EPA-450/3-79-034a
Ammonium Sulfate Manufacture
Background Information for
Proposed Emission 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
December 1979
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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 Protection Agency,
Research Triangle Park, N.C. 27711, or from National
Technical Information Services, 5285 Port Royal Road,
Springfield, Virginia 22161.
PUBLICATION NO. EPA-450/3-79-034a
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Background Information and
Draft Environmental Impact Statement
for Proposed Emission Standards for
Ammonium Sulfate Manufacture
Type of Action: Administrative
Prepared by:
k
~T-±/ii ..it
Don R. Goodww
Director, Emission Standards and Engineering Division
Environmental Protection Agency
Research Triangle Park, North Carolina 27711
Approved by:
(Date)
tewki ns
Assistant Administrator for Air, Noise, and Radiation
Environmental Protection Agency.
Washington, D.C. 20460
Draft Statement Submitted to EPA1 s JAN
Office of Federal Activities for Review on
(Date)
This document may be reviewed at:
Central Docket Section
Room 2903B, Waterside Mall
Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Additional copies may be obtained at:
U.S. Environmental Protection Agency Library (MD-35)
Research Triangle Park, North Carolina 27711
National Technical Information Service
5285 Port Royal Road
Springfield, Virginia 22161
m
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TABLE OF CONTENTS
Section
Page
1.0 SUMMARY 1-1
1.1 Proposed Standards .... 1-1
1.2 Environmental Impact 1-1
1.3 Economic Impact 1-3
2.0 INTRODUCTION .2-1
2.1 Authority for the Standards .... 2-1
2.2 Selection of Categories of Stationary Sources 2-5
2.3 Procedure for Development of Standards of
Performance 2-7
2.4 Consideration of Costs 2-9
2.5 Consideration of Environmental Impacts 2-11
2.6 Impact on Existing Sources 2-12
2.7 Revision of Standards of Performance 2-13
3.0 AMMONIUM SULFATE INDUSTRY 3-1
3.1 General 3-1
3.2 Production Processes and Their Emissions 3-6
3.3 Emissions Under Existing Regulations 3-24
3.4 References ^ 3-30
4.0 EMISSION CONTROL TECHNIQUES 4-1
4.1 Factors Affecting Emission Control Techniques ...... 4-1
4.2 Distribution of Emission Control Equipment in the
AS Manufacturi ng Industry 4-6
4.3 Wet Scrubbing in the Ammonium Sulfate Industry ..'.. 4-6
4.4 Fabric Filtration in the Ammonium Sulfate
Industry 4-13
4.5 EPA Emission Test Data 4-15
4.6 References 4-24
5.0 MODIFICATION AND RECONSTRUCTION . 5-1
5.1 Background •.. ... 5-1
5.2 40 CFR Part 60 Provisions for Modification and
Reconstruct!' on 5-1
5.3 Applicability to Ammonium Sulfate Plants 5-3
5.4 References 5-6
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TABLE OF CONTENTS (Concluded)
Section
Page
6.0 MODEL PLANTS AND REGULATORY ALTERNATIVES 6-1
6.1 Model Plants 6-1
6.2 Regulatory Alternatives ....6-3
6.3 Summary 6~5
6.4 References •• 6"6
7.0 ENVIRONMENTAL IMPACT
7-1
7.3
7.4
7.5
7.6
7.1 Air Pollution Impact 7-1
7.2 Water Pollution Impact 7-20
Solid Waste Impact 7-21
Energy Impact 7-21
Noise Impact 7-22
References 7-23
8.0 ECONOMIC IMPACT ....' - B~l
8.1 Industry Economi c Profi1e 8-2
8.2 Cost Analysis of Alternative Control Systems 8-37
8.3 Other Cost Considerations 8-88
8.4 Economic Impact Analysis 8-92
8.5 Socio-Economic and Inflationary Impacts 8-109
9.0 RATIONALE FOR THE PROPOSED STANDARD 9-1
9.1 Selection of Source for Control 9-1
9.2 Selection of Pollutants 9~2
9.3 Selection of the Affected Facility 9-3
9.4 Selection of the Format of the Recommended
Standard 9'4
9.5 Selection of the Best System of Emission Reduction
and the Numerical Emission Limits 9-8
9.6 Selection of Visible Emission Limits 9-17
9.7 Selection of Performance Test Methods 9-17
9.8 Selection of Monitoring Requirements 9-20
Q 99
9.9 References • *~"
'VI
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LIST OF TABLES
Table
1-1
3-1
3-2
3-3
3-4
3-5
3-6
3-7
3-8
3-9
3-10
4-1
4-2
6-1
7-1
7-2
7-3
7-4
Matrix of Envi ronmental and Economic Impacts of
Proposed Particulate Emission Limits
Analysis of 1977 Ammonium Sulfate Production
Average Ammonium Sulfate Plant Size ,
Summary of Uncontrolled AS Emission Data — EPA
Emission Tests on AS Dryers
Typical Parameters for A Caprolactam By-Product
Ammonium Sulfate Plant Dryer
Gas Flow Rates and Capacities (Synthetic Ammonium
Sulfate Plants)
Typical Parameters for a Synthetic Ammonium Sulfate
PI ant Dryer ,
Design of Rotary Dryers Used for Ammonium Sulfate
Drying
Estimated Air Flows for Coke Oven Plant Ammonium
Sul fate Dryers . „ . .
Estimated Parameters for A Coke Oven Ammonium Sulfate
Dryer
Comparison of Allowable Emissions Under General State
Process Weight Regulations , . . .
Ammonium Sulfate Industry- Supplied Wet Scrubber
Performance Data
AS Particulate Control Systems Tested by EPA
Model Plant Parameters for Ammonium Sulfate Dryers
Impact Summary of 1985 Particulate Emissions from
Ammonium Sulfate Plants ,,.,».«,.' , *. ,,,,*,,,.,. ,^
Impact Summary for 1985 Caprolactam Emission from ""
Caprolactam Ammonium Sulfate Plants Coincident with
Particulate Emission Control
Source Data for Dryers
Maximum 24-Hour Average, Particulate Concentrations
Calculated for Ammonium Sulfate Dryers at Caprolactam
Plants for Five Air Flow-to-Production Ratios
Page
-- *^
1-2
3-3
3-4
3-11
3-14
3-18
3-19
3-20
3-25
3-26
3-29
4-8
4-16
6-2
7-3
7-5
7-7
7-10
vii
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LIST OF TABLES (Continued)
7-6
7-7
7-8
7-9
7-10
7-11
7-12
8-1
8-2
8-3
8-4
8-5
8-6
7-11
7-12
7-14
7-15
Maximum 24-Hour Average Particulate Concentrations
Calculated for Ammonium Sulfate Dryers at Primary
Production Plants for Four Air Flow-to-Production
Ratios -
Maximum 24-Hour Average Particulate Concentrations
Calculated for Ammonium Sulfate Dryers at Coke Oven
Operations for Four Air Flow-to-Production Ratios .
Maximum Annual Average Particulate Concentrations
Calculated for Ammonium Sulfate Dryers at Caprolactam
Plants for Five Air Flow-to-Production Ratios 7-13
Maximum Annual Average Particulate Concentrations
Calculated for Ammonium Sulfate Dryers at Primary
Production Plants for Four Air Flow-to-Production
Ratios
Maximum Annual Average Particulate Concentrations
Calculated for Ammonium Sulfate Dryers at Coke Oven
Operations for Four Air Flow-to-Production Ratios .
Maximum 3-Hour Average Caprolactam Concentrations
Calculated for Ammonium Sulfate Dryers at Caprolactam
Plants for Five Air Flow-to-Production Ratios 7-lb
Maximum Annual Average Caprolactam Concentrations
Calculated for Ammonium Sulfate Dryers at Caprolactam
Plants for Five Air Flow-to-Production Ratios ... 7-1/
Maximum 24-Hour Average Caprolactam Concentrations
Calculated for Ammonium Sulfate Dryers at Caprolactam
Plants for Five Air Flow-to-Production Ratios 7-l»
Production of Ammonium Sulfate by Source 8-3
Ammonium Sulfate Producing Plants, Locations, and
Capacities
Ammonium Sulfate Capacity Distribution by Process .
Resource Use, 1976
Consumption of Ammonium Sulfate by Use
United States Ammonium Sulfate and Nitrogen Consumption
1955-1978
8-5
8-7
8-16
8-17
8-19
vm
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LIST OF TABLES (Continued)
Table
8-7
8-8
8-9
8-10
8-11
8-12
8-13
8-14
8-15
8-16
8-17
8-18
8-19
8-20
8-21
8-22
8-23
8-24
8-25
Fertilizer Prices .
Ammonium Sulfate Capacity, Production, Consumption, and
Inventories
Ammoni urn Sul fate Imports and Exports
Ammonium Sulfate Prices
Financial Parameters for Selected Companies
Industry Concentration of Ammonium Sulfate Producers ..
Production and Exhaust Gas Rates for Model Plant
Ammonium Sulfate Dryers
Particulate Emission Parameters for Model Plant
Ammonium Sulfate Dryers
Specifications for Emission Control Systems
Bases for Estimating Annualized Costs for Emission
Control Systems
Costs of Particulate Emission Control Equipment for the
Ammonium Sulfate Industry
Component Capital Cost Factors for FRP Fabric Filter—
8.5 m3/min (300 acfm)
Component Capital Cost Factors for FRP Fabric Filter —
28.3 m3/min (1000 acfm)
Component Capital Cost Factors for FRP Fabric Filter—
283 m3/min (10,000 acfm)
Component Capital Cost Factors for FRP Fabric Filter—
1,189 m3/min (42,000 acfm)
Component Cost Factors for FRP Fabric Filter— 1,698
m3/min (60,000 acfm)
Component Capital Cost Factors for STD Fabric Filter—
8.5 m3/min (300 acfm)
Component Capital Cost Factors for STD Fabric Filter—
28 m3/min (1000 acfm) ,
Component Capital Cost Factors for STD Fabric Filter—
283 m3/min (10,000 acfm) , ,
Page
8-20
8-22
8-24
8-27
8-29
8-31
8-38
8-39
8-41
8-43
8-44
8-45
8-46
8-47
8-48
8-49
8-50
8-51
8-52
IX
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LIST OF TABLES (Continued)
Table
Page
8-26
8-27
8-28
8-29
8-30
8-31
8-32
8-33
8-34
8-35
8-36
8-37
8-38
8-39
8-40
8-41
8-42
Component Capital Cost Factors for STD Fabric Filter—
1189 m3/min (42,000 acfm) .......
Component Capital Cost Factors for STD Fabric Filter—
1698 m3/min (60,000 acfm)
Component Capital Cost Factors for Venturi Scrubber —
8.5 m3/min (300 acfm)
Component Capital Cost Factors for Venturi Scrubber —
28.3 m3/min (1000 acfm)
Component Capital Cost Factors for Venturi Scrubber —
283 m3/min (10,000 acfm)
Component Capital Cost Factors for Venturi Scrubber —
1189 m3/min (42,000 acfm)
Component Capital Cost Factors for Venturi Scrubber —
1698 m3/min (60,000 acfm)
Component Capital Cost Factors for Low Energy Scrubber
— 8.5 m3/min (300 acfm)
Component Capital Cost Factors for Low Energy Scrubber
— 28.3 m3/min (1000 acfm)
Component Capital Cost Factors for Low Energy Scrubber
— 283 m3/min (10,000 acfm)
Component Capital Cost Factors for Low Energy Scrubber
— 1189 m3/min (42,000 acfm)
Component Capital Cost Factors for Low Energy Scrubber
— 1698 m3/min (60,000 acfm)
Cost of Control Systems: Caprolactam By-Product
Industry; 27.2-Mg/h (30 Tons/h) Dryers
Cost of Control Systems: Caprolactam By-Product
Industry; 22.7-Mg/h (25 Tons/h) Dryers
Cost of Control Systems: Prime Industry
Cost of Control Systems: Coke Oven By-Product
Industry
Capital and Annual Operating Cost Estimates for Two
22.7-Mq/h (25 Ton/h) Ammonium Sulfate Dryers
8-53
8-54
8-55
8-56
8-57
8-58
8-59
8-60
8-61
8-62
8-63
8-64
8-67
8-68
8-69
, 8-70
, 8-72
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LIST OF TABLES (Concluded)
Table
8-43 Incremental Cost of Particulate Control to Meet
Option II: Caprolactam By-Product Industry; 27.2-Mg/h
(30 Ton/h) Dryers , 8-74
8-44 Incremental Cost of Control to Meet Option II: Caprolactam
By-Product Industry; 22.7-Mg/h (25 Ton/h) Dryers ... 8-75
8-45 Incremental Cost of Particulate Control to Meet
Option II: Prime Industry 8-76
8-46 Incremental Cost of Particulate Control to Meet
Option II: Coke Oven By-Product Industry ,..-, 8-77
8-47 Cost-Effectiveness of Additional Particulate Control to
Meet Option II: Caprolactam By-Product Industry;
27.2 Mg/h (30 Ton/h) Dryers 8-81
8-48 Cost-Effectiveness of Additional Particulate Control to
Meet Option II: Caprolactam By-Product Industry;
22.7 Mg/h (25 Ton/h) Dryers 8-82
8-49 Cost-Effectiveness of Additional Particulate Control
to Meet Option II: Prime Industry 8-83
8-50 Cost-Effectiveness of Additional Particulate Control to
Meet Option II: Coke Oven By-Product Industry 8-84
8-51 Capital Investment in the Ammonium Sulfate Industry .. 8-98
8-52 Impact on Model Plant Rates of Return of Regulatory
Options Under Full Cost Absorption 8-101
8-53 Impact on Product Price of Reaulatory Options Under
Full-Cost Pricing 8-103
8-54 Investment Impacts 8-105
8-55 Incremental Annualized Costs of Control: 1985 8-108
9-1 Summary of Uncontrolled AS Emission Data — EPA
Emmission Tests on AS Dryers 9-5
9-2 Opacity Observations 9-18
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LIST OF ILLUSTRATIONS
Page
3-1 Flow Diagram for Ammonium Sulfate Processes ........... 3-7
3-2 Ammonium Sulfate Plant Caprolactam By-Product Process
Flow Diagram ........................................ 3_8
3-3 Process Flow Diagram Synthetic Ammonium Sulfate Plant . 3-16
3-4 Process Flow Diagram for Coke Oven Ammonium Sulfate
Plants Showing Alternate Process for Product Dyring . 3-23
3-5 State Regulation Limitations on Particulate Emission
From New Processes .................................. 3-28
4-1 Solubility of Ammonium Sulfate in Water Versus
Temperature ......................................... 4-2
4-2 Uncontrolled Ammonium Sulfate Dryer Emissions Particle
Size Distribution ................................... 4-4
4-3 Uncontrolled AS Emissions Versus Gas Flow ............. 4-5
4-4 Controlled AS Particulate Emissions From EPA Emission
Tests — Calculated Grain Loadings .................. 4-18
4-5 Controlled AS Partiticulate Emissions From EPA Emission
Tests — Calculated Mass Emission Rates ..... ........ 4-19
4-6 Average Controlled Grain Loading Test Data — EPA
Method 5 ............................................ 4-20
4-7 Average Controlled AS Mass Emission Rate Data — EPA
Method 5 ............................................ 4-21
8-1 Ammonium Sulfate Synthetic Production Plants .......... 8-8
8-2 Coke Oven By-Product AS Plants ........................ 8-10
8-3 Ammonium Sulfate Production Plants .................... 8-13
8-4 Cost Multiplier Factors for Selected Control
Equi pment .................................... ....... 8-66
8-5 Investment Costs for Control Alternatives Used on
Ammoni urn Sul f a te Dryers ...................... ....... 8-7 1
8-6 Incremental Cost of Option II Control Alternatives
for Two 22.7 Mg/h (25 Ton/h) Ammonium Sulfate
Dryers in Caprolactam By-Product Industry ........... 8-78
8-7 Incremental Cost of Option II Control Alternatives
for a 13.6 Mg/h (15 Ton/h) Ammonium Sulfate Dryer
in Prime Industry ................................... 8-79
xn
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LIST OF ILLUSTRATIONS (Concluded)
Figure Page
8-8 Incremental Cost of Option II Control Alternatives
for A 2.7 Mg/h (3 Ton/h) Ammonium Sulfate Dryer
in the Coke Oven By-Product Industry ...» 8-80
8-9 Cost-Effectiveness of Option II Control Alternatives
for Two 22.7 Mg/h (25 Ton/h) Ammonium Sulfate
Dryers in the Caprolactam Industry 8-85
8-10 Cost-Effectiveness of Option II Control Alternatives
for a 13.6 Mg/h (15 Ton/h) Ammonium Sulfate Dryer
in the Prime Industry 8-86
8-11 Cost-Effectiveness of Option II Control Alternatives
for a 2.7 Mg/h (3 Ton/h) Ammonium Sulfate Dryer
in the Coke Oven By-Product Industry 8-87
9-1 Controlled AS Particulate Emissions From EPA Emission
Tests —Calculated Mass Emission Rates 9-12
xiii
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1.0 SUMMARY
1.1 PROPOSED STANDARDS
This Background Information Document (BID) supports proposed
standards for particulate emissions from ammonium sulfate (AS)
dryers within ammonium sulfate manufacturing plants. The proposed
particulate matter emission limits apply to the three major seg-•
ments of the AS industry: caprolactam by-product plants, synthetic
plants, and coke oven by-product plants. Additional information
and regulatory rationale may be found in the preamble and regula-
tion for Subpart PP in the Federal Register.
The proposed emission standards under 40 CFR Part 60, Subpart
PP would restrict particulate emissions from AS dryers to:
0.150 kilograms per megagram of AS production
. (0.30 pounds per ton); and
15 percent opacity.
Control of particulate emissions from AS manufacturing plants
is achieved by installation of an emission control system to remove
particulate matter from the exhaust gas stream. Venturi scrubbers
have been adequately demonstrated to be the best technological
system of continuous,emission reduction for AS dryers. Fabric
filters, though not considered the most attractive add-on control
system, should also be able to achieve the level of control required
by the standard.
1.2 ENVIRONMENTAL IMPACT
The proposed emission limit would reduce annual nationwide
particulate emissions from AS dryers placed on line in AS manu-
facturing plants between 1980 and 1985 by about 539 Mg/year. This
represents a reduction of about 80 percent in the emissions emitted
under a typical State Implementation Plan (SIP) regulation. The
proposed emission limits would not adversely affect water quality,
1-1
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solid waste disposal, energy conservation, or noise level, The
environment impacts are summarized in Table 1-1,
1.3 ECONOMIC IMPACT
An economic impact assessment of the proposed emission limits
has been prepared, as required under Section 317 of the Clean Air
Act (as amended in 1977),. The proposed limits would have negligible
impact on compliance costs, inflation or recession, competition with
respect to small business, consumer costs, and energy use. The
standards would reduce profitability (as measured by rate of
return on assets) by less than 1,0 percent.
The Agency*s guideline for determining the necessity for
developing an Inflationary Impact Statement is increased operating
costs in the fifth year of operation of more than $100 million.
The increase associated with the proposed limits Is about $0,5
million per year.
The complete economic impact analysis appears In Chapter 8,0,
A summary of the economic impacts of the proposed emission limits
is also presented in Table 1-1,
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2.0 INTRODUCTION
Standards of performance are proposed following a detailed
investigation 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 Ammonium
Sulfate Manufacturing Plants — Background Information for Proposed
Particulate Emission Standards, report number EPA
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 sources of air pollution which
"... causes or contributes significantly to, air pollution which
may reasonably be anticipated to endanger public health or welfare."
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 contin-
uous 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 provides that the cost of achieving the necessary emission
2-1
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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 orrty to stationary
sources, the construction or modification of which commences after
regulations are proposed by publication in the Federal Register.
The 1977 amendments to 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 performance. Regulations must be
promulgated for these new categories on the following
schedule:
25 percent of the listed categories by August 7, 1980
75 percent of the listed categories by August 7, 1981
100 percent 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.
3. EPA is authorized to promulgate a design, equipment, work
practice, or operational standard when an emission stan-
dard 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
2-2
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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 pollu-
tion potentials are high. Congress does not intend that new
source 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
2-3
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1
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 reduc-
tion 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 application of
production processes and available methods, systems, and techniques,
including fuel cleaning or treatment or innovative fuel combustion
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 sometimes necessary. In some cases physical measure-
ment of emissions from a new source may be impractical or exorbitantly
expensive. Section lll(h) provides that the Administrator may pro-
mulgate 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.
2-4
-------
In addition, Section lll(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
adequately demonstrated; (3) the technology will not cause or
contribute to an unreasonable risk to public health, welfare or
safety; (4) the governor 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 condi-
tions attached to assure the source will not prevent attainment of
any NAAQS. Any such condition will have the force of a performance
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 promulgation 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 assign-
ing priorities to various source categories. The approach specifies
2-5
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areas of interest by considering the broad strategy of the Agency
for implementing the Clean Air Act. Often, these "areas" are
actually pollutants which are emitted by stationary 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 stan-
dards of performance for the source category; (3) projections of
growth and replacement of existing facilities for the source
category; and (4) the estimated incremental amount of air pollution
that could be prevented, in a preselected future year, by standards
of performance for the source category. Sources for which new
source performance standards were promulgated or are under develop-
ment during 1977 or earlier, were selected on these criteria.
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 applic-
able new source standards of performance.
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 emis-
sions may require refinement. In the developing of standards,
differences in the time required to complete the necessary investi-
gation 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.
2-6
-------
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 con-
tinue to be, used to establish the order in which projects are
initiated and resources assigned.
After the source category has been chosen, determining the
types of facilities within the source category to which the standard
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 is no adequately demonstrated
system for controlling 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,
2.3 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.
2-7
-------
The objective of a program for development of standards is to
identify the best technological system of continuous 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 opera-
tional 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 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 evolved which
takes into account the following considerations.
1. Emissions from existing well-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,
2-8
-------
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 develop-
ment 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.
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
concentration/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 cases, 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 impact assessment with respect to any standard of perform-
ance established under Section 111 of the Act. The assessment is
required to contain an analysis of:
2-9
-------
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;
2. The potential inflationary or recessionary effects of the
standard or regulation;
3. The effects on competition of the standard or regulation
with respect 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 practicable, 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 comparison 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 air pollutants are not the only costs
considered. Total environmental costs for control of water pollut-
ants 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 the capital requirements
placed on plants in the absence of Federal standards of performance
2-10
-------
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
performance.
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, ... require(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,"
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."
2-11
-------
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 beneficial 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 construction or modification of which is
commenced ..." after the proposed standards are published. An
existing source becomes a new source if the source is modified or
is reconstructed. Both modification and reconstruction are
defined in amendments to the general provisions of Subpart A of
40 CFR 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 components 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 stan-
dards. In such cases, reconstruction is equivalent to new
construction.
2-12
-------
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 riot 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 promul-
gated 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 any industry may improve with technological advances.
Accordingly, 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 avail-
able 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.
2-13
-------
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3. AMMONIUM SULFATE INDUSTRY
3.1 GENERAL
3.1.1 Overview
Ammonium sulfate (AS) has been an important nitrogen fertilizer
source for many years. One of the reasons for AS's early rise to
importance as a fertilizer material was that it developed as a by-
product from such basic industries as steel and petroleum manufacturing.
The amount of by-product generation has continued to dominate the AS
production industry. In fact, by-product AS from the rapidly growing
caprolactam segment of the synthetic fibers industry is now the
single largest source of this material. The production of AS as a
by-product from such large and basic industries ensures that it will
continue to be an important source of U.S. nitrogen fertilizer
tonnage.
Ammonium sulfate is one of the older forms of nitrogen fertilizer
and is still used in significant quantities. However, since 1950
AS's share of the total nitrogen fertilizer market has declined as
other nitrogen fertilizers (e.g., anhydrous ammonia, ammonium
nitrate (AN), urea, and nitrogen solutions) have grown more rapidly.
(This decline is also due to the increased demand for diammom'um
phosphate (DAP) as a raw material for a mixed fertilizer.)
Ammonium sulfate's percentage of the total nitrogen market will
likely continue to decrease although total production may increase.
This possible increase in tonnage would be a result of additional
by-product material from the steady growth in caprolactam production
rather than from any new synthetic AS plants. The rapid increase in
synthetic fiber demand (nylon-6), for which caprolactam is the
production intermediate, means that approximately 1.8 ..to 4.0 Mg of
o
AS will come on the market for every Mg of caprolactam produced.
3-1
-------
3.1.2 Uses for Ammonium Sulfate
In 1977, the total domestic AS production was about 2.1 million
3
Hg. Over 95 percent of this total was consumed as fertilizer.
This proportion of total use is not expected to change appreciably.
Based on 1975 data, approximately 32 percent of domestic production
of AS was used as direct application fertilizer, 43 percent was used
for NPK fertilizer mixtures, 20 percent was exported for fertilizer
usage, and 5 percent was used domestically for miscellaneous purposes.*
3.1.3 Sources and Quantities of Ammonium Sulfate Production
Over 90 percent of ammonium sulfate is generated from three
types of plants: synthetic, caprolactam by-product plants and coke
oven by-product plants. Synthetic AS is produced by the direct
combination of anhydrous ammonia and sulfuric acid. Caprolactam
AS is produced as a by-product from two or three streams generated
during caprolactam manufacture. The ammonia recovered from coke
oven off-gas is reacted with sulfuric acid to produce coke oven AS.
These three processes are reviewed in Section 3.2.
Table 3-1 provides an analysis of AS production in 1977 by
number of production plants, plant capacity, actual production and
percentage of capacity utilization. Currently, AS produced from
three caprolactam AS plants is the largest source of AS production,
representing about half of total supply.
3.1.4 Plant Sizes and Locations
Synthetic and caprolactam AS plants are fairly scattered around
the U.S., while coke oven AS plants are concentrated heavily in the
steel-producing states, particularly Ohio and Pennsylvania.
*AS is used as an additive or raw material for the following products:
livestock feeds, insulation, fermentation additive, photography,
nylon dyes, ammonium alum, Pharmaceuticals, hydrogen peroxide, print-
ing ink and animal bone glue.
3-2
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The current average AS plant size for the three significant AS
categories has been determined from 1977 production data and is
tabulated in Table 3-2.
Table 3-2. AVERAGE AMMONIUM SULFATE PLANT SIZE
Source
Average plant size,
Mg/yr (tons/yr)
Average plant size,
Mg/hr (tons/hr)
Synthetic AS
Caprolactam AS
Coke Oven AS
79,000 (87,000)
531,000 (584,000)
13,200 (14,500)
13.3 (14)a
60.6 (66)b
1.8 (2.1){
aBased on 24 hr/day, 300 day/yr operation.
bBased on 24 hr/day, 365 dayVyr operation.
3.1.5 Future Trends in the Production of Ammonium Sulfate
Trends in the production and demand for AS over the next 4- to
5-year period are summarized in the following paragraphs.
3.1.5.1 Synthetic Ammonium Sulfate
Synthetic AS production is expected to remain fairly static
with no new plants forecast.8 Table 3-1 confirms the likelihood
that no new synthetic AS production facilities will be added in the
foreseeable future, since much of the presently available capacity
is not being utilized.
3.1.5.2 AS from Coke Oven Gas
Coke oven AS capacity will not increase appreciably since most
new coke oven batteries will be replacements, with some large new
coke ovens recovering the by-product ammonia rather than producing
AS.9 The plants also have the process option to use phosphoric
acid instead of sulfuric acid with the subsequent recovery of
ammonium ph'osphate.
3-4
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3.1.5.3 Caprolactam By-Product Ammonium Sulfate
Caprolactam demand has been projected to increase at a rate of
5 to / percent per year through the end of this decade. However,
the three present production plants, together with caprolactam
imports, are expected to provide an adequate supply until at least
1980,
A continuation of this demand growth would indicate the likeli-
hood of additional caprolactam and by-product AS capacity coming on-
line from 1980 to 1990,llj12 future AS dryers to be either installed
as additions to existing plants or as part of an entirely new
caprolactam plant.
3.1.5.4 Ammonium Sulfate from Miscellaneous Sources
Ammonium sulfate and sulfuric acid are by-products derived
from the manufacture of methyl methacrylate (MMA) at one existing
facility. However, no new plants of this type are expected to be
built because new technology for future MMA plants eliminates the
manufacture of AS. The MMA plant with AS by-product may convert
its plant to the new process in early 1980's thereby eliminating
14
AS generation.
AS is also produced as a by-product of nickel manufacture
from ore concentrates at two U.S. plants. These plants indicate
that another nickel refinery employing this process would not be
installed until the mid- to late-1980s.15
Scrubbing of sulfuric acid plant tail gas using one of several
available ammonia scrubbing processes does not appear to be a
significant future source of this material since new sulfuric acid
plants are all employing SO- control technology which does not
16
generate by-product AS.
3-5
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3.2 PRODUCTION PROCESSES AND THEIR EMISSIONS
Ammonium Sulfate is produced from several types of plants (e.g.,
caprolactam AS plants, synthetic AS plants and steel industry coke
oven AS plants). A generalized process flow diagram for the three
major types of AS manufacturing plants is shown in Figure 3-1. The
basic difference in the three production processes is the method of
producing AS crystal from the various feedstocks. From the crystal-
lization step onward, manufacturing operations are quite similar:
they involve an AS crystal dewatering device and a drying device
followed by a screening device.* In the following sections, the
three AS manufacturing processes are discussed in detail.
3.2.1 Caprolactam By-Product Ammonium Sulfate
The typical process flow diagram developed for caprolactam
by-product AS is shown in Figure 3-2. It is based on information
obtained from inspections of the three U.S. caprolactam production
plants and information derived from responses to EPA inquiries.**
The material flow rates shown in Figure 3-2 are based on a dryer
i
production rate of 23 Mg/hr of product (25 tons/hr). The majority
of these plants contain more than one dryer production train and two
or more crystal!izers feeding a dryer.
The AS crystals are produced by continuously heating and
circulating a 40 percent AS mother liquor through a draft tube-
baffle crystallizer. The crystallizer typically operates in the
temperature range of 77° to 82°C (170° to 180°F) and a pressure of
about 660 mmHg (12.8 psia). Water vapor released from the crystal -
1izers is condensed in one or more heat exchangers. A slurry of
mother liquor and crystals, known as "magma," flows from the
crystal!izer to a settling tank. The magma may be combined with
* Screening appears to be nonexistent in the coke oven by-product
AS industry.
**Requests for information under the provisions of Section 114 of
the Clean Air Act Amendments of 1977.
3-6
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a mother liquor stream to facilitate transport to the settling
tank. The settling tank is designed to reduce the liquid load on
the centrifuges by decanting clear liquid overflow as the crystals
settle to the bottom of the tank. The slurry feed to the crystal!izer
normally consists of 60 to 70 percent AS crystals.
The centrifuge performs a bulk separation between the AS
crystals and mother liquor. In the centrifuge operation, the
crystal throughput varies from 8 to 11 Mg/hr (9 to 12 tons/hr)
per centrifuge for a two-centrifuge system. The number of centrif-
uges exceeds the number of crystal!izers to provide spare centrifuge
capacity in case lines become plugged with solid AS.
Inspections of the centrifuge installations at the three
caprolactam plants determined the following with respect to AS
emissions from these units:
1. At two-out-of-three plants, there were no visible AS
particulate emissions from the centrifuge vents.
2. At the third plant, uncontrolled centrifuge AS emissions
were estimated to be 0.01 kg/Mg (0.02 lb/tons).* All
of the centrifuge vent lines were manifolded to a wet
scrubber. According to the plant management, this was
necessary because the centrifuges are located in an
enclosed area, and they are subject to OSHA regulations
pertaining to the area.
Dryers, which are the principal source of AS particulate
emissions, can be either the fluidized bed or rotary drum type.
All fluidized bed units found in the industry are heated continu-
ously with steam-heated air. The rotary units are either direct-
fired (oil or natural gas) or heated with steam-heated air. The
fluidized bed dryers appear to be replacing rotary units in the
newer installations. The following reasons for this trend were
obtained from the literature and contact with vendors of this
equipment:
.17,18
*Data from Plant F response to EPA 114 letter.
3-9
-------
1 In the fluidized bed unit AS fines tend to be swept out
of the bed (in effect classifying the material) during
the drying cycle, thus improving the particle size dis-
tribution and quality of the product. A granular AS
product is claimed to be more marketable.
2. Space requirements for fluidized bed units are signifi-
cantly less for the same throughput.
3. Capital and operating costs are less with fluidized
bed units.
4. Heat and mass transfer rates are greater for fluidized
bed units.
Gas flow rate, and heat and mass transfer rates are the important
parameters for drying AS. According to a drying equipment vendor, a
gas flow rate of 2200 scm/Mg of product (70,000 scf/ton) is considered
representative for steam-heated air, while 600 scm/Mg of product
(20,000 scf/ton) is typical for direct-fired dryers. Based on
data obtained from caprolactam plant visits, air flows for the AS
dryers at caprolactam plants range from 560 scm/Mg (18,000 scf/ton)
of product to 3200 scm/Mg (103,000 scf/ton) of product. The lower
values represent direct-fired units and the higher values represent
units using steam-heated air.
EPA has recently conducted a series of AS emission tests on
dryers at a number of AS production plants using EPA Method 5.
Uncontrolled AS emission data are summarized in Table 3-3. Uncon-
trolled AS emissions for three rotary dryers ranged from 0.41 kg/Mg
(0.82 Ib/ton) to 77 kg/Mg (153 Ib/ton) with an overall average of
approximately 26 kg/Mg (52 Ib/ton). Rotary drier data supplied by
one AS manufacturer indicated an uncontrolled AS emission rate estimate
of 20 kg/Mg (39 Ib/ton), based on a material balance over the AS
scrubbing equipment.21 Data from an emissions test on a fluidized
bed dryer at a caprolactam by-product AS plant indicated an average
uncontrolled AS emission rate of 110 kg/Mg of product (221 Ib/ton).
The factors affecting uncontrolled emission rates from the dryer are
discussed in Section 4.1.
3-10
-------
Table 3-3. SUMMARY OF UNCONTROLLED AS EMISSION DATA -
EPA EMISSION TESTS ON AS DRYERS*
Dryer
Plant type
Average uncontrolled AS emissions
gm/dscm [gr(dscf)] kg/Mg (Ib/ton)
A Rotary Dryer
4.38 (1.93)
0.41 (0.82)
B Fluidized Bed Dryer
39.0 (17.2)
110 (221)
C Rotary Dryer
8.87 (3.91)
3.46 (6.92)
D Rotary Dryer
98.3 (43.3)
77 (153)
*Detailed uncontrolled emission data for the individual plants is
given in Appendix C, Tables C-l, C-4, C-6, and C-8.
3-11
-------
At one caprolactam AS plant, the particulates and gas samples
taken during EPA emission testing were analyzed for caprolactam; small
concentrations of which are present in the dryer exhaust. Uncontrolled
caprolactam particulate emissions averaged 0.011 g/dscm (3.3 ppm)
equivalent to 1.12 Kg/hr (2.46 Ib/hr). However, gas chromatograph
measurements of the inlet gas phase samples, indicated a total
caprolactam concentration of 0.272 g/dscm (57.8 ppm) equivalent to
19.6 Kg/hr (43.3 Ib/hr). These rates are significantly higher than
those reported by the company: 0.014 to 0.060 g/dscm (3 to 13 ppm).
Based on the EPA test, most of the caprolactam emissions from the
AS dryer (approximately 94 percent) are present in the vapor phase.
Caprolactam hydrocarbons (also referred to as volatile organic
compounds) are carried over from the process streams which produce
AS as a by-product. Caprolactam, (CH2)5CONH, has a melting point
of 60°C and a boiling point of 140°C. This means that any capro-
lactara present in the AS dryer at the operating temperatures
involved, about 85°C, is in the liquid phase. The caprolactam
vapor present in the exit gas results from the vapor pressure at
the temperature of the dryer. However, the majority of caprolactam
is carried through the process. The liquid phase caprolactam in
the dryer adheres to the AS crystals and passes through the drying
and classifying process. This residual HC serves the useful purpose
of preventing AS caking in storage. (Synthetic AS plants add a
heavy hydrocarbon after drying in order to prevent caking.) The
majority of caprolactam HC is removed from the system in this
fashion.
22
The AS crystalline product typically contains 2.0 to 2.5 percent
water on entry to the dryer and 0.1 to 0.5 percent at the outlet.
The product AS from the dryer is conveyed to an enclosure where it
is screened, generally to coarse and fine products and the small
mesh fines.* One coarse product contained 95 percent -6+18 mesh
*The mixture of fines and oversize particles is sold as a so-called
standard grade or the fines may be recycled to the process.
3-12
-------
crystals and a standard fine crystal of -18 mesh with no fines
recycle.* The screening operation is typically carried out within
a building, and a screen enclosure may be used to minimize fugitive
dust in the processing building.
The parameters for a 23 Mg/hr (25 ton/hr) dryer in the typical
AS production train are listed in Table 3-4.
The hot gases from the dryer are passed through an AS particu-
late collection device, typically a wet scrubber. In most cases,
these devices are used both for product recovery and for pollution
control. The air pollution control devices in use in this industry
are discussed in Chapter 4.
3.2.2 Synthetic Ammonium Sulfate Production
Synthetic AS is produced from pure ammonia and concentrated
sulfuric acid. The chemical reaction is essentially the neutralization
of sulfuric acid with ammonia as indicated by the following chemical
equation:
2NH3 (gas) + H2S04 (liquid)—(NH4)2S04 (solid) + HEAT
Ammonia Sulfuric Acid Ammonium Sulfate
This reaction is highly exothermic, liberating approximately
67,710 cal/g mole or 120,000 Btu/lb mole of product. The raw
materials are reacted in neutralizer/crystallizer units designed
with means of controlled heat removal. Heat removal is achieved
by controlled water addition and evaporation under either vacuum
(subatmospheric) or atmospheric pressure conditions. By regulating
water evaporation and slurry recirculation rates in the neutralizer/
crystal!izer, an appropriate amount of cooling/evaporation and percent
of solids in the slurry is achieved for optimum crystal size formation.
Precipitated crystals are separated from the mother liquor (dewatered)
usually by centrifuges. Following dewatering the crystals are dried
and screened to product specifications.
*No. 6 mesh has a particle opening of 0.132 in. and No. 18 a
particle opening of 0.039 in.
3-13
-------
Table 3-4. TYPICAL PARAMETERS FOR A CAPROLACTAM
BY-PRODUCT AMMONIUM SULFATE PLANT DRYER
Parameter
Type/Value
Dryer
Product flow through dryer, Mg/hr (tons/hr)
Air flow through dryer, scm/min (scfm)
acm/min (acfm) @85°C (185°F)
Air flow per ton of product, scm/Mg(scf/ton)
Air temperature
Inlet to dryer °C (°F)
Outlet of dryer °C (°F)
(Inlet to scrubber)
AS Uncontrolled AS emission from dryer
kg/Mg of product (Ib/ton)
Rotary dryer
FB dryer
AS Product temp., and water content, wt. percent
Dryer inlet 66° C (150° F)
Dryer outlet 80° C (175° F)
Water evaporated per ton of product
||
Steam input to dryer kg cal/hr (Btu/hr)
Sat 125 psig at 177° C (350° F)
Rotary or
Fluidized
Bed
23 (25)
825 (29,200)
1000 (35,500)
2490 (80,000)
149 (300)
85 (185)
26 (52)
111 (221)
2.0-2.5
0.1-0.5
24-25 (48-50)
3,024,000
(12,000,000)
3-14
-------
The typical plant configuration for the synthetic AS plant is
shown in Figure 3-3. It is based on the results of four plant
trips and information derived from responses to EPA inquiries.*
Figure 3-3 includes a schematic of a typical synthetic AS plant...
Material flow rates shown in Figure 3-3 are based on a dryer pro-
duction rate of 13.7 Mg/hr (15 tons/hr).
Anhydrous ammonia and concentrated sulfuric acid are combined
in a crystallizer similar to the draft tube baffle type used in
caprolactam by-product AS plants. However, a cooling section^or
external heat exchanger is used to dissipate much of the heat
generated in the reaction. The mother liquor is injected at the
point of reaction to improve the cooling.
The crystal!izer shown has an "elutriation leg" at the magma
discharge. Mother liquor flowing in this leg blows back or "elutri-
ates" the fine particles of AS into the main chamber but allows
the larger particles to pass to the discharge point. This action
tends to produce a uniform crystal size distribution.
The AS crystal slurry leaves the crystallizer at a temperature
of about 95°C, and is pumped to one or more centrifuges. The cen-
trifuges remove most of the mother liquor which is then returned
to the reactor/crystal!izer. No visible emissions were observed
from centrifuges at the four synthetic AS plants visited.
The AS crystals, containing typically 1 to 2 percent moisture,
are then fed to the AS dryer. One plant operator indicates that
during hot days, these crystals can become so dry following centrifu-
23
gation that the dryer can be operated at times without heat. As
in the caprolactam process, the AS dryer is the only significant
emission source in the process. Only rotary dryers are known to
be used in synthetic AS production plants. The dryer gas flows
*Requests for information under the provisions of Section 114 of
the Clean Air Act Amendments of 1977.
3-15
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and the flow rate per ton of product for the four plants visited are
shown in Table 3-5. The parameters for the 13.7 Mg/hr (15 ton/hr)
dryer in the typical synthetic AS plant are shown in Table 3-6.
Based on rotary dryer design information supplied by a vendor
of these units (Table 3-7), the gas flow rate per ton for the
direct-fired dryers appears to be within the range of field measure-
ments. Uncontrolled AS emissions from the rotary dryers are
summarized in Table 3-3, and average 26 kg/Mg (52 Ib/ton) of
product, based on recent EPA emission test measurements (see
Section 4.5).
The product output of the dryer is passed on to screens where
a coarse and standard product may be separated with possible recycle
of fines. Screens are normally located inside a storage building.
Fugitive dust from the screening operations are minimal. The AS
product conveyors and elevators are enclosed and may be located'in
buildings.
The synthetic plants add a small quantity (approximately 0.05
?fi
percent) of a heavy hydrocarbon such as "Armoflow" to the product
as it emerges from the dryer to control caking. The hot AS emission-
laden gases from the dryer are sent through a particulate collection
device for air pollution control and then vented to the atmosphere.
Control devices in use in this industry are discussed in Chapter 4.
3.2.3 Ammonium Sulfate from Coke Oven Gas
In the process of carbonizing coal to coke such as in the
steel industry, coal volatiles including ammonia, ammonium hydroxide
and ammonium chloride are liberated. Many of the bituminous coals
used in coke production contain 1 to 2 percent nitrogen, and approxi-
mately 15 to 20 percent of this quantity can be recovered as ammonia.
Ammonia formation is normally considered to occur at coking temperatures
of approximately 1000°C (1832°F) such as those utilized in steel
27
industry coking operations. The production of ammonium sulfate
3-17
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3-18
-------
Table 3-6. TYPICAL PARAMETERS FOR A SYNTHETIC
AMMONIUM SULFATE PLANT DRYER
Parameter
TypeAValue
Dryer type'
Product flow through dryer
fcons
l\
hr \ hr j
Air flow through dryer scm/min (scfm)
acm/min (acfm) @ 93° C (200° F)
Air flow per ton of products scm/Mg f-^— )
\totij
Air temperature
Inlet to dryer °C (°F) :
Outlet to dryer °C (°F)
AS uncontrolled emission from dryer, kg/Mg
(Ib/ton) of product
Product temp and water content, wt. percent
Dryer inlet 88° C (190° F)
Dryer outlet 93° C (200° F)
Water evaporated per ton of product r^- |—-)
Mg \ tony
Natural gas input to dryer kg cal/hr (Btu/hr)
Rotary, direct-
fired
.13.7 (15.0)
135 (4750)
170 (5920)
620 (20,000)
232 (450)
93 (200)
26 (52)
2.0-2.5
0.1-0.5
24-25 (48-50)
504,000
(2,000,000)
3-19
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3-20
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from coke oven gas is the most common approach taken for the recovery
of ammonia from the coking of coal. The AS production from recovered
ammonia is accomplished by one of three different methods: direct,
indirect and semidirect processes, according to the method of con-
on
tacting the ammonia and sulfuric acid.
