Amendment to Missouri Air Permit No. 012005-008 (as ...speciation for the reverberatory furnace was...

Amendment to Missouri Air Permit No. 012005-008 (as amended) to

Account for Condensable Particulate Emissions

Best Available Control Technology Analysis for Total PM10

Prepared For:

Buick Resource Recycling Facility

18594 Hwy KK

Boss MO 65440

Prepared By:

Shell Engineering & Associates, Inc.

2403 West Ash

Columbia MO 65203

August 5, 2015

i

Table of Contents

Table of Contents ................................................................................................. i List of Tables ....................................................................................................... ii List of Figures ..................................................................................................... ii 1.0 Introduction .................................................................................................. 1

1.1 Overview .................................................................................................... 1

1.2 Site Location ............................................................................................... 2

1.3 Process Description ................................................................................... 3

2.0 Condensable Particulate Emission Estimates .......................................... 7

2.1 Overview .................................................................................................... 7

2.2 Main Stack.................................................................................................. 8

2.3 BSN Scrubber .......................................................................................... 11

2.4 Propane Combustion ................................................................................ 11

3.0 Best Available Control Technology .......................................................... 13

3.1 Overview .................................................................................................. 13

3.2 Identification of Potential Control Technologies........................................ 13

3.3 BACT Selection ......................................................................................... 14

3.3.1 Reverberatory Furnace (Main Stack) ................................................. 14

3.3.2 Blast Furnace ..................................................................................... 15

3.3.3 Sweat Furnace ................................................................................... 16

3.3.4 BSN Process ..................................................................................... 18

3.3.5 Propane Combustion ......................................................................... 18

4.0 Conclusion ................................................................................................. 31

Appendix A. RBLC Search Results ................................................................ 33

ii

List of Tables

Table 3-1. Reverberatory Furnace Technology Review ................................ 21

Table 3-2. Blast Furnace Technology Review ............................................... 23

Table 3-3. Dry Scrubber Annual Cost Effectiveness Detail .......................... 26

Table 3-4. Sweat Furnace Technology Review .............................................. 28

Table 3-5. BSN Process Technology Review................................................. 29

Table 3-6. Propane Combustion Technology Review (Dross and Refinery Kettle Heat Stacks) ........................................................................................... 30

Table A-1. RBLC Process Code 82.590, Lead Products and Smelting, January 2004 to Present ................................................................................... 33

Table A-2. RBLC Process Code 13.310, Boiler/Furnace <100 MMBTU/hr, Natural Gas (including propane and LPG), January 2004 to Present ........... 35

List of Figures

Figure 1-1. General Facility Location ............................................................... 5

Figure 1-2. Facility Layout ................................................................................. 6

Figure 3-1. Blast Furnace Least Cost Envelope ............................................ 25

1

1.0 Introduction

1.1 Overview

The Doe Run Company's Buick Resource Recycling Facility (BRRF) is located in

northwest Iron County, Missouri approximately 3 miles east of Boss. The facility

was issued a PSD permit in 2005 (permit no. 012005-008, project no. 2001-10-

058) by the Missouri Department of Natural Resources (MDNR). The purpose of

the permit was to eliminate the annual production limits on the individual furnaces

and increase the facility-wide production to 175,000 ton/yr (lead cast). Special

condition no. 5 to the original permit set an emission limit of 30.57 tons of

filterable and condensable particulate matter less than 10 microns (PM10) from

the installation in any rolling twelve month period.

The permit was amended in 2007 (permit no. 012005-008A, project no. 2007-06-

053). The installation total PM10 limit was replaced with a main stack only

emission limit. Special condition no. 4 to the amended permit set an emission

limit of 9.2 tons of filterable and condensable particulate matter less than 10

microns (PM10) from the main stack (EP-08) in any rolling twelve month period.

According to the permit file, the emission limit was calculated based off a

maximum annual production of 175,000 ton/yr and a controlled PM10 emission

factor of 0.105 lb-PM10/ton-Pb-Produced.

12-month Main Stack PM10 Limit (permit 012005-008A) =

175,000 (ton/yr) * 0.105 (lb-PM10/ton) / 2000 (lb/ton) =

9.2 ton-PM10/yr

The emission factor used in the calculation above is representative of only the

filterable fraction of the PM10 emissions which account for approximately 15% of

the total PM10 (filterable + condensable). Special condition no. 4 to the

amended permit specifically states that the annual emission limit is based on

summation of the filterable and condensable components; however, the emission

factor used to develop the limit includes only the filterable fraction.

2

As specified in the permit, subsequent monitoring associated with special

condition no. 4 was based on stack test derived emission factors. The stack test

method used to develop the emission factors was method 201A (filterable PM10

only). It should be noted that the use of method 201A is believed to be fully

supported by the permit and was approved in the stack test protocols.

Furthermore, MDNR personnel has reviewed the permit file and determined that

it was the permit writer's intention that the limit was specific to the filterable

fraction and did not intend for the special condition to include the condensable

particulates. This has led to confusion in subsequent permitting.

Because condensable emissions were not directly considered as part of the

review associated with permit 012005-008, the MDNR has requested a control

technology review to ensure that the condensable controls employed by the

facility are considered Best Available Control Technology (BACT). It should be

noted that at the time the permit was originally issued in January 2005, PM10

BACT limits were exclusively specified for the filterable component only.

The MDNR specifically requested a review of each emission unit permitted under

012005-008 to determine if it is a source of condensable particulate. Next,

MDNR requested that a technology review be completed for each source of

condensable particulate to determine if existing control technologies in place

constitute BACT for total PM10 or if additional technologies are required pursuant

to the PSD regulations.

The purpose of this report is to document the control technology review for

sources of condensable particulate permitted under Missouri air construction

permit no. 012005-008.

1.2 Site Location

The facility is located approximately three miles east of Boss, MO in northwest

Iron County. The facility is approximately 90 miles southwest of St. Louis and

3

125 miles east of Springfield. The UTM coordinates of the facility referenced to

the 1983 North American Datum, Zone 15 are 664.8 km east and 4167.1 km

north. The elevation in the facility ranges from approximately 1,360 to 1,440 ft-

asl.

A map showing the general location of the facility has been provided as Figure 1-

1. A map showing the facility layout has been provided as Figure 1-2.

1.3 Process Description

The BRRF's secondary lead production operation is divided into three major

areas:

1. Raw Material Preparation & Separation

2. Smelting

3. Refining

The facility receives raw material in the form of large industrial batteries, small

automotive batteries, coke, limestone, silica, glass, scrap steel, scrap lead metal

and other lead bearing materials contained in various container configurations.

Batteries are shredded and drained . The shredded batteries are then sent

through a hydro-separation process which separates out the paste and plastic

from the posts, separators, grids and sediment.

Plastic components are washed and sold to be made into new battery cases.

The remaining battery parts, except acid and plastic, go to the reverberatory or

blast furnace. These two furnaces work together to recycle the lead containing

materials into lead bullion, which, after refining, can then be used by industry

again.

4

Lead bearing scrap is sweated in two propane-fired reclamation (sweat) furnaces

to separate lead from metals with higher melting points and non-metal

contaminants. This lead bullion is tapped from the reclamation furnaces for

further processing in the refinery.

Crude lead from the blast furnace, reverberatory furnace, sweat furnaces, and

remelt scrap is refined by softening, alloying and oxidation processes. These

processes are performed in the refinery in batch type kettles in order to achieve

the degree of purity or alloy type requested by the customer. After refining,

finished lead is cast into various sizes and shapes according to customer

specifications.

After casting, the product is then stored to allow final cooling and then is loaded

and shipped to the customer.

5

Figure 1-1. General Facility Location

4000

4200

4400

200 400 600 800

No

rth

ing

(UT

M-k

m)

Easting (UTM-km)

Kansas City

Springfield

St. Louis

Buick Resource Recycling Facility, LLCBoss, MO

6

Figure 1-2. Facility Layout

4166561

4166761

4166961

4167161

664311 664511 664711 664911 665111

No

rth

ing

(UT

M-m

)

Easting (UTM-m)

Battery Bunker

Paste Storage

Ref inery

Reverberatory Furnace

Main Stack

Blast Furnace

Blast Furnace Feed Storage

Covered Storage

Change House

Administration Building

Hammermill

Hydro Separator

Warehouse

Facility Boundary (Hwy KK)

7

2.0 Condensable Particulate Emission Estimates

2.1 Overview

A summary of particulate sources included in permit 012005-008 has been

provided below.

Point No. Source Description Condensable Emissions?

(Yes/No) Comment

8

Main Stack (reverberatory furnace, blast furnace,

sweat furnaces, refinery, and building ventilation)

Yes

16 BSN Scrubber Yes

18 Crystallizer No Emission point has been

eliminated.

19 Sodium Carbonate Surge

Bin Baghouse No

Emission point has been eliminated

21 Crystallizer Boiler Yes Emission point has been

eliminated.

22-23 Dross Kettles Yes

24-28 Refinery Kettles Yes

31A Drum Shredder Feed

Hopper No

Building ventilation baghouse operating near

ambient. No process combustion source

present.

31B Drum Shredder Hygiene

Baghouse No



present.

31C Drum Shredder Main

Baghouse No



present.

32 Laboratory Baghouse No

33 Changehouse Boiler Yes

Condensable PM emissions not considered for BACT because source

not modified for permit 012005-008

34 Main Shop Forge Yes Emission point has been

eliminated.

71 Reverb. Furnace Hygiene

Baghouse No


ambient

72 Rotary (Refinery North)

Furnace Baghouse No


ambient

8

Point No. Source Description Condensable Emissions?

(Yes/No) Comment

73 Sweat Furnace Baghouse No Building ventilation

baghouse operating near ambient

85 Wood Boiler Yes Emission point has been

eliminated.

57 Silo No Emission point has been

eliminated.

58 Material Blender No Emission point has been

eliminated.

