New Source Review for Stationary Sources of Air Pollution (2006) / Chapter Skim
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3 Emission Sources Subject to New Source Review and Technology Options
3 Emission Sources Subject to New Source Review and Technology Options
Pages 57-109
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From page 57... ...
The answers to those questions provide insight into the emissions, energy use, and other implications of technological choices regarding preventive measures, repairs, and replacements. In this chapter, we use language that implies the colloquial meanings, as opposed to the "legal" terminology of maintenance and modification as these terms are used in NSR permitting.
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From page 58... ...
Therefore, cost implications of alternatives for repair and replacement are summarized. OVERVIEW OF NEW SOURCE REVIEW PERMITS The purpose of this section is to identify and evaluate the frequency of NSR permitting activity with respect to industrial categories for the purpose of determining which emission sources represent the highest priority for assessment.
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From page 59... ...
For NOx, the largest share of modification permits -- in both number of permits (46%) and NSR permitted emissions (35%)
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From page 60... ...
. For PM, the highest frequency of NSR permits for modifications was for SIC types 49 (electric, gas, and sanitary services)
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From page 61... ...
The data do not include situations in which NSR permits for major modifications were not issued, such as for facilities that considered but decided against making a modification or facilities that made modifications but did not get an NSR permit for a major modification, whether because of noncompliance or because the source agreed to reduce emissions and obtained a state permit. Despite the limitations of the data, they are among the most comprehensive available.
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From page 62... ...
62 NEW SOURCE REVIEW FOR STATIONARY SOURCES OF AIR POLLUTION TABLE 3-1 NSR Permit Activity Pollutant, 1997-2002, Manufacturing versus Electricity Generationa Manufacturing Sector Number of Permits Permitted Emissions (tpy) Census Emissions State Tot Grn New Mod Grn New Mod Plants Plants tpy Carbon monoxide AL 24 2 12 7 385 6,729 5,353 5,444 386 190,106 WI 13 2 6 5 240 1,831 2,875 9,936 907 56,427 AR 12 1 5 6 3,694 3,054 12,206 3,316 96 93,876 LA 11 0 7 5 - 8,360 3,315 3,545 198 592,306 NC 10 0 4 5 - 14,067 4,470 11,306 886 63,506 FL 9 1 4 2 490 2,894 15,697 15,992 234 48,569 IL 8 0 4 4 - 5,701 515 17,953 1,644 114,147 TX 6 0 4 2 - 1,059 6,422 21,808 466 386,465 OH 5 0 2 5 - 7 5,589 17,974 342 701,527 TN 5 0 2 2 - 2,271 338 7,407 211 91,929 IN 5 1 3 1 135 1,180 272 9,303 341 237,363 Total 148 10 71 59 5,813 72,785 73,750 363,753 12,949 4,351,945 Nitrogen oxides AL 25 3 13 6 287 5,206 2,258 5,444 382 66,693 LA 18 1 11 5 186 3,442 2,504 3,545 214 146,447 FL 16 1 7 5 394 3,428 622 15,992 270 44,255 AR 10 1 3 4 406 86,700 2,936 3,316 102 31,170 IL 10 0 5 4 - 5,875 1,486 17,953 2041 102,435 WI 10 2 6 2 1,842 916 360 9,936 951 43,953 NC 8 1 3 3 767 1,127 4,175 11,306 912 43,718 TX 6 0 4 2 - 2,093 8,329 21,808 470 280,741 PA 6 0 2 1 - 4,889 916 17,128 476 110,514 TN 6 0 3 3 - 4,013 487 7,407 232 60,711 IN 6 1 3 2 75 1,022 2,102 9,303 358 43,912 OH 6 0 3 5 - 138 1,637 17,974 345 69,263 MN 6 0 3 1 - 1,194 106 8,091 278 20,808 CA 5 0 0 2 - - 1,577 49,418 1,804 73,855 Total 181 13 85 60 6,463 133,659 36,343 363,753 14,515 1,803,675 Particulate matter (PM10)
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From page 63... ...
