EPA-450/3-85-004
Review of New Source Performance
  Standards for Ammonium Suifate
               Manufacture
           Emission Standards and Engineering Division
           U.S. ENVIRONMENTAL PROTECTION AGENCY
                Office of Air and Radiation
           Office of Air Quality Planning and Standards
              Research Triangle Park, NC 27711

                   February 1985

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This report has been reviewed by the emission Standards and Engineering Division of the Office
of Air Quality Planning and Standards, EPA, and approved for publication. Mention of trade
names or commercial products is not intended to constitute endorsement or recommendation
for use. Copies of this report are available through the Library Services Office (MD-35), U.S.
Environmental Protection Agency,  Research Triangle Park,  N.C.  27711, or from National
Technical Information Services, 5235 Port Royal Road, Springfield, Virginia 22161.

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                            TABLE  OF  CONTENTS
     LIST OF  FIGURES

     LIST OF  TABLES

1.   Executive Summary                                              1-1

     1.1  Regulatory  History of  Current  Standard                    1-1
     1.2  Best Demonstrated Control  Technology                      1-2
     1.3  Enforcement of NSPS                                      1-2
     1.4  Industry Growth Trends                                   1-3
     1.5  Economic Considerations  Affecting  the NSPS                1-3

2.   Industry Description                                          2-1

     2.1  Introduction                                              2-1
     2.2  Background  Information                                   2-4
     2.3  Ammonium Sulfate Production                              2-5
          2.3.1  Caprol actam By-Product  Ammonium  Sulfate           2-5
          2.3.2  Synthetic Ammonium Sulfate                         2-9
          2.3.3  Coke Oven By-Product Ammonium Sulfate             2-12
     2.4  References                                                2-17

3.   Current  Standards  for Ammonium Sulfate  Plants                  3-1

     3.1  Affected Facilities                                      3-1
     3.2  Controlled  Pollutants  and Emission Levels                3-1
     3.3  Monitoring  Requirements                                   3-1
     3.4  Testing Requirements                                     3-2

4.   Status of Control  Technology                                   4-1

     4.1  Emission Sources                                         4-1
     4.2  Emission Control Equipment in  Ammonium  Sulfate           4-3
            Industry
          4.2.1  Venturi Scrubbers                                 4-6
          4.2.2  Centrifugal Scrubbers                             4-6
          4.2.3  Other Wet Scrubbers in  the AS Industry            4-7
          4.2.4  Fabric Filtration in the AS Industry              4-7
     4.3  Plant Testing                                            4-8
     4.4  References                                                4-1°

5.   Compliance Test Results                                       5-1

     5.1  References                                                5-3
                                   i n

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                            TABLE  OF CONTENTS
6.   Cost Analysis                                                      6-1

     6.1  Capital  Costs                                                 6-1
     6.2  Annualized Costs                                              6-5
     6.3  Cost Effectiveness                                            6-10
     6.4  References                                                    6-13

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                             LIST OF  FIGURES
Figure No.                                                  Page

  2-1     Caprolactam By-Product  Ammonium Sulfate            2-6
            Process  Flow  Diagram

  2-2     Synthetic  Ammonium Sulfate  Process                 2-10
            Flow Diagram

  2-3     Process Flow Diagram for  Coke Oven By-Product
            Ammonium Sulfate Showing  Alternate Drying        2-14
            Processes

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                              LIST  OF  TABLES
Table No.                                                  Page

  2-1     U.S. Production and Consumption  of                 2-2
            Ammonium Sulfate

  2-2     Typical  Parameters for a  Caprolactam               2-8
            By-Product Ammonium Sulfate  Dryer

  2-3     Typical  Parameters for a  Synthetic                 2-11
            Ammonium Sulfate Dryer

  2-4     Estimated Parameters for  a  Coke  Oven               2-16
            By-Product Ammonium Sulfate  Dryer

  4-1     Summary  of Uncontrolled Emission Data  from         4-2
            EPA Emission Tests on AS  Dryers

  4-2     Ammonium Sulfate Industry-Supplied Wet             4-4, 4-5
            Scrubber Performance Data

  4-3     AS Particulate Control  Systems Tested  by EPA       4-9

  4-4     Results  of EPA Emission Testing                    4-10

  5-1     Industry-Supplied Emission  Test  Data    -     .      5-2

  6-1     Capital  Cost Summary for  a  Venturi Scrubbing       6-2
            System (Caprolactam By-Product Plant with
            22.7 Mg/hr Capacity)

  6-2     Capital  Cost Summary for  a  Venturi Scrubbing       6-3
            System (Synthetic Plant with 13.6 Mg/hr
            Capacity)

  6-3      Capital Cost Summary for a Venturi Scrubbing      6-4
            System (Coke Oven By-Product Plant with
            2.7 Mg/hr Capacity)

  6-4     Venturi  Scrubber Operating  Parameters              6-6

  6-5     Annualized Cost Summary for a  Venturi              6-7
            Scrubbing System (Caprolactam  By-Product
            Plant  with 22.7 Mg/hr Capacity)

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                              LIST  OF TABLES
Table No.

  6-6     Annualized Cost Summary  for  a  Venturi Scrubbing    6-8
            System (Synthetic Plant  with 13.6 Mg/hr
            Capacity)

  6-7     Annual!zed Cost Summary  for  a  Venturi              6-9
            Scrubbing System (Coke Oven  By-Product
            Plant with 2.7 Mg/hr Capacity)

  6-8     Average U.S. Retail  Price  for  Ammonium  Sulfate     6-11

  6-9     Cost Effectiveness of AS Particulate  Recovery      6-12
            Using Venturi Scrubbers  (March  1984 dollars)

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                         1.   EXECUTIVE  SUMMARY

1.1  Regulatory History of Current Standard
     The new source performance standards (NSPS)  for ammonium sulfate (AS)
particul ate matter were proposed on February 4,  1980,  and promulgated by
the Environmental  Protection Agency (EPA) on November 12, 1980 (40 CFR 60,
Chapter 1, Subpart PP).  The standards  apply to  ammonium sulfate  dryers that
were constructed,  reconstructed, or modified on  or after February 4,  1980,
and produce ammonium sulfate as a caprolactam by-product, as a coke oven
by-product, or by  synthetic manufacture (direct  combination of ammonia and
sulfuric acid).  The standards state that exhaust gases discharged to the
atmosphere from ammonium sulfate dryers must not contain AS particulate
matter in excess of 0.15 kg per megagram of ammonium sulfate produced (0.30
pound of particulate per ton of ammonium sulfate produced).  The standards
also limit visible emissions from stacks to 15 percent opacity.
     There are requirements in the NSPS for continuous monitoring of mass
flow rates to crystal!izers and for the continuous monitoring of pressure
drops across particulate control equipment.  The flow monitoring device
must have an accuracy  of +_  5 percent.  However,  if a facility uses weigh
scales of the same accuracy to directly measure production rates of AS, the
use  of flow monitoring devices is not  required.   The NSPS requires that
affected  facilities install, calibrate, maintain, and operate pressure drop
monitors  across emission control devices,  and that these devices be accurate
to +_ 5 percent.  Records from AS feedstream flow monitoring and  pressure
drop monitoring are required under the NSPS to be retained for 2 years from
the  date  the measurements are made by  the  operator.
                                    1-1

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     The objective of this report is to review the ammonium sulfate NSPS
and to assess the need for revision  on  the  basis  of developments  that  have
occurred since the NSPS was promulgated in  1980.
1.2  Best Demonstrated Control  Technology  (BDCT)
     The NSPS is based on the use of medium energy venturi  scrubbers as
an add-on measure to control  particulate emissions from AS  dryers.   No
significant changes in control  technology  for AS  dryers have occurred  since
promulgation of the NSPS.  Because ammonium sulfate has a moderately high
water solubility, wet scrubbing is employed throughout  the  industry.  Wet
scrubbing allows easy recycle of collected  particulates back into process
streams, avoiding alternative waste  disposal  problems.   In  the caprolactam
by-product AS industry there are small  amounts of caprolactam carried
through the AS manufacturing process.   Dryer emissions  of caprolactam, a
volatile organic compound (VOC), are also  controlled effectively  by wet
scrubbing.
     There is only one dry emission  control  process that has operated  at  an
AS facility.  This is a baghouse which  was  used at a synthetic AS plant.  A
telephone survey of the synthetic AS industry indicates that this plant has
been mothballed since 1979.
1.3  Enforcement of NSPS
     Since proposal and promulgation of the NSPS, there have been no new,
modified, or reconstructed facilities which have  come under the standards.
However, emission data gathered from the industry since promulgation of
the NSPS indicate that emission levels  set  by the NSPS  are  being  achieved
at existing plants.  There is an incentive  for AS producers to meet the
NSPS because captured emissions may  be  recovered, reprocessed, and  sold as
                                    1-2

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product.  There are no in-stack opacity monitors  in  most  AS  participate
control  applications due to the use of wet  scrubbing .  Water  droplets and
steam in the stack make the exhaust gases difficult  to  monitor by  available
equipment.  Therefore, no continuous opacity data are available for AS dryers.
1.4  Industry Growth Trends
     Since proposal and promulgation of the NSPS  there  has been a  decline
in the total production capacity of ammonium sulfate plants.  Several
plants producing synthetic AS and coke oven by-product  AS have closed
operations.  Caprolactam by-product AS has  experienced  a  small  capacity
increase, but the potential for further AS growth in the  near future is
limited by the demand for caprol actam, which is used to manufacture nylon-6
fibers.  Consumption of ammonium sulfate has also experienced a decline  in
the last 4 years due to an increased use of alternative nitrogenous fertilizers.
There are no indications that these production and consumption patterns
will-be altered in the next few years.
1.5  Economic Considerations Affecting the NSPS
     A  review of venturi scrubber costs in the AS industry was performed
to determine the cost effectiveness of achieving the NSPS for each of the
three regulated AS processes.  The cost effectiveness of venturi scrubbers
ranges  from a cost savings of $36 per megagram of particulate captured for a
545 Mg/day caprolactam plant to a cost of $655 per megagram for a 65 Mg/day
coke oven by-product  plant.  There is a cost savings of $21 per Mg for a
326 Mg/day  synthetic  AS plant.  Cost  savings are generated by recovery
credits for AS particulates that are  captured by scrubbers and recycled
back to process streams.   Recovery credits are dependent on dryer emission
rates,  scrubber collection efficiencies, and AS market prices.
                                    1-3

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                        2.   INDUSTRY  DESCRIPTION

2.1  Introduction
     On February 4, 1980,  the EPA proposed new source performance  standards
for ammonium sulfate dryers.  The standards established  parti cul ate  emission
limits for ammonium sulfate dryers in three categories of  ammonium sulfate
production.  Affected facilities include dryers in  synthetic  process  plants,
caprolactam by-product plants, and coke oven by-product  plants  that  were
constructed, reconstructed, or modified on or after February  4, 1980.
The proposed standards were promulgated on November 12,  1980.  Ammonium
sulfate is produced as a by-product of several other processes, such  as
nickel reduction, sulfuric acid tail  gas scrubbing, and sewage  sludge
processing, none of which are subject to the NSPS.
     At the time of the NSPS development, there were approximately 50 plants
employing  one of the three regulated processes for production of ammonium
sulfate.   Production capacity has declined between 1977 and 1983 from 3,143
x  103 Mg/yr to  2,869 x 103 Mg/yr with several plant closings  in the  industry.1
U. S. consumption of ammonium sulfate has dropped from 955 x  103 Mg  in 1977
to 624 x  103 Mg  in  1983.2  Production and consumption trends  are presented  in
Table 2-1.
     There are  three plants currently producing AS as a by-product of
caprolactam, and these three  plants produce over 50 percent of the total
AS in the United States.  Caprolactam is used  in the manufacture of nylon-6
fibers.   One caprolactam plant  expanded AS production in 1980-81 from
860  x  103 to 910 x  103 Mg/yr, but the modification was exempt  from the NSPS

                                    2-1

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        TABLE  2-1.  U.S. PRODUCTION AND CONSUMPTION OF AMMONIUM SULFATE
                             (103 Metric tons)
Year
1983
1982
1981
1980
1979
1978
1977
1976
1975
1970
Production
Capacity
2869*
2869
2911
2866
2948
3099
3143
3382
3416
3530
Production Rate
(% Capacity)
N.A.
N.A.
90.2
81.2
87.1
80.7
79.3
67.8
76.2
64.1
Actual
Production
N.A.
N.A.
2626
2327
2568
2501
2492
2293
2603
2263
Consumption
624
650
769
791
707
768
955
956
742
700
*  Projected

   N.A. - Not Available

Sources:

  "World Fertilizer Capacity,"  3/26/84,  TVA  National Fertilizer Development
  Center, Muscle Shoals,  Alabama.

  Fertilizer Trends 1982, TVA National Fertilizer Development Center.

  "Commercial Fertilizers - Consumption  for  Year Ended June 30, 1984,"
  USDA Crop Reporting Board.

  Fertilizer Reference Manual,  June  1982,  The  Fertilizer  Institute.
                                     2-2

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based on the date for commencement  of construction.3   A survey  of  the
industry indicates no anticipated expansion  or new construction of capro-
1 actam by-product AS plants in the near future.4'6'6
     There has been a decline in production  in both the synthetic
manufacture of ammonium sulfate and coke oven by-product AS since  1978,
with plant closings in both segments of the  industry.   A telephone survey
of synthetic AS producers confirms that most are operating well below
design production capacities.
     Ammonium sulfate's share of the fertilizer market has increasingly
been displaced by other sources of higher analysis nitrogen fertilizers,
such as anhydrous ammonia and urea.  Ammonium sulfate is 20.9 percent
nitrogen compared to 82 percent for anhydrous ammonia and 44.5 percent for
urea.  Ammonium sulfate will continue to be a leading source of plant
nutrient sulfur in the U.S. fertilizer market, but there has been  a notable
 increase in the use of other sulfur carriers, such as ammonium thiosulfate,
 rather than expanding supplies of AS.7  Based on current capacity  utilization,
 announced  expansions, and consumption patterns, the likelihood of  any
 significant growth of ammonium sulfate fertilizer manufacture  in the next
 few years  is  nil .4
     The Fertilizer Institute  (TFI)  reports an average operating rate  for
 AS  producers  in  1983  at 71  percent  of their total capacity, with the middle
 50  percent of the plants falling between 39 and 72 percent.7  This indicates
 that  ample capacity is available in the U.S. to meet any future increased
 demands which may occur.  There  have been no  plant modifications or recon-
 structions in the AS  manufacturing  industry which  are subject to the NSPS.

                                    2-3

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     The Clean Air Act Amendments  of 1977 require that  the  EPA  review  the



NSPS at least every 4 years to assess the need  for possible revision



of standards [Section lll(b)(l)(B)].  This report presents  the  results of



the first review of the NSPS for ammonium sulfate.  The review  was  conducted



by examination of current ammonium sulfate literature,  contacts with EPA



Regional and State offices, contacts with producing plants, and contacts



with fertilizer trade associations.



2.2  Background Information



     The primary use of ammonium sulfate (>95%)  is as  an agricultural



fertilizer.  More than 50 percent  of ammonium sulfate  is generated  as  a



by-product of caprolactam, which is used in the  manufacture of  nylon-6



fibers.  Because a great percentage of AS is generated  as a by-product of



another process, production is not based solely  on the  demand for  fertilizer,



but more on the demand for primary products.



     The ammonium sulfate dryer is the main source of  particul ate  emissions



in the production process.  There  are other sources of  fugitive emissions



such as crystallization, dewatering, screening,  and materials handling,



but they are not, in the opinion of EPA, significant emission sources.^



Two types of dryers used in AS production are rotary dryers and fluidized



bed dryers.  Rotary dryers may be  direct fired  or steam heated, and



fluidized bed dryers in the industry are all steam heated.   Gas flow



rates, heat transfer rates, and mass transfer rates are the important



parameters for drying AS.  These parameters may  vary widely with different



dryers in the industry.
                                   2-4

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2.3  Ammonium Sulfate Production
     The three ammonium sulfate production  processes  covered by the NSPS
are caprolactam by-product,  coke  oven  by-product,  and synthetic manufacture.
The basic difference in the  three production  processes is  the method of
producing the AS crystals from the various  feedstocks.  From the step of
crystallization onward, the  three processes are quite similar.  The slurry
of crystals is dewatered by  centrifugation, dried  and screened  (except in
coke oven by-product processes where screening appears to  be nonexistent),
and the dryer exhaust gases  are vented to the emission control  equipment.
The dried AS crystals are conveyed to storage, and fines separated by
screening are recycled back  to the crystallizer.
2.3.1  Caprolactam By-Product Ammonium Sulfate - A typical process flow
diagram for caprolactam by-product ammonium sulfate is shown in Figure 2-1.
It is based on information obtained from plant visits to the three capro-
lactam production plants and responses to EPA inquiries.9   The  material  flow
rates in Figure 2-1  are based on a typical  AS production rate  of  22.7 Mg/hr
(25 ton/hr).
     The ammonium sulfate crystals are produced by continuously heating
and circulating a 40 percent AS mother liquor through a draft  tube-baffle
crystallizer  at temperatures of 77° to 82°C (170° to  180°F) and at  a
pressure of  about 660 mm Hg  (12.8 psia).  Water vapor is released from
the crystallizer and condenses in one or more heat exchangers.   The  AS
slurry, known  as "magma" flows out of the crystallizer to  the  settling
tank, where  clear liquid is  decanted  as the AS crystals settle to the
bottom  of  the  tank.
                                    2-5

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                                                                                                     VACUUM
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                                        Figure 2-1.   CAPROLACTAM  BY-PRODUCT  AMMONIUM SULFATE

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     The slurry of ammonium sulfate crystals  and  mother  liquor  moves  next
to the centrifuge system, where a bulk  separation is  performed.  Typical
crystal throughput for a two centrifuge system varies from 8-11  Mg/hr
(9-12 ton/hr) per centrifuge.  A spare  centrifuge is  generally  provided
on stand-by in the event that lines become plugged with  solid AS.
     From the centrifuges, the AS crystals enter the  dryer, which  is  the
principal source of AS particulate emissions.  Both rotary drum and fluidized
bed dryers are used in the caprolactam industry.  Typical  operating parameters
for a  caprolactam by-product AS dryer are presented in Table 2-2.
     Caprolactam, (CH2)5 CONH, is carried through the AS process stream in
small  quantities.  Caprolactam has a melting point of 60°C (140°F) and a
boiling  point of  140°C  (284°F), so any caprolactam present in the AS dryer
at the operating  temperatures  involved, about 85°C (185°F), is  in the liquid
phase.  This  residual hydrocarbon coats the AS crystals and serves as an
anti-caking  agent in  storage,  circumventing the  need for addition of other
substances to  prevent caking of the AS product.  The majority of capro-
lactam is  removed from  the  system  in this manner.
      From  the  dryer,  ammonium  sulfate  crystals are conveyed to a screening
 area for separation  and storage.   The  screening  operation  is typically
 carried out  within  a  building,  and  a screen  enclosure may  be used to prevent
 fugitive emissions.   The exhaust  gases  from  the  dryer are  passed through  a
 particulate  collection  device,  usually  a  wet  scrubber.  Some screening
 operations are also equipped with  wet  scrubbers.  Liquid waste  streams from
 the collection device are recycled back  into process streams,  eliminating
 water pollution concerns and increasing production efficiencies.
                                     2-7

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        TABLE  2-2.   TYPICAL  PARAMETERS FOR A CAPROLACTAM BY-PRODUCT
                          AMMONIUM  SULFATE DRYER
Parameter
Type/Value
Dryer


Product flow through dryer,  Mg/hr (tons/hr)

Air flow through dryer, scm/min  (scfm)

                        acm/min  (acfm)  (385°C  (184°F)

Air flow per ton of product, scm/Mg (scf/ton)

Ai r temperature

     Inlet to dryer, °C (°F)

     Outlet of dryer, °C (°F)
       (Inlet to scrubber)

Uncontrolled particulate emissions from dryer

     kg/Mg of product (Ib/ton)

          Rotary dryer

          FB dryer

AS product temperature and water content,  wt. percent

     Dryer inlet 66°C (150°F)
                          •
     Dryer outlet 80°C (175°F)

Water  evaporated per ton  of product, kg/Mg (Ib/ton)

Steam  input to dryer kg cal/hr (Btu/hr)

     Sat  125 psig at 177°C  (350°F)
Rotary or
 fluidized bed

23 (25)

825 (29,200)

1000 (35,500)

2152 (70,000)



 149 (300)

  85 (185)
26  (52)

111 (221)



2.0 - 2.5

0.1 - 0.5

24  - 25  (48 -  50)

3,024,000

    (12,000,000)
                                    2-8

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2.3.2  Synthetic Ammonium Sulfate   -  Synthetic AS is produced by
neutralizing concentrated sulfuric  acid with  pure ammonia in a crystal! izer/
reactor as indicated by  the  following chemical equation:
     2NH3 (gas)  +  H2S04 (liquid)  — >   (NH^SO^solid) + Heat
      Ammonia        Sulfuric  acid          Ammonium sulfate
     This reaction is highly exothermic,  liberating approximately
67,710 cal/g mole (120,000 Btu/lb mole) of  product.  Heat removal is
achieved by a cooling section  or external  heat exchanger.  The AS mother
liquor stream is injected at the point of the ammonia-sulfuric acid
reaction to improve the  cooling. A typical plant configuration for the
synthetic manufacture of AS  is shown  in Figure 2-2.  Material flow rates
in Figure 2-2 are based  on a typical  dryer production  rate of 13.7 Mg/hr
(15 tons/hr).
     The crystallizer may have an  "elutriation leg" at  the magma discharge.
Mother liquor flowing in this  leg blows back  or  "elutriates" the fine AS
particles into the main  chamber, but  allows the  larger  particles to pass
to the discharge point,  producing  a more  uniform crystal size distribution.
     The AS crystal slurry leaves the crystallizer and  is pumped to one
or more centrifuges, which remove most of the mother liquor and recirculate
it back to the crystallizer.  Upon  leaving the centrifuges the AS crystals
have a 1-2 percent moisture  content.
     The AS crystals are then  fed to  the  dryer,  the only significant
emission source in the process. Only rotary  dryers are known to be used
in synthetic AS production plants.  Operating parameters for the 13.7 Mg/hr
(15 ton/hr) dryer in Figure  2-2 are shown in  Table 2-3.

                                   2-9

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J.Ai*
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                                                                                                         3.700'
                                           Figure  2-2.   SYNTHETIC  AMMONIUM SULFATE  PROCESS
                                                                          FLOW DIAGRAM

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              TABLE  2-3.   TYPICAL  PARAMETERS  FOR A SYNTHETIC
                           AMMONIUM  SULFATE DRYER
Parameter
 Type/Value
Dryer
Product flow through dryer,  Mg/hr (ton/hr)

Air flow through dryer,  scm/min (scfm)
                        acm/min (acfm)  @  93°C  (200°F)
Air flow per ton of product,  scm/Mg (scf/ton)

Ai r temperature

     Inlet to dryer, °C (°F)

     Outlet to dryer, °C (°F)

AS uncontrolled emission from the dryer,
     kg/Mg (Ib/ton) of product

Product temperature and water content  percent

     Dryer inlet - 88°C (190°F)

     Dryer outlet - 93°C (200°F)

Water evaporated, kg/Mg (Ib/ton)
 Rotary,  direct
   f i red

 13.7  (15.0)

 135 (4750)
 170 (5920)
591 (19,000)



 232 (450)

  93 (200)

 26 (52)





 2.0 - 2.5

 0.1 - 0.5

 24 - 25  (48  - 50)
                                    2-11

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     Screening of the AS divides a coarse and a standard  product.   As  in
caprolactam by-product manufacture, screening takes  place inside  a  storage
building, and fugitive dust is minimal.   Synthetic plants may  add  a small
quantity of heavy hydrocarbon to the product  to prevent caking.
2.3.3  Coke Oven By-Product AS - In the  carbonization  of  coal  into  coke,
many volatile substances are liberated.   At  a temperature of 1000°C
(1832°F), which is common in steelmaking, the liberation  of ammonia in
the off-gases is optimized.  Formation of ammonium sulfate is  traditionally
the most common method for the recovery  of the ammonia off-gases  from
the coking process.  This is accomplished by  one of  three different
methods, which are classified according  to the means of contacting  the
ammonia with sulfuric acid.  These are the direct, indirect, and  semidirect
processes.  Most of the ammonia produced in  coke plants is recovered as
ammonium sulfate by the semidirect process.   The balance  is produced
in the form of concentrated ammonia liquors  by the indirect process.
The direct process also recovers ammonia directly as AS,  but this
process is not used in the U.S.^
     In the semidirect process the off-gases  are cooled and washed  to
remove tar and yield an aqueous condensate high in ammonia content.
The ammonia is released from the condensate in a still.   It is then
combined with the main gas stream, reheated  to approximately 21°C
(70°F), and scrubbed with a dilute (5 to 6 percent)  sulfuric acid  solution.
Ammonium sulfate crystals of high purity are  formed  and removed  as  product.
                                  2-12

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     The indirect process  recovers  ammonia  from the  coking off-gases as a



dilute ammonia liquor,  from which  ammonia is  stripped  and converted



to a concentrated liquor.   The dilute  liquor  is treated with steam in a



stripping column to release free ammonia present  in  salts such as ammonium



carbonate and ammonium sulfide.  The liquor is then  treated with lime to



decompose fixed salts such as  ammonium chloride,  after which it passes to



a second stripping column  where the remaining ammonia  is  released.  This



ammonia is recovered in a  more concentrated liquor and can be converted



directly to a solid in a crystallizer.



     In the direct process the off-gases are  first cooled for maximum



removal of tar, and are then passed through the crystal!izer/saturator



where they are washed with sulfun'c acid.   The AS crystals that form in



the liquor are recirculated until  the  desired crystal  size is attained.



There are problems associated  with  the direct process, such as deposition



of tar in the saturator and decomposition  of  ammonium  chloride carried by



the gas to form hydrochloric acid,  creating corrosion  problems.



     Figure 2-3 shows a schematic of the coke oven by-product ammonium



sulfate process.  The reaction between ammonia and sulfun'c acid is exo-



thermic, and a large portion of the generated heat is  used in evaporating



water from the sulfuric acid bath.   Approximately 1  kg of 77.8 percent



F^SO^ is consumed per kg of AS produced.    The AS crystals precipitate and



are pumped in a slurry to the centrifuges  for removal  of  liquids.  The



crystals are then conveyed to a dryer, where  the  moisture content is





                                   2-13

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ro
i
                                                                                               Hulk

                                                                                               Slorngp
                                                                                     Cyclone   1


                                                                           Pneumatic  >v     /

                                                                           Conveyor    \>/


                                                                   Heater   H	A*r     \	 nulk
                                                                                              Storage
                         Figure  2-3.  PROCESS FLOW  DIAGRAM FOR COKE  OVEN AMMONIUM SULFATE

                                       PLANTS SHOWING  ALTERNATE DRYING PROCESSES

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reduced to about 0.15 percent and sent to storage.   In coke oven  by-product



AS a small amount of gypsum may be added to prevent  caking.  Gypsum



preferentially combines with moisture from the atmosphere.



     Dewatering equipment varies in each plant,  and  may include vacuum



filters, centrifuges, and dryers in more than one combination.  Mother



liquor from the dewatering and drying processes  is  recycled back



into the process stream.  Table 2-4 lists operating  parameters  for  a



typical coke oven AS dryer.



     Two U.S. facilities have adopted Nippon Steel's TAKAHAX process for



coke oven gas desulfurization (COGD), of which AS is a by-product.   The



process changes were exempt from the NSPS based  on  the date for commence-



ment of construction.  Only one of the two plants is currently  in operation,



A slip stream from this process, rich in sulfur  salts, constitutes  the AS



feed stream.  Variations in the process may use  sodium carbonate  or



caustic soda as the alkali in place of ammonia.   In  either  case,  the end



product is sulfuric acid or elemental sulfur, respectively, instead of



AS.  The facility currently in operation produces AS as the end product.
                                   2-15

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        TABLE  2-4.   ESTIMATED PARAMETERS FOR A COKE OVEN BY-PRODUCT
                          AMMONIUM SULFATE DRYER
Parameter
 Type/Value
Dryer



Product flow through dryer,  Mg/hr (ton/hr)

Air flow through dryer, scm/min  (scfm)

Air mass flow assumed per ton product
     scm/Mg (scf/ton)

Ai r temperature

     Inlet to dryer, °C (°F)

     Outlet to dryer, °C (°F)

AS uncontrolled emission from the dryer,
     kg/Mg of product (Ib/ton)

Product temperature and water content  percent

     Dryer inlet - 49°C (120°F)

     Dryer outlet - 66°C (150°F)

Water  evaporated, kg/Mg (Ib/ton)

Steam  heat input to dryer, kg cal/hr (Btu/hr)
 Rotary vac. filter-
 dryer, centrifuge-
 dryer or  rotary dryer

 2.7  (3.0)

   99  (3,500)


 2203 (70,000)
  149  (300)

   80  (175)

  10.0 (20.0)a





  2.5

  0.5

  20 (40)

163,800 (650,000)
 a   Estimated  based on 1 percent of AS product appearing as uncontrolled
    dryer  emissions.
                                    2-16

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2.4  References

1.   Fertilizer  Reference Manual,  June  1982.  Published by the Fertilizer
     Institute.

2.   Commercial  Fertilizers  -  Consumption  for Year ended June 30, 1983,
     USDA Crop Reporting Board.

3.   Information provided in a letter  from F. L. Piguet, Allied Fibers
     and Plastics, to Jack Farmer, U.S.  Environmental Protection Agency,
     Research Triangle Park, N.C., dated August 2, 1984.

4.   Information provided in a letter  from Karl T. Johnson, The Fertilizer
     Institute,  to Peter Schindler,  U.S. EPA, dated  June 8, 1984.

5.   Information provided in telephone  conversation  by Max Beal, Nipro, Inc.,
     to Peter Schindler, U.S.  EPA, on  June 18, 1984.

6.   Information provided in telephone  conversation  by E. Harre, TVA
     National Fertilizer Development Center, to Peter Schindler, U.S.
     EPA, on May 30, 1984.

7.   Information provided in a letter  from Edwin A.  Harre, TVA National
     Fertilizer Development Center, to Naum Georgieff, U.S. Environmental
     Protection Agency, Research Triangle  Park, N.C., dated June 7, 1984.

8.   Ammonium Sulfate Manufacture - Background  Information for Proposed
     Emission Standards, EPA-450/3-79-034a, p.  9-3.

9.   Reports of plant trips to:  The Allied Chemical  Company,  Hopewell , Va;
     NIPRO  Inc., Augusta, GA; Dow Badische Company,  Freeport,  TX;  regarding
     ammonium sulfate plant emission standards  development.  Docket No. A-79-31,

10.  Coal,  Coke, & Coal Chemicals, p.  290, copy  provided with  letter  from
     John Stavik, Dravo/Still, to Naum Georgieff,  U.S. EPA, dated  July  11, 1984,

11.  Reference  10, p. 297.

12.  Information provided in letter and enclosures from  R. F.  Wyse, U.S.
     Steel,  to  Peter Schindler, U.S. Environmental  Protection  Agency,
     dated  July 27,  1984.
                                 2-17

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           3.    CURRENT STANDARDS  FOR  AMMONIUM  SULFATE  PLANTS

3.1  Affected  Facilities
     The NSPS  regulates newly constructed,  reconstructed,  and  modified
ammonium sulfate plants that produce AS as  a  caprolactam by-product,  as
a coke oven by-product, or by the  synthetic process  (direct  combination
of ammonia and sulfuric acid.)  Each ammonium sulfate  dryer  is the
affected facility.
     An existing ammonium sulfate  plant may be subject  to the  NSPS  if:
(1) it is modified by a physical  or operational  change  in an existing
facility thereby causing an increase in the emission rate to the  atmosphere
of particulate matter, or (2) if in the course of reconstruction  of the
facility, the fixed capital cost of the new components  exceeds 50 percent
of the cost that would be required to construct a comparable entirely new
facility that meets the NSPS.
3.2  Controlled Pollutants and Emission Levels
     Particulate matter is the pollutant regulated by  the NSPS, and dryer
emissions are limited to not more than 0.15 kg of particulate  matter per
Mg (0.30 Ib/ton) of AS produced.  Visible emissions are limited to not
more than 15 percent opacity.
3.3. Monitoring Requirements
     The promulgated standards require continuous monitoring of the mass
flow of  ammonium sulfate feed material to the crystal! izer.   Those facilities
with weigh scales are exempt from this requirement.  The feed  stream in  a
                                   3-1

-------
caprolactam plant is the oximation  AS  stream to the AS plant and the
oleum stream to the caprolactam rearrangement  reaction.  The feed stream
in synthetic and coke oven by-product  plants is the sulfuric acid stream
to the crystallizer.
     Another requirement of the standard  is continuous monitoring of the
pressure drop across the control  system for the affected facility to help
insure proper operation and maintenance of the system.  Mass flow
and pressure drop data, including calibration  measurements of the
instrumentation, must be maintained for 2 years by the affected facility.
     There is no in-stack opacity monitoring requirement due to the use
of wet scrubbing in most AS particulate control applications.  The presence
of water droplets in the stack would make the  exhaust gases difficult to
monitor by available equipment.
3.4. Testing Requirements
     The EPA Reference Methods (40  CFR 60, Appendix A) to  be used in
conjunction with compliance testing of AS dryers  include:
          1.  Method 5 for the concentration of particulate matter.
          2.  Method 1 for sample and velocity traverses.
          3.  Method 2 for velocity and volumetric  flow  rate.
          4.  Method 3 for gas analysis.
For Method 5, the sampling time for each  run  shall  be  60 minutes  minimum,
and the volume shall be at least 1.50 dry standard  cubic meters  (53 dry
standard cubic feet).  Methods for computing  particulate emission  rates
and AS production rates are contained in  40  CFR 60,  Subpart PP.
                                   3-2

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                       4.   STATUS  OF  CONTROL  TECHNOLOGY

4.1  Emission Sources
     The ammonium sulfate  dryer is the main  source  of  particulate  emissions
in the AS manufacturing process,  and  the only source which  is  regulated
by the NSPS.  Both fluidized bed  dryers and  rotary  dryers  are  used in  AS
producing facilities.   All  fluidized  bed dryers  found  in the industry  are
heated indirectly with steam-heated air.  Rotary dryers may be either  direct
fired (by oil or gas)  or steam heated.
     Gas flow rates are higher for steam heated  dryers—typically  2200 scm/Mg
of product (70,000 scf/ton), than for direct fired  units--600  scm/Mg  (20,000
scf/ton).  Fluidized bed dryers have  demonstrated higher  rates of  uncontrolled
emissions, largely due to fines being swept  out  of  the system.  Because this
characteristic creates a more granular, salable  product,  fluidized bed dryers
are more desirable from a production  standpoint.  Fluidized bed dryers exhibit
greater heat and mass transfer rates, and smaller space requirements  than  rotary
dryers with the same throughput.  Capital and operating costs  are  also less
for fluidized bed dryers, making them more economically desirable.1  Fluidized
bed dryers, however, would  require more efficient particulate  control  equipment
in order to comply with air pollution regulations,  as  the emission rates  per
ton of product are greater.
      Table  4-1 contains a summary of uncontrolled particulate emissions from
several dryersjn the  industry that were tested using EPA Method 5.2  The wide
range of uncontrolled  emissions (expressed as mass of particulate  emissions
per mass of  product)  is a result  of the various flow  rates for differing

                                     4-1

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TABLE 4-1.  SUMMARY OF UNCONTROLLED EMISSION DATA
       FROM EPA EMISSION TESTS ON AS DRYERS
Plant
A
B
C
D
Dryer Type
Rotary Drum
Fluidized Bed
Rotary Drum
Rotary Drum
Average Uncontrolled AS Emissions
gm/dscm
4.38
39.0
8.87
98.3
(gr/dscf)
( 1-93)
(17.2 )
( 3.91)
(43.2 )
kg/Mg
0.41
110.0
3.46
77.0
(Ib/ton)
( 0.82)
(221.0 )
( 6.92)
(153.0 )
                       4-2

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dryer systems.   The high rotary dryer emission  rate  at  Plant D was  attributed
to a high inlet emission load caused  by  a  process  variation  at the  plant.
It was indicated that the crystallizer at  Plant D  periodically goes  into  a
fines cycle, lasting anywhere from 10 to 15 hours, during  which  time a  much
heavier proportion of AS fines is produced in the  dryer product  than is normal.3
Plant personnel stated that the operator can prevent this  condition  by  varying
the dryer air flow rate, but this was not  done during testing  so as  to  maintain
constant operating conditions.  Particulate emission rates are directly
related to the gas-to-product ratio,  and are influenced by gas  velocity and
particle size distribution.  No additional data on uncontrolled  emissions
from AS dryers have become available since promulgation of the NSPS.
4.2  Emission Control Equipment in the Ammonium Sulfate Industry
     There have been no major changes in control technology since promulgation
of the  ammonium sulfate NSPS.  Wet scrubbing is used at all  of the operating
ammonium sulfate  facilities  for the  control of AS dryer particulate emissions.
The  use  of wet scrubbing  is  for environmental  reasons, as well  as to increase
production  efficiencies.   Wet  control processes allow  easy recycle of captured
AS  particles back into  process streams, increasing  production efficiency and
eliminating the  cost  of waste  disposal.   The moderately high water solubility
of  AS  makes wet  scrubbing and  recycle of  captured particulates  a viable
control  alternative.   Industry supplied operating and  performance data for a
number of  wet  scrubbers  in use is  presented  in Table 4-2.  Most of the scrubbers
 are of the low energy type with  pressure  drops equal to or  less than 15 cm
                                      4-3

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                           TABLE 4-2.  AMMONIUM SULFATE INDUSTRY-SUPPLIED WET SCRUBBER PERFORMANCE  DATA3

Plant F
Plant E
Plant B
Plant H
Plant G
Plant I
Plant C
Plant D
Scrubber
Vendor
Ducon
AAFb
AAF
Ducon
Ducon
	
MAC
NA
NA
Ducon
Ducon
Heil
AS Scrubber
Type
Centrifugal
Rotocloned
Rotoclone
Centrifugal6
Centri fugal
Venturi
Spray
Packed Tower &
NH3 Condenser
Packed Tower
Centrifugal
Centrifugal
Venturi
AS Production Gas Flow to Observed Scrubber
Rate Scrubber Pressure Drop
Mg/hr (TPH) sm3/min (scfm) cm H90 WC (in H00 WC)
	 	
	 1,127 (39,900)
	 410 (14,600)
	 810 (28,600)
19.1 (21) 144 ( 5,100)
19.1 (21) 242 ( 8,560)
14.7 (16) 73 ( 2,585)
8.50 ( 9.34) 90 ( 3,180)
16.2 (17.8 ) 112 ( 3,950)
8.4 (9.2 ) 85 ( 3,000)
7.6 (3)
12.7 (5)
12.7 (5)
34.0 (13.4)
22.9 ( 9.0)
25.9 (10.2)
17.3 ( 6.8)
UKf
UK
15.2 ( 6)
15.2 ( 6)
33.0 (13)
Scrubber L/G Ratio9
Liters/lOOOm3
(gal/1000 acf)
254 (1.9)
348 (2.6)
415 (3.1)
267 (2.0)
267 (2.0)
3,075 (23.0)
909 (6.8)
3,338 (25.0)
40,050 (300)
2,311 (17.3)
267 ( 2.0)
267 ( 2.0)
3,605 (26.9)
<•»  All data supplied by industry in response to EPA  114  letter  requests or from visits to AS production plants.
b  American Ai r Filter.
c  Not Applicable (not a standard design).
d  Trade name of American Air Filter Company.
e  Cyclones precede centrifugal  scrubbers.
f  Unknown.
9  Scrubber liquid-to-gas ratio.

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                       TABLE 4-2. (cont)  AMMONIUM SULFATE INDUSTRY-SUPPLIED WET SCRUBBER PERFORMANCE DATA
i
en



AS Particulate Concentrati
on
Scrubber Inlet Scrubber Outlet
mq/dsm3 (gr/dscf) mg/dsnP (gr/dscf)
PI
PI
PI
PI
PI
PI
PI
ant
ant
ant
ant
ant
ant
ant
F
E
B
H
G
I
C
	 220
	 57.2
	 708
	 87
	 48
28,500 (12.4) 11.5
	 25.2
9.2
	 41.2
	 48.1
36.7
(.096)
(.025)
(.309)
(.038)
(.021)
(.005)
(.011)
(.004)
(.018)
(.021)
(.016)
AS Mass Flow
Scrubber Inlet Scrubber
kg/hr (Ib/hr) kg/hr
	 	
	 5.6
	 1.2
1,909 (4,200) .45
.22
	 .14
	 .23
	 .254
	 .25
AS Mass
Outlet
(Ib/hr)

(12.4 )
( 2.67)
(i.o )
(.48 )
(.30 )
(.50 )
(.56 )
(.55)
Discharge
kg/Mg (1
.13 (
.032 (
.36 (
.26 (
.14 (
.037 (
.012 (
.007 (
.016 (
.030 (
.015 (
Rate
b/ton
.25 )
.065)
.72 )
.52 )
.27 )
.073)
.023)
.014)
.031)
.06 )
.031)
      Plant D

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(6 in.) WG.  The data contained  in  Table  4-2 were  provided by AS producers
during EPA plant visits  and  in  responses  to EPA  inquiries during development
of the NSPS in 1978-79,  and  do  not  reflect  any equipment modifications which
may have occurred since  that time.
4.2.1  Venturi Scrubbers -  Two  existing  AS plants employ venturi  scrubbers
to control particulate emissions.   Pressure drops  and  liquid-to-gas  ratios
are similar for both of  these control  devices.   Performance  data and emission
test data for the venturi  scrubber  at  Plant B  are  included in Table  4-2.  No
emission test data were  supplied for the  venturi  scrubber at Plant D.  Based
o~n test measurements of  the  scrubber inlet  and outlet  mass flows,  the  venturi
at Plant B has an average collection efficiency  of 99.96 percent,  which  is
typical of venturi scrubbers in  other applications.  Particulate emissions
average .037 kg/Mg of AS production.  A 25  percent AS  solution  was used  as
the scrubbing liquid, and although  the emission  test was conducted at
approximately 50 percent of  the maximum production rate, the collection
efficiencies  are similar to those measured  during a period of  full capacity
production.^
4.2.2  Centrifugal Scrubbers - Centrifugal  scrubbers are  employed  at a number
of AS  plants  for particulate control, including  two of the three  existing
caprolactam  plants.  Energy requirements and collection efficiencies of
centrifugal  scrubbers are generally lower than those of Venturis.  Emission
test  data  for centrifugal scrubbers at Plants C, E, and F  are  provided in
Table 4-2.   Pressure drops  range from 7.6 cm to 34.0 cm WG   (3  to  13.4 in. WG),
                                     4-6

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and mass emissions vary  from 0.015  to 0.26  kg/Mg  (0.031  to  0.52 ib/ton) of AS


production.   No centrifugal  scrubber  inlet  data are  available, and collection


efficiencies cannot be determined.

4.2.3  Other Wet Scrubbers in the AS  Industry  - Several  other wet scrubbing


systems currently in use for AS particulate control  include packed tower

scrubbers, spray type scrubbers, and  Type "N"  Rotoclones (a trade name  of


American Air Filter Corporation).  Particulate control  data for each  of these


control devices are presented in Table 4-2  (Plants H,  G, and I).  Collection


efficiencies of these devices are generally lower than those of previously


mentioned AS particulate control devices.  Vendor design efficiency  data  for


Rotoclones typically ranges from 90 to 99.3 percent  for particulates  3  microns


in diameter, with pressure drops of 15.3 to 28 cm (6 to 11  in.) WG  and  high


liquid-to-gas ratios.5  Collection efficiencies of packed towers  depend on


liquid-to-gas ratios and pressure drops.  One plant which designed  its  own


packed tower reports an estimated collection efficiency of  less than  90

percent.5  Spray-type scrubbers demonstrate collection efficiencies  near


75 percent for  most types of 2 micron particulates.  Pressure drops  are low,


usually 2.5 cm  to 5 cm  (1-2 in.) WG.6


4.2.4   Fabric Filtration in the Ammonium Sulfate Industry

Only one  known  domestic producer of  AS has used a baghouse for AS particulate


control,  but this plant has been mothballed since 1979.7  The unit  has  30m2


(320 ft2) of filter cloth which comprises  24 bags, and it employs a reverse

jet  cleaning mechanism.  The filter  medium is Dacron® felt, which exhibits


good acid resistance  and flex  abrasion.  At the operating gas flow rate of


approximately  35m3/min  (1250 acfm) the gas-to-cloth ratio of this baghouse


is 4:1.
                                      4-7

-------
     Fabric filters are adversely  affected  if  condensation  occurs  in  the



baghouse, and this is especially true  in  ammonium sulfate particulate control.



Caking of AS particles due to condensation  may cause  blinding  in fabric



filters.  It is imperative that the exhaust gas be maintained  at a temperature



above the dew point to avoid this  problem.   This is the  major  drawback in



employing fabric filters for AS particulate control.   Evidence of  condensation



problems at the existing baghouse  has  been  confirmed  by  AS  accumulations on



the inside wall of the inlet ducts, and  periodic shutdown for  bag  removal,



laundering, and reinstallation (every  30  days).  It is possible that  energy



requirements for maintaining temperatures above the dew  point  may  require



more energy than would ordinarily  be required  to operate the dryer.^



4.3  Plant Testing



     During the development of the existing NSPS for  ammonium  sulfate plants



a survey of producing facilities determined that very few met  the  criteria



for AS particulate emission testing to support an NSPS.  These criteria



i ncluded:



     0    Candidate best demonstrated  control  technology in operation



     0    Accessibility of potential  control equipment sampling ports



     0    Control equipment age and/or condition



     0    Availability of sampling ports  and support  scaffolding



     0    Reasonably nonturbulent  flow field



     0    Representative plant capacity



Four AS producing facilities were  selected  which met  the criteria  for testing,



and emissions testing was carried  out  by  EPA contractors at each facility,



designated A through D.  EPA Method 5  was used to determine AS particulate



                                     4-8

-------
emission rates and grain loadings  at  the inlet  and  outlet  of  each  control
device.  Table 4-3 describes the selected test  facilities,  type  of AS  production
process employed, and control technology in use.   Plant  E  was not  tested  by  EPA;
information was provided by a State Agency, and the test methodology was
judged acceptable by EPA.

           TABLE 4-3.  AS PARTICULATE CONTROL SYSTEMS TESTED  BY  EPA
Plant
Designation
A
B
C
D
E

AS
Process
Synthetic
Caprolactam
Synthetic
Syntheti c
Caprol act am

Controlled
Facility
Rotary Dryer
Fluid Bed Dryer
Rotary Dryer
Rotary Dryer
Fluid Bed Dryer

Control Technology
In Use
Baghouse
Venturi Scrubber
Centrifugal Scrubber
Venturi Scrubber
Cyclones and
Centrifugal Scrubber
      Results  of EPA  emission testing  at facilities A through D are summarized
 in  Table  4-4,  along  with  the industry-supplied emission data from Plant E.
 The wide  range of  uncontrolled  emission data  represents the varying process
 rates for AS  drying  equipment encountered  in  the  industry.  Lower parti cul ate
 removal  efficiencies at  Plants  A  and  C can  be attributed  partially to lower
 uncontrolled  dryer emission  rates at  these  respective  facilities.  With
 differences in uncontrolled  emission  rates  at Plants A and C near two orders
 of  magnitude  as compared with those of Plants B  and D,  comparison of outlet
 mass emissions only for  all  four  facilities may  be  somewhat misleading.

                                      4-9

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                 TABLE  4-4.   RESULTS OF EPA EMISSION TESTING
Plant
Designation
A
B
C
0
E
AS Production
Rate (Mg/hr)
16.4
26.5
15.2
8.4
8.9
Average
Uncontrolled
Emission Rate
(kg/Mg)
0.41
110.0
3.46
77.0
N.A.*
Average
Control led
Emission Rate
(kg/Mg)
.007
.156
.08
.14
.14
Particulate
Removal
Efficiency
(%)
98.3
99.9
97.7
99.8
N.A.
*  Not Available


4.5  References

1.   Ammonium Sulfate Manufacture  -  Background  Information for Proposed
     Emission Standard,  EPA-450/3-79-034a,  p. 3-10.

2.   Reference 1, p.  3-11.

3.   Reference 1, p.  9-12.

4.   Reference 1, p.  4-10.

5.   Reference 1, p.  4-12.

6.   Reference 1, p.  4-13.

7.   Information provided by Occidental  Chemical  Corporation  in  a telephone
     conversation between Russ Bowman  and  Peter Schindler, U.S.  Environmental
     Protection Agency,  Research Triangle  Park, N.C.,  on July 13, 1984.

8.   Reference 1, p.  4-15.
                                     4-10

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                         5.   COMPLIANCE  TEST  RESULTS
     Since proposal  and  promulgation  of  the NSPS, there have been no new,
reconstructed, or modified facilities which have  come  under the NSPS.  Emission
testing, however, has been performed  at  some  existing  facilities, and testing
results have been obtained by EPA.
     A second State-approved emission test was  performed  at Plant E by a
contractor to the company and the State  has  provided the  test  results to
EPA.l  The test results  are contained in Table  5-1, and are well  below the
NSPS requirements, at .04 kg/Mg of AS production.  This facility  operates  one
rotary dryer  and one fluidized bed dryer.  The  exhaust air from both  dryers
is combined and treated in a series of fines removal  cyclones  before  it  is
redistributed to two wet scrubbers.  The scrubbers, a  Ducon  type UW-3 size
126  and  a  Ducon type UW-3 size 72, are of the centrifugal type, and air  flows
are  1250 m3/min  (44,000 acfm) and 450 m3/min (16,000 acfm),  respectively.
The  scrubbers discharge to the atmosphere through  separate stacks at  about
80 feet  above the ground.  The emission  test data  provided by the State  was
 for  the size  72  scrubber, which  is the  smaller of  the two, and the newer
 control  device.2
      In response to a written  request from EPA,  emission  data have been
 provided from a  caprolactam by-product  AS plant, designated Plant J.  This
 plant  expanded AS production capacity in 1980, but the expansion is not
 subject to NSPS  based on  the date for commencement of  construction.  The
 plant  controls  particulate emissions from rotary dryers,  centrifuges, and
 fugitive sources by the use of wet scrubbers.  Two scrubbers were  replaced
 recently, one handling  centrifuge emissions  (1979) and the other treating
 rotary dryer emissions  (1980).  Both new units  are Ducon UW-4  scrubbers,
                                      5-1

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size 42 and 66, respectively,  and  operating efficiencies are reported to be

99 percent for each.   The  centrifuge  abatement  reduced AS particulate emissions

from 14.6 Mg/yr to 5.1 Mg/yr,  though  this  emission  source is not  subject to

NSPS.  The scrubbing  liquor for all dust collectors  at this plant is a recir-

culated oxime sulfate solution with a 10 gpm  liquid  rate per scrubber.

Emissions testing was performed for the  rotary  dryer and new scrubber addition

as part of the State  permitting process, and  emission results were  0.021 kg/Mg

AS produced.3  Test results for this  dryer at Plant  J, designated dryer #4,  are

presented in Table 5-1.  Additional controlled  emissions data  for three other

rotary dryers at Plant J are included in Table  5-1.   Dryers #1,  #2,  and #3 were

tested in conjunction with the State's Prevention of Significant  Deterioration

(PSD) program.  Dryer #1 was tested in November 1980, and  #2  and  #3 were tested

in December 1983.4   The reported emission data from Table  5-1  indicates that

the  NSPS  for  ammonium sulfate particulate  matter (.15 kg/Mg AS  produced) is

being easily  achieved by current control  methods.

               TABLE  5-1.  INDUSTRY SUPPLIED EMISSION TEST  DATA
     Plant      Controlled
                 Facility
             Production    Air Flow     Controlled
Control          Rate         Rate      Emission  Rate
              (Mg/hr)     (DSCM/min)       (kg/Mg)
E


J






#1
#2
#3
#4
1 Rotary & 1 FB
(dryer-stream
combi ned)
Rotary Dryer
Rotary Dryer
Rotary Dryer
Rotary Dryer
- -1 - - 1
Centrif .
Scrubber
(CS)
CS
CS
CS
CS
9.85


44.5
36.4
81.8
52.7
421.7


215.9
221.8
359.4
196.3
0.04


0.031
0.053
0.090
0.021
                                      5-2

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5.1  References

1.   Letter from Lou  Musgrove,  State  of Georgia, Department of Natural
     Resources,  Environmental  Protection Division, to Peter Schindler,
     U.S. Environmental  Protection  Agency, Research Triangle Park, N.C.,
     dated June  11,  1984.

2.   Information provided  in  a telephone conversation between Lou Musgrove,
     State of Georgia EPD,  and Peter  Schindler, U.S. EPA, on October  9, 1984.

3.   Letter from F.  L. Piguet, Allied Fibers  &  Plastics, to Jack Farmer,
     U.S. Environmental  Protection  Agency, Research Triangle Park, N.C.,
     dated August 2,  1984.

4.   Information provided  in  a telephone conversation between Evans Drake,
     Allied Fibers and Plastics,  and  Peter Schindler, U.S. EPA, on
     October 5,  1984.
                                     5-3

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                              6.    COST  ANALYSIS

     This chapter presents the updated costs  of a control  system required
to best achieve the current NSPS  for ammonium sulfate particulate matter.
Venturi scrubbers are the selected control  systems for cost  analysis  in  the
three segments of the AS industry, as they  represent best  demonstrated control
technology (8DCT).  Capital and annualized  costs  of venturi  scrubbers are
estimated for three new model AS  plants; a  22.7 Mg (25 ton)  per hour  caprolactam
by-product plant, a 13.6 Mg (15 ton) per hour synthetic plant,  and a  2.7 Mg
(3 ton) per hour coke oven by-product plant.   All costs are  presented in
March 1984 dollars and are considered to be accurate to +. 30 percent.
     The control system includes  all the equipment and auxiliaries required
to provide the specified emission control.   The capital cost of a control
system includes  all the cost items necessary to design, purchase, install,
and commission the control system.  In addition to the direct costs,  the
capital cost  includes such indirect items as engineering,  contractor's fee,
construction  expense, and  a contingency.
     The  annualized cost  represents the cost of owning and operating the
control  system.  The operating cost covers the utilities,  supplies, and
labor  required to  operate  and maintain the system on a day-to-day basis.
The cost  of  owning the system includes capital-related charges such as
capital  recovery,  property taxes,  insurance, and  administrative charges.

6.1  Capital  Costs
     The  capital  costs for a  venturi  scrubbing system  are estimated for
three  model  plants,  representing  each segment  of  the AS industry.  Cost
breakdowns  for  each  model  plant  are  presented  in  Tables 6-1 through  6-3.
                                      6-1

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       TABLE 6-1.  CAPITAL COST SUMMARY  FOR  A  VENTURI  SCRUBBING SYSTEMS
            (Caprolactam By-Product  Plant  with 22.7  Mg/hr  Capacity)


Description                                                Cost (10-3 dollars)

A.   Di rect Costs

     1.    Scrubber, fan and auxiliaries  (C)                         113.3

     2.    Instruments and controls  (10%  of C)                        11.3

     3.    Taxes (3% of C)                                             3.4

     4.    Freight (5% of C)                                           5.7

                                 Base Price  (B)                     133.7

     5.    Installation^ (56% of B)                                   74.9

                                 Total  Direct  Costs  (TDC)           208.6

B.   Indirect Costs

     1.    Engineering and supervision (10% of  B)                     13.4

     2.    Construction and field (10% of B)                          13.4

     3.    Construction Fee (10% of  B)                               13.4

     4.    Start-up (1% of B)                                          1.3

     5.    Performance Test (1% of B)                                  1.3

     6.    Contingencies (3% of B)                                     4.0

                                 Total  Indirect Cost (TIC)          46.8

                                 Total  Capital Cost                 255.4


a  March 1984 dollars.

b  Includes factors for foundations and supports, handling and erection,
   piping,  electrical, insulation,  and paint.   Does  not include costs
   for site preparation, facilities, and buildings.

Source:   " Estimating Air Pollution  Control Costs," Part II, Table I.

                                     6-2

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       TABLE 6-2.   CAPITAL COST SUMMARY  FOR  A  VENTURI  SCRUBBING SYSTEM*
                  (Synthetic Plant  with  13.6 Mg/hr  Capacity)


Description                                                Cost (103 dollars)

A.   Direct Costs

     1.   Scrubber, fan and auxiliaries  (C)                          45.9

     2.   Instruments and controls  (10%  of C)                         4.6

     3.   Taxes (3% of C)                                            1.4

     4.   Freight  (5% of C)                                          2.3

                                 Base Price  (B)                      54.2

     5.   Installation^ (56% of B)                                   30.4

                                 Total Direct  Costs (TOC)            84.6

B.   Indirect Costs

     1.   Engineering and supervision (10% of  B)                      5.4

     2.   Construction and field (10% of B)                           5.4

     3.   Construction Fee (10% of  B)                                5.4

     4.   Start-up (1% of B)                                         0.5

     5.   Performance Test (1% of B)                                  0.5

     6.   Contingencies (3% of B)                                    1.6

                                 Total  Indirect  Cost  (TIC)           18.8

                                 Total Capital  Cost                103.4



a  March 1984 dollars.

h  Includes factors for foundations and  supports,  handling  and erection,
   piping, electrical, insulation,  and paint.   Does not  include costs
   for site preparation, facilities,  and buildings.

Source:  "Estimating Air Pollution  Control Costs,"  Part  II, Table  I.

                                     6-3

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       TABLE 6-3.   CAPITAL COST SUMMARY  FOR  A  VENTURI  SCRUBBING SYSTEMa
               (Coke Oven By-Product  Plant with  2.7 Mg/hr  Capacity)


Description                                                Cost (10^ dollars)

A.   Di rect Costs

     1.   Scrubber, fan and auxiliaries  (C)                          40.6

     2.   Instruments and controls  (10%  of C)                          4.1

     3.   Taxes (3% of C)                                             1.2

     4.   Freight  (5% of C)                                           2.0

                                 Base Price  (B)                      47.9

     5.   Installation13 (56% of B)                                   26.8

                                 Total Direct  Costs  (TDC)            74.7

B.   Indirect Costs

     1.   Engineering and supervision (10% of  B)                      4.8

     2.   Construction and field (10% of B)                            4.8

     3.   Construction Fee (10% of  B)                                 4.8

     4.   Start-up (1% of B)                                           .5

     5.   Performance Test (1% of B)                                    .5

     6.   Contingencies (3% of B)                                     1.4

                                 Total  Indirect  Cost  (TIC)          16.8

                                 Total Capital Cost                  91.5




a  March 1984 dollars.

b  Includes  factors  for foundations and  supports, handling and erection,
   piping,  electrical, insulation,  and paint.   Does  not include costs
   for site  preparation, facilities,  and buildings.

Source:  "Estimating Air Pollution  Control  Costs," Part II, Table I.

                                     6-4

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The methods for determining representative capital  costs  are described  in
the EPA publication "Estimating Air Pollution  Control  Costs," May  1984.  This
publication is a compilation of 18 articles on air  pollution control  cost
estimating which appeared in Chemical  Engineering magazine  from October  6,
1980 to April  30, 1984.  All costs in  this study were  updated to March  1984
dollars by the Chemical Engineering Plant Cost Index for  fabricated equipment.
The operating parameters for the venturi  system used in this cost  study  are
presented in Table 6-4.  The venturi  scrubber  is evaluated  for three  different
air flow rates, typical of the dryers  in  each  AS industry segment.  Volumetric
flow rate, pressure drop, and materials  of construction are the main  variables
for determining venturi scrubber capital  costs.
6.2  Annualized Costs
     In the ammonium sulfate industry  the annualized cost of operating  a
particulate control device is a function  of the number of hours the dryer
operates per year.  This value determines operating costs such as  labor,
utilities, and overhead.  In this study,  AS dryers  are assumed to  operate
at the following rates:  8,400 hours/year for  caprolactam by-product  plants,
5,400 hours/year for synthetic plants, and 7,400 hour/year  for coke oven
by-product plants.  Annualized costs  and  cost  factors  are calculated  from
current labor prices and from Part II  of  "Estimating Air  Pollution Control
Costs," and are updated to March 1984  dollars.
     Annualized cost breakdowns for venturi scrubbers  in  each of the  three
regulated AS industry segments are presented in Tables 6-5  through 6-7.
Credits for recovery of AS dryer emissions by  venturi  scrubbers help  to
                                      6-5

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               TABLE  6.4  VENTURI  SCRUBBER  OPERATING  PARAMETERS






A.   Pressure drop:   30.5 cm (12  in)  H20



B.   Liquid-to-gas ratio:   0.33 m3/100m3  (25  gal/103  ft3)




C.   Operating temperatures



     1.   Inlet:   79°C (175°F)



     2.   Outlet:   43°C (110°F)



0.   Construction materials:  fiberglass  lined carbon steel



E.   Fan



     1.   Location:   between dryer and venturi



     2.   Materials:   304 SS



     3.   Head pressure:  38.1  cm (15 in) H20 @ 21°C, 1  atm



     4.   Type:  radial tip



F.   Average venturi  life:  10 yr



G.   Particulate removal efficiency:   99.9%



H.   Scrubbing liquor:  25% AS solution



I.   Gas flow  rate from dryer



     1.  Caprolactam:  1005 m3/min (35,500 cfm)



     2.  Synthetic:  168 m3/min (5,920 cfm)



     3.  Coke  oven:  199 m3/min (4,200 cfm)
                                     6-6

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      TABLE 6-5.   ANNUALIZEO  COST  SUMMARY  FOR A VENTURI SCRUBBING SYSTEM
          (Caprolactam By-Product  Plant with 22.7 Mg/hr Capacity)

