II

.P889233498

1111111
11
1111111111
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United States

Office of Air Ouality

Environmental Protection

Planning and Standards

Agency

Research

Triangle

EPA;~j~0~82;013b-

,i

April1989

Park NC 27711

Air

r~nAEPA Sulfur Oxides :

\1111h
Emissions
fron?

Final
EIS

Fluid Catalytic
Cracking Unit

Regenerators

Background
Information

for

From u Igated
Standards

'

I
st

II

REPRODUCED

BY

U.S. DEPARTMENT
NATIONAL

TECHNICAL

SPRINGFIELD,

OF:.COMMERCE
INFORMATION

VA. 22161-

SERVICE

TECHNICAL
REPORT
DATA
~Ple~se reed 1,2srrucn'ons on the ~prcrsr before cornplerinpl

1Ek~i~TOrg-B2-013b n.
TITLE

AND

Sulfur

I~C~"-"~~"S'ag"s ,ns

SUBTITLE

Oxides

15.

Emissions

U'nit Regenerators
Promulgated

from

Fluid

- Background

Catalytic

Information

Cracking

for

16.PERFORMING
ORGANIZATION
CODE
18. PEAFORMING

.PERFORMING

ORGANIZATION

NAME

AND

ADDRESS

lo.

Office of Air Quality Planning and Standards

Envi ronmental Protection
Agency
Research Triangle
Park, North Carolina
27711
12. SPONSORING

AGENCY

of

Air

and

Research

~6.

ABSTRACT

Park,

NO.

AND PERIOD

COVERED

Final
10. SPONSORINGAGENCYCODE

Protection

Triangle

SUPPLEMENT

REPORT

ECEMENTNO.

13. TYPE OF REPORT

and Standards

Radiation

Environmental

II.

Planning

PROGRAM

ORGANIZATION

~1.CONTRACT/GRANT
NO.

NAME AND ADDRESS

DAAfor Air Quality

Office

DATE

1989

Standards

.AUTnOR(S)

U.S.

REPORT

I April

Agency

North Carolina

27711

EPA/2OO/04

NOTES

Standards
of performance
to control
emissions
of sulfur oxides (SOx) from new,
modified,
and reconstructed
fluid catalytic
cracking unit regenerators
are being
promulgated
under Section 111 of the Clean Air Act.
This document contains
a summary

of public conrPTients,EPAresponses, and a discussion of differences

and promulgated

I(EY

WORDS

nND

DESCRIPTORS

of Performance
processes

Petroleum

refineries

catalytic
Oxides

ANALYSIS

Air Pollution
I Sulfur
Oxides

Standards
Industrial

Fluid

DOCUMENT

b.lDENTIFIERSIOPEN

Air Pollution
Pollution
Control

Sulfur

between the proposed

standard.

Stationary

ENDEDTERMS

1C. COSATI FildlCroup

Control

13B

Sources

cracking

8. DISTRIBUTION STATEMENT

) i s. SE CUR IT v C~S~T~;iS~cporr7--rZ~7?J~5~?I

Unlimited

I Unclassified
?O. SECURITY

CLASS lTi~ir p~gel

Unclassified
EP*

form

2220-1

(Re.

6-77)

p~rilevs

E51TION

15 OBSOLETE

22. PRICE

I ~Ao~

Sulfur

Oxides

Emissions

from

Fluid Catalytic Cracking

Unit Regenerators
Background
Information
for Promulgated Standards
Emissions

Standards

U.S. ENVIRONMENTAL

Division

PROTECTION

AGENCY

Office of Air Quality Planning and Standards

Research Triangle Park, North Carolina 27711
April 1989

I-R

DISCLAIMER

This report
has been reviewed
by the Emission
Standards
Division,
Office
of Air Quality
Planning
and Standards,
Office
of Air and
Radiation,
Environmental
Protection
Agency,
and approved
for
publication.
constitute

charge
and

to

Mention
endorsement

Federal

non-profit

Library
Services
Research
Triangle
from the National
Road,

Springfield,

of company
by EPA.

employees,
or~aizations

or product
Copies
are

current
--

as

names does not

available
free
of

contractors
supplies

permit

-?

and grantees,
--

from

the

Office,
MD-35, Environmental
Protection
Agency,
Park NC 27711; or may be obtained,
for a fee,
Technical
Information
Services,
5285 Port Royal
Virginia

22161.

ii

ENVIRONMENTAL

PROTECTION

Background
Information
Environmental
Impact
for

Sulfur

Fluid

Oxides

AGENCY

and Final
Statement

Emissions

From

Catalytic
Cracking
Regenerators

repared

Unit

by:

~i~t~
k R.

Director,

U.S.

i.

/(Dat

Emission

Standards

Environmental

Research

Farmer

Triangle

Park,

-The emission

Agency

NC 27711

standards

new, modified,
at

111

will

limit

emissions

and reconstructed

regenerators
S~ction

Division

Protection

of

petroleum
the

Clean

fluid
Act

sulfur

catalytic

refineries.
Air

of

cracking

The standards
and

are

based

oxides

on

from

unit

implement
the

A~ninistra-

tor's
determination
of 3une 11, 1973 (38 FR 15380) that petroleum
refineries
contribute
significantly
to air pollution
which may
reasonably
be anticipated
to endanger public health or welfare.
2.

Copies of this
document
have been sent to the following
Federal
Departments:
Labor,
Health
and Human Services,
Defense,
Transportation,
Agriculture,
Cor~merce, Interior,
and Energy;
the National
Science
Foundation;
the Council
on Environmental
Quality;
members
of the State
and Territorial
AirPollution
Program Administrators;
the

Association

Regional
3.

For

of

Administrators;

additional

Mr. Robert

Standards

Copies

of

5285 Port

Springfield,

Pollution

and

other

Control

interested

contact:

L. qjax

Development

this

Technical

Royal

Branch

(MD-T3)

Protection
Agency
Park,
NC 27711
541-5578

document

U.S. EPA ~ibrary

Research Triangle
National

Air

information

U.S. Environmental
Research
Triangle
telephone:
(919)
4.

Local

may be obtained

(MD-35)
Park, NC 27711
Information

Road

VA 22161

Service

from:

Officials;

parties.

EPA

TABLE

OF CONTENTS

Section

1.0

P age

SUMMARY

1.1

...................

.....

Summary of Changes
Definition

of Affected

1.1.2

Definition

of

1.1.3

Methods

1.1.4

Definition

1.1.5

Averaging

1.1.6

Clarification

for

1.1.7

Reduction

1.1.8

Minor

Summary of
1.2.1

1.2.3

Feed

of

Test

Method

...................

Energy

and

Action

...................

...

.....
.......
.....
....

.........,

Promulgated
of

Need

2.2

Regulated

2.3

Designation

2.4

Format

2.5

Level

2.5.1
2.5.2

for

t~e

Economic

Action

..,...

of Promulgated
1-6

............

of

1-6

and Irretrievable
Resources

.....

Environmental
and Energy Impacts
of Delayed Standards
.......
Com~ents

............

of

Standards

Standards

Standards

1-7

2-1

..............

2-5

Facility

.........
.~.

2-8
......

................

for

Add-on

Level

of

Standard

Controls

1-7

..............

......

Level
Add-on

1-6

. 2-1

of Affected
the

1-6

Promulgated

Impacts

Irreversible
Commitment

Pollutant

of

1-5
1-6

-GENERAL COMMENTS ...................

2.1

1-4

1-6

Considerations

Summary of Public

1-3

Calculation

Locations

r.

1-2

1-4

Requirements.

Impacts

Action

1-2

Pollutant

and Sampling

Impacts

1-1

Determinations.

in Reporting

1.2.3.2

......

Times for Compliance

..

1-1

....,....

of Regulated

Changes

Other

.........

Facility

Compliance

of

1.2.3.1

2.0

Fresh

Environmental

1.2.2

1.3

Proposal

1.1.1

Procedures

1.2

Since

1-1

Control
for
..............

2-11
2-16

Standard
FCCU's

.....

2-16

without
2-17

j Precedingpage blank

TABLEOF CONTENTS
(Continued)
Section

Page
2.5.3

2.6
3.0

4.0

5.0

6.0

7.0

Feed

Sulfur

Cutoff.............

Averagi ny Times

2-19

.................

2-19

CONTROL TECHNOLOGYCOMMENTS .........

3.1

SO, Scrubbers

...................

3.2

SO, Reduction

Catalysts

3.3

Low-Sulfur

Feedstocks

..

...

3-1

3-1
..

............

3-6

...............

3-7

ENVIRONMENTAL
AND ENERGYIMPACTS COMMENTS.......

4-1

4.1

Model Plants

4-1

4.~

Water

Impacts

4.3

Solid

Waste

4.4

Energy

4.5

Air

Used for

Impact

Analyses

. 4-2
Impacts

Impacts

Impacts

................

4-7

..................

4-10

...................

. 4-11

COSTS AND ECONOMIC IMPACTS COMMENTS

5.1

Scrubber

5.2

SO, Reduction Catalysts

5.3

Economic

Costs

General

6.2

With

6.3

Without

6.4

Feed

..........

5-1

..,...............

Impact

COMPLIANCE TESTING
61

......

5-1

Costs .........,

Analysis

5-10

.........,....5-11

AND MONITORING

COMMENTS .......

...................
Add-On

Control

Add-On
Sulfur

COMPLIANCE

COMMENTS

7.1

Source

7.2

Compliance

7.3

Changing

..
Devices

Control

Cutoff

.........,

Devices

..........

6-15
6-29

..................

7-1

Oper--~%on During Malfunctions

iJsing Partial

6-1
6-2

................

Compliance

6-1

Scrubbing

Method

............

.......
........

7-1
7-2
7-2

::

TABLE
OFCONTENTS
(Concludeh)
Section

Page

8.0

MODIFICATION/RECONSTRUCTION

COMMENTS ..........

8-1

9.0

RECORDKEEPJNG

AND REPORTING

COMMENTS

9-1

10.0

MISCELLANEOUS

COMMENTS

APPENDIX A - Control

..........

.................

Equipment

Costs

10-1

and Fifth

vii

Year

Impacts

LIST

OF TABLES

Table
1-1

A-i
A-2

Page
LIST OF COMMENTERSON PROPOSED STANDARDS
OF PERFORMANCEFOR SULFUR OXIDES EMISSIONS

FROMFCCU REGENERATORS
,,,,,,,........

1-8

BASIS FOR DETERMININGSCRUBBERANNUALCOSTS ,,,,

A-i

CAPITAL COST FOR SODIUM-BASEDHIGH ENERGY

VENTURI

SCRUBBING SYSTEM AND

PURGE TREATMENT FOR MODEL UNITS

A-3

,,,.,,,,,,

A-2

ANNUAL COST OF SODIUM-BASED HIGH ENERGY

VENTURISCRUBBING
FOR 2,500 m3/sd MODELUNITS ...
A-4

A-3

ANNUAL COST OF SODIUM-BASED HIGH ENERGY

VENTURISCRUBBING
FOR 8,000 m3/sd MODELUNITS ...
A-5

A-4

ANNUAL COST OF SODIUM-BASED JET EJECTOR

VENTURI SCRUBBING SYSTEM AND PURGE

TREATMENT
FOR MODELUNITS ,-,
A-6

,.,......,

A-5

ANNUALCOST OF SODIUM-BASED JET EJECTOR

VENTURI
SCRUBBING
FOR2,500 m3/sd
MODEL UNITS
A-7

,.,,,.,.,..........

A-6

A-7

ANNUALCOST OF SODIUM-BASED JET EJECTOR

VENTURJ
SCRUBBING
FOR8,000 m3/sd
MODEL UNITS

A-8

,...,,.,......,...,

DUALALKALI SCRUBBINGSYSTEMCOSTS BASED

ON 1.5

WEIGHT PERCENT SULFUR FEED

:i

....,....

A-8

.,,......

A-9

A-9

ELECTROSTATICPRECIPITATOR COSTS

A-IO

FIFTH YEARCAPITAL COST IMPACTS ,.,,......

A-ii

A-ii

FIFTH YEAR ANNUALCOST IMPACTS

A-12

V111

,,..,,.,,.

On January

17, 1984, the

(EPA) proposed
sions

from fluid

refineries
Air

standards
catalytic

Public

revisions
sions
for

to the

included
FCCU's

a daily
tions,

and the
would

proposed

revisions

air

comments
the
1.1

EPA's

revisions

the

over

Public

companies.

CHANGES

The proposed

SINCE

standards

The primary

on

determinadeter-

on the

included

commenters

two

association,

State
an

summary of

serve

as the

proposal

basis

for

and promulgation.

PROPOSAL

were

changes

revised

were

as a result

made

in the

Definition

of Affected

Definition

of

Methods ~for Compli ance Determinations

Definition

Averaging

Clarification

Fresh

standard

compliance

This

comments
between

The revi-

Most of the

trade

individual.

standards

in

requested

commenters

to these

standards

of compliance

daily

an industry

and a private

Clean

compliance

were

petroleusi

111 of the

for the

responded.

Other

agencies,

responses

the

comments

at

(50 FR 46464).

daily

which

emis-

On November 8, 1985,

pollutant

making

times

made to the

SUMMARY OF

c omment s .

for

(SO,)

proposed

determination

and 12 commenters

company,
and

oxides

of Section
on the

regulated
the

Agency

(FCCU) regenerators

were proposed

controls,

be made.

control

engineering

unit

requested

in the

methods

refining

pollution

for sulfur

the authority

rule

averaging

minations

represented

proposed

the

Protection

and 18 commenters responded.

add-on

basis,

Environmental

were

a change

with

U.S.

cracking

comments

the Federal Register

SUMIARY

of performance

(49 FR 2058) under

Act.

1.0

of reviewing

following

public

areas:

Facilitj,
Feed

of Regulated

Pol'lutant

Times for Compliance

of Test

Method

Calculation

Procedures

and Sampling

Lo ca t i o ns

Reductions

in Reporting

and

Compliance

Testing

Requirements

1.1.1 Definition of AffectedFacility

The proposed
facility.
the

standards

identified

This was done because

FCCU regenerator.

each regenerator

SO, are generated

Some new FCCU's are designed

1-1

as the

affected

in and emitted
to incorporate

from
more

than

one regenerator.

The EPA believes

that

identifying

each FCCU

regenerator
as the affected facility
for multiple regenerator configurations is unreasonable.
If only one regenerator in a multiple
regenerator

configuration

would be impossible
to isolate

in some multiple

regenerater.

minimize

the cost

unlikely

that

an

facility

is now defined

of Fresh

The standards

include

of

sulfur

possibility
cutoff

was

that

exists

is

that

by identifying

fractionator
of the

allowed

cutoff

a refiner

the

all

that

by including

specifically

from

the

could

it

is

config-

others.

Therefore,,

regenerators

serving

which limits
feed

circumvent

hydrocarbon

unit

because

Therefore,

these

to

the

the

an FCCU.

streams

recycled

units

definition

of

fresh

not

circumvent

the

would

as "fresh

feed" low sulfur-containing

petroleum

and the gas recovery

feed

feed

The revised

derivatives

unit

from

are not a

the

gas recovery units.

The

feed sulfur

a refiner

identifies

"fresh

cutoff,
fresh

feed"

facility.

ens-ure

fractionator,

1.1.3

to include

in the

or gas recovery

to

definition
them

regenerator

without

a feed sulfur

recycle from the fractionator'and

the

unit,

Feed

as "fresh

affected

revised

sulfur

work on the

in a multiple

or reconstructed

Definition

amount

part

arrangements

reactor.

1.1.2

the

ducting

it

of the exhaust gases from the

and downtime for revamping

would be modified

FCCU

standards,

Furthermore, because the refiner would want to

only one regenerator

the affected

to the

regenerator

and measure the SO, content

affected

uration

were to become subject

from the

as"recycle",

thus

FCCU,

excluding

feed."

Methods for Compliance Determinations

At proposal,

required

to

a continuous

identify

excess

emission
emissions,

monitoring
which

were

system

(CEMS) was

defined,

for

the

standard

for FCCU's with add-on controls, as sulfur dioxide (S02) in excess of

the control deviceoutlet
concentration measured during the most recent
performance
S02 emission

test.

The proposed

monitoring

standard

system only

specified

at the

control

the

use of a continuous

device

outlet.

standard for FC6U's without add-on controls also identified

which were defined
a dry basis.)

as SO2 in excess

The EPA received

of 300 vppm at O percent

comments that

1-2

this

approach

(The

excess emissions,
oxygen on
would result

in

an

unreasonable

excess

concentrations
test.

changed

These comments,

eliminate

the

performance

daily

the

in part,

led EPA to revise

of the
for

add-on controls
rather

(90 percent

FCCU's

than using

test.

the

daily)

compliance

basis.
limit.

they

Assurance
for

daily

The

the

are

of the

for

to identify

is less

FCCU's

on a

the

stringent)

need
now

Emission

for

Monitoring

for

FCCU's

to

FCCU's with

consists

of

at

least

18 \/alid

consists

of

at

least

2 valid

the

EPA concluded

determinations

30 successive,

on January

standards

that
(i)

60 Appendix

Systems

without

compliF,

As~surance

Require-

Used for

Compliance

add-on

controls

compliancewith

now

the

add-on

control

devices,

They.require

rolling
hours

data

22.valid

calendar

days.

of

where

data,

minimum

days

A valid
a valid

day
hour

points.

of Regulated Pollutant

with add-on control

change were:

with only the

standard.

of

As proposed

is required

are now used for

demonstrate

out

Definition

SO2 monitor

1 - Quality

have been incorporated.

of every

on a continual

to 40 CFR Part

Procedure

8 testing

standards

facility

S02 monitors

kg coke burn-off

requirements

all

on the

of compliance

continuous

of data

for

to

for FCCU's with add-on controls

subject

standard

Method

9.8 kg SO,/1,000

1.1.4

performance

and

to comply specifically

Procedures,

Gas Continuous

De te rm i n a t i o n ."

of data

inlet

approach

controls

emissions

Only an outlet

determinations,

data

this

determination

status

Because

data

the

definition

add-on

or 50 vppm, whichever

50 vppm emissi`on

For

with

The standard

seeks

requires

during

emission

excess

if the owner or operator

ments

device

S02 as the controlled

pollutant and requires the use of
S02 monitors located at the control device inlet and outlet

determine

"Quality

measured

excess

now require

reduction

identifies
continuous

ance

control

level

standards

basis,

(i;e.,

when

from the

dependence

for a compliance

to

limit

test.

Both

without

emissions

for

the

17, 1984,
FCCU's.

regulated

SOx was the

After

further

pollutant

resulted

(2) GEMSare not available

above,

in requiring
for

the
both

inlet

SO,, but are

1-3

standard

The reasons
change

pollutant

consideration,

for the

devices should be S02.

as described

regulated

the

for

FCCU's

for this

to daily

compliance

and outlet

monitors;

available

for

S02;

(3)

sulfur trioxide (S03) constitutes a small portion of total SO, emissions;

and (4) best demonstrated technology (i.e.,

scrubbers) would be essenti-ally

the same for SO2 and SO,.

For the standard

for FCCU's without

add-on control

devices,

the

Agency concluded that the regulated pollutant should remain SO,, because
SO3 could constitute a significant portion of the total SO, emissions
from FCCUls using SO, reduction
included

in the

were received

revisions

proposed

These conclusions

on November 8, 1985.

were

No comments

on using SO2 as the regulated

pollutant

for FCCU's with

but comments were received

regarding

SO, as the

add-on controls,
regulated

catalysts,

pollutant

for FCCU's without

add-on controls.

No additional

data or information was obtained that was sufficient for the Agencyto
conclude
add-on

that
controls.

on control
devices

1.1.5

SO2 should
Thus,

devices

the

be the
the

regulated

pollutant

pollutant

regulated

pollutant

to

7 days.

to determine

considered
performance.
average

period

for

and

FCCU's

without

for

ration

the

normal

both

the

with

the

Clarification

compliance

and

FCCU's with

would

times

better

add-on
take

the

other

rolling
controls

into

7-day calendar

for

catalyst

of a I-day

was changed to a rolling

averaging

scrubbers

on SOx reduction

The proposed

cutoff

for

performance

selection
for

controls

variability,

so we would have daily

1.1.6

standards

add-on

results

in scrubber

indicatedthat

time for the feed sulfur

be consistent

test

of process variability

The analysis

add-on control

has changed since proposal from

source

long term variability

the effect

add-

is SO,.

The EPA analyzed

the

for FCCU's without

for FCCU's with

is SO2 and for FCCU's without

Averaging Times for Compliance

The averaging times forcompliance

3 hours

to

regulated

conside-

averaging

7-day averagetwo standards,

of Test Method Calculation

for

FCCU's without

of Method 8 to determine
The proposed

calculation
standards

the

total

add-on

Procedures and Sampling

controls

SO, emissions

standards

did not provide

sufficient

procedures

for determining

total

were

revised

to

include

and

determinhtions.

Locations

The standard

,.J

modifications

1-4

requires

the use

from affected

facilities..

information

SO, emissions.
to

the

regarding

The

calculation

procedures

specified

emissions
upstream
flue

dard

for

standards

of the

is unsafe

high

carbon

required

monoxide

to require

FCCU's

without

rulemaking

devices,

a standard

add-on

with any one of these

The standards
flexibility

revised

The stanto

allow

For FCCU's

of the CO boiler.

Requirements
the

refiner

with a standard
for

control

devices,

the refiner

to demonstrate

due to the

location.

been

that

the recommendedlocation for SO2 monitoring has

provides

Initially,

stated

manual sampling

has

an a\ternativestandard

without

cutoff.

One corrsnenter

at this

controls

`Reduction in Reporting

elect

SOx

to be conducted

upstream or downstream of the CO boiler.

been changed to downstream

control

of total

sampling

to conduct

and pressures
add-on

with add-on controls,

This

that

(CO) boiler.

personnel

gas temperatures

sampling either

1.1.7

calculation

as S02.

The proposed
it

in Method 8 to allow

add-on
and

may elect
at

compliance

with

one of the

in compliance

a later

time,

but also

devices,
content

compliance

the

refiner

alternative

way to allow the

objectives

add-on

sulfur

to demonstrate

and,
in this

control

a feed

standards

were developed,

for

may

standards,

r.efiner

to encourage

greater

the use of

hydrotreating
and SO, reduction catalysts.
The reporting and recordkeeping requirements for the proposed standards required that a refiner
give

a 90-day

different

prior

notification

standard

and'conduct

Since proposal,

of his

intent

a performance

to be subJect
test

with

each change.

the EPA has changed thestandards

c ompl i a nce dete rmi n at i o ns .

This change

to conduct performance tests

requires

to a

to require

an owner or operator

every day regardless.of

the standard

which the

owner or operator

seeks

to comply.

The 90-day

notification

significantly

reduces

a refiner's

flexibility

other

when the owner or operator

standards,

subject
identified

to the

regardless
Particular

without

in the

required quarterly,

next

compliance

Thereis not

seeks to comply with one of the

of whether
standard

with

prior

significantly
increasing EPA's ability to enforce the standard.
fore, the regulation
has been changed so that prior notification
required

dai~y

the

owner or operator

previously.
report.

All changes

Compliance

reports

has been
must be
are

unless no exceedances have occurred during a

1-5

particular
quarter,
in whichcase semiannual reports may be submitted.
The proposal had not allowed semiannual reporting when there were
periods of no exceedances.
If an owner or operator elects to comply
with an alternative
SOx standard, a quarterly report with notification
of the change must be submitted to the Administrator in the quarter
following
1.1.8

such a change

even if no violations

of a standard

have occurred.

FljnorChanges

Several changes have been made to the SO, emission percent reduction equation and SO, emission rate equation such that direct results
from the
1.2

test

methods

can be used in the equations.

SUMMARY
OF IMPACTSOF PROMULGATED
ACTION

1.2.1

Environmental Impacts of Promulgated Action

Environmental

49 FR 2058.
minimal

1.2.2

impacts

The revisions

effect'on

of the

proposed

standards

are described

to the

proposed

standards

will

of the

standards.

the environmental

impacts

in

have a
^7;

Energy and Economic Impacts of Promulgated Action

The energy

Chapters

and economic

of the

final

background

have been revised;

standards

The nationwide

are greater

cumulative

the

than

capital

would be 8117 million

(reported

if

scrubbers

all

sodium

above 0.30

are

percent

cost

dollars).
contents

are

described

information

used

by weight.

would

estimates

not

differ,

because

weight

percent

1.2.3

Other

1.2.3.1

Implementation

percent

need

to

therefore,

costs

are

control

not

included

in Fourth

units

install

processing

of

with

in

sulfur

1984 dollars),

sulfur

year
quarter

levels

nationwide
1984

feeds with sulfur

These

presented

FCCU.'s

of these

feed sulfur

a scrubber.
those

feed

in fourth

impacts

at proposal.

year

fifth

would be at the

The costs

quarter

with

(reported

from

for

fifth

facilities

cracking

of 0.30 weight

in the

in

document

and economic

calculated

The corresponding

would be $45 million

Fluid catalytic

therefore,

at

cost

those

costs

standards

annual

standards

The energy impacts have not changed since proposal.

for sodium scrubbers

of the

impacts

6, 8, and 9 of the proposal

(BID).

A-ii

?~

cutoff

and

nationwide

Tables
contents

cost

A-10

and

of

0.30

here.

Considerations

Irreversible

of these

and

standards

Irretrievable

will

1-6

Commitment

result

in the

of

use

of

Resources.

sodium-based

scrubbers

in many cases.

natural resources,
However,

the

compared

to national

"Sulfur

Oxides

lost

the

adverse

shown

waste,

from delaying
1.3

rate

water

regulatory

proposed

were

requests
their

for

This

a public

are

interested

parties

categorized,

of the

year

to

be small

proposal

impact

BID.
7-6

standards

or energy

air

The annual

represents

the

delayed.

No

are

impacts

given

18 correspondents

proposed

on the proposed

hearing

so none

are

expected

commenting

an the

in Table

A list

presented

to

standards.
to those

under

the

to

the

their

preamble

comments have been

following

General

Comments (Section

Control

Technology

Environmental

Costs

Compliance Testing

Compliance

Modification/Reconstruction

Recordkeeping

and Reporting Corranents (Section

Miscellaneous

Comments (Section

topics:

2)

Comments (Section
Impacts

and Economic Impacts

3)

Comments (Section

Comments (Section
7)
Comments

1-7

10)

(Section

4)

5)

and Monitoring Comments (Section

Comments (Section

and

The corrsnents from

and Energy

of commenters,

document.

pertaining

proposed

and from 12

There were no

assigned

of this

and EPA's responses

are

revisions.

numbers

1-1

comments

standards,

was held.

EPA docket

from the

and they

adversely

in Table

the

BID for the

documentpresents

resulting

expected

would

column

each

from

and the

regulation

of

COMMENTS

commenting

correspondence

use

action.

and the

affiliations,

7-6

pollution,

received

standards

correspondents

is

standards

in Table

for

SUMMARY OF PUBLIC

Letters

additional

and Energy Impacts of Delayed Standards.

Reduction"

reductions

solid

resources

of these

Emissions

emission

the

use.

in implementation
at

necessitate

sodium carbonate and sodium hydroxide.

of these

Environmental

quality

will

especially

commitment

1.2.3.2
Delay

This

8)

9)

6)

TABLE I-i.
LIST OF COMMENTERSON PROPOSED
STANDARDS OF PERFORMANCEFOR SULFUR OXIDES
EMISSIONS

FROM FCCU REGENERATORS

Commenter and Affiliation

1.

Docket

Mr. J.A. Stuart

South Coast Air Quality
9150

Flair

Item No.

IV-D-1
Management District

Drive

El Monte,

CA

91731
IV-D-2

2.

Mr.

J.J.

Moon

Ph ii ii ps Petroleum Company
704 Phillips
Building
Bartlesv.ille,

3.

Mr. Phillip
Conoco,
P.O.

IV-D-3

TX

77252

Ms. Gael Fletcher

Koch Refining Company
St.

IV-D-4

Box 43596

Paul,

MN 55164

Mr. R.V. Struebing

Getty

Oil

P.O.

Box

fulsa,
6.

L. Youngblood

Box 2197

P.O.

5.

74004

Incorporated

Houston,

4..

OK

Mr.

1650

OK

74102

William

American

IV-D-5

Company

F. O'Keefe

Petroleum

IV-D-6

Insti.tute

1220 L Street,
Northwest
Uashington,
D.C.
20005
7.

Mr,

Peter

W. McCallum

The Standard

IV-D-7

Oil Company

Midland
Building
Cleveland,
OH 44115-1098
8.

Mr. J.R.

Bowler

CITGO Petroleum
Lake
Box

Lake
9.

Charles

~~-D-8

Corporation

Operations

1562

Charles,

LA

70602

Mr. R.H. Murray

Mobil Oil Corporation
3225

Gallows

Fairfax,

1V-D-9

Road

VA 22037

1-8

TABLE 1-1.
STANDARDS

LIST
OF COMMENTERS ON PROPOSED
OF PERFORMANCE
FOR SULFUR OXIDES

EMISSIONS FROM FCCU REGEN~RATORS

Commenter

10.

and

Mr. J.
Texaco,

Affiliation

Donald
U.S.A.

1050 17th
Washington,

Docket

Annett

Street,
D.C.

Item

IV-D-I0

N.W.
20036
JV-D-11

II.

Mr.

A.G.

Shell

Smith

Oil Company

P.O.
Box 4320
Houston,
TX 77210

12.

Mr. Michael J.Duffy

Ashland
Petroleum
Company
P.O.

13.

14.

Box

KY

Mr.

Arnel

L.G.

Oil

Products

Box

2001

Houston,

TX

Mr.

Johnson

J.M.

U.S.A.

TX

Mr.

Johnson

A.R.

77001
IV-D-15

and Webster
Box

Boston,

25

IV-D-14

2180

Houston,

Mr.

Company

77252

Company,
Box

P.O.

17.

IV-D-13

P.O.

Stone

16.

41114

Gulf

P.O.

15.

391

Ashland,

Exxon

IV-D-12

Engineering

Corporation

2325

M~

02107

Franklyn

Isaacson

Summit

Court

Westfield,

NJ

IV-D-1~

07090

Mr.
Bill
Stewart
Texas
Air
Control

IV-D-18
Board

6330 Highway 290 East

Austin,
TX 78723
18.

Mr.

3.G.

Amoco Oil
P.O.

Box

Chicago,

Huddle

IV-D-20

Company
6110A

IL

60680

1-9

No,

:r3
TABLE 1-I.

LIST

OF COMMENTERS ON PROPOSED

STANDARDS OF PERFORMANCEFOR SULFUR OXIDES

EMISSIONS

Commenter

19.

and Affiliation

Mr. Allan
Diamond

P.O.

A. Griggs

Item

No.

IV-K-1

Box 20267

TX

20. Mr. Franklyn

25 Sumr~it

J.G.

78220-0267

Isaacson

1V-K-2.

Court

Westfield,
Mr.

Docket

Shamrock

San Antonio,

21.

FROM FCCU REGENERATORS

NJ 07090~
Huddle

IV-K-3

Amoco Oil Company

P.O.

Box 6110A

Chicago,

IL

60680

22. Mr.M.J. Hage

Mobi~ Oil
3225

23.

Corporation

Gallows

Rd.

Fairfax,

VA 22037

Mr.

Wasil~a

N.J.

IV-K-4

IV-K-5

SOHIO

Midland
Building
Cleveland,
OH 44115-1098
24.

Mr.

J.

Donald

Annett

Texaco,
USA
1050 17th Street,
Washington,
D.C.
25.

Mr.

J.R.

IV-K-6

N.W.
20036

Bowler

IV-K-7

CITGO Petroleum
.Corporation
bake Charles
Operations
Box

1562

Lake
26.

Mr.

Charles,
James

Lyondell

LA

70602

H. O'Brien

Petrochemica~

IV-K-8

Company

1200
Lawndale
Box 24 51

27.

Houston,

TX

Mr.

Johnson

J.M.

Exxon
P.O.

Company,
Box

77252-2451
IV-K-9

U.S.A.

2180

HOvS~on,
TX77001
1-10

TABLE 1-I.

LIST

OF COMMENTERS ON PROPOSED

STANDARDSOF PERFORMANCE
FOR SULFURdXIDES
EMISSIONS

Commenter

28.

Mr.

and

B.F.

Affiliation

Mr.

Shell

3.A.

Oil

Docket

Ballard

Phillips
Petroleum
Bartlesville,
OK
29.

FROM FCCU REGENERATORS

Item

IV-K-10

Company
74004

Eslick

IV-K-11

Company

One Shell
Plaza
P.O.
Box 4320

30.

Houston,

TX

Mr.

Kienle

Shell

R.R.

Oil

One

Shell

P.O.

Box

Houston,

77210
IV-K-12

Company
Plaza
4320

TX

77210

1-11

No.

2.0

2.1

NEED FOR

THE

GENERAL COMMENTS

STANDARDS

Comment:

Two commenters

(IV-D-7

represent

an unnecessary

fore,

standards

the

commenters

for

and

burden

should

SO, could be controlled

stated

to the

of the

that

petroleum

be withdrawn.

withdrawal

the

industry

The reasons

standards

standards

are:

and,

cited

(1)

there-

by the

other

sources

of

at a much lower cost per ton and (2) the SO,

emissions

from FCCU's are

emissions

emitted

in

IV-D-16)

the

insignificant
United

when compared to the total

SO,

States.

Response:
Section

list

111

categories

of

a category

causes,

or contributes

Section

promulgate

demonstrated"
been

ities

as:

source

these

areas

sources.

evaluated

and

ranked

from

of

that

standards

of

new source
development

of growth

category;

pollution

list.

performance

and replacement

and (4) the

estimated

performance

performance

for

the

the

source

standards

already
that

source

of existing

2-1

the

these
such

might

factors

by

be

category;

facilities

incrementa~

were selected

of

required

Sources

using

for

amount of air

future

(NSPS) were promulgated

1977, or earlier,

prior-

pollutants

emit

involving

category.

attention

implementing

that

in a preselected

...

areas

actually

of control
for

and

assigning

specifies

are

any)

may

"best

of-EPAfor

(if

it

considerable
for

by a process

levels

c~ould be prevented

during

in this

categories

control

(2) estimated

source

the

of interest

Source

of emission

standards

strategy

shall

to propose

reflect

The approach

broad

"...

or welfare."

Administrator

of an approach

categories.
the

Often,

level

(3) projections

the

development

to

which

health

of the Clean Air Act of 1970,

to the

are

pollution

public

sources

regulations;

required

the

endanger

directs

Administrator

in his judgement

air

(BDT) for

by stationary

State

to,

if

technology

by considering

(1) the

in such list

which

Clean Air Act.

the

The Administrator

performance,

passage

pollutants

sources.

to

Ill(a)(l)

to various

emitted

directs

of

given

interest

Act

significantly

standards

Since

Air

of sources

be anticipated

Further,

has

Clean

of stationary

include
reasonably

the

year
for

by
which

or under
these

criteria;

one of the source categories

"Petroleum Refineries,"
Section
now requires

Ill(f),

placed on the initial

priority

list

was

of which FCCU's are a part.

added by the Clean Air Act Amendments of 1977,

EPA to list

major

source

categories.