NEW SOURCE REVIEW AND TECHNOLOGY OPTIONS 63 Electricity-Generating Sector Number of Permits Permitted Emissions (tpy) Emissions Tot Grn New Mod Grn New Mod (tpy)
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From page 64... ...
continued VA 7 0 3 4 - 161 90 5,986 854 13,514 IN 6 0 4 2 - 472 253 9,303 456 14,689 MS 6 2 1 3 111 13 116 3,008 103 7,712 TX 5 0 3 2 - 219 1,497 21,808 419 34,010 IA 5 0 1 3 - 197 628 3,749 32 7,379 SC 5 3 3 0 282 86 - 4,450 172 8,137 GA 5 0 2 2 - 55 236 9,083 145 29,335 CA 5 0 0 2 - - 222 49,418 1,520 15,891 Total 207 14 99 80 1,067 11,656 13,936 363,753 15,397 606,681 Sulfur dioxide FL 20 1 7 11 37 3,161 21,247 15,992 237 7,3497 AL 14 0 7 6 - 2,137 3,319 5,444 327 84,797 IL 8 0 3 4 - 16,392 2,747 17,953 1,130 240,356 WI 8 2 4 2 82 685 104 9,936 637 80,598 LA 7 0 5 2 - 10,763 1,995 3,545 132 151,246 NC 7 1 2 3 244 5,661 5,837 11,306 755 72,180 AR 7 1 2 3 791 232 10,401 3,316 86 54,095 OH 6 0 2 5 - 1,590 2,719 17,974 334 330,991 IN 6 1 3 2 39 384 2,400 9,303 330 125,434 TX 5 0 3 2 - 93 12,600 21,808 369 233,257 IA 5 0 1 3 - 5,913 2,132 3,749 30 67,285 TN 5 0 2 3 - 902 585 7,407 107 122,658 VA 5 0 2 2 - 612 117 5,986 664 97,063 Total 131 8 58 54 1,206 53,725 68,349 363,753 9,776 2,914,441 Volatile organic compounds WI 36 2 23 10 93 2,934 743 9,936 1,233 56,490 AL 27 3 8 10 2,023 1,308 1,843 5,444 566 88,546 LA 13 1 8 5 12 2,702 3,188 3,545 235 90,490 AR 12 0 7 3 - 1,696 837 3,316 117 33,988 FL 12 1 5 3 16 420 1,990 15,992 507 18,622 NC 11 0 7 3 - 2,372 1,148 11,306 1,156 78,718 GA 11 0 3 5 - 448 1,316 9,083 227 32,111 IL 10 0 4 7 - 6,645 2,443 17,953 1,741 136,081 SC 10 3 5 0 844 1,504 - 4,450 187 46,631 KY 9 1 2 4 107 609 4,116 4,218 559 57,951 MI 8 0 5 2 - 2,935 103 1,6045 765 71,594 MS 8 1 4 3 678 501 1,148 3,008 188 39,079 OH 8 0 2 5 - 3 2,251 17,974 820 77,781 TX 8 0 5 3 - 405 1,451 21,808 568 192,080 VA 8 0 3 4 - 991 301 5,986 822 55,460
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From page 65... ...
NEW SOURCE REVIEW AND TECHNOLOGY OPTIONS 6 Electricity-Generating Sector Number of Permits Permitted Emissions (tpy) Emissions Tot Grn New Mod Grn New Mod (tpy)
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From page 66... ...
NOTE: Table lists only states with five or more NSR permits in manufacturing plants, but totals are for all states. ing sector and 9.0-25.6% in the electricity-generating sector were issued for modifications, depending on the pollutant.
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From page 67... ...
Alabama, Florida, Louisiana, and Wisconsin have substantial permitting activity for modifications in the electricity-generating sector for three or more pollutants. Table 3-2 provides examples of the distribution of NSR permits among selected industries and states for five pollutants in the manufacturing sector.
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From page 68... ...
