EPA-450/2-74-019a
     BACKGROUND INFORMATION
FOR  STANDARDS  OF  PERFORMANCE:
 PHOSPHATE FERTILIZER INDUSTRY
VOLUME  1:  PROPOSED STANDARDS
          Emission Standards and Engineering Division
          U.S. ENVIRONMENTAL PROTECTION AGENCY
             Office of Air and Waste Management
          Office of Air Quality Planning and Standards
          Research Triangle Park, North Carolina 27711

                    October 1974

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This report is issued by the Environmental Protection Agency to report
technical data of interest to a limited number of readers.  Copies are
available free of charge to Federalemployees, current contractors and ,
grantees, and nonprofit  organizations - as supplies permit - from the Air
Pollution Technical Information Center, Environmental Protection Agency,
Research Triangle Park, North Carolina  27711; or, for a fee, from the
National Technical Information Service, 5285 Port Royal Road, Springfield,
Virginia 22161.
                  Publication No.  EPA-450/2-74-019a
                                   II

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                             PREFACE
 A-   Pur p o s e of t h js Report
      Standards of performance under section 111  of the Clean
 Air Act-/ are proposed only after a very detailed investigation
 of air pollution1 control 'methods available.to the affected       ,
 industry and the impact of their costs on'the "industry.  This
 report summarizes the information obtained from such a study
 of the phosphate 'fertilizer industry.  It is being distributed in
 'connection with formal proposal of standards for that industry
 in the- Federal' Register.- Its purpose is to explain.the
 background and ba'sis of  the proposal in "greater detail than
 could  be included in the Federal Register, and to facilitate
 analysis of the proposal by interested persons, including those
 who may not be. fami! i-ar  with the many technical aspects of the
 industry.  For addi'tional information, for copies of documents   ,   -
 (other tKan published  literature)  cited in the Background
 Information Document,  or to comment  on the proposed standards,     ,
 contact Mr. Don  R. Goodwin,"Director, Emission Standards and
' Engineering Division,  United States'  Environmental Protection  •
 Agency, Research Triangle Park, North - Carolina-27711" [(919)688-8146],
 B.  Authority for  the  Standards
       Standards  of  performance  for  new stationary sources are
 promulgated  in  accordance with  section  111"of the Clean Air Act
  (42 USC  1857c-6),  as  amended  in  1970.   Section 111 requires
       !_/   Sometimes  referred to as  "new source  performance
  standards"  (NSPS).
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the establishment of standards of performance for new stationary
sources of air pollution which "... may contribute significantly
to air pollution which causes or contributes to the endangerment
of public health or welfare."  The Act requires that standards
of performance for such sources reflect "... the degree of
emission limitation achievable through the application of the best
system of emission reduction which (taking into account the cost
of achieving such reduction) the Administrator determines has
been adequately demonstrated."  The standards apply only to
stationary sources, the construction or modification of which
commences after regulations are proposed by publication in
the Federal Register.
     Section 111 prescribes three steps to follow in establishing
standards of. performance.
     1.  The Administrator must identify those categories of
         stationary sources for which standards of performance
         will ultimately be promulgated by listing them in the
         Federal Register.
     2.  The regulations applicable to a category so listed must
         be proposed by publication in the Federal Register within
         120 days 'of its listing.  This proposal provides interested
         persons an opportunity for comment.
     3.  Within 90 days after the proposal, the Administrator
         must promulgate standards with any alterations he deems
         appropriate.
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     It is important to realize that standards of performance,
by themselves, do not guarantee protection of health or welfare;
that is, they are not designed to achieve any specific air
quality levels.  Rather, they are designed to reflect best
demonstrated technology (taking into account costs) for the
affected sources.  The overriding purpose of the collective
body of standards is to maintain existing air quality and to
prevent new pollution problems from-developing.
     Previous legal challenges to standards of performance for
Portland cement plants, steam generators, and sulfuric acid
plants have resulted in several court decisions-/ of importance
in developing future standards.  In those cases, the principal
issues were whether EPA:  (1) made reasoned decisions and
fully explained the basis of the standards, (2) made available
to interested part-ies the information on which the standards
were based, and (3) adequately considered significant comments
from interested parties.
     Among other things, the court decisions established:
(1) that preparation of environmental impact statements,is not
necessary for standards developed under section 111 of the Clean
Air Act because, under that section, EPA must consider any
counter-productive environmental effects of a standard in
determining what system of control is."best;" (2) in considering
costs it is not necessary to provide a cost-benefit analysis;
     27Port!ant Cement Association v Ruckelshaus, 486 F. 2nd
375 (D.C. Cir. 1973); Essex Chemical Corp. v Ruckelshaus, 486
F. 2nd 427 (D.C. Cir. 1973).

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(3)  EPA is not required to justify standards that require  different
levels of control in different-industries unless -such  different
standards may be unfairly discriminatory; and (4)  it is
sufficient for EPA to show that a standard can be  achieved
rather than'that it has been achieved by existing  sources.
     Promulgation of standards ,of performance does not prevent
State or local agencies from adopting more stringent emission
limitations for the same sources.  On the contrary section  116
of the Act (42 USC 1857-D-l) makes clear that States and other
political subdivisions may enact more restrictive  standards..  „
Furthermore, for heavily"polluted areas, more stringent-standards  .
may be required under section 110 of the Act (42 USC 1857c-5) in
order to attain or maintain national ambient air quality standards
prescribed under section 109  (42 USC 1857c-4).' Finally, section 116
makes clear that a-State may not adopt or enforce less stringent
standards than those adopted by EPA under section 111.
     Although it is clear that standards of performance should be
in terms of limits on emissions where feasible,-  an alternative
method of requiring control of air pollution is sometimes
necessary.  In some cases physical measurement*bf emissions
from a new source may be impractical or  exorbitantly expensive.

     37'"Standards of performance,' ... refers to the degree of
emission control which can  be achieved through  process changes,
operation changes, direct emission control, or  other methods.  The
Secretary [Administrator] should not make a technical judgment
as to how the standard should be implemented.   He should determine
the achievable limits and let the owner  or operator determine the
most economical  technique to  apply."  Senate Report 91-1196.
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 for example, emissions of hydrocarbons from storage  vessels  for
              '     ~j       :     • '
petroleum liquids are greatest during storage and tank filling/
The nature of the emissions (high concentrations for  short
periods during filling and low concentrations for longer
periods during storage) and the configuration of storage tanks
make direct emission measurement highly impractical.   Therefore,
a more practical approach to standards of performance for
storage vessels has, been equipment specification.
C.  Selection of Categories of Stationary Sources
     Section 111 directs the Administrator to publish and from
time to time revise a  list of categories of sources for which
standards of performance are to be proposed. .A category is to
be  selected  "... if  [the Administrator] determines it may contribute
significantly to air pollution which  causes or contributes to the
endangerment of public health or welfare."
     Since  passage of  the  Clean Air Amendments of 1970, considerable
 attention  has been given  to the  development of  a system for
 assigning  priorities to various  source categories.  In  brief,
 the approach that  has  evolved is  as  follows.
      First,  we  assess  any areas  of emphasis  by  considering the
                                              - •*
 broad EPA strategy for implementing the Clean Air Act.  Often,
 these "areas"  are  actually pollutants which are primarily emitted
 by stationary sources.  Source categories  which emit these
 pollutants are  then  evaluated and ranked by a process involving
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such factors as (1) the level  of emission control  (if any)
already required by State regulations; (2) estimated levels
of control that might result from standards of performance  for the
source category; (3), projections of growth and replacement
of existing facilities for the source category; and (4)  the
estimated incremental amount of air pollution that could be_,
prevented, in a preselected future year, by standards of
performance for the source category.        „         -,.>'..
     After the relative ranking is complete, an estimate
must be made of a schedule of activities required to develop
a standard.  In some cases, it may not be feasible to immediately
develop a standard for a source category with a very high
priority.  This might occur because a program of research
and development is needed or because techniques for sampling
and measuring emissions may require refinement before study
of the industry can be initiated.  The schedule of activities
must also consider differences in the time  required to complete
the necessary  investigation for different source categores.
Substantially more time may be necessary, for example, if  a
number of pollutants must be investigated in a single source
category.   Even late  in the development  process the
schedule  for completion of  a standard may change.   For
example,  inability to  obtain emission data  from

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well-controlled sources in time to pursue the development
process in a systematic fashion may force a change in
scheduling.
     Selection of the source category leads to another major^
decision:  determination of the types of sources or facilities
to which the standard will apply.  A source category often
has several facilities that cause air pollution. -Emissions
from some of these facilities may be insignificant and, at the
same time, very expensive to control.  An investigation of
economics may show that, within the costs that an owner could
reasonably afford, air pollution control is better served by
applying standards to the more severe pollution  problems.  For
this reason  (or perhaps because there may be  no  adequately
demonstrated system  for controlling emissions from certain
facilities), standard's often do not apply to  all  sources within
a category.  For  similar  reasons,  the standards  may  not  apply
to all  air pollutants emitted  by  such sources.   Consequently,
 although  a source category  may be  selected  to be covered by  a
 standard  of performance,  treatment of some  of the pollutants or
 facilities within that  source  category  may  be deferred.
 D.  Procedure  for Development  of Standards  of Performance
      Congress  mandated that sources regulated under section. Ill
 of the Clean Air Act be required to utilize the best practicable
 air pollution control  technology that has been  adequately
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demonstrated at the time of their design and construction.  In so
doing, Congress sought to:
     1.  maintain existing high-quality air,
     2.  prevent new air pollution problems, and
     3.  ensure uniform national standards for new facilities.
     The selection of standards of performance to achieve the
intent of Congress has been surprisingly difficult.  In general,
the standards must (1) realistically reflect best demonstrated
control practice; (2) adequately consider the cost of such control;
(3) be applicable to existing sources that are modified as well
as"new installations; and (4) meet these conditions for all
variations of operating conditions being considered anywhere in
the country.
     A major portion of the program for development of standards
is spent identifying the best system of emission reduction which
"has been adequately demonstrated" and quantifying the emission
rates achievable with the system.  The legislative history of
section 111 and the court decisions referred to above make clear
that the Administrator's judgment of what is adequately demonstrated
is not limited to systems that are in actual routine use.
Consequently, the search may include a technical assessment
of control systems which have been adequately demonstrated but
      ?
for which there is limited operational experience.  To date,
determination of the "degree of emission limitation achievable"
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 has  been commonly based onj (but not  restricted  to)  results
.of tests of emissions^ from existing  sources.  This  has            ,  -  ,-.
 required worldwide investigation and measurement  of emissions
 from control  systems.   Other countries  with  heavily populated,    - 4-
                                                            •
 industrialized areas  have sometimes  developed more  effective
 systems of control than those used in the United  States..     •••.ซ.
      Because the best demonstrated systems of emission  reduction  may
 not  be in widespread  use, the data base upon which  the  standards  ,
 are  established will  necessarily be  somewhat'limited.   Test
 data on existing well-controlled sources are an obvious starting
 point in developing emission limits  for new  sources/. However,
 since the control of  existing sources generally represents
 retrofit technology or was originally designed  to meet  an
 existing State or local regulation,  new sources may be  able
 to meet more stringent emission standards.  Accordingly, other
 information must be considered and judgment  is  necessarily
 involved in setting proposed standards.
      Since passage of the Clean Air Amendments  of 1970, a
 process for the development of a standard has evolved.   In
 general, it follows the guidelines below.
      1.  Emissions from existing well-controlled  sources
          are measured.
      2.  Data on emissions from such sources are  assessed with
          consideration of such factors  as:  (a) the representativeness
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    of the source  tested  (feedstock,  operation, size, age,
    etc.); (b)  the age  and  maintenance  of the control
    equipment tested  (and possible  degradation in the
    efficiency  of  control of similar  new equipment even
    with good maintenance procedures);  (c)  the design
    uncertainties  for the type of control equipment  being
    considered; and (d) the degree  of uncertainty affecting
    the judgment that new sources will  be able to achieve
    similar levels of control.
3.   During development  of the standards,  information from
    pilot and prototype installations,  guarantees by vendors
    of control  equipment, contracted  (but not yet constructed)
    projects, foreign technology, and published  literature
    are considered, especially for sources  where "emerging"
    technology appears  significant.
4.   Where possible, standards are set at a level that is
    achievable with more than one control  technique 'or
    licensed process.
5.  Where possible, standards are set to encourage  (or at least
    permit) the use of process modifications or new processes
    as  a  method of control   rather than "add-on" systems of
    air pollution control.
6.  Where possible, standards are set to permit use of
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         systems capable of controlling more than one pollutant
         (for example, a scrubber can remove both gaseous  and
         particulate matter emissions, whereas an electrostatic
         precipitator is specific to particulate matter).
     7.  Where appropriate, standards for visible emissions are
         established in conjunction with mass emission standards.
         In such cases, the standards are set in such a way that
         a source meeting the mass emission standard will  be able
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         to meet the visible emission standard without additional
                                  )
         controls.  (In some cases, such as fugitive dust, there
         is no mass standard).
     Finally, when all pertinent data are available, judgment
is again required.  Numerical tests may not be transposed  directly
into regulations.  The design and operating conditions of  those
sources from which emissions were actually measured cannot be
reproduced exactly by each new source to which the standard of
performance will apply.
E.  How Costs are Considered
     Section 111 of the Clean Air Act requires that cost be
considered in setting standards of performance?  To do this requires
an assessment of the possible economic effects of implementing
various levels of control technology in new plants within  a
given industry.  The first step in this analysis requires  the
generation of estimates of installed capital costs and annual
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operating costs for various demonstrated control  systems,
each control system alternative having a different overall
control capability.  The final step in the analysis is to
determine the economic impact of the various control  alternatives
upon a new plant in the industry.  The fundamental question to
be addressed in this step is whether or not a new plant would
be constructed given that a certain level of control  costs  would
be Incurred.  Other issues,that would be analyzed in this  step
would be the effects of control costs upon product prices  and the
effects on product and raw material supplies and producer
profitability.
     The economic impact upon an industry of a proposed standard
is usually addressed both in absolute terms and by .comparison
with the control ,costs, that.would be incurred as a result
of compliance with typical existing State control regulations.
This incremental approach is taken since a new plant would
be required "to comply with State regulations in the absence
of a Federal standard of performance.  This approach requires
a detailed analysis of the impact upon the industry resulting
from the cost differential that usually exists between the
standard of performance and the typical State standard.
     It should be noted that the costs for control of air
pollutants are not the only control costs considered.  Total
environmental costs for control of water pollutants as well

