EPA-450/3-88-015
Characterization and Control
  of Radionuclide Emissions
       From Elemental
   Phosphorus Production
         Emissions Standards Division
         U.S. Environmental Protect
     U.S. ENVIRONMENTAL PROTECTION AGENCY
         Office of Air and Radiation
      Office of Air Quality Planning and Standards
      Research Triangle Park, North Carolina 27711
           February 1989

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This report has been reviewed by the Enission Standards Division of the Office of Air Quality Planning and
Standards,  EPA,  and approved for publication.  Mention of trade names  or comercial products  is not intended
to constitute endorserent or recomendation for use.   Copies of this report are available  through the Library
Services Office (HD-35), U.S. Environnental Protection Agency,  Research  Triangle  Park, North  Carolina 27711,
or fron National Technical Infornation Services, 5285 Port Royal Road, Springfield, Virginia 22161.

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                                  PREFACE

     Midwest  Research Institute  (MRI)  prepared  this  report  for the U.  S.
 Environmental  Protection  Agency, Office  of Air  Quality  Planning and
 Standards on  Contract No.  68-02-4379,  Work Assignment 12, Ms.  Elizabeth
 Grainger and  Mr.  Lee  Beck  served as technical project monitors.
     The report was prepared by Mr. Dennis Wallace,  Ms. Katy Allen,  and
 Mr. Jim Obremski  in MRI's  Environmental  Engineering  Department.  Mr. Mark
 Turner, Mr. Butch Smith, and Ms. Carol Athey provided valuable  comments
 and other members of  the Environmental Engineering Department contributed
 to specific portions  of the report.
 Approved for:
 MIDWEST RESEARCH INSTITUTE

                        j
                        tr-
 Roy Neulicht, Program Manager
 Environmental Engineering Department
December 12, 1988
                                   11

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                             TABLE  OF  CONTENTS
 LIST OF FIGURES	  iv

 LIST OF TABLES	  v


 SECTION 1.0  INTRODUCTION	  1-1

 SECTION 2.0  ELEMENTAL PHOSPHORUS INDUSTRY DESCRIPTION	  2-1
              2.1  INDUSTRY  CHARACTERIZATION	  2-1
              2.2  ELEMENTAL PHOSPHORUS PRODUCTION PROCESSES	  2-5
                   2.2.1  Process  Description	  2-5
                   2.2.2  Radionuclide Distributions	  2-10
              2.3  REFERENCES FOR  SECTION  2	  2-14

 SECTION 3.0  EMISSIONS FROM ELEMENTAL PHOSPHORUS PLANTS	  3-1
              3.1  SOURCES OF RADIONUCLIDE EMISSIONS	  3-1
              3.2  KILN EMISSION CHARACTERIZATION	  3-9
                   3.2.1  Mass Emission Rates of  Po-210, Pb-210
                            and PM	  3-9
                   3.2.2  Acid Gas Emissions	  3-17
                   3.2.3  Po-210 and  Pb-210 Particle Size
                            Distributions	  3-17
              3.3  KILN BASELINE EMISSIONS	  3-21
              3.4  REFERENCES FOR  SECTION  3	  3-23

 SECTION 4.0  EMISSION  CONTROLS	  4-1
              4.1  DESCRIPTION  OF  APPLICABLE CONTROL SYSTEMS	  4-2
                   4.1.1  Spray Towers	  4-2
                   4.1.2  Venturi  Scrubbers	  4-6
                   4.1.3  Wet ESP's	  4-10
                   4.1.4  SD/FF Systems	  4-17
                   4.1.5  HEPA  Filters	  4-23
              4.2  PERFORMANCE  OF  ALTERNATIVE  CONTROL TECHNOLOGIES...  4-29
                   4.2.1   Venturi  Scrubbers	   4-30
                   4.2.2   Wet  ESP's	   4-35
                   4.2.3   SD/FF Systems	   4-38
                   4.2.4   HEPA  Filters	   4-41
              4.3   COST  OF CONTROL TECHNOLOGIES	   4-41
                   4.3.1  Venturi Scrubber  Cost Assumptions	   4-44
                   4.3.2  Wet ESP Cost Assumptions	   4-44
                   4.3.3  SD/FF Cost Assumptions	   4-44
                   4.3.4  HEPA Filter Cost Assumptions	   4-45
              4.4   REFERENCES FOR SECTION 4	   4-47

SECTION 5.0   CONTROL ALTERNATIVE PERFORMANCE AND COST	   5-1
              5.1  DEFINITION OF CONTROL ALTERNATIVES	   5-1
              5.2  PERFORMANCE OF CONTROL ALTERNATIVES	   5-3
              5.3  COSTS OF CONTROL ALTERNATIVES	   5-12
              5.4  REFERENCES FOR SECTION 5	  5-29

APPENDICES A-E:  SEPARATE CBI VOLUME
                                    iii

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                              LIST OF FIGURES
Figure 2-1.
Figure 3-1.
Figure 3-2.
Figure 3-3.
Figure 4-1.
Figure 4-2.
Figure 4-3.
Figure 4-4.
Figure 4-5.
Figure 4-6.
Figure 4-7.
Figure 4-8.
Figure 4-9.
Figure 4-10.
Figure 4-11.
Figure 5-1.
Figure 5-2.
                                                         Page
General  elemental  phosphorous  plant process flow ......  2-7
Vapor pressure  curves for  Po and  Pb ...................  3-4
Summary  of  Po-210  emission data .......................  3-13
Summary  of  Pb-210  emission data .......................  3-14
Countercurrent  flow  spray  tower .......................  4-3
Venturi  scrubber ......................................  4-7
Wetted-throat venturi scrubber ........................  4-8
Adjustable-throat  venturi  scrubber ....................  4-9
Illustration of ESP  operating  principles ..............  4-12
Circular-plate  type  wet ESP ...........................  4-14
Flat-plate  type wet  ESP ...............................  4-15
Spray dryer/fabric filter  system ......................  4-18
Pulse- jet fabric filter ..................... . .........  4-21
The HEPA filter performance curve .....................  4-25
Examples of HEPA filter systems .......................  4-27
Capital costs of control alternatives .................  5-17
Annual 1 zed costs of  control alternatives ..............  5-18

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                               LIST OF TABLES


 TABLE 2-1.   PRODUCTION  OF ELEMENTAL PHOSHPORUS 1967-1987	  2-3

 TABLE 2-2.   USERS OF ELEMENTAL PHOSPHORUS BY-PRODUCT SLAG	  2-4

 TABLE 2-3.   OPERATING ELEMENTAL PHOSPHORUS PLANTS,  1988	  2-6

 TABLE 2-4.   Po-210 CONCENTRATIONS  IN ELEMENTAL PHOSPHORUS PROCESS
               STREAMS	  2-12

 TABLE 2-5.   Pb-210 CONCENTRATIONS  IN ELEMENTAL PHOSPHORUS PROCESS
               STREAMS	  2-13

 TABLE 3-1.   RADIONUCLIDE  EMISSIONS  FROM  ELEMENTAL PHOSPHORUS
               OPERATIONS	.-	  3-2

 TABLE 3-2.   NODULE COOLER EMISSION  ESTIMATES	  3-6

 TABLE 3-3.   SUMMARY OF  TEST CONDITIONS	  3-10

 TABLE 3-4.   CALCINER PM EMISSION DATA	  3-11

 TABLE 3-5.   CALCINER RADIONUCLIDE EMISSION DATA	  3-12

 TABLE 3-6.   ACID  GAS EMISSION  LEVELS	  3-18

 TABLE 3-7.   PARTICLE SIZE  DISTRIBUTION BASED ON IMPACTOR  SAMPLES	  3-19

 TABLE 3-8    PARTICLE SIZE  DISTRIBUTION BASED ON SASS CYCLONE
               SAMPLES	   3-20

 TABLE  3-9.   BASELINE  Po-210 AND Pb-210 EMISSIONS	   3-22

 TABLE  4-1.   ESTIMATED EFFICIENCY OF MONSANTO SCRUBBER	   4-34

 TABLE  4-2.   ESTIMATES OF VENTURI SCRUBBER  PERFORMANCE	   4-36

 TABLE  4-3.   SUMMARY OF ESP EFFICIENCY CALCULATIONS	   4-39

 TABLE  4-4.  ASSUMPTIONS  USED IN ESTIMATING DIRECT AND INDIRECT
               COSTS	   4-43

TABLE  5-1.  PARTICLE SIZE  DISTRIBUTIONS FOR  Po-210 and Pb-210	   5-5

TABLE 5-2.  ESTIMATED FRACTIONAL EFFICIENCIES FOR VENTURI SCRUBBER
              CONTROL ALTERNATIVES	   5-6

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                        LIST OF TABLES  (continued)
                                                                       Page

TABLE 5-3.   ESTIMATED FRACTIONAL EFFICIENCIES FOR WET ESP CONTROL
               ALTERNATIVES	   5-7

TABLE 5-4.   ESTIMATED PERFORMANCE FOR VENTURI SCRUBBER OPTIONS	   5-9

TABLE 5-5.   ESTIMATED Po-210 EMISSION LEVELS ACHIEVED BY CONTROL
               ALTERNATIVES	   5-10

TABLE 5-6.   ESTIMATED Pb-210 EMISSION LEVELS ACHIEVED BY CONTROL
               ALTERNATIVES	   5-11

TABLE 5-7.   REDUCTION OF Po-210 EMISSIONS FROM BASELINE	   5-12

TABLE 5-8.   REDUCTION OF Pb-210 EMISSIONS FROM BASELINE	   5-13

TABLE 5-9.   CAPITAL COST OF CONTROL ALTERNATIVES	   5-15


TABLE 5-10.  ANNUALIZED COST OF CONTROL ALTERNATIVES	   5-16

TABLE 5-11.  SUMMARY OF COSTS FOR VENTURI SCRUBBER—10 INCH
               PRESSURE DROP	   5-19

TABLE 5-12.  SUMMARY OF COSTS FOR VENTURI SCRUBBER--25 INCH
               PRESSURE DROP	   5-20

TABLE 5-13.  SUMMARY OF COSTS FOR VENTURI SCRUBBER—40 INCH
               PRESSURE DROP	   5-21

TABLE 5-14.  SUMMARY OF COSTS FOR VENTURI SCRUBBER—80 INCH
               PRESSURE DROP	   5-22

TABLE 5-15.  SUMMARY OF COSTS FOR WET WALLS ELECTROSTATIC/
               PRECIPITATOR—200 SCA	   5-23

TABLE 5-16.  SUMMARY OF COSTS FOR WET WALLS ELECTROSTATIC/
               PRECIPITATOR—400 SCA	   5-24

TABLE 5-17.  SUMMARY OF COSTS FOR WET WALLS ELECTROSTATIC/
               PRECIPITATOR—600 SCA	   5-25

TABLE 5-18.  SUMMARY OF COSTS FOR WET WALLS ELECTROSTATIC/
               PRECIPITATOR—800 SCA	   5-26

TABLE 5-19.  SUMMARY OF COSTS FOR SPRAY DRYER/FABRIC FILTER	   5-27

TABLE 5-20.  SUMMARY OF COSTS FOR HEPA FILTRATION SYSTEM	   5-28

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                               1.0   INTRODUCTION

       The  U.  S.  Environmental  Protection Agency's (EPA's) Office of
  Radiation Programs (ORP) is developing a National Emission Standard for
  Hazardous Air Pollutants (NESHAP)  under the authority of Section 112 of
  the Clean Air Act  for radionuclide emissions from elemental phosphorus
  production facilities.   Background information on the elemental  phosphorus
  production processes,  radionuclide emissions from these processes,
  availability  of control  techniques that could reduce these emissions,  and
  the performance and costs  of  alternative control  techniques is needed  to
  support that  regulatory  development effort.   The  ORP will  use that •
  background information to  define regulatory  alternatives and to  evaluate
  the emission  reductions, risk levels,  and costs associated  with  each of
  the regulatory alternatives.
      This report presents  the results of a study  conducted  by the
  Industrial Studies Branch  (ISB) in EPA's Office of Air Quality Planning
 and Standards (OAQPS) that was designed to collect the background
 information.   The specific objectives of the study were to  identify the
 sources of radionuclide emissions,  particularly polonium-210 (Po-210) and
 lead-210 (Pb-210),  from elemental  phosphorus production; to determine
 baseline emissions  levels of Po-210 and Pb-210 for the key  emission
 sources at each  operating elemental phosphorus plant; to identify feasible
 control  alternatives;  and to estimate  the performance and cost of those
 control  alternatives.   Although  all potential sources of Po-210 and Pb-210
 from elemental phosphorus production were considered, this  study  focused
 on Po-210  and  Pb-210 emissions from the calcining  (or nodulizing
 operations) because previous studies indicated  that those operations are
 the primary sources of radionuclide emissions from the process.
 Consequently,  this report deals primarily with  the characterization and
 control of  Po-210 and Pb-210 emissions from nodulizing calciners or kilns,
 but other sources of emissions are addressed  briefly.
     The objectives identified above were addressed through  three  primary
data gathering and analysis tasks.   First, all emission data generated by
EPA and elemental phosphorus facilities over the past 10 years were
compiled and analyzed.   As a consequence of these analyses,  data gaps  were
                                   1-1

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 Identified, and an emission test program that addressed those gaps was
 conducted concurrently with this study.  The results of that test program
 are included in this report.  Second, plant visits were conducted at  each
 of the five operating facilities to collect data on process and control
 system operations, process residuals and emissions, and control system
 performance and cost.  Finally, additional information on control system
 performance and costs was obtained through a literature review, contact
 with knowledgeable EPA personnel, and telephone contacts with control
 equipment vendors.
      The results of this  study are presented in the four sections which
 follow.   Section 2 contains a  description  of the elemental  phosphorus
 industry.   It  describes the elemental  phosphorus production process  and
 presents data  on the  distribution of  radionuclides  in process streams and
 residues.   Section 3  discusses emissions from the elemental  phosphorus
 production  process.   Sources of radionuclide emissions  are  identified, and
 estimates of Po-210 and Pb-210 emissions from the different  sources are
 presented.  Detailed  information  on Po-210, Pb-210, part-leu late matter
 (PM), and acid gas emissions from the calcining/nodulizing operation  is
 presented, and baseline estimates of PM and radionuclide emissions from
 those operations are developed for each operating facility.  Section 4
 addresses control of calciner/nodulizing kiln radionuclide emissions.
 Potential control techniques are described, and procedures for estimating
 the performance and cost of these techniques are presented.   Specific
 control alternatives for calciner operations are defined in Section 5, and
 estimates of the performance and costs of these  alternatives are
developed.
                                   1-2

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                 2.0   ELEMENTAL  PHOSPHORUS  INDUSTRY  DESCRIPTION

       Phosphate rock is the basic raw material used in the production of
  phosphorus and phosphorus products.  About 10 percent of the phosphate
  rock mined in the U.S. is used in the production of elemental phosphorus,
  which is produced by a high-temperature reduction process.  Environmental
  releases associated with the elemental  phosphorus process include air
  emissions of criteria pollutants  such as  particulate  matter (PM) and
  sulfur dioxide (S02) as  well  as the acid  gas  hydrogen fluoride (HF),
  liquid effluent streams  that  have low pH  and  contain  radionuclide
  materials,  and large quantities of  slag materials  that must  be stored  or
  disposed as solid waste.  The  primary concern of this study  is  the
  potential for  emission of two  radionuclide daughters of uranium-238
  (U-238)~polonium-210 (Po-210) and  lead-210 (Pb-210)-during  the  high-
  temperature operations.
      This section briefly describes the elemental phosphorus  industry and
  the elemental phosphorus production processes as a background for under-
  standing radionuclide emission problems  and control alternatives.  The
 discussion  is divided into two subsections.   The first provides an overall
 description of the industry and identifies operating plants and their
 capacities.   The second describes  the elemental  phosphorus  production
 process, identifies  production  and waste streams,  and  presents the distri-
 bution of Po-210 and Pb-210  among  those  streams.
 2.1   INDUSTRY  CHARACTERIZATION
      Elemental  phosphorus  is produced  from the reaction of phosphate  ore
 with  silica  and  carbon (coke) in a high-temperature electric furnace.  The
 key raw  material with respect to both  the product and radionuclide
 emissions  is the phosphate ore.  Phosphate ore deposits are located
 principally  in three regions of the United  States:
     1.  Southeastern region (mainly Florida,  but also  South Carolina,
 North Carolina, and Georgia);
     2.  Northern Rocky Mountain region (eastern  Idaho, western Wyoming,
northern Utah,  and southwestern  Montana); and
     3.  Middle Tennessee.
                                   2-1

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      Most of the phosphate rock used in this country's phosphate rock and
 phosphate fertilizer industries is taken from Florida reserves, but most
 of the ore used in elemental phosphorus production is obtained from the
 Tennessee and Rocky Mountain regions.   The phosphate ores from the three
 principal regions are distinct in their radiological characteristics.
 Generally, ores from the southeastern  region have the highest radionuclide
 concentrations, followed respectively  by those from the northern Rocky
 Mountain region and those from middle  Tennessee.   The radioactivity
 content of phosphate rocks from different deposits within the same general
 region, however,  may vary widely.   Details on the radioactivity levels of
 the ores used at  operating elemental phosphorus plants  are presented in
 Section 2.2.
      The principal  products of the  elemental  phosphorus  industry are
 elemental  phosphorus and  two by-products  associated  with  Its  production-
 calcium silicate  slag and  ferrophosphorus  (FeP).   The production rates of
 elemental  phosphorus for  the years  1967 through 1987 are  shown  in
 Table 2-1.    Typically, calcium  silicate  slag  is  produced  at  a  rate  of 8
 to  9  Mg per Mg  of elemental  phosphorus produced,  and ferrophosphorus  is
 produced at a rate of 0.1  to  0.3 Mg per Mg of elemental phosphorus
 produced.
      Elemental  phosphorus  is  used primarily in the manufacture of high-
 grade phosphoric acid, which  serves as  a feedstock in the production of
 chemicals and food products.   In 1986,  50 percent of the supply was used
 to  produce sodium tripolyphosphate, and small quantities (about 20,000 Mg)
 were  exported.3  End uses include detergents, metal treatment, foods and
 beverages, and chemicals.
      Historically, the calcium silicate slag produced in this  process has
 been  used as an aggregate material.   Some of the uses of this  material are
 given  in Table 2-2.2  However, as outlined in Section 2.2.2.,  this slag
may contain Po-210 and Pb-210, and it has  been demonstrated to contain
U-238.  Consequently, concerns have  been raised about use  of the
material.  Information collected from plant visits during  this study
 indicates that most  slag  currently is being stockpiled at  plant  sites.
     The other major by-product is ferrophosphorus.   Plant  contacts
indicated that the market  for this product  is  limited, but  some  is  sold in
                                   2-2

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   TABLE 2-1.  PRODUCTION OF  ELEMENTAL  PHOSPHORUS 1967-1987l

 Yaay.            Production,                       Production,
 Year	Hg  (tons)	Year            Mg (tons)


 1987        312,117 (343,329)     1975       408,642 (449,506)

 1986        330,652 (363,717)     1974       476,523 (524,175)

 1985        326,582 (359,196)     1973       477,748 (525,523)

 1984        350,966 (386,063)     1972       490,990 (540,089)

 1983        332,772  (366,050)     1971        495,535 (545,089)

 1982        328,354  (361,189)     1970        542,323 (596,555)

 1981        387,334  (426,067)      1969        566,347 (622,982)

 1980        392,482  (431,730)      1968        557,585 (613,343)

 1979         417,765  (459,541)      1967        533,642 (587,006)

 1978         401,158  (441,274)

-1977        391,174  (430,291)

1976        396,959  (436,655)
                            2-3

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   TABLE 2-2.  USES OF ELEMENTAL PHOSPHORUS BY-PRODUCT SLAG2
 Neutralizer for acidic soils
 Road  ballast
 Manufacture of  Portland  cement
 Manufacture of  slag concrete blocks
 Slag wool as thermal  insulation
 Ceramic bodies  and  glazes
 Railroad ballast  and  roadbeds
 Fill for septic tank  drainage fields
 Roadway, substation,  and soil stabilization at commercial
  facilities and  utility installations
Municipal sewage  plant filter beds
Aggregate for parking lot and driveway paving
Built-up roofing  aggregate
                             2-4

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   specialty markets such  as  specialty steels, cast  alloys,  and  paint
   pigments.  One plant sells the ferrophosphorus to  a  plant that  processes
   it to recover vanadium.
       In 1980, eight elemental phosphorus plants were operating  in  the
   U.S.  However, since that time, the two Florida plants, Mobil in Pierce
   and Stauffer in Tarpon Springs, have shut down as a result of high
  electrical  costs in that State.  Recently,  Monsanto dismantled  its
  facility in Columbia,  Tennessee.   Consequently,  only five plants currently
  are operating, and this number is not  expected to increase in the
  foreseeable future.  Table 2-3 identifies the  five operating plants and
  presents estimates of  their operating  capacities  for phosphorus  production
  and of  the  quantity  of  phosphate  ore that would be  required to produce
  this  capacity.  The  estimates  are  based on quantities published  by  EPA  in
  1983.    During plant visits performed during July and August 1988,
  industry personnel indicated that  capacities had not  changed since  1983.
  They also indicated  that production rates vary from 50 to  100  percent of
  capacity depending upon market demand.
  2.2  ELEMENTAL PHOSPHORUS PRODUCTION PROCESSES
  2.2.1  Process Description
      Elemental phosphorus is produced by a thermal process that uses
  silica as a  fluxing agent for  the  calcium  present  in phosphate  feed  ore.
 Phosphate is reacted  with silica and  coke  in  a  reducing  atmosphere to form
 elemental phosphorus  (PJ,  CO,  and calcium silicate  slag.   In addition,
 by-product FeP is  formed from the  reaction of elemental  phosphorus with
 coke and  iron  oxide.  Simplified equations for  the process  are:2

       4 Ca5F(POJ3+18 Si02+30 C *  18 CaO-SiO^l/9 CaF2+30 CO++3P^     (l)
           (ore)                       (slag)
              2 P205+10 C * 10 COt+P^t (intermediate reaction)
(2)
                       2 Fe203+6C+Pu * 4 FeP+6 CO*                     (3\
     Figure 2-1  presents a simplified  process  flow diagram  that generally
represents the process  used at  the  five operating  plants.   The  paragraphs
                                   2-5

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          TABLE  2-3.  OPERATING  ELEMENTAL PHOSPHORUS  PLANTS,  1988
Plant

FMC Corporation, Pocatello, Idaho
Monsanto Co., Soda Springs, Idaho
Stauffer Chemical Co., Silver Bow,
MM..*
Phosphorus
capacity,
10 Mg/yr
(10 tons/yr)
123 (135)
95 (105)
38 (42)
Ore
requirements,
10 Mg/yr
(10 tons/yr)
1,470 (1,620)
1,000 (1,100)
380 (420)
Stauffer Chemical Co., Mt. Pleasant,
  Tenn.

Occidental Chemical Co., Columbia,
  Tenn.
41 (45)


45 (50)
440 (480)



490 (540)
                                   2-6

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ro
I
                                                                             CO FROM
                                                                             FURNACE
  TO SCRUBBER
               ELECTRICAL
               POWER
               TO
               TAPHOLE ^
               FUME   ~" A
               SCRUBBER  ^~
                                                   FEED
                                               PROPORTIONING
                                                   AREA
                                                                                               COKE   )„ COKE
                                                                                             STORAGE  r*™ SUPPLY
                        SlAO   FEP
                         TAP   TAP
	     	TT

>RAGE[~K^ANKCAH)
          tAj    DO
                                                                        H2O, RESIDUE
                               Figure 2-1.   General  elemental phosphorus plant process flow.

