DAQ-2024-008107

1/23/24, 11:28 AM State of Utah Mail - Easton Technical Products Ozone RACT Analysis
https://mail.google.com/mail/u/0/?ik=539c285453&view=pt&search=all&permmsgid=msg-f:1786550844794523150&simpl=msg-f:1786550844794523…1/2
Ana Williams <[e-mail]>
Easton Technical Products Ozone RACT Analysis
Brian Mensinger <[e-mail]>Thu, Dec 28, 2023 at 11:20 AM
To: Ana Williams <[e-mail]>, "Jon Black ([e-mail])" <[e-mail]>
Cc: "Adam R. King" <[e-mail]>, Chase Peterson <[e-mail]>
Ana,
Attached is Easton Technical Products (Easton’s) Reasonably Available Control Technology (RACT) analysis for 2015 8-hour
Ozone Standard and its precursors (NOx and VOCs) in response to the letter sent by the Utah Division of Air Quality on May
31, 2023, which is required to be submitted by January 2, 2024.

Easton’s business climate is in a period of change, as their client demands continue to evolve. This may result in future
changes to the Salt Lake Facility, including changes to emissions sources, emissions calculations methodologies, and/or
emission factors. However, for the purposes of this RACT analysis, Easton has evaluated its emissions profile in a manner
consistent with historical emissions calculations, i.e., those used to develop its 2015 Approval Order (AO) DAQE-
AN103650011-15. Easton requests that UDAQ reach out to Adam King (Easton), Chase Peterson (Trinity Consultants), or
Brian Mensinger (Trinity Consultants), copied on this email, before making any recommendations or final decisions on this
RACT analysis to ensure plans align with Easton’s long-term business outlook.

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: [e-mail]
Phone: [phone] Cell: [phone]

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, 11:28 AM State of Utah Mail - Easton Technical Products Ozone RACT Analysis
https://mail.google.com/mail/u/0/?ik=539c285453&view=pt&search=all&permmsgid=msg-f:1786550844794523150&simpl=msg-f:1786550844794523…2/2
Easton Ozone RACT Analysis 2023-1222 v1.00.pdf
1044K
OZONE SERIOUS NONATTAINMENT SIP
Reasonably Available Control Technology Analysis
Easton Technical Products / Salt Lake City, UT

Prepared By:
TRINITY CONSULTANTS
4525 Wasatch Boulevard
Suite 200
Salt Lake City, UT 84124
[phone]

Prepared On Behalf Of:
EASTON TECHNICAL PRODUCTS
5040 W Harold Gatty Dr.
Salt Lake City, UT

December 2023

Project 234502.0054

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TABLE OF CONTENTS
1. EXECUTIVE SUMMARY 1-1
2. INTRODUCTION 2-1
2.1 Description of Facility ............................................................................................... 2-1
2.2 Emission Profile ........................................................................................................ 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. BOILERS 4-1
4.1 Boilers NOX RACT ...................................................................................................... 4-1
4.1.1 Boilers NOX, Step 1 - Identify All Reasonably Available Control Technologies ................. 4-1
4.1.2 Boilers NOX, Step 2 - Eliminate Technically Infeasible Control Technologies ................... 4-1
4.1.3 Boilers NOX, Step 3 - Rank Remaining Control Technologies by Control Effectiveness ..... 4-3
4.1.4 Boilers NOX, Step 4 – Evaluate Most Effective Controls and Document Results ............... 4-3
4.1.5 Boilers NOX, Step 5 – Select RACT ............................................................................ 4-4
4.2 Boilers VOCs RACT ..................................................................................................... 4-4
4.2.1 Boilers VOCs, Step 1 - Identify All Reasonably Available Control Technologies ............... 4-4
4.2.2 Boilers VOCs, Step 2 - Eliminate Technically Infeasible Control Technologies ................. 4-4
4.2.3 Boilers VOCs, Steps 3-5 – Select RACT ...................................................................... 4-5
5. OVEN 5-1
5.1 Oven NOX RACT ......................................................................................................... 5-1
5.1.1 Oven NOX, Step 1 - Identify All Reasonably Available Control Technologies ................... 5-1
5.1.2 Oven NOX, Step 2 - Eliminate Technically Infeasible Control Technologies ..................... 5-1
5.1.3 Oven NOX, Step 3 - Rank Remaining Control Technologies by Control Effectiveness ....... 5-2
5.1.4 Oven NOX, Step 4– Evaluate Most Effective Controls and Document Results .................. 5-2
5.1.5 Oven NOX, Step 5 – Select RACT .............................................................................. 5-2
5.2 Oven VOCs RACT ....................................................................................................... 5-2
5.2.1 Oven VOCs, Step 1 - Identify All Reasonably Available Control Technologies ................. 5-2
5.2.2 Oven VOCs, Step 2 - Eliminate Technically Infeasible Control Technologies ................... 5-3
5.2.3 Oven VOCs, Steps 3-5 – Select RACT ........................................................................ 5-3
6. OTHER SMALL NATURAL GAS BURNERS 6-1
6.1 Other Small Natural Gas Burners NOX RACT .............................................................. 6-1
6.1.1 Other Small Natural Gas Burners NOX, Step 1 - Identify All Reasonably Available Control
Technologies ..................................................................................................................... 6-1
6.1.2 Other Small Natural Gas Burners NOX, Step 2 - Eliminate Technically Infeasible Control
Technologies ..................................................................................................................... 6-1
6.1.3 Other Small Natural Gas Burners NOX, Steps 3 - Rank Remaining Control Technologies by
Control Effectiveness ......................................................................................................... 6-2
6.1.4 Other Small Natural Gas Burners NOX, Steps 4 – Evaluate Most Effective Controls and
Document Results .............................................................................................................. 6-2
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6.1.5 Other Small Natural Gas Burners NOX, Steps 5 – Select RACT ...................................... 6-2
6.2 Other Small Natural Gas Burners VOCs RACT ............................................................ 6-2
6.2.1 Other Small Natural Gas Burners VOCs, Step 1 - Identify All Reasonably Available Control
Technologies ..................................................................................................................... 6-2
6.2.2 Other Small Natural Gas Burners VOCs, Step 2 - Eliminate Technically Infeasible Control
Technologies ..................................................................................................................... 6-3
6.2.3 Other Small Natural Gas Burners VOCs, Steps 3-5 – Select RACT ................................. 6-3
7. NATURAL GAS-FIRED EMERGENCY GENERATOR ENGINES 7-1
7.1 Natural Gas Fired Engines NOX and VOCs RACT ......................................................... 7-1
7.1.1 Natural Gas Emergency Generators NOX and VOCs, Step 1 - Identify All Reasonably
Available Control Technologies ............................................................................................ 7-1
7.1.2 Natural Gas Emergency Generators NOX and VOCs, Step 2 - Eliminate Technically
Infeasible Control Technologies ........................................................................................... 7-1
7.1.3 Natural Gas Emergency Generators NOX and VOCs, Steps 3–5 – Select RACT ................ 7-3
8. PAINT BOOTH 8-1
8.1 Paint Booth VOCs RACT ............................................................................................. 8-1
8.1.1 Paint Booth VOCs, Step 1 – Identify All Reasonably Available Control Technologies ....... 8-1
8.1.2 Paint Booth VOCs, Step 2 - Eliminate Technically Infeasible Control Technologies .......... 8-1
8.1.3 Paint Booth VOCs, Step 3 - Rank Remaining Control Technologies by Control Effectiveness
8-2
8.1.4 Paint Booth VOCs, Step 4 – Evaluate Most Effective Controls and Document Results ...... 8-3
8.1.5 Paint Booth VOCs, Step 5 – Select RACT ................................................................... 8-3
9. PULTRUSION 9-1
9.1 Pultrusion VOCs RACT ............................................................................................... 9-1
9.1.1 Pultrusion VOCs, Step 1 - Identify All Reasonably Available Control Technologies .......... 9-1
9.1.2 Pultrusion VOCs, Step 2 – Eliminate Technically Infeasible Control Technologies ........... 9-1
9.1.3 Pultrusion VOCs, Step 3 – Rank Remaining Control Technologies by Control Effectiveness 9-
2
9.1.4 Pultrusion VOCs, Step 4 – Evaluate Most Effective Controls and Document Results ........ 9-3
9.1.5 Pultrusion VOCs, Step 5 – Select RACT ...................................................................... 9-3
10. DEGREASING 10-4
10.1 Degreasing VOCs RACT ........................................................................................... 10-4
10.1.1 Degreasing VOCs, Step 1 – Identify All Reasonably Available Control Technologies ...... 10-4
10.1.2 Degreasing VOCs, Step 2 – Eliminate Technically Infeasible Control Technologies ........ 10-4
10.1.3 Degreasing VOCs, Step 3 - Rank Remaining Control Technologies by Control Effectiveness
10-6
10.1.4 Degreasing VOCs, Step 4 – Evaluate Most Effective Controls and Document Results .... 10-6
10.1.5 Degreasing VOCs, Step 5 – Select RACT .................................................................. 10-7
11. SMALL FUGITIVES 11-1
11.1 Small Fugitives VOCs RACT ..................................................................................... 11-1
11.1.1 Small Fugitives VOCs, Step 1 – Identify All Control Technologies ................................ 11-1
11.1.2 Small Fugitives VOCs, Step 2 – Eliminate Technically Infeasible Control Technologies .. 11-1
11.1.3 Small Fugitives VOCs, Steps 3-5 – Select RACT ........................................................ 11-2
12. CONCLUSIONS 12-1
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APPENDIX A. DETAILED COST CALCULATIONS A-1
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1. EXECUTIVE SUMMARY
On May 31, 2023, the Utah Division of Air Quality (UDAQ) sent a letter to Easton Technical Products
(Easton) that identified Easton’s Salt Lake Facility (the Salt Lake Facility) as a major stationary source within
the Northern Wasatch Front (NWF) Ozone Nonattainment Area (NAA). This letter indicated that UDAQ
anticipates that the United States Environmental Protection Agency (EPA) will reclassify the NWF 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, one of which is a RACT
analysis for all major sources.

The precursors to ozone are oxides of nitrogen (NOX) and volatile organic compounds (VOCs). Thus, the
enclosed RACT analysis focuses on the emission sources at the Salt Lake Facility that emit these pollutants.
Easton has the potential to emit 50 tons per year (tpy) or more of VOCs, classifying it as a major source
subject to SIP requirements.

Easton’s business climate is in a period of change, as their client demands continue to evolve. This may
result in future changes to the Salt Lake Facility, including changes to emissions sources, emissions
calculations methodologies, and/or emission factors. However, for the purposes of this RACT analysis,
Easton has evaluated its emissions profile in a manner consistent with historical emissions calculations, i.e.,
those used to develop its 2015 Approval Order (AO) DAQE-AN103650011-15.

UDAQ has requested the following elements for a 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 rates 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, Easton is submitting this RACT analysis no later than January 2, 2024.

1 Ozone SIP Planning RACT Analysis information provided by Ana Williams, Utah Department of Environmental Quality on
January 9, 2023.
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2. INTRODUCTION
2.1 Description of Facility
Easton manufactures a variety of products, from archery arrows to medical equipment, and from tent poles
to military equipment. Its Salt Lake Facility is located in Salt Lake City, Utah, in Salt Lake County. Its air
emissions primarily consist of VOCs resulting from materials used in or on their products. Easton currently
operates under approval order (AO) DAQE-AN103650011-15. This RACT analysis focuses on the following
equipment:

► Natural gas-fired boilers;
 Two (2) 5.25 million British thermal units per hour (MMBtu/hr), each
► Natural gas-fired oven;
 One (1) 6.00 MMBtu/hr
► Other small natural gas-fired burners;
 One (1) 2.45 MMBtu/hr
 One (1) 0.35 MMBtu/hr
 Two (2) 0.40 MMBtu/hr, each
 One (1) 0.33 MMBtu/hr
 Two (2) 1.70 MMBtu/hr
 One (1) 0.43 MMBtu/hr
 One (1) 0.03 MMBtu/hr
► Natural gas-fired emergency generators;
 Two (2) 63 horsepower (hp)
► A paint booth;
► Pultrusion lines;
► Degreasing dip tanks; and
► Small fugitives.

