Development Document for
Proposed Effluent Limitations Guidelines
and New Source Performance Standards
INSULATION FIBERGLASS
Manufacturing Segment of the Glass
Manufacturing Point Source Category
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
JULY 1973
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DEVELOPMENT DOCUMENT
for
PROPOSED EFFLUENT LIMITATIONS GUIDELINES
and
NEW SOURCE PERFORMANCE STANDARDS
INSULATION FIBERGLASS MANUFACTURING SEGMENT
OF THE GLASS MANUFACTURING
POINT SOURCE CATEGORY
Robert W. Fri
Acting Administrator
Robert L. Sansom
Assistant Administrator for Air & Water Programs
Allen Cywin
Director, Effluent Guidelines Division
Michael W. Kosakowski
Project Officer
July 13, 1973
Effluent Guidelines Division
Office of Air and Water Programs
U.S. Environmental Protection Agency
Washington, D. C. 20460
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ABSTRACT
This document presents the findings of an extensive in-house study
of the insulation fiberglass manufacturing segment of the glass
manufacturing category of point sources by the Environmental Protection
Agency for the purpose of developing effluent limitations guidelines and
Federal standards of performance for the industry, to implement Sections
30U and 306 of the Federal Water Pollution Control Act, as amended (33
U.S.C. 1251, 1314 and 1316, 86 Stat. 816 et.seq.) (the "Act").
Effluent limitations guidelines contained herein set forth the
degree of effluent reduction attainable through the application of the
best practicable control technology currently available and the degree
of effluent reduction attainable through the application of the best
available technology economically achievable which must be achieved by
existing point sources by July 1, 1977 and July 1, 1983 respectively.
The standards of performance for new sources contained herein set forth
the degree of effluent reduction which is achievable through the appli-
cation of the best available demonstrated control technology, processes,
operating methods, or other alternatives. The proposed regulations for
all three levels of technology set forth above establish the requirement
of no discharge of process waste water pollutants to navigable waters.
Supportive data and rationale for development of the proposed
effluent limitations guidelines and standards of performance are con-
tained in this report.
111
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CONTENTS
Sectipn
I Conclusions 1
II Recommendations 3
III Introduction 5
IV Industry Categorization 27
V Waste Characterization 31
VI Selection of Pollutant Parameters 39
VII Control and Treatment Technology 43
VIII Cost, Energy and Nonwater Quality Aspect 67
IX Effluent Reduction Attainable Through the
Application of the Best Practicable Control
Technology Currently Available Effluent
Limitations Guidelines 79
X Effluent Reduction Attainable Through the
Application of the Best Available Technology
Economically Achievable Effluent Limitations
Guidelines 83
XI New Source Performance Standards 85
XII Acknowledgments 87
XIII Bibliography 89
XIV Glossary 91
Supplement A 99
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FIGURES
Page
I Flame Attenuation Process 8
II Rotary Spinning Process 10
III How Insulation Fiberglass Is Made 11
IV Wire Mesh Chain Cleaning 20
V Size Distribution of Insulation Fiberglass Plants 25
VI General Water Flow Diagram for an Insulation
Fiberglass Plant 32
VII Biological Treatment at Plant A 44
VIII Water Flow Diagram of Plant A 49
IX Schematic Diagram of Plant B 53
X Water Flow Diagram of Plant B 54
XI Water Flow Diagram of Plant D 56
XII Water Flow Diagram of Plant E 59
XIII Chain Cleaning at Plant E 60
XIV Water Flow Diagram of Plant F 62
XV Flow Chart for Plant G 64
XVI Investment Cost of Total Recycle Per Unit Production 73
XVII Annual Operating Costs of Total Recycle Per Unit Production 74
XVIII Energy Consumption of Total Recycle 78
VI
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TABLES
I Properties Related to Applications of Glass Fibers
II Chemical Compositions of Glasses Used to Form
Commerical Fibrous Glass
III Primary Fibrous Glass Wool Products
IV Fibrous Glass Mats-Basic Forms
V Fibrous Glass Packs- Basic Forms
VI U.S. Shipments and Value of Wool Glass Fiber
1964-1971
VII Insulation Fiberglass Plants
VIII Constituents of Insulation Fiberglass Plant Waste Streams
IX Chain Wash Water Usage
X Raw Waste Loads for Insulation Fiberglass Plants '
XI Annual Raw Waste Loads
XII Sieve Analysis on Waste Cullet Water
XIII Biological Treatment System at Plant A
XIV Water Pollution Abatement Status of Existing Primary
Insulation Fiberglass Plants
XV A Comparison Between the Alternate Treatment and Control
Technologies
XVI Water Pollution Abatement Costs for Total Recycle
XVII Estimated Cost of Waste Water Treatment for Insulation
Fiberglass Manufacture
XVIII Summary of Capital and Operating Cost Effects:
Wool Glass Fiber
XIX Effects on Returns on Investment: Wool Glass Fiber
XX Metric Units Conversion Table
12
13
16
17
18
21
24
33
34
35
36
38
45
47
68
69
71
72
75
97
vn
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SECTION I
CONCLUSIONS
For the purpose of establishing effluent limitations guidelines and
standards of performance, the insulation fiberglass manufacturing
segment of the glass manufacturing category of point sources serves as a
single logical subcategory. Factors such as age, size of plant, process
employed, and waste water constituents and waste control technologies do
not justify further segmentation of the industry.
Presently, 6 of the 19 operating plants are achieving no discharge
of process waste waters to navigable waters. It is concluded that the
remainder of the industry can achieve the requirement as set forth
herein by July lr 1977. The aggregate capital needed for achieving such
limitations and standards by all plants within the industry is estimated
to be about $10 million, assuming that there are presently no treatment
facilities. These cost could increase the capital investment in the
industry 1.2 to 3.8 percent. As a result, the increased costs of
insulation fiberglass to compensate for pollution control requirements
could range from 0.6 to 3.8 percent under present conditions. The
application of achieving such limitations and standards will result in
complete elimination of all toxic substances in the waste waters.
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SECTION II
RECOMMENDATIONS
No discharge of process waste water pollutants to navigable waters
is recommended as the effluent limitations guidelines and standards of
performance for the insulation fiberglass manufacturing segment of the
glass manufacturing category of point sources. This represents the
degree of effluent reduction obtainable by existing point sources
through the application of the best practicable control technology
currently available, and the best available technology economically
achievable. This also represents, for new sources, a standard of
performance providing for the control of the discharge of pollutants
which reflects the greatest degree of effluent reduction achievable
through application of the best available demonstrated control tech-
nology, processes, operating methods or other alternatives.
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SECTION III
INTRODUCTION
Purpose and Authority
Section 301(b) of the Act requires the achievement by not later than
July 1, 1977, of effluent limitations for point sources, other than
publicly owned treatment works, which are based on the application of
the best practicable control technology currently available as defined
by the Administrator pursuant to Section 304(b) of the Act. Section 301
(b) also requires the achievement by not later than July 1, 1983, of
effluent limitations for point sources, other than publicly owned
treatment works, which are based on the application of the best
available technology economically achievable which will result in
reasonable further progress toward the national goal of eliminating the
discharge of all pollutants, as determined in accordance with
regulations issued by the Administrator pursuant to Section 304(b) to
the Act. Section 306 of the Act requires the achievement by new sources
of a Federal standard of performance providing for the control of the
discharge of pollutants which reflects the greatest degree of effluent
reduction which the Administrator determines to be achievable through
the application of the best available demonstrated control technology,
processes, operating methods, or other alternatives, including, where
practicable, a standard permitting no discharge of pollutants.
Section 304(b) of the Act requires the Administrator to publish
within one year of enactment of the Act, regulations providing guide-
lines for effluent limitations setting forth the degree of effluent
reduction attainable through the application of the best practicable
control technology currently available and the degree of effluent reduc-
tion attainable through the application of the best control measures and
practices achievable including treatment techniques, process and
procedure innovations, operation methods and other alternatives. The
regulations proposed herein set forth effluent limitations guidelines
pursuant to Section 304 (b) of the Act for the insulation fiberglass
subcategory of the glass manufacturing category of point sources.
Section 306 of the Act requires the Administrator, within one year
after a category of sources is included in a list published pursuant to
Section 306 (b) (1) (A) of the Act, to propose regulations establishing
Federal standards of performances for new sources within such
categories. The Administrator published in the Federal Register of
January 16, 1973 (38 F.R. 1624), a list of 27 source categories.
Publication of the list constituted announcement of the Administrator's
intention of establishing, under Section 306, standards of performance
applicable to new sources within the insulation fiberglass manufacturing
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subcategory of the glass manufacturing category of point sources, which
was included within the list published January 16, 1973.
Summary of Methods Used for Development of the Effluent Limitations
Guidelines_and Standards of Performance
The effluent limitations guidelines and standards of performance
proposed herein were developed in the following manner. The point
source category was first studied for the purpose of determining whether
separate limitations and standards are appropriate for different
segments within the category. This analysis included a determination of
whether differences in raw material used, product produced,
manufacturing process employed, age, size, waste water constituents and
other factors require development of separate limitations and standards
for different segments of the point source category. The raw waste
characteristics for each such segment were then identified. This
included an analysis of (1) the source flow and volume of water used in
the process employed and the sources of waste and waste waters in the
plant; and (2) the constituents (including thermal) of all waste waters,
including toxic constituents and other constituents which result in
taste, odor, and color in the water or aquatic organisms. The
constitutents of the waste waters which should be subject to effluent
limitations guidelines and standards of performance were identified.
The full range of control and treatment technologies existing within
each segment was identified. This included an identification of each
distinct control and treatment technology, including both in-plant and
end-of-process technologies, which are existent or capable of being
designed for each segment. It also included an identification of, in
terms of the amount of constituents (including thermal) and the
chemical, physical, and biological characteristics of pollutants, the
effluent level resulting from the application of each of the treatment
and control technologies. The problems, limitations and reliability of
each treatment and control technology and the required implementation
time was also identified. In addition, the non-water quality
environmental impact, such as the effects of the application of such
technologies upon other pollution problems, including air, solid waste,
noise and radiation were also identified. The energy requirements of
each control and treatment technology was identified as well as the cost
of the application of such technologies.
The information, as outlined above, was then evaluated in order to
determine what levels of technology constituted the "best practicable
control technology currently available," the "best available technology
economically achievable" and the "best available demonstrated control
technology, processes, operating methods, or other alternatives." In
identifying such technologies, various factors were considered. These
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included the total cost of application of technology in relation to the
effluent reduction benefits to be achieved from such application, the
age of equipment and facilities involved, the process employed, the
engineering aspects of the application of various types of control tech-
niques process changes, non-water quality environmental impact
(including energy requirements) and other factors.
The data on which the above analysis was performed was derived from
EPA permit applications, EPA sampling and inspections, consultant
reports and industry submissions.
General^Description of the Industry
The industry covered by this document is the insulation fiberglass
manufacturing segment of the glass manufacturing source category. It
encompasses a part of the Standard Industrial classification 3296 in
which molten glass is either directly or indirectly made, continuously
fiberized and chemically bonded with phenolic resins into a wool-like
insulating material. The scope of this subcategory also includes those
products generally referred to as insulation fiberglass by the industry,
that are produced by the same equipment and by the same techniques as
thermal insulation. These include, but are not limited to, noise
insulation products, air filters, and bulk wool products. This category
will be referred to as a primary process in contrast to a secondary
operation in which waste textile fiberglass is processed into an
insulation product. Such secondary operations are excluded because of
their textile orgin and the difference in processing techniques.
Insulation fiberglass research and development laboratories are also
excluded in this report, because the range of such research includes
textiles, and a great diversity of experimentation not necessarily
related to insulation products. The term insulation fiberglass is
synonymous to the terms glass wool, fibrous glass, and construction
fiberglass.
The modern fiberglass industry was born in 1935 when the Owens
Illinois Glass company and the Corning Glass Works combined their
research organizations later forming Owens-Corning Fiberglas in 1938.
The original method of producing glass fibers was to allow molten glass
to fall through platinum bushings, forming continuous relatively thick
threads of soft glass. The glass streams are then attenuated (drawn)
into thin fibers by high velocity gas burners or steam. This process
generally referred to as flame attenuation is pictured in Figure I.