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  below describe  the major  components of this process  and  identify points in
  the process where operations differ significantly  among  the  plants.
      Phosphate  ore is mined offsite and is shipped by  rail or  truck  to
  each of the five plants for processing.  The three western plants  receive
  their ore from  Idaho mines that operate about 7 months per year.   These
  plants stockpile large amounts of ore during the summer months to  continue
  process operations during the winter months.  The  two Tennessee  plants
  receive ore from Tennessee mines 12 months per year.  At each of the
  plants, the ore is stockpiled and then processed before it is fed  to the
  calciner.  The specific processing steps  vary depending upon the ore
  characteristics and calciner operations as described below.
      At FMC, the ore is screened  to remove oversized material,  which is
  sent to an ore crusher for processing.  The screened material and fines
 generated by the process are formed into  briquettes by briquette
 presses.   The briquettes are screened,  and  the  fines  are  recycled to the
 briquetting process.   The  briquettes are  then used  as feed to the
 calciner.
     At the other four plants, as-received  ore  is blended with  recycled
 fines to  form the feed to  the calciner.  The principal  difference in  the
 facilities  is  that the Tennessee plants use an ore  that has been  washed.
 Consequently,  the moisture content of the calciner  feed is higher at  these
 plants than  at the western plants.
     The prepared phosphate ore blend is fed to one of two types  of
 "calciners'—a traveling-grate calciner (FMC only) or a rotary kiln.  The
 objective of the calcining process is to remove moisture from the ore,
 combust any volatile constituents in the ore, and produce a feedstock for
 the electric furnace that is physically stable and appropriately sized.
 In the traveling-grate calciner,  the preformed briquettes  are placed in
 pallets to a fixed depth.  The pallets  move through  the calciner,  and the
 briquettes are heated to a temperature  of  about  1300°C (2400°F)  by
 overfire burners that are fueled  by CO  or  natural  gas.  An induced draft
 fan pulls  the combustion gases  downward  through  the  bed.   In  the rotary
 kiln, the  phosphate ore blend is fed continuously  to the upper end of  the
 kiln.  As  the ore moves through the kiln, moisture and volatiles are
driven  off,  and the remaining material  is heated to  a  temperature  of about
                                   2-8

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  1300°C (2400°F)  by  combustion gases that flow through the kiln counter-
  current to  the ore.  At  those temperatures,  the ore is heated to its
  incipient melting point,  and  the  tumbling action of the kiln agglomerates
  the  material  into larger  nodules.   Typically,  the kilns have a solids
  residence time of about 4 h.   The  kilns  are  fueled by a combination of CO,
  coal,  and natural gas.
      Both types of calciners  generate  large  quantities of high-temperature
  combustion gases.  Volumetric flows  for  the  calciners  currently operating
 .range  from about 3,700 to  11,000 m3/min  (130,000  to 400,000  acfm)  at
  temperatures  in the range  of  320° to 430°C (600°  to 800°F).   Two of the
  five plants use a waste heat  boiler for energy recovery.   The gases from
  the kiln or boiler are treated in an air pollution control system before
  they are discharged to the atmosphere.  The air pollution  control systems
  for the five plants are described in Section 4.  Details on the combustion
 gas characteristics and kiln operating rates are presented in Appendices A
 through E.
      The nodules  or briquettes that leave the calciner are air cooled and
 subjected to crushing  and  sizing  operations.   Materials that are
 approximately 1.5 to 2.5  cm (0.6  to 1.0 in.)  in diameter are sent to the
 feed  proportioning area for the electric  furnace.   Undersized material is
 recycled to  the ore  blending area  and subsequently through the calciner.
      The nodulized or briquetted phosphate feed material  is sent to  a
 proportioning  area where it is mixed  with  sized coke and  silica to obtain
 the required weight proportion of furnace  feed  (burden).   A proper ratio
 of  S102 to CaO is required  to  form slag with the necessary  flow properties
 to  facilitate removal from  the  furnace.  Coke is added  as  a carbon source
 to  reduce the  intermediate  reaction product P205 to elemental
 phosphorus.  This proportioned furnace feed burden is conveyed  to the
 furnace  burden bins.
     The electric furnace is a large chamber lined with carbon blocks  in
 the lower section.  Three  consumable carbon electrodes  extend through the
 roof to conduct the electric current.  An  electric arc  is formed between
 the electrodes and the  furnace  lining.  The burden material is gravity fed
continuously  to the  top  of  the  furnace from where  it progresses downward
until  it is heated and  eventually melts  in the  intense  heat of the
                                   2-9

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  electric  arc.   At  the heat  source,  the maximum temperature can reach
  4400'C  (7950'F).   At  1400°  to  1800'C  (2550°  to 3270«F),  silica becomes a
  strong  acid that reacts with the  calcium phosphate to yield a calcium
  silicate  slag and  P205.  The P205 in  turn reacts  with the carbon in the
  coke and  is reduced to CO and  Pu.2
      The elemental phosphorus is driven off as a vapor  in  the  CO  off-gas
 stream.  The slag and ferrophosphorus continually collect  in the  bottom of
 the furnace in molten layers with the denser ferrophosphorus layer  below
 the slag layer.  Periodically, these molten by-products are tapped
 separately.  Slag is tapped approximately once each hour and
 ferrophosphorus up to several times each day.   The slag and
 ferrophosphorus are air cooled in a pit and stockpiled for later use.
      At three of the five facilities, the furnace product gases are
 treated for dust removal  in an electrostatic precipitator (ESP).  At the
 other two facilities, the gas stream is routed  directly to the  phosphorus
 recovery processes.   The  gas stream from the ESP,  or from the furnace at
 those plants that do  not  have an  ESP,  are  sent  to water  spray condensers
 where the gases are cooled  and the  phosphorus is condensed  to a liquid.
 The condensed phosphorus  is  collected  under  water, purified by  filtering,
 and then pumped to underwater storage. The gas  stream  from  the  condenser
 is primarily CO.  Essentially all of the phosphorus-free CO  is  recycled to
 fuel  the nodulization process.  The remaining CO is recycled to  other
 plant operations  or exhausted  through  flare stacks.  Plant personnel
 indicated that  CO is flared only on days when the kiln is not operating.
 2.2.2  Radionuclide Distributions
     The primary objective of this study is to  evaluate Po-210 and Pb-210
 emissions from elemental phosphorus plants (particularly from the
 nodulizing kiln or calciner) and to develop alternatives for the control
 of these emissions.  Consequently, the distribution of Po-210 and Pb-210
 among the different process streams is of interest.   The paragraphs below
 summarize the information  that has been collected  on  these distribu-
 tions.  This information is  based  on comprehensive  studies of elemental
 phosphorus production  conducted for EPA prior to 1983,  test  data developed
by EPA in 1983 and 1984, and  data  supplied  by the plants  during  earlier
EPA studies  and  during site  visits  conducted  for this study.
                                   2-10

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       Both Po-210 and Pb-210 are volatile metals.  As such, it is quite
  likely that they will  be volatilized in the calciner and leave the
  calciner with the combustion gas  stream.   However, data from the five
  operating facilities indicate that  at  least some of the Po-210 and Pb-210
  remains  in the nodules that  are fed  to  the electric furnace.   Plant
  environmental  personnel  and  industry research  personnel  contacted  during
  this  study all  agreed that any Po-210 and  Pb-210 that does reach the
  electric  furnace would be volatilized and  returned  to the kiln with the
  CO.  Available  data generally support this conclusion, but limited data
  from the  EPA facility studies indicate that some  Po-210 and Pb-210 is
  deposited  in the slag.2  However,  these data should be viewed with caution
  because slag streams are  difficult to sample and analyze and because
 Po-210 and Pb-210 concentrations in  the slag depend on the age of the
 slag.   This age dependence results from decay of other radiouclides that
 are known to be present in the slag.
     Tables 2-4 and 2-5 summarize  available data on Po-210  and Pb-210  in
 elemental  phosphorus  streams.   These  data  generally suggest that  most
 Po-210 and Pb-210  concentrates  in  the kiln  exhaust stream, but they do  not
 demonstrate conclusively  that  this stream  is the  only pathway  for these
 constituents.   In particular, they indicate that  significant quantities of
 Po-210  and Pb-210 remain  in the slag in some cases.  During plant visits,
 plant personnel  indicated  that these  levels appear to overestimate the
 quantities  of radionuclides in the slag.  Monsanto research personnel
 indicated  that slag sampling was difficult, and accurate  values could not
be obtained.    However, they estimate that Po-210 concentrations  in the
slag are about 5 to 10 pCi/g.
                                  2-11

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 TABLE  2-4.   Po-210  CONCENTRATIONS  IN ELEMENTAL  PHOSPHORUS PROCESS STREAMS
 Process stream
   FMC,Monsanto,
 Idaho     Idaho
                                           Po-210 concentrations, pCi/q
                                                stauffer           occidental,
                                                         Tenn.
                                                Tenn.
                                          Monsanto,
                                             Tenn.
 Ore
       n
    21 9
    23J
                                 1261
36C
40'
                                                         3.5°
                                                                                      4.11
 Nodu I es



 Slag


 Ferrophosphorus

 Inlet  PM



 Stack  PM
  <2.6a       1.9b
     8i
   9.8J

   <16a   -
  <0.6a

 2,5009    1,920"
 2,600?
 4,400*

19,0009   37,000b
25,000!"    5,000"
53,000*   35,000"
               0.091
<2° (fresh)     0.4d
2.7C (piled)
<1.9C

3,400'
37,000'
0.05C
                                            3.3T
                                                                  <0.8T
1.0r
                                                                   1,200°
^Based on EPA test data collected in 1977 as presented  in  Reference  4.                     "
 Based on EPA test data collected in 1984 as presented  in  Reference  5;  includes  combined ore
 dnd pocycIo f6oo«
 Based on EPA test data collected in 1982 as presented  in  Reference  6.
gBased on data supplied to EPA by facility as presented  in Reference 2.
 Data presented in Reference 2.  Concentrations assumed  to be equal  to thosse measured at the
 Monsanto, Tennessee, facility in 1982 as presented  in Reference 7.
 Based on EPA test data collected in 1982 as presented  in  Reference  7.
*Based on test data collected by EPA in 1984 as presented  in Reference 8.
.Based on EPA test data collected in 1988 as presented  in  Reference  9.
 Based on test data collected by EPA in 1984 as presented  in Reference 10
J8ased on data supplied to MR I  by facility during 1988 site visit and reported in
 Reference 11.  Nodule estimates based on average of three measurements made through bed-
kvalues ranged from 5.8 to 14.9.
jBased on EPA test data collected in 1988 as presented in Reference  12.
 Based on data supplied to MRI  by facility during 1988 plant visit as reported in
 Reference 13.
mBased on emission test data  collected  by the faciIity in  1985 through 1987 as reported in
 Reference 11.
"Based on emission test data  collected  by the facility in  1988 as reported in Reference 14
 Based on data supplied to MRI  by the  facility during 1988 plant visit as reported in
 Reference 15.
                                          2-12

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ro
i
Nodules



Slag




Ferrophosphorus


Inlet PM



Stack PM
                              18
                       1.1*


                        339

                       180k


                       2409

                       710k
                                    5.6
9.700^

8.200"
                                                
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 2.3  REFERENCES FOR SECTION 2

  1.  Bureau of Census,  U.  S. Department of Commerce.  Current Industrial
      Reports:   Inorganic Chemicals.  Washington, D.C.  1968-1987.

  2.  Stula, R. T.,  R.  E. Balanger, C. L. Clary,  R. F. May, M. E. Spaeth,
      and J. P. Swenson.   Airborne Emission Control Technology for the
      Elemental Phosphorus  Industry, Final  Report for EPA Contract
      No. 68-01-6429.   Science Applications,  Inc.  La Jolla, California
      January 1984.

  3.  U.  S.  Department  of the Interior,  Preprint  from the 1985 Minerals
      Yearbook:  Phosphate  Rock.   Pittsburgh,  Pennsylvania.  1986.

  4.  Eadie, 6. and  0. Bernhardt.   Radiological Surveys  of Idaho  Phosphate
      Ore Processing—The Thermal  Process Plant.   Prepared for U. S.
      Environmental  Protection Agency.   Las Vegas,  Nevada.   Technical  Note
      ORP/LV-77-3.   November  1977.

  5.  U.  S.  Environmental Protection Agency.   Emissions  of  Lead-210 and
      Polonium-210 from Calciners  at Elemental Phosphorus  Plants: Monsanto
      Plant, Soda Springs,  Idaho.   Washington, O.C.   September 1984.

  6.   Andrews,  V.  Emissions of Naturally Occurring Radioactivity:
      Stauffer  Elemental  Phosphorus  Plant.  Prepared  for U.  S.
      Environmental  Protection Agency.  Las Vegas, Nevada.   Publication
      No.  EPA-520/6-82-019.  November 1982.

  7.   Andrews,  V.  Emissions of Naturally Occurring Radioactivity:
      Monsanto  Elemental Phosphorus  Plant.  Prepared  for U. S.
      Environmental  Protection Agency.  Las Vegas, Nevada, Publication
      No.  EPA-520/6-82-021.  November 1982.

 8.   U. S.  Environmental Protection Agency.  Emissions of Lead-210 and
      Poloniun-210 from Calciners at Elemental  Phosphorus Plants:   FMC
      Plant, Pocatello,  Idaho.  Washington,  D.C.   June 1984.

 9.   Radian Corporation.  Draft Final  Emission Test Report, Monsanto
      Elemental  Phosphorus Plant,  Soda Springs, Idaho.  Prepared for U. S.
      Environmental  Protection Agency under  Contract No.  68-02-4338.
      Research Triangle  Park,  North Carolina.   October 1988.

10.   U. S. Environmental  Protection Agency.   Emissions of Lead-210 and
      Polonium-210 from  Calciners  at Elemental  Phosphorus Plants:   Stauffer
      Plant,  Silver Bow,  Montana.   Washington,  D.C.   August 1984.

11.  Memo and attachments from Wallace.,  D., and  K.  Leeds,  Midwest
      Research Institute,  to Beck,  L.,  EPA/ISB.  August 9,  1988.   Site
     Visit—FMC Corporation,  Pocatello,  Idaho.
                                   2-14

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 12.  Radian Corporation.  Draft Final Emission Test Report,  FMC  Elemental
     Phosphorus Plant, Pocatello, Idaho.   Prepared for U.  S.  Environmental

                                          68-02-4338-   Research
 13.  Memo and attachments from Wallace,  D.,  and  J.  Obremski, Midwest
     Research Institute, to Beck,  L.,  EPA/ISB.   August 23, 1988.  Site
     Visit-Stauffer Elemental  Phosphorus  Plant,  Mount Pleasant
     Tennessee.


 14.  Memo and attachments from  Wallace D., and K. Leeds, Midwest Research
     Institute  to Beck, L.,  EPA/ISB.  August 9,  1988.  Site 5i sit"
     Monsanto Elemental  Phosphorus Plant, Soda Springs, Idaho.
15*  Rp^rrh  ?"^mrtS/r2m "allace' D- and J. Obremski, Midwest
     Research  Institute,  to Beck, L., EPA/ISB.  August 23, 1988.   Site
     Visit-Occidental  Elemental Phosphorus Plant, Columbia, TennesseJ.
16"   2IS°?'  rual^ac?VD-' M1dwest ^search Institute,  with  Abbot,  D.,
     Monsanto  Chemical Company.  July 12, 1988.  Radionuclides  in
     Phosphorus Process Streams.
                                2-15

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               3.0  EMISSIONS FROM ELEMENTAL PHOSPHORUS PUNTS

      The primary objectives of this study are to estimate current  emission
 rates of the radionuclides Po-210 and Pb-210 from elemental phosphorus
 plants and to evaluate control measures for those emissions.  This  section
 identifies potential sources of Po-210 and Pb-210 emissions, presents
 estimates of emission levels, and provides information on the character-
 istics of the emissions as a basis for the control technology assessments
 that are presented in Sections 4 and 5.  The discussion addresses the
 different sources of radionuclide emissions within the elemental
 phosphorus process, but it focuses on emissions from the calcining  (or
 nodulizing) operation because emissions from the calciner are much greater
 than those from all other plant operations combined.   The three sections
 below provide a brief discussion of the different emission sources and the
 estimated levels of emissions from these sources, discuss calciner
 emissions in detail,  and  present estimates of  baseline emissions for
 calcining operations  at the five operating facilities.
 3.1  SOURCES OF RADIONUCLIDE  EMISSIONS
      The  Po-210 and Pb-210  concentration  data  presented  in Section  2.2.2
 indicated that  these  radionuclides  are  present at significant  levels in
 three elemental  phosphorus  production streams—the ore feed, calcined
 nodules,  and  slag from  the  electric furnaces.  If the processing,
 handling, or  storage  of these process streams generates particulate  matter
 (PM)  emissions,  then  Po-210 and Pb-210 are emitted to the atmosphere.  The
 operations  that  result  in emissions include high-temperature furnaces
 (specifically the calciner and the electric furnaces); nodule cooling,
 crushing, and screening; and transfer and storage of ore, nodules, slag,
 electric furnace ESP catch, and calciner air pollution control  device
 (APCD) catch.  The paragraphs below briefly describe each of these sources
 and present preliminary estimates of the levels of Po-210 and Pb-210
 emissions from these sources.   Table 3-1 provides a  summary of  these
 preliminary estimates  for  the different  sources as a means of comparing
 the relative levels  of emissions from  those sources.   These estimates are
 based on information collected by EPA  surveys and sampling programs  that
were conducted in support  of the 1983  NESHAP proposal.1-3   More  detailed
                                   3-1

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                 TABLE 3-1.  RADIONUCLIDE EMISSIONS FROM ELEMENTAL PHOSPHORUS OPERATIONS
Emissions, Cl/yr
Storage and handling operations
Noduli2ing Kiln
Nodule coolers
Electric furnace
Nodule crushing/screening
Storage and handling operations
Ore
co Nodules
iv> Slag
ESP catch
Kiln APCO catch

FMC,
Idaho1
6.9
0.2
0.31
NA

NA
NA
NA
NA
NA
PO-210
Monsanto,
Tenn.
0.75
Neg.
0.015
Neg.

NA
Neg.
NA
NA
NA

Stauf fer,
Mont.3
0.20
0.003
0.003
Neg.

Neg.
Neg.
NA
Oa
NA

hMC,
Idaho1
0.003
0.001
0.005
NA

NA
NA
NA
NA
NA
Pb-210
Monsanto,
Tenn.
0.48
Neg.
0.001
Neg.

NA
Neg.
NA
NA
NA

Stauf fer,
Mont.-3
0.28
Neg.
0.001
Neg.

Neg.
Neg.
NA
Oa
NA
 System does not include ESP.
Neg. = <0.001.
  NA = Not  available.

-------
  information on calciner emission rates is presented in Section 3.2.  No
  additional data on emissions from sources other than the calciner were
  identified during this study.
       The principal source of Po-210 and Pb-210 emissions from elemental
  phosphorus production is the nodulizing kiln or calciner.  Emissions from
  the  calciner are generated via  three mechanisms.  First, both Po-210 and
  Pb-210  are relatively volatile  metals as  evidenced by the vapor pressure
  curves  shown in Figure 3-1.*'s   The horizontal  axis of the curve indicates
  temperature and the  vertical axis  indicates  the partial  pressure of the
  Pb-210  and Po-210  at temperature.   The  maximum  concentration  that the
  metal can  achieve  in vapor phase is  the ratio of the partial  pressure to
  760 mmHg.   At  the  temperatures  reached  in the calciner/kiln ore  bed
  (~1300°C),  significant quantities of  Po-210 and  Pb-210 are volatilized  and
  exit the kiln  as vapor in the combustion gas stream.  These vapor-phase
 metals generally condense on surfaces of PM that  is  entrained in  the
 combustion gas  before they penetrate the air pollution control system.
 Second, as the combustion gases  are drawn through the ore bed of the
 moving grate-calciner or the tumbling ore in a kiln, relatively large
 quantities of PM are entrained in the combustion gas stream.  These
 entrained particles,  which contain Po-210 and Pb-210, also are exhausted
 from  the calciner with the combustion gases.   Third, Po-210 and  Pb-210 can
 be volatilized in the electric furnace and returned to the kiln  in the CO
 fuel  stream.  The Po-210  and  Pb-210  again  will  leave the  kiln  as  vapor and
 condense on PM surfaces downstream  from  the kiln.
      Data on the relative concentrations of Po-210 and  Pb-210  in  the  ore
 feed  and nodule product were  collected by  EPA at  three facilities.6"8
 These  data  indicate that  on a mass basis assuming the nodule mass  flux  is
 about  80  percent of the ore mass flux, less than  10  percent of the  Po-210
 and 20 to 60  percent  of the Pb-210 are retained  in the nodules for  rotary
 kiln operations.  For  the moving grate calciner,  about 30 percent of the
 Po-210 and  almost all  of the Pb-210 remain in the nodules.  These  losses
 represent the quantity of material lost to the calciner/kiln combustion
 gases via the first two mechanisms.   No data  on the quantity of Po-210 and
 Pb-210 that return to the calciner/kiln with  the CO were identified during
this study.  However,  the quantities  are  expected to be relatively small
                                   3-3

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400
   600
             aoo
                       looo      120.0
                     Temperature (*C)
                                                             1800
Figure 3-1.   Vapor pressure curves  for Po and Pb,
                           3-4

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 because of the cleaning/condensation process used to remove  dust  and
 phosphorus from this stream.  Table 3-1 presents preliminary estimates  of
 the total  quantities of Po-210 and Pb-210 that are emitted from the
 nodulizing kiln or calciner.1" '   These estimates are based on limited
 test data  and on control levels in place before 1983 and will be  updated
 in Section 3.2.  However, they do serve to compare the relative magnitude
 of calciner emissions to emissions from other processes.
      Nodules are discharged from the calciner/kiln to the nodule  cooler
 where they are air cooled.   The high-velocity airflow in the  coolers
 results in entrainment of PM, which contains Po-210 and Pb-210.   However,
 data generated by EPA, which are presented in Table 3-1, indicate that
 with the exception of emissions generated at FMC,  these emissions are
 negligible in comparison to calciner emissions.   These data are supported
 by the emission estimates shown in Table 3-2,  which are based on the PM
 emission limits that  States have  established for  nodule cooling emissions
 and the concentrations of Po-210  and  Pb-210  that  have  been  measured in
 nodules. "  '10   These estimates are  based  on the  assumption that  Po-210
 and Pb-210  are  uniformly distributed  throughout the  calcined  nodules.
 This  assumption is  likely to  produce  conservatively  high  estimates because
 volatilization  in  the calciner or  kiln will  deplete  Po-210  and Pb-210  near
 nodule  surfaces.   These  surface materials  are more  likely to  be eroded and
 entrained during cooling.   The differences at FMC may result  from  the  high
 temperature of  the cooler exhaust which  is estimated to be  in the  200° to
 300°C  (400° to  600°F) range.  It is possible that Po-210 could be
 volatilized from the  nodule bed in the cooler and that a portion of the
 volatilized material  could be emitted as a vapor at the exhaust gas
 temperatures.
     The nodules are removed from the cooler and subjected to  crushing and
 screening operations to generate a feed that is sized appropriately for
 the electric furnace.   Again, fugitive PM emissions from these operations
can contain Po-210 and Pb-210.  However,  the data  in Table 3-1 indicate
that emissions of Po-210 and Pb-210 from  crushing  and screening operations
are estimated to be less than 0.001 Ci/yr at  each  of the three plants
tested by EPA.
                                   3-5

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               TABLE 3-2.   NODULE COOLER EMISSION ESTIMATES
Facility
FMC
Monsanto
Stauffer
Allowable
PM, lb/h10
83
31
12
Nodule activity
level, Ci/qs-a
Po-210
8
1.9
4
Pb-210
27
5.6
7
Estimated
emissions, Ci/yr
Po-210
0.003a
0.001
<0.001a
Pb-210
0.009a
0.001
<0.001
dNote that these emission levels are lower than those measured by EPA in
 earlier studies as reported in References 1 and 3.
                                   3-6

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      The final processing step that is a potential source of Po-210 and
 Pb-210 emissions is the electric furnace.  The Po-210 and Pb-210 that
 enter the furnace with the nodules are partitioned among four discharge
 streams—slag, ferrophosphorus, primary phosphorus/CO gas stream, and
 fugitive emissions from furnace tapholes.  The data presented in
 Section 2.2.2 indicate that of the total  Po-210 that enters the plant with
 the ore, 5 to 60 percent is contained in  the slag and less than
 0.1 percent is contained in the ferrophosphorus.  For Pb-210, the
 percentages range from 20 to 60 percent and less than 0.1 percent for slag
 and ferrophosphorus, respectively.  Plant personnel contacted during site
 visits indicated that these estimated Po-210 concentrations are higher
 than the concentrations that they would expect to remain in the slag given
 the high temperatures reached in the furnace.   Also,  as  described in
 Section 2,  radionuclides in the slag are  difficult to sample and analyze,
 and the concentrations that were reported have large  uncertainties.
 Consequently,  the information on distribution  of Po-210  and Pb-210  is  not
 considered  to  be reliable.
      The Po-210  and  Pb-210  that are  emitted from the  tapholes may be
 captured by localized hoods  and collected by the emission  control system,
 or they may be emitted to the atmosphere  through furnace shop windows,
 doors,  and  roof  monitors.   No data are  available on the quantities that
 are collected  by the emission control system.   However, the  data in
 Table 3-1 indicate that  as much  as 0.31 Ci/yr  of  Po-210 and  0.005 Ci/yr of
 Pb-210  are  emitted from  the furnaces.   Note  that  these levels are quite
 small in comparison  to kiln emissions.  The  Po-210  and Pb-210 that are
 entrained in the  phosphorus/CO  stream can be collected in the ESP (if one
 is  used), condensed with the phosphorus, or returned to the  kiln with the
 CO.  Plant personnel had no data on the radionuclide content of the ESP
 dust but did indicate that virtually no radionuclides were collected with
 the phosphorus.  The kiln emission rates account for any Po-210 or Pb-210
 that returns to the kiln with the CO.
     Fugitive PM emissions from transfer and storage of ore, nodules, and
waste streams also can be a source of Po-210 and Pb-210.   The only storage
and transfer operations for which emission data are available are those
related to nodule handling.   Generally,  these operations  are enclosed,  and
                                   3-7

-------
 emissions  are controlled by hooding  systems with collection in scrubbers
 or baghouses.  Measurements conducted  by EPA prior to 1983 indicate that
 emissions  from these operations  are  less than 0.001 Ci/yr for each of the
 five  plants.   Generally, emissions from ore handling and kiln air pollu-
 tion  control  device catch handling also can be assumed to be negligible
 because  all plants  currently use  some  type  of wet collection, and the
 moisture in these streams will limit fugitive emissions.  No data were
 identified on the level  of emissions from the handling of slag or ESP
 catch.   However, the data on plant production rates,  slag generation
 rates, and radionuclide  concentrations  in the slag presented in
 Section  2.0 were used to generate "worst-case"  estimates of Po-210 and
 Pb-210 emission rates from slag handling.   These  emission estimates were
 obtained by multiplying  the  activity levels  in  the slag  (see Tables 2-4
 and 2-5) by the annual PM emission rates  determined from the following
 equations for material handling (Eq. 3-1) and wind erosion  from active
 storage  areas  (Eq.  3-2)r11
                                   3 ' * • «** ** % ^ » -^
                         = 1.18xlO"      >      • 9W                  (3-1)
                                      (M/2) •
where
     E! = materials handling PM emissions, kg/yr
      U - mean wind speed, m/s
      M = material moisture content, percent
      W * plant P^ production capacity, Mg/yr
and
                       E2 =

where
     E2 = emissions from wind erosion,  kg/yr/acre
      S = silt content of slag,  percent
      P = percentage of days  with  >0.25 mm precipitation per year
      f = percentage of time  wind  exceeds  5.4 m/s
As a worst case the mean  wind speed  was assumed  to be 15 m/s,  the material
moisture content 0.25 percent, the silt content  10 percent,  the percentage
                                   3-8

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 of time the wind exceeds 5.4 m/s 100 percent, and the percentage  of  days
 with precipitation 0 percent.  Under these worst-case scenarios,  all
 plants are estimated to have Po-210 and Pb-210 emissions of  less  than
 0.003 Ci/yr for materials handling and less than 0.0003 Ci/acre/yr for
 wind erosion.
 3.2  KILN EMISSION CHARACTERIZATION
      As indicated by the information presented in Section 3.1, the
 nodulizing kiln (or calciner) is by far the greatest source of Po-210 and
 Pb-210 emissions from elemental  phosphorus production.  Consequently,
 control technology analyses presented in Section 4.0 focus on this
 emission source.  This section provides a comprehensive review of
 available calciner emission data.   It is divided into three subsections.
 The first presents information on  Po-210,  Pb-210, and PM emission rates.
 The second discusses acid gas emissions from the calcining operation, and
 the third presents data on Po-210  and Pb-210 particle size distributions.
 3.2.1   Mass Emission Rates of Po-210.  Pb-21Q and PM
      The emissions of PM and  radionuclides  from  elemental  phosphorus  plant
 calcining operations have been tested  extensively by both  EPA and  the
 facilities since 1977.   Data  are available  for four  of the  five operating
 facilities.   Although  these tests provide a  firm basis for  regulating
 radionuclide  emissions,  evaluation of  the data to  identify  general emis-
 sion trends  is complicated by the plant-to-plant variations in processes
 and air  pollution  control  systems and by the inherent uncertainties that
 result from complex  sampling situations (high moisture, high  temperature,
 and cyclonic  flows)  and radionuclide analytical techniques.   The available
 test data  are summarized  in Tables 3-3 through 3-5.  Table 3-3 identifies
 test locations and presents information on stack gas conditions.
 Table 3-4 presents PM emission rates and concentrations, and Table 3-5
 presents Po-210 and Pb-210 emission concentrations and annual  emission
 rates.
     Figures 3-2 and 3-3 present a  more detailed  summary of the emission
concentration data for Po-210 and Pb-210,  respectively.   In each  figure,
run-specific emission concentrations  are presented for the  test series
that are summarized in Table 3-5.   The data  are grouped  into one of four
levels of control—no control,  low-energy  scrubber, venturi  scrubber,  and
                                   3-9

-------
                                                             TABLE  3-3.    SUMMARY  OF  TEST  CONDITIONS*
CO
 I
Test conditions
Test
10
A
B
C
0
E
f
G
H
I
J
K
I
Hh

N
0
P
Q.
R1
S
I

u

V
u

Facility
FMC, Idahob










Monsanto. Idaho


Stauffer, Mont.



Occidental. Tenn.
FMC. Idaho
FMC, Idaho

FHC. Idaho

Monsanto. Idaho
Monsanto, Idaho

Unit tested
Calclner
Calclner
Calclner
Calciner
Calclner
Calctner
Calclner
Calctner
Calclner
Calciner
Calciner
Kiln
Kiln

Kiln Ho.
Ki In No.
Kiln No.
Kiln No.
Kiln No.
Calclner
Calciner

Calciner

Kiln
Kiln

2-1
2-2
2-2
1-1
1-2
2-1
2-2
2-1
2-2
1-1
1-2











1




Air pollution control
None
None
Slinger scrubber/cyclonic mist elUinator
Slinger scrubber/cyclonic «lst elUinator
Slinger scrubber/cyclonic list •lUtnator
Slinger scrubber/cyclonic «Ut tllilnator
Slinger scrubber/cyclonic list elUfnator
Slinger scrubber/cyclonic list eliminator
Slinger scrubber/cyclonic list elUinator
Low-energy venturi/horizontal chevron-'blade
•ist elUinator
Spray tower
Spray tower/high-energy venturi/cyclone
•1st elUinator
Spray tower/wet ESP
None
Spray tower only
Spray tower/wet ESP
Low-energy scrubber
None
Low-energy venturi/horlzontal chevron-balde
•ist elUinator (typical AP)
low-energy venturi/horlzontal chevron-blade
•ist elUinator (maximum Ap)
Spray tower
Spray tower/high-energy venturi/cyclone
•ist elUinator
Test
date
1983
1983
1983
1983
1983
1985
1985
1987
1987
1987
1987
1983
1987

1979
1983
1983
1983
1985
1988
1988

1988

1988
1988

Test
sponsor
EPAC
EPAC
EPAC
EPAC
EPAC
fMCd
FMCd
FMCf
FMCf
FMCf
FMCf
EPA«
Monsanto'

EPAj
EPAk
EPAk
EPAk
Occidental"
EPAn
EPA"

EPA"

£PA°
EPA°

Votunetric flow
•J/«1n
4.020
5.210
3.550
3.220
2.620
2,360*
2.340*
3.870
3,880
2,890
3.830
8.070
7.470

NA
2,240
681
614
3.250
8.760
7.390

6.170

5.860
5,760

acf«
142.000
184.000
125.000
114.000
92.500
83.300*
82.500*
137.000
137.000
102.000
135.000
285.000
264.000

NA
79.200
24,100
21.700
115.000
309.000
261.000

218.000

207.000
203,000

Temperature
•C °F
290
280
62
59
58
NA
NA
54
54
54
49
68
67

NA
350
15
13
73
240
59

58

NA
NA

550
530
140
139
136
NA
NA
130
130
129
121
155
152

NA
660
59
55
163
460
138

137

NA
NA

Moisture,
percent
9.5
9.9
15.4
20.8
20.7
NA
NA
17.7
17.7
15. 5
13.9
33.1
33.1

NA
15.8
2.1
1.7
18.8
11.0
19.1

19.0

41.3
38.9

            JJAII tests are based on three-run averages  unless noted otherwise.
            Each of the  tests at FMC is fro« one of two parallel strews associated with one calclner (e.g..  Calciner 2-1 is  for test on Scrubber No. 1, Calciner No.  2 )
            ^References 6 and 12.
            "Reference 13.
            fOnly dry standard conditions presented in  test report.
            ^References 14 and 15.
            (•References 7 and 16.
            .Based on 12  runs, 3 each on outlets of parallel scrubbing system.
            .References 17 and 18.
            ^Reference 3.
            ^References 8 and 19.
            Two runs.
            "Reference 20.
            "Reference 21.
            "Reference 22.

-------
                    TABLE 3-4.   CALCINER PM EMISSION DATA
Test
IDa
A
B
C
0
E
F
G
.H
I
J
K
L
M
0
P
Q
R
S
T
U
V
W
Control measure'3
None
None
SS/Cyc
SS/Cyc
SS/Cyc
SS/Cyc
SS/Cyc
SS/Cyc
SS/Cyc
LEV/Ch
LEV/Ch
ST
ST/HEV/Cyc
None
ST
ST/WESP
LES
None
LEV/Ch
LEV/Ch
ST
ST/HEV/Cyc
Concentration
g/dscm
1.0
6.9
0.089
0.32
0.14
NA
NA
0.046
0.062
0.032
0.018
0.34
0.023
4.4
0.14
0.060
0.27
1.09
0.082
0.095
0.59
0.027
gr/dscf
0.45
3.0
0.039
0.14
0.063
NA
NA
0.020
0.027
0.014
0.008
0.15
0.010
1.9
0.060
0.026
0.12
0.48
0.036
0.041
0.26
0.012
Emission rate
kg/h
98.4
835
12.0
35.9
13.7
8.44
8.84
5.31
9.44
4.72
2.77
77.6
4.72
184
4.54
1.81
49.0
246
21.9
20.8
104
4.90
Ib/h
217
1,840
26.4
79.1
30.3
18.6
19.5
11.7
20.8
10.4
6.1
171
10.4
406
10.0
4.0
108
541
48.3
45.8
230
10.8
"See references on Table 3-3.
 SS/Cyc = slinger scrubber with cyclone mist eliminator.
    LEV = low-energy venturi.
    HEV = high-energy venturi.
     ST = spray tower
     Ch = Chevron-blade mist eliminator.
    LES = low-energy scrubber.
   WESP = wet electrostatic precipitator.
                                   3-11

-------
                 TABLE 3-5.   CALCINER RADIONUCLIDE EMISSION DATA
Test
IDa
A
B
C
0
E
F
G
H
1
J
K
L
M
N
0
P
0
R
S
T
U
V
M
Control measure
None
None
SS/Cyc
SS/Cyc
SS/Cyc
SS/Cyc
SS/Cyc
SS/Cyc
SS/Cyc
LEV/Ch
LEV/Ch
ST
ST/HEV/Cyc
ST/WESP
None
ST
ST/WESP
LES
None
LEV/Ch
LEV/Ch
ST
ST/HEV/Cyc
Po-210 emissions
pCi/g PM nCi/dscm
4,100
1,050
17,000
12,000
27,000
25,000
29,000
21,000
18,000
37,000
38,000
37,000
10,000


37,000
31,000
350
4,400
55,000
51,000
39,000
35,000
4.6
6.2
1.44
3.04
3.80
1.47
1.43
0.961
1.10
1.18
1.96
12.5
0.23
0.23

4.88
1.61
0.23
4.8
4.5
4.9
23
0.95
Ci/yr
3.3C
6.1C
1.4C
2.6C
2.7C
1.2d
1.7d
0.72d
1.36d
1.24d
2.04d
21C
0.35d


1.2C
0.37C
0.36d
8.0C
9.0C
7.9C
30C
1.4e
Pb-210
pCi/g PM
39
28
330
74
330






9,700


2,900
4,800
4,600
180
180
200
1,300
2,200
8,200
emissions
nCi/dscm
0.04
0.19
0.03
0.02
0.05






3.3

0.34
12.5
0.65
0.25
0.049
0.20
0.015
0.12
7.3
0.23

Ci/yr
0.029°
0.18C
0.026C
0.016C
0.039C






5.6C


4.0C
0.16C
0.056C
0.075d
0.32C
0.030C
0.19C
9.5C
0.34e
j*See references on Table 3-3.
 SS/Cyc * slinger scrubber with cyclone mist eliminator.
    LEV * low-energy venturi.
    HEV * high-energy venturi.
     ST = spray tower
     Ch = Chevron-blade mist eliminator.
    LES * low-energy scrubber.
   WESP = wet electrostatic precipitator.
^Assumes plant operates 85 percent of  time.
Biased  on facility assumptions on operating rates.
eAssumes plant operates 95 percent of  time.
                                          3-12

-------
                           p
                           b
                                                          Po-210  Concentration  (nCl/dscm)
 at

 CO

 ro
-a
o
i
ro
m
ui
.j*
o
CL

PI
                        FMC
               O
               o
               o


               m

               o

              (Q
o

c
IT
(T

o m
6 o am m o
-nO
-noO T
-I
T3
T) T>
?; -in H
*- *- ?;?; c c c
S
O
o o

03


I-
^*r m





-------
10

 1
 n>
u>
I
I—»
£»
-o
cr
n>

«i.
U)
ui
Q.
Pt
                              p

                              2
                                                              Pb-210  Concentration  (nCi/dscm)
                         z

                         0       FMC

                         O
                         o
                         3

                             STAUFFEH
                  I-

               (A O
                          FMC
               O- 3  MONSANTO
               cr D
                      STAUFFER
                         m
                         W   STAUFFER
                         "D
                          FMC
               CT 5;  MONSANTO
               O —
1 1 1 1 II 1 1
> >OJ > CO
omo
> • Jlf • •
o moo o


> 	 • — • — • 	 »
-H H H C C

1 1 1 II 1 II
CO 00 COCO

m

T3 -0 -0
D
20 OZ 2
C
	 • • •
^ ZZ
1 1 1 1 1 1 II

0

r i- r < < <

V




O O







-------
 wet ESP.  The emission data presented  in  Table 3-5 and Figures 3-2 and 3-3
 were not subjected to rigorous  statistical  analyses,  but the graphical
 displays in Figures 3-2 and 3-3 provide substantive information on the
 Po-210 and Pb-210 emissions from different  facilities with different
 control systems.  The paragraphs below discuss the overall variability of
 the Po-210 and Pb-210 concentrations, with  particular emphasis on  the
 variability of emissions over time, and identify  data that can be  used to
 assess control device performance and the effects  of  new control systems
 on Po-210 and Pb-210 emissions.
      The data presented in Figures 3-2 and  3-3  indicate  that measured
 emissions for individual test runs range over  almost  3 orders  of magnitude
 for both Po-210 (approximately 0.1 to 30 nCi/dscm)  and Pb-210  (less  than
 0.01 to 9 nCi/dscm).   Contributors to this variability include the
 inherent imprecision in the sampling and analysis method,  changes in
 operating conditions  at a plant over time, plant to plant  differences  in
 ore feed characteristics and  calciner operating conditions, and different
 levels  of add-on  air  pollution control.   The data collected to date are
 not sufficient to quantify the contributions of these different mechanisms
 to the  overall  variability in  emissions.   However, careful examination  of
 the data in  Figures 3-2  and 3-3  leads  to the following qualitative
 observations.
      1.   The run-to-run  variation within a given test  sequence  is
 relatively small.  Generally the largest measured  concentration for a
 given test is  less than two to three times the  smallest measured
 concentration.  For Po-210, the two exceptions  are  Test A which ranges
 from about 2 nCi/dscm to 9  nCi/dscm (a factor of 4.5)  and Test  B which
 ranges from 0.4 to 16 nCi/dscm (a factor of  40).   For  Pb-210, primary
 exceptions are Test B which ranges from 0.04 to  0.3  nCi/dscm  (a factor  of
 7.5), Test E which ranges from 0.02 to 0.12 nCi/dscm (a factor of 6), and
 Test U which ranges from 0.04 to 0.3 nCi/dscm (a factor of  7.5).  Each  of
 these tests was conducted on one of the two moving grate calciners.   On
 balance, these data suggest that variation  associated with  sampling  and
 analysis imprecision is reasonable,  i.e.,  the variability in a 3-run test
that is  attributable to sampling and analysis imprecision is likely  to be
a factor of 3 or less.   The data also  suggest that emissions from moving
grate calciners are more  variable than  those  from kilns.

                                   3-15

-------
      2.   The test-to-test variability at the same plants at different
 times generally is greater than the within test run-to-run variability at
 those same facilities.   Four sets  of Po-210 test data illustrate this
 observation.   Tests L and V were conducted at the outlet of the Monsanto
 spray tower in 1983 and  1988,  respectively.  The within test range was
 spanned  by a factor of  less than 1.5 for both tests while average
 emissions for the two tests were 12.5 nCi/dson and 23 nCi/dscm, a factor
 of about 2.   Tests at the outlet of the  low-energy venturi  scrubber at FMC
 were  conducted in 1987  (Tests  J and K) and 1988 (Test T).   The within test
 run-to-run range  spanned  a factor  of 2 or less for all  three tests.
 However,  average  the emission  concentration in 1987 was about 1.6 nCi/dscm
 and the  average in 1988 was about  4.5 nCi/dscm,  a factor of about 3.
 Tests  were conducted at the outlet  of the high energy venturi  scrubber in
 1987  (Test M)  and 1988 (Test W).  The 12  measurements in 1987  ranged  over
 a factor of  about 4 while the  3  measurements  in  1988 ranged over  a factor
 of about  1.5.   In contrast,  the  average emissions  in 1987 were
 0.23 nCi/dson  while those in 1985 were 0.95 nCi/dscm, a  factor  of over
 4.  Because the individual  test  runs  in 1985  represent different
 scrubbers, the range is larger than would  be  found  for test  runs  on a
 single scrubber.   Hence,  the between  test  range  is  slightly  larger than
 the within test range.  Finally, tests were conducted at the outlet of the
 ESP at Stauffer in  1979 (Test N) and  1983  (Test  Q).  Within  test  run-to-
 run variability range over  a factor of less than 2  for each  test while
 average concentrations for  the two  tests were 0.23  nCi/dscm  (1979) and
 1.61 nCi/dscm  (1983), a factor of between 7 and 8.  These data, in
 combination with  those presented in (1) above, suggest that the
 contribution of operating variability to overall variability in emission
measurements is somewhat greater than the contribution of sampling and
 analysis imprecision.
     3.  Control  systems comprising a spray tower and high energy venturi
or a spray tower and wet ESP can achieve  significant reductions (greater
than 90 percent)  in Po-210 and Pb-210 emissions.  This observation is
based on comparison of the tests at the outlet to the Monsanto spray tower
 (Tests L and V) to the emissions at the venturi outlet (Tests M and W) and
the tests at the spray tower inlet  (Test  0), spray tower outlet (Test P)
                                   3-16

-------
  and ESP outlet  (Tests Q and N) at Stauffer.  The performance of these
  control systems  is  analyzed in more detail in Section 4.
  3.2.2  Acid  Gas  Emissions
       Elemental phosphorus calcining operations are sources of acid gas
  emissions  that can  include S02, HF, HC1,  and P205.  However, the primary
  constituents are S02  and HF.   These acids are generated by fluorides and
  sulfides that are contained in the phosphate ores and in coal that is used
  to  supplement the CO  as fuel  in the calciner.   This study is not concerned
  directly with acid  gas  emissions,  but  they do  play an important role in
  evaluating emission control  alternatives.   Consequently,  available data
  were  collected from emission  test  reports,  and  information on acid gas
  levels  was requested  from plant personnel  during  plant  visits.   The
  limited data that were  obtained are presented  in  Table  3-6.
  3.2.3   Po-210 and Pb-210  Particle  Size Distributions
      The control  technology assessments in Chapter  4  require  an  estimate
  of the  particle size distributions  of Po-210 and  Pb-210 emissions.  The
  only radionuclide-specific particle  size data that were identified  during
  this study were those generated by  EPA in support of NESHAP development.
  During  that comprehensive test  program, particle size data were collected
  at the  inlets and outlets of control systems at the three Western plants
 using one of two  methods—a cascade  impactor or the SASS cyclones.  The
 data generated  from  that program are tabulated in Tables 3-7 and 3-8 for
 the impactor samples and SASS samples,  respectively.
      The data in  Table 3-7 indicate the distributions at the scrubber
 inlet are distinctly different from those  at the outlet  at FMC.   In
 general, the  inlet data  are bimodal with significant fractions of the
 emissions less than  1.0  urn and greater  than 10  ym  in diameter.   At  the
.outlet,  over  70 percent  of the Po-210 and  Pb-210 were  in the  two  fractions
 that were less than  0.9  um in  diameter except  for  the  Pb-210  on  Calciner
 No.  1  at FMC.  Consequently,  additional controls must  focus on submicron
 PM.
     The data in Table 3-7  also  indicate that the distributions of both
 Po-210 and Pb-210 at Stauffer  and Monsanto are different from those  at
 FMC.  However,- the SASS  results  in Table 3-8 and the cascade impactor
 tests in Table 3-7 indicate that the  distributions at Monsanto are
                                   3-17

-------
TABLE 3-6.  ACID GAS EMISSION LEVELS
Facility
FMC, Idaho
Monsanto, Idaho
Stauffer, Mont.
Stauffer, Tenn.

Occidental, Tenn.
Location
Stack
Stack
Kiln
exhaust
Kiln
exhaust
Stack
Stack
HF levels
ppmv kg/h
18-40 6-8
1.5
45
180
0.7.
66
SO, levels
ppmv kg/h
200

68
250
64
774
Ref.
14,15
17
3
21
21
20
               3-18

-------
TABLE 3-7.  PARTICLE SIZE DISTRIBUTION BASED ON IMPACTOR SAMPLES
Pollutant
Po-210










Pb-210









Control
level
None


Low-energy
scrubber



ESP
Ventur i

None


Low-energy
scrubber


ESP
Venturi

Facility/
location
FMC/2-1
FMC/2-2
FMC/1
FMC/2-2
FMC/1-1
FMC/1-2
Stauffer
Monsanto
Stauffer
Monsanto
FMC/1
FMC/2-1
FMC/2-2
FMC/1
FMC/2-2
FMC/1-1
FMC/1-2
Stauffer
Monsanto
Stauffer
Monsanto
FMC/1
Percentage of pollutant in size ranqe

75
33.5
23.8
65.0
70.7
71.6
85.8
52.2
60.0
50.1
70.0
72.5
41.5
12.4
30.0
61.2
26.9
21.3
60.0
60.0
54.1
60.0
53.5
Approximate particle size 0-50. urn
U.5-O.9
3.9
2.6
7.5
6.1
3.1
2.9
21.6
26.5
23.5
18.0
7.8
6.2
2.4
12.5
11.8
17.9
23.4
18.1
26.5
22.4
26.5
14.5
0.9-1.3
4.9
3.8
6.0
7.5
1.6
2.3
12.9
6.3
16.5
5.3
5.7
9.5
1.8
13.3
4.6
21.4
8.5
14.3
7.5
14.1
8.5
11.0
1.5-3
5.8
5.2
6.9
5.6
1 .3
1.4
8.9
4.7
4.4
4.7
5.5
11 .8
1.3
12.2
a. 8
4.8
12.8
5.2
4.0
4.9
3.5
10.5
3-10
18.0
15.6
7.6
6.8
1 .9
2.5
3.4
1.4
3.5
1 .4
5.8
13.0
32.3
19.0
q 5
y • j
13.1
17.0
2.0
1.8
3.3
1.2
8.2

>10
33.9
49.0
7.0
3 -5
j . j
20 A
£w * *+
5 i
J • 1
1 0
' • \f
0.6
2.0
0.6

18 0
1 O • \J
49.7
13.'o

IK 0
i J m O
17.0
0 4
*J • *t
0.2
1.2
0.3
2.3
                            3-19

-------
TABLE 3-8.  PARTICLE SIZE DATA BASED ON SASS CYCLONE SAMPLES
Percentage of pollutant
in size range

Pollutant
Po-210



Pb-210




Facility
Stauffer


Monsanto
Stauffer


Monsanto
Approximate particle
size D-50. urn
Location
Spray tower
outlet
ESP outlet
Stack
Spray tower
outlet
ESP outlet
Stack
<:L
72.2

91.2
94.6
92.4

96.9
93.7
1-3
9.6

0.3
.3.7
4.0

1.1
4.3
3-10
0.4

0.1
0.5
0.2

0.1
0.6
>10
17.8

8.4
1.2
3.4

1.9
1.4
                           3-20

-------
 comparable to those at Stauffer.  In the absence of other information,
 these data suggest that distinct particle size distributions should be
 used  for moving grate calciners (FMC) and nodulizing kilns (all other
 plants)  in the control  technology assessments.  The data from the earlier
 tests indicate that the cascade impactor data from Stauffer and the
 Monsanto values from 1988  are  the most  reliable data for kiln particle
 size  estimates.  The cascade  impactor data from FMC are the only data
 available  for the moving grate calciner.
 3.3   KILN  BASELINE EMISSIONS
      Baseline estimates of the annual emissions  of  Po-210  and Pb-210  from
 each  of  the five  operating facilities were developed on  the basis of
 actual emissions  at  the control device outlet  and regulatory  emission
 levels.  Actual baseline emission estimates are  based on the  most recent
emission tests  conducted by either the facility  or EPA.  Regulatory
baseline emission estimates were based on the PM emission limits imposed
by the States and best estimates of radionuclide activity levels in PM
emissions.  The results of these analyses are presented in Table 3-9.
                                  3-21

-------
             TABLE  3-9.  BASELINE  Po-210 AND  Pb-210  EMISSIONS
Actual
emissions, Ci/yr
Facility
FMC-Idahoa
Monsanto- Idaho0
Stauffer-Monte
Stauffer-Tenn.h
Occi dental -Tenn.
Po-210
10. Ob
1.4d
0.74f
0.281.
0.31J
Pb-210
0.14C
0.34d
O.llf
0.0581.
0.064J
PM
emission
limit, Ib/h
304
33
589
78.4
437
Regulatory
baseline, Ci/yr
Po-210
57
4.9
6.0
0.26
1.5
Pb-210
0.29
1.3
0.89
0.0056
0.31
aBased on facility production data.
DBased on EPA tests of 1983 and 1988.
^Assumes 90 percent operation.
aBased on EPA 1988 tests.
^Assumes kiln operates 85 percent of time.
ABased on EPA 1983 tests.
jJBased on twice Montana limit for No. 2 kiln.
 Estimated based on data supplied by facilities.  Operating rate estimated
.to be in the range of 85 to 100 percent of capacity.
lEstimated based on Occidental emissions and relative plant capacities.
JBased on plant tests conducted in 1985.
                                   3-22

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 3.4  REFERENCES FOR SECTION 3

  1.  Eadie, G. and Bernhardt, D.  Radiological Survey of  Idaho Ore
      Processing—The Thermal Process Plant.  Prepared for U. S.
      Environmental Protection Agency.  Las Vegas, Nevada.  Technical Note,
      ORP/LV-77-3.  November 1977.

  2.  Andrews, V.  Emissions of Naturally Occurring Radioactivity from
      Monsanto Elemental Phosphorus Plant.  Prepared for U. S. Environ-
      mental Protection Agency.  Las Vegas, Nevada.  Publication
      No. EPA-520/6-82-021.  November 1982.

  3.  Andrews, V.  Emissions of Naturally Occurring Radioactivity from
      Stauffer Elemental Phosphorus Plant.  Prepared for U. S. Environ-
      mental Protection Agency.  Las Vegas, Nevada.  Publication
      No. EPA-520/6-82-019.  November 1982.

  4.  Weast, R. C., ed.  CRC Handbook of Chemistry and Physics,  64th
      Edition.  Cleveland.   The Chemical Rubber Company.   1984.
      p.  D-196.

  5.  Brooks,  L.  S.  The Vapor Pressure  of Polonium.   Journal  of the
      American Chemical  Society.   77:3211.  1955.

  6.  U.  S.  Environmental Protection  Agency.   Emissions of  Lead-210  and
      Polonium-210  from Calciners  at  Elemental  Phosphorus Plants:  FMC
      Plant, Pocatello,  Idaho.  Washington,  D.C.   June 1984.

  7.   U.  S.  Environmental Protection  Agency.   Emissions of  Lead-210 and
      Polonium-210  from  Calciners  at  Elemental Phosphorus Plants:  Monsanto
      Plant, Soda Springs,  Idaho.  Washington, D.C.  September 1984.

 8.   U.  S.  Environmental Protection Agency.  Emissions of Lead-210 and
      Polonium-210  from  Calciners  at  Elemental Phosphorus Plants:  Stauffer
      Plant, Silver Bow, Montana.  Washington, D.C.  U. S. EPA.
      August 1984.

 9.   Stula, R. T., R. E. Balanger, C. L. Clary, R. F. May,  M. E. Spaeth,
      and J. P. Swenson.  Airborne Emission Control Technology for the
      Elemental Phosphorus Industry, Final Report for EPA Contract
      No. 68-01-6429.  Science Applications, Inc.  La Jolla, California.
      January 1984.

10.  Memo and attachments from Leeds, K., Midwest Research  Institute, to
     Beck, L., EPA/ISB.  October 14,  1988.  State Emissions Standards for
     Elemental Phosphorus Plants.

11.  Cowherd,  C., G.  Muleski,  and  J.  Kinsey.   Control  of  Open  Fugitive Dust
     Sources.   Prepared for U.  S.  Environmental  Protection  Agency.   Research
     Triangle  Park, North Carolina.   Publication No.  EPA-450/3-88-008
     September 1988.
                                   3-23

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12.  Radian Corporation.  Emission Testing of Calciner Off-Gases At FMC
     Elemental Phosphorus Plant, Pocatello, Idaho.  Emission Test Final
     Report, Volume I.  Prepared for U. S. Environmental Protection Agency
     under Contract No. 68-07-3174.  Research Triangle Park,, North
     Carolina.  August 1984.

13.  Letter from Hebert, F., FMC, to O'Neal, G., EPA.  September 6,
     1985.  Summary of 1985 emission test results.

14.  Letter from Bowman, M., FMC Corporation, to Magno, P., EPA/ORP.
     February 26, 1988.  Summary of FMC emission data.

15.  Memo and attachments from Wallace D., and K. Leeds, Midwest Research
     Institute, to Beck, L., EPA/ISB.  August 9, 1988.  Site Visit~FMC
     Corporation, Pocatello, Idaho.

16.  Radian Corporation.  Emission Testing of Calciner Off-gases at
     Monsanto Elemental Phosphorus Plant, Soda Springs, Idaho.  Emission
     Test Final Report, Vol. I.  Prepared for U. S. Environmental
     Protection Agency under Contract No. 68-02-3174.  Research Triangle
     Park, North Carolina.  August 1984.

17.  Memo and attachments from Wallace, D., and K. Leeds, Midwest Research
     Institute to Beck, L., EPA/ISB.  August 9, 1988.  Site Visit--
     Monsanto Elemental Phosphorus Plant, Soda Springs, Idaho.

18.  Letter from Wind, D., Monsanto Chemical Company, to McLaughlin, T.,
     EPA/ORP.  May 10, 1988.  Emission data from Monsanto, Soda Springs,
     facility.

19.  Radian Corporation.  Emission Testing of Calciner Off-Gases At
     Stauffer Chemical Elemental Phosphorus Plant, Silver Bow, Montana.
     Emission Test Final Report, Volume I.  Prepared for U. S.
     Environmental Protection Agency under Contract No. 68-07-3174.
     Research Triangle Park, North'Carolina.  August 1984.

20.  Memo and attachments from Wallace, D., and J. Obremski, Midwest
     Research Institute, to Beck, L., EPA/ISB.  August 23, 1988.  Site
     Visit—Occidental Elemental Phosphorus Plant, Columbia, Tennessee.

21.  Radian Corporation.  Draft Final Emission Test Report, IFMC Elemental
     Phosphorus Plant, Pocatello, Idaho.  Prepared for U.  S. Environmental
     Protection Agency under Contract No. 68-02-4338.  Research Triangle
     Park, North Carolina.  October 1988.

22.  Radian Corporation.  Draft Final Emission Test Report, Monsanto
     Elemental Phosphorus Plant, Soda Springs, Idaho.  Prepared for U. S.
     Environmental Protection Agency under Contract No. 68-02-4338.
     Research Triangle Park, North Carolina.  October 1988.
                                   3-24

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23.   Memo and attachments from Wallace,  0.,  and  J.  Obremski,  Midwest
     Research Institute,  to Beck,  L.,  EPA/ISB.   August 23,  1988.   Site
     Visit—Stauffer Elemental Phosphorus  Plant, Mount Pleasant,
     Tennessee.
                                 3-25

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                            4.   EMISSION CONTROLS

      The nodulizing kiln or calciner is by far the most significant source
 of Po-210 and Pb-210 emissions from elemental phosphorus production.  This
 section describes and assesses control  technologies that can be used to
 reduce those emissions.  Generally Po-210 and Pb-210 are volatilized in
 the kiln or calciner and preferentially condense on the fine particles in
 the calciner PM emission stream.   The control systems that are installed
 in the industry effectively collect large particles, but they are not
 effective controlling fine particle emissions.   Consequently, the technol-
 ogies examined in this section are those that have been demonstrated to
 achieve high control  efficiencies  on fine particles.  However,  control  of
 Po-210 and Pb-210 emissions is complicated by two factors.   First, because
 the temperature of the flue gas leaving the kiln may be 400°C (750°F)  or
 higher, significant concentrations of Po-210 can remain in  the  vapor phase
 (see Figure 3-1).   Second,  the exhaust  contains  relatively  high concentra-
 tions of SO2 and HF;  these  acid gases can  condense  in  the control  system
 leading to subsequent  corrosion and  deterioration of performance.
 Mechanisms-for cooling  the  exhaust gases and  reducing  the acid  gas concen-
 tration in the gases  are discussed  later in  this section.
      Applicable control systems for  the kiln  or calciner emissions are
 examined  in  the three  subsections below.  The first describes the  control
 systems;  discusses  the operating principles of each system; and identifies
 key  design and  operating parameters which affect performance, as measured
 by Po-210  and  Pb-210 reduction, and costs.  The second describes proce-
 dures for estimating the performance of each type of control system and
 discusses the emission data that are available on system performance.  The
 third describes the general procedures for estimating the costs for each
 control system and presents assumptions  used to  develop estimates for
major cost elements for each of the control systems.   Details  of specific
control alternatives and the performance and cost of those  alternatives
are contained in Section 5.
                                   4-1

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 4.1   DESCRIPTION OF APPLICABLE CONTROL SYSTEMS
     The four fine PM control techniques examined  during this  study are
 wet electrostatic precipitators (wet ESP's), venturi  scrubbers,  spray
 dryers with pulse jet fabric filters (SD/FF's), and  high-efficiency
 particulate air (HEPA) filters.  The wet ESP and venturi  scrubber were
 selected because they are the control systems that are  used  at operating
 elemental phosphorus plants.  The SD/FF and HEPA were selected as high-
 efficiency PM control devices that have excellent potential  for
 controlling Po-210 and Pb-210 emissions but that have not  been applied to
 elemental phosphorus plants.  The SD/FF systems have been  applied
 successfully to combustion sources and mineral and metallurgical  furnaces
 and have demonstrated high control efficiencies for condensible metals and
 acid gases.  The HEPA filter has been demonstrated to achieve  high  control
 efficiencies on radionuclide emissions from uranium industry processes.
     Four of the five operating elemental  phosphorus facilities currently
 operate spray towers as either the primary control system  or as a gas
 conditioning technique.  These spray towers will remove coarse PM as well
 as acid gases from the gas stream.  All  of the control techniques,  except
 the SD/FF, can benefit from inclusion of a spray tower upstream of  the
 primary fine PM control device to reduce temperature, gas  volume, and  acid
 gas concentration.
     The five subsections below address  spray towers and the four fine PM
 control  techniques individually.   Each  section includes a description of
 the control technique,  a discussion of  the operating principles for the
 technique, and identification of  the key design  and operating parameters.
 4.1.1  Spray Towers
     A spray tower is one of the  most simply constructed wet scrubbers,
 comprising a cylindrical  vessel constructed of steel, plastic,  or wood and
one or more sets of  nozzles  that  are used  to spray  liquid into  the gas
 stream.   The exhaust gas  generally enters  the bottom of  the tower and
moves upward as  shown in  Figure 4-1.    Liquid, generally water  or a slurry
of water and lime, is sprayed downward from one  or  more  levels  to provide
a countercurrent flow of  liquid and  gas  in  the tower.   This countercurrent
 flow exposes the exhaust  gas  with  lowest pollutant  concentration  to the
freshest scrubbing liquor.
                                   4-2

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teuds MOJJ  }ua-uro.-i9}unoo
                                 " pmbrj

-------
     As a preconditioner upstream from a fine PM control  device,  a spray
 tower  serves three functions.   First, it reduces the temperature  of the
 gas  stream by evaporative cooling.  This temperature reduction enhances
 Po-210 and Pb-210 control by increasing condensation, and  it reduces the
 gas  volume that must be treated by the fine PM control system. Second,
 the  spray tower reduces the concentration of S02 and HF in  the control
 stream by absorption.  The HF is a highly soluble gas and  is absorbed
 readily in water.  However, because S02 is less soluble than HF,  a lime
 slurry typically is used to enhance S02 removal.  Plant personnel
 contacted during this study indicate that operating spray towers  generally
 achieve S02 reductions of 75 percent and HF reductions of 99 percent or
 more.2'   Third, the spray tower removes coarse PM from the  gas stream.
 Typical efficiencies for spray towers are reported to be 90  percent  on
 particles 5 um in diameter or greater and 60 to 80 percent on  particles  in
 the  3  to 5 ym size range.1*  The test data presented in Table  3-4  indicate
 that a PM control efficiency of about 97 percent was achieved  by the spray
 tower  at Stauffer.
     The primary PM collection mechanism for spray towers is  inertia!
 impaction of particles to liquid droplets.   Key parameters that affect
 particle collection by impaction for particles  of a given size are
 scrubbing zone height, gas velocity  in the  spray tower  (generally pressure
 drop (AP)  across the tower is used as  a  surrogate),  liquid-to-gas  (L/G)
 ratio, and spray droplet size.   The  pressure  drop across  the tower and the
 L/G ratios affect operating cost as  well  as  performance.   Typical  values
 of operating characteristics for spray towers are:
     APS                     0.25-0.5  kPa  (1  to  4 in. w.c.)
     L/G ratio5               1.3 to  2.7  i/m3  (10  to  20 gal/kacfm)
     Droplet size1            500 to  1,000 um
     The primary acid  gas  collection mechanism  in spray towers is
 absorption.   Removal of  a  gaseous pollutant by absorption  requires
 intimate contact between the exhaust stream and  the  sorbent  liquid.  Three
 steps are  involved  in  absorption.  In  the first  step, the  gaseous
pollutant  diffuses  from  the  bulk area  of the gas phase to  the gas-liquid
 interface.   In the  second  step,  the gas moves (transfers)  across the
 interface  to  the liquid  phase.   This step is extremely rapid  once  the gas
                                   4-4

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 molecules (pollutant) arrive at the interface area.  In the third step,
 the gas diffuses into the bulk area of the liquid, thus making room for
 additional gas molecules to be absorbed.  The rate of absorption (mass
 transfer of the pollutant from the gas phase to the liquid phase) depends
 on the diffusion rates of the pollutant in the gas phase (first step) and
 in the liquid phase (third step).   For HF, which is highly soluble, the
 rate is gas-phase controlled.  For the less soluble S02, the rate is
 liquid-phase controlled and depends on the reaction rate of S02 with lime
 to form calcium sulfate.
      The following design factors  enhance gas diffusion, and,  therefore,
 absorption:
      1.  Large interfacial  contact area between the gas and liquid  phases;
      2.  Good mixing  of the gas and liquid phases  (turbulence); and
      3.  Sufficient residence or contact time between  the  phases  for
 absorption to occur.
      An important  factor  affecting the amount of a pollutant that can be
 absorbed  is  its  solubility.   Solubility governs  the amount  of  liquid (L/G
 ratio)  required  and the necessary  contact  time.  More  soluble  gases  (such
 as  HF)  require  less liquid.   Also,  more soluble  gases will  be  absorbed
 faster.   Solubility is a  function  of temperature.   As temperature
 increases, the amount of  gas  that  can  be absorbed  by a  liquid  decreases.
 The  solubility and  gas scrubbing efficiency also are affected  by  the pH  of
 the  scrubbing liquor.  Plant  personnel  indicate that for S02,  efficiency
 increases monotonically with  the pH of  the scrubbing liquor (i.e., an
 increase of pH will increase  scrubber efficiency).   However, for HF, the
 optimal scrubbing efficiency  is achieved at a pH of about 7.5  to 8.0, and
 higher pH levels result in significant decreases in efficiency.  The pH in
 the spray towers at the elemental phosphorus plants in Tennessee generally
 is maintained in the range of 7.5 to 8.O.3  Personnel at the western
elemental phosphorus plants indicated that the characteristics  of their PM
and water necessitate  maintenance of pH in the range of 4.5 to  5.0 to
inhibit precipitation  and  scaling in the scrubbing  system.7
                                   4-5

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4.1.2  Venturi Scrubbers
     A venturi scrubber is a high-efficiency PM control device  that
enhances particle collection by generating high-velocity,  turbulent  flow
conditions  in the gas stream.  A venturi scrubber consists of three
sections—a converging section, a throat section, and a diverging  section
as shown in Figure 4-2.   The exhaust stream enters the converging
section, and gas velocity and turbulence increase.  Liquid is introduced
either at the throat or at the entrance to the converging section.   In  the
throat, the gas stream is mixed with the droplets that are sheared from
the walls, and gaseous and particulate pollutants are transferred  from  the
gas stream to these droplets.  The exhaust stream then exits through the
diverging section.  Venturis can be used to collect both particulate and
gaseous pollutants, but they are more effective in removing particles than
in removing gaseous pollutants.
     Liquid can be injected at the converging section or at the throat.
Figure 4-3 shows liquid injected at the converging section.  Because this
type of venturi provides a liquid coat on the throat surface, it is very
effective for handling hot, dry exhaust gases that contain dusts that tend
to cake on or abrade a dry throat.   Generally,  this wet throat approach  is
more appropriate for application to elemental  phosphorus kiln or calciner
operations for two reasons.  First, because the gas stream contains high
concentrations of HF and S02, the wetting/drying phenomena that  occurs at
the throat in dry throat applications can result in increased corrosion.
Second, the PM in these exhaust streams  has a tendency to  scale, and  this
scaling is enhanced in a dry throat.   Consequently,  the wetted throat has
fewer operation and maintenance problems and  achieves  better  long-term
performance than the dry throat.
     Manufacturers have developed modifications to  the basic  venturi
design to maintain scrubber efficiency by changing  the pressure  drop  for
varying exhaust gas rates.   One particular  development is  the annular-
orifice,  or adjustable-throat,  venturi scrubber (Figure  4-4).  The  throat
area is varied by moving  a  plunger, or adjustable disk,  up  or down  in the
throat, decreasing or increasing  the  annular opening.  Gas  flows through
the annular opening and atomizes  liquid  that  is  sprayed  onto  the plunger
or swirled in from the top.   One  of the  two venturi  scrubbers  installed  at
                                   4-6

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                                 Converging
                                   section

                               - Throat
                               _ Diverging
                                   section
Figure 4-2.  Venturi scrubber.1
                4-7

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Liquid
 inlet
Liquid
 inlet
       Figure 4-3.  Wetted-throat venturi  scrubber.1,
                             4-8

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  Liquid inlet
Figure 4-4.   Adjustable-throat venturi scrubber.1
                        4-9

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elemental phosphorus plants is a movable throat  venturi.   The  other is a
fixed-throat, tandem-nozzle unit.
     Venturis are the scrubbers used most commonly  at  elemental  phosphorous
plants and are capable of achieving the high particle  collection effi-
ciency.  As the exhaust stream enters the throat, its  velocity increases
greatly, resulting in droplet atomization and turbulent mixing of the  gas
with any liquid present.  Particulate matter in  the gas is collected in
these droplets, primarily by impaction.  These liquid  droplets then are
removed from the scrubber exhaust stream by cyclonic separators  or chevron-
blade mist eliminators.
     Particle removal efficiency increases with  increasing pressure drop
(resulting in high gas velocity and turbulence.)  Venturis can be  operated
with pressure drops ranging from 1 to 25 kPa (5  to 100 in. w.c.).   Venturi
scrubbers that operate with pressure drops of less than 12.5 kPa  (50 in.
w.c.) have been installed on nodulizing kilns.   At these pressure  drops,
the gas velocity in the throat section is usually between 30 and  120 m/s
(100 and 400 ft/s).  An increase in pressure drop increases operating
costs because of the energy required by the fan  to remove the  large air
volumes from the kilns at higher static pressures.  It also increases
capital cost because thicker construction materials are required to handle
the lower static pressures in the ductwork.
     The liquid injection rate,  or L/G ratio, also affects particle
collection.  The L/G ratio depends on the temperature (evaporation  losses)
of the incoming exhaust stream and the particle concentration.   Most
venturi systems operate with an  L/G ratio of 0.4 to  1.3 z/m3  (3 to
10 gal/1,000 ft3).   Liquid-to-gas ratios less than 0.4 z/m3
(3 gal/1,000 ft3)  are usually not sufficient to cover the  throat, and  add-
ing more than 1.3  z/m3  (10 gal/1,000 ft3)  does  not usually significantly
improve particle collection efficiency.    The two operating venturi
scrubbers in the elemental phosphorus  industry  have  L/G ratios  of about
0.8 z/m3 (6 gal/1
4.1.3  Wet ESP's
0.8 z/m3 (6 gal/1,000 ft3)  and  2.4  z/m3  (18  gal/1,000 ft3).
     Electrostatic precipitators  are  high-efficiency PM collection  devices
that have been applied widely to  a  variety  of  combustion sources  and
metallurgical furnaces that have  a  wide  range  of combustion  gas
                                   4-10

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   characteristics.  Particle collection is accomplished by exposing  the gas
   stream to a high-energy electrical field which charges particles and moves
   them to an oppositely charged surface (the collection electrode) where
   they are collected.   The primary characteristic that distinguishes wet
   ESP's from dry  ESP's  is the use of liquid flow rather than rapping to
   remove the collected  PM from the collection electrode.   The discussion
   below addresses  only  wet ESP's.
        The basic principles of  the electrostatic precipitation process  are
   (1) development  of a  high-voltage direct  current  that is used to charge
  particles  in the gas  stream,  (2)  development of an electric  field  in  the
  space between the discharge electrode and the  positively charged collec-
  tion electrode that propels the negatively charged ions and particulate
  matter toward the collection electrode, and (3) removal  of the collected
  particulate by use of water flushing.  These basic principles of the
  electrostatic precipitation process are illustrated in Figure 4-5.
       The electrostatic precipitation process occurs within  an enclosed
  chamber; a  high-voltage transformer (to step up the line  voltage) and  a
  rectifier  (to convert  AC voltage to DC) provide the power input.   The
  precipitation chamber  has a  shell  made of  metal, tile, or fiberglass-
  reinforced  plastic (FRP).  Suspended within  this shell are the grounded
  collecting  electrodes  (usually plates), which are connected to the
  grounded steel framework  of the supporting structure and to an earth-
 driven ground.  Suspended between the collection plates are the discharge
 electrodes, also known as corona electrodes,  which  are insulated from the
 ground and negatively charged with voltages ranging from  20  kV to
 100 kV.  The large difference in voltage between the  negatively charged
 discharge electrode and positively charged  collection  electrode creates
 the electric field that drives  the negatively charged  ions and  particles
 toward  the collection electrode.
     The  last segment of  the process covers the  removal of the  dust from
 the collection electrodes.  In wet  ESP's, the collected particulate matter
 is removed by an intermittent or continuous stream of water that flows
down over the collection electrodes and into a receiving sump.   The liquid
from the sump is circulated through a treatment system to  remove suspended
particles and adjust pH.
                                   4-11

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EARTHED  COLLECTOR
ELECTRODE AT
POSITIVE POLARITY
ELECTRICAL   CHARGED
FIELD        PARTICLE
                  DISCHARGE ELECTRODE
                  AT NEGATIVE POLARITY
                                                                   HIGH VOLTAGE
                                                                   CURRENT SUPPLY
        UNCHARGED
        PARTICLES
PARTICLES ATTRACTED
TO COLLECTOR ELECTRODE
AND FORMING DUST LAYER
     Figure 4-5.   Illustration of  ESP operating principles.
                                      4-12

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       The major differences in the types of wet ESP's are the shape of the
  collector, whether treatment of the gas stream is vertical or horizontal,
  whether incoming gas is preconditioned with water sprays, and whether the
  entire ESP is operated wet.   Figures 4-6 and 4-7 show two types of wet
  ESP's, the circular-plate variety and the square or rectangular flat-plate
  type.   One wet ESP currently is installed on one nodulizing kiln.   The ESP
  is  a circular-plate type with a spray tower upstream of  the ESP to
  condition the gas  stream.  Plant personnel  indicated that when  the ESP
  reaches the end of its useful  life,  they probably will install  a flat-
  plate  system because  it is easier to maintain than the circular-plate
  unit.
      The casing can be  constructed of steel  or FRP,  and discharge
  electrodes  can  be  carbon steel,  special  alloys, or  FRP, depending  on the
  corrosiveness of the gas stream.  The  system  that presently is  in  use  has
  FRP plates,  but plant personnel  indicated that these plates have not
  lasted well  in  the cold winter environment in Montana.  However, because
 the kiln exhaust is corrosive and liquid pH must be maintained at 5 or
 less, the plates roust be constructed of FRP or corrosion-resistant  alloys.
      In circular-plate wet ESP's, the circular plates are irrigated
 continuously; this continuous flow provides the electrical ground for
 attracting the particles and  also removes them from the plate.   These
 systems can generally handle  flow rates of 850 to  2,800 m3/min  (30,000  to
 100,000 ftVmin).  Preconditioning sprays remove a significant amount of
 particulate by impaction.   Pressure drop through these units usually
 ranges  from 0.25 to 0.75 kPa  (1  to 3  in.  w.c.).8
      Rectangular flat-plate units operate in  basically the  same manner  as
 the  circular-plate  wet  ESP's.  Water  sprays  in an  inlet plenum or in  an
 upstream spray tower precondition  the  incoming  gas and provide some
 initial  particulate removal.  The water  sprays  are located over the  top of
 the electrostatic fields, and collection plates are irrigated continu-
 ously.  The collected particulate flows downward into a trough that  is
 sloped to a drain.  Typically the water is treated onsite  to remove  the
 suspended solids, and treated  water is recycled to  the system.   Plant
personnel indicated that the water for the ESP currently operating at  an
elemental phosphorous facility is treated to  a pH of  about  5 to prevent
scaling on the plates.7

                                   4-13

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                           CLEAN GAS  <2>  DISCHARGE
HOOD
      ACCESS
      MANWAY
PRECIPITATOR
      HIGH VOLTAGE
      INSULATOR
      PRECIPITATOR
      BASE
      PRECONOITIONER
      SPRAYS
PRECONDITIONER
    GAS INLET


      PRECONOITIONER
      DRAIN
WATER
DISTRIBUTOR
COLLECTION
CYLINDER
                                                          EMITTING
                                                          ELECTRODE
VENTURI/ORAIN
GUTTER
                                                         STRAIGHTENING
                                                         VANES
                                                         ACCESS MANWAY
PREOPITATOR
DRAIN
               Figure 4-6.  Circular-plate  type  wet  ESP.
                                        4-14

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                                          GAS
                                          OUTLET
   HOOD
         PURGE AIR
         MANIFOLD
PRECIPITATOR
 WATER
 DISTRIBUTOR
  ACCESS
  DOOR
  COLLECTING
  PLATE
  EMITTING
  ELECTRODE
 VENTURI/DRAIN
 GUTTER


PRECONDITIONER
ENTRY INLET
    ACCESS
    MANWAV
               GAS DISTRIBUTION
               BAFFLES
        PRECONOITIONER
        DRAIN
                       ACCESS
                       MANWAY
                                                                    HIGH VOLTAGE
                                                                    INSULATOR
                                                                 PRECIPITATOR
                                                                 DRAIN
QUENCH/SCRUBBING
SPRAY
                                                        GAS
                                                        INLET
              Figure  4-7.   Flat-plate type wet  ESP.
                                    4-15

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     The performance of a wet ESP is affected by design and operating
properties of the system as well as flue gas conditions.  Key design
characteristics include the specific collection area (SCA), the aspect
ratio, and gas flow distribution.  Key operating characteristics include
particle size resistivity, temperature, and H20 content of the gas stream.
     The SCA is defined as the ratio of collection surface area to the gas
flow rate into the collector.  Expressed in metric units,
                                                     2
                    era - total collection surface, m            ,-   . .»
                                  1,000 m3/h
     Increases in the SCA of a precipitator design will, in most cases,
increase the collection efficiency of the precipitator.  Most conservative
designs call for an SCA of 20 to 25 m2 per 1,000 m3/h (km3/h) (350 to
400 ft  per 1,000 acfm [kacfm]) to achieve a collection efficiency of more
than 99.5 percent.  The general range of SCA is between 11 and 45 m  per
km3/n (200 and 800 ft2 per kacfm), depending on precipitator design
conditions and desired collection efficiency.8*9  The wet ESP currently
operating on a nodulizing kiln has an SCA of about 9.3 m /knt /h
(170 ftVkacfm).
     The aspect ratio (AR) is the ratio of the effective length to the
effective height of the collector surface.  The AR can be calculated using
Equation 4-2.

                      ap - effective  length, m  (ft)
                      MK " effective  height, m  (ft)

Typical AR's for ESP's range from 0.5 to 2.0.   However,  for high-
efficiency ESP's (those having collection efficiencies  of >99 percent),
the AR used in precipitator design should be greater  than 1.0,  usually 1.0
to 1.5.
     Gas flow through the ESP chamber should be slow  and evenly
distributed through the unit.  The gas velocities  in  the duct leading  into
the ESP are generally between 6 to 24 m/s (20  and  80  ft/s).   The gas
velocity into the ESP must be reduced for adequate particle collection.
This velocity reduction is achieved by using an expansion inlet plenum.
The inlet plenum contains perforated diffuser  plate openings  to distribute
                                   4-16

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  the gas  flow evenly through the precipitator.  Typical gas velocities in
  the ESP  chamber  range from 0.6 to 2.4 m/s (2 to 8 ft/s).  With an aspect
  ratio of 1.5, the  optimum gas velocity is generally between 1.5 to 1.8 m/s
  (5  to 6  ft/s).
      Resistivity is  a measure of how difficult it is for a given particle
  to  conduct electricity.   The higher  the  measured resistivity (the value
  being expressed  in ohm-cm),  the harder it is for the particle to transfer
  the charge.  Resistivity  is  influenced by the chemical  composition of the
  gas stream and PM, the moisture content  of the gas  stream,  and the
  temperature.  Resistivity must  be kept within reasonable  limits for the
  ESP to perform as designed.   The preferred range  is  10a to  1010 ohm-cm.
      Temperature is  important because  it  affects  resistivity  and  because
  it  affects the condensation of  Po-210.  The  use of a  spray  tower  upstream
  from the scrubber will reduce the temperatures of the gas stream  to about
  70°C (150°F)  and condense virtually all of the Po-210 in the gas  stream.
 4.1.4  SD/FF Systems
      The SD/FF system is a multipollutant control system that is used to
 control  PM emissions as well as to reduce the concentrations of acid gases
 in the  stream.   The SD/FF comprises  two primary components—a spray dryer
 or absorber and  a pulse jet fabric filter.  In the spray dryer, the gas
 stream  is cooled, vapor-phase Po-210  and  Pb-210 condense on the surfaces
 of the  PM in  the  gas  stream and  the  lime  that is injected  into the spray
 dryer, and  HF and S02 are  absorbed in the lime slurry.  The  evaporative
 cooling  in  the spray  dryer  results in a dry,  particulate-laden gas
 stream.   The  PM is removed  from  the gas stream in  a pulse  jet  fabric
 filter.   The  paragraphs below  describe  the spray dryer system  and  the
 fabric filter separately.
      In the spray drying process, sorbent  is  injected  into the gas  stream
 as a liquid or liquid  slurry spray with sufficient moisture to promote
 rapid adsorption of the acid gases.  However,  the evaporative cooling of
 the acid gases vaporizes the moisture from the sorbent and produces a dry
 PM which must  be collected.  Systems  that  have been installed on
combustors and furnaces have used varied mechanisms to introduce sorbent
to the gas stream.  Sorbent may be injected through liquid  nozzles or
rotary atomizers.   It may be screw-fed or  pneumatically blown in dry and
                                   4-17

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rewetted by water-only nozzles, or it may be injected wet or dry into a
fluidized bed with overhead water sprays.  The ensuing discussion focuses
upon one of these systems—the atomizing spray dryer absorber—because it
is the most likely to be applied to metallurgical furnaces such as those
in elemental phosphorus plants.
     Figure 4-8 illustrates a typical spray drying process.10  Lime is
slaked, mixed with water, and then pumped as a slurry to a feed tank.
Depending on the inlet concentration of pollutants, slurry is metered into
the spray absorber (shown with a rotary atomizer in Figure 4-8).  Flue gas
heat is sufficient to dry the slurry into a solid powder within the
reactor vessel, and some of the solids are collected in the bottom of the
absorber vessel while the remainder are collected in the particle
collector.  Recycle of solids back to the feed tank may be selected as an
option if sorbent utilization is very low or higher removals of gaseous
pollutants are desired.
     The lime feed rate to the spray dryer affects acid gas removal
efficiencies; it also has a significant impact on cost.  The control  of HF
and S02 are governed by the following chemical  reactions.

                  Ca(OH)2+S02 - CaS03  •  1/2 H20+l/2 H20          (Eq.  4-3)

              CaS03  • 1/2 H20+l/2 02+3/2 H20 * CaSO,, •  2 H20     (Eq.  4-4)

                        Ca(OH)2+2HF * CaF2 • 2  H20               (Eq.  4-5)

Data collected from combustion processes indicate that  acceptable levels
of acid gas control  can be achieved at a 1.5:1  stoichiometric ratio of
lime to HF and S02 combined.   At that stoichiometric ratio,  the
requirements for lime addition are 1.7 kg lime  per kg of S02  and  2.8  kg  of
lime per kg of HF emitted from the kiln.
     Temperatures should be maintained at levels that promote condensation
of volatile metals such as Po-210 and Pb-210 and, at the same time,
prevent liquid condensation.   The control of this process to  achieve
optimal temperatures is relatively simple.   The spray dryer  outlet  flue
gas temperature and  moisture are controlled  to  a narrow range.   Sorbent  is
                                   4-18

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                             1. LIME FEEDER
                             2. LIMESLAKER
                             3. FEEDTANK
                             4. HEAD TANK
                             5. SPRAY ABSORBER
                             6. DUST COLLECTOR
                             7. STACK
                    PARTICLE RECYCLE
                                       DRY WASTE
Figure 4-8.   Spray dryer/fabric filter system.1'
                       4-19

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 thereby  precluded  from contacting  downstream surfaces as a wet powder
 leading  to  solids  buildup.  The  system also  is  operated  well  above the
 dewpoints of any acid  gases.  Temperatures are  typically controlled at
 110°  to  160°C  (230°  to 320°F) by limiting the amount of  water injected.10
      The particulate matter that leaves  the  spray dryer  must  be controlled
 by a  high-efficiency PM collector.  The  control  device typically employed
 on metallurgical furnaces is a fabric  filter.   Generally,  fabric filters
 are classified by  the  type of cleaning mechanism that is used to remove
 the dust from the  bags.  The three types of  units are mechanical  shakers,
 reverse  air, and pulse jet.  Essentially all  fabric  filters that are
 employed with spray  dryers are pulse jet units.   The paragraphs below
 briefly  describe the design and  operating characteristics  of  pulse jet
 filters  and identify key design  parameters for  SD/FF systems.
      A schematic of  a  pulse jet  filter is shown  in Figure  4-9.   Bags in
 the baghouse compartment are supported internally by rings or  cages.   Bags
 are held firmly in place at the  top by clasps and have an  enclosed bottom
 (usually a metal cap).   Dust-laden gas is filtered through the  bag,
 depositing dust on the outside surface of the bag.   Pulse  jet cleaning  is
 used  for cleaning bags  in an exterior filtration  system.
      The dust cake is  removed from the bag by a blast of compressed  air
 injected into the top  of the bag tube.  The blast of  high pressure  air
 stops the normal flow of air through the filter.  The air blast develops
 into  a standing or shock wave that causes the bag to flex or expand as the
 shock wave travels down  the bag tube.   As the bag flexes, the cake
 fractures and deposited  particles are discharged from the bag.  The shock
wave  travels down and back up the tube in approximately 0.5 seconds.
      The blast of compressed air must be strong enough for the shock wave
 to travel the length of  the bag and shatter or crack the  dust cake.  Pulse
 jet units use air supplied from a common header which feeds into a nozzle
 located  above each bag.  In most baghouse designs, a venturi  sealed at the
top of each bag is used  to create a large enough pulse to travel down and
up the bag.  The pressures involved are commonly between  414 kPa and
689 kPa  (60 and 100 psig).   The importance  of the venturi is  being
questioned by some pulse jet baghouse  vendors.  Some baghouses operate
with only the compressed air manifold  above each bag.11
                                   4-20

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                           TUBE SHEET
  CLEAN AIR PLENUM

  PLENUM ACCESS


  BLOW PIPE


  INDUCED FLOW
 BAG CUP & VENTURI
TO CLEAN AIR OUTLET
  AND EXHAUSTER
DIRTY AIR INLET & DIFFUSES
      Figure 4-9.   Pulse-jet fabric filter.2
                          4-21

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     Most pulse jet filters use bag tubes that are 10  to  15 cm  (4  to
6 in.) in diameter.  Typically, the bags are 3.0 to 3.7 m (10 to 12 ft)
long, but they can be as long as 7.6 m (25 ft).    Generally, these bags
are arranged in rows, and the bags are cleaned one row at a time in
sequence.  Cleaning can be initiated by a pressure drop switch, or it may
occur on a timed sequence.
     The key design and operating parameters for a SD/FF  are the air-to-
cloth ratio (or the filtration velocity), the bag material, operating
temperature in the filter, operating pressure drop across  the filter, and
the lime usage rate in the spray dryer.
     The air-to-cloth ratio is actually a measure of the  superficial gas
velocity through the filter medium.  It is a ratio of  the flow rate of gas
through the fabric filter (at actual conditions)  to the area of the bags
and is usually measured in units of m /min  of cloth area  (acfm/ft ).  No
operating data are available for elemental  phosphorus  systems, but
generally, the air-to-cloth ratio on SO/FF systems is  in the range of 1.5
to 3 m3/rain/m2 (5 to 10 acfm/ft2) of bag area.10
     Bag material selection generally is based on prior experience of the
vendor.  Xey factors that generally are considered are:  cleaning method,
abrasiveness of the participate matter and  abrasion resistance of the
material, expected operating temperature, potential chemical  degradation
problems, and cost.  No information was obtained  on types  of material
typically used for metallurgical applications.  However,  given the
temperature and acid gas concentrations in  the nodulizing  kiln exhaust
gases, some type of teflon-coated synthetic material  is likely to be the
material  of choice.
     The operating temperature of the fabric filter is  of  critical
importance.  Since the exhaust gas from nodulizing kilns or calciners  can
contain HF and S02, the unit should be operated at sufficiently  high
temperatures to ensure that no surface temperatures drop below the  acid
dewpoint.  Otherwise,  condensation of acid  gases  will result  in  corrosion
of the housing or bags.  Gas temperatures maintained  at about  150°C
(300°F) ensure that no surfaces are cooled  below  the  dewpoint.   At  the
same time, temperatures should be as low  as  possible  to ensure complete
condensation of Po-210.  Above a maximum  temperature  that  is dependent on
                                   4-22

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  filter type,  bags will degrade or  in  some cases  fail  completely.   Gas
  temperatures  should be kept safely below the  allowed  maximum.   Temperature
  of the inlet  gas to the fabric filter  is maintained at appropriate levels
  by adjusting  the liquid flow rate to the spray dryer.
       Pressure drop in fabric filters generally is maintained within  a
  narrow range.  For pulse jet filters, the upper end of the range typically
  is 2.5 to 3.7 kPa (10 to 15 in. w.c.).   Pressure drops below the minimum
  indicate that either (1)  leaks have developed, or (2)  excessive cleaning
  is removing the base cake from the bags.  Either phenomenon results  in
  reduced performance.   Pressure drops  greater than the  maximum indicate
  that  either (1)  bags  are  "blinding,"  or (2) excessive  cake is building on
  the bags  because of  insufficient  cleaning.  The  primary problem that
  results from excess pressure drop is  reduced flow through  the system and
  positive  pressure in the  kiln.  Over  time, high pressure drops  also lead
  to  bag erosion and degradation.
  4.1.5  HEPA  Filters
      High-efficiency particulate  air filters are commonly used  in
  industries that require high-efficiency removal of particulate matter in
  the submicron  range.  These stringent levels of air cleaning may be
  necessary either to protect human health or to produce  a particulate-free
 work environment.  The HEPA technology is used extensively  in nuclear,
 military,  pharmaceutical,  aerospace, microelectronics,  research, and
 health care applications.
     By definition,  a  HEPA filter  is a throwaway,  extended-pleated-medium,
 dry filter with (1)  a rigid  casing enclosing the full depth  of the pleats,
 (2)  a  minimum particle  removal  efficiency of 99.97  percent  for 0.3-um
 thermally  generated, monodisperse  dioctylphthalate  (OOP) particles,  and
 (3)  a  maximum pressure drop  of 0.25  kPa  (1.0  in. w.c.) when clean and
 operated at rated airflow capacity.12
     Diffusion  and inertia!  impaction are  the primary mechanisms for
 particle collection by HEPA filtration.  The effectiveness of these
mechanisms varies with particle  size, airflow velocity through the medium
and, to some extent,  particle density.   At a constant  air velocity,  the
diffusion mechanism predominates as particle size decreases;  inertia!
impaction accounts for  collection of larger sized particles.   For a given
                                   4-23

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particle size, the effectiveness of diffusion decreases  and  inertia!
collection increases as flow velocity increases.  For  a  given  particle
size and velocity, an increase  in particle density decreases the
effectiveness of diffusion and  increases the effectiveness of  the  inertia!
effect.
     The HEPA filter efficiencies are based on numbers of particles
removed, not on mass removed as is common with air pollution control
devices.  Parameters that are commonly used to describe  HEPA filtration
performance are the efficiency, penetration, and decontamination factor
(OF).  Each of these terms is defined below.

                    Efficiency,  percent  =  (U-0)/U  *  100          (Eq. 4-6)
                    Penetration, percent = (D/U) * 100           (Eq. 4-7)
                       Decontamination factor = U/D              (Eq. 4-8)

where:
     U = upstream particle count
     0 = downstream particle count

The OF is commonly used to compare filter performance because it
demonstrates differences between filter performances more distinctly than
either efficiency or penetration.  For example,  a 99.995 percent efficient
filter (DF=20,000) is twice as effective as a 99.99  percent efficient
filter (DF=10,000), and six times as effective as a  99.97 percent
efficient filter (DF=3,333).
     Within a single filter, performance varies  depending on particle
size.  Lowest removal efficiencies (highest penetration)  occur for
particles in the 0.07- to 0.12-um range (Figure  4-10).   Design
efficiencies are determined by challenging the filter with 0.3 urn
mondispersed OOP particles.  Filters are designed to achieve efficiencies
ranging from 99.97 percent to 99.999 percent for this particle size.
     The properties of a HEPA filter that  are of primary  concern when
designing a system are its particle collection efficiency,  airflow
capacity, and pressure drop.  The HEPA filters are available in a range of
sizes and capacities.  The largest capacity filter available is
                                   4-24

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                           % PENETRATION VS. PARTICLE SIZE
P
E
N
E
T
R
A
T
I
0
N
      10
                   .07
•1                      .2

  PARTICLE SIZE (MICRON)
                                                                   .3    .4
                Figure 4-10.  The HEPA  filter  performance
                            curve.
                                       4-25

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(0.6 m)x(0.6 m)x(0.3 m) ([24 in.]x[24 in.]x[11.5 in.]) and is rated at
57 m3/min (2,000 ft3/nrin) airflow.  To accommodate large airflows,
multiple filters are arranged in banks.  Filters usually are removed and
replaced when the pressure drop across the filter reaches twice the clean
filter pressure drop, i.e., 0.5 kPa (2.0 in. w.c.).
     The environmental conditions to which the filter system will be
exposed must be considered when designing a HEPA filter system.  Key
environmental parameters requiring consideration are temperature,
moisture, corrosion potential, and vibration potential.  The combined
influence of these parameters will affect the selection of a filter for a
particular application.  Unfortunately, the application of HEPA filters to
severe environmental conditions often requires a compromise in filter
properties.  Manufacturers frequently have information on the ability of
components used in the construction of filters to resist chemical or
environmental factors, but the combined effects of humidity, chemical
agents, and heated air upon filters and the interrelationship with the
construction materials are typically unknown.  Destructive environmental
testing is recommended when the suitability of a filter for a specific
environment is in doubt.
     A HEPA filter consists of five components:  the filter medium, the
medium separators (optional), the media-to-frame sealant, the filter
frame, and the filter housing.  Figure 4-11 is a schematic of a typical
filter and arrangement of multiple filters in a filter bank.
     The filter medium may be folded and supported by corroguated metal
separators, typically aluminum, or be preformed and self-supporting.  It
may be composed of asbestos, .cellulose, microglass fibers,  plastics, or
ceramic materials, or blends thereof.   Fire-resistant filter media are
usually composed of fiberglass, sometimes with a small  percentage of
asbestos added to improve resistance to HF, or ceramic material.
Proprietary media designed for enhanced HF resistance are available.  The
HEPA filter media are rated at 100 percent relative humidity conditions
and will tolerate both high humidity and direct wetting.   However, exces-
sive amounts of moisture, either from airborne droplets or  condensation  on
the element can completely plug the filter and result in  failure  by over-
pressure.  The important factors in moisture resistance are the wet
                                   4-26

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                          Fitarfrmw
ClUMIM
                                                  Fittw FnriM
                 Figure 4-11.   Examples  of HEPA filter systems.
12
                                        4-27

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tensile strength of the media, which is related to media rupture under
high overpressure, and its water repellency, which is related to the
plugging that produces the high overpressure.
     The sealant is the most sensitive component of the filter apparatus
with respect to environmental conditions.  The sealant traditionally used
to seal the fiber core into the frame is a heat- and moisture-resistant
elastomeric adhesive.  Commonly used sealants are chemically expanded
self-extinguishing urethane foam; solid urethane; neoprene; or silicone.
Filters that will be operated continuously at high temperatures of about
200°C (400°F) may be sealed with compressed glass-fiber matting,
refractory adhesives, or silicone.  The qualities desirable in a sealant
are (1) moisture and corrosion resistance, (2) ability to withstand
radiation exposure and alternating exposure to heat and cold or dry to
humid air, and (3) maintenance of seal  integrity at design operating
conditions and potential  transient conditions.
     Filter frames are available in a variety of fire-retardant materials
including rigid urethane, 1.9-cm (0.75 in.) exterior grade particle board,
1.9-cm (0.75-in.) plywood, 14 gauge Type 409 or 304 stainless steel, or
zinc or aluminum coated steel.   Metal frames are selected when a high
degree of corrosion resistance is required, or when continuous wetting or
high humidity at high temperatures is expected.  Under these conditions,
wood frames have been found to absorb moisture and swell, rupturing the
filter-to-frame seal  and  permitting filter by-pass to occur.   The sides of
the filter are sealed to  the frame with an appropriate sealant.   When high
sound or vibration levels are expected, wood frames are preferred over
metal ones (other factors being equal)  because of their superior vibration
damping characteristics.
     Prior to operation,  one or more HEPA filters are mounted  into  a
filter housing that consists of the requisite number  of holding  frames to
accommodate the number of filters to be installed.  The housing  typically
is zinc- or aluminum-coated corrosion-resistant steel,  or stainless
steel.  Critical  aspects  of the mounting fixture  are  (1)  the  structural
integrity; (2) tolerances on dimensions,  flatness,  alignment,  and the
finish of the filter  seating surface; (3)  the method  of sealing  the
mounting fixture into the filter housing;  (4)  rigidity  of  filter clamping
devices; and (5)  the  degree and uniformity of filter  gasket  compression.

                                   4-28

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       When a corrosive environment such as that found  in the nodulizing
  kiln exhaust exists, stainless steel is recommended for ductwork and
  filter housings.  Even this material may be insufficient in highly
  corrosive atmospheres, and epoxy- or vinyl-coated stainless steel or
  fiber-reinforced plastics may be necessary.
       In severe applications like those in elemental phosphorus plants, it
  may be necessary to modify and improve the environment to which the system
  will be exposed by pretreating the air prior to entry into the HEPA
  system.  Scrubbers may be employed upstream  to remove corrosive
  constituents  such as inorganic acids.   Consideration must  be given  to
  moisture carryover if wet scrubbers  are used.   Demisting devices  should  be
  added  downstream of wet  scrubbers  to reduce  the moisture content  of the
  gas  stream, and  the gas  stream should be  reheated  to prevent  condensation
  from occurring on  the filter element.   A  prefilter system may  be  added
  upstream of the  HEPA system to  reduce particulate  loading and  increase
  HEPA filter life.   Prefilters  should be provided if  the particulate
  loading exceeds 2.3  mg/m3  (0.001 gr/acf).  The decision to install
  prefilters should be  based on providing the best operational balance
  between HEPA filter  life and capital and maintenance costs for the
 prefilters.  Generally, the use of a prefiltration system will extend HEPA
  life by a factor of 2.  Estimates of filter life for HEPA filters are
 presented as a part of the cost analyses in Section 4.3.
      The principal costs  in operating a  HEPA  filtration system are energy
 costs (i.e.,  fan power),  replacement  filters, and  labor.   The frequency of
 changing the  filters is the primary factor affecting these  costs.  For
 elemental  phosphorus applications,  replacement  filters  and  labor may
 constitute  over 90 percent of the total  cost  of owning  a system (including
 capital  costs) over a 20-year period.
 4.2   PERFORMANCE  OF  ALTERNATIVE  CONTROL  TECHNOLOGIES
     One of the primary objectives of this study is to  assess the ability
 of the alternative control technologies  to reduce Po-210 and Pb-210 emis-
 sions from nodulizing  kiln or calciner operations.  This subsection pre-
 sents available information on the performance of each of the four primary
control  techniques and establishes procedures  for estimating Po-210 and
Pb-210 control  efficiencies for  the  specific control alternatives that are
                                   4-29

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evaluated on a pi ant-by-plant basis  in Section 5.0.   In  general,  these
procedures are based on estimates of overall PM control  efficiencies  or
particle-size-specific control efficiencies.  The Po-210 and  Pb-210
efficiencies then can be estimated on the basis of the Po-210 or  Pb-210
concentrations in the PM or in specific size fractions.  To the degree
that emission data are available, the validity of the estimciting
procedures was evaluated by comparing estimated efficiencies  to measured
control efficiencies.  Each of the four control techniques is addressed in
individual subsections below.
4.2.1  Venturi Scrubbers
     The control efficiency of venturi scrubbers is highly dependent  on
particle size distribution and on the L/G ratio and pressure  drop across
the scrubber.  The penetration across a venturi scrubber (where penetra-
tion is 1 minus control efficiency) for a particle of specific diameter
can be estimated by the following equations which was developed by Yung
and Calvert.1  The equations presented below are used to develop
performance estimates for venturi scrubber control options in Section  5.

                                                       K   °'5
                     4 K  +4.2-5.02 K  o.5(i4M)tan'1
where:
     Pt(dD) = penetration for one particle size
          B = parameter characterizing the liquid-to-gas ratio,
              dimensionless
        Kpo = inertial parameter at throat entrance,  dimensionless

Note:  Equation 4-9 was developed assuming that the venturi  has an
infinite-sized throat length.  This is valid  only when z,  as defined
below, is greater than 2.0.
                                                                  I- 4-10)

where:
      i = throat length parameter,  dimensionless


                                   4-30

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       ir = venturi  throat  length,  cm
       CD = drag  coefficient  for  the  liquid  at  the  throat  entrance,
            dimensionless
       PS = gas density, g/on3
       Dd = droplet diameter, cm
       PI  = liquid density, g/cm3
                               (yHl-a  (L/G)   '                 (Eq. 4-11)
                                 gt
 where:
       Dd = droplet diameter, cm
      vgt = gas velocity in the throat, cm/s
      L/G = liquid-to gas ratio, dimensionless

                               B  = (L/G)  --                    (£q.  4_12)
                                         VD
 where:
        B * parameter characterizing  liquid-to-gas ratio, dimensionless
      L/G = liquid-to-gas ratio,  dimensionless
      PI  = liquid density, g/cm3
      pg  = gas density, g/cm3
      C0  « drag coefficient for the  liquid at the throat entrance,
            dimensionless
                                     dp2  v
                               KPO =  r^aj"                     (EI- 4-i3)

where:
     Kpo * 1nertial  parameter at  the  throat entrance,  dimensionless
      dp = particle  aerodynamic resistance  diameter, cmA
     vgt = gas velocity  in  the throat,  cm/s
      Ug = gas viscosity, g/cm •  s
      dd = droplet diameter,  cm

                              KPO =     d                      (Eq- 4-14)
                                  4-31

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where:
     Kpo = inertia! parameter at the throat entrance, dimensionless
      dpg = particle aerodynamic geometric mean diameter, cmiA
     v j. = gas velocity in the throat, cm/s
      u- = gas viscosity, g/cm • s
      d  = droplet diameter, cm
                       Cn = 0.22 + ir^-ll+O.lSN ' )             (Eq. 4-15)
                        u          NReo        Keo
where:
       CQ = drag coefficient for the liquid at the throat entrance,
            dimensionless
     ^Reo = Reynolds number for the liquid droplet at the throat inlet,
            dimensionless

                               NReQ = ^1                     (Eq> 4.16)

where:
          = Reynolds Number for the liquid at the throat entrance,
            dimensionless
            gas kinematic viscosity, cm /s
      Vgt = gas velocity in the throat, cm/s
       \>g = gas kinematic viscosi
       Dj = droplet diameter, cm

                           dpg = dpg(Cfx*pr-J                  (Eq. 4-17)

where:
                                            0  S
     dp_ = particle aerodynamic geometric mean diameter,
     dps = particle physical,  or Stokes, diameter, pm
      C^ = Cunningham slip correction factor, dimensionless
      pp = particle density, g/cm
                          Cf » 1 +    -d                        (Eq. 4-18)
                                   4-32

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 where:
      Cf  =  Cunningham slip  correction factor,  dimensionless
       T  =  absolute temperature,  K
      dps  =  particle physical,  or  Stokes,  diameter, urn
                               _            AP,l/2
                           vgt    I    (L/G) ^  ]     t

where:
     v_t = gas  velocity  in throat,  cm/s
      AP = pressure  drop,  cm H20
     L/G = volumetric  liquid-to-gas  ratio,  dimensionless

In general, only  the pressure  drop  and L/G ratio were  allowed to vary in
the analyses conducted during  this  study.   All  other values  were held
constant at the following  levels:
     pa = 1,000 kg/m3
     Pg = 1.0 kg/m3
     ug = 2. 0x10" * g/on»s
     \)g = 0.2 cm2/s
     Emission testing was  conducted  recently at  the inlet and  outlet  of  a
high-energy venturi  scrubber at the  Monsanto facility  in Soda  Springs,
Idaho.  The data  in  Section 3.0 indicate that the Po-210 emissions were
measured at 23 nCi/dscm at the inlet and 0.95 nCi/dscm at the  outlet, a
reduction of about 96 percent.   The  particle size distribution estimates
from the 1988 EPA tests at the Monsanto spray tower outlet was used to
estimate the Po-210 control efficiency using the above equations.  The
results, which are tabulated in Table 4-1, estimate that the overall
efficiency of the venturi scrubber in controlling Po-210 would be about
75 percent,  a level that is significantly less than the measured value
obtained by  Monsanto.  Two factors may have contributed to this large
difference as described below.
     First,  the data in Table  4-1 illustrate the sensitivity of these
calculations  to the particle size distribution,  particularly the
distribution  in the submicron fraction.   The particle  size distribution
that  was used for these calculations introduces  uncertainty  to the
                                   4-33

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          TABLE 4-1.  ESTIMATED EFFICIENCY OF MONSANTO SCRUBBER

  Particle diameter
Range
TOTAL
Assumed
 mean
Po-210
fraction
 Fractional
penetration
   Total
penetration


<0.5
0.5-0.9
0.9-1.5
1.5-3
3-10
>10
A

0.35
0.67
1.26
2.12
5.48
10
B
*
0.600
0.265
0.075
0.040
0.018
0.012
C

0.397
0.034
0.0011
0.000097
—
—
BxC

0.238
0.0090
0.00008
0.000004
—
—
                                                 0.25
                                  4-34

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  analyses because the particle size was measured  in the ductwork between
  the spray tower and the venturi.  This high moisture stream from the  spray
  tower is difficult to sample, and the inherent difficulties associated
  with particle size sampling in the high moisture exhaust stream can result
  in significant measurement errors.  If the actual particle size at the
  venturi  inlet is different than that assumed for the calculation,  the
  model  will  produce biased results.
      Second,  the measurements of PM particle size at the  venturi  inlet and
  outlet indicate that  the  efficiency of the venturi  is uniform  overall
  particle size ranges.   In light  of the strong  dependency  of  venturi
  scrubber performance  on particle  size  suggested  by  the performance model
  and  generally supported by other  venturi scrubber test data, this finding
  is quite surprising.  The estimated efficiency of 95  percent or greater  in
  particles less  than 0.5 ym in size  is  particularly  surprising.  Conse-
  quently, the measured efficiency may be biased high and should be used
 with caution.
      In  light the differences in the predicted and measured results at
 Monsanto, analyses based, on a combination of measured performance at
 Monsanto and FMC and estimated performance  based on the  Yung/Calvert model
 were selected for estimating  venturi scrubber performance.   The estimated
 performance  of the Monsanto and FMC is  scrubbers  presented  in Table  4-2.
 The model is well  established  in  the technical  literature  and generally is
 used  by vendors for scrubber design.  Because the  analysis  are  somewhat
 uncertain the  results  presented  in  Section  5  should  be interpreted with
 caution because they are highly sensitive to  particle  size distribution
 and measurement limitations.
 4.2.2   Wet ESP's
     For  applications of ESP's to a specific type of industrial  process
 such as elemental phosphorus nodulizing kilns or calciners, the primary
design factor that affects  ESP performance is the SCA,  which is  a ratio of
the collection plate area to the volumetric  flow through  the ESP.   This
relationship  is incorporated in the Deutsch-Anderson  equation  for  estimat-
ing ESP  efficiency:
                           n = 1-exp [-w(A/Q)J
                                  4-35

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          TABLE 4-2.  ESTIMATES OF VENTURI SCRUBBER PERFORMANCE
Facility
Monsantoa
FMCb

Pressure
drop
High
Maximum0
Typical d
Po-210
Inlet
4,052
1,075
1,075
Outlet
172
1,065
1,208
Pb-210
Inlet
1,280
43.6
43.6
Outlet
40.58
26.1
4.1
Efficiency
Po-210
96
Neg. .
Neg.
Pb-210
97
40
91
^Reference 13.
DReference 14.
Adjustable low-energy throat venturi  scrubber  operated at system maximum
 AP.
Adjustable throat low-energy venturi  scrubber  operated at typical
 operating AP.
                                  4-36

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  where:
       n - collection efficiency of the ESP
       A = collecting plate area, m2
       Q = volumetric gas flow rate, m3/s
       w = migration velocity, m/s

  The equation indicates that ESP collection efficiency increases with
  increasing values of the SCA and the migration velocity.  The migration
  velocity is a function of the characteristics of the emission stream
  (particularly resistivity and particle  size distribution)  and wet ESP
  design  parameters such as electrode  arrangement and field  strengths.
  Mathematically,  the  migration velocity  can  be estimated  as:

                         w « S dp kc (for dp < 5 urn)              (Eq.  4-21)
                                     or
                            w » Sdp (for dp 5 urn)                  (Eq. 4-22)
 with
                                 ,    PECEP
                                 S  =  TT77~                      (Eq. 4-23)
                                   .  and    9
                               kc = 1+0.172/dp                    (Eq. 4.23)

 where:
      kc = Cunninham correction factor,  dimensionless
      dp = particle diameter,  wm
      p = 30/D+2  where  D  is  the dilectric  constant  (generally  about  1 for
           air)
      Ec = charging field  strength, V/m
      Ep = collecting field strength, V/M
      Ug  =  dynamic  viscosity, g/cm-s
      S  =  constant of proportionality

In practice, w is determined empirically based on test data from similar
operations.  For this study,  the data from  the 1983 EPA PM tests at
Stauffer were used to develop estimates  for w.   The procedure is described
below.
                                   4-37

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     The first step in developing size-specific values for w was  to
estimate S, as a constant, based on the measured removal efficiency  for
the smallest fraction of PM at Stauffer.  This constant value  for S  was
then used to estimate size-specific migration velocities using
Equations 4-21, 4-22, and 4-23.  Table 4-3 summarizes the calculations
used to determine S and presents estimates of w for the different size
ranges of Po-210 emissions that were measured by EPA during the 1983 test
program.  These values of w are used to estimate control efficiencies for
the different wet ESP control alternatives presented in Section 5.
     Data from sites other than Stauffer are not available to  assess the
validity of the ESP model.  However, the overall efficiency for Po-210  as
measured by the EPA Method 5 tests at Stauffer was compared to the
predicted efficiency based on the migration velocities reported in
Table 3-2.  The Method 5 tests measured an inlet concentration of Po-210
of 4.88 nCi/dscm and an outlet concentration of 1.61 nCi/dscm, a  reduction
of 67 percent.  The model based on the impactor inlet data also estimated
a 67 percent efficiency.  Consequently, the model  appears to yield
consistent results for Stauffer.   However, data are not available to
determine how well the model  can  be generalized to other facilities  and to
control systems with different design parameters.
4.2.3  SD/FF Systems
     Estimation of the efficiency of SD/FF systems in removing Po-210 and
Pb-210 from the nodulizing kiln/calciner exhaust is much more complicated
than was the case for venturi scrubbers or wet ESP's because information
on the performance of these systems is quite scarce.  Mo specific informa-
tion was found on the removal of  Po or Pb emissions from metallurgical
furnace exhaust streams, and  only limited information was obtained for Pb
removal from combustion gas streams.  Further,  no  general  models are
available on the performance  of fabric filters,  and data are not adequate
to establish the effect of spray  dryers on fabric  filter performance.
Hesketh notes that pulse jet  PM emissions are  unusual  in  that Targe
particles may be released because of the agglomeration  and  the high
cleaning energy.15  Fractional  particle size collection  has  little
practical significance because  size and number  concentrations  change
radically over the filtration/cleaning cycle.   For  any  specific
                                   4-38

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             TABLE 4-3.  SUMMARY OF ESP EFFICIENCY CALCULATIONS

 1.  Key input parameters (from test)

      n = 0.558  .
      Q = 11.35,™ /s
      A = 364 m
      dp = 0.35 um

 2.   Calculate w for d = 0.35 urn

      w = [-ln(l-n)]  Q/A
        = 0.0255 m/s

 3.   Calculate kc  for dp = 0.35 ym

     k_  = 1+0.172/0.35
        = 1.491

4.   Calculate S

    S = w/dpkc = 0.489 m/s-ym

5.  Estimated values of w for different particle size ranges
  range, um

       <0.5
    0.5-0.9
    0.9-1.5
      1.5-3
       3-10
ige,
average. um

  0.35
  0.67
  1.16
  2.12
  5.48
 14
                0.0255
                0.0411
                0.0651
                0.112
                0.268
                0.643
                                  4-39

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application, pulse jet collection efficiency is reported to be a function
of inlet concentration, filtration velocity, pulse intensity, pulse
duration, and pulse form.15  Test data generally show that for a specific
process with fabric filter operating parameters held at steady conditions,
the outlet concentration of a pulse jet filter remains relatively
constant.  Under such conditions, the efficiency of the fabric filter  is
primarily a function of the total inlet concentration.
     The findings described above suggest a procedure for estimating
Po-210 and Pb-210 removal efficiencies for OS/FF systems based on the
following assumptions:
     1.  The PM removal efficiency of a pulse jet fabric filter is not
particle-size dependent;
     2.  At the temperatures achieved in a SD/FF system, essentially all
Pb-210 and Po-210 is in particle form.  Consequently, Po-210 and Pb-210
are removed by the fabric filter at the same efficiency as total PM;
     3.  Pulse jet fabric filters associated with SD/FF systems have been
shown to achieve outlet PM concentrations in the range of 22 mg/dscm
(0.01 gr/dscf) to below 2.2 mg/dscm (0.001 gr/dscf). 10'16  An outlet
concentration of 22 mg/dscm (0.01 gr/dscf) will  provide a conservative
estimate of achievable PM control efficiency; and
     4.  The PM concentration at the inlet to the fabric filter is  a
combination of the solvent/acid gas reaction products and the PM emitted
from the kiln.
     Under the assumptions described above,  the  Po-210 and Pb-210 control
efficiencies can be estimated as follows:

        F , , .  .        Inlet  PM concentration-Outlet PM concentration
        trnciency  =               Inlet RM Concentrat1on
Obviously, no data are available  to  validate this  procedure  for nodulizing
kilns or calciners.  However,  estimates of the  efficiency were  developed
for a "model facility" under the  following set  of  assumptions which are
based on "typical" levels  reported by  elemental  phosphorus facilities.
     SO 2 concentration      1,200 ppmv
     HF concentration       600  ppmv
     PM concentration       4,000 mg/dscm
                                   4-40

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  Under these assumptions, the estimated PM efficiency of the fabric filter
  is 99.87 percent.  Although specific data are not available for metal-
  lurgical furnaces, data from SD/FF systems on municipal combustors
  indicate that efficiencies of about 99.9  percent can be achieved for
  volatile metals such as lead, arsenic,  and cadmium.16
  4.2.4  HEPA Filters
       No data were located  on the performance  of HEPA filters on combustion
  systems or  high-temperature furnaces.   However,  the  fractional  efficiency
  curve in Figure 4-10 indicates  that a minimum efficiency of greater than
  99.998  percent  is achieved  on particles in  the  0.1 to 0.2  urn size  range
  and that efficiencies generally are greater than 99.999 percent.   For  this
  study,  the  overall  efficiency conservatively  was assumed to be
  99.998  percent.
  4.3   COST OF CONTROL TECHNOLOGIES
      The capital  and annualized costs for each of the applicable control
 devices were determined following the guidelines established in Capital
 and Operating Costs of Selected Air Pollution Control Systems (GARD
 Manual) and in the EAB Cost Control Manual. Third Edition. 17»18  These
 manuals were prepared for the U. S. EPA to provide technical assistance to
 regulatory agencies in estimating the cost of  air pollution control
 systems.  The costs in the  GARD  Manual  are based on December 1977 dollars
 and those in the EAB Cost Control  Manual generally are based on  1986
 dollars.  The costs were adjusted  to mid-1988  dollars using indices
 provided in  Chemical  Engineering and by  the  Bureau of Labor Statistics.
 Since  the same basic procedure was  used  to cost  each  of  the control
 techniques,  a cost program was developed for use on a microcomputer.  The
 paragraphs below describe the  general cost methodology and  key assumptions
 that were used to  cost control options.  Detailed assumptions for each
 operating facility are presented in Appendices A through  E.
     The costs were calculated assuming that each of the  fine PM control
measures, with the exception of the SD/FF,  were added  to control  the
exhaust from an existing spray tower.  The  existing system removes most of
the large particles, quenches and cools  the exhaust  gas stream (thus,
reducing gas  volume and ensuring  condensation of gaseous radionuclide
                                   4-41

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 emissions),  and  properly  conditions  the  stream for treatment by the other
 options.
      Capital costs  include  the  direct and  indirect costs  to purchase and
 install the  necessary ductwork,  control  device,  fan systems, and stack.
 Direct capital costs include  instruments,  controls,  taxes,  freight,
 foundations, supports, erection  and  handling,  electrical  work,  piping,
 insulation,  painting, and site preparation.   Indirect capital  costs
 include engineering and supervision, construction  and field expenses,
 construction fee, startup performance test, and  contingencies.   Table  4-4
 presents the assumptions used for direct and  indirect cost  estimates based
 on  information given in the GARD manual.  All  ductwork was  sized based on
 a gas velocity of 20 meters per  second (m/s)  (4,000 ft/min).  Site-
 specific estimates of the length of additional ductwork to  connect  the
 existing control system with the add-on control device were developed  for
 the analyses in Section 5.  Stack diameters were calculated  to  provide a
 stack gas velocity of 18 m/s (3,600 ft/min).  All stack heights  are
 assumed to be 15 m (50 ft) for the add-on equipment.  With  the  exception
 of connecting ductwork, no special retrofit costs were included  in  the
 cost analyses.  Based on information collected during plant  visits, no
 retrofit problems are expected at these facilities.
     Annualized costs include the total  utility costs, the total operating
 labor costs, the total  maintenance costs, the total overhead costs, the
 capital charges, and the total waste disposal  costs.  The  annualized costs
 were based on 8,640 hours per year of operation (360 days).   The utility
 costs reflect actual utility costs in the area of each facility as
 presented in Appendices A through E.   The operating and  maintenance labor
 costs were determined using  an average hourly  wage of $12/hour (h).  The
 operating labor hours per shift  for each  control  device  were 4 h/shift  for
 SD/FF's,  2 h/shift for  scrubbers, and 1  h/shift for ESP's.  The main-
 tenance labor was assumed  to be  1 h/shift for  ESP's and  scrubbers and
 2 h/shift for SD/FF's.
     The  quantity of sludge  or dry waste  collected  by  the  add-on control
devices was determined  based on  the efficiency of particulate removal.   In
the case  of the SD/FF,  the quantity of  lime added to  the system also is
considered.   The cost to dispose  of the waste  in  a  secured landfill  was
                                   4-42

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   TABLE 4-4.   ASSUMPTIONS USED IN ESTIMATING DIRECT AND INDIRECT COSTS3

                                                     ESP       VS       FF

 Direct  costs

   Purchased equipment costs                            .
     TIControl deviceARD      AR       AR
     2.   Auxiliary equipment                          AR       AR       AR
     3.   Instruments and controls                     0.10      0.10     0.10
     4.   Taxes                                        0.03      0.03     0.03
     5.   Freight                                      0.05      0.05     0.05

   Total                                              1.00      1.00     1.00

   Installation direct costs
     TIFoundations and supports                     0.04      0.06     0.04
     2.   Erection and handling                        0.50      0.40     0.50
     3.   Electrical                                   0.08      0.01     0.08
     4.   Piping                                       0.01      0.05     0.01
     5.   Insulation                                   0.02      0.03     0.07
     6.   Painting                                     0.02      0.01     0.02
     7.   Site preparation                             AR        AR        AR
     8.   Facilities and buildings                     AR        AR        AR

  Total                                              1.67      1.56     1.72

 Indirect costs

  Installation indirect costs
1. Engineering and supervision
2. Construction and field expenses
3. Construction fee
4. Startup
5. Performance test
6. Model study
7. Contingencies
Total
0.20
0.20
0.10
0.01
0.01
0.02
0.03
2.24
0.10
0.10
0.10
0.01
0.01
0.02
0.03
1.91
0.10
0.20
0.10
0.01
0.01
0.02
0.03
2.17
aThe numerical  factors are multiplied  by  the  purchased  equipment costs to
.obtain total  costs.
 AR = as required.
                                   4-43

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 assumed  to  be  $20/ton.  The waste  is considered  to be hazardous for these
 calculations because  of the concentration of  radioactive  material.   (For
 comparison, it should be noted that the cost  of  disposing of  nonhazardous
 wastes is approximately $5/ton.)
 4.3.1  Venturi  Scrubber Cost Assumptions
     The capital and  annualized costs for venturi  scrubbers were based on
 procedures  established in the CARD manual and on equipment costs
 established therein.  Because of the large airflow encountered  at most
 kilns, two  identical  scrubber systems in parallel  were costed on one-half
 of the total exhaust  stream.  Radial fans were costed because of their
 ability  to operate at high pressures and temperatures in  an abrasive gas
 stream.  The costs of the starter motor, direct  and V-belt drives,  and
 dampers  are included  in the fan costs.  The corrosiveness (fluorides)  of
 the gas  stream entering a scrubber from the rotary  kiln calciner requires
 that fabricated equipment cost estimates be based on the use of  a
 combination of  Haste!loy and Type 316 stainless  steel.  Plate thickness  of
 the fan  housing and ductwork was determined based on system static
 pressure.  Details on the cost inputs for venturi scrubber control options
 for each facility are presented in Appendices A through E for the
 individual facilities.
 4.3.2  Wet ESP Cost Assumptions
     Capital and annualized costs for the ESP were based on  an EPA cost
 update.19'20  The primary factor, other than SCA, that affects ESP costs
 is material  of construction.   The corrosiveness (fluorides)  of the gas
 stream entering an ESP from the rotary kiln  calciner requires  that
 fabricated equipment the  ductwork and  ESP housing be constructed of a
 corrosion resistant material.   Costs  for these components  were based on
 the use of Type 316 stainless  steel.   Collecting  electrodes  also were
 assumed to be constructed  from Type 316  stainless steel.
4.3.3  SD/FF Cost Assumptions
     Spray dryer/fabric filter systems provide efficient collection  of
both condensible PM and acid gases.  Key  design parameters that  affect
system performance and costs are  lime  addition, gas temperature  entering
the FF, FF air-to-cloth ratio,  and  pressure drop  through the system.   Lime
addition  rates  were calculated  under the  assumption of a 1.5:1
                                   4-44

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   stoichiometric ratio of lime to HF and S02 combined.  The gas temperature
   at the FF inlet was assumed to be 150°C (300'F).  An air-to-cloth ratio of
   1:1.2  m /m3/min (4:1 ft2/ft3/min)  and  a system pressure drop of 3.1 kPa
   (12.5  in.  w.c.)  were used.
       Total direct costs  for the SD/FF  unit were estimated on the basis of
   the cost equation:

                               C-  7.115 Q°-517

  where:
       C = total direct cost, $x!03 in December 1987
       Q = volumetric flow, acfm

  This cost equation  is based on  comprehensive information collected by EPA
  as  a part of  the municipal  waste  combustion study.   Vendors contacted
  during  this study indicated  that these  costs would  provide reasonable
  ±30 percent estimates.
  4.3.4   HEPA Filter Cost Assumptions
      Calciner gas stream characteristics that affect HEPA  filter  design
  and costs are moisture content, inorganic acid content, and loading in the
 gas stream to be treated.  A spray tower is assumed to exist upstream of
 the HEPA filtration  system; the high moisture content of the spray tower
 exit gases requires  treatment of the gases by a demister and reheater
 upstream of the HEPA filter.   These components were  included in the cost
 of the HEPA system.   Because  the exhaust gases are corrosive,  Type 304
 stainless steel  housings  and  filter  frames,  acid-corrosion  resistant
 filter media,  and  vinyl-clad  aluminum  separators  are  included  in  the cost
 of the system  and  replacement  filters  to  provide  the  best available
 corrosion resistance.  Because the PM  loading  in  the gas stream exceeds
 the  recommended maximum of 2.3 mg/m3 (0.001 gr/acf),  the cost of a
 prefiltration system is included in the total system cost.  Estimated
 costs of the HEPA system,  consisting of the prefilters, HEPA filters
prefilter/HEPA filter bank housing,  demister, reheater,  and demister/
reheater housing were obtained from equipment vendors.
                                   4-45

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     A major operating cost for HEPA filters is filter replacement.   The
operating life of a HEPA depends on the increase in pressure drop
resulting from particle collection within the filter media.  A general
guideline used to design filter systems is 4 lb/1,000 ft /min rated
capacity (1.82 kg/1,000 ft3/min).12  Filter life was estimated by assuming
a HEPA capacity of 7.9 lb/1,000 ft3/min (3.6 kg/1,000 ft3/min) per filter
based on vendor information.21  The methodology used to estimate filter
life consisted of the following steps:
     1.  Obtain particle size distribution in spray tower exit gas stream
from test data (where available);
     2.  Predict the mass of particles removed by prefiltration using
design prefilter removal efficiencies for a given particle size;
     3.  Predict mass of particles removed by HEPA filter using filter
design HEPA removal  efficiencies;
     4.  Assume a filter capacity for HEPA filter and calculate HEPA
filter operating life with and without use of a prefilter;
     5.  Calculate prefilter life as two times the HEPA filter life
without the use of a prefliter; and
     6.  Calculate HEPA filter life as the HEPA capacity divided by the
particulate loading  rate into the HEPA filter.
     Estimation of the labor cost to replace prefliters and HEPA filters
as they are exhausted is based on 0.25 hours of labor per filter per
replacement cycle.   For example,  filter replacement for a 36 filter bank
requires 9 hours.
     Exhausted filters are expected to exhibit  increased concentrations of
particulate matter containing Po-210 and Pb-210.   To reduce the  risk  of
inhalation of particles that may  become airborne  as a result of  filter
handling during the  replacement process, an  automatic bagout containment
system is included  in the system  cost.   Automatic  bagout  facilitates
removal of exhausted filters without direct  operator contact.  Heavy  duty
PVC bags are installed inside the filter housing  between  the filters  and
the housing access door.   When the door is opened,  the  bags form  a  barrier
between the operator and  the contaminated filter.   By working through the
bag, the operator  can remove the  filter and  draw  it into  the bag  without
direct contact. The cost of replacement bags was  included  in the estimate
of replacement material  cost.

                                   4-46

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  4.4   REFERENCES FOR SECTION  4

   1.   Joseph, G., and D. Beachler, APTI Course SI:412C Wet  Scrubber  Plan
       Review.  U. S. Environmental Protection Agency.  Research  Triangle
       Park, N.C.  Publication No. EPA 450/2-82-020.  March  1984.

   2.   Memo and attachments from Wallace, D. and K. Leeds, Midwest Research
       Institute, to Beck, L., EPA/ISB.  August 9, 1988.  Site Visit—
       Monsanto Elemental Phosphorus Plant, Soda Springs, Idaho.

   3.   Memo and attachments from Wallace, D. and J. Obremski, Midwest
       Research Institute, to Beck, L., EPA/ISB.  August 23, 1988.  Site
       Visit— Stauffer Elemental  Phosphorus Plant, Mount Pleasant,
       Tennessee.

  4.  Schifftner,  K. and H.  Hesketh.   Wet Scrubbers,  A Practical
      Handbook.   Chelsea, Lewis  Publishers, Inc.   1986.

  5,  U. S.  Environmental Protection  Agency.   Control Techniques  for
      Particulate  Emissions  from Stationary Sources— Volume I.   Publication
      No.  EPA-450/3-81-005a.   Research Triangle Park, N.C.   September 1982.

  6.  Reference  was  eliminated to  prevent  disclosure  of  CBI  data.

  7.  Memo and attachments from  Wallace, D.  and J. Obremski, Midwest
      Research Institute, to Beck, L.,  EPA/ISB.  August 9,  1988.  Site
      Visit— Stauffer Elemental  Phosphorus  Plant, Silver Bow, Montana.

  8.   U. S. Environmental Protection Agency.  Operation and  Maintenance
      Manual for Electrostatic Precipitators.  Publication
      No.  EPA/625-1-85/017.  Research Triangle Park,  N.C.  September  1985.

  9.   Beachler, D., APTI Course SI:412B, Electrostatic Precipitator Plan
      Review.  Prepared for U. S. Environmental Protection Agency.
      Research Triangle Park, N.C.  Publication No. EPA 450/2-82-019.
      
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13.  Radian Corporation.  Draft Final Emission Test Report.  Monsanto
     Elemental Phosphorus Plant, Soda Springs, Idaho.  Prepared  for  U.  S.
     Environmental Protection Agency under Contract No. 68-02-4338.
     Research Triangle Park, North Carolina.  October 1988.

14.  Radian Corporation.  Draft Final Emission Test Report.  FMC Elemental
     Phosphorus Plant, Pocatello, Idaho.  Prepared for U. S. Environmental
     Protection Agency under Contract No. 68-02-4338. Research Triangle
     Park, North Carolina.  October 1988.

15.  Hesketh, H.  Air Pollution Control.  Ann Arbor, Ann Arbor Science.
     1981.

16.  Environment Canada.  The National  Incinerator Testing and Education
     Program:  Air Pollution Control  Technology,  Report EPS 3/UP/2.
     Ottawa, Ontario.  September 1986.

17.  GARD, Inc.  Capital and Operating  Costs of Selected Air Pollution
     Control Systems.  Prepared for U.  S. Environmental  Protection
     Agency.  Research Triangle Park, N.C.  Publication
     No. EPA 450/5-80-002.  December  1978.

18.  U. S. Environmental Protection Agency.   EAB  Control  Cost Manual,
     Third Edition.  Publication No.  EPA 450/5-87-001A.   Research Triangle
     Park, N.C.  February 1987.

19.  Turner, J. H. et al.  Sizing and Costing of  Electrostatic
     Precipitators.  Part I.   Sizing  Considerations.   Journal  of the Air
     Pollution Control Association.   38(4):458-421.

20.  Turner, J. H. et al.  Sizing and Costing of  Electrostatic
     Precipitators.  Part II.   Costing  Considerations.   Journal  of the Air
     Pollution Control Association.   38(5):715-726.

21.  Telecon.   Allen, K., Midwest Research Institute,  with  Clark, R.,
     Environmental Product Sales,  Inc.,  Raleigh,  N.C.  August  12, 1988.
                                  4-48

-------
                 5.0   CONTROL ALTERNATIVE  PERFORMANCE AND COST

        Information  on the feasibility,  performance,  and costs of alternative
   emission control  techniques for  elemental  phosphorus process calciners and
   nodullzing kilns  is  needed to assess  potential  regulatory limits for
   Po-210 and Pb-210 emissions.  This section defines  viable control
   alternatives and presents information on the performance  and capital  and
   annualIzed costs of  those alternatives for each of  the  five  operating
   facilities.  Nationwide reductions in Po-210 and Pb-210 emissions also are
   estimated, and total nationwide capital and annualized cost  estimates are
   presented.   The results presented in this section are based  on the
  emission data presented in Section 3.0 and  the performance and cost
  estimation  procedures presented  in Section  4.0 for different control
  technologies.
  5.1  DEFINITION OF CONTROL ALTERNATIVES
       As outlined in  Section 4, four fine  PM control  techniques were
  identified as having  potential for control of Po-210 and Pb-210 emissions
  from  caldners-venturi  scrubbers, wet electrostatic precipitators
  (ESP's), spray dryers with pulse jet fabric filters  (SD/FF's)  and high
  energy particulate air (HEPA)  filters.  Ten different control  alternatives
  based on these four technologies  were examined.  Four of the  alternatives
  are based on venturi  scrubbers  at different  pressure drops (AP's)   four
  are based on wet ESP's with different  specific collecting areas (SCA's)
 and one each  is  based on a SD/FF  system and  a  HEPA filter system   The '
 paragraphs below describe the control  alternatives  and the  assumptions
 that were used to assess  performance and cost  of  these systems.
     Four of the control  alternatives comprise venturi  scrubbers operated
 downstream from a spray tower.  Four different pressure drops  were
 examined-2.5 kPa (10  in. w.c.), 6.2 kPa (25 in. w.c.), 10  kPa (40 in
 «.c.), and 20 kPa (80  in. w.c.).  The values  from 2.5 kPa to 10  kPa
 represent the range of AP's for  venturi scrubbers at recently  installed
 control systems on  elemental phosphorus plant calcining operations.  The
 20 kPa level  was  selected as a control  alternative that is more stringent
 than the controls typically used in the  industry,  but  that has  been
applied to other  metallurgical processing facilities.   Two other
                                   5-1

-------
 assumptions  were made  in  evaluating  the  performance and costs of the
 venturi  scrubber control  alternatives.   First,  a spray tower was assumed
 to  be used upstream  from  the  venturi  to  control  acid gases and condition
 the gas  stream  for the  venturi.  All  of  the  operating facilities except
 FMC currently have a spray tower as  a part of their control  system that is
 assumed  to be useable as  the  conditioning system for the venturi.  Second,
 for all  the  venturi  scrubber  control  alternatives,  the L/G ratio was
 assumed  to be 1.3 a/m3  (10 gal/1,000  ft3).   This value was selected
 because  it represents the upper end of the range typically found in
 venturi  scrubber applications.  A cyclonic mist  eliminator also was
 assumed  for  all venturi scrubber alternatives.   Note that  although FMC
 does not have a spray tower in their  systems, no tower was costed for this
 study.   The  low energy  scrubber that  FMC has in  place as assumed to
 provide  coarse PM control and gas conditioning.
     The four ESP control alternatives that were considered  comprised
 spray towers for acid gas control and gas stream conditioning  followed by
 flat-plate wet ESP's.  The four SCA levels that  were  considered  were
 39.4 (m/s)-1 (200 ft'/kacfm), 78.8 (m/s)'1 (400  ftz/kacfm),  118  (m/s)'1
 (600 ftVkacfm), and 158 (m/s)-1 (800 ftVkacfm).  These four  SCA levels
 are higher than the SCA at the one wet ESP that  is applied to  a  nodulizing
 kiln.  However, that unit is an older unit with  relatively low PM removal
 efficiency.  The range of 39.4 to 158 (m/s)"1 (220 to 800 ft:i/kacfm)  is
 representative of the SCA levels typically found on metallurgical  and
 mineral  processing facilities.  The spray tower upstream from  the  ESP  will
 remove acid gases from the gas stream and reduce the temperature  to  65° to
 70°C (150° to 160°F)  to assure that the  Po-210  and Pb-210 are condensed
 before they enter the ESP.
     The ninth control  alternative  is the SD/FF  control system described
 in Section 4.1.4.   For this  alternative,  the  exhaust stream is vented
 directly to the spray dryer  without pretreatment.  No SD/FF systems have
 been applied to elemental  phosphorus  facilities.   However,  they were
 selected as a stringent control  technique because they have been
 demonstrated to control  acid  gases  and condensation PM in other
metallurgical and  mineral  processing  operations  such as aluminum reduction
 and glass manufacturing.  Key  assumptions that were made to estimate
                                   5-2

-------
  performance and cost are that sufficient moisture will be added  to reduce
  gas temperature to 120°C (250°F) at the inlet to the FF, that  lime will be
  added at a 1.5 stoichiometric ratio for HF and S02 combined, and that a
  pulse jet fabric filter capable of maintaining an outlet grain loading of
  0.023 g/dscm (0.01 gr/dscf)  will be installed.
       The final  control  alternative comprises a spray tower scrubber,  a
  reheat system,  a prefilter,  and a HEPA filter in sequence.   The spray
  tower is used  to reduce the  acid content  of  the gas  stream and to remove
  larger sized PM.   The reheat system is needed to raise  the  gas stream
  temperature  sufficiently to  prevent condensation of  moisture  and  inorganic
  acids  in the HEPA  filter.  The  prefilter  is  used to  reduce  the PM loading
  to  the HEPA filter and  thereby  extend  its  life.   The HEPA filter  system
  has not  been applied to  elemental phosphorus  facilities and generally is
  not applied to furnaces  that generate  gas volumes as large as  those
  generated by elemental phosphorus process calciners or nodulizing kilns.
  However, the system was  selected for consideration because HEPA filters
  have been used successfully to control radionuclide emissions from uranium
 processing facilities and they do provide a much greater level of control
 than is provided by the  other control alternatives.
 5.2  PERFORMANCE OF CONTROL ALTERNATIVES
      The performance  of  each  of  the 10 control alternatives  was calculated
 based  on the  reduction from baseline emissions that could  be achieved  by
 application of  the  control  alternative. For  each control  alternative  and
 each operating  facility,  annual  emissions of  Po-210 and  Pb-210  were
 estimated using  the procedures described in Section 4.   These estimated
 emission  levels were compared to  the  baseline  emission estimates that  are
 presented  in Table 3-9 to determine achievable emission reductions.
     Performance models for venturi scrubbers and wet ESP's are presented
 in Sections 4.2.1 and 4.2.2, respectively.   Application of these models
requires information on the emission rate of Po-210 and Pb-210 at the
venturi and ESP inlet and on the  particle size distribution of these
emissions.  The  estimates of Po-210 and Pb-210 emission  rates at the
                                   5-3

-------
scrubber/ESP inlet, based on the assumptions that a spray tower is located
upstream from primary control device are:
                               Emissions, Ci/yr
     Facility                Po-210         Pb-210
     FMC                      10             0.14
     Monsanto                 30             9.5
     Stauffer, Montana        2.4            0.32
     Stauffer, Tennessee      0.28           0.058
     Occidental               0.31           0.064
The estimates for FMC, Monsanto, and Stauffer, Montana, are based on tests
conducted by EPA in 1983 and 1988 that measured emissions at the outlet of
low-energy scrubbers at those facilities.1"3  Because the control systems
at the two Tennessee plants consist of spray tower scrubbers,, the emission
estimates for those two facilities are based on the baseline emissions
from those facilities that were presented in Table 3-9.  Estimates of the
particle size distribution for these emissions are presented in Table 5-1.
Separate estimates were developed for moving grate calciners (FMC) and
rotary kilns (all other facilities).
     The performance models presented in Chapter 4 and available test data
were used to develop estimates of the fractional efficiencies that could
be achieved by the venturi scrubber and wet ESP control alternatives for
the six particle size fractions identified in Table 5-1.   The results of
the model calculations are presented in Table 5-2 for the four venturi
scrubber alternatives and in Table 5-3 for wet ESP's.  Generally, the
models indicated that all of the control measures are relatively effective
in removing particles greater than 1 ym in diameter.   However, only the
high efficiency systems (venturi scrubbers with AP's  of 10 kPa or greater
and wet ESP's with an SCA of 78.8 (m/s)'1) are effective  in controlling
particles less than 1 ym in diameter, which is the size fraction in which
the Po-210 and Pb-210 are concentrated.
     Because the model results and test results agreed well for wet ESP's,
the fractional efficiencies presented in Table 5-3, the particle size
distributions presented in Table 5-1, and the estimated annual inlet
emission rates presented above were used directly to  estimate annual
Po-210 and Pb-210 emission rates.
                                    5-4

-------
      TABLE 5-1.  PARTICLE SIZE DISTRIBUTIONS FOR Po-210 AND Pb-210a
Po-210
Particle
Range
<0.5
0.5-0.9
0.9-1.5
1.5-3
3-10
>10
size, vm
Median
3.5
0.67
1.16
2.12
5.48
14
Moving
grate8
76.0
4.0
3.8
2.8
3.7
9.6
Rotary
kilnc
52.2
21.6
12.9
8.9
3.4
1.0
Pb-210
Moving
grate6
36.5
17.7
11.5
8.8
13.2
12.3
Rotary
ki1nc
60.0
18.1
14.3
5.2
2.0
0.4
dAssumed to be at the outlet to a spray tower upstream from the high-
 efficiency PM collector.
"Based on size distribution at the FMC slinger scrubber outlet.
cBased on size distribution at outlet from spray tower at Stauffer.
                                   5-5

-------
TABLE 5-2.  ESTIMATED FRACTIONAL EFFICIENCIES FOR VENTURI SCRUBBER
                      CONTROL ALTERNATIVES
Fractional efficiencies
Particle size, urn
Range
<0.5
0.5-0.9
0.9-1.5
1.5-3
3-10
>10
Median
3.5
0.67
1.16
2.12
5.48
14
AP (kPa)
= 2.5
10.0
49.9
86.5
98.1
99.8
>99.9
6.2
31.2
80.6
96.8
99.5
99.9
>99.9
10
46.9
89.7
98.5
99.8
>99.9
>99.9
20
69.9
96.5
99.5
99.9
>99.9
>99.9

-------
TABLE 5-3.  ESTIMATED FRACTIONAL EFFICIENCIES FOR WET ESP
                  CONTROL ALTERNATIVES
                       5-7

-------
     As discussed in Section 4.3, the measured efficiencies for Po-210 and
Pb-210 at Monsanto were significantly higher than the efficiencies
estimated by the scrubber model.  Consequently, the estimated scrubber
efficiencies estimated by the model were adjusted to compensate for the
apparent low bias of the model.  Table 5-4 presents the estimates of
scrubber performance for the four control alternatives for Po-210 and
Pb-210 for rotary kiln and moving grate calciners.  The left half of this
table presents the modeled results based on the data presented in
Tables 5-1 and 5-2.  The right half of the table presents the adjusted
results.  The basis for these adjusted results and the calculation
procedures are documented in Reference 4.
     The adjusted efficiencies presented in Table 5-4 were applied to the
emission rates presented above to estimate controlled emissions under each
of the four venturi scrubber options.  The results are presented in
Tables 5-5 and 5-6.  These emission rates presented in Tables 5-5 and 5-6
were compared to the baseline emission rates presented in Table 3-7, and
emission reductions were calculated.  These results are presented in
Table 5-7 for Po-210 and 5-8 for Pb-210.
     Control efficiencies also were developed for the SO/FF and the HEPA
using the procedures described in Section 4.2.  Efficiencies for the SO/FF
system were calculated based on an assumed outlet loading of 0.023 g/dscm
(0.01 gr/dscf) and estimated inlet loadings of 13 g/dscm (5.7 gr/dscf) for
rotary kilns and 15 g/dscm  (6.7 gr/dscf) for moving grate calciners.
These inlet loading estimates are based on the uncontrolled PM emission
rates measured at FMC and Stauffer in 1984 and the quantity of lime added
to the system to control S02 at concentrations of 500 ppmv and HF at
1,500 ppmv.1*3  The resultant efficiencies are 99.82 percent for rotary
kilns and 99.85 percent for moving grates.  For the HEPA filter, the
efficiency was assumed to be 99.998 percent as described in Section 4.2.4.
     The estimated efficiencies defined above then were used to estimate
Po-210 and Pb-210 emissions for each of the five operating facilities.
Since the HEPA filter is installed downstream from a spray tower, the
emission rates presented above were used as "uncontrolled" emission
rates.  The SD/FF system does not  include a spray tower.  Consequently,
"uncontrolled" emissions were estimated using the spray tower outlet rates
defined  above and the assumption that the spray tower is almost 65 percent

                                    5-8

-------
                      TABLE  5-5.
        Control alternative
        Wet scrubber
          AP = 2.5 kPa
          AP = 6.2 kPa
          AP = 10 kPa
          AP = 20 kPa
ESP
SCA =
SCA =
SCA =
SCA =
39.4 (m/s)-
78.8 (m/s);
118 (m/s)-
158 (m/s)-1
en
I
O
Spray dryer/fabric filter

HEPA filter
                                           Po-210 EMISSION LEVELS ACHIEVED BY CONTROL ALTERKATIVES
                                                                 Emission  levels.  Ci/vr
                                                                           Stauffer
                                              8.0
                                              4.0
                                              2.0
                                              1.0
                                                     2.9
                                                     1.0
                                                     0.38
                                                     0.14
21
14
 3.0
 1.5
                                                         7.4
                                                         2.4
                                                         0.84
                                                         0.29
1.5
1.1
0.24
0.12
              0.59
              0.19
              0.07
              0.02

              0.012

            <0.001
0.20
0.13
0.028
0.014
            0.07
            0.02
            0.01
           <0.01
                                                                                         0.001
                                                                                                      Occidental
0.22
0.14
0.031
0.016
               0.08
               0.02
               0.01
              <0.01
                           0.002
                                                                                                       <0.001

-------
TABLE 5-6.  ESTIMATED Pb-210 EMISSION LEVELS ACHIEVED BY CONTROL ALTERNATIVES
Emission levels, mC1/yr
Control alternative
Wet scrubber
AP = 2.5 kPa
AP = 6.2 kPa
AP = 10 kPa
AP = 20 kPa
ESP
SCA = 39.4 (m/s) ,
SCA = 78.8 (m/s)7
SCA = 118 (m/sr
SCA = 158 (m/s)
Spray dryer/fabric filter
HEPA filter
FMC

70
28
9.8
5.6

25
8.0
2.8
1.0
0.6
0.003
Monsanto

6,600
2,800
950
480

2,500
840
290
100
49
0.019

Stauffer
Montana Tennessee

220
96
32
16

85
2.8
9.6
3.5
1.6
<0.01

41
17
5.8
2.9

15
5.1
1.7
0.64
0.29
<0.01
Occidental

45
19
6.4
3.2

17
5.6
1.9
A * ^
0.70
0.32
<0.01

-------
                                 TABLE  5-7
CJl
I
IX)
        Wet scrubber
          AP = 2.5 kPa
          AP = 6.2 kPa
          AP = 10 kPa
          AP = 20 kPa
        ESP
          SCA
          SCA
          SCA
39.4 (m/s)-1
78.8 (m/s)-1
1 1 O /_ / \ — 1
                        2.0
                        6.0
                        8.0
                        9.0
a
a
a
a
a
a
0.5
0.62
0.08
0.15
0.25
0.27
0.09
0.17
0.28
0.29
 2.2
 6.3
 9.0
10.2

-------
                        TABLE 5-8.  REDUCTION OF Pb-210 EMISSIONS FROM BASELINE
Emission reduction. mC1/yr
Control alternative
Wet scrubber
AP = 2.5 kPa
AP = 6.2 kPa
AP = 10 kPa
AP = 20 kPa
ESP
SCA =39.4 (m/s).
SCA = 78.8 (m/s).
SCA = 118 (m/s)-
SCA = 158 (m/s)
SD/FF
HE PA
FMC

70
110
130
130

120
130
140
140
140
140
Stauffer
Monsanto

a
a
a
a

a
a
50
240
290
340
Montana

a
14
78
94

25
82
100
110
110
110
Tennessee

17
41
52
55

43
53
56
57
58
58
Occidental

19
45
58
61

47
58
62
63
64
64
Total

110
210
320
340

240
320
410
610
660
710
aBase!1ne control results 1n lower emissions  than those  achievable  by  this  control  option

-------
  efficient  in  removing  Po-210  and  Pb-210 from the exhaust stream   This
  65 percent efficiency  estimate  is  based on  the  performance measured by EPA
  at Stauffer.   The resulting  emission  estimates  are  presented  in
  Tables 5-5 and 5-6 for Po-210 and  Pb-210, respectively.   The reductions
  from baseline are presented in Tables  5-7 and 5-8.   Both  of these  control
  alternatives achieve a significant reduction in emissions  beyond those
 that are estimated for venturi scrubbers and wet ESP's.
 5.3  COSTS OF CONTROL ALTERNATIVES
      Capital  and  annualized costs  for each of the 10 control alternatives
 evaluated were developed  using the procedures described in Section 4 3
 Nationwide  and plant  specific  capital  and annualized  cost summaries for
 each  control alternative  are presented  in Tables  5-9  and  5-10,  respec-
 tively.   Nationwide capital and annualized costs  for  the  10 control
 alternatives are compared graphically  in  Figures  5-1  and  5-2.   A  more
 detailed  breakdown of costs for each alternative  is presented in
Tables 5-11 through 5-20.   Details on the cost inputs for the venturi
scrubber, wet wall ESP,  SD/FF,  and HEPA filter system for each facility
are presented in Appendices  A through E.
                                 5-14

-------
                           TABLE 5-9.  CAPITAL COST OF CONTROL ALTERNATIVES
                                        (Rounded  Cost,  1988  $)
Control
1.

2.

3.
4.
=^=
a..

FMC

Monsanto
Plant
Occidental

Stauffer,
Montana

Stauffer,
Tennessee
Total
Venturi scrubber
10 Inch AP
25 Inch AP
40 inch AP
80 Inch AP
Electrostatic
precipitator
200 SCA
400 SCA
600 SCA
800 SCA
Spray dryer/
fabric filter
HEPA filtration
5,940,000
7,810,000
8,500,000
13,280,000

10,640,000
15,500,000
20,280,000
24,790,000
17,330.000
4,200,000
a
a
a
6,590,000

6,630,000
9,860,000
12,890,000
15,720,000
10,380,000
2,870,000
2,020.000
2,510,000
3,230,000
6,120,000

4,530,000
6,500.000
8,600,000
11.340,000
10,060,000
1,610,000
a
1,690.000
1.890.000
3,870,000

2,350,000
3,310.000
4,080,000
4,750.000
7,540,000
620,000
1,460,000
1,870,000
2,460,000
5,230,000

3,140,000
4,390,000
5,950.000
7,390,000
6.580,000
1,020,000
9,400,000
13,000,000
16,000,000
35,000,000

27,000,000
40,000.000
52.000,000
64,000,000
52,000,000
10,000,000
No costs are incurred for this alternative because facility has  more  efficient control  in place.

-------
un
I
                               TABLE 5-10.
                                 ANNUALIZED COST OF CONTROL ALTERNATIVES
                                   (Rounded Cost, 1988 $)       ™««*vta
       Control
       2.
      3.
                                         Monsanto
                                             Plant
                                             —  ii i  _

                                           Occidental
                                         Stauffer,
                                          Montana
       1.  Venturi scrubber
           10 inch AP
           25 Inch AP
           40 Inch AP
           80 Inch AP
                            Stauffer,
                            Tennessee
Electrostatic
  predpltator

200 SCA
400 SCA
600 SCA
800 SCA
                 1.600,000
                 2,110,000
                 2,430,000
                 3,750,000
2,010,000
2,840,000
3,650,000
4,430,000
                                       1,260,000
                                       1,820,000
                                       2,330,000
                                       2,820,000
  970,000
1.320,000
1,670,000
2,030,000
                                                                                               Total
a
a
2,220,000
740,000
920,000
1,150,000
1.910,000
a
680,000
740,000
1,110,000
590,000
750,000
930,000
1,610,000
2,900,000
4,500,000
5,200,000
11,000,000
790,000
830,000
870,000
910,000
640,000
850,000
1,120,000
1,370,000
5,700,000
7,700,000
9,600,000
12,000,000
*- *~*r.c nue^oo.oooMao.™    ,630,M     ^     ^    ^ ^

                             i>700'000    ^i^^^MOL.J^fL^-000-000
                                    beCaUSe fKl"*» "« -r. efficient control In p,ace.

-------
     Control  Alternative
            Capital  Costs
Control
    VS/10
    VS/25
    VS/40
    VS/80
WESP/200
WESP/400
WESP/600
WESP/800
    SD/FF
    HEPA
             10   20   30   40   50   60   70
                   Cost-$ Millions
            FMC    W Monsanto
            Stauf, MT EHm Stauf, TN
Occidental
       Figure 5-1, Capital costs of control alternatives,
                     5-17

-------
      Control  Alternative
          Annualized  Costs
 Control
    VS/10
    VS/25
    VS/40
    VS/80
WESP/200
WESP/400
WESP/600
WESP/800
   SD/FF
    HEPA
                                 40
         10    20     30
              Cost-$ Millions
    •i FMC     ESS Monsanto Fl Occidental
    ^^ Stauff.MT inn3 Stauff.TN
Figure 5-2. Annualized costs of control alternatives.
50
                    5-18

-------
TABLE 5-11.
                                    SUMMARY OF COSTS FOR VENTURI SCRUBBER— 10 INCH PRESSURE DROP
                                                (Rounded Cost, 1988 $)
en
I

TOTAL
1.
2.




3.


TOTAL
1.
2.
3.
4.
5.
6.

CAPITAL INVESTMENT
Scrubber cost
Auxiliary equipment
Ductwork
Fan system
Stack(s)
Waste disposal
Installation
Direct costs
Indirect costs
ANNUAL COSTS
Utilities
Operating labor
Maintenance
Overhead
Sludge disposal
Capital charges

FMC
5,940,000
1,580,000

960,000
500,000
50,000
19,000

1,740,000
1,090,000
1,600,000
240,000
120,000
100,000
140,000
60,000
940,000

Monsanto
2,530,000
1,000,000

--
310,000
--
20,000

740,000
460,000
970,000
150,000
120,000
100,000
140,000
60,000
400,000
Plant
Occidental
2,020.000
650,000

170,000
210,000
20,000
10,000

590,000
370,000
740,000
120,000
90,000
80,000
100,000
30,000
320,000

Stauffer,
Montana
1,690,000
390,000

170,000
290,000
20,000
10,000

500,000
310,000
660,000
30,000
120,000
100,000
140,000
10,000
270,000

Stauffer.
Tennessee
1,460,000
470,000

120,000
150,000
20,000
10,000

430,000
266,000
590,000
90,000
60,000
100,000
90,000
20,000
230,000

-------
                        TABLE 5-12.
                                      OF COSTS
                                          (Rounded
                                                                               ,KCH PRESSURE DROP
CJl
I
ro
CD
 TOTAL CAPITAL INVESTMENT
   1.  Scrubber cost
   2.  Auxiliary equipment
       Ductwork
       Fan system
       Stack(s)
       Waste disposal
  3.   Installation
       Direct costs
       Indirect costs

TOTAL ANNUAL COSTS
  1.   Utilities
      Operating labor
      Maintenance
      Overhead
      Sludge disposal
      Capital charges
         2.
         3.
         4.
         5.
         6.
	 	 	
FMC
	 	 	 __
7,810,000
2,080,000
1,270,000
670,000
50,000
19,000
2,290,000
1,430,000
2,110,000
450,000
120,000
100,000
140,000
70,000
1,230,000
======
	 . 	
Monsanto
— • 	 	 	 __
3,200,000
1,180,000
470,000
20,000
940,000
590,000
1,200,000
280,000
120,000
100,000
140,000
60,000
500,000
_
Plant
Occidental
— '
2,510,000
770,000
230,000
270,000
20,000
10,000
740,000
460,000
920,000
230,000
90,000
80,000
100,000
30,000
400,000
=^^ 	 	 	

Stauffer,
Montana
— 	 _ 	
1,690,000
390,000
170,000
290,000
20,000
10,000
500,000
310,000
680,000
50,000
120,000
100,000
140,000
10,000
270,000

Stauffer,
Tennessee
	
1,870,000
560,000
160,000
230,000
20,000
10,000
550,000
340,000
750,000
180,000
60,000
100,000
90,000
20,000
290,000

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TABLE 5-13.
                                   SUMMARY OF COSTS FOR VENTURI SCRUBBER-40  INCH PRESSURE DROP
                                               (Rounded Cost,  1988 $)
en
i
ro

TOTAL
1.
2.




3.


TOTAL
1.
2.
3.
4.
5.
6.

CAPITAL INVESTMENT
Scrubber cost
Auxiliary equipment
Ductwork
Fan system
Stack(s)
Waste disposal
Installation
Direct costs
Indirect costs
ANNUAL COSTS
Utilities
Operating labor
Maintenance
Overhead
Sludge disposal
Capital charges

FMC
8,500,000
2,080,000

1,270,000
1,030,000
50,000
20,000

2,490,000
1,560,000
2,430,000
660,000
120,000
100,000
140,000
70,000
1,340,000

Monsanto
4,460,000
1,550,000

--
760,000
—
20,000

1,310.000
820,000
1,530.000
410,000
120,000
100,000
140,000
60,000
1,700,000
Plant
Occidental
3,230,000
950,000

290,000
410,000
20,000
10,000

950,000
590.000
1,150,000
340.000
90,000
80,000
100,000
30,000
510,000

Stauffer,
Montana
1.890.000
390,000

170,000
390,000
20,000
10,000

550,000
350,000
740,000
70,000
120,000
100,000
140.000
10,000
300,000

Stauffer,
Tennessee
2,460,000
730,000

210,000
310,000
20,000
10,000

720,000
450,000
930,000
270,000
60,000
100,000
90,000
20,000
390,000

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                       TABLE 5-14.  SUMMARY OF COSTS  FOR  VENTURI  SCRUBBER—80 INCH PRESSURE DROP
                                                 (Rounded  Cost,  1988  $)
un
i
ro
ro

TOTAL
1.
2.




3.


TOTAL
1.
2.
3.
4.
5.
6.
= .' . — a.

CAPITAL INVESTMENT
Scrubber cost
Auxiliary equipment
Duct wo rk
Fan system
Stack(s)
Waste disposal
Installation
Direct costs
Indirect costs
ANNUAL COSTS
Utilities
Operating labor
Maintenance
Overhead
Sludge disposal
Capital charges

FMC
13.280,000
2,970,000

1,800,000
2,110.000
50,000
20,000

3,890,000
2,430,000
3,750,000
1,230,000
120,000
100,000
140,000
70,000
2,090,000

Monsanto
6,590,000
2,220,000

—
1,210,000
--
20,000

1,930,000
1,210,000
2,220,000
760,000
120,000
100.000
140,000
60,000
1,040,000
Plant
Occidental
6,120.000
1,940,000

400,000
820,000
20,000
10,000

1,790,000
1,120,000
1,910,000
640,000
90,000
80,000
100,000
30,000
960,000

Stauffer,
Montana
3.870,000
460,000

220,000
1,300,000
20,000
10,000

1,130,000
710,000
1,110,000
130,000
120,000
100.000
140,000
10,000
610,000

Stauffer,
Tennessee
5,230,000
1,610,000

300,000
800,000
20,000
10,000

1,530,000
960,000
1,610,000
510,000
60,000
100,000
90,000
20,000
820,000

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                    TABLE  5-15.   SUMMARY  OF  COSTS  FOR  WET  WALL  ELECTROSTATIC PRECIPITATOR—200 SCA
                                               (Rounded Cost, 1988 $)
I
ro
CO

TOTAL
1.
2.


3.

TOTAL
1.
2.

CAPITAL INVESTMENT
Purchased equipment
Auxiliary equipment
Ductwork
Fan system
Stack(s)
Installation
Direct costs
Indirect costs
ANNUAL COSTS
Direct costs
Indirect costs

FMC
10,640.000
2.650.000

1,010,000
330.000
40.000

3,910,000
2,710,000
2,010,000
270,000
1,740,000

Monsanto
6,630.000
1,540,000

780,000
190.000

2,430,000
1,690,000
1,260,000
180,000
1,080,000
Plant
Occidental
4,530.000
1,390,000

180,000
150,000

1,660,000
1,150,000
970,000
170,000
800,000

Stauffer,
Montana
2,350,000
660,000

80,000
140.000

860.000
600.000
790.000
100,000
690,000

Stauffer,
Tennessee
3,140,000
950,000

130,000
110,000

1,150,000
800,000
640,000
120,000
520,000

-------
                      TABLE 5-16.   SUMMARY  OF
CJl
I
ro
 TOTAL CAPITAL INVESTMENT
   1.   Purchased equipment
   2.   Auxiliary equipment
       Ductwork
       Fan  system
       Stack(s)
   3.   Installation
       Direct costs
       Indirect costs

TOTAL ANNUAL COSTS
  1.  Direct costs
  2.  Indirect costs
                                                                 HXOHSTATIC PREC,P.TATOR~400 SCA
FMC
	
15,500,300
4,490.000
1,010,000
330,000
40,000
5,700.000
3,950,000
2,840,000
320,000
2,520,000
•
Monsanto
— 	 	 . 	
9,860,000
2,760,000
780.000
190,000
3,620,000
2,510,000
1,820,000
220,000
1,600,000
========
Occidental
"•"
6,500,000
2,130,000
180,000
150,000
2,390,000
1,650,000
1,320,000
200,000
1,120,000
Stauffer,
Montana
— 	
3,310,000
1,030,000
80,000
140,000
1,210,000
840,000
830,000
100,000
730,000
Stauffer,
Tennessee
— ' '
4,390,000
1,420,000
130,000
110,000
1,610,000
1.120,000
850,000
130,000
720,000

-------
                    TABLE 5-17.  SUMMARY OF COSTS FOR WET WALL ELECTROSTATIC  PRECIPITATOR—600  SCA
                                               (Rounded Cost,  1988 $)
I
ro
ui

TOTAL
1.
2.



3.


TOTAL
1.
2.

CAPITAL INVESTMENT
Purchased equipment
Auxiliary equipment
Ductwork
Fan system
Stack(s)
Installation
Direct costs
Indirect costs
ANNUAL COSTS
Direct costs
Indirect costs

FMC
20,280.000
6,290,000

1,010,000
330,000
40,000

7,450.000
5,160,000
3,650,000
370,000
3,280,000

Monsanto
12,890,000
3,910,000

780,000
190,000
—

4,730,000
3,280,000
2,330,000
250,000
2,080,000
Plant
Occidental
8,600,000
2,930,000

180,000
150,000
—

3,160,000
2,190,000
1,670,000
220,000
1,450,000

Stauffer,
Montana
4,080,000
1,320,000

80,000
140,000
—

1,500,000
1,040,000
870,000
110,000
760,000

Stauffer,
Tennessee
5,950,000
2,010,000

130,000
110,000
--

2,180,000
1,510,000
1,120,000
150,000
970,000

-------
                      TABLE 5-18.  SUMMARY OF
en
I
crv
           ~   • •  .- —	— -   _ _
        TOTAL CAPITAL  INVESTMENT
          1,
          2.
 Purchased equipment
 Auxiliary equipment
 Ductwork
 Fan system
 Stack(s)
 Installation
Direct costs
 Indirect costs
       TOTAL ANNUAL COSTS
         1.  Direct costs
         2.  Indirect costs
                                                                 aEaROSTAT.C PKEnHTATOK-eOO SCA
FMC
— — 	
24,790,000
8,000,000
1,010,000
330,000
40,000
9,100,000
6,310,000
4,430,000
420,000
4,010,000
1
Monsanto
— 	 	 — 	 .
15,720,000
4,980,000
780.000
190.000
5,770,000
4,000,000
2,820,000
280,000
2.540,000
~
Occidental
— — — • ,-
11,340,000
4,410,000
180,000
150,000
3,900,000
2,700,000
2,030,000
250,000
1,780.000
- 	
Stauffer,
Montana
— 	 • — — 	
4,750,000
1,570,000
80,000
140,000
1,740,000
1,210,000
910,000
120,000
790,000
Stauffer.
Tennessee
— 	 . —
7,390,000
2,560,000
130,000
110,000
2,710,000
1,880,000
1,370,000
170,000
1,200,000

-------
en
i
ro
                              TABLE 5-19.  SUMMARY OF COSTS FOR SPRAY DRYER/FABRIC FILTER
                                                (Rounded Cost. 1988 $)

TOTAL CAPITAL INVESTMENT
1. Purchased equipment
2. Auxiliary equipment
Ductwork
Fan system
Stack(s)
3. Installation
Indirect costs
TOTAL ANNUAL COSTS
1. Direct costs
2. Indirect costs

FMC
17,330,000
10,870,000
190,000
700,000
30,000

5.540.000
9,970,000
6,350,000
3,620,000

Monsanto
10,380,000
6,330,000
340,000
390,000

3,320,000
5,430,000
3,280,000
2,150.000
Plant
Occidental
10,060,000
6,530,000
100,000
180,000

3,250,000
4,630,000
2,450,000
2,180,000

Stauffer,
Montana
7,540,000
4,810,000
40,000
270,000

2.420,000
3,070,000
1,420.000
1,650,000

Stauffer,
Tennessee
6,580,000
4,230,000
50,000
200,000

2,100,000
3,120,000
1,720,000
1,390,000

-------
TABLE 5-20.   SUMMARY OF COSTS FOR HEPA FILTRATION SYSTEM
                (Rounded Cost, 1988 $)

TOTAL
1.
2.



3.
c_n
1
IX)
oo
TOTAL
1.
2.
^ - ' - — —

CAPITAL INVESTMENT
Purchased equipment
Auxiliary equipment
Ductwork
Fan system
Stack(s)
Installation
Direct costs
Indirect costs
ANNUAL COSTS
Direct costs
Indirect costs

FMC
4,200,000
1,300,000

200.000
370,000
44,000

1,380,000
900,000
10,140,000
9,340,000
800,000

Monsanto
2,870,000
800,000

220,000
250,000
20,000

950,000
620,000
15,700,000
5,110,000
590,000
Plant
Occidental
1,610,000
500,000

40,000
170,000
20,000

530,000
350,000
10,070,000
9,710,000
360,000

Stauffer,
Montana
620,000
190,000

20,000
70,000
10,000

200,000
130,000
2,960,000
2,810,000
150,000

Stauffer,
Tennessee
1,020.000
310,000

40.000
100,000
20,000

340,000
220,000
7,450,000
7,220,000
230,000

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5.4  REFERENCES FOR SECTION 5

1.  U. S. Environmental Protection Agency.  Emissions of Lead-210 and
    Polonium-210 from Calciners at Elemental Phosphorus Plants:  FMC
    Plant, Pocatello, Idaho.  Washington, D.C.  June 1984.

2.  U. S. Environmental Protection Agency.  Emissions of Lead-210 and
    Polonium-210 from Calciners at Elemental Phosphorus Plants:  Monsanto
    Plant, Soda Springs, Idaho.  Washington, O.C.  September 1984.

3.  U. S. Environmental Protection Agency.  Emissions of Lead-210 and
    Polonium-210 from Calciners at Elemental Phosphorus Plnats:  Stauffer
    Plant, Silver Bow, Montana.  Washington, D.C.  August 1984.
                                   5-29

-------
                                    TECHNICAL REPORT DATA
                            iPlease read Instructions on the reverse before compienmi
 1. REPORT NO.
  EPA-450/3-88-015
             3. RECIPIENT'S ACCESSION NO.
 4. TITLE AND SUBTITLE
  Characterization and  Control of Radionuclide
  Emissions From Elemental  Phosphorus Production
             5. REPORT DATE
              February  1989
             6. PERFORMING ORGANIZATION CODE
 7 AUTHOR(S)
                                                            8. PERFORMING ORGANIZATION REPORT NO.
 9. PERFORMING ORGANIZATION NAME AND ADDRESS
  Midwest Research Institute
  Suite 350
  401 Harrison Oak Blvd
  Gary, NC  27513
             10. PROGRAM ELEMENT NO.

              Work Assignment 12
             11. CONTRACT/GRANT NO.

              EPA Contract No. 68-02-4379
 12. SPONSORING AGENCY NAME AND ADDRESS
  Elizabeth A. Grainger, Project  Officer
  Industrial Studies Branch,  Emissions Standards Division
  OAQPS
  U.S. Environmental Protection Agency,  RTP, NC  27711
             13. TYPE OF REPORT AND PERIOD COVERED
              May 1988 to February  1989
             14. SPONSORING AGENCY CODE
 15. SUPfH.EMENTARY NOTES
 16. ABSTRACT  j^g report presents  the  results of a study conducted  by the Industrial
 Studies Branch in EPA's Office of  Air Quality Planning and  Standards that was designed
 to  collect background information  on radionuclide emissions  from  elemental phosphorus
 production processes.  The Office  of Radiation Programs will use  this information to
 evaluate the National Emission Standard  for Hazardous Air Pollutants for radionuclide
 emissions from elemental phosphorus  production in response  to  litigation by the Sierra
 ^lub.

      Information gathered included all emission data generated over the past 10 years
 by  EPA and elemental phosphorus  facilities,  test  results of the test  program conducted
 concurrently with this study (two  scrubbers),  data compiled from plant  visits to each
 of  the five  operating facilities,  and  data  acquired through review  of published
 literature,  contact  with knowledgeable EPA  personnel,  and telephone contacts with
 control  equipment vendors.

     This  report  provides descriptions of the  elemental phosphorus production processes
 radionuclide emissions from those processes, availability of control  techniques that
 could  reduce those emissions, and the performance  and  costs of alternative  control
 techniques.
 7.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                              b.IDENTIFIERS/OPEN ENDED TERMS
                                                                           COSATI I leld/CfOUp
 Elemental  Phosphorus production, air
 emissions,  radionuclide emissions, acid
 gas emissions,  particulate matter emissions
 spray towers,  scrubber, ESP, fabric filter,
 high efficiency particulate air filter
Elemental phosphorus
production,  air pollutior
air emission,  air
pollution control equip-
ment, air emission
standards
                                              19. SECURITY CLASS /This Report/
                          21. NO. OF PAGES
                                             2O SECURITY CLASS /Thtspagei
                                                                        •22. PRICE
SPA Form 2220-1 i'Rev. 4-77)
                      ^=EVIOUS EDITION .3 OBSOLETE

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