-

RECEIVED

TRADE

SECRET

CLERK’S

OFFICE

(stt.~

~5~’

.~•

p.

~

&c.s

Y4~’or

MAY

2

cic

-ø”i-

1?iinoti.

~ncr~s

/n,vQ

3

003

r~,*

t~5”~

~

BEFORE THE ILLINOIS

POLLUTION CONTROL BOARD

IN THE MAflEROF:

)

AS

___

Petition of Cromwell-Phoenix, Inc.

)

(Adjusted Standard)

for

au Adjusted Standard from 3S

)

III. Adm. Code Subpart F, Section 218.204 (c)

)

(the “Paper

Coating

Rule”)

)

PETITION FOR ADJUSTED STANDARD

CROMWELL-PHOENIX,

Inc.

(“CROMWELL”),

through

its

attorneys,

Quarles

&

Brady

LLC, pursuant to

35

III. Mm.

Code Subpart

D, Section

104.400 et seq.,

and Section

22.1

of the Illinois

Environmental

Protection

Act, 415

1LCS

5/28.1

(the

“Act”),

respectfully submits

this

Petition

for

Adjusted

Standard

(‘Petition”)

to

the

Illinois

Pollution

Control

Board

(the

“Board”)

seeking an adjusted

standard

from the

VOM content limitations of 35

III.

Adm.

Code

Subpart

F

Section

218.204(c)

as

those rules

apply

to

the emissions of volatile organic material

(“VOM”)

from

CROMWELL’s

corrosion

inhibiting

(“CI”)

packaging

materials

production

facility

in

Alsip, Cook County, Illinois.

1.

PROCEDURAL HISTORY

CROMWELL

began

production

at

its

Alsip

facility

in

early

2001.

Following

an

inspection

by

the

Illinois

Environmental

Protection

Agency

(“IEPA”)

and

an

exchange

of

correspondence,

LEPA

issued

Violation

Notice

A-2001-00265

dated

November

20,

2001.

Among

other

things,

the

Violation

Notice

alleged that CROMWELL

had

failed to demonstrate

compliance

with the reasonably available control

technology (“RACT”)

emission

limitations set

forth in

35

III.

Adm. Code 218, Subpart F, applicabte to

paper

coating

operations.

33S4~

I

This filing

issubmiflc4 on rncyccd

p~pcr

PETITIONER’S EXHIBIT I

---

k.

)

CROMWELL

held

telephonic

meetings

with

representatives

of

the

Illinois

Environmental

Protection Agency

(“IEPA”) to

discuss the

Violation Notice,

and

submitted

its

Compliance

Commitment

Agreement

to

IEPA

on

February

19,

2002.

The

Compliance

Commitment Agreement explained that

the

VOM in

CROMWELL’S products acts

as more than

a mere carrier for active ingredients.

The VOM acts

as a paper softener, improves paper folding

qualities,

dissolves

and

retains

corrosion

inhibitor

compounds

and

facilitates

their

gradual

migration to

the customer’s

wrapped metal

parts over a

prolonged

period

of time.

Thus

while

CROMWELL advised

IEPA

that

it was

attempting

to

find

coating

fonnulations

that

would

comply

with

the

applicable

RACT

standanis,

it

also

advised

that

reformulation

was

likely to

impair product quality and could,

because of the need to utilize dryers to drive off added water,

ironically have the undesirable effect of increasing emissions of VOM.

CROMWELL

noted,

additionally,

that because it

prints

on

the majority of its products before

applying the corrosion

inhibiting solutions,

its printing/coating operations are regulated by

35

lii. Mm. Code Subpart

H,Section

218.401

governing printing.

IEPA

responded

by

issuing

its

Notice of Intent to Pursue

Legal

Action

on

March

19,

2002.

CROMWELL

held another

telephonic meeting

with

IEPA

and

strongly

urged

that a

representative of IEPA visit its facility so that the agency could

view

first

hand the operations in

question.

Mr.

David

Ii.

Bloomberg,

a coatings

specialist with

IEPA’s

Air

Quality

Planning

Section,

visited

the

facility

on

May

9,

2002.

Following

the

facility

visit and

subsequent

discussions with JEPA, both parties agreed that CROMWELL would

file

thisPetition,

CROMWELL

submitted

a Clean

Air

Act

Permit

Program

(“CAAPP”)

application

to

IEPA

on

March

29,

2002.

That

application

demonstrates

that

CROMWELL

is a

true

minor

---

D

source.

CROMWELLhas requested that IEPA issue a lifetime air operating permit. The CAAPP

application currently is under review at EPA.

Ii.

35

ILL ADM. Code

Section

104.406

A.

Standard From Which ReliefIs Sought (Section 104.406(a))

CROMWELL

requests

that

the

Board grant CROMWELL

an

adjusted

standard

from

3S

Ill. Mm.

Code Subpart

F, Section

218.204(c)

(the “Paper Coating

Rule”) as

this nile

applies

to

the

emissions

of

VOM

from

CROMWELL’S

operations

in

Alsip,

Cook

County,

Illinois.

These rules became effective on August 16,

1991.

The Paper

Coating Rule

from

which

CROMWELL

seeks and adjusted

standard

requires paper coaters to utilize coating materials containing

no more than

2.3

pounds of VOM

per gallon of coating

applied

(excluding

water).

In

the

alternative,

the source

may utilize

a

capture system and

control device which

achieves an

81

reduction in the overall emissions of

VOM

from

the

coating line,

and

a

90

reduction of the

captured

VOM

emissions,

or

achieve

VOM reductions that are equivalent to the limitations of 35

JAC 218.204.

See 35111.

Adni. Code

Subpart F, Section 218.207.

As will be demonstrated herein, CROMWELL cannot use compliant

coatings, and

the approved control technologies will

work only

at unreasonable

costs and with nominal VOM

reduction benefit; as such, they are not RACT for CROMWELL.

B.

Nature of Regulation

of General Applicability (Section 104.406(b))

The

regulations

from

which

CROMWELL

seeks

an

adjusted

standard

were

among those promulgated to implement Section

182(d) of the Clean Air Act,

42 U.S.C.

7401

et

seq.

which,

among

other

things,

requires

individual

states

with

severe

ozone

non-attainment

areas to

adopt RACT regulations applicable

to sources of VOM

within

the non-attainment

area.

-3-

---

D

As mandated by the Clean Air Act, the Board established the requirements described in the Paper

Coating Rule.

The

Chicago-area

severe

ozone

non-attainment area

includes

sources

located

in

Cook,

L)uPage. Kane, Lake, and Will

counties,

Oswego Township

in

Kendall County, and Mix

Sable and Goose Lake Townships in Grundy County.

CROMWELL is located in Cook County

which is part of the Chicago-area designated severe ozone non-attainment area.

CROMWELL is aminor source and is seeking a lifetime air operating pemñt.

C.

level of Justification (Section 104.406(c))

The

regulations

of

general

applicability

from

which

CROMWELL

seeks

an

adjusted standard

do

not specifya level ofjustilication

for an adjusted standard.

U.

Facility and Process Description (Section 104.406(d))

1.

General Information

CROMWELL

is

an

Illinois

corporation

located

in

Alsip,

Cook

County,

Illinois.

CROMWELL

emptoys 31

people and operates in a 98,000 square

foot building.

The

building was constructed

in

(965; CROMWELL began operations in the building in

early 2001.

CROMWELL’S

equipment

is approximately

40

years

old.

CROMWELL

believes

that

it

is

the

only

manufacturer of corrosion

inhibiting packaging materials in

Illinois.

2.

~sDescdtion

CROMWELL

produces

corrosion

inhibking

packaging

materials

by

-4-

---

0

In

most

cases various

images

are printed

on

the kraft

paper prior to

the

application

of

the

CI

solutions.

These

images

include

the

CROMWELL

logo,

lot

number, product usage instructions, and graduated lines for measurement purposes.

The

images

are

applied

using

an

in-line

(lexographic

printing

cylinder

and

water

based

tiexographic inks.

3.

~flionofE~jssions

The

only

emissions

of regulated

pollutants

from

the

production

of

the

corrosion inhibiting packaging materials are the relatively low emissions of VOM.

None

of the

VOM

compounds

used

are

defined

as

Hazardous

Air

Pollutants under

Section

112(b) of the Clean

Air Act.

CROMWELL selects the

impregnation coating and carrier

constituents based upon their ability

to be retained

in the

product for a prolonged period

-5-

---

I)

of time.

Therefore, the emissions of

VOM

are very low by

design.

Low vapor pressure

VOM

carrier compounds are utilized, and the finished packaging material is rewound on

a

cylindrical

core

immediately

after

the

solutions

are

applied,

thereby

physically

encapsulating the

product

and further impeding the

volatilization

of the

liquid

fraction

components.

In

addition,

the

vast

majority

of

the

packaging

products

are

produced

without

using

dryers.

Less

than

10

of CROMWELL’S

products require the

use of

infra-red

(“ER”)

dryers.

IR

drying

is

required

when

the

CI

solution contains

a greater

pementage of water.

The

e~ccesswater

must be

driven

off using the

lit

dryers.

It

is

important

to note that

since both

water and VOM will

be driven off concurrently,

VOM

emissions will

increase

as the amount of drying

that is required

increases.

(Iravimetric

tests

have

been

performed

to

determine

the

weight

loss

and

emissions

from

the

Ci

packaging production processes, including storage.

In the most recent tests, the weightof

the

virgin

paper

used,

CI

solution

applied,

and

the

final

products

produced

were

determined over

periods that represent

their typical holding

times

in

the

CROMWELL

facility.

The gravimetric data demonstrate that the overall

VOM emissions are less

than

5

of

the

weight of Ci

solution

applied.

This

emission

factor

assumes

that

the

VOM losses are proportional

to their composition in the liquid fraction of the

Cl

solution.

In fact, the water will likely preferentially volatilize relative to the VOM components due

to its higher

vapor pressure.