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as air pollutants are analyzed wherever possible.
     A thorough study of the profitability and price-setting
mechanisms of the industry is essential to the analysis so
that an accurate estimate of potential adverse economic impacts
can be made.  It is also essential to know the capital requirements
placed on plants in the absence of Federal standards of performance
so that the additional capital requirements necessitated by these
standards can be placed in the proper perspective.  Finally, it
is necessary to recognize any constraints on capital availability
within an industry as this factor also influences the  ability
of new plants to generate the capital  required for  installation
pf the additional control equipment  needed to meet  the standards
of performance.                                ^
      The  end  result  of  the  analysis  is a presentation  of  costs
 and  potential  economic  impacts  for  a series  of control
 alternatives.   This  information is  then  a major  factor which
                  •-    •    -                    t        '-•'••
 the  Administrator considers in selecting a standard.
 F.   Impact on Existing  Sources
      Proposal of standards of performance may affect an  existing
 source in either of two ways.  First, if modified after
 proposal of the standards, with a subsequent increase in
 air pollution, it is subject to standards of performance as
,,if it Were a new source.  (Section  111 of the Act defines a
 new'source as  "any"stationary source, the instruction or
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modlflcation of which is commenced after the regulations are
proposed.")—'
     Second, promulgation of a'Standard of performance requires
States to establish standards of performance for the same pollutant
for existing sources in the same industry under section 111(3) of
the Act; unless the pollutant limited by the standard for new
sources is one listed under section 108 (requiring promulgation of
national ambient air quality standards) or one listed as a
hazardous pollutant under section 112.  If a State does not act,
EPA must establish such standards.  Regulations prescribing
procedures for control of existing sources under section lll(d)
will be proposed as Subpart B of 40 CFR Part 60.
G.  Revision of Standards of Performance
     Congress was aware that the level of air pollution control
ach-ievable by any industry may improve with technological
advances.. Accordingly, section 111 of the Act provides that
                     *
the Administrator may revise such standards from time to time.
Although standards proposed and promulgated by EPA under section 111
are designed to require installation of the "... best system of
emission reduction ... (taking into account the cost)..."
the standards will be reviewed periodically.   Revisions will be
proposed and promulgated as necessary to assure that the standards
     37Specific provisions dealing with modifications to existing
facilities are being proposed by the Administrator under the
General Provisions of 40 CFR Part 60.
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 continue  to  reflect  the  best  systems  that  become  available
 in  the  future.   Such revisions  will not  be retroactive  but
 will  apply to  stationary sources  constructed  or modified  after
 proposal  of  the  revised  standards.
 H.  Why Standards  of Performance  for  Fluorides?
      Two  questions are basic  to the control of  fluorides:  why
 control them and why do  so with section  111?
      The  deleterious effects  of fluoride on both  animals  and
 vegetation have  been extensively  documented.-  The  effect on
 animals is through the digestive  tract when relatively  large
 quantities of  contaminated.vegetation are  ingested.   Citizens,
•both  privately and in groups, have sought  relief  from fluoride
 damage  through suits against  the  alleged industrial  sources.
 In  one  case, a citizens'  group  sent to EPA data which support
 the need  for Federal  regulation of fluorides.   State agencies
 have  recorded  and  acted  on numerous public complaints on  the
                                             T^-
 adverse effects  of fluorides  on the growth, yield, quality, and
 appearance of  marketable goods  such as fruit, grains, leafy
 vegetables,  pine trees,  ornamental plants, and  dairy cattle.
      In determining  that there  is a need to control  fluoride
 emissions into the atmosphere,  the Administrator  relied heavily
 upon  the  report  Fluorides, which  was  prepared for the Agency by
      5/   National  Academy  of  Sciences,  Fluorides,  prepared  for
 EPA  under Contract No.  CPA 70-42,  Washington,  p. C.  20418,  1971
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the National Academy of Sciences in 1971. Jn preparing this
report, the Academy made a concerted effort to evaluate the
world literature on the subject and distill the best scientific
knowledge available on the biological effects of fluorides.
This report concludes:  "Current knowledge indicates that air-
borne fluoride presents no direct hazard to man, except in
industrial exposure.  However, through the commercial, aesthetic,
and ecologic functions of plants, fluoride in the environment
may indirectly influence man's health and well being."  After
considering the available information on fluorides, the Administrator
has concluded that, even though present evidence indicates that
fluorides in the range of ambient concentrations encountered under
worst conditions do not damage human health through inhalation,
they do present a serious risk to public welfare-  and v/arrant
control.  Fluoride emissions affect public welfare not only through
their effects on aesthetic values, but also through a decrease in
the economic value of crops which are damaged by exposure  to
fluorides and through adverse effects on the health of animals
ingesting vegetation which has accumulated excessive amounts of
fluorides.
      ง7As  used  in  the  Clean  Air Act,
 includes, but is  not limited to,  ".  .
 crops,  vegetation, man-made materials,
 visibility,  and climate, damage  to and
 and hazards  to transportation, as well
 and on  personal comfort  and well  being
 42 U.S.C. 1857h(h)  as amended.]
                             xviii
the term  "effects on welfare"
,  effects  on soils, water,
animals,  wildlife, weather,
deterioration of property,
as effects on economic values
," [See section 302(h)

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     Private citizens and citizens'  groups have actively sougnt
means to alleviate fluoride damage.   One citizens'  group, Center
for Science in the Public Interest,  has written the Agency
describing at great length the need for fluoride regulations.
A number of lawsuits have been initiated which are concerned with
fluoride effects on agricultural products, and at least 20
citizens' suits have been filed against aluminum plants that emit
fluorides.
     The Administrator's decision to control fluoride emissions at
the national level was based on the following:
     1.  The present national ambient air quality standards for
         particulate matter,'standing alone, would not provide
         adequate welfare protection against the effects of
         fluoride for two reasons:  (a)  fluorides are emitted
         as both'particulate matter and gases, and (b)  since
         the ambient standard is for "non-specific" particulate
         matter, compliance with that standard would not ensure
         fluoride concentrations sufficiently low to prevent
         damage.
     2.  Although many states have adopted  fluoride control
         regulations, major  sources of  fluoride emissions exist
         in several  states with no fluoride regulations.
     3.  A uniform  national  standard of performance for  new
         sources would discourage movement  of major fluoride
         emitters to states  with no fluoride regulations.
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      4.   Primary aluminum reduction  plants,  one of the major
          sources of fluoride  emissions,  are  commonly located
          near major waterways that comprise  borders between
          states.  The  potential  for  interstate conflict concerning
          control of emissions from such  plants has prompted
          Federal investigations  in the past, and  in at least one
          case a  state  has  requested  initiation of abatement
          conference proceedings  under section 115 of the Act
          [42  U.S.C.  1857d].
      An  EPA report entitled  "Preferred Standards  Path Report for
 Fluorides" (November 1972) contains  a detailed discussion of the
"advantages and disadvantages  of  each regulatory option provided
 to the Administrator under the Act to control fluoride emissions
 on a  national  level.—    In general,  the  Administrator concluded
 that  fluorides should  be regulated under section  111 of the Act
 for the  following reasons:
      1.   In contrast with  the problems presented  by the six
          pollutants  for  which national ambient air quality
          standards have  been  promulgated, the fluoride problem
          is highly localized  in  the  vicinity of major point
          sources in  agricultural  areas and is not complicated
          by the  presence of numerous mobile  sources.  Promulgating
          a national  ambient air  quality  standard  for fluorides
      77A  copy of this  report  is available  for inspection during
 normaT business hours  at the  Freedom of Information Center,
 Environmental  Protection Agency, 401 M Street, S.W., Washington, D. C.
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    under section 109 would require states to submit
    implementation plans to attain and maintain such
    standards.  Because of the complex problems involved
    in relating emissions to ambient levels, most plans
    would include regulations based on best demonstrated
    control technology.  The same result can be accom-
    plished more directly and efficiently through the
    promulgation of standards of performance.
2.  Adopting national standards of performance would be
    more compatible with .existing state regulations than
    adopting ambient air quality standards.
3.  Since accumulation of fluorides during chronic exposure
    to low-level ambient concentrations may result in
    fluoride levels detrimental to either vegetation or to
    the health of animals consuming the vegetation, an
    ambient standard for fluorides may not in fact ensure
    prevention of adverse welfare effects.
4.  An ambient fluoride standard stringent enough to ensure
    complete protection against any welfare effects might
  •  require closure of major sources of fluoride emissions.
    A more practical and feasible approach is to minimize
    fluoride damage through best demonstrated control
    technology; i.e., by regulating fluoride emissions
    under section 111.
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     5.  The National Academy of Sciences report indicates that
         because fluorides present no direct hazard to human
         health, the provisions,of section 112 for controlling
         fluorides as a hazardous air pollutant could not be used.
     Promulgation of the proposed standards of performance for
fluorides will affect existing sources as explained in section F
of this preface.  Of particular note is that states will  be
required to establish standards for the control of fluorides
from existing sources under section lll(d) of the Act.  The
resulting control may not be as stringent as that required by
the standards of performance for new sources.  As indicated
previously, regulations,prescribing procedures for control of
existing sources under section lll(d) will be proposed as Subpart
B of 40 CFR Part 60.
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                      TABLE  OF CONTENTS            \

                                                              Page
Introduction 	  	   1
   Selection of Affected Facilities	   1
   Selection of Pollutants for Control  	   5
   Selection of Units for the Standards	'	   6
   Selection of Sampling and Analytical  Methods	   9
   Selection of Facilities for Source Tests	10
Wet-Process Phosphoric Acid Plants ....  	,	   19
   Summary of Proposed Standard	   19
   Description of Process	  •   20
   Emissions and Methods of Control	  .   22
   Rationale for Proposed Standard .  •	-...-.<....   24
Superphosphoric Acid Plants. . ..-. .  . -: .  ...... >  ....   27
   Summary of Proposed Standard    	•. V ......   27
   Description of Process	27
   Emissions and Methods of Control   .....  	   30
   Rationale for Proposed Standard ... 	   30

Diammonium Phosphate Plants	37
   Summary of Proposed Standards  ......... 	   37
   Description of Process  .	38
   Emissions and Methods of Control	38
   Rationale for Proposed Standard 	   40
Run-of-Pile Triple Superphosphate Plants	   45
   Summary of Proposed Standards  	   45
   Description of Process. ...:......,  	   46
   Emissions and Methods of Control	46
   Rationale for Proposed Standard ....  	   48
Granular Triple Superphosphate Plants. . .  	   53
   Summary of Proposed Standards  	  	   53
   Description of Process	54
   Emissions and Methods of Control   	   54
   Rationale for Proposed Standard   	   56
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                                                             Page
Granular Triple Superphosphate Storage.  	    61
   Summary of Proposed Standards	    61
   Description of Process	•  •    61
   Emissions and Methods of Control  	    53
   Rationale for Proposed Standard	    65

References	, .t	  .    69
Appendix A - The Economic Impact of Standards of
             Performance on the Phosphate
             Fertilizer Industry.  ............."  73
Technical Report Data Sheet ......... i  -.  ...••...   119
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   BACKGROUND INFORMATION FOR PROPOSED STANDARDS OF PERFORMANCE:
                   PHOSPHATE FERTILIZER INDUSTRY
                           INTRODUCTION
Selection of Affected Facilities
The phosphate fertilizer industry is totally dependent on phosphate
rock as its major raw material.  About fifteen .major processes are
used to process phosphate rock into fertilizers and other -products.
Six of the major processes have been selected for the current program.-
Others are planned for inclusion in future programs.
Figure 1 shows the large number of fertilizer products and chemicals
produced from phosphate rock.  After preparation, the rock is used
directly in the production of phosphoric acid, normal superphosphate-,
triple superphosphate, nitrophosphate, electric furnace phosphorus'and
defluorinated animal feed supplements.  Phosphoric acid is an intermediate
material, since it is subsequently consumed in the production of
superphosphates, ammonium phosphates, complex fertilizers, superphosphoric
acid and dicalcium phosphate.
EPA has conducted an extensive study of the industry, including a testing
program to develop standards of performance for emissions from the
following facilities, which are areas of major growth or are major sources
of emissions.

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             FIGURE 1
PHOSPHATE ROCK PROCESSING INDUSTRY

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     1.   Wet-process phosphoric acid
     2.   Superphosphoric acid
     3.   Diammonium phosphate
     4.   Run-of-pile triple superphosphate (production and storage)
     5.   Granular triple superphosphate production
     6.   Granular triple superphosphate storage
These processes are indicated by the  shaded buildings shown in Figure 1.
In selecting the six areas for which  standards were to be developed,
primary considerations were the growth potential  of each process and  the
environmental impact of a standard.  Recent articles in the literature
indicate that production by these processes will  increase by as much  as
                                 234
20 percent over the next 2 years.   '   Table 1 shows projected growth
for wet-process phosphoric acid, ammonium phosphates, and triple
superphosphates of about 70, 90, and  20 percent,  respectively, over the
decade of the seventies.   The environmental impact of these processes is
significant as evidenced by the estimated fluoride emissions shown.
Superphosphoric acid was selected because of its  tremendous growth potential
(150 percent between 1970 and 1980),  even though its collective environmental
impact is not estimated to be as great as that of some of the other processes.
A potential source of large quantities of gaseous fluoride emissions  is ponds
used as cooling and settling basins for process waters.  Water from these
basins, commonly called gypsum ponds, is used to scrub fluorides out of
exit-gas streams from each phosphate fertilizer process.  The fluoride
content of this gypsum pond water ranges from 5,000 to 10,000 parts per million,
and the pond itself appears to be a major source  of fluoride emissions.

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Approximations of these emissions range from 0.16 to 5.0 pounds per acre per
day,9'10 which for a typical 200 acre, pond Is 32 to 1QQO pounds of fluoride per
day.  There is no suitable technique to measure fluoride emissions from
gypsum ponds, but the Environmental Protection Agency is now funding a
research project at North Carolina State University to study emissions from
these ponds.  This background information may permit preparation of
performance standards for gypsum ponds at a later date.
Selection of  Pollutants for Control
In assessing  the environmental  impact of each of the processes for which
standards are now being proposed,  the quantity and  toxicity of emitted
pollutants were considered.  Laboratory analyses performed on samples of
feedstocks, products, byproducts,  and scrubbing liquid did not indicate
significant amounts of heavy metals  such as mercury, beryllium, cadmium,
arsenic,  etc. However, significant  quantities of  fluoride were found in
all  of  the samples.   Documented evidence shows that fluorides emitted by
phosphate fertilizer  plants are responsible for damage to commercially  grown
flowers,  fruits,  and  vegetables.5'6'7'23'24  Low concentrations of  fluorides
can also  be  absorbed  by grasses and  plants and cause fluorosis  in animals
 feeding upon  such forage.   This disease  causes mottling  of teeth,  affects  bone
                                                                5  7 23  24
 structure,  retards  growth,  and adversely affects general  health.  '  '   '
 Fluoride is  emitted from  phosphate fertilizer  processes  as colorless,
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 gaseous silicon tetrafluoride (SIF^) and hydrogen  fluoride  (HF).    Also,
 because of the residual  fluoride in the recycled water stream which is  used
 as the scrubbing medium,  any mist entrained  in the scrubber  exhaust would
 contain fluorides.   Essentially all  of the fluoride emissions were found

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to be water-soluble.  For this reason, it was originally considered to
establish performance standards for water-soluble fluorides only.  However,
during the National Air Pollution Control Techniques Advisory Committee
(NAPCTAC) meeting in February 1973, fluoride standards were discussed for two
industrial categories, primary aluminum and phosphate fertilizer.  A change
from water soluble to total fluorides was recommended by a representative for
 the primary aluminum industry.  He revealed that some "insoluble" fluoride
compounds will slowly dissolve if allowed to remain in the water-tmpinger
              >
section of the sample train.  Since EPA had not closely controlled the time
between capture and filtration of the fluoride samples, the change to total
fluorides was, made to assure a more accurate data base.  Since recalculation
on the basis of total fluorides revealed that 80 percent of the data remained
unchanged and the greatest change was only three percent, it was not necessary
to change the absolute value of the proposed standards.

Selection of Units for the Standards
Units of both concentration and mass were considered for the standard.
Concentration units have the advantage of being simple and easy to enforce,
and they are a parameter used in the design of air pollution control
systems.  However, they do not necessarily indicate efficient control of
mass emissions for this industry.  For a given concentration in the
effluent gas stream from a control system, the quantity of emissions will vary
directly with the effluent gas volume.  Our data revealed that even within
the same process, the gas volumes vary significantly.  For wet-process
phosphoric acid plants, gas volumes from plants producing 375 and 325 tons
P20g  per day varied from 47,500 to 295,000 standard cubic feet per ton of
PO,-, respectively.

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A mass standard will encourage industry to minimize the amount of process air
used, which could further reduce fluoride emissions.  A drawback is that '
many plants do not weigh the fertilizer product; they do, however,.determine
quite accurately the weights of raw materials and the P^O,- content of the
feedstock.  Therefore, the best units for the performance standard are
"pounds of fluoride per ton of P?0,- fed."  The same units are used by
a State agency for its phosphate fertilizer emission control regulations.
Because water absorption of fluorides is the common control mechanism, the
possibility of a single fluoride emission standard was considered for all
processes in the industry.  This approach, however, proved impractical.
The great variation of fluoride concentrations and gas volumes from each
process precludes the selection of a single standard that would represent
"best demonstrated control" for all processes.  Table 2 shows some of the
major differences in emissions from the six processes.  Although the
final concentration of fluorides is about the same for most of the
processes, the volume of emissions varies greatly, not only from process
to process but also for the same process operated by different owners.
Consequently, the mass emission rates measured as pounds of fluoride per
ton of P205 vary by a fac'tor of 1,000.  Obviously, a single performance
standard for all processes based on either mass or concentration of
fluoride in the emissions would be unsuitable.

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During preliminary plant inspections of each of the six processes,  some
plants of each type had visible emissions of less than 10 percent opacity.
A scrubber that effectively controls gaseous fluorides appears  to effectively
control particulate fluorides also.  Therefore, a separate performance
standard for particulates was felt to be unnecessary.