68 NEW SOURCE REVIEW FOR STATIONARY SOURCES OF AIR POLLUTION TABLE 3-2 NSR Permit Activity by Pollutant, 1997-2002, Selected Manufacturing Industriesa Permitted Emissions Number of Permits (tpy) Census Emissions State Tot Grn New Mod Grn New Mod Plants Plants Emissions Carbon monoxide SIC 26: Paper and Allied Products AL 5 1 2 2 215 2,811 1,555 19 21 5,3208 AR 3 0 1 2 - 917 3,920 8 7 3,2977 NC 3 0 1 2 - 8,678 3,920 14 29 1,7926 WI 3 0 3 0 - 1,305 - 51 89 24,496 GA 2 0 2 1 - 707 185 25 21 142,217 Total 20 1 12 8 215 25,626 9,148 543 722 552,075 SIC 28: Chemicals and Allied Products LA 5 0 4 1 - 464 263 16 90 448,938 AL 3 0 2 1 - 239 578 12 27 46465 KY 2 0 1 0 - 473 - 11 45 1,125 MI 2 0 1 1 - 865 863 48 47 1,289 TX 2 0 2 0 - 334 - 94 184 265,755 Total 20 0 13 7 0 2,761 7,719 1,733 1,518 1,255,846 SIC 20: Petroleum and Coal Products LA 3 0 1 2 - 297 1,828 54 25 78,071 IL 2 0 0 2 - - 38 93 152 2,945 TX 2 0 2 0 - 725 - 194 38 41,077 Total 9 0 4 4 0 1,070 1,866 2,074 1,500 460,508 SIC 33: Primary Metal Industries WI 8 0 3 5 - 526 2875 6 77 14,067 AL 3 0 2 1 - 2,239 37 11 45 38,900 AR 3 1 1 1 3,694 753 3,942 7 10 6,055 IN 2 0 1 1 - 585 272 18 54 193,361 NC 2 0 1 1 - 4,380 436 1 20 6,568 OH 2 0 1 2 - 5 4,201 29 52 572,213 OR 2 0 0 2 - - 2,521 5 15 5,947 TN 2 0 0 1 - - 192 9 14 12,386 VA 2 0 1 1 - 3,473 341 4 21 2,340 Total 35 2 13 19 3,880 15,843 16,820 287 893 1,658,200 SIC 3: Transportation Equipment AL 3 1 2 0 171 482 - 6 8 409 Total 3 1 2 0 171 482 0 355 593 1,7434 Nitrogen oxides SIC 26: Paper and Allied Products AL 5 1 2 2 129 1,715 1,723 19 19 31,516 WI 3 0 3 0 - 324 - 51 90 28,858
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From page 69... ...
AR 2 0 1 1 - 86,264 711 8 7 18,523 GA 2 0 2 1 - 386 125 25 21 34,011 NC 2 0 0 2 - - 4,071 14 30 13,897 Total 21 1 11 9 129 92,724 7,903 543 786 318,804 SIC 28: Chemicals and Allied Products LA 8 1 6 0 186 1,813 - 16 93 73,815 FL 7 0 3 3 - 226 180 69 36 8,974 AL 5 0 3 1 - 405 251 12 35 8,022 AR 2 0 0 1 - - 1,091 8 14 4,688 KY 2 0 1 0 - 229 - 11 48 5,564 TX 2 0 2 0 - 236 - 94 182 109,926 Total 34 1 20 8 186 4,038 2,023 1,739 1,638 416,235 SIC 2: Petroleum and Coal Products LA 8 0 3 4 - 201 2,499 54 29 47,242 CA 2 0 0 0 - - - 205 171 29,212 IL 2 0 0 2 - - 151 93 163 29,361 MN 2 0 1 1 - 109 106 29 59 5,540 TX 2 0 2 0 - 1,857 - 194 38 102,101 Total 18 0 7 7 0 2,258 2,756 2,074 1,600 321,098 SIC 33: Primary Metals Industries WI 5 0 3 2 - 592 360 6 85 3,577 AL 3 0 2 1 - 1,019 37 11 40 5,984 OH 3 0 2 2 - 37 384 29 54 13,659 TN 3 0 1 2 - 197 338 9 13 3,239 AR 2 1 0 1 406 - 749 7 11 1,728 IN 2 0 1 1 - 54 36 18 58 16,871 OR 2 0 0 2 - - 571 5 16 1,367 SC 2 1 1 0 2 347 - 11 8 757 VA 2 0 1 1 - 798 296 4 24 1,001 Total 31 2 14 15 409 4,154 3,063 287 1033 150,948 SIC 3: Transportation Equipment AL 4 2 2 0 158 342 - 6 6 168 Total 7 2 3 0 158 1,422 0 355 669 2,6754 Particulate matter (PM10) SIC 26: Paper and Allied Products AL 6 1 2 3 46 284 1,078 19 22 10,367 WI 5 0 5 0 - 211 - 51 75 1,307 continues
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From page 70... ...
