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					                        DRAFT White Paper – Asphalt Roofing Manufacturing

                                                       Strategy Evaluation
                                                  Portland Air Toxics Solutions


Table of Contents
Introduction ............................................................................................................................................... 2
I.        SOURCE CATEGORY: Asphalt Roofing Manufacturing .......................................................... 3
     A.  Source Category Description ......................................................................................................................3
       A.1.  Asphalt Roofing Manufacturing in the PATS Area ..............................................................................3
       A.2.  Asphalt Roofing Manufacturing Devices .............................................................................................3
     B. Modeling Results: Degree of Contribution and Emission Reductions Needed. ....................................4
       B.1.  Description of emissions/2017 modeling results from asphalt roofing manufacturing ........................4
       B.2.  Main risk drivers ...................................................................................................................................5
     C. Source Category Effect on Distribution of Emissions ..............................................................................5
II.         SUMMARY OF EXISTING EMISSION REDUCTION STRATEGIES ............................... 6
     A.     Measures for Asphalt Roofing Manufacturing Processes ........................................................................6
III.        SUMMARY OF POTENTIAL NEW EMISSION REDUCTION MEASURES .................... 8
     A.     Narrative Overview of Strategies Evaluated.............................................................................................8
     B.     Summary of Strategies Evaluated ..............................................................................................................8
     C.     Other Measures Considered .....................................................................................................................12
IV.         DETAILS FOR EACH POTENTIAL NEW EMISSION REDUCTION MEASURE ........ 13
     A. Strategy #1: Thermal oxidation (Require PM and VOC controls beyond the NSPS on asphalt
     storage tanks, blowing stills, saturators, coater-mixer tanks, and coaters) ..................................................13
V.          ATTACHMENTS ....................................................................................................................... 15
     Attachment A: Considerations [To be filled out by PATSAC/DEQ] ............................................................15
VI. References ........................................................................................................................................ 19

Tables
Table 1. 2017 Predicted HAP Emissions for Asphalt Roofing Manufacturing Source Category
(pounds/year) .............................................................................................................................................. 3
Table 2: Reduction Targets for Asphalt Roofing Manufacturing ............................................................... 4
Table 3: Blueprint and Brainstorm List Strategies ..................................................................................... 8
Table 4: PATS Pollutants Emission Reductions from Each Strategy......................................................... 9
Table 5: Other Pollutants Reduced by Each Strategy ............................................................................... 10
Table 6: Summary of Strategies Evaluated: Timeframe, Technical Feasibility, and Cost ....................... 11
Table 7: Blueprint and Brainstorm List Strategies ................................................................................... 15
Table 8: Effectiveness ............................................................................................................................... 15
Table 9: Implementation/Feasibility Barriers ........................................................................................... 16
Table 10: Cost Considerations .................................................................................................................. 17
Table 11: Benefits and Distribution of Benefits and Cost ........................................................................ 18



Page 1 of 19               DRAFT Asphalt Roofing Manufacturing White Paper                                          Portland Air Toxics Solutions
Introduction

The purpose of this document is to evaluate potential emission reduction strategies for asphalt roofing
manufacturing in the PATS study area. For the asphalt roofing manufacturing source category, one
strategy was evaluated.
Section I describes the asphalt roofing manufacturing source category and the magnitude and type of
emissions from the manufacturing process, summarizes the modeling conclusions regarding degree of
contribution of asphalt roofing manufacturing to times above benchmark, describes the emission
reductions needed, and describes the spatial extent.
Section II summarizes existing emission reduction measures.
Section III provides three tables that summarize the strategy evaluation, provide an overview of
emission reduction measures evaluated, and list the strategies that were considered, but not evaluated.
Section IV provides a detailed narrative of the strategy and describes the strategies’ impact on the
primary considerations as requested by the advisory committee: magnitude, timeframe, other pollutants,
technical feasibility, and cost.
Section V contains additional details on the full range of considerations for each strategy as requested
by the advisory committee.




Page 2 of 19     DRAFT Asphalt Roofing Manufacturing White Paper            Portland Air Toxics Solutions
I.     SOURCE CATEGORY: Asphalt Roofing Manufacturing

A. Source Category Description
The asphalt roofing manufacturing source category (SIC 2952, NAICS 324122) consists of facilities that
use a fibrous substrate and processed asphalt to manufacture roofing products. Facilities in this source
category may manufacture shingles, laminated shingles, mineral-surfaced roll roofing, or saturated felt
roll roofing. Asphalt roofing facilities may also have collocated asphalt processing operations, such as
an asphalt blowing still, that prepares the asphalt raw material for application to the substrate.
A.1.      Asphalt Roofing Manufacturing in the PATS Area
This source category included projected 2017 emissions from a total of three facilities. A total of 12
PATSAC HAP species, primarily organic HAP, were represented in the emissions from the asphalt
roofing manufacture source category. The reduction strategy for this source category can provide
emission reductions for the organic HAP species.