Particularly characteristic of this industry are the interrelationships
between air pollution and potential water pollution.  Also, solid waste
and water pollution problems can be encountered with the production of
wet-process phosphoric acid, an intermediate product.   Filtered crystals
of gypsum, a byproduct, along with impurities such as  fluorides, cilcium,
iron, aluminum, and magnesium compounds, are slurried  and pumped to nearby
gypsum ponds.  The water is continuously recycled both for process  use
and as the scrubbing medium for the control devices.  When heavy
rainfall causes the pond to overflow, the overflow is  treated with  lime
to raise the pH to acceptable levels and precipitate fluorides before it is
discharged to a receiving body of water.
Selection of Sampling and Analytical Methods
An EPA sampling train was developed to measure fluoride emissions.   Samples obtained
from the 2-hour isokinetic samples were filtered in the. laboratory  to permit

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water-soluble and water-insoluble fluorides to be determined separately.
The water-soluble portions were analyzed with the specific ion electrode.
The water-insoluble portions were fused with sodium, distilled with sulfuric
acid, and then analyzed by the SPADNS-Zirconium Lake Method.
Results of EPA tests generally compared favorably with emission measurements
conducted by the owner or operator.  Although no single explanation for
isolated differences was evident, some of the differences could be due to
variations in sampling techniques employed by operators of the various plants
that were tested.  These operators use a less sophisticated sampling
technique than EPA.  Their sampling train has no ice bath and the operators
sample at the point of average velocity, rather than traversing and sampling
isokinetically as required by the EPA procedure.  Analytical techniques have
been verified by comparative tests.  Most EPA and industry results agreed
within 10 percent.  However, substantially lower values were reported by a
State agency (see Table 3).
Selection of Facilities for Source Tests
The phosphate fertilizer industry uses water scrubbers to remove fluoride
from their emissions.  Figures 2, 3, 4, and 5 show the types of scrubbers
                                                                 1811
commonly installed for air pollution abatement in this industry.  ปฐป11
The efficiency of these scrubbers is difficult to ascertain without a source
test because there is no known device that continuously monitors gaseous
fluorides or particulates in this industry.  Since gaseous fluorides are
invisible, it is impossible by visual observations to directly judge the
effectiveness of the control  system for fluoride removal.  Particulate
10

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emissions can often be estimated by sight observations,  and  the presence
of excessive visible emissions is an indication of poor  performance for both
participates and fluorides.  The best indicators of efficiency or
performance available to the plant operator are scrubber pump discharge
pressure and pressure differential through the control  device.
The initial screening of best-controlled plants was based on:
     1.  Emission data submitted by manufacturers,
     2.  Emission data submitted by States,
     3.  Recommendations by The Fertilizer Institute, and
     4.  Conversations with industry representatives.
Over 50 plants in eight States were inspected in this program.  During
investigation of various plant control devices, we were limited by the same
problems as the operator -- inability to appraise control efficiency without
a source test.  Consequently, best-controlled plants were selected according
to the type of control device used, its operating characteristics, and
apparent quality of maintenance.
Very few processes employed the  best emission control systems.  Some that did
were not suitable for emission testing, and the data base for  the  recommended
performance standard  for each affected facility is thus limited.   In all
processes,  however,  control is achieved by removal of fluorides from air
with water, an  extremely good solvent for  fluorides.  Fluoride removal
by a water medium  is  thus  common to the family  of processes  and this permits
a broader  base  for  the  application of engineering judgment  than  individual
consideration of each process alone.
 12

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Although only a limited number of affected facilities were sufficiently
well controlled to warrant testing, most of those selected used a packed
scrubber with the scrubbing liquid sprayed on the packing perpendicular to
the direction of gas flow (Figure 2).  They had consistently high
control efficiencies.  The packed scrubber, which appears to represent
best demonstrated control technology, can be used by all affected facilities.
Other types of scrubbers used by the industry are shown in Figures 3, 4 and
5.  Although fluoride emissions from these were higher than from the
packed scrubber, there appears, to be no reason why similar levels of
control cannot be achieved by these  types.
During the test program for the development of standards, the following
criteria were used in conducting emission tests of each process:
     1.  The plant was operating at or above its design rate.
     2.  The scrubbers appeared to be properly maintained.
     3.  Where possible, plants were tested which'use phosphate rock
         from different rock deposits.
     4.  In some cases, emission measurements were conducted on the
         same scrubbers during summer and winter to determine if scrubber
         performance changed appreciably.
     5.  When possible, emission measurements were conducted during process
         operating conditions that would generate the highest rate of
         emissions of fluorides.
By employing these five criteria, emission measurements from comparatively few
"best-controlled" plants provide a firm data base for the development of
performance standards.
                                                                            13

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                CLEANED GAS
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WATER
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                 'Figure 3.  Cyclonic scrubber.
                                            15

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CONTAMINATED
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                       WATER OUTLET
CLEANED
  GAS
               Figure 4.  Air-induced venturi scrubber.
   16

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Figure 5.  Water-induced venturi scrubber.
                                                                 17

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                WET-PROCESS PHOSPHORIC ACID PLANTS
SUMMARY OF PROPOSED STANDARD
A standard of performance is being'proposed for new wet-process-
phosphoric acid (WPPA) plants.  The proposed standard would limit emissions
of total fluorides from the wet-process phosphoric acid plant, which  •
is the affected facility.  Major sources include but are not limited to
the reactor, filter, filtrate seal tanks, barometric condenserTiotwells,'
fluosilicic acid tanks, and clarifier tanks.  The standard applies at the
point(s) where emissions are discharged from the afr pollution control
system or from the affected facility if no air pollution control system
is utilized.
The proposed standard would limit emissions to the atmosphere as ,
follows:
Total  Fluorides
No more  than 10  grams of  total  fluoride  per metric  ton  of  P20g  input  to
the process (O.OZ pounds per ton).
                                 19

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DESCRIPTION OF PROCESS
The basic reaction is the acidulation of tricalcium phosphate in  the
phosphate rock.  Phosphate rock, sulfuric acid, and water react to
produce phosphoric acid and calcium sulfate dihydrate (gypsum).
simplified reaction is:
                                                               13
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The production of wet-process phosphoric acid (WPPA)  is depicted in  the
flow diagram shown in Figure 6.  The process consists of a reaction  step
(where rock is acidulated to form phosphoric acid), a filtration step
(where the solids are separated from the acid), and an evaporation step
(where the acid is concentrated).  At the beginning of the process,
measured quantities of 93-percent sulfuric acid, weak phosphoric acid
(from the filter cake washing process), and pulverized phosphate rock
are introduced into a reactor.  The highly exothermic reaction is cooled
by a vacuum cooler, which also degasifies the slurry of dissolved air,
carbon dioxide, and fluorides.  After a retention time of 5 to 8 hours,
the slurry is pumped to a filter where the acid is separated from the
byproduct gypsum.  -The gypsum is reslurried with effluent process water
amd pumped to the gypsum pond.  The acid, containing about 30-percent
P205, is concentrated by vacuum -evaporators to about 54-percent
The 54-percent ?2ฎ5 aci'd is then pumped to product storage tanks.
Some plants recover fluorides as byproduct fluosilicic acid by installing
absorption sections on the top of the evaporators immediately upstream
from the barometric condensers.  '
 20

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EMISSIONS AND METHODS OF CONTROL
Gaseous fluorides evolve from any /luoride-containing liquid because of the
vapor pressure of the fluoride.    The rate of evolution varies with
temperature, concentration, absolute pressure, and exposed area of the
liquid surface.
Some poorly controlled WPPA plants can emit 0.07 pound of fluoride per
ton of P205 input.    A 500-ton-per-day (TPD) P20g installation, equipped
with such control equipment would emit 35 pounds of fluorides each day of
operation.  Well-controlled plants which use packed scrubbers or other
equally effective control can achieve fluoride emissions below 0.02 pound
fluoride per ton of P^Og input (see Figure 7).  Such a well -control led
500-TPD P20g plant would- emit 10 pounds of fluoride per day,
Best demonstrated emission control consists of  scrubbing off-gases. with
pond water in a packed scrubber.  These typically achieve 98 to 99 percent
removal of fluorides.
Several State and local regulations limit fluoride emissions from wet-
process phosphoric acid plants.  Some regulations restrict the mass of
emissions per unit of production.  Others are based on the fluoride content
of surrounding vegetation or ambient air concentrations.   The most  ,
stringent State regulation, 0.02 pound fluoride per ton of P205 feed to the
process, would permit the typical 500-TPD PpO  plant to emit 10 pounds of
fluoride per day.

 22

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RATIONALE FOR PROPOSED STANDARD
Selection of Pollutants for Control
Fluoride is the only significant air pollutant emitted from WPPA plants.

Discussion
Preliminary investigation revealed the location of several  reportedly
well-controlled plants.  Twelve were visited and information was obtained
on the process and control equipment.  Seven were not further considered
for testing because fluoride fumes were excessive in the processing
area (perhaps the result of inadequate maintenance) or the physical
arrangement of the equipment (e.g., ductwork configuration) was not
suitable for accurate testing.  Stack tests were conducted at the remaining
five locations.  One of these was-later tested a second time to see if
seasonal variations had any effect on emissions.  Results of that test
showed higher emissions during warm weather, indicating a possible effect
of i.the  temperature of gypsum pond water on the effectiveness of the control
device.  However, similar seasonal tests of emissions from superphosphoric
acid and diammonium phosphate plants failed to confirm such an effect.
During the  initial plant surveys, 12 plants with scrubbers exhibited no
visible  stack  emissions other than uncombined water vapor.  Results of one
test on  Plant  A, which measured 0.065 Ib/ton of P205, were not considered

-------
 during  the  final evaluation of the data.- This figure was unexplainably much
 higher, not only than  any  other  EPA sample, but also much higher than any results
 the  operator had measured  from numerous  tests over the previous year.  No definite
 reason  for  the  high  number could be identified.  The process instrumentation
 gave no indication of  a  process  upset  or scrubber malfunction.  Results of the
 other two samples were 0.011  and 0.019 pound fluoride per ton P205 input.  Results
 of testing  by the operator indicated average fluoride emissions of 0.013 pound
 fluoride with a range  of 0.007 to 0.018  pound fluoride per  ton p205  input.

 Results of  the  tests conducted by EPA  reveal emissions from plants with packed
 scrubbers (Plants A, B,  C, and E) averaged  0.015, 0.006, 0.002, 0.012  (retest of
 Plant C), and 0.011  pound  fluoride per ton  of p205  input.   Plant  D,  controlled
 by an impingement scrubber,  averaged 0.008  while  ranging from 0.006  to 0.011;
 however on  the average,  impingement scrubbers do  not perform as well  as packed
 scrubbers for this  process.
 Concurrent testing  by the  plant  operator indicated  average  fluoride  emissions
 of 0.014 (Plant B)-'and 0.010 (Plant. C) pound fluoride per ton  P205  input.
 Individual  samples  ranged from 0.010  to  0.017 pound.
 Tests were conducted by EPA while the  plants were operating at  or near their
' design" production rates.  A complete  summary of test results .can  be found in
 Volume 2.
 The proposed standard of  10 grams of total  fluoride per metric ton of
 P.-.Oj. input  (0.02 pound per ton)   is supported by emissions  measured from the
   c.  O
 plants  as  presented in Figure 7.  The standard will require installation  and
 proper maintenance of equipment  representative of the best technology
 which  has  been demonstrated for  the industry.  In the Administrator's
 judgment,  achievability of the  proposed standard of 10 grams of total fluoride
 per metric ton  (0.02  Ib F/ton P2ฐ5) nas been adequately demonstrated.
                                                                               25

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A visible emissions standard is not recommended for WPPA plants.   Since  there
can be no emissions visible even from an uncontrolled WPPA plant,  a standard
would have little meaning.
 26

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                       SUPERPHOSPHORIC ACID PLANTS

SUMMARY OF PROPOSED STANDARDS

A standard of performance is being proposed for new superphosphoric acid (SPA)
plants that manufacture acid-for the production of fertilizer.  The proposed
standard would limit emissions of total fluorides from the superphosphoric
acid plant, which is the affected facility.  Major sources include but are not
limited to evaporators, product cooling tanks, and barometric condenser hotwells.
The standard applies at the point(s)'where emissions are discharged from the air
pollution control system or>from the affected facility if no air pollution control
system is utilized.  The proposed standard would limit emissions to the atmosphere
as follows:
Total Fluorides
No more than 5 grams of total fluorides per ton of P^Or input to the process
(1 x 10"2 Ib/ton).
DESCRIPTION OF PROCESS

SPA is produced by concentrating 54-percent P?0r phosphoric acid to 70 (+2)*
.percent P90[-.  Two commercial processes are used for SPA:  vacuum evaporation
      *'  . .ฃ O              *•*-..--
(VE) and submerged combustion (SC).
Production of SPA by vacuum evaporation (VE-SPA) is. depicted in Figure 8.   Clarified
54-percent P205 phosphoric acid is continuously fed to a vacuum evaporator.  The
hot off-gases, which contain water vapor and fluorides, are condensed in the
water-cooled barometric .condenser.  The fluoride-laden condenser water flows to
the hotwell where it cools before draining to the gypsum pond.  The concentrated
acid is continuously drawn from the evaporator to product cooling tanks, where
it is cooled before being pumped to storage.

In the submerged combustion (SC-SPA) process, depicted in Figure 9, hot gases are
forced below the surface of the 54-percent PpOj- phosphoric acid in a submerged
                                   27

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combustion evaporator.   Water vapor, fluorides,  and  phosphoric  acid mist  are
driven from the solution, and concentrated acid  is drawn  off  as  product.   Fluorides
                                                                           13 19
and phosphoric acid mist generated by this process are  difficult to control.   '

EMISSIONS AND METHODS OF CONTROL
Uncontrolled SC-SPA plants can release as much as  22 pounds of  fluorides  per  ton of
P00C.18  An uncontrolled 200-TPD installation would  emit  185  pounds of  fluoride
 d 5                                              ,         .
each hour of operation.
In addition to the absence of combustion products  and their dilution  effect,  a
second advantage of the VE-SPA system is that fluorides are absorbed  by water
in the barometric condenser during normal operation  of the process.   This sig-
nificantly reduces the quantity of fluorides which must be controlled by  the
                        13 18 19
emission control device.  '  '
No State or local regulation specifically limits fluoride emissions from  SPA
plants.  However, one State requires that any source of fluorides (i.e.,  SPA
plants) not specifically regulated by the State  will'be controlled in accordance
with "latest available technology."
RATIONALE FOR PROPOSED STANDARD
Selection of Pollutants for Control

The potential pollutants from SPA plants are phosphoric acid  mist, sulfur
oxides, combustion products, and fluorides.  Manufacturers of SPA normally
control phosphoric acid mist to increase product yield.  The  equipment  necessary
to control fluorides to the limits proposed by the standards  will also  provide
some control for any phosphoric acid mist, sulfur oxides, and combustion  products
not now controlled.  Therefore, only fluorides were  considered  for standards
development.
30

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Discussion

No SC-SPA plants were tested bv-EPA in the development  of  the
proposed standards for several  reasons:   1)  no well-controlled
plants were observed; 2) the majority of members of the phosphate
fertilizer industry consider submerged combustion an outdated process and
future growth unlikely; and 3) the Act makes clear that new plants should
utilize processes which have the least environmental impact.

Two seemingly well-controlled VE-SPA plants were located.
One produces a specialized SPA used as an intermediate for the production
of animal feed.  This process is designed to steam-strip fluorides from
the acid to minimize the possible effect on'animals that consume the feed.
As might be expected, this results in  high evolution of fluorides from
the process.  The average for the test by EPA was 0.02 Ib F/ton of P20g
input with a range of 0.015 to 0.024.  This average is 20 to 40 times
greater than that measured from a similar plant which produces SPA as an
intermediate for the fertilizer industry and consequently does not purposely
strip fluorides.  Because the process  associated with animal feed is
distinctly different from the majority of SPA  plants which  produce an
intermediate for the fertilizer industry,  it was decided to recommend
that  the  standard not apply to those  facilities that prepare animal feed.
 (In the  event a single  plant manufactures  for  both markets, it will be
subject  to the  standard when  producing a  fertilizer intermediate.)  Consequently,
 the data  from this  first plant test were  not used  in the  development of  the
 performance standard.
                                                                               31

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The second well-controlled plant, which does produce SPA for the fertilizer
industry, was tested by EPA in the early winter of 1971  and again in  the
summer of 1972.
Results of the two tests (three samples per test) conducted by EPA (Figure 10).
reveal emissions from Plant A average 9 x 10"  and 4.6 x 10"  pound of
fluoride per ton of P205 respectively.  Individual sample results ranged  from
4.1 x 10"4 to  15 x 10"4 Ib F/ton P205.
Tests were conducted by EPA while the plant was operating at or near its  design
production rate.  A complete summary of test results can be found in Volume 2.
During the initial plant surveys, none of the VE-SPA plants exhibited visible
stack emissions other than uncombined water vapor.
Based on the emission test data  from  the VE-SPA plants,  EPA originally
considered proposing a  standard  of  1  gram of fluoride per metric  ton of f
P90,- input  (2  x 10"3 Ib/ton).  The  inherently low uncontrolled  emissions
  c, o
from this process made  it obvious that the  SC-SPA process  could not be economically
 controlled  to  the same  level.  This would probably preclude  any future con-
struction  of the  SC-SPA process  and,  at that time this  action seemed justifiable
since  inherent characteristics of the SC-SPA process  render it  significantly
more  polluting than  the VE-SPA process.   Furthermore, as stated previously,
 representatives  of  the  industry  indicated that  the SC-SPA  process was near
 obsolete and would  not be built  regardless  of  any subsequent air pollution
 standard.   When the  standard was presented at  the National  Air  Pollution
 Control  Techniques  Advisory Committee (NAPCTAC)  meeting, it became obvious that
 two companies consider the SC-SPA process the  more desirable.   In fact,  they
  32

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contend that the decreasing quality of the nation's phosphate rock reserves
coupled with the inability of the VE-SPA plant to use acid from poor quality
rock make it essential for the SC-SPA process to remain a viable option for
future plants.  They maintain that a standard which permits the SC-SPA process
is in the best interest of our national resources.
In altering the standard to permit the SC-SPA process, the result is that
VE-SPA plants will not be required to install a control device.  Separate
standards for VE-SPA and SC-SPA plants were considered.  This alternative has
little merit.  The original objective of the fluoride standard was to indirectly
force prospective SPA plant operators to construct the VE-SPA process, not to
reduce fluoride emissions from VE-SPA plants (which are only about four pounds
per day).  The standard now recommended is sufficiently stringent to still
                                                                        
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     a.   The  average  fluoride concentration measured  by  EPA. from packed
     scrubbers  controlling  wet-process  phosphoric  acid plants, diammonium
     phosphate  plants,  granular  triple  superphosphate plants and granular
     triple superphosphate  storage buildings  was three ppm.

     b.   One  designer of a  packed scrubber reported that an exit concentration
     of three ppm fluorides can  always  be achieved and that they are designed
     to achieve 1.5-2 ppm.
     Data supplied by a major operator  of an  SO-SPA plant indicate that  gases
exit his plant at a rate of 47,000 standard cubic  feet per ton of  P205-   The
exit concentration of 11,000 ppm by volume is reduced to 50 ppm with the
existing control system.
     To verify the practicality of a standard which is  essentially equivalent
to 3 ppm (although higher concentrations are pernrissable if the volume of
exhaust gas is reduced), conventional design criteria were used to estimate
the efficiency (measured in terms of transfer units)  which would  be required
of a control  device.
     The number of transfer units necessary to achieve three ppm was calculated
as follows.  The calculation assumes that the concentration of fluorine in the
scrubbing  liquid is constant through the scrubber, a valid assumption because
of its  relatively high  concentration in the  inlet liquid.  The number of transfer
                                                              Q
units required to scrub a  lean  gaseous effluent is defined by:
                         NOG,= 1n
                                  Yl -
 Where:
       rtr
       Ufa
         =  number  of  transfer units
      Y,   =  fluoride  concentration  in  the  inlet gas phase  (.11,000 ppm)
                                                                                35

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     Y2  = fluoride concentration in the outlet.gas phase (3 ppm)
     Ya  = fluoride concentration in the gas phase in equilibrium with the
           scrubbing liquor (1.5 ppm, based on equilibrium vapor pressure
                                      pr                   p/r
           data for gypsum pond water)   and other sources.

