& EPA
         United States
         Environmental Protection
         Agency
Office of Air Quality
Planning and Standards
Research Triangle Park, NC 27711
EPA-453/R-93-022
August 1993
         Chromium Emissions from

         Industrial Process Cooling

         Towers - Background Information

         for Proposed Standards
                 NESHAP

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CHROMIUM EMISSIONS FROM INDUSTRIAL PROCESS COOLING TOWERS-
       BACKGROUND INFORMATION FOR PROPOSED STANDARDS  .
                        August 1993
           U. S. Environmental Protection Agency
                Office of Air and Radiation
        Office of  Air Quality Planning and Standards
             Research Triangle Park, NC  27711

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                        TABLE  OF  CONTENTS
LIST OF FIGURES	    vn
LIST OF TABLES     	viii

CHAPTER 1.0  SUMMARY       	    1-1
             1.1   CONTROL  OPTIONS	    1-1
             1.2   ENVIRONMENTAL  IMPACT  ..........    1-3
             1.3   ECONOMIC IMPACT  	  .........    1-3

CHAPTER 2.0  .INTRODUCTION	    2-1
             2.1   BACKGROUND  AND AUTHORITY FOR
                   STANDARDS	    2-1
             2.2   SELECTION OF POLLUTANTS  AND
                   SOURCE CATEGORIES  	    2-5
             2.3   PROCEDURE FOR  DEVELOPMENT OF
                  •NESHAP	    2-6
             2.4   CONSIDERATION  OF COSTS  ...........    2-9
             2.5   CONSIDERATION  OF ENVIRONMENTAL
                   IMPACTS	.  .   2-10
             2.6   RESIDUAL RISK  STANDARDS	  .   2-11

.CHAPTER 3.0  INDUSTRIAL PROCESS  COOLING TOWERS  	    3-1

             3 .1   GENERAL	    3-1
             3.2   DEFINITION  OF  SOURCE  CATEGORY  .•.  .  .  .    3-1
             3.3   INDUSTRIAL  COOLING SYSTEM COMPONENTS  .  .    3-2
                   3.3.1 Cooling Tower	    3-2
                   3.3.2 Heat Exchangers and Cooling
                         Water Cycle	    3-6
             3.4   CHEMICAL TREATMENT PROGRAMS 	  .    3-8
                   3.4.1 Purpose	'	    3-8
                   3.4.2 Corrosion	3-10
                   3.4.3 Scaling and Fouling	3-18
                   3.4.4 Microbiological Control  	   3-19
                   3.4.5 Cooling System Control  	   3-20
             3.5   MAINTENANCE REQUIREMENTS  	   3-22
             3.6   COMPOSITION AND  FORMATION OF DRIFT  .  .  .   3-23
             3.7   DRIFT EMISSION RATE	3-25
             3.8   REFERENCES  FOR CHAPTER 3  ........   3-27

 CHAPTER 4.0  EMISSION CONTROL TECHNIQUES  	    4-1

             4.1   CONTROL  TECHNIQUES  	    4-1
                   4.1.1 Nonchromate Treatment Programs .  .    4-1
                   4.1.2 Reduction of Drift	4-15
             4.2   REFERENCES  FOR CHAPTER 4	4-20

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                   TABLE OF CONTENTS (continued)
 CHAPTER 5.0  MODEL COOLING TOWERS 	   5_1

              5.1  MODEL IPCT SYSTEMS	   5-1
                   5.1.1  Model Cooling Towers 	   5-2
              5.2  HEXAVALENT CHROMIUM EMISSION FACTOR ...   5-8
                   5.2.1  Baseline Emission Factor 	  5-12
                   5.2.2  Controlled Emission Factor ....  5-13
                   5.2.3  Modeled Hexavalent Chromium
                          Emissions  	 .....  5-15
              5.3  DISTRIBUTION OF MODEL TOWERS AND
                     BASELINE EMISSIONS BY INDUSTRY  ....  5-16
                   5.3.1. Petroleum Refineries .	  5-16
                   5.3.2  Chemical Manufacturing Plants  .  .  5-18
                   5.3.3  Primary Metals Industry  	  5-20
                   5.3.4  Miscellaneous Industries 	  5-20
              5.4  NATIONWIDE EMISSIONS SUMMARY  . 	  5-26
              5.5  REFERENCES FOR CHAPTER 5	5-32

 CHAPTER 6.0   REGULATORY ALTERNATIVES  	   6-1

              6.1  DEVELOPMENT OF REGULATORY ALTERNATIVES   .   6-1
              6.2  APPLICATION OF ALTERNATIVES TO MODEL
                   TOWERS	   6-1
              6.3  MACT  FOR THE IPCT SOURCE CATEGORY .  .  .  .   6-3

 CHAPTER 7.0   ENVIRONMENTAL AND ENERGY  IMPACTS 	  .  .   7-1

              7.1  AIR POLLUTION IMPACT  	  .....   7-1
                   7.1.1  Existing Sources	   7-1
                   7.1.2  New Sources	•....   7-6
              7.2  WATER POLLUTION IMPACT  	   7-9
                   7.2.1  Chromium Discharges	   7-9
                   7.2.2  Phosphorus  Discharges   ......    7-9
                   7.2.3  Zinc Discharges	7-14
                   7.2.4  Molybdate Discharges	7-1.4
                   7.2.5  New Sources  .  .	7-14
              7.3   SOLID WASTE DISPOSAL  .....  	   7-14
              7.4   ENERGY IMPACT 	  :....'   7-17
              7.5   STATE REGULATIONS	!  !  !   7-18
                   7.5.1  Air Emissions	7-18
                   7.5.2   Water Discharges  	   7-21
              7.6   POLLUTION PREVENTION  	   7-22
              7.7   REFERENCES  FOR  CHAPTER 7	'.   7-25

CHAPTER 8.0   COST  ANALYSIS  OF CONTROL  OPTIONS	  .    8-1

              8.1   INTRODUCTION	    8-1
              8.2  ANNUALIZED  COST OF CONTROL TECHNIQUES .  .    8-1
                                IV

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                  TABLE OF CONTENTS (continued)
                  8.2.1  High-Efficiency Drift Eliminator
                         Retrofits  	
                  8.2.2  Nonchromate Water Treatment
                         Programs 	
                         Summary of Costs and Cost
                         Effectiveness of Regulatory
                         Alternatives	
     8.2.3
             8.3  REFERENCES FOR CHAPTER 8
CHAPTER 9.0  ECONOMIC IMPACTS
             9.1  INDUSTRY PROFILES
             9.2
                  9.1.1
                    1.2
                    .1.3
                  9.1.4
                    1.5
                    1.6
                    .1.7
                  9.1.8
            The Supply and Demand of Chrornate
            Corrosion Inhibitors 	  .
            Chemical Manufacturing 	  ,
            Petroleum Refining 	
            Primary Metals	  . .  .
            Tobacco Products Industry  ...
            Textile Finishing  	
            Tire and Rubber Products ....
            Glass Products .... 	
     ECONOMIC IMPACT ANALYSIS  .  	
     9.2.1  Methodology  .	
     9.2.2  Percentage Price Increases .  .  .
     9.2.3  Percentage Reductions in the.
            Quantity Demanded  	
     9.2.4  Further Analysis of the Chemical
            Manufacturing Industry . . .  .  .
             9.3  SMALL BUSINESS IMPACTS

             9.4  REFERENCES FOR CHAPTER  9
                                                             Page
 8-1

 8-4


 8-7

8-18

 9-1

 9-2

 9-2
 9-4
9-13
9-20
9-26
9-33
9-39
9-44

9-49
9-49
9-53

9-55

9-59

9-62

9-64
APPENDIX A.
APPENDIX B.
EVOLUTION OF THE BACKGROUND INFORMATION
DOCUMENT
INDEX TO ENVIRONMENTAL IMPACT
CONSIDERATIONS 	
APPENDIX  C.  SUMMARY  OF  TEST  DATA
              C.I  DESCRIPTION OF TESTS   	
                  C.I.I   Department  of  Energy,  Gaseous
                          Diffusion Plant,  Paducah,
                          Kentucky 	
 A-l


 B-l

 C-l

 C-l


 C-l

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                   TABLE  OF CONTENTS  (continued)
                   C.I.2  National  Institute  of  Standards
                         and Technology,
                         Gaithersburg, Maryland 	    C-5
                   C.I.3  Exxon Refinery,  Ethylene
                         Production, Baytown, Texas  ....    C-7
                   C.I.4  Exxon Refinery,  Lube Oil
                         Production, Baytown, Texas  ....   C-ll
                   C.I.5  A Southeastern Manufacturing
                         Facility	C-14
                   C.I.6  National  Institute  of  Standards
                         and Technology,  Gaithersburg,
                         Maryland	C-19
                   C.I.7  Allied Fibers, Moncure, North
                         Carolina	C-20
             C.2   SUMMARY OF TEST  DATA	C-22
             C.3   ANALYSIS OF TEST METHOD	C-23
                   C.3.1  Procedure for Screening Elements  .   C-24
                   C.3.2  Precision of Test Method  .....   C-25
             c.4  "REFERENCES FOR APPENDIX c	c-88

APPENDIX D.  EMISSION MEASUREMENT  OF COOLING
             TOWERS       	    D-l

             D.I   INTRODUCTION	•	    D-l
             D.2   EMISSION MEASUREMENT METHODS	    D-3
                   D.2.1  Scope of  Test Programs  ......    D-3
                         D.2.1.1 Facility Selection  '.....    D-3
                         D.2.1.2 Types of Samples  and Data
                                 Collected	    D-5
                         D.2.1.3 Emission and Process
                                 Sampling Locations  ....    D-7
                   D.2.2  Selection of Sampling and
                         Analytical Methods  	    D-8
                         D.2.2.1 Total Chromium and  Hexavalent
                                 Chromium Emissions  ....    D-8
                         D.2.2.2 Minerals	    D-9
                         D.2.2.3 Particle Size	D-13
                         D.2.2.4 Ambient  Air	D-14

             D.3   COOLING TOWER OPERATIONS AND
                  MONITORING	  .   D-15

             D.4  .QUALITY ASSURANCE/QUALITY CONTROL
                   FOR TEST PROGRAMS	D-15
                  D.4.1  QA/QC for Previous EPA Cooling
                         Tower Tests	D-16
                         D.4.l.l  Title Page and Table
                                   of Contents	D-17
                               VI

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TABLE OF CONTENTS (continued)
D.4.
D.4.
D.4.
D.4.
D.4.
D.4.
D.4.
D.4.
D.4.
D.4.
D.4.
D.4.
1.2
1.3
1.4
1.5
1.6
1.7
1.8
1.9
1.10
1.11
1.12
1.13
       D.4.1.
       D.4.1.
   Project Description ...  D-17
   Project Organization  .  .  D-17
   Quality Assurance
   Objectives	D-17
   Sampling Procedures .  .  .  D-17
   Sample Custody  	  D-18
   Calibration Procedures  .  D-18
   Analytical Procedures  .  .  D-18
   Data Reduction,  Validation
   and Reporting	D-18
   Internal QC Checks  ...  D-19
11 Performance and Systems
   Audits	  D-19
   Preventive Maintenance  .  D-22
13 Assessment of Data
   Reduction, Accuracy and
   Completeness  ......  D-22
14 Corrective Action ....  D-22
15 QA Reports to Management   D-22
D.4.2  Recommended QA/QC for Performance
       Testing	D-23
             VI1

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                          LIST OF FIGURES
                                                              Page
 Figure 3-1.  Internals of crossflow and counterflow
              cooling towers 	    3-4

 Figure 3-2.  Details of splash fill and film fill	    3-5

 Figure 3-3.  Operating principles of various drift
              eliminators	'3-7

 Figure 3-4.  Corrosion mechanism on carbon steel
              surface	3-11

 Figure C-l.  Tower C-637-2A of Department of Energy
              Gaseous Diffusion Plant  . ,	C-27

 Figure C-2.  Cooling tower at NIST facility in
              Gaithersburg,  Maryland 	   C-28

 Figure C-3.  Tower 68 at Exxon-Baytown refinery 	   C-29

 Figure C-4.  Tower 84 at Exxon-Baytown refinery 	   C-30

'Figure C-5.  Cooling tower No.  22-900 at  a
              Southeastern manufacturing facility  	   C-31

 Figure C-6.  Cooling tower No.  22-901 at  a
              Southeastern manufacturing facility  ...  .  .  .   C-32

 Figure C-7.  Tower TW-3  at Allied Fibers	  .  .  .   C-33

 Figure D-l.  Schematic of Marley comfort  cooling tower
              with Munters D-15  high-efficiency drift
              eliminators	 .  .    D-6

 Figure D-2.  Schematic of CTD emission test method
              sampling train	D-ll
                               Vlll

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                          LIST OF TABLES

                                                              Page

TABLE  1-1.    SUMMARY OF CONTROL OPTIONS	     1-2

TABLE  1-2     ASSESSMENT OF ENVIRONMENTAL AND ECONOMIC
           *  IMPACTS OF CONTROL OPTIONS ... 	     1-4

TABLE  1-3.    NATIONWIDE CAPITAL AND ANNUALIZED COSTS OF
              CONTROL OPTIONS FOR INDUSTRIAL PROCESS.
              COOLING TOWERS	......     1-5

TABLE  3-1.    QUALITATIVE CLASSIFICATION OF CORROSION
              RATES	    3-14

TABLE  3-2.    ANODIC AND CATHODIC CORROSION INHIBITOR  .   .    3-15

TABLE  3-3.    CHROMATE BASED CORROSION INHIBITORS  ....    3-17

TABLE  4 -1.    RANGES OF WATER QUALITY PARAMETERS FOR
              REPRESENTATIVE NONCHROMATE COOLING
              WATER  TREATMENT PROGRAMS	     4-3

.TABLE  4-2.    HIGH PROCESS TEMPERATURE CHEMICALS 	    4-11

TABLE  4-3.    SUMMARY OF EPA-SPONSORED AND EPA-APPROVED
              EMISSION TESTS'	    4-19

TABLE  5-1.    MODEL  TOWER PARAMETERS 	 .....     5-3

TABLE  5-2.    RECIRCULATION RATES FOR MODEL TOWERS AS
              DEVELOPED FROM INFORMATION REQUESTS  ....     5-6

TABLE  5-3.    EMISSION FACTORS FROM EPA- AND
              INDUSTRY-SPONSORED TESTS 	    5-10
                                                              6
TABLE  5-4.    SOURCE CATEGORY STANDARD INDUSTRY
              CLASSIFICATION (SIC)	    5-17

TABLE  5-5.    CHROMIUM EMISSION ESTIMATES FOR
              PETROLEUM REFINERIES ............    5-19

TABLE  5-6.    CHROMIUM EMISSION ESTIMATES FOR CHEMICAL
              MANUFACTURING	    5-21

TABLE  5-7.    CHROMIUM EMISSION ESTIMATES FOR PRIMARY
              METALS INDUSTRY	    5-22

TABLE  5-8.    CHROMIUM EMISSION ESTIMATES FOR TOBACCO
              INDUSTRY .	    5-24
                                 IX

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                     LIST  OF  TABLES  (continued)
 TABLE 5-9.


 TABLE 5-10.


 TABLE 5-11.


 TABLE 5-12.


 TABLE 5-13.


 TABLE 6-1.


 TABLE 6-2.


 TABLE 7-1.


 TABLE 7-2.



 TABLE 7-3.

 TABLE 7-4.
   t

 TABLE 7-5.



 TABLE 7-6.


 TABLE 7-7.

 TABLE  7-8.



TABLE  7-9.
 CHROMIUM EMISSION ESTIMATES FOR TIRE AND
 RUBBER INDUSTRY  	
 CHROMIUM EMISSION ESTIMATES FOR TEXTILES
 FINISHING INDUSTRY 	  .
 CHROMIUM EMISSION ESTIMATES FOR GLASS
 PRODUCTS INDUSTRY  	
NATIONWIDE HEXAVALENT CHROMIUM EMISSIONS
SUMMARY	

REFERENCES FOR RESPONSES TO SECTION 114
INFORMATION REQUESTS    	
EMISSION  ESTIMATES  FOR ALL REGULATORY
ALTERNATIVES  	
DISTRIBUTION OF  REGULATORY ALTERNATIVES
AMONG EXISTING IPCT'S   	
BASELINE EMISSION RATE  ESTIMATES  FOR
MODEL TOWERS  	
HEXAVALENT CHROMIUM,  PHOSPHORUS,  AND
PARTICULATE MATTER  (PM)  EMISSION ESTIMATES
 (1991) FOR EACH REGULATORY ALTERNATIVE .  .

CHROMATE-BASED CORROSION INHIBITORS   .'.  .

EMISSION ESTIMATES  FOR  1998  (FIFTH YEAR
OF STANDARD)  	
ESTIMATED WATER DISCHARGES  (1991)  OF
HEXAVALENT CHROMIUM FOR ALL REGULATORY
ALTERNATIVES  	
ESTIMATED PHOSPHORUS DISCHARGES  (1991)  FOR
EACH REGULATORY ALTERNATIVE   	
SELECTED PHOSPHORUS DISCHARGE SOURCES

ESTIMATED WATER DISCHARGES OF HEXAVALENT
CHROMIUM FOR ALL REGULATORY ALTERNATIVES
IN 1998 (FIFTH YEAR OF STANDARD)  ....
ESTIMATED PHOSPHORUS DISCHARGES FOR EACH
REGULATORY ALTERNATIVE IN 1998  (FIFTH
YEAR OF STANDARD)   	
 5-25


 5-27


 5-28


 5-29


 5-30


  6-2


  6-5


  7-2



  7-3

  7-5


  7-8



 7-10


 7-11

-7-13



 7-15



 7-16
                                x

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                    LIST OF TABLES  (continued)
TABLE  7-10
TABLE  7-11.
TABLE  7-12
TABLE  8-1.
TABLE  8-2.
TABLE  8-3.
TABLE  8-4.
'TABLE  8-5.
TABLE  8-6.
TABLE  8-7.
TABLE  8-8.
TABLE  8-9.
TABLE  8-10
TABLE  9-1
TABLE  9-2
TABLE  9-3
ESTIMATED ANNUAL REDUCTIONS IN ENERGY
CONSUMPTION FOR REGULATORY ALTERNATIVE  II
(HEDE RETROFIT)  	,
ESTIMATED ANNUAL INCREASE IN ENERGY
CONSUMPTION FOR REGULATORY ALTERNATIVE  III
(NONCHROMATE)	
REPRESENTATIVE STATE WATER QUALITY
CRITERIA 	
HEDE RETROFIT COSTS FOR MODEL COOLING
TOWERS .	.  .  .

NONCHROMATE COSTS FOR MODEL COOLING
TOWERS 	 .........

CONTROL COST ESTIMATE FOR PETROLEUM  .
REFINERIES 	  ,

CONTROL COST ESTIMATE FOR CHEMICAL
MANUFACTURERS	
CONTROL COST ESTIMATE FOR PRIMARY METALS
INDUSTRY .  . 	

CONTROL COST ESTIMATE FOR TOBACCO
INDUSTRY	:

CONTROL COST ESTIMATE FOR TIRE AND
RUBBER INDUSTRY   	
CONTROL COST ESTIMATE FOR TEXTILES
FINISHING INDUSTRY  	
CONTROL COST ESTIMATE FOR GLASS  PRODUCTS
INDUSTRY  	  .........

SUMMARY OF COSTS AND COST EFFECTIVENESS
OF IMPROVED CONTROL  	
                                                              Pac
                                                              7-19
                                                              7-20
                                                              7-23
                                                               8-8
                                                               8-9
                                                              8-10
                                                              8-11
                                                              8-12
                                                              8-13
                                                              8-14
                                                              8-15
                                                              8-16
                                                              8-17
VALUE OF SHIPMENTS FOR CHEMICAL MANUFACTURING
INDUSTRIES, 1980-1989  ....  	      9-7

U.S. PRODUCTION OF KEY CHEMICALS,
1986-1989	'  .  .  .  .     9-10

PRODUCTION  INDEXES FOR THE U.S. CHEMICAL
INDUSTRY, 1980-1990   	     9-11

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                    LIST OF TABLES  (continued)
                                                              Page
TABLE 9-4    VALUE OF SHIPMENTS  FOR THE  PETROLEUM
TABLE
TABLE
TABLE
9
9
9
-5
-6
-7
AVERAGE U.S. PRODUCTION OF PETROLEUM
PRODUCTS, 1981-1990 	 	
AVERAGE APPARENT CONSUMPTION IN THE U.S.
OF PETROLEUM PRODUCTS, 1981-1990 	
VALUE OF SHIPMENTS FOR THE PRIMARY METALS
INDUSTRIES, 1980-1989 	
9
9
9
-17
-18
-21
TABLE 9-8


TABLE 9-9


TABLE 9-10


TABLE 9-11


TABLE 9-12


TABLE 9-13


TABLE 9-14


TABLE 9-15


TABLE 9-16


TABLE 9-17


TABLE 9-18


TABLE 9-19
U.S. MINE PRODUCTION OF PRIMARY METALS,
 (FERROUS AND NONFERROUS)  1986-1990  .  .

U.S. APPARENT CONSUMPTION OF  PRIMARY
METALS, 1986-1990   	
VALUE. OF SHIPMENTS FOR TOBACCO  PRODUCTS,
1980-1989   	  ......
U.S. PRODUCTION OF TOBACCO PRODUCTS,
1980-1988   	
U.S. PER-CAPITA CONSUMPTION OF TOBACCO
PRODUCTS, 1981-1989	
VALUE OF SHIPMENTS FOR THE TEXTILE
FINISHING INDUSTRIES, 1980-1989
TEXTILE MILL PRODUCTION INDEX,
1980-1989   	
VALUE OF SHIPMENTS FOR THE TIRE AND  INNER
TUBE INDUSTRY, 1980-1989  	
U.S. PRODUCTION OF CAR, TRUCK, AND  BUS
TIRE, 1980-1989   	
VALUE OF SHIPMENTS FOR SIC 3211 AND
SIC 3221	
U.S. PRODUCTION OF FLAT GLASS AND
GLASS- CONTAINERS, 1986-1990   .  .  .
ANNUAL CONTROL COSTS  (1991 DOLLARS)
FOR THE REGULATED INDUSTRIES  .  .  .
9-24
9-25
9-28
9-30
9'-32
9-35
9-37
9-41
9-43
9-46
9-47
                                                              9-54
                               XI1

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                    LIST OF TABLES (continued)
                                                              Page
TABLE'9-20   REVENUE FIGURES FOR  PRICE  INCREASE
             SCENARIOS I AND II	     9-56

TABLE 9-21   PERCENTAGE PRICE  INCREASES FOR
             SCENARIO I	     9-57

TABLE 9-22   PERCENTAGE PRICE  INCREASES FOR
             SCENARIO II	•     9-58

TABLE 9-23   PERCENTAGE REDUCTIONS  IN QUANTITY DEMANDED
             FOR SCENARIO  I	     9-60

TABLE 9-24   PERCENT REDUCTIONS IN  QUANTITY DEMANDED
             FOR SCENARIO  II	     9-61

TABLE A-l.   EVOLUTION OF  THE  BACKGROUND INFORMATION
             DOCUMENT	      A- 4

TABLE B-l    CROSS-INDEXED REFERENCE SYSTEM TO
             HIGHLIGHT ENVIRONMENTAL IMPACT PORTIONS
             OF THE DOCUMENT	      B-2

TABLE C-l.   SUMMARY OF OPERATING PARAMETERS AND
             METEOROLOGICAL DATA  DURING TESTS AT
             DEPARTMENT OF ENERGY,  GASEOUS  DIFFUSION-   '
             PLANT, PADUCAH, KENTUCKY	'.  . .     C-34

TABLE C-2.   SUMMARY OF OPERATING PARAMETERS AND
             METEOROLOGICAL DATA  DURING TESTS AT NATIONAL
             INSTITUTE OF  STANDARDS AND TECHNOLOGY,
             GAITHERSBURG, MARYLAND (FIRST  TEST)   ....     C-36

TABLE C-3'.   SUMMARY OF OPERATING PARAMETERS AND
             METEOROLOGICAL DATA  DURING TESTING OF
             TOWER 68 AT EXXON REFINERY,  BAYTOWN,
             TEXAS	     C-37

TABLE C-4.   SUMMARY OF OPERATING PARAMETERS AND
             METEOROLOGICAL DATA  DURING TESTING OF
             TOWER 84 AT EXXON'S  REFINERY,  BAYTOWN,.
             TEXAS	     C-39
TABLE C-5.
TABLE C-6.
SUMMARY OF OPERATING PARAMETERS AND
METEOROLOGICAL DATA DURING TESTS AT A
SOUTHEASTERN MANUFACTURING FACILITY   .

OBSERVATIONS DURING EMISSION TESTS AT
A SOUTHEASTERN MANUFACTURING FACILITY,
JULY 13, 1987, THROUGH JULY 17, 1987  .
                                                              C-41
                                                              C-43
                               Xlll

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                     LIST OF TABLES (continued)
                                                              Page
 TABLE C-7.   SUMMARY OF OPERATING PARAMETERS AND
              METEOROLOGICAL DATA DURING TESTS AT
              NATIONAL INSTITUTE FOR STANDARDS AND
              TESTING, GAITHERSBURG, MARYLAND
              (SECOND TEST)  	    c_47

 TABLE C-8.   SUMMARY OF OPERATING PARAMETERS AND
              METEOROLOGICAL DATA DURING TESTS AT
              ALLIED FIBERS, MONCURE, NORTH CAROLINA  ...    C-48

 TABLE C-9.   SUMMARY OF EMISSION TEST RESULTS--
              DEPARTMENT OF ENERGY GASEOUS DIFFUSION
            .  PLANT,  PADUCAH,  KENTUCKY   	    C-49

 TABLE C-10.   SUMMARY OF EMISSION TEST RESULTS--NATIONAL
              INSTITUTE OF STANDARDS AND TECHNOLOGY,
              GAITHERSBURG, MARYLAND 	 .    C-51

 TABLE C-ll.   SUMMARY OF EMISSION TEST RESULTS FOR
              TOWER 68 AT EXXON REFINERY,  BAYTOWN,
              TEXAS	    c_53

 TABLE C-12.   SUMMARY OF EMISSION TEST RESULTS FOR
              TOWER 84 AT EXXON REFINERY,  BAYTOWN,
              TEXAS	    c_55

 TABLE C-13.   SUMMARY OF EMISSION TEST RESULTS--
              SOUTHEASTERN MANUFACTURING FACILITY  ... . '.    C-57

 TABLE C-14.   SUMMARY OF SENSITIVE PAPER DRIFT
              MEASUREMENTS	    C-68

 TABLE C-15.   SUMMARY OF EMISSION TEST RESULTS--NATIONAL
              INSTITUTE OF  STANDARDS  AND TECHNOLOGY'S
              STEAM AND WATER CHILL PLANT,  GAITHERSBURG,
              MARYLAND (SECOND  TEST)	,    c-69

 TABLE C-16.   SUMMARY OF EMISSION TEST RESULTS--
              ALLIED  FIBERS, MONCURE,  NORTH CAROLINA ...     C-81

TABLE D-l.    SUMMARY OF EPA-SPONSORED COOLING TOWER
              TEST  PROGRAMS  .	     D_4

TABLE D-2     SUMMARY OF ACCEPTANCE CRITERIA,  CONTROL
              LIMITS, AND CORRECTIVE.ACTIONS  .......     D-20
                               xiv

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                           1.0  SUMMARY

     National emission standards for hazardous air pollutants
 (NESHAP) are established under Section 112 of the Clean Air Act
 (CAA)  (P.L. 101-459), as amended in 1990.  Section 112(b) of the
CAA contains a list of hazardous air pollutants  (HAP's), which
are the specific air toxics to be regulated by NESHAP.  Emission
standards established under Section 112 apply to both new and
existing sources and are to achieve the maximum degree of
reduction in HAP emissions achievable, taking into consideration'
the cost of achieving such emission reductions, any non-air
.quality health and environmental impacts, and energy
requirements.  These standards have been  termed the maximum
achievable control technology (MACT) standards.
     Chromium'compounds are included on the list of HAP's
established in Section 112(b) of the CAA.  Section 112(c)
requires the Administrator to use this pollutant list  to develop
and publish a list of source  categories for which NESHAP are to
be developed.  The source category list was published  on July  16,
1992.   Industrial process cooling towers  (IPCT's), which emit
chromium compounds, are included on the source  category list.
This background  information document  (BID) supports proposed
standards  for chromium emissions from  IPCT's.
1.1  CONTROL OPTIONS
     Table 1-1 is a summary of  the control options  for chromium
emissions  from IPCT's. ' Three control  options have been .
 identified.  Option I is  the  "no action," or baseline,  option;
Option II  involves the use of high-efficiency drift eliminators
 (HEDE's) on  IPCT's; and Option III involves  the use of
 nonchromate-based water treatment programs and  represents  MACT
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TABLE 1-1.  SUMMARY OF CONTROL OPTIONS
Control option
Option I (no action)
Option II
Option III
Control technique ''••• :; •:}- ' •" ""r
Existing (baseline) level of control
-nonchromate- based water treatment
programs used in 90 percent of IPCT's
-high-efficiency drift eliminators
used on 5 percent of IPCT's
-IPCT's on chromate use 13 parts per
million chromate in cooling water
High- efficiency drift eliminators that
reduce uncontrolled emissions by
67 percent
Nonchromate -based water treatment
programs that eliminate all chromium
emissions
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for both new-and existing IPCT's. These options form the basis of
the proposed regulatory alternatives for controlling chromium
emissions from IPCT's.
1.2  ENVIRONMENTAL IMPACT
     Table 1-2 summarizes the environmental and economic impacts
associated with the control options for IPCT's.  Control Option I
represents no.change to existing conditions.   Control Option II
(HEDE retrofits) would reduce nationwide chromium emissions from
the baseline level of 22.9 megagrams per year  (Mg/yr) (25.3 tons
per year  [tons/yr])  to 7.8 Mg/yr (8.6 tons/yr).  Control
Option III (nonchromates) would completely eliminate chromium
emissions from IPCT's.
     As shown in Table 1-2, the reduction in nationwide chromium
emissions associated with either of the control options would
result in minimal adverse environmental impacts.  .Control
Option III would have a negligible negative water impact;
chromium  discharges would decrease, but phosphate discharges
would increase under this control option.  Control Option III
also would have a negligible positive impact on solid waste
resulting from the elimination of chromium from the waste stream.
A negligible positive energy impact would be attributable to
Control Option II due to the lower energy demands to operate
cooling towers equipped with HEDE's.  Under Control Option III,
energy demands would increase slightly, resulting in a negligible
negative energy impact.
1.3  ECONOMIC IMPACT
     An overview of the economic impacts of the options for
controlling chromium emissions from IPCT's is  presented in
Table 1-2.  Table 1-3 summarizes the nationwide capital and
annualized costs associated with each of the control options.
Analyses of the costs and economic impacts are presented in
Chapters 8 and 9.
                               1-3

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 TABLE  1-3.'- NATIONWIDE  CAPITAL AND ANNUALIZED COSTS OF CONTROL
         OPTIONS  FOR  INDUSTRIAL PROCESS COOLING TOWERSa
Control option
Control Option I
Baseline
Control Option II
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                                1-5

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                         2.   INTRODUCTION

2.1  BACKGROUND AND AUTHORITY FOR STANDARDS
     According to industry estimates, more than 2.4 billion
pounds of toxic pollutants were emitted to the atmosphere in 1988
(Implementation Strategy for the Clean Air Act Amendments of
1990. EPA Office of Air and Radiation, January 15, 1991).  These
emissions may result in a variety of adverse health effects,
including cancer, reproductive effects, birth defects, and
respiratory illnesses.  Title III of the Clean Air Act Amendments
of 1990 provides the tools for controlling emissions of these
pollutants.  Emissions from both large and small facilities that
contribute to air toxics problems in urban and other areas will
be regulated. - The primary consideration in establishing national
industry standards must be demonstrated technology.  Before
national emission standards for hazardous air pollutants  (NESHAP)
are proposed as Federal regulations, air pollution prevention and
control methods are examined in detail with respect to their
feasibility, environmental impacts, and costs.  Various control
options based on different technologies and degrees of efficiency
are examined, and a determination is made regarding whether the
various control options apply to each emissions source or if
dissimilarities exist between the sources.  In most cases,
regulatory alternatives are subsequently developed that are then
studied by EPA as a prospective basis for a standard.  The
alternatives are investigated in terms of their impacts on the
environment, the economics and well-being of the industry, the
national economy, and energy and other impacts.  This document
summarizes the information obtained through these studies so that
                               2-1

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 interested persons will be able  to evaluate the information
 considered by EPA in developing  the proposed standards.
     National emission standards for hazardous air pollutants for
 new and existing sources are established under Section '112 of the
 Clean Air Act as amended in 1990 [42 U.S.C. 7401 et seg., as
 amended by PL 101-549, November  15, 1990], hereafter referred to
 as the Act.  Section'112 directs the EPA Administrator to
 promulgate standards that "require the maximum degree of
 reduction in emissions of the hazardous air pollutants subject to
 this section  (including a prohibition of such emissions, where
 achievable) that the Administrator, taking into consideration the
 cost of achieving such emission  reductions, and any non-air
 quality health and environmental impacts and energy requirements,
 determines is achievable ... ."  The Act allows the Administrator
 to set standards that "distinguish among classes,.types, and
 sizes of sources within a category or subcategory."
    • The Act differentiates between major sources and area
 sources.  A major source is defined as "any stationary source or
 group of stationary sources located within a contiguous area and
 under common control that emits  or has the potential to emit
 considering controls, in the aggregate, 10 tons per year or more
 of any hazardous air pollutant or 25 tons per year or more of any
 combination of hazardous air pollutants."  The Administrator,
however, may establish a lesser  quantity cutoff to distinguish
between major and area sources.  The level of the cutoff is based
 on the potency, persistence, or  other characteristics or factors
 of the air pollutant.  An area source is defined as "any
 stationary source of hazardous air pollutants that is.not a major
 source."  For new sources,  the amendments state that the "maximum
degree of reduction in emissions that is deemed achievable for
new sources in a category or subcategory shall not be less
stringent than the emission control that is achieved in practice
by the best controlled similar source, as determined by the
Administrator."  Emission standards for existing sources:
                               2-2

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     may be "less stringent than the standards for new
     sources in the same category or subcategory but shall
     not be less stringent, and may be more stringent than--

          (A) the average emission limitation achieved
          by the best performing 12 percent of the
          existing sources (for which the Administrator
          has emissions information),  excluding those
          sources that have,  within 18 months before
          the emission standard is proposed or within
          30 months before such standard is
          promulgated, whichever is later, first
          achieved a level of emission rate or emission
          reduction which complies, or would comply if
          the source is not subject to such standard,
         • with the lowest achievable emission rate (as
          defined by Section 171)  applicable to the
          source category and prevailing at the time,
          in the category or subcategory for categories
          and subcategories with 30 or more sources,  or

          (B) the average emission limitation achieved
          by the best performing five sources (for
          which the Administrator has or could
          reasonably obtain emissions information) in
          the category or subcategory for categories or
          subcategories with fewer than 30 sources.

     The Federal standards are also known as "MACT" standards and

are based on the maximum achievable control technology previously

discussed.  The MACT standards apply to both major and area

sources, although the existing source standards may be less

stringent than the new source standards, within the constraints

presented above.  The1MACT is considered to be the basis for the

standard, but the Administrator may promulgate more stringent

standards than the MACT floor, which have several advantages.

First, they may help achieve long-term cost savings by avoiding

the need for more expensive retrofitting to meet possible future

residual risk standards, which may be more stringent  (discussed

in Section 2.7).  Second, Congress was clearly interested in

providing incentives for improving technology.  Finally, in the

Clean Air Act Amendments of 1990,  Congress gave EPA a clear

mandate to reduce the health and environmental risk of air toxics

emissions as quickly as possible.
                               2-3

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      For area sources,  the Administrator may  "elect  to promulgate
 standards or requirements  applicable  to  sources  in such
 categories or subcategories which provide  for the use of
 generally available  control technologies or management practices
 by  such sources  to reduce  emissions of hazardous air pollutants."
 These area source standards are also  known as "GACT"  (generally
 available control technology)  standards, although MACT may be
 applied at the Administrator's discretion, as discussed
 previously.
      The standards for  hazardous  air  pollutants  (HAP's), like the
 new source performance  standards  (NSPS)  for criteria pollutants
 required by Section  111 of the Act  (42 U.S.C.  7411), differ from
 other regulatory programs  required by the  Act (such  as the new
 source review program and  the  prevention of significant
 deterioration program)  in  that NESHAP and  NSPS are national in
 scope (versus  site-specific).  Congress  intended for the NESHAP
 and NSPS  programs to provide a degree of uniformity  to State
 regulations  to avoid situations where some States may attract
 industries by relaxing  standards  relative  to  other States.
 States  are  free  under Section  116 of  the Act  to establish
 standards more stringent than  Section 111  or  112 standards.
     Although NESHAP are normally structured  in terms of
numerical  emissions  limits, alternative approaches are sometimes
necessary.   In some  cases,  physically measuring emissions from a
 source may be  impossible or at least  impracticable due to
 technological  and economic  limitations.  Section 112 (h)  of the
Act allows the Administrator to promulgate a  design,  equipment,
work practice, or operational  standard, or combination thereof,
in  those  cases where it is  not feasible to prescribe or enforce
an  emissions standard.  For example,  emissions of volatile
organic compounds (many of  which may  be HAP's, such as benzene)
from storage vessels for volatile organic liquids are greatest
during tank filling.   The nature of the emissions (i.e.,  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
                               2 - 4.                      -'

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impractical."-  Therefore, the MACT or GACT standards may be based
on equipment specifications.
     Under Section 112 (h) (3), the Act also allows the use of
alternative equivalent technological systems:  "If, after notice
and opportunity for comment, the owner or operator of any source
establishes to the satisfaction of the Administrator that an
alternative means of emission limitation" will reduce emissions
of any air pollutant at least as much as would be achieved under
the design, equipment, work practice, or operational standard,
the Administrator shall permit the use of the alternative means.
     Efforts to achieve early environmental benefits are
encouraged in Title III.  For example, source owners and
operators are. encouraged to use the Section 112(i) (5) provisions,
which allow a 6-year compliance extension of the MACT standard in
exchange for the implementation of an early emission reduction
program.  The owner or operator of an existing source must
demonstrate a 90 percent emission reduction of HAP's (or
95 percent if the HAP's are particulates) and meet an alternative
emission limitation, established by permit, in lieu of the
otherwise applicable MACT standard.  This alternative limitation
must reflect the 90 (95) percent reduction and is in effect for a
period of 6 years from the compliance date for the otherwise
applicable standard.  The 90 (95) percent early emission
reduction must be achieved before .the otherwise applicable
standard is first proposed, although the reduction may be
achieved after the standard's proposal (but before January 1,
1994) if the source owner or operator makes an enforceable
commitment before the proposal of the standard to achieve the  •
reduction.  The source must meet several criteria to qualify for
the early reduction standard, and Section 112 (i) (5) (A)  provides
that the State may require additional reductions.
2.2  SELECTION OF POLLUTANTS AND SOURCE CATEGORIES
     As'amended in 1990, the Act includes a list of 190 HAP's.
Petitions to add or delete pollutants from this list may be
submitted to EPA.  Using this list of pollutants, EPA will
publish a list of source categories  (major and area sources) for
                               2-5

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which emission standards will be developed.  Within 2 years of
enactment  (November 1992), EPA will publish a schedule
establishing dates for promulgating these standards.  Petitions
may also be submitted to EPA to remove source categories from the
list.  The schedule for standards for source categories will be
determined according to the following criteria:
      (A) The known or anticipated adverse effects of such
     pollutants on public health and the environment;
      (B) The quantity and location of emissions or
     reasonably anticipated emissions of HAP's that each
     category or subcategory will emit; and
      (C) The efficiency of grouping categories or
     subcategories according to the pollutants emitted or
     the processes or technologies used.
     After the source category has been chosen, the types of
facilities within the source category to which the standard will
apply must be determined.  A source category may have several
facilities that cause air pollution, and emissions from these
facilities may vary in magnitude and control cost.  Economic
studies of the source category and 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
standards, the standards may not cover all pollutants or
facilities within that source category.
2.3  PROCEDURE FOR DEVELOPMENT OF NESHAP
     Standards for major and area sources 'must (1) realistically
reflect MACT or GACT;  (2) adequately consider the cost, the
non-air quality health and environmental impacts, and the energy
requirements of such control; (3)  apply to new and existing
sources; and (4)  meet these conditions for all variations of
industry operating conditions anywhere in the country.
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      The  objective  of  the  NESHAP  program is  to  develop  standards
 to  protect  the  public  health by requiring facilities  to control
 emissions to the  level achievable according  to  the MACT or GACT
 guidelines.   The  standard-setting process involves three
 principal phases  of activity:   (1)  gathering information,
 (2)  analyzing the information,  and (3)  developing the standards.
      During the information-gathering phase,  industries are
 questioned  through telephone surveys,  letters of inquiry,  and
 plant visits by EPA representatives.   Information is  also
 gathered  from other sources, such as  a literature search.   Based
 on  the information acquired about the industry, EPA selects
 certain plants  at which emissions tests are  conducted to provide
 reliable  data that characterize the HAP's emissions from
' well-controlled existing facilities.
      In the second phase of a project, the information about the
 industry, the pollutants emitted, and the control options  are'
 used- in analytical studies.  Hypothetical "model plants" are
 defined to  provide a common basis for analysis.  The model plant
 definitions, national pollutant emissions data, and existing
 State regulations governing emissions from the source category
 are then used to establish regulatory alternatives.  These
 regulatory alternatives may be different levels of emissions
 control or different degrees of applicability or both.
      The EPA conducts studies to determine the cost,  economic,
 environmental,  and energy impacts of each regulatory alternative.
 From several alternatives, EPA selects the single most plausible
 regulatory alternative as the basis for the NESHAP for the source
 category under study.
      In the third phase of a project, the selected regulatory
 alternative is translated into standards, which,  in turn,  are
 written in the form of-a  Federal regulation.  The Federal
 regulation limits emissions to the levels indicated in  the
 selected regulatory alternative.
      As early as is practical  in each standard-setting  project,
 EPA representatives discuss the  possibilities  of  a standard  and
 the form it might  take with members of  the National Air Pollution.
                                2-7

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Control Techniques Advisory Committee, which is composed of
representatives from industry, environmental groups, and State
and local air pollution control agencies.  Other interested
parties also participate in these meetings.
     The information acquired in the project is summarized in the
background information document  (BID).  The BID, the proposed
standards, and a preamble explaining the standards are widely
circulated to the industry being considered for control,
environmental groups, other government agencies, and offices
within EPA.  Through this extensive review process, the points of
view of expert reviewers are taken into consideration as changes
are made to the documentation.
     A "proposal package" is assembled and sent through the
offices of EPA Assistant Administrators for concurrence before
the proposed standards are officially endorsed by .the EPA
Administrator.  After being approved by the EPA Administrator,
the preamble and the proposed regulation are published in the
Federal Register.
     The public is invited to participate in the standard-setting
process as part of the Federal Register announcement of the
proposed regulation.  The EPA invites written comments on '.the
proposal and also holds a public hearing to discuss the proposed
standards with interested parties.  All public comments are
summarized and incorporated into a second volume of the BID.  All
information reviewed and generated in studies in support of the
standards is available to the public in a "docket" on file in
Washington, D.C.  Comments from the public are evaluated, and the
standards may be altered in response to the comments.
     The significant comments and EPA's position on the issues
raised are included in the preamble of a promulgation package,
which also contains the draft of the final regulation.  The
regulation is then subjected to another round of internal EPA
review and refinement until it is approved by the EPA
Administrator.  After the Administrator signs the regulation, it
is published as a "final rule" in the Federal Register.
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2.4  CONSIDERATION OF COSTS
     The requirements and guidelines for the economic analysis .of
proposed NESHAP are prescribed by Presidential Executive Order
12291 (EO 12291} and the Regulatory Flexibility Act (RFA).   The
EO 12291 requires preparation of a Regulatory Impact Analysis
(RIA) for all "major" economic impacts.  An economic impact is
considered to be major if it satisfies any of the following
criteria:
     1.  An annual effect on the economy of $100 million or more;
     2.  A major increase in costs or prices for consumers;
individual industries; Federal, State, or local government
agencies; or geographic regions; or
     3.  Significant adverse effects on competition, employment,
investment, productivity, innovation, or on the ability of United
States-based enterprises to- compete with foreign-based
enterprises in  domestic or  export markets.
     An RIA describes the potential benefits and costs of the  •
proposed regulation and explores alternative regulatory and
nonregulatory approaches to achieving  the desired  objectives.   If
the  analysis identifies less costly alternatives,  the RIA
includes an explanation of  the  legal  reasons why the less-costly
alternatives could not be adopted.  In addition to requiring an
analysis of the potential costs and benefits,  EO 12291  specifies
that EPA,  to the extent allowed by  the CAA  and court orders,
demonstrate that the  benefits  of the  proposed  standards  outweigh
the  costs  and  that the net  benefits are maximized. .
     The RFA requires Federal  agencies to.give special
consideration  to the  impact of regulations  on small businesses,
small  organizations,  and small governmental units.  If  the
proposed regulation  is  expected to  have  a significant  impact on a
substantial  number of small entities,  a regulatory flexibility
analysis must  be prepared.   In preparing this analysis,  EPA takes
 into consideration such factors as  the availability of  capital
 for small entities,  possible closures among small entities,  the
 increase in production costs due to compliance,  and a comparison
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 of the relative compliance costs as a percent of sales for small
 versus large entities.
      The prime objective of the cost analysis is to identify the
 incremental economic impacts associated with compliance with the
 standards based on each regulatory alternative compared to
 baseline.  Other environmental regulatory costs may be factored
 into the analysis wherever appropriate.  Air pollutant emissions
 may cause water pollution problems, and captured potential air
 pollutants may pose a solid waste disposal problem.  The'total
 environmental impact of an emission source must,  therefore,  be
 analyzed and the costs determined whenever 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  for proposed standards.   It is also essential to know the
 capital requirements for pollution control systems already placed
 on plants so that the additional capital requirements
 necessitated by these Federal  standards can be placed in proper
 perspective.   Finally,  it is  necessary to assess  the  availability
 of capital to provide the additional  control equipment needed  to
 meet  the  standards.
 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  for  various
 industries, the United  States Court of Appeals for  the District
 of Columbia Circuit has-held that environmental impact  statements
 need not be prepared by EPA for proposed actions under the Clean
Air Act.  Essentially,  the Court of Appeals  has determined that
 the best system of emissions reduction requires the Administrator
 to take into account counterproductive environmental effects of
                               2-10

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proposed standards as well as economic costs to the industry.  On
this basis, therefore, the Courts established a narrow exemption
from NEPA for EPA determinations.
     In addition to these judicial determinations, the Energy
Supply and Environmental Coordination Act of 1974 (PL-93-319)
specifically exempted proposed actions under the Clean Air Act
from NEPA requirements.  According to Section 7(c)(1), "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" : (15 U.S.C. 793(c) (1)) .
     Nevertheless, EPA has concluded that preparing environmental
impact statements could have beneficial effects on certain
regulatory actions.  Consequently, although not legally required
to do so by Section 102(2) (C) of NEPA, EPA has adopted a policy
requiring that environmental impact statements be prepared for
various regulatory actions,  including NESHAP developed under
Section 112 of the Act.  This voluntary preparation of
environmental impact statements, however, in no way legally
subjects the EPA to NEPA requirements.
     To implement this policy, a separate section is included in
this document that 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 discussed.
2.6  RESIDUAL RISK STANDARDS
     Section 112 of the Act provides 'that 8 years after MACT
standards are established (except for those standards established
2 years after enactment, which have 9 years), standards to
protect against the residual health and environmental risks
remaining must be promulgated, if necessary.  The standards would
be triggered if more than one source  in a category or subcategory
exceeds a maximum individual risk of  cancer of I1 in 1 million.
These residual risk regulations would be based on the concept of
providing an "ample margin of safety  to protect public health."
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The Administrator may also consider whether a more stringent
standard is necessary to prevent--considering costs, energy,
safety, and other relevant factors--an adverse environmental
effect.  In the case of area sources controlled under GACT
standards, the Administrator is not required to conduct a
residual risk review.
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              3.0   INDUSTRIAL  PROCESS  COOLING  TOWERS

3.1  GENERAL
     This section provides a description of the source category
and the major users of industrial process cooling towers
(IPCT's), the cooling tower system, the heat exchangers served by
cooling towers, cooling water chemical treatment programs, the
mechanism by which hexavalent chromium (Cr+6)  is emitted, and the
emission control techniques.
3.2  DEFINITION OF SOURCE CATEGORY
     All cooling towers that are used to remove heat from an
industrial process or chemical reaction are included in the IPCT
source category.  Towers that are used to cool both industrial
processes and heating, ventilating, and air conditioning  (HVAC)
and refrigeration systems also are included in the source -
category.  Only towers devoted exclusively to cooling HVAC and
refrigeration systems are excluded from the source category.
     Major users of IPCT's that also use chromium-based water
treatment chemicals are chemical manufacturing plants, petroleum
refineries, primary metals facilities, and several miscellaneous
manufacturing industries (textiles, tobacco products, tire and
rubber products, and glass products).  Other major users of
IPCT's, which do not use chromium-based water treatment
chemicals, include the electrical utility, food processing, and
pulp and paper industries.  The number of plants in each
industry, the total number of IPCT's in each industry, and the
number of IPCT's that are using chromates were estimated by
procedures presented in Chapter 5.  From the information '
presented in detail in Chapter 5, it is estimated that IPCT's are
used at approximately 189 petroleum refineries, 1,824 chemical
                               3-1.