10 Blast Furnace Building

Fugitives No

Building enclosed and evacuated to baghouse

near ambient

11 Dross Plant/Reverb.

Furnace Building Fugitives No

Building enclosed and evacuated to baghouse

near ambient

12 Refinery Building Fugitives No Building enclosed and

evacuated to baghouse near ambient

37 Resuspension No

74-79 Haul Roads No

13 Open Storage Fugitives No

2.2 Main Stack

The main stack (EP-8) is a source of filterable, inorganic and organic

condensable particulate matter. The primary sources routed to the main stack

are the blast furnace and the reverberatory furnace. The main stack also

receives process gases from the two sweat furnaces and refinery along with a

large volume of building ventilation air. The main stack was tested on 10/3/2012

and had a total PM10 (filterable and condensable) emission factor of 0.85 lb/ton

of lead produced. The speciation for the main stack was 8.5% filterable, 20.6%

organic CPM, and 70.9% inorganic CPM. The reverberatory furnace was tested

on 9/26-27/2012 and accounted for 13.3% of the main stack emissions. The

speciation for the reverberatory furnace was 26.9% filterable, 14.9% organic

CPM, and 58.2% inorganic CPM. The emissions from the blast furnace, sweat

furnaces, refinery and building ventilation were calculated by subtracting the

reverberatory furnace emissions from the total emissions emitted from the main

stack. The calculations have been summarized below:

9

Source Particulate Matter Type

Existing Control Device

Controlled PM10 Emission

Factor (lb/ton)

Fraction of Subtotal (%)


Filterable Baghouse 0.0303 26.88

Organic Condensable

Thermal Oxidizer 0.0168 14.93

Inorganic Condensable

Dry Scrubber with Fabric Filtration

0.0656 58.18

Subtotal: 0.1128 100.00

Blast Furnace, Sweat Furnace,

Refinery, Building

Ventilation


Organic Condensable

None 0.1583 21.47


None 0.5370 72.83

Subtotal: 0.7374 100.00

Main Stack (EP-08)

Filterable

Refer to Above

0.0723 8.51

Organic Condensable

0.1752 20.60


0.6027 70.89

Total: 0.85 100.00

A. Total controlled PM10 emission factor from 10/3/2012 stack test = 0.85 lb/ton (lead produced)

B. 13.3% of total PM10 assumed from reverb. furnace based on 9/2012 scrubber stack test

C. Main stack speciation from 10/3/2012 stack test (Filt 8.5%, OCPM 20.6%, ICPM 70.9%)

D. Reverb. Furnace speciation from 9/26-27/2012 dry scrubber stack test

(Filt 26.9%, OCPM 14.9%, ICPM 58.2%)

E. Blast furnace, etc. emissions calculated by difference.

The potential annual PM10 emissions from the reverberatory furnace were then

estimated using the emission factor from the stack test and a maximum annual

lead production rate of 175,000 ton lead cast/yr:

Potential Annual PM10 Emissions (Reverb) =

175,000 (ton lead cast/yr) * 0.1128 (lb/ton) / 2000 (lb/ton) =

9.87 ton/yr

The potential annual PM10 emissions from the blast furnace, sweat furnaces,

refinery, and building ventilation were then estimated using the emission factor

10

from the stack test and a maximum annual lead production rate of 175,000 ton

lead cast/yr:

Potential Annual PM10 Emissions (Blast Furnace and Sweat Furnace) =


64.52 ton/yr

The blast furnace and sweat furnace emissions were then apportioned based on

the average production rates from the 2013 and 2014 calendar years:

2014

(ton/yr) 2013

(ton/yr)

2013-14 Average (ton/yr)

Fraction of Total (%)

Blast Furnace Castable Lead Production

41242 42557 41900 91.71

Sweat Furnace Castable Lead Production

5327 2244 3786 8.29

Total 46569 44801 45685 100

Potential Annual PM10 Emissions (Blast Furnace) =

64.52 (ton/yr) * 0.9171 =

59.17 ton/yr

Potential Annual PM10 Emissions (Sweat Furnace) =

64.52 (ton/yr) * 0.0829 =

5.35 ton/yr

The reverberatory furnace was stack tested as a condition of Missouri Section (5)

permit no. 062011-004 in September 2012. Due to the installation of a thermal

oxidizer, particulate baghouse, and dry scrubber with fabric filtration on the

reverberatory furnace, the blast furnace represents the largest remaining source

of PM10 emissions. Approximately 87% of the PM10 emissions from the main

stack come from the particulate baghouse used to control the process emissions

from the blast furnace. In addition to the blast furnace, the baghouse also

ventilates two sweat furnaces and provides refinery kettle and building

ventilation.

11

The main stack was tested for condensable PM again in December 2013. The

condensable PM emissions from the main stack were approximately 70% less

than the October 2012 test. The higher of the two tests was used as the basis

for the BACT economic analysis.

2.3 BSN Scrubber

The BSN scrubber (EP-16) (formerly referred to as the BDC scrubber) is a

source of PM10 due to dust and acid mist emissions from the battery breaking

process. The maximum hourly filterable PM10 emissions for the scrubber are

0.283 lb/hr, which corresponds to a potential annual emission rate of 1.24 ton/yr.

Stack test data is not available for this source and an emission factor search did

not yield any data for condensable PM. It is known that sulfuric acid mist will

cause visible opacity at concentrations above 5 ppm. Facility personnel have not

witnessed visible emissions, besides water vapor, from this source. Therefore,

condensable emissions were calculated assuming a conservative H2SO4

concentration of 5 ppmv. At a standard flow rate of 30,000 scfm and 5 ppmv

H2SO4, the ideal gas model gives an hourly emission rate of 2.29 lb/hr. This

equates to 10.03 ton/yr at 8,760 hr/yr continuous production.

The total PM10 emissions are equal to 11.27 ton/yr (1.24 filterable + 10.03

condensable).

2.4 Propane Combustion

PM10 emissions from the combustion of propane were estimated from the

source specific MHDR and an emission factor of 1.106 lb/Mgal (FIRE, SCC

10201002). Forty-six percent (46%) of the total PM10 is condensable. The

emissions for each source have been summarized below.

12

Emission Point No.

Source Description MHDR

(Mgal/hr)

Emission Factor

(lb/Mgal)

Hourly Emissions

(lb/hr)

Potential Annual

Emissions (ton/yr)

EP-22 Dross Kettles 0.0994 1.106 0.1100 0.48

EP-23 Dross Kettles 0.1492 1.106 0.1650 0.72

EP-24 Refinery Kettles 0.1271 1.106 0.1405 0.62





First the maximum hourly emissions were calculated from the MHDR and the

emission factor. A sample calculation for one of the dross kettles (EP-22) has

been provided below.

Hourly PM10 Emissions (EP-22) =

0.0994 (Mgal/hr) * 1.106 (lb/Mgal) =

0.11 lb/hr

The potential annual emissions were then calculated from the hourly emissions

assuming a conservative 8,760 hr/yr of continuous operation.

Potential Annual PM10 Emissions (EP-22) =

0.11 (lb/hr) / 2000 (lb/ton) * 8760 (hr/yr) =

0.48 ton/yr

A crystallizer boiler (EP-21) and a main shop forge (EP-34) were included in the

original analysis associated with permit 012005-008, but are no longer at the

facility.

13

3.0 Best Available Control Technology

3.1 Overview

The federal PSD program requires that all major stationary sources apply BACT

to each regulated NSR pollutant that has the potential to be emitted in significant

quantities. The facility is defined as a major stationary source in accordance with

the PSD regulations.

The original BACT analyses for permit 012005-008 was developed by IES

Engineers and followed the procedures outlined in the USEPA, "New Source

Review Workshop Manual", Office of Air Quality Planning and Standards, Draft,

October 1990. The manual describes a five step "top down" approach:

1. Identify all potential control technologies,

2. Eliminate technically infeasible options,

3. Rank remaining technologies by control effectiveness,

4. Eliminate control options based on "collateral impacts" of the control

option (for example, cost effectiveness), and

5. Select BACT.

3.2 Identification of Potential Control Technologies

Potential control technologies for PM10 have been listed and ranked by filterable

control efficiency below (total control efficiency is source specific and dependent

upon the filterable fraction).

A thermal oxidizer and dry scrubber with fabric filter were installed on the

reverberatory furnace in 2011-2012. At the time permit 012005-008 was issued

in January 2005, the scrubbing technology was not cost effective for removal of

condensable PM and the MDNR determined that the up-front desulfurization

process in place at that time was BACT.

Baghouses are considered technically feasible for condensable PM removal and

have been installed on all significant sources of PM10. Additionally, the

14

secondary lead NESHAP requires that the building containing the blast furnace,

reverberatory furnace, sweat furnaces, and refinery to be ventilated to a

baghouse at sufficient volumetric flow to achieve a negative pressure differential

on the building.

Rank (based on filterable control)

Control Technology

Assumed Control Efficiency (%)

Filterable PM ICPM OCPM

1 Baghouse 99.7 0 0

2 Dry scrubber 99 95 0

3 Wet ESP 99 88 0

4 Dry ESP 99 29 0

5 Wet scrubber 95 57 0

6 Cyclone 80 0 0

7 Thermal Oxidizer 0 0 98

8 Catalytic Oxidizer

0 0 98

A. Baghouse filterable control efficiency (99.69%) from MO air permit 012005-008, "Review of

Application for Authority to Construct and Operate", Table 7.

B. Inorganic CPM control efficiencies adapted from EPRI, "Estimating Total Sulfuric Acid

Emissions from Stationary Power Plants", March 2012.

C. Thermal oxidizer organic CPM control efficiency from Air Pollution Control Technology

Fact Sheet, Thermal Incinerator

3.3 BACT Selection

3.3.1 Reverberatory Furnace (Main Stack)

A summary of the control technologies examined for control of PM10 emissions

from the reverberatory furnace has been provided as Table 3-1.

15

The reverberatory furnace emits PM10. A thermal oxidizer and dry scrubber with

fabric filter were installed on the reverberatory furnace in 2011-2012 to reduce

SO2 emissions. The highest level control technology for PM10 is already

utilized. As stated above, the dry scrubber with fabric filter would not have been

cost effective for PM10 and MDNR permitted the former upfront feed

desulfurization as the appropriate BACT control.