In the 1950ts, Owens-Corning Fiberglas and the Cie de St. Gobain
perfected the centrifugal or rotary process. A single stream of molten
glass is fed into a rotating platinum basket which distributes the glass
on an outer rotating cylindrical spinner. The spinner contains a large
number of small holes arranged in rows in the wall. The molten glass is
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FIGURE I
FLAME ATTENUATION PROCESS
FLAME OR STEAM
ATTENUATION
OVERSPRAY
BINDER SPRAY
FURNACE
DOWNWARD DRAFT
OF AIR
MOLTEN GLASS1
STREAM
HOLES
PLATINUM BUSHING
GLASS FIBERS
MAT
WIRE MESH CHAIN OR FLIGHT CONVEYOR
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forced through the holes forming fibers which are then attenuated 90°
from their forming direction by high velocity gas burners, air or steam
as depicted in Figure II. The output of a single spinner may range from
0.23 to O.i»5 metric tons per hour (500-1000 Ib/hr) and up to 5 or 6
spinners are used to feed fiber to one line.
Figure III depicts the basic insulation fiberglass processes. The
flame attenuation and rotary spinning processes have their own
individual merits. The flame attenuated product has greater
longitudinal strength because the fibers are attenuated in the same
direction (away from the gas or steam blower) and the lengths
conseguently align in one direction to give added tensile strength in
that direction. This property results in decreased damage to the
product upon installation. Rotary spun fibers, on the other hand, are
attenuated as they form on the circumference of a rotating disk. The
fiber lengths thus assume random directions as they fall. Standard
building insulation produced by the flame attenuated process generally
uses less fiber (approximately 35%) to achieve the same thermal
properties as rotary spun standard insulation. Since insulation is
priced in accordance to its thermal properties, annual production
ratings and plant capacities measured in kilograms can be somewhat
misrepresentative when comparing the economics of the two processes.
All small plants utilize the flame attentuation process and are
financially better off than an economic impact based on overall
industry, plant capacity would indicate. Rotary forming processes can
produce more uniform fibers. They are also capable of producing huge
tonnages of wool, and for these reasons the rotary process now dominates
the industry.
Borosilicate glasses and low alkali silicate glasses are generally
used in making glass fibers because of their chemical durability. The
surface area to weight ratio of the glass fibers in glass wool products
is so great that even atmospheric moisture could seriously weather
common silicate glass fibers. Table I is a compilation of the uses for
the various types of insulation fiberglass and Table II lists the glass
composition. These tables serve as examples of insulation fiberglass
products. Technological changes brought on by consumer demands has
already made some of these products obsolete. The low thermal
conductivity property of insulation fiberglass is not directly
attributable to the glass, but rather to the ability of the glass fibers
to establish stationary pockets of air. The fiberglass web in which
these pockets are held minimizes heat transfer by air convection
currents and limits it to conduction in air which is a much slower rate.
There are two methods of producing the molten glass (1260-1316°C)
that feeds the fiberizing machine in the forming area. The older method
involves first producing 2.5 cm. (one inch) glass marbles and then
feeding the marbles to a small remelt furnace which in turn feeds the
fiberizer with molten glass. There can be several remelt pots to each
production line. The marbles may either be produced at the plant site
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FIGURE II
ROTARY SPINNING PROCESS
DOWNWARD DRAFT
OF AIR
ATTENUATION
AIR
FURNACE MOLTEN GLASS
STREAM
ASSEMBLY CAN SWING
BACK AND FORTH FOR
EVEN DISTRIBUTION
OF FIBERS
HOOD WALL
SPRAY
NOZZLE
ROTATING SPINNER
HOLE ON
CYLINDRICAL WALL
COATED FIBERS
FALL TO CHAIN
HOOD WALL
OVERSPRAY RING
BINDER SPRAY RING
10
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TABLE II
CHEMICAL COMPOSITIONS OF GLASSES USED TO FORM
COT1ERICAL FIBROUS GLASS (PERCENT) (4)
Type
Al/U CaO " MgO " B_0 "" Na.'O" ~K 0 " ZrO Ti^ PbO Fe
i^32? 2 />
1. Low-alkali, lime-
alumina borosilicate 54.5 14.5 22.0 8.5 0.5
2. Soda-lime boro-
silicate 65.0 4.0 14.0 3.0 5.5 8.5 0.5
3. Soda-lime boro-
silicate 59.0 4.5 16.0 5.5 3.F 'i.O 0.5
4. Soda-line 73.0 2.0 5.5 3.5 16.0
5. Lime-free soda
borosilicate 59.5 5.0 7.0 14.5 4.0 3.0 2.0
13
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or made at. a centrally located plant with a large furnace and shipped to
other plants. The original purpose of this seemingly redundant
procedure is to insure glass uniformity before the fibers are made by
visually inspecting the glass marbles. The mechanical problems caused
by seeds and bubbles are more troublesome in fibers than massive glass
because of the small glass diameters involved. The assurance of better
quality control in the glass making stage, however, has led to the
replacement of the intermediate glass marble process by direct feed
furnaces. Currently only one company operates marble-feed processes for
insulation products, since this company finds it less costly to ship
marbles than to build and maintain glass making furnaces at every small
plant.
Rotary processes are always fed by direct melt furnaces because
rotary spinners have high volume production capabilities which can only
be matched by direct melt furnaces. Furthermore the high cost of a
glass furnace usually necessitates that it be large, which in turn
requires a large plant capacity in order for the operation to be
profitable. Both marble feed and direct melt processes feed flame
attenuation forming processes.
When production changes occur in a direct melt process the molten
glass flow is temporarily diverted from the fiberizers and quenched with
water. The glass immediately solidifies and fractures into fragments
resembling a mixture of sand and aggregate, which is termed cullet. A
major portion of the cullet is collected at the machine in hoppers for
reuse into the melting furnace. If the furnace is not bled by producing
cullet, the lighter components in the molten glass will volatilize and
the composition of the glass will be unpredictably altered. This is not
a problem in the marble-feed process because of the very small volume of
molten glass held in the remelt pots. This problem, along with other
restrictions, requires that direct melt processes be operated 24 hours a
day, all year round.
The quality of water needed for cullet cooling is not critical in
that this water may be reused, with make up water added to compensate
for the water vaporized by contact with the hot glass. It is not
important that the water be cooled, but sufficient suspended solids must
be removed so as to prevent damage to the pumps. Colloidal silica
suspensions are controlled by sufficient blowdown.
After the molten glass is divided into fibers and attenuated, the
fibers are sprayed in mid-air with a phenolic water-soluble binder
(glue) and are forced by a downward air draft onto a conveyor chain. In
many plants the newly formed fibers are oversprayed with water at the
same time that the binder is applied. This overspray serves to cool the
almost molten glass, minimizing both volatilization and early
polymerization of the binder.
14
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The binder is a thermosetting resin composed of a dilute solution of
phenols (resin) and other chemical additives which provide terminal
cross-linking and stability of the finished product. The resin itself
is a complex mixture of methylolphenols in both the monomer and polymer
states. For some products lubricants are applied to the newly formed
fibers singly or in addition to the binder. The lubricant, usually a
mineral oil, is used to minimize skin irritation (fiber abrasion) of
persons handling the insulation. Tables III, IV, and V list the binders
and lubricants used for the various insulation products. The properties
and uses of each product are also listed. These tables serve again as
examples. Rapidly changing technology has led to improved products
since the lists were compiled.
The binder is diluted with two to six times its volume in water
before it is applied to the product. The quality of the dilution water
is important in that it must not contain solids of such size as to plug
the spray nozzles and in that it must not contain sufficient
concentrations of chemicals that would interfere with the curing
properties of the binder. For instance magnesium and calcium found in
hard water are incompatible with the binder.
The fibers fall to the chain where they collect in the desired mass
and depth as required for the ultimate product. The density of the
fiber mass (mat) on the conveyor is controlled by the fiber production
rate and the speed of the conveyor chain. For rotary forming process
the chain speed will range from 127 to 508 linear cm/sec (50-200
ft/min). This mat then proceeds by conveyor through curing (200-260°C)
and cooling ovens, it is compressed, and an appropriate backing
(asbetos, paper, aluminium, etc.) may be applied as a vapor barrier.
The product is then sized and/or rolled and packaged. The cured mat may
instead be shredded to make blowing and pouring wool. This product is
used where existing structures require insulating material that can be
blown or poured into the walls. The thermal properties » however, are
inferior to backed insulation.
The cured phenolic resin imparts a yellow color to the glass wool
which may not be appealing to the customer. Consequently, various
colored dyes are applied to the fiberglass in the binder spray and other
than esthetics do not beneficiate the product.
Two types of chains are employed in the forming area. Flexible wire
mesh conveyor belts were originally used, but many have since been
replaced by flight conveyors. These are hinged steel plates that
contain numerous holes or slits. The air stream which transports the
glass fibers to the conveyor also contains droplets of resinous binder
which have not adhered to the glass fibers. Many of these droplets
deposit resin on the chain, and if not removed, the resin build-up will
eventually restrict passage of the air stream. When the deposit becomes
sufficiently great, insulation fiberglass formation is no longer
possible, necessitating replacement of the conveyor.
15
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TABLE V
FIBROUS GLASS PACKSBASIC FORMS
Product
Fiber Diameter
nun. Nominal
Fiber Diameter,
in.. Nominal
Notes
Bonded packs
(coarse fibers)
Curly wool
0.11
0.15
0.20
2.5
0.029
O.OOU5
0.0060
0.0080
0.100
0.00115
Packs 1/2 and 1 in. thick
water-soluble or insolubl
binders. Used in air
filters, air washers and
as distillation column
packing
Bulk wool - usually lubri
cated. Special uses in
process industries
18
-------
Historically the wire mesh chain has been cleaned while in service
by routing the chain through a shallow pan containing a hot caustic
water solution (refer to Figure IV). Fresh caustic makeup to the pans
created caustic overflow containing phenolic resin and glass fiber.
Another method of chain cleaning uses either fixed position pres-
surized water sprays or rotating water sprays. Unlike the caustic soda
bath processes, the waste waters from this method are amenable to treat-
ment and recirculation. Water spray chain cleaning has replaced caustic
chain cleaning at all but one plant which uses a combination of the two
methods. Although both methods have been used to clean wire mesh
chains, it is impratical to caustic clean flight conveyors. Unlike the
flexible wire mesh chains, the hinged plates of the flight conveyor
cannot be so easily routed through a pan. Furthermore a flight conveyor
is more expensive than a wire mesh chain, and corrosion caused by the
caustic is of greater concern. Spray cleaning has the added advantage
of cooling the forming chain, thereby decreasing both volatilization and
polymerization of the phenolic resin.
Pipe insulation is made in various ways. One principal method in-
volves wrapping uncured insulation about mandrels and curing the bundels
batchwise in ovens. The mandrel is a perforated pipe of the appropriate
dimensions. Caustic is still used by the industry to batch clean
mandrels. However, the volumes involved are much less than those
required for chain washing and are consequently much less of a problem.
Another source of water pollution is hood wash water. The hood is
either a stationary or rotating wall used to maintain the air draft in
the forming area. It is necessary to wash the hood in order to keep any
wool that has agglomerated there from falling onto the chain and causing
nonuniformity of the product.
Insulation fiberglass plants experience both air particulate and
odor problems. Particulate emissions are found in the glass furnace,
forming area, and curing and cooling ovens exhaust gases. The principal
source of odors is volatilized phenols in the curing and cooling ovens
exhaust gases. Several methods, involving both wet and dry processes,
are being investigated in an effort to reduce the air emissions. At the
present time the industry considers air pollution control to be a more
serious problem than water pollution control.
Sales and Growth
The insulation fiberglass industry is a rapidly expanding industry
as evidenced by the fact that the industry is currently at 100 percent
production. Current annual glass wool production is estimated at 0.77
million metric tons (1700 million pounds) per year. Profits before tax
on sales range from about 9 percent to 20 percent with a median of 12
percent. Table VI summarizes recent sales. Supply and demand
projections estimate 8 percent growth per year for the next five years.
This picture may substantially change in light of the recent trend in
fuel conservation, a situation which will create even more demand for
19
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insulation materials. In anticipation of this growth, new plants and
expansions are planned in high demand areas. In addition, the industry
is constantly revamping its plants utilizing the latest technology to
obtain more and a better product. Major changes are made at times of
furnace rebuilding, normally about every five years. Although the
industry may operate in old plants, it operates new processes.
The principal federal government influence on demand is brought
about through changes or modifications in building code requirements.
Such a change took place recently when the Department of Housing and
Urban Development, Federal Housing Administration, revised the Minimum
Property Standards for multi-family and single-family housing in order
to fulfill the Department's commitments to the National Energy
Conservation policy. The revision, which took effect in July 1971 for
single-family construction and in June 1972 for multi-family
construction, went into effect immediately for all mortgage insurance
projects for which a letter of feasilbility has not been issued and for
low rent public housing projects for which a program reservation has not
been issued. This implementation will definitely provide more
economical operating costs for the heating and cooling of residential
units and will also conserve the nation's energy resources.
