United States       Office of        EPA-230-05-84-008
Environmental Protection   Policy Analysis      May 1984
Agency         Washington, DC 20460
The Cost of Clean Air
and Water Report to
Congress
1984
ENVIRONMENTAL
 PROTECTION
  AGENCY
DALLAS, TEXAS

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                   FINAL REPORT

                 THE COST OF CLEAN

                   AIR AND WATER

                REPORT TO CONGRESS

                       1984
                     May 1984
       U.S. Environmental  Protection Agency
             Office of Policy Analysis
                 Washington, D.C.
                    Contractor:

Development Planning and Research Associates, Inc.

                in association with

            TCS Management Group, Inc.
                        and
          Pope-Reid and Associates, Inc.

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                   REPORT OF THE ADMINISTRATOR

                             OF THE

                 ENVIRONMENTAL PROTECTION AGENCY

                             TO THE

                  CONGRESS OF THE UNITED STATES

                       IN COMPLIANCE WITH
    SECTION 312(c) OF THE CLEAN AIR ACT,  AS AMENDED BY PUBLIC
          LAW 91-604, THE CLEAN AIR AMENDMENTS OF 1970

                               AND

SECTION 516(b) OF PUBLIC LAW 92-500, THE  FEDERAL WATER POLLUTION
                 CONTROL ACT AMENDMENTS OF 1972

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                             EXECUTIVE SUMMARY
          The Clean Air Act and Clean Water Act include provisions which
require the Administrator of the Environmental  Protection Agency to make
and report detailed estimates of the costs of carrying out the respective
Acts.  This report presents such estimates as two separate reports, one
concerned with the control of air pollution, the other with the control of
water pollution.  This summary provides information on both reports and
presents listings of "water costs," "air costs," and "combined costs."

          This report includes only those costs associated with federal
regulatory actions resulting from the Clean Air and Clean Water Acts, and
does not account for costs voluntarily incurred by polluters, required by
State or local governments only, or mandated by other federal laws.  It
does not include costs incurred prior to the dates of the respective Acts
(Air—1970, Water—1972) (nor expenditures which would have taken place if
the Acts had not been passed).

          This document specifically does not represent EPA policy
concerning the application of presently available or projected
emissions-control technology to any industry or activity.  To estimate the
cost of complying with EPA regulations to the industries included in the
report, it was necessary to make simplifying assumptions.  Thus, the
control technologies assumed in providing these estimates are not to be
regarded as specifically required by law nor by EPA.  Moreover, cost
estimates included in this study may differ from cost estimates included in
other studies because of differences in definition of the industries.

          The costs reported for the control of air pollution are, for the
most part, based on compliance with federally-approved State Implementation
Plans, federal New Source Performance Standards, and federal regulations
for mobile sources.  The costs reported for the control of water pollution
are, for the most part, based on compliance with federal Effluent
Limitations Guidelines, New Source Performance Standards, and Pretreatment
Standards.  Regulations for hazardous and toxic pollutants are also
included.

          Preparation for this report was begun in 1980, and completed in
1983.  It reflects, for the most part, the regulatory framework existing in
December 1982.

          In the air report, the cost of regulations implementing the Clean
Air Act Amendments of 1977 are not estimated separately, except where
information was available from a detailed industry study.  It is difficult
to assess the costs of complying with BACT (Best Available Control
Technology) and LAER (Lowest Available Emission Rates) because these
requirements are source-specific.  (BACT and LAER govern emissions from
certain new sources in attainment and non-attainment areas respectively.)
NSPS costs were frequently used as an approximation for BACT or LAER costs.

                                     1

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No information was available concerning the cost of complying with BART
(Best Available Retrofit Technology) standards, which apply to certain
sources in designated attainment areas.  Except where NESHAPS (National
Emissions Standards for Hazardous Air Pollutants) are involved, there is
also very little information available on fugitive emission control costs.
The report does not include cost estimates for most fugitive emission
controls.

          In the water report, some of the regulations proposed or
promulgated in accordance with the 1976 Consent Decree with the National
Resources Defense Council have not been incorporated in the cost estimates
It is difficult to assess the impact of certain expected regulatory change
on the control costs included in this report.  The Clean Water Act of 1977
(amending the Federal Water Pollution Control Act of 1972) will require
less stringent controls for conventional  pollutants than in the past.
However, additional regulations promulgated in accordance with the 1976
NRDC Consent Decree will result in more stringent guidelines for certain
industries.  More detail is provided regarding the costs included in this
report and future regulatory changes in the Introductions to the Air Repor
and Water Report.


                       COST OF IMPLEMENTING THE ACTS

          The base year for the costs presented here is 1981; all costs ar
expressed in millions of 1981 dollars.  The report includes estimates of
investment and annual costs for two historical periods:  1970-81 (Air),
1972-81  (Water) and projections of these costs for the period from 1982
through  1990,

          The costs reported include:

          •  Capital costs of equipment and installation

          •  Annual capital costs (sum of equivalent annual cost or curren
             and previous years capital expenditures)

          •  Direct operating and maintenance costs.

          The methodology used to generate costs is discussed in the
introduction of each report and in more detail in the specific chapters.
The methodology involves the analysis of specific regulations for affected
sectors  of industry and  the development of cost estimates for the control
equipment or methods characteristic of each sector.

          The estimates  of the costs are engineering estimates; they are
not obtained from  industry surveys.  The estimates are based on the assume
application of existing  technology, and are developed by various technique
such as  the use of "model" plants, or actual data on an existing plant.
Various  other assumptions are used, such as the selection of an "average"
air-pollution regulation typical of all State Implementation Plans.  The
assumptions probably result in an overstatement of costs, since no

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allowances are made for technological innovation, which might reduce the
costs of pollution control.

          A summary of the findings is included in the three following
tables.  Table 1 presents estimated total air and water pollution control
costs, Table 2 presents estimated air pollution control costs, and Table 3
presents estimated water pollution control costs.  The tables show both
investment costs and annual costs.  (Annual costs include annualized
capital costs and operating and maintenance costs.)

          Major industry groups are consistent among these tables; however,
individual line items are presented only where costs have been developed.
Some industries have only air or only water costs associated with them and
so appear in only one of the last two tables.  Table 1 is the sum of Tables
2 and 3.  For example, the table entry for Mobile Sources appears in Tables
1 and 2 as an air pollution item.  A key at the end of this summary
explains how the individual industry chapters were grouped in these summary
tables.

          The government expenditures shown in the tables are based on
expenditures to run pollution control programs at the federal, state, and
local levels and the projected distribution of grants for construction of
municipal water treatment plants.  Program operating costs are included for
both air and water pollution control with "Annual Costs" in both  Tables 2
and 3; the construction grants are included with "Investment" in  Table 3,
with annualized capital costs of the grants included with the "Annual
Costs" shown in Table 3.

          Various major industries appear as single entries because of
their significance in terms of pollution control costs, such as electric
utilities, petroleum refining, iron and steel, primary aluminum and copper,
and pulp and paper.  The Mobile Sources category includes passenger cars,
light and heavy-duty gasoline and diesel trucks, aircraft, and motorcycles.

          Further details on any group may be found via the key to
aggregation given at the end of this summary, or the individual chapters of
the report.


                            COMPARISON OF COSTS

          In terms of the combined costs given in Table 1, the highest
levels of expenditures are associated with the Energy Industries  (largely
electric power plants and petroleum refining) and Mobile Sources.

          The 1981 annualized cost of pollution control due to federal
regulations was estimated to be $42.5 billion, or about one percent of GNP
in 1981.  The cumulative cost from 1970 to 1978 was $171 billion  and the
projected cost over the period 1981 to 1990 is estimated at $525.8 billion.

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          In Table 2 (Air Pollution Control Costs), the groups showing the
largest portions of investment costs include the Energy Industries
(specifically, power plants), and Mobile Sources.  The Mobile Sources cost
include costs for lead phase-down and lead-free gasoline production; these
elements of cost may be associated with the Petroleum Refining Industry in
other studies.  The Metals and Other Industrial Costs groups fall below
Mobile Sources in a ranking of Investment expenditures.  The estimated
costs for the metals industry group shows separate costs for the three
major metals:  steel, aluminum, and copper.

          One of the individual features which may be noted in Table 2 (Ai
Pollution Control Costs) is the singularly high level of expenditures for
the control of Mobile Sources; these costs reflect the projected automobil
populations, as well as increasing stringency of regulations.

          In Table 3 (Water Pollution Control Costs), the highest level of
expenditure is that for the Chemical Industries (principally the organic
chemicals industry) with the next highest levels of expenditures shown for
the energy industry (largely for Petroleum Refining and, again, electric
power plants).

          The water pollution control costs in Table 3 include federal
grants for construction of municipal treatment plants as an investment
expenditure.  The Water Report contains a discussion of nonpoint sources
(agriculture, silviculture, urban runoff and new construction runoff
control) in Chapter 10.  The costs for controlling pollution from nonpoint
sources are discussed in Chapter 10, but do not appear in the cost tables
in this summary.  Estimates of these costs range from annual expenditures
of $4 billion to $5 billion.
                   THE ECONOMIC IMPACT OF EPA'S PROGRAM

          This section provides some perspective as to the economic effect
of EPA programs.  Widely disparate views on the economic impact of EPA's
program have been expressed by some environmentalists—who say the prograir
stimulates the economy and creates jobs—and by some businessmen—who say
the program causes capital shortages and inflation in boom times and cause
unemployment and stifles profitability in recessionary times.

          The truth probably lies somewhere in between.  While costs of—
pollution programs are high in absolute terms, the overall effects on
prices, GNP, and employment are projected to be small and neither strongly
positive nor negative in the long run.

          Most concern about economic effects should be focused on a few
heavily polluting industries which either are very capital-intensive
materials production industries or are characterized by many economically

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-------
marginal  operations.  Of key importance for these industries are (1)
concerns about limits on expansion due to capita! shortfalls or siting
constraints posed by environmental regulations and (2) the effects of these
limits on growth in these and related industries.

          This section does not discuss whether environmental programs (or
various elements of them) have favorable benefit/cost ratios, since few
credible benefits data have been generated which would allow such analysis.
This section does briefly detail what is and is not known about the costs,
macroeconomic and microeconomic impacts, and energy impacts associated with
the environmental program.


                                   Costs

          The federal pollution control program is projected to cost about
$526 billion in the period 1981-1990 above expenditure levels which would
have resulted without new federal requirements put in place since 1970.
About $256 billion of these expenditures are for air pollution control, and
$270 billion are for water pollution control.  Capital investment for
federally-required controls will be about $176 billion over the same
period.  About $102 billion of this total, or 58 percent, is related to the
requirements of the Clean Air Act; the remaining $74 billion is for water
pollution control.  The cost of controlling pollution from nonpoint sources
is not included in the summary tables, but is discussed in Chapter 10 of
the water report.  Projections for the cost of controlling nonpoint source
pollution range from $4 billion to $5 billion, annually.

          The annualized cost of air and water pollution control due to
federal regulations was estimated at 262.2 billion for the period
1979-1984.  Air pollution control costs for this period are $126.5 billion,
while water pollution control costs are $135.7 billion.  Capital investment
costs for the same period are $100.3 billion for both air and water
pollution control.


                           Macroeconomic Impacts

          These costs can be put in perspective by looking at their
macroeconomic effect on the economy.  The magnitudes of these effects
depend upon the general state of the economy.  In a slack economy pollution
control investment can stimulate growth and employment with little real
effect on prices, while in a tight economy such investment can increase
prices and tend to replace other capital spending plans with a relatively
small effect on employment.  Macroeconomic forecasts can project these
effects, but only with a wide band of uncertainty.

Price and Growth Effects

          A Data Resources, Inc. (DRI) forecast prepared for EPA and CEQ in
July 1981 shows the Consumer Price Index is currently about 3.3 percent
higher than it would have been without federal pollution requirements and
that by 1987 this difference will be about 6.6 percent, meaning that

                                     17

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consumer prices will  increase an average 0.4 percentage points per year
more than they would without these requirements over the period 1970-1987.

          DRI estimated that real GNP in 1981 (with federal pollution
regulations) is marginally lower than it would have been without federal
pollution requirements because capital and other resources have been
consumed that would otherwise not have been utilized.  DRI estimated that
by 1987 real GNP will be almost 0.7 percent lower than it would have been
without federal pollution requirements.

          These estimated effects on the economy are in terms of
conventional measures for these prices and GNP.  Since these measures do
not take into account the benefits of the environmental programs in terms
of improved public health and welfare, these forecasts exaggerate the
negative impacts on inflation and economic growth.

Employment Effects

          The DRI forecast for EPA and CEQ estimated that the impact on
unemployment in 1981 would be a net decrease in the unemployment rate of
0.3 percentage points.  Equipment installation and monitoring of pollutior
control equipment creates jobs.  By 1987, the model predicts there are
524,000 additional jobs created as a result of pollution control
regulations.  The program directly creates jobs in the construction
industry (42,000 on-site jobs on EPA-funded sewage treatment projects in
1980, with one and one-half times that number of off-site jobs) and in the
pollution control manufacturing industry (Arthur D. Little, Inc., estimate
that employment in this industry would be around 44,000 in 1983 as a resul
of the 1970 and 1972 air and water legislation), with many more indirect
jobs stimulated by these expenditures.

          On the other hand, when pollution control costs result in higher
prices, lower demand and hence lower production and lower employment
result.  Furthermore, some transitional unemployment results from the
closing of marginal plants which cannot afford to comply with environment
requirements.  Since January 1971, 155 closures involving nearly 33,000
jobs have occurred for which the firm has said that pollution requirements
were a significant factor; 53 closures involved federal action.


                             COST METHODOLOGY

          Cost estimates for each industry are presented in a table
following the corresponding chapter text.  To estimate compliance costs th
industry is usually divided into a number of sectors.  Sectors may be
defined according to production process, control technology, regulations,
available cost data, or any other factors that can influence costs.  The
cost data for an individual sector may take one of two forms:  "exogenous"
total  costs, or cost functions.  The cost methodology section in each
chapter indicates the type of cost data used in that chapter.

          Exogenous sector costs are total year-by-year investment and/or
O&M costs that are estimated without using the computer model designed for
the report.  The exogenous form  is sometimes used because the complexity c
                                     18

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the chapter precludes the use of cost functions alone.  In other instances,
these costs are taken from a detailed economic study of the industry
commissioned by the EPA.  The use of these studies improves the consistency
and coherency of this report with other EPA publications.  Some of these
economic reports may not provide detailed information about control costs.
In these cases the reported costs do not necessarily conform to the
standard format, e.g., new plant costs may not be separately identified,
although costs projected into the future include costs for both new and
existing plants.  Similarly, the source document may not use the same
breakdown of annual costs or the same discount rate as is normally used in
the existing computer model.  Nevertheless, the overall costs and timing of
the costs are reported as developed in the designated source document.

          Costs in most chapter sectors are generated from cost equations
that express control costs as a function of plant capacity.  (Larger plants
usually benefit from economies of scale.)  In most cases future cost
estimates are based on the assumption of continued application of current
technologies.  Capital and operating and maintenance (O&M) costs are
calculated separately.  The computer program computes total industry costs
by applying the cost functions to industry plant data, taking into account
compliance schedules estimated by the chapter author.  The cost functions,
which are based on engineering model giant costs, are expressed in a
standard exponential form:  Cost = AX , where X is a measure of capacity.
O&M costs are adjusted according to estimates of capacity utilization
percentages.

          Industry plant data include the plant population for a base year,
historical growth rates, and expected future growth rates.  Compliance
schedules simply reflect the percentage of the plant population that
complied with a regulation in each past year and estimates of the
percentage that will comply in each future year.  These estimates are based
on the compliance date specified in the pertinent regulation, allowing for
lead time required to construct and install the control technology
required.  New plants are assumed to comply upon construction.

          To calculate the annual capital costs, the computer program uses
the stated life of the control equipment and a real (not nominal),
before-tax discount rate of ten percent.  The discount rate accounts for
the "opportunity" cost of control equipment investment funds.  It is
understood that other systems of depreciation are used, that other discount
rates are sometimes applicable, that "opportunity costs" for other uses of
capital are not taken into account, and that tax write-offs are commonly
applied to control equipment.  The ten percent real rate is used as a
"compromise" value which is intended to reflect an average value of the
highly varied individual cases.

          The computer program also calculates the cost of replacing
control equipment at the end of its useful life.  These costs are assumed
to be some fraction of the original cost of equipment as certain elements,
such as the foundations, do not need to be replaced.

          The program excludes costs associated with pollution control that
would have been incurred without the inducement of federal regulations.  It
does this by excluding from the plant population a precompliance fraction
                                     19

-------
that is provided by the chapter author.  This fraction represents plants
that either can comply with the applicable regulation without installing
controls or plants that installed controls even in the absence of
regulations.

          When pollution control results in product or by-product recovery
the value of the recovered product is calculated and credited against the
O&M costs associated with the control.  Credits are estimated by
multiplying the price of the recovered product by the amount of the
recovered product.  In some cost sectors, the O&M costs or cost function
have been estimated net of credits.  In other cases, credits or credit
functions have been estimated separately.  In credit function sectors,
credits, like costs, are expressed as an exponential function:  Credit =
AX  , where X is a measure of capacity.  Credits, in the same way as O&M
costs, are adjusted according to capacity utilization estimates.