Each of these emission sources will be discussed in a subsequent section. All correspondence regarding this
submission should be addressed to:

► Mr. Adam King
► Easton Technical Products
► Environmental, Health, and Safety Manager
► 5040 Harald Gatty Dr.
► Salt Lake City, UT 84116
► Phone: [phone], ext. 2293
► Email: [e-mail]
2.2 Emission Profile
Easton has established the following Potential to Emit (PTE) profile, given in tons per year (tpy). A full
explanation of calculation methods and inputs can be found within the 2015 permitting files.
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Table 2-1. Easton’s PTE
Unit Group
Potential Annual
Emissions Estimate
(tpy)
NOX VOC
Boilers 1.60 0.09
Oven 0.91 0.05
Other Small Natural Gas Burners 1.16 0.06
Natural Gas-Fired Emergency
Generator Engines 0.05 0.01
Paint Booth -- 1.01
Pultrusion -- 13.73
Degreasing -- 32.27
Small Fugitives -- 4.86
Total PTE 3.73 52.09

Actual emissions from 2017 will be utilized in initial SIP planning. The Salt Lake Facility’s 2020 actual
emissions are presented here due to their improved representation of the Salt Lake Facility since the 2017
reporting period.
Table 2-2. Easton’s 2020 Actual Emissions
Unit Group Actual Annual Emissions Estimate (tpy)
NOX VOC
Total 2020 Emission Rate 3.88 4.40
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3. REASONABLY AVAILABLE CONTROL TECHNOLOGIES BACKGROUND
Easton has organized this 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), a recommendation to
states is provided, 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
Easton has referenced the published CTGs, 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
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 it 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”

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.
6 UDAQ Ozone SIP Planning RACT Analysis, provided January 9, 2023.
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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 (5) basic steps of a “top-down” RACT analysis, 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 CTGs,
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 that 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; 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 (1) 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
feasible without adverse energy or environmental impacts, it is not necessary to evaluate the remaining
options with lower control efficiencies.

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

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.
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.
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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.

The following sections, Sections 4 through 11, represent the Salt Lake Facility’s RACT analysis. Each section
represents a different emissions source group.
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4. BOILERS
Easton operates two (2) 5.25 MMBtu/hr boilers at the Salt Lake Facility.
4.1 Boilers NOX RACT
The NOX that is formed during combustion results from two (2) primary 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.
4.1.1 Boilers NOX, Step 1 - Identify All Reasonably Available Control Technologies
In order to identify control technologies applied to natural gas boilers, the following sources were reviewed:

► EPA’s RBLC Database;10
► EPA’s Air Pollution Technology Fact Sheets;
► South Coast Air Quality Management District (SCAQMD) Example Permits;
► Texas Commission of Environmental Quality’s (TCEQ’s) BACT Combustion Workbook; and
► Bay Area Air Quality Management District (BAAQMD) Nonroad BACT Assessments.

Available control technologies for natural gas boilers include the following:

► Low NOx Burner (LNB);
► Ultra Low NOx Burner (ULNB);
► Flue Gas Recirculation (FGR);
► Selective Catalytic Reduction (SCR); and
► Good combustion practices.

The control efficiencies, as well as technical and economic feasibility, are compared to the closest available
presumptive norm for natural gas boilers as established in UAC R307-316 NOX Emission Controls for Natural-
Gas Fired Boilers greater than 5 MMBtu/hr. The boilers rated at 5.25 MMBtu/hr are subject to rule R307-
316. The standards included in R307-316 are as follows:

► NOX Emission Rate of nine (9) parts per million by volume (ppmv); and
► Operation and maintenance (O&M) in accordance with manufacturer's emissions-related instructions.11
4.1.2 Boilers NOX, Step 2 - Eliminate Technically Infeasible Control Technologies
To demonstrate a complete analysis, Easton has evaluated the following technologies, including both
replacement burners and add-on controls.

10 Database accessed November 9, 2023.
11 R307-316 does not require the retrofit of existing units to meet the established standards.
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LNB/ULNB
LNB/ULNB 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 staged fuel LNB/ULNB, 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 leftover 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. ULNB often incorporates internal FGR for
further emissions control.

Removal and replacement of the combustion chamber may cause technical issues such as limited space
availability, platform modifications, and modification of fuel supply, instrumentation, and valves.12
Therefore, due to the need to re-design the combustion chamber, LNB and ULNB are technically infeasible.
However, an economic feasibility analysis has been included for completeness.
FGR
FGR is frequently used with both LNB and ULNB burners. However, it can also be utilized as a standalone
technology outside of the combustion chamber. FGR involves the recycling of post-combustion air into the
air-fuel mixture to reduce the available oxygen and help cool the burner flame.

Implementation of external FGR requires several physical modifications including tapping the exhaust duct
to draw flue gas and recirculating it back to the fan. Additionally, minor modifications will also be needed for
damper controls.13 These physical modifications for the exhaust duct are often made to the outside of the
unit to eliminate further modifications to the combustion chamber. The inclusion of additional duct work and
associated fans all requires enough space for the additional equipment, as well as sufficient space around
the equipment to ensure proper maintenance.

The boilers and burners at the Salt Lake Facility are inside a building and are surrounded by other
equipment. The physical locations of the boilers and heaters do not allow for the additional duct work
required to tap into the exhaust stream and redirect it back to the combustion chamber. Thus, FGR is
technically infeasible.
SCR
SCR has been applied to stationary, fossil fuel-fired, combustion units for emission control since the early
1970s. It has been applied to large (>250 MMBtu/hr) 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. This reduces the NOX into nitrogen and
water.14 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. In practice, SCR systems
operate at efficiencies in the range of 70 to 90 percent.15

12 The Ins and Outs of Low NOX Burner Retrofits (power-eng.com).
13 NOX Control on a Budget: Induced Flue Gas Recirculation (power-eng.com).
14 EPA Air Pollution Control Technology Fact Sheet, SCR, EPA-452/F-03-032.
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
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The control effectiveness of SCR for a unit less than 250 MMBtu/hr is highly dependent on the configuration
of all controls involved.

A search of EPA’s RBLC showed that no burners less than or equal to 13 MMBtu/hr have installed SCRs as
control equipment. Therefore, SCR is not considered technically feasible as it is not commercially available.16
Good Combustion Practices
The use of good combustion practices 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. Good combustion practices are accomplished through burner design as it
relates to time, temperature, and turbulence, and burner operation as it relates to excess oxygen levels.
This control technology is technically feasible.
4.1.3 Boilers NOX, Step 3 - Rank Remaining Control Technologies by Control
Effectiveness
The technically feasible control technologies evaluated above are ranked based on which technology can
achieve the lowest emission rate.

1. ULNB = 9 ppm or 0.008 lb/MMBtu
2. LNB = 30 ppm or 0.036 lb/MMBtu
3. Good Combustion Practices
4.1.4 Boilers NOX, Step 4 – Evaluate Most Effective Controls and Document
Results
Easton conducted a cost analysis for a LNB and ULNB following the method described in EPA Cost Control
Manual Chapter 2, Concepts and Methodology. Key to this analysis is the NOX emission rate reductions and
interest rate. For this analysis, Easton has used a reduction rate of 50 and 60 percent for LNB and ULNB,
respectively, from EPA Alternative Control Technology Guidelines.17
Since the actual nominal interest rate for a project of this type is not readily available to Easton, 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%.18 A nominal interest rate of 7% has
been referenced in EPA’s Cost Manual and has been commonly relied upon for control technology analyses
for several decades as a representative average over time.

Using a manufacturer-supplied total equipment cost and 7% interest rate, it would cost $255,346 and
$212,789/ton of NOX removed for LNB and ULNB, respectively. Calculations are shown in Appendix A and
are based on EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and Methodology,
Table 2.4.

16 Database accessed November 9, 2023.
17 EPA Technical Bulletin, Nitrogen Oxides (NOX) Why and How They Are Controlled, Table 16. Unit Cost for NOX Control
Technologies for Non Utility Stationary Sources, Source Type - Process Heaters - Natural Gas – LNB & LNB+FGR
18 OMB Circular A-4, https://obamawhitehouse.archives.gov/omb/circulars_a004_a-4/
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The cost per ton of NOX removed is beyond acceptable cost control effectiveness levels.
4.1.5 Boilers NOX, Step 5 – Select RACT
The retrofit technologies reviewed have been established as technically or economically infeasible. As a
result, Easton proposes the implementation of good combustion practices as RACT.
4.2 Boilers VOCs RACT
4.2.1 Boilers VOCs, Step 1 - Identify All Reasonably Available Control
Technologies
In order to identify control technologies applied to natural gas boilers the following sources were reviewed:

► EPA’s RBLC Database;19
► EPA’s Air Pollution Technology Fact Sheets;
► SCAQMD Example Permits;
► TCEQ’s BACT Combustion Workbook; and
► BAAQMD Nonroad BACT Assessments.

Available control technologies for natural gas boilers include the following:

► Oxidizers; and
► Good combustion practices.
4.2.2 Boilers VOCs, Step 2 - Eliminate Technically Infeasible Control Technologies
Oxidizers
Thermal oxidation, regenerative thermal oxidation, and catalytic oxidation all destroy VOCs by raising the
temperature of the material above its auto-ignition point in the presence of oxygen, and maintaining it at
high temperature for sufficient time to complete combustion to carbon dioxide and water.20 The search of
EPA’s RBLC and the various air management districts’ databases showed that no burners less than or equal
to 6.0 MMBtu/hr have installed oxidizers (thermal oxidizer/afterburner, RTO, catalytic oxidation) as control
equipment. The implementation of oxidizers for the control of VOCs was isolated to unique cases, and the
generally established control method did not include the use of an oxidizer. As such, oxidizers are technically
infeasible.
Good Combustion Practices
The use of good combustion practices usually includes the following components: (1) proper fuel mixing in
the combustion zone; (2) high temperatures and low oxygen levels in the primary zone; (3) overall excess
oxygen levels high enough to complete combustion while maximizing burner efficiency, and (4) sufficient
residence time to complete combustion. Good combustion practices are accomplished through burner design
as it relates to time, temperature, and turbulence, and burner operation as it relates to excess oxygen
levels. This technology is technically feasible.

19 Database accessed November 9, 2023.
20 Thermal Incinerator, Air Pollution Control Technology Fact Sheet, EPA-452/F-03-022
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4.2.3 Boilers VOCs, Steps 3-5 – Select RACT
The execution of good combustion practices is the only control technology that is technically feasible for the
boilers and burners at the Sale Lake Facility. As such, good combustion practices are determined to be RACT
for Easton’s boilers and burners.
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5. OVEN
Easton operates one (1) 6.0 MMBtu/hr oven at the Salt Lake Facility.
5.1 Oven NOX RACT
NOX formed during combustion results from two (2) major mechanisms: thermal NOX and fuel NOX. Because
natural gas is relatively free of fuel-bound nitrogen, the contribution 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.
5.1.1 Oven NOX, Step 1 - Identify All Reasonably Available Control Technologies
In order to identify control technologies applied to natural gas ovens the following sources were reviewed:

► EPA’s RBLC Database;21
► EPA’s Air Pollution Technology Fact Sheets;
► SCAQMD Example Permits;
► TCEQ’s BACT Combustion Workbook; and
► BAAQMD Nonroad BACT Assessments.

