EPA-450/3-79-017
Phosphate Rock  Plants  -
 Background  Information
 for  Proposed Standards
    Emission Standards and Engineering Division
    U.S. ENVIRONMENTAL PROTECTION AGENCY
       Office of Air, Noise, and Radiation
    Office of Air Quality Planning and Standards
    Research Triangle Park, North Carolina 27711

           September 1979

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I
               This report has been reviewed by the Emission Standards and Engineering Division of the Office of Air
               Quality Planning  and Standards, EPA, and approved for publication. Mention of trade names or
               commercial products is not intended to constitute endorsement or recommendation for use. Copies of
               this report are available through the Library Services Office (MD-35), U.S. Environmental Protect.on
               Agency. Research Triangle Park, N.C. 27711; or, for a fee, from the National Technical Information
               Services,  5285 Port Royal Road, Springfield, Virginia 22161.
                                            Publication No. EPA-450/3-79-017

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                        Background Information
                               and Draft
                    Environmental Imoact Statement
                       for Phosnhate Rock Plants

                    Tyoe of Action:   Administrative

                             Prepared by:
 Don R.  GoodwirV
 Director,  Emission  Standards  and  Engineering  Division
 Environmental  Protection  Agency               ^vision
 Research Triangle Park, North  Carolina  27711

                           Aoproved by:
                                                              (Date)
David G. Hawkins
Assistant Administrator for Air, Noise and Radiation
Environmental Protection Aaencv            Kaaiation
Washington, D. C.  20460  "

Draft Statement Submitted to EPA's
Office of Federal Activities for Review on
 This  document  may  be  reviewed  at:

 Central  Docket Section
 Room  2903B, Waterside Mall
 Environmental  Protection Aqency
 401 M Street,  S.W.        "
 Washington, D.  C.  20460

 Additional cooies may be obtained at:

 Environmental  Protection Agency Library (MD-35
 Research Triangle Park,  No?th Carolina  27711
                                                             (Date)
                                                           7//7/71
                                                             (Date)
coon   Techn1cal Information Service
5285 Port Royal Road
Springfield, Virginia  22161

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IV

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                              TABLE OF CONTENTS
                                                                   Page
Chapter 1.  SUMMARY		   1-1
  1.1       Proposed Standards	.  ;  .   i-i
  1.2       Environmental and Economic Impact	   1-5-
  1.3       Economic Impact Analysis  	   1-9
Chapter 2.  INTRODUCTION	   2-1
  2.1       Authority for the Standards	.  .  .   2-1
  2.2       Selection of Categories of Stationary Sources.  .  .  .   2-6
  2.3       Procedure for Development of Standards of
             Performance	   2-8
  2.4       Consideration of Costs	  .  .   2-11
  2.5       Consideration of Environmental  Impacts .......   2-12
  2.6       Impact on Existing Sources	   2-14
  2.7      .Revision  of Standard of Performance	   2-15
Chapter 3.  PHOSPHATE ROCK PROCESSING INDUSTRY 	 ...   3-1
  3.1       General	  '3-1
  3.2       Processing  Methods - General  ............   3-4
            3.2.1   Mining and Beneficiation	'. . .   3-4
            3.2.2   Drying.	   3.3
            3.2.3   Calcining	   3-12
            3.2.4   Crushing  and  Grinding  ............   3-14
          t  3.2.5   Materials Handling and Storage	   3-20
  3.3       Process Emissions  as Restricted by Typical  and Most
            Stringent  State Regulations  	  ...    3-24

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                                                                  Page
  REFERENCES	,	  3-27
Chapter 4.  EMISSION CONTROL TECHNIQUES 	  4-1
  4.1      -Mining	4-1
  4.2       Beneficiation	4-1
  4.3       Conveying of Wet Rock	4-1
  4.4       Phosphate Rock Drying	4-2
            4.4.1  Scrubbers. .	  .  4-2
            4.4.2  Electrostatic Precipitators. . 	  4-4
            4.4.3  Fabric Filters	4-5
  4.5       Phosphate Rock Calciners	4-10
            4.5.1  Scrubbers	4-12
            4.5.2  Electrostatic Precipitators	4-12
            4.5.3  Fabric Filters	4-12
  4.6       Grinding	4-14
            4.6.1  Scrubbers	4-14
            4.6.2  Electrostatic Precipitators	4-16
            4.6.3  Fabric Filters .	4-16
  4.7       Materials Handling and Storage	4-18
  4.8       Wet Grinding	4-19
  REFERENCES	  4-21
Chapter 5.  MODIFICATION AND RECONSTRUCTION	 . .  .  5-1
  5.1       40 CFR Part 60 Provisions for Modification and
             Reconstruction	5-2
            5.1.1  Modification	5-2
            5.1.2  Reconstruction	'	5-3
  5.2       Applicability to Phosphate Rock Processing
             Operations	5-4
                                     vi

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                                                           '       .Page
            5.2.1  Modification	   5-4
            5.2.2  Reconstruction	 .  .  .   5-5
Chapter 6.  ENVIRONMENTAL IMPACT 	   6-1
  6.1       Introduction 	 .........   6-1
  6.2       Environmental Impact of Standards of Performance  .  .   6-2
            6.2.1  Air Impact	• .  .  .   6-2
                   6.2.1.1   Emissions Limited by State
                             Implementation Regulation .;. .  .  .   6-2
                   6.2.1.2   Uncontrolled Particulate Emissions  .   6-4
                   6.2.1.3   Particulate Emissions Levels
                             Achievable Using Alternative
                             Control  Systems 	   6-7
                   6.2.1.4   Particulate Emission Reductions
                             Due to Standards of Performance  .  .   6-7
                   6.2.1.5   Atmospheric Dispersion Modeling.  ,  .   6-12
           .6.2.2  Solid Waste Impact	 .  .  .   6-19
            6.2.3  Energy Impact	 .  .  .   6-21
                   6.2.3.1   Current Energy Usage . .  . .!. .  .  .   6-22
                   6.2.3.2   Energy Increase Resulting from More
                             Stringent Levels of Control  ....   6-26
                   6.2.3.3   Summary of Energy Impact . ...  .  .   6-28
            6.2.4  Water Impact.	.......    6-29
            6.2.5  Radiation Impact	........    6-31
            6.2.6  Resource and Trade-Off Analysis .......    6-33
  6.3       Alternative Action Plans	    6-34
            6.3.1  Continued Use of SIP Regulations.  ......    6-35
            6.3.2  Establishing Levels of Control for New
                    Sources	    6-35

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            6.3.3  Delaying the Establishment of Standards
                    of Performance. .  ."'. .... ". .  .  .  '.""'. .   6-37
  REFERENCES	6-38
Chapter 7.  ECONOMIC IMPACT	   7-1
  7.1       Phosphate Rock Industry Economic Profile	7-1
            7.1.1  Industry Structure  	   7-1
            7.1.2  1977 Production of Phosphate Rock	7-5
            7.1.3  Consumption Pattern for Phosphate Rock  ....   7-8
            7.1.4  U.S. Phosphate Rock, Inventory Stocks	-7-10
            7.1.5  U.S. Trade Patterns and World Phosphate
                    Rock Situation.	7-10
            7.1.6  Recent Industry Performance and Prices  ....   7-13
            7.1.7  Industry Outlook and Growth Projections.  .  .  .   7-21
  7,2       Cost Analysis of Alternative Emission Control  Systems   7-30
          •  7.2.1  Introduction 	 	   7-30
            7.2.2  Cost of Alternative Control  Measures  	   7-34
                   7.2.2.1   Calciner Model  Facility .......   7-37
                   7.2.2.2  Dryer Model  Facility	7:41
                   7.2.2.3  Grinder Model Facility. .......   7-51
                   7.2.2.4  Ground Rock Transfer Systems.  ....   7-52
                   7.2.2.5-  Monitoring Costs.	,.   7-57
  7.3       Other Cost Considerations	7-59
  7.4       Economic Impact Analysis of Alternative Emissions
             Control  Systems	  .  .   7-61
            7.4.1  Introduction	  .-7-61
            7.4.2  Model  Plant Analysis  for  the Florida  Region.  .   7-62
                   7,4.2.1   Investment and Operating  Costs  for a
                             New Uncontrolled  Florida Plant .  .  ,
                                   viii
7-62

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                   7.4.2.2   Summary of Control  Costs  for
                             Florida Model  Plant	  ..   7-67
                   7.4.2.3   Economic Impact on  New Model  Plant.  .   7-74
                   7.4.2.4   Economic Impact on  Modified Model
                             Plant.	  .  .  .   7-78
            7.4.3  Model  Plant Analysis for the Western Region.  .   7-81
                   7.4.3.1   Investment and  Operating  Costs for
                             a New Uncontrolled Western Plant  .  .   7-81
                   7.4.3.2   Summary of Control  Costs  for Western
                             Model Plant.	7-82
                   7.4.3.3   Economic Impact on  New Model  Plant.  .   7-91
                   7.4.3.4   Economic Impact on  Modified Model
                             Plant	   7-94
            7.4.4  Summary  of Economic Impact on New  and
                    Modified Phosphate Rock Plants. ........   7-96
  7.5       Potential  Socioeconomic and' Inflationary  Impacts.  .  .   7-98
  REFERENCES	-......-	7-102
Chapter 8.  RATIONALE FOR THE PROPOSED STANDARD 	   8-1
  8.1       Selection of Source for Control	   8-1
  8.2       Selection of Pollutants and Affected Facilities ...   8-4
  8.3       Selection of the Best System of Continous Emission
             Reduction Considering Costs	8-9
  8.4       Selection of the Format	   8-16
                                                          i
  8.5       Selection of Emission  Limits	8-24
            8.5.1  Dryers	8-25
            8.5.2  Calciners	   8-28
            8.5.3  Grinders	8-31
            8.5.4  Ground Rock Transfer Systems 	   8-35
                                    ix

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  8.6
  8.7
  8.8
  8.9
                                                      Page
Visible Emission Standards	8-37
8.6.1  Proposed Visible Emissions Standards 	  8-38
8.6.2  Measurement Difficulties for Steam Plumes. .   .  8-42
Modification and Reconstruction Considerations.  . .   .  8-44
8.7.1  Modification	8-44
8.7.2  Reconstruction	8-46
Selection of Monitoring Requirements. ........  8-46
8.8.1  Phosphate Rock Dryers and Calciners	8-48
8.8.2  Phosphate Rock Grinders and Ground Rock
        Handling Systems	  8-49
Selection of Performance Test Methods 	  8-50
  REFERENCES ............ ...............  8'51
Appendix A. Evolution of the Selection of the Best System of
             Continuous Emission Reduction ............  A-l
                                                       B-l
                                                       C-l
Appendix B. Index to Environmental Impact Considerations .....
Appendix C. Summary of Test Data .................
Appendix D. Emission Measurement and Continuous Monitoring. ...  D-l
Appendix E. Enforcement Aspects ........... ......  E-1
Appendix F. The- Stack Gas Dispersion Model .......... .  •  F-l
Appendix G. Conversion from English to Metric Units  .......  6-1

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                                1.  SUMMARY

 1.1  PROPOSED STANDARDS

     Standards of performance for phosphate rock plants are being proposed
 under the authority of Section 111 of the Clean Air Act.  Accordingly, the
 aim of the proposed standards is to require the best demonstrated technology
 (considering cost and nonair quality health and environmental  impact and
energy requirements) for the control  of particulate emissions  be installed
and properly operated at new, modified, and reconstructed phosphate rock
plants.   The proposed standard is  based on information presented in this
document and derived from 1) available technical  literature on the phosphate
 rock industry and applicable emissions control  technology, 2)  technical
 studies  performed for EPA by independent research organizations, 3) data
 obtained from the industry during  visits to phosphate rock plants and com-
munications with various representatives of the industry, 4) comments and
suggestions solicited from experts,  and 5) the  results of emissions measure-
ments conducted by EPA and the industry.  In accordance with Section 117 of
the Clean Air Act, proposal  of the standards was  preceded by consultation
with appropriate advisory committees, independent experts, industry repre-
sentatives, and Federal  departments  and agencies.
     A summary of the proposed standards and monitoring requirements is  pre-
sented in Table 1-1.  The proposed standards limit particulate emissions from
 dryers,  calciners, grinders, and phosphate rock handling/storage facilities.
 For each facility, the best system of continuous  emission reduction,' consider-
 ing cost and nonair quality health and environmental  impact and energy require-
 ments, was determined to be the baghouse or the high energy scrubber. However,
                                   •1-1

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the high efficiency electrostatic precipitator (ESP)  was  judged to  be equally as
effective a particulate emissions reduction system as the baghouse  or high  energy
scrubber.  The'proposed standards are,  therefore,  based on the use  of any of the
three alternative emissions reduction systems.  Cost  considerations would favor
the use of the baghouse or high energy  scrubber over  the  electrostatic precipita-
tor, and the incremental  nonair quality adverse impacts associated  with the alter-
native controls would favor the use of  the baghouse (especially for grinders and
phosphate rock handling/storage systems)  over the  scrubber and ESP.
     The proposed standards for phosphate rock dryers limit emissions to
0.02 kilogram of particulate matter per megagram of rock feed (0.04 Ib/ton)
and 0 percent opacity.  These standards are based on EPA source tests at
two representative phosphate rock plants processing Florida pebble  rock,
and related experience concerning the  identified  "best system of continuous
emission reduction."  The  test data are summarized in Figures 8.4,  8.5 ard 8.6.
The results of the tests show that the dryer  controlled by a venturi scrubber
operating at a pressure drop of 18 inches of water'will achieve an  emissions
level of about 0.019 kg/Mg, while the dryer employing an electrostatic precipi-
tator and scrubber system  for control achieved an emission level of 0.012 kg/Mg
during tests conducted by  the EPA.  The level of control  (99.2%) attained by
the venturi scrubber at 18 inches of pressure drop is nearly equivalent to  that
which would be expected using the best system of emissions reduction (the bag-
house or a high energy venturi scrubber operating at 25 inches of water pressure
drop).  Consequently, it is concluded that the emissions  level of 0.02 kg/Mg
reflects the control  attainable by the best system of emissions reduction.
      The proposed standards for phosphate rock calciners limit emissions to
 0.055 kilogram of particulate matter per megagram of rock feed (0.11 Ib/ton)
                                    1-3

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 and 0 percent opacity.   These standards  are  based mainly  on  EPA source  tests
 at two representative phosphate rock calciners  processing western  benefi-
 ciated and unbeneficiated  phosphate rock.   The test  data are  summarized in
 Appendix C.   One of the  calciners  employed a high energy  wet scrubber con-
 sidered to be representative  of the  best system of emissions reduction.  The
 other calciner employed  a wet scrubber with  collection  efficiency  somewhat
 less than that reflecting the best system of emissions  reduction.  For  this
 calciner, the expected level  of control  which would be  achieved  by the  best
 system of emissions reduction was  estimated  by  adjusting  emissions test data
 to reflect operation  of  the venturi  scrubber at an  elevated  pressure drop
 of 27 inches  of water.   These adjusted emission levels, as well as those
 measured for  the existing high energy scrubber,  are consistent with the
 level  of control  being proposed as the limit of the standard.

      The  proposed standards for  phosphate rock  grinders limit emissions  to
 0.006 kg/Mg  of rock  feed (0.012 Ib/ton)  and 0  percent  opacity,  These stan-
 dards  are  based  on  EPA source  tests at four separate grinder facilities
 representing  a wide range of exhaust air rates, grinder designs, capacities,
 and  product feeds.  Emissions  from all the facilities  were controlled by bag-
 houses.  The  level  of control   reflected by the proposed emissions limit  has
 been set  slightly greater than the value attained by baghouses  in the tests
 to account for potential   inaccuracies in  the  feed rate data  compiled
 during the source tests.   However, the potential liberal level  of the
 standard should not preclude installation of  the best  system  of emissions reduc-
tion in new and modified facilities.   Baghouses  are the prevailing  control
 approach  now  employed to meet existing standards far less  stringent than
 the  proposed  standard.  Moreover,  the proposed  emis$ions limit is lower
                                    1-4

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than that which would be attained by any other control system economically
comparable to the baghouse.                                      '    '

     The proposed standard for ground phosphate rock material handling and
storage systems limit emissions of particulate matter to 0 percent opacity
from any point in the transfer system.  The standard is based on EPA source
tests at three separate rock transfer facilities utilizing pneumatic systems,
Experience shows that no visible emissions occur from the enclosures when
the process equipment is properly maintained...  Because of the wide varia-
tion in handling and storage facilities, a visible emissions standard is.
the only standard appropriate for these facilities.     •!        •••

     The proposed opacity standards help to assure that emission control
systems are properly maintained and operated so as to comply with the mass
emission standards on a continuous basis.  The opacity standards
have been proposed on the basis of tests performed at facilities repre-
sentative of best emissions control technology currently employed by the
industry.  The test data are summarized in Appendix.C.

1.2  ENVIRONMENTAL AND ECONOMIC IMPACT                   I

    . Estimates, of. the relative beneficial and adverse impacts associated
with the proposed standards and the various candidate emission control
alternatives are presented in Table 1-2.  The judgements  presented in the,
matrix of Table. 1-2 are based on the environmental  impact analysis  of
Chapter 6 and the economic impact analysis of Chapter 7.   A cross  reference
between the EPA guidelines for the preparation of Environmental  Impact
Statements and this document is included in Appendix B.
                                   1-5

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     The impact of the standard is judged by comparing the consequences of
imposing the standard to the consequences expected to result under current
State implementation regulations.  Accordingly, the matrix compares the
impact of each candidate control capable of achieving the proposed standard
with the prevailing controls (baseline controls) now being employed to meet
typical State implementation regulations.

     For both the phosphate rock dryer and calciner, the low energy wet
scrubber is the baseline control system upon which the impacts associated
with the other control alternatives are measured.  Compliance with the pro-
posed standard (by application of any of the three candidate control systems)
will improve air quality significantly over that attained by the low energy
scrubbers.  Emissions from dryers would be reduced by approximately 85 percent
below the levels required by a typical State standard, and emissions from
calciners would be reduced by about 88 percent below the typical State requi-
rements.  The maximum 24-hour average ambient air concentration of particu-
late matter due to emissions from a typical dryer or calciner controlled to
the level of the proposed standard would be about 88 vg/m3 and 14yg/m3,
respectively.
     The secondary environmental impacts due to the proposed, standards for
dryers and calciners are expected to be minimal with two exceptions:  1)  the
economic impact incurred when high efficiency electrostatic precipitators
are used to achieve the standard, and 2) the energy impact when high energy
wet scrubbers are employed.  Utilization of the electrostatic precipitator
for control  of dryer and calciner emissions would increase overall  production
costs (over costs to meet SIP regulations) by about 2.2 or 5.3 percent,
                                     1-7

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respectively.  Utilization of the high energy scrubber would increase total
energy requirements of the dryer and calciner processes by about 8 percent.
The magnitude of either of these impacts would not preclude the use of the
associated control system.  However, it is expected that the baghouse and the
high energy scrubber would provide the most economical means of achieving the
proposed levels of control for dryers and calciners, and the likelihood of
operators installing electrostatic precipitators to comply with the NSPS appears
remote.  Installation and operation of baghouses for control  of dryer or calciner
emissions is expected to increase overall  production costs at any given plant by
about 0.1 and 0.3 percent, respectively.   Similarly, the increase in produc-. ,
tion costs when high energy scrubbers are  employed to meet the  proposed stand-
ards for dryers and calciners would be about 0.4 and 1.2 percent, respectively.

     The amount of water required for air pollution control of dryer and
calciner emissions is small in comparison  with the large volumes of process
waters used for other purposes.  The incremental increase  (over the baseline
control) of solid materials and radiochemical pollutants collected from wet
control  devices  designed  to  attain  the standard  is  negligible  compared to
the total amounts already collected by the baseline controls and still
more inconsequential when compared to the total  quantity of solid wastes
produced in the mining and processing of phosphate rock.

     For the phosphate rock grinder and rock transfer systems,  the  baghouse
is the baseline control  system upon which  impacts associated with other con-
trol alternatives are assessed.   The prevailing  control  practice in the
industry is to employ baghouses  to control  grinding and  transfer systems.
Because the system of best emission reduction is  currently  utilized to meet

                                    1-8

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State implementation regulations, the more stringent emission limits of the
proposed standard are not expected to result in significant impact.  If .
alternative controls (other than the baseline control) are utilized (e.g.,
the wet scrubber) to meet the standards, only small secondary incremental
impacts would be expected to occur.  (See Table 1-2.)

1.3  ECONOMIC IMPACT ANALYSIS
     Executive Order 12044, dated March 24, 1978,  requires executive
branch agencies  to  prepare  regulatory analyses for regulations that may
have major economic consequences.  The screening criteria used by EPA to
determine if a proposal  requires a regulatory analysis under Executive
Order  12044 are:  1) additional national annualized compliance costs, in-
cluding capital  charges, which  total $100 million  within any calendar year
by the attainment date,  if  applicable, or within five years; and 2)  a
major  increase in prices or production costs.             ;
     The  impacts  associated  with the  proposal  of  performance  standards for
phosphate  rock  plants  do not exceed the  EPA  screening  criteria.   Therefore,
promulgation of the  proposed standard does not constitute  a major action
requiring  preparation  of an  economic  impact  analysis  under the  Economic
Impact Statement Program.
                                   1-9

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                             2.   INTRODUCTION

      Standards  of performance  are proposed following a detailed investi-
 gation  of air pollution  control  methods  available  to the  affected  industry
 and  the impact  of their  costs  on the  industry.   This document summarizes
 the  information obtained  from  such  a  study.   Its purpose  is  to explain  in
 detail  the  background  and  basis  of  the proposed  standards  and to facilitate
 analysis  of the proposed  standards  by interested persons,  including  those
 who  may not be  familiar with the many technical  aspects of the industry.
 To obtain additional copies of this document or  the  Federal  Register notice
 of proposed standards, write to  EPA Library  (MD-35),  Research  Triangle  Park,
 North Carolina  27711.  Specify Phosphate Rock Plants  - Background  Information
 for  Proposed Standards, document number EPA-450/3-79/017 when  ordering.
 2.1  AUTHORITY  FOR THE STANDARDS.
     Standards  of performance for new stationary sources are established
 under section 111 of the Clean Air Act (.42 U.S.C. 7411), as amended,
 hereafter referred to as the Act.  Section 111 directs the Administrator
 to establish standards of performance for any category of new stationary
 source of air pollution which ".   . . causes or contributes significantly
to, air pollution which may reasonably be anticipated to endanger public
health or welfare."
                                   2-1

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     The Act requires that standards of performance for stationary sources
reflect, ". .  .  the degree" of emission limitation achievable through the
                 *
application of the. best technological  system of continuous emission reduction
... the Administrator determines has been adequately demonstrated."  In
addition, for stationary sources whose emissions result from fossil fuel
combustion, the standard must also include a percentage reduction  in emissions.
The Act also provide that the cost of achieving the necessary emission
reduction, the nonair quality health and environmental impacts and the
energy requirements all be taken into account  in establishing'standards of
performance.  The standards apply only to stationary sources, the  construction
or modification of which commences after regulations are  proposed  by publication
in the Federal Register.
     The 1977 amendments of'the Act altered or added numerous provisions
which apply to the process of establishing standards of performance.
     1.  EPA is required to list the categories of major  stationary sources
which have not already been listed and regulated under standards of perform-
ance.  Regulations must be promulgated for.these new categories on the following
schedule:
     25 per cent of the listed categories by August 7, 1980
     75 per cent of the listed categories by August 7, 1981
     100 per cent of the listed categories by August 7,'1982
A governor of a State may apply to the Administrator to add a category which
is not on the list or to revise a standard of  performance.
     2.  EPA is required to review the standards of performance every four
years, and if appropriate, revise them.
                                   2-2

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      3.   EPA  is  authorized  to  promulgate  a  design,  equipment, work  practice,
 or  operational standard when an  emission  standard is  not  feasible.
      4.   The  term  "standards of  performance"  is  redefined and a  new term
 "technological system of continuous emission  reduction" is defined.  The new
 definitions clarify that the control system must be continuous and  may include
 a low-polluting  or non-polluting process  or operation.       ;
      5.   The  time between the  proposal and  promulgation of a standard under
 section 111 of the Act is extended to six months.
      Standards of performance, by themselves, do not guarantee protection
 of  health or welfare because they are not designed to achieve, any specific
 air quality levels.  Rather, they are designed to reflect the degree of emission
 limitation achievable through application of the best adequately demonstrated
 technological system of continuous emission reduction, taking into.consideration
 the cost of achieving such emission reduction, any nonair quality health and
 environmental impact and energy requirements.
      Congress had several  reasons for including these requirements.   First,
 standards with a degree of uniformity are needed to avoid  situations where
 some  States may attract industries by relaxing standards relative to other
 States.  Second,  stringent standards enhance the potential for long  term
 growth.  Third, stringent standards may help achieve long-term cost  savings
by avoiding the need for more expensive retrofitting when  pollution  ceilings
may be reduced in the future.   Fourth,  certain types of standards for coal
burning sources can adversely affect the coal  market by driving  up the  price of
low sulfur coal  or effectively excluding certain coals from the  reserve base
because their untreated  pollution potentials are high.   Congress  does not  intend
                                   2-3

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that new scarce performance standards contribute to these problems.  Fifth,
the standard-setting process should create incentives for improved technology.
     Promulgation of standards of performance does not prevent State or local
agencies from adopting more stringent emission limitations for the same sources.
States are free under section 116 of the Act to establish even more stringent
emission limits than those established under section 111 or those necessary
to attain or maintain the national ambient air quality standards (NAAQS) under
section 110.  Thus, new sources may in some cases be subject to limitations
more stringent than standards of performance under section 111, and prospective
owners and operators of new sources should be aware of this possibility in
planning for such facilities.
     A similar situation may  arise when  a major emitting facility  is to be
constructed in a geographic area which falls under the prevention  of significant
deterioration  of air quality  provisions  of Part C of the Act.  These provisions
require, among other things,  that major  emitting  facilities to be  constructed
in  such  areas  are to be subject to  best  available control  technology.  , The   .
term "best  available control  technology" (BACT),  as  defined in the Act, means
 "...  an  emission limitation  based on  the maximum, degree of reduction of  each
pollutant  subject  to  regulation under this Act  emitted  from or which results
from any major emitting  facility,  which  the  permitting  authority,  on a
 case-by-case  basis, taking into account  energy,  environmental,.and economic
 impacts  and other  costs,  determines is achievable for  such facility through
                                   2-4

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 application  of production  processes  and  available  methods,  systems,  and
 techniques,  including  fuel  cleaning  or treatment or  innovative  fuel  combus-
 tion  techniques for  control  of  each  such pollutant.   In  no  event  shall
 application  of 'best available  control technology1 result in  emissions  of any
 pollutants which will  exceed the emissions  allowed by  any applicable  standard
 established  pursuant to section 111 "or 112  of  this Act."
     Although  standards of performance are  normally  structured  in terms  of
 numerical emission limits where feasible, alternative  approaches are  some-
 times necessary.  In some cases physical measurement of emissions from  a  new
 source may be  impractical or  exorbitantly expensive.   Section lll(j)  provides
 that the Administrator may promulgate a  design or equipment standard  in those
 cases where  it  is not feasible to prescribe or enforce a standard of  performance.
 For example, emissions of hydrocarbons from storage vessels for petroleum
 liquids are  greatest during  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 impractical.   Therefore, a more practical approach
 to standards of performance for storage vessels has been equipment specification.
     In addition, section lil(j) authorizes  the Administrator to grant
waivers of compliance to permit a source  to  use innovative continuous emission
 control technology.   In order to grant the waiver,  the Administrator must find:
 (1) a substantial likelihood that the technology will produce greater emission
reductions than the standards require, or an equivalent reduction  at lower
economic, energy or environmental  cost;  (2)  the proposed  system  has  not been
                                   2^5

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adequately demonstrated; (3) the technology will not-cau.se'or contribute to
an unreasonable risk to public health, welfare or safety; (4) the governor
                                                     a
of the State where the source is located consents; and that, (5) the waiver
will not prevent the attainment or maintenance of any ambient standard.  A
waiver may have conditions' attached to assure the source will not prevent
attainment of any NAAQS.  Any such condition will have the force of a per-
formance standard.  Finally, waivers have definite end dates and may be terminated
earlier if the conditions are not met or if the system fails to perform as
expected.  In such a case, the source may be given up to three years to meet
the standards, with a mandatory progress schedule.
2.2  SELECTION OF CATEGORIES OF STATIONARY SOURCES
     Section 111 of the Act directs the Administrator to list categories of
stationary sources which have not been listed before.  The Administrator,
".  . . shall include a category of sources in such list if in his judgment
it causes, or contributes significantly to, air pollution which may reasonably
be anticipated to endanger public health or welfare."  Proposal and promulga-
tion of standards of performance are to follow while adhering to the schedule
referred to earlier.
     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.  The approach specifies areas of  interest by con-
sidering the broad strategy of the Agency for implementing the Clean Air Act.
Often, these "areas" are actually pollutants which are emitted by stationary
                                   2-6

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  sources.   Source  categories which  emit  these  pollutants  were  then  evaluated
  and ranked by a process  involving  such  factors  as  (1)  the  level  of emission
  control  (if any)  already required  by State regulations;  (2)  estimated  levels
  of control that might be required  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 the source category.   Sources for which new source performance standards were
 promulgated or are under developemnt during 1977 or earlier,, were selected on
 these  critieria.
     The  Act  amendments  of  August,  1977, establish  specific criteria to  be
 used in determing  priorities for all  source categories  not  yet listed  by EPA.
 These  are
     1)   the quantity of air pollutant emissions which  each  such  category
 will emit,  or will  be designed  to emit;
     2)   the extent to which each such pollutant may reasonably be  anticipated
 to endanger public  health or welfare; and
     3)   the mobility and competitive nature of  each such category  of sources
 and the consequent  need for nationally applicable new source standards of per-
 formance.
     In some cases, it may not be feasible to immediately develop a standard
 for a source category with a high priority.  This might happen when a program
of research is needed to develop control  techniques  or because techniques
for sampling and measuring emissions may require refinement.'  In  the developing
                                   2-7

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of standards, differences in the time required to complete the necessary
investigation for different source categories must also be considered.  For
example, substantially more time may be necessary if numerous pollutants-
must be investigated from a single source category.   Further, even late in
the development process the schedule for completion of a standard may  change.
For example, inability to obtain emission data from well-controlled sources
in time to pursue the development process, in a systematic fashion may  force
a change in scheduling.  Nevertheless', priority ranking is,  and will continue
to be, used to establish the order in which projects are initiated,and re-
sources assigned.
     After the source category has been chosen, determining .the types  of
facilities within the source category to which the standards will apply must
be decided.  A source category may have several facilities that cause  air
pollution and emissions  from some of these  facilities may be insignificant
or very expensive to control.  Economic studies of the source category and
of applicable control technology may show that air pollution control  is better
served by applying  standards to the more severe pollution sources.  For this
reason, and  because there  be no adequately  demonstrated system for con-
trolling emissions  from  certain facilities, standards often  do not apply  to
all facilities at a source.  For  the same reasons, the standards  may  not  apply
to all.air pollutants emitted.  Thus, although a  source category  may  be selected
to be  covered by a  standard of performance, not all  pollutants or facilities
within that  source  category may be covered  by  the standards.
                                   2-8

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2.3  PROCEDURE FOR DEVELOPMENT OF STANDARDS OF PERFORMANCE
     Standards of performance must (1) realistically reflect best
demonstrated control practice; (2) adequately consider the cost, and the
nonair quality health and environmental impacts and energy requirements
of such control; (3) be applicable to existing sources that are modified or
reconstructed as well as new installations; and (4) meet these conditions
for all variations of operating conditions being considered anywhere in the
country.
     The objective of a program for development of standards js to identify
the best technological system of continuous emission reduction which has
been adequately demonstrated.  The legislative history of section 111 and
various court decisions make clear that the Administrator's judgment of
what is adequately demonstrated is not limited to systems that are in actual
routine use.  The search may include a technical  assessment of control
systems which have been adequately demonstrated but for which there is
limited operational experience.  In most cases, determination of the
"...  degree of emission reduction achievable ..." is based on results
of tests of emissions from well controlled existing sources.   At times,  this
has required the investigation and measurement of emissions from control
systems found in other industrialized countries that have developed more
effective systems of control than those available in the United States.
     Since the best demonstrated systems of emission reduction may not
be in widespread use, the data base upon which standards are  developed  may
                                     2-9

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 be somewhat limited.	Test-, data on existing well-controlled sources are
 obvious  starting points 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 before a judgment can be
 made  as  to  the level  at which the  emission  standard  should be set.
      A process for the  development of a standard has  envoived which takes
 into  account  the following considerations.
      1.   Emissions  from existing wel1-controlled sources  as measured.
      2.   Data  on emissions from such  sources  are assessed  with  consideration
 of such  factors as:   (a) how  representative  the  tested source  is in  regard
 to feedstock,  operation, size,  age, etc.; (b)  age  and maintenance of the
 control  equipment  tested;  (c)  design  uncertainties of control equipment
 being considered;  and  (d)  the  degree  of uncertainty that new  sources will be
 able  to  achieve similar  levels  of  control.
      3.   Information from pilot and prototype  installations, guarantees by
 vendors  of control equipment,  unconstructed but  contracted projects, foreign
 technology, and published  literature are also  considered during the standard
 devlopment process.  This is especially important for sources where  "emerging"
technology appears to be a significant alternative.
     4.   Where possible, standards are developed which permit the use of more
than one control technique or  licensed process.
                                   2-10

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      5.  Where possible, standards are developed to encourage or permit
 the use of process modifications or new processes as a method of control
 rather than "add-on" systems of air pollution control.     '.
      6.  In appropriate cases, standards are developed to permit the use
 of systems capable of controlling more than one pollutant.: As an example,
 a scrubber can remove both gaseous and particulate emissions, but an
 electrostatic precipitator is specific to particulate matter.
      7.  Where appropriate, standards  for visible emissions are  developed
 in conjunction with concentration/mass emission  standards.   The  opacity
 standard is established at a level that will  require proper operation  and
 maintenance of the emission control  system installed to meet the  con-
 centration/mass  standard on a day-to-day  basis.   In  some cases, however,
 it is not  possible to develop concentration/mass  standards,  such  as  with
 fugitive sources  of emissions.   In these  dases,  only opacity standards  may
 be developed  to  limit emissions.
 2.4 CONSIDERATION OF COSTS
     Section  317  of the  Act  requires,  among other things, an economic im-
 pact assessment with  respect  to any standard of performance  established
 under section  111  of  the Act.  The assessment is required to contain an
 analysis of:
     (1)  the  costs of compliance with the regulation and standard including
 the extent to which the  cost of compliance varies depending on the effective
 date of the standard or regulation and the development of less expensive or
more efficient methods of compliance;

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     (2)  the potential inflationary recessionary effects of the standard
or regulation;
     (3)  the effects on competition of the standard or regulation with re-
spect to small business;
     (4)  the effects of the standard or regulation on consumer cost, and,
     (5)  the effects of the standard or regulation on energy use.
     Section 317 requires that the economic impact assessment be as
extensive as practical* taking into account the time and resources available
to EPA.
     The economic impact of a proposed standard upon an industry is usually
addressed both in absolute terms and by comparision with the control costs
that would be incurred as a result of compliance with typical existing State
control regulations.  An incremental approach is taken since both new and
existing plants 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 exists between a standard of performance and the typical
State standard.
     The costs for control of ai.r pollutants are not the only costs considered.
Total environmental costs for control of water pollutants as well 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
                                    2*12

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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 of additional control equipment
needed to meet the standards of perfonnance.

2.5  CONSIDERATION OF ENVIRONMENTAL IMPACTS
     Section 102(2)(C) of the National Environmental Policy Act (NEPA) of
1969 requires Federal agencies to prepare detailed environmental impact
statements on proposals for legislation and other major Federal actions
significantly affecting the quality of the human environment.   The objective
of NEPA is to build into the decision-making process of Federal agencies a  •
careful consideration of all environmental aspects of proposed actions.
     In a number of legal  challenges to standards of performance for various
industries, the Federal Courts of Appeals have held that environmental impact
statements need not be prepared by the Agency for proposed actions under
section 111 of the Clean Air Act.  Essentially, the Federal Courts of Appeals
have determined that "... the best system of emission reduction, .  . . requires(s)
the Administrator to take into account counter-productive environmental  effects
of a proposed standard, as well as economic costs to the industry .  .  ."
On this basis, therefore,  the Courts ". . . established a narrow exemption
from NEPA for EPA determination under section 111."
                                  2-13

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     In addition to these judicial determinations, the Energy Supply and
Environmental Coordination Act (ESECA) of 1974 (PL-93-319) specifically
exempted, proposed actions under the Clean Air Act from NEPA requirements.
According to section 7(c)(l), "No action taken under the Clean Air Act
shall'be-deemed a major Federal action significantly affecting the quality
of the human environment within the meaning of the National Environmental
Policy Act of 1969."
     The Agency has concluded, however, that the preparation of environmental
impact statements could have beneficial effects on certain regulatory actions.
Consequently, while not legally required to do so by section 102(2)(C) of
NEPA, environmental impact statements will be prepared for various  regulatory
actions, including standards of performance developed under section 111 of
the Act;  This  voluntary  preparation  of environmental impact statements,
however, in  no  way legally subjects the Agency to NEPA requirements.
     To implement this policy, a  separate section is included in this
document which  is devoted solely  to an analysis of the potential environmental
impacts associated with the  proposed  standards.   Both adverse and  bene-
ficial  impacts  in  such areas as air and water pollution,  increased solid
waste  disposal, and increased  energy  consumption  are identified and discussed.

2.6   IMPACT  ON  EXISTING  SOURCES
      Section 111  of the  Act  defines a new  source  as  ".  .  .  any stationary
source,  the  contraction  or modification  of which  is  commenced  ..."  after
the  proposed standards  are  published.  An  existing  source becomes  a new  source
                                    2-14

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if the source is modified or is reconstructed.  Both modification and re-
construction are defined in amendments to the general provisions of Subpart
A of 40 CFG Part 60 which were promulgated in the Federal Register on December
16, 1975 (40 FR 58416).  Any physical or operational change to an existing
facility which results in an increase in the emission rate of any pollutant
for which a standard applies is considered a modification.  Reconstruction,
on the other hand, means the replacement of componenets of an existing facility
to the extent that the fixed capital cost exceeds 50 percent of the cost
of constructing a comparable entirely new source and that it be technically
and economically feasible to meet the applicable standards.  , In such 'cases,
reconstruction is equivalent to new construction.
     Promulgation of a standard of performance requires States to establish
standards of performance for existing sources in the same industry under
section lll(d) of the Act if the standard for new sources limits emissions
of a designated pollutant (.i.e. a pollutant for which air quality criteria
have not been issued under section 108 or which has not been listed as a
hazardous pollutant under section 112).   If a State does not act, EPA must
establish such standards.  General provisions outlining procedures  for
control of existing sources under section lll(d) were promulgated on November
17, 1975, as Subpart B of 40 CFR Part 60 (40 FR 53340).
2.7  REVISION OF STANDARDS OF PERFORMANCE
     Congress was aware that the level  of air pollution control  achievable
by an industry may improve with technological  advances.   Accordingly,

                                   2-15

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section 111 of the Act provides that the Administrator ". . .  shall, at
least every four years, review and, if appropriate, revise ..." the
standards.  Revisions are made to assure that the standards 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 the proposal of the revised standards.
                                   2-16

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                   3.  PHOSPHATE ROCK PROCESSING INDUSTRY
 3.1  GENERAL
      The phosphate rock industry consists of mining and rock processing
operations centered close to ore reserves.
      Phosphate rock mines of significant commercial importance are located
in Florida, North Carolina, Tennessee, Idaho, Wyoming, Utah, and Montana
(Figure 3-1).   In 1975, 21 producers were spread over 36 locations and employed
                               2
a total of about 12,000 people.   Table 3-1 presents the total  domestic pro-
duction and shipments for the years from 1965 to 1977.  Future production is
expected to increase to an annual rate of five percent.
      Nearly three-quarters of the domestic production capacity is located
in Florida.  In 1976, Florida and North Carolina produced 41.3 million tons,
accounting for more than 84 percent of the total domestic production.
      Phosphate rock is used primarily to produce phosphatic fertilizers.
About 20 percent of the rock is converted to other products, such as elemental
phosphorus and defluofinated animal-feed supplements.  Thirty percent  is ex-
ported.
     The ingredient of the rock that is of economic interest is tricalcium
phosphate, Ca3(P04)2, also known in the industry as bone phosphate of lime
(BPL) because the first commercial source of this chemical  was charred
animal bones.  The rock is usually graded on the basis of its BPL content,
e,g.5 68 BPL rock contains 68 percent by weight of tricalcium phosphate.
The final product contains roughly 68 to 74 percent BPL.8
     Chemically, phosphate rock may be considered to contain a  substituted
fluorapatite.  The basic fluorapatite structure is represented  as
                                     3-1

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       Table 3-1.   PRODUCTION AND SHIPMENTS OF PHOSPHATE ROCK3'4

Year
1965
1966
1967
1968
.1969
1970
1971
1972
1973
1974
1975
1976
1977
Production
(103 tons)
'29,482
39,044
39,700
41,251
37,725
38,739
38,886
40,831
42,137 '
45,686
48,816
48,659
51,266
Shipments
(10-3 tons)
29,039
36,443
37,835
37,319
36,730
38,765
40,291
43,755
45,043
48,435
48,439
43,230!
51,383
        )2'Ca2F.    Nearly all  phosphate ores contain a modified form of
this structure in which some of the phosphate is replaced by fluoride and
carbonate.     The total fluoride content of typical  phosphate rock is
approximately 4 to 5 percent by weight, expressed as fluorine.*1
     Commercial phosphate rock contains 30 to 38 percent F'205 plus a
variety of impurities such as iron, aluminum, magnesium, silica, carbon
dioxide, sodium, potassium, and sulfates.
                                         12
                                   3-3

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3.2  PROCESSING METHODS - GENERAL
     There are two major characteristics of phosphate rock which influence
the way it is mined and processed—hardness and organic content.
Generalized flow diagrams for phosphate rock mining and processing  '
operations in Florida, Tennessee, and the Western states are presented
in Figures 3-2, 3-3, and 3-4, respectively.
     Only phosphate rock operations associated with fertilizer manufacture
were investigated for development of standards of performance.  The
basis for their selection and for the omission of other phosphate
operations such as elemental phosphorus, thermal defluorination, and
nodulizing, is. presented in Chapter 8.
3.2.1  Mining and Beneficiation
     Hard rock is found in the Western states, with hardness generally
decreasing the further north it is found.  Conventional earth moving
equipment is used to remove the first five to fifty feet of earth,
called overburden, thus exposing the layer of phosphate rock.  The rock
is then removed from the deposit using a number of techniques, ranging
from dynamite blasting for the hard rocks found in Utah, to using a
"ripper" (a toothed implement used for gouging and breaking the rock
from the surface) for the softer rocks.  Two small underground mines are
also operated in Montana.
     Western rock is usually hauled by truck, to the. rock, processing plant.
The first step in processing the rock is to separate it from impurities,
a process called bene.fici.atton.  The sequence of steps comprising beneficiation
at plants mining Western hard-rock ores differs from plant to plant depending
                                  3-4

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                                         TO CONTROL EQUIPMENT

MINING
*
WASHING AND
SENEFICI
ATION
*
| 	 T" 	 	
DRYING
*
GRINDING
-»

GROU.VO ROCK
TRANSFER
— ]
Figure 3-2.  Generalized  flow  scheme -for  Florida
                                                             TO FERTILIZER
                                                            MANUf aCTURI«iC
                                                            operations

                                                     TO CONTROL EQUIPMENT
OPEN
PIT
MINING

— — *^s~ '~fT
— 1 '" 1 Jl
(pxop~^5|o:j!!
T
8ENEFICIATION
!
TAILINGS
—
1
NOOUL.ZING ; u^'"^™
FURNACE
1 i
FUE1 Ai»
Figure 3-3.  Generalized  flow  scheme  for Tennessee phosphate  rock.
                                                      TO CONTROL
                                                      EQUIPMENT
CALCINING
t
FUEL .