     Using these criteria, NOS is calculated as 8.9 transfer units.   If a
packed scrubber is installed downstream of an existing control  device which
achieves 50 ppm, then only 3.5 transfer units are required of the packed
scrubber.

     Packed scrubbers now operating at other phosphate fertilizer processes
commonly achieve three to four transfer units.   Therefore, a scrubber of about
the same efficiency would be needed to supplement typical existing control at
SC-SPA plants.
     It is possible that other acid gases such as SOX may adversely influence
the absorption efficiency and require slightly more transfer units than the
above calculations would indicate.  Also, the presence of acid mists may require
the installation of a mist eliminator or some other partlculate collection device,
such as a venturi scrubber.  Even if this additional  control is needed, the cost
of control is not prohibitive (0.13 percent of the sales price of SPA as
reported in the economic report following the technical reports) and in the
Administrator's judgment, the achievability of the proposed  standard has been
adequately demonstrated.

     Since no existing SC-SPA plant now operating has a control device which
can be considered best technology, we are unable to obtain visible emission
data.  Consequently, no visibility standard will  be recommended at this time
for the SPA process.
 36

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                       DIAMMONIUM PHOSPHATE PLANTS

SUMMARY OF PROPOSED STANDARDS
Standards of performance are being proposed for new diammonium phosphate
(DAP) plants.  The proposed standards would limit emissions  of total
fluorides and visible emissions from the diammonium phosphate plant,  which
is the affected facility.  Major sources include but are not limited  to
the reactor, granulator, dryer, cooler, screens, and mills.   The standards
apply at the point(s) where emissions are discharged from the air pollution
control system or from the affected facility if no air pollution control
system is utilized.
The proposed standards would limit emissions to the atmosphere as follows:

Total Fluorides
No more than 30 grams fluoride per metric ton of PgOg input  to the process  for
new diammonium phosphate plants (0.06 pound per ton).

 Visible  Emissions
 Visible  emissions  shall  be  less  than  20  percent opacity.
                                                                            37

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DESCRIPTION OF PROCESS

The process consists of a prereactor, a reactor-granulator,  and  accessory
                                                                     19
equipment for drying, cooling, and screening the product  (Figure 11).
The primary reaction is:  2 NH3 + H3P04 •> (NH4)2 HP04.

Unreacted ammonia gas which is not absorbed by the  rock  is carried  from
the prereactor and granulator with the exhaust gas.   Most of the ammonia
is recovered by scrubbing the exhaust gas with a weak (20 to 30  percent
PgOg) phosphoric acid solution.  •

The DAP slurry in the reactor is pumped to the granulator where  additional
ammonia and recycled product are added to form a solid material  which
averages 18 percent nitrogen and 46 percent Pg^-  ** 1S  then driedป  cooled,
and screened before being conveyed to storage.

EMISSIONS AND METHODS OF CONTROL

Considerable quantities of fluorides can be stripped from the scrubbing
medium, dilute phosphoric acid which contains fluorides.  This source of
fluorides is particularly significant when a higher concentration acid
(30 to 40 percent Pg^) ^s use(*.  Fluorides are also present in  any
mist entrained from the scrubbers or in solid particulates carried  from
both the granulator and dryer.
                           J  '  „   '  r '
Poorly controlled diammonium phosphate plants  can release up  to  0.5
pound of fluoride to the atmosphere per ton of-PgOg input.    A 500-TPD
 38

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P205 installation, equipped with such control  equipment, would emit
250 pounds of fluorides each day of operation.  Well-controlled
DAP plants employing primary and secondary scrubbers can achieve  fluoride
emissions below 0.06 Ib F/ton PgOg input or 30 pounds of fluoride per  day
(see Figure 12).
Although ammonia is a potential pollutant from diammonium  phosphate  plants,
the industry has long maintained good control  of ammonia,  a major raw
material, because of its relatively high cost.
The best demonstrated control for ammonia consists of scrubbing  emissions
with a weak phosphoric acid solution.  Fluorides are removed by
secondary scrubbing   with packed scrubbers.
Several State and local regulations limit fluoride emissions from
diammonium phosphate plants.  Some restrict the mass of emissions per
unit of production.  Others are based on the fluoride content of surrounding
vegetation or ambient air concentrations.   The most stringent State
regulation, 0.06  pound fluoride per ton of PgOg feed to the process,
would permit the  typical 500-TPD  P205 plant to emit 30 pounds of fluoride
per day.
RATIONALE FOR PROPOSED STANDARDS

Selection of Pollutants for Control
Ammonia,  fluorides, and particulates  are  potential  pollutants from this
process.   The low concentrations  of ammonia measured during this program
 (1  ppm)  verified  that  operators  are very  effectively recovering ammonia.

-------
Combustion products from the drying operation are present in the stack
gases, but in very minor concentrations.  Therefore, only fluorides and
particulates were considered for standards development.

Discussion

Preliminary investigations revealed the locations of several reportedly well-
controlled plants.  Nine were visited and information was obtained on the process
and control equipment.  Six were not further considered for testing because
either fluoride fumes were excessive in the processing area (perhaps the result
of inadequate maintenance) or the equipment (e.g., ductwork configuration)
was not suitable for accurate testing.  One of these (Plant B) was modified to
accommodate an EPA test in March of 1973.  Stack tests were conducted at the
remaining locations.  Plant A was tested twice.
During the initial plant surveys, 9 plants with scrubbers exhibited no
visible stack emissions other than uncombined water vapor.

Emission measurements at Plant A were conducted by EPA during different
seasons.  The two tests yielded average results of 0.040 and 0.028 Ib F/ton
P205, respectively, as shown in Figure 12.  During the first EPA test the
operator tested his plant using a different test method.  His results indicated
an average emission of 0.034 Ib F/ton P00,-.
                                       ฃ b
EPA emission measurements at Plant B yielded average results of 0.039 Ib F/ton
P2ฐ5'  The operator of Plant B has reported average fluoride emissions of 0.041
pound per ton of P2ฐ5-  This average is based on 23 emission tests during a
12-month period.  Some of the higher results vary enough from the mean
                                                                         41

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  to question  their  validity as part of  the  total sample population with
  99-percent confidence.  However,  they  have been included in Figure 12.
  Plant  C was  tested by EPA to estimate  an emission factor for DAP plants
  as part of an  industrial study which preceded the program for developing
  standards.   Plant  C compromises fluoride control.  Rather than install
  a  separate water scrubber to control fluorides, they use a weak acid
  (22 percent  P2ฐ5)  i" an attempt to recover ammonia, particulates, and
  fluorides in a single scrubber.   Data from Plant C were not considered in
  the development of a recommended  new source performance standard for DAP
  plants.

-All tests were conducted by EPA while the plants were operating  at  or near the
 design production rate.   A complete summary of test data  for Plants A and  B
 can be found in Volume 2.   Since Plant C was tested under another study, the
 test data from that plant are not presented in Volume 2 but may  be  obtained
 fmm thp Fmission Standards and Engineering Division.
The proposed  standard of 30 grams  of fluoride per metric ton
of  P20g input (0.06 pound per ton) .is supported by emissions measured by EPA
from Plant A and Plant B as presented in Figure 12.  This standard will
require installation and proper maintenance of equipment representative of the,
best technology which has been demonstrated for the industry.  In the
Administrator's judgment, the achievability of the proposed standards has been
adequately demonstrated.

The proposed visible emission standard of 20. percent is based on data obtained
in  February 1974.   Visible emissions were read simultaneously by two qualified
observers during a  valid one-hour  test.  Other data collected at the DAP plant
were not considered representative due to problems  with the control  equipment
during part of the  test and because during another portion,  the  plant was
forced to reduce its production below normal due to operational  problems.
                                                                            43

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                 RUN-OF-PILE TRIPLE SUPERPHOSPHATE
                               PLANTS
SUMMARY OF PROPOSED STANDARDS
Standards of performance are being proposed for new run-of-pile triple
superphosphate  (ROP^TSP) production plants and ROP-TSP storage piles.
The  proposed standards would limit emissions of  total  fluorides
from the run-of-pile  triple superphosphate plant (including the storage .
building(s)), which is the affected facility.  Major sources include but are
not  limited to  the TVA cone mixer, curing belt (den),  transfer conveyors,
and  storage piles.  The standards apply at the point(s) where emissions '
are  discharged  from the air pollution control system or from the affected
facility if no  air pollution control system is utilized.   The same  standards
are  being proposed for granular  triple superphosphate  plants and will be
discussed for such plants in a separate section.
.'otal Fluorides

No more than 100 grams of total fluoride per metric ton of P00r  input
                                                            25    K
(0.20 pound per ton).
Visible Emissions

Visible emissions shall  be  less than  20  percent  opacity.

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DESCRIPTION OF PROCESS

Measured quantities of ground rock and 54-percent P205 phosphoric  acid
are combined in a mixer (Figure 13).   The resultant viscous  slurry
drops onto a slowly moving belt (or den)  where it solidifies.   When  the
porous mass reaches the end of the belt,  it is reduced to  small  chunks by
a cutter.  The ROP-TSP is then conveyed to a storage pile  where the
reaction continues.  After approximately 30 days the reaction  is complete,
and the product is considered "cured" and ready for shipment.

EMISSIONS AND METHODS OF CONTROL
Emissions of fluorides and particulates occur during the production,
conveying, and storage of ROP-TSP.   Emissions from storage are greater
during periods when the pile is being rearranged than when it has  lain
undisturbed for an extended period.

Uncontrolled ROP-TSP plants can release 1  pound of fluoride per ton of
     I Q
PgOs.    A typical uncontrolled 600-TPD installation would emit 600
pounds of fluoride each day of operation.

The best demonstrated control of fluoride  consists of scrubbing emissions
with water.  No visible emissions were observed from storage facilities
with   this  type of  control.  This verifies good control  of particulate
emissions.

Several State and local regulations limit  fluoride emissions from  ROP-TSP
plants.  Some restrict the mass of emissions per unit of production.

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47

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Others are based on the fluoride content of surrounding vegetation or
ambient air concentrations.1  The most stringent State regulation, 0.17
pound fluoride per ton of P205 input,17 would permit the typical  600-TPD
P205 plant to emit 102 pounds of fluoride per day.  (This limitation,
however, is based on the analytical technique used by the State and
cannot be directly compared to the proposed  standards of performance.)


RATIONALE FOR PROPOSED STANDARDS

Selection of Pollutants for Control

The major pollutants emitted from this process are fluorides and
particulate matter.  Reasons for the decision to require control  of only
fluorides are presented in the Introduction.
Selection of Units  for the  Standard
Considerable attention was  devoted to  the  selection of  units for  ROP-TSP
standards.   Initially, separate  standards  were  considered for  ROP-TSP
manufacture  and ROP-TSP storage  since  emissions from  one of the major
sources,  the storage pile,  are independent of production rate.  Most
manufacturers,  however, have  a single  control system  for the two  sources
Therefore,  this approach  was  not practical.
With a single  control  device, emissions from manufacture and storage
cannot be separately measured.  Standards  based on storage  factors were
considered.   However, emissions from a storage  pile are dependent on
 turnover, age,  and quantity of ROP-TSP in  storage.  Incorporation of a

-------
"turnover" factor in the units of the standards was not considered
because of the extreme difficulty in quantifying and  maintaining records
of this activity.  Standards based on age of the product were briefly
considered because fresh ROP-TSP evolves more fluorides than cured ROP-TSP.
The units of such standards, however, would be cumbersome, and enforce-
ment would rely heavily on records kept by the manufacturer.

The final decision to orooose units  of pounds  of fluoride per
ton of P205 input to the process seemed most appropriate since 90 percent
of the total fluorides released from ROP-TSP are evolved during the
                                    19
mixing, setting, and conveying steps   and because total
the process is routinely measured.
                                                              input to
Discussion
                                                  22
Seven plants produce ROP-TSP in the United States.    One does not control
fluorides from the storage pile.  The remaining six were visited, visible
emissions were evaluated, and information was obtained on the process and
control equipment.  Four were not further considered for testing because
emissions were excessive (perhaps the result of inadequate maintenance),
because the equipment (e.g., ductwork configuration) was not suitable
for accurate testing, or because a test could not be. scheduled (e.g.,
one plant only operated 3 to 6 weeks per year).
During the initial plant surveys, five plants with scrubbers exhibited
no visible stack emissions other than uncombined water vapor.  Three of
these were not tested for reasons listed above.
                                                                 49

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Results of the three tests conducted by EPA at two plants  CFtgure 14)  reveal
average emissions of 0.19, 0.21, and'0.12 pound of fluoride per ton  of P205
input.  Individual samples ranged from 0.03 to 0.31 pound  of fluoride  per
ton P205 input.  Average results of similar tests by the operator of Plant
A over the previous year tend to support the averages obtained by EPA.  The
average of 35 tests was 0.16 pound of fluoride per ton of  P20g Input.   Figure
14 also presents emission measurement data submitted by the operator of a
plant controlled by cyclonic scrubbers CPlant B).  The measured emission rate
from this installation was 0.08 pound of fluoride per ton  of P205 input. These
plant tests were not performed in accordance with EPA test procedures.

All tests were conducted by EPA while the plants were operating at or  near
their dp^nn production rates..  A complete summary of test results can be
found in Volume 2.
The proposed standard of 100 grams of fluoride per metric ton of PZ05 input
 (0.20 pound per ton) is supported by emissions measured from Plants A and B
as presented in Figure 14.  This standard will require installation and
proper maintenance of equipment representative of the best technologywhich
has been demonstrated for the  industry.
The Agency originally considered proposing a  standard of 150 g  F/metric ton
 (0.3  Ib  F/ton  P2ฐ5)  based on the actual  emission  tests of  best-controlled
 plants.  However,  like SC-SPA  plants, ROP-TSP plants  have  not  been  fitted with
 the more efficient control  equipment  typical  of  other phosphate fertilizer
 processes.   It is estimated that a  packed  scrubber  could possibly limit
 emissions  to as  low as  0.06 Ib F/ton  P20g,  based on a typical  400,000 scf/ton
 effluent at  three ppm  exit  concentration.
  50

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to a predetermined area in the building by conveyors.  After 3 to 5 days,
during which fluorides evolve from the storage pile, the product is
considered cured and ready for shipping.  Front-end loaders move the
GTSP to elevators or hoppers where it is conveyed to screens for size
separation.  Oversize material is rejected, pulverized, and returned to
the screen.-Undersize material is returned to the GTSP production
plant.  Material within specification is shipped as product.
EMISSIONS AND METHODS OF CONTROL

Emissions from GTSP storage are limited to fluorides and particulates.
The fluorides are emitted both in the gaseous form and as a constituent
of the particulate emissions.   Emissions of gaseous and solid  particulate
fluorides are greater during periods when the GTSP product is  being
rearranged rather than when it is in piles where it has lain undisturbed.
Some poorly controlled GTSP storage facilities can release as  much as
15 x 10"  pound of fluoride per hour  per ton of  P00B in
storage.  Such a storage facility with 1,500 tons of P20g could emit
                                                                      -4
55 pounds of fluoride each day of storage.  Well-controlled  GTSP
storage facilities can restrict fluoride emissions to less than 5x10
pound fluoride per hour per ton of P205 stored (see Figure 18).  A well-
controlled 1,500-ton PgOg storage facility achieving 5 x 10   pound of
fluoride per hour per ton of P205 stored would emit about 18 pounds of
fluoride each day of storage.
                                                                    63

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 The best-demonstrated control  of fluoride consists  of scrubbing emissions  '
 with water.     No visible emissions -were observed from storage facilities
 with  this  type of control.   This-verifies. good control  of fluoride  and
 also provides incidental  control  of  particulate emissions.