, The direct process treats the mixture of volatile off-gases from
coke production by first cooling them to remove the maximum possible
quantity of tar. Following tar removal the gases are passed through
a saturator--either a bubbler or spray type—where they are washed
with sulfuric acid. The AS crystals form in the liquor and are
recirculated in the saturator until the desired crystal size is
formed. After the desired crystal size is realized, this material
is separated from the liquor by centrifugation, washed, dried and
conveyed to storage.
The indirect process was developed primarily to improve AS
crystal purity by further removal of such contaminates as tar,
pyridine and other organic compounds. In this method the volatile
off-gases are first cooled by recirculated wash liquor and scrubbing
water. These liquors are then combined and treated with steam in
a stripping column to release relatively high purity "free" ammonia
present in the forms of such easily disassociated salts as ammonium
carbonate and ammonium sulfide. The partially stripped liquor is
then treated with lime solution to decompose such "fixed" salts as
ammonium chloride. This treated liquor then passes to a second
stripping column where essentially all the remaining ammonia is
freed from the liquor. The stripped ammonia is recovered as a crude
ammonia solution which in turn is redistilled or converted directly
to AS in a saturator/crystallizer.
The semidirect process was developed from both the above
techniques. The volatile off-gases are cooled and washed to remove
the majority of the tar and yield an aqueous condensate containing
a high percentage of the ammonia present in the gas. Ammonia is
3-21
-------
then released from this aqueous condensate in a small still. The
evolved ammonia is then recombined with the main gas stream and the
whole stream reheated to approximately 21°C (70°F). This reheated
gas stream is then scrubbed with 5 to 6 percent sulfuric acid and
a near-saturation 60 to 70 percent ammonium sulfate solution.
Spray-absorbers or saturators are used for this operation. Ammonium
sulfate crystals are formed and removed as product similar to the
previously described procedure. The semidirect process yields an
essentially pure AS and high ammonia recovery,,
In the schematic process flow diagram (Figure 3-4), the first
step is the concentration of ammonia in the coke oven off-gas stream.
The AS is then produced by continuously reacting the concentrated
ammonia stream with sulfuric acid in a simple "saturator." As the
AS product concentrations increase, crystals drop to the bottom of
the reactor and are pumped as a slurry to storage. This type of
process is reported to be the most widely used in the industry.
Alternatively, the detarred coke oven gas stream, which contains
a low percentage of ammonia, is contacted with dilute sulfuric acid
in a stream of mother liquor in an absorber to produce a dilute AS
solution which is then concentrated by evaporation. From this
point on, the plant may be operated in batch-wise fashion with a
frequency sufficient to handle the AS accumulation in storage, or
the AS slurry is processed on a continuous basis. The slurry is
pumped to a settling tank (not shown in Figure 3-4) where it is
settled to a concentration of about 80 percent solids.
As shown in Figure 3-4 the AS is then dried by various pro-
cedures. In one of the plants visited, the AS is then pumped to
a rotary vacuum filter which combines the operations of filtration
and drying.30 In other plants, the two operations may be carried
out in separate units. Alternatively, the dewatering-drying
operation is carried out using a combination centrifuge-dryer or
in a centrifuge followed by a rotary dryer.31 Of the 12 coke plants
3-22
-------
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3-23
-------
recovering by-product ammonia as AS which were surveyed, approximately
half use rotary vacuum filters as dewatering-drying devices and the
balance employ centrifuge-dryers or combinations of separate centrifuges
and dryers.32 Air flow data for plants employing the rotary vacuum
filter dryer and centrifuge dryer are shown in Table 3-8. The
results show an average of approximately 1100 scm/Mg (35,000 scf/ton)
if the plant No. 2 system data are discounted as oversized.
Mother liquor removed in the process is returned to storage
or recycled in the case of the continuous process. The AS product
contains a wide range of sizes from coarse to fine particles. It
is fed by conveyors to a warehouse pile. Normally, no screening
is performed on the product AS. Parameters for the dryer are shown
in Table 3-9 based on an estimated typical production rate of
2.7 Mg/hr (3 tons/hr).
3.3 EMISSIONS UNDER EXISTING REGULATIONS
Allowable AS particulate emission rates under most existing
• state regulations are related to process weight rate which, in
most cases, is the dryer throughput rate. For plants that recycle
screened product, the dryer throughput rate may be higher than the
final production rate. Other states have regulations limiting
particulate emissions from process sources based on concentrations
and/or visible emissions. In Texas, AS particulate emissions are
determined as a function of process vent gas flow. Figure 3-5 is
a display of allowable partiuclate emission rates as a function
of process weight rate for 39 states.
A process weight regulation defined by E (pounds/hour of
emissions) - 4.1 P°'67 (tons/hour of dryer throughput) is used
by the greatest number of states—21 out of 50- for process weight
rates less than 27 Mg/hr. For this reason, this regulation is
selected as the baseline emission level which is used to evaluate
the environmental and economic impacts associated with various emission
3-24
-------
Table 3-8. ESTIMATED AIR FLOWS FOR COKE OVEN
' PLANT AMMONIUM SULFATE DRYERSa
Plant
No.
Production rate, Air flow, Air flow/ton, Reference
System Mg/hr (tons/hr) scm/m (scfm) scm/Mg (scf/ton) Number
Combination
centrifuge and
dryer
Vacuum
filter-dryer
Rotary
5.5 (6.0) 115 (4000) 1250 (40,000) 33
3.4 (3.7) 142 (5000) 2535 (81,000) 34
2.1 (2.3) 29.5 (1040) 845 (27,000) 35
Vacuum
filter-dryer
4.6 (5.0) 79.3 (2800) 1060 (33,800)
36
Estimates based on reported fan or blower sizes.
3-25
-------
Table 3-9. ESTIMATED PARAMETERS FOR A COKE
OVEN AMMONIUM SULFATE DRYER
Parameter
Type/Value
Dryer
. ,
Product flow through dryer
(tons\
--
Air mass flow assumed per ton product
sera
Mg
Air flow through dryer scm/min (scfm)
Air temperature
Inlet to dryer °C (°F)
Outlet to dryer °C (°F)
AS uncontrolled emission from the dryer,
kg/Mg of product (Ib/ton)
Product temperature and water content percent
Dryer inlet - 49°C (120°F)
Dryer outlet - 66°C (150°F)
Water evaporated, kg/Mg (Ib/ton)
Steam heat input to dryer kg cal/hr
(Btu/hr)
Rotary vac. filter-
dryer, centrifuge-
dryer or rotary dryer
2.7 (3.0)
1095 (35,000)
50 (3,500)
149 (300)
80 (175)
10.0 (20.0)a
2.5
0.5
20 (40)
163,800 (650,000)
'Estimated based on 1 percent of AS product appearing as uncontrolled
dryer emissions.
3-26
-------
control alternatives.* As shown in Figure 3-5, this regulation is
also the least stringent regulation for process weight rates less
than 27 Mg/hr. The weighted average allowable emission rate,
considering all state regulations, is estimated to be only 10 to 20
percent less than the selected baseline emission level.
Table 3-10 compares the allowable mass emissions under existing
state regulations with mass emissions based on a 0.044 g/dscm (0.02
gr/dscf) controlled grain loading, for a process weight range of 2.3
to 45.4 Mg/hr (2.5 to 50 tons/hr).
For a typical large AS production train of 23.7 Mg/hr (25 tons/
hr), allowable particulate emissions from the AS dryer show an order
of magnitude spread, ranging from a low of 2.6 kg/hr (5.7 lb/hr}**
for two states (having the most stringent regulations) to a high of
16 kg/hr (35 Ib/hr) for 25 states. For a typical medium sized AS
production train of 13.7 Mg/hr (15 tons/hr), allowable particulate
emissions from the AS dryer also show an order of magnitude spread,,.
ranging from ajow of 1.6 kg/hr (3.4 lb/hr)** for two states to a
high of 11.8 kg/hr (26 lb/hr) for 21 states.
Based on inspections of all the caprolactam AS plants and four
of the eight synthetic AS plants, all of these facilities appear to
be meeting existing state regulations on emissions from the AS dryer.
Observations at the two coke oven AS plants visisted indicated that
the dryers at these facilities were meeting state emission regula-
tions.
*Baseline emission level is that level which can be achieved by
state and local regulations in the absence of additional standards
of performance.
**The high emission values presented are based on equations relating
process emissions to production rate. The low emission values are
based on a fixed allowable grain loading of 0.044 g/dscm (0.02
gr/dscf) and an assumed vent gas flow of 2490 scm/Mg of product
80,000 scf/ton).
3-27
-------
!g
01
• m
o
c
o
01
c
o
rt
4J
iJ m
-------
Table 3-10. COMPARISON OF
GENERAL STATE
Process Weight Rate
Mg/hr
__
2.3
4.5
9.1
13.6
18.1
22.7
27.2
36.3
45.4
(tons/hr)
• , — _
(2.5)
(5.0)
(10.0)
(15.0)
(20.0)
(25.0)
(30.0)
(40.0)
(50.0)
Allowable Emissions
_______
Control to 0.02 gr/dscf1
Typical'
kg/hr (Ibs/hr)
0.3
0.7
1.0
1.5
2.1
2.6
3.1
4.1
5.2
(0.6)
(1.5)
(2.3)
(3.4)
(4.6)
(5.7)
(6.9)
(9.1)
(11.4)
3.5
5.9
8.7
11.4
13.8
16.1
18.1
19.3
20.2
(7.8)
(13.0)
(19.2)
(25.2)
(30.5)
(35.4)
(40.0)
(42.5)
(44.6)
Basis:
2490 dscm/Mg (80,000 dscf/ton)
- 4.! (P, tonsAr ,0.67 „ „
. 55 (P,
3-29
-------
3.4 REFERENCES
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
Development Document for Effluent Limitations Guidelines
and New Source Performance Standards for the Formulated
Fertilizer Segment of the Fertilizer Manufacturing Point
Source Category. U.S. Environmental Protection Agency.
EPA 440/1-75/042-a. January 1975. p. 14.
Chemical Economics Handbook. Stanford Research Institute.
Menlo Park, California. December 1976,, p. 756.6002E.
Ibid., Reference 2. p. 756.6001B.
Data provided by Allied Chemical Corporation, Morristown
New Jersey in a telephone conversation between T. Poole
and M. Drabkin, MITRE Corporation, Metrek Division,
October 3, 1978.
Op. Cit. Reference 2. p. 756.6001C.
Op. Cit. Reference 2. p. 756.60031).
Data provided by U.S. Department of Commerce, Bureau of
the Census, Washington, D.C., in a telephone conversation
between Jack Ambler and Marvin Drabkin os the MITRE
Corporation, Metrek Division, on August 11, 1978.
Op. Cit. Reference 5.
Chemical Engineering.
Op. Cit., Reference 1.
Op. Cit., Reference 2.
Op. Cit., Reference 2.
Chemical Engineering.
March 29, 1976. p. 82.
p. 756.6001C.
p. 625.2031D.
p. 756.6001C.
July 3, 1978. p. 25.
Information provided by SRI International, Menlo Park,
California, in a letter from B. Johnson to S. T. Cuffe,
U.S. Environmental Protection Agency, Research Triangle
Park, North Carolina, May 7, 1979.
Information provided by Amax Metals Corp., Port Nickel, •
Louisiana, in a telephone conversation between VI. Swafford
and M. Drabkin, MITRE Corporation, Metrek Division,
October 3, 1978.
'3-30
-------
16.
17.
18.
19.
20.
MITRE Corporation, Metrek Division, Draft Report (to be
published). A Review of Standards of Performance for New
Stationary Sources--Sulfuric Acid Plants. U.S. Environmen-
tal Protection Agency. MTR-7972. Prepared for the Office
of Air Quality, Planning and Standards, Research Triangle
Park, North Carolina, pp. 4-24.
Rosin, S. M., Process Engineering (England), October 28,
1970.
Information provided by the Fuller Company, Catasauqua,
Pennsylvania, in a letter from R. Aldrich to M. Drabkin,
MITRE Corporation, Metrek Division, August 22, 1978.
Data provided by the Fuller Company, Catasauqua, Pennsyl-
vania, in a telephone conversation between R. Aldrich and
M. Drabkin, MITRE Corporation, Metrek Division, August 18,
1978.
Trip reports from visits to Allied Chemical Corp., Hope-
well, Virginia, Nipro, Augusta, Georgia and Dow Badiche
Company, Freeport, Texas; also responses to 114 letters
to these companies.
21. Information provided by the Allied Chemical.Corp., Hope-,
well, Virginia, in a letter from F. L. Piquet to E. Robisoh,
MITRE Corporation, Metrek Division, on December 20, 1978.
22. Trip reports from visits to Allied Chemical Corporation,
Hopewell, Virginia; Nipco Incorporated, Augusta, Georgia;
and Dow Badiche Company, Freeport* Texas, by the MITRE
Corporation, Metrek Division.
i
23. Information provided by Occidental Chemical Co., Lathrop,
California, in a conversation between D. Mueller and E.
Robison, MITRE Corporation, Metrek Division, June 28, 1978.
24. Trip reports from visits to Occidental Petroleum Corp.
(Lathrop, California, and Houston, Texas plants), Chevron
Chemical Co., Richmond, California and Valley Nitrogen
Producers, Helm, California.
25. Data provided by C-E Process Equipment, Bartlett-Snow
Division, Chicago, Illinois, in a telephone conversation
between F. Aiken and M. Drabkin, MITRE Corporation,
Metrek Division, September 6, 1978.
26. Data provided by Occidental Petroleum Corporation, Houston,
Texas, during a plant visit by the MITRE Corporation,
Metrek Division, June 12, 1978.
3-31
-------
27. Op. Cit., Reference 1. p. 18.
28. Op. Cit., Reference 1. p. 18.
29. McGannon, H. E., The Making, Shaping and Treating of Steel,
9th Edition, Pittsburgh, Pennsylvania, U.S. Steel Corp.
1971.
30. Information provided by Bethlehem Steel Corp., Burns
Harbor, Indiana and reported in the MITRE Corporation,
Metrek Division Internal Memorandum No. W56-M323,
September 15, 1978.
31. Information provided by AS producers and reported in the
MITRE Corporation, Metrek Division-Memorandum No. W58-Z6 to
C Sherwood, U.S. Environmental Protection Agency, Research
Triangle Park, North Carolina, October 27, 1978.
32. Ibid., Reference 31.
33. Data provided by Bethlehem Steel Corp., Sparrows Point,
Maryland, in a telephone conversation between W. Toothe
and E. Robison, MITRE Corporation, Metrek Division,
November 9, 1978.
34. Data provided by Bethlehem Steel Corp., Burns Harbor,
Indiana, in a telephone conversation between G. Shelbourne
and E. Robison, MITRE Corporation, Metrek Division,
November 21, 1978.
35 Data provided by Jim Walter Corp., Birmingham, Alabama,
in a telephone conversation between C. Mason and M. Drabkin,
MITRE Corporation, Metrek Division, November Ifo, 1978.
36. Data provided by U.S. Steel Corp., Lorain, Ohio, in a
telephone conversation between R. Bollock and L. Robison,
MITRE Corporation, Metrek Division, November 21, 1978.
3-32
-------
4. EMISSION CONTROL TECHNIQUES
This chapter discusses the control technology applicable to
dryers at AS manufacturing plants. As discussed in Chapter 3, the
dryer is the only significant source of particulate emissions. At
caprolactam AS plants, the dryer may also be a source of caprolactam
emissions. Fugitive particulate emissions from equipment for screening
and materials handling are not significant; therefore, control
technology for these sources is not discussed.
4.1 FACTORS AFFECTING EMISSION CONTROL TECHNIQUES
The type of emission control equipment applied to the AS dryer
depends on a number of factors, the most important of which are the:
1. Chemical and physical properties of AS,
2. Particle size distribution of the emissions,
3. Amount of uncontrolled emissions in the dryer vent gas.
4.1.1 Chemical and Physical Properties of Ammonium Sulfate
At the operating temperatures of the dryers (in the 100° to
150°C range), AS emissions occur as a solid particulate. Only above
a temperature of 235°C will it decompose. The solid is an inorganic
salt, but it can become contaminated with organic impurities such as
caprolactam at caprolactam by-product AS plants and tars at coke oven
by-product AS plants. Because the salt exhibits moderately high
solubility in water, wet scrubbing is commonly used. Figure 4-1
shows the relationship of solubility and AS solution temperature. At
some plants the scrubber solution concentration is maintained near
the saturation limit (approximately 45 percent AS at plant operating
temperatures). The AS scrubber solution is strongly acidic (pH of 2
to 4), necessitating consideration to materials of construction. The
AS is moderately hygroscopic and has a tendency to agglomerate into
hard lumps on absorption of moisture while in storage. Organic anti-
caking agents, required for the synthetic AS product, are added to
4-1
-------
M
H
O
1
50
49
48
47
46
45
44
43
42
41
40
o; 20 40 60 80 100 120 140 160 180 200 220
TEMPERATURE F
FIGURE 4-1
SOLUBILITY OF AMMONIUM
SULFATE IN WATER VS TEMPERATURE
4-2
-------
the dryer product; therefore, they do not pass through the control
device.
4.1.2 Particle Size Distribution of Uncontrolled AS Emissions
Test data have been obtained on the particle size distribution
of uncontrolled AS particulate emissions from a number of different
dryers and are presented in Figure-4-2*. These results indicate that
from 93 to 99+ percent by weight of the particles are greater than 1
micron. It should be noted that the particle size distribution from
the one fluidized bed dryer tested (Plant B) indicated a signifi-
cantly larger percentage of particles greater than 1 micron (over
99.9+ percent) as compared with the rotary dryer results—the latter
ranging from 93 to 99.9 percent greater than 1 micron.
4.1.3 Uncontrolled AS Emission Rates
The mechanism responsible for entrainment of particulate matter
by dryer gases is aerodynamic drag. The drag force depends upon
several factors such as gas and particulate velocities and the physi-
cal properties of the gas and solid.
The gas velocity and particle size distribution of the dryer
feed are the primary factors influencing uncontrolled dryer emission
rates. The type of dryer or type of mechanism for moving the solids
through the dryer (rotating flights or fluidizing air) also affects
the quantity of particulate which becomes airborne. Figure 4-3
shows the relationships between gas flow and uncontrolled AS dryer
emission rates for the facilities tested by EPA.
The uncontrolled AS emission rate of 111 kg/Mg (212 Ib/ton)
measured from one fluidized bed dryer, is higher than the rates
measured from three rotary dryers ranging from 0.4 kg/Mg to 77 kg/Mg
(0.8 Ib/ton to 153 Ib/ton). Fluidized bed dryers would, therefore,
*Detailed tabulations of particle-size distribution test results are
presented in Appendix C, Tables C-12 through C-15.
4-3
-------
to
E
-------
100
• D/
10 _
o
S-
-»J
o
u
CO
cr>
CD
1.0
«O
O
i-
ro
Q.
OO
ear
0.1
10
I
100
Gas Flow Rate
(dscm/Mg Product)
1,000
Figure 4-3. Uncontrolled AS Emissions Versus Gas Flow
4-5
-------
appear to require more efficient control equipment in order to comply
with air pollution regulations (see Table 3-3).
4.2 DISTRIBUTION OF EMISSION CONTROL EQUIPMENT IN THE AS
MANUFACTURING INDUSTRY
In most cases, the incentive for installing particulate control
equipment to collect dryer emissions was to achieve compliance with
state and local air pollution regulations. However, at one plant
using fluidized bed drying, the recent EPA test indicated that uncon-
trolled emissions are about 10 percent of dryer capacity.* In this
situation, AS particulate emission control is required for process
feasibility as well as for compliance with pollution control regula-
tions.*
Scrubbers are commonly used to control particulate emissions
in all segments of the AS industry. At the three existing capro-
lactam AS plants, wet scrubbers are employed to control particulate
emissions. At synthetic AS plants wet scrubbers are predominately
used. The only dry pollution control system In service is a fabric
filter baghouse at one synthetic plant. For those coke oven facilities
which dry or pneumatically convey AS, no emission control system is
employed or relatively inefficient control devices such as cyclones
are installed.** This data is based on surveys of nine steel com-
panies which account for about 75 percent of total coke oven by-
product AS production.
4.3 WET SCRUBBING IN THE AMMONIUM SULFATE INDUSTRY
Wet scrubbing is used in the majority of .AS manufacturing
facilities for AS particulate removal from the dryer vent gas
stream. Available information on performance of wet scrubbers in use
*See Appendix C, Table C-4
**The cyclones are considered primarily as items of process equipment
being used for product recovery, and therefore, they are not dis-
cussed as emission control equipment.
4-6
-------
by the AS manufacturing industry, is presented in Table 4-1. As
indicated by the table, most of the scrubbers in use are of the low
energy type with pressure drops equal to or less than 15.24 cm.
(6 in.) WG. Very few of these scrubbers have been installed in
recent years. Although many of these scrubbers are of the low energy
type, they are adequate to meet present state and local air pollution
regulations. Each type of scrubber commonly used in the industry
including those which are candidates for "best demonstrated control
technology" are discussed briefly in the following sections.
4.3.1 Venturi Scrubbers
The venturi scrubber is an air pollution control device in
which the scrubbing liquid is atomized in a moving gas stream.
Venturi scrubbers are used to control dryer emissions at some AS
plants and in many particulate control applications in other indus-
tries. Collection efficiency is enhanced by three dominant factors:
inertia! impaction, condensation of water vapor on the particulate '
and in this application the high solubility of AS in water. In the
venturi throat region, the gas velocity is considerably higher than
that of the accelerating liquid. This causes the AS liquid solution
to atomize into many fine droplets. Particulates impinge upon the
slower moving liquid droplets by inertia! impaction. Also, the
dryer exhaust temperature and humidity of the gas promotes condensa-
tion of water vapor on the particulates. The increased wetness and
weight of the particulates increases the probability of their impinge-
ment on wetted surfaces as a result of inertia! impaction.
Two existing AS plants are known to employ venturi scrubbers to
control particulate emissions—Plants B and D. Both units accept the
full AS dryer particulate emission with no intermediate cyclones.
Table 4-1 shows that the pressure drops and liquid-to-gas ratios are
very similar. Pressure drops of the Venturis at Plant B and Plant D
are 25.4 dm. (10 in.) and 33,0 cm. (13 in.) WG, respectively. These
4-7
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I
Venturis are considered to operate in the low pressure drop range
12.7 to 50.8 cm. HG as compared with medium and high pressure drop
venturi scrubbers which operate at 50 to 100 cm. HG and 100 to 150
cm. HG, respectively.
The Plant D and Plant B units are both operated with high
'liquid-to-gas ratios (3605 and 3075 liters/lOOOH3, respectively)
as compared to liquid-to-gas ratios normally encountered in other
industries, i.e., in the 900 to 1350 range.7. For a given venturi
scrubber design, and with gas flow rate determined by the AS dryer
operation, AS particulate collection efficiency becomes a function
of liquid-to-gas ratio. The high liquid-to-gas values encountered
in the Plant D and Plant B operations appear to be needed to ensure
high AS particulate efficiency, especially for the smaller particle
sizes.
Company-supplied emission test data on the Plant B venturi
scrubber are summarized in Table 4-1. The test appears to have been
performed using the EPA Method 5 procedure. Based on test measure-
ments of both scrubber inlet and outlet, the average collection
efficiency is 99.96 percent. The data also shew low scrubber outlet
AS particulate concentration of 10.4 mg/dscm (0.005 gr/dscf) and
0.04 kg/Mg of AS production. A 25 percent AS solution was used as
scrubbing liquid. Although this test was conducted at approximately
50 percent of the maximum AS production rate, the collection effi-
ciencies are similar to those measured during a period of full
production. Results of recent EPA emission test values obtained
on this scrubber as well as the Plant D venturi scrubber are presented
in Section 4.5.
4.3.2 Centrifugal Scrubbers
Centrifugal scrubbers are employed at a number of AS plants to
control dryer emissions. Particulate-laden gas usually enters the
scrubber tangentially, imparting a spinning motion to the gas. The
• 4-10
-------
AS participates are captured by their impacting on droplets of water
or weak AS solution and/or by their contact with wetted surfaces.
For some types of scrubbers, collection efficiency is enhanced by
directing the gas against rotating vanes. The pressure drops
reported from AS plants range from 7.6 cm. to 33.0 cm. (3 to 13 in.)
WG (see Table 4-1). However, higher pressure drops for centrifugal
scrubbers do not necessarily imply higher efficiencies. Efficiencies
vary widely among different types of centrifugal scrubbers.
Ducon centrifugal scrubbers are employed at two of the three
existing caprolactam AS plants. The Ducon Company UW-4 scrubber is
reported to be capable of achieving higher removal efficiencies than
their UW-3 centrifugal scrubber. Collection efficiency for the UW-3
is estimated to be about 95 percent for particulates 3 micron in
diameter and larger. Collection efficiencies for the UW-4 are
estimated to be about 98 percent for particulates greater than 1
micron. . Energy requirements are generally lower than those of
venturi scrubbers.
Industry-supplied emission test data are available on centrifugal
scrubbers (all with a liquid-to-gas ratio of approximately 267 liters/
1000M ) employed for AS particulate control at various AS production
plants (see Table 4-1). Scrubber outlet grain loadings vary from a
low of 36 mg/dscm (0.016 gr/dscf) to a high of 660 mg/dscm (0.294
gr/dscf); mass emissions varied from 0.07 to 0.35 kg/Mg of AS
production. There are no scrubber inlet data available so that
scrubber efficiencies cannot be determined. It is not known how
closely EPA Method 5 test procedures were followed for many of the
tests. EPA emission tests were recently conducted on one of these
centrifugal scrubbers with the results shown in Section 4.5.
4.3.3 Rotool ones
Type "N" Rotoclones (a trade-name of American Air Filter Corp.)
are employed at one AS production plant and in similar applications
4-11
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in other Industries. Particulate-laden gas Is ducted through a
stationary impeller at high velocity, forcing the scrubber liquor to
fora a turbulent sheet. The centrifugal force, exerted by rapid
changes in the direction of flow, causes the AS particulates to
impinge on the turbulent sheet. Vendor design efficiency data
indicate that general particulate collection efficiency typically
ranges from 93 to 99.3 percent for particulates 3 micron in diameter
for type "N" Rotoclones with pressure drops of 15.24 to 28 cm. (6 to
q
11 in.) WG and high liquid-to-gas ratios.
As indicated in Table 4-1, data are available on two "Type N"
Rotoclones. Pressure drop in both these units is given as 12.7 cm.
(5 in.) WG. However, the liquid-to-gas ratio involved in these two
AS scrubbing operations is difficult to determine, since the liquid
circulation is entirely internal. Scrubber outlet grain loadings
showed a ten-fold variation ranging from 68 mg/dscm (0.03 gr/dscf)
to 704 mg/dscm (0.31 gr/dscf). Mass emissions varied from 0.03 to
0.35 kg/Mg of AS production. It is not known how closely EPA Method 5
test procedures were followed in these tests.
.* ' ,
4.3.4 Packed Tower Scrubbers
Only two packed tower scrubbers are known to be in use at AS
plants (see Table 4-1). Neither of these units appears to be
standard design. Collection efficiency depends on the liquid-to-gas
ratio, pressure drop, and other factors. Pressure drops are cominonly
about 4.0 cm. WG/Meter (0.5 in. WG/ft) of packing.10 One plant which
designed its own packed tower scrubber reports an estimated collection
efficiency of less than 90 percent.11 At another plant a spray chamber
scrubber is used in series after a packed tower scrubber. Collection
efficiency of properly designed packed tower scrubbers is comparable
with other low-energy-type scrubbers.
4.3.5 Spray-Type Scrubbers
Spray-type scrubbers are used at several older AS plants to
collect AS particulate (Table 4-1). Spray nozzles are used to
4-12
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atomize the liquid to form fine droplets. The pressure drop is
relatively low, usually 2.5 cm to 5.0 cm. (1 to 2 in.) WG, and the
operating costs ere minimal. Collection efficiencies of the spray-
type of contact scrubber are usually not competitive with medium
and high energy scrubbers, Efficiencies for most types of 2 micron
12
particulates are typically near 75 percent.
4.4 ' FABRIC FILTRATION IN THE AMMONIUM SULFATE INDUSTRY
All fabric filters (baghouses) operate in basically the same
way; dirty gas is ducted to the unit where it is filtered by cloth
tubes or bags. This filtering action is extremely efficient and
results normally in better than 99 percent of the entrained particles
being removed by the bags. The bags must be periodically purged of
this collected material. The method and frequency of cleaning
differentiates one type of baghouse from another.
Only one domestic AS producer employs a baghouse for AS particu-
late control—Plant A. This firm uses a Carter-Day baghouse, Model
24RJ60, with a reverse jet cleaning mechanism. The unit has 30 m
(320 ft2) of filter cloth which comprises 24 bags. The filter
medium employed is Dacron®felt, which is reported to have good acid
resistance and flex abrasion.
At Plant A, the exhaust gas from the dryer passes directly to
the baghouse, through the filters, to a blower, and out the stack.
At the operating gas flow rate of approximately 35 m /min (1250
acfm) the gas-to-cloth (GC) ratio of this baghouse is 4.* This
ratio appears to be somewhat lower than in other industries using
14
felted bags.
*The basic design parameter used in specifying any baghouse for any
application is the gas-to-cloth ratio, defined as the ratio of
actual gas-flow to net cloth area. Thus,
GC = I/A
where GC = gas-to-cloth ratio in feet/minute
I = volumetric gas flow in acfm
A = net cloth area in square feet
4-13
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At Plant A, the dryer exhaust gas temperature ranges from
ambient* to 80°C (176°F), with an average operating temperature of
about 54°C (135°F). Due to the baghouse GC constraint on the gas
flow rate, the ratio of dryer exhaust gas to product rate is signif-
icantly lower than most other dryers used by the industry.** This
low flow rate appears to be compensated by the low moisture content
and high sensible heat content of the feed entering the dryer.
While the baghouse at this plant represents one of the most
efficient types of particulate collection devices, it should also
be noted that the plant operates only intermittently and encounters
frequent operational problems associated with the use of the fabric
filter system.
In spite of the fact that insulation covering the ductwork and
baghouse minimizes temperature drop in the dryer exhaust gas, the
following evidence indicates that the temperature of the dryer exhaust
and/or baghouse surfaces were not maintained sufficiently above the
dew point at all times:***
1. AS accumulations on the inside wall of the inlet ducts.
2. Periodic baghouse shutdown for bag removal, laundering, and
reinstallation (every 30 days).
3. Daily flushing of the cone discharge section of the bag
house with water.
" *During hot weather it is reported that the dryer Is sometimes
operated with burner shutoff, in effect operating the dryer as
an evaporative cooler. .
**The baghouse in use at Plant A was originally designed for
another application; the maximum allowable design gas flow
rate to this unit is appreciably lower than the normal
direct-fired dryer gas flow (see Table 3-7).
***Based on a measured 13 percent water vapor concentration in
the dryer exhaust at this plant/ the dew point of the
exhaust gas stream is estimated to be about bi
4-14
-------
Although fabric filters are susceptible to condensation problems,
maintaining the temperatures of all surfaces above the dew:point would
probably alleviate bag blinding and the associated problems listed
above. It is likely, however, that maintaining baghouse temperatures
above the dew point may require more energy than would ordinarily be
required to operate the dryer.
Currently there is no data available regarding the use of fabric
filter particulate control systems on caprolactam by-product AS plants.
However, at the one caprolactam by-product plant tested by EPA, results
show that most of the hydrocarbon (HC) emissions from the AS dryer
(about 94 percent) are present in the vapor phase at the exit gas
temperatures involved, about 85°C. At this operating temperature
condensation of caprolactam vapor should be minimal and it is unlikely
that blinding* would occur.16'17'18'19
4.5 EPA EMISSION TEST DATA '
Based on a survey of the AS production industry which included
visits to all three caprolactam AS plants, four synthetic AS plants
and two coke oven AS plants, it was determined that very few plants
met the criteria for AS particulate emission testing. These criteria
included:
• Best demonstrated control technology
6 Reasonably nonturbulent flow field
• Accessibility of control equipment ports
• Control equipment age and/or condition
• Availability of ports and support scaffolding
• Representative plant capacity
Best demonstrated control technology was determined based on an
evaluation (in the case of wet scrubbers) of available data on
*The embedded "dust" blinds or plugs the fabric pores to such extent
that the fabric resistance become permanently excessively high.
Excessive resistance results in high operating energy requirements
for the system.
4-15
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scrubber pressure drop and liquid-to-gas ratio as well as the types
of wet scrubbers in use in the industry. Three plants with wet
scrubbers (including one caprolactam AS plant and two synthetic
AS plants) were chosen for emission testing based on consideration
of all of the above factors. The one dry AS particulate control
system in use (baghouse) was chosen for testing since it represents
a unique application of this control method in the AS manufacturing
industry. Table 4-2 lists those facilities which have been tested
together with the control equipment in use.
Emission testing was carried out by EPA contractors at each of
facilities A through D using EPA Method 5 to determine AS particulate
emission rates and grain loading at the inlet and outlet of each of
the control devices. In addition, caprolactam inlet and outlet
emission levels were determined at Plant B. At all of the facilities
Table 4-2. AS PARTICULATE CONTROL SYSTEMS TESTED BY EPA
Plant
Designation
A
B
C
D
E
Controlled
Facility
Rotary
Dryer
Fluid Bed
Dryer
Rotary
Dryer
Rotary
Dryer
Fluid Bed
Dryer
Control Technology
In Use
Baghouse
Venturi Scrubber
Centrifugal
Scrubber
Venturi Scrubber
Cyclones and
Centrifugal
Scrubber
*This was a company-sponsored emission test; the EPA Method 5
procedure used by the test contracter has been accepted by EMB.
4-16
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tested by EPA, particle size distributions were determined for AS
participate at the inlet to the respective control devices.
Detailed tabulations of AS emission test results are presented
in Appendix C, Tables C-l through C-10. Detailed tabulations of
caprolactam concentrations and emission rates, which are determined
at Plant B, are presented in Appendix C, Tables C-ll and C-12.
Detailed tabulations of particle size distributions determined,at
the four facilities tested are presented in Appendix C, Tables C-13
through C-16. Detailed tabulations of the observed opacities for the
four plants tested are given in Tables C-17 through C-20. Summarized;
descriptions of each of the facilities tested are presented in^
Appendix C. r • ; -v, -
. ' The emission tests at facilities A through D are presented in
terms of calculated controlled AS grain loadings in Figure 4-3 and
calculated controlled mass emission rates in Figure 4-4. Averages
of this test data together with available industry data, the latter
believed to be the result of valid EPA Method 5 testing, are shown
in Figures 4-5 and 4-6 on grain loading and mass emission bases,
respectively.
The AS particulate emission results calculated in terms of a
mass emission rate (Figures 4-4 and 4-6) are based on an indirect
determination of dryer process weight rate, since all-existing plants
visited and/or tested except one (Plant D) have no AS'dryer product
weigh scales. Additionally, it was indicated that Plant D's weigh
scale was not reliable so that AS production was based on metered
sulfuric acid consumption to the process. A discussion of methods
and accuracy of AS production rate, indirectly determined at the
plants tested, is presented in Appendix E.
Of the six data points shown in Figuresx4-5 and 4-6, five
represent wet scrubber operation, with two of these points repre-
senting the Plant B venturi scrubber. In the EPA test this scrubber
achieved an average controlled grain loading of 0.046 g/dscm (0.021
gr/dscf), an average mass emission rate of 0.16 kg/Mg, and an average
4-17
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FIGURE 4-4
CONTROLLED AS PARTICULATE EMISSIONS FROM EPA
EMISSION TESTS—CALCULATED GRAIN LOADINGS
4-18
-------
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FIGURE 4-5
CONTROLLED AS PARTICIPATE EMISSIONS FROM EPA
EMISSION TESTS—CALCULATED MASS EMISSION RATES
4-19
-------
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FIGURE 4-7
AVERAGE CONTROLLED AS MASS EMISSION RATE DATA—
EPA METHOD 5
4-21
-------
collection efficiency of 99.85 percent when operating at close to full
plant capacity. The emission test conducted by the company reported
a 0.011 g/dscm (0.005 gr/dscf) grain loading and a mass emission
rate of 0.04 kg/Mg of AS production at an average efficiency of
99.98 percent. As mentioned earlier, however, this result was
obtained at about one-half of plant capacity.
The venturi scrubber at Plant B has also been demonstrated to
collect over 88 percent of caprolactam emissions from the AS dryer.
This percentage is higher than that based on test data supplied by
the company which indicated 50 to 60 percent caprolactam collection
efficiency.21 At Plant B, 94 percent of the caprolactam emissions
in the dryer exhaust are in the gaseous state. The caprolactam
emissions coming out of the stack are also mostly gaseous-97 percent
measured in the vapor phase.
Two sets of baghouse outlet emission tests were conducted at
Plant A, since the first set of tests were rejected due to discovery
of some defective bags which resulted in an abnormally high grain
loading result. The second set of baghouse outlet tests resulted in
an average mass emission rate of 0.007 kg/Mg of AS production and an
average 0.022 gr/dscf grain loading. Coupled with the average inlet
results from the first set of tests, the baghouse showed a collection
efficiency of 98.7 percent. This efficiency was somewhat lower than
expected since baghouses are normally capable of 99+ p'ercent effi-
ciency. Of the factors influencing emission rates at Plant A, one
is most significant. The baghouse in use was originally designed
for another application; the maximum allowable design gas flow rate
to this unit is appreciably lower than normal direct-fired gas flow.
The constraint on gas flow rate, by restricting the ratio of dryer
exhaust gas-to-product rate, results in a significantly lower
uncontrolled inlet emission rate than most other dryers used in
the industry. The fabric filter inlet uncontrolled emission rate was
0.41 kg/Mg of production. Those of facilities controlled by venturi
4-22
-------
scrubbers were 110 kg/Mg and 77 kg/Mg. This represents an uncontrolled
mass emission difference in the range of two orders of magnitude.
Facility D, a synthetic AS plant with a rotary drum dryer, is
controlled by a venturi scrubber operating at a pressure drop of 33
centimeters (13 inches W.6.) and a L/6 ratio of 3,600 liters/1000 m3
(27 gallons per 1000 acf). Analysis of EPA test results at Plant D
show a high uncontrolled emission rate entering the control device;
the control system did however demonstrate the typically high control
efficiency (99.8 percent) achievable with a venturi scrubber. The
outlet emission rate, 185 milligrams per dry standard cubic meter and
0.158 kg/Mg of product, was affected by the high inlet emission load
caused by a process variation at Plant D. It was indicated that the
crystallizer at Plant D periodically goes into a fines cycle, lasting
anywhere from 10 to 15 hours, during which time a much heavier proportion
of AS fines is produced in the dryer product than is normal.
Test E (the industry-supplied outlet grain loading result for
which an emission test report was available), shown in Figure 4-5,
represents a low-energy wet scrubber—a centrifugal scrubber opera-
ting at a nominal AP of about 23 cm. (9 in.) WG and an liquid-to-gas
ratio of 267 liters/lOOOm3.22 It should be noted that this unit
operates downstream from a set of cyclones which remove a significant
portion of the AS particulate from the dryer vent gas prior to treat-
ment in the wet scrubber. Additionally, no opacity during a preliminary
screening of this plant was noted to be at least 10 percent.
23
4-23
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4.6 REFERENCES
1. Perry, J. H., Chemical Engineering Handbook, McGraw Hill
Publishing Company, N.Y., N.Y., 3rd Ed., p. 196.
2. Jackson, B. L. and Marks, P. J., Source Emissions Test
Report, Occidental Chemical Co., Houston, Texas, Ammonium
Sulfate Dryer Baghouse, R. F. Weston, Inc., EPA Contract
No. 68-02-2816, Draft Report, p. 24.
3 Clayton Environmental Consultants, Inc., Draft Report,
Emission Testing at an Ammonium Sulfate Manufacturing
Plant, U.S. Environmental Protection Agency Report
No. 78-NHF-l, Southfield, Michigan, November, 1978, p. 13.
4 Scott, Environmental Technology, Inc., Particulate Emissions
From An Ammonium Sulfate Plant Controlled by a Cyclonic
Scrubber. U.S. EPA Contract No. 68-02-2813, Work Assignment
No. 27, Draft Report, p. 2-4.
5. Scott, Environmental Technology, Inc., Particulate Emissions
From An Ammonium Sulfate Plant Controlled by a Venturi
JfcSbber. U.S. EPA Contract No. 68-02-2813,, Work Assignment
No. 28. Draft Report, p. 2-4.
6. Cheremisinoff, P. N. and Young, R./.. Wet Scrubbers - A
Special Report, Pollution Engineering, Volume 6, No. b,
p. 34, May, 1974.
7. Cheremisinoff, P. M. and Young. R. A , Air Pollution Control
and Design Handbook, Marcel Dekker, Inc., N.Y., N.Y., iy//,
' Part 2, p. 751.
8 Data provided by the Ducon Company, Mineola, N.Y., 1n*
telephone conversation between H. Krockta and Craig Sherwood
of U.S. EPA, OAQPS on December 20, 1978.
9. Data provided by American Air Filter, Inc.,, Louisville,
Kentucky, in a telephone conversation between W. Klimczak
and Craig Shemood of U.S. EPA, OAQPS on December 11. 1978.
10. Op. C1t., Ref. 34, p. 35.
11. Response of Occidental Petroleum Corp., Plainview, Texas,
to EPA 114 request.
12 Maqill, P. C., et al., Air Pollution Handbook, McGraw-Hill
' Book Co., N.Y., N.Y., 1956, p. 13-48.
4-24
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13. Theodore, L. and Buonicore, A. J., Industrial Air Pollution
Control Equipment for Particulates, CRC Press, 1976, p. 258.
14. Ibid, p. 288.
15. Op. Cit., Ref. 2, p. 20.
16. Information provided by Dow-Badische, Company in a telephone
conversation between R. Ray and R. Zerbonia, PES, April 19,
1979.
17. Information provided by Mclluaine, Company in a telephone
conversation between M, Mclluaine and R. Zerbonis, PES.
May 2, 1979.
18. Information provided by Joy Manufacturing Company, in a
telephone conversation between R. Hide and R. Zerbonia,
PES, May 2, 1979.
19. Control Techniques for Particulate Air Pollutants, U.S.
Environmental Protection Agency, AP-51, p. 118.
20. Information provided U.S. EPA, OAQPS, Durham, North Carolina,
in a telephone conversation between Craig Sherwood and
Marvin Drabkin of The MITRE Corporation, Metrek Division,
on January 12, 1979.
21. Information provided by Dow Badische Company in response
to EPA 114 letter inquiry.
22. Neck, S. L., Source Test Report - Columbia Nitrogen Corporation,
Augusta, Georgia, August 9, 1977. Ammonium Sulfate Plant -
N003 Scrubber, Technical Services, Inc., Jacksonville, Florida.
23. Op. Cit., Reference 7.
4-25
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5. MODIFICATION AND RECONSTRUCTION
5.1 BACKGROUND
Upon promulgation, NSPS apply to all affected facilities that
are constructed, modified, or reconstructed after the date of proposal
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 these provisions, 40 CFR 60.14 and 60.15, respectively, 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 .the modification/
reconstruction provisions to the affected facility (the AS dryer) and
details conditions under which existing facilities could become subject
to standards of performance. Section 5.2 examines the general provisions
applicable to modification and reconstruciton. Section 5 3 relates
these provisions to the AS industry and process dryer. The enforcement
division of the appropriate EPA regional office should be contacted
regarding any questions on modification or reconstruction applicability.