GRINDING
t
g AIB
                                                                 TO FERTILIZER
                                                                 MANUFACTURING
                                                      TO ELEMENTAL
                                                      PHOSPHORUS
                                                       FURNACE
 Figure  3-4. Generalized flow scheme for  western phosphate  rock.
                                   3-5

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on the hardness of the ore and the end use of the rock.  A typical
Western beneficiation plant consists of a primary crusting step,
particularly in the southern sector of the region, to reduce the size
of the ore to below 1/4 inch.  This size reduction is carried out in
several steps, the last of which is a slurry-grindina process which uses
a wet rod mill to reduce the ore to particles about the size of beach
sand.  The slurry is then size-classified in hydrocyclones, using centrifuoal
force to separate product-size material from the tailings (clay and sand
particles smaller than about 100 mesh).  The ore is then filtered from
the slurry and conveyed to further processing.  The tailings are
discarded.
     The deposits in Tennessee consist of small pockets of brownish
phosphate sands surrounded by brown silica sand.  The phosphate sand is
mined using draglines and small power shovels, then hauled by truck or
rail to the processing plants.  A typical Tennessee beneficiation unit
consists of a  unit called a  log-washer, in which the ore is slurried with
water and any  large agglomerated masses are broken up, followed by size-
classification using hydrocycloning.  The product-size fraction is then
sent to nodulizing kilns where it is prepared for use in electric arc
furnaces to produce elemental, phosphorus.
     The Florida  and North Carolina deposits consist of a consolidated
mass of phosphate pebbles and clays known as matrix, which is deposited
in  a discrete layer of considerable extent.  The Florida and North
                                                13                  14
Carolina deposits occupy aBout 1.8 million acres   and 5Q,QOQ acres,
respactt-valy.
                                     3-6

-------
      Mining in Florida and North  Carolina  is  conducted by stripping over-
 burden  from the matrix deposits and  removing  the matrix layer by use of
 large electrically driven  draglines.   Since the  phosphate rock normally
 occurs  below the water table,  large  pumps  are used  to  keep the water out
 of the  area being mined.   Even so, the rock contains from 10  to 25  percent
 moisture  as it comes  from  the  ground.   This high moisture cbntent precludes  any
 potential  for  particulate  emissions  during mining.  Once  mined, the  matrix
 layer is  dropped into sumps, slurried  with water, and  pumped  to beneficiation
 plants.   A typical  Florida  beneficiation unit involves  a  preliminary wet
 screening  to separate a fraction  called pebble rock, which  is  smaller than
 1/4  inch  and larger than 14 mesh, from the balance of  the  ore.   The  pebble
 product is  then  sent  to the rock  dryer.  The  North Carolina ore  does  not
 contain pebble  rock.   In North Carolina, the  ore  fraction  larger  than 1/4 inch
 is sent to  a hammer m-;il and then recycled to the screens.  .In  both  Florida
 and  North  Carolina  benefication  processes, the  ore fraction smaller  than 14 mesh
 is slurried  and  treated by two-stage   flotation, which uses hydrophilic or
 hydrophobic  chemical  reagents  in  conjunction with aeration to selectively
 separate suspended particles.  No air  pollutants are generated'during either the
mining or beneficiation processes  except at a  few plants which mine the hard
 rock  in the  southern  part of the Western reserves.  Because of the dry climate
 in that area, dust similar to that generated in rock quarrying operations  is
produced during mining and hauling of the rock.
           i
    Ore leaving the beneficiation  plants must  be either dried, calcined, or
nodulized before it can be further processed.   The particular route  taken depends
on its organic content and the  ultimate product for  which  it|is destined.  Since
Florida  rock is relatively free of organics, it is dried by simply heating to
                                   3-7

-------
about 250°F to drive off free water.  Rocks mined from other reserves
in the nation, however, contain organics and must be heated to 1400°
to 1600°F.  If not removed, the organics cause a slime which hinders filtration
during the manufacture of wet-process phosphoric acid, the starting material
for phosphate fertilizer.  During nodulization, the ore is heated to 2200. to
2600°F.  The nodulizing process not only drives off water, carbon dioxide, and
organic matter, but also causes the ore to fuse into larger lumps suitable
for feed to the electric arc furnace used in the manufacture of elemental
phosphorus.  Only the Tennessee ore and some Western ores are nodulized.
3.2.2.  Drying .
      Phosphate ores are dried  in direct-fired  dryers,  ie,, the combustion
products  contact the ore directly.  Most dryers are fired with either  natural
gas,  No.  2 or No. 6 fuel oil,  and many  are  equipped to burn more  than  one  type
of fuel.  Through the  late  sixties  and  early  seventies,  there was a  trend
toward fuel  oil, usually No.  6.  Both  rotary  and fluidized-bed units  are
employed, with the  rotary  the  more  common.  Figures 3-5 and  3-6  present typical
schematics  of the two  types of dryers.   Ore is about  10 to  15 percent moisture
by weight when fed  to  the  dryer.   It  is discharged  when ft  reaches  between 1
and 3 percent moisture,  the percentage being  determined by  the  ultimate use
 of the ore.   As  shown  in Table 3-2, capacities of dryers range  from 5 to  350
 tons per hour (.tph),  with  200 tph  a representative average.   The newer
 installations favor the larger capacities.  Typical  air volumes  used by the
 industry range from 20,000 dry standard cubic ft per  minute (dscfm)  for a 65  tph
 unit to 120,000 dscfm for a 350 tph unit,   A typical  dryer processing 250
 tph of rock will discharge between 70,000 and 100,000 dscfm of gas.   Conservative
 operators minimize air usage to decrease fuel consumption and to reduce the
 size and cost of the air pollution control device.
                                     3-8

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Table 3-2.   CAPACITIES AND GAS  FLOW  RATES  FOR  PHOSPHATE  ROCK  DRYERS
                                                                                15
Company
Agrlco Chemical
Beker Industries
Borden Chemical
Brewster Phosphates
Conserv, Inc.
Freeport Chemicals
Gardinier, Inc.
H. R. Grace fi Co.
Hooker Chemical •
IMC Corporation
IMC Corporation
Mobil Chemical
Occidental Chemical
Rocky Htn. Phosphates
J. R. Simplot
Stauffer Chemical
Stauffer Chemical
Swift Chemical
Texasgulf, Inc.
USS Agri-Chem
Location
Pierce, Fla.
Conda , Idago
. Plant City, Fla.
Bradley, Fla.
Nichols, Fla.
Uncle Same, La.
Ft. Meade, Fla.
Bartow, Fla.
Columbia, Tenn.
Noralyn, Fla.
Kingsford, Fla.
Nichols, Fla.
White Springs, Fla.
Garrison, Montana
Conda, Idaho
Leefe, Wyoming
Vernal, Utah
Bartow , F1 a .
Aurora, N.C.
Ft. Meade, Fla
Product
Rate
Tons/hr
1,000
63
150
31 5a
no
200
200
196
330
165
21
550a
333
350
350
242
5
150
55
26
26
178
265
233
187
Type of
Facility
NR
Fluid Bed
Rotary
NR
NR
Fluid Bed
Fluid Bed
NR
Rotary i
Fluid Bed'
Rotaryb
NR ,
NR '
Fluid Bed
Rotary
Rotary
Fluid Bed
Rotaryc
Rotary
Rotary
Rotary
Rotary
Rotary
Fluid Red
Fluid Bed
Rotary
Stack Gas
Flow Rate
scfmX10-3
800
27
52
145a
27
: NR
NR
77
130a
18
155a
70
78
78
93
NR
22
15
10
• 10
56
76
NR
NR
 aTotal fo'r two dryers.
  This dryer operates at
 eThis dryer operates at
  This dryer operates at
400"F (exit pas  temperature).
250°-300°F (exit gas temperature).
300°F (exit gas  temperature).
                                       3-11

-------
     Emissions from dryers range from 0.5 to 5 grains per dry standard cubic
foot (gr/dscf), or about 400 to 4000 pounds per hour (Ib/hr), for a
typical 250 tph dryer.  There are no significant differences in the gas
volumes or emissions from fluid bed or rotary dryers.
     Process variables which affect emissions from a phosphate rock dryer
include the type of rock being processed (a factor only at Florida plants),
fuel type, air flow rate, product moisture content in the case of a rotary
dryer, and speed of rotation.  A unique situation regarding rock types in
the Florida industry deserves some comment.  The pebble rock described
earlier receives much less washing than does the concentrate rock from the
flotation processes, and, therefore, has a higher clay content.  As a result
uncontrolled emissions from drying pebble rock are substantially higher than
when drying ore from the flotation process.16'17'18
3.2.3.  Calcining
     The most  common type of calciner is the fluidized-bed unit (illustrated
in  Figure 3-7), but rotary calciners are also used.  Calciners differ from
dryers in that their much higher temperatures require refractory linings.
Also,  as shown in  Figure 3-6, the fluidized-bed dryer has an external c.ombustion
chamber with the flue gases passing through the dryer, whereas the calciner
                                   3-12

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(Figure 3-7) employs combustion within the bed of phosphate rock in
order to achieve the higher temperatures.   Calciners range in capacity
from 20 to 70 tph; a representative average is about 50 tph.  As noted
for dryers, the newer calciner installations also tend to be of larger
capacity.  Average air volumes used by the industry range from 17,000
dscfm for a 20-tph calciner to 50,000 dscfm for a 70-tph unit.  A
typical 50-tph unit will discharge between 30,000 and 60,000 dscfm of
exhaust volume with particulate emissions of 0.5 to 5 gr/dscf for total
uncontrolled particulate emissions of 250 to 2500 Ib/hr.   Table 3-3
summarizes production rate and volumetric flow rate for fluid bed and
rotary calciners.
3.2.4.  Crushing and Grinding
     Crushing and grinding are widely employed in the processing of phosphate
rock.  These operations range in scope from jaw crushers which reduce 12-inch
hard rock to fine pulverizing mills which produce a product the consistency
of talcum powder.  Crushing is employed in some locations in the Western field;
however, these operations are used for less than 12 percent of the rock mined
in the United States.  The fine pulverizing mills or grinders are used by all
manufacturers to produce fertilizer.  These may be either roller or ball mills.
     Roller mills and ball mills are used to reduce the phosphate rock to a
fine powder «• typically specified as 60 percent by weight passing a 200-mesh
sieve.  Roller and ball mills are about equally favored in the industry.  A
typical grinding circuit is illustrated in Figure 3-8.
                                   3-14

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    The roller mill is composed of hardened steel rollers which rotate
against the inside of a steel ring, as shown in Figure 3-9.  Ore is fed
into the mill housing by a rotary valve which prevents the escape of air
into the feed system.  The rock is scooped up from the floor of the housing
by plows and directed into the path of the rollers, where it is ground between
the rollers and the steel ring.  Ground rock is swept from the mill by a
circulating airstream.  Some product size classification is provided by the
"revolving whizzers" at the top of the housing.  The average particle size
leaving the mill can be controlled by varying the speed of revolution of the
whizzers.   Further size segregation is provided by the air classifier which
separates  oversize particles from product size particles and recycles the
oversize 'portion to the mill.  The product is separated from the carrying air
stream by a cyclone and conveyed to ground-rock storage.  The air stream is
returned to the mill in a closed loop.
    The ball mill is basically a drum revolving about an axis, slightly inclined
to the horizontal (Figure 3-10).  The drum contains a large number of steel
balls about 1 inch in diameter.  Rock is charged into the mill  through a
rotary valve, ground by attrition with the balls, and swept from the mill  by
a circulating air stream as described above for roller mills.
    Roller and ball mills are operated slightly below atmospheric pressure
to avoid fugitive discharge of rock dust into the air.  As a result, there
is infiltration of atmospheric air into the circulating streams.   This tramp
air is discharged from the circuit through a dust collector to  the atmosphere.
Mill  capacities range from 15 tph of phosphate rock for a smaller roller mill
to about 260 tph for a large ball mill.  Generally speaking, roller mills  are
                                   3-17

-------
       A Product outtet
                           Revolving
                           whizzers
                             drive
                       Grinding ring
                       'Grinding roller
                              -Feetter
Figure 3-9.  Roller Mill
            3-18

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limited to about 75 tph per unit; therefore, many operators install several
in parallel rather than a single large ball mill.  There is no clear trend
toward either method of grinding.  Discharge air volumes range from 1100
dscfm for the 15 tph unit to 19,000 dscfm for a 260 tph unit; however,
as noted above, this discharge stream is a purge of tramp air which enters the
system as a result of the vacuum and is therefore more dependent upon the
design and construction of the grinding 'circuit than on the capacity of
the mill.  For example, it would not be unusual to find .a mill grinding
150 tph discharging 19,000 dscfm nor a 250-tph unit discharging 10,000
dscfm.  A typical mill has a capacity of 50 tph and discharges between
3500 and 5500 dscfm of air containing 0.5 to 5 gr/dscf of particulate.  At
this rate, the typical grinder could emit as much as 237 pounds of particulate
each hour of operation.  Table 3-4 summarizes production rate and volumetric
flow rate for several types of mills.
3.2.5  Materials Handling and Storage
     Between each of the operations described, provision is usually made
to convey and/or store the rock.  The materials handling and storage
operations employed by the phosphate rock industry range from truck
hauling and open storage to sophisticated pneumatic transfer systems
and silos.  Some mention has previously been made of the normal methods of
conveying ore from the mines to beneficiation plants.   A discussion of the
handling ahd storage procedures commonly employed at other steps in the
various processes will now be given.
     Beneficiated rock is commonly stored wet in open  piles.  Several  methods
are used to reclatm the material from the piles, including skip loaders,
underground conveyor belts, and above-ground reclaim trolleys.  The

                                   3-20

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reclaimed ore is formally conveyed to the next processing step, whether
drying, calcining, or nodulizing, by either open or weather-protected
conveyor belts.
      Rock  discharged  from  the" rock  dryers  or  calciners  is  usually
 conveyed to storage silos  on  weather-protected  conveyors.   From  the
 silos it is either transported in  rail  cars and trucks  to  consumers,
 or conveyed to grinding  mills which prepare the rock  for feed  to
 fertilizer plants.
      Ground rock is usually conveyed in some  type  of  totally enclosed
 screw conveyor, the dust pump, or  the air  slide system.  The screw
 conveyor consists of  a long screw  enclosed in a tube  or covered
 trough, and is driven at one end.   Ground  rock  fed into one end  of  the
 tube is carried along the flights  of the screw  and discharged  at the
 opposite end.   The dust  pump system employs  an  aerated  bin to  generate  a
 continuous stream of  fluidized rock.  The  rock  dust is  then blown  from
 the ground-rock surge bin to the receiving units through pipelines.
 Provision  must be made at the discharge end to  vent the conveying
 airstream.  The air slide, illustrated in  Figure 3-11,  is  composed  of
 a rectangular duct separated into upper and lower segments by  porous
 tile.  The duct is inclined downward from the feed end  to  the  discharge.
 Rock dust is fed into the upper segment of the  duct,  and air  is  blown
 at the  low pressure  into  the  lower  segment.  The air diffuses upward
 through the porous tile into  the rock  dust,  assisting rock flow by
 gravity down  the  incline  to  the discharge end.  Provision must be made  to
 inject  air at intervals throughout  the length  of a long conveyor and to
 purge the excess  air from the upper segment.
                                     3-22

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                                                            3-23

-------
3.3.   PROCESS EMISSIONS AS RESTRICTED BY TYPICAL AND MOSTrSTRINGENT
      STATE REGULATIONS
      Table 3-5 presents a tabulation of state process weight tables for
states in which the phosphate rock industry is located,  Florida's
                                                                       ^
limitations are most stringent, and those of Tennessee (for existing plants),
North Carolina, Idaho, Montana, and Wyoming (for existing plants), are the
typical.  A comparison of emission rates from plants under each of these
two levels of limitation  (most stringent and typical) is presented in Table
3-6.  Materials handling  systems are not included because of the difficulty
in determining a representative system.
                                     3-24

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                           REFERENCES FOR CHAPTER 3
 1.  Stanford Research Institute.  1975 Directory of Chemical Producers.
     Menlo Park, California.  1975.  Also 1975 Directory of Chemical Producers.
     January-September 1977 Update (no copyright information)

 2.  Blue, T.A., and T.F. lorries.  Phosphate Rock.  Chemical Economics Handbook.
     Menlo Park, California.  Stanford Research Institute.   December 1975.   pp.
     760.OOOOA-760.0010.

 3.  Eertilizer Trends, 1976.   Bulletin Y-lll.  National Fertilizer Development
     Center, Tennessee Valley Authority.   Muscle Shoals, Alabama.   March 1977.   p.

 4.  Telephone conversation.  Mr. David M. Augenstein, PEDCO Environmental, Inc.,
     and Mr. Ed Harre, Tennessee Valley Authority.   April 179 1978.

 5.  National Fertilizer Development Center, Tennessee Valley Authority, North
     American Production Capacity Data.  Muscle Shoals, Alabama.   Circular  Zr-57

 6.  Wiley, J.H.  The Outlook for Phosphate Fertilizers. TVA.Fertilizer Con-
     ference.  Kansas City, Missouri.

 7.  Stowasser, W.F.  Phosphate Rock.   United States Department of the Interior,
     Bureau of Mines.  Preprint from Bulletin 667.   1975.

 8.  Trace Pollutant Emissions from the Processing  of Nonmetallic  Ores.   PEDCO
     Environmentalj Inc.  U. S. Environmental Protection Agency Contract No.
     68-02-1321, Task No. 4.  p. 6-1.

 9.  Stevenson, R.M.  Introduction to  the Chemical  Process  Industries.   Reinhold
     Publishing Corporation.  New York.  1966.  p.  157.

10.  Barber, J.C.,  and T.D. Farr.  Fluoride Recovery from Phosphorus Production.
     Chemical Engineering Progress, 66:  11  pp.  56-62.
15
                                     3-27

-------
11.   Lehr, J.R., and McClellan, G.H.   Fluorine Content and Properties of
     Commercial  Phosphate Rocks.   Technical  paper presented at the American
     Chemical-Society Symposium Fluorine Sources and Technology on August 30,
     1972, in New York, New York.

12.   Considine,' D.M. (ed.).  Chemical and Process Technology Encyclopedia.
     McGraw Hill Book Co. New York, New York.   1974.  p.  872.

13.   Sauchelli,  V. Chemistry "and Technology of Fertilizers.  New York, Reinhold
     Publishing Corporation, 1960.  p. 68.

14.   Texasgulf,  Incorporated.  Texasgulf Phosphate.   200 Park Avenue, New York,
     N. Y.

15.   Information obtained from the following sources:  a.  Letters from A.B.
     Capper, Catalytic, Inc., to Lee Beck, EPA, dated August 30, 1974; September
     6, 1974; October 18, 1974; Octeber 25, 1974; October 30, 1974; November 4, 1974;|
     November 20, 1974; December 30, 1974; and January 6 .1975.- b.  Letter
     from R.A. Schutt, EPA, to Mr. Lee Beck, EPA, dated October 15, 1974.

16.   U.S. Environmental Protection Agencv.  Compilation of Air Pollutant Emissions
     Factors, 2nd Edition.  April  1973, .Document No AP-42.  Section 8.18.

17.   Florida Department of Pollution Control.   Hearing Officer's report, 22
     November 1972, in the matter of W.R. Grace and Co., Cities Service Co.,
     and Mobil Chemical Co.

18.   Lindsey, A.M., and Segars, Control of Particulate Emissions from Phosphate Rock
     Dryers.  Environmental Protection Agency Publication No.  APTD-1334. pp.  29-34.

19.   Duncan, L.J. Analysis of Final State Implementation Plans - Rules and
     Regulations.  Environmental Protection Agency Publication No. APTD-1334.
     pp. 29-34.
                                   3-28

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                    4.  EMISSION CONTROL TECHNIQUES
      The task of minimizing emissions from the complex sequence of operations
 employed in a typical phosphate rock processing plant usually requires appli-
 cation of several different control systems.  At phosphate rock installations,
 the normal sequence of operations is:  mining, beneficiation, conveying of
 wet rock to and from'storage, drying or calcining, conveying and storage of
 dry rock, grinding, and conveying and storage of ground rock.  In general,
 each operation has a separate control system.
 4.1  MINING
      Over 98 percent of the phosphate rock produced in the United States  is
 mined from ground.where  the moisture content  is  high  enough'to  oreclude
 particulate emissions  during extraction  of the ore..   In  tne  relatively small  amount
;of mining  performed  in areas where  ground  moisture  content is not sufficient  tn
 prevent emissions, such  as the hard-rock areas of Utah and Wyoming,  some
 particulate is generated during blasting and  handling of the overburden  and
 ore body.   These emissions are minimized by wetting the  active  mining  area
 with water from tank trucks.

 4.2  BENEFICIATION
     Jenefielation is performed in a water slurry.  Since the rock is wet, it does
not become airborne and presents no  threat to air quality.
 4.3 CONVEYING OF WET ROCK
      Mined rock is normally moved by conveyor belts.   Some are  ooen,  others
closed for weather-protection.  In ajl except  the relatively  small plants  in the
                                   4-1

-------
hard rock areas of Utah and Wyoming, the high moisture content of the rock
(from 10 to 15 percent by weight)  prevents emission of participate.  Weather-
protected conveyors also offer some emission control in arid or windy locations.
4.4  PHOSPHATE ROCK DRYING
          The air stream from a rock dryer contains participate and combustion
products including moisture.  The relatively low temperatures at which the rock
                                                  2
is dryed is too low to drive off gaseous fluoride.   The effluent is about
160° to 200°F, and the particulate loading is about 3 grains per dry cubic
foot.3  The most common control system  is a wet scrubber, although     electro-
static precipitators are used by two companies.  Examples of the efficiency
and emission  rate' for several collection systems are given  in Table 4-1.
(Additional details of EPA  tests and the results of some sampling conducted by
the industry  are presented  in Appendix  C.)                     .
4.4.1  Scrubbers
           Scrubbers are  the most common control device  used by operators of
phosphate  rock dryers.   Probably the most  important design  parameters for scrubbers
are the  amount of  scrubber  water used  per  unit  volume of gas  treated  (liquid-to-
                                                                         4
gas .ratio)  and the  intimacy of  contact between  the  liquid and  gas phases.   The
pressure loss across  the scrubber  is often  times  used as an indication of the
latter.   Venturi  scrubbers  with a  relatively low  pressure loss  (12  inches of
water) will  have  a collection efficiency of 80  to  99  percent  for  particulates of
 1 to  10  microns  in diameter and 10 to  80 percent  for  those  less than  1 micron,
whereas  "high-pressure-drop"  scrubbers (30 inches^P) may have collection effi-
 ciencies of 96 to 99.9 and 80 to 96 percent, respectively,  for particles  in the
 same size ranges.5  As reported in Appendix C,  one dryer using a  scrubber operated
 at a pressure drop of 18 inches of water was tested by EPA  and found to
 have emissions of 0.015 gr/dscf.  Emissions before the scrubber were
 about 2 gr/dscf, indicating a control.efficiency of greater than  99 percent.
                                      4-2

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4.4.2  Electrostatic Precipitators
          There are currently two operators of phosphate rock dryers which use
electrostatic precipitators (ESP's).  One uses a conventional dry-type ESP
to control emissions from two rotary dryers.  The precipitator was designed for
95 percent efficiency, but its operating efficiency is typically about 93 percent.7
The other operator uses a wet electrostatic precipitator designed and built by
MikroPul Division of United States Air Filter Corporation.  This unit controls
emissions from  two .dryers, operated in parallel.  One is a rotary design and  the
other  is a fluid bed.- The control system at this plant is unusual in that
emissions from  the dryers are first cleaned by two impingement scrubbers (one
for each dryer).  The streams-are then combined and discharge through the ESP.
The  ESP was  designed for an efficiency of 90 percent,  but is  operating more
efficiently  because the gas flow'rate is approximately half the  design  value.
 Simultaneous inlet and outlet tests have not been performed  on  the dryers,  but
the operator reports inlet  loadings to be 0.6 to  1.0  gr/dscf and EPA tests
show outlet  emissions  to average about 0.01 gr/dscf (98 to 99 percent efficiency).
A similar ESP used  to  collect emissions  from an aluminum pot line  averaged 98.5
                                                                                8
percent efficiency  for particulate  in the size range  0.2 to  1.0 micron diameter.
Ninety-eight percent of  the particulate  from phosphate rock  dryers is larger
                 9
than Oi4  microns.
          Plate (electrode) voltage and  the ratio of  plate area to the volume of
gas  treated  are the most important  variables affecting emissions from electrostatic
 precipitators.  However,  the  resistivity of the dust  in  the  gas stream being
cleaned and  the efficiency with  which  captured material  is cleaned from  the plates
 can  also affect emissions.
                                    4-4

-------
 4.4.3  Fabric Filters
           Bag filters are not currently used to control emissions  from phos-
 phate rock dryers.  The industry's apprehension regarding baghouse controls
 for dryers stems from the high moisture content of the exhaust gases (20 to
 30 percent by volume) and the potential "blinding" of bags caused by mixing
 of moisture and clay material.  The industry is concerned the high moisture
 content would require costly precautionary measures^ such as preheating the
 baghouse before startups' and providing auxiliary heat at all  times to insure
 the gas temperature from the dryer does not fall  below the dew point in any
 portion of the baghouse.
           In  one EPA study   to  determine  the  feasibility of more stringent
 emissions  regulations  for  phosphate rock  dryers,  it  was  concluded there are
 no  apparent technical  problems which  wo.uld preclude  the  use  of bag filters
 for control of dryer emissions.   Numerous  examples of baghouse installa-
 tions  utilized in  similar  and  more  difficult applications  are  related in
 this study.   The problem of  moisture  condensation  has  been resolved  in
 other  industries.   Typically,  condensation is avoided by maintaining  a  50°F
 difference between  the wet and dry  bulb (W.B. and  D.B.) temperature.  This
 can usually be accomplished  by insulating  all vent lines and the  filter.
 Presently most dryer facilities employ long runs of uninsulated ductwork
 which is conducive to the. formation of condensation.   In designing a new
 plant to use a baghouse, the-length of the exhaust gas line from the dryer
 to the baghouse  exit should be minimal and well insulated to minimize
 heat loss.   Control of fuel rate can also help maintain a low relative
 humidity.
          Overheating of the baghouse need not be a problem.   For a typical
dryer exhaust  a,t 165°F (D.B.) and 30 percent (by volume)  water, the tempera-
ture of the baghouse should be maintained  at about 215°F,  well  within  the
                                    4-5                     :

-------
acceptable temperature range of most bag fabrics.   This temperature could
probably be maintained by proper design of the dryer and insulation of the
vent lines.  However, auxiliary heating may be required for some low tempera-
ture dryers.  In any case, it would be desirable to provide a temperature
control system which would prevent the gas stream from becoming any colder
than 50°F above the wet bulb temperature or of exceeding the temperature for
which the bag is designed.  Other factors such as acidity of the gas stream,
and adsorption, adhesion, and electrostatic properties of the particles which
could adversely affect the performance of a baghouse can generally be solved
by proper selection of the fabric for the bag.  Manufacturers of fabric filters
consider the gas properties and recommend the proper fabric for a given installa-
tion.
           Bag filters have btcome increasingly common as a control device  in
 industries where high collection efficiencies are required.  One of the more
 common applications is on rotary dryers.  They are used extensively on dryers
 at asphalt, cement, and mixed-fertilizer plants; and  in the clay industry.14

           Due to similarities in emissions characteristics (including  a
 composition of mainly clay particles, the experience of the clay industry
 may be quite applicable to the phosphate rock industry.   Nearly all  of the
 kaoline (clay) spray dryers and several  of the kaoline rotary kiln  dryers
                                      4-6

-------
 in  Georgia  are  equipped with  bag  filters.     The  typical  particle  size  from
 the kaolin  dryers  is  smaller  than  from  a  rock  dryer  --  80  percent  less  than
 two microns  as  compared to  50  percent less  than two  microns.   The  kaolin  gas
 stream  typically contains between  20 and  50  percent  moisture,  a  dew-point
 between  160° and 180°F and  a  dry bulb temperature  between  200° and 250°F.15
          The Georgia state agency reports that there are no visible emissions
for the kaolin rotary kilns or spray dryers when the baghouse is maintained
properly.    The bag filters used in the kaolin industry are cleaned either
by shaking or pulse air.  The state agency also reports that operating
problems with the filters (such as occasional bro.ken bags) have been minor.1-8
          Another application which may be similar to the phosphate rock dryer
is tne collection of dust from a mixed-fertilizer dryer.  Baghouses are used
extensively at granular fertilizer manufacturing plants.to collect dust from
dryers drying various mixtures of triple superphosphate, normal  superphosphate,
                                     19
potash, and solid nitrogen compounds.    State agency data indicate a dry bulb
temperature of 186°F and a wet bulb temperature of 116°F.20
          Of the two manufacturers contacted, Wheelabrator Frye  Corporation
and American Air Filter, both indicated that a bag filter could  collect the
dust from a phosphate rock dryer.   They also stated that in their opinion
the baghouse has been used successfully on  even more difficult applications
such as dryers in asphalt plants.
                                 21
                                   4-7

-------
          The potential  control  efficiency of the baghouse on dryer emis-
sions may be estimated by applying fractional efficiency data to the particle
size distribution of dryer emissions.  Figure 4-1 shows the particle size
distribution of particulate matter emitted from three separate dryer faci-
lities.  The size distributions are determined with the use of sampling
equipment (Brink Cascade Impactor) which separate the stack gas particulate
matter into size fractions.  The material collected in each size fraction
is quantified gravimetrically, and the cutoff particle size for each size
fraction (impactor stage) is calculated based on impactor geometry, gas
impactor velocity, and particle density.  The particle density was assumed
to be 2.8 gm/cc, which is consistent with the density of the known-major
components  in the emissions stream (apatite  and  clays) and the value commonly
used by the industry  in  developing design specifications for emission collec-
tion equipment.25'39  The size of particles  in the dryer emissions shown  in
Figure 4-1  are  relatively fine due to  the composition of the phosphate ore
(Florida pebble rock)' processed.  The  pebble rock contains relatively soft
clays which disaggregate readily, resulting  in the generation of fine par-
ticles.  Emissions from  pebble rock  dryers are of major concern,  since the
substantial  portion of phosphate  rock  production occurs in Florida.
           Figure  4-2  shows  the effect  of particle  size on  collection effi-
ciency of the bag filter.   The efficiency plot was developed  from  test
data for a baghouse  performing  under control conditions similar  to those
 produced by phosphate rock dryers.   The performance  of fabric  filter col-
 lectors  is relatively unaffected by  the size distribution  of particulates.
 By contrast, particle size exerts a  substantial  impact on  the  performance
 of scrubbers, as seen in Figure  4-2  (estimated by utilizing  an analytic
 scrubber model developed by EPA40).   Based on the two particle size
                                     4-8

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                                   4-10

-------
distributions shown 1n Figure 4-1, and the performance curve of Figure 4-2,
the overall efficiency of a baghouse treating dryer emissions would be 99.0 to
99.4 percent (estimated by summing the partial efficiencies for selected
particle size increments).  By contrast, the low energy scrubber (12 inches
of water pressure drop), which is typically used throughout the industry,
attains an estimated overall  efficiency of 93.6 to 96.5 percent, depending
on the liquid to gas ratio employed.  However, the scrubber can achieve
collection efficiencies equivalent to the baghouse when,designed suitably
(i.e., for high energy and liquid to gas flow rates).

4.5  PHOSPHATE ROCK CALCINERS
          As discussed in Chapter 3, calciners and dryers process  the same
feed material, phosphate rock.  The major differences  between the  two pro-
cesses are the final temperature to which the rock is  heated (200°F for
dryers and up to 1600°F for calciners) and the.exhaust gas temperatures
(about 165°F  for dryers and 200°F to 700°F for calciners).  The parti -
culate concentration from the processes are about the  same.(0.5 to 5 gr/dscf)
and, as shown in Table 4-2, the size distribution of the particulates in
the exhaust gases is similar.
          Table 4-2.  PARTICLE SIZE DISTRIBUTION OF EMISSIONS FROM
                      PHOSPHATE ROCK DRYERS AND CALCINERS
                                          Percent Less Than Stated Size
Diameter, Microns
10
5
2
1
0.75
0.5
Dryers3
82
60
27
11
7
3
Calciners25
96
81
52
26
10
5
       Compiled as the mid point of the range of size distributions observed
        at different  phosphate  rock  dryers
                                    4-11
                                          5,41

-------
          Because of the similar characteristics  of the  participate matter
in the exhaust gases from dryers and calciners,  it is  expected that  the
"control!ability" of emissions from the two processes  is similar,  and that
control technology for dryers can be applied to emissions from calciners.
Emissions from the control devices of the two processes, including the
opacity of the emissions, should be the same when controlled to the  same
degree.
          The gas stream leaving the calciner is usually passed through a
cyclone to a particulate control device.  One company is using an electro-
static precipitator,  but the most  common control  device  is  a wet scrubber.
4.5.1  Scrubbers
           Scrubbers are popular for controlling emissions  from phosphate
rock calciners because they  are reportedly  "less  sensitive  to  damage caused  by
the high temperature of the  calciner exhaust."
 4.5.2  Electrostatic Precipitators
           Only one calciner now uses an ESP to control emissions.   The ESP
 1s two-stage and operates with an inlet particulate loading of about 5 gr/dscf
                                                                           2fi
 and an outlet loading of about 0.05 gr/dscf, about 99.0 percent efficient.
 Factors  affecting the performance of an ESP were discussed in Section 4.4.2.
4.5.3 Fabric  Filters

         Bag filters are not currently used to control emissions from phosphate
rock calciners.  As in the case of rock dryers, the industry is apprehensive
of overheating of the bags due to high exhaust temperatures, and potential
blinding of the bags due to mixing of moisture and clay material.
                                   4-12

-------
          In one EPA study   concerning the control of emissions from
 phosphate rock dryers, it was concluded there were no apparent technical
 problems which would preclude the use of bag filters for control of .dryer
 emissions.  Because the controllability of dryer and calciner emissions
 is similar, it is expected that bag filters would also be applicable for
 control of calciner emissions.  Baghouse installations are currently used
 in numerous applications similar to the service which would be required for
 phosphate rock calciners.  The high exhaust gas temperatures are controlled
 by a variety of approaches in other industries, such as radiation type
                                         97
 coolers (used in metallurgical industries  ), water spray, or dilution with
 ambient air.  The problem of-moisture condensation is typically resolved
 by maintaining approximately a 50°F temperature difference between the wet
 and dry bulb temperature.  For emergency protection of the baghouse filters,
 a relief system is used to vent high temperature exhaust gases if the
 temperature control system fails.   Such emergency equipment is reliable and
 relatively inexpensive compared to the costs of replacing damaged filters.
 In addition to temperature protection afforded by gas conditioning, special
 nylon or fiberglass textile filter fabrics capable of service at 450°F may
 also be used as a protective measure against transient temperature peaks.
 The control  system manufacturer considers the economic tradeoffs  associated
with the alternative baghouse designs and recommends  a suitable fabric and
 gas conditioning system.
          The potential control efficiency of a baghouse for calciner
 emissions may be estimated by applying fractional efficiency data to the
 particle size distribution of calciner emissions.  Since the particle size
 distribution and composition of calciner and dryer emissions is similar, the
                                    4-13

-------
collection efficiency of the baghouse for the dryer and calciner applications
is similar.  Based on the size distribution of calciner exhaust particles
given in Table 4-2, and the bag filter performance curve of Figure 4-2,  and
the bag filter performance curve of Figure 4-2, the overall  efficiency of  a
baghouse treating calciner emissions would be 99.0 percent.   The efficiency
of low energy scrubbers normally used to control  calciner emissions in the
industry is somewhat lower (about 94 to 97 percent).

4.6   GRINDING
           Dried and  calcined  rock is  ground  prior to being used for the  manu-
facture of fertilizers, as  described  in  Chapter 3.  The  grinding or milling
circuit operates  under slightly negative  pressure to prevent the escape  of
air  containing ground rock.   Because  the  system is  not airtight, some air is
drawn  into the system and must be vented.  This vent stream is usually dis-
charged through a fabric  filter (baghouse),  although a wet scrubber is also
sometimes  employed.  The  temperature  of  the  air is  typically about 125°F
and  contains  particulate  matter.
           The grinding operation is  purely mechanical and there is no threat
of fluoride evolution other than as  a part of  the particulate.
4.6.1  .Scrubbers
           Scrubbers are  sometimes  used to control emissions from grinders.
 They  are  usually  low-energy  (8 to  10 inches pressure drop) Venturi or
 impingement  scrubbers.   Emissions  from these devices are typically about
                                    4-14

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10 times greater than for fabric filters.   Scrubbers  also  add  to  the  volume
of effluent water which must be treated before  discharge.
4.6.2  Electrostatic Precipitators
          Electrostatic precipitators have not  been used  to  control emissions
from phosphate rock grinders.
4.6.3  Fabric Filters
          Fabric filters are the most common device used  to  control emis-
sions from grinders.  This is probably because  the particulate collected by
the baghousecan be added directly to the product, thereby increasing
yields.  Also, the low moisture content and only slightly elevated tempera-
ture (125° to 150°F), eliminates the reasons industry claims for  avoiding
the use  of baghouses  on  dryers  and  calciners.   Table 4-4 presents typical
emission rates  for grinders.  Details of EPA tests and results of some
 industry tests  are presented in Appendix C.  The operators  report no
variation in emissions as a result of such factors as fineness of
grinding, type of rock, ambient conditions, or any other equipment or
                                          30
process variable which can be controlled.
      Variations in emissions from one unit to another at a  given location
appear a function only of the total volume of exhaust air (Table 4-4).
 For a given fabric filter, evidence suggests that the discharge loading  .
 1s fairly constant over a range of air flows:   If true,  the mass emission
 rate is proportional to the total gas volume.   The largest source of
 variation in emissions is, of course, the differences in design parameters
 and maintenance of the particular devices  cited.   The  reader  is  referred
 to Control  Techniques for Particulate Air  Pollutants   for additional
 detail about the design and operation of control devices.
                                  4-16

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4.7  MATERIALS HANDLING AND STORAGE
     Emissions from i,;aterials handling  systems  are  difficult to quantify,
partially because of the great number of  different  systems  employed to
convey rock, and partially because a large  part of  the'emission potential
for these operations is fugitive emissions.  Materials  handling systems
range from -"front-end loaders" and other  manual  conveyances  to  automated
pneumatic systems.  The basic difference's between the systems from an
emissions standpoint are the precautions  taken  to prevent the dust from
becoming airborne and the ease with which it can be captured  if it does.

     The most common type of transfer system for unground rock consists  of
conveyor belts and bucket elevators.   In order to minimize  fugitive emissions
caused by ambient air currents,  conveyor belts moving  dried  rock are usually
covered and sometimes enclosed.   The  major source of emissions from this
type of system is the "transfer  point"  where the material falls  by gravity
from the conveyor belt.   Small  amounts  of fugitive dust  can  also be present
at points along the housed enclosure  because of the  movement of  the belt over
the rollers, thermal air currents created by the hot rock,  or ambient winds.
Transfer points are sometimes hooded  and evacuated to  minimize fugitive
emissions, but none in the phosphate  rock industry have  been seen which
are 100 percent efficient.  Some conveyors used for  similar  applications
in the crushed-stone industry, however,  do control  transfer  points to the
                        - •     32
point of no visible emissions.
     Bucket elevators are usually enclosed and evacuated to  a control device
since otherwise they would generate substantial  amounts  of dust.
     Rock which has been ground  is usually conveyed  in totally enclosed
systems, such as described in Chapter 3.  These systems  are  very effective
                                   4-18

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at limiting fugitive emissions since discharge points of material and of
particulate-laden air are well defined and easily controlled.  In essentially
all cases, particulate emissions can be effectively controlled by proper
maintenance of the transfer system and its control device.  Since the
pneumatic systems operate under positive pressure, monitoring of emissions
from the control device is the only necessary means for enforcement of a
visible emission standard.  A leak in the transfer system itself will require
immediate attention of plant personnel to minimize product loss.
     Dry rock, both ground and unground, is normally stored in enclosed
bins or silos which are vented to the atmosphere.  Emissions from the
vents are frequently controlled by fabric filters.  For pneumatic ground
rock handling systems,'this is the same fabric filter which controls
emissions from the transfer system.  The dust they collect is returned to
the silo.
     The emissions potential for a typical materials handling and storage
                                                        33
system is estimated as 2 pounds per ton of rock handled.     The control of
air pollution must be a priority item in the design of new materials
handling systems since retrofitting is often costly and difficult because
of space limitations and often results in a less efficient system.
4.8  WET GRINDING
     The most promising "air pollution control technique" for dryers and
calciners is the recent move toward wet grinding of rock for the manufacture
of wet-process phosphoric acid (WPPA).  The rock is ground in a water slurry
and then added to the WPPA reaction tanks without drying.  This has not been
done previously because the water entrained with the ground rock would
require a stronger acid in the WPPA reaction (or be removed by evaporation)
                                   4-19

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to maintain the 54-percent P^Og strength needed for production of fertilizer.
Historically, 93-percent sulfuric acid has been diluted to 58-percent for the
WPPA reaction prior to addition to the reactor to permit removal of the
heat of dilution.  If added to the reactor at 93 percent strength, the
heat of dilution coupled with the heat of reaction would exceed the capacity
of the vacuum flash cooler used for temperature control.  Also, it was
widely accepted that the higher temperatures would result in formation of
smaller crystals of waste gypsum which would complicate the separation of
product acid from waste gypsum.

     Two companies have now overcome their reservations about the wet
grinding process.  They have designed larger flash coolers on .the reactors
to remove the heat of dilution, and have found no significant difference
                                  34
in the crystal size of the gypsum.    The products from the reactor are
fed to the evaporators at 28 to 32-percent P^Og acid, the same as the
conventional WPPA process.
     The only significant problem created by wet grinding is the water
balance around the plant.  EPA's effluent water regulations require zero
discharge by 1980.  Wet grinding adds about 300 gallons per minute to an
effluent discharge volume which operators of WPPA  plants are already
finding difficult to control.  However, the potential  savings (elimination
of the energy intensive phosphate rock dryer and its air pollution control
system and air pollution controls for the grinder) is a strong incentive
to the operator.
     Plant management contends that the major driving force for the process
is not improvements in technology, but increasingly expensive fuel  costs
                                       35
and stringent air emission regulations.    It is now less expensive to
                                   4-20

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treat the wet rock than to contend with high energy costs and increasingly
stringent air regulations.
     The impact of the wet grinding process could be far-reaching since about
                                                                          36
70 percent of all phosphate rock is ultimately used to produce fertilizer,
and 85 percent of the rock used for fertilizer must first be converted to
phosphoric acid.37  If wet grinding proves to be a trend in the industry
(and present indications are that it will),38 the growth rate for phosphate
rock dryers will become negligible.  Of course, there will continue to be
a requirement for dry rock unless ways are found to introduce wet ground
rock into the processes other than WPPA.  Much of this need may be filled
by the capacity  of existing dryers rather than construction of new ones.
The need for emission controls on phosphate rock grinders, though
diminished, will continue since the calcination process will probably
continue at  its  current rate of growth and calcined rock must be ground.
                                    4-21

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                     REFERENCES FOR CHAPTER 4
 1


 2


 3
7


8



9

10

11

12

13


14

15

16
Sauchelli, V. Chemistry and Technology of Fertilizers.  New York.
Reinhold Publishing Corporation.  I960., p. 75.

Letter from J. C. Barber, Tennessee Valley Authority, to Lee Beck,
Environmental Protection Agency, dated November 18, 1975.

Chemical Construction Corporation.  Engineering and Cost Study of
Emissions Control in the Phosphate Industry.  Unpublished draft.
Volume XI.  August 1972.
                                                *
Tomany, J. P.  A Guide to the Selectio'n of Air Pollution Control Equip-
ment; Air Correction Division, Universal Oil Products.  Darien, Connecticut.
Undated.  P. 14.

Lindsey, A. M., and Segars, R.   Control of Particulate Emissions from
Phosphate Rock Dryers.  Environmental Protection Agency Region IV,
Atlanta, Georgia.  January 1974.

Information obtained from the following sources:
a.  Letters from "A. B. Capper, Catalytic, Inc., to Lee Beck, EPA,
dated August 30, 1974; September 6, 1974; October 18, 1974;
October 25, 1974; October 30, 1974;.November 4, 1974; November 20,
1974; December 30, 1974; and January 6, 1975.
b.  Letter from R. A. Schutt, EPA, to Mr. Lee Beck, EPA, dated
October 15, 1974.

Letter from R. C. Tirnberlake, Brewster Phospnates, to P. J.  Traina,
Environmental  Protection Agency, dated May 3,  1974.

Gooch, J.  P. and McCain, J.  D.  Particulate Collection Efficiency
Measurements on a Wet Electrostatic Precipitator.   EPA Publication do.
650/2-75-033.   March 1975.

Lindsey and Segars.  op cit.

Ibid.

Ibid.

Ibid.

Control Techniques for Particulate Air Pollutants, Environmental  Protection
Agency, Publication Number AP-51, January 1969, P. 125.

Lindsey and Segars.  op cvt.   p. 6.

Ibid.

Ibid.
                               4-22

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17.

18.
Ibid,

Ibid.
            p.  7
19.  Trip Reports written to J.  C.  Berry,  Environmental  Protection  Agency,
     by Lee' Beck, Environmental  Protection Agency,  dated December 12,
     1974, and January 15, 1974 (2);  January 17,  1974;  January 22,  1974;
     January 31, 1974; February 4,  1974;  (2) February 7, 1974; and  February  8,
     1974.

20.  Lindsey and Segars,  op_c_i£.   p.  8

21.  Ibid.

22.  Ibid,  p. 9

23.  Environmental Protection Agency. Control Techniques  for Particulate
     Air Pollutants,  Environmental  Protection Agency Publication  No. AP-51
     January 1969.  p. 125.

24.  Lindsey and Segars,  op cit.

25.  Letter from Mr.  J. F. Cochrane,  J.  R. Simplot  Company, to Mr.  Don R.
     Goodwin, Environmental Protection' Agency, dated May 27, 1975.

26.  Ibid.

27.  Danialson, J. A.  Air Pollution  Engineering  Manual, Cincinnati, Ohio,
     U. S. Department of Health,  Education and Welfare,  Public Health Service
     Publication No.  999-AP-40.   p. 260

28.  Environmental Protection Agency.   Control Techniques for Particulate
     Air Pollutants,  Environmental  Protection Agency.  Publication  No. AP-51,
     January 1969.  p. 125

29.  Information obtained from the following sources:  (a)  Letters from A.  B.
     Capper, Catalytic, Inc., to Lee  Beck, EPA, dated August 30,  1974;
     September 6, 1974; October 18, 1974;  October 25, 1974; October 30, 1974;
     November 4, 1974; November 20, 1974;  December  30,  1974; and  January 6,
     1975;  (b)  Letter from R.  A.  Schutt, EPA, to  Mr.  Lee Beck,  EPA, dated
     October 15, 1974.

30.  Conversations between Mr. Lee Beck,  Environmental  Protection Agency,
     and Messrs Basil Powell, U.  S. S. Agri-Chemical , and J.  Gadston,
     Royster Company, on September 23 and  26, 1974, respectively.  Also
     reported in trip report from Mr.  C.  L. Vacher, Catalytic, Inc., to
     Mr. Lee Beck, Environmental  Protection Agency, dated October 17, 1974.

31.  Information obtained from the following sources:  (?a)  Letters from
     A. B. Cappter, Catalytic, Inc.,  to Lee Beck, EPA,  dated August 30,
     1974; September 6, 1974; October 18,  1974; October 25, 1974; October 30,
     1974; November 4, 1974; November 20,  1974; December 30, 1974;  and
     January 6, 1975;  (b)  Letter from R. A. Schutt, EPA, to Mr. Lee Beck,
     EPA, dated October 15, 1974.
                                 -4-23

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32.
33.
34.
    Vervaert, A. E. , Jenkins, R. , and Basala, A.  An Inves tigation of th e
    Best Systems of Emissions Reduction for Quarrying and Plant Process
    Facilitiefin  the Crushed and Broken Stone  Industry.  Draft document
    prepared by the Environmental .Protection Agency, Research Triangle
    Park, North Carolina.  August 1975.  p. C-17
     Environmental  Protection Agency.  Compilation of Air "P?11"*8"* ?|!]«1on
     Factors,  Second  Edition, April  1973,  U.  S.  Environmental Protection
     Agency,  Publication  No. AP-42.  p. 8.18-1.
     Telephone conversation between Mr.  Lee Beck,               .
     Agency and Mr.  Fred Huges  on June 23,  1975.   Also,  letter  from
     Mr.  Harold Long, Agrico Chemical  Company,  to  Mr.  Don  R.  Goodwin,
     Environmental Protection Agency,  dated August 19, 1975.

35.  Ibid.

36   PEDCo-Environmental Specialists.   Trace Pollutant Emissions from  the
     Processing of Non-metallic Ores.   Environmental Protection Agency
     Contract Number 68-02-1321, Task No. 4.  p.  6-1

37.  Stowasser, W. F.  Phosphate Rode.. United States Department of the
     Interior, Bureau of Mines.  Preprint from Bulletin 667.   1975.  p, 6.

38   Telephone conversation between Mr. Lee Beck, Environmental Protection
     Agency! Snd  Mr. Fred  Huges, on June 23, 1975   Also, letter from
     Mr.  Harold Long, Agrico Chemical Company, to Mr. Don R.  Goodwin,
     Environmental Protection Agency, dated August  19, •  I97b.

39   Telephone conversation with J. F.  Cochrane and Roger Humberger.
     Simplot  Company, on December  21  and 22, 1978,  respectively.

40.  L.  E.  Sparks of Environmental  Protection Agency, SR-52 Program-
     mable Calculator Programs  for Ventun  Scrubbers  and Electrostatic
     Preci pita tors.  EPA document  No.  EPA-600/7-78-026 , March 1978.

41.  Engineering-Science,  Inc., EPA Report  for Mobil  Chemical ,  Nichols ,
     Florida.   Prepared for Environmental  Protection  Agency, Contract
     No. 68-02-1406, January 1976.
                                    4-24

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                5.  MODIFICATION AND RECONSTRUCTION

    In accordance with Section 111 of the Clean Air Act,  standards  of
performance shall be established for new sources within a stationary
source category which "...may contribute significantly to air pollution
..."  Standards apply to operations or apparatus (facilities)  within  a
stationary source, selected as "affected facilities," that is, facili-
ties for which applicable standards of performance  have been  promulgated
and the construction or modification of which  commenced after the pro-
posal  of said standards.

    On December 16, 1975, the Agency promulgated amendments to the
general provisions of 40 CFR Part 60, including additions and revisions
to clarify modification and the addition of a reconstruction provision.
Under the provisions of 40 CFR 60.14 and 60.15, an "existing facility"
may become subject to standards of performance  if deemed modified or
reconstructed.  An "existing facility" defined  in 40 CFR 60.2(aa) is an
apparatus of the type for which a standard of performance is promulgated
and the construction or modification of which was commenced before the
date of proposal of that standard.  The following discussion examines
the applicability of these provisions to phosphate rock processing
facilities and details conditions under which existing facilities could
become subject to standards of performance.  It is important to stress
that since standards of performance apply to affected facilities which,
combined with existing and other facilities comprise a stationary source,
the addition of an affected facility to a stationary source through any
                               5-1

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mechanism, new construction, modification or reconstruction, does not
make the entire stationary source subject to standards of performance,
only the added af-fected facility.  :

5.1.  40 CFR PART 60 PROVISIONS FOR MODIFICATION AND RECONSTRUCTION

5.1.1.   Modification
             It is important that these provisions"be fully understood
prior to investigating their applicability.