The 2017 inventory includes three asphalt roofing manufacturing facilities: GS Roofing Products
Company, Owens-Corning Corporation, and Malarkey Roofing Company. None of these facilities have
collocated asphalt processing operations. Oregon DEQ determined that each of these facilities qualified
for a standard air contaminant discharge general permit, and none of them are major sources of HAP
emissions. One facility has the potential to emit volatile organic compounds (VOC), a criteria pollutant
and ozone precursor, over the 100 ton per year threshold for a major source, but has taken a federally
enforceable limit on VOC emissions and is recognized as a minor source of criteria pollutants. The
2017 projected emissions from asphalt roofing manufacturing are presented in Table 1.



     Table 1. 2017 Predicted HAP Emissions for Asphalt Roofing Manufacturing Source Category
                                          (pounds/year)
                                                                                                                   1,4-Dichlorobenzene




                                                                                                                                                                                                            Methylene Chloride




                                                                                                                                                                                                                                                       Perchloroethylene

                                                                                                                                                                                                                                                                           Trichloroethylene
                                                                                                                                                                          Formaldehyde
                                                                                                     Chromium VI
                                                                           1,3-Butadiene




                                                                                                                                         Diesel PM2.5
                         Acetaldehyde




                                                                                                                                                        Ethylbenzene




                                                                                                                                                                                                Manganese



                                                                                                                                                                                                                                 Napthalene
                                                                                           Cadmium
                                           Acrolein




                                                                 Benzene
               15-PAH




                                                      Arsenic




                                                                                                                                                                                                                                              Nickel
                                                                                                                                                                                         Lead




Subcategory
Total –          5      659             1,492         0.4       627                          5                                                          70             4,374             11     74                               36           15


A.2.      Asphalt Roofing Manufacturing Devices
Asphalt roofing is manufactured by applying asphalt to a fiber mat substrate. The following types of
roofing products are manufactured by asphalt roofing lines: shingles, laminated shingles, smooth-
surfaced roll roofing, mineral-surfaced roll roofing, and saturated felt roll roofing. The process steps
include asphalt heating, asphalt and filler mixing, application to substrate by coating or impregnation
(using coaters or saturators and wet loopers), surface granule application, adhesive and sealant
application, and cutting and packaging operations. While not present at the three facilities identified in


Page 3 of 19            DRAFT Asphalt Roofing Manufacturing White Paper                                                                                                                   Portland Air Toxics Solutions
this study, asphalt roofing manufacturing plants may have a collocated asphalt processing plant that
oxidizes asphalt to increase the softening temperature to make it suitable for use in manufacturing
roofing products. This procedure typically is performed in a blowing still, where air is bubbled through
the heated asphalt raw material. However, for the three facilities in this source category, the asphalt is
processed at other off-site locations and delivered to the facility to manufacture roofing products. There
is also ancillary equipment, such as storage tanks for processed asphalt, asphalt loading racks and
storage silos for granules and fillers associated with the asphalt roofing manufacturing process.

Asphalt is produced from the heavy “bottoms” fractions generated during crude oil distillation, and
consists of a mix of heavy organic compounds. Therefore, emissions from this source category are
mostly organic compounds, including organic HAP such as formaldehyde and acrolein, that have
volatilized from asphalt, and PM that has formed when organic vapors condense upon cooling
(condensed PM) (Federal Register, 2001). Emissions from asphalt roofing manufacturing are typically
associated with the handling, and application of asphalt to the substrate. Metal HAP emissions, vastly
smaller than the organic HAP emissions, may be generated from combustion sources. Mineral handling
and mixing operations are not expected to be sources of HAP emissions.


B. Modeling Results: Degree of Contribution and Emission Reductions Needed.
B.1.   Description of emissions/2017 modeling results from asphalt roofing manufacturing
Table 2 shows the various pollutants that are attributed to asphalt roofing manufacturing in the PATS        Deleted: ¶
domain and identifies the reduction targets for the specific PATS pollutants. The targets represent the
reductions needed to meet ambient benchmark concentrations for asphalt roofing manufacturing
facilities (not considering background concentrations). The reduction targets were developed based on
commensurate reductions from all source sectors – point, area, and mobile – at the most impacted
receptor near each source.
Whereas Table 1 lists all pollutants attributed to the asphalt roofing manufacturing source category,
table 2 below represents the asphalt roofing manufacturing source categories contribution to benchmark
exceedances. The additional emissions denoted in Table 1 are from industrial fuel use at asphalt roofing
manufacturing and are accounted for in the industrial fuel use white paper.