Therefore, the VOM emission

factors used hy CROMWELL

can be considered worst case.

it is clear that the VOM emissions from the Ci solution are

very low dueto their low volatility and their effective retention in the paper substrate.

-6-

---

1)

Based

on

these

emission

factors,

total

VOM

emissions

from

the

CROMWELL facility were no more than approximately

5

to 6 tons per year for calendar

years

2001

and 2002.

Typical hours ofoperation are approximately 2900

hours per year.

Projecting operations to

8760

hours per

year, and continuous

full web

width maximum

operation of all

production

units,

potential

emissions

from

the

facility are less

than

25

tons

per

year,

including

ancillary

mixing

and

handling

operations.

Therefore,

the

CROMWELL

facility is asimple minor source.

CROMWELL

has

been

working

on

CI

solution

reforniulations

in

an

attempt

to

reduce

the

as-applied

VOM

content

(less

water)

to

as

great a

degree

as

practicable,

while still

pmviding

sufficient

solids dissolution,

retention, and

migration.

However,

as

the amount of water in the solutions is increased, so does the need to

utilize

the

JR

dryers to drive offthe excess water.

Along with the increased

evolution of waler

will

be

an

associated

proportionate

increase

in

VOM

emissions

for the

equivalent

CI

product produced. This

is counterproductive

to the goal ofVOM emissions reduction.

4.

Pollution Control Equipment

CROMWELL

does not

employ the use of any pollution control equipment

in its operations.

S.

Permit Status

At

the request of

LEPA, CROMWELL submitted a Clean Air Act Permit

Program

(“CAAPP”)

application on

March

29,

2002.

Although

a

CAAPP

application

was submitted, CROMWELL

is a

minor source.

Accordingly, in its CAAPP application

CROMWELL

requested

that

a

lifetime

air

operating

permit

be

issued

for

the

CROMWELL

facility.

The CAAPP application

is

under review within

IEPA.

During

.7..

---

n

the

course

of discussions

between

IEPA

and

CROMWELL

concerning

the

CAMP

application and Notice of Violation A-2001 -00265,

IEPA

and

CROMWELL

agreed that

CROMWELL

should submit this Petition

for Adjusted

Standard.

It

is

CROMWELL’s

understanding that its air operating permit will be issued upon the Board’s issuance of its

Opinion andOrder on this Petition.

6.

General Description ofthe

Local Non-Attainment Area

CROMWELL

is

located

in

an

industrial

area

in

Alsip,

Illinois

on

Ridgeway Avenue.

The

nearest school

or residential area is

approximately

I

mile

from

the CROMWELL facility.

The

city ofAlsip is located in Cook County, Illinois, which is

part of the Greater Chicagoland

Severe-I 7

Ozone non-attainment area designated under

40

CFR 81.314,

as defined by USEPA pursuant to Section

107 of the CleanAir Act.

K

Cost of

Compliance and Compliance Alternatives (35MC 104.406(e))

Achieving compliance with the applicable limitations of 35 IAC Pan 218 Subpart

F requires that either the VOM content of the Cl Solutions be reduced, or that add-on controls be

applied.

The

technical

and

economic

feasibility

of these

two

options

for

the

CI

packaging

productionoperations atCROMWELL are discussed below.

1.

CROMWELL’t~~$ions

Were Not Contemplated by Applicable Rules

Achieving the VOM content levels

in

the Cl coatings that are called for in

the

applicable

section

of

35

IAC

Part

218

Subpart

F

(35

RC

218.204(c))

is

not

practicable for functional, environmental,

andeconomic reasons.

Unlike conventional coating operations, where VOM solvents are used as

carriers

of

pigments

and

other

solids,

and

the

VOM

solvents

are

intended

to

be

evaporated, the VOM components in CROMWELL’S Cl solutions are intended to remain

-8-

---

1)

H

in

the

CI

packaging

products

in

order

to

pcrfonn

their

essential

corrosion

inhibiting

functions.

As

such,

CROMWELL

has

inherent

economic

and

product

performance

incentives

to

ensure

that

the

VOM

components

are

retained

in

the

product

and

not

emitted. Therefore, the high molecular weight,

low volatility VOM

components

in

the

Cl

Solutions

are selected

by

CROMWELL

to

enhance retention

in

the product, and

not

be

emitted,

by

design.

It

is important to note that the

35

IAC

Part

218

Subpart F paper coating

standards

arc

based

on

the

Control

Techniques

Guideline

(CTG)

titled

“Control

of

Volatile

Organic

Emissions

from

Existing

Stationary

Sources

—

Volume

11:

Surface

Coating of Cans,

Coils,

Paper,

Fabric,

Automobiles

&

Light

Duty

Trucks”

dated

May

1977

(EPA4SO/2-77-OO$).

In Section

5.0

of this document (Paper Coating),

it describes

the paper coating process as follows (Page

5-1):

“In

organic solvent paper coaling, resins

are dissolved

in

an organic solvent or solvent mixture

and

this solution

is

applied

to

a

web (continuous roll) of paper.

As

the

coated web is dried, the solvent evaporates and

the coating cures”

(Emphasis added).

Clearly, for conventional coaters, the purpose

of

the

solvent is to act as a cattier for the pigments and resins.

In such a case the

intent is

for

the

solvent

to

be

evaporated,

leaving

the

solids

to

dry

and/or

cure

as

the

surface

coating

on

the

paper

substrate.

In

the

case

of

CROMWELL,

the

liquid

organic

components

are

intended

to

be

impregnated

into

and

remain

with

the

paper

product.

They are intended to become an integral component of the product.

This type ofproduct

clearly was not contemplated at the time the CTG forpaper coating was devctoped.

Further,

on

page 5-13 of the paper coating CTG,it describes how the vast

majority of solvents used in conventional paper coating operations are evolved during the

-9-

---

C

application,

drying,

and

curing

steps.

“Many plants

report that

96

percent

of solvent

introduced to the coating line is recovered.

Part of the sovent

remains with the finished

product

after

it

has

cured

in

the

oven.

Some

coaters

estimate

that

2

or

3 percent

of

solvent

remains

in

the

product.”

This

again

differentiates

the

conventional

coating

operations

contemplated

by

the

paper

coating

CTG

from

the

type

of

CI

packaging

production operation

at

CROMWELL.

CROMWELL applies

the

CI

solution to the bail

paper substrate with

the

intent that the vast majority of the

Cl solution constituents

Will

remain

in and become

an integral

pan of the final

product.

While conventional

coating

operations drive off

96

percent

or more of

the solvent applied,

the CI

packaging materials

produced

by

CROMWELL

retain over

95

of

the organic

liquids

applied,

since these

organic

liquid

components

are

an

integral

part

of

the

product.

It

is

clear

that

CROMWELL’S type

of operation

and their products were not contemplated

in

the CTO

for the paper coating

industry.

It

is important

to

understand

that

the presence

of the VOM

components in

the

Cl

solutions

and

CI

products provides an

essential corrosion

inhibiting

function.

These VOM

components

are themselves corrosion inhibiting, and they serve

to

facilitate

the

gradual

migration

of other

corrosion

inhibiting

solids

present

in

the

Cl packaging

products

onto the customer’s

wrapped metal parts over a prolonged period

of time.

In

addition,

it

is

undesirable

for

the

CI

products

manufactured

by

CROMWELL

to

contain

excess

water,

as

the

presence

of

residual

water

in

the

CL

products

promotes corrosion.

Excess

water also

causes

unacceptable

expansion of

the

paper fibers

resulting in

the

product becoming

wrinkled

and

welted,

as

well as

the cut

sheets

becoming

curled.

This

makes

the

products

very

difficult

to

handle

by

-10-

---

C)

CROMWELL

personnel

and

their customers,

and

results

in

the

inability

to

achieve a

good wrap on

the metal

items that are being protected

by

the

CL papers.

Therefore,

if

additional water was utilized

in

lieu of some of the VOM components in the

CI

solution,

additional supplemental heated drying operations would be

required in order to drive off

the

excess

water.

Not

only

would

additional

energy be

consumed

in

doing

this,

but

additional VOM would be evolved in the process.

The VOM would evaporate along with

the

excess

water,

thus

increasing

the

net

overall

emissions

from

the

facility.

CROMWELL asserts that this would result in a detriment to the environment, and would

negatively impact the economicviability of the

a

production operations.

A

projection of VOM emissions

changes was

made in order

to

approximate

the

emissions

impact resulting from a reformulation of the

CI

solutions to

the

2.3

lbs VOM

per gallon level required under

35

IAC

218.204(c).

The emissions projection was based

on an extrapolation of the

VOM emissions

factor established at the current

CL

solution

VOM

contents,

vapor

pressures

and ambient

operating conditions,

and

applying

the

increased constituent

vapor

pressures at the

elevated

temperatures,

and

the

decreased

VOM

contentsof the Cl solutions.

Basedon

heating the substrate

to a minimum

of 54°C

(129°F),the VOM emissions of the reformulated CI solutions are projected to increase by

a factor of approximately 7.8

times

above that of the

current

formulations.

In

such

a

case, annual VOM emissions would

increase

from the current

5

or 6 tons per

year, up to

approximately 39 tons per year, or higher.

Actual substrate temperatures will

likely need

to

be

considerably

higher

than 54°C,probably

in excess of 65°C(150°F),in

order to

sufficiently drive oftthe excess water.

Therefore, VOM emissions would accordingly be

even

higher.

Again,

it

is

important

to

emphasize

that

the

intent

of the

CI

solution

—

It

—

---

C)

1)

impregnation

process is

to retain

the

VOM

constituents

in

the

substrate.

The

use of

elevated process temperatures is counterpmductive to this goal.

2.

Add-On Controls A

Not ~

Reasonable

CROMWELL’S

consultant,

ERM,

Inc.,

analyzed

the

technical

and

economic

feasibility of the application of add-on control devices to CROMWELL’S

Cl

coating operations.