5.2 40 CFR PART 60 PROVISIONS FOR MODIFICATION AND RECONSTRUCTION
5.2.1 Modification
§60.14 defines modification as follows:
". • ..any physical or operational changes to an existing
facility which results in an increase in the emission rate
to the atmosphere of any pollutant to which a standard applies
shall be considered a modification within the meaning of section
111 of the Act. Upon modification, an existing facility shall
5-1
-------
become an affected facility for each pollutant to which a standard
applies and for which there is an increase in the emission rate to
the atmosphere."
Paragraph (e) lists certain physical or operational changes which
by themselves are not considered modifications. These changes include:
a. Routine maintenance, repair, and replacement.
b. An increase in the production rate not requiring a capital
expenditure as defined in 60.2(bb).
c. An increase in the hours of operation.
d. 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. (Conversion to coal, as
specified in lll(a)(8) of the Clean Air Act, is also exempted.)
e. 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.
f. The relocation or change in ownership of an existing facility.
Paragraph (b) clarifies what constitutes an increase in emissions
in kilograms per hour and the procedures for determining the increase
including the use of emission factors, material balances, continuous
monitoring system 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 per-
formance. Paragraph (f) simply provides for superseding any conflicting
provisions.
5.2.2 Reconstruction
§60.15 regarding reconstruction states:
"An existing facility shall be considered an affected
facility by the Administrator upon reconstruction through
5-2
-------
the replacement of a substantial majority of the existing
facility's components irrespective of any change of emission
rate. The owner or operator may request the Administrator
to determine whether the proposed reconstruction involves
replacement of a substantial portion of the existing facility's
components based on the capital cost of all new construction and
other technical and economic considerations."2
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, housing, etc., rather than
totally replacing it in order to avoid subjugation to applicable stan-
dards of performance. As noted, upon request EPA will determine if the
proposed replacement of an existing facility's components constitutes
reconstruction.
5.3 APPLICABILITY TO AMMONIUM SULFATE PLANTS
5.3.1 Modification
Investigation of the AS industry has shown that there are no
actions or changes, either physical or operational, applicable to the
AS dryer that would qualify as a modification. There are, however,
potential actions or changes which may increase AS emissions but are
not to be considered as modifications to existing AS dryers, irrespective
of any change in the emission rate.
5.3.1.1 Maintenance, Repair, and Replacement
Maintenance, repair and component replacement which are considered
routine for a source category are not considered modifications under
§60.14 (e)(l). An increase in emissions is not expected to
occur as a result of normal maintenance or replacement of AS dryer
components.
5-3
-------
Routine maintenance would involve periodic cleaning out of accumu-
lated deposits of AS on the dryer walls and lubrication of moving parts
such as the drive gears and trunnion rolls on a rotary dryer and motor
drives on air blowers. Routine maintenance should not have any notice-
able effect on dryer emissions.
Several dryer components can be expected to require replacement
as a matter of routine due to the unit being in continuous service
for long periods of time. These components may include the oil or gas
firing nozzles supplying heat to direct-fired rotary dryers, fan
blades in the air blowers, and drive gears and trunnion rolls on
rotary dryers. Replacement with equivalent components should not
affect emissions and would be considered exempt under §60.14(e)(l).
5.3.1.2 Alternative Fuel
The use of an alternative fuel would not be considered a modifi-
cation if the existing facility was designed to accommodate the
alternative. In the case of a direct-fired rotary dryer originally
designed to use oil or gas as fuel, the substitution of oil for gas
would be considered exempt under §60.14(e)(4).
5.3.1.3 Addition of a System to Control Air Pollutants
The addition or use of any system or device whose primary function
is to reduce air pollutants, except the replacement of such a system
or device by a less efficient one, is not by itself considered a
modification under§60.14. For example, the replacement of a rela-
tively inefficient cyclone with a venturi scrubber in an existing dryer
installation, for the purpose of reducing AS particulate that would
otherwise be emitted to the atmosphere, would not be considered a
modification under §60.14(e)(5).
5-4 '
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5.3.1.4 Increase in Production Rate Without a Capital Expenditure
An increase in production rate of an existing facility is not in
and of itself a modification under §.60.14 if the increase can be
accomplished without incurring a capital expenditure on the plant
containing the affected facility.*
Ammonium sulfate dryers are generally overdesigned for recommended
throughput. It is possible for an AS production plant to increase the
amount of AS throughput in the dryer and still achieve the required
amount of moisture removal. This increase in the dryer production rate
would not be considered a modification under §60.14(e)(2). If the
need for increased capacity requires a capital expenditure to modify
the dryer, then that dryer may be considered a modification under this
section. Should expansion of AS plant capacity require a new dryer,
then the new dryer would be considered an affected facility subject to
the NSPS.
5.3.1.5 Equipment Relocation
Relocation of a dryer within the same plant would not constitute
a modification.
5.3.1.6 Removal -or Disabling of a Control Device
The intentional removal or disabling of any emission control
component of an existing dryer installation which would cause an
increase of emissions would be a modification. An existing facility
that is modified becomes an affected facility subject to the NSPS.
*capltal expenditure is defined as "an expenditure for a physical or
operational change to an existing facility which exceeds the product
of the applicable annual asset guideline repair allowance percentage
specified in the latest edition of Internal Revenue Science Publica-
U?5 * Iuan? the 6x1st1n9 facility's basis, as defined by Section
1012 of the Internal Revenue Code." (40 CFR 60, Sect. 60 2[bb])
5-5
-------
The reconstruction provision (§60.15) is applicable only where an
existing facility is extensively rebuilt. Determination is based on
the capital cost of all new construction and other technical and economic
considerations. An action that would be construed as reconstruction of
an AS dryer is the replacement or extensive rebuilding of the dryer
shell and internals.
Ammonium sulfate dryers are expected to have a useful life of 25
years, on the average. It is not believed practical to attempt major
reconstruction of these since the costs involved would be comparable to
those for new units, and considerable plant downtime could be involved.
5
The usual practice is to replace the entire unit at this point. The
new AS dryer would then be subject to the NSPS.
5-6
-------
5.4 REFERENCES
U.S. Environmental Protection Agency. Code of Federal Regu-
l«o ??i(CFR)» T1tle 40» Protection of Environment, Section
60.2 (h), Definitions. Office of the Federal Register.
Washington, D.C., revised as of July 1, 1977. p. 6.
U.S. Environmental Protection Agency. Code of Federal Regu-
ln !?nsn'CFR)> Title 40» Protection-of Environment, Section
60.15, Reconstruction. Office of the Federal Register
Washington, D.C., July 1, 1977. p. 18.
Data provided by C-E Process Equipment, Bartlett-Snow Division,
Chicago, Illinois, 1n a telephone conversation between Fred
A1ken and Marvin Drabkin of the MITRE Corporation, Metrek
Division, on January 29 1979.
4. Ibid., Reference 3.
5. Ibid., Reference 3.
1.
2.
3.
5-7
-------
-------
6.0 MODEL PUNTS AND REGULATORY ALTERNATIVES
The purpose of this chapter Is to define model plants and Identify
regulatory alternatives. Model plants are parametric descriptions of
the types of plants that, In EPA's judgment, will be constructed
modified, or reconstructed. The model plant parameters are used'as a
basis for estimating the environmental, economic, and energy impacts
associated with the application of the regulatory alternatives (ways
in which EPA could regulate emissions from AS dryers) to the model
plants.
6.1 MODEL PLANTS
Since the dryer is the only significant emission source in the AS
industry, each AS model plant refers to a specific combination or set
of dryer operating conditions. Therefore, in this case, a model plant
may be more appropriately called a "model dryer."
Each AS manufacturing sector 1s unique from a technical stand-
point. Dryer types and sizes, gas-to-product flow rates, and uncon-
trolled particulate emission rates vary from one sector to another and
often within each sector. For this reason, it was apparent that no
single model plant (or dryer) could adequately characterize the AS
industry. Accordingly, several model plants were specified in terms of
the appropriate parameters.
Table 6-1 lists model dryer parameters used in the environmental,
energy, cost and economic analysis for each industry category: capro-
lactam AS. synthetic AS and coke oven AS. Each industry sector is
represented by a single plant size consisting of one or more dryers.
Because the gas-to-product ratio varies considerably between AS dryers,
four different gas-to-product, ratios were selected to represent each
industry category. Each of the four (4) gas-to-product ratios applies
to the three Industrial categories. In addition, another model plant
with a slightly larger dryer and higher gas flow rate has been Incor-
porated 1n order to make the caprolactam by-product sector model plants
6-1
-------
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more representative of-the AS industry. This yields a total of 13
model plant or dryer cases.
The selection of the model dryer productian rates and gas flows is
based on published literature, information obtained during plant
visits, and responses to EPA requests for information. The selected
production rates in Table 6-1 are very close to the average values
shown in Table 3-2 except for the caprolactam AS category. This
category is represented by two AS dryers, each having a capacity of
22.7 Mg/hr (25 tons/hr); total capacity is 45.4 Mg/hr. The gas-to-
product ratios in Table 6-1 range from 142 to 2260 meters per ton
(5,000 to 80,000 dscf/ton), a range which applies to nearly all dryers
found in the AS industry. In Table 6-1, the actual gas flow rates were
computed from the standard gas flow rates by assuming a temperature of
80°C (175°F), a pressure of 760 mm Hg (1 atmosphere), and a moisture
content 'of 4 percent. A range of gas flows is used to characterize
either a rotary drum dryer or a fluidized bed dryer because either
dryer type could be used with a new plant. Air flows assumed for the
cost and economic impact analysis include 565 m3/Mg (20,000 dscf/ ton)
for indirect-fired rotary dryers and 2260 m3/Mg (80,000 dscf/ton) for
indirect-fired fluidized bed units. A gas flow of 142 m3/Mg is also
included to represent a few direct-fired dryers in this range.
6.2 REGULATORY ALTERNATIVES
The purpose of this section is to define various regulatory
alternatives or possible courses of action EPA could take to abate
AS particulate emissions from the dryer. Regulatory alternatives
that were considered are listed as follows:
1. Standards of performance for AS particulate emissions
based on add-on controls,
2. Design, equipment, work practice, or operational standards
or combinations of these which reflect the best system of
continuous emission reduction.
3. No regulation.
6-3
-------
6.2.1 ADD-ON CONTROLS
In application to participate collection from AS dryers, both the
venturi scrubber and the fabric filter represent add-on controls that
have the potential to reduce AS emissions by over 99.9 percent, and
thus are able to achieve control levels of similar stringency. Based
on test measurements and control technology documentation ' * both the
venturi scrubber and the baghouse can potentially reduce the AS emissions
to less than 0.150 kilograms per Mg of AS production.
6.2.1.1 Venturi Scrubbers
Medium energy (25-33 centimeters pressure drop) venturi scrubbers
with high liquid to gas ratios have demonstrated an ability to reduce
AS dryer emissions by more than 99.9 percent (from 77 and 108 kg/Mg to
0.160 and 0.145 kg/Mg).
Due to the high collection efficiency achieved and the fact that
it is compatible, and complimentary, to the processes involved, venturi
scrubbing is considered the most attractive add-on control system.
6.2.1.2 Fabric Filters
The only operating baghouse in the AS industry demonstrated a
level of emission control (an average particulate collection effi-
ciency of 98.7 percent) which is seemingly less than the stringency
level achieved by the venturi scrubber. However, the fabric filter
baghouse should also be able to achieve AS collection efficiencies
greater than 99 percent based on similar applications in other
industries.
1,2,3
6.2.2 DESIGN, EQUIPMENT, WORK PRACTICE, OR OPERATIONAL STANDARDS
Section lll(h) of the Clean Air Act establishes a presumption
against design, equipment, work practice, and operational standards.
For example, a standard based on a specific type of drying equipment
without add-on controls or a standard limiting the dryer air flow rate
cannot be promulgated unless a standard of performance is not feasible.
6-4
-------
Performance standards for control of AS dryer particulate emissions
have been determined as practical and feasible; therefore, design,
equipment, work practice, and operational standards were not considered
as a regulatory option.
The point should be noted that uncontrolled emissions from all
known dryers are too great to comply with existing state regulations
even at the lowest air flow rates. It is, therefore impractical to
consider a standard solely on the process equipment type or to limit
emissions by specifying the air flow.
6.2.3 NO REGULATION
The alternative of no additional regulation may be appropriate
when the impact of the regulation, or the potential for emission in
the future, is insignificant. Under the no-regulation option, emission
levels would be set by existing SIP regulations; typically these are in
the range of 0.71 kg/Mg to 1.3 kg/Mg of AS production. This option is
characterized by the use of a low energy wet scrubber to meet the
required emission limit, a reduction of about 97 to 98 percent.
6.3 SUMMARY
Two regulatory alternatives apply to each of the 13 model plant
cases. Option I, the no-regulation alternative, serves as an example
for existing or baseline control, typically about 97 to 98 percent.*
Option II, that .of add-on controls, is characterized by the use of
the venturi scrubber or the fabric filter which represent a 99.9
percent level of control. The model plants are used as a basis for
estimating the environmental, energy, and economic impacts associated
with application of the alternative regulatory options. (These are
presented in Chapters 7 and 8.)
^Baseline control reflects the degree of emission reduction which
can be achieved by the enforcement of a typical state regulation.
Baseline control is a reference for comparison rather than an
example of the "best system."
6-5
-------
6.4 REFERENCES
1. EPA, AP-40, Air Pollution Engineering Manual, 2nd Edition,
May 1973, pp. 111-132.
2. Information provided by Mcllvaine, Company in a telephone
conversation between M. Mcllvaine and R. Zerbonia, PES,
May 2, 1979.
3. Control Techniques for Particulate Air Pollutants, U.S.
Environmental Protection Agency, PA-51, p. 118.
4. Data contained in EPA emission test reports at ammonium sulfate
plants by Scott Environmental Technology, Clayton Environmental
Consultants, and Jackson and Marks Company.
6-6
-------
7. ENVIRONMENTAL IMPACT
This chapter presents an assessment of the alternative regula-
tory options discussed in Chapter 6. It addresses the air, water,
solid waste, noise and energy impacts associated with these alterna-
tive regulatory options.
7.1 AIR POLLUTION IMPACT
The air pollution impact of the alternative regulatory options
for the ammonium sulfate industry is the effect of applying Option II
limits on new plants as compared with the operation of the same plants
under Option I. The degree of emission control under Option I would
be determined by state and local regulations for the control of
particulate emissions. A typical state regulation limit is taken as
a basis for comparison. Emissions allowed by state regulations for
various process weight rates (production rates) are shown in
Figure 3-5. The values selected as typical are shown in the figure
and are listed in Table 3-10 for the operating range of the typical or
model plants. The impact of applying Option II is presented both in
terms of mass emission reduction and in terms of ambient concentration
reduction in the following sections.
7.1.1 National Air Pollution Emission Impact
The general description of the AS industry in Chapters 3 and
8 included three principal sources, i.e., caprolactam plants, synthetic
plants and coke oven by-product operations. The available evidence
for industry growth projections resulted in the following conclusion:
Coke oven operations have leveled off and that ammonia from any new
ovens may well be recovered as anhydrous ammonia rather than ammonium
sulfate. New coke ovens are being added to replace older units
rather than being added as new capacity, with the net result that
the AS from this source is expected to decline in the future. It is
7-1
-------
unlikely that more than four plants will implement modification or
reconstruction in the five years following 1980.
Similarly, the AS from synthetic plants is expected to level
off because of the superiority of DAP as a nitrogen carrier and the
large quantities of AS available from caprolactam production. This
trend, plus the fact that only about 60 percent of the available
capacity is presently being used, strongly indicates that no new
synthetic plants will be built in the foreseeable future (see
Table 3-2). Replacement of dryers which will be 25 years old in
1985 is considered in the impact analysis. Two plants currently
operating with old dryers are expected to replace them by 1985.
The total capacity of these two plants is 24.5 Mg/hr (27 tons/hr).
Replacement of this capacity is simulated with two new 13.6 Mg/hr
(15 tons/hr) plants.
Caprolactam production, on the other hand, is expected to
increase in response to an increase in demand of 5 to 7 percent
per year.
1977 caprolactam production was 394 Gegagrams (Gg) while industry
capacity was (and is) 511 Gg. At 6.1 percent growth rate (the indus-
try's rate of growth from 1971 to 1977), 1985 annual production would
be 633 Gg, 122 more than current caprolactam capacity. Additional
facilities capable of producing the shortfall would have to be
constructed, and under existing technologies would yield an additional
400 Gg of AS.
Replacement of older dryers associated with caprolactam AS
production is limited in consideration to those constructed before
1960 and, therefore, 25 years old by 1985. Only one dryer meets
this age requirement. One model plant at 50 tons/hr capacity simulates
the replacement.
Table 7-1 summarizes the impact of a 0.115 kg/Mg Option (0.3 lb/
ton) on caprolactam and coke oven by-product and synthetic AS plants
which otherwise would be controlled by existing state regulations.
7-2
-------
Table 7-1. IMPACT SUMMARY OF 1985 PARTICULATE
EMISSIONS FROM AMMONIUM SULFATE PLANTS
Mg/year (tons/year)
Plant Type
Caprolactam By-Product
1 . Growth
2. Replacement
3. Subtotal
Synthetic
1.
2.
3.
Coke
1.
2.
3.
Growth
Replacement
Subtotal
Oven By-Product
Growth
Replacement
Subtotal
Emissions Under Option II
Existing 0.150 kg/Mg
State Standards (0.30 Ib/ton)
284 (313)
208 (228)
492 (540)
0
113 (124)
113 (124)
0
65 ( 72)
65 ( 72)
60 ( 66)
45 ( 48)
105 (114)
0
20 ( 22)
20 ( 22)
0
6 ( 7)
6 ( 7)
1985
Emission
Reduction
224
164
388
93
93
58
58
(246)
(179)
(425)
0
(102)
(102)
0
( 64)
(64)
TOTAL
670 (737)
131 (144)
539 (593)
7-3
-------
These emission values were determined using the methodology referred
to as TRC Model IV.2
The reduction of particulate matter emissions to 0.15 kg/Mg
(0.30 Ib/ton) may be effected by emission control using a venturi
scrubber at a moderate pressure drop or a baghouse. The baghouse
may be somewhat superior to the scrubber in the collection of fine
particulate, but it cannot collect the residual caprolactam, a
hydrocarbon, which is carried through the system and emitted from
the dryer principally as a vapor. The scrubber can collect a sub-
stantial portion (88 percent) of this vapor along with the particulate
collection, even though it is present in small concentrations (60 ppm).
A very small part of the caprolactam is present in solid form and may
be picked up with a baghouse.
The impact analysis for the collection of caprolactam emitted
from the AS dryer is shown in Table 7-2. With a scrubber, the
estimated caprolactam emission reduction is 464 Mg/year (510 tons/
year) in addition to the 539 Mg/year (593 tons/year) of particulate
matter. These results apply only to the add-on regulatory option.
Clearly, the no-regulation option means no control beyond existing
standards and, hence, no impact.
7.1.2 Dispersion Analysis and Models
A dispersion analysis for the model plants was performed to
determine the maximum ground level concentrations of particulate
matter (AS) (and caprolactam) around the principal AS plant types
and to determine the locations of the maxima from the point of
discharge. The analysis was carried out using the Industrial
Sources Complex (ISC) Dispersion model and "worst case" climato-
logical conditions. The ISC Model short-term computer program
(ISCST) was used to compute the maximum 24-hour average particulate
concentration and the maximum 3-hour and 24-hour average caprolactam
concentration for distances beyond 100 meters from the plant. The
7-4
-------
Table 7-2. IMPACT SUMMARY ,FOR 1985 CAPROLACTAH EMISSION FROM
CAPROLACTAM AfWONIUM SULFATE PLANTS
COINCIDENT WITH PARTICULATE EMISSION CONTROL
Mg/year (tons/year)
Control Type
Uncontrolled
Emission
Emission with
Control Device
Emission
Reduction
Scrubber
1.
2.
Industry Growth
Replacement
Total
312
228
540
(343)
(250)
(293)
44
32
76
( 48)
( 35)
( 83)
268
196
464
(295)
(215)
(510)
Baghouse
1.
2.
Industry Growth
Replacement
Total
312
228
540
(343)
(250)
(293)
295
216
511
(324)
(238)
(562)
17
12
29
(19)
( 13)
( 32)
7-5
-------
3-hour maximum reflects the national ambient «iir quality standard
specification for hydrocarbons. The ISC model long-term program
(ISCLT) was used to compute the annual average concentrations of
particulate and caprolactam again at distances; beyond 100 meters.
The impact data for the dispersion analysis were taken from the
model plant description.
The Industrial Source Complex (ICS) Dispersion Model used in
the dispersion analysis is an extension of existing EPA models to
assess the air quality impact of emissions from a variety of sources
associated with an industrial source complex. It also accounts for
the effects of gravitational settling on ground-level concentrations
and deposition.
The short-term model (ISCST) extends the EPA Single-Source Model
(CRSTER). The long-term model (ISCLT) combines the basic features of
the Air Quality Display Model (AQDM) and the Climatological Dispersion
Model (COM) to compute the annual ground-level concentration. A more
detailed description of the model is available in Reference 3. The
ISC model is estimated to be accurate to a factor of 2 based on tests
of the parent models.
7.1.2.1 Model Plant Characteristics
AS plant stack and emission data based on the model plant
parameters defined in Chapter 6 were used as the input data to the
dispersion models. These parameters are summarized in Table 7-3.
The process components and mass balance for typical caprolactam
by-product AS plants are shown in Figure 3-2; for synthetic AS
production, Figure 3-3; for coke oven by-product plants, Figure 3-4.
7.1.2.2 Meteorological Considerations
Meteorological data from four locations were used to determine
the "worst case" dispersion conditions around the AS plants. Data
from rural Mobile, Alabama, and Burrwood, Louisiana, were used for
7-6
-------
Table 7-3. SOURCE DATA FOR DRYERS
Data that Vary with Dryer Air Flow Rate
Plant Type
Primary
Caprolactam
Coke Oven
Primary
Caprolactam
Coke Oven
Primary
Caprol actam
Coke Oven
Air Flow
Rate
(dscm/kg)
0.156
0.624
1.561
2.497
0.156
0.624
1.561
2.497
2.762
0.156
0.624
1.561
2.497
0.156 .
0.624
1.561
2.497
0.156
0.624
1.561
2.497
2.726
0.156
0.624
1.561
2.497
0.156
0.624
1.561
2.497
0.156
0.624
1.561
2.497
2.726
0.156
0.624
0.561
2.497
Stack
Diameter
(m)
0.240
0.479
0.759
0.959
0.310
0.619
0.979
1.238
1.399
0.107
0.215
0.340
0.429
0.250.
0.501
0.793
1.002
0.323
0.647
1.023
1.294
1.461
0.113
0.227
0.358
0.453
0.240
0.479
0.759
0.959
0.310
0.619
0.979
1.238
1.399
0.107
0.215
0.340
0.429
Participate
Emission
Rate
(g/sec)
(a)
3.17
3.17
3.17
3.17
8.94
8.94
8.94
8.94
8.94
8.22 x 10"}
8.22 x 10~f
8.22 x 10"}
8.22 x 10"1
(b)
0.567
0.567
0.567
0.567
1.89
1.89
1.89
1.89
1.89
0.113
0.113
0.113
0.113
(c)
0.567
0.567
0.567
0.567
1.89
1.89
1.89
1.89
1.89
0.113
0.113
0.113
0.113
Caprolactam
Emission
Rate
(g/sec)
uata that Do Not Change
with Dryer Air Flow Rate
Stack stack
Stack Exit Exit
Height Velocity Temperature Operating
W (m/sec) (°K) Hours
Baseline Control Option
—
»••
—
6.30
6.30
6.30
6.30
—
__
—
12.2 15.24 316 5400
18.3 15.24 316 8400
6.1 15.24 316 7400
Baghouse Option
.—
M_
—
6.30
6.30
6.30
6.30
6.30
__
__
__
«
12.2 15.24 353 5400
18.3 15.24 353 8400
6.1 15.24 353 7400
Venturi Scrubber Option
..
__
__
—
0.76
0.76
0.76
0.76
0.76
__
__
__
—
12.2 15.24 316 5400
18.3 15.24 316 8400
6.1 15.24 316 7400
7-7
-------
caprolactam by-product AS plants; Tulsa, Oklahoma, and Columbia,
Missouri, were used for the synthetic AS plants; and Pittsburgh,
Pennsylvania, for coke oven AS plants, during the periods 1973 to
1975. The climate of these areas is similar to that of areas where
new construction may be expected. From the record of sequential
hourly data, 20 "worst case" days were selected for the 24-hour
calculations for each plant type. The two caprolactam AS stacks
were oriented North and South for maximum interaction.
Similarly, 3-hour "worst case" dispersion conditions were
determined for the maximum 3-hour caprolactam concentrations. For
the annual concentrations, the "STAR" summary was used which incor-
porated the frequency of wind speed and direction classified accord-
ing to the Pasquill Stability Categories.
The location of the point of maximum ground-level concentration
and the concentrations at various distances from the plant were
determined using a radial receptor grid. Receptors were placed at
100, 1000, and 10,000 meters from the source with seven additional
receptors interspersed between these points. Angular spacing of
these points at 10° intervals provided receptors at 360 points around
the source. A preliminary analysis indicated that the point of
maximum ground-level concentration was located beyond 100 meters,
the minimum model distance.
No terrain effects were included in the analysis except those
implicitly contained in the meteorological data for the Mobile,
Alabama, and Tulsa, Oklahoma, areas.
The ISC model calculations indicate that the meteorological
conditions associated with the maximum short-term concentrations
from ammonium sulfate plants occur infrequently. During only 6 days
in 1964 did meteorological conditions prevail which would permit
concentrations within 80 percent of the maximum values indicated.
This frequency applies to the caprolactam plant, synthetic, and coke
7-8
-------
oven AS plants. The maximum short-tern concentrations of both particu-
late and caprolactam emission for both plants 1s estimated to occur not
more than 3 to 4 percent of the year.
7'1<2*3 -fesu1ts and Discussion of the Dispersion Analysis
The results of the dispersion analysis under "worst case" meteo-
rological conditions are presented in Tables 7-4 through 7-12. These
values assume a pristine atmosphere and should be added to any back-
ground concentrations. Ambient AS concentrations are less for baghouse
control than for venturi; this reflects the greater plume buoyancy due
to the higher discharge temperature at the baghouse, i.e., 80°C (177°F)
versus 43°C (110°F), even though the emission rate is identical with
that of the scrubber discharge.
The national primary ambient air quality standards for particu-
late matter as published in the Federal Register, Volume 36 No. 84
April 30, 1971 are:
o
• 75 ngs/m , annual geometric mean
• 260 ngs/m - maximum 24-hour concentration not to be
exceeded more than once a year.
Caprolactam By-Product Plants
For the caprolactam by-product model plants, the maximum 24-hour
average particulate ground-level concentrations occur at 700 meters.
The maximum 24-hour concentration is reduced by a factor of 80
percent (224 to 47.4 ^g/m3) by controlling to 0.15 kg/Mg rather than
the state emission limit. The maximum annual average occurs at 300
meters and is reduced by a factor of 80 percent (29,1 to 6.l5ng/m3)
by control with a venturi scrubber.
In those areas where the ambient standards are attained, the
Option II model plant contributions appear to be satisfactory for
Installation 1n Class II and III areas but they would be too great
to meet the 24-hour maximum Increment requirement for a Class I area.
7-9
-------
Table 7-4. MAXIMUM 24-HOUR AVERAGE PARTICULATE CONCENTRATIONS
CALCULATED FOR AMMONIUM SULFATE DRYERS AT
CAPROLACTAM PLANTS FOR FIVE
AIR FLOW-TO-PRODUCTION RATIOS
(Micrograms Per Cubic Meter)
Concentration
Distance
Cm)
0.
156 m3/kg
by Air Flow-to-Production Ratio
0.624 m3/kg 1.561 m3/kg 2
(a) Baseline
100
700*
1,000
10,000
100
700*
1,000
10,000
100
700*
1,000.
10,000
9.
2.
1.
6.
1.
4.
2.
1.
1.
4.
2.
1.
32 x
24 x
03 x
19
39 x
23 x
11 x
31
97 x
74 x
19 x
31
10 1
102
102
id
10 1
10 1
10 1
10 1
10 1
4.35
1.46
8.71
6.18
3.00
2.36
1.63
9.98
9.19
3.08
1.84
1.31
x 10
1 1.52
x 102 8.94
x 10
(b)
x 10
x 10
x 10
(c)
x 10
x 10
1 7.05
4.71
Baghouse
5.49
1 1.25
1 1.18
-1 9.92
Venturi
3.22
1 1.89
1 1.49
9.96
Control
x
x
x
1'Ql 6
101 7
101 5
4
.497 m3/kg
Option
.35
.01 x 10 1
.93 x 101
.70
2.726 m3/kg
3.48
6.22 x
5.21 x
4.69
101
10 l
Option
x
x
x
x
10"1 3
10 ! 9
10 * 8
10"1 9
Scrubber
x
x
x
1
10 ! 1
10 1 1
10'1 9
.21 x 10"1
,28
.39
.87 x 10 -1
Opti on
.34
.48 x 10 1
.25 x 101
.94 x 10'1
2.43 x
7.83
7.08
7.20 x
7.36 x
1.31 x
1.10 x
9.91 x
lo-1
1
10-1
ID'1
10 1
10 1
10-1
*Distances to the maximum concentrations calculated at or beyond 100 meters
from the stack for air flow-to-production ratios of 0.156, 0.624, 1.561,
2.497, and 2.726 cubic meters per kilogram of ammonium sulfate production.
7-10
-------
Table 7-5. MAXIMUM 24-HOUR AVERAGE PARTICULATE CONCENTRATIONS
CALCULATED FOR AMMONIUM SULFATE DRYERS AT
PRIMARY PRODUCTION PLANTS FOR FOUR
AIR FLOW-TO-PRODUCTION RATIOS
(Micrograms Per Cubic Meter)
Distance
On)
Concentration by Air Flow-to-Production Ratio
1,000
10,000
300
1,000
10,000
100
300*
1,000.
10,000
0.156 m3/kg 0.624 m3/kg 1.561 m3/kg 2.497 m3/kg
(a) Baseline Control Option
6.82 x 101 3.98 x 101 2.56 x 101
1.02 x 10
1.56 x 10
5.27 x 101
3.01
2 1.22 x 102 1.02 x 102 8.70 x 101
4.07 x 101 3.33 x 101 3.01 x 101
(b) Baghouse Option
1.93 x 101 1.35 x 101
7.74
5.89
5.06
4.44
5.26 x 10-1 4.97 x lO'1 4.67 x 10'1 4.26 x 10~1
(c) Venturi Scrubber Option
1.83 x IQl 1.22 x 101 7.11 4.53
2.79 x 101 2.20 x 101 1.82x10* 1.56X101
9-43 7.29 5.96 5.39
5.39 x 1Q"1 5.24 x 10"! 5.08 x 10'1 4.96 x 10-1
n
and 2
max1>um concentrations calculated at or beyond 100 meters
a7K-°r !lr flow-to-Production ratios of 0.156, 0?624, 1 561
.497, cubic meters per kilogram of ammonium sulfate production
7-11
-------
Table 7-6. MAXIMUM 24-HOUR AVERAGE PARTICULATE CONCENTRATIONS
CALCULATED FOR AMMONIUM SULFATE DRYERS AT
COKE OVEN OPERATIONS FOR FOUR
AIR FLOW-TO-PRODUCTION RATIOS
(Mlcrograms Per Cubic Meter)
Distance
100
200
1,000
10,000
Concentration by Air Flow-to-Production Ratio
0.156 m3/kg 0.624 m3/kg 1.561 m3/kg 2.497 m3/kg
(a) Baseline Control Option
2.33 x 102 1.42 x 102 7.73 x 10A 4.90 x 101
2.33 x 102 1.42 x 102 1.01 x 102 8.20 x 101
1.37 x 101 1.30 x 101 1.23 x 101
4.41 x 10"1 4.40 x 10'1 4.37 x 10'1
(b) Baghouse Option
2.92 x 10
2.92 x 101
1.92
i. ^f- • •»» •
6.06 x ID'2 6.06 x 10'2 6.04 x 10'2 6.02 x
(c) Venturi Scrubber Option
1.95 x 101 1.06 x 101 6.73
3.20 x 101
3.20 x 101
1.95 x 101 1.39 x 1Q1 1.13 x 10
200
1,000. 1.93 1.88 1.78
10,000
^_^___^^_^— .. i •-- JT -r-^l i „__ ~f
*Distances to the maximum concentrations calculated at or beyond 100,
from the stack for air flow-to-production ratios of 0.156, 0.6^4, i.
and 2.497 cubic meters per kilogram of ammonium sulfate production.
7-12
-------
Table 7-7. MAXIMUM ANNUAL AVERAGE PARTICULATE CONCENTRATIONS
CALCULATED FOR AMMONIUM SULFATE DRYERS AT
CAPROLACTAM PLANTS FOR FIVE
AIR FLOW-TO-PRODUCTION RATIOS
(Micrograms Per Cubic Meter)
Concentration by Air Flow-to-Production Ratio
Distance ~~
(m) 0.156 m /kg 0.624 m3/kg 1.561 rr,3/kg 2.497 m3/kg 2.726 m3/kg
(a) Baseline
1
10
100
500*
,000
,000
4
2
1
4
.47
.91 x 101
.37 x 101
.27 x 10'1
1.30
1.84
1.13
4.42
x 101
x 101
x 10"1
2.73
1.21
9.17
4.14
(b) Baghouse
1
10
100
700*
,000
,000
6
5
2
9
.08 x 10"1
.65
.82
.01 x 10"2
8.47
3.18
2.14
8.82
x 10"2
x 10~2
1.52
1.85
1.56
8.52
Control
x 10'1
x 10"1
x 10'1
Option
x TO'2
x 10~2
(c) Venturi Scrubber
1
10
100
500*
,000.
,000
9
6
2
9
.45 x 10"1
.15
.90
.02 x 10"2
2.75
3.88
2.40
8.91
x 10'1
x 10~2
5.78
2.56
1.94
8.75
x 10"2
x 10'2
Option
8.
9.
7.
4.
6.
1.
1.
8.
03 x 10~2
20
83
08 x ID'1.
22 x 10"3
35
26
28 x 10'2
4.89 x
7.96
7.09
4.04 x
3.64 x
l.JJ)
1.08
8.12 x
io-2
10
10"3
ID"2
Option
1.
1.
1.
8.
70 x 10~2
95
66
62 x 10~2
1.04 x
1.68
1.50
8.52 x
io-2
io-2
*Distances to the maximum-concentrations calculated at or beyond 100 meters
from the stack for air flow-to-production ratios of 0.156, 0.624, 1.561,
2.497, and 2.726 cubic meters per kilogram of ammonium sulfate production.
7-13
-------
Table 7-8. MAXIMUM ANNUAL AVERAGE PARTICULATE CONCENTRATIONS
CALCULATED FOR AMMONIUM SULFATE DRYERS AT
PRIMARY PRODUCTION PLANTS FOR FOUR
AIR FLOW-TO-PRODUCTION RATIOS
(Micrograms Per Cubic Meter)
Distance
(m)
100
400*
1,000
10,000
100
400*
1,000
10,000
100
400"
1,000
10,000
Concentration by Air Flow-to-Production Ratio
0.156 m3/kg 0.624 m3/kg 1.561 m3/kg 2.497 m3/kg
(a) Baseline Control Option
8.75 3.10 9.00 x 10"1 3.58 x 10'1
2.45 x 101 1.71 x 101 1.10 x 101 8.51
8.51 6.78 5.61 4.94
3.94 x TO'1 3.70 x 10"1 3.46 x 10'1 3.30 x 10"1
(b) Baghouse Option
1.16
4.12
1.50
2.54 x 10"1 4.52 x 10~2 2.30 x 10'2
2.52
1.16
1.48 1.07
9.26 x 10"1 7.86 x TO"1
7.03 x 10"2 6.47 x 10~2 5.83 x 10"2 5.48 x 10'2
(c) Venturi Scrubber Option
5.55 x 10"1 1.61 x 10'1 6.41 x 10'2
3.06 1.98 1.52
1.53 1.21 1.00 8.81 x 10'1
7.03 x 10"2 6.60 x 10"2 6.23 x 10"2 5.90 x TO"2
1.57
4.39
*Distances to the maximum concentrations calculated at or beyond 100 meters
from the stack for air flow-to-production ratios of .0.156, 0-624, J-^l,
2 497 and 2 726 cubic meters per kilogram of ammonium sulfate production.
7-14
-------
Table 7-9. MAXIMUM ANNUAL AVERAGE PARTICULATE CONCENTRATIONS
CALCULATED FOR AMMONIUM SULFATE DRYERS AT
COKE OVEN OPERATIONS FOR FOUR
AIR FLOW-TO-PRODUCTION RATIOS
(Micrograms Per Cubic Meter)
Concentration by Air Flow-to-Production Ratio
Distance _
(m) 0.156 nT/kg
0.
624 m3/kg
1.561 m3/kg 2.
(a) Baseline
100
200*
1,000
10,000
=
2.35 x 101
2.35 x TO1
1.
3.
-
47
54 x 10-2
==^
=====
1.41
1.41
1.
3.
41
53
=====
x 101
x 10 !
x TO'2
"-' ' — — •
7.85
9.29
1.33
3.51
(b) Baghouse
1,
10,
100
200*
000
000
2.
2.
2.
4.
99
99
02 x 10'1
86 x TO'3
1.
1.
1.
4.
59
59
93
85
x TO'1
x ID'3
7.24
1.09
1.78
4.83
Control
=====
x TO'2
Option
x TO'1"
x TO'1
x TO'3
(c) Venturi Scrubber
1,
10,
100
200*
000.
000
3.
3.
2.
4.
23
23
03 x 10-1
97 x 10"3
1,
1.
1.
4,
94
94
94
85
x TO"1
x TO"2
1.08
1.28
1.82
4.83
x TO"1
x TO"3
497 m3/kg
"•" — ' — ^^»-_ , _, ,»,,,. i i I, ^
Option
5
7
1
3
3
8
1
4
-
.09
.62
.28
.51 x
.90 x
.23 x
.67 x
.80 x
10-2
==================
10-1
10-1
ID"1
TO'3
Option
7
1
1
4
.00 x
.05
.76 x
.82 x
NT1
10-1
10-3
*Distances to the maximum concentrations calculated at or beyond 100 meters
from the stack for air flow-tp-production ratios of 0.156, 0.624, 1.561,
2.497, and 2.726 cubic meters per kilogram of ammonium sulfate production.
7-15
-------
Table 7-10. MAXIMUM 3-HOUR AVERAGE CAPROLACTAM CONCENTRATIONS
CALCULATED FOR AMMONIUM SULFATE DRYERS AT
CAPROLACTAM PLANTS FOR FIVE
AIR FLOW-TO-PRODUCTION RATIOS
(Micrograms Per Cubic Meter)
Concentration by Air Flow-to-Production Ratio
Distance
(m) 0.156
m3/kg
0.624 m3/kg
1.561 m3/kg 2.497
(a) Baseline
100
300*
1,000
10,000
3
4
2
2
.33 x
.52 x
.72 x
.05 x
102
102
102
ioi
1.54
3.07
2.00
1.79
x 102
x 102
x 102
x 101
6.06
2.08
1.44
1.79
(b) Baghouse
100
400*
1,000
10,000
2
3
2
2
.47 x
.77 x
.49 x
.05 x
102
102
102
101
5.40
2.17
1.58
1.79
x 101
x 102
x 102
x 101
1.38
1.27
8.83
1.79
(c) Venturi
100
200*
1,000,
10,000
3.99 x
5.40 x
3.27 x
101
101
101
2.46
1.85
3.69
2.40
2.15
x 101
x 101
x 101
0.73
2.49
1.73
2.15
Control
x 101
x 102
x 102
x 101
Option
x 101
x 102
x 101
x 101
Scrubber
x 101
x 101
x 101
m3/kg
2.726 m3/kg
Option
2.70
1.63
1.05
1.79
8.56
8.91
5.89
1.24
Opti
3.24
1.95
1.26
2.15
x 101
x 102
x 102
x .101
x 101
x 101
x 101
on
x 101
x 101
1.53 x
1.44 x
9.12 x
1.79 x
6.48
7.18 x
5.11 x
8.91
1.84
1.73 x
1.09 x
2,15
ioi
102
101
101
!
IQl
ioi
101
101
*Distances to the maximum concentrations calculated at or beyond 100 meters
from the stack for air flow-to-production ratios of 0.156, 0.624, 1.561,
2.497, and 2.726 cubic meters per kilogram of ammonium sulfate production.
,7-16
-------
Table 7-11. MAXIMUM ANNUAL AVERAGE CAPROLACTAM CONCENTRATIONS
CALCULATED FOR AhflONIUM SULFATE DRYERS AT
CAPROLACTAM PLANTS FOR FIVE
AIR FLOW-TO-PRODUCTION RATIOS
(Micrograms Per Cubic Meter)
Concentration by Air
Flow-to-Production Ratio
Distance
(m) 0.156 m /kg 0.624 m3/kg 1.561 m3/kg 2.497 m3/kg
2.726 m3/kg
(a) Baseline Control Option
100
500*
1,000
10,000
100
700*
1,000
10,000
ICO
500*
1,000.
10,000
3.15
2.05 x 101
9.68
3.01 x 10"1
2.02
1.88 x 101
9.40
3.00 x 10"1
0.38
2.46
1.16
0.36 x 10"1
9.18 x
1.29 x
8.00
2.96 x
2.82 x
1.06 x
7.13
2.94 x
1.10 x
1.55
0.96
0.36 x
10"1 1.93
101 8.52
6.46
10"1 2.92
(b) Baghouse
10"1 5.05
101 6.18
5.22
10"1 2.84
(c) Venturi
ID"1 2.30
1.02
0.78
x Kf1 5.66 x 10"2
6.48
5.52
x 10"1 2.87 x 10"1
Option
x 10"2 2.07 x 10~2
4.52
4.17
x 10"1 2.76 x 10'1
Scrubber Option
x 10"1 0,68 x lo"2
0.78
0.66
10"1 0.35 x 10"1 0.35 x 10"1
3.45
5.61
5.00
2.84
1.22
3.69
3.62
2.70
0.4 x
0.68
0.60
0.34
x 10"2
x 1.0"1
x 10"2
x ID'1
ID'2
x 10'1
*Distances to the maximum concentrations calculated at or beyond 100 meters
from the stack for air flow-to-production ratios of 0.156, 0.624, 1.561,
2.497, and 2.726 cubic meters per kilogram of ammonium sulfate production.
7-17
-------
Table 7-12. MAXIMUM 24-HOUR AVERAGE CAPROLACTAM CONCENTRATIONS
CALCULATED FOR AMMONIUM SULFATE DRYERS AT
CAPROLACTAM PLANTS FOR FIVE
AIR FLOW-TO-PRODUCTION RATIOS
(Micrograms Per Cubic Meter)
Concentration by Air Flow-to-Production Ratio
Distance
Cm)
0.156 m"3/kg
0.624
m3/kg
1.561 m3/kg 2.497 m3/kg
(a) Baseline Control
100
700*
1,000
10,000
6.57 x 101
1.58 x 102
7.29 x 101
4.36
3.
1.
6.
4.
06
03
14
35
x 101
x 102
x 101
1.
6.
4.
3.
07 x 101
30 x 101
97 x 101
32
2.726 m3/kg
Op ti on
4.
4.
4.
3.