                  Table 2: Reduction Targets for Asphalt Roofing Manufacturing

                                                               Projected 2017 emissions from
                                    Range of Reduction         asphalt roofing manufacturing
 Times Above                              Targets               contributing to benchmark
  Benchmark        Pollutant         in lbs & (percent)              exceedances (lbs)
More than 10    Benzene                     457                              505
times above                                 (91)
benchmark
                15 PAH                       1.5                               2
                                            (88)




Page 4 of 19     DRAFT Asphalt Roofing Manufacturing White Paper            Portland Air Toxics Solutions
A data quality analysis was performed for all source categories. The data quality rating for asphalt
roofing manufacturing was determined to be an A rating (Excellent).
To see details on each of the pollutants, please see October 27, 2010 presentation at the advisory
committee meeting, available at:
http://www.deq.state.or.us/aq/toxics/docs/pats/armitageIntroPATS.pdf
B.2.   Main risk drivers
Some pollutants emitted by asphalt roofing manufacturers may be risk drivers for the PATS study area
as a whole, but the facilities only contribute significantly to risk in their immediate vicinity.

Benzene and 15-PAH are both pollutants that have exceedances that are more than 10 times above the
benchmark. Asphalt roofing manufacturing contributes to the emissions of these two main risk drivers
in the PATS study area.

C. Source Category Effect on Distribution of Emissions
The emissions of benzene, 15-PAH, and formaldehyde contribute to the exceedances in localized impact
areas near the asphalt manufacturing facilities. While their contribution may be significant to these
pollutants in the area immediately surrounding the facilities, these pollutants are dominated by other
sources that are dispersed throughout the study area.

To see details on each of the pollutants, please see January 25, 2011 presentation at the advisory
committee meeting, available at
http://www.deq.state.or.us/aq/toxics/docs/pats/1_25_11analysisPresentation.pdf




Page 5 of 19     DRAFT Asphalt Roofing Manufacturing White Paper            Portland Air Toxics Solutions
II. SUMMARY OF EXISTING EMISSION REDUCTION STRATEGIES
Emissions from asphalt roofing manufacturing processes generally originate from asphalt handling, and
application, and to a lesser degree, asphalt storage and sand and mineral filler handling processes.
Because the HAP volatilized from asphalt generally have low boiling points, they can be present in both
condensed particulate matter (PM) and gaseous forms, depending on the temperature of the vent or
exhaust gas. When the temperature of the vent gas is below the boiling point of a HAP, the HAP will
condense into particulate form (i.e., a cooler vent gas will have more HAP in the form of condensed PM,
whereas a hotter vent stream will contain mostly gaseous HAP). Emissions from mineral handling
components of the asphalt roofing manufacturing process consist primarily of PM in the form of mineral
dust and existing control strategies have specifically addressed this type of emission. Control measures
currently in place have stemmed from various federal and state regulations and permitting conditions.
These measures are summarized below.

A. Measures for Asphalt Roofing Manufacturing Processes
   Federal
      New Source Performance Standards: Asphalt Roofing Manufacture, 40 CFR Part 60, subpart
      UU. In 1982, U.S. EPA promulgated the Asphalt Roofing Manufacture NSPS that applies to
      saturators and mineral handling and storage processes at asphalt roofing plants that commence
      construction or modification after November 18, 1980. The standards establish numeric limits
      for particulate matter, which are typically controlled with high-efficiency fabric filter bed control
      devices for asphalt saturators and storage vessels, and fabric filter baghouses for mineral
      handling and storage processes. Note the NSPS also applies to blowing stills used to process
      asphalt flux to make it suitable for roofing product manufacturing; however, none of the three
      facilities identified in the PATS area perform asphalt processing.
      New Source Performance Standards: Volatile Organic Storage Vessels (including Petroleum
      Liquid Storage Vessels) For Which Construction, Reconstruction or Modification Commenced
      After July 23, 1984, 40 CFR Part 60, subpart Kb. Promulgated in 1987, with subsequent
      amendments in 1989, 2000 and 2003, this standard applies to storage vessels used to store
      volatile organic liquids. The regulation has specific size and vapor pressure thresholds for
      applicability. The vapor pressures of asphalt storage tanks will likely be below the threshold for
      applicability. If applicable to a tank, however, the regulation requires controls on tank vents to
      reduce volatile organic compound (VOC) emissions, such as floating roofs, or routing tank
      emissions to a closed vent system and control device (e.g., flare).
      National Emission Standards for Hazardous Air Pollutants: Asphalt Processing and Asphalt
      Roofing Manufacture, 40 CFR Part 63, subpart LLLLL (68 FR 24561). On May 7, 2003, U.S.
      EPA republished final HAP standards for asphalt processing and asphalt roofing manufacturing.
      The standards include emission limits for total hydrocarbons (for existing and new facilities that
      process asphalt with a blowing still) and PM from asphalt roofing manufacturing lines. For total
      hydrocarbon control, the strategy consists of capturing emissions and routing them to a
      combustion device, such as a thermal oxidizer, flare, boiler, or process heater. Particulate matter
      control strategies include high-efficiency air filters, fabric filter baghouses, and electrostatic
      precipitators. The NESHAP applies to major sources, with an individual HAP emission greater
      than 10 tons per year, or total HAP emissions exceeding 25 tons per year. None of the three
      asphalt roofing manufacturing facilities in the PATS area qualify as major sources of HAP
      emissions, and therefore, the NESHAP for major sources does not apply.