Cost Element                                              Cost  (lo3 dollars)
A.   Direct Operating Costs
     1.   Utilities
          a.   Water ($0.40/1000 gal)                             17-9
          b.   Electricity ($0.05/kwh)                            54.5
     2.   Operating Labor
           a.   Direct ($10.89/hr @ 4 hrs/shift)                   45.7
           b.   Supervision (15% Direct  Labor)                       6.9
     3.    Maintenance
           a.   Labor  (110% x Direct Labor @ 1  hr/shift)           12.6
           b.   Materials  (100% x Maint. Labor)                    12.6
 B.   Capital Charges
     1.    Overhead  [80% x  (2a + 2b + 3a)]                        52.2
     2.    Fixed Costs
           a.   Capital Recovery (16.3% x Capital  Costs)           41.6
           b.   Insurance,  taxes,  admin. (4% x Capital Costs)     10.2
 C.    Subtotal                                                    254-2
 D.    Credit  for  Recovered  Product3                           (1,012.8)
 E.    Net Annualized  Cost                                      (  758.6)
 a   Based on a $60/Mg price  for  by-product AS, with 20% reprocessing charge,
 b   Values in parenthesis  are  cost  savings.
 Source:   "Estimating Air Pollution  Control Costs," Part II, Table III.
                                      6-7

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      TABLE 6-6.   ANNUALIZED  COST  SUMMARY  FOR A VENTURI SCRUBBING SYSTEM
                   (Synthetic Plant  with 13.6 Mg/hr Capacity)

Cost Element                                              Cost  (1()3 dollars)
A.   Direct Operating Costs
     1.   Utilities
          a.   Water ($0.40/1000 gal)                               1.9
          b.   Electricity ($0.05/kwh)                              5.8
     2.   Operating Labor
          a.   Direct ($10.89/hr @ 4 hrs/shift)                   29.4
          b.   Supervision (15% Direct  Labor)                       4.4
     3.   Maintenance
          a.   Labor (110% x Direct Labor  @ 1  hr/shift)             8.1
          b.   Materials (100% x Maint. Labor)                      8.1
B.   Capital Charges
     1.   Overhead  [80% x (2a + 2b + 3a)]                         33.5
     2.    Fixed Costs
           a.   Capital Recovery (16.3% x Capital  Costs)            16.8
           b.   Insurance, taxes,  admin. (4% x Capital Costs)       4.1
 C.    Subtotal                                                    112<1
 D.    Credit  for Recovered  Product9                              (152.0)b
 E.    Net Annualized  Cost                                        ( 39-9)
 a   Based on a $100/Mg price  for  synthetic  AS, with 20%  reprocessing charge.
 b   Values in parenthesis  are cost  savings.
 Source:   "Estimating Air Pollution  Control  Costs," Part  II, Table  III.
                                      6-8

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      TABLE  6-7.   ANNUALIZED  COST  SUMMARY  FOR A VENTURI SCRUBBING SYSTEM
            (Coke Oven  By-Product  Plant with a 2.7 Mg/hr Capacity)

Cost Element                                              C°st <103 d°11ars>
A.   Direct  Operating Costs
     1.   Utilities
          a.   Water ($0.40/1000 gal)                               I-9
          b.   Electricity ($0.05/kwh)                              5-8
     2.   Operating Labor
          a.   Direct ($10.89/hr @ 4 hrs/shift)                   40.3
          b.   Supervision (15% Direct  Labor)                       6-°
      3.   Maintenance
          a.   Labor (110% x Direct Labor @ 1  hr/shift)           11.1
          b.   Materials  (100% x Maint. Labor)                     H.l
 B.    Capital  Charges
      1.   Overhead  [80%  x  (2a + 2b + 3a)]                         45.9
      2.   Fixed  Costs
          a.   Capital Recovery (16.3% x  Capital Costs)           14.9
          b.    Insurance,  taxes,  admin.  (4% x Capital Costs)       3.7
 C.   Subtotal                                                    140'7
 D.   Credit for Recovered Product3                                (9.6)
 E.   Net Annualized Cost                                         131-1

 a   Based on a $60/Mg price for by-product  AS,  with  a  20%  reprocessing charge,
 b   Values in parenthesis are cost  savings.
 Source:  "Estimating Air Pollution  Control  Costs," Part  II, Table III.
                                      6-9

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offset annualized costs,  which  improves  the  cost  effectiveness  for  participate


removal.  In this study,  the recovery credits  in  a  22.7  Mg/hr caprolactam



by-product AS plant and in a 13.6 Mg/hr  synthetic AS  plant  create a net



savings in annualized costs.  This does  not  hold  true for the coke  oven


by-product AS plant because a much lower AS  production rate (2.7 Mg/hr)


and lower uncontrolled emissions limit the collected  particulates available



for capture and process recycle.


     Credits for recovered product will  vary directly with  changes  in the


market price of ammonium sulfate.  Credits for this cost study  are  calculated


based on a March 1984 average wholesale  price of  $60/Mg for by-product AS and


$100/Mg for synthetic granular AS, with  a 20 percent  reprocessing  charge.1



Average U.S. market prices for AS over the past years are presented in Table 6-8.



6.3  Cost Effectiveness


     The cost effectiveness of controlling AS particulate emissions can



be related to the quantity of pollutants removed  from dryer exhaust streams



by using the annualized costs as  a basis.  This study utilizes  a 99.9 percent



efficient particulate  recovery rate by the control  device,  and  particulate


emission  rates  from typical AS dryers as listed in Chapter 2.  The calculated


cost  effectiveness of  venturi scrubbers for AS particulate control  at each
                                 •

model  plant  is  presented  in Table 6-9.  The cost effectiveness  varies from


a  savings of $36/Mg  of particulate removed in the  caprolactam by-product


plant  to  a  cost of S655/Mg  of particulate removed  in  the coke oven by-product



AS plant.   The  synthetic  AS  plant in  this study  demonstrated a savings of
                                      6-10

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         TABLE 6-8.   AVERAGE  U.S.  RETAIL  PRICE  FOR  AMMONIUM  SULFATE



          Month/Year                   Price (S/ton)

           March 1984                      150

           March 1983                      146

           March 1982                      165

           March 1981                      150

           March 1980                      138

           March 1979                      118

           March 1978                      109

           March 1977                      101

           April 1976                       98.20

           April 1975                      148

           April 1970                       52.40

           April 1965                       53.40
Sources:
  Fertilizer Trends 1982 - TVA National  Fertilizer  Development Center.
  Prices Paid by Farmers - Crop Reporting  Board,  SRS,  USDA,  October 1983,
  Information provided from Paul  Andalinas,  USDA.
                                     6-11

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       TABLE 6-9.   COST EFFECTIVENESS  OF AS  PARTICULATE RECOVERY USING
                    VENTURI  SCRUBBERS  (March 1984 dollars)
                Plant Size
Plant Type    Mg/hr (ton/hr)
Annualized Cost   AS Removed3 Cost  Effectiveness
  ($1000/yr)	(Mg/yr)a   ($/Mg  AS  Removed)
Caprol actam
Synthetic
Coke Oven
22.7
13.6
2.7
(25)
(15)
( 3)
[758. 6]b
[ 39.9]
131.1
21,095
1,915
200
[ 36]
C 21]
655
a   Based on 99.9% collection efficiency.

b   Brackets indicate cost savings.
                                     6-12

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$21 per Mg particulate removed.   These  values  are  sensitive to AS market prices

and particulate recovery  efficiencies.


6.4  References

1.   Information obtained in a telephone  conversation  between E. Harre, TVA
     National  Fertilizer  Development  Center, and Peter Schindler, U.S. EPA,
     on September 7,  1984.
                                     6-13

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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA-450/3-85-004
2.
4, TITLE AND SUBTITLE
Review of Standards of Performance for Ammonium
Sulfate Manufacture
7. AUTHOR(S)
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Office of Air Quality Planning and Standards
U.S. Environmental Protection Agency
Research Triangle Park, N.C. 27711
12. SPONSORING AGENCY NAME AND ADDRESS
Director for Air Quality Planning and Standards
Office of Air and Radiation
U.S. Environmental Protection Agency
Research Triangle Park, N.C. 27711
3. RECIPIENT'S ACCESSION NO.
5. REPORT DATE
February 1985
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO.
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
13. TYPE OF REPORT AND PERIOD COVERED
14. SPONSORING AGENCY CODE
EPA/200/04 j
15. SUPPLEMENTARY NOTES ' 	 ~~ 	 ~
        This report  presents  the findings of the 4-year review of the new  source
   performance standards  for  ammonium sulfate manufacture.  Affected facilities
   are those dryers  at  plants that  manufacture ammonium sulfate as a caprolactam
   by-product, as  a  coke  oven by-product, or by synthetic manufacture (direct
   combination of  ammonia and sulfuric acid).

17- KEY WORDS AND DOCUMENT ANALYSIS
a. DESCRIPTORS
Air Pollution
Pollution Control
Ammonium Sulfate Manufacturing
Caprolactam
18. DISTRIBUTION STATEMENT
Unlimited
b. IDENTIFIERS/OPEN ENDED TERMS
Air Pollution Control
Stationary Sources
19. SECURITY CLASS (this Report)
Unclassified
20. SECURITY CLASS 1 This page)
Unclassified
c. COS ATI Field/Group
135
21. NO. OF PAGES
Rfi
22. PRICE
EPA Form 2220-1 (Rev. 4-77)   PREVIOUS EDI TION is OBSOLETE

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