47
94 x 101
18 x 101
31
2,45
4.38 x
3.67 x
3.30
101
Ifll
(b) Baghouse Option
1
10
100
700*
,000
,000
4.64 x 101
1.41 x 102
7.02 x 101
4.36
1.
7.
5.
3.
00
87
45
36
x 101
x 101
x 101
1.
4.
3.
3.
83
17 x 101
94 x 101
31
(c) Venturi Scrubber
1
10
100
300*
,000.
,000
7.89
18.96
7.23
0.52
3.69
12
7
0
.3
.35
.52
1.29
7.56
5
0
.97
.4
1.
3.
2.
3.
07
09 x 101
80 x 101
29
8.1,0 x
2.61 x
2.36 x
2.40
ID"1
ID*
101
Option
0.54
5.9
5
0
.0
.,4
0.29
5.25
4.4
0.4
*Distances to the maximum concentrations calculated at or beyond 100 meters
from the stack for air flow-to-production ratios of 0.156, 0.624, 1.561,
2.497, and 2.726 cubic meters per kilogram of ammonium sulfate production.
7-18
-------
The maximum allowable increase in the 24-hour concentration as defined
by 40 CFR 52.21 is 10 pg/m . This judgment assumes that the 45 Mg/hour
plant is considered to be a major source.
The ground-level concentrations of caprolactam are shown in
Tables 7-10, 7-11, and 7-12 which include the 3-hour maximum average
as well as the 24-hour and annual averages. Only the maximum 3-hour
concentration is specified as an ambient standard for hydrocarbons.
Since caprolactam is a hydrocarbon, it would relate to the ambient
standard of 160 hig/m (0.24 ppm) maximum 3-hour concentration (6 to
9 a.m.), not to be exceeded more than once per year. Clearly, a
45 Mg/hr AS plant with a venturi scrubber that collects hydrocarbons
as well as particulate would not exceed this value.
Synthetic Plant
The 24-hour and annual average particulate concentrations near a
13.6 Mg/hr synthetic plant are shown in Tables 7-5 and 7-8.
The results show that the 24-hour average particulate ground-level
concentration would be reduced from 156 to 27.9 t^g/m3 with a venturi
scrubber controlled to 0.15 kg/Mg (0.3 Ib/ton). The baghouse is
slightly more effective because it does not reduce the air temperature
significantly and thus maintains the plume buoyancy. Again, the total
emission is the same.
The controlled Option II concentrations could meet applicable
standards when operating alone. In conjunction with other plants in an
attainment locality, the contribution to the ambient particulate value
could be important to area growth. In nonattainment areas, stringent
control is necessary to minimize offset values and to allow for progress
toward meeting the ambient standards.
Coke Oven Plant
The coke oven plant results shown in Tables 7-6 and 7-9 indicate
lesser ambient air concentration impacts for the smaller plants.
7-19
-------
7.2 WATER POLLUTION IMPACT
Effluent guidelines set forth in 40 CFR 418.60 limit water
pollution from synthetic and coke oven AS plants but not caprolactam
AS plants. It requires zero discharge of "effluent" to navigable
waters. If a discharge should be made into a municipal sewer, it
must be pretreated to reduce ammonia to 30 mg (as N) per liter.
There are no limitations on biological oxygen demand (BOD), total
suspended solids (TSS), or pH. The guidelines for caprolactam
plants have yet to be written.
The caprolactam AS plant has a comparatively large throughput
of water because the feed stock is a 40 percent solution of AS and
water. The water evaporated in the crystallizer is condensed and
recycled to the principal plant for plant use.
The synthetic AS plants achieve the zero discharge requirement
readily since the water input to the plant (in the acid) is lost by
evaporation from the crystallizer or the scrubber. Most of the water
evaporated from the crystal!izer is condensed and recycled to the
scrubber and mother liquor tank systems. A small quantity of make-up
water (1 gallon per minute in one case) is needed and none is dis-
charged.
The coke oven plant may operate the scrubber system separately
from the saturator condenser system. With continuous removal of
scrubber water, a very small quantity of nitrogen may be lost in the
discharge.
The necessity for adding a scrubber for emission control creates
no water pollution problems and there is no impact. The same would
be true for a baghouse application where the AS collected must be
mixed with water for recycle to the process. The product AS is
generally stored in warehouses which protect it from runoff with
rainwater. One of the most beneficial impacts of scrubbers is that
7-20
-------
they return a valuable product (AS fines) to the process for recovery,
and for this reason the scrubber may serve as an integral part of the
process. With the baghouse, an extra step is necessary to reslurry the
AS collected.
7.3 SOLID WASTE IMPACT
The AS plants generate no solid waste as part of the processes.
The fines from the screening process are either sold as a product or
recycled to the plant. The scrubber (or baghouse) catch is returned
to the process. Any inert material input passes out with the product.
7.4 ENERGY IMPACT
The implementation of Option II for the AS plant would increase
the energy requirements for scrubbers by a factor which depends on
the level of emission control required. For the 45 Mg/hr caprolactam
plant with two 2.49 m3/kg (80,000 dscf/ton) dryers and two venturi
scrubbers, the added pressure drop of 10 in. water column (13 in.
with a venturi less 3 in. for an elementary scrubber) would increase
the horsepower requirement for the two fan motors from 70 to 305 hp
metric (69 to 301 hp engl.), an increase of 235 hp metric (232 hp
engl.). The added horsepower needed to increase the ratio from 0.4
3 "3
to 3.5 I/am (3 to 26 gal/100 acf) would raise the horsepower require-
ment of the two pumps from 32.5 to 278 hp metric (32 to 274 hp engl.),
an increase of 245 hp metric (242 hp engl.). The equivalent energy
consumption would be 441 Kw-hr/hr, or about 0.65 percent of the total
energy required to manufacture AS at caprolactam by-product AS plants.
The energy requirements for the synthetic AS plant will be lower
in proportion to the lower air and water flow requirements per ton of
product. Control to the same high-efficiency conditions as discussed
with the caprolactam plant would require an increase of motor power
from 8.2 to 48.6 hp (8.1 to 47.9 hp), an increase of 40.4 hp metric.
The equivalent energy consumption would be 37 Kw-hr/hr, or less than
7-21
-------
0.1 percent of the total energy required to manufacture AS at snythetic
AS plants. Obviously, much or all of the added horsepower could be
saved with the other regulatory options.
7.5 NOISE IMPACT
The implementation of Option II could theoretically increase the
noise generated by the scrubber fan because of the higher pressure
necessary for greater collection "efficiency. The increase in noise
level can be limited by the installation of acoustical materials and
• i • i
overall design of the fan for low noise generation. One field obser-
vation of a fan operating at the high pressure level (13 in. W.C.) and
in the open air, revealed no significant sound level above the back-
ground noise in the plant.
Occupational exposure to noise is regulated under Occupational
Safety and Health Standards set forth in 29 CFR 1910.95.
7-22
-------
7.6 REFERENCES
1. Chemical Engineering, March 19, 1976, p. 82.
2. Hopper, T.G. and H.A. Marrone, Impact of NSPS on 1985
National Emissions from Stationary Sources, Report Nos
EPA-450/3-017, TRC3 Inc.9 May, 1976, p. 9-13.
3. Cramer, H.E. Company, Inc., Dispersion Model Analysis of .
the Air Quality Impact of Emissions from Ammonium Sulfate
Production Plants, EPA Contract No. 68-02-2507.
4. Harris, C.M., Handbook of Noise Control, McGraw-Hill Book
Company, 1957, pp. 25-10.
7-23
-------
-------
8.0 ECONOMIC IMPACT
Ammonium Sulfate (AS) is produced by 40 companies operating
61 plants in the U.S. Although a variety of production processes
are utilized, three types of plants are predominant in the
industry: (1) prime product, (2) coke oven by-product and (3)
caprolactam by-product. In 1977 over 92 percent of total AS
output was produced by plants using these three processes.
Approximately 95 percent of domestic consumption of AS is in
the form of fertilizer. Other uses include tanning, food
processing, water and sewage treatment, cattle food supplement
and pharmace-'ticals. None of these subsidiary uses takes up more
than 2 percent of total AS production, and none of them is
expected to increase in importance over the period 1979-1985.
The agricultural sector is therefore likely to remain the
dominant consumer of AS.
For geographical reasons, the U.S. is both an importer (from
Canada) and an exporter (primarily to Latin America) of AS.
Historically, exports have exceeded imports, although the size of
exports has fallen since 1968 when AID subsidies for AS exports
to third world countries were removed.
Capacity utilization in the industry is quite low (63
percent in 1978) and industry growth is expected to be minimal
over the next seven years (1979-1985). At this time no company
has specific plans to expand its capacity during that seven-year
period although the possibility exists that one or two new
caprolactam by-product plants will be constructed.
The economic impacts of implementation of Option II
on the Ammonium Sulfate industry are likely to be negligible.
Product prices will be virtually unaffected by the regulation.
Rates of return on plant investments will decline by less than
1.05 percentage points for affected facilities earning relatively
high rates of return on investment (15 percent) and by less than
8-1
-------
0.68 percent for affected facilities earning relatively low rates
of return (6 percent). Over the whole of the five-year period
following promulgation, the estimated maximum total capital cost
of the regulation for the AS industry is $0.958 million. This
level of control expenditures appears to be affordable as it is
less then 0.01 percent of the total value of current AS output.
The estimated industry wide level of annualized costs of the
standard in the fifth year following promulgation is relatively
small, $0.480 million, also less than 0.01 percent of the total
value of current AS output. two factors account for the small
impacts. First, the size of the control costs incurred by
affected facilities in achieving the required emissions reduc-
tions are small relative to other costs. Second, two sector of
the industry, synthetics and coke oven by-products, are likely to
experience no growth over the five-year period (1980-1985)
while growth in the third sector, caprolactam by-products, will
be largely determined by economic conditions in the market for
caprolactam, not the market for Ammonium Su'lfate.
8.1. Industry Economic Profile
8.1.1. Product
8.1.1.1. Production
Ammonium Sulfate is a greyish white crystalline salt
produced by the neutralization of ammonia with sulfuric acid. It
is produced synthetically as a prime product, but larger quanti-
ties are manufactured as by-products in a variety of industrial
processes. Such processes include the coking of coal, caprolac-
tam Manufacture, nickel reduction, aery late and sulfuric acid
production, and water and sewage treatment (see table 8-1).
j
8-2
-------
Table 8-1. Production of Ammonium Sulfate by Source*
(103 Megagrams)
Year
1962
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976
1977
1978
Coke Oven
By-product
540
563
618
643
693
670
608
579
540
490
548
544
496
444
450
427
407
Capro-
1 actam
257
304
389
465
575
582
537
644
825
948
1019
1044
943
1012
1241
1102
Prime
Product
5DO
521
777
959
1048
1127
820
689
602
551
505
555
589
606
409
456
(1709)**
Other
243
266
309
347
288
175
459
406
292
153
161
264
338
292
347
164
Total
1540
1654
2093
2414
2604
2556
2424
2317
2259
2142
2234
2408
2366
2354
2447
2153
2116
*Data by source not available for years prior to 1962.
Includes caprolactam, prime product and other.
SOURCES: U.S. Department of Commerce, Bureau of the Census. Current
Industrial Reports Series M28A. 1950-1975.
U.S. Dept. of the Interior, Bureau of Mines. Minerals Yearbook
1950-1973.
Department of Energy Information Administration.
8-3
-------
The three most important AS production processes are synthetic or
prime product, coke oven by-product and caprolactam by-product.
These processes are estimated to account for 23.5 percent, 12.1
percent and 47.4 percent of total U.S. ammonium sulfate capacity
respectively. None of the remaining processes, nickel reduction,
acrylate and sulfuric acid tail gas scrubbing, or water and
sewage treatment, accounts for more than 4.6 percent of industry
capacity. Each of the three major processes is discussed below.
(a) Synthetic Product. In synthetic AS plants ammonia is
directly neutralized with sulfuric acid to produce ammonium
sulfate. Typically these plants obtain feedstocks from other
facilities although several are located in fertilizer complexes
where products such as ammonia, ammonium nitrate, nitric acid,
sulfuric acid and phosphoric acid are produced.1 Average prime
product plant capacity is estimated to be 79.01 Gg* (see table
8-3). Actual capacities range from 0.9 Gg to 263 Gg with six of
the plants producing less than 60 Gg (see table 8-2).
Ten plants are currently in operation, all brought on stream
prior to 1974. Seven of these are located in the West
(California, Texas, Arizona and Idaho). The remaining three are
in the East (New Jersey, Maine and Pennsylvania) (see figure
8-1). No new plants have been brought into full-time operation
since 1973 and industry observers believe that no additional
capacity will be constructed over the next seven years (1979-
1985).2 There is corroborating evidence for this view. David
et. al.3 examined the financial viability of six prime product
plants in operation in 1973. Their study showed that if those
plants had been required to bear the full costs of all
*A gigagram (Gg) is equivalant to one million kilograms or one
thousand metric tons.
8-4
-------
Jable 8-2. Anroonium Sulfate Producing Plants, Locations and Capacities
Company
Location
apacity
Megagrams)
Prime Product
Delta Chemicals, Inc.
Heico, Inc.
Occidental Petroleum Corp.
Hooker Chemical Corp., subsidiary
Richardson-Merrell, Inc.
J. T. Baker Co., subsidiary
J. R- Simplot Co.
Minerals & Chemical Div.
Standard Oil Co. of California
Chevron Chemical Co., subsidiary
Valley Nitrogen Producers, Inc.
Arizona Agrochemical Co.,
subsidiary
Caprolactam By-P roduct
Allied Chemical Corp., Fibers Div.
Badische Corp.
Nipro, Inc.
Coke Oven By-Product
Alabama By-Product Corp.
Armco Steel Corp.
Bethel ehern Steel Corp.
CF&I Steel Corp.
Chattanooga Coke and Chemicals Co.
Colt Industries, Inc.
Crucible Stainless Steel & Alloy
Divison
Donner-Hanna Coke Corp.
Empire Coke Co.
Inland Steel Co.
Interlake, Inc.
Jones & Laughlin Industries, Inc.
Jones & Laughlin Steel Corp.,
subsidiary
Kaiser Steel Corp.
Lykes Corp.
Youngstown Sheet & Tube Co.
Subsidiary
National Steel Corp.
Granite City Steel Div.
Great Lakes Steel Div.
Weirton Steel Div.
Northwest Industries, Inc.
Lone Star Steel Co., subsidiary.
Searsport, Me.
Delaware Water Gap, Pa.
Houston, Tx.
Lathrop, Ca.
Plainview, Tx.
Phillipsburg, N.J.
Pocatello, Idaho
Richmond, Ca.
Helm, Ca.
Chandler, Az.
Hopewell, Va.
Freeport, Tx.
Augusta, Ga.
Tarrant, Ala.
Hamilton, Ohio
Houston, Tx.
Bethlehem, Pa.
Burns Harbor, In.
Johnstown, Pa.
Lackawanna, N.Y.
Sparrows Point, Md.
Pueblo, Colo.
Chattanooga, Tn.
Midland, Pa.
Buffalo, N. Y.
Tuscaloosa, Ala.
Indiana Harbor, In.
South Chicago, 111.
Aliquippa, Pa.
Pittsburgh, Pa.
Fontana, Ca.
Campbell, Ohio
Granite City, 111.
Zug Island, Mich.
Weirton, W. Va.
Lone Star, Tx.
R-5
25.4
18.1
136.1
101.6
136.1
0.9
40.8
59.0
263.0
9.1
838.3
400.0
354.7
10.9
7.3
3.6
24.5
20.9
21.8
39.0
36.3
(N.A.)
(N.A.)
3.6
12.7
1.8
22.7
3.6
20.0
22.7
23.6
10.0
5.4
(N.A.)
10.0
3.6
-------
Table 8-2 (continued)
Company
Republic Steel Corp.
Iron and Chemical Div.
Sharon Steel Corp.
Fairmont Coke Works
Shenango, Inc.
U.S. Steel Corp. USS Chemicals Div.
Jim Walter Corp.
Jim Walter Resources, Inc.
subsidiary, Chemicals Div.
Wheeling-Pittsburgh Steel Corp.
Location
Chicago, 111.
Cleveland, Oh.
Gadsden, Ala.
Nassillon, Oh.
Thomas, Ala.
Warren, Oh.
Youngstown, Oh.
Fairmont, W. Va.
Neville Island, Pa.
Fairfield, Ala.
Fairless Hills, Pa.
Geneva, Utah
Lorain, Ohio
Birmingham, Ala.
Follansbee, W. Va.
Monessen, Pa.
Capacity
(103 Mega grams)
4.5
24.5
10.0
2.7
3.6
4.5
11.8
5.4
5.4
(N.A.)
11.8
21.8
20.0
14.5
21.8
8.2
Nickel Reduction
AMAX Inc.
AMAX Nickel Refining Co., Subs.
S.E.C. Corp.
Sulfuric Acid Tail Gas Scrubbing
By-Product
CF Industries, Inc.
Farmland Industries, Inc.
Braithwaite, La.
El Paso, Tx.
Plant City, Fla.
Green Bay, Fla.
Raleigh, N.C.
Other
Mallinckrodt, Inc.
Rohm and Haas Co.
Rohm & Haas Texas Inc., subsidiary Deer Park, Tx.
Tahoe Truckee Sanitation Agency Truckee, Ca.
Upper Occoquan Sewage Authority Fairfax County, Va.
(open May 1979)
90.7
2.4
21.8
14.5
(N.A.)
155.0
1.6
1.8
N.A. = not available
SOURCES:
Stanford Research International. 1978 Directory of Chemical Producers, pp.
457-458.
Research Triangle Institute.
8-6
-------
Table 8-3. Ammonium Sulfate Capacity
Distribution by Process - 1978
Process
Synthetic
Ammonium
Sulfate
Coke oven
by-product
Caprolactam
by-product
Nickel Reduction
by-product
Sulfuric Acid
Tail Gas
by-product
Acrylate
by-product
Water & sewage
treatment
by-product
SUBTOTAL
Other
TOTAL
Number of
Plants
10
40
3
2
2
1
2
60
N.A.
60+
Total
Plant
Capacity
(103 Megagrams)
790.11
529.00
1593.00 '.
93.10
36.30
155.00
3.40
3200
161
3361
Average Plant
Capacity
(103 Megagrams)
79.01
13.23
531.00
46.55
18.15
155.00
1.70
53.3
N.A.
N.A.
Share of
Industry
Capacity
(X)
23.5%
15.7%
47.4%
2.8%
1.1%
4.6%
.1%
95.2%
4.8%
100%
SOURCE: Table 8-2.
8-7
-------
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8-8
-------
resources used in the production of AS, five of the plants would
have experienced economic losses in that year, indicating that it
would be unprofitable for companies to construct new AS facili-
ties. However, all six plants were able to generate revenues to
cover their variable operating costs, making it more advantageous
for existing plants to stay open than to close down. Other
factors enabling the existing prime product facilities to remain
in operation were the availability of captive feedstocks on site
at all plants4, and, for the three plants located in California,
locational advantages over AS by-product producers situated in
the eastern states. As the structure of the AS industry has not
altered substantially since 1973, these factors continue to
protect the financial viability of prime producers.
Coke Oven By-product. The coking of coal generates gases
containing ammonia. In coke oven ammonium sulfate by-product
operations such gases can be "scrubbed" with sulfuric acid to
produce ammonium sulfate crystals. Utilizing this type of
process, between 7.5 kg and 13.5 kg of AS may be obtained for
every ton of coke produced by the plant.
The 40 coke oven by-product plants currently in operation
are relatively small, (plant size ranges from 1.8 Gg to 39 Gg),
with an average annual capacity of 13.23 Gg. Twenty-four of the
plants are located in the Eastern steel-producing states
(Pennsylvania, West Virginia, Ohio and Alabama). The others are
scattered throughout the rest of the country, with small concen-
trations in Texas, Illinois, Utah and Indiana (see figure 8-2).
Production of coke oven AS has declined in recent years as has
the number of plants utilizing this process. Coke oven by-
product output peaked in 1966 when 693 Gg of AS were produced by
48 plants.5*6 By 1973 the leol of output had dropped to 544 Gg
and the number of plants to 46.7 In 1978, output from coke oven
by-product plants declined still further to 407 Gg and the
8-9
-------
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8-10
-------
number of plants to 40. Further contraction of capacity is
scheduled in the future. The U.S. Steel plant at Duluth will
close in May, 1979.8
The decrease in coke oven AS production is the result of a
shift on the part of coke oven by-product plants to the
manufacture of alternative ammonia-based products such as ammonia
liquor, diammonium phosphate and anhydrous ammonia. Quantitative
data on the extent of such adjustments over the past five years
is available for only one of these products, ammonia liquor.
Between 1973 and 1978, coke oven by-product output of ammonia
liquor almost tripled, from 5.6 Gg to 15.4 Gg.9»10 Qualitative
evidence indicating that shifts from the production of AS to the
production of anhydrous ammonia are taking place was provided by
industry sources.11*12 This trend has been encouraged by the
post-1973 increase in the price of anhydrous ammonia relative to
the price of ammonium sulfate* and by the potential for spot-
shortages in the supply of ammonia produced from natural gas.
Two factors suggest that the process of transition from AS
production to other ammonia by-products will continue. First,
many of the existing coke oven by-product plants are relatively
old and may be due for reconstruction or replacement in the next
five to ten years. In a survey of coke oven plants, David et.
al. discovered that 20 of the 22 coke oven AS by-product plants
whose ages could be determined were constructed before I960.13
Second, new technologies are being adopted which enable coke oven
*In 1973 the ratio of the price of anhydrous ammonia to the price
of AS was 1.59; over the period 1974-76 this ratio averaged 1.70.
8-11
-------
by-product facilities to produce more valuable high-quality
anhydrous ammonia,* making that process a more profitable alter-
native.
The above factors suggest that the coke oven by-product
sector of the AS industry is likely to contract over the period
.
1979-1985, although the rate of contraction is difficult to
forecast.
Caprolactam By-product. Caprolactam can be produced by a
number of processes, though only three are currently utilized in
the U.S. Each of these processes involves the reaction of
hydroxylaminesulfate with cyclohexanone to produce cyclohexanone
sulfate. This compound is then neutralized with ammonia to
produce Caprolactam and AS. AS is also produced in the course of
manufacturing the hydroxylaminesulfate, a process which is
carried out on site. Slight variations in the processes used by
BASF, Nipro and Allied Chemicals result in variations in the
yield of AS per kg of Caprolactam produced. The actual range of
yields is estimated to be between 1.8 and 4.4 kg of AS per kg of
Caprolactam produced.15 The three plants are located in Texas,
Virginia and Georgia (see figure 8-3).
Although the Caprolactam by-product sector of the AS indus-
try consists of only three firms, their joint capacity is
estimated to be '1593 Gg or 47.4 percent of total industry
papacity, more than double that of any other sector of the
*0ne such technique is Phosam, developed by U.S. Steel and
recently implemented by Armco Steel Corporation at its facility
in Middletown, Ohio.1'*
8-12
-------
c
ID
8-13
-------
industry. In addition, 1977 caprolactam AS production was 1102
Gg, over 51 percent of total industry output for that year.* The
. i
caprolactam by-product sector achieved its dominant position in
the domestic industry over the ten year period 1962-1972. In
1962, total caprolactam production was 257 Gg representing only
16.7 percent of total AS output. By 1972, however, sector output
had increased to 1019 Gg, and its share of total output rose to
45.6 percent. Slower growth was experienced between 1972 and
1978.
Industry sources estimate that the caprolactam sector will
continue to grow at an estimated annual rate of 5 to 7 percent
with a corresponding increase in its share of industry output.
Much of the growth is likely to come at the expense of the
declining sectors of the industry, synthetic product and coke
oven by-product, as the industry-wide annual growth rate is
expected to be quite small (between 1 and 2 percent). Despite
the projections of substantial growth in the caprolactam by-
product sector, none of the three companies currently manufactur-
ing caprolactam intends to increase the size of its plants over
the period 1979-1985. "^ 19,20 In factj Allied and Badische Corp.
have indefinitely postponed or abandoned earlier proposals to
increase the size of existing plants and/or construct facilities.
The basis for the decision to delay construction of new
plants may be the existence of excess capacity. In 1977, the
production of caprolactam itself was 394 Gg21 while industry
capacity was 511 Gg 22, implying a relatively low sector capacity
utilization rate of 77.1 percent. It should be noted, however,
*Data on 1978 caprolactam AS production has been withheld by the
Bureau of Census for reasons of confidentiality.16
**C & E News., p. 12, June 18, 1979 reports that Dow-Badische
Corporation will expand caprolactam capacity 20 percent
at Freeport, Texas plant.
8-14
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that if industry caprolactam production continues to increase at
an annual rate of 6.1 percent between 1978 and 1985 (its rate of
growth from 1971-1977), 1985 annual production of caprolactam
would be 633 Gg, 122 Gg more than the current capacity.
Additional facilities capable of producing the shortfall would
have to be constructed and under existing technologies would
yield an additional 400 Gg of AS. A slightly larger growth rate
of 7 percent would result in a 1985 production level of 677 Gg of
caprolactam, 166 Gg in excess of current output.
8.1.1.2. Resource Use
Estimates of labor and energy consumption in the three
major sectors of the AS industry for 1976 are presented in table
8-4. Similar resource-use levels are presumed to have prevailed
in 1977.
8.1.1.3. Product Use.
The primary use of AS is as a fertilizer. It is also
employed in a number of industrial processes:
Fertilizer Use. Approximately 95 percent of apparent U.S.
consumption of AS is in the form of fertilizer (see table 8-5).
It is used because it provides two plant nutrients, nitrogen (N)
and sulfur (S), which are lost in the process of continuous
cropping. The product has two other desirable properties.
First, AS crystals do not readily absorb water from the air,
enabling the product to maintain its quality during transport and
long periods of on-farm storage. Second, AS is particularly
appropriate for use on high alkaline soils since an acid residue
is formed as the fertilizer decomposes, neutralizing the excess
alkaline. AS may be applied to crops directly or as part of a
fertilizer blend which includes other macronutrients. The data
presented in table 8-5 indicate that blend fertilizer applica-
tions have been and continue to be more important than direct
applications.
8-15
-------
Table 8-4. Resource Use, 1976
Resource
Number of Workers
Energy (1012Btu's)
Industry Sector
Synthetic
163
4.164
Coke Oven
By-product
458
1.460
Caprol actam
By-product
1005
6.37
SOURCE: RTI (See Appendix A)
8-16
-------
Table 8-5. Consumption of Ammonium Sulfate by Use
(103 Mg) '
Year
1960
1965
1970
1975
1978
Direct
Application
Fertilizer*
533
771
776
814
816
Fertilizer
Mixtures"*"
702-748
682-728
1158-1204
1122-1168
1091-1137
Industrial
Uses'*-
54-100
54-100
54-100
54-100
54-100
• —
Total Apparent
Consumption
1335
1553
2034
2036
2007
*United States Department of Agriculture, Statistical Reporting Service Crop
VnEnl^i °ard> Consult™" J2l Commercial Fertilizers in the U.S. Annual/
iyou-19/o.
+RTI estimates resultant from the subtraction of direct application
fertilizer and industrial uses from total apparent consumption.
""Stanford Research Institute. Chemical Economics Handbook. 1976.
Estimates in range due to fluctuations in consumption for industrial
purposes.
8-17
-------
Although U.S. fertilizer consumption of AS has increased
between 1955 and 1978, the importance of AS as a nitrogen
fertilizer has diminished. Until 1947, AS was the primary source
of solid nitrogen fertilizer in the U.S. However, because of its
relatively low nitrogen content (20.9 percent N) and its lack of
other macronutrients (phosphate and potash), AS has been replaced
by high analysis fertilizers as the major nitrogen source (see
section 8.1.3). These fertilizers include ammonium nitrate (33.5
percent N), urea (45.5 percent N), anhydrous ammonia (82 percent
N) and a variety of nitrogen solutions. The use of the high
analysis fertilizers instead of AS is partly explained by their
technological characteristics. (Urea, for example, is a quick
release fertilizer, suitable for application just prior to
harvesting, whereas AS is a slow release fertilizer, more
usefully applied at planting.) In addition, the price per unit
of nitrogen contained in AS is higher than the price per unit of
nitrogen for the high analysis products.* Finally, shipping
costs per unit of nitrogen from the plant to the farm gate are
lower for the high analysis chemicals.
AS is also in demand because of its relatively high sulfur
content (24 percent S). However, it is not the only fertilizer
capable of providing sulfur to sulfur-depleted soils. Substitute
chemicals include the superphosphates (1.2 percent to 11.9
percent S), potassium sulfate (18 percent S), elemental sulfur
(30 to 99.6 percent S), and gypsum (16.8 percent S). In
addition, new products such as sulfur-coated urea have become
sulfur-substitutes for AS. Consequently, though the demand for
*The price per kg of nitrogen for the major nitrogenous fertiliz-
ers in 1978 was as follows: AS, 57.5 cents; anhydrous ammonia,
18.6 cents; ammonium nitrate, 45.5 cents; Urea, 41.1 cents (see
table 8-7).23
8-18
-------
Table 8-6.
United States Ammonium Sulfate and Nitrogen Consumption 1955-1978
Megagram)
Year
1955
1956
1957
1958
1959
1960
1961
1962
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976
1977
1978
Ammonium
Sulfate
Consumed
1495
1314
1305
1324
1398
1335
1411
1368
1438
1706
1553
1452
1647
1310
1504
2034
2267
1897
2250
1846
2036
1897
2063
2007
Nitroaen
Available from
Ammonium Sulfate
314
285
274
278
294
280
296
287
301
358
326
305
346
275
316
427
479
398
472
388
428
398
433
421
Total Nitrogen
Consumed
as
Fertilizer
1779
1754
1937
2072
2423
2484
2750
3057
3564
3949
4208
4832
5468
6158
6312
6767
7379
7278
7525
8308
7809
9385
9659
9048
Ammonium Sul fate's
Share of Total
Nitrogen Consumed as
Fertilizer
17.65
16.25
14.15
13.42
12.13
11.27
10.77
9.39
8.45
9.07
7.75
6.31
4.47
4.47
5.00
6.31
6.45
5.47
6.28
4.67
5.47
4.24
4.48
4.65
SOURCES: United States Dept. of Agriculture, Economic Research Service, The
Changing U.S. Fertilizer Industry. Agricultural Economics Report No. 3787
August 1977TTp. 48, table 1.
United States Dept. of Agriculture, Economics, Statistics and Cooperatives
Service. Commercial Fertilizer: Consumption for Year Ended June 30, 1978.-
November 1978, p. 6, table 2.
United States Dept. of Agriculture, Statistical Reporting Service, Crop
Reporting Board. Consumption of Commercial Fertilizer in the U. S.
Annual. 1956-1978. —
8-19
-------
Table 8-7. Fertilizer Prices
(Dollars per megagram)
Year
1955
1956
1957
1958
1959
1960
1961
1962
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976
1977
1978
Ammonium
Sulfate
49.52
40.47
36.55
36.51
36.51
63.82
64.15
62.83
57.54
57.98
58.86
58.20
59.74
59.41
57.87
57.76
56.99
57.43
60.85
121.25
163.14
110.88
115.40
122.80
Ammoni urn
Nitrate
97.11
91.88
89.07
91.33
90.00
89.56
90.50
89.73
88.62
87.30
86.53
83.50
81.61
68.01
67.95
66.10
69.80
71.27
78.66
153.25
204.95
148.82
158.42
152.33
Urea
N.A.
N.A.
N.A.
141.09
134.48
128.97
124.56
119.60
116.84
115.74
114.09
110.78
109.34
101.31
92.28
91.28
90.28
89.78
99.31
201.62
268.83
183.07
185.08
186.83
Anhydrous
Ammoni a
181.33
173.61
167.00
164.79
159.83
154.87
153.77
148.26
140.54
136.69
133.38
129.52
124.74
100.33
83.16
82.25
87.68
88.58
96.72
201.57
291.96
209.70
200.21
184.39
28% N
Solution
N.A.
N.A.
N.A.
N.A.
N.A.
N.A.
N.A.
N.A.
N.A.
N.A.
N.A.
N.A.
N.A.
60.19
45.44
50.62
55.25
57.10
63.27
126.85
168.65
120.06
125.16
119.45
Superphos-
phate
38.64
38.80
39.41
40.95
41.28
41.61
42.16
42.33
44.42
44.31
44.92
45.52
46.41
47.56
48.67
50.87
53.35
55.72
60.46
107.69
121.80
107.09
111.94
104.00
SOURCES:
United States Department of Agriculture, Economics Statistics and
Cooperatives Service. Agriculture Prices Annual Summary, 1960-1977.
United States Department of Agriculture, Economics, Statistics &
Cooperatives Service, 1979 Fertilizer Situation, p. 10, table 5.
United States Department of Agriculture, Economic Research Service, The
ChlMng u!s! Fertilizer Indust^. Agricultural Economics Report No7T78.
August 19"7TT~p. 53, tabieTI
8-20
-------
sulfur fertilizers is likely to increase this does not necessari-
ly imply that there will be a substantial strengthening in the
demand for AS in the future.*
Industrial Use. Relatively small quantities of AS (approxi-
mately 5 percent of domestic consumption) are used in the
manufacture of industrial products. These include cattle feed
supplement, viscous rayon, fire control, fermentation, water and
sewage treatment, pharmeceuticals, tanning, antibiotics and pho-
tographic equipment. Total industrial use of AS is estimated to
be between 54 Gg and 100 Gg, and is not expected to increase
substantially.25
8.1.2. Production Trends
Over the period 1955-1978 AS output levels have exhibit-
ed considerable variability, ranging from a low of 1354 Gg in
1960 to a high of 2604 Gg in 1966 (see table 8-8). In addition,
no clear long term industry-wide production trend has been
established. For example, in 1955 output was 1954 Gg and by 1978
it had only increased to 2116 Gg.
The period 1955-1978 can be divided into four phases:
1955-1960, 1961-1966, 1967-1971 and 1972-1978. In the first
phase (1955-1960) AS production fell as domestic consumption
remained static and export levels fell. Although general fertil-
izer use was increasing, farmers began to adopt high analysis
fertilizers as a nitrogen source instead of increasing their use
of AS.
The advent of pollution control has reduced sulfur dioxide
emissions. Consequently, less sulfur is now being transmitted to
the earth via rainfall tuan was the case prior to 1970. In
addition, the switch to high analysis nitrogenous fertilizers has
reduced the stock of sulfur in the soils. These two factors have
combined to create the possibility of future depletion of sulfur
in soils.24
8-21
-------
Table 8-8. Ammonium Sulfate
Capacity, Production, Consumption and Inventories
(1CP Megayrams)
Year
1955
1956
1957
1958
1959
1960
1961
1962
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976
1977
1978*
Capacity
N.A.
N.A.
N.A.
N.A.
N.A.
N.A.
1335
1411
1483
1703
2435
2780
2789
2837
2957
2955
2957
2971
3311
3301
3435
3435
3361
3361
Production
1954
1795
1770
1570
1555
1354
1402
1540
1654
2093
2414
2604
2556
2424
2317
2259
2142
2234
2408
2366
2354
2447
2153
2116
Percent
Utilization
N.A.
N.A.
N.A.
N.A.
N.A.
N.A.
105
109
112
123
99
94
92
85
78
76
72
75
73
72
68
58
57
52
Consumption
1495
1314
1305
1324
1398
1335
1411
1368
1438
17(36
1553
1452
1647
1310
1504
2034
22157
1897
2250
1846
2036
1897
2063
2007
Inventories
N.A.
N.A.
N.A.
N.A.
N.A.
N.A.
N.A.
N.A.
N.A.
N.A.
484
319
430
397
599
546
161
238
131
404
360
203
258
325
*1978 Production data is based on the calendar year.
SOURCES:
British Sulphur Corp. London, England.
U.S. Dept. of Agriculture, Statistical Reporting Service, Crop Reporting
Board. Consumption of Commercial Fertilizer in the U.S., 1956-1978.
U.S. Department of Commerce, Bureau of the Census. Current Industrial
Reports Series M28B. 1966-1978.
i
U.S. Department of Commerce, Bureau of the Census. Current Industrial
Reports Series M28A, 1965.
i
U.S. Dept. of Agriculture, Economics, Statistics, and Cooperatives Service.
1979 Fertilizer Situation, p. 9, table 3.
8-22
-------
During the second phase (1961-1966) production went through
a period of expansion, rising from 1402 Gg in 1961 to 2604 Gg in
i%6. The increase in production during this time can be
explained by three factors: (1) the world-wide surge in the
demand for nitrogenous fertilizer,** (2) the introduction of a U.
S. A.I.D. program to subsidize AS exports to third world
countries, particularly Latin America, and (3) the employment of
new chemical processes capable of generating AS as a low cost
by-product.
Following the peak output levels achieved in 1966, AS
production began to wane despite record export levels demand in
1967. Output continued to fall during the third phase (1967-
1971) until 1971, when production bottomed out at 2142 Gg. This
period of declining output was partially the result of (1) excess
capacity throughout the fertilizer industry and (2) a substantial
decrease in demand for U.S. exports from 1461 Gg in 1966 to 468
Gg in 1971 (see table 8-9). The decline in foreign demand was
associated with the termination of the U.S. AID subsidy program
in 1968 and an increase in Latin American nitrogenous fertilizer
capacity.
During the fourth phase (1972-1978), AS production fluctuat-
ed from year to year, exhibiting no apparent trend. This
variability may partially be explained by divergent trends in
separate sectors of the AS industry. In 1972 and 1973 a gradual
contraction in coke oven by-product production was more than
offset by expansion within the caprolactam sector. In 1974,
however, caprolactam production was curtailed by rapidly
prime product plants were opened between 1960-1965.26
*The domestic price per metric ton of AS rose from $36.55 in
1959 to $63.82 in 1960 and remained at or close to that level
between 1960 and 1965.
8-23
-------
Table 8-9. Ammonium Sulfate Imports and Exports
(103 Megagrams)
Year
1955
1956
1957
1958
1959
1960
1961
1962
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976
1977
1978
Imports
157
180
150
170
197
191
224
219
213
160
164
145
152
119
125
198
208
239
271
234
199
513
297
295
Exports
555
692
709
351
363
215
131
489
445
439
872
1,461
950
1,266
737
474
468
471
441
505
572
682
445
355
Net Exports
398
512
559
181
166
24
-93
270
232
279
708
1,316
798
1,147
612
276
260
232
170
271
373
169
148
60
SOURCES ;
U.S. Dept. of Commerce, Bureau of Economic Analysis. Business Statistics,
March 1978, p. 123.
United States Department of Agriculture, Agricultural Stabilization and
Conservation Service. The Fertilizer Supply 1973-74, 1973-74, 1974-75.
United States Department of Agriculture, Economics, staj;istj" anjj 1R
Cooperatives Service. 1979 Fertilizer Situation. December 1978, p. 18,
tables 19 and 21.
U.S. Dept. of Commerce Bureau of the Census. U.S.. Experts Schedule_B
Commodity and Country Report FT - 410, 1955-1977.
8-24
-------
increasing energy prices. The result was a reduction in the
output of by-product ammonium sulfate and a decline in total AS
production.
Output levels remained relatively unchanged in 1975 . and
increased only slightly in 1976. During these years, increased
-caprolactam by-product compensated for a decline in synthetic
production. In 1977, production fell from its 1976 level of 2447
Gg to 2153 Gg. The cutback was generated by a reduction in
caprolactam by-product AS. Output again fell in 1978 to 2116
Gg.
8.1.3. Domestic Consumption
Domestic consumption of AS increased at an average annual
rate of 1.29 percent between 1955 and 1978, from 1495 Gg in 1955
to 2007 Gg in 1978. The increase in domestic AS consumption has
been much smaller than the increase over the same period in total
nitrogen consumption by the agricultural sector. Total nitrogen
consumption rose from 1779 Gg in 1955 to 9048 Gg in 1978, an
average annual increase of 7.33 percent. During this period the
share of domestic agricultural consumption of nitrogen provided
by AS fell from 17.65 percent to 4.65 percent. Between 1955 and
1969 AS consumption was relatively stable, fluctuating between
1305 Gg (1957) and 1706 Gg (1964). In 1970, domestic consumption
of AS increased as exports fell and by-product output increased,
rising from 1504 Gg in 1969 to 2054 Gg in 1970. Since 1970,
output has fluctuated from year to year, peaking at 2267 Gg in
1971 and 2250 Gg in 1973. No long run growth trend for
consumption of AS has emerged over this period, although sulfur
deficiencies in the content of cultivated soils may generate some
increase in domestic demand for the product over the next five to
ten years. In this context, it is worth noting that of the total
domestic consumption of AS in 1978, 48 percent (390 Gg) went to
the Pacific Region of the United States where soil-sulfur content
8-25
-------
is low. The Appalachian States on the other hand, accounted for
only 56 percent (4.6 Gg) of total U.S. direct application
ammonium sulfate consumption.27
8.1.4. Prices
Ammonium sulfate prices dropped steadily over the period
1955-1959 from $49.52 in 1955 to $36.15 in 1959 (see table 8-10).
The price fall corresponded with a period of contracting domestic
demand and declining exports. In 1960 market prices rose sharply
to $63.82 as domestic consumption increased. Prices remained
stable in 1961, but fell back to $62.83 in 1962 as domestic
consumption again declined. Over the period 1963-1973 prices
remained relatively stable, ranging from $56.99 in 1971 to $60.85
in 1973. In 1974, the price of AS almost doubled, rising to
$121.25 as the price of natural gas increased, reflecting its
diminished availability. Prices peaked in 1975 at $163.14, and
then began to taper off. By 1978 the prices had fallen to
$122.80.
8.1.5. International Trade
Over the period 1955-1978 the U.S. both imported and
exported AS. However in all but one of those years (1961) it has
been a net exporter of the product. Net exports have varied
greatly from year to year, being extremely low in 1960 (24 Gg)
and 1978 (60 Gg), and negative in 1961 (-93 Gg), but being
relatively large in 1966 (1316 Gg) and 1968 (1147 Gg) (see Table
8-9).
Exports were more variable than imports during the period
ranging from a low of 131 Gg in 1961 to a high of 1461 J»n 1966.
"'Prices presented in this section are per meqagram of AS.
greatly from year to year, being extremely low in 1960 (24 Gg)
and 1978 (60 Gg), and negative in 1961 (-93 Gg), but being
relatively large in 1966 (1316 Gg) and 1968 (1147 Gg) (see table
8-9). . ;
8-26
-------
Table 8-10. Ammonium Sulfate Prices
(Dollars per megagram)
Year
1955
1956
1957
1958
1959
1960
1961
1962
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976
1977
1978
Domestic
Price
49.52
40.47
36.55
36.51
36.51
63.82
64.15
62.83
57.54
57.98
58.86
58.20
59.74
59.41
57.87
57.76
56.99
57.43
60.85
121.25
163.14
110.88
115.40
122.80
Export
Price
49.75
45.79
41.52
38.75
35.66
31.13
38.57
33.94
36.41
39.83
45.33
46.76
45.26
38.59
38.54
17.01
15.50
29.71
32.09
74.74
73.30
45.30
41.80
60.85
*NA - not available
SOURCES
U.S. Department of Agriculture, Statistical Reporting Service.
Agricultural Prices, 1955-1960.
U.S. Department of Agriculture, Economics Research Service. The
Changing U.S. Fertilizer Industry. Agricultural Economic Report
No. 378. August, 1977, p. 53, table7.
U.S. Department of Commerce, Bureau of the Census. U.S. Exports
Schedule B-Commodity and Country Report FT-410, 1955^1559.
British Sulphur Corporation, Half Yearly Export Price Indications
for Ammonium Sulphate, 1963-1974, 1967-1978.
8-27
-------
Between 1955 and 1961, exports fell from 555 Gg to 131 Gg.