 Several  State and local  regulations  limit fluoride  emissions  from
 granular triple superphosphate storage  facilities.   Some restrict  the
 mass of  emissions per unit of  production.   Others are based on the
 fluoride content of surrounding vegetation or ambient air concentrations.1
 The most stringent State  regulation,  0.05  Ib F/ton  P205  stored per day,
 would permit  a 1,500-ton  P205  storage facility  to emit 75 pounds of
 fluoride per  day.

 RATIONALE FOR PROPOSED STANDARDS

 Selection of  Pollutants for Control

 Only fluorides and  particulates are potential pollutants  from  this
 process.  Reasons  for  the  decision to require control  of  only  fluorides
 are presented in  the  Introduction.  Since  control of  fluoride  will
 inherently provide  some control of particulate, only  an opacity standard
 is  recommended to assure particulate  control
 Selection of  Units  for the Standard

 This  is  the only one of the affected  facilities in the phosphate fertilizer
 industry for  which  a standard of "pounds of fluoride per
 ton of P205 input" was not considered to be applicable.  The amount of
 fluorides evolved from a storage pile is dependent on turnover, age,  and
 quantity of the GTSP in storage.  The proposed  units  are based on  the
quantity and age of the GTSP  in the  storage building.        "            65

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Discussion
Preliminary investigations revealed the location of several reportedly well-
controlled facilities.  Six were visited, visible emissions were evaluated,
arid information was obtained on the process and control equipment.  Four
were not further considered for testing because the maintenance was
inadequate or the equipment (e.g., ductwork configuration) was not suitable
for testing.  Three stack tests were conducted by EPA at the remaining
two locations.  Both plants utilized packed scrubbers with gypsum pond
water as the scrubbing medium.
During the initial plant surveys, 6 plants with scrubbers exhibited no
visible emissions other than uncombined water vapor.
The tests conducted by EPA indicate average emissions from Plant A
are 4 x 10   pound fluoride per hour per ton of P^O,- stored (see Figure
18).  The 6TSP storage building was about 21 percent full during.these
source tests.
                                                               -4
EPA's first test of Plant B indicated emissions averaged 1 x 10   pound
fluoride per hour per ton P^O,- stored.  Concurrent testing by the operator
indicated 2xlO~  pound fluoride per hour per ton PoO,--  The 6TSP
storage building was approximately 30 percent full during this period.
 66

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A second test of Plant B by EPA at a later date indicated 4 x 10   pound
fluoride per hour per ton of PoOc-  During this .second test the storage
building was about 15 percent full.
Tests were conducted by EPA while 6TSP production was at or near design
production rates and more than 20 percent of the GTSP in the building was
manufactured within the 10 days prior to testing.               .
Also, as noted above for each test, the storage buildings ranged from 15-30
percent full.  A complete summary of test data can be found in Volume 2.
The proposed standard will require that a storage building be filled
to at least 10 percent capacity and that at least 20 percent of the GTSP
stored be fresh (produced no longer than 10 days prior to testing) during
a^compliance test.  If the provision requiring'20 percent of the material
to be fresh exceeds production capabilities, the plant operator will be
required to have greater than five days maximum production in the building
during testing.
The minimum amount of product stored (10 percent of the building's capacity)
is required because the standard becomes unduly restrictive when very small
inventories are present in the building.  The denominator in the units of the
proposed standard is the amount of material  stored.  If this quantity is
small the allowable pounds per hour of emissions is correspondingly small.
With low inlet concentrations to the scrubber (because of the small amount
of material stored), some fluorides may be stripped from the contaminated
scrubbing medium.  Emissions in terms of "pounds per hour per ton P90,-
                                                                   L- 0
stored" may then exceed the standard even though they are s.malj  in terms of
pounds per hour.
                                                                       67

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A minimum amount of fresh material is required to be stored during testing
since, as mentioned earlier, fresh GTSP evolves more fluoride than cured GTSP.

The proposed standard of 0.25 gram of fluoride per.hour per metric ton of
P205 in storage (5 x 10"4 pound per hour per ton) is supported by emissions
measured from the plants as presented in Figure 18.   This standard will
require installation and proper maintenance of equipment representative of
the best technology which has been demonstrated for the industry.

The proposed visible emissions standard of 20 percent is based on data
obtained in'February 1974.  Visible emissions were read simultaneously by
two qualified observers during two 2-hour tests.
In the Administrator's judgment, the achievability of the proposed standards
has been adequately demonstrated.
68

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REFERENCES
1.  "Engineering and Cost Study of Emissions Control  in The Phosphate
    Industry," Chemical Construction Corporation under contract to the
    Environmental Protection Agency (Contract CPA-70-156), unpublished
    draft.  August 1972.
2.  "Fertilizer:  The Figures are Looking Lots Better," Chemical
    Marketing Reporter.  April 17, 1972.  p. 5.

3.  "Clear Sailing Ahead for Fertilizer Phosphates,"  Chemical  Week.
    December 6, 1972.  p. 31.
4.  "Fertilizers:  Global Accent," Chemical Week.  September 27, 1972.
    p. 11.
5.  Oelschlager, vi., "Determination of Fluoride Standards for Vegetation
    and Animals," Fluoride (Journal of the International Society for
    Fluoride Research).  Vol. 5, No. 3, July 1972.  p. 111.

6.  Leonard, C. D. and Graves, H. B., Jr., "Effect of Fluoride Air
    Pollution on Florida Citrus," Fluoride (Journal of the International
    Society for Fluoride Research).  Vol. 5, No. 3, July 1972.  p. 145.
7.  Antonelli, Dr. Giuseppe,  "Effects of Fluorine in the Regions Close
    to the Industries  that Produce it .  .  .," Rass. Trim., Odont. Vol. 35,
    No. 2, April-June  1954.  pp. 95-122.  (Italian - English translation
    obtained from EPA  Air Pollution Technical Information Center.)
                                                                  69

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8.  Teller, A. J., "Control of Gaseous Fluoride Emissions,"  Chemical
    Engineering Progress.  Vol, 63, No. 3, March 1967.   pp.  75-79.

9.  Cross, F. L. and Ross, R. W., "New Developments in  Fluoride Emissions
    from Phosphate Processing Plants," JAPCA.. Vol.  19,  No.  1,  January 1969.
    p. 15.
10. King, W. R., "Fluoride Emissions from Wet-Process Phosphoric Acid
    Plant Gypsum and Cooling Ponds," presented at ACS National Meeting,
    New York, N.Y. August 27, 1972.
11. Information obtained by EPA emission measurements or supplied by
    phosphate industry producers in support of Industrial  Studies Branch
    program.
12. Reynolds, J. and Rom, J., "The Phosphate Industry Source Testing
    Program," presented at TFI Conference on Environmental  Control  and
    Fertilizer Production, Washington, D.C. May 4, 1972.

13.  Slack, A. V., Phosphoric Acid. Vol. 1.  Marcel Dekker, Inc.,
     New York, N. Y. 1968.
14.  "Wet-Process Phosphoric Acid." Chemical and Engineering News.  Vol.  45,
     March  20, 1967. pp. 54-58.
15.  Illarionov, V. V. et al. Zh. Prikl. Khim. Vol. 36, 1963, pp. 237-241
      (estimates of vapor pressure obtained by Russian investigators).
70

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16.  Atmospheric Emissions from Wet-Process Phosphoric Acid Manufacturers,
     U.S. Department of Health, Education and Welfare. NAPCA No.  AP-57,
     April 1970.

17.  "Rules of the State of Florida Department of Pollution Control,"
     Chapter 17-2, 1972.

18.  "Control Techniques for Fluoride Emissions," U.  S. Department of
     Health, Education and Welfare, unpublished draft.  May 13,  1970.

19.  Sauchelli, Vincent, Chemistry and Technology of  Fertilizer,
     Reinhold Publishing Corp., New York, N.  Y. 1960.

20.  "Superphosphate:  Its History, Chemistry, and Manufacture," U.  S.
     Department of Agriculture and Tennessee  Valley Authority.   December
     1964.

21.  Bixby, D. W. et al.  "Phosphatic Fertilizers - Properties and
     Processes," The Sulphur Institute, Washington, D. C.,  Tech. Bull.
     No. 8. October 1966.

22.  "1972 Directory of Chemical Producers,"  Stanford  Research Institute,
     Menlo Park, California. 1972.

23.  "National Emission Standards Study," Senate Document No.  91-63,
     U. S. Government Printing Office, Washington, D.C. 1970.
24.  "Fluorides," National Academy of Sciences, Washington, D.C. 1971.
25.  Tatera, Bernard S., Parameters Which Influence Fluoride Emissions from
     Gypsum Ponds, Ph.D. Dissertation, University of Florida, 1970.

26.  Personal communication with Dr.  Aaron J.  Teller,  Ph.D., March 16, 1973

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                  APPENDIX A

THE ECONOMIC IMPACT OF STANDARDS OF PERFORMANCE
      ON THE PHOSPHATE FERTILIZER INDUSTRY
                        73

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I.  Overvi ew
    A.  Scope
        The purpose of this paper is to examine the background of the  phosphate
    industry and to analyze the economic impact of proposed standards  of
    performance upon the industry.  The scope of this study is limited to
    new sources only, that will fall under jurisdication of section lll(b).
        After promulgation of standards of performance for a designated
    pollutant, such as fluorides, existing manufacturing facilities become
    subject to emission regulations under State implementation plans,  similar
    to those designed for achievement of national ambient air quality  standards.
    This requirement is under section lll(d) of the Clean Air Act.  This
    appendix does not discuss sources subject to section lll(d).
    B.  Summary
        Costs for control of fluoride emissions under the standards of performance
    for wet-process phosphoric acid (WPPA), superphosphoric acid (SPA), and
    diammonium phosphate (DAP) manufacturing are minor, amounting to less than
    1 percent in sales price at the wholesale level  (phosphate producer).  Costs
    for emissions control for run-of-pile triple superphosphate is about 2
    percent of wholesale price and  for granular triple superphosphate, 4 percent.
        The growth for new facilities  in the phosphate industry will be fairly
    substantial during the 1970's.  A  growth rate  of an approximate 6 percent
    is expected for new facilities  in  WPPA  and DAP.  Calculations yield 2 WPPA
    units per year of the 900-TPD (P205 basis) size  and approximately 3 DAP
    plants (500-TPD PgOg) per year.  No estimates  have been made for replacement
    of existing facilities; most  facilities in the industry today  are less than
    ten years old.  Some 3 SPA units of the 300-TPD  (P205)  size .will be built.
        Little growth is expected  for run-of-pile triple  superphosphate  produc-
    tion; only slight growth  is  expected  for granular triple  superphosphate
    because of increasing  competition  from  diammonium phosphate  and concentrated
    liquids production  (SPA),  particularly  in  the  area of  manufacture of  mixtures.
    Projected  granular  triple superphosphate production  is expected to  be conducted
    by  complexes  designed  for multi-product operations.  Therefore, facilities
     equipped for  DAP manufacture will  also  produce GTSP  to satisfy demand for
     direct application  materials and overseas  exports.   Three new storage units
     are expected  to be  built during the  1970's,  each unit  to  accommodate  250-TPD
     (P0OJ GTSP  production.
       
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     The impact of standards of performance upon the fertilizer industry
will be minimal, both for domestic consumers and the balance of trade.
While demand for phosphate products are relatively inelastic, cross
elasticities of demand do exist among competitive phosphate products  (i.e.,
high analysis products vs. low analysis products, bulk goods vs. bagged
goods, solid fertilizers vs. liquid, for some samples of competition).  The
standards of performance will not be a deterrent to those products that are
gaining acceptance with farmers.  They will only accelerate this trend as con-
trol costs will further prohibit manufacture of run-of-pile triple superphosphate
and GTSP for the mixed fertilizers markets.
     Lastly, a standard has been proposed for SPA to allow two competitive
manufacturing  processes to remain as viable alternatives to producers;
namely, the submerged combustion and the vacuum evaporation processes.
A control cost of $0.28 per ton P205 for the submerged process has been cal-
culated for a system that represents a technology transfer from DAP manufacturing.
It is estimated that the vacuum evaporation process can attain 0.01 Ib F/ton
P205 without control.  This would appear to be a cost disadvantage for the sub-
merged process; however, the impact of the standard upon the industry is
expected to be negligible.                                       <•
                                                                              75

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II.  Economic Profile
     A.  Industry Structure
         The phosphate fertilizer industry is only a segment of the agricultural
     chemical industry that is devoted to the production  and marketing of com-
     modities bearing the basic nutrients—nitrogen, phosphorous,  and potash—
     for crop production.  From the perspective of end-use products, the scope
     of the agricultural chemical industry includes ammonia, ammonium nitrate,
     urea, ammonium phosphates, nitrophosphates, mixed plant foods (in varying
     N-P-K combinations), superphosphates, phosphoric acid, and potash.  The
     phosphate production sector of the" agricultural chemical industry begins
     with the mining of phosphate rock, proceeds with the basic chemical produc-
     tion of phosphoric acid and its subsequent processing to diammonium phosphate
     (DAP), superphosphoric acid (SPA), and triple superphosphate (TSP), and
     culminates at the retailer level where many thousands of-blends of fertilizers
     are formulated to satisfy the diverse interests of consumers.  There are three
     basic types of retailers—granular NPK producers  (manufacturers of chemical
     formulations), liquid fertilizer manufacturers, and mechanical  (dry bulk)
     blenders.  These three groups of retailers compete with each other in some
     markets  (mixed fertilizers).
         The basic chemical producers in  the  industry  will  sell merchant phosphoric
     acid  and products  derived from  phosphorie acid, such  as DAP  or  SPA.  NPK pro-
     ducers  can  buy from a choice  of raw  materials  then to produce  a  specific product.
     For example, the typical  NPK  plant operator  can buy  DAP or produce his  own from
     wet-process  phosphoric acid to  satisfy  a product  demand.  Therefore, some  com-
     petition can be  expected among  the  various phosohate concentrates.
         The basic chemical producers, which  are  the focus of  this  analysis, are
     generally not identifiable  as   single    product  firms.   Very  few firms are
     totally dependent  on fertilizer production for their business.   Most fertilizer
     production  is conducted  as  a  subsidiary  activity  in  well  diversified, often-
     times large, corporations.  These firms  are  chemical  manufacturers or
     petrochemical companies.   Some  companies are farm cooperatives,  vertically
      integrated from production to the marketing in geographic areas in which they
      are economically based.   These  latter firms are primarily engaged in   serving
      farm customers  in  ways  such as  retailing fertilizers, purchasing and shipping
      grains and other agricultural products  to regional  centers,  and providing  necessary
      supplies and services for conduct of an agricultural economy.   Thirdly, there
      76

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are firms engaged in fertilizer production that derive the main portion

of their revenues from totally unrelated activities, such as steel manu-

facture, pipeline construction, etc.