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 manufacturing plants,  210  primary metals  plants,  and 599 plants
 in the miscellaneous  industries.1"3   In addition,  the percentage
 of cooling towers  using chromium-based water treatment  chemicals
 in each industry is estimated as  20  percent  at petroleum
 refineries,  10 percent at  chemical manufacturing  plants,
 10 percent at primary metals  facilities,  7.5 percent at plants in
 the tire and rubber industry,  and 2.5  percent at  plants in the
 other  miscellaneous industries.4"7  These estimates  result in a
 total  of about 790 IPCT's  using chromium-based water treatment
 chemicals:   136 at petroleum  refineries,  510 at chemical plants,
 97 at  primary metals  plants,  and  47  at miscellaneous plants.8"15
 The nationwide baseline Cr+6  emissions from  these towers are
 estimated to be 22.9  megagrams per year (Mg/yr)  (25.3 tons per
 year [tons/yr]).
 3.3  INDUSTRIAL COOLING SYSTEM COMPONENTS
 3.3.1   Cooling Tower
     Cooling towers are devices that cool  warm water by
 contacting  it  with ambient air that  is drawn or forced  through
 the  tower.   Typically,  about  80 percent of the cooling  occurs
 from evaporation of water as  the air flowing through the tower
 contacts  water cascading from the  top  to  the bottom  of  the tower.
 The  remaining  20 percent of the cooling is the result of sensible
 heat transfer  that raises the  air  temperature.16  Most .tower
 systems are  designed with recirculating water systems to conserve
 water  resources  or reduce costs of purchasing water.  The major
 cooling tower  components include the fan(s),  fill material, water
 distribution deck,  or  header,  drift  eliminator, structural frame,
 and  cold  water basin.    Other  components that  affect  tower
 operation include the  pumps and pipes  necessary to circulate the
 cooling water  through  the cooling  tower and  heat exchanger loops.
     Most IPCT's are designed  with induced-draft airflow, but
many have forced-draft  airflow, and  some  (especially in the
utilities industry) have natural-draft airflow.  Induced draft is
provided by  a  propeller-type axial fan located in the stack at
 the top of the tower.    Forced-draft  towers are usually smaller
 than induced-draft towers and  have either  centrifugal fans
                               3-2

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located at the base of the tower, which is constructed as a
plenum to provide positive-pressure airflow through the fill
material, or axial fans located on the side of the tower.
Natural-draft airflow relies on air currents created by
temperature differences between the air in the tower and the
atmosphere.  When the cooling demands are minimal and the air
temperature is low enough, water can be circulated through the
tower and cooled sufficiently without using the fans.  In these
instances, a natural draft is created in the cooling tower.  'In
addition, the direction of the airflow through a mechanical draft
tower is either crossflow or counterfldw.  Crossflow refers to
horizontal airflow through the fill, and counterflow refers to
upward vertical airflow.  Schematics of counterflow and crossflow
cooling towers are presented in Figure 3-1.
     Fill material is used to maintain an even distribution of
water across the horizontal plane of the tower and to create as
much water surface as practical to enhance evaporation and
sensible heat transfer.  The fill material improves the water-to-
air interface by creating either a large number of water droplets
or many thin vertical sheets (or tubes) of water.  Splash fill is
constructed as successive layers of staggered impact surfaces in
the form of bars.  Small droplets are formed as warm water falls
through the fill and splashes off each layer.  Splash fill
typically is constructed of wood, polyvinyl chloride (PVC),
polystyrene, polypropylene, or asbestos cement board.  Film fill
is constructed of sheets of material in a "honeycomb"
configuration.  The fill is oriented such that water enters the
open end of the honeycomb .and flows vertically in sheets along
the surface of the fill.material.  Typically, film fill materials
are PVC, polystyrene, or polypropylene.  Schematics of both
splash and film fill are presented in Figure 3-2..
     The mechanism by which the warm water is distributed over
the fill material depends on the type of tower.  In crossflow
towers, there is a water distribution deck above the fill
material at the top of the tower.  The floor of this deck
contains gravity flow nozzles, and the water level in the deck
                               3-3

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                            AIR
                          OUTLET
               WATER
               INLET
FAN

 WATER
 INLET
              WATER OUTLET
                   MECHANICAL  DRAFT
                   CROSS-FLOW TOWER
                          AIR
                         OUTLET
             WATER  OUTLET
                   MECHANICAL  DRAFT
                   COUNTER-FLOW  TOWER
Figure  3-1.   Internals of crossflow and counterflow
                   cooling towers.

(Reprinted from Drift  Technology for Cooling  Towers,
             The Marley  Company, 1973.)
                           3-4

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                    SPLASH FILL
                      FILM FILL
 Figure 3-2.  Details  of splash fill and film  fill.



(Reprinted from Custodis-Cottrell product brochure.)
                         3-5

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 controls the-rate of water flow onto the fill.   In counterflow
 towers,  the water distribution system is constructed of  a  series
 of header pipes connected to pressure flow nozzles placed  above
 the fill material.   In both systems,  the nozzles are arranged  to
 provide  even water distribution over the fill material.
     Water droplets entrained in the air and the dissolved and
 suspended solids contained in the droplets that  are emitted  from
 cooling  towers  are referred to as drift.   (Drift is. discussed  in
 Section  3.6.)   Drift eliminators can be  installed at the exit  of
 the fill sections to reduce the amount of drift  in the exiting
 airflow.   The efficiency of a drift  eliminator is a function of-
 its design.   Figure 3-3  presents schematics of the three major
 drift  eliminator designs:   herringbone (blade-type),  waveform,
 and cellular (or honeycomb).   In general  (with a few exceptions),
 herringbone  units are the  least efficient,  cellular units  are  the
 most efficient,  and waveform units achieve an intermediate
 efficiency.   Drift  eliminators are constructed of wood,  PVC,
 metal, asbestos-cement,  polystyrene,  or  cellulose.   The  material
 most often specified is  PVC.   Drift  eliminators  installed  in
 towers built  in  recent years  are more likely to  be high-
 efficiency waveform or cellular units, but a large number  of
 older towers  still  have  low-efficiency eliminators.
     The  structural  frame  of  cooling  towers  can  be wood,
 concrete,  masonry,  steel-,  and combinations of these materials.
 The  cold  water basins  (reservoirs) typically are located directly
 below the fill material  at  the base of the cooling tower.  Basin
 size is affected by the  size  of the tower  and by the  necessity to
 accommodate any  short-term fluctuations in the water  volume  of
 the  system.
 3.3.2  Heat Exchangers and  Cooling Water Cycle
     In a typical IPCT system,  cooling water is  pumped from  the
 cooling tower basin  to the  heat  exchanger(s) served by the tower,
 and  the heated water flows  back to the cooling tower  water
distribution deck.   The  cooling water  loop may include numerous
 separate  heat exchangers of various designs.  Heat  exchangers are
designed  to transfer heat from one fluid to  another.  The
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                                              Wood Latrh
                                              Bfades
                                  BLADE-TYPE
                                  ELIMINATOR
                                                   Plemtle
                                 WAVEFORM
                                 ELIMINATOR
                                  CELLULAR
                                  ELIMINATOR
Figure  3-3.  Operating principles of various drift eliminators


                (Reprinted from Reference No.  17.)


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 transfer can'- occur directly by mixing the hot  and cold materials
 or indirectly through a device separating the  hot and cold
 materials.   Indirect heat exchanger types include shell-and-tube,
 flat plate,  and spiral designs.   In most  industries, heat
 transfer is  accomplished with shell-and-tube heat exchangers that
 typically are constructed from carbon steel.16 However, metals
 such as  stainless  steel,- copper,  and admiralty brass are also
 used.  Graphite blocks,  titanium,  Hastelloy, and  other very
 corrosion-resistant metals are used in severe  environments.
      Although maximum process fluid temperatures  may exceed
 1000°C  (1832°F), the bulk fluid process temperatures at the
 inlets to the heat exchangers are much less than  the process
 fluid temperatures due to heat losses between  the process reactor
 and heat exchangers.   In addition,  because the volume of cooling
 water is much greater than the volume of  process  fluid that is
 cooled per unit time,  and because of other losses in heat, the
 temperature  of the cooling water  within the heat  exchanger  (bulk
 water temperature)  rarely exceeds 70°C (160°F) in most IPCT
 systems.  The temperature of  the  heat exchanger material  (skin
 temperature)  on both the process  side and the  water side of the
 exchanger is  less  than the process  fluid  temperature and greater
 than the bulk water temperature.
      The side of the  heat exchanger providing  the cooling is
 referred to as the water side, and  the  side with  the process
 fluid is referred  to  as  the process  side.  The water side of the
 heat  exchanger is  of  primary  interest for the  cooling tower
 source category because  of the effects  of cooling water treatment
programs on operating and maintaining the heat exchangers.  Water
velocities in heat  exchangers  vary but  normally range between 0.9
 to 2.4 meters  per  second (m/s)  (3 to 8  feet per second tft/s]).18
 3.4  CHEMICAL  TREATMENT  PROGRAMS
 3.4.1  Purpose
     Chemicals  are  added to the recirculating  cooling water to
 inhibit  the corrosive  effects  of  the  water, to control the rate
of scaling and fouling,  and to control  the growth of
microorganisms  in both the  cooling tower  and the  heat exchangers.
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As evaporation occurs during cooling, the chemical constituents
of the water become concentrated.  A percentage of the
recirculating water is intentionally discharged (blowdown) to
limit the concentrations of suspended and dissolved solids to
acceptable levels.  Also, as water cascades through the tower,
some is entrained and emitted from the stack as drift.  Fresh
water (makeup) is added to make up for the losses resulting from
evaporation, blowdown, and drift.
     Typical water treatment program chemicals include  (1) a -
corrosion inhibitor,  (2) an antiscalant,  (3) an antifoulant,
(4) a dispersant,  (5) a surfactant,  (6) a biocide, and  (7) an
acid and/or caustic soda for pH control.  Chromium-based
chemicals are corrosion inhibitors.  The quality of the cooling
tower water supply directly affects the type and quantity of
chemicals required to maintain a satisfactory chemical treatment
program.  The three problems--corrosion, scaling and fouling, and
microbiological growth--and the chemicals used to control them
are discussed later in this section.
     Physical parameters that affect the selection of chemical
treatment programs include heat exchanger material, bulk water
and water-side skin termperatures, water velocity, and holding
time index.19'20  The holding time index is usually defined as
the half-life of the recirculating water, or the time required
for half of the recirculating water to be replaced.
     Major water chemistry parameters that affect the selection
of chemical treatment programs include pH, calcium hardness
(calcium ion concentration), alkalinity  (bicarbonate, carbonate,
and' hydroxide ions), chloride, sulfate, silica, iron, dissolved
solids  (conductivity), and suspended solids.19'20  Water  quality
also directly affects the number of cycles of concentration that
can be maintained.  The number of cycles of concentration is •
-defined as the ratio of either the conductivity or calcium
hardness of the recirculating water to that of the makeup water.
The maximum allowable conductivity or  calcium hardness  is
established based  on the chemical treatment program and the
acceptable rates of corrosion and scaling.  In general, limits
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 are set'so as not to exceed the mineral solubility and cause
 scale formation.  Generally, the higher the water hardness or
 recirculating water pH,  the fewer the cycles of concentration
 allowable.  Recently developed calcium dispersants allow more
 cycles of concentration or higher pH in IPCT operations.
 3.4.2  Corrosion
      3.4.2.1  Description.  Corrosion is the oxidation of a metal
 by some oxidizing agent  in the environment.   The area over which
 metal is oxidized (corroded)  is called the anode;  the area over
 which the oxidizing agent is reduced is called the cathode.   In
 water,  an electrochemical cell is formed in which cations migrate
 toward the cathode,  anions move toward the anode,  and electrons
 flow through the metal  from anode to cathode.   Water is the
 conducting fluid or electrolyte,  and the metal surface develops
 anodic and cathodic areas as the  result of differences in
 electrochemical  potential,  temperature,  and the concentration of
 dissolved oxygen or solids.   In equipment made from a single type
 of metal,  differences in electrochemical potential occur  as  the
 result  of impurities in  the metal,  localized stresses,  grain size
 or composition differences,  and discontinuities on the surface.21
 An electrochemical  potential  difference also is created when two
 different metals are in  contact both with each other and  the same
 solution.   This  electrochemical potential difference causes
 galvanic  corrosion  in the active  (or least noble)  metal that
 serves  as  the  anode.21'22  For both single and multiple metal
 systems,  local differences  in dissolved oxygen and solids
 concentrations and  in temperature also  cause anodic  and cathodic
 areas in  the metal  to form.   Anodic surfaces will  exist in
 regions of  low oxygen concentration,  low temperature,  and high
 salt concentrations.16'23  As  the anode  corrodes and releases
 cations to  solution, electrons  are  released  that flow through the
metal to  the cathode.  The  flow of  electrons through the metal  is
 the corrosion  current, which  is limited  by the  rate  at which
 electrons are accepted by the  oxidizing  agent at the  cathode.
 Figure 3-4  illustrates the mechanisms for  corrosion  in a single
metal and presents the reactions at  the  anode and  cathode.
                               3-10

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                   WATER(ELECTROLYTE)
                    ANODIC REACTIONS



                      Fe * Fe+++2e~



                     -*• Fe(OH)2 (soluble form)



Fe(OH)2+H2O+f02  -»• 2Fe(OH)3  (insoluble  red-brown deposit)



                   CATHODIC REACTIONS



              iO2+H2O+2e~ '* 2OH~  (at pH  >4)



               2e"+2H+ * H2gas (at pH <4)



                  l|H2+02gas  -^ H20+OH~
Figure  3-4.   Corrosion mechanism on carbon steel surface.



              (Reprinted from Reference  21.)
                           3-11

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       Two primary types  of  corrosion  occur  in  cooling water
  systems depending on the equipment design  and the system
  operation:   general  and localized corrosion.16'18'21'22  in
  general corrosion (the  less harmful  type of corrosion), the metal
  dissolves uniformly.  General  corrosion occurs when the local
  concentration or temperature difference along the metal surface
  causes differences in electrochemical potential and creates
  corrosion cells.  The movement of these cells from place to place
  on the metal surface  as concentrations and temperatures fluctuate
  cause uniform corrosion along  the surface  of  the metal.21
  However, the corrosion rate is enhanced by high concentrations
  and temperature.  Fouling  from corrosion products is likely to be
  the major problem when general corrosion occurs.21'22
      Localized corrosion,  typically  in the form of pitting,
  occurs when the  anodic sites remain  stationary and corrosion
 proceeds rapidly at localized points.  Corrosion of this type, is
. a more serious problem than general  corrosion in industrial
 systems because  it can cause metal to perforate in a very short
 time.21'22  Pitting corrosion is the formation of cavities or
 holes in the metal and can occur in  crevices  within a metal, at
 joints between metal  sections, and under deposits of suspended
^ solids and precipitating chemical species.   Conditions that
 promote these deposits are low-velocity water flow,  high
 concentrations of dissolved solids,  and high pH.21  Pitting can
 also occur when a dissolved cathodic (less  active)  metal plates
 out in spots on an anodic  (active)  surface.  This most serious
 form of galvanic corrosion typically occurs in systems containing
 both copper and steel components.  The copper can plate out on
 steel surfaces,  causing galvanic corrosion  of the steel.   Once
 the plating occurs, it is very difficult to inhibit  the resulting
 corrosion.21  Severe localized galvanic corrosion also can result
 if the anodic area is small relative to the cathode;  when the
 electron flow is from a small  anodic area to a large  cathode
 (which serves as an electron sink),  the anode corrodes rapidly
 and a pit  develops.  However,  when the anodic surface area is
 substantially larger than the  cathodic surface, the  corrosion is •
                                3-12

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general in nature because only a thin layer of metal will be
removed over time.  Pitting corrosion can also occur when small
anodic areas are left unprotected by inhibitors,  as discussed
below.
     3.4.2.2  Corrosion Inhibitors.  Inhibitors are added
primarly to protect the heat transfer surfaces from corrosion.
These surfaces are the most critical metal components in the
system.  Corrosion can be .retarded, but not totally, prevented,
and the rate of corrosion that is acceptable varies among
systems.  The terms and corrosion rates presented in Table 3-1
are generally used to describe the severity of.carbon steel and
copper corrosion.
     Corrosion inhibitors used in a recirculating system limit
the rate of reaction at the anode, the cathode, or both.  The
mechanisms by which these inhibitors protect the metal are
passivation, precipitation, and adsorption.  Anodic and cathodic
inhibitors produce a barrier film, or deposit, on the anodic and
cathodic metal surfaces, respectively.  The barrier created by
passivation is an oxide that forms on the metal surface, and the
barrier created by precipitation is an insoluble precipitate that
coats the metal surface.  Typically, anodic inhibitors are
passivators, and  cathodic inhibitors are precipitators.
Table 3-2 lists various anodic and cathodic inhibitors.
Molecules that have polar properties provide a barrier by
adsorbing on the  entire metal surface.  Adsorption inhibitors are
usually organic compounds.
                          18,21,22
     The rate of corrosion at the anode is controlled by the rate
of the cathodic reaction  (i.e., the same mass of the anode
corrodes for a given cathodic reaction rate).  Thus, pitting may
occur if only small spots of the anodic surface remain
unprotected and the cathodic reaction is not controlled by
cathodic inhibitors and/or organic adsorption inhibitors.
Although chromate  is an excellent anodic inhibitor, the
likelihood that small  spots will remain unprotected increases as
the  concentration  of chromate maintained in  the recirculating
water decreases.18'21'22
                               3-13

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TABLE 3-1'-.  QUALITATIVE  CLASSIFICATION OF CORROSION RATES18
Description
Negligible
Mild
Moderate
Severe
Corrosion rates, pm/yr (mils/yr)a
Carbon steel
<25.4-50.8 (254.0 (>10)
Copper alloy
<2.54 (<0.1)
3.81-5.08 (0.15-0.2)
5.08-8.89 (0.2-0.35)
12.7-25.4 (0.5-1)
                           3-14

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  TABLE 3-2.
ANODIC AND CATHODIC CORROSION
    INHIBITORS
Anodic
          Cathodic
Chromate
          Polyphosphate
Molybdate
          Zinc
Orthophosphate
          Polysilicate
Nitrite
Orthosilicate
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     3.4.2.2"-.!  Chromium-based inhibitors.   Chromates
historically have provided the best protection against corrosion
for the money and effort.  Less stringent monitoring and control
of chemical concentration and pH are required with chromates than
with alternative treatments.  Even if the inhibitor feed is
temporarily interrupted, the existing barrier film will continue
to provide protection for several days.
     Chromate concentration typically must be maintained above
200 parts per million (ppm) if the chromates are used alone in
the recirculating water.  However, chromates (which are anodic
inhibitors) typically are used in combination with cathodic
inhibitors.  In these combinations, smaller concentrations of
chromate provide the same corrosion protection that is provided
by high concentrations of chromate alone.  Vendors provide many
chromium-based formulations for use in IPCT's.   The chromium
concentrations in these formulations generally range from 3 to
30 ppm as chromate.  However, very few plants use chromate in
concentrations of less than 10 ppm, and the results obtained with
these "low" chromate water treatment programs have been mixed.
Programs that contain less than 10 ppm of chromate require
tighter chemical control and more expensive chemical additives
than are required for formulations that use higher chromium
concentrations.  Plants that use chromates prefer to use higher
chromate concentrations  (i.e., 10 ppm or more)  to avoid the
additional costs for additives and tighter control requirements.
     The inhibitor chemicals most commonly added to chromate-
based formulations are zinc and phosphate; but organic compounds,
polysilicates, and molybdates also are used.  Some of the effects
that these compounds have on the treatment program are discussed
below, but because the same chemicals are used in nonchromate
treatment programs, they are discussed in greater detail in
Section 4.1.1.  Table 3-3 provides concentrations and typical
operating conditions of some of the corrosion inhibitor
formulations discussed in various publications.18'21'22
     Molybdates are anodic inhibitors that protect all metals but
are most effective on steel.  Zinc is an effective cathodic
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  TABLE 3-3."-  CHROMATE-BASED  CORROSION  INHIBITORS18'21'22'24'25
Chromate/zinc
Chromate/orthophosphate
Qiromate/orthophosphate/ziiic
Ohromate/polyphosphate/zinc
Chromate/zinc/phosphonate
Chromate/phosphonate/specified
Chromate/phosphonate/dispersant
Chromate/dispersant
Chromate/polysilicate
Chromate/zinc/dispersant
Chromate/molybdate
5-20/2.5-10
20-25/3-3.5
5-10/10
15-25/2-5/2-5
15-25/2-5/2-5
10-30/3-5/3-5
20-25/5-10/2.5-3.0
15-25/2-4/3-5
2-3/2-3/5-10
20-25/2-4/3-5
5-10/3-5
5-15/2-6/2-6
3-5/30
5-10/3-6
5-10/5-10
10-20/1-2/1.5-10
10-15/1-2/5-10
10-30/1-5
pH 6.5-7.0
pH 7.0-7.5
pH 6.2-6.8
pH 6.2-6.8
pH 6.0-7.0
pH 6.5-7.0 CaH 100-600 ppmc
pH 6.0-6.5 CaH <400
pH 6.5-7.5
pH 6.5-7.0
pH 6.5-7.0
Not specified
pH 7.5-8.5
pH 7.5-8.0
pH 7.5-8.0
pH >7.5
Si < 10 ppm
pH 7.0-9.0
pH 7.5-9.0
pH >7.5
aln all combinations except chromate/polysilicate, the organic triazole corrosion inhibitors should be included at
 1 to 10 ppm when the system contains copper.
''The components of some combinations can be formulated differently for different applications.
cCaH is calcium hardness.
                                           3-17

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 inhibitor for steel when the pH is below about 8.0;  with
 increasing pH,  the solubility of zinc decreases,  and fouling may
 result.   Polyphosphates also are effective cathodic  inhibitors
 for steel,  but they may react with copper or aluminum.
 Consequently,  organic azoles are added to formulations  containing
 phosphate that are used in systems containing components made
 with copper alloys.   In addition,  because of the  nutrient value
 of  polyphosphate,  it is especially important to monitor
 microbiological activity and maintain the recommended types and
 concentrations  of  microbiocides in the recirculating water when
 polyphosphate  is used.   Orthophosphates are effective anodic
 inhibitors,  but they typically must be used in small quantities
 or  in conjunction  with phosphate-specific dispersants to reduce
 the likelihood  of  fouling.
 3.4.3 Scaling  and Fouling
      3.4.3.1 Description.   Scale  formation occurs when dissolved
 solids and  gases in  cooling water  reach their limit  of  solubility
 and precipitate onto piping and heat  transfer surfaces.  Fouling
 occurs when deposits of dirt,  leaves,  and/or flocculations of
 insoluble salts or hydrous  oxides  produced by corrosion
 agglomerate  in  the heat exchanger  tubes.   Scaling and fouling
 reduce the  flow rate and heat  transfer in any heat exchanger.
 These conditions also contribute to pitting-type corrosion by
 creating corrosion cells  and preventing the corrosion inhibitor
 from contacting the  surface of  the metal.   Calcium carbonate is
 the most common scale found in  cooling water systems, but calcium
 sulfate and  calcium  phosphate also can be  formed in many systems.
All  three types  of scale  become less  soluble  and, therefore, more
 likely to form  at  high  temperatures.   Calcium sulfate is more
 likely to form  at  low pH, and the  other two  scales are more
 likely to form  at high pH.
     3.4.3.2  Antiscalants  and Antifoulants.   Control of scaling
and fouling  is achieved by  controlling  deposition onto surfaces.
Deposition can be affected by changing  the  solubility of scale-
 forming salts, reducing the  crystalline growth capacity of scale-
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forming salts, and dispersing constituents that form fouling-
related flocculations.
     Chemical compounds that are commonly used and are the most
effective in controlling the rate of scaling include
polyphosphates, phosphonates,  and polymeric and copolymeric
dispersants.  These compounds reduce the crystalline growth
capacity of calcium salts.  Certain phosphonate compounds affect
the solubility of the calcium salts and reduce the formation of
scale.  Polymeric dispersants reduce the potential for
fouling.18'21'22
     Phosphonates typically are added to chromate-zinc
formulations as an alternative to phosphate because phosphonates
control scaling better than phosphate does.  Also, the amount of
chromate can be reduced when phosphonate is used because the
phosphonate system can be operated at a slightly higher pH.  A
disadvantage of using phosphonate is that the powerful oxidizing
potential of chlorine can promote corrosion of copper if
phosphonates are present in the system.  Adding benzotriazole  (or
other azoles) and dispersants can effectively control this
problem.  Phosphonates are also subject to biological oxidation,
which results in the release of. orthophosphonate ions that can
cause fouling as well as reduce the recommended concentration of
phosphonate.  However,  fouling is much less of a problem in
systems treated with phosphonate than in systems treated with
polyphosphates.18            •   .    •     .
3.4.4  Microbiological Control
     Three types of microorganisms are found in cooling tower
water systems:  bacteria, fungi, and algae.  Bacteria are
dispersed in the water, fungi invade wood components, and algae
attach to surfaces in the tower.  Slim'e produced by bacteria can
coat heat exchanger surfaces and aggregate debris on those
surfaces, thereby.reducing the efficiency of heat transfer.
Biological deposits on metal surfaces also can accelerate pitting
corrosion.  Fungi can decay wood either by surface attack  (soft
rot) or internal attack of the cellulose (white rot) and, thus,
are a threat to the structural integrity of wooden towers.  Algal
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 growth can coat the fill material and reduce the effectiveness  of
 the water droplet formation and,  thus,  the effectiveness  of  heat
 transfer in the tower.
      Microbiocides can  be classified as oxidizing agents,  enzyme
 poisons,  organic chemical compounds,  and miscellaneous  compounds.
 The oxidizing agents include chlorine,  bromine,  and iodine.
 Chlorine is the most widely used  and the least  costly
 microbiocide.   Enzyme poisons include methylene bisthiocyanate,
 acrolein,  and heavy metals (e.g.,  copper sulfate,  copper  citrate,
 tin,  phenylmercurie acetate,  and  methyl mercury).   Acrolein  and
 the heavy metals are considered to be outdated  technology and are
 not known to be currently used in IPCT  systems.   Organic
 compounds include dodecylquamidine hydrochloride and quaternary
 ammonium salts and normally require  high dosage rates.  Most
 microbiocides  used for  treating cooling water are.included in the
 categories above,  but dithiocarbamates  are a class  of
 miscellaneous  compounds  that  also are effective microbiocides.
 However,  they  reduce chromate and, thus,  cannot  be  used in
 chromate-treated systems.18/21
      Organic chemical compounds that  either hydrolyze to•
 relatively nontoxic forms  or  that  can be  detoxified are also used
 as microbiocides.   Hydrolyzable materials  include
 2,3-dibromo-3-nitrilopropionamide, chlorinated  cyanurates,' and
 halogenated hydantoins.  Chemicals that are both hydrolyzable and
 detoxifiable are methylene bis-thiocyanate  and bromonitro-
 styrene.   Isothiazolin is  a'widely used biocide  that can be
 detoxified.23
 3.4.5  Cooling  System Control
     A cooling  system chemical feed and monitoring  control system
maintains  the proper operating conditions  of  the cooling system
 to minimize  corrosion and  fouling.  Addition  of  treatment
 chemicals  is regulated to  prevent overfeeding and underfeeding
and thereby  optimize  performance and  operating costs.  Cooling
system control  is achieved by monitoring water quality conditions
and feeding  appropriate concentrations of the required treatment
chemicals described previously.  Control system components may
                               3-20

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include pH and conductivity monitors, a blowdown control valve,
corrosion inhibitor feed, acid feed, microbiological control
chemical (biocide) feed, and .a makeup water pump.  The components
of the control system may be completely automated via an
integrated computer system, automated yet function independently
of one another, controlled by a combination of automated and
manual controls, or operated manually.
     A minimum control system consists of pH and conductivity
monitors and some sort of chemical feed system.  This type of-
control system, whether manual or automated, maintains the proper
pH for effective corrosion inhibition based on the type of
corrosion inhibitor used.  This basic control system also
controls the blowdown through conductivity measurements to limit
conditions that favor scaling or fouling.  Computer-based control
systems are available that automate water quality.monitors and
chemical feed pumps.  The control system program operates the
chemical feed pumps based on measurements of specific water
quality parameters.  Even tighter control of chemical addition is
achieved through computer feedback loops in which the computer
compares the actual water quality to planned water quality
conditions and adjusts chemical feed pumps to achieve the desired
water quality conditions.
     The level of control automation required by a cooling system
depends on whether manual control at the plant is adequate to •
maintain acceptable pH and conductivity.  A system operated by
experienced personnel may not require as much automated control
as a plant with inexperienced personnel or a plant that lacks the
employee time to adequately monitor the cooling systems.
However, using automated equipment may offer savings in chemical
costs to some cooling systems through quality control and tighter
monitoring conditions, which are possible with computer-run  '
systems.  Although an automated control system may prove cost
effective, nonchromate- and chromate-based treatment programs
both can be operated successfully without such a system.19'20
                               3-21

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 3.5  MAINTENANCE REQUIREMENTS
     The maintenance requirements  for cooling  towers and
 associated heat  exchangers  are  a -function  of the  effectiveness of
 the  chemical  treatment  programs.   The effectiveness of the
 corrosion  inhibitor is  important to  the  life expectancy of metal
 surfaces exposed to the recirculating water in both the tower and
 heat exchanger.   Metal  structural  components of the tower such as
 steel  columns and beams,  connector plates  and  bolts, piping and
 pumps, valves, and  controller equipment  corrode from exposure to
 the  cooling tower water.  However, the most critical corrosion
 occurs in  the heat .exchangers.   Excessive  corrosion, followed by
 fouling in heat  exchangers, will result  in both the need for
 excessive  tube bundle cleaning  to  maintain heat transfer and tube
 bundle replacements  because of  pitting corrosion.
     Corroded tubes  may be discovered during routine inspections
 of the heat exchanger,  but, in  many  instances, contamination of
 the  recirculating water with process  fluid (or vice versa) is the
 first indication of  failed tubes.  Typically,  the leaking tubes
 are  identified and plugged.  Some  loss of  efficiency or cooling
 capacity because of  plugged tubes  can usually  be tolerated
 because cooling  systems are often  designed with an excess of heat
 exchange capacity.   However, in some  processes, this margin may
 not  exist because production levels are  such that a "capacity
 bottleneck" is present at the heat exchanger.  A new tube bundle
 generally  is  required when about 10 to 15  percent of the tubes
 are plugged.
     Scaling  and fouling can occur in both the cooling tower and
 the heat exchangers.  In the cooling  tower, scaling and fouling
 can reduce tower heat rejection capacity by interfering with
 splash or film fill  water distribution and the formation of water
droplets.   Airflow characteristics also can be altered when
airflow passages  in  the fill and drift eliminator become blocked;
 this blockage increases the pressure  drop  across the system and
reduces cooling  efficiency.  The tower fill and drift eliminator
 surfaces are  inspected periodically and cleaned if necessary.
Usually,  this work is performed during a process shutdown.
                              3-22

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However, cle'aning may be required more frequently if the scaling
rate increases because of poor control of the cycles of
concentration, contamination problems, or lack of attention to
the chemical treatment program.
     Scaling and fouling in heat exchanger tubes reduce the heat
transfer capacity because of the low thermal conductivity of the
crystalline film created on the tube surfaces and flow
restrictions that result.  The level of scaling and fouling in
heat exchangers and, thus, the level of maintenance required, can
vary with changes or variations in the water treatment program.
The scale and foulants can be removed physically by a process
called rodding, by water blasting, or by flushing with acids.
These physical cleaning methods require that the heat exchanger
be taken out of service until the maintenance ,is completed.
Alternatively, side stream filters can be used to continuously
remove silt and other foulants while the system is in service.
In industrial plants that operate nearly continuously, the heat
exchangers may not be inspected and cleaned for 3 years or more
unless a problem occurs.  Chemical cleaning also can take place
while the system is in service/ but the effectiveness of this
procedure depends upon the level of scaling or fouling.  If
strong acids are to be used, the heat exchanger will be taken out
of service to protect ancillary cooling water system components.
3.6  COMPOSITION AND FORMATION OF DRIFT
     Water droplets entrained in the air and the dissolved and
suspended solids contained in the droplets that are emitted from
the stack are referred to as drift.  These droplets contain the
chemical constituents, additives, and contaminants present in the
recirculating water.  The droplets are formed both from water's
splashing down through the fill material and from the shearing
action of the airflow along the water surfaces within the tower.
In the past, drift was usually associated only with the loss of
water from the tower stack, but the minerals, metals, and other
constituents of'the recirculating water are also emitted in the
drift droplets.  The rate at which drift is emitted from the
tower (i.e., the drift rate) is primarily a function of the air
                               3-23

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velocity through the fill  material,  the  recirculation  rate,  and
the  type of  fill material  and drift  eliminator  used.   Although
air  velocity has a greater impact  on the drift  rate, drift  rate
is usually expressed as  a  percent  of the water  recirculation
rates  for two reasons:   most  IPCT's  are  designed  so that air
velocities through the fill are  comparable,  and it is  much  easier
to measure the water recirculation rate  than the  air velocity
through  the  fill.   The rate of water flow through the  fill
material is  referred to  as "water  loading,"  and the range of
water  loading in IPCT's  is typically 81.5 to 410  liters per
minute per square meter  of a  horizontal  cross section  of the fill
(L/min/m2)  (2 to 10 gallons per  minute per square foot
[gal/min/ft2]),26'27 The  velocity of the airflow in the fill
typically is from 91 to  213 meters per minute (m/min)  (300  to
700  feet per minute [ft/min]).   At.91 m/min  (300  ft/min), the
airflow  will entrain all water droplets  smaller than
•370  micrometers  (/tm)  in  diameter (14.6 thousandths-of-an-inch
[mils]).   At 213 m/min  (700 ft/min),  water droplets smaller than
800  jim (31.5 mils)  in diameter will  become entrained in the
airflow.   A  drift eliminator  manufacturer indicated .that drift
rates  are highest when the air velocity  is at either end of the
range.   Within the overall range,  minimum drift rates  are
obtained over a  much broader  range for high-efficiency drift
eliminators  than for low-efficiency  drift eliminators.
     Velocities  in the stack  are usually between  460 and
550  m/min (1,500 and 1,800 ft/min) and,  thus, are capable of
carrying droplets  larger than 800  ^m (31.5 mils)  in diameter.28
If droplets  this large are created in or near the stack, possibly
by collision between droplets in the turbulent  air stream or by
impingement  and  condensation  of  smaller  droplets  on structural
members  near the fan, they may also  become entrained.
     Splash  fill towers  tend  to  have higher  drift rates than film
fill towers,  because splash fill is  designed to create water
droplets.  As mentioned  previously,  herringbone design drift
eliminators  are  the least  efficient,  and cellular drift
                               3-24

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eliminators "are generally the most efficient type of drift
eliminator.
     The recirculating water contains the corrosion inhibitors;
other additives; naturally occurring silica and calcium- and
magnesium-containing compounds; and other dissolved solids.  The
concentration of these dissolved solids increases in evaporating
drift droplets.  According to the theoretical calculations of
evaporation rates used to generate Table 3-4, droplets that are
created at 30 /xm (1.2 mils) and below get much smaller as they
evaporate, and the concentration of the solids in those droplets
increases as evaporation occurs.  Tests sponsored by EPA show
that, in many cases, over 90 percent of the Cr+^ emissions are
contained in droplets less than 30 fjaa (1.2 mils) in
diameter.29"31  Thus, the tower emissions may include water
droplets containing various concentrations of dissolved solids,
and the smallest of these droplets (<30 /jm [1.2 mils] in
diameter) may contain a significantly higher concentration of
dissolved solids, including chromate.
3.7  DRIFT EMISSION RATE
     As mentioned previously, drift is often expressed as the
percentage of the recirculating water flow rate that is emitted.
Based on test results, a drift eliminator manufacturer claims
that the achievable drift rates range from 0.001 to 0.02 percent
of the recirculating water.  The approximate dividing line
between drift rates for high- and low-efficiency drift
eliminators is 0.04 to 0.02 percent.  Those achieving a lower
percentage are "high efficiency," and those that cannot achieve
0.02 percent are "lower efficiency."32'33  However, it is
important to note that drift rate results are highly dependent on
the measurement method; therefore, achievable drift rate claims
may not be comparable if they are based on different measurement
methods.  According to a cooling tower manufacturer, differences
in drift rate measurement arise when drift is expressed in terms
of a percentage of the water flow rate because drift is more a
function of airflow rate than water flow rate.  Therefore, drift
should be expressed as a concentration of tower exhaust air
                               3-25

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 rather than 'as a percentage of the recirculating water flow rate.
 However, because water flow, rate is more easily measured than
 exhaust airflow rate, industry prefers to express drift in terms
 of percentage of water flow rate.32
      One drift measurement method employs a type of paper
 sensitive to the impingement of drift droplets.  An impinging
 droplet leaves a mark on the paper that, after microscopic
 examination,  can be correlated to the droplet size; thus,  the
 total mass of drift water may be calculated.  However, this
 method aerodynamically -excludes droplets smaller than about 30 /wn
 (1.2 mils)  in diameter.29'3°  Traditionally, the main focus of .
 drift control has been to minimize the deposition of droplets and
 salts in the  vicinity of the tower;  drift deposition on plant or
 personal property in the immediate area around the tower can be a
 nuisance.   Droplets less than 30  ^m (1.2 mils)  do.not deposit but
 evaporate further and remain airborne.34  Thus,  the sensitive
 paper method  measures only the portion of the drift most  likely
 to cause deposition problems  in the  immediate area around  the
 tower.
      Other measurement techniques  collect drift  droplets
 isokinetically.  A mineral  or  a tracer in the collected draft
 droplets  is recovered in  a  sample  train for  chemical analysis.  '
 The  chemical  analysis performed determines the mass  of the
 mineral or added tracer recovered  in the  sample.   Then, if  it  is
 assumed that  the concentration  of  the  salt or tracer in the drift
 is the same as that  in the  cooling water  itself,  the drift  rate
 can be calculated.   Minerals and tracers  that have been used  for
 analysis include, but  are not limited  to, sodium,, calcium,
magnesium, strontium,  and chromium.  The  collection  and recovery
 efficiencies  for this  type of method are greater than  those of
 the sensitive paper method.  Over time, several different
 sampling train configurations have been developed.   For a given
tower, different collection and recovery efficiencies may be
obtained with each of these configurations.  Therefore, drift
rates measured with different configurations may not be
comparable.

                               3-26

-------
     When these isokinetic methods are used to measure drift

rates it is assumed that the mineral or tracer concentration in

the drift is equivalent to that in the cooling water.  If,

because of droplet evaporation, the salt concentration is

significantly higher in the drift than in the cooling water, this

method may overestimate the drift water loss rate.  However,

regardless of this uncertainty in the drift rate, the emission

rate of the salt is accurately measured with the isokinetic
method.  This study is primarily concerned with the chromium '

emission rate, not the actual drift rate of water and salt

combined.  Therefore, the EPA emission tests performed in this

study report only the Cr+^ emission rate.  For each test, the

emission rate is expressed as a percentage of the Cr+6

recirculating rate.  (Further discussion on the EPA test program

is included in Section 4.1.4.)  This percentage can equal the

drift rate only if.the equivalent concentration assumption is

made.

3.8  REFERENCES FOR CHAPTER 3
 1.
 2.
 3.
 4.
 5.
United States Refining Capacity.  June 9, 1986.  National
Petroleum Refiners Association.  Washington, D.C.  pp. 5-17.
1987 Census of Manufactures.
Washington, D.C.
U.S. Department of Commerce.
 6.
Steel, USA:  Into the '80's, Techno-Economic-Report.
Institute for Iron and Steel Studies.  Green Brook, NJ.
January 1980.

Letter and attachments.  Roti, J., Drew Industrial Division,
Ashland Chemical, to Crowder, J., EPArlSB.  July 16, 1991.
Response to questionnaire on cooling water treatment
programs and control equipment.
 «
Letter and attachments.  James, E., Betz Industrial, to
Crowder, J.,' EPArlSB.  July 17, 1991.  Response to
questionnaire on cooling water treatment programs and
control equipment.

Questionnaire.  Eastin, P., Nalco Chemical Company, to
Myers, R., EPArlSB. . August 5, 1991.  Response to
questionnaire on cooling water treatment programs and
control equipment.
                               3-27

-------
  7.   Questionnaire.   Lutey,  R.,  Buckman Laboratories,  to
      Myers,  R.,_EPA:ISB.   August 6,  1991.   Response to
      questionnaire on cooling water  treatment programs and
      control equipment.

  8.   Responses  to Section 114 information  requests  Nos.  1  through
      94  listed  on Table  5-14.

  9.   Telecon.   Upchurch,  M.,  MRI,  with Dean,  J.,  Brown and
      Williamson Tobacco  Company.   October  31,  1986.  Number  of
      cooling towers.

10.   Telecon.   Upchurch,  M.,  MRI,  with Gallo,  T., Corning  Glass
      Works,  Inc.   October 31,  1986.  Number of cooling towers.

11.   Telecon.   Upchurch,  M.,  MRI,  with Mabry,  R., Mount  Vernon
      Mills.   October  31,  1986.   Number of  cooling towers.

12.   Telecon.   Upchurch,  M.,  MRI,  with Durvin,  T.,  PPG
      Industries,  Inc.  October 30, 1986.   Number  of  cooling
      towers.                                               .
13.  Telecon.  Upchurch, M., MRI, with Jordan, S., PPG
     Industries, Inc.--Glass Division.  October 30,  1986.
     of cooling towers.
Number
14.  Telecon.  Upchurch, M., MRI, with Howard, W., Jr.,
     R. J. Reynolds Tobacco Company.  December 2,  1986.  Number
     of cooling towers.

15.  Telecon.  Upchurch, M., MRI, with Ryan, S.,  Reynolds
     Aluminum.  October 23, 1986.  Number of cooling'towers.

16.  Chemical Engineers Handbook.  5th Edition.   J. Perry and
     Chilton, eds.  New York, NY.  McGraw Hill.   1973.

17.  Kelly, G. M.  A System-Efficient Approach to Cooling Tower
     Energy Modifications'.  Cooling Tower Institute Technical
     Paper No. TP-85-18.  New Orleans, Louisiana.  January 1985.

18.  McCoy, J. W.  The Chemical Treament of Cooling Water.
     Chemical Publishing Company, Inc.  New York,  NY.  1983.
     pp. 8-12, 21-44, 124-187.

19.  Memorandum.  Marinshaw, R., MRI, to Myers, R., EPArlSB.
     April 3, 1991.  Trip report:  Nalco Chemical  Company,
     Naperville, Illinois, on February 22, 1991.

20.  Memorandum.  Marron, J., MRI, to Myers, R.,  EPArlSB.
     April 3, 1991.  Trip report:  Betz Industrial, Trevose,
     Pennsylvania, on February 26, 1991.
                               3-28

-------
21.  Betz Handbook of Industrial Water Conditioning.  8th
     Edition.  Betz Laboratories.  Trevose, PA.  1980.
     pp. 167-190, 202-215.

22.  Strauss, S. and P. Puckorius.  Cooling-Water Treatment for
     Control of Scaling, Fouling, Corrosion.  Power Magazine.
     June 1984.  pp. S-l through S-24.

23.  The Nalco Water Handbook.  Nalco Chemical Company.
     F. Kemmer, ed.  McGraw-Hill Book Company.  New York, NY.
     1988.  pp. 20.1-22.22, 38.3-38.30.

24.  Letter.  Macht, W., Betz Entec, Inc., to Randall, D.', MRI.
     April 10, 1987.  Biocides and chromate-based water treatment
     programs.

25.  Letter and attachments.  James, E., Betz Laboratories, Inc.,
     to Crowder, J., EPA:ESED.  March 27, 1987.  Comments on
     draft background information document Chapters 3-6, 8.

26.  Baker, D.  Cooling Tower Performance.  Chemical Publishing
     Company.  New York, NY.  1984.  pp. 120-129.

27.  Telecon.  Randall, D., MRI, with Depalma, T., Custodis-
     Cottrell.  June 4, 1987.  Effect of water loading on drift
     rate.

28.  Telecon.  Nicholson, B., MRI, with Kuharic, I., Marley
     Cooling Tower Company.  October 15, 1986.  Cooling tower
     parameters.

29.  Emission Test.Report:  Exxon Company U.S.A., Baytown, Texas.
     EMB Report 85-CCT-3.  November 1986.

30.  Emission Test Report:  National Bureau of Standards Steam
     and Water Chill Plant, Gaithersburg, Maryland.  EMB
     Report 85-CCT-4.   November  1986.

31.  Emission Test Report:  Southeastern Manufacturing Facility.
     Draft.   Prepared for U. S.  Environmental Protection Agency,
     Research Triangle  Park, North Carolina.  September 1987.

32.  Telecon:  Bellin,  P., MRI,  with Holmberg, J., Marley Cooling
     Tower Company.  April 2, 1985.  Drift eliminator, efficiency.


33.  Telecon:  Bellin,  P., MRI,  with Holmberg, J., Marley Cooling
     Tower Company.  July 19, 1985.  Drift eliminator efficiency.