             Section 60.14 defines modification as follows:
                  "Except as provided  under paragraphs  (e),
             and  (f) of this section,  any physical or operational
             changes to an existing facility which result in an
             increase  in emission rate to the atmosphere of any
             pollutant to which a standard applies shall be a
             modification.  Upon modification, an existing facility
             shall become an affected  facility for each pollutant
             to which  a standard applies and for which there is  an "
             increase  in the emission  rate".
             Physical  changes  in equipment design such as a modification
of  the dryer flights to increase gas-to-sol ids contact or the replacement
of  a totally enclosed  ground rock transfer system with an open system
would probably subject the operator to the provisions of Section 60.14
since emissions from the equipment would increase.
         Paragraph (e)  lists certain physical  or operational  changes
which will not be considered as modifications,  irrespective  of  any
change in the emission  rate.   These changes  include:
             1   -  Routine maintenance, repair and  replacement.
             2  -  An increase  in  the  production  rate not requiring
                   a  capital  expenditure  as defined in Section 60.2(bb).
                                5-2

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              3  -  An increase in the hours of operation.
              4  -  Use of an alternative fuel or raw material if prior
                    to the standard, the existing facility was designed
                    to accommodate that alternate fuel or raw material.
              5  -  The addition or use of any system or device whose
                    primary function is the reduction of air pollutants,
                    except when an emission control system is removed or
                    replaced by a system considered to be less efficient.
          Paragraph (b) clarifies what constitutes an increase in
 emissions in kilograms per hour and .the methods for determining the
 increase, including the use of emission factors, material balances,
 .continuous monitoring systems, and manual emission tests.  Paragraph (c)
 affirms that the addition of an affected facility to a stationary source
 does-not make any other facility within that source subject to standards
 of performance.  Paragraph (f) simply provides for superceding any
 conflicting provisions.
5.1.2  Reconstruction
      Section 60.15 regarding reconstruction states:
           "If an owner or operator of an existing facility proposes
      to replace components8 and the fixed capital cost of the new
      components exceeds 50 percent of the fixed capital  cost tnat
      would be required to construct a comparable entirely new facility,
      he shall notify the Administrator of the proposed replacements.
      The notice must be postmarked 60 days (or as soon as  practicable)
      before construction of the replacements is commenced.  ..."
      The purpose of this provision is to ensure that an  owner or operator
does not perpetuate an existing facility by replacing all  but vestigial
components, support structures, frames, housings, etc., rather than  totally
replacing it in order to avoid subjugation to applicable  standards of
performance.   As noted, upon request, EPA will  determine  if the
proposed replacement of an existing facility's  components  constitutes
reconstruction.
                               5-3

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5.2  Applicability to Phosphate Rock Processing  Operations

    5.2.1  Modification
     The following physical  or operational  changes will  not be con-
sidered as modifications to existing phosphate rock plants, irrespective
of any change in the emission rate:
                  1.   Changes  determined to be  routine  maintenance,  repair,
                       or replacement.   For phosphate rock processing plants,
                       this will  include the replacement or refurbishing  of
                       equipment elements subject to high heat or  abrasion
                       and  impact such  as refractory linings, crushing sur-
                       faces, screening surfaces, and conveyor belts.

                   2.  An  increase in the production rate if  that.increase
                       can  be accomplished  without  a capital  expenditure  ex-
                      . ceeding the existing facility's  IRS  annual  asset guide-
                       line repair allowance of 6.5 percent per  year.

                   3.  An increase in the hours  of operation.
                   4.  Use of an alternative raw material,  such as Florida
                       land pebble, if the existing facility was designed
                       to accommodate such material.
                   5.  Use of  an alternative fuel, such  as switching from
                       natural  gas  to fuel oil, if the  existing facility was
                       designed to  accommodate  the alternate-fuel.   If the
                       facility was  not so designed, the switch would be con-
                        sidered a modification unless it 'could be  demonstrated
                                 5-4

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                      that the new fuel did not result in an increase
                      in emissions.  However, conversion to coal required
                      for energy considerations, pursuant to Section
                      113(d) (5) or Section 119 (as in effect before the
                      date of enactment of tne Clean Air Act Amendments
                      of 1977) of the Act, shall not be considered a
                      modification.

                  6.  The addition or use of any air pollution control
                      system except when a system is removed or replaced
                      with a system considered to be significantly less
                      effective.

     The impact of the modification provision on existing phosphate
rock, facilities should be very slight.  Except as noted above, no con-
dition is foreseen which would deem an existing phosphate rock pro-
cessing facility modified.

5.2.2  Reconstruction
     The replacement of facility components could be considered recon-
struction if the fixed capital  cost of replacement exceeds  50  percent of
the cost to construct an entirely new facility.

     One action which could be considered reconstruction  for a dryer,
calciner, grinder or ground rock transfer system would be the  replace-
ment and extensive refurbishing of power plant and drive  mechanism,
including motor, chains, belts, gears, couplings,  reducers,'clutches,
bearings, etc.  In such  case, the test involving the relationship
between the fixed capital  cost of the replacement versus  the correspond-

                                5-5

-------
ing costs for complete reconstruction of the facility should be used to
determine applicability of the reconstruction provision.  The final
determination will be made by the EPA Administrator based on information
provided by the owner.
     Replacement of facility components which are subjected to extreme
heat (e.g., refractory linings) or attrition due to abrasion or impact
(e.g., crushing surfaces, screening surfaces and conveyor belts) could
be considered routine maintenance and may therefore be exempted by the
reconstruction and modification provisions.
                               5-6

-------
                     CHAPTER 6.  ENVIRONMENTAL IMPACT

6.1  INTRODUCTION
     This chapter identifies and analyzes the environmental impacts of alterna-
tive emission control systems as applied to the phosphate rock processing
industry.  Incremental impacts on air, water, solid waste, and energy resulting
from the use of alternative control systems are assessed.  The short-term
versus long-term trade offs, including resources commitments, of the
alternative control systems are described and compared for each impact analysis.
Impacts of establishing emission standards (based upon application of the
different control systems) are compared with the impacts of not proposing or
promulgating standards of performance for new sources.
     Those processes within the phosphate rock processing industry that are
included in the impact analysis are drying, calcining, grinding and ground
product materials handling.  Processes not considered, and hence, not included
in the impact statement, are mining and beneficiation.  Descriptions of
these processes are in Chapter 3.
     The alternative control systems under consideration as the best demon-
strated controls for the phosphate rock processing industry are the high effi-
ciency electrostatic precipitator (ESP), fabric filters (baghouses) and high
energy scrubbers.  Each of these devices is currently used by the industry to
control emissions; however, their application is usually process specific.
Scrufihers, for example, are the most common control  device for emissions from
dryers and clrtctners:, although.most are low energy devices; (8 to 10 inches of  water),
                                     6-1

-------
 whereas baghouses are commonly used to control  emissions from grinding and
 materials  handling.   Baghouses are not currently being  used to control
 emissions  from dryers and  calciners.   From the  similarity  between  the  emission
 characteristics from  phosphate rock dryers and  calciners and similar operations
 in  other industries,  such  as  clay  and  kaolin  dryers,  it is  believed  that
 fabric  filter  application  on  phosphate rock dryers and  calciners is  feasible an
 and could  achieve high particulate control  efficiencies.  Additional discussion
 on  the  alternative control  system  is presented  in Chapter 4.

 6.2 ENVIRONMENTAL IMPACT  OF  STANDARDS OF  PERFORMANCE
 6.2.1   Air Impact
     The air impact resulting  from the application of the alternative control
 systems  is evaluated  by considering the incremental reduction  in particulate
 emissions  beyond  that  achieved to  meet state  implementation  regulations.
 6^2J.I  Emissions Limited  by State Implementation Regulations

     State Implementation  regulations  that are of concern for this  industry
 are limited to eight states:  Florida, Tennessee, Idaho, Montana, Utah,
 Wyoming, California, and North Carolina.  Mass emissions of particulates
 from rock processing plants in six of  these states are limited to a general
 process weight rate regulation.  These regulations are illustrated  in Figure
 6-1,  Another state uses the criteria of best available  equipment that  is
 reasonable and practical; in the eighth state (California),  each county sets
its own regulations.   In all cases where process weight  rate is used, the
regulations become more stringent as the process weight  rate increases.  Six
                                    6-2

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                 6-3

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states use one equation for process weight rate of 30 tons per hour or less
and another equation for more than 30 tons per hour.  Process weight, in
general, is defined as the amount by weight of solid fuel, recycled material
and raw material being handled in that process; it does not include liquid
and gaseous fuels, uncombined water and process air.

6.2.1.2  Uncontrolled Particulate Emissions - The uncontrolled particulate
emission characteristics  are summarized by source in Table 6-1 for the phosphate
rock  processing  industry.  The emissions  data  are  based on  information  reported
by the industry  and data  collected  by  EPA.1'2'3'4   Emission factors listed
for dryers  and  calciners  include  the effect of primary cyclones.   Cyclones  are
considered  as part of the process equipment.   This is because  cyclones  are  used
primarily for material  recovery and recycle rather than for pollution control.
Furthermore,  note that no distinction  is  made  in  the table  between rotary  and
fluidized bed dryers  and  calciners.  Available emission information  does not
reveal  any  obvious  differences  in emissions from  the two  units after the
cyclone.
      Variations in  emission  factors are due to inherent differences  in  the pro-
cessed rock and differences  in  the process design.  In drying  and calcining,
the range  of emissions rates are  caused primarily by differences  in the ore.
The industry reports  that drying  of pebble rock results  in  greater emissions
 than  that resulting from drying of other grades of beneficiated rock.
                                       6-4

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       6-5

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Compared to other ores, pebble rock is softer and more easily disintegrated by
attrition, and contains more submicron clay particles which are easily sus-
pended.  During the process of calcining, the greater emission loadings are*
experienced during processing of unbeneficiated rock.
     The emission information for dryers and calciners presented in Table 6-1
represents emission characteristics for units that are direct-fired with fuel
oil or natural gas.  The emission rates, gas flow rates, and temperatures
presented are the median of the ranges observed in the industry, and are
assumed to be typical values.  The variations in exhaust gas volumes for dry-
ers and calciners are relatively small (+20 percent) whereas variations in the
the values for grinders and ground rock handling are larger.  Energy consider-
ations are believed to be  responsible for the smaller variation in values for
dryers and calciners; large variations in values for grinding and ground rock
handling  are  probably due  to  variations in process design.
     The  particle size information in Table 6-1 (i.e., mass median diameters,
mt), and  standard geometric deviations, Sg, for log-normal distributions) are
based  on  particle sizing tests of emissions from dryers, calciners and
           e.  />, "/
grinders.1'5'6'7  The  values  presented are the midpoint of the  ranges observed
for particulate emissions  from phosphate  rock plants and are assumed to be re-
presentative  of  "typical"  phosphate  rock  facilities.  For those sources where
only  a single particle sizing test was conducted the distribution provided by
that  test was assumed  representative.  The particle  size distributions  for
emissions from material  handling were assumed equivalent to  those for grinders.
                                        6-6

-------
 6.2.1.3   Particulate Emissions Levels Achievable Using Alternative Control
 Systems  - The  emissions  levels which  are  achieved  when  the  alternative  control
 systems  are  applied  to typical  uncontrolled  emission  sources  are  shown  in
 Table  6-2.   The  overall  collection efficiencies  of the  baghouse and ESP alter-
 natives  are  estimated by applying fractional efficiency data  available  in  the
 literature     to the typical particle  size distribution given  in  Table  6-1.
 The  collection efficiency of the scrubber alternatives  is estimated by  applying
 an EPA venturi scrubber  model  which utilizes as  inputs  the  assumed scrubber
                                                          o
 operating condition  and  typical emissions characteristics.     The predicted
 emission  levels  associated with each control alternative are consistent  with
 emissions levels observed at phosphate rock  facilities  presently employing the
 candidate control systems (see Appendix C).
     It should be noted  that both the ESP and scrubber  are  capable of achiev-
 ing  control  efficiencies equivalent to that attained by the fabric filter.
 This is accomplished by  designing the control system for the expected emissions
 characteristics.  Alternative  designs will result in different collection
 efficiencies, different  capital and operating costs, and possibly different
 environmental impacts.   Because the analyses of control  alternatives is con-
cerned with selection of the best system of emissions reduction considering
cost and nonair environmental  impacts, the less efficient  versions of  the
scrubber and ESP are also considered  in the analysis as  candidate  control
systems.

6-2.1.4  Particulate Emission  Reductions  Resulting  from  Alternative  Control
Systems - To estimate the impact of the alternative control  systems on emissions
levels, it is necessary  to  determine  the  total  amount  of industrial production
                                         6-7

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 which will be affected by the New Source Performance Standard.   The  standard
 will  apply to:  1)  new plants,  2)  processes  with  existing  plants  that  undergo
 major modifications,  and  3)  new processes within  a  plant that  are a  result  of
 expansion.
      New sources  resulting from plant expansion and  from new plants  (Items  1
 and 3 above)  are  expected to  total about  5 percent per year based  upon produc-
 tion  figures  from 1950  compared  to those  projected for 1980.9',110 Hence, if TPW
 is  the total  (industry) process  weight of phosphate  rock for the nth year following
 promulgation  of standards, this  growth of new sources can be expressed as TPW
      n                                                                      0
 (1.05  -1), where TPWQ  represents  production for  the base  year corresponding
 to  n=6.  Based upon a 20-year life expectancy of  existing  process  equipment,
 new sources due to major  in-plant modifications would be 5 percent per year
 of  the  base year  production (TPWQ).  Hence,  new sources resulting  from major
 in-plant modifications  can be expressed as n(0.05 TPWQ).  Therefore, the  total
 of  new  source process weight  for the nth  year (N$n)  after promulgation of new
 source  standards  can be expressed as follows:
(NSn)
                                     n (0.05)} (TPWQ)
The new, source yearly process weight predicted by this equation, using the
base year of 1975, where (TPWQ) = 56,700,000 short tons,9 are in thousands
of short tons:
n . 1 5 10 20
Nsn
TPWn
5,700
59,500
29,800
'72,400
64,000
92,400
122,100
150,400
                                    6-9

-------
The predicted total process weight (TPWn) for the industry  is  also  included for
comparison purposes.
         Processing of production from new sources will  be by various  schemes
(e.g., drying,  calcining,  etc.).  Hence,  in assessing the impact, it is necessary
to  anticipate  the  percent  of new source production  by the various processes.
Based  on available data for current  production  by various processes, 90 percent
of  process weight  from new sources will be processed through dryers and 10
percent  in  calciners. . Furthermore,  90 percent of the process weight from new
sources  is  assumed to be ground and is throughput for ground rock handling.
Based on application  of the various  candidate emission  control  systems, and the
 typical  gas  characteristics of emissions  presented  earlier  (Table 6-1), the
 total  emissions from new sources are projected  for  1, -5,  10, and 20 years  into
 the future.   These results are presented in Table 6-3 in  tons/year.
          The impacts of the various  control alternatives  on source  emissions
 levels  are given  in  Table 6-4 in terms of the difference between the emissions
 allowed by typical state implementation regulations and the typical  source
 emissions levels  resulting from the various control alternatives.  Using the
 results presented in this table, the new source production  rates given earlier
 and throughputs of 90,  10, 90,  and 90  percent for drying, calcining, grinding
 and ground rock handling,  respectively,  the reduction in totals emissions can
 be estimated.  These total  reductions  in emissions are presented in Table 6-5,
 The  results  of Tables  6-3 and 6-5 reveal that utilization of the most effi-
  cient candidate control systems will  result in  total new source  emission
  reductions  of 95  percent beyond that required by typical state  implementation

                                       6-10

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         Table 6-4.  REDUCTION OF EMISSIONS FROM SIP LEVELS WHEN
                     ALTERNATIVE CONTROLS ARE APPLIED (Ib/ton)
Source
Dryer
Calciner
Grinder
Ground Rock
Handling
Alternative Control System
Fabric filter
High energy scrubber
High efficiency
0.22
0.73
0.87
0.19
Medium energy scrubber
ESP
0.16
0.34
0.87
0.19
regulations.   Utilization  of the  less efficient medium energy scrubber or ESP
results in total  new source  emission  reductions  of 87 percent beyond the
state implementation requirements.   In  addition,  variation between the levels
of control has the greatest  incremental  impact on the process of drying, and
very little impact on grinding and  ground rock handling as can be seen in
Table 6-5.
6.2.1.5  Atmospheric Dispersion Modelling11- An  atmospheric dispersion model
was used to assess the level of the ambient concentration which results
from emissions from phosphate rock processing plants.  The modelling considered
estimates over 24-hour and  annual averaging periods for particulates.  All
pollutants are assumed to display the dispersion behavior of non-reactive  gases.
The estimated pollutant concentrations  are based on the application of state-of-
the-art modelling techniques, which  implies a readability of the estimates
to within about  a factor  of two.
                                     6-12

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6-13

-------
         As shown in Table 6-6, eight combinations of process and size were
examined:  70 and 25 tons per hour (TPH) calcining operations, JOO and 50 TPH
drying operations, and 100 and 20 TPH grinding operation.  The levels of con-
trol  achieved by the various  control  alternatives and the control  level achieved
by typical  state implementation  regulations were examined within each combination.
         The following assumptions are applied in the analytical  approach:
         1.  There are no significant seasonal or hourly variations in emission
rates for these plants.
         2.  The plants are located in flat or gently rolling terrain.  In
restrictive terrain, the dispersion of effluents could be more impaired,'resulting
in higher ambient concentration levels.
         3.  The meteorological regime is unfavorable to the dispersion of
effluents.  The effect of this is to introduce an element of conservatism into
the analysis.
A stack not sufficiently taller than surrounding structures is an unfavorable
feature of all 18 prototype plants analyzed (EXCEPTION:  £he three 100 TPH
grinding facilities).  This causes- aerodynamic complications which can
seriously interfere with the rise of the effluent plume, thereby producing signi-
ficantly higher ground-level concentrations.  The physical dimensions and other
dispersion-related plant characteristics associated with these designs are
summarized in Table 6-7.  Note that 18 "plants" are enumerated.
                                  6-14

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-------
         The dispersion model used to analyze this plant is the single source
model (JMHCRD-1) developed by EPA's Meteorology Laboratory.   A summary description
of this model is given in Appendix F.l.
         The model is programmed to use a previously determined set of dispersion
conditions derived from the basic meteorological"data for each hour of the given
year'.  The calculations simulate the interactions between the plant characteristics
and  these dispersion conditions to produce a dispersion pattern for each hour.
These computations are performed for each point in an array of 180 receptors
encircling the plant.  Cumulative averages are calculated at each of the
receptors for any number of  hours.  In the case of phosphate rock processing,
the  averaging periods of interest are 1 hour, 24 hours, and annual.
         The phosphate rock processing plants were modelled with the aerodynamic-
effects version of JMHCRD-1 (Appendix F.2).  These effects were found to be
critical for the 300 TPH drying plant and the 20. TPH grinding plant.   The
effects were noticeable in most of the other phosphate rock processing cases
examined, but were less significant.  The exceptions to this were the 100 TPH
grinding facilities where no significant aerodynamic effects were noted.

         Preliminary analyses indicated that the critical  meteorological
conditions (i.e., those giving rise to maximum short-term impact) varied with
the different prototype plant designs.  These may be categorized into two
general sets of conditions, namely, those characterized by high wind speeds
under slightly unstable conditions and those characterized by low wind speeds under
highly unstable atmospheric conditions.  Within each of these two general

                                    6-16

-------
classes, there was further differentiation exhibited  by wind  speed.   In addition,
if such conditions occur frequently at a given location,  especially  if they can
be combined with a high directional bias in the wind, then  longer-term impact
(e.g.,  24-hour and annual) will also tend to be  a maximum.

         The maximum estimated concentrations for the various averaging periods
associated with each pollutant from each phosphate rock process  are  given in
Table 6-7.
         As expected, the highest concentrations  are  generated by sources which
are emitting at the ceiling rates permitted by typical state implementation re-
gulations.  The maximum 24 hour average particulate  concentration resulting
from a 70 TPH calciner is estimated to occur .3 km from the  115.2  m stack, and
would be about 89 yg/m3 when the calciner is regulated by  state implementation
regulations.  When the calciner emissions are controlled by  fabric filters,
high energy scrubbers, "or high efficiency electrostatic precipitators, the
maximum resulting 24 hour average particulate concentration  is expected to be
14 ug/m3.  The concentration of particulate matter resulting from smaller cal-
ciners  (25 TPH) is proportional to the decrease in capacity  for the typical
calciner plants investigated.
         The 300 TPH drying process plants have higher concentrations than the
50 TPH  plants with respect to their emission rates.   For example, although
Plants  7 and 12 have nearly equivalent emission rates, the 300.TPH plant
(Plant  7)  has much higher maximum concentrations as  well as  slightly shorter
distances  to maximum annual concentrations.  These high concentrations at
                                      6-17

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-------
extremely close-in distances for the 300 TPH drying process plants are due to
•severe aerodynamic complications on the plume rise.  Emissions from the 50 TPH
plants do not experience these aerodynamic conditions since they have a much
higher exit velocity than the 300 TPH plants.  Based on the modelling results
in Table 6-7, ambient concentrations of particulate matter are expected to
violate both the annual and 24 hour National Ambient Air Quality Standards
near a 300 TPH dryer which is controlled to comply with typical state imple-
mentation regulations.  Substantial concentrations would also be expected when
medium energy scrubbers or electrostatic precipitators are used as control.
 It  is estimated that utilization of fabric  filters or controls of equivalent
 efficiency  (high  energy scrubber and high efficiency ESP) would reduce ambient
 concentrations to  acceptable  levels.
         The highest participate concentrations from the grinding process
plants are produced by Plant  18 and are due partly to a relatively high emission
rate, but primarily to aerodynamic effects  on plume rise.   The three 20 TPH
grinding process  plants have  relatively much higher maximum concentrations
with respect to their  emission  rates than the 100 TPH grinding process plants.
These are due to  the aerodynamic  effects such as downwash on plume rise, created
mostly  by much lower exit velocities for the 20 TPH plants.  This also
 causes  the  20 TPH maximum concentrations to be extremely close to the plants.
 None  of the model  grinder plants alone  are  estimated to  cause .violations of the
 ambient air standards.
 6.2o2   Solid Waste Impact
        Nbne of the alternative  emission control  systems  are expected  to result
                                        6-19

-------
 in  significant  additional solid waste impacts beyond that experienced under
 enforcement  of  state  regulations.
       The solid waste  from  phosphate rock  processing  (drying,  calcining,  grinding
 and ground rock handling) consists  of material  that is  collected in  air
 pollution control devices.   Although emissions  from grinders  and ground rock
 handling are controlled largely by  using baghouses,  some  scrubbers are  also
 being used.  Emissions  collected by baghouses should not  be considered  solid
waste because this material  is recycled.  Companies do, however,  recycle this'
material in different ways:  to ground rock storage, to the grinder, directly
 to product, etc.  Scrubbed emissions from grinding  and ground rock handling
 are normally piped to large  settling ponds which also contain sol ids-laden  .
effluent from other plant processes.  The incremental amount of solids  added
 as  a result  of  more stringent control of emissions will be negli-
 gible.
       The emissions from dryers and calciners  are  usually collected
with scrubbers, although some electrostatic precipitators are also used.
The usual practice for  handling the material collected in scrubbers
                                                       .»
 and electrostatic precipitators, which is generally considered solid
waste, is to pump it to the  large settling ponds mentioned above.
Data on solid waste from 10  dryers  includes values ranging from 1.75
Ib/ton to 16 Ib/ton with an  average of 8.35 Ib/ton of rock processed.
       The incremental impact of the alternative control systems..on solid
 waste is presented in Table 6-8.   The incremental amounts  represent the
 additional solid waste over that which  is  produced when typical state re-
gulations are enforced,  assuming that all collected emissions from grinding

                                    6-20

-------
and ground rock handling are recycled, and that those from calcining and drying
are wasted.  Basically, therefore, the values in Table 6-8 are the sum of
annual emissions reductions for calcining and drying at new sources as present-
ed in Table 6-5.                                              ,
       Considering that about 70 percent of the material in ore mined in Florida
                                                  1 o
is removed as unuseful waste during beneficiation,  and that this amounts to
over 100 million tons per year, then the additional amount of solid waste re-
sulting from application of the control alternatives shown in Table 6-8 is
insignificant.

6.2.3  Energy Impact
       The energy impact of more stringent levels of control for the phosphate
rock processing industry is the resulting incremental increase in energy for
pollution control  systems beyond that required to meet existing  state standards.
              Table 6-8.   INCREMENTAL IMPACT OF ALTERNATIVE CONTROLS
                          ON SOLID WASTE
                                        (TONS/YEAR)
Control
Alternatives
Fabric filter
High energy scrubber
High efficiency ESP
Medium energy scrubber
ESP
Years after imposition of Controls
on New Sources
1 5 10 20
775 4,021 8,631 20,282
510 2,649 5,690 13,370
                                       6-21

-------
The forms of energy, by process, Included in the impact are electricity  for
dryers, calciners, grinders, pollution control equipment and ground  rock
handling systems and fuel for calciners and dryers.  The control devices included
are scrubbers (impingement, cyclonic and yenturi), electrostatic precipitators
(ESP's), and baghouses.
6.2.3.1  Current Energy Usage . Typical energy usages and ranges of  energy  usage
for phosphate rock dryers and associated air pollution control devices  currently
being used are shown in Table 6-9.  Process energy usage for dryers  varies
from 251,000 to 481,000 Btu/ton processed.  The process fuels being  used
to fire the dryers are natural gas and fuel oil.  Electrical usage for
dryers is typically 6000 Btu/ton or approximately 1-1/4 to  2-1/2 percent of
the total processing energy.  Note in Table 6-9 that the energy consumption
of the pollution control devices for dryers, which is entirely electrical
energy, does not have a large impact on the total process a"nd control energy
consumption.  The energy usage of the control devices varies from less  than
1.0 percent of the total energy usage for cyclonic scrubbers to 6.8  percent
for medium energy venturi  scrubbers.   However,  of the  total  electrical energy
consumption, cyclonic scrubbers  consume about one-third of the electrical energy,
and the other control devices listed which  do not  include baghouses consume  more
than one-half.   Hence, control  devices  for  dryers  currently  have a large impact
on electrical  energy only.

       Energy usages reported for five fluidized-bed phosphate rock  calciners
range from 375,000 to 525,000 Btu/ton processed with an average of 469,000
                                    6-22

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 Btu/ton.  Unfortunately,  it is not possible to accurately determine from industrial
data the portions of electrical energy consumed by fluidized-bed calcining and by
 the  associated  emission controls separately.  However, the total electrical
 energy consumption is less than 2.5 percent of the total process and control
 energy consumption by impingement and cyclonic scrubbers and by electrostatic
 precipitators.   When medium energy venturi  scrubbers  are used,  the  electrical
 energy consumption for both calcining and emission control  is  15% of the total
 process and control energy consumption.   By a comparison with  electrical  energy
 usuage for controlling emissions from dryers, it would appear  that  the  electrical
 energy consumed by control systems for calcining units would be about the same
 percent of the total process and control  energies, that is, from less than 1.0
 percent of the total process and control  energy consumption for cyclonic
 scrubbers to about 6.8 percent for medium energy venturi scrubbers.
                                                             *
     If an average control device energy usage is assumed to be 4 percent of
 total electrical energy usage, as is typical for phosphate rock dryers, then
 the e«ergy currently required to operate the control  device would  average
 18,760 Btu/ton.  Although no energy data are available for rotary  calciners,
 their energy consumption is believed to be approximately 525,000 Btu/ton.
 This value is based on the fact that rotary calciners are normally  less thermally
 efficient than fluidized beds.10
     Electrical energy is the only form of energy used for phosphate rock
 grinders, which are usually ball mills or roller mills.  The control of emissions
 from grinders appears to be mainly by baghouses, with some venturi  scrubbers
 also being used.   In Table 6-10 is shown the typical  and the range  of energy
                                        6-24

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 consumption for grinders and their respective control devices and the percent
 of the total process and control energy consumed by the control device.  The
 energy requirement for the control equipment is approximately 5 percent of the
 total energy, and averages 1385 Btu/ton of rock processed.
     Data concerning energy consumption of rock transport systems is reported
 by only one company.  Their system consumes 43,600 Btu/ton and the associated
 baghouses consume 1,838 Btu/ton or 4.0 percent of the total.  It is interesting
 to note that this company's rock transport system and associated control device
 consume 54  percent as much energy as its grinder and associated control device.
 Again, the  energy impact of the control device (4 percent) is relatively minor.

-6v2"3-.i2- Energy  Increase ResuUI-ng- from More Stringent Control - Table 6-11
 compares energy  consumption for various control alternatives with current
 energy usage.  ESP's  show  a lower  energy  consumption than  the  other  control
 devices.   This is  because  of  the  low pressure  drop  across the device  and  the
 ab.sence  of energy  requirements for pumps,  shakers,  compressors for pulse  air
 cleaning,  etc.  The high voltage  used  by  ESP's is  usually discharged with  a low
 average amperage and consequently does not consume much  energy compared  to the
 energy required for movement of  large volumes of  gases  through the  system.  The
 energy required for operation of a fabric filter is about the same as  for a venturi
  scrubber operating at 18 inches of water AP.   Venturi  scrubbers  operating  at
  25 to 27 inches of water AP will  consume the most  energy of the systems  compared,
  and low energy venturi scrubbers operating at about 6  inches of water, AP  will  con-
  sume less energy than fabric filters and about the same as ESP's.
                                         6-26

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                                                          6-27

-------
       Comparison of the control system energy estimates in Table 6-11 with
the prevailing energy consumption figures in Table 6-9 suggests that control
devices for calciners and most dryers will operate with less energy than current
control devices regardless of the control option chosen.  This is not likely,
and is probably the result of comparing energy estimates derived from two
different information sources.  The current energy consumption figures were
obtained from owners and operators of calciners, and the projected energy re-
quirements for the various control levels were obtained from designers of the
control equipment.  However, the relative comparisons of design energy between
the different systems are believed to be accurate.

6.2.3.3  Summary of Energy Impact - The energy impact resulting from more
stringent levels of control for phosphate rock processing will be on electrical
energy only and will depend on the type of control alternative that is used.
The overall increase in energy requirements for any affected facility over that
being consumed by the process and existing control devices under state regula-
tions will be less than 8 percent for even the most energy - intensive control
alternatives.
       The data in Table 6-11 clearly illustrate that the energy impact will be
more adverse for venturi scrubbers than for the other control  devices.  Rela-
tive to the prevailing controls employed to meet state regulations for dryers
and calciners (low energy wet scrubbers which operate at about 6 inches of AP), it
is expected that more stringent emission regulations will result in an 8 percent
increase in total process energy requirements if high energy venturi scrubbers
                                    6-28

-------
  are used, approximately no change in energy requirements  if ESP's'are  used,
  and about a 5 percent increase when baghouses are used.

        Minimal actual energy impact is expected for controlling emissions from
  grinding and ground rock materials handling to the more stringent levels of
  control discussed in this chapter.  The reason for this is that the emissions
  from these processes are currently being controlled in a number of plants with
  baghouses.   If new sources within the industry use an alternative control de-
  vice other than the baghouse, the overall  process  energy requirements  will
 increase or decrease slightly depending on the type  of control  alternative
 used (i.e.,  scrubber of  ESP).
 6.2.4   Water Impact
        Promulgation of Federal  standards of performance for the phosphate
 rock processing  industry will  have little  additional  impact on  water pollution
 beyond  the  impact  resulting from  compliance with state regulations.   It
 is  not  possible  to  define  the exact nature  of  the water  impact  associated
 with the control of  emissions from phosphate   rock processing because the
 amount  of wastewater generated is so highly influenced by the type and
 application of control systems and because any wastewaters from these opera-
 tions are normally combined with other wastewaters  prior to treatment,  re-
 cycling and/or discharge.  However, the absolute water impact from phosphate rock
processing is believed to be minor compared with those from phosphate rock
beneficiation and from further processing operations on phosphate rock, such as
phosphoric acid production.
                                     6-29

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     Currently  the only potential sources of water pollution from phosphate
 rock processing  are waters from scrubbing of emissions, primarily from
drying and calcining operations.  Regardless of. the exact source of waste
waters from phosphate rock processing, the amount of water used is relatively
small compared with the amount of water used for beneficiation.  About
10,000 gallons per ton of product is used for beneficiation,15 whereas
250  to 350 gallons of water per ton of processed rock is typically used
to scrub emissions from drying.

     Treatment of waste waters from phosphate rock processing normally
consists of gravity separation in ponds which also contain  waste waters
from beneficiation and/or phosphoric acid production.  Occasionally the
overflow from  these ponds is treated by addition of floculating agents and
pH adjustment.   Wastewaters  from rock processing constitute a negligible
addition to these ponds.
      Deposition  of the overflow waters from  the settling poinds is- dependent upon
a number of factors.  These  include:
          - the  amount recycled;
          - rainfall,  (total and  frequency);
          - surface runoff;
          - evaporative  losses;
          - available pond  acreage.
 In  the western states where  evaporative  losses are a major  factor,  the
 entire overflow  from  the ponds is  usually  recycled and  accounts for 65 percent
                                     6-30

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 or greater of the process water.  In the eastern states, evaporative  losses
 normally do not offset the effect of precipitation.  Hence part of  the
 overflow from the ponds  is  intermittently or  continuously discharged to
 receiving bodies'of  water;  the  remaining portion, 60  to  90 percent,  is
 recycled.15
 6.2.5,  Radiation  Impact
        The pollutants-contained  in the treatment waters  can encompass not
 only  the recognized  parameters  such as suspended solids, high acidity, fluorides,
 and phosphates, but  also radiochemical pollutants (e.g., radtum-226).T6  The source
 of the  radiochemical pollution problem is the widely  acknowledged presence of
uranium, in phosphate  rock in the range of 0.1  to 0.4 pounds per  ton  of  rock.   Dis-
 charge  or failure of the holding ponds described above  (6.2.4)  could therefore
 constitute a major pollution problem  to the aquatic environment of  receiving
 streams; likewise, seepage  of these waters into aquifers could  contaminate drinking
 waters.  Sampling of recycled water reportedly  has  indicated that such waters con-
 tain  90 to 100 picocuries per liter of radiochemical  pollutants17 -  more than 3
 times the Atomic  Energy  Commission (AEC) standard for release to an  unrestricted
 environment  within an  AEC licensed plant, and 30 times the maximum permissible
 concentration  for water.  However, when the radium  concentration in  the water
 table aquifer  was compared  at mined and unmined Florida phosphate rock reserves,
 no significant differences  were found.18
        Sizeable quantities  of radioactive particles have been found in solid
wastes  discarded  from phosphate rock plants.   One study analyzed for radiochemical
pollutants in  phosphate rock slimes (a by-product of beneficiation)  and found
                                    6-31

-------
radium-226, uranium and thorium in quantities of 45, 89, and 53 picocuries per
gram, respectively.19  Soil throughout the United States typically contains
                                                       20
between 0.15 and 2.8 picocuries of radium-226 per gram.tu
      Recent  attention  has  been  given  to  the  exposure to  radioactivity
  of  persons  in structures  built on  reclaimed phosphate land.   One study
  showed exposure of inhabitants of  such  structures  to be up to 50 times
  the normal  background level  of radiation.21  This  exposure is about 2.5
  times greater than the present federal  guideline for maximum exposure
  of  uranium miners.22   Promulgation of regulations under the authority of the
  Resource Conservation and Recovery Act (RCRA) will result in controls to alleviate
  the potential health hazards being increased at landfills.
    Air emission standards  will  impact on the discharge of radiochemical pollutants
only to the extent that they may require a slightly greater aqueous discharge and
sludge disposal (i.e.,  from scrubbers).  However, as explained in  6.2.4, the
quantity of water used for emission  control devices is negligible  compared to the
total water usage at a phosphate rock plant.   If we consider only  the incremental
difference between the water usage necessary to comply with existing emission
regulations and the amount necessary for standards of performance  likely to be
proposed, the impact of standards of performance on radiochemical  pollution will
be negligible.  Likewise, the additional  amount of particulate collected and
ultimately disposed as solid waste will be negligible.  In fact, particulate
collected by dry collection devices  such as baghouses will  have a  positive impact
on radiochemical pollution since it can be returned to product inventories rather
than discarded.
                                         6-32

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6.2.6  Resource and Trade-Off Analysis
     Application of the alternative control  systems  to control  emissions  from
the phosphate rock processing industry to within  an  obtainable  limit  will
result in minimal  or no short-term versus long-term  trade-offs  between
environmental parameters.  However,  their application does  result in
trade-offs between  the environmental  parameters  and economics, and between
environmental parameters and  energy..
     The use of any of the alternative  control systems—ESP1 s, high
energy venturi scrubbers, or  baghouses—should not  result in any short-
term versus long-term trade-offs  involving  air quality,  water  pollution
and solid waste generation.   Basically  this means that the  application
 of any one of the control systems to meet a stringent control  level  will
 not result in any adverse short-term or long-term impact on  either solid
 waste or water,  and that use of any  one of  the systems can accomplish  the
 same beneficial  air impact.

      A significant trade-off in controlling emission  from phosphate  rock
 grinding and materials handling exists  between the  irretrievable  loss  of
 product (resource)  and the type of control  system.  Dry  dust control systems
 allow the captured emissions  to be recycled as product whereas wet control
 systems make this practice economically infeasible.   The economic benefits
 of recovering collected emissions  is  demonstrated by the fact .that most
 plants currently  recycle emissions from the  primary dry  collectors and from
 baghouses  employed in control of  grinders emissions.
                                    6-33

-------
     Environmental-economic trade-offs also exist in the choice of a  con-
trol system for each of the four emission sources.   For the  more stringent
control requirements, capital  costs are greater for a baghouse than for
venturi scrubbers (see Chapter 7).   However, energy requirements and  overall
operating costs, are greater for the venturi scrubbers.   Therefore, the use
of the baghouse would result in long-term economic and environmental  benefits,

     Totally economic short-term versus long-term trade-offs exist in the
application of the alternative control systems.  For example, the high
initial capital cost of ESP's  can only be compensated for in the long-term
by their low operating and maintenance costs relative to the other two
alternative control systems.  In the application of the venturi scrubber,
there is another totally economic trade-off which is low initial cost
versus high energy costs.  Thus in the long-term the high-energy venturi
scrubber is not the most economical control system for particulate control.
Use of such a device is also a long-term commitment to greater energy
consumption.
     Trade-offs resulting from the use of water with  the  venturi  scrubber
and not with the other devices is not considered  to be  significant.   The
reason for this is that the quantity  of water  used by scrubbers is not
large thus permitting the waste waters so  generated to  be treated by
conventional methods and recycled.
6.3  ALTERNATIVE ACTION PLANS
     The environmental impact of .the  three alternative  control systems is
                                    6-34

-------
 considered  a major factor for the evaluation of three alternative action
 plans,   the three  plans  are:   1}  the continued use of SIP regulations;.
 2) establishing more  stringent levels of control for new sources and,
 3) delaying the promulgation of standards of performance in anticipation of
 being able  to establish more stringent control in the future.
6.3»1  Continued Use of SIP Regulations
       From a technical and economic  standpoint,  continued  use  of SIP
regulations for new sources is unwarranted.  This  is  because application
of any of the three alternative control systems—ESP's,  scrubbers,
and baghouses—are capable of better  control than specified  by  the SIP
regulations.  The corresponding emissions reductions  over the SIP's  for
typical-sized.new sources is presented in Table 6-5.
6.3.2  Establishing New Levels of Control  for New Sources                  •
       A relative ranking of environmental  impacts for the alternative
control  systems is  shown  in Table 6-12.   Number one was  used  in  the ranking
to indicate the least adverse impact, and succeeding numbers  were  used to
indicate a^greater degree of adverse impact.   Wherever possible  quantita-
tive information  was used in ranking (e.g.,  particulate  control  limit);
otherwise best  engineering judgements were made.
       Control  of emissions with  ESP's and baghouses  produced minimum
impacts  to water,  solid waste  and energy.  Actually,  these two control
devices  have no impact on water and allow collected  particulate matter to
be recycled. This  minimizes  solid waste, conserves  a  resource, and requires
                                    6-35

-------
Table 6-12.  RANKING OF IMPACTS FOR THE ALTERNATIVE
             CONTROL SYSTEMS
Control System
High-energy Venturi
scrubber
High efficiency ESP
Baghouse
Medium energy scrubber
ESP
Impacts
Air
1
1
1
2
2
Water
3
1
1
2
1
Solid Waste
3
1
1
2
1
Energy
3
1
2
2
1
Radiation ,
3
1
1
2
1
                         6-36

-------
 far less  energy  for operation than does a venturi scrubber.  Application of
 venturi scrubbers to control emissions to the same degree as baghouses will
 result in a significant impact on energy, a negligible impact on solid
 waste and water, and will not permit the economic recovery of particulate
 matter.                        .   •      '

 6'3'3  Delaying  the Establishment of Standards of Performance
       If establishment of standards of performance is delayed  for about
 five years, EPA will be in a.better position to evaluate the technical and
 economic feasibility of wet grinding.  If proved feasible, wet-grinding
would enable the Agency to promulgate standards which would disallow all
particulate emissions from phosphate rock drying and grinding of low
 >rganic ores (about 75 percent of the ores currently mined).  However,
 or the following reasons, delaying  of the standards is not recommended:
         1,
Over 36,000 tons of avoidable particulates would be emitted from
existing plants over the next five years.  This can be seen from
the interpolation of the annual emissions reduction data given
1n Table 6-5.
The emissions data presented in Appendix C would be out-dated and no
longer valid.  This would, at great expense to the taxpayers,
necessitate a new engineering program to evaluate the level
of control attainable at that time.
Prompt institution of stringent standards will make wet-grinding
even more economically attractive than it is  now.   This will
serve to hasten industry's development of the process.
                                      6-37

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                            REFERENCES FOR CHAPTER 6
 1.  Lindsey, A.M., R. Segars.  Control of Particulate Emissions from
     Phosphate Rock Dryers.  Environmental Protection Agency, Region IV,
     Air Programs Office, Technical Assistance Branch, Atlanta, Georgia.
     January 1974.

 2.  Chemical Construction Corporation, Base Data of the Industry Technical
     Survey, Volume XI of Engineering and Cost Study of Emissions Control  in
     the Phosphate Rock Industry.   Prepared for Environmental Protection Agency,
     Contract No. CPA-70-156, 30 June 1970.

 3:  Chemical Construction Corporation, Summary, Volume I of Engineering and
     Cost Study of Emissions Control in the Phosphate Rock Industry.   Prepared
     for'Environmental Protection Agency, Contract No. CPA-70-156, 30 June 1970.

 4.  D. M. Augenstein of PEDCO Environmental, Inc., Air Pollutant Control  Tech-
     niques for Phosphate Rock Processing Industry.  Prepared for Environmental
     Protection Agency, EPA Document No.^EPA-450/3-78-030, OAQPS No.  1.2-113.
     June 1978.

 5.  Engineering-Science, Inc.  EPA Report for Mobil Chemical, Nichols,
     Florida.  EPA Emissions Test Report No. 75-PRP-3.  January 1976.

 6.  Letter from J. F. Cochrane, J. R. Simplot Company, to Don R. Goodwin,
     Environmental Protection Agency, response  to  information  request regarding
     phosphate rock grinders and calciners, dated May 27,1975.

 7.  Baladi, E.  Stationary Source Testing of a Phosphate Rock Plant at
     the Beker Industries Corporation Conda, jldaho.  EPA Emissions Test
     Report No. 75-PRP-4.  November 1975.

 8:  L. E. Sparks of U.S. Environmental Protection Agency, Office of Research
     and Development, SR-52 Programmable Calculator Programs for Venturi
     Scrubbers and Electrostatic Precipitators.  EPA Document No. EPA-600/7-
     78-026.  March, 1978.

-9.  National Fertilizer Development Center, Tennessee Valley Authority.
     North American Production Capacity Data.  Muscle .Shoals, Alabama.
     Circular Z-57.

10.  U.S. Department of the Interior, Bureau of Mines.  Minerals Yearbook,
     1971.  Volume,!.

•IT.  Walden Research Division of Abcor, Inc.  Modeling Analysis.of the
     Ambient Air Impact of Phosphate Rock Processing.  October 1975.

12.  Fullen, H.T., B.P. Faulkner.   Inorganic Fertilizer and Phosphate
     Mining  Industries-Water Pollution and Control.  Battelle-Memorial
     Institute, Battelle-Northwest.  Richland, Washington.  12020FPO.
     August  1971.  p. 207.
                                    .6-38

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13.  Kaufmann, R.F., and Bliss,  J.D.   Effects of Phosphate Mineralization and
     the Phosphate Industry on Radium-226 in Ground Water of Central  Florida.
     EPA Document No. EPA/520-6-77-010.   October, 1977.   p. 3.

14.  Guimond,  R.J.,  and Windham, S.T.  Radioactivity Distribution  in
     Phosphate products, By-Products,  Effluents, and Wastes. EPA  Technical
     Note No.  ORP/CSD-75-3.  August 1975.  p. 5.

15.  Environmental Protection Agency.  Preliminary Findings Radon  Daughter
     Levels in Structures Constructed  on  Reclaimed Florida Phosphate  Land.  '.
     EPA Technical Note No. ORP/CSD-75-4.  September 1975.  p.  6.

16.  Ibid,  p. 14.                          .

17.  Ibid,  p. 13.


18.  Kunii, D. and 0. Levenspiel.  Fluidization  Engineering, New York,
     John Wiley and  Sons, Inc.  1969.  p. 28.

19.  Kennedy Van Saun.Corp.-. Rock Talk Manual.   K1074.   1974.   p.  57-58.

20.  Versar, Inc.  Development Document for Effluent Limitation Guidelines
     and Standards of Performance, Mineral  Mining and Proce«;sing Industry.
     Volume II.  Prepared for the Environmental  Protection Agency.  Contract
     No. 68-01-2633.  January 1975. p. V-65, V-69.

21.  Rouse, J.V.  Radipchemical  Pollution from Phosphate  Rock Mining  and
     Milling.   Environmental  Protection Agency.   Presented at Water Resources
     Problems  Related to Mining, American Water  Resources  Association,
     Proc. No. 18.  June 1974.  p. 65-71.

22.  Ibid.
                                   fi-39;

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                              7.   ECONOMIC IMPACT
7.1  PHOSPHATE ROCK INDUSTRY ECONOMIC PROFILE
7.1.1  Industry Structure
     Table 7-1 shows phosphate rock producing companies, plants, and capacities
The industry consists of 20 firms which are currently mining phosphate rock at
31 locations.   Another five mines are expected to be operational by 1983, and
four others have been planned with indefinite start-up dates.  Most firms have
mining operations and rock processing plants at the same location, while a few
companies mine in several areas and ship the rock to a central processing
plant.  Total  industry capacity in January 1978 is estimated at 57.9 million
metric tons per year.
     The southeastern U.S. is the center of the domestic phosphate rock industry,
with Florida,  North Carolina, and Tennessee having over 90 percent of the
domestic rock capacity (see Table 7-2).  Florida, with approximately 78 percent
of 1978 domestic capacity, dominates the U.S. industry and is the world's
largest phosphate rock producing area.   Most of these plants are located
around Polk and Hillsborough counties in Central Florida, with expansion
taking place in Hardee and Manatee counties.  Hamilton county, located in
North Florida, is the other phosphate rock producing area.
     Tennessee's phosphate rock industry, located in the middle of the State,
has declined in importance over the last several years and is now the least
important rock producing area in the country.  The Tennessee Valley Authority
and two private corporations have discontinued mining in Tennessee, and no new
plant expansion is planned.
     North Carolina possesses a rich phosphate rock deposit in Beaufort County
along the Pamlico River.  Texasgulf, the only company currently exploiting

                                    7-1

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               Table 7-1.  PHOSPHATE ROCK PRODUCERS AND PLANT CAPACITIES
                                                                        1,3
                                          1967
                   % Increase   % of U.S. Total
           1977     1967-77         1977
International Minerals and Chemicals
       Bonnie, Florida
       Kingsford, Florida
       Noralyn, Florida

Agrico Chemical Co. (Williams)
       Pierce, Florida
    ,   Ft. Green, Florida

Occidental Agricultural Chemicals
       White Springs, Florida

Mobile Chemical
       Nichols, Florida
       Fort Meade, Florida

Brewster Phosphate
       Brewster, Florida
       Bradley, Florida

J. R. Simplot
       Ft. Hall, Idaho

U. S. Steel-Agri-Chem, Inc.
       Ft. Meade, Florida

Gardinier
       Ft. Meade, Florida

Monsanto Industrial Chemical Co.
       Columbia, Tennessee
       Henry,  Idaho

Comi nco-Ameri can
       Garrison, Montana

Texasgulf
       Aurora, North  Carolina

Swift Chemical
       Bartow, Florida
1,814


3,257
1,905
  680
1,340 32
8,618 • 58
2,722 43
4,264 38
3,175
1,814
1,814 -44
1,966 . .
1,814 -5
20.5
15.6' ;
4.9
7.7
5.7 '
3.3
3.3
3.6.
3.3
249
3,175     4,536
2,903     2,903
-63
          43
0.5


8.2


5.3
                                      7-2

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                                                             % Increase   % of U.S.  Total
                                           1967       1977      1967-77        .  1977
Stauffer Chemical  Co.
       Mt.  Pleasant, Tennessee
      . Vernal, Utah
       Wopley Valley,  Idaho

W. R. Grace & Co.
       Hookers Pr, Florida
       Bonnie Lake, Florida
       Manatee Co., Florida

Beker Industries
       Dry Valley, Idaho

Borden Chemical Co.
       Teneroc, Florida
     .  Big Four, Florida

Hooker Chemical Co
       Columbia, Tennessee

Presnell Phosphate
       Columbia, Tennessee

George Relyea
       Garrison, Montana

T-A Minerals
       Polk City, Florida

U. S. Total

Top 5 Firms

Top 10 Firms
  2,948      1,950       -34




  2,268      4,808       112




            1,089


   907       907



   454       454


   454       454


    91        91


             454


44,970    55,271       23

23,577    33,566       42

35,506    46,312       30
  3.5
  8.7
  2.0


  1.6



  0.8


  0.8


  0.2


  0.8


100.0

 60.7

 83.8
                                     7-3

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          Table 7-2.  PHOSPHATE ROCK PLANT CAPACITY BY REGION, 1978
                                                                   ,35
Florida

North Carolina

Tennesse

Western States

   Total
    Capacity          Percent        Number
   _              .of             of
(10  metric tons)       Total         Companies

    45,360             78.3            11

     4,536              7.8     ,        1

     2,359              4.1             4

     5,647              9.8            _6

    57,902            100.0   .         22
 Number
   of
.Plants

  15

   1.