Major source

1:

cate-

yories are defined as those categories

for which an average site plant
has the potential
to emit 100 tons or more per year of any one pollutant.

This helps demonstrate

the significance

of the SO, emissions

iip

from FCCU'sbecause EPAhas estimated that total SO, emissions from

new, modified,

17 units)

and reconstructed

FCCU's in the fifth

under Regulatory Alternative

year (a total

of

I (baseline emissions; i.e.,

emissions from the units if controlled

under current regulations)
would
be 86,900 tons, an average emission rate of 5,100 tons/yr per FCCU. The
standards

reflect

BDT and would reduce these

76,100 tonslyr;

this reduction represents

In surnsnary, the standards

FCCU's serve

the

intent

total

a significant'

of performance

of Section

emissions

by about

improvement.

for SO, emissions

111 of the Clean Air Act.

from
Neither

the

ability to control other SO, sources at a lower cost nor.the percentage

of total SO, emissions emitted in the United States that are comprised by
FCCU SO, emissions

negate

the need for

these

standards.

Comment:

One commenter (IV-D-16) asked the following

questions

pertaining

to the need for the standards.withrespect to preventionof significant deterioration

(PSD) requirements which also regulate FCCUSO,

emissions:

(1)

If each model source could yield

considerably

250 tons per year of uncontrolled

covered

by the

technology
rules
stated

(2)

be withdrawn.

rules

should

ai those

through

for

necessary

the modeling

1-7)

show that

If not,

be reissued,

best

sulfur
results

unregulated

2-2

available

do the job,

the
with

to satisfy

If the 3.5 weight percent

abandoned,

SOx, the source is

(BACT). Thus, if PSD will

should

proposed

PSD requirements

more than
control

the proposed

proposal

BID and

baseline

emissions

PSD BACT.

feedstock
(proposal

model plant
BID pages

FCCU's meet Class

is

7-4
II and

III

PSD, and primary

quality

standard

and

secondary

national

(NAAQS). Thus,

there

ambient

air

is no need for this

NSPS.

(3)

Since the SO, discharges

are above the small source tons per

year

trigger

or

limit,
III

doesn't

this

BACT, regardless

of Class

I1

increment?

Response:
Congress

would also

clearly

be subject

applicability

of

discussed
listed

source

structed

will

unclassified
of the

ambient

that

specified

allowable

air

the

the

increase

are

on the

application
source

or major

After

that

date,

reduces,

by the

for

area.

that

The current
emission

limitation

the

III

after

August

40 CFR 52.21
modification
each

net

emissions

allowable
under

the

which

1977,

for

will
occurs

would

or

increase
that

area

be less

than

ambient

air

, the

cause

maximum

the

ambient

The EPA expects

(pristine

concentration
on which

the

by a major
requirements

increase

by sources

helps

that

environment)

to the

source

2-3

as attain-

attainment

raise-the

that

is

from the FCCU

specified

will

increase

the

unit

is designated

maximum allowable

emissions

the

emissions

increase

was submitted
subject

same amount,

if

thi s si tuation

7,

(i.e.,

or has a potential

of the

The baseline

are

or recon-

NAAQS. CNote:

areas.l

is

a new, modified,

is

I area

source"

a maximum allowable

an increase

in a Class

date
under

equal

to equal

noClass

earliest

III),

increase
If

as

to regula-

that

concentration

NAAQS.

will

FCCU would be located

there

or

specified

above

concentration

in an area

II,

the

subject

and if the

The maximum allowable

if

concentration

I,

NSPS'~s

needed,

stationary

to PSD requirements

area

baseline

C40 CFR 52.21(c)~.

not

which emits,

on the classification

(Class

air

NSPS is

Therefore,

the S02 levels

area

the

to

BACT. Thus,

or more of any pollutant

be subject

Depending

including

as a "major

Clean Air Act).

not affect

subject

of which FCCU's are a part,

pollutants

in an S02 attainment

ment for S02.

show that

(b)(l)(i)(a)

per year

FCCU would

located

many sources

refineries,

of air

100 tons

under the

not

Petroleum

in 40 CFR 52.21

to emit,

that

to PSD requirements,

PSD does

below.

a stationary
tion

understood

is
first

and
established
complete

stationary
of 40 CFR 52.21.
in the

emissions

determine

may operate;

no

that

area
increase

the
is,

the

source

will

be subject

169(3)) means "...

of reduction

emitted

to BACT. The term BACT, as defined

an emission limitation

of each

pollutant

subject

from, or which results

the permitting
account

authority,

energy,

based on the maximumdegree

to regulation

on a case-by-case

basis,

and economic

determines is achievable for such facility

production

processes

including

fuel

techniques

and available

cleaning

impacts

Several

and other

sions

the

source

unemployment
desire

will

conditions,

for that

etc.

After

industry),

all

to emit;

these

attractiveness
other

variables

are taken

no specified

levels

for use by the

the amount of emis-

source

wanting

into

of

combustion

constraints

of the

sources

costs,

However, the entire

wi~l influence

be allowed

which

and techniques,
fuel

of each such pollutant."

other constraints

Act

through application

or innovative

(the

are
area's

to locate

considderation,

in the

area,

BACT is then

determined.

There
dependent

are

on the

constraints

on a case-by-case
industry

locate

allowable

emissions

rather

lenient

States

are

relying

basis).
in its

of BACT; each BACT determination

within

the

and there

increase

upon the

(i.e.,

the

in having an

source

could

large
receive

Due to budget limitations,

to conduct

thorough

NSPS program.

At this

BACT investigations
point,

is

BACT is determined

was a substantially

available,

BACTdetermination.

not able

area

If an area was interested

region

the

many
without.

NSPS program

provides an integral part of the BACTdeterminations

process.
The
development of. NSPS follows the same course as the development of BACT
without

the additional

determination

process.

BACTis developed.
stated

As such,

control

which will
established

exceed

the

pursuant
maximum

"...

could

NSPS provides

in no event

technology"

PSD/BACT requirements.do
the

that

be imposed on the BACT

the

BACTcould be more stringent

in 40 CFR 169(3)

available

defines

constraints

result

emissions
to Sections
not

emission

application

that

2-4

need

for

BACT can

of "best

of any pollutants

by any applicable
the

from which

than NSPS, however, as

111 or 112 of this

preclude
level

shall

baseline

in emissions

allowed

-"

into

allowable emissions increase may or may not be available

source.

this

facility,

taking

methods, systems,

or treatment

for control

under

from, any major emitting

environmental,

in 40 CFR

Act."

standard
In summary,

NSPS; rather,
allow.

NSPS

'P

2.2

REGULATED POLL~TANT

In the proposed
change the

regulated

revisions

(50 FR 46464),

pollutant

from SO, to S02 for the

add-on controls,

but keep SO, as the

standard

without

add-on

proposed

decision

standard

without

responses

follow.

controls.

the

regulated

Comments

to keep SO, as the

add-on

controls.

commenters

(IV-K-P,

Agency proposed
standard

pollutant
were

regulated

to
with

for the

received

only

pollutant

on the

for the

These comments and the

Agency's

Comment:

Several
use SO2 rather

than

SO, reduction
refinery~
lated

only

tested
contact

pollutant

only regulated

for

monitor

comnenter,

the

although

atmosphere,

and

monitor

could

the

the

continuous

for

regu-

standard
of SO3.

to acid mist

monitors

before

EPA

other

EPA usually

emissions

SO3 condenses

emissions

that

how an opacity

limit

that

for the standard

SO2 and that

This commenter questioned

to the

stack-mounted

regulated

One commenter (1V-K-2) stated

an in-stack

with

occurs

are

SO2.

with

According

SO, as the

catalysts.

sources

1V-K-6, and 1V-K-8) suggested

approved

any atmospheric

upon

by EPA are

contact

In another
several

points

(1)

comment letter
pertaining

The Federal
is

only

Register

effect

(2)

oxygen drives
is

emissions.

in the

(3)

the

0.5

SO3 content

the

reaction

proposal

refining

of oxygen

gas:

oxygen content
of FCCU flue

to sulfur
content.

may

gas.

trioxide,
Thus,

it

the

linear.

is greater
This

of the FCCU flue

claims that

the

power

lessthan

S03 typically
the

notice

increase

to

Commenter IV-K-2 stated

to the S03 component

substantially

Although

(IV-D-16),

than 10 percent

statement

is

BID and on the

based

of the total

on test

comnenter's

data

SO,

reported

experience

in

industry.

SO, reduction
catalysts
work best
operates
to maximize the fraction

when the regenerator

leaving as SO3.

Another commenter (1V-K-6) stated that preliminary data previously

submitted
their

to EPA from several

refineries

indicate

only an insignificant
same result

was also

SOx reduction

the SO, emissions

amount of SO3.
found without

catalyst

trials

have generally

contained

(This commenter noted that

the use of SO, reduction

2-5

at one of
the

catalysts.)

Commenter IV-K-8 stated

that

by using SO2 as the regulated

pollutant (1) the same monitoring technique (pro;en S02 monitors) would
be used as is for add-on scrubber
consistency

and reliability

technology

and (2) cost savings and

of the sample results

would be gained.

This commenter also stated that emerging SO, reduction catalyst data
indicate -that S03 is unaffected by the catalysts; SO, reduction
catalysts

control

SO2, while allowing

the percent,

amount of SO3 to increase; and, therefore,

not create a large excess of SO3.
Response:
The Agency has considered

the

but not the total

SO, reduction

arguments

catalysts

presented

by the

do

commenters

and reviewed the data available

on the composi~tion of SO, when using

SO, reduction

this

catalysts.

After

that the most appropriate

review,

the Agency still

regulated pollutant

catalysts
is SO,, not SO2
The Agency recontacted

SOx reduction

for SO, reduction

catalyst

the mechanism by which SOx reduction catalysts

sions (see Docket Nos. LV-E-19 and IV-E-2O).
Con~snenterIV-K-8 states,
that

SO, reduction

sulfate

the SO, reduction

catalysts

compound that

reduce total SO, emisContrary to what

vendors indicate

remove S03, forming a metal

is much more stable

pound formed when the SO2 reacts

vendors to review

catalyst

preferentially

believes

than

the metal

with the catalyst.

sulfite

com-

As the SO, reduc-

tion catalyst picks up more and more SO3, the equilibrium

disturbed.
To regain equilibrium,
more SO2 becomes S03.

balance is
~lf the rate

of S02 to SO3 is less than the rate of metal sulfate formation (SO3
plus metal oxide), then the SO3 percentage in the FCCU~emissions will
dec rease .
metal

On the other hand, if the SO2 to SO3 rate

sulfate

formation

rate,

then

th'is

S03 percentage

To ensure maximum SOx removal efficiency,

likely

operate

a regenerator,

is faster
will

than the

increase.

the owner or operator

to the extent

possible,

would

in such a manner

that the SO2 to S03 rate is not limiting;

that is, create
within the regenerator that increase the S03 percentage.

conditions

The Agency again reviewed the data on SO2/SO3 in regenerator

emissions,

including

The Agency requested

available

on this

that

submitted

in the

revised

be submitted.

by Corrsnenters

IV-K-6 and IV-K-8.

proposal

any data

Very little
2-6

that

that

data were submitted.

were

The`data
that

base

remains

the more recent

SO3 than
ever,

data

the earlier

that

there

very limited
generally

data.

the

is a potential

catalysts

control
agrees

with

uncondensed

determinations,

however,

plume opacity.
and maintenance

tion

is

available

suggest.,

S02 as the

how-

regulated

not necessarily

reflect

by SOx reduction

that

is affected

condensation

If

sufficient

may also

compliance

had been

the

of

opera-

higher

than

in-stack

Thus, it is the plume

limit

presented,

regulated

reading

Some informa-

of S03 and,

help

compliance

extent

to comply with the

the

emissions

data

on~this

then

pollutant

to the

the

for

of

possi-

Agency

FCCU's

would

without

SO2 CEMS's cou~ld be used for

determinations.

allow the

that

same monitoring
cost

savings

S02 CEMS's will

results

sampling.

likely

technique

be applied

technique

is

to

evaluated

other

EPA usually

regulated
for

to be used as for

controls

for FCCU's without

no need

IV-K-2 that

utant .woulld

be gained.

yield

than would keeping

is

S02 as the.regulated..poll

technique

not necessarily

There

appropriate

using

would

having an SO2 standard

sample

is

of a source

from SOx to S02 so that

The Agency agrees

and that

opacity

would

to show proper
device.

but did not receive,

data

changing

add-on controls

intended

are burned.

it

Opacity
emissions

control

ability

transmissometers

visible

are

the

standard,

considered

stack.

by the condensation

The Agency requested,

bi ii ty .

in the

plume

fuels

affects

opacity

that

particulate

indicates

that

IV-KI2

made through

of the

opacity
(plume)

Commenter

are

wt~en higher sulfur

is

still

of

amounts of S03 to be emitted,

using

S03 emissions

opacity

have

data

can be obtained

Transmissometers

tion

S03.

large

S02 only will

of SO, that

not measure

this

have a lower percentage

recent

by a standard

The Agency agrees

The Agency

the

for

Thus, regulating

potential

tendto

Some of the

which would be undetected

pollutant.

and inconclusive.

on its

more consistent
that

standards.

own merit.

are

2-7

Agency

the

and reliable
Method 8

same monitoring

Each possible

regulated

is

and using

and using

The facts

only S02 shed no light

source.

the

add-on controls.

requirement

sources

However,

an SO, standard

alternative

refinery
this

or

add-an

raised

only for

monitoring

by Commenter

SO2 and that

on whether an SO, standard

not

2.3

DESIGNATIONOF AFFECTEDFACILITY

Comment:

Several commenters(IV-D-I, IV-D-15,and IV-D-1~)recommended

a
broadening of the designation of the affected facility.
Twocommenters
(IV-D-1 and IV-D-15) stated that the FCCUreactor should be included
as part of the affected facility because of the dependencybetween
the reactor and regenerator. One commenter(IV-D-15) suggested that,

foran FCCU
reactor using multiple regenerators, the affected facility
should i nclude the reactor and all of the regenerators serving the
reactor, because it may be possible that SO, control systems used on
muitiple regenerator systems are more efficient.
Another commenter

(IV-0-16)recommended
that the affected facility shouldinclude the
FCCUreactor,

fractionator,

and gas recovery unit.

The commenter

stated that hydrocarbon streams recycled from the fractionator or gas

recovery unit are defined as "fresh feed" to the affected facility,

Therefore, by increasing the amountof these low sulfur streams recycled

to the FCCUreactor,

sulfur cutoff,

a refiner

could circumvent the intent

because it would be easier to maintaina

of the fe~d

feedstock.

sulfur content belowthe 0.30 weight percent sulfur level by recycling

these.

Response:

The rationale for.selection of the affected facility was presented

in the preamble to the proposed standards (49 FR2060). As stated in
the prear~le, SO, are generated in and emitted.from the FCCUregenerator,

The designation of the regenerator of each FCCU

as the affected facility,
rather than the entire FCCU,would lead to bringing replacement equipment under these standards sooner and thus, would adhere to the purpose
of

Section

111 of the

Clean

Air

Act.

The EPAagrees that identifying

each FCCUregenerator

as the

affected facility for multiple regeneratorconfigurationsis unreasonable.

If only one regenerator in a multiple regenerator configuration

were to become subject to the standards, it would be impossible in some

multiple regenerator ducting arrangements to isolate and measure the

SO, content of the exhaust gases from the affected regenerator.

Furthermore,

because

the

refiner

would want to minimize

the cost

and

downtimefor
revamping
workonthe unit, it is unlikelythat onlyone
2-8

regenerator

in

or

reconstructed

is

now defined

a multiple

regenerator

without
to

The proposed
those

petroleum

refiner

would

the

include

others.

all

of "fresh

derivatives

recycled

circumvent

the

would

Therefore,

regenerators

definition

not

configuration

serving

feed"
within

feed

the

be modified

affected

an FCCU reactor.

specifically
the

sulfur

facility

excluded

FCCU. To ensure

cutoff

by adding

that

low-

sulfur content recycle from the fractionator and gas recovery unit,
EPA has revised

the

definition

of "fresh

feed"

in the

regulation.

The

revised definition specifically identifies petroleumderivatives from

the

FCCU, fractionator,

excludes

them

from

and
the

gas

recovery

definition

of

unit

"fresh

as recycje,

and thus

feed."

Comment:

One commenter

(IV-D-12)

stated

that

the

proposed

not apply

to Reduced Crude Conversion

IRCC) processes

Treatment

(ART) units.

justification

i.

The following

which

has

heavy

2.

The refining
different

metal

constituents,

content.
catalyst

high

Consequently,
design.

objective
employs

or Asphalt

carbon

residue,

and

may have a

(residual

distillate

an adsorbent

Resid~91

commenter's
ACC unif
(reduced crude),

RCC units

for an RCC unit

from an FCCU processing

should

was provided:

AnFCCU processes
clean gas oils while the
processes
asphalt-containing
long residuum
higher sulfur
very different

standards

upgrading)

is

oils.

3.

The ART process

ca tal ys t .

rather

than

4.

The ART process obj~ective is'minimal

change'in
other than metals removal.
It is a feedstock

a cracking

the feedstock
upgrading

process.

5.

The ART and RCC units

residual
avoid

upgrading.
undesirable
and

operated

secondary

is accomplished
burn,

are

These units

reactions.

by multiple

catalyst

heat

under

stage

conditions

are designed

critical

and operated

Control

regeneration,

~o

to

of heat

release

limited

carbon

exchange.

Response:
To upgrade
distillate

residual

product

yields,

(HOC), which includes

The HOC units
feedstocks.

catalyst

feedstocks

new processes

termed

RCC, and ART are being

are FCCU's that

process

As in a conventional

regeneration.

and to increase

Emissions

gasoline

heavy oil

installed

residual

FCCU, emissions

and other
occur

of SO, may, in fact,

2-9

and middle

cracking

at refineries.
heavy oil
as a result

be greater

of

from

HOCunits than from other FCCU's because HOCfeedstocks have a higher

coke make rate than gas oil feeds, and because a greater portion of the
sulfur in HOCfeedstocks forms coke than that in gas oil feeds.
The
EPA's analysis
for

of SO, emissions,

HOC units

showed that

able and affordable

presented

control

the proposed

for HOCunits.

in Appendix

costs,

and cost effectiveness

standards

for

The results

F of the proposal

FCCU's are achiev-

of this

analysis

were

BID.

Emissions, emission control, and control costs for the ART process
were further evaluated by EPA (see Docket A-79-09, item IV-B-17).
The
differences
exist.

stated

by the commenter

The ART process

inert

microspheric

between

an ART unit

does not employ a catalyst,

contact

material'that

and an FCCU do

but rather

collects

uses

contaminants.

an

The

objective of the ARTprocess is feedstockupgrading,not processing,

and some of the

operating

Nevertheless,

important

operation,

and emissions

unit

the

under

material,

For

thereby

in regenerator

that

warrant

both

an

is performed

restoring

for

during

operation

are expected

emissions

(see

control

feasibility

Based on a scrubber
effectiveness

calculated

cost

effectiveness

expected

CO emissions,-if
be

item

for

IV-D-3O),

the

and

catalyst

in the unit.
the

regenerator

range of emissions
based

The EPA

on reported
that

and had a reasonable

of 90 percent,
is below

In addition,

particulate

Opacity

and determined

ART unit

or

those on HOC's.

was appl.icable

for FCCU's.

necessary,

a conv~ntional

for an ART unit

SO, efficiency

cost

of an ART

from an ART unit

and cost

Docket A-79-09,

reuse

including

of an ART unit by a scrubber

cost.

and

to be within

from all types of FCCUregenerators,

control

regulation

ART unit

it

of CO, SO,, and particulate

evaluated

the

configuration,

to burn off coke from the

and emissions
normal

~,d

may vary significantly.

similarities

exist

FCCU NSPS.

FCCU, regeneration
contact

conditions

emissions

the scrubber
the

'range

costs
are

of

I:;I

to control
estimated

to

reasonable.

The similarity
ability
unit

of control
regenerator

objective
that
icant
subject

the

material

to

emissions

equipment
can meet

of the

reasons

in

the

FCCU NSPS.

the

the

regenerator

a reasonable

cost

FCCU standards.
is

different

regenerated

to support
the

at

ART process
being

from

is

contention
Therefore,

2-10

indicate

The facts
than

not

that

a catalyst

that
the

and the

proposed

that
that

of the

the

ART

the

FCCU as~d

are

an ART unit

avail-

not

signif-

should

standards

not

covered

be
both

ART and HOC units

and the

that

HOC, or any

an ART unit,

treatment

unit

promulgated

regenerator

other

achieve

standards
similar

the

continue

type

to require

of~fluidized

FCCU particulate,

bed

opacity,

CO,

and SO, standards.

2.4

FORMAT

OF THE

STANDARDS

Comment:
Several

commenters

(IV-D-3,

IV-D-1O,

IV-D-11,

IV-D-14,

and IV-K-12)

stated that EPA should establish a single SO, standard for FCCU's.
reasons cited by the commenters for setting a single standard are:
a single

standard

determining

the

(2) a single

would allow

refiners

most cost-effective

standard

the options

and flexibility

method of meeting

would comply with Section

The
(1)

that

Ill(h)

of

limit;

and

of the Clean Air

Act whichimplies that the Administrator should prescribe a performance

standard

rather

feasible

to

than

do

a work

practice

or equipment

standard,

where

so.

Response:
There

are three

(1) scrubbing
catalysts;

techniques

of FCCU regenerator

and (3) using

hydrotreating
and

method

of continuous

energy,

and nonair

emission

quality

techniques

consideration
and impacts
that

occurring

for controlling

associated

of FCCU applications,

effectively
and represent

by using SO, reduction

FCCU-feedstocks
or processing
sources

that

without

the

establish

obtained
naturally

by either
occurring

can effectively
use

of

alternative

add-on

by feedstoek
oils.

of performance
that

reflect

for new,

the

costs,

The
best

environmental,

for FCCU's, EPA evaluated

SO, emission
control

all

Upon thorough

reduction

techniques,

capability,

EPA determined

SO, emissions

from all

types

BDT for FCCU SO, and SO2 emissions.

SO, emissions

catalysts
low sulfur

high
crude

2-11

sulfur

oils.

reduce

EPA concluded

standards.

can be reduced

or by using low sulfur

hydrotreating

and continuously
controls,

crude

FCCU SO, emissions.

However, for many FCCU applications,

effectively

SO, reduction

obtained

considering

with each of these

systems

(2) using

impacts.

standards

of the availability,

scrubbing

standards

reduction,

health

FCCU SO, emissions:

low sulfur

FCCU regenerators

To develop SO, emission

available

gases;

FCCU feedstocks

EPA to develop

reconstructed

to control

exhaust

low sulfur

or from naturally

Clean Air Act requires

modified,

applicable

it

feedstocks

For the

SO, emissions
is

reasonable

to

The standard

for

add-on

device achieve a 90 percent

reduction

format

of add-on

controls

consistent

with

controls

reduction

was selected
for

all

Section

requires

it

to allow refiners

reduction

low sulfur

Although

SO, emissions
costs

for the other

hydrotreating,

or

believes

it

afforded

low sulfur

that

using

that

impacts

controls

to use SO,

a combination

effective

add-on

instead

SOx reduction

at reducing

they have lower

a

to give up some emission

controls

by using SO, reduction

feedstocks

of both

when compared to using

is reasonable
without

is

the standard

add-on

may be less

a standard

benefits

or

performance

This

for some FCCUapplications,

that

by establishing

The percent

levels.

without

feedstocks,

environmental

The EPA judged

reduction

refiner

nonair

control

the

the flexibility

techniques

than scrubbers

and smaller

scrubber.

these

sulfur

A standard

also was established

techniques.

reflects

which requires

ref lect ...ap pi i ca tio n of BDT.

catalysts,

best

feed

Ill(a)(l),

the

in SO2 emissions.

because
expected

that

of

in

catalysts,

return

catalysts,

scrubbers.

:?
If

hydrotreating,

or

low suliur feedstocks for his particular FCCU

application will not achieve
the

standard

install

without

add-on

and operate

reduction

an add-on

then

control

the

device

refiner

that

can

still

achieves

90 percent

of S02 emissions.

The standards
Section

111

nor the

standard

type

controls,

of

are

the

be operated

to

Clean

for

of controls

performance
Air

standards

Act.

Neither

FCCUls without

that

must

achieve

the

and are
the

add-on

be used

or

controls

exactly

consistent

add-on

with

control

standard

specifies

how the

the

controls

are

to

standard...

Comment:

Several~commenters
that

the

add-on

percent
controls

emission

limit

(IV-D-2,

reduction
should

format

be changed

standard

IV-D-3,
proposed
to

to control

SO, emissions

percent

reduction,

which

is

and IV-0-11)

by EPA for

an emission

would simplify

refiner

IV-D-10,

limit

compliance

to a specific

a moving

the

stated

standard

format.

with
An

and would allow

level

rather

than

a
a

target.

Response:
Compliance
performance
device.

with

source

the

test

The EPA agrees

percent
at
that

both

reduction
the

inlet

an emission

format

requires

and outlet
limit

format

of the
for

conducting
control
the

standard

for add-an controls wouldsimplify complianceproceduresby requiring

2-12

~y

source

testing

only

would not reflect

above,

limit

could

the percent
percent
be

level

will

device.

using

is difficult

percent

reduction.

had no means
device.

than

emission

requirements

device

(see

results

continuous

a moving

now are required

Section

control

6.2).

device.

for

to

refiners

to

achieve.

the

coke

a control

outlet

S02 monitor,

reduction

the

requirements

and outlet
refiner

the

to

will

percent

reduction

calculated

becomes

achieved

monitoring

reduction,

thus

to

emission

to achieve

determine

results,

outlet

at the inlet

The percent

is

device

Consequently

available

monitoring

target

the

that

to the commenters'

percent

changed

specified

With only a scrubber

The EPA has

with

to the control

that

the

may perceive

level

the

acontrol

of monitoring

An emission

because

concentration

format

by scrubbers.

BDT.

Rather,

inlet

this

A refiner

no specific

to operate

S02 monitors

by the

the

represents

outlet.

monitoring

it

monitoring

achieved

achievable

S02 monitor only may have contributed

control

the

is

on the

control

have

there

vary depending

and continuous
the

However,

to be a "moving target"
device

refiner

by the

of control

control

that

constant

outlet.

greateremissions.

format

The proposed

opinion

device

reduction

in

format
the

device outlet

the

result

reduction
at

control

90 percent

reduction

achieved

the

the best level

As discussed
format

at

a fixed

by

rather

Comment:

Three

commenters

EPA for the

ate.

standard

One commenter

allows

no

discourage
while

latitude

perhaps
sulfur

scale

was considered

Coast Air Quality

that

allowable
that

this

format

burn-off

was

recorded

format,

the

yields

the

format

of light
will

suggested

stated

development

that

because

coke

and can change significantly.

SCAQMDrule

2-13

uses

a format

who
products

be reduced,
that

EPA

in coke
the

of the

(SCAQMD)Rule 1105,

inappropriate

will

refiners

for variation

(IV-D-1)

by

inappropri-

and

penalizes
emissions

allows

during

is

content

The commenter

Management District

are not normally

a coke

format

sulfur

increase

level.

proposed

cokeburn-off

The format
that

format

add-on controls

coke

A second commenter

format

concluded

in

coke make because

content.

burn-off

of

variation

improvements

a sliding

burn-off

statedthat-the

to an unachievable

consider

rates

(IV-D-9)

improvements.

process

reducing

that

for FCCU's without

for

process

implement

stated

coke
South

but it

was

burn-off

instead
expressed

in

terms

of kilograms

of S02 per thousand

barrels

of feed.

-A third

com-

--a

menter(IV-D-8)stated that a percent reductionformatshouldbe

adopted

rather

than

a nonflexible

limit

of

sulfur

on coke.

Response:
Based on a sensitivity
proposal

analysis

BID, EPA concluded

that

presented

in Appendix F of the

the coke burn-off

format

relates

well to normal fluctuations in SO, emissions from FCCU'sprocessing a

vari ety of feeds.

This is because SO, emissions are related directly

1'7

to the coke suifur content. Normally,FCCU's

are operatedto limit the
amount of coke that
improvements

that

can be burned
reduce

the

off

coke

in the

make rate

regenerator.
are

Process

made to allow

the

refiner

to process more feed through the unit until the unit is again

limited

in the

amount of coke it

improvement that

results

can burn off.

An exampleof a process

in reduced cake make is high temperature

regeneration (HTR). The initial result of HTRwouldbe reduced SO,

emissions from FCCU's on a mass basis.
of coke burn-off
related

to the

throughput

until

within

the

standard

offers

greater

basis.

However, SOxemissions in terms

would remain the same because SO, emissions

sulfur

on coke.

the

unit

Thus,

is again

even though

refining

The commenters

provided

the

refiner

coke burn-off

emissions

flexibility

-I_:

could

are

increase

limited

and still

would increase.

This

than a mass of SO, per unit

no new information

to refute

be
format

of feed

this

conclusion.

A sliding
content

would

scale

that

be difficult

coke on catalyst
considers

format

is not

a sliding

scale

The EPA considered

to.enforce

readily
format

catalyst

EPA did not select

siderations.
or inlet

for

variation

because

the

obtainable.
reduction

content

reason,

sulfur
of the

EPA

format

for the

standard

for

This format would require the SO,

FCCU emissions

a percent

reduction

SO, concentration

sulfur

For this

to reduce

With'SO, reduction

in coke

unreasonable.

a percent

FCCU's without add-on controls.

reduction

allows

percentage.

The

format because of compliance

catalysts,

to measure.

by a set

there

Thus,

::I
con-

is no uncontrolled

it would be impossible

to

detenr~ine through stack testing the percent reduction being achieved by

the catalysts.
An~alternative
method would be to estimate the percent
reduction achieved
for feed sulfur.and

by SO, reduction
SO, emissions.

catalysts
using EPA's correlation
However, EPA's correlation
represents
2-14

an average

useful

for

all

FCCU's and feedstocks.

for analyzing

the overall

While the

correlation

impact of the standards,

is

inlet

SO,

concentrations may be lower or higher than the level predicted by the

correlation
cannot

for

a specific

be used

on a case-by-case

separate

correlation

dards

unreasonable,

is

tion

select
The

EPA

direct

coke

particulate

standard;

and would
2.5
2.5.1

burn-off

method

use

for

stan-

of a correla-

is not
determining

catalysts,

format

the

EPA did not

reasonable

sulfur-on-coke

identical

the

be readily

LEVEL

coke

to the
is

by the

SO, emissions

a practical

format.

the

relationship

correlation

develop

that

when~using SO, reduction

reduction

format

to

EPA concluded

not

the

and FCCU affected

uncontrolled

is

Thus,

The cost

each feedstock

there

considers

burn-off

basis.

potential

concentration

a percent

feedstock,

Therefore,

Because

SO, inlet

its

for

for determining

practical.

FCCU and

to

coke

the

relationship.
format

burn-off

because

rate

The

selected

can

of

for

the

be recorded

NSPS

reasonably

available,

OF STANDARDS

Level

for

Add-On

Control

Standard

Comment:

Two commenters

(IV-D-2

standard

for

add-on

controls.

standard

for

add-on

controls

commenter
should

(IV-D-2)

and JV-D-4)

One commenter
is

excessively

that

the

be 300 vppm rather

than

50 vppm.because

equivalent

applications.
IV-D-18)

In contrast,

stated

that

the

standard

BDT for

is

stated

reduction

(or 50 vppm) is achievable.

the

options

proposed

standards

are

industry

processing

(IV-D-4)

for

realistic

Another

for

achieving

when analyzed

and emission

control

of the

stated

that

the

Another

add-on
a.300

controls

vppm standard

is

for most FCCU

(IV-D-1, iV-D-11, and

reasonable.

add-on controls

provided

level

SO, reduction

three'commenters

(IV-D-11)
that

that

standard

to a 90 percent

the

stringent,

stated

approximately

stated

questioned

One commenter
at

90 percent

commenter

(IV-D-18)

compliance

in terms

by weight
with

the

of existing

practices,

Response:
The standard
are

reduced

The

standard

for

add-on

by 90 percent
is

based

controls

requires

that

or to 50 vppm, whichever

on test

data

that

2-15

demonstrate

FCCU SO2 emissions

is

less

that

stringent.
scrubbers

can

achieve 90 percent reductions in FCCUSO, emissions.

The 50 vppm

outlet concentrationlevel wasestablishedbecausescrubberSO,removal

efficiency tends to decrease at low inlet SOxconcentrations (see

Section 3.1 of this document). Therefore, the 50 vppmlevel is not

intended to compare with the 90 percent
The EPA disagrees

that

level

for most cases.

a 300 vppm standard

90 percent

reductions

for most FCCU applications.

processing

feedstocks

with sulfur

contents

is equivalent

to

Most FCCU's are

ranging from 0.3 to 2 percent

by weight, with corresponding uncontrolled SO, emissions ranging from

300 to 2,000 vppm. Fluid catalytic cracking unit SO, emissions when

:1

controlled by scrubbers would range from 50 to 200 vppm. Thus, a 300

:,j

vppm SO, emission

most cases.

by application

level

2.5.2

would not compare to 90 percent

In summary, 4300

achievable
the

standard

for

the

Level

vppm standard

does not represent

of BDTand, therefore,

standard

of Standard

for
for

add-on
FCCU's

reduction
the

was not selected

in
level

as

controls.
Vithout

`3
Add-On Controls

Comment:

Seven commenters (IV-D-2, 1V-D-3, IV-D-6, IV-D-7, IV-D-8, IV-0-9,

and

IV-D-10)

controls

stated

that

the

standard

for

FCCU's

without

add-on

should~be set at 13 kg SO,/1,0O0 kg coke burn-off

because:

(1) increasing the level to 13 kg SO,/1,000 kg coke burn-off would

have a limited

impact

by SO, reduction

on ambient

catalysts

air

quality;

(2) 80 percent

are not supported

by the

limited

reductions
commercial

tests cited by EPA; and (3) a 13 kg S0,/1,0O0 kg coke burn-off emission limit would allow more refiners
to use the catalysts
rather than

add-on controls since SO, reduction catalysts are the only costeffective

and environmentally

commenters
limit

tant

should

and IV-D-10)

the

Phase Ii

dard.

control

added that

be made to account

from S02~to SO,.

supported
that

(IV-D-6

acceptable
for the

In contrast,

an increase

change

proposed

of the

SCAQMDRule 1105 is more stringent

The commenter stated

that

One commenter

SO, reduction

II of the

rule.

stated

that

reduction

required

tially

equivalent

the

emission
to the

level

Board (TACB) to control

Two

in the

in the

levels

to be used to meet Phase

Control

alternative.

emission

controlled

pollu-

two commenters (IV-D-1 and IV-D-18)

by EPA.

of control

(IV-D-1)

catalysts

Another
by the
required

FCCUSO, emissions.
2-16

i.

than

reported
the stan-

are expected

commenter

(IV-0-18)

standard

is essen-

by the Texas Air

Response:

The EPA disagrees

with the comment that

are the only cost-effective

alternative.

and environmentally

The EPA determined,

energy,

and nonair

control

FCCU SO, emissions

to using

SO, reduction

quality

SO, reduction

acceptable

considering

health

costs,

impacts,

and are

that

BDT.

catalysts,

control

environmentai,

scrubbers

Furthermore,

refiners

catalysts

effectively

as an alternative

may use hydrotreating

or low

sulfur feedstocks to achieve compliance with the 9.8 ky S0x/1,000

coke burn-off level.
The level
was selected
catalysts
the

to allow

with

further

stocks,

of the
best

standard

(9.8

refiners

flexibility

currently

development

especially

reduction

those

needed

80 percent.

to

lower
the

For example,

to~use

catalyst

with

achieve

kg SOx/1,0O0 kg coke burn-off)

available

of the

and to encourage

technology.