34.  Memorandum from Marinshaw,  R., MRI,  to Industrial Process
     Cooling  Towers Project Files.  September 9, 1991.  Draft.
     Relationships  between evaporation  and droplet  size.
                               3-29

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                 4.0   EMISSION CONTROL TECHNIQUES

4.1  CONTROL TECHNIQUES
     This chapter describes techniques that are available to
reduce hexavalent chromium (Cr+^) emissions from industrial
process cooling towers (IPCT's).   The control techniques
discussed include substituting nonchromate-based chemicals for
chromate-based water treatment programs and retrofitting towers
with high-efficiency drift eliminators (HEDE's).    .
4.1.1  Nonchromate Treatment Programs
     In recent years, research efforts in cooling water treatment
technology have focused almost exclusively on alternatives to
chromate for corrosion protection.  The result has been the
development of improved polymers that overcome the earlier
scaling and fouling problems with nonchromates and that have made
nonchromate water treatment programs more competitive to
chromate-based programs in cost and effectiveness.   Nonchromate
treatment programs typically consist of combinations of cathodic
inhibitors, anodic inhibitors, antiscalants, and dispersants.
Many of the compounds used in nonchromate programs are
essentially the same as those used as additives in the chromate
programs described in Section 3.4.2.2.  With all. nonchromate
inhibitors, monitoring and control are critical.  It is necessary
to control carefully the recommended pH and inhibitor concen-
trations.  Vendors typically recommend some level of automated
control  (i.e., automated control of chemical feed, blowdown, pH,
or some combination of these). 2~5  However, most systems do not
require total feed and control automation.  Good control of
nonchromate programs  can be achieved manually.  In addition, when
chlorine is used as a biocide, microbiological control is more
                               4-1

-------
 critical for"many of the nonchromate programs  that  require
 alkaline conditions because chlorine is  less effective  at higher
 pH levels than at the lower levels  characteristic of  chromate
 programs.4
      Suitable operating conditions  for common  nonchromate
 treatment programs are shown in Table 4-1.  Typical nonchromate
 formulations are  based on phosphates,  molybdates, zinc, and
 organics.  These  and less common programs are  discussed below.
    •  4.1.1.1  Treatment Formulations and Operating  Conditions.
      4.1.1.1.1 Phosphates.   Phosphate-based programs are widely
 used  in  IPCT's.   The constituents of phosphate-based  treatment
 programs include  orthophosphates and/or  polyphosphates  and
 dispersants.   The "dispersants"  used with phosphate programs are
 actually stabilizers that maintain  the solubility of phosphate
 under conditions  in which they  would otherwise be-insoluble.
 Concentrations of phosphates  in water treatment programs
 generally range from 4  to 18  parts  per million (ppm).   If the
 system contains copper  or copper alloys, azoles are included in
 the treatment  program to  prevent phosphate from reacting with the
 metal.   With these combinations, effective corrosion control can
 be achieved  and deposition of calcium carbonate and calcium
 phosphate scale can be  minimized.
      Phosphate inhibitor  programs may  be modified to treat water
 with  water quality limitations.  Increased use of additives or
 other program  modifications may  be  required to operate  a
 phosphate  program successfully under high iron concentrations,
 high  calcium hardness  (>800 to  1,000 ppm CaC03), high water side
 skin  temperatures  (60°  to 82.2°C [140° to 180°F]),   and  high
 chloride  concentrations  (up to  15,000  ppm chloride).5   An
 advantage  of phosphates over  chromates is that they do  not react
with  reducing  agents  (contaminants  such as H2S and  organic
 compounds) in  the  recirculating  water  and,  thus, do not lose
 their effectiveness  in  contaminated water.3'6
     4.1.1.1.2  Molybdates.  Until  recently,  molybdate  treatments
were rarely used  in  situations where the cooling water was
 contaminated because the  cost of molybdate treatments, under even
                               4-2

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 the best  of "conditions, was  substantially higher than the cost of
 phosphate-based and  other nonchromate treatment programs.  When
 used alone, molybdate, like  chromate, is required in very high
 concentrations to achieve satisfactory results  (typically several
 hundred ppm or even  higher for some conditions).  However,
 molybdate formulations incorporating other inhibitors (azoles,
 zinc, phosphate), phosphonates, dispersants, and surfactants have
 been developed.  With these  new formulations, the molybdate
 concentration in the recirculating water can be as low as 2 to
 6 ppm.  As part of a zinc-based program, molybdate can reduce
 mild steel corrosion rates and may function as an inhibitor for
 pitting corrosion.   For best results, it has been recommended
 that a passivating pretreatment be conducted for up to 1 week
 with molybdate at five times the maintenance dosage; but for many
 systems,  pretreatment at two to three times the maintenance      :
 dosage for 24 to 48  hours is sufficient.2'3'6'7
     Molybdate-based treatment programs are used successfully
 with a system pH in  the range of 6.5 to 9.0.  However, the metal
 oxide film can be easily destroyed if the system pH drops below
 the lower end of this range  (i.e., when the environment is highly
 corrosive), and deposition from scaling and fouling can interfere
with film formation  when the system p'H is at the upper end of the
 range.  These potential problems are controlled by adding
polymeric dispersants and phosphonates to the formulation.
Although  the quickest and best recovery from a pH excursion is
accomplished with chromate treatments, recovery from short-term
pH excursions reportedly is  good with molybdate treatments.
Molybdates are compatible .with all oxidizing and nonoxidizing
microbiocides.  Automatic control of pH, blowdown,  and inhibitor
feed rate is recommended.  Low water velocity should be avoided
because it can cause fouling and deposition, which damage the
film.2'3'6'7
     4.1.1.1.3  Organics.  A number of all-organic formulations
can be used to control corrosion.   Modified lignins and tannins,
polyamines, phosphonides, phosphonium compounds, and heterocyclic
nitrogen  compounds have been used, separately or in combination
                               4-4

-------
with each other, as primary corrosion inhibitors in all-organic
formulations.  Typically, the target concentration reported is
that of the total product (inhibitor, antiscalant, dispersant,
surfactant, etc.) rather than that of the primary corrosion
inhibitor or other individual components.  For most programs,  the
target concentration is 50 to 150 ppm of product.  The cost of an
all-organic program is greater than that of chromate and most
other nonchromate programs because the chemicals are more costly
and because larger amounts of the chemicals are required.
     The most common heterocyclic nitrogen compounds are the
azoles, which are excellent copper corrosion inhibitors.  Azoles
protect.copper by repairing defects  (penetration and areas of
erosion) that occur in the naturally formed protective film of
cupric oxide.  They also act synergistically with the natural
film of calcium carbonate precipitate.  Tolytriazole is one of
the most effective organic compounds, but it is the most
difficult to formulate.  The compound 2-mercaptobenzothiazole
also is effective but is oxidized to the inactive disulfide form
if chlorine is present.  When the formulation contains azoles,
another inhibitor also must be included to protect carbon steel
components of the cooling system.
     The introduction of organo-phosphorus compounds has led to a
new treatment procedure known as the alkaline approach.  This .
type of program relies on the natural alkalinity and the reduced
corrosivity of the water at high pH to inhibit corrosion.  The
system pH is raised to 7.5 to 9.0, and the organo-phosphorus
compound controls the precipitation of calcium carbonate and
other scale-forming species.  However, in some systems,
especially those operating at high temperature or with low flow
velocities, the program may also need to be supplemented with
other inhibitors.  An advantage of organo-phosphorus compounds is
that, unlike polyphosphates, they do not revert to orthophosphate
except under severe microbiological attack.  Thus, the likelihood
of fouling with organo-phosphorus programs is lower than with
polyphosphate-based treatment programs.
                               4-5

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      The protective films produced by all-organic treatments  are
 more easily damaged than those produced by chromate,  and closer
 control of operating parameters is required with all-organic
 programs than with chromate.   Microbiological  growth  and
 deposition must be strictly controlled to avoid interference  with
 film formation,  alkaline conditions must be maintained,  and the
 inhibitor concentration (or total product)  must not be allowed to
 fall below recommended levels.   Typically,  pH  is maintained in
 the  range of 7.5 to 8.5,  although in some programs it can be
 higher (8.8 to 9).   Because alkaline conditions decrease the
 toxicity of some biocides (e.g.,  chlorine and  methylene
 bisthiocyanate),  the consumption of biocides is greater  with  all-
 organic programs than with chromate programs.   Alkaline
 conditions are a major advantage of all-organic programs because
 acid feed is not required.8 Alkaline conditions also promote
 scale formation,  especially if  the water is very hard.
 Successful all-organic programs  depend on the  presence of some
 scale;  organic phosphates such  as the phosphonates are often
 included in the  formulation to  control the  amount.  The  best
 results  are achieved when the pH,  blowdown,  and inhibitor
 concentration are controlled automatically.2'3'6'7'^
      4.1.1.1.4  Zinc.   Zinc-based treatment programs  typically
 include  other inhibitors  (e.g.,  phosphates  and azoles) and
 organo-phosphorus and polymeric  dispersants.   The other
 inhibitors  are added-for  synergistic  effects to ensure adequate
 corrosion  inhibition.   A  combination  of  azoles  and zinc  are
necessary when the  cooling  system contains  copper components
because  zinc  (and phosphate) only protects  ferrous components.
Zinc  in  combination with  polyphosphate (alone  or with
orthophosphate)  can be  effective  when the calcium hardness of the
water is too  low for phosphates alone to maintain effective
corrosion inhibition.
     Dispersants are added because  zinc may otherwise be
precipitated  from the  recirculating water under  typical operating
conditions.   Excessive  levels of  orthophosphate  and contamination
with hydrogen sulfide both may cause  precipitation of zinc and
                               4-6

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 loss  of  inhibitor.   In  addition,  zinc hydroxides may precipitate
 at  high  pH  (greater  than  about  8) because  zinc  solubility
 decreases with  increasing pH.   However, various organic
 phosphorus  compounds and  polymeric  dispersants  can  control  the.
 amount of deposition and  increase the zinc solubility pH.
 Alkaline zinc programs  (pH  7.5  to 9) have  the highest temperature
 limitations of  nonchromate  programs.8
      4.1.1.1.5   No corrosion inhibitor.  A treatment- program
 without  a corrosion  inhibitor is  uncommon  and is used only  in
 systems  that are easily controlled,  that are constructed of very
.corrosion-resistant  heat  exchanger  materials, or that are not
 subject  to  high temperatures or contamination.  Only scale  and
 fouling  control agents  are  added, and a high pH is  maintained.
 Calcium  carbonate scale prevents  corrosion,  but the scale must  be
 controlled; insufficient  scale will not provide adequate
 protection, and excessive scale will hamper heat transfer.
 .Therefore,  makeup water must have calcium  hardness, and the
 amount in the  recirculating water must be  monitored closely.
 Automatic controllers help prevent  problems.  If antiscalants and
 dispersants are not  added,  the number  of cycles of  concentration
 must  be  decreased to prevent deposition, and blowdown must  be
 increased.   However, excessive scaling  is  still likely  to  occur
 in systems  with no corrosion inhibitor,  and, thus,  the
 maintenance effort is higher for such  systems  than for  systems
 using a  treatment program that includes  a  corrosion inhibitor.
      4.1.1.1.6  Others.  Nitrites and  orthosilicates  are two
 anodic inhibitors that are often used  in closed systems but are
 rarely used in open systems.  Nitrites  are required in  very high
 concentrations, are attacked by oxidizing  agents  and .certain
 bacteria,  are toxic to animal life, and are only  about  two-thirds
 as effective as chromate.  Orthosilicates  also must be  used in
 high dosages,  are slow to take effect,  and are not as effective
 as the other nonchromate inhibitors.3   Use of ozone as  a
 corrosion inhibitor has been reported in a small  number of
 cooling  towers but has not been given wide acceptance by
 industry.   No other chemicals are added with ozone to the
                                4-7

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 recirculating water; scale, corrosion, and microbiological growth
 are said to be controlled by ozone alone.  However,  rigorous
 monitoring and maintenance are required when ozone is used.10
      4.1.1.2  Effectiveness of Nonchromate Treatment Programs.
 Due to the limitations of the early nonchromate-based water
 treatment programs,  nonchromates were rejected by many in
 industry, particularly for IPCT systems that operated under high
 temperatures,  which generally are found in petroleum refineries
 and chemical manufacturing plants.   According to water treatment
 chemical vendors,  the problems with the initial nonchromate-based
 programs have largely been overcome and nonchromate-based water
 treatment programs can be designed to achieve results comparable
 to  chromates in most,  if not all,  IPCT systems.4'5
      Some responses  to information requests received in 1985 and
 1986 from petroleum refineries and steel plants indicated that
 treatment cost,  process debits,  fouling,  and corrosion rates
 increased when chromate programs were switched to nonchromate
 programs.11"27  A  few respondents  indicated that the problems,
 especially fouling,  became too severe to continue with
 nonchromates.   However,  other respondents indicated  that
 nonchromates worked  well;   Information gathered more recently
 from four petroleum  refineries and  18 high-temperature process
 chemical  manufacturing plants more  accurately demonstrates  the
 performance  capabilities  of the nonchromate-based programs
 currently in use.                 .
      During  site visits  to four petroleum refineries,  information
 was  collected  on 21  IPCT  systems.   Three  of  the four refineries
 used relatively poor quality makeup water and reported data  on
 heat  exchangers with carbon steel tubes  that  were  subjected  to
 severe process environments.   Recirculation  rates  for the IPCT's
 ranged from  12,100 liters  per minute  (L/min) .to 340,700 L/min
 (3,200 gallons per minute  [gal/min] to 90,000  gal/min).  The
majority  of  the 21 IPCT,systems  have  been operated on
nonchromates for at  least  6  years..  In most of  these  IPCT
systems,  the nonchromate-based treatment  programs  have performed
well and have achieved results comparable  to previous  chromate-
                               4-8

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based programs.  Although quantitative data on the changes in
performance of the water treatment programs following conversion
to nonchromates are limited, plant personnel were generally
pleased with the overall performance of the nonchromates.
Several operators pointed out that the more serious problems
originate on the process side of the heat exchangers, rather than
on the water side, and, thus, are not related to the type of
water treatment program.  Others also noted that serious problems
with the water treatment program occurred only in heat exchangers
that were operated outside the design ranges for temperature and
flow and that the same problems occurred in these heat exchangers
when chromate was used.
     Three of the four refineries reported no apparent change in
general corrosion rates (based on corrosion coupon .data)
following conversion to nonchromates.  Estimated carbon steel
corrosion rates for these three facilities were reported to be
less than 1 mil per year (mil/yr).  The fourth refinery, which
had mostly welded carbon steel heat exchanger tubes, reported an
increase in corrosion along the welded seams of the tubes
following conversion to nonchromates.  However, actual corrosion
rates were not available.  In addition, several of the plant's
heat exchangers were reported to be operating.above design
temperatures.
     Information on heat exchanger pitting was reported for three
of the four refineries.  Operators at one plant suspected that
although the incidence of pitting had not changed, .the pitting
rate had increased following conversion.  However, they had not
yet gathered enough data to quantify the increase.  Pitting in
one IPCT system at another refinery was reported to have
decreased following conversion.  For the majority of the IPCT
systems, however, there had been no apparent change in heat
exchanger pitting.
     Fouling generally was reported to be the same with both
chromate-based and nonchromate-based programs.  Two of the
refineries reported serious fouling problems, but the problems
occurred with both chromate-based and nonchromate-based programs.
                               4-9

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Of the 21 IPCT systems on which information was collected, an
increase in fouling was reported for only one system.28
     To further investigate the performance of nonchromate-based
water treatment programs in IPGT systems that served severe
process environments, information was gathered from manufacturers
of chemicals that are produced under high process temperaturers.
As a first step, several industry representatives were asked to
identify chemicals that are produced under very high
temperatures.  Additional high-process-temperature chemicals were
identified from Kirk-Othmer's Concise Encyclopedia of Chemical
Technology.  Process temperatures for these chemicals ranged from
300°C (572°F) to 1,100°C (2,012°F).  (The lower limit of this
range was arbitrarily selected to ensure a reasonably large
population of manufacturers from which information could be
collected).  A list of these chemicals and their corresponding
process temperatures is provided in Table 4-2.
     In response to an information request on the performance ,of
nonchromates in IPCT systems that are operated under "severe"
service conditions (i.e., systems with heat exchanger process-
side skin temperatures in excess of 1(71°C [160°F]), 18 chemical
manufacturing plants provided information on 41 IPCT systems.
The IPCT systems targeted for this information request serve
chemical manufacturing processes that require high process
temperatures.  Data were reported on a total of 524 heat
exchangers in severe process environments.  Recirculation rates
for the 41 IPCT's ranged from 1,960 L/min to 624,600 L/min
(520 gal/min to 165,000 gal/min), and averaged 132,500 L/min
(35,000 gal/min).  The IPCT systems have been operated with
nonchromate-based programs for an average of 6.1 years and range
up to 15 years.  In addition to the high, and in some cases
extremely high, heat exchanger operating temperatures, these
systems are operated with wide ranges of makeup water conditions,
heat exchanger materials, and various levels of control
automation.  Because chromate program data were unavailable for
many of the systems,  a comprehensive comparison of performance
between chromate-based and nonchromate-based programs is not
                               4-10

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 TABLE 4-2.  HIGH PROCESS TEMPERATURE CHEMICALS
Compound
1.
2.
3..
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
2- and 4 -methyl pyridine
Acetaldehyde
Adiponitrile (ADN)
Allyl chloride
Ammonia
Anthraquinone
Carbon monoxide
Carbon tetrachloride
Chloroform
Epoxy resin (EPR)
Ethylene
Hydrogen cyanide (HCN)
Methanol
Propylene
Tetrachloroethyle-ne (PERC)
Trichloroethylene (TCE)
Vinyl chloride (VC)
Temp., °C
350-550
480
. .
300

350-450

300-650
650-775

750-900
1,100

600-800
425
280-450
450-550
aBased on Kirk-Othmer's Concise Encyclopedia of
 Chemical Technology.
                       4-11

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 possible.   However,  based on the  information  provided,  the
 overall  performance  of  the nonchromate-based  programs appears to
 be  good, and,  in many cases,  exceptional.
      Based on  the corrosion rate  classification provided  in
 Table 3-1,  37  of the 41 IPCT systems had either mild or
 negligible corrosion and 3 systems  experienced moderate
 corrosion.  The  remaining system  reported a range of
 1  (negligible) to 14 (severe) mils/yr for the general corrosion
 rate.  However,  it should be noted  that the two plants  with the
 highest  reported corrosion rates  also reported problems with low
 pH  excursions  that could have accelerated corrosion in  the
 systems.
      Only  8 of the 41 systems were  characterized as having
 greater  than 5 percent  "problem"  heat exchangers  (i.e., those
 experiencing severe  corrosion, pitting, scaling, or fouling).  Of
 these  eight IPCT systems,  one is  reported to  have had an  increase
 in  the number  of problem heat exchangers following conversion to
 nonchromates,  and three are  reported ' to have  had no change in the
 number of problem heat  exchangers following conversion; chromate
 program data were not available for the other four systems.  Only
 7 of the 41 IPCT systems  were reported to need carbon steel tube
 bundles replaced more often  than  an average of once every
 10 years, and  none of the plants  reported a decrease in tube
 bundle life expectancy  following  conversion to nonchromates.  In
 only one of the  IPCT systems  were process upsets reported to have
 a greater adverse effect  on water treatment program performance
 following conversion from chromates to nonchromates.
     The severity' of  the  process environment  was defined  in terms
 of heat exchanger operating temperatures.  The process
 environment was  classified as severe if heat  exchanger  process
 side skin temperature exceeded 71°C (160°F).  For the 524 heat
 exchangers reported  to  operate in severe process environments,
process-side skin temperatures averaged 85°C  (185°F) and  ranged
up to 307°C (585°F);   inlet bulk fluid process temperatures
averaged 101°C (214°F)  and ranged up to 316°C (600°F);   outlet
bulk fluid process temperatures averaged 54°C (129°F)  and ranged .
                              4-12

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up to 149°C X300°F);  outlet bulk water temperatures averaged 38°C
(100°F)  and ranged up to 104°C (220°F).
     Among the IPCT's reported to be operating in the most severe .
process environments were two IPCT's at the PPG Industries, Inc.,
plant in Lake Charles, Louisiana.  These IPCT's serve vinyl
chloride (TE-I.I tower) and tetrachloroethylene/trichloroethylene
(Per Tri tower) processes.  The TE-II IPCT system has been
operated under a nonchromate-based program for 12 years and
currently uses a molybdate/zinc corrosion inhibitor formulation.
The Per Tri system has used a phosphate-based inhibitor for
15 years.  Process-side skin temperatures for the two systems •
averaged 107°C  (224°F) and 177°C  (350°F), respectively.  Other
heat exchanger operating temperatures were also above the  average
for all of the systems on which data were reported.  Both  IPCT
systems are operated  at seven cycles  of concentration, and pH,
conductivity  (blowdown), and chemical feed are manually monitored
and controlled.  In addition, in  the  TE-II system, three of the
five severe process environment heat  exchangers are operated
below design  flow--a  condition under  which more fouling and
underdeposit  corrosion would be  expected than  if  the  system
operated at design flow.  However,  despite these  conditions,  a
carbon  steel  corrosion rate of only 0.7 mils/yr  (negligible)  was
reported for  these two systems.   No problem  heat  exchangers are
reported for  either system.   In  addition, neither system  is
reported to have problems with scaling,  scheduled heat  exchanger
cleanings  are required no more than once per year,  and  no
unscheduled cleanings have  been  required.
      Other IPCT systems  that  had heat exchanger  operating
temperatures  among the highest  reported include  tower CT-301  EII,
which serves  an epoxy resin process at  the Dow Chemical Company
plant in Freeport, Texas,  and the OHC tower, which serves
 tetrachloroethylene and dichloroethane processes at the
 Occidental Chemical Corporation plant in Deer Park,  Texas.  The
 CT-301 EII system was converted to a phosphate-based inhibitor in
 May 1990.   At the same time,  an integrated control system was
 installed.  Carbon steel corrosion rates are reported to be less .
                               4-13

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 than 2 mils/yr, which is comparable to the corrosion rate
 reported under the previous chromate-based program.  Although
 other information on the performance of the nonchromate program
 for this system is limited, no problems are reported.
      The OHC system has operated under a phosphate-based
 corrosion inhibitor for 2 years, and chemical control is fully
 automated.  Carbon steel corrosion rates for both the current
 nonchromate and previous chromate programs are reported to be
 less than 1 mil/yr.   Since the conversion to nonchromates,  the
 scheduled cleaning frequency (once per year)  has not changed and
 no unscheduled process shutdowns have occurred.
      The only IPCT system for which high heat exchanger
 temperatures coincided with serious problems was the hydrogen
 cyanide/ammonia recovery IPCT system at the E.  I. 'du Pont de
 Nemours  & Company,  Inc.,  plant in Victoria,  Texas.   In this
 system,  process-side  skin and inlet bulk fluid process
 temperatures were  below or near average for the  group,  and  outlet
 bulk fluid temperature was  slightly above average,  but outlet
 bulk water temperature (66°C [150°F])  was the highest reported.
 This system has experienced severe fouling since the conversion
 from chromate to a phosphonate  corrosion inhibitor.   However,
 water treatment program performance is  expected  to  improve  when'
 the  facility switches  to  a  phosphate/zinc formulation in
 April 1991.
      In  order to analyze  the data  collected during  these
 investigations, makeup water quality was  defined in terms of  pH
 and  the  concentrations of chloride, total  hardness,  and total
 dissolved solids.  Typical  freshwater ranges  for.these parameters
 are pH 6 to pH  8; 10 to 100  ppm  chloride;  50  to  400  ppm total
hardness as calcium carbonate; and  25 to  5,000 ppm  total
dissolved solids.  Makeup water  quality is considered poor  if the
water is characterized by levels of any of these parameters
outside these typical ranges.  In addition, total dissolved
solids concentrations at the upper end of this range generally
require pretreatment before use as makeup water.   Makeup water
quality for the 41 IPCT systems covered by the information
                               4-14

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request varied considerably.  Total dissolved solids ranged from
2 to 800-ppm, pH ranged from 6.0 to 10.5, and hardness ranged
from 25 to 276 ppm as CaC03.  Chloride concentrations ranged from
4 to 200 ppm during average rainfall conditions and in some
systems up to 1,000 ppm during drought.  Among the systems using
the poorest quality makeup water, very few nonchromate program
performance problems were reported. .One facility with poor
quality makeup water reported an increase in carbon steel
corrosion rate and in the number of problem heat exchangers
following the conversion from chromates to nonchromates.
However, problems reported for other systems with poor quality
makeup' water were generally negligible..
     Although tight control of water quality parameters and
chemical feed is more critical for nonchromate-based than for
chromate-based water treatment programs,  the information request
responses demonstrated that sophisticated control systems are not
a requirement for successful nonchromate program operation.
Generally, the performance of cooling systems under manual
control is without notable problems.  For example, the largest
IPCT system for which information was obtained  (recirculation '
rate of  (624,600 L/min [165,000 gal/min]) was controlled manually
and reported no problems with the water treatment program.
Although more manually controlled systems than completely
automated systems  (i.e.,  systems with automated pH, blowdown, and
chemical feed control) were identified as having some minor
problems, manually controlled and semiautomated systems were
reported to have roughly the same occurrence of. only minor to
negligible problems.  The-data indicate that completely automated
systems produce slightly better results,  but other factors must
also contribute to the overall effectiveness of water treatment
programs.  The majority of  IPCT's experienced only negligible
performance problems regardless of the level of control
automation.29
4.1.2  Reduction of Drift
     Historically, the purpose of drift reduction has been to
alleviate the nuisance deposition of water drift and its
                               4-15                       •

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dissolved solids on nearby buildings or on personal property such
as automobiles.  More recently, the concern has focused on the
environmental impact caused by the compounds contained in the
drift and, thus, the deposition of these, compounds.  Installation
of HEDE's is the most common way to reduce drift.
     Drift eliminators are designed with pressure drops, lower
than those of other air pollution control equipment and rely
primarily upon the impaction of water droplets on drift
eliminator surfaces to reduce the amount drift exiting the
cooling tower.  The drift eliminator blades are configured to
force directional changes in the airflow such that the momentum
of the water droplets causes them to impinge onto the blade
surfaces.  The number 'of directional airflow changes, the spacing
between the blade surfaces, the angle of directional change, and
the capability to return the .collected water to a quiescent area
of the-plenum are .the major design differences in drift
eliminators that affect efficiency.
     Figure 3-3 shows sketches of various types of drift
eliminators.  Low-efficiency drift eliminators include
herringbone, some waveform (sinusoidal), and some cellular
designs.  Herringbone designs are constructed to create two or
three major directional changes in the airflow.  The blades are
sloped in opposing directions in a manner that provides drainage
of the accumulated drift into the fill area.  The blades
typically are constructed of wood, but other materials (e.g.,
metal and asbestos cement board) also are used.  Waveform drift
eliminators are configured in a sinusoidal wave pattern such that
two major directional changes in the.airflow are created.  The
sinusoidal blades are constructed of asbestos cement board or
polyvinyl chloride (PVC) material.  Cellular drift eliminators
are configured with thinner blades in a honeycomb pattern.  The
airflow passages in the cellular drift eliminators, which are
narrower than those of other designs, reduce the distance a
droplet must travel across the stream to impact on the surface.
Drainage of the collected water to prevent reentrainment is not a
design criteria of low-efficiency drift eliminators  (LEDE's).
                               4-16

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     High-efficiency drift eliminators include a few of both
cellular and sinusoidal designs.  The cellular HEDE's that
achieve the higher efficiencies are designed with complex
configurations that contain numerous, closely constructed airflow
passages.   Thin materials of construction .are used to reduce the
area of blockage to the airflow and minimize the pressure drop
that is created by the eliminator.  For•sinusoidal drift
eliminators, the blades are placed closer together in high-
efficiency designs than in low-efficiency designs, and the exit
is configured with a tip for draining captured water that
normally is partially reentrained in the airflow.  Typically,
drainage of water into a quiescent area of the tower is a major
design consideration of HEDE's.                                   .
     The performance of a drift eliminator is affected primarily
by the droplet or particle size' and the airflow velocities
through the drift -eliminator.  Small droplets are created both
from evaporation of larger droplets and the physical breakdown of
larger droplets into small droplets.  Parameters that affect the
rate of evaporation and the size of droplets created include the
water distribution system, the type of fill, the type of tower,
the meteorological conditions, and the temperature of the
recirculating water.
     A drift eliminator manufacturer indicates that HEDE's can
remove 80 percent or more of. the drift discharged from low-
efficiency herringbone drift eliminators.30  These drift
eliminator efficiencies, however, are based on data collected
with a test method that has not been submitted to EPA for
approval.   Five series of emission tests that included both
sensitive paper measurements and isokinetic tests were conducted
by EPA on towers-equipped with LEDE's and HEDE's.  Table 4-2
presents the results of the EPA-sponsored isokinetic tests at
Exxon's Baytown, Texas, refinery; the National Institute of
Standards and Technology  (NIST), formerly the National Bureau of
Standards in Gaithersburg, Maryland, a southeastern manufacturing
facility  (SMF); and Allied Fibers, Moncure, North Carolina.31"35
Table 4-2 also presents the results of an emission test conducted
                               4-17

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by Mobil Oil'-Corporation.36  For each test, an emission factor
was developed that expresses the Cr+6 emissions as a percentage
of the Cr+6 recirculating in the tower.  The Cr+6 emission factor
calculated from the test results for towers equipped with LEDE's
was set at 0.03 percent of the Cr+6 recirculating.  The emission
reduction achievable by using HEDE's instead of LEDE's was
determined to be 67 percent in simultaneous tests of towers of
similar construction and operation  (except for the drift
eliminator) at the SMF.  Therefore, the Cr+6 emission factor for
HEDE's was set at 0.01 percent of the Cr+6 recirculating.  The
Exxon and NIST data show that this level should be achievable by
Other towers equipped with HEDE's.  The NIST and Exxon HEDE Cr+6
emissions are much lower than 0.01 percent of the Cr+6
recirculating, and the emission reduction for HEDE's over LEDE's
at Exxon was about 88 percent.  Although the Exxon towers were of
different designs, they were operated in a similar manner during
the tests.  With the exception of the Allied test, the average
emission factors presented in Table 4-3 are largely consistent
with each other and industry estimates and are therefore believed
to be adequate for estimating nationwide Cr+6 emissions.
Additional discussion of the data and development of the emission
factors is presented in Section 5.2.
     For the EPA tests, in addition to isokinetic emission tests
that were performed to determine Cr+6 emissions from five cooling
towers, tests on three towers by the sensitive paper technique
were conducted to determine the mass emissions and size spectra
of the water drops greater than about 30 microns  (j*m) in
diameter.  Tests by the absorbent paper technique were conducted
to determine the emissions of Cr"1"6 in droplets greater than about
30 /mi in diameter.  The results of these tests consistently
indicated that greater 'than 90 percent of the Cr+6 emissions in
the drift were smaller than 30 /xm in diameter.31'32
     Emission tests sponsored by EPA indicate that HEDE
performance depends upon installation and maintenance practices.
Inspections should be conducted periodically to ensure that the
drift eliminators fit tightly around structural members so that
                               4-18

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TABLE 4-3. SUMMARY OF EPA- SPONSORED AND EPA- APPROVED
EMISSION TESTS30"35

Cr+^ emission factor*3
LEDE
HEDE
EPA- sponsored tests
Exxon
NIST (1st test)
SMF
NIST (2nd test)
Allied
0.0318a
0.0267
0.0037a
0.0038
0.0087
0.0051
0.337 to 1.471C
Industry test
Mobil
0.033

aAs discussed in Section 5.2, extreme outlying data were not
 included in these averages.
D<-tr+6 emission rate expressed as a percentage of the Cr+^
 recirculating rate.
GBased on test results for four surrogate elements.
                               4-19

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 cooling water cannot bypass them.   In addition,  towers' should be

 inspected for leaks  from the distribution deck planking to  ensure

 there  are no leaks bypassing the drift eliminators  into the tower

 plenum.   This leakage,  which is  often entrained  in  the high-

 velocity air in  the  stack,  can cause high .drift  rates.
 4.2  REFERENCES  FOR  CHAPTER 4
 1.
 2.
 3.
 4.
 7.
 8.
 9.
10
11.
Memorandum.   Marinshaw,  R.,  MRI,  to Myers,  R.,  EPArlSB.
January 19,  1990.   Meeting with George Brannon,  Nalco
Chemical Company,  on December 6,  1989.

Betz  Handbook of  Industrial  Water Conditioning.   8th
Edition.   Betz Laboratories,  Trevose,  Pennsylvania.  1980.
pp. 167 to 190, 205 to 215.

Strauss,  S.,  and  P.  Puckorius.  Cooling-Water Treatment  for
Control of Scaling,  Fouling,  Corrosion.   Power  Magazine.
June  1984.   pp. S-l through  S-24.

Memorandum.   Marinshaw,  R.,  MRI,  to Myers,  R.,  EPA:ISB.
April 3,  1991.  Trip report:   Nalco Chemical  Company,
Naperville,  Illinois, on February 22,  1991.

Memorandum.   Marron,  J.,  MRI,  to  Myers, R., EPA:ISB.
April 3,  1991.  Trip report:   Betz Industrial,  Trevose,
Pennsylvania,  on  February 26,  1991.

Simon,  D.   3tate-of-the-Art  Survey of  Nonchromate Cooling
Water Corrosion Inhibitors.   MTI  Manual No. 4.   Materials'
Technology Institute of  the  Chemical Process  Industries,
Inc.  July 1980.  pp. 1  to 24.

Letter  and attachments.   Metz,  B.,  Wright Chemical Corp., to
Crowder,  J.,  EPA:ESD.  April  9, 1987.  Comments  on draft
background information document.

The Changing  Chemistries  of  Cooling Water Treatment.
M. Kaufman.   Industrial Water Treatment.  October 1990.
pp. 13  to 16.                               .

McCoy,  J. W.  The Chemical Treatment of Cooling  Water.  New
York,  New York.  Chemical Publishing Company, Inc.   1983.
pp. 8 to  12,  21 to 44, 124 to 187.
Historical Perspective of Cooling Tower Ozonation.
and M. Bukay, ed's.  Industrial Water Treatment.
October 1990.  pp. 26 to 32.
                                                         A. Pryor
Letter and attachments.  Evans, R., AMOCO Oil Company, to
Myers, R., EPA:ISB.  June 14, 1985.  Response to Section 114
information request.
                               4-20

-------
12.  Letter and attachments.  Simmons, R., ARCO Petroleum
     Products Company, to Farmer, J., EPA:ESD.  June 3, 1985.
     Response to Section 114 information request.

13.  Letter and attachments.  Parker, F., Chevron U.S.A., to
     Farmer, J., EPA:ESD.  May 16 and 31, 1985.  Response to
     Section 114 information request.

14.  Letter and attachments.  Johnson, J., Exxon Company, U.S.A.,
     to Farmer, J., EPA:BSD.  May 20, 1985.  Response to
     Section 114 information request.

15.  Letter and attachments.  Dunn, W.,  Gulf Oil Products
     Company, to Farmer, J., EPA:ESD.  May 21, 1985.  Response to
     Section 114 information request.

16.  Letter and attachments.  Johnson, R., Phillips Petroleum
     Company, .to Farmer, J., EPArESD.  June 5, 1986.  Response to
     Section 114 information request.

17.  Letter and attachments.  Kienle, R., Shell Oil Company, to
     Farmer, J., EPA:ESD.  May 22, 1985.  Response to Section 114
     information request.    '                            ,

18.  Letter and attachments.  Hawes, R., Mobil Oil Corp., to
     Farmer, J., EPA:ESD.  May 20, 1985.  Response to Section 114
     information request.

19.  Letter and attachments.  Cox, R., Texaco U.S.A., to Farmer,
     J., EPA:ESD.  May 24, 1985.  Response to Section 114
     information request.

20.  Letter and attachments.  Mullins, J., Shell Oil Company, to
     Farmer, J., EPA:ESD.  August 7, 1986.  Response to
     Section 114 information request.

21.  Letter and attachments.  Felderman, A., Union Oil Company of
     California, to Farmer, J., EPArESD.  July 11, 1986.
     Response to Section 114 information request.

22.  Letter and attachments.  Kopeck, J., Union Oil Company of
     California, to Farmer, J., EPA:ESD.  July 11, 1986.
   ,  Response to Section 114 information request.

23.  Letter and attachments.  Campbell,  R., Union Oil Company of
     California, to Farmer, J., EPA:ESD.  July 11, 1986.
     Response to Section 114 information request.

24.  Letter and attachments.  Holmes, M., Chevron U.S.A., Inc.,
     to Farmer, J., EPA:ESD.  July 18, 1986.  Response to
     Section 114 information request.
                               4-21

-------
25.  Letter and attachments.  Boyer, D., Chevron U.S.A., Inc., to
     Fanner, J., EPA:ESD.  July 18, 1986.  Response to
     Section 114 information request.

26.  Letter and attachments.  Hannon, M., Chevron U.S.A., Inc.,
     to Farmer, J.  EPA:ESD.  August 5,  1986.  Response to
     Section 114 information request.

27.  Letter and attachments.  Lenz, G.,  Chevron U.S.A., Inc., to
     Farmer, J., EPArESD.  August 5, 1986.  Response to
     Section 114 information request.

28.  Memorandum. , Marinshaw, R., MRI, to Myers, R., EPArlSB. •
     May 15, 1991.  Summary of information gathered from
     California petroleum refineries.

29.  Memorandum.  Marinshaw, R., and J. Marron, MRI, to
     Myers, R., EPA:ISB.  June 7, 1991.  Preliminary analysis of
     Section 114 information requests on nonchromate-based
     cooling water treatment programs.

30.  Telecon.  Bellin, P., to Holmberg, J., Marley Cooling Tower
     Company.  July 19, 1985.  Drift eliminator efficiency.

31..  Emission Test Report:  National Bureau of Standards,
     Gaithersburg, Maryland.  EMB Report 85-CCT-4.  October 1986.


32.  Emission Test Report:  Exxon Company Petroleum Refinery,
     Baytown, Texas.  EMB Report 85-CCT-3.  November 1986.

33.  Emission Test Report:  Southeastern Manufacturing Facility.
     EMB Report 87-CCT-5.  Draft.  September 1987.

34.  Emission Test Report:  National Institute of Standards and
     Technology, Gaithersburg, Maryland.  U. S. EPA Contract
     No. 68D90055, ESD/TSD Project No. 85/02.  Draft.
     October 1990.

35.  Memorandum and attachments.  McClintock, s., Entropy, to
     Bivins, D., EPA/EMB.  June 5, 1991.  Cooling tower data
     analysis of the Allied Fibers emission test.

36.  Letter and attachments.  Hawes, R., Mobil Oil Corp., to
     Randall, D., MRI.  August 24, 1987.  Emission test results.
                               4-22

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                    5.0  MODEL COOLING TOWERS
 »

     This chapter defines design and operating parameters for
seven model industrial process cooling tower (IPCT) systems.  The
models represent the nationwide population of IPCT systems in
seven industries that currently use chromium-based chemicals in
the recirculating cooling water.  The seven industries are
grouped into four industry categories:  petroleum refineries,
chemical manufacturing plants, primary metals industry, and
miscellaneous industries.  The miscellaneous industries category
includes tobacco products, tire and rubber products, textile
finishing mills, and glass products.  This chapter also presents
emission factors that relate the hexavalent chromium (Cr+6)
emission rate to the Cr+^ recirculation rate for EPA-sponsored
emission tests an'd one industry test that used a sampling
procedure similiar to that used in the initial series of EPA
tests.  Finally, this chapter presents the nationwide estimated
baseline Cr+6 emissions for each industry and for the total of
all industries.                         .
5.1  MODEL IPCT SYSTEMS
     Six model cooling towers were developed to characterize the
existing size range of cooling towers in all industries, and each
industry is characterized by a distribution of up to four of
these model towers.  The baseline and controlled Cr+6 emission
rates are a function of the recirculation rate and the Cr+°
concentration in the recirculating water.  The Cr"1"6 emission
rates for the model towers were based on emission factors
developed from emission test data.
     The model towers were developed based on information
obtained from site visits, telephone contacts, and information
                               5-1

-------
requests.  It was necessary to rely upon engineering judgment in
those cases where the information obtained from cooling tower
users, chemical treatment vendors, industry sources, and source
tests was inconsistent and/or incomplete.
5.1.1  Model Cooling Towers
     Parameters used to define the model cooling towers include
the water recirculation rate, liquid-to-gas (L/G) ratio, cooling
range, cycles of concentration, and air velocity through the
fill.  These.parameters were used to determine other parameters
such as the heat load, tower dimensions, evaporation rate,
blowdown rate, airflow rate, and number of cells.  The heat load
that can be dissipated by the IPCT is a function of the
recirculation rate and the cooling range.  Although the average
cooling range may vary among industries, the average range of
11.1°C (20°F)  for petroleum refineries  (the highest and most
representative average, according to information request
responses) was applied to all industries.1  This action maximizes
the blowdown rate, which, as is shown in Chapter 8, results in
the highest (or worst case) water treatment chemical costs.
Average values also were assumed for the cycles of concentration,
L/G ratio, stack air temperature, and the efficiency of heat
dissipation in the fill, which minimized the number of model
tower types needed to characterize the industries.  Six model
IPCT's were developed, and the parameters for each are presented
in Table 5-1 and are discussed in greater detail in the following
sections.
     5.1.1.1  Recirculation Rate.  Recirculation rate is the main
parameter used to define a model tower; all other parameters are
a function of recirculation rate or are constant.  Model tower
recirculation rates were based on responses to information
requests from plants in each of the industries.2  An attempt was
made to group the recirculation rates that are characteristic of
each industry into ranges comparable to those of the other
industries.  This resulted in a total of six model tower sizes in
various combinations to represent the seven industries.  The
miscellaneous industries were represented by only one or two
                               5-2

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model tower types, and the petroleum refining, chemical
manufacturing, and primary metals industries were represented by
four model tower types each.  This arrangement was selected
because the overall range of recirculation rates obtained from
the information requests was much smaller for the miscellaneous
industries than for the other industries.  The ranges and
averages from the information requests and the resulting model
recirculation rates for each industry are presented in Table 5-2.
     5.1.1.2  Evaporation Rate.  The evaporation rate is a
function of the recirculation rate, the cooling range, and the
atmospheric temperature and humidity.  The evaporation rate can
be estimated with Equation 1, which was used to calculate
evaporation rates for the model towers:3
                       E = (0.00153)(R)(AT)                     (1)
where:                                            •
      E = evaporation rate, liters per minute  (L/min);
      R = recirculation rate of cooling water, L/min; and
     AT = cooling range of water, °C.                 .    .
     Atmospheric conditions also affect the ratio of  latent-to-
sensible heat transfer, which typically is about 4 to I.3  Also,
as discussed above, the average cooling range of 11.1°C  (20°F)
obtained from the information request responses from  petroleum
refineries was applied to all of the industries.
     5.1.1.3  Slowdown Rate.  Equations 2 and 3 present  the
approximate relationships among the blowdown, evaporation, drift,
and makeup rates and the  cycles of concentration.3'.4'5
                         M = B +E + D                          (2)
where:
C =

M =
B =
D -
C =
E =
  B + E + D
     B+D

makeup rate, L/min;
blowdown rate, L/min;
drift rate, L/min;
cycles of concentration; and
evaporation rate, L/min.
                                                               (3)
                                5-5

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Typically, the drift rate is either neglected or approximated as
up to 0.02 percent of the recirculation rate, and the cycles of
                          •'i. -             *
concentration are predetermined based on the makeup water quality
and the water treatment program.  Equation 4, produced by rear-
ranging Equation 3 and neglecting the drift rate, shows that
blowdown can be expressed as a function of cycles of concen-
tration and the evaporation rate:
                           B = E/(C-1)                         (4)
The information request respondents indicated that most towers
operate with two to eight cycles of concentration and that the
average is four.6  Thus, four cycles of concentration and the
evaporation rate determined from Equation 1 were used in
Equation 4 to calculate the blowdown rate for each.model tower.
     5.1.1.4  Tower Dimensions.  Model tower stack diameters were
determined from estimates of the airflow rate and velocity.  A
cooling tower manufacturer indicated that the L/G ratio varies
among towers from about 0.5 to 2.5 and that the stack and fans
are designed for air velocities in the range of 6.1 to
11.2 meters per second  (m/s) (1,200 to 2,200 feet per minute
          *7
[ft/min]).   The responses to the information requests indicate
that 0.8 is a typical L/G ratio.7  This ratio and the specific
volume of saturated air at the estimated average temperature in
the tower (32°G [90°F])  were used to calculate the airflow rate.
The total stack area was then calculated using an air velocity of
8.6 m/s (1,700 ft/min).   The number of fan cells per tower was
estimated by trial and error.  The stack area per cell was
determined by dividing the total stack area by the number of
cells selected, and the cell stack diameter was calculated from
the cell stack area.  The calculation procedure was repeated
until a series'of cell diameters was obtained that increased
slightly as the recirculation rate increased.  This relationship
of diameter to recirculation rate was indicated in the responses
to information requests and in manufacturers' product
literature.7'8  The resulting diameter was then rounded to the
nearest whole number and the individual cell stack area, total
stack area,  and the stack air velocity were recalculated.  The
                               5-7

-------
 revised air velocities differ from the target by less than
 6 percent (except for the smallest tower)  and are well within the
 design range.   Table 5-1 presents the results.
      The height of the tower depends on the type of fill and the
 efficiency of  the fill at creating a large water-to-air
 interface.  Responses to the information requests indicate that a
 wide range of  tower heights exists for a specific tower or cell
 recirculation  rate.  Because the model towers have been selected
 with similar recirculation rates per cell, selecting the tower
 heights based  on this parameter would result in nearly uniform
 tower heights.  However,  the responses to the information
 requests indicate that the tower height typically increases as
 the recirculation rate increases.8'9  Therefore, the data from
 the information requests have been used to estimate the heights
 of the model towers,  and the results are shown in Table 5-1.
      The lengths of the model towers were determined by assuming
•a distance of  1.2 m (4 ft)  between the fans and 0.6 m (2 ft)  from
 the end fans to the edge of the tower.  These values  are averages
 of distances observed during EPA-sponsored emission tests and
 obtained from  tower manufacturer product literature.   All but one
 of the six model towers were arranged with an equal .number of fan
 cells and riser ceils; the largest tower was arranged with two
 fan cells per  riser cell.   These configurations and the resulting
 lengths,  presented in Table 5-1, are within the range of those in
 the information request responses.®'9
      The widths of the model towers were determined by adding
 2.7 m (9 ft) to each side of the fan and 1.2 m (4 ft)  between
 fans.  The results are provided in Table 5-1 and, again, are
 similar to the widths reported in the responses to the
 information requests.^'9
 5.2  HEXAVALENT CHROMIUM EMISSION FACTOR
      In order  to estimate baseline and controlled emissions of
 Cr+6, emission factors were developed that relate the Cr+6
 emission rate  to the Cr+^ recirculation rate.  The emission
 factors express the emission rate as a percent of the
 recirculation  rate.  The percentage is equivalent to units (in
                                5-8

-------
this case, milligrams [mg])  of Cr+6 emitted per unit of Cr+6
recirculating in the tower (mg Cr+^ emitted/mg Cr+6
recirculating)..  Data from seven EPA-sponsored emission tests and
one industry-sponsored emission test were considered in
developing nationwide emission factors.  The EPA-sponsored tests
were conducted at the Department of Energy Gaseous Diffusion
Plant in Paducah, Kentucky (DOE-Paducah); the Exxon refinery in
Baytown, Texas (Exxon-Baytown); the National Institute of
Standards and Technology facility, formerly the National Bureau
of Standards, in Gaithersburg, Maryland (NIST-Gaithersburg); a
southeastern manufacturing facility  (SMF); and the Allied Fibers
facility in Moncure, North Carolina  (Allied-Moncure).  The
industry-sponsored emission test was conducted on two towers at
the Mobil Oil Corporation refinery in Torrance, California
(Mobil-Torrance).  Emission factors were developed for towers
equipped with low-efficiency drift eliminators (LEDE's) at Exxon-
Bay town, SMF, and Mobil-Torrance, and for towers equipped with
high-efficiency drift eliminators  (HEDE's) at Exxon-Baytown,
NIST-Gaithersburg, SMF, and Allied-Moncure.  Emission factors
were not developed for the test at DOE-Paducah because an unknown
quantity of chromium in the sample was lost during laboratory
analysis.  The average baseline  (LEDE) and controlled  (HEDE)
emission factors for each test site are presented in      •      •
Table 5-3.10"15
     Three procedures were used to calculate emission factors.
The Cr+6 emission factors for the Exxon and first series of NIST
tests were determined by dividing theoretical Cr+6 emission rates
by actual Cr+6 recirculating rates  (Procedure 1).  It was
necessary to calculate theoretical Cr+6 emission rates because
the Cr+6 concentrations in the recirculating water were not high
enough to collect sufficient quantities of Cr+6 in the sampling
equipment to allow-direct analysis for Cr+6.  The emission
samples were, however, analyzed for  total chromium, and the
recirculating water samples were analyzed for both Cr+6 and total
chromium.  It was then assumed that  the Cr+6-to-total chromium
ratio in the emission samples was equal to that in the
                               5-9

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recirculating water, and the theoretical Cr+6 emission rate was
calculated by equating the Cr+6-to-total chromium ratios.
     At the SMF, the Cr+6 emission factor was calculated by the
same procedure described above.  In addition, because
recirculating Cr+6 levels at the SMF were 10 to 20 times higher
than at any tower tested previously, emission samples were
obtained that could also be analyzed for Cr+6.  In this case, the
Cr+6 emission factors were determined by dividing the actual Cr+
emission rates by the actual Cr+6 recirculation rates
 (Procedure 2).  It was assumed that Cr+6 emission factors
developed using this procedure would yield results that were more
representative of actual Cr+6 emissions than would emission
factors developed using Procedure 1.  However, as shown in
Table 5-3, these emission factors are approximately 9 times lower
than the factors obtained by Procedure  1.  Further testing of
Procedure 2 by EPA  indicated that the test method was responsible
-for much of the conversion of Cr+6  to trivalent chromium  (Cr+  ).
     Data from the  Mobil-Torrance test  indicate that emission
samples contain a higher proportion of  Cr+3  than does the
recirculating water.  For the Mobil towers,  on average,  half of
the chromium in the emission samples was  in  the trivalent  form.
These test data were recorded using a slightly different  sampling
 train than was used for  the EPA-sponsored tests and were not
 subject to EPA  quality assurance/quality  control.  However,  the
 data from both  Mobil-Torrance  and  the SMF indicate that  a portion
 of the Cr+6  was reduced  to  Cr+3  prior to  sample analysis.   The
 additional testing  by EPA to determine  the cause  of  the
 conversion of Cr+6  to Cr+3  at  the  SMF test provides  reason to
 suspect  that the  same interference due  to sampling methods
 occurred at  the Mobil test.
     Unlike  the previous tests,  in which Cr+6 emission rates were
 determined by directly measuring either total or hexavalent
 chromium in  the recirculating  water and drift samples,  a
 different analytical procedure was used to determine emission
 factors  for  the second NIST-Gaithersburg and Allied-Moncure
 tests.   This procedure  (Procedure 3),  which has been used
                                5-11

-------
 extensively by the Cooling Tower Institute, uses surrogate
 mineral concentrations to determine the drift rate.  In the
 second NIST and Allied tests, the recirculating water and drift
 samples were analyzed for several native elements.  After
 screening, emission data for four elements were selected as the
 basis for determining the drift rate for each tower.  The overall
 emission factor for each tower was determined by averaging the
 individual emission factors for the four selected elements.  This
 method of determining tower emission factor relies on the
 assumption that the emission rate for any element in the
 recirculating water is the product of a constant overall tower
 emission factor and the concentration of the element in the
 recirculating water.   A serious shortcoming of this procedure is
 that there is little  scientific basis for the method of screening
 out certain elements  from the group of elements above detection
 limit in both the emission sample and recirculating water.
.Because of the wide range of emissions and concentrations of
 elements in the recirculating water,  the magnitude of the average
 emission factor calculated using this procedure is highly
 dependent upon which  elements are screened out.
      As shown in Table 5-3,  the range and standard deviation of
 emission factors developed from each set of test data indicate
 the difficulty in obtaining precise drift test results.   In
 addition to the chromium conversion issue,  which apparently
 biases  emission factors  developed using Procedure 2,  and the
 validity of the screening method used in Procedure 3,  other '
 problems were also experienced with the test program,  as
 described below.   However,  because  the average emission factors
 developed from the majority of the  tests are consistent with each
 other and with industry  estimates,  it  is believed that the  test
 results  are adequate  for  the  purposes  of estimating nationwide
 Cr+°  emissions.
 5.2.1 Baseline  Emission  Factor
      The nationwide baseline  emission  factor was  set  at
 0.03  percent  of  the Cr+6  recirculation rate.   This  value is  based
 on  the average of  LEDE emission factors  using Procedure  1 for  the
                               5-12

-------
EPA-sponsored tests at the SMF and Exxon and for the test
conducted by Mobil.  Two of the seven runs for the Exxon test
were not included in the average because they were considered
suspect.  The emissions for these two runs were substantially
higher than those for the other runs.  In fact, results from
these two runs indicated that the theoretical mass emission rate
of Cr+6 was comparable to or even greater than the mass discharge
rate of Cr+6 in the blowdown.a  This result contradicts
engineering judgment and is inconsistent with the makeup feed
rates of Cr+6 for these towers.  For these reasons, the two
outlying runs were declared invalid, and the Exxon LEDE emission
factor of 0.0318 percent of. the Cr+6 recirculating rate is based
on the remaining five runs.  Because of the chromium conversion
problem, emission factors developed using Procedure 2 were not
considered in determining the nationwide baseline.emission
factor.  Further, because neither the NIST nor the Allied towers ,
were equipped with LEDE's, Procedure 3 emission factors did not
apply to baseline emissions.
5.2.2  Controlled Emission Factor
     The nationwide controlled emission factor is dependent on
the emission reduction potential of HEDE's.  The tests at the SMF
were specifically designed to determine the effectiveness of
HEDE's and LEDE's operating under similar conditions.  Controlled
and uncontrolled towers of similar design and operation were
tested simultaneously under essentially identical meteorological
conditions.  Because of this specific test design and the good
test precision achieved at the SMF, the nationwide controlled
emission factor was calculated by applying the emission reduction
aFor example, the blowdown rate for Cooling Tower 68 was
 approximately 70 gallons per minute  (gal/min).  At an average
 Cr+° concentration of 7.6 mg/L, the Cr+6 discharge rate
 is approximately 120,000 mg Cr+6/hr.  For one run on Fan Stack 1
 of Cell 1  (recirculation rate = 2,100 gal/min), the measured
 emission rate was 25,060 mg/hr.  If this emission rate were
 projected for the entire tower  (recirculation rate
 = 22,500 gal/min), the tower emission rate would be
 approximately 270,000 mg/hr  (225 percent of the Cr+6 discharge
 in the blowdown).
                               5-13

-------
 observed in the tests at the SMF  (using Procedure 1) to the
 baseline emission factor.  Comparing the controlled and
 uncontrolled towers using data from the EPA modified Method 13
 test runs, the HEDE achieved a 67 percent emission reduction over
 the LEDE.  Therefore, the emission factor for HEDE's is
 0.01 percent of the Cr+6 recirculating rate.
      Although there was considerable scatter in the data from run
 to run, controlled emission factors developed from the Exxon-
 Baytown and both NIST tests averaged 0.0037, 0.0038 (first test--
 Procedure 1),  and 0.0051 percent  (second test--Procedure 3),
 respectively.   Thus,  the. nationwide controlled emission factor-
 developed from the SMF data is a conservative value that provides
 a margin above the highest value observed for an HEDE in
 available emission tests.   This value ensures that the emission
 reduction potential of HEDE's is not overestimated.   The NIST and
 Exxon controlled emission factors are significantly below this
 level,  and the emission reduction for HEDE's over LEDE's was'
 higher at Exxon than  at the SMF (88 percent  versus 67 percent).
 As with the baseline  runs,  however,  outlying data were not
 included in the average controlled emission  factor for the Exxon
 test.
      Data for  the Allied-Moncure test  indicate  an emission factor
 of 0.337 to 1.471 percent,  which is between  one and  two orders of
 magnitude higher than the average emission factor for  all  of  the
 previous tests.  Unlike  the Exxon-Baytown test  in which two of
 the seven runs  resulted  in  extremely high values,  the Allied
 results  are consistently higher  for all runs.   The reasons  for
 the very high results  are not understood.  However,  several
 factors  about the Allied test differ from the previous  tests.
 Because  the Allied tower serves a  direct contact  spray  heat
 exchanger,  the  cooling water contains a high concentration  of
 ethylene glycol  (9.5 percent).  In addition, the  cooling water
 treatment program includes an antifoaming agent and a dispersant.
According to a water treatment chemical vendor, the type of
dispersant used  (ethoxylated octylphenol)  acts as a surfactant to
reduce the surface tension of the cooling water.  This may result
                               5-14

-------
in the production of water droplets that are smaller than
otherwise would be formed in the tower and may increase the
number of droplets that exit the tower as drift.16  The
interaction of the ethylene glycol and cooling water additives
may also have an effect on the emission rate.  According to a
cooling tower vendor, ambient conditions also may have
contributed to the elevated emission rate at Allied.  In cool.
weather, cooling towers produce much more fog and condensation.
Condensate may redissolve solids encrusted on the tower
structural members and sampling equipment.  The resulting highly
concentrated liquid .can.then enter the sampling nozzle and
contaminate the sample.17  Because the Allied results are so much
higher than those of previous tests, the emission factor
developed from the Allied data was not taken into consideration  .
in developing a nationwide controlled emission factor.
5.2.3  Modeled Hexavalent Chromium Emissions
     The baseline Cr+6 emission rate for each model tower was
calculated by multiplying the nationwide baseline emission factor
by the model recirculation rate and the Cr+6 concentration in the
recirculating water as shown in Equation 5:
                              (K) (CCr+6) (R)          •          (5)
        ,ECr+6 -
where:
    ECr+6
Cr+6 emission rate, mg Cr+6/min
               .+6
        K =  Cr+D emission factor, 0.03 percent of recirculating
             Cr+6 (mg Cr+6 emitted/mg Cr+6 recirculating/100);
    CCr+6 =  concentration of Cr+6 in cooling water, mg Cr+6
             recirculating/L of water (for the model towers, this
             equals 5.83 parts per million [ppm] ); and
        R =  recirculation rate of cooling water,  L/min.
Analysis of information request responses showed that the
chromate concentration maintained in petroleum refinery cooling
towers using chromate-based treatment is about 13 ppm.18  Further
analysis of the limited data for other industries showed various
average chromate concentrations for individual industries, but
the average for the combination of all nonpetroleum industries
also was about 13 ppm.19  In addition, a survey conducted by the
                               5-15