3.3.2 Blast Furnace


from the blast furnace has been provided as Table 3-2. The least cost envelope

was plotted and provided as Figure 3-1. The least cost analysis identified four

(4) control technologies for additional analysis:

1. Dry scrubber and thermal oxidizer following existing baghouse

2. Dry scrubber following existing baghouse

3. Wet ESP following existing baghouse

4. Thermal Oxidizer following existing baghouse

An annualized cost of $21.29/scfm was calculated for the dry scrubber and

thermal oxidizer following existing baghouse. This was estimated based on the

escalated capital costs from the reverberatory furnace dry scrubber as provided

by Doe Run plus an additional $8/scfm for the thermal oxidizer which

corresponds to the low range of values reported by EPA in their Air Pollution

Technology Fact Sheet. A detail of the annual cost calculations for the dry

scrubber have has been provided as Table 3-3. The annualized cost

effectiveness for the dry scrubber and thermal oxidizer following the existing

baghouse is $75,456/ton (200,000 scfm and 56.43 ton/yr reduction ) of PM10

reduced. The dry scrubber and thermal oxidizer are not economically feasible.

An annualized cost of $13.29/scfm was calculated for the dry scrubber following

the existing baghouse. This was estimated based on the escalated capital costs

from the reverberatory furnace dry scrubber. The annualized cost effectiveness

16

for the dry scrubber and thermal oxidizer following the existing baghouse is

$60,437/ton (200,000 scfm and 43.98 ton/yr reduction ) of PM10 reduced. The

dry scrubber is not economically feasible.

An annualized cost of $12/scfm was used for the wet ESP, which was estimated

based on the low range of values reported by EPA in their Air Pollution

Technology Fact Sheet. The annualized cost effectiveness for the wet ESP

following the existing baghouse is $58,594/ton (200,000 scfm and 40.96 ton/yr

reduction ) of PM10 reduced. The wet ESP is not economically feasible.

An annualized cost of $8/scfm was used for thermal oxidizer, which was

estimated based on the low range of values reported by EPA in their Air Pollution

Technology Fact Sheet.. The annualized cost effectiveness for the thermal

oxidizer following the existing baghouse is $128,514/ton (200,000 scfm and

12.45 ton/yr reduction ) of PM10 reduced. The thermal oxidizer is not

economically feasible.

A Baghouse was selected as BACT for the control of PM10 emitted from the

blast furnace.

3.3.3 Sweat Furnace


from the sweat furnace has been provided as Table 3-4. Four (4) control

technologies were analyzed:

1. Dry scrubber following existing baghouse and thermal oxidizer

2. Wet ESP following existing baghouse and thermal oxidizer

3. Wet scrubber following existing baghouse and thermal oxidizer

4. Dry ESP following existing baghouse and thermal oxidizer

An annualized cost of $13.29/scfm was calculated for the dry scrubber following

the existing baghouse and thermal oxidizer. This was estimated based on the

17

escalated capital costs from the reverberatory furnace dry scrubber as provided

by Doe Run. A detail of the annual cost calculations for the dry scrubber have

has been provided as Table 3-3. The annualized cost effectiveness for the dry

scrubber following the existing baghouse and thermal oxidizer is $66,952/ton

(20,000 scfm and 3.97 ton/yr reduction ) of PM10 reduced. The dry scrubber is

not economically feasible.



Technology Fact Sheet. The annualized cost effectiveness for the wet ESP

following the existing baghouse and thermal oxidizer is $64,865/ton (20,000 scfm

and 3.70 ton/yr reduction ) of PM10 reduced. The wet ESP is not economically

feasible.

An annualized cost of $17/scfm was used for the wet scrubber, which was


Technology Fact Sheet. The annualized cost effectiveness for the wet scrubber

following the existing baghouse and thermal oxidizer is $139,918/ton (20,000

scfm and 2.43 ton/yr reduction ) of PM10 reduced. The wet scrubber is not


An annualized cost of $9/scfm was used for the dry ESP, which was estimated


Technology Fact Sheet. The annualized cost effectiveness for the dry ESP

following the existing baghouse and thermal oxidizer is $128,571/ton (20,000

scfm and 1.40 ton/yr reduction ) of PM10 reduced. The dry ESP is not


A Baghouse and thermal oxidizer was selected as BACT for the control of PM10

emitted from the sweat furnaces.

18

3.3.4 BSN Process


from the BSN process has been provided as Table 3-5.

The BSN scrubber provides PM10 control associated with acid mist and dust

emissions from the battery breaking and separation processes. It is technically

feasible to add a wet ESP following the existing wet scrubber. An annualized cost

of $9.00/scfm was used for the wet ESP, which corresponds to the low range of

values reported by EPA in their Air Pollution Technology Fact Sheet. The

annualized cost effectiveness for the wet ESP is $27,163/ton (30,000 scfm and

9.94 ton/yr reduction) of PM10 reduced. The wet ESP is not economically

feasible.

Fabric filters (baghouses), dry scrubbing, and dry ESPs would not be technically

feasible due to the high acid loadings from the battery breaking and separation

process. A thermal oxidizer was not evaluated due to the low level of organic

emissions anticipated from this process.

A wet scrubber was selected as BACT for the BSN process. A wet scrubber is

currently used to control emissions from the BSN process.

3.3.5 Propane Combustion


from propane combustion has been provided as Table 3-6. Six (6) control

technologies were analyzed:

1. Dry scrubber

2. Wet ESP

3. Dry ESP

4. Wet Scrubber

5. Baghouse

19

6. Thermal Oxidizer

An annualized cost of $13.29/scfm was calculated for the dry scrubber. This was

estimated based on the escalated capital costs from the reverberatory furnace

dry scrubber as provided by Doe Run. A detail of the annual cost calculations for

the dry scrubber have has been provided as Table 3-3. The annualized cost

effectiveness for the dry scrubber is $60,220/ton (13.5 MMBTU/hr, 2,900 scfm

and 0.64 ton/yr reduction) of PM10 reduced. The dry scrubber is not




Technology Fact Sheet. The annualized cost effectiveness for the wet ESP is

$56,129/ton (13.5 MMBTU/hr, 2900 scfm and 0.62 ton/yr reduction) of PM10

reduced. The wet ESP is not economically feasible.

An annualized cost of $9/scfm was used for the dry ESP, which was estimated


Technology Fact Sheet. The annualized cost effectiveness for the dry ESP is


reduced. The dry ESP is not economically feasible.

An annualized cost of $17/scfm was used for the wet scrubber, which was


Technology Fact Sheet. The annualized cost effectiveness for the wet scrubber

is $94,808/ton (13.5 MMBTU/hr, 2900 scfm and 0.52 ton/yr reduction) of PM10

reduced. The wet scrubber is not economically feasible.

An annualized cost of $6/scfm was used for the baghouse, which was estimated


Technology Fact Sheet. The annualized cost effectiveness for the baghouse is

20


reduced. The baghouse is not economically feasible.

An annualized cost of $8/scfm was used for the thermal oxidizer, which was


Technology Fact Sheet. The annualized cost effectiveness for the thermal

oxidizer is $386,667/ton (13.5 MMBTU/hr, 2900 scfm and 0.06 ton/yr reduction)

of PM10 reduced. The thermal oxidizer is not economically feasible.

For small propane burners of the sizes analyzed, no documented case could be

found where add-on controls have been installed.

Based on the information presented above, good combustion practices were

selected as BACT.

21

Table 3-1. Reverberatory Furnace Technology Review

Rank (Based on

Overall Control)

Control Technology

Assumed Control Efficiency (%) Unitized Annualized

Cost ($/scfm-yr)

Total Annualized Cost ($/yr)

Emission Reduction

(ton/yr) Filterable PM

ICPM OCPM Overall

1

Dry scrubber and thermal oxidizer following existing

baghouse

90 95 98 94.10

2

Wet ESP and thermal oxidizer following existing

baghouse

90 88 98 90.03

3 Dry scrubber

following existing baghouse

90 95 0 79.47

4 Wet ESP following existing baghouse

90 88 0 75.40

5

Wet scrubber and thermal oxidizer following existing

baghouse

70 57 98 66.62

6

Dry ESP and thermal oxidizer following existing

baghouse

90 29 98 55.70

7 Wet scrubber


70 57 0 51.98

22

8 Dry ESP following existing baghouse

90 29 0 41.07

9 Thermal Oxidizer following existing

baghouse 0 0 98 14.64

10 Existing Baghouse Base control

A. Inorganic CPM control efficiencies adapted from EPRI, "Estimating Total Sulfuric Acid Emissions from Stationary

Power Plants", March 2012.

B. Thermal oxidizer organic CPM control efficiency from Air Pollution Control Technology Fact Sheet, Thermal Incinerator

C. Low range of filterable control used due to following existing high efficiency baghouse (low loading)

D. Unitized annualized costs from associated Air Pollution Control Technology Fact Sheets, except dry scrubbing

E. Dry scrubber annualized cost escalated from cost data for reverb. Furnace dry scrubber

23

Table 3-2. Blast Furnace Technology Review

Rank Control

Technology


Cost ($/scfm-yr)

Cost of PM10

Removed ($/ton)

Emission Reduction


ICPM OCPM Overall

1

Dry scrubber and thermal oxidizer following existing

baghouse

90 95 98 95.36 21.29 75456 56.43

2

Wet ESP and thermal oxidizer following existing

baghouse

90 88 98 90.26 20 74892 53.41

3 Dry scrubber


90 95 0 74.32 13.29 60437 43.98

4 Wet ESP following existing baghouse

90 88 0 69.22 12 58594 40.96

5

Wet scrubber and thermal oxidizer following existing

baghouse

70 57 98 66.54 25 126968 39.38

6

Dry ESP and thermal oxidizer following existing

baghouse

90 29 98 47.29 17 121515 27.98

7 Wet scrubber


70 57 0 45.50 17 126253 26.93

24

8 Dry ESP following existing baghouse

90 29 0 26.25 9 115905 15.53

9 Thermal Oxidizer following existing

baghouse 0 0 98 21.04 8 128514 12.45

10 Existing Baghouse Base control







25

Figure 3-1. Blast Furnace Least Cost Envelope

0

1000000

2000000

3000000

4000000

5000000

6000000

0.00 10.00 20.00 30.00 40.00 50.00 60.00

Tota

l An

nu

aliz

ed

Co

st (

$/

yr)

Emission Reduction (ton/yr)

Least Cost Envelope

Inferior Controls

1

3

9

4

26

Table 3-3. Dry Scrubber Annual Cost Effectiveness Detail

Cost Item Cost

DIRECT ANNUAL COSTS

Operating Labor

Operator 2 hr/day 30.00 $/hr $21,900

Supervisor 15 % of operator $3,285

Operating Materials -

Maintenance

Labor 2 hr/day 30.00 $/hr $21,900

Material 100 of maint. labor $21,900

Bag Replacement

591 Bags 79.50 $/Bag CRF = 0.4021 $18,890

Utilities

Propane Mgal/yr $/Mgal $0

Electricity 4,918,840 kW-hr/yr 0.05 $/kW-hr $245,942

Lime 488 ton/yr 100.00 $/ton $48,800

INDIRECT ANNUAL COSTS, IC

Overhead 60 % of sum of operating labor and mtrl and $41,391

maintenance labor and materials.