continued SIC 26: Paper and Allied Products (continued) GA 3 0 2 1 - 55 17 25 17 12,643 LA 3 0 2 1 - 994 4 12 14 8,631 KY 2 0 0 1 - - 603 9 17 716 NC 2 0 0 2 - - 801 14 34 4,608 Total 28 1 15 11 46 2,399 3,027 543 728 85,440 SIC 28: Chemicals and Allied Products FL 15 0 7 7 - 651 587 69 42 1,306 LA 6 1 4 0 14 184 - 16 82 6,882 AL 4 0 1 2 - 13 262 12 50 1,762 KY 4 0 2 1 - 111 131 11 59 1,563 Total 36 1 18 13 14 1,044 3,524 1,733 1,769 80,166 SIC 2: Petroleum and Coal Products LA 8 0 3 5 - 46 419 54 26 5,337 IL 2 0 0 2 - - 18 93 196 5,999 TX 2 0 2 0 - 207 - 194 38 8,954 Total 14 0 6 7 0 280 437 2,074 1,709 53,767 SIC 33: Primary Metal Industries WI 11 0 6 7 - 255 230 6 90 3,185 TN 4 0 1 2 - 475 160 9 16 3,096 AL 3 0 2 1 - 132 6 11 72 8,513 AR 1 1 1 247 4 108 7 10 424 OH 3 0 2 2 - 21 389 29 92 13,296 VA 3 0 1 2 - 135 64 4 23 1,426 IN 2 0 1 1 - 24 22 18 69 9,363 NC 2 0 2 0 - 238 - 1 24 391 SC 2 1 2 0 2 84 - 11 7 368 Total 43 3 20 21 354 1,429 1,391 290 1,134 114,932 SIC 3: Transportation Equipment AL 2 1 1 0 41 37 - 6 10 225 Total 4 2 1 1 47 37 13 342 695 7,424 Sulfur dioxide SIC 26: Paper and Allied Products AL 6 0 1 4 - 799 2,660 19 18 33,294 NC 3 0 1 2 - 5,277 5,729 14 26 20,766 FL 2 0 1 1 - 241 40 10 11 26,260 GA 2 0 2 1 - 203 5 25 17 55,075
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From page 71... ...
NEW SOURCE REVIEW AND TECHNOLOGY OPTIONS 1 TABLE 3-2 Continued Permitted Emissions Number of Permits (tpy) Census Emissions State Tot Grn New Mod Grn New Mod Plants Plants Emissions Sulfur dioxide continued SIC 26: Paper and Allied Products (continued)
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From page 72... ...
KY 2 0 0 2 - - 2,926 9 23 2,653 Total 39 1 17 14 637 4,094 7,144 543 930 203,827 SIC 28: Chemicals and Allied Products AL 5 0 1 2 - 4 186 12 45 29,171 LA 5 1 2 2 12 67 108 16 96 36,533 KY 3 0 1 1 - 556 369 11 72 14,434 TX 2 0 2 0 - 113 - 94 195 70,873 Total 22 1 9 10 12 945 2,877 1,746 2,076 372,390 SIC 2: Petroleum and Coal Products IL 2 0 0 2 - - 6 93 153 16,976 TX 2 0 2 0 - 157 - 194 39 79,617 Total 6 0 3 2 0 161 6 2,074 1,610 254,230 SIC 33: Primary Metal Industries WI 7 0 2 5 - 109 212 6 89 2,980 IN 3 0 2 1 - 22 38 18 78 10,423 SC 3 1 1 0 2 71 - 11 8 684 TN 3 0 0 2 - - 449 9 14 1,868 VA 3 0 1 2 - 303 272 4 27 3,492 AL 2 0 1 1 - 307 1 11 64 9,181 OH 2 0 0 2 - - 562 29 49 4,754 Total 31 1 10 18 2 1,361 2,078 291 1,097 103,323 SIC 3: Transportation Equipment MI 7 0 5 1 - 2,935 65 35 154 25,082 AL 3 2 0 0 1,386 - - 6 28 1,181 WI 2 0 1 1 - 79 232 9 54 5,261 Total 18 4 7 3 2,171 4,223 663 355 1,237 125,425 aNSR permit data are unofficial from EPA -- preliminary, unpublished, not subjected to review, or not distributed outside EPA; this may not be a complete list of all NSR permits obtained in 1997-2002. NOTE: Table lists only states with five or more NSR permits in manufacturing plants, but totals are for all states.
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From page 73... ...
The key inferences from the available data suggest that the following industries have substantial NSR permitting activity for modifications, whether measured in terms of the number of permits or permitted emissions: electricity generation; paper and allied product; and chemicals and allied products. Other industries that appear to be of secondary importance with respect to permitting activity include stone, clay, and glass products; primary metal industries; and food and kindred products.
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From page 74... ...
Furthermore, because industrial boilers are common to many industries, they are also characterized. Systematic data are not available from which to assess the claim of foregone opportunities for facilities that are claimed to have refrained from making modifications for fear of triggering a requirement to obtain an NSR permit.