          Most cost estimates presented in this report are based on the
cost of installing and operating controls to meet standards at each
regulated source.  Thus, they do not reflect less costly control strategie
available for some facilities either through creation of emission bubbles
or by trading emission reduction credits with other facilities.

          This report also does not reflect any actions taken by industria
plants to decrease overall wastewater discharge after promulgation of
regulations.  Because data collected by the Bureau of Census indicate that
the amount of water discharged by industry is decreasing, the cost
estimates in this report may be overstated.

          This cost methodology differs from that followed in the August,
1979 report in that it:

          1. includes estimates of replacement costs, and

          2. does not assume that any fraction of industry was controlling
             emissions to the level set by New Source Performance Standard
             before the promulgation of these standards.

          Two other areas of costs are reported here which are not
developed through the methodology describe above.  Costs to government are
reported based on expenditures as scheduled in legislation.  The procedure
for estimating the costs of control for mobile sources (automobiles,
aircraft, etc.) is described within the text of Chapter A4.

          The uncertainties of forecasting even five years into the future
are well known.  The estimates are based mainly on present technology and
current trends in industry growth, with no allowance for innovation.  In
some situations, control technology has been assumed to be available that
has not yet been commercially demonstrated.  The estimated costs are
derived from an extrapolation of current practice; rarely in this century
would  such  an extrapolation have held true.
                                     20

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                            OTHER METHODOLOGIES

          Various other sources have estimated the cost of pollution
control  using other techniques.  This section discusses some of these other
sources  and how they differ form this report.


                        Bureau of Economic Analysis

          The Bureau of Economic Analysis (BEA), U.S.  Department of
Commerce, publishes the results of an annual  survey of industries detailing
capital  expenditures for air, water, and solid waste pollution abatement.
The survey requests information on total plant and equipment expenditures
for pollution abatement, not just that attributable to federal legislation.

          One of the major features of the BEA survey is that it samples
enterprises, not actual plants.  A company is categorized by its major
product.  For example, if a large petroleum company owns a textile mill,
any pollution control  investment at the textile mill would be classified
under petroleum refining.  Thus, while the aggregate BEA estimates are
quite useful, the individual industry-specific estimates reveal little
about the cost to a specific industrial process.


                           Bureau of the Census

          The Bureau of the Census, U.S. Department of Commerce, publishes
the results of an annual survey of manufacturing establishments detailing
both capital investment and operating costs for pollution abatement.  This
survey also asks for total expenditures, not just that due to federal
regulation.  Unlike BEA, the Census survey is based on a plant or
establishment classification.  Therefore, industry-specific estimates
reveal more about the cost to a specific industrial process.  The Census
survey,  however, includes manufacturing industries only.

          One of the main problems with the Census survey is that
depreciation is included as a part of operating costs.  Only total
operating costs are reported by program (air, water, or solid waste).  The
specific line items of operating costs (i.e., labor, materials and
depreciation) are not reported by media.

          Since the depreciable lives of air and water pollution abatement
equipment vary considerably, it is impossible to accurately subtract out
depreciation.  Furthermore, the depreciation expenses  are likely to reflect
changes  in tax provisions.  Thus, the inclusion of depreciation limits the
reliability of this survey in estimating operating and maintenance costs.


                            McGraw-Hill Survey

          The Economics Department of McGraw-Hill Publications Company
issues the results of an annual survey of pollution control expenditures.
The methodology used for this survey has never been revealed by the
Company, and, thus, it is difficult to compare with other estimates.-


                                     21

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                              Key to  aggregated  cost  tables  in  executive  summary
                                                           "Air"  report                        "Water"  report
            Table entries                                 chapter number                      chapter  numbers


Government Expenditures                                A2.                                    W2.

Fuels It Energy

   Coal Mining & Coal  Cleaning                         A3.5                                   W3.1
   Oil 4 Gas Extraction 4 Processing                   A3.3                                   W3.2
   Petroleum Refining                                   A3.4                                   W3.3
   Electric Utilities                                   A3.1                                   W3.4
   Coal Gasification                                   A3.6

Mobile Sources                                         A4

Nonooint Sources                                        -                                    W10.


Food Processing

   Feedlots and Meat Processing                         -                                    W8.6,  M8.7
   Other Food Processing                               A9.3,  A9.4                            W8.1,  M8.2,
                                                                                             M8.3,  W8.4,  M8.5

Chemicals

   Basic Inorganic Chemicals                           AS.4,  AS.7,  AS.3                       W4.2
   Organic Chemicals                                   AS.l,  AS.2                            W4.1,  W4.3
   Agricultural Chemicals                              AS.3,  AS.5,  A5.S, AS.9                 W4.3,  W4.9,  W4.1
   Formulated Chemicals                                A8.1,  AS.4,  A8.5                       W4.5,  M4.6,  W4.7
                                                                                             W4.ll, W4.12,
                                                                                             W7.3,  W9.1

Construction Materials                                 A7.1,  A7.2,  A7.3,                     W6.1,  W6.2,  W6.3
                                                       A7.4,  A7.S,  A9.5                       W6.4,  W6.S,  W6.6
                                                                                             W7.1

Metals

   Ore Mining 4 Dressing                                -                                    WS.l
    Iron 4 Steel                                        A6.1                                   WS.2
   Aluminum                                            A6.S                                   W5.5
   Copper                                              A6.S
   Monferrous Metals,  Ferroalloys, 4 Foundries         A6.2,  A6.3,  A6.4,                     WS.3,  MS.4,  MS.6
                                                       A6.7,  A6.3,  A6.9,
                                                       A6.10, A6.ll,  A6.12

Soft  Goods

   ?ulo 4 Paper                                        A9.1,  A9.2                            M7.4
   "extiles                                               -                                   W4.14
   Leather 4  Rubber                                       -                                   W4.4,  W8.3

Manufacturing

   Electroplating                                         -                                   W5.7
   Surface Coatings                                    A8.2                                   W5.3,  W5.9
   Furniture  Manufacture                                  -                                   M7.2
   Lead Acid  Batteries                                 A8.6

Services
   Drycleamng                                         AS. 3
   Hospitals'                                             -                                  W9.2
   Photographic Processing                                -                                  W4.13

Municipal Waste Incineration                           A10.1

Other  Industrial Costs

   Industrial 4 Commercial Heating Soilers             A3.2
   Industrial 4 Commercial Incinerators                A10.2
   Mood Waste Soilers                                  A3.7
                                                         22

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                  THE COST OF CLEAN AIR



               REPORT OF THE ADMINISTRATOR

                         OF THE

             ENVIRONMENTAL PROTECTION AGENCY

                         TO THE

              CONGRESS OF THE UNITED STATES

                   IN COMPLIANCE WITH

SECTION 321(c) OF THE CLEAN AIR ACT, AS AMENDED BY PUBLIC
      LAW 91-604, THE CLEAN AIR AMENDMENTS OF 1970

-------

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                                 CONTENTS

      Chapter                                                    Page

Al    Introduction and Summary                                   Al-1

A2    Government Expenditures                                    A2-1

A3    Energy Industires                                          A3-1
A3.1  Fossil-Fuel-Fired Electric Plants                          A3.1-1
A3.2  Industrial and Commercial Boilers                          A3.2-1
A3.3  Natural Gas Processing Industry                            A3.3-1
A3.4  Petroleum Refining                                         A3.4-1
A3.5  Coal Cleaning                                              A3.5-1
A3.6  Coal Gasification                                      .    A3.6-1
A3.7  Wood Waste Boilers                                         A3.7-1

A4    Mobile Sources                                             A4-1

A5    Chemicals Industries                                       A5-1
A5.1  Petrochemicals Industry                                    A5.1-1
A5.2  Vinyl Chloride                                             A5.2-1
A5.3  Nitric Acid Industry                                       A5.3-1
A5.4  Sulfuric Acid Industry.                                    A5.4-1
A5.5  Phosphate Fertilizer Industry                              A5.5-1
A5.6  Nonfertilizer Phosphorus Chemicals                         A5.6-1
A5.7  Mercury-Cell Chlor-Alkali Industry                         A5.7-1
A5.8  Ammonia and Urea                                           A5.8-1
A5.9  Ammonium Nitrate Fertilizer                                A5.9-1

A6    Metals Industries                                          A6-1
A6.1  Iron and Steel                                             A6.1-1
A6.2  Iron Foundries                                             A6.2-1
A6.3  Steel Foundries                                            A6.3-1
A6.4  Ferroalloy Industry                                        A6.4-1
A6.5  Primary Aluminum Smelting                                  A6.5-1
A6.6  Primary Copper Smelting                                    A6.6-1
A6.7  Primary Lead                                               A6.7-1
A6.8  Primary Zinc Smelting Industry                             A6.8-1
A6.9  Secondary Aluminum                                         A6.9-1
A6.10 Brass and Bronze Industry                                  A6.10-1
A6.ll Secondary Lead Smelting                                    A6.11-1
A6.12 Secondary Zinc                                             A6.12-1

A7    Mineral-Based Industries                                   A7-1
A7.1  Cement Industry                                            A7.1-1
A7.2  Structural Clay Products Industry                          A7.2-1
A7.3  Lime Industry                                              A7.3-1
A7.4  Asphalt Concrete Processing      .                          A7.4-1
A7.5  Asphalt Roofing Manufacture                                A7.5-1

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                           CONTENTS  (Continued)

                                                                 Page

                                                                 A8-1
                                                                 A8.1-1
                                                                 A8.2-1
                                                                 A8.3-1
                                                                 A8.4-1
                                                                 A8.5-1
                                                                 A8.6-1

                                                                 A9-1
                                                                 A9.1-1
                                                                 A9.2-1
                                                                 A9.3-1
                                                                 A9.4-1
                                                                 A9.5-1

AID   Solid Waste Reduction Industries                            A10-1
A10.1 Municipal  Waste                                            A10.1-1
A10.2 Industrial, Commercial, and Building Incinerators           A10.2-1

A8
A8.1
A8.2
A8.3
A8.4
AS. 5
A8.6
A9
A9.1
A9.2
A9.3
A9.4
A9.5
Chapter

Manufacturing and Services Industries
Paint Manufacturing Industry
Surface Coatings
Dry Cleaning Industry
Printing Ink Manufacture
Synthetic Fiber (Nylon) Manufacture
Lead-Acid Storage Batteries
Forest and Agricultural Industries
Kraft Pulp Industry
Neutral Sulfite Semi chemical Paper
Grain Elevators
Feed Mills
Plywood Veneer








Industry




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                   Chapter Al  Introduction and Summary


          Section 312(a) of the Clean Air Act ("the Act" or CAA) requires
that the Administrator of the Environmental Protection Agency (EPA) submit
to Congress a detailed summary of the costs incurred to comply with the
Act.  The Cost of Clean Air Report is written in fulfillment of that
requirement.  The report provides air pollution control cost estimates for
each industry (or other source category) that incurs high control costs
and/or produces exceptionally high uncontrolled emissions levels.

          This report includes only those costs incurred to meet federally
mandated regulations.  It does not include all costs of abating air
pollution.  Costs are based on federal regulations and regulations
established by the states in implementation plans submitted to EPA.  The
cost estimates are intended to be incremental costs, meaning that they
exclude costs for the estimated level of control practiced prior to the
1970 Clean Air Act Amendments.

          All abatement costs in this report are stated in January 1981
dollars.  Where costs are derived relative to another time period, these
costs were inflated using the implicit price deflator of the Gross National
Product (fixed nonresidential part).

          Table A1.3 (located at the end of the chapter) summarizes
estimates of the capital investments and annualized costs required for
implementing the Act in 1981 and over the periods 1970-1978, 1979-1981,
1979-1984, and 1981-1990.  Annualized costs include operating and
maintenance costs, deposition, and interest charges.  Each figure in Table
A1.3 is repeated in the appropriate industry chapter, where important
assumptions and background data are presented and discussed.

          The chapter corresponding to each industry is divided into five
sections:  Industry Characteristics,  Emission Sources and Pollutants,
Regulations, Control Technology, and Cost Methodology.   Appendices for each
of the individual chapters are grouped together in a separate volume.  The
appendices contain more detailed cost information, descriptions of
regulations, industry data, assumptions, and references.  A comprehensive
reference list also appears at the end of this volume.   The purpose of this
report is to estimate and summarize air pollution control costs for a very
broad range of industries.  The report is not intended to provide detailed
discussions of production processes and the complete range of applicable
control techniques.  Interested readers are encouraged to consult the
references for more complete technical descriptions and evaluations.
     i
          Note that this report does  not dictate EPA policy with respect to
the application of presently available or projected technology for the
control of effluent quality by any industry or activity.  Simplifying
assumptions were required in order to estimate the effect of EPA
Regulations on the industries included.  The control technologies, or mix
thereof, which were assumed in order to provide these estimates are neither
                                   Al-1

-------
specifically required by law nor by EPA; no contrary interpretation of the
contents of this document should be made.

          The remainder of this introduction is presented in three
sections.  The first section provides an overview of federal air pollution
control requirements and regulations.  The second section briefly describe
several widely used air pollution control  technologies.  The third section
describes the methodology used in this report to estimate air pollution
control costs.  These discussions are presented in this introduction to
avoid excessive repetition within the main body of the report.  A thorough
reading of these sections will enhance the reader's understanding of the
individual chapters.

Federal Air Regulations

          The 1970 and 1977 Clean Air Act Amendments required EPA to
establish national ambient air quality standards (NAAQS).  The Amendments
created two primary programs for meeting these standards.  One program
focuses on mobile source emissions.  Most mobile source regulations are in
the form of limitations on the allowable emission rates of mobile sources,
such as automobiles, trucks, aircraft, and motorcycles.  Responsibility fo
compliance with mobile source standards is primarily borne by vehicle
manufacturers.  These standards are described in greater detail in
Chapter 4.

          The second program for meeting NAAQS involves the control of
stationary source emissions.  Stationary source regulations are implemente
through the states.  The remainder of this section explains the major
components of the stationary source control program.

          Each state is divided into several areas.  These areas are
identified either as in attainment or nonattainment of the air quality
standards for each of six criteria pollutants:  particulate matter, sulfur
oxides (sulfur dioxide), nitrogen oxides, carbon monoxide, ozone
(photochemical oxidants), and lead (40 CFR 52).  The Act requires that eac
state adopt a State Implementation Plan (SIP) to ensure eventual attainmen
and maintenance of air quality standards for nonattainment areas and to
maintain an adequate level of air quality in attainment areas (CAA, Sectio
110; 40 CFR 51).  SIPs must be approved by EPA, after which they are
incorporated  into the Code of Federal Regulations (40 CFR 52).  Each SIP
contains provisions for meeting federal requirements (i.e., requirements
specified in  the Act) and requirements set by the individual state. _!/ In
If When setting stationary source standards to achieve NAAQS for the
   criteria pollutants, states take into account the reduction in emission
   expected to be achieved through the federal mobile source standards.
   SIPs must also include under certain conditions, programs for inspectio
   and testing of in-use motor vehicles, known as an inspection/maintenanc
   (I/M) program [CAA, Section 110(a)(2)(6); 40 CFR 51.11(b)]. Because
   emission levels are lowered as a result of the mobile source controls,
   states may regulate stationary sources to a lesser degree than might be
   the case without the mobile source standards.

                                   Al-2

-------
cases where federal and state emission regulations would govern the same
source, the more stringent of the two generally applies.

          The federal air quality control programs, which are incorporated
into the SIPs, generally distinguish between existing and new sources and
between attainment and nonattainment areas.  The programs include the
following regulations exclusively for new or modified sources:  New Source
Performance Standards (NSPS) for sources in all areas; Prevention of
Significant Deterioration (PSD) regulations, which require Best Available
Control Technology (BACT) for sources in attainment areas; and requirements
that sources in nonattainment areas meet Lowest Achievable Emissions Rates
(LAER).  The federal  programs also include National Emission Standards for
Hazardous Air Pollutants (NESHAP) for new and existing sources in all
areas, and visibility regulations, which require Best Available Retrofit
Technology (BART) for certain existing sources in designated attainment
areas.

          The following discussion first provides a general  description of
the SIPs and their state-specific regulations.  It then more completely
describes the federal air programs listed above.  The section concludes
with an explanation of the regulations costed in this report.

State-Specific Regulations in SIPs

          A State Implementation Plan must specify a control strategy for
each major source located in, or impacting on, a nonattainment area.  This
strategy must be calculated to result in the area's reaching and
maintaining NAAQS'for each pollutant.  More general state regulations,
which are also incorporated into the SIPs, apply to sources  in attainment
and unclassified areas. If  The following discussion focuses on the
state-specific standards, not the federal programs discussed in the next
section.

          SIPs were originally required to establish emission limits for
five criteria pollutants:  particulate matter, sulfur oxides, nitrogen
oxides, carbon monoxide, and ozone. 2J  Lead was added as a  criteria
pollutant in 1978. 3/  The process of determining lead attainment status
and developing lead emission standards is still underway.
If" Some areas are not classified as attainment or nonattainment areas
~~   because of inadequate monitoring facilities.

2/  Hydrocarbons, precursors of ozone, were initially a criteria pollutant,
~   Because "no consistent quantitative relationship exists nationwide
    between ambient air ozone concentrations and hydrocarbon air quality
    levels," EPA revoked the NAAQS for hydrocarbons on January 5, 1983 (48
    FR 627).