   4
  27
                                       7-4

-------
this resource, recently expanded plant capacity by 43 percent and  has plans
for further expansion.  Another company has announced plans  for a  large  opera-
tion in Washington, North Carolina.
     The western phosphate rock industry is located in eastern Idaho, northern
Utah, western Wyoming, and southern Montana.  This area accounts for almost
six million metric tons per year of the U.S. capacity, or about 10 percent.
Six companies currently operate seven mines and six processing plants.
     The U.S. industry is relatively concentrated as the 10  largest producers
control about 84 percent of the capacity.   The two largest companies control
over 34 percent.   In the Florida region, two firms have nearly 44 percent of
the State's capacity, while the five largest companies control over 70 per-
cent.
     There exists a great deal of vertical integration in the industry.   As
Table 7-3 indicates, only three phosphate rock producers do  not also produce
phosphate fertilizer products. '  '   In many cases, the rock producers also
have their fertilizer facilities at the same location as the mine or rock
processing plant".  Four producers use their phosphate rock to produce ele-
mental phosphorus at the mining site and at other locations.
     U.S. companies producing phosphate rock own a sizable portion of the
domestic phosphate fertilizer capacity.   As Table 7-4 indicates,  the U.S. rock
producers control from 60 to 71 percent of the domestic phosphate fertilizer
capacity. ' '     The domestic rock producers also control  over 74 percent of
the U.S. elemental phosphorus capacity.
7.1.2  1977 Production of Phosphate Rock
     U.S. production of phosphate rock in  1977 amounted to nearly 46.4 million
metric tons, an increase of about 5.1 percent over the 1976 production level.
                                    7-5

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       Table 7-3.  VERTICAL INTEGRATION IN U.S. PHOSPHATE INDUSTRY
                                                                  1,3,4
Company
Rock
WPPA
DAP    Super
TSP     Furnace
Agrico
Beker
Bordon
Brews ter
Cominco
Gardinier
W. R. Grace
Hooker
IMC •
Mobil
Monsanto
Occidental
Presnell
Relyea
J. R. Simplot
Stauffer
Swift
TVA
Texasgulf
USS Agri -Chemicals
X
X
X
X
• X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X

X
X
X
.
X
X

X


X
X


X
X
X
X

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Rock s  Phosphate rock
WPPA -  Wet  Process  Phosphoric Acid
'DAP s Ammonium Phosphates
Super - Concentrated Superphosphoric Acid
TSP s Triple  Superphosphate
Furnace s Furnace Phosphoric Acid
P4 s Elemental  Phosphorus
                                     7-6

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        Table 7-4.  PHOSPHATE FERTILIZER CAPACITY CONTROLLED
                    BY PHOSPHATE ROCK PRODUCERS    1'3'35
Phosphoric Acid
Ammonium Phosphate
Concentrated. Superphosphon'c Acid
Triple Superphosphate
64
61
71
67
                                7-7

-------
The producers in Florida and North Carolina together accounted for about 86
percent of this output, or about 40.1 million tons.  In 1977, production from
Tennessee was near the 1976 level, well below production throughout the 1960's.
Western rock production was about 4.6 million metric tons, with southeastern
Idaho producing about 80 percent of the total western output.
7.1.3  Consumption Pattern for Phosphate Rock
     There are three principal outlets for phosphate rock produced in the U.S.
First, the major portion of the phosphate rock consumed (about 50 percent) is
used captively near the mine site to manufacture phosphoric acid, high-
analysis fertilizers, and elemental phosphorus.  Second, about 20 percent of
the rock is sold to domestic fertilizer manufacturers and other producers of
elemental phosphorus.  The third outlet is the export market, which annually
consumes roughly 30 percent of the U.S. supply.  Of the domestic demand,  .
approximately 88 percent is consumed in the manufacture of agricultural chemi-
cals, mainly phosphoric fertilizers (see Figure 7-1).  The remaining output is
used in industrial chemical production, primarily  elemental phosphorus, which
goes into the manufacture of detergents, animal feeds, food products, metals
and alloys, and a host of other products.
     The Florida and North Carolina phosphate  rock industries are dependent
upon the domestic fertilizer market and the export market for disposing of
their output.  Less than 1 percent of  the rock sold or used  in the United
States  is converted into elemental phosphorus, defluorinated rock, or other
minor applications.  'Nearly two-thirds of the  annual Florida and-North
Carolina supply is consumed in fertilizer manufacture with the balance being
exported.
     All of the rock produced in  Tennessee is  burned in domestic electric
furnaces to produce elemental phosphorus and industrial chemicals.  As for
Western rock,  about 80 percent of the  annual production is consumed domes-
                                       7-8

-------
      Figure 7-1.   Domestic Consumption Pattern for Phosphate Rock, 1977

                           (10  metric  tons)
U.S. Demand-
    34,207
                        ->-Agri culture—
                              30,123
                                  88.1%
                        -*-Industrial
                               4,084
                                  11.9%
                                                 •Defluorinated Rock
                                                      298
                                                        0.9%
.Normal  Superphosphate
      913
        2.7%

•Wet-Process
  Phosphoric Acid
   27,024
       79.0%

•Direct  production of
  triple superphosphate
    1,852
        5.4%

•Direct  applications
       36
        0.1%
                                                 •Elemental,Phosphorus
                                                   3,904
                                                      11.4%
 Ferrophorphorus
     180
       0.5%
                                   7-9

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                                      10
tically, with slightly more than one-third used in fertilizer production and
the remainder used in electric furnaces to produce elemental phosphorus.
Roughly 20 percent of the western production is exported, mainly to Canada.
     One factor adversely affecting future demand for phosphate rock is the
decline in the use of elemental phosphorus.  About 45 percent of. end use is in
detergents, and environmental regulations have caused replacement or highly
reduced concentrations of phosphates in the detergent industry.  This trend is
                   37
likely to continue.
7.1.4  U.S. Phosphate Rock Inventory Stocks
     In Florida and  North Carolina, substantial stocks of marketable rock  are
maintained throughout the year  so that an  uninterruptible feed of rock  for .the
fertilizer plants will be available.;  Mining companies in the West  accumulate
stocks  only  in the mild  months  so that the  plants can be supplied through  the
winter  months.
     Industry  stocks reached their  high  in 1970 with an  inventory of nearly
13.2 million metric  tons of  marketable rock.   During the early part of  the
decade,  increasing  demand for rock  steadily depleted the stocks  to  less than
5.3 million  metric  tons  in 1974.u    Continued production  increases, coupled
with  flat demand  in 1975 and 1976,  increased inventoried rock  to 13.8 million
metric tons  at the beginning of 1978.
 7.1.5   U.S.  Trade Patterns  and the  Phosphate Rock Situation
      As Table 7-5 indicates, the U.S  is  a net exporter  of  phosphate rock.
 Over 13.2 million metric tons of rock were exported in  1977, with more  than
 93 percent of this total coming from Florida.   Western  producers exported the
 remainder to Canada.  Exports fell  sharply during 1975  and 1976  as  prices rose
 sharply and then dropped to help clear inventories after a strong year  in
7-10

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Table 7-5.  U.S. EXPORTS AND IMPORTS OF PHOSPHATE ROCK
                      (10  metric  tons)

1964
1965
1966
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976
1977
Exports
5,782
6,643
8,390
9,137
10,976
10,284
10,649
11,419
12,950
12,585
12,605
11,131
9,433
13,230
Imports
159
134
161
126
105
127
123
76
50
59
165
33
46
158
                      7-11

-------
1974.  In 1977, exports were up only 5 percent over 1974.  Over the last
several years, an increasing percentage of Florida rock has been going to the
export market, where prices are generally higher.  This trend is unlikely to
continue indefinitely, however, as most export demand is for high grade, high
quality rock.  Grade refers to the percentage of bone phosphate of lime (BPL)
in the rock, and quality refers to the absence of foreign materials.   The
quality and grade of rock being taken from existing mines in Florida are
declining severely, and the remaining exploitable deposits are of low quality.
This signals a long-term, gradual decline in Florida's importance in the
industry,-with the slack in high quality rock, supply likely .to be taken up by
                                     38
North Carolina and Western producers.
     While the United States is the world's largest producer of phosphate
rock, with almost 42 percent of the world production in 1976,   it is not the
world's largest exporter.  Morocco, the world's third leading rock producer,
behind the United States and the Soviet Union, dominates the world's export
                                                            12
market with 37 percent of the world's rock export shipments.    The U.S., on
the  other hand, supplies between 20 and 25 percent of the world's export
shipments.  As a result of its dominance and its plentiful supplies of high
quality rock, Morocco, almost alone, dictates the price of phosphate rock in
                                       12
the  export market throughout the world.
     In June of 1977, Beker Industries, an American fertilizer manufacturer
with some phosphate production capacity of its own, announced that it had
                                                                   39
contracted to purchase a substantial quantity of rock from Morocco.    This
was  the first penetration of the U.S. market by a foreign producer, but it is
unlikely that  imports will account for a significant component of U.S.  supply
in the foreseeble  future.
                                   7-12

-------
7.1.6  Recent Industry Performance and Prices
     Since over 80 percent of the phosphate  rock  sold or  used  in  the  United
States is consumed in the production of fertilizers, and  since most" of  the
rock exported is eventually turned into fertilizers abroad,  the U.S.  phosphate
rock industry is naturally tied closely to the domestic and  world  fertilizer
markets.  As a result, when discussing the performance of the domestic  rock
industry, one is also considering the performance of the domestic  and world
                                                   V
fertilizer markets, and vice versa.
     In the early to mid 1960's, world and domestic fertilizer use  expanded
rapidly as farmers at home and abroad responded to threats of famine facing an
increasing world population.   In order to feed the world from a limited amount
of land, -it was imperative that increasing amounts of fertilizers be used to
obtain higher crop yields..  With the use of  fertilizers growing worldwide, the
production of phosphate rock expanded, both  to supply domestic needs and to
satisfy the burgeoning world demand.   As Table 7-6 indicates, U.S. production
of phosphate rock grew from a level of 23.3  million metric tons in 1964 to
37.5 million metric tons in 1968, a compound annual growth rate of 12.6 per-
cent.    The biggest jump in production came in 1966 when production increased
nearly 10 million tons.   Much of this increase in U.S.  production during this
period was due to the export market.   U.S.  rock exports nearly doubled from
5.8 million metric tons in 1964 to 11.0 million metric tons in 1968, a growth
rate of over 17 percent annually (see Table 7-5).
  ,%  The healthy growth rates experienced by the rock and fertilizer indus-
tries from the early to mid 1960's attracted new producers,  mainly oil com-
panies, into the industry and caused existing producers to expand their ca-
pacity.  However,  this build-up in both rock and fertilizer capacity surpassed
                                  7-13

-------
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-------
 the increase in demand, resulting in overcapacity and overproduction that
 became evident in 1968.  World demand, which for several years had been the
 savior of the,U.S. industry, was less than had been expected, while at the
 same time the domestic market dropped off somewhat (see Table 7-7).  Producers
 had relied more on estimates of what farmers theoretically needed to meet the
 demand for food than on projections  of what they would actually buy.   This
 resulted in the expansion that led to the massive overcapacity in the late
 1960's.
      From 1968 through 1971, domestic phosphate rock and fertilizer producers
 suffered through  a recessionary period as a result of decreased demand  and
 overcapacity.   Capacity utilization  during the  period hovered around  60  to 70
 percent,  as opposed to normal  levels of 80 to  90  percent.   U.S.  producers  were
 not able to ease  the  oversupply situation by substantially  increasing exports
 because  the industry  lost  much of  its  export trade  to  Morocco,  which was
 beginning to  exert its influence on  the  world market.
     Faced with weak  demand,  rock producers  cut back  production  in  1969 to  a
 level  of  34.2 million metric  tons, which  rose only  slightly to  35.1 million
 metric tons  in 1970 (see Table 7-6).14'15  Even with the decreased production,
 industry  stockpiles mounted  from a level  of  9.0 million metric  tons in 1967 to
 a high of 13.2 million  metric  tons in 1970  (see Table 7-7).    Prices for phos-
 phate  rock  and other  fertilizer products  plummeted, and fertilizer producers
 suffered  losses in 1968 and 1969.  In 1969,  for example, net  income (before
 interest  and taxes) as  a percent of  net sales was negative 4.3 percent.15
     Responding to the  absence of profits, rock and fertilizer producers
                                                                 t
 instituted heavy cost-cutting measures.  Production improvements were  made  in
 new plants, uneconomical fertilizer plants were closed, four western rock
mines were shut down,  cheaper transportation methods were devised,  and market-
 ing activities were cut back.  Because of these measures,  coupled with slowly
                                     7-15

-------
increasing demand, the fertilizer producers turned a profit for the first time
in three years.   Net earnings (before interest and taxes) were 0.8 percent of
net sales.17' The recovery of the industry continued in 1971 and on into 1972
as prices showed signs of firming and production approached 80 percent of
capacity.  In addition, inventories were decreasing and approaching normal
levels (see Table 7-7).
     The cyclical nature of the phosphate rock and fertilizer industries
became evident in late 1972 and during 1973 as demand for phosphate products
caught up with and surpassed supply.  Demand  for phosphate products rose
faster than  expected  for several reasons.  First, rising farm crop prices
signaled farmers  to use more fertilizer  in order to obtain higher yields.
Second,  the  expansion of food crop  acreages at home and  abroad generated an
increased demand  for  fertilizers.   Third, U.S. agricultural aid to foreign
countries led to  an expansion of fertilizer use  in developing countries.
Thus, the strong  demand coupled with  the decrease  in capacity made it  diffi-
cult  for the U.S. phosphate  industry  to  meet  the demand  in the domestic  and
export  markets  for  both phosphate  rock  and  fertilizers.  Production of rock
reached an  all-time high of  38.2 million metric  tons  in  1973, and  industry
stocks  reached  the  lowest  level  (6.9  million  metric  tons at end of year)  since
1965  (see Table 7-7).n   Production of  most fertilizer products was running  at
                                      18
90 to 95 percent of capacity in 1973.
      The tight  supply situation in the  United States  was compounded by price
controls imposed by the  Federal  government.   Phase II  controls .limited domes-
 tic phosphate prices  to  the low levels  that prevailed when  the  industry had
 excess capacity.   Meanwhile, there were no controls  on export prices,  which
 increased substantially because of strong foreign  demand.   Fertilizer  prices
 in the export market were 30 to 50 percent higher than domestic prices.
                                                                        19
As
                                   7-16

-------




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       7-17

-------
a result, the investor-owned rock and fertilizer producers directed more of
their sales efforts to the attractive export market, leaving the patron-
oriented cooperatives with the difficult task of filling the shortages created
in the domestic market.  This reversed the historical experience in which the
export market absorbed any excess after the U.S. phosphate producers had
supplied the domestic market.  With the increased sales volume and dramati
cally higher overseas prices, U.S. fertilizer producers enjoyed their most
profitable year in a decade  in 1973.
     With the mounting domestic fertilizer shortage facing the United States,
the Cost of Living Council lifted price controls on fertilizer products late
in 1973 with the promise that the industry would supply more fertilizer to
                                               r~-
domestic markets.  With this announcement and the continued strong demand for
fertilizers, domestic  prices increased steadily for the remainder of 1973 and
throughout 1974.  By early 1974,  prices for phosphate  fertilizers had risen by
more than 33 percent over the freeze  price  level, while the price for phos-
phate rock had  risen to $9 to $23 per.short ton (depending on quality)  in
                                                                 22
January  1974, from $6.50 to  $20.20  per short  ton in January 1973.    In addi-
tion, discounting on list prices  was  just about eliminated for  fertilizers.
Throughout 1974 domestic and export prices  continued  to increase.   In April
1974, U.S. rock producers were  charging $22 per short ton for 70 percent  BPL
(bone phosphate of  lime)  rock,  up from $12  per  short  ton  a year earlier.  By
the  first  part  of  1975 this  price had risen to  $35.50 per short ton; it re-
mained  constant throughout  1975.22'23  Prices for phosphate rock.on  the export
market  were  even higher,  because demand was stronger  abroad.  In October  1974
the  U.S.  export price  for 70 percent  BPL  rock was $47 per metric ton, compared
                                                                     24
with the $65 per metric ton being charged  by  Morocco  in January 1975.
                                    7-18

-------
      This  difference  between  the  U.S.  and Moroccan export prices can be explained
.as  follows.   First, the  quoted  prices  reflect the prices received by the
producer,  that  is,  they  are net of  transportation costs.   Second, the largest
market  for U.S.  and Moroccan  exports  is  Western  Europe.3  Hence, the transporta-
tion  costs for  Moroccan  rock  are  much  smaller than those for U.S.  rock being
shipped to Western  Europe.    Because  exports to Western Europe  are  a large
proportion of total U.S.  exports, the  average price received by  U.S.  producers
is  lower than the price  received  by Moroccan  exporters.   The world price in
late  1973  was only $15 per metric ton.12  The export price  in 1976 fell  to
$32.76  per metric ton and continued its  decline  to $25.85 per metric  ton in
1977, rebounding slightly to  $26.59 for  the first part of 1978.   Prices  charged
by  the  Moroccans also fell significantly during  this  period,  although  not to
the extent of U.S. prices.36'40
      While fertilizer and phosphate rock capacity increased  only slightly in
1974, producers were encouraged by  the higher prices  to  operate  plants at
maximum capacity and to  keep  other  plants  in  operation that  might  otherwise
have  been  closed for economic reasons.   Production  of phosphate  rock  increased
about 8.4  percent in 1974 to 41.5 million metric  tons.   Industry stocks  were
decreased  by  1.6 million  metric tons to  an all-time  low of 5.2 million metric
tons  and export quantities remained essentially constant  (see Table 7-7).
Thus, the  higher domestic prices  removed the  incentive to increase exports,  so
the increased U.S. supply was able  to go to the domestic market.   Nonetheless,
the supply and demand situation remained tight in the U.S. in 1974 as fertilizer
demand was  boosted further by continued  high  prices for farm products and
increased  farm acreage.    Farm products were selling at double the 1967 base
year  prices and acreage in 1974 was 10 to 20 percent above 1973 plantings.25
Demand  for phosphate fertilizer was said to be 15 percent higher than the
available supply.
                 26
                                    7-19

-------
     Although production continued to increase throughout 1975 and 1976,
domestic demand dropped slightly from its 1974 level and export demand fell
sharply both years.  The flattening in domestic demand was a result of a bad
year in the fertilizer industry (1975) following the all-time high prices and
production levels of 1974.  Fertilizer prices came down, which helped clear
surpluses, and phosphate rock prices retreated somewhat from the sharp in-
creases of 1974.  Fertilizers began to recover in 1976, but domestic use of
phosphate rock failed to rise even though prices came up slightly.  This was
partially due to decreased production of elemental phosphorus in Tennessee and
the West for nonagricultural uses.
     In 1975, the world fertilizer market was also depressed and U.S. exports
of phosphate rock dropped from 12.6 million metric tons in 1974 to 11.1 in
1975.  This slump continued in 1976 as prices continued to fall and exports
reached a 1976 low of 9.4 million metric tons, down 25 percent from 1974.  The
combination of production increases and softening demand permitted phosphate
producers to increase their year-end inventories from a low of 5.2 million
metric tons in 1974 to 12.2 million metric tons in 1976.
     The fertilizer industry recovered well in 1977 and domestic demand for
phosphate rock rose from 31.1 million metric tons in 1976 to 34.2 in 1977,
although the average value of rock sold on the U.S. market dropped by 17
percent, to $15 per short ton.  World fertilizer demand also strengthened
greatly, and the closing of the large Bu Craa mine in the Spanish Sahara has
helped to relieve  oversupply conditions.    Exports rose to 13.2 million
metric tons, a 40  percent increase from the previous year, and although world
prices continued to fall  from 1974 levels, prices were still significantly
higher than those  prevailing before Morocco tripled its prices in 1974.
                                    7-20

-------
       Demand for fertilizers is expected to fall again in 1978 as U.S. farm
  income continues to fall.   Future demand for phosphate will be greatly influ-
  enced by USDA farm programs,  which determine whether the acreage under pro-
  duction will  be cut back.   The effect of these programs  is expected to be
  neutral  at  best,  and could  entail  a significant reduction in fertilizer use.
  It  is  also  uncertain how much  longer the trend in  increased fertilizer use per
  acre will continue.   Production of phosphate  rock  for  the first  three months
  of  1978  is  down  3  percent from 1977,  and inventories are  increasing.   Exports
 were also down,  although the price  has  risen  from  $25.85  per metric  ton to
 $26.52 per metric  ton, but were reported  to be  picking up  in .April.
 7-1.7  Industry Outlook and Growth  Projections
      Table. 7-8 indicates the additional phosphate  rock processing capacity of
 each current or future producer that is expected to come on stream by 1983.
 These estimates are based on announced and planned capacity expansions that
 could change according to future industry performance.   While the total indus-
 try expansion could be less  depending on the conditions,  these totals are
 expected to  be the maximum capacity available by 1983.
      As indicated in Tables  7-8 and 7-9, total industry capacity  in  1983  is
 expected to  be around 72.9 million  metric tons of rock  per year.1'3   This
 represents a net  increase of 25.9 percent,  or  15.0  million metric  tons, over
 the  January  1978  total.  Three  new  firms have  plans to  enter the  industry
 while  about  eight new mines will be  opened.
     According  to Table 7-9, about  two-fifths  (6.2  million metric tons) of the
 absolute  capacity increase will be  in Florida.  The expansion will represent
 only a 14 percent increase over January  1978 capacity, a much lower growth
 rate than was expected"a few years ago.  Two producers are phasing out mines
and replacing them with operations having similar capacities.  Two companies
                                    7-21

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Company/Location
Table 7-3.  ANNOUNCED OR PLANNED U.S. PHOSPHATE
            ROCK CAPACITY ADDITIONS BY 1983,              , 3 42
            BY COMPANY  (Thousands of metric tons per year)  ' '

                      Additional or
                     Reduced Capacity              Capacity  Planned|
      1978 Capacity     By 1983    1983 Capacity    Beyond  1983
Agrico Chemical Co.
     Pierce, Florida
     Fort Green, Florida

Amax-Phillips
     Manatee Co., Florida

Beker Industries
     Dry Valley, Idaho
     Manatee Co., Florida

Borden Chemical
     Teneroc,  Florida
     Big Four,  Florida

Brewster Phosphate
     Brewster,  Florida

CF  Industries,  Inc.
     Hardee City,  Florida

Cominco-American
     Garrison,  Montana

Earth  Sciences (Alumet)
     Soda  Springs,  Idaho

Gardinier
      Fort  Meade,  Florida

W.  R.  Grace & Co.
      Bonny Lake,  Florida
      Hookers Prairie,  Florida 2,540
      Manatee Co., Florida
5,443
3,175
-
1,179
907
5,715
-
249
-
1,996
2,268
2,540
5,443
3,175
3,629 3,629
181 1,361
-907
1,089 1,089
5,715
1,814 1,814
249
2,268 2,268
1,996
-2,268
2,540
2,722 2,722
5,443
3,175
3,629
•1,361
1,814
1,089
5 ,715
1,814
249
2,268
1,996
2,540
2,722
 Hooker Chemical
      Columbia, Tennessee
             454
454
                                                          454
                                           7-22

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Company/Location
                Additional or
              Reduced Capacity
1978 Capacity •    By 1983    1983 Capacity
Capacity Planned
  Beyond 1983
International Minerals & Chemicals
North Wales, Florida
Kingsford, Florida
Polk Co., Florida
Husky Oil Tracts, Idaho
Miss. Chemical Corp.
Wauchula, Florida
Mobil Chemical
Nichols, Florida
Ft. Meade, Florida
Monsanto
Columbia, Tennessee
Ballard, Idaho
North Carolina Phosphate Co.
South Creek, N. C.

2,722
8,618
0 91
0 1,814

-

1,361
2,903

907
907



2,722
8,618
91
1,814

••

1,361
2,903

907
907



2,722
8,618
91
1,814

1,814

1,361
2,903

907
907

3c n o
,629
Occidental Agricultural Chemicals
White Springs, Florida
Presnell Phosphate
Columbia, Tennessee
George Re 1 yea
Garrison, Montana
J. R. Simplot
Ft. Hall, Idaho
Stauffer Chemical
Mt. Pleasant, Tennessee
Vernal , Utah
Woo ley Valley, Idaho
Swift Chemical
Bartow, Florida
T-A Minerals Corp.
Polk City, Florida
2,722

454

91

1,814

544
726
680

2,722

454
2,722

454

91

1,814

544
726
.680

2,722

454
2,722

454

91

1,814

544
726
680

2,722

454
                                          7-23

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Company/Location
                Additional  or
              Reduced Capacity              Capacity Planned
1978 Capacity     By 1983    1983 Capacity    Beyond 1983
Texasgulf, Inc.
     Lee Creek, M. C.         4,536

U. S. Steel-Agrichemicals
     Fort Meade, Florida      1,814

Total                        57,901
                   4,536
                  14,969
 9,072.



 1,814

72,870
 9,072



 1,814

80,127
                                          7-24

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just entering the industry have plans to begin production in the state by
1983, and one major producer plans to add to its capacity by opening a small
Florida mine.  These expansions represent 41.3 percent of the U.S. capacity
increase.
     In North Carolina, the only current producer has plans to double its
capacity by 1983, an increase of 4.6 million metric tons.  In addition, a new
producer has announced plans for a 3.6 million metric ton per year plant to be
opened at an undetermined time.  There are  no plans for expansion in any
Tennessee phosphate operations.  Two firms  are making major expansions in
Idaho, including  one major  producer whose operations are currently all in
Florida.  Another company has  plans  for  a slight  capacity increase at one of
its mines.
     The rate  of capacity  increase  has  slowed  in  recent years,  and these
estimates  could be somewhat optimistic  depending  on  the  performance  of the
fertilizer and phosphate rock industries over  the next  few years.  Several
variable factors (among them the price  of farm crops, price  of  fertilizer,
 crop acreage planted,  and weather conditions)  influence  domestic demand  for
 fertilizer.  The five-year decline in farm income and the  USDA  farm  programs
 will almost certainly exert a negative influence on the growth  of the industry.
 There has also been a steady decrease in nonagricultural  uses of phosphate
 rock over the past few years, which is likely to continue/  The U.S. Bureau of
 Mines has projected that domestic consumption will increase by only 2.3  per-
 cent per year between now  and 1985, which would put demand at 39.2 million
                                           41
 metric tons per year in 1983  (Table 7-10).
      Predictions are for greater stability in world phosphate markets.  It is
 unlikely that  there will be either severe  oversupply or shortage conditions
 between 1978  and 1985,  a welcome change after the boom and bust periods of the
                                     7-26

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                Table  7-10.   PROJECTED PHOSPHATE DEMAND BY 1983
                            (Millions of metric tons)

1977
.1983
High
(% Growth /yr)
Low
(% Growth/yr)
Probable
(% Growth/yr)
Domestic
Demand
34.2

43.3
' (4.0)

37.4
- (1.5)

39.2
(2.3)
Export
Demand
13.2

18.8
.(6.0)

16.3
(3.5)

17.2
•(4.5)"
Total
Production
46. 4a

62.1

53.7

56.4
Capacity
Capacity Utilization (%)
:55.3b ' 84.0

72. 9C 85.2

72.9 73.7

72.9 77.4
Notes:
           Total  production does not include inventory stocks  that  were
           required to meet demand.
           Capacity by the end of 1974.
           Capacity by the end of 1980.
                                  7-27

-------
preceding decade.  The industry also seems to be reaching a more stable price
structure after the drastic hike of 1974 and steady drops of the last three
years.
     World demand for fertilizer is expected to grow at about 4 to 5 percent
per year, and most estimates of growth in world demand for phosphate rock are
close to this figure.  This figure is lower than the growth experienced over
the last decade, partially because developed nations which have historically
purchased most of the U.S. exports are reaching the upper stage of the growth
curve for fertilizer use.  In  addition, the rate of world population growth is
declining,  indirectly affecting world fertilizer consumption.
     One factor  that is  significant  in determining what share of the export
market  is controlled by  U.S. producers is  that most world demand is  for high
quality rock.  Florida,  which  now  controls  almost  all'of the U.S.  export
market, will  have an increasingly  difficult time meeting quality requirements
                                                ^O
as  the  quality of  its ore continues  to decline.    Morocco,  the  world's  leading
phosphate  rock exporter, has  no  problems  with  quality.  U.S. producers will do
well  merely to maintain  their current  market  share,  and even this  depends  on
pricing and production  decisions by  Morocco,  over  which they have  little
 control.
      Projections based  on a probable annual growth rate of  4.5  percent  put
 U.S.  exports at  17.2 million metric  tons  in 1983.   Using  the median  projec-
 tions for domestic and export demand,  56.4 million metric  tons  of  .U.S.  rock
 will be consumed in 1983 while the industry will  have a  capacity of  72.9
 million metric tons.  This indicates that the industry will  have to  produce  at
 about  78 percent of capacity to meet demand.   The U.S.  industry has  historically
 produced at between 80 and 90 percent of capacity and, given the projected
 demand range (Table 7-10), they will probably continue at this level or reduce
                                     7-28

-------
 production  slightly.   Current  inventories  are  on  a  three-year rising,trend,  so
 it  is  possible  there will be some  cutback  to reduce these  inventories  if
 demand is soft  in  the  next  few years.
     On the basis  of the above discussion, the majority of the new plants and
 planned expansions outlined in Table 7-8 will be  needed by 1983  if producers
 wish to keep operating at normal capacity  levels.    It is unlikely that planned
 capacity will not be sufficient to keep pace with demand unless unforeseen
 circumstances arise.   Future projections lead to the conclusion that a period
of relative stability in the phosphate rock industry will  exist until at least
the middle of the next decade.
                                      7-29

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7.2  COST ANALYSIS OF ALTERNATIVE EMISSION CONTROL SYSTEMS
7.2.1  Introduction
    . As is discussed in Chapter 5, the entire  phosphate  rock  processing
operation is defined as the  stationary source,  for purposes of  establishing
standards of performance.  But comprising  this processing  operation  are
four kinds of  "affected facilities":  dryers,  calciners, grinders, and
ground rock transfer systems.  New source  performance standards are
being considered for each  of these four  facilities.
      In  the consideration  of these standards it is  convenient to define
a model  facility.  Each model  is  of such size and process  configuration
as to be fairly representative of both typical new and existing facilities
in the  phosphate rock  industry.   Furthermore, to achieve the proposed
new source standards,  three particulate emission control systems have
 been studied  for application to the dryer, grinder, and calciner model
 facilities.   Emissions from most ground rock transfer systems are already
 controlled  to a "no visible emissions" level by use of fabric filters.
 Thus, achieving  a no visible emissions level requires no additional  control
 cost, if a system operator  follows proper operating and maintenance procedures.
 However, if an  operator permits his system to violate these procedures,  itiis
  possible that a  no visible  emissions level would be exceeded, and that,  to up-
  grade the system to this  level he would need  to  incur additional operating costs,
      In this  section,  costs are  presented  for each of the three  control  systems,
  as they are applied to the  various  model  facilities.  Incremental operating
  costs  are also  presented  for  the  ground rock  transfer system baghouses.  The
  costs  of these  systems have been based  on  certain technical  parameters  asso-
                                      7-30

-------
  dated with  the model  facilities,  (e.g.,  the  gas  volumetric,  flowrates)  as
  well  as  the  participate control levels under  consideration.   (These para-
  meters are listed in Table 7-11).  However, because these.are model facility
  costs, they  cannot be taken to reflect costs  of control systems in use at.
  existing installations.  Estimating control costs at an existing installations
  is very difficult without first performing detailed engineering studies.
       Some model facility costs have been  based on data  obtained from  the
  individual phosphate rock companies through requests for  information
  under the authority of Section 114 of the  Clean Air Act.2 to 5  Cost
  data have also been available from the Industrial Gas Cleaning Institute
  (IGCI). which, under an EPA contract, has  provided information based on
 bids from actual  vendors of control equipment.6*7  Finally, a control
 equipment vendor8 and selected literature references 9 to 13 were used
 to obtain the remaining information.•
      Two  major-kinds  of costs  have been  developed herein:   installed
 capital and total  annualized costs.  The  installed capital  cost for each
 control device system includes  the  purchased cost of the major equipment
 and auxiliary equipment, the cost for site preparation and  installation
 of the equipment, and design engineering cost.  No attempt has  been made
 to include costs for research and development, possible  lost  production
 during equipment; installation, or.losses during startup.
     In addition, two installed cost estimates.have been made for each
model facility control system.   The first of these reflects the "cost of
Installing the equipment at a new facility, built, as It were, "from the
                                 7-31

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 ground up".  The other, the modified facility or retrofit control cost,
 1s somewhat higher, because the-cost for installing a system in an
 existing facility is greater, due to special design considerations, more
 complex piping requirements, etc.  Estimating this additional installation
 cost or retrofit penalty is difficult, since so many factors enter in,
 each of which is peculiar to an individual  facility.  However, for the'
 sake of simplicity, a retrofit penalty equal to fifty percent of the
 installation cost in a new model facility has been used in this  section.
 This penalty is added to the installed cost of the control system in
 the new facility to estimate the corresponding control  cost in the modified
 facility.
      The total  annualized cost is comprised of three categories:   the
 direct operating cost,  the annualized  capital  charges,  and (where  applicable)
 the  dust recovery credit.   The first accounts  for  operating  and maintenance
 costs,  such  as:
      •   Labor and materials  needed to operate  the control  equipment;
      t   Maintenance  labor  and  materials;
      •   Utilities, which include  electric power, process water,.and
         cooling water;
      •  Water,treatment '(herein, applicable to the electrostatic  pre-
        cipitator and venturi scrubber systems).
     The annualized capital charges account for depreciation, interest,
administrative overhead, property taxes, and Insurance.   The depreciation
and Interest portion is computed by use of a capital recovery factor,
                                 7-33

-------
the value of which depends on the device operating life (10 years for
the electrostatic precipitators and venturi scrubbersT"r5"~years for the
fabric filters) and the interest rate.  (An annual interest rate of 10
percent has been assumed.)  Administrative overhead, taxes, and insurance
have been fixed at an additional 4 percent of the installed capital cost
per year.
     The dust  recovery credit  accounts  for the value of the phosphate
rock dust recovered by the  control equipment.   (In this section the
credit  has  only  been  applied to  fabric  filters  controlling the grinder
model facilities).  The dust recovery credit  is  estimated  based on an
assumed value  for the collected  dust of $22 per  megagram  ($20 per  ton),
and  an  assumed dust loading of 2 gr/dscf to the  inlet  of  the  fabric
filter.  Other cost factors used in  computing the total annualized cost
appear  in Table 7-12.  All  costs reflect first quarter 1978  prides.
      The total annualized cost is then  obtained simply by adding  the
 direct operating cost to the annualized capital  charges,  and subtracting
 any dust recovery credit from the sum.
 7.2.2  Cost of Alternative Control Measures
      For each of the new and modified calciner and dryer facilities dis-
 cussed in  the Introduction, costs have been estimated for the wet elec-
 trostatic  precipitator, venturi scrubber, and fabric filter  control
 systems.   Costs  for  venturi scrubbers  and fabric filters have been devel-
 oped for model  grinder facilities.   The  costs of the alternative control
 systems  have  been computed at four  alternative  control levels:  These    •
 levels correspond to the performance of the  alternative  systems at dif-
 ferent operating designs.   The  greatest level  of control  considered is
 that which is achieved  by  the baghouse.   The level  reflecting least con-
 trol corresponds to  the  performance required  to meet typical state air
 pollution  regulations.

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     Each of these control systems consists of several pieces of equipment.
First, the wet electrostatic precipitator system consists of the ESP
itself, auxiliary equipment (fans, pumps, etc.) and a centrifugal scrubber
precleaner.  This low efficiency precleaner is installed upstream for
purposes of scrubbing the corrosive gases (sulfuric acid mist, mainly)
from the effluent before  it enters the ESP.  (These corrosive gases
result from the combustion of the more commonly used high sulfur fuel
oil in the calciners and  dryers.) Use of a scrubber precleaner has been
found to be more cost-effective .than constructing the ESP from stainless
steel or other corrosion-resistant materials.
     Each venturi scrubber system is comprised of the scrubber itself,
auxiliaries (fans, pumps, stack, etc.) and sludge disposal equipment.
The dis.posal equipment consists of a slurry settling system and  two
filtering systems (one standby) to dewater the slurry product.
     A dust disposal system consisting of dust hoppers, screw conveyors,
and a dust storage bin is included in the cost of each fabric filter
system.  Since the dust  is captured in the dry state, this system permits
the rock to be recycled  to the  process.  However, except  for the dust
captured by the  grinder  baghouses, the material is of such low quality
that  no  recovery-credit  is taken  for it.  Also included in the control
system cost are  the  fabric filter  (shaker-type), a fan, and a stack.
                                   7-36

-------
 7.2.2.1   Calciner Model  Facility                       .
      Tables  7-13  and  7-14'illustrate  the  new and  modified calciner model
 facility control  costs at  the  four  alternative  levels  of control,  for each
 of the  three control  systems discussed  previously..  Note that  these levels
 correspond to 99  to 94.5 weight  percent control of the device  inlet
 particulate  loading.  As stated  previously,  the maximum  control level  con-
 sidered  for  each  of the controls is that which is achieved by  the  baghouse,
 while the lowest  level reflects  a typical State air pollution  regulation.

     As  discussed in  Chapter 4,  venturi scrubbers are  the most commonly
 used of  the  three control  systems, mostly because they are less sensitive
 to  damage caused  by the high temperature of  the calciner exhaust.   Because
 of  this  high temperature,  no fabric filters  are being employed by  calciner
 operators.   However,  if suitable provision is made for cooling the  gas
 stream before it  reaches the filtering compartments, then fabric filters •
 can be used.   Lastly, only one calciner is now being controlled by an ESP,
 but 99 percent control has been obtained with it.
     Since high-sulfur content fuel  can be used to fire calciners, all
 three systems have been designed to protect against corrosive combustion
gases.  The ESP system employs the aforementioned  centrifugal scrubber
precleaner,  whereas the venturi scrubber and fabric filter systems are
fabricated of 316  L stainless steel—a metal  that  is  particularly  resistant
to acids and  acid  mists.
     At all  control levels, in  both  the new and  the modified  facilities,
the ESP system installed  cost is  greater than the  other two systems.   The
 Installed cost of the ESP increases  substantially  with  increasing  particulate

                                  ;7-37

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-------
 control efficiency.(see Tables 7-13 and 7-14). This occurs because
 the cost of the ESP unit alone (comprising nearly all  of the  total  system
 cost) is primarily a function of the collecting surface area, which, in
 turn, depends on the system control  efficiency.  As the efficiency of the
 ESP varies from 94.5 to 99.0 percent, the ESP surface area to gas volume
 ratio varies from about 0.69 to 4.0 m2/m3 per minute (200 to 1200 ft2/1000 ACFM).
 On the other hand, the costs of the centrifugal scrubber and the ESP system
 auxiliaries are functions of the volumetric flowrate, and hence, do not depend
 on the removal efficiency.
     The ESP total  annualized cost also varies substantially with the
system control  efficiency.   Based on the model  process weight capacity
and operating factor, this cost ranges from $1.46 to $2.29 per Mg, as
the efficiency goes from 94.5 percent to 99.0 percent in a modified plant.
      Because control efficiency  has  a negligible  effect on  the  installed
 cost of a  venturi  scrubber .system,  the new  and modified plant capital
 costs  are  the  same for each  control  level  ($601,700 and $860,700,
 respectively).  However,  since the  scrubber electric power cost is
 directly  proportional  to  the scrubber pressure drop,  itself a function
 of the control  efficiency,  the direct operating cost is seen to increase
 about  50  percent  as the efficiency rises from 94.5 to 99.0 percent.,  Note
 finally,  that the scrubber total  annualized cost is substantially lower
 than the  corresponding ESP system costs.  It ranges from $0.77  to $1.35/Mo.
      The fabric filter installed costs, though lower than the ESP costs, are
 significantly higher than the scrubber investment estimates.  However,
 the annualized cost for the fabric filter is slightly less  than that
                                     7-40

-------
of the scrubber at comparable control  efficiency.   Lastly, it bears
noting that the fabric filter cost corresponds to a sinnle level  of effi-
ciency.  Nearly all filters are designed to achieve the most stringent
control level.
     The relationships between total  annualized costs and the various
control levels are graphically illustrated in Figures 7-2 and 7-3.
7,2.2.2  Dryer Model  Facility
     The same inlet dust loading, moisture content, and control  systems
discussed for calciners also apply to  the dryer model facilities.   How-
ever, some of the parameters, such as  the operating factor, are different
(See Table 7-11).                                                  .
     Venturi scrubbers are also the most commonly used system for controlling
dryer particulate emissions.  Two operators of rock dryers employ electro^
static precipitators, one of which is a dry unit and the other, a wet ESP.
The latter system includes a wet Impingement scrubber upstream from the
ESP, installed for corrosion protection purposes.  (The design of the
model plant ESP control'system has been patterned after it.)  As explained
1n Chapter 4, fabric filtration is a feasible alternative for controlling
dryer particulate emissions, even though no existing installations
currently employ this method.
                                   7-41

-------
     600
     500
     400
•P
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     300
rr   200
•M
O
     100
Ventun
Scrubber
System
 Fabric
 Filter
 System
                                  96           97          98


                                Control System Efficiency (%)
        Figure 7-2.  Cost curve for new calciner model facility.
                                       7-42

-------
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         94
95
  96          97          98


Control System Efficiency (%)
                                                                      99
          Figure 7-3.  Cost curves  for modified calciner model  facility.
                                         7-43

-------
      Tables 7-15 and 7-16 show that the ESP system costs (both installed
and total annualized) are significantly higher than the scrubber and
fabric filter costs at all control levels.  The highest of these installed
costs ($2,215,000 for the modified plant at 99.3% efficiency) is about
two and one half times the lowest ($890,000) for the new plant at 95.5%
control  efficiency.  The total annualized costs for these extreme cases
are $0.68/Hg and $0.37/Mg, respectively.
     As  with the calciner application, the venturi  scrubber installed
costs are the same at each control level.   The variability in the total
annualized cost is solely attributable to  the differences in the respec-
tive electric power costs.
      The fabric filter system installed costs are $851,000 and $1,100,000
 respectively,  'for the new and modified facilities—values that fall  between
 the scrubber and ESP system  costs.   The total  annualized cost ranges from
 $256,000 (new  facility)  to $306,000  (modified facility),  which clearly makes
 it the  least expensive  control  alternative for control  levels of about 98.0%
 efficiency  and more.
     The costs  of dryer  controls  are  shown graphically,  in  Figures
7-4 and  7-5.
     As  stated  previously, the systems  employed'for controlling the
calciner  and dryer model  plants have been  specially designed-to resist
the corrosiveness of this exhaust stream.  To illustrate the differences
between these costs and  the costs of systems not designed with corrosion
protection, Tables 7-17 and 7-18 have been constructed, respectively, for
                                   7-44

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                                 7-47

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the new and modified model  facilities.  It is clear from both tables that
the total annualized costs  for ESP systems without corrosion protection
are substantially lower than their counterparts.  The biggest difference
is due to the fact that no  scrubber precleaner is required with the no
protection system.  In addition, the process water, water treatment, and
                                                    i
electric power operating costs are lower.
     The cost differences between designs' featuring protection and no pro-
tection from corrosion, are less pronounced for the venturi scrubber and
fabric filter control systems.  This is because the scrubber or baghouse
units designed with corrosion protection have been fabricated from 316 L
stainless steel, while the normal designs have been constructed of materials
such as rubber-lined carbon steel, which afford some, but not enough, pro-
tection.
7.2.2.3  Grinder Model Facility
     No corrosive gases are emitted from grinding operations.  Therefore,
the control systems do not have any built-in corrosion protection.  Thus,
the venturi scrubbers and fabric filters are fabricated of carbon steel,
instead of the corrosion-resistant 316 L stainless.   (Because none are
used to control grinders,:;no ESP costs have been developed.)  This fact,
coupled with the much lower volumetric flowrate, has  resulted in sub-
stantially lower control costs for grinder facilities.  The important
process  parameters  are listed in Table 7-11.
     Most commonly  the vent stream from  the grinders  is discharged through
a  fabric filter, because the effluent is low, both in moisture content
and in temperature.  Low energy venturi  scrubbers are also occasionally
                                    7-51

-------
employed, since these devices are able to meet the  SIP  emission limits
with  relative ease.
     As with the calciner and dryer models, the installed costs of the
fabric filters are higher than those for the venturi scrubbers.  But, as
Tables 7-19 and 7-20 clearly show, the total annualized costs follow a
different pattern.  For .the new facility the venturi scrubber annualized
cost  ranges-from $72,000 to $74,000/year.  Again, the fabric filter
system annualized costs are the lower:   $17,000 and $20,000, respectively,
for the new and modi'fied facilities.  Finally, Figures  7-6 and 7-7 exhibit
the costs for the two grinder control systems.
             /
      From the cost-figures presented in  this section, it  seems reasonable
to conclude that fabric filters are generally  the least costly choice for
controlling particulate emissions from calciners, dryers, and grinders.
Venturi scrubbers would be a second choice,  and ESP's would  rate a poor
third on a  total annualized cost basis.
7.2.2.4  Ground Rock Transfer Systems
      As stated in the Introduction, the  emissions from  the ground rock
transfer systems are usually captured in fabric filters and recycled to
the storage process.  Because the ground rock  is valuable, these baghouses
are installed for economic reasons.  Consequently,  the  fabric filter may be
considered  as standard process equipment in ground  rock transfer systems.
However, if a zero visible emissions standard  is imposed  for ground rock
systems, additional resources may be necessary to prevent occasional escape
of emissions  (such as when a bag tears)  from the baghouse compartment.
      The best way to prevent baghouse upsets is to  follow a strict mainten-
ance  procedure.  This procedure can be further subdivided into two areas:
bag  replacement  and general equipment maintenance.
                                    7-52

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Figure 7-6.  Cost curves for new grinder model facility,
                        7-55

-------
     80
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                                                 System
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98.5         99         99.5

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                                                         100
    Figure 7-7.   Cost  curves  for modified grinder model facility.
                            7-56

-------
     Normally, bags are replaced only when they are broken or excessively
worn.  The life of an individual bag is quite variable, ranging from less
than 1 to 10 years.    However, to prevent bag failure, one source suggests
changing the bags annually.    This would assure that a zero  visible  emissions
limit is constantly achieved.  Assuming a typical gross bag area of 14 m2
(500 ft?), per baghouse, and a bag cost of $7.00/m2 ($0.65/ft2), the cost of
replacing polypropylene bags would be $325/year.  Labor for changing the
bags would amount to 8 manhours/year, or $80/year (based on a $10/manhour
labor rate).    Finally, an additional 8 manhours/year ($80)  are required
for general equipment services,   such as lubricating the fan.  Altogether,
the incremental cost for maintaining a zero visible emissions limit over
the normal cost of control would be approximately $500/year.
     Granted, some of these costs would be incurred under normal transfer
system maintenance procedures and would not be attributable entirely to the
incremental resources required to achieve a visible emissions standard.
Nonetheless, to be conservative, the entire amount has been charged to main-
taining a zero visible emissions limit on ground rock transfer system bag-
houses.

