Alkali Cleaning Section Heater (EP 21-07B)23 MMBtu/hr The permittee must develop a Good Combustion and Operating Practices (GCOP) Plan. This unit is also required to be equipped with low-NOx burners (0.07 lb/MMBtu). 50 LB/MMSCF NA BACT-PSD TX-0656 GAS TO GASOLINE PLANT TX 05/16/2014 &nbsp;ACT heaters (5)24.3 MMBTU/H ultra low NOx burners 0.036 LB/MMBTU NA BACT-PSD MI-0440 MICHIGAN STATE UNIVERSITY MI 05/22/2019 &nbsp;ACT FGFUELHEATERS 25 MMBTU/H Low NOx burners and good combustion practices.0.05 LB/MMBTU HOURLY; EACH HEATER BACT-PSD -SJVAPCD CA 11/30/2022 Boiler ≥20 MMBtu/hr Assumed SCR 0.003 LB/MMBTU NA BACT -BAAQMD CA 8/4/2010 Boiler < 33.5 MMBtu/Hr Ultra Low NOx Burners & FGR NA BACT -SCAQMD CA 9/2/2022 Boiler 8.4 MMBtu/hr Low NOx Burner 7 PPMV 15 min BACT Throughput Emission Limit NA RBLCID Facility/Agency Name State Permit/Document Issued Process Name Control Method Averaging Time Case-by-Case SC-0179 CAROLINA PARTICLEBOARD SC 03/18/2015 &nbsp;ACT THERMAL OIL HEATER #2 1.83 MMBTU/H NATURAL GAS USAGE AND GOOD COMBUSTION PRACTICES.0.01 LB/H NA BACT-PSD KY-0115 NUCOR STEEL GALLATIN, LLC KY 04/19/2021 &nbsp;ACT Galvanizing Line #2 Zinc Pot Preheater (EP 21-09)3 MMBtu/hr The permittee must develop a Good Combustion and Operating Practices (GCOP) Plan 5.5 LB/MMSCF NA BACT-PSD OK-0156 NORTHSTAR AGRI IND ENID OK 07/31/2013 &nbsp;ACT Refinery Boiler 5 MMBTUH Good Combustion 0.0054 LB/MMBTU 3-HOUR AVG N/A MI-0442 THOMAS TOWNSHIP ENERGY, LLC MI 08/21/2019 &nbsp;ACT FGPREHEAT 7 MMBTU/H Good combustion practices 0.025 LB/MMBTU HOURLY; EACH UNIT BACT-PSD *LA-0315 G2G PLANT LA 05/23/2014 &nbsp;ACT Reactor Charge Heater - 53B001 10.1 MMBTU/HR Combustion controls (proper burner design and operation using natural gas)0.05 LB/H HOURLY MAXIMUM BACT-PSD TX-0772 PORT OF BEAUMONT PETROLEUM TRANSLOAD TERMINAL (PBPTT)TX 11/06/2015 &nbsp;ACT Commercial/Institutional-Size Boilers/Furnaces 13.2 MMBTU/H Good combustion practice to ensure complete combustion.0.3 T/YR NA BACT-PSD SC-0193 MERCEDES BENZ VANS, LLC SC 04/15/2016 &nbsp;ACT Energy Center Boilers 14.27 MMBTU/hr Annual tune ups per 40 CFR 63.7540(a)(10) are required.5.5 LB/MMSCF 3 HOUR BLOCK AVERAGE BACT-PSD AR-0171 NUCOR STEEL ARKANSAS AR 02/14/2019 &nbsp;ACT SN-233 Galvanizing Line Boilers 15 MMBTU/hr each Good combustion practices 0.0055 LB/MMBTU NA BACT-PSD LA-0349 DRIFTWOOD LNG FACILITY LA 07/10/2018 &nbsp;ACT Hot Oil Heaters (5)16.13 mm btu/hr Good Combustion Practices and Use of low sulfur facility fuel gas 0.0054 LB/MM BTU NA BACT-PSD KY-0115 NUCOR STEEL GALLATIN, LLC KY 04/19/2021 &nbsp;ACT Pickle Line #2 – Boiler #1 &amp; #2 (EP 21- 04 &amp; EP 21-05)18 MMBtu/hr, each The permittee must develop a Good Combustion and Operating Practices (GCOP) Plan 5.5 LB/MMSCF EACH BACT-PSD WI-0292 GREEN BAY PACKAGING INC. –MILL DIVISION WI 04/01/2019 &nbsp;ACT P44 Space Heaters 20 mmBTU/hr Good Combustion Practices, the Use of Low-NOx Burners 0.0055 LB/MMBTU NA BACT-PSD AR-0140 BIG RIVER STEEL LLC AR 09/18/2013 &nbsp;ACT FURNACES SN-40 AND SN-42, DECARBURIZING LINE 22 MMBTU/H COMBUSTION OF NATURAL GAS AND GOOD COMBUSTION PRACTICE 0.0054 LB/MMBTU