3/  October 5, 1978 (43 FR 46270)
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          In addition to the control  of criteria pollutants, the 1977
Amendments [CAA, Section lll(d)] required SIPs to establish limits for
"designated pollutants" that are emitted from "designated facilities."  A
pollutant becomes a designated pollutant if it is not a criteria pollutant
and its emissions are subject to a NSPS.  The NSPS specifies the type of
facility that emits the designated pollutant.  Such facility, if already
existing, is a designated facility.  Requiring states to establish
standards for designated pollutant emissions from existing designated
facilities (40 CFR 60.21) effectively broadens the applicable NSPS to cove
existing facilities.  However, the standards for existing facilities are
not necessarily as stringent as the NSPS.  Designated pollutants/facilitie
include total reduced sulfur (TRS) from Kraft pulp mills, fluorides from
phosphate fertilizer plants, and acid mist from sulfuric acid plants.

          An industry whose production processes emit several pollutants
may be subject to differing emission limits for each pollutant, depending
on the classification of its location.  For example, the area in which a
plant is located may be classified as attainment for particulates but
nonattainment for sulfur oxides.  The cost of meeting emission limits will
depend on the attainment status of the source location and the stringency
of the state's regulatory program.

          EPA encourages states to set nonattainment area emission
limitations that require Reasonably Available Control Technology (RACT)
(CAA, Section 108) for existing major sources.  The Agency provides
guidance to states in defining RACT for specific pollution-emitting
processes.  This guidance includes suggested process weight rate standards
for general process industries and industry-specific emission limits and
control techniques (40 CFR 51, Appendix B).  EPA also provides guidance or
RACT in a series of source-specific control technique guideline documents.
If less stringent limits will result in attaining air quality standards ir
a timely manner, states may avoid requiring RACT levels of control.

          States also have significant flexibility in choosing the
standards applied in attainment areas.  Thus, there may be a great deal of
state-to-state variation in the degree of air pollution control required
for an existing emission source whether that source is a nonattainment are
or an attainment area.  Some states establish general emission limits that
apply to a large group of industries emitting that pollutant; others defir
limits for specific industries.  States may specify standards for each
emission source in a nonattainment area.  In these cases, standards for
similar emission sources may vary from one nonattainment area to another
within the same state.

          The Code of Federal Regulations defines the existing point
sources in nonattainment areas that are subject to SIPs.  These include
stationary sources that emit over 100 tons per year of any pollutant in ar
urban area, those that emit over 25 tons per year of any pollutant in a
non-urban area, and any stationary source listed in Appendix C of Title 4C
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Section 51, of the Code of Federal Regulations (40 CFR 51, Appendix C).  If
This latter category includes certain types of chemical process industries,
food and agricultural industries, metallurgical industries, and mineral
products industries.

Federal Programs For New or Modified Sources

          States are responsible for implementing federal standards for new
or modified sources 2/ through construction permit programs.  Three
categories of standards may be applied to new sources, depending on the
type, size, and location of the source:  New Source Performance Standards
(NSPS), requirements for Best Available Control Technology (BACT), and
Lowest Achievable Emissions Rate (LAER) standards.  Each will be discussed
separately below.

          EPA has established New Source Performance Standards (NSPS) for
more than 30 stationary source categories (CAA, Section III; 40 CFR 60).
Table Al.l lists the sources covered by NSPS that had been promulgated as
of February 1983.  An NSPS governs all new sources in the particular source
category and size range specified by the standard unless BACT or LAER apply
to these sources.

          BACT and LAER requirements govern emissions from certain new
sources in attainment and nonattainment areas, respectively.  Certain
categories of new sources in attainment areas are subject to prevention of
significant deterioration (PSD) preconstruction review, which requires the
use of Best Available Control Technology (BACT) (CM, Part C; 40 CFR
51.24).  Major new sources in nonattainment areas must control emissions to
the Lowest Achievable Emissions Rate (LAER) (CAA, Section 173; 40 CFR
51.18).  The major features of these permit programs are described below.

          Attainment Areas:  The goal of the PSD program is to prevent the
deterioration of air quality in areas where emission levels are below the
national ambient air quality standards (i.e., attainment areas).  Emissions
in each attainment area may be allowed to increase only in specified
increments above the baseline concentration of a pollutant. _3_/  PSD
_!/  The complete definition can be found in 40 CFR 51.1.  An urban area is
    a region with a 1970 urban place population equal to or greater than
    one million/

2J  In the remaining discussion new sources will also include modifications
~   of existing sources.

2J  The PSD regulations set certain requirements for classifying an
    attainment area as Class I, II, or III,for purposes of specifying
    allowable increments.  For example, national parks and wilderness areas
    over a certain size must be designated as Class I areas.  Baseline
    concentration is the ambient concentration within a given area measured
    after August 7, 1977.  Increments are measured in micrograms per cubic
    meter and vary in stringency for each class.  The allowable increment
    is the smallest for Class I areas and the largest for Class III areas.
    Allowable increments currently exist only for sulfur dioxide and total
    suspended particulates.

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              Table Al.l.   New source performance standards*
                  Affected source
                       Date of initial
                        promulgation
Fossil Fuel-Fired Steam Generators
  (_> 250 million Btu and for which construction is
  commenced after August 17, 1971)
Electric Utility Steam Generating Units
  (> 250 million Btu and for which construction is
  commenced after September 18, 1978)

Incinerators
Portland Cement Plants
Nitric Acid Plants
Sulfuric Acid Plants
Asphalt Concrete Plants
Petroleum Refineries

Storage Vessels for Petroleum Liquids
  (constructed after June 11, 1973 and prior
  to May 19, 1978)

Storage Vessels for Petroleum Liquids
  (constructed after May 18, 1978)

Secondary Lead Smelters
Secondary Brass and Bronze Ingot Production Plants
Iron and Steel Plants:  Basic Oxygen Process Furnaces
Sewage Treatment Plants
Primary Copper Smelters
Primary Zinc Smelters
Primary Lead Smelters
Primary Aluminum Reduction Plants
Phosphate Fertilizer Industry:  Wet
  Phosphoric Acid Plants
Process
Phosphate Fertilizer Industry:  Superphosphoric Acid Plants
Phosphate.Fertilizer Industry:  Diammonium Phosphate Plants
Phosphate Fertilizer Industry:  Triple Superphosphate Plants
Phosphate Fertilizer Industry:  Granular Triple
  Superphosphate Storage Facilities
Coal Preparation Plants
Ferroalloy Production Facilities
Steel Plants:  Electric Arc Furnaces
                           12/23/71
                            6/11/79

                           12/23/71
                           12/23/71
                           12/23/71
                           12/23/71
                            3/08/74
                            3/08/74
                            3/08/74
4/04/80

3/08/74
3/08/74
3/08/74
3/08/74
1/15/76

1/15/76
1/15/76
1/26/76

8/06/75

8/06/75
8/06/75
8/06/75

8/06/75

1/15/76
5/04/76
9/23/75
                                                          Continued	
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                         Table Al.l.  (Continued)
                  Affected source
Date of initial
 promulgation
Kraft Pulp Mills                                                2/23/78
Glass Manufacturing Plants                                     10/07/80
Grain Elevators                                                 8/03/78
Stationary Gas Turbines                                         9/10/79
Lime Manufacturing Plants                                       3/07/78

Automobile and Light Duty Truck Surface Coating Operations     12/24/80
Ammonium Sulfate Manufacture                                   11/12/80
Lead Acid Battery Manufacture                                   4/16/82
Phosphate Rock Plants                                           4/16/82
Asphalt Processing and Roofing Manufacture                      8/06/82

Industrial  Surface Coating:  Large Appliances                  10/27/82
Surface Coating of Metal Furniture                             10/29/82
Metal Coil  Surface Coating Operations                          11/01/82
Graphic Arts Industry:  Publication Rotogravure Printing       11/08/82
*0rdered as in the Code of Federal Regulations (40 CFR 60),
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 preconstruction  review  requires  analysis  of  air quality  impacts  that  will
 result  from  the  operation  of  the new  source.   The  specific  Best  Available
 Control  Technology  (BACT)  required  for  a  new source  is determined  on  a
 case-by-case basis,  depending on the  air  quality impact  analysis,
 technological  considerations, and the cost and energy requirements of
 alternative  control  techniques.   Emission levels achievable with BACT must
 be  at least  as stringent as any  applicable NSPS or NESHAP  (described
 below).   If  a source is not covered by  NSPS,  BACT  standards may  be based o
 emission limits  specified  in  SIP regulations  for similar sources.

           PSD review governs  only certain sizes and/or categories  of  new
 sources.  The program covers  any new  source  that has the potential to emit
 at  least 250 tons  per year of any pollutant  regulated under the  Act.   It
 also covers  new  sources in 28 specified categories when  the new  source  has
 the potential  to emit at least 100  tons per  year of  any  pollutant. The 28
 specified categories are listed  in  Table  A1.2.   BACT does  not  apply to  any
 source  emitting  less than  100 tons  per  year  of a pollutant  or  to a source
 that emits between  100  and 250 tons per year of a  pollutant if it  is  not i
 a category listed  in Table A1.2.

           Nonattainment Areas:   The permit program for construction of  new
 major sources in nonattainment areas  requires that any emissions from the
 new source not interfere with progress  toward eventual attainment  of
'national ambient air quality  standards.  States must ensure that addition?
 emissions from a new source are  offset  by at least an equivalent reduction
 of  emissions from  existing sources.   One  approach  available to states is t
 create  margins for growth  by  requiring  additional  emission  reductions froir
 existing sources in  the SIP.   Alternatively,  a state may elect to  implemen
 an  offset policy.   Under an offset  policy, the owner of  the proposed  new
 source  must  negotiate reductions from existing sources.

           Not only  must emissions of  new  major sources be  offset by
 reductions from existing sources, but the new source must  also meet the
 Lowest  Achievable  Emission Rate  (LAER).  LAER must be the  lower  of either
 the most stringent limitation in any  SIP  for that  source category  or  the
 most stringent limitation  available in  practice for  that type  of source.
 Because these standards change over time, LAER is  determined on  a
 case-by-case basis.   LAER  must be at  least as stringent  as  NSPS  and
 generally should be more stringent  than the  emission rates  achievable with
 BACT.

           Each major new source  constructed  in a nonattainment area is
 subject to LAER.  Under regulations requiring LAER,  a major source is
 defined as one having th«  potential to  emit  more than 100  tons per year of
 a pollutant.  LAER is not  required  for  sources emitting  less than  100 tons
 per year of  a pollutant.   For most  industries, fugitive  emissions  are not
 counted in the annual emission rate used  to  determine if LAER  is required.
 Fugitive emissions  are  those  emissions  exiting indirectly  from an  emissior
 source, e.g., leaks  and emissions that  escape during loading and unloading
 material.  However,  fugitive  emissions  are counted for the  source
 categories listed in Table A1.2. The inclusion of fugitive as well as
 process emissions  for those 28 categories effectively lowers the tons per
 year emission threshold for LAER.

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        Table A1.2.  Source categories subject to PSD regulations*


          Fossil fuel-fired steam electric plants (> 250 million Btu/hr
            heat input)
          Coal cleaning plants (thermal dryers)
          Kraft pulp mills
          Portland cement plants

          Primary zinc smelters
          Iron and steel  mill  plants
          Primary aluminum ore reduction plants
          Primary copper smelters
          Municipal incinerators (capable of charging > 250 tons
          refuse/day)

     •    Hydrofluoric, sulfuric, nitric acid plants
     •    Petroleum refineries
     t    Phosphate rock processing plants
     •    Coke oven batteries
     •    Sulfur recovery plants

     t    Carbon black plants
     •    Lime plants
     •    Furnace process:  primary lead smelters, fuel conversion plants,
            sintering plants
     •    Secondary metal production facilities

     t    Chemical  process plants
     t    Fossil fuel boilers  (> 250 million Btu/hr heat input)
     *    Petroleum storage and transfer facilities (capacity > 300,000
            barrels)
     •    Taconite ore processing facilities

     •    Glass fiber processing plants
     •    Charcoal  production  facilities
*If having the potential to emit at least 100 tons per year of any
 pollutant.
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Federal  Programs for Existing Sources

          There are two federal  programs that cover existing emissions
sources.   National  Emission Standards for Hazardous Air Pollutants
(NESHAPs) cover both new and existing sources, and Best Available Retrofit
Technology (BART) is applied to  existing sources.   Each is discussed
separately below.

          NESHAPs.   NESHAPs set  limitations for specific hazardous
pollutants from specified sources.   Many of the regulations are generic,
covering many types of sources tnat emit the specified pollutant (40 CFR
61).  The Clean Air Act defines  a hazardous air pollutant as one "to which
no ambient air quality standard  is  applicable and  which causes or
contributes to air pollution which  may reasonably  be anticipated to result
in an increase in mortality or an increase in serious irreversible or
incapacitating reversible illness," [CAA, Section  112 (a)(l)].  NESHAPs
have been established for asbestos, beryllium, beryllium rocket motor
firing, mercury, and vinyl chloride.  NESHAPs also have been proposed to
limit benzene emissions from several sources.

          BART.  The federal visibility protection program was designed tc
prevent or remedy visibility impairment in mandatory class I Federal areas
I/ (CAA, Section 169A; 40 CFR 51.300).  The regulations require the
installation of BART by major existing stationary  sources in operation on
August 7, 1977, and not in operation prior to August 7, 1962.  Under
regulations requiring BART, major stationary sources are defined as source
listed in Table A1.2 that have the  potential to emit more than 250 short
tons per year of any one pollutant.

Regulations Covered in the Cost  of  Clean Air Report

          The Cost of Clean Air  Report includes the cost of compliance wit
SIPs, NSPS, NESHAPs and in a few instances, BACT or LAER.  The term "SIP"
is used in this report to refer  to  the state regulations that are mandatec
by the Clean Air Act but not included in other federal programs such as
NSPS or NESHAPs.

          SIP costs are usually  estimates of the cost of complying with
either an average SIP standard or the standard established by the majority
of SIPs.  Either of these control levels is often  achievable with RACT (4C
CFR 51, Appendix B).  States often  differentiate between new and existing
sources in setting emission limits.  New sources are generally required tc
meet more stringent standards.  This does not necessarily imply greater
control costs for new sources, however,' because it is often less expensive
to install pollution controls during plant construction than it is to
retrofit them.  In cases where there are significant compliance cost
I/  An area designated as mandatory class I under the PSD program (see
    footnote 1, page 8) has the lowest maximum allowable ambient air
    concentration of criteria pollutants of the three classes of PSD areas
    and may not be designated as other than a class I area.
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differences between new and existing sources, SIP costs may be estimated
separately for each.

          BACT and LAER are not costed separately except where information
was available from a detailed industry study (Electric Utilities and Iron
and Steel).  The BACT and LAER compliance costs are difficult to estimate
because of the source-specific nature of the regulations.  BART compliance
costs are not available.  The regulation discussion in each chapter does
not review the BACT, LAER, or BART regulations, which were described
earlier in this section.

Control Technologies

          The following discussion provides a brief description of the most
widely used control devices installed on stationary sources in
manufacturing industries.  Three of the devices are used solely for
particulate matter control — mechanical collectors, electrostatic
precipitators, and fabric filters.  Wet scrubbers are used to control both
particulate matter and sulfur dioxide.  Combustion devices are used
primarily to control volatile organic compound (VOC) and carbon monoxide
emissions; they also remove particulate matter.  Three other techniques are
used for VOC control - adsorption, absorption, and refrigeration.

          Mechanical collectors are low efficiency particulate control
devices that remove larger particles with relatively simple capture
mechanisms.  Settling chambers and cyclones are the most common types of
mechanical collectors.  Settling chambers use gravity to collect particles
on multiple trays and ultimately on the bottom surface of the chamber by
controlling the velocity of the gas stream as it passes through the
chamber.  Cyclones employ centrifugal force in a turning gas stream to
force particles against cylindrical walls.   Particles are collected for
discharge at the bottom of the cyclone collector while clean gas passes out
the top through a center tube.

          Mechanical collectors are normally chosen to improve the
efficiency of other control devices or of the production process itself.
Their own relatively low removal  efficiency is insufficient to meet most
federal air pollution control standards.

          Electrostatic precipitators (ESPs) remove sub-micron-sized
particle matter from large volume gas streams that are easily ionized.   The
ESP charges particles with electrical energy by passing the gas stream
through an electrostatic field. .The particles are neutralized and
collected on a surface with opposite polarity and removed by mechanical
devices.  Collection efficiency,  which can  exceed 99 percent, depends on
the length of time particles are  exposed to the electrostatic field,  the
strength of the field, and the resistivity  of the particles, a factor that
varies with temperature and the moisture content of the gas..

          Fabric filters achieve  high efficiency particulate removal  from
gas streams with dry particulates or process gases with water in the  vapor
state.  The fabric filter, also called a baghouse, is composed of

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compartments of filter bags or tubes.  As the gases are forced through eac
compartment, particles are captured on the surface of the fabric bags.
After a period of particulate collection, the filter surfaces are cleaned.

