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 PACKS—BASIC 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

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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
G
120
34
35
32
18
16
2
270
75
77
71
41
35
5
44
38
14
63
50
8
3
700
600
200
1000
800
120
48
                                  34

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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
I
Average
Annual Raw
120
18
16
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
RETl
SLUI
TE 	 *
)GE
k
JRN
DGE
•*

WA
SUF
TER
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i


r
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AND
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i
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AND
SEDIMEN
fc
*1
^
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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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    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

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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

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                                 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

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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

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                              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

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                              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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                              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

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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

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                               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

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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]

-------
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.
                                  83

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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.
                                  85

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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
                                   93

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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.
                                  94

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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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