-------
Chemical Manufacturers Association  (CMA) indicated that cooling
tower water at chemical manufacturing plants contains an average
of about 13 ppm chromate.
                         20
Thus, 13 ppm chromate (5.83 ppm
Cr+6) was used in Equation 5.
5.3  DISTRIBUTION OF MODEL TOWERS AND BASELINE EMISSIONS BY
     INDUSTRY
     Two major considerations within each industry category are
the number of model cooling towers each industry category
contains and the distribution of those model cooling towers among
the six model types.  The number and types of cooling towers
within a particular industry category are related to the typical
cooling demands for the processes involved.  As discussed in
Section 5.1.1.1, the model cooling tower size is determined by
the recirculation rate, and, as shown in Table 5-1, each industry
was characterized by one, two, or four model cooling tower types
based on the recirculation rate ranges obtained from information
request responses.  The total number of cooling towers in each
industry was estimated using the procedures discussed in
Sections 5.3.1 through 5.3.4.  These tower estimates were used
with the percentages of towers in each of the selected
recirculation rate ranges in Table 5-1 to determine the
distribution of each model type for each industry.  Hexavalent
chromium emissions for each industry were estimated from the
percentage of towers in the industry using chromate-based water
treatment, the Cr+6 concentration in the. recirculating water, the
emission factor, and the average fan utilization rate for the
industry.  The source of industry-specific data and the. baseline
emissions for each industry are also discussed in Sections 5.3.1
through 5.3.4.  Table 5-4 lists the Standard Industrial
Classification'(SIC) codes for each of the industries for which
Cr"*"6 emissions were estimated.
5.3.1  Petroleum Refineries
     In January 1986, there were 189 operating petroleum
refineries in the United States with a total crude operating
capacity of 14.64 million barrels per calendar day.21  The
refineries that responded to the information requests have a
                               5-16

-------
TABLE 5-4.
SOURCE CATEGORY STANDARD INDUSTRY
 CLASSIFICATION (SIC)
Source category
Petroleum refining
Chemical manufacturing :
Industrial organic
Industrial inorganic
Agricultural
Miscellaneous
Primary metals
Blast furnaces and steel mills
Primary copper
Primary nonferrous metals, N.E.C.
Glass products
Flat glass.
Glass containers
Tobacco products
Cigarettes
Cigars
Chewing and smoking tobacco
Rubber products
Tires and inner tubes
Dyeing and finishing textiles, except
wood fabrics and knit goods
Finishing plants, cotton
Finishing plants, manmade
Finishing plants, N.E.C.
SIC code
2911
2812; 2813; 2816; 2819
2861
2873; 2874; 2875; 2879
2891; 2892; 2893; 2895; 2899
3312
3331
3339
3211
3221
2111
2121
-2131
3011
2261
2262
2269
                     5-17

-------
 total crude capacity of 4.41 million barrels per calendar day and
 206 cooling' towers.18'21  The same ratio of towers-to-crude
 capacity was applied to all 189 refineries to obtain the estimate
 of 680 towers in the industry.  Data from the information request
 responses indicate that the mean concentration of chromate in the
 recirculating water is about 13 ppm, and that the fans run an
 average of 87.3 percent of the time.18  Current estimates by
 water treatment vendors indicate that approximately 20 percent of
 the towers in the petroleum refining industry are using chromate-
 based water treatments.22"24  Table 5-5 presents the tower and
 operating parameters and baseline Cr+6 emissions from cooling
 towers in the petroleum refining industry.
 5.3.2  Chemical Manufacturing Plants
      Two similar estimates of the number of chemical
 manufacturing facilities in the United States have been obtained.
 The CMA estimates that there are from 1,500 to 2,000 bulk
•chemical manufacturing plants.20  The 1987  Census of Manufactures
 from the U.S.  Department of Commerce indicated that there were
 5,341 chemical manufacturing establishments and that 1,824 of
 these establishments had more than 20 employees.25  It has been
 assumed that  the processes operated at most plants with fewer
 than 20 employees do not require cooling towers.   Therefore,
 emission calculations "have been based on the estimate that
 1,824 plants  have cooling towers.   Because  the towers in the
 chemical manufacturing industry were much smaller than those  in
 the petroleum refining industry,  according  to the information
 request responses,  the model tower types for the  chemical
 manufacturing  industry are also smaller.  The responses to
 information requests also indicated that there are about
 2.8 towers  per'plant and that the  fans run  an average of
 72.2  percent of the time.26  The results of a CMA survey indicate
 that  the average chromate concentration in  IPCT's at chemical
 manufacturing  plants is about 13 ppm.20  Current  estimates by
 water treatment vendors indicate  that approximately 10  percent  of
 chemical manufacturers  currently use chromium to  control
       ,   p p 9 4.
 corrosion.1" **   The tower and operating parameters  and the
                               5-18

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 baseline Cr+6 emissions from cooling towers in the chemical
 manufacturing industry are presented in Table 5-6.
 5.3.3  Primary Metals Industry
      The primary metals industry includes steel manufacturing
 plants and nonferrous primary metals plants.  The number of
 primary and specialty steel -making plants was based on the 1980
 Techno -Economic Report from the Institute for Iron and Steel
         *"J C
 Studies.     After adjustment to account for the number of plants
 known to be shut down, it was estimated that there are 149 plants
 in the industry.  The 1987 Census of Manufactures indicated that
 61 primary nonferrous metal plants have more than 20 employees.25
 As with the chemical manufacturing industry, it was assumed that
 only plants with more than 20 employees would have processes that
 need cooling towers.  Responses from steel manufacturers to the
 information requests indicate that each site has an average of
 4.6 cooling towers,  the average chromate concentration in the
 recirculating water  is 13  ppm,  and the  average daily fan
 utilization rate is  about  78.8  percent.28   Recent estimates by
 water treatment  vendors indicate that approximately 10 percent  of
 primary metals plants use  chromate -based water treatment
Table 5-7 presents the tower and operating
          22 -
programs. •"
parameters and  the  combined baseline  Cr+6  emissions from cooling
towers at steel -making  and primary nonferrous metal manufacturing
plants.
5-3.4  Miscellaneous  Industries
     This category  comprises other industries that -use chromium-
based corrosion inhibitors and includes tobacco products
manufacturing,  tire and rubber products manufacturing, textile
finishing mills, and  glass products manufacturing.  The number of
plants in each  industry has been estimated from the 1987 Census
of Manufactures by the  same procedure used to determine the
number of chemical manufacturing plants'.25  Based on the small
amount of data available from information request responses,
there does not appear to be large-scale use of chromium- based
corrosion inhibitors.   In fact, none of the responses to the 1987
information request from tobacco, textiles, and glass plants
                    .  .         5-20

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indicated that chromate-based corrosion inhibitors are used.
Recent estimates by water treatment vendors indicate that the
percentage of miscellaneous industry plants that use chromium
ranges from less than 1 to 5 percent.22"24  Thus, it was assumed
that 2.5 percent of the towers in these industries are using
chromate-based water treatment.  It also was assumed that the
average chromate concentration in towers for all of the
miscellaneous industries was 13 ppm, to be consistent with the
information for the other industries.
     5.3.4.1  Tobacco Products.  The tobacco products industry
contains 49 plants with greater than 20 employees, and each plant
has an average of about 5.5 cooling towers.25'29'30  Because the
towers are used primarily as part of climate control systems, the
heat load is moderate.  Thus, more than half of the industry has
been represented by the next-to-smallest model tower type.
Information request responses indicated that the fans operate
_about 59 percent of the time.30  Table 5-8 presents the tower and
operating parameters and the baseline Cr+6 emissions from cooling
towers at tobacco products manufacturing plants.
     5.3.4.2  Tire and Rubber Products.  The tire and rubber
products manufacturing industry contains 97 plants with greater
than 20 employees, each with an average of about 2.7 cooling
towers.25'31'32  Information request responses received in  1987
indicated that the industry can be represented by the next-to-
smallest model tower, that about 15 percent of the towers used
chromate-based water treatment, and that the fans operated  about
65.5 percent of the time.31  According to a water treatment
vendor, the number of plants using chromium in most industries
has decreased by at least 50 percent in the last 5 years, and, as
mentioned previously, responses from other vendors indicate that
the percentage of miscellaneous industries plants that use
chromate is generally less than 5 percent.22'24  Therefore, it is
assumed that a maximum of 7.5 percent of tire and rubber plants
currently use chromium.  Table 5-9 presents the  tower and
operating parameters and the baseline Cr+6 emissions from cooling
towers at-tire and rubber manufacturing plants.
                               5-23

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-------
      5.3.4.3-  Textile Finishing Mills.   The finishing step is
 assumed to require the vast majority of the cooling in the
 production of textile products.  Therefore,  the plants chosen  for
 this category were restricted to those  within the  SIC codes  for
 the finishing of various textiles.   The available  data indicate
 that there are 322 finishing plants  with greater than
 20  employees  and each plant has an average  of about 2.4 cooling
        O C  *3 O  O A
 towers.^3'JJ'J4   Because air washing systems and cooling of  air
 compressors comprise  the majority of the cooling requirement,  the
 heat load  is  moderate.   The information request responses
 indicated  that the industry could be represented by the smallest
 model tower.   The information request responses also indicated
 that the average fan  utilization rate is about 47  percent.34
 Table 5-10 presents the tower and operating  parameters and the
 baseline Cr+6  emissions from cooling towers  at textile finishing
 mills.
      5.3.4.4   glass Products.   This  industry includes  flat g"lass
 and  glass container manufacturing plants, which contain 38 and
 93 plants with greater  than 20  employees, respectively.25  From
 the  limited information request  data available,  it  is  estimated
 that  an average  plant can be  represented with 0.4  of the  next-to-
 smallest model tower  type.35'38   This corresponds  well  with the
model types used to represent  the.other  miscellaneous  industries.
Table 5-11 presents the  tower  and operating parameters  and the
baseline Cr+6  emissions  from  cooling towers at  glass products
manufacturing plants.
5.4  NATIONWIDE  EMISSIONS SUMMARY
     Table 5-12  summarizes  the estimated Cr+6 emissions for each
industry category and presents the estimated number of  cooling
towers and total nationwide emissions for all four industry
categories.  Chromium emissions from the  industrial cooling tower
source category are estimated to be  23 megagrams per year
 (25 tons per year).
                               5-26

-------






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5-28

-------
TABLE 5-12.  NATIONWIDE HEXAVALENT CHROMIUM EMISSIONS SUMMARY
Industry
Petroleum refining
Chemical manufacturing
Primary metals
Tobacco products
Tire and rubber
Textiles finishing
Glass manufacturing
TOTAL
No. of
cooling towers
using chroma te
136
510
97
7
2.0
19
1
790
Cr+6
Mg/yr
8.90
10.42
3.37
0.108
0.088
0.030
0.0039
22.9
Tons/yr
9.81
11.49
3.71
0.12
0.097
0.033
0.0043
25.3
                             5-29

-------
  Ref.
  No.
            TABLE "'5-13.
                   Company name
                              REFERENCES  FOR  RESPONSES  TO  SECTION  114
                                   INFORMATION  REQUESTS
        Bethlehem Steel Corp.
        Inland Steel Corp.
        Lone Star Steel Company
        LTV Steel Corp.

        McLouth Steel Products Corp.
        U.S. Steel Corp.
        Wheeling-Pittsburgh Steel Corp.
        Amoco Oil Company
        ARCO Petroleum Products Company

        Chevron U.S.A., Inc.
        Exxon Company U.S.A.
        Sulf Oil Products Company
        Mobil Oil Corp.
        Phillips Petroleum Company

        hell Oil Company
       Texaco USA
                                     Middletown, Ohio; Ashland, Ky!      ~          "             ~~
                                     Burns Harbor, Ind.; Johnstown, Pa.
                                     East Chicago, Ind.
                                     Lone Star, Tex.
                                     Warren and Cleveland, Ohio; Aliquippa, Pa.; Gadsden, Ala.

                                     Trenton, Mich.
                                     Fairiess, Pa:; Gary, Ind.; Lorain, Ohio; Orem, Utah
                                     Monessen, Pa.; Steubenville, Ohio
                                     Texas City, Tex.; Whiting, Ind., Salt Lake City, Utah; Savannah, Ga
                                     Femdale, Wash.; Houston, Tex.; Philadelphia, Pa.; PrudhoeBay, Alaska

                                     Pascagoula, Miss.; Bakersville and El Segundo, Calif.; El Paso Tex
                                     Baton Rouge, La.; Baytown, Tex.; Billings, Mont.; Bernicia, Calif. '
                                     Port Arthur, Tex.
                                     Ferndale, Wash.; Beaumont, Tex.; Paulsboro, N.J.; Joliet 111
                                     Sweeny and Borger, Tex.; Woods Cross, Utah

                                     Deer Park, Tex.; Norco, La.; Wilmington, Calif.
                                     Port Arthur,  Tex.;  Convent, La.; Wilmington, Calif.
       Occidental Chemical Corp.
       Pfizer, Inc.
       Acme Steel Company
       Kaiser Aluminum & Chemical Corp.

       Chevron U.S.A., Inc.
       Shell Oil Company
       UNOCAL Corp.	
                                    Anaheim, Calif.; Detroit, Mich.; Greenville, Ohio
                                    Niagara Falls, N.Y.; Columbia, Tenn.; Jeffersonville, Ind.; Pottstown, Pa
                                    Canaan, Groton, and Wellington, Conn.; Southport N C
                                    South Chicago, m.
                                    Spokane and Mead, Wash.

                                    El Paso, Tex.; Barber's Point, Hawaii; Pascagoula, Miss.; El Segundo, Calif
                                    Deer Park, Tex.; Martinez and Wilmington, Calif.; Norco, La.
                                    Lemont, HI.; Rodeo and Wilmington. Calif.
30
 Abbott Laboratories
 Air Products & Chemicals, Inc.
 American Cyanamid Hannibal Plant
 Armour Pharmaceutical
  (Rorer Group, Inc.)
 Bemis Specialty Films

 Borden Chemical
 Camac Corp.
 Cams Chemical Company
 Chevron Chemical—Ortho Division
 Dial Corp. (Greyhound Corp.)

 E. I. du Pont de Nemours & Company
Ferro Corp.
General Latex and Chemical Corp .-Ohio
Goodyear Tire and Rubber Company
 Harshaw/Filtrol Partnership

 f. R. SLmplot Company-Helm Plant
 U>nza, Inc. (Glycol Division)
 Lubrizol Corp.
 vfcCloskey Corp. (California)
 viilliken and Company

 Monsanto Agricultural Products
 Company
 Norton Thiokol, Inc.
 fepera, Inc.
 *-ReN Corp., Cherokee Nitrogen
 )ivision, Olin Chemicals
 Abbott Park, m.
 Allentown, Pa.
 Hannibal, Mo.
 Kankakee, m.

 Minneapolis, Minn.

 Diboll, Tex.
 Bristol, Va.
 Lasalle, HI.
 Richmond, Calif, (two plants)
 Montgomery, HI.

 Charleston, S.C.
 Culver City, Calif.
 Ashland, Ohio
 Beaumont, Tex.
 Cleveland, Ohio

 Helm, Calif.
 Painesville, Ohio
 Deer Park, Tex.
 Los Angeles, Calif.
  iGrange, Ga.

Luling, La.
 ireenville, S.C.
 •larriman, N.Y.
Pryor, Okla.
Charleston, Tenn.
                                                     5-30

-------
TABLE 5-13.   (continued)
Ref.
No.
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
83
84
85
86
87
88
89
90
91
92
93
94
Company name
Procter and Gamble
Reichhold Chemicals, Inc.
Rubicon, Inc.
Ruetgers-Nease Chemical Company, Inc.
SmithKline Chemicals
Standard Chlorine of Delaware
Stepan Company
Union Carbide Corp.
Uniroyal Chemical Company, Inc.
USI Chemicals Company
Vista Chemical Comany
General Foods Manufacturing Corp.
Holland Dairies, Inc.
Mallet and Company, Inc.
AFG Industries
Corning Glass Works
Appleton Papers, Inc.
International Paper Company
Arco Petroleum Products Company
Calumet Refining Company
Fina Oil and Chemical Company
Murphy Oil Company
Union Pacific Resources Company
Aurora Industries, Inc.
Revere Copper Products, Inc.
Chaparral Steel Company
Georgetown Steel Corp.
Nucor Steel Division/Nucor Corp.
American Fuel Cell and Coated Fabrics
Burlington Industries
Graniteville Company
Hitco
Winston Mills, Inc.
Copper Tire and Rubber Company
Cupples Company
Dunlop Tire Corp.
Gates Molded Products
General Tire, Inc.
Oliver Rubber Company, Oakland Plant
American Tobacco Company
Brown & Williamson Tobacco Company
Liggett and Myers Tobacco Company
Lorillard, Inc.
R. J. Reynolds Tobacco Company
Plant location(s)
Cincinnati, Ohio
White Plains, N.Y.
Geismar, La.
Gracewood, Ga.
Conshohocken, Pa.
Delaware City, Del.
Winder, Ga.
Danbury, Conn.
Geismar, La.
Morris, HI.
Westlake, La.
White Plains, N.Y.
Holland, Ind.
Carnegie, Pa.
Kingsport, Tenn. and Bridgeport, W. Va.
Wilmington, N.C.
Appleton, Wis.
Moss Point, Mass.
Femdale, Wash.
Chicago, m.
Port Arthur, Tex.
El Dorado, Ark.
Wilmington, Calif.
Montgomery, Dl.
New Bedford, Mass.
Midlothian, Tex.
Georgetown, S.C.
Darlington, S.C.
Magnolia, Ark.
Caroleen, N.C.
Graniteville, S.C.
Gardena, Calif.
Swannanoa, N.C.
Findley, Ohio
St. Louis, Mo.
Buffalo, N.Y.
Denver, Colo.
Akron, Ohio
Oakland, Calif.
Reidsville, N.C.
Louisville, Ky.
Durham, N.C.
Greensboro, N.C.
Winston-Salem, N.C.
          5-31

-------
 5.5

  1.


  2.


  3.


  4.


  5.



  6.


  7.



  8.


  9.


10.


11.



12.



13.




14.
 REFERENCES FOR CHAPTER 5

 Responses to Section 114 information requests Nos.  9-17
 listed on Table 5-13.

 Responses to Section 114 information requests Nos.  1-94
 listed on Table 5-13.

 Chemical Engineers Handbook.   5th Edition.   Perry and
 Chilton, eds.   McGraw Hill,  New York.   1973.

 Cooling Tower Fundamentals.   J.  Hensley,  ed.   Marley Cooling
 Tower Company,  Mission,  Kansas.   1983.
     ^ Handbook of Industrial Water Conditioning,  Eighth
 Edition.   Betz Laboratories,  Trevose,  Pennsylvania.   1980
 pp.  167-190,  202-215.

 Responses  to  Section 114  information requests  Nos.  1,  5-61
 69-66,  69-73,  76-94  listed on Table 5-13.

 Telecon.   Nicholson,  B.,  MRI,  with Kuharic,  I.,  Marley
 Cooling Tower Company.  October 15,  1986.   Liquid- to- gas
 ratios  and stack velocities.

 Responses  to  Section 114  information requests  Nos.  26, '30
 43,  50, 53, 59,  69,  77, 84 listed on Table  5-13.

 Responses  to  Section 114  information requests  Nos.  9-17,
 23-25 listed  on Table 5-13.                              •

 Emission Test  Report:  Exxon  Company Petroleum Refinery,
 Baytown, Texas.   EMB Report  85- CCT- 3.  November  1986.

 Emission Test  Report:  Southeastern Manufacturing  Facility.
 Draft.  Prepared for U. S.  Environmental Protection Agency,
 Research Triangle Park, North  Carolina.  September  1987.

 Emission Test  Report:  National  Bureau of Standards Steam
 and Water  Chill  Plant, Gaithersburg, Maryland.   EMB
 Report  85-CCT-4.  November 1986.

 Letter  and attachments.   Hawes,  R.,  Mobil Oil  Corp., to
 Randall, D., MRI.  August 24,  1987.  Response  to request for
 emission test  report on Mobil  Oil, Torrance, California,
 refinery.

 Emission Test  Report:  National  Institute of Standards and
 Technology, Gaithersburg,  Maryland.  U. S. EPA Contract
No. 68D90055,   ESD/TSD Project  No.  85/02.  Draft.  October
 1990.
                               5-32

-------
15.   Memorandum and attachments.   McClintock,  S.,  Entropy,  to
     Bivins,  D., EPA/EMB.   June 5, 1991.   Cooling tower data
     analysis of the Allied Fibers emission test.

16.   Telecon.  Marinshaw,  R.,  MRI, to Trulear, M.,  Nalco Chemical
     Company.  July 29, 1991.   Effect of  cooling water additives
     on drift rate.

17.   Telecon.  Marinshaw,  R.,  MRI, to Lindahl, P.,  Marley Cooling
     Tower Company.  July 23,  1991.  Factors that affect drift
     rate.

18.   Responses to Section 114 information requests Nos. 9-17,
     23-25, 69 listed on Table 5-13.

19.   Responses to Section 114 information requests Nos. 1,  5-8,
     18, 22,  26, 30, 43, 50, 53,  59, 77,  84 listed on Table 5-13.

20.   Letter and attachments.  Mayer, A.,  Chemical Manufacturers
     Association, to Cuffe, S., EPArlSB.   September 27, 1986.
     Summary of CMA member survey on corrosion inhibitors used in
     process cooling towers including average ppm in circulating
     water.

21.-  United States Refining Capacity.  June 9, 1986.  National
     Petroleum Refiners Association,  pp. 5-17.

22.   Letter and attachment.  James, E., Betz Industrial, to
     Crowder, J., EPAiISB.  July 17, 1991.  Response to
     questionnaire on cooling water treatment programs.

23.   Letter and attachment.-  Roti, J., Drew Industrial, to
     Crowder, J., EPA:ISB.  July 16, 1991.  Response to
     questionnaire on cooling water treatment programs.  .

24.   Telecon.  Marron, J., MRI, to Lutey, R., Buckman
     Laboratories.  August 2, 1991.  Information on cooling water
     treatment programs.

25.   1987 Census of Manufactures.  U.S. Department of Commerce,
     Washington, DC.

26.   Responses  to Section  114 information requests Nos. 18-20,
     26-61, listed on Table 5-13.

27.   Steel, USA:  Into  the  80's, Techno-Economic Report.
     Institute  for Iron and Steel  Studies.  Green Brook, NJ.
     January.   1980.  16 pp.

28.   Responses  to Section  114 information requests Nos. 1-8,  21-
     22,  76-78  listed on Table 5-13.
                               5-33

-------
29.




30.



31.



32.




33.



34.



35.




36.



37.



38.
Telecon\   Upchurch,  M.,  MRI,  with Dean,  J.,  Brown  &
Williamson Tobacco  Company.   October  31,  1986.  Number of
cooling towers.

Responses  to  Section 114 information  requests Nos. 90-94
listed on  Table  5-13.

Responses  to  Section 114 information  requests Nos. 84-89
listed on  Table  5-13.

Letter and attachments.   Carpenter, E.,  Uniroyal Goodrich
Tire Company, to Randall, D., MRI.  October  21, 1986.
Cooling tower and chemical treatment  data.

Telecon.   Upchurch,  M.,  MRI,  with Mabry,.R., Mount Vernon
Mills.  October  31,  1986.  Number of  cooling towers.

Responses  to  Section 114 information  requests Nos. 79-83
listed on  Table  5-13.

Telecon.   Upchurch,  M.,  MRI,  with Jordan, S., PPG
Industries--Glass Division.   October  30,  1986.  Number of
cooling towers.

Telecon.  Upchurch,  M.,  MRI,  with Gallo,  T.,  Corning Glass
Works, Inc.   October 31,  1986.  Number of cooling towers.

Telecon.  Upchurch, M.,  MRI,  with Durvin, T., PPG
Industries.   October 30,  1986.  Number of cooling .towers.

Responses to  Section 114  information  requests Nos. 65-66
listed on Table 5-13.
                              5-34

-------
                 6.0   REGULATORY  ALTERNATIVES

6.1  DEVELOPMENT OF REGULATORY ALTERNATIVES
     Based on an analysis of possible emission control
techniques, three regulatory alternatives have been developed
to assess the emission reduction and cost impacts of the
various control options on the model plants.  These
alternatives are listed below.
     1.  Regulatory Alternative I (Baseline)—No regulatory
action.  This alternative involves no further regulatory
action to control hexavalent chromium emissions from
industrial process cooling towers (IPCT's).
     2.  Regulatory Alternative II—Drift eliminator
retrofit.  This alternative would require that cooling towers
that use chromate-based chemical treatment programs be
retrofitted with high-efficiency drift eliminators (HEDE's).
     3.  Regulatory Alternative III—Nonchromate programs.
This alternative would require that only nonchromium-based
water treatment chemicals be used in cooling towers.
6.2  APPLICATION OF ALTERNATIVES TO MODEL TOWERS
     Baseline hexavalent chromium (Cr+6) emission estimates
were calculated for each category of model tower.  Similarly,
the incremental cost associated with each regulatory
alternative was determined for all models in all categories.
A reduction from baseline emissions was then determined for
each alternative, arid the cost effectiveness was calculated
(see Chapter 8).  Hexavalent chromium emissions estimates for
all regulatory alternatives are presented in Table 6-1.  The
cost and emission impact of each of the regulatory
alternatives beyond baseline are summarized below.
                             6-1

-------
      TABLE 6-1.
EMISSION ESTIMATES FOR ALL REGULATORY
      ALTERNATIVES

Petroleum manufacturing
Chemical manufacturing
Primary metals
Textile finishing
Tobacco products
Tire and rubber
Glass manufacturing
All industries
Cr+6 emissions under
regulatory alternatives, Mg/yr
I
(Baseline)
8.90
10.42
3.37
0.108
0.088
0.030
0.0039
22.9
IIa
3.04
3.56
1.15
0.037
0.030
0.010
0.0013
7.8
IIIb
0
0
0
0
0
0
0
0
      ^    the current best estimate of an achievable
 emissions reduction of 64 percent as supported by EPA
 tests.
"Based on 100 percent emission reduction through
 prohibiting use of chromate.
                           6-2

-------
     Regulatory Alternative II.  As explained previously in
Section 4.1.3, the best estimate of the emission reduction
achievable by an HEDE is 67 percent.  Assuming that 5 percent
of IPCT's already are equipped with HEDE's, the emission
reduction achievable with this alternative is 64 percent.
The cost of this alternative would be from the purchase,
installation, and testing of the drift eliminators in all
towers using chromate.  The enforcement burden for this
alternative is high and involves emission testing after every
retrofit to ensure compliance and annual inspections of all
IPCT's using chromate to ensure that the HEDE's are in good
condition and are properly sealed.
     Regulatory Alternative III.  A ban on all chromate use
in cooling towers would result in elimination of all public
health risk attributable to Cr+6 emissions from IPCT's.  The
cost of this option is attributable to increased chemical
cost of nonchromate treatment programs and the installation
of chemical feed and control equipment.  The enforcement
burden for this option is very low, involving prohibiting the
sale of chromate by chemical treatment vendors.
6.3  MACT FOR THE IPCT SOURCE CATEGORY                 '.  '
     To develop a NESHAP under the CAA as amended November
1990 requires that a distinction be made between major and
area sources.  A major source is defined as "any stationary
source or group of stationary sources within a contiguous
area and under common control that emits more than 10 tons
per year (tons/yr) of any one HAP or more than 25 tons/yr of
any combination of HAP's."  No known IPCT7s emit more than
10 tons/yr of chromium compounds.  However, the majority of
chromium-using IPCT's are located at facilities (including
most refineries and chemical plants and many primary metals
plants) that emit in excess of 25 tons/yr of HAP's.  Because
these three industries represent 80 percent of the
chromium-using plants and 94 percent of chromium-using
IPCT's, it can be assumed that most IPCT's will be considered
major sources.
                             6-3

-------
      The CAA as amended gives the Administrator discretion
 with regard to the appropriate control level to be required
 for area sources (i.e., those that emit less than the major
 source cutoff).  Such sources may be regulated using
 generally available control technology (GACT)  as opposed to
 maximum available control technology (MACT).   Just as with
 standards developed for major sources,  the Administrator may,
 for area sources, develop different standards  for new and
 existing sources.
      The MACT for new major sources is  defined to be no less
 stringent than the level of emission control achieved in
 practice by the best controlled similar source.   For existing
 major sources,  MACT must be no less stringent  than the
 average emission level achieved by the  best performing
 12  percent of existing sources or the best performing
 5 sources in categories with less than  30  sources.   These
 minimum required levels of control are  called  the "MACT
 floors."  The Administrator may also set standards  that
 "distinguish among  classes,  types and sizes of sources within
 a category or subcategory."   In determining MACT for a source
 category or subcategory,  costs and economic impacts must be
 considered.   Eight  years  after MACT is  established  an
 analysis of residual  risk is required in order to determine
 if  additional controls  are  necessary.
     There  is no  need to  define a "floor"  for  GACT,  but  a
 qualitative assessment  must  be made  that demonstrates  that
 the area  sources  cause  an adverse threat to health  or  the
 environment.  In  addition to costs  and  economic  impacts, the
 technical capabilities  of plant owners  or  operators who
 operate and maintain  the emission control  system must  also be
 considered.  However, a residual .risk analysis is not
required for GACT standards.
     As shown in Table  6-2,  nonchromates are used in
approximately 90 percent of  the IPCT's  in the  industries
affected nationwide.  It is  estimated that HEDE's are used in
only 5 percent of the IPCT's nationwide.  Thus, not only is
                             6-4

-------

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 the use o'f nonchromates the more effective hexavalent
 chromium emission control method,  nonchromates are more
 widely used than HEDE's.   Thus,  in the absence of
 subcategorization of the IPCT source category,  the MACT floor
 for existing major sources,  and  MACT for new major sources
 would be the use of nonchromates.   Because nonchromates are
 so widely used,  GACT for the IPCT  source category  is  likely
 to be use of nonchromates.
      As Table 6-2 also shows,  nonchromates are used in  at
 least 80 percent of the IPCT's in  each of the industry
 categories of concern.   Thus,  an industry-based
 subcategorization of the  IPCT source category would not
 result in any subcategory with a less stringent MACT.   In
 addition,  the available information indicates that
 nonchromates are currently used  in the majority of IPCT
 systems of all "sizes.   Nonchromates are in much more
 widespread use than chromate in  industries that use large
 IPCT's,  such as  petroleum refining and chemical
 manufacturing, and in  industries that use small IPCT's,  such
 as  textile finishing and  glass manufacturing.   Also>  in most
 plants,  IPCT's generally  are either all  on chromate or  all on
 nonchromates and,  as stated  above,  a large majority of  plants
 use nonchromates.   Thus,  a size-based subcategorization also
 would  not  change MACT  for. the  IPCT source category.  High
 process  temperatures and  poor  quality makeup  water  have been
 identified as  two  of the  most  critical parameters  for
 determining the  success of a cooling water  treatment program.
 Results  of  a recent  telephone  survey and  information request
 among manufacturers  of chemicals that  require high process
 temperatures indicate that nonchromates are used in more than
 80 percent  of the  IPCT's  that  serve  these processes and that
the nonchromate-based water treatment programs currently
available are achieving results comparable to or better than
chromate-based water treatment programs.  Further,  the
quality of the makeup water used by  the plants responding to
the information request varied considerably.  Results
                             6-6

-------
achieved at plants with the poorest quality makeup water did
not indicate a higher occurrence of problems related to the
water treatment program than were indicated for the plants
that used good quality water.  Thus, it does not appear that
subcategorization of the IPCT source category according to
process temperatures or water quality is warranted.
                            6-7

-------

-------
              7.0  ENVIRONMENTAL AND ENERGY IMPACTS

     An analysis of the environmental and energy impacts of the
regulatory alternatives specified in Chapter 6 for controlling
Cr+6 emissions from industrial process cooling towers is
presented in this chapter.  The incremental increase or decrease
in air pollution, water pollution, solid waste disposal, and
energy consumption for Regulatory Alternatives (RA's) II (high-•
efficiency drift eliminator  [HEDE] retrofit) and III (nonchromate
programs) as compared to RA I  (baseline) are discussed. . The
baseline control level represents the existing Cr+6 emission
level.  All impacts are based on the current population of towers
in each industry category presented in Chapter 5 and on the
industry growth projections that are presented in Chapter 9.
7.1  AIR POLLUTION IMPACT
7.1.1  Existing Sources
     The model towers established in Chapter 5 were used to
estimate the emissions of Cr+6,  phosphate,  and particulate  matter
(PM) from existing sources.  Table 7-1 presents the model towers
and the baseline emission rates of each pollutant.
     7.1.1.1  Primary Emissions.  The annual Cr+6 emissions for
the model towers in each industry are presented in Table 7-2 for
each RA.  The average number of cooling towers per plant, their
average size, and their utilization rates were used to calculate
the emissions.  The total baseline Cr+6  emissions from all  IPCT's
are 22.9 megagrams per year  (Mg/yr)  (25.2 tons per year
[tons/yr]).  The chemical manufacturing, petroleum refining, and
primary metals industries account for 99 percent of the total
Cr+6 emissions.
                               7-1

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      7.1.1.2--  Secondary Emissions.   Nonchromate treatment
 programs typically require higher levels of phosphates  and
 polymeric dispersants than chromate treatment programs.
 Nonchromate treatment programs may also contain molybdates.
 Thus,  secondary emissions of these compounds would increase  under
 RA III.   There are currently no Federal standards  for air
 emissions of any of these compounds.
      7.1.1.2.1  Phosphate emissions.   Phosphate compounds are  the
 most commonly used nonchromate water treatment.  To arrive at  a
 maximum  estimate of phosphate emissions from cooling towers, it
 was assumed that all towers not using ^chromates as corrosion
 inhibitors use phosphates and that  all towers using chromates  are
 using  them in combination with a phosphate  compound.  The typical
 concentration of phosphates in towers not using chromates is 14
 to  18  parts per million (ppm)  and in  towers using  baseline
 chromate programs -is 2  to 5 ppm (see  Table  7-3)-1   For purposes
 of  this  analysis,  a 15  ppm phosphate  concentration was assumed
 for towers using nonchromate programs,  and  a 3  ppm phosphate
 concentration  was assumed for towers  using  baseline chromate
 programs.   It  was assumed that the  emission factors developed  for
 estimating Cr+6  emissions from IPCT's also  apply to'phosphate.
     Phosphate emission estimates for each  RA and  each industry
 are presented  in Table  7-2.   Total  baseline phosphate emissions
 for all  IPCT's are  estimated to be  103.3 Mg/yr  (114 tons/yr).
 Phosphate  emissions  under RA III are  estimated  to  be 151  Mg/yr
 (166 tons/yr), a 45  percent  increase  over baseline.  Regulatory
Alternative  II would reduce  phosphate emissions  64  percent from
 towers using chromate.  This  would  result in an  overall phosphate
 emissions  estimate  of 95.1 Mg/yr (105  tons/yr),  an 8 percent
 reduction below  baseline.
     7.1.1.2.2   Zinc  emissions.  Zinc  is a  common  corrosion
 inhibition agent present  in many IPCT treatment  programs.  Almost
all current chromate programs  contain  zinc because  the two metals
act synergistically  to  inhibit  corrosion; therefore, less of each
is required.  Nonchromate treatments may also contain zinc at
levels similar to those in the  chromate/zinc  treatment they
                                7-4

-------
             TABLE  7-3.   CHROMATE-BASED CORROSION  INHIBITORS
Combination*
Chromate/orthophosphate
Chromate/orthophosphate/zinc
Chromate/polyphosphate/zinc
Chromate/zinc/phosphonate
Chromate/phosphonate
Chromate/phosphonate/dispersant
Concentration, ppnr*
20-25/3-3.5 •
5-10/10
15-25/2-5/2-5
15-25/2-5/2-5
10-20/3-5/3-5
20-25/5-10/2.5-3.0
5/10/unknown
15-25/2-4/3-5
2-3/2-3/5-10
20-25/2-4/3-5
5-10/3-5
5-10/not specified
5-15/2-6/2-6
Operating conditions
pH 7.0-7.5
pH 6-2-6.8
pH 6.2-6.8
pH 6.0-7.0
pH 6.5-7.0 CaH 100-600 ppmc
pH 6.0-6.5 CaH < 400-600 ppm
pH 6.5/7.2
pH 6.5-7.5
pH 6.5-7.0
pH 6.5-7.0
Not specified
pH 7.5-8.5
pH 7.5-8.5
aln all combinations the organic triazole corrosion inhibitors should be included at 1 to 10 ppm when the system
  contains copper.
bDifferent formulations are required depending on the pH range of operation.
cCaH is calcium hardness.
                                            7-5

-------
 replace.  As' chromate/zinc treatments are replaced by nonchromate
 treatments, zinc emissions are not expected to change
 significantly.2'3  Therefore, no zinc emissions estimates were
 calculated.
      7.1.1.2.3  Molybdate emissions.  Molybdate treatments
 currently have a very small share of the water treatment market.
 Although good performance can be achieved with these treatments,
 the chemical cost is much higher than that of other treatment
 programs.  Although the market for molybdate programs is expected
 to grow under RA III, predicting the amount of increased usage is
 not possible without extensive market research.  Also,  the
 toxicity of molybdate is lower than that of Cr+6,  and molybdate
 is not currently considered to be environmentally hazardous.4
 Therefore,  molybdate emissions were not estimated.
      7.1.1.2.4  Particulate matter.  Particulate matter emissions
 were calculated by assuming a total dissolved solids content of
,1,000 ppm in the recirculating water and applying a PM emission
 factor of 0.03 percent.  It was assumed that the emission factors
 developed for estimating Cr+6 emissions from IPCT's also apply to
 PM.   Thus,  PM-emissions are estimated to be 172 times higher than
 Cr+6 emissions from a baseline tower (1,000 ppm PM/5.82 ppm
 Cr+6).   Regulatory Alternative II would reduce PM emissions by
 64 percent  in towers that are retrofit with HEDE's.  Table 7-2
 presents the estimated emissions of PM for all industry
 categories  under each RA.
 7.1.2  New  Sources
      The projected Cr+6 emissions in the fifth year of  the
 standard were estimated by multiplying the current Cr+6 emissions
 in each industry by the projected annual production rate change
 of that industry compounded over 7 years.   The baseline year for
 the regulation is 1991;- therefore,  the emission estimates were
 projected 7 years from 1991 in order to include emission
 estimates for 1998,  which will be the fifth year of the standard.
 In some cases,  the available information was extrapolated because
 projections were provided for less than 7 years or for  only
                                7-6

-------
segments of a particular industry.  The estimated Cr*6 emissions
in 1998 for each industry and each RA are presented in Table 7-4.
     The chemical manufacturing industry is expected to increase
production by an annual rate of,2 percent from 1991 to 1995.^  No
information was available regarding growth rates past 1995;
therefore, it was assumed that the chemical manufacturing
industry would continue to increase production at the same annual
rate through 1998.  The petroleum refining industry is expected
to increase production capacity by less than 2 percent from 1991
to 1996.6  Therefore, the annual growth rate for that time period
is approximately 0.4 percent; this growth rate was assumed to  •
continue at the same rate from 1996 to 1998.  The production of
tires and nontire rubber products is expected to increase 1 to
2 percent in 199O.7  An annual growth rate of 1.5 percent was
applied from 1990 through 1998.
     Primary iron and steel production is expected to decrease by
greater than 10 percent in 1991 and then return to 1990 levels in
1992.  After 1992, shipments are expected to remain relatively
the same over the long term.8  An average annual growth rate of
0.2 percent per year was applied to nonferrous metals production.
Because the nonferrous metals make up approximately 38.5 percent
of the primary metals industry (as discussed in Chapter 5), an
average annual growth rate of 0.1 percent was used for the'
primary metals industry.  An average annual growth rate of
1 percent was applied to glass production from 1991 to 1998.
The output of tobacco products is expected to decline by as much
as 5 percent per year for the next 4 years.^  This decline was
applied through 1998.  Production of textile, mill products
increased 1 percent per year from 1988 to 1990.9  This growth
rate was applied through 1998.
     The total phosphate and PM emissions for each industry in
1998 are also presented in Table 7-4.  The total baseline Cr+6
emissions from all industrial process cooling towers  (IPCT's) are
estimated to be 25 Mg/yr (28 tons/yr) in 1998.  This represents
an increase in emissions'of 9 percent between 1991 and 1998.
                               7-7

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 7.2  WATER  POLLUTION  IMPACT
     Regulatory Alternative  III affects the  chemistry of the
 cooling water  and would affect the  chemistry of the blowdown,
 which may result in water pollution impacts.  As users switch
 from chromate-based treatment programs to nonchromate-based
 treatment programs, substitutes for chromate must be added to the
 cooling water.  Among the possible  substitutes are phosphates,
 phosphonates,  zinc, and molybdates.  The relative increase or
 decrease in discharges of Cr+6 and  phosphate under the various
 RA's was estimated using the model  towers developed in Chapter  5
 and  presented  in Table 7-5 and Table 7-6.  Blowdown rates for
 each tower  were multiplied by the average concentration of each
 chemical in the cooling water before and after implementation of
 each RA to  calculate  the discharge.
 7.2.1  Chromium Discharges
     Table  7-5 presents the  estimated discharges of Cr+6 via
.blowdown for each industry category under each RA.  The baseline
 discharge was  calculated using the  model chromate level of 13 ppm
 (5.82 ppm Cr+6) and the blowdown rate for each model tower.
 Current Cr+6 discharges are  estimated to be  400 Mg/yr  (440
 tons/yr).   These untreated discharge estimates represent Cr+6
 contained in IPCT blowdown prior to treatment.  Current water
 regulations require that most of these discharges be treated for
 Cr+6 removal either on the plant site or at  publicly owned
 treatment works  (POTW's).
     Regulatory Alternative  II  (requiring HEDE retrofits) would
 not  change  the quality of  the water effluent from IPCT's, and
 pollutant discharges  would  remain  essentially the  same  as those
 under RA  I. Regulatory Alternative III would eliminate all water
 discharges  of  Cr+6.
 7.2.2   Phosphate Discharges
     Phosphorus  is  an essential  nutrient  for plants  and animals.
 Excessive discharges  of phosphorus, however, to  lakes  and streams
 can promote the  growth of  algae, which  can  produce toxins and
 raise  the biochemical oxygen demand. The net result  is a lower
 dissolved oxygen level, which can  have  disastrous consequences
                                7-9

-------
TABLE 7-5".  ESTIMATED WATER DISCHARGES (1991)  OF HEXAVALENT
          CHROMIUM FOR ALL REGULATORY ALTERNATIVES
Industry
Petroleum refining
Chemical manufacturing
Primary metals
Textiles finishing
Tobacco products
Tire and rubber
manufacturing
Glass manufacturing
All industries
No. of Cr-
using towers
136
510
97
19
7
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Annual nationwide
Cr+6 discharge, Mg
Baseline
and RA II
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182
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for aquatic life.  Nonchromate treatment programs often contain
phosphorus in the form of phosphates or phosphonates.  To
estimate the maximum increase in phosphorus levels under RA III
it was assumed that:   (1) all towers currently using chromates
would switch to a phosphate-containing treatment program,
(2) current chromate treatments would contain 3 ppm phosphate,
and (3) nonchromate treatments would contain 15 ppm phosphate.
     Table 7-6 shows the baseline phosphate discharges and the
discharges under RA III to the receiving water for each industry
category.  The current discharge rate (7,700 Mg/yr
[8,470 tons/yr]) is expected to increase by 826 Mg/yr
(909 tons/yr)  (approximately 11 percent) to 8,524 Mg/yr
(9,376 tons/yr) under RA III.  Table 7-7 compares this estimated
discharge increase from cooling towers to discharges from
selected phosphorus sources.
     Phosphorus export coefficients estimate the mass loading of
phosphorus to a surface water body per year per unit of source
(e.g., hectare  [HA]).11  These coefficients are used to model the
loading from similar sources.  However,  numerous factors affect
the coefficients' magnitude.  Export coefficients are calculated
from watersheds with known soil types, precipitation, land uses,
and other site-specific characteristics that alter runoff.  An
export coefficient is selected to model the mass loadings of a
watershed by matching the characteristics of the two watersheds
as closely as possible.  Thus, the nationwide phosphorus loadings
from particular sources listed in Table 7-7 are presented in
ranges that represent variability in loadings due to varying
characteristics incorporated in export coefficients that may be
applied to that source type.  The total discharge of phosphorus
from IPCT's under RA III is relatively small compared to the
other selected sources .listed in Table 7-7.  However, the impact
of increased phosphorus discharges on a site-specific basis could
affect the nutrient condition of local receiving waters.
                               7-12

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 7.2.3   Zinc Discharges
     As stated  in  Section  7.1.1.2.2, nonchromate treatments
 contain levels  of  zinc  similar  to  those  in baseline chromate
 programs.  Therefore, zinc discharges are not expected to
 increase under  any of the  RA's.
 7.2.4   Molybdate Discharges
     As stated  in  Section  7.1.1.2.3, there are not presently
 enough  data to  estimate the amount of increased use of this
 chromium substitute.
 7.2.5   New Sources
     Growth factors presented in Section 7.1.2 were used to
 estimate the trends in  Cr+6 and phosphate discharges over the
 7-year  period from 1991 to 1998.  Tables 7-8.and 7-9 present the
 growth  factors  for  each industry and the projected  (1998)
 discharges of Cr+6  and  phosphate  (respectively) for each
 regulatory alternative.
     The total  baseline discharges of Cr+6 in 1998 are estimated
 to be 426.8 Mg  (469.5 tons/yr).  This represents an increase in
 Cr+6 discharges of  6.5  percent between 1991 and 1998.  Baseline
 discharges of phosphate in 1998 are estimated to be 8,168 Mg  .
 (8,985  tons/yr).  This  represents an increase in phosphate
 discharges of 7.2 percent  between 1991 and 1998.
 7.3  SOLID WASTE DISPOSAL
     Slowdown from  cooling towers may be treated to reduce the
 concentrations  of corrosion inhibitors (e.g., chromium, zinc,
phosphorus, and molybdenum).  The resulting sludge is likely to
be more  concentrated in these elements than the blowdown was
before  treatment.
     Chromium-containing solid waste (i.e., the treatment sludge)
 is sometimes identified as a hazardous waste, EPA hazardous waste
No. D007, under Resource Conservation and Recovery Act (RCRA)
Part 261 Subpart C--Characteristics of Hazardous Waste; it is
considered a hazardous  waste if its leachate by the Toxicity
Characteristic Leaching Procedure contains greater than
5 milligrams per liter  (mg/L)  total chromium.  Chromium-
containing waste is also subject to the  Land Disposal
                              7-14

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TABLE "-7-8.  ESTIMATED WATER DISCHARGES OF HEXAVALENT
  CHROMIUM FOR ALL REGULATORY ALTERNATIVES  IN 1998
                (5th Year of Standard)
Industry
Petroleum refining
Chemical manufacturing
Primary metals
Textiles finishing
Tobacco products -
Tire and rubber
manufacturing
Glass manufacturing
All industries
Annual
growth rate
projection,
percent
0.4
2
0.1
1
-5
1.5
1

Animal nationwide
. Cr4"6 discharge, Mg
Baseline
and RA II
159
205
59
0.6
1.4
1.7
0.1
426.8
RA III
0
0
0
0
0
0
0
0
                         7-15

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TABLE 7-9.'- ESTIMATED PHOSPHATE DISCHARGES FOR EACH REGULATORY
                     ALTERNATIVE IN 1998a
                   (5th Year of the Standard)
Industry
Petroleum refining
Chemical manufacturing
Primary metals
Textiles finishing
Tobacco products
Tire and rubber industry
Glass manufacturing
AH industries
==============
Annual growth
rate projection,
percent
0.4
2
0.1
1
-5
1.5
1

===========
Baseline annual
nationwide P
discharges, Mg
1,704
4,781
1,444
55
123
52
9.2
8,168
— ^— -— —
Total P
discharges
under RA HI,
Mg
2,035
5,291
1,566
58
126
55
9.2
9,140
                            7-16

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 Restrictions'in  RCRA Part  268, which  allows  land  disposal  only  if
 the  hazardous waste  is  treated in  accordance with
 Subpart D--Treatment Standards.  A concentration  in  the waste of
 5 mg/L total  chromium may  not be exceeded  to allow land disposal.
 Hazardous  wastes also must be handled and  stored  according to
 specific RCRA procedures.  Baseline Slowdown discharges of.Cr+6
 are  estimated at 400 Mg/yr (440 tons/yr).  Therefore, solid waste
 disposal of a maximum of 400 Mg/yr (440  tons/yr)  of.Cr+6 may be
 expected in the  sludge  from blowdown  treatment processes.
     Zinc-, molybdenum-, and phosphorus-containing wastes  are not
 identified as hazardous wastes and therefore do not  have the same
 solid 'waste disposal requirements  as  chromium-containing wastes.
 Under RA II,  the blowdown  Cr+6 concentrations would  be the same
 as baseline Cr+6 blowdown  concentrations,  resulting  in the same
 Cr+6 solid waste disposal  (400 Mg/yr  [440  tons/yr] maximum).
 Regulatory Alternative  III would eliminate the use of Cr+6 and,
 thus, eliminate  solid waste disposal  of  Cr+6 from IPCT's.
 7.4  ENERGY IMPACT
     Energy impacts  over baseline  (RA I) would result from using
 HEDE's (RA II) and the  chemical feed  and control  equipment
 required for  nonchromate-based water  treatment programs  (RA III).
 For both alternatives,  the energy  impacts  would be relatively
 minor.
     Although HEDE's  are designed  for greater impaction of water
 droplets on eliminator  surfaces than  are low-efficiency drift
 eliminators (LEDE's), the  pressure  drop  through an HEDE is
 generally  less than  the pressure drop through an  LEDE.  Thus, a
 net energy savings results when LEDE's are replaced  with HEDE's.
 The difference in pressure drop between  an LEDE and  an HEDE is
mainly a function of  eliminator design,  type of tower (crossflow
vs. counterflow), and air  velocity. .For crossflow towers
designed with eliminator airflow velocities  in the typical range
of 91.5 to 213 meters per  minute (m/min) (300 to  700 feet  per
minute [ft/min]), the difference in pressure drop between  an HEDE
and an LEDE is negligible.  However,  for counterflow towers,  the
reduction in  pressure loss, and thus,  the  reduction  in energy
                               7-17

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 consumption,"- is more significant.13  Based on information
 provided by vendors, the difference in pressure loss between a
 counterflow tower with an HEDE and a counterflow tower equipped
 with an LEDE can be estimated to be 0.076 grams per square
 centimeter (0.03 inches of water).13'15  Based on the assumption
 that 25 percent of the IPCT's in the industries of concern  are
 counterflow design,  the nationwide energy savings due to this RA
 would be 5,294  megawatt hours per year (MWhr/yr).   Table 7-10
 summarizes the  nationwide energy savings  for each of the seven
 industries.
      As discussed in Chapter 3,  nonchromate-based water treatment
 programs generally require tighter control of chemical feed and
 recirculating water quality parameters.   As discussed in
 Chapter 8,  the  components required for a  basic chemical feed and
 monitoring system include a pH controller,  conductivity
 controller,  and metering chemical feed pumps.   Information
 provided by vendors  indicates that this type of system typically
 requires 0.5 kW to operate,  and at least  50 percent of the  IPCT's'
 in the  industries of concern have at least one of  these control
 components  in.place.16"18  Based on these assumptions,  the
 resulting nationwide increase in energy consumption due to  this
 RA would be  2,587 MWhr/yr.   Table" 7-11 summarizes  the nationwide
 increases in energy  consumption for each  of the seven industries.
 7.5   STATE REGULATIONS
 7.5.1   Air Emissions
      The California  Air Resources Board (CARB)  is  the first  State
 agency  to regulate Cr+6 emissions from cooling towers.   The  CARB
 identified Cr+6  as a toxic  air contaminant  (TAG)  in January  1986.
 California State law requires that once a substance has been
 identified as a  TAG,  a  report must be  prepared by  CARB to
 determine the appropriate degree  of control  needed for the
 substance.19  The  CARB  estimated  that  in  1985  Cr+6  emissions  from
 cooling towers  (all  types,  including industrial) accounted for
 68 percent of all  Cr+6  emissions  in the State  of California.19
The airborne toxic control measure (ATCM)  adopted  by the CARB  in
March 1989 banned  Cr+6-containing compounds  from use in all
                               7-18

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TABLE 7-10.  ESTIMATED ANNUAL REDUCTIONS  IN.ENERGY
     CONSUMPTION. FOR REGULATORY ALTERNATIVE II
                  (HEDE RETROFIT)
Industry category
Petroleum refinishing
Chemical manufacturing
Primary metals
Textile finishing
Tobacco products
Tire and rubber products
Glass products
Nationwide
Annual energy savings, MWhr/yr
2,450
2,380
420
4.5
20.2
18.4
0.5
5,294
                       7-19

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TABLE 7-11.  ESTIMATED ANNUAL INCREASE IN ENERGY
    CONSUMPTION FOR REGULATORY ALTERNATIVE III
                   (NONCHROMATE)
Industry category
Petroleum ref inishing
Chemical manufacturing
Primary metals
Textile finishing
Tobacco products
Tire and rubber products.
Glass products
Nationwide
Increased annual energy
consumption, MWhr/yr
520
1,610
338
41
18
57
2.5
2,587
                      7-20

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cooling towers.  The ATCM requires owners or operators of cooling
towers to:
     1.  Register existing cooling towers with the local air
pollution control district (APCD) or air quality management
district  (AQMD);
     2.  Discontinue using Cr+^;                           •
     3.  Keep the concentration of Cr+6 in the recirculating
water below 0,15 mg/L;
     4.  Monitor the recirculating water for chromium by'an
approved method every 6 months;
     5.  Maintain records of the test results for 2 years; and
     6.  Provide information to the local APCD on all new towers
installed after the ATCM is adopted.
Operators of wooden towers may receive an exemption that will
allow greater than 0.15 mg/L Cr+6 in recirculating water for a
period of 6 months- after the ATCM compliance date.  Violation of
the ATCM may result in a civil penalty not to exceed $10,000 per
day for each day of violation.  The local APCD's must adopt a
control measure at least as stringent as the ATCM adopted by
CARB.  Districts were required to propose measures by July 1990
and to adopt measures by September 1990.20  The ATCM was codified
March 12, 1990.21
     The CARB is currently working with local APCD's to adopt
local control measures for chromium.  Although most of the APCD's
are adopting the ATCM verbatim or with only minor changes, some
APCD's have not adhered to the schedule for ATCM proposal and
adoption.  As of March 1991,  15 out of a total of 41 APCD's have
adopted chromium control measures approved by CARB.19  No other
States are known to be considering proposals to limit Cr+^
emissions from-cooling towers.
7.5.2  Water Discharges
     Representative State water quality criteria for Cr+6, zinc,
and phosphorus are presented in Table 7-8.  The most, recent
Federal water quality criteria for chromium and zinc were
published in the Federal Register in July 1985 and March 1987,
respectively.  Most States have now adopted EPA water quality
                               7-21

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 criteria for-chromium and zinc.22   The  water  quality  criteria  for
 Cr+6  has reduced the allowable concentration  of  Cr+6  for
 discharge to surface waters  in the  United  States.
      Phosphorus  may be addressed in water  quality  criteria or
 narrative standards.   Sixteen States have  numeric  phosphorus
 criteria ranging from 7.4 to 1,000  micrograms per  liter  (/xg/L)
 for various  types of receiving waters.  Lakes and  reservoirs
 generally have the most restrictive phosphorus criteria.  Almost
 all States have  regulations  containing  narrative statements
 prohibiting  discharge of any substances at levels  that are
 injurious to fish and wildlife or that  render water unsuitable •
 for drinking.22   Molybdenum  is typically addressed under a heavy
 metals category  for which standards are set relative  to the
 toxicity of  each substance.
     Most zinc water quality standards  are calculated from an
 equation that considers the  hardness of the receiving water.
 Zinc toxicity changes  with water hardness.  The  majority of
 values presented in Table 7-12  were calculated for a  hardness of
 100 mg/L as  calcium carbonate,  which is a  hardness value often
 used for comparison purposes.                         .
     Permit  values  applied to  the discharges from  a'facility are
 likely to differ from the values in Table  7-12.  Permit values
 are determined from a  number of  site-specific factors including
 waste-load allocations  and consideration of the  designated uses
 of the receiving water.
 7.6  POLLUTION PREVENTION
     The  Pollution  Prevention Act of 1990  (PPA)  (passed by
 Congress  on  October 27,  1990)  establishes  pollution prevention as
 national  policy  to  prevent pollution or reduce it at  the source
 whenever  feasible;  recycle in an environmentally safe manner,
 whenever  feasible,  pollutants  that  cannot  be prevented;  treat in
 an environmentally  safe manner, whenever feasible,  pollutants
 that cannot be prevented  or  recycled; and  dispose of or release
pollutants in an  environmentally safe manner only as a last
 resort.
                               7-22

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     Pollution prevention is not defined in the Act, but it is
intended to include source reduction and to exclude most forms of
recycling.    Pollution prevention policy applies to any
hazardous substance, pollutant, or contaminant.
     Source reduction is defined as any practice that reduces the
amount of any hazardous substance, pollutant, or contaminant
entering any waste stream or otherwise released into the
environment (including fugitive emissions) prior to recycling,
treatment, or disposal and reduces, the hazards to public health
and the environment associated with the release of such
substances, pollutants, or contaminants.23  Regulatory
Alternative II cannot be considered a source reduction technique.
High-efficiency drift eliminators would reduce the amount of
drift and, thereby, reduce the amount of chromium emitted, but
this would not reduce the amount of chromium entering the waste
stream (i.e.,  the concentration of chromium in the drift and
blowdown).  However, RA III is considered a pollution prevention
alternative under the PPA.  Converting to nonchromate-based water
treatment programs would reduce the emissions of chromium to zero
and eliminate pollution at the source through a cost-effective
change in materials used.  In addition to eliminating chromium
emissions, using nonchromates has several other benefits.
Besides eliminating onsite spills, transportation, storage, and
water discharges of a hazardous substance, using nonchromates
also eliminates worker exposure to a hazardous substance during
formulation and use.  The nonchromate alternative eliminates the
use of chromium at the source and thereby constitutes a pollution
prevention measure.-
     Under RA III phosphate emissions and discharges would
increase.  This would likely affect the local growth of aquatic
plants and deplete dissolved oxygen in the receiving water.
However,  a large percentage of the phosphate concentration may be
removed from discharges by standard wastewater treatment methods.
                               7-24

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7.7

 1.
 5,

 6

 7
10
11.
12
13.
14.
REFERENCES FOR CHAPTER 7

Betz Handbook of Industrial Water Conditioning.  Betz
Laboratories, Inc.  Trevose, Pennsylvania.  8th Edition.
1980.  pp. 207-208.

Telecon.  Nicholson, B., MRI, with Soule, C., Dearborn
Division, W. R. Grace & Company.  March 26, 1986.  Effects
of regulatory alternatives on water discharges.

Telecon.  Nicholson, B., MRI, with Dowdle, B., Mogul.
March 30, 1987.  Effects of regulatory alternatives on water
discharges.

Robitaille, D. R.  Molybdate Inhibitors for Problem Cooling
Waters.  Chemical Engineering.  October 4, 1982.  pp. 132 to
142.

Chemical and Engineering News.  69.(25):30.  June 24, 1991.

U.S. Industrial Outlook 1991--Petroleum Refining,  pp. 4-2.

U.S. Industrial Outlook 1991--Plastics and Rubber.
pp. 14-5.

Telecon.  Marron, J., MRI,. with Bell, C. , U.S. Department of
Commerce.  July 22, 1991.  Iron and Steel production growth
projections.
     Predicast Forecasts.
     August 3, 1990.
                      Issue No. 120.  Fourth Quarter.
U.S. Industrial Outlook 1990--Food, Beverages and Tobacco.
pp. 34-33.

Modeling Phosphorus Loading and Lake Response Under
Uncertainty:  A Manual and Compilation of Export
Coefficients.  U. S. Environmental Protection Agency.
Publication No. EPA-440/5-80-011.  June 1980.

Analysis of Phosphorus Sources in the Environment.  U. S.
Environmental Protection Agency.  Publication
No. EPA-560/2-79-002.  March 1979.

Telecon.  Marinshaw, R., MRI, to Lindahl, P., Marley Cooling
Tower Company.  August 12, 1991.  Pressure drop through-
drift eliminators.

Fax transmittal.  Skold, J., Munters Corporation, to
Marinshaw, R., MRI.  August 13, 1991.  Pressure drop through
Munters D-15 drift eliminators.                           ,
                               7-25

-------
 15.   Fax transmittal.   Whittemore,  M.,  Brentwood Industries,
      Inc.,  to Marinshaw,  R.,  MRI.   August 13,  1991.   Pressure
      drop through Brentwood CDX drift  eliminators

 16.   Telecon.  Marinshaw,  R.,  MRI,  to  James,  E.,  Betz Industrial
      August 2,  1991.   Cooling water treatment programs and
      control equipment.

 17.   Telecon.  Marinshaw,  R.,  MRI,  to  Domino,  E.,  Betz
      Industrial.   August  15,  1991.   Chemical  feed and control
      equipment  costs,  operation, and maintenance.

 18.   Telecon.  Marinshaw,  R.,  MRI,  to  Eastin,  P.,  Nalco Chemical
      Company.  August  19,  1991.  Water  treatment  chemical  and
      control equipment costs  and requirements.

 19.   Staff  Report.  State  of  California Air Resources Board.
      Proposed Hexavalent Chromium Control Plan.   January 1988
      40 p.                                              J

 20.   Proposed Hexavalent Chromium Control Measure  for Cooling
      Towers.  State of California Air Resources Board.
   ,   January 20,  1989.  23 p.

 21. •  Telecon.  Marron, J., MRI, with Popejoy, C.,  California  Air
      Resources Board.  February 20, March 7, and March 15, 1991.
      Status  of the California  hexavalent chromium  control
     measure  for  cooling towers.

22.  Memorandum.  Marron, J. ,  MRI,   to Chromium Emissions From'
      Industrial Process Cooling Towers NESHAP Project  File.
     State Water  Quality Criteria.   August 5, 1991.  •

23.  Memorandum.  Laskowski, S., EPA, to Pollution Prevention
     Advisory Committee.  Pollution Prevention Act of  1990.
     November 27, 1990.
                              7-26

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              8.'0  COST ANALYSIS OF CONTROL OPTIONS
8.1  INTRODUCTION                                        • .
     This chapter presents estimates of the nationwide costs that
would be incurred by the petroleum refining, chemical
manufacturing, primary metals, and miscellaneous industries to
reduce hexavalent chromium (Cr+6) emissions from industrial
process cooling towers  (IPCT's).   Regulatory Alternatives II
(high-efficiency drift eliminator [HEDE] retrofits) and III (use
of nonchromates) were evaluated with respect to Regulatory
Alternative I (baseline) to determine the increase in costs for
each of the two control technologies represented by the
regulatory alternatives.  Cost factors for each of the model
towers presented in Chapter 5 were first determined and then
applied to the number and sizes of model towers that best
represent the industries of concern.  The costs are based on
information obtained from vendors, manufacturers, and responses
to information requests.  In some cases, it was also necessary to
rely on engineering judgement and information on general industry
practices and trends to develop cost factors.
8.2  ANNUALIZED COST OF CONTROL TECHNIQUES
8.2.1  High-Efficiency Drift Eliminator Retrofits
     Regulatory Alternative II is based on retrofitting HEDE's on
all IPCT's in which chromium is used to control corrosion.  The
components of the cost estimate for this alternative include
capital costs, the cost- of a compliance test, and the cost of
annual inspections.  Maintenance and labor costs are not included
because it is assumed that the maintenance and labor requirements
for HEDE's are no different than those for standard, low-
efficiency drift eliminators  (LEDE's).  Energy costs also are not
                               8-1

-------
 included in "the cost estimate for this  alternative.   The  pressure
 drop through  a typical HEDE in a crossflow tower is  comparable  to
 the  pressure  drop through an LEDE,  and,  thus,  the difference  in
 energy requirements  between a tower equipped with HEDE's  and  a
 comparable  tower with LEDE's is negligible.1  The difference  in
 pressure drop through a counterflow HEDE and a counterflow LEDE
 is more significant,  but because it is  estimated that a maximum
 of 25  percent of IPCT's in the industries of concern are  of
 counterflow design,  it is assumed that  any difference in'energy
 requirements  for counterflow IPCT's is  also negligible.1'2
      It is  estimated that 5 percent of  existing towers are
 already equipped with HEDE's.3
      8.2.1.1   Capital Costs.   Capital costs include  the purchased
 equipment costs,  taxes and freight,  direct installation costs,
 and  indirect  installation costs.  According to a cooling  tower
 manufacturer,  typical unit material costs (including taxes) for
 HEDE's  are  $5.50>per square foot ($/ft2)  for crossflow towers and
 $3.60/ft2 for counterflow towers.   Unit  freight and  direct
 installation  costs for crossflow towers  are estimated to  be
 $0.70/ft2 and $2.75/ft2,  respectively.   For counterflow towers,
 unit freight  and direct  installation costs  are typically
 $0.50/ft2 and $1.85/ft2,  respectively.   Also,  contingencies for
 HEDE retrofits are estimated  to be  20 percent.2
     In  order to estimate the  entire purchased equipment  costs
 for a drift eliminator retrofit,  it  is necessary to  estimate  the
 area of  drift eliminator required.   For  a crossflow  IPCT, the
 required drift eliminator area is estimated from the  tower
height,  tower length,  and angle  of  the eliminator to  vertical
using the following equation:1
             A =  (H)  (L) (1/cosfl) (2)                             (1)
where:
             A = drift eliminator area;
             H = height of tower;
             L = length of tower; and
          cos0 = cosine of angle of eliminator to vertical,
                 typically 9 degrees.
                               8-2

-------
     The factor of two takes into account the two banks of drift
eliminators in a crossflow tower.  Because the drift eliminator
area required for a crossflow IPCT is comparable to that required
for a counterflow IPCT with equivalent recirculation rate and
splash fill, Equation 1 can be used to estimate the HEDE areas
required for all model towers without the need to account for the
percentage of crossflow and counterflow towers.^
     The values above were used to estimate capital.costs for
retrofitting HEDE's on all model towers.
     8.2.1.2  Compliance Test Costs.  It is assumed that
compliance tests would be required on all IPCT's equipped with
HEDE's to ensure that the tower achieves a drift rate of no more
than 0.01 percent of the recirculating water flow.  Therefore,
the cost of a compliance test is included in the overall, cost
estimate for Regulatory Alternative II.  As discussed in
Appendix C, results from EPA-sponsored emissions tests indicate
that a minimum of 18 test runs are required to distinguish
between the emission rate for a tower equipped with HEDE's and
for a comparable tower equipped with LEDE's.  According to a .
testing firm, the cost of an IPCT emissions test using the
Cooling Tower Institute sampling train with surrogate mineral
analysis can be estimated to be $57,000.4  This cost includes the
cost of 18 test runs, sample analysis using inductively coupled
argon plasma spectroscopy, and preparation of an emissions test
report.  Thus, the cost of a compliance test is assumed to be
$57,000 for all model towers.
     8.2.1.3  Annual Inspection Costs.  Under this regulatory
alternative, all IPCT's equipped with HEDE's would be required to
be inspected annually.  The purpose of the inspection is to
ensure that the HEDE's are in good condition and are properly
sealed.  The cost of the annual inspection was assumed to
increase with tower size, starting at $600 for model towers with
recirculation rates up to 18,900 liters per minute (L/min)
(5,000 gallons per minute [gal/min]) and increasing to $1,200 for
the largest model tower 'size.  These figures are consistent with
                               8-3

-------
standard rates that a major drift eliminator manufacturer charges
for inspecting a cooling tower.5
     8.2.1.4  Annualized HEDE Retrofit Costs.  The annualized
cost to retrofit HEDE's on each of the model IPCT's is summarized
in Table 8-1.  These costs are based on an annual interest rate
of 10 percent and an HEDE lifetime of 15 years.  In addition, to
account for the distribution of IPCT designs (75 percent
crossflow and 25 percent counterflow) in the industries of
concern, a composite unit cost for HEDE's was used in estimating
the cost to retrofit HEDE's on the model towers.  As shown in
Table 8-1, the annualized costs of this regulatory alternative •
range from $8,700 for the smallest model tower to $51,000 for the
largest tower.
8.2.2  Nonchromate Water Treatment Programs
     Regulatory Alternative III is based on banning the use of
chromate-based water treatment programs in IPCT's.  The
components of the nonchromate program costs that were applied to
the model towers include the increased cost of nonchromate
chemicals over the cost of chromate chemicals and the cost to
install and operate automated chemical feed and control
equipment.  Information recently obtained from petroleum
refineries, chemical manufacturing plants that produce high-
process-temperature chemicals, and water treatment chemical
vendors indicates that, with few exceptions, nonchromates perform
comparably to chromates in controlling corrosion in IPCT systems,
provided that the water treatment programs are properly
controlled.6'7  Therefore, in estimating the increased costs for
nonchromate programs over chromate programs, it was assumed  that
corrosion rates, heat exchanger lifetime, cleaning requirements,
and other maintenance requirements are comparable for both types
of water treatment programs.  Thus, it was assumed that there are
no increases in maintenance costs associated with the performance
of water treatment programs following conversion to nonchromates.
Based on information provided by water treatment chemical
vendors, it is not necessary to shut down an IPGT system when
converting from chromates to nonchromates and  there are no costs
                               8-4

-------
associated with the conversion process other than the costs
associated with installing automated chemical feed and control
equipment.8'10  For systems that are severely scaled or fouled,
conversion should be scheduled to coincide with scheduled
shutdowns to allow cleaning of the system.  (In such cases,
cleaning would also be required if the system were to continue to
operate on a chromate-based water treatment program.)  Finally,
because manpower requirements are comparable for both chromates
and nonchromates,  it is assumed that labor costs do not change
following conversion to nonchromates.
     8.2.2.1  Water Treatment Chemical Costs.  Information
obtained from four water treatment chemical vendors indicates
that the costs of chromate-based water treatment programs range
from $30 to $130 per million pounds of blowdown, and the costs of
nonchromate-based water treatment programs range from $60 to
$250 per million pounds of blowdown.11"14  To estimate
representative chemical costs for both types of programs, a
weighted average of the costs submitted by all four vendors was
determined.  The weighing factors taken into consideration
included the average costs of each type of chromate and
nonchromate program, the percentage of sales of each type 'of
program by the vendors, and estimates of each vendor's market
share of petroleum refineries, chemical plants, primary metals
plants, and other industries.  This resulted in an average
chromate program cost of $72 per million pounds of blowdown and
an average nonchromate program cost of $126 per million pounds of
blowdown.
     8.2.2.2  Chemical Feed and Control Equipment Costs.  Based
on information obtained from water treatment vendors, the minimum
equipment requirements to achieve adequate control of
nonchromate-based water treatment programs include a pH
controller, conductivity/blowdown controller, and some  (typically
two) metering chemical feed pumps.11'14  The components of the
cost estimate for a typical installation of these three types of
control equipment include capital costs and annual costs.  These
are discussed below.
                               8-5

-------
     8.2.2.2".!  Capital costs.  Capital costs include the
purchased equipment costs, direct installation costs, indirect
installation costs, freight, and taxes.  Vendors have indicated
that the costs of a basic pH controller, conductivity controller,
and metering pump are $2,000, $2,000 and $600, respectively, and
direct installation costs are typically 25 percent of the capital
costs.12'13'15  It is assumed that indirect installation costs,
taxes, and freight can be estimated as 20 percent, 3 percent, and
5 percent, respectively, of the capital costs.  These figures
were used to estimate the costs to install a complete control
system in a model cooling tower.
     8.2.2.2.2  Annual costs.  Annual costs include maintenance
costs and the cost of energy to operate the equipment.
Maintenance costs include the costs to replace probes and rebuild
pumps.  Based on information provided by vendors, pH probes
typically cost $175 and must be replaced annually, conductivity
probes typically cost $150 and must be replaced every 3 year's,
and pump maintenance costs are typically $75 per year.  The
entire control system typically requires 0.5 kilowatts to
operate.15  The unit cost of electricity for industry was assumed
to be $0.047 per kilowatt-hour.16  These figures were used to
estimate the annual costs of chemical feed and control systems on
the model towers.
     8.2.2.3  Annualized Costs for Nonchromate-Based Programs.
The annualized costs to convert and operate the model IPCT's on.
nonchromate-based water treatment programs are summarized in
Table 8-2.  The chemical cost component represents the^difference
in annual chemical costs between chromate-based and nonchromate-
based programs.  In determining the annualized capital costs for
the chemical feed and control equipment, a 5-year equipment life
and 10 percent interest rate were assumed.15  In addition,
approximately 50 percent of the plants in 'the industries of
concern already have at least one of these three types of control
equipment in place, and many plants have all three types of
equipment.  For the purpose of estimating the equipment costs, it
was assumed that 50 percent of the IPCT's nationwide would
                               8-6

-------
 require all three types of control equipment and 50 percent of
 the IPCT's nationwide would require two of the three types of
 control equipment.17  The annualized costs of this regulatory
 alternative range from $4,300 for the smallest model tower to
 $144,000 for the largest model tower.
 8.2.3  Summary of Costs and Cost Effectiveness of Regulatory
        Alternat ives
      The annualized costs and cost effectiveness, of the
 regulatory alternatives for each of the seven industries -by model
 IPCT size are presented in Tables 8-3 to 8-9.   Table 8-10
 summarizes the nationwide costs and cost effectiveness values for
 the regulatory alternatives.   Regulatory Alternative II, which is
 based on retrofitting HEDE's  on all chromate-using IPCT's,
 achieves a 64 percent emission reduction,  based on the
 assumptions that each HEDE reduces emissions by 67 percent and
 5 percent of all IPCT's already are equipped with HEDE's.   The
 overall annualized cost of this alternative is $11.3 million,  and
 the cost effectiveness is $750,000 per megagram ($/Mg).
 Regulatory Alternative III, which is based on converting all
 chromate-using IPCT's .to nonchromate-based water treatment
 programs,  achieves a 100 percent emission reduction.   The  overall
 annualized cost of this alternative is $14 million,  and the cost
.effectiveness is $610,000/Mg.
                               8-7

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 8.3  REFERENCES  FOR  CHAPTER  8

 1.  Telecon.  Marinshaw, R., MRI, with Lindahl,  P., Marley
     Cooling Tower Company.  August  12, 1991.  Pressure drop
     through high efficiency drift eliminators.

 2.  Telecon.  Marinshaw, R., MRI, with Beyer, A., Marley
     Cooling Tower Company.  August  13 and 16, 1991.  Costs
     associated  with retrofitting high efficiency drift
     eliminators.

 3.  Telecon.  Marron, J., MRI, with DePalma, T., Tower
     Performance, Inc.  August 20, 1991.  Use of  high
     efficiency  drift eliminators by industry.

 4.  Telecon.  Marinshaw, R., MRI, to Watson, P., Entropy
     Environmentalists. ' August 19 ,1991.  Estimated cost of
     cooling tower compliance test.

 5.  Telecon. Marron, J., MRI, to Beyer, A.,  Marley Cooling
     Tower Company.  August  20, 1991.  Cooling tower
     inspection  costs.

 6.  Memorandum.  Marinshaw, R., MRI, to Myers, R., EPA:ISB.
    •May 15, 1991.   Summary  of Information Gathered From
     California  Petroleum Refineries.

 7.  Memorandum.  Marinshaw, R. and  Marron, J., MRI, to
     Myers, R.,  EPArlSB.  June 7, 1991.  Preliminary
     Analysis of Section 114 Questionnaires on Nonchromate-
     Based Cooling Water Treatment Programs.

 8.  Telecon.  Marinshaw, R., MRI to Eastin, P.,  Nalco Chemical
     Chemical Company.  October 22,  1991.  Converting cooling
     towers from chromates to nonchromates.

 9.  Memorandum.  Marron, J., MRI, to Myers, R.,  EPArlSB.
     April 3, 1991.  Trip report:  Betz Industrial, Trevose,
     Pennsylvania, on February 26, 1991.

10.  Telecon.  Marron, J., MRI, to Clavin, S., Betz Industrial.
     October 15, 1991.  Cleaning and pretreatment cost
     requirements associated with conversion to nonchromates.

11.  Letter and attachments.  Roti,  J., Drew Industrial
     Division,  Ashland Chemical,  to  Crowder, J.,  EPArlSB.
     July 16, 1991.  Response to questionnaire on cooling
     water treatment programs and control equipment.

12.  Letter and attachments.  James,  E., Betz Industrial, to
     Crowder, J., EPA:ISB.  July 17,  1991.  Response to
     questionnaire on cooling water  treatment programs and
     control equipment.
                               8-18

-------
13.  Questionnaire.  Eastin, P., Nalco Chemical Company, 'to
     Myers, R.,  EPA:ISB.  August 5, 1991.  Response to
     questionnaire on cooling water treatment programs and
     control equipment.

14.  Questionnaire.  Lutey, R.,  Buckman Laboratories, to
     Myers, R.,  EPArlSB.  August 6, 1991.  Response to
     questionnaire on cooling water treatment programs and
     control equipment.

15.  Telecon.  Marinshaw, R., MRI, with Domino, E., Betz
     Industrial.  August 15, 1991.  Cost and lifetime of
     chemical feed and control equipment.

1.6.  Monthly Energy Review, Energy Information
     Administration.  Retail prices of electricity.
     March 1991.  p.109.

17.  Telecon.  Marinshaw, R., MRI, with James, E., Betz
     Industrial.  August 2, 1991.  Cooling water treatment
     programs and control equipment.
                               8-19

-------

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                   9.0  ECONOMIC IMPACTS

     The purpose of this chapter is to determine the
economic impacts likely to occur as a result of the
regulation of hexavalent chromium emissions from IPCT's
(Industrial Process Cooling Towers).  By limiting these
emissions, the proposed regulatory alternatives hold the
potential for cost increases for all firms that currently
use chromate corrosion inhibitors.  Furthermore, to the
extent that the regulation could affect the use of chromates
in IPCT's, the suppliers of such products could face the
reduction or elimination of the market for their products.
     In Section 9.1, industry profiles are developed for the
suppliers of chromate corrosion inhibitors and for the major
end users of these corrosion inhibitors for cooling tower
operation.  Section 9.1.1 provides  information on the market
and suppliers of corrosion inhibitor products.  In Sections
9.1.2 through 9.1.4, profiles are  presented for those
industries which are major users of chromates, namely,
chemical manufacturing, petroleum  refining, and the primary
metals  industry.   Profiles of the  textile  finishing, tobacco
products, tire  and rubber products, and glass products
industries are  presented  in Sections  9.1.5 through  9.1.8.
These industries are relatively minor users of  chromate
corrosion inhibitors.   For all  the user industries, data are
presented regarding the value of  shipments,  industry
structure, domestic production, domestic  consumption,
foreign trade,  and employment.  These data are reported in
order to provide the statistical  basis for the economic
 impact  analysis.
      Section 9.2  examines the economic impacts of the
different regulatory alternatives.  The impacts are
 expressed in terms of  price increases and reductions in
 quantity demanded for  each of the user industries.
                           9-1

-------
     The economic impacts in Section 9.2 are calculated
using aggregate industry data rather than product data
because IPCT's are not specific to the manufacture of
individual products but instead are used in the production
of many products at a manufacturing site.  In this sense,
cooling towers represent a utility to the plant.  For
example, in the petroleum refining industry, IPCT's are not
used solely for the production of distillate fuel but also
for the manufacture of many other petroleum products.
     Regulating hexavalent chromium emissions from IPCT's
may have a significant impact on a substantial number of
small businesses.  If this is the case, then, according to
the Regulatory Flexibility Act, the proposing agency must
prepare a Regulatory Flexibility Analysis  (RFA).  In order
to determine whether a RFA is necessary, the magnitude of
the regulation's  impact  on small businesses is examined in
Section 9.3.
9.1  INDUSTRY PROFILES
9.1.1  The Supply and Demand of Chromate Corrosion
       Jnhibitors
     The  corrosion inhibitors market  covers the  use  of a
large  number  of  chemicals that  function as corrosion
inhibitors  in a  variety of  industrial applications.   The
market is often  described in terms  of corrosion inhibitors
that function to reduce or  eliminate  corrosion on either  the
 "process  side"  or the "water side"  of industrial operations.
The process side refers to  chemicals  added to process
 streams at  petroleum refineries,  oil  fields,  and pipelines
 in order to limit the corrosive effects of the materials
 being processed.  Corrosion inhibitors used on the water
 side include those intended to reduce corrosion in either
 boiler water or in cooling tower water.  Those used in
 cooling water applications are the focus of concern in this
 discussion.1
                           9-2

-------
     Chromates have historically been the easiest and most
effective to use of all corrosion inhibitors because they
required less monitoring and .control than nonchromate
corrosion inhibitors.  This contributed to the lower cost of
chromate programs versus substitute programs.  However,
regulations restricting the allowable effluent emissions of
hexavalent chromium have caused many IPCT operators to use
substitutes in order to avoid increased productions costs.
The improvement in the performance of nonchromate
formulations has also influenced the decision of many firms
to substitute for chromate formulations.  Although early
nonchromate programs had their difficulties, those currently
sold are as easy to control and as effective or more
effective than chromates.2'3
     Corrosion inhibitors  are sold by firms who supply these
chemical formulations for  use in water treatment or process
applications.  The market  was worth over  $700 million in
1988.  With respect to water treatment applications, the
primary  suppliers  include  Betz Laboratories, Calgon,
Dearborn, Drew Chemicals,  Mogul, and Nalco  Chemical.
     The corrosion inhibitor formulation  is only part of  the
product  sold  by  these  companies.  The  identification .of  the
optimal  formulation for  a  specific  facility requires the
specialized  expertise  of the technical  staffs  of the
suppliers.   In most cases  the  formulations  are changed  in
response to  changes in plant process parameters or changes
 in intake water  quality.  In essence,  the product  being sold
 is a corrosion inhibitor service rather than a specific
 group of chemicals.
      It is  important to note that the industries using .
 corrosion inhibitors place greater emphasis on the technical
 services.1  While  these  industries prefer to purchase the
 formulations at the least possible cost, they cannot afford
 the high costs associated with corrosion.  The costs include
                           9-3

-------
those resulting from inefficient heat exchange and the need
to replace corroded heat exchangers and other process
equipment.  Consequently, industries using chromate
corrosion inhibitors may be relatively price-insensitive if
chromates have been identified as the most effective
corrosion inhibitor.  However, this is less likely now than
in the past because nonchromates are now as effective as
chromates.  Also, the costs of using chromates will increase
due to regulation, thus making them more comparable to
nonchromate costs.
9.1.2  Chemical Manufacturing
     The  chemical industry  (SIC 28) is extremely diverse in
terms of  the range of products manufactured.  To simplify
the discussion of the industry, it  is helpful to consider
the industry as being composed of five major subgroups  --
basic chemicals, organic chemicals, synthetic materials,
agricultural chemicals,  and finished chemical products.  It
should be noted that there  is considerable overlap among
these five subgroups.
     Basic chemicals are used as building blocks,  processing
aids, or catalysts  in  chemical  and  non-chemical.
manufacturing.   This group  includes commercially  important
 inorganics (such as sulfuric acid  and  phosphates), inorganic
pigments, chlor-alkalies, and industrial gases.   Basic
 chemicals are usually  recovered from mineral ores or as
 coproducts in manufacturing processes such as metals
 production or petroleum refining.   For the most part, basic
 chemicals are generic products in that they are usually sold
 as commodities and there is little product differentiation.
      Industrial organic chemicals are substances containing
 elemental carbon; they are usually derived from petroleum
 and natural gas.  These chemicals can be categorized into
 three groups:  basic organics, intermediates, and finished
 goods.  Basic organic chemicals are derived directly from
 raw materials such as aliphatics and aromatics.
                            9-4

-------
Intermediate organics are more refined basic organics which
are used to produce finished organic products.   The
distinction between basic, intermediate,  and finished
organics is blurred; in many instances basic and
intermediate organics are sold as end products.   Organic
chemicals are used in the manufacture of  many chemical
products including plastics, synthetic rubber,
Pharmaceuticals, and adhesives.
     Synthetic materials include plastics,  man-made fibers,
and synthetic rubber.  Plastics are polymers which are
combined with curatives, fillers, and other agents and then
shaped or molded under pressure to a solid state.  Key
plastic materials include acrylonitrile-butadiene-styrene
(ABS) resins, polyethylene, polyvinyl chloride,  and
phenolic.  Man-made fibers include materials developed
from cellulose  (known as cellulosics) and fibers derived
from hydrocarbons (non-cellulosics).  Rayon and acetate are
major cellulosics; nylon, polyester, and polypropylene are
major non-cellulosics.  Synthetic rubbers,  often referred to
as elastomers because of their elasticity,  are polymeric
materials which resemble natural rubber.   Most often used  in
tire production, major synthetic rubbers include
styrene-butadiene rubber  (SBR), polybutadiene, and nitrile
rubber.
     Agricultural chemicals are chemicals used by the farm
industry, most  notably fertilizers and pesticides.
Fertilizers  include nitrogen, phosphate, and potash
formulations; they are used to provide nutrients
to crops.  Pesticides and herbicides are used to destroy
insects, weeds, and fungus; usually they are proprietary
formulations.
     Chemical products are  upgraded basic and intermediate
chemicals manufactured for  specific end uses.  They  are not
sold as  commodities, but  are  sold with brand names and
compete  on performance as well as price.  Coatings and
                           9-5

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allied products, soap and toiletries, and drugs are major
chemical product groups.
     Chemical manufacturing processes often operate at
extremely high temperatures/ particularly in the production
of petrochemicals.  Many sectors of the industry use large
amounts of water to cool their production process and often
employ cooling towers.  Fourteen four-digit chemical
manufacturing industries which are part of SIC 28 have been
identified as chromate users.  These industries are SICs
2812, 2813, 2816, 2819  (industrial inorganic chemicals),
2861  (gum and wood chemicals, an industrial organic
industry), 2873,  2874,  2-875, 2879  (agricultural chemicals),
and 2891, 2892, 2893, 2895, 2899 (miscellaneous chemical
products).  Survey results  indicate  that  of those processes
using cooling, towers, 10 percent use chromate  corrosion
inhibitors.1  The producers most likely to use IPCT's are
large facilities  producing  several products at high
temperatures.
      While  in certain instances the  data  presented are
specific  to the 14  industries  under  consideration, the
majority  of data  are aggregate information concerning the
entire  chemical industry.
      9.1.2.1   Tndustrv  Shipments.  The aggregate  historical
values  of shipments for the 14 industries are shown in  Table
 9-1.   The data  represent the value of all products and
 services  sold by establishments in the chemical
 manufacturing industries using chromate corrosion
 inhibitors.
      The peak occurred in 1981 when shipments were valued at
 $68,300 million.  The value of shipments subsequently fell
 •Estimates of the percentage of plants using chromate
  corrosion inhibitors are based on an engineering survey
  of the major cooling water treatment chemical vendors.
                           9-6

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        TABLE 9-1.  VALUE OF SHIPMENTS FOR CHEMICAL
                     MANUFACTURING INDUSTRIES, 1980-1989'°
- -• Value of Shipments
(10* 1991 Dollars)"
1989
1988
1987
1986
1985
1984
1983
1982
1981
1980
65,152
63,446
59,363
56,898
61,420
64,411 .
58,865
61,071
68,300
67,429
•The  industries  in question are SICs  2812,  2813,  2816,  2819,
 2861, 2873, 2874, 2875, 2879, 2891, 2892, 2893, 2895, and
 2899.
'The  data are normalized using the implicit price deflator
 for GNP.   -
                           9-7

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10.6 percent in 1982, due in large part to the recession.
Through 1985 the value of shipments fluctuated due to a
number of reasons.  These difficulties included a strong
U.S. dollar (which hurt the industry's balance of trade),
high energy and raw material costs, overcapacity from plant
expansions at the end of the previous decade,  and the
economic downturn of 1985.  Also, from 1980 to 1985 the
industry was restructuring.  By trimming excess capacity and
employment, manufacturers steadily increased the industry
value of shipments from 1986 to 1989 when shipments were
valued at $65,152 million.  Also contributing to this growth
were lower oil prices and a decline in the value of the
dollar.
     9.1.2.2  Industry Structure.  According to the 1987
Census of Manufactures, in that year there were 5,343
establishments in the 14 industries.  Of these, 1,824  (34%)
employed 20 or more personnel.  The establishments in the
industry were controlled by 3,602 companies.
     The chemical industry's capacity utilization rate had
been over 80 percent since 1987.6  However,  capacity growth
combined with decreased demand from the automotive and
construction sectors helped push down the utilization rate
from 89 percent in 1989 to 78 percent in 1990.7
     The chemical industry is highly integrated as well as
diversified.  Many of the major chemical producers are
integrated backward into chemical feedstocks such as
petroleum; many are also integrated forward into finished
chemical products.  Almost all of the major chemical
producers are diversified into other markets to some degree.
Of the top 100 chemical producers  (ranked by chemical
sales), only 40 producers had 100 percent of their revenues
in 1990 generated from chemical product sales.8
     9.1.2.3  Domestic Production.  There is no meaningful
measure of aggregate unit output for the chemical industry
                          9-8

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because of the diversity of products manufactured by the
industry.  Table 9-2 shows domestic production for several
important chemical products from 1986 to 1989.  This table
gives an indication of the level of activity in the
industry.
     The majority of the chemicals listed enjoyed production
growth from 1986 to 1988, as did the entire chemical
industry.  Growth fell in 1989 for many chemicals as the
economy  slowed in the latter part of the year.
     Annually, the Federal Reserve Board compiles a
production index for the chemical industry.  The index
eliminates differences in measuring units  (pounds, gallons,
cubic feet, etc.) and indicates the sum total of production
in the industry.  It allows for comparison of year to year
production and identification of trends in the  industry.
Chemical production rose 5.4 percent  in 1987  and  1988  (Table
9-3).  Production rose in  1990  in all sectors except
industrial organic  chemicals and agricultural chemicals.
      9.1.2.4  pomestic consumption.  Chemicals are used  in a
wide range of industries,  most  notably the automobile,
construction, agricultural, and pharmaceutical  industries. .
Many of  the  industries which are heavy consumers  of
chemicals are influenced by the general health  of the
economy.  Therefore,  the chemical  industry tends  to follow
the general  business  cycle of  the  economy.  The demand for
 chemicals declined beginning  in the fourth quarter  of 1989
 in response to the slowdown in the economy.   As the economy
 suffered, so did the  automotive and construction industries,
 two major consumers of chemicals.
      Since many chemical products are used to produce other
 chemical products, there are interdependences among
 different sectors of the industry.  For. example, demand  for
 basic chemicals such as nitrogen and phosphate is influenced
                           9-9

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TABLE 9-2.  U.S. PRODUCTION OF KEY CHEMICALS, 1986-1989*
                           1986
        1987
        1988
1989
 Ragic Chemicals (106 kg)
 Nitric Acid
 Chlorine
 Sulfuric Acid
 Industrial Organic
 Chemicals (10* kg)
 Ethylene
 Propylene
 1,3-Butadiene
 Agricultural Chemicals
 (106  kg)
 Nitrogen Solutions
 Phosphate Rock
 Potassium Chloride
 Chemical Products
 (106  gallons)
 Coatings and Allied
   Products
 6,109   6,554   7,249
 9,467  10,050  10,212
32,652  35,612  38,628
14,905
 7,494
 1,155
15,854  16,875
 8,627   9,627
 1,329   1,437
 5,393   5,432   6,349
32,865  35,680  38,301
 1,556   1,642   2,035
   987
                  7,574
                 10,354
                 39,282
 15,870
  9,331
  1,416
                  5,120
                 43,251
                  2,101
 1,013   1,056    1,069*
•Preliminary
                           9-10

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by demand for agricultural chemicals which are manufactured
with these chemicals.
     The sensitivity of chemical sales to price changes,  or
the elasticity of demand, is generally regarded to be low.
While to some extent individual chemicals may serve as
substitutes for others, there are few substitutes for
generic chemical products.  Also, chemical products are
generally regarded as necessities and very often represent a
very small portion of the price of final products that they
are used to produce.  For these reasons, relatively small
changes in chemical prices are not usually associated with
significant changes in quantities demanded.
     Published estimates of the elasticity of demand for
chemicals in general are uncommon.  Those estimates that
have been located indicate that elasticities for specific
chemicals vary widely, but are most often between -0.5 and
zero.  These estimates indicate that the demand for
chemicals is generally relatively inelastic, as a one
percent increase in price would cause a decrease in quantity
demanded of less than one percent.
     9.1.2.5  Foreign Trade.  From  1980 to 1985, the trade
balance for the U.S. chemical industry declined.  The
strength of the U.S. dollar hurt domestic exports.  However,
strong demand overseas in the latter part of the decade, due
to growing foreign  economies in  combination with a weaker
dollar, reversed this trend.  The value of chemical exports
in 1989 was $39,231 million  (1991 dollars), while  imports
were valued at  $22,314 million.6  The trade balance of
$16,917 in 1989 was almost double that  of  1985.'
     9.1.2.6   Employment.  In  1989,  there were 228,800
employees  in the  14 industries  under consideration.5  This
figure  represents  a 2.1  percent increase  from 1988.5  Of the
1989 employment total,  133,000  personnel were production
workers.
                          9-12

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     9.1.2.7  outlook.  Industry growth will closely follow
the growth of the domestic economy.7  As previously stated,
the demand for chemicals is dependent on some of the major
economic sectors such as automotive and construction
industries.
9.1.3  Petroleum Refining
     The Standard Industrial Classification Code for
petroleum refining is 2911; this industry includes all firms
involved in the refining of crude oil into marketable
products.  Major petroleum products include motor gasoline,
distillate fuel oil, residual oil, jet fuel, and liquified
petroleum gases.
     The refining of crude oil involves extremely high
process temperatures.  For this reason, cooling towers used
in the refining of petroleum products often use chromate
corrosion  inhibitors.  Survey results indicate that  20
percent of the cooling towers in petroleum refining  use
chromates.1
     9.1.3.1  Tndustrv shipments.  The petroleum refining
industry's value  of  shipments is shown  in Table 9-4.  In
1987, certain product classes of SIC  2911 were reassigned to
other 4-digit industries;  this  reassignment  had the  effect
of redefining SIC 2911.*  Thus,  value of shipments data are
only reported from 1987  onwards.   Previous  data are  not
comparable to what is reported  in  the table.
     In 1988, the value  of shipments declined 2.6  percent.
There was a subsequent  6 percent increase  in 1989  as crude
 oil  prices rose.
      9.1.3.2  Industry  Structure.   As of June,  1991, there
 were approximately 190  domestic refineries.'  The number  of

 •Estimates of the percentage of plants using  chromate
  corrosion inhibitors are based on an engineering survey
  of the major cooling water treatment chemical vendors.
                           9-13

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      TABLE 9-4.  VALUE OF SHIPMENTS FOR THE PETROLEUM
                  REFINING INDUSTRY, 19 87-198 94'5
                                    Value of Shipments
                                     (106 1991 Dollars)'
             1989

             1988

             1987
141,067

133,366


136,983
The data are normalized using the implicit price deflator
 for GNP.
                           9-14

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refineries has declined 41.4 percent since 1981 when there
were 324 U.S. petroleum refineries.10  The majority of the
closures occurred in the earlier part of the decade among
the smallest refineries.  The trend toward larger refineries
was encouraged by the high crude oil prices prevailing
before 1985  (which favored more integrated facilities) and
decreases in petroleum consumption.
     In the last 15 years, no new refineries have been built
in the United States.  Future construction is unlikely due
to the nature of the permitting process, current economic
conditions, and environmental constraints.  New capacity is
added via construction of new processing units at existing
refineries, modifications to existing units, and through
taking parts from or reactivating mothballed refineries.
     The indu.stry utilization rate for operable capacity
(operating capacity plus idle capacity) rose from 86.3
percent in 1989 to 87.1 percent in 1990.!0  Also rising was
the utilization rate for operating capacity, from 90.2
percent in 1989 to 90.9 percent in 1990.10  Most refineries
are designed to be efficient at rates between 85 to 95
percent of capacity.
     Many petroleum refining companies are integrated
backward to crude oil production.  Major petroleum refiners
such as Exxon, Sunoco and Amoco are all active in the
exploration and drilling of crude oil.  From 1981 to  1989,
the major integrated oil companies accounted for 65 to 75
percent of total U.S. refining capacity."  The major
refiners are also involved in the marketing of their
products to the consumer as well as producing petrochemical
products.  The volatile nature of the oil industry has
caused this diversification into other markets.  As a
result, there has been more intense competition in marketing
among oil producers, particularly in the gasoline market.
Discounts for paying with cash and the emergence of
                          9-15

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convenience stores are examples of new marketing approaches
used by gasoline marketers.
     9.1.3.3  Domestic Production.  Production of several
major petroleum products is shown in Table 9-5.  In 1990,
finished motor gasoline was the number one petroleum
product/ accounting for 46 percent of domestic refineries1
net production of finished petroleum products.10  After
increasing steadily from 1985 to 1989, production fell
slightly (less than 1%) in 1990.  Production of residual
fuel oil and liquified petroleum gases also fell in 1990.
Distillate fuel oil; jet fuel, and other petroleum products
experienced increased production in 1990.
     9.1.3.4  Domestic Consumption.  Table 9-6 details
trends in the apparent consumption (production plus imports
minus exports) of petroleum products from 1981 to 1990.  The
consumption of finished motor gasoline declined 1.3 percent
in 1990 to 7.2 million barrels per day due to an increase in
the average price of motor gasoline and a gain in fuel
efficiency.  Distillate fuel oil experienced a 4.3 percent
decrease in consumption; this was the first decline since
1982.  The decline was partly attributable to milder weather
which lowered the demand for heating oil.  Also contributing
to the decline in overall consumption was a slowdown in  the
growth of industrial production, resulting in  lower demand
for diesel fuel.  Milder weather also affected electric
utility demand for residual fuel oil.  Consumption of
residual fuel oil fell 10.3 percent, resulting in 1.2
million barrels consumed per day in 1990.  Jet fuel
continued its decade-long rise  in consumption.  Demand rose
2.2 percent to push daily consumption to  1.5 million barrels
in 1990.  The impetus behind jet fuel consumption  is an
increase in business and recreational air travel.  Liquified
                          9-16

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petroleum gases experienced the second largest drop in
demand, 6.7 percent in 1990.  Consumption of other petroleum
products rose 5 percent in 19.90.
     Four factors influence the demand for petroleum
products:  economic growth, prices, weather conditions, and
conservation efforts.10  Economic expansion increases
consumption of petroleum products.  Petroleum prices are
inversely related to consumption levels; the lower the
price, the greater the consumption.  Weather directly
influences the demand for heating fuels and residual fuel
oils.
     The demand for refined petroleum products, in the
short-run, is widely held to be relatively price  inelastic.
Petroleum products are regarded as necessities for which
there  are no readily available substitutes.  In the long-
run, the demand becomes less inelastic as consumers have
more time to switch to alternate  fuel sources.
     9.1.3.5  Foreign Trade.  According to the 1991 U.S.
Industrial Outlook, in 1989 exports  for SIC 2911  were  valued
at  $4,800 million  (1991 dollars)  while imports were valued
at  $12,726 million.  This  difference resulted in  a negative
balance  of trade of $7,926 million.
      9.1.3.6  Employment.   In  1989,  the petroleum refining
 industry employed  72,400 personnel.  Of this total,  47,900
personnel were  production  workers.5  Texas, California,
 Louisiana, and  Pennsylvania accounted  for 63 percent of the
 industry's employment  in  1987.4
      9.1.3.7  outlook.  For the long-run,  domestic refinery
 output is not expected to  expand significantly  over its
 level at the  end of the 1980s,  given present and planned
 capacity."  It  is  unlikely that demand will increase
 significantly due  to expectations for higher product prices.
      The biggest issue facing the industry is the effect of
 environmental restrictions on the production of
                           9-19

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transportation fuels.  These fuels have been included in the
Clean Air Act because of the pollution they cause in
congested, urban areas.  Changes in the formulations of
these fuels will necessitate major changes in refinery
processing.  These changes may affect industry profits.  For
example, gasoline reformulation will probably necessitate a
capital investment of $10 to $30 billion during the next
decade.
9.1.4  Primary Metals
     Three four-digit primary metals industries use chromate
corrosion inhibitors in their IPCT's.  These industries are
SIC 3312, Blast Furnaces and Steel Mills, SIC 3331, Primary
Copper, and SIC 3339 Primary Nonferrous Metals Not Elsewhere
Classified.  Survey results indicate that 10 percent of the
IPCT's  in these industries use chromate corrosion
inhibitors.1
     9.1.4.1  industry  shipments.  Table 9-7 details value
of shipments data  from  1980 to 1989.   For all three
industries the values  of their shipments were the highest in
either  1980 or 1981.   Each  industry experienced  declines
during  the economic  downturns of  1982  and  1985.  SIC  3312
had a  3.7 percent  decline  in  its  value of  shipments  in 1989,
when the  value was $51,455  million.   In the same year, SIC
3331 had  a 3.9 percent increase to a  value  of  $4,459
million.  Also growing in  1989 was the value of  shipments
for SIC 3339, which was $5,001 million (a  3.9%  increase over
 1988).
      9.1.4.2   Jndustrv structure.  SIC 3312 is made up of
 establishments  that manufacture hot metal,  pig iron,  and
 silvery pig iron from iron ore and iron and steel scrap.
 •Estimates of  the  percentage  of plants using  chromate
  corrosion inhibitors are based on an engineering survey
  of the major cooling water treatment chemical vendors.
                           9-20

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TABLE 9-7.
VALUE OF SHIPMENTS FOR THE PRIMARY METALS
 INDUSTRIES,  1980-19894'5
           Value of Shipments  (106 1991 Dollars)'

Blast

Furnaces
and Steel Primary

Mi 11s
Coooer
SIC 3312 SIC 3331
1989
1988
1987
1986
1985
1984
1983
1982
1981
1980
— • ' ••"— ~gg— —=•=•;
•The data
for GNP.
51,455
53,411
44,801
41,776
46,724
50,993
47',772
50,101
83,174
79,847
-Jgggg^gg '••?
are normalized

4,459
4,293
2,963
2,470
2,747
3,481
4,544
4,187
7,766
8,754
using the

Primary
Nonferrous
Metals,
n.e.c.
SIC 3339
5,001
4,811
3,831
3,074
3,755
4,020
4,542
4,362
4,743
	 6,210
implicit price



Total
60,915
62,515
51,595
47,320
53,226
58,494
56,858
58,650
95,683
94,811
-~ =
deflator

                        9-21

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The establishments are also engaged in converting pig iron,
scrap iron, and scrap steel into steel, as well as hot-
rolling iron and steel into basic shapes such as plates,
sheets, strips, rods, bars, and tubing.4   Data  for  1987
indicate that SIC 3312 was comprised of 342 establishments
operated by 270 companies.4  Sixty-five percent (222) of all
establishments employed 20 or more personnel.
     The domestic steel industry restructured during 1980s
in response to a long, cyclical slide in demand which ended
in 1986.  This downturn was caused by increased foreign
competition from substitute materials such as plastics,
aluminum, glass, and ceramics.  In order to restructure,  the
industry reduced capacity by 25 percent, halved its labor
force, and modernized its remaining facilities.  Also, the
major integrated producers retreated from producing
commodity steel products due to increased competition from
minimills  (smaller, less integrated producers who have
significantly lower capital costs).  Instead, they are now
concentrating on higher-margin products such as coated and
galvanized steel.  The industry is becoming more
internationalized as domestic producers enter  joint ventures
and projects with foreign producers.
     SIC 3331 is part of the larger SIC 333, Primary
Nonferrous Metals.  Firms  in SIC  3331  are primarily engaged
in the smelting of copper  from the ore and in  the  refining
of copper by electrolytic  or other processes.4  According to
the 1987 Census of Manufactures,  there were  13
establishments  in this industry,  12 of which employed  20  or
more personnel.  The  13 establishments were  owned  by eight
companies.
     The Census of Manufactures reported  that  there were  108
establishments  in SIC 3339  in 1987; these were owned by 96
companies.  Forty-nine establishments  employed 20  or more
personnel.
                          9-22

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     9.1.4.3  Domestic Production.  Production data specific
to the three industries under consideration are not
available.  Therefore, Table 9-8 details the information
concerning the production of all primary metals by domestic
mines.  The value of primary metals production from mines
rose less than one percent from 1989 to 1990 to a value of
$12,953 million.  Domestic steel consumption was weak in
1990, but this was almost offset by increased world
consumption.  At the same time the majority of nonferrous
metals increased in production.
     Information concerning capacity utilization rates for
the three industries is not available for 1990.  The most
recent data indicates that in 1988 the capacity utilization
rate was 82 percent for SIC 3312, 94 percent for SIC 3331,
and 92 percent for SIC 3339.13
     9.1.4.4  Domestic Consumption.  The value of apparent
consumption of both ferrous and nonferrous metals from  1986
to 1990 is  listed in Table 9-9.   These data are reported  in
lieu of specific information for  SICs 3312, 3331, and 3339.
The consumption of ferrous metals was $50,207 million in
1990, a 1.9 percent increase from 1989.  Strong foreign
demand for  steel offset a decline in domestic demand.
Nonferrous  metals consumption decreased  to  $25,673  million
due to a  slight to moderate decrease in  demand.
     Approximately one-third of  steel consumption  is
accounted for by consumer products.14  Steel consumption is
also  dependent  on the demand from the automobile  and  heavy
machinery industries.   Nonferrous metals such as  copper and
aluminum  are  used  in  electrical  equipment  and
telecommunications  equipment.   Copper  is also consumed for
use  in building construction,  industrial machinery and
equipment,  transportation equipment, and consumer products.
                           9-23

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     TABLE 9-8.   U.S. MINE PRODUCTION OF PRIMARY METALS,
                  (FERROUS AND NONFERROUS)  1986-199012
                                   Value  of  Production
                                     (106 1991 Dollars)*
             1990
             1989
             1988
             1987
             1986
12,953 (est.)
   12,863
   11,494
    8,619
    6,967	
•The  data are normalized using the implicit price deflator
 for GNP.
est. - Estimate.
                          9-24

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          TABLE 9-9.  U.S. APPARENT CONSUMPTION OF
                      PRIMARY METALS, 1986-199012
Value of Apparent Consumption
(10* 1991 Dollars)*

1990
1989
1988
1987
1986
Ferrous
50,207 (est.)
49,247
50,617
46,929
46,172
Nonferrous
25,673 (est.)
26,344
26,263
23,523
22,967
The  data  are  normalized using  the  implicit  price deflator
 for GNP.

est. - Estimate.
                          9-25

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     9.1.4.5  Foreign Trade.  Exports of ferrous metals in
1990 were valued at approximately $4,244 million (1991
dollars), a 19.6 percent incr.ease in current dollars over
1989.  Imports totalled $15,527 million in value.  Seven
thousand five hundred fifty-seven million dollars of
nonferrous metals were exported in 1990, while $9,006
million were imported.12
     9.1.4.6  Employment.  In 1989, total employment in-SIC
3312 was 190,600 with 148,800 (78%) personnel employed in
production.  Seventy-nine percent  (3,000) of the 3,800
personnel employed in the SIC 3331 were production workers;
7,700 production workers in SIC 3339 accounted for 73
percent of total industry employment of 10,500.5
     9.1.4.7  outlook.  The long-term outlook for steel is
that demand will be stable over the next five years, barring
an economic downturn.14  Overcapacity, which plagued the
industry in the mid-1980s, will not be a problem in the
1990s due to the industry's restructuring.  However, steel
producers will have to replace some aging facilities, as,
well as having to install technology to control hazardous
emissions regulated by the Clean Air Act.  In order to  do
this, the producers will have to make large capital outlays;
attracting the necessary funds will be difficult because
investors are not drawn to an industry whose profit margins
are  not high.  The major integrated producers may
deintegrate to deal with this financial pressure.15
     No  long-term forecasts are available for the nonferrous
metals industry.  Increases in. production were  expected for
1991.  Demand for the majority of  nonferrous metals was
expected to decline, resulting in  price decreases.14
9.1.5  Tobacco Products  Industry
     The tobacco products  industry is composed  of four  four-
digit  industries:  cigarettes  (SIC 2111), cigars (SIC 2121),
chewing  and smoking tobacco (SIC  2131),  and tobacco  stemming
                          9-26

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and redrying (SIC 2141).   Only the first three will be
examined in this profile because SIC 2141 does not employ
cooling towers in the manufacturing process.
     Survey results indicate that cooling towers are used in
the production of tobacco products, and that no more than
2.5 percent of these towers use chromate corrosion
inhibitors.1
     9.1.5.1  Industry Shipments.  The value of shipments
data from 1980 to 1989 for each of the three tobacco
industries are listed in Table 9-10.  The total value of
shipments rose 60.4 percent from 1980 to 1989, with the
decade-high of $25,098 million occurring in 1989.  Cigarette
shipments (SIC 2111) accounted for 93.5 percent of total
1989 tobacco product shipments.  Like the total value of
shipments, the value of cigarette shipments grew steadily
throughout the ten-year period, growing 63.3 percent from
1980.  The ten-year high occurred in 1989 as shipments grew
4.1 percent to $23,468 million.  From 1980 to 1989, chewing
and smoking tobacco shipments grew 63 percent in value.  The
value of shipments grew 5.9 percent in 1989 to achieve a
decade-high value of $1,409 million.  Only cigar shipments
declined in value from 1980 to  1985, 45.6 percent.
     Driving the growth in the  value of shipments  for SICs
2111 and 2131 were retail price hikes by tobacco product
producers and strong exports to Europe and the Far East.16
SIC 2121 suffered from import competition.16
     9.1.5.2  Industry Structure.   In 1987, there  were  61
total establishments for these  three industries,  49 with
more than 20 employees.  According to the 1987 Census of
Manufactures, there were  12 establishments  in SIC 2111,  20
 'Estimates of the percentage of plants using chromate
  corrosion inhibitors are based on an engineering survey
  of the major cooling water treatment chemical vendors.
                          9-27

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TABLE 9-10.  VALUE OF  SHIPMENTS FOR TOBACCO PRODUCTS,
              1980-19894'5
Value of Shipments (106 1991 dollars)*

1989
1988
1987
1986
1985
1984
1983
1982
1981
1980
•The data
for GNP.
Cigarettes
SIC 2111
23,468
22,535
20,130
18,779
18,278
17,621
16,528
16,499
15,281
14,374
are normalized
Ciaars
SIC 2121
221
226
222
302
299
314
379
345
399
406
using the
Chewing
and
Smoking
Tobacco
SIC 2131
1,409
1,330
1,291
1,271
1,161
1,018
915
905
884
864
implicit price
Total
25,098
24,091
21,643
20,352
19,738
18,953
17,822
17,749
16,564
15,644
deflator
                       9-28

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in SIC 2121, and 29 in SIC 2131.  The domestic cigar
industry had 16 companies in 1987 and the chewing and
smoking tobacco industry 23.  In 1990, there were six
domestic cigarette companies.
     Currently, the cigarette industry is dominated by the
two largest producers — Philip Morris, Inc. and R.J.
Reynolds Tobacco Co. — which in 1990 accounted for 70.9
percent of the market.  The remaining four companies held
the rest of the market with individual shares ranging from
3.7 to 10.8 percent.16
     Domestic decline in the consumption of cigarettes has
forced producers to diversify in an attempt to become less
dependent on cigarette sales.  For example, Philip Morris
has diversified into soft drinks, beer, and real estate.
R.J. Reynolds formed RJR Kabisco with the Nabisco
Corporation, and Brown and Williamson is a unit of B.A..T.
Industries.  Cigarettes remain the primary source of revenue
for these companies, but as the cigarette market becomes
more mature, cigarette producers will continue to diversify.
     9.1.5.3  Domestic Production.  Domestic production of
tobacco products is shown in Table 9-11.  Production of
cigarettes  in 1988 totalled  695 billion units, up less than
one. percent from the previous year.
     Overall production of  cigarettes  fell  2.7 percent  from
1980 to 1988.  Cigar production fell  50 percent; chewing  and
smoking tobacco production  fell 13.4  percent from 1980  to
1987.
     In all cases, production peaks occurred at  the
beginning of the decade.  Production  fell  as total
consumption of tobacco decreased  steadily  throughout the
decade.
                          9-29

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     TABLE 9-11.  U.S. PRODUCTION OF TOBACCO PRODUCTS,
                   1980-198817
                             " Quantity
            Cigarettes
 Cigars
(10* Units)
  Chewing and
Smoking Tobacco
    (10« kg)
1988
1987
1986
1985
1984
1983
1982
1981
1980
695.0
689.0
658.0
665.0
669.0
667.0
694.0
737.0
714.0 	
2.0
2.1
2.9
3.1
3.5
3.6
3.7
4.0
4.0
-— — — —
N.A.
64.0
66.7
71.7
73.9
73.5
73.9
73.9
73.9 	
— >•*••"« • 	 .»•••.. 	 ',t!
N.A. - Not Available.
                           9-30

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     9.1.5.4  Domestic consumption.   Domestic consumption
for tobacco products declined steadily throughout the decade
(Table 9-12).  From 1981 to..1989,  cigarette per-capita
consumption declined 24 percent,  cigar per-capita
consumption 42 percent, and chewing and smoking tobacco per-
capita consumption 35 percent.  The declines in consumption
are attributable to higher prices for tobacco products,
health concerns, declining social acceptance, and
restrictions on where people can smoke.
     The demand for tobacco products is generally believed
to be inelastic — that is, smokers will pay higher prices
to continue their habit.  Smokers, however, may be more
responsive to price than first believed.  The introduction
to the market of generic and discount brands shows that
consumers are at least conscious of the price of tobacco
products.  While the  demand for tobacco products is probably
still relatively inelastic, consumers are at least
responsive to price segmentation tactics by producers.
     9.1.5.5  Foreign Trade.  As domestic consumption of
tobacco  products declines, foreign markets become
increasingly important to  U.S. manufacturers.   Exports of
cigarettes  totalled $6.7 billion  (1991  dollars)  in  1990, a
31  percent  increase from  1989.16  The  leading markets for
U.S.  exports are Europe and  the  Far  East.  Information
concerning  imports is unavailable.
      9.1.5.6  ^mplovroent.  According to the 1989 Annual
Survey of Manufactures,  29,600  personnel were employed in
 SIC 2111, 22,100  of whom were production workers.
 Employment in the cigarette  industry is down 25 percent from
 the 39,300 personnel in 1980.4  SIC 2121 experienced a 62
 percent drop in employment;  2,300 personnel were employed by
 the industry in 1989 as opposed to 6,100 in 1980.4   Of the
                           9-31

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TABLE 9-12,
U.S. PER-CAPITA CONSUMPTION OF TOBACCO
 PRODUCTS,  1981-198916
                             Quantity
             Cigarettes
               (Units)
                 Cigars
                 (Units)
           Chewing  and
              Smoking
           Tobacco  (kg)
 1989
 1988
 1987
 1986
 1985
 1984
 1982
 1981
   2,926
   3,096
   3,197
   3,274
   3,370
   3,448
   3,739
   3,836
28.3
29.1
31.7
35.8
37.9
43.8
45.2
48.9
0.47
0.49
0.53
0.55
0.60
0.66
0.68
0.72
                       9-32

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2,300 employees in 1989, 1,800 were production workers.
There was a decrease of eight percent in the number of
personnel in SIC 2131 in the same time period; 3,300 were
employed in 1989 as opposed to 3,600 in I960.4 Two thousand
three hundred personnel were production workers in 1989.
     9.1.5.7  Outlook.  According to the 1990 U.S.
Industrial Outlook, the five-year forecast was that all
tobacco products would experience five percent annual
declines in output.  The cigarette industry was expected to
weather this decline due to strong foreign demand.  However,
it was expected that this foreign demand would level off
after record years at the end of the 1980s.
9.1.6  Tjextile Finishing
     Textile mill products are included in SIC group 22.
The group includes establishments involved in the
preparation of fiber and the manufacture of yarn, thread,
twine, and cordage; the manufacture of broad woven fabric
and carpeting; the dyeing and finishing of fiber, yarns, and
knit apparel; the coating and treating of fabrics; and the
manufacture of knitted apparel, felt goods, nonwoven
fabrics, and miscellaneous textiles.
     The types of textile mills most likely to use cooling
towers include finishing plants for cotton (SIC 2261),
finishing plants for manmade fibers  (SIC 2262), and
finishing plants not elsewhere classified  (SIC 2269).  The
establishments in SIC 2261 are engaged in finishing
purchased cotton broadwoven fabric as well as in  the
shrinking and sponging of cotton fabrics.  They also
chemically finish cotton fabrics for water repellency, fire
resistance, and mildew proofing.  In SIC 2262 manmade fiber
and silk broadwoven fabric are finished.   SIC Industry 2269
is made up of establishments which dye and finish textiles.
    The use of chromates in cooling towers in textile
manufacturing is less frequent than  in major  industries
                          9-33

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because the temperature of the manufacturing process is less
severe.  Survey results indicate that, at most, 2.5 percent
of the IPCT's used in textile production use
chromium-based corrosion inhibitors.*
     Due to the availability of data,  the information
presented pertains to the three industries only in certain
instances.  The information in the domestic production,
domestic consumption, foreign trade, and outlook sections is
for the textile industry as a whole.
     9.1.6.1  industry Shipments.  The value of industry
shipments from 1980 to 1989 is shown in Table  9-13.  SIC
2662 had the highest value of shipments in 1989 ($4,110
million) among the three industries.  However, this figure
represented a 7.6 percent decline from 1988.   Also
experiencing a decline was SIC 2261; the value of shipments
fell 3.2 percent to $1,513 million  in 1989.  Only SIC  2269
experienced growth between 1988 and 1989, growing 11.3
percent to a decade-high of $1,559 million.
     9.1.6.2  industry structure.  The textile industry  is a
complex production and marketing chain by which fiber  is
made into fabric or finished products for sale to consumers
and industrial users.  The steps performed at  each  part  of
this chain are complex and diverse.   Therefore, the firms in
textile manufacturing vary greatly  according to size and
specialization.  Several major  companies manufacture fabric
and finished products, while  smaller  firms are more special-
ized.  However,  no one company  dominates the  industry.
Since  the start  of the  1980s,  intense foreign  competition
has  forced the textile  industry to  undergo major
 "Estimates of the percentage of plants using chromate
  corrosion inhibitors are based on an engineering survey
  of the major cooling water treatment chemical vendors.
                           9-34

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TABLE 9-13.  VALUE OF SHIPMENTS FOR THE TEXTILE
             FINISHING INDUSTRIES, 1980-19894'5
SIC 2261 SIC 2262
•"
1989
1988
1987
1986
1985
1984
1983
1982
1981
1980
	 .-in i '••• 	 "-••
•The data
for. GNP.
1,513
1,563
1,609
1,045
1,038
1,076
1,137
1,026
1,591
1,946 	 	
are normalized

4,110
4,447
5,105
4,943
4,648
4,832
4,731
4,335
4,294
3,910
using the

SIC 2269
1,559
1,401
1,469
1,086
1,186
1,389
1,526
1,404
1,057
1,066
.-
implicit

Total
_ — — — — — — ^— —
7,182
7,411
8,183
7,074
6,872
7,297
7,394
6,765
6,942
6,922
price deflator

                      9-35

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restructuring.  Foreign textile manufacturers have lower
production costs, particularly lower labor costs.   As a
result, they have been able .to take away market share from
domestic producers.  To become more competitive, U.S.
producers have closed obsolete facilities, increased
expenditures on more productive equipment, and reduced the
labor force.  Furthermore, several major mergers and
acquisitions have taken place, solidifying the position of
some of the larger firms.
     According .to the 1987 Census of Manufactures, there
were 648 establishments in the three textile finishing
industries, owned by 605 companies.  Three hundred twenty-
one of these establishments employed 20 or more personnel.
SIC 2261 had 198 establishments owned by  184 companies.  The
largest total'number of establishments was in SIC 2262 where
there were 268 owned by 245 companies.  The 182
establishments (176 companies) in SIC 2269 were the  fewest
of the three industries.  There were 105  establishments
employing 20 or more personnel in SIC 2261, 123 in SIC 2262,
and 93 in SIC 2269.
       9.1.6.3  Domestic Production.  Output data for all
textile mill products is unavailable.  In lieu  of actual
output, Table 9-14 reports  the Federal Reserve  Board's
textile mill production index.  It  is evident that
production grew  21.2 percent  from 1980 to 1989.  Textile
production is heavily affected by the level of  inventories
held by apparel manufacturers and clothing retailers.  When
large  inventories  of apparel  are held, textile  production
must slow down until these  inventories are lowered.
     To become more competitive on  the world market, U.S.
producers have focused on increasing productivity by
reducing labor inputs and increasing capital expenditures on
                          9-36

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                                                     It
TABLE 9-14.  TEXTILE MILL PRODUCTION INDEX, 1980-1989
                             Total Textile Mill Products
                                      (1980=100)	
          1988
          1988
          1987
          1986
          1985
          1984
          1983
          1982
          1981
          1980
121.2
115.3
115.0
108.3
101.4
103.4
100.1
 88.5
 97.3
100.0
                        9-37

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plant equipment.  Investment in plant and equipment totalled
$2.2 billion in 1989 and $2.1 billion in 1990.w
     Data for 1988 indicate that the capacity utilization
rate was 89 percent in SIC 2261, 90 percent in SIC 2262, and
68 percent in 2269.13
     9.1.6.4  Domestic Consumption.  Consumption of textile
products can be viewed in terms of three markets:  the home
furnishing market, the apparel market, and the industrial
and commercial market.  Approximately 38 percent (2,332
million kilograms in 1988) of textile fiber shipments go to
the home furnishing market.  In 1989, consumers spent $17.4
billion on semi-durable home furnishings.  Major home
products include carpets, bedclothes, drapes, and towels.
This market is highly cyclical and is determined by the
level of disposable income.  During the recession of the
early 1980s, demand for home furnishings  (and hence textile
products) was down, particularly for carpets, which are
high-price, replacement items.  Approximately 60 percent of
textile fibers used in home furnishings are used in the
production of carpets and rugs.18
     A key market in the textile industry is  the apparel
market, which uses approximately 37.4 percent (2,283 million
kilograms in 1988) of all fiber processed.  The market  is
important to textile manufacturers because of the  large
consumer outlays  each year on  apparel.  An estimated  $170
billion was spent on clothing  in 1989.18
     Industrial uses for  textile fabrics  account for  roughly
21 percent  (1,282 million kilograms  in  1988)  of  all textile
fibers and  include medical uses, filtration  products,
automobile  seat covers, and  book bindings.  Like the  home
furnishing  and  apparel  markets, demand  for textile fabrics
in industrial applications  is  cyclical.   Usage of industrial
fibers declined in  1982 and  again  in 1985 in response to
business  cycle  downturns.11
                           9-38

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     9.1.6.5  r™"»
-------
inner tube industry includes the manufacture of tires for
autos, aircraft, farm vehicles, bicycles, and trucks.
According to survey results, .no more than 7.5 percent of the
IPCT's employed in tire and inner tube manufacturing use
chrornate corrosion inhibitors.1
     9.1.7.1  Industry Shipments.  The value of shipments
from 1980 to 1989 is listed in Table 9-15.  The value of
industry shipments fell during the 1982 recession and the
1985 economic downturn.  There was growth of 6.4 percent
from 1986 to 1988.  The value subsequently dropped less than
one percent in 1989, ending the decade at $12,559 million.
     9.1.7.2  Industry Structure.  The 1987 Census of
Manufactures reports that 115 companies operated 163
facilities in the tire and inner tube industry.  Ninety-
seven facilities  (59.5%) employed 20 or more personnel.
     The tire industry has become global after a series of
sales, mergers, acquisitions, and restructurings in the
1980s.  A substantial amount of domestic capacity is now
controlled by foreign firms.  There remain only two public
tire manufacturers, Goodyear Tire and Rubber and Cooper Tire
and Rubber.  The  firm with the largest world market  share is
Michelin, with a  22 percent share.  Goodyear controls 20
percent of the world market, Bridgestone/Firestone 17
percent, Continental General nine percent, and
Pirelli/Armstrong six percent.21
     Nearly all of the largest tire manufacturers are
vertically integrated.  These manufacturers produce  the
necessary raw material  (carbon black, synthetic rubbers,
etc.) and many often market their tires directly to
•Estimates of the percentage of plants using chromate
 corrosion  inhibitors  are based on an  engineering  survey
 of the major  cooling  water  treatment  chemical vendors.
                          9-40

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     TABLE 9-15.
VALUE OF SHIPMENTS FOR THE TIRE AND
 INNER TUBE INDUSTRY,  1980-19894-5
                                   Value  of  Shipments
                                    (106 1991 Dollars)*
             1989
             1988
             1987
             1986
             1985
             1984
             1983
             1982
             1981
             1980
                        12,559
                        12,615
                        12,083
                        11,853
                        12,802
                        13,556
                        13,323
                        12,708
                        14,285
                        13,973
•The data  are  normalized using the implicit price deflator
 for GNP.
                          9-41

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consumers through company-owned retail outlets.   The
large producers are also diversified into non-tire markets,
most often into related chemical fields.
     In addition to large multinational tire producers,
there are a number of independent tire manufacturers.  These
companies all operate more or less domestically, are less
integrated, and often market on a geographic or specialty
product basis.
     9.1.7.3  nomestic Production.  Production of passenger
car, truck, and bus tires is shown in Table 9-16.  Domestic
production of tires rose one percent in 1989 to 216.4
million units.  Production of tires in the U.S. declined
during 1982 and 1985.  Production, however, is  still below
levels in the latter part of the  1970s.   In 1977, the U.S.
produced 232'million units, 6.7 percent more than 1989
production.
      9.1.7.4  nomestic consumption.  The  decline  in tire
demand in  recent  years is due  in  large  part to  the
popularity of the radial tire.  Radial  tires have useful
lives double  that of  the bias  ply and have  become  the
consumer's choice in  the original equipment market  (OEM)  and
the replacement market.  Radial tires  accounted for 94
percent  of passenger  car tires and 65  percent  of highway
truck tires sold in 1989.   Despite an increase in the number
 of registered vehicles in the U.S.,  tire consumption has
 declined as consumers need tires less frequently.   Imported
 cars (equipped with foreign tires) and imported tires have
 also contributed to the decline in U.S. tire consumption.21
      The demand for tires is most likely relatively
 inelastic because tires are necessities for which no
 substitutes exist.  Consumers, though, are to some degree
 conscious of price as seen in the increase in  lower-priced
 imports.  Except  in the case of specialty, high performance
                           9-42

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TABLE 9-16.  U.S. PRODUCTION OF CAR, TRUCK, AND  BUS
              TIRES,  1980-198921
                               Quantity  (10* Units)
         1989
         1988
         1987
         1986
         1985
         1984
         1983
         1982
         1981
         1980
216.4
214.6
206.0
190.3
196.9
209.4
186.9
178.5
181.8
159.3
                       9-43

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tires, however, consumers purchase tires out of necessity.
While the decision to purchase tires certainly includes
consideration of price, it is doubtful that consumers who
need tires would postpone the purchase solely on the basis
of price.
     9.1.7.5  Foreign Trade.  Between 1985 and 1990, imports
grew steadily.  Exports grew sharply between 1988 and 1989.
In 1989, exports were valued at $918 million (1991 dollars)
while imports were valued at $2,868 million.22
     9.1.7.6  Employment.  In 1989, there were 68,000
employees in SIC 3011 according to the Annual Survey of
Manufactures.  Fifty-four thousand, six hundred  (80%) were
production workers.
     9.1.7.7  Outlook.  Tire production is forecast to grow
by only one percent annually for the next several years
according to Standard and Poor's Corporation.21   Further
consolidation will force small private tire manufacturers to
cooperate more closely with their customers.  Speed of
delivery and quality of service, not quality differences.
between tires, are increasing in importance.
9.1.8  Glass Products
     The segments of the glass products industry most  likely
to use chromates are the producers of flat glass (SIC  3211)
and glass containers  (SIC 3221).  Flat glass products
include those used in building construction, car windows and
windshields, mirrors, solar panels, and signs.   Glass
container products are used for commercial packaging,
commercial bottling, and home canning.
     Glass product manufacturers are relatively  minor  users
of chromium-based corrosion inhibitors.   Survey  results
indicate that  no -more than  2.5 percent of the cooling  towers
                          9-44

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used in flat glass and glass container production use
chromate corrosion inhibitors.*
     9.1.8.1  Industry shipments.  The constant dollar value
of industry shipments for the glass products industry is
shown in Table 9-17.  The value of industry shipments of
flat glass products fell 2.8 percent in 1989 to $2,664
million.  Prices have declined in recent years as
manufacturers engaged in price competition to boost volume.
Shipments of glass containers also fell in value, declining
2.0 percent to 5,174 million.
     9.1.8.2  industry Structure.  For the flat glass
industry  (SIC 3211) the 1987 Census of Manufactures reported
that there were  84 establishments, 38  (45%) of which
employed  20 or more personnel.   In 1987,  SIC  3221, the  glass
container industry, had 106 establishments, 88 percent  (93)
employing 20 or  more personnel.
     9.1.8.3  Domestic Production.  Table 9-18 reports
production data  for  flat  glass  and glass  containers.  The
production of flat glass  rose  steadily from 1986  to  1989,
then  levelled out at 4.7  billion square feet.  Production of
glass  containers peaked  in 1989 when  285.5 million units
were  produced.
      9.1.8.4  pomestic consumption.   Nearly  57 percent of
 flat  glass shipments is  consumed by the construction
 industry and 25 percent is used by the automotive industry.23
 The remaining quantity is used in "specialty products" such
 as signs, mirrors, and solar panels.   Demand for flat glass
 •Estimates of the percentage of plants  using chromate
  corrosion inhibitors are based on an engineering survey
  of the major cooling water treatment chemical vendors.
                           9-45

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      TABLE 9-17
VALUE OF SHIPMENTS FOR SIC 3211 AND
SIC 32214-5
                  Value of-Shipments  (106 1991 Dollars)'
                  Flat Glass
                  Glass
               Containers

1989
1988
1987
1986
1985
1984
1983
1982
1981
1980 	
SIC 3211
2,664
2,741
2,954
2,868
2,645
2,583
2,530
2,266
2,398
2,455
	 — 1^— l«l —
SIC 3221
5,174
5,280
5,536
5,535
5,645 .
5,662
6,370
7,098
7,129
7,132
Total
7,838
8,021
8,490
8,403
8,290
8,245
8,900
9,364
9,527
9,587
*The  data are normalized using the implicit price deflator
 for GNP.
                           9-46

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TABLE 9-18.  U.S. PRODUCTION OF FLAT GLASS
             AND GLASS  CONTAINERS, 1986-199023'24


Quantity

Flat Glass Glass Containers
(10* square feet) (106 units)





est.
N.A.
1990
1989
1988
1987
1986
- Estimate.
- Not Available.
4.2 (est.) 285
4.7
4.2
4.1
3.7


.1 (est.)
285.5
280.4
281.6
N.A.


                  9-47

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in the automobile and construction industries has declined
due to the recession beginning in 1989.
     Glass containers are most frequently used to hold beer,
food, and soft drinks.  These markets accounted for 86
percent of glass container shipments in 1989.  Demand for
glass containers fell slightly in 1990 as metal cans gained
market share.24
     Estimates of the elasticity of demand for flat glass
products and glass containers are unavailable.  Flat glass
products are necessary inputs in building construction and
automobile manufacturing, although plastics can be used as
substitutes.  Also, the cost of flat glass products, in most
cases, represents a small portion of the final cost of
buildings and automobiles.  These factors suggest that the
demand for flat glass products is somewhat inelastic.
     The demand for glass containers is most  likely less
inelastic than the demand for flat glass products because of
the availability of close substitutes  in aluminum cans and
plastics.  Glass container manufacturers may  have some
difficulty in passing on large price increases.
     9.1.8.5  Foreign Trade.  In  1989, exports of flat glass
were valued at $534 million  (1991 dollars) and imports at
$460 million.23  Exports of glass  containers were valued at
$51 million  (1991 dollars) while  imports were valued  at $190
million.24
     9.1.8.6  Employment.  According to the Annual  Survey of
Manufactures, there were 15,000 personnel employed  in SIC
3211 in  1989, 12,100  (81%) of whom were production  workers.
Thirty-nine thousand  three hundred personnel  were employed
in SIC 3221,  34,500  (88%) of whom were production workers.
     9.1.8.7  outlook.   Strong demand  from the automotive
and  construction  industries  for  flat glass is expected to
boost output  after the  mid-1990s.  New product development
                          9-48

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will continue in order to generate new demand in these
industries.23
     The glass container industry is expected to grow one
percent annually from 1991 to 1995.  The majority of glass
containers will be utilized by the food and beverage
industries.24
9.2  ECONOMIC IMPACT ANALYSIS
     This section examines the economic impacts resulting
from the regulation of hexavalent chromium emissions from
IPCT's.  To determine the economic impacts, three regulatory
alternatives  (RA's) are considered.  Regulatory alternative
one  (RA I) involves no further regulatory action, while
regulatory alternatives two and three  (RA II and RA III)
require regulation of emissions.  RA II requires IPCT's
using  chromates to be retrofitted with high-efficiency drift
eliminators  (HEDE's); RA III requires  a total ban of
chromate use  in IPCT's.  Both RA II and RA III will have
economic impacts on firms using chromates in their IPCT's.
These  impacts are expressed  in terms of price increases  and
the  resultant reductions in  quantity demanded.
9.2.1  Methodology
     The  implementation  of emissions control techniques
causes an  increase  in the costs of production.   This
increase  in  costs  results in an upward and  leftward  shift of
the  regulated firm's  supply  curve  (in  other words,  a
decrease  in  supply).  This decrease leads  to a  higher price
and  a  lower  quantity  demanded.  The shift  of the regulated
 firm's supply curve also causes  a  corresponding shift in the
market supply curve for an  industry;  the market supply curve
 is by definition the horizontal  summation  of the supply
 curves of all firms in the  industry.   A leftward shift,  or
 decrease in supply, of the market supply curve will result
 in a higher equilibrium price and lower quantity demanded
 for the industry.
                           9-49

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     This analysis will calculate the maximum percentage
change in price for two different scenarios.   Both scenarios
assume that the affected firms will be able to fully pass on
their control costs. Scenario I also assumes that the
marginal firms in the regulated industry are the ones still
using chromates in their IPCT's.  Therefore,  only the
marginal firms will experience an increase in costs due to
the regulation of chromate use.  In order to calculate the
maximum percentage change in price, we divide the control
costs associated with a regulatory alternative by the total
revenue attributable to chromate users.  This approach
averages the price  increase among the firms using chromates
in their IPCT's.  For the regulation of hexavalent chromium
emissions, the control costs result from either the use of
HEDE's or the substitution of  nonchromate corrosion
inhibitors.  The  first step  in deriving the total revenue
attributable to chromate users is to multiply the value  of
shipments for the regulated  industry by the percentage  of
facilities using  IPCT's.  This product  is then multiplied  by
the  percentage of IPCT's using chromates  in  order to obtain
the  revenue  base.
      However,  firms using  chromates may not  be  the  marginal
firms in their respective  industries.   Thus,  a  second
approach is  used to calculate the percentage price  increase.
 Scenario II  estimates the  expected price increase by
 averaging the increase in costs across an entire regulated
 industry.  To calculate the average price increase, the
 control costs associated with either regulatory alternative
 are divided by the total value of shipments for the
 regulated industry.  This average price increase represents
 a point estimate of the expected cost increase for the
 marginal firm.   Since the estimate represents an average
 price increase, we should expect some of the more efficient
 firms in each industry to experience a lower cost  increase.
 We  should also expect that some of the less efficient  firms
        '  .                 9-50

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will experience a greater cost increase than the average
estimate.
     It is difficult to determine what the actual percentage
price increase will be for a firm using chromate corrosion
inhibitors.  The distribution of IPCT's among firms in the
regulated industries is unknown.  It is also not known
whether firms using chromates in their IPCT's have a great
amount of pricing discretion.  These firms will absorb some
of the control costs associated with RA II and RA III if
they cannot achieve the maximum percentage price increases.
     An important determinant of the size of the percentage
increase in the equilibrium price for a regulated industry
is the market structure.  Under perfect competition, firms
will be able to fully recover costs through the price
increase.  However, as the market structure deviates from
perfect competition, the price  increase will be less than
what is necessary to fully recover costs.  Since the seven
regulated  industries under consideration are not fully
competitive, the firms in the industry will increase their
prices by  less than what is  necessary to fully recover
control  costs.  Note, however,  that the calculations in this
analysis assume full-cost pass  through; in other words,  the
calculations are based on the model of perfect competition.
     An  increase  in price will  result  in a decrease in the
quantity demanded  or  output.  The percentage reduction in
output can be  calculated using  the  formula  for the price
elasticity of  demand.
                           E =
where E
     %AQD
      %A?
             price elasticity of demand
              percentage change in quantity demanded
             percentage change in price
                           9-51

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Rearranging the formula:
                       %AQD «• %AP X E
Thus, the percentage change in quantity demanded can be
determined using the previously calculated percentage
changes in price for either scenario and an estimate of the
price elasticity of demand.
     The price elasticity of demand is a measure of the
responsiveness of the quantity demanded to changes in price.
If the price elasticity is between 0 and -1, then demand is
characterized as being price inelastic.  An increase in
price will cause a less than proportional decrease in the
quantity demanded.  The more price inelastic demand is, the
greater the ability of producers to increase prices without
losing output.  Since the percentage change in price is
greater than the percentage change in quantity demanded, we
expect the total revenue of producers to increase. When the
price elasticity is equal to -1, demand is characterized as
being unitary  elastic,  and the changes in price and quantity
demanded are the same.  Because  the changes exactly offset
each other, total  revenue will remain the same.   Finally,
when the price elasticity  is  less  than -1, then an  increase
in price will  cause a more than  proportional decrease  in the
quantity demanded.  In  this  case demand is characterized as
being elastic.  Relatively elastic demand restricts the
ability of  producers  to increase prices without  losing
output and  therefore  revenues.   Since  the percentage change
in quantity demanded  will  be greater than the  percentage
change  in  price,  we expect the total revenue  of  producers  to
decrease,if they increase  the price of their  products.
      In this analysis it can be assumed that  the demand
 curve for  each industry under consideration is most likely
price inelastic.   However,  because published  estimates of
 the various price elasticities are rare,  the  percentage
 reductions in the quantity demanded are calculated using an
                           9-52

-------
inelastic estimate of price elasticity (-0.5),  an unitary
elastic estimate (-1.0), and an elastic estimate (-1.5).
Another reason for using the three estimates is that the
demand curves for the products associated with a particular
industry will most likely vary from being relatively
inelastic to being slightly inelastic.  For example, while
the demand for flat glass products is relatively inelastic,
the demand for glass containers is only slightly inelastic
due to the possible substitutes previously mentioned.  Using
the inelastic and unitary elastic estimates accounts for the
variability of inelasticity in each industry.  The elastic
estimate is used as a worst-case estimate; if demand were
elastic, then an increase in price would cause a larger
percentage reduction in the quantity demanded than if demand
were inelastic or unitary elastic.
9.2.2  Percentage Price Increases
     As outlined in the methodology, the maximum percentage
price increases are calculated for two different scenarios.
In addition, control costs are calculated for two.regulatory
alternatives.  The choice of scenario will not change total
control costs for either regulatory alternative;  These
costs are listed in Table 9-19.  For either regulatory
alternative, the industry that will bear the highest control
costs is the chemical industry.  The  industries that have
the highest percentage  of IPCT's using chrornate corrosion
inhibitors  (chemical manufacturing, petroleum refining,  and
primary metals) bear higher control costs than the
relatively minor users  of chromates  (tobacco products,
textile finishing, tire and rubber products, and glass
products).
     The revenue figure used to calculate the percentage
price  increases depends on the assumptions we make.  For
Scenario I, where we assume that the  marginal  firms are
                          9-53

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     TABLE 9-19.   ANNUAL CONTROL COSTS (1991 DOLLARS)
                  FOR THE REGULATED INDUSTRIES23
     Industry
                           " Regulatory Alternative
II:  HEDE
Retrofits
                                        III:  Nonchromates
Chemical
Manufacturing
Petroleum Refining
Primary Metals
Tobacco Products
Textile Finishing
Tire and Rubber
Products
Glass Products
6,640,000

2,870,000
1,380,000
   87,700
  157,000
  170,000

    8,520
7,260,000

4,470,000
1,990,000
   93,700
   81,100
  113,000

    5,650
                          9-54

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using chromates, the revenue figure used for each regulated
industry is the value of shipments of the industry
attributable to chromate users.  As previously mentioned,
control costs are averaged across the entire industry for
Scenario II due to the lack of information for identifying
firms using chromates.  Thus, the total value of shipments
of the industry is used as a revenue figure.  The revenue
figures used for both scenarios are listed in Table 9-20.
     The data reported in Tables 9-19 and 9-20 allow us to
calculate the maximum percentage price increases.  Table
9-21 details the results for Scenario I.  For all industries
the percentage  increases are very small.  The largest
increases will  occur in chemical manufacturing; the marginal
firm will have  to  increase prices by 0.299 percent if IPCT's
are retrofitted with HEDE's, and 0.326 percent  if the use  of
chromates in IPCT's is banned  altogether.
     If control costs are assigned to all firms in the
industry  (Scenario II), then the percentage  price increases
are even smaller  (Table 9-22).  Except for the  chemical
manufacturing  industry, in no  case will  firms  in an  industry
have to  increase  price by more than  0.010 percent.   Firms  in
chemical manufacturing will  have to  increase price by  0.010
percent  for RA II or  0.011 percent  for RA III  to fully
recoup control costs.
9.2.3  Percentage Reductions in the  Quantity Demanded
      The percentage reductions in the quantity demanded in
each industry are detailed in Tables 9-23 and 9-24.  Using
the derived percentage price increases,  the reductions were
 calculated for inelastic,  unitary elastic,  and elastic
 demand scenarios.
      As was the case with the percentage changes in price,
 all the percentage reductions are very small for both
 scenarios.   In no case would an industry experience even a
                           9-55

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     TABLE 9-20.   REVENUE FIGURES  FOR PRICE INCREASE
                   SCENARIOS I AND II
     Industry
1989 Value of Shipments (1991 Dollars)
  Scenario I:          Scenario II:
  Marginal Firms
 Us ing Chromates
                                         All Firms Using
                                             Chromates
Chemical
Manufacturing
Petroleum Refining
Primary Metals
Tobacco Products
Textile Finishing
Tire and Rubber
Products
   2,224,167,097

  28,213,400,000
   2,762,883,369
     504,017,213
      86,450,000
     560,532,055

     135,102,368
 65,152,000,000

141,067,000,000
 60,915,000,000
 25,098,000,000
  7,182,000,000
 12,559,000,000

  7,838,000,000
                          9-56

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        TABLE 9-21.   PERCENTAGE PRICE INCREASES FOR
                     SCENARIO I
Industry
                            Regulatory Alternative
II:  HEOE
Retrofits
III:  Nonchromates
Chemical
Manufacturing
Petroleum Refining
Primary Metals
Tobacco Products
Textile Finishing
Tire and Rubber
Products
Glass Products
  0.299%

  0.010%
  0.050%
  0.017%
  0.182%
  0.030%

  0.006%
      0.326%

      0.016%
      0.072%
      0.019%
      0.094%
      0.020%

      0.004%
                         9-57

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        TABLE  9-22.  PERCENTAGE PRICE INCREASES FOR
                      SCENARIO II
      Industry
                             Regulatory Alternative
II:  HEDE
Retrofits
                                         III:   Nonchromates
 Chemical
 Manufacturing
 Petroleum Refining
 Primary Metals
 Tobacco Products1
 Textile Finishing
 Tire and Rubber
 Products
 Glass Products1
  0.010%

  0.002%
  0.002%

  0.002%
  0.001%
0.011%

0.003%
0.003%

0.001%
0.001%
*The percentage  changes  are  less  than  0.001%.
                          9-58

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one percent reduction in the quantity demanded.   Table 9-23
details the reductions in quantity demanded for Scenario I.
These reductions in the quantity demanded will occur if
chrornate-using firms are the marginal firms in the industry
and increased price to fully recoup control costs (Scenario
I).  The chrornate-using firm in the chemical manufacturing
industry would experience the largest output reductions.  If
demand were elastic, the quantity demanded would drop by
0.448 percent for RA II and a 0.490 percent for RA III.  The
chemical manufacturing industry will also have the largest
reductions in quantity demanded if control costs are borne
by the entire industry (Scenario II).  These reductions are
detailed in Table 9-24.  Under RA II the reduction will be
0.015 percent, while under RA III it will be 0.017 percent.
9.2.4  Further Analysis of the Chemical Manufacturing
       Industry
     Some of the chemicals produced  by the chemical
manufacturing industry have a low market price due to  the
low value added during production.   Firms producing low
value-added chemicals may experience greater economic
impacts than firms  producing high value-added chemicals
because control costs as a percentage of price are higher.
     However, an analysis of a  low  value-added chemical,
ethylene,  indicates that the impacts resulting from the
regulation of hexavalent chromium emissions are  less  severe
than those for  the  chemical  industry overall.  The results
show that  impacts are not only  a  function  of  price but a
function of volume  as well.  A  low  value-added chemical
would  have to be produced at low  volume  in order for  firms
 in the industry to  experience  significant  impacts.   Based on
 our knowledge of  the chemical  industry,  we observe  that most
 low value-added chemicals are  in  fact produced at high
 volumes.   Thus,  control costs  are spread over a larger
 volume of  output,  resulting in a  lower unit cost of
 compliance and less severe  impacts.
                          9-59

-------
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9.3  SMALL BUSINESS IMPACTS
     According to the Regulatory Flexibility Act, the
proposing agency must determine whether the regulation will
have a significant impact on a substantial number of small
entities.  If more than 20 percent of small entities are
significantly impacted, then a Regulatory Flexibility
Analysis (RFA) must be prepared.  Using the criteria of the
Act, it can be determined that there is not a significant
impact on a substantial number of small entities due to the
regulation of hexavalent chromium emissions from IPCT's.
     A significant impact occurs if any of the following
four criteria are satisfied.  The first criterion is that
annual compliance costs increase total costs of production
by more than 5 percent.  The second criterion is that
compliance costs as a percent of sales are at least 10
percentage points higher for small entities.  If the capital
cost of compliance represent a significant portion of the
capital available to small entities, then the impact is
considered significant.  Finally, the impact is also
considered significant if the requirements are likely to
result in closures of small entities.
     It is highly unlikely that any criterion would be met
for either regulatory alternative.  Information is not
available concerning the costs of production for firms in
the regulated industries.  However, because compliance costs
as a percentage of value of shipments are very small, it is
highly unlikely that the total costs of production would
increase by more than five percent.  In other words, the
assumption is that the value of shipments can be used as an
approximation of the costs of production.  It is also
doubtful that compliance costs as a percentage of sales
would be significantly higher, as shown by the
aforementioned percentage price increases.  Capital
availability should not be constrained because total control
costs are relatively small and would not require extensive
                          9-62

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capital financing.  If capital availability is not a
problem, then the likelihood of closures is small.  Since
there are no significant impacts on a substantial number of
small entities, an RFA is not"required.
                          9-63

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REFERENCES
 1.  "The Corrosion Inhibitors Market, Report #A1048."
     Frost and Sullivan, Inc., New York, NY.  1982.  pp. 4,
     9, 117.
 2.  Memorandum.  Marinshaw, R., MRI, to Myers, R., EPA:ISB.
     April 3, 1991.  Trip report:  Nalco Chemical Company,
     Naperville,' Illinois, on February 22, 1991.
 3.  Memorandum.  Marron, J., MRI, to Myers, R., EPA:ISB.
     April 3, 1991.  Trip report:  Betz Industrial, Trevose,
     Pennsylvania, on February 26, 1991.
 4.  1987 Census of Manufactures.  U.S. Department of
     Commerce, Washington, DC.
 5.  1989 Annual Survey of Manufactures, U.S. Department of
     Commerce, Washington, DC.
 6.  Industry Surveys, "Chemicals — Basic Analysis."
     Standard & Poor's Corp., New York, NY, November  8,
     1990.  pp. C42, C48.
 7.  U.S. Industrial Outlook  1991 — chemicals  and Allied
     Products,  pp. 12-1-12-13.
 8.  Chemical and  Engineering News.  51(25):32-41.  June  24,
     1991.
 9.  Telecon.  MRI, to Laffly,  G., American Petroleum
     Institute.  June 18,  1991.   Information  on petroleum
     refineries.
 10.  Petroleum  Supply Annual  1990, Volume 1.   U.S.
     Department of Energy,  Washington,  DC.  pp. xi,  16-26,
     49,  81.
 11.  U.S. Industrial Outlook  1991 — Petroleum Refining.
     pp.  4-2; 4-4.
 12.  Mineral Commodities  Summaries,  1991.   U.S. Department
     of the Interior, Washington, DC.   p.  5.
 13.  Current Industrial Reports - Manufacturers' Utilization
     of Plant Capacity.   U.S. Department of Commerce,
     Washington,  DC.  April 1990.
 14.  U.S.  Industrial  Outlook 1991 — Metals,   pp. 15-1,
      15-5.
                           9-64

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15.  Industry Surveys,  "Steel and Heavy Machinery — Basic
     Analysis."  Standard & Poor's Corp.,  New York, NY,
     August 9, 1990, pp. 525-27.

16.  Industry Surveys,  "Food,. Beverages, and Tobacco —
     Basic Analysis."  Standard & Poor's Corp., New York,
     NY,. June 27, 1991, p. F34-F35.

17.  Statistical Abstract of the United States 1990.  U.S.
     Department of Commerce, Washington, DC.  p. 752.

18.  Industry Surveys,  "Textiles, Apparel, and Home
     Furnishings — Basic Analysis."  Standard & Poor's
     Corp., New York, NY, June 14, 1990, p. T79-T83.

19.  U.S. Industrial Outlook 1991 — Textiles,  p. 9-1.

20.  Industry surveys,  "Textiles, Apparel, and Home
     Furnishings - Current Analysis."  Standard & Poor's
     Corp., New York, NY, June 13, 1991, p. T52.

21.  Industry Surveys,  "Autos-Auto Parts — Basic Analysis."
     Standard & Poor's Corp., New York, NY, December 13,
     1991, p. A94-A96.

22.  U.S. Industrial Outlook 1991 — Plastics and Rubber.
     p.  14-2.

23.  U.S. Industrial Outlook 1991 — Construction Materials.
     pp. 7-3, 7-9.

24.  U.S. Industrial Outlook 1991 — Cans  and Containers.
     pp. 11-2, 11-4.

25.  Memo.  Midwest Research Institute  to  Phil Mulrine,
     Environmental Protection Agency/ISB/SSS, September 20,
     1991.
                          9-65

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                   APPENDIX A.




EVOLUTION OF THE BACKGROUND INFORMATION DOCUMENT

-------

-------
  APPENDIX A.  EVOLUTION OF THE BACKGROUND INFORMATION DOCUMENT

     The source category survey (Phase I.)  for chromium emissions
from industrial process cooling towers (IPCT's)  was begun in
October 1984 by the U. S. Environmental Protection Agency (EPA).
In April 1985, 18 Section 114 information requests were sent; 9
of these requests -were sent to petroleum refineries, and 9 were
sent to primary metals facilities.  All but one of these
facilities responded to the information request.  The study to
develop a national emissions standard for chromium emissions from
IPCT's was initiated in September 1985.  Table A-l lists major
events and accomplishments in the evolution of the background
information document  (BID) for the standard.
     In October 1985, an effort was begun to obtain the
information needed to develop the BID  (Phase II)." The
information gathering effort included literature surveys;
canvassing of State, regional, and local air pollution control
agencies; plant visits; meetings with industry representatives;
contacts with engineering consultants and equipment vendors;
Section 114 information collection; and emission testing.
     Twelve plants were visited to gather background information
(including the types of water treatment programs and drift
eliminators used) on IPCT's and to identify candidate test sites.
As a result of the plant visits, four emission tests were
conducted on a total of six cooling towers.  Of these six cooling
towers, three were equipped with high-efficiency drift
                               A-l

-------
eliminators "(HEDE's), two were equipped with low-efficiency drift
eliminators (LEDE'S), and one was equipped with both.
     Additional Section 114 information requests were sent to
three petroleum refineries, five chemical manufacturing
facilities, and one primary metals facility in June 1986.  All of
these facilities responded to the information request.
     Chapters 3 through 6 and 8 of the draft BID, which describe
the industry,  emission control techniques, model plants,
regulatory alternatives, and cost of emission controls, were
completed in February 1987 and mailed to industry for review and
comment.            ,    .
     In April 1987, Section 114 information requests were sent to
139 companies.  Of these 139 companies, 61 reported that they had
no cooling towers.  The remaining 74 companies  (76 facilities)
that responded to the request comprised 38 chemical manufacturing
plants, 8 tire and rubber plants, 5 petroleum refineries, 5
textile finishing plants, 5 tobacco processing plants, 3 food and
kindred products plants, 3 primary metals plants, 3 steel plants,
2 pulp and paper plants, and 2 flat glass and container plants.
The overall response rate for the information request was 97
percent.
     In September 1987, evaluation of test data obtained at the
Southeastern Manufacturing Facility (SMF) revealed the potential
for conversion of hexavalent chromium to trivalent chromium in
the cooling tower.  The regular project schedule was delayed in
December 1987 to permit additional source testing and laboratory
studies to determine the extent of conversion and whether
conversion was occurring in the cooling tower, drift eliminator,
or sampling train.  Despite additional testing by EPA using test
methods that were designed specifically to prevent conversion in
the sampling equipment, conversion from Cr+° to Cr+3 could not be
eliminated.
     In October 1989, sites were conducted to four petroleum
refineries that had recently converted IPCT's from chromate-based
to nonchromate-based water treatment programs.  The purpose of
the visits was to determine the effectiveness of nonchromate-
                               A-2

-------
 based water  treatment  programs  in  comparison  to  the  chromate-
 based programs  that  had  been used  previously  at  the  refineries.
      During  the period of  July  to  December  1989,  six plants with
 IPCT's  that  were  equipped  with  HEDE's were  visited.  The purpose
 of  the  visits was to evaluate the  feasibility of additional
 emission testing  using a different test method that  quantified
 drift rates  based on the emissions of surrogate  elements.  In
 July 1990 and January  1991, source tests were conducted at two
 facilities using  the surrogate  element test method.
      From February to  May  1991,  surveys were  sent to nine
 chemical manufacturing companies and nine water  treatment '
 chemical suppliers in  order to  determine the  costs and
 effectiveness of  nonchromate-based water treatment programs.  The
 surveys focused on the performance of nonchromates in  severe
 operating environments.  The response rates for  the  chemical
 company and  water treatment supplier surveys  were 100  percent and
.44  percent,  respectively.  Information on cooling tower and drift
 eliminator costs  and designs was also gathered by telephone from
 several manufacturers.
      In November  1991, the BID  was revised  to incorporate the 'new
 data that had been collected during the previous three years, and
 the status of the project  was presented to  the National Air
 Pollution Control Techniques Advisory Committee.  Three work
 group meetings  were  held between April and  August 1992 to discuss
 the .status of the project, options selection, and the  draft
 preamble and standard.  The BID was again revised in
 September 1992  prior to  Work Group Closure.
                                A-3

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TABLE A-l.  EVOLUTION OF THE BACKGROUND INFORMATION DOCUMENT
(Dale
12/06/84
02/07/85
02/21/85
02/28/85
04/15/85
04/16/85
04/17/85
04/18/85
04/23/85
05/08/85
08/08/85
08/20/85
09/01/85
09,76/85
01/07/86
01/15/86
01/15/86
01/20/86
01/30/86
01/31/86
02/10/86
03/03/86-
03/07/86
03/27/86
04/17/86
04/21/86
05/07/86
Company, coiuultint, or agency/location
U. S. Environment*! Protection Agency
Mogul Division, Dexter Corp., Chagrin Falls, OH
Marley Cooling Tower Company, Mission, KS
U. S. Environmental Protection Agency, EM6
Mobil Oil Corporation, Torrance, CA
Arco Petroleum Products Company, Carson, CA
Chevron U.S.A. Inc., Richmond, CA
Amoco Oil Company, Chicago, IL
Atlantic Richfield Co., Los Angeles, CA
Chevron U.S.A., Inc., San Francisco, CA
Exxon Company, U.S.A., Houston, TX
Gulf Oil Products Co., Houston, TX
Mobil Oil Corp., Fairfax, VA
Phillips Petroleum Co., Barflesville, OK
Shell Oil Co., Houston, TX
Texaco, Inc., Houston, TX
Armco Inc., Middleton, OH
Bethlehem Steel Co., Bethlehem, PA
Inland Steel Corp., East Chicago, IL
LTV Steel Company, Cleveland, OH
Lone Star Steel Co., Lone Star, TX
McLouth Steel Products Corp., Trenton, NJ
National Steel Corp., Pittsburgh, PA
U.S. Steel Corp., Pittsburgh, PA
Wheeling-Pittsburgh Steel Corp., Wheeling, WV
Chemical Manufacturers' Association,
Washington, D.C.
U. S. Environmental Protection Agency, ISB
U. S. Environmental Protection Agency
U. S. Environmental Protection Agency
U. S. Environmental Protection Agency
U. S. Department of Energy (DOE), Paducah, KY
U.S. Environmental Protection Agency
Association of Building Owners and Management
(ABOM)
Munters Corporation, Fort Myers, FL
Exxon Company, U.S.A., Baytown, TX
Amoco Oil Company, Texas City, TX
U. S. Environmental Protection Agency
Munter* Corporation, Fort Myers, FL
U. S. Environmental Protection Agency
Philip Morris U.S.A., Richmond, VA
U.S. Environmental Protection Agency
Chevron U.S.A., Inc., Pgscagoula, MS
Nature of action
Source test plan submitted
Visit to water chemicals vendors
Visit to cooling tower manufacturer
Recommendation memo on cooling tower modeling
Visit to petroleum refinery
Visit to petroleum refinery
Visit to petroleum refinery
Section 114 information request
Section 114 information request
Request for information about cooling water and corrosion inhibitor use
from member chemical manufacturing plants
HEM inputs submitted
Chromium chemicals concurrence meeting
Technical Report— Cooling Towers
Information memorandum submitted to ESD/OD
Visit to gaseous diffusion plant.
Emission test request to conduct method evaluation tests at Munters
Corp. was submitted
Requesting ABOM participation in cooling towers study
Visit to cooling tower manufacturer
Visit to petroleum refinery
Visit to petroleum refinery
Emission test request for Exxon-Baytown refinery
Visit to cooling tower manufacturer
Five specific sites identified as candidates for additional testing
Visit to tobacco company
Source test request for DOE gaseous diffusion plant, Paducah, KY
Visit to petroleum refinery
                            A-4

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TABLE A-l.   (continued)
Date
05/08/86
05/13/86
05/22/86
05/27/86
06/04/86
06/12/86
06/16/86
06/23/86-
06/27/86
06/26/86
08/18/86-
08/22/86
08/21/86
08/31/86-
09/05/86
09/15/86
11/26/86
12/12/86
12/19/86
12/19/86
02/13/87
03/10/87
04/07/87
04/21/87
04/23/87
04/30/87
04/30/87
05/11/87
05/26/87
06/25/87
06/29/87
07/01/87
07/09/87
07/13/87
07/13/87-
07/17/87
09/09/87
12/15/87
05/04/88
05/09/88
Company, consultant, or agency/location
NASA-Langley Research Center, Hampton, VA
U. S. Environmental Protection Agency
National Bureau of Standards (NBS),
Gaithersburg, MD
U.S. Environmental Protection Agency
Union Oil Co. Los Angeles,
Chevron U.S. A., San Francisco, CA
Shell Oil Co., Houston, TX
Pfizer, Inc., New York, NY; Inmont Corporation,
Clifton, NJ; Hooker Industrial and Specialty
Chemicals, Niagara Falls, NY
DOE, Paducah, KY
Interlake Inc., Oak Brook, JL
Kaiser Aluminum & Chemical Corp., Oakland, CA
LTV Corp., Cleveland, OH
NBS, Gaithersburg, MD
U. S. Environmental Protection Agency
Exxon-Baytown Refinery, Baytown, TX
U. S. Environmental Protection Agency
U. S. Environmental Protection Agency
U. S. Environmental Protection Agency
U. S. Environmental Protection Agency
U. S. Environmental Protection Agency
U.S. Environmental Protection Agency
U. S. Environmental Protection Agency
U. S. Environmental Protection Agency ,
U. S. Environmental Protection Agency
U. S. Environmental Protection Agency
Southern Manufacturing Facility (SMF)
U. S. Environmental Protection Agency
U. S. Environmental Protection Agency
U.S. Environmental Protection Agency
U. S. Environmental Protection Agency
U. S. Environmental Protection Agency
U. S. Environmental Protection Agency
U. S. Environmental Protection Agency
U. S. Environmental Protection Agency
SMF
U.S. Environmental Protection Agency
U. S. Environmental Protection Agency
U. S. Environmental Protection Agency
U. S. Environmental Protection Agency
Mature of action
Visit to research center
Start Action Request for Development of an Accelerated NESHAP—
Chromium Emissions from Cooling Towers
Visit to NBS facility
Source test request for NASA-Langley
Section 114 information request
Section 114 information request
Section 1 14 information request
Source test conducted
Section 1 14 information request
Source test conducted
Questionnaire to 18 water treatment chemical suppliers
Source test conducted
Responses to Section 114's received
Preliminary cost estimates for regulatory alternatives
Argonne modeling inputs submitted
Model plant memo revised
Cost memo revised
BID chapters 3 through 6 and 8 mailed out to industry
Draft test plan for additional tests submitted
Draft BID chapters 7.1 & 7.2 submitted
Section 114 information request to 139 companies
Draft BID Appendix C submitted
Visit to SMF
Additional test site selected
Test request for SMF submitted
Draft Working Group package submitted
Draft Regulatory Impacts Analysis (RIA) submitted
Risk Assessment inputs to HEM model
Final Working Group Package submitted
Final draft of RIA
Information package sent to Working Group Members
Source test conducted
Preliminary test data received from Entropy
Project schedule delayed to allow testing and laboratory studies to
investigate chromium speciation in cooling towers
Revised draft HEM risk assessment inputs for modeling annual
incidence and maximum individual risk submitted
Results from laboratory studies received
          A-5

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TABLE A-l.   (continued)
Date
05/27/88
OS/08/88-
08/11/88
07/18/89
08/23/89
10/02/89-
10/03/89
10/04/89
10/20/89-
10/21/89
10/22/89-
10/23/89
12/05/89
12/13/89
12/14/89
12/14/89
07/13/90-
07/19/90
01/14/91-
01/22/91
02/15/91
02/22/91
02/26/91
03/26/91
05/24/91
06/07/91
06/19/91-
08/22/91
08/28/91
09/20/91
10/01/91
Company, consultant, or agency/location
U. S. Environmental Protection Agency
SMF
University of North Carolina, Chapel Hill, NC
Allied-Signal, Inc., Moncure, NC
Chevron U.S.A., Inc., Richmond, California
TOSCO Corporation, Martinez, California
Chevron U.S.A., Inc., El Segundo, California
Shell Oil Company, Martinez, California
E. I. duPont de Nemours & Company, Inc.,
Wilmington, NC
E. I. duPont de Nemours & Company, Inc.,
Camden, SC
Amoco Chemical Company, Mount Pleasant, SC
Georgetown Steel Corporation, Georgetown, SC
National Institute of Standards and Technology,
Gaithersburg, MD
Allied Fibers, Moncure, NC
Chevron Chemical Company, San Ramon, CA
Monsanto Chemical Company, St. Louis, MO
Dow Chemical U.S.A., Midland, MI
E. I. du Pont de Nemours & Company, Inc.,
Beaumont, TX
Eastman Chemical Products, Inc., Kingsport, TN
Occidental Chemical Corp., Dallas, TX
PPG Industries, Inc., Pittsburgh, PA
Union Carbide Corp., Danbury, CT
Vulcan Materials Company, Birmingham, AL
Malco Chemical Company, Naperville, IL
Betz Industrial, Trevose, PA
[I. S. Environmental Protection Agency
Betz Industrial, Trevose, PA
Malco Chemical Company, Naperville, IL
Dearborn Chemical Company, Lake Zurich, IL
Calgon Corp., Pittsburgh, PA
Dexter Corp., Chagin Falls, OH
Chemtreat, Inc., Richmond, VA
Chemlinlc, Inc., Houston, TX
3uclcman Laboratories, Memphis, TN
Drew Industrial, Boonton, NJ
J. S. Environmental Protection Agency
J. S. Environmental Protection Agency
J. S. Environmental Protection Agency
J. S. Environmental Protection Agency
'J. S. Environmental Protection Agency
Nature of action
Revised draft of Chapters 3 through 8 and Appendices C, D, and F
submitted
Method development test
Visit to university physical plant
Visit to synthetic fiber manufacturer
Visit to petroleum refinery
Visit to petroleum refinery
Visit to petroleum refinery
Visit to petroleum refinery
Visit to chemical manufacturer
Visit to chemical manufacturer
Visit to chemical manufacturer
Visit to steel plant
Source test
Source test
Section 1 14 information request to nine companies
Visit to water treatment chemical supplier
Visit to water treatment chemical supplier
Technical memorandum: Status of California chromate ban
Questionnaire to nine water treatment chemical suppliers
Technical memorandum: Preliminary analysis of Section 114
information request responses
Revised drafts of BED Chapters 3 to 8, and Appendix C submitted
Technical memorandum: Analysis of drift rate data from NIST and
Allied tests
Technical memorandum: Data for economic impacts analysis
Draft BED summary report
          A-6

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TABLE A-l.   (continued)
Date
10/24/91
11/20/91
11/21/91
01/10/92
02/28/92
04/06/92
04/20/92
04/24/92
05/20/92
06/03/92
07/09/92
Company, consultant, or agency /location
I}. S. Environmental Protection Agency
National Air Pollution Control Techniques
Advisory Committee
U.S. Environmental Protection Agency
V. S. Environmental Protection Agency
U. S. Environmental Protection Agency
Work Group
U. S. Environmental Protection Agency
U.S. Environmental Protection Agency
Work Group
U. S. Environmental Protection Agency
Work Group
Nature of action
Docket transmitted to Air Docket Office
Meeting
BID Chapters 3 to 8 and Appendix C revised
Stan action request submitted
OAQPS decision meeting
Informational meeting
OAR decision meeting
BID Chapter 9 revised
Options selection meeting
BID Appendix D revised
Meeting on preamble and regulation
           A-7

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                APPENDIX B.




INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS

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                           APPENDIX B.
           INDEX TO ENVIRONMENTAL  IMPACT CONSIDERATIONS

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

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     TABLE "B"-l.  CROSS-INDEXED REFERENCE SYSTEM TO HIGHLIGHT
          ENVIRONMENTAL IMPACT PORTIONS OF THE DOCUMENT
Agency guidelines for preparing
regulatory action environmental
impact statements (39 FR 37419)
Location within the background
information document
1.  BACKGROUND AND SUMMARY OF
    REGULATORY ALTERNATIVES

    Summary of regulatory
    alternatives
    Statutory basis for
    proposing standards
    Relationship to other
    regulatory agency actions
    Industries affected by the
    regulatory alternatives
    Specific processes
    affected by the regulatory
    alternatives
The regulatory alternatives
from which standards will be
chosen for proposal are
summarized in Chapter 1,
Section 1.1; a detailed
description of the control
techniques is provided in
Chapter 4, Section 4'. 1.

The statutory basis for
proposing standards is
summarized in Chapter 2,
Section 2.1.

The relationships between EPA
and other regulatory agency
actions are discussed in •
Chapter 7.

A discussion of the industries
affected by the regulatory
alternatives is presented in
Chapter 3, Section 3.1 and
Chapter 5, Section 5.3.
Further details covering the
business and economic nature
of the industry are presented
in Chapter 9, Section 9.1.

The specific processes and
facilities affected by the
regulatory alternatives are
summarized in Chapter 5,
Sections 5.1 and 5.3.  A
detailed technical discussion
of the processes affected by
the regulatory alternatives is
presented in Chapter 3,
Section 3.3.
                               B-2

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                     TABLE B-l.  (continued)
Agency guidelines for preparing
regulatory action environmental
impact statements (39 FR 37419)
Location within the background
information document
2.  REGULATORY ALTERNATIVES
    Control techniques
    Regulatory alternatives
3.  ENVIRONMENTAL IMPACT OF
    THE REGULATORY
    ALTERNATIVES

    Primary impacts directly
    attributable to the
    regulatory alternatives
    Secondary or induced
    impacts
4.  OTHER CONSIDERATIONS
The alternative control
techniques are discussed in
Chapter 4.

The various regulatory
alternatives are defined in
Chapter 6.  A summary of the
major alternatives considered
is  included in Chapter 1,
Section 1.1.

The primary impacts on mass
emissions and ambient air
quality due to the alternative
control systems are discussed
in Chapter 7, Sections 7.1
through 7.4.  A matrix
summarizing the environmental
impacts is included in
Chapter 1.

Secondary impacts for the
various regulatory
alternatives are discussed in
Chapter 7, Sections 7.1
through 7.4.

A summary of the potential
adverse environmental impacts
associated with the regulatory
alternatives is included  in
Chapter 1, Section 1.2, and
Chapter 7.  Potential socio-
economic and inflationary
impacts are discussed in
Chapter 9, Section 9.2.
                                B-3

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    APPENDIX C.




SUMMARY OF TEST DATA

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                APPENDIX G.  SUMMARY OF TEST DATA

     This appendix presents the results of seven EPA-conducted
tests for hexavalent chromium (Cr+6) emissions from industrial
process cooling towers (IPCT's).  The test data were considered
in developing emission factors and in quantifying the performance
of high-efficiency drift eliminators (HEDE's) versus low-
efficiency drift eliminators (LEDE's) as described in Chapter 4.
The emission data include mass emissions and particle size
distributions.  For each test series, Section C.I presents
descriptions of the physical and operating parameters of the
cooling tower and of the water treatment program.  The test
results are tabulated in Section C.2.  Section C.3 presents an
evaluation of the proposed test method, based on the results of
the two most recent EPA-sponsored emission tests.
C.I  DESCRIPTION OF TESTS
C.I.I  Department of Energy. Gaseous Diffusion Plant. Paducah,
       Kentucky1
     C.I.1.1  Process Description.  The Department of Energy
facility at Paducah, Kentucky,  is operated by Martin Marietta
Energy Systems, Inc.  This facility enriches uranium in the U235
isotope using a gaseous diffusion (cascade) process.  The
diffusion process involves pressure-induced flow of the uranium
hexafluoride (UFg) process gas through microporous barriers.  The
heat of compression is removed from the process gas by
thermosyphon refrigerant systems to control the operating
temperature.  The refrigerant is vaporized in process gas coolers
and is transferred to water-cooled heat exchangers, where it is
condensed before it returns to the gas coolers.  Recirculating
cooling water is pumped from a basin to the process condensers
                               c-l

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 and returned to the cooling towers, where waste process heat is
 rejected to the atmosphere.  The UF6 is cooled indirectly for
 safety and reliability considerations.
      The process cooling tower system consists of two towers that
 are designated C-637-2A and C-637-2B.  A schematic of the
 C-637-2A and C-637-2B system is shown in Figure C-l.   The
 C-637-2A tower was selected for source testing; this  tower is a
 seven-cell Marley Cooling Tower Company (Marley)  crossflow design
 with two fans per riser cell and is equipped with both LEDE's
 (herringbone) and HEDE's (Thermatec Spectra).  Riser  cell Nos.  1
 through 5 are equipped with LEDE's and redwood splash fill.  The
 HEDE riser cell Nos.  6 and 7 contain polyvinyl chloride (PVC)
 splash fill.
      The tower was originally constructed in the early 1950's
 with redwood splash fill and herringbone drift eliminators in all
 the riser cells.  Riser cell Nos. 6 and 7 were recently modified
, by the installation of the PVC splash fill and Thermatec Spectra
 drift eliminators.  The water systems of towers C-637-2A and
 C-637-2B are served by a common pumphouse that has a  total
 nominal capacity of 605,670 liters per minute (f/min)
 (160,000 gallons per minute [gal/min]):  six pumps are rated for
 75,709 f/min (20,000 gal/min)  each and four pumps are rated for
 37,854 f/min (10,000 gal/min)  ea'ch.  Each of the tower systems  is
 constructed with a water basin having a capacity of 15.9 million
 liters (4.2 million gallons).   Makeup water from the  Ohio River
 is softened and clarified and then supplied through a
 76.2-centimeter (cm)  (30-inch [in.])  pipeline to the  pumphouse.
      Two 152.4-cm (60-in.)  cooling water supply and return loops
 ("G" and "H" on Figure C-l) are used to recirculate the tower
 water through the process building.  The return lines of each
 loop are connected by a "crossover" pipeline that allows water  to
 be directed to either the C-637-2A or 2B tower for cooling.
 Another "crossover" pipeline interconnects the process cooling
 water supply lines.  The recirculating water enters the tower
 after the flow is split into seven branches (riser pipes)  that
 serve each of the seven riser cells.   The flow from each of the
                                C-2

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riser pipes is split and conveyed into the water distribution
decks of each of the two fan cells.
     The water distribution decks are located directly above the
splash fill sections of the fan cells and equipped with gravity
flow nozzles for even distribution of the recirculating water in
a cascade over the fill material.  Propeller fans measuring
6.7 meters (m) (22 feet [ft]) in diameter that are located in the
stack of each cell provide 17,273 cubic meters per min (m3/min)
(610,000 cubic feet per min [ft3/min]) of induced horizontal
airflow through the fill sections.
     Sodium bichromate with a target concentration of 18 to
20 parts per million (ppm) is added to the recirculating cooling
water to inhibit corrosion in the heat exchangers.  Chromate
additions are made manually, and the chromate levels are measured
daily.  A chlorine residual of 0.5 ppm is the target
concentration for controlling biological organisms in the
recirculating water.  Chlorine is continuously injected into the
system at a constant flow rate.  The pH of the water is monitored
continuously by a pH probe and meter.  Additions of sulfuric acid
are made manually to maintain the 6.0 to 6.1 target pH range.
The calcium hardness is maintained at concentrations between 350
and 500 ppm in the recirculating" water by controlling the
blowdown rate.
     C.I.1.2  Operating Conditions During Testing.  The C-637-2A
cooling tower operating parameters that were monitored throughout
the test period were the fan motor amperage, pump outlet
pressures, total water flow, basin water temperature, return
water temperature, chlorine addition rate, makeup water flow
rate, pH, wet well temperature,  and blowdown rate.
Meteorological data were obtained from the National Weather
Service  (NWS) at the Paducah Airport for each day that tests were
performed and included hourly observations of dry bulb
temperature, dew point, wind speed, and wind direction.
Table C-l is a summary of the cooling tower operating parameters
and meteorological data recorded and obtained during the test
period.
                               C-3

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     The cooling tower was not operating at the recirculating
water design capacity during the tests due to low process cooling
demands.  It was necessary to increase the water flow rates of
the riser cells being tested to between 90 and 100 percent of
design capacity  (30,564 to 33,959 £/min [8,074 to 8,971 gal/min],
respectively) by directing some of the recirculating water in the
riser cells not being tested to the riser cells that were being
tested.  This was accomplished by partially closing the isolation
valve for the riser cells not being tested.  Additionally, the
distribution of the riser cell water to each of the fan cells was
balanced by adjusting the individual flow control valves on each
fan cell until the depth of water appeared to be equal in the
distribution decks.  The blowdown rate was maintained at zero
throughout the test period to minimize the loss of sodium bromide
that was added to the recirculating water as a tracer chemical.
     On the day prior to the first test series, the recirculating
water flow rates on riser cell Nos. 4 and 7 were adjusted while
the water flow rates were measured.  Water flow rates were
established at 32,176 ^/min (8,500 gal/min) and 32,555 l/min
(8,600 gal/min) for riser cell Nos. 4 and 7, respectively.  A
water flow measurement on riser pipe No. 7 concurrent with the
first test series indicated that the flow was at 85 percent of
capacity, or 28,390 f/min (7,500 gal/min).  The reason for this
variation is not known, but there may have been a leak in the
pitot tube during the pretest flow rate measurement.  Inspection
of the drift eliminator in fan cell No. 13 indicated the presence
of a significant water leak from the distribution deck into the
tower on the fan side of the drift eliminator section.  The first
test on riser cell No. 7 was invalidated because the water flow
rate was less than 90 percent of the design flow rate and because
of the water leak into the tower on the fan side of the drift
eliminator.  The tests on riser cell No. 7 were successfully
repeated after the pitot tube was repaired and a broken redwood
plank in the side of the water distribution deck was replaced.
The remaining tests on riser cell Nos. 4,  5, and 6 were completed
                               C-4

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 under  acceptable conditions with respect  to  the  test  plan  and
 Cooling  Tower  Institute  (CTI)  guidelines.
 C.I.2  National  Institute  of  Standards  and Technology.
       Gaithersbura. Maryland2
     c-1.2.1   Process  Description.  The National Institute of
 Standards and  Technology (NIST),  formerly the National Bureau of
 Standards,  is  a  Federal  Government research  facility  near
 Gaithersburg,  Maryland.  On the grounds are  seven laboratory/
 office buildings with  a  total  floor area  of  58,066 square  meters
 (m2) (625,000  square feet  [ft2])  and a  number of support
 buildings with a floor area of 62,711 m2  (675,000 ft2).  Comfort
 cooling  and cooling for  laboratory processes (lasers, ovens,
 etc.)  are both provided  by a four-cell  Marley tower located near
 the western boundary of  the facility.   The tower was  installed in
 the early 1960's.
     A schematic of the  cooling tower system is  provided in
 Figure C-2.  The tower is  a crossflow design with redwood  splash
 fill and one fan per cell.  Propeller fans measuring  6.7 m
 (22 ft)  in  diameter are  located in the  stack of  each  cell.  In
 1985,  the tower  was retrofitted with high-effici-ency  Hunters D-15
 drift  eliminators.
     The capacity of the water basin is about 1.893 x 106  (
 (500,000 gal).   Four pumps each rated for 33,312  £/min
 (8,800 gal/min)  circulate  the  water to  the chillers.  The  water
 from the chillers is combined  and returned to the tower through a
 106.7-cm (42-in.) riser pipe.   Above the tower,  the flow is split
 into four branches and distributed to each of the cells.   The
water distribution decks are located directly above the fill and
are equipped with gravity  flow nozzles.  In  winter, heated water
 is sprayed up  into the rear of  the tower to  prevent icing.
     A solution  of molybdate and polyacrylate is  used to inhibit
corrosion in the heat  exchangers.  The target concentration of
molybdate in the recirculating water is about 15  ppm.
Conductivity and pH are monitored continuously,  and blowdown
occurs automatically when the  conductivity reaches
1,800 micromhos  (/imhos) .   Blowdown averages  about  227,126  liters
                                C-5

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per day  (//d)  (60,000 gallons per day  [gal/d]) in summer and
about 7,571  f/d  (2,000 gal/d) in winter.
     Makeup  water  is provided by the City of Gaithersburg.  The
conductivity is  generally about 300 /xmhos, but after heavy rains
and after salt has been applied to the roads in the winter, the
conductivity increases.  Makeup requirements average about
1.136 x  106  t/d  (300,000 gal/d) in summer and about 208,200 f/d
(55,000  gal/d) in  winter.  Most of the water has first been used
for once-through cooling of oil and air compressors.
     Biological  growth is controlled by manually adding 24.6 I
(6.5 gal) of a solution containing disodium cyanodithiocarbamate
(7.35 percent) and potassium methyldithiocarbamate
(10.15 percent)  once a week.
     C.I.2.2  Operating Conditions During Testing.  Eight test
series were  conducted.  The cooling tower operating parameters
that were monitored during each test series included the
recirculating water temperatures into and out of the chiller,
recirculating water flow rate, daily blowdown and water makeup,
wind speed,  and  wind direction.  Meteorological data were also
obtained from th,e  NWS at Washington National Airport.
     The design  water flow was achieved on each of the test days,
but one chiller  was not operated; water simply circulated through
it.  The low  ambient temperature and low demand during Test
Series 5, 6,  and 7 necessitated turning off a second chiller and
one fan.  Table  C-2 is a summary of the cooling tower operating
parameters and meteorological data recorded during the test
period.
     It was determined from the estimated system, volume that
adding about  90.7 kilograms (kg) (200 Ib) of crystalline sodium
dichromate would result in a Cr+6 concentration of slightly over
15 ppm in the recirculating water.  This amount of sodium
dichromate was added on the day before the first test, and lesser
amounts were  added on following days to replenish the estimated
losses via blowdown and drift.  To determine the actual Cr+6
concentration, water samples were taken during each test series
and later analyzed for Cr+6.  Sodium bromide also was added to
                               c-6

-------
the recirculating water to evaluate bromide as a surrogate for
chromium in drift emissions testing.
     A pretest walk-through of the tower was conducted on
Tuesday, August 19, 1986.  Inspection of the drift eliminators
revealed a number of water leaks into the fan side of the
eliminator sections.  This was most significant in the first
cell, but in no case did the airflow appear to be shearing
droplets away from the water stream.  Inspection of the water
flow along the outside of the tower revealed an unequal
distribution that was most pronounced on the windiest days.  The
strongest winds were evident on Wednesday, August 20, when the
anemometer mounted atop a nearby building indicated gusts of up
to 22.5 kilometers per hour (km/h)  (14 miles per hour [mph]).  On
the tower itself, an anemometer indicated 22.5 km/h  (14 mph), and
the NWS reported winds of 16.1 to 24.1 km/h (10 to 15 mph) for
that day.  In no instance, however, was drift observed from the
sides of the tower.  All tests were completed under acceptable
conditions with respect to the test plan and CTI guidelines.
C.I.3  Exxon Refinery. Ethylene Production,Baytown, Texas3
     C.I.3.1  Process Description.  Tower No. 68 provides cooling
for the catalytic light-end units, which recover ethylene and
other light-end products.  The tower handles a constant heat load
24 hours per day.  Figure C-3 is a schematic of tower No. 68.
This tower consists of four counterflow cells and one Marley
crossflow cell.  Each cell has one single-speed fan and redwood
herringbone drift eliminators.  The counterflow section has
redwood splash fill and is served by two risers that distribute
the water over the fill through a manifold and pressure spray
nozzles.  The crossflow section has plastic splash fill and is
served by one riser that supplies a water distribution deck
equipped with gravity flow nozzles.  Two pumps circulate water
from the northern end of the common basin to the process heat
exchangers, and a third pump is on standby.  Slowdown is
withdrawn from the system before the water is returned to the
tower.  Makeup water from the San Jacinto River is supplied
through a 10.2-cm (4-in.) pipeline to the basin.  The fans are
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 5.5 m  (18 ft) in diameter in the counterflow cells and 7.3 m
 (24 ft) in diameter in the crossflow cell.
      The corrosion inhibitor is a chromate/zinc formulation that
 is supplied by Betz Industrial (Betz).  The target concentration
 of chromate in the recirculating water is 10 to 15 ppm.  The
 solution is added automatically at a rate that is set manually.
 Dispersant is added in the same manner.  A free chlorine residual
 of 0.2 to 0.5 ppm is the target for control of microbiological
 growth.  Chlorine gas is injected into a side stream of the
 makeup water and added to,.the southern end of the basin.  The pH
 of the water is monitored continuously, but it is not used as an
 automatic controller.  When pH exceeds the critical control range
 of 6.0 to 9.0, it must be corrected by manually adding acid or
 caustic soda.  Slowdown is dictated by the conductivity, which
 should not exceed 1,500 /imhos.
      C.I.3.2  Operating Conditions During Testing.  The operating
• parameters that were monitored throughout the test period include
 fan motor amperage, pump outlet pressure, hot water line
 pressure,  water flow in each riser,  temperature in each riser,
 basin water temperature,  pH,  conductivity, wind speed and
 direction,  wet bulb temperature,  and dry bulb temperature.   In
 addition,  the makeup water flow rate was measured and the
 blowdown was estimated concurrently with the fourth test series.
 Table C-3  is a summary of the cooling tower operating parameters
 and meteorological data recorded during the test period.
      On the day prior to the first test,  the recirculating water
 flow rates  were measured.   The flow in the crossflow cell was
 about 20 percent greater than the flow in each of the counterflow
 cells.   However,  because the pump outlet pressures and fan
 amperages were constant and within design specifications, no
 changes were made to the  air or water flow rates for the test.
      The drift eliminator on one  side of the crossflow cell was
 determined  to be in good  condition based on visual inspection.
 The drift eliminators  in  the counterflow cells could not be
 inspected.   However,  it appeared  that a similar quantity of drift
 was being emitted from each stack,  although the amount may  have
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 been slightly less from cell  No.  l.   The  quantity  of  steam  rising
 from cell  No.  1  also appeared to  be  slightly  less  than  that from
 the  other  cells.   Some of  the nozzles in  the  distribution deck on
 cell No. 5 were  plugged, and  a few of the redwood  slats in  the
 lower sections of  the counterflow cells were  broken,  but the
 overall condition  of the tower was reasonably good.
      Water meters  are not  installed  on the makeup  and total
 blowdown lines so  alternative methods were attempted  to estimate
 these flows.   During the fourth test series,  a meter  was
 connected  to  the pressure  taps on an existing orifice plate in
 the  makeup line.   This indicated  an  average flow of about
 1,060 £/min  (280 gal/min)  over the 6 hours of monitoring (greater
 in the afternoon than in the  morning)  but did not  include the
 56.8 to 75.1  f/min  (15 to  20  gal/min)  diverted for chlorine
 injection  or  the amount leaking through a valve into  the system
 from a nearby  tower  (No. 58),  which  is treated with a phosphate
 inhibitor  from Calgon Corporation (Calgon).   The Betz
 representative used  the phosphate concentration in the
 recirculating  water  of tower  No.  68  to calculate a gain of  about
 94.6  f/min  (25 gal/min).   Later work by Exxon confirmed that this
 estimate was correct.
      To estimate the tower No.  68  blowdown, the flow  was diverted
 to a  208-t  (55-gal)  drum.  The amount  of  time required  to fill
 the  drum a couple of times was recorded.  This estimated flow
 rate  was within 20 percent of  the  estimate calculated by the Betz
 representative based on cycles of  concentration and an  estimate
 of evaporation.
      Water temperatures also  are  not monitored by on-line
 equipment.  Therefore,  fittings were attached to taps on the
 three risers and the hot water  return  line itself.   Mercury-in-
 glass thermometers were used to record the temperature.   The
 basin temperature .was determined about 5  ft from the  basin wall
 below cell Nos. 1,  2, and  5.  A mercury-in-glass thermometer was
placed in a perforated  can that was attached to a length of
conduit.   With this method, it was not possible to determine the
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actual temperature drop in each cell, but the average basin
temperature in all three locations was the same.
     Two sources of meteorological data were available:  one
station set up at the tower and one maintained by Exxon refinery
personnel less than a mile from the tower.  Both stations
indicated that the wind direction was from the southeast, and
very few directional changes deviated more than 45 degrees from
the southeast.  Both average and peak wind speeds, however, were
considerably higher at the tower station.  The differences may
have been the result of instrument calibration differences, or
they may have been caused by a slight tunneling effect created at
the tower station where the wind had to pass between the cooling
tower and a cryogenic process column (and other shorter
equipment) 27.4 to 36.6 m (30 to 40 yards) downwind of the
station.  Gusts rarely exceeded 24.1 km/h (15 mph), and drift was
never visible from the sides of the crossflow tower.  The ambient
temperature also varied between the stations.  The actual
temperature is probably that obtained at the tower site since the
several thermometers that were used recorded the same levels.
     Three days prior to the first test, the Exxon process
personnel responsible for the tower disconnected the chlorine
injection line to preclude any possible adverse health effects "on
test personnel.  Chlorine will also react with most hydrocarbons.
Thus, a decrease in the free chlorine residual concentration
(normally determined once per shift) is the best indicator of a
process fluid leak into the water.  Alternatively, gas traps on
the hot water return line, visual inspection of the surface of
the water in the basin and the distribution deck of cell No. 5,
and the chromate concentration were used to confirm that the
process heat exchangers were not leaking.  The chromate
concentration, as determined by the.operators each shift, was
essentially constant and within the desired control range during
the testing period.  The Betz analysis on Tuesday agreed with
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that of the operators.  The pH and conductivity were also within
control ranges.                                   .
C.1.4  Exxon Refinery. Lube Oil Production. Baytown. Texas3
     C.I.4.1  Process Description.  Cooling for the vacuum
distillation unit for lube oil is provided by tower No. 84.
Although the tower is operating at less than design capacity, it
handles a constant heat load 24 hours per day.  Figure C-4 is a
schematic of tower No. 84.  The tower is a Marley counterflow
design with four riser cells and four fan cells.  Each fan cell
has one 6.7-m (22-ft)-diameter constant-speed fan.  The average
measured airflow per fan ranged from 222 to 287 dry standard
cubic meters per minute (dsm3/min) (470,000 to 609,000 dry
standard cubic feet per minute [dscfm]).  Each cell is equipped
with PVC film fill and a high-efficiency Marley XCEL-15 drift
eliminator.  Water is distributed over the fill through a
manifold and spray nozzles.  Two pumps circulate the water from
the basin extension at the south end of the tower through the
process heat exchangers.  A recent potassium retention time study
determined that the system volume was about 2.082 x 106 t
(550,000 gal) of .water.
     Slowdown is designed to be controlled by the conductivity of
the recirculating water.  At certain set points, a valve is
actuated in a line off the main hot water return.  Most of the
makeup water is supplied through a 15.2-centimeter  (6-inch) pipe
to the basin extension, but part of it is diverted continuously
into five smaller lines.  The inhibitor, dispersant, chlorine,
sulfuric acid, and caustic soda are injected into the smaller
lines automatically.
     The corrosion inhibitor is a 7:1 chromate/zinc formulation
that is supplied by Nalco Chemical Company (Nalco).  The target
chromate concentration in the recirculating water is 8 to 12 ppm.
The solution is injected into one of the small makeup lines for a
specific fraction of every 10-minute interval.  The on/off time
fraction can be changed by entering new values into the computer
memory.  The dispersant is injected into another makeup line in
an identical manner.  Acid and caustic are injected based on pH
                               C-ll

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 set points within the control range of 6.8  to 7.5.   Chlorine  gas
 is injected continuously at a rate controlled by a  free  chlorine
 residual monitor that is generally set to keep the  concentration
 in the range of 0.3  to 0.5 ppm.   The conductivity of the makeup
 water is about 150 /mhos,  and the control range for the  number of
 cycles is 6 to 8.
      C.I.4.2  Operating Conditions During Testing.   The  operating
 parameters monitored throughout  the test  period were fan motor
 amperage,  pump outlet pressures,  cold water line pressure, water
 flow in each riser,  temperature  in three  of the risers,  basin
 temperature,  temperature in pump inlet lines,  pH, conductivity,
 wind speed and direction,  and dry bulb temperature.   The
 computerized system  that monitors inlet and outlet  temperatures
 and the makeup,  blowdown,  and recirculating water flow rates  was
 not calibrated correctly at the  start of  the test.   With the
 exception  of the blowdown,  attempts at calibration  were  not
 successful.   These problems are  not considered to affect the
 amount  of  drift, and only  the makeup and  blowdown could  not be
 monitored  directly by the  test personnel.   Table C-4  is  a summary
 of  the  cooling tower operating parameters and  meteorological  data
 recorded during the  test period.
     On  the  day prior to the  first  test series,  the water flow
 rates in each riser  were measured.   The flows  in Risers  A and B
 were about 15  percent less  than the flows in Risers  C and D.  The
 total flow was  25  percent greater than  the  tower design  and
 20 percent greater than  the pump ratings.   From  the pump head
 pressure and  the manufacturer's pump  curves, it  was calculated
 that the flow should be  about  77,980  f/min  (20,600 gal/min).  The
measured rate was  about  10  percent  greater  than  this calculated
rate.  As  scale and  fouling increase, and with additional process
heat loads, the head pressure will  increase slightly and cause a
decrease in the flow rate.  The conditions  as measured (and with
all the  fans running) represented normal operation.   Therefore,
no attempt was made to equalize the flow  in the risers or to
reduce the overall flow to the design rate.
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     The drift eliminators could be inspected through a porthole
in the fan stack below the fan.  The drift eliminator in Cell A
is assumed to have at least one defect because entrained droplets
were observed periodically in the same area of the stack.  The
other drift eliminators appeared to be in good condition.  The
water distribution through the fill was even, although it did
cascade along some vertical beams at a greater rate than along
others.
     The quantity of blowdown was not easily determined because
the conductivity control was not working and the valves in the
line were closed.  Also, recirculating water can be withdrawn
from the system in the process area for general ground-cleaning
purposes.  The operators, however, indicated that they had not
been using any of this water on the test days.  Finally, a water
balance on the process side of the overhead vacuum condensers
indicated an excess of about 189 (/min (50 gal/min).  This is
approximately the amount that the Nalco representative calculated
for the blowdown based on the cycles of concentration and an
estimate of the evaporation loss.
     The recirculating water temperature was measured with
mercury-in-glass thermometers in fittings attached to taps in
three of the risers.  The basin temperature was determined with a
mercury-in-glass thermometer at the intersection of the main
basin and the basin extension.  The temperatures indicated by
gauges on the lines to the pumps were also recorded; they were
consistently 2 degrees lower than the thermometer reading.
   .  Meteorological data were available both at the tower site
and from the Exxon meteorological station almost a mile away.
The wind direction continued to be steady from the southeast, and
the wind speeds were higher on the chart recorder at the tower
station.  At this site, there were no obstructions around the
station except for the tower itself.
     The operator log indicated that the chromate concentration
in the recirculating water was constant at the upper limit of the
control range over the 2-day test period.  The concentration
agreed with that obtained by. the Nalco representative on
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August 29.  The pH, conductivity, and free chlorine residual were
also within the control ranges.
C.I.5  A Southeastern Manufacturing Facility^
     C.I.5.1  Process Description.  This plant has indicated that
the type of cooling water treatment program is confidential
business information and would place the company at a competitive
disadvantage if known by other manufacturers of its product.  The
EPA and the company have agreed that rather than maintaining the
type of cooling water treatment as confidential information
pending a formal determination, the Agency would treat the
company name, plant location, type of manufacturing process, and
the names of plant personnel as confidential.
     Cooling Tower No. 22-900 was constructed in 1979 and serves
the heating, ventilation, and air conditioning (HVAC) system for
the plant.  It is a Marley Class 500 tower (Model 575-68-02).
The two-cell, crossflow, induced-draft tower has molded
polypropylene, ladder-type splash fill and high-efficiency Marley
XCEL-10 drift eliminators.  The tower is about 12.5 meters  (m)
(41 feet [ft]) wide, 17 m (56 ft) long, and 6.7 m (22 ft) high to
the top of the distribution deck  (9.8 m [32 ft] high to the top
of the stacks).  The tower is designed to cool 28,390 f/min
(7,500 gal/min) of water from 38°C to 29°C (100°F to 85°F) when
the wet bulb temperature is 26°C  (78°F).  Single-speed fans in
both cells are operated by 44.7-kilowatt (kW) (60-horsepower
[hp]) motors and produce a design airflow of 13,390 actual cubic
meters per minute  (m3/min) (472,700 actual cubic feet per minute
[acfm]) each.  .Typically, the fans shut off automatically when
the outside temperature is less than 17°C (62°F); however, the
fans can also be operated manually.  The design evaporation rate
is 428 t/min  (113 gal/min), and the chromate concentration in the
recirculating water is maintained at 450 to 600 ppm.  Chromate
generally is not added to the recirculating water of this tower;
however, the chromate concentration is maintained by adding
blowdown containing chromate from the adjacent process tower.
Ladders at each end provide access to the top of the tower, and
                               C-14

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electrical power is available at the site.  Figure C-5 is a
schematic of the HVAC tower (tower No. 22-900).
     Cooling Tower No. 22-901 was constructed in 1979 and serves
process equipment such as the vacuum pumps, compressors, various
heat exchangers, and other process equipment.  The two-cell, .
crossflow, induced-draft tower, which also is a Marley Class 500
tower (Model 597-94-02), has molded polypropylene, ladder-type
splash fill (identical to that in Cooling Tower No. 22-900) and
slat-type LEDE's.  The drift eliminators consist of two layers of
redwood slats.  The slats in both layers run 45° from horizontal
in opposite directions such that they are perpendicular to each
other.  Because the slats are inclined, they return collected
water to the basin more efficiently than typical horizontal
slats.  The tower is about 17.4 m (57 ft) wide,  20.7 »  (68 ft)
long, and 8.5m  (28 ft) high to the top of the distribution deck
(11.6 m [38 ft] high to the top of the stacks).   The tower is
designed to cool 19,990 f/min  (5,281 gal/min) of water from 39°C
to 28°C (102.8°F to 82°F) when the wet bulb temperature is 26°C
(78°F).  Two-speed fans in both cells are operated by 55.9-kW
(75-hp) motors and produce a maximum design airflow of
19,660 m3/min  (694,300 acfm) each.  The design evaporation rate
is 613 £/min  (162 gal/min), the chromate concentration  in the
recirculating water is maintained by the plant at 250 to 300 ppm,
and blowdown is used as part of the makeup for tower No. 22-900.
The tower operates 24 hours per day, ladders at each end provide
access to the top of the tower, and electrical power is available
at the site.  Figure C-6 is a schematic of the process tower
(tower No. 22-901).
     The power house supervisor was not sure what the cycles  of
concentration were for the HVAC tower but indicated that the
process tower operated at approximately 12 cycles of
concentration.  The recirculating water treatment program depends
upon chromate as the only corrosion inhibitor.  Because zinc
and/or other synergistic inhibitors are not contained in the
treatment program, substantially higher levels of chromate  are
necessary than when a blended treatment is used.  Corrosion
                               C-15

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protection  is provided  for heat exchanger surfaces, compressors,
and pumps.  Carbon  steel  (No. 4140) is used as the material of
construction for  some heat exchanger surfaces.  Organic biocides
and an iron dispersant  also are added to the recirculating water.
Currently,  an aqueous solution of chromate is added manually once
a week to the recirculating water to maintain the target
concentrations  (250 to  300 ppm"for the process tower and 450 to
600 ppm for the HVAC tower).  The calcium hardness of the makeup
water is 22 ppm,  and a  continuous blowdown of 18.9 to 22.7 f/min
(5 to 6 gal/min)  is used  to control the cycles of concentration.
     The majority of the  makeup water is steam condensate added
as a result of the manufacturing process.  Adding the remaining
makeup water, which can be either softened water or city water,
is controlled manually.   The blowdown from the process tower is
used as makeup for the  HVAC tower.  The HVAC blowdown is
collected along with other wastewater in an above-ground holding
tank.  A precipitation-type wastewater treatment process is used
to remove heavy metals  before the water is discharged to the
local publicly owned treatment works (POTW).
     C.I.5.2  Operating Conditions During Testing.  Eight test
series were conducted Monday through Friday, July 13-17, 1987.
Operating parameters for  both cooling towers were monitored
simultaneously during testing to ensure that representative
conditions  existed.  The  parameters monitored included the
operation of the  pumps  and fans on each tower, the inlet water
temperatures at the distribution decks, the cold water basin
temperatures, distribution deck water levels, and the
characteristics of the  tower interior during testing (leak
checks).  Table C-5 is  a  summary of the cooling tower operating
parameters  and'meteorological data recorded during the test
period.
     During pretest measurements, the HVAC tower water flow rate
was determined to be 40,000 £/min (10,600 gal/min), which is
approximately 7,600 f/min (2,000 gal/min) over the design flow
rate.  On Monday, the inside of the cooling tower was inspected
under this  flow condition.  Cooling water was overflowing the
                              c-16

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 distribution deck onto the fan deck,  falling through the spaces
 between the fan deck planking into the interior of  the cooling
 tower (thus bypassing the drift eliminators),  and causing "rain"
 inside the tower.  Many of these drops were being drawn up
 through the fan stack, creating an artificially high drift rate.
 This is improper cooling tower operation,  and,  thus,  testing
 could not take place until the flow rate was adjusted to the
 design flow.
      Plant personnel adjusted the flow rate on the  HVAC tower by
 bypassing some of the flow from the distribution deck to the cold
 water well.  In addition,  cracks between plywood decking over the
 distribution box were caulked to prevent overflow onto the fan
 deck.   Both water diversion and caulking were continued until
 maximum water flow to the distribution deck was obtained without
 causing "rain" inside the tower.   The flow rate was measured to
 be at the design flow rate under these conditions,  and testing
.was then possible for this tower.
      The process cooling tower was running at full  pump capacity,
 but the distribution decks of both cells had a water level of
 only 1.9 to 3.8 cm (0.75 to 1.5 in.)  out of a possible 15.2 cm
 (6 in.).  Plant personnel said that this was the normal operating
 condition for this tower.   It was further  discovered that the
 cooling water loop for this tower had a 61,300 t  (16,200 gal)
 holding tank for a portion of the process  water.  All of the
 cooling water that leaves one particular process enters this
 tank.   It is served by four pumps,  rated at 2,400 f/min
 (630 gal/min)  each,  that return the water  to the cooling tower.
 The pumps are level-activated such that at a low tank level no
 pumps operate.  As the level rises, successive pumps turn on so
 that the tank does not overflow.   During testing, two pumps were
 normally operating.   Under this condition,  the holding tank water
 level usually fluctuated less than 30.5 cm per hour (1 foot per
 hour)  depending upon how much cooling water was needed for the
 process.  Occasionally,  one pump or three  pumps were in service,
 but at no time during the test were all four pumps  seen on or off
 simultaneously.  Therefore,  the flowrate fluctuations during
                               C-17

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tests were of little consequence when compared to the total flow
of the cooling tower.  However, the tank level was measured, and
water samples of this hot well were taken whenever mass balance
samples were taken from the cooling towers to account for the
level change in the mass balance tests.
     After correcting these minor problems, the first test began
on the afternoon of Monday, July 13, 1987.  On Tuesday morning, a
review of the process tower airflow and water flow rate results
from Monday's test showed the tower to have a liquid-to-gas (L/G)
ratio of 0.5 to 0.6.  This is much lower than is typical for most
towers.  Plant personnel agreed to divert the flow from both
cells into one cell to double the L/G ratio.  The L/G ratio for
the HVAC tower was determined to be approximately 1.8 (near the
typical maximum for cooling tower design).  However, the flow
rate to the distribution deck in this tower could not be reduced
significantly because nearly the entire cooling capacity of the
tower was required for proper chiller operation.  Discussions
with J. D. Holmberg of Marley indicated that tests at Marley
using the isokinetic heated bead sampler followed by filters have
shown that the L/G ratio should have little or no effect on the
drift rate unless the flow was so low that some of the
distribution deck was not receiving any water (which was not the
case).  However, diverting the flow to one cell would allow
testing on a more representative tower because most process
towers operate at an L/G ratio between 1.0 and 2.O.1  Runs 1 and
2 were completed with flow in both cells.  Run 3 on the process
tower on Tuesday afternoon was performed with flow diverted into
Cell C.  Runs 4 and 5 on Wednesday were performed with flow in
both cells while results were analyzed on Run 3.  Runs 6 and 7 on
Thursday and Run 8 on Friday were performed with flows in one
cell.  Thus, four runs were completed under each L/G ratio
condition.
 Taken from a July 14, 1987, telephone conversation with
 J. D. Holmberg of Marley.
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     On Friday, July 17, the Power House Supervisor provided
information on the replacement and operation of process heat
exchangers during the test week that indicated a steady heat load
was present and few new heat exchanger surfaces came in contact
with the cooling water.
     Additional observations concerning the tests at the

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     A pretest walk-through was conducted prior to the start of
the first run.  Some leakage from the hot water basins was
observed bypassing the drift eliminators, but the rate of leakage
was considered to be negligible.  Because the hot water basins
were covered, it was not possible to check water levels during
the test.  However, there was no reason to suspect unequal
distribution of water among the four cells of the tower.
     The first run was begun with all four condensers operating.
However, near the end of the run, the flow to condenser No. i was
shut off.  During the remaining four runs, only condenser Nos. 2,
3, and 4 were operated.  During the last two days of the test,
the sample lines in the trains used on Cell 2 were changed from
Teflon™ to PVC.  No other changes in the trains were made during
the test, and all test runs were completed under acceptable
conditions with respect to CTI guidelines.
C.1.7  Allied Fibers. Moncure. North Carolina6
     C.I.7.1  Process Description.  Allied Fibers manufactures
high-strength polyester fiber that is used in tire cord, belts
and hoses, ropes, seat belts, and other products.   Terephthalic
acid and ethylene glycol are mixed with a catalyst and other
materials to form a paste, which then undergoes a three-stage
process to produce polyester yarn strands or filaments.
     Two identical towers, TW-2 and TW-3, are associated with the
polymer process.  Both are two-cell, induced draft, crossflow
towers with splash fill.  TW-2 was constructed in 1973, and TW-3
was constructed in 1975.  Both towers were rebuilt in 1988.  At
that time, Marley XCEL-15 drift eliminators were installed on
both towers.  The towers share a common sump and have a combined
recirculation rate of 12,870 to 13,248 f/min (3,400 to
3,500 gal/min).  There is one fan per cell, and the .design
airflow capacity is 5,239 actual cubic meters per minute (acmm)
(185,000 actual cubic feet per minute [acfm]).  The design
cooling water temperature range is from 40° to 34°C (104° to
93°F) in the summer and 21° to 13°C (70° to 56°F) in the winter.
A schematic of tower TW-3 is shown in Figure C-7.
                               C-20

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     Water treatment chemicals are supplied by Nalco,  and no
corrosion inhibitor is used.  The water treatment program
includes two biocides, a dispersant,  an antifoam agent,  and pH
control additives.  The recirculating water has a total  solids
content of 0.86 percent, and the pH is maintained between 6.0 and
7.0.  Because TW-2 and TW-3 serve a direct contact spray heat
exchanger, the recirculating water also contains approximately
9.5 percent ethylene glycol.
     C.I.7.2  Operating Conditions During Testing.  Testing was
originally planned for both TW-2 and TW-3.  However, because of
leakage from the hot water basins and fan deck into the plenum of
TW-2, only TW-3 was tested.
     Because of the high solids and ethylene glycol content of
the recirculating water, the interior structural members of the
tower were coated with material.  Some of this material was loose
and had the potential to be carried out the fan stack.  In
addition, in the mornings, heavy condensation formed in the tower
plenum.  It is also possible that some of the encrusted material
on the internal members of the tower was dissolved and carried
out the fan stack with the condensate.              ,
     Foam presented another problem during the initial stages of
testing.  The recirculating water discharging into the hot water
basins formed a thick foam, which occasionally overflowed the
basins or was blown onto the fan deck, where it reverted to a
liquid.  The fan deck included several drain holes to prevent
accumulation of the liquid.  This was also a concern during the
testing because of the  liklihood that the draining  liquid could
be carried out the fan  stacks by the air flow.  To prevent this
from occurring, the drain holes were plugged during the test
runs, and additional antifoaming agent was batch  added to the
basins when needed.
     During the test, the recirculation rate for  the combined
flow to TW-2 and TW-3 and the inlet and outlet temperatures were
monitored.  Meteorological  data recorded  included dry bulb
temperature, relative humidity, barometric pressure, and wind
speed and direction.  These data are summarized  in  Table C-8.
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      The drift tests were conducted on both cells of TW-3 using
 two pairs of sampling trains—one pair per cell.   To reduce the
 possibility of contamination of the samples by the nozzles, glass
 nozzles were used instead of the stainless steel  nozzles as had
 been used on previous tests.  In addition, three  wet impingers
 were used in the train instead of the usual two.   Following one
 trial and one aborted run,  testing was conducted  over a period of
 4 days with four runs per day.  As with the second NIST test,
 this test was designed to determine the drift rate based on
 selected native elements in the recirculating water.    The test
 was completed in accordance with CTI guidelines.
 C.2  SUMMARY OF TEST DATA
      The results of the EPA isokinetic and the absorbent paper
 emission tests at the Department of Energy's,  Gaseous Diffusion
 Plant in Paducah,  Kentucky,  are summarized in Table C-9.1  For
 the tower tested,  each riser supplies water to two fan cells.
.Stack emissions were sampled from fan cell Nos. 7 through 14
 (riser cell Nos.  4 through  7).   For most tests, half  of the
 sample was collected from each of the fan  stacks  corresponding to
 a riser cell.   All data for the isokinetic emission tests are
 reported in Table  C-9  as being greater than the value presented
 because only about one-third of the chromium was  transferred with
 the liquid to the  vial used for analysis after the sample was
 concentrated.   The balance  of the chromium remained in the beaker
 used to evaporate  the  water from the sample and required rinsing
 with aqua regia to solubilize the chromium for analysis.   This
 method of rinsing  was  not performed with the beakers  used to
 concentrate samples collected at the Department of Energy's,
 Gaseous Diffusion  Plant in  Paducah,  Kentucky.
      The results of the first Method 13-type and  absorbent paper
 emission tests  at  NIST in Gaithersburg,  Maryland,  are summarized
 in  Table C-10.2  The results  of  the Method 13  and absorbent paper
 emission tests  at  Tower 68  at the Exxon  refinery  in Baytown,
 Texas,  are  summarized  in Table  C-ll.3  Although there are  three
 riser  cells  and five fan stacks,  individual  tests  were  conducted
 on  each  fan  stack.   The results  of  the Method  13-type,  absorbent
                               C-22

-------
 paper,  and ion exchange emission tests  at Tower 84  at the Exxon
 refinery in Baytown,  Texas,  are summarized in Table C-12.3  The
 results of the Method 13-type and absorbent paper tests at the
 Southeastern Manufacturing facility are summarzied  in
.Table C-13.4  Sensitive paper drift measurements at three test
 sites (Paducah, Gaithersburg, Baytown)  are summarized in
 Table C-14.1""3
      The results of the second Method 13-type emission test at
 NIST in Gaithersburg, Maryland, are summarized in Table C-15, and
 the results of the Method 13-type emission test at  Allied Fibers
 are summarized in Table C-16.5'6  For both of these tests,
 emission rates were determined for a number of selected elements.
 C.3. ANALYSIS OF TEST METHOD7
      The cooling tower emission test method used in the second
 NIST and Allied tests currently is under consideration for
 approval by EPA.  This method, which has been used  extensively  by
 CTI, uses surrogate element concentrations of minerals that are
 native to the recirculating water for determining drift rate.
 The method requires isokinetic sampling of cooling  tower drift
 emissions and determining mineral concentrations in the
 recirculating water and drift by inductively coupled argon plasma,
 spectroscopy.  Elements that are found in the sample in
 concentrations that are close to the detection limit and other
 "unreliable" elements are screened out.   (In previous tests
 conducted by a testing firm retained by CTI, several elements
 were found to give inconsistent results for drift rate
 determinations, and, thus, are considered to be unreliable.)
 Mineral-specific drift rates are then determined from these data
 for the remaining elements  (i.e., those that were not screened
 out), and the overall tower drift rate for a specific test run is
 determined by averaging the mineral-specific drift rates  for that
 run.
      Because of the high variability in test data from the two
 EEA-sponsored tests  in which this test method was used, the data
 from the second NIST and Allied tests were analyzed to evaluate
 the reliability of the test.method  in distinguishing between an
                                C-23

-------
LEDE-equipped tower and an HEDE-equipped tower.  The specific
objectives of this analysis were to evaluate the procedure for
screening elements for average drift rate determinations and to
determine whether the method has sufficient precision to
distinguish between the emission levels for HEDE's and LEDE's in
a typical compliance setting.
     The results of this analysis suggest that the test method
does have significant limitations in its ability to distinguish
between drift rates for towers equipped with HEDE's and for
towers equipped with LEDE's within an acceptable number of test
runs.  In addition, improvements in the test method are unlikely
due to cooling tower stack test conditions, which generally are
inappropriate for obtaining a representative sampling of the
exhaust stream.  The following sections describe in detail the
approach and the results of the analysis of the test method.
C.3.1  Procedure forScreening Elements
   ' Although there is general agreement that the detection limit
criteria is reasonable for screening out elements, additional
procedures have been considered for screening out unreliable data
for the remaining elements.  Two possible criteria that have been
proposed are chemical characteristics and identification of
outliers.
     C.3.1.1  Chemical Class.  Historically, drift tests
conducted by CTI have used alkali metals to determine drift rate.
These elements are reported to be more reliable in terms of
repeatability.  Drift rates from the second NIST test indicate a
bimodal distribution with the alkali or alkaline earth metals
behaving quite differently from the transition metals.  However,
the Allied data show no such systematic differences.  Although
some questions have been raised about a number of factors that
may have affected the magnitude of the drift rates at Allied (as
described in Section C.I.7.2), the Allied data are noteworthy in
that (1)  the element-specific drift rates for Allied were less
variable than those for NIST; (2) as mentioned previously,
variations in the Allied data do not appear to be related to
specific classes of elements; and (3)  the overall drift rates
                              C-24

-------
based on all elements above detection limit were comparable for
the Allied and second NIST tests.  Therefore,  the data available
provide no compelling reason for screening out elements based on
chemical class.
     C.3.1.2  Outlier Identification.  Several approaches are
available for identifying outliers.  A simple method uses a
cutoff of two times the standard deviation—all data points that
differ from the mean by more than twice the standard deviation
are considered outliers.  In a normally distributed population,
the range defined by this criteria includes 95 percent of the
distribution.  This approach is more liberal than approaches in
some texts, which suggest ranges of three or even four times the
standard deviation.  However, applying this approach to log
transforms of the NIST and Allied data, which were found to be
more normally distributed than the raw drift rates, yields no
outlying points.                                   %
C.3.2   Precision of Test Method
     The precision of the test method was evaluated by analyzing
the standard deviations of the run-specific drift rates.  The
data suggest that a reasonable estimate for the standard
deviation of the drift rates is 60 to 100 percent of the mean,
and for the purpose of the analysis, a standard deviation of
80 percent was assumed.
     A variety of approaches could be used to evaluate whether  a
method has sufficient precision to differentiate between an HEDE-
equipped tower and an LEDE-equipped  tower.  The method selected
because of its straightforward,  intuitive interpretation involved
a hypothetical comparison of HEDE- and LEDE-equipped towers that
were assumed to have "true" drift rates of 0.01 percent and
0.03 percent of the recirculation rate, respectively.  It was
also assumed that the HEDE tower would have to achieve a drift
rate of at least 0.01 percent  lower  than the LEDE tower  (i.e.,
the HEDE drift rate must be no greater than 0.02 percent of the
recirculation  rate)  in  order for the HEDE tower drift  rate to  be
considered to  be significantly lower.  The frequency with which
the test method would fail to  demonstrate that the HEDE tower
                               C-25

-------
v   achieves a significantly lower emissions rate than the  emissions
   rate from the LEDE tower was then determined.   Based  on a maximum
   error of 5 percent,  it was determined that  a  minimum  of 18  test
   runs would be required to reliably characterize the magnitude of
   the  drift rate for a typical tower equipped with HEDE's.
                                C-26

-------
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-------
TABLE C-3.  SUMMARY OF OPERATING PARAMETERS AND METEOROLOGICAL
      DATA DURING TESTING OF TOWER 68 AT EXXON'S REFINERY,
                         BAYTOWN,  TEXAS
Parameter
Date
Run Nos.

.

Pretest
08/31/86




Recirculating water flow, L/min (gal/min)
Riser 1
Riser 2
Riser3
27,656 (7,307)
27,478 (7,260)
33,408 (8,827)
Test
Series No. 1
09/01/86
CT-68-1-1
CT-68-2-1
CT-68-5-1
CT-68-5-2




Test
Series No. 2
09/02/86
CT-68-4-1
CT-68-5-3






Fan amperage, amps
Cell 1
Cell 2
Cell 3
Cell 4
Cell5





85
90
78
90
120
Pump outlet pressure, kg/cm2 (psig)
Pump 3
Pump 3B
Hot water line pressure, psig



5.6 (80)
5.6 (80)
2.0 (28)
84-85
89-90
77-78
90
120

5.6 (80)
5.6 (80)
2.0 (28)
Water temperature, °C (°F)
Basin 1/3
Basin 2/4
Basin 5
Hot water line, °C (°F)
Riser 1
Riser 2
RiserS
Makeup water flow, L/min (gal/min)
Slowdown, P/min (gil/min)









Water chemistry on-line monitor
PH
Conductivity, jimho*
Operator analysis
pH
Conductivity, pmhos
Free chlorine, ppm
Chromate, ppm


27-30 (82-85.5)
29 (85)
28-30 (83-85.5)
38-39 (99.5-102)
38-39 (100-102)
39 (103)
38-39 (100-102)



7.87-7.96
1,029-1,056
28-29 (83-85)
28-29 (83-84.5)
28-29 (83-85)
38-39 (100-102)
-(-)
_(_)
38-39 (101-102)
-1,230 (-325)
-265 (-70)

7.90-8.04
1,026-1,038





7.7
1,000-1,057
0.2
12
7.9-8.1
1,022-1,035
0-0.1
13-14
                                 . C-37

-------
                            TABLE C-3.    (continued)
Parameter
Pretest
Test
Series No. 1
Test
Series No. 2
Vendor analysis*
PH
Conductivity, )mhos
m-alkalinity, ppm
Chromate, ppm
Free chlorine, ppm
Calcium, ppm
Cycles
Chromate inhibitor feed rate, L/d (gal/d)
















7.9
1,020
80
14
0
226
5.9
15.1 (4.0)
Meteorological data at tower
Wind speed, in/sec (ft/sec)
Wind direction, 00-360
Ambient temperture, *C (°F)



2-11 (6-37)
180-360
32 (89)
0.4-9 (1-29)
Unknown
31-33 (87-91)
Meteorological data at Exxon station
Wind speed, m/sec (ft/sec)
Wind direction, 00-360
Ambient temperature, "C (*F)



2-5 (7-18)
90-180
25.4-30.2
(77.8-86.4)
3-6 (10-21)
90-180
29-30
(84-86)
*Vcndor analysis only performed on date of second test series.
                                          C-3 8

-------
TABLE C-4.  SUMMARY OF OPERATING PARAMETERS AND METEROLOGICAL
     DATA DURING TESTING OF TOWER 84 AT EXXON'S REFINERY
                        BAYTOWN,  TEXAS
Parameter
Date
Run Nos.



Recirculating water flow, L/min (gal/min)
Riser A
Riser B
Riser C
Riser D
Pretest
09/03/86





20,000 (5,300)
19,600 (5,200)
23,000 (6,100)
23,000 (6,100)
Fan amperage, amps
Cell A
CellB
Cell C
CeHD
60
60
60
63
Test
series No. 1
09/04/86
CT-84-A-1
CT-84-A-2
CT-84-C-1
CT-84-C-2





Test
series No. 2
09/05/86
CT-84-B-1
CT-84-B-2
CT-84-D-1
CT-84-D-2






60
60
60
63
Pump outlet pressure, kg/cm2 (psig)
Pump 84A
Pump 84B


6(80)
6 (80)
60
60
60
63

6(80)
6 (80)
Cold water line pressure, kg/cm2 (psig)
Water temperature, °C (°F)
Basin
Line to pump 84A
Line to pump 84B
Riser A
Riser C
Riser D
Makeup flow rate, L/min (gal/min)
Slowdown, L/min (gal/min)
Water chemistry on-line monitoring
pH
Conductivity, )mhos
Free chlorine, ppm
Operator analysis
pH
Conductivity, )mhos















29 (85)
27-28 (82-83)
27-28 (82-83)
37.5-38
(99.5-100)
37.5-38
(99.5-100)
37.5-38
(99.5-100)



6.8-7.1
Unknown
0.35-0.57

7.25
1,200
29 (84-85)
27-28 (82-83)
27-28 (82-83)
36.9-38
(98.5-100)
36.9-38
(98.5-100)
36.9-38
(98.5-100)



6.8-7.0
Unknown
0.15-0.30

7.0
1,100
                                 C-39

-------
                            TABLE  C-4.   (continued)
Parameter
Makeup conductivity, )mhos
Chromate, ppm
Vendor analysis*
PH
Free chlorine, ppm
Chromate, ppm
Conductivity, )mhos
Cycles
Chromate feed rate, L/d (gal/d)
Meteorological data at tower
Wind speed, m/sec (ft/sec)
Wind direction, 00-360
Ambient temperature, "C (°F)
Meteorological data at Exxon station
Wind speed, m/sec (ft/see)
Wind direction, 00-360
Ambient temperature, °C ("F)
Pretest

















Test
series No. 1
160
12.5








1-9.8 (4-32)
270-360
33 (92)

2-4.5 (7-15)
90-110
30-31 (86-87)
Test
series No. 2
150
12.5

6.9
0.2
12.5
1,100
7.3
11.4(3.0)

2-8 (6-26)
270-360
29-33 (84-91)

0.4-2 (1-7)
120-180
30 (86)
'Vendor analysis only performed on date of second test series.
                                           C-40

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to take picture of it, but there is not enough light.
run.




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for 10 minutes during the run before being repaired




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11 il
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fall if they are heavy enough; otherwise they are dr
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                                         C-46

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-------
 C.4  REFERENCES  FOR APPENDIX  C

 1.   Entropy  Environmentalists,  Inc.   Emission Test Report:
     Department  of  Energy  Gaseous  Diffusion Plant, Paducah, KY.
     Prepared for U.  S.  Environmental  Protection Agency.
     Research Triangle Park,  NC.   EMB  Report  85-CCT-2.
     October  1986.  53 pp.

 2.   Entropy  Environmentalists,  Inc.   Emission Test Report:
     Natural  Bureau of Standards Steam and Water Chill  Plant,
     Gaithersburg,  MD.  Prepared for U.  S. Environmental
     Protection  Agency.  Research  Triangle Park, NC.  EMB
     Report 86-CCT-4. October  1986.   44 pp.

 3.   Entropy  Environmentalists,  Inc.   Emission Test Report:
     Exxon Company, U.S.A., Baytown, TX.  Prepared for  U. S.
     Environmental  Protection Agency.   Research.Triangle  Park,
     NC.   EMB Report  86-CCT-3.   November 1986.   62 pp.

 4.   Entropy  Environmentalists,  Inc.   Emission Test Report:
     Southeastern Manufacturing Facility. Prepared for U.  S.
     Environmental  Protection Agency.   Research  Triangle  Park,
     NC.   EMB Report  86-CCT-04.  July  1988.   75  pp.

,-5.   McClintock, S.,  and W. Kirk (Entropy Environmentalists,
     Inc.).  Emission Test Report: National  Institute  of
     Standards and  Technology,  Gaithersburg,  MD.   Prepared for
     U.  S. Environmental Protection Agency.   Research Triangle
     Park, NC.  EMB Report 91-CCT-5.   June 1991.

 6.   McClintock, S.,  and W. Kirk (Entropy Environmentalists,
     Inc.).  Emission Test Report: Mineral  Drift  Emission
     Testing  of  a Cooling  Tower—Chromium NESHAP Development,
     Allied Fibers  Process Cooling Tower, Moncure, NC.   Prepared
     for U. S. Environmental  Protection Agency.  Research
     Triangle Park, NC.   EMB  Report 91-CCT-	.   August  1991.

 7.   Memorandum. Wallace, D.,  and R.  Marinshaw, MRI, to
     Myers, R. ,  EPA:ISB.  August 28,  1991.  Analysis  of Drift
     Rate Data From the NIST  and Allied Tests.
                               C-88

-------
              APPENDIX D.




EMISSION MEASUREMENT OF COOLING TOWERS

-------

-------
       APPENDIX D - EMISSION MEASUREMENT OF COOLING TOWERS

D.I  INTRODUCTION
     Between  June  1986  and  January  1991,  The  EPA's  Emission
Measurement  Branch sponsored  a total  of  six emission  testing
programs at  five  cooling  tower facilities.    The  data were col-
lected  to  support  a  chromium National  Emission Standards  for
Hazardous Air Pollutants (NESHAP).    The test sites were selected
based  principally  upon  (1)   cooling  tower   design,   (2)  drift
eliminator design,  and (3)  additives and  mineral concentrations
in the  cooling tower  water.   Secondary  considerations included
availability and funding.
     The specific objectives of these test programs were:
     •  To determine  the  total chromium  and  hexavalent chromium
        emissions from cooling tower facilities.
     •  To  determine  the  mineral  drift  emission  rates  from
        cooling   tower facilities  and  whether  one  or  more
        surrogate  compounds  could  be  used  to  establish  the
        emission rates for all compounds.
     •  To  assess  the performance  of  various  methods  for  the
        determination  of  particulate   emissions  from  cooling
        towers.
     •  To assess the performance of new methods for the sampling
        and analysis of hexavalent chromium.
     •  To assess the performance  of  available methods  for the
        determination of cooling tower drift emissions.
     To accomplish  these  objectives, the following types of data
were obtained:
     •  Emission  concentrations of minerals,  total chromium, and
        hexavalent chromium (Cr )  through  the  use of isokinetic
        sampling  equipment.
                               D-l

-------
Emission  concentrations  of  surrogate compounds  through
the use of isokinetic sampling equipment.

-------
D.2  EMISSION MEASUREMENT METHODS

D.2.1  Scope of Test Programs
     Table  D-l summarizes the  types of  data collected  at each
test site and  the measurement locations.  The test methods used
for collection and analysis are discussed in Section D.2.2.

D.2.l.l   Facility  Selection -  As  previously mentioned,  EPA's
Emission Measurement Branch  (EMB)  sponsored a total  of  six test
programs at five cooling tower facilities from 1986 through 1991.
Facilities in reasonably good condition, with at least some cells
of the  cooling tower system equipped with  high-efficiency drift
eliminators, were selected for testing.
    All  the cooling  tower  systems  selected were  mechanically-
induced draft  cooling towers built  by Marley. ,  These towers use
a large  fan to force air  through  the cooling tower  and out the
top of  the fan  stack.    The most common  type of  cooling tower
systems function as a heat exchanger for air conditioner systems
in large office or  administrative complexes.   Cooling towers are
also  used  to  cool process equipment or  products  within  an
industrial  facility.   Depending on  tower  size and the  needs of
the  facility,  between  1,500 and  70,000  gallons  of water  may
circulate through the tower each minute.
 Mention of company or  product  names does  not  constitute
 endorsement by the US. Environmental Protection Agency.
                               D-3

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     TABLE D-1. SUMMARY OF EPA-SPONSORED COOLING TOWER TEST PROGRAMS
Test
Program
June 1986
June 1986
September 1986
July 1987
July 1990
January 1991
Facility Test
No. of Fan Cells
NBS (NIST), MD
Four Fan Cells
All Equipped with Munters
D-1 5 HEDE's
Paducah Gaseous Diffusion
Plant, KY
Seven Fan Cells
Five cells equipped with
standard efficiency and two
cells equipped with Thermatec
Spectra HEDE's
Exxon Company, TX
Five Fan Cell System-
Standard Efficiency Drift
Eliminators
Four Fan Cell System -
equipped with Marley XCEL-15
HEDFs
Southeastern Manufacturing
Facility
Four Fan Cells, two cells
equipped with Marley XCEL-10
HEDEs, and two cells
equipped with standard
efficiency drift eliminators
NIST, MD
Four Fan Cells, all equipped
with Munters D-1 5 HEDFs
Allied Fibers, NC
Four Fan Cells, all equipped
with Marley XCEL-15 HEDE's
Sample Type
or
Method
Emissions/Ml 3
Emissions/Sensitive
Paper
Tower Water
Emissions/Ml 3
Emissions/Disk Sizing
Emissions/Sensitive
Paper, Absorbent Paper
Tower Water
Emissions /M 13
Emissions/Sensitive
Paper, Absorbent Paper
Tower Water
Emissions/Ml 3 (CTD)
Emissions/Backward
Nozzle
Ambient Air/MM5
Tower Water
Emissions/M13 (CTD)
Emissions/MM5
Ambient Alr/MM5
Tower Water
Emissions/Ml 3 (CTD)
Emisstons/MMS
Ambient Air (CTD)
Tower Water
Pollutants/
Parameters
Measured
Soluble Cr
Total Cr
Drift Rate, Drift Size
Cr*3, Soluble Cr. Total
Cr
Total Cr, NaBr
Total Cr < 15 um
Drift Rate, Drift Size
Cr*. Total Cr
Total Cr
Drift Rate, Drift Size
Cr*6, Total Cr
C*6, TotaJ Cr
Total Cr < 4 fjm
Total Cr
Cr*6. Total Cr
32 Minerals
PM10
32 Minerals
32 Minerals,
suspended dissolved
solids
32 Minerals
PM10
32 Minerals
32 Minerals,
suspended dissolved
solids 	 mmmi
M13: Modified Method 13 sample train.
MM5: Modified Method 5 sample train.
                                     D-4

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     Figure  D-l  is  a  schematic  of  the cooling  tower  system
located at the National Institute  of Standards and Technology in
Gaithersburg, Maryland.   This system is  typical  of most cooling
tower designs.
     Water droplets  and  aerosols  that  leave  the  cooling  tower
through the  fan cells are  referred to  as  drift.   Emissions or
drift from the cooling tower are reduced by high-efficiency drift
eliminators.    Drift  eliminators are designed to  reduce cooling
tower  drift   by  forcing   the   exhaust  air   through  several
directional  changes  which  cause water  droplets in  the air to
impact the drift eliminator surface and drain into the cold water
basin of the  tower.   The drift eliminators tested  in this study
were made by Mar ley,  Munters, and Thermatec.
D.2.1.2  Types  of  Samples and Data Collected  -  Samples and data
collected from cooling towers fall into four major categories:
     •  Tower Emission Samples
     •  Cooling Water Samples
     •  Ambient Air Samples
     •  Meteorological Data
Emissions were analyzed for:
     •  Total Chromium
     •  Hexavalent Chromium
     •  Minerals (32 elements)
     •  Surrogate compounds, such as Sodium Bromide
     •  Total Particulate
                               D-5

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                                                                     .8
                                                                     "5
                                                                      =

                                                                     "5
                                                                     £
                                                                      
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 Cooling tower  water  samples  were  collected for  measuring  the
 concentrations  of  the following:
      •   Total dissolved  and  suspended  solids
      •   Minerals  (32  elements)
      •   Total chromium
      •   Hexavalent chromium
 Ambient air  samples were analyzed for:
      •   Minerals  (32  elements)
      •   Total chromium
      As an  integral  part  of  all  the  test programs,  process
 operation data were monitored and recorded.  These data typically
 included:
      •   Recirculating water  flow and water pressure
      •   Water blowdown rates (if applicable)
      •   Water temperature  in the basin or riser
      «   Water chemistry  and/or additives
      •   Fan  speed  or  amperage
      Depending  on  the  availability  and  compatibility  of  data
 acquisition   systems,   these   data   were   collected   either
 automatically or  manually.  In some  cases,  the same  data  were
 collected both ways as a quality assurance check on the data.

D-2.1.3    Emission  and  Process   Sampling  Locations  -  Stack
emissions from a cooling tower fan cell were generally sampled at
the  top. of  the fan  stack  directly  over  the fan  blade.    The
sampling equipment  was traversed across  the fan  cell between the
hub of the fan blade and the edge of the cell  wall.   The traverse
                               D-7

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points were determined using an annular  area  formula along radii
that formed 90° angles to each.
     Ambient air  samples were taken  about 100 meters  upwind  of
the test site.   Occasionally,  ambient air sampling locations were
moved from one day to another due to changes in wind direction.
     Cooling  water  samples were  taken  either  from  the  deck
located on top of the cooling tower or from a spigot on the riser
pipe.
     Meteorological  (met) data were taken on-site for temperature
and  barometric  readings of  the  day.    Locally available  met
stations at airports or  industrial facilities were used to supply
detailed weather  analysis data  (such as dew  points,  wind speed
and direction, etc.) during the test program.

D.2.2  Selection  of  Sampling and Analytical Methods
     Several  toxic  and  many  non-toxic  pollutant emissions were
measured during the test programs.   This  section discusses  the
rationale  behind  the  selection  of the  test method (.s)  used to
measure  each  pollutant  and describes  the application of these
methods during the test  programs.

D.2.2.1  Total Chromium  and Hexavalent Chromium Emissions  -
     Hexavalent   chromium has  been  the  primary  concern  in  air
emissions  from cooling tower facilities.  Hexavalent chromium,  a
carcinogen,  as chromate  is  used  in some  cooling tower systems  for
corrosion   control.    Since   emissions   of   chromium  have  been
routinely  measured  by  industry,  one of  the  first  objectives of
                                D-8

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these  test programs  was  to ascertain  the  makeup  of  chromium
emissions in terms of total  chromium  and  Cr*6.  A modified Method
13 train was  selected for this purpose.   Before the first test,
it was  assumed that the  ratio  of Cr*6  to total  chromium  in the
air emissions was the same as the  ratio of Cr*6 to total chromium
in the cooling tower recirculating water.
     The first  test  program produced results for total chromium
emissions  that  approximated  those  concentrations  anticipated
through the use of mass-balance equations.  The analysis was done
using Neutron  Activation Analysis (NAA).    A  graphite furnace
atomic absorption spectrometer (GFAA)  was used in tandem with the
NAA for  quality control  studies.   However,  Cr*6  emissions were
less than 25% of the anticipated values.
     Over the next three test programs,  various methods were used
to determine  Cr*6 emissions,  but none were successful;   One of
the biggest  obstacles to the test program was  the inability to
prevent  Cr*t from  converting to trivalent  chromium  during the
                                                            +6
sampling phase  of the  test. Though  a  test  method for Cr  was
later developed under  another  EPA study,   attempts  to verify Cr
emissions from  cooling  towers  were dropped after the failure of
the July 1987 test program to quantify Cr*6 emissions.
D.2.2.2   Minerals and Surrogate  Compounds  - The  June 1986 test
program was the first attempt for this series of test programs to
                                                           +6
quantify emissions by measuring a surrogate  compound for C .  In
theory, the  ratio of  the surrogate to  other components  in the
cooling water was believed to be the same as in the emissions.
                               D-9

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     The  use of surrogate compounds had been used by industry in

 previous  emissions  tests to establish the drift rates of cooling

 towers.   Cooling tower drift rate  (i.e.,  the  emission rate of

 water droplets  and  aerosols)  is defined as the mass emission rate

 of  a compound (typically in units of micrograms  per hour [/ig/hr])

 divided by  its  mass circulation rate in the water  (also  in  Mg/nr)

 times  100%.   Industry test  programs  utilized  emission  sampling

 methods   similar  to  Method  13  and  another  method which used

 heated,  glass  beads.    Industry test  teams  have  reported drift

 rates that  closely^match the  expected  drift rate of 0.005%.

     In   the  EPA-sponsored  test  programs,  a  modification  of

 the Cooling Tower  Institute  test  method, similar  to Method  13,

-was "used  in  determining  cooling  tower  drift  emissions  (see

 Figure D-2).   These modifications included:

     •  The  use  of  0.5 molar  (M)  nitric  acid  for  a reagent
        instead of  0.1 M nitric acid,  and the use  of  0.5 M  nitric
        acid for rinsing the  probe  and sampling  glassware instead
        of  1.0 M nitric acid.  This  step made the molarity of
        nitric  acid   in  the  combined  reagent/rinse   sample
        consistent.

     •  The  use  of   three   impingers   with  a  total  of   250
        milliliters (mL) of reagent  instead of two impingers with
        200 mL of reagent,  and using the  filter  only  as  a quality
        control  step.    Removing  the  filter  from the  sample
        analysis results eliminated  ambiguities  due to high blank
        levels of the target  compounds.

     •  Using acetone to first rinse the nozzle and  probe  of  the
        sampling equipment.   Formerly, only  the nitric  acid  was
        used as a  rinse reagent.   Because  of the long  length of
        the sampling probe,  it was believed  that rinsing with an
        additional    reagent   would   assure   complete   sample
        collection.
                               D-10

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     The modified test method, known as EPA's Draft Cooling Tower
Drift (CTD) Emission Test Method, or the CTD method, was utilized
in  the   last  two  test  programs at  NIST,   Maryland and  Allied
Fibers,  North Carolina.  For the Allied Fibers test, the relative
standards  deviations  (RSD)   among  five  sets of  paired  trains
ranged  from 39  to  154% depending  upon the element  analyzed.
Previous test programs by both EPA and industry had RSD's usually
exceeding  200%.   These large variances  in  precision are usually
attributed  to  the  unique   characteristics  of  cooling  towers,
particularly  the   large  stack  diameter   to   be  sampled  and
considerable cyclonic  flow  that prevents a uniform distribution
of emissions across the stack opening.
     However, the  drift rates among  the compounds tested varied
sharply  from  the  expected  "single-value" drift number that had
been assumed.   The NIST drift rate  averages ranged from a value
of  0.007%,  which is comparable  to  industry estimates,  to values
up  to  6.0%.  The  Allied Fibers drift  rate averages ranged from
0.02  to  2.00%.    Data   assessment  suggests   that  a  linear
relationship existed between the solubility of a compound and its
drift rate, but  no theory is proposed as to why this relationship
occurred,  and  the relationship  was  not consistent enough to use
as  the  basis for predicting emissions with  surrogate compounds.
     Inspection  of previous industry test reports show that this
pattern of inconsistent drift rates was always present.  Several
reports cited  drift rates of 0.005%  for  cooling towers; however,
the results were based on calculations  using only  those elements
associated with low  drift  rates,  such  as  sodium and  magnesium.
                               D-12

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 Data  presented  in  the appendices  of these reports  did  not present
 the actual element-specific  drift rates, but when  calculated, the
 drift values  for elements such as iron and copper were orders of
 magnitude greater  than those presented  in the report.
      Based  on  the  test  programs  at  Allied  Fibers  and  NIST,
 together with a reevaluation  of  previous  industry test reports,
 the use of surrogate compounds to determine  emissions of other
 pollutants is not  recommended.
D.2.2.3   Particle  Size - Evaluating the test methodology used to
determine the particle size of drift emissions progressed through
several  stages.    During the first  three test programs,  both a
sensitive paper  (SP)  sampling method and an absorbent paper-  (AP)
sampling  method were used  in  determining  particle  counts  and
sizes.  Both methods  showed  good  mutual agreement, but fell well
short  of  approximating  the  values  calculated by  mass  balance.
The  SP and  AP  techniques  are  believed  to  have significantly
underestimated  the   small   droplet  flux  downstream  of  high-
efficiency drift eliminators.
     In response to  the inconsistency noted  above,  the  Southern
Research  Institute suggested another  method  of  particulate/PM10
collection.   This  method employed  a modified Method  5  sampling
train  in  tandem with an impaction  paper (IP) sampling  device.
The modified Method 5 train  consisted  of a glass  nozzle  followed
by 6 inches of heated glass  probe and  a 47-millimeter (mm)  total
particulate filter.  The IP device consisted of a 47-mm absorbent
paper  placed  near the  nozzle in a heated  Teflon™ holder.   In
                              D-13

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theory, the  IP  device would  capture particles  larger than  30
microns  (M)  in  diameter,  whereas  smaller  particles would  flow
around  the  impact ion device.    The  30-/I   size  was  considered
optimal  in that  water droplets  of this size  or  smaller  would
evaporate and for~m PM10 particles.
     This system, when employed during the NIST test, provided no
usable  data  because  the  gravimetric  analysis  of  the  total
particulate filters was  either negligible  or negative.   The same
system, when  used at the Allied  Fibers  test,  provided data, but
interpretation  of the data remained  circumspect  due to:  (a) the
inability  to  provide  an  accurate assessment of  how much of the
particulate captured  by  the impaction device could  be compared to
the  total particulate sampled through  the nozzle,  and  (b) the
fact  that  the  Allied  Fibers  cooling tower  was  considerably
different  from   the  majority  of  cooling  towers,  with higher
amounts  of dissolved and suspended solids present  in the cooling
water,  and large amounts of additives/pollutants.

D.2.2.4    Ambient Air -  During the  last three  test programs at
Southeastern Manufacturing   Facility  (SMF),  NIST,  and Allied
Fibers,  ambient  air  samples  were  taken  upwind  of the  cooling
tower.   The  ambient  air system  for  SMF and NIST  consisted of  a
modified Method  5 train consisting of a filter  holder with a 3-
 inch filter  collecting the air sample.   Because  of the high blank
 values of filters (with  respect  to air  emissions),  the last test
 at Allied Fibers used  a CTD sampling  train  without a  probe  to
 capture ambient air samples.
                                D-14

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     Since  a  full  battery of  air  samples  was  not taken,  the
ambient air samples were not used to correct the emission results
from  the cooling  tower.   This  step  was  primarily  a  quality
control step in the case of a local phenomenon affecting the test
program.                                     *

D.3  COOLING TOWER OPERATIONS AND MONITORING
     The emission rate  is  a function of air velocity through the
fill, type of fill, type of drift eliminator, recirculation rate,
concentration of cooling water constituents, and tower condition.
Air  velocity  is generally considered  to  be the  most  important
factor  in  drift or emission  rate.   Improper maintenance of the
drift eliminators, basins, or fan  cells can result in high drift
rates.

D.4  QUALITY ASSURANCE/QUALITY CONTROL  FOR TEST PROGRAMS
     A  vital  part  of  any  sampling  and  analysis program  is
provision   for   procedures that   assure  the  quality   of  data
obtained.   These  procedures  are  termed  quality  assurance and
quality  control (QA/QC)  and  serve  to  (1)  document the quality
(accuracy,   precision,  completeness,   representativeness,  and
comparability)  of  generated data  (QA);  (2)  maintain the quality
of data within  predetermined  control limits  for specific  sampling
and  analysis  procedures  (QC);  and  (3)  provide  guidelines for
corrective  actions   if  QC  data    indicate  that   a  particular
procedure is out of control.
                               D-15

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     Cooling tower test programs are complex and the test methods
applied to these sources are not  routinely  done.   Therefore,  EPA
recognized  that  a  rigorous  QA/QC  program  was  essential  to
successful test programs.  This section  describes both the QA/QC
procedures for the  EPA-sponsored  cooling tower test programs and
the  recommended  QA/QC  procedures   for  future  cooling  tower
testing.

D.4.1  OA/OC for Previous EPA Cooling Tower Test Programs
     A  QA/QC  Procedures  Section  was  included in  each work plan
(site-specific  test plan)  for  all  test programs.    The QA/QC
section was reviewed by all test team participants,.including the
Work Assignment Manager, prior  to each test program.  Though not
always  stated  in each  QA/QC  section,  the following elements were
implicit in each QA/QC plan for each test program:

        Title Page
        Table of Contents
        Project Description
        Project Organization and Responsibility
        QA Objectives
        Sampling Procedures
        Sample Custody
        Calibration Procedures and Frequency
        Analytical Procedures
        Data Reduction, Validation, and  Reporting
        Internal QC Checks
        Performance and System Audits
        Preventive Maintenance
        Assessment of Data Precision, Accuracy, and  Completeness
        Corrective Action
        Reports to Management
     The following discussions will utilize the QA/QC  elements to
highlight  the QA/QC  procedures  and  QA/QC  content for  the EPA
cooling tower  test programs.
                               D-16

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 D.4.1.1  Title Page and Table of Contents - Self-explanatory.

 D.4.1.2  Project Description -  A general description of the test
 program and the  process to be tested was provided.  In the major-
 ity of cases, a  test  matrix table was prepared.  A schedule with
 anticipated  dates  for completion  of  significant subtasks  was
 prepared.

'D.4.1.3   Project Organization  and Responsibility -  Because all
 the cooling tower test programs were  complex,  and most involved
 interaction of  several parties, the delineation  of  test program
 organization and responsibilities  was crucial  to the success of
 the  project.     The  responsibilities  of   key   personnel  and
 organizations were described in the text of each work plan.

 D.4.1.4   Quality Assurance  Objectives - The QA  objectives were
 generally based  on previous  experience in  the application of the
 various measurement/sampling systems.

 D.4.1.5    Sampling  Procedures  -  Detailed descriptions  of  all
 sampling procedures used were included in  each  work plan.   These
 descriptions addressed the following areas:
    •  Sampling   location  specification  and  guidelines  used  to
       select them.
    •  Specific  sampling procedures to be used  (by reference for
       standard   protocol   and   by   detailed  description   for
       nonstandard protocols).
   . •'  Figures    to   illustrate  sampling   locations,   sampling
       equipment, charts  or flow diagrams to summarize procedural
       steps.
                              D-17

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    • Description  of containers,  procedures, reagents,  etc.  for
      sample  collection, preservation, transport, and storage.
    • Special procedures for  equipment preparation.
    • Sample  preparation  procedures  (concentration,   dilution,
      cleanup).
    • Forms for  sample collection,  recovery,  and  transport.

D.4.1.6  sample Custody - Each work plan addressed the procedures
used to ensure sample integrity.

D.4.1.7   Calibration Procedures  and  Frequency - When required,
each  work  plan  included  a  description  of  the  calibration
procedures for  each critical measurement  system.   This included
listing  the  procedures   for  reference  to  standard  operating
procedures, the  frequency  of calibration,  and information on the
calibration standards used (source, traceability, purity).
D.4.1.8   Analytical Procedures - As for the sampling procedures,
details  of  the  analytical  procedures were established in  the work
plan.   This  involved reference to  standard protocols,  complete
description of  procedures for  nonstandard protocols,  and flow
diagrams and charts summarizing procedures.

D.4.1.9   Data  Reduction.  Validation,  and Reporting  -  For each
critical measurement parameter, the following  were considered:
     • The  data reduction  scheme planned on the collected data.
     • All  equations used  to  calculate the  concentration  or value
       of the measured  parameter and the reporting units.

                                D-18

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     •  The principal procedures  used  to validate  data  integrity
        during  collecting,   transferring   (if   applicable),   and
        reporting of  data.
     •  The methods used to  identify  and  treat outliers.
     •  The data flow or reporting scheme from  collection  of raw
        data through  storage and validation  of results.
 D.4.1.10  Internal PC Checks - The  section  on internal QC checks
 addressed the acceptance  criteria and  control  limits used  to
 control the data quality in the field.   Table D-2 summarizes the
 typical control  limits  for the EPA cooling tower  test programs
 along with corrective actions.
     Also  included  in the  internal  QC checks  were the  QC samples
analyzed  to  document  the  validity of  the  data  and control  its
quality.   QC samples  for  the cooling  tower test  program included
blank samples,  analytical replicates, and spiked samples.

D.4.l.ll  Performance and System Audits - Performance and technical
systems audits were  conducted  for  each cooling  tower test program.
Technical systems audits consist of  an  evaluation of all components
of a critical measurement system to determine their proper selection
and use.  They include a careful evaluation of both field and labor-
atory  quality  control procedures.   Systems audits  were typically
performed before or shortly after systems were operational, and were
sometimes repeated depending on the  measurement system and the test
program duration.                       .
                                D-19

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                                          TABLE D-2.

       SUMMARY OF ACCEPTANCE CRITERIA, CONTROL LIMITS, AND CORRECTIVE ACTIONS
Criteria
Control Limits
                                                                  Corrective Action
Manual Sampling

Row Alignment



Isokinetics

Final Leak rate
(after each port)

Dry Gas Meter
Calibration

Individual Correction
Factor (Y,)

Average Correction
Factor

Intermediate Dry
Gas Meter

Analytical  Balance
(top loader)

Barometric Pressure


Mineral (Element)
Analytical  Results

Instrument Calibration
Standard Check
(every 10 samples)

Instrument Calibration
Blank Check
(every 10  samples)

Instrument Interference
Check (before and after every
analytical  run or at least once
every 4 hours)

Duplicate
(every 10 samples)
Avg. resultant angle
within 20°
100 ± 10%

^ 0.02 acfm or 4% of
sampling rate, whichever
is less

Post average factor (Y)
agrees ± 5% of pre-factor

Agree with 2% of
average factor

1.00 ± 1%
Calibrated every six
months against standard

0.1 g of NIST Class S
Weights

Within 2.5 mm Hg of a
mercury-in-giass barometer
 ± 10% of true value
 ± 3 times the standard deviation
 of the mean blank value
 ± 20% of true value
Adjust flow data to correct for
misalignment based on
misalignment angles

Qualify data

Adjust sample
volume for port

Adjust sample volumes using the
Y that gives smallest volume

Redo correction factor
Adjust the dry gas meter
and recalibrate

Recalibrate against EPA
standard

Repair balance and recalibrate
Recalibrate
 Recalibrate
 Identify and correct problem,
 recalibrate and reanalyze
 previous 10 samples

 Reverify interelement and
 background correction factors
 ± 20% relative percent difference  Reanalyze
                                             D-20

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                                  TABLE D-2. (continued)
Criteria
Control Limits
Corrective Action
Duplicate Matrix Spike Recovery
(every 10 samples)

Hexavalent Chromium
Analytical Results

Instrument Calibration Check
Sample
(every 10 samples)

Matrix Spike
(every 10 samples)

Duplicate
(every 10 samples)

Calibration Linearity Check (6
points, prior
to analysis of sample)

Particle Sizing

Analytical Balance
Constant Weight
 ± 20% of true value
 ± 10% of true value
 ± 10% of true value
Reanalyze
Recalibrate
Reanalyze
 ± 20% relative percent difference   Reanalyze
 ± 10% of true value for each
point
<  ± 2 mg of NIST Class S
weights

±  0.5 mg for sequential
weighings 2 6 hours apart
Remake and/or reanalyze
standards
Adjust or repair balance and
recalibrate

Desiccate and rewekjh untl
criteria are met
      ^Relative difference (%) for duplicate analyses, where:

          Percent Difference -  First Value _• Second Value x  100%
                               0.5 (First +  Second Value)
                                             D-21

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D. 4. 1.12    Preventive   Maintenance  -  The  work   plan  addressed
procedures for  preventive  maintenance activities  relevant to  the
sampling and  analysis efforts.   Preventive maintenance  tasks  were
performed to minimize downtime during the test programs.
D. 4. 1.13  Assessment of Data Precision. Accuracy, and
Specific procedures  (calculations,  etc.)  to assess  data precision,
accuracy, and completeness were  included  in each work plan. D. 4. 1.14
corrective Action - Depending on the scope of the test program, work
plans   presented  a  corrective   action  scheme   including  staff
responsibilities to be  followed  when a measurement system was found
•ho be out of control.

D. 4. 1.14   Corrective Action  - Depending on  the scope  of the test
program, work  plans presented a  corrective  action scheme  including
staff responsibilities  to be followed when a measurement  system was
found to be out  of control.                                   *

D. 4. 1.15   OA Reports  to Management  - For each  cooling tower test
program, a mechanism was established for reporting to management on
the performance of  critical measurement systems  and data  quality.
Items reported  included:
      •  Changes to the work plan, if any.
      •  Limitations  or  constraints  on the use  or applicability of
        the data, if any.
      •  Quality  programs,  guality  accomplishments,  and  status of
        corrective actions.
      •  Results  of QA systems  and/ or performance evaluation audits.
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     •  Assessments  of  data quality  in terms  of precision,  bias,
        completeness,  representativeness, and comparability.
The  final  reports  for all  test programs  included  a separate  QA
section, documenting QA activities that support the data quality and
validity of the conclusions.
D.4.2  Recommended OA/OC for Performance Testing
     Because  of the  complexity of cooling  tower testing,  special
attention must  be  paid  to the QA/QC procedures  for  these programs.
It is recommended that QA/QC procedures be an integral part of every
performance  test program.    The essential  elements  of QA/QC  for
cooling tower test programs have been  identified and defined in the
previous section.  The control limits,  acceptance criteria, and data
quality  objectives used  in  the EPA-sponsored  cooling tower  test
programs  and presented  in  the previous  section  may  be used  as
guidelines.  Since the analysis  of  drift emissions is not currently
a routine procedure,  some key QA/QC procedures for conducting these
analyses and assessing the data  for cooling  tower test programs are
discussed below.
     Generally,  emission  concentrations  from  cooling towers  are
measured in amounts below 50 jig per cubic meter.  Consistency, care,
and  planning  in  sampling  procedures,  recovery  procedures,  and
analysis are necessary  to ensure all QA/QC  objectives  are met,  and
that the cause of the problems can be traced down when encountered.
     If  the  analytical  detection limits  are  high,  the  percent
recoveries  of  the internal  standards  in  the  samples should  be
examined.    The analytical  detection  limit  is  affected by  many

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factors, some  of which can  be controlled  to some  degree by  the
analytical laboratory  (sample size,  final volume, percent  recovery
of standards, level of standards spiked,  and instrument sensitivity)
and other factors  (sample matrix and interferences)  that cannot be
controlled by the laboratory.   If  the  sample internal standards are
within the QC  limits, the high detection limits are most  likely a
result  of  sample  interferences.   If they are  poor,  the percent
recoveries for the  laboratory method blank should be examined.   If
these are within the QC limits, the high detection limits are caused
by sample matrix effects  and  an alternate sample reagent or cleanup
procedure may offer improvement.
     Blanks  and  replicate samples,  respectively, can  be useful in
assessing sample  contamination  and  in monitoring the  precision of
the drift emissions sampling  and analysis.  If blanks/replicates are
used, a suggested sampling frequency is provided  below:
     •  Field Blank - One per sampling location.
     •  Proof Rinse  Blank -  One per sampling  train and one  for a
        representative number of sample  containers.   Analyze one of
        each prior to the field test.
     •  Reagent and Solvent Blanks - One for each new lot  number of
        reagent used.
     •  Laboratory Method Blank -  One  replicate for no more than 10
        samples of a given matrix.
     •  Laboratory  Replicate  -  One  replicate  for  no  more than 10
        samples of a given matrix.
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