          Fabric filters are often classified according to the method of
cleaning:  shaker type, reverse air, or pulse jet.  The cleaning method
depends on the durability of the fabric material.  Cleaning can take place
continuously during the filtering process or intermittently, between
periods of filtering.  The removal efficiency of the unit, which can excee
99 percent, varies according to the air-to-cloth ratio, type of material ,
and the characteristics of the gas stream.

          Wet scrubbers may be installed solely for particulate collection
or as part of a flue gas desulfurization (FGD) system.  FGD systems collec
both particulate and sulfur dioxide emissions from boilers.  The most
common type of wet scrubber is the venturi scrubber, which achieves
collection efficiencies higher than 99 percent for one micron or larger
particles and from 90 to 99 percent for smaller particles.  The venturi
scrubber removes suspended particles from gas streams by generating
atomized droplets; these droplets entrap particles in the gas stream
through collision and agglomeration.  A separator removes the agglomerates
from the gas stream, usually by centrifugal force.

          FGD systems include both a scrubber and a gas cooler in the
separator.  The gas cooler serves as an absorber for removing sulfur
dioxide for the flue gas.  Sulfur dioxide in the flue gas reacts with the
scrubbing solution and forms a sludge.  The sludge is then disposed of in
landfill.  Sulfur dioxide removal efficiency can range from 80 to 95
percent.

          Combustion devices are primarily installed to control VOCs,
carbon monoxide, and odorous compounds, although they also remove
particulate matter.  They are most efficiently applied to sources with
combustible gases, low gas flow rates, and low particulate concentrations.
The exhaust or fugitive process gases are directed through vents to a
combustion chamber for combustion to carbon dioxide and water vapor.

          Incinerator systems (also called "afterburners") are categorized
into two types according to the burning mechanism:  (1) direct and thermal
and (2) catalytic.  Direct and thermal incinerators are similar; both rely
on simple combustion.  The difference between them is that thermal
incinerators require additional fuel to achieve combustion.  Thermal
incinerators can achieve removal efficiencies in excess of 95 percent.

          Catalytic incinerators employ a catalyst bed to achieve
combustion at a lower temperature than thermal incinerators; they are
better suited for gas streams containing organic vapors or solvents.  Thei
removal efficiency depends on the catalyst characteristics, gas velocity,
oxygen concentration, operating temperature, and waste gas concentration.

          The cost-effectiveness of incineration can sometimes be improved
by making use of the heat generated in the incineration process.  The heat

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may be used either as an aid in the combustion process itself (primary heat
recovery) or to generate steam for use in other processes (secondary heat
recovery).

          Adsorbers remove organic liquid and vapors from process streams
that do not contain particulates or water-soluble compounds.  Adsorbent
materials must be highly porous for gas molecule penetration and have a
large surface area.  The most widely used adsorbent is carbon.

          The process waste stream is cleaned when pollutant compounds are
mechanically and chemically bonded to the granular surface of the
adsorbent.  Removal efficiency is nearly 100 percent during initial
adsorption.  When the adsorbent becomes saturated and efficiency begins to
drop, the adsorbent is regenerated at a high temperature to remove the
pollutants.  Both the captured vapors and the adsorbent are recovered for
reuse after regeneration.

          Absorbers are primarily used to control VOC emissions.  The
absorbent, a liquid solvent, removes gaseous pollutants from a process
stream by dissolving or chemically combining with the solute of gaseous
organic compounds.  The liquid-gas mixture can then be desorbed to remove
the solute and recover the solvent, or it may simply be returned to storage
with the volatile organic liquid that was the source of the emission.

          Absorption is most commonly used for recovering hydrocarbons from
petroleum storage and transfer operations.  In many cases it is used in
conjunction with other pollution control techniques.

          Refrigeration removes pollutants from a gas stream by
condensation^Gaseous pollutants are condensed for removal  or recovery
when the gas stream is cooled.  One of two different cooling processes may
be used.  Surface condensers refrigerate the vapors without contact, by
cooling the walls that separate coolant from vapor.  Contact condensers
cool the vapor by spraying the coolant on the gas stream.

          Vapor recovery systems used in collecting VOC emissions from
storage and transfer of volatile organic liquids employ refrigeration and
condensation as stages of the process.  Refrigeration is often used in
conjunction with other control techniques.  It must generally be followed
by a secondary control system to treat the non-condensible gases.
Refrigeration can also be employed to condition the solvent in absorption  -~
systems.

Cost Methodology

          Cost estimates for each industry are presented in a table
following the corresponding chapter text.  To estimate compliance costs the
industry is usually divided into a number of sectors.  Sectors are defined
according to production process, control technology, regulations, available
cost data, or any other factors that can influence costs.  The cost data
for an individual sector may take one of two forms:  "exogenous" total


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costs, or cost functions.  The cost methodology section in each chapter
indicates the type of cost data used in that \chapter.

          Exogenous costs are calculated outside the computer model for t\
report.  The exogenous form is sometimes used because the complexity of tf
chapter precludes the use of cost functions alone.  In other instances,
these costs are taken from a detailed economic study of the industry
commissioned by the EPA.  The use of these studies improves the consistenc
and coherency of this report with other EPA publications.  Some of these
economic reports may not provide detailed information about control costs.
In these cases the reported costs do not necessarily conform to the
standard format, e.g., new plant costs may not be separately identified,
although costs projected into the future include costs for both new and
existing plants.  Similarly, the source document may not use the same
breakdown of annual costs or the same interest rate as is normally used ir
the existing computer model.  Nevertheless, the overall costs and timing c
the costs are reported as developed in the designated source document.

          Costs in most chapter sectors are generated from cost equations
that express control costs as a function of plant capacity.  (Larger plant
usually benefit from economies of scale.)  In most cases future cost
estimates are based on the assumption of continued application of current
technologies.  Capital and operating and maintenance costs are calculated
separately.  The computer program computes total industry costs by applyir
the cost functions to industry plant data, taking into account compliance
schedules estimated by the chapter author.  The cost functions, which are
based on engineering model plant costs, are expressed in a standard
exponential form:  Cost = AX  , where X is a measure of capacity.  O&M cost
are adjusted according to estimates of capacity utilization percentages.
Industry plant data include the plant population for a base year,
historical growth rates, and expected future growth rates.  Compliance
information is simply the percentage of the plant population that compliec
with a regulation in each past year and estimates of the percentage that
will comply in each future year.  These estimates are based on the
compliance date specified in the pertinent regulation, allowing for lead
time required to construct and install the control technology required.
New plants are assumed to comply upon construction.

          To calculate the annual cost of capital, the computer program
uses the stated life of the control equipment and a real, before-tax
interest rate of ten percent.  The interest rate accounts for the
"opportunity" cost of control equipment investment funds.  Moreover,
because  income taxes are not considered, these costs represent the total
costs  to society for pollution co'ntrol.-  It is understood that other'
systems of depreciation are used, that other interest rates are sometimes
applicable, that "opportunity costs" for other uses of capital are not
taken  into account, and that tax write-offs are commonly applied to contrc
equipment.  The ten percent interest rate is used as a "compromise" value
which  is intended to reflect an average value of the highly varied
individual cases.

          The computer program also calculates the cost of replacing
control equipment at the end of its useful life.  These costs are assumed
to be  some fraction of the original cost of equipment as certain elements,
such as  the foundations, do not need to be replaced.

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          The program excludes costs associated with air pollution control
that would have been incurred without the inducement of federal
regulations.  It does this by excluding from the plant population a
precompliance fraction that is provided by the chapter author.  This
fraction represents plants that either can comply with the applicable
regulation without installing controls or plants that installed controls
even in the absence of regulations.  When estimating compliance costs for
SIPs, this precompliance fraction may also include the percentage of the
plant population not regulated by SIPs.  (Some plants are not covered by
SIPs because they are located in states whose SIPs do not have regulations
governing the industry or because certain plants are exempted by the SI'Ps.)

          When pollution control results in product or by-product recovery,
the value of the recovered product is calculated and credited against the
O&M costs associated with the control.  Credits are estimated by
multiplying the price of the recovered product by the amount of the
recovered product.  In some cost sectors, the O&M costs or cost function
have been estimated net of credits.  In other cases, credits or credit
functions have been estimated separately.  In credit function sectors,
credits, like costs, are expressed as an exponential function:  Credit =
AX , where X is a measure of capacity.  Credits, in the same way as O&M
costs, are adjusted according to capacity utilization estimates.  In cases
when credits exceeded costs on an annualized basis for a sector, it was
assumed that the control technique would be adopted for economic reasons.
Neither the sectors costs nor credits were included in the cost estimates
of this report.

          The bulk of the cost estimates are for compliance with SIP, NSPS,
and NESHAP regulations.  Very little information is available on BACT and
LAER costs; NSPS costs were often used as a surrogate.  Except where
NESHAPs are involved, there is also very little information available on
fugitive emission control costs.  The report does not include cost
estimates for most fugitive emission controls.

          Most cost estimates presented in this report are based on the
cost of installing and operating controls to meet standards at each
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available for some facilities either through creation of emission bubbles
or by trading emission reduction credits with other facilities.

          This cost methodology differs from that followed in the August,
1979 report in that it:

          1. includes estimates of replacement costs, and

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                          Chapter A2  Government

          This chapter presents estimates of expenditures made by federal,
state, and local  governments for both air pollution control  programs and
control  of air pollution emitted from government facilities.

          The principal  expenditures in the government sector are
programmatic—for research, monitoring, administration, and  enforcement.
Research is supported primarily by federal  funds.   Most state and local
funds, supplemented by federal  grants, are directed toward the development
of regulations, monitoring, and enforcement.

          Governments also incur the cost of meeting air pollution
standards at government facilities.   At the federal level, the Department
of Defense, the Tennessee Valley Authority, and the Department of Energy
are the major sources of such expenditures.

          Table A2.1 presents the pollution control expenditures made by
EPA, non-EPA federal agencies,  and state and local  governments.   The EPA
expenditures are also reported  in Table A2.2, disaggregated  according to
administration, enforcement, research and development, and grants to state
and local governments.  The grants to state and local  governments are
subtracted from the EPA total in Table A2.1, because they are included with
the state and local government  expenditures in Table A2.1.

          Table A2.3 summarizes total government expenditures.   Because  of
the nature of the data,  total costs  are not divided between  capital  and  O&M
costs components.
                               A2-1

-------
            Table A2.1  Federal,  state,  and local  expenditures
                         on air pollution control
               (by fiscal  year in millions of 1981 dollars)
Year
1970
1971
1972
1973
1974
1975
1976*
1977
1978
1979
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
EPAa
185
169
191
213
185
175
189
159
144
193
233
145
135
115
115
115
115
115
115
115
115
Non EPA
federal
190
292
493
613
619
303
235
336
372
308
280
228
226
189
189
189
189
189
189
189
189
Total
federal
375
461
684
826
804
478
424
495
516
501
513
373
361
304
304
304
304
304
304
304
304
State &
local0
149
183
245
261
204
188
204
278
343
354
234
233
218
206
206
206
206
206
206
206
206
Total
524
644
929
1087
1008
666
628
773
859
855
747
606
579
510
510
510
510
510
510
510
510
*Includes transition quarter

Sources:  aTable A2.2.
           U.S.  Office of Management and Budget,  Special  Analyses  Section
           52.2, 1980, 1982 and 1984 Budget of the U.S.  Government,
           Appendix to the Budget of the U.S.  Government.   For updated air
           pollution control  expenditures refer to the 1985 Budget of the
           U.S.  Government.

           EPA,  Office of the Comptroller, includes federal grants and
           state matching share.
                                  A2-2

-------
   Table A2.2.  U.S. EPA air pollution control expenditures by category
               (by fiscal year in millions of 1981 dollars)
                      (values independently rounded)
Year
1971
1972
1973
1974
1975
1976*
1977
1978
1979
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
Administration
83
103
155
163
145
135
162
139
138
214
147
133
119
119
119
119
119
119
119
119
Enforcement
.
--
3
7
16
17
22
21
27
35
29
27
18
18
18
18
18
18
18
18
Research &
development
140
116
119
133
97
87
93
73
57
77
59
60
53
53
53
53
53
53
53
53
Total
223
219
277
303
258
239
277
233
222
326
235
220
190
190
190
190
190
190
190
190
Grants to
state
and local
govts.**
52
65
84
92
72
66 '
89
75
78
93
90
84
77
77
77
77
77
77
77
77
 *Includes transition quarter.
**These grants are included in the administration category.

Sources:  Hearings before a subcommittee of the Committee on Appropria-
          tions.  U.S. House of Representatives EPA Budget Preparation and
          Control  Division.  U.S. Budget.  Environment and Natural
          Resources Section, CEQ, En y'Tron mental Quality 1971.  Cost of
          Clean Air, EPA, 1973.  EPA Grants Assistance Division Appendix to
          the 1980 'U.S. Budget.  EPA Justification of Appropriation
          Estimate for the Committee on Appropriations,. FY 1983 and FY
          1982.
                                  A2-3

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                      Chapter A3.   Energy Industries
          For the purpose of this report, the broad category "Energy
Industries" was defined to include those industries which gather, transfer,
process, and deliver energy to the consumer.   These include:  Fossil-Fuel -
Fired Electric Power Plants, and, because of the similarities with other
industries included in this category with respect to technology, Industrial
and Commercial Heating Boilers.   Also included are a group of industries
which process and deliver fuels  to various consumers.   These include:

             Natural Gas Processing
             Petroleum Refining
             Coal Cleaning
             Coal Gasification
             Wood Waste Boilers

          One important and relevant subject  that is not included here
appears in another Chapter.

          •  Producing and using gasoline with little  or no lead is
             discussed in Chapter 4, "Mobile  Sources."

          Air pollution abatement costs  are summarized in Table A3.
                                   A3-1

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             Chapter  A3.1  Fossil-Fuel-Fired Electric Plants
          This chapter covers the cost of compliance with SIPs and NSPS by
fossil-fuel-fired boilers and stationary gas turbines in electric utility
power plants.  Estimated costs include the cost of equipment that controls
particulate, sulfur dioxide, and nitrogen oxides emissions and premiums
paid for low sulfur fuel to reduce sulfur dioxide emissions during
combustion.

Industry Characteristics

          Electric utilities produce 97 percent of the electricity
generated in the United States;  the remainder is generated by industrial
and commercial establishments.  Most utility power plants generate
electricity by producing steam from burning fossil fuels (coal, oil, and
gas).  Other plants are powered by water (hydro) or nuclear power.

          This section discusses the ownership, capacity, and production of
all types of power plants.   It also describes the distribution of fuel  use
by fossil-fuel-fired power plants and gas turbines.

          Ownership.  Both private companies and public agencies
(municipalities and federal agencies) own electric utility systems.   All of
these utilities, because of their monopoly position in local markets, are
regulated by local or state governments.  Most private companies and
municipalities both generate and distribute electricity to industries,
commercial  establishments,  and residences.  The federal agencies, however,
only operate the generating units.  They sell the electricity to local
service companies or rural  cooperatives for distribution to consumers.

          About 200 private utility companies operate 80 percent of  total
installed capacity and 90 percent of steam generating capacity.  Half of
the publicly owned capacity is operated by almost 200 municipalities, and
half by five federal agencies.  One of the federal agencies, the Tennessee
Valley Authority, controls  the largest electricity generation system in the
United States.

          In 1979 revenues  from sales of electricity totalled $71 billion
for private companies, $6 billion for municipalities, and $3 billion for
federal agencies.  Utilities are classified into SIC 4911, Electric
Services.

          Capacity and Production.  Installed utility capacity in 1980
totalled 614 million kilowatts,  and electricity production totalled  2.3
trillion kilowatt hours.  Both capacity and production increased at  about
5 percent per year between  1970  and 1980.  Production is expected to
increase at less than 2 percent  per year through 1990.
                                  A3.1-1

-------
          During the 1970's, there was a change in the distribution of
total capacity and production by type of unit.  The use of steam generatio
and hydropower declined relative to nuclear power.  Both the capacity and
electricity generation of steam powered units fell from 83 to 78 percent o
the total, while that of hydropower plants fell from 16 to 12 percent, and
that of nuclear power plants increased from 1 to 10 percent.  In the next
ten years, the fraction of total electricity production is expected to fal
for steam generation, to remain unchanged for hydropower, and to continue
growing for nuclear power.

          Distribution of Fossil-Fuel-Fired Units.  There are 934 power
plants with fossil-fuel-fired boilers (steam generators) and 541 with gas
turbines.  Most utility boilers have a capacity larger than 73 megawatts
(250 million Btu per hour)  although some are as small as 30 megawatts (100
million Btu per hour).  They are designed to burn coal, oil, gas, or a
combination of these fuels.  Utility gas turbines, which have a capacity
between 15 and 100 megawatts (50-350 million Btu per hour), burn only oil
or gas.

          Between 1970 and 1980, conventional steam power plant capacity
increased 40 percent from 260 to 425 million kilowatts.  The average annua
capacity utilization rate, called the load factor, for these boilers range
from 0.3 for natural gas and distillate oil units to 0.6 for coal units.
These factors are low because the seasonal demand for electricity requires
utilities to maintain excess capacity.

          There are currently more than 2,000 steam electric generating
units.  Forty-seven percent burn coal, and the remainder are fairly equal!
divided among those burning oil, gas, and a combination of oil and gas.
The coal-fired units account for 60 percent of capacity, with the remainir
capacity equally divided among the other three categories.