7.2.2.5  Monitoring Costs
     Monitoring requirements imposed by a performance standard would  inflict
additional costs on phosphate rock plants.  The potential  requirements may
include opacity monitoring equipment, rock feed measurement equipment, and
equipment to monitor scrubber performance parameters.  However, some  of
the potential monitoring requirements are already being satisfied by
existing plants.  At plants utilizing scrubbers to comply with existing
                                    7-57

-------
standards, the scrubber pressure drop and liquid supply pressure are
measured and continuously recorded as_ normal operating procedure.  At
calciner, dryer, and grinder facilities, the rock feed rate is normally
controlled by weigh feed control equipment which also may be utilized to
provide measurement of the rock feed rate (as may be required during per-
formance testing).19 The weighfeed device is typically utilized as process
equipment to insure efficient operation of dryers, calciners, and grinders.
The  installed cost of rock feed control equipment is about $14,000 for a
facility  processing 150  tons per hour of rock, which amounts to an annualized
cost (including  operating and assumed maintenance costs) of about $3500
          18
per  year.
      The  most significant potential monitoring costs would result from a
visible  emissions type standard.  Equipment and  installation costs for
opacity  measurement equipment are estimated to be approximately  $20,000
per  exhaust  stack, and annual operating  costs  (including data recording
and  reduction)  are estimated at about  $9,000.  Based on a 10 percent
 annual  interest rate  (plus  an additional 4  percent  for administrative
overhead and taxes)  and  a  15 year operating life, the  annualized cost of
 an opacity monitoring system would  be  about $12,500 per year.   This cost
 is relatively minor compared to the total  annualized  cost of  those
 facility emission control  systems which  are ducted  to  the common monitored
 stack.
                                    7-58

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 7.3  OTHER COST CONSIDERATIONS
      In addition to the proposed controls on air emissions, phosphate rock
 producers are presently incurring costs to control water-born effluents.
 Because these costs represent normal investment and operating costs, they are
 included as a part of the uncontrolled plant costs in the following section.
 These costs are incurred only by Eastern producers.   Western producers can
 operate with  no discharge and without incremental  expenditures on control
 equipment because  of the characteristics of  the rock mined there, the process
 practices dictated  by those  characteristics,  and a favorable balance between
 rainfall  and  evaporation.
      The  costs  to Eastern  producers  are  wholly  incurred  in treating  and  stor-
 ing suspended solids.  The EPA regulations require the effluent discharge  to
 have  a  total suspended solids concentration not  exceeding  30 mg/1  for a  30 day
 average, or 60 mg/1 maximum average  for  any one  day.  The  investment and
 operating costs for a model plant with a capacity of 2.4 million metric  tons
 is given in Table 7-21.  Controls consist of pond treatment of the slimes and
 sand tailings.  Costs were updated from their 1974 values to 1977 values using
an inflator of 1.23.
                                      7-59

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     Table  7-21.  COST OF COMPLIANCE FOR MODEL EASTERN PHOSPHATE ROCK
                 MINING AND BENEFICIATING FACILITY, 1977
Invested Capital  Costs
     Total
     Annual Capital Recovery

Operating and Maintenance Costs
     Annual 0 & M
     Annual Energy and Power

Total Annual Costs

Cost/Metric Ton of Product

Raw Haste  Load Parameters (mg/liter)
     Suspended Solids
     Dissolved Fluoride
     Phosphorus  (total)
$13,751,400
  1,731,000


    619,000
    413,000

  2,763,000

$         1.61
   3-560
   2*
   4*
      Sources:   Development Document and  Arthur D. Little,  Inc. estimates,
      Notes:     The model  plant has  a capacity of  2.4 million metric tons
                per year,  is 15 years old,  and is  located  in the  Eastern
                region (Florida, North Carolina, and Tennessee).
               *Estimates  average values.
                                         7-60

-------
 7.4  ECONOMIC IMPACT ANALYSIS OF ALTERNATIVE  EMISSION  CONTROL SYSTEMS
 7.4.1  Introduction
      In this section, the potential economic  impact on the phosphate rock
 industry of .imposing various particulate emission control levels will be
 analyzed.   In so doing, model plants representing typical new and modified
 plants in Florida and in the West will be developed and the investment and
 annual  operating costs for each will be estimated.  Based on the information
 presented in section 7.2, the costs of the alternative emission control  systems
 will  be estimated so that the control  costs can be compared with the overall
 plant economics.   Finally,  the incremental  costs of compliance under various
 new source performance standard  (NSPS) levels  will be  compared to the  control
 costs of  the emissions reduction already required under the  appropriate  State
 Implementation Plans (SIP)  in order to analyze the economic  impact  resulting
 from  implementing those  levels.
      In the  U.S.  phosphate  rock  industry, every operation  is different in some
 respect.   In  addition  to  differences in the  sizes  of the mines  and processing
 plants, there are important.and  significant  differences in overburden thick-
 ness, matrix  thickness, and  rock quality.  Processing operations differ since
 plants  dry, grind, and calcine different amounts of rock and use different
 types of equipment to perform these operations.  Furthermore, some plants are
 associated with larger fertilizer complexes while other plants are not.   As  a
 result of these plant differences, it is difficult to construct a model  plant
 for analytical purposes that takes into account all of these variations.
However, reasonable assumptions have been made and the  costs estimated  for
hypothetical new operations that are considered to be representative of the -
phosphate  rock industry.
                                     7-61

-------
     In considering the costs of the alternative emission control systems,
three control options were devised which reflect the range of equipment combi-
nations which can be employed to meet the NSPS and SIP levels.  Control option A,
which employs fabric filters to control emissions, and option B, which uses
filters on grinding plants and Venturi  scrubbers on all  other facilities, have
similar annual  costs.   Control option C, which  utilizes  electrostatic  precipita-
tors  (ESP's) on all  operations except grinders,  is  significantly more  expensive
than  the  other  two technologies..  Based on  current  industry  practice,  control
option B  represents the most typical  control  system.   Other  combinations  of
 equipment could be used, but the control  options developed in this chapter
 reflect the range of control costs and indicate the cost of  the most typical
 systems.
 7.4.2  Model Plant Analysis for the Florida Region
 7.4.2.1  Investment and Operating Costs for a New Uncontrolled Florida Plant--'
      The model  plant  for  the Florida region has a capacity  of 2,381,400  metric
 tons of  rock per year.   It  mines  and processes  1,905,120  metric tons  per year,
 a capacity utilization of 80 percent.   Operations  for this  plant  involve
 mining the phosphate matrix with a dragline  (which also removes the overburden),
  slurrying the matrix in a sump, and pumping  the slurry to a beneficiation
  plant.  At the beneficiation plant, washing and sizing produce a  coarse  pebble
  product and remove the slimes; a double flotation process upgrades the rock to
  the finished product which is dried and ground.  The rock is dried in two 145
  metric  tons per  hour  (tph) rotary dryers.  Forty percent of the dried rock is
   ground  in  one il tph  ball  mill and two 14 tph  roller mills.  The remaining 60
   percent of the dried  rock  is sold  to  other processors.
                                       7-62

-------
       The  costs  of  mining  and  beneficiating  phosphate  rock will  increase drama-
  tically for  new operations, and  not just  because  of increases  in  equipment
  costs.  Nearly  all of the high quality  rock in  Florida  has  already  been mined
  or will be mined shortly, thus leaving  only the lower quality  rock.   Producers
  are having to dig  deeper in order to obtain the rock and  also  to mine a larger
  matrix to obtain a ton of marketable rock.   This  requires much  larger mining
  equipment than was needed 5 to 10 years ago  and also requires a larger  benefi-
  ciation plant to prepare the product for drying and grinding.  Finally, the
  cost of land is increasing because of competing uses for the land and because
 the supply of mineable land is steadily decreasing.
      Whereas older plants  and mines could be built and put into operation at
 an investment of about $10.00 per annual ton of capacity,  costs have escalated
 to the point that the investment  for a  new mine and  plant  is at least double
 that  and could  grow to around  $40-45  per annual  ton  of  capacity.31>32  Based
 on the best  information  available to  EPA at  the  present  time,  it is  estimated
 that  an uncontrolled  plant with a capacity of 2,381,400  metric  tons  of rock
 per year would  require a capital  outlay  of over  $85,932,000  or  almost $36.08
 per annual metric ton  of capacity.33  This investment includes  nearly
 $34,500,000 for  mining operations  (see Table 7-22) and almost $51,500,000 for
 the processing plant,  including the costs  of water pollution control  equipment
 (see Table 7-23).
     The annual operating costs for mining and processing operations  take into
 account charges for power, fuel, maintenance  and repair,  labor, local taxes,
 insurance,  overhead, and other miscellaneous  supplies and items.   The annual
operating cost for mining operations is  estimated to  be about $8,619}000  (see
Table 7-24),  while the costs for operating the processing plant are estimated
                                     7-63

-------
            Table 7-22.  ESTIMATED FLORIDA MINING INVESTMENT COST
                                                                 33
Operation
Thousands of dollars
Dragline   -                                                     28,554
Hydraulic Water Pumps, Pipelines, etc.                           1,259
Hydraulic Monitor Operation                                        155
Slurry Pumping                                                   2,060
Drainage, Dams, Roads, Clearing Land, etc.                       1,356
Prospecting                                                        346
Miscellaneous Equipment                                            359
Mining Overhead (Mine Shops, Office, etc.)                         375
                                                               $34,464
Cost Per Annual Metric Ton (80% capacity utilization) = $18.09
                                    7-64

-------
   Table 7-23.
ESTIMATED INVESTMENT FOR UNCONTROLLED FLORIDA PROCESSING PLANT
       (Capacity:   2,381,400 metric tons)
Operation
Washing, Screening, and notation
Dryers - 2 145 M.T./Hr Rotary
Grinders:
  1 Ball Mill - 91 M.T./Hr
  2 Roller Mills - 14 M.T./Hr
Pneumatic Transfer Systems
Storage
Water Pollution Control
Miscellaneous Equipment

Cost Per Annual  Metric Ton (80% capacity utilization) = $27.02
                                       Thousands of dollars
                                                 28,334
                                                  2,704

                                                    244
                                                    749
                                                    206
                                                  2,325
                                                 13,751
                                                  3.155
                                               $51,468
                                     7-65

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to be $14,829,000 per year (see Table 7-25).  Thus, the total operating cost


for mining and processing is about $12.30 per metric ton of product if the
      *      '           -

plant is utilized at 80 percent of capacity.


7.4.2.2  Summary of Control Costs for Florida Model Plant-


     Table 7-26 summarizes the costs of alternative emission control systems


for the new model plant.  Included are the costs of controlling the drying


plant, which contains two rotary dryers, and the grinding plant, which has one


ball mill and two roller mills.  Control option B (see Table 7-26) is con-


sidered to be the most typical control system for the entire model plant since


scrubbers are the most common control technique used for dryers and fabric


filters are the most common device, used to control emissions from grinders.


Control option A uses fabric filters on both dryers and grinders.  Control


option C employs electrostatic precipitators on the dryers and fabric filters


on the grinders.

     For each control option, three sets of costs are provided:  (1) installed


capital cost, (2) total annualized cost, and (3) annual total cost.  The


installed capital cost and the total annualized cost are taken from


section 7.2.  Total annualized costs include a capital recovery charge based

on an interest rate of 10 percent and the lifetime of the capital equipment.


The annual total cost is equal to total annualized cost minus the capital


recovery charge; that is, the annual total cost is just the sum of the fixed

and variable operating costs.  This cost is used in the economic analysis,

since the analytical technique (discounted cash flow rate of return) implicitly


accounts for depreciation and recovery of the initial capital! investment.  The


total annualized costs for each option are used to calculate the inflationary


impacts of the NSPS in section 7.5.
                                        7-67

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         Table 7-25.   ESTIMATED OPERATING COSTS FOR UNCONTROLLED
                         FLORIDA PROCESSING PLANT33	
                                    Basis
                             Thousands of dollars
Power
Fuel
Reagents
Direct Operating Labor
Water Pollution Control
Maintenance Labor
Maintenance Supplies
Administration and Overhead
Taxes and Insurance
41.7 x 106 kWh @ $0.03/kWh
9.4 x 106 gal. @ $0.28/gal.
2% of investment/yr.
2% of investment/yr.
2% of investment/yr.
Dollars Per Metric Ton (80% capacity utilization) = $7.78
                                         7-68

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- ---As  can-be -seen  from  Table  2-26,  the  total  annualized cost of control
 option A is  $0.31  per  metric  ton  for  all  control  levels.   Option B ranges  from
 $0.29 to $0.36 per metric ton,  while  option  C  ranges  from $0.41 per ton  for
 the  SIP  level to $0.68 per ton  for  the  most  stringent NSPS level.   The capital
 requirements for the alternative  control  systems  are  approximately $1,386,000
 for  option B, $2,022,000  for  option A,  and from $2,100,000 to  $4,406,000 for
 option C.
     Table 7-27 gives  the control costs for  an  existing plant  whose capacity
 is expanded  by 50  percent to  3,572,100  metric  tons  per year by adding one
 145  tph  rotary dryer and  four 14  tph  roller  mills.  These costs  also reflect a
 capacity utilization of 80 percent.   The  dryers and grinders in  the existing
 plant would  be unaffected by  the  NSPS,  but would  have to  meet  the  SIP stand-
 ards.  The new dryer and  grinders,  on the other hand,  would have to meet the
 NSPS level,  if it  differed from the SIP standard.   Thus,  the control costs  for
 the  expansion are  added to those  required to meet the SIP level  in the exist-
 ing  plant to calculate control  costs  for  the entire facility.
     The total annualized cost  of controlling the emissions from the expansion
 would be $0.38 to  $0.45 per metric  ton  for option B,  the  most  typical control
 system (see  Table  7-27).   Meanwhile,  option  A would cost  $0.41 per metric ton
 and  option C would cost from  $0.50  to $0.77  per metric ton.  Adding these
 costs to the costs of  controlling the emissions from  the  existing  plant gives
 the  control  costs  for  the entire  plant  (also shown  in Table 7-27).   Depending
 on the control level,  the annualized  cost of emissions reduction would range
 from $0.32 to $0.34  per metric  ton  for  option B, $0.34 per ton for option A,
 and  $0.44 to $0.53 per ton for  option C.
                                   7-70

-------











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     For the entire plant, the capital requirements for the alternative con-
trol systems would be $2,450,000 for option B, $3,424,000 for option A, and
from $3,465,000 to $4,615-,000 for option C.
7.4.2.3  Economic Impact on New Model Plant—
     A discounted cash flow rate of return (DCFRR) technique is used to calcu-
late the economic impacts of imposing different NSPS control levels on the
model plants.  This involves calculating the net annual after-tax cash flow
generated by the investment in the new or modified plant and discounting this
cash flow over the life of the project.  (The lifetime of the plants was
assumed to be 20 years).  The interest rate which results in a stream of
discounted cash flows whose sum is zero is called the internal rate of return
(IRR).
     An IRR is calculated for a plant utilizing each of the control options
under each of the NSPS control levels.  These IRR's are then compared to a
baseline IRR, which was calculated from a plant meeting the SIP level of
control by Option B (scrubbers on the dryers and fabric filters on the grinders),
since this is the most economical method for plants to conform to proposed
state regulations.
     The method and assumptions used to calculate the IRR's are described
below.  The selling price of phosphate rock from a typical Florida plant was
assumed to be $19.80 per metric ton and was assumed to remain constant over
the life of the plant.  The baseline cost of production for an uncontrolled
plant was $12.30 per metric ton; this was derived in section 7.4.2.1.  The
unit control costs were taken from Table 7-26.  The production and control
costs are annual total costs, that is, they do not include a capital recovery
charge.  The sum of the unit baseline production and the unit control costs
                                    7-74

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were subtracted from the selling price to get profits before tax.  This figure'



was multiplied by .52 to determine after-tax profits per ton of phosphate rock
                                                                        4 .


produced.  (The corporate tax rate was assumed to be 48 percent.)  Total plant



capital, including the cost of controls, per ton of rock produced was calcu-



lated from the mining and processing investment costs in Tables 7-22 and 7-23;



investment in the control equipment was taken from Table 7-26.  It was assumed



that, all of this investment was made prior to startup of the plant.  Using an



iterative procedure, various interest rates were used to discount the stream



of after-tax profits over 20 years; the interest rate that equated the sum of



these discounted cash flows with the investment per ton of product represented



the internal rate of return for that investment.



     The baseline return on investment  for a new Florida plant was estimated



to be 5.4 percent (see Table 7-28).  This is a  low  rate of return, which might



seem to contradict  the industry's  plans for expansion  in this region.  However,



several points  not  explicitly  incorporated in the analysis might  help resolve



this discrepancy.   First,  the  analysis  assumes  a constant selling price  for



phosphate  rock.   In actuality,  producers  planning to enter the  industry  or to



expand  existing capacity may anticipate higher  (and more stable)  prices  in the



future  that  would increase the rate of  return.   Second, a higher rate of



capacity utilization would lower  unit production costs, raise profits,  and



 increase return on  investment.  Third,  the analysis does not allow for  an



 investment tax credit,  which would also increase the  IRR.   Fourth,  it was



 assumed that none of the investment was financed through borrowing.  Borrowing



 a portion of the required  capital  would also  increase  the  IRR,  because  only



 the amount of the investment financed out of  equity or retained earnings



 enters, into the internal rate  of return calculations  as total plant capital.
                                     7-75

-------
                         s   -<    «*>
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     In the analysis that follows, two types of impacts will be considered.
First, it is assumed that the producer absorbs the incremental cost of comply-
ing with each NSPS control level.   The impact of this full cost absorption is
measured by the decline in return on investment from the baseline IRR.  Second,
it is assumed that the producer raises the selling price enough to maintain
the IRR investment at its baseline level.  This is a case of full cost pass-
through.                      .
     Option A
          Table 7-28 shows that the impacts of the proposed standard are the
same at all levels if fabric filters are used to control emissions from the
dryers and grinders.  Under full cost absorption, the return to capital de-
clines by 1.3 percent from the baseline  level.  Under full cost pass-through,
the price would need to rise from $19.80 per metric ton to $19.84, an increase
of 0.19 percent, to maintain return on investment at its baseline level.
     Option B
          Under full cost absorption, the return to capital would decline by
1.9 percent if the stringent level of control (NSPS 1) were imposed.  If more
moderate levels of control were implemented (NSPS 2 and NSPS 3), the decline
would be 0.9 and 0.4 percent, respectively.  Under full cost pass-through,
producers would need to raise the price  by 0.3 percent (from $19.80 to $19.87)
to maintain return on investment  if the  stringent control level were  imple-
mented.  At the NSPS 2 and NSPS 3 control levels, price increases of 0.13
and 0.3 percent, respectively, would be  needed.
                                      7-77

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     Option C
          As.Table 7-28 shows, the most severe impacts would occur if electro-
static precipitators were used on the dryers and fabric filters were used to
control emissions from the grinders.  Under full cost absorption, the decline
in return on investment would range from 11 percent at NSPS 1 to 5.6 percent
at NSPS 3.  Under full cost pass-through, the price increase necessary to
maintain return on investment at its baseline level would range from 1.9 per-
cent at the stringent control level to 0.9 percent at the moderate level of
control.
Summary
     From the discussion in this section, producers would use fabric filters
on the dryers and grinders (option A) if the stringent level of control (NSPS 1)
were imposed'.  Employing this option to meet the standard minimizes the impacts
on return on investment (full cost absorption) and on price (full cost pass-
through).  If either the NSPS 2 or NSPS 3 level of control were imposed, the
producer would choose option B, which consists of wet scrubbers on the dryers
and fabric filters on the grinders.  Option C would never be selected, since
the cost of this option is significantly, higher than that incurred by using
options A or B at each control level.  Thus, the impacts of complying with any
of the proposed NSPS levels are insignificant.
7.4.2.4  Economic Impact on Modified Model Plant—
     For the modified model plant,  it is assumed that a 2,381,400 metric ton
per year existing plant expands capacity by 50 percent.  The control costs for
this modified plant were presented  in section 7.4.2.2.  It is assumed that the
modified plant utilizes 80 percent  of its capacity.  In order to conduct the
                                      7-78

-------
 impact analysis, the following assumptions were made:   the  rock  sells  for  an
 average price of $19.80 per metric ton; the existing plant  operates  at  a cost
 of $8.78 per metric ton and was''built with a capital investment  of $13,09  per
 metric ton; the new facilities of the expanded plant operate at  a cost  of
 $17.26 per metric ton and could be built with a capital  investment of $50.61
 per metric ton; and the entire expanded plant operates  at a cost of  $11.61 per
 metric ton and could be built with a capital investment  of  $25.60 per metric
 ton, not including the cost of emissions control.
     The impacts on the modified plant were calculated  using the same approach
 as was used for the new Florida plant.   The baseline internal rate of return
 was estimated at 14.7 percent and was based on the costs of a modified plant
 that meets the SIP requirements by Option B.   The economics of the expanded
 plant are more favorable than those of the new plant, because the investment
 and operating costs of the existing plant are much lower.  The results of the
 analysis are given in Table 7-29.  .
     Option A
          As Table 7-29 shows, the impacts of the proposed standard are the
 same at all levels of control.  Under full cost absorption,  the decline in
 return on investment from its baseline  level  is 1.5 percent.  Under full cost
pass-through,  the price would need to rise from $19.80  to $19.90, an  increase
of 0.5 percent,  to maintain the rate of return at its baseline level.
     Option B
          Under full  cost absorption,  imposition of the stringent control
level  (NSPS 1) would cause return  on investment to decline by 0.3 percent.
Under the NSPS 2 and NSPS 3 control  levels,  the IRR would decline by  0.14 and
                                   7-79

-------



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7-80

-------
 0.07 percent, respectively.   Under full cost pass-through, a price increase of
 0.1 percent would be required to maintain the return on investment if the
 stringent level  of control  were imposed.   The price increases under the more
 moderate control  levels are essentially zero.   Furthermore,  the capital require-
'ments of the plant under any of the NSPS  levels would be unchanged from those
 required under the SIP level.
      Option C
           Employing electrostatic  precipitators on  the dryers and fabric
 filters  on the grinders would  cause severe  impacts  at all  control  levels.
 Under full  cost absorption,  the decline in  return on  investment would  range
 from 4.7 percent  (NSPS 1) to 3.1 percent  (NSPS  3).  Under  full  cost pass-
 through,  the price increases needed to  maintain return on  investment at  its
 baseline level would  range  from 1.6 percent  (NSPS 1)  to 1.1 percent (NSPS  3).
 Summary
      If  modifications  to an  existing plant were  undertaken, producers would
 choose option  B (wet  scrubbers  on  the dryers and fabric  filters  on the grin-
 ders) regardless  of the  level of control.   Even  at the  stringent control
 level, the  impacts are  very  small.  Again, option C would never  be selected as
 the  control  level, because of the  significantly higher  capital and annual
 costs associated with this option.
7.4.3  Model Plant Analysis  for the Western Region
7.4.3.1  Investment and Operating Costs for a New Uncontrolled Western Plant—
     For the Western phosphate region,  the model plant has a capacity of
1,270,000 metric.tons, and produces 1,016,000 metric tons of marketable rock
per year (a capacity utilization of 80  percent).  This scheme-assumes  an open
                                       7-81

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pit mine in the mountains where the ore is mined, segregated and stockpiled.
There is a 25 mile contracted truck haul to the milling site, where the rock
undergoes crushing,, sizing, desliming, and filtration.  The calcining plant,
the next step in the process, includes three 54 tph fluid bed calciners, while
the grinding plant contains one 91 tph ball mill and two 14 tph roller mills.
Not all of the calcined rock is ground—25 percent is sold to other proces-
sors.
     The investment and operating costs of a Western mine and uncontrolled
                                                            34
processing plant are detailed in Tables 7-30, 7-31, and 7-32  .   Mining equip-
ment and maintenance facilities would require an estimated capital  investment
of over $10,000,000, or about $8.15 per metric ton of capacity.   Meanwhile,
the investment for the uncontrolled processing plant would amount to an esti-
mated $23,562,000 or $18.55 per metric ton of capacity (see Table 7-31).
Thus, the total capital needed to construct a new mine and plant would be
$34,094,000 or about $26.70 per metric ton of capacity.
     The annual operating costs for the mining and processing operations were
estimated in a manner similar to that used for the Florida plant, assuming a
capacity utilization of 80 percent.  For the mining operations,  the annual
costs would be about $7,564,000 (see Table 7-30), while the costs for operat-
ing the processing plant are estimated to be $6,557,000 (see Table  7-32).   The
total operating costs for mining and processing amount to about $13.89 per
metric ton of product per year.
7.4.3.2  Summary of Control Costs for Western Model Plant--
     Table 7-33 presents a summary of the costs of alternative emission con-
trol systems for the new model plant.   As was the case for the Florida plant,
three types of costs are provided for each control system:   (1)  installed
                                       7-82

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    Table 7-30.  ESTIMATED WESTERN MINING INVESTMENT AND OPERATING COSTS34
                  (Capacity:  1,270,000 metric tons per year)
Investment for Mining Equipment and
Maintenance Facilities:                                      $10,352,000
Investment per Ton of Product (80% capacity utilization) = $10.19
    Operating costs
(80% capacity utilization)                           Thousands of dollars

Supplies:
     Diesel Fuel                                                 709
     Oil, Gasoline, Grease, Etc.                                 143
     Tires                                                       201
     Blasting Supplies                                           252
         . Total                                      ,          1,315
Direct Operating Labor                                         1,252
Maintenance Labor                                                442
Maintenance Supplies                                             696
Administrative Overhead                                          208
Truck Haulage to Processing Site                               3,005
Local  Taxes and Insurance                                        207
Land Investment Royalty ($0.28 per metric ton)                   439
     Total Operating Costs              ,                       7,564
     Cost Per Metric Ton (80% capacity utilization) = $7.44
                                       7-83

-------
 Table 7-31.  ESTIMATED INVESTMENT FOR UNCONTROLLED WESTERN PROCESSING PLANT
                  (Capacity:   1,270,000 metric tons, per year)	
                                                     Thousands of dollars
                                                                            34
Beneficiation
Calciners - 3 54 tph Fluid Bed                       .
Grinders:
     1 91 tph Ball Mill
     2 14 tph Roller Mills
Pneumatic Transfer Systems
Storage Facilities
Miscellaneous Equipment
     Total Investment
Cost Per Metric Ton (80% capacity utilization) = $23.19
 4,012
14,347

   255
   766
                                         7-84

-------
            Table 7-32.   ESTIMATED OPERATING COSTS FOR UNCONTROLLED
                          WESTERN PROCESSING PLANT34
                  (Capacity:   1,270,000 metric tons per year)
                                       Basis
                               Thousands of dollars
Supplies:
   Power
   Fuel-Bunker C
   Water
Direct Operating Labor.
Maintenance Labor
Administrative Overhead
Maintenance Supplies
Local Taxes and
  Insurance
42.6 x 106 kWh @ $0.03/kWh
12.2 x 106 gal @ $0.28/gal
 800 x 106 gal @ $0.03/1,000 gal
   of Investment Per Year
2% of Investment Per Year
1,278
3,416
   24
  451
  261
  185
  471
Total Annual Operating Cost
Cost Per Metric Ton (80% capacity utilization) = $6.45
                                    7-85

-------
capital cost, (2) total annualized cost, and (3) annual total cost.  The
annual total costs are used in the economic impact analysis, while the annual-
ized costs are used to estimate inflationary impacts in section 7.5.  Control
option B is considered to be the most typical control system for the entire
model plant, since it includes wet scrubbers on the calciners and fabric
filters on the grinders.  Control option A, "using fabric filters on both
calciners and grinders, is comparable in cost to option B, while control
option C, requiring electrostatic precipitators, has the highest capital and
operating costs of the three options.
     Control option A, according to Table 7-33, would require a capital invest-
ment of $3,114,000 and an annualized cost of $0.90 per ton, regardless of the
control level.  At all control levels, option B would require a capital invest-
ment of around $2,125,000.  The annualized cost would range from $0.85 per ton
at the SIP level to $1.06 per ton at the most stringent NSPS level.   Finally,
the costs of control option C range from $3,056,000 for capital equipment and
an annualized cost of $1.17 per ton at the SIP level to $5,891,000 for capital
and $1.80 per ton in annualized costs at the most stringent NSPS level.
     The control costs for a modified plant are summarized in Table 7-34.   For
the purposes of this analysis, it is assumed that the calcining capacity of an
existing plant is increased by 33 percent by adding one 54 tph calciner;
grinding capacity is increased by 50 percent by adding four 14 tph roller
mills.  Again, the calciners and grinders of the existing plant would not be
affected by the NSPS, but would have to meet the current SIP standard.   The
new calciner and grinders, however, would have to meet the appropriate NSPS
level.  Once again, the control costs for the expanded portion of the plant
are added to those required to meet the SIP level in the existing plant to
calculate control costs for the entire facility.
                                      7-86

-------





















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       Under control option A, the annualized cost of controlling emissions from
  the new facilities would be $1.16 per metric ton for all control levels (see
  Table 7-34).   Meanwhile, the annualized cost range.for option B would be $1.09
  to $1.25 per  metric ton, while option C would range  from $1.33 to $1.95 per
  metric ton.   Incorporating these costs with the control  costs for the existing
  plant,  the annualized  costs  of reducing emissions  from the  entire plant would
  be $0.97 per  metric ton  for- option A,  $0.91 to  $0.95  per ton  for option B,  and
  $1.21  to $1.37 per ton for option C.   For  the entire  plant, the  capital  require-
  ments  for the alternative  control systems  would  be $4,622,000  for option A,
  $3,288,000  for option B, and from $4,456,000 to  $5,401,000 for option C.
  7.4.3.3   Economic  Impact on New Model  Plant--
      To  determine  the economic impact  of imposing the different NSPS control
  levels on the new Western model plant, the same analytical approach used for
 the new and modified Florida plants  was employed.  This analysis assumed an
 average selling price of $22.04 per  metric ton and an uncontrolled unit produc-
 tion cost of $13.89, which was  derived in section 7.4.3.1.   The control  costs
 were reported  in  section  7.4.3.2.
      The baseline IRR used  in this analysis was  calculated for a  plant that
 met the SIP level  of control  by employing option B  (scrubbers  on  the calciners
 and fabric filters  on the grinders).   As  Table 7-35 shows, the  rate of  return
 is  9.3  percent.
     Option A
           Table 7-35  shows  that the impacts on new plant economics are the
same at all control  levels.  Under full cost absorption, the return on invest-
ment would decline by 3.9 percent from the baseline rate of return.   Under
                                       7-91

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 full cost pass-through, producers would  have  to  increase  the  price  from  $22.04
 to $22.23 per metric ton, an  increase of 0.9  percent,  to  maintain the  return
 on investment at  its baseline  level.
     Option B
          Under full cost absorption, the rate of return  would decline by 4.3
 percent at the stringent level of control, by 1.8 percent at  the NSPS 2  level,
 and by 0.8 percent at the NSPS 3 level.  Under full cost  pass-through, the
 price would need  to rise by 1.0 percent  at the NSPS 1  level,  by 0.4 percent at
 the NSPS 2 level, and by 0.1 percent at  the NSPS 3 level  in order to maintain
 the return to capital at its baseline level.  Furthermore, employing option B
 to meet the NSPS  level of control would  have no effect on total plant capital
 per ton of product, since this option would be used to meet the SIP level of
 control.
     Option C
          Selection of this option to meet the NSPS control  levels would
 result in the most severe impacts on the plant economics.   Under full  cost
 absorption,  the decline in return on investment would range  from 22 percent
 (NSPS 1)  to 9 percent (NSPS 3).  Under full  cost pass-through, the price
 increase  needed to maintain the IRR would range from 5.2 percent (NSPS 1) to
1.9 percent (NSPS 3).
Summary
     From the preceding discussion,  it is concluded  that option A  (fabric
filters on calciners and grinders)  would be  selected  if the  stringent  level  of
control (NSPS 1)  were the standard.   Under the moderate levels of  control
(NSPS 2 and  NSPS  3), option B (wet  scrubbers  on  the calciners  and  fabric
                                      7-93

-------
filters on the grinders) would be chosen.  Under no circumstances would op-
tion C be chosen to comply with any of the control levels, because of the
significantly higher capital and annual costs associated with this option.
7.4.3.4  Economic Impact on Modified Model Plant--
     For the modified plant, it is assumed that the existing plant undergoes
expansion of its calcining capacity by 33 percent and its grinding capacity by
50 percent.  The control costs for this modified plant were presented in
section 7.4.3.2.  In order to conduct the impact analysis, the following
assumptions were made:  the rock sells for an average price of $22.04 per
metric ton; the existing plant operates at a cost of $15.28 per ton and was
built with a capital investment of $19.64 per ton; the new facilities of the
expanded plant operate at a cost of $18.51 per ton and could be built with a
capital investment of $43.65 per annual ton; and the entire expanded plant
operates at a cost of $16.09 per ton and could be constructed with a capital
outlay of $25.64 per annual ton, not including the cost of emission control.
The results of the analysis are presented in Table 7-36.  The baseline return
on investment of 7.8 percent was calculated for a plant that met the SIP level
of control using option B.
     Option A
          As Table 7-36 shows, the impacts on the rate of return and on price
are the same at all of the NSPS control  levels.  Under full cost absorption,
the decline in the return on investment  is 5.3 percent.  Under full cost
pass-through, Western producers would  have to raise the price from $22.04 to
$22.22, an increase of 0.8 percent, to maintain the return to capital at its
baseline level.
                                        7-94

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-------
     Option B


          The smallest impacts occur when wet scrubbers are used on the cal-

ciners and fabric filters are used on the grinders.  Under full cost absorp-

tion, the decline in the return on investment is 1.5, 0.5, and 0.3 percent at

the NSPS 1, NSPS 2, and NSPS 3 levels,, respectively.  Under full cost pass-

through, prices would have to rise by 0.9, 0.4, and 0.2 percent at the NSPS 1,

NSPS 2, and NSPS 3 levels of control, respectively.  Furthermore, there would

be no impact on total plant capital requirements at any of the control levels.


     Option C


          The most severe impacts would occur if electrostatic precipitators

were used on the calciners and fabric filters were used on the grinders.

Under full cost absorption, the decline in return on investment would range

from 15 percent (NSPS 1) to 10 percent (NSPS 3).  Under full cost pass-through,

the increase in price needed to maintain the return to capital would range

from 2.3 percent (NSPS 1) to 1.5 percent (NSPS  3).


Summary


     As the preceding analysis showed, option B would be  selected to comply

with all of the NSPS control levels.  The impacts on both rate of return and

price are  insignificant when this option is used.  Because of the signifi-

cantly higher capital and annual costs associated with option C, this option

would not  be selected in order to comply with any of the  NSPS levels.


7.4.4  Summary of  Economic Impacts on New and Modified Plants
                                                                 j

     Table 7-37 presents a summary of the control options that would be

selected to control  emissions from new and modified Florida and Western plants

to meet the various  NSPS control levels, based  on the analyses in Sections 7.4.2
                                          7-96

-------
 and 7.4.3.   Option B, which consists of wet scrubbers on the dryers or cal-
 ciners and fabric filters on the grinders, would be chosen for,all plants to
 meet the NSPS 2 and NSPS 3 levels of control;  it would be applied to the
 modified Florida and Western model  plants at all three control  levels.
 Option A,  which consists of fabric  filters on  the dryers,  calciners,  and
 grinders,  would be applied to the new Florida  and Western  plants  to meet the
 stringent  NSPS  control  level.
      Table  7-37 also summarizes  the  price increase associated with each
 selected option necessary to  maintain the return on  investment at  the baseline
 level.   All of  the required price increases  are  less  than. 0.9 percent.  All  of
 the  increases estimated  for the  Florida model plants  are under 0.2  percent.
      Implementation  of the NSPS  control levels would  not cause any  adverse
 economic impact on  the phosphate  rock  industry since  all plants would have to
 meet the SIP level of control in  the absence of  an NSPS.  The incremental cost
 of meeting the different NSPS levels is small enough that the profitability of
 the plants is not significantly affected.   Hence, new plant construction or
modification of existing plants would not be affected.
                                       7-97

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7.5  POTENTIAL SOCIOECONOMIC AND INFLATIONARY IMPACTS
     Executive Order 12044 requires that the inflationary impacts of major
legislative proposals, regulations, and rules be evaluated.   The proposed NSPS
would be considered a major action (thus requiring the preparation of an
Inflation Impact Statement) if either of the following criteria apply:
     (1)  Additional annualized costs of compliance, including capital charges
          (interest and depreciation), will total $100 million within any
          calendar year by the attainment date, if applicable, or within five
          years of implementation.
     (2)  Total additional cost of production is more than 5 percent of the
          selling price of the product.
     The NSPS for phosphate rock would not qualify as a major action by the
second criterion, since the largest price increase was estimated to be less
than 0.9 percent.  The remainder of this section is devoted to estimating the
total additional cost of compliance with the various NSPS control levels.
     As shown in Table 7-8 in section 7.1.7, the industry expects to add
21,138 metric tons of capacity in the Florida region and to add 4,263 metric
tons in the Western region.  Most of this expansion will occur by 1983.  The
remainder will be added sometime after 1983 (see the last column in Table 7-8).
To estimate the incremental cost of compliance for the industry, it was assumed
that all of the increases to existing capacity would occur in 1985.
     For each region, 'the planned total addition to capacity was apportioned
into two subtotals, additional capacity from new plants and additional capacity
from modifications to existing plants.  These subtotals were then divided by
the new model plant capacity and the increase in existing capacity of the
modified model plant, respectively.  In other words, the planned capacity
additions were transformed into "model plant equivalents."  Any fractions were
rounded up to the nearest whole plant.  Using this approach, it was estimated
                                     7-98

-------
that expansion in the Eastern region would occur by building seven new Florida
plants and by modifying four existing plants; in the Western region, four new
plants would be built and one plant would be modified.  The estimated compli-
ance costs were based on the options that would be selected and which were
presented in Table 7-37.  The results are given in Table 7-38.
     As Table 7-38 shows, the incremental cost of compliance with the NSPS 1
level of control is under $1 million, well below the threshold of $100 million
specified in-the Executive Order.  For the NSPS 2 and NSPS 3 control levels,
the maximum  total costs are estimated at $930 thousand and $408 thousand,
respectively.   Since neither the annualized  cost of compliance nor  the esti-
mated price  impacts of  the NSPS meet the criteria specified in the  Executive
Order,  the proposed NSPS  for the phosphate rock industry  is not a major action
and  thus  does  not require the preparation of an Inflation  Impact  Statement.
      No adverse socioeconomic impacts cf  the NSPS are anticipated.   Because
the  impacts  are insignificant,  the expansion planned  by  the industry should
not  be  affected.  Thus, there will be no  significant  effect on  regional employ-
ment and income.
                                         7-99

-------
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-------
              Table  7-38.   POTENTIAL  TOTAL  INCREMENTAL  COST  OF
                   COMPLIANCE WITH  NSPS  CONTROL  LEVELS,  1983
                            (Thousands of  dollars)
Control level
NSPS 1
NSPS 2
NSPS 3
Installed capital cost
8,408
0
0
Total a'nnuali zed
845
930
408
costb



aControl options on which these estimates are based are given in Table 7-37.
 Control costs are taken from Tables 7-26, 7-27,  7-33,  and 7-34.
bCosts calculated assuming that seven new plants  are built and four existing
 plants are modified in the Eastern (Florida) region and that four new plants
 are built and one plant is modified in the Western region.
                                      7-101

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                      REFERENCES FOR SECTION 7.1
 1.  Worlcf "Fertilizer Capacity Data:  National Fertilizer Development  Center,
     Tennessee Valley Authority,  Muscle Shoals, Alabama, May  1978.

 2.  Directory of Chemical Producers - U.S.A.  Stanford Research  Institute,
     Menlo Park, California, 1975.

 3.  Blue, T. A. and T. F. Torries.  Phosphate Rock, Chemical  Economics Hand-
     book, Stanford Research Institute, Menlo Park, California, December  1975,
     pp. 760.OOOOA-760.0010.

 4.  Chemical Profile - Phosphorus.  Chemical Marketing Reporter, 207(21):9,
     March 24, 1975.

 5.  Phosphate Rock - 1974.  Mineral Industry Surveys, U.S. Department of
     Interior, Bureau of Mines, Washington, D.C., March 19, 1975.

 6.  Sweeney, J. W. and R. N. Hasslacher.  The Phosphate Industry in the
     Southeastern United States and Its Relationship to World  Mineral  Ferti-
     lizer Demand, U.S. Department of the Interior, Bureau of  Mines, Washing-
     ton, D.C., Information Circular 8459, 1970, p. 32.

 7.  Stowasser, W. F.  Phosphate Rock, Preprint from Mineral Facts and Problems,
     1975 Edition, Bulletin 667, U.S.  Department of the Interior, Bureau of
     Mines, Washington, D.C., p. 6.

 8.  Stowasser, W.F.  Phosphate Rock, Preprint from 1973 Minerals Yearbook,
     U.S. Department of the Interior, Bureau of Mines, Washington, D.C., p. 6.

 9.  Stowasser, W.F.  Phosphate Rock, Preprint from 1973 Minerals Yearbook,
     U.S. Department of the Interior, Bureau of Mines, Washington, D.C., p. 7.

10.  Emigh, G. D.   Phosphate Rock,  Mining' Engineering, (24):48.  January
     1972.

11.  Stowasser, W. F.  Phosphate Rock, Preprint from Mineral Facts and Problems,
     1975 Edition, Bulletin 667, U.S.  Department of the Interior, Bureau of
     Mines, Washington, D.C., p. 8.

12.  Kessler, F.  Morocco Reaps Big Profits by Boosting Price  of a Scarce
     Fertilizer Ingredient, The Wall Street Journal, 184(125):18, December 26,
     1974.

13.  Eilertsen, D. E.  Phosphate Rock, Minerals Yearbook - 1968, U.S. Depart-
     ment of the Interior, Bureau of Mines, Washington, D.C.,  p. 923.

14.  Lewis, R. W.   Phosphate Rock, Minerals Yearbook - 1970, U.S.  Department
     of the Interior, Bureau of Mines, Washington, D.C., p.  927.

15.  Stowasser, W. F.  Phosphate Rock, Minerals Yearbook - 1972, U.S. Depart-
     ment of the Interior, Bureau of Mines, Washington, D.C.,  p. 1031.
                                       7-102

-------
 16.  The  Fertilizer  Institute.   Fertilizer Financial  Facts for the Calendar
     Year 1969, p. 1.

 17.  Fertilizer Financial  Picture  Brightens.   Chemical  and Engineering News,
     49(17):16, April 26,  1971.

 18.  Deyrup,  C. A.   Fertilizer  Supply  Shortage is  Limiting Factor in Effort to
     Increase Output of Grains,  Chemical  Marketing Reporter,  204(14):3,
     October  1, 1973.

 19.  Emigh, G. D.  Phosphate  Rock,  Mining Engineering,  (26):115,  February
     1974.

 20.  The  Fertilizer  Institute.   Fertilizer Financial  Facts for the Year Ended
     December 31,  1973, p.  1.

 21.  Fertilizer Sales Running High but Returns are Disappointing.   Chemical
     Marketing Reporter, 204(23):17, December 3,  1973.
                                          *
 22.  Price Hikes  Haven't Dampened  Fertilizer  Demand.   Chemical  Week,'114(5):
     21-22, January  30, 1974.

 23.  Phosphate Rock  Prices Rise as  World  Demand Increases,   Chemical  Marketing
     Reporter, 207(6):21,  February 10,  1975.

'24.  Emigh, G. D.  Phosphate  -  Fertilizer Boom Strains  World  Supplies,  Engineer-
     ing  and  Mining  Journal,  (176):146, March 1975.

 25.  In Full  Swing:  The Biggest Fertilizer Season to Date.   Chemical  Week,
  '   114(17):13,  April 24,  1974.

 26.  Nilsen,  J. M.   Fertilizer  Woes Multiply, Chemical  Engineering,  81(9):86,
     April  29, 1974.

 27.  The  Fertilizer  Institute.   Fertilizer Financial  Facts for the Year Ended
     June 30, 1974,  p. 1.

 28.  Boom in  Agrichemicals.   Business  Week, Number 2334,  June 8,  1974,  p.  53.

 29.  Shortage Now, Glut Later.   Chemical  Week, 113(1):6,  July 4,  1973.

 30.  U.S.  Farmers  are Buying  Less  Fertilizer.  Chemical Week, 117(15):34,
     October  8, 1975.

 31.  Stowasser, W. F.  U.S. Department of the Interior, Bureau of Mines,
     Washington,  D.C. to K. H.  Lloyd,  Standards Analysis  and  Strategies Divi-
     sion,  OAQPS,  Environmental  Protection Agency, Research Triangle  Park,
     N.C.,  January 21, 1976,  Personal  Communication.

 32.  Cole,  A.  Pedone Engineering,  Inc.,  Lakeland, Florida to K.  H.  Lloyd,
     Standards Analysis and Strategies Division, OAQPS, Environmental  Protec-
     tion Agency,  Research Triangle Park, N.C. , January 21, 1976,  Personal
     Communication.
                                      7-103

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 33.
 34.




 35.



 36.


 37.


 38.


 39.


 40.


 41.


42'.


43.
 Interim Report:   Estimation of Costs for Typical Florida Phosphate Opera-
 tion.   Arthur D.  Little, Inc., Cambridge, Mass., Prepared for Office of
 Air Quality Planning and Standards, Environmental Protection Agency
 Contract No.  68-02-1349, January 16, 1976.

 Interim Report #2.   Estimation of Costs for Typical Western Phosphate
 Operation.   Arthur D.  Little,  Inc., Cambridge, Mass., Prepared for Office
 of Air Quality Planning and Standards,  Environmental Protection Agency
 Contract No.  68-02-1349, January 23, 1976.

 Paul,  Duane A.,  Richard L.  Kilmer,  Marilyn  A.  Altobello, and David N.
 Harrington.   The  Changing U.S.  Fertilizer Industry, Agricultural  Economic
 Report No.  378,  Dept.  of Agriculture,  1977, pp.  100-102.

 Phosphate Rock-1977.   Mineral  Industry  Surveys,  U.S.  Department of the
 Interior,  Bureau  of Mines,  Washington,  D.C.,  March  15,  1978.

 Phosphates  Banned in Michigan.   Chemical  Marketing  Reporter,  October  10,
 1977,  p.  28.

 Marginal  Deposits Will  Satisfy Future Phosphate  Demand.   European  Chemical
 News,  February 25,  1977,  p.  22.

 Beker  Jolts Fertilizer  Trade.   Chemical Marketing Reporter,  June 13,
 •!•«? / / j  p •  / .

 Garbacz,  C. G.  Phosphate-U.S.  Rock Supply  Edges  Higher,  Engineering and
 Mining Journal, March 1978,  p.  79.

 Phosphate Growth  Paths  are  Cleared.  Chemical  Week, August 31,  1977 p.
 38.                                                          ...

 Survey of Mine and  Plant  Expansion:  Engineering  and  Mining Journal,
 January, 1978, p. 79.

 Stowasser, W. F.  U.S.   Department of the  Interior, Bureau of Mines,
Washington, D.C.  to A.   Keeler,  Research Triangle  Institute, Research
Triangle Park, N.C., May  3,  1979, Personal  Communication.
                                        7-104

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                      REFERENCES  FOR SECTION  7.2
 1.  Written communication from Lee L. Beck (Industrial Studies Branch,
     ESED) to Kenneth H. Lloyd {EAB, SASD).  October 29, 1974.
                                                            /
 2.  Section 114 response from H.W. Long, Jr. (Agrico'Chemical Company,
     Pierce, Florida) to Don R. Goodwin (U.S. EPA, OAQPS, ESED).
     May 15, 1975.

 3.  Section 114 response from J.F. Cochrane (J.R. Simplot Company,  Pocatello,
     Idaho) to Don R. Goodwin (U.S. EPA, OAQPS,  ESED).   May 27, 1975.

 4.  Section 114 response from J.R. Terry (W.R.  Grace and Company,
     Bartow, Florida) to Don R. Goodwin (U.S. EPA, OAQPS, ESED) April 16, 1975.

 5.  Written communication from M.J. Martinasek  (W.R. Grace and Company,
     Bartow, Florida) to William M. Vatavuk (U.S. EPA,  OAQPS,, SASD,  EAB).
     August 27, 1975.

 6.  Steenberg, L.R. Air Pollution Control Costs of Electrostatic Precipi-
     tators for Coal-FTred Utility Boilers.  The Industrial Gas Cleaning
     Institute (Stamford, Connecticut) EPA Contract No. 68-02-1473,  Task No.
     9. April 16, 1975.                                     •

 7.  Steenberg, L.R., Air Pollution Control Costs for Equipment in Phosphate
     Rock Plants.  The Industrial Gas Cleaning Institute (Stamford,  Connecticut)
     EPA Contract No. 68-02-1473, Task No. 6, October 30, 1975.

 8.  Written communication from Robert L. McCallister (Fisher-Klosterman,
     Inc.,Louisville, Kentucky) to.William M. Vatavuk (U.S. EPA, OAQPS,
     SASD, EAB).  October 28, 1975.

 9.  Guthrie, Kenneth M.  Process Plant Estimating Evaluation and Control.
     Craftsman Book Company of America (Los Angeles, California).1974.

10.  Process Plant Contraction Estimating Standards.  Volume 4, Division 100,
     Sections 280 and 650.Richardson Engineering Services, Inc. (SolanaTBeach,
     California).  1975.  '

11.  Vatavuk, W. M. and  L. Theodore.  A Comprehensive Technique for  Calculating
     Particulate Control Device Efficiencies Utilizing  Particle Size Distribu-
     tions.  Proceedings of the Second National  Conference on Energy and the
     Environment.American Institute of Chemical  Engineers (Dayton  and Ohio
     Valley Sections, Dayton, Ohio).  November 13-15, 1974.