See

Reasonably Available Control Technology (“RACT”) Analysis

by ER.M, Inc. at Exhibit A attached hereto.

The technically feasible control options were

determined to be oxidation and a combination carbon adsorptioa/oxidation system.

As can be seen in the RACT analysis

in Exhibit A, the costs of installing

add-on oxidation or carbon adsorption/oxidation controls at CROMWELL are excessive.

Table 2 of Exhibit A summarizes

the

annualized costs

associated withthe application of

these control

technologies.

The annual cost per ton of VOM controlled for each of these

options ranges from approximately $25,000 to $70,000.

This is well above the level that

would be considered reasonable under a conventional RACT demonstration.

Also, these

costs

do

not consider the costs

associated with

compliance demonstration testing,

which

likely

would be

on

the order of $40,000 to

$50,000.

In

addition, while the annualized

costs are themselves excessive, the initial capital outlay would also be prohibitive and

the

ongoing

annual

cost

of the

controls

would

be on

the

order of

$375,000

to

$560,000.

These costs

are clearly excessive, given

that

the

actual

level of VOM

emissions

to

be

controlled is on the order

of 5

or 6 tons per year,

F.

Proposed Adjusted Standard (35 JAC

104.406(1))

CROMWELL

proposes

the

following

adjusted

standard

for

adoption

by

the

Board:

-

12-

---

U

CROMWELL

may

continue

to

operate

its

corrosion

inhibiting

packaging

materials production operations as long

as:

I.

The total

actual

‘(GM

emissions ~om

the CROMWELL

facility

do

not

exceed

25

tpy.

2.

The Versil Pak wax

laminating coatings continue to meet

the applicable

VOM

content limitations under

35

JAC

Part

218

Subpart F.

3.

The

web

fed

and

sheet

fed

Cl

coating

and

printing

lines

use

only

Corrosion

Jniiibiting

solutions

whose

as-applied

VOM

contents

do

not exceed

8.3

lbs

VOM per gallon, less water.

4.

CROMWELL

shall

operate in

full

compliance

with

all

other

applicable

provisions of

35

lAC Part248 Subpart F.

5.

CROMWELL

shall

continue to

investigate viable

reduced

VOM

content

CI

coatings

and,

where

practicable,

shall

substitute

such

coatings

as

tong

as

such

substitution

does

not

result

in a

net

increase

in

VOM

emissions.

An

annual

report

summarizing the activities and results of these investigatory efforts

will

be prepared by

CROMWELL and submitted to the IEPA.

6.

CROMWELL

shall operate in full compliance with the Clean Air Act.

7.

CROMWELL shall

continue to report

all annual emissions to the JEPA.

-

13

-

---

1)

C.

The Quantitative

and

Qualitative

Impact

of CROMWELL’S

Activity

(35

JAC

104.406(g))

Due

to

the

nature

of

the

VOM

components

used

in

the

Cl

solutions

at

CROMWELL,

less

than

5

Ions of actual

VOM per year are emitted

from that

portion

of

their

production operations.

Approximately

5 to 6 tons per yearof actual

VOM

are typically emitted

from

the entire plant,

including

the Versil Pak wax

laminating operations.

This

is a relatively

small contribution to the local air shed when compared to the hundreds of thousands of tons of

VOM

emitted each year in the Chicagoland Nonattainment Area.

in addition, if

CROMWELL

were to attempt to utilize reduced

VOM content

Cl

coatings.

VOM

emissions

would

actually

increase.

As

previously

described,

if water

were

utilized

in

the

Ci

solutions in

lieu of some of the

VOM

components,

additional

supplemental

heated drying would be required in order to drive off the excess water.

This would result in an

increase

in

VOM

emissions

for

the

same

product

produced,

since there

would

be

additional

VOM

driven

off

along

with

the

excess

water.

Also,

there

would

be

additionat

energy

consumption required to perform the increased supplemental drying.

As described

in

Exhibit A at page 9, if the most economical add-on controls were

applied to the Cl coating operations at

CROMWELL,

the associated energy and environmental

impacts would be substantial

in comparison to the small net reduction

in VOM

emissions.

In

order

to

control

the

15.21

tons

per

year of potential

VOM

emissions

from

the

Cl

coating

operations,

approximately

13.5

million

cubic

feet of natural

gas

will

be burned,

resulting

in

emissions of over 800 tons of CO2 (a greenhouse gas),

0.67 tons of NO~

(an

acid rain precursor,

criteria

pollutant,

and an

ozone

precursor),

and

0.57

tons

of CO (an

acute

toxic

and

criteria

pollutant).

In

addition,

over

120,000

kWhr

of

electricity

would

be

consumed

annually.

14-

---

0

Therefore,

the

deleterious

energy

and

environmental

impacts

would

be

substantial,

while

the

benefits

of VOM reduction would be minimal.

H.

Justification (Section

104.406(b))

As

previously

described,

the

Paper

Coating

Rule

did

not

contemplate

the

issues

pertaining

to

manufacturers

of

CI

materials

when

the

rule

was

promulgated.

Moreover,

compliance

with

the

Paper

Coating

Rule

would

undermine

the

quality

and

efficacy

of

CROMWELL’s

products.

Compliance

would

necessitate

the

addition

of

water

to

CROMWELL’s

formulae.

As

residual

water

is,

obviously,

undesirable

for

CROMWELL’s

products.

CROMWELL

would be

forced to

use

supplemental

IR

dryers

to

drive

off the excess

water.

This

extra step in

the

manufacturing

process would have

the

unintended

and

unwanted

effect

of driving off additional VOM

and

increasing

the net

overall emissions

from

the facility.

Thus,

CROMWELL’s

compliance

with

the

RACT

standards

is

not

feasible

without

incuthng

extraordinary cost and expense,

compromising

product

quality

and fhnctionality,

and increasing

the

overall

VOM

emissions

from

the

facility.

The

RACT

adjusted

standard

proposed

by

CROMWELL

is justified

because

it

is

technically

feasible,

economically

reasonable,

and

will

have

no

significant

adverse

impact

on

the

ambient

air

quality

in

the

Greater

Chicagoland

Nonattainment Area.

1.

ConsIstency with

Federal

Procedural Requirements (Section 104.406(Q)

I.

Consistengwith Federal

By

granting

the

proposed

adjusted

standard, the Board will

not violate any

provisions of the Clean Air Act.

CROMWELL’s operations and

the

appropriate RACF

requirements applicable to

CROMWELL are subject to

this

proceeding.

Pursuant to the

Act

and

the Clean Air Act,

the

Board is empowered to determine what constitutes RACT

-

is

-

---

C)

for

CROMWELL.

Accordingly, under

its

authority

to

adopt

RACT

regulations,

the

Board may grant the requested relief consistent with

federal law.

2.

Federal Procedural Requirements

Under federal law, the Board’s grant of the adjusted standard requested

by

CROMWELL will be submitted

to the 1JSEPA

for inclusion

as

a RACT rule specific to

CROMWELL

in

the

State

Implementation

Plan

for

illinois.

As

such,

the

adjusted

standard will comport with federal procedural requirements.

J.

Rearing (SectioQ

&04.406Q))

CROMWELL requests a bearing in thismatter before the Board.

K.

Supporting Documents (Section 104.406(k))

Supporting documents cited in this Petition are attached hereto as ExhibIts A and

B.

HI.

SECTION 28.1(C) FACTORS

Under

Section

28.1(c) of

the

Act,

415

ILCS

5/28.1,

the

Board

may grant

individual

adjusted

standards

upon

adequate

proof

that:

I)

the

factors

relating

to

the

petitioner

are

substantially and significantly different from the factors relied upon by the Board in adopting the

general

regulation

applicable

to

the

petitioner;

2)

the

existence of

those

t~ctorsjustifies

an

adjusted

standard;

3)

the requested standard

will

not

result

in

environmental

or

health

effects

substantially and significantly more adverse than the effects considered by

the Board in adopting

the

rule of general

applicability; and

4)

the adjusted standard

is consistent with any

applicable

federal law.

-16-

---

C)

A.

The

Factors

Relating To

CROMWELL

Are Substantially

and

Significantly

Different

CROMWELL’S

operations

are

unique

in

Illinois.

Examination

of

the

CII)

published

for

the

paper

coating

industrydemonstrates

clearly

that CROMWELL’S operations are

distinct

from

those that

the

LEPA

sought

to

regulate when

it promulgated

35

Ill.

Adm. Code,

Subpart F,

Section 218.204 (c).

Thus

the

factors

relating

to CROMWELL are

substantially and

signifteantly

different than those pertaining to typical paper coaters.

B.

The Existence of Those Factors

Justifies

an Adjusted Standard

As

discussed

fully

itt

this

Petition.

CROMWELL

has

investigated

a

number

of

compliance

options.

The

compliance

alternatives

investigated

include

experiments

with

reformulated

Cl

coatings

and

the installation

of add-on

controls.

These

alternatives

have

not

proven

to

be

technically

feasible

or

economically

reasonable.

Under

the

circumstances,

the

requested

adjusted

standard

is technically

and

C.

The

Adjusted

Standard

Will

Not

Result

in

an

Adverse

Impact or Health Effect

As

discussed previously

in

this

Petition, the

requested adjusted

standard will

not

have

an

adverse

environmental

impact or

health

effect.

CROMWELL is

a minor

source,

and,

based

upon

information

and

belief,

is

the only

CI

material

manufacturing

facility

located

in

illinois.

By definition, CROMWELL’s emissions will

have only a minor impact on

air

within the Greater Chicagoland Nonattaininent Area.

t7-

---

U

P.

The Proposed

Standard

is Consistent

with

ApplicableFederal Law

The

proposed

adjusted standard is consistent with

federal

law

as

discussed in this

Petition.

The

granting

of the

adjusted

standard will

not violate

any

provision of the

Clean

Air

Act

because

no

federal

RACT

standards

have

been

established

that

are

applicable

to

CROMWELL’s

specific

IV.