Administrative Charges 2 % of TCI $283,863

Property Taxes 1 % of TCI $141,931

Insurance 1 % of TCI $141,931

Capital Recovery TCI $ 14,193,148 CRF = 0.1175 $1,667,122

TOTAL ANNUAL COST 13.29 $/scfm $2,658,856

A. Adapted from EPA Air Pollution Control Cost Manual (APCCM)

27

B. Design Parameters

Standard Flow = 200000 scfm

Actual Flow = 221591 acfm

Stack Temperature = 125 F

C. Capital Cost

Reverb. Scrubber TCI 7,300,000 $ (June 2011) @ 75000 acfm

Dry Scrubber TCI 13,983,544 $ (June 2011), TCI=TCIBase * (Flow/FlowBase)0.6

Escalated based on Fabricated structural metal mfg PPI

Jun-11 PPI 140.1 Unitless; US Bureau of Labor Statistics

Feb-14 PPI 142.2 Unitless; US Bureau of Labor Statistics (most recent)

Dry Scrubber TCI 14,193,148 $ (Current)

D. Electricity consumption

PF = 0.000181*Q*∆P*Θ

PF = Fan Power (kW-hr/yr) = 4918840 kW-hr/yr

Q =actual volumetric flow (acfm) = 221591 acfm

∆P = Pressure drop (in. H2O) = 14 in H2O, for dry scrubber

Θ = Annual operation (hr/yr) = 8760 hr/yr

E. Capital recovery factor

Dry Scrubber

Lifetime 20 years

Interest 10 %

CRF 0.1175

Bags

Lifetime 3 years

Interest 10 %

CRF 0.4021

28

Table 3-4. Sweat Furnace Technology Review

Rank Control

Technology


Cost ($/scfm-yr)

Cost of PM10

Removed ($/ton)

Emission Reduction


ICPM OCPM Overall

1

Dry scrubber following existing

baghouse and thermal oxidizer

90 95 0 74.32 13.29 66952 3.97

2

Wet ESP following existing baghouse

and thermal oxidizer

90 88 0 69.22 12 64865 3.70

3

Wet scrubber following existing

baghouse and thermal oxidizer

70 57 0 45.50 17 139918 2.43

4

Dry ESP following existing baghouse

and thermal oxidizer

90 29 0 26.25 9 128571 1.40

5 Existing Baghouse

and Thermal Oxidizer

Base control



B. Low range of filterable control used due to following existing high efficiency baghouse (low loading)

C. Unitized annualized costs from associated Air Pollution Control Technology Fact Sheets, except dry scrubbing

D. Dry scrubber annualized cost escalated from cost data for reverb. Furnace dry scrubber

29

Table 3-5. BSN Process Technology Review

Rank Control

Technology


Cost ($/scfm-yr)

Cost of PM10

Removed ($/ton)

Emission Reduction


ICPM OCPM Overall

1 Wet ESP following

existing wet scrubber

90 88 0 88.22 9 27163 9.94

2 Existing wet

scrubber Base control



B. Low range of filterable control used due to following existing scrubber (low loading)

C. Unitized annualized costs from associated Air Pollution Control Technology Fact Sheets

30

Table 3-6. Propane Combustion Technology Review (Dross and Refinery Kettle Heat Stacks)

Rank Control

Technology


Cost ($/scfm-yr)

Cost of PM10

Removed ($/ton)

Emission Reduction

(ton/yr) Filterable PM10

Inorganic CPM

Organic CPM

Overall

1 Dry scrubber 99 95 0 88.48 13.29 60220 0.64

2 Wet ESP 99 88 0 85.92 12 56129 0.62

3 Dry ESP 99 29 0 64.32 9 56739 0.46

4 Wet scrubber 95 57 0 72.40 17 94808 0.52

5 Baghouse 99.7 0 0 54.09 6 44615 0.39

6 Thermal Oxidizer 0 0 98 8.97 8 386667 0.06







F. CPM assumed 80% inorganic and 20% organic

31

4.0 Conclusion

The Doe Run Company's Buick Resource Recycling Facility (BRRF) is located in

northwest Iron County, Missouri approximately 3 miles east of Boss. The facility

was issued a PSD permit in 2005 (permit no. 012005-008, project no. 2001-10-

058) by the Missouri Department of Natural Resources (MDNR).

Since condensable emissions were not directly considered as part of the review

associated with permit 012005-008, the MDNR has requested a control

technology review for total PM10 (including condensable).

Each source permitted under 012005-008 was analyzed to determine if it was a

source of condensable PM. An estimate of the CPM was then made for each

applicable source and added to the associated filterable emissions.

A control technology review was then completed for each source according to the

five step BACT "top down" approach:

1. Identify all potential control technologies,

2. Eliminate technically infeasible options,

3. Rank remaining technologies by control effectiveness,

4. Eliminate control options based on "collateral impacts" of the control

option (for example, cost effectiveness), and

5. Select BACT.

A summary of the pollution controls or work practices that are in place that meet

or exceed BACT are provided below.

Point No. Source Description Pollution Control in Place

EP-8 Reverberatory Furnace Thermal Oxidizer and Dry Scrubber with Fabric Filter

EP-8 Blast Furnace Baghouses

EP-8 Sweat Furnaces Baghouse and Thermal

Oxidizer

EP-16 BSN Process Wet Scrubber

32

Point No. Source Description Pollution Control in Place

EP-22 to 23 Dross Kettles Good Combustion

Practices

EP-24 to 28 Refinery Kettles Good Combustion

Practices

The controls and operational requirements listed above are federally enforceable

as set forth in construction permit conditions or other federally enforceable

regulations or documents (i.e., SIP Consent Judgments). As such, no additional

permit conditions are needed in addition to the Amendment for Missouri Air

Permit No. 062011-004 Special Condition 2.F as set forth in the January 13,

2014 submittal to the agency.

33

Appendix A. RBLC Search Results

Table A-1. RBLC Process Code 82.590, Lead Products and Smelting, January 2004 to Present

RBLC ID Facility Name State Permit

No.

Permit Issue Date

Process Name Pollutant Test

Method BACT Limit

FL-0320 EFT LEAD-ACID

BATTERY RECYCLING FACILITY

FL

PSD-FL-404

(0570057-020-AC)

9/22/2009 Battery breaking area

Particulate matter,

total (TPM)

Method 5 and 29

0.005 gr/dscf



FL

PSD-FL-404

(0570057-020-AC)

9/22/2009 Lead Smelting

Particulate matter,

total (TPM)

Method 5 0.005 gr/dscf



FL

PSD-FL-404

(0570057-020-AC)

9/22/2009 Furnace Tapping,

Charging and Lead Refining

Particulate matter,

total (TPM)

Method 5

0.005 gr/dscf

and 2.68 lb/hr



FL

PSD-FL-404

(0570057-020-AC)

9/22/2009 Soda Ash Silos

Particulate matter,

total (TPM)




FL

PSD-FL-404

(0570057-020-AC)

9/22/2009 Building ventilation

Particulate matter,

total (TPM)

Method 5

0.005 gr/dscf

and 36.6 lb/hr



FL

PSD-FL-404

(0570057-020-AC)

9/22/2009 Plastic Pellet Silo

Particulate matter,

total (TPM)


34

RBLC ID Facility Name State Permit

No.

Permit Issue Date

Process Name Pollutant Test

Method BACT Limit



FL

PSD-FL-404

(0570057-020-AC)

9/22/2009 Emergency Generator

Particulate matter,

total (TPM)

Mfg. Certification

0.12 g/hp-hr

35

Table A-2. RBLC Process Code 13.310, Boiler/Furnace <100 MMBTU/hr, Natural Gas (including propane and LPG),

January 2004 to Present

RBLC ID State Permit No. Permit

Issue Date Process Name Pollutant Control Technology

RBLC Limit

AK-0071 AK AQ0164CPT01 12/20/2010 Sigma Thermal Auxiliary Heater

(1) TPM

Good Combustion Practices

7.6 LB/MMSCF


(1) TPM10


7.6 LB/MMSCF


(1) TPM2.5


7.6 LB/MMSCF

AL-0191 AL 209-0090-

X001,X002,X003 03/23/2004 BOILERS, NATURAL GAS, (3) FPM10 CLEAN FUEL 0.38 LB/H

AL-0230 AL 503-0095-X001

THRU X026 08/17/2007

NATURAL GAS-FIRED BATCH ANNEALING FURNACES (LA63,

LA64) FPM10

0.0076 LB/MMBTU

AL-0230 AL 503-0095-X001

THRU X026 08/17/2007

NATURAL GAS-FIRED PASSIVE ANNEALING

FURNACE (LO41) FPM10

0.0076 LB/MMBTU

AL-0230 AL 503-0095-X001

THRU X026 08/17/2007

3 NATURAL GAS-FIRED BOILERS WITH ULNB &

EGR (537-539) FPM10

0.0076 LB/MMBTU

AL-0230 AL 503-0095-X001

THRU X026 08/17/2007

NATURAL GAS-FIRED BATCH ANNEALING FURNACE (535)