          Stationary gas turbine capacity at power plants more than
tripled, from 16'to 51 million kilowatts, in the 1970's.  Because gas
turbines are only used at peak load periods, each one is operated an
average of only 500 hours a year.  As a result, gas turbines provide only
1.5 percent of fossil-fuel-fired power generated by utilities.

          Utilities consume 80 percent of coal, 5 percent of distillate
oil, 50 percent of residual oil, and 20 percent of natural gas sold in the
United States.  Between 1970 and 1980, the consumption of coal by utilitie
increased at 5 percent per year to 890 million short tons.  Oil consumptic
increased at 8 percent per year from 1970 to 1978.  It then fell at 20
percent per year, reaching 360 million barrels in 1981.  Natural gas
consumption declined between 1970 and 1976 at an annual rate of 4 percent
and then increased between 1976 and 1980 (to 3.7 trillion cubic feet), als
at a 4 percent annual rate.  In the 1980's, utility demand for fuels is
expected to increase at 2 percent per year for coal and to decrease at 5 t
6 percent per year for oil  and gas.

          The substitution of coal for oil reflects the relatively higher
price for oil.   It also reflects Department of Energy policies that
discourage the use of oil and gas and require that all newly constructed
boilers burn coal.  Oil and gas utility boilers were not ordered in the
late 1970's and are not expected to be ordered in the future.
                                  A3.1-2

-------
          This forecast growth in utility boiler capacity reflects this
substitution of coal for oil and gas.  Between 1980 and 1990, coal-fired
boiler capacity is expected to grow at 3.5 percent per year, oil and
gas-fired capacity is expected to decline at an annual rate of 1.4 percent,
and gas turbine capacity is expected to increase at 2.9 percent per year.

Emission Sources and Pollutants

          Both steam generators (boilers) and stationary gas turbines emit
air pollutants in their flue or exhaust gases.  The type and level of
emissions depend on fuel characteristics, equipment design, and various
combustion factors.

          Natural gas and distillate oil  are considered clean fuels because
of their low ash and sulfur content and their relative ease in burning with
high efficiency.  Coal and most residual  oils contain significant amounts
of sulfur and ash, require more sophisticated combustion equipment, and are
more difficult to burn at high efficiencies.

          This section discusses the operation and primary emissions of
each type of utility boiler (coal, oil, and gas)  and of stationary gas
turbines.

          Utility Boilers.  All utility boilers are of the water-tube
design.  Air and fuel enter the combustion chamber of the boiler through
multiple burners.  The combustible matter reacts  with oxygen in the air to
release thermal energy.   Water-filled tubes in the walls of the chamber
absorb the thermal energy and generate steam.  The steam turns the blades
of the steam turbines in the generator, producing electricity.  Superheat
and reheat sections of the generator allow further stages of heat transfer
and gas cooling, thus permitting efficient use of the combustion gases.

          There are several types of water-tube boilers, which differ
according to firing equipment, fuel  handling system, and placement of the
burners on the firing wall.  The four most common types—tangential, single
wall, horizontally opposed, and turbo furnace—can burn coal, oil, gas or a
combination of these fuels.

          Coal-fired utility boilers are  primarily the pulverized type,
firing coal that has been finely ground.   There are also a few stoker
utility boilers that burn coal.

          Three types of coal-burning units—cyclone, vertical,  and
stoker—are no longer sold, but a few remain in use.  Cyclone boilers
cannot be adapted to meet emissions  regulations.   Vertical  boilers
primarily burn anthracite coal, which is  declining in use,  and stoker
boilers have design capacity limitations.

          In a pulverized boiler, part of the coal  is burned in  the fuel
bed, and part in suspension.  Particulate emissions from pulverized units
are lower for boilers with the wet bottom than the dry bottom design.   In a
wet or slag bottom furnace, the temperature is maintained above  the ash


                                  A3.1-3

-------
fusion temperature so that the ash is melted and can be removed from the
furnace as a liquid or slag.   Thus, as little as 50 percent of the ash is
emitted in the flue gas.  In a dry bottom furnace, the temperature is
maintained below the ash fusion temperature so that the ash will not fuse.
Nearly all the ash particles are formed in suspension, and about 80 percer
of the ash leaves the furnace entrained in the flue gas.

          The ash content of coal, along with type of combustion unit, fue
feed rate, and the degree of fly ash (ash in the flue gas) reinjection,
determines the quantity of uncontrolled particulate emissions.  A typical
ash content for coal is 9 percent by weight, although it may range from 3
to 30 percent.

          In a coal-fired furnace, from 90 to 95 percent of sulfur in the
coal is converted to sulfur oxides, which are emitted in the flue gas.  Tl-
balance of the sulfur is emitted in the fly ash or removed with the slag c
ash in the furnace.  Sulfur levels in coal range from trace amounts up to
percent by weight.  Western low sulfur coals average 1.6 percent sulfur;
Eastern medium sulfur coals average 2.2 percent sulfur; and Central high
sulfur coals average 2.8 percent sulfur.

          The nitrogen oxides emission rate, which is lower than that of
particulates and sulfur oxides in coal-fired utility boilers, depends
primarily upon the firing method.  Among coal-fired utility boilers, the
cyclone boilers have the highest emission rate, and tangential boilers hav
the lowest.

          Oil- and gas-fired utility boilers burn liquid fuel in
suspension"!  Combustion of residual oil results in much higher levels of
particulate and sulfur dioxide emissions than combustion of distillate oil
Residual oil is the only liquid fuel with significant levels of ash.  In
boilers firing residual oil, however, particulate emission can be reduced
by as much as 60 percent when the boiler is fired at low loads.

          In fuel oil combustion, almost all of the sulfur in the fuel is
converted to sulfur oxides.  The sulfur content of residual fuel ranges
from 0.5 to 2.0 percent, while that of distillate oil averages 0.25
percent, and that of natural  gas, only a trace.

          Nitrogen oxides emissions from firing residual oil are primarily
organic, formed from the nitrogen content of the fuel.  Almost all nitroge
oxide emissions from firing distillate oil and gas, which have low nitroge
content, are thermal, formed from nitrogen in the combustion air.  The
level of thermal nitrogen oxides emissions depends on the firing
configuration.  Nitrogen oxides emissions are the only significant
emissions from gas-fired boilers.

          Utility Stationary Gas Turbines.  Stationary gas turbines are
rotary internal combustion engines fueled by distillate oil, natural gas,
or diesel fuel and occasionally by residual or crude oils.  Air first
enters a compressor where it is pressurized before passing to the
combustion chamber.  Fuel is then introduced into the chamber and burned.
                                  A3.1-4

-------
Hot combustion gases are rapidly quenched by secondary dilution air and
then expanded through the turbine, which drives the compressor and provides
shaft power.  The hot gases are further expanded across the power turbine
blades that drive the electrical generators and then exit as exhaust gases.

          The major pollutants emitted by stationary gas turbines are
sulfur oxides and nitrogen oxides.  As with oil-fired boilers, virtually
all of the sulfur content in the fuel is converted to sulfur oxides.
Organic nitrogen oxides are formed from burning fuels with nitrogen content
while thermal nitrogen oxides emissions are generated with all fuel types.
Because residual and crude oils have the highest sulfur and nitrogen
content of the liquid fuels, turbines that burn these fuels have higher
emission rates then those that burn other liquid fuels.

Regulations

          Electric utility regulations in three NSPS and in SIPs govern
fossil-fuel-fired utility steam generating units (boilers) and stationary
gas turbines at power plants.  These regulations set limits for particulate
matter, sulfur dioxide, and nitrogen oxides from boilers, and sulfur
dioxide and nitrogen oxides from stationary gas turbines.

          NSPS.  Two NSPS regulate all fossil-fuel-fired steam generators
with a heat input rate of greater than 250 million Btu per hour.  The NSPS
(40 CFR 60.40) promulgated December 23, 1971,  established limits for units
that commenced construction after August 17, 1971, and before September 19,
1978.  The revised NSPS (40 CFR 60.40a), promulgated June 11, 1979, set
more stringent limits for units commencing construction after September 18,
1978.

          The NSPS regulations include emission limits for particulates,
sulfur dioxide, and nitrogen oxides.  These limits vary according to the
type of fuel burned (solid, liquid, and gaseous).   The revised NSPS
requires not only a limit on emissions from flue gas but also a reduction
in potential pollutant concentration in combustion gases.  This type of
standard discourages the burning of low ash and low sulfur fuel  as a
control method and encourages the installation of flue gas control devices.

          Another NSPS (40 CFR 60.330), promulgated September 10, 1979,
covers nitrogen oxides and sulfur dioxide emissions from stationary gas
turbines with heat input at peak load equal  to or greater than 10.7
gigajoules per hour.  This NSPS regulates the  larger-sized turbines
(greater than 10 million Btu per hour) that are operated by utilities
during peak load periods.

          SIPs.  States establish general emission limits for particulates,
sulfur dioxide, and nitrogen oxides from all combustion sources, including
utility boilers and turbines.  The regulations vary within and among states
according to characteristics of the combustion source.  These
characteristics include heat input rate, age (new or existing),  fuel  type,
facility size, and geographic location (attainment or non-attainment area).
                                  A3.1-5

-------
          The emission limits for sources with a heat input rate greater
than 100 million Btu per hour apply to utility steam generating units.
Utility stationary gas turbines are governed by the limits for sources wit
a heat input rate of over 50 million Btu per hour.

          Particulate emission limits are more stringent for the large
boilers than for the smaller turbines, but the sulfur dioxide regulations
generally do not vary according to source size or heat input rate.  For
those SIPs that differentiate among fuel types, the sulfur dioxide limits
for residual oil are generally more stringent than those for coal.  Most o
the sulfur dioxide regulations for existing sources are designed to be met
by burning low sulfur fuel rather than by installing controls for reducing
emissions in the flue gas.

          Nitrogen oxides standards are included in only 16 SIPs.  They
generally apply to combustion sources with a heat input rate of greater
than 250 million Btu per hour.  In those 16 states most utility boilers
that are not already covered by NSPS are affected by these limits.

Control Technology

          Particulate Controls.  Particulate emissions from utility boiler
can be controlled with low efficiency mechanical collectors or with high
efficiency controls such as electrostatic precipitators, wet scrubbers, an
fabric filters.  Each technology is discussed briefly below.

          Mechanical collectors (cyclones) are capable of removing only
larger particles.  They do not achieve the level of efficiency required by
the more stringent SIPs or by NSPS.  Cyclones are placed on most coal-fire
boilers without the inducement of federal regulations, because
recirculating the larger particulates into the furnace for further burning
increases boiler efficiency.  Their costs are not included in this chapter

          Electrostatic precipitators (ESPs) are the most widely used
particulate control technology for utility coal- and residual oil-fired
boilers.  Only a few utility coal-fired boilers have fabric filters.   Both
types of equipment can achieve removal efficiency above 99 percent.

          Sulfur Dioxide Controls.  Sulfur dioxide emissions can be
controlled by removing the sulfur oxides from the combustion gases (flue
gas desulfurization) or by switching to low-sulfur fuel.   The use of low
sulfur fuels rather than the installation of a flue gas control device has
been encouraged by the emission standards in most SIPs.  However, the most
recent NSPS for large boilers, which requires a reduction in potential
emissions in the flue gas, virtually requires a flue gas control device on
newly constructed utility boilers.

          Flue gas desulfurization (FGD) systems are installed on utility
boilers primarily to control sulfur dioxide emissions although they also
control particulate matter.  These systems include an ESP or prescrubber,
which removes fly ash from the flue gas, and an absorber, where the flue
gases are then scrubbed or absorbed in a scrubbing solution.  Sulfur


                                  A3.1-6

-------
dioxide reacts with the slurry in the scrubber-absorber and forms a sludge
or a sulfur by-product.  FGD processes are usually categorized as
nonregenerable or regenerate.  The nonregenerable process produces the
sludge waste product that requires ponding or treatment to permit disposal
in a land fill.  Regenerate FGD processes recover sulfur dioxide from the
combustion gases and convert it into marketable by-products such as sulfur,
sulfuric acid, and liquid sulfur dioxide.

          Nonregenerable FGD processes are better developed and more widely
applied to utility boilers.  They include lime or limestone scrubbing, the
dilute or concentrated double alkali process, and scrubbing with sodium
carbonate or sodium hydroxide solutions.   These FGD systems can generally
be designed to provide sulfur dioxide removal efficiencies of 80 to 95
percent under normal operating conditions.

          Some of the regenerate processes have been demonstrated in
systems of over 100 MW capacity but they  are not in wide use.  These
processes include wet scrubbing systems such as the magnesium oxide,
Wellman-Lord, and citric acid processes and a number of dry sorbent types,
which do not require water quenching of the combustion gases.  Sulfur
dioxide removal efficiencies in excess of 90 percent have been
demonstrated.  Regenerable systems generally have a higher initial  cost and
operating expense than the nonregenerable processes and depend on credits
from selling the by-product sulfur to partially offset the higher cost.

          Burning low sulfur fuels is the other strategy commonly used to
limit sulfur dioxide emissions.  Low sulfur coal and oil may occur
naturally, or the sulfur may be chemically or physically removed from the
fuels.  Refineries chemically treat oil with a hydrodesulfurization process
to remove the sulfur.  Sulfur may be physically separated from coal  either
at coal-cleaning plants or by the user.   Because of the lower supply of
naturally occurring low sulfur fuels, the cost of desulfurization,  and the
cost of transportation, the price of low  sulfur fuels is higher than the
price of other fuels in some regions.  Boilers in the West do not incur a
premium for low sulfur coals because low  sulfur coals are mined in  the
western states.

          Nitrogen Oxides Controls.   The  primary technique for controlling
nitrogen oxides emissions from utility boilers and turbines is combustion
modification.  The objective is to reduce the peak flame temperature or the
residence time at peak flame temperature  in the combustion chamber.   The
modifications can achieve removal  efficiency sufficient for the most
stringent SIPs and for NSPS.

          Boiler modifications include overfire air, flue gas
recirculation, burners-out-of-service, and low NO  burners.   Most oil- and
gas-fired units employ overfire air and flue gas recirculation.   Some
existing oil and gas-fired units modify combustion by alternately firing
with some burners while leaving others out of service.   Nitrogen oxides
from existing coal-fired boilers are generally not controlled because these
boilers are not subject to NO  standards.  New coal-fired boilers are
designed with overfire air orxlow NO  burners to comply with NSPS.
                                    A


                                  A3.1-7

-------
          The wet techniques of water and steam injection are commonly use
to control nitrogen oxides from utility gas turbines.  Steam or water is
injected directly into the combustion chamber or into the fuel or air pric
to entering the combustion chamber.

Cost Methodology

          Total compliance costs for electric utilities are presented in
Table A3.1.1.  Costs of compliance with particulate and sulfur dioxide
standards were taken from a recent EPA study of the impact of environments
regulations on the electric utility industry by Temple, Barker, and Sloan,
Inc. (TBS).  These exogenous costs were disaggregated by type of fuel
burned, age of unit, and type of control (equipment or burning low sulfur
fuel).

          Costs for nitrogen oxides control were estimated separately for
boilers and gas turbines.  Average costs per kilowatt of capacity were
multiplied by affected capacity.  The average cost figures were obtained
from the EPA background document on the stationary gas turbine NSPS (EPA
450/2-77-017a) and recent estimates calculated for EPA by Acurex.  Capacit
information was taken from the TBS study and DOE data.

          For estimating nitrogen oxides control costs, we assumed that
units subject to SIPs will reach full compliance by 1990 and those subject
to NSPS comply upon construction.  For particulate and sulfur dioxide
controls, the costs provided by TBS reflect historic compliance patterns i
to 1979 and TBS projections of compliance through 1990.
                                  A3.1-8

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              Chapter A3.2  Industrial and Commercial Boilers

          This chapter covers the cost of compliance with participate and
sulfur dioxide standards in SIPs and NSPS by coal- and oil-fired industrial
and commercial boilers.  These boilers generate steam for space heat,
electricity, and heat for industrial processes.  Estimated costs include
the costs of control equipment, which reduces particulate and sulfur
dioxide emissions in the flue gas, and premiums paid for low sulfur fuel,
which produces lower sulfur dioxide emissions during combustion.

Industry Characteristics

          Commercial and industrial boilers constitute 99 percent of the
nonresidential boiler population.  Their capacity, however, is only 55
percent of total boiler capacity, the remainder being utility boilers.
These boilers operate in a wide variety of commercial establishments and
industries.  Commercial boilers are generally smaller than industrial
boilers, although there is considerable overlap in size.  Industrial
boilers, with a few exceptions, are smaller than utility boilers.

          This section discusses the types of commercial and industrial
establishments that use boilers, and the growth and size distribution, fuel
use, and annual capacity utilization of boilers.   Most of the data
presented below are based on surveys of the boiler population in 1971 and
1977.

          Usage.  Commercial boilers are widely used in a variety of
establishments.  The smallest operate in apartment buildings, the largest
in large institutions and hospitals.  Others operate in schools, churches,
small colleges, office buildings, and hotels.

          Industrial boilers are used by almost all manufacturing
industries.  The chemical, petroleum refining, food, and paper industries
are the major boiler operators.  Other major industry groups using boilers
include primary metals, textile mills, lumber and wood products, rubber,
and transportation.