Available control technologies for natural gas ovens include the following:

► LNB; and
► Good combustion practices.
5.1.2 Oven NOX, Step 2 - Eliminate Technically Infeasible Control Technologies
LNB
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 staged 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 leftover 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.

The oven is not currently equipped with LNBs, and their installation would require a complete redesign of its
combustion system. As a result, the installation of LNBs makes this control system technically infeasible.
However, a cost analysis has been included for completeness.

21 Database accessed December 18, 2023.
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Good Combustion Practices
The use of good combustion practices 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. Good combustion practices are accomplished through burner design as it
relates to time, temperature, and turbulence, and burner operation as it relates to excess oxygen levels.
This control technology is technically feasible.
5.1.3 Oven NOX, Step 3 - Rank Remaining Control Technologies by Control
Effectiveness
The technically feasible control technologies evaluated above are ranked based on which technology can
achieve the lowest emission rate.

1. LNB = 30 ppm or 0.036 lb/MMBtu
2. Good Combustion Practices
5.1.4 Oven NOX, Step 4– Evaluate Most Effective Controls and Document Results
Easton conducted a cost analysis for the implementation of an LNB. Consistent with the methodology
described for the Boilers, a manufacturer-supplied total equipment cost and 7% interest rate resulted in
$226,142/ton of NOX removed. The cost per ton of NOX removed is beyond acceptable cost control
effectiveness levels. Therefore, Easton considers this technology economically infeasible for this unit.
5.1.5 Oven NOX, Step 5 – Select RACT
The retrofit of technologies reviewed has been established as technically or economically infeasible. As a
result, Easton proposes the implementation of good combustion practices as RACT.
5.2 Oven VOCs RACT
5.2.1 Oven VOCs, Step 1 - Identify All Reasonably Available Control Technologies
In order to identify control technologies applied to natural gas ovens, the following sources were reviewed:

► EPA’s RBLC Database;22
► EPA’s Air Pollution Technology Fact Sheets;
► SCAQMD Example Permits;
► TCEQ’s BACT Combustion Workbook; and
► BAAQMD Nonroad BACT Assessments.

Available control technologies for natural gas ovens include the following:

► Oxidizers; and
► Good combustion practices.

22 Database accessed November 9, 2023.
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5.2.2 Oven VOCs, Step 2 - Eliminate Technically Infeasible Control Technologies
Oxidizers
The search of EPA’s RBLC showed that no burners less than or equal to 6.0 MMBtu/hr have installed
oxidizers (thermal oxidizer/afterburner, RTO, or catalytic oxidation) as control equipment. As such, Easton
considers oxidizers as technically infeasible for the oven at the Salt Lake Facility.
Good Combustion Practices
The use of good combustion practices 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 burner efficiency, and (4) sufficient
residence time to complete combustion. Good combustion practices are accomplished through burner design
as it relates to time, temperature, and turbulence, and burner operation as it relates to excess oxygen
levels. This technology is technically feasible.
5.2.3 Oven VOCs, Steps 3-5 – Select RACT
The execution of good combustion practices is the only control technology that is technically feasible for the
boilers and burners at the Salt Lake Facility. As such, good combustion practices are determined to be RACT
for Easton’s oven.
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6. OTHER SMALL NATURAL GAS BURNERS
Easton operates various small heaters and ovens. As these units are <2.50 MMBtu/hr and are direct fired,
add on controls are not technically feasible and have not been considered for these units.
6.1 Other Small Natural Gas Burners NOX RACT
6.1.1 Other Small Natural Gas Burners NOX, Step 1 - Identify All Reasonably
Available Control Technologies
In order to identify control technologies applied to natural gas burners the following sources were reviewed:

► EPA’s RBLC Database; 23
► EPA’s Air Pollution Technology Fact Sheets;
► SCAQMD Example Permits;
► TCEQ’s BACT Combustion Workbook; and
► BAAQMD Nonroad BACT Assessments.

Available control technologies for natural gas burners include the following:

► LNB;24 and
► Good combustion practices.

No presumptive norm has been previously established for these units.
6.1.2 Other Small Natural Gas Burners NOX, Step 2 - Eliminate Technically
Infeasible Control Technologies
Easton has evaluated the following technologies.
LNB
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 staged 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 leftover 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.

LNB technology uses internal FGR, which involves recirculating hot oxygen-depleted flue gas from the
heater into the combustion zone using burner design features and fuel staging to reduce NOX. This
technology is technically feasible.

23 Database accessed December 18, 2023.
24 The RBLC Database search did not list this technology for units less than 2.50 MMBtu/hr.
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Good Combustion Practices
The use of good combustion practices 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. Good combustion practices are accomplished through burner design as it
relates to time, temperature, and turbulence, and burner operation as it relates to excess oxygen levels.
This control technology is technically feasible.
6.1.3 Other Small Natural Gas Burners NOX, Steps 3 - Rank Remaining Control
Technologies by Control Effectiveness
The technically feasible control technologies evaluated above are ranked based on which technology can
achieve the lowest emission rate.

1. LNB = 30 ppm or 0.036 lb/MMBtu
2. Good Combustion Practices
6.1.4 Other Small Natural Gas Burners NOX, Steps 4 – Evaluate Most Effective
Controls and Document Results
Easton conducted a cost analysis for the implementation of LNB. For this analysis, Easton has used a
reduction rate of 50 percent, taken from EPA Alternative Control Technology Guidelines.25 Consistent with
the methodology described for the Boilers, a manufacturer-supplied total equipment cost and 7% interest
rate resulted in $547,722/ton of NOX removed for an LNB. The cost per ton of NOX removed is beyond
acceptable cost control effectiveness levels; therefore, Easton considers this burner technology economically
infeasible for these units.

The cost per ton of NOX removed increases as the unit size decreases. As a result, LNBs and ULNBs for
smaller units are also considered economically infeasible.
6.1.5 Other Small Natural Gas Burners NOX, Steps 5 – Select RACT
The retrofit of reviewed technologies has been established as technically or economically infeasible. As a
result, Easton proposes the implementation of good combustion practices as RACT.
6.2 Other Small Natural Gas Burners VOCs RACT
6.2.1 Other Small Natural Gas Burners VOCs, Step 1 - Identify All Reasonably
Available Control Technologies
In order to identify control technologies applied to natural gas burners, the following sources were
reviewed:

► EPA’s RBLC Database;26
► EPA’s Air Pollution Technology Fact Sheets;
► SCAQMD Example Permits;

25 EPA Technical Bulletin, Nitrogen Oxides (NOX) Why and How They Are Controlled, Table 16. Unit Cost for NOX Control
Technologies for Non Utility Stationary Sources, Source Type - Process Heaters - Natural Gas – LNB & ULNB
26 Database accessed November 9, 2023.
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► TCEQ’s BACT Combustion Workbook; and
► BAAQMD Nonroad BACT Assessments.

Available control technologies for natural gas burners include the following:

► Oxidizers; and
► Good combustion practices.
6.2.2 Other Small Natural Gas Burners VOCs, Step 2 - Eliminate Technically
Infeasible Control Technologies
Oxidizers
The search of EPA’s RBLC showed that no burners less than or equal to 6.0 MMBtu/hr have installed
oxidizers (thermal oxidizer/afterburner, RTO, or catalytic oxidation) as control equipment. As such, Easton
considers oxidizers as technically infeasible for the burners and boilers at the Salt Lake Facility.
Good Combustion Practices
The use of good combustion practices 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 burner efficiency, and (4) sufficient
residence time to complete combustion. Good combustion practices are accomplished through burner design
as it relates to time, temperature, and turbulence, and burner operation as it relates to excess oxygen
levels. This technology is technically feasible.
6.2.3 Other Small Natural Gas Burners VOCs, Steps 3-5 – Select RACT
The execution of good combustion practices is the only control technology that is technically feasible for the
other small natural gas burners at the Sale Lake Facility. As such, good combustion practices are determined
to be RACT for Easton’s other small burners.
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7. NATURAL GAS-FIRED EMERGENCY GENERATOR ENGINES
Easton currently operates two (2) 63 hp natural gas-fired emergency generator engines to maintain critical
systems during an emergency.
7.1 Natural Gas Fired Engines NOX and VOCs RACT
7.1.1 Natural Gas Emergency Generators NOX and VOCs, Step 1 - Identify All
Reasonably Available Control Technologies
The following sources were reviewed to identify available control technologies:

► SCAQMD LAER/BACT Determinations;
► SJVAPCD BACT Clearinghouse;
► BAAQMD BACT/TBACT Workbook
► TCEQ BACT Requirements;
► EPA’s RACT/BACT/LAER Clearinghouse RBLC Database for Natural Gas Generators (process type 17.230
Small Internal Combustion Engines [<500 hp] – Natural Gas)27; and
► EPA’s Air Pollution Control Technology Fact Sheets.

Available control technologies for natural gas-fired emergency generator engines include the following:

► Limited Hours of Operation;
► Routine Maintenance;
► Good Combustion Practices;
► Use of Natural Gas;
► SCR; and
► Non-Selective Catalyst Reduction (NSCR).

The following step evaluates the technical feasibility of each of these options.
7.1.2 Natural Gas Emergency Generators NOX and VOCs, Step 2 - Eliminate
Technically Infeasible Control Technologies
Limited Hours of Operation
One (1) available way to control the emissions of all pollutants released from a natural gas-fired emergency
generator engine is to limit the hours of operation for the equipment. Under New Source Performance
Standards (NSPS) Subpart JJJJ28, only 100 hours of operation for maintenance and testing are allowed for
generators designated as emergency. It is conservatively estimated that the emergency generators will each
run for no more than 100 hours per year for testing and maintenance. This option is considered technically
feasible.

27 Database accessed November 10, 2023.
28 40 CFR 60.4243(d)(2)
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Routine Maintenance
Routine maintenance ensures the engine is working properly and as efficiently as possible, which, in turn,
helps reduce emissions. For spark ignition internal combustion engines, 40 CFR 60 Subpart JJJJ requires
that owners and operators of EPA-certified engines operate and maintain the engine consistent with the
manufacturer’s emissions-related written instructions. Routine maintenance is considered technically
feasible.
Good Combustion Practices
Good combustion practices refer to the operation of engines at high combustion efficiency, which reduces
the products of incomplete combustion. The natural gas-fired emergency generator engines at Easton are
designed to achieve maximum combustion efficiency. The manufacturer has provided operation and
maintenance manuals that detail the required methods to achieve the highest levels of combustion
efficiency for the units. Use of good combustion practices is considered technically feasible.
Use of Natural Gas
Natural gas is one of the cleanest fossil fuels and is a highly efficient form of energy. It is composed mainly
of methane, and its combustion results in less NOX in comparison to other fossil fuels. Use of natural gas for
the emergency generator engines is considered technically feasible.
SCR
SCR systems introduce a liquid reducing agent such as ammonia or urea into the flue gas stream prior to a
catalyst. The catalyst then reduces the temperature needed to initiate the reaction between the reducing
agent and NOX to form nitrogen and water.