For many feed-

sulfur

level

content,

of

a feedstock

the

with

0.5

reduction

achieve

standard.

In response

of the

contacted

a number of companies

catalysts

to request

ability

updated

of developmental

SO, reduction

catalyst

catalyst

data

test

SO, emissions
developers
show catalyst
continues

a wide

to

achieve

level

of

reasonable.

standard

The

determination

consideration
increase
primary
and

for

purpose

scrubbers

of

of the benefits

in SO,-emissions
of the
can

FCCU's
the

standards

achieve

to the

this

2-17

points

catalyst
of

feedstocks.

EPA believes

controls

is

standard

included

and the

BDT of scrubbing.
emission

FCCU

technology

catalysts
future

of

by~the

tests,

add-on

is to reduce

cost-effective

the

catalyst
of

reduce

some data

range

of SO, reduction

compared

to

As the

a greater

level

and avail-

SO, reduction

reported

to use

without

EPA

Based on a survey

90 percent.

for

to

SO, reduction

performance

data

be able

standard

sulfur

comments,

performance;

of SO, reduction

the

to the

developers

The test

will

than

in SOx emissions

by the

as

less

percent

commercial

of catalyst

refiners

results

weight

on the

current

as high

the

is

catalysts.

reported

range

develop,

Based on the
the

developers,

performance

to

technology

information

by 65 to 75 percent.
span

emission

known to be developing

SO, reduction

havebeen

the

standard

50 percent

level

SO, reduction

performance,

would needapproximately
the

kg

Because the

FCCU SO, emissions,

reductions,

EPA

concluded that
emissions

it is not reasonable

by raising

the

level

to further

of the

increase

allowable

::1

standard.

The EPAproposed standards regulating

total

FCCUSO, emissions

because S03 can comprise a substantial portion of the FCCUSO, emissions when SO, reduction catalysts are used, and the potential SO,
emissions from FCCUregenerators can be significant.
Both SO2and
SO3 are emitted

from FCCU regenerators.

Data from source

tests

indicate

that S03usually comprisesless than 10 percent of the total SO, emissions.

However, with high excess air and certain types of catalysts

catalyst

additives,

SO3 can c.onprise a substantial

percent) of the total

SO, emissions.

portion

or

(up to 60

The.SO, reduction catalyst

data

used by EPAto select the level of the standard are reported in terms
of total

SO, emissions.

Thus, EPA's choice for the level of the stan-

dard took into consideration that the controlled pollutant is SO,

instead

of 302.

2.5.3

Feed

Sulfur

Cutoff

Comme
nt :
Two commenters (IV-0-4 and IV-D-11) stated
sulfur

cutoff

of 0.30 weight

percent

sulfur

that

an arbitrary

feed

is too restrictive.

One

commenter (IV-D-11) wrote that a feed sulfur cutoff equivalent to 9.8 kg

SO,/1,00O

kg coke burn-off

accomplished

should

by developing

and SO, production

be established.

a correlation

using

test

This would be

between

feed sulfur

content

data.

Response:
The selection
percent

was not arbitrary.

proposed

standards,

consideration
emissions

sulfur

feed

levels

refiners

to use naturally

level

cutoff

of 0.30 weight

in the
level

preamble

to the

was selected

based

of scrubbers to control SO,

low sulfur

feedstocks,

and the

are expected to be processing

occurring

on

low sulfur

feed-

if they

feed or to hydrotreat

high

feeds.

is presented
on test

between FOODfeed sulfur

on p. 3-18 of the
data

for

a large

Based on this correlation,

1,000

sulfur

of the costs for application

A correlation
based

the

cutoff

As was discussed

from FCCU's processing

stock sulfur
elect

of the feed sulfur

kg coke burn-off

proposal

BID.

content

and SO, emissions

The correlation

is

number of FCCU's and feedstock

types.

an FCCU
SO, emission level of 9.8 kg SO,/

corresponds

to a feed sulfur

2-18

level

of

approximately

0.3

weight

percent.

Thus,

the

feed

sulfur

cutoff

level

established by EPAis approximately equivalent to the standard for

FCCU's

without

determine,

sulfur
2.6

add-on

controls.

on a case-by-case

content

There

basis,

is

no

need

for

a correlation

each

refiner

between

to

feed

and SOx production.

AVERAGING

TIMES

Comment:

Commenters

IV-D-EO) stated
i nc reased .
IV-D-11)
appropriate

that

averaging

the

of these

that

averaging

controls

commenters

(IV-0-3,

for

for the

(2) no process

control

(IV-D-2)

device

stated

add-on

lengthened

to

7 days

commenters

(IV-0-11)

determinations

with

the

excess

for

the

stated

should

hours

that

1,000

the

averaging

kg coke burn-off

Response:
Upon evaluation
commenters
foe

that

FCCU's with

the

period

standards
of the
averaging

for

feed

in a 3-hour

catalysts;
concentrations
commenter

times

should

reasons.

be

One of the

period
daily

the

for

peaks

compliance

not.exceeding

Two commenters (1V-D-4 and IV-D-EO)

for

the

should

add-on

control

be a rolling

time

for

add-on

long-term

variability

compliance

controls

and 9.8

30-day

comments on variability,

and without

The EPA assessed

would be

FCCU's

time

Another

averaging

with

and

(1) a 7-day

not.

averaging

7 days

13 kg SO,/1,000 kg coke burn-off.

stated

and for

in S02 inlet

same variability
the

be

for compliance

averaging

would

and

IV-0-1O,

can be adjusted

emissions

at

1V-D-6,

when using SO, reduction

that

be set

IV-0-11,

standardsshould

reasons:

for variation
3

IV-D-10,

controls
the

variables

whereas

that

period

following

SO2 emissions

and (3) 7 days would account

the

for the

time would be consistent

cutoff;

1V-D-6,

time

standards

period to regulate
to

1V-D-4,

a 7-day averaging

for the

add-on

sulfur

IV-D-3,

Several

stated

without

(IV-D-2,

.period.

EPA agreed
with

should

the

kg/

with t~e

standards

be lengthened.

by statistically

analyzing

the

continuous SO2 monitoring data from an EPA study of a sodium scrubber

applied to an FCCU(see Docket A-79-09, item IV-B-5).
Several of the
commenters
ability
tion

pointed

in scrubber
and feedstocks.

to this
inlet

study

as an example of the

conditions

The hourly

due to variability

percent

2-19

reductions

potential

vari-

in FCCU operaachieved

by the

scrubber

were used in a time series

averaging times.
estimated
once

to compare various

For a given averaging time, the time series model

the minimum scrubber performance

in

level that would be expected

10 years.

The results
ensure

analysis

that

analysis

exceedances

variability.

of

However,

performance
of the

of this

level

the

standard

with a 7-day

estimated

standard.

showed that

3 hours

would

rolling

not

This result

indicates

occur

average,

once in 10 years

is too short
due

normal

the minimum

was greater

that

to

to

than

the

level

7 days would adequately

accountfor normalvariability in scrubberperformance.

Because

the SO, reduction

developmental

stages,

for long-term

anal ys i s .

7 days would allow

ables

after

such

there

and

would
for

longer
the

be

changes

time

standard

as to

for

because
due

a different

the

feedstock,

standards

controls.

normal

The

included

a revision

7 days.

Six commenters

IV-K-10)

all

variatidn.

(IV-K-1,

add-on

EPA did

with

IV-K-5,

EPA's revision.

process

whereas

for

averaging

1V-K-3,

to use
vari-

3 hours

a 7-day averaging

The revised

of the compliance

in the

with the comment that

not

7 days is long enough to eliminate

to

agreed

still

were appropriate

EPA concluded that

both

add-on

is

amount of time to adjust

Therefore,

without

that

However, EPA agreed

reasonable

FCCU's

technology

were no tests

a reasonable

would be too short.

time

catalyst

controls
choose

exceedances

proposed

time

IV-K-9,

No commenters

of

standards

from 3 hours

IV-K-6,

:T:

to
and

disagreed.

Comment:

Two commenters
period

for the

(IV-D-4

feed sulfur

and IV-D-20)
cutoff

pe ri od .

The use of the 30-day

a 30-day

rolling

generator

average

period

stated

should

period

that

be a 30-day

the averaging
rolling

would be appropriate

isused

for the

fossil

average
because

fuel-fired

steam

NSPS.

Response:
Whenever

an individual

practical,

source

EPA determines

category

30-day

rolling

average

simply

to copy

the

period

fossil

basis.
for

NSPS regulatory

It

is not appropriate

the FCCU feed

fuel-fired

steam

requirements

sulfur

generator

cutoff
NSPS.

on

to use a
standard
The

proposed 7-day averaging period was selected by EPAafter careful

consideration

of a range

of averaging

2-20

periods.

A daily

averaging

time

was judged by EPAto be too short to account for sampling variability.

Also, a daily averagingtime Houldconstrain a reiinerls flexibility in

blending different types of feedstocks'for processing in the FCCU. A
7-day averaging time would reduce sampling variability and increase
refiner'flexibility

in selecting

the FCCUfeedstock

mix.

However,

increasing the averaging time beyond a 7-day period would allow feddstocks with sulfur

contents

significantly

greater

than 0.30 weight

percent to be processed in the FCCUduring a portion of the sampling

peri od. Consequently,a refiner would~

be able to process high sulfur
feedstocks without having t~ use any SO, controls.
Therefore, EPA
selected the 7-day averaging period to allow reasonable fl'eiibility

to the refiner

for processing different

2-21

sulfur content feedstocks.

3.0

3.1

CONTROL

TECHNOLOGY

COMMENTS

SO, SCRUBBERS

Comment:

Two commenters
the

performance

proposed
data

of scrubbers

standard

for

that

scrubber

base;

feeds

(2 percent

(IV-D-9)
feeds

(IV-D-5 and IV-D-9)

wrote

as applied

add-on

constituents

efficiencies.

Thus,

high

sulfur

coal

differs

high

sulfur

feedstocks.

They stated

should

be confirmed.

scrubber

tLe

higher

sulfur

among scrubber

sulfur

that

performance

from scrubber

that

One commenter

differences

containing

of

upon an insufficient

on FCCU's processing

can be subtle

and chemical

removal

is founded

performance

there

EPA's assessment

to FCCU's.

controls

or more sulfur)
that

challenged

for

performance

affect

scrubber

boilers

for

firing

FCCU's processin~

Response:
Scrubber

SO, control

and good contacting

scrubbing

between

liquor.

as those

However,
high

scrubber
exhaust

coal

Therefore,

high

lower

con~ustion

off the

for

flue

for

ities

between

process

that

exhaust

gases

A comparison

between

take

place

in the

are similar

boilers

FCCU regenerator
3-1

deri.ved
exhaust

material

the

similar

The catalyst

Given the

fuels,

air

to

to the
similar-

combustion

is expected

to yield

from coal-fired
gases

to,

showed that

similar

in boilers.

to those

if the

by adding

is thus

FCCU regenerator

of FCCU

is applicable

boilers.

regeneration

solid

confirm

the composition

This comparison

process

as

gas streams.

by EPA to

industrial

during

to

to FCCU's processing

is a carbonaceous

coke and other

place

that

sorbent

applied

to determine

industrial

fuel-fired

catalyst

that

catalyst
takes

scrubbers

testing

gases

feedstocks.

The regeneration

processes

liquor

gas and the

SO,-containing

EPA compared

boiler

sulfur

used in solid

regenerator.

judgment,

was available

of sodium scrubbers

coke is burned
the

to

coke formed on the FCCU catalyst

to the

flue

have not been applied

to industrial

FCCU's processing
the

none

performance.

performance

scrubbing

SO,-containing

applied

scrubbers

feeds,

gases

the

of the

gas streams would be expected to operate

scrubbers

because

sulfur

a function

Based on engineering

higher SD,-containing
well

is

and industrial

boilers,

boiler flue gases was presented in fable 4-3 in the proposal BID. The
comparison showed that

the ranges in concentration

of most FCCUregen-

erator exhaust gas constituents ~nitrogen (N2), oxygen (02), 002, SOx,
nitrous

oxides (N0,)1 are similar

to the boiler

flue gas concentrations.

Scrubber systems installed on FCCUregenerators will thus experience

similar inlet concentrations as boiler scrubber systems. The primary
difference between FCCUregenerator exhaust gases and boiler flue gases
is the particulate emissions. Boiler particulate emissions are higher
and ~canpo2ed primarily

of regenerator

of fly ash.

particulate

Catalyst

emissions.

fines comprise the majority

In an industrial

boiler application,

fly ash is typically

collected upstream of a non-venturi type scrubber.
A similar typeof scrubber applied to an FCCUwould require particulate
control

(refer

upstream

from the

scrubber.

According

to scrubber

to Docket A-79-09, item IV-J-6), the particulates

through the pa'rticulate

control

the scrubber

of the application.

regardless

vendors

that pass

device would not affect

the design of

This is because catalyst

fines are no more erosive than fly ash and neither type of particu7ate
would interfere

particuiates

with the scrubbing

reaction.

Thus, the difference

in

from an industrial boiler and an FCCUare not expected to

affect scrubber performance.

Hydrocarbon emissions from FCCUregenerators
may be higher than those from boilers.
The presence of hydrocarbons in
the FCCUgas stream will not affect
Due to the

low solubi7ity

scrubber

of hydrocarbons

operation

or perfon~ance.

in the aqueous

scrubbing

liquor, the hydrocarbons will not be absorbed but pass through the
scrubber to the atmosphere. .Other differences
in gas compositions are
minor and are not expected
systems

for

industrial

II-B-21)

in flue
boilers

and consideration

conclusion

that

applicable

to

applied

the applicability

of scrubber

FCCU regenerators.

The similarities
between

to invalidate

industrial
FCCU's.

to an industrial

gas flow rates

and characteristics

and FCCUls (refer

of their
boiler

Source

boiler

to Docket A-79-09,

differences

support the reasonable

sodium scrubber

test

results

burning

for

a high

item

performance

a sodium

sulfur

is

scrubber

fuel

show that

sodium scrubbers can achieve at least

sions at high inlet SO, concentrations

90 percent reduction in SOx emis(refer to Docket A-79-09, item

II-A-11).

a reasonable

Therefore,

EPA has

reached

3-2

conclusion

that

the

FCCU standard
expected

is achievable

range

and that

of FCCU regenerator

The commenter

did

not

scrubbers
exhaust

provide

gas

performance

for

industrial

boilers

scrubber

performance

for

FCCU's.

Therefore,

mentioned

expect
to

that

similarities,

scrubber

applicable

sulfur

for

to show that

would

be different

than

in consideration

EPA believes

performance

over the

concentrations.

any information

scrubber

above

are

that

it

industrial

is

of the

reasonable

boilers

to

is applicable

FCCU's.

Conanent:

One commenter

scrubber

system

SO, removal

(1V-D-16)

currently

As discussed

applied

below,

90 percent

to achieve

Research

and Engineering
applied

high

the

of 95 percent

A-79-09,

items

1I-D-41

concentrations

bers

vendors

in

tower

reported

(see

should
Docket

that

of all

sodium scrubbers

achieved

SO, control

A-79-09,

items

efficiencies
and

11-1-50).

90 percent

companies

However,

ERE scrubber

II-I-42

of

refining

Exxon

for the

efficiencies

other

for

(see

ERE states

the

Docket

that

at

low

than 500 vppm), SOx removal decreases.

a minimum outlet

Docket A-79-09,
sodium

items

tower

scrubber

non-venturi
at least
item

scrubber

Due

concentration

II-B-10

vendors

and performance
type

at a location

achieve

reduction.

licensor

II-D-95j.

other

or tray

A-79-09,

Docket

scrubbers

of

and II-D-50)

standard.

applicability

FCCUSO, emissions
device

the

has been guaranteed,

The EPA testresults

fluctuation,
(see

contacted

the

(spray

and

and process

EPA

regarding

90 percent

has been changed to SOE.

of SO, emission

for

(less

50 vppm is reasonable
The

sodium

be guaranteed.

SO, control

has installed

included

levels

(see

it

to sampling

poliutant

(ERE) is the

scrubbers

is

guarantee

scrubbershave

The ERE has guaranteed

and

to FCCU's will

to FCCU's are venturi-type

to FCCU's.

show that

inlet

of the

would similarly

designed

in excess

the

SO, reduction

Sodium scrubbers.applied

system

licensor

the regulated

S02 removal

currently

if

as opposed to 302 removal.

Response:
Since proposal,
and thus

asked

for

information

of non-venturi

designs)
scrubbers

type

to FCCU's.
installed

IV-3-6).

Based

3-3

reductions
on these

These

to control

downstream from a particufate

90 percent

scrub-

control

in SOx emissions
responses,

EPA

believes that, besides ERE, other sodium scrubber

90 percent SO, removal in FCCUapplications.

vendors will

guarantee

Comment:

One commenter (IV-K-E) stated

to

issue

an NSPS because

emissions

that

no add-on

has been adequately

EPA does not have the authority

control

device

demonstrated.

for

sulfur

oxide

The commenter made this

claim by maintaining that if "a 3-hour averaging period is too short

to ensure

that

exceedances

of the proposed

to normal FCCU or control

system

standard

variability,"

would not occur

then

tests

tion would not prove the adequacy of add-on controls

emissio ns .
data

for sulfur

dura-

in the

BID Appendix

to lower~FCCUSO, emissions,

C are

for short

since

"all

periods."

Response:
Since the standards
the regulated
if

the

sion

pollutant

regulated

still

proposed,

the Agency changed

from SO, to SO2 for add-on controls.

pollutantfor

the

standard

for

add-on

Even

controls

were

SO,, the pgency disagrees that the lack of long-term SO, emisreduction

data

been adequately
contain
that

were originally

ability

supports

reduction

period

refinery

gives

scrubber

to attain

performance

over a 7-day

to attain

period,

and adjust

process

with

and believes

are adequately

conclusion,

demonstrated

because

variables,

does not.

commenter's

at

have

in each

SOx emission
least

90 percent

a 7-day averaging

more time to correct

changes,~ ~t~ereas a 3-hour period

the

scrubbers

well over 90 percent

ability

operators

scrubbers

The Agency believes

and maintained

a scrubber's

SO, emission

that

CAppendix C does

data for SO2.)

of well-operated

tests

a conclusion

for SO, emissions.

(12 day) test

of the short-term
reduction

to support

demonstrated

long-term

the

fails

minor problems

in

such as feedstock

Thus, the Agency disagrees

that

add-on

controls

for SO, emissions.

Comment:

One commenter
scrubbers

for

added that

request,
f.ired

the

that

steam

(IV-K-12)

effective

stated

SQ3 reduction

company has test

indicate
generators

that

that
at

available

SOg percent

gas

The co~8nenter

to the Agency upon

removal from scrubbers

production

3-4

on flue

is not warranted.

data,

a western

EPA's reliance

field

is

very

'"

oxide

In that event, the cormnenter noted, the Agency has no data

proving the adequacy of devices

the

of this

due

on oillow,

while

:-~7

SOp percent

removal

scrubbers

are

although

they

is much higher.

known to

are

be less

efficient

According

effective

for

to the.:commenter,
submicron

for

SO2 and particulate

the

concerns

particulates,

removal.

Response:
The Agency

that

flue

appreciates

gas scrubbers

The EPA agreesthat

controlling

This appears

from

scrubbers

S03 removal.

resolved

to differences

indicated

in scrubber

by the

portion

Thus, the

this

steam

commenter for

out,

generators

showing

of total

potential

this

it

possibly

regenerators,

SO, from regenerators

adverse

environmental

the

apparent

although

Although

all

(80 to 99

as pointed

rulemaking,

design.

in

on FCCU regenerators

can be substantial

to contradict,

for

of SO3 emissions.

be as effective

by scrubbers

on oil-fired

commenter

However, as shown in Appendix

The Agency does not believe

to.be

small

S02.

on SO3 removal

by the

for control

may not

that SO3 removal efficiency

percent).

needs

systems

S03 as in controlling

irdicate
data

are not effective

scrubber

of the BID, data

expressed

commenter's
"very

low"

contradiction
is

likely

not

as

due
low as

S03 constitutes
using

impact,

add-on
even.jf

controls.
scrubber

efficiency
for S03 removal is actually "very low," will be very small.
Thus, the Agency believes that the decision to use SO2 as the regulated
pollirtant

for

regenerators

with

add-on

controls

is still

appropriate.

Comment:

One commenter
systems

(i.e.,

would result

(IV-D-7)

scrubbers)

stated

and the

flue

gas desulfurization

have poor operability.

in more frequent

profitability

that

FCCU shutdowns,

nation's

refining

Scrubber
reducing

(FGD)

shutdowns

refinery

capacity.

Response:
At proposal,

sodium scrubbing

to seven FCCU regenerators

at

These seven FCCU regenerators

processing
other

capacity.

scrubbers
There

sodium

scrubbers

or reduced

is

represent

refinery

support his claims.

to control

11 percent

increased

to

SO, emissions.

the

FCCU shutdowns,

have begun opera-

operation
reduced

of these
refinery

The commenter provided

The sodium scrubbers

3-5

FCCU

to the Agency's knowledge, two

show that

profitability.

applied

of nationwide

FCCUls at two refineries

no information
has

had been effectively

refineries

Since proposal,

controlling

tion.

five

systems

applied

capacity,

no data

to

to FCCU's have operated

continuously with no failures between FCCUturnarounds (see Docket

A-79-09, item I.I-B-1O). Thus, EPA continues to believe scrubbers are

an effective
3.2

control method for reducing FCCUSO, emissions.

SO, REDUCTION
CATALYSTS

Comment:

.:j

CaTimenters (IV-D-2,
that

SO, reduction

IV-D-7, IV-D-8, IV-D-9, and IV-D-1O) stated

catalysts

80 percent reductions

are not demonstrated

in SO, emissions.

and cannot

achieve

Three commenters (IV-D-2,

IV-D-9, and IV-D-IO)argued that EPA's data on 80 percent reductions in

SO, emissions are based on "ideal"
tive of many refinery operations.
that SOx reduction catalysts will
selecting FCCUcracking catalysts
processing

a variety

ii

feedstocks which are not representa-

One commenter(IV-D-7) pointed out

T~

reduce a refiner's flexibility

in
thereby affecting FCCUefficiency in

of feedstocks.

Another commenter (IV-D-9) stated

that: (1) the thoroughness of contact between the SO, reduction

catalyst and regenerator gases determines the maximumachievable SO,
control; (2) innovations in regenerator technology that reduce regenerator

catalyst

inventory

will

reduce contact

time and thereby

nega-

tively affect SOx reduction catalyst capability; (3) FCCUregeneration

efficiency deteriorates over the course of a 2- to 3-year period, and
this deterioration,
which may affect the performance of SO, reduction
catalysts,

is not addressed

by any existing

corrtmercial test

data;

and

(4) the impact of feedstock sulfur content and composition on SO,

reduction
could
sulfur

catalyst

effectiveness

impede applicability

has not been fully

of the

catalysts

recognized,

at moderate

and

feedstock

levels.

Response:
The EPA considers SO, reduction catalysts
to be an emerging
technology.
The standards allow for their use and thereby encourage
their

further

development.

Current

According to SO, reduction catalyst

catalysts

show promising results.

developers,

current SOx reduction

catalysts
can achieve SOx emission reductions of 65 to 75 percent (see
Section 2.5.2).
Concerns and uncertainties
about catalyst
performance
remain

because

the

technology

is not fully

developed

at this

time.

Developers of SO, reduction catalysts

report that optimum performance
of SO, reduction catalysts
is achieved when: (1) the FCCUis operated
3-6

--3

in the complete CO combustion mode with.an excess oxygen content of 1.5

to 2.0 percent by volume in the FCCUregenerator exhaust gas; (2) FCCU
regeneration
temperatures are maintained as low as possible while
maintaining complete CO combustion; and (3) good contact is maintained

between the SO, reduction catalyst

erator

and combustion air within the regen-

(see Docket A-79-09, item IV-B-9).

operating
standard

lysts

restrictions
for

only.

may prevent

FCCU's without

In these

using hydrotreated

cases,

Thus, it is possible

some refiners

add-on

controls

the refiner

or low sulfur

from achieving

using

SO, reduction

that
the
cata-

can achieve the standards

feedstocks,

combination with SO, reduction catalysts,

either

by

alone or in

or by scrubbing.

Comment:

One commenter (IV-D-1) stated

that

recently

completed studies

show

that SO, reduction catalysts are capable of achieving the necessary SO,
reductions

such that

FCCU's operating

California

can achieve

Phase

at refineries

II of Rule 1105 of the

located

in Southern

SCAQMDregulations

(60 kg S02/1,000 barrels of feed).

Response:

Phase II of Rule 1105 is more stringent

without

add-on controls

than the standard

proposed by EPA. The commenter's

for FCCU's

indication

that SO, reduction catalysts used in FCCU'slocated in Southern California

are expected to achieve an emission limit more stringent
than this standard
supports EPAls determination that, in many cases, the SO, reduction

catalysts
3.3

can achieve the level of the9.8

LOW-SULFUR

kg 50,/1,000 k'g'coke burn-off.

FEEDSTOCKS

Comment:

One commenter

(IV-D-16)

stated

that

the

proposal

B1D did not

consider using virgin feedstocks that naturally contain low sulfur as

a control technique for FCCUSO, emissions. The commenter recommended
that

the

standards

be reevaluated

with consideration

given

to whether

the proposed standards will have any impact because of the probable
diversion

of low-sulfur

feedstocks

to affected

menter suggested that EPAcalculate

using

low sulfur

facilities.

The com-

an "avoidance cost" for refiners

FCCU feedstocks.

3-7

Response:

The proposal BIDdid not evaluate the exclusive processing of

low sulfur virgin feedstocks as a control alternative for reducing FCCU

SO, emissions. At the time the proposedstandards were being developed,
refiners in the United States were experiencing limited supplies and
high prices for low sulfur feedstocksand crude oils. As a consequence,

_I

new process units were installed

at many refineries
in orde.r to allow
the processing of high sulfur crude oils.
Thus, EPA did not believe
that

low sulfur

feedstocks

would be a cost-effective

alternative

to

achieve these standards.

The proposed standards, however, provided-a
feed sulfur cutoff.
The EPArecognizes that low sulfur virgin feedstocks are one means a refiner may choose to achieve compliance with
either the standard for FCCU's without add-on controls or feed sulfur
cutoff.
At present, the availability
of low sulfur crude oils has

improvedand crude oil prices have significantly declined from the peak
1980 prices, but not all refiners will choose to limit FCCUprocessing
to low sulfur virgin feedstocks.

Many refiners

sing crude oils containing Ito 2 percent sulfur.

potential

exists

that.refiners..will

be processing

are currently

proces-

Furthermore, the
higher sulfur

content

crude oils within the next 5 years. Therefore, EPAexpects that most
refiners will use SO, reduction catalysts, hydrotreating, or scrubbers
to

achieve

these

standards.

3-8

:I

4.0

4.1

ENVIRONMENTAL

AND ENERGY

IMPACTS

COMMENTS

MODEL PLANTS USED FOR IMPACT ANALYSES

Comment:

One commenter

is less

(IV-D-16)

today than

January

FCCU's used by EPA for

impacts

using

showing

the

reduced

FCCU fresh

the

estimates

energy,

capacity

to

Response:
According

to the Oil andGasournal

IV-J-2),

FCCU capacity

has

m3/sd, or about 2.5 percent.

that

of the

cited

the

size

data

impacts

his

(see

Oil and Gas

claims.

1980 to

This decrease is a result of the shutdown

However,

also

period,a

modified

or reconstructed,

and new FCCUls were constructed.

FCCU

and

New

existing

construction

units

are reported

(see

Docket A-79-09,

that

12 new FCCU's

were undergoing
1984.

Based

estimates
that

on this

provided

standards

reconstructed
reasonable

were

modification

A review

undergoing

construction

reconstruction

of this

EPA still

proposal

7 modified

information

5 years.
data

that

Table

be subject

new, modified,

by EPA in the proposal

(see

the.growth

The EPA projected

FCCU's would

of the

units

1981 and mid-

BID are reasonable.

The size

shows

and 14 existing

believes

or reconstructed

of

"Boxscores"

or revamping- between the"years

in the

on these

and

1980.

FCCU's were

in Hydrocarbon Processing

FCCU's projected
based

since

number of existing

information,

within

which have closed

IV-J-3).

expansion

10 new and

these

item

item

1984 by 21,450

refineries

this

be

of new

Docket A-79-09,

from

of
should

andnumber

of FCCU's at unprofitable
during

capacity

and economic

from the

support

decreased

feed

numbers and sizes

environmental,

The commenter

decreasing

total

the

The connmenter stated

and revamped FCCU's.

Journal

that

1980, and that

analyzing

are incorrect.

reevaluated

stated

A-10 for

and

BID also

estimated

to.

appear
sizes).

Comment:

One commenter

(IV-D-16)

stated

that

the 3.5 weight

percent

sulfur

feed level model plant should not be included

in the impact analyses

because

reflect

the 3.5 percent

The commenter
that

cited

sulfur

a "Davison

only one heavy oil

model doesnot
Catalagram

FCCU processed
4-1

66" (1982)

feed

with

industry

practice.

which stated

a sulfur

content

above

2 percent
0.6

and that

the median value of the feedstock

sulfur

content

was

percent.

Response:

The EPAdeveloped model plants based'on current industry practices

and onprojected

refining

trends

over a 5-year period.

At the time the

model plants were developed, manyrefining companieswere developing

and putti ng i n place "bottom-of-t he-barrel " refi ni ng to al low t he processing of higher.sulfur feedstocks than currently practiced by the
industry.
Model plants were selected to Span the range of possible

feedstock sulfur contents including "bottom-of-the-barrel" refining.

The EPA`recognizesthat most refiners currenti.y are processing feedstocks containing up to about 2 weight percent sulfur, but the potential
exists that FCCU's (especially HOC's) will be processing higher sulfur
feedstocks within 5 years. Thus, although the 3.5 weight percent
sulfur model plant may not reflect current industry practice, a reasonable potential exists that some FCCU's will be processing during the
next 5 years feedstocks containing greater than 2 weight percent sulfur.
Therefore, it is reasonable to include the 3.5 weight-percent
sulfur
model plant

in the

impact

analyses.

Comment:

One commenter (IV-D-16) asked why environmental,

economic

impacts

proposal

BID.

for

calcium-based

scrubbers

energy,

were omitted

and

from the

Response:
The analysis
of the

proposal

of various
BID was not

scrubbing
meant

to

systems presented
be all

inclusive.

in Chapter 4
The environ-

mental, energy, and,economicimpacts for calcium-basedscrubbers applied

to FCCU's were not analyzed

in the-proposal

does not use a sodium scrubber

that the refiner

scrubber

system.

scrubber

to

4.2

to achieve the standards,

would choose either

achieve

However, a refiner
these

BID because if a refiner

EPA expects

a dual alkali or a regenerable

could

choose

touse

a calcium-based

standards.

WATER IMPACTS

Comment:

Five commenters (IV-D-4,..IV-D-5, IV-D-7, IV-D-16, and IV-D-20)

stated that the waste disposal aspects of the proposed standards are
4-2

more complex than

One commenter
obtain
only

(IV-D-16)

a permit

scrubbers.

shown by the

This

commenter

requested

discharge

permits

need to

install

replacement

presented

no inland
of waste

that

rivers

could

under

Federal
not

discharge

additional

that

have

refineries

The

of water

treatment

a Wellman-Lord

receive
(IV-D-5)

would

systems

to

the costs

scrubber

for

used at a

ponds can be expected

under the Resource Conservation

used

commenter

bodies

wastewater

settling

been

could

Another

large

to

from sodium

scrubbers

inland

BID.

would be able

This con~snenter cited

of a fly ash pond for

proposal

be used for disposal.

near

levels.

and stated

liquids

regulations.

located

fn;the

refiner

sodium

EPA show that

expensive

power plant,

scrutiny

that

refineries

meet permitted

that

noted

or large

commenter
that

stated

for the discharge

where oceans

stated

analysis

to receive

and Recovery Act (RCRA).

Response:
The EPA agrees

application
that

that

the waste

and operated

at

or other

reasonable

apply

to all

wastes

are

wastewater
treated

with

from the main refinery

of
If

these

the

separately

system,

regulate

them.
sodium

about 6 percent
sul fates.
dissolved

There

scrubber

associated

with

then

limitations

(40 CFR 419) technically

refinery

control

accounted
are

under

processed,

treated,

wastewater

collection,

~However, the major polluting

scrubber

wastestream

solids

by weight,

are

currently
of

basis,
would

is

its

the

sodium

high

scrubber

of the Federal

a discharge

and still

comply with

standa rds .

The EPA's Quality Criteria

4-3

discharged

solids

or

content,

of sodium

applicable

wastestream.

outside

the

419 regula-

of the

primarily

regulations

on whether

the

treatment,

dissolved

where appropriate,

accommodate

or

characteristic

solids,
be based

Part

far

would be made to

wt~ich consists

no Federal

discharged

The costs
the

determinations

when these

or are

system.

for

locations.

devices

wastewater

treatment

case-by-case

on dissolved

on a case-by-case

guidelines

the

are

can be installed

at inland

pollution

main

systems

refineries

from air

wastes

solids'content

limitations
Such

effluent

wastewater

wastes

of scrubber

for

from the main refinery

disposal
treated

types

costs

The petroleum refining

tions.

aspects

of scrubbers are complex. However, it is EPA's judgement

sodium scrubbers

treatment

disposal

to the
Instead,

would be developed
effluent

guidelines.

receiving

a State's

water

water

for Water specifies

body

can

quality

a maximum

~irJolve~
rolidr
content
at500.9/1
Infrerh
uarer.lodiu.
icrub~er ~3
wastes are produced at the rate of 0.19 to 0.38 m3 per minute.