12.  Chemical Engineering.  Economic Indicators.  May 8, 1978.
                                   7-105

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13.  Kinkley, M.L. and R.B. Neveril. Capital and Operating Costs of Selected
     Air Pollution Control.Systems.  'GM
     Contract No. 68-02-2072. May 1976.
Inc. (Ni]es, Illinois).  tPA
14.  Written communication from Larry G. Jones (SOB, ESED) to Gene U. Smith
     (SOB, ESED).  April 26, 1978.

15.  Written communication from L. E. Sparks (PATB, IERL) to Lee L. Beck
     (ISB, ESED, OAQPS).  April 12, 1977.

16.  Written communication from Lee L. Beck (ISB, ESED) to William M. Vatavuk
     EAB, SASD).  May 30, 1978.

17.  Written communication from William M. Vatavuk (U.S. EPA, OAQPS, SASD,
     EAB, Research Triangle Park, N.C.) to William Hunter (Air Resources,
     Inc., Palatine, Illinois).  May 25, 1978.

18.  Written communication from George DeNobile (Marketing Department,
     Merrick Scale Manufacturing Company) to George Richard (Environ-
     mental Engineering Division of TRW, Inc.)  May 01,  1979.

19.  Telephone communication between George Richard (TRW Environmental
     Engineering Division) and Jerry Mead (plant superintendant, Simplot
     Company) May 31, 1979, and between George Richard and Douglas Mercer
     (Environmental Control Supervisor, Texas Gulf Inc.), May 23, 1979.
                                  7-106

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                    RATIONALE FOR THE PROPOSED STANDARD
                             »
8.1  SELECTION OF SOURCE FOR CONTROL

     The United States is the largest producer and consumer of phosphate
rock in the world, producing an estimated 40 percent and consuming approxi-
mately 35 percent of the world's supply.  Total U. S. production of market-
able (beneficiated) phosphate rock in 1976 was about 50 million short tons,
about eighty percent of which was from Florida.1  About 70 percent of domestic
consumption of phosphate rock is as fertilizer.  The other major uses are in
animal feeds, detergents, electroplating and polishing of metals, insecticides
and medicines.
     Demand for phosphate rock in the years 1985 and 2000, respectively,
is projected to be 45 and 69 million tons for the United States and 162
and 387 million tons for the rest of the world.2
     Phosphate rock deposits are found in 23 states.  Florida, the leading
producer for many years, furnished 80 percent of domestic production in 1976,
with the remaining production occurring in Tennessee, North Carolina, and the
western states.3
     Figure 3.1, Chapter 3,  shows the distribution of phosphate rock mines.
In 1975, these mines ranged  in size from 120,000 to 4.4 million tons per
year and are located in urban, suburban and rural areas.  From 1959 to 1973,
the production of phosphate  rock increased at an annual rate of about
                                   8-1

-------
6 percent, and  1s expected  to  increase  at  a  ratTe  of about 3  percent through
              4
the year  2000.
     The  Industry presents  a significant potential  contribution  to air
pollution due to large volumes  of material  handled.   Any step in  which  the
phosphate rock  is handled in the dry state  presents  a potential  for emission
of particulate  matter.  Many of the processes employed in preparation of the
rock; drying, calcining, grinding and pneumatic materials transfer, use
large volumes of air which, at the process  exhaust,  contain suspended par-
tidklates.  The environmental effects of particulate emissions have been
Investigated by the Environmental Protection Agency (EPA) and have been
                                                                     5
determined to pose a significant threat to public health and welfare,.
      Section 111  of the Clean Air Act of 1970 extends authority to EPA to
 regulate emissions by developing standards of performance for new stationary
                                  »
 sources based on  the degree of emission limitation achievable through appli-
 cation of the best systems of emission reduction.  Section lll(b), which
 allows EPA to limit emissions of pollutants for which air quality criteria
 have been prescribed, is appropriate for the phosphate rock industry, a
 major source., of particulates.  In a study performed by the Argonne National
 Laboratory, for EPA in April 1975, phosphate rock grinders ranked fifteenth
•of 56 of the Nation's  largest  particulate source categories.   This same study
 concluded that setting standards  of performance in 1975 would prevent the
                                  8-2

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emission of 10,500 tons  of participate per year by  1985  and,  on  that  basis,
the source was ranked 24 out of 107 candidates  for  standards  of  performance.   In
another part of the study,  phosphate  rock dryers was  ranked  fourth
highest of eighteen parti oil ate source categories  which require control
systems with moderate energy consumption.  The study  showed  that setting
standards of performance  for dryers in 1975 would  prevent the emission
of 3,800 tons of  particulate per year by  1985.
     The above characteristics of  the industry, high  growth  rate, significant
emissions and availability  of  control  technology, underscore  the need for stan-
dards of performance.  The  decision to develop standards of performance now
rather  than to postpone them for several years was influenced by  EPA's recent
regulatory activity tn thts  industry.  Standards of performance for the high
growth  fertilizer processes  were promulgated on 6 August 1975.  Effluent water
standards  for the industry  were promulgated on 8 April 1974 and amended on
6  August 1975 for the mining and beneficiation processes.  The phosphate rock
production and fertilizer production  segments  of the  industry are interdepen-
dent and  it is difficult  to consider  one  segment while ignoring the other/  As
a  result,  EPA engineers developed  a level  of expertise in the rock processing
operattons while  studying the  fertilizer  operations.  Similarly, the industry has
developed  a working  knowledge  of regulatory proceedings  prescribed by the
Clean Air Act.  The  expertise  developed by these two  factions would be
diminished if standards  development were  postponed.   Also, since any increase
                                   8-3

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 1n phosphate rock mining  will  result in increased fertilizer production
 and visa versa,  new sources  in one area will  ultimately result in new
 sources  in  the other.   The industry should know what emission control
 measures will be expected in all  areas  of production, allowing them to plan
 costs more  accurately  and have some degree of confidence in  the level  of
 emission control  that  will be  expected  by regulatory 'authorities.

 8.2  SELECTION OF POLLUTANTS AND  AFFECTED FACILITIES
      Operations  which  are considered as affected facilities  are drying,
 calcining,  ground rock handling and storage,  and grinding.   The bases  for
 selection of these processing  steps are 1) significant increase in future
 growth,  2}  significant potential  for emissions, and  3)  availability of
 technology  to insure significant  reduction of emissions.  Each  operation
 will be  discussed separately.
     Drying is chosen  as  an  affected  facility largely becojse of  the impor-
 tance of this operation in preparing  Florida  rock  for fertilizer manufacture.
 About 96 percent  of  the rock produced in  Florida is dried.  Dryers  are also
 used to  some extent  in the other  processing areas, usually for processing
 rock destined for shipping or manufacture  of  fertilizers.  Since the .future
 growth of fertilizer industries (estimated at  3 percent per year) is dependent
 on supplies of rock, 1t is likely that demand for additional  dryers will
 parallel demand, for additional  fertilizer.  Drying presents  a potential •
 for emission of partlculate matter because of attrition of the rock in the
dryer and the large volume  of air which sweeps through the  dryer and must
be vented to the  atmosphere.   The  magnitude of the potential  for emissions can
                                  8-4

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be estimated by considering a typical  rock dryer, processing 250 tons
of rock per hour, discharging 85,000 scfm.  The average loading of
particulate' matter in the air stream is about 2 grains per standard
cubic foot.  The potential annual emission for such a dryer is about 5700 tons
of particulate matter,  assuming  90  percent operating factor and no control
of emissions.  As detailed in Chapter 4, technology is available to
insure significant reduction in these emissions.
     The potential emission of gaseous .fluorides from rock dryers is
not significant.  This observation is supported by the experience of
                                             7   •
Tennessee  Valley Authority (TVA) researchers.-  In their experiments
to determine the temperature at which fluorine volatilization begins,
TVA heated phosphate rock samples to 932eF, 11120F, 1292°F;, 1472°F, and
1742°F for 30 minutes each..  Chemical analyses of samples before and
after heating showed fluorine volatilization only in the sample which
was heated to 1742°F.  Seven percent of the fluorine in that sample .
was volatilized.  The lack of a fluorine emission problem is also
evidenced by a study done by the  Battelle Memorial Institute in a study
                                        p
of the fertilizer industry  done for EPA  and (negatively) by the
absence of any existing legal restriction on fluoride emission from
phosphate  rock dryers.  For these reasons, rock drying is not a candidate
for standards of performance governing fluoride emissions.
     Calcining is also selected as an affected facility for emissions of
particulates.  The potential growth of this operation is substantial,
                           i
since any  new fertilizer installation processing North Carolina or Western
phosphate  rock will require a calciner.  These two areas of the phosphate
industry are likely to expand since the reserves in both locations are
extensive  and are not as yet developed to their potential. As a source of
                                 8-5

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emission of participate matter, a typical calciner processes 50 tons
of rock per hour (tph), exhausting 45,000 dscfm  of gases  with  a  participate
loading of 2 grains per standard cubic foot.  The potential annual
emissions rate for such a calciner is about 3,000 tons, assuming a 90
percent operating factor and no emission control.  Technology  is avail-
able to permit significant reduction  in  the uncontrolled  emissions  rate.
     Data on gaseous  fluoride  emissions  from  calciners  are contradicting.
Two reports9*10  indicate that  the  temperature of calcination  is  insufficient
to drive off gaseous  fluorides.  However,  one operator  reports finding
0.002  pounds of  gaseous fluorides  in  his calciner exhaust per ton  of
 rock processed by his calciner.    This  level  appears relatively minor con-
 sidering  that  fluorides emission standards for the related phosphate fertilizer
 Industry  permit  a range of 0.01  to 0.2  Ib/ton of phosphorous pertoxide (P205)
 feed for units of comparable capacity to phosphate  rock calciners.
      A fluoride standard is not recommended  for calciners because  emissions
 of gaseous fluorides from calciners  is  believed to  be very small,  if indeed
 present at all.  Moreover, the recommended particulate  standard  will  result
 tn significant reduction of emissions of particulate fluorides.  Also, a
 standard for fluorides would discourage the use of dry collection  devices,
 such as fabric filters, in favor of scrubbers.  Fabric filters are generally
 recognized as being  superior to scrubbers for control of particulate^missions,
 and have no water pollution potential.
       011-fired dryers and calciners also have a potential for emitting
 sulfur oxides when high sulfur residual fuel oils are burned.  However,
 phosphate rock  typically contains about 55 percent CaO which tends to
 react with the sulfur oxides, reducing emissions of this pollutant in the
 off-gases.  Though data on sulfur oxide emissions from phosphate rock dryers
                                   8-6

-------
 and calciners are sketchy, one operator of a phosphate rock calciner reports
 only 0.04  to 0.08 parts per minion  (ppm) S02  in exhaust gases when
                                                    1 ?
 burning  No. 6 fuel  oil containing  3  percent sulfur.   -With  no removal
 of S02 in  the calciner, S02 in the exhaust  gases would be  about 1,000 ppm
 Indicating an S02 removal efficiency of greater than  99 percent.  At
 least one  patent has been obtained for a system using phosphate rock as
 a  scrubbing medium  for sulfur oxides.     A  standard  for emissions  sulfur
.oxides   is not recommended for phosphate rock dryers or Ceilciners.
     The grinding operation.is selected as an affected facility for
particulate emissions.  Projected growth of the grinding operations can
be expected to parallel the'growth of fertilizer production.  The potential
for contribution to air pollution is substantial; a typical milling instal-
lation grinds 50 tons of rock per hour, exhausting 5,400 scfm of gases
with a particulate loading of 2 grains per standard cubic foot before
emission control.  The annual emissions potential for such a unit is about
300 tons per year, assuming 90 percent operating factor and no attempt at
emission control.  Technology is available for significant reduction of
this potential emission.

     It should be noted at this point that considerable advances have
recently been made In wet grinding.   If this procedure is adopted, air pol-
lution in the Florida segment of the industry could be drastically reduced
since the rock drying step could be eliminated,  and wet grinding presents
no air pollution potential.

                                  8-7

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     The final process which  is  selected  as  an  affected  facility is
ground rock  handling  and  storage.  The'growth potential  of these operations
1s of course substantial,  since  any  new installation will  handle and/or
store ground rock.  The emissions  potential  for these  operations is  very
difficult to quantify, since  systems  for  the handling  and  storage of rock
are highly individualistic and often  complex, reflecting the  plant
operator's judgement  as to what  is most suitable for the particular
installation.  As a result, there  is  no system  which can be called typical.
However, there are available  methods  of conveying,  storing, crushing,  and
        r
size-classification which would  insure significant  reduction  of fugitive
emissions.   As noted  in Chapter  3, certain types of equipment (screw con-
veyors, pneumatic systems, etc.) are  common.
     Mining, beneficiation, thermal defluorination, elemental  phosphorus
production and nodulizing  are not selected as affected facilities.  The
deposits in  Florida, North  Carolina, and Tennessee are of such a
character as to pose little air pollution threat in the mining step,  in
that they are located in moist earth.  Mining operations at Western
deposits located in arid country can be dusty.   However, these operations
account for only about 2 percent of the nation's production and are in very
rural  locations.   A program to develop standards specific to this small
portion of the industry is not warranted.   Beneficiation presents no  s'igni-
                                                                     s»
ficant potential  for air pollution-since the  operations involve slurries
of rock in water.   Thermal defluorination,.elemental phosphorus production,
and nodulizing are not selected as  affected  facilities  because they fail
to meet the criterion  of significant growth potential.14   Operators
interviewed generally  concurred in  the opinion that  substantial increase
in production capacity was unlikely in the foreseeable future.
                                8-8

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 8.3  SELECTION OF THE BEST SYSTEM OF CONTINUOUS EMISSIONS REDUCTION
 CONSIDERING COST
                                  4
      The control  options  for each of the affected sources are summarized in
 Table 8-1.   While the efficiency of fabric filter collectors  is relatively
 unaffected  by  the size distribution of the particles,  particle size affects
 the performance of scrubbers and ESPs  substantially, especially for fine
 particles such  as those emitted  by  phosphate  rock plant  facilities.  The
 fabric  filter  is  capable  of removing at least 99  percent of particulate  emis-
 sions from  dryers and calciners  while  the  low energy scrubbers  typically
 used  throughout the  industry are capable of an  efficiency between about  94
 and 97  percent.   However, with proper,  design,  both the scrubber and the  ESP
 are capable  of  achieving  the high efficiencies  attained  by the  fabric filter.
 This  is  accomplished  by designing the  scrubbers for high  energy and liquid/
 gas ratios,  and designing the ESPs  for high area/gas volume ratios. .
      Baghouses  are not currently used  to control  emissions from phosphate
 rock  dryers and calciners.   The  industry is concerned  that baghouses  may
 blind or be overheated when treating the hot,  moist stack gases from dryers
 and calciners.  However,  EPA's analysis shows  that, these problems are resolv-
 able, and that  there  are  no apparent technical  problems  which would preclude
 the use of  baghouses  for  control  of dryer  or  calciner emissions.  The 1974
 EPA study,  Control of Particulate Emissions from  Phosphate Rock  Dryers,  by
 A.  Lindsey and  R. Segars, outlines  examples of baghouse  installations utilizr
 ed  in applications similar  to the phosphate rock dryers and calciners.  The
 problem of moisture condensation has been resolved in other industries by
maintaining sufficient temperature difference between wet and  dry bulb
temperature control relative humidity.   The problem of overheating is avoid-
ed by maintaining  exhaust  gas temperatures in  the  acceptable temperature
range of the bag fabrics.   Other factors, such as  acidity of the gas stream,

-------
             Table 8-1   AFFECTED FACILITIES AND CONTROL  OPTIONS
                  Affected Facilities
              1.  Dryers

              2.  Calcfners

              .3.  Grinders
              4. Ground rock'handling and
                   storage
         Control Options
a) Baghouse
b) Het electrostatic predpftator
c) Scrubber
«) Baghouse
b) Het electrostatic preclpltator
c) Scrubber
a)'Baghouse
51 Ket electrostatic preclpltator
e) Scrubber
a) dosed 'conveyors and silos vented
   to scrubber
b) Closed conveyors and silos vented
   to baghouse
c) Closed conveyors and silos vented
   to electrostatic predpltator
adsorption, adhesion and  electrostatic properties of the particles  which could
adversely affect the performance of a baghouse can generally be  solved by pro-
per  selection of the fabric for the bag.
     The  cost of the alternative control  systems  depends on the  performance
and the associated design of the system.   Tables  8-2 through 8-4 summarize
the costs of the control options at various collection efficiencies,  ranging
from the  high efficiency achieved by the fabric filter, high energy
scrubber  and high efficiency ESP to the lower  efficiencies attained by the
low energy scrubber and ESP.  These costs were derived from information
presented in Tables 7-15, 7-13, and 7-19 respectively, for dryers,  calciners
and grinders.  The reader is referred to the discussion of Chapter  7.2 for
detail of the parameters considered when developing the cost data.
     The  installation costs for a scrubber are consistently lower than
the other two control systems for each of the  processes considered.   Wet
electrostatic precipitators are the most expensive device to install, and
                                      8-10

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baghouses consistently have medium installation costs.  When considering
the total annualized costs, however, fabric filters become the least
expensive and wet electrostatic precipitators the most expensive.

     Based on the average June 1975 selling price of $18.00/ton  for
phosphate rock, the industry would experience additional (above those
incurred under the SIP regulations) dryer costs amounting to about 0.4
percent of the product price when high energy scrubbers are used to
achieve emission control equal to that attained by the baghouse.  Simi-
larly, the annualized cost of calciners would increase by 1.2 percent
of the product price to attain baghouse control efficiency.  If the
industry chooses baghouses to control emissions, the additional control
costs for the dryer and calciner would be 0.1 and 0.3 percent of the
product price, respectively.  Utilization of electrostatic precipitators
would create additional control costs for the dryer and calciner of 2.2
and 5.3 percent of the product price, respectively.  For grinders, the
lowest annualized emission control costs are attained when the bag-
house (the prevailing system used to meet existing SIP regulations) is
employed.
     If baghouses or scrubbers are utilized, none of the levels of control
discussed in this chapter will cause a significant impact on the profit-
ability of a typical new or modified phosphate rock plant.  However, the
Impact on profitability of the plant would be significant  if the more
costly electrostatic precipitators were employed.  It is estimated that
Installation and operation of high efficiency electrostatic precipitators
would require product price increases of 1.9 and 5.2 percent to maintain
return on investment expected from an SlP-controlled new Florida plant and
                                   8-14

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 new western plant,  respectively.   By contrast,  meeting more stringent con-
 trol  standards  by utilization  of  high energy scrubbers would require product
 price increases of 0.3 and 1.0 percent  to  maintain  return  on investment
 expected  from an SIP  controlled new  Florida  plant and  new  western  plant,
 respectively.   The  additional  cost of meeting more  stringent standards
 using baghouses would be  negligible.   See  Chapter 7 for more detail  on  the
 economic  impacts of the levels of control  considered in this document:

      The  environmental impacts are least when using fabric  filters to
 control emissions from phosphate  rock dryers, calciners, grinders and
 ground rock  transfer  systems.  This  is  because aqueous  effluents are non-
 existent  and  energy requirements  are minimal  for fabric filters.  Discharge
 of  solid  wastes,  including radiochemical pollutants, is also  least when
 using  fabric  filters  because the  particulate collected  can often be returned
 to  product  inventories.   However,  the increase (over prevailing controls) of
 solid  materials  and wastewaters produced while achieving compliance using
 scrubbers on wet ESPs is  insignificant  in comparison with 1)  the large
 volumes of  process wastes, and 2)  the total wastes  already collected by
 prevailing  controls to meet existing state regulations.
     After evaluation of  all cost and environmental  impacts, a fabric filtration
 system or a high energy venturi scrubber was determined to be the best techno-
 logical system of continuous emission reduction  for each of the affected facili-
 ties discussed  in this, document.   However,  the high efficiency electrostatic
 precipitator  (ESP) is judged to be equally as effective as the baghouse or high
energy scrubber  in terms of emissions reduction  capability.  The proposed stand-
 ards may, therefore, be based on the use of any  of the three alternative controls,
 Cost considerations  would favor the use of the baghouse or high energy scrubber
 over the ESP, and the incremental  nonair quality adverse impacts associated with
                                   8-15

-------
the alternative controls may marginally favor the use of the baghouse over
the scrubber and ESP.  Finally, the experience of the industry in using '
scrubbers extensively to control emissions from dryers and calciners would
favor the use of scrubbers at future installations to minimize technical
uncertainties associated with equipment installation and.operation.
     Declaration of the fabric filter or the high energy scrubber as the
best system of emission reduction does not preclude the use of other sys-
tems which might also meet a proposed standard.  The operator may select
for use any other system of equal emissions reduction capability and which
is also environmentally acceptable.  This would include any of the three
options discussed here.  However, due to cost considerations, it is not
expected that the ESP would be utilized at any of the affected facilities.
The industry historically prefers to use the wet scrubber to control dryer
and calciner emissions, and the baghouse for grinders.  This trend would be
expected to continue under the proposed standards, although use of high
energy scrubbers would be a more costly alternative for achieving compli-
ance in most situations.
8.4  SELECTION OF THE FORMAT
     In accordance with the language of Section 111 of the Clean Air Act,
the standard must reflect the degree of emissions limitation attainable
by the best system of emissions  reduction.  Theoretically, the para-
meter which best expresses the degree of emission limitations attain-
able is control efficiency.  Since control efficiency is a function of
particle size, the standard could be posed as a specified removal effi-
ciency requirement for  various particle size ranges in the exhaust stream.
The imposition of control efficiency is equitable in the sense that all
operators must provide  equivalent degrees of removal regardless of the
uncontrolled  emission rates.   Implementation would require costly and
cumbersome performance  test requirements, including measurement of quan-

-------
tity and size of particulates entering and leaving the control device  to
assure compliance.  Moreover, a format utilizing control efficiency as the
enforceable element of the regulation would require a demonstration that
the mandated levels of control are achievable with the best system of
emissions reduction.  While there is ample data for estimating the efficiency
of the various alternative control methods, only limited test data is avail-
able to validate definitely the attainable efficiencies in phosphate rock
applications.   Predictions for the efficiencies have been included in this
document for purposes of estimating air quality impacts only.   These pre-
dictions were  made using particle size distribution data and mathematical
performance models or fractional  efficiency data for the various  alternative
controls,  and  do not constitute a sufficient  basis  for the  development  of a
control  efficiency standard.

     •Another  direct means  of  regulating  control technology  involves the
 operating  and  design  standard.  This  format consists  of specifications for
 equipment  and  operating  procedures consistent with the best system of
 emissions  reduction.  Compliance with the operating and design standards
would be assured by  periodic  on-site  inspection to ascertain that equip-
ment is being utilized in the prescribed manner.  The equipment standard
was not considered as a  candidate format because of provisions in the
Act which favor application of emissions limits when  feasible to
prescribe and enforce.   Moreover, there are significant drawbacks in the
application of the equipment standard.  First, the equipment standard is
overly restrictive 1n that it discourages the use of alternative control
designs and the development of improved control technologies.   Second,  the
equipment standard 1s generally difficult to prescribe and implement.
     The  two  most  frequently  employed options  for  use as the format of
 a particulate  standard  are a  concentration standard or a mass per unit
                                  8-17

-------
 of feed standard.  For either format, the standard limit depends
on the  level of emissions which are to be controlled.  For example, a bag-
house operating at 99.5% efficiency will attain a control limit of  .01
gr/dscf for a  2 gr/dscf emissions loading, while a control limit of .02
gr/dscf would  be  possible for a stream emitting 4 gr/dscf.  This is unlike
^the formats involving efficiency and equipment specifications,  which  are
 determined independent of the particulate loading  of the uncontrolled emis-
 sions stream.   Thus, for the concentration or process weight  standard, there
 is some question  concerning the definition of the  emissions stream  needing
 control.   Should  the emissions  limitation achievable by  best  technology be
 determined for an "average", representative, typical  or  worst case  emission
 stream?  To assure that all industry can meet the  standard, it  would  be
 necessary to base the standard  on the most adverse emissions  control  problem
 which occurs.   However, if the  emissions stream is  highly variable  in nature
 and pollutant emissions,  the latter standard could be met at  many sources by
 application of less than "best" technology.   Such  a result would not  seem
 to be consistent with the apparent intention of Section  111  of  the  Clean
 Air Act.  One means of mitigating this problem is  to establish  separate
 emissions limits  for distinguishable source sub-categories emitting
 pollutant levels.  For example, the emission standards for boilers  are
 specified in terms of fuel type utilized (coal, oil, and gas).

      A logical subcatagorization scheme for emission sources  in the phos-
 phate rock industry would be based on distinguishable feed ores.  Although
 emissions concentrations and mass per unit feed rates are known to  vary
 substantially for grinders, dryers and calciners depending on the type of
 feed (e.g., pebble rock is known to produce  greater emissions than  other
 benefielated ores during drying ), it is not clear if separate  standards
                                   8-18

-------
 should be developed for the various categories of ore feeds.  A major
 problem concerning this approach is the fact that other differences in  the
 ore  (e.g., moisture content, clay content) also affect the emission rate
 significantly.  The actual significance of the various ore characteristics
 on emissions levels is not specifically known.  In addition, the cate-
 gorization of ore feeds is further complicated by the fact that operators
 frequently blend different ore types as they are introduced to the various
 plant processes.  Therefore, it would not appear feasible to establish
 separate emissions standards for ore feed categories at this time.  Conse-
 quently, the emissions standard should reflect the level of control
 attainable for representative conditions producing the greatest emission
 levels.

      the next issue in the format development is whether the emission limita-
 tion  achieved by the best system of emissions reduction  (for the character-
 ized  emission stream) is best reflected by a concentration or mass'per unit
 feed  format.  EitheV format may be used with the same control result if  the
 two units are related consistently to each other.  Figures 8-1 to 8-3 show
 there is no consistent relation for dryers, calciners, and grinders.  That
 is, compliance with a concentration standard does not guarantee compliance
with a particular level  of mass emissions, or vice versa.  Thus,  either the
concentration format or the mass emissions per unit feed format must be chosen
as the best representation of the system attaining  maximum  emissions  re-
duction.   The-advantages of the mass  emissions  standard  are >as  follows:
      1.   The mass emissions format is  consistent with existing applicable
          state  standards.
                 *                                               •
      2.   The mass-emissions format  relates directly to  the  total quantity
          of emissions discharged  to  the atmosphere.
                    \  •                                    .
      3.   The mass  emissions format  is more equitable.  The degree of
          emissions permitted are  related  to the amount of product processed.
                                   8-19

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    4.  The  mass  emissions format does not discourage use of controls or
        exhaust gas systems which affect exhaust gas volume (e.g., a more
        efficient burning of fuels for heat in the calciner at lower air
        flows).   Thus this format would permit the concentration of the
        exhaust gas stream to Increase, while the system would remain in
        compliance in terms of total emissions per unit of useful product.
    5.  This  format ensures that the standard is not circumvented by
        dilution, or that the standard is not achieved merely because of
        high  volume flow in the exhaust design.  Attainment of the
        standard  is not dependent on the exhaust system but on the over-
        all  control of  emissions generated by the process.

    The advantages associated with the concentration standard are generally
related to practical considerations:
     1.  The concentration  standard is more easily enforced since
        compliance  is more  easily verified.
     2.  The concentration  standard avoids judgments of equity in defining
         feed rate or  process weight.  By  contrast, mass emissions standards
         involve issues  such as  1) whether the process weight should be
         expressed in  terms  of  feed  rate or  rate of useful product produced
         and 2) whether the quality  of the product should  affect  the
         allowable emissions limits.

     Based on a comparison of advantages of  the  alternative formats, it
has been determined by EPA that the  mass  per unit  feed  format is  the more
equitable and logical  approach  for the  standard  development.  The process
weight  format is  appropriate for dryers,  caldners and  grinders.  However,
a mass  emissions  or concentration format is  not  appropriate  for  ground
                                  8-23

-------
rock handling systems because: 1) emissions from these systems vary
                                  v
greatly due to appreciable differences in design from plant to plant,
and 2) a substantial portion of the potential emissions from ground rock
handling systems are fugitive emissions and cannot feasibly be measured.
Therefore, a visible emission standard is the only format appropriate to
material handling facilities.

8.5  SELECTION OF EMISSIONS LIMITS
     The proposed emission limits are based on the emissions levels attain-
able by application of the best demonstrated system of emission reduction,
considering costs,  and environmental, economic and energy impacts.  This
system may be defined as either the  fabric filter or the high energy venturi
scrubber.  However, the high efficiency electrostatic precipitator is judged
to  be equally effective in terms of  emissions reduction capability.  The
proposed emissions  limits may, therefore, be based on the use of any of the
three alternative controls.
      In selecting emission limits it is important to recognize that the
levels of control achievable by the  control alternatives discussed in
Chapters 6 and  7 are not to be interpreted as recommended emission standard
 limits.   Rather,  these  control levels were established as  representative
 emissions  levels  achievable  by alternative control  systems  operating on
typical  uncontrolled  process emissions  streams.  These  levels were
 selected for the purpose  of estimating environmental and cost impacts
 which would occur if they were attained  as control  targets.   The  levels
 are in the neighborhood of that  expected  if  the alternative systems would
 be used and may,  therefore,  be considered somewhat  representative  of the
 different control  systems in the assessments.   The  specific determination
                                   8-24

-------
of an appropriate standard is based primarily on source test data.  The
impact of this standard may be determined by relating the control level of
the standard with the appropriate impact analysis of the alternative control
systems in Chapters 6 and 7.  The emission limits proposed for each of the
sources (dryers, calciners, grinders, material handling equipment) are
discussed below.
8.5.1   DRYERS
     Particulate emissions were measured from a rotary bed and fluid bed
dryer at two phosphate rock plants.  Each of the dryers was used to process
Florida pebble rock.  The pebble rock is considered to present the most ad-
verse conditions for control of emissions from dryers because it receives
relatively little washing and enters the dryer containing a substantial per-
centage of clay.  Based on previous discussion, both types of dryers, the
rotary and the fluid bed, are considered to generate equivalent emissions
levels.
     At Facility A, an oil-fired rotary dryer processes from 220 to 440 TP.H
of phosphate rock, depending on the moisture content and type of rock
processed.  The dryer was tested during normal operation using EPA Method
5.  In one series of tests conducted by EPA, only Florida pebble rock was
dried.  In another set of tests conducted by the operator, pebble rock
was processed in the first operator test and flotation cell concentrates
were tested during the second test.  The dryer emissions iare treated by
a  venturi scrubber operating at a pressure drop of 18 inches of water.

     Results  of  the  tests of Facility A are shown in Figure 8-4.  Emissions
from the  venturi  scrubber averaged  .039 Ib/ton and  .038  Ib/ton for the EPA
                                   8-25

-------

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Figure 8-4.  Partlculate Emissions from Well-
       Controlled Phosphate Rock Dryers.
          ,j
                     8-26

-------
and operator tests, respectively.   Individual  test sample results ranged
from 0.034 to 0.47 Ib/ton.  '
     At Facility B, an oil-fired rotary dryer and an oil-fired fluid bed
dryer are operated in parallel  to  dry Florida pebble rock at an average
production rate of 330 TPH and 165 TPH, respectively.  Emissions from each
dryer are partially controlled by  a separate impingement scrubber.  Emis-
sions from the scrubber are combined and treated by a two-stage wet electro-
static precipitator (ESP).  The ESP, which presently operates at a plate
                                        2
area to gas volume ratio of about  400 ft /1000 ACFM, was designed to treat
approximately twice the volume of  air which is actually processed.  EPA
measured emissions from the ESP using EPA Method 5 while the operator mea-
sured emissions employing the Florida Department of Pollution Control  Method,
     The results of the tests of Facility B are shown in Figure 8-4.  Emis-
sions from the ESP averaged .025 Ib/ton and .054 Ib/ton for the EPA and
operator tests.  Individual test sample results ranged from .014 to .10
Ib/ton.
     The test results  (Facility A) show that the venturi-scrubber is  cap-
able of achieving emission levels  of .039 Ib/ton from phosphate rock dryers
emitting high loadings of particulate matter comprised of relatively fine
particles.  The high efficiency ESP and scrubber system (Facility B) demon-
strated even lower emission levels during tests conducted by the EPA (.025
Ib/ton).  At Facility A, test results19 revealed the scrubber achieved 99.2%
efficiency.
     It is estimated that a baghouse control  device could achieve 99.4%
efficiency when treating the same emissions loading and particle size dis-
                                    8-27

-------
 tribution.13'   The additional  degree of control  to achieve the same perfor-
 mance (99.4%)  as a baghouse can be attained by a scrubber by increasing its
 energy input.   The actual  energy needed to achieve a given emissions  level
 will  vary depending on the characteristics of the emissions stream.   At
 Facility  A,  where the emissions are considered representative  of the  most
 adverse contr'ol  problem'in the industry,  it is estimated  (based  on  an empir-
 ically calibrated mathematical  model  of venturi  scrubber  performance)16 that
 increasing the  scrubber pressure drop to  25 inches  of water would achieve
 control equivalent to a baghouse,  resulting in -a  reduction  of  emissions
 levels by about  20 percent below that measured.   Therefore,  it is EPA's
 judgement that an  emissions  limit  of  0.04  Ib/ton  reflects  the  emissions
 level  attainable by  the best system of emissions  reduction  (either a  high
 energy scrubber  or a  baghouse),  and that these technologies  are  available
 and may be applied to  meet this  control level  without cost  hardship to the
 phosphate rock industry.
     For a typical size  dryer  (250 TPH) the recommended standard would limit
 emissions to approximately one-sixth of the rate permitted under-the most
 stringent state  standard.
8.5.2  CALCINERS
     Particulate emissions were measured from fluid bed calciners at two
phosphate rock plants.  Each of the calciners are used to  process western
phosphate rock.   Western rock may be considered to produce more adverse
(a)
     The efficiency of the baghouse control  is estimated by applying a  frac-
     tional  efficiency curve (efficiency .versus particle size)  to  the parti-
     cle size distribution of the dryer emissions.   The efficiency curve  was
     developed from test data acquired from  the Particulate Pollutant System
     Study conducted by the EPA, and is representative of a baghouse perform-
     ing under control  conditions similar to those  produced by  phosphate
     rock dryers.
                                   3-28

-------
conditions for emissions control  from calciners because it receives less
cleaning during benefielation than other ore "types.  "Iff addition,  one of
the two calciners processes a mix of both beneficiated and unbeneficiated
rock, lending to a still more adverse control  problem.
      At Plant C, an oil-fired fluid bed calciner removes  moisture and
 organics from western  beneficiated rock.   The calciner unit is  designed for
 70 TPH capacity but processes 80 TPH by using rock  feed which has been
 partially dried.  The  calciner emissions  are  treated by a venturi scrubber
 operating at a pressure drop of  12 inches of  water.   Emissions  measurements
 were performed by both EPA and the operator using EPA Method 5.
      Results of the tests  at Plant C are  shown in Figure  8-5.   Emissions
 from the venturi scrubber  averaged .14  Ib/ton for the EPA tests and  .24
 ^and .136 Ib/ton for the operator tests.   Individual  test  sample results
 ranged from .09 to .31 Ib/ton.

      At Facility K, an oil  fired fluid  bed calciner processes blends  of
 beneficiated and unbenefidated  rock at the rate of 25 TPH.  The  calciner
 emissions are controlled by an Entoleter scrubber operating  in  the range
 of pressure drop 23 to 30  inches of water.  Emissions measurements have
 been performed by the  operator using EPA Method 5 as part of the  testing
 requirements imposed by the State of Idaho.

      Results of the tests  at Facility K are shown in Figure  8-5.   Emissions
 from the Entoleter scrubber averaged .10 Ib/ton when blends  consisting  of
 at least one-third unbeneficiated rock  were processed and the scrubber  was
 operated at 30 inches  of water pressure drop.  When over  one-half of the
 feed was unbeneficiated rock, and the scrubber was  operating at 23.5  inches
 water, emissions levels were measured at .08  Ib/ton.

      The overall test  results show that a venturi scrubber operating at low
 energy (12 inches water) is  capable of  achieving  emissions levels  of  .24
                                    8-29

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 Ib/ton and less from phosphate rock calciners processing western benefici-
 ated rock, and that an Entoleter scrubber operating at relatively high
 energy (23 to 30 inches water)  is capable of achieving emission levels of
 .10 Ib/ton from calciners  generating higher levels  of participate emissions.
 These emission levels  are  appreciably lower than  those now permitted  by the
 most stringent State regulations  (.6 Ib/ton in  Florida).   At  Facility K,
 the Entoleter scrubber, operated  at a pressure  drop of 23  to  30 inches of
 water is  estimated  to  achieve  the control  level attainable by the best sys-
 tem of emissions  reduction.17   At Facility C, the particulate removal  effi-
 ciency of the venturi  scrubber  can  be improved  to the  level attainable by
 the baghouse  (99.0%) by increasing  the energy .input.   Estimates of the emis-
 sion levels which would be anticipated from the venturi scrubber  when  oper-
 ated at higher pressure drops are shown in  Figure 8-5.  The estimates  are
 made by adjusting the  measured  emissions at  the 12  inch pressure  drop  to
 reflect the performance of the  scrubber at  the energy  level (27 inches AP)
 creating  the  best system of emissions reduction.  The  adjustments are made
 using  a calibrated model which  predicts scrubber performance  at various
 energy inputs.    At the appropriate  energy  level, the high energy scrubber
 is  equivalent  to the fabric filter  in terms of removal efficiency.  Both
 the  fabric filter and  high energy scrubber are available technology which
 may  be applied to control emissions from calciners without cost hardship to
 the  phosphate  rock industry^-As shov/n in Figure 8-5, the emissions level
 attainable by  the high efficiency wet scrubbers (or a baghouse)  when con-
 trolling the more adverse loadings expected from calciners is  0.11 Ib/per
 ton of rock feed or less.  It is EPA's judgement that this emission limit
 reflects the emission level attainable from calciners when the best system
of emissions reduction  (either baghouse or the venturi  scrubber) is employed.
                                    8-31

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8.5.3  GRINDERS
     Particulate emissions were measured from four grinders.  The ore feed
is essentially dry when entering the grinders and is typically ground to a
fine powder.  The discharge air stream from grinders consists of the purge
tramp air entering the system and the quantity of this air flow is dependent
primarily on  the design of the grinding circuit rather than the capacity
of the mill.  Airflow varies substantially among grinders, and the amounts
of exhaust  air measured from the four facilities reflect the range of
typical variations expected in the industry.  The test data support the
general conclusion apparent from industry data that emissions variations
are  not clearly related to factors such as fineness of grinding, type of '
ore, or process variables (see Table 4-4).  Given the difficulties in de-
fining any  specific  grinding system which produces a more adverse emissions
control problem than another, the grinders tested were selected to represent
a wide variation of  exhaust air rates, grinder designs, capacities, and
product feeds.  Table 8-5 describes  the various grinder facilities incor-
porated in  the testing program.
               Table  8-5.  CHARACTERIZATION OF  CONTROLLED
                          GRINDERS  SELECTED  FOR TEST
Facility
Designation


D
E
F

G

Type
of Mill


ball
rol ler
roller & ball

ball

Capacity,
TPH


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35
77
77
80
52
Exhaust
Air,
dscfm


13600
2708
6645
5133
4124
5568
Ratio,
dscfm
TPH


110
78
87
67
52
108
Average
exhaust
concentra-
tion
gr/dscf
.0098
.0065
.002
.0028
.0021
.0049
Average
mass
emissions,
1b/ ton

.0088
.004
.001
"•"
.0009
.0045
                                    8-32

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                    8-33

-------
     Emissions from each of the four grinder facilities are treated with
fabric filters.  Figure 8-6 illustrates the results of emissions tests
conducted at each of the facilities.  Emissions from the baghouses averaged
.0088, .004, .001, and .0009 Ib/ton for the EPA tests and .0045 Ib/ton for
the test made by the operator.  All tests were performed using EPA Method
5.  Individual test samples varied from .0006 to .0097 Ib/ton.  The emissions
tests demonstrate that an emissions level of .01 Ib/ton can be achieved by
fabric filters for a variety of grinder applications.  However, because of
the relatively wide variation in emissions expected from grinders  (as  illus-
trated in Figure 8-6}, and because of potential inaccuracies in ore feed
rates associated with the test results, it is EPA's judgment that the
emissions level reflecting the best system of emissions reduction should
be set at .012 Ib/ton,  This potentially liberal level for the emissions
limit should not preclude the installation of best emissions reduction
systems. It is noted that 80 percent of the emissions from current phosphate
rock grinding capacity is controlled by baghouses despite the allowance of
less capable control technology by existing standards.  Installation of bag-
house controls for grinders is motivated by the recovery value of the pro-
duct collected as much as by existing emissions standards.  Hence, it is
expected that baghouses will become the predominant means of compliance
with the proposed NSPS for grinder facilities, consequently, the lowest
emission levels will tend to be achieved despite the potentially liberal
emissions standard.

     For typical sized grinders of 50 TPH capacity, the recommended standard
would Hm1t emissions from grinders to approximately 2 percent of the rate
enforced under the most stringent state regulation.
                                    8-34

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8.5.4  GROUND ROCK TRANSFER SYSTEMS

     Emissions from handling and storage of ground rock are very difficult
to characterize owing to the fact that these systems vary greatly from plant
to plant and no "typical" system can be defined.  Moreover, a substantial
portion of the potential emissions from handling and storage operations is
fugitive emissions.  Normal industrial practice is to control dust from the
various sources by enclosures and air evacuation or pressure systems ducted
to baghouses.  Baghouses provide recovery of the rock dust which is sub-
sequently returned to the rock inventory.  Experience shows that no visible
emissions occur from the enclosures when the process equipment is properly
maintained.  Consequently, emissions from ground rock transfer systems are
manifested and monitored at the overall collection device (e.g., the
baghouse).  Because of wide variations in handling and storage facilities,
a visible emission standard is the only standard appropriate for these
facilities.
     Three pneumatic systems employed in the transfer of ground phosphate
rock were selected for emissions evaluation.  Two of these systems trans-
ferred ground rock from a storage silo at a rock grinder to a storage silo
at a wet-process phosphoric add plant.  The third system transferred ground
rock from a rock grinder to a storage silo at a run-of-pile triple super-
phosphate plant.  Emissions from the transfer systems were passed through
baghouses which utilize a1r-to-cloth ratios of 4 to 1, 8 to 1, and 9 to 1.
Visible emission measurements were made at the baghouse exhaust according
to EPA Method 9.
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     The exhaust from the baghouses of each of the transfer systems was
witnessed for visible emissions by two qualified observers during normal
transfer operations for two hours at one system, and one hour at the
others.  The opacity level of the baghouse emissions was observed to be
zero throughout the test periods.  Based on these results, it is concluded
that the visible emissions limit which reflects the level attainable by the
best system of emissions  reduction for phosphate rock handling and storage
systems is zero opacity from any point in the transfer system.
                                   8-36

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8.6  VISIBLE  EMISSION STANDARDS

     The opacity level of visible emissions 1s an Indication of the mass
concentration of a particular pollutant.  Various studies have shown
that opacity  varies directly with mass concentrations of particulate
matter.  The  applicability and enforcement of opacity standards related
to particulate matter have been established 1n several court cases for
facilities subject to new source performance standards (NSPS) under
Section 111 of the Clean Air Act.

     Opacity  standards help to assure that emission control systems are
properly maintained and operated so as to comply with mass emission
standards on  a continuous basis.  Opacity test methods are quicker,
easier to apply, and less costly than concentration/mass tests for particu-
late matter.  Since EPA  considers opacity standards to be a necessary
supplement to particulate mass emission standards, opacity levels are
established as Independent enforceable standards.
     Where both opacity and concentration/mass standards are applicable
to a given source, EPA establishes opacity standards for new source
performance standards that are not more restrictive than the corresponding
concentration/mass standard.  The opacity standard is generally achievable
if the source 1s in compliance with the concentration standard.  In specific
cases where it can be demonstrated that the opacity standard is being
violated while the particulate standard is being met, provisions for
individual review are included in 60.11(e) of 40 CFR 60.
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 8.6.1  Proposed Visible Emissions Standards

      Visible emission data were obtained during the development of the
 proposed standards using EPA Reference Method 9 (6-m1nute average
 opacities based on the average of 24 observations (one every 15 seconds)
 during the 6-minute period).   The tests were performed at facilities
 representing the best emission control  technology currently employed by
 the industry.   Appendix C contains data on visible emission observations
 performed at two dryers, two  calciners, two grinders and  three  ground-
 rock handling systems.   More  than 100 man-hours of visible emission  ob-
 servations were performed (approximately 32 man-hours for dryers,  29
 man-hours for calciners, 31 man-hours for grinders and 8  man-hours for
 ground-rock handling systems).

 Phosphate Rock Dryers
     Data on visible emissions from dryers were obtained for Facilities
A and B.  Facility A utilizes a Venturi Scrubber to control  emissions and
Facility B employs an electrostatic precipitator (ESP).  Both facilities
process Florida pebble rock, which is considered to produce the most adverse
emission control problem.

     Observations at Facility A Included approximately eight hours of
measurements for two separate dates.  The observed opacity was zero
throughout the test periods.  The average particulate loading during
the test was 0,015 gr/dscf or 0.039 Ib/ton.
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     Observations at Facility B Included approximately 6 hours of measure-
ments on two separate dates.  Opacity averages for six minute observations
sets ranged from Q% to 7.7%.  The average particulate concentration during
the period of visual observations was 0.010 gr/dscf and the process weight
emission rate was 0.025 Ib/ton.
     It may be noted that the facility exhibiting the highest opacity read-
ings exhibited the lower values for particulate concentration in the stack
gases,  the difference between the opacity levels observed for the two
types of control systems primarily reflects differences in diameters of
discharge stacks rather than significant differences in control  perfor-
mance.  ESPs typically require larger stacks due to higher volumes of flow
required during operation.  Setting separate opacity standards for the two
control systems is not considered appropriate because ESPs are not expected
to be used in meeting the proposed NSPS.  Thus the proposed opacity standard
is based on the performance of the scrubber-controlled facility and is set
at zero percent opacity.  Control systems reflecting best emissions control
capability (the high energy scrubber or baghouse) and meeting the proposed
emissions limit should experience no difficulty meeting the proposed opacity
standard.  Should any affected dryer facility be controlled with an ESP and
comply with the partlculate limit of 0.02 kg/Mg but not the opacity limits,
a separate opacity limit may be established for that facility under 40 CFR
60.11(;e).  The provisions of 40 CFR 60.11(e) allow owners or operators of
sources which exceed the opacity standard while concurrently achieving the
performance emissions limit to request establishment of a specific opacity
standard for that facility.  Prior to establishing such a'specific-standard,
the owner or operator must request opacity tests to be performed concurrently
with the emissions performance tests.
                                   8-39

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Phosphate Rock Calciners

     Participate emissions were measured from fluid bed calciners at two
phosphate rock plants (Facilities C and K).  Each of the calciners are used
to process western phosphate rock.  Western rock may be considered to pro-
duce the more adverse conditions for emissions control because this rock
is subject to less cleaning during beneficiation than other ore types.  In
addition, one of  the two  calciners processes a mix of both beneficiated
and  unbeneficiated rock,  lending to a  still more adverse  control  problem.
Facility C  utilizes  a  venturi  scrubber for particulate  control and  Facility
K employs an Entoleter Centrifield  scrubber.       -

      A total of 13.75  hours  of visual  emissions  data was  collected  as  a
part of the testing  procedures for  these two  facilities  (on  two  separate
dates  for Facility C and  on  one date  for Facility  K).   An opacity of  zero
percent was observed throughout the monitoring period at both facilities.
 During the  sampling  and analysis procedures at Facility C, the average measured
 particulate loading was 0.047 gr/dscf or 0.14 Ib/ton.  Particulate
 emissions data were not obtained simultaneously during the collection
 of visible  emissions data at  Facility K.  However, the results of partic-
 ulate sampling tests performed at Facility K in March, September and
  December of ,1975 indicated paniculate  emissions of  .082, .095 and .107
  Ib/ton  of  ore  feed.   Considering the  fact that  the  results of these
                                     8-40

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tests were relatively constant and made over a nine month period, it is
reasonable to expect these levels to be representative of the levels that
         «
may have been measured in June 1976 when the observations of visual
emissions were made.