For SCR systems to function effectively, exhaust temperatures must be high enough (200°C to 500°C) to
enable catalyst activation. For this reason, SCR control efficiencies are expected to be relatively low during
the first 20 to 30 minutes after engine start up, especially during maintenance and testing. Generally,
engine loads during maintenance and testing for emergency engines are very low, which also reduces
exhaust temperatures, resulting in low SCR control efficiencies. Controlling the excess ammonia (ammonia
slip) from SCR use can also be difficult. Although SCR has been implemented on large (greater than one [1]
megawatt [MW]) diesel-fired emergency generators, it has not been demonstrated on smaller emergency
engines or natural gas-fired units.29 Since SCR is anticipated to have a relatively low control efficiency during
maintenance and testing due to short periods of operation, low loads, and frequent starts/stops,
implementing SCR technology for the emergency engine is not technically feasible.
NSCR
NSCR is an add-on NOX control technology for exhaust streams with low oxygen content. NSCR uses a
catalyst reaction to simultaneously reduce NOX, CO, and hydrocarbon to water, carbon dioxide, and
nitrogen. The catalyst is usually a noble metal.30 NSCR has many of the same operational issues as an SCR,
most notably the need for the temperature to reach approximately 850°F to enable catalyst activation.
NSCR control efficiencies are expected to be relatively low during the first 20 to 30 minutes after engine

29 Appendix B: Analysis of the Technical Feasibility and Costs of After-Treatment Controls on New Emergency Standby Engines
California Air Resources Board
30 CAM Technical Guidance Document, B.16 Nonselective Catalytic Reduction;
https://www3.epa.gov/ttnchie1/mkb/documents/B_16a.pdf
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start up. Because testing and maintenance operation of emergency engines is typically done for short
duration runs, NSCRs are considered technically infeasible.
7.1.3 Natural Gas Emergency Generators NOX and VOCs, Steps 3–5 – Select RACT
Easton proposes that RACT for the natural gas-fired emergency generator engines is operating and
maintaining the engine in accordance with good combustion practices, which will include routine
maintenance being performed on the units in accordance with the NSPS Subpart JJJJ requirements and
combusting only natural gas. The hours of operation will be limited to 100 hours for maintenance and
testing per year in accordance with NSPS Subpart JJJJ and Reciprocating Internal Combustion Engine (RICE)
National Emission Standards for Hazardous Air Pollutants (NESHAP) Subpart ZZZZ.
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8. PAINT BOOTH
8.1 Paint Booth VOCs RACT
8.1.1 Paint Booth VOCs, Step 1 – Identify All Reasonably Available Control
Technologies
Easton has reviewed the following sources to identify available control technologies:
► EPA’s RBLC Database;31
► EPA’s Air Pollution Technology Fact Sheets;
► SCAQMD LAER/BACT Determinations;
► San Joaquin Valley Air Pollution Control District (SJVAPCD) BACT Clearinghouse;
► BAAQMD BACT/TBACT Workbook;
► Permits available online; and
► Utah Administrative Rule 307-350 Miscellaneous Parts and Product Coatings.

Several add-on control technologies were identified to reduce VOC emissions from painting activities. These
add-on control technologies include:

► Oxidizers:
 Thermal oxidizer (TO);
 Regenerative Thermal Oxidizer (RTO);
► Carbon Adsorption;
► Reduced VOC content;
► Application Methods; and
► Work Practice Standards.
8.1.2 Paint Booth VOCs, Step 2 - Eliminate Technically Infeasible Control
Technologies
Thermal Oxidizer
In a simple TO, the emission stream is heated in the presence of sufficient oxygen to oxidize the VOCs
present. A typical afterburner is a flare and is not equipped with any heat recovery device. Control
efficiencies range from 70 to 99.99%32. This technology is considered technically feasible.
Regenerative Thermal Oxidizer
An RTO is equipped with ceramic heat recovery media (stoneware) that has a large surface area for heat
transfer and can be stable up to 2,300°F. Operating temperatures of the RTO system typically range from
1,400°F to 1,500°F with a retention time of approximately one (1) second. The combustion chamber of the
RTO is surrounded by multiple integral heat recovery chambers, each of which sequentially switches back
and forth from being a pre-heater to a heat recovery chamber. In this fashion, energy is absorbed from the

31 Database accessed December 19, 2023.
32 EPA Air Pollution Control Technology Fact Sheet, Thermal Incinerator, EPA-452/F-03-022
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gas exhausted from the unit and stored in the heat exchange media to preheat the next cycle of incoming
gas. Control efficiencies range from 95-99%33. This technology is considered technically feasible.
Carbon Adsorption
Carbon adsorption uses a filter bank of canisters or filters that contain activated carbon, which adsorbs the
VOC emissions as they pass through before being released to the atmosphere. Carbon adsorption units work
best with lower-temperature operations. At the Salt Lake Facility, the properties of the paint booth’s exhaust
stream would cause equipment and ductwork to plug due to the adhesive nature of paint, thus causing
frequent process interruptions. Furthermore, the paints mixed in the paint sprayer react to form a hard
coating on the surface of the pole; this would occur on the surface of carbon adsorption units, quickly
rendering them inefficient. Therefore, carbon adsorption is considered technically infeasible.

It is for these same reasons that a Regenerative Thermal Oxidizer with Concentrator (RCO) has not been
included in detail. The concentrator is an adsorption unit that shares the same technical infeasibilities as the
Carbon Adsorption given above.
Reduced VOC Content
Many air quality agencies have established VOC concentration or material vapor pressure limitations which
reduce the potential for VOC emissions from a facility. Often, these limits are established via process-specific
rules and limits given within the rule and are further specified to the exact type of application.34 Easton is
subject to Utah Administrative Rule 307-350 Miscellaneous Parts and Product Coatings which contains a
table which establishes VOC content and vapor pressure limits for a variety of chemical use cases. The use
of chemicals with a reduced VOC content is technically feasible.
Application Methods
High-efficiency application methods ensure that VOC-containing substances are applied in ways that
minimize volatilization and usage. Easton is subject to Utah Administrative Rule 307-350 Miscellaneous Parts
and Product Coatings, which requires the use of one (1) of the following application methods:

► Electrostatic application;
► Flow coat;
► Dip/electrodeposition coat;
► Roll coat;
► Hand Application Methods;
► High-volume, low-pressure (HVLP) spray; or
► Another application method capable of achieving 65% or greater transfer efficiency equivalent or better
to HVLP spray, as certified by the manufacturer.

Easton proposes that the use of these application methods is technically feasible.
Work Practice Standards
Work practice standards include company policies and operating procedures that have the potential to limit
VOC emissions. Easton is subject to Utah Administrative Rule 307-350 Miscellaneous Parts and Product
Coatings which requires the use of the following work practices:

33 EPA Air Pollution Control Technology Fact Sheet, Regenerative Incinerator, EPA-452/F-03-021.
34 Utah regulations which limit the content of VOC and/or the vapor pressure of the compounds used include R307-304,335,
342, 344-355.
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► Storing all VOC-containing coatings, thinners, and coating-related waste materials in closed containers;
► Ensuring that mixing and storage containers used for VOC-containing coatings, thinners, and coating-
related waste material are kept closed at all times except when depositing or removing these materials;
► Minimizing spills of VOC-containing coatings, thinners, and coating-related waste materials;
► Conveying VOC-containing coatings, thinners, and coating-related waste materials from one location to
another in closed containers; and
► Minimizing VOC emissions from cleaning of application, storage, mixing, and conveying equipment by
ensuring that equipment cleaning is performed without atomizing the cleaning solvent and all spent
solvent is captured in closed containers.35

Easton proposes that the use of these work practice standards is technically feasible.
8.1.3 Paint Booth VOCs, Step 3 - Rank Remaining Control Technologies by Control
Effectiveness
The feasible control technologies presented above have been ranked based on control efficiencies
documented as being achieved in practice, below.
1. Oxidation (RTO, TO) = 90-99% control
2. HVLP or Equivalent, Low VOC, and Best Management Practices = variable control
8.1.4 Paint Booth VOCs, Step 4 – Evaluate Most Effective Controls and Document
Results
Easton conducted a cost analysis for the implementation of RTO. For this analysis Easton has used a
reduction rate of 90 percent for RTO.36 This resulted in $694,017/ton of VOCs removed. The cost per ton of
VOCs removed is beyond acceptable cost control effectiveness levels and therefore Easton considers this
technology economically infeasible for these units.
8.1.5 Paint Booth VOCs, Step 5 – Select RACT
Easton uses all technically and economically feasible controls which includes reduced-VOC content,
appropriate application methods, and work practice standards, as described in R307-350 Miscellaneous Parts
and Product Coatings. Easton proposes that its paint booth meets RACT.

35 This list has been abbreviated to reflect the work practice standards implemented at the Salt Lake Facility.
36 Estimated removal efficiency, Assumed maximum efficiency given in EPA Cost Control Manual Section 3 Chapter 2
Incinerators and Oxidizers
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9. PULTRUSION
9.1 Pultrusion VOCs RACT
Easton operates multiple pultrusion lines at its Salt Lake Facility. The pultrusion lines use open baths of
VOC-containing materials and electric heating elements to create carbon fiber tubes that are then processed
for a variety of uses. VOC emissions result from the adhesive used to keep carbon fiber spools wrapped
together and from the open baths of coatings applied to the carbon fiber prior to its being shaped into a
tube.
9.1.1 Pultrusion VOCs, Step 1 - Identify All Reasonably Available Control
Technologies
In order to identify control technologies applied to carbon fiber coating operations, the following sources
were reviewed:

► EPA’s RBLC Database;37
 41.014 – Paper, Plastic & Foil Web Surface Coating (except 41.007 & 41.018);
 41.016 – Plastic Parts & Products Surface Coating (except 41.015);
 41.017 – Polymeric Coating of Fabrics;
 41.999 – Other Surface Coating/Printing/Graphic Arts Sources; and
 49.999 – Other Organic Evaporative Loss Sources.
► EPA’s Air Pollution Technology Fact Sheets;
► BAAQMD BACT Library;
► SCAQMD BACT Library;
► SJVAPCD BACT Library; and
► TCEQ’s BACT Library.

Available control technologies for pultrusion were observed from the search of the RBLC and the California
regulatory districts; they include the following:

► Oxidizers;
► Carbon Adsorption; and
► Good Work Practices38.
9.1.2 Pultrusion VOCs, Step 2 – Eliminate Technically Infeasible Control
Technologies
Oxidizers
Oxidizers come in a variety of forms, including TOs, RTOs, and CatOxes. All destroy VOCs by raising the
temperature of the VOC-containing material above its auto-ignition point in the presence of oxygen and
maintaining it at high temperatures for sufficient time to complete combustion. Ideally, this results in the
creation of carbon dioxide and water; however, due to the low concentration of VOCs being emitted from
the pultrusion process, each of these technologies would require a supplemental combustion source, such

37 Database accessed December 18, 2023.
38 Scrubbers, condensors, and the use of alternative materials were not observed in the search of the RBLC or the California
regulatory districts.
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as natural gas. This would result in the production of all criteria pollutants, i.e., VOCs, NOX, CO, PM10, PM2.5,
and SO2.

Oxidizers are best used for consistent applications with moderate to high VOC loadings. This is not
representative of the variable operation of the open baths of the pultrusion lines. The pultrusion lines are
operational for up to two (2) shifts per day, i.e., they are non-operational during one (1) to two (2) shifts
per day, or up to 16 hours per day. An oxidizer would either have to run at all times, resulting in the
combustion of large amounts of supplemental fuel gas, or they would have to undergo daily startups and
shutdowns. Daily startups and shutdowns would result in an inordinate amount of emissions and
maintenance. EPA’s Fact Sheet for RTOs states that oxidizers are appropriate for waste streams that are
consistent over long periods of time.39

Oxidizers also require a large footprint to be housed in, which the Salt Lake Facility does not have available.