CONCLUSION

CROMWELL

requests

that

the

Board

grant

the

proposed

adjusted

standard

as

an

alternative to the

RACT

regulations adopted by the

Board

in the Paper

Coating Rule.

To

require

CROMWELL.

to

comply

with

the

requirements of

35

Ill..

Adm.

Code

Subpart

F,

Section

218.204(c)

et

seq.

would

result

in

substantial

economic

hardship

to

CROMWELL

with

no

conesponding

environmental

benefit.

It

is

not

technically

feasible

to

comply

with

the

Paper

Coating Rule ascompliant

coatings do not meet CROMWELL’s

product efficacy standards,

and

because

compliance

could

have

the

reverse

effect

of

creating

increased

emissions

and

environmental

detriment.

Finally,

add-on

controls

are

unreasonably

expensive,

provide

little

environmental benefit, and have associated

significant

adverse

ancillary

environmental

impacts.

Pursuant

to

35

Il).

Mm.

Code

104.406,

CROMWELL

submits

the

technical

report

prepared

by

Environmental

Resources

Management,

Inc.

(Exhibit

A),

and

the

Affidavit

of

CROMWELL (Exhibit B) to

veril~’

the facts

asserted

in this Petition.

-18-

---

U

H)

WHEREFORE,

Cromwell-Phoenix,

lnc.

respectfully

requests

that

the

Board

grant

CROMWELL

the

proposed

adjusted

standard

from

35

III.

Mm.

Code,

Subpart

F,

Section

18.204(c)

as

those

rules

apply

to

the

emissions

of

VOM

from

Cromwell-Phoenix,

Inc.’s

operations

in

Alsip. Cook County, Illinois.

CROMWELL-PHOENIX,

INC.

Janine M.

Landow-Esser

QUARLES & BRADY

LLC

500

W.

Madison

Street

Suite

3700

Chicago, Illinois

60661

May 29, 2003

-19-

---

0

---

Cromwell-Phoenix, Inc.

(I)

C)

Reasonably Available Control

Technology

(RACT) Analysis

tllino~s

EPA

JO

No.

031 003 MW

May2003

TRADE

SECRET

(1.t

£~~V1,5

/:~9~~6~

~

Aisip,

Illinois

ERM

Deli

veñnq

se,stainable solutions in a more competitive would

---

U

0

Cromwell-Phoenix. Inc.

May2003

RACF Analysis

Page 1

REASONAOLY

AVAILABLE

CONTROL

ThcuwoLoGv

(RACV) Aw,u.nrs

A source specific

RACT

analysis is presented herein in

support of a demonstration

of

technological

and

economic feasibility of add-on

pollution

controls

at

the Cromwell-

Phoenix,

Inc.

(Cromwell-Phoenix)

manufacturing

facility

in

Alsip,

Illinois.

PACT is

defined as “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 economicfeasibility” (44 FR 53761, September 17, 1979).

Cromwell-Phoenix is a manufacturer of corrosion inhibiting packaging materials for the

metal parts industry.

The corrosion inhibiting packaging materials are produced by

impregnating kraftpaper with corrosioninhibiting (CI) solutions.

The

first

step

in

the

RACT

analysis

is

to

determine

for

the

pollutants

in

question

applicable

control

technologies

that

have

practical

potential

for

this

type

of

manufacturing

operation.

The

control

technologies

are

ranked

in

order

of

overall

control

effectiveness.

If it

can

be

shown

that

the

most

stringent

level

of control

is

infeasible

on the

basis of

technical

and

economic factors,

then

the next

most

stringent

level

of control

is identified

and

similarly

evaluated.

This

iterative

process continues

until

the

PACT

level under consideration is

not

eliminated

by

technical and economic

factors.

---

o

0

Cromwell-Phoenix,

Inc.

May2003

RAcrAnalysis

Page

2

This

PACT

analysis generally follows

the flop-down”

BACT analysis processdescribed

in

the

tJSEPA’s

Office

of

Air

Quality

Planning

and

Standards

(OAQPS)

guidance

documents, and is summarized as follows:

•

Applicable

emission

control

technologies

are

identified

that

have

practical

potential for application to the above described manufacturing operations.

•

An efficiency level is proposed (or add-on controls that would constitute PACT.

•

Technically infeasiblecontrol options are eliminated.

•

The

remaining control

technologies

are

ranked

in

the order

of

overall

control

effectiveness.

•

The

most

effective

control

technology

options

are

evaluated

considering

•

Each of the above steps is detailed in the following sections.

A.

Identification of Applicable

VOC

Control

Technologies

1.

Condensation

Condensation is

a

basic separation

technique in

which

a

gas stream

containing

VOCs is

first brought to saturation and then the

VOCs

are condensed to a liquid.

The conversion of a vapor phase

VOC

to its

liquid phase can be accomplished by

sufficiently

lowering

the

gas

stream

temperature

and/or

by

increasing

its

pressure.

The

most common

approach

is

to

reduce

the

temperature

of the

gas

stream at constant pressure.

Condensation

systems

are

effective

only

for

gas

streams

containing

high

concentrations of high

molecular weight

VOCs

(e.g.

heavy oils).

The minimum

VOC

concentration

achievable

at

the

outlet

of

a

condensation

system

is

the

saturation concentration for

that particular

VOC.

Water is the most common and

cost effective coolant. Therefore, even moderate

VOC

removal efficiencies

(50)

are

not

achievable

unless

the

vapors

will

condense

at

relatively

high

temperatures.

The

exhaust

stream

at

Cromwell-Phoenix contains

very low

concentrations

of

relatively

low

molecular

weight

(75

-

145

lbs/lb-mole)

VUCs

which

condense

only

at

very

low

temperatures.

Such

temperatures

are

achievable

only

by

---

I

Cromwell-Phoenix. Inc.

May 2003

tACT Analysis

PageS

energy-intensive

mechanical

refrigeration

of the

exhaust gas

stream. Therefore,

2.

Adsorption

Adsorption is a process by

which compounds such as

VOCs are

retained on the

surface of a solid.

Physical adsorption is

a phenomenon where gaseous or liquid

compounds

adhere

to

the surface of a

bed

of solid adsorbent particles that are

highly

porous

and

have

very

large surface to volume ratios.

Activated carbon

is

one

of

the

most

effective

and

most

common

adsorbents

used

for

removal

of

gaseous

VOCs

from

industrial exhaust

streams.

VOC

adsorption onto activated

carbon

is a

physical

process

based

upon

attractive

forces

known

as

Van

der

Waals forces. The magnitude of these

attractive forces is primarily

a

function of

the surface area of

the gaseous molecules and the amount of surface

area of

the

solid

that

is available

(or

adsorption.

Other

intermolecular

forces of

attraction

also affect adsorption ability.

At equilibrium, the quantity of gas that is adsorbed

onto activated

carbon is a function of

the adsorption temperature

and pressure,

the

VOC

being adsorbed, and the carbon characteristics such as particle

size

and

pore structure.

Activated carbon is a particulady effective

adsorbent

for

gaseous

VOCs due

to

its

extremely high surface area

to

weight ratio, and its

pronounced

capillary action.

Carbon

adsorption

removal

systems

are

most

effective

for

VOCs

having

molecular weights between approximately 60 and 180.

The molecules need

to be

“large”

enough

to

develop sufficient

Van der

Waals

forces with

the adsorbing

media,

yet

they can’t be so large

that the Van

der

Waals forces are so great

that

the molecule cannot

be removed during the desorption cycle. Therefore,

higher

molecular weight compounds

are

too

difficult

to desorb while lower molecular

weight compounds experience little to no adsorption. The majority of

VOCs

used

by

Cromwell-Phoenix

have

molecular

weights

in

this

range,

therefore

they

would be amenable to effective adsorption arid

desorption.

Also,

given

the

variety of the

materials utilized

at Cromwell-Phoenix,

it

is

not

practical

to

recover

the

solvents

for

reuse.

Solvent

recovery and

reuse

is

most

---

1)

Cro,nwel)-Phoenix, Inc.

May 2UO

tACT

Analysis

Page 4

feasible

for

single solvent

systems.

Also,

it

is

not

feasible

to

recover such

a

solvent

mixture via

decantation

since the solvents are

water soluble. Therefore,

the

only

technically

feasible

control

option would

be

to

utilize

an

activated

carbon

adsorption system

as

a

pre-concentrator,

and

then thermally

desorb

the

solvents,

directing

the

concentrated

stream

to

a

thermal

oxidizer

for

VOC

destruction.

In such

a scenario, the volumetric flow rate of the

desorption

stream

is typically

10

of the volumetric flow rate of the adsorptionstream.

While

the

limitations

described

above

will reduce

the

effectiveness of

a

carbon

adsorption system and

will

present some

safety

hazards,

a

carbon

adsorption

concentrator

in

conjunction

with

a

thermal

oxidation

control

device,

for

the

purpose of

this

RACT

analysis,

will

be

considered

a

technologically

feasible

control option that will

be

further

3.

Liquid Absorption

The

process

of

absorption generally refers to

the intimate contact

of a mixture of

gases with

a liquid sorbate

(typically

aqueous)

so that a part

of one or more of

the constituents

in

the gas stream will

dissolve in

the

liquid. These devices are

referred

to

generally

as

wet

scrubbers

and

they

include

packed

bed,

plate.

counter

current and

cross-current

designs.

The

most

effective

transfer result

for

art

infinite

scrubber

column is to

achieve

equilibrium

between

the

gas-phase

and

liquid-phase

compounds.

While

the

VOCs

used

at

Cromwell-Phoenix

are

soluble

in

an

aqueous

sorbate,

their

exhaust

concentrations

are

so low

that

the

scrubber

would

exhibit

a

very

low

transfer

efFiciency

of the gaseous VOCs into the liquid sorbate.

Also, given the polar nature of the organic materials at Cromwell-Phoenix, these

compounds would not

be readily

separable from

the sorbateliquid for purposes

of recovery.