     Based on the test data, it is clear that the best emissions control
e^u4-pwefit currently used for calcihers (venturi scrubbers with a pressure
drop of 12 inches at Facility C, and Entoleter Scrubber varying from 20 to
30 inches at Facility K) can maintain visible emission levels produced by
the calcining process to a level no greater than zero percent opacity.  The.
control technology which will be  required  by the proposed emissions stan-
dard  represents a level of control exceeding that currently used on
Facilities C and K.  A visible emissions limit of zero percent opacity is
recommended for phosphate rock calciners.  Significant excursions of plume
opacity above this level will be indicative of improper operation of the
control equipment.
Phosphate Rock Grinders                  ,                            .
     Data on visible emissions from grinders were obtained at Facilities F
and 6.  Close to ,1.7 hours of data were recorded at these facilities (on two
separate dates at each facility).  The average opacity level recorded was
zero throughout the measurement period.  The average concentration of
particulate emissions during the periods of observation were .002 and .002
gr/dscf of feed, forTacilities F arid G, respectively.  The respective mass
weight emission rates were 0.0013 and 0.0009 Ib/ton.
                                   8-41

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     The  use of  baghouses as control devices on these two facilities
represents demonstrated best technology, and test data shows that this
level of  control  produces emissions exhibiting no greater than  zero
percent opacity.  Therefore, EPA believes that the visible emission
standard  for phosphate rock grinding processes should be zero percent
opacity.

Ground Rock Handling Systems

     The  visible  emission standard for the ground-rock handling systems was
discussed in Section 8.5.  A visible emissions standard of zero percent
opacity 1s proposed.

8.6.2  Measurement Difficulties for Steam Plumes
     All  visible, observations of visible emissions from dryers and cal-
dners were hampered by the steam content of the plume leaving the stack.
For some  industrial processes steam interference is of such a magnitude
that the  establishment of a visible emission standard would be impractical.
For example, this was the reason given for not establishing a visible
emission standard for hydrators used within the lime manufacturing
        18
Industry  .

     However, the existence of steam 1n a plume is not,  by itself, a
sufficient reason to preclude the establishment of a visible emission
standard.  EPA Reference Method 9 Instructs observers to make readings  at
a down-plume point where the steam has dissipated.  The  methodology of
making visual measurements on steam plumes 1s an Important part of the
training of certified observers.
                               8-42

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     For the development of standards for dryers and calciners,
                         *
over 60 man-hours of opacity readings were gathered by certified ob-
servers under a variety of conditions.  EPA concludes that the observed
values are valid, and therefore, the presence of interference from steam
plumes does not preclude the establishment of a visible emission stand-
ard for those facilities.
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8.7  MODIFICATION AND RECONSTRUCTION CONSIDERATIONS

     The proposed standards would apply to specified systems  (drying,  calcining,
grinding, and ground rock handling and storage systems)  within the phosphate
rock industry which are modified or constructed after the date of regulation
proposal.  Statutory and regulatory provisions defining  "modification" and
"reconstruction" are discussed in Chapter 5, and the general  applicability  of
these provisions to the phosphate rock industry is  described.

8.7.1  Modification

     The information presented in Chapter 5 indicated that except for  speci-
fied categories of changes, a modification is any physical or operational
change to an existing facility which results in an  increased  emission  rate
of a pollutant to which a standard applies.

     For the phosphate rock industry, it is unlikely that existing phosphate
rock facilities will become "affected" facilities as a result of modification.
The following series of physical or operational changes  would be specifically
exempted and would not be considered "modifications" regardless of their
effects on emission rates:

     1.  Changes determined to be routine maintenance, repair, or
         replacement.
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 2.  An increase in the production rate if that increase can be accomplish-
     ed without a capital  expenditure exceeding the existing facility's
     IRS annual asset guideline repair allowance of 6.5  percent per year.

 3c  An increase in the hours  of operation.

 4,  Use of an  alternative raw material,  such as  Florida  land pebble, if
     the existing facility was designed to accommodate such  material.

 5.   Use of an  alternative  fuel,  such  as  switching  from natural gas to
     fuel oil,  if the existing facility was designed to accommodate the
     alternate  fuel.  If the facility was not so designed, the switch
     would  be considered a  modification unless it could be demonstrated
     that the new fuel  did  not result in an increase in emissions.
     However, pursuant  to  Section  113(d}(5) or Section 119 (as in
     effect  before  the  date of enactment of the Clean Air Act
     Amendments of  1977) of the Act, conversion to coal required for
     energy  considerations shall not be considered a modification.
6.  The addition or use of any air pollution control system except
    when a system is removed or replaced  with a system considered
    to be significantly less effective.

7.  The relocation or change in ownership of an existing facility.
    However, the purchase  and  installation of a used piece of equip-
    ment at a stationary source to expand capacity  would  be  considered
    new construction and,  thus, subject to standards of  performance.
                              8-45

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8.7.2  Reconstruction

     The replacement of facility components could be considered reconstruction
if the fixed capital cost of replacement exceeds 50 percent of the cost to
construct an entirely new facility.

     One action which could be considered reconstruction for a dryer, calciner,
grinder or ground rock transfer system would be the replacement and extensive
refurbishing of power plant and drive mechanism, including motor, chains, belts,
gears, couplings, reducers, clutches, bearings, etc.  In such a case, the
test involving the relationship between the fixed capital cost of the replace-
ment versus the corresponding costs for complete reconstruction of the facility
should be used to determine applicability of the reconstruction provision.
The final determination will be made by the EPA Administrator based on infor-
mation provided by the owner.
     Replacement of facility components which are subjected to extreme heat
 (e.g., refractory linings) or attrition due to abrasion or impact (e.g.,
 crushing surfaces, screening surfaces and conveyor belts) could be considered
 routine maintenance and may therefore be exempted by the reconstruction
 and modification provisions.

 8.8   SELECTION OF MONITORING  REQUIREMENTS
      Under section  114(a) of  the Clean  Air  Act,  the Administrator may
 require the owner or operator of any stationary  emission source  to  install,
 use, and maintain monitoring  equipment  or methods.  EPA has  exercised  this
 authority in the standards of performance  for several  source categories  by
 requiring the monitoring of pollutant emissions  or  parameters that  are

                                    8-46

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Indicators of pollutant emissions.  The requirements for continuous'monitor-
1ng are necessary to determine 1f a control device 1s being properly operated
and maintained.  It also aids 1n determining when and 1f a performance test
should be required.  The costs of purchasing, installing, and operating
the monitoring devices must be considered reasonable and affordable.
  .  Opacity monitoring systems have been demonstrated as a reasonable
and effective means of determining proper operation and maintenance of par-
tlculate emission control  systems.  Opacity standards are set at levels
which ensure proper operation and maintenance of the control  system, but
which do not require use of a more efficient system.  The opacity standards
and continuous monitoring requirements do not impose additional  significant
requirements or costs over those required to comply with the  numerical
emissions limit standard.   The opacity monitoring systems are also substan-
tially less costly and more easily applied than periodic mass emissions
tests for particulate matter.
     When wet particulate collection devices (e.g., a Venturi scrubber)
are employed to control emissions, entrained water droplets prevent the
accurate measurement of opacity.  In this case, continuous compliance
through proper operation and maintenance of the control  device would be
determined by monitoring pertinent operating parameters  of the control
device.  When a scrubber 1s used to control the emissions, the proposed
standard would require monitoring the pressure drop across the scrubber
and the scrubbing fluid supply pressure to the scrubber rather than
opacity.  Measurements which show significant deviation  from  levels main-
tained during the performance tests will  indicate improper operation of the
the control equipment.

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8.8.1  Phosphate Rock Dryers and Caldners
     Particulate emissions from phosphate rock dryers and calciners may be
controlled with baghouses, electrostatic precipitators, or scrubbers.  Each
of these devices has been identified as an environmentally acceptable means
of meeting the proposed emissions standard.  The applicability and enforce-
ability of continuous monitoring requirements for facilities controlling
emissions with these control devices has been established for various in-
dustrial emission  sources  regulated by NSPS.  Accordingly, continuous
monitoring of the opacity of the emissions from the calciners and dryers
is recommended.  However, when  scrubbers are used to control emissions,
monitoring of scrubber  operating parameters  (pressure drop and fluid
supply  pressure) would  be recommended  rather  than opacity.  Furthermore,
if alternative  controls are employed which would also preclude the use of
a continuous monitoring system  as  specified  by the  standard, the operator
may  request  establishment of alternative monitoring procedures or  require-
ments  under  the provisions  of 40  CFR 60.13(i).
      As specified  in Sections  60.7(b)  and (c) of  the regulations  (Notifi-
 cation and Recordkeeping),  the  operator of any  source  subject  to  the pro-
 posed standards would be required to maintain records  of the occurrence
 and duration of any periods of start-up, shutdown,  or malfunction  in the
 operation of an affected facility, any malfunction  of the air  pollution
 control equipment, or any periods during which  a  continuous monitoring
 system or monitoring device is not operating.  All  excess emissions  must
 also be reported to EPA for each calendar quarter.   Generally, excess
 emissions of opacity are defined as all six-minute average opacity
 values that exceed the proposed visible emission standard of zero percent
 opacity, except those  occuring during start-up, shutdown, or malfunction
                                   8-48

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 of the facility or control device.  Where scrubbers are used, excess
 emissions are indicated when parameter measurements are more than 10 percent
 below the average levels maintained during the most recent performance test
 in which compliance with the proposed standards was demonstrated.
      Requirements for visible emissions monitoring equipment and procedures
 are outlined in Appendix B of 40 CFR 60.  It should be noted that effluent
 gases from calciners  and dryers may contain trace amounts  of fluorides  which
 react with moisture in the plume to form acids capable of etching glass
 materials.  Glass  lenses from opacity monitoring equipment should either
 be protected from  fluoride containing gas  streams,  or  replaced with  a
 material  not subject  to  etching.

 8.8.2  Phosphate Rock Grinders  and  Ground  Rock Handling Systems
      Particulate emissions  from  grinders and  ground rock handling systems
 are typically controlled with baghouses.   Continuous monitoring of the
 opacity of emissions  from these facilities will provide indication of suit-
 able  operation and maintenance of the baghouse controls.  Should an operator
 choose to employ high energy scrubbers to meet the proposed NSPS, alterna-
 tive monitoring requirements as discussed previously would be recommended.
 Record keeping and notification obligations associated with the
monitoring requirements are the same as discussed in Section 8.8.1.
                                   8-49

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8.9  SELECTION OF PERFORMANCE TEST METHODS
     The performance test method recommended for measurement of particulate
emissions is EPA Reference Method 5, described in Appendix A of 40 CFR 60.
Method 5 was utilized to determine particulate emissions rates for the
source tests supporting the establishment of the proposed standard, and is
typically applied as a performance test procedure for various stationary
source categories for which NSPS have been promulgated.  Under the proposed
standards for phosphate rock plants, performance tests for particulate
matter emissions would be required for air pollution control devices on all
affected facilities.
      A measurement  of the mass  rate of rock  feed would also be required
during a performance test,  because the units  of the proposed standards for
dryers,  calciners,  and  grinders are kilograms  of particulate per megagram
of phosphate rock  feed.   A  measuring  device  such as a  conveyer belt scales
would be required  to  determine  the  mass  rate of feed.
      The test method recommended for  measurement of visible emissions  is
 EPA Reference Method 9, described in  Appendix A of CFR 60.   Method 9 was
 employed to acquire the visible emissions measurements used to  support the
 proposed visible emissions  standard for the four affected phosphate rock
 facilities, and is consistently applied to establish visible emissions
 standards for facilities subject to NSPS.
                                     8-50

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                                REFERENCES FOR  CHAPTER 8
   Stowasser, W. F.  Phosphate Rock:  in Mineral Facts and Problems.  United States
   Department of the Interior, Bureau of Mines.  Bulletin 667, 1976.  pp. 819-834.
 2
   Stowasser, W. F.  Phosphate Rock.  United States Department of the Inferior,
   Bureau of Mines.  Preprint of Bulletin 667, 1975.  p.  15.
 3
   Stowasser, W. F. 0£. cit.
 4
   Stowasser, W. F.  op.  cit.
 5
   U.  S.  Department of Health,  Education and Welfare.   Air Quality Criteria  for
   Particulate Matter.  National  Air Pollution Control  Administration  Publication
   Number AP-49. January  1969.

   Argonne National  Laboratory.   Priorities  and Procedures  for  the  Development  of
   Standards  of Performance  for New  Stationary Sources  of Atmospheric  Emissions.
   Prepared for  the  U.  S.  Environmental  Protection Agency, Contract  Number IAG-04-0463,
   Project Number 2

  Letter  from Mr. J. C. Barker* Tennessee Valley Authority, to Mr.  Lee Beck,
  Environmental Protection Agency, dated November 18, 1975.
8
  Battelle Memorial Institute. Inorganic Fertilizer and Phosphate Mining Industries
  Water Pollution and Control.  Environmental Protection  Agency Document Number
  12020 FPD 09/71.   pp. 99-102.
9
  Letter from Mr.  J. C. Barber,  Tennessee Valley Authority, to  Mr.  Lee Beck,
  Environmental Protection Agency, dated November 18,  1975.
                                         8-51

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10
Barber, J. C., and Farr, T. D.  Fluoride Recovery from Phosphorous
Production.Chemical Engineering Progress.  Volume 66, Number 11.
p. 57.
11
12
    Wright, T. J.  Control of Gaseous and Particulate Emissions in Phos-
    phate Calcination.  American Institute of Mining, Metallurgical and
    Petroleum Engineers, Inc.  (AIME Environmental Quality Conference,
    Washington, D. C., June 7 - 9, 1971).
    Ibid.
13
Betts, A. G.  Recovery of Sulfur Dioxide  ($02) from Gas Streams  and
Precipitation of Aluminum Fluorine Product.  United States  Patent Office
Patent Number 3,697,248.  October 10,  1972.
14
    Chemical  Construction  Corporation.   Engineering  and  Cost Study of
    Emissions Control  in the  Phosphate  Industry.  An unpublished draft
    prepared  under  contract to  the  Environmental  Protection Agency
    (Contract CPA-70-156).  August  1972.
 15   Trip  report from Mr.  C.  L.  Vacher,  Catalytic,  Incorporated,  to  Mr.  Lee
     Beck, Environmental  Protection  Agency,  dated December 30,  1974.

 16  Sparks, L,E,, SR-52 Programmable  Calculator Programs  for Venturi
     Scrubbers and Electrostatic Precipitators, (EPA-600/7-78-026),
     March 1978.

 17  Letter from J,L, Smith,  Simplot Company, to Jack Farmer, Environmental
     Protection Agency,  dated May 19,  1976,  containing scrubber efficiency
     data for Venturi and Centrifield  scrubber units.
                                8-52

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18
19
Environmental Protection Agency, Standard Support and Environmental
Impact Statement, Volume 1:  Proposed Standards of Performance for
Lime Manufacturing Plants, EPA-450/2-77-007a, April, 1977.

Engineering Science, Inc., EPA Report for Mobil Chemical  Nichols,
Florida.   Prepared for Environmental  Protection Agency,. Office of Air
Quality Programs and Standards, Emissions Measurement Branch,  01  Jan-
uary.
                                 8-53

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             APPENDIX A.  EVOLUTION OF THE SELECTION OF BEST
                             SYSTEM OF EMISSION REDUCTION
 A.I.  BACKGROUND DEVELOPMENT
       Federal  emission control  interest in the phosphate fertilizer
 industry, of which phosphate rock plants are a part,  was first initiated by
 a 1970 U. S. Senate report from the Secretary of Health, Education  and
 Welfare.    This  report stated in part thafthe industry  is  a  major  source
 Qf fluorides which, can cause damage to plants and livestock..   Shortly  there-
 after, EPA began a study  of the. phosphate fertilizer  industry to determine
 to what extent it contributes to air pollution.   This study identified several
 sources of paniculate and  fluoride emissions  and reported that substantial
 growth in .the  industry is likely.2   As  a result of the study,  EPA developed
 standards of performance  for sources  of particulates and fluorides  in the
 high growth fertilizer manufacturing  processes.   The standards were promulgated
 on  August 6, 1975.3  The study also  identified several sources in the phosphate
 rock processing  segment  of  the  industry as having substantial potential  for
 particulate emissions, which prompted this second phase of standards develop-
 ment for  the industry.
       In  the course of the program to develop standards of performance,
 discussions were held to solicit Information and data from practically  all
of the phosphate rock producers, two state agencies,  EPA Region IV and  two
industry trade  associations:  The Fertilizer Institute and the Florida
Phosphate  Council.  In addition,  a telephone survey was  undertaken  to
identify and locate well-controlled installations. EPA also enlisted several
                                  A-l

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contractors to aid in the development of background information, cost data
on air pollution control systems, and an analysis of the economic and
environmental'impacts of several levels of emissions control.
A.2.  PLANT INSPECTIONS
      From the information gathered, EPA engineers (and contractors in some
cases) selected and visited 25 reportedly well-controTied plants to evaluate
particulate emission control systems and to obtain information on process
operations.  Control systems were evaluated on the basis of:
         • Design parameters.
         • Emissions data from previous source tests.
         • Visible emissions.
         •Maintenance.
         • Efficiency of the system in collecting the emissions and
            ducting them to the  control devices.
In addition, process variables which affect the level of uncontrolled
emissions, such as the -type of process employed and the raw materials used,
were noted to assure that the plants were representative of the industry.
A.3.   DEVELOPMENT OF THE  DATA BASE  FOR THE STANDARD
     Of  the 25  plants  visited,  12 were selected for further evaluation
of  their control  systems  by measuring their emissions.  Results of most  of
these  performance tests are summarized in Appendix C.  These  data, along witn
the cost and  environmental  impact of several  levels of emission control,
 and recommended performance standards for phosphate rock plants., were pre-
 sented to  the National  Air  Pollution Control Techniques Advisory Committee
 (NAPCTAC)  on  March  18,  1976.

                                 A-2

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       EPA (with  the  aid  of  a  contractor)  completed the  Background Infor-
mation  Document  (including  the  Rationale  Chapter),  issue  paper,  preamble
and  proposed  standard, and  presented  this  documentation to  the EPA Working
Group on  October 19,  1978.  The proposed  standard  was similar to that
recommended at the NAPCTAC  meeting, although the format of  the emissions
limit was  changed from a concentration  limit to a  mass emissions per unit
feed limit.   The Working Group  also resolved to authorize an upgrade of
the Background Information  Document to  improve the  data. base.
      After an upgrading of the Background Information Document,  and
appropriate revision of the proposed standard, a documentation package
consisting of the BID, preamble, proposed standard, and action memorandum
was mailed on April 18, 1979 to the Steering Committee for  review on a
consent agenda.
      Comments from the Steering Committee were received and incorporated as
appropriate into  the regulatory package.  The revised package (the "AA
Concurrent Package"  was mailed in  July 1979 to the  Administrator.
                                  A-3

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                      REFERENCES FOR APPENDIX A
1.  United States Senate.  National Emission Standards Study.   Senate
    Document No. 91-63.  March 1970.

2.  Chemical Construction Corporation.  Engineering and Cost Study in
    the Phosphate Industry.  Unpublished draft.  EPA Contract No.
    CPA-70-156.  August 1972.

3.  Environmental Protection Agency.  Federal Register.  40 CFR Part
    60.  pp. 33152-33166.  Washington, D. C. U. S. Government.
    November 17, 1975.
                                  '  A-4

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                           APPENDIX B
           INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS

     This appendix consists of a reference system, cross-indexed with
the October 21, 1974, Federal  Register (39 FR 37419) containing the
Agency guidelines- concerning the preparation of Environmental Impact
Statements.  This index can be used to identify sections of the
document which contain data and information germane to any portion
of the Federal Register guidelines.
                             B-l

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                APPENDIX C.  SUMMARY OF TEST DATA
      A test program was undertaken by EPA  to evaluate  the best  partlculate
                            •
 control  techniques available for  controlling participate emissions  from
 phosphate rock dryers,  caldners, grinders, and  ground-rock  handling  systems.
 In addition,  tests were performed to determine the amount of fluorides
 evolved from a calciner controlled by  a venturi  scrubber.  This appendix
.describes the facilities  tested and  summarizes  the results  of partlculate
 and fluoride emission tests and visible emission observations.

      Two dryers, two  calclners  tnd four grinders were tested for,particul ate
 emissions using EPA Reference Method 5, and one calciner was tested for
 fluorides using EPA Reference Method 13.  In addition, visible emission
 observations were performed at two dryers, one calciner, three grinders,
 and  three ground-rock handling systems.  These observations were performed
 using EPA Reference Method 9.  Results of the front-half catches (probe  and
 filter)  from the partlculate emission measurements  conducted are graphed
 1n Figures  1  and 3 for visual  comparison  and the  complete results are presented
 1n Tables C-1  through  C-14.  Results'of visible-emission observations  are
 presented in Tables  C-15  through C-35.

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       FACILITY  C             C       C      K
CONTROL DEVICE  VS           VS       VS     ES
               VS - VENTURI SCRUBBER     ES -- CENTRIFIELD
                                              SCRUBBER
  Figure C-2.  Particulate emissions from phosphate rock calciners
                           C-3

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                          BH -- baghouse

Figure C-3.  Particulate emissions from phosphate rock grinders
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DESCRIPTION OF FACILITIES

     A.  Oil-.fired (No. 6 fuel oil) rotary dryer designed to reduce the
moisture in phosphate rock from between 10 and 15 percent to less than
3 percent.  Its production rate varies from 220 TPH to 440 TPH, depending  on
the moisture content and the type of rock being processed.  Florida land
pebble was dried during each of the EPA tests and during the first test
conducted by the operator.  Flotation cell concentrates were being dried during
the second operator test.  Emissions from the dryer are cleaned by a Ducon
venturi scrubber which has a pressure drop of 18 inches of water and uses
950 gal/min of recirculated water.  EPA tests were conducted only while the
process was operating normally.  EPA and operator particulate measurements
were performed using EPA Method 5,  Visible emission measurements were made
by EPA at the scrubber exhaust in accordance with EPA Method 9.
     B.  One oil-fired rotary dryer and one oil-fired fluid bed dryer operated
1n parallel.  Nominal production rates are 330 TPH for the rotary dryer and
165 TPH for the fluid bed dryer; however, actual production rate is dependent
on the amount of moisture and type of rock fed to the dryers.  Both dryers
were operated normally at full capacity and processed 100 percent Florida
land pebble for each of the EPA tests.  Emissions from both dryers are
partially cleaned by two parallel Impingement scrubbers (one for each dryer).
Emissions from the scrubbers are combined and ducted to a two-stage wet
electrostatic precipitator (ESP) which has a total collecting area of
50,600 square feet and a gas velocity of 1.53 feet per second.  The cleaned
gas exits the ESP from two vertical stacks.  The ESP was reportedly designed
for  approximately  twice  the volume of .gas currently being processed.  EPA
                                  C-5

-------
 particulate measurements were performed using EPA Method 5.  The operator
 conducted measurements using the State of Florida Department of Pollution
 Control Method.  Visible emission observations were made at the ESP
 exhausts in accordance with EPA Method 9.
      C.  Fluid bed, oil-fired (No. 2 fuel oil) calciner used to remove
 moisture and organics from phosphate rock.  Designed to calcine 70 TPH,
  but the operator has  increased  the calcining  capacity  to  8'0 TPH  by  drying a
  portion of the  feed prior to calcination.   Calciner emissions  are cleaned
 by an ARCO venturi scrubber Y(hich has a pressure drop of 12 inches of
 water and uses about 600 gal /mi n recirculated water.  Tests were conducted
 only while the process was operating normally.  EPA and company particulate
 measurements were performed using EPA Method 5.  The results  of the  tests  by the
 Company  are  reported in  Tables C-6  and  C-7.  Fluoride tests were  performed
'EPA Method  13, and visible emissions were  recorded  using EPA  Method  9.
      D.  Kennedy Van Saun ball mill used to grind phosphate rock.  Production
 throughput  is nominally rated at 124 TPH, but is dependent on the degree of
 fineness to which the rock is ground.  Emissions from the grinder are cleaned
 by a Mikro-Pulsaire baghouse.  Tests were conducted only during normal
 process operation,  Particulate measurements were performed using EPA Method
 5.  Visible emissions were not recorded.
      E,  Raymond roller mill used to grind dried phosphate rock.  Production
 throughput is nominally rated at 35 TPH, but is dependent on the degree of
                                   C-6

-------
fineness to which the  rock is ground.  During  the  first  two  tests,  rock
was ground to 65 percent  through 200 mesh,  and it  was  ground to  90  percent
through TOO mesh (65 to 85 percent through 200 reesh), during the third test.
Emissions from the grinder are cleaned by a baghouse.  Tests were conducted only
during, periods when the process was operatina normally.  Particulate measurements
were performed using EPA Method 5.  Visible emission observations were made at
the baghouse exhaust.

      F.  One  roller mill  and one ball  mill  operated  in parallel.  Production
rates cannot  be measured  accurately, but experience shows that the roller rail!
normally operates, at 27.5 TPH and  ball mill  at 50  TPH.  The  method  used
to determine  if mills  are operating  at full  capacity is  by  the  amperage
reading  of the mill motors and fans.   Mills were operated at full capacity during
all  EPA  tests.   Emissions from both  grinders are combined and cleaned by a
baghouse which  has  an air-to-cloth ratio of 4. to 1.   Tests were conducted
only while the  process was operating normally.  EPA particulate measurements
were performed  using EPA Method 5.  Particulate measurements made by the
operator were performed using Western Precipitation Method  WP-50.  The results
are presented 1n Table C-12.  Visible  emission  observations  were made at the
baghouse exhaust in  accordance with EPA Method  9.
      G.  Harding ball mill used to grind calcined phosphate rock to 50 percent
 minus 200 mesh.  Production throughput is nominally rated at 60 TPH.
 Emissions  from  the grinder are  cleaned by a Mikropul, pulse-air  cleaned bag-
 house with an air-to-cloth ratio  of about 5 tol.  Tests were conducted only
                                   C-7

-------
during periods when the process was operating normally.  EPA and company
participate measurements were performed using EPA Method 5.  Results of the
Company tests are shown in Table C-14.  Visible emission observations were made
at the baghouse exhaust in accordance with EPA Method  9.

     H.  Pneumatic system for transferring ground phosphate rock from a storage
silo at a phosphate rock grinder to a storage silo at  a wet-process phosphoric
acid plant.  About 60 percent of the rock transferred  is small enough to
pass through a 200 mesh screen.   The system was transferring about 60 tons of
ground rock per hour, which is its normal operating rate.  It has an exhaust
gas flow rate of about 1700 dscfm.  Emissions from the system pass first
through a cyclone and then through a Mikro-Pulsaire baghouse which has an
air-to-cloth ratio of about 4 to 1.  Visible emission  measurements were
made at the baghouse exhaust in accordance with EPA Method 9.

      I.   Pneumatic system  for  transferring ground  phosphate  rock  from a
 storage  silo  at a  phosphate  rock  grinder to  a  storage  silo at a wet-process
 phosphoric acid plant.   About  60  percent of  the rock transferred  is  small
 enough to pass through a 200 mesh screen.  The system  is designed to transfer
 about 47.5 tons of ground  rock per hour,'but can transfer a  maximum  of
 87.5 tons per hour.   It was  operating at about 77.5 tons per hour during  the
 EPA tests.  Emissions from the transfer system exhaust through a  cyclone  to
 a Mikro-Pulsaire baghouse which has 36 bags, each of which are 96 inches
 long by 4.5 inches in diameter.  The exhaust gas flow  rate is about  2,500
  dscfm and" the air-to-cloth  ratio  is  about 8 to.!.' Visible  emission measurements
                                   C-8

-------
were made at the baghouse exhaust in accordance with EPA Method 9.
     0.  Pneumatic system for transferring ground phosphate rock from
a phosphate rock grinder to a storage silo at a run-of-pile triple super-
phosphate plant.  About 70 percent of the rock transferred is small enough
to pass through a 200 mesh screen.  The system was transferring about
15 tons of ground rock per hour, which is its normal operating rate.
It has an exhaust gas flow rate of about 2000 dscfm.  Emissions from the
system pass through a cyclone to a baghouse which  has  25 bags,  each of
which are 96 inches long by 4.5 inches in diameter, yielding an air-tordoth
ratio of about 9 to 1.  Visible emission measurements were made at the
baghouse exhaust in accordance with EPA Method 9.

     K.  Fluid, bed, natural gas-fired calciner used to remove moisture
and  organics from phosphate rock.  Designed to calcine 46 tph, but
operator has difficulty maintaining the design.product!on rate because
of lack of surge capacity between calciner and grinder.   Calciner emissions
are  cleaned by an Entoleter Centrifield scrubber which operates in
a range of 20  to 30 inches of water pressure drop.  Parti oil ate measure-
ments were conducted  by  the operator using EPA Method  5  while  the
calciner was operating normally.  Visible emissions were recorded by EPA
using  EPA Method 9.   Visible emission measurements were  not recorded
simultaneously with the  Method  5  tests.
                                   C-9

-------
                                     TABLE  C-l
                                   FACILITY  A
                        Summary of Results of Tests of a Dryer
Run Number

Date-

Test Time - Minutes
Production Rate - TPH
Stack Effluent (From a Scrubber)
   Flow rate - ACFM
   Flow rate - DSCFM
   Temperature - °F
   Water vapor - Vol .  %

Visible Emissions at
Collector Discharge -
% Qoacity
Parti oil ate Emissions
   Probe and filter catch
      gr/DSCF
      gr/ACF
      Tb/hr
      Ib/ton
   Total catch
      gr/ACF
      Ib/hr
      Ib/ton
1
3/18/75
108
250
6,786
3,289
153
27.4

0.014
0.009
9.07
0.036
0.058
0.037
36.57
0.146
2
3/18/75
108
235
115,967
74,553
152
25.7
See Tables
0.017
0.011
11.14
0.047
0.042
0.028
27.46
0.117
3
3/19/75
108
240
116,437
73,782
153
26.6
C-l 5 through
0.013
0.008
8.04
0.034
0.051
0.032
32.44
0.135
Averac
-
108
242
116,397
73,875
153
26.6
C-17
0.015
0.009
9.42
0.039
0.051
0.032
32.16
0.133
                                           C-10

-------
                                      TABLE  c-2
                                    FACILITY A
                        Summary of Results of Tests of a Dryer
 Run  Number
 Date
 Test Time - Minutes
 Production Rate - TPH
 Stack Effluent (From a Scrubber)
   Flow rate - ACFM
   Flow rate - DSCFM
   Temperature - °F
   Water vapor - Vol. %
Visible Emissions at
Collector Discharge -
% Ooacity
Particulate Emissions
 1
9/4/74
9/8/74
                                     Average
                                      360

                                  109,000
                                   65,000
                                      160
                                     24.8
Probe and filter catch
gr/DSCF a
gr/ACF a
Tb/hr
Ib/ton
Total catch
gp/DSCFa
gr/ACF a
Ib/hr
Ib/ton
' Calculated
NR - Not Reported

0.025
0.015
14.7
0.041

0.046
0.027
26.7
0.074



0.018
0.011
10.0
0.036

0.040
0.024
21.5
0.060



0.022
0.013
12.3
0.038

0.043
0.026
24.1
0.067



-------
                                      TABLE C-3
                                    FACILITY  B
                        Summary of Results of Tests of a Dryer
 Run Number
 Date

 Test Time - Minutes
 Production Rate - TPH
 Stack Effluent   (From an ESP)
   Flow rate - ACFM
   Flow rate - DSCFM
   Temperature - °F
   Water vapor - Vol. %
Visible Emissions at
Collector Discharge -
% Ooacity
Particulate Emissions
   Probe and filter catch
      gr/DSCF
      gr/ACF
      Tb/hr
      Ib/ton
   Total catch
      gr/DSCF
      gr/ACF
      Ib'/hr
      Ib/ton
1
3/20/75
108
394
134,463
113,144
112
9.2

0.012
0.010
11.91
0.030
0.015
0.013
14.66
0.037
2
3/20/75
108
394
133,566
110,758
115
10.0
See Tables
0.013
0.010
12.08
0.031
0.016
0.014
15.06
0.038
3
3/24/75
108
379
129,084
111,918
104
7.46
C-18 through
0.005
0.005
5.23
0.014
0.009
0.008
8.80
0.023
Avera<
-
108
389
132,371
111,940
no
8.9
C-20
0.010
0.008
9.74
0.025
0.013
o.on
12.84
0.033
                                            c-i*

-------
                                      TABLE  C-4"
                                    FACILITY B
                              Summary of  Results  of
                                 Tests of a Dryer
Date

Test Time - Minutes
Production Rate - TPH
Stack Effluent   (From  an  ESP)
   Flow rate - ACFM
   Flow rate - DSCFM b
   Temperature - °F
   Water vapor - Vol. %

Visible Emissions at
Collector Discharge -
% Ooacity
Particulate Emissions
   Probe and filter catch
      gr/DSCF
      gr/ACF
      Tb/hr
      Ib/ton
   Total'catch
      gp/DSCF C
      gr/ACF c
      Ib/hr
      lb/tonc
6/10/74 - 8/14/74

        NR
       423

   124,373
   115,348
        NR
        NR

        NR
        NR"
        NR
        NR
        NR

      0,023
      0.021
       22.8
      0.054
     'aAverage of  11  tests, 9 of which were performed while both dryers were fired with
       natural gas.
       Calculated; assuming a stack gas temperature of 110°F.
     Calculated.
     NR  - Not Reported
                                          C-T?

-------
Run Number
Date
                 TABLE  C-5
               FACILITY  c
           Summary  of Results
         of Tests of a Caldner
  1         2,3         4          5          6

4/8/75    4/8/75    4/9/75    4/9/75    4/10/75    4/10/75
Average
Test Time - Minutes
Production Rate - TPH
Stack Effluent (From a
Flow rate - ACFM
Flow rate - DSCFM
Temperature - °F
Water vapor - Vol.
Visible Emissions at
Collector Discharge -
% Opacity
Parti cul ate Emissions
120
80
Scrubber)
47,197
25,319
141.5
% ' 25.1
0

120
, 80

50,160
27,764
143.5
22.6
0

120
80

51 ,456
28,407
145.8
22.5
0

120
80

54,719
28,005
158.5
26.7
0

120
80

50,324
27,525
146.0
23.1
0

120
80

49,262
26,338
144.6
25.0
0

120
80

'50,520
27,226
146.7
24.2
0

Probe and filter catch
gr/DSCF
gr/ACF
Ib/hr
Ib/ton
Total catch
gr/DSCF
gr/ACF
Ib/hr
Ib/ton
NR - Not Recorded
0.038
0.020
8.18
0.10
0.040
0.021
8.62
0.11

0.055
0.030
13.10
0.16
0.057
0.031
13.46
0.17

0.048
0.027
11.8
0.15
0.051
0.028
12.49
0.16

0.046
0.023
10.98
0.14
0.057
6.029
13.68
0.17

0.041
0.023
9.75
0.12
0.044
0.024
10.44
0.13

0.053
0.028
11.99
0.15
0.067
0.035
15.03
0.19

0.047
0.025
9.20
0.14
0.053
0.028
12.29
0.15

                                           C-14

-------
                                     TABLE  C-6
                                   FACILITY  C
                              Summary of Results
                            of Tests  of  a  Calciner
Run Number

Date

Test Time - Minutes
Production Rate - TPH
Stack Effluent  (From a Scrubber)
   Flow rate - ACFM
   Flow rate - DSCFM
   Temperature - °F
   Water vapor - Vol.  %

Visible Emissions at
Collector Discharge -
% Ooacity
Particulate Emissions
   Probe and filter catch
      gr/DSCF
      gr/ACF
      Tb/hr -
       Ib/ton
   Total catch
      gp/DSCF
      gr/ACF
      Ib/hr
      Ib/ton
   1
10/2/73
10/3/73
10/3/73
                          Average
98
51.7
46,850
29,558
131
12.38
NR
0.034
0.021
8.54
0.17
NR
NR
NR
NR
98
35.9
38,391
25,540
124
9.51
NR
0.043
0.028
9.32
0.23
NR
NR '
NR
NR
98
35.9
41 ,069
26,885
126
10.81
NR
0.049
0.032
11.30
0.31
NR
NR
NR
NR
98
41.2
42,103
27,328
127
10.90
-
0.042
0.027
9.46
0.24
-
-
-
«•
 NR  - Not Reported
                                            C-15

-------
Run Number

Date
Test Time - Minutes
Production Rate - TPH
Stack Effluent  (From a  Scrubber)
   Flow rate - ACFM
   Flow rate - DSCFM
   Temperature -  °F
   Water vapor -  Vol. %
Visible  Emissions  at
Collector  Discharge -
% Ooacity
Parti oil ate  Emissions
                                     TABLE  C-7
                                   FACILITY  C
                              Summary of Results
                             of Tests of a Calciner
                                      1           2
Average
  120 •
 64.8

48,451
32,756
 132
 6.37
Probe and filter catch
gr/DSCF
gr/ACF
Tfa/hr
Ib/ton
Total catch
gr/DSCF
gr/ACF
Ib'/hr
Ib/ton

0.043
0.029
12.03
0.186

NR
NR
NR
NR

0.020
0.013
5.58
0.086

NR
NR
NR
NR

0.032
0.021
8.80
0.136

-
•
-
..
    a Two of three tests were averaged.  The third test was invalidated by sample  contamination.
   NR - Not Reported                                                        .      . •    ,
                                            C-16

-------
                                    TABLE  C-7a
                                    FACILITY K
                               Summary of Results
                             Of Tests of a Calciner
Run Number
Date
Test Time - Minutes
Production Rate - TPH
Stack Effluent
  Flow rate - ACFM
  Flow rate - DSCFM
  Temperature - °F
  Water vapor - Vol. %
Visible Emission at
Collector Discharge - % Opacity
Particulate Emi ssions
  Probe and filter catch
1
3/9/75
NR
27
2
9/2/75
NR
25
3
12/17/75
NR
25

11



NR
,100 "
NR
NR
NR
NR
10,900
NR
NR
NR
NR
10,900
NR
NR
NR
  Average
    25.7
10,967
     gr/DSCF
     gr/ACF
     Ib/hr
     lb/ton
  Total catch
     gr/DSCF
     gr/ACF
     Ib/hr
     Ib/ton
            UT
0.023
NR
2.21
0.082
0.025
NR
2.37
0.095
0..028
NR
2.67
0..107
0.025

7.26
0.094
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
- NR
 (1)
      Calculated from information  submitted  by operator
 NR  -  Not Reported
                                       C-16a

-------

-------
 Run  Number

 Date
                                        TABLE C-8
                                      FACILITY  C
                                  Summary  of  Results
                               of Tests of a Calciner
                                  2         3         4
               Average
                      4/4/75     4/5/75    4/8/75    4/8/75    4/9/75    4/10/75
120
80
120
80
120
80
120
80
120
80
120
80
Test Time - Minutes          120
Production Rate - TPH        80
Stack Effluent (From a Scrubber)
   Flow rate - ACFM      53,213   50,116   47,101   49,251   55,430   49,563   50,779
                         27,965   27,752   26,267   26,803   28,275   26,663   27,288
                                   145.0    143.3    144.4    152.5
                                    22.3     21.9     23.8     27.6
Flow rate - DSCFM
Temperature - °F       146.3
Water vapor - Vol. %    26.1
       143.5
        24.6
145.8
 24.5
Visible Emissions at
Collector Discharge -
% Opacity
Fluoride Emissions
   Total catch
      gr/DSCF
      gr/ACF
      Ib/hr
      Ib/ton
                      0.00020   0.00038   0.00092   0.00046
                      0.00010   0.00021    0.00051    0.00025
                      0.05       0.09       0.21       0.11
                      0.0006     0.0011     0.0026     0.0014
0.00035   0.00104
0.00018   0.00056
0.08      0.24
0.0010    0.0030
    0.00056
    0.00030
    0.13
    0.0016
                                            C-17

-------
Run Number
        TABLE C-9
      FACILITY  D
 Summary of Results
of Tests of a Grinder
         1           '2
Average
Date
Test Time - Minutes
  •>
Production Rate - TPH
Stack Effluent (From a Baghouse)
   Flow rate - ACFM
   Flow rate - DSCFM
   Temperature - °F
   Water vapor - Vol . %
Visible Emissions at
Collector Discharge -
% Ooacity
Parti cul ate Emissions
   Probe and filter catch
      gr/DSCF
      gr/ACF
      Tb/hr
      "Ib/ton
   Total catch
      giVDSCF
      gr/ACF
      Ib/hr
      Ib/ton
1/11/73
128
121
15,200
13,200
115
5.80
NR
0.0102
0.0089
1,154
0.0095
0.0132
0.0114
1.49
0.0123
1/11/73
128
131
14,700
12,800
115
6.10
NR
0.0115
0.0100
1.270
0.0097
0.0155
0.0134
1.70
0.0130
1/12/73
128
120 '
14,900
13,000
118
5.30
NR
0.0078
0.0068
0.869
0.0072
0.0100
0.0087
1.11
0.0093
-
128
124
14,900
13,600
116
5.70
NR
0.0098
0.0072
1.098
0.0088
0.0129
0.0095
1.43
• 0.0012
    NR - Not Recorded
                                            C-18

-------
 Run Number
 Date
                                       TABLE   C-10
                                  •   FACILITY   E
                               Summary of  Results
                              of  Tests of a Grinder
 Test Time - Minutes
 Production Rate -  TPH
 Stack  Effluent  (From a Baghouse)
    Flow  rate  -  ACFM
    Flow  rate  -  DSCFM
   Temperature  - °F
   Water vapor - Vol. %
Visible Emissions at
Collector Discharge -
% Ooacity
Particulate Emissions
   Probe and filter
1
2/16/73
120
36.0
3,295
2,720
161
5.32
2
2/16/73
120
36.0
3,256
2,654
161
6.05
3
2/16/73
120
33.0
3,386
2,751
161
6.53
Average
-
120
35.0
3,312
2,708
161
5.97
                                      NR
NR
                                                              NR
                          NR
gr/DSCF
gr/ACF
Tb/hr
Ib/ton
Total ' catch
.WDSCF
gr/ACF
Ib/hr
Ib/ton
i 1
0.0085
0.0070
0.198
0.0055

0.0149
0.0122
0.347
0.0096
0.0066
0.0054
, 0.149
0.0041

0.0178
0.0146
0.406
0.0113
0.0044
0.0035
0.102
0.0031

0.0080
0.0065
0.188
0.0057
0.0065
0.0053
0.150
0.0042

0.0136
o.om
0.314
0.0089
NR  -  Not Reported
                                          c-iy

-------
                                    TABLE  C-ll
                                   FACILITY  F
                              Summary  of Results
                            of Tests  of a Grinder
Run Number

Date

Test Time - Minutes
Production Rate - TPHa
Stack Effluent  (From a Baghouse)
    Flow rate - ACFM
    Flow rate - DSCFM
    Temperature -  °F
    Water  vapor -  Vol.  %

 Visible  Emissions at
 Collector Discharge -
 % Ooacity
 Parti oil ate Emissions
1
3/25/75
120
77.5
8,385
6,676
146
9.47
2
3/25/75
120
77.5
8,582
6,809
155
8.47
3
3/26/75
120
77.5
7,897
6,449
139
8.79
Average
-
120
77.5
8,288
6,645
147
8.91
Probe and filter catch
gr/DSCF
gr/ACF
Tb/hr
Ib/ton
Total ' catch
gp/DSCF
gr/ACF
Ib/hr
m/4-nn

0.002
0.002
0.117
0.0015

0.003
0.002
0.159
0.0021

0.002
0.001
0.099
0.0013

0.003
0.002
0.159
0.0021

0.002
0.001
0.093
0.0012

0.002
0.002
0.116
0.0015

0.002
0.001
0.103
0.0013

0.003
0.002
0.145
0.0019
                                                         the normal  production rate when
                                                                 in  U. was calc.Uted
         using the normal production rate
                                             C-20

-------
 Run Number
 Date
                                       TABLE  C-12
                                 .    FACILITY  F
                                Summary of Results
                              of Tests of a Grinder
     Average9
V3/74 - 6/27/74
 Test Time - Minutes
 Production Rate - TPH
 Sta;ck Effluent (From.a Baghouse)
    Flow  rate  - ACFM
    Flow  rate  - DSCFM
    Temperature -  °F
    Water vapor -  Vol.  %
Visible Emissions at
Collector Discharge -
% Ooacity
Parti oil ate Emissions
   Probe  and filter catch
      gr/DSCF
      gr/ACF
      Tb/hr
      ]b/ton  ,
  Total'catch
     gi»/DSCFb
     gr/ACF
     Ib/hr
     Ib/ton

   a Average of 15 tests.
     Calculated.
   NR - Not Reported
       NR
       NR

       NR
     5,133
       NR
       NR

      NR
      NR
      NR
      NR
      NR

  0.0028
     NR
    0.12
     NR

-------
                                     TABLE  C-13
                                   FACILITY  G
                              Summary of Results
                             of Tests of a  Grinder
Run Number

Date

Test Time - Minutes
Production Rate - TPH
Stack Effluent  (From a  Baghouse)
   Flow rate - ACFM
   Flow rate - DSCFM
   Temperature - °F
   Water vapor - Vol. %
Visible Emissions at
Collector Discharge -
% Qoacity
Particulate Emissions
1
4/5/75
200
81.4
6,713
4,194
233
0.0
2
4/7/75
200
81.0
6,830
4,286
231
0.0
3
4/7/75
200
80.8
6,446
3,983
241
0.0
Averagi
-
200
81.1
6,663
4,124
235
0.0
0-
Probe and filter catch
gr/DSCF
gr/ACF
Tb/hr
Ib/ton
Total catch
giVDSCF
gr/ACF
Ib/hr
Ib/ton
•
0.0014
0.0009
0.05
0.0006

0.0015
0.0009
0.05
0.0006

0.0034
0.0021
0.12
0.0015

0.0038
0.0024
0.14
0.0017

0.0016
0.0011
0.06
0.0007

0.0039
0.0024
0.13
0.0016

0.0021
0.0014
0.08
0.0009

0.0031
0.0019
0.12
0.0013
                                           C-22

-------
                                      TABLE  C-14
                                    FACILITY  G
                               Summary of Results
                             of Tests of a Grinder
 Run  Number

 Date

 Test Time  -  Minutes
 Production Rate - TPH
 Stack Effluent  (From a Baghouse)
   Flow rate - ACFM
   Flow rate - DSCFM
   Temperature - °F
   Water vapor - Vol. %
Visible Emissions at
Collector Discharge -
% Ooacity
Particulate Emissions
1
10/3/73
120
52
8,242
5,635
159
0.84
2
10/3/73
120
52
8,423
5,661
177
0.00
3
10/3/73
120
52
8,058
5,408
177
0.00
Averac
-
120
52
8,241
5,568
171
0.28
NR
NR
NR
Probe and filter catr.h
gr/DSCF
gr/ACF
•Tb/hr
Ib/ton
Total ' catch
gr/DSCF
gr/ACF
Ib/hr
Ib/ton
0.0047
0.0032
0.23
0.0044

NR
NR
NR
NR
0.0061
0.0041
0.30
0.0057

NR
NR
NR
NR
0.0038
0.0025
0.18
0.0034

NR
NR
NR
NR
0.0049
0.0033
0.24
0.0045


*•
—

  NR - Not Reported
                                          C-23

-------
                                       Table  C-lb
                                       FACILITY A
                              SUMMARY OF VISIBLE EMISSIONS
Date:  March 18, 1975
Type of Plant:  Phosphate Rock Dryer
Type of Discharge: Stack from scrubber
Location of Discharge: Top of stack
Height of Point of Discharge: 96 feet
Description of Background: Gray sky
Description of Sky: Overcast
Hind Direction: East
Color of Plume:- White
Interference of Steam Plume: Yes •
Duration of Observation: 3 nours, 9 minutes
       SUMMARY OF AVERAGE OPACITY
Distance from Observer to Discharge  Point:
                              2000  feet

Height of Observation Point: Ground  level
Direction of Observer from Discharge Point:
                              Nortnwest
Wind Velocity:
Detached Plume:
                 No
     SUMMARY OF AVERAGE OPACITY
Time
Set Number Start End
1 9:00 9;06
2 *
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
13
19
20
Opaci ty
Average
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Time
Set Number Start End
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Opaci ty
Average
0
0
0
0
0 .
u
0
0
0
0










  Subsequent sets were each of 6-minutes  duration, and there were no time lapses  between
   sets.
                                            C-24

-------
                                          Tablo C-15, continued.
                            SKETCH SHOWING HOW OPACITY VARIED WITH TIME-
g  10
a.
O
s


0
                                         234
                                             TIME, hours
                                        C-25