     Generally, the basic chemical producers will own the sources of their

raw materials  (e.g., phosphate rock mines).  According to 1970 production

statistics^   , the ten largest firms in rock mining are ranked as follows:

                     TEN LARGEST PHOSPHATE ROCK'PRODUCERS
             Firm
International Minerals & Chemicals
Continental Oil Company (now Williams Co.)
Mobile Chemical
Occidental Chemical Company
American Cyanamid
U.S.S. Agrichemicals
Swift & Company
Texas Gulf, Inc.
Stauffer Chemical Company
Cities Service, U.S. Phosphoric
Total U.S. Production
Percent of total production of ten largest firms

     Based on the production of wet process phosphoric acid, which is the cornerstone
of the basic chemical production in this industry, the ten largest firms in terms
of 1972 production are as follows:
                     TEN LARGEST PHOSPHORIC ACID PRODUCERS
      Production
   (1000 Short Tons)

         8,000
         6,500
         5,900
         3,750
         3,650
         3,640
         3,000
         3,000
         2,500
         2,000
        50,640
          83%
             Firm
      Production
(1000 Short Tons,
CF Industries                                                         838
Freeport Minerals                                                     600
Cities Service, U.S. Phosphoric                                       544
Farmland Industries                                                   455
Beker Agricultural Products                                           411
Texas Gulf, Inc.                                                      346
01 in Corporation                                                      337
W. R. Grace                                                           300
U.S.S. Agri-Chemicals                                                 266
J.R. Simplot                                                          265
Total U.S. Production                                               6,114
Percent of total production of ten largest firms                     71%
     A review of the two above tabulations finds some vertical integration from
the mine through the chemical production.  Each of the phosphate rock producers
named above owns basic chemical production facilities directly or through equity
interest in chemical producing companies.  CF Industries and Farmland Industries
are integrated from the chemical production stage forward to the ultimate retailing
                                                                                  77

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of fertilizers.  Freeport Minerals is strong in ownership of sulfur reserves,  an
important raw material for production of phosphoric acid.  Beker Industries
is a newcomer into the fertilizer industry as they purchased the fertilizer
assets of Hooker Chemical (Occidental Petroleum) and El  Paso Products Company.
B.  Production
    The scope of this study limits discussion to four basic commodities that
are produced and traded.  These are  wet-process phosphoric acid, superphosphoric
acid, triple superphosphate, and ammonium phosphates.  Production data for 1960
through 1971 are presented in Table 1 for these commodities.  A discussion of
the features of these commodities follows.
    1.  Wet-Process Phosphoric Acid
        The production of this chemical intermediate, which is the cornerstone
    of the industry, has grown at a phenomenal rate of 14 percent compounded
    annually for the period shown in Table 1.  The growth has been due to the
    increased demand for phosphate nutrients over the years and due to the sub-
    stitution from low analysis to high analysis products (triple superphosphate
    and diammonium phosphate) that require phosphoric acid for their production.
    High analysis products contain some 45 to 50 percent P20g as opposed to 18
    to 24 percent P205 in low analysis products, such as normal superphosphate.
        Wet-process phosphoric acid  is used to produce triple superphosphate,   .
    diammonium  (or monoammonium)  phosphate,  superphosphoric acid and complete NPK
    foods  (those  containing some  formula  of  nitrogen, potash,  and P205)-  Normally
    phosphoric acid is produced very near the rock mines to minimize the shipping
    charges as phosphoric acid is a more concentrated product than phosphate rock.
    2.  Triple Superphosphate
        The production of triple  superphosphate has  been  in a downtrend since 1966,
    which may  indicate a likely course for future  trends  in production of  run-of-pile
    triple  superphosphate and a close substitute,  monoammonium  phosphate.  Since
    1900, triple  superphosphate has  grown at  a  compounded rate  of 4  percent.
        Triple superphosphate is  produced by two methods; the den method and
    the granulator method.  The den method produces a material  (run-of-pile)
    that is  non-uniform in particle size.  This  material  is  stored, pulverized,
    and shipped to NPK plants for  ammoniation.  The granulator method produces
    a  granular  product that is sold to bulk blender retailers for mixing or
    for direct application (as a 0-46^0 fertilizer) to the soil.
         No statistics are available as to the breakdown of run-of-pile versus
    direct granulator production.   In the industry, run-of-pile production by
    the primary producer may be  granulated and sold as GTSP to bulk blender

    78

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TABLE 1.  U.S. PRODUCTION OF THREE COMMODITIES IN THE PHOSPHATE INDUSTRY. 1960-1971

Year
1960
1961
1962
1963
1964
1965
1966
1967
1968
1969
1970
1971

Wet> Process
Phosphoric Acid
1325
1409
1577
1957
2275
2897
3566
3752
3861
3867
4642
5286
(1000 Tons of
Triple Super-
phosphate
986
1024
960
1113
1225
1466
1696
1481
1389
1354
1395
1381
W
Ammonium
Phosphates
269
370
536
786
1016
1081
1376
1747
1633
1844
2070
2359

Superphosphoricc
Acid
35
55
55
75
120
188
260
418
NA
NA
NA
NA
 All grades containing 40 percent or more available P^O,- which have been made by
 acidulating rock with phosphoric acid.

 Mono- and diammonium phosphates and their processed combinations with ammonium
 sulfates.  Excludes ammonium phosphates produced in combination with potash salts.

Production derived from thermal acid and wet-process phosphoric acid, based on a
 marketing study of the industry conducted by Chemical Construction Company.

NA - Not available.

SOURCE:  U.S. Department of Commerce, Current Industrial Reports.
                                                                               79

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 retailers  as  a direct application  fertilizer.   Ultimately,  essentially all run-
 of-pile production becomes  granulated,  either  by  the  primary  producer or  by the
 NPK plant.
    Triple superphosphate affords  a way of shipping P^ values in a
•concentrated  form,  whether  for distribution into  domestic markets or for
 exports.   Some 80  percent of  triple superphosphate plant capacity is
 located in Florida near the rock mines.
 3.   Ammonium  Phosphate
     By definition, these are  products manufactured directly from arnnoma,
 phosphoric acid, and optionally  other acids  in contrast with  those ammoniated
 phosphates produced in NPK granulation  plants  from ammonia  and run-of-pile
 triple superphosphate.  "Diammonium"  phosphates include 16-48-0 and  18-46-0
 grades.  Monoammonium phosphates are  11-48-0.   These  two  generic  products
 are produced strictly from ammonia and  phosphoric acid; other ammonium phosphates
 are produced from a mixture of ammonia, phosphoric acid,  nitric acid,  and
 possibly  sulfuric acid.
     Production  of arrcnonium phosphate has grown at a rate of 20 percent com-
 pounded annually  since  1960.  The rapid growth has been at the expense of
 other  competitive  phosphate  fertilizers.  The  following statistics will
 support this.   In  1960, ammonium  phosphates absorbed 20 percent of wet-
 process phosphoric acid production; in 1971,  45  percent.   In  contrast,
 triple superphosphate absorbed  52 percent of  wet-process phosphoric acid
 production in  1960  and  only 18 percent in 1971.  (One ton of P205 in triple
 superphosphate requires 0.7 ton of P205 from  phosphoric acid.)
      NPK and  superphosphoric  acid  production consume  the  remainder of wet -
  process phosphoric acid that is not  used in ammonium phosphate and  triple
  superphosphate processing.
  4.  Superphosphoric Acid
      Superphosphoric acid is a concentrated form (70-75 percent P205)  of
  thermal  or  wet-process phosphoric acid.   Phosphoric acid is concentrated   ^
  by two methods-(a) vacuum evaporation technique, and (b)  submerged combustion
  process.
      Documentation  of  superphosphoric acid production is very limited.
  The usual reporting  groups, such as Department  of Commerce and TVA, do not
  report production figures.  The  Fertilizer Institute reports production
   80

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   in its Fertilizer Index but privately concedes that its published figures
   for the years of 1969-1971 are far below estimates of actual  production.
   Dr. William White^ of the Fertilizer Institute estimates that 1972
   production approaches 600,000 tons (P205 basis).  This is signi-
   ficantly different than  the 258,000 ton figure published in the Fertilizer
   Index for the 12-month period ending in June 1972.
       Superimposing the 600,000 estimate on an imaginary trend line with data
   developed by Chemical Construction Company^  ' would reinforce the. Tatter's
   data trend.  Linear  regression analysis of the Chemical Construction Company
   data yields an  historic growth rate of 35 percent from 1960 through 1968.
C.  Capacity
    The phosphate fertilizer industry has  followed  a cyclical  pattern  of  capital
investment in new plants.   This pattern  is  demonstrated by the two  graphs  for
phosphoric acid and ammonium phosphate (mostly diammonium phosphate;  this  term
will  be applied to ammonium phosphates produced directly from wet-process
phosphoric acid)  production, shown in Figures 1  and 2.   As shown  in the graphs
by the duration between peak utilization (operating near 100 percent),  the cycle
length is about 6 to 7 years.  During the  1965 to 1972 cycle, expansion peaked
in 1969.   Slackened demands prompted price cutting  and eventual  temporary shut-
down of some facilities.  At the end of the cycle,  supply of plant  capacity
becomes in balance with production.
  „  For an insight into the cyclical trend of capacity utilization, the
following operating ratios are presented for phosphoric acid and diammonium
                     (4)
phosphate production.
                Year
                1965
                1966
                1967
                1968
                1969
                1970
                1971
                1972
                1973
                1974
                1975
                1976
Production, as Percent of Capacity
     WPPA
      100
       92
       80
       77
       69
       84
       96
       96
       89
       89
       83
       82
DAP
 72
 63
 66
 56
 54
 78
 96
 96
                                                                          81

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          FIGURE  1.  CAPACITY UTILIZATION QF WET-PROCESS PHOSPHORIC ACID

                       jfc-|Miii|^

  2750
  [   65   66   67   68  69   70   71  72   73   74   75  76   77

  |L-;Ld^L;-i-il-ii^-:-^                          	:.l:-.u._--_i::_.;-. _i~-
  ,SOURCES:  Development Planning & Research Associates,  TVA
82

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                                                83

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 During mid-1973,  the  industry was  operating  near capacity.   Idle  plants  that
 had  been  shut-down  during  the 1968-1970  recession were  being refurbished for
 production.   Beker  Industries is one  example of a firm  that  purchased  idle
 phosphate facilities  from  petroleum companies for acid  and ammonium production.
 New  plant construction  as  announced by Agrico Chemical  and IMC  will  not  pro-
 vide significant  additions to supply  of  phosphates until  1975 to  1976.   By
 inspection of the profiles in Figures 2  and  3 and the operating ratios pre-
 sented above,  planned plant capacity  for phosphoric acid  seems  sufficient
 through  1976;  and ammonium phosphate  capacity, on the other  hand, will have
.to be increased to  cope with the projected demand.
 D.   Consumption
     For  an understanding of the historical consumption  patterns of the four
 commodities named above, an overview  of  consumption of  all phosphate fertilizers
 is presented.  Although some superphosphoric acid is consumed ultimately in
 the  form of animal  feed supplements,  almost  all phosphate production •
 from wet-orocess  phosphoric acid ends up UL.fejr.tilizers..
      Historical data  are presented tor U.S.  consumption (total  consumption,
 mixtures, and direct  application materials)  in Table 2,  Liquids  and solids (bulk
 and  bagged) are all included in these data.   Total  consumption  includes  phosphate
 values derived from wet-process phosphoric acid to produce triple superphosphate,
 and  phosphate rock  reacted with sulfuric acid to produce  normal superphosphate.
      Overall,  the growth trend in  total  consumption has been at a rate of 6.5
 percent  compounded  annually from the  base year 1960. However,  normal  superphosphate
 production has declined steadily from 1,270,000 tons (P205)  "in  I960 to 670,000
 tons (P90c) in 1970.  The  gap in phosphate values generated  by  the decline in NSP
       ฃ, O
 has  been mostly taken up by diammonium phosphate production, as well as  wet-process
 phosphoric acid,  the  intermediate  product.   Hence, consumption  of wet-process
 phosphoric acid  and diammonium phosphate production have  grown  at a more rapid
 rate than total, consumption of phosphates.
     The  two other major categories presented in Table 2 separates the basic
 chemicals that are  applied directly to the  soil from those  that receive  further
 processing into  mixtures.;  foods containing  at least two of  the nutrients'basic to
 plant growth.  Some duplication of reporting is evident in  the  TVA statistics  as
 some undetermined amount appears  twice,  in  "mixtures" and "direct applications"
                                                                                 85

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     Review of the data in Table 2 shows that demand for materials with only one
 or two basic nutrients, the ammonium phosphates, has been very important in recent
 years.  Ammonium phosphates, other than DAP, and normal superphosphate have
 declined in importance as "direct application materials".  Almost all  direct
 application materials are now DAP or GTSP.  Demand for these materials appears
 to have grown more rapidly than total consumption.,  Two explanations for this
 trend are the rise of bulk blending operations and intensive cultivation (emphasis
 on increased yield per acre).
     Delivery of low cost fertilizer materials to the farm has been the factor
responsible for this trend.  Farmers have lately realized that mechanical blends
of granulated concentrates do just as well as a granulated, chemically produced
NPK food and at lower costs.  A shift from normal superphosphate and run-of-pile
triple superphosphate production to the granulated concentrates, DAP and GTSP is seen.
     The shift in product usage has also been accompanied by a shift in raw materials
 for NPK plants.  Run-of-pile triple superphosphate has been replaced by wet-
 process phosphoric acid as a raw material.  Improvement in phosphoric acid
 technology has made it possible to ship a stable product, as most NPK plants
 are far removed from the areas of acid production (Florida^ for example).
     Consumption of superphosphoric acid is only recently beginning to enter an
 important expansion phase.  Data for consumption is limited.  To this point in
 time, the acid has been used for producing some animal feed supplements and mostly
 liquid  fertilizers.  Superphosphoric acid consumption is estimated at only 15
 percent of overall phosphate consumption.
     Several reasons are presented to explain the expected expansion of super-
 phosphoric acid consumption.  Technology has made it possible to produce a
 product without the problems of sludge formation due to presence of micronutrients.
 Increased crop yield per unit PgOg applied from liquids fertilizers has
 been claimed.  Transportation and distribution costs of liquids are less
 than for solid fertilizers.  The need for foreign exchange spurs superphosphoric
 acid production, particularly in light of the recent Occidental Petroleum
 announcement of a 20 year trade deal with Russia..
     The implications of all the shifting patterns in the industry in response
 to shift in demands for cheaper, better quality products are as follows:
 86

-------
    1.  Granular concentrates will continue to expand in production; these in-
        clude DAP and GTSP.
    2.  Run-of-pile production will decline and be replaced by GTSP (bulk
        blender) and diammonium phosphate.
    3.  Superphosphoric acid will  have the largest growth rate of the four commodities
        These will  be important factors in determining growth rates for each
        process segment and the number of new units.
E.  New Units
    Future growth for consumption  of fertilizers has  been estimated at 5.4 per-
cent annually from the base year of 1971^ ' by the Department of Commerce.  TVA
estimates overall consumption of P205 to be 4 percent from 1970 to 1980.^7'
Projection of new units will be determined from use of projected growth rates,
capacity utilization, and estimated shifts in demand.  Due to the present
situation in this industry, attrition through 1980 is expected to be minimum
(with the exception of normal superphosphate processing).
    1.  Het-Process Phosphoric Acid
        For purposes of discussion, the announced construction of wet-process
    phosphoric acid plants  is  assumed to satisfy demand through 1976 and will
    be unaffected by the recommended standards of performance.  This includes
    the Agrico and the IMC facilities, which recently have commenced construction.
         A growth rate of 5 to 8 percent in wet-process phosphoric acid production can
    be expected to accommodate overall phosphate demand for domestic consumption and
    exports growth and to -replenish gaps left by normal superphosphate production.
    Calculations of added capacity needed to supply this demand will yield
    annual expansion of approximately 600,000 tons (Pp^r basis) for a 6-per-
    cent growth rate.  For the 1976 through 1980 time frame, this will amount
    to 10 units of the 900-TPD size or 18 units of the 500-TPD size.         .
    2.  Piammonium Phosphate
        From interpretation of available statistics,  there is apparently a
    catch-up phase expected for this category in terms of present capacity
    utilization and expected demand growth.
       .Overall, the growth rate of ammonium phosphates is projected at 6
    percent to correspond with the similar increase in wet-process phosphoric .
    acid.  It is difficult to predict number of new units to be affected by
                                                                                  87

-------
the  standards of performance because they apply only to units that
produce diammonium phosphate only in a single process.   Much  of  the  pro-
jected growth in ammonium phosphates -v/i 11  be supported  by  NPK production.
    A conservative assumption for determining number of new diammonium
phosphate plants would be to assume that three-fourths  of  production for
each new wet acid plant will be devoted to solids  manufacture, either DAP
or 6TSP.  This would allow the remainder to be sold as  merchant  wet-process
phosphoric acid or superphosphoric acid.  This is  based on past  performance  of the
concentrates producers, such as those in Florida.   In actual  estimates then,  there
will be approximately 20 DAP units of the 500-TPD  size  through 1980.
3.  Triple Superphosphate  (Granular Only)
    Based on earlier discussion, only granulated concentrates are expected
to  be of importance in the future for the triple superphosphate.  Further-
more, only those producers of wet-process phosphoric acid  will manufacture tripTe
superphosphate as has happened mostly in the past.
    According to information sources in the  industry, the trend in qranular
production  is to conduct  triple superphosphate processing in the same facility
producing diammonium phosphate.  The only additional requirement for GTSP
production  in a DAP plant would be  the  storage facility.
     For purposes of determining new storage  units, an assumed growth rate
of  4 percent  in current granular    production  (approximately 700,000 tons
per year PgOg) will yield 2-3  units (250-TPD P205) through 1980.  This
growth  rate would  be consistent with past  performance for all triple super-
phosphate production.
4.   Superphosphoric Acid
     From  all  indications, this portion of  the  industry  is expected  to
expand rapidly.  Whether  this  expectation  is realistic  or a  reflection of
bold optimism is  unknown.  Ultimately,  the availability of merchant wet-
process phosphoric acid will  be  the factor that determines the  constraints
on SPA expansion.
 88