Therefore, the only practical means of disposal would

be

discharge

to

the

sewer,

where

some

or

most

of

the

VOCs

that

were absorbed

may

re-

volatilize en

route to or at

the POTW.

For these reasons, it is concluded that

gas

absorption is

not

4.

Oxidation

Complete oxidation converts gaseous VOCs to carbon dioxide, water and

other

various

products of combustion,

Oxidation

systems

include direct combustion

flares,

as well as

two types

of commercially

available oxidation control systems

-

a.

Flares

---

1~)

Cromwell-Phoenix.

lnc

May

2~X13

tACT

Analysis

Page 5

A flare is a direct combustion device

in which air and the combustible gases

in

the

exhaust

stream

react

at

the

burner.

Combustion

must

occur

instantaneously

since

there

is

no

residence

combustion

chamber.

The

principal

factors

affecting

flare

combustion

efficiency are

the

exhaust

gas

heating

value,

flammability

limits, density and

effectiveness

of

flame

zone

mixing. If the concentration

of VOCs in

the exhaust is at or above the lower

flammability

level,

then utilization

of a

flare

may

be

appropriate.

For

this

reason,

flares

are

typically

used

only

in

the

steel,

petroleum

and

petrochemical industries, as they are inappropriate for most other industries

due to lower hydrocarbon concentrations. Since the expected exhaust stream

VOC concentrations

at Cromwell-Phoenix

will

be very low

(roughly

‘10

—

15

ppmv), flares are not a technically feasible option.

b.

Catalytic Oxidation

Catalytic

oxidation

devices

ernpk.y

a

catalyst

bed

that

initiates

oxidation

reactions

at relatively

low

temperatures.

The

exhaust

stream

is

heated

to

approximately 650°Fand passed through the catalyst bed where the oxidation

reactions are initiated without alteration of the catalyst itself. For the catalyst

to be effective, the active sites upon which the VOCs react must be accessible1

and the

catalyst must

be

active.

The

build

up of non-combustible particles.

polymerized

materials, or

reaction

of the catalyst with certain elements can

either

“mask”

or

“poison”

the

catalyst,

thus

making

it

unavailable

for

initiating oxidation reactions.

While

it would

be difficult to impossible to design a catalytic oxidation system

to

preclude

the

possibility

of

the

catalyst

being

masked

or

poisoned,

it

is

unlikely

that

the

materials

utilized

by

Cromwell-Phoenix

would

render

a

catalytic control device ineffective.

However, given the low concentrations

of

VOCs in

the exhaust stream,

the

temperature

rise across the catalyst bed

(Si’)

would be so low that a poisonedor masked catalyst would likely go undetected,

since there may not

be

a significantly discernible change in the

AT.

Therefore,

the ongoing performance of a catalytic oxidation system could not be effectively

ascertained. Despite these technical concerns,and (or purposes of completeness,

catalytic oxidation will

be considered a technically

feasible control

option

that

will be furtherevaluated.

c.

Thermal Oxidation

Thermal oxidation is a reliable and effective control technology that converts

gaseous

VOCs

to

carbon

dioxide,

water

and

various

other

products

of

combustion

at

relatively

high

temperatures,

typically

1350

-

1800°F. The

exhaust gases are

preheated in

a heat

exchanger and then

directed

into

the

high

temperature combustion chamber where the VOCs are oxidized,

in

the

case

of

Cromwell-Phoenix,

the

VOC

concentration

will

be

well

below

the

level

that

is

necessary to provide

any

appreciable

degree

of

self-sustained

combustion.

Therefore,

a supplemental fuel

burner system must

be

utilized.

---

C)

(7)

Cromwell-Phoenix,

nc.

May 2~O3

RACTAnalysis

Page 6

Primary

heat

exchangers

can

be

used

to

raise

the inlet

temperature

of

the

exhaust stream, thus reducing the amount of supplemental fuel required.

Two

categories

of

thermal

oxidizers

are

generally

used:

Recuperative

and

Regenerative. A recuperative thermal oxidizer uses either a shell-and-tube or

a

plate-to-plate

heat

exchanger

for

heat

recovery,

while

a

regenerative

thermal oxidizer uses a ceramic medium that is usuallystored

in twoor more

separate chambers.

Some regenerative thermal oxidizers employ a single bed

design with a mobile high temperature oxidation zone. The recuperative-type

thermal

oxidizers operate with a heat

exchanger effectiveness of up

to 70,

while

regenerative

thermal

oxidizers

employ

heat

exchangers

having

an

effectiveness of up to 95.

Both

of

these

types

of

thermal

oxidizers

are

technologically

feasible

for

application

at

Cromwell-Phoenix.

Since

the

exhausts

will

contain

low

concentrations

of

VOCs

at

ambient

temperatures,

the

regenerative

thermal

oxidizer will likely

be

the more appropriate control

option from

an

economic

stand point. This is dueto its greater energy recovery capability. However, both

recuperative

and

regenerative

control

systems

will

be

further

evaluated

as

technologically feasible options.

Also, the recuperative system will be evaluated

Ior usein conjunction with the carbon adsorption pre-concentrator.

B.

Proposed Efficiency Level of Add-onControls Which Constitute RACT

Based on the majority of RACT determinations, and

on the control device efficiency

requirements of

35 MC

Part 218

Subparts F and

H, a

minimum 90

VOC control

efficiency

will

be required

of an add-on

control

device.

In

addition, a minimum

overall

control

efficiency

of

81

is

required

to

meet

the

Subpart

F

RACT

requirements,

therefore

the

capture

efficiency

should

be

at

least

90

(Overall

Control

Efficiency

(81)

=

Capture

Efficiency

(90)

x

Control

Device

Efficiency

(90)).

To

ensure

the

achievement

of

a

minimum

90

capture

efficiency,

a

permanent

total

enclosure

(PTh) would

likely

need

to be established

for the

three

coating operations, and perhaps also to include the mixing tank.

The costs (or such

an enclosure are

included in

order

to present a complete RACT cost analysis.

An

approximation of the cost to fabricate a Permanent Total Enclosure is $137,000.

For

purposes

of this RACF analysis, it

is assumed thata control device efficiency of 90

with

100

VOC

capture

efficiency

are

achieved, and the

costs

of

fabricating

and

exhausting a

Permanent

Total Enclosure are included.

C.

Elimination of Technically Infeasible VOC Control Options

On the

basis of the criteria described above

in Section

C,

the following

VOC

control

options have been determined to be technically infeasible:

---

0

L)

Cromwell-Phoenix. Inc.

May 2003

RACF Analysis

Yage 7

1.

Condensation

2.

Liquid Absorption

3.

Flares

Therefore, these control options will not be further evaluated.

D.

Ranking of Remaining Control Technologies

The remaining

three

control technologiesare ranked below in Table I

in the order of

control effectiveness:

Table

Range of Control

Control Level for

Pollutant

Technology

Efficiency

()

RACT Analysis

VOC

Recuperative Thermal

90-99

?

90

Oxidation

VOC

Regenerative Thermth

90-98

?

90

Oxidation

VOC

Catalytic Oxidation

90-98

?

90

VOC

Carbon Adsorption

90-98

?

91)

Concentrator with

Thermal Oxidation

Cont to C

E.

Evaluation of the Most Effective Control Technologies Not Eliminated

The

most

effective

remaining

control

options

were

evaluated

relative to

energy,

environmental and economic impacts.

1.

Economic Impacts

The economic impacts of the above control options were evaluated in accordance

with

the

IJSEPA’s

OAQPS

Control

Cost

Manual,

by

William

M.

Vatavuk.

Economic

analyses

were

calculated

using

the

most

current

(1999)

version

worksheets

provided

by

Mr.

Vatavuk.

The

economic analysis

anticipates

the

installation of a single control device for

all controlled processes since this is the

most

cost

effective

means

of

control.

It

should

be

noted

that,

while a single

control

device

will

exhibit

the

lowest

economic costs

for add-on

controls

on

a

$/

ton

of

pollutant

controlled

basis,

such

a

configuration

poses

potential

---

0

1)

Cromweil-Phoenix, Inc.

May2003

RAa Analysis

Page 8

problems

from

an

operational

standpoint.

For

example,

it

would

be

unacceptable to have to shut down all of the controlled

operations if the control

device requires preventive

maintenance,

or

should

it

malfunction.

Also, some

costs such

as ductwork are more substantial

for a central unit than for multiple

control devices.

Ductwork costs have not

been included

in this

RACT analysis.

Therefore, while a single

central device is

the

most cost effective configuration,

operational and ancillary

(actors need to

be considered

for an overall

feasibility

determination.

Given the outcome of this report, such further in-depth analysis

is not warranted at this time.

Total annual costs were determined for the purchase, installation and operation

of each of the control devices considered.

The total exhaustair flow rate is based

on

the

sum

of the exhaust requirements

of each

of

the controlled sources.

The

annual

cost

calculations

for

each

of

the

control

technologies

evaluated

are

included herein.

The

results of the economic cost

analyses

for the control

options

evaluated

are

summarized

below in Table 2. The annual costs for the control devices are based

on an

expected

life of

10 years and

art annual interest rate of 7.0.

All analyses

are

based

on

90

control

of

the

allowed (potential)

VOC

emissions

that were

reflected

in the March 2002 CAAPP permit application (Exhibit

200-1) for the Ci

coating operations, including the flexo inks and mixing tanks (Total

16.9 tpy).

Therefore, the annual controlled amount of VOCs is calculated at15.21

tons.

Table 2

RACT Analysis

—

Overall Plant

Annual Cost per Ton

Control Option

IQ1~I

Annual ~çost

($)

of V9çControlled

1$)

Recuperative Thermal

1,075,713

70,724

Oi’qdizer

Regenerative Thermal

4~412

30,796

Oxidizer

558,670

36,730

Catalytic Oxidizer

Carbon Adsorber

376,942

24,783

Concentrator with

a Thermal Oxidizer

---

0

0

Cromwell-Phoenix. Inc.