NA BACT-PSD MI-0440 MICHIGAN STATE UNIVERSITY MI 05/22/2019 &nbsp;ACT FGFUELHEATERS 25 MMBTU/H Good combustion practices 0.005 LB/MMBTU HOURLY; EACH UNIT BACT-PSD -SJVAPCD CA 11/30/2022 Boiler ≥20 MMBtu/hr PUC quality natural gas or propane with LPG backup NA NA BACT Throughput Emission Limit RBLCID Facility/Agency Name State Permit/Document Issued Process Name Control Method Averaging Time Case-by-Case AL-0307 ALLOYS PLANT AL 10/09/2015 &nbsp;ACT 2 CALP LINE BOILERS 24.59 MMBTU/H GCP 0.006 LB/MMBTU NA BACT-PSD *OH-0387 INTEL OHIO SITE OH 09/20/2022 &nbsp;ACT 29.4 MMBtu/hr Natural Gas-Fired Boilers: B001 through B028 29.4 MMBTU/H Good combustion practices and the use of natural gas 4.86 T/YR PER ROLLING 12 MONTH PERIOD B001 TO B0 BACT-PSD WY-0075 CHEYENNE PRAIRIE GENERATING STATION WY 07/16/2014 &nbsp;ACT Auxiliary Boiler 25.06 MMBtu/h good combustion practices 0.0017 LB/MMBTU 3 HOUR AVERAGE BACT-PSD OH-0375 LONG RIDGE ENERGY GENERATION LLC - HANNIBAL POWER OH 11/07/2017 &nbsp;ACT Auxiliary Boiler (B001)26.8 MMBTU/H Good combustion controls 0.13 LB/H NA BACT-PSD WI-0283 AFE, INC. –LCM PLANT WI 04/24/2018 &nbsp;ACT B01-B12, Boilers 28 mmBTU/hr Ultra-low NOx Burners, Flue Gas Recirculation and Good Combustion Practices 0.0036 LB/MMBTU NA BACT-PSD WI-0284 SIO INTERNATIONAL WISCONSIN, INC. -ENERGY PLANT WI 04/24/2018 &nbsp;ACT B13-B24 &amp; B25-B36 Natural Gas-Fired Boilers 28 mmBTU Ultra-Low NOx Burners, Flue Gas Recirculation, and Good Combustion Practices.0.0036 LB/MMBTU NA BACT-PSD AR-0140 BIG RIVER STEEL LLC AR 09/18/2013 &nbsp;ACT BOILERS SN-26 AND 27, GALVANIZING LINE 24.5 MMBTU/H COMBUSTION OF NATURAL GAS AND GOOD COMBUSTION PRACTICE 0.0054 LB/MMBTU NA BACT-PSD TX-0772 PORT OF BEAUMONT PETROLEUM TRANSLOAD TERMINAL (PBPTT)TX 11/06/2015 &nbsp;ACT Commercial/Institutional-Size Boilers/Furnaces 13.2 MMBTU/H Good combustion practice to ensure complete combustion.0.3 T/YR NA BACT-PSD SC-0193 MERCEDES BENZ VANS, LLC SC 04/15/2016 &nbsp;ACT Energy Center Boilers 14.27 MMBTU/hr Annual tune ups per 40 CFR 63.7540(a)(10) are required.5.5 LB/MMSCF 3 HOUR BLOCK AVERAGE BACT-PSD KY-0110 NUCOR STEEL BRANDENBURG KY 07/23/2020 &nbsp;ACT EP 03-05 - Steckel Mill Coiling Furnaces #1 &amp; #2 17.5 MMBtu/hr, each This EP is required to have a Good Combustion and Operating Practices (GCOP) Plan.5.5 LB/MMSCF NA BACT-PSD KY-0110 NUCOR STEEL BRANDENBURG KY 07/23/2020 &nbsp;ACT EP 05-01 - Group 1 Car Bottom Furnaces #1 - #3 28 MMBtu/hr, each This EP is required to have a Good Combustion and Operating Practices (GCOP) Plan.5.5 LB/MMSCF NA BACT-PSD MI-0425 GRAYLING PARTICLEBOARD MI 05/09/2017 &nbsp;ACT EUFLTOS1 in FGTOH 10.2 MMBTU/H Good design and operating/combustion practices.0.0054 LB/MMBTU TEST PROTOCOL SHALL SPECIFY BACT-PSD MI-0424 HOLLAND BOARD OF PUBLIC WORKS - EAST 5TH STREET MI 12/05/2016 &nbsp;ACT EUFUELHTR (Fuel pre-heater)3.7 MMBTU/H Good combustion practices.0.03 LB/H TEST PROTOCOL WILL SPECIFY AVG TIME BACT-PSD MI-0435 BELLE RIVER COMBINED CYCLE POWER PLANT MI 07/16/2018 &nbsp;ACT EUFUELHTR1: Natural gas fired fuel heater 20.8 MMBTU/H Good combustion controls 0.17 LB/H HOURLY