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From page 75... ...
Because there is no national clearinghouse on NSR permitting activity or the status of the NSR permitting programs in each state, the committee asked the State and Territorial Air Pollution Program Administrators and the Association of Local Air Pollution Control Officials (STAPPA/ALAPCO -- referred to in this report as STAPPA) about the current state of NSR implementation.
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From page 76... ...
For example, Alaska has adopted the new federal NSR rules by reference, whereas Alabama continues to use the prerevision NSR rules. Many states reported that they are awaiting finality on the federal rules given the uncertainty caused by litigation pertaining to the NSR reforms.
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From page 77... ...
Thus, it is possible in some states that facility changes that might not trigger NSR could trigger the need for a minor permit, which in some cases might be of equivalent stringency. Getting a minor permit instead of an NSR permit appears to be generally more desirable to facilities because of the greater delays and expense associated with the NSR permit process, which can involve long public comment and greater documentation than a minor permit.
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From page 78... ...
For example, electricity-generating power plants are among the source categories for which there is a relatively high frequency of NSR permits associated with modifications. Other industries, such as petroleum refining and paper, are important in selected regions of the country.
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From page 79... ...
For example, for coal-fired power plants, the choice of an appropriate furnace design and the design of other plant components often depends at least to some extent on the rank of the coal and its properties. The choice of furnace design can influence baseline emission rates.
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From page 80... ...
80 NEW SOURCE REVIEW FOR STATIONARY SOURCES OF AIR POLLUTION plant includes coal storage and handling facilities and pulverizer mills that typically deliver finely pulverized coal to the burners via a pneumatic transport system. The furnace, also often referred to as a boiler, is the structure where combustion of the coal takes place.
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From page 81... ...
. The compressor increases the pressure of ambient air for delivery into the combustor, where pressurized gaseous fuel (typically natural gas)
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From page 82... ...
A given repair or replacement activity may or may not trigger a requirement for an NSR permit, depending on the specifics of each case. Key elements of repair and replacement at a typical fossil-fuel-fired steam power plant are the following (Babcock and Wilcox 1978)
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From page 83... ...
NEW SOURCE REVIEW AND TECHNOLOGY OPTIONS 83 · Safety considerations: These often involve proper operation of various monitoring, observation, and detection systems, such as burner observation, flame failure, unburned combustibles, fuel:air ratios, water levels, feedwater and boiler conditions, pressures, and temperatures. · Outages: These are scheduled outages for preventive maintenance (in the colloquial sense)
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From page 84... ...
Many repair or replacement projects also can prevent more catastrophic failure of a plant. For example, replacing worn heat-exchanger tubes potentially could prevent a catastrophic failure that could substantially damage a plant or injure personnel.
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From page 85... ...
Detailed reviews of NOx control-technology options are available elsewhere (EPA 1994a,b,c)
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From page 86... ...
Table 3-3 is useful in providing a baseline for uncontrolled emission rates that can be used to assess the overall effectiveness of pollution-prevention and pollution-control strategies that reduce emissions. In practice, a typical power plant has one or more methods for source reduction or control of NOx emissions and therefore has emissions lower than the uncontrolled rates shown in Table 3-3.
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From page 87... ...
if uncontrolled emissions are 1.0 lb/106 Btu to $700-1,800 per ton if uncontrolled emissions are 0.4 lb/106 Btu. At an uncontrolled emission rate of 0.7 lb/106 Btu, but with a capacity factor of 0.5, the cost effectiveness, corresponding to the
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From page 88... ...
All the cost analyses reported in the preceding paragraphs pertain to a new plant. The costs to retrofit emission controls to existing plants can be considerably higher, depending on site accessibility and whether the retrofit can be accomplished during a scheduled outage without increasing outage time.
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From page 89... ...
in the pulp industry. As is common when addressing emission sources for airborne pollutants, electricity-generating-facility boilers are deliberately excluded from this category.
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From page 90... ...
Pulp and paper processing can use biomass as a combustor fuel, which results in high PM emissions. Because industrial boiler and combustor use is widespread and tailored to specific applications, the potential to emit a particular criteria pollutant or its precursors varies widely, depending on the fuel mix and installed emission controls.
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From page 91... ...
NEW SOURCE REVIEW AND TECHNOLOGY OPTIONS 1 parts over time, degrading burner performance. Periodic inspection and repair are required to monitor and address degraded burner operation.