FPM10 0.0076

LB/MMBTU

AL-0231 AL 712-0037 06/12/2007 VACUUM DEGASSER BOILER PM 0.0076

LB/MMBTU

AL-0231 AL 712-0037 06/12/2007 GALVANIZING LINE FURNACE PM 0.0076

LB/MMBTU

AR-0076 AR 1113-AOP-R0 02/17/2004 BOILER, HOT WATER, (2) SN-

PBCDF-05, -06 FPM10 NATURAL GAS ONLY. 0.1 LB/H

36



RBLC Limit

AR-0076 AR 1113-AOP-R0 02/17/2004 BOILER, PROCESS STEAM, (2)

SN-PBCDF-03, -04 FPM10 NATURAL GAS ONLY. 0.3 LB/H

AR-0076 AR 1113-AOP-R0 02/17/2004 BOILER, LABORATORY SN-

PBCDF-16 FPM10 NATURAL GAS ONLY. 0.1 LB/H

AR-0077 AR 2062-AOP-R0 07/22/2004 BOILERS FPM10 NATURAL GAS

COMBUSTION ONLY 0.0076

LB/MMBTU

AR-0086 AR 883-AOP-R4 06/11/2004 VTD BOILER FPM10 GOOD COMBUSTION

PRACTICE 0.4 LB/H

AR-0090 AR 1139-AOP-R6 04/03/2006 PICKLE LINE BOILERS, SN-52 FPM10 GOOD COMBUSTION

PRACTICE 0.3 LB/H

AZ-0047 AZ 1001653 12/01/2004 AUXILIARY BOILER FPM10 0.0033

LB/MMBTU

CA-1191 CA SE 07-02 03/11/2010 AUXILIARY BOILER TPM

OPERATIONAL RESTRICTION OF 500

HR/YR, USE PUC QUALITY NATURAL

GAS

0.2 GRAINS PER 100

DSCF

CA-1191 CA SE 07-02 03/11/2010 AUXILIARY BOILER TPM2.5 OPERATIONAL

RESTRICTION OF 500 HR/YR

0.2 GRAINS PER 100

DSCF

CA-1192 CA SJ 08-01 06/21/2011 AUXILIARY BOILER TPM

USE PUC QUALITY NATURAL GAS,

OPERATIONAL LIMIT OF 46,675 MMBTU/YR

0.0034 GR/DSCF

CA-1192 CA SJ 08-01 06/21/2011 AUXILIARY BOILER TPM10

USE PUC QUALITY NATURAL GAS,

OPERATIONAL LIMIT OF 46,675 MMBTU/YR

0.0034 GR/DSCF

37



RBLC Limit

FL-0286 FL PSD-FL-354 AND 0990646-001-AC

01/10/2007 TWO 99.8 MMBTU/H GAS-

FUELED AUXILIARY BOILERS FPM10

2 GS/100 SCF GAS

FL-0335 FL 1210468-001-

AC(PSD-FL-417) 09/05/2012

Four(4) Natural Gas Boilers - 46 MMBtu/hour

TPM Good Combustion

Practice 2 GR OF

S/100 SCF

FL-0335 FL 1210468-001-

AC(PSD-FL-417) 09/05/2012


TPM10 Good Combustion

Practice 2 GR OF

S/100 SCF

FL-0335 FL 1210468-001-

AC(PSD-FL-417) 09/05/2012


TPM2.5 Good Combustion

Practice 2 GR OF

S/100 SCF

IA-0088 IA 57-01-080 06/29/2007 INDIRECT-FIRED DDGS

DRYER PM

0.015 GR/DSCF

IA-0088 IA 57-01-080 06/29/2007 INDIRECT-FIRED DDGS

DRYER FPM10

0.015 GR/DSCF

*IA-0106 IA PN 13-037 07/12/2013 Startup Heater TPM good operating

practices and use of natural gas

0.0024 LB/MMBTU

*IA-0106 IA PN 13-037 07/12/2013 Startup Heater TPM10 good operating

practices & use of natural gas

0.0024 LB/MMBTU

*IA-0106 IA PN 13-037 07/12/2013 Startup Heater TPM2.5 good operating

practices & use of natural gas

0.0024 LB/MMBTU

IN-0121 IN 145-23127-00001 09/01/2006 602B FURNACE FPM BAGHOUSE 0.45 LB/T GLASS PULLED

IN-0121 IN 145-23127-00001 09/01/2006 602B FURNACE FPM10 BAGHOUSE 0.45 LB/T GLASS PULLED

38



RBLC Limit

*IN-0158 IN 141-31003-00579 12/03/2012 TWO (2) NATURAL GAS

AUXILIARY BOILERS FPM

GOOD COMBUSTION PRACTICES AND

FUEL SPECIFICATIONS

0.0075 LB/MMBTU


AUXILIARY BOILERS FPM10


FUEL SPECIFICATIONS

0.0075 LB/MMBTU


AUXILIARY BOILERS FPM2.5


FUEL SPECIFICATIONS

0.0075 LB/MMBTU

LA-0192 LA PSD-LA-704 06/06/2005 FUEL GAS HEATERS (3) FPM10

USE OF LOW SULFUR PIPELINE NATURAL

GAS AND GOOD COMBUSTION PRACTICES

0.14 LB/H

LA-0203 LA PSD-LA-710 06/13/2005 AUXILIARY THERMAL OIL

HEATER FPM10

USE OF NATURAL GAS AS FUEL AND

GOOD COMBUSTION PRACTICES

0.59 LB/H

LA-0204 LA PSD-LA-709(M-1) 02/27/2009 CRACKING FURNACES A-D FPM10

GOOD COMBUSTION PRACTICES AND USE OF NATURAL GAS AS

FUEL

0.007 LB/MMBTU

LA-0229 LA PSD-LA-731 07/10/2008 EQT122-EQT125 - FOUR VCM

CRACKING FURNACES TPM10

GOOD COMBUSTION PRACTICES AND CLEAN BURNING

FUELS

0.007 LB/MMBTU

LA-0231 LA PSD-LA-742 06/22/2009 SHIFT REACTOR STARTUP

HEATER TPM10

GOOD DESIGN AND PROPER OPERATION

0.25 LB/H

LA-0231 LA PSD-LA-742 06/22/2009 GASIFIER STARTUP

PREHEATER BURNERS (5) TPM10


0.03 LB/H

39



RBLC Limit

LA-0231 LA PSD-LA-742 06/22/2009 METHANATION STARTUP

HEATERS TPM10


0.42 LB/H

LA-0240 LA PSD-LA-747/1280-

00141-V0 06/14/2010 Boilers TPM10

Good equipment design and proper combustion

practices,

fueled by natural gas/alcohol

0.1 LB/H

LA-0240 LA PSD-LA-747/1280-

00141-V0 06/14/2010 Boilers TPM

Good equipment design and proper combustion

practices,

fueled by natural gas/alcohol

0.13 LB/H

LA-0244 LA PSD-LA-291(M3) 11/29/2010 EQT0027 - PACOL CHARGE

HEATER H-201 TPM10 0.86 LB/H

LA-0244 LA PSD-LA-291(M3) 11/29/2010 EQT0028 - PACOL STARTUP

HEATER H-202 TPM10 No additional Control 0.21 LB/H

LA-0246 LA PSD-LA-619(M6) 12/31/2010 EQT0323 - Boiler 401F TPM10

Proper design and operation, good

combustion practices and gaseous fuels

0.74 LB/H

*LA-0272

LA PSD-LA-768 03/27/2013 AMMONIA START-UP HEATER

(102-B) TPM10

GOOD COMBUSTION PRACTICES: PROPER DESIGN OF BURNER

AND FIREBOX COMPONENTS;

MAINTAINING THE PROPER AIR-TO-FUEL

RATIO, RESIDENCE TIME, AND

COMBUSTION ZONE TEMPERATURE.

0.53 LB/H

40



RBLC Limit

*LA-0272

LA PSD-LA-768 03/27/2013 AMMONIA START-UP HEATER

(102-B) TPM2.5

GOOD COMBUSTION PRACTICES: PROPER DESIGN OF BURNER

AND FIREBOX COMPONENTS;

MAINTAINING THE PROPER AIR-TO-FUEL

RATIO, RESIDENCE TIME, AND

COMBUSTION ZONE TEMPERATURE.

0.53 LB/H

MD-0035 MD 009-5-0049 08/12/2005 VAPORIZATION HEATER PM 0.001

LB/MMBTU

MD-0036 MD CPCN 9055 03/10/2006 FUEL GAS PROCESS HEATER FPM10

USE OF LNG QUALITY, LOW

SULFUR NATURAL GAS

0.0074 LB/MMBTU

MD-0040 MD CPCN CASE NO.