For these reasons, this control technology is technically infeasible for the Salt Lake Facility.
Carbon Adsorption
Carbon adsorption utilizes a column or filter of activated carbon to adsorb targeted pollutants as pollutant-
laden gas flows through it. In adsorption (as opposed to absorption, e.g., a wet scrubber) the pollutant
molecules are attracted to the carbon by a physical, rather than a chemical, process. The result is a weaker
bond that can be reversed with heat or pressure. Carbon adsorption is typically used in applications where
the recovery and reuse of the volatile components of the gas stream is cost efficient.

Carbon adsorption generally works well for high-velocity streams with low VOC concentrations (500-2,000
ppm).40,41 A well-designed adsorber system can achieve 95-98% control efficiency under these parameters,
although the control rate is approximately linearly correlated with the material’s vapor pressure. Carbon
adsorbers are technically feasible and are evaluated further in Step 4.
Good Working Practices
Good working practices include following the guidance described in Part 60 of Title 40 of the Code of
Federal Regulations (40 CFR 60), Subpart VVV, Standards of Performance for Polymeric Coating of
Supporting Substrates Facilities. At the rate of VOC emissions from pultrusion at the Salt Lake Facility,
Subpart VVV requires the monitoring of VOC usage. Other good working practices include minimizing use of
VOC-containing materials, keeping those materials in closed containers when not in use, cleaning the
materials when spilled, etc. Performing good working practices is technically feasible.
9.1.3 Pultrusion VOCs, Step 3 – Rank Remaining Control Technologies by Control
Effectiveness
Technically feasible control technologies are ranked based on their control efficiencies:

1. Carbon Adsorption = 95-98% control
2. Good working practices = variable control

39 EPA Air Pollution Control Technology Fact Sheet, Regenerative Incinerator, EPA-452/F-03-021.
40 TCEQ Technical Guidance Package for Chemical Sources: Carbon Adsorption Systems.
41 EPA’s Air Pollution Control Technology Fact Sheet (EPA-452/F-03-019) specifies in a permit review case: if the heat content
of the emission stream is less than 300 Btu/scf, and no supplementary fuel has been added, then the application is
considered unacceptable.
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9.1.4 Pultrusion VOCs, Step 4 – Evaluate Most Effective Controls and Document
Results
Carbon Adsorption
Easton conducted an economic feasibility analysis for a carbon adsorption system, found in Appendix A,
which follows the method described in EPA Cost Control Manual Chapter 2, Concepts and Methodology. For
this analysis, Easton has used a reduction rate of 96.5% (the average of 95-98%), as described previously.

Using a manufacture-supplied total equipment cost and 7% interest rate, it would cost $19,368/ton of VOCs
removed to install a carbon adsorption unit on the Pultrusion process. The cost per ton of VOCs removed is
considered economically infeasible. This estimate is very conservative, because there are 34 pultrusion lines
at the Salt Lake Facility and the filtration cost estimate accounts for only two (2) canister carbon adsorption
units. Engineering was not completed for this RACT analysis, but Easton anticipates that multiple carbon
units will be required and thereby increasing the cost/ton linearly.
Good Working Practices
No infeasibilities related to environment, energy, or economics were identified for the use of good working
practices.
9.1.5 Pultrusion VOCs, Step 5 – Select RACT
Due to the evolving nature of Easton’s business climate, evaluations of site-specific controls and their costs
are still being made for the Salt Lake Facility. This could result in future changes to the results of this
section of the RACT analysis. RACT for VOCs resulting from the pultrusion lines is the implementation of
good working practices.
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10. DEGREASING
10.1 Degreasing VOCs RACT
Easton operates three (3) degreasing dip tanks at its Salt Lake Facility. The dip tanks are used to remove
excess extrusion oil from aluminum shafts following the extrusion process. The three (3) dip tanks are
arranged in series, such that one (1) shaft is dipped in each of the three (3) dip tanks, becoming cleaner
after each dip tank, until a clean shaft is ready for further processing. This is a batch process, with several
batches occurring in a single day. Mineral spirits are used in the dip tanks and are the source of the VOCs
from this process.
10.1.1 Degreasing VOCs, Step 1 – Identify All Reasonably Available Control
Technologies
In order to identify control technologies applied to degreasing operations, the following sources were
reviewed:

► EPA’s RBLC Database;42
 41.999 – Other Surface Coating/Printing/Graphic Arts Sources; and
 49.008 – Organic Solvent Cleaning & Degreasing (except 49.006).
► EPA’s Air Pollution Technology Fact Sheets;
► BAAQMD BACT Library;
► SCAQMD BACT Library;
► SJVAPCD BACT Library;
► TCEQ’s BACT Library; and
► UAC R307-355 Degreasing.

Available control technologies for degreasing operations include the following:
► Oxidizers;
► Carbon Adsorption;
► Wet Scrubber;
► Good Work Practices; and
► Alternative Materials43.
10.1.2 Degreasing VOCs, Step 2 – Eliminate Technically Infeasible Control
Technologies
Currently, no collection of the VOCs from this process is being conducted. In order to utilize an add-on
control device, Easton would be required to install a vent above the dip tanks as well as a fan and duct work
to capture the VOC for further control. Easton has determined that the installation of a collection system is
technically feasible. Thus, additional add-on control devices are evaluated for technical feasibility.
Oxidizers
Oxidizers come in a variety of forms, including TOs, RTOs, and catalytic oxidizers (CatOxes). All destroy
VOCs by raising the temperature of the VOC-containing material above its auto-ignition point in the

42 Database accessed December 15, 2023.
43 Condensors were not observed to be used for degreasing dip tanks in the search of the RBLC or the California regulatory
agencies.
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presence of oxygen and maintaining it at high temperatures for sufficient time to complete combustion.
Ideally, this results in the creation of carbon dioxide and water; however, due to the low concentration of
VOCs being emitted from the degreasing dip tanks, each of these technologies would require a
supplemental combustion source, such as natural gas. This would result in the production of all criteria
pollutants, i.e., VOCs, NOX, CO, PM10, PM2.5, and SO2.

Oxidizers are able to handle minor fluctuations in the flow of combustible material, meaning that larger
fluctuations require larger quantities of supplemental fuel. Oxidizers are best used for applications with
moderate to high VOC loadings.44 This is not representative of degreasing dip tanks. Oxidizers also require a
large footprint to be housed in, which the Salt Lake Facility does not have available.

For all of these reasons, this control technology is technically infeasible for the Salt Lake Facility.
Carbon Adsorption
Carbon adsorption utilizes a column or filter of activated carbon to adsorb targeted pollutants as pollution-
laden gas flows through them. In adsorption (as opposed to absorption, e.g., a wet scrubber) the pollutant
molecules are attracted to the carbon by a physical, rather than a chemical, process. The result is a weaker
bond that can be reversed with heat or pressure. Carbon adsorption is typically used in applications where
the recovery and reuse of the volatile components of the gas stream is cost efficient.

Carbon adsorption generally works well for high-velocity streams with low VOC concentrations (500-2,000
ppm).45,46 A well-designed adsorber system can achieve 95-98% control efficiency under these parameters,
although the control rate is approximately linearly correlated with the material’s vapor pressure.

Carbon adsorbers are technically feasible and are evaluated further in Step 4.
Scrubbers
Scrubbers utilize absorption to control VOCs (as opposed to adsorption, e.g., carbon adsorbers). Absorption
is a commonly applied operation in chemical processing as a raw material or product recovery technique in
the separation and purification of gaseous streams containing high concentrations of organics. In
absorption, the organics in the gas stream are dissolved in a liquid. The contact between the absorbing
liquid and the gas stream is accomplished in counter-current spray towers, scrubbers, or packed or plate
columns. The resulting material from the absorption cycle must be treated or disposed of once the solution
reaches its saturation point. The scrubbing liquid with the contaminant is typically regenerated in a stripping
column in conditions of elevated temperature or reduced pressure (vacuum conditions). The contaminant is
then recovered using a condenser.

Mineral spirits are not water soluble; therefore, many common types of scrubbers are technically
infeasible.47 Of the EPA’s nine (9) different types of scrubbers described in its scrubbing fact sheets, only
one (1) is described as being able to realistically control VOCs resulting from mineral spirits; a mechanically
aided scrubber.48 This is due to its ability to use amphiphilic bock copolymers for hydrophobic VOCs.

44 EPA’s Air Pollution Control Technology Fact Sheet for Thermal Oxidizers (EPA-452/F-03-022)
45 TCEQ Technical Guidance Package for Chemical Sources: Carbon Adsorption Systems.
46 EPA’s Air Pollution Control Technology Fact Sheet (EPA-452/F-03-019) specifies in a permit review case: if the heat content
of the emission stream is less than 300 Btu/scf, and no supplementary fuel has been added, then the application is
considered unacceptable.
47 Mineral Spirits Safety Data Sheet, Cameo Chemicals, https://cameochemicals.noaa.gov/chris/MNS.pdf
48 Air Pollution Control Technology Fact Sheet: Mechanically-Aided Scrubber, U.S. EPA, EPA-452/F-03-013.
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However, the fact sheet for this scrubber type goes on to explain that the application of mechanically aided
scrubbers is “limited due to high maintenance requirements” and is only capable of high collection
efficiencies “with commensurate high energy consumption.”49 Scrubbers were not observed to be used to
control degreasing operations in dip tanks in the RBLC search. This, in conjunction with the difficulties
presented by the EPA fact sheets, leads to their technical infeasibility in the control of these degreasing
operations.
Good Working Practices
Good working practices include following the guidance described in UAC R307-355 Degreasing. Listed
practices include installing a cover and keeping it closed when the dip tanks are not in use; use of an
internal draining rack for certain solvents; storage of waste or used solvent in covered containers;
maintaining equipment in good operating condition; posting written procedures of operation and
maintenance; and maintaining sufficient freeboard for certain solvents. This is technically feasible.
Alternative Materials
Mineral spirits are used to remove extruding oils from aluminum shafts after they have been extruded and
prior to the shafts’ further finishing. The extruding oil is not soluble in water, thus requiring the use of
another hydrophobic chemical, such as mineral spirits. Recently, Easton has been working with industrial
professionals to identify materials that could feasibly be used in place of the existing materials. On-site
research is still being conducted by Easton personnel. Since no alternative has currently been identified, the
use of alternative materials has not been deemed technically feasible at this time.
10.1.3 Degreasing VOCs, Step 3 - Rank Remaining Control Technologies by Control
Effectiveness
Technically feasible control technologies are ranked based on their control efficiencies:

1. Carbon Adsorption = 95-98% control
2. Good working practices = variable control
10.1.4 Degreasing VOCs, Step 4 – Evaluate Most Effective Controls and Document
Results
Carbon Adsorption
Easton conducted an economic feasibility analysis for an activated carbon filter system, found in Appendix A,
which follows the method described in EPA Cost Control Manual Chapter 2, Concepts and Methodology. For
this analysis, Easton has used a reduction rate of 96.5% (the average of 95-98%), as described previously.

Using a manufacture supplied total equipment cost and 7% interest rate, it would cost less than
$10,000/ton of VOCs removed to install an activated carbon filtration unit. The cost per ton of VOCs
removed is considered economically feasible for the degreasing dip tanks.
Good Working Practices
No infeasibilities related to environment, energy, or economics were identified for the use of good working
practices.

49 Air Pollution Control Technology Fact Sheet: Mechanically-Aided Scrubber, U.S. EPA, EPA-452/F-03-013.
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10.1.5 Degreasing VOCs, Step 5 – Select RACT
Due to the evolving nature of Easton’s business climate, evaluations of site-specific controls and their costs
are still being made for the Salt Lake Facility. This could result in future changes to the results of this
section of the RACT analysis. RACT for VOCs resulting from the degreasing dip tanks for a carbon
adsorption system is less than $10,000.