          Growth and Size Distribution.  The number of commercial and
industrial boilers increased dramatically between 1971 and 1977.
Commercial boilers quadrupled from 127 to 548 thousand, and industrial
boilers tripled from 414 to 1,254 thousand.  Because the growth was
primarily due to an increase in the number of smaller boilers, however,
capacity showed little or no growth from 1971 to 1977.  Commercial  boiler
capacity in millions Btu per hour increased from 0.8 to 1.1 million, and
industrial boiler capacity remained at 3.0 million.

          In 1977, 97 percent of commercial and industrial  boilers had a
capacity of less than 10 million Btu per hour.  Commercial  boiler capacity
is more concentrated in the lower size ranges than is industrial boiler
capacity.  Boilers with a capacity of less than 50 million Btu per hour


                                  A3.2-1

-------
equal 80 percent of total commercial boiler capacity. Less than 50 percent
of industrial boiler capacity falls into this smaller size range.  Only 5
percent of commercial  boiler capacity has a capacity greater than 250
million Btu per hour;  25 percent of industrial boiler capacity is in this
larger size class.

          The increased price of fuel since 1979, and the subsequent lower
growth in demand for energy, makes future growth in total boiler capacity
unlikely.  There is also no reason to expect the size distribution to
change.  Shifts in the use of fuel types are discussed below.

          Fuel Use.  Industrial  and commercial boilers fire coal, residual
and distillate oil, and gas.  Although some boilers can be modified to fir
more than one type of fuel, most are initially designed to fire only one
type.

          Between 1971 and 1977, the proportion of boiler capacity designe
to fire each type of fuel did not change significantly.  Coal-fired boiler
represent approximately 20 percent of both commercial and industrial boile
capacity.  Oil-fired boilers represent approximately 50 percent of
commercial boiler capacity (the remaining 30 percent are gas-fired) and
approximately 30 percent of industrial boiler capacity (the remaining 50
percent are gas-fired).

          Department of Energy policies that discourage the use of natural
gas or oil by major industrial users, along with relatively higher prices
for these two fuels, are expected to result in a shift to coal for larger
boilers.  Although a few large residual oil-fired boilers are expected to
switch to coal by design modification, most new large coal-fired units are
replacements for retiring units.  Large oil or gas-fired units were not
ordered in the late 1970's and are not expected to be ordered in the
future.

          Smaller boilers firing gas and distillate oil are not expected t
switch to coal even with the recent rise in prices of liquid fuels.
Currently the premium paid for oil or gas is largely offset by the ease of
operation and lower maintenance costs.

          Annual Capacity Utilization.  The percentage utilization of tota
annual fuel burning capacity in boilers is called the load factor.  It is
computed from annual capacity and fuel consumption data.  The average loac
factor for industrial  and commercial boilers is low, ranging from 0.1 to
0.5.  This is a result of the large number of boilers on standby, either t
be used during seasonal operations or in case of interruptions in the
supply of purchased power.

          Average  load factors fell between 1971 and 1977.  Although this
may have been due  to a different data base or methodology, it is also
consistent with a decline in energy demand during the recession of 1977.
If the recent slow growth in energy demand since 1979 continues, load
factors are not likely to change.
                                  A3.2-2

-------
Emission Sources and Pollutants

          A boiler produces heat in the form of steam by fuel combustion.
Liquids other than water can also be heated in the boiler for use in
subsequent industrial processes and heating applications.  The hot flue
gases pass through a heat recovery section after producing steam in the
boiler.  They are then discharged through a stack.

          Pollutants emitted by fossil-fuel combustion are a function of
fuel composition, combustion efficiency, and combustion equipment design.
Particulate emissions, which are in the form of smoke and fly ash (ash in
the flue gas), are related to the ash content of the fuel and the
combustion efficiency and design of the boiler.  Sulfur oxide emissions,
which are primarily in the form of sulfur dioxide, are a function of the
sulfur content of the fuel.  Sulfur dioxide emission rates do not depend on
the type or size of furnace.

          Nitrogen oxides are formed by the combination of oxygen (in the
combustion air) and nitrogen.  When combined with oxygen, nitrogen in the
fuel forms organic NO  and nitrogen in the combustion air forms thermal
NO .  Thermal nitrogefi oxide emissions are a function of peak flame
temperature and available oxygen, variables that depend on boiler size,
firing configuration, and operating practices.  Carbon monoxide and
hydrocarbon emissions from all  types of boilers are negligible.

          Natural gas and distillate oil are considered clean fuels because
of their low ash and sulfur content and their relative ease in burning at
high efficiency.  Coal and most residual oils contain significant amounts
of sulfur and ash, require more sophisticated combustion equipment, and are
more difficult to burn at high  efficiencies.

          This section discusses the operating characteristics and emission
levels of coal-fired (both pulverized and stoker) and oil-fired boilers.
Gas-fired boilers are not included because their primary emissions,
nitrogen oxides, are relatively low and generally remain uncontrolled in
commercial and industrial units.  Only those pollutants with high emissions
levels (particulates, sulfur oxides, and nitrogen oxides) are discussed.

          Coal-Fired Boilers.  Coal-fired boilers are of two primary
designs:  pulverized and stoker.

          A pulverized unit fires coal that has been ground into small
particles.  Particulate emissions from pulverized boilers are lower for
those with the wet bottom design than the dry bottom design.  In a wet or
slag bottom furnace, the temperature is maintained above the ash fusion
temperature so that the ash is  melted and can be removed from the furnace
as a liquid or slag.  Thus, as  little as 50 percent of the ash is emitted
in the flue gas.  In a dry bottom furnace, the temperature is maintained
below the ash fusion temperature so that the ash will not fuse.  Nearly all
the ash particles are formed in suspension, and about 80 percent of the ash
leaves the furnace entrained in the flue gas.
                                  A3.2-3

-------
          A stoker-fired boiler uses stokers to feed coal onto a grate in
the furnace and to remove the ash residue into a hopper for disposal.
In stoker-fired units, the coal burning rate and the size of the coal
affect the particulate emission level.   In a properly operated stoker unit
the passage of air and the agitation of the fuel bed on the grate serve tc
keep ash accumulations porous.  The ash is then discharged to an ashpit ir
fairly large pieces.  Stokers are often preferred over pulverizers because
of their greater operating range, their lower power requirements at higher
rates of combustion, their capability to burn a variety of solid fuels, ar
their high efficiency and ease of combustion control.

          In a coal-fired furnace, about 90 to 95 percent of sulfur in the
coal is converted to sulfur dioxide.  The balance of the sulfur is emittec
in the fly ash or combined and removed with the slag or ash in the furnace
Nitrogen oxides emissions in coal-fired boilers are much smaller than
particulate and sulfur oxides emissions.

          Oil-Fired Boilers.  Oil-fired boilers burn distillate and
residual oil in suspension.  Combustion of residual oil results in much
higher levels of particulate and sulfur dioxide emissions than combustion
of distillate oil.  The significantly higher levels of ash in residual oil
than distillate oil increase the particulate emission rate.  In boilers
firing residual oil, however, particulate emissions can be reduced by as
much as 60 percent when boilers are fired at low loads.

          In fuel oil combustion, essentially 100 percent of the sulfur
content of the fuel is converted to sulfur dioxide.  The sulfur content oi
residual fuel ranges from 0.5 to 2.0 percent, while that of distillate oil
averages 0.25 percent.

          Nitrogen oxides emissions from residual oil firing are primarily
organic, formed from the nitrogen content of the fuel.  Nitrogen oxide
emissions from distillate oil firing are primarily thermal, formed from tt
nitrogen in the combustion air and dependent on the firing configuration.

Regulations

          Federal air pollution standards cover newly constructed larger
industrial boilers; state standards cover all sizes of industrial and
commercial boilers.  Both federal and state regulations set limits for
particulate matter, sulfur dioxide, and nitrogen oxides.

             NSPS.  One NSPS governs the larger industrial boilers. The
NSPS, which was promulgated December 23, 1971 (40 CFR 60.40), established
limits for any boiler with a heat input rate of more than 250 million Btu
per hour that commenced construction after August 17, 1971.  A revised
NSPS, promulgated June 11, 1979 (40 CFR 60.40a), which set more stringent
limits for electric utility steam generating units that commence
construction after September 19, 1978, does not cover industrial boilers.

          The NSPS emission limits vary according to the type of fuel tha'
is fired - solid, liquid, or gaseous.  There is also currently under


                                  A3.2-4

-------
development a NSPS  for  industrial boilers with  capacity  between  10  and  250
million Btu per  hour.

           SIP.   SIP emission  limits  for  combustion  sources  govern
industrial and commercial  boilers.   The  regulations  vary primarily
according  to size of source  (heat input  rate, expressed  as  million  Btu  per
hour), age, fuel type,  and geographic  location  (attainment  or
non-attainment area).   States  determine  the  heat  input rate on either a
design or  actual basis  and measure emissions by considering either  all
units of a facility, individual  units, or individual  stacks.  In  recent
years, SIPs have become more  specific  in differentiating among boiler size,
fuel type, and geographic  location.

           Particulate regulations are  more stringent for larger  boilers
than for smaller boilers and  for new sources than for existing sources.
They are generally  expressed  as  emission limits in  pounds of particulate
matter per million  Btu  heat  input.

           Sulfur dioxide regulations vary little  by  boiler  size  but do vary
by  fuel type.  For  those SIPs  that differentiate  among fuel  types,  the
limits for residual oil are  generally  more stringent than those  for coal.
Most sulfur dioxide regulations  for  existing sources are designed to be met
by  burning low sulfur fuel rather than by installing controls for reducing
flue gas emissions.  They  are  generally  expressed as emissions per  unit
heat input or per heat  release potential (Ib per million Btu), percent
sulfur by  weight in fuel,  sulfur dioxide concentration in effluent  gas, and
mass rate  of emissions  per unit  of time.  A  few SIPs require that the
potential  sulfur concentration in combustion gases  be reduced by a
specified  percentage or require  application  of  BACT  control  technology.
These regulations implicitly  prohibit  compliance  by  burning low  sulfur
fuel.

           Nitrogen  oxides  standards  are  included  in  only 16 SIPs.  Because
they primarily apply to combustion sources with a heat input rate of
greater than 250 million Btu  per hour, only  the largest  industrial boilers
that are not also covered  by  NSPS are  affected  by these  limits.

Control Technology

           Particulate emissions  from boilers can be  controlled with low
efficiency mechanical collectors or with high efficiency controls such as
electrostatic precipitators  (ESPs),  fabric filters,  and  wet scrubbers.
.Sulfur dioxide control  is  achieved by  flue gas desulfurization (FGD)
systems or by burning low  sulfur fuels.  FGD systems  are used for high
efficiency particulate  and sulfur dioxide emission control.  Often, boilers
that have  control devices  also burn  low  sulfur fuel  to comply with
regulations.

           Each control  method  is discussed bel'ow, followed  by our
assumptions about boiler compliance.   Because cost data  are  not available
for nitrogen oxides control on the larger industrial  boilers that are
affected by the  nitrogen oxides  standards, these controls and costs are not
included.

                                  A3.2-5

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          Mechanical  Collectors.  Mechanical  collectors are capable of
removing only larger particles.   They  do not achieve the level of
participate control  efficiency required by the more stringent SIPs or by
NSPS.  Mechanical  collectors are placed on most coal-fired boilers without
the inducement of federal  regulations.   Recirculating the larger
particulates into the furnace for further burning increases boiler
efficiency,  and even very lenient local  air pollution regulations would
not allow the emission of  the larger oarticles that are captured by
mechanical  collectors.  Therefore, we do  not cost collectors.  We assume
that boilers with collectors that do not  achieve standards will comply by
installing more efficient  particulate collection devices.

          Electrostatic Precipitators and Fabric Filters.  ESPs are the
most widely used particulate control technology on pulverized coal- and
residual oil-fired boilers.   Fabric filters are being used increasingly on
coal-fired stokers and to  some extent on  pulverized coal-fired units.  Use
of fabric filters is favored when sulfur  content of the coal  is very low
and when carbon content of the particulate is high (as in spreader
stokers).

          Most ESPs  and fabric filters  that are installed on  boilers are
designed to achieve  high removal efficiency:   97 to 99 percent for ESPs on
coal-fired boilers,  78 percent for ESPs on residual oil-fired boilers, and
96 to 99 percent for fabric  filters on  coal-fired boilers.  When properly
operating, they achieve an efficiency level higher than that  required by
SIPs and the NSPS.

          High efficiency  (higher than  would normally be considered
necessary) controls  are installed in order to prevent noncompliance during
periods of faulty operation.  These higher efficiency controls are also
attractive because their cost is not significantly higher than a lower
efficiency design.  Therefore, ESP and  fabric filter cost estimates for
compliance with SIPs and both NSPS are  based on the high efficiency desigr

          Flue Gas Desulfurization.  Wet  scrubbing FGO systems are
installed on industrial boilers  primarily to control  sulfur dioxide
emissions, although  they also control particulate matter.  These systems
operate by putting flue gases in contact  with a scrubbing solution after
fly ash has been removed in  an ESP or prescrubber.  Sulfur dioxide reacts
with the slurry in a scrubber-absorber  and forms a sludge.  The sludge is
separated and disposed of, while the scrubbing solution is recirculated
with the makeup slurry.  Sulfur is discarded as waste with the sludge.
These FDG systems can .generally be designed to provide sulfur dioxide
removal efficiencies of 80 to 95 percent  under normal operating conditions
FGD systems are not  widely used on industrial boilers, because boilers can
comply with SIPs and NSPS  by burning low  sulfur fuels.

          Most FGD systems applied to coal-fired industrial boilers in the
United States employ the dual alkali process, although those  installed on
boilers in the pulp  and paper industry  scrub with sodium carbonate or
sodium hydroxide solutions.   Other types  of systems include lime or
limestone and ammonia scrubbing.  The sodium systems  are installed on


                                  A3.2-6

-------
oil-fired steam generators that are part of thermally induced oil recovery
operations at oil drilling sites.  Our cost estimates for FGD systems
assume that dual alkali and sodium designs are installed on coal-fired
units and that only the sodium design is installed on oil-fired units.

          In costing FGD systems on larger coal-fired boilers, we assumed a
particulate removal efficiency of 93 percent.  This achieves both SIP and
NSPS standards (emissions less than 0.10 Ib per million Btu) for larger
boilers.  Our cost estimates for oil-fired boilers assumed FGD units with
78 percent particulate removal, resulting in emissions of about 0.05 Ib per
million Btu.  This level is sufficient to meet SIP and NSPS standards.

          We assumed a sulfur dioxide removal efficiency of 90 percent,
which reduces emissions to a lower level (about 0.6 and 0.3 Ib per million
Btu for coal- and oil-fired boilers, respectively) than required by SIPs or
the NSPS.  This is a typical efficiency level for currently installed FGD
units.

          Low Sulfur Fuel.  Low sulfur coal  and oil may occur naturally, or
the sulfur may be chemically or physically removed from the fuels.
Refineries chemically treat oil with a hydrodesulfurization process to
remove the sulfur.  Sulfur may be physically separated from coal either at
coal-cleaning plants or by the user.  Because of the lower supply of
naturally occurring low sulfur fuels, the cost of desulfurization,  and the
cost of transportation, the price of low sulfur fuels is higher than the
price of other fuels in some regions.  Boilers in the West do not incur a
premium for low sulfur coals because low sulfur coals are mined in  the
western states.

          We assumed the premium paid for low sulfur rather than high
sulfur fuel is a cost of compliance.  We defined low sulfur coal as having
sulfur content less than 1.5 percent and low sulfur oil as having sulfur
content less than 1.0 percent.

          Compliance.  We divided the boiler populations according  to the
type of control device currently installed,  based on EPA compliance data
reports.  In our analysis, we assumed that only one type of control  device
is installed on each boiler and that the proportion of the boiler
population installing each type will remain  constant.  The following
compliance schedules for each segment of the boiler population were also
derived from the EPA compliance reports.

          Smaller (between 25 and 100 million Btu per hour) pulverized
coal-fired boiler units that are to be equipped with ESPs or fabric filters
are expected to comply with SIPs by 1985.   The larger units were assumed to
have complied by 1979.  The smaller stoker coal-fired boiler units  to be
equipped with ESPs or fabric filters are expected to comply with SIPs by
1988.  The larger units were assumed to have complied by 1981.   The larger
residual oil-fired boilers, which are equipped with ESPs, were assumed to
have complied with SIPs by 1979.  All larger boilers beginning operation
after 1971 are assumed to comply with SIPs or NSPS upon construction.
                                 •A3.2-7

-------
          Coal-fired boilers with FGD systems are expected to comply with
SIPs by 1983.  Residual  oil-fired boilers with FGD systems were assumed tc
be in compliance by 1981.  Boilers newly constructed after 1971 were
assumed to comply with SIPs or NSPS upon operation.

          Separately, we determined the amount of low sulfur coal and oil
purchased at a premium by industrial  and commercial boilers, most of which
also have a control device.  The fuel volume was based on analysis of EPA
compliance data and the  percent of boiler fuel consumed in states with SIF
sulfur dioxide standards that require low sulfur fuel.  Boilers that burn
low sulfur coal at a premium were assumed to have complied with SIPs by
1980 and those that burn low sulfur oil, by 1975.  New boilers (constructe
after 1971) that burn low sulfur fuel were assumed to comply with either
SIPs or NSPS immediately upon construction.