The major uses for glass wool are wall insulation, roof decking,
acoustical tile, pipe insulation, ventilation ducts, and appliance and
equipment insulation. In the areas of residential insulation and
acoustical tile, fiberglass has largely replaced its competition (e.g.
mineral wool, perlite, urethane, wool fiberboard, Tectum, lightweight
concrete or gypsum, foam glass, and ceramic insulation) because of the
combined properties of low cost, light weight, low thermal conductivity,
and fire resistance. In the residential insulation sector, fiberglass
products have an estimated 90 percent of the market. The principal
competition for non-residential uses are urethane, styrene, and calcium
silicate. Due to the greater competition fiberglass products have only
a relatively small share of this market.
An estimated breakdown of products for the year 1971 is given below.
As seen Batt insulation (standard building insulation) is the principal
product averaging 67 percent of total production.
ESTIMATE OF U.S. CONSUMPTION OF
WOOL GLASS FIBER, 1971
Batt Insulation t»50 1000
Acoustic Tiles 11 90
Board Insulation 80 175
Pipe, Appliance and Equipment 75 165
Miscellaneous 40 89
TOTAL 686 Thousand metric 1519 Million 1
tons
22
-------
At present only three companies produce fiberglass insulation. The
nineteen existing plants and the estimated production by their parent
companies are listed in Table VII. Figure V is a production size
distribution graph of these plants. Because a high volume production
is necessary and the glass fiber operation is difficult to scale downr
there are no very small plants when compared to other industries. The
smallest plant produces 2270 metric tons (5 million pounds) of specialty
products per year.
23
-------
TABLE VII
INSULATION FIBERGLASS PLANTS
Owens-Corning
Fiberglas Inc.
Approximate Percent of
Industry Production
77
Johns-Manville
10
Certain-Teed
St. Gobain
13
Plant Locations
Barrington, NJ
Fairburn, GA
Kansas City, KS
Newark, OH
Santa Clara, CA
Waxahachie, TX
Cleburne, TX
Corona, CA
Defiance, OH (3)
Parkersburg, WVA
Penbyrn, NJ
Richmond, IN
Winder, GA
Berlin, NJ
Kansas City, KS
Mountaintop, PA
Shelbyville, IN
(recently purchased
from PPG, Industries)
24
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SECTION IV
INDUSTRY CATEGORIZATION
Introduction
In developing effluent limitations guidelines and standards of
performance for new sources for a given industry, a judgment must be
made by EPA as to whether effluent limitations and standards are
appropriate for different segments (subcategories) within the industry.
The factors considered in determining whether such subcategories are
justified for the insulation fiberglass manufacturing segment of the
glass manufacturing category of point sources are:
1. Wastes Generated
2. Treatability of Waste Waters
3. Manufacturing Process
4. Chain Cleaning Process
5. Plant Size
6. Plant Age
7. Raw Materials
8. Product
9. Air Pollution Control Equipment
For the purposes of this report the insulation fiberglass
manufacturing segment consists of primary plants in which molten glass
is either directly or indirectly made, continuously fiberized and
chemically bonded with phenolic resins into a wool-like insulating
material. As the result of an intensive literature search, plant
inspections, and communications with the industry, it is the judgment of
this Agency that the primary insulation fiberglass industry should be
considered as a single subcategory. Not included are secondary plants
which process waste, textile fiberglass and research and development
facilities.
27
-------
Factors Considered
1. Waste Generated
From evaluation of the available data it is concluded that the types
of wastes generated in producing insulation fiberglass such as suspended
solids, dissolved solids, phenols, and oxygen demanding substances are
common to all such plants. The only exceptions are dyes and water
treatment backwashes. The former parameter presents no problem in so
far as quality of recycled water. The quality of water treatment
backwashes varies considerably among the industry depending upon the
intake water quality. The principal factor of concern to the industry
is water hardness which will inhibit the bonding properties of the
phenolic resins. The generally similar nature of the wastes generated
in insulation fiberglass production indicate that the industry should be
considered as a single subcategory.
2. Treatability of Waste Waters
From discussions with the industry and from plant inspections it was
concluded that in a recycle system for a insulation fiberglass plant
only three basic parameters in the process water affect its
treatability, suspended solids, dissolved solids, and pH. The recycled
waters can be adequately treated for reuse by coarse filtration, pH
control (if necessary), and fine filtration or coagulation - settling.
Sufficient blowdown as can be handled as overspray or binder dilution
water is needed to check the buildup of dissolved solids. Through
proper design of the treatment system there should be no forseeable
reason other than plant expansion that these basic systems need to
altered in order to accommodate varying waste load characteristics.
Therefore treatability of waste water factors indicate that all
insulation fiberglass plants fit into a single subcategory.
3. Manufacturing Process
As described in Section III of this document, there are two types of
glass fiber forming processes, flame attenuation and rotary. Both
processes are dry, and since the products are the same water quality is
not affected.
U. Chain Cleaning Process
As described in Section III, there are also two basic methods for
cleaning the forming chain of the glass fibers and phenolic resins. One
method consists of dragging the wire mesh chain, on its return path to
the forming area, through a hot caustic bath. The second method
consists of spraying the wire mesh chain or flight conveyor with high
velocity water.
28
-------
The resultant wastes from caustic cleaning are extremely difficult
to treat and unless considerable dilution is provided, the wastes are
not suitable for recycling. The principle reason for this is that the
only practical sink for the waste waters in a completely closed system
is for overspray and binder dilution, and that unless diluted, the
caustics are incompatible with phenolic resins. The blowdown from spray
washing is amenable to treatment and recycle.
Two subcategories therefore would seem appropriate. However, at the
present time only one plant employs caustic chain washing. The
remainder of the industry has switched to spray washing and has future
plans to employ only spray washing equipment. The one existing plant
that uses caustic baths does so in conjunction with spray washing
equipment and it is not necessary in this case to blowdown from the
caustic bath. The carryover caustic on the chain is so diluted by the
wash water volumes that no problems are anticipated in the recycle
system.
For these reasons the industry cannot be meaningfully subcategorized
according to chain cleaning techniques.
5. Plant Size
It has been determined from the data (Tables X and XI) and from
inspections that despite the wide range in plant capacities, plant size
has no effect upon the quality of waste waters. Plant size does affect
the costs of installing total recycle systems because of the effect of
plant size on the volume of water used. In the economic analysis of
Section VIII it is concluded that the cost of recycle per unit
production will increase as much as three fold for plants producing less
than 9000 metric tons per year. However, plants of this size usually
produce specialty products (e.g. pipe insulation) which command a higher
price per unit weight than standard residential insulation. This factor
will minimize the financial impact for the smaller plants. Therefore
subcategorization of according to plant size is not indicated.
6. Plant age
Glass wool plants span an age of from 2 years to more than 25 years
since plant start up. About 30 percent of the plants are 10-15 years
old while 25 percent are less than 10 years old. All plants that are at
least 5 years old have undergone considerable upgrading of the
production processes and in many cases facilities have been expanded
with installation of state of the art processes. Waste water
characteristics are therefore similar for plants despite any difference
in age. Except for old plants of large capacity, plant age should not
significantly affect costs of installing the facilities. In large old
plants space limitations and major pipe relocations will increase the
29
-------
capital costs. However, the capital cost of recycled water is lowest
for large plants and this will help compensate for the increased
installation costs. Hence, plant age is not an appropriate basis for
subcategorization.
7. Raw Materials
The raw materials required for wool glass are much the same as for
standard massive glass, 55-73 percent silica and 27-15 percent fluxing
oxides (e.g. limestone and borates). The compositions of typical
glasses are listed in Tables I. Once the glass is made either as fibers
or cullet, it is for all practical purposes inert in water, and thus
will not chemically affect waste water quality.
The type of resin used, however, will exert some influence on both
air and water quality. The industry is continually formulating new
binder mixtures in an effort to minimize problems. However, the
industry can not be meaningfully subcategorized according to type of
binder used for the following reasons. Different products can require
different binder formulations, and these products can be made at
different times on the same line. Composition changes in the binder can
occur at any time, as the industry tries to improve the product and
decrease raw material costs. No matter what formulation of resin is
used, the general waste characteristics are the same and a chemical -
physical treatment system will not be affected.
8. Product
The type of product made will affect the chain wash water quality in
that different products may require different resin formulations.
However, for the same reasons given in the paragraph above, the industry
cannot be meaningfully subcategorized on this topic.
9. Air Pollution Control Equipment
The type of system used to control air pollution will definitely
affect the water treatment scheme. In plants where dry air pollution
control equipment is adequate, high pressure, low volume chain sprays
are feasible, easing the water treatment problem. Evaluation of the
economics in Section VIII indicates that the cost differences of the
water treatment systems as they apply to air emissions control system
are not a factor.
At this time contaminated scrubber water is being accommondated by
process water total recycle systems, and it is not necessary to
subcategorize according to methods of air pollution control.
30
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SECTION V
WASTE CHARACTERIZATION
Waste. Watgr Constituent Analysis
A general water flow diagram for an insulation fiberglass plant is
pictured in Figure VI. Non process waters identified in this diagram
include boiler blowdown and water treatment backwashes. Those
parameters that are likely to be found in significant quantities in each
of the waste streams are listed in Table VIII. A more detailed analysis
of each waste flow (i.e. concentration ranges) is not possible since the
combined waste stream only has been of interest to the industry from
whom most of the data was obtained. The principal process waste streams
within the process are the chain cleaning water and water sprays used on
the exiting forming air.
The principal uses for steam are for building heating and steam
attenuation. In the latter case the industry has been converting to
compressed air attenuation. The accompanying boiler blowdown in this
case is replaced by non-contact cooling water for air compressors.
Flow Rate Analysis
Water usages vary significantly between plants. Factors such as
design of furnace, method of chain cleaning and method of air emissions
control will affect quantities of water. For example, plants at which
marbles are remelted require very little furnace cooling water, since
the remelt furnaces are small melting pots. Large continuous drawing
furnaces, however, need large quantities of water to control oven
temperatures and to protect the furnace bricks. Table IX lists chain
wash water flows for plants of various sizes. Again there is no
correlation between plant size and water usage for chain washing,
because each of the three insulation fiberglass producers uses chain
wash water at different pressures and therefore at different flow rates.
Raw, Waste Loads
Table X summarizes the raw waste concentrations for several plants.
Although the numbers are not completely comparable because of treatment
differences and different blowdown percentages, the table nevertheless
shows a wide variance in waste water composition. Other factors
affecting the raw waste load include binder composition, chain
temperature, and other thermal and time factors affecting the rate of
resin polymerization. Annual raw waste loads in metric tons are
computed in Table XI. The values are based upon an average of five
parmaeters at four plants.
31
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TABLE IX
CHAIN WASH WATER USAGE
Plant Plant Size1
Thousands of Million pounds
Metric Tons per year
Per Year
1 All production figures are estimates.
Water Usage
Chain Sprays
liters/sec.
gpm
A
B
C
D
E
F
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120
34
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75
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TABLE XI
ANNUAL RAW WASTE LOADS
Plant Estimated Size
(1000 metric
tons per yr.)
Kilograms Pollutant Per Metric Ton Product
Suspended Dissolved
Phenol
Solids
BODC
COD
Solids
A
E
H
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Average
Annual Raw
120
18
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131
Waste Load
0.36
0.06
0.90
0.33
0.41
316
1.29
4.45
0.40
5.60
2.90
2240
1.67 11.0
8.90 31.5
8.1
6.65 24.2
4.40 18.7
3390 14,400
18.0
14.1
16.0
12,300
(Metric tons per yr.)
Derived by multiplying kg/metric ton by 771,000 metric tons product
per year by 1/1000 metric ton per kg.
36
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One particular waste stream addressed by this report is cullet
cooling water. Suspended solids concentrations are extremely variable
and depend upon how many fiberizers are being by-passed. Concentrations
in the waste water can range from a few hundred to tens of thousands
mg/1 even after settling. A size distribution study of the suspended
solids resulting from cullet cooling appears in Table XII.
As seen from this table 99.50 percent of the cullet should be amenable
to primary settling. However, especially at high cullet producing
times, an appreciable amount of minus 100 mesh glass particles can
remain suspended in the waste water. Visual inspections at some plants
noted cullet scattered about the river banks below discharges of cullet
cooling water.