-------
 F.
     For the industry as a whole, only enough expansion will occur to
convert available acid that is not used to produce concentrates.  This
is axiomatic if the industry is to operate profitably.  Approximately
twent-five percent of all future WPPA expansion can be projected to accomo-
date SPA plants.  Taking into account the Agrico and IMC combined new
facilities (1,000,000 tons P205 per year total) and the projected expans-
ion from 1976 through 1980, some 10 SPA plants will be built (300-TPD Pp05).
Prices
     Price competition in the fertilizer industry has been very intense historically
 because of the large numbers of participants in all  facets of manufacturing--
 basic chemicals production,  down-the-line manufacturers of mixed goods, blenders,
 and retailers.  No one chemical  producer can be said to.be a price leader.   The
 participation of farm cooperatives  in  the manufacturing segment of fertilizers,
 including the basic chemicals,  undoubtedly has  been  a steadying factor on
 prices, minimizing cyclic fluctuations in prices.
     List prices are available for (agricultural  grade)  wet-process phosphoric
 acid,  triple  superphosphate  (run-of-pile and granular),   diammonium  phosphate,
 and superphosphoric acid grade  (72  percent available phosphoric acid  basis)  in
 the Chemical  Marketing Reporter  published by Snell Publishing Company of New
 York.   These  prices,  however, are not  meaningful as  discounts,  variability in
 credit terms  to buyers,  and  service fees  combine to  determine the  realized
 price  available to the producer.
     The long  term  profile  of wholesale prices for triple  superphosphate
 (granular)    and diammonium  phosphate  is  presented in Figure  3.    The
 estimates of  prices  realized  by  manufacturers are plotted  against  the  ranges
 of  listed quotations of  the  same  products  for 1971 and  1972.  The  spreads in
 prices  shown  reflect the difference in  quotations by various  manufacturers at
 any given time  rather  than variability  in  time.  No long term profile of prices is  avail
able for wet-process phosphoric  acid,  superphosphoric acid, and triple superphosphate.
     These prices will  be used as  parameters for measuring the impact of
 pollution control.  Total annualized control cost and the difference in
 control costs between existing,  comparably stringent state standards and pro-
 posed  Federal  standards  of performance  for triple superphosphate and diammonium
 phosphate will be measured against prices  (1972) for the respective products.
                                                                                    89

-------

-------
    A summary of list prices (December 25, 1972) is presented in Table 3 for
all commodities concerned.  Point of origin for all quotations is Florida.
Prices are based on largest volume available, railroad cars or tanks.
    On October 25, 1973, prices on wholesale phosphate commodities
were decontrolled.  Prices had been frozen at levels established near
year-end 1972 prices by President Nixon's Economic Stabilization Program.
According to the Cost of Living Council, prices have advanced 60 per-
cent from the October 25 frozen level to January 8, 1974.
G.  Foreign Trade
    Trade statistics for triple superphosphate and ammonium phosphates (mostly
DAP) are presented in Table 4.   No data are available for phosphoric acid
(wet-process or SPA), probably for the reason that trade has been non-existent
because of transportation properties associated with movements of acids.

    As the data show, the U.S.  has been an exporter of phosphates, on balance.
The reasons for this include technological competition, favorable location of
rock, and the Agency for International Development (AID).  Under AID, export
purchases of products have been possible by underveloped nations through U.S.
foreign aid.  AID providestechnical assistance, as well as financing of
fertilizers, to these nations in fertilizer applications.
    The recent unilateral devaluation of the dollar has placed the domestic
industry in a favorable position by pricing American products at discounts
relative to the foreign currencies of competive producing nations.  This
should be beneficial to the domestic producers at least for the short to
intermediate term.
                                                                     91

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 II.  Control  Costs  for Affected  Facilities
     A.   Introduction
          The  purpose of  this  section  is to report the expected capital and
     annual costs to control  emissions from wet-process phosphoric acid, super-
     phosphoric  acid, diammonium phosphate, and triple superphosphate  (run-of-
     pile and granular)   processes.  Estimates of control costs will  be
     presented for  two model  plants for each  process.  These estimates will be
     based on information  developed from  a study under contract with the
     Industrial  Gas Cleaning  Institute/8'  Comparisons of these data with industry
     data submitted to the Environmental  Protection Agency will be presented and
     discussed.  Cost-effectiveness considerations for fluoride control will be
     discussed.
     B.   General Digcussion of Control Alternatives

          Basically, venturi,  cyclonic, and packed scrubbers are applied to
     moisture laden streams carrying  fluorides from process plants.
     Each process stream has  certain  characteristics that require
     various  service functions--(l) recovery  of ammonia or phosphoric  acid which
     are  valuable materials,  (2)  gaseous  fluoride control, and (3) dust recovery
     from granulation.   These functions will  come into focus as model  plants for
     the  various processes are discussed.
          These scrubbers will  be referred to  as primary and secondary  collectors.
     Primary  scrubbers serve  to  remove particulates, phosphoric acid mists, and
     ammonia. Secondary collectors perform gaseous absorption.        Pond water
     is the general scrubbing medium, except  for weak phosphoric acid  used to
     recover  ammonia  (DAP  plants).
     C.   Control Costs—Acid  Manufacture
          1.  Wet-Process Phosphoric Acid
              Model  plants  producing 500 and 900 ton per day  (P205) are presented
          in Table  5 for  WPPA  plants.  Capital and annual  costs are presented
          for  packed scrubbers with  the scrubbing liquid sprayed on the packing
          perpendicular to  the direction gas flow designed to remove fluorides.
          Capital  costs include a scrubber, fan, water circulating pumps, 120
          feet of ductwork, and a 100  foot stack.  All surfaces exposed to
          scrubbing  (pond)  water  are coated with  polyvinyl chloride  (PVC) or
          similar corrosion resistant  material.
94

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                    TABLE 5
CAPITAL AND ANNUAL COST FOR; PACKED SCRUBBER ON WPPA PLANTS
Plant Size, TPD P205
Gas Flow.SCFM
Capital Cost ($)
Scrubber
Auxiliary equipment
(fan, pumps, etc.)
Installation Cost
Total Capital Cost
Annual Cost ($/yr)
Operating labor
Maintenance (5%)
Utilities
Depreciation (10 yr)
Interest (8%)
Property Tax, Ins. (2%)
Administrative (5%)
Total Annual Cost
500
25,000

17,700
8,500
36,300
62,500

2,000
3,100
2,800
6,250
5,000
1,250
3,100
23,500
900
36,000

21 ,600
9,400
40,900
71 ,900

2,000
3,600
! 4,400
7,200
5,750
1 1 ,450
1 3,600
28,000
                                                              95

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          For  the models, the packed scrubber  is designed to meet the
      standard under most operating conditions, using pond water as the
      scrubbing medium.  The scrubbers are assumed to be designed for
      approximately 4.5  transfer  units, with a corresponding pressure drop
      of approximately 4 inches,  water gauge.
          The  annual  control  cost per  ton P20g ranges  from  $0.135  to  $0.221
      for the  500-TPD plant and $0.08  to  $0.152  for the 900-TPD plant.
      These ranges  are a reflection of the variability in  gas  flows  pre-
      viously  discussed.
      2.  Superphosphoric Acid
          Costs for the vacuum evaporation process are not considered
      since, as mentioned earlier, the process can probably achieve  the
      level,of the  standard without air pollution control.   Model  plants
      are presented for the submerged  combustion process.
           For the submerged combustion process for  producing  superphos-
      phoric acid, control  technology to  meet  the  standard of  performance
      has not  been tested to determine compliance.   Experts in EPA feel
      that technology transfer  of a venturi cyclonic-packed scrubber from
      applications on other phosphate processes is possible to achieve the
      standard.
           For a 300-TPD P2Gg model plant, capital and  annual  control costs
      estimates are presented in  Table 6  for a combination system that would
      be found on a diammonium  phosphate  drier or  reactor.  The basis for
      developing these estimates  is the background data presented in Table 7.
      The cost for the packed scrubber was slightly  adjusted to correct  for
      increased packing  depth (to 8.9 NTU).  A gas flow rate of 8,000 scfm
      was assumed for determination of the costs.  The  cost of control on a
      unit basis is $0.28 per ton P0.
96

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                                  TABLE 6

                CAPITAL AND ANNUAL CONTROL COSTS FOR SPA PLANTS
                         (SUBMERGED COMBUSTION PROCESS)~
Control Equipment
Venturi scrubber with cyclonic separator
followed by a paeked scrubber
Gas Flow Rate ACFM
                8,000
Capital Costs ($)

  Collector
  Auxiliary Equipment (fans, pumps,
   ductwork, instrumentation)
  Installation Cost

  Total Capital  Cost
                18,400

                 9,500
                41,000

                68,900
Annual Cost ($/yr)

  Operating Labor
  Maintenance (5%)
  Utilities
  Depreciation (10 yr)
  Interest (8%)
  Property Tax and Insurnace (2%)
  Administration (5%)

  Total Annual Cost
                 2,000
                 4,000
                 5,010
                 6,920
                 5,540
                 1,380
                 3,460

                27,800
                                                                          97

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         The system outlined above to meet the standard does not remove
     any sulfur oxides emissions to any known extent.  -The system is
     designed to remove only particulate and fluoride  emissions.
 D.  Control Costs - Phosphate Fertilizer Manufacturing
     Capital and annualized cost estimates for emissions control are pre-
 sented in Table 7 for five generic types of devices used in phosphate
 fertilizer manufacturing.  These estimates are presented on an uniform
 dry gas flow basis.   Moisture and temperature considerations will  dictate
 the final  size selection as capital  estimates for the model  plants  will  be
 based on the actual  gas flow input.   Utilities requirements  will  be direct-
 ly proportional  to actual gas flow input.
     Capital costs include the basic scrubber, the fan, interconnecting
 ductwork from the scrubber to the 50-foot stack (assumed height), which
 is included, and a return pump.  Materials of construction include
 rubber-lined mild steel  or Dyne! lined fiberglass reinforced plastic (FR.P).
 Costs for a pumping  system to recycle gypsum pond water  and the con-
 struction  and maintenance of the gypsum pond itself are not included.
 These costs are  assumed to have been  assimilated into the cost structure
 of the fertilizer industry.
     1.  Diammonium Phosphate (DAP)
         Model  plants  producing 500 and 800 tons  of P20r with engineering
     specifications for estimating  costs are  presented in Table 8.   There
     are three distinct gas streams  that must be  vented to a  scrubber
     system—(a)  reactor-granulator,  (b) the  drier, and (c)  the cooler
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     gaseous  fluoride  removal.
         Weak (30%) phosphoric  acid is  the  scrubbing medium for the  primary
     collectors for purposes of ammonia  recovery.   The  cyclonic  section is
     an entrainment separator  for phosphoric  acid mists.   Pond water  serves
     as 'the  scrubbing  medium for  the packed scrubbers.
98

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     A summary  of control  costs  for the model  plants   is  presented In
 Table 9.    A two-stage  cyclonic scrubber is  assumed  for  the reactor-
 granulator stream,  and  venturi  cyclones for  the  drier and cooler-
 transfer  points  streams.   The venturi  should  remove  particulates  from
 the  latter streams  more effectively than a two stage cyclone although
 both types are interchangeable.   Total  control costs  with MM-
 credits   are $0.88  per  ton P205 for the 500-TPD  plant and $0.70
 for  the 800-TPD  plant.  Gaseous  fluoride control  costs alone are
 $0.46 per ton  P205  for  the 500-TPD plant and  $0.40 for the 800 TPD
 plant.
 2.   Triple Superphosphate (GTSP  and ROP)
     In reference to earlier discussions, granular triple  super-
 phosphate will be produced in the same  facilities as diammonium
 phosphate.   The  same basic control  equipment  could be used,-.in the
manufacture, of both Products, although  triple superphosphate production
 requires  approximately  twice as  much recirculation of solids  during
 granulation  as does DAP per unit output.  Hence,  gas  volumes  generated
 for  equivalent P20g production will be  significantly larger for triple
superphosphate.   In addition,  storage  ventilation will require
scrubbing.
     Engineering  specifications for  estimating control  costs are pre-
sented in  Table 10  for  two  models to produce 250-TPD  and 400-TPD
P205.  Venturi-packed systems are assumed installations for models
in lieu of venturi-cyclonic and packed combinations.   This
would be  the situation  for  the facilities where ammonia recovery is
practiced  only at the reactor-granulator during DAP processing.
    A summary of control costs for  granular  triple superphosphate
production is presented in Table ,11.  Unit costs  for all  control
systems are  $3.-96- per ton P20g for the 250-TFD model  and $3.56 per
ton P20g for the 400*TPD plant.   Storage control  costs alone are  $0.57
per ton P20g for the smaller plant and $0.50 per  ton P20g for the
larger plant.
    Run-of-pile triple superphosphate production  requirements
for emissions control  to meet the standards  of performance
ar2 presented in  Table 12.  Gas  streams from the  den, cutter, and
                                                                   101

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                                   TABLE 12.


CAPITAL AND ANNUAL CONTROL COSTS FOR RUN-OF-PILE  TRIPLE  SUPERPHOSPHATE  PRODUCTION

Model Plant Size ^205)

A. Engineering Specifications:
Gas to Scrubber, ACFM
Collector
Scrubbing Medium
B. Cost Summary
1. Capital Requirements ($)
2. Total Annual Cost ($)
250-TPD

400-TPD

I
60,000
Venturi Cyclone
100,000
Venturi Cyclone
Pond Water { Pond Water
315,000^
135,000
3. Unit Control Costs ($ per |
ton P205) 1-64
1
450,000^
200,000
1.52
* 'Scrubber portion of costs is $60,000;  auxiliary and  installation  costs are
   $255,000.


^ ^Scrubber portion of costs is $90,000;  auxiliary and  installation  costs are
   $360,000.
                                                                              105

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     storage are assumed to be combined and treated in a central  collec-
     tion system.  This is generally the practice in industry today.
     Control technology consists of a venturi cyclone followed by a
     packed scrubber, all with pond water as the scrubbing medium.
         For the selected model plants, unit control costs are $1.64 per
     ton P205 for the 250-TPD plant and $1.52 per ton P205 for the 400-
     TPD plant.  The basis for the capital estimates are the purchase
     costs of the venturi cyclone (A) in Table 7 and for the packed
     scrubber in (E); with auxiliary and installation costs for a storage
     facility (D).
 E.  Documentation of Reported Industry Data
     All data reported to EPA by industry for emissions control systems
 which are considered best demonstrated technology  for their respective
 process plants  have been compiled and analyzed.  A tabulation of these
 data and EPA estimates  derived for comparable bases are presented in Table
  13>  The  industry  reporting  has been  sparse,  and  only  qualitative  infer-
  ences  can  be  drawn from their analysis.
      Statistics are presented in Table 13  for  process capacity,  plant
  (battery  limits)  capital,  control  systems, capital,  and  year of installa-
  tion.   The capital  estimates reported by industry are  in actual  dollars
  and have  not  been  corrected  for inflation.  EPA estimates are in 1973
  dollars and have been developed from plant models presented earlier.
  Operating costs have not been analyzed due to insufficient, inconsistent
  reporting.
      In general, capital estimates of fluoride emissions  control systems
  are in agreement with EPA estimates for wet-process phosphoric acid,
  superphosphoric acid, and  granular  triple superphosphate processing.
  EPA estimates for run-of-pile production appear low probably because the
  costs for piping and ductwork associated with ventilating the storage area
  have been omitted.
106

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     In  terms  of percents  of battery  limits  plant capital, emissions
 controls for  solids  processing  as  shown  by  the  data  for ROP and GTSP,
 are the highest for  any process.   Emissions control  capital ranges
 from 15 to 25 percent of battery limits  plant  capital  for these process-
 es.  Control  systems for wet-process phosphoric acid production are
 5 to 10 percent.  Controls for superphosphoric acid  production  are
 about 6 percent for  the submerged combustion process.
      No conclusions  can be drawn from the reported industry data  concern-
 ing the impact of the recommended standards of performance
 F.  Cost-Effectiveness
     All processes considered for standards of performance have been
 assumed to require packed scrubbers as the best available demonstrated
 control technology.   The effectiveness of these scrubbers is based on
 the principle  of a concentration gradient  between gaseous fluorides in
 the effluent stream  and  the vapor phase in equilibrium with the scrubbing
 medium.   The outlet  concentration of the clean gas  is limited by the
 concentration  of the fluorine  in  the pond  water (which is somewhat a
 function  of  the pH)  and  the water temperature, both factors determining
 the vapor pressure  of fluoride in equilibrium  with  the liquid phase of the
  scrubbing pond water.   Removal  efficiency, or  adsorption efficiency
  (measured in transfer units)  requirements  depend  on the concentration
  of fluoride  in the  process streams.  Key design factors governing the
  number of transfer  units are  packing depth and packing materials.
      The relationship of cost  vs.  adsorption efficiency for packed
  scrubbers common to the industry is presented in  Figure  4  for a  range
  of 3 to 7 transfer units.  The annualized cost of the scrubber for  a
  500-TPD P205 wet-process phosphoric acid plant is selected as the  para-
  meter in Figure 4.   The choice of  the effluent gas stream of a wet-
  process phosphoric  acid plant is appropriate in discussion of cost-
  effectiveness  because this emission source is probably the most signi-
  ficant of all  sources under consideration and offers a wide range
108

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1_   PROPOSED STANDARDS OF PERFORMANCE FOR PHOSPHORIC ACID PLANTS.