Page 6 of 19    DRAFT Asphalt Roofing Manufacturing White Paper             Portland Air Toxics Solutions
       National Emission Standards for Hazardous Air Pollutants for Area Sources: Asphalt Processing
       and Asphalt Roofing Manufacturing, 40 CFR Part 63, subpart AAAAAAA. On December 2,
       2009, U.S. EPA promulgated the NESHAP for area sources in the asphalt processing and asphalt
       roofing manufacturing source category (74 FR 63236). The area source NESHAP establishes
       emission limits for PAH (or alternative emission limits for PM) for asphalt processing operations
       and roofing product manufacturing operations. The PM limit ensures that equivalent PAH
       emissions reductions are being achieved. The three asphalt roofing manufacturing facilities
       identified in the PATS area are subject to the area source NESHAP for asphalt roofing
       manufacturing. The control strategy to meet the NESHAP limits consists of routing roofing line
       vents (saturators, wet loopers, coaters, and coating mixers) to PM control devices, typically high-
       efficiency fiber bed filter control devices which achieve co-control of PAHs and PM emissions.

   State of Oregon
       Oregon has adopted by reference the federal NSPS standards (40 CFR Part 60, subparts UU and
       Kb) listed above in OAR 340-238-0060(3)(yy) and (q) respectively. The major source NESHAP
       (40 CFR Part 63, subpart LLLLL) is also adopted by reference in OAR 340-244-0220(qqqq). At
       the time of this writing, the area source NESHAP (40 CFR Part 63, subpart AAAAAAA) has not
       been reflected in the state codes under OAR 340-244-0220 (the compliance date for existing
       affected sources was December 2, 2010). However, facility permits indicate reserved sections
       where the applicable area source NESHAP requirements may be added, indicating intent of the
       state to adopt the area source NESHAP. No additional state regulatory requirements have been
       established for the asphalt roofing manufacturing source category.

   Local
       These sources are located in the Portland AQMA, which has emission standards for VOC point
       sources in place (OAR 340-232-0010). However, the emission standards do not list asphalt
       roofing manufacturing as one of the regulated sources. Therefore, this rule does not apply to this
       source category. Permits do not indicate any further local regulations that apply to the three
       sources in the PATS area.




Page 7 of 19    DRAFT Asphalt Roofing Manufacturing White Paper            Portland Air Toxics Solutions
   III.          SUMMARY OF POTENTIAL NEW EMISSION REDUCTION MEASURES
          DEQ has evaluated one strategy for reducing emissions from asphalt roofing manufacturing. The
          strategy evaluated, results of the evaluation, and other strategies considered are summarized in this
          section. Detailed strategy descriptions and evaluations can be found in sections IV and V.

   A. Narrative Overview of Strategies Evaluated
          The strategy evaluated is the establishment of emission standards for PAH and formaldehyde.
          Currently, PM emission limits for process emissions are in place at facilities in this source category.
          Sources are typically able to meet these limits using PM control devices, such as high-efficiency fiber
          bed filters. The evaluated control strategy would replace filtration-type PM control devices with thermal
          oxidation of the process vent streams as the control for not only PM, but also vapor-phase organic HAP
          emissions.



   B. Summary of Strategies Evaluated
          The strategy under consideration at the blueprint and brainstorm list levels is listed in Table 3. For
          convenience, the strategy is referred to as “Thermal oxidation” in the subsequent tables and narrative
          discussions. Table 4 identifies the expected emission reductions for each HAP species due to each of
          the emission reduction strategies, while Table 5 qualitatively describes the potential associated ozone
          precursor, fine particulate, and greenhouse gas emission reductions. Finally, Table 6 describes,
          wherever possible, the timeframe to reduce emissions, the technical feasibility, and total cost summary
          for each emission reduction strategy.