Cost Methodology

          The total costs of controlling industrial and commercial boiler
emissions are reported in Table A3.2.1.  The costs of pollution control
equipment — ESPs, fabric filters, and FGD systems -- are estimated with
cost equations.  Costs are expressed as a function of boiler capacity in
million Btu per hour.  They were derived from two recent EPA documents tha
present detailed control costs for coal- and oil-fired industrial boilers
(EPA Contract No. 68-02-3058 by Radian and EPA 450/5-80-007).  The authors
of these documents assumed an annual  load factor of 0.4.  FGD costs includ
sludge waste handling costs.

          The cost of burning low sulfur coal and oil was estimated by
applying a low sulfur premium to the amount of low sulfur fuel burned by
industrial boilers.  We  estimated the low sulfur premium for industrial an
commercial boilers using the price difference between low and high sulfur
fuels paid by utilities.
                                  A3.2-8

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               Chapter A3.3  Natural Gas Processing Industry


          Revision of this chapter included adjusting the pollution control
costs to 1981 dollars and editing and updating the discussion of applicable
regulations and industry characteristics.

Regulations

          SIPs contain the primary regulations governing this industry,
since there is no NSPS.  The SIPs of the states where most sour natural gas
production occurs have a wide variety of sulfur dioxide regulations
governing gas processing plants.  Most have requirements that are the
equivalent to requiring 2- or 3- stage Glaus plants on gas plants over a
given size.  This size varies from about 5 to 15 metric tons of total
sulfur input per day, depending on the state, county, and location (rural
versus urban).  Florida has the most stringent rules, requiring tail-gas
cleanup since 1975 and forbidding any flaring of hydrogen sulfide.
Oklahoma requires tail-gas cleanup for all  new plants; New Mexico requires
it for new large plants (over 50 metric tons per day total sulfur input).
In other states, tail-gas cleanup for large sulfur plants may be
unofficially required for new permits, even though this is not spelled out
in the regulations.   Upgrading existing 2-stage Glaus units to 3-stage
units has been required to meet ambient or general emission standards in
some areas.  Sulfur dioxide standards are now also being established in the
revised SIPs of other states with natural gas processing plants.

          States with natural gas processing facilities have been recently
encouraged by EPA to include volatile organic compound standards for these
facilities in their revised SIPs.  Prior to the 1981 release of a draft CTG
document, few states included these regulations.

          Although no NSPS have been proposed for this industry, NSPS are
under development.  The draft regulation would require control  of volatile
organic compound and sulfur dioxide emissions from new or modified
facilities at natural gas/gasoline processing plants.   The draft sulfur
dioxide standard, which is expressed as a percentage efficiency requirement^
would in effect require a reduction in sulfur dioxide.  The efficiency
requirement would vary with plant size and have a lower size cut-off.

Industry Characteristics

          The natural gas industry may be viewed as having three major
sectors:  exploration, production, and transmission-distribution.   The
exploration for and production of natural gas is usually associated with
that of petroleum.  The distinction between "oil  wells" and "gas wells" is
arbitrary—based on the ratio of oil  to gas produced.   Therefore,  much of
the exploration for natural  gas is done by companies considered to be oil
companies, most of them small.  Natural  gas is processed by the production


                                  A3.3-1

-------
sector for the most part, prior to entering transmission pipelines.  The
production sector is dominated by large firms, many of them primarily
petroleum producers, but a large number of small firms contribute a sizabl
share of the total output.  The transportation/distribution sector is
primarily organized as public utility companies which operate under Federe
and/or State regulations.  These companies may get involved in processing
when gas is retrieved from underground storage facilities.  Although many
gas-transmission companies are now integrating back into exploration and
production, the basic structure of the industry remains as described here.

          As of January 1, 1980, the 772 natural gas processing plants in
the United States had a total capacity of 71.2 billion cubic feet per day.
The average through-put rate of these plants in 1979 was 44.9 billion cub-
feet per day.  More than 65 percent of gas processing capacity and
through-put is accounted for by plants located in Louisiana and Texas.
From 1971 to 1978 the amount of total production and gas processed
decreased an average of 2 percent per year.  Total production has risen
slightly since 1978 because of the incentives provided by the Natural Gas
Policy Act of 1978 in deregulating the price of natural gas.  All control;
of natural gas prices are scheduled to be lifted by 1985.

Pollutants and Sources

          Natural gas is primarily methane, but the raw gas contains
varying amounts of heavier hydrocarbons and other gases such as carbon
dioxide, nitrogen, helium, hydrogen sulfide and water vapor.  To obtain a
natural gas of pipeline quality, much of the content of these undesired
components must be removed.  The gas is normally purified at or near the
well site in a natural gas processing plant.  The heavier hydrocarbons
which can be conveniently condensed are combined with the liquid (oil)
production and sent to refineries for further processing or are sold as
liquified petroleum gas (LPG) or petro-chemical feed s.tock.

          Hydrogen sulfide and sulfur oxides derived from it are the
air-pollution factors of greatest concern.  Because of the corrosive,
poisonous, and odorous nature of hydrogen sulfide, only very low
concentrations are permitted in the natural gas product.  Approximately 5
percent of the natural gas produced in the United States (so called sour
gas) must be treated to remove hydrogen sulfide.  The hydrogen sulfide
content of raw natural gas varies from trace quantities to over 50 percen-
by volume.  The high-concentration wells are operated more as sulfur
sources than as natural gas wells.

          It is in the disposal of the' removed hydrogen sulfide that
pollution occurs.  Disposal can be by recovery of sulfur, or flaring, or
venting.  Although removal of the hydrogen sulfide from sour natural gas
universally practiced, recovery of the corresponding sulfur in elemental
form to avoid air pollution is not universally practiced.  In the large
operations, Glaus plants have been installed for this purpose, but in man;
small plants the hydrogen sulfide is merely flared, resulting in emission:
of sulfur oxides.  Venting is not acceptable because of the toxic nature  <
hydrogen sulfide.


                                  A3.3-2

-------
          For the natural gas plants which have Glaus plants, the source of
sulfur oxides emitted is the Glaus plant tail gas, which is incinerated.
The sulfur content of this emission corresponds to 4-6 percent of the
sulfur originally fed to the Glaus plant.  For the natural gas plants
without Glaus plants, the sources of the sulfur oxides emitted are the
flares in which the hydrogen sulfide that was removed from the gas is
burned.

          Emissions of hydrocarbons (from compressors) and nitrogen oxides
are also matters of concern for new or modified plants due to the PSD and
nonattainment regulations.  These emissions are not analyzed in this
chapter.

Control Technology

          Because of the severe limitations on the hydrogen sulfide content
of pipeline gas, all natural gas processing plants that handle sour gas
already have amine-type scrubbing facilities or the equivalent to remove it
from the raw gas.  The technology needed to prevent hydrogen sulfide from
causing air pollution consists of:

          t  A Glaus sulfur plant in which most of the hydrogen sulfide is
             converted to elemental sulfur (94-96 percent cleanup)

          t  Treatment facilities to remove remaining sulfur compounds from
             the Glaus plant tail gas (99-99.9 percent overall cleanup)

Costing Methodology

          Cost data developed by EPA for refinery sulfur plants
(EPA-230/3-76-004) were modified by changing the capital  recovery figure
and correcting for inflation.   Since Glaus plants larger than about 20
metric tons per day (22 short tons per day) produced a net credit when
sulfur was valued at $43.5 (1979 $) per metric ton ($39.5 per short ton),
only Glaus units smaller than this are considered a cost.  November,  1979
prices for crude sulfur ranged from $53 to $97 per metric ton ($88 to $48
per short ton), depending on quality factors and the location of the  source
relative to the Tampa market.   The use of $43.5 reflects  the probability
that prices will drop as more sulfur recovery from flue gases come on line
and as the sulfur content of imported crude oil  rises.

          Only three existing plants are estimated to have tail  gas cleanup
units.   -

          Industry growth is hard to estimate in view of the slowly
increasing capacity (1.5 percent per year, 1975-1979) and increasing  output
of sulfur units, 6.5 percent per year (1975-1978).  In 1979, the 70
operating Glaus plants in the natural  gas processing industry had a total
sulfur capacity of 2,187 thousand metric tons per year (2,410 thousand
short tons per year), and an actual production rate of 1,753 thousand
metric tons per year (1,932 thousand short tons per year).   Apparently the
existing plants are extending their coverage to gas plant output that was


                                  A3.3-3

-------
formerly flared.  Future operating rates are estimated at 89 percent.  It
is assumed that new plants will  be built annually amounting to 8 percent <
existing capacity, i.e., the replacement of old with new as they wear out
over a 16-year life plus an extra 2 percent for new fields and reservoirs
remote from old plants.  (This is the historic rate of addition of new
reservoirs and fields.)  the increment was distributed in various size
plants in the same proportion as existing operating sulfur plants.  The
upgrading of Glaus units from 2  to 3 stages probably involved 20-30 perce
extra cost in constant dollars but was ignored because of lack of -
quantitative data and because much of this upgrading was done in the
1970-1972 period, before the SIPs were formalized.

          The costs developed using the above approach are shown in Table
A3.3.1.  The NSPS costs reported in this table represent the cost to new
plants of complying with more recent (post=1979) regulations enforced by
states, not NSPS regulations.
                                  A3.3-4

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                     Chapter A3.4  Petroleum Refining

          This chapter covers the cost of compliance with air pollution
regulations by all stages of the petroleum refining industry including
refining, storage and transfer.  Table A3.4.1 lists the pollutants
regulated at each source and the basis for the total industry costs
reported in Table A3.4.2.

Industry Characteristics

          The petroleum industry is often divided into extraction,
refining, and transporting and marketing operations.  Each market is
dominated by the sixteen major oil  companies, which are fully integrated
into all stages of production.  These sixteen companies produce about 70
percent of crude oil, operate about 70 percent of refinery capacity, and
market about 70 percent of retail gasoline volume.  There are, however,
many smaller companies operating at only one stage, including several
thousand in exploration and drilling, a few hundred in refining and a few
hundred in retail marketing.

          This chapter covers air emissions from refining processes,
loading at distribution sites, and storage at the refinery and distribution
sites.

          Extraction of crude oil includes exploration, drilling oil wells,
and extracting and pretreating the crude oil  before storing or transporting
it to refineries.  Federal air regulations do not address emissions
generated at this stage of production.  Natural  gas, which is also
extracted from oil wells and produced and sold by oil  companies, is covered
in chapter 3.3.

          Refining of crude oil into petroleum products comprises several
processes.These include separation (distillation), conversion (e.g.,
cracking, reforming, alkylation, coking, visbreaking), treating (e.g.,
hydrotreating, chemical sweetening), and handling.  Refining products
include gasoline, distillate fuel oil (heating oil and diesel fuel),
residual fuel, jet fuel, and liquid petroleum gas (LPG).   Other products
include kerosene, petrochemical feedstocks, coke, still gas, special
naphthas, lubricants, and asphalts.  The larger oil companies also
manufacture petrochemicals; however, the petrochemicals industry is covered
in chapter 5.2.

          Operable refinery crude capacity in the United States in 1981 was
18.465 million barrels per day at 303 refineries, according to the annual
refining survey of the Oil and Gas Journal.  (The Department of Energy, on
the other hand, reports 315 operating refineries in the United States and
its territories with crude capacity of 18.051 million  barrels per day.)
The distribution of refineries by capacity size is reported by the National
Petroleum Council in its 1979 refinery survey.   Refineries with capacity


                                  A3.4-1

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     Table A3.4.1.  Petroleum refining emissions sources, regulations

                       and pollution control devices
            Sources
Regulated Pollutant'
  Control Devices
Refinery Catalytic
  Cracking Regenerator
Refinery Fuel Gas
  Combustion Devices

Sulfur Recovery Plants

Miscellaneous Refinery
  Sources

Petroleum Storage Facilities:
  Crude oil and gasoline
   storage tanks
  Jet fuel storage tanks

Petroleum Transfer Facilities:
  Bulk storage terminals
  Gasoline service stations
Particulate matte:

Carbon monoxide


Sulfur dioxide


Sulfur dioxide

VOC and fugitive
 benzene


VOC

VOC


VOC


VOC
Electrostatic pre-
cipitator
Carbon, monoxide
boiler

Costs reported in
  Chapter A3.2

Tail gas treatmen-

Slowdown systems  <
 incinerators
Floating roof

Floating roof
Vapor recovery or
incineration.syst

Vapor balance sys-
 VOC = Volatile organic compound

 3Costs for this device are not included in total costs for the industry
 (Table A3.4.2), because the value of recovered product exceeds the contn
 cost, thereby yielding a net credit.
                                 A3.4-2

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larger than 100,000 barrels per day constitute 65 percent of total refinery
capacity but only about 20 percent of operating refineries.  Refineries
with a capacity less than 50,000 barrels per day constitute only 17 percent
of total refinery capacity but 67 percent of total refineries.

          Total refinery capacity grew at the average annual rate of 3.5
percent from 1971 to 1981.  The annual rate increased from 3 percent during
the year 1971 to 1976, to 4 percent during the years 1976 to 1981.
Expansion of existing facilities and an increase in the number of small
refineries were the main sources of growth in the past five years.  Since
1974 more than 64 small refineries have been built, largely a result of the
incentives provided by the federal small refineries entitlements program.

          Capacity utilization during the 1970's remained relatively high
(over 80 percent), reflecting stable demand growth for petroleum products.
In 1980, however, capacity utilization began to fall and decreased to less
than 65 percent in 1981.  Decontrol of oil prices in 1980, which caused
prices for refined products to rise, led to a severe decline in the demand
for refined products by utilities and industrial and residential users and
caused refinery shutdowns as well as the low capacity utilization in 1981.
Capacity growth also declined and fell to 1.7 percent in 1981.  Capacity
for the remainder of the 1980's is not likely to increase, because oil
demand is not expected to grow during the decade of the 1980's.  This
reflects both a switch to coal and a reduction in total energy demand.

          Crude oil processed by refineries and gasoline production
declined in 1980 and 1981.  Although gasoline storage capacity rose from
246 to 275 million barrels between 1972 and 1977, it is not expected to
increase by more than 1 percent per year in the 1980's given the falling
demand.  Naphtha jet fuel storage capacity has remained at 2.6 million
barrels since 1971 and is also not likely to grow in the future.

          Petroleum refineries are classified into SIC 2911: Petroleum
Refining.  The value of shipments for 1972 was $25.9 billion and for 1977,
$91.7 billion.

          Transporting and Marketing.  Petroleum products.are transported
from refineries to a chain of distribution centers by pipeline, barge,
ship, tank truck, or rail car.  Bulk terminals are distribution and storage
facilities having the capacity to distribute more than 475 barrels of
product per day.  They receive product from the the refinery by pipeline,
barge, or ship, store it in above ground tanks,  and dispense it into tank
trucks or railcars.  Bulk plants, which have a throughput of less than 475
barrels per day, are secondary distribution locations.  Gasoline is
transported by tank truck from bulk plants to gasoline service stations,
the final distribution sites.

          Bulk terminals and plants are concentrated primarily on the
Atlantic Seaboard and in the North-Central States where the lack of
refineries creates a reliance on imports from other regions and a demand
for a larger distribution network.  From 1972 to 1977, the number of bulk
terminals remained at approximately 1900 and the total storage capacity


                                  A3.4-3

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increased only slightly, from 430 to 450 million barrels.  Gasoline storag
capacity rose from 155 to 166 million barrels, and naphtha jet fuel storag
capacity has remained at 8.7 million barrels.  During the same period,
however, the number of bulk plants fell  from 23,000 to 15,000, while their
storage capacity remained at 70 million gallons.  This decline in number
and implicit increase in capacity per plant was partly the result of a
reduction in the number of gasoline service stations.  The numoer of
gasoline service stations fell from 226,000 in 1972 to 154,000 in mid-1981
The annual  rate of decline has been 5 percent since 1978 in response to ti"
decline in gasoline demand.

          Petroleum bulk terminals and plants, which are both classified
into SIC 5171, reported sales for 1977 of $8.7 billion and $21.3 billion,
respectively.  Gasoline service stations, SIC 554, reported sales of
$56.5 billion.

Emission Sources and Pollutants

          This section describes the pollutants and sources listed in the
regulations section, except for sulfur dioxide emissions from fuel gas
combustion devices.  Emissions from fuel gas combustion devices are
discussed in Chapter 3.2 on industrial and commercial heating.

          Catalytic Cracking Regenerators.  Catalytic cracking is the
principal refinery process for converting heavy oil to lighter, more
marketable products, such as gasoline.  During the cracking operation, a
fraction of the heavy oil feed bonds to the catalyst in the form of coke
deposits.  These deposits impede the catalyst's ability to promote the
cracking reactions; thus, a regenerator must regenerate the catalyst by
burning off the coke deposits.

          Three types of catalytic cracking units currently operate in U.S
refineries: fluid (FCC) and two types of moving units, Thermoflor (TCC) ar
Houdriflow (HCC).  The following discussion addresses only FCC units
because they constitute all new units and 95 percent of existing units, an
because the continuous regeneration required in these units causes
significant emissions.