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      of absorption efficiency possibilities, depending on choice of packing
      depth.   An underlying assumption for these costs are the design condi-
      tions of pond water temperature, selected as 80ฐF, and acid concentration
      (hydrofluoric), measured as pH 2.0.     In the day-to-day applications,
      absorption efficiency will vary as these characteristics of the pond
      water change.
          For the-purpose of illustrating cost-effectiveness,  four  levels  of
      control with the appropriate costs are presented below.
                                                       Incremental     Incremental
                                          Total         Fluorides      Cost per
                                                        Captured..
Level    Efficiency, %
  A           95.00
  B           98.90
  C           99.40
  D           99.91
     Based on 500-TPD model plant  (see Table 5)
     Based on emission rate of 1.8  F per  ton P205<
Annual
Cost, $(')
23,380
23,500
23,900
24,450
Incremental
Cost, $
23,380
120
400
550
                                                  Tons/Year^2)
                                                      141
                                                        5.8
                                                        0.74
                                                        0.6
Incremental
  Ton, $
166
20.7 (B over A)
540 (C over B)
724 (D over C)
    As the  results show, cost per unit of fluoride captured decreases
somewhat  above the base level efficiency of 95 percent.  The reason for
this is that much of the capital, which is spent for installation and
erection  of the control device, and operating costs for labor and utilities
would be  unchanged for the fpur control levels.  As absorption efficiency,
approaches  level D, cost per unit rises rapidly and will rise exponentially
beyond D  as pond water equilibrium conditions are approached by the
fluoride  content of the effluent gas stream.
    The following tabulation shows the required transfer units to comply
with proposed limits the phosphate manufacturing processes subject to
standards of performance,
            Source      Standards  of  Performance               MTU
                             0.02 Ib F/ton P20g                4.5
                             0.06 Ib F/ton P205                2.0
                             0.20 Ib F/ton P205                3.0
                             0.20 Ib F/ton P205                4.5
                             0.0005 Ib per hr F/ton  P^       1.0
                             0.01  Ib F/ton P205                8.9
                 WPPA
                 DAP
                 GTSP
                ROP-TSP
              GTSP storage
      submerged  combustion  SPA
110

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    The emission data from which the above NTU's were derived are based on
    test data collected by EPA on those plants chosen for the best demon-
    strated control  systems.
         These data  generally show that the proposed standards  of performance
    for the various  selected  processes  would appear on the lower end  of the  cost
    effectiveness curve, Figure 4.  From the standpoint of total  costs, setting
    a standard at higher levels, such as the requirement for SPA, would result in
    very negligible  incremental costs.   The overriding factor would appear to be a
     technical one.  The pond water conditions represent the obvious constraint
     to achievement .of  high transfer  units.  Stripping of  fluorides from feed
     materials in  the various processes  in  quantities  over what constitutes
     normal conditions  would  add to the  inlet  loadings to  the scrubber  and tend
     to increase  the emission levels.   Particulate  plugging of scrubber
     packing  would reduce  effective absorption surface and efficiency.
         In conclusion, the recommended standards and even standards  at levels
     higher than those  recommended are  not prohibited  by cost.

IV.   Economic Impact of Standards of Performance
     A.   General  Discussion
         According to the  Clean Air Act, promulgation of Standards of Per-
     formance for a  designated  pollutant would require States  to  formulate
     implementation  plans  with  emission regulations for existing  sources
     emitting fluorides in a  manner similar to state implementation plans  for
     attainment  of National Ambient Air Quality  Standards  (NAAQS).. As  a
     result of this  legal  mandate, the  economic  impact of the  proposed  standards
     of performance  may have  farther  reaching  consequences than  what  the fol-
     lowing analysis will  show  for new  phosphate  facilities.  The  economic
     impact of emission limitations on  existing.facilities that would result
     from the promulgation of state standards  is  not in  the scope  of  this anal-
     ysis.
     B.   Total Pollution Abatement
         Development Planning and Research  Associates (DPRA)  conducted  an  investi-
     gation of the economic effects of  water pollution abatement  on the fertilizer
     industry.   They presented  model  plant  investments for appropriate  model plant
     phosphate facilities. For example, for an  integrated phosphoric acid plant com-
     plex producing  diammonium  phosphate as its  final  product, capital  investments
     for  double  liming  and primary clarification  as specified water treatment are
                                                                                 111

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about $4,000,000 for a 900-TPD (P205) Plan* compared with some $40,000,000
total plant capital invested for phosphoric acid, ammonia, and solids pro-
cessing facilities.  Reported annual water abatement costs (depreciation,
operating expense, maintenance costs) are approximately $3.00 per ton P20g
product.  For the 500-T'PD model plant, abatement costs are an approximate $4.00
per ton PoOr.  In terms of product price, these estimates would be approximately
r        2 5
$1.50 and $2.00, respectively.
    DPRA indicated that increased abatement costs for diammonium phosphate
(and phosphoric acid, which is the intermediate product) could be passed on
to the consumer to the extent of $4.00 per ton product.  This would allow the
more efficient (and larger size) producers to pay for the water abatement
equipment and maintain profitability at a rate equivalent to 8 percent or
better on their capital investment.  According to DPRA analysis, the smallest
viable producer under this assumption would be a 170,000 ton per year plant
(235-TPD P205).  New plants entering the fertilizer market would be larger
than this size because of increased investment requirements per unit capacity
and higher expected rate of return for attracting new venture capital into
this industry; hence, the rationale for the 5QTJ?TPD plant assumed as the
"small model plant" in this analysis for the standards of performance.
     The price increases  are expected for the following reasons.   The
 demand for fertilizer is  fairly inelastic,  cross elasticities  between
 competitive phosphate products notwithstanding.   Second the price level
 of all  fertilizers is substantially lower than  a decade ago,  which has  been
 possible through  improvements in technology in  ammonia and wet-process
 phosphoric acid processing.   Thirdly,  prices at the retail  level  are double
 those at the production  level.  Hence, a $4.QO  increase in DAP (  or 6 to
 7 percent of the  producers'  sales'price)1 is only 3 percent at the consumer level.
     With this background  information on the ability of the fertilizer industry
 to pass along costs above current price levels,  the impact of abatement
 under the standards of performance will be analyzed.
112

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C.  Impact of Control Costs on Model Plants    ,                      ,
    Table 14'presents a summary of annualized control  costs for all the
processes under consideration for standards of performance. .The control
costs are presented on both a total product basis and a P205 basis.
Measure of control costs as a percent of sales is also presented for the
various products.  Lastly, a column for impacts due directly to Federal
standards of performance is presented, that is, the difference in costs
between the proposed Federal standards of performance and an existing
stringent State regulation.  The Florida regulations are deemed as the. most
stringent in the U.S. today and are assumed as the applicable State standard for
comparison with the  Federal standards of performance.  The actual allow-
able effluents for the various processes under the Florida regulation
are not comparable with those under the Federal standards of performance
because of differences in emission measurement techniques.  Therefore,
model plant control  configurations as presented in the tables in Section
III are assumed t.o comply with Florida's standards; any control less ef-
fective than the model plant  control configurations will not comply with
Florida's regulation.
    1.  General Discussion of Plant Costs
        As Table  14  shows, only triple superphosphate seems high in
    magnitude of  costs relative to  fluoride emissions control cost for
    other processes.  The costs for granular  triple superphosphate seem
    prohibitive,  in  particular; however, as pointed out earlier, a com-
    plex that can capably produce  two products (DAP and GTSP) interchange-
    ably with the same solids manufacturing facility can optimize  utiliza-
    tion of the owner's capital by  operating  his phosphoric acid plant at
    full capacity and produce a product mix that will maximize his profits.
    It is important  to point  out that basically the same emission  control
    equipment is  used in both DAP and GTSP production.
         If ammonia credits are excluded from  the DAP recovery system,  con-
    trol costs for the average DAP  plant (midway between 500-TPD and 800-TPD
    P205) would be $1.60 per  ton P205 for  control of the reactor-granulator,
    drier, and cooler process streams.  An estimate of costs for control
                                                                               113

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of similar process streams within the same plant for 6TSP production
would be $2.60 per ton P205.  Hence, GTSP processing would cost $1.00
per ton more than DAP processing and require an additional $1.60 per
ton P205 for control of emissions during storage.
    The costs of emissions control as shown in Table 14 for run-of-pile
triple superphosphate are low in comparison with GTSP; however, ROP-TSP
is an intermediate product sold to an NPK plant, which would have to
granulate a finished product from this intermediate material and incur
internal costs of emissions control in addition to the $1.58 per ton
P2C>5 incurred at the ROP-TSP processing level.  Therefore, the NPK
plant operator would have to superimpose this incremental cost into his
overall cost structure, which would include his own internal control ex-
penses and the price of various phosphate substitutes (wet-process
phosphoric acid, DAP, GTSP) available to produce NPK fertilizers.
    The costs for the submerged combustion process of producing super-
phosphoric acid represent the annualized costs for application of a •  ,.,
venturi-cyclone/packed scrubber system, that is a transfer of technology
from diammonium phosphate production.  The costs are presumed for a
plant exhibiting no control although this is not quite the case as
evident from industry correspondence.  On the other side of the coin,
the costs do not take into account engineering, design, testing, and
start-up for a system that has not been effectively demonstrated on a
submerged combustion plant.
2.  Impact of Federal Standards over State Standards
    Table 14 summarizes the cost differences between the Federal stand-
ards of performance and correspondingly stringent State standards.  The
state of Florida requires new plants to employ control systems as effec-
tive as those assumed in the model plant configurations, with one excep-
tion—the submerged combustion process for producing superphosphoric
acid.  Hence, one direct impact of the Federal standards of performance
would be the imposing of a universal cost penalty of some 28 cents per
ton P205 on the submerged process plant.   As this amounts to only 0.13
percent of sales, there should be no impact.
                                                                      115

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       For diammonium phosphate and GTSP facilities in States other than
   Florida, the Federal standards of performance would have a direct im-
   pact.  Secondary scrubbers required for DAP facilities in these areas
   would cost an additional 43 cents per ton P205, storage facilities
   would require fluoride control at a cost of $1.61 per ton P205 manu-
   factured.  Triple superphosphate facilities in areas other than
   Florida probably have some fluoride emission control on the reactor,
   but probably not on driers and coolers'in granulating facilities.  Pri-
   mary scrubbers would be  required anyway for particulate emissions regu-
   lations applicable under NAAQS.  Secondary scrubbers for fluoride re-
   moval on new GTSP plants in these areas might require an additional  64
   cents per ton P205, in addition to the control costs for storage.  As
   some 80 percent of triple superphosphate production is confined  to
   Florida and will remain  so in the future, the impact of the standards
   of performance will be minimal on this portion of  the industry.
        Lastly, there will be no  impact on wet-process phosphoric  acid
   plants  or the vacuum evaporation production of SPA for emissions con-
   trol  imposed by the standards of performance.  No  impact  is expected
   for  ROP triple superphosphate because  of declining trends  in production,
   as cited  earlier.
        For plants built elsewhere  than  the state of Florida,  some impact
    due  to  the  standards of  performance may be  expected  for  diammonium
    and  granular  triple  superphosphate for the  reason  that States  other
    than Florida  have  not  required  as stringent control  of fluorides.
D.   Impact  of Standards  of Performance on  the  Phosphate  Industry
    For  most  of the  processes  under consideration  for standards of performance,
control  costs associated with  fluoride  emission control  are  small.  Assuming
trends as shown in Figure  3, price  increases  seem to be  in  prospect in the forsee-
able future.   The reasons  for this  are  as  follows:   (1)  with elimination of
smaller, high cost operations, supply-demand relationships are improving for the
producers,  (2) effects of dollar devaluation  provide an assist for the domestic
industry by making exports more attractive to foreign markets, (3) internal
dynamics of the industry trending toward bulk blending and liquids production
which offer cost savings at the retailer level  of the industry, and (4) in-
creased crop production increasing demand for fertilizers as result of a cur-
rent world-wide shortage of grain supplies.  In general, cost increases in
production as a result of promulgating standards of performance on new sources
will  be readily absorbed into increased prices at the consumer level.
116

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    One area of possible impact would be GTSP production.   As this product
competes with DAP for mixtures production, the higher costs under the
standards of performance on a unit ton (P2ฐ5) basis with respect to DAP
would be a deterrent for the producer who sold in the market bidding for
mixture materials.  For a direct application of fertilizer to the soil,
this situation would not exist and the GTSP producer would pass costs along.
    As discussed earlier, the effects of the dollar devaluation should
benefit agricultural fertilizer producers.  As the magnitude of devaluation
far overshadows cost increases for fluoride emission control, no impact on
foreign trade is readily foreseen as a result of the promulgation of the
Federal standards of performance.
                                                                       117

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1.  Harre, Edwin A., Fertilizer Trends—1969, National  Fertilizer Development
    Center, Tennessee Valley Authority, Muscle Shoals,  Alabama.

2.  Private Communication with William White, Fertilizer Institute,  May 18,
    1973.

3.  Chemical Construction Company, unpublished report on a marketing survey
    of the fertilizer industry, EPA Contract No.  70-156, 1971.

4.  Initial Analysis of the Economic Impact of Water Pollution  Control  Costs
    Upon the Fertilizer Industry, Development Planning and Research  Associates,
    A Report to the Environmental Protection Agency, Contract No. 68-01-0766,
    November 1972.

5.  "Soviet and Occidental Oil in Multibillion-Dollar Deal", New York Times,
    April 13, 1973.

6.  U. S. Industrial Outlook 1972 (With Projections to 1980), U. S.  Department
    of Commerce, Bureau of Domestic Commerce, April 1972.

7.  Harre, E. A., Kennedy, F. M., Hignett, T. P., and McCure, D. L., Estimated
    World Fertilizer Production Capacity as Related to Future Needs  1970 to
    1975, National Fertilizer Development Center, Tennessee Valley Authority,
    Muscle Shoals, Alabama.

8.  Hardison, L. C., Air Pollution Control Technology in Seven Selected Areas,
    Report prepared for Environmental Protection Agency under Contract No.  68-
    02-0289 by the Industrial Gas Cleaning Institute, 1973.
     118

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                                  TECHNICAL REPORT DATA
                           (Please read Instructions on the reverse before completing)
 REPORT NO.
 EPA-450/2-74-019a
                                                          3. RECIPIENT'S ACCESSION-NO.
 TITLE AND SUBTITLE BACKGROUND  iNhORMAI ION HJk SiANUAKUb  Uh
 PERFORMANCE:  PHOSPHATE  FERTILIZER INDUSTRY
 VOLUME 1.  PROPOSED STANDARDS
                                                          5. REPQBT.DATE
                                                                       1974
                                                          6. PERFORMING ORGANIZATION CODE
. AUTHOR(S)
                                                          8. PERFORMING ORGANIZATION REPORT NO.
. PERFORMING ORGANIZATION NAME AND ADDRESS
  U.S. Environmental  Protection Agency
Office of Air and Waste  Management
Office of Air Quality  Planning and Standards
Research Triangle Park,  N.C. 27711	
                                                          10. PROGRAM ELEMENT NO.
                                                          11. CONTRACT/GRANT NO.
 2. SPONSORING AGENCY NAME AND ADDRESS
                                                          13. TYPE OF BEPOR.T AND PERIOD COVERED
                                                                   FfnTl
                                                          14. SPONSORING AGENCY CODE
 5. SUPPLEMENTARY NOTES
16. ABSTRACT
 This document provides background information  on  the derivation of the  standards of
 performance for  the  phosphate fertilizer  industry.   Volume 1 provides a general
 description of the facilities for which standards are proposed and provides  the  ration
 rationale for the proposed standards of performance.  Included is an analysis  of the
 economic impact  of the standards on the industry.  The proposed standards  require
 control at a level typical of well controlled'existing plants and attainable with
 existing technology.   To determine these  levels,  extensive on-site investigations were
 conducted, and design factors, maintenance  prartice, available test data,  and  the
 character of emissions were considered.
                               KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                              b.lDENTIFIERS/OPEN ENDED TERMS
                                                Air Pollution Control
                                                                        c.  COSATI Field/Group
 Air Pollution
 Pollution control
*Performance  standards
*Phosphate fertilizer industry
*Wet-process  phosphoric acid plants
*Superphosphoric acid plants
*Diammonium phosphate plants
                                              *Run-of-pile  triple superp
                                              *Granular triple  superpho"
                                              *Granular triple  superpho
 hosphate plants
 phate  plants
iphate  storage
18. DISTRIBUTION STATEMENT

  Unlimited
                                              19. SECURITY CLASS (ThisReport)'
                                                Unclassified
 >1. NO. OF PAGES
     148
                                              20. SECURITY CLASS (Thispage)
                                                Unclassified
                                                                        22. PRICE
6PA Form 2220-1 (9-73)
                                          119

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