                                Table 3: Blueprint and Brainstorm List Strategies

                    Blueprint Level Strategy           Brainstorm List Strategy
                    Emission standards (for PAH        #1 Thermal oxidation (Require PM and
                    and formaldehyde)                  VOC controls beyond the NSPS on
                                                       asphalt storage tanks, blowing stills,
                                                       saturators, coater-mixer tanks, and
                                                       coaters)




Page 8 of 19       DRAFT Asphalt Roofing Manufacturing White Paper             Portland Air Toxics Solutions
                                           Table 4: PATS Pollutants Emission Reductions from Each Strategy

                                                                                                           Emissions Reduced from Each Strategy
                                                                                                                     In lbs and (percent)




                                                                                                                                     1,4-Dichlorobenzene




                                                                                                                                                                                                                           Methylene Chloride




                                                                                                                                                                                                                                                                      Perchloroethylene

                                                                                                                                                                                                                                                                                          Trichloroethylene
                                                                                                                                                                                         Formaldehyde
                                                                                           1,3-Butadiene




                                                                                                                       Chromium VI




                                                                                                                                                           Diesel PM2.5
                                           Acetaldehyde




                                                                                                                                                                          Ethylbenzene




                                                                                                                                                                                                               Manganese




                                                                                                                                                                                                                                                Napthalene
                                                                                                             Cadmium
                                                          Acrolein




                                                                                 Benzene
                                  15-PAH




                                                                     Arsenic




                                                                                                                                                                                                                                                             Nickel
                                                                                                                                                                                                        Lead
 Strategy
#1 – Thermal oxidationa        2                                               480                                                                                                                                                                                                                            Deleted: 4
                               (95)                                            (95)                                                                                                                                                                                                                           Deleted: 626¶
                                                                                                                                                                                                                                                                                                              (95)
a
 Reduction estimates assume all anticipated 2017 emissions are captured and routed to control device. Percent reduction is expected efficiency of the                                                                                                                                                         Deleted: 1,417¶
control device.                                                                                                                                                                                                                                                                                               (95)
                                                                                                                                                                                                                                                                                                              Deleted: 0¶
                                                                                                                                                                                                                                                                                                              (0)
                                                                                                                                                                                                                                                                                                              Deleted: 596
                                                                                                                                                                                                                                                                                                              Deleted: 0¶
                                                                                                                                                                                                                                                                                                              (0)
                                                                                                                                                                                                                                                                                                              Deleted: ¶
                                                                                                                                                                                                                                                                                                              Deleted: ¶
                                                                                                                                                                                                                                                                                                              Deleted: 66¶
                                                                                                                                                                                                                                                                                                              (95)
                                                                                                                                                                                                                                                                                                              Deleted: 4,155¶
                                                                                                                                                                                                                                                                                                              (95)
                                                                                                                                                                                                                                                                                                              Deleted: 0¶
                                                                                                                                                                                                                                                                                                              (0)
                                                                                                                                                                                                                                                                                                              Deleted: 0¶
                                                                                                                                                                                                                                                                                                              (0)
                                                                                                                                                                                                                                                                                                              Deleted: 34¶
                                                                                                                                                                                                                                                                                                              (95)
                                                                                                                                                                                                                                                                                                              Deleted: 0¶
                                                                                                                                                                                                                                                                                                              (0)



Page 9 of 19    DRAFT Asphalt Roofing Manufacturing White Paper                                                        Portland Air Toxics Solutions
                                                Table 5: Other Pollutants Reduced by Each Strategy

                                                         Emissions Reduced from Each Strategy
                                                                   In lbs and (percent)



                                              Fine Particulate



                                                                   Greenhouse
                                 Precursors



                                              (PM2.5)
                                 Ozone




                                                                   Gases
 Strategy                                                       Notes
#1 – Thermal oxidation        342,000a                         Thermal oxidizers would reduce VOC
                                                                 Increase
                              (95)                             emissions but generate greenhouse gases
                                                               (e.g., CO2 and N2O), as well as small
                                                               amounts of fine particulate.
a
  Maximum reduction potential based on 95% reduction of plant site emission limits (PSEL) for VOC.