Summary
In summary, water usage and raw waste loads are not relatable in a
practical manner to production levels or techniques. Of the nineteen
existing plants, there may be as many different formulas for relating
these factors. There are significant differences between plants even
within the same company. A compensating factor, however, is the fact
that all such wastes are amenable to the same general type of chemical
and/or physical treatment.
37
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TABLE XII
SIEVE ANALYSIS
ON WASTE GULLET WATER
um Equivalent
297
149
105
74
44
37
% By Weight
Retained
98.30
1.20
0.30
0.05
0.01
0.05
0.09
U.S. Sieve Number
50
100
140
200
325
400
Finer Passed
100.00%
38
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SECTION VI
POLLUTANT PARAMETERS
Selected Parameters
Upon review of the Corps of Engineers Permit Applications for
discharge of waste waters from insulation fiberglass plants, EPA data,
industry data, and observations made during EPA plant inspections the
following chemical, physical, and biological properties or constitutents
are found within the process wastewater effluent.
Phenols
BOD5
Dissolved Solids
Total Suspended Solids
Oil and Grease
Ammonia
PH
Color
Turbidity
Temperature (Waste heat)
Specific Conductance
Phenols
The basic constituents of the binder are phenol, formaldehyde, urea, and
ammonia which react to form various mono and poly methylol phenols.
Therefore, free phenols will always occur in any water that has contact
with uncured resin. Phenol concentrations range from 4 mg/1 in once
through process waters to several hundred mg/1 in recycled waters. In
the case of the higher concentrations, these consist of colloidal
suspensions of resins in a partially polymerized state. However, as
some companies have found, a significant portion of the total phenols
also occur in a free state.
Phenols have exhibited toxic or damaging effects to fish at
concentrations of 1 mg/1. The threshold concentrations for taste or
odor have been cited to be as low as 0.010 mg/1 and 0.00001 mg/1 in
unchlorinated and chlorinated waters respectively. For these reasons
the united states Public Health service (USPHS) has limited phenols to
0.001 mg/1 in drinking water.
Biochemical Oxygen Demand /5 day^
Because of the nature of the organic compounds used in the binder, a
BOD5 will exist. Values range from 156 mg/1 to 7,800 mg/1, with the
39
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higher values again representing recycled waters. Data from one indus-
trial biological treatment plant show that this constituent is easily
treatable. Industrial wastes with a high BOD5 have caused serious
oxygen depletion problems in streams with a relatively low assimilative
capacity.
Chemical Oxygen Demand
For the same reasons as given above, a sizeable chemical oxygen
demand will exist in the raw waste stream. Values range from 3290 mg/1
to 43,603 mg/1, the higher values occurring in recycled waters. A 94
percent reduction was accomplished by an activated sludge plant, but the
resultant levels in the effluent were still high (300 mg/1). Under the
proper conditions, waste waters with a high COD can cause oxygen
depletion conditions in the receiving waters.
Dissolved Solids
Dissolved (filtrable) organics and super-fine colloidal organics,
that are classified as being filtrable according to Standard_Methods
(12), will increase the background dissolved solids concentrations
significantly as a result of chain washing and wet air pollution
control. Net increases of 200 mg/1 to gross concentrations of U0,000
mg/1 are noted. A closed water cycle will significantly raise the level
of this parameter.
Dissolved solids concentrations as low as 50 mg/1 are harmful to
some industrial operations. The USPHS has set a standard of 500 mg/1 if
more suitable supplies are, or can be made, available. This limit was
set primarily on the basis of taste thresholds. Limiting concentrations
of dissolved solids for fresh water fish may range from 5,000 to 10,000
mg/1. Concentrations exceeding 2,100 mg/1 in irrigation waters have
proved to be harmful to crops.
Total Suspended solids
Conglomerated glass fibers and partially polymerized resins will
appear as suspended solids in the chain wash water. Values have been
reported to be as high as 770 mg/1 in untreated waste waters.
Suspended solids may kill fish and shellfish by causing abrasive
injuries, by clogging the gills and respirating passages of various
aquatic fauna; and by blanketing the stream bottom, killing eggs, young
and food organisms, and destroying spawning beds. Indirectly, suspended
soldis are inimical to aquatic life because they screen out light and
because, by carrying down and trapping bacteria and decomposing organic
wastes on the bottom, they promote and maintain the development of
noxious conditions and oxygen depletion, killing fish, shellfish and
fish food organisms, and reducing the recreational value of the water.
40
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Oil and Grease
Mineral oils are frequently added to the binder to alleviate
abrasion problems. The amounts of lubricant used are proprietary
information but relatively small. Slight oil sheens have been noted in
the waste streams of some plants during inspections. Values for final
effluents range from 7.5 mg/1 to 140 mg/1.
Oil and grease has demonstrated deleterious effects upon domestic
water supplies and toxicity towards fish. This parameter is also
esthetically undesirable.
Ammonia
Ammonia is sometimes added to the binder for stabilization purposes.
The rate of binder polymerization is decreased by an increasing pH.
Ammonia can also added to the chain wash water to inhibit polymerization
in order to minimize screen and filter plugging. Ammonia concentrations
in effluents range from 0.6 mg/1 to 4.83 mg/1.
The toxicity of ammonia to aquatic life increases markedly with
increasing pH. Untreated wastes from insulation fiberglass
manufacturing operations frequently have a pH greater than 9, which can
increase the toxic level of ammonia. Concentrations of ammonia as low
as 0.3 mg/1 have exhibited deleterious affects on fish.
ES
As previously mentioned the binder polymerization reaction is pH
dependent. Unless neutralization is practiced, waste water from an
insulation fiberglass plant will be alkaline with a pH greater than 9.0.
Not only is the hydrogen ion a potential pollutant in itself, it can
also affect the toxicity of other substances, such as ammonia. The
permissible range of pH for fish depends upon many factors such as
temperature, dissolved oxygen, prior acclimatization, and the content of
various anions and cations, but is estimated to be from 6.0 to 8.5 under
normal conditions.
Color
Color will result from both the polymerized resin (yellow to brown)
and any dye that is added to the product in the binder spray. Colored
waste streams have been seen at nearly all the plants inspected. It is
especially noticeable at plants with process water recirculation
systems. Color of itself is considered undesirable for esthetic
reasons.
41
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Turbidity
Turbidity is a measure of the light absorbing properties of the
constitutents in water. For an insulation fiberglass plant these result
from colloidal suspensions and from dyes. Values range from 55 to 200
Jackson Turbidity Units for once through waters.
Excessive turbidity in water interfers with the penetration of light
and inhibits photosynthesis, thereby decreasing the primary productivity
upon which the fish-food organisms depend. Turbidity makes it difficult
for fish to find food. It can modify the temperature distribution in
water bodies, lowering bottom temperatures and bottom productivity.
Temperature
Since high temperatures are required to make molten glass (2700°F.),
thermal increases in contact and non-contact waters will be noted.
Higher temperatures decrease the solubility of dissolved oxygen in
water, increase the metabolism of fish increasing their demand for
oxygen, increase the toxic effects of many substances, favor the growth
of sewage fungus and the putrefaction of sludge, and exhibit direct
toxic affects on fish.
Specific Conductance
Specific conductance is a measure of the capacity of water to
convey an electric current. This property is related to the total
concentration of ionized substances in the water and the water tem-
perature. Thus in the absence of a large amount of colloidal solids
that are analytically classified as dissolved (filtrate), specific con-
ductance will be proportional to the total dissolved solids
concentration. For qualitative measurements this is a quick and
practical method of monitoring dissolved solids.
Specific conductance is related to osmotic pressure which, when
sufficiently high, can draw water from fish gills and other delicate
organs. Good mixed fish fauna are not usually found in waters with a
specific conductance greater than 2000 micro-mhos.
42
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SECTION VII
CONTROL AND TREATMENT TECHNOLOGY
Historical Treatment
In only one insulation fiberglass plant has secondary or more
advanced treatment been applied to an effluent. Historically plants
have discharged their waste streams to publicly owned treatment works.
Use of biological end-of-pipe treatment for phenolic waste waters was
attempted at Plant A. The treatment scheme (Figure VII) consisted of
equalization, alum coagulation, nutrient addition, temperature control,
extended aeration, post chlorination, aerobic sludge digestion, and
vacuum filtration. It is noteworthy that the recirculation of chain
wash waters was practiced thirteen years ago at this plant and that only
blowdown from this recycled water received biological treatment. Table
XIII summarizes the performance of the system. Despite the percent
removal efficiencies of the treatment system, objectionable
concentrations of phenol and COD were still discharged, in addition the
parameter of color received no treatment other than dilution. The
company researched use of activated carbon absorption in an effort to
remove the dye and the remaining phenol and COD in the effluent.
However, this approach proved more costly than total recycle of process
waters.
The only parameter that may interfer with a biological publicly
owned treatment works is phenol. Only certain strains of microorganisms
effectively remove phenols from waste waters and their effectiveness is
confined to low concentration ranges. Therefore, if sufficient dilution
water is not present, wide variations of phenol in the raw waste load,
due to process changes, may adversely affect the populations of these
organisms.
State of the Art Treatment Technology
The industry already has long realized that recirculation of chain
wash water is feasible and that a blowdown is necessary to control the
buildup of solids in the system. The industry also recognizes that
suitable treatment of the blowdown for reuse as overspray or binder
dilution water is less costly than performing advanced treatment to a
final effluent. In the total recirculation scheme the contaminants in
the blowdown essentially go onto the product as the binder and overspray
waters evaporate from the hot fiberglass. There has been no noticeable
affect on product quality due to the small addition of these extra
solids on the fiberglass. As an alternate method of blowdown disposal,
some plants because of favorable climatic conditions and space
availability have employed evaporation ponds.
43
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FIGURE VII
BIOLOGICAL TREATMENT AT PLANT A
WAS
SLUE
A
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SLUI
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JRN
DGE
*
WA
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Table XIII
Biological Treatment System
at
Plant A
Parameter
Phenol
Suspended Solids
COD
BODS
Flow was 0.57 million liters per day
Raw Waste
mg/1
212
769
6532
991
Final Effluent
mg/1
1.48
27
298
19.8
Percent
Removal
99.3
92.0
94.4
97.7
45
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The amount of water necessary to effectively clean the chain can be
reduced by use of increased water pressures. However, sufficient
concentrations of suspended and dissolved solids can in turn limit this
pressure due to problems of increased pump maintenance and spray nozzle
clogging. Since the dissolved solids concentration in the chain wash
system is determined by the blowdown rate and degree of resin
polymerization it is the more difficult of the two parameters to
control. The need to eliminate waste streams other than chain wash
water by use as overspray or binder dilution will limit the blowdown
rate of the recirculation chain wash system. This in turn will effect a
steady state concentration of solids in the system which limits the wash
water pressure.
The above methods constitute the current "state of the art treatment
technology11 employed by the industry. Table XIV lists the water
pollution abatement status of all existing primary plants. In summary
the table shows that 3 plants completely recycle all process waters.
Another does the same except for cullet cooling water. Four plants
recycle with three blowing down to evaporation ponds and the fourth to a
spray field. Four plants recycle and discharge blowdown to publicly
owned treatment works. Five discharge once through waters to such
works. Six plants have plans for complete recirculation of process or
all wastes streams.
All three insulation fiberglass producers operate plants in which
process water is recirculated and in which blowdown is used as overspray
or binder dilution. Thus the entire industry has the technology to
apply the "state of the art treatment technology".
Detailed descriptions of those plants that are currently practicing
this technology follow. The plants described cover the entire range of
types of plants: new and old; small, medium and large; flame
attenuation and rotary spinning processes. The examples also illustrate
how air pollution abatement methods can affect the water system.
It should be noted that technology transfer of specific items
between plants is not always possible. This is especially true when
comparing rotary and flame attenuation processes, which have widely
different glass, binder, and air flow rates. This does not affect the
conclusions that total process water recycle is practicable for all
plants.