Unless

the receiving water body has sufficient

flow for dilution,
its dissolved
solids content will exceed the water quality criterion
downstream from
the

sodium scrubber

discharge

For many refineries,

point.

the

sodium scrubber

wastewater

would constitute

a small portion of the total refinery wastewater flow. Therefore, the

dissolved solids content of the combined scrubber and treated
wastestreams

may be within

acceptable

levels-.

refinery

A permit may be issued

for the discharge of sodium scrubber wastes to a publicly-owned treatment

works (POTW)by way of a sewer if the POTWreceives

wastewater flow from the municipality

wastestream

dissolved

solids

sufficient

i~

total

it serves such that the scrubber

are diluted

to acceptable

levels.

At proposal,there weresevensodiumscrubbersoperatingto control

SO, and particulate
are

located

at

emissions

coastal

from FCCU's.

locations.

Since

to saltor

brackish

water.

to the Agency's

SO, and particulate

from FCCU's have begun operation.

discharges

seven sodium scrubbers

proposal,

knowledge, two other scrubbers controlling

emissions

All

At least

No requirements

one of these
exist

for the

discharge of sodium scrubber wastes to brackish or salt water.

to brackish

or salt

to all refiners
the proposal

discharge

water

in inland

preamble.

to surface

methods may apply.

pending,

or discharge

locations.

to a sewer will

Disposal

not be available

This was acknowledged by EPA in

Where permits

waters or sewers,

are unavailable

other.wastewater

for direct

disposal

These other disposal methods include evaporative

deep-well

injection,

and recycle.

Evaporative

pending is

limited to those western States where evaporation exceeds precipitation.

Deep-well injection
is of limited applicability
due to the hazards of
groundwater

contamination

refiner

elects

to

charge

permit,

in many parts

install

he will

a sodium

of

scrubber

the
but

need to use one of these

United
cannot

disposal

States.
obtain

If

a dis-

methods.

The

added cost of these disposal methods would be greater than the disposal
cost used fcr- EeA's cost estimates.
Ho~ipver, other scrubber systems,
such
controls

as dual
at

alkali,
reasonable

are

available

to meet

cost.

4-4

the

standard

for

add-on

11~

Sodium

control

scrubbers

have

SO, emissions

of 47 sodium
charge
deep-well

either

it
to

water

is

sewers,

possible

for

a permit

to

As mentioned
wastewater

to

dual

strated

removal

efficiencies

BID, Chapter
and FCCU flue

systems
these

are

gases

to these

comments (see

dual

alkali

the

refiner

Table

catalysts,

have

no significant

add-on

The costs

by EPA in the

and again

for dual

Appendix

developed

or by complying

with the

wastes

and

have

demon-

boilers

between
3.2),

(see

industrial

these

scrubbing

and c.ost effectiveness

proposal
alkali

preamble

in response

and are judged

volume

proposal,

to

provides

Alternatively,

with the

hydrotreating

feed sulfur

of

(see

scrubbers

IV-B-15)

compliance

by using

or Wellman-L~s~

systems

to this

since

to demonstrate
controls

item

wastes.

cost.

on industrial

in Section

Docket A-79-09,

may choose

liquid

wastes;

scrubbing

(discussed

surface

which have no

liquid

similarities

to

with minimal

solid

Due to the

costs

wastes

scrubbing,

produce

These

A-8 in the

scrubbing

FCCU's without

drying

instead

were evaluated
8),

location

of the

systems

7 use

wastestream.

to FCCU's at a reasonable

to FCCU's.

BID, Chapter

be reasonable.

SO, scrubber

5 dis-

refinery

scrubber

to

population

pending,

of the

to dispose

of 90 percent

4).

proposal

sodium

means

product.

applicable

scrubbers

another

~hich

sulfur

boiler

an inland

but

a salable

proposal

at

discharge

locations

boilers,

23 use

a refiner

other

produce

water,
dispose

wastes

scrubbing,

industrial

to

and spray

and

to

inland

From a total

recycle

alkali

liquid

at

boilers.

surface

are applicable

significant
citrate

use

above,

impacts

include

to

and I uses

or

extensively

applied

9 discharge

obtain

or

These

currently

injection,

Therefore,

used

from industrial

scrubbers

to a sewer,

been

standard

for

or SOx reduction

cutoff

using

low sulfur

feedstocks.

The sodium

scrubber

wastewater

from the FCCU regenerator

from the
fines

wastestream

would

la nd fi 1 1 .

Currently,
(ESPls)

of in landfills.
will

be

wet

in

be removed

precipitators
and

exhaust

gas.

a settling
from

the

catalyst

include

fines,

fines

these

pondanddisposed

are

collected

FCCU particulate

4-5

sodium

salts

are removed
catalyst
of

in a

in electrostatic
NSPS, and are disposed

when removed from the

dissolved

removed

fines

Eventually,

settling

fines

catalyst

These catalyst

pond.

to meet the

Catalyst
will

contains

such

settling
as

sodium

pond,

sulfate, sulfite, and bisulfite.

However, neither catalyst fines nor
sodium salts are reactive in water and do not create a leachate problem
like

coal fly ash.

Therefore,

selected

for disposal

catalyst

fines

the SO, NSPS will

of catalyst

settling

fines.

not affect

Thus,

pond would fall

under

it

the method'

is doubtful

that

RCRA.

Comment:

One commenter (IV-D-PO) agreed with EPA that

may not be applicable

availability

in inland

refinery

locations

.sodium scrubber

blow-down on refinery

such a high

seriously

of total

solids

in the

the high dissolved

necessitate

the

solids

installation

solids

of the activated

receiving

waters.
alkali

where water

In support of this,
quality,

and stated

in the blowdown would

sludge plant, leading to

The commenter stated

impacts on receiving
of dual

scrubbers

showing the impact of

wastewater

dissolved

reduce the efficiency

high dissolved

that

level

alkali

or areas

or wastewater discharge is restricted.

the commenter provided an example calculation

that

single

waters would

scrubbers.

Response:

As.discussed above, EPA agrees that the potential

impact that high
dissolved solids from sodium scrubbers would have on receiving waters
may, in certain cases, necessitate
use of another control technique,
such as a dual alkali scrubber.
However, it is EPA's opinion that the
sodium scrubber
treatment

will

not negatively

affect

a refinery's

wastewater

plant.

The EPA's analysis of sodium scrubbers- presented in the proposal

BID includes the cost of wastewater treatment facilities.
These facilities

include

aeration

bas.iri to reduce

By using these
stream

a settling

pond for removal of catalyst

the

wastewater

chemical

treatment

treatment plant.
wastewater

treatment

the refinery's
wastewater

If the treated
facility

treatment

plant

will

the

mixed

treatment
not

4-6

the

refinery's

effluent

is

main wastewater

oxygen demand of the wastestream.

facilities,

does not need to pass through

fines and an
scrubber

waste-

main wastewater

from the sodium scrubber

with

the

plant,

be affected.

treated

effluent

the refinery's

from

main

4.3

SOLID

WASTE IMPACTS

Comment:

One commenter
the

preamble

impacts.

cost

to the

impacts

for

scrubber

costs

water,

should

increase

disposal

costs

water

Another

According

the

would rise

solid

would

have

by weight.

that

address

Since

waste

scrubber

accordingly,

if disposal

systems that

are currently

no added

that
waste

disposal

sol'id

generated

waste

the

(IV-D-7)
the

in

states

the waste

to the commenter,

amount of solid

to

preamble

commenter

do notadequately

systems.

greatly

scrubbers

and why the

50 percent

much.

standards

of scrubber

disposal

presented

pertained

the commenter reasoned

be twiceas

proposed

that

why sodium

waste
is

two statements

standards

asked

solid
waste

is 50 percent

questioned

proposed

The commenter

sodium

the

(IV-D-16)

wrote

that

waste

impacts

systems

could

by a refinery
locations

and

are available.

R~sponse:

The sodium scrubbing

control
type

both particulate

of scrubber,

required

to

an additional

achieve

particulate

emissions

the

as well as SO, emissions.

With this

control

current

particulate

standard-.

(primarily

catalyst

does not incrementally

control

to FCCU's

particulate

the

emissions

applied

increase

the dry weight

by a dry particulatecontrol

amount of particulates

"chargeable"

would

volume.

It

a scrubber

device,

collected

be wet

will

cost

and,

thus,

more

to

to~ a landfill

transport

than

dry

amount of water added to the solids

dards

and

scrubber

is

included

costs.

as a conservative

scrubber

waste

In order

the water
to date,

estimate

to the
to

the

none of the

of the

costs

(see

Section

the

additional

in settled

percent

solids

settling

to FCCU's has been emptied.

waste''

more

and encompass

in a

a larger

solids

collected

The increase;due

cost

analysis

disposal

to dispose

sodiurn

was added
liquid

document).

waste

disposal

(sludge),

content

of the

scrubber`solids.

ponds used for

the

of

cost

treated

5.1 of this
solid

to

in

to the SO, stan-

in the

waste"

Therefore,

collected

solids

cost

due to

it was necessary

sodium scrubbers

EPA has no information

4-7

over
are not

scrubber

Thus,

of FCCU

waste

sodium scrubbers

is "chargeable"

a ''liquid

sewer

determine

contained

to determine

as a "solid

In addition,

of solid

and dispose

solids.

Control

by a sodium scrubber

However, solids
weigh

would not be

such as an ESP.

by the

to the SO, standards.

scrubber

fines)

device

However,
applied

regarding

the

water content of settled particulates

(sludge) co'llected by a sodium
scrubber. Instead, EPAhas information regarding the solids content of
wastes for other scrubbing systems, such as dual alkali scrubbers. For

these other systems, scrubber waste is typically 60 percent solids.

To be conservative, EPAassumed that the settled sodium scrubber waste
would be approximately 50 percent solids, by weight. The EPAbelieves
that sodium scrubbers would not significantly increase the amount of
solid

waste generated

by a refinery,

Other types ofnonregenerable

scrubber systems, such as dual

alkali, spray drying, or lime/limestone scrubbers, produce a greater

quantity of solid waste with little

sodium scrubbers.

liquid discharge compared to

A dual alkali scrubber controlling SO, emissions

from an FCCUprocessing

a 1.5 weight percent

sulfur

feedstock

will

produce approximately 7,700 Mg/yr of solid waste for a 2,500 m3/stream

day (sd) FCCUand 25,000 Mg/yr for an 8,000 m3/sd FCCU. The EPA
considers the solid waste impacts for-these systems reasonable.
Should
solid

waste disposal

consider

control

not be possible,

techniques

that

the refiner

would need to

do not produce solid

include using regenerable scrubber systems(e.g.,

waste.

These

Wellman-Lord or

citrate scrubbers which produce salable sulfur products), hydrotreating,

SO, reduction

catalysts,

or the purchase of low sulfur

feedstocks.

Comment:

One commenter (IV-D-4) stated that the proposed standards

discourage the recovery of reusable material by imposing sodium

scrubbers which consume large quantities

other less desirable wastes.

and produce

Each megagramof SO2scrubbed will con-

sume 1 Mg of-sodium hydroxide.

groundwater

of raw materials

The waste is a potential

surface and

contaminant.

Response:

The EPAdisagrees that the proposed sta?dards discourage the

recovery

of sulfur.

The~standard

allows the use of hydrotreating

of these

control

technologies,

or from the regenerator

the

refinery

sulfur

for FCCU's without

add-on

or SO, reduction catalysts.

sulfur

is eventually

plant.

4-8

controls

With both

removed from the FCCUfeedstock

reclaimed as a salable product in

_i

The amount

approximately
through

scrubber.

tants

resulting

these

impacts

impacts

sodium

hydroxide

1.15 times

the

discharge

of

are
are

the

application

reasonable.

discussed

in

discussed

in

by sodiumscrubbers

amount of SO, in the

The EPA evaluated

from
are

the

consumed

the

scrubbers

The water

impacts

Section

Section

4.2
5.1

of this

of

gas stream

impacts

of

this

is

passing

of secondary

pollu-

and determined
of scrubber
document,

that

wastewater

and the

cost

document.

Comment:

One commenter
SO, reduction

(IV-D-16)

catalysts

By dividing

the

by the

commenter determined

fifth-year

reported

that

FCCU solid

that

according

are not expected

nationwide

(820 millionlyr)
increase

stated

the

waste

to have a solid

cost

cost

to the

for

waste

SO, reduction

of the catalysts

use of SO, reduction

by 11,000

preamble,
impact.
catalysts

(81,8O0/M9),

catalysts

the

would

Mglyr.

Response:
The EPA does not believe
would

result

that

in a significant

the use of SO, reduction

increase

in FCCU solid

catalysts

waste

for

the.

reasons discussed below. 'Whenused as an additive, SO,'reduction

catalysts

replace

catalyst

inventory

One of the

their
than

may result

the

tests

formulations

because

produce

would

increasing

a softer

makeup rate

are

would

one.

rate

total
of time.

particulate

for the
much

be in the

quantity
In this
emissions

or solid
4-9

that

increases

than

earlier

catalyst
because

of

catalyst

likely

as a constituent

interest

formulation
cost

catalyst

waste.

to

of the cracking
without

used in the

SO, reduction

less

formulations

can be accomplished
catalyst

less

formulations.

a harder
most

this

Based

developers

developed

of cracking
case,

reported

waste

and therefore,

SO, control

of

is greater

newer SO, reduction

harder

catalyst

softness

of up to 40 percent.

solid

Other recently

and consequently,
the

waste

catalyst

the SOx reduction

over a period
increase

its

The developer

circulating

and IV-D-24).

tan additive),

developer,

makeup

JI-D-57
to the

inso~id

it

items

of the

due

reduction

a lower

incorporate
catalyst

that

10 percent

that,

catalyst.

these

a harder

have

use than

cracking

stated

are anticipated

The EPA believes

to

catalyst

by another

5 percent

5 and up to

Docket A-79-09,

in an increase

on recent

than

developers

SO, reduction
for

less

(see

catalyst

that

than

from

catalysts

FCCU
would not

In summary, whether

the

SOx reduction

tuent

of the

cracking

SO, reduction
solid

waste

4.4

catalyst

ENERGY

catalyst,

catalyst
over

is in the form of anadditive

it

is unlikely

formulations

current

that

or aconsti-

the use of newer

would significantly

increase

FCCU

levels.

IMPACTS

Comment:

One commenter (IV-D-5) stated that the scrubber electric

ments

presented

2 percent

in the

increase

menter stated

that

proposal

to control

stated

that

too low.

Instead

estimated

of the

by ERA, the

0.2 to

in electric

consumption

an increase

in FCCUenergy consumption of 100 percent

wouldbe morerealistic.
system

BID are

requirecom-

Thecommenter
operates a Wellman-lord
scrubbing

SO, emissions

from a utility

energy usage for the scrubber

boiler.

The commenter

is 10 MWcompared to the

0.166 MWenergy usage estimated by EPAfor an 8,000 m3/sd model plant.

The higher energy usage is due to the use of booster
to pressurize

the

Wellman-Lord

flue

gas

scrubber,

in order

especially

blowers necessary

to move the gases

following

through

the

a CO boiler.

Response:
The EPA reevaluated
requirements

its

estimate

of the electrical

of Wellman-Lord

scrubber

systems.

the FCCUregenerator
boiler.

gas through

less

energy

is required

a Wellman-Lord

system

trial

should

or utility

requirements

be lower for

boiler

in

with

high

temperature

The EPA expects

the

to operate

high temperature

believes

with
that

Wellman-Lord

the

majority

the estimate
scrubber

system

requirements

sodium scrubbers

applied

to FCCU's and they

and

regeneration.

presented

are the

based

modified,

energy

in the
rather

only scrubber

are the

systems
4-10

for

than

an indus-

system energy
on an FCCU
of a CO boiler.

reconstructed

FCCU's

Consequently,

EPA

requirements

proposal

in the proposal

of sodium scrubbers

because

than

instead

of the electrical

The energy im'pacts reported

energy

BID are

regeneration
new,

system

Therefore, scrubber energy

The Wellman-Lord

proposal

of

scrubber

an FCCU application

application.

presented

operating

leaves

to move the FCCU regenerator

or other

the energy used for a boiler application.

requirements

The gas stream

at a higher pressure than the flue gas exiting a

As a result,

exhaust

energy

of

BID is reasonable.

BID are based on the

than

Wellman-Lord

systems

EPA expects

that

systems

have been

most refiners

to

install

to

provided

achieve

the

standard

no information

Therefore,

EPA did

revise

The EPA does acknowledge

system

chooses

to

4.5

AIR

use

add-on

regarding

not

a Wellman-Lord

for

sodium scrubber

the

that

energy

impact

commenter

energy
of

requirements.

sodium

an FCCU owner or operator

may experience

sodium

controls.l.The

greater

energy

scrubbers.

choosing

impacts

to use

than

if

one

scrubber.

IMPACTS

Comment:

Four commenters
the

(IV-D-3,

appropriateness

of using

SO, concentrations.
SO, emissions
would

only

impact

that

bring

13 kg S0,/1,000kg
cooling

of the

ing

small

the

air

in ground-level
level

would

if

all.

at

the

include

exit

that

sulfuric

quality

the

acid

temperature
commenter

further

reported

air

for

that

controlling

or

control

to

benefits

to

reduce

sodium
gas

cost

temperature

(2000C).

suggested

cause

gas

exit

stack

in the

of Regulatory

reheating
and

This
modeling

velocity
heights

increase

NSPS little,

concentrations
analysis.

used

diminish-

a net

proposed

of
and

Alternative

below

the

a stack

15.3

exit

to

commenter
is

The commenter suggested

that

the modeling

thereby

EPA require

ground-level

scrubber

and a flue

that

the

kg coke burn-off

of the

suggested

an

below

by scrubbing,

in some cases,

level

impact,

a level

A 13 kg S0x/1,000
quality

FCCU

kg coke burn-off

is accomplished

(IV-D-I~)

dew point

of 260"C

wrote

questioned

ground-level

in a ground-level
If

benefit,

gases

flue

increase

gas would lower the plume rise,

in the

the

(IV-D-3)

small.

concentration.

reheat

stated

quite

commenter

scrubber

if they

decrease

coke burn-off

reduce

Another

a small

exhaust

and IV-D-16)

below a 13 kg 50,/1,000

about
already

IV-D-8,

scrubbers

One commenter

to a level
is

IV-0-6,

m/s.

The

velocities

I aredistorted.

Response:
Scrubbing

a gas

the

stream

Unless
emitted

gas

from

the

stream
is

scrubber

from a FCCU regenerator

of the
plume

plume

reduces

lowers

reheated
stack

not using
the

effective

the

temperature

downstream
will

of the

be cooler

a scrubber.
height

wi 11 ri se.

4-11

of the

above

than

gas

scrubber,

the

the

emitted

plume

Lowering the
the

stream.

ground

plume

temperature
to

which

the

The results of dispersion modeling performed by EPA and presented.

the proposal BID were used to analyz~ the air quality impact of the
proposed standards.
within

In all

the national

cases,

ambient

air

ground level

quality

SO, concentrations

standards.

plantscenarios
except the one processing
ground level SOx concentrations
predicted

For all

the

in

are
model

a low sulfur feedstock, the

for implementation of the

proposed standards are lower than the baseline (uncontrolled)

concentrations.;-~

In these cases,the
decrease in SO, emissions afforded by implementation
of scrubbers offsets the lower plume rise.
This analysis showed that
applying

a scrubber

to a model plant

processing

a low sulfur

feedstock

(0.3 weight percent sulfur)

to achieve 9.8 and 6.5 kg SO,/1,O00 kg coke

burn-off

Alternatives

levels

(Regulatory

would increase

the I-hour maximum ground level

of the FCCU to a level

amount

of emission

not compensate
exhaust
occur

reduction

for the

in actuality

and,

above the

content

achieved

However,

because

SO, concentration

(uncontrolled)

by the

control

resulting

this~model

would

not

case.

The small
did

from the cooler

scenario

would not

0.3 weight

percent

low-sulfur

cutoff

would comply with the

a scrubber

downwind

alternatives

plant

any FCCU processing

feedstocks

therefore,

baseline

lower plume rise

gas temperature.

sulfur

III and IV, respectively)

be installed

on the

source.

Also the model assumes that a scrubber would reduce model plane SO,
emissions

to the level

of the regulatory

reductions

required

to achieve

considered

are

than

less

alternative.

the model plant

the 90 percent,

The SO, emission

regulatory

requi.red.by

alternatives

the

standard.

The EPAagrees that if a control technique other than a scrubber

was

used

to

achieve,

achieve

the

resulting

than

if a scrubber

tion

catalysts

less

The additional

result

same

the

the

standard

emission

plume

than

scrubber

of SO, reduc-

without

add-on

the application
by scrubbers
the

use

would

may be less

application

so that

concentrations

the

concentrations

FCCU's

provided
rise,

as

controls

of scrubbers.
would

of

likely

scrubbers

would

than the use of SO,

cata`lv-~:--.

The stack
modeling

for

reduction

reduction

lower

level

However, the

in lower ground level

reduction

reduction

maximum ground

emission
for

emission

were used.

to meet

would provide
compensate

the

analysis

temperatures,
were

selected

heights,

and exit

as average

4-12

velocities

values

from data

used
for

in

the

actual

FCCU scrubbers.
tions

Only one of the

existing

before

proposal

is

Reheat

is used only occasionally

during

certain

for

the

weather

model
reason,

and the

assumption

equipped

to

are

based

with

reduce

conditions.

plants

For this

seven FCCU sodium scrubber

EPA believes

that

of no reheat

the

are

stack

the visible

The stack
on actual

scrubber

EPA selected

scrubber

modeling

reheat.

steam plume

parameters

sodium

installa-

installations.

input

parameters

selected

appropriate.

Comment:

One commenter

(IV-D-9)

between feed sulfur

sions,

inflating

stated

that

and coke sulfur

the

percent

the

use

overstates

reduction

of the

correlation

uncontrolled

attributed

to

SOx emis-

catalysts.

Response:The EPA agrees

proposal

same time,

The correlation

data

reason,

it
used

for

of

a useful

SO, emissions

SO, emissions

on p.

by industry

the

reasonable

and

is

emissions.

The EPA considers

and SOx reduction

on

For this

in the-proposal

estimating

catalyst

based

types.

shown

for

the

feedstocks.

correlation

means

of

However,

from other

number of FCCU's and feedstock

that

3-18

for some feedstocks.

SO, emissions

uncontrolled

and

presented

by EPA was provided

a large

representative

correlation,

understates

EPA concludes

lation

the

BID, overstates

at the
test

that

BID is
the

corre-

uncontrolled

FCCU

performance.

Comment:

One commenter
adequately
sions.

address

(IV-D-16)
the

effect

The commenter argued

catalysts

would not increase

(Sections

C.3.1.1

that

SO, reduction

stated

the preamble

of SO, reduction
that

the

and Docket

raised

does not

catalysts

preamble

NO, emissions.

and C.3.1.2)

catalysts

that

states

on NO, emisthat

SOx reduction

However, the
A-79-09,

item

proposal

II-B-20

BID

show

NO, emissions.

Response:
Most

from the
tion.

refiners

use

one of two techniques

FCCU regenerators:

Data from some tests

regenerators

show an increase
using

control

HTR or catalytically
of NO, emissions

both CO combustion promoter catalysts

combination

to

and SO, reduction

promoters
4-13

promoted

CO combus-

from regenerators

in NO, emissions.

CO combustion

CO emissions

Separate

without

using

catalysts
data

for

SOx reduct.ion

in

catalysts suggest that the use of these catalysts may increase NO,
emissions. Thus, at this time, it is unclear whether the NO,~increases
observed

for

SO, reduction

catalyst

tests

catalyst

or the CO combustion promoter.

are due to the reduction

Recent commercial tests

of SO,

reduction catalysts in FCCU's utilizing HTRshow no increase in NO,

emissions (see Docket A-79-09, item IV-B-9). No recent tests of SO,
reduction

catalysts

in FCCU's utilizing

Because most FCCU's subject

and because

to the

newer SO, reduct.ion

CO promoters

standards

catalyst

were available.

are expected

formulations

to use HTR

have not increased

N4, emissions, EPA believes that the use of the SO, reduction catal'yst

technologywi.ll not increase NO,emissions.

Co nt:
One commenter
State

regulations

Regulatory
that

the

unit.

(IV-D-16)
into

account

Alternative
selection

Then,

which~the

I.

unit

the

in estimating

plants

emissions
is

that

To remedy this,

of model

baseline

model

stated

BID fails

to take

baseline

emissions

for

the

include

can

proposal

commenter recommended

site

selection

be estimated

based

for

each

on the

State

in

located.

Response:

Emissions of SOx from FCCU's canvary

the

feedstock

processed,

FCCU operation,

significantly

depending on

and capacity

utilization.

Many refiners
have been able to achieve existing State SO, regulations
with little
or no control.
It is difficult
to determine FCCUSO, emission
the

rates

taking

various

individual

formats

simplifying

of

assumptions

State

State

regulations

regulations

regarding

into

do not

account

~end

because

themselves

to

FCCUSO, emissions.

Selection of sites for each model plant is not a reasonabl~

approach

factor

as there

provides

emi s s io ns .

This

is no basis

a reasonable
factor

for

site

estimate

selection.

Using an emission

of baseline

is based on emission

test

nationwide
results

FCCUoperations that represent the level of SO, control

FCCU'sto achieve State and local SO, regulations
prior
and local
tions

that

baseline

SO, regulations
have

changed

have changed
do not

affect

FCCUSO, emissions.

4-14

little

since

EPA's

estimate

FCCUSO,

for typical

achieved by
to 1979. State

1979; those
of nationwide

regula-

Comment:

One commenter
shows a "-4" air
Response:
A "-4",

(IV-D-16)

impact

denoting

in Table

1-1 because

emissions.

This

asked why Table

in three

short-term

FCCUls represent
that

BID

cases.

significant

means

1-1 in the proposal

air

impact,

a significant

FCCUls emit

was entered

source

of SO,

than

100 tons

much greater

per

year of SO,. Because FCCU's are a significant

source ofSO,, and an
SO, control technology with reasonable co.st and nonair environmental
impacts was identified
for FCCU's, a short-term \arge.a~verse
air
impact would result

if:

(1) standards

more stringent

than

the

current

level of SO, control were not developed, (2) development of standards

was delayed,

and (3)

no standards

were developed.

Comment:

One commenter

determine current
correct,

EPA should

emissions

is

levels

factor

factor

will

Model plants

test

current

generated

FCCU operations

FCCU's that

will

Thus, model plants

the

FCCU's that

based

not

are

but instead

to these

sulfur

based on the

of older

use of

reflect

represent

SO, standards

to this

predict

and recon-

in this way do not necessarily

be subject

on a composite

FCCU SO,

presented in the proposal

provide a more reasonable

will

nationwide
and does

is

emissions.

based on feed

emissions

or emissions

be subject

data

were developed

model plant

is used to

model plant

be from new, modified,

the feed sulfur-SO, emissions correlation

BID. Model plants

factor

If the factor

to estimate

emission

SO, emissions

and throughputs;

an emission

used by EPA to determine

on actual

FCCU's.

that

FCCUSO,.emissions.

use this

based

what potential

stated

nationwide

Response:
The emission

structed

(IV-D-16)

over

estimate

standard

than

those
the

next

of emissions
an emission

newer
5 years.

from
factor

FCCU's.

Comment:

One commenter
uncontrolled

(IV-K-2)

emissions

6,000 Mg/yr and that

between

400 and

1,200

questioned

from a typical

controlled

the

FCCU are

emissions

Mg/yr.

4-15

source

of EPAls claim

between

from a typical

2,000

and

FCC~ are

that

Response:
The uncontrolled
represent

Regulatory

emissions

estimates

Alternative

referred

I (Baseline)

to in the comment

for model FCCU units

with

a throughput capacity of 2,500 and 8,000 m3/day, respectively, with a

fresh feed sulfur content of 1.5 percent,
this feed sulfur content would be typical

The Agency estimates that

of FCCUls subject to the

standard,
Emissions were calculated on the basis of 1,400 vppm for
feed sulfur content of 1.5 weight percent.
This vppm estimate is consistent with actual data from pilot and commercial FCCU's, shown in
Figure

3-6 of the proposal

BID.

The controlled

emission

estimates

of

400 Mg/yr and 1,200 Mg/yr represent control in the 2,500 m3/day and

8,000m3/day
regenerator,
respectively,
to 9.8 kg50,/1000
kgcokeL~_S
burn-off.

This level

can be met by SOx reduction

catalysts

being

used at facilities with a fresh feed sulfur content of 1.5 percent. If

scrubbers
typical

are

used,

lower

controlled

emissions

FCCU.

would

occur

at

this
-4

4-16

5.0

5.1

SCRUBBER

COSTS AND ECONOMIC IMPACTS COMMENTS

COSTS

Comment:

Five
stated

commenters

the

opinion

BID are

unrealistic

claimed

that

higher.

(IV-D-5,
that

IV-D-6,

the

scrubber

and are

the

scrubber

The reasons

1V-D-9,
costs

significantly

cost

cited

presented

and

IV-D-20)

in the

proposal

underestimated.

estimates

by the

IV-D-1O,

should

be

commentersfor

The commenters

2.2

the

to

7 times

low cost

estimates

are:

(1)

The EPA based the cost analysis

FCCU exhaust
volumes,
scrubber
off site

(2)

There
FCCU's
at

The EPA did

discharge

not

factors
different

cost

can cause
refineries.

dual

alkali

considerable

FGD systems

at

any

in

of the

systems might be
or wastewater

restricted.

of retrofit

installations.

The EPA did notconsider

a cost for business
that
would result
from a scrubber
malfunction
the

(6)

is

variation

The EPAshould include separate costs to account for the difficulty

(5)

for

The EPA did not consider

site
space availability
and soil
conditions,
FCCU turnaround
schedule,
equipment
availability,
startup
costs,
or climate
when preparing
the capital
costs

model units,
although
use of dual alkali
required
in areas where water availability

(4)

assumptions
costs,
and

costs.

estimates.
cost
of

(3)

on erroneous
waste disposal

It

interruption
shutting

down

FCCU.

is not appropriate

costs

from the

FCCU with

for

scrubber

an ESP if

modification

or

EPA to subtract

costs

scrubbers

in the

are

case

required

a credit

for

ESP

of an existing

as a result

of

reconstruction.

Response:
To respond
detailed
to perform

proposal
commenters
specific

cost

to these
data

a general

BID.

single

addressed

EPA decided

alkali

reevaluation

Concurrently,

and then
cost

for

comments,

scrubbers

of the

EPA solicited
the

individual

items.

5-1

cost

first

to solicit

from vendors
data

presented

supplementa~

cost

comments-pertaining

more

and then
in

data

the

from
to

A.

General

vendors

other

BID cost

Cost

than

Review.

EPA solicited

Exxon; Exxon provided

estimates

were

from two other

First,

based.

scrubber

The

vendors,

the costs

EPA received

scrubber

Elements
in

has

Corporation

insta~lation

with

actually
has,

of

tion

refinery

scrubbers

to

The analysis
that

the

industrial

of these
costs

provided

to FCCU's, were the

estimates

and are

conservative

serve

to

other

provide

the

companies

believe

the

Exxon

system

the

American

pumps,

not

is

designed

tory

linings

to

catalyst

fines

requires

sparing

by the

multiple

venturi

as specified

to maintain
of

the

FCCU's

B.
specific

safe
the

by the

scrubbers

the

for

flue

scrubber

from

gas.

than

operation

for

cases,

and

operation

In particular,
design

coded

American

provided
vessels

the

a single

Fluid
about

cost

data
larger
refrac-

abrasive

effects

the

Exxon design

cracking

nonstop,
their

periods

and

throat

catalytic

Exxon designs

of

analyzers,

3 years

for time

Petroleum

are

variable

by

of

special

and critical

vendors.

that

petroleum

and use

Further,

equipment

other

that

companies,
shell

equipment

vessel

by the

cost

specifica-

(ASME) and design

coded

Exxon

rather

design
that

LI

alkali

vendor

industry.

two vendors

steel

and reliable

comments

reliability

call

other'two

in.some

Review of Specific
cost

and applica-

of single

of all

refining

design.

venturis,

lo~ger

familiar

FCCU's.

vendor

Engineers

other

rotating

may be in continuous

significantly

in the

refinery

of all

the

equipment

the

in the

specifies

units

coded

protect

to

use of redundant

the

of Mechanical

such

not

highest

.specifications

one of the

specify

those

with

and electrical

(API);

than

use and the

necessary

design

but

Exxon

specifications.

due to more stringent

scrubber

Society

piping,

Institute
did

vendors

is

with the design

by Exxon,

applied

then

to

data (see Docket A-79-09, item IV-B-14)

scrubbers
tions

Environmental

therefore,

and equipment

boilers,

data

Corporation

a subcontractor
and,

experience

proposal

cost

Elements

as

scrubbers,

codes,

2000 has considerable

of

showed

Exxon

on which the

on an FCCU.

served

scrubber'

Exxon is the only company

installed

however,

several

FCCU operation,

Andersen

been

from

detailed

Environmental

(EEC) and Andersen 2000 (IV-D-32, IV-D-36).

whose

data

or

scrubbers

equal

to that

control.

Cost Comments.

provided

by companies.

5-2

Second, EPA considered

the

One commenter (IV-D-5)

because

of erroneous

information
the

concluded

FCCU's using

(see

the exhaust
HTR appear

coke

composition,

typical

levels

compared
were

found

model plant

amount

air.

exhaust

regenerator
for
not

During these
for

cost

FCCUls operating

flue

gas

the

capital

Docket A-79-09,
boilers

with jet
costs

item

must install

the
that

venturis

Fluid

the rlEV-type

would

in the

enter

a 3EV scrubber

CO boiler.

impact
the

scrubber

would be about

10 percent

an FCCU to a high-energy

IV-B-16).

This

in the

cost

Tables

A-5 through

revised

increased

of the

JEV

the

catalytic

that

the

that

Appendix

to

commenters

EPA used erroneous

EPA, therefore,

transport

This

solid

also

revised

units

(see

using

CO

presented

flue gas volume

air

gas.volume

required

to aJEV

than

the volume of gas from

(see

Docket

A-79-09,

in about

a 3 percent

previously

calculated.

this

(IV-D-5,

assumptions

reviewed

the

IV-D-6,

volume

for
waste

IV-D-9,

contain

and disposal
waste

disposal

waste

disposal

disposal

costs

used

of collected
cost

is

IV-D-IO)

scrubber

The cost values used in the proposal

the

the

on FCCU's

combustion

flue

volume resulted

A-7 in

gas volume

to include

cracking

of the

higher

over

and

gas

exhaust

The JEV costs

scrubber

JEV scrubber

the

item

increase
the

costs.

Several

BID.

venturi

were

analyses,

exhaust

installed

scrubber.

The EPA determined

and

and

for

As a result.,.,EPA

because

coke,

to industry

in the proposal BJD did not account for the additional

that

the

used

(JEV's)

3EV scrubbers

IV-B-16).

between

conditions.

CO boiler.
for

FCCU exhaust

gas volumes

values

EPA revised

ejector

from the

and annual

the

of actual

for

for FCCU regenerators

by SPA indicating

evaluations,

contribution

exhaust

to beginning

representative

analysis

to burn

gas volumes were sent

prior

The EPA

relationships

necessary

Furthermor,

review

and EPA

the cost

Model plant

volumes reported

exhaust

no comments were received

were

used for

of air

Additional

item IV-B-4).