Page 10 of 19   DRAFT Asphalt Roofing Manufacturing White Paper                 Portland Air Toxics Solutions
         Table 6: Summary of Strategies Evaluated: Timeframe, Technical Feasibility, and Cost

Blueprint level
                                                Timeframe to              Technical
                           Strategy          Reduce Emissions            Feasibility         Cost Summary
Emission            #1 – Thermal oxidation   The time required    Facilities were          From the major
standards (for                               to permit and        expected to be able to   source NESHAP
PAH and                                      install a thermal    meet area source         preamble: cost-
formaldehyde)                                oxidizer can be      NESHAP (40 CFR           effectiveness of
                                             significant. The     Part 63, subpart         controlling roofing
                                             major source         AAAAAAA) PM              line emissions
                                             NESHAP (40 CFR       limits (surrogate for    using thermal
                                             Part 63, subpart     PAHs) using existing     oxidation =
                                             LLLLL) allowed 3     PM control devices       $559,000 per ton
                                             years for existing   (i.e., fiber-bed         of HAP.
                                             sources to install   filters).                NOTE: The use of
                                             thermal oxidizers                             thermal oxidizers
                                             on roofing line                               was rejected for
                                             equipment.                                    new sources due to
                                                                                           high cost-
                                                                                           effectiveness
                                                                                           values. The major
                                                                                           source NESHAP
                                                                                           also rejected the
                                                                                           beyond-the-floor
                                                                                           option of
                                                                                           controlling
                                                                                           existing roofing
                                                                                           line emissions
                                                                                           using thermal
                                                                                           oxidation due to
                                                                                           high cost-
                                                                                           effectiveness
                                                                                           values.




Page 11 of 19     DRAFT Asphalt Roofing Manufacturing White Paper        Portland Air Toxics Solutions
   C. Other Measures Considered
   The following strategies were also considered as being potential emission reduction measures available for
   the asphalt roofing manufacturing source category, but were not evaluated as a new emission reduction
   strategy.
           Emission standards (for PAH and formaldehyde) – lower applicability thresholds to include smaller
           sources. This strategy was not evaluated because the area source NESHAP for this source category
           does not contain applicability thresholds. Therefore, asphalt roofing manufacturing sources that are
           not subject to the major source NESHAP (40 CRF Part 63, subpart LLLLL) are subject to the area
           source NESHAP (40 CFR Part 63, subpart AAAAAAA) and were to be in compliance with these
           standards by December 2, 2010. As pointed out above, the three sources identified in the PATS area
           are subject to the area source NESHAP for asphalt roofing manufacturing.
           Reduce use – review asphalt use and its applications. This strategy is not only a pollutant prevention    Comment [A1]: PATSAC member feedback to
                                                                                                                     address the demand reductions.
           technique, but also a cost savings measure. In fact, U.S. EPA has acknowledged that market-driven
           process changes have already accounted for significant asphalt reductions in the roofing
           manufacturing industry (Federal Register, 2009). These reductions have come from the change in
           industry from felt substrates to fiberglass mat substrates, which require less asphalt application. We
           would expect that facilities would continue to research techniques and practices to help reduce the
           amount of raw materials consumed in product manufacturing. However, we are unable to determine
           if any further improvements are possible at each facility, much less be able to quantify the potential
           emissions reductions that could be achieved and associated costs for the three facilities identified in
           the PATS area in this source category.
           Review the use of filters or thermal oxidizers on asphalt storage tanks as a means for emission
           reductions




Page 12 of 19   DRAFT Asphalt Roofing Manufacturing White Paper            Portland Air Toxics Solutions
   IV. DETAILS FOR EACH POTENTIAL NEW EMISSION REDUCTION MEASURE
   The five primary considerations below are from the PATSAC Considerations List.
   (reference: http://www.deq.state.or.us/aq/toxics/docs/pats/3_2_11regroupedConsideraton.pdf)

   A. Strategy #1: Thermal oxidation (Require PM and VOC controls beyond the NSPS on asphalt
   storage tanks, blowing stills, saturators, coater-mixer tanks, and coaters)
   Narrative Overview
   This strategy is the only technically available new emission reduction measure available that can be
   evaluated for this source category. In fact, the major source NESHAP requires thermal oxidation as a
   control for new asphalt roofing manufacturing process vents, and existing and new source asphalt
   processing vents. Therefore, the technology is available, but is only required of major sources of HAP
   emissions in this source category. As noted earlier, the three sources in the PATS area are minor sources
   and are not subject to the major source NESHAP requirements. Furthermore, none of these sources operates
   a blowing still for asphalt processing.
   The control strategy would entail collecting and routing emissions from asphalt storage tanks, blowing stills
   (if any are ever constructed in the PATS area), saturators, mixing tanks, and coaters to a thermal oxidation
   device, such as a boiler, process heater, flare, or regenerative thermal oxidizer.