May

2003

RACT

Analysis

Page

9

Based on

the

annual

costs

per

ton

of

VOCs

controlled

for

each

of

the

control

options

described

above,

none

of

the

control

options

are

deemed

to

be

economically

feasible.

Including

the

costs for the installation

of

ductwork and

compliance demonstration of the control

device and the total

enclosures would

only add

to the economic infeasibility of each option. Therefore,

the actual costs

per ton

of implementing any of

the above control

options

will

be even higher.

Finally, as

was stated earlier,

while

the

utilization

of

a single

centrally-located

control

device

is

the

most

economically

feasible

option,

it

may

not

be

operationally feasible due to both

anticipated

and unanticipated

shut

downs of

the

control

device.

If

only

a

single

control

device

were

employed,

normal

preventive

maintenance

requirements

or

an

equipment

malfunction

would

require

the

shutdown of

all

Cl

coating operations.

Clearly,

this would

not

be

acceptable from

a production and customer requirement standpoint.

Therefore,

for operational purposes, multiple conliol

devices would

have to

be

employed

whose costs will be higher than the lowest cost option described

above.

2.

Environmental and Energy Impacts

To accomplish

the

annual

control of the 15.21 potential

loris of VOCs using the

most economical control option, approximately

13.5 million cubic feet of natural

gas

will

be burned, resulting in emissions of over 800 tons of

CO2

(a greenhouse

gas),

0.67

tons

of NO~(an

add

rain

precursor, criteria

pollutant

and an ozone

precursor) and

0.57 tons of CO (an acute toxic and criteria pollutant). In addition,

over

120,000

kWhr

of

electricity

will

be

consumed

annually.

Therefore,

the

deleterious

energy and environmental

impacts would

be

substantial, while the

benefits of VOC reduction would be minimal.

P.

Selection

of

the Most Effective Control Option Not Eliminated

All of the most effective control

technology options not

technically eliminated have

been

shown

to

be

economically

infeasible

since

the

total

annual

costs

for

the

installation

and operation of the least costly option is approximately $25,000 per ton

of VOC controlled.

It should

be recalled that this cost does

not include

the cost of

ductwork nor does it reflect compliance demonstration costs (which could approach

$40,000

-

$50,000) or operationally

necessary multiple control devices. Therefore, the

actual control costs

will

be considerably higher.

In

addition, the initial

capital cost

and the substantial annual operating costs would put Cromwell-Phoenix at a serious

economic

competitive

disadvantage.

Therefore,

the

application

of

such

add-on

controls

would

be

detrimental

to

the

viability

of

this

plant.

Finally,

there

are

substantial

environmental

impacts

from

even

the

least

energy

intensive

control

option, including substantial

emissions

of

CO2 from

the combustion

of

the natural

gas fuel and VOCs.

C.

Alternative Strategy

to Achieve

RACT

---

0

1)

Cromwell-lThoenix. Inc.

May

2003

RACY

Analysis

Page

ID

Since the use of add-on controls has been shown to be

economically infeasible,

it is

proposed

to minimize VOC emissions by continuing to use

Cl

coatings that contain

the

lowest

levels of VOM

possible, while still achieving product functionality

and

quality, and minimizing VOM emissions

from

supplemental

drying. The use of non-

VOC solvents such as water, acetone and methyl acetate will be used

to the greatest

degree practicable.

---

C-P TRACT

Cost

Analysis.xls

5/16/2003

Company Name~ Cromwell-Phoenix,

Inc.

Location:

Alsip,

Illinois

Process:

CI Paper Coating Operations

TOTAL

ANNUAL

COST

SPREADSHEET PROGRAM

-

RECUPERATIVE

THERMAL

C’XIPIZERS

Describesthe

anxtua2.

operating

costs

for

purchasing,

installing

and

operating a recuperative thermal oxidizer to control the above process.

COST BASZ DATE: April 1988

ti)

VAPCCI

(2)

3rd Quarter 2001

101.8

INPITD

PARAMETERS

-

-

Gas flowrate

(sctm)

20000

--

Reference temperature

CoP):

77

- -

Inlet

gas temperature

(oP)

80

--

Inlet gas density (lb/sc~h

0.0139

--

Primary heat recovery

(fraction):

0.70

--

Waste gas heat content

(STU/saf)

:

0.061

--

Waste

gas heat content

(WtTJ/lb),

0.83

--

Gas heat capacity

(BTU/lb-oF):

0.255

--

Combustion temperature

(oF)

:

1600

- -

Preheat temperature

to?)

:

1144

- -

Fuel

heat of combustion

(ETtI/Ibi

:

21502

--

Fuel density

(1b/fta)

:

0.0408

DESIGN

PARA~IETERS

--

Auxiliary

Fuel

Reqrmnt

(ib/nirt)

10.842

(sctnt)t

265.7

--

Total Gas

flowrate

(scfm)

:

20266

CAPITAL COSTS

Page 1

of

4

Recuperative

---

C-F

It.ACT

Cost Analysis.xls

5/1612003

Equipment

Costs

($)

--

Incinerator:

s

0

heat

recovery:

0

@

35

heat recOvery:

0

S

SO I heat recovery:

0

S

70

heat recovery:

254,639

P’VE Containment or other capital coøts

total Equipment Cost--base:

254,639

—-escalated:

343,344

Instrumentation:

0

Sates tax:

10,300

Freight:

17,167

Purchased Equipment Cost

($)

405,145

Direct Installation Costs:

Foundations

& Supports:

32,412

Handling & Erection:

56,720

Electrical:

16,206

Piping:

8,103

Ductwork and Insulation:

4,051

Painting:

4,051

Direct Installation

Cost:

121,544

Site Preparation:

0

Buildings or Pfl:

t31~00O

Total Direct Coat:

663,689

Page 2 of

4

Recuperative

---

C-P RACT Cost Analysis.xis

5/16/2003

Indirect Installation costs:

Engineering:

40,515

Field Expenses:

20,251

Contractor Fees~

40,515

Start-Up:

8,103

Performance Test:

4,051

Contingencies:

12,154

Total Indirect Coat:

125,59S

Total

Capital Investment

($)

:

189,284

ANNUAL COST INPUTS

Operating factor

(hr/yr)

:

6760

Operating labor rate

C$/hr)

:

16.48

Maintenance labor rate

C$/hr):

18.13

Operating labor factor (hr/ahh

0.5

Maintenance

labor

factor

(hr/sb):

0.5

Electricity

price

1$/kwh):

0.069

Natural

gas

price

(s/macf):

6.00

Annual

interest

rate

(fraction):

0.070

Control

system

life

(years)

:

10

capital recovery factor:

0.1424

Taxes,

insurance,

admin.

factor:

0.04

Pressure drop

(in. w.cJ:

19.0

ANNUAL

COSTS

Item

Cost

($/yr)

Nt.

Factor

W.F.(cond.)

Operating labor

9,023

0.008

Supervisory labor

1,353

0.001

Maintenance labor

9,925

0.009

Maintenance materials

9,925

0.009

Natural gas

839,016

0.779

Electricity

45,367

0.042

overhead

13,136

0.017

0.045

Taxes,

insurance,

administrative

31,511

0.029

Page

3 of

4

Recuperative

---

C-P RACT

Cost Analysis.xls

5/16/2003

Capital

recovery

-

112,316

0.104

0.134

Total

Annual

Cost

1,075,713

1.000

1.000

tt)

Original

equiputent

costs reflect this date.

£2)

VAPCCI

—

Vatavuk Air Pollution Control Cost Index

(for thermal

incinerators)

corresponding to year and quarter shown.

Original

equipment cost, purchased equipment cost,

and total

capital investment

have been escalated to this

dAta

via

the

VAPCcI and control eqviptnent

vendor data.

Latest indexes included herein.

costs for

20000

RACT

Cost

Summary

Table

smfm

.y~tem

1 Purchased Equipment Coat

(PEC)

405,145

2 Total Direct Cost

(includes PEC)

663,689

3 total Indirect Cost

~

gg

4 tOtal Capital Investment

(—

2+3)

769,284

5 Annual Direct Operating Costs

913,630

6 Annual

Indirect

Operating

Costs

49,701

7

Annual

Capital

Recovery

Costs

1l2.~7~

8

total

Annual

Costs

I—

5+6+7)

1,015,713

Oxidizer

VOC

Control

Efficiency

90

1

Annual

VOC

Input

to the Control Device

16.9 tong

Annual

VOC

Emissions

Controlled

15.21

Annual

‘0C Emissions after Controls

1.69

Annual Cost of Control Device

$

70,124

S/ton Controlled

Page

4

of 4

Recuperative

---

C-PRACT Cost Analysis.xls

5/1

612003

Company

Name:

Cromvell-Phoenix,

Inc.

Locationt

Alsip, tilinois

Process:

CI Paper Coating Operations

TOTAL

AN$tJAj.

COST SPREADSUEET PROGRAM- -REGENERATIVE

THERMAL

OXIDIZER

(flO)

Describes the annual operating costs for purchasing,

installing and

operating a regenerative thermal oxiditer to control the above process.

COST BASE DATE:

DeCember 1988

£11

VAPCCI

12)

3rd

Quarter 2001

110.8

INPUT

PARAMETERS

- -

Gas

flowrate

(scfrn)

20000

- -

Reference temperature

(OF)

:

77

- -

Inlet gas temperature

(oF):

60

-

-

Inlet gas density

(lb/scf)

:

0.0739

- -

Primary

heat recovery

(fraction)

:

0.95

--

Waste gas heat content

(ETtJ/scf)

:

0.061

-.

Waste gas heat content

(BtU/lb)

:

0.83

- -

Gas heat capacity (STU/th-oF)

:

0.265

-.