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11. SMALL FUGITIVES
11.1 Small Fugitives VOCs RACT
Fugitive VOC emissions result from the use of a variety of coatings, cleaners, paints, and maintenance
products used throughout the Salt Lake Facility in small quantities.
11.1.1 Small Fugitives VOCs, Step 1 – Identify All Control Technologies
Easton has reviewed the following sources to identify available control technologies:
► EPA’s RBLC Database;
► EPA’s Air Pollution Technology Fact Sheets;
► California Air Resource Board, BACT Guidelines Tool; and
► Utah Administrative Rule 307-350 Miscellaneous Parts and Product Coatings.

The following control methods were generally listed for the control of fugitive VOC sources:

► Capture and Control;
► Reduced VOC Content;
► Application Method; and
► Work Practice Standards.
11.1.2 Small Fugitives VOCs, Step 2 – Eliminate Technically Infeasible Control
Technologies
Capture and Control
In order to implement a standalone control device, emissions must first be captured and routed to a central
location. The standard capture methods for product manufacturing can be broadly described as pick-up
vents and enclosures.

Pick-up vents generally consist of an exhaust system strategically placed over the VOC-emitting process. For
example, a hood located over a process tank, or a pick-up point located next to a printer. These pick-up
vents generally have a high capture efficiency because the emission flow rate at that location is constant.
The materials used at Easton are applied as needed to individual components and thus, a pick-up vent is
not technically feasible.

An enclosure entails confining the emissions with physical boundaries. Enclosures generally operate under
slightly negative pressure, thus evacuating the VOCs from the area with exhaust air. Enclosures come in
many forms but are generally effective when the VOC emissions are generated within a relatively small
space. Manufacturing examples include ovens, spray booths, or other specific pieces of equipment. Given
that fugitive VOC emissions result from several production areas and at inconsistent intervals across the Salt
Lake Facility, an enclosure is technically infeasible.
Reduced VOC Content
Many air quality agencies have established VOC concentration or material vapor pressure limitations which
reduce the potential for VOC emissions from a facility. Often, these limits are established via process-specific
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rules and limits given within the rule and are further specified to the exact type of application.50 Easton is
subject to Utah Administrative Rule 307-350 Miscellaneous Parts and Product Coatings which contains a
table which establishes VOC content and vapor pressure limits for a variety of chemical use cases. The use
of chemicals with a reduced VOC content is technically feasible.
Application Methods
High-efficiency application methods ensure that VOC-containing substances are applied in ways that
minimize volatilization and usage. Easton is subject to Utah Administrative Rule 307-350 Miscellaneous Parts
and Product Coatings, which requires the use of one (1) of the following application methods:

► Electrostatic application;
► Flow coat;
► Dip/electrodeposition coat;
► Roll coat;
► Hand Application Methods;
► High-volume, low-pressure (HVLP) spray; or
► Another application method capable of achieving 65% or greater transfer efficiency equivalent or better
to HVLP spray, as certified by the manufacturer.

Easton proposes that the use of these application methods is technically feasible.
Work Practice Standards
Work practice standards include company policies and operating procedures that have the potential to limit
VOC emissions. Easton is subject to Utah Administrative Rule 307-350 Miscellaneous Parts and Product
Coatings which requires the use of the following work practices:

► Storing all VOC-containing coatings, thinners, and coating-related waste materials in closed containers;
► Ensuring that mixing and storage containers used for VOC-containing coatings, thinners, and coating-
related waste material are kept closed at all times except when depositing or removing these materials;
► Minimizing spills of VOC-containing coatings, thinners, and coating-related waste materials;
► Conveying VOC-containing coatings, thinners, and coating-related waste materials from one location to
another in closed containers; and
► Minimizing VOC emissions from cleaning of application, storage, mixing, and conveying equipment by
ensuring that equipment cleaning is performed without atomizing the cleaning solvent and all spent
solvent is captured in closed containers.51

Easton proposes that the use of these work practice standards is technically feasible.
11.1.3 Small Fugitives VOCs, Steps 3-5 – Select RACT
Easton utilizes all technically feasible control methods including reduced VOC content, appropriate
application methods, and good work practice standards. Easton proposes that the use of all technically
feasible controls meets RACT.

50 Utah regulations which limit the content of VOC and/or the vapor pressure of the compounds used include R307-304,335,
342, 344-355.
51 This list has been abbreviated to reflect the work practice standards implemented at the Salt Lake Facility.
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12. CONCLUSIONS
The tables below provide a summary of the controls considered and the technical/economic feasibility conclusions. All technologies are considered
in Step 1. As technologies are eliminated in Steps 2, 3, and 4, they are shown crossed out in strikethrough in the step in which it is eliminated.
Once eliminated, the technology is no longer considered in further steps. Technology that is not eliminated in Steps 1-5 has been selected as
RACT. See Table 12-1, below.

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Table 12-1. RACT Summary Table, Sections 4 Through 11
RACT
Step
Boilers
(Section 4)
Oven
(Section 5)
Other Small Natural Gas
Burners
(Section 6)
Natural Gas-
Fired
Emergency
Generators
(Section 7)
Paint Booth
(Section 8)
Pultrusion
(Section 9)
Degreasing
(Section 10)
Small
Fugitives
(Section 11)
NOX VOCs NOX VOCs NOX VOCs NOX & VOCs VOCs VOCs VOCs VOCs
Step
1
- LNB
- ULNB
- FGR
- SCR
- Good
Combustion
Practices
- Oxidizers
- Good
Combustion
Practices
- LNB
- Good
Combustion
Practices
- Oxidizers
- Good
Combustion
Practices
- LNB
- Good
Combustion
Practices
- Oxidizers
- Good
Combustion
Practices
- Limited
Hours of
Operation
- Routine
Maintenance
- Good
Combustion
Practices
- Use of
Natural Gas
- Lean Burn
Technology
- SCR
- NSCR
- Oxidizers
(TO, RTO)
- Carbon
Adsorption
- Low-VOC
coatings
- HLVP
Coating Gun
or Equivalent
- Best
Management
Practices
- Oxidizers
- Carbon
Adsorption
- Good
Work
Practices
- Oxidizers
- Carbon
Adsorption
- Wet
Scrubber
- Good
Work
Practices
- Alternative
Materials
- Capture
and Control
- Reduced
VOC Content
- Application
Methods
- Work
Practice
Standards
Step
2
- LNB
- ULNB
- FGR
- SCR
- Good
Combustion
Practices
- Oxidizers
- Good
Combustion
Practices
- LNB
- Good
Combustion
Practices
- Oxidizers
- Good
Combustion
Practices
- LNB
- Good
Combustion
Practices
- Oxidizers
- Good
Combustion
Practices
- Limited
Hours of
Operation
- Routine
Maintenance
- Good
Combustion
Practices
- Use of
Natural Gas
- Lean Burn
Technology
- SCR
- NSCR
- Oxidizers
(TO, RTO)
- Carbon
Adsorption
- Low-VOC
Coatings
- HLVP
Coating Gun
or Equivalent
- Best
Management
Practices
- Oxidizers
- Carbon
Adsorption
- Good
Work
Practices
- Oxidizers
- Carbon
Adsorption
- Wet
Scrubber
- Good
Work
Practices
- Alternative
Materials
- Capture
and Control
- Reduced
VOC Content
- Application
Methods
- Work
Practice
Standards

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RACT
Step
Boilers
(Section 4)
Oven
(Section 5)
Other Small Natural Gas
Burners
(Section 6)
Natural Gas-
Fired
Emergency
Generators
(Section 7)
Paint Booth
(Section 8)
Pultrusion
(Section 9)
Degreasing
(Section 10)
Small
Fugitives
(Section 11)
NOX VOCs NOX VOCs NOX VOCs NOX & VOCs VOCs VOCs VOCs VOCs
Step
3
- LNB
- ULNB
- Good
Combustion
Practices
- Good
Combustion
Practices
- LNB
- Good
Combustion
Practices
- Good
Combustion
Practices
- LNB
- Good
Combustion
Practices
- Good
Combustion
Practices
- Limited
Hours of
Operation
- Routine
Maintenance
- Good
Combustion
Practices
- Use of
Natural Gas
- Lean Burn
Technology
- Oxidizers
(TO, RTO)
- Low-VOC
Coatings
- HLVP
Coating Gun
or Equivalent
- Best
Management
Practices
- Carbon
Adsorption
- Good
Work
Practices
- Carbon
Adsorption
Filters
- Good
Work
Practices

- Reduced
VOC Content
- Application
Method
- Work
Practice
Standards
Step
4
- LNB
- ULNB
- Good
Combustion
Practices
- Good
Combustion
Practices
- LNB
- Good
Combustion
Practices
- Good
Combustion
Practices
- LNB
- Good
Combustion
Practices
- Good
Combustion
Practices
- Limited
Hours of
Operation
- Routine
Maintenance
- Good
Combustion
Practices
- Use of
Natural Gas
- Lean Burn
Technology
- Oxidizers
(TO, RTO)
- Low-VOC
coatings
- HLVP
Coating Gun
or Equivalent
- Best
Management
Practices
- Carbon
Adsorption
- Good
Work
Practices
- Carbon
Adsorption
- Good
Work
Practices
- Reduced
VOC Content
- Application
Method
- Work
Practice
Standards

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RACT
Step
Boilers
(Section 4)
Oven
(Section 5)
Other Small Natural Gas
Burners
(Section 6)
Natural Gas-
Fired
Emergency
Generators
(Section 7)
Paint Booth
(Section 8)
Pultrusion
(Section 9)
Degreasing
(Section 10)
Small
Fugitives
(Section 11)
NOX VOCs NOX VOCs NOX VOCs NOX & VOCs VOCs VOCs VOCs VOCs

Step
5
- Good
Combustion
Practices
- Good
Combustion
Practices
- Good
Combustion
Practices
- Good
Combustion
Practices
- Good
Combustion
Practices
- Good
Combustion
Practices
- Limited
Hours of
Operation
- Routine
Maintenance
- Good
Combustion
Practices
- Use of
Natural Gas
- Lean Burn
Technology
- Low-VOC
coatings
- HLVP
Coating Gun
or Equivalent
- Best
Management
Practices
- Good
Work
Practices
- Carbon
Adsorption
- Good
Work
Practices
- Reduced
VOC Content
- Application
Method
- Work
Practice
Standards