   Primary Considerations
   a. Magnitude of Reductions. Based on the control efficiency requirements for total hydrocarbons in the
   major source NESHAP (40 CFR Part 60, subpart LLLLL), 95 percent of total hydrocarbons should be
   possible, and is the level required by the federal regulation. In practice, the emission reductions would        Comment [A2]: Analysis by the Contractor
                                                                                                                    assumed all emissions in Table 1were from asphalt
   likely be less than 95 percent, since capture and control of all of the anticipated emissions may not be         manufacturing, whereas most emissions in Table 1
   possible (i.e., depending upon the collection efficiency). This assumes that thermal oxidation will not affect   are from the industrial fuel use at these facilities. The
                                                                                                                    White Paper and tables have been adjusted to take
   emissions of metal HAP.                                                                                          into account actual emission from asphalt roofing
                                                                                                                    manufacturing.
   b. Timeframe to Implement. As there are no current regulations that require thermal oxidation for the three
                                                                                                                    Deleted: For this evaluation, we have assumed this
   existing sources, there should be ample time to consider regulation and for sources to investigate control       level of reduction for the organic species in the 2017
   strategies, purchase equipment, and perform installation and break-in of new control equipment. In similar       projected emissions inventory. In total, about 6,900
                                                                                                                    pounds per year (3.4 tons per year) of PATS
   situations for existing major source asphalt roofing manufacturing sources, the NESHAP (40 CFR Part 60,          pollutant emissions could be reduced if all of the
   subpart LLLLL) allows three years for compliance with the standards. Considering this action would be a          2017 emissions were routed to a thermal oxidation
                                                                                                                    control device.
   regulatory requirement beyond those adopted and implemented by the state, there would likely be additional
   implementation time required for regulatory development and public comment.

   c. Other pollutants reduced. Thermal oxidation will reduce organic HAP emissions, as well VOC and PM
   emissions from asphalt roofing manufacturing processes. The level of PM emission reductions are expected
   to be similar to those of the currently employed particulate control devices. However, thermal oxidation
   will also control vaporous organic compounds that may further condense into PM in the atmosphere, so
   there may be some additional PM control. We are unable to quantify these additional reductions. VOC
   reductions are possible as well, and thermal oxidation is capable of reducing VOC emissions by 95 percent.
   Assuming the VOC plant specific emission limits (PSEL) for the three facilities, complete capture of VOC
   emissions, and a 95 percent reduction, up to 342,000 pounds per year of VOC could be reduced with the
   thermal oxidation control strategy. However, if the actual VOC emissions are much lower than the PSEL,
   these emission reduction potentials decrease also. Greenhouse gas emissions, such as N 2O and CO2 will
   increase due to thermal oxidation, especially if the thermal oxidation device requires supplemental fuel to
   maintain proper combustion.
Page 13 of 19   DRAFT Asphalt Roofing Manufacturing White Paper            Portland Air Toxics Solutions
   d. Technical feasibility. As noted above, thermal oxidation is technically feasible and is required of new
   major source facilities in this source category. If the thermal oxidation device, such as a regenerative
   thermal oxidizer, is used, then the facility will require a natural gas supply line if one is not currently
   available.
   e. Cost. This control strategy would most likely be implemented as a regulatory requirement above those
   currently required in state and federal regulations. The federal major and area source NESHAPs for this
   source category (40 CFR Part 63, subparts LLLLL and AAAAAAA, respectively) have investigated thermal
   oxidation for asphalt roofing manufacturing processes, and for area sources such as the three facilities in the
   PATS area, have determined the strategy to be a “beyond the MACT floor” option. In other words, this
   control strategy is more stringent than that required by the Clean Air Act. Therefore, costs were considered
   in deciding whether regulations based on the use of this control was warranted. In the case of area sources
   such as these, thermal oxidation requirements were not adopted based primarily on cost. According to the
   major source NESHAP evaluation (Federal Register, 2001), a cost-effectiveness of thermal oxidation is on
   the order of $559,000 per ton of HAP reduced.




Page 14 of 19   DRAFT Asphalt Roofing Manufacturing White Paper            Portland Air Toxics Solutions
    V. ATTACHMENTS
    Attachment A: Considerations [To be filled out by PATSAC/DEQ]
    This list of considerations will be used by PATSAC as an informal tool to understand toxics reduction strategies. If the committee chooses, it
    may also use these considerations to shape its recommended package of strategies or implementation steps. The tables below are cross-walked to
    the Committee’s Considerations reference (DEQ web link below). For example, in Table 8, consideration 1.c. Effect on Exposure, refers to
    consideration 1.c in the Committee’s full considerations list.