Combustion temperature

(OF)

:

2000

--

Heat

loss

(traction)

:

0,01

- -

exit

temperature

(oF):

176

-

-

Fuel heat of combustion

(BTU/1b):

21502

--

Fuel density (lb/ft3);

0.0406

DESIGN

PARAMETERS

Auxiliary

Fuel Requirement

(lb/mm)

:

1.966

(scfm)

:

48.2

total

Gas

Flowrate

(sctm):

20048

Page

1 of

4

Regenerative

---

C-P RACT Cost Analysis.xls

5/18/2003

TOTAL

CMIT~.L INVESTMENT

(5)

(31

(Cost correlations range:

5000 to 500,000 scfm)

PTE Containment Or other capital costs

137000

35

1 heat recovery--base:

0

--escalated:

0

e 95

1

heat recovery--base:

1,016,304

--escalated:

1,368,558

ANNUAL

COST

INPUTS

Operating factor

(hr(yr):

6760

Operating labor rate

($fhr)

:

16.48

Maintenance labor rate

(S/hr)

:

iS.13

Operating labor factor

(hr/sb)

0.50

Maintenance labor tactor

(hr/wk)

:

1.00

Electricity price

(S/kwh)

:

0069

Natural gas price

($/mect)

:

6.00

Annual interest rate

(fraction)

:

0.070

Control system life (years)

:

10

Capital recovery factor:

0.1424

Taxes, insurance,

admin.

factor:

0.04

Pressure drop

(in.

.t.c.):

20.0

ANNUAL COSTS

Itew~

Cost

($/yr)

~4t.Factor

W.F.(cond.)

Operating

labor

9,023

0.019

- -

- -

Supervisory labor

1,353

0.003

-

- - -

Maintenance labor

943

0.002

-

- -

-

Maintenance materials

943

0.002

Natural gas

151,939

0.324

Electricity

47,260

0.101

Overhead

7,357

0.016

0,042

Taxes, insurance, administrative

54,742

0.117

Page? of 4

Regenerative

---

C-P RACT Cost Analysisids

5/16/2003

capital recovery

194,852

0,416

0.533

Total

Annual

coat

468,412

1.000

1.000

(11

Base total capital investment

reflects this date.

(2) VAPcCZ

a

Vatavuk Air Pollution Control Cost

Index

(for regenerative

thermal oxidizers)

corresponding to year and quarter shown.

Base

total capital investment

has been escalated to this date via VAPCCI and

control equipment vendor data.

Latest indexes included herein.

£3)

Source: Vatavuk, William

t’L

ESTIMATING COSTS OF AIR POLLUTION

CONTROL.

Boca Raton,

FL: Lewis publishers,

1990.

COMPARISON OF REECO/DUPONT, COsT-AIR,

AND

MANUAL. RTO

COSTS:

(1stQtr. ‘91

$)

Flew

(scfm)

REECo (5)

Manual (5) (aj

ManualfREECo

COST-AIR ($) bj

C-PJREECo

2,000

340,000

371,061

1.09

640,305

1,88

5,000

425,000

423,946

1.00

713,363

1.68

10,000

500,000

512,067

1.02

835,125

1.67

25,000

850,000

776,511

0.91

1,200,413

1.41

50,000

1,500,000

1,217,217

0.81

1,809,225

1.21

100,000

2,850,000

2,098,629

0.74

3,026,850

1.06

a

Escalated

from AprU. ‘88 to

1st quarter ‘91 and rnuttiplked

by ~nstaILat¾on

factor of 1.416(1.21.18).

Range

of correlatIon; 10,000

to

100,000 scfm.

(b~Escalated

from Dec. ‘88 to 1st quarter ‘91,

Costa petta~nto 95

heat recovery

units.

Range of correlation:

5,000

to

500,000

scfm.

PageS of

4

Regenerative

---

C-P RACT

Cost Analysis.xls

5/16/2003

Costs for

20000

RACT

Cost Summary Table for RTO

sr’fm

svcten

1 Total Capital Xnvestinent

1,368,558

2 Annual Direct Operating Costs

211,461

3

Annual

Indirect Operating Costs

62,099

4 Annual Capital Recovery Costs

1S4.aS2

S Total

Annual

Costs

(s

2+3.4)

468,412

Oxidizer

voc

control

Efficiency

90 1

Annual

VOC

Input

to

the

Control

Device

16.9

tons

Annual

VOC

Emissions

controlled

15.21

Annual

VOC

Emissions after Controls

1.69

Annual Cost of Control Device

$

30,796

S/ton Controlled

3

Page 4 of

4

Regenerative

---

C-P

RACT Cost Anatysis.xts

Sf16/2003

Company

Name:

Cromwell-Phoenix,

Inc.

Location~

Alsip,

Illinois

Process:

CI Paper Coating Operations

TOTAL

ANNUAL

COST SPREADSMEET PROGRAM-

-CATALYTIC INCINERATORS

(FIXED)

Describes

the annual operating costs for purchasing,

installing

and

operating

a

Catalytic

Oxidizer

to

control

the

above

process.

cos’r

REFERENCE

DATE;

April

1988

(11

VAPCCI

2)

3rd

Ouarter200l

109.8

INPUT

PARAMETERS

--

Gas

flowrate

(ectin),

20000

-

-

Reference temperature

(OF)

:

77

- -

Inlet

gas

temperature

(oF)

80

-

-

Inlet gas density

(th/scf)

0.0739

- -

Primary heat recovery (fraction)

:

0.70

--

Waste gas heat content

(8TU/scf);

0.061

-

-

Waste gas heat content

(BTtJ/lb)

0.83

- -

Gas heat capacity

(anT/lb-oF)

0248

-

-

combustion

temperature

(oF)

:

650

- -

Preheat temperature Con

:

479

--

Fuel heat of combustion

(BTTJ/lb):

21502

--

Fuel density (lb!ft3):

0,0408

DESIGN

PP.RA1IETERS

- -

Auxiliary

Fuel

Reqrmnt

(lb/mm)

:

3.870

(scfm)

;

94.9

- -

Total Gas Flowrate

(scfm),

20095

--

catalyst Volume

(ft3)

:

38.9

Page

1

of

4

Catalytic

---

C-P RACT

Cost Analysis.xls

5/16/2003

CAPITAL

COSTS

Equipment

Costs

(S)

-

-

Incinerator:

@

0

1

heat

recovery:

0

@

35

1

heat

recovery:

0

e

50

heat recovery:

0

‘5 70 1 heat recovery:

344,811

--Other (auxiliary equipment,

etc.):

C

Total

Equipment

Cost--base:

344,811

I

--escalated:

409.261

Instrumentation

40,926

Sales

Tax

12,278

Freight

20,463

Purchased

Equipment

Cost

(5):

482,928

Direct Installation Costs:

Foundation

&

Supports

38,634

Handling

&

Erection

67,610

ElectrIcal

19,317

Piping

9,659

Ductwork

&

Insulation

4,629

Painting

4,829

Buildings

or

PIE:

137,000

Total

Direct

Cost:

164.801

Indirect

Installation

Costs:

Engineering

46,293

Field

Expenses

24,146

Contractor Fees

48,293

Start-Up

9,659

Performance Test

4,829

Contingencies

14,488

Totsl

Indirect

Costs,

3,49,709

Page 2 of

4

Catalytic

---

C-P tACT

Cost Artalysis.xls

5/16/2003

total

Capital

Investment

CS)t

914.fl4

AE~1UAL

COST

INPUTS

Operating factor

(hr/yr)

:

8760

Operating labor rate

(S/lw)

:

16.48

Maintenance labor rate

($/hr)

:

18.13

Operating labor factor

(hr/sh)

:

0.0

Maintenance labor factor

Chr/sh)

:

0.5

Electricity price

(S/kwh):

0.069

Catalyst price

(S/fta):

650

Natural

gas

price

(Sfmscf)

6.00

Annual

interest

rate

(fraction):

0.07

Control

system

life

(years)

:

10

Catalyst

life

(years)

:

2

Capital

recovery

factor

(system)

:

0.1424

Capital

recovery

factor

(catalyst)

0.5531

Taxes,

insurance,

admin.

factor:

0.04

Pressure

drop

(in.

w.c.,l:

21.0

ANNUAL

COSTS

Itexn

Coat

($fyr)

t’lt.

Factor

W.?.(cond.)

Operating

labor

0

0.000

Supervisory

labor

0

0.000

Maintenance

labor

9,925

0.018

Maintenance

materials

9,925

0.018

Natural

gas

299,160

0.535

Electricit.y

49,742

0.089

Catalyst

replacement

15,110

0.027

Overhead

11,910

0,021

0.057

Taxes,

insurance,

administrative

36,581

0.065

Capital

recovery

126,317

0.226

0.292

Page 3

of

4

CatalyUc

---

C-P RACT Cost Analysis.xls

Total Annual Cost

558,670

1.000

1.000

(13

Original equipment coats reflect this date,

(2) VAPCCI

—

Vatavuk Air Pollution Control Cost Index

(for catalytic

incinerators) corresponding to year and quarter

shown,

Original

equipment coat,

purchased equipment cost, and total capital investment

have been escalated to this date via the VAPCCI and control equipment

vendor data,

~ACT

Cost Summary Table

5/1612003

1

Purchased

Equipment

Cost

(PEC)

2 Total Direct Cost

(includes PEC)

3 Total Indirect Cast

4 Total Capital Investment

(.

2.3)

482,928

764,807

149.708

914,514

5 Annual Direct Operating Coats

6 Annual

Indirect Operating Costs

I Annual Capital Recovery Costs

8 Total Annual Costs

(-

5.6,7)

383,863

48,491

126.317

558,670

Oxidizer

VOC Control Efficiency

(1)

Annual

VOC

Input

to

the

Control

Device

Annual

VOC Emissions Controlled

Annual

VOC

Emissions

after

Controls

Annual Cost

of

Control

Device

90

16,9

tons

15.21

tons

1 .69 tons

36,730

per tOn controlled

Page4of

4

Catalytic

---

C-P RACT Cost Analysis.xls

5/16/2003

Company

Name:

Cromwell-Phoenix,

Inc.