However, in the early sixties they began to rise as 1) demand for
fertilizer in third world countries increased, 2) production
capacity in the U.S. rose, and 3) U.S..AID programs to subsidize
fertilizer exports to developing countries were implemented.
After 1966, export levels declined following a deemphasis of
export subsidies for fertilizers and a rise in the nitrogenous
fertilizer capacity in major U.S. export markets, particularly
Latin America. Since 1970, export levels have been relatively
stable, ranging from 355 Gg in 1978 to 682 Gg in 1976. Average
annual exports from 1970-1978 were 490 Gg.
The level of imports was much less variable than the level
of exports from 1955-1978. In all but one year, 1976, imports
ranged from 119 Gg to 297 Gg. The 1976 level of imports was
unusually large in 1976 (513 Gg), stimulated by a record level of
domestic demand for nitrogenous fertilizer. Imports fell back to
more typical levels in 1977 (297 Gg) and 1978 (295 Gg), although
they were still in excess of the annual average level of imports
(209 Gg) for the period 1955-1978.
8.1.6. Market Structure
8.1.6.1. Firm Characteristics
The. firms involved in the production of AS are, by and
large, vertically and/or horizontally integrated companies for
whom AS production is not a major source of revenue. Though this
is particularly true of by-product manufacturers, it also holds
for prime producers, many of whom manufacture other fertilizers
and chemicals. Most of the firms are relatively large (e.g.
Allied, U.S. Steel, Nipro, BASF), and some are multinational
corporations. Because of the diverse nature of the other
activities of the firms involved in AS production (steel produc-
tion, industrial chemicals, fertilizer, etc.) profits vary con-
siderably among these companies (see table 8-11). However, in
8-28
-------
Table 8-11. Financial Parameters for Selected Companies
Company
Standard Oil
Co. of California
Chevron Chemical
Co, Subsidiary
Occidental Petroleum
Corporation -
Hooker Chemical
Corp. Subsidiary
Richardson-Merrell ,
Inc., J. T. Baker
Co., subsidiary
Allied Chemical
Corp., Fibers
Division
Year
1977
1977
1978
1977
AS
Process
Synthetic
Synthetic
Synthetic
Caprolactam
After Tax-Returns
on Equity
13.31%
13.23%
14.29%
11.3%
Net Worth/Debt
Ratio
1.06
0.70
1.56
0.71
SOURCES
Securities and Exchange Commission. 10K Forms.
8-29
-------
1977 profit levels appeared to provide an adequate rate of return
on equity for several of the companies, ranginy, from 11.3 percent
to 14.29 percent for the four companies for which data was
available.
8.1.6.2. Market Concentration
The domestic AS industry is highly concentrated with
the largest four firms controlling 53.5 percent and the top eight
firms 70 percent of total AS capacity (see table 8-12). The
industry is, in fact, dominated by the three caprolactam by-
product producers -Allied, Nipro, and BASF. Since future industry
growth is likely to be concentrated in this sector, industry
concentration will probably increase over the next five to ten
years, although it has been relatively stable since 1970.
Consequently,, the structure of the supply industry suggests that
quasi-monopoly pricing behavior may become a possibility. How-
ever, the product itself faces strong competition from close
substitutes such as urea and ammonium nitrate in the nitrogenous
fertilizer market, and this strong interproduct competition
limits the ability of dominant AS producers to manipulate product
price.
8.1.7. Supply and Demand
8.1.7.1. Supply
No attempt was made to develop an econometric model of
the AS industry. Nevertheless, it is clear that the production
of AS is heavily influenced by its own price and the price of key
inputs. For the prime product sector such inputs include
sulfuric acid and anhydrous ammonia, labor, machinery and equip-
ment. In the case of coke oven by-product AS, an important
consideration is the value of alternative by-products such as
anhydrous ammonia, ammonia liquor and diatnmonium phosphate.
8-30
-------
Table 8-12. Industry Concentration of Ammonium Sulfate Producers
(Share of total production capacity)
£ of
firms
Year
1970
1978
1979
Largest
Four
Firms
52%
54
53.5
Largest
Eight
Firms
68%
70
70
Largest
Ten
Firms
73.5%
76
76
Largest
Twenty
Firms
87%
88
88
Largest
Forty
Firms
99%
98
98
SOURCE: Research Triangle Institute.
8-31
-------
Increases in the prices of these alternative by-products relative
to the price of AS and the development of new technologies for
their manufacture resulted in a decline in the production of coke
oven by-product AS. A critical variable in the caprolactam
by-product sector is the price of caprolactam itself. As the
price of caprolactam increases, stimulating the production of
that product, the output of by-product AS increases. It should
be noted that caprolactam is the more valuable of the two
products. Its current (1979) market price is $1399.92 per metric
ton, compared with $71.65 per metric ton for AS.28
8.1.7.2. Demand
Econometric techniques were used to analyze time series
data on the domestic consumption of AS for 1955-1977. The
objective was to investigate the impact on consumption of changes
in the prices of AS and substitute commodities, technical
innovation and the level of output in the agricultural sector,
the major user of AS. A number of different specifications of
the relationship beteen AS consumption and the various possible
explanatory variables were considered in the analysis. The two
most satisfactory estimated equations are presented below. These
equations attempt to explain the share of total nitrogen fertil-
izer consumption accounted for by AS in terms of its own price,
the price of ammonium nitrate, the price of anhydrous ammonia and
a time trend. The time trend was included to allow for the
possibility of technical change. The estimated equations are:
*Data on AS consumption and product prices is presented in tables
8-5, 8-7 and 8-10.
8-32
-------
CAS
(1) log — = -1.92 -2.78** log PAS + 2.40** log PAN
N (1.23). (1.23) (1.05)
+ 0.002 Tog T ; R2 = 0.51,
(0.05)
CAS
(2) log — = -3.50 - 2.60** log PAS + 1.87** log PAA
N (1.22) (0.88)
+ 0.04 log T; R2 = 0.50,
(0.06)
where,
CAS = domestic consumption of ammonium sulfate
measured in terms of its nitrogen content,
N = total domestic consumption of nitrogen fertilizer,
PAS = price of ammonium sulfate
PAA = price of anhydrous ammonia,
PAN = price of ammonium nitrate,
T = time,
R2 = the coefficient of multiple correlation,
log = natural logarithms.
**.
The two equations presented here were most satisfactory in the
sense that they accounted for more of the variation in the data
than any other estimated equation for which the coefficients
attached to the price variables were of expected sign and
significance at the 5% level. In addition, in both cases the
Durbin-Watson statistics provided no support for the hypothesis
that serial correlation existed in the error structure.
these coefficients are significantly different from zero at the
95 percent confidence level.
8-33
-------
The figures in parentheses are the standard errors of the
estimated coefficients. Each of the above equations explains
approximately fifty percent of the variation in AS consumption
over the period 1955-1977.* They are, therefore, not satisfac-
tory tools for purposes of forecasting future trends in ammonium
sulfate consumption. However, the results do indicate that the
price of ammonium sulfate itself and the prices of substitute
products such as anhydrous ammonia and ammonium nitrate strongly
influence AS consumption. Equations (1) and (2) suggest that a
one percent increase in the price of AS reduces the size of its
share of the nitrogen fertilizer market by between 2.6 and 2.78
percent. On the other hand, a one percent increase in the price
of the substitute nitrogen fertilizer** increases ammonium sul-
fate' s share in the nitrogen fertilizer market by between 1.8 and
2.4 percent. Own-price and cross-price impacts appear to be
substantial, supporting the view that a great deal of interaction
takes place between the markets for the different nitrogenous
fertilizers.
Finally, it should be noted that in the estimated equations
the time trend included to account for technological change
explained virtually none of the variation in the share of AS in
total nitrogen consumption. However, this result should not be
interpreted as positive evidence that consumption of AS was not
*The R2 coefficient measures the fraction of the sample period
variation in the dependent variable explained by the estimated
equation.
**The prices of ammonium nitrate, urea and anhydrous ammonia have
been highly correlated over the past 25 years because they use
common inputs. Thus we may regard movements in the price of
one of these fertilizers as representative of changes in the
prices of them all.
8-34
-------
influenced by product innovation in the fertilizer industry. The
data used in the analysis exhibited the statistical problem of
severe multicol linearity among the explanatory variables (in
particular among fertilizer prices). Consequently, only the very
simple equations presented above provided partially satisfactory
results.
8.1.8. Baseline Projections
8.1.8.1. Baseline Regulatory Environment
The industry is assumed to be in compliance with
existing State Implementation Plan (SIP) regulations prior to
enforcement of any new source performance standard.
8.1.8.2. Baseline Growth Rates
Industry sources estimate that the annual rate of
growth for AS consumption will be approximately 1 percent per
year. However, there will be considerable variation in the
growth rates experienced by the three major sectors in the
industry.
Synthetic. No growth is expected in this sector in the
five years following 1980 (1981-1985). However, although none
of the existing plants have definite plans to modify or recon-
struct their facilities, two producers may need to replace
their dryers.
Coke Oven By-Product. Output from this sector is ex-
pected to decline in the five years following 1980 though the
rate of decrease is not known. No new plants are forecast,
and it is unlikely that more than four plants will implement
major modification or reconstruction programs in the five
year period 1981 through 1985. The forty coke oven plants
currently producing AS use dryers with expected lives of
8-35
-------
20-50 years. On average, each year only one or two plants will
need to replace dryers. Thus, over a five-year period, only six
to ten plants will have to consider retrofitting new equipment,
and at least half of these plants are likely to close if the
downtrend in coke oven production continues. (Between 1973 and
1978 the number of operational coke oven by-product plants fell
from 46 to 40).
!
|
]
Caprolactam By-Product. The growth rate for caprolactam
production is forecast to be between 5 and 7 percent over the
period 1979-1985. It was noted in section 8.1.1 that in 1977
caprolactam production was 394 Gg, while industry capacity was
511 Gg. A 6.1 percent growth rate for caprolactam implies that
caprolactam output will be 633 Gg in 1985. Two new capro-
lactam plants would be needed to provide the additional 122 Gg
of caprolactam production capacity required to meet projected
1985 production levels and provide measurable excess capacity.
Each plant would have a caprolactam capacity of approximately
115 Gg and an AS capacity of 380 Gg. In addition to these
new plants, an existing facility will probably have to replace
its drying equipment in the five-year period 1981 through 1985.
Thus a total of three caprolactam plants will have to install
emissions control in order to meet the emissions limits established
by any promulgated regulation.
8.1.8.3. Baseline Projections of New. Modified and Reconstructed
Facilities
The total number of new and reconstructed facilities pro-
jected under baseline conditions is summarized below:
Affected Facilities
Synthetic 2
Coke Oven By-Product , 4
Caprolactam By-Product 3
8-36
-------
8.2 COST ANALYSIS OF ALTERNATIVE CONTROL SYSTEMS
This section presents an analysis of the costs of alternative control
systems for dryers in three major segments of the ammonium sulfate industry.
The control systems considered are fabric filter, venturi scrubber, and low-
energy scrubber; the branches of the industry are the caprolactam byproduct,
prime production, and coke oven byproduct segments.
The approach taken in determining the costs involved three steps; (1)
determination of representative model plant parameters directly related to
control costs; (2) application of the selected control systems to each
segment of the industry; and (3) assessment of the total costs for the appli-
cation of each control system at each typical dryer exhaust rate. The
analysis includes total capital and annualized costs for each control system
and also the incremental cost and cost-effectiveness of those systems capable
of meeting the most stringent emission limitation. Results of this analysis
will be used in determining the economic impacts of the control systems in
Section 8.4.
The particulate control systems are designed in accordance with the model
plant parameters furnished in Section 6 and shown in Tables 8-13 and 8-14.
Tables 8-13 presents the^ production capacities of ammonium sulfate dryers and
the corresponding exhaust gas volumes for the three segments of the industry.
As shown in the table, dryers with the same production capacity may have
different exhaust gas rates.
Model plant particulate emission parameters are shown in Table 8-14
functions of dryer production capacity and gas exhaust rates. The table sets
forth the levels of uncontrolled emissions and those permitted by State
Implementation Plans (SIP) and Option II with one exception, uncontrolled par-
ticulate emissions are estimated at 12.5 g/Nm3 (5 gr/dscf), a value derived by
back-calculation from emission levels at an assumed 99.6 percent removal
efficiency. The exception is Case 1, the 27.2-Mg/h (30-ton/h) dryer, for
which the value is based on actual p^ant data.
The Option II offers two formats, one regulating the mass particulate
emissions and one limiting the concentration. As shown in Tables 8-13, the
control level stipulated by either of the Option II formats is much more rigorous
than those required,by SIP. For this reason, the alternative control systems are
8-37
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deigned to meet Option II requirements. The standards used are those governing
participate concentration in the effluent gas stream. Because both Option II
formats require equivalent removal efficiency levels, the costs and cost-
effectiveness of complying with either regulatory.format are considered the same.
The control systems for which estimates were made are as discussed in
Chapter 6. Table 8-15 describes the three alternative control systems: the
fabric filter, the venturi scrubber, and the low-energy scrubber.
8.2.1 New Facilities
8.2.1.1 Capital and Annualized Operating Costs of Control Systems—
The capital and annual operating costs for each control system depend on
the exhaust gas rate from the dryer. This rate varies significantly among
segments of the ammonium sulfate industry and also within each segment. Cost
estimates applicable to all types and sizes of dryers are obtained by
consideration of the following exhaust gas rates:
j
(acfm)
m /min
8.5
28.3
283
1,189
1,698
(300)
(1,000)
(10,000)
(42,000)
(60,000)
Capital cost estimates are developed by (1) determining basic equipment
costs, f.o.b.; (2) developing component factors for capital costs based on
equipment costs; and (3) applying the cost component factors to the basic
equipment costs to obtain total capital costs. The capital costs represent
the total investment required for purchase and installation of the basic
control equipment and associated auxiliaries, including equipment for dust
recovery. No attempt is made to include either costs of research and develop-
ment or costs of possible production losses during equipment installation and
startup. The installation period for a control system is estimated to be
approximately 2 months. Because little information is available regarding
construction interest charges for such a short installation time, such charges
are not included. All costs are stated in mid-1978 dollars and are based on
equipment costs obtained from manufacturers.
8-40
-------
TABLE 8-15. SPECIFICATIONS FOR EMISSION CONTROL SYSTEMS
II.
Fabric filter
A.
B.
C.
D.
Bag medium: Dacron felt
Air-to-cloth ratio: 4:1
Cleaning mechanism: reverse jet (heated)
Units requiring insulation: dryer, ductwork, and
baghouse
Operating temperatures
1. Inlet and outlet: 79°C (175°F)
2. Dew point: 51°C (123°F) at 12.6 volume percent of
water vapor (maximum)
Pressure drop: 15.2 cm (6 in.) H20 (suction baghouse)
Fan location: discharge of baghouse
Construction material: a. fiberglass-reinforced plastic
b. carbon steel
I. Typical duct distances between dryer and fabric filter
1. Caprolactam byproduct: 12.2 m (40 ft)
2. Prime product: 6.1 m (20 ft)
3. Coke oven byproduct: 3.0 m (10 ft)
Venturi scrubber
F,
G,
H.
A. Pressure drop: 30.5 cm (12 in.) H20 (pressure venturi)
B. Fan location: between dryer and scrubber
C. Liquid-to-gas ratio: 0.37 m3/100 m3 (28 gal/10 ft )
D. Operating temperatures
1. Inlet: 79°C (175°F)
2. Outlet: 43°C (110°F)
E. Construction material: fiberglass-reinforced plastic
F. Typical duct distances between dryer and venturi
scrubber
1. Caprolactam byproduct: 15.2 m (50 ft)
2. Prime product: 9.1 m (30 ft)
3. Coke oven byproduct: 4.6 m (15 ft)
III. Typical low-energy scrubber used to meet process weight
regulations
A. Scrubber type: centrifugal,
B. Pressure drop: 5-13 cm (2-6
C. Operating temperatures
1. Inlet: 79°C (175°F)
2. Outlet: 43°C (110°F)
D. Liquid-to-gas ratio: 0.27-0.68
having no moving parts
in.) H20
m3/100
m
(2-5 gal/10'
ft3)
8-41
-------
Annualized costs represent the cost of operating and maintaining a
control system plus the cost of recovering the capita] investment required for
the system. They include direct costs (utilities, operating labor, and
maintenance), indirect costs (capital charges, overhead, and fixed costs), and
credits for recovery of marketable particulate dust. Table 8-16 presents the
assumptions made in estimating annualized costs.
Table 8-17 presents estimates of unit costs, f;o.b., for the basic equip-
ment of a control system. The estimates represent actual costs obtained
directly from equipment manufacturers.
The cost of a fabric filter unit includes the costs of the filter bags,
air cleaning system, screw conveyor and air lock, fan, dampers, and pumps.
Also included in the cost is a mix tank fitted with an agitator for mixing
collected dust. The filter bags are dacron felt, and the materials of con-
struction for the total system are either fiberglass-reinforced plastic (FRP)
or carbon steel [referred to as standard construction material (STD)]. It is
recommended that the carbon steel used be coated to protect against corrosion.
According to published data, exposure of mild steel to a 10 to 30 weight ;
percent solution of ammonium sulfate at temperatures ranging from 50° to 75°C
(122 to 167°F) results in a corrosion rate of at least 50 mils (0.05 inch) per
year.35 At this rate, carbon steel components with a corrosion allowance of
0.125 inch would have an expected life of 2.5 years.
The cost of a venturi scrubber unit includes the costs of the scrubber,
mist eliminator, fan, dampers, circulating pumps, and mix tank with cover.
The material of construction is FRP.
The cost of a low-energy scrubber unit includes the scrubber, circulating
pumps, and a mix tank with cover. The scrubber is made of polyvinyl chloride.
Tables 8-18 through 8-27 present the capital cost factors for fabric
filters of FRP and STD construction. Tables 8-28 through 8-32 present the
capital cost factors for a venturi scrubber, and Tables 8-33 through 8-37
present the capital cost factors for a low-energy scrubber. These factors
are based on information obtained from control system manufacturers and on
PEDCo engineering experience. The factor by which equipment costs are multi-
plied to obtain total capital costs is called the equipment cost multiplier.
8-42
-------
TABLE 8-16. BASES FOR ESTIMATING ANNUALIZED COSTS
FOR EMISSION CONTROL SYSTEMS3
(mid-1978 dollars)
Unit cost
Direct operating costs
Utilities
Water
Electricity
Operating labor
Direct
Supervision
Maintenance
Labor
Material
Miscellaneous
Capital charges
Overhead
Plant
Payroll
Fixed costs
Capital recovery
Taxes and insurance
Administration and
permits
Recovery credits
Reprocessed ammonium
sulfate
$0.0625/m3 ($0.25/103 gal)
$0.03/kWh
$7.25/h
15% of direct labor
115% of operating labor
Equal to operating labor
Cost of bag replacement every 4 yrs
50% of operating and maintenance
labor plus maintenance materials
20% of operating labor
14.67% of total capital costs
2.0% of total capital costs
2.0% of total capital costs
$53/Mg ($48/ton)
Estimates are for the control system and associated solid
waste disposal equipment. Calculations are based on the
following operating factors: caprolactam, 8400 h/yr; prime
product, 5400 h/yr; coke oven byproduct, 7400 h/yr.
Based upon a 12 yr life and a 10% interest rate.
c Based on a market price of $66.14/Mg with a 20% discount for
reprocessing costs.
8-43
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TABLE 8-18. COMPONENT CAPITAL COST FACTORS FOR
FRP FABRIC FILTER 8.5 m3/min (300 acfm)
Description
Equipment, f.o.b.
manufacturer
Site erection of
equipment
Duct work
Instrumentation
Piping
Electrical work
Foundations
Structural work
Site work
Insulation
Painting
Other
Total Direct Cost Factor
Engineering
Contractor's overhead
and profit
Shakedown
Spares
Freight
Taxes
Other
Total Indirect Cost Factor
Contingencies
Direct Costs
Components
Material
1.000
0.009
0.028
0.097
0.075
0.188
0.068
0.218
0.005
0.052
0.007
1.747
Labor
0.033
0.018
0.029
0.179
0.122
0.068
0.049
0.005
0.077
0.042
0.622
Factor
Total
1 000
0.042
0.046
0.126
0.254
0.310
0.136
0.267
0.010
0.129
0.049
Total
2.369
Indirect Costs
Basis for factor
10% of total direct
costs
26.5% of total direct
costs
5% of direct costs
1% of direct material
cost only
3% of direct material
cost only
3% of direct material
cost only
20% of total direct
and indirect costs
TOTAL EQUIPMENT COST MULTIPLIER
Factor
0.237
0.628
0.118
0.002
0.052
0.052
Total
1.089
0.692
4.150
8-45
-------
TABLE 8-19. COMPONENT CAPITAL COST FACTORS FOR FRP FABRIC
FILTER—28.3 m3/min (1000 acfm)
Description
Equipment, f.o.b.
manufacturer
Site erection of
equipment
Duct work
Instrumentation
Piping
Electrical work
Foundations
Structural work
Site work
Insulation
Painting
Other
Total Direct Cost Factor
Engineering
Contractor's overhead
and profit
Shakedown
Spares
Freight
Taxes
Other
Total Indirect Cost Factor
Contingencies
Direct Costs
Components
Material
1.000
0.005
0.019
0.050
0.039
0.097
0.052
0.182
0.003
0.043
0.006
1.496
Labor
0.026
0.012
0.015
0.092
0.063
0.052
0.042
0.003
0.068
0.036
0.409
Factor
Total
1.000
0.031
0.031
0.065
0.131
0.016
0.104
0.224
0.006
0.111
0.042
Total
1.905
Indirect Costs
Basis for factor
10% of total direct
costs
26.5% of total direct
costs
5% of direct costs;
1% of direct material
cost only
3% of direct material
cost only
3% of direct material
cost only
20% of total direct
and indirect costs
TOTAL EQUIPMENT COST MULTIPLIER
Factor
0.191
0.505
0.095
0.015
0.045
0.045
Total
0.896
0.560
3.361
8-46
-------
TABLE 8-20.
PRP FABRIC
Desciiption
Equipment, f.o.b.
manufacturer
Site erection of
equipment
Duct work
Instrumentation
Piping
Electrical work
Foundations
Structural work
Site work
Insulation
Painting
Other
Total Direct Cost Factor
Engineering
Contractor's overhead
and profit
Shakedown
Spares
Freight
Taxes
Other
Total Indirect Cost Factor
Contingencies
Direct Costs
Components
Material
1.000
0.002
0.012
0.013
0.007
0.026
0.030
0.045
0.001
0.036
0.001
T. 174
Labor
0.006
0.010
0.004
0.019
0.015
0.030
0.010
0.001
0.058
0.009
0.162
Factor
Total
.
1.000
0.008
0.022
0.017
0.026
0.041
0.060
0.055
0.002
0.094
0.010
Total
1.335
Indirect Costs
Basis for factor
10% of total direct
costs
26.5% of total direct
costs
5% of direct costs
1% of direct material
cost only
3% of direct material
cost only
3% of direct material
cost only
20% of total direct
and indirect costs
TOTAL EQUIPMENT COST MULTIPLIER
Factor
01 1A
• X j<±
0.354
0.067
0.012
0.035
0.035
Total
0.637
0.394
8-47
-------
TABLE 8-21. COMPONENT CAPITAL COST FACTORS FOR FRP
FABRIC FILTER—1,189 m3/min (42,000 acfm)
Direct Costs
Description
Equipment, f.o.b.
manufacturer
Site erection of
equipment
Duct work
Instrumentation
Piping
Electrical work
Foundations
Structural work
Site work
Insulation
Painting
Other
Total Direct Cost Factor
Engineering
Contractor's overhead
and profit
Shakedown
Spares
Freight
Taxes
Other
Total Indirect Cost Factor
Contingencies
Components
Material
1.000
0.001
0.014
0.010
0.002
0.013
0.016
0.023
0.001
0.029
0.001
1.110
Labor
0.003
0.011
0.002
0.005
0.007
0.016
0.005
0.001
0.046
0.005
0.101
Factor
Total
1.000
0.004
0.025
0.012
0.007
0.020
0.032
0.028
0.002
0.075
0.006
Total
1.211
Indirect Costs
Basis for factor
10% of total direct
costs
26.5% of total direct
costs
5% of direct costs
1% of direct material
cost only
3% of direct material
cost only
3% of direct material
cost only
20% of total direct
and indirect costs
TOTAL EQUIPMENT COST MULTIPLIER
Factor
0.121
0.321
0.061
0.011
0.033
0.033
Total
0.580
0.358
2.149
8- 48
-------
TABLE 8-22. COMPONENT COST FACTORS FOR FRP
FABRIC FILTER—1,698 m3/min (60,000 acfm)
Description
Equipment, f.o.b.
manufacturer
Site erection of
equipment
Duct work
Instrumentation
Piping
Electrical work
Foundations
Structural work
Site work
Insulation
Painting
Other
Total Direct Cost Factor
_
Engineering
Contractor ' s overhead
and profit
Shakedown
Spares
Freight
Taxes
Other
Total Indirect Cost Facto:
Con t ing enc i e s
Direct Costs
Components
Material
1.0000
0.0009
0.0152
0.0071
0.0014
0.0104
0.0144
0.0211
0.0004
0.0247
0.0007
1.0963
Labor
0.0027
0.0128
0.0015
0.0036
0.0058
0.0144
0.0048
0.0004
0.0392
0.0041
0.0893
Factor
Total
1.0000
0.0036
0.0280
0.0086
0.0050
0.0162
0 0^88
0.0259
0.0008
0.0639
0.0043
Total
1.1856
Indirect Costs
Basis for factor
10% of total direct
costs
26.5% of total direct
costs
5% of direct costs
1% of direct material
cost only
3% of direct material
cost only
3% of direct material
cost only
-
20% of total direct
and indirect costs
TOTAL EQUIPMENT COST MULTIPLIER
Factor
0.119
0.3142
0.0593
0.0109
0.0329
0.0329
Total
0.5692
-0.3510
2.1058
8-49
-------
TABLE 8-23. COMPONENT CAPITAL COST FACTORS FOR STD
FABRIC FILTER—8.5 m3/min (300 acfm)
Description
Equipment, f.o.b.
manufacturer
Site erection of
equipment
Duct work
Instrumentation
Piping
Electrical work
Foundations
Structural work
Site work
Insulation
Painting
Other
Components
Material
1.0000
0.0135
0.0405
0.1399
0.1081
0.2703
0.0972
0.3142
0.0676
0.0743
0.0101
Total Direct Cost Factor 2.1357
Labor
0.0472
0.0270
0.0419
0.2581
0.1757
0.0973
0.0709
0.0676
0.1182
0.0608
0.9647
Factor
Total
1.0000
0.0607
0.0675
0.1318
0.3662
0.4460
0.1945
0.3851
0.1352
0.1925
0.0709
Total
Indirect Costs
Engineering
Contractor's overhead
and profit
Shakedown
Spares
Freight
Taxes
Other
Total Indirect Cost Factor
__ - - "'"
Contingencies
Basis for factor
10% of total direct
costs
26.5% of total direct
.costs
5% of direct costs
1% of direct material
cost only
3% of direct material
cost only
3% of direct material
cost only
20% of total direct
and indirect costs
TOTAL EQUIPMENT COST MULTIPLIER
-
3.1004
Total
8-50
-------
TABLE 8-24. COMPONENT CAPITAL COST FACTORS FOR STD
FABRIC FILTER—28 m3/min (1000 acfm)
Description
Equipment, f.o.b.
manufacturer
Site erection of
equipment
Duct work
Instrumentation
Piping
Electrical work
Foundations
Structural work
Site work
Insulation
Painting
Other
Total Direct Cost Factor
Engineering
Contractor ' s overhead
and profit
Shakedown
Spares
Freight
Taxes
Other
Total Indirect Cost Facto
Contingencies
Direct Costs
Components
Material
1.0000
0.0099
0.0398
0.0130
0.0795
0.19S9
0.1074
0.3750
0.0059
0.0875
0.0124
1.9293
Labor
0.0525
0.0250
0.0382
0.1899
0.1292
0.1074
0.0870
0.0059
0.1390
0.0750
0.8491
Factor
Total
1.0000
0.0624
0. 06^3
0.0512
0.2694
0.3281
0.2148
0.4620
0.0118
0.2265
0.0874
Total
2.77S4
Indirect Costs
Basis for factor
10% of total direct
costs
26.5% of total direct
costs
5% of direct costs
1% of direct material
cost only
3% of direct material
cost only
3% of direct material
cost only
r
20% of total direct
and indirect costs
TOTAL EQUIPMENT COST MULTIPLIER
Factor
0.2778
0.7363
0.1389
0.0193
0.0579
0.0579
Total
1.2881
0.8133
4.8798
8-51
-------
TABLE 8-25. COMPONENT CAPITAL COST FACTORS FOR STD
FABRIC FILTER—283 m3/min (10,000 acfm)
Description
Equipment, f.o.b.
manufacturer
Site erection of
equipment
Duct work
Instrumentation
Piping
Electrical work
Foundations
Structural work
Site work
Insulation
Painting
Other
Total Direct Cost Factor
Direct Costs
Components
Material
1.0000
0.0068
0.0475
0.0517
0.0190
0.1057
0.0916
0.1850
0.0034
0.1500
0.0059
1.666C
Labor
0.0239
0.0493
0.0147
0.0774
0.0631
0.0916
0.0418
0.0034
0.2387
0.0358
0.6397
Factor
Total
1.0000
0.0307
0.0968
0.0664
0.0964
0.1638
0.1832
0.2268
0.0060
0.3887
0.0417
Total
2.3063
Engineering
Contractor's
and profit
Shakedown
Spares
Freight
Taxes
Other
Contingencies
erhead
Cost Factor
[• COST MULTI
Indirect Costs
Basis for factor
10% of total direct
costs
26.5% of total direct
costs
5% of direct costs
1% of direct material
cost only
3% of direct material
cost only
3% of direct material
cost only
120% of total direct
and indirect costs
PLIER
Factor
0.2306
0.6112
0.1153
0.0167
0.0500
0.0500
...I..- ' •-
Total
1.0738
0.6760
4.0561
—
8-52
-------
TABLE 8-26. COMPONENT CAPITAL COST FACTORS FOR STD
FABRIC FILTER—1139 m3/min (42,000 acfni)
Direct Costs
Description f Components
I MiSl.'^ri.'di
Egu .1 pmen t , f . o . b . I
manufacturer jj I.OOOO
Site erection of
equipment
Duct vork
Instrumentation
Piping
Electrical work
Foundations
Structural work
Site work
Insulation
Painting
Other
Total Direct Cost Factor
Engineering
Contractor ' s overhead
and profit
Shakedown
Spares
Freight
Taxes
Other
Total Indirect Cost Factor
Contingencies
0,0057
0.0974
0.0633
0.0123
0.0931
0.1160
0.1665
0.0036
0.2049
0.0054
1.7687
Labor
Factor
Total Total
.1.0000
0.0201
0.0802
0.0135
0.0325
0.0516
0.1160
0.0376
0.0036
0.3259
0.0322
0.7132
0.0258
0.1776
0.0773
0.0448
0.1447
0.2320
0.2041
0.0072
0.5300
0.0376
2.4819
Indirect Costs
Basis for factor
10% of total direct
costs
26.5% of total direct
costs
5% of direct costs
1% of direct material
cost only
3% of direct material
cost only
3% of direct material
cost only
20% of total direct
and indirect costs
TOTAL EQUIPMENT COST MULTIPLIER
Factor
0.2482
0.6577
0.1241
0.0.77
0.0531
0.0531
Total
1.1539
0.7272
4.3630
8-53.
-------
TABLE 8-27. COMPONENT CAPITAL COST FACTORS FOR STD
FABRIC FILTER—1698 m3/min (60,000 acfm)
Direct Costs
Description
Components
Material TLabor
Factor
Total
Total
Equipment, f.o.b.
manufacturer
Site erection of
equipment
Duct work
Instrumentation
Piping
Electrical work
Foundations
Structural work
Site work
Insulation
Painting
Other
_ • .
Total Direct Cost Factor 1.6S71
1.0000
0.0063
1 0.1084
1 0.0509
0.0098
0.0742
0.1030
0.1504
0.0029
0.1758
1 0.0049
0.0191
0.0913
0.0107
0.0259
0.0411
0.1030
0.0340
0.0029
0.2797
0.0291
1.0000
0.0259
0.1997
0.0616
0.0357
0.1153
0.2060
0.1844
0.0050
0.4555
0.0340
0.6368
Engineering
Contractor's overhead
and profit
Shakedown
Spares
Freight
Taxes
Other
Total Indirect Cost Factor
_ •
Contingencies
Indirect Costs
Basis for factor I Factor
10% of total direct
costs
26.5% of total direct
costs
2.3239
Total
5% of direct costs
1% of direct material
cost only
3% of direct material
cost only
3% of direct material
cost only
20% of total direct
and indirect costs
^_____ — J
TOTAL EQUIPMENT COST MULTIPLIER
8-54
-------
TABLE 8-28. COMPONENT CAPITAL COST FACTORS FOR VENTURI
SCRUBBER—8.5 mV»in (300 acfm)
Description
Equipment, f.o.b
manufacturer
Site erection of
equipment
Duct work
Instrumentation
Piping
Electrical work
Foundations
Structural work
Site work
Insulation
Painting
Other
•
Total Direct Cost Factor
Engineering
Contractor's overhead
and profit
Shakedown
Spares
Freight
Taxes
Other
Total Indirect Cost Factor
Contingencies
TOTAL EQUIPMENT
Direct Costs
Components
Material
1.000
0.008
0.030
0.111
0.095
0.225
0.045
0.193
0.007
0.007
1.721
Labor
0.029
0.020
0.035
0.235
0.145
0.045
0.043
0.007
0.037
0.596
Factor
Total
1.000
0.037
0.050
0.146
0.330
0.370
0.090
0.236
0.014
0.044
Total
2.317
Indirect Costs
Basis for factor
10% of total direct
costs '
26.5% of total direct
costs
5% of direct costs
1% of direct material
cost only
3% of direct material
cost only
3% of direct material
cost only
20% of total direct
and indirect costs
COST MULTIPLIER
Factor
0.232
0.614
0.116
0.017
0.052
0.052
Total
1.083
0.680
4.080
8-55
-------
TABLE 8-29. COMPONENT CAPITAL COST FACTORS FOR VENTURI
SCRUBBER—28.3 mVmin (1000 acfm)
Ds script ion
Equipment, f.o.b.
manufacturer
Site erection of
equipment
Duct work
Instrumentation
Piping
Electrical work
Foundations
Structural work
Site work
Insulation
painting
Other
Total Direct Cost Factor
Compone
Material
1.000
0.021
0.025
0.107
0.084
0.158
0.038
0.164
0.011
0.005
1.613
Direct Costs
nts
Labor |
* 1
0.076
0.016
0.031
0.202
0.100
0.033
0.037
0.011
0.032
0.543
Factor
Total
1.000
0.097
0.041
0.138
0.286
0.258
0.076
0.201
0.022
0.037
TOual
2.156
_J.
. i
j-
Engineering
Contractor's overhead
and profit
Shakedown
Spares
Freight
Taxes
Other
Total Indirect Cost Factor
Contingencies
Indirect Costs
Basis for factor
10% of total direct
costs
26.5% of total direct
costs
5% of direct costs
1% of direct material
cost only
3% of direct material
cost only
3% of direct material
cost only
20% of total direct
and indirect costs
__
TOTAL EQUIPMENT COST MULTIPLIER
Factor
0.216
0.571
0.108
0.016
0.048
0.048
•
Total
1.007
i ""
0.633
3.796
8-56
-------
TABLE 8-30. COMPONENT CAPITAL COST FACTORS FOR VENTDRI
SCRUBBER—283 m3/min (10,000 acfm)
Description
Equipment, f.o.b.
manufacturer
Site erection of
equipment
Duct work
Instrumentation
Piping
Electrical work
Foundations
Structural work
Site work
Insulation
Painting
Other
Total Direct Cost Factor
Engineering
Contractor ' s overhead
and profit
Shakedown
Spares
Freight *
Taxes
Other
Total Indirect Cost Factor
Contingencies
Direct Costs
Components
Material
1.000
0.019
0.039
0.048
0.045
0.160
0.051
0.182
0.012
0.006
1.562
Labor
0.066
0.034
0.014
0.110
0.092
0.051
0.041
0.012
0.035
0.455
Factor
Total
1.000
0.085
0.073
0.062
0.155
0.252
0.102
0.223
0.024
0.041
Total
2.017
Indirect Costs
Basis for factor
10% of total direct
costs
26.5% of total direct
costs
5% of direct costs
1% of direct material
cost only
3% of direct material
cost only
3% of direct material
cost only
20% of total direct
and indirect costs
TOTAL EQUIPMENT COST MULTIPLIER
Factor
0.202
0.534
0.101
0.016
0.047
0.047
Total
0.947
0.593
3.557
8- 57
-------
TABLE 8-31. COMPONENT CAPITAL COST FACTORS FOR VENTURI
SCRUBBER—1,189 m3/min (42,000 cicfm)
Description
Equipment, f.o.b.
manufacturer
Site erection of
equipment
Duct work
Instrumentation
Piping
Electrical work
Foundations
Structural work
Site work
Insulation
Painting
Other
Total Direct Cost Factor
Engineering
Contractor's overhead
and profit
Shakedown
Spares
Freight
Taxes
Other
Total Indirect Cost Factor
Contingencies
Direct Costs
Components
Material
1.000
0.005
0.027
0.014
0.024
0.145
0.029
0.104
0.007
0.003
1.358
Labor
0.038
0.023
0.004
0.036
0.077
0.029
0.024
pi 007
0.020
0.258
Factor
Total
1.000
0.043
0.050
0.018
0.060
0.222
0.058
0.128
0.014
0.023
Total
1.616
Indirect Costs
Basis for factor
10% of total direct
costs
26.5% of total direct
costs
5% of direct costs
1% of direct material
cost only
3% of direct material
cost only
3% of direct material
cost only
20% of total direct
and indirect costs
Factor
0.162
. 428
0.081
0.014
0.047
0.047
Total
0.767
0.477
2.860
8-58
-------
TABLE 8-32 . COMPONENT CAPITAL COST FACTORS FOR VENTURI
SCRUBBER—1698 ro3/min (60,000 acfm)
Description
Equipment, f.o.b.
manufacturer
Site erection of
equipment
Duct work
Instrumentation
Piping
Electrical work
Foundations
Structural work
Site work
Insulation
Painting
Other
Total Direct Cost Factor
Engineering
Contractor ' s overhead
and profit
Shakedown
Spares
Freight
Taxes
Other
Total Indirect Cost Factor
Contingencies
Direct Costs
Components
Material
1.000
0.006
0.027
0.012
0.02.7
0.130
0.026
0.095
0.005
0.003
1.331
Labor
0.032
0.023
0.004
0.035
0.069
0.026
0.021
0.005
0.018
0.233
Factor
Total
1.000
0.038
0.050
0.016
0.062
0.199
0.052
0.116
0.010
0.021
Total
—
1.564
Indirect Costs
Basis for factor
10% of total direct
costs
26.5% of total direct
costs
5% of direct costs
1% of direct material
cost only
3% of direct material
cost only
3% of direct material
cost only •
20% of total direct
and indirect costs
TOTAL EQUIPMENT COST MULTIPLIER
Factor
0.156
0.414
0.078
0.013
0.040
0.040
Total
0.741
0.461
2.766
8-5g
-------
TABLE 8-33. COMPONENT CAPITAL COST FACTORS FOR
LOW-ENERGY SCRUBBER—8.5 m3/min (300 acfm)
Description
Equipment, f.o.b.
manufacturer
Site erection of
equipment
Duct work
Instrumentation
Piping
Electrical work
Foundations
Structural work
Site work
Insulation
Painting
Other
Total Direct Cost Factor
Engineering
Contractor's overhead
and profit
Shakedown
Spares
Freight
Taxes
Other
Total Indirect Cost Factor
Contingencies
Direct Costs
Components
Material
1.000
0.008
0.027
0.100
0.085
0.202
0.040
0.174
0.006
0.006
1.648
Labor
0.026
0.018
0.031
0.211
0.130
0.040
0.039
0.006
0.034
0.535
Factor
Total
1.000
0.034
0.045
0.131
0.296
0.332
0.08Q
0..213
0.012
0.040
Total
2.183
, .,._
Indirect Costs
Basis for factor
10% of total direct
costs
26.5% of total direct
costs
5% of direct costs
1% of direct material
cost only
3% of direct material
cost only
3% of direct material
cost only
20% of total direct
and indirect costs
TOTAL EQUIPMENT COST MULTIPLIER
Factor
0.218
0.578
0.109
0.016
0.049
0.049
Total
1.019
0.640
3.842
8- 60
-------
TABLE 8-34. COMPONENT CAPITAL COST FACTORS FOR
LOW-ENERGY SCRUBBER—28.3 m3/min (1QOO acfm)
Description
Equipment, f.o.b.
manufacturer
Site erection of
equipment
Duct work
Ins trumen ta t ion
Piping
Electrical work
Foundations .
Structural work
Site work
Insulation
Painting
Other
Total Direct Cost Factor
Engineering
Contractor's overhead
and profit
Shakedown
Spares
Freight
Taxes
Other
Total Indirect Cost Factor
Contingencies
Direct Costs
Components
Material
1.000
0,014
0.035
0.096
0.083
0.206
0.039
0.168
0.006
0.006
1.653
Labor
0.051
0.022
0.030
0.204
0.132
0.039
0.038
0.006
0.033
0.555
Factor
Total
1.000
0.065
0.057
0.126
0.287
0.338
0.078
0.206
0.012
0.039
Total
2.208
Indirect Costs
Basis for factor
10% of total direct
costs
26.5% of total direct
costs
5% of direct costs
1% of direct material
cost only
3% of direct material
cost only
3% of direct material
cost only
20% of total direct
and indirect costs
TOTAL EQUIPMENT COST MULTIPLIER
Factor
0.221
0.585
0.110
0.017
0.050
0.050
Total
-
1.033
0.648
3.889
8-61
-------
TABLE 8-35. COMPONENT CAPITAL COST FACTORS FOR
LOW-ENERGY SCRUBBER—283 m3/min (10,000 acfm)
Description
Equipment, f.o.b.
manufacturer
Site erection of
equipment
Duct work
Instrumentation
Piping
Electrical work
Foundations
Structural work
Site work
Insulation
Painting
Other
Total Direct Cost Factor
Engineering
Contractor's overhead
and profit
Shakedown
Spares
Freight
Taxes
Other
Total Indirect Cost Factor
Contingencies
Direct Costs
Components
Material
1.000
0.015
0.061
0.074
0.047
0.153
0.033
0.169
0.004
0.006
1.562
Labor
0.038
0.052
0.021
0.129
0.098
0.033
0.038
0.004
0.033
0.446
Factor
Total
1.000
0.053
0.113
0.095
0.176
0.251
0.066
0.207
0.008
0.039
Total
2.008
Indirect Costs
Basis for factor
10% of total direct
costs
26.5% of total direct
costs
5% of direct costs
1% of direct material
cost only
3% of direct material
cost only
3% of direct material
cost only
20% of total direct
and indirect costs
Factor
0.201
Ot^ T5
. 3 J £.