          The catalyst bed in an FCC is continually circulated between the
reactor, where the coke is deposited on the catalyst, and the regenerator,
where the coke is burned off.  The amount of coke deposited on the catalys
per unit of feedstock is a function of the feedstock composition and other
operating conditions.  The major pollutants emitted from the FCC
regenerator are carbon monoxide and particulates, in the form of catalyst
fines, coke dust, and ash.  If the feedstock is high in sulfur, release of
sulfur dioxide in the flue gas can occur.  Other pollutants include
hydrocarbons, nitrogen oxides, ammonia, aldehydes, and cyanides.  Only
carbon monoxide and particulate emissions are significantly high to be
regulated and therefore covered in this chapter.
                                  A3.4-4

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          Sulfur Recovery Plants.  Glaus sulfur recovery plants are
operated by refineries to recover elemental sulfur from process gases.
Sulfur recovery is the second stage of the desulfurizing "sweetening"
process tn which refineries reduce the sulfur content of high sulfur fuels.
Most refineries use amine scrubbing units whose amine solution "scrubs" or
absorbs hydrogen sulfide, the form in which sulfur occurs in the fuel gas.
The hydrogen sulfide is either burned to sulfur dioxide through a flare or
sent to a sulfur recovery plant.

          Because of the profitability of recovering the elemental sulfur
product, large refineries build Glaus sulfur recovery plants.  Control
costs for sulfur dioxide emissions from the Glaus plants are included in
this chapter.

          Miscellaneous Refinery Sources.  Petroleum passes through several
types of equipment during the various stages of the refinery.  During the
processing at each stage, fugitive VOCs are emitted.  The primary sources
of fugitive VOC emissions are (1) vacuum producing systems, (2) wastewater
separators, (3) process unit turnarounds, and (4) miscellaneous equipment
leaks.

          The vacuum producing system, the first operation in a refinery,
separates crude oil into its major constituents by distillation, stripping,
and absorption.  The steam ejectors (vacuum jets) on the vacuum
distillation columns of the system are the primary source of noncondensible
hydrocarbon emissions.

          Wastewater separating systems treat the oily wastewaters from
refineries.  The API separator, the major unit, is a gravity settling
device that causes oil  to rise to the liquid surface and suspended solids
to settle to the bottom so that they can be collected.  Hydrocarbon
emissions result from evaporation of volatile organic compounds from an
uncovered surface.

          Process unit turnaround refers to the shutdown,  repair or
inspection, or start-up of a process unit.   Hydrocarbon vapors  from
turnarounds in all refinery process units are vented to a  blowdown system,
which is a set of relief devices, piping, or vessels.   If  uncontrolled,  the
blowdown system discharges significant levels of VOC emissions.

          Sources of VOC leaks in refineries primarily include  valves,
flanges and other connecting devices, pump  and compressor  seals, drains,
and pressure relief devices.  If these sources are on vessels that contain
petroleum liquids with benzene, then benzene emissions are also leaked.

          Petroleum Storage.  Petroleum storage facilities are  located  at
refineries, along pipelines, and at distribution sites.  The larger
vessels, which are the majority of those regulated, are primarily  at
refineries and petroleum bulk terminals.   The most significant  hydrocarbon
or VOC emissions occur from those vessels used to store crude oil,
gasoline, and naphtha-type jet fuel.   The magnitude of the emissions
                                  A3.4-5

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depends on the material  in storage, climatic and meteorological condition
and the type, size, and  condition of the tank.

          Petroleum Transfer Operations.  Transfer facilities include bul
terminals, bulk plants,  and service stations, as well as refinery loading
platforms.  VOC emissions occur during loading of storage tanks, barges,
ships, tank trucks, and  tank cars, as vapors are displaced from the empty
tanks.  Displaced vapors include vapors formed from evaporation of the
residual product from a  previous load, vapors generated from the newly
loaded product, and vapors formed in the tank prior to removal of the
previous load.  The extent of hydrocarbon emissions that escape during
loading depends on the physical and chemical characteristics of the
previous and new cargo,  the method of unloading and loading, and whether
the tank was cleaned or  purged between loads.

Regulations

          Petroleum industry regulations cover emissions from refinery
processes, sulfur recovery plants, refinery leaks, and petroleum storage
and transfer at refineries and distribution sites.

          In addition to the specific regulations described in the
following paragraphs, petroleum refineries, sulfur recovery plants, and
petroleum storage and transfer facilities (with a capacity exceeding
300,000 barrels) are on  the list of major sources subject to BACT.  Major
new petroleum industry sources of all types sited in non-attainment areas
are subject to LAER.

          Refinery Catalytic Cracking Regenerators.  Regulated pollutants
from catalytic cracking  regenerators include particulate matter and carbo
monoxide; standards of performance are now under development for sulfur
oxide emissions.  NSPS (40 CFR 60.102 and 103), promulgated in 1974, cove
particulate and carbon monoxide emissions from fluid catalytic cracking
units.

          SIPs generally cover all types of catalytic cracking
regenerators.  Particulate limits range from the NSPS level to less
stringent limits.  Most  SIP carbon monoxide regulations are similar to th
RACT standard suggested  in Appendix 8 (40 CFR Part 41), which requires
complete secondary combustion of waste gases.

          Refinery Fuel  Gas Combustion Devices.  The 1978 NSPS for
petroleum refineries (40 CFR 60.104) sets sulfur dioxide limits for fuel
gas combustion devices except for fuel gases released to flare.  The limi
governs hydrogen sulfide in the gases.

          SIPs cover both fuel gas combustion devices and process heaters
State combustion regulations that specify sulfur content in oil apply to
the oil-fired boilers found in refineries.  Most states require RACT
standards for process heaters.  Appendix B (40 CFR, Part 41) suggests a
hydrogen sulfide limit from the process gas stream.  Although these sulfu
dioxide standards apply  to combustion sources in refineries, the compliam


                                  A3.4-6

-------
costs are estimated in Chapter 3.2 on industrial and commercial heating,
which covers combustion sources in all industries.

          Sulfur Recovery Plants.  The 1978 petroleum refinery NSPS  (40 CFR
60.104) also covers sulfur dioxide emissions from sulfur recovery plants.
The limit varies according to the type of control system.  The majority of
SIPs require the RACT standard in Appendix B.

          Miscellaneous Refinery Sources.  Fugitive emissions from
miscellaneous refinery sources include benzene and VOC.  These sources
include vacuum producing systems, wastewater separators, process unit
turnarounds, and miscellaneous equipment leaks.  States with ozone
non-attainment areas have adopted VOC regulations suggested by the control
technique guideline documents released by EPA in 1977 and 1978.  Rather
than setting emissions limits, these SIP regulations specify control
equipment such as incineration and vapor loss control devices.
Approximately 85 percent of the refinery population is affected by these
SIPs.

          A National Emission Standard for Hazardous Air Pollutants
(NESHAPS) covering benzene emissions was proposed on January 5, 1981
(46FR1165).  It would regulate benzene emissions from all fugitive emission
sources in refineries and chemical plants that process petroleum liquids
with at least 10 percent benzene by weight.  The standard would allow no
detectable emissions from leaks in safety/relief valves and product
accumulator vessels.  It would also require a leak detection and repair
program for pipeline valves and pumps and certain equipment for
compressors, sampling connections, and open-ended valves.  These controls
are similar to those required by VOC regulations for SIPs.   Because the
NESHAPS covers only those petroleum refineries that produce benzene (a
petrochemical feedstock), and because these refineries are located in
states that regulate fugitive VOC emissions, the NESHAPS does not impose
more stringent standards than SIPs.

          Petroleum Storage Facilities.   Two NSPS regulate VOC emissions
from petroleum storage vessels with capacities exceeding 40,000 gallons.
The 1974 NSPS (40 CFR 60.112) applies to vessels whose construction began
between mid-1973 and mid-1978.  The 1978 revised NSPS (40 CRF 60.112a) is
more stringent and applies to vessels whose construction began after
mid-1978.  Both regulations specify control  equipment for two ranges of
storage pressure.  The control equipment includes a vapor recovery system,
floating roof and, for the 1978 NSPS, external  floating roof with double
seal.

          SIP regulations, which are modeled after Appendix B (40 CFR Part
41, Appendix B) and EPA control  technique guideline documents of 1977 and
1978, require control  equipment similar  to that of both NSPS.

          Petroleum Transfer Facilities.   The petroleum distribution/
marketing system comprises a chain of loading sites, including bulk
gasoline terminals, bulk gasoline plants, and gasoline service stations.
A NSPS for bulk gasoline terminals, proposed December 17, 1980 (45 FR


                                  A3.4-7

-------
83126), would require loading racks equipped with a vapor collection
system.

          SIP regulations specify control equipment (primarily vapor
recovery) that is suggested in the EPA control technique guideline
documents for the loading of tank trucks at bulk gasoline terminals, bulk
gasoline plants, and gasoline stations.  Because some states are in
attainment for ozone and have no VOC regulations, only 70 percent of
terminals and 90 percent of bulk plants and service stations are covered t
SIPs.

Control Technology

          Catalytic Cracking Regenerators.  Particulate matter can be
removed from the regenerator gas with two-stage internal cyclones and hig}
efficiency electrostatic precipitators (ESPs).  Two-stage internal cyclone
are commonly installed in regeneration systems to improve the catalyst
recovery efficiency.  Since their installation is not motivated by
environmental regulations, their costs are not included in this chapter.

          We have assumed that ESPs meet the NSPS limit of 1.0 kg/1000 kg
coke burn off and a SIP limit of 1.73 lb/1000 Ib coke burn off, which is
equivalent to the New York process weight standard of 95 Ibs/hr. In 1971,
about 31 percent of fluid catalytic cracker capacity was equipped with
ESPs.  Plants representing the remaining 69 percent of capacity without
ESPs in 1971 were assumed to install ESPs at the rate of 16.7 percent per
year from 1972 to 1978.

          Carbon monoxide and unburned hydrocarbons in the flue gas of
catalyst regenerators can be controlled by high temperature regeneration <
the catalyst or by burning the flue gas in a carbon monoxide waste-heat
boiler.  High temperature regeneration causes a complete conversion of co
to carbon dioxide, thereby resulting in low levels of coke deposit on the
catalyst and increasing catalyst activity.  Because the increase in
catalyst efficiency indicates economic motivation for utilizing high
temperature regeneration and because sufficient cost information is
unavailable, we have not included costs for this technique.

          Waste-heat boilers provide significant thermal energy when
reducing carbon monoxide emissions to levels required by NSPS or SIPs.  Wi
have assumed a control efficiency of 99.5 percent, which reduces carbon
monoxide emissions to less than 50 ppm.  Because the value of the steam
generated from large carbon monoxide boilers outweighs the cost of the
boiler, we assumed that these boilers are installed for economic reasons
and yield a net credit to the industry.  Therefore, no costs are recorded
for carbon monoxide control in catalyst regenerators.

          Sulfur Recovery Plants.  Sulfur dioxide emissions from sulfur
recovery plants can be controlled by three methods:  (1) low temperature
extended Glaus reaction with tail gas treatment (IFP-1 or Sulfreen), (2)
oxidation-scrubbing of the tail gas (IFP-2 or Wellman-Lord), and (3)
reduction-scrubbing of the tail gas (Beavon, clean air, or SCOT).  The
                                  A3.4-8

-------
first method achieves an average SIP standard of 99 percent recovery when
retrofited to an incinerator.  IFP-1 was chosen to represent this level of
efficiency for costing SIP compliance.  The second and third methods,
represented by Well man-Lord and Beavon, respectively, achieve 100 percent
control, which meets the NSPS requirement of 97.9 percent recovery.  We
assumed that each method is installed in equal proportions on new sulfur
recovery plants.

          We assumed that sulfur recovery plants would only recover 95
percent sulfur without any air pollution control regulations.  Plants
operating in 1972 were assumed to comply with SIPs between 1972 and 1978.
We also assumed that all plants beginning operation in 1972 through 1977
comply with SIPs, and those beginning after 1977 comply with NSPS.

          The cost of the fuel-desulfurizing process (the amine units and
the sulfur recovery plants) is reflected in a premium on the price of low
sulfur fuel.  This premium is incurred by fuel users, such as utilities and
operators of industrial  and commercial gas boilers, who use low sulfur fuel
as a method of complying with sulfur dioxide standards for fuel gas
combustion.  Therefore,  these costs do not appear in this chapter.

          Miscellaneous  Refinery Equipment.  Noncondensable vapors vented
from vacuum ejectors of  vacuum systems can be controlled by venting the
vapors through piping into blowdown systems or fuel gas systems and
incinerating the collected vapors in furnaces, waste heat boilers, or
incinerators.  The recovered vapors yield enough energy when combusted that
there is a net credit for the control.

          A floating roof system for covering the forebays of wastewater
separators is the preferred method of controlling the VOC emissions.
Vapors from the fixed roof separator can also be vented to vapor recovery
systems.  Either method  recovers product whose value outweighs the cost of
the control system.

          Control of vapor that is released from reactors during process
unit turnarounds is similar to the techniques described above.  The vapors,
when vented to a blowdown system and incinerated, also yield a net credit
for the investment.

          The recommended control technique, for VOC emissions from
equipment leaks is a monitoring and maintenance program and, when
necessary, a seal oil reservoir degassing vent control  system.  Given the
increased price- of gasoline in the past few years, the value of the
recovered gasoline product is much greater than the total  cost of both
control techniques.

          We assume that compliance with the SIP control  requirements for
miscellaneous refinery equipment is induced by the value  of the recovered
gasoline product.  Therefore, no costs are reported.

          Petroleum Storage.   Crude oil, jet fuel, and gasoline are the
primary fuel-related refinery materials whose storage requires a vapor


                                  A3.4-9

-------
pressure that is covered by VOC regulations.  The 1974 NSPS and most SIPs
require a vapor control  system, a floating roof, or an equivalent system.
Because of the value of recovered product, these control techniques are
cost effective for crude oil  and gasoline storage.  There are, however, nt
costs for installing floating roofs on naphtha jet fuel storage tanks.
Because of the colder climate, an incineration system, which does not
recover product, is applied to facilities for crude oil and storage at
Valdez, Alaska.

          The 1980 revised NSPS for petroleum storage tanks and the
California SIP differ from the 1974 NSPS and other SIPs in the regulation
of tanks with a pressure of 1.5-11.1 psia (78-570 mm of mercury).  These
tanks must install an external floating roof with a double seal or
equivalent.  The additional product loss prevented by this more stringent
control also results in a net credit on average.  It is assumed that all
crude oil and gasoline storage tanks beginning operation after 1970 and a'
existing tanks in California would comply because of the cost effectivene;
of the control.

          Petroleum Transfer Operations.  VOC emissions during petroleum
transfer can be controlled with three techniques: a controlled method of
loading, a system for recovering or incinerating petroleum vapors, or a
system for balancing displaced vapors.  Controlled loading methods are use
for loading at all types of distribution sites.  Vapor recovery and
incineration systems are currently installed only at gasoline bulk
terminals, and vapor balance systems are used at gasoline bulk plants and
gasoline service stations.

          Splash loading is the uncontrolled method of filling a tank
through an opening in the top of the tank.  The splashing of gasoline as
the gasoline falls to the surface of the liquid saturates with hydrocarbor
the vapors that are vented through the opening.  Two methods of control!e<
loading are available: submerged-fill and bottom loading.  Submerged-fill
loading reduces the splashing by loading the gasoline through a pipe that
extends from the top opening to the bottom of the tank.  Bottom loading
reduces the splashing by pumping gas into the tank from an opening in the
bottom of the tank.

          A vapor recovery system collects VOC from the air-vapor mixture
that is displaced during the transfer of gasoline.  The air-vapor mixture
may be treated and then held in a vapor holder tank before being piped in'
the processing units and tanks of the system.  Systems in current use
remove the VOC from the mixture with.three different processes:
refrigeration, compression/refrigeration/absorption, and carbon adsorptior

          Refrigeration-type recovery units remove VOCs in a condenser by
straight refrigeration at atmospheric pressure.  In a compression/refriger
ation/absorption system, the vapors are first saturated with gasoline and
after storage in a vapor holder, they are compressed, cooled, and
condensed.  Uncondensed vapors are absorbed by chilled gasoline in a packe
absorber column.  The carbon adsorption vapor recovery unit uses beds of
activated carbons to remove VOCs from the air-vapor mixture.
                                  A3.4-10

-------
          The most commonly used incineration system is the thermal
oxidation unit.  Instead of recovering gasoline, the unit relies on burning
VOC vapors (using a pilot flame) to produce non-polluting combustion
products.

          The vapor balance or displacement system also recovers vapors.
It operates by transferring vapors displaced from the receiving tank to the
tank being unloaded.  A vapor line between the truck and storage tanks
creates a closed system that permits the vapor spaces of the two tanks to
balance with each other.

          EPA recommends all of these methods of control for adoption by
states in their SIPs.   We have assumed that the submerged-fill  loading
method is used at every loading rack and that bulk terminals install a
vapor recovery system rather than incineration system where possible.  (In
colder climates, where vapors evaporate at a lower rate, the value of the
recovered vapors may be so low that an incineration system is less costly.)

          Each vapor recovery method is cost-effective because of the large
volume of recovered gasoline and the recent high price of gasoline.  We
have assumed that, on average, bulk terminals do not incur a cost for VOC
control, because the credit gained from installing vapor recovery units on
some terminals outweighs the costs incurred with the incineration system on
other terminals.  Vapor balance systems are also profