United States       Office of Air Quality        EPA-450/3-85-012
Environmental Protection  Planning and Standards       March 1985
Agency         Research Triangle Park NC 27711
Air
Review of New
Source Performance
Standards for
Sulfuric Acid Plants

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                                  EPA-450/3-85-012
Review of New Source Performance
  Standards for Sulfuric Acid Plants
           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, North Carolina 27711

                   March 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 the National Technical Information Services, 5285 Port Royal Road,
Springfield, Virginia 22161.

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                           TABLE  OF CONTENTS
LIST OF ILLUSTRATIONS                                              v

LIST OF TABLES                                                    vi

1.0   EXECUTIVE SUMMARY                                           1-1

1.1   Best Demonstrated Control  Technology                        1-1
1.2   Current S02 NSPS Levels Achievable With Best                 1-2
      Demonstrated Control  Technology                             1-3
1.3   Current Acid Mist Levels (and Related Opacity  Levels)
      Achievable With Best  Demonstrated Control  Technology
1.4   Cost Considerations Affecting the SOe NSPS                  1-3
2.0   THE SULFURIC ACID MANUFACTURING INDUSTRY                    2-1

2.1   Industry Characterization                                   2-1
      2.1.1   Geographic Distribution                             2-1
      2.1.2   Production                                          2-1
      2.1.3   Industrial Trends                                   2-6
2.2   Contact Process for Sulfuric Acid Production                2-8
      2.2.1   Elemental Sulfur Burning Plants                     2-9
      2.2.2   Spent Acid and Other By-Product Plants              2-9
2.3   Emissions from Contact Process Sulfuric Acid Plants          2-9
      2.3.1   Sulfur Dioxide                                      2-11
      2.3.2   Acid Mist Formation                                 2-14
      2.3.3   Visible Emissions (Opacity)                         2-18
      2.3.4   Oxides of Nitrogen                                  2-20
2.4   References                                                  2-21

3.0   CURRENT STANDARDS FOR SULFURIC ACID PLANTS                  3-1

3.1   Background Information                                      3-1
3.2   Facilities Affected                                         3-2
3.3   Controlled Pollutants and Emission Levels                   3-2
3.4   Testing and Monitoring Requirements                         3-4
      3.4.1   Testing Requirements                                3-4
      3.4.2   Monitoring Requirements                             3-5
3.5   References                                                  3-7

4.0   STATUS OF CONTROL TECHNOLOGY                      _         4-1

4.1   Control Technology Applicable to the NSPS Control  of S02
      Emissions From Contact Process Sulfuric Acid Plants
      4.1.1   Dual Absorption Process                             4-1

                                  ii i

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      4.1.2   Sodium Sulfite  -  Bisulfite  Scrubbing               4-6
      4.1.3   Ammonia Scrubbing                                 4-7
      4.1.4   Molecular Sieves                                   4-7

4.2   Control  Technology Applicable  to the  MSPS  for  Acid  Mist
      Emissions From Contact  Process  Sulfuric  Acid Plants       4-8
      4.2.1   Vertical  Tube Mist  Eliminators                     4-9
      4.2.2   Vertical  Panel  Mist Eliminators                    4-12
      4.2.3   Horizontal Dual  Pad Mist Eliminators               4-14
4.3   References                                                4-17

5.0   COMPLIANCE TEST RESULTS                                   5-1

5.1   Analysis of NSPS Compliance Test Results                  5-1
5.2   Comparison of NSPS Compliance  Test  Data  with
        Day-To-Day Emission Control  Performance                  5-4
5.3   Analysis of SO? Excess  Emissions Reports                  5-5
5.4   References                                                5-7

6.0   COST ANALYSIS                                             6-1

6.1   Dual Absorption Process                                   6-1
      6.1.1   Capital Costs                                     6-1
      6.1.2   Annualized Costs                                  6-2
6.2   Molecular Sieve Process                                   6-9
      6.2.1   Capital Costs                                     6-9
      6.2.2   Annualized Costs                                  6-9
6.3   Sodium Sulfite-Bisulfite Process                          6-9
      6.3.1   Capital Costs                                     6-9
      6.3.2   Annualized Costs                                  6-11
6.4   Ammonia Scrubbing                                         6-11
      6.4.1   Capital Costs                                     6-11
      6.4.2   Annualized Costs                                  6-16
6.5   Mist Eliminators                                          6-21
      6.5.1    Capital  Costs                                    6-21
      6.5.2    Annualized Costs                                 6-21
6.6   Sulfur Dioxide Monitors                                   6-21
      6.6.1    Capital  Costs                                    6-21
      6.6.2    Annualized Costs                                 6-23
6.7   Cost Effectiveness                                        6-23
      6.7.1    Sulfur Dioxide  Control                           6-23
      6.7.2    Sulfuric Acid Mist Control                       6-25
6.8   References                                                6-28
                                   iv

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                            LIST  OF  FIGURES

Figure No.                                                 Page


  2-1        Contact  Process  Sulfuric Acid Plants
            Completed  in  U.S.  Since  1971                    2-4

  2-2       Gross  Annual  Production  of  Sulfuric Acid
            (New and Fortified),  1971 to 1983               2-5

  2-3       Sulfuric Acid Consumed in U.S. by End
            Use, 1983                                       2-8

  2-4       Contact-Process  Sulfuric Acid Plant Burning
            Elemental  Sulfur                               2-11

  2-5       Contact-Process  Sulfuric Acid Plant Burning
            Spent  Acid                                     2-13

  2-6       Sulfuric Acid Plant Feedstock Conversion
            vs.  Volumetric and Mass  S02 Emissions at
            Various  Inlet S02  Concentrations by Volume      2-16

  2-7       Sulfuric Acid Plant Concentrations of Mist for
            Mass Stack Emissions  per Unit of Production at
            Inlet  SO?  Volume Concentrations                 2-20

  4-1        Dual  Absorption  Sulfuric Acid Plant Flow
            Diagram                                         4-5

  4-2       Vertical Tube Mist Eliminator Installation      4-10

  4-3       Vertical Panel Mist Elminator Installation      4-13

  4-4       Horizontal  Dual  Pad Mist Eliminator             4-16

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                           LIST OF TABLES

Table No.                                                       Page

  2-1       NSPS Sulfuric Acid Plants                            2-2

  2-2       Sulfuric Acid Production                             2-6

  2-3      Sulfur Dioxide Feed and Emissions  for
           Four-Stage Converters                                2-14

  4-1      Contact Sulfuric Acid Plants Built Since
           Proposal  of the NSPS                                 4-2

  5-1      NSPS Compliance Test Results for Sulfuric
           Acid Plants                                          5-2

  6-1      Capital Cost Summary - Incremental Cost for
           Dual Absorption 750 TPD Plant                        6-3

  6-2      Capital Cost Summary - Incremental Cost for
           Dual Absorption 1500 TPD Plant                       5-4

  6-3      Consumption and Unit Cost Estimates for
           Annual Incremental  Operating Cost  of Dual
           Absorption                                           6-5

  5-4      Annualized Cost Summary - Incremental Cost
           for Dual  Absorption 750 TPD Plant                     6-7

  6-5      Annualized Cost Summary - Incremental Cost for
           Dual Absorption 1500 TPD Plant                       6-8

  6-6      Capital and Annualized Cost Summary -
           Molecular Sieve Process                              6-10

  6-7      Capital Cost Summary - Sodium Sulfite-Bisulfite
           Scrubbing 750 TPD Plant                              6-12

  6-8      Capital Cost Summary - Sodium Sulfie-Bisulfite
           Scrubbing 1500 TPD Plant                             6-13

  6-9      Annualized Cost Summary - Sodium Sulfite-Bisulfite
           Scrubbing 750 TPD Plant                              5-14

  6-10     Annualized Cost Summary Sodium Sulfite-Bisulfite
           Scrubbing 1500 TPD Plant                             5-15
                                      VI

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Table No.                                                    Page

  6-11       Capital  Cost Summary -  Ammonia
            Scrubbing 750 TPD Plant                          6-17

  6-12       Capital  Cost Summary -  Ammonia  Scrubbing
            1500 TPD Plant                                   6-18

  6-13       Annual ized Cost Summary -  Ammonia Scrubbing
            750 TPD  Plant                                    6-19

  6-14       Annual ized Cost Summary -  Ammonia Scrubbing
            1500 TPD Plant                                   6-20

  6-15       Capital  and Annual ized  Cost  Summary  -
            Mist Eliminators                                 6-22

  6-16       Capital  and Annualized  Cost  Summary  -
            Continuous Sulfur Dioxide  Monitors               6-24

  6-17       Cost Effectiveness  - Sulfur  Dioxide  Control       6-26

  6-13       Cost Effectiveness  - Sulfuric Acid Mist Control   6-27

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1.0  EXECUTIVE SUMMARY

     The objective of this report is to review the new source performance

standards (NSPS) for sulfuric acid plants in terms of developments  in  control

technology, economics and new issues that have evolved since the original

standard was promulgated in 1971.  The achievability of the standard and  the

potential for making the standard more restrictive are analyzed in  the light

of technical and cost considerations and compliance test data available for

plants built since the promulgation of the NSPS.  The NSPS review includes

the S02 emission and acid mist emission standards.  The opacity standard,

while included in the sulfuric acid plant NSPS, is not reviewed separately

since it is directly related to the acid mist emission standard.  The  following

paragraphs summarize the results and conclusions of the analysis.

1.1  3est Oemonstrated Control Technology

     Sulfur dioxide and acid mist are present in the tail  gas from  all  contact

process sulfuric acid production units.  In modern four-stage converter

contact process plants burning sulfur with approximately 8 percent  SO? in the

converter feed and producing 98 percent acid, S02  and acid mist emissions are

generated at the rate of 26 to 56 Ib/ton of 100 percent acid and 0.4 to 4

Ib/ton of 100 percent acid, respectively.  The dual  absorption  process is the

best demonstrated control  technology* for S02 emissions from sulfuric  acid
*It should be noted that standards of performance for new sources
 established under Section 111  of the Clean Air Act  reflect  emission
 limits achievable with the best adequately demonstrated  technological
 system of continuous emission  reduction (taking into consideration
 the cost of achieving such emission reduction, as well  as  any  nonair
 quality health and environmental  impacts  and  energy requirements).

                                     1-1

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plants, while the high efficiency acid mist  eliminator  is  the  :v?3t  demonstrated

control technology for acid mist  emissions.   These  two  emission  control

systems have become the systems  of choice for sulfuric  acid  plants  built  or

modified since the promulgation  of the NSPS.   Forty of  the 46  new or  modified

sulfuric acid production plants  built  since  1971  and subject to  NSPS  incorporate

the dual absorption process, and  all  4-6 plants  use  the  high  efficiency  acid

mist eliminator.

1.2  Current S02 NSPS levels Achievable With  Best Demonstrated Control
     Technology

     All sulfuric acid production units subject to  NSPS have demonstrated

compliance with the current SO?  NSPS  control  level  of 4 Ib/ton.  The  compliance

test results for dual  absorption  plants showed  a considerable  range from  a

low of 0.12 Ib/ton to a high of  3.8 Ib/ton.   The average SOg emission level

obtained in the TISPS compliance  tests  for dual  absorption  plaits is about one

order of magnitude lower than the S02  emission  level  obtained  from  uncontrolled

single absorption plants.  Information received on  the  performance  of several

sulfuric acid plants indicates that low S02  emission results  achieved  in

NSPS compliance tests apparently  do not reflect day-to-day S02 emission

levels.  These levels appear to  rise  toward  the standard as  the  conversion

catalyst ages and its activity drops.   Rased  on these considerations, it  is

recommended that the level  of S02 emissions  as  specified in  the  current NSPS

not be changed at this time.
                                     1-2

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 1.3  Current Acid Mist Levels (and Related Opacity  Levels)  Achievable
      With Best Demonstrated Control  Technology

      All  46 sulfuric acid production units subject  to  NSPS  showed compliance

 with the current acid mist NSPS  control  level of  0.15  Ib/ton of 100 percent

 acid.  The NSPS compliance test  data are all  from plants with acid mist

 emission control  provided by the high efficiency  acid  mist  eliminator.  The

 data show a wide range with a low  of 0.004 Ib/ton to a high of 0.15 Ib/ton.

 Acid mist emission  (and related  opacity)  levels are unaffected by factors

 affecting S02  emissions,  e.g., conversion  catalyst aging.   Rather, acid

 mist emissions are  primarily a function  of moisture levels  in the sulfur

 feedstock and  air fed to  the sulfur  burner, and the efficiency of final

 absorber  operation.   The  spread  observed  in NSPS compliance test values is

 probably  a  result of  variation in  these  factors.  Making the acid mist standard

 more stringent  is not  believed to  be  practicable at this time because of the

 need to provide  a margin  of  safety due to  in-plant operating fluctuations,

 which introduce  variable  quantities of moisture into the sulfuric  acid

 production  line.


 1.4  Cost Considerations Affecting the S02 NSPS

     The  cost effectiveness of control was estimated for four types of S02

control  systems:  dual absorption, ammonia scrubbing,  sodium sulfite  scrubbing,

and molecular sieve adsorption.  The cost effectiveness ranged from $245 to

$625 per ton of S02 removed for the large (1,500 TPD) model  plant  size and

from $282 to $751 per ton for the small  (750 TPD)  model  plant  size.  For both

plant sizes, dual absorption was  estimated to  be the most cost effective

control  option.
                                     1-3

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     The cost analysis for acid mist  control  showed essentially  no  difference
in cost effectiveness ($47-50 per ton of acid mist  removed)  for  the vertical
tube (Brinks type)  and the horizontal  dual  pad (York  type) mist  eliminators
for the two model  plant sizes.
                                    1-4

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2.0  THE SULFURIC ACID MANUFACTURING INDUSTRY



2.1  Industry Characterization



     2.1.1  Georgraphic Distribution



     In 1971 there were 167 contact process sulfuric acid and oleum



plants in the United States.   By 1977 the number of plants had decreased



to 150 and 32 sulfuric acid units were subject to the NSPSJ   In September



of 1984 there were 46 plants subject to the NSPS2 out of a total  of 132



pi ants.^  Table 2-1 provides a summary of the number of units subject  to



NSPS and their design tonnage.



     Figure 2-1 shows the geographical  distribution of contact process



sulfuric acid units subject to the NSPS.  The heaviest concentration  of



new units is in Region IV (Southeast).   The high concentration of sulfuric



acid units constructed in Florida since 1971 can be explained by the



presence of rich phosphate rock deposits.  More than BO percent of the



phosphate rock mined goes into the manufacture of phosphate fertilizers,4,5



which is also the end use of two-thirds of the total  U.S. sulfuric acid



production.6  Since most sulfuric acid is consumed near its point of



manufacture, units with production dedicated for phosphate fertilizer



manufacture will  usually be located near phosphate rock deposits.



     2.1.2  Producti on



     U.S. production of sulfuric acid from July 1983 through  June 1984



totalled approximately 37.7 minion tons, representing an average yearly



increase of 2.2 percent (722,000 tons)  since 1971.7>8  Figure 2-2 shows total



annual  production of sulfuric  acid for  1971 to 1983,  including production



by the lead chamber process, which has  been phased out of the industry.





                                   2-1

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TABLE  2-1.  NSPS SULFURIC ACID PLANTS
Company
Agrico Chemical Co.

Allied Corp.
American Cyanamid
Badger Army
Ammunition PI ant
Beker Ind. Inc.
CF Ind. Inc.
GIL Chem. Inc.
Conserv. Inc.
Farmland Ind.
Freeport Chem. Co.
Gardinier, Inc.
'*!. R. Grace K Co.

Location
S. Pierce, FL
Donal dsonvill e, LA
Anacortes, WA
Westwego, LA
Savannah, GA
Baraboo, WI
Conda, 10
Tan, LA
Bartow, FL
Plant City, FL
Plant City, FL
Sayerville, NJ
Nichols, FL
Bartow, FL
Uncle Sam, LA
Tampa, FL
Bartow, FL

Unit
10
11
10
11
0
1
1
1
1
2
7
G
D
C
h
1
3
4
0
7
9
4
5
6
Capacity
(TPD)
2000
2000
1800
1800
115
1600
800
350
1200
800
2000
1500
1500
1000
1000
2000
1600
1600
1250
1750
2600
1800
1800
1800
              2-2

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TABLE 2-1.  NSPS SULFURIC ACID PLANTS (c —O
Company
Industrial Chemicals
International
Mineral s ^
Chemical s Corp.


Mississippi Chem.
Corp.
Occidental Chem.
Corp.


PVS Chem. Inc.
Ronn S Haas Corp.
Shell Chen. Co.
J.R. Simplot Co.


Texasgul f , Inc.


USS Agri -Chemical s

Location
Penuelas, PR
New Wai es, FL




Pascagoula, MS

White Springs, FL



Copley, OH
Deer Park, TX
Wood River, IL
Helm, CA
Pocatello, ID

Aurora, NC


Ft. Meade, FL

Unit
1
1
2
3
4
5
3

C
0
E
F
1
3
1
4
1
2
3
4
5
1
2
Capacity
(TPO)
60
2750
2750
2750
2500
2500
1500

1800
1800
2000
2000
250
800
360
1800
500
600
1525
1525
3100
2200
2200
             2-3

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                FIGURE 2-1
CONTACT PROCESS SULFURIC ACID PLANTS COMPLETED IN U.S. SINCE 1971
                                                                    PUERTO RICO -1

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Production by the contact  process  represented  99.3  percent  of  ':ota1

production in 1971,  increased  to  99.7  percent  in  1975,  and  100  percent

in 1983.  Table 2-2  shows  the  increase in  sulfuric  acid production  by

region from 1975 through 1983. Production  in  the South represented

70 percent of the U.S.  Total  in 1975  and  77 percent  in  1983.9


                   TABLE 2-2.   SULFURIC ACID PRODUCTION
                      (Thousand tons  of 100% H2S04)
Regi on
Northeast
North Central
West
Soath
1975
1,903.7
3,089.2
4,528.2
21 ,535.7
Change Total Production
1983 (%) 1983 (%)
1,440.1 -24 4
2,040.3 -34 6
4,736.3 +5 13
28,074.9 +30 11
     The growth of the sulfuric acid industry since promulgation  of the

NSPS has been largely dominated by the growth in the phosphate fertilizer

industry in the early and mid-seventies.  Of the 46 contact  process

sulfuric acid units subject to NSPS, the output of at least  36 units is

dedicated to the acidulation of phosphate rock as the first  step  in the

manufacture of wet-process phosphoric acid and superphosphate fertilizers,

     About 81 percent of the contact process sulfuric acid is produced

from elemental sulfur, representing approximately 76 percent of the toal

sulfur consumption in the U.S.  The remaining acid is made from iron


                                    2-6

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pyrites (3 percent);  byproduct  sulfuric  acid  from  smelters  ('J.  percent);



and hydrogen sulfide,  spent  alkylation  acid,  and acid  slud;:- from petroleum



refineries (8 percent) JO



     Sulfuric acid is  produced  in  various  concentrations  and in four



grades:  commercial,  electrolyte  or  high purity, textile  (having low



organic content),  and  chemically  pure  (C.P.)  or  reagent grade.  The



various end uses of sulfuric acid  are  shown in Figure  2-3.  In addition



to the manufacturing  of fertilizer,  other  major  uses are  petroleum refining



(6 percent), inorganic  chemicals  (3  percent), synthetic rubber and plastics



(3 percent), and inorganic chemicals (3  percent) Jl An increasing number of



sulfuric acid consumers,  specifically  fertilizer manufacturers, produce



their own sulfuric acid for  captive  use.






     2.1.3  Industrial  Trends



     U.S. sulfuric acid production in  1971 was 29.0 million tons,12 and



approximately 36.6 million tons in 1983J3   Production is  expected to



increase to 48.0 million  tons by  the year  1995j^



     Tables 2-1, and  2-2, and Figure 2-1 show the  strong  trend towards



siting sulfuric acid  plants  in  the southern States.  Over 77 percent of



the sulfuric acid  design  capacity  is located  in  EPA Regions IV and VI.



In 1971, EPA projected  two new  units to  be coming  on-line each y^ar for



the next several years.  On  the average, three to  four new  units have



actually been completed each year  s.i nee  1971.  Of  the  total of 46 new



units, over half are  located in Florida.   Most of  the  sulfuric acid
                                   2-7

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            100% EQUIVALENT SULFURIC_ACiD CONSUMPTION (xlp3), metric tons
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production units in the South are captive in nature with the output  going



into phosphate fertilizer production at the same plant  comolax.   As



stated earlier, 77 percent of the 1983 total  national  production  of



sulfuric acid was in the South.  Therefore, based on the influence of



high phosphate fertilizer production on the new construction in Region  IV,



and on the production trends of sulfuric acid most units projected to



be coming on-line in the foreseeable future will  probably be located in



the South.



     The location of sulfuric acid plants is not dependent on the location



of sources of sulfur, but rather on the location of various  industries



associated with the use of sulfuric acid; i.e., the fertilizer and petroleum



refining industries.





2.2  Contact Process for Sulfuric Acid Production1^



     All  contact sulfuric acid manufacturing processes  incorporate three



basic operations:   (1) burning of sulfur or sulfur-bearing feedstocks to



form S02, (2) catalytic oxidation of S02 to $03,  and (3) absorption  of



$03 in a strong acid stream.  The several  variations in  the  process  are



due principally to differences in feedstocks.  The least complicated



systems are those that burn  elemental  sulfur.  Where there are appreciable



organics and moisture as in  spent acid and acid sludge,  additional operations



are required to remove moisture and particulates  prior  to catalysis  and



absorption.  The compositiion of feedstock can  affect the sulfur  conversion



ratio, the volume of exhaust gases, and the character and rate of pollutant



releases.



                                   2-9

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     2.2.1  Elemental  Sulfur  Burning  Plants
     Figure 2-4 is  a  schematic  diagram  of  a contact sulfuric plant burning
elemental  sulfur.   Sulfur is  burned to  form a  gas mixture which is
approximately 8 to  10 percent sulfur  dioxide,  1.1 to 13 percent oxygen,
and 79 percent nitrogen.   Combustion  air  is predried by passing through
a packed tower circulating 98 percent sulfuric  acid which acts as a
desiccant.  Drying  of the air minimizes acid mist formation and resultant
corrosion throughout  the  system.
     S02 is oxidized  to 803 in  the presence of  a catalyst containing
approximately 5 percent vanadium  pentoxide.  The temperature of the
reacting gas mixture  increases  as  the composition approaches equilibrium.
Maximum conversion  to $03 requires several conversion  stages with
intermediate gas cooling.  The  gas exiting the  converter  is cooled
in an economizer to temperatures  between  230°  and 260°C,  and $63 is
absorbed in 98 percent sulfuric acid  circulating in  a  packed tower.
The acid content and  temperature  must be carefully  controlled  to prevent
excessive 803 release.
      If fuming sulfuric acid (oleum)  is produced, the  863 containing
gases are first passed through  an oleum tower  which  is  fed with acid
from  the  98 percent absorption  system.   The  gas stream from the oleum
tower is passed through the 98  percent  acid  absorber for  recovery  of
residual sulfur trioxide.
      2.2.2  Spent Acid and Other By-Product  Plants
      Where spent acid, sludge,  and similar feedstocks  are employed,  the
processes  are more elaborate and expensive than sulfur-burning plants
                                   2-10

-------
BLOWER
                                                    STEAM  JO
                                                      4ATMOSPHERE
                                  BOILER FEED WATER	
   STORAGE
                                            PRODUCT
                           FIGURE 2-4
        CONTACT-PROCESS SULFURIC ACID PLANT BURNING
                       ELEMENTAL SULFUR

-------
due to the fact that  the sulfur  dioxide  containing  gas  stream  is



contaminated.   Gases  must he  cleaned  if  high-quality  acid  15 to be



produced.  This requires additional  gas  cleaning  and  cooling equipment



to remove dust, acid  mist,  and  gaseous  impurities,  along with  excessive



amounts of water vapor.   Purification equipment consists of cyclones,



electrostatic  dust and mist precipitators,  plus scrubbers  and  gas-cooling



towers in various combinations.   Figure  2-5 shows one configuration  of a



spent acid plant.  The balance  of the process  following the drying tower



is essentially the same as  an elemental  sulfur-burning  plant.



     A few plants burning only  hydrogen  sulfide or  hydrogen sulfide  plus



elemental sulfur use  a simplified version  of the  above  process.  Wet  gases



from the combustion chamber and  waste heat  boiler are charged  directly to



the converter with no intermediate treatment.  Gases  from  the  converter



flow to the absorber, through which  70  to  93 percent  sulf'jric  acid is



circulating.  In such a "wet  gas" plant  much of the sulfur trioxide



from the converter is in the  form of  acid  mist which  is not absorbed  in



the absorption tower.  High efficiency  mist collectors  are used both  to



recover product and to minimize air  pollution.



2.3  Emissions from Contact Process  Sulfuric Acid Plants15



     2.3.1  Sulfur Dioxide



     Mass S02 emissions vary inversely  as  a function  of the sulfur



conversion efficiency (i.e.,  fraction of S02 oxidized to 803). For  sulfur



burning plants, the inlet S02 concentration to the  catalytic  converters



normally ranges between 7.5 and 8.5 percent, but  can  be as high as  10.5



percent.  Conversion efficiency depends upon the  number of stages  in the



catalytic converter and, to a lesser extent, on the amount of  catalyst.
                                  2-12

-------
ro
i
                      r—SPENT ACID
                      -SULFUR
                      - FUEL OIL
                   WATER
FURNACE     DUST  WASTE HEAT   GAS      GAS    ,-,..,,,,„>,«„,
          COLLECTOR  BOILER   SCRUBBER  COOLER   p^tcMTATORS
                                                                                         S02
                                                                                       STRIPPER


                                                                                     r-*. TO
                                                                                     [ATMOSPHERE
                                                                                   ^  -k
               DRYING
               TOWER
                                            *•  ACID TRANSFER  <
                                                             ABSORPTION
                                                               TOWER
                93% ACID PUMP TANK COOLER
                                   ACID COOLERS    98% ACID PUMP TANK
                                                 FIGURE  2-5
                                CONTACT-PROCESS SULFURIC ACID PLANT
                                           BURNING SPENT ACID

-------
     Most plants built  prior to  1960  had  only  three  catalyst  stages,

and overall  conversion  efficiencies were  approximately  95 t.D  96  percent.

Sulfur burning plants  built  since I960  generally  have four  or five

stages and efficiencies normally range  between 96 and 98 percent.   For

three-stage plants,  S02 release  ranges  between 56 and 70 Ib/ton  and

for four-stage plants,  between 26 and 56  Ib/ton.

     Spent acid plants  followed  the same  design trend.  Most  three-stage

plants were built prior to 1960  and four-stage plants have  usually  been

built after 1960.  Typical  S02 concentrations  in  the converter feed,

conversion efficiencies, and resultant  emissions  for plants burning

sulfur, H2$ or primarily acid sludge  are  given in Table 2-3.
          TABLE 2-3.  SULFUR DIOXIDE FEED AMD EMISSIONS  FOR
                          FOUR-STAGE CONVERTERS
Hydrogen Sul
(•with some •
Feedstock Sulfur sulfur comp(
SOg in converter feed, 7.5 to 8.5 7
% by volume
S02 emissions, Ib/ton 26 to 56 50 to 36
100% acid
SOg emissions, ppm 1500 to 1500 to
bv volume 4000 4000
fide
Dther Acid
Dunds) Sludge
6 to 8
30 to 112
1500 to
4000
                                   2-14

-------
     Exit S02 concentrations from contact plants vary as a function

of the SC>2 content of dry gases fed to the converter.  Where S02


strength is relatively low, there is a significantly greater volume


of gases handled per ton of acid produced.


     A plant with 4.0 percent SC>2 in the dry gases to the converter


will  exhaust over two and one-half times the gas volume of a plant

                                                        o
operating on a 10.0 percent S02 stream, i.e., 147,500 ft /ton vs.


54,500 ft3/ton.


     The relationship between mass emission rate, sulfur conversion and


S02 exit concentrations has been plotted in Figure 2-6 for plants  of


various S02 strengths.  The curve can be used for uncontrolled single


absorption plants and for those plants equipped with tail  gas removal


systems or with the dual  absorption process.  It can be seen that  the


NSPS of 4.0 15 per ton of acid requires 99.7 percent sulfjr conversion


(dual  absorption) or an equivalent SO? exit gas concentration of 280 ppm.


This  conversion is achieved by the dual  absorption technique.  At  98


percent conversion, which is optimum for most single absorption contact


plants, exit S02 concentrations can vary from 1,400 to 4,000 ppm as the


inlet  S02 content varies from 4.0 to 10.0 percent.

     2.3.2  Acid Mist Formation


     The sulfuric acid liquid loading in the tail  gas from the absorber


in a  contact process plant is classified into two broad areas based on


the acid particle size:   (1) spray, which is defined as acid particles


larger than 10 microns,  and (2) mist,  which is defined as  acid particles


smaller than 10 microns.   The EPA method for measuring sulfuric acid mist


(Method 8)  reports $03 gas as well  as  particulate acid mist.
                                     2-15

-------
                              Sulfur Conversion - Percent of Feedstock Sulfur
    10,000
     5000
o.
i
3
     200
     150
     100
                                                                              O  O   o CN
        1.0
                   2.0    3.0   4.0  5.0
                                               10.0    15   20     30
                                                                                       100
                          S02 Emissions - Lb Per Ton of 100% H,S04 Produced
                                       FIGURE  ^ -0
                   SULFURIC ACID PLANT FEEDSTOCK SULFUR CONVERSION
                    VS. VOLUMETRIC AND MASS SO. EMISSIONS AT VARIOUS
                          INLET SO2 CONCENTRATIONS BY VOLUME
                                               2-16

-------
     Spray is primarily formed by mechanical generation of pa-'-.icles that
are formed when a gas and liquid are mixed together.  Examo'es of spray
formation are liquid droplets formed by nozzles and liquid entrainment
leaving a packed tower.  A typical  tower design in a modern acid plant
will have a spray loading of 0.08 to 0.15 grains per actual cubic foot
(gr/ft^) under normal operating conditions.
     Acid mist formation is more complex to define than spray.  There are
two primary mechanisms of acid mist formation.  The first mechanism is
the reaction between two vapors forming a liquid or solid.  This is best
exemplified by the reaction of sulfur trioxide and water vapors to form
submicronic sulfuric acid mist.
        H2°(water vapor)  + S03(gas) 	*  H2s°4(liquid particulate)
     Tne second mechanism of mist formation is vapor condensation in the
bulk gas phase by lowering the gas  stream temperature beyond the liquid
dew point.  The dew point of a sulfuric acid under typical  conditions is
about 300° to 350°F.  However, because of the uncertainties of non-ideal-
conditions and wall  effects, the gas stream temperature is normally
maintained between 375° and 425°F.   This is done to insure that acid mist
is not present to attack metal  equipment.
     The formation of sulfuric acid mist in an acid plant  is due to a
combination of these mechanisms.  When a gas stream containing 863, ^SOq.
and H20 vapor is  cooled below the liquid dew point, the H;jS04 vapor condenses
and the 503 vapor and ^0 vapor combine to form ^$04,  which also condenses.
Submicronic mist  particles  will  be  formed when the gas  is  cooled faster

                                   2-17

-------
than the condensable vapor can be removed  by  mass  transfer  p.?.,  "shock



cooling").  The conditions for "shock  cooling"  are present   i  the  absorbing



towers of an acid plant.



     The practical  key to controlling  mist formation  is  to  keep  the  moisture



content in a gas stream as low as possible.   As  an example  of  mist forming



capability of extraneous  water,  1 ounce  of water vapor carried through



the plant has the potential  to produce 2.35 gr/ft^ of submicronic  acid  mist.



The water content of the  gas stream will be increased if  any of  the



following conditions are  present:



     1.  High organic content of contaminated elemental  sulfur (sulfur



         burning plants only).



     2.  Acid mist carryover from upstream equipment.



     3.  Inadequate drying of the process  air stream.



     d.  Low absorbing tower acid strengths.



\t acid strengths below 98.5 percent,  the  acid  begins to  exert a measurable



water vapor pressure.  The optimum absorbing  tower acid  has  the  minimum



vapor pressure of both water (minimizing mist formation  problems)  and



sulfur tri oxide (minimizing 803  slippage).



     In oleum producing plants,  greater  quantities and a  much  finer  mist



are produced.  From 85 to 95 weight percent of  the particles are less



than 2 microns in diameter as compared with about  30  percent less  than



2 microns for 98 percent  acid production.   Acid  mist  emissions prior to



control equipment range between  0.4 to 4 Ib/ton  for sulfur  burning contact



plants producing no oleum to about 1 to  10 Ib/ton  for spent  acid burning



plants producing oleum, based on an 8 percent SOg  feed to the  converter.





                                   2-18

-------
      Spent  acid  plants  characteristically  form  acid  mist  in the  early



 stages  of the  process.   This  requires  mist  removal prior  to  Joying  and



 oxidation as well  as  from  the tail  gas  after  absorption.



      "Wet gas" plants burning hydrogen  sulfide  deliberately form acid mist



 by  not  drying  the  process  gas.  Much of this  mist is  recovered as product



 acid  with gas  cooling equipment and high efficiency  mist  eliminators or



 electrostatic  precipitators.



      For a  given mass emission rate, acid  mist  concentrations vary  as a



 function of the exhaust  gas volume and the  SO?  concentration of  the gases



 fed to  the  converter.   Figure  2-7 shows a  relationship between mass emission



 rates and concentrations over  a range  of S02  strengths.  The curves can be



 used with any  gas  stream before or after mist eliminators, provided there



 is  no di1uti on.



     2.3.3  V i sib1e Emissions  (0paci ty )



     Acid "list in  exhaust  gases creates visible emissions ranging from



 white to blue  depending  on particle size, concentration and background.



 -(here there is no  control  of mist, opacities generally range from 80 to



 100 percent.




     The effect of acid mist on opacity is very dependent on the size of



 the mist particle.   The smaller particles scatter light more,  producing  a



 denser  plume.   Nevertheless, it has been demonstrated that opacity  of



 the plume from an efficient $03 absorber is a function of acid mist



concentration  and that visible emissions can he eliminated by  minimizing



 acid mist levels  in the acid plant tail gas or through the use of a  good



mist eliminator.   At  the current  NSPS  acid mist  control  level,  there are



essentially  no visible emissions  (less  than 10 percent opacity).



                                   2-19

-------
   0.02   0.03  0.04           0.10        0.20   0.30    0.50

    ACID MIST EMISSIONS, Ib H2S04/T OF 100 PERCENT H2 S04 PRODUCED
1.00
                    FIGURE 2-7
  SULFURIC ACID PLANT CONCENTRATIONS OF MIST
      FOR MASS STACK EMISSIONS PER UNIT OF
PRODUCTION AT INLET SO2 VOLUME CONCENTRATIONS
                       2-20

-------
     2.3.4  Oxides of Nitrogen
     Nitrogen oxides present in the converter gas also cause acid mist
emissions, since they reduce the efficiency of the absorption tower.
Nitrogen oxides may result from the fixation of atmospheric nitrogen in
high temperature sulfur furnaces, or may be formed from nitrogen compounds
in the feedstocks.  Nitrogen oxides can be held to a reasonable minimum
by using the same techniques which have been applied to steam generators.
For instance,  in the decomposition of spent acid containing nitrogen
compounds, operation at  furnace temperatures less than about 2000°F  and a
low oxygen content will  generally keep nitrogen  oxides concentrations
be!ow 100 ppm.
                                  2-21

-------
2.4  REFERENCES
     1.  Orabkin,  M.  and  K. J. Brooks (Mitre Corporation).  A Review of
Standards of Performance  for New Stationary Sources - Sulfjric Acid
Plants.  Prepared  for U.S. Environmental Protection Agency, Research
Triangle Park,  N.C.   Publication No. EPA-450/3-79-003.  January 1979.
p. 4-1 .

     2.  Information  generated from the following sources:

         a.  Stationary Source Compliance Division, U.S. Environmental
Protection Agency. Compliance Data System Source Data Report.  Printouts
dated February  3,  1984, and January 25, 1985.  92 p.

         b.  Tennessee Valley Authority.  World Fertilizer Capacity -
Sulfuric Acid.   Printout  dated  August 16, 1984.  12 p.

         c.  SRI international.  1984 Directory of Chemical Producers.
Menlo Park, California.   1984.

         d.  Letter and attachments from Thomas, W.C., State of Florida
Department of Environmental Regulation, to Beck, L.L., EPA.  May 21, 1984.

         a.  Massoglia, M.F., D.D. McFadden and L.L. Piper (Research
Triangle Institute).   The NSPS Triennial Review:  Final Report.
Prepared for U.S.  Environmental Protection Agency, Washington, D.C.  RTI
Publication No. RTI/2747/01-13F, December 20, 1984.

         f.  Telephone Conversations initiated by Lee Beck, U.S.
Environmental Protection  Agency, to the following individuals:
Conversation Date
February
February
March 1 ,
March 29
November
November
November
December
December
December 5
December 5
January 23
January 23
January
January
January
         19
         19
         5,
         5,
February 4,
February 4,
13, 1984
16, 1984
1984
 1984
19, 1984
    1984
    1984
   1984
   1984
   1984
   1984
   1985
   1984
   1985
   1985
   1985
   1985
   1985
        25
        28
        28
Person Contacted

Bruce Varner
Rick Watman
Mike Pucci
Mark Hooper
Ken Roberts
John Cole
Beverly Foster
Steve Riva
Ed Chromanski
Ann Zownier
John Hoi 1ingsworth
Jerry Vetter
Pat McCoy
Sammy Amerson
Johnnie Cole
Fred Roe
Sammy Amerson
John Ledger
             Affil iation

             EPA,  Region  V
             EPA,  Region  III
             EPA,  Region  II
             EPA,  Region  X
Florida Dept. of Environmental Regulation
Florida Dept. of Environmental Regulation
             EPA,  Region  IV
             EPA,  Region  II
   NJ Bureau of Air Pollution  Control
   NJ Bureau of Air Pollution  Control
             CIL Chemicals,  Inc.
             Beker Industries, Inc.
             EPA,  REgion  V
 NC Division of Environmental  Management
Florida Dept. of Environmental Regulation
  GA Environmental  Protection  Division
  NC Division of Environmental Management
daho Division of Environmental Management
                                    2-22

-------
 February  5,  1985        Ed Chromanski      NJ Bureau of Air Pollution Control
 February  5,  1985        Byron Sullivan     NJ Bureau of Air Pollution Control
 February  8,  1985        Ed Chromanski      NJ Bureau of Air Dilution Control
 February  14, 1985       Craig Rushin                 EPA,  ^gion  VI
 February  22, 1985       Chris Roeder   Florida Dept. of Environmental  Regulation
 March  14,  1985          Lynn Malcolm        Ohio Environmental  Protection  Agency
 March  27,  1985          Charles Meskal  Fresno County Air  Pollution  Control  District

     3.   Bureau of the Census.  Current Industrial  Reports - Sulfuric
 Acid.  U.S.  Department of Commerce, Washington,  D.C. Publication  No.
 MA28B(83)-1.  July 1984.  6 p.

     4.   Office of Air Quality Planning and Standards.   Phosphate Rock
 Plants -  Background Information for Proposed Standards.  U.S. Environmental
 Protection Agency, Research Triangle Park, N.C.   Publication No.
 EPA-450/3-79-017.   September 1 979.  p. 3-1.

     5.   Bureau of Mines.   Minerals Yearbook,  1983,  Volume 1.   Metals  and
 Minerals.  U.S. Department of the Interior, Washington,  D.C. 1984, p.  671.

     6.   Ibid,  p. 838.

     7.  Bureau of Census.  Current Industrial Report -  Sulfur  Acid.
 U.S. Department of Commerce,  Washington,  D.C.  Publication  No.  M28A(77)-14
 Supplenent 1.  June 1978.
     8.  Reference 3.

     9.  References 1, 3, and 7.

     10.  Reference 5, p. 840.

     1 1 .  Reference 5, p. 838.

     12.  Reference 7.

     13.  Reference 3.

     14.  Predicasts, Inc.   PTS Time Series Dialog Information Retrieval
Service.  File No.  799008.   Predicasts,  Inc., Cleveland OH.  Printout
accessed February  1985.  2 p.

     15.   Reference 1,  pp.  4-11 through  4-15.

     16.   Reference 1,  pp.  4-15 through  4-23.
                                  2-23

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 3.0  CURRENT STANDARDS FOR SULFURIC ACID PLANTS



 3.1  Background Information



     Prior to the promulgation of the NSPS in 1971, almost all  existing



 contact process sulfuric acid plants were of the single-absorption design



 and had no SOg emission controls.  Emissions from these plants  ranged



 from 1500 to 6000 ppm S02 by volume, or from 21.5 lb of S02/ton of



 100 percent acid produced to 85 lb of S02/ton of 100 percent acid produced.



 Several State and local agencies limited S02 emissions to 500 ppm from new



 sulfuric acid plants, but few such facilities had been put into operation.^



     Many sulfuric acid plants utilized some type of acid mist  control



 prior to 1971, but several  had no controls whatsoever.  Uncontrolled acid



 mist emissions varied between 2 and 50 mg/scf,  which is equivalent to about



 0.4 to 9 lb of H2S04/ton of 100 percent acid produced, the lower figure



 representing emissions from a plant burning high-purity sulfur.  State  and



 local  regulatory agencies had only begun to limit acid mist emissions to



 more stringent levels.  For example, some agencies had adopted  limits of  1 and  2



 mg/scf, respectively, for new and existing plants.



     It is  estimated that S02 emissions from sulfuric  acid plants  totalled



 530,000 tons in 1971 and 180,000 tons  in 1983.2  This  represents  a 66 percent



 drop in S02 emissions from this industry during a time period when production



 increased by 26 percent.   It  is not known what  portion of this  drop  in  SOg



 emissions is due to NSPS-controlled plants  or to existing plants  covered  by



 State  Implementation Plans  (SIP).




     No corresponding data  are available for the effect  of the  NSPS  on  acid



mist emissions  from the industry.






                                    3-1

-------
3.2  Facilities Affected

     The NSPS regulates  sulfuric  acid  plants  that were  planned  or  under

construction or modification  as of  August  17,  1971.   Each  sulfuric  acid

production unit (or "train")  is the affected  facility.  The  standards  of

performance apply to contact-process sulfuric  acid and  oleum facilities

that burn elemental  sulfur,  alkylation acid,  hydrogen sulfide,  metallic

sulfides, organic sulfides,  mercaptans,  or acid  sludge.  The NSPS  does not

apply to metallurgical  plants that  use acid plants as control systems, or

to chamber process plants or  acid concentrators.

     An existing sulfuric acid plant is  subject  to the  promulgated  NSPS

if:  (1) a physical  or operational  change  in  an  existing facility  causes

an increase in the emission  rate  to the  atmosphere of any  pollutant to

which the standard applies,  or (2)  if  in the  course  of  reconstruction  of

the facility, the fixed capital cost of  the new  components exceeds  50  percent

of the fixed capital cost that would be  required to  construct a comparable

entire new facility that meets the  NSPS.

3.3  Controlled Pollutants and Emission  Levels

     The pollutants to be controlled  at  sulfuric acid plants by the NSPS

are defined by 40 CFR 60, Subpart H as follows:

     1.  Standard for sulfur dioxide

          (a)  "On and after the  date. . . no owner  or  operator subject
          to the provisions  of this subpart shall  cause to be discharged
          into the atmosphere from  any affected  facility  any gases which
          contain sulfur dioxide  in excess of 2  kg per  metric ton  of
          acid produced (A- lb per ton),  the production  being expressed
          as 100 percent ^SO^.


                                    3-2

-------
     2.  Standard for acid mist

          (a)  "On and after the date. . . no owner or operator subject
          to the provisions of this subpart shall  cause to b
-------
     Emission tests from both the original  dual-absorption  sij1furic  acid



plant and the single absorption  plant  with  sodium sulfite-sodium  bisulfite



scrubbing indicated that both operations  were  capable  of  maintaining S02



and acid mist emissions below 4  Ib/ton and  0.15 Ib/ton,  respectively,  at



full  load operations.  Additionally,  control  of acid mist below 0.15 Ib/ton



at these plants resulted in stack emissions below 10 percent  opacity.



Continuous stack monitoring at these  plants indicated  that  at full  load,



the plants could be consistently operated so that S02  emissions woul_d  be



kept  within the limits of the performance standard.   In  Section 5.0  of this



report, NSPS emission test results for S02  and acid  mist  are  presented for



all sulfuric acid units completed since the promulgation  of the standard.



3.4  Testing and Monitoring Requirements



     3.4.1  Testing Requirements^



     Performance tests to verify compliance with S02,  acid  mist,  and opacity



standards for S'jlf'jric acid plants must he  conducted within 60 days  after



the plant has reached its full capacity production rate,  but  not  later than



180 days after the initial start-up of the  facility.   The EPA reference



methods to be used in connection with sulfuric acid  plant testing include:



     1.   Method 8 for the concentrations of 502 and  acid mist



     2.   Method 1 for sample and velocity  traverses



     3.   Method 2 for velocity and volumetric flow  rates



     4.   Method 3 for gas analysis.
                                    3-4

-------
     For Method 3, each performance test consists of three septate runs of



at least 60 minutes duration each with a minimum sample volure of 40 dry



standard cubic feet (dscf).  The arithmetic mean of the three runs taken is



the test result to which compliance with the standard applies.



     The sulfuric acid production rate, expressed as tons/hr of 100 percent



H2S04, is to he determined during each testing period by suitable methods



and confirmed by a material balance over the production system.  Sulfur



dioxide and acid mist emissions in Ib/ton of 100 percent ^$04 are determined



by dividing the emission rate in tons/hr by the hourly 100 percent acid



production rate.



     3.4.2  Monitoring Reginrernents



     SOg emissions in the tail  gas from sulfuric acid plants are  required



to be continuously monitored.  Continuous SOg monitoring instrumentation



should he able to:   (1) provide a record of performance, and (2)  provide



intelligence to plant operating personnel  such that suitable corrections



can be made when the system is  shown  to be out of adjustment.   Plant  operators



are required to maintain the monitoring equipment in calibration  and  to



furnish records of $03 excess emission values to the Administrator of EPA



or to the responsible State agency.



     Measurement principles used in the gas analysis instruments  are:



     1.   Infrared absorption



     2.   Colorimetric titration of iodine



     3.   Selective  permeation  of S02  through a  membrane



     4.   Flame photometric measurement





                                   3-5

-------
     5.   Chromatrographic measurement



     6.   Ultraviolet absorption.



The ultraviolet absorption system  and  the iodine  titration  method  have



received widespread application  for SOj  measurement  in  sulfuric  acid  plants



subject to NSPS.



     The continuous monitoring system  is calibrated  using  a gas  mixture



of known S02 concentration as  a  calibration  standard.   Performance evaluation



of the monitoring system is conducted  using  the SOg  portion of EPA Method  8.



     Excess S02 emissions are  required to be reported to EPA (or appropriate



State regulatory agencies) for all  3-hour periods  of such  emissions  (or  the



arithmetic average of three consecutive  1-hour periods).   Periods  of  excess



emission are considered to occur when  the integrated (or arithmetic  average)



plant stack SC>2 emission exceeds the standard of  4 I'D/ton  of 100 percent



produced.
                                    3-6

-------
3.5  REFERENCES

     1.  Orabkin,  M.  and K.J.  Brooks  (Mitre  Corporation).  A Review of
Standards of Performance for  New  Stationary  Sources - Sulfjnc Acid Plants.
Prepared for U.S.  Environmental Protection Agency, Research Triangle Park,
N.C.  Publication  No.  EPA-450/3-79-003.  January 1979.  p. 3-1.

     2.  Office of Air Quality Planning  and  Standards.  National Air Pollutant
Emission Estimates, 1940-1983. U.S.  Environmental Protection Agency,
Research Triangle  Park, N.C.   Publication No. EPA-450/4-84-028.
December 1984.   p. 28.

     3.  U.S. Environmental Protection Agency.  Code of Federal Regulations.
Title 40, Subpart  H,  SC Part  60.  Washington, D.C.  Office of the Federal
Register.  December 23, 1971.

     4.  Office of Air Programs.  Background Information for Proposed Standards,
U.S. Environmental  Protection  Agency, Research Triangle Park, N.C.
Publication No. APTD-0711.  August  1971.  p. 43-48.

     5.  Reference 3.
                                   3-7

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4.0  STATUS OF CONTROL TECHNOLOGY

4.1  Control Technology Applicable to the NSPS Control of SO? Emissions
     from Contact Process Sulfuric Acid Plants

     There are a few physical mechanisms and many chemical means of removing

S02 from gas streams.  Almost any soluble alkaline material  will absorb a

significant fraction of S0£ even in a crude scrubber.  For years, sulfur

dioxide has been removed from many process gases where the S0£ adversely

affected the product.  The problems of removing S02 from acid plant gases

are principally that of finding the least expensive mechanism consistent

with minimal formation of undesirable by-products.  The control  processes

in use by the sulfuric acid industry in units installed since the

promulgation of the NSPS are reviewed below.

4.1.1  Dual  Absprption Process

     The dual  absorption process (used partially as the basis of the rationale

for the SOg NSPS) has become the SOg control  system chosen by the sulfjnc

acid industry since promulgation of the NSPS.  This can be seen  by examination

of Table 4-1,  which presents a tabulation of the new sulfuric acid units built

since the promulgation of the NSPS together with their locations, design

capacities,  basic process design,  and S02 and acid mist control  technologies.

As shown on  Table 4-1, 40 of the 46 new units built since the promulgation

of the NSPS  have employed the dual  absorption process for S02 control.

This process offers the following  advantages  over other S02  control  processes:

     0    As opposed to single absorption with  scrubbing,  a  greater fraction
          of the sulfur in  the feed is converted to sulfuric acid.

     0    There are no by-products
                                    4-1

-------
TABLE 4-1.  CONTACT SULFUKIC ACID  PLANIS BUILT SINCE PROPOSAL OF THE NSPSl
Company
Agrico Chemical Co.



All ied Corp.
American Cyanamid

Badger Army
Ammunition Plant
Beker Ind. Inc.


CF Ind. Inc.


CIL Chem. Inc.

Conserv. Inc.
Farmland Ind.

Freeport Chem. Co.
Gardinier, Inc.

W.R. Grace & Co.


Industrial Chemicals

Location
S. Pierce, FL

Donal dsonvi lie, LA

Anacortes, WA
Westwego, LA
Savannah, GA
Baraboo, WI

Conda, ID
Taft, LA

Bartow, FL
Plant City, FL
Plant City, FL
Sayerville, NJ

Nichols, FL
Bartow, FL

Uncle Sam, LA
Tampa, FL

Bartow, FL


Penuelas, PR

Unit
10
11
10
11
D

1
1

1
2

7
C
11
C
F
1
3
4
0
7
9
4
5
6
1

Year
Compl eted
1975
1975
1974
1975
1975
1978
1975
1981

1973
1974

1975
1975
1975
1975
1975
1982
1982
198?
1974
1980
1976
1976
1976
1977
1976

Capacity
(TPD)
2000
2000
1800
1800
115
1600
800
350

1200
800

2000
1500
1500
1000
1000
2000
1600
1600
1250
1750
2600
1800
1800
1800
60

Process Emission Control System
Design SO? Acid Mist
DA
DA
DA
DA
DA
DA
DA
SA

DA
SA

DA
DA
DA
DA
DA
DA
DA
DA
DA
DA
DA
DA
DA
DA
SA

Process
Process
Process
Process
Process
Process
Process
Sodium
Sulfite
Process
Ammoni a
Scrubber
Process
Process
Process
Process
Process
Process
Process
Process
Process
Process
Process
Process
Process
Process
Ammonia
Scrubber
York Demister
York Demister
York Type "S"
York Type "S"
Fiber Mi st El im.
Mist El iminator
Bri nk Demi ster
Mist Eliminator

Brink Mist El im.
Brink Demister

Brink HV Demister
Brink Demister
Brink Demister
Mist El iminator
Mi st El iminator
Monsanto CS-II
Oerni sters
Demi sters
Fiber Hist El im.
Fiber Mi st E 1 im.
Fiber Mist El im.
Brink Demister
Brink Demister
Brink Demister
Glass Fiber Mist
El iminator

-------
                        TABLE  4-1.   CONTACT SULFURIC ACID PLANTS BUILT SINCE PROPOSAL OF THE NSPS  (cont)
I
CO
Company
International
Mineral s &
Chemical s Corp.


Mississippi Chem.
Corp.

Occidental Chem.
Py* nt-4
Corp .


PVS Chem. Inc.
Rohin & Haas Corp.

Shell Chem. Co.
J.R. Simplot Co.


Texasgulf, Inc.


USS Agri -Chemicals

Location
New Wales, FL


Pascagoula, MS

White Springs, FL



Copley, OH
Deer Park, TX

Wood River, IL
Helm, CA
Pocatello, ID


Aurora, NC


Ft. Meade, FL

Unit
1
2
3
4
5
3

C
D
E
F
1
3

1
4
1

2
3
4
5
1
2
Year .
Compl eted
1975
1975
1975
1981
1981
1975

1975
1975
1980
1980
1976
1976

1978
1976
1976

1976
1976
1974
1981
1982
1982
Capacity
(TPD)
2750
275U
2750
2500
2500
1500

1800
1800
2000
2000
250
800

360
1800
500

600
1525
1525
3100
2200
2200
Process
Design
DA
DA
DA
DA
DA
DA

DA
DA
DA
DA
DA
SA

DA
DA
SA

SA
DA
DA
DA
DA
DA
Emi ssi on
SO?
	 *-
Process
Process
Process
Process
Process
Process

Process
Process
Process
Process
Process
Ammoni a
Scrubber
Process
Process
Ammoni a
Scrubber
Ammonia
Scrubber
Process
Process
Process
Process
Process
Control System
Acid Mist
Brink Demister
Brink Demister
Brink Demister
Brink Demister
Brink Demister
Bayer/Lurgi Mist
El iminator
Brinks Demi ster
Brinks Demister
Brinks Demister
Bri nks Derni ster
Monsanto Demi ster
Fiber Mist El im.

Fi ber Mi st El im.
Brinks Demister
Bri nks Demi ster

Brinks Demister
Bri nk ; npmi ster
Brinks Ue.-ni ster
Bri nks Demi sLi-r
Demi sters
Demi sters
   SA = Single Absorption
   DA = Dual  Absorption

-------
     0    Contact acid plant  operators  are  familiar with  the  op^ations
          involved.

     Figure 4-1  is a process  flowsheet  of the  dual absorption  process.

The S03 formed in the first three  converter stages is  removed  in  a  primary

absorption tower and the remainder of  the gas  is  returned to  the  final

conversion stage(s).  Removal  of  a product  of  a  reversible reaction

                      S02 +  1/2 02 ->  S03

drives the oxidation further  toward completion approaching the reaction

equilibrium expressed by:
                                $03
                       K =           1/2
                            (S02)  (02)

where K is the reaction equilibrium constant  peculiar to the  temperature  of

the reaction and the parenthetical  entities  are the molar quantities  of the

gases involved.  The resulting 863  is absorbed in a secondary absorption

tower which yields at least 99.7 percent overall  conversion  of the  sulfur to

sulfuric acid.2

     The dual absorption process permits higher inlet S02 concentrations

than normally used in single absorption plants since the second conversion

step effectively handles the residual S02 from the first conversion step.

Higher inlet S02 concentrations permit  a reduction in equipment size which

partially offsets the cost of the additional  equipment required for a dual

absorption plant.  The dual absorption  equipment occupies little more space

than a conventional plant, even though  an additional absorber is required.

     Spent acid or H2S may be used as feedstock in dual  absorption  processes

with appropriate conventional process gas pretreatment,  i.e., particulate
                                    4-4

-------
I
CJ1
                 9WAC'D   SS&fJB&ER  C°NVERTER    ECONOMI2ER *gBJgf M*ACI°
                                           FIGURE  4-1
                             DUAL ABSORPTION SULFURIC ACID PLANT
                                         FLOW DIAGRAM

-------
removal.  The dual  absorption  process  requires  the  same  types  v:  equipment



as the conventional  single absorber  design.   Although  additional  equipment  is



required, the on-stream production  factor and manpower requirement  are  the  same.^



4.1.2  Sodium Sulfite - Bisulfite Scrubbing



     Tail gas scrubbing systems  are  generally applicable to  all classes of



contact acid plants.  They can provide control  of SC>2  and to some extent



303 and acid mist.



     In the Well man-Power Gas  process, the tail  gases  are first passed



through a mist eliminator to reduce  acid mist.   Following mist  removal, the



SC>2 is absorbed in  a three-stage absorber with  a sodium sulfite solution.



A sodium bisulfite  solution results  and is fed  to a heated crystallizer where



sodium sulfite crystals are formed  and S02 gas  and  water vapor  are  released.



The crystals are separated from the  mother liquor and  dissolved in  the  recovered



condensat^ for recycle to the  absorber.  The recovered wet S02  is sent  back to



the aci d pi ant.^



     In all processes employing sulfite-bisulfite absorption even without



regeneration, some  portion of  the sulfite is oxidized  to sulfate, from  which



the sulfur dioxide  cannot be regenerated in the heating sequence.  This sulfate



must be purged from the system.   In  the Wei 1 man-Power  Gas process,  some thio-



sulfate is also formed.  Apparently, the extent of oxidation is dependent  on



several factors such as the oxygen content of the gas  stream,  the temperature



and residence time of the liquor in  the recovery sections, and  the presence



of contaminants that may act as oxidation catalysts.5



     Since promulgation of the NSPS, two plants have used the sodium



s.il f ite-bisulfite control system.  One of the plants was designed for dual



                                    4-6

-------
absorption but later converted the second absorber to a sodiun s Pfite-



bi sufits system.  The sodium sulfite-bisulfite system presented operational



difficulties, however, and was subsequently converted to an ammonia scrubber,



which is the control system the plant currently uses.^  The other  plant  was



designed to use sodium sulfite-bisulfite scrubbing from the outset.  The



plant is part of an Army ammunition production facility, however,  and has



not been used.  Construction of the plant was completed in 1981  and the



plant was operated only long enough to verify its operability.  Emissions



from the plant have not been measured.7



4.1-3   Ammonia Scrubblng



     The ammonia scrubbing process uses  anhydrous ammonia (NH3) and water



make-up in a two-stage scrubbing system  to remove S02 from the acid plant



tail gas.  Excess ammonium sulfite-bisulfite solution is reacted with



sulfuric acid in a stripper to evolve S02 gas and produce an ammonium



sulfate by-product solition.  The S02 is returned to the acid plant and



the solution is treated for the production of fertilizer grade ammonium



sulfate.  The process is dependent on a  suitable market for ammonium sulfate.^



     Five NSPS sulfuric acid plants use  an ammonia scrubbing system



for tail gas SOg emissions control.



4.1.4  Molecu!ar Sieves



     This process utilizes a proprietary molecular sieve system in which



SOg is adsorbed on synthetic zeolites.  The adsorbed material  is desorbed



by purified hot tail gas from the operating system and sent back to the



acid pi ant.






                                    4-7

-------
     Since the promulgation of the sulfuric  acid  plant  NSPS,  one  new  unit

was built with a molecular sieve system for  SOg control.   How,-;,^,  extensive

operational  difficulties with  this system caused  this  plant  to  be  retrofitted

with a dual  absorption system for S02  control.  The  dual  absorption system

was retrofited in January 1979 and has  operated satisfactorily  since  that

t i me. 9

4.2  Control  Technology Applicable to  the NSPS^for Acid Mist  Emissions
     from Contact Process Sulfuric Acid Plants^

     Effective control  of stack gas acid mist  emissions can  be  achieved  by

fiber mist eliminators and electrostatic precipitators  (ESP's).   Although

ESP's are frequently used in the purification  section  of spent  acid plants,

there is no evidence that any have been installed to treat the  stack  gas of

any new sulfuric acid plants.   Even though ESP's  have  the advantage of

operating with a lower pressure drop than fiber mist eliminators  (normally

less than 1 inch'of water), lack of application of this equipment  to  new

sulfuric acid units is probably due primarily  to  its relatively  large size

and resultant high installation cost compared  to  fiber mist  eliminators.

Maintenance costs (to keep the ESP's operating within  proper tolerances  for

the acid environment which is corrosive to the mild  steel  equipment)  are

also high.

     Mist eliminators are generally located  downstream of the S02  absorbers

to collect mist generated during the production process.  An exception  to

this is when a sodium sulfite-bisulfite scrubber  is  used to control SO?  emissions.

With the sodium sulfite system, it is  best to  locate the mist eliminator

upstream of the scrubber to minimize the formation  of sulfates  which  must

be purged from the system.  The scrubber exit  gas does not normally require

mi st removal.
                                 4-8

-------
      Fiber mist eliminators utilize the mechanisms  of  impaction  and
 interception to capture large to intermediate  size  mist particles and of
 Brownian movement  to effectively collect  micron  to  submicron  size particles.
 Fibers used may be chemically resistant glass  or fluorocarbon.   Fiber mist
 eliminators are available  in  three  different configurations covering a
 range of efficiencies required for  for  various plants  having  low to high
 acid mist loadings and  coarse to fine mist particle sizes,
 respectively.   The three fiber mist  eliminator configurations are:
           1.   Verticle  tube
           2.   Verticle  panels
           3.   Horizontal dual  pads.
 4.2.1   Vertical  Tube  Mist  Eliminators
      Tubular mist  eliminators  consist of a number of vertically oriented
 tubular  fiber  elements  installed in parallel  in the top of the absorber
 on new  acid plants and  usually  installed in a separate tank above or  beside
 the  absorber on  existing plants.  Each element  consists of glass fibers
 packed between two concentric  screens made of 316 stainless steel.   In an
 absorber  installation (see Figure 4-2) the bottom end  cover of the element
 is equipped with a liquid seal pot to prevent gas bypassing.   A pool  of
 acid provides the seal in the separate tank design.  Mist  particles collected
 on the surface of the fibers become  a part of the liquid film  which wets
the fibers.  The liquid film is moved horizontally through  the fiber  beds
by the gas drag and is moved downward by gravity.   The  liquid  overflows the
seal  pot continuously, returning to  the  process.
                                    4-9

-------
                ACCESS
                MANHOLE
MISTY
GAS IN
                                           CLEAN GAS OUT
                                                TU8E PLATE
                                                 CYLINDRICAL
                                                ^SCREENS
                                                 FIBER ELEMENTS
                                                RECOVERED
                                                LIQUID (MIST)


                                                SEAL PIPES
                                                LIQUID SEAL
                                                LIQUID &
                                               SOLIDS OUT
                         FIGURE  4-2
      VERTICAL TUBE MIST ELIMINATOR INSTALLATION
                              4-1Q

-------
     Tubular mist eliminators use inertial impaction to collect larger



particles (normally greater than 3 microns) and use direct interception and



Browm'an movement to collect smaller particles.  The low superficial  velocity



of gas passing through the fiber bed (20 to 40 feet per second) provides



sufficient residence time for nearly all of the small  particles with  random



Brownian movement to contact the wet fibers,  effecting removal  from the gas



stream.  The probability that such a particle could pass through the  bed



following the resultant greatly lengthened travel  path is very  low.



     Design volumetric flow rate through an element is about 1000 standard



cubic feet per minute (scfm), and the number  of elements required for a given



plant size can be determined from the gas volume handled at capacity.



Depending on the size of the sulfuric acid plant,  anywhere from 10 to 100



elements may be used; each element is normally 2 feet  in diameter and 10



feet high.



     Pressure drop across the element varies  from 5 to 15 inches of water



with a higher pressure drop required for a higher  removal  efficiency  on



particles smaller than 3 microns.  The manufacturer of these elements



guarantees a mist removal  efficiency of 100 percent on particles larger than



3 microns and 90 to 99.8 percent on particles smaller  than 3 microns  with



99.3 percent being most common.   These efficiencies can  be achieved on  the



stack gas of sulfuric acid plants burning elemental  sulfur or bound-sulfur



feedstocks (spent acid, wet gas, etc.)  and producing acid  or oleum.



     Because the vertical  tube mist eliminator does not  depend  only upon



impaction for mist removal, it can be operated at  a volumetric  flow rate



considerably below design  with no loss  in efficiency.
                                    4-11

-------
     As can be seen on Table 4-1,  the  vertical  tube  mist  eliminator



(Brinks type) is used in  the great  majority  of  new sulfuric  acid units  for



acid mist control.



4.2.2  Vertical  Panel Mist  Eliminators



     Panel  mist  eliminators use fiber  panel  elements  mounted  in a  polygon



framework closed at the bottom by  a slightly conical  drain pan equipped



with an acid seal  pot to prevent gas bypassing.  The  polygon  top is



surmounted by a  circular ring which is  usually  installed  in  the absorption



tower and welded to the inside of  the  absorption  tower  head.  Each panel



element consists of glass fibers packed between two  flat  parallel  315



stainless steel  screens.  In large high velocity  towers,  recent designs



have incorporated double polygons,  one inside the other,  to  obtain more



bed area in a given tower cross section.  Pressure  drop across the panel  is



usually about 3 inches of water.



     As in the high efficiency tubular mist  eliminator  above, the  gas  flows



horizontally through the bed, but  at a much  higher  superficial velocity



(400 to 500 ft/min) using the impaction mechanism for collection of the mist



particles.  Gas leaving the bed flows  upward to the  exit  port, while the



collected liquid drains downward across the  pan and  out through the seal



pot back into the tower or to a separate drain system (see  Figure  4-3).



     The polygon may contain 10 to 48 vertical  sides, each  side normally



consisting of an 18  1/2" x 53" panel.   A smaller  18 1/2"  x  26" panel is



available for small  plants, e.g.,  35 tons per day.
                                    4-12

-------
                     CLEAN GASES OUT
 ACCESS MANHOLE
MIST LADEN
  GASES
L	     DISTRIBUTOR F

f™ """ mm "™"
                   SEAL POT

   DISTRIBUTOR PAN OF TOWER
                                       FIELD WELD
                                           STRUCTURAL
                                           SUPPORT
                                           CYLINDER
                                           ELEMENTS
                                           IN POLYGON
                                           FRAME
                                           RECOVERED
                                           LIQUID
                      FIGURE 4-3
  VERTICAL PANEL MIST ELIMINATOR INSTALLATION
                          4-13

-------
     Because of the large percentage  of  submicron  mist  present  'n  the  stack



gas of a spent acid plant and  of  a  plant  producing oleum str-^r  than



20 percent, the vertical  panel  mist eliminator  will  usually  give unsatisfactory



performance for these plants when used  for  acid mist  control  in  the  tail  gas.



These units are generally used in dual  absorption  plants for removal of



acid mist from the intermediate absorber  to protect  downstream  equipment



from corrosion.



     Vertical  panel mist  eliminators  normally  operate with  a liquid  level



in the acid seal  pot below the conical  drain pan.   Although  the  velocity



through the panels could  be increased at  lower  throughputs  by raising  the



liquid level to cover the lower part  of  each panel,  this would  cause reentrain-



m^nt of s;>ray  by the gas  passing  over the liquid level  in the basket.



4.2.3  Horizontal  Dual  Pad Mist Eliminators



     Two circular fluorocarbon fiber  beds held  by  stainless  steel  screens




are oriented horizontally in  a vertical  cylindrical  vessel  one  above the



other, so tnat the coarse fraction  of the acid  mist  is  removed  by  the  first



pad (bottom contactor)  and the fine fraction by the other (top  contactor),



as shown in Figure 4-4.  The  bottom contactor consists  of two plane  segmented



sections installed at an  angle to the horizontal  to facilitate  drainage  and



give additional area for  gas  contact.  The assembly may be located either



adjacent to or on top of  the  absorption  tower.



     This unit uses the high  velocity impacting mist collection mechanism,



as does the panel  mist  eliminator;  however, the collected acid  drains  down-



ward through the pads countercurrent  to the gas flow producing  a scrubbing





                                    4-14

-------
action as well.  Collected acid may be drained from external  connections  or



returned directly to the absorber through  liquid  seal  traps.



     Total  pressure drop across both pads  is  usually about  9  inches  of



water.  The superficial  velocity through the  unit  is 9 to  10  feet  per second.



Hence, the diameter of the cylindrical  shell  and  the pads  is  determined



from the volume of gas handled.  Height  requirements for the  unit  depend



upon whether it is located adjacent to or  positioned on the absorber, but



are roughly 1.5 to 2 times the diameter  of the unit.
                                     4-15

-------
           <-.
      \ 'CLEAN GAS
     ,  VJ TO ATMOSPHERE
 DRAIN !
           TOP CONTACTOR
       r BOTTOM CONTACT!
CONTACTOR^ L DRA|N

                i
             MIST-LADEN     <• ABSORBER
              GAS IN
              (COURTESY OF YORK SEPARATORS, INC.)
               FIGURE 4-4
HORIZONTAL DUAL PAD MIST ELIMINATOR
                 4-16

-------
 4.3  REFERENCES
      1.   Information generated from the following sources:

           a.  Stationary Source Compliance Division, U.S.  Environmental
 Protection Agency   Compliance Data System Source Data Report.   Printouts
 dated February 3, 1984, and January 25, 1985.  92 p.

          b.  Tennessee Valley Authority.  World Fertilizer  Capacity  -
 Sulfunc Acid.  Printout dated  August 16, 1984.   12  p.

 Monin P  I' rS1RL1nt?rnat1i°^1*   1984 01rectory of Chemical  Producers.
 Menlo Park, California.  1984.

          d.  Letter and attachments from Thomas,  W.C., State of Florida
 Department of Environmental  Regulation,  to Beck,  L.L., EPA.  May 21, 1984.

          e.  Massoglia, M.F.,  D.D.  McFadden and L.L.  Piper  (Research
 Triangle Institute).   The  NSPS Triennial  Review:   Final Report.
 Prepared for  U.S.  Environmental Protection Agency, Washington  0 f
 Publication No. RTI/2747/01 -18F, December  20, 1984.          '  ""

    _      f.  Telephone  Conversations  initiated  by  Lee Beck, U.S.
 tnvironmental  Protection Agency, with  the  following individuals:
                                                            RTI
 Conversation Date
                Person Contacted
                                                     Affil iation
 February 1 3,
 February 16,
March 29
November
December
December
December
December
January 23
January 25
January 28
January 28
February 4
February
February
February
February
     1984
     1984
  1984
19,  1984
4,
5,
5,
8,
1984
1984
1984
1984
1985
1985
1985
1985
1985
1985
1985
1985
1985
 Bruce  Varner
 Rick Watman
 Mark Hooper
 Ken Roberts
 Steve  Riva
 Ed Chromanski
 Ann Zownier
 John Hoi 1ingsworth
 Jerry  Vetter
 Sammy  Amerson
 Johnnie Cole
 Fred Roe
 Sammy Amerson
 John Ledger
 Ed Chromanski
Byron Sullivan
 Ed Chromanski
                            Florida Dept.
                                  NJ
                                  NJ
              EPA, Region V
              EPA, Region III
              EPA, Region X
               of Environmental  Regulation
              EPA, Region II
       Bureau of Air Pollution Control
       Bureau of Air Pollution Control
              CIL Chemicals,  Inc.
              Beker Industries,  Inc.
  NC Division of Environmental  Management
 Florida Dept. of Environmental  Regulation
      GA Environmental  Protection Division
   NC Division of Environmental  Management
Idaho Division of Environmental  Management
    NJ Bureau of Air  Pollution Control
    NJ Bureau of Air  Pollution Control
    NJ Bureau of Air  Pollution Control
                                 4-17

-------
February 14, 1985     Craig Rushin                 EPA,  Region VI
February 22, 1985     Chris Roeder   Florida Dept. of Environmental  Regulation
February 25, 1985     Pat McCoy                    EPA,  Region V
March 14, 1985        Lynn Malcolm        Ohio Environmental  Protection  Agency
March 27, 1985        Charles Meskal   Fresno County Air  Pollution  Control  District

     2.  Drabkin, M. and K. J. Brooks (Mitre Corporation).   A Review of
Standards of Performance for New Stationary Sources - Sulfuric: Acid
Plants.  Prepared for U.S. Environmental  Protection Agency,  Research
Triangle Park, N.C.  Publication No.  EPA-450/3-79-003.   January 1979.
p. 4-1.

     3.  Reference 2, p. 4-26 and 4-28.

     4.  Reference 2, p. 4-28 and 2-29.

     5.  Reference 2, p. 4-29.

     6.  Telecon.  Beck, Lee, EPA, OAQPS,  with Riva,  Steve,  EPA,. Region  II.
December 5, 1984.  NSPS Sulfuric Acid Plants in EPA Region  II.

     7.  Telecon.  Beck, Lee, EPA, OAQPS,  with McCoy,  Pat,  EPA,  Region V.
February 25, 1985.  NSPS Sulfuric Acid Plants  in EPA  Region  V.

     8.  Reference 2, p. 4-29.

     9.  Reference 7.

    10.  Office of Air Quality Planning and Standards.   Final  Guideline
Document:   Control  of Sulfuric Acid Mist  Emissions from  Existing Sulfuric
Acid Production Units.  U.S.  Environmental  Protection Agency,  Research
Triangle Park,  N.C.  Publication No.  EPA-450/2-77-019.   September 1977.
pp. 6-1  through 6-23.
                                   4-18

-------
  5.0   COMPLIANCE TEST RESULTS
       Several  resources were accessed to determine the NSPS compliance status
  of sulfuric acid plants operating in the United States, including:
           EPA Regional  Offices
           State environmental  control  offices
           Local  environmental  control  offices
           A printout of EPA's Compliance Data System
           A study  performed for EPA's  Office of Planning  and  Policy  Evaluation
           by the Research Triangle Institute
      The results of this  survey show that  there are  46  NSPS plants currently
 operating in the United States,  and  all  appear  to  be in compliance with the
 NSPS.
 5.1   Analysis  of NSPS Compliance  Test Results
      The NSPS  limits emissions  of S02 to 4 pounds  per ton of acid produced.
 As shown in  Table 5-1,  results  of compliance tests (Method 8)  on the 46 sulfuric
 acid  units  indicate that all have  achieved the  NSPS  for S02.  However, most
 of the plants  operate with  S02 emissions between 2 and 4 pounds per ton,  and
 about  half of  these are in  excess  of 3 pounds per ton.  The available information
 is insufficient to determine whether the plants with  highest emissions could
 achieve  lower emissions through changes in  maintenance or  operation.
     Performance test results indicate  that all  plants have  also  complied
with the NSPS for acid  mist, and no violation of the  opacity regulation was
measured at 30 plants.   Similar to the  S02  emissions, many plants were found to
be operating close  to the  NSPS  limit  for acid mist  and opacity.  Opacity data
are not available for the  remaining 16 plants.

                                     5-1

-------
TABLE  5-1.  NSPS COMPLIANCE TEST RESULTS FOR SULFURIC ACID PLANTSi
Company
Agrico Chemical Co.
Allied Corp.
American Cyan amid
Badyer Army
Ammunition Plant
Beker Ind. Inc.
Y1 CF Ind. Inc.
ro
CIL Chem. Inc.
Conserv. Inc.
Farml and Ind.
Freeport Chem. Co.
Gardinier, Inc.
W.R. Grace X Co.
Location
S. Pierce, FL
Oonal dsonvill e, LA
Anacortes, WA
Westwego, LA
Savannah, GA
Baraboo, WI
Conda, ID
Taft, LA
Bartow, FL
Plant City, FL
Plant City, FL
Sayerville, NJ
Nichols, FL
Bartow, FL
Uncle Sam, LA
Tampa, FL
Bartow, FL
Unit
10
11
10
11
D
1
1
1
1
2
7
C
I)
C
F
1
3
4
D
7
9
4
5
6
Capaci ty
(TPO)
2000
2000
1800
1800
116
1600
800
350
1200
800
2000
1500
1500
100U
1000
2000
1600
1600
1250
1750
2600
1800
1800
1800
Emi ssior
S0_£_ /
3.72
3.43
2.2
1.1
1.07
3.20
2.21
Down/Never Tested
3.7
0.84
0.12
2.76
1.81
1.12
3.7
2.2
1.2
1.3
1.96
1.37
1.98
1.8
0.9
2.5
i Test Results
Icid Mist
0.11
0.12
NA
0.08
0.004
0.02
0.09

0.12
0.01
0.02
0.05
0.05
0.04
0.12
0.12
0.07
0.08
0.11
0.05
0.06
0.06
0.13
0.09
Opacity
0
0
NA
NA
NA
NA
0

NA
NA
NA
0
2.7
0
0
0
0
5
1 '\
0
0
5.2
5.0
5.8

-------
TABLE 5-1.   NSPS  COMPLIANCE  TEST  RESULTS  FOR  SULRJRIC  ACID  PLANTS (cont)
Company
Industrial Chemicals
International
Mineral s K,
Chemicals Corp.


Mississippi Chem.
Corp.
Occidental Chem.
Corp.
en
OJ
PVS Chem. Inc.
Rohm & Haas Corp.
Shell Chem. Co.
J.R. Simplot Co.

Texasgulf, Inc.


USS Agri -Chemicals

Location
Penuelas, PR
New Wales, FL


Pascagoula, MS
White Springs, FL


Copley, OH
Deer Park, TX
Wood River, IL
Helm, CA
Pocatello, ID

Aurora, NC


Ft. Meade, FL

Unit
1
]
2
3
4
5
3
C
1)
E
F
]
3
1
4
I
2
3
4
5
1
2
Capac i ty
(TPD)
60
2750
2750
2750
2500
2500
1500
1800
1800
2000
2000
250
800
360
1800
500
600
1525
1525
3100
2200
2200
SO?
0.15
2.64
2.29
3.17
2.10
3.79
0.95
3.47
3.71
2.61
3.32
2.53
2.32
3.24
2.30
3.6
3.6
1.7
1.8
2.52
2.0
1.2
Emission Test Results
Acid Mist
0.02
0.04
0.03
0.06
0.02
0.05
0.13
0.10
0.04
0.05
0.04
0.09
0.08
0.01
0.04
0.15
0.15
0.05
0.07
0.13
0.05
0.04
Opaci ty
NA
0
0
NA
0
0
NA
0
0
0
0
NA
9.2
NA
NA
NA
NA
o
u
(J
6.6
6.6

-------
5.2  Comparison of NSPS Compliance Test  Data  with Oay-to-Day
     Emission Control  Performance^
     Literature indicates that dual  absorption  plants  can  be expected to
operate after an initial  startup period  with  fresh  catalyst with $03 emissions
in the range of 2 to 3 Ib/ton.  To determine  whether emission control performance
deteriorates with time, a number of inquiries were  made  of sulfuric acid
plants that were subject  to NSPS.
     Data obtained from an 1,800 ton/day dual absorption sulfuric acid plant
(two production units) indicated an  apparent  deterioration of emission
performance following  initial  startup.   The NSPS compliance test for this
plant (Method 8) showed emissions to average  0.93 Ib SOg per ton of acid
produced.  About a year later, emission's recorded by the continuous emissions
monitor (CEM) had increased to 2.59  Ib/ton.   Nineteen  months after the performance
test, the emission recorded by the CEM had increased to  2.95 Ib/ton, and the
CEM data  recorded 30 months after the performance test indicated a S0£ emission
rate of 3.2 Ib/ton.
     Another plant had an NSPS test  result of 0.95  Ib  S0£/ton after fresh
catalyst  was added to  the absorption towers,  but reported  a day-to-day
operating level  of 1 to 2 1 b S02/ton.
     From these data,  it  can be seen that the S02 emission values obtained
during the initial  compliance  test do not necessarily  reflect day-to-day
plant operating levels.  These levels appear  to realistically lie in the 2 to
3 Ib/ton  range for dual absorption units.  There is a  definite trend towards
increased S02 emission values  as  the conversion catalyst ages and its activity
                                  5-4

-------
 correspondingly decreases.  Thus,  even  though  a  large  percentage of the

 compliance test results are significantly  less than  the NSPS of 4 Ib/ton, it

 appears that SO? emissions tend  to rise towards  the  control limit as the

 plant and catalyst  age.

      Acid mist  emission (and  related opacity) levels are unaffected by

 conversion catalyst  aging.  These  emissions are  primarily a function of

 moisture  levels in the  sulfur  feedstock  and air  fed to the sulfur burner,

 and  the efficiency of final absorber operation.
 5.3   Analysis of SOg Excess Emissions Reports

      Periods of excess emissions were compiled for each NSPS sulfuric acid

 plant operating in the United States during the period of April  1983 through

 March 1984. 3  During that 12-month period, 13 plants reported exceedances,

 with  the number of individual  exceedances at the 13 plants ranging  in number

 from  1 to 49.

     Analysis of these reports indicates considerable variation  among

 respondents in the interpretation of the excess emission  report  (EER)

 requirements.  The general  provisions of the regulations  define  the  content

of EERs  as it pertains  to exceedances as:

          The magnitude of excess emissions  computed  in accordance with
          §60.13(h),  any  conversion  factor(s)  used,  and the  date and time
          of  commencement and  completion  of  each time period of excess
          emissions.   [§60.7(c) (1)]

Subpart  H defines  exceedances  as:

          Periods of  excess emissions  shall  be  all  three-hour periods
          (or the  arithmetic average  of three  consecutive one-hour
          periods)  during which the  integrated  average sulfur dioxide
          emissions exceed the applicable  standards in §60.82.  [§60.84(e)]
                                   5-5

-------
     Of the 13 reports showing exceedances,  only  five of thes.3 correctly defined



exceedances as a 3-hour period during which  the average emissions exceeded the



standard.  The remaining eight reported  all  periods of time during which the



standard was exceeded.  These periods ranged from 2 minutes to 20 hours.  Many



of the shorter periods of reported  exceedances (2 hours or less) probably



would not show up as exceedances  if integrated over the 3-hour period in which



they occurred.  Conversely,  exceedances  lasting over 3 hours are reported as



one exceedance, when as many as seven could  be involved if converted to 3-hour



integrated periods.



     The effect of the apparent oversight  of the  3-hour duration reporting



requirements can be  further  illustrated  by considering the 12 months of EER



data reported by one plant.   The  plant reported 39 incidences of excess



emissions for the year with  the following  durations:



               Less  than 1 hour           18



          0    1 to  2 hours                5



               2 to  4 hours                6



               4 to  6 hours                7



          0    Over  6 hours                3





Only about half of the reported exceedances  would be considered excess



emissions for which  reporting would be required.
                                  5-6

-------
 5.4   REFERENCES
     1.   Information generated from the following sources:

          a.  Stationary Source Compliance Division, U.S. Environmental
Protection Agency.  Compliance Data System Source Data Report.  Printouts
dated February 3, 1984, and January 25, 1985.  92 p.

          b.  Tennessee Valley Authority.  World Fertilizer Capacity -
Sulfuric  Acid.  Printout dated  August 16, 1984.  12 p.

          c.  SRI international.  1984 Directory of Chemical  Producers.
Menlo Park, California.  1984.

          d.  Letter and attachments from Thomas, W.C., State of Florida
Department of Environmental  Regulation, to Beck, L.L., EPA.   May 21, 1984.

         e.  Massoglia, M.F.,  D.D.  McFadden and L.L.  Piper (Research
Triangle  Institute).  The NSPS Triennial  Review:  Final  Report.
Prepared  for U.S.  Environmental  Protection Agency,  Washington,  D.C.
Publication No.  RTI/2747/01-18F,  December  20,  1984.

         f.  Telephone  Conversations  initiated by Lee  Beck,  U.S.
Environmental  Protection  Agency,  with  the  following  individuals:
                                                                     RTI
Conversation Date
                         Person Contacted
                                                    Affil iation
 February  13,
 February  1 6,
 March  29
 November
 December  5,
 December  5,
 December  5,
 December  5,
 January 23,
 January 25,
 January 28,
 January 28,
 February 4,
 February 4,
 February 5,
 February 5,
 February 8,
 February 1 4,
 February 22,
 February 25,
 March 14,
March 27,
             1984
             1 984
          1984
          9,  1984
           1 984
           1984
           1984
           1984
           1985
           1935
           1 985
           1985
           1985
           1 985
           1985
           1  985
           1985
             1985
             1985
             1985
         1985
         1985
 Bruce  Varner
 Rick Watman
 Mark Hooper
 Ken Roberts
 Steve  Riva
 Ed Chromanski
 Ann Zownier
 John Hoi 1ingsworth
 Jerry  Vetter
 Sammy  Amerson
 Johnnie Cole
 Fred Roe
 Sammy  Amerson
 John Ledger
 Ed Chromanski
 Byron  Sull ivan
 Ed Chromanski
 Craig Rushin
Chris Roeder
Pat McCoy
Lynn Malcolm
Charles Meskal
Florida Dept
       EPA,
       EPA,
       EPA,
       . of
   NJ
   NJ
Bureau
Bureau
 NC
Fl orida
                   Region V
                   Region III
                   Region X
                  Environmental Regulation
              EPA, Region II
              of Air Pollution Control
              of Air Pollution Control
              CIL Chemicals, Inc.
              Beker Industries, Inc.
     Division of Environmental  Management
     •ida Dept. of Environmental Regulation
   GA Environmental  Protection Division
   NC Division of Environmental Management
Idaho Division of Environmental Management
    NJ Bureau of Air Pollution  Control
              of Air Pollution  Control
              of Air Pollution  Control
              EPA,  Region VI
Florida Dept. of Environmental  Regulation
              EPA,  Region V
     Ohio Environmental  Protection  Agency
 Fresno County Air  Pollution Control District
   NJ
   NJ
Bureau
Bureau
                                         5-7

-------
     2.  Drabkin, M.  and K.  J.  Brooks  (Mitre  Corporation).   A  Review of
Standards of Performance for New Stationary  Sources  -  Sulfuric Acid
Plants.  Prepared for U.S.  Environmental  Protection  Agency,  Research
Triangle Park, N.C.  Publication No. EPA-450/3-79-003.  January 1979.
pp. 5-9 through 5-11.

     3.  Massoglia, M.F., D.D.  McFadden  and  L.L.  Piper  (Research Triangle
Institute).  The NSPS Triennial  Review:   Final  Report.  Prepared for U.S.
Environmental  Protection Agency, Washington,  D.C.  RTI  Publication No.
RTI/2747/01-18F, December 20,  1984.
                                   5-8

-------
                               6.  COST ANALYSIS

     This chapter  presents  current  (June 1984) costs of control systems
 necessary to meet  the  sulfur  dioxide and sulfuric acid mist emission provisions
 of  the  current  NSPS  for  sulfuric  acid plants.  Four systems are analyzed for
 sulfur  dioxide  control:   the  dual absorption sulfuric acid process; the
 molecular sieve; the sodium sulfite-bisulfite scrubbing process; and the
 ammonia scrubbing  process.  For control of sulfuric acid mist, two types of
 mist eliminators are analyzed:  the vertical tube ("candle" or "Brink") type
 and the horizontal dual  pad (York "S") type.  Capital and annual 1 zed costs
 are estimated for  the  following model plant sizes, all given on a 100 percent
 acid basis:  681 Mg  per  day (750  tons per day) and 1,361 Mg per day (1,500
 tons per day).
     The costs  presented are  based primarily on information provided by
 vendors and developed  from  literature sources.  (See Appendix A for copies of
 letters sent to vendors.)   Capital costs are on a turnkey basis and thus
 include the purchase cost of  equipment and auxiliaries, taxes, freight, and
 all necessary installation  costs, as well as indirect costs such as engineering
 and supervision, construction  and field expense, contractor fee, and contingency.
 Annualized costs include direct operating costs such as operating labor,
 maintenance labor, utilities,  and materials, as well as indirect costs such
 as  capital charges',  overhead,  property taxes, insurance, and administration.
 Net annualized  cost  is also presented, representing total annualized cost
 less the credit for  recovered  sulfuric acid product.  Since the capital costs
 were obtained from turnkey  cost correlations, they are, by definition, "order-
 of-magnitude" (i.e., greater  than ^30 percent in accuracy).  Because many of
 the annualized  costs were calculated directly, the accuracy of the annualized
 cost estimates  is expected  to  approach that of a study estimate (^30 percent).
Finally, cost effectiveness is given for both sulfur dioxide control and
control  of sulfuric  acid mist.

6.1    DUAL ABSORPTION PROCESS

6.1.1   Capital  Costs

       The capital  costs for dual  absorption are estimated for the two model
plants and represent the incremental costs of achieving the NSPS compared to
                                     6-1

-------
an uncontrolled, i.e. single absorption,  plant.   The  control  system is
comprised of all the equipment necessary  for providing  the  second  absorption:
an absorption tower, pumps, heat exchangers, and  piping and instrumentation.
       The dual absorption process has essentially  become the state of  the
art for producing sulfuric acid.  Therefore, plant  vendors  are the best
source of cost information concerning the second  absorption portion of  the
plant.  Accordingly, contact with vendors provided  total turnkey costs
(References 1, 2, and 3) from which were  factored out the individual  direct
and indirect cost components by use of appropriate  factors  based on data .from
Reference 8.  All costs were updated to June 1984 dollars by  employment of
the Chemical Engineering (CE) Plant Cost  Index.   Tables 6-1 and 6-2 present
the capital costs for dual absorption for the model plants.
       As an example of the factoring procedure mentioned above, consider the
681 Mg per day plant for which the incremental total  direct cost for dual
absorption is $1,118,000.  The cost of the absorber itself  is calculated to
be 50 percent of the total direct cost ($558,000).  Similarly the  costs for
the auxiliary equipment are as follows:  $112,000 for pumps (10 percent of
total  direct cost); $168,000 for piping (15 percent); and $280,000 for  heat
exchangers (25 percent).

6.1.2  Annualized Costs
       The annualized costs associated with owning  and operating  the second
absorption system are estimated for each of the model  plants.  Direct operat-
ing cost includes operation, maintenance, utilities and catalyst  replacement.
Utilities include an "energy penalty" or loss of steam credit for reheating
of the gas prior to reentering the converter.  The  cost of catalyst replace-
ment includes the disposal cost for the spent catalyst.  Assumed  values for
consumption and unit costs associated with these items are shown  in Table 6-3.
       Most indirect costs were factored from capital  costs or direct operat-
ing costs using appropriate factors from References 4 and 8.  Capital recovery
was calculated from the total capital cost with a 10 percent rate of return
and a 10-year equipment life (References 4 and 8).
       The annualized cost development includes an  estimation of  the credit
for sulfuric acid recovered as a result of the second absorption.  The amount
                                     6-2

-------
                                 Table  6-1

                            CAPITAL  COST  SUMMARY
                    INCREMENTAL COST FOR  DUAL  ABSORPTION
                       681 MG PER DAY (750  TPD) PLANT
                            (June 1984 Dollars)
                                                                  Cost in
                                                                Thousands
                                                                of Dollars
Direct Cost3
  Absorber
  Pumps
  Piping
  Heat exchangers
                  Total  Direct Costb
Indi rect Costc
  Engineering and supervision (10 percent of direct)                 112
  Construction and field expense (8 percent of direct)                89
  Contractor fee (6 percent of direct)                                67
  Contingency (12 percent of direct)                                 134
                  Total Indirect Cost                                402

Total  Capital Cost 	1.520
aDirect cost for each item of equipment includes cost of auxiliary equipment,
 instruments and controls, taxes, freight, foundations, handling and erection,
 and any other required installation costs.

bCost developed from information from References 1, 2, 3 and 8.

cPer Reference 8.
                                     6-3

-------
                                 Table  6-2

                            CAPITAL COST SUMMARY
                    INCREMENTAL COST FOR DUAL ABSORPTION
                      1361 MG PER DAY (1500 TPD)  PLANT
                            (June 1984 Dollars)
                                                                  Cost  in
                                                                 Thousands
                                                                 of Dollars
Direct Cost3
  Absorber                                                           791
  Pumps                                                              158
  Pi pi ng                                                             237
  Heat exchangers                                                    395
                  Total  Direct Cost5                 ,              1,581
                                         - ,           i
                                                     i
Indirect Costc
  Engineering and supervision (10 percent of direct)                 158
  Construction and field expense (8 percent of direct)               126
  Contractor fee (6 percent of direct)                                95
  Contingency (12 percent of direct)                                 190
                  Total  Indirect Cost                                569

Total Capital Cost         	2,150
aDirect cost for each item of equipment includes cost of auxiliary equipment,
 instruments and controls, taxes, freight, foundations, handling and erection,
 and any other required installation costs.

bCost developed from information from References 1, 2, 3 and 8.

cPer Reference 8.
                                      6-4

-------
                                  Table  6-3

                             CONSUMPTION AND  UNIT
                    COST  ESTIMATES FOR ANNUAL. INCREMENTAL
                      OPERATING COST  OF  DUAL  ABSORPTION
                     (Based  on  350 Stream Days Per Year)
       Operating  Cost  Item
Consumption (Production)
 Unit Cost
  (Credit)
 Operating  labor
 Maintenance  labor
 Plant water
 Electricity  (pumps, fan)
 Loss of stream credit
 Catalyst replacement (including
  disposal)
 Sulfuric acid credit
 525 hours per year3
 525 hours per year3
 3.91m3 per 1,000
 47.5 Gj per 1,000
 335 Gj per 1,000
 0.01m3 per 1,000 Mgn

 17 Mg per 1,000 'MgJ
$10.89/hourb
$11.98/hourc
$0.20/m3e
$15.28/Gj9
$7.30/Gj9
$4,240/m3i

$71.66/Mgk
Reference 4.
Deference 5.
cTen percent premium over operating labor (per Reference 4).
^Calculated on basis of water required for absorption.
Reference 6.
fReference 7.
9Cost updated from Reference 13.
"Reference 9.
^Reference 4 and Reference 9 (updated).
^Calculated from incremental  efficiency of dual  versus single absorption.
^Reference 10.

-------
of sulfuric acid recovered for each model  plant was  calculated  from  the
difference in sulfur conversion efficiency between single  and dual absorp-
tion (98 and 99.7 percent, respectively, Reference 9).   Credits for  this
recovered product were then calculated using a price of $65 per ton  ($71.66
per Mg) as quoted in the Chemical  Marketing Reporter.  This price  is based  on
a Gulf Coast location and has remained quite stable during the  period January
to June, 1984.  The annualized costs for dual absorption are shown in Tables
6-4 and 6-5.
                                      6-6

-------
                                  Table 6-4


                            ANNUALIZED COST SUMMARY

                     INCREMENTAL COST FOR DUAL ABSORPTION

                        681 MG PER DAY (750 TPD) PLANT

                             (June 1984 Dollars)
                                                                   Cost in
                                                                  Thousands
                                                                  of Dollars
 Direct Operating Cost

   Operation

     Operating labor
     Supervision labor3

   Maintenance
     Labor
     Material  (100 percent  of maintenance labor)b

   Utilities
                                                     *
     Plant waterc                         "          i
     Electricity
     Loss  of steam credit

   Catalyst replacement

 Indirect  Operating  Cost

   Overhead*^

     Plant (50 percent  of operating  labor, super-
       vision  and maintenance)

     Payroll  (20 percent of  operating  labor,  supervision
       and maintenance  labor)

Capital recovery (10 percent  rate of  return,
   10 years  equipment, life)

Insurance,  taxes, and  administration  (four
   percent  of  total  capital  cost)

Total Annualized Cost  Without Credit

Credit For  Recovered Acid

Net Annualized  Cost
   6
   1
   6
   6
 173
 583

  10
   7


   3


 247


  61


1,103

 (290)

  813
315 percent of operating labor (Reference 4)
bReference 4

cRounded to zero

^Factors from Reference 8

-------
                                Table  6-5
                           ANNUALIZED  COST  SUMMARY
                    INCREMENTAL  COST FOR  DUAL ABSORPTION
                      1361  MG PER DAY  (1500 TPD)  PLANT
                            (June 1984 Dollars)
                                                                  Cost  1n
                                                                 Thousands
                                                                 of  Dollars
Direct Operating Cost
  Operation
    Operating labor
    Supervision labor3
  Maintenance
    Labor
    Material (100 percent of maintenance 1abor)b
  Utilities
    Plant water0
    Electricity
    Loss of steam credit
  Catalyst  replacement
 Indirect Operating Cost
  Overhead^
    Plant  (50  percent of operating labor, super-
       vision and maintenance)
    Payroll  (20 percent of  operating,  supervision,
       and  maintenance labor)
 Capital  recovery  (10 percent  rate  of  return,
  10  years  equipment life)
 Insurance,  taxes,  and administration  (four
  percent  of total  capital  cost)
 Total  Annualized  Cost Without Credit
 Credit For Recovered Acid
 Net Annual i zed Cost	
    6
    1
    6
    6
  346
1,165
   20
    7
    3
  350
   86

  1,996
   (580)
  1,416
 a!5 percent of operating labor (Reference 4)
 bReference 4
 CRounded to zero
 ^Factors from Reference 8
                                      6-8

-------
 6.2    MOLECULAR SIEVE PROCESS

 6.2.1  Capital Costs

        There are no known applications of the molecular sieve  process  to
 control S02 emissions from a single absorption sulfuric acid plant.
 Reference 9 identified one such plant but indicated that the owner planned to
 convert the plant to double absorption.  Furthermore,  the major  supplier of
 this technology for sulfuric acid plants no longer offers the  process,
 presumably because the technology has not proven successful for  this
 application.
        Nevertheless, a modest amount of cost data for  the molecular sieve
 process is available (Reference 11) and has been updated and presented in
 Table 6-6.  The reader is cautioned that:  (a) the original costs are  old;
 (b) the original  costs may have been high due to necessary developmental
 costs;  and (c) the  costs  presented  in Table 6-6 are representative of  a
 process that may  not be adequate for continuous compliance with  the sulfur
 dioxide emission  limitation.               ~          ;

 6.2.2  Annualized Costs

        The annualized  costs  for the molecular sieve process are  updated from
 Reference  11 and  also  presented  in  Table  6-6.  The  total  annualized costs on
 a  per ton  acid  basis were  updated from  data  in  the  reference by the use of
 the CE  index and are assumed  to  hold  for  all  model  plant  sizes.

 6.3     SODIUM  SULFITE-BISULFITE  SCRUBBING

 6.3.1   Capital  Costs

        Reference 9 indicated  no  applications  for sodium sulfite-bisulfite
scrubbing  for sulfur dioxide  NSPS compliance  from the time of NSPS promulga-
tion through 1978.  Furthermore, because  of the wide acceptance of dual
absorption technology, it  is not likely that many single absorption  plants
                                     6-9

-------
                  Table 6-6


      CAPITAL AND ANNUALIZED COST  SUMMARY

            MOLECULAR SIEVE PROCESS

             (June 1984 Dollars)


                CAPITAL COST
                                  Cost  in
                            Thousands of Dollars
                                          1,361
                            Mg  PD _  Mq  PD
Total  Capital  Cost Costa    3,363         5,105
               ANNUALIZED COST
                                  Cost  in
                            Thousands of  Dollars
                            ~6811,361
                            Mg PD	Mg PD
Total  Annual i zed Costb	1,119	2.237

alncludes all  direct and indirect costs for
 applying the process to a new sulfur-burning
 sulfuric acid plant (Reference 11).
^Includes all direct and indirect annual  costs
 (operating and maintenance, utilities, overhead,
 depreciation, insurance, taxes, and administra-
 tion) .
                    6-10

-------
with  sodium sulfite-bisulfite  scrubbing  have been or will be built.  Neverthe-
less,  sodium-based  scrubbing appears to  be  a viable technology for meeting
the NSPS  and thus  costs  for this  technology have been estimated.
        The  capital  costs for the  two model  plants were developed from vendor
information, scaling  the cost  for the model plants by use of a 0.6 exponent.
The control  system  in each case consists of all necessary equipment to absorb
sulfur dioxide  from the  weak exhaust stream and regenerate a strong sulfur
dioxide stream  suitable  for conversion to elemental sulfur or liquid sulfur
dioxide or  for  recycle to the  sulfuric acid plant itself.  The capital  cost
excludes  the cost  for this conversion or recycle and therefore the annualized
cost  does not include a  credit for  recovered acid, sulfur, or liquid sulfur
dioxide.  Total  turnkey  costs  were  supplied (Reference 14), which were then
factored  to  show direct  cost and  the various items of indirect costs.  Tables
6-7 and 6-8 present these capital costs  for the two model plants.

6.3.2   Annualized Costs

        The  annualized costs associated with owning and operating the sodium
sulfite-bisulfite scrubbing systems are  estimated for each model plant.
Direct  costs include  operating labor, maintenance, and steam.  The operating
labor  and maintenance requirements  were  taken from Reference 15 and the steam
requirement  from Reference 14.  Unit costs  for these items were taken from
Table  6-3.   The  cost  to  treat  a bleed stream of sodium salts and the cost of
making  caustic soda were  calculated but  not included as they are negligible
compared  to  other operating costs.
        Indirect  costs were factored from  capital or direct operating costs
using the appropriate  factors  from  References 4 and 8.  Capital  recovery was
calculated on the basis  of a 10 percent  interest rate and a 10 year assumed
equipment life (References 4 and  8).  The annualized costs for the model
plants are shown in Tables 6-9 and  6-10.

6.4    AMMONIA SCRUBBING.

6.4.1   Capital Costs

       Only  two  ammonia scrubbing applications  were identified in the earlier

                                     6-11

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                                 Table  6-7


                            CAPITAL  COST  SUMMARY

                     SODIUM SULFITE-BISULFITE  SCRUBBING

                      681 MG PER DAY (750 TPD)  PLANT

                            (June 1984  Dollars)    *
                                                               Cost  in
                                                             Thousands
                                                             of  Dollars
Total  Direct Cost3                                              3,280


Indirect Cost

  Engineering and supervision (10 percent of direct)

  Construction and field expense (8 percent of direct)

  Contractor fee (6 percent of direct)              :

  Contingency (12 percent of direct)

             Total Indirect Cost                                1,180


Total  Capital Cost         	4,460	

aDirect cost of equipment includes cost of auxiliary equipment, instruments
 and controls, taxes, freight, foundations, handling and erection, and any
 other  required installation costs.  Costs developed from Reference 14.
                                      6-12

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                                 Table  6-8


                            CAPITAL COST SUMMARY

                     SODIUM SULFITE-BISULFITE SCRUBBING

                       1361 MG  PER DAY (1500 TPD) PLANT

                            (June 1984  Dollars)
                                                               Cost in
                                                              Thousands
                                                              of Dollars
Total Direct Cost3                                              4,970


Indirect Cost

  Engineering and supervision (10 percent of direct)
  Construction and field expense (8 percent of direct)

  Contractor fee (6 percent of direct)
  Contingency (12 percent of direct)                <

             Total  Indirect Cost                                1,790


Total Capital Cost	6,760

aDirect cost of equipment includes cost of auxiliary equipment,  instruments
 and controls, taxes,  freight, foundations, handling and erection,  and any
 other required installation costs.  Costs developed from Reference 14.
                                     6-13

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                                 Table  6-9


                           ANNUALIZED COST SUMMARY
                     SODIUM SULFITE-BISULFITE SCRUBBING

                       681 MG PER DAY (750 TPD)  PLANT
                            (June 1984 Dollars)
                                                                  Cost  in
                                                                 Thousands
                                                                 of Dollars
Direct Operating Cost

  Operation
    Operating labor3                                                274
    Supervision laborb                                               41

  Maintenance (4 percent of total  capital  cost)c                    178

  Utilities                                         !
    Electricity                           ~          '                125
    Steam                                                           633
Indirect Operating Cost

  Overheadd
    Plant (50 percent of operating labor, super-                    202
      vision and maintenance)
    Payroll (20 percent of operating, supervision,                   81
      and maintenance labor)
Capital  recovery (10 percent rate of return,                        726
  10 years equipment life)
Insurance, taxes, and administration (four                          178
  percent of total capital cost)

Total Annual ized Cost	2,438
aLabor requirements from Reference 15.
b!5 percent of operating labor (Reference 14).
Reference 15.
dFactors from Reference 8.  Assumes that 50 percent of maintenance cost is
 maintenance labor.


                                     6-14

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                                  Table 6-10


                            ANNUALIZED COST SUMMARY

                      SODIUM SULFITE-BISULFITE SCRUBBING

                       1361 MG PER DAY (1500 TPD)  PLANT

                             (June 1984 Dollars)
                                                                   Cost  in
                                                                  Thousands
                                                                  of  Dollars
 Direct Operating Cost

   Operation
     Operating labor3
     Supervision 1aborb

   Maintenance (4 percent  of total  capital  cost)c

 -  Utilities
     Electricity     ~
     Steam
  412
   62

  270
  251
1,266
 Indirect  Operating  Cost

   Overhead^

     Plant  (50  percent of  operating  labor,  super-
       vision and maintenance)

     Payroll (20 percent of operating,  supervision,
       and  maintenance labor)

Capital recovery (10 percent rate of return,
   10 years equipment life)

Insurance, taxes, and administration (four
   percent  of total   capital cost)

Total Annualized Cost
  305


  122


1,100


  270


4,058
^Labor requirements from Reference 15.
b!5 percent of operating labor (Reference 14).
Reference 15.
factors from Reference 8.  Assumes that 50 percent of maintenance cost is
 maintenance labor.
                                    6-15

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NSPS review (Reference 9).  Because of the production  of  ammonium  sulfate as
a by-product, this scrubbing process could possibly  be desirable for  sulfuric
acid plants that are part of a fertilizer complex.   Therefore, costs  for this
technology have been estimated, although the technology would probably  only
be employed in preference to dual  absorption in highly-specific  applications.
       The capital costs for the two model plants were developed from informa-
tion supplied by a vendor of this  technology and using an approach similar to
that for sodium-based scrubbing.  As with the sodium sulfite-bisulfite
scrubbing system, this system includes all necessary equipment  to  absorb
sulfur dioxide and regenerate a strong sulfur dioxide stream for further
processing.  The cost of a plant to recover elemental  sulfur or produce
liquid sulfur dioxide is not included.  The acid plant is assumed  to be part
of a fertilizer complex and thus facilities for granulating the ammonium
sulfate by-product will be available.  The direct and indirect  costs were
factored from the total turnkey costs  (Reference 14) by employing  appropriate
factors from References 4 and 8.  Tables  6-11 and 6-12 present  the capital
costs.

6.4.2  Annualized'Costs
        The  annualized costs  for ammonia scrubbing are estimated for each
model  plant.   The  direct  costs include operating labor, maintenance, elec-
tricity,  and  the cost of  ammonia, which can be noted to be the major annual-
ized  cost item.  The operating labor  and maintenance requirements were taken
from  Reference 15  while the  steam and ammonia requirements were taken from
Reference 14.  The unit costs  for these were from Table 6-3 and from Chemical
Marketing Reporter for the unit cost  of ammonia.
        Indirect  operating costs were  factored from  the capital or direct
operating costs  with  factors from References 4 and  8.  Capital recovery  is
based on  a 10 percent  interest rate and an assumed  useful  life of 10 years
for the equipment.  The  annualized  costs  for the model plants are presented
in Tables 6-13 and 6-14.
                                      6-16

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                                Table 6-11

                            CAPITAL COST SUMMARY
                             AMMONIA SCRUBBING
                      681 M6 PER DAY (750 TPD) PLANT
                            (June 1984 Dollars)
                                                               Cost in
                                                              Thousands
                                                              of Dollars
Total Direct Cost9                                              1,544

Indi rect Cost
  Engineering and supervision (10 percent of direct)              154
  Construction and field expense (8 percent of direct)            124
  Contractor fee (6 percent of direct)                             93
  Contingency (TZ'percent of direct)                              185
             Total  Indirect Cost                                  556

Total Capital Cost	2,100	
aDirect cost of equipment includes cost of auxiliary equipment,  instruments
 and controls, taxes,  freight, foundations, handling and erection,  and any
 other required installation costs.  Costs developed from Reference 14.
                                     6-17

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                                Table 6-12


                            CAPITAL COST SUMMARY

                             AMMONIA SCRUBBING

                     1361 MG PER DAY (1500 TPD)  PLANT

                            (June 1984 Dollars)
                                                               Cost  in
                                                              Thousands
                                                              of  Dollars
Total  Direct Cost9                                              2,344


Indirect Cost

  Engineering and supervision (10 percent of direct)               235

  Construction and field expense (8 percent of direct)             188

  Contractor fee (6 percent of direct)                             141

  Contingency (12-percent of direct)                              282

             Total Indirect Cost                                  846


Total  Capital Cost	3,190	

aDirect cost of equipment includes cost of auxiliary  equipment,  instruments
 and controls, taxes, freight, foundations, handling  and  erection,, and any
 other required installation costs.  Costs developed  from Reference 14.
                                     6-18

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                                 Table 6-13


                           ANNUALIZED COST SUMMARY

                              AMMONIA SCRUBBING

                       681 MG PER DAY (750 TPD) PLANT

                             (June 1984 Dollars)
                                                                  Cost in
                                                                 Thousands
                                                                 of Dollars
 Direct Operating Cost

   Operation

    Operating labopa                                                274
    Supervision laborb                                               41

   Maintenance (4 percent of total capital cost)c                     84

   Utilities     _
    Electricity                                                      78

 Chemicals  (ammonia)                                                 662


 Indirect Operating Cost

   Overhead^

    Plant  (50 percent of operating labor, super-                    179
      vision and maintenance)

    Payroll (20 percent of operating, supervision,                   71
      and maintenance labor)

 Capital  recovery (10 percent rate of return,                        342
   10 years equipment life)

 Insurance, taxes, and administration (four                           84
  percent of total  capital  cost)

Total  Annual ized Cost	1,815
aLabor requirements from Reference 15.
b!5 percent of operating labor (Reference 14).
cReference 15.
dFactors  from Reference 8.  Assumes that 50 percent of maintenance cost is
 maintenance  labor.
                                 6-19

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                                Table 6-14

                          ANNUALI ZED COST SUMMARY
                             AMMONIA SCRUBBING
                      1361 MG PER DAY (1500 TPD) PLANT
                            (June 1984 Dollars)
                                                                 Cost in
                                                                Thousands
                                                                of  Dollars
128
Direct Operating Cost
  Operation
    Operating labor
    Supervision labor3
  Maintenance (4 percent of total  capital  cost)b

  Utilities
    Electricity —                                                  lbb
Chemicals  (ammonia)                                               1,323

Indirect Operating Cost
  Overhead0
    Plant  (50 percent of operating labor, super-                    243
       vision and maintenance)
    Payroll  (20 percent of operating,  supervision,                   97
       and  maintenance labor)
Capital  recovery  (10 percent  rate of  return,                        519
   10  years equipment life)
 Insurance, taxes,  and administration  (four                          128
   percent  of total  capital cost)
 Total Annual i zed  Cost      _ _ _ _ __ -  3'014 -
 aLabor requirements from  Reference  15.
 bl5 percent of operating  labor (Reference 14).
 ^Reference 15.                                           .               .
 factors from Reference 8.  Assumes  that  50 percent of  maintenance cost  is
  maintenance labor.
                                      6-20

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 6.5     MIST ELIMINATORS

 6.5.1   Capital  Costs

        The  capital  costs  of mist eliminators  for the model plants are esti-
 mated  on  the basis  of  contact with equipment  vendors.  Note that in accord-
 ance with the model plant parameters the  681  megagrams per day (750 TPD)
 plant  employs a "Brinks"  type mist eliminator, while the 1,381 Mg per day
 (1500  TPD)  plant employs  a York "Type S"  mist eliminator.  Each mist elim-
 inator has  an approximate efficiency of 97 percent.  No data was found
 on a third  type —  the vertical panel mist eliminator — which was discussed
 in the earlier  NSPS review (Reference 9).  Discussion with vendors and
 mention in  the  literature (Reference 12)  has  indicated that this type of mist
 eliminator  would not be efficient enough  for  this application, presumably
 because of  its  marginal effectiveness in  removing submicron particles and
 possible  re-entrainment problems when operating at high gas velocities.  The
 mist eliminator capital costs are presented in Table 6-15.

 6.5.2   Annualized Costs
       Because mist eliminators have no moving parts and require little
attention, the only significant direct operating cost is for moving gas
through the unit.  This electricity cost has been calculated on the basis of
gas flowrate, pressure drop, and the unit cost of electricity previously
presented in Table 6-3.  The maintenance requirements for the demisters would
be negligible (Reference 1) consisting of cleanout and minor repair as
necessary during scheduled annual  shutdowns.  Indirect costs include capital
recovery and insurance, taxes, and administration.  There is also a substantial
credit for recovered sulfuric acid.  The annualized costs are also summarized
in Table 6-15.

6.6    SULFUR DIOXIDE MONITORS

6.6.1  Capital  Cost

       The capital  cost of an in-stack continuous monitor for sulfur dioxide

                                '  '  6-21

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                                Table  6-15


                    CAPITAL  AND  ANNUAL IZED COST  SUMMARY

                             MIST  ELIMINATORS

                           (June 1984  Dollars)

                              CAPITAL COST
                   	Total  Capital  Cost in Thousands of Dollars
                   681  Mg  Per  Day  (750 TPD)1361 Mg Per Day  (1500 TPD)
                    Vertical Tube  (Brinks)3	Horizontal Dual  Pad  (York)b

                            68                              112
                              ANNUALIZED COST	

                                                  Annualized  Costs  in
                                                  Thousands of  Dollars
                                             681  Mg  Per  Day    1381  Mg  Per  Day
                                                (750 TPD)        (1500  TPD)
                                              Vertical Tube    Horizontal Dual
                                                (Brinks)	Pad (York)
Direct Operating Cost

  Utilities

    Electricity^'                                  48              107


Indirect Operating Cost
    Capital recovery (10 percent rate of           11               18
      return, 10 years  equipment life)
    Insurance, taxes, and administration            3                4
      (four percent of total  capial  cost)

Total  Annualized Cost Without Credit               62              129

Credit for Recovered Acid                         (36)             (73)

Net Annual 1 zed Cost    	26	56	

alncludes all direct and indirect costs for the purchase and installation
 of the unit in the top portion of the final  absorber in a new sulfur-burning
 dual  absorption sulfuric acid plant.  (Calculated from cost data from
 Reference 1.)
^Includes all direct and indirect costs for the purchase and installation
 of a mist eliminator vessel  above the final  absorber in a new sulfur-burning
 dual  absorption sulfuric acid plant.  (Calculated from cost data from
 Reference 18.)
cPressure drops:  681 Mg per day -- 8 in. W.C.; 1381 Mg per day — 9 in. W.C.


                                      6-22

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is estimated based on data supplied by vendors  (References  16 and  17).  The
cost of the monitor is independent of acid plant  size.   Each monitor  is a
single-point extractive analyzer that employs a photoelectric (UV) principle.
Continuous samples are aspirated from the stack to  the  analyzer and results
are transmitted by a 4-20 mi Hi ampere electronic  signal  to  the readout in the
control room in the range of 0-500 ppm.  A three-tube bundle connects the
probe and the analyzer:  one tube carries sample  gas; the  second  is for
calibration gas; and the third is for high-pressure blowback air  to periodica-
lly clean the probe.  The analyzer is automatically calibrated once every 24
hours.  It is assumed that the distance between the probe  and the analyzer  is
approximately 100 feet.  The capital cost for continuous sulfur dioxide
monitoring is shown in Table 6-16.

6.6.2  Annualized Cost

       The only direct annualized cost item for the continunous monitor  that
is  not negligible is for  replacement of calibration gas (Reference 16).
Indirect costs include capital recovery and insurance, taxes,  and administra-
tion.  The annualized cost for continuous sulfur  dioxide monitoring  is  also
shown  in Table 6-16.

6.7   COST EFFECTIVENESS

6.7.1  Sulfur Dioxide Control
       Cost effectiveness for the types of sulfur dioxide control is shown in
 Table  6-17.   For the small model plant, cost effectiveness ranges from $311
 per Mg of S02 removed to $827, and for the large model plant the cost
 effectiveness ranges from $270 to $687 per Mg of S0£ removed.  For both
 model  plants, dual absorption is the  least costly at $311 per Mg for the
 small  plant and $270 per Mg  for the large plant.  Recalling the caveat from
 Section  6.2 concerning  the costs of the molecular sieve process, it can be
 seen from Table 6-17 that dual absorption is significantly more cost-effective
 than other applicable control technologies.  Indeed, dual absorption has
 accounted for over 87 percent of the  sulfuric acid plants built in the period
                                      6-23

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                               Table 6-16

                   CAPITAL AND ANNUALIZED COST SUMMARY*
                    CONTINUOUS SULFUR DIOXIDE MONITORS
                           (June  1984 Dollars)

                              CAPITAL COST
     Purchased  cost  of  analyzer                              40,800
     Flexible tubing from probe  to  analyzer                   2,950
     Installation                                             6,000
     Total  Capital  Cost          	         49,750
                             ANNUALIZED COST
Direct Operating Cost
  Maintenance (calibration gas)                                  '700

Indirect Operating Cost
  Capital recovery (10 percent rate of return,                 8,100
    10 years equipment life)
  Insurance, taxes, and administration (four                   1,990
    percent of total  capital cost)

Total Annualized Cost	10.800	
aCosts apply to either model plant.  Costs developed from References 16 and 17
                                      6-24

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1973 to 1977 (Reference 9) and undoubtedly accounts for an even greater
percentage for the period 1978 to the present.  Dual  absorption has become
the state of the art for producing acid, partly because it is the most
cost-effective technology for control of sulfur dioxide emissions.

6.7.2  Sulfuric Acid Mist Control

       The cost-effectiveness for control  of sulfuric acid mist is presented
in Table 6-18.  There is essentially no difference in the cost-effectiveness
of $52 and $55 per Mg of acid removed, especially when it is considered that
the costs were developed on a slightly different basis (see footnotes  for
Table 6-15).  Both units are capable of performing at efficiencies higher
than the 97 percent level required for other model plants to be in compliance
(Reference 12).  The horizontal  dual  pad mist eliminator is slightly less
cost-effective because it is defined in the model plant analysis to have a
slightly higher pressure drop (9 vs. 8 in. W.C.).
                                     6-25

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                               Table  6-17
                           COST  EFFECTIVENESS

                          SULFUR  DIOXIDE CONTROL

                            (June 1984  Dollars)
 Control  Method
               Annualized   S0£ Removed       C/E
 Plant Size       Cost         Mg/yr          $/Mg
Mg/day (TPD)   ($103/yr)a   (tons/yr)b       ($/ton)
Dual absorption

Molecular sieve

Ammonia scrubbing

Sodium sul fite-
bisulfite scrubbing
681 (750)
1361 (1500)
681 (750)
1361 (1500)
681 (750)
1361 (1500)
681 (750)
1361 (1500)
824
1427
1130
2248
1826
3025
2449
4069
2650 (2920)
5290 (5820)
2960 (3260)
5920 (6510)
2960 (3260)
5920 (6510)
2960 (3260)
5920 (6510)
311 (282)
270 (245)
382 (347)
380 (345)
617 (560)
511 (465)
827 (751)
687 (625)
alncludes the cost of continuous sulfur dioxide monitoring.
bFor dual absorption, calculated from the incremental  amount of sulfuric
 acid recovered vs. single absorption; for other controls, calculated using
 a removal efficiency of 95 percent and assuming a 98 percent conversion  of
 S02 to sulfuric acid in the single absorption process (Reference 9).
                                     6-26

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                                 Table  6-18


                             COST EFFECTIVENESS

                          SULFUR  ACID MIST  CONTROL

                             (June 1984 Dollars)
 Control Method
               Annualized   Acid Removed     C/E
 Plant Size       Cost          Mg/yr         $/Mq
Mg/day (TPD)   ($lo3/yr)    (tons/yrja      ($/ton)
Vertical tube

  (Brinks type)
   681 (750)
26
 504 (554)
52 (47)
Horizontal dual

  pad (York type)
  1381 (1500)
56
1020 (1120)      55 (50)
Calculated from acid recovery due to mist eliminator.
                                    6-27

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6.8    REFERENCES

  1.   Personal  communication with Mr.  Douglas  R.  Hansen, Monsanto Enviro-
       Chem, St. Louis, MO,  February  17,  March  5,  and March  14, 1984.
         (Documented by letters  dated February  21, March 6,  and March 20,
         1984.)
  2.   Personal  communication with Mr.  Helmut'Diekmann  and Mr. Chris Czoch,
       Lurgi Corp., River Edge,  NJ, February  24, February 28, and March  5,
         1984.  (Documented  by letter dated March  6, 1984.)
  3.   Personal  communication with Mr.  Richard  Warner,  Ralph M. Parsons  co.,
       Pasadena, CA, March 1, 1984.  (Documented by letter dated March 2, 1984.)
  4.   Vatavuk,  William M. and Neveril, Robert  B., "Part II:  Factors for
       Estimating Capital  and Operating Costs," Chemical Engineering,
       November  3, 1980.
  5.   U.S. Department of Commerce, Bureau of Labor Statistics, Monthly  Labor
       Review, May 1984.
  6.   "Chemical Water", Chemical  Week, February 22, 1984.

  7.   Riedel, R.W., et al., "Alternatives in Sulfuric  Acid  Plant Design",
       Chemical  Engineering Progress, March,  1977.
  8.   Peters, M.S., and Timmerhaus,  K.D. Plant Design and  Economics for
       Chemical  Engineers.  Third  Edition McGraw-Hill,  New York, NY.  1980.
  9.   Drabkin,  Marvin, and Brooks, Kathryn J., A  Review of  Standards of
       Performance for New Stationary Sources — Sulfuric Acid Plants,
       EPA Contract No. 68-07-2526, January 1979.    '

 10.   Chemical  Marketing Reporter, Schnell Publishing  Co.,  New York, NY,
       August 13, 1984.
 11.   Collins,  J.J., et al., "The Purasiv Process for  Removing Acid Plant
       Tail Gas", Chemical Engineering  Progress, June  1974.
 12.   Final Guideline Document:  Control of  Sulfuric Acid Mist Emissions
       from Existing Sulfuric Acid Production Units, U.S. Environmental
       Protection Agency, Office of Air Quality Planning and Standards,
       September 1977.
 13.   Friedman, Leonard J., "Sulfuric  Acid Energy Design for the 80's",
       Chemical  Engineering Progress, February, 1982.
 14.   Personal  communication with Mr.  Al Giovanetti,  Davy-McKee Corp.,
       Lakeland, FL, February 23 and  March 22,  1984.   (Documented by letter
         dated March 23, 1984.)

 15.   Mathews,  J.C., et al., So2 Control Processes for Non-Ferrous
       Smelters, EPA Contract No.  68-02-1491, January  1976.
 16.   Personal  communication with Mr.  Ronald Buck, E.  I. duPont de  Nemours
       and Company, Inc., Wilmington, DE, August  21,  1984.
 17.   Personal  communication with Mr. James  McGeoch,  Lear-Siegler,  Inc.,
       Havertown, PA, August 21, 1984.
 18.   Personal  communication with Mr. Paul  Fabian, York  Separators,  Fair-
       field, NJ, March 22, 1984.  (Documented  by  letter dated  March 22,
       1984.)


                                     6-28

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TECHiNICAL REPORT DATA
(Please read Instructions on the reverse before completing;
1 REPORT NO. 2. |3. RECIPI E— S ACCESSION NO.
EPA-450/3-85-012
4. TITLE AND SUBTITLE
Review of New Source Performance Standards for
Sulfuric Acid Plants
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
DAA for Air Quality Planning and Standards
Office of Air and Radiation
U. S. Environmental Protection Agency
RTP, N.C. 27711
5. REPC "-, " DATE
Marrh 1QR5
6. PE-rORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT N
FlO. PROGRAM ELEMENT NO.
11 CONTRACT/GRANT NO.
13. TYPE OF REPORT AND PERIOD COVERE
14. SPONSORING AGENCY CODE
EPA 200/04
15. SUPPLEMENTARY NOTES ' 	 • 	 • 	 ' 	
     This report reviews  the current New  Source Performance  Standards for Sulfuric  Acid
     Plants.  It includes a summary of the  current standards,  the  status of current
     applicable control technology, and the ability of plants  to meet the current
     standards.
                                 KEY WORDS AND DOCUMENT ANALYSIS
                   DESCRIPTORS
                                               b.IDENTIFIERS/OPEN ENDED TERMS
    Air Pollution
    Sulfuric  Acid  Plants
]    Sulfur Oxides
I    Standards of Performance
j    Pollution Control
                                                                           t. COSATI Held/Group
  Air Pollution  Control
     13B
    Release Unlimited
19. StC'JRiTC CLASS (ThisReoof',

    Unclassified

5PA >=„,„, 2220-1 (Rev. a_77)
                              SCI~!CN 'S OBSOLETE
                                               20 SEC'JRITV CLASS  This ,-;aeeI

                                              I	ynclaos-i-£»6d	
; 21 NO. OF PAGES
i     93
                           ; P 2 PRICE

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