Location:

Alsip,

Illinois

Processt

CI Paper Coating Operations

TOTAL

ANNUAL

COST

SPREADSHEET

PROGRAM-

-

CARBON

ADSORBER

CONCENTRATOR

w/THEPJIAI.,

OXIDIZER

This spreadsheet describes the annual operating costs for a carbon adsorption concentrator system

operating in conjunction with a recuperative thermal oxidizer controlling the 10

desorption stream,

STAnE

I VOC

~WMOVAt

-

C1fl~ON AflSflR~’R rn!Knn’RATOR

COST BASE DADZ:

Third Quarter 1989

(2)

VAPCCI

3

3rd Quarter 2001

105.7

INPUT

PARAMETERS:

—-

Inlet stream flowrate

(acfm)

:

20000

- -

Inlet stream temperature

(OF)

80

- -

Inlet

stream

pressure

(atm)

:

1

--

VOC

to

be

condensed:

Propylene

Glycol

--

Inlet

VOC

flowrate

tlb/hr)

:

3.86

--

VOC molecular

weight

(lb/lb-mole):

16.10

--

VOC

inlet

volume

fraction:

l.665512E-05

--

VOC

inlet

concentration

(ppmvh

16.7

--

VOC

inlet partial pressure

(psia):

0.0002

--

Required ‘ICC removal

(traction)

:

0.950

- -

Freurtdlich isotherm equation constants for VOC

(see Table

1 below)

‘ICC number

(enter Table

1

or zero,

i:

1011

K:

0.412

H:

0.389

--

laws

isotherm

equation

constants

(see

Table

2

below)

VOC

number

(enter

Table

2

#or

zero,

if

84

1.40474

0.18738

-0. 02663

--

Adsorption

time

(hr)

:

8.0

--

Desorption time

(hr)

:

4.0

--

Number

of

adsorbing

vessels;

2

--

Superficial

carbon

bed

velocity

(ft/mm)

:

75

--

Carbon

price

($/lb)

3.00

Page

1 of

10

Carbon Adsorber- Recup

---

C-P RACT

Cost Analysis.xls

5/16/2003

--

Material

of

construction

(see

list

below):

41

1.3

DESIGN

PARAMETERS:

--

Carbon equilibrium capacity--Freundlich

(lb VOC/lb

0.0162

0.3926

--

Carbon working capacity

(lb VOC/lb carbon):

0.0081

--

Number of desorbing vessels:

2

--

Total number of vessels:

4

-

-

Carbon requirement,

total

(ib)

:

7611

-

-

Carbon requirement per vessel

(1b)

:

1903

--

Gas

fLowrate

per

vessel

(acfm);

10000

--

Adsorber vessel diameter

(ft)

:

13,029

--

Adsorber vessel length

(ft)

:

4.476

--

Adsorber vessel surface area

(ft2):

449.87

--

Carbon

bed

thickness

(ft)

:

0.476

--

Carbon

bed

pressure

drop

(in.

w.c.):

(5

1,609

CAPITAL COSTS

Equipment

Costs

($)

--

Adsorber

vessels

163,333

--

Carbon

22,833

--

Other equipment

(condenser, decanter,

etc.)

135,321

Total

equipment

cost

($)--base:

290,259

•

--escalated:

340,246

Instrumentation:

34,

025

Sales

Tax:

10,207

fleight:

17,012

Purchased

Equipment

Cost

(5)

:

401,490

Direct

Installation

Costs:

Foundations

&

Supports:

32,119

Handling

&

EreCtion:

56,209

Electrical:

16,060

Piping:

8,030

Ductwork

and

Insulation:

4,015

Painting:

4,015

Direct

Installation

Cost:

120,447

Page

2 of

10

Carbon Adsorber

-

Recup

---

C-P

RACT Cost Ana!ysis.xls

5/16/2003

Site

Preparation:

suildings

or

PTE

Constr:

137,000

Total Direct cost:

658,937

Indirect Installation Costs;

Engineering:

40,149

Field

Expenses:

20,074

Contractor Fees:

40,149

start-Up:

8,030

Pertornanct

TeSt:

4,015

contingencies:

12,045

Total Indirect Coat:

124,462

Total Capital Investment

CS):

783,399

($/acfm)

:

39.2

ANNUAL

COST

INPUTS:

Operating

factor

(hr/yr)

:

8760

Operating labor rate

($/hr):

16.48

Maintenance labor rate

(5/br):

18.13

Operating

labor

factor

(hr/sb):

0.5

Maintenance

labor

factor

(hr/sb):

0.5

Electricity

price

($/kwhr)

:

0.069

Recovered

VOC

value

(S/tb):

0.0000

Steam price

($11000

ib)

:

7.50

Cooling water price

($/1000 gal):

0,20

Carbon replacement labor

(S/lb):

0.05

Overhead rate

(fraction):

0.6

Annual interest rate

(fraction):

0.070

Control system life

(years)

10

Capital recovery factor

(system):

0.1424

Carbon life

(years)

:

$

Capital recovery factor

(carbon):

0.2439

Taxes,

insurance,

adtnin.

factor;

0.04

PageS of

10

Carbon

Adsorber

-

Recup

---

C-P RACT

Cost Ana1ysis~ds

5/16/2003

ANNUAI~

COSTS:

Item

Cost

($/yr)

Wt.

Factor

W.F.(cond.)

Operating

labor

9,023

0.045

Supervisory

labor

1,353

0.007

Maintenance

labor

9,925

0.050

Maintenance materials

9,925

0.050

Electricity

3,785

0.019

Steam

987

0.004

Cooling water

81

0.000

Carbon

replacement

6,107

0.031

Overhead

18,136

0.091

0.244

Taxes, insurance, administrative

31,336

0.158

Capital recovery

107,973

0.544

0.702

Sub-Total Carbon Adsorber Annual Costs

198,531

1,000

0.964

Recovery credits

0

Carbon Adsorber Annual Costs

(wJcredit)

198,531

(S/million act)

18.89

Notes:

(11

This

program

has

been

based

on

data

and

procedures

in

Chapter

4

of the OAQPS CONTROL COST MMWAL

(5th edition)

(2)

Ease

equipment

costs

reflect

this

date.

33

VAPCCI

—

Vatavuk

Air

Pollution

Control

Cost

Index

(for

carbon

adsorbers)

corresponding

to

year

and

quarter

shown.

Ease

equipment

cost,

purchased equipment cost,

and total capital investment have been

escalated to this date via the VAPCCI and control equipment vendor data.

4

Enter one of

the following:

carbon steel--’l’; 316 stainless steel--

‘1.3’;

Carpenter

20

(ca-3)--1.9’1

Monel-400--’2.3’;

Nickel-200--’3.2’;

titanium--

‘4.5’

5)

This

is the carbon bed pressure drop

ONLY.

There will be additional pressure drop

through the ductwork

.

For estimating ductwork pressure losses,

see Chapter 10

of

the OAQPS CONTROL COST MANUAL

(5th edition)

Page

4 of

10

Carbon Adsorber

-

Recup

---

C-P RACT Cost Anaiysis.xis

5/16/2003

Table

1.

Preundlich

Constants

thr

Selected

compounds

¶6)

Correlation Range

(psia)

VOC

VOC

nutnber

K

M

Temperature

(F)

Minimum

Maximum

Benzene

1002.

0.597

3.176

77

0.0001

0.05

Chlorobenzene

1002

1.05

0.186

77

0.3001

0.01

Cyclohexane

1003

0.508

0.210

100

0.0001

0.05

Dichioroethane

1004

0.976

0.281

77

0,0001

0.04

Phenol

1005

0.855

0.153

104

0.0001

0.03

Trichj.oroethane

1006

1.06

0.161

77

0.0001

0.04

Vinyl

chloride

1007

0.200

0.477

100

0,0001

0.05

tn-Xyltne

clow-presware

1009

0.108

0.113

77

0.0001

0.001.

m-Xylene

(high-pressur

1009

0.521

0.0703

77

0.001

0.05

Acrylonitrile

1010

0.935

0.424

100

0,0001

0.015

Acetone

1011

0.412

0.389

100

0.0001

0.05

Toluene

1012

0.551

0.210

77

0,0001

0.05

6)

These constants fit the following equation:

Q

-

K(PLAM

where:

Q

equilibrium adsorption capacity (lb/lb carbon)

P

—

VOC partial pressure

(psia at

1 atm

& listed temperature)

*t*~*4****

**fr****t*t******fr*fr*t*4**4***~*****

Table

~.

Correlation Constants for Yaws Isoth Correlation Ranges

(ppn’tv)

vOC

VOC

number

A

B

C

Minimum

Maximum

Phosgene

6

-0.64469

0.60428

-0.02986

10

10000

Carbon tetrachloride

9

1.07481

0.28186

0.02273

10

10000

Chloroform

11

0.67102

0,36148

-0.02288

10

10000

Formaldehyde

18

-2.48524

0.69123

-0.00375

10

10000

Methyl

chloride

21

-1.91871

0.62053

-0.00549

10

10000

Carbon disulfide

35

-0.18899

0.47093

-0.01481

10

10000

tetrachioroethylene

39

1.40596

0.20802

-0.02097

10

10000

Vinyl chloride

55

-0.98889

0.66564

-0.04320

10

10000

1,1,2-Trichloroethane

59

1.17163

0.27791

-0.02746

10

10000

PageSot

10

Carbon Adsorber- Recup

---

C-P RACT

Cost Anaiysis.xls

5/16/2003

Acetonitrile

60

-0.79666

0.63512

-0.02598

10

10000

Methyl

isoc-yanate

61.

-1.07519

0.85881

-0.06816

10

10000

Acetaldetiyde

69

-1.17047

0.62766

-0.02475

10

10000

Ethylene glycol

84

1,40414

0.28738

-0.02663

10

121