46
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TABLE XIV
WATER POLLUTION ABATEMENT STATUS OF EXISTING
PRIMARY INSULATION FIBERGLASS PLANTS
Plant status
A Complete recirculation of process waters. Some indirect cooling
water from an experimental air emissions control device discharged
to stream
B Complete recirculation
C Discharge once-through waters to POTW.1 Plans for recirculation
D Complete recirculation except for discharge of cullet cooling
water
E Complete recirculation of phenolic wastes by 5-1-73. Other
wastes to POTW
F Complete recirculation
G Completely recycle phenolic waters. Caustics and other waters to
POTW
H Recycle with blowdown to POTW, cooling waters to river. Plans for
complete recirculation
I Discharge once-through waters to POTW. Recycles cullet water. Plans
for complete recirculation
J Recycle on 1 line. Other lines discharge to river
K Recycle with blowdown to evaporation pond
L Evaporate wastes in pond
M Discharge once-through water to POTW. Plans for recirculation
N Wastes used for spray irrigation
O Discharge to POTW
P Recycle with blowdown to evaporation seepage ponds
Q Discharge once-through waters to POTW. Plans for recirculation
R Discharge one-through waters to POTW. Plans for recirculation
S Recycle with blowdown to POTW
POTW - Publicly Owned Treatment Works
47
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Plant A
This plant was built in 1956 and currently has a production capacity
of 120,000 metric tons (270 million pounds) per year. Four rotary lines
are fed by direct melt, gas fueled furnaces and employ flight conveyors
in the forming area. The plant produces standard building insulation,
acoustical ceiling board, pipe insulation, and blowing wool.
Efforts to close the water system have been undertaken for the past
thirteen years. The plant has been operating a complete closed circuit
process water loop for the past three years, but is continuing to
research more effective and economic ways of internally treating the
waste waters for reuse. Figure VIII depicts the present system.
The company considers the crucial point in this water system to be
the huge amounts of heated air, that when drawn through the forming area
become saturated with water from the chain wash and air scrubber system.
The plant has a 1.5 percent blowdown of dirty water which stabilizes the
total solids concentration within the system to between one and two per-
cent. Phenol cencentrations range between 200 to 500 mg/1 within the
system.
The plant is currently operating stationary chain sprays at 21
atmospheres absolute pressure using recycled water. Clean water is used
at between 135 and 20** atmospheres when the resin buildup is
particularly bad. This flow is estimated to average 0.6 I/sec (10 gpm)
and to occur over a period of 10 minutes each shift. The dirty water
sprays use 19 I/sec (300 gpm) per machine. This plant operates its
water systems at a higher total solids concentration than other plants
and must therefore use less powerful pumps in order to protect them from
severly erosive conditons.
As seen from Figure VIII, the system consists of directly recycling
screened chain wash water, periodic blowdown for binder dilution water,
and chemical treatment of additional blowdown before being returned to
the recycle water system. Since a very low percentage blowdown exists,
the plant must thoroughly treat a large portion of the process water
before recycling it. The company originally employed flocculation and
clarification to remove dissolved organics and suspended solids, but has
recently discontinued flocculation without harmful effects to the
manufacturing process. Sludge from the treatment systems is landfilled.
The company considers the use of recycle water as overspray to be
neither practicable nor desirable from an air emmissions standpoint.
The probable reason is the relatively high concentration of contaminants
in the recycle water when compared to those plants that do recycle water
as overspray.
48
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49
-------
Like the rest of the industry this plant is dissatisfied with the
performance and maintenance requirements of diatomaceous earth filters
and is investigating alternate treatment methods such as paper filters
and cyclones.
A considerable amount of cullet is produced. The cullet quench water
system is a separate recirculation system with blowdown to the
flocculation treatment system. The indirect furnace cooling water
system is also closed. Blowdown from this system goes to the
flocculation system. Chromates are used in the cooling waters for
corrosion control but are retained in the closed water system.
Caustic mandrel cleaning for the pipe insulation manufacturing process
is performed at this plant. However, the volumes of caustic blowdown
are such that they can be put into the wash water recirculation system
without causing noticeable problems.
Air has replaced steam in the forming process thus reducing the
demand for softened waters. The only water required for air attenuation
is for indirect cooling of the air compressors.
The majority of water used in the plant is for particulate air
pollution control of the forming air. This water is also used as chain
wash water. The company is therefore concerned that future regulations
which may require changes in air pollution control equipment will affect
the wash water system.
A pilot dehumidification system is used on the forming air of one
line to control odor. Contact cooling water is recycled with the
blowdown going to the chain wash water system. Noncontact once through
cooling water for the dehumidification system is discharged to a small
stream behind the plant. The only contaminant in this discharge is
thermal, as the temperature is estimated between 31 and 40 degrees
Centigrade, At present this is the only plant within the industry
employing a dehumidification system.
One of the more effective techniques to curb odor problems at this
plant has been to change binder compositions to inhibit phenol
volatilization in the hot forming area. However, whenever this is done
the wash water quality must be re-evaluated to insure its compatability
with the new binder. The company expressed concern that future air
pollution abatement requirements will further complicate the wash water
system, but at this time they see no reasons why the system cannot
remain a total recirculation system.
No treatment problems can be foreseen at this and all the other
plant due to start-up or shut down. This does not preclude the
50
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possibility of temporary plant shutdown due to process upsets or
treatment system problems.
51
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Plant B
This plant best represents how a new plant can avoid air and water
treatment problems through proper design before the plant is built. The
plant was completed in June of 1971, and with only two lines has a
capacity of 34,800 metric tons (75 million pounds) per year. The plant
employs rotary spinners that are fed by cold, top feed electric melt
furnaces. This technique has the advantage of virtually eliminating the
air emissions encountered by conventional gas fired furnaces. The
electricity costs are three times that of gas. However, the total costs
are about the same since the electrodes are positioned at the bottom of
the furnace and require but one-third the energy to melt the same amount
of raw materials. Gas fired furnaces have their burners less
efficiently positioned in the furnace walls. Only standard building
insulation is produced at this plant.
Figure IX is a schematic diagram of the plant operations, and Figure
X is a detailed water flow diagram. As it can be seen the process is
virtually identical to that at Plant A. However flocculation, using
Benonite clay and a polymer, and diatomite filtration are still
employed, and since the air and water treatment systems operate both
efficiently and economically, there are no plans to alter the system.
As long as the total solids concentration can be held below two percent,
the recycle system will function properly.
52
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Plant D
This plant is currently experiencing the most difficult problems
within the industry in maintaining a completely closed cycle water
system, and as such serves as an example that, with even minimal
internal waste water treatment, a closed water loop can be operated. In
1965 the plant was bought from a company who also produced fiberglass.
The structure was built in 1961. In September 1970 the company was
given a cease and desist order by the State Water Pollution Control
Board and since that time has operated the system shown in Figure XI.
The plant is medium sized (32,000 metric tons per year) and produces
only standard building insulation. There are two lines employing rotary
spinners and direct melt, gas fueled furnaces.
At the heart of the treatment system there are two 25,000 liter
(6500 gallon) sumps, one for each line. The wash water passes through
40 mesh screens and receives approximately five minutes retention time
in the sumps before the water is again used to clean the flight
conveyor. A pressure of 7 atmospheres is used to clean the flight
conveyors.
A small amount of water is pumped from the sumps to two 38,000 liter
(10,000 gallon) tanks for additional settling. Sludge is then pumped to
a 19,000 liter (5,000 gallon) tank to hold until it is hauled away to a
landfill. The plant is able to keep the total solids in as little
control that exists by blowing down 98,000 and 57,000 liters (26,000 and
15,000 gallons) per day respectively as overspray and binder dilution
water.
Because the preliminary screening is inadequate and the water in the
sump is constantly stirred up due to the short retention time, quite a
bit of foaming occurs. So much foaming occurs that a half resin, half
fiber mass eventually floats and hardens to a depth of about two feet,
necessitating "digging out" the sumps once a week. While this is being
done, both lines must be shut down for a period of 10 to 12 hours. In
addition the flight conveyors must also be blasted with crushed walnut
shells to free them of polymerized resin. Walnut shells are used to
minimize chain wear. Despite the lost time in production and high
maintenance costs, the plant is still able to make some profit.
By the autumn of 1973 automatic, chain driven scrappers will be
installed in both sumps and the existing screens will be repositioned
for easier access to the sumps. In addition a portion of the recycled
water will be treated by flocculation much like plants A and B.
However, it is not known at this time what percentage of the recycled
water flow .will be so treated, and it is conceivable that this will be
as high as 100 percent. The plant expects to profit from the
installation of the treatment facilities since increased production will
offset the cost of the wast treatment.
55
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Because the recycled water currently has a total solids
concentration of 4 percent (ninety percent of which are dissolved
organics) the air wet scrubbers employing recycled water are
ineffective. Like other plants, it is estimated that the total solids
should be less than two percent in order to keep these water and air
systems in control.
Except for cullet cooling water all waste waters are sent to the
sumps. The former is discharged to a stream without adequate treatment.
Since the plant has gone to total recycle, trout have reportedly
reappeared downstream. A successful fish farm reportedly is also
operating downstream of the plant.
57
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Plant E
A recirculation system is expected to be installed at this plant by
May 1, 1973. It is medium sized having a capacity of 18,200 metric tons
(41 million pounds) per year. There are four flame attenuated lines,
one rotary spun line, and one line which uses textile fiberglass wastes
as a raw material. Standard building insulation is produced by five
primary lines that are fed by gas fueled, direct melt furnaces. The
plant was purchased in 1952, but the original structure is considerably
older.
The water flow diagram for this plant appears as Figure XII. As
seen, the recycle technique differs considerably from that employed at
Plants A and B. Except for the blowdown treatment system, the
recirculation system has been successfully in operation since May 1972.
Wire mesh chains are used in the forming area of the flame
attenuated lines. The plant employs a combination of both hot caustic
washing and 1U atmospheres pressure water spray washing of the wire mesh
chains (refer to Figure XIII). The only blowdown from the caustic bath
occurs as carryover water on the chain which is then washed by the spray
wash water system. Attempts to get away from using caustic have so far
not succeeded, but the amount of caustic entering the system does not
interfer with the binder because of the sizable dilution of wash water.
The rotary spinning line employs a flight conveyor cleaned only by a
rotating water spray. The waste textile line is a dry process.
Although drop out boxes are used with water sprays for the exiting
forming air, considerably less water is used than for plants A and B.
Sufficient suspended solids are removed by the Hydrasieves and
sufficient blowdown occurs so that this plant does not need to treat the
recycled water by floccualtion and coagulation as do Plants A and B.
The blowdown treatment system consists of pH adjustment,
coagulation, settling and vacuum filtration. The treated water then is
used as resin dilution water.
Sludge and backwash from lime softening, cooling tower blowdown and
boiler blowdown is directed to a lagoon for settling. Overflow is
neutralized with sulfuric acid and discharged to a municipal sanitary
sewer. Gullet cooling water is directed to the same lagoon and is
discharged to a sanitary sewer.
58
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Plant F
This plant best illustrates how with minimization of water usage,
most problems of the general recirculation model can be avoided. The
plant was built in 1969 with two standard insulation lines employing
marble fed, flame attenuation processes. The addition of two similar
lines in 1972 has boosted the plant from small to medium size. Current
production is 15,900 metric tons (35 million pounds) per year. Since
the plant was built, it has successfully maintained the total recycle
system depicted in Figure XIV.
The principal reason for the reliability of the system is that
approximately eight percent of the process water flow is continually
blown down. This condition is able to be attained by use of low volume,
high pressure (69 atmospheres), rotating, chain (wire mesh) water
sprays. The only other water usage within the system is to flush out
the dirty water pit. The blowdown, 2 I/sec (30 gpm), is consumed in the
process as overspray.
In order to protect the pumps and spray nozzles, suspended solids
are removed from the recycled water by vibrating screens, diatomaceous
earth filters, and fiberglass filters operated in series. With the com-
bination of water treatment and high blowdown rate, the total solids
concentration ranges between 0.3 and 0.5 percent. This then allows high
pressure pumps to be used, which in turn minimizes water usage and makes
the system possible. The addition of anhydrous ammonia aids the filters
in that the ammonia inhibits polymerization of the phenols and thereby
keeps the filters free. Although this practice will raise the dissolved
solids concentration, this problem is adequately handled by the high
blowdown percentage. Even though it is used in the binder, additional
ammonia is automatically added to the recycled water to obtain an
optimum pH of about 9.0.
The plant also minimizes water usage by using dry air pollution
control equipment. Drop out boxes (without water sprays) are used for
the exiting forming air. High energy fiberglass filters are used for
the curing oven gases.
Maintenance of the diatomaceous earth (Per) filters has proven to be
a major cost of the system, and the company is researching alternate
treatment schemes that need less attention. Flocculation is so far the
most promising technique.
Cooling tower blowdown is bled into the recycle system. No water
softening is required at this plant.
61
-------
Pn
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-------
Plant G
This plant was the recipient of government research funds in 1968
demonstrating the feasibility of complete recirculation of chain washing
waters. The project was based upon three principles. First, the
caustic baths used to clean the forming chains could be replaced by high
pressure water (69 atmospheres). Secondary diatomite filtration would
prevent spray nozzle plugging. Last, the entire blowdown from the
system could be used as overspray. Figure XV illustrates the process
water system.