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From page 92... ...
2 NEW SOURCE REVIEW FOR STATIONARY SOURCES OF AIR POLLUTION TABLE 3-5 National Emissions Inventory of Typical Petroleum-Refining Processes, tons per year Process (no. facilities with process)
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From page 93... ...
Also notable in Table 3-5 is the predominance of combustion sources to overall emissions. Many of these combustion sources are associated with the operation of one of the refining processes listed.
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From page 94... ...
4 NEW SOURCE REVIEW FOR STATIONARY SOURCES OF AIR POLLUTION heating the liquid feed to progressively higher temperatures. The different components in the feed volatilize (change from liquid to gas)
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From page 95... ...
NEW SOURCE REVIEW AND TECHNOLOGY OPTIONS Sulfur Recovery The sulfur-recovery process, also referred to as gas "sweetening," involves removing primarily hydrogen sulfide (H2S) from process gases for conversion to elemental sulfur and eventual resale.
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From page 96... ...
The equipment replacement provision (ERP) would have exempted changes from triggering NSR activities that are considered "routine maintenance and repair" (see Chapter 2)
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From page 97... ...
All the subprocesses depicted in Figure 3-4 and the power boiler are critical to the overall production rate, and each has components that require repair or replacement to ensure proper operation. Thus, each section of a typical Kraft mill is potentially affected by the NSR changes.
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From page 98... ...
8 NEW SOURCE REVIEW FOR STATIONARY SOURCES OF AIR POLLUTION White liquor (Na2S and Digester NaOH) Evaporators Wood chips Black liquor & pulp Concentrated black liquor Blow Tanks Condensate Chemical Recovery Boilers Na(SO4)
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From page 99... ...
NEW SOURCE REVIEW AND TECHNOLOGY OPTIONS quality of the pulp, and depending on the final product, bleach the pulp. The brownstock washers are used to separate the digestion liquids from the pulp material.
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From page 100... ...
, and PM. The emission rates of the pollutants depends on the wood products used (softwood versus hardwood)
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From page 101... ...
For existing Kraft mills, these types of activities have the potential to trigger NSR, and any effort to assess the effect of operational changes in the NSR program on Kraft mills depends on the nature of the activities. Table E-3 in Appendix E lists repair and replacement and other activities peculiar to Kraft mills that are periodically undertaken.
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From page 102... ...
Technological advances can lead to lower costs of installing pollution-control devices, lower costs of operating the devices, improved emission-reduction performance, or some combination of those. Understanding the relationship between regulation and technological change is important for accurate assessment of the costs and, in some cases, the benefits of environmental regulation, including the changes in NSR rules being considered in this report.
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From page 103... ...
To illustrate the relationship between environmental regulation and the development of emission-control technologies, we consider two examples of such technologies: FGD technology used to reduce emissions of SO2 and SCR technology used to reduce NOx emissions from fossil-fuel-fired boilers used to generate electricity. Both FGD and SCR are technology options that are included in the modeling analysis of the electricity sector as reported in Chapter 6.
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From page 104... ...
That improvement is seen as a direct result of the stronger incentive to continually reduce emissions associated with a need to hold SO2 allowances to cover all emissions. Keohane (2002)
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From page 105... ...
. Most units complied with the regulation by installing low-NOx burners, although flexibility provisions in the law, such as emission-rate averaging across units at a plant, encouraged firms to reduce emissions through other means, such as changing air-fuel mixtures and adjusting boiler temperatures to reduce NOx emissions, before investing in control technology (Swift 2001)
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From page 106... ...
. New Source Review Modifications and Incentives for Technological Change Several economic researchers have asked whether NSR regulations inhibit technological change.
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From page 107... ...
Those favoring the NSR rule changes have asserted that concerns over triggering NSR reduced investments at existing plants and reduced markets for new technologies (see Box 3-1)
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From page 108... ...
However, American Electric Power has recently announced its intentions to construct the first commercial IGCC plant in the United States some time in the next 5-6 years. · NSR permits for modifications have been issued for a wide variety of emission-source categories but primarily, following whether measured by number of permits or by amounts of permitted emissions, in electricitygenerating facilities; stone, clay, and glass products; paper and allied products; chemicals and allied products; and food and kindred products.
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From page 109... ...
· There is substantial variation among states regarding the implementation status of the NSR revisions and the existence of a minor-construction permitting program that might cover modifications that are not covered under NSR. There is limited experience with NSR revisions where the programs have been implemented.
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