BACT-PSD MI-0435 BELLE RIVER COMBINED CYCLE POWER PLANT MI 07/16/2018 &nbsp;ACT EUFUELHTR2: Natural gas fired fuel heater 3.8 MMBTU/H Good combustion controls.0.03 LB/H HOURLY BACT-PSD MI-0440 MICHIGAN STATE UNIVERSITY MI 05/22/2019 &nbsp;ACT FGFUELHEATERS 25 MMBTU/H Good combustion practices 0.005 LB/MMBTU HOURLY; EACH UNIT BACT-PSD *MI-0445 INDECK NILES, LLC MI 11/26/2019 &nbsp;ACT FGFUELHTR (2 fuel pre-heaters)27 MMBTU/H Good combustion practices 0.07 LB/H HOURLY; EACH FUEL HEATER BACT-PSD MI-0423 INDECK NILES, LLC MI 01/04/2017 &nbsp;ACT FGFUELHTR (Two fuel pre-heaters identified as EUFUELHTR1 &amp; EUFUELHTR2)27 MMBTU/H Good combustion practices.0.15 LB/H HOURLY; EACH FUEL HEATER BACT-PSD MI-0442 THOMAS TOWNSHIP ENERGY, LLC MI 08/21/2019 &nbsp;ACT FGPREHEAT 7 MMBTU/H Good combustion practices 0.025 LB/MMBTU HOURLY; EACH UNIT BACT-PSD OH-0374 GUERNSEY POWER STATION LLC OH 10/23/2017 &nbsp;ACT Fuel Gas Heaters (2 identical, P007 and P008)15 MMBTU/H Combustion control 0.075 LB/H NA BACT-PSD MI-0412 HOLLAND BOARD OF PUBLIC WORKS - EAST 5TH STREET MI 12/04/2013 &nbsp;ACT Fuel pre-heater (EUFUELHTR)3.7 MMBTU/H Good combustion practices 0.03 LB/H TEST PROTOCOL BACT-PSD AR-0140 BIG RIVER STEEL LLC AR 09/18/2013 &nbsp;ACT FURNACES SN-40 AND SN-42, DECARBURIZING LINE 22 MMBTU/H COMBUSTION OF NATURAL GAS AND GOOD COMBUSTION PRACTICE 0.0054 LB/MMBTU NA BACT-PSD KY-0115 NUCOR STEEL GALLATIN, LLC KY 04/19/2021 &nbsp;ACT Galvanizing Line #2 Alkali Cleaning Section Heater (EP 21-07B)23 MMBtu/hr The permittee must develop a Good Combustion and Operating Practices (GCOP) Plan 5.5 LB/MMSCF NA BACT-PSD KY-0115 NUCOR STEEL GALLATIN, LLC KY 04/19/2021 &nbsp;ACT Galvanizing Line #2 Annealing Furnaces (15) (EP 21-15)4.8 MMBtu/hr, each The permittee must develop a Good Combustion and Operating Practices (GCOP) Plan 5.5 LB/MMSCF NA BACT-PSD KY-0115 NUCOR STEEL GALLATIN, LLC KY 04/19/2021 &nbsp;ACT Galvanizing Line #2 Zinc Pot Preheater (EP 21-09)3 MMBtu/hr The permittee must develop a Good Combustion and Operating Practices (GCOP) Plan 5.5 LB/MMSCF NA BACT-PSD TX-0656 GAS TO GASOLINE PLANT TX 05/16/2014 &nbsp;ACT heaters (5)24.3 MMBTU/H clean fuel and good combustion practices 2.44 T/YR NA BACT-PSD LA-0349 DRIFTWOOD LNG FACILITY LA 07/10/2018 &nbsp;ACT Hot Oil Heaters (5)16.13 mm btu/hr Good Combustion Practices and Use of low sulfur facility fuel gas 0.0054 LB/MM BTU NA BACT-PSD WI-0292 GREEN BAY PACKAGING INC. –MILL DIVISION WI 04/01/2019 &nbsp;ACT P44 Space Heaters 20 mmBTU/hr Good Combustion Practices, the Use of Low-NOx Burners 0.0055 LB/MMBTU NA BACT-PSD AL-0307 ALLOYS PLANT AL 10/09/2015 &nbsp;ACT PACKAGE BOILER 17.5 MMBTU/H GCP 0.006 LB/MMBTU NA BACT-PSD KY-0115 NUCOR STEEL GALLATIN, LLC KY 04/19/2021 &nbsp;ACT Pickle Line #2 – Boiler #1 &amp; #2 (EP 21- 04 &amp; EP 21-05)18 MMBtu/hr, each The permittee must develop a Good Combustion and Operating Practices (GCOP) Plan 5.5 LB/MMSCF EACH BACT-PSD *LA-0315 G2G PLANT LA 05/23/2014 &nbsp;ACT Reactor Charge Heater - 53B001 10.1 MMBTU/HR Combustion controls (proper burner design and operation using natural gas)0.05 LB/H HOURLY MAXIMUM BACT-PSD AR-0171 NUCOR STEEL ARKANSAS AR 02/14/2019 &nbsp;ACT SN-233 Galvanizing Line Boilers 15 MMBTU/hr each Good combustion practices 0.0055 LB/MMBTU NA BACT-PSD SC-0179 CAROLINA PARTICLEBOARD SC 03/18/2015 &nbsp;ACT THERMAL OIL HEATER #2 1.83 MMBTU/H NATURAL GAS USAGE AND GOOD COMBUSTION PRACTICES.0.01 LB/H NA BACT-PSD MI-0448 GRAYLING PARTICLEBOARD MI 12/18/2020 &nbsp;ACT Thermal oil system for thermally fused lamination lines (EUFLTOS1 in FGTOH)10.2 MMBTU/H Good Design and Operating/Combustion Practices 0.0054 LB/MMBTU HOURLY BACT-PSD Throughput Emission Limit RBLCID Facility/Agency Name State Permit/Document Issued Process Name Control Method Averaging Time Case-by-Case KY-0110 NUCOR STEEL BRANDENBURG KY 07/23/2020 &nbsp;ACT EP 10-07 - Air Separation Plant Emergency Generator 700 HP This EP is required to have a Good Combustion and Operating Practices (GCOP) Plan.4.77 G/HP-HR NMHC + NOX BACT-PSD KY-0110 NUCOR STEEL BRANDENBURG KY 07/23/2020 &nbsp;ACT EP 10-04 - Emergency Fire Water Pump 920 HP This EP is required to have a Good Combustion and Operating Practices (GCOP) Plan.4.77 G/HP-HR NMHC + NOX BACT-PSD MI-0406 RENAISSANCE POWER LLC MI 11/01/2013 &nbsp;ACT FG-EMGEN7-8; Two (2) 1,000kW diesel- fueled emergency reciprocating internal combustion engines 1000 kW Good combustion practices 4.8 G/B-HP-H TEST PROTOCOL; EACH UNIT BACT-PSD MI-0433 MEC NORTH, LLC AND MEC SOUTH LLC MI 06/29/2018 &nbsp;ACT EUEMENGINE (North Plant): Emergency Engine 1341 HP Good combustion practices and meeting NSPS Subpart IIII requirements.6.4 G/KW-H HOURLY BACT-PSD WI-0300 NEMADJI TRAIL ENERGY CENTER WI 09/01/2020 &nbsp;ACT Emergency Diesel Generator (P07)1490 HP Operation limited to 500 hours/year and operate and maintain according to the manufacturer’s recommendations.4.8 G/HP-H NA BACT-PSD MI-0441 LBWL--ERICKSON STATION MI 12/21/2018 &nbsp;ACT EUEMGD1--A 1500 HP diesel fueled emergency engine 1500 HP Good combustion practices and will be NSPS compliant.6.4 G/KW-H HOURLY BACT-PSD OH-0377 HARRISON POWER OH 04/19/2018 &nbsp;ACT Emergency Diesel Generator (P003)1860 HP Good combustion practices (ULSD) and compliance with 40 CFR Part 60, Subpart IIII 19.68 LB/H NMHC+NOX. SEE NOTES.BACT-PSD OH-0375 LONG RIDGE ENERGY GENERATION LLC - HANNIBAL POWER OH 11/07/2017 &nbsp;ACT Emergency Diesel Generator Engine (P001)2206 HP Good combustion design 24.71 LB/H NMHC+NOX. SEE NOTES.BACT-PSD MD-0042 WILDCAT POINT GENERATION FACILITY MD 04/08/2014 &nbsp;ACT EMERGENCY GENERATOR 1 2250 KW LIMITED OPERATING HOURS, USE OF ULTRA- LOW SULFUR FUEL AND GOOD COMBUSTION PRACTICES 4.8 G/HP-H NA LAER OH-0366 CLEAN ENERGY FUTURE - LORDSTOWN, LLC OH 08/25/2015 &nbsp;ACT Emergency generator (P003)2346 HP State-of-the-art combustion design 21.6 LB/H NA BACT-PSD -SCAQMD CA 12/10/2015 Emergency generator 2220 BHP Diesel particulate filter installed 4.8 g/bhp-hr NA BACT -SCAQMD CA 12/10/2015 Emergency generator 755 BHP Diesel particulate filter installed 4.8 g/bhp-hr NA BACT -SJVAPCD CA 4/29/2022 Emergency generator >750 bhp EPA Tier 4 Final certification level or equivalent for applicable horsepower range 0.5 g/bhp-hr NA BACT Throughput Emission Limit RBLCID Facility/Agency Name State Permit/Document Issued Process Name Control Method Averaging Time Case-by-Case OK-0156 NORTHSTAR AGRI IND ENID OK 07/31/2013 &nbsp;ACT Fire Pump Engine 550 hp Good Combustion 0.35 LB/MMBTU 3-HOUR AVG BACT-PSD OH-0375 LONG RIDGE ENERGY GENERATION LLC - HANNIBAL POWER OH 11/07/2017 &nbsp;ACT Emergency Diesel Fire Pump Engine (P002)700 HP Good combustion design 4.97 LB/H NMHC+NOX. SEE NOTES.BACT-PSD OH-0360 CARROLL COUNTY ENERGY OH 11/05/2013 &nbsp;ACT Emergency generator (P003)1112 KW Purchased certified to the standards in NSPS Subpart IIII 1.93 LB/H NA BACT-PSD *MI-0452 MEC SOUTH, LLC MI 06/23/2022 &nbsp;ACT EUEMENGINE (South Plant): Emergency engine 1341 HP Good combustion practices.0.86 LB/H HOURLY BACT-PSD SC-0193 MERCEDES BENZ VANS, LLC SC 04/15/2016 &nbsp;ACT Emergency Generators and Fire Pump 1500 hp Must meet the standards of 40 CFR 60, Subpart IIII 100 HR/YR 12 MONTH ROLLING SUM BACT-PSD OH-0370 TRUMBULL ENERGY CENTER OH 09/07/2017 &nbsp;ACT Emergency generator (P003)1529 HP State-of-the-art combustion design 2 LB/H NA BACT-PSD OH-0377 HARRISON POWER OH 04/19/2018 &nbsp;ACT Emergency Diesel Generator (P003)1860 HP Good combustion practices (ULSD) and compliance with 40 CFR Part 60, Subpart IIII 19.68 LB/H NMHC+NOX. SEE NOTES.BACT-PSD OH-0375 LONG RIDGE ENERGY GENERATION LLC - HANNIBAL POWER OH 11/07/2017 &nbsp;ACT Emergency Diesel Generator Engine (P001)2206 HP Good combustion design 24.71 LB/H NMHC+NOX. SEE NOTES.BACT-PSD -SCAQMD CA 12/10/2015 Emergency Generator 2220 BHP Diesel particulate filter installed NA NA BACT -SCAQMD CA 12/10/2015 Emergency Generator 755 BHP Diesel particulate filter installed NA NA BACT -SJVAPCD CA 4/29/2022 Emergency Generator >750 bhp EPA Tier 4 Final certification level or equivalent for applicable horsepower range 0.14 g/bhp-hr NA BACT Throughput Emission Limit RBLCID Facility/Agency Name State Permit/Document Issued Process Name Control Method Averaging Time Case-by-Case KY-0110 NUCOR STEEL BRANDENBURG KY 07/23/2020 &nbsp;ACT EP 11-05 - Radio Tower Emergency Generator 61 HP This EP is required to have a Good Combustion and Operating Practices (GCOP) Plan.3.5 G/HP-HR NMHC + NOX BACT-PSD NJ-0084 PSEG FOSSIL LLC SEWAREN GENERATING STATION NJ 03/10/2016 &nbsp;ACT Emergency Diesel Fire Pump 100 H/YR use of ULSD a clean burning fuel, and limited hours of operation 1.7 LB/H NA LAER OH-0379 PETMIN USA INCORPORATED OH 02/06/2019 &nbsp;ACT Black Start Generator (P007)158 HP Tier IV engine Tier IV NSPS standards certified by engine manufacturer.0.104 LB/H NA BACT-PSD LA-0379 SHINTECH PLAQUEMINES PLANT 1 LA 05/04/2021 &nbsp;ACT VCM Unit Emergency Cooling Water Pumps 180 hp Good combustion practices/gaseous fuel burning.2.98 G/KW-HR NA BACT-PSD MI-0434 FLAT ROCK ASSEMBLY PLANT MI 03/22/2018 &nbsp;ACT EUFIREPUMPENGS (2 emergency fire pump engines)250 BHP Good combustion practices.3 G/B-HP-H HOURLY; EACH ENGINE (NMHC+NOX)BACT-PSD LA-0328 PLAQUEMINES PLANT 1 LA 05/02/2018 &nbsp;ACT Emergency Diesel Engine Pump P-39B 300 HP Good combustion practices and NSPS Subpart IIII 4 G/KW-H NA BACT-PSD MD-0045 MATTAWOMAN ENERGY CENTER MD 11/13/2015 &nbsp;ACT EMERGENCY DIESEL ENGINE FOR FIRE WATER PUMP 305 HP EXCLUSIVE USE OF ULTRA LOW SULFUR FUEL AND GOOD COMBUSTION PRACTICES 4 G/KW-H NA LAER MD-0043 PERRYMAN GENERATING STATION MD 07/01/2014 &nbsp;ACT EMERGENCY DIESEL ENGINE FOR FIRE WATER PUMP 350 HP GOOD COMBUSTION PRACTICES, LIMITED HOURS OF OPERATION, AND EXCLUSIVE USE OF ULSD 3 G/HP-H NA LAER OH-0378 PTTGCA PETROCHEMICAL COMPLEX OH 12/21/2018 &nbsp;ACT Firewater Pumps (P005 and P006)402 HP Certified to the meet the emissions standards in Table 4 of 40 CFR Part 60, Subpart IIII and employ good combustion practices per the manufacturer’s operating manual 2.64 LB/H NA BACT-PSD -SCAQMD CA 12/10/2015 Emergency Generator 374 BHP Diesel particulate filter installed 3 g/bhp-hr NA BACT -SJVAPCD CA 4/29/2022 Emergency Generator <750 bhp EPA Tier 4 Final certification level or equivalent for applicable horsepower range 0.3 g/bhp-hr NA BACT Throughput Emission Limit RBLCID Facility/Agency Name State Permit/Document Issued Process Name Control Method Averaging Time Case-by-Case NJ-0084 PSEG FOSSIL LLC SEWAREN GENERATING STATION NJ 03/10/2016 &nbsp;ACT Emergency Diesel Fire Pump 100 H/YR use of ULSD a clean burning fuel, and limited hours of operation 0.1 LB/H NA LAER OH-0366 CLEAN ENERGY FUTURE - LORDSTOWN, LLC OH 08/25/2015 &nbsp;ACT Emergency fire pump engine (P004)140 HP State-of-the-art combustion design 0.11 LB/H NA BACT-PSD *WI-0261 ENBRIDGE ENERGY - SUPERIOR TERMINAL WI 06/12/2014 &nbsp;ACT EG7 - Diesel Emergency Electric Generator w/ tank 197 BHP NSPS engine [Tier 3 emergency engine]. EG7 Storage tank, conventional fuel oil storage tank, good operating practices; limiting leakage, spills. (FT01). Engine limited to 200 hours / year (total) and NSPS requirements. 3.75 GRAM / HP-H NOX + NMHC HOURLY AVG., FOR EG7 BACT-PSD TX-0846 MOTOR VEHICLE ASSEMBLY PLANT TX 09/23/2018 &nbsp;ACT FIRE PUMP DIESEL ENGINE 214 kW Meets EPA Tier 4 requirements 0.19 G/KW HR BACT-PSD *OH-0387 INTEL OHIO SITE OH 09/20/2022 &nbsp;ACT 275 hp (205 kW) Diesel-Fired Emergency Fire Pump Engine 275 HP Certified to meet the standards in Table 4 of 40 CFR Part 60, Subpart IIII and good combustion practices 0.7 LB/H NA BACT-PSD LA-0328 PLAQUEMINES PLANT 1 LA 05/02/2018 &nbsp;ACT Emergency Diesel Engine Pump P-39B 300 HP Good combustion practices and NSPS Subpart IIII 4 G/KW-H NA BACT-PSD OH-0377 HARRISON POWER OH 04/19/2018 &nbsp;ACT Emergency Fire Pump (P004)320 HP Good combustion practices (ULSD) and compliance with 40 CFR Part 60, Subpart IIII 2.12 LB/H NMHC+NOX. SEE NOTES.BACT-PSD MD-0044 COVE POINT LNG TERMINAL MD 06/09/2014 &nbsp;ACT 5 EMERGENCY FIRE WATER PUMP ENGINES 350 HP USE ONLY ULSD, GOOD COMBUSTION PRACTICES, AND DESIGNED TO ACHIEVE EMISSION LIMIT 3 G/HP-H NOX + NMHC LAER LA-0328 PLAQUEMINES PLANT 1 LA 05/02/2018 &nbsp;ACT Emergency Diesel Engine Pump P-39A 375 HP Good combustion practices and NSPS Subpart IIII 4 G/KW-H NA BACT-PSD OH-0378 PTTGCA PETROCHEMICAL COMPLEX OH 12/21/2018 &nbsp;ACT Firewater Pumps (P005 and P006)402 HP Certified to the meet the emissions standards in Table 4 of 40 CFR Part 60, Subpart IIII and employ good combustion practices per the manufacturer’s operating manual 2.64 LB/H NA BACT-PSD -SJVAPCD CA 4/29/2022 Emergency Generator <750 bhp EPA Tier 4 Final certification level or equivalent for applicable horsepower range 0.14 g/bhp-hr NA BACT Throughput Emission Limit RBLCID Facility/Agency Name State Permit/Document Issued Process Name Control Method Averaging Time Case-by-Case AL-0226 TORAY CARBON FIBER AMERICA, INC. (CFA)AL 12/20/2007 &nbsp;ACT BOILERS 66.6 MMBTU/H each LOW NOX BURNERS PLUS FLUE GAS RECIRCULATION (FGR)0.024 LB/MMBTU NA BACT-PSD *WA-0350 SGL AUTOMOTIVE CARBON FIBERS WA 04/13/2015 &nbsp;ACT Carbon Fiber Production (Normal Operation) Lines 3-6 1760 tons of carbon fiber per year SCR for Lines 3 - 6. No SCR on lines 7-10 8.5 LB LB/HR OTHER CASE-BY-CASE Throughput Emission Limit RBLCID Facility/Agency Name State Permit/Document Issued Process Name Control Method Averaging Time Case-by-Case AL-0226 TORAY CARBON FIBER AMERICA, INC. (CFA)AL 12/20/2007 &nbsp;ACT 132,086 GALLON SOLVENT DELIVERY STORAGE TANK VENTED TO SCRUBBER SCRUBBER TA2-2 95 % REDUCTION NA N/A AL-0226 TORAY CARBON FIBER AMERICA, INC. (CFA)AL 12/20/2007 &nbsp;ACT 211,338 GALLON ACRYLONITRILE DELIVERY STORAGE TANK VENTED TO SCRUBBER TA2-2 SCRUBBER TA2-2 95 % REDUCTION NA N/A *WA-0350 SGL AUTOMOTIVE CARBON FIBERS WA 04/13/2015 &nbsp;ACT Carbon Fiber Production (Normal Operation) Lines 7-10 1760 tons of carbon fiber per year NA 1.7 LB HR BACT-PSD *WA-0350 SGL AUTOMOTIVE CARBON FIBERS WA 04/13/2015 &nbsp;ACT Carbon Fiber Production (Normal Operation) Lines 3-6 1760 tons of carbon fiber per year NA NA BACT-PSD Throughput Emission Limit NA NA NA RBLCID Facility/Agency Name State Permit/Document Issued Process Name Control Method Averaging Time Case-by-Case TX-0662 BEAUMONT PLANT TX 07/22/2014 &nbsp;ACT Methanol Plant Dry low NOx burners and SCR 0.015 LB/MMBTU 24-HOUR BACT-PSD *WA-0350 SGL AUTOMOTIVE CARBON FIBERS WA 04/13/2015 &nbsp;ACT Carbon Fiber Production (Shutdown Mode) Lines 3-6 SCR 8.5 LB HR OTHER CASE-BY-CASE *WA-0350 SGL AUTOMOTIVE CARBON FIBERS WA 04/13/2015 &nbsp;ACT Carbon Fiber Production (Normal Operation) Lines 3-6 1760 tons of carbon fiber per year SCR for Lines 3 - 6. No SCR on lines 7-10 8.5 LB LB/HR OTHER CASE-BY-CASE Throughput Emission Limit NA NA RBLCID Facility/Agency Name State Permit/Document Issued Process Name Control Method Averaging Time Case-by-Case IN-0251 RES POLYFLOW, LLC IN 08/03/2016 &nbsp;ACT PLASTICS TO FUEL CONVERSION 51.74 MMBTU/H PROCESS FUEL GAS COMBUSTION TO GENERATE HEAT REQUIRED FOR PROCESSING 98 % OVERALL CONTROL EF NA OTHER CASE-BY-CASE IN-0253 RES POLYFLOW, LLC IN 08/03/2016 &nbsp;ACT PLASTICS TO FUEL CONVERSION 51.74 MMBTU/H PROCESS FUEL GAS COMBUSTION TO GENERATE HEAT REQUIRED FOR PROCESSING 98 % OVERALL CONTROL EF NA OTHER CASE-BY-CASE LA-0295 WESTLAKE FACILITY LA 07/12/2016 &nbsp;ACT Bulk Storage Vents (RLP 5, 9, 10, &amp; 11)1200 ACFM Good design and operating practices 0.01 LB/H HOURLY MAXIMUM BACT-PSD *LA-0315 G2G PLANT LA 05/23/2014 &nbsp;ACT Methanol Degassing Water Scrubber 11.2 LB/H HOURLY MAXIMUM BACT-PSD TX-0681 OLEFINS PLANT TX 08/08/2014 &nbsp;ACT Caustic tank Carbon adsorption system (CAS)166 PPMW NA BACT-PSD TX-0888 ORANGE POLYETHYLENE PLANT TX 04/23/2020 &nbsp;ACT Ethylene Treater Regeneration Vents – Process Vents Emissions associated with this activity will be routed either back into the process or to flares. Any uncontrolled venting to the atmosphere will be limited to 20 ppmv of VOC. 20 PPMV UNCONTROLLED BACT-PSD TX-0888 ORANGE POLYETHYLENE PLANT TX 04/23/2020 &nbsp;ACT Polyethylene Product Residual Filters, Pellet Dewatering Dryers, and Pellet Loading – Process Vents Limiting amount of VOC per million pounds of pellets. Extruder vent emissions will be controlled using two thermal oxidizers. 80 LB/MMLB HOURLY BACT-PSD NA Throughput Emission Limit NA NA NA RBLCID Facility/Agency Name State Permit/Document Issued Process Name Control Method Averaging Time Case-by-Case AL-0226 TORAY CARBON FIBER AMERICA, INC. (CFA)AL 12/20/2007 &nbsp;ACT BOILERS 66.6 MMBTU/H each LOW NOX BURNERS PLUS FLUE GAS RECIRCULATION (FGR)0.024 LB/MMBTU NA BACT-PSD AL-0226 TORAY CARBON FIBER AMERICA, INC. (CFA)AL 12/20/2007 &nbsp;ACT CARBON FIBER MANUFACTURING PROCESS (CFA-3) WITH THERMAL OXIDIZER LOW NOX BURNERS AND GOOD OPERATING PRACTICES 57.6 LB/H NA BACT-PSD TX-0242 AMERICAN ACRYL L.P.TX 04/21/1999 &nbsp;ACT SUPPORT PROCESS UNITS USE NATURAL GAS IN BOILER, EMISSIONS FROM TANKS ROUTED TO SCRUBBER (99.9% RECOVERY), 28 LAER LDAR, BOILER EQUIPPED WITH LOW NOX BURNERS, O2 POOR AIR USED NA LAER Throughput Emission Limit NA NA NA RBLCID Facility/Agency Name State Permit/Document Issued Process Name Control Method Averaging Time Case-by-Case AL-0226 TORAY CARBON FIBER AMERICA, INC. (CFA)AL 12/20/2007 &nbsp;ACT 132,086 GALLON SOLVENT DELIVERY STORAGE TANK VENTED TO SCRUBBER SCRUBBER TA2-2 95 % REDUCTION NA N/A AL-0226 TORAY CARBON FIBER AMERICA, INC. (CFA)AL 12/20/2007 &nbsp;ACT 211,338 GALLON ACRYLONITRILE DELIVERY STORAGE TANK VENTED TO SCRUBBER TA2-2 SCRUBBER TA2-2 95 % REDUCTION NA N/A SC-0116 CYTEC CARBON FIBERS, LLC SC 04/30/2008 &nbsp;ACT AN STORAGE AND RECOVERY EXISTING WASTE HEAT RECOVERY BOILER OR PROCESS HEATER/AFTERBURNER WITH CARBON BED ADSORBERS AS BACK UP. 0.4 LB/H NA BACT-PSD SC-0116 CYTEC CARBON FIBERS, LLC SC 04/30/2008 &nbsp;ACT POLYMER PRODUCTION EXISTING WASTE HEAT RECOVERY BOILER OR PROCESS HEATER/AFTERBURNER WITH CARBON BED ADSORBERS AS BACK UP. 0.4 LB/H NA BACT-PSD SC-0116 CYTEC CARBON FIBERS, LLC SC 04/30/2008 &nbsp;ACT OXIDATION AND CARBONIZATION NATURAL GAS FIRED TWO-STAGE THERMAL OXIDIZER 20 PPMW TOC NA BACT-PSD SC-0122 CYTEC CARBON FIBERS, LLC SC 04/30/2008 &nbsp;ACT POLYMER PRODUCTION EXISTING WASTE HEAT RECOVERY BOILER OR PROCESS HEATER/AFTERBURNER WITH CARBON BED ADSORBERS AS BACK UP. 0.4 LB/H NA BACT-PSD SC-0122 CYTEC CARBON FIBERS, LLC SC 04/30/2008 &nbsp;ACT OXIDATION AND CARBONIZATION NATURAL GAS FIRED TWO-STAGE THERMAL OXIDIZER 20 PPMV TOC NA BACT-PSD TX-0242 AMERICAN ACRYL L.P.TX 04/21/1999 &nbsp;ACT SUPPORT PROCESS UNITS 28 LAER LDAR, MONITORING, EMISSIONS FROM TANKS ROUTED TO THE SCRUBBER (99.9% RECOVERY)NA LAER NA Throughput Emission Limit NA NA NA NA NA NA NA NA