The plant is an old, small sized plant (2,300 metric tons per year)
producing pipe insulation. As such, a simpler binder mixture is used
than for standard building insulation, and fewer problems are
encountered in recyling the waters. The recycle system operates between
0.1 and 0.5 percent total solids concentration.
Several items have been changed since the research grant. The
diatomite filters have not proven to be as successful as they were
originally thought to be, since excessive maintenance is required. The
company has subsequently decided to replace these filters with a
screening and clarification system. The research report also included
anticipated resin savings into the systems costs, since the recycled
phenols do display some binding properties. However, these properties
are not as significant as first assumed and no cost savings occurred.
Additional pipes discharging process waters have been discovered
since the research project was carried out, and have been subsequently
connected into the treatment system. The remaining discharges have been
diverted to a sanitary sewer. These wastes include caustics for mandrel
cleaning, cooling water, and other phenol free waste streams.
63
-------
FIGURE XV
WATER FLOW DIAGRAM OF
PLANT G
92 GPM (61/SEC)
DUST COLLECTOR
15 GPM^ (1 I/SEC)
(1 I/SEC)
17 GPM A.
. 200 PSI
OVERSPRAY PUMPS
(1000CM. Hg)
1000 PSI
CHAIN CLEAN
PUMPS (5200 CM. Hg)
BINDER AND
OVERSPRAY
12 GPM EACH
TO EVAPORATION
(.81/SEC)
BINDER MIX. RM.
I
FIBER GLASS MACHINES
SOFTENER
_BA_CK_W_ASJH _
MANDRjrL WAShf!
BOILER BLOW ~~"
DOWN 1
DOMESTIC &STORM
SEWER
(~ DOMESTIC
\ WASTE
i V -_.
SCRAP COLLECTION PIT
A SCRAP PUMP
B+B1 SLURRY PUMPS
SUMP PUMP
PRIMARY FILTER
DIRTY WATER TANK
DIATOMITE FILTER
FILTERED WATER TANK
CARTRIDGE FILTERS
FILTERED WATER SUPPLY TANK
HOLDING TANK WITH AERATOR
SEPTIC TANK
SOFTENERS
TO PRESCOTT RUN
PUMP
VALVE, NORMALLY CLOSED
CHAIN CLEANING STATION
64
-------
Summary
In summary the preceeding examples illustrate the following points.
1. The type of fiberizing process has no effect upon the
treatability of the wastes in a recycle system.
2. High pressure sprays (68 atmospheres) can effectively clean the
forming chain if sufficient treatment of the recycled water is
provided so as to avoid damage to the pumps, pipes, and spray
nozzles.
3. Smaller volumes of water can be used at higher pressures in
order to effectively clean the chain.
U. The size of the plant has no effect upon the treatability of
the wastes in a recycle system.
5. The age of a plant does affect the efficiency of a recycle
system in that in the design of a new plant minor changes in
the process will significantly improve the treatability of the
waste waters.
6. Although recycled phenols do have some binding capabilities
they are not such as to cause a significant reduction in the
amount of binder used.
7. The treatment systems described operate within a rather narrow
range of total solids concentrations. New binder formulations
and additional wet air pollution control equipment may
necessitate significant changes in the recycle system requiring
external blowdown as an interim measure. The reason for this
is that only a limited quantity of water can be eliminated as
binder dilution or overspray water. When additional
contaminated waste streams are created by the installment of
wet air pollution control equipment, it may be necessary to
discharge a less objectionable waste stream, such as non-
contact cooling water. This would be necessary in order to
accomondate the contaminated air scrubbing waters into the
total recirculation system.
8. Using properly treated blowdown for overspray or binder
dilution water will not affect the quality of the product.
9. The use of blowdown for either overspray or for binder dilution
varies among the industry, depending upon the the particular
air emissions, water rate, and treatment problems encountered
by each company.
65
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SECTION VIII
COST, ENERGY AND NON-WATEF QUALITY ASPECTS
Cost Reduction, Benefits of Alt.ernat.eTreat.ment: and
Control Technologies
The three alternate treatment and control technologies considered
are biological treatment, biological treatment and carbon adsorption,
and complete recycle. All three treatment schemes consist of recycling
chain wash water and treatment of only the blowdown. Consideration of
treatment of once through process water has long since been abandoned by
the industry because of the large volumes involved and the amenability
of chain wash water to treatment and recycle.
Table XV compares the costs and effluent qualities for the three
alternate treatment schemes as they are estimated for Plant A. The
table clearly indicates that total recycle is the best economic
alternative of the three treatment schemes for best practicable control
technology currently available, best available technology economically
achievable, and best available demonstrated control technology. It is
here assumed that the relationship between the costs of the three
alternatives will hold for different plant sizes. Even if this were not
true, it is quite significant that no discharge of pollutants can be
achieved at costs comparable to end of pipe treatment technology.
Furthermore best available technology economically achievable
specifies application of technology "which will result in reasonable
further progress toward the national goal of eliminating the discharge
of all pollutants". Total recycle of process waters both is
economically achievable and meets the no discharge of pollutants goal.
Total recycle of process waters is currently practiced by a significant
portion of the industry.
Cost of Total Recycle of Process Waters
Table XVI summarizes the water pollution abatement costs for a few
insulation fiberglass plants. Investment costs have been interpolated
to August 1971 dollars by using EPA tables of sewage treatment plant
cost indexes. (1U) Two depreciation periods are used in calculating
total annual cost. The first is the true depreciation period as deter-
mined by the company. For the second, a 10 year depreciation is used
for the purposes of comparison.
An economic study by one consultant (11) concluded that zero dis-
charge is practical for the insulation fiberglass industry. The firm
selected two basic forms of recycle systems. Treatment A, coarse
filtration, fine filtration and water recycle is practiced at Plant F.
67
-------
TABLE XV
A COMPARISON BETWEEN THE ALTERNATE TREATMENT
AND CONTROL TECHNOLOGIESl
Capital Costs ($1000)
Annual Operating Costs
($1000) 2
Effluent Quality
($1000)
BODS (mg/1)
COD (mg/1)
Phenol (mg/1)
Suspended Solids
(mg/1)
Color
Raw Waste Extended
Load Aeration
1160
540
Extended Total
Aeration Recycle
Activated
carbon
1320
556
785
508.5
991
6532
212
769
20
298
1.48
27
103
503
0.053
53
0*
0*
0*
0*
yes
yes
no
no
i. All cost data based upon a 123,000 metric tons (270 million pounds)
per year plant.
Slowdown is 0.57 million liters per day.
2. Operating and maintenance costs and power costs for extended aeration
and activated carbon are assumed to be the same for the total recycle
system.
3. Estimated
*. No discharge hence no pollutants.
68
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Treatment. B, coarse filtration, flocculation, settling and water
recycle, is practiced at Plant B. Table XVII lists the resultant fixed
capital investment and annual operating costs for the two treatment
schemes scaled to the four plant sizes considered by the consultant.
As a conservative estimate 80 percent production was used to
calculate incremental capital and operating costs as shown in Table
XVIII, Assumed selling prices and estimated current fixed capital
investments were used. Figures XVI and XVII both clearly show that the
investment cost of total process water recycle per unit production and
the annual operating cost per unit production for the treatment systems
are not linealy related to plant size. Therefore, the smaller plants
will spend more per unit of product in order to maintain a closed water
system than larger plants.
Assuming no price increases the relative effects on company and
plant pretax earnings as a result of the incremental operating costs,
will be equal to the proportion of selling price represented by these
costs. If incremental costs are passed on, the current rate of
profitability will be maintained. As current returns on investment are
unknown for individual plants, the relative effects on returns on
investment can only be obtained by assuming a certian level of profits
on sales before taxes, and measuring sensitivity at various levels of
returns on investment.
For this analysis, average pretax earnings are assumed to be 12 per-
cent on sales for wool glass fibers. The current returns on investments
tested are 5, 10, and 15 percent in Table XIX. Thus for wool glass, a 1
percent increase in operating costs will reduce returns on investments
by 8.3 percent of the current rate.
Plants of any size that currently have a return on investment no
better than 5 percent will become marginal and could possibly cease
production. However, no such facilities currently exist. Plants
operating at over 5 percent return on investment will continue to enjoy
reasonable returns.
The capital that is needed for the industry to achieve no discharge,
assuming that there are presently no treatment facilities, will range
from 6.0 to 13.5 million doallars depending upon the recycle alternative
10 million dollars being the estimated mean. Operating costs of
pollution control equipment are estimated to be 3.7 million dollars per
year for the industry. The consultant concluded that the insulation
fiberglass industry has the financial capabilities to install total
recycle facilities, and that this will have minimal effect on the
selling price of its products.
The economic analysis of the consultant report was based upon
treatment systems employed at only two plants of different companies.
70
-------
TABLE XVII
ESTIMATED COST OF WASTE WATER TREATMENT FOR
INSULATION FIBERGLASS MANUFACTURE (11)
Type _Treatment_System
Plant
Capacity,
Thousand Million
metric Ib/yr
tons/yr.
(A)
Coarse Filtration
Fine Filtration
Water Recycle
(B)
Coarse Filtrati
Flocculation
Settling
Water Recycle
200
41
440 Fixed Cap. Investment ($1000)
Fixed Cap. Investment/Metric
tons/yr.
Annual Operating Cost $1000)
Annual Operating Cost/Metric
tons/yr
90 Fixed Cap. Investment ($1000)
Fixed Cap. Investment/Metric
tons/yr.
Annual Operating Cost ($1000)
Annual Operating Cost/Metric
tons/yr
20 Fixed Cap. Investment ($1000)
Fixed Cap. Investment/Metric
tons/yr.
Annual Operating Cost ($1000)
Annual Operating cost/Metric
tons/yr.
Investment ($1000)
Investment/Metric
Fixed Cap.
Fixed Cap.
tons/yr.
Annual Operating cost ($100)
Annual Operating cost/Metric
tons/yr.
2000
10.0
610
3.0
800
19.5
200
4.9
325»
36.1
80
8.9
150
65.2
46
20.0
1050
5.2
680
3.4
9.8
2003
4.9
17.8
71
7.9
70
30.4
37
16.1
1. Based on Costs reported by the Industry
2. Actual investment was closer to $600,000 but the existing system has
more capacity than required.
3. Reported cost was closer to 0.3*/lb., but reported treatment
chemical cost seems high.
71
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73
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Pi
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TABLE XIX
EFFECTS ON RETURNS ON INVESTMENT
WOOL GLASS FIBER (11)
Plant Size
Capacity
(M metric
Waste Water
Operating Cost
as % of
Predicted affect on
return on investment
if currently at
tons/yr) Treatment Type
200 A
B
HI A
B
9 A
B
2 A
B
Selling Price
.64
.68
1.04
1.11
1.79
1.57
3.83
3.10
5%
a. 7
4.7
4.6
4.5
4.3
4.4
3.4
3.7
IPX
9.5
9.5
9.2
9.1
8.5
8.7
6.8
7.4
15%
14.2
14.2
13.7
13.6
12.8
13.0
10.2
11.1
75
-------
Figures XVI and XVII compare the costs of water treatment for different
sizes of plants as determined from actual industry calculations and the
estimations by the consultant previously mentioned. As seen* actual
costs lie within or below the limits estimated by the consultant report,
and it can be assumed that the conclusions of the consultant study
general hold true for the entire insulation fiberglass industry.
Further analysis reveals that annual operating and investment of
recycle per annual production rating roughly double from the largest
plant, 200,000 metric tons per year, to plants producing 9,000 metric
tons per year. Eighty-five percent of the insulation fiberglass plants
operate within this range and the relatively small cost variance should
not give the large plants a particular advantage. In fact the largest
plants, which seemingly have the greatest cost advantage, are old plants
which require considerable plant modifications not accounted for in the
economic analysis. The costs of recycle systems increase at a much
faster rate for plants smaller than 9,000 metric tons per year.
However, plants in this size range produce specialty products that sell
for a higher price than the standard building insulation that is most
economically produced by medium and large size plants. The average
price of industrial insulation which includes pipe insulation is UO
percent more than for building insulation. This means that the
percentage cost increase relative to market price should vary less over
the entire range of plant sizes than Figures XVI and XVII indicate. In
fact the smallest primary insulation plant has successfully recycled
chain wash waters for 3 1/2 years.
Non-Water Pollution Effects of the Closed Treatment System
Subsurface disposal of process waters by seepage ponds, has caused
ground water contamination at one insulation fiberglass plant
Evaporation ponds should therefore be lined or sealed. Insufficient
information, regarding spray irrigation with process waste waters,
exists to judge this disposal method.
In the progression from no treatment to recycle systems the industry has
had to contend with increasing amounts of sludges consisting of cullet,
glass fiber - resin masses, particulates removed from stack gases, and
wasted product. Since these solids are in an unusable form, they are
hauled to sanitary landfills. Restrictions at some sites prohibits
burial of phenolic wastes because of the fear of ground water
contamination. One company proposes to autoclave its sludges to insure
complete polymerization of the phenols. It should be emphasized that
the amounts of solid wastes generated by total recirculation system is
no greater than if the industry were to employ alternate end of pipe
waste water treatment technologies.
76
-------
Total process water recirculation systems have no adverse impact on
air emmissions. In only one case has this been the exception (Plant D).
In this case indequately treated water is recycled as air scrubber water
and may actually transfer contaminants to the air. However, this plant
will soon be installing additional water treatment equipment which
should correct the problem.
The use of high pressure spray water pumps does produce
objectionable levels of noise. However, a fiberglass plant is extremely
noisy, especially in the forming area. The small increment of
additional noise introduced by pumps and other miscellaneous recycle
equipment will not affect the hearing protection measures already
practiced by the industry.
This type of treatment system does affect land requirements. The
treatment systems employed at Plants A and B and proposed at Plant D re-
quire considerable space for flocculating and settling tanks, since low
pressure, high volume wash systems are used. Emergency holding ponds
are desirable but not practicable at many existing urban plants.
Estimated energy consumption for existing and proposed treatment
systems are given in Figure XVIII. As seen from the graph power
requirements are nearly directly proportional to plant size. The
industry considers the extra energy needed to operate water treatment
systems to be minor when compared to the energy requirements of the
fiberglass manufacturing equipment and furnaces.
77
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78
-------
SECTION IX
EFFLUENT REDUCTION ATTAINABLE THROUGH THE APPLICATION
OF THE BEST PRACTICABLE CONTROL TECHNOLOGY CURRENTLY
AVAILABLE EFFLUENT LIMITATIONS GUIDELINES
Introduction
The effluent limitations which must be achieved July 1, 1977 are to
'specify the degree of effluent reduction attainable through the
application of the best practicable control technology currently avail-
able. This technology is generally based upon the average of the best
existing performance by plants of various sizes, ages and unit processes
within the industrial category and/or subcategory industry. This
average is not based upon a broad range of plants within the insulation
fiberglass manufacturing industry, but based upon performance levels
achieved by exemplary plants. Consideration must also be given to:
a. The total cost of application of technology in relation to the
effluent reduction benefits to be achieved from such application;
b. the size and age of equipment and facilities involved;
c. the processes employed;
d. the engineering aspects of the application of various types of
control techniques;
e. process changes;
f. non-water quality environmental impact (including energy require-
ments) .
Best practicable control technology currently available emphasizes
treatment facilities at the end of a manufacturing process but includes
the control technology within the process itself when the latter are
considered to be normal practice within an industry.
A further consideration is the degree of economic and engineering
reliability which must be established for the technology to be
"currently available." As a result of demonstration projects, pilot
plants and general use, there must exist a high degree of confidence in
the engineering and economic practicability of the technology at the
time of commencement of construction or installation of the control
facilities.
79
-------
Effluent Reduction Attainable Through The Application of Best:
Practicable Control Technology Currently Available
Based upon the information contained in Sections III through VIII of
this report, a determination has been made that the degree of effluent
reduction attainable through the application of the best practicable
control technology currently available is no discharge of process waste
water pollutants.
Identification of Best Practicable Control Technology Currently Available
Best practicable control technology currently available for the
insulation fiberglass manufacturing subcategory is recycle and reuse of
process waters within the operation. To implement this will require:
1. Replacement of caustic baths with pressurized water sprays in
order to clean forming chains of glass fiber and resin. This
has already been accomplished by the industry.
2. The higher the pressures are, the better the cleaning results.
This results in minimizing the use of other cleaning methods
and in the design of smaller treatment systems, since less water
is used.
3. Reuse of chain wash water after suitable treatment.
4. Slowdown from the chain wash system to control dissolved solids
disposed of in the process as overspray, binder dilution water,
or extra - process by evaporation.
5. Incorporation of hood wash water into the chain wash system.
6. Incorporation of other miscellaneous process waters, such as
mandrel cleaning caustic, into the chain wash system.
7. Recirculation of cullet cooling water with blowdown to the chain
wash recirculation system.
This treatment technology is currently being implemented by the
industry with completion expected before the July 1, 1977 deadline.
Rationale for the Selection of Best Practicable Control Technology
Currently Available
Age and Size of Equipment and Facilities
80
-------
As set forth in this report, industry competition and general
improvements in production concepts have hastened modernization of plant
facilities throughout the industry. This coupled with the similarities
of waste water characteristics for plants of varying size substantiate
that total recycle is practicable.
Total Cost of Application in Relation to Effluent Reduction Benefits
Based upon the information contained in Section VIII of this report,
the industry as a whole would have to invest up to an estimated maximum
of $10,000,000 to achieve the effluent limitations prescribed herein.
This amounts to approximately a 1.2 to 3.8 percent increase in projected
total capital investment, and an anticipated increase of 0.6 to 3.8
percent in the operating cost.
Table XI lists the annual raw waste loads for this industry. About
fifty percent is discharged to publicly owned treatment works. Another
thirty-two percent is retained by existing recycle operations. The
proposed standards would prevent direct discharge of the remaining
amounts of pollutants to navigable streams. In conjunction with the
Pretreatment Standards for existing sources, the standards would
eliminate that portion of pollutants not receiving treatment at publicly
owned treatment works. In addition the proposed regulations would
prevent discharge of pollutants at future plants.
It is concluded that the ultimate reduction to zero discharge of
pollutants outweighs the costs. Presently 32 percent of plants are
achieving no discharge of pollutants.
Processes Employed
All plants in the industry use the same or similar production
methods, the discharges from which are also similar. There is no
evidence that operation of any current process or subprocess will
substantially affect capabilities to implement best practicable control
technology currently available.
Engineering Aspects of Control Technique Applications
This level of technology is practicable because 32 percent of the
plants in the industry are now achieving the effluent reductions set
forth herein. The concepts are proved, they are available for
implementation, they enhance production, and waste management methods
may be readily adopted Lhrough adaptation or modification of existing
production units.
8]
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Process Changes
This technology is as an integral part of the whole waste management
program now being implemented within the industry. While it does
require inprocess changes, they are practiced by many plants in the
industry.
Non-Water Quality Environmental Impact
There is one essential impact upon major non-water elements of the
environment: a potential effect on soil systems due to strong reliance
upon the land for ultimate disposition of solid wastes. With respect to
this, it is addressed only in a precautionary context since no evidence
has been discovered which even intimates a direct impact. However,
subsurface disposal of process waste waters from seepage, percolation or
infiltration is not recommended due to possible contamination of ground
waters.
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SECTION X
EFFLUENT REDUCTION ATTAINABLE THROUGH THE APPLICATION OF THE BEST
AVAILABLE TECHNOLOGY ECONOMICALLY ACHIEVABLE EFFLUENT LIMITATIONS
GUIDELINES
The effluents limitations reflecting this technology is no discharge
of process waste water pollutants to navigable waters as developed
in Section IX.
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SECTION XI
NEW SOURCE PERFORMANCE STANDARDS
The effluents limitations for new sources is no discharge of process
waste water pollutants to navigable waters as developed in Section IX.
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SECTION XII
ACKNOWLEDGMENTS
The author wishes to express his appreciation to various personnel
with the insulation fiberglass industry for their willing cooperation in
providing analytical data, flow diagrams, related information, and
assistance with respect on-site plant visits. In this regard those
persons so cited are: Mr. S.H. Thomas, Director of Environmental
Control, and Mr. George w. Fletcher, Environmental control Specialist,
Owens-Corning Fiberglas; Mr. E.M. Fenner, Director of Technical
Relations, and Mr. G.A. Ensign, Manager of Environmental Control
Engineering, Johns-Manville; Mr. E.B. Norwicki, Manager of Environmental
Control, Certain-Teed Saint Gobain; and Mr. L.T. Powell, Manager of
Process Engineering, Pittsburgh Plate Glass Industries. In addition to
these men and their immediate staff the author also wishes to express
his appreciation to the plant managers and staff at those plants
inspected by EPA for their more than cooperative assistance.
Acknowledgment is given to the Office of Research and Monitoring for
providing contacts in the fiberglass industry through existing and past
Technology Research Projects. Previous Interim Guidance Documents by
the Office Permit Programs have formed a basis upon which this document
was written.
Thanks is given to Ernst Hall, Walter Hunt and Ronald McSwiney of
the Effluent Guidelines Division who spent many extra hours revising the
document. The working group/steering committee members who reviewed
this document in order to coordinate intragency environmental efforts
are Ernst Hall, Effluent Guidelines Division; Taylor Miller, Office of
Enforcement and General Council; Arthur Mallon and Charles Ris III,
Office of Research and Monitoring; James Santroch, National
Environmental Research Center, Corvallis; John Savage, Office of
Planning and Evaluation; J. William Jordan and James Grafton. Office of
Permit Programs; and Robert Atherton, Office of Air Quality Planning and
Standards. Last but not least, appreciation is given to the secretarial
staff of the Effluent Guidelines Division in particular Ms. Kay Starr,
in the typing of drafts, revisions, and final preparation of the
effluent guidelines document.
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Section XIII
BIBLIOGRAPHY
1. Encyclopedia Britannica, "Glass Fibers," Volume 10, William Ben-ton,
Publisher, Chicago, PP. 475-476.
2. Phillips, C. J., "Fiber Glass," The Encyclopedia Americana, Volume
6, Americana corporation. New York, PP. 170-170b.
3. Shreve, R. Norris, Chemical Process Industries, 3rd edition, McGraw-
Hill Book Company, New York, PP. 700-702, (1967).
4. Shand, E. B., Glass Engineering Handbook, 2nd edition, McGraw-Hill
Book Company, New York, PP. 375-410, (1958).
5. Phenolic T_ Waste Reuse by Diatgmite Filtration, Johns-Manville
Products Corporation, Water Pollution Control Research Report,
federal grant number 12080 EZF (September, 1970).
6. Baloga, J.M., Hutto, F.B., Jr., and Merrill, E.I., "A Solution To
The Phenolic Pollution Problem In Fiber Glass Plants: A Progress
Report," chemical Engineering Progress Symposium Series, American
Institute of Chemical Engineers, Number 97, Volume 65, PP. 124-127.
(1968) .
7. Angelbeck, Donald L., Reed, Walter B., and Thomas, Samuel H.,
"Development and Operation of a Closed Industrial Waste Water
System," Owens-Corning Fiberglass Corporation Paper Presented at the
Purdue Industrial Waste Conference, Purdue University, West
Laffayette, Indiana, (May 4, 1971).
8. Fletcher, George W., Thomas, Samuel H. and cross, Donald E.,
"Development and Operation of a Closed Wastewater System For The
Fiberglas Industry," Owens-Corning Fiberglas corporation. Paper
Presented at the 45th Annual Conference, Water Pollution Control
Federation, Atlanta, Georgia, (October 9, 1972).
9. "Welcome to Owens-corning Fiberglas.. .A citizen of Newark., Ohio,"
Owens-Corning Fiberglas Corporation.
10. Helbring, Clarence H., et al, "Plant Effluent - Recycle and Reuse,
PPG Industries, Works t50, Shelbyville, Indiana, "PPG Industries, A
Paper Presented at the Purdue Industrial Waste conference, Purdue
University, West Laffayette, Indiana, (1971).
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11. "Initial Economic Impact Analysis of Water Pollution Control Costs
Upon The Fiber Glass Industry," report to Environmental Protection
Agency by Arthur D. Little, Inc., Cambridge, Massachusetts, Contract
No. 68-01-0767, (1973).
12. StandarcLMethods for the Examination of Water and Wastewater, 13th
edition, American Public Health Association, Washington, D. C.
(1971).
13. "Methods for Chemical Analysis of Water and Wastes," Environmental
Protection Agency, National Environmental Research Center,
Analytical Quality Control Laboratory, Cincinnati, Ohio (1971).
1U. "Sewage Treatment Plant and Sewer construction cost Indexes,"
Environmental Protection Agency, Office of water Programs
Operations, Municipal Waste Water Systems Division, Evaluation and
Resource Control Branch.
15. Screening Study for Background Information from Fiber Glass
Manufacturing, Vulcan-Cincinnati, Inc,. Cincinnati, Ohio, prepared
for EPA, Contract number 68-02-0299, (December U, 1972).