0.100
0.016
0.047
0.047
Total
0.943
0.590
3 541
8- 62
-------
TABLE 8-36 . COMPONENT CAPITAL COST FACTORS FOR
LOW-ENERGY SCRUBBER—1,189 m3/min (42,000 acfm)
Description
Equipment, f.o.b.
manufacturer
Site erection of
equipment
Duct work
Instrumentation
Piping
Electrical work
Foundations
Structural work
Site work
Insulation
Painting
Other
Total Direct Cost Factor
Engineering
Contractor's overhead
and profit
Shakedown
Spares
Freight
Taxes
Other
Total Indirect Cost Factor
Contingencies
Direct Costs
Components
Material
1.000
0.006
0.061
0.030
0.019
0.111
0.027
0.139
0.002
0.004
" 1.399
Labor
0.021
0.050
0.009-*
0.053
0.061
0.027
0.031
0.002
0.027
0.281
Factor
Total
1.000
0.027
0.111
0.039
0.072
0.172
0.054
0.170
0.004
0.031
-
Indirect Costs
Basis for factor
10% of total direct
costs
26.5% of total direct
costs
5% of direct costs
1% of direct material
cost only
3% of direct material
cost only
3% of direct material
cost only
20% of total direct
and indirect costs
TOTAL EQUIPMENT COST MULTIPLIER
Factor
0.168
0.445
0.084
0.014
0.042
0.042
Total
' i:680r
Total
0.795
0.495
2.970
8- 63
-------
TABLE 8-37. COMPONENT CAPITAL COST FACTORS FOR
LOW-ENERGY SCRUBBER—1698 m3/min (60,000 acfm)
Description
Equipment, f.o.b.
manufacturer
Site erection of
equipment
Duct work
Instrumentation
Piping
Electrical work
Foundations
Structural work
Site work
Insulation
Painting
Other
Total Direct Cost Factor
Direct Costs
Components
Material
1.000
0.005
0.056
0.025
0.034
0.125
0.022
0.128
0.002
0.004
Labor
1.401
0.018
0.046
0.007
0.060
0.068
0.023
0.029
0.001
0.022
0.274
Factor
Total
1.000
0.023
0.102
0.032
0.094
0.193
0.045
0.157
0.003
0.026
Indirect Costs
Basis for factor
Engineering
Contractor's overhead
and profit
Shakedown
Spares
Freight
Taxes
Other
Total Indirect Cost Factor
10% of total direct
costs
26.5% of total direct
costs
5% of direct costs
1% of direct material
cost only
3% of direct material
cost only
3% of direct material
cost only
Contingencies
20% of total direct
and indirect costs
Total
TOTAL EQUIPMENT COST MULTIPLIER
8-64
-------
Figure 8-4 presents a comparison of the equipment cost multipliers for each
control system at various exhaust gas rates.
Total control system costs (i.e.. capital and annualized operating
costs) are shown in Tables 8-38 through 8_41. Costs for ^ caprolactam
industry are based on t*o pairs of dryers, one pair having a capacity of 22.7
Mg/h (25 tons/h), and the other pair having a capacity of 27.2 Hg/h (30 tons/h)
Each dryer requires a separate control system. Costs for the prime industry
and the coke oven byproduct industry are also based on the installation of one
control system per dryer, but a plant requires only one dryer. Dryer capac-
ities are assumed to be 13.6 Mg/h (15 tons/h) for the prime industry and 2.7
Mg/h (3 tons/h) for the coke oven byproduct industry. Where required all
costs are adjusted to mid-1978 dollars by use of the Chemical Engineering Cost
Index.
A comparison of the investment (total capital) costs for each of the
alternative control systems is given in Figure 8-5.
The captured particulate is reprocessed to recover ammonium sul.fate,
which has value as a source of nitrogen fertilizer. The value of the recov-
ered material offsets some of the direct operating costs and capital charges
These recovery credits are particularly significant in the caprolactam byproduct
industry, which is now the single largest manufacturing source of ammonium
sulfate.
Annualized cost of operation of a control device is a function of the
number of hours the dryer is operated per year. Dryers are assumed to operate
at the following rates: 8400 h/yr for the caprolactam byproduct industry,
5400 h/yr for the prime production industry, and 7400 h/yr for the coke oven
byproduct industry.
8.2.1.2 Product Dryer Costs-
Table 8-42 shows the costs of a fluidized-bed dryer and of a rotary drum
dryer. Each dryer has a production capacity of 23 Mg/h (25 tons/h) and is
indirectly heated by steam-heated air. Although a fluidized-bed dryer is
sometimes thought to be less expensive to install and operate, this comparison
does not take into account the added cost required for a cooling system. The
capital cost of a fluidized-bed dryer With a cooling system is slightly
~. 8-65
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8-72
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more than that of a rotary drum dryer. Most of the operating costs and
characteristics of the two dryers are comparable but, because-of a higher gas
flow rate and pressure drop, the horsepower requirements for a fluldlzed-bed
dryer are higher than for a rotary dryer. The fluidized-bed dryer, however,
has the advantage of sweeping fines out of the bed; it in effect classifies'
the product and thereby improves product quality.
8.2.1.3 Incremental Cost of Control Systems-
Control systems designed to meet the emission limitations of a State
Implementation Plan (SIP) are generally less costly than those designed to
meet the more stringent limitations of the Option II. (Typical SIP's
for ammonium sulfate facilities apply relatively lenient process weight
regulations to particulate emissions). The low-energy scrubber is the
baseline control device needed to meet SIP regulations. Incremental
cost, therefore, is considered here to be the difference between the
cost of a fabric filter or venturi scrubber and the cost of a low-
energy scrubber.
Incremental capital and annualized control costs for each of the major
segments of the ammonium sulfate industry are presented in Tables 8-43 through
8-46. Generally, the fabric filter and venturi scrubber cost more than a low-
energy scrubber. The annualized cost of a venturi scrubber at low exhaust gas
rates, however, is slightly less than the annualized cost of a low-energy
scrubber because of the high market value of the ammonium sulfate recovered.
Figures 8-6 through 8-8 show cost curves for the incremental costs of control
equipment in each segment of the ammonium sulfate industry.
8.2.1.4 Cost-Effectiveness of Control Systems--
Tables 8-47 through 8-50 compare the cost-effectiveness of fabric filters
and venturi scrubbers with that of low-energy wet scrubbers in the same appli-
cations. Each table shows the difference in the annualized costs of removing
a standard amount of pollutant with a fabric filter or venturi scrubber and
removing the same amount of pollutant with a low-energy scrubber. These
costs, which are given for each segment of the industry, take into account the
direct operating costs, capital charges, and credits for dust recovery.
Figures 8-9 through 8-11 indicate the cost-effectiveness of each control
system at various dryer exhaust gas rates.
3- 73
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TABLE 8-49. COST-EFFECTIVENESS OF ADDITIONAL PARTICULATE CONTROL
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8-87
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8.2.2 Modified/Reconstructed Facilities
8.2.2.1 Capital and Annualized Operating Costs of Control Systems--
Because it requires special design modifications, installing a control
system in an existing plant that has been modified, reconstructed, or expanded
may be more costly than in a new facility with the same exhaust gas rate.
Estimating the additional installation cost or retrofit penalty is difficult
because of such plant-specific factors as availability of space, need for
additional ducting, and engineering requirements.
Configuration of equipment in a plant determines the location of the
control system. A retrofit installation may require long ducting runs from
ground level to the control device, stack, and reprocessing equipment. Costs
may increase considerably if the control equipment must be placed on the roof
of a process building, thus requiring the addition of structural steel support.
It is estimated that rooftop installation can double the structural costs. In
addition, it is likely that premium wage rates in accordance with governmental
regulations and/or union agreements will have to be paid for installation
labor. Also, space restrictions and plant configuration problems may increase
contractor's fees and engineering fees, estimated for a new facility at 15
percent and 10 percent of total costs, respectively. These charges may be 20
percent and 15 percent, respectively, for a retrofit installation. These fees
also vary with the difficulty of the job, the risks involved, and prevailing
I
economic conditions.
The annualized costs of control systems for modified/reconstructed facili-
ties are calculated similarly to those for new facilities; however, the com-
ponents of capital costs for modified plants (see Table 8-16) are approximately
20 percent higher than those for new facilities.
8.3 OTHER COST CONSIDERATIONS \
This section deals with the cost of complying with various Federal regu-
lations. The regulations concern water quality, prevention of significant
deterioration (PSD) of air quality, solid waste disposal, and the hazards in
working with ammonia ano sulfuric acid determined by the Occupational Safety
and Health Administration (OSHA).
8-88
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8.3.1 Costs of Compliance with Water Quality Regulations
Facilities within the prime segment of the ammonium sulfate industry that
discharge into surface waters are subject to the effluent limitations specified
in National Pollutant Discharge Elimination System (NPDES) permits. Direct
dischargers are required to comply with the effluent limitations based on best
practicable technology (BPT) through July 1977 and best available technology
(BAT) economically achievable by mid-1984. The current standard for both BPT
and BAT prohibits the discharge of any process waste water pollutants into
navigable waters. Prime facilities already discharging into publicly owned
treatment works must comply with Federal pretreatment standards.
New facilities discharging ammonium sulfate into surface waters are
subject to NSPS, which are identical to BAT limitations. New plants discharg-
ing into publicly owned treatment facilities must meet Federal pretreatment
standards more stringent than those for existing sources.
No known prime and caprolactam industries discharge effluents into
sewage systems. The coke oven industry may discharge into sewage systems.36
8.3.2 Costs of Compliance with PSD Regulations
The 1977 amendments to the Clean Air Act include extensive provisions to
prevent significant deterioration of air quality in regions where pollutant
levels are already lower than those specified in ambient standards. The PSD
regulations apply only to major stationary sources and specify the amount or
"increment" of deterioration that the EPA will allow for a particular pol-
lutant. The AS industry is subject to PSD requirements as it is included in
the 28 listed categories of sources that emit or have the potential to emit 9i Mg
(100 tons) per year or more of any pollutant. These include iron and steel mill
plants, coke oven batteries, and chemical process plants. In addition, any
source with the potential to emit 227 Mg (250 tons) per year is subject to
the regulations.
All such major sources are required to install the best available control
technology (BACT) for each pollutant exceeding the limit. In addition, the
owner or operator of a proposed source or modification is required to demon-
strate that allowable emission increases from the source will not cause a
8-89
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violation of the National Ambient Air Quality Standards. To comply 1th these
required and obtain a construction permit, the owner or operator of a
orooosed new source must agree to conduct ambient air quainy momtonng to
e' tent the EPA determines necessary. The owner or operator of the source
*. required to sub.it information regarding the design and layout «*»•
,nn »n analysis of likely impairment to visibility, soils, and vegeta-
:°r
from
o .
operation of I singambient air monitor to more than $100,000 for e*tens,ve
modeling and testing.
833
Solid Waste Disposal Regulations.
and other solid wastes must be disposed of in a land-
—
waste is generated.
034 Cpj|tsof_CoInp^^
O««3.H "ual>J—— —J-— ; ne-nn \ n^^,,iT _a+--i rvn c
^T^^Ho-n (OSHA) KeaaMHliS
The cost of compliance with OSHA regulations for the prime
,
promulgated by OSHA.
8.-90
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The cost of complying with OSHA regulations depends on such variables as
the type and configuration of process equipment and special design considera-
tions. Many OSHA requirements for the storage and handling of anmonia and
sulfuric acid are already commonly practiced in the industry. Consequently,
the additional costs incurred for compliance with OSHA regulations can only be
broadly estimated to be in the order of magnitude of several thousand dollars.
The costs incurred for compliance are small in relation to total plant costs.
8-91
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8.4. Economic Impact Analysis
8.4.0. Introduction
The economic impact analysis is based on the synthetic,
coke oven by-product and caprolactam by-product model plants
presented in section 6,1. The analysis focuses upon worst-case
model plants, that is, those plants likely to be most adversely
affected by the regulatory options considered below. All other
types of plants will be less adversely affected by the regulatory
options than the worst-case facilities, and, as the estimated
regulatory economic impacts for worst-case plants are very small,
the economic impacts on other plants are likely to be negligible.
Consequently, the additional information generated by a more
extensive and resource intensive analysis would provide no useful
additional information. Price and rate of return impacts asso-
ciated with the regulatory options are calculated for the
worst-case model plants and form the basis for the assessment of
industry wide economic impacts. From an economic perspective,
plants facing the highest incremental costs of complying with a
regulation are the worst case plants, that is, the AS plants with
the highest exhaust rates. Plants with smaller dryer exhaust
rates encounter smaller incremental costs of control and will be
less adversely affected by a regulator alternative.
8.4.1. Control Options
Two control options are being considered by EPA:
Option 1. New modified and reconstructed plants must comply with
emissions limits typical of existing SIP regulations.
This regulatory option could be achieved by the installation
of low energy scrubbers on the dryers. Under this regulation, no
plant would incur any incremental costs* and consequently no
economic impacts would result from its implementation.
Incremental costs, in this situation, are those additional costs
a firm incurs in meeting Option II that it would not incur in
meeting Option I, existing SIP emission limits.
8-92
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°Ption n-- New> modified and reconstructed plants must comply
with an emissions limits of 0.150 kilograms per megagram of AS
production.
Two control devices can be used by each of the three major
types of AS plants to attain compliance with Option II: (1)
medium energy venturi scrubbers, and (2) fabric filters. Plants
utilizing either of these control technologies will incur incre-
mental costs; that is, costs that would not be encountered by
complying with existing SIP's. Consequently, economic impacts
would result from the implementation of regulatory Option II.
8.4.2. Economic Methodology
8.4.2.1. Regulatory Scenarios
Economic impacts are estimated only for regulatory
Option II as no incremental costs would be incurred by firms
complying with regulatory Option I. However, as was noted above,
affected facilities may comply with regulatory Option II by
installing venturi scrubbers or fabric filters. Venturi scrubbers
and fabric filter baghouses may be constructed of fiberglass
reinforced plastic (FRP), stainless steel, lined carbon steel,
or carbon steel (STD). (FRP has the highest acidic corrosion
resistance and STD has the least resistance.) Economic impacts,
however, are estimated only for FRP venturi scrubbers, FPP fabric
filters, and STD fabric filters. Economic impacts are estimated
under two alternative assumptions about firm pricing behavior:
(1) full cost absorption and (2) full cost pricing. Combining
the two control technologies with the two alternative pricing
models yields six regulatory scenarios:
8-93
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Control Technology
Pricing Policy
Scenario 1
Scenario 2
Scenario 3
Scenario 4
Scenario 5
Scenario 6
Venturi Scrubbers Full Cost Absorption
Venturi Scrubbers
Full Cost Pricing
STD Fabric Filter Full Cost Absorption
STD Fabric Filter Full Cost Pricing
FRP Fabric Filter Full Cost Absorption
FRP Fabric Filter
Full Cost Pricing
i
Under full cost absorption an affected firm bears the full
incremental costs of environmental controls, accepting a lower
rate of return on its capital investment. Under full cost
pricing the firm adjusts product prices so as to maintain its
current after-tax rate of return on capital investment.
The alternative assumptions about firm pricing behavior are
associated with different market conditions in the affected
industry. In both cases, firms are assumed to have no monopsony
power in resource markets. Thus, they cannot pass back cost
increases to resource suppliers. However, in the cost absorption
case the domestic industry as a whole is assumed to be a price
taker, unable to affect the market price of its product either
because of the existence of close product substitutes, or because
of strong international competition in domestic and foreign
markets. Full cost pricing will take place if the industry
S-94
-------
produces a commodity for which no substitutes exist or if it is a
constant cost industry.*
In fact, the U.S. ammonium sulfate industry faces strong
competition from substitute products such as urea, airaonium
nitrate and anhydrous ammonia in domestic markets. In overseas
markets it faces competitition from foreign producers of AS.
Consequently, the full cost absorption scenarios evaluated below
provide more representative estimates of the economic impacts
resulting from implementing regulatory Option II than do the full
cost pricing scenarios. Full cost pricing scenarios are only
considered in order to provide a maximum estimate of the possible
inflationary consequences of such a regulation.
8.4.2.2. Economic Conditions
The impacts associated with each of the six regulatory
scenarios are calculated under two different sets of economic
.conditions.. Both sets of conditions assume that all control
equipment has a twenty-year life; the price of AS received by
producers is $66.14 per metric ton and the tax rate is 52
percent. However, under the first set of conditions, firms are
assumed to have a target rate of return on investment of 6
percent. Under the second set, the target rate of return is
assumed to be 15 percent. None of the firms for which financial
data was available received an after tax return on equity of less
than 11.3 percent or more than 14.29 percent in 1977 (see table
8-11). Hence the alternative assumptions about the target rate
of return for affected facilities cover the range of actual rates
of return on equity experienced by firms producing AS.
A lower bound of 6 percent was selected for the interest
rate variable to reflect the general economic conditions facing
In a constant-cost industry, as industry output increases unit
costs remain constant as long as resource prices, labor produc-
tivity and the industry technology remain the same.
8-95
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the iron and steel industry, of which coke oven by-products
plants are a part. The iron and steel industry experienced an
average after-tax rate of return on equity of only 7.4 percent
between 1968 and 1977 and in four of those years the after-tax
rate of return was less than 6 percent.
8.4.2.3. Estimation of Regulatory PHre Impacts Under Full Cost
Pricing
Under full cost pricing, the firm is assumed to respond
to cost increases by adjusting product price to maintain a target
rate of return on investment. The required price change (AP) may
be calculated using the following equation:
A TOC + r x AK/(l-t)
AP »•
Q
where AP » required product price change
ATOC = annual total operating costs of the control
equi pment
AK = total acquisition and installation costs of the
control equipment
Q » annual plant output
r = target rate of return
t = tax rate
Note that total annual operating costs (ATOC) include an
allowance for depreciation of the equipment in addition to
regular maintenance and operating costs. Annual depreciation is
estimated to be 5 percent of the acquisition and installation
costs of the control equipment.*
*The depreciation estimate is based on the assumption of straight
line depreciation of the equipment over its twenty year life.
plants, capital expenditures and employment in the AS industry.
In addition, interindustry and macroeconomic impacts are dis-
cussed.
8-96
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8'4*2'4* Estimation of Rate of Return Impacts Under Full Cost
Absorption
Under full cost absorption, an Increase in plant costs
of production results in a lower rate of return on investment for
the firm as it cannot pass cost increases on to consumers in the
form of higher product prices. The impact on the plant's rate of
return on investment is given by the following equation:
(t-1) AJOC - rAK
Ar = ....
K + A K
where Ar denotes the change in the rate of return in investment
and K denotes the pre-regulation level of capital investment
(measured in dollars). Note that K represents the pre-regulation
level of capital investment in the affected facility.
8.4.2.5. Other Economic Impacts
The price and rate of return impacts estimated by the
above techniques are used to make a quantitative assessment of
the probable impact of regulatory Option II on industry growth,
new plant openings, reconstructions and modifications of existing
facilities, annualized costs of control and investment levels.
These data are used to assess the extent of interindustry and
macroeconomic impacts associated with Option II.
8.4.2.6. Data
In addition to information about target rates of return
and the tax rate, the estimation of price and rate of return
impacts requires data on the following variables for each
affected facility: (1) total acquisition and installation costs
of the control equipment (AK), (2) total annual operating costs
of the control equipment (ATOC), and (3) the pre-regulation
capital stock (K). Data on AK and ATOC were obtained from
section 8.2. Estimates of pre-regulation capital investment for
the synthetic, AS coke oven by-product and caprolactam model
plants are presented in table 8-51.
8-97
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Table 8-51 Capital Investment in the Ammonium Sulfate Industry
(December 1978)
•
Process
Synthetic
Coke Oven
Caprol actam
Model Plant
Capacity
(Mg)
73,483
19,958
381,022
Pre-Regulation
Capital
($io6)
1.526
0.647
21.756
SOURCE: Research Triangle Institute
8-98
-------
The estimates of pre-regulation capital investment levels
were obtained in the following ways:
Synthetic Product. Data on the value of capital equipment
tied up in a synthetic AS plant with a capacity of 63.5 Gg in
1973 are presented in David et.al.34 These data were updated to
December 1978 using the Bureau of Labor Statistics (BLS)
machinery and equipment price index.35 This figure was then
multiplied by a factor of 1.157 (=73.483Gy/63.5Gg) to obtain an
estimate of the level of capital investment required for a
synthetic AS plant with a capacity of 73.483Gg.
Coke Oven By-product Plant. A capital output coefficient
for the iron and steel industry was calculated by dividing total
industry assets by the total value of industry shipments for
1977.36 This coefficient was updated to December 1978 using the
BLS machinery and equipment and iron and steel price indices.
The capital-output coefficient was then multiplied by the value
of the shipments of the plant, estimated to be $1.32 million, to
obtain an estimate of total capital investment for the coke oven
by-product model plant.*
Caprolactam By-Product. A capital-output coefficient for
the organic chemical industry was obtained by dividing 1976 total
industry assets by total value of shipments for S.I.C. code
industry 2869, Industrial Organic Chemicals.37 The capital-
output ratio was updated to December 1978 using the BLS price
indices for machinery and equipment and industrial chemicals.
The updated capital output ratio was then multiplied by the value
of AS shipments from the model plant, estimated to be $25.2
million, to obtain the estimate of total capital investment for
the caprolactam model plant.
Plant value of shipments is obtained by multiplying plant
capacity by product price, where the price of AS is assumed to
be $66.14 per metric to-
8-99
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8.4.3. Economic Impacts
8.4.3.1. Summary
Regulatory options I and II are likely to have minimal
impacts on the ammonium sulfate industry itself. New plant
construction and modifications or reconstructions of existing
facilities that would have taken place in the absence of an NSPS
will almost certainly still be carred out.. Further, price, rate
or return, investment and employment impacts will probably be
negligible. In addition, it should be noted that the AS industry
may be beneficially affected by forthcoming NSPS's for urea and
ammonium nitrate.
8.4.3.2. Rate of Return Impacts
Estimates of the impacts on model plant ROI's of
regulatory Option II are presented in table 8-52. These results
were calculated on the assumption that firms absorb all the
control costs and do not increase product prices. For synthetic
and coke oven by-product plants, the impacts associated with
complying with regulatory Option II are smallest when Venturi
scrubbers are installed. For caprolactam plants, the impacts are
smallest when compliance is achieved by installing STD fabric
filbers. However, based on operating experience and nearly equal
overall costs, it is most realistic that FRP venturi scrubbers
will be installed to meet a stringent standard.* 38' Plants
*Capital costs of FRP venturi scrubbers are less than those of
STD fabric filters and annualized cost of FRP Venturis are only
2 4 percent qreater. Venturi scrubbers are also much more
compatible and complimentary with the AS process. AS feed streams
are used as a scrubbing liquor and are easily recycled to the
process without addition of excess water. The dry collected AS
would require reslurry prior to being recycled to the process.
Dry collection is also suseptible to condensation problems and
STD fabric filters, due to corrosion rate, have a much shorter
expected life than the FRP constructed control devices. (See
table 8-38 and Chapters 3 and 4)
8-100
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Table 8-52 Impact on Model Plant Rates of Return of Regulatory Options under
Full Cost Absorption
Model
Plant
Synthetic
Coke Oven By-Product
Caprolactam By-Product
Change in Rate of Return (oercentaae ooints^
Venturi Scrubbers
(FRP)
(r*=6%)
-0.68
-0.37
-0.29
(r=15%)
-1.05
-0.65
-0.40
Fabric Filters
(STD )
(r=6%)
-0.62
-0.51
-0.16
(r=15%)
-1.33
-1.25
-0.35
Fabric Filters
(FRP)
(r=6%)
-2.93
-1.39
-0.75
(r=15%)
-6.36
-3.13
-1.60
r denotes the initial rate of return
Source: Research Triangle Institute.
8-101
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earning a low initial ROI (6 percent) will experience decreases
in their ROI's of between 0.29 (for caprolactam) and 0.68 (for
synthetic) percentage points. These are extremely small impacts
and are unlikely to deter firms from carrying out their invest-
ment plans. If firms earn a higher initial ROI (15 percent) the
percentage point impacts will be slightly larger, with decreases
ranging from of 0.40 (caprolactam) to 1.05 (synthetic). However,
these impacts are still small, and firms experiencing relatively
high initial ROI's are also unlikely to alter investment plans in
the face of such changes. Further note that, the smallest ROI
impacts occur in the caprolactam sector where all future industry
growth is likely to be concentrated.
•
8.4.3.3. Price Impacts
The potential price impacts associated with regulatory
Option II, calculated under the assumption of full cost pricing,
are presented in table 8-53. Price impacts vary directly with
the level of the target ROI assumed for each plant. However, the
price impacts of regulatory Option II are smallest for coke
synthetic and coke over by-product plants if they install venturi
scrubbers instead of fabric filters. Again, the smallest impacts
are associated with the cheapest control technologies. Plants
with a relatively low target ROI (6 percent.) under full cost
pricing will increase product prices by between 0.52 percent
(caprolactam by-product) and 0.45 percent (synthetic). Plants
with relatively high target ROI's (15 percent) will attempt to
increase product prices by between 0.71 percent (caprolactam by-
product) and 0.69 percent (synthetic). The above price increases
are relatively small and if passed through by AS users to consumers
would result in a negligible increase in the general rate of
inflation. Such price increases, if implemented across the AS
industry, might reduce AS consumption by between 0.99 and
8-102
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Table 8-53 Impact on Product Price of Regulatory Options
under Full-Cost Pricing
Model
Plant
Synthetic
Coke Oven By-Product
Caprolactam By-Product
Percentage Change in Product Price
Venturi Scrubbers
CFRP)
(r*=6%)
0.45
0.38
0.52
(r-15%)
0.69
0.66
0.71
Fabric Filters
(STD)
(r=6%)
0.40
0.53
0.29
(r-15%)
0.87
1.27
0.62
Fabric Filters
(FRP)
(r=6%)
1.92
1.41
1.35
(r=15%)
4.16
3.17
2.87
r denotes the target rate of return on investment.
Source: Research Triangle Institute.
8-103
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2 07 percent-below the 1985 levels.* Even if such consumption
decreases occurred, there would be no-significant. Impacts on..the
need -for additional AS facilities as the construction of
caprolactam by-product facilties (the sector in which growth will
occur) is determined by growth in the demand for caprolactam
rather than for AS. In fact, as was noted above, AS producers
are more likely to absorb cost increases than to raise prices
especially when the cost increases are small. Since the costs of
regulatory Option II are very small (see section 8.4.5.6), actual
price impacts are likely to be negligible. Consequently, output
effects are also likely to be negligible.
8.4.3.4. Employment Impacts
Regulatory Option II is unlikely to have a measurable
impact on employment. The additional labor required for operat-
ing the control devices required under Option II is less than
one-tenth of a man year, and no more than seven control devices
are likely to be installed during the five-year period following
promulgation. As AS output is likely to be unaffected by the
regulation, no employment effects will result from adjustments to
industry production levels.
8.4.3.5. Investment Impacts
Data on the investment impacts associated with regula-
tory Option II are presented in table 8-54. Regulatory"Option II
is likely to have no impacts on either the construction of new
facilities or the modification or reconstruction of existing
*These estimates, based on the assumption that
venturi scrubbers, are obtained by multiplying
firms install
the smal1est
own-price elasticity of demand estimate (2.60) presented in
section 8.1.7 by the smallest estimated potential price increase
(0.38 percent) and the largest own price elasticity of demand
(2.78) presented in section 8.1.7. by the largest estimated
potential price increase (0.71 percent).
8-104
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Table 8-54 Investment Impacts
Synthetic
Caprolactam By-Product
Coke Oven By-Product
TOTAL
Affected
Plants
2
3
4
9
Incremental
Plant Costs of
Control
(106 dollars)
0.06.1
0,252
0.020
-
Incremental
Sector Costs of
Control
(106 dollars)
0.122
0.756
0.080
0.958
SOURCE: Research Triangle Institute
8-105
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plants. Under baseline projections, three caprolactam plants
will be required to install control devices. It is probable that
each of these plants will choose to install (FRP) medium energy
venturi scrubbers. The incremental capital cost of installing
each control unit (assuming maximum gas flow rates) is $252,000.
Thus, the total incremental capital cost of controls for the
caprolactam sector will be 0.756 million. Four coke oven by-
product manufacturers are also likely to install control equip-
ment over the five year promulgation period. They are likely to
install venturi scrubbers because, for coke oven plants, these
devices are cheaper than fabric filters. The maximum incremental
cost of each such scrubber for a model coke oven by-product plant
i • i
is $20,000. Thus, the total incremental cost of controls for the
coke oven by-product sector over the five year promulgation period
will be $30,000. Two existing synthetic plants may also have to
install controls. They are likely to install venturi scrubbers,
because for coke oven plants, these devices are cheaper than
fabric filters. The maximum incremental cost of each such
scrubber for a model synthetic plant is $61,000. Thus, total
incremental capital costs of controls for the synthetic sector
will be $122,000. The maximum of the regulation total capital
costs for the entire industry will, therefore, be $0.958 million.
These costs are very small relative to the historic patterns of
capital investment in the affected industries. Further, they
represent less than one hundreth of one percent of the total value
of projected AS output for 1985*. The industry is therefore un-
likely to face problems in financing these additional capital
expenditures.
*AS output is projected to be 677 Gg in 1985 and, for this
calculation, was valued at $66.14 per metric ton.
8-106
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8.4.3.6. Total Annualized Costs of Control
Total incremental annualized costs of control are
presented in table 8-55 and are based on data presented in
section 8.2. A capital recovery factor of 0.16, based on the
assumption of a 15 percent rate of interest and a twenty year
life for the control equipment, was used to calculate annua'lized
capital costs. Coke oven by-product and synthetic AS plants are
assumed to install venturi scrubbers capable of dealing with the
highest gas flow rates considered in section 8.2. Caprolactam
plants are also assumed to install FRP venturi scrubbers. By
the fifth year after promulgation, under Option II total industry
annualized costs of control will be $430,200. The industry-
wide price increase required to generate revenues of an equivelant
amount would be miniscule, less than 0.01 percent in 1985.
8.4.3.7. Interindustry Impacts
Interindustry impacts will be negligible if control
cost increases are absorbed by AS producers. If they are passed
through to AS users in the form of higher prices then demand for
other nitrogenous fertilizers may increase. However, because AS
has such a small share of the total nitrogen fertilizer market,
the increase in the demand for each of the other nitrogenous
fertilizers would be quite small. In addition, under full cost
pricing farmers would be faced with higher costs of production
for agricultural output. However, the share of AS fertilizer
costs in total agricultural production costs is very small (less
than one percent). Consequently, any change in the cost of
producing AS would have a minimal impact on costs of production
in agriculture and on food prices.
8-107
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8-108
-------
8*5' Soclo-Econonric and Inflationary Impacts
The socio-economic impacts of regulatory Option II will be
very small.
(1) AnnuaTlzed Costs. In the fifth year following promulga-
tion of regulatory Option II, annualized costs of compliance will
be $0.4775 mil lion, well below the regulatory analysis criterion
of $100 million.
(2) Price Impacts. An industry wide price increase of less
than one-hundreth of one percent is all that would be required to
provide revenues to meet these costs. In addition, the most
adversely affected plants would only have to increase product
price by 0.71 percent. Potential price increases are therefore
also well below the 5 percent criterion for a regulatory
analysis.
(3) P^and for Scarce Materials. It is conceivable that an
ammonium sulfate regulation could increase demand for urea, one
of the materials specified in the Federal Register as of special
importance. However, any possible increase in the demand for
urea which is likely to be considerably less than one percent,
well below the 3 percent criterion outlined in the Federal
Register.40
8-109
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REFERENCES
1. Milton L. David, C. Clyde Jones and J. H. Malk; "Economic
Analysis of Proposed Effluent Guidelines for the Fertilizer
SfacLring Industry", EPA Report 230-1-74-035, 1974; p.
II-9.
2 Telephone Conversation between Janis Moss of RTI and R.
Johnson of J. R. Simplot, April 6, 1979.
3. David et. al., p. IJ-9.
4. Stanford Research Information. Directory of Chenncal
ducers, 1978.
5 US Dept. of the Interior, Bureau of Mines: "Coke
Produces in the U.S. in 1967," Mineral Industry, 1969,
Table 1-
t
6 US Dept of Commerce, Bureau of the Census: Current
Industrial Reports-series M28B; various issues.
i
I
7. David et. al., P- II.
8. Telephone conversation between Janis Moss of RTI and Jerry1
Cornell of U.S. Steel Corporation;, April 5, 1979.
9. U.S. Dept. of Interior, Bureau of Mines/Minerals Yearbook,
1974. \
in ii <; Dent of Energy, Energy Information Administration,
y^s^yiu^
1978.
11 Telephone conversation between Janis Moss of RTI and Jerry
Cornell, U.S. Steel Corporation, April 5, 1979.
12. Chemical Engineering, July 3, 1978, p.25.
13. David et. al., p. H-9.
14. Louis T. Colaianni, Coke-Oven Offgas Yields Fuel, chemical
by-products; Chemical Engineering, March 29, 1976, pp.
82-83.
15. Source: Chemical Economics Handbook,
16 Conversation between Vincent H. Smith of RTI and Jack
Ambles of the Bureau of the Census, April 9, 1979.
8-110
-------
17. Chemical Economics Handbook. Stanford Research Institute
International, Menlo Park, California., December 1976,
p. 756.600 1C.
18. Telephone conversation between Jam's Moss of RTI and David
Crone of Badische Corp., April 5, 1979.
19. Telephone conversation between Jam's Moss of RTI and John
Lucas of Allied Chemical Corporation, April 7, 1979.
20. Telephone conversation between Jam's Moss of RTI and J. G.
Broughton of Nipro, Inc., April 6, 1979.
21. U.S. International Trade Commission; Synthetic Organic
Chemicals; U.S. Production and Sales, 1977.
22. Directory of Chemical Producers.
23. U.S. Department of Agriculture, 1979 Fertilizer Situation.
24. Electrical Weekly, April 2, 1974; pp. 7-8..
25. David et al. p. 1-11.
26. Stanford Research Institute. Chemical Economic Handbook,
1976.
27. U. S. Department of Agriculture, Statistical Reporting Ser-
vice, Crop Reporting Board. Consumption of Commercial
Fertilizer jm the United States Year Ended June 30. 1978.
28. Op Cit. Stanford Research International.
29. National Association of Corrosion Engineers. Corrosive Data
Survey, 5th Edition. 1974.
30. David, M.L., C.C. Jones, and J.M. Malk. Economic Analysis of
Proposed Effluent Guidelines for the Fertilizer Manufacturing
Industry (Phase II). EPA-230/1-74-035, 1974. pp. V-3 through
V ~ D • i
31. PEDCo Environmental, Inc. Cost of Monitoring Air Quality in
the United States. (Draft) Prepared for the U.S. Environ-
mental Protection Agency under Contract, No. 68-02-3013,
Cincinnati, Ohio, pp.3-1 through 3-2.
32. Bureau of National Affairs, Inc. Occupational Safety and
Health Reporter, Washington, D.C. 1(31):5565-5573 and
8301-8303.
8-111
-------
33. American Iron and Steel Institute, Annual Statistical
Report, 1977, p. 13, table 2.
34. David et a!., Appendix A.
3b. U.S. Department of Commerce, Bureau of Labor Statistics,
Producer Prices and Price Indexes. 1976 and 1978.
36. American Iron and Steel Institute, Annual Statistical
Rep_ort, 1977.
37. U.S. Department of Commerce, Bureau of the Census, Annual
Survey of Manufactures, 1976.
I
38. Information provided by Dow-Badische, Company in a telephone
conversation between R. Ray and R. Zerbonia, PES, April 19, 1979.
39. Information provided by AS producers and contained in trip
reports from visits to Allied Chemical Corp., Hopewell, Virginia;
Nipro Chemical, Augusta, Georgia; and Dow Badische Company,
Freeport, Texas; also responses to 114 letters to these
companies.
40. Federal Register, Environmental Protection Agency, improv-
ing Environmental Regulations, Final Report and Implementa-
tion, Execution Order 12044; May 29, 1979.
8-112
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9. RATIONALE FOR THE PROPOSED STANDARD
9.1 SELECTION OF SOURCE FOR CONTROL
The ammonium sulfate (AS) industry is a significant contributor
to nationwide emissions of particulate matter. The Priority List
(40 CFR 60.16, 44 FR 49222, August 215 1979) identifies various sources
of emissions on a nationwide basis in terms of quantities of emissions
from source categories, the mobility and competitive nature of each
source category, and the extent to which each pollutant endangers health
and welfare. The Priority List reflects the Administrator's determina-
tion that emissions from the listed source categories contribute
significantly to air pollution and is intended to identify major source
categories for which standards .of performance are to be promulgated.
The ammonium sulfate manufacturing industry is listed among those
source categories for which new source performance standards (NSPS)
must be promulgated.
AS has been an important nitrogen fertilizer for many years. Its
early rise to importance as a fertilizer evolved from its availability
as a by-product from basic industries such as steel manufacturing
and petroleum refining. By-product generation has continued to
dominate the AS production industry. In fact, by-product AS from
the caprolactam segment of the synthetic fibers industry is now the
single largest source, accounting for more than 50 percent of AS
production.
Production of AS as a by-product also ensures that it will
continue as an important source of nitrogen fertilizer in the United
States. This is illustrated by the fact that, in response to an
increase in demand, caprolactam production is expected to increase
at compounded annual growth rrtes of up to 7 oercent through the
year 1985; and for every megagram of caprolactam produced,.2.5 to
4.5 megagrams of AS are produced as a by-product.
Over 90 percent of AS is generated from three types of plants:
synthetic, caprolactam by-product, and coke oven by-product. Inves-
tigation has shown that all growth in the AS industry will be within
9-1
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these industry sectors. Synthetic AS is produced by the direct
combination of ammonia and sulfuric acid. Caprolactam AS is produced
as a by-product from streams generated during caprolactam manufacture.
Ammonia recovered from coke oven off gas is reacted with sulfuric
acid to produce coke oven AS. These three major segments of the AS
industry would be regulated by the proposed new source performance
standard.
9.2 SELECTION OF POLLUTANTS
I
Study of the AS industry has shown that ammonium sulfate emissions
are the principal pollutant emitted to the atmosphere from AS plants.
At operating temperatures, the AS emissions occur as solid particulate
matter, a "criteria" pollutant for which national ambient air quality
standards have been promulgated. Studies have been conducted to
evaluate the influence of AS as a co-factor in carcinogenesis and
i
to determine the effects of AS upon human cardiopulmonary function.
Results appear inconclusive as to the deleteriousness of AS as an air
1 2
pollutant in itself. »
Currently a variety of wet collection systems are employed to
control AS particulate emissions to levels of compliance with State
and local air pollution regulations, a reduction of 97 to 98 percent.
Existing State Implementation Plan (SIP) regulations vary from a low
of 0.71 kilogram to a high of 1.3 kilograms of particulate per megagram
of AS production. However, by the year 1985 new, modified, and;
reconstructed AS manufacturing dryers would cause annual nationwide
particulate emissions to increase by about 670 Mg/year (737 tons/year)
with emissions controlled to the level of a typical SIP regulation.
(Estimate based on the growth rate demonstrated over the past decade.)
Hydrocarbon (HC) emissions are also emitted from process dryers
at caprolactam by-product AS plants. Test data indicate that the HC
emissions are largely in the vapor phase and at least two orders of
magnitude lower than AS particulate emissions (110 kg/Mg for particulate
9-2
-------
matter versus 0.78 kg/Mg for the HC emissions). In addition, current
particulate control systems (wet collectors) have demonstrated an 88
percent removal efficiency of the uncontrolled caprolactam HC emissions.
At this control level, new, modified, and reconstructed caprolactam AS
plants would add only about 76 Mg per year to nationwide HC emissions
by 1985. Therefore, the only pollutant recommended for control by the
proposed standards is particulate matter.
9.3 SELECTION OF THE AFFECTED FACILITY
Ammonium sulfate crystals are formed by continuously circulating
a mother liquor through a crystal!izer. When optimum crystal size is
achieved, precipitated crystals are separated from the mother liquor
(dewatered), usually by centrifuges. Following dewatering, the crystals
are dried and screened to product specifications.
On-site inspection of AS plants reveals that nearly all of the
particulate matter emitted to the atmosphere from AS manufacturing
plants is in the gaseous exhaust streams from the process dryers.
Other plant processes such as crystallization, dewatering, screening,
and materials handling are not, in the opinion of EPA, significant
emission sources.
AS dryers can be either of the fluidized bed (FB) or rotary drum
type. All FB units found in the industry are heated continuously with
steam-heated air. The rotary units are either direct-fired or steam
heated. Based on data obtained from plant visits, air flow rates for
the AS dryers at caprolactam plants range from 560 scm/Mg of product
to 3,200 scm/Mg of product. The lower value represents direct-fired
rotary drum drying units and the higher value represents fluidized bed
drying units using steam-heated air. At synthetic plants, air .flow
rates range from 360 scm/Mg to 770 scm/Mg of product. All drying
units at synthetic plants are of the rotary drum type; however, both
direct-fired and steam-heated air are used as methods of dryer heating.
One consequence of the wide range of gas flow rates for the
differing drying systems is that particulate emission rates, which are
9-3
-------
directly related to the gas-to-product ratio,* also vary considerably
for each drying unit involved. Emission test results using EPA Method
5 at typical facilities are presented in Table 9-1.
Since the process dryer is the only significant source of AS
particulate emissions, the AS manufacturing industry can be effectively
controlled by specifying emission limitations for the process dryer..
Therefore, the AS dryer has been selected as the affected facility for
which particulate matter regulations are proposed.
9.4 SELECTION OF THE FORMAT OF THE RECOMMENDED STANDARDS
A mass per unit-time performance standard and such non-performance
type standards as design, equipment, work practice, and operational
standards were initially considered but were later judged as inappro-
priate for application to the AS industry. A standard based on mass
per unit time (e.g., kg/hr) would require that a relationship be
constructed showing how the allowable mass rate of emissions would
vary with both production and time. Such a relationship could not be
determined without extensive source tests performed at great expense.
Section lll(h) of the Clean Air Act establishes a presumption
against design, equipment, work practice, and operational standards.
For example, a standard based on a specific type of drying equipment
without add-on controls or a standard limiting the dryer air flow rate
cannot be promulgated unless a standard of performance is not feasible.
Performance standards for control of AS dryer particulate emissions
have been determined as practical and feasible; therefore, design,
equipment, work practice, or operational standards were not considered
as regulatory options.
The point should be noted, however, that uncontrolled emissions
from all known dryers are too great to comply with existing state
*6as-to-product ratio is defined as the volume of dryer exhaust gas
per unit of production, e.g., dry standard cubic meters per megagram
of ammonium sulfate produced.
9-4
-------
Table 1. SUMMARY OF UNCONTROLLED AS EMISSION
DATA — EPA EMISSION TESTS ON AS DRYERS
Plant
A
B
C
D
Dryer Type
Rotary Drum
Fluidi zed Bed
Rotary Drum
Rotary Drum
Average Uncontrolled AS Emissions
gm/dscm
4.38
39.0
8.87
98.3
(gr/dscf)
( 1.93)
(17.2)
( 3.91)
(43.2)
kg/Mg
0.41
no.
3.46
77.
(Ib/ton)
( 0.82)
(221. )
( 6.92)
(153.0)
9-5
-------
regulations even at the lowest air flow rates. It therefore would be
impractical to consider a standard solely on the process equipment
type or to limit emissions by specifying the air flow.
Two additional formats for the proposed standard were also
considered: mass standards, which limit emissions per unit of feed to
the AS dryer or per unit of AS processed by the dryer; and concen-
tration standards, which limit emissions per unit volume of exhaust
gases discharged to the atmosphere.
Mass standards, expressed as allowable emissions per unit of
production, relate directly to the quantity of particulate matter
discharged to the atmosphere. They regulate emissions based on units
of input or output, thereby denying any dilution advantage. Mass
standards allow for variation in process techniques such as decreasing
the air flow rate through the dryer. A primary disadvantage of mass
standards, as compared to concentration standards, is that their
enforcement may be more time consuming and therefore more costly. The
more numerous measurements and calculations required also increase the
opportunities for error. Determining mass emissions requires the
development of a material balance on process data concerning the
operation of the plant, whether it be input flow rates or production
flow rates. The need for such a material balance is particularly
relevant in the case of AS plants. The determination of throughput in
the affected facility, the AS dryer, is seldom direct. None of the
plants investigated during development of the proposed standards made
direct measurement of the dryer input or output. Process weights were
determined indirectly through monitoring of input stream feed rates.
In general, enforcement of concentration standards requires a
minimum of data and information, thereby decreasing the costs of
enforcement and reducing the chances of error. Furthermore, vendors
of emission control equipment usually guarantee equipment performance
in terms of the pollutant concentration in the discharge gas stream.
Although in the AS industry enforcement of concentration standards may
9-6
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be complicated by use of two-stage FB dryers which add ambient air
streams at the discharge end of the dryer. There is a potential for
circumventing concentration standards by diluting the exhaust gases
discharged to the atmosphere with excess air, thus lowering the con-
centration of pollutants emitted but not the total mass emitted. For
combustion operations, this problem can usually be overcome by correcting
the concentration measured in the gas stream to a reference condition
such as a specified oxygen or carbon dioxide percentage in the gas
stream. However, in the AS industry the drying process frequently
does not involve direct combustion. The drying air may be heated by
an outside source; therefore, it is not always possible to "correct" •
the amount of exhaust air to account for dilution.
Because design dryer gas flow rates vary for process reasons,
concentration standards applied to the ammonium sulfate industry would
penalize those plant operators who chose to use a low air flow rate
for the AS dryer. A decrease in the amount of dryer air decreases the
volume of gases released but not necessarily the quantity of particulate
matter emitted. As a result, the concentration of particulate matter
in the exhaust gas stream would increase even though the total mass
emitted might remain nearly the same.
Because mass standards directly limit the amount of particulate
matter emitted to the atmosphere per megagram of AS production, a single
mass standard can be applied to all dryer types and sizes, production rates,
and air flow rates. The flexibility of mass standards to accommodate
process variations, such as the wide range of gas-to-product ratios found
in the industry, allows all segments of the AS industry to be regulated with
a single mass emission limit. These advantages outweigh the drawbacks
associated with the determination of process weight. Consequently, mass
standards were judged more suitable for regulation of particulate emissions
from AS dryers and were selected as the format for expressing the standard
of performance for ammonium sulfate manufacturing plants.
The use of mass units results from discussion with control officials,
representatives of affected industries, and others knowledgeable in
the field. The purpose of using mass units is to facilitate enforcement
9-7
-------
of the new source performance standards as well as to allow plant
operators to vary air flow according to the needs of the individual
process involved.
In proposing mass limits, it is implicit that compliance be
achieved through the application of remedial equipment that will limit
the discharge of pollutants to the atmosphere. The mass limit recom-
mended will apply to the exhaust gas streams as they discharge from
control equipment. The proposed standard expresses allowable particulate
emissions in kilograms of particulate per megagram of AS production.
i
9.5 SELECTION OF THE BEST SYSTEM OF EMISSION REDUCTION AND THE
NUMERICAL EMISSION LIMITS
|
Best systems of emission reduction and emission limits were
selected based on emission data and background information obtained
through the following procedure. First, the known available source
test emission data were obtained. These were supplemented with AS
production information from industry publications and literature
related to air pollution control and process equipment. Secondly,
verbal and written communications were made with several representa-
tives from manufacturing companies, trade associations, and air
pollution control agencies. Finally, nine of the plants were visited
to obtain process and emission control information. Relative control
efficiencies of different types of control devices were evaluated on
the basis of conversations with plant operators, test data (where
available), and visual observations of opacity from control devices.
Judgment regarding the feasibility of stack testing was made for each
plant. Of the nine plants visited, five locations were unsatisfactory
because the control equipment was judged to be less than optimum or
the physical layout of the equipment made testing infeasible. One
unit could not be tested because it was undergoing an equipment modifi-
cation. Facilities, at four plants were selected for stack testing
using EPA Reference Method 5 to evaluate control techniques currently
used for controlling particulate emissions from AS dryers. A descrip-
tion of the facilities and detailed results of the EPA emissions
tests are presented in Chapter 4, Section 4.5 and in Appendix C.
9-8
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9.5.1 Control Technology
Both venturi scrubbing and fabric filtration represent the most
efficient add-on control techniques available to abate particulate
emissions. In application to particulate collection from AS dryers,
both have the potential to reduce AS emissions by over 99.9 percent
and both can potentially reduce the AS emissions from process dryers
to less than 0.15 kilogram per megagram of AS production, although
energy requirements and costs may differ.
At present, a variety of wet-scrubbing systems are employed to
control AS particulate emissions. The majority of these are low-
energy wet-scrubbers; the only high-efficiency wet collectors that are
being used with ammonium sulfate dryers are medium energy venturi
scrubbers in use at two plants. EPA tests on medium energy venturi
scrubbers controlling AS emissions show that greater than 99.9 percent
particulate removal efficiency can be attained.
Several parameters affect the performance of wet-scrubbing
systems; other parameters being equal, however, collection efficiency
tends to increase with the increased energy input. Increases in the
pressure drop and the liquid-to-gas ratio are directly related to
increase in efficiency: the higher the pressure drop, the higher the
removal efficiency of particulates. Pressure drop can be increased
(and hence efficiency can be increased) simply by increasing the gas
velocity and/or the water injection rate within the design limits of
the control equipment. When gas cleaning requirements change, the only
adjustment necessary to the venturi scrubber, in most cases, is in the
flow of scrubbing liquid to increase the pressure drop. Thus, higher
cleaning efficiency is accomplished without modification or addition.
Venturi scrubbers are most _uitable for application to AS dryers.
In caprolactam by-product AS plants, AS feed streams are used as a
scrubbing liquor and in synthetic AS plants the condensate from the
reactor/crystal!izer is used as the scrubbing liquor. This allows the
collected particulate to be easily recycled to the system without
addition of excess water.
9-9
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Because medium-energy (25 to 33 centimeters W.6. pressure drop)
venturi scrubbing with high liquid-to-gas ratios achieves a high
collection efficiency and because venturi scrubbing is compatible with
and complimentary to the processes involved, it is considered the most
attractive add-on control system.
The fabric filter baghouse should also be able to achieve the
level of control required by the standard based on similar applications
in other industries. Normal operation of a baghouse for AS particulate
collection, i.e., at temperatures above the dewpoint of the exhaust
gas, should be feasible. However, in assessing fabric filters as an
emission control option, the following factors must be considered.
For high gas flow rates, capital and operating costs as well as energy
requirements are higher for fabric filters than for medium energy
scrubbers of the same construction material (see Table 8-38). For
caprolactam by-product plants using steam-heated fluidized bed dryers,
the ratio of gas flow to product rate is at least an order of magnitude
higher than that of the direct-fired rotary drum dryer operating with
fabric filters. As the size of a baghouse becomes larger, capital and
annual operating costs increase. For example, maintaining the tempera-
ture of the exhaust gas and baghouse surfaces above the dewpoint may
require more energy than would ordinarily be required to operate the
dryer.
With caprolactam by-product AS plants apparently providing the
bulk of the anticipated growth in the AS industry, consideration
should also be given to caprolactam hydrocarbon emissions from AS
dryers. Available test data indicate that most of the caprolactam
emissions associated with the AS dryer are in the vapor state. This
i
suggests that caprolactam emissions would pass through a fabric filter
collection system. On the other hand, a venturi scrubber has demon-
strated removal efficiency of 88 percent of the caprolactam from AS
dryers. Thus, use of venturi scrubbers would, at a minimum, maintain
existing HC control levels now achieved by in-use wet collection
systems.
9-10
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9.5.2 Emission Tests
Of the four tests by EPA, one was conducted to determine the
control level achievable by a Tow energy wet scrubber of the cen-
trifugal type operating at a low pressure drop of 15 centimeters
o
(6 inches W.G.) and low liquid-to-gas ratio of 267 liters/1000 m
(2 gallons per 1000 acf). Analysis of EPA test results at Plant C,
a synthetic AS plant with a rotary drum dryer, indicates that this
emission control equipment is not representative of the best available
control technology. Observed opacities at Plant C range between 10
and 15 percent. Average controlled grain loading was 200 milligrams
per dry standard cubic meter. The particulate collection efficiency
at this facility was 97 percent. An inadequate control equipment
performance might be expected from consideration of the pressure drop
and L/G ratio together with the particle size distribution. Facility C
had a size distribution of 5.9 percent of particles in the 0 to 1.11
micron range.
The facility did however achieve a low mass emission limit
(0.08 kg/Mg of product). This was in large part a consequence of
the low uncontrolled inlet emission rate brought about by a low gas-
to-product ratio at this facility.
The one dry AS particulate control system in use (the fabric
filter unit at Plant A) was tested because it represents a unique
application of this control method in the AS manufacturing industry.
Facility A, a synthetic AS plant with a rotary drum dryer, showed average
particulate emissions of 0.007 kilograms per megagram of AS production
and a collection efficiency of 98.7 percent.
Of the factors influencing emission rates at Plant A, one is
most significant. The baghouse in use was originally designed for
another application; the gas flow rate to this unit is appreciably
lower than normal direct-fired gas flow. This constraint on gas
flow rate, by restricting the ratio of dryer exhaust gas-to-product
rate, results in a significantly lower uncontrolled inlet emission
rate than most other dryers used in the industry. The fabr.ic filter
inlet uncontrolled emission rate was 0.41 kg/Mg of production. Those
9-11
-------
of facilities controlled by venturi scrubbers were 110 kg/Mg and 77 kg/Mg.
This represents an uncontrolled mass emission difference in the range of
two orders of magnitude. Comparison of the outlet mass emissions for this
facility with those of the other facilities tested is, in this situation,
somewhat misleading.
i
Facility D, a synthetic AS plant with a rotary drum dryer, is
controlled by a venturi scrubber operating at a pressure drop of 33^
centimeters (13 inches W.G.) and a L/G ratio of 3,600 liters/1000 m
(27 gallons per 1000 acf). Analysis of EPA test results at Plant D
show a high uncontrolled emission rate entering the control device;
the control system did however demonstrate the typically high control
efficiency (99.8) percent) achievable with a venturi scrubber. The
outlet emission rate, 192 milligrams per dry standard cubic meter and
0.158 kg/Mg of product, was affected by the high inlet emission load
caused by a process variation at Plant D. It was indicated that the
crystallizer at Plant D periodically goes into a fines cycle, lasting
anywhere from 10 to 15 hours, during which time a much heavier propor-
tion of AS fines is produced in the dryer product than is normal.
" ' i
Facility B, a caprolactam by-product AS plant with a fluidized
bed dryer, is also controlled by a venturi scrubber; in this case the
unit operates at 25.9 centimeters (10 inches W.G.) pressure drop and a
L/G ratio of 3,075 liters/1000 m3 (24 gallons per 1000 acf). EPA test
results show an average controlled outlet emission rate of 0.156 kg/Mg
of AS production and 43 milligrams per dry standard cubic meter. The
overall particle collection efficiency was 99.9 percent by weight, a
control efficiency regarded as typical of venturi scrubbers. The mass
emission level achieved at Plant B and the particular control equipment •
used are considered representative of best demonstrated control
technology. |
Additional emission test data have been provided by the AS plant
operators. One facility's test results (using EPA Method 5) show an
average emission rate of 0.135 kg/Mg of AS production. Facility E,
a caprolactam AS plant with FB dryer, is controlled by a centrifugal
scrubber preceded by a system of cyclones. The scrubber operated at
9-12 !
-------
34 centimeters (13.4 inches) W.G. pressure drop and L/G ratio of 267
liters/1000 m3 (2.0 gallons per 1000 acf). Although the L/G ratio is
somewhat low, collection efficiency was enhanced by the cyclones which
precede the scrubber; thus, a low outlet emission concentration was
achieved.
Figure 1 presents the results of the four EPA emission tests and
the one plant operator test in the format selected for the new source
standard.
9.5.3 Regulatory Options
Review o^ the performance of the emission control techniques led
to the identification of two regulatory options. The two options are
based on emission control techniques representative of two distinct
levels of control. Each option specifies numerical emission limits for
AS dryers appliable to the three major sectors of the AS industry.
Option I is equivalent to no additional regulatory action. Emission
levels would be set by existing SIP regulations, typically in the range
of 0.71 kg/Mg to 1.3 kg/Mg of AS production. This option is characteri-
zed by the use of a low energy wet scrubber to meet the required emission
limit, a reduction of 97 to 98 percent. Option II, based on the use of
a venturi scrubber or fabric filter, would set an emission limit of
0.15 kilogram per megagram of AS production, the level of emission
control identified as achievable by EPA source tests. As applied to the
AS industry, both the venturi scrubber and the fabric filter3'4'5 control
systems are capable of greater than 99.9 percent control efficiency;
thus Option II represents the most stringent control level that can be
met by all segments of the AS industry.
The environmental impacts, energy impacts, and economic impacts
of each regulatory option were analyzed and compared using model plants
for the new, modified, and reconstructed AS facilities. However, each
AS manufacturing sector is unique from a technical standpoint. Dryer
types and sizes, gas-to-product flow rates, and uncontrolled particulate
emission rates vary from one sector to another and often within each
9-13
-------
\
1
0.6r-
0.5}
1
co DA
g*>
•8 o
03 «3
09 *^
us
W P.
0) «W
£ ° 0.3
•rl
^_1 J^
H 0)
(4 P.
^o
V> r4
Key:
O Method 5 - Current EPA Test
O "Method 5 - Company Test
{ Average of Three Test Runs
c _
•^—
O
o
_
'
.
i — ^
r i— ' «
• I
e ^
—
'
0.30
0.25
iO.2
0
•§
o
1 ^
1 o
r15 g
0)
p.
t>0
1
4 o.io
0.2
o.i
C
C
c
o
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^
A
1 1
B C
Facility
1
1)
,
E
FIGURE 1
CONTROLLED AS PARTICULATE EMISSIONS FROM EPA
EMISSION TESTS-CALCULATED MASS EMISSION RATES
9-14
-------
sector. For these reasons it was apparent that no single model plant
could adequately characterize the AS industry. Accordingly, several
model dryers were specified in terms of the following parameters:
production rate, dryer types, exhaust gas flow rates, emission rates,
stack height, stack diameter, and exit gas temperatures. The descrip-
tion of the model plant parameters and the evaluation of the regulatory
options as applied to the model plants are found in Chapters 6, 7, and 8.
Under Option I, new manufacturing plants' annual nationwide
particulate emissions would increase by about 670 Mg/year (737 tons/
year) between 1980 and 1985. Under Option II, nationwide emissions
would increase by,131 Mg/year (144 tons/year). This represents
a reduction of about 538 Mg/year or 80 percent in the emissions that
would be emitted under a typical SIP regulation.
The. results of the dispersion analysis under "worst case"*
meteorological conditions show the maximum 24-hour concentration
of particulates in the vacinity of a new AS plant would be reduced
by a factor of 80 percent (from 224 to 47.4 micrograms per cubic meter)
by controlling to Option II rather than the SIP emission limit. The
maximum annual average is reduced from 29.1 to 6.15 micrograms per cubic
meter under Option II. Thus, the implementation of Option II would
result in reduction of ambient air concentration of particulate matter
in the vicinity of new, modified, or reconstructed AS plants.
Effluent guidelines set forth in 40 CFR ,418.60 limit water
pollution from synthetic and coke oven AS plants. The caprolactam
by-product AS plant has a comparatively large throughput of water.
This water is removed in the crystallizer, condensed and recycled
to the principal plant for plant use. The addition of a wet scrubber
for emission control would not create a water pollution problem
*Worst case conditions refer to the atmospheric and meteorological
conditions that result in the highest pollutant concentrations.
9-15
-------
since all scrubbing liquor would be recycled to the process. The same
would be true with a baghouse since it is a dry collection system.
Consequently, the water pollution impact of Option II is zero.
The AS plants generate no solid waste as part of the process
since all collected AS is recycled to the process. Furthermore, no
significant increase in noise level is anticipated under Option II.
For typical plants in the AS manufacturing industry, an increase
in energy consumption would result from compliance with Option II.
The energy required, in excess of that required by a typical SIP
regulation, to control new caprolactam by-product AS plant to the .
level of Option II would be 8.8 gigawatt-hours of electricity per year
in 1985 using venturi scrubbers. The overall energy increase would
amount to less than 0.65 percent of the total energy required to run
the plant. For synthetic and coke-oven AS plants, the 1985 incremental
energy increase would be 0.61 and 0.14 gigawatt hours per year,
respectively, or less than a 0.1 percent increase. The total energy
increment would be 9.5 gigawatt hours per year in 1985. These figures
indicate that Option II would not significantly increase energy con-
sumption at AS plants and that Option II would have a minimal impact
on national energy consumption.
Economic analysis also indicates that the impact of Option II is
minimal. The capital cost of the installed emission control equipment
necessary to meet Option II, on all new and reconstructed AS facilities
coming on-line nationwide during the period 1980 to 1985, would be
about $958,000. The total annualized cost of operating this equipment
during the same period would be about $480,200. These costs are
considered reasonable, and are not expected to prevent or hinder
expansion or continued production in the AS manufacturing industry.
The incremental cost necessary to offset the cost of meeting Option II
would be about 0.01 percent of the wholesale price of AS.
Consideration of the beneficial impact on national particulate
emissions; the lack of water pollution impact or solid waste impact;
9-16
-------
and the minimal energy impact; the reasonable cost impact; and the
general availability of .demonstrated emission control technology
leads to the selection of Option II as the basis for standards of
performance for new AS dryers.
9.6 SELECTION OF OPACITY LIMITS
The best indirect method of ensuring proper operation and
maintenance of emission control equipment is the specification of
exhaust gas opacity limits. Determining an acceptable exhaust gas
opacity limit is possible because opacity levels were evaluated for
AS dryers during EPA tests; therefore, the data base for the particu-
late standards includes information on opacity. A standard of
15 percent opacity is proposed for all affected facilities to ensure
proper operation and maintenance of control systems on a day-to-day
basis. Ammonium sulfate dryers were observed to have no opacity
readings greater than 15 percent opacity, and a total of 90 minutes
of opacity of less than or equal to 15 percent but greater than
10 percent during observation periods of 180, 120, 438, and
408 minutes (1146 minutes total). The results of these observations
are summarized in Table 9-2.
9.7 SELECTION OF PERFORMANCE TEST METHODS
The use of EPA Reference Method 5 — "Determination of Particulate
Emissions from Stationary Sources" (40 CFR Part 60, Appendix A) would
be required to determine compliance with the mass standards for particu-
late, matter emissions. Results of performance tests using Method 5
conducted by EPA on existing ammonium sulfate dryers comprise a major
portion of the data base used in the development of the proposed
standard. EPA Reference Metl.'H 5 has been shown to provide a repre-
sentative measurement of particulate matter emissions. Therefore, it
is included for determining compliance with the proposed standards.
Method 5 calculations require input data obtained from three
other EPA test methods conducted previous to the performance of
Method 5. Method 1 — "Sample and Velocity Traverse for Stationary
9-17
-------
Table 2. OPACITY OBSERVATIONS
Percent
Opacity
>10 andllB
>5 and < 10
>0 and 1 5
0 Percent
Total Observation
j Time (Minutes)
Facility
A
0
0
0
180
180
B
36
186
198
18
438
C
54
66
0
0
120
D
0
0
318
90
408
Total
Observation
Time
(Minutes)
90
252
516
288
1,146
9-18
-------
Sources" must be used to obtain representative measurements of
pollutant emissions'. The average gas velocity in the exhaust stack is
measured by conducting Method 2, "Determination of Stack Gas Velocity
and Volumetric Flow Rate (Type S Pitot Tube)." The analysis of gas
composition is measured by conducting Method 3, "Gas Analysis for
Carbon Dioxide, Oxygen, Excess Air, and Dry Molecular Weight." These
three tests provide data necessary in Method 5 for determining concen-
tration of particulate matter in the dryer exhaust. All opacity
observations would be made in accordance with the procedures established
in EPA Method 9 for stack emissions.
Since the proposed standards are expressed as mass of emissions
per unit mass of ammonium sulfate production, it will be necessary to
quantify production rate in addition to measuring particulate emissions.
.Ammonium sulfate production in megagrams shall be determined by direct
measurement using product weigh scales or computed from a material
balance. A material balance computation based on the chemical reactions
used in the formation of ammonium sulfate is an acceptable method of
determining production rate since the formation reactions used in all
industrial sectors are quantitative and irreversible.
If a material balance is used, the ammonium sulfate production
rate for synthetic and coke oven by-product ammonium sulfate plants
shall be calculated from the metered sulfuric acid feed rate to the
reactor/crystallizer. For caprolactam by-product ammonium sulfate
plants, production rate shall be.determined from the oximation ammonium
sulfate solution flow rate and the oleum flow to the caprolactam
rearrangement reaction.
9.8 SELECTION OF MONITORING REQUIREMENTS
To further ensure that installed emission control systems
continuously comply with standards of performance through proper
operation and maintenance, monitoring requirements are generally
included in standards of performance. . In the case of ammonium sulfate
9-19
-------
dryers, the most straightforward means of ensuring proper operation
and maintenance is to require monitoring of actual particulate emis-
sions released to the atmosphere. Currently, however, there are no
continuous particulate monitors in operation for AS dryers; and
resolution of the sampling problems and ^development of performance
specifications for continuous particulate monitors v/ould entail a
major development program. For these reasons, continuous monitoring
of particulate emissions from AS dryers is not required by the
" ' !
proposed standards.
The best indirect method of monitoring proper operation and
maintenance of emission control equipment is to continuously monitor
the opacity of the exhaust gas. The proposed opacity limit for AS
dryers is 15 percent. However, in the case of AS dryers, the character
of the exhaust gas when wet scrubbers are used for emission reduction
precludes the use of continuous in-stack opacity monitors. Where con-
densed moisture is present in the exhaust gas stream, in-stack continuous
monitoring of opacity is not feasible; water droplets and steam can
interfere with operation of the monitoring instrument. Since most
new facilities are likely to use wet scrubbers, continuous monitoring
of opacity is not required by the proposed standards.
An alternative to particulate or opacity monitors is the use of
pressure drop monitor as a means of ensuring proper operation and
maintenance of emission control equipment. For venturi scrubbers,
particulate removal efficiency is related directly to pressure drop
across the venturi; the higher the pressure drop, the higher the
removal efficiency. For fabric filters, pressure drop is used as
an indicator of excessive filter -resistance or damaged filter media.
Therefore, in order to provide a continuous indicator of emission
control equipment operation and maintenance, the proposed standards
require that the owner or operator of any ammonium sulfate manufac-
turing plant subject to the standards install, calibrate, maintain,
and operate a monitoring device which continuously measures and
i i
permanently records the total pressure drop across the process
9-20
-------
emission control system. The monitoring device shall have an
accuracy of ±5 percent over its operating range.
The proposed standards would also require the owner or operator
of any ammonium sulfate manufacturing plant subject to the standards
to install, calibrate, maintain, and operate flow monitoring devices
necessary to determine the mass flow of ammonium sulfate feed material
to the process. The flow monitoring device shall have an accuracy
of ±5 percent over its operating range. The AS feed streams are:
for synthetic and coke oven by-product AS plants, the sulfuric acid
feed stream to the reactor/crystal!izer; for caprolactam by-product
AS plants, the.oximation AS stream to the AS plant and the oleum
stream to the caprolactam rearrangement reaction.
Records of pressure drop and calibration measurements would have
to be retained for at least 2 years following the date of the measure-
ments by owners and operators subject to this subpart. This requirement
is included under 60.7(d) of the general provisions of 40 CFR Part 60.
9-21
-------
9.9 References
1.
Bell, K.A., W.S. Linn, and O.D. Hackney, Effects of
Sulphate Aerosals Upon Human Cardiopulmonary Function,
CRC-APRAC-CAPM-27-75, May 1977.
2. Gooleski and Leighton, Studies on the Effect of AS on
Carcinogenesis. EPA 600/1-78-020, March 1978.
3. Air Pollution Engineering Manual, 2nd Edition, EPA,
AP-40, p. 111-132. May 1973.
4. Information provided by Mcllwaine Company in a telephone
conversation between M. Mcllwaine and R. Zerbonia, PES,
May 2, 1979.
5. Control Techniques for Particulate Air Pollutants, U.S.
Environmental Protection Agency, AP-51, p. 118.
9-22
-------
APPENDIX A
EVOLUTION OF THE PROPOSED STANDARDS
-------
-------
APPENDIX Ai. EVOLUTION OF THE PROPOSED STANDARDS
In early 1978,. the Argonne National Laboratory prepared a list
of 156 major source categories and ranked them in order of priority
for NSPS development. The method used to rank thetsource categories
was based on emissions, public health/we!fare, and source mobility
which were criteria set forth by the Congress in the 1977 Clean Air
Act Amendments. Ammonium sulfate was ranked 44th in priority on a
list.of 72 source categories selected by EPA.
Based upon the results of a screening study conducted in March
1978, standards development was initiated for the AS category.
In May 1978, a literature survey was begun and the industry was
canvassed by phone to obtain information on plant operations and to
determine1 which plants, if any, appear to be well controlled. rPI ant
visits were then scheduled to obtain information on process details,
quantities of emissions, and emission control equipment. The
feasibility of emission testing was also determined during the plant
visits. The significant events relating to this effort are discussed
in the chronology below.
A.I CHRONOLOGY . ,
The chronology to follow lists the important events which have
occurred in the development of background information for a New
Source Performance Standard for Ammonium Sulfate Manufacturing.
A-l
-------
Date
Activity
October 14, 1977
March 21, 1978
January 3, 1978
April 20, 1978
April 13, 1978
June 6, 1978
June 7, 1978
June 12, 1978
July 31, 1978
August 31, 1978
June 12, 1978
June 13, 1978
June 20, 1978
June 26, 1978
June 27, 1978
Literature survey initiated for screening
study. Telephone survey of AS plants
initiated.
Screening study completed. A decision was
made to initiate standards development.
Section 114 letters sent.
Project starting date.
MITRE
Contract awarded to
Plant visit to the Allied Chemical Corp.,
caprolactam plant in Hopewell , Virginia.
j
First contact with the Industrial Gas
Cleaning Institute (IGCI) regarding control
technology for AS dryer emissions.
!
Plant visit to the Rohm and Haas acrylate
production facility in Pasadena, Texas.
Initial test request submitted to EMB.
Preliminary model plant data submitted to
Plant visit to the Occidental Chemical
Company in Houston, Texas.
Plant visit to the Dow-Badische Chemical
Company caprolactum plant at Freeport,
Texas,
Plant visit to the Bethlehem Steel Company
coke oven by-product AS plant.
Plant visit to the Chevron Chemical Company
synthetic AS production facility at
Richmond, California.
Plant visit to the Valley Nitrogen Producers
Company synthetic AS plant at Helm,
California.
A-2
-------
Date
Activity
June 28, 1978
July 25, 1978
September 12, 1978
October 3, 4, 1978
October 6-12, 1978
October 26, 1978
November 31, 1978
December 5, 6, 1978
December 12, 13, 1978
January 31, 1979
February 28, 1979
March, 1979
April, 1979
April, 1979
May, 1979
June, 1979
June, 1979
Plant visit to the Occidental Chemical
Company synthetic AS production facility at
Lathrop, California.
Plant visit to the Nipro Chemical Company
caprolactam production facility in Augusta,
Georgia.
Emission testing at Plant A.
Emission testing at Plant B.
Telephone survey of coke oven facilities.
Emissions testing at Plant A for additional
information.
•Final model plant parameters submitted to
EMB.
Emission testing at Plant C.
Emission testing at Plant D.
Complete test results received from EMB.
Preliminary cost analysis available from
EMB.
Completion of technical portion of BID,
Chapters 3-7.
Industrial mailout of BID Chapters 3-7.
Completion of NSPS economic analysis,
Chapter 8; Rationale, Chapter 9; and Preamble
EPA Working Group mailout.
Revision of BID chapters, Regulation, and
Preamble to account for Working Group and
Industry comment.
EPA Steering Committee mailout.
A-3
-------
Date
August 13, 1979
August 28, 1979
Activity
Mai lout to Industry, Environmental Groups
and other Government Agencies (BID,
Regulation, and Preamble).
National Air Pollution Control Techniques
Advisory Committee meeting for review of
BID, Regulation, and Preamble).
A-4
-------
APPENDIX B
INDEX TO ENVIRONMENTAL CONSIDERATIONS
-------
-------
APPENDIX B
INDEX TO ENVIRONMENTAL CONSIDERATIONS
This appendix consists of a reference system which is cross
indexed with the October 21, 1974, Federal Register (39 FR 37419)
containing EPA guidelines for 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
-------
;! i APPENDIX B .
INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS
Agency Guidelines for Preparing
Regulatory Action Environmental
Impact Statements (39 FR 37419)
Location Within the Background
Information Document (BID)
1. Background arid Description
of Proposed Action
Summary of Proposed,
Standard
2.
.The standards are summarized in
"Chapter 1, Section 1.1.
Statutory Basis for .the
Standard
Facility Affected
Process Affected
„ Availability of Control
"'3 ' Technology " ' "" '
.( -,,-,1-1 *' .-'••--,,'( -.;»-- "s-,-: :':i"if f j,,"!, i, (
" Existing Regulations. -.-r
at State or Local
.. Level ,
Alternatives to the
Proposed Action
Option I
Environmental Imp'acts
Costs
. .
!•!!-!„- ........ I (I, i III' II III III 4ib ................ -""S ..... :* ...... .'t_'
The statutory basis for the
standard is given in Chapter 2.
A description of the facility to
be affected is given in Chapter 3,
Section 3.1.
A description of the process to be
affected is given in Chapter 3,
Section 3.2. ,.
'I;.!,,!1 ;,; i,;. 4 ;„<;,.I. >•• tji'.i'H' i a '"" . '., I
Information on the availability
; of control technology is given
in Chapter 4.
!lf;KA idiscuisslon o^existirig'regula- "
tions or the industry to be
,, affected by the standards is
'included in Chapter 3, Section 3.2,
, The environmental impacts associated
with Option I emission control
systems are considered in Chapter 7.
The cost impact of Option I emission
control systems is considered in
Chapter 8, Section 8.2.
(Continued)
B-2
-------
INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS (Concluded)
Agency Guidelines for Preparing
Regulatory Action Environmental
Impact Statements (39 FR 37419)
Location Within the Background
Information Document (BID)
Health and Welfare
Impact
3. Environmental Impact of
Proposed Action
Air Pollution
Water Pollution
Solid Waste Disposal
Energy
Costs
The impact of Option I emission
control systems on health and
welfare is considered in Chapter 7,
The air pollution impact of the
proposed standards is considered
in Chapter 7, Section 7.1.
The impact of the proposed
standards on water pollution is
considered in Chapter 7, Section 7.1.
The impact of the proposed
standards on solid waste disposal
is considered in Chapter 7,
Section 7.3.
The impact of the proposed
standards on energy use is
considered in Chapter 7, Section 7.4.
The impact of the proposed
standards on costs is considered
in Chapter 8, Section 8.2
B-3
-------
-------
APPENDIX C
SUMMARY OF TEST DATA
-------
-------
APPENDIX C. SUMMARY OF TEST DATA
A test program was undertaken by EPA to evaluate the best dem-
cnstrated^control technology,avail able in the AS production industry,
for controlling particulate emissions from the AS dryer. This appen-
dix summarizes the results of the particulate emission tests and
visible emission observations.
One baghouse and three wet scrubbers (two venturi and one cen-
trifugal scrubber) were tested using EPA Reference Method 5. Results
of the front-half catches (probe and filter) from the particulate em-
ission measurements conducted are shown in Figures C-l through C-4.
The controlled particulate emission values are displayed in concen-
tration and mass units in these figures. In addition, pertinent
industry-supplied data are shown in Figures C-l through C-4. Com-
plete EPA emission test results are presented in Tables C-l through
C-21. .
Visible emission observations were made at the exhaust of the
above control devices in accordance with procedures recommended in
EPA Reference Method 9 for visual determination of the opacity of em-
issions from stationary sources. Results of opacity determinations
at the four facilities tested are summarized in Tables C-2, C-3, C-5,
C-7 and C-9, respectively, and presented in detail in Tables C-17
through C-21.
C-l
-------
C.I DESCRIPTION OF FACILITIES
Plant A ' !
Gas-fired rotary dryer rated at 16.3 Mg'/hr (18 TPH). AS partic-
ipate emissions are collected by a reverse jet type baghouse. Two
sets of baghouse outlet emission tests were conducted at Plant A
using EPA Method 5. The first set of outlet tests (Table C-2) was
rejected due to discovery of some punctured bags which resulted in an
abnormally high grain loading result. The second set of baghouse
outlet tests (Table C-3) was conducted during a period of normal
•; i
operation. Uncontrolled AS emissions and particle size distribution
data were determined at the baghouse inlet (Tables C-l and C-13, re-
spectively). Visible emission observations were made at the baghouse
exhaust using EPA Method 9 (Table C-17).
I
Plant B
Fluidized-bed dryer rated at 26.5 Mg/hr (29.2 TPH). The AS bed
in this unit is fluidized by two streams of air: steam-heated air
i
for drying the moisture-laden AS, introduced at the front end of the
dryer, and ambient air for cooling of the AS product introduced at
the back end of the dryer. AS particulate emissions from the dryer
are controlled by a venturi scrubber. Emission tests were conducted
only during periods when the process was operating normally. Scrub-
ber inlet and outlet AS particulate levels were measured using EPA
Method 5 (Tables C-4 and C-5). Particle size distribution data were
determined at the scrubber inlet (Table C-14). Visible emission
C-2
-------
observations were made of the stack gas leaving the scrubber using
EPA Method 9 (Table C-18). Since Plant B is a caprolactam AS produc-
tion facility, measurements were made of caprolactam emissions at
both the scrubber inlet and outlet. Actual determinations of capro-
lactam concentrations were made using gas chromatograph methods and
results are shown in Tables C-ll and C-12.
Plant C
Gas-fired rotary dryer rated at 15.2 Mg/hr (16.7 TPH). AS par-
ticulate emissions are collected by a wet scrubber of the centrifu-
gal type. Emission tests were conducted during periods of normal
operation. Scrubber inlet and outlet AS particulate levels were
measured using EPA Method 5 (Tables C-6 and C-7). Particle-size dis-
tribution data were determined at the scrubber inlet (Table C-15).
Visible emission observations were made of the stack gas leaving the
scrubber using EPA Method 9 (Table C-19).
Observed opacities at Plant C range between 10 and 15 percent
during the test. Controlled grain loading averaged 0.20 gr/dscm.
The control equipment in this case is a centrifugal scrubber designed
for aAP of approximately 6" W.6. and an L/G ratio of about 5.0
gal/1000 acfm. Actual values of these parameters could not be
calculated from the available test data so it is not known whether
one or both of these key scrubber factors were operating at design
values.
C-3
-------
plant D
Gas-fired rotary dryer rated at 8.4 Mg/hr (9.2 TPH). AS partic-
ulate emissions are collected by a venturi scrubber. Scrubber inlet
and outlet AS particulate levels were measured using EPA Method 5
(Tables C-8 and C-9). Particle-size distribution data were deter-
mined at the scrubber inlet (Table C-16). Visible emission observa-
tions were made of the stack gas leaving the scrubber using EPA
Method 9 (Table C-20).
Observed opacities at Plant D were 0 percent during the test.
Controlled grain loading averaged 0.192 grams/dscm. The control
equipment in this case, a venturi scrubber, is designed for aAP of
approximately 13 inches W.G. and a L/G ratio of about 27 gal/1000
acf. Actual values of these parameters could not be calculated from
the available test data; so it is not known whether one or both of
these key scrubber factors were operating at design values. The com-
pany, however, is not able to provide^he original design data for
this unit which was installed in 1965. With respect to variations
in process operation, it was indicated that the crystallizer at Plant
D periodically goes into a fines cycle, lasting anywhere from 10 to
15 hours, during which time a much heavier proportion of AS fines is
produced in the dryer product than is usual (approximately 4 to 5
2
times the normal amount).
C-4
-------
C.2 REFERENCES : •
1. Information provided by 'Plant D in a telephone conversation
with Marvin Drabkin of The MITRE Corporation, Metrek
Division, on March 28, 1979.
2. Information provided by Plant D in a letter to Marvin
Drabkin of The MITRE Corporation, Metrek Division, dated
March 16, 1979.
C-5
-------
Table C-l. FACILITY A - FIRST SET OF TESTS , r .<
SUMMARY OF RESULTS - BAGHOUSE INLET
Run Number
Date
Test Time-Minutes
AS Production Rate
Dryer Vent Gas Data
Flow rate - acm/min
(acfm)
Flow rate - dscm/min
(dscfm)
Temperature - °C
Water vapor - Vol
Particulate Emissions
Probe and Filter Catch
gm/dscm
(gr/dscf)
gm/acm
(gr/acf)
kg/hr
(Ib/hr)
kg/Mg
(Ib/ton)
Total Catch
gm/dscm
(gr/dscf)
gm/acm
(gr/acf)
kg/hr
(Ib/hr)
kg/Mg
(Ib/ton)
1
9/12/78
120
Mg/hr 15.8
(TPH) (17.4)
Ln 36 . 7
JLli
) (1300)
in 27.1
m) (960)
67
(153)
. % 12.9
;S
Catch
2.29
(1.01)
1.70
(0.75)
3.8
(8.36)
0.24
(0.48)
2
9/12/78
120
14.9
(16.4)
37.2
(1320)
26.8
(950)
80
(176)
12.4
2.17
(0.96)
1.56
(0.69)
3.56
(7.84)
0.24
(0.48)
3
9/13/78
120
18.7
(20.6)
37.2
(1320)
26.8
(950)
76
(170)
13.0
8.69
(3.83)
6.26
(2.76)
14.1
(31.2)
0.75
(1.51)
Average
120
16.4
(18.1)
37
(1310)
26.8
(950)
74
(166)
12.8
4*38
(1.93)
3.17
(1.40)
7.1
(15.8)
0.41
(0.82)
(Data not determined)
C-6
-------
Table C-2. FACILITY A - FIRST SET OF TESTS
SUMMARY OF RESULTS - BAGHOUSE OUTLET
Run Number
Date
Test Time-Minutes
AS Production Rate - Mg/hr
(TPH)
Stack Gas Data
Flow rate - acm/min
(acfm)
Flow rate - dscm/min
(dscfm)
Temperature - °C
(°F)
Water vapor - Vol. %
1
9/12/78
120
15.8
(17.4)
35.5
(1260)
27.6
(980)
55
(131)
2
9/12/78
120
14.9
(16.4)
34.4
(1220)
26.8
(950)
59
(139)
3
9/13/78.
120
18.7
(20.6)
33.6
(1190)
26.2
(930)
58
(138)
Average
120.
16.4
(18.1)
34.5
(1223)
26.9
(955)
57
(136)
13.7
11.8
12.3
12.6
Particulate Emissions
Probe and Filter Catch
gm/dscm
(gr/dscf)
gm/acm
(gr/acf)
kg/hr
(Ib/hr)
kg/Mg
(Ib/ton)
Total Catch
gm/dscm
(gr/dscf)
gm/acm
(gr/acf)
kg/hr
(Ib/hr)
kg/Mg
(Ib/ton)
0.063
(0.028)
0.049
(0.022)
0.109
(0.24)
0.007
(0.014)
0.192
(0.085)
0.149
(0.066)
0.318
(0.70)
0.021
(0.043)
0.211
(0.093)
0.165
(0.073)
0.336
(0.74)
0.018
(0.036)
0.155
(0.069)
0.122
(0.054)
0.254
(0.56)
0.015
(0.031)
(Data not determined)
C-7
-------
Table C-2 (continued). FACILITY A - FIRST SET OF TESTS
SUMMARY OF RESULTS - BAGHOUSE OUTLET
Baflhouse Particulate
Removal Efficiency
Visible Emissions
S5 percent opacity, minutes
observed
0 percent opacity, minutes
observed
No visible emissions,
minutes observed
97.2
0
0
120
91.1
0
0
120
97.6
0
0
120
95.3
C-8
-------
Table C-3. FACILITY A - SECOND SET OF TESTS
SUMMARY OF RESULTS - BAGHOUSE OUTLET
Run Number
Date "f
Test Time-Minutes
AS Production Rate - Mg/hr
'^ W (TPH)
Stack Gas Data •
Flow rate - acm/min
(acfm)
Flow rate - dscm/min
: ;(dscfm)
Temperature - °C
(°F)
Water vapor - Vol. %
Particulate Emissions
Probe and Filter Catch
gm/dscm
(gr/dscf)
gm/acm
(gr/acf)
(Ib/ton). -.,-.-.•,.-
gm/dscm
(gr/dscf)
gm/acm
(gr/acf)
kg/hf
(Ib/hr)
kg/Mg
(Ib/ton)
.10/26/78
60
13.6
(15.0)
39.2
(1390)
33.8
(1200).
45
(114)
7.3
0.036
(0.016)
0.031
(0.014)
(0-.I6X
0^0-05
(0.011)
,i; . . ...
"•.-.••-. •'- •
2
10/26/78
60
13.6
(15.0).
38.9
(1380)
31.9
(1130)
45
(114)
11.6
0.052
(0.023)
0.043
(0.019)
, CO^Z33w;
(0.015>,
(Data not
•• . . . 3
10/26/78,
60
14.18
(15.6)
38.7
(1370)
32.2
(1140)
49
(121)
9.6
0.059
(0.026)
0.049
(0.022)
... €0:^251-
- (0,016>V
determined)
,•- -
Average
60 ;
13.9
(15.4)
38.9
(1380)
32.6
(1157)
46
(116)
9.5
0.049
(0.022)
0.040
(0.018)
^*-21X;
: CK009"
(0.014)
C-9
-------
Table C-3 (continued). FACILITY A - SECOND SET OF TESTS
Table C j uontinuecu guMMARY QF RESULTS _ MGHOUSE OUTLET
Baghouse Particulate
Removal Efficiency
Visible Emissions
<5 percent opacity, minutes
observed
0 percent opacity, minutes
observed.
No visible emissions,
: minutes observed
0
0
0
0
0
0
60
60
60
98. T
afiased on average inlet pounds per hour measured in the earlier tests
(Table C-l) and the average outlet pounds per hour derived from this
set of tests..
-C-10
-------
Table C-4. FACILITY B
SUMMARY OF RESULTS - "SCRUBBER INLET
Run Number
Date
Test Time-Minutes
AS Capacity* - Mg/hr
(TPH)
Dryer Vent Gas Data
Flow rate - acm/min
(acfm)
Flow rate - dscm/min
(dscfm)
Temperature - °C
(°F)
Water vapor - Vol. %
Particulate Emissions
Probe and Filter Catch
gm/dscm
(gr/dscf)
gm/acm
(gr/acf)
kg/hr
(lb/hr)
kg/Mg
(Ib/ton)
1
10/3/78
120
26.5
(29.2)
1500
(53,100)
1214
(43,000)
83
(182)
3.5
39.7
(17.5)
2927
(6,440)
110.5
(221)
2
10/4/78
120
26.5
(29.2)
1491
(52,800)
1194
(42,300)
86
(188)
3.7
37.4
(16.5)
2713
(5,970)
102
- (204)
3
10/4/78
120
26.5
(29.2)
1494
(52,900)
1192
(42,200)
86
(188)
4.0
40.1
(17.7)
2913
(6,410)
114.5
(229) :-
Average
120
26.5
(29.2)
1494
(52,900)
1200
(42,500)
85
(186)
3.7
39.0
(17.2)
2850
(6,270)
110.5
(221)
*Plant B was operating close to capacity at the time of testing.
production rate is held company-confidential.
Actual
C-ll
-------
Table C-4 (continued). FACILITY B
SUMMARY OF RESULTS - SCRUBBER INLET
Total Catch
gm/dscm
(gr/dscf)
gra/acm
(gr/acf)
kg/hr
(Ib/hr)
kg/Mg
(Ib/ton)
39.7
(17.5)
37.4
(16.5)
40.1
(17.7)
39.0
(17.2)
2927
(6,440)
110.5
(221)
2713
(5,970)
102
(204)
2913
(6,410)
114.5
(229)
2850
(6,270)
110.5
(221)
C-12
-------
Table C-5. FACILITY B
SUMMARY OF RESULTS - SCRUBBER OUTLET
Run Number
Date
Test Time-Minutes
AS Capacity* - Mg/hr
(TPH)
Stack Gas Data
Flow rate - acm/min
(acfm)
Flow rate - dscm/min
(dscfm)
Temperature - °C
(°F)
Water vapor - Vol. %
Particulate Emissions
Probe and Filter Catch
.gm/dscm
(gr/dscf)
gm/acm
(gr/acf)
kg/hr
(Ib/hr)
kg/Mg
(Ib/ton)
Total Catch
gm/dscm
(gr/dscf)
gm/acm
(gr/acf)
kg/hr
(Ib/hr)
kg/Mg
(Ib/ton)
*Plant B was operating close to capacity at the time of testing.
production rate is held company-confidential,
C-13
1
10/3/78
120
26.5
(29.2)
1646
(58,300)
1443
(51,100)
40
(105)
6.1
0.038
(0.017)
0.034
(0.015)
3.40
(7.50)
0.13
(0.26)
0.408
(0.018)
3.61
(7.96)
0,13
(0.27)
2
10/4/78
120
26.5
(29.2)
1629
(57,700)
1418
(50,200)
43
(110)
6.1
0.018
(0.008)
0.015
(0.007)
1.62
(3.58)
0.06
(0.12)
0.022
(0.010)
1.87
(4.13)
0.07
(0.14)
3
10/4/78
120
26.5
(29.2)
1644
(58,200)
1440
(51,000)
40
(104)
6.4
0.072
(0.032)
0.063
(0.028)
6.45
(14.2)
0.24
(0.49)
0.081
(0.036)
7.13
(15.7)
0.27
(0.54)
Average
120
26.5
(29.2)
1641
(58,100)
1435
(50,800)
41
(106)
6.2
0.043
(0.019)
0.038
(0.017)
3.83
(8.43)
0.14
(0.29)
0.047
(0.021)
4.20
(9.26)
0.15-6
(0.32)
Actual
-------
Table C-5 (continued)
SCRUBBER OUTLET
Scrubber Particulate
Removal Efficiency
Visible Emissions^
<_ 15 percent opacity,
minutes observed
<_ 10 percent opacity,
~~ minutes observed
<_ 5 percent opacity,
~~ minutes observed
0 percent opacity,
minutes observed
99.9
27
93
99.9
99.8
99.9
30
90
38
82
C-1A
-------
Table C-6. FACILITY C
SUMMARY OF RESULTS - SCRUBBER INLET
Run Number
Date
Test Time-Minutes
AS Production Rate
Mg/hr
(TPH)
Dryer Vent Gas Data
Flow rate - acm/min
(acfm)
Flow rate - dscm/min
(dscfm)
Temperature - °C
(°F)
Water vapor - Vol. %
Particulate Emissions
1000
6.09
(16.7)
131.4
(4654)
99.9
(3537)
84
(184)
7.2
30
6.09
(16.7)
131.8
(4666)
92.9
(3290)
82
(181)
14.2
Probe and Filter Catch
gm/dscm
(gr/dscf)
gm/acm
(gta/acm)
kg/hr
(Ib/hr)
kg/Mg
(Ib/ton)
Total Catch
gm/dscm
(gr/dscf)
gm/acm
(gr/acf)
kg/hr
(Ib/hr)
kg/Mg
(Ib/ton)
11.39
(5.02)
8.64
(3.81)
69.1
(152.2)
4.55
(9.11)
6.35
(2.80)
4.47
(1.97)
3.58
(7.89)
2.56
(4.72)
(Data no
3*
Average
,65
6.09
(16.7)
131.5
(4660)
96.4
(3414)
83
(183)
10.7
8.87
(3.91)
6.56
(2.89)
52.5
(115.6)
3.46
(6.92)
*Results of this run not included due to non-isokinetic sampling
C-15
-------
Table C-7.
FACILITY C
SUMMARY OF RESULTS
SCRUBBER OUTLET
Run Number
Date
Test Time-Minutes
AS Production Rate - Mg/hr
(TPH)
Stack Gas Data
Flow rate - acm/min
(acfm)
Flow rate - dscm/min
(dscfm)
Temperature - °C
Water vapor - Vol. %
ParticulatP Emissions
Probe and Filter Catch
gm/dscm
(gr/dscf)
gm/acm
(gr/acf)
kg/hr
(Ib/hr)
kg/Mg
(lb/ton)
Total Catch
gm/dscm
(gr/dscf)
gm/acm
(gr/acf)
kg/hr
(Ib/hr)
kg/Mg
(lb/ton)
12/6/78
60
15.1
(16.7)
121
(4313)
97
(3436)
60
(140)
9.6
0.155
(0.0686)
0.124
(0.0547)
0.90
(2.0)
0.06
(0.12)
C-16
2
12/6/78
60
15.1
(16.7)
120
(4255)
93
(3304)
60
(140)
11.9
0.256
(0.1132)
0.199
(0.0879)
1.45
(3.2)
0.095
(0.19)
(Data not
3
12/6/78
60
15.1
(16.7)
119
(4245)
ioo
(3542)
57
(136)
6.2
0.208
(0.0918)
0.173
(0.0766)
1.27
(2.8)
0.085
(0.17)
determined)
Average
60
15.1
(16.7)
120
(4271)
96
(3427)
59
(139)
9.2
i
0.206
(0.091)
0.165
(0.073)
1.22
(2.7)
O.Q8
(0.16)
!
1
^m^m
-------
Table C-7 (continued).
Scrubber Particulate
Removal Efficiency
Visible Emissions
10-15 percent opacity,
minutes observed
£10 percent opacity,
minutes observed
98.7
FACILITY C
SUMMARY OF RESULTS
SCRUBBER .OUTLET
95.9
60
_*
97.3
--**
60
*Run No. 3 did not produce usable inlet data
**No opacity data obtained due to darkness
C-17
-------
Table C-8. FACILITY D
SUMMARY OF RESULTS - SCRUBBER INLET
Run Number
Date
Test Time-Minutes
AS Production Rate
Mg/hr
(TPH)
1*
12/12/78
__
—
—
—
__ .
—
—
—
—
__
2 3**
12/12/78 12/13/78
110
8.4 8.4
(9.3) (9.3)
131
(4652)
102
C3612)
81
(178)
7.4
103.23
(45.48)
80.15
(35.31)
640
(1408)
75.5
(151)
4
12/13/78
50
8.4
(9.3)
143
(5092)
113
(3994)
82
(181)
6.1
95.45
(42.05)
74.93
(33.01)
654
(1439)
77.5
(155)
Dryer Vent Gas Data
Flow rate - acm/min
(acfm)
Flow rate - dscm/min
(dscfm)
Temperature - °C
(°F)
Water vapor - Vol. %
Particulate Emissions
Probe and Filter Catch
gm/dscm
(gr/dscf)
gm/acm
(gr/acf)
kg/hr
(Ib/hr)
kg/Mg
(Ib/ton)
Total Catch
gm/dscm
(gr/dscf)
gm/acm
(gr/acf)
kg/hr
(Ib/hr)
kg/Mg
(Ib/ton)
*p,in Nr> 1 aborted due to test difficulties
**Run No! 3 data found to be invalid due to leak in sampling equipment
(Data not determined)
Average
80
8.4
(9.3)
137
(4872)
107
(3803)
82
(180)
6.8
98.29
(43.3)
77.63
(34.2)
647
(1424)
76.5
(153)
C-18
-------
Table C-9. FACILITY D
SUMMARY OF RESULTS - SCRUBBER OUTLET
Run Number
Date
Test Time-Minutes
AS Production
Stack Gas Data
Flow rate -
Flow rate -
Temperature
Water vapor
Rate - Mg/hr ,
(TPH)
acm/min
(acfm)
dscm/min
(dscm)
- °C
- Vol. %
1
12/12/78
1 OA
JL4.Q
8.45
(9.3)
131
(4663)
113
(4027)
/ c
45
(114)
7.4
2
12/12/78
120
8.45
(9.3)
124
(4399)
108
(3830)
43
(111)
7.1
3
12/13/78
120
8.45
(9.3)
139
(4929)
120
(4256)
45
(114)
7.1
Particulate Emissions
Probe and Fi
gm/dscm
(gr/dscf)
gin/ a cm
(gr/acf)
kg/hr
(lb/hr)
kg/Mg
(Ib/ton)
Total Catch
Iter Catch
OT "7 f\
• 179
(0.079)
0.154
(0.068)
1 22
(2.7)
0.145
(0.29)
0.118
(0.052)
0.102
(0.045)
0.77
(1.7)
0.09
(0.18)
0.254
(0.122)
0.238
(0.105)
2.04
(4.5)
0.24
(0.48)
Average
120
8.45
(9.3)
131
(4664)
114
(4038)
45
(113)
7.4
0.190
(0.084)
0.165
(0.073)
1.36
(3.0)
0.158
(0.32)
gm/dscm
(gr/dscf)
gm/acm
(gr/acf)
kg/hr
(lb/hr)
kg/Mg
(Ib/ton)
(Data not determined)
C-19
-------
Table C-9 (continued). FACILITY D
SUMMARY OF RESULTS
SCRUBBER OUTLET
Scrubber Particulate
Removal Efficiency
Visible Emissions
0 percent opacity,
minutes observed
120
99.9
120
99.9
120
*Inlet data not
available with which to calculate scrubber efficiency
C-20
-------
Table C-10. FACILITY E
SUMMARY OF RESULTS - SCRUBBER OUTLET*
Run Number
Date
Test Time-Minutes
AS Production Rate - Mg/hr
(TPH)
Dryer Vent Gas Data
Flow Rate - acm/min
(acfm)
Flow Rate - dscm/min
(dscfm)
Temperature - °C
(°F)
Water Vapor - Vol. %
Particulate Emissions
Probe and Filter Catch
gm/dscm
(gr/dscf)
gm/acm
(gr/acf)
. kg/hr
(Ib/hr)
kg/Mg
(Ib/ton)
Total Catch
gm/dscm
(gr/dscf)
gm/acm
(gr/acf)
kg/hr
(Ib/hr)
kg/Mg
(Ib/ton)
1
8/9/77
80
8.9
(9.8)
395
(13,974)
345
(12,197)
46
(115)
5.7
0.0928
(0.0409)
0.0814
(0.0359)
1.95
(4.28)
0.22
(0.44)
2
8/9/77
64
8.9
(9.8)
398
(14,079)
377
(13,338)
46
(115)
5.3
0.0538
(0.0237)
0.0472
(0.0208)
1.14
(2.51)
0.13
(0.26)
3
8/9/77
64
8.9
(9.8)
390
(13,807)
342
(12,116)
46
(116)
5.1
0.0261
(0.0115)
0.0232
(0.0102)
0.54
(1.19)
0.06
(0.12)
Average
69
8.9
(9.8)
390
(13,953)
355
(12,550)
46
(115)
5.4
0.0577
(0.0254)
0.0501
(0.0223)
1.21
(2.66)
0.14
(0.2.7)
(Data not determined)
C-21
-------
Table C-10 (.continued). FACILITY E
SUMMARY OF RESULTS -
SCRUBBER OUTLET
Scrubber Particulate
Removal Efficiency
Visible Emissions^
(Data not available with which to calculate)
(Data not determined)
*This test was done by the company test contractor.
- C-22
-------
Table C-ll. FACILITY B
SUMMARY OF RESULTS - CAPROLACTAM
CONCENTRATIONS AND EMISSION RATES
SCRUBBER INLET
Run Number
Date
Test Time-Minutes
AS Capacity* - Mg/hr
(TPH)
Stack Effluent
Flow rate - acm/min
(acfm)
Flow rate - dscm/min
(dscfm)
Temperature - °C
(°F)
Water vapor - Vol. %
Caprolactam Emissions
Probe and Filter Catch
ppm
kg/hr
(Ib/hr)
kg/Mg
(Ib/ton)
Total In Vapor Phase
ppm
kg/hr
(Ib/hr)
kg/Mg
(Ib/ton)
1
10/3/78
120
26.5
(29.2)
1497
(53,000)
1214
(43,000)
83
(182)
3.5
1.90
0.65
(1.44)
0.024 .
(0.049)
49.9
17.18
(37.8)
0.65
(1.30)
2
10/4/78
120
26.5
(29.2)
1491
(52,800)
1194
(42,300)
86
(188)
3.7
4.67
1.58
(3.48)
0.059
(0.119)
60.3
20.45
(45.0)
0.77
(1.54)
3
10/4/78
120
26.5
(29.2)
1494
(52,900)
1192
(42,200)
86
(188)
4.0
<0.35 ;
<0.118
(0.26)
<0.004
(0.009)
63.3
21.45
(47.2)
0.81
(1.62)
Average
120
26.5
(29.2)
1494
(52,900)
1200
(42,500)
85
(186)
3.7
3.29
1.118
(2.46)
0.042
(0.084)
57.8
19.68
' (43.3)
0.74
(1.49)
*Plant B was operating close to capacity at the time of testing.
production rate is held company-confidential.
Actual
C-23
-------
1
10/3/78
120
26.5
(29.2)
2
10/4/78
120
26.5
(29.2)
3
10/4/78
120
26.5
(29.2)
Average
120
26.5
(29.2)
1646
(58,300)
1443
(51,100)
40
(105)
6.1
1629
(57,700)
1418
(50,200)
43
(110)
6.1
1644
(58,200)
1440
(51,000)
40
(104)
6.4
1641
(58,100)
1435
(50,800)
41
(106)
6.2
Table 0-12. FACILITY B
SUMMARY OF RESULTS - CAPROIACTAM
CONCENTRATIONS AND EMISSION RATES
SCRUBBER OUTLET
Run Number
Date
Test Time-minutes
AS Capacity* - Mg/hr
(TPH)
Stack Effluent
Flow rate - acm/min
(acfm)
Flow rate - dsctn/min
(dscfm)
Temperature - °C
(°F)
Water vapor - Vol. %
Caprolactam Emissions
Probe and Filter Catch
ppm
kg/hr
(Ib/hr)
kg/Mg
(Ib/ton)
Total In Vapor Phase
ppm
kg/hr
(Ib/hr)
kg/Mg
(Ib/ton)
*Plant B was operating close to capacity at the ti*e of testing.
production rate is held company-confidential.
0.201
0.082
(0.181)
0.003
(0.006)
0.26
< 0.104
(0.28)
< 0.004
(0.008)
0.28
<0.113
(0.25)
< 0.0045
(0.009)
0.201
0.082
(0.181)
0.003
(0.006)
5.64
6.89
8.23
6.92
2.31
(5.09)
0.087
(0.174)
2.77
(6.10)
. 0.104
(0.209)
3.36
(7.40)
0.126
(0.253)
2.81
(6.20)
0.106
(0.212)
Actual
C-24
-------
Table C-13. AMMONIUM SULFATE PARTICLE SIZE
DISTRIBUTION ANALYSIS
Facility: A
Date: 9/13/78
Sampling Method: Anderson Cascade Impactor
Plate No.
1
2
3
4
5
6
7
8
Back-up
Filter
Total
Effective
Diameter,
Microns
9.5
6.0
4.0
2.72
1.72
0.87
0.83
0.35
Net Wt-.
mg.
45.7
3.7
1.8
1.0
1.5
0.8
0.8
1.3
0.8
57.4
Weight
Percent
79.6
6.4
3.2
1.7
2.6
1.4
1.4
2.3
1.4
100
Cumulative
Wt. Percent
100
20.3
13.9
10.8
9.1
6.5
5.1'
3.7
1.4
C-25
-------
Table C-14. AMMONIUM SULFATE PARTICLE
SIZE DISTRIBUTION ANALYSIS
Facility: B
Date: 10/4/78
Sampling Method: Brinks Cascade Impactor
Impactor
Fraction
.
Cyclone
Stage 1
Stage 2
Stage 3
Stage 4
Stage 5
Back-up
Filter
Total
Range of
Effective
Diameter
Microns
____———— — ___«_^—
>8.04
2.74-8.04
1.62-2.74
1.10-1.62
0.58-1.10
0.36-0.58
<0.36
_ — — . _
Size Distribution by Weight
Net Wt. Cumulative
(mg) Percent Percent
289.2 99.3 100
2.0 0.7 0.7
<0.1 <0.1 <0.1
-------
Table C-15. AMMONIUM SULFATE PARTICLE
SIZE DISTRIBUTION ANALYSIS
Facility: C
Date: 12/6/78
Sampling Method:
Anderson Cascade Impactor
Plate No.
1
2
3
4
5
6
7
8
Back-up
Filter
Total
Effective
Diameter,
Microns
_>11.8
7.49
4.94
3.42
2.18
1.11
0.67
0.45
<0.45
..
Net Wt.
mg:
450.4*
200.8
818.3
253.4
42.2
56.0
11.5
11.5
31.3
1875.4
Weight
Percent
24.0
10.7
43.6
13.5
2.3
3.0
0.6
0.6
1.7
Cumulative
Wt. Percent
100.0
76.0
65.3
21.7
8.2
5.9
2.9
2.3
1.7
*Weight includes particulate collected in Plate No. 0 and in
nozzle and head of sampler up stream of the collection plates.
C-27
-------
Table C-16. AMMONIUM SULFATE PARTICLE
SIZE DISTRIBUTION ANALYSIS
Facility: D
Date: 12/13/78
Sampling Method: Anderson Cascade Impactor
Plate No.
1
2
3
4
5
6
7
8
Back-up
Filter
Total
Effective
Diameter,
Microns
>14.73
9.28
6.15
4.26
2.11
1.40
0.85
0.58
<0.58
Net Wt.
mg.
157.3
789.5
1271.6
413.8
71.2
13.2
0.5
0.0
0.3
2717.4
Weight
Percent
5.8
29.1
46.8
15.2-
2.6
0.5
0.0
0.0
0.0
Cumulative
Wt. Percent
100.0
94.2
65.1
18.3
3.1
0.5
0.0
0.0
0.0
C-28
-------
Table C-17. PLANT A
a. Summary of visible emissions
Date
Type of Plant
Type of Discharge
Location of Discharge
Height of Discharge Point (ft)
Distance from Observer to
Discharge Point (ft)
Height of Observation Point (ft)
Direction of Observer from
Discharge Point
Description of Background
Description of Sky
Wind Direction
Wind Velocity (mph)
Color of Plume
Detached Plume
Duration of Observation (hrs)
Test 1
10/26/78
Ammonium
sulfate
Stack
Baghouse
outlet
45
25
25
NE
Solid
gray
building
Partly
cloudy
10-15
a
a
1
Test 2
10/26/78
Ammonium
sulfate
Stack
Baghouse
outlet
45
25
25
NE
Solid
gray '
building
Partly
cloudy
10-15
a
a
1
Test 3
10/26/78
Ammonium
sulfate
Stack
Baghouse
outlet
45
25
25
NE
Solid
gray
building
Partly
cloudy
10-15
a
a
1
Plume was not visible
C-29
-------
Table C-17. PLANT A (Concluded)
b. Summary of average
opacity
Time
Date
TEST 1
10/26/78
TEST 2
10/26/78
TEST 3
10/26/78
Set number
1
2
3
4
5
6
7
8
9
10
1
2
3
4
5
6
7
8
9
10
1
2
3
4
5
6
7
8
9
10
Start
8:50
8:56
9:02
9:08
9:14
9:20
9:26
9:32
9:38
9:44
10:44
10:50
10:56
11:02
11:08
11:14
11:20
11:26
11:32
11:38
12:22
12:28
12:34
12:40
12:46
12:52
12:58
1:04
1:10
1:16
End
8:56
9:02
9:08
9:14
9:20
9:26
9:30
9:38
9:44
9:50
10:50
10:56
11:02
11:08
11:14
11:20
11:26
11:32
11:38
11:44
12:28
12:34
12:40
12:46
12:52
. 12:58
1:04
1:10
1:16
1:22
Opacity
Sum
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Average
0
0
0
'0
0
0
'0
0
0
0
0
0
0
: o
0
: o
; o
0
0
0
1 0
0
0
0
1 0
0
0
0
; o
0
C-30
-------
Table C-18. PLANT B
a. Summary of visible emissions
Date
Type of Plant
Type of Discharge
Location of Discharge
Height of Discharge Point (ft)
Distance from Observer to Discharge
Point (ft)
Height of Observation Point (ft)
Direction Observer from Discharge
Point
Description of Background
Description of Sky
Wind Direction
Wind Velocity (mph)
Color of Plume
Detached Plume
Duration of Observation (hrs)
Test 1
10/3/78
Ammonium
Sulfate
Stack
Scrubber
Outlet
55
250
0
105°E
Green
elevator
shaft
Overcast
125°SE
5
White
No
3
Test 2
10/4/78
Ammonium
Sulfate
Stack
Scrubber
Outlet
55
60
55
SE
Green
elevator
shaft
Hazy
NE
10
White
No
2.3
Test 3
10/4/78
Ammonium
Sulfate
Stack
Scrubber
Outlet
55
250
0
105°E
Green
elevator
shaft
Hazy;
partly
cloudy
45°NE
5-10
White
No
2
C-31
-------
Table C-18. PLANT B (Continued)
b . Summary
Date Set number
TEST 1
10/3/78 1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20 '
21
22
23
24
25
26
^ W
27
^> /
28
29
£• .7
30
of average
opacity
Time
Start
3:15
3:21
3:27
3:33
3:39
3:45
3:51
3:57
4:03
4:09
4:15a
4:21
4:27b
4:33
4:39
4:45
4:51
4:57
5:03
5:09
5:15
5:21
5:27
6:00
6:02
6:08
6:14d
6:20
6:26
6:32
6:38
End
3:21
3:27
3:33
3:39
3:45
3:51
3:57
4:03
4:09
4:15
4:21
4:27
4:33
4:39
4:45
4:51
4:57
5:03
5:09
5:15
5:21
5:27
5:31C
6:02
6:08
6:14
6:20
6:26
6:32
6:38
6:44
Opacity
i
i
Sum Average
60.00
60.00
60.00
60.00
60.00
60.00
60.00
60.00
60.00
60.00
60.00
60.00
60.00
60.00
60.00
60.00
60.00
60.00
60.00
60.00
60.00
60.00
60.00
60.00
60.00
75.0
90.0
88.75
90.0
90.0
1
10.00
10.00 ,
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
io.oo!
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
12.50
15.0
14.79
15.0
15.0
started at 4:15.
Rain stopped at 4:40.
System down. Wind velocity between 0-5 mph.
direction changed to NW.
C-32
-------
Table C-18. PLANT, B (Continued)
Date Set number
TEST 2
10/4/78 1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
: '20
21
22
23
TEST 3
10/4/78 1
2
3
4
5
6
7
8
9
10
Time
Start
8:40
8:46
8:52
-8:58
9:04
9:10
9:16
9:22
9:28
9:34
9:40
9:46
9:52
9:58
6:04
6:10
6:16
6:22
6:28
6:34
6:40
6:46
6:52
2:15
2:21
2:27
2:33
2:39
2:45
3:26
3:31
3:37
3:43
End
8:46
8:52
8:58
9:04
9:10
9:16
9:22
9:28
9:34
9:40
9:46
9:52
9:58
6:04
6:10
6:16
6:22
6:28
6:34
6:40
6:46
6:52
6:58
2:21
2:27
2:33
2:39
2:45
2:51
3:30
3:37
3:43
3:49
Opacity "
Sum
28.75
30.00
25.00
20.00
15.00
23.75
11.25
17.50
12.25
' 1.25
2.50
0
2.50
2.50
3.75
0
1.25
0
2.50
3.75
0
3.75
10.00
57.50
67.50
60.00
60.00
60.00
57.50
52.50
30.00 .
30.00
30.00
Average
4.79
5.00
4.16
3.33
2.50
3.95
1.87
2.91
2.04
0.20
0.41
0
0.41
0.41
0.62
0
0.20
0
0.41
0.62
0
0.62
1.66
9.58
11.25
10.00
10.00
10.00
9.58
8.75
5.00
5.00
5.00
C-33
-------
Table C-18. PLANT B (Concluded)
Date
Set number
Time
Start
End
Opacity
Sum
Average
TEST 3 (Continued)
11
12
13
15
16
17
18
19
20
3:49
3:55
4:01
4:07
4:13
4:19
4:25
4:31
4:37
4:43
3:55
4:01
4:07
4:13
4:19
4:25
4:31e
4:37
4:43
4:49
30.00
30.00
30.00
30.00
30.00
30.00
30.00
30.00
30.00
30.00
5.00
00
00
00
00
00
00
,00
5.00
5.00
direction changed to SE at 4:30.
.C-34
-------
Table C-19. PLANT C
a. Summary of visible emissions
Date
Type of Plant
Type of Discharge
Location of Discharge
Height of Discharge Point (ft)
Distance of Observer to Discharge Point (ft)
Height of Observation Point (ft)
Direction, of Observer from Discharge Point
Description of Background
Description of Sky
Wind Direction
Wind Velocity (mph)
Color of Plume
Detached Plume
Duration of Observation (hrs)
Test 1
12/6/78
(NH4)2S04
Outlet
50
200
0
S
Skya
Clear
NW
10-20
White
No
1
Test 2
12/6/78
(NH4)2S04
Outlet
50
200
0
S '
Sky
Clear
NW
10-25
White
No
1
Some interference from cooling tower in background.
C-35
-------
Table C-19. PLANT C (Concluded)
— _
b. Summary
of average
opacity
Time
Date
TEST 1
12/6/78
TEST 2
12/6/78
Set number
1
2
3
4
5
6
7
8
9
10
1
2
3
•J
4
5
—/
A
\J
7
8
g
?
10
Start
10:37
10:43
10:49
10:55
11:01
11:07
11:13
11:19
11:25
11:31
2:54
3:00
3:06
3:12
3:18
3:24
3:30
3:36
3:42
3:48
End
10:43
10:49
10:55
11:01
11:07
11:13
11:19
11:25
11:31
11:37
3:00
3:06
3:12
3:18
3:24
3:30
3:36
3:42
3:48
3:54
Opacity
Sum
42.5
50.0
55.0
67.5
50.0
55.0
42.5
47.5
52.5
60.0
45.0
75.0
70.0
70.0
70.0
77.5
67.5
75.0
60.0
67.5
Average
7.08
8.33
9.16
11.25
8.33
9.16
7.08
7.91
8.75
10.00
7.5
12.5
11.66
11.66
11.66
12.9
11.25
12.5
10.0
11.25
C-36
-------
Table C-20. PLANT D
a. Summary of
Date
Type of Plant
Type of Discharge
Location of Discharge
Height of Discharge Point (ft)
Distance from Observer to Discharge
Point (ft)
Height of Observation Point (ft)
Direction of Observer from Discharge
Point
Description of Background
Description of Sky,
Wind Direction
Wind Velocity (mph)
Color of Plume
Detached Plume
Duration of Observation (hrs)
visible emissions
Test 1
12/12/78
Ammonium
sulfate
Outlet
20
150
0
SE
Sky
Gray
Clouds
SE
0-20
White
No
2
Test 2
12/12/78
Ammonium
sulfate
Outlet
. 20
150
0
SE
Sky
Gray
Clouds
S
10-20
White
No
1.5
Test 3
12/13/78
Ammonium
sulfate
Outlet
20
150
0
SE
Sky
Blue w/
Clouds
S
0-10
White
No
2.9
Test 4
12/13/78
Ammonium
sulfate
Outlet
20
150
0
SE
Sky
Clear
Blue
S
0-15
White
No
0.4
C-37
-------
Table C-20. PLANT D (Continued)
Date
TEST 1
12/12/78
TEST 2
12/12/78
b. Summary of
i1
Set number
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
average
opacity
Time
Start
12:30
12:36
12:47
12:59
1:05
1:11
1:17
1:23
1:29
1:35
1:41
1:47
1:53
1:59
2:05
2:11
2:17
2:23
2:29
2:35
3:40
3:46
3:52
3:58
4:04
4:10
4:16
4:22
4:28
4:34
4:40
4:46
4:52
4:58
5:04
End
12:36
12:42
12:53
1:05
1:11
1:17
1:23
1:29
1:35
1:41
1:47
1:53
1:59
2:05
2:11
2:17
2:23
2:29
2:35
2:41
3:46
3:52
3:58
4:04
4:10
4:16
4:22
4:28
4:34
4:40
4:46
4:52
4:58
5:04
5:10
i
Opacity
Sum
2.5
17.5
9.0
12.5
12.5
10.0
2.5
7.5
12.5
5.0
5.0
15.0
12.5
20.0
2.5
7.5
5.0
7.5
2.5
10.0
7.5
5.0
2.5 ~
7.5
5.0
5.0
10.0
7.5
5.0
5.0
2.5
2.5
10.0
2.5
2.5
Average
i „
0.41
2.91
1.50
2.08
2.08
1.66
0.41
1.25
2.08
0.83
0.83
2.50
2.08
3.33
0.41
1.25
0.83
1.25
0.41
1.66
1
I
1.25 ]
- 0.83
0.41
1.25
0.83
0.83
1.66
1.25
0.83
0.83
i
0.411
0.41
1.66
0.41
0.41
C-38
-------
Table C-20. PLANT D (Concluded)
Date Set number
TEST 3
12/13/78 1
2
3
4
5
6
7
8
9
10
11
12
13 '
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
TEST 4
12/13/78 1
2
3
4
Time
Start
8:48
8:54
9:00
9:06
9:12
9:18
9:24
9:30
9:36
9:42
9:48
9:54
10:00
10:06
10:12
10:18
10:24
10:30
10:36
10:42
10:48
10:54
11:00
11:06
11:55
12:01
12:07
12:13
12:19
2:37
2:43
2:49
2:55
End
8:54
9:00
9:06
9:12
9:18
9:24
9:30
9:36
9:42
9:48
9:54
10:00
' 10:06
10:12
10:18
10:24
10:30
10:36
10:42
10:48
10:54
11:00
11:06
11:12
12:01
12:07
12 : 13
12:19
12:25
2:43
2:49
2:55
3:01
Opacity
Sum
2.5
0
2.5
2.5
0
0
2.5
0
2.5
0
0
2.5
0
2.5
2.5
0
7.5
0
2.5
0
0
2.5
0
0
0
2.5
2.5
0
2.5
10.0
10.0
5.0
5.0
Average
0.41
0
0.41
0.41
0
0
0.41
0
0.41
0
0
0.41
0
0.41
0.41 •
0
1.25
0
0.41
0
0
0.41
0
0
0
0.41
0.41
0
0.41
1.66
1.66
0.83
0.83
C-39
-------
0.14
0.12
0.10
p
.8
CO U
CO U
0.08
•o
*§
U
0.06
m
0.04
0.02
Key
D Method 5 - Current EPA f)
^ Test
O Method 5 - Company Test
Average
€
€
BCD
Facility
0.308
0.204
0.220
0)
4J
"^
o) e
4>J Cd
oj *J
•3 w
O >^
0.132 w-S
rt t-i
PM a)
&
3
2
to
0.088
0.044
FIGURE C-1
CONTROLLED AS PARTICULATE EMISSIONS FROM EPA
EMISSION TESTS-CALCULATED GRAIN LOADINGS
C-40
-------
CO
Su
•rl O
CO 3
CO 13
•d o
e t-i
w a,
cu u-i
ce c
» o
U 4J
0)
o.
Key:
€
O
0.6
0.5
0.4
0.3
0.2
0.1
Method 5 - Current EPA Test
Method 5 - Company Test
Average
O
0.30
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0.10
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•
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w _ 0.06
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w "O 0.04
P-I 0
0.04A
FIGURE C-3
AVERAGE CONTROLLED AS GRAIN LOADING TEST DATA-
ERA METHOD 5
C-42 '
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0.5
0.4
(A
g
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05 3
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rt iH
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APPENDIX D
EMISSION MEASUREMENT AND CONTINUOUS MONITORING
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APPENDIX D. EMISSION MEASUREMENT AND CONTINUOUS MONITORING
D.I EMISSION MEASUREMENT METHODS
During the standard support study, for armonium sulfate manufac-
turing plants, EPA, conducted paniculate emission tests at four
facilities, one controlled with a baghouserand the other three with
scrubbers. There were three test runs before and after each control
system, and three test runs were repeated at the facility with the
baghouse. The tests were-run in accordance with EPA Mehtod 5 (40 CFR
Part 60 - Appendix A). Method 5 provides detailed procedures and
equipment criteria, and other considerations necessary to obtain
accurate and representative particulate emission data. Visible
Emission data were taken during the EPA tests in accordance with
Method 9 (40 CFR Part 60 - Appendix A),
Of the four facilities tested, technical problems existed, at
three of them. The facility with the baghouse had a very high outlet
emission rate due to some bags that were damaged. A decision was made
to repeat the test after the baghouse was rebagged. Two of the
facilities with scrubbers for controls had very high inlet loadings,
causing clogging of the sampling nozzle; normal testing times were
shortened to obtain samples.
D.2 MONITORING SYSTEMS
The opacity monitoring systems that are adequate for other
stationary sources, such as steam generators,-.covered by performance
specifications contained in Appendix B of 40 CFR 60 Federal Register.
October 6, 1975, are also technically feasible for ammonium sulfate
manufacturing plants except where condensed moisture is present in the
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exhaust stream. When wet scrubbers are used for emission reductions
i
from ammonium sulfate plants, in-stack continuous monitoring of
opacity is not applicable; EPA Method 9 would be required to deter-
mine opacity. Another parameter, such as pressure drop, would need
to be monitored in order to provide a continuous indicator of
emission control.
Equipment and installation cost for visible emission monitoring
are estimated to be about $18,000 to $20,000 per site. Annual oper- |
ating costs which include the recording and reducing the data, are
estimated at about $8,000 to $9,000 per site. Some savings in
operating costs may be achieved if multiple systems are used at a
given facility.
D.3 PERFORMANCE TEST METHODS
Consistent with the data base upon which the new source standards'
I
have been established, the recommended performance test method for
particulate matter is Method 5 (Appendix A, 40 CFR 60 - Federal j
Register), (December 23, 1971 as amended August 18, 1977). In order |
to perform Method 5, Methods 1 through 4 must be used.
Subpart A of 40 CFR 60 requires that affected facilities which |
are subject to standards of performance for new stationary sources
must be constructed so the sampling ports adequate for the performance
tests are provided. Platforms access, and utilities necessary to
perform testing at those ports must be provided.
D-2
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Sampling cost for performing a test consisting of three Method 5
runs is estimated to range from $5,000 to $9,000. If in-plant
personnel are used to conduct tests, the costs will be somewhat less.
The recommended performance test method for visible emission
is Method 9 (Appendix A, 40 CFR 60, Federal Register. November 12,
1974).
D-3
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APPENDIX E
ENFORCEMENT ASPECTS
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APPENDIX E. ENFORCEMENT ASPECTS
The recommended standard of performance will limit the emission
of AS participate matter from the AS dryer at new or modified AS pro-
duction plants. This standard can be defined either as a concentra-
tion or a mass emission limitation coupled with a visible emission
limitation. Compliance with either standard in a new plant can be
achieved by installation of a dry collection system (baghouse) or a
low-to-medijm-energy wet scrubber such as a venturi scrubber. Each
dryer is served by a separate control system. Aspects of enforcing
the AS dryer standards of performance are discussed below.
E.I PROCESS OPERATION
Factors affecting the level of uncontrolled AS particulate emis-
sions from the AS dryer include AS feed rate, gas velocity, the res-
idence time of the AS crystal, and its size distribution. Normally
these factors do not vary under steady state operation. Feed rate of
AS crystal to the dryer and crystal size distribution will be direct-
ly affected by upsets in upstream centrifuge and crystallizer opera-
tions, respectively. Monitoring of centrifuge drive current (direct-
ly affecting AS crystal feed rate to the dryer), and crystal!izer
liquor level, temperature and magma density and recirculation rate
(affecting crystal size distribution) would ensure normal process
operation during enforcement testing.
The process parameter that should be monitored to ensure that
the AS dryer is operated normally during enforcement tests is the
E-l
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dryer's process weight rate. Due to the lack of product weigh scales
in the industry, the process weight rate through the dryer is usually
not possible to determine directly.
A material balance computation based on the chemical reactions
i
used in the formation of ammonium sulfate is an acceptable method of
determining production rate since the formation reactions used in all
industrial sectors are quantitative and irreversible. If production'
rate is determined by material balance, the following equations shall
be used.
(1) For synthetic and coke oven by-product ammonium sulfate
plants, the ammonium sulfate production rate shall be determined
using the following equation:
p = AxBxCx 0.0808
|
where: ;
p = Ammonium sulfate production rate in megagrams per hour.
• ' • i .1
A = Sulfuric acid flow rate to the reactor/crystal!izer
in liters per minute averaged over the time period
taken to conduct the run.
i
B = Acid density (a function of acid strength and temperature)
in grams per cubic centimeter.
C - Percent acid strength in decimal form.
0.0808 = Physical constant for conversion of time, volume, and
mass units. ,
(2) For caprolactam by-product ammonium sulfate pi ants, the
ammonium sulfate production rate shall be determined using the
following equation:
P = [DxExFx (0.8612)] + [6 x H x I x (1.1620)]
E-2
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where:
P = Production rate of caprolactam by-product ammonium
sulfate in megagrams per hour.
D = Qximation ammonium sulfate process stream flow rate
in liters per minute averaged over the time period
taken to conduct the run.
E = Density of the process stream solution in grams per
liter.
F = Percent ammonium sulfate in the process solution in
decimal form.
G = Oleum flow rate to the rearrangement reaction in
liters per minute averaged over the time period
taken to conduct the run.
H = Density of oleum in grams per liter.
I = Equivalent sulfuric acid percent of the oleum in
" " ' decimal form.
0.8612 = Physical constant for conversion of time and mass units,
1.1620 = Physical constant for conversion of time and mass units,
E.2 DETERMINATION OF COMPLIANCE WITH A CONCENTRATION STANDARD
Determination of compliance with a concentration (grain loading)
standard involves measurement of particulate concentration in the
exit gas from a control device. Devices used to control particulate
emissions from the AS dryer normally exhaust their effluents to the
atmosphere through a stack. The methods specified in 40 CFR 60
(methods 1, 2, 3, 4, and 5) provide specific guidelines for the mea-
surement of particulate emissions from a stack. Use of these test
methods will yield weight and volumetric flow data needed to calculate
the concentration of particulate in the offgas.
E-3
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Unlike existing facilities which sometimes require deviation
from optimum sampling procedures due to physical limitations in the
emission discharge configuration, new facilities can and should be
designed to assure that optimum sampling conditions exist. For
example, the optimum sampling location is a distance equal to 8 or
more duct diameters downstream and 2 or more upstream from any
constriction, expansion or other element that might disturb the flow
pattern of the gas stream. Although the reference methods allow
deviation from these optimum criteria, new facilities should be
designed to ensure that the results from emission measurements are
as accurate and precise as possible. Furthermore, utility services
and sample access points can also be incorporated into the design of
new sources to facilitate sampling.
Sampling problems encountered, where emissions are exhausted
directly to the atmosphere, can be overcome by the use of stack
extensions. These extensions may be either temporary or permanent
and should be designed to conform as nearly as possible to optimum
sampling criteria. . .
Monitoring of AS dryer process weight rate is also required to
ensure that the dryer is operating at maximum rated capacity. This
can be determined by indirect methods as indicated in Section E.I.
E.3 DETERMINATION OF COMPLIANCE WITH A MASS EMISSION STANDARD
Determination of compliance with an AS mass emission standard
involves measurement of AS particulate concentration in the stack
gas from a control device, the volumetric stack gas flow rate and
E-4
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the process weight rate from the AS dryer. EPA test Methods 1
through 5 (40 CFR 60) yield data with which to determine particulate
concentration and volumetric flow rate. The AS process weight would
in most cases be determined indirectly (as indicated in Section E.I).
It has been found that indirect determination of process weight at
AS plants is accurate to within +5 percent. Therefore product weight
scale are not being required by the Regulation.
Requirements for optimum sampling procedures would be similar
to those described in Section E.2.
E.4 DETERMINATION OF COMPLIANCE WITH A VISIBLE EMISSION STANDARD
Due to the time and expense of performing quantitative emission
measurements via EPA Methods 1 through 5, this test does not provide
an economically feasible means of ensuring, on a day-to-day basis,
that AS emissions are within the prescribed grain loading limit. A
visible emission standard for AS particulate requires only an observer
who is trained in reading of visible emissions. Determination' of
visible emissions can usually be performed with a minimal preparation
and no prior notice to the owner. When promulgated with an AS partic-
ulate standard, a visible emission standard will assure that the
emission control devices continue to be properly maintained and
operated. All visible emission observations would be made in
accordance with the procedures established in EPA Method 9 for stack
emissions.
E-5
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E.5 EMISSION MONITORING REQUIREMENTS :
The recommended standards of performance do not require the
installation of continuous monitoring system to monitor the opacity
of the exit gas stream discharged into the atmosphere from the |
control device. Continuous opacity monitors range in cost from $5,000
to $7,000 with installation in the offgas stack ranging from one to
two times equipment cost.3 Continuous particulate monitors are still
under development by manufacturers of stack monitoring equipment.;
E.6 REFERENCES !
1 Information provided by Chevron Chemical Corp., Richmond, CaVif.
lf in a™nversat?on between Charles Moore and Marvin Drabkiri of
The MITRE Corporation, Metrek Division, on December \it is/».
9 Information provided by Dow Badische Corporation, Freeport, Texas,
2' n a conversion between Karl Coffman and Marvin Drabkin of The
MITRE Corporation, Metrek Division, on October 3, 197b.
3 Information provided by The MITRE Corporation, McLean, Va., in a
conveTsationbetween Alberto Sabadell and Marvin Drabkin of The
MITRE Corporation, Metrek Division, on March ZO, 19/y.
E-6
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1. REPORT NO.
EPA-450/3-79-034a
TECHNICAL REPORT DATA
(Please read Instructions on the n verse before comfit ting/
4. TITLE AND SUBTITLE
|3. RECIPIENT'S ACCESSION NO.
Ammonium Sulfate Manufacture-Background Informa-
tion for Proposed Emission Standards
5. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION RE.P~O~RT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Office of Air Quality Planning and Standards
Environmental Protection Agency
Research Triangle Park, N.C. 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. N.C. ?7711
5. REPORT DATE
December. 1979 (Datp nf_Issjjj
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-02-3061
13. TYPE OF REPORT AND PERIOD COVERED
Draft
14. SPONSORING AGENCY CODE
EPA/200/04
FARY NOTES
Standards of performance for the control of emissions from ammonium sulfate
manufacture plants are being proposed under the authority of Section 111 of the
Clean Air Act. -These standards would apply to new, modified, or reconstructed
facilities at caprolactum by-product, synthetic and coke oven by-product ammonium
sulfate manufacturing plants. This document contains background information,
environmental and economic impact assessments, and the rationale for the standards,
as proposed under 40 CFR Part 60, Subpart PP.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
Air Pollution
Pollution Control
Standards of performance
Ammonium sulfate manufacture plants
Caprolactum by-product plants
Fertilizer
8. DISTRIBUTION STATEMENT
Unlimited
EPA Form 2220-1 (Rev. 4-77) PREVIOUS EDITION is OBSOLETE
b.IDENTIFIERS/OPEN ENDED TERMS
Air Pollution Control
19. SECURITY CLASS (This Report)
Unclassified
>0. SECURITY CLASS (This page)
Unclassified
c. COSATI Field/Group
13 E
21. NO. OF PAGES
313
22. PRICE
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