9129 11/12/2008 BOILER PM

0.005 LB/MMBTU


9129 11/12/2008 BOILER FPM10

0.005 LB/MMBTU


9129 11/12/2008 BOILER FPM2.5

0.005 LB/MMBTU


9129 11/12/2008 HEATER PM

0.007 LB/MMBTU


9129 11/12/2008 HEATER FPM10

0.007 LB/MMBTU


9129 11/12/2008 HEATER FPM2.5

0.007 LB/MMBTU

MN-0053 MN 13100071-001 07/15/2004 BOILER, NATURAL GAS (1) PM CLEAN FUEL AND

GOOD COMBUSTION. 0.008

LB/MMBTU

41



RBLC Limit

MN-0070 MN 06100067-001 09/07/2007 SMALL BOILERS &

HEATERS(<100 MMBTU/H) FPM10

0.0025 GR/DSCF

NJ-0079 NJ 18940 -

BOP110003 07/25/2012

Commercial/Institutional size boilers less than 100 MMBtu/hr

FPM use of Natural gas 0.17 LB/H

NJ-0079 NJ 18940 -

BOP110003 07/25/2012


TPM10 0.46 LB/H

NJ-0079 NJ 18940 -

BOP110003 07/25/2012


TPM2.5 Use of Natural gas 0.46 LB/H

NJ-0080 NJ 08857/BOP110001 11/01/2012 Boiler less than 100 MMBtu/hr FPM use of natural gas a

clean fuel 0.22 LB/H

NJ-0080 NJ 08857/BOP110001 11/01/2012 Boiler less than 100 MMBtu/hr FPM10 use of natural gas a


NJ-0080 NJ 08857/BOP110001 11/01/2012 Boiler less than 100 MMBtu/hr FPM2.5 use of natural gas a


NV-0037 NV 15347 05/14/2004 AUXILIARY BOILER FPM10 RESTRICTION OF OPERATION TO NATURAL GAS

0.5 LB/H

NV-0044 NV 257 01/04/2007 COMMERCIAL/INSTITUTIONAL-

SIZE BOILERS FPM10

USE OF NATURAL GAS AS THE ONLY

FUEL

0.0075 LB/MMBTU

NV-0046 NV 468 05/16/2006 COMMERCIAL/INSTITUTIONAL

BOILER FPM10

GOOD COMBUSTION PRACTICE

0.0078 LB/MMBTU

NV-0047 NV 114 02/26/2008 BOILERS/HEATERS - NATURAL GAS-FIRED

FPM10 FLUE GAS

RECIRCULATION 0.0077

LB/MMBTU

NV-0048 NV 468 05/16/2006 COMMERCIAL/INSTITUTIONAL-

SIZE BOILER (<100 MMBTU/H)

FPM10 NATURAL GAS IS THE ONLY FUEL USED BY

THE UNIT.

0.0078 LB/MMBTU

42



RBLC Limit

NV-0049 NV 257 08/20/2009 BOILER - UNIT FL01 FPM10

FLUE GAS RECIRCULATION AND

OPERATING IN ACCORDANCE WITH

THE MANUFACTURER'S

SPECIFICATION

0.0075 LB/MMBTU

NV-0049 NV 257 08/20/2009 SMALL INTERNAL

COMBUSTION ENGINE (<600 HP) - UNIT FL12

FPM10 THE UNIT IS

EQUIPPED WITH A TURBOCHARGER.

0.0022 LB/HP-H

NV-0049 NV 257 08/20/2009 BOILER - UNIT BA01 FPM10


THE MANUFACTURER'S

SPECIFICATION

0.0077 LB/MMBTU

NV-0049 NV 257 08/20/2009 BOILER - UNIT BA03 FPM10


THE MANUFACTURER'S

SPECIFICATION

0.0076 LB/MMBTU

NV-0049 NV 257 08/20/2009 BOILER - UNIT CP01 FPM10


THE MANUFACTURER'S

SPECIFICATION

0.0076 LB/MMBTU



THE MANUFACTURER'S

SPECIFICATION

0.0075 LB/MMBTU

43



RBLC Limit



THE MANUFACTURER'S

SPECIFICATION

0.0075 LB/MMBTU

NV-0050 NV 825 11/30/2009 WATER HEATERS - UNITS NY037 AND NY038 AT NEW

YORK - NEW YORK FPM10

LIMITING THE FUEL TO NATURAL GAS ONLY AND GOOD

COMBUSTION PRACTICES

0.0075 LB/MMBTU

NY-0095 NY PSD-NY-0001 05/10/2006 AUXILIARY BOILER FPM10 LOW SULFUR FUEL 0.0033

LB/MMBTU

OH-0252 OH 07-00503 12/28/2004 BOILERS (2) FPM10 0.31 LB/H

OH-0276 OH 13-04176 06/10/2004 BOILER FOR VACUUM

OXYGEN DEGASSER VESSEL FPM10 0.21 LB/H

OH-0309 OH 04-01358 05/03/2007 BOILER (2), NATURAL GAS PM 0.04 LB/H

OH-0309 OH 04-01358 05/03/2007 BOILER (2), NATURAL GAS FPM10 0.15 LB/H

OH-0323 OH 03-17392 06/05/2008 BOILER PM 0.02

LB/MMBTU

OH-0323 OH 03-17392 06/05/2008 BOILER FPM10 0.094 LB/H

*OH-0350

OH P0109191 07/18/2012 Steam Boiler TPM10 0.48 LB/H

*OH-0352

OH P0110840 06/18/2013 Auxiliary Boiler TPM10 Clean burning fuel, only

burning natural gas 0.79 LB/H

*OH-0355

OH P0112127 05/07/2013 4 Indirect-Fired Air Preheaters TPM10 0.007

LB/MMBTU

OK-0097 OK 2000-306-C M-1

PSD 02/03/2004

BOILERS, NATURAL GAS, STEAM GENERATORS

FPM10 CLEAN FUELS 0.63 LB/H

OK-0097 OK 2000-306-C M-1

PSD 02/03/2004 HEATERS/OXIDIZERS PM

EXCLUSIVE USE OF COMMERCIAL

NATURAL 0.12 LB/H

44



RBLC Limit

GAS OR PROPANE.

OK-0128 OK 2003-106-C(M-1)

PSD 09/08/2008

Ladle pre-heater and refractory drying

TPM10 natural gas fuel 0.0076

LB/MMBTU

OK-0129 OK 2007-115-C(M-

1)PSD 01/23/2009

FUEL GAS HEATER (H2O BATH)

TPM10 0.1 LB/H

OK-0134 OK 2008-100-C PSD 02/23/2009 Nitric Acid Preheaters No. 1 (EU

401, EUG 4) TPM Natural gas combustion 0.15 LB/H

OK-0134 OK 2008-100-C PSD 02/23/2009 Nitric Acid Preheaters No. 1 (EU

401, EUG 4) TPM10 Natural gas combustion 0.15 LB/H

OK-0135 OK 2008-100-C PSD 02/23/2009 NITRIC ACID PREHEATERS #1,

#3, AND #4 TPM 0.15 LB/H

OK-0135 OK 2008-100-C PSD 02/23/2009 NITRIC ACID PREHEATERS #1,

#3, AND #4 TPM10 0.15 LB/H

OK-0135 OK 2008-100-C PSD 02/23/2009 BOILERS #1 AND #2 TPM 0.6 LB/H

OK-0135 OK 2008-100-C PSD 02/23/2009 BOILERS #1 AND #2 TPM10 0.5 LB/H

OR-0048 OR 25-0016-ST-02 12/29/2010 NATURAL GAS-FIRED BOILER FPM10 CLEAN FUEL 2.5

LB/MMCF

PA-0262 PA 06-05007D 10/01/2007 ESR FURNACES (6 UNITS) FPM 12 LB/H

*PA-0291

PA 37-337A 04/23/2013 AUXILIARY BOILER TPM 0.005

LB/MMBTU

SC-0111 SC 1680-0046-CU 12/22/2009 FACE PRIMARY DRYER FPM10


NATURAL GAS AS FUEL

SC-0111 SC 1680-0046-CU 12/22/2009 CORE PRIMARY DRYER FPM10 GOOD COMBUSTION

PRACTICES AND NATURAL GAS AS

45



RBLC Limit

FUEL

SC-0112 SC 0420-0060-DO 05/05/2008 VACUUM DEGASSER BOILER FPM10

GOOD COMBUSTION PRACTICES PER

MANUFACTURER'S GUIDANCE

0.0076 LB/MMBTU

SC-0112 SC 0420-0060-DO 05/05/2008 TUNNEL FURNACE BURNERS FPM10

NATURAL GAS COMBUSTION WITH GOOD COMBUSTION

PRACTICES PER MANUFACTURER'S

GUIDANCE

0.0076 LB/MMBTU

SC-0114 SC 0160-0020-CB 11/25/2008 PROPANE VAPORIZERS (ID15) TPM

TUNE-UPS AND INSPECTIONS WILL BE PERFORMED AS OUTLINED IN THE

GOOD MANAGEMENT PRACTICE PLAN

0.04 LB/H

SC-0114 SC 0160-0020-CB 11/25/2008 PROPANE VAPORIZERS (ID15) FPM10


GOOD MANAGEMENT PRACTICE PLAN.

0.04 LB/H

SC-0114 SC 0160-0020-CB 11/25/2008 NATURAL GAS SPACE

HEATERS - 14 UNITS (ID 18) TPM 0.15 LB/H


HEATERS - 14 UNITS (ID 18) FPM10 0.15 LB/H

46



RBLC Limit

SC-0114 SC 0160-0020-CB 11/25/2008 75 MILLION BTU/HR BACKUP

THERMAL OIL HEATER TPM 0.54 LB/H


THERMAL OIL HEATER FPM10 0.54 LB/H


THERMAL OIL HEATER TPM

GOOD COMBUSTION PRACTICES WILL BE USED AS CONTROL FOR PM EMISSIONS.

0.54 LB/H


THERMAL OIL HEATER FPM10

GOOD COMBUSTION PRACTICES WILL BE USED AS CONTROL

FOR PM10 EMISSIONS.

0.54 LB/H

SC-0115 SC 0680-0046-CB 02/10/2009 PROPANE VAPORIZERS (ID

14) TPM 0.04 LB/H

SC-0115 SC 0680-0046-CB 02/10/2009 PROPANE VAPORIZERS (ID

14) FPM10


GOOD MANAGEMENT PRACTICE PLAN.

0.04 LB/H


HEATERS - 14 UNITS (ID 17) TPM 0.15 LB/H


HEATERS - 14 UNITS (ID 17) FPM10 0.15 LB/H

*SC-0149

SC 1860-0128-CA 01/03/2013 NATURAL GAS BOILER EU004 PM 0.005

LB/MMBTU

47



RBLC Limit

*SC-0149

SC 1860-0128-CA 01/03/2013 NATURAL GAS BOILER EU004 FPM 0.002

LB/MMBTU

*SC-0149

SC 1860-0128-CA 01/03/2013 NATURAL GAS BOILER EU004 FPM10 0.005

LB/MMBTU

*SC-0149

SC 1860-0128-CA 01/03/2013 NATURAL GAS BOILER EU004 FPM2.5 0.005

LB/MMBTU

*SC-0149


LB/MMBTU

*SC-0149


LB/MMBTU

*SC-0149


LB/MMBTU

*SC-0149


LB/MMBTU

*SC-0149


LB/MMBTU

*SC-0149


LB/MMBTU

*SC-0149


LB/MMBTU

*SC-0149


LB/MMBTU

TX-0501 TX PSD-TX 55M3

AND 6051 07/11/2006

TURBINE EXHAUST DUCT BURNER (3)

FPM10 0.25 LB/H

TX-0501 TX PSD-TX 55M3

AND 6051 07/11/2006 POWER STEAM BOILER FPM10 0.64 LB/H

WI-0207 WI 03-DCF-184 01/21/2004 BOILER, S52/B52, 11 MMBTU/H PM NATURAL GAS /

PROPANE; GOOD COMBUSTION

0.0075 LB/MMBTU

48



RBLC Limit

CONTROL

WI-0207 WI 03-DCF-184 01/21/2004 BOILER, S53 / B53, 34

MMBTU/H PM

NATURAL GAS / PROPANE; GOOD

COMBUSTION CONTROL

0.0075 LB/MMBTU

WI-0207 WI 03-DCF-184 01/21/2004 BOILER, S50/B50, 60 MMBTU/H PM

NATURAL GAS/ PROPANE; GOOD

COMBUSTION CONTROL

0.0075 LB/MMBTU

WI-0207 WI 03-DCF-184 01/21/2004 BOILER, S51/B51, 80 MMBTU/H PM NATURAL GAS, GOOD

COMBUSTION CONTROL

0.0075 LB/MMBTU

WI-0223 WI 03-RV-370 06/17/2004 THERMAL OIL HEATER, GTS

ENERGY, S31, B31 PM

USE OF NATURAL GAS / DISTILLATE OIL, W/ RESTRICTION ON

OIL USAGE

0.84 LB/H

WI-0223 WI 03-RV-370 06/17/2004 THERMAL OIL HEATER, GTS

ENERGY, S32, B32 PM

USE OF NATURAL GAS / DISTILLATE OIL, W/ RESTRICTION ON

OIL USAGE

1 LB/H

WI-0226 WI 04-RV-128 08/27/2004 NATURAL GAS FIRED BOILER FPM10 NATURAL GAS 0.8 LB/H

WI-0227 WI 04-RV-175 10/13/2004 NATURAL GAS FIRED AUXILLIARY BOILER

FPM10 NATURAL GAS FUEL, GOOD COMBUSTION

PRACTICES 0.74 LB/H

WI-0227 WI 04-RV-175 10/13/2004 GAS HEATER (P06, S06) FPM10 NATURAL GAS FUEL 0.08 LB/H

WI-0228 WI 04-RV-248 10/19/2004 B63, S63; B64, S64 - NATURAL GAS STATION HEATER 1 AND

2 FPM10 NATURAL GAS FUEL 0.006 LB/H

49



RBLC Limit

WI-0228 WI 04-RV-248 10/19/2004 B63, S63; B64, S64 - NATURAL GAS STATION HEATER 1 AND

2 PM NATURAL GAS 0.01 LB/H

WV-0021

WV R14-0021 06/09/2004 BOILER, NATURAL GAS, 39.00

MMBTU PM 0.32 PPH

-- DRAFT --

Amendment to Missouri Air Permit No. 012005-008 (as amended) to

Account for Condensable Particulate Emissions

Wet Scrubber Cost Analysis for the Control of PM10 Emissions from the

Blast Furnace

Prepared For:

Buick Resource Recycling Facility

18594 Hwy KK

Boss MO 65440

Prepared By:

Shell Engineering & Associates, Inc.

2403 West Ash

Columbia MO 65203

November 4, 2015

1

1.0 Introduction

The Buick Resource Recycling Facility (BRRF) was issued a PSD permit in 2005

(permit no. 012005-008, project no. 2001-10-058) by the Missouri Department of

Natural Resources (MDNR). Because condensable emissions were not directly

considered as part of the review associated with permit 012005-008, the MDNR

has requested a control technology review to ensure that the condensable

controls employed by the facility are considered Best Available Control

Technology (BACT). It should be noted that at the time the permit was originally

issued in January 2005, PM10 BACT limits were exclusively specified for the

filterable component only.

The MDNR specifically requested a review of each emission unit permitted under

012005-008 to determine if it is a source of condensable particulate. Next,

MDNR requested that a technology review be completed for each source of

condensable particulate to determine if existing control technologies in place

constitute BACT for total PM10 or if additional technologies are required pursuant

to the PSD regulations.

A BACT analysis was submitted on August 15, 2015. As part of the review

procedure, the MDNR has requested a detailed review of the cost associated

with the installation of a wet scrubber on the blast furnace for the control of total

PM10.

2

2.0 Emission Estimates

The main stack (EP-8) is a source of filterable, inorganic and organic

condensable particulate matter. The primary sources routed to the main stack

are the blast furnace and the reverberatory furnace. The main stack also

receives process gases from the two sweat furnaces and refinery along with a

large volume of building ventilation air. The main stack was tested on 10/3/2012

and had a total PM10 (filterable and condensable) emission factor of 0.85 lb/ton

of lead produced. The speciation for the main stack was 8.5% filterable, 20.6%

organic CPM, and 70.9% inorganic CPM. The reverberatory furnace was tested

on 9/26-27/2012 and accounted for 13.3% of the main stack emissions. The

speciation for the reverberatory furnace was 26.9% filterable, 14.9% organic

CPM, and 58.2% inorganic CPM. The emissions from the blast furnace, sweat

furnaces, refinery and building ventilation were calculated by subtracting the

reverberatory furnace emissions from the total emissions emitted from the main

stack. The calculations have been summarized below:

Source Particulate Matter Type

Existing Control Device

Controlled PM10 Emission

Factor (lb/ton)

Fraction of Subtotal (%)



Organic Condensable

Thermal Oxidizer 0.0168 14.93


Dry Scrubber with Fabric Filtration

0.0656 58.18

Subtotal: 0.1128 100.00

Blast Furnace, Sweat Furnace,

Refinery, Building

Ventilation


Organic Condensable

None 0.1583 21.47


None 0.5370 72.83

Subtotal: 0.7374 100.00

Main Stack (EP-08)

Filterable

Refer to Above

0.0723 8.51

Organic Condensable

0.1752 20.60


0.6027 70.89

Total: 0.85 100.00

A. Total controlled PM10 emission factor from 10/3/2012 stack test = 0.85 lb/ton (lead produced)

3

B. 13.3% of total PM10 assumed from reverb. furnace based on 9/2012 scrubber stack test

C. Main stack speciation from 10/3/2012 stack test (Filt 8.5%, OCPM 20.6%, ICPM 70.9%)

D. Reverb. Furnace speciation from 9/26-27/2012 dry scrubber stack test

(Filt 26.9%, OCPM 14.9%, ICPM 58.2%)

E. Blast furnace, etc. emissions calculated by difference.

The potential annual PM10 emissions from the blast furnace, sweat furnaces,

refinery, and building ventilation were then estimated using the emission factor

from the stack test and a maximum annual lead production rate of 175,000 ton

lead cast/yr:

Potential Annual PM10 Emissions (Blast Furnace and Sweat Furnace) =


64.52 ton/yr

The blast furnace emissions were then separated based on the average

production rates from the 2013 and 2014 calendar years:

2014

(ton/yr) 2013

(ton/yr)

2013-14 Average (ton/yr)

Fraction of Total (%)

Blast Furnace Castable Lead Production

41242 42557 41900 91.71

Sweat Furnace Castable Lead Production

5327 2244 3786 8.29

Total 46569 44801 45685 100

Potential Annual PM10 Emissions (Blast Furnace) =

64.52 (ton/yr) * 0.9171 =

59.17 ton/yr

4

3.0 Wet Scrubber Annual Cost Effectiveness

An annualized cost of $829,716 ($4.15/scfm) was calculated for the installation of

a wet scrubber on the blast furnace following the existing baghouse. This was

estimated based on the escalated capital costs and procedures documented in

the EPA Air Pollution Control Cost Manual (APCCM). A detail of the annual cost

calculations for the wet scrubber has been provided as Table 3-1. The assumed

control efficiencies for filterable PM10 and inorganic CPM were 70% and 57%,

respectively. A low filterable control efficiency was used due to the fact that the

scrubber would be following an existing high efficiency baghouse. The inorganic

control efficiency was adapted from an Electric Power Research Institute (EPRI)

document titled "Estimating Total Sulfuric Acid Emissions from Stationary Power

Plants". The control efficiency for the emissions of organic condensable PM was

assumed insignificant. The total PM10 control efficiency was then calculated to

be 45.5%, which corresponds to a reduction of 26.92 ton/yr. The annualized cost

effectiveness for the wet scrubber following the existing baghouse is $30,822/ton

of PM10 reduced. The installation of a wet scrubber following the existing

baghouse is not economically feasible.

5

Table 3-1. Wet Scrubber Annual Cost Detail

Cost Item Cost

DIRECT ANNUAL COSTS

Operating Labor



Operating Materials -

Maintenance

Labor 2 hr/day 30.00 $/hr $21,900

Material 100 of maint. labor $21,900

Utilities

Propane Mgal/yr $/Mgal $0

Electricity 9,963,556 kW-hr/yr 0.05 $/kW-hr $498,178

INDIRECT ANNUAL COSTS, IC

Overhead 60 % of sum of operating labor and mtrl and $71,613

maintenance labor and materials.

Administrative Charges 2 % of TCI $18,768

Property Taxes 1 % of TCI $9,384

Insurance 1 % of TCI $9,384

Capital Recovery TCI $ 938,417 CRF = 0.1098 $103,033

TOTAL ANNUAL COST 4.15 $/scfm $829,716

A. Adapted from EPA Air Pollution Control Cost Manual (APCCM)

B. Design Parameters

Standard Flow = 200000 scfm

Actual Flow = 221591 acfm

Stack Temperature = 125 F

C. Capital Cost

6

Venturi Scrubber Cost 139,530 $(2002) (APPCM, Section 6, Table 2.6)

Venturi Scrubber EC 265,107 $(2002), 1.9 factor to account for fans, pumps, and other instrumentation

Cost Escalation Factor 1.32 current/2002,http://www.bls.gov/data/inflation_calculator.htm

Venturi Scrubber EC 349,942 $(Current), $(2002) * cost escalation factor

Venturi Scrubber PEC 377,937 $(Current) EC*1.08

Venturi Scrubber TCI 938,417 $(Current) PEC*1.91*1.3, 1.3 factor for retrofit

D. Electricity consumption

Pressure Drop 25 in H2O

Fan HP Requirment 1453 HP, Pressure drop * actual flow / 6356 / 0.6

Total HP Requirement 1525 HP, 1.05 * fan HP, fan + pump Electricity Consumption 9963556 kW-hr/yr

E. Capital recovery factor

Venturi Scrubber

Lifetime 15 years

Interest 7 %

CRF 0.1098

The special conditions listed in this permit were included based on the authority granted the

Missouri Air Pollution Control Program by the Missouri Air Conservation Law (specifically

643.075) and by the Missouri Rules listed in Title 10, Division 10 of the Code of State

Regulations (specifically 10 CSR 10-6.060). For specific details regarding conditions, see 10

CSR 10-6.060(12)(A)10. “Conditions required by permitting authority.”

Buick Resources Recycling Facility, LLC Iron County, S14, T34N, R2W

1. Superseding Condition The conditions of this permit supersede the 4.515 lb/hr PM10 BACT limit for EP-

08 found in Table 1 of PSD permit 012005-008C (Project 2009-11-022) previously issued by the Air Pollution Control Program. The conditions of this permit also supersede the 24.2 ton per 12-month PM10 limit for EP-08 found in special condition 2.F of permit 062011-004 (Project 2011-02-043) previously issued by the Air Pollution Control Program.

2. Buick Resources Recycling Facility, LLC shall emit less than 19.16 lb/hr of PM10 from the blast furnace and sweat furnaces combined. Buick Resources Recycling Facility, LLC shall obtain the PM10 emission rate of the blast furnace and sweat furnaces by conducting performance testing after the Process Baghouse (CD-38), but prior to the introduction of air from the Dry Lime Scrubber System (CD-35-37).

3. Buick Resources Recycling Facility, LLC shall emit less than 2.94 lb/hr of PM10

from the reverberatory furnace and afterburner. Buick Resources Recycling Facility, LLC shall obtain the PM10 emission rate of the reverberatory furnace and afterburner by conducting performance testing after the Dry Scrubber (CD-37).

4. Buick Resources Recycling Facility, LLC shall emit less than 100.64 tons of PM10 from the main stack in any rolling 12-month period.

5. Performance Testing A. Buick Resources Recycling Facility, LLC shall demonstrate compliance

with Special Conditions 2 and 3 by conducting performance testing once every five(5) years on the Process Baghouse (CD-38) and Dry Scrubber (CD-37). The applicable test methods and procedures shall be in accordance with promulgated EPA test methods. Selected test methods shall be proposed and submitted to the Air Pollution Control Program’s Stack Testing Unit for review and approval. Initial testing shall occur no later than 180 days after the issuance date of this amendment. Testing shall consist of three 1-hour test runs. Buick Resources Recycling Facility, LLC shall not operate the scrubber bypass during the testing event.

B. The dates on which performance tests are conducted shall be pre-arranged with the Air Pollution Control Program a minimum of 30 days prior to the proposed test dates so that this Program may arrange a pretest meeting, if necessary, and assure that the test dates are acceptable for an observer to be present. A completed Proposed Test Plan form (copy enclosed) may serve the purpose of notification and shall be approved by the Air Pollution Control Program prior to conducting the required emission testing.

C. Two copies of a written report of the performance test results shall be

submitted to the Director of the Air Pollution Control Program within 30 days after completion of any required testing and receipt of analysis. The report shall include legible copies of the raw data sheets, analytical instrument laboratory data, and complete sample calculations from the required EPA test method for at least one sample run.

6. Recordkeeping and Reporting Requirements

A. Buick Resources Recycling Facility, LLC shall maintain all records required by this permit for not less than five years and shall make them available immediately to any Missouri Department of Natural Resources’ personnel upon request.

B. Buick Resources Recycling Facility, LLC shall report to the Air Pollution

Control Program’s Compliance/Enforcement Section, P.O. Box 176, Jefferson City, MO 65102, no later than ten days after the end of the month during which records indicate an exceedance of an emission limitation imposed by this permit.

Basis From the 2012 stack test, the emission factor for total PM10 was 0.85 lb/ton. At 175,000 ton/yr

lead production and assuming a 1.3 safety factor this would give a lb/hr emission rate for the

main stack of 22.1 lb/hr (175000*0.85*1.3/8760).

The 2012 stack test on the dry scrubber and main stack gave a split of 13.3% of the emissions

from the reverb. furnace.

Reverb emission rate = 2.94 lb/hr (22.1*0.133)

Blast furnace emission rate = 19.16 lb/hr (22.1-2.94)

A ton/yr 12-month emission rate could then be calculated from the 22.1 lb/hr main stack

emission rate when the dry scrubber was operating and 32.76 lb/hr emission rate from December

2011 before the dry scrubber was installed (this is equivalent to the emission levels when the

facility is by-passing the scrubber and adding soda ash to the feed to control SO2

emissions). This would give a 12-month emission rate of 100.64 ton/yr.

(22.1*8040 + 32.76*720)/2000=100.64 ton/yr

8040+720=8760 hours per year, or 365 day/yr * 24 hr/dy

1

Hess, Alana

From: Lanzafame, Jim <[email protected]>

Sent: Wednesday, February 15, 2017 12:20 PM

To: Hess, Alana

Subject: RE: Partial response to recent PM10 discussions

Joseph,

Give me a call when you can. Suggest we “complete” the cost analysis for all kettle heat stacks (indicated 1 kettle heat

stack was 0.32 t/yr.).

Jim L.

Senior Environmental Technical Engineer

Office, 573-626-3406

Cell, 636-575-2797

From: Hess, Alana [mailto:[email protected]] Sent: Wednesday, February 15, 2017 12:11 PM To: Lanzafame, Jim Cc: Crocker, Margaret; Joseph Stolle ([email protected]) Subject: RE: Partial response to recent PM10 discussions

Jim,

If all of the kettles combustion emissions were combined and routed to one scrubber, the overall cost ($/ton) would be

less. Please submit a cost analysis for this scenario.

Thanks,

Alana L. Hess, PE

Environmental Engineer III

Missouri Department of Natural Resources

Phone: (573) 526-0189

Fax: (573) 751-2706

E-mail: [email protected]

Mailing Address:

Air Pollution Control Program – Permits Section

Attn: Alana Hess

2

P.O. Box 176

Jefferson City, MO 65102

From: Lanzafame, Jim [mailto:[email protected]] Sent: Friday, February 10, 2017 4:11 PM To: Hess, Alana Cc: Crocker, Margaret; Joseph Stolle ([email protected]) Subject: Partial response to recent PM10 discussions

Alana,

Attached are our responses to those items we promised for today 02/10. We will continue to provide information on

the previously submitted anticipated schedule. Expect next submittals 02/17.

TASK

Decide whether limit should be based on feed or castable lead units

completed __02/10_____________

RESPONSE

BRRF is planning to submit alternate emission limits based on tons of material fed to the furnaces.

TASK

Consultant’s review of BACT equipment listed in Ms. Hess’s email and explanation of why they are not feasible.

completed _02/10______________

RESPONSE

BRRF’s consultant has provided the following response.

On Thursday, January 26, 2017 the MDNR provided a list of potential BACT controls for primary PM10 emitted from the

dross and refinery kettle heat stacks. The list of potential BACT controls included an evaluation of a wet scrubber assuming an unitized annual operating cost of $2/scfm (fiber-bed scrubber, 1995 dollars). The total annual operating cost was then calculated by converting from 1995 to 2017 dollars and assuming a standard flow rate of 1,000 scfm. Unit Annualized Operating Cost = $2/scfm (1995 dollars) Unit Annualized Operating Cost = $3.15/scfm (2017 dollars) calculated using the US inflation calculator Total Annual Operating Cost = $3,150/year (2017 dollars) The emission reduction associated with a wet scrubber is 0.32 ton/yr. (primary PM10), which corresponds to an MDNR calculated cost effectiveness of $9894.51 (calculated difference is believed to be due to rounding). The MDNR stated that this is within the feasibility range.

The BACT analysis provided by Doe Run in August 2015 utilized a wet scrubber unit annual operating cost of $17/scfm,

which is believed to be on the extreme low end of the range for the size of scrubbers being analyzed. A $3,150 annual

operating cost is not realistic and would not even come close to covering the operating labor and maintenance

costs. The operating maintenance and labor costs have been provided below (the low end of the range for only a part-

time operator and labor hours per day were used):

Wet Scrubber Annual Labor and Maintenance Costs

Cost Item Cost

3

DIRECT ANNUAL COSTS

Operating Labor



Maintenance

Labor 2 hr/day 30.00 $/hr $21,900

Material 100 of maintenance. labor $21,900

Total $94,170

Considering only the part-time operating labor and maintenance costs gives a cost effectiveness of $294,281/ton

($94170/0.32 tons) is calculated, which is not cost effective. Use of just a full-time operator would increase the cost by a

factor of roughly 2.8. For an emission source this small, and given the information provided above, we do not believe

that a wet scrubber is cost effective for the control of PM10 emissions from the propane burners associated with the

dross and refinery kettles.

BRRF would welcome the opportunity to discuss its response to your question.

No need to reply.

Jim L.

Senior Environmental Technical Engineer

Office, 573-626-3406

This message is intended solely for the designated recipient and may contain confidential, privileged or proprietary information. If you have received it in error, please notify the sender immediately and delete the original and any copy or printout. Please note that any views or opinions presented in this e-mail are solely those of the author and do not necessarily represent those of The Doe Run Company. Finally, the recipient should check this message and any attachments for the presence of viruses or malware. The Doe Run Company accepts no liability for any loss or damage caused through the transmission of this e-mail.

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