    Considerations (reference: http://www.deq.state.or.us/aq/toxics/docs/pats/3_2_11regroupedConsideraton.pdf)



                                                           Table 7: Blueprint and Brainstorm List Strategies

                                            Blueprint Level Strategy                 Brainstorm List Strategy
                                            Emission standards (for PAH              #1 Thermal oxidation (Require PM and
                                            and formaldehyde)                        VOC controls beyond the NSPS on
                                                                                     asphalt storage tanks, blowing stills,
                                                                                     saturators, coater-mixer tanks, and
                                                                                     coaters)




                                                                             Table 8: Effectiveness

                  Strategy                                      1.c. Effect on Exposure1                                        1.d. Pollution Prevention2
#1 – …




1
  Effect on exposure: How well does the measure target spatial extent of the emissions? Some reductions may have more pronounced effects on localized concentrations; others
may do more to reduce pollutants area-wide. (OAR 340-246-0170 4(g)). Ability to address short term or acute exposures if relevant.
2
  Pollution prevention: Where does the strategy fit in the pollution prevention hierarchy? 1. Modify the process, raw materials, or product to reduce the quantity and toxicity of air
contaminants generated. 2. Capture and reuse air contaminants. 3. Treat to reduce the quantity and toxicity of air contaminants released. (OAR 340-246-0050)
Page 15 of 19       DRAFT Asphalt Roofing Manufacturing White Paper                        Portland Air Toxics Solutions
                                                          Table 9: Implementation/Feasibility Barriers

                                                                                                     2.d.                                           2.f. Non-regulatory
           Strategy                  2.a. Legal Authority3             2.c. Funding4            Implementation5            2.e. Acceptance6             Approaches7
#1 – …




3
  Legal authority: Does the measure fall under existing regulations or are new laws/ rules required? Does federal pre-emption preclude new laws/rules? Is/will the proposed
    measure be addressed through other planned Federal, state, or local rulemaking or other processes?
4
  Funding: What is the cost to DEQ or other agency to implement the measure? How could the agency cost be funded? How certain is the funding mechanism?
5
  Implementation: Is there a ready structure for implementation or ability to coordinate with existing programs?
6
  Acceptance: Is there public and stakeholder support for the measure?
7
  Non-regulatory approaches: Could the measure be implemented through incentives or education? Is there an opportunity to implement the measure through a community-based
    multi-stakeholder collaborative process? Could the measure begin as voluntary and later become mandatory as necessary in a contingency plan?

Page 16 of 19      DRAFT Asphalt Roofing Manufacturing White Paper                    Portland Air Toxics Solutions
                                                                        Table 10: Cost Considerations

                                                               3.c. Other
                                    3.b. Cost                Environmental                                                                              3.f. Indirect Economic
         Strategy                 Effectiveness8               Impacts9                       3.d. Energy10               3.e. Public Safety11                   Costs12
#1 – …




8
  Cost effectiveness: What is the cost per unit of air toxics reduced?
9
  Other environmental impacts: Potential for the emission reduction measure to transfer pollutants to soil or water, or cause harm to human health or the ecosystem.
10
   Energy: Effect of measure on energy use.
11
   Public safety: What is the affect of the measure on public safety? For example, would emission reductions restrict activities related to adequate lighting, heat, ventilation,
     signage or access to emergency services?
12
   Indirect economic costs: What are the potential indirect costs to communities, the local economy or business sectors?

Page 17 of 19       DRAFT Asphalt Roofing Manufacturing White Paper                         Portland Air Toxics Solutions
                                                    Table 11: Benefits and Distribution of Benefits and Cost

                     Benefits                                                                                      Distribution of Benefits and Cost
                                                                                        4.c. Indirect                     5.a. Risk               5.b. Cost
    Strategy               4.a. Health13                4.b. Livability14            Economic Benefits15               Distribution16           Distribution17
#1 – …




 13
    Health: What are the health benefits of meeting the benchmarks? This could be measured as the number of cancer cases avoided and/or value of statistical life and medical
         costs avoided.
 14
    Livability: Improved quality of life associated with improved nuisance conditions such as odor or noise.
 15
    Indirect economic benefits: What are the potential benefits to communities, the local economy or business sectors?
 16
    Risk distribution: Could the measure change the social distribution of risk in the PATS area, i.e. sensitive populations and environmental justice communities?
 17
    Cost distribution: Could the measure impose disproportionate costs or economic impacts to environmental justice communities in the PATS study area?

Page 18 of 19     DRAFT Asphalt Roofing Manufacturing White Paper                       Portland Air Toxics Solutions
VI. References

Federal Register, 2001. “National Emission Standards for Hazardous Air Pollutants: Asphalt Processing and
Asphalt Roofing Manufacturing; Proposed Rule”. 66 FR 58609-58642. November 21.

Federal Register, 2009. “National Emission Standards for Hazardous Air Pollutants for Area Sources: Asphalt
Processing and Asphalt Roofing Manufacturing; Final Rule”. 74 FR 63235-63266. December 2.




Page 19 of 19   DRAFT Asphalt Roofing Manufacturing White Paper         Portland Air Toxics Solutions

				
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