-------
                                      Table C-16
                                      FACILITY A
                             SUMMARY OF VISIBLE EMISSIONS
Date:  March 18, 1975
Type of Plant:  Phosphate roc* dryer
Type of Discharge:  Stack from scrubber
Location of Discharge:  Top of stack
Height of Point of Discharge:  96 feet
Description of Background:  Cloudy sky
Description of Sky:  Cloudy
Wind Direction:  South-West
Color of Plume:  White
Interference of Steam Plume:  Yes
Duration of Observation:  2 hours, 2£ minutes
            SUMMARY OF AVEPvAGE OPACITY
Distance from Observer to Uisciiarge Point:
                                 luuu
Height of Observation Point:  Ground level
Direction of Observer from Jiscnarge Point:
                              ilorth-'.fest
Wind Velocity:
Detached Plume:
                             mi/rir
                 No
         SUMMARY OF AVERAGE OPACITY
Ti nie
Set dumber Start End
1 4:22 4:28
2 *
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Opacity
Average
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Time Opacity
Set Number Start End Average
21 0
22 0
23 u
24 . • 0
2s • 0















* Subsequent sets were each of 6-minute durations, and there were no time lapses
  between sets.
                                          C-26

-------
                                         Table C-16, continued.
                            SKETCH SHOWING HOW OPACITY VARIED WITH TIME:
   15
   10
o.
s-"
                                         2                 3
                                             TIME, hours
                                   C-27

-------
                                       Table   C-17
                                       FACILITY A
                              SUMMARY OF VISIBLE EMISSIONS
Date:  March 19, 1975
Type of Plant:  Phosphate rock dryer
Type of Discharge:  Stack from scrubber
Location of Discharge: Top of stack
Height of Point of Discharge:  96 feet
Description of Background:  Blue sky
Description of Sky:  Clear
Wind Direction:  Vlest Northwest
Color of Plume:  White
Interference of Steam Plume:  Yes
Duration of Observation:  2 hours, 51 minutes
       SUMMARY OF AVERAGE OPACITY
Distance from Observer to Discharge Point:
                                 100 feet
Height of Observation Point: Ground level
Direction of Observer from Discharge Point:
                                   Soutn

Wind Velocity:  15-30
Detached Plume:  No
     SUMMARY OF AVERAGE OPACITY

Set Number
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
. 17
18
19
20
Time Opacity
Start End Averaqe
11:30 11:36 0
* ' 0
0
0
0
0
0
0
0
0
0
0
0
0
0
• o
0
0
0
0
Time
Set Number Start End
21
22
23
24
25
26
27
28










"

Opaci ty
Averaqe
0
0
0
0
0
0
0
0












 * Subsequent sets were each of 6-minutes duration, and there:were no time  lapses
   between sets.
                                           C-28

-------
                                         Tibia C-17, continued.
                            SKETCH SHOWING HOW OPACITY VARIED WITH TIME:
  15
V
&
                                         2                 3
                                             TIME, hours
                                          C-29

-------
                                       Table  C-18
                                       FACILITY  B
                              SUMMARY OF VISIBLE EMISSIONS *
Date:  March 20, 1975
Type of Plant:  Phosphate rock dryer
Type of Discharge: Stack from electrostatic
Location of Discharge:  Stac*     precipitat
Height of Point of Discharge: >£#90 feet
Description of Background:  Blue sky
Description of Sky:  Clear
Wind Direction:  West
Color of Plume: White
Interference of Steam Plume:  Yes
Duration of Observation: 2 hours, 15 minutes
       SUKMARYOF AVERAGE OPACITY
Distance from Observer to Discharge Point:
                                    feet
Height of Observation Point: Ground level
Direction of Observer from Discharge Point:
                             South Soutueast
Wind Velocity:  8
Detached Plume:

Set Number
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Time Opacity
Start End Averaqe •
2:00 2:06 5.0
** 7.7
6.7
5.0
5.8
6.7
7.1
5.0
5.4 .
5.6
5.6
5.0
5.0
4.6
5.0
5.0
' 5.0
5.0
4.6
5.0
Time
Set Number* Start End
21
22
23
24
25
26
27
28
29
30
31
32
33
34
' 35
36
37
38
39
40
Opacity
Average
5.0
6.9


















  *Four observers  made  simultaneous readings (two observers for each  of two stacks).  The
   greatest of their readings is reported.
 **Subsequent sets were each of 6-minutes duration, and there were  no time lapses
   between sets.
                                          C-3U

-------
                            Table C-18, continued.
                   SKETCH SHOWING HOW OPACITY VARIED WITH TIME:
3
15

«

 5
 .
     DIM
                            2             34
                               TIME, hours
                         C-31

-------
                                       Table  c-19
                                       FACILITY  B
                              SUMMARY OF VISIBLE EMISSIONS*
Date:  March 20, 1975
Type of Plant:  Phosphate rock dryer
Type of Discharge:  Stack from electrostatic
Location of Discharge: Top of stacRreclp
Height of Point of Discharge:^9° feet
Description of Background:  Clear blue sky
Description of Sky:  Clear
Wind Direction:  Northeast
Color of Plume: White
Interference of Steam Plume:  Yes
Duration of Observation:  2 hours
Distance from Observer to Discharge Point:
                                150 feet
Height of Observation Point:  Ground level
Direction of Observer from Discharge Point:
                           South Southeast

Wind Velocity: 10
Detached Plume: Yes
SUMMARY

Set Number
1
2
3
4
5
6
7
8
9
10
Tl
12
13
14
15
16
17
18
19
20
OF AVERAGE OPACITY
Time Opacity
Start End Average
5:17 5:23 3.8
** ' ' 4.6
2.3
2.9
1.0
3.1
1.7
0.8
0.6
0.8
0.4 '
2.1
2.9
1.2
0
0
0
0
0
0
SUMMARY OF AVERAGE
Time
Set Number Start End
21
22
23
24
25
26 '
27
28
29
30
31
32
33
34
35
36
37
38
39
. 40
OPACITY
Opacity
Average
0
0


















 *Four observers made simultaneous readings  (two  observers for each ;of two stacks).  Trie
  greatest of their readings is reported.
**Subsequent sets were each of 6-minutes duration,  and  there were no time lapses between
  sets.
                                           Cr32

-------
                                Table C-H9, continued.
                       SKETCH SHOWING HOW OPACITY VARIED WITH TIME:
  15





| 10

S
a


>  5
     niiiiiiiiiiiiiiii
                                  2              3


                                     TIME, hours
                                  C-33

-------
                                         Table C-20
                                         FACILITY B
                                SUMMARY OF VISIBLE EMISSIONS *
  Date:  March 24,  1975
  Typ& of Plant:  Phosphate  rock  dryer
  Type of Discharge:  Stack from electrostatic
                 3                 preci pita tor
 • Location of Discharge:  Stack
  Height of Point of  Discharge:   90  feet
  Description of  Background:  Cloudy  sky
  Description of  Sky:-  Partly cloudy
  Wind Direction:   Southwest
  Color of Plume: White
  •Interference of Steam Plume: Yes
  Duration of Observation:   103 minutes, 15 seconds
Distance from Observer to Discharge Point:
                         .   120 feet
Height of Observation Point: Ground level
Direction of Observer from Discharge Point:
                         Southeast
Wind Velocity:
Detached Plume:
                No
5UMWU

Set Number
- 1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Of OF AVERAGE OPACITY
Time Opacity
Start End Averaqe
1:05 1:11 4.8
** ' 4.8
4.0
4.5
4.4
4.7
5.2
4.8
4.6
4.8
2.9
4.0
3.8
3.9
4.0
4.2
0
4.0


SUMMARY OF AVERAGE
	 	 Time
Set Number Start End
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
OPACITY 	
	 Opacity
Averaqe



*•
















 *Four observers made simultaneous  readings  (two observers for each of two stacks).  The
  greatest of their readings  is  reported.
**Subsequent sets were each of 6-minutes duration, and there were no time lapses between
  sets.
                                           C-34

-------
                            Table C-20, contimMd.
  15

| 10
I
>  5
o
i  0
jii
                 SKETCH SHOWING HOW OPACITY VARIED WITH TIME:
                           2              3
                              TIME, hours
                             C-35

-------
                                        Table C-21
                                        FACILITY C
                               SUMMARY OF VISIBLE EMISSIONS*
 Date: APr1l  4,  1975
 Type of Plant:   Phosohate  rock calciner
 Type of Discharge:  participate
 Location of Discharge:  Stack *rom scrubber
 Height of Point of Discharge:  105 feet
 Description of Background: Sky
 Description of Sky:    Overcast
 Hind Direction:  North
 Color of Plume:  white
 Interference of Steam Plume:  Yes
 Duration of Observation:  2 hours, 5 minutes
Distance from Observer to Discharge Point:
                         .   1440 feet
Height of Observation Point:Ground level
Direction of Observer from Discharge Point:
                           South Southeast
Wind Velocity: 3-10
Detached Plume: No
SUMMA1

Set Number
1
2
3
4
5
6
7
8
9
10
n
12
13
14
15
16
17
18
19
20
*Y OF AVERAGE OPACITY
Time Opacity
Start End Averaqe
2:50 2:56 0
** 0
0
' ' 0
0
0
0
• o
0
0
0
0
0
0
0
0
0
0
0
0
' 	 SUMMARY OF AVERAGE OPACITY
• 	 Time 	 Opaci ty 	
Set Number Start End Average
-21
22 .
23
24
25
26
27
28
29
30
31
32
33
34
'35
36
37
38 -
39
40
 *Two observers made simultaneous  readings.  The greater of their readings  is  reported.
**Subsequent sets were each  of 6rm1nutes duration, and there were no time lapses between
 sets.               .          .

-------
                                       Tattle C-21, continued.
                         SKETCH SHOWING HOW OPACITY VARIED WITH TIME:
15

10

 5
                                      2                 3
                                          TIME, hours
                                      C-37

-------
                                        Table C-22
                                        FACILITY  C
                               SUMMARY  OF VISIBLE  EMISSIONS *
 Date:  April 5, 1975
 Type of  Plant:  Phosphate rock calciner
 Type of  Discharge:  Participate
 Location of Discharge:  Stack  from scrubber
 Height of Point of  Discharge:  105 feet
 Description of Background:  Sky
 Description of Sky:   Overcast
•Hind Direction:   South
 Color  of Plume: White
 Interference of Steam Plume:   Yes
 Duration of Observation:  2 hours, 5 minutes
       SUMMARY OF AVERAGE OPACITY
Distance from Observer to Discharge Point:
                             600 feet

Height of Observation Point:Ground leve1
Direction of Observer from Discharge Point:
                                     East
Wind Velocity: 15-2b
Detached Plume: No
     SUMMARY OF AVERAGE OPACITY
Time
Set Number Start End
1 8:45 9:01
2 **
3
4
5
6
7
3
9
10
11
12
13
14
15
16
17
18
19
20
Opaci ty
Averaqe
0
0
0
0 .
0
0
0
0
0
0
o •
0
0
0
0
0
0
0
0
0
Time Opacity
Set Number Start End ' Average
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37 '
38
39
40
 *Two observers made simultaneous  readings.  The greater of their readings is reported.
**Subsequent sets were each  of 6-minutes  duration, and there were no time lapses between
  sets.
                                           C-38

-------
                                        Table C-22, continued.
                             SKETCH SHOWING HOW OPACITY VARIED WITH TIME:
s
o>
a.



«3
   15



   10
                                          Z                 3

                                              TIME, hours
                                        C-39

-------
                                       Table C-23
                                       FACILITY  C
                              SUMMARY OF VISIBLE EMISSIONS *
Date:April 9, 1975
Type of Plant:" Phosphate rock calciner
Type of Discharge: Participate
Location of Discharge: Stack from scrubber
Height of Point of Discharge: 105 feet
Description of Background: Snowy sky
Description of Sky:   Overcast
Wind Direction: South
to!or of Plume: White
Interference of Steam Plume: Yes
Duration of Observation:  1 hour, 45 seconds
       SUMMARY OF AVERAGE OPACITY
Distance from Observer to Discharge Point:
                                 1/4 mile
Height of Observation Point: Ground le.val
Direction of Observer from Discharge  Point:
                              Southeast
Wind Velocity: 5-20
Detached Plume: I>)0
     SUMMARY OF AVERAGE OPACITY

Set Number
1
2
3
4
5
6
7 •
8
9
10
11
ia
13
14
15
16
17
18
19
20
Time Opacity
Start End Average
8:50 8:56 0
** • 0
0
0
0
0
0
0
0
0










Time
Set Number Start End
21
22
23 ,.
24
25
26
.27
28 '
29
30
31
32
33
34
35
36
37
38
39
40
Opaci ty
Average




















    *Two  observers made simultaneous readings.  The greater of their readings  is reported.
   **Subsequent  sets were each of 6-minutes duration, and there were no  time lapses between
     sets.
                                             C-40

-------
                                         Table C-23, continued.
                             SKETCH SHOWING HOW OPACITY VARIED WITH TIME:
   15



I  10
u
£


is
cj
                                         2                 3

                                             TIME, hours
                                   C-41

-------
                                        Table C-24
                                        FACILITY C
                               SUMMARY OF VISIBLE EMISSIONS *
 Date: April 9, 1975
 Type of Plant: Phosphate rock calciner
 Type of Discharge: Particulate
. Location of Discharge: Stack from scrubber
 Height of Point of Discharge: 105 feet
 Description of Background:   skV
 Description of Sky: Overcast
 •Hind Direction: South
 Color of Plume: VJh1te
 Interference of Steam Plume:  Yes
 Duration of Observation: 2 Hours, 0 minutes
        Cf
Distance from Observer to Discharge Point:
                              1440 feet
Height of Observation Point: Ground level
Direction of Observer from Discharge Point:
                              Southeast
Wind Velocity:  2-3
Detached Plume: Ho
     SUMMARY OF AVERAGE OPACITY

Set Number
1
2
3
d
t
5
6
7
*
8
9
10
11
1 l
12
13
14
15
16
17
18
19
I «*
20
	 Time 	 Opacity
	 Start End Average
5:00 5:06 0
** • o
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Time
Set Number Start End
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Opacity
Averaqe




















      sets.

                                               C-42

-------
                                        Table C-24, continued.
                            SKETCH SHOWING HOW OPACITY VARIED WITH TIME-
5  10
0.
                                         2                 3
                                             TIME, hours
                                     C-43

-------
                                        Table C-25
                                        FACILITY  C
                               SUMMARY OF VISIBLE EMISSIONS*
 Date: April 10, 1975
 Type of Plant:  Phosphate Rock Calciner
 Type of Discharge:  Particulate
 Location of Discharge:  Stack from Scrubber
 Height of Point of Discharge:  los feet
 Description of Background:  Sky
 Description of Sky: Overcast
 Hind Direction: East
'Color of Plume: White
 Interference of Steam Plume:  Yes
 Duration of Observation: 2 hours 0 min
        SUMMARY OF AVERAGE OPACITY
Distance from Observer to Discharge Point:
                               1440 feet
Height of Observation Point: Ground Level
Direction of Observer from Discharge Point:
                               Southeast
Wind Velocity:  2 to 5
Detached Plume:  No
     SUMMARY OF AVERAGE OPACITY

Set Number
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Time Opacity
Start End Average
7:30- 7:36 0
** 0
0
0
0
0
0
0
0
0 .
0
0
0
0
0
0
0
0
0
0
Time
Set Number Start End
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Opaci ty
Average




















  *  Two observers made simultaneous  readings.  The greater of their readings is reported.
 **  Subsequent sets were each of 6 minutes  duration, and there were no time lapses between
     sets.
                                             C-44 '

-------
                                       Table C-25, continued.
                          SKETCH SHOWING HOW OPACITY VARIED WITH TIME:
15
10
                                      234
                                          TIME, hours
                                       C-45

-------
                                       Table C-26
                                       FACILITY C
                              SUMMARY OF VISIBLE EMISSIONS *
Date:  April 10,  1975
Type of Plant:  Phosphate Rock  Caldner
Type of Discharge:  Participate
Location of Discharge:  Stack from  Scrubber
Height of Point of Discharge:  105  feet
Description of Background:   Sky
Description of Sky:  Overcast
•Hind Direction:   North
Color of Plume:   White
Interference  of Steam Plume:   Yes
Duration of Observation:  3 hours 0 min
Distance from Observer to Discharge Point:
                               1400 feet
Height of Observation Point:   Ground Level
Direction of Observer from Discharge Point:
                               Southeast
Wind Velocity:  0 to 16
Detached Plume:  No
                                                      SUMMARY OF AVERAGE OPACITY

Set Number
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
	 Time 	 Qpaci ty
Start End Average
10:45 10;51 0
** ' o
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Time
Set Number Start End
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Opaci ty
Averaqe
0
' 0

n
u
o
w
o
\J
0
\J
fl
U










   *  Two observers made  simultaneous reaoings.  me greater of their  readings 1s reported.
  **  Subsequent sets were  each of 6 *toutes duration, and there were  no  time lapses between
      sets.
                                            C-46

-------
   15






I  10
U

OJ
m.


>   5






I  a
                                           TaWt C-26, continusd.
                             SKETCH SHOWING HOW OPACITY VARIED WITH TIME:
                                            TIME, hours
                                          C-47

-------
                                       Table C-27
                                       FACILITY F
                              SUMMARY OF VISIBLE EMISSIONS *
Date:   March  25,  1975
Type of Plant:  Phosphate  Rock  Grinder
Type of Discharge:  Stack  from  Baghouse
Location of Discharge:  T°P of  stack
Height of Point of Discharge:  75 feet
Description of Background: Brown, Rusty  Conveyor
Description of Sky:  Overcast
Hind Direction:  Not Reported
Color of Plume:  White
Interference  of Steam Plume:  No
Duration of Observation:  2 hours 14 min
Distance from Observer to Discharge Point:
                                50 feet
Height of Observation Point:   85 feet
Direction of Observer from Discharge Point:
                                East
Wind Velocity:  Not Reported
Detached Plume:  No
SUMMARY

Set Number
1
2
c*
3
4
5
w
6
w
7
/
8
W
g
10
11
t I
12
13
14
15
16
17
18
19
V J
20
OF AVERAGE OPACITY
Time Opacity
Start End Average
12:30 12:36 0
** ' 0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
SUMMARY OF AVERAGE
Time
Set Number Start End
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
OPACITY
Opaci ty
Average
0



















  * Two observers made simultaneous readings.  The greater of their  readings is reported.
 ** Subsequent  sets were each of 6 minutes duration, and there were  no  time lapses between sets
                                            C-48

-------
                                          Table C-27, continued.
   15

| 10
!
£  5
u
i  0
                             SKETCH SHOWING HOW OPACITY VARIED WITH TIME:
                                         2                 3                 4
                                             TIME, hours
                                      C-49

-------
                                     Table C-28
                                     FACILITY F
                            SUMMARY OF VISIBLE EMISSIONS *
 Date:   March 25,  1975
' Type of Plant:  Phosphate Rock Grinder
 Type of Discharge:  Stack from Baghouse
• Location of Discharge:  Top  of Stack
 Height  of  Point of  Discharge: 75  feet
 Description of Background: Brown, Rusty
 Description of Sky: Partly Cloudy
 •Hind Direction:  Northwest
 Color of Plume:  White
 Interference of Steam Plume: No
 Duration of Observation:  2 hours  0 min
                                               Distance from Observer to Discharge Point:
                                                                              50 feet
                                               Height of Observation Point:  90 feet
                                       Conveyor Direction of Observer from Discharge Point:
                                                                              East
                                               Wind Velocity:  10
                                               Detached Plume:  No
                                                     SUMMARY  OF AVERAGE  OPACITY

Set Number
1




7
/
g
10
11
-.11
12
13
14
15
16
17
18
19
20
	 Time 	 Qpaci ty
Start End Average
5:00 5:06 0
** 0
0
o
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Time
Set Number Start End
21
22
23
24
25 ,
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Ooacitv
Averaae










  .  Two observers -id. staltaneous readings.   The greater of their readings 1s reported.
.«  Upsets «« each of 6 »1»Utes .-ration,  and  there ..re no «.. Upses between
     sets.

-------
   15
tt
a
                                          Table C-28, continued.
                            SKETCH SHOWING HOW OPACITY VARIED WITH TIME:
                                        2                 3

                                            TIME, hours
                                         C-51

-------
                                       Table C-29
                                        FACILITY F
                               SUMMARY OF VISIBLE EMISSIONS*
 Date:   March 26, 1975
 Type of Plant:  Phosphate Rock Grinder
 Type of Discharge: Stack from Baghouse
 Location of Discharge: Top of Stack
 Height of Point of Discharge: 75 feet
 Description of Background: Off-white Building
 Description of Sky: Clear
•Wind Direction: Northeast
 Color  of Plume:  White
 Interference of Steam Plume:  No
 Duration of Observation:  2 hours 0 min
        SUMMARY OF AVERAGE OPACITY
Distance from Observer to Discharge Point:
                              50 feet
Height of Observation Point:   85 feet
Direction of Observer from Discharge Point:
                              East
Wind Velocity:  15  to 25
Detached Plume:  No
     SUMMARY OF AVERAGE OPACITY

Set Number
1
2
3
w
4
5
6
7
8
9
•TO
n

13
14-
15
16
17
18
19
20
Time Opacity
Start End Average
11:00 11:06 0
** . 0
0
0
0
0
0
0
0
0
0
o
0
0
0
0
0
0
0
0
Time
Set Number Start End
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Opaci ty
Average
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0




   *  Two  observers made simultaneous readings.  The greater of their  readings is reported.
  **  Subsequent sets were each of 6 minutes duration, and there were  no  time lapses between
      sets.
                                              C-52

-------
                                           T«We C-29, continued.
   15
 S
 a.
i   o
                            SKETCH SHOWING HOW OPACITY VARIED WITH TIME:
                                        2                 3

                                            TIME, hours
                                C-53

-------
                                        Table  C-30
                                        FACILITY 6
                               SUMMARY OF VISIBLE EMISSIONS *
 Date: April 5, 1975
 Type of Plant: Phosphate Rick Grinder
 Type of Discharge:  Particulate
- Location of Discharge:  *«* f™ Ba9house
 Height of Point of Discharge:  46 feet
 Description of Background:  Dark Building
 Description of Sky: Overcast
 Wind Direction:   South
 Color of Plume:  None
 Interference  of  Steam Plume:   No
 Duration of Observation:  3 hours  0 min
Tim? Opacity ,.._,,. 	 £
Set Number
1

3
4




8
10
n
12
13
14
15
16
17
18
19
20 '
Start End Averaqe
4:00 4:06 0
** • o
o
0
0
0
0
o
0
0
0
0
0
0
0
0
0
0
0
0
Set Number Start
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Distance from Observer to Discharge Point:
                               270 feet

Height of Observation Pdlnt: Around Level
Direction of Observer from Discharge Point:
                               East

Wind Velocity: 4 to 20
Detached Plume: No
                                                        SUMMARY  OF AVERAGE OPACITY
                                                                                Opacity
                                                                                   0
                                                                                   0
                                                                                   0
                                                                                   0
                                                                                   0
                                                                                   0
                                                                                   0
                                                                                   0
                                                                                   0
                                                                                   0
   *  Two observers made simultaneous readings.   The greater el their  readings is reported.
  **  Subsequent sets were each of 6 minutes duration, and there was a 16 minute lapse
      (6:44 to 7:00) in readings during a plant malfunction.
                                                C-54

-------
                                         Tablo C-30, continued.
                            SKETCH SHOWING HOW OPACITY VARIED WITH TIME:
   15


1  10
I
>   5
                                         2                 3
                                             TIME, hours
                                          C-55

-------
                                      Table  C-31
                                      FACILITY  6
                              SUMMARY  OF VISIBLE EMISSIONS  *
Date:   April  7,  1975
Type of Plant: Phosphate  Rock Grinder
Type of Discharge:  Participate
Location of Discharge:  Duct from Baghouse
Height of Point of Discharge: 46 feet
Description of Background:  Dark Building
Description of Sky:   Overcast
•Mind Direction:   Korthwest
Color of Plume:   None
Interference  of  Steam Plume: No
Duration of Observation:  3  hours 20 min
        SUMMARY OF AVERAGE OPACITY

Set Number
1 '
2
3
4
S
6
7
8
9
10
11
12
13
14
15
16
T7
18
19
20
Time Opacity
start End Average 	
9:25 9:31 0
** 0
0
0
w
n
u
n
\j
o
o
0
0
o
\J
n
V
0
o
V
0
V
n
\J
n
\j
o
\J
o
w
0
.
Set Nun
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
  Distance from Observer to  Discharge  Point:
                                 270 feet
  Height of Observation Point:  Ground  Level
  Direction of Observer from Discharge Point:
                                 East
  Wind Velocity:  7 to  15
  Detached Plume:  No
        SUMMARY  OF  AVERAGE OPACITY,
                   Time	Opacity
s»t Number     Start  End,	Average
                                  0
                                  0
                                 •o
                                  0
                                  0
                                  0
                                  0
                                  0
                                  0
                                  0
                                  0
                                  0
                                                                                           ,.„,
                                               C-56

-------
                                          Table C-31, continued.
   15
 s  10
o •

I   0
                          .   SKETCH SHOWING HOW OPACITY VARIED WITH TIME:
                                         2                 34
                                             TIME, hours
                                       C-57

-------
                                        Table C-32

                                        FACILITY 6

                               SUMMARY OF VISIBLE EMISSIONS *
 Date:  April 7, 1975
 Type of Plant:  Phosphate Rock Grinder
 Type of Discharge:  Participate
> Location of Discharge: Duct from Baghouse
 Height of Point of Discharge:  46 feet
 Description of Background:  Dark Building

 Description of Sky:   Overcast
 Hind Direction:   Northwest
 Color of Plume:   None
 Interference  of Steam Plume:  No
 Duration of Observation:  3 hours 20 min
Distance from Observer to Discharge Point:
                               275  feet
Height of Observation Point:  Ground  Level
Direction of Observer from Discharge Point:

                               Northeast

Wind Velocity:  5 to 13
Detached Plume:  No
                                                        SUMMARY  OF  AVERAGE  OPACITY
                                                                                Opacity
sunriHf
Set Number
1

•3
«j
A
T
c
3
£
o
7
8
9
10
11
12
13
14
15
16
17
18
10
t y
20
Time Opacity
Start End Averaqe
3:20 3:26 0
** • 0
fl
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Time
Set Number Start End
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
                                                                                Average

                                                                                  0
                                                                                  0
                                                                                  0
                                                                                  0
                                                                                  0
                                                                                  '0
                                                                                  0
                                                                                  0
                                                                                  0
                                                                                  0
                                                                                  0
                                                                                  0
   *  Two observers made simultaneous  readings.  The greater of their readings is reported.
  **  Subsequent sets were each  of 6 minutes duration, and visible emissions measurements were
      curtailed for twenty minutes (from  5:51 to 6:11) during a plant malfunction.
                                                 C-58

-------
                                           Table C-32, continued.
   15
£ 10
u
                            SKETCH SHOWING HOW OPACITY VARIED WITH TIME:
                                        2                 3

                                            TIME, hours
                                          C-59

-------
                                       Table   C-33
                                       FACILITY  H.
                               SUMMARY  OF VISIBLE EMISSIONS *
 Date: March 26, 1975
 Type of PIant:  Materials Hand! 1ng
 Type of Discharge: Particulate
. Location of Discharge: Baghouse Stack
 Height of Point of Discharge:   ISO feet
 Description of Background:   Green Trees
 Description of Sky:  Clear
 Hind Direction:   Northeast
 Color of  Plume:   White
 Interference  of Steam Plume:  No
Distance from Observer to Discharge Point:
                               75  feet
Height of Observation Point:     150 feet
Direction of Observer from Discharge Point:
                       South-Southwest

Mind Velocity:  5
Detached Plume:  No
UUrauiuu ui uu:
SUMMARY

Set Number
1

3


6

8
9
10
n
12
13
14
15
16
17
18
19
20
nF AVERAGE OPACITY _
Time Ooacity 	
Start End Averaqe
3:00 3:06 0
** ' 0
n
w
0
0
o
V
0
o
w
o
o
\f
0
\J
o
w
o
\J
n
w
n
w
n
w
n
\j
n
\j
n
V
n
u
SUMMARY OF AVERAGE OPACITY 	
Set Number Start ^d ' Averaqe
• 21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40

     -
                                                                      -
                                                                                    between
                                              C-60

-------
                                        TaWe C-33, continued.
                          SKETCH SHOWING HOW OPACITY VARIED WITH TIME:
15

10

 s

 0
                                     2                 3
                                         TIME, hours
                                     C-b'I

-------
                                       Table  C-34
                                       FACILITY  I
                               SUMMARY  OF VISIBLE EMISSIONS  *
 Date: March 25, 1975
 Type of Plant:  P™und rock transfer
 Type of Discharge: Stack from baghouse
• Location of Discharge: Top of stack
 Height of Point of Discharge: 100 feet
 Description of Background: Dark gray overcast
 Description of Sky:   Overcast
-Wind, Direction: West
 to!or of Plume:  Wnite
 Interference of Steam Plume: No
 Duration of Observation:  1 hour, 0 minutes
                                             Distance from Observer to Discharge Point:
                                                                          300  feet
                                             Height of Observation Point: 30 feet
                                             Direction of Observer from Discharge Point:
                                                                          North

                                             Wind Velocity:  10
                                             Detached Plume: No   .
SUMMAF
Set Number
1

3
4
5
p.
7
a
g
10
11
12
13
14
15
is
17
IB
19
20
Time Opacity
Start End Average
3:17 3.:23 0
** 0
0
0
0
0
0
. 0
0
0






Time Opacity
Set Number Start End Average 	
21
22
23
25
26
27
28
29
30
31
. 32
33
34
35
36
37
38
39
40
 *Two observers made  simultaneous readings.  The greater of
Subsequent sets were  each   of 6-minutes duration, and there were
  sets .
                                                                              {*         een
                                                                              lapses between
                                                 C-62

-------
                                       Table C-34, continued.
                          SKETCH SHOWING HOW OPACITY VARIED WITH TIME:
15

10

 5

 0
                                      2                 3
                                          TIME, hours
                                  C-63

-------
                                        Table C-35
                                        FACILITY J
                               SUMMARY OF VISIBLE EMISSIONS *
 Date: March 25, 1975
 Type of Plant: Ground rock transfer
 Type of Discharge: Stack from baghouse
. Location of Discharge:T°P of stack
 Height of Point of Discharge: 12° feet
 Description of Background: Gray sk^
 Description of Sky: Overcast
'Hind Direction:   Northwest
 Color of Plume: White
 Interference of Steam Plume: ;^°
 Duration of Observation:  1  hour, 0 minutes
Distance from Observer to Discharge Point:
                                   150 feet

Height of Observation Point: 75 feet
Direction of Observer from Discharge Point:
                             Nortnwest
Wind Velocity: 10
Detached Plume: H
                                                       SUMMARY OF AVERAGE OPACITY

Set Number
1
2
3
4
~
5
6
7
1
8
9
10
n
12
13
14
15
16
17
18
19
20
Time Ooacitv
Start End Averaqe
4:45 4:51 0
** 0
0
a
0
0
0
0
0
0
0 '









Time Ooacitv
Set Number Start End Averaae .
21
22
23
24
25
26
27
28
29
30
31
32
33
A ft
34
35
36
37
38
39
40
    *Two observers  made  simultaneous readings.  The greater of their readings  is  reported.
   **Subsequent sets  were each of 6-minutes duration, and there were no time  lapses between
     sets.                     .          .
                                               C-64

-------
                                          Table C-35, continued.
                            SKETCH SHOWING HOW OPACITY VARIED WITH TIME:
   15



|  10
Oi
a.


I   5

1   o
                                         2                 3

                                             TIME, hours
                                         C-65

-------
                                       TABLE  C-36
                                       FACILITY K
                             Summary of Visible Emissions
  Date:  June 22, 1976
  Type of Plant:  Phosphate rock calciner
  Type of Discharge:  Stack from scrubber
  Location of Discharge:  Top of stack
  Height of Point of Discharge:  150 feet
  Description of Background:  Sky
  Description of Sky:  Partly cloudy
  Wind Direction:  Northeast
  Color of Plume:  White
  Duration of Observation:  1 hour 0 minutes
                SUMMARY OF AVERAGE OPACITY
Distance from Observer to Discharge Point:
                             200 yards
Height of Observation Point:  Ground level
Direction of Observer from Discharge Point:
                             Northwest
Wind Velocity:  15-20 MPH
Detached Plume:  Yes
                /

                - SUMMARY OF AVERAGE OPACITY
Time
Set Number Start End
1 2:00 2:06
2 *
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Opacity
Average
0.83
0
0
0
0
0
0
0
0
0










Time Opacity
Set Number Start End Average
21
22
23
24
•"" 25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
* Subsequent sets were each of 6 minutes duration,  and. there were  no  time  lapses  between  sets.
                                           C-66

-------
                                       Tiblt C-36, continued.
                         SKETCH SHOWING HOW OPACITY VARIED WITH TIME:
15

10

 5
                                      2                 3
                                          TIME, hours
                                           C-67

-------

-------
           APPENDIX D.  EMISSION MEASUREMENT AND CONTINUOUS MONITORING
 D.I  Emission' Measurement Mathods
      For the phosphate rock processing industry, the Environmental Protection
 Agency relied on Method 5 for measuring particulate emissions, Method 9 for
 measuring visible emissions, and Method 138 for fluoride emissions.  These
 methods were used as described in Appendix A of 40 CFR Part 60 and published
 1n the Federal  Register (December 23, 1971 and October 23, 1974).
      The particulate mass catches from these process emissions were relatively
 low, especially for the baghouse controlled emissions.   The mass catch amounts
 ranged from about 12 mg to over 300 mg.  For the particularly low concentra-
 tions, some tests were extended to over 3 hours in an effort, to obtain
 accurately measurable catches.  In-house tests have shown that acceptable
 accuracy (j^ 10/0 can be obtained with a minimum catch of 25 mg.   Most of the
 inaccuracy at this level  and lower is found on the high side of the measure-
 ment; that is,  somewhat more mass is measured than is actually collected.
      Visible emission readings were made difficult because of high moisture
 content of scrubber exhausts from several  of the processes.   In  most cases,
 opacity readings were made at the leading  edge of the steam plume.
 D.2  Continuous  Monitoring
      Effluent gas from the phosphate rock  processes  are not  excessively  hot
 (less than  121°  C or 250°F),faut can contain fluorides that may react
with water to form acids that would etch, glass materials.  Glass  lenses
 on  opacity monitoring equipment should  either  be protected from fluoride
 deposits  or  replaced  with  material  not  subject to  etching.  Visible emission
                                     D-l

-------
monitors are covered by EPA performance standards contained is Appendix B
                     «
of 40 CFR Part 60 (Federal Register. September 11, 1974).
     Equipment and installation costs are estimated to be $18,000 to $20,000
and annual operating costs, including data recording and reduction, are
estimated at $8,000 to $9,000.
D.3  Performance Test Methods
     The performance test method  recommended  for  particulate matter is
Method  5.   Because of the construction  of  some control equipment, special
stack extensions may be  required  to obtain acceptable sampling conditions.
                                               ;
Low  particulate concentrations  in the  stack  gases from fabric collectors
necessitate longer  sampling  times and  larger sample  volumes.  The recommended
minimum sampling  volume  is  4.5  dsm3 (160 dscf).   Commercially available  high
 volume  sampling  trains  conforming to Method  5 specifications would  allow tests
 of shorter duration while obtaining the minimum sample  volume,  thus reducing
 time and expense of tests.
      Sampling costs for a test consisting of 3 particulate runs is  estimated
 to be about $5,000 to $9,000.  This estimation is based on the  sampling site
 modifications such as ports, scaffolding, ladders, and extensions costing
 from $2,000 to $4,000 and testing  being conducted by contractors.  If in-plant
 personnel are used to conduct  the  tests, the costs will  be somewhat less.

      Method 9 is  recommended for visible emissions.
                                     D-2

-------
                 APPENDIX E.  ENFORCEMENT ASPECTS

  E.I.   GENERAL
        The recommended standards of performance will  limit emissions
  of particulates  and visible emissions  from phosphate rock dryers,
  calciners,  grinders and  ground  rock transfer systems  at phosphate  rock
  Plants.   The  control  systems which  can be  installed  to comply with these
  standards are scrubbers, fabric filters, electrostatic precipitators, or
  a combination of these.  The control system may serve one or several
 affected facilities simultaneously.  Aspects of enforcing these standards
 are discussed below for each affected facility.
 E.2.  DRYERS
      Factors affecting the  level of uncontrolled emissions from phosphate
  rock dryers include the design and operation of the dryer and the type of
 rock being dried.  The effect of process design and operation on uncontrolled
 ennssions is discussed in Chapter 3.  The operator usually has  little control
 over the design of the dryer after it is installed, and operation during:a
 compliance test should be no.different than the way the process  is  normally
 operated.   The compliance test should  be  performed  while the dryer  is opera-
ting at the maximum  production rate at which it is expected to run in
the future, which may be greater than design parameters indicate.  As  stated
1n the facility descriptions in Appendix C, dryers are designed for a
certain degree of moisture removal, and production at this  moisture removal
                                  E-l

-------
rate will be a function of the characteristics of the feed to the dryer.
Generally, production throughput at a constant moisture removal rate
will be greater for small, dry feed than for large, wet feed.  The.
enforcement official should therefore be more concerned with  the heat
Input  (fuel addition rate) to the  dryer than the production  throughput.
          *
Some dryers are designed  to bum more than one  type of  fuel  (i.e.,
natural  gas or fuel oil). In  these cases, emissions from the dryer
should be sampled while  the  dryer is burning  the dirtiest fuel  it will
burn in the future.   An exception to this  would occur if the dryer is
designed to burn one fuel, such as natural gas, during normal operation,
 but can use an alternate fuel, such as fuel oil, when the cleaner fuel
'is not available.  In these cases, the dryer should be tested during
 normal conditions (e.g., burning  natural  gas).  What is  "normal" is
 somewhat subjective and  should be determined by the enforcing agency.
      The type of rock  being processed by the dryer may affect emissions
 from some dryers processing rock from the  Florida deposits.  The Florida
 rock falls into two calssifications, pebble rock and concentrates.   Most
 operators indicate that they  experience greater  particulate emissions
 when drying pebble rock than  when  drying concentrates.  The reason
 they give is that the pebble rock goes  through  fewer washings in the
 beneficiation process (see Chapter 3) and, therefore, has more clay
 adhering  to  its  surface.  Attrition in  the dryer causes submicron-sized
                                    E-2

-------
  clay particles  to be sloughed off, resulting 1n greater emissions to
  the control system.  Because of this, at least half of the rock being
  processed during the performance tests .should be pebble rock.  Of
                                            t ' .
  course, if pebble rock will never be processed in the dryer, this
  requirement should be waived.
  E.3.  CALCINERS
       The enforcement aspects for calciners are the same as those
  presented above for dryers.  The only-noteworthy difference is that it
  is unlikely that any units will  be built to calcine Florida rock,  so
 the type of raw material fed to  the calciner  need  not concern the
 enforcement official.
.E.4.   GRINDERS
       Phosphate rock grinders  are  of  two basic  designs:   ball  mills  and
 roller milis.   Ball  mills are  usually ducted  to a "single  control device;
 however, roller mills  are frequently  operated in parallel with  several
 ducted to one  control  device.  Therefore, it is incumbent on  the enforcement
 official to be certain  that all mills ducted to the control device are
 operating  during the compliance tests.   Types of raw materials  do not
 affect  emissions from phosphate rock grinders.
      Factors  which  affect production rate from phosphate rock  grinders
 are the  mesh size (fineness) of the grind and the design of the grinder.
 Generally, emissions per  ton of production will increase as the rock is
 ground to smaller mesh sizes.  To increase the fineness of the grind,
 the operator must increase  the residence time of the rock in the grinder,
 biasing  the particle size distribution toward the smaller sizes.  However,
                                 E-3

-------
the process which will ultimately use the ground rock has been designed
to accept a certain size rock, typically 60 percent through 200 mesh,
                                                    *
and operates most efficiently with that size of rock.  Therefore,
fineness of the grind is not generally a parameter which the operator
changes frequently.  As with dryers and calciners, production throughput
of grinders is incidental to other considerations.  Production tonnage
decreases as the mesh size being produced gets smaller.  Once the
product size is set,  the operator usually monitors the amperage of
the mill motor and/or mill fan  and runs the grinding mill  at the
maximum production  possible without damaging  the  equipment.  The enforce-
ment  official should  obtain these maximum tolerances from  previous
•operating  data  (usually available from past log  sheets)  or,   if  necessary,
from  design data.
E.5.   GROUND ROCK HANDLING SYSTEMS
       The ground rock handling standard is  unique in that  it only  regu-
 lates visible emissions.  Also, because the  ground rock handling system
 usually operates  intermittently, the visible emissions test must be
 scheduled when the  system will be operated for the duration of the
 observations.
                                  E-4

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                APPENDIX F.  THE STACK GAS DISPERSION MODEL
 F.I.  DESCRIPTION OF THE SINGLE SOURCE MODEL CJMHCRD-1)
       The model used to estimate ambient concentrations for the phosphate
 rock processing plant is one developed by the Meteorology Laboratory,  EPA.
 This model is designed to estimate concentrations due to sources at a  single
 location for averaging times from one hour to one year.

       This model  is a Gaussian  plume model  using  diffusion  coefficients
 suggested by Turner (1970).* Concentrations  are  calculated for each hour
 of the year, from observations  of wind direction  (in  increments  of  10 degrees),
 wind speed,  mixing  height,  and  atmospheric stability.  The  atmospheric
 stability is derived  by  the Pasquill  classification method  as described by
 Turner (1970).  In  the application of this model, all pollutants are con-
 sidered to display  the dispersion behaviour of non-reactive gases.

      Meteorological data for 1964 are used as input to the model.  The reasons
for this choice are:  (1) data from earlier years  did not have sufficient
resolution in the wind direction! and (2) data from subsequent years are
readily available on magnetic tape only for every  third hour.
       *Turner, D. B., "Workbook of Atmospheric Dispersion Estimates," U.S
 Dept. of H.E.W., PHS Publication No. 999-Ap-24 (Revised 1970).
                                  F-l

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      Mtxtng height data are obtained from the twice-a-day upper air observa-
tions made at the most representative upper air station.   Hourly mixing heights
are estimated By the model using an objective interpolation schemed

      A feature of this model ts the modification of plume behavior to
account for aerodynamic effects -for plants in which the design is not optimal
(see Appendix B).  Another important aspect of the model ts the ability to
add concentrations from stacks  located closely together.  In this feature,
no consideration  is  gtven to  the physical separation between the stacks
since all  are assumed  to  be located  at the same geographical point.
       Calculations  are made  for 180  receptors', (at 36 azimuths and five  selectable
distances from  the  source).   The OMHCRD-1 model used here can consider  both
diurnal  and seasonal variations in the  source.  Separate  variation  factors can
 be applied on a monthly basis to account for seasonal  fluctuations  and  on an
 hourly basis to account for diurnal  variations.   Another  feature of the model
 Is the ability .to compute frequency distributions for concentrations of any
 averaging period over the course of a year.   Percentages  of various ranges  in
 pollutant concentrations are calculated.
 F.2.  AERODYNAMIC-EFFECTS .'MODIFICATION -OF THE SINGLE  SOURCE MODEL
 Note: The aerodynami c- effects version is a more general form of ^e single
       source model.  All remarks made in section F.I apply equally to either
       version.
    '   The single, source model does not address the aerodynamic complications
 which arise when plant design is less than ideal.  These effects result from
 the  interaction of  the wind with the physical structure of the plant.  Such
 interaction can retard or, in the  extreme, prevent plume rise.  The extreme
                                   F-2

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 case is coranonly referred to as ''downwash."   With  downwash,  the  effluent  is
 brought downward into the wake of the plant,  from  which  point  it diffuses as
 though emitted very close to the ground.   In  the retardation case, some of
 the dispersive benefits of plume rise are  lost; while in the downwash case,
 all of the benefits of plume rise are lost, along  with most of the benefits
 of stack elevation.  Both phenomena-but especially downwash-can seriously
 increase the resulting' ambient air impact.

       The aerodynamic-effects  modification, then,  is an attempt to include
 these  effects  in  a predictive  model.   It was developed within EPA and, while
 not yet  validated,  is  the  best-known  operational approach.   Basically, it
 enables  the  model to make  an hour-by-hour, stack-by-stack assessment  of
 the extent (if any) of aerodynamic complications.   The parameters used in
 making the assessment  are wind spaed, stack gas exit velocity,  stack  height,
 stack diameter, and building height.  If a particular assessment  indicates no
 aerodynamic effect, then for that stack for that hour,  the model  behaves just
 like the unmodified version.  If there are aerodynamic effects, the modified
version contains equations fay which the impact of these effects on ground-
level  concentrations is estimated.

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           APPENDIX 6.  CONVERSION  FROM  ENGLISH  TO  METRIC  UNITS
 To convert from
 Acre (ac)
 British Thermal  Unit
   (Btu) .
 Cubic Foot (ft3)
 Degree Farenheit (°F)
 Gallon (G)
 Grains per Actual
   Cubic Foot  (Gr/ACF)
 Grains  per Dry Standard
   Cubic Foot  (gr/dscf)

 Inch  of Water (Pressure)
Pound  (Ib)
Square  Foot (ft2)
Ton (T)
Ton per Hour (TPH)
         to
 Square Meter (m2)
 Joule (J)
 Cubic Meter (m3)
 Degree Celsius (°C)
 Cubic Meter (m3)
 Milligrams  per Actual
   Cubic  Meter (mg/m3)
 Milligrams  per Dry
   Standard  Cubic Meter
   (mg/dsm3)
 Pascal (Pa)
 Kilogram
 Square Meter  (m2)
 Kilogram  (kg)
Kilogram per Second
  (kg/s)
  Multiply  by
,  4.047  x 103
  1.055  x 103

  2.832  x 10-2
  °C = (°F - 32J/1.8
    *>
 3.785 x 10-3
 2.288 x 1Q3

 2.288 x 103

 2.488 x 102
 4.536 x 10-1
 9.290 x 10-2
 9.072 x 102
 2.520 x 10-1
                                    G-l

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                                         (EXAMPLE)
                                   TECHNICAL REPORT DATA
                            (Piuue read Instructions on the reverse before completing;
                             2.
1. REPORT NO.
EPA-450/3-79-017	
4. TITLE AND SUBTITLE
Phosphate  Rock Plants - Background Information:   Volume
1,  Proposed Standards.
                          6. PERFORMING ORGANIZATION CODE
r. AUTHOR^)
                                                            8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Office of Air Quality Planning  and Standards
Environmental Protection Agency
Research Triangle Park, North Carolina  27711
 12.SPONSORING AGENCY NAME AND ADDRESS
 DAA for Air Quality Planning and Standards
 Office of Air, Noise  and  Radiation
 U.  S. Environmental Protection Agency
 Research Triangle Park. North Carolina  27711
                                                           3. RECIPIENT'S ACCESSION NO.
                           i. R£POR.T DATE
                           September 1979
                                                            10. PROGRAM ELEMENT NO.
                           11. CONTRACT/GRANT NO."


                             68-02-3063
                           13 TYPE OF REPORT AND PERIOD COVERED
                              Draft
                           TSTSPONSOHING AGENCY CODE
 15. SUPPLEMENTARY NOTES
 •J6. ABSTRACT
 Standards  of Performance for the control of emissions  from phosphate rock plants  are
 being proposed under the authority  of Section 111 of the Clean Air Act.  These stan-
 dard! would  apply to new, modified, and reconstructed  phosphate rock dryers,  calcners,
 grinders,  and ground rock handling  systems, and would  limit emissions of Pjrticulate
 matter  by  85 to 98 percent below the levels permitted  by current typical state regu-
 lations.   This document  contains  background information, environmental and economic
 impact  assessments, and the rationale for the proposed standards... Volume•«-"»»«
 will be published when the standards are promulgated,  will contain a summary  of the
 public  comments on the proposed standard and EPA's  responses.  A discussion of any
 differences  between the proposed  and promulgated  standards will also be included.
 =
KEY WORDS AND DOCUMENT ANALYSIS
                   DESCRIPTORS
                                               b.lOeNTIFIEHS/OPEN ENDED TERMS
                                         c.  COSATI Field/Group
 Air pollution
 Pollution  control
 Standards  of performance
 Phosphate rock plants
 Particulate matter
                Air Pollution  Control
 J18. DISTRIBUTION STATEMENT
  Jnlimited
               19. SECURITY CLASS (This Report I

                 Unclassified
                                                                           21. NO. OF PAGES
                                                20. SECURITY CLASS iThispage)
                                                  Unclassified
                                                                           22. PRICE
  EPA F«m 2220-UR«v. 4-77)   MCVIOUS COITION is                              «»,„«„
                       .S. GOVERNMENT PRINTING OFFICE: 1979 -640-01* 3942REGION NO. 4

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