The calculated

be reasonable.

representatives
volumes

Docket A-79-09,

in part,

volumes.

commenter,

based on stoichiometric

of excess

to

gas

from the

to be appropriate.

the

to actual

were low,

of FCCU exhaust

gas volumes

gas volumes were developed

the

EPAlscosts

and received

information

that

that

assumptions

was requested

reviewed

stated

catalyst

t~ased only

5-3

BID represent
fines

on the

in

stated

that

costs.
the

The

proposal

the cost for

in a landfill.

additional

mass

of

solid

wastes

collection

to

be disposed

device instead

In the proposal

treated

liquid

the

use

of a wet

of an ESP (see Section

BID, no costs

were credited

it is appropriate
disposal

to surface

water.

by assuming

that

as the

4.3 of this

document).

Upon review,
all

of the

the treated

to provide a more conservative

costs

scrubber

to the disposal

waster because EPA assumed that

wasteS were disposed

waste

due to

liquid

EPA decided

that

estimate of liquid

affected

facilities

would

discharge to sewers.
Some refiners,
especially
in coastal locations,
will likely be able to discharge the treated scrubber liquid wastes to
surface

waters

without

incurring

a sewer discharge

cost.

Two commenters (IV-D-5 and IV-D-9) questioned

of off site costs,

that

site

The EPA has considered

soil conditions,

turnaround

and startup

in the

water,

protection,

fire

The scrubber

refer

within
to that

process

unit

available

limits,
cost

costs

costs

estimates.
steam,

and its

equipment

will

in this

of the

refinery

include

air,

climate,

electricity,
utilities.

impacts

include

FCCU. The battery

associated

the

a 20-percent

contingency

turnaround
startup,
and

a particular
not

the FCCUbattery

than that

assumed in the

is

that

provided

the

site

expense

therefore,

in

site-specific

schedules,

and the

have,

are

within

contingency

The EPA considers

are

limits

Where utilities

incur a cost greater

climate,

with

isavai-lable

space

and

of off sites

been

considered

by EPA.
In support

space

and equipment

requirements,
retrofit

of

their

comments

availability,

one commenter

installation

and SO, emissions

on costs

provided

of a sodium scrubber
from an FCCU at

of construction

and pond and treatment

(IV-D-10)

an existing
5-4

' I:i

for offsites,

and other

cost

equipment.

conditions,

availability,

included

limits

estimate.

to soil

costs

equipment availability,
Off sites

capacity

However,

cost

related

specific

compressed

supporting

the refiner

soil

to the scrubber provided the utilities

of the

or insufficient

each capital

are

portion

variability,

up costs, or construction

used by EPA:to evaluate

the battery

estimates.

costs

or equipment

including

schedule,

cost of connecting utilities

located

space

FC~Uturnaround schedule, start

cli mate .

EPA's assumptions

Twoother commenters(JV-D-6and IV-D-10)stated

EPA did not consider

conditions,

., j

capital

to control
refinery.

climate,

system
costs

for the

both particulate
The single

'~

alkali

scrubber

is

sized

for

a flue

gas

volumetric.flow

rate

similar

to

the 8,000 m3/sd model plant used by EPAin developing costs.

A compar-

ison

estimate

of

shows

the

that

commenter's
the

total

The commenter
compared

to

adjustment,
construction

climate.

and believes

that

in this

these

response).

cost

estimate

is

cost

estimate

for

on an existing

project

estimate
for

tions
tive

the

the commenter's
EPA's

revised

scrubber

by a vendor.
stages

are

typically

installed

to the

This

a constru~F;tion

project

well

A factor-

cost

specifications
the

final

these

scrubber

the

with
costs

design

allowances
and construc-

cost

cost.of

experience
that

defined.

generous

actual

on a vendor's
of this

of cost

several

more defined,

and closer

cost

very

from a preliminary
type

of

in equipment

to FCCUls, and EPA believes

actual

not

contain

becomes

are based

of the

factors

of cost-factors

than

were developed

early

uncertainties

lower,

EPA's costs

costs

specifications
will

is

and

for by EPA's

dollars,

alkali

cost

cost

accounted

higher

single

provided

in

As a project

normally

commenter's

costs

also

allowance,

the discussion

50 percent

scrubber

estimate

when the

tion.

design

same.

indirect

The cor~menter

to equivalent

a comparably-sized

for

the

27-percent

the

(see

about

FCCU.

cost

account

factor

approximately

is developed

to

by EPA.

cost

is

account

are adequately

When adjusted

estimate

type

to

EPA evaluated

cost

The commenter's
factor-type

estimates

productivity,

factors

contingency

revised

an additional

labor

The

both

used

estimate

included

EPA's

factor

factor

cost

with

for

a 60-percent

base

which

20 percent

cost

40-percent

this

estimate

direct

applied

to the

applied

cost

estimate
project.

scrubber

The

app~ica-

are more representa-

than

the

cost

estimate

provided by the commenter. Thus, the differencebetween the cor~menter's

cost

estimate

and EPA's

of

commenter's

nature

the

revised
cost

One commenter (TV-D-20)

more appropriately
because
water

single

than

parts,

alkali

cost

data

single

alkali

indicated

the

"front

systems

to show that
half"

largely

due

that

to the

EPA's cost

use of dual

alkali

may not be applicable

or wastewater
systems.

is

preliminary

estimate.

be based on the

availability

provided

costs

discharge
dual

A dual

and the

alkali
alkali

"back half."
5-5

estimates
FGD systems,

in areas

is restricted.
systems
scrubber

should

where
The con~snenter

are more expensive

consists

The front

half

of two

of a dual

alkali

scrubber

resembles

a single

alkali

scrubber

without

a wastewater

treatment unit and performs the same function--removing SOx from a gas
stream by contacting it with a caustic or soda ash scrubbing liquor.
In the back half of a dual alkali scrubber, however, the purge is
treated

to regenerate

scrubber

the

simply treats

The EPA agrees

is not permitted,

to single
calcium
water,

that,

alkali

sludge

but disagrees

discharge

scrubbers

would be a viable

alkali

alkali

produce a

disposed

scrubbing

wastewater

alternative

scrubbers

would be more readily

dual

a single

of scrubber

because dual alkali

that
that

for reuse;

the purged liquor.

where direct

scrubbers

sulfate

liquor

and discharges

dual

alkali

scrubbing

systems

than

waste-.

would be more

expensive than si'ngle alkali.

The commenter

EPA's proposed
estimates

compared

single

by the

scrubber

commenter's

in the proposal

commenter

to estimate

for

actual

alkali

gas flow rates

scrubbers

The comrmenter's
cost

tion

these

of

dual

alkali

(see

Docket A-79-09,

systems
single
half

alkali
of

differences
costs

cost

model was used by the

costs

alkali

assuming

scrubber

and sulfur

scrubber

both

sizes

Corporation

of

provided

scrubber.

Also,

them

independent

by an

existed,

based

90 percent.

costs

loading.

are a func-

The commenters

costs
a dual

EPA performed

on.data

item

from.vendors

IV-B-15).

back-half

Exxon provided
vendor

for

EPA with
of dual

costs

Exxon's
for the

Environmental

both

sizes

a cost

alkali

estimate

front

Elements

of dual

scrubbers

evalua-

dualalkali..

Speci fically,

scrubber.

costs

higher than

a further
of

were used to develop

alkali

cost

information

cost estimates for dual alkali scrubbing were significantly

EPA's proposal estimates for all dual alkali model units.
Because

to

For each of the model plants

scrubber
dual

alkali

scrubber

BID, a computer

dual

dual

costs.

contractors.

Thecommenter'-s

tion of volumetric

costs

on proprietary

presented

SO, reduction.

capital

alkali

were based

provided

L~

alkali

provided
for

the

to

back

half of a dual alkali scrubber applied to the 8000m3/sdFCCU

only.
The commenter's
would control

and EPA's costs

capital

cost

based on a scrubber

both FCCU particulate

The EPA's revised

are greater

are

than

those

estimates

capital

that

and SO, emissions.

cost

estimates

in the proposal
for Exxon's

design

BID, but less

single
5-6

for dual

alkali

alkali

scrubbers

than Exxon's

scrubber.

This is

:I;

because

the back half

scrubbing
less

liquor

costly

purged

than

costs

dewatering

the

disposal

A comparison

remained significantly
on proprietary
scrubbers

actual

costs

commenter

plants,

total

alkali

believes.

applied

to

Therefore,
plants

it

model

systems.
for

the

scrubber

model plants,
the

alkali

are 93 percent
inappropriate
are

a function

capital

costs

cost

by vendors
scrubber

of nationwide

costs;

dual

only

use of dual

(IV-D-20)

also

alkali

cost

estimates

because,
of both

for single

whereas

gas

alkali

flow

systems
5-7

data

are

model

cost

estimates
costs.

of model

for single

single..alkali
for

cost

data

BID (see

single

EPA's revised

alkali

costs

for

The commenter's

alkali

for dual
and feed

alkali

for the low sulfur

The EPA believes

rate

the

represent

control

costs

single
costs

for

national

model plants.

capital

as

scrubbing,

costs

higher.than

costs.

sys-

more costly

in the proposal

to EPAls revised

alkali
waste

of this

assume that

was

alkali

are

alkali

cost

estimates

sulfur

alkali

of EPA's indivi-

estimates

ofS02

The commenter's

percent

cost

some facilities.

provided

but are significantly

of dual

at

an analysis

of dual

of dual

the

costs

alkali

costs

less,~costly

decrease

not to revise

alkali

provided

information

costs

alkali

would

those

commenter was not possible.

single

are similar

cost

sludge

is based

the use of only

1.5 and 3.5 weight

single

waste-

information

cost

item IV-B-24).

systems

cost

current

to single

Docket A-79-09,

for

total

EPA's

The EPA performed

comparison

the

dual alkali

ratherthan

plants

with

dual

costs

was decided

This commenter

alkali

costs
total

by the

alkali

Therefore,

to reflect

dual

be

system.

by Exxon

detailed

supplied

single

estimate
the

treat

alkali

and a comparison'

provided

scrubber

which reflect

a conservative

to

by contractors

commenter,

of data

that
dual

developed

commenter,

to those

The EPA's'analysis

total

data

to the

dual

than

alkali

the commenter's

cost

to EPA by the

indicates

dual

t~he commenter's

because

notprovided

tems

of the

higher than EPA's revised

and provided

capital

needed

to

facilities.

of EPA's revised

However,

was found

specified

cost

the purged

reuse,

from a single

ponds

the

for

system

discharge

than

commenter shows that

estimate.

it

treatment

in-ground

greater

scrubber,..whe~e

regenerate

before

for

are

and

to

alkali

wastewater

liquor

treatment

by the

treated

the

scrubbing

Construction
water

is

of the.dual

capital
this

approach

alkali

systems

sulfur

a function

costs

only

content,

of waste

is

gas flow rate.

the

reagent

Dual alkali

solution,

the

control requires equipment. to regenerate. cost

of which depends,

in part,

on the

.i:13

s'ulfur

content of the flue gas. Becausesingle alkali systemsdo not have

such equipment,
waste

single

alkali

gas flow rate.

by applying
sulfur

believes,

costs,

Therefore,

a constant

content

control
single

percentage

that

reevaluate

cost

alkali

The EPA reevaluated

these

The EPA

vary widely from one refinery

ration and the availability

Costs

that

alkali

associated

-..3

EPA needed

FCCU's with

to another-based

of land.

single

content, is doubtful.

existing

costs.

ii

for different

the accuracy of the cor~nenter's

of retrofitting

derived

estimates.

(IV-D-9 and IV-D-EO) stated

the cost

only of

estimates

costs

in erroneous

IJhich increase with feed sulfur

Two commenters

are a function

alkali

of dual

models would result

therefore,

costs

with

to

scrubbers.
retrofit

will

on the refinery

In some cases,

,4

space

configu-

limitations

around an existing FCCUmay result in relocating

utilities
and piping
runs, longer ducting runs, and other factors that may make scrubber
installations
more difficult
than at a new refinery.
Therefore, EPA
agrees

that

retrofit.

model plants.

capital
cost

(less

added

anticipated

to

three

shutting

interruption

down the

reliability
states

emissions
device

still
cost

be able
would

interruption

or unavoidable

be incurred.

One commenter

credit

has been properly

to operate
impact

inappropriately

are

the FCCU.
For

this

when revising
(IV-D-20)

operated

reason,
the

stated

during

3.2),

a period

a violation
the
not

i~:T

of

provided
During

refiner

would

interruption

include

a business

BID costs.

EPA subtracted

Llj

to 40 CFR 60

no business

of an existing
5-8

malfunction

and maintained.

EPA did

proposal
that

in the easer

limit

failure,

Therefore,

a cost

in Section

Provisions

not considered

scrubber

5 years.

have demonstrated

(discussed

of an emission

This

FCCU's

a scrubber

sodium scrubbers

in excess

the control

of a sudden

result.from

some

scrubber

EPA did not consider

of 95 percent

device

of the

over the next

The General

of a control

for

by one commenter.

.can occur.

malfunction
period

would

in excess

mal functions

that

that

FCCU. Although

factors

estimates

modified/reconstructed

standard

stated

that

cost

of 20 percent

seven

to~this

(IV-D-20)

dn the

was estimated

of the

to be subject

business

scrubber

costfactor

contingency)

One commenter
for

be included

A re.trofit

cost

was

should

an ESP cost

FCCU with an ESP in

place

if

scrubbers

reconstruction.
priate
the

ESP cost

cases.

credit

retrofit

C.

as a result

The EPA agrees

in these

which

are required

the

were

three

of costs

credit

BID costs

modified

or

is not appro-

were revised

or

to eliminate

reconstructed

FCCUls

in

included.

Summary of Cost Changes.

reevaluation

an ESP cost

The proposal

for

costs

that

of modification

and of the

As a result
review

of both the general

of specific

cost

comnents,

EPArevised the capital and annual cost estimates for FCCUscrubbers.

The following

changes

were adjusted

based on the data

revised

to

account

as a result
increased

for

to include

were

installed

costs

were

ESP cost

waste

for

of the

on modified
i ncl uded.

gas

air;

Costs

volume

discharges;
modified

or

then

further

the

are

of

the

document.

costs

BID costs
new cost

Changes

to increase

1984 dollars,

estimates

in cost

(fron

872 to 8117 million).

costs

to increase

adjusted

to

from proposal
Thus,

total

nationwide

after

the

annual

therefore,
are

not

cost

to

content
is

show that

of the

above

0.3

$45 million.

would
applicable,

need to
dual

alkali

all

dollars.

EPA concluded
2.2

to

7.

A of this

million);

capital

adjusted
from

nationwide

of

would

to

proposal

annual

per.year);
of 29 percent

8117 million,

facilities

a scrubber.

scrubbers

result

for the first

The fifth
feedstocks

could

assuming

feedstocks

year

nationwide

with

sulfur

feed sulfur
Where sodium

be used

in

5 years

processing

would be below the

5-9

1984

retrofit

nationwide

a total

standards

processing

scrubbers.

to

B36.6.million

percent.

install

which

63 percent

caused

that

per year).
the

weight
Units

percent

not

of

increased

standards

are used at

of 0.3-weight

sodium

costs

for

Appendix

caused

cost for SO, control

date

scrubbers

cost

contents

capital

effective

sulfur

in cost

(from %35.to

annual

estimates

in

a total

Changes

scrubbers

and

(from $72 to 893.6

(from 835 to 945 million

these

sodium-based

above

by 5 percent

1984 dollars,

FCCU's;

by a.factorof

as described

were

reconstructed

understated

increased

costs

cost analyses,

presented

costs

scrubber

for retrofit

adjusted

are

by 30 percent

capital

not

the

were

(4) a cost

FCCU's

and the specific

proposal

entering

for the three

reconstructed

were

costs

(3) waste disposal

was deleted
or

components

(2) JEV scrubber

After both the general

Results

with

flue

combustion

credit

of individual

received;

liquid

was added

and (5) the

(1) costs

increased

of CO boiler

installation

that

were made:

at

cutoff

and

scrubbers

a similar

5.2

SO, REDUCTIONCATALYSTSCOSTS

Comment:

Three commenters(IV-D-6, IV-D-9, and IV-D-2O)wrote that the SO,

reduction

catalyst

technology

requires

a capital

outlay.

(IV-0-6 and IV-D-9) stated that because the catalysts

in units

with HTR, older

units

subject

Two commenters

can only be used

to the modification

or reconstruc-

tion provisions that do not or cannot operate in this mode will be

required to convert or modify their units.
This
conversion
could
cost
from $10-20 million

per FCCU. The third

commenter (IV-D-20) stated

that

althoughit maybe true that -the use of SO,reductioncatalysts would

require

little

outlay

for capital

equipment,

two exceptions

-~

would be:

(1) a smal~~,cefinery that does not have a sulfur recovery unit, and

-7

(2) a refinery with inadequate sulfur recovery unit capacity to handle

,I

the increased sulfur load due to the SO, reduction catalyst technology.
In either case, a capital expenditure would be necessary.
Two of the

commenters(IV-D-6 and IV-D-9) also stated that annual costs for SO,
reduction

catalysts

will

likely

be at

least

2 times

higher

than

EPA's

estimate.

Response:
Many refiners

have modified their

regeneration

tion (e.g.,
throughput).

reduced SO, emissions, improved yields, and increased

It is unlikely that an older FCCUwould become jubject

standards

advantages

FCCU's to HTR. High

temperature

these

offers

older

over conventional

through the modification/reconstruction

without modifying the unit to HTR.. A.refiner

reduction catalysts
in an FCCUmodified
solely to use SO, reduction catalysts.
standa~s
likely

cannot
to select

capital

utilize

SO, reduction

another

control

reyenera-

to

provisions

is more likely.to

use SO,.

for HTRthan modify an FCCU

If an FCCUsubject to these
catalysts,

techniquethan

the refiner
incur

is more

a 810-20 million

expenditure.

Use of SO, reduction

refinery

fuel

gas,

catalysts

will

increase

which is removed from the

the amount of H2S in

fuel

gas in a sulfur

recovery unit.
The increase in the amount of H2S to a sulfur recovery
unit is only about 5 to 10 percent.
Sulfur recovery units generally
are

overdesigned

in H2S production

by much more than

from refinery

this

process
5-10

to account

for swings or surges

units.

is doubtful

It

that

the

use of SO, reduction

un i t.

The EPA does agree,

unit

capacity

not

catalysts

the

standards

are

tion

would

reasonableness

of

to obtain

catalysts.

a sulfur

in certain

need

to

cases

be added.

standards,

These

demonstrated

developers

reported

recovery

factors
since

do

the

technology.

or licensing

for commercially

recovery

sulfur

however,

developing

costs

Catalyst

that

as best

companies

current

would overload

the

based on scrubbers

The EPA contacted

catalysts

however,

or a new unit

affect

alone

SO, reduction

available

costs

for

SO, reduc-

the

technology

ranging from $0.60 to g1.60/m3 of fresh feed processed; The fifth year
cost

for SO, reduction

cost

factors

annual

catalysts

.provided

throughput

containing

by the

for

greater

all

than

cost for SO, reduction

Costs

is

under

a newer catalyst
the

cost

to

catalyst

affected
0.30

as the

by,multiplying

by the

total

processing

percent

sulfur.

are presented
the

fifth

year

The new fifth

year

to 850 million.

as a range because

The upper

end

developer

of this

catalyst

the

feedstocks

ranges from 820 million

development.

decrease

developers

weight

catalyst

formulation;

calculated

facilities

catalysts

for SOx reduction

technology

was then

of the

formulation

is

range

the

represents

catalyst

expects

produced

in

greater

quantities.
5.3

ECONOMIC

IMPACT

ANALYSIS

Comment:

Several
IV-D-20)

stated

on the

control

some cases,
economic
new

point

device

ZV-D-1O)

Executive

prices

to the

(IV-D-3,

will

and the

wrote

postpone

impact

not

that

nation's
the
the

economy.
wrote

that

attractiveness

additional
costs

have

cost
Three

of

new investments

the

5-11

(IV-0-15)

Impac~
wrote

of FCCU modifica-

commenters

or other

(TV-D-3,

standards

of FCCU operation

FCCU's.

affect

costs

of a Regulatory

of a scrubber

proposed

and

an adverse

the compliance

and would cause

on the profitability

IV-D-15,

Four commenters

One conunenter

be feasible.
the

IV-D-10,

would

preparation

Order 12291.
reduce

IV-D-9,

standards

and IV-D-20)

where the

would

IV-D-6,

proposed

high to require

under

current

tions

of

IV-0-15,

sufficiently

that

the

industry

IV-D-9,

Analysis

and

that

refining

(IV-D-6,
are

commenters

would,

SO,

IV-D-9,
in

a significant
and construction

Response:
The cost.analysis
Executive
Since

Order

that

upward.
these

presented

in the proposal

12291 by the Office

time,

in response

This latest

revisions,

of Management and Budyet

to comments,

cost revision

the

fifthyear

EPA has revised

is presented

nationwide

BID were all

Order 12291.

less

than

The price

0.4 percent.

(OMB).
costs

in Appendix A.

With

costs

a regulatory

are still

impact analysis

increasesublished

Using the

under

these

annualized

below the 8100 million level that triggers

under Executive

SID was reviewed

revised

~9

in the proposal
control

costs

and

second quarter 1984 product prices, that figure increases to approximately

0.8 percent for.the worst case considered (3.5 weight percent sulfur
feedstock).

The EPAstill

The capital

"
i4

considers this to be acceptable.

required

for

the

control

devices

will

increase

the

investmentfor a newFCCU
by 9 percent for the 8,000m3/sdunit and by
15 percentfor
percentages

that

the 2,500 m3/sd unit.

sufficiently

is otherwise

high

to

economically

The EPAdoes not consider these

deter

a decision

to

install

an FCCU

justified.

Comment:

One commenter
classified

as small

BID that due'to

little

('IV-D-16)

percentage

the discontinuance

the

level

is anticipated

of

small

refining

of concern.

to mean insignificant
should

be exempt

an exemption

businessesbecause

construction

the

suggested

for

EPA had stated

that

refineries

in the

of the entitlements
at small
businesses

The commenter
emissions

for

program, very

refineries.
affected

Therefore,
will

be well

seemed to.interpret

and suggested

that

proposal

this

small

below

statement

refineries

reason.

Response:
The EPA does
refineries

to

not consider

the potential

be insignificant,

Scaling

emissions

from small

down emissions

from

EPA's

model FCCUsizes to a unit of the size discussed below (950 m3/sd)

indicates

greater
refineries

that,

than

currently

with

100 Mg SO,/yr.

because

A recent

that

even

of

feedstock,

Therefore,

insignificant

investigation

operate

a low sulfur

has

emissions

would

be

EPA would not exempt small

emissions.
revealed

FCCU's are classified

that

14 of the

as small

116 refineries

refiners,

i.e.,

less than 1500 employees and less than 8000 m3/sd crude oil refinery
5-12

-3

throughput.

The EPA guidelines

Analysis

should

be performed

business

sector

will

The EPA continues

require

believe

20 per'cent

asignificant

adverse

that,

due

entitlements

program,

very

refineries.

However,

EPA examined

would

have

on

small

impact,

Annual Refining

percentile

little

to the

of the small
economic

discontinuance

construction

the

Flexibility

is

impact

impact.
of the

anticipated

that'the

at

small

regulations

business.

To examinethat

Journal

a Regulatory

if more than

experience

to

that

throughput

EPA selected

Survey,the:
of

the

from

the

1984 Oil

FCCU representing.the

population

of currently

and Gas

low 20th
operating

small

refineries,
~nich was an 950 m3/sd FCCUin a 1,350 m3/sd refinery.
To approximate`the impact on revenue and production costs, EPAused the
control

costs'

in Appendix

BID scaled

down to

19 percent

drop in product

sales

revenue

the

A and the

refinery

amounted

to

revenues

size

with

prices.
less

on page
revenues

one

and

of the

reduced

The compliance

than

9-34

cost

one-half

to

proposal.

reflect

as a percent

of

percent.

The

sdmewas true of compliance costs as a percent of' production cpsts.

install
tional
not

an FCCU of
15 percent

expect

Therefore,

any

on

unit

to

size

provide

small

EPA does

and smallrefiners.

this

under
scrubber

refineries
not
is

feel

these

to
that

standards

controls.
close

the

as

to

size.

5-i 3

cost

Furthermore,
a result

differential

significantenough

would

justify

an ad'diEPA does

of this
impact

To

action.

between

an exemption

large
based

6.0

6.1

COMPLIANCE

TESTING

AND MONITORING

COMMENTS

GENERAL

Comment:

One commenter

proposed standards
CO incinerator

(JV-D-11)

states

while

pointed

that

SO, testing

velocity

and

for

metric

SO, concentration

flow

correct

rate."

the preamble
flow

rates

The regulation

"shall

be the

The commenter

believed

to the

is conducted upstream of the

volumetric

downstream of the CO incinerator.

ling

out that

are

determined

indicates

that samp-

same as for determining

the

regulation

volu-

statement

is

Response:
The EPA agrees
at

the

with

same location

specified

in

the

the

as the

commenter;

SO, testing

volumetric

flow

rate

pointed

out that

should

be performed

measurement,

as is

regulation.

Comment:

One commenter
states

that

sampling

The commenter
manual

(650-7690C).
due

sample

should

stated

sampling

tical

(IV-D-20)

due

that

be conducted
it

to the

frequent

probe

unsafe

high

Additionally,
to

is

flue

upstream
to

gas

train

of the

require

operating

regulation
CO boiler.

personnel

temperatures

sainpl i ng at extreme

sampling

the proposed

at

to
this

temperatures
problems

conduct
location

is

and

imprac-

rapid

failures.

Response:
The EPA recognizes
Sampling
for

the

operator

the

either

upstream

standard

without

add-on

to test

downstream

chooses

calculation

procedures

SO, contribution

or

commenter's
downstream

to and approved

by the

addition,

the

location

downstream

of

th~

CO boiler

safety.

from the

CO boiler

is

for

However,

of the

du~ to the auxiliary

submitted
to

regarding

controls.

for determining

recommended

concern

the

CO boiler,

the

owner

rate

and the

fuel burned in the boiler

for

the

inlet

the

standard

prior

must be

to sampling.

GEMS has
with

or

alternative

coke burn-off

Administrator

6-1

if

acceptable

add-on

been

In

changed

controls.

Comment:

Seven

commenters

(IV-D-2,

and IV-D-20)

requested

standards

be

to

menters

to

(IV-D-P)
of

catalyst

(IV-D-3)

also

feed sulfur

lishment

IV-D-6,

performance

establishment

the spent

inclusion

determine

IV-D-3,

periodic

One cormnenter
the

used

(IV-D-2,

conducting

the

IV-D-S,

also

the

during

3-hour

the

compliance

value

test

IV-D-7,

IV-D-9,

to

(S):

feed

value (T) that

period

monitoring
or sulfur

Another

commenter

by theratio

suggested

sulfur

on

estab-

from the

of actual

feed

or

between

would be derived

(A) to the

suggested

sulfur

(IV-D-16)

com-

emissions.

of a relationship

One commenter

(C) multiplied

report

(weekly)

SO, emissions.

of

and IV-D-20)
excess

IV-D-16,

in the

A number

periodic
between

IV-D-9,

methods

determine

determination

of a trigger-level
test

emissions.

suggested

and coke sulfur.

compliance

excess

tests

and emitted

IV-D-7,

of alternative

a relationship

suggested

IV-D-6,

feed

during

i_g

sulfur

the

T = CA/S.

Response:
The standards
basis.
not

now require

The methods
reasonable

because

(vs.

excess

6.2

WITH

proposed

methods

they

do not

by the

to use

generate

emissions)
ADD-ON

compliance

to

be determined

commenters

for

on a daily

excess

for

determining

compliance

data

sufficiently

accurate

emissions

are

on a daily
for

basis

compliance

determinations.

CONTRO1

DEVICES

Comment:

One commenter
device

should

proposal,

the
used.

be given

which

operation

(JV-K-1)

would

of continuous

inlet

over

recent

highly

most

variable.

content
with

test

the

required

supported

compliance

The commenter

both

to be highly

an inlet

an operator

flexibility

monitoring

is expected

from using

have

that

to choose
using

of a GEMS in which both

The commenter

the

the

stated

this

an outlet

monitor

and outlet

by suggesting

that

not

test

if

stated

justify
the

feed

that,

variable,

the
to

where

the

monitor~to

control

between the original

an inlet

would

and outlet

of an add-on
only,

and

monitor

are

the

advantages

additional
the
the

operator

cost

FCCU is
feed

not

sulfur

may benefit

demonstrate

compliance

standard.

Another

commenter

for

standard

the

(IV-K-2)
for

add-on

stated
controls,

6-2

that,

during

the

a measurement

compliance
at

both

the

inlet

and the

the

outlet

proposed

provided

is

standards

needed.

However,

after

the

only need an "alerting

by an outlet

monitor

compliance

service,"

test,

which could

be

alone.

Response:
The standard
reduction

for

or 50 vppm, whichever

monitoring

for

compliance

on a daily

meet

this

status

intent,

tial

problems,

the

90 percent

the

the

of the

inlet

outlet

standard

the

source,

however, that

an inlet

the

compliance

determinations

on controls.

Thus,

or

standard

operators

for

to

determine

basis

controls

tion
change

their

"90 percent
a CEFtS is
as

well

as

choice

compliance

the

intent

to

determinations

would

be subject

to the

or 50 vppm, wt~ichever

is less

add-

the

control
that,

device
for

such

be made only on the

for

so they

for

S02 emissions
out

will

regard

the

recognites,

to meet

point

device.

at

compliance

so that

of the

control

maintained

Therefore,

regulation

by the

and

source

50 vppm standard

outlet

without

or the

outlet

wishes

variable,

The Agency

their

the

scrubber

an incorrect

the

declare

with

for maki~pgcontinuous

the

modified

only

S02 emissions

reduction
installed

to

The Agency

have both

constant.

to

by limitingtheir

a GEMS at

compliance.

being achieved

to

of compliance

standard.

in relation

To

compliance

is not "highly"

may stay

may lead

has

actual

to FCCU-operation

reduction

Agency

proposal.

the Agency to poten-

must

monitor is unnecessary

install

of the outlet

Agency

due

emissions

percent

the

owners or operators,

alert

of

determine

revised

determination

performance

may choose

add-on

to 50 vppm and

simply

to

show the

Even where feed sulfur

outlet

for

owners

that

the

may vary

determination

is

in the

data

standard,

is 90 percent
The intent

controls

needs

scrubber

the

add-on

Agency

data.

controls

stringent.

make an accurate

while

only

for

less

as described

concentration

measuring

is

basis,

reduction

feed,

add-on

not data that

andto

and outlet

of the

FCCU's using

the

percent

reduc-

Such owners or operators

inlet

of

whole

standard

stringent,"
the

control

may
on

provided
device

outlet.

Comment:

Several
recommended
the

standard

to indicate

commenters
that
for

the

outlet

add-on

compliance

(IV-D-3,

IV-D-6,

IV-D-9,

CEM requirements

controls

(determine

because

excess
6-3

IV-D-11,

should
GEMS are

emissions).

and LV-D-16)

be eliminated
an

unsuitable

for
means

Three conanenters

(LV-D-3, IV-D-6, and IV-D-9) stated that a post-scrubber CEMSis

unsuitable to indicate scrubber performance due to large variations
in scrubber

inlet

SOx concentrations.

S02 concentration

established

expected to indicate

Therefore,

the

scrubber

during the performance test

compliance with the SO, emission

extended periods of operation.

ii

outlet

cannot be

standard

over

Three commenters(IV-D-6, IV-D-11, and

1V-D-16) cited that the outlet S02 concentration measured during the
performance test of the scrubber and used to define excess emissions is
relatively
meaningless since it would be very difficult
to determine a
" rep r es e nt a t i ve "~fe ed . Two commenters (IV-0-6 and IV-D-9) also stated
that

the outlet

SO2 concentration

level measured during the scrubber

performancetest could very likely correspondto a scrubber efficiency

better

than the standard

as there

exists

a strong

possibility

that

the

scrubber would be operating at a reduction efficienty greater than 90

percent during the performance test. One commenter(IV-D-6) noted that
using an S02 concentration
unsuitable

because

to indicate

scrubber

the method does not take

of the relationship
feedstocks

level

into

performance

accountthe

pq

--Y

is

variation

between S03 and SO2 over time and over the range of

to be used.

the outlet-monitor

Finally,

one commenter (IV-D-11) stated

that

approach cannot compensate for changes in flue gas

volume. The commenter recommendedthat an SO2 monitor upstream of the

scrubber

is necessary

to indicate

scrubber

performance.

Response:
At proposal,

affected

facilities

complying with the standard

for

add-on controls were required to maintain a continuous S02 monitor at

the

scrubber

trigger

outlet,

outlet

concentration

performance
test.
standard
ance

control

of the

'device.

controls.

or operators

established

based on a

during the initial

has been changed to require

percent

reduction.being

ThereforP,

the

regulation

daily

achieved

compli-

by the

has been revised

to

of a scrubber inlet and outlet S02 monitor for

who elect

to comply~with

(An ~owner or operator

vppm standard,

were determined

In the revised proposal, EPAproposedthat the

require the installation

owners

emissions

level

for add-on controls

determinations

add-on

and excess

as discussed

the

standard

who seeks to comply solely

in the

previous

6-4.

comment,

for

add-on

with the 50

is required

to

install

only an outlet

commenters

is

GEM.) Thus,

the

situation

described

stated

that

since

method

of determining

by the

eliminated.

Comment:

One commenter
only

triggers

(IV-D-16)

awareness,

the

specified

under 40 CFR 60.105(e)(3)(iii)

adjusting

to

an oxygen-free

basis

an excess

emission

excess

emissions

need not be precise,

is

report

and thus,

unnecessary.

Response:
The standards
basis,

rather

than

now requi`re

determination

determination

of excess

determinations

have

determinations

because

a source

is

in

a greater

need

the

former

compliance

for
are

while

the

of compliance,
emissions.

precision
used

latter

has

been

excess

determine

are

ness that a source may not be in compliance.

basis

Compliance

than

to

on a daily

used

emission

whether

to

or

trigger

Therefore,

not

aware-

the oxygen-free

retained.

Comment:

One commenter
achieves
the

greater

standard

GGG, 40 CFR Part

fluid

are

leaks.

dual

commenter

by an initial

as

"less

seal

systems

for

that

test,

this

quarterly

meeting
monitoring

referred

approach~in

include

system

to detect

be determined

monitoring

to
which

a barrier

requirements

compliance

device

compliance

The commenter

~OC monitoring
that

control

technologies

drastic"

an example

proposed

performance

an add-on
than

are reasonable.

exempt from monthly

This

because

controls,

60,

mechanical

that

in S02 emissions

add-on

for scrubbers

pumps with

felt

reductions

without

requirements
Subpart

(IV-K-9)

instead

of inlet

and out-

let SOx'concentration

using EPA Reference Method 6 or 6B, and continuous

monitoring

scrubber

gas

of wet gas

ratios,

ongoing

and

pressure

process

drop,

to

variables,

evaluate

such

scrubber

as

pH, liquid-to-

performance

in an

basis.

Response:
Monitoring

for the control

and testing

technique

moni to ri ng a nd t es t i ng .
techniques

has no bearing

monitoring

or testing

example

in Subpart

requirements

are

and to meet the

The relative
on the

GGG referred

intent

stringency

selection

requirement

chosen

by the

6-5

be appropriate

or goal

of the

of different

of the

for each control

to

to

commenter

control

most appropriate
technique.
is

not

The
appropriate.

For pumps without

control

technique;

how well

seals

dual

the

seals,

that

control

the

exemption
usetwo

is doing,

and repair

monitoring

but rather

it

control

for monthly leak detection

control

techniques.

is the control.

technique.

and repair

based on its

The purpose
on each control
of the

baris.

technique

suggested
status

In summary, the
requirements

for

commenter

are

for dual

seals

not give

was

technique.

is determining

the Agency must collect

data..

can be determined.

commenter may give

information

information

The

on the

opera-

from which the

be determined.

Agency has determined

scrubbers

compliance and that

does not have to

standards

Therefore,

but it does

can

these

the

is not a monitoring

to the control

from which compliance

by the

scrubber,

compliance

for

The dual

Therefore,

requirement

appropriateness

of monitoring

compliance on a daily
procedure

The testing

is the

is not to monitor

but a means by which an owner or operator

determined

tion

leak detection

monthly

for pumps are an alternative

"exemption"

the

is,

monthly

are

that

appropriate

the monitoring

for determining

continuous

the arguments and the proposed change offered

unfounded

to

support

a change.

by

Comment:

Several

commenters

(IV-D-2,

IV-0-3,

IV-D-20, IV-K-E, and IV-K-9) stated

unreliable

due to monitor

generation

of imprecise

intensive

operator

unreasonable

that

operational

maintenance

data,

excessive

This

of the

commenter

GEMS, stating

inlet

to maintain

commenter

and

ability
his

plugging

knowledge,

run 24 hrs/day
commenter

referred

to

analyzer

IV-K-2

of the

included

and span drift,

plu'gging,

the

also

and

full

month
gaps

GEMS data

6-6

of

give

accurate

monitoring

it
about

difficulties
showing

an outlet

is very

gas stream.

concerns

Commenter

in the

be eliminated.

operability

expressed

and

for continuous

has shown that

potential

have

controls

in a saturated

analyzer.

not

to the

add-on

about

GEMS, stating

one

zero

noted

the requirement

FGD experience

the

EPA does
for

outlet

concerns

Commenter

of an inlet

particulate

and

utility

difficult

Problems

are

requirements.

expressed

that

IV-D-16,

S02 monitors

sample system

One commenter (IV-K-9) proposed that

monitoring

IV-D-7,

continuous

problems.

and inaccurate

attention,

IV-D-6,

This
the

oper-

due to

LV-K-2 stated
that

the

results.

that,
device

to
can

Th i s

by a GEMS in each

of

--7i

the

first

10 days

in Figure

Commenter IV-K-2 also

GEMS sample

C-l

asked

collecting

of the

BlD for

theproposed

how GEMSreliability

and

conditioning

standards.

was proven,

systems

were

used

and what

to

prove

GEMS

reliability.

Res ponse:
The EPA extensively
GEMS during

the

development

of 40 CFR 60.
systems

Current

provide

maintenance

obtain

in

the

rator

the

proposed

are

similar

dioxide

EPA has gathered

of

some of these

to

Appendix

assurance

F,

GEMS but
Procedure

procedures

The Agency

scrubber
reheat

has,

using inlet

II-A-18A).

flue

gas prior

to the

12 days.

Over

data.

occurred

time

testing
with

regard

60,

which

conducted

tests

rather

just

does

that

not

was on a saturated

monitor.

The duration

no difficulty

of the

saturated

nature

that

with careful

outlet

removal

quality

of the

outlet
flue

gas.

maintenance

monitors

on a saturated

difficulty

is difficult.)

6-7

without

in

was about
obtaining

analyzer
This

system
limited

of the monitors,

can be avoided.

the

item

in the flue

of the testing

problems

that

stream

was experienced

backflushing

directly

an Exxon wet gas

gas

There was no particulate

state

it

contains

S02 GEMS(see Docket A-)9-09,

overcome through adequate design and maintenance

commenter

to compare

at

time,

to

insufficient

history

example,

long te~m use and potential

stated

on the ope.cational

for

monitor

suggests

regenerators.

determinations.

inlet

the

acceptable

GEMSused for compliance

gas.

this

proven

on some FCCU catalyst

40 CFR Part

and outlet

regene-

generators;

for

Some regular

due to

to

were

as discussed

to FCCU catalyst

installed

data

steam

technology

information

the
i,

The outlet

of the

valid

been

is necessary

D, FCCU catalyst

of coal-fired

be applicable

and

Experience

Further,

Appendix

S02 monitoring
have

basis.

availability.

to those

operation

of manual attention

standards,

should

monitors

regenerators;

greater

monitoring

when proper

on a continuous

2 hrslday

continuous

Da, and Appendix

state-of-the-art

data

employed

or

the

steam generators

Sulfur

accurate

of S02 and diluent

D, Subpart

show that

approximately

exhausts

therefore,
for

are

an 85 percent

reliability

of Subpart

and

techniques

BID for

the

studies

precise

has shown that

to

studied

The difficulty
gas

stream

can be

of the GEMS. (The

cannot

be overcome,

but

The Agencydoes not agree'that particulate plugging will be a

"fatal"

problem.

In-stack

shields

and improved

filters

outside-stack

have been redesigned

with better

conditioning

have been

systems

developed that allow removal of the in-stack filter,

when necessary.

Furthermore,technologiesare available to circumventGEMS

plugging.
Properly

designed

prevent

systems usually

particulate

plugging

have back-purge

of the

sampling

capabilities

probe

to

in the stack.

Studies have also shown that high pressure (greater than 70 psi) air in
backflushing sample lines and~probes improves removal of particulate
and moisture from the in-stack probes and filters
both upstream and
downstream

of scrubbers.

Manufacturers

of the

systems

and installation

personnel would be responsible for designing each system for a specific

source.

Proper

design

along

should be able to prevent

owner or operator

will

with consistent

particulate

be able

and proper

maintenance

plugging to the extent

to obtain

the minimum data

that

an

requirements.

Based on these studies, EPAhas concluded that continuous S02

monitors

tained

are reliable

and accurate

when properly

(see Docket A-79-09, item IV-J-l),

the minimum requirements-for

Thus, the

promulgated

S02 moni to rs .
24 hrslday

retain

and main-

and are capable of meeting

determining

standards

operated

~%

compliance
the

with these

requirement

sta nda rd s.

for continuous

The EPA does not expect the GEMSto run nonstop for

for an entire

month.

The minimum data requirements(i.e,,

collection
of 18 valid hours of data per day for 22 days out of every
30) provide for downtime. This provides the owner or operator time to
maintain

and

calibrate

the

GEMS and

correct

minor

malfunctions.

Comment:

One commenter
"undeveloped"

(IV-K-2)

continuous

asked

emission

the proposed Section

60.106(e)(2)

control

and outlet

device inlet

why EPA bases

monitor.

the

NSPS on an

The commenter referred

which requires
to determine

to

S02 CEMS's at the

kg of SD2/hr values,

while

BID Appendix D, p. 0-13, says that the accuracy of a similar GEMSused

to calculate

kg of S02/kg of coke is unknown,

The "similar

is confusing

GEMS" referred

of the BID for

the proposed

the

reliability

to by the

commenter

standards,

p. 0-13,

6-8

Response:
The commenter

of two different
that

CEMSls.

is in Appendix

is a GEMSthat

is to

obtain

an estimate

latter

estimate

of both

requires

clearly

states

that

serious

questions

measurement

measurement
as to the

this

GEMS, ~hich

that

i s cons i dered

tries
require

standard

for FCCU's requires

or other

1981)
the

the

add-on

demonstrated

as specified

commenter
are

needs

that

control

and

of these

(see Docket

monitors

measurement

of

tries

the

to make is

standard

a format

for

the

add-on

in parts
to the

requires

the

02 or

02 or CO2 CEMS's
for

in this

evaluating

format

In summary, the
Continuous

reliability

and

the

are deemed

(46 FR 8352, January

inappropriate.

have

is

the

and diluent

specifications

item II-J-2).

that

Rather,

and outlet

Such

60.13

It

add-on

be measured

inlet

systems

in 40 CFR Part

available

burn-off.

of the SO2 and diluent

monitoring

A-79-09,

for

S02 emissions

performance

BID

kg of coke burn-off,

S02 emissions
device.

and the

estimate;

standards

of coke

The

introduces

resulting

the

burn-off.

12~ parameters

kg S02/1,000

However,

The reliability

acceptability
adequate

of the

of at most two parameters,

C02emissions.
been

accuracy

kg of.coke

many variables

by volume (vppm) at both the

measurement
has

10 to

of this

un rel i ab le .

do not

scrubber

of

to estimate

controls

per million

kg of S02 and 1,000

26,

comparison
emission

accuracy

to

meet

controls.

Comment:

One commenter
downtime
instead

that

(IV-K-3)

and maintenance,
of 22,

such

and 12 hrslday

they

1 year).

According

believe

much more severe

commenter,
service

added

that

more complex,

and the

of 18.

is reasonably

a GEMSplaced

because

of its

for

15 days

The commenter

performed

GEMSwould be expected

per

GEMS

month

stated

(installed

of a CO boi~e~

exposure

for

on one FCCU with

upstream

than thatseen

sampling

allowance

successful

is downstream

and a higher SO, concentration

The commenter

data

commerci'al- experience

The installation

to the

an increased

as requiring
instead

the company has limited

GEMS installation
than

recommended

a
less

and an ESP.

would be subject
to hot catalyst

to

fines

by a downstream analyzer.
by an upstream

GEMS would

be

to have a lower operating

factor.

Response:

In requiring
based

data

its

selection

the use of CEMS's for determining

of

18 hours

of data

out of 30 days on the minimum data

6-9

compliance,

EPA

in a 24-hour

day and 22 days

requirements

for compliance

of

determinations specified for utility boilers under Subpart Da of 40 CFR

Part 60. Under these standards, EPAconcluded that the required data
to be collectedprovided

sufficient

information

to characterize

emis-

sions, and that properly operated and maintained CEMS'swere capable of

meeting these requirements. The operating conditions at the upstream
GEMSat FCCU's are similar to those found at a Subpart Da boiler GEMS
prior

to the

flue

gas scrubber.

Comnent:

One commenter (IV-K2) asked whether EPAplanned to require an

approved manual emissiontest
twice an hour, 18 hours a day, at times
when the GEMSfails.
If a manual emission test is needed, this commenter

askedhowlong the revised Method8 takes to perform.

Resgonse:

No manual testing would be required when the GEMSfails provided

the facility meets the minimumdata requirements specified by EPA.
Minimumdata requirements were established to allow for periods when
CEMS's are

permitted

shut

down for

to be lost

requirements

correction

provide

various

reasons

but limit

beforesupplemental
time

amount of data

sampling is required.

for GEMSmaintenance

of minor malfunctions.

the

and calibration

Malfunctions

These
and

are not likely

to occur

every 30-day period. Thus, EPAexpects that most CEMS'sroutinely

will operate better than the minimumdata requirements and supplemental
sampling

will

be rarel.y

necessary

Many methods are available

or operator

sampling;each

owner

these minimum data

Control Plan required by Appendix F, Procedure i.

samplingscheme,

representing

for supplemental

would develop his approach to obt;lining

in the-quality
acceptable

to meet them.

at least

Any

such as Method 8, would have to obtain

18 hours of operation

daily.

data

Method 8 is unlikely

to be used, however, because it measures SO, when only S02 data need to
be obtained.

Methods 6 and 6B are more likely

to be used.

If Method 6

is used, the minimumsampling time is 20 minutes and the minimumsampling

volume' is 0.02 ~scm (0.71 dscf) for each sample. Samples are taken at
approximately ;_0-minute intervals.
Each sample represents a i-hour
average.
18 valid

To csLain on: valid day from supplemental

samples.

sample representing

Method 6B, if

used,

would also

a minimum of 18 hours.
6-10

sampling requires
have to collect

If a back-up monitor is

used

instead,

still

then

a minimum of

18 valid

hours

to

obtain

a valid

Method

6 nor

day is

required.

Comment:

One commenter

be usd

(ZV-K-2)

to supply

back-up

6 and 68 have sampling

tures

for

Method

pointed

data

the

neither

GEMSfails

because:

and poor reliability,

forbidden

when using

6A and 49 FR 9686

out that

that

when the

problems

above 1200C are

9684

believes

for

EPA has stated

that

method

6B).

at

(1) Methods

and (2j tempera-

either

Method

68 can

(see

49 FR

The commenter

least

1600C is needed

when

testing.

Response:
The commenter
may be used

data

to

8,

gather

requirements

temperature
which

without

is concerned
supplemental

for the

referred
is

used

to

by the

to

methods

these

possible
missing

poor

that

reliability

operator.

and are

Details

not

with

the commenter's

of the

operator

would be provided

Appendix

F,

Procedure

only

actual

minimum

The 160"0
when using

the

commenter's

standard

concern

been

concerns

addressed

in 49 FR 9684.

the

the

controls.

required

Method

for

about

FCCU's

Methods

tothe

procedure(s)

two methods

to

chosen

Control

sampling

changes

can supplement

means~~availabl~e

in the Quality

about

by the

These

means by which an owner or operator

data

to meet

for Method 8.

have

as reported

is

(6 and 68) that

to 1200C is irrel~vant

identified

The Agency believes

add-on

compliance

temperature

160"C probe temperature

methods

in order

for

Thus, the

probe

test

cor~Tienter

in dete~mining

6A and 6B limiting

and

data

standard

add-on controls.

problems

with the

the

made
are

occasional

owner

or

by the owner or

Planirequired

by

1.

Conanent:

One commenter
of the

control

of

GEMS data,

the

(IV-K-2)

device

The commenter

operator

from "bunching

taking

minimum

be calculated

rather

period.

suggested

than

felt

all

this

up" valid

measurements

that
using

the

of the

should

the 7-day average

valid

6-11

hours

daily
within

be done in order

GEMSdata

on "bad"

individual

days.

points

performance
the

averages
7-day

to prevent

an

on "good" days and

Response:
The deliberate
de'scribed

by the

actions

on the part of an owner or operator

commenter would clearly

be seen as an attempt

to

circumvent the standard and such circumvention is illegal,

prohibited
by the NSPS General Provisions in Subpart' A, Section 60.12 of 40 CFR
Part

60.

Further,

collect

the minimum data

18 valid

requirements

(i.e.,

hours out of every 24 hours) will

requirement

limit

to

the potential

.s

for showing a source to be in compliance when the source would actually

be out of compliance if bunching did not occur.

does not believe
for

determining

has retained

it

necessary

daily

the

to change

compliance

averaging

the method of averaging

when using

of all

Therefore, the Agency

valid

the

add-on

-;I

data

controls

and

hours.

Ijij

Comment:

One commenter
averaging

rolling

daily

that

percent

average

separately.

(IV-K-2)

suggested

reduction

rather

the time seriesmodel

the Agency require

when calculating

inlet

and outlet

in making this
was analyzed

and, through a sample calculation,

values

values

than averaging

The commenter,

reduction

that

that

provides

a more stringent

The Agency considered

both averaging

the

data

suggestion,

pointed

in terms

of percent

averaging

percent

emission

7-day
out

values

r~

emission

standard.

Response:
valuesand
the

averaging

7-day

rolling

inlet

and outlet

average.

daily

data

Calculating

percent

separately

a daily

reduction
when calculating

average

of hourly

percent r~ductions requires both monitors to be operating at the same

time

for

inlet
time
or

a minimum of 18 hrs/day

and outlet
that

either

monitors

are

data

separately

monitor

to obtain
allows

rolling

methodsdescribed

(see

calculation

is insufficient
the

opposite

day.

Averaging

more leeway

before

back-up

in the

measurements

ir3

needed.

calculated

analysis

a little

is not functioning

Further, the Agencyfound little

in the

a valid

r9

by the

7-day percent
commenter

Docket A-79-09,

provided

by the

as the

difference (less than 0.4 percent)

reduction

for

the

item IV-B-13).
commenter

to

Agency can easily

result.

6-12

data

value
used

using

in the

In addition,

show a I'more

construct

the

time

the

stringent"

two
series

example
standard

an example showing

_:5

In summary,

data

separately

does

so with

operators

the

Agency

believes

adequately
the

the

and accurately

potential

of cost

by decreasing

averaging

the

need

inlet

determines

savings
for

of

to

using

and outlet

compliance,

affected

back-up

owners

and
and

measurement

methods.

Comment:

Two commenters
reported

by EPA.

collecting

and

were

included

cost

of 840,000

D-l gives
asked

(IV-K-P and IV-K-9)

One commenter

conditioning
in the
in

a cost

whether

the

of the

preamble

the

Agency

updated

(IV-K-9)

mated

GEMS.

costs

(analyzer,

of

sampling
per

8175,000

per analyzer

816,000
stack

the

system.

the

This

for

for

monitoring
minated

commenter

additional

monitor

appears

the

because

inlet

of

the

sampling

the

proposed

of

the

proposal.

the

82,000

coot

8150,000

to

This commenter
to

be about

for an across-the-

that

the

to reflect
and

total

would be about

costs

stated

and

underesti-

that

system,

system

estimate

only

the

installation

requirement

and outlet~to~
cost

questioned

system and about

manpower

GEMS

original

costs)

system and about

that

the

estimated

also

felt

a reliable

the Agency substantially

maintenance

the

sample

(1981 dollars),

from

for an across-the-stack

and not

at

costs

the

of CEMS's

GEMS, as BID Table

to 880,000

an extractive

annual

costs

commenter

additional

commenter

analyzer

ensure

This

The second
the

commenter

felt

to

and installation

for an extractive

840,000
of

analyzer

estimated

the

the

This

system,

8100,000
also

GEMS.
for

the

asked whether

needed

of a GEMSas $59,000

The second commenter

the

(IV-K-2)

systems

price

questioned

for

add;on~control

of
cost

costs.

continuous
~devices

be eli-

revised

proposal

CEMS's.

Response:
The cost
notice

reflected

tin

February

for

the

additional

the

cost

of an extractive

analyzer

system

of 869,300

data

by contacting

(see

Docket

also

A-79-09,

for

item

IV-A-1).

an S02/diluent

installation

original

a revised

installation

1981 costs
fourth

and data

quarter
acquisi-

DAS).

attempted

and source

and

the

and obtained

the

the

analyzer

(including

without

recently

vendors

in

The Agency updated

(DAS); 846,200

The Agency

costs

GEMS reported

1981 dollars).

estimate

system

vendor

the

extractive

1984 cost

tion

of

to

obtain

ownersor
The study

extractive

updated

operators
found

system

GEMS cost

using

GEMS

"worst-case"

from 943,000

to

8100,000
costs

(1984 dollars).

for

longer

backflush
are

sample

systems,

generating

lines,

worst-case

costs

for

%180,000 (including
an extractive
815,400

data

reports.)

an S02/N0,/diluent

costs

i.ncluded

corrosion-resistant

and computer

emissions

far

(The worst-case

GEMS) ranged

an extractive

probes,

acquisition

Worst-case

systems

from 82,000

analyzer

to 886,000.

system,

costs

of

(which

to 980,000.

Total

would be from 845,000

"Best-case"

including

The commenter

probe
capable

installation

a DAS and installation).

analyzer

additional

installation,

provides

costs
ranged

an estimate

to
for

from

of about

8100,000

(analyzer, sampling system, and installation).

Taking out the cost of
a DAS (about 823,100) from the worst-case costs, the commenter's
estimate

falls

in the middle-to-upper

The Agency notes

analyzer,
case

that

its

when updated

costs

range

original

end of the worst-case

cost

estimate

to 1984 dollars,

reported

in the

still

updated

costs.

I~

for an extractive

falls

within

the worst-

study.

The across-the-stack cast estimate (840,460) obtained in February

1981 was for a complete

outlet

added a cost

for

of 820,000

cost,including

(February
dollars

a cost

a nd i ns tal la t i o n .

of about

costs

Best-case

without

condition

analyzer

(834,000

815,000

installation).

for the

Commenters

in the upper

The annual

proposal
the-stack

maintenance

BID Appendix
GEMS.

thecommenter's

range

estimate

896,000,

analyzer

plus

(analyzer,

GEMS

installation

estimated

cost

of 816,000

for
results

for

to 8153,000.
to 860,000

a DAS, plus
costs

sampling,

of the worst-case

costs

the

DAS,

more

with

to be 834,400

IV-K-9 estimated

D were 811,000

Updating

1984

Assuming a DAScost of 823,100, total

8150,000 to 8175,000 per analyzer

which falls

880,400

quarter

for an S02/diluent

were estimated

to 945,000

Total

for the analyzer,

a DAS would be from 822,900

costs

a DAS.

GEMSgathered

fromB44,000-to

ranging from 82,000 to 880,006.

worst-case

892,900

Agency

was, thus,

cost to fourth

vendor estimates

a DAS) to range

for

monitor

Data on across-the-stack

show worst-case

(including

outlet

Updating this
estimate

to which the

and 820,000

for the

1981 dollars).

system

installation

installation,

yields

recently

monitoring

either
is

of about

estimates.

Agency

in the

an extractive
an estimate

an extractive

8400 to

and installation),

vendor

by the

per

or across-

similar

to

system and is

more

conservative

than

the

commenter's

estimate

for

an across-the-stack

system.
6.3

WITHOUT ADD-ON CONTROL DEVICES

Comment:

Several
that

commenters

EPA had underestimated

commenter

(IV-Kd)

and analyze

daily

traversing

system

3-person
would

is

used,

estimated

for

checks,
crew

operation

would

in part,

that

analyzed

at 15 minutes

rates

to

that

daily

Method

for

the

8 sampling,

and analysis
management.

annual

would

that

cost

3 technicians

the
have

cost

commenter

8 to
did

"reasonable"

not yet

of effort

be
not

would

think

developed.

and implemented.

it

costs

an automatic
This

preparing

FCCU.

an automatic traversing

and

asked
the

are

to

claim

based,

also

in part,

based

traversing
noted

Commenter
system
that

reports

the

the

total
believes

cost

on

'(at 858,800/yr).
yearly

unknown?
the

costs

costs

The
to

on a traversing

asked the
cost

the

commenter

how EPA determined

costs

estimates

to be 8 hours

that

This

la~or

be about

for

and 1 professional

system.

commenter

would

12 hours

Method 8 and what the

traversiny

1V-K-6

hours

reasonable

are

each day and

labor

per

when
was

This commenter

daily

be required

The commenter

of revised
that

(IV-K-2)

"reasonable"

when the

an automatic

assumption

8184,000

the

used~'vendor

estimated

trains,
that

estimated

Commenter

IV-K-12

teach at B41,600/yr)

Another
commenter

Commenter

stated

would be required

estimated

which
of the

$250,000jyr.

a contractor,

and

a full-time

also

This commenter

using

manually.

crew,

1V-K-3

This

no automatic

require

commenter

charges.

apiece

be about

4 man-years

Method

labor

assumes

testing

to be about
samples

to collect

and maintenance

This

per sample.

estimate

and project

stack

One

9300,000/yr.

would

Commenter

sixteen

labor

is accomplished

repair,

cost

for

cost

sampling

etc.

This commenter

sampling

this

stated

Method 8 testing.

expense

testing

be necessary.

assumed,
hour

that

daily

analyses,

and IV-K-12)

would be about

testing,

and maintenance

$400,000/yr.

annual

but all

that

IV-K-6,

of daily

and 2 assistants)

be responsible

back-up

that

indicates

(supervisor

calibration

costs

Method 8 samples

specifically

The commenter

IV-K-4,

the

believes

commenter

of

(IV-K-3,

be

system

Agency to identify

would be if you did not

1V-K-3
can

adding

questioned

be readily
equipment

EPA's

developed
such

as

system will increase system complexity and that

6-15

problems with an automatic

significant

and

Another

testing

degrade

on-stream

commenter

requirement

mance of this

test

exists,

connmenter,

future

is

of the

stack

stated

that

the daily

out that

speculative

because

development

protocols

determination

no means of automated

it must be performed

and unfounded

testing

may be

manual stack

using EPA Method 8 for 80, emissions

pointing

system

system (such as binding)

factor.

(IV-K-4)

is premature,
to this

traversing

manually.

of an automatic
given

perfor-

Accordi ng

traversing

the technical

complexity

involved.

Response:
The standard

year.

requires

one 3-hour

sample

per day,

3~5 days per

As noted in the comment summary, one cor~menter states

explicitly

that they calculated their labor costs assuming no automatic traversing

system.

The Agency believes

assumption.

After

commenters

that

further

the

not be used for

assumption

evaluating

the

the

other

consideration,

commenters
the

contends that

Agency has revised

it

the

made the

EPA has agreed

of an automatic

and recommending

although the Agency still

instead,

that

traversing

daily

with

system

the
should

Method 8 testing,

is technologically

cost

same

estimate

feasible.

assuming

that

monorail
systemwill be instal;edat eachof the twosampling
pens
and that

the

a single

sampling

item

IV-B-12).

that

it

area

to protect

tions,

sampling

train

for

will

traversing

Although

be used,

and changing

not addressed

was appropriate
the

train

to also

sampler

by the

include

from

such as rain and snow. The capital

and enclosure

is estimated

estimated

cost

the

two sampling

using

trains,

is used,

(see

for

of

Docket A-79-09,
EPA decided

an enclosed

various

weather

sampling
condi-

With the

system,

we assumed

revised

assumptions,

only

one sampling

this

halves the number of samples to be analyzed to 365 (1 per day).

The EPA disagrees

would be devoted
sample

is

average

sampling,

required

of 8labor

each

to this
day.

hours

and perform

and moved from one port

with the commenters'

full-time

per

periodic

claim

stack

testing.

The Agency

believes

day to

prepare

maintenance
6-16

i4

When the Agency originally

traversing

one in each port.

train

ports

movement

cost of the monorail system

to be 820,000.
an automated

manual

commenters,

a cost

and equipment

with

the

that

to the

next;

i.l

3 or more people

Only one 3-hour

that

it

equipment,

on spare

would

take

conduct

equipment,

with

an
the

an
-

added

labor

for

analysis

of

is the same or similar

adjusted

for

the

each

This

strongly

Commenter
the

that

to prepare.

The Agency

of

sample

quarterly

is

equivalent

per

sample.

This

by Commenter

reports

estimate

to

less

than

the

12 hour

of

the

above

per

affected

1V-K-3.

would take

with

basis

cost

hours

points,

the

On the

annualized

1.3

assumed by Cornmenter 1V-K-6 and, when

disagrees

IV-K-6.

revised

to that

number

Agency estimated

about

about 50 hours

one

per

hour

day

is

per

day.

estimate

assumptions

facility

The

used

by

and revisions,

estimated

to

be

8120,000.
Comment:

Many commenters
and IV-K-8)
standard

tha't

stated

for

daily

that

FCCU's

testing

according

(IV-K-1,
daily

without

for

1V-K-3,

testing

should

add-on

was too costly

to one commenter

monitoring

IV-K-2,

scrubber

or

One commenter

(IV-K-3)

stated

which this
basis

type

to satisfy

stated

that,

in general,

be required
burden

compliance

if,

occurs.

in

the

FCCU's, as the
Commenter

costs

impose
are

IV-K-1

that

feed

states

the

hydrotreat

information
it,

of
option.

instance`

in

on a daily

same commenter also

should

not

an unreasonable
that

a disproportionate
that

especially,

performed

This

of obtaining
also

the

is being

independent-of:

stated

felt

he knew of no other

compliance

course

will

under

requirements.

direct

commenters

when compared to the costs

sampling

CorrPTienter IV-K-3

Method 8 testing

The

IV-K-6,

from the

and unduly burdensome,

testing

of non-routine

IV-K-5,

be deleted

controls.

(1V-K-4),

the

IV-K-4,

the

cost

hardship

cost
of'daily

on small

unitsize.
cost

of daily

Method

8 testing

could hamperimprovementsin SO, reduction catalyst developmentand

felt

that

burden

the

estimated

cost

on FCCU operators

cat al ysts

of 8130,000/yr

who choose

would

to develop

put

an onerous

and use SOx reduction

A third
significant

commenter

(lV-K-6)

and would affect

This commenter

noted

that

the

stated

that

profitability

the corporation

the

economic

impact

is

of FCCU operation.
operates

9 FCCU's and

claimed that they would have to spend approximately $3.6 millionlyr

conduct

daily

Method

8 testing.

6-17

to

Response:
The Agency

recognizes

inexpensive,

but that

has examined

various

the

standards.

to meet

the

testing

is

Agency
daily

is

be sure

the

just

that

Agency

the

control

8 is

cost.

determined
alternative

or

operator

not

The Agency

compliance

opt to use SO, reduction

has

owner

cost

costs

of

relative

options

costs

are

reasonable

requiring

with

catalysts

that

daily

Method

that

enables

the

i~s in compliance

or

eliminating

on a

will

economic

impact

reported

and

standards

large)

refiner
should

petroleum

of the

the

controls.

of

on small

facility

of other

a valid

is

needed

situations

basis
for

for

this

being

standard

FCCU's

The Agency believes

the

without

that
are

with

the

economic
add-on

impacts

to affect
6-18

notice

of the

costs

be

These

affected
which

FCCU's

of complying
will

of the

refined

controls,
for

to

land

reasonable.

projected

standard

the monitoring

unlikely

is

add-on

controls

and

if not all,

prices

impact

FCCU's with

potential

to the small

most,

by all

the

proposal

impact

price

compliance

of FOOD

refineries

original

in the

compliance
for

large

because

included

or "onerous,"

profitability

and

in the

resulting

standard

is "unreasonable"

The economic

assuming

than

Method B testing

not

What
etc.)

an affected

The Agencystudied

to be small

Therefore,
for

is

or the

findings

and the

the

various

monitoring,

lack

burden

affected.

standards

be capable

expensive

standard

the

(49 FR 2072).

with

more

add-on

be adversely

obtained

for

testing

is "significant,"

products

facilities

that

is expected

were

Daily

of the

one or the other.

standards

to

one method or another,

annual,

sampling

subject

compliance.

discussed

these

facilities

Similarly,the

requirement.

The Agency disagrees

operation

excluding

the

determining

investment

(capital,

unreasonable.

impact

affected

capital

total

for

for rejecting

for

meeting

in order to show daily

economic

basis

"non-routine"

this

methods

to all

of the

the

for

similar

results

various

not a basis

is whether

of compliance

cost

the

is not a valid

is relevant

daily

Method

to show daily

viable

compliance available

as the

the

available

only

with

not an unreasonable

that

the

testing

basis.

the standards

is

also

methods

currently

continuous

the

daily

For facilities

The relative

is

it

standards,

to

that

without
with

smaller

associated

SO, reduction

with
catalyst

I:i

development.

Even with the higher monitoring costs, SO, reduction

catalysts
are still
likely to be the least expensive route to meeting
the standard.
Thus, development on SO, reduction catalysts
will still
continue
these

as owners or operators

try to minimize their

costs

in meeting

standards.

The third commenter's estimate of B3.6million

assumes: (1) all 9
FCCU's will use SO, reduction catalysts
and (2) the cost per FCCUfor
daily

Method 8 testing

are highly

unlikely

is 8400,000
to occur

per FCCU. The Agency believes

because:

(1) we do not expect

both

all

FCCU's

(e.g., such as those with very high sulfur feed contents) to use SO,
reduction

catalysts

and (2) the commenter

overestimates

the

cost

of

dail~ Method8 testing (see response to the previous comment).

In conclusion,
testing
sive

the Agency believes

is reasonable

methods that

compliance
approval
Comment

the cost of daily Method 8

in order to ensure daily

allow

the

determinations
of the

that

compliance.

Agency to make equivalently

are encouraged

Less expen-

accurate

daily

and may be used subject

to the

Administrator.

One commenter (IV-K-4) stated that daily stack testing is an

unduly burdensome requirement and added that EPA has not provided a
sufficient

basis

stack testing.
using

to justify

such.an

According to this

either

Method

8 or

of frequency

and is

inequitable

options.

In

addition,

the

presented

to support

necessitate

Another
testing

using

The commenter

Method

to refiners

commenter

that

(1V-K-5)

Method 8 for
provided

the

opposed

reasons

runs counter

to the

tivity

of the

need for this

current

American

various

that

no

in terms

control.

data

have

been

would vary so widely

basis.

the

as the

effort

workforce.

6-19

daily

reduction

basis

for

his

manual
catalysts.
remarks:

(2) EPA has not adequately

requirement;

national

proposed

sulfur

(1) the approach is too labor-intensive;

demonstrated

as daily

manual stack testing

unreasonable

using

emissions

FCCU's using

three

6 is

remarked

on a daily

commenter

requirement

commenter, daily

a modified

a thesis

monitoring

extraordinary

and (3) the

requirement

to increase

the produc-

as to

Response:

These standards

require

an owner or operator

to determine

compli-

ance status on a daily basis.

For owners or operators using SO,
reduction catalysts
to meet the standards,
the Agency has thoughtfully
and thoroughly considered options by which daily compliance determinations could be made accurately and with certainty.
At this time, daily
testing

is the

goal.

only method that

the

Agency knows will

accomplish

The Agency has "minimired" the amount of required

one 3-hour

test

per day to help

reduce

the

labor

strongly

disagrees

that

the

frequency

but still

Thus, the Agency

of the testing

is either

unreasonable or inequitable,

as owners or operators subject to the

standard

or

for

add-on

controls

alsd required

to make daily

industry

example,

(for

for

low-sulfur

determinations.

content

feeds

are

Data has been submitted

see Docket A-79-09,

item

-"

sampling to

burden,

meet the goal of daily compliance determinations.

this

IV-K-8)

that

by

show wide

variation
in SO, emissions from FCCU's using SO, reduction catalysts.
Even if this variation does not vary "so widely," an FCCUoperating
right

at

the

emission

limit

may go above

small variation.

Thus, daily

The Agency points

out that

tion

catalysts

determination

testing

and

approval,

to change.

can

effort

see

labor

no merit

to

increase

perform
the

for ensuring
to

the

determined

the

the

a cleaner

comment

testing

productivity

of

that

cost

That the
to

runs

counter

the

American

the

cost

be reasonable.

Thus,

testing

the

Agency

and employment

to the
work

approach

runs counter to the

environment.
such

may

but the daily

The Agency has considered

Failure to makedaily compliance determinations

national

to

are appropriate.

to Method 8 testing

is unlikely

has

due

data on FCCU's using SO, reduc-

alternatives

is irrelevant.

limit

determinations

as additional

of compliance

daily

emission

and be used upon Administrator

is labor-intensive
of the

compliance

are generated,

become available

the

national

effort

of
to

force.

Comment:

One commenter(IV-Kd)
contractor

believed

manpower exists

that

to conduct

the

insufficient

qualified

Method 8 compliance

sampling.

Response:
The EPA assumed
the

Method

8 compliance

that

in-house
sampling.

personnel

would

The EPA believes

6-20

be used
there

to
is

conduct
sufficient

lead
on

time

to train

contractor

such

personnel

without

requiring

or solely

relying

manpower.

Comment:

One commenter

(1V-D-16)

stated

that

the

proposed

regulation

does

not supply sufficient

information (calculation procedures) under

Section

Methods and Procedures,"

60.106,

"Test

to determine

total

SO,

emissions.

Response:
The EPA agrees
been revised
specified

with

the commenter.

to indicate

in Reference

SO, emissions

that

Therefore,

modification

Method 8 will

the

to the

be required

regulation

calculation

has

procedures

to calculate

total

as SOE.

Comment:

One commenter
Table C-14 of the
proposal

(IV-0-16)
proposal

BID states,

for the

values

asked how S03 values

BID when Section

in reference

in Table

C-14,

to the

0.1.3.2

field

"S03 could

could

be presented

in

(page D-8) of the

tests

providing

not be determined

the

in the

data
field

Response:
The remaining

of the

proposal

were later

BID states

analyzed

The emission
"Sulfur

portion

that

statement

made

in Section

S03 and particulate

sulfate

in a laboratory

summaries

Trioxide"

of the

in Table

included

all

0.1.3.2

samples

by ion chromatographic

C-14 of

the

proposal

sulfates~'collected

analysis.

BJD labeled
in the

isopropanol

impinger which passed through a heated (1780C) filter.

This would
have included most of the sulfuric
acid mist, if any were present
(see

next

water

comment).

soluble

The emissions

probe

and

h~~~ed

all

determined by water leaching the probe wash residue ~iid filter

and

the

in the

included

as

of

collected

"Sulfates"

filter,

analysis

sulfates

labeled

leachate.

Comment:

One commenter
acid

mist

and

(IV-D-16)

sulfur

trioxide

asked
can

if
be

separate

values

for

sulfuric

determined.

Response:

The EPA knows of no practicable

valves

for

these

technique

two species.
6-21

to determine

separate

Comment:

Many commenters (IV-K-1, IV-K-3, IV-K-4, ZV~-K-5,IV-K-8, IV-K-10,

and 1V-K-12) suggested
demonstrating

alternatives

continuous

to daily

compliance.

Method 8 testing

The commenters

for

suggested

three

basic types of alternatives:

(1) the use of less frequent

testing,

for SO, until an SO3 GEMSis developed,

(2) periodic testing

Method 8

and (3) the use of continuous S02 monitors with periodic testing for

-"

SO3. One commenter (1V-K-8) stated, in general, that the daily application of Method 8 is cumbersome, and thus, the proposed rule should
contain

provisions

to allow

compli~ance based

on a broader

pointed out that:

Qermitteeto

spectrum

demonstrate

of options.

for flexibility

or operating

encourage better

with

strategy;

process

regard

testiny options and

to future

(2) more flexible

understanding

within

continuous

This commenter

(I) the proposed ru~e restricts

does not provide

monitoring

the

improvements

language

the regulated

in

would

community;

II

and (3) exclusion of such a provision would require that future changes
be made through

formal

rulemaking.

Less Frequent Method 8 Testing.

that

testing

for~continuous

as frequently
if

emission
tests

compliance

as proposed.

a week of daily

limit,

Method

then

on consecutive

commenter pointed

more frequently

One commenter (IV-K-10) seated

may not need to be performed

Thi~s commenter
8 testing

the testing

shows

suggested,
that

frequency

out that

the tests

than necessary

show that daily testing

feed or operational

no test

should

days once each quarter

for
is

over

be relaxed

or semi-annually,

are too expensive

and that

example,

a history

the

to seven
The

to be performed

of testing

by Method 8 is notnecessary

that

data may

if there are no

upsets.

Periodic SO, Testing Until SO, GEMSDeveloped. Two commenters

(IV-K-4 and IV-K-5) suggested-that
instead of 'daily Method 8 testing
EPA require annual stack testing
(IV-K-5) or quarterly.or
mo~nthly
stack

testing

asdetermined

on a case-by-case

SO, GEMShas been developed.

choice

recommendation

SO, monitc:

dnd develop

commenter provided

to annual

Conenter
testing)

performance

literature

(1V-K-4)

1V-K-5 suggested
that

standards

on an S02 monitor

should be able to monitor S03 also.

basis

EPA specify
for

until

las a second
a continuous

such a monitor.

that

This

they thought

The other commenter (IV-K-4) felt

~-22

less

frequent

experience

compliance

with

was sufficient

FCCU catalysts

from an FCCUthat
gradual

testing

indicates

can achieve

to allow

the

less

commenter (IV-K-1) simply stated

standard
FCCU

should

that

the proposed

frequent

be used until

because
changes

that

general

in emission

standards

compliance

their

rates

are sufficiently

testing.

Another

some alternative

a SO, GEMSis proven

to the SO,

to be practical

in

service.

SO~ Monitors with Periodic Method 8 Testing.

One commenter
(IV-K-3) suggested using an SO2 GEMSwith an "SOg multi~lier"
to determine daily
average

compli ance,

of periodic

with

(e.g.,

This commenter stated

sentative

feedstock

the multipl
biannual)

that

i er determined

measurements

the periodic

and operating

tests

using

could

conditions

from a rol ling

Method 8.

be run at repre-

to ensure

a fair

estimate

of the SO3 multiplier.

Another

commenter

determinations
periodic

are

comparisons

(IV-K-12)

required,

the

recommended,

compliance

use of an SO2 CEMS~in conjunction

of performance

This commenter made this

if daily

between the

suggestion

on the

basis

with

GEMSand Method 8.
of:

(1) their

belief

that S03/S02ratios are relatively constant and predictable, and that

the SO3 component of SO, is relatively
that

describe

the variability

and on which the

and scattered;
the

in the

requirement

insignificant;
ratio

for daily

FCCU regenerator

is operated

of SO3 to SO, in emissions,

testing

(3) maximum S03 emissions

(2) EPA's data

is based,

are most likely

in a complete

are

limited

to occur when

combustion

mode without

SO, reduction additive on the catalyst,

because, as the oxygen atmosphere
increases,
the conversion of S02 to S03 is favored, and SO3 will be
driven

to maximum concentrations

used to remove total

monitoring

at one of their

mode without

between

tion

sulfur;

sulfur

if SO, reduction
(4) a summary provided

FCCU's operating

reduction

additive

the GEMSand a wet chemistry

of only a few parts

per million

SO, emissions; and (5) additional

support

their

conclusion

that

using SO, reduction catalysts

amounts

additive

is not

by them of emission

in the complete

shows

method,

reasonably

good

regenerator

agreement

and shows an SO3 concentra-

-- less than 1 percent

FCCUtest

combustion

results
flue'gases

of total

provided by them
on units

not

but with COboilers contain negligible

of S03,
6-23

A third commenter(IV-K-8) proposed that the~fraction of S03 not

recorded

on the

SO.2 monitor

modified Method 6.

be determined

periodically

occurs

by a Method 8 or

This would be in addition to SO2 monitoring on a

continuous basis.
This commenter pointed out that
them indicates that approximately 10 to 20 percent
sulfur

I'

data provided by
of the flue gas

as SO3.

Response:
The Agency has considered

the alternatives

suggested

by the

comme
nte rs i The Agency agrees that any test should not be performed
more frequently than necessary and that a history of test data may
show that

daily testing

is unnecessary.

However, such a "history

:~~
i;i!

of

test data" does not exist at this time andwithoutsuchdata, the

Agency does not believe

any of the alternative

monitoring

or testing

schemessuggestedcan be implemented
at this time and ensure that
accurate

continuous

commenters

did

compliance

not provide

determinations

much data

are made.

to support

their

Further,

arguments,

the
and

available data showthat the SO3/SO,ratio. can be variable.

As noted

above,

one of the

commenters

provided

:II~

literature

on an

S02 monitor that they thought.should

be able to monitor SO3 also.
The
information and literature
provided were insufficient
for the Agency to
evaluate this potential for this particular
monitor.
The Agency has
examined other monitors
none of the

monitors

for their

examined

The Agency does agree

ability

to monitor SO,.

has proven

that

suitable.

many of these

alternatives

acceptable as more data on SO, reduction catalyst

are gene rat ed .

Therefore,

the standard

alternatives

supported

case basis.

Some of the criteria

ratio,

product

temperature),

catalyst

The development

explicitly

may be shown

use and SO, emissions

states

thdt

such

data may be approved on a case-bythat may be considered

feed variability,

operationdl variability

alternative,

by sufficient

To date,

frequency

of product

are the SOS/SO,

slate

changes,

in regenerator conditions (e.g., excess oxygen,

addition

of a successful

upon approval

schedules,
SO, monitor

by the

and FCCU operating

would also

Administrator,

conditions.

be an accepta~,~

to Method 8 testing.

In the meantime, however, ~the Agency has retained daily Method 8 testing
for determining compliance on a continuous basis for the FCCUwithout
add-on

control

standard.

6-24

?[.~

Comment:

Onecommenter(IV-K-6)states that the use of;ontinuous S02

monitors

will

without

provide

add-on

controls

Response:
As discussed
continues
tant

a means of determining
at

a more

in Section

to believe

that

2.2,

reasonable

cost

"Regulated

Pollutant,"

SO, is the

for FCCU's operating

without

do not measure

SO3, they

cannot

detenninations

when SOx reduction

compliance
than

Method

controls.

regulated

po~lu-

As SOE monitors

be used to provide

catalysts

8.

the Agency

most appropriate

add-on

for FCCU's

continuous

compliance

are being used.

Comment:

Two comme.nters (IV-D-6

emission
for

monitoring

requirement

FCCU's without

tions

add-on

are not a true

commenters

argued

considerably

should

controls

indication

that

unsuitable

that

for the

FCCU outlet

SO, emission

in subsequent
the

the continuous

be eliminated

of the

during

stated

because

variables

from those

concentrations

and IV-D-9)

S02 concentra-

rate.

The

operations

performance

test,

standard

can differ

making outlet

as a gauge of compliance.

Response:

As originally
reasonable

catalysts,

however,

that

determination

sions

(i.e.,

such an excess

of compliance

daily testing

Comment:

emission

does not provide

relevant
using

as the most

for FCCU's using

per 1,000 kg. of--coke- burn-off.

is no longer

daily

S02 monitoring

emissions

S02 concentration

of SO, emissions

concern,

excess

recognizing

on FCCU outlet

cation

EPA considered

means of determining

reduction
based

proposed,

SO,

level

a precise

indi-

This particular

as the

standard

now requires

direct

measurements

of SO, emis-

with Method 8).

I~

One commenter (IV-D-~) stated that since there will be catalyst

particles

in the

flue

Method 8 requires

gas to the

"the

absence

menter also pointed out that

for

outlet

(IV-K-2)

gases.

of other

this
the

whether

also

particu!ate

matter?"

asked in a later

revised

from particulates

commenter questioned

how can Method 8 be used as

The com-

problem could render Method 8 invalid

This commenter

how EPA knows that

to interference

scrubber,

propo2ed

Method 8 is not subject

as is Method 8.

testing

of revised
6-25

comment letter

In addition,

proposed

the

Method 8 has

been performed that shows no particulate

one tester,
reproducibility
by different
One commenter (IV-K-4) stated that

interference,
repeatability
by
testers,
precision, and accuracy.
EPA has failed to recognize

possible

with common practice

ulate

interfering

control

believes

refiners

of either

adjust

are likely

standard.

injection

associated

in the Method 8 stack

that

particulate

effects

particle

ammonia

using Methods 6 and 8.

that,
amine

interfering

effects

and quantify

methodology

the presence

could i nval idate the Method 8 test

changes

the

have been made in the

in the

_i

more developmental
interfering

EPA adopts

effects

a specific

test

purposes.

of "other

results.

regulation

particulate

Therefore,
to permit

matter"

appropriate

the

insertion

of a

heated filter
and probe in the sampling train, prior to the impingers.
The heated probe and filter will prevent the particulate
matter from
getting

into the impinger solution.

at least

99.95

Method 5.

percent

There

efficient,

the

analysis

of particulates

would be required

as required

is no indication

would not eliminate

because

Filters

still

in Section

or reason

to suspect

problem.
exist,

then

these

alternative

by the

standards

of
filters

analytical

tech-

for use upon

Administrator.

The Agency has not conducted

these

are

interference

niques (for example, ion chromatography) are available

approval

that

3.1.1

If analytical

to specifically

testing
address

of Method 8 as modified
the

commenter's

under

concerns.

The Agency knows of no technical

reason,

however,

fications

to Method 8 under this

subpart

would adversely

reproducibility,

precision,

oraccuracy

of Method 8.

In

procedures

for minimizing

the

repeatability,
addition,
sulfate
tive

EPA is currently
interference

of measuring

same equipment

developing

in particulate
both

particulate

and analytical

test

as to why the modiaffect

mattermeasurements.
matter

techniques

6-26

and
will

sulfur

the

The alternaoxides

be addressed

-4

ESP to

in SO, determinations

these

before

method for NSPS SOx compliance monitoring

Response:
that

into

to EPA, the

and improve fine particle`removal

work should be done to identify

The EPA agrees

according

The commenter added that

test

The commenter

to use an ESP to comply with the FCCU

or an "enhanced"

resistivity

SO, emission

measurement.

The commenter stated

ESP can produce significant

on the

test

for pa~tic-

with
at

that

the
time.

The EPA acknowledges

SO, dete ni nat ions .
eliminate

the

ference

problems

and/or

that

ammonia has known interfering

We bell eve there

interference

and are

with respect

amines are expected

are

a~ternative-'

currently

techniques

studying

to ammonia.

Thus,

on

to

potential

in cases

or are known to create

effects
inter-

where ammonia

problems,

the

owner

~ or operator should consult the A~Tlinistratorfor approval of alternative

test

methods.

Comment:

One commenter
using

Reference

(IV-K-6)

Method 8 is

analyzer,

even though

S02 ratio

in the stack

could

the

gas.

SOx emissions

the collection
than

of a grab sample

a continuous

be some minor variation

The commenter believed

prior

to obtaining

standardsspecified

in the

operator
the

that

from FCCU's using SO, reduction

the

course

ratio

that

of a day is any greater

in the

stack

gas and thus.no

The EPA assumes

that

the

evidence

operators

will

for the

commenter's

valid

operating

actions

on the

results

clearly

part

tosampling.

of an owner or operator

constitute

a circumvention

S02 to SO3

samples

will

prior

SOx through

in the

of operating conditions at the facility

conditions

each day.

variation

obtain

of

would be

in total

representative
not alter

sample.

the measurement

catalysts

the variation
than

SOg to

could

daily

accomplished by conducting revised Method 8 for one shift

The Agency knows of no evidence

on-line

the use of Method 8

where an unscrupulous

conditions

proposed

that
reliable

could

results

operating

Response:
The revised

less

there

give unrealistic

adjust

stated

remarks.
that

are

and, therefore,
Such deliberate

to obtain

unrealistic

of the standard

and is

illegal
under Subpart A, the General Provisions (40 CFR Section 60.12).
Inspection of plant operating data by EPA and State personnel would
lead

to

detection

of

such

alteration

of

plant

operation.

Comment:

One commenter
the

appropriate

revised

(IV-K-2)

temperature

Method tl.

questioned
for the

The commenter

whether
heated

based his

1600C (320"F)

probe and filter

question

on the

is
in the
following

as se rt io ns :

(a)

The commenter

believed

be above this

value,

that

the dew point

especially

6-27

for SO3 can often

for fCCU's running

more than

0.3 weight percent

sulfur

in the feed,

acid

filter

will

in the

to yield

(b)

heated

correct

and collecting

not help the

revised

sulfuric

:j

Method 8

results.

The commenter believed that a minimumprobe temperature of

200"C (400"F) was being established for Method5, and believed

the 1600C probe temperature

seems to be recreating

an earlier

problem.

(c)

The commenter believed

that

this

modification

would allow the

probe and heated filter

to corrode and leak in a few days if
used in a flue gas with a high SO, content.
This commenter also asked how the 1600C (320"F) temperature at the
probe

is reached

if

the

stack

temperature

is hotter,

or if

it

I:i

is

colder. This commenter stated that if a "probe catch" is a deposit

in the probe, the probe would soon plug up.
Response:
The EPA based the selection
filter
inthe

of the temperature

for the heated

i::ii

and probe in the revised Method 8 on the temperature specified

proposed Method 55 and 5F (50 FR 21863, May 29, 1985), which are

the methods for sampling particulate

matter at FCCU's. The EPA agrees
that the dew point for S03 may be higher than the temperature of the
heated filter
and probe (1600C). In such instances,
the filter
would
pick up condensed S03 (most likely, though, as sulfuric acid mist),
thereby leading to a low estimate of S03 as measured in the impingers.
The Agency believes
pick

that

up only a small

this

part

problem

of the

would pass through the filter

exists

provided

1600C

The commenter's

The materials
filter
Further,

holders
the

3-hour test)
required

that,

to underestimate

the

is

mist,

the

filter

and the

would

rest

--3

in the impingers.

in such situations,

emissions,

third

assertion

but believes

and filter

foy cleaning.
periodic

is

and stainless

are not subject

to conduct

acid

because

a potential
that

it

is small

maintained.

used (glass
probes

sulfuric

and be collected

Thus, the Agency recognizes

bias

is small

neither

steel)

to corrosion
holder

checks.

6-28

nor

correct,

in the probes and

from sulfuric

acid.

are removed each day (after

In addition,
leak

relevant

FCCUoperators
If

leaks

are

the

would be
detected

in

the

system,

need

to

regard

the

will

system

fails,

stack

temperature

if

then

from an SO, enforcement

standpoint

pass

- and thus

the

system would

is

hotter,

the

filter

from the
there

is

- more SO, will

no temperature

adjustment

and a temperature

is common practice

desired

di~fferent

However, if the stack temperature

through

It

the

being

temperature

impingers

made.

the

stack

at the probe.

the

to

temperature,

problem
in

sampling

be repaired.

With
probe

OP if the

be trapped

has

to

be made

is colder,

less

adjustment

to electrically

heat

no

has

the probe

SOx

to

be

to attain

temperature.

Finally,
operating

with

regard

procedures,

requires

that

collected

the

sample

eliminates

to plugging

sampling
probe

conducted

be cleaned

be discarded

the potential

of the

from

problem

probe,

using

out

after

the

analysis.

brought

as part

revised
each

Method

run
This

up by the

of normal
8

and that

the

procedure

commenter.

Comment:

One commenter
deleted

from

(IV-K-2)

Method

asked

why the

isopropanol

impinger

was

8.

Response:
Method 8 was designed

measurement of sulfuric
is used to collect
peroxide

the

hydrogen

peroxide

emissions.

capture

and SO3, while

S02.

the

In the
will

standards

hydrogen

absence

collect

all

of the

for SO, reduction

catalysts

EPA eliminated

the

IPA impinger

is to simplify

the

test

analysis,

calculations.

IPA

the SO,

Therefore,

of which

and

(IPA) impinger

is no need to separate

effect

6.4

separate

SO,; there

Method 8, the
and

the

The isopropanol

impinger

The current

based on total

sulfur

acid

is used to collect

compounds together.
are

for

acid and S02.

sulfuric

impinger

impinger,

primarily

S02 from other

from

procedure,

FEED SULFUR CUTOFF

Comment:

One commenter
sulfur
too

that

at

expensive

to

such testing

previously
for

FCCU's

(IV-K-1O)

using

the

that

the cost

alternative

be performed

should

felt
more

feed
often

be required

found to contain

than

of testing

sulfur
is

cut-off
necessary

once per week if the

below 0.3 percent

a week.

6-29

sulfur

the

feed

standard

is

and suggested

feed is

in every

sample

Response :

For these

standards,

owners and operators

are required

determine compliance on a continuous basis (i.e.,

As described
the

in the proposed standards;

FCCU fresh

feed once per day.

may change on an hourly basis.

on adail_y basis).

most refiners

Fresh

feed

Requiring

sulfur

samples

to

manually sample
content,

to

however,

be collected

once

per hour is not practical

using manualsampling
techniques.
Therefo re ,
the Agency selected a sampling frequency of one sample per 8-hour
shift.

This

sulfur

frequency

would measure

level and iS reasonable

practices.

The sampling

major

fluctuations

considering

current

program suggested

by the

refinery

on a daily

not

of

a good

indicator

future

basis.
use;

Furthermore,

many refiners

feed

sampling

commenter would not

allow the Agency to be sure that the owner or operator

meeting the standard

in fresh

use

is in fact
past feed usage is
different

feeds

or feed blends for short periods of time.

Therefore, the Agency has
retained daily testing for feed sulfur content for those operators
using

this

alternative

standard.

6-30

r"

7.0

7.1

SOURCE OPERATION

COMPLIANCE

COMMENTS

DURING MALFUNCTIONS

Comment:

One commenter (IV-D-7) requested

standards

that

allow

a certain

requiring

a FCCU shutdown.

that

amount

of

EPA consider
scrubber

establishing

downtime

without

Response:
The General

Provisions

control

equipment.

failure

of air

process

to operate

caused
any

other

scrubbers

this

levels

standards

Thus,

for

of

it

scrubber

usual

sudden

and

process

manner.

are

emissions

equipment,

of the

are

operation,

considered
of

or of a

that

careless

in excess

(discussed

is unnecessary

a standard

due

standard.

to

In addi-

re~i-

in Section

to provide

or

malfunctions.

to FCCU's have demonstrated

95 percent

of

unavoidable

Failures

not

a violation

applied

in excess

document).

or

represent

currently

equipment,

condition,

60.8(c),

do not

only

for malfunction

by poor maintenance,

upset

Section

a malfunction

ability

in a normal

or in part

in

means

control

preventable

As stated

tion,

"Malfunction"

pollution

entirely

in 40 CFR 60 provide

3.1

aprovision

of

in the

downtime.

Comment:

One commenter
to continue

(IV-D-16)

operating

asked

duriny

if

the

continuous

affected

facility

emissionmonitor

is

allowed

malfunctions.

Response:
An affected
emission

monitor

60.7(b)
shall

facility

malfunctions.

and (c)(3)
maintain

toring

However,

of any

or monitoring

(or semiannual,

periods

device

is

if no exceedances
report

shall

tifying

each period

during

which the

system

properly

except

repairs

operate

or

for

zero

adjustments.

or maintain

which

inoperative,

include

and span
It

continuous

should

a continuous
7-1

under 40 CFR

a continuous

and the

moni-

quarterly

during a particular

the date

checks,

continuous

the owner or operator

have occurred

compliance

during

as prescribed

during

quarter)
inoperative,

to operate

of the General Provisions,

records

system

may continue

and time

monitoring
and the

be noted

monitoring

idensystem was

nature

that

failure

of the
to

system would be

considered

as a violation

rather

than

a malfunction

(see 40 CFR 60.105

and 60.13).
7.2

COMPLIANCE USING PARTIAL SCRUBBING

Comment:

One commenter

requirement

that

(1V-D-3)

stated

that

the add-on control

EPA should

delete

the

device must be operated

to reduce

SO, in the entire exhaust stream by 90 percent (or to 50 vppm). Instead,,

a portion

of the FCCU regenerator

and rejoin

with

the

scrubbed

could then operate

exhaust

portion

a smaller

gas could

further

scrubber

bypass

downstream.

the

scrubber

A refiner

at or less than full

capacity

to

meet the 9.8 kg 50,/1,000 kg coke burn-off level of the standard for
FCCU's without

add-on

controls.

A smaller

scrubber

would mean smaller

-7

capital and annual operating costs, energy savings, eliminate the need

'"

for

reheat,

and

improve

nonair

environmental

benefits.

Response:
The 90 percent
scrubbers,

which

stream.

can

A relaxation

would cause
7.3

standard

it

is

achieve

intended

90 percent

of the standard

no longer

to reflect

to reflect

control

the capability

of the

ent'ire

to 9.8 kg S0,/1,000
the

capability

of

exhaust

kg coke burn-off

of scrubbers.

CHANGING COMPLIANCE METHOD

Comment:

A commenter (1V-D-16;) questioned

after

each change by a refiner

Rather,

the

commenter stated

ctwnpliance method the first

the need for a compliance test

from one method of compliance

that

one compliance

time selected

test

to another.

for each

is sufficient.

Response:
This comment is no longer

daily determinations
test (by definition)

applicable

operator

standards

now require

of compliance.
Under the standards,
a compliance
is required every day regardless of the standard

with which the owner or operator

or

as the

has been

previously

Four commenters

(IV-D-2,

seeks

to comply or to which the owner

subject.

Comment:

the

90-day

to another

notification
should

prior

be modified

IV-D-6,

IV-D-16,

to changing
to allow
7-2

for

and IV-D-2U) wrote

that

from one method of compliance

an immediate

change

in

emergency

ca ses .

as an emergency
to

the

The commen~ters pointed

shutdown

commenters,

different
add-on

in

standard
controls

of a hydrotreater

such

(e.g.,

to

the

~out example situations,

or of a scrubber.

cases

a refiner

would

change

from the

standard

feed

sulfur

such

want

Acco rd i ng

to comply

with

for FCCU's.without

cutoff)inediately,

rather

than

;urrail FCCU
processing
until the shut-down
controlunit is repaired.
Two of these

notification

commenters

compliance

of thechange

all

removed

records

appropriate

only

a refiner
annual)

for

to demonstrate
required

when an owner-or
to90

is alsd

requiredin

is sub~ect'may
compliance

EPA agrees

prior

no prior

to

inwriting

in writing
whenever

reduction

with

determinations

with

notification

compliance

operator

percent

The notification

notified

compliance

Thus,

requirements

is

EPA~is

that'daily

standards.

choic~e of SO, standard

comply.

that

method.

and EPA i's notified

compliance

Notification
the

the

notification

GEMS (e.g.,

maintained,-and

now requires

of the

and has

prior

are

in compliance

Response:
The regulation

maintained,

stated

should be required provided that recor'ds~appropriate

demonstrate

be made for

(IV-D-6 and IV-D-20)

the

provided

elects

be-submitted

report.

7-3

However,

to go from.the

any

50 vppm

or 50 vppm compliance).

a quarterly
any other

are-

or operator.adds

report

of any change

with which an owner or operator

of

that

the regulation

of the change.

an owner

commenters

changes

along

in the

with

elects

standard

a quarterly

in
to

towhich

(or

semi-

8.0

MODIFICATION/RECONSTRUCTION

COMMENTS

Comment:

One commenter
tion,as

written

(IV-D-2)

in 60.108(a),

which is replaced
The corranenter
or

suggested
should

by equipment

cited

that

alike

an example

the definition

be modified

to exclude

in design,

of an existing

of reconstruc-

shape,
unit

equipment

and metallurgy.

damaged

by disas.ter

misfortune.

Response:
Section
tion

60.15

occurs

the

upon

of

be required

if

is

technologically

the

replacements,

performance.
are

not

50 percent

to construct

specifies
if

of the

and

economically

to comply

the

entirely

the

reconstruc-

capital

capital

feasible

with

that

fixed

fixed

a comparable,

The circumstances

pertinent

Provisions

of components

exceeds

would

after

General

replacement

new components

it

the

cost

if

for

applicable

an existing

of

that

new facilityand
the

facility,

standards

prompting the reconstruction

when determining

cost

of

activities

facility

has

undergone

reconstruction.

Each
basis.

reconstruction

Section

will

use

facility
ically

60.15(f)

in maki.ng
can

determination

his

provide

feasible

to

sets

is.decided

forth

the

comply

that

with

the

If
it

it

must comply with

is

which

the

the

Administrator

ownerloperator

not

of the

technologically

applicable

will retain its "existing" status.

provision is met and it is feasible
standards,

criteria

determination.
evidence

on a case-by-case

standards,

or
the

econom-

facility

However, if the fixed capital cost

for the facility to comply with the

NSPS.

Comment:

One commenter
included

in these

definition

catalysts.
the

standards

to

that

supercede

a special
Section

Specifically,

the

FCCU regenerator

that

The commenter recommended that,

increase

pre-project

X), reduction

will

case,

catalysts

result,

the

operators

emission

level

not been used.

t)-l

provision
60.14

will
is using

increase

the
to

SO, emis-

SO, reduction

be allowed

whether

an

to

for

use,

which would h'ave existed

A modification

be

referred

in determining

should

should

regarding

commenter

of whether a given "project"

from an existing

emission

stated

of modification.

the determination
sions

(IV-D-3)

had

would not occur

unless

the post-project

level.

Operators.who

advantage

exceeded

the

adjusted

and'thereby

avoid

an emission

a net

pre-project

catalysts

They can use SO, reduction

project

affected

this

do not use SO, reduction

over those who do in preventing

gi ven " proj ect ."

with

emissi'ons

would have an

increase

catalysts

emission

in a

concurrently

increase

at

the

facility.

Response:
The inclusion
with

Section

of the

111(a)(4)

suggested

of the

special

Clean

Air

provision

Act,

is

which

inconsistent

defines

"modifica-

tion" to mean"any physical change in, or changein the methodof

operation

of" a source

to the

intent

that

"modification"

Air

Act.

new pollution
this

is

the

current

definition

Clean

emissions.

provision

best

serves

problems.

compliance

increases

from,

intent

of the

modified

of

statute

NSPS at,

contrary

NSPS program.

The

of the

Section

NSPS program

the

with

is also

application

the

One way that

It

and the

straightforward

One key purpose

by requiring

emissions

increases

of the modification

EPA believes

the

that

seeks

111

of

is

to

to

achieve

and thereby

prevent

minimizing

facilities.

Comment:

One commenter
as standpipes,
should

not

slide
be

fined

include

in a single

of the

work

on an affected

cost

of

an

fractionator

the

entire

items

that

of

cost

other

maintenance

regenerator
if

internal

a facility

require

the

routine

affected

and

an affected

of a new unit.

facility
FCCU,

routine

gas

plant

facility

Also,

and gas plant.

entire

These two units

and

cost

redework

exceed

of rebuilding
of the

FCCU includes

usually

are

Another

rebuilding

can commonly

the

or

shouldbe

20 percent
an

modified

because

such

components

increase.
facility

can represent
To a refiner,

is

items,

maintenance

a resultantemissions

fractionator

turnaround

50 percent

significant

without

(1V-D-16) stated

to

and

that

in determining

Many of the

repaired

commenter

stated

valves,

included

reconstructed.

frequently

(IV-D-7)

new unit
th~

do not require

any

rebuilding.

Response:
The reconstruction
until
facility

50 percent

of the

provision
"fixed

with a comparable,

(40 CFR 60.15)

capital

new facility
8-2

cost"

cannot

to replace

be invoked
the

has been incurred

existing
by the

owner

.,-

or

operator.

and

repair

erator

The period
is

called

refractory

inspected
from

and

the

ranging

repaired

10 years

II-D-40,

II-D-41,

determine

incurred

1I-D-42,

the

total

to replace

and repair

fixed

of the existing
Thus,

maintenance

items

from the

The EPA disagrees

can exceed

The EPA examined

literature

articles,

refineries

(see

erator

routine

If

to
the

to

tion

are

not,

for the

or

however,

choice

the

a typical

of equipment

such

rebuilding

nition

of the

tion
is

a new unit

affected

provision).
discussed

earlier

or

facility

(i.e.,

operational

in

this

provision
change

led

regen-

replaced

during

the

oil,

Justifica-

affected

Section

restrict

to

facility,

2.2

of

this

50 percent

broaden

invoking

of the

FCCU

Such ma3or

occurrence.

reason

the

reconstruction

the

defi-

reconstrucprovision

section.

(40 CFR 60.14)

to

an existing

8-3

is invoked
facility

turnaround,

point.

in

of

or converting

a single

the

cost

because

increasing

crude

to

EPA to

of the

work may exceed

an inadequate

The meaning and intent

The modification
physical

is

as

comprises

The possibility

is

than

50 percent

document.

of

this

reports,

services

data

50 percent

discussed

facility.

turnaround

during

is

cost

routine

trip

These

sour

in 40 CFR 60.101(n),

of the

fixed

work typically

responses,

rather

as defined

that

components

of a new affected

turnaround

that

during maintenance

rebuilding

above,

occur

surpass

costs

exempt

than

or more

regeneration,

may approach

less

changes,

a heavier

surmnation

specifically

that

repaired

major

those

(assuming

IV-8-18).

As discussed

several

high-temperature

changes

is

in the

of expended

who provide

rebuilding

used

items

sunmation

114 letter

item

are

provisions.

cost

Section

are typically

changing

cost

capital

A-79-09,

facility.

turnaround.

to

comment

and companies

components

capacity,

from

Docket

a new affected

the

of the

data

no need

are
life

when they

are

components
in the

a useful

Docket A-79-09,

incurred

reconstruction

with

50 percent

that

facility's
is

of time

incurred

The costs

regen-

on information

have

The costs

cost

maintenance

components

Based

(see

II-D-43).

capital

there

internal

period

are not included

costs.

conclude

and

for

turnaround,

components

turnarounds

components.

are not replaced)

capital

regenerator

during

a typical

as required.

to an indefinite

and maintained

shut.down

and other

replaced

industry,

FCCU is

During

cyclones,

or

repaired
to

the

a turnaround.

linings,

refining
from

in which

when any

results

in an

increase

in the emission

a standard

applies.

As the

increase

emissions,the

addition,

paragraph

nance,

repair,

rate to the atmosphere of any pollutant

and

actions

described

modification
(e)

provision

of Section

replacement

by the commenter

60.14

to which
do not

would not be invoked.

specifies

by themselves,

that

shall

routine

not

:'ij

In

mainte-

be considered

~?

modifications.
Comment:

One commenter (IV-D-8) stated

"inclusion

period"
with

struction

provisions

during

a normal 2-year
of the

A refiner

a routine

a i-calendar

for reconstruction

A refiner

pr ematu r el y.

that

is more logical

turnaround

standards

could

period

by the

recon-

began 1 or 2 months

a sizeable

due to the

than a E-year period.

be affected

if a shutdown

would not install

shutdown

year or a 12-month

process modification

excessive

downtime

incurred.

Response:
The EPA considered
i-calendar

year

or a 12-month

not more logical

industry

than

(i.e.,

period

and

and therefore,

this

schedule

period

for

for

A process

repair

items

unit

that
is

does not expect

of.the

NSPS.

Therefore,

period

whether

regenerator

provides

extensive

component

6U.15.

The Agency
of

the

of

that

the

to

with

during

2-year

the

includes
capital

costs

period

will

alter

to unduly

the

intent

equipment.

:1

prolong

that

determining

if

an emissions

questioned
increase

is

original

actually
intent

period

again

the methods
has

8-4

the

method of determining
"proposing"
of
at

Section

the

4-year

Comment:

(IV-D-13)

the

of avoiding

NSPS.

One commenter

each 2-year

NSPS, EPA believes

objective

the

from

be a "reconstruction."

likely

the

is

that

on when to replace

particular

is every

as fixed

2-year

is not

within

consider

indicates

typically

an FCCU regenerator

replacement,
will

Information

qualify

likely

that

reconstruction

FCCU regenerators

turnaround

a reasonable,

an owner/operator

FCCU's.

components

for this

for

would occur

do not

not

and concluded

BID, p. 5-3)

revamping

the FCCU owner or operator

life

review

period"

by an FCCU's owner o'r operator

is,

2-year

"inclusion
proposal

a turnaround

The Agency also

useful

period

a maximum of one turnaround

maintenance

That

(see

of operation).

decisions

the P-year

a 2-year

and literature

normal turnaround
years

again

occurred

to be used in

when determining

the

applicability

that

of the modification

EPA should

emission
asked

outline

factor

intends

to use.

consideration

material

Another

balance

tonnage

for FCCUls EPA

suggested

a coke

for an

The commenter also

factor

(IV-D-15)
of

a~ceptable

approach.

emission

commenter

the

The commenter stated

information

AP-42 or other

whether

substantial

the specific

and/or

what specific

provisions.

burnoff

taking

is

into

increased

by

amounts.

Response:
Specific

guidelines

whether

an

increase

ability

of possible

be considered
would

cannot

in

emissions

has

is whether

is

to

to

the

that

an emission

facility

be used

due

One factor

whether

the

to

occurred

circumstances.

in assessing

occur

be presented

wide

vari-

undoubtedly

increase

or will

determine

would

had occurred

be capable

of

or

utilizing

a newfeedstock. Anewfeedstockwill probablyhavea different s:lfur

content

than

bility

those

that

the

was designed

to

previously

used,

SO, emissions
accommodate

will
the

in emissions

resulting

considered

a modification

[see

that

be considered

of

increased

increase
sions

coke

related

to

the

Pollutant

factors

generally

reflect

the

ators.

The range

determined

complete

Catalyst

boiler.
determining
amount

rates

can

range

regeneration

is

Flue gas compositions

the
of air

coke

composition

required

to

in the

for

emission

factor
be capable
an

SO, emis-

is directly

FCCU regenerators

from

these

thus

individual

FCCU regener-

emission

ranges

in feed
the

rates

sulfur,

stoichiometric

do not
may be

coke
relation-

FCCU catalysts.
similar

to

solid

and flow rates

and formation
oxidize

8-5

the

coke.

fuel

combustion

may be calculated
rate

by

emission

levelsand

pollutant

typical

not

feedstock,

cause

however,

and by evaluating

in regenerating

or will

then

off.

in AP-42;

of emissions

is

Another

undoubtedly
burned

however,

alone

is

be estimated

average

the

change

no change

is

of FCCU regenerator

by considering

involved

that

represent

that

possi-

facility

raw material,

facility

will

a strong

existing

amount of SO, emissions

coke

described

and FCCU capacity,

ships

the

of

factors

the

rate

the

If the

is

40 CFR 960.14(e)(4)~.

Assuming

because

emission

emission

yield,

burn-off.

amount

from

whether

in the coke burn-off

to increase

using

is

ther'e

change.

alternative

an increase

would

and thus,

in a

by

and by calculating

Coke formation

rates

vary depending on the FCCUand how it

is operated.

Coke yield,

expressed as a weight percentage of the feed, varies between 4 weight

percent
item

and 6.5 weight percent

for many FCCUfeeds (see Docket A-79-09,

11-1-53).

Coke is composed of carbon,

hydrogen,

sulfur,

and small

amounts of

nitrogen and metals. Coke may typically contain from 4 to 12 percent

hydrogen (see Docket A-79-09, items 11-0-50, II-D-49, and II-D-47).
The sulfur content of the coke may range from less than 0.1 to 5 weight
percent or more, depending on the type of feed processed.
that the nitrogen and metals content of coke is negligible,
would represent the balance of coke composition.

Assuming
carbon

Certain regenerator combustion'air inlet and flue gas compositions

must also beassumed when calculating emissions. Inlet air to the
regenerator may contain from 76.0 to 78.8 volume percent nitrogen,
20 volume percent oxygen, and from 1.2 to 4.0 volume percent water.
A detailed discussion describing calculation
and/or estimating techniques to determine emission rates is presented in the proposal BID,
pp.

3-15

and 3-16.

Comment:

One commenter (IV-D-16) recommended t~at

should berewritten,

to dllow a better

Section 60.100(b)

understanding

and (c)

of reconstruction.

Response:

Sections
nition

60.100 (b) and (c) are not intended

or clarification

of the definition

to provide the defi-

of reconstruction,

as it

applies to 40 CFR 60; however, Section 60.100(c) was confusing and it

has been revised.
A detailed discussion of the meaning of reconstruction
is provided;in Subpart A, General Provisions,
under Section 60.15.
Specific

clarifications

as applicable

for

Subpart

or additions
J,

are

to the definition

provided

8-6

under

Section

of reconstruction,
60.108,

9.0

RECORDKEEPING AND REPORTING COMMENTS

Comr~nt:-

The Office
reporting
the

of Management

was too

Agency

to

trequent,

obtain

and Budget
andthat

the

commented

semiannual

necessary

that

quarterly

reporting

would

all~ow

information.

Response:

For FCCU's, EPA has concluded that

annual-reporting.if

quarter)

is t'he appropriate

reasons.
ance

information

rather

testing

isneeded

icant

emission

emissions
near

true

there

littl'e

regulated.
long

periods

occur,

~ facilities

addition,

to ensure

of time during

quarterly
have.had

the

Sources'complying
supply

only

pliant

sources

this

reporting
a period

amount of data
with

a semiannual

the

that
is

proposed
negative

are

toprovide

reports.

9-1

of

located

areas.

signifexcess

This

the control

category

to

is

in clusters
Because

be recovered

standard

declaration

of several

on the environment.

for

the

tech-

resale,

be self-

are; not out of compliance

appropriate

revised

no further

so periods

sources

to be provided

compli-

performance.

one

which significant

when the

would be required

the quarterlycompliance

source

direct

because

save money by operating

for

particular

source's

nonattainment

cannot

(or semi-

the following

contain

quickly

generally

pollutants

i.ncentive

Therefore,

impact

popu'lated,

and the

for

refineries,

refineries

does not

correctly
is

could

urban,

generally

niques

petroleum

because

during.a

The FCCU is

have a significant

industrial,

refinery

in

of the

betaken

documentation.

sources

particularly

the reports

can

reporting

occurred

fre~uency

indicators

action

for

could

is that

than

enforcement

have

reporting

The major reason

Therefore,

for

no exceedances

quarterly

environmental
for quarters
has

been

impacts
when

exceeded.

in these

cases

s.tandard

would need to

statement.
additional

In

is reasonable.
Only noncom-

information

in

10.0

MISCELLANEOUS

COMMENTS

Comment:

One commenter
states

that

SO, rules
,

(IV-D-16)

FCCU flue

that

gas

wrote

is

that

similar

apply to stationary

FCCU's.

If these

releases

less

rules

than

to

the proposal

stationary

sources

were applied

250 million

since

preamble

source

flue

gas,

should be prescribed

to FCCU's, regenerators

the

for

with

heat

BTU's per hour would be exempt.

Response:
The EPA assumes
referring

to

utility

from

a coal-fired

erator

exhaust

cable,

it

boilers

is

that
boilers.

utility
gases,

not

two source

and

economic

for

which

boiler
and

is

simply

categories.
are

the

to

that

copy

the

being

the

developed

devices

are

standards

differences

characterize

of the

should

for

could

exist

the

process

source

is
flue

gas

of FCCU regen-

same control

to

commenter

composition

Whenever practical,

that

standards

the

similar

some of the

when significant

aspects

sources,

Although

appropriate

to FCCU's

the

by stationary

appliutility

between

operation

category

or

be considered.

industry
In

addition, the SO, standards for FCCU'sconsider the additional control

alternatives

available

to FCCU's that

are

boilers.

The utility

boiler

refiner's

flexibility

to use high sulfur

the

use of SO, reduction

treating.

Thus,

it

fo r ut ii i ty boile

standard

catalysts,

not available

applied

to FCCU's would reduce

feedstocks

low sulfur

is not reasonable

to utility

to simply

and would~not

allow

feedstocks,

or hydro-

copy the

S02 standards

rs .

Comment:

Two commenters
package

should

(1V-D-6 and IV-D-10)

undergo

NAPCTACreview

NAPCSAC
meeting the regulation
proposed

standards

Response:
The purpose

are
for

from an independent
regulatory
facto rs .

alternatives,
Althouyh

because

the proposal

at the original

of SO,.

a NAPCTACmeeting
committee

control

the standard

in terms of SO,, the~ standard

again

that

was in terms of S02 while the current

in terms

advisory

suggested

is

for

EPA to receive

regarding

techniques,

control

for FCCU's without

is stilf~achievable
10-1

the

comments

need for
costs,

add-on

standards,

and other
controls

by the identified

is

controltechniquesandthe environmental,
energy,andeconomic
impacts
are still

reasonable.

Therefore,

it

is not necessary

to conduct

another NAPCTAC
review due to the change of this standard from S02 to
SO,.
Comment:

One commenter (IV-K-2) asked why EPA requires

explanations

when fewer than

monitoring

data

have

been

18 valid

hours

dates

and

of continuous

emissions

obtained.

Response:
Facilities
more valid

using

hours

add-on

controls

of GEMSdata

for

at

are required
least

to obtain

18 or

22 days each month.

As

pointed out by this samecommenterelsewhere, there is somepossibility

than an owner or operator
minimize
erate

the "bad"

actions

illegal

may try to maximize the "good" days and

days in trying

are attempts

to circumvent

under 40 CFR Part

wo~ds,

valid

60, Subpart

such an owner or operator

invalidate

to meet the
the

standard.
standard,

A, Section

may turn

off

which is

60.12.

the

In other

GEMSor otherwise

its data on a "bad" day in order to generate

hours. --With the dates and a brief

Such delib-

explanation,

less than 18
the Agency can

look for patterns that indicate that an owner or operator may be

circumventing the standard and thus discourage this type of behavior.
Comment:

One commenter

"monitored

parameter

(IV-K-2)

data,"

suggested

that

EPA'should

but use "excess emissions"

not use

to target

inspections.

Response:
The discussion

of

"Monitored

Parameter

Data"

and "Excess

Emissions Data" in the reproposal notice was generic to the entire

NSPS/NESHAP
development process and not addressed specifically
to the
FCCUstandards
needed to target
monitored

inspections

parameter

emis'si o n data.
equipment rather
operating

being proposed.
data

While both types of data may not be

for

any one standard,

may be more appropriate

to collect

For example, in standards

that

than being a numerical

emission

parameters

would likely

ta rget i ng i ns pect i o ns .

be the

best

Thus, the Agency will

10-2

in some cases,

require
data

limit,

excess

particular
monitoring

to collect

continue

than

for

to judge,

on a

case-by-case
or

basis,

the type of data that

is appropriate

for-each

NSPS

NESHAP.

Comment:

One commenter
"redundant"
EPA states
later

(IV-K-2)

asked what is the difference

GEMSand a "spare"
that

redundant

discusses

the

use

between

GEMS. The corruTienter pointed

CEMS's are not warranted

of a spare

out that

because

of cost,

but

100 percent

of the

time,

GEMS.

Response:
If
then

EPA required

a second

GEMS would

ability.ilt

is

100 percent

availability

ddwntime.

requirements
at least

68 testing,

refers

to the

is

there

GEMS as

not

no meaningful

high

to

cost

be met`by

the

percent
secbnd

availmonitor

for ensuring

close

EPA proposed

a single

may be.times

to

minimum

GEMS, taking

when minimum

into

data

GEMS. The owner or operator

the~needed

GEMS.

It

a "spare"

required.

that

Thus,

(first)

and the

to

the

warranted.

there

a second

requirements
but

that

likely

still,

to

EPA refers

in obtaining

or

who chooses
is

not

could

Even

second

optional,

operator

is

options

Method

data

that

are not met by the

three

minimum

context

that

close
to ensure

GEMSand believes

requirements

account

operate

be required

in this

as a "redundant"
data

a GEMS to

is

data

in this

monitor.

manual

a second

difference

between

contextthat

that

GEMS for

the

a second
for

GEMS

an owner

back-up

"redundant"

EPA
with

options,

The EPA recognizes

purchase

- Method 6 testing,

Therefore,

testing

has

or

purposes

and

"spare."

Comment:

Onecommenter

(IV-K-2)
as

pointed

88 percent

reduction

being

exceedance

if the S02 is less

out that

an exceedance

than

the

preamble

may not,

in

example
fact,

of

be an

50 vppm.

Response:
The pgency

i nc omp1ete .

50 vppm or

the

add-on

that

the

would

less

control

outlet

primarily
occur

that

the

An add-on control

are

was

agrees

is

not

percent

example

point

when the

out
control

in

device whose outlet

in exceedance
reduction.

S02 vppm was greater

to

provided

that

for

device

10-3

of the

50.

percent
efficiency

preamble

is

S02 emissions

standard

The example

than

the

regardless

implicitly

The object

reduction
was less

of

assumed

of the

example

an exceedance
than

90 percent.

Comment:

One commenter'(IV-K-2)
to

achieve

a standard"

describe

emissions

suggested

rather

greater

than

that

EPA use the words "failure

"exceedance

of a standard"

to

than those allowed by a standard.

The

corra~enter added~that "exceedance" has the connotation of being better

than or superior
standard,

to, which, in the case of a percent

would be a reduction

better

than

reduction

required.

Response:

The word "exceedance"

is used by EPA in the context

of not

achieving a prescribed emission level set by EPA. Exceedanceof a

percent
not

reduction

achieved

reduction

standard

an emission

means that
level

a facility

tin this

based on flue gas scrubbers)

case,

"exceedance"

consistency
has

been

with other

90 percent

specified

has been used by EPA in numerous standards

to maintain

or process

unit has

emission

by EPA. This term

of performance.

standards,

the

Therefore,

use of the word

retained.

Comment:

One commenter

(IV-K-2)

asked whether

page 46465, column i, paragraph

proposed

standards

should

the words "source

owner" on

i, of the preamble to the revised

be "source

owner or operator."

This

commenter

also asked whether the word "provide" on page 46465, column 1, paragraph
i, of the preamble to the revised

" reco rd ."

errors

In addition,

in the preamble.

proposed standards

means "i~epore" or

the cor~8~enterpointed out various typographical

In an earlier

commenter provided a thorough list

commentletter

of editorial

(IV-D-16),

this

and typographical

changes that should be incorporated into the proposal BIDand the

Federal Register
Response:

notice.

The EPA inadvertently

sentence

clarify

referred

that

to by the

the requirement

omitted the words "or operator"

commenter.

Therefore,

to provide

for every 30-day period using continuous

manual emission test is the responsibility
or operator

or an appropriate

person

o pe, ra to r .

10-4

from the

EPA wishes

to

a minimum of 22 days of data

monitors or an approved
of either the plant owner

designated

by the owner or

The commenter refers to the requirement to "provide" monitoring

data for determining performance of the add-on control~ device (using
continuous

monitors

explained

or an approved

in the preamble to the revised

46467 under

"Recordkeeping

jectto

standard

to

manual emission

the

~ecord!the

data

from

as well as at the outlet.

"record"

in

the

A listing
provided

context

of each

here

since

the

the

Requirements,'!

add-on

controls

continuous

emission

Therefore,

the'worb

of this

on page~

refiners

sub-

would be required

monitor

at

"provide"

the

inlet,

means to

requirement.

typographical
errors

As

proposed standards

and Reporting

for FCCU's with

test),.

error

and suggested

and suggestion
changes

is not

do not

affect

the

intent or technical discussions presentledin these documents. Noneof

the

typographical

errors

impairs

the

meaning

orexplanation

of

the

standards intended by EPA. The suggestions haye been reviewed and.al-l

appropriate

changes

have been made.

1U-5

APPENDIX

CONTROL EQUIPMENT
AND FIFTH

COSTS

YEAR IMPACTS

TABLE A-i.
-

BASIS

FOR DETERMINING

-~--

Direct

Operating

SCRUBBER

-1-~--~-

ANNUAL COSTSa

--~-`---

---I

Costs

Laborb

817.51/hour

Maintenance
(includes
labor,
and overhead)

materials,

1.5 percent

of total

capital

cost

Uti lities

Electricity

B0.0795/kWh

Water

80.0763/m3

Compressed Air

90.861/1,000 m3

CausticSodac(ZodaRshd)

f268/Mg
(8122/M9)

Steam

813.53/1,000

kg

Polyelectrolytee

B10.07/kg

Solid Waste Disposalf

BZ0.13/Mg

Liquid Waste Disposalf

Indirect
Tax,

Operating
Insurance,

Capital

Fourth

80.16/m3

Costs
and Administration

Recovery

quarter

(to sewer)

4 percent

Factor

1984

13.15

of~total

percent

of total

Bureau

Liquid~caustic

soda,

100 percent;

F.O.B.

Gulf

Bulk soda ash,

light,

99 percent;

F.O.B.

Wyoming; Docket

F,O.B.

3300,
Dallas,

From industrial

cost

capital

dollars.

blnciudes
40percentoverhead;
V.S.Department
of Labor,

Polymer

capital

an anionic

polyacrilomide

Coast;

settling

Docket

of

Labor

A-79-09,

A-79-09,

ayent;'~0-pound

Statistics,

item

item

II-E-6

II-E-6.

bags,

Texas.
boilers

- EPA-450/3-82-021

August

Costs of Sulfur Dioxide,

Particulate
Matter
Fuel Fired Industrial
Boilers.
p. 2-16.

1982.

and Nitrogen

A-i

Oxide

Control

onfossil

cost

TABLEA-2.

CAPITALCOSTFORSODIUM-BASED
HIGHENERGY
VENTURI
SCRUBBING
SYSTEM AND PURGE TREATMENT FOR MODEL UNITSa

Capital

Costs

Direct

Costsb

Indirect

Costs

Contingency

2,500 m3/sd

8,000 m3/sd

Model

Model

CostsC

TOTAL CAPITAL COST

ESP Capital Cost Creditd

Costs are reported
1984

dollars,

Materials

to

2.9

5.0

1.3

2.2

0.8

1.4

5.0

8.6

-1.0

-1.8

of dollars,

a Gulf

Unit

Coast

adjusted

to fourth

quarter

location.

and labor.

Twenty percent
From Table

in millions

delivered

Unit

of total

A-9 in this

direct
appendix;

and indirect
cost

A-2

costs.

provided

for

comparison

purposes.

TABLE A-3.

ANNUALCOST OF SODIUM-BASEDHIGH ENERGYVENTURI SCRUBBINGFOR

2,500m3/sdMODEL
UNITS

Annual
Annual

test,

in

Thousands

of

i)ollarsa

Costs
0.3

wt.

Sulfur

Oirect operating

Feed

1.5

wt.

Sulfur

3.5

Few

wt.

Sulfur

Feed

Costs

Labor

53.7

53.7

53.7

Maintenance

75.0

75.0

75.0

Electricity

22.4

22.4

22.4

water

10.2

10.2

10.2

Utilities

Compressed
Caustic

Air

0.4

Soda

155

579

(95)

(355)

(Soda Asn)

0.4
1,089

(668)

Steam

1.1

1.1

1.1

Polyelectrolyte

4.9

4.9

4.9

7.1

7.1

15.6

15.6

Solid

waste

Oispasal

Liquid waste D~sposaib

Indi rect Operating
Tax,

Insurance,

Capital
TOfAL

ANNUAL

and Administration
Cost

(5004 Ash)

(Soaa

EMISSION

15.6

200

200

200

658

658

658

1,200

1.630

(1,140)

(1.400)

-272

-272

ESP Credite

Caustic

7.1

COST

Soda

ANNUAL

Costs

Recovery

Caustic

HET

0.4

2,140

(1,720)

-272

COST

Soda

Asn)

930

1,360

1,870

(870)

(1,130)

(1,440)

450

1.570

3,130

2.070

810

600

REDUCTION

Cnr so, rerr~ov~dlyr]

C05T EFFECT~YEnESSd

CS/ng 50, rrmoved]

aHumDers may not

bAssumes liquid

add to totals

waste disposal

cFrom TaDle A-g in this

agased

on net

annual

cost

due to rounding.

to sewer, 50 gal/minute,

appendix.
with

Fourth

caustic

soda.

A-3

quarter

1984 dollars.

TABLE A-4.

ANNUALCOST OF SODIUM-BASEDHIGH ENERGYVENTURI SCRUBBINGfOR

8,000 mSLsdMODEL
UNITS

Annual
Ai~nual

Cost,

in

Thousanas

of

Dollarsa

Costs
0.3

wt.

Sulfur

Feed

1.5

wt.

Sulfur

3.5

Feed

Suifur

wt.

Feed

Direct Operating Costs

LaDor

53.7

Maintenance

129

53.7

53.7

129

129

Utilities

Electricity
water

Compressed Air

71.6

71.6

71.6

30.6

30.6

30.6

0.4

0.4

Caustic Sooa
(5044 ASh)

506
(313)

Steam

1,1)60

0.4

3,480
(2,150)

3.2

3.2

3.2

Poi yel ect rol yt e

14.6

14.6

14.6

Solid waste Disposal

22.7

22.7

' 22.7

31.2 ~

31.2

31.2

Liquid waste Dlsposalb

[nai rect Operating Costs

Tax,

Insurance,

Capital

and AQalnistrafion

Recovery Cost

344

304

304

1,131

1,131

1.131

TOTAL Ant(UAL COST

Caustic

Soda

(soda Asn)
ESP Credit'

2,340

3.690

5.310

(2.150)

(2,980)

(3,980)

429

-429

-424

MET AN~JUAL COST

Caust~e Soda

(Sop4 Psh)

EnISS~ON

1,910

3,260

4.1380

(1,720)

(2,550)

(3.550)

1,440

5.350

9,990

1.330

610

490

REDUtTIDN

E~ngSD, removed/yrl
COST EFFECtIVENESSd

Cs/nr so, removed]

"numoers may not aao ~o~totals aue to rounding.

Foorrh quarter 1984 dollars.

bAssumesliquid waste disposal to sewer. 100 gal/minute.

cFrMn Taole A-9 in this
"Basea

on net

annual

cost

appenair.
*~th

caustic

soda.

A-4

TABLE A-5.

CAPITAL COST FOR SODIUM-BASED JET EJECTOR VENTURI SCRUBBING

SYSTEM AND PURGE TREATMENT FOR MODEL UNITSa

2,500 m3/sd
Capital

Costs

Direct

Costsb

Indirect

Costs

Contingency

Model

Costsc

TOTAL CAPITAL

COST

ESP Capital Cost Creditd

aCosts are reported

dollars,

delivered

bMaterials
cTwenty

in millions
to

a Gulf

of dollars,
Coast

8,000 m3/sd

Unit

Model

Unit

4.2

7.2

1.6

3.2

1.2

2.1

7.0

12.5

-1.0

-1.8

adjuste'd

to fourth

quarter

location.

and labor.

percent

of total

dFrom Table A-9 in this

direct

and indirect

costs.

appendix; cost provided for comparison purposes.

A-5

1984

TABLE A-6.

ANNUAL COST OF SODIUM-BASED

2,500

m'/sd

JET

VENTURI

SCRUBBING

FOR

MODEL UNITS

Annual
Annual

EJECTOR

Cost,

in

Thousands

of

3ollarsa

Costs
1.5

vs.

Sulfur

Dfrecs Ogcradng

O
reed

3;5

vs.

Sulfur

X
Feed

Costs

Labor

53.7

~a~nrenance

53.7

205

105

364

304

Utilities

Electricity
Ylter

10.2

Compressed

Air

10.2

3.3

Caustic
Soda
(5064 Ash)

0.3

568
(341)

1,083
(650)

Steam

1.1

1.1

Polyelectroyte

5.2

5.2

7.1

7.1

31.1

31.1

Solid

Uaste

DlsDosal

Lfquld Yaste Dlsoosalb

indirect Opcranng Costs

Tax,

insurance,

Capital
TOfAL

and

Recovery

ANNUAL

Administration

Cast

ESP Crealt
ANNUAL

2,290
(2.060)

2.800
(2.370)

-272

-272

2,020
(1,790]

2, 530
(2.100)

1.610

3,070

EffECTIYENESSc

CS/ng 50, rt~oved~

1,250

aWumbers may nor add to totals

due to rounding.

bAssuunas liquid

to sever.

caasea

921

REOUCTIOH

Cng 50, remarca/yr~

COSf

921

CDSf

Caustic
Soda
(5064 Ash)

WISSION

280

COSf

Caustic
Soda
(5964 Asn)

NET

280

on net

vaste
annual

dlsDosal
cost

rith

caustic

Fourth

50 gal/minute.
soda.

A-6

820

guarter

1984 dollars.

i`?

TABLE A-7.

ANNUALCOST OF SODIUM-BASEDJET EJECTOR VENTURI SCRUBBINGFOR

8,000 m3/,dE~ODEL
UNITS
Annual
Annual

Cost,

of 0011arsa

Costs
l.S
Sulfur

Direct

in Thousands

Operating

wt.

t
Few

3.5
Sulfur

wt.:
Few

Costs

Labor

53.7

naintenance

53.7

188

188

Utitities

Electricity

976

Yater

30.7

Compressed
Caustic

Air

976
30.7

0.4

Soda

(Soaa Asn)

3.4

1,818

3,606

(1,101)

(2.183)

Steam

3.4

Polyelectrolyte

15.6

15.6

Solid Ya~;e Dfsposal

22.7

22.7

Liquid Yaste Disposalb

62.3

62.3

Indirect
Tax,

Operaring
Insurance,

Capital
TOTAL

Costs
and

Recovery

ANNUAL

Caustic

(Soaa

~ninisrrazion

Cost

500

1.644

1,644

COST

Soaa

'

Asn)

ESp

Credit

NET

AN~QIAL COST

Caustic Soda
(Soda Asn)

EnISSION

500

5.310

7,100

(4,600)

(5,680)

-429

-029

1,BSD
(4,170)

6,670
(5,250)

5,160

9.840

940

630

REDUCTION

[nq 50, remavea/yr]

COST EFFECTIYENESSc

CS/ng 50, removea]

"NumDers may not add to totals

due to rounding.

bAssumes

to sewer,

'aaseo

liquid

on net

waste
annual

disposal
cost

with

caustic

Fourtn cluarter

100 gal/minute.
sooa.

A-7

19134dollars.

TABLE A-8.

DUAL ALKALI SCRUBBING SYSTEM COSTS BASED ON 1.5

PERCENT

SULFUR

2,500 m3/sd '

Cost

Model

CAPITAL

Direct

Costs

Contingency

Unit

Model

Unit

2,500

4,400

1,100

2,000

Costs

TOTALCAPITALCOST
ESP Capital

8,000 rn3/sd

COSTS

Costs

Indirect

WEIGHT

FEEDa

Cost Credit

700

1,300

4,300

7,700

(1,000)

(1,800)

ANNUAL COSTS

Direct Operating Costs

Operating

Labor

38

65

116

33

Maintenance

75

Utilities
Soda

Ash

Lime

101

Electricity
Water

Was te

Indirect

Di s pos a~

Operating

Tax,

61

191

125

393

172

308

565

1,013

Costs

Insurance,

and

Capital

Administration

Recovery

Cost

ESP Credit
NET ANNUALCOST
EMISSION

316

(272)

(429)

870

2,020

REDUCTION

CMg 502 removedlyr~

1,670

5,350

COST-EFFECTIVENESS

CB/M9of 502 removed~

520

"Costs are reported in thousands of'dollars,

1984

dollars.
A-8

380

adjusted to fourth quarter

TABLE A-9.
ELECTROSTATIC PRECIPITATOR COSfSa
(Fourth
Quarter
1984 Dollars)

2,500 m3/sd
Costs

Model

CAPITAL

Unit

8,000 m3/sd
Model

Unit

COSTS

Equipment Costs

Control Deviceb

324,000

542,000

Auxiliariesc

43,400

81,100

Instruments and Controlsd

36,700

62,300

fares

29,400

49,800

and Freighte

Installation Costsf

611,000

fOTAL CAPITALCOSTS

1,045,000
ANNUAL

Direct

1.037,000
1,772,000

COSTS

Costs

Operating

Laborg

General Maintenanceh
Replacement Parts'
UtilitiesJ

Waste Disposalk
Indirect

Tax,

Insurance,

28,100

28,100

820

1,380

11,000

35,200

7,840

25,100

32,800

32,800

41,800

70,900

and

Administrationm
Capital

27,000

Costs

Overheadl
Property

27,000

Recovery

Cost"

TOTAL ANNUALCOSTS

A-9

122,800

208,200

272,000

429,000

TABLE A-9.

afourth

quarter

FOOTNOTES

1984 dollars.

bRemovalefficiency ~ 95 percent; drift velocity

0.076 m/sec; plate area

for the 2,500 m3/sd unit = 1,000 m2, for the 8,000 m3/sd unit = 3,200 m2
air flow for the 2,500 m3/sd unit
27 m3/sec, for the 8,000 m3/sd unit =
87 m~/sec. Docket A-79-09; item II-I-1I.
tAuxiliaries

include bypassducting:

6.4 mm carbon

steel,

insulated;

2 expansion

joints;

4.5

conveyor.

m screw

2 round

19.7 m length,

2 elbows
dampers

Docket

with

A-79-09,

dInstrument and controls.calculated

auxiliary

equipment

cost.

127 cm diameter,

6.4 mm carbon
automatic

items

steel,

controls;

II-A-5,

insulated;
and

II-E-5,

a 23 cm x

and II-E-95.

as 10 percent of control device~and

Docket

A-79-09,

item

1I-A-5.

eTaxes and freight calculated

as 8 percent of control
equipment cost.
Docket A-79-09; item 11-A-5.

device and auxiliary

fIncludes indirect and direct installation costs and 20 percent contingency

calculated
tion costs
electrical

as 141 percent
include
costs
work, piping,

of purchased
equipment cost.
Indirect
installafor foundations
and supports,
erection
and handling,
insulation,
and piping.
Docket A-79-09, item

II-A15.

9lncludes

operator

and supervisor

costs.

Operating

labor

costs

are based on

1.25 operator
man-hours
per shift,
3 shifts
per day, 365 days per year and
817.51 per man-hour.
Supervisor
labor costs are included
by adding 15 percent

to

the

hInciudes

operator

labor

costs.

and material

Docket

costs.

0.75 man-hours
per man-hour.

per shift,
3 shifts
Material
costs are

costs,

A-79-09,

Docket

A-79-09,

item

item

Maintenance

II-A-5.

labor costs

are based on

per day, 365 days per year,

and 817.51
equal to 100 percent
of maintenance
labor

II-A-5.

leased on q.078 percent of total capital costs.

Docket A-79-09, item II-

A124.

JBasedon 16 15 watts/m2plate area, 357days per year 80.0795per kWh,

and 1,000mZplate area for the smallESPand 3,200m2plate area for the
large

ESP.

Docket

A-79-09,

item

II-A-5.

kCost to removewaste is based on 916.50/metric ton.

I1-1~82,

and

Docket A-79-09, items

II-A-5.

l0verhead calculated as 80 percent operating labor and maintenance (labor

only).

Docket

mCalculated
item

as 4 percent

item

II-A-5.

of total

installed

capital

cost,

Docket A-79-09,

II-A-5.

"Capital
interest
item

A-79-09,

recovery
rate.

cost
Capital

basedon
recovery

20 years

operating

factor

= 0.1175.

II-A-5.

A-10

life,

and 20 percent

Docket

A-79-09,

annual

TABLE A-3O.

FIFTH

YEAR CAPITAL

COST IMPACTSa

NEW FCCU CONSTRUCTION(1984-1989)

Fresh Feed

Feed Sulfur

Capacity

Content

(m~/sd)

(wt. %)

Number of

Capital

Units:

Per

Cost

Unit:

Capital

Cost:

A x B

(8 Millions)

(B Millions)

2,500b,C

0.3

5.0

5.0

8,000b,e

0.3

8.6

8.6

2,500b

1.5

5.0

15.0

8,000b

1.5

8.6

25.8

2,500b

3.5

5.0

5.0

8,000b

3. 5

8.6

8.6

TOTAL CAPITAL

COST

IMPACT

68.0

MoDrFIED/RECoNsTRuCTED FCCU's (1984-1989)

Fresh Feed

FeedSulfur

Capacity
(m~/sd)

Content
(wt. 1)

Number
of

Capital Cost

Units:

Per Unit:
B
Adjustmente: C
(8 Millions)
(~ Millions/Unit)

Retr.ofit Cost

Capital test:
A x (B + C)
(B Millions)

2,500d

1.5

7.0

--

7.0

2,500b

1.5

5.0

0.8

5.8

8,000b

1.5

8.6

--

8.6

8,000d

1.5

12. 5

--

12.5

8,000b

1.5

8.6

1.4

20.0

8,000b

3. 5

8.6

--

TOTAL CAPITAL

aqth

quarter

COST

8.6

IMPACT

62.5

1984 dollars.

bHigh-energy venturi scrubb~r.

CAt a feed
standard

of 0.3
this

sulfur
would

percent

cost

dJet-ejector
e20 percent

would

content
need

to

or less,
not

be

of higher
be met,

the

and

than

0.3

percent,

this

cost

would

regenerator

the

90 percent

be incurred.

would not be required

to meet the

incurred.

venturi scrubber.
of direct

and indirect

capital

cost;
A-ii

excludes

emission

At feed

ESP credit.

sulfur

reduction
contents

standard,

and

TABLE A-ii.

Fresh

Feed

Feed

Caeaci
ty
(m3/sd)

FIFTH

Sulfur~

YEAR ANNUAL COST

Number

Content
(wt. X)

of

Annual

IMPACTS"

Cost

Annual

Units: A

Per
Uniti B
(B i,ooo s)

Cost

AxB

(8 1,O0O's)

2,50Ob,C

0.3

930

930

2,500b

1.5

1,360

4,080

2,500d

1.5

2,020

2,020

2,500ble

1.5

1,780

1.780

2,SOOb

3.5

1,870

1,870

8,00Ob,C

0.3

1,910

1,910

8,000b

1.5

3,260

13.040

8,000d

1.5

4,880

4,880

8,000b,e

1.5

3,950

7,900

8,000b

J. 5

4,880

9,760

TOTAL ANNUALCOST IMPACT

aqth quarter

48,170

1984 dollars.

bHigh-energy venturi scrubber.

tAt a feed sulfur
reduction

content of higher than 0.3 percent,

standard

feed sulfur

contents

be

to meet

required

dJet-ejector
eAnnualized

would need to be met,

of 0.3 percent
the

standard,

and this

or less,
and

this

the 90 percent emission

cost

would

the regenerator
cost

would

not

be incurred.

would not
be incurred.

venturi scrubber.
capital

cost

includes

retrofit

A-12

cost;

excludes

ESP credit.

At