16. Water Quality Criteria, 2nd edition, The Resources Agency of
California, State Water Quality Control Board, publication No. 3-A
(1963) .
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SECTION XIV
GLOSSARY
Act
The Federal Water Pollution Control Act Amendments of 1972.
Annual Operating Costs
Those annual costs attributed to the manufacture of a product or
operation of equipment. They include capital costs, depreciation,
operating and maintenance costs, and energy and power costs.
Atmosphere
Unit of pressure. One atmosphere is normal atmosphere pressure, 11.70
pounds per square inch.
Batt
Standard wool mat used for residential insulation.
Best Available Technology Economically Achievable (BATEAL
Treatment required by July 1, 1983 for industrial discharges to surface
waters as defined by Section 301 (b)(2)(A) of the Act.
Best Practicable control Technology Currently Available (BPCTCA)
Treatment required by July 1, 1977 for industrial discharges to surface
waters as defined by Section 301 (b) (1) (A) of the Act.
Best Available Demonstrated control Technology (BADCT)
Treatment required for new sources as defined by Section 306 of the Act.
Binder
Chemical substance sprayed on the glass fibers in order to bond them
together. Synonymous with the terms resin and phenolic resin.
Blowing Wool
Insulation that is either poured or blown into walls. It is produced by
shredding standard insulation mats and is also referred to as pouring
wool.
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BOP 5
Biochemical Oxygen Demand, 5 day, 20°C.
Bore-silicate
A type of glass containing approximately five percent boric oxide.
Capital Costs
Financial charges which are computed as the cost of capital times the
capital expenditures for pollution control. The cost of capital is
based upon a weighed average of the separate costs of debt and equity.
Category and Subcategory
Divisions of a particular industry which possess different traits which
affect water quality and treatability.
Caustic
Any strongly alkaline material. Usually sodium hydroxide.
Chain
A revolving metal belt upon which the newly formed glass fibers fall to
form a thick mat. There are two general types of chains: wire mesh
chains and flight conveyors. The latter are hinged metal plates with
several holes to facilitate the passage of air.
cm
Centimeter
COD
Chemical Oxygen Demand
Gullet
Chunks of solid glass formed when molten glass bled from a furnace comes
into contact with water.
Curing
The act of thermally polymerizing the resin onto the glass fibers in a
controlled manner.
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Depreciation
Accounting charges reflating the deterioration of a capital asset over
its useful life.
Diatomaceous Earth
A filter media used in this case to remove fine glass-resin particles.
The process of filtration is referred to as diatomite filtration.
Dry,Air Pollution Control
The technique of air pollution abatement without the use of water.
Fiberglass
Extremely fine fibers of corrosion resistant glass of diameters
typically less than 0.015 mm. Also fiber glass.
Flame Attenuation
The glass fiber forming process in which thick threads of glass are
forced through perforated bushings and then reduced in diameter by
burning gases or steam.
Forming Area
The physical area in which glass fibers are formed, sprayed with
lubricant and/or binder, and fall to the chain. A downward forced air
draft is maintained to insure proper binder dispersal and to force the
fibers to the chain.
Glass Wool
The cured fiberglass - resin product. Also referred to as insulation
fiberglass.
gpm
Gallons per minute
Investment Costs
The capital expenditures required to bring the treatment or control
technology into operation. These include the traditional expenditures
such as design; purchase of land and materials; site preparation; con-
struction and installation; etc.; plus any additional expenses required
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obring the technology into operation including expenditures to establish
related necessary solid waste disposal.
1
Liter
Lubricant
Usually a mineral oil added to the binder to inhibit abrasion from the
fibers,
Thousand (e.g. thousand metric tons) .
Mandrel
A pipe-line metal form with numerous holes. Serves as a form about
which insulation is shaped to make pipe insulation.
Mat
The newly formed layer of fiberglass on the chain.
mg/1
Milligrams per liter. Nearly equivalent to parts per million
concentration.
MM
Million (e.g. million pounds)
Navigable Waters
The waters of the United States including the territorial seas.
New Source
Any building, structure, facility, or installation from which there is
or may be a discharge of pollutants and whose construction is commenced
after the publication of the proposed regulations.
Operations and Maintenance
Costs required to operate and maintain pollution abatement equipment.
They include labor, material, insurance, taxes, solid waste disposal
etc.
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Overspray
Water spray applied to the newly formed glass fivers, the purpose of
which is to both cool the hot glass and to decrease the rate of resin
volatilization and polymerization.
Pack
A fiberglass product made from relatively thick fibers, as compared to
glass wool insulation, that is used for special application (e.g. air
filters and distillation column packing).
ES
A measure in the hydrogen ion concentration in water. A pH of 7.0
indicates a neutral condition. A greater pH indicated alkalinity and a
lower pH indicates acidity. A one unit change in pH indicates a 10 fold
change in acidity and alkalinity.
Phenol Class of cyclic organic derivatives with the basic formula
C*6*H*5*OH
Pretreatment
Treatment proved prior to discharge to a publicly owned treatment works.
Process Water
(i) Any water which comes into rjntact with any glass, fiberglass,
phenolic binder solutions or any other raw materials, intermediate or
final material or product, used in or resulting from the manufacture or
insulation fiberglass and (ii) Non-contact cooling water.
Resin
Synonymous to Binder
Rotary Spun
The glass fiber forming process in which glass is forced out of holes in
the cylindrical wall of a spinner.
Sec
Second. Unit of time.
Secondary Treatment
Biological treatment provided beyond primary clarification.
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Silicates
A chemical compound containing silicon, oxygen, and one or more metals.
Staple Fiber
Glass fibers with used short irregular lengths for insulation products
in contrast to continuous filaments used for textile products.
Wet Air Pollution Control
The technique of air pollution abatement utilizing water as an
absorptive media.
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TABLE XX
METRIC UNITS
CONVERSION TABLE
MULTIPLY (ENGLISH UNITS) by TO OBTAIN (METRIC UNITS)
ENGLISH UNIT ABBREVIATION CONVERSION ABBREVIATION METRIC UNIT
acre ac
acre - feet ac ft
British Thermal
Unit BTU
British Thermal
Unit/pound BTU/lb
cubic feet/minute cfm
cubic feet/second cfs
cubic feet cu ft
cubic feet cu ft
cubic inches cu in
degree Fahrenheit F°
feet ft
gallon gal
gallon/minute gpm
horsepower hp
inches in
inches of mercury in Hg
pounds Ib
million gallons/day mgd
mile mi
pound/square
inch (gauge) psig
square feet sq ft
square inches sq in
tons (short) t
yard y
0.405
1233.5
0.252
0.555
0.028
1.7
0.028
28.32
16.39
0.555(°F-32)1
0.3048
3.785
0.0631
0.7457
2.54
0.03342
0.454
3,785
1.609
(0.06805 psig +1)1
0.0929
6.452
0.907
0.9144
ha hectares
cu m cubic meters
kg cal kilogram - calories
kg cal/kg kilogram calories/kilogram
cu m/min cubic meters/minute
cu m/min cubic meters/minute
cu m cubic meters
1 liters
cu cm cubic centimeters
°C degree Centigrade
m meters
1 liters
I/sec liters/second
kw killowatts
cm centimeters
atm atmospheres
kg kilograms
cu m/day cubic meters/day
km kilometer
atm atmospheres (absolute)
sq m square meters
sq cm square centimeters
kkg metric tons (1000 kilograms)
m meters
1 Actual conversion, not a multiplier
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SUPPLEMENT A
CONSULTATIONS AND PUBLIC PARTICIPATION
Scope of Consultations
Prior to the publication of the Development Document and the
proposed regulations for the insulation fiberglass manufacturing
industry, the following agencies, groups, and corporations were given
the opportunity for comment:
1. All State and U.S. Territory Pollution Control Agencies
2. Ohio River Valley Sanitation Commission
3. New England Interstate Water Pollution Control Commission
4. Delaware River Basin Commission
5. Hudson River Sloop Restoration, Inc.
6. Conservation Foundation
7. Businessmen for the Public Interest
8. Environmental Defense Fund, Inc.
9. Natural Resources Defense Council
10. The American Society of Civil Engineers
11. Water Pollution Control Federation
12. National Wildlife Federation
13. The American Society of Mechanical Engineers
14. Department of Commerce
15. Water Resources Council
16. Department of the Interior
17. Certain - Teed Saint Gobain
13. Johns-f'anville Corporation
19. Owens-Corning Fiberglas Corporation
Industry Participation
The concept of total recycle of process waters was initiated by a
Federal Water Quality Administration research grant (5) in 1968. Further
documentation by the industry (7, 8, 10) further substantiated that
total recycle could be applied to rotary processes.
On July 27, 1972, members of the Enforcement Office and Office of
Refuse Act Programs of the EPA met with representatives of the then
four firms that manufactured insulation fiberglass. The industry was
presented with a draft interim guidance proposing no waterborne waste
discharge by January 1,^1976 as a permit condition.
The industry representatives concurred with the draft regulations.
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Plant inspections were conducted by the project officer during the
month of March, 1973. During this period, the principal water pollution
officials of each of the four firms were consulted. The now existing
three firms were asked to comment on the development document by
June 22, 1973. Two of the companies replied.
The companies were concerned that the no discharge of pollutants
requirement would be applied to plants where both insulation and textile
products are made. The regulations apply only to insulation fiberglass
manufacturing operations.
The industry also requested that boiler blowdowns, water softener
backwashes and noncontact cooling waters be omitted from the no discharge
requirements. The chemistry of the binder is such that it should not be
exposed to certain contaminants (e.g. magnesium and calcium ions) in
boiler blowdown and water softener backwashes. These two waste streams
have been omitted from the definition of process waste waters.
At present, there is no discharge of these waste waters to navigable
waters. In some instances these wastes are discharged to publicly owned
treatment works, but no treatability problems have been reported. The
constituents in these waste waters include dissolved solids, suspended
solids, pH and heat.
Noncontact cooling water is currently recycled and the blowdown
used for overspray or binder dilution at existing exemplary plants.
Industry still has the option of cooling these waters to meet the no
discharge of pollutants requirement. Industry, under Section 316 of
the Act, can be granted less stringent limitations for noncontact
cooling waters if it can be demonstrated "to the satisfaction of the
Administrator that any effluent limitation proposed for the control
of the thermal component of any discharge from such source will require
effluent limitations more stringent than necessary to assure the pro-
tection and propagation of a balanced, indigenous population of shell-
fish, fish, and wildlife in and on the body of water into which the
discharge is to be made." "The Administrator may impose an effluent
limitation under such sections for such plant, with respect to the
thermal component of such discharge (taking into account the interaction
of such thermal component with other pollutants), that will assure the
protection and propagation of a balanced, indigenous population of
shellfish, fish, and wildlife in and on that body of water."
Industry also commented that at plants in urban locations,
insufficient room is available to construct holding ponds for
system upsets and that such upsets may have to be discharged. Because
of the nature of these wastes, no discharge can be allowed to navigable
waters.
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If in the case of process upsets discharges are sent to a
publicly owned treatment works, sufficient pretreatment must be provided
to prevent upsets in the public system and to meet any applicable
pretreatment requirements. It is possible that manufacturing shut-
downs may result from such actions.
Effluent Standards and Water Quality Information Advisory Committee
Comments
Concern over increased air pollution was raised because the blow-
down is disposed of on the hot fiberglass as either overspray or binder
dilution. When used for binder dilution there has been no measurable
increase in air emissions, because the binder has orders of magnitude
more of the same volatile matter. When used as overspray, one company
has experienced air emission problems. Another has not and is currently
practicing this method. The second company maintains a total solids
concentration in its recycled water 10 times less than the first,
accounting for the difference in air emissions.
The committee also questioned whether requiring no discharge of
pollutants by 1977 as best practicable control technology currently
available was really imposing more stringent a requirement than the
Act states. The Act designates no discharge of pollutants as a national
goal to be achieved by 1935. However, this technology is currently
in practice by the industry and has been shown to be economically and
technologically practicable for over three years. No discharge of
process water pollutants does meet the requirements for best practicable
control technology currently available and can, therefore, be set as a
July 1, 1977 requirement.
Other Federal Agencies
No comments were received from other Federal agencies before
July 2, 1973.
Public Interest Groups
The comments received from public interest groups agreed with the
conclusions and recommendations of the development document.
Period for Additional Comments
Upon signature of the proposed rule-making package by the
Acting Administrator, interested persons will have 21 days in which
to comment on the proposed regulations.
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