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APPENDIX A. DETAILED COST CALCULATIONS
Cost Analysis for Boilers
Table A-1. RACT Control Cost Evaluation for LNB Replacement - General Information
Parameter Value Notes
Heat Input 5.25 MMBTU/hr per unit
Current Emission Rate 0.80 TPY, per unit, Using lb/MMBtu
Reduction Efficiency 50%
Estimated using the EPA's Technical Bulletin, Nitrogen Oxides, Why and How They are
Controlled (EPA 456/F-99-006R).
Estimated Emission Rate 0.40 TPY, per unit, Using lb/MMBtu
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 -- NO X 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
Table A-2. RACT Control Cost Evaluation for LNB Replacement - Capital Investment
Parameter Value Notes
Total Equipment Cost $53,300
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 $56,700
Cost estimate based on communication with Holbrook Servco December 2023, several
sizes and costs were provided and a linear interpolation was applied.
Contingency $11,340
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 -- NO X
Emissions from Industrial/Commercial/Institutional (ICI) Boilers, Section 6.1.1.4
Contingencies.
Freight $2,665
EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and
Methodology, Table 2.4
Sales Tax $1,599
EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and
Methodology, Table 2.4
Instrumentation $5,330
EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and
Methodology, Table 2.4
Total Increase in Capital
Investment ($)$130,934 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) $18,642
EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and
Methodology, Equation 2.8
Process Information
Labor Costs
Economic Factors
Easton Page 1 of 15 Trinity Consultants
Cost Analysis for Boilers
Table A-3. RACT Control Cost Evaluation for 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 $2,427
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 $1,213
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 $1,213
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 $34,345 Sum of Insurance, Tax, and Other Annual Costs
Table A-4. RACT Control Cost Evaluation for LNB Replacement - Annual Operating, Insurance, Tax, and Other Costs
Parameter Value Notes
Total Annual Cost $102,139 Sum of Capital Recovery Cost, Total Direct Operating Costs, Insurance, Tax and Other
Annual Costs.
NOX Removed (tpy)0.40
Cost per Ton of NOX Removed
($/ton)$255,346
1. While this cost analysis sites the EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and Methodology, the cost estimates used for a
retrofit are consistent in Alternative Control Techniques Document -- NOx Emissions from Industrial/Commercial/Institutional (ICI) Boilers, Section 6.1.2
Annual Operations and Maintenance (O&M) Costs
Direct Operating Costs
Insurance, Tax, and Other Annual Costs1
NOX Cost Per Ton Removed
Easton Page 2 of 15 Trinity Consultants
Cost Analysis for Boilers
Table A-5. RACT Control Cost Evaluation for ULNB Replacement - General Information
Parameter Value Notes
Heat Input 5.25 MMBTU/hr per unit
Current Emission Rate 0.80 TPY, per unit, Using lb/MMBtu
Reduction Efficiency 60%
Estimated using the EPA's Technical Bulletin, Nitrogen Oxides, Why and How They are
Controlled (EPA 456/F-99-006R). The LNB+FGR represents approximately the same control
efficiency as the ULNB for ICI Boilers fired on Natural Gas.
Estimated Emission Rate 0.32 TPY, per unit, Using lb/MMBtu
Operator ($/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
Table A-6. RACT Control Cost Evaluation for ULNB Replacement - Capital Investment
Parameter Value Notes
Total Equipment Cost $53,300
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 $56,700
Cost estimate based on communication with Holbrook Servco December 2023, several sizes
and costs were provided and a linear interpolation was applied.
Contingency $11,340
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 $2,665
EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and Methodology,
Table 2.4
Sales Tax $1,599
EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and Methodology,
Table 2.4
Instrumentation $5,330
EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and Methodology,
Table 2.4
Total Increase in Capital
Investment ($)$130,934 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) $18,642
EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and Methodology,
Equation 2.8
Process Information
Labor Costs
Economic Factors
Easton Page 3 of 15 Trinity Consultants
Cost Analysis for Boilers
Table A-7. RACT Control Cost Evaluation for ULNB 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 $2,427
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 $1,213
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 $1,213
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 $34,345 Sum of Insurance, Tax, and Other Annual Costs
Table A-8. RACT Control Cost Evaluation for ULNB Replacement - Annual Operating, Insurance, Tax, and Other Costs
Parameter Value Notes
Total Annual Cost $102,139 Sum of Capital Recovery Cost, Total Direct Operating Costs, Insurance, Tax and Other
Annual Costs.
NOX Removed (tpy)0.48
Cost per Ton of NOX Removed
($/ton)$212,789
1. While this cost analysis sites the EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and Methodology, the cost estimates used for a
retrofit are consistent in Alternative Control Techniques Document -- NOx Emissions from Industrial/Commercial/Institutional (ICI) Boilers, Section 6.1.2 Annual
Operations and Maintenance (O&M) Costs
Direct Operating Costs
Insurance, Tax, and Other Annual Costs1
NOX Cost Per Ton Removed
Easton Page 4 of 15 Trinity Consultants
Cost Analysis for Oven
Table A-9. RACT Control Cost Evaluation for LNB Replacement - General Information
Parameter Value Notes
Heat Input 6.00 MMBTU/hr per unit
Current Emission Rate 0.91 TPY, per unit, Using lb/MMBtu
Reduction Efficiency 50%
Estimated using the EPA's Technical Bulletin, Nitrogen Oxides, Why and How They are
Controlled (EPA456/F-99-006R).
Estimated Emission Rate 0.46 TPY, per unit, Using lb/MMBtu
Operator ($/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 -- NO X 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
Table A-10. RACT Control Cost Evaluation for LNB Replacement - Capital Investment
Parameter Value Notes
Total Equipment Cost $53,800 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 $57,100 Cost estimate based on communication with Holbrook Servco December 2023, several
sizes and costs were provided and a linear interpolation was applied.
Contingency $14,275
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 -- NO X
Emissions from Industrial/Commercial/Institutional (ICI) Boilers, Section 6.1.1.4
Contingencies.
Freight $2,690
EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and
Methodology, Table 2.4
Sales Tax $1,614 EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and
Methodology, Table 2.4
Instrumentation $5,380 EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and
Methodology, Table 2.4
Total Increase in Capital
Investment ($)$134,859 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) $19,201
EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and
Methodology, Equation 2.8
Process Information
Labor Costs
Economic Factors
Easton Page 5 of 15 Trinity Consultants
Cost Analysis for Oven
Table A-11. RACT Control Cost Evaluation for 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 $2,504 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 $1,252 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 $1,252 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 $34,498 Sum of Insurance, Tax, and Other Annual Costs
Table A-12. RACT Control Cost Evaluation for LNB Replacement - Annual Operating, Insurance, Tax, and Other Costs
Parameter Value Notes
Total Annual Cost $102,851 Sum of Capital Recovery Cost, Total Direct Operating Costs, Insurance, Tax and Other
Annual Costs.
NOX Removed (tpy)0.46
Cost per Ton of NOX Removed
($/ton)$226,046
1. While this cost analysis sites the EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and Methodology, the cost estimates used for a
retrofit are consistent in Alternative Control Techniques Document -- NOx Emissions from Industrial/Commercial/Institutional (ICI) Boilers, Section 6.1.2 Annual
Operations and Maintenance (O&M) Costs
Direct Operating Costs
Insurance, Tax, and Other Annual Costs1
NOX Cost Per Ton Removed
Easton Page 6 of 15 Trinity Consultants
Cost Analysis for Other Small Natural Gas Burners
Table A-13. RACT Control Cost Evaluation for LNB Replacement - General Information
Parameter Value Notes
Heat Input 2.45 MMBTU/hr per unit
Current Emission Rate 0.37 TPY, per unit, Using lb/MMBtu
Reduction Efficiency 50%
Estimated using the EPA's Technical Bulletin, Nitrogen Oxides, Why and How They are
Controlled (EPA 456/F-99-006R).
Estimated Emission Rate 0.19 TPY, per unit, Using lb/MMBtu
Operator ($/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 -- NO X 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
Table A-14. RACT Control Cost Evaluation for LNB Replacement - Capital Investment
Parameter Value Notes
Total Equipment Cost $51,300 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 $54,900 Cost estimate based on communication with Holbrook Servco December 2023, several
sizes and costs were provided and a linear interpolation was applied.
Contingency $10,980
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 -- NO X
Emissions from Industrial/Commercial/Institutional (ICI) Boilers, Section 6.1.1.4
Contingencies.
Freight $2,565
EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and
Methodology, Table 2.4
Sales Tax $1,539 EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and
Methodology, Table 2.4
Instrumentation $5,130 EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and
Methodology, Table 2.4
Total Increase in Capital
Investment ($)$126,414 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) $17,999
EPA Cost Control Manual Section 1, Chapter 2 Cost Estimation: Concepts and
Methodology, Equation 2.8
Process Information
Labor Costs
Economic Factors
Easton Page 7 of 15 Trinity Consultants
Cost Analysis for Other Small Natural Gas Burners
Table A-15. RACT Control Cost Evaluation for 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 $2,344
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 $1,172
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 $1,172
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 $34,178 Sum of Insurance, Tax, and Other Annual Costs
Table A-16. RACT Control Cost Evaluation for LNB Replacement - Annual Operating, Insurance, Tax, and Other Costs
Parameter Value Notes
Total Annual Cost $101,329 Sum of Capital Recovery Cost, Total Direct Operating Costs, Insurance, Tax and Other
Annual Costs.
NOX Removed (tpy)0.19
Cost per Ton of NOX Removed
($/ton)$547,722
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
Easton Page 8 of 15 Trinity Consultants
Cost Analysis for Paint Booth
Table A-17. Vendor Estimated RTO Cost
Flow Rate (scfm)Basic Equipment Costa
50,000 $1,191,950
40,000 $1,018,025
30,000 $944,100
20,000 $709,013
10,000 $580,000
Table A-18. Easton Process Parameters
Process Average
Flow Rate (scfm)a
VOC Emission
Rate (lb/hr)b
Estimated Emission
Rate (tpy)b
Tent/Paint 30,000 0.29 0.13
90%
a The installed cost of an RTO is based on a cost estimate from Catalytic Products in
December 2023.
a The average flow rate shown is the sum of flow rates per Easton 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.
b Estimated removal efficiency assumes maximum efficiency given in EPA Cost Control Manual Section 3 Chapter 2 Incinerators and Oxidizers:
Easton Page 9 of 15 Trinity Consultants
Cost Analysis for Paint Booth
Table A-19. Annualized RTO Cost
Parameter Equationa Tent/Paint
Direct Costs
Purchased equipment costs
Basic Equipment, RTO, BE Interpolated from Table 1 $888,618
Ductworkb $300/linear ft x 450 ft, vendor estimate
for 25,000 acfm not estimated
Instrumentation 0.10 BE $88,862
Sales taxes 0.03 BE $26,659
Freight 0.05 BE $44,431
Purchased Equipment Cost, PEC PEC = 1.18 BE $1,048,569
Direct Installation Costs, DIC 0.3 PEC $314,571
Total Direct Costs, DC PEC + DIC $1,363,139
Indirect Installation Costs
Engineering 0.10 PEC $104,857
Construction & field expenses 0.05 PEC $52,428
Contractor fees 0.10 PEC $104,857
Start-up 0.02 PEC $20,971
Performance test 0.01 PEC $10,486
Contingencies 0.03 PEC $31,457
Total Indirect Costs, IC 0.31 PEC $325,056
TOTAL CAPITAL INVESTMENTc (DC + IC) * 1.25 retrofit factor $2,110,245
Direct Annual Costs
Operating Labor
Operator 2hr/shift* 3 shift/day*360 days/yr *
$23.50/hr $50,760
Supervisor 15% of operator $7,614
Maintenance
Labor 1hr/shift* 3 shift/day*360 days/yr *
$29.00/hr $31,320
Operating Materials
Natural Gasf RTO Natural Gas Consumption
Calculations $578,947
Electricity
Fan Assume no combustion air needed NA
Total Direct Annual Cost Total $668,641
Indirect Annual Costs
Overhead 60% of sum of operating and
maintenance labor $53,816
Administrative charges 2% of TCI $42,205
Property tax 1% of TCI $21,102
Insurance 1% of TCI $21,102
Capital recovery factor 15 Years, 7% Interest 0.11
Capital Recoveryd CRF*TCI $232,127
$370,353
$1,038,995
$902,334
a 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.
b 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.
c 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.d 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.
Total Indirect Annual Costs
TOTAL ANNUAL COST
Cost per Ton Removed
Easton Page 10 of 15 Trinity Consultants
Cost Analysis for Paint Booth
Table A-20. RTO Natural Gas Consumption and Emission Reductions
Process
Tent/Paint
Waste Gas, Qwi, scfm 30,000
VOC (as propane) Emission
Concentration a, volume fraction 1.42E-06
VOC Concentration in Waste Gas,
ppm VOC 1.4 This line shows negligible contribution of VOC to heating value
Process Gas Exhaust Temperature, F 68 Assumed to be ambient temperature
Auxiliary Fuel Requirement, Qaf,
scf/yr 56,983,020 Assumed negligible heat contribution from VOC
Fuel Costc, $/yr $578,947 U.S. Energy Information Administration, Natural Gas Prices. Average year to date value for
September 2023 industrial price of natural gas in Utah ($10.16/1000 ft3).
VOC Process Emissions, tpy 1.28
VOC Emissions from Auxiliary Fuel
Combustion, tpy 0.16 AP-42 Table 1.4-2
VOC Emissions Reduction d, tpy 1.10 Calculated as heater emissions minus emissions from auxiliary fuel combustion.
a
b
Parameter Comments
c It is assumed that oxygen in the exhaust is sufficient for combusting VOC, and an additional air blower, and subsequent electricity cost is not required.
d Emission reduction = Process Emissions x 98% destruction efficiency - VOC emissions from Auxiliary Fuel Combustion. 98% destruction efficiency is provided on page 2-7
of OAQPS Section 3.2 for an incinerator operating at 1600 deg F.
e According to vendor's information, RTO provides 90% CO destruction efficiency or 10 ppmv CO outlet concentration, whichever is less stringent (per McGill AirClean
04/29/05). This calculation is based on 90% control efficiency.
Easton Page 11 of 15 Trinity Consultants
Cost Analysis for Pultrusion
Table A-21. RACT Control Cost Evaluation for Carbon Absorber - General Information
Scenario 1 Notes
Process Information
Uncontrolled Emissions (tpy)13.73
Exhaust Airflow (acfm) 5,000 EPA 456/F-99-004
Capture Efficiency (%)90%Engineering Estimate
Control Efficiency (%)96.5%Average of 95-98%, EPA 456/F-99-004
Electrical Consumption (kWh/year)162,279 Calculated, Based on Exhaust Airflow
Gas Consumption (MMBtu/year)0Engineering Estimate
Water Consumption (Mgal/year)0Engineering Estimate
Utility Costs
Electricity ($/kWh)0.07 Average Utah Prices (Feb 2023)
Natural Gas ($/MMBtu)10.35 Average U.S. Prices (Feb 2023)
Water ($/Mgal)33.45 Sandy, UT (2" Meter, July 2016)
Labor Costs
Operator ($/hour)45.63 Per EPA Air Pollution Control Cost Manual, Chapter 2.
Inflation factor applied.
Supervisor ($/hour)6.85 Per EPA Air Pollution Control Cost Manual, Chapter 2.
Inflation factor applied.
Maintenance ($/hour)46.57 Per EPA Air Pollution Control Cost Manual, Chapter 2.
Inflation factor applied.
Economic Factors
Dollar Inflation (2002 to 2017)1.7092 U.S. Consumer Price Index, 2023
Equipment Life Expectancy (Years)10 EPA 456/F-99-004
Interest Rate (%)7.00%Current Avg SBA Loan Rate
Capital Recovery Factor (CRF)0.1424 Calculated
Key Assumptions
Easton Page 12 of 15 Trinity Consultants
Cost Analysis for Pultrusion
Table A-22. RACT Control Cost Evaluation for Carbon Absorber - Capital Investment
Scenario 1 Notes
Purchased Equipment Costs
Total Equipment Cost1 63,796 A, Vendor Estimate
Instrumentation 6,380 0.10 × A
Sales Tax 3,828 0.06 × A
Freight 3,190 0.05 × A
Total Purchased Equipment Costs 77,193 B = 1.18 × A
Direct Installation Costs 2
Foundations and Supports 6,175 0.08 × B
Handling and Erection 10,807 0.14 × B
Electrical 3,088 0.04 × B
Piping 1,544 0.02 × B
Insulation 772 0.01 × B
Painting 772 0.01 × B
Site Preparation & Buildings -No estimate / Site specific
Total Direct Installation Costs 23,158 C = 0.30 × B
Indirect Installation Costs 2
Engineering 7,719 0.10 × B
Construction and Field Expense 3,860 0.05 × B
Contractor Fees 7,719 0.10 × B
Start-up 1,544 0.02 × B
Performance Test 772 0.01 × B
Process Contingencies 2,316 0.03 × B
Total Indirect Installation Costs 23,930 D = 0.31 × B
Total Capital Investment ($)124,281 TCI = B + C + D
Table A-23. RACT Control Cost Evaluation for Carbon Absorber - Annual Operating, Insurance, Tax, and Other Costs
Scenario 1 Notes 1
Direct Annual Costs 3
Operating Labor (0.5 hr, per 8-hr shift)24,985 E
Supervisory Labor (15% operating labor)3,748 F = 0.15 × E
Maintenance Labor (0.5 hr, per 8-hr shift)25,500 G
Maintenance Materials 25,500 H = G
Electricity 11,360 I
Natural Gas 0 J
Water 0 K
Replacement Filters 69,360 RF, Engineering Estimate
Total Direct Annual Costs 160,452 DAC = E + F + G + H + I + J + K + RF
Indirect Annual Costs 3
Overhead 47,839 M = 0.60 × (E + F + G + H)
Administrative Charges 2,486 N = 0.02 × TCI
Property Tax 1,243 O = 0.01 × TCI
Insurance 1,243 P = 0.01 × TCI
Capital Recovery4 17,695 Q
Total Indirect Annual Costs 70,506 IDAC = K + L + M + N + O + P + Q
Total Annual Cost ($)230,957 TAC = DAC + IDAC
Pollutant Removed (tpy)11.92 Calculated
Cost per ton of Pollutant Removed ($)19,368 $/ton = TAC / Pollutant Removed
4.Capital Recovery factor calculated based on Equation 2.8a (Section 1, Chapter 2, page 2-21) and Table 1.13 (Section 2, Chapter 1, page 1-52) of U.S. EPA
OAQPS, EPA Air Pollution Control Cost Manual (6th Edition), January 2002.
Capital Cost
Operating Cost
1.U.S. EPA OAQPS, EPA Air Pollution Control Cost Manual (6th Edition), January 2002, Section 3.2, Chapter 2, Equation 2.33
2.U.S. EPA OAQPS, EPA Air Pollution Control Cost Manual (6th Edition), January 2002, Section 3.2, Chapter 2, Table 2.8
3.U.S. EPA OAQPS, EPA Air Pollution Control Cost Manual (6th Edition), January 2002, Section 3.2, Chapter 2, Table 2.10
Easton Page 13 of 15 Trinity Consultants
Cost Analysis for Degreasing
Table A-24. RACT Control Cost Evaluation for Carbon Absorber - General Information
Scenario 1 Notes
Process Information
Uncontrolled Emissions (tpy)32.27
Exhaust Airflow (acfm) 5,000 EPA 456/F-99-004
Capture Efficiency (%)99%Engineering Estimate
Control Efficiency (%)96.5%Average of 95-98%, EPA 456/F-99-004
Electrical Consumption (kWh/year)162,279 Calculated, Based on Exhaust Airflow
Gas Consumption (MMBtu/year)0Engineering Estimate
Water Consumption (Mgal/year)0Engineering Estimate
Utility Costs 0.07
Electricity ($/kWh)Average Utah Prices (Feb 2023)
Natural Gas ($/MMBtu)10.35 Average U.S. Prices (Feb 2023)
Water ($/Mgal)33.45 Sandy, UT (2" Meter, July 2016)
Labor Costs
Operator ($/hour)45.63 Per EPA Air Pollution Control Cost Manual, Chapter 2.
Inflation factor applied.
Supervisor ($/hour)6.85 Per EPA Air Pollution Control Cost Manual, Chapter 2.
Inflation factor applied.
Maintenance ($/hour)46.57 Per EPA Air Pollution Control Cost Manual, Chapter 2.
Inflation factor applied.
Economic Factors
Dollar Inflation (2002 to 2017)1.7092 U.S. Consumer Price Index, 2023
Equipment Life Expectancy (Years)10 EPA 456/F-99-004
Interest Rate (%)7.00%Current Avg SBA Loan Rate
Capital Recovery Factor (CRF)0.1424 Calculated
Key Assumptions
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Cost Analysis for Degreasing
Table A-25. RACT Control Cost Evaluation for Carbon Absorber - Capital Investment
Scenario 1 Notes
Purchased Equipment Costs
Total Equipment Cost1 63,796 A, Vendor Estimate
Instrumentation 6,380 0.10 × A
Sales Tax 3,828 0.06 × A
Freight 3,190 0.05 × A
Total Purchased Equipment Costs 77,193 B = 1.18 × A
Direct Installation Costs 2
Foundations and Supports 6,175 0.08 × B
Handling and Erection 10,807 0.14 × B
Electrical 3,088 0.04 × B
Piping 1,544 0.02 × B
Insulation 772 0.01 × B
Painting 772 0.01 × B
Site Preparation & Buildings -No estimate / Site specific
Additional duct work -No estimate / Site specific
Total Direct Installation Costs 23,158 C = 0.30 × B
Indirect Installation Costs 2
Engineering 7,719 0.10 × B
Construction and Field Expense 3,860 0.05 × B
Contractor Fees 7,719 0.10 × B
Start-up 1,544 0.02 × B
Performance Test 772 0.01 × B
Process Contingencies 2,316 0.03 × B
Total Indirect Installation Costs 23,930 D = 0.31 × B
Total Capital Investment ($)124,281 TCI = B + C + D
Table A-26. RACT Control Cost Evaluation for Carbon Absorber - Annual Operating, Insurance, Tax, and Other Costs
Scenario 1 Notes 1
Direct Annual Costs 3
Operating Labor (0.5 hr, per 8-hr shift)24,985 E
Supervisory Labor (15% operating labor)3,748 F = 0.15 × E
Maintenance Labor (0.5 hr, per 8-hr shift)25,500 G
Maintenance Materials 25,500 H = G
Electricity 11,360 I
Natural Gas 0 J
Water 0 K
Replacement Filters 69,360 RF, Engineering Estimate
Total Direct Annual Costs 160,452 DAC = E + F + G + H + I + J + K + RF
Indirect Annual Costs 3
Overhead 47,839 M = 0.60 × (E + F + G + H)
Administrative Charges 2,486 N = 0.02 × TCI
Property Tax 1,243 O = 0.01 × TCI
Insurance 1,243 P = 0.01 × TCI
Capital Recovery4 17,695 Q
Total Indirect Annual Costs 70,506 IDAC = K + L + M + N + O + P + Q
Total Annual Cost ($)230,957 TAC = DAC + IDAC
Pollutant Removed (tpy)30.83 Calculated
Cost per ton of Pollutant Removed ($)7,492 $/ton = TAC / Pollutant Removed
4.Capital Recovery factor calculated based on Equation 2.8a (Section 1, Chapter 2, page 2-21) and Table 1.13 (Section 2, Chapter 1, page 1-52) of U.S. EPA
OAQPS, EPA Air Pollution Control Cost Manual (6th Edition), January 2002.
Capital Cost
Operating Cost
1.U.S. EPA OAQPS, EPA Air Pollution Control Cost Manual (6th Edition), January 2002, Section 3.2, Chapter 2, Equation 2.33
2.U.S. EPA OAQPS, EPA Air Pollution Control Cost Manual (6th Edition), January 2002, Section 3.2, Chapter 2, Table 2.8
3.U.S. EPA OAQPS, EPA Air Pollution Control Cost Manual (6th Edition), January 2002, Section 3.2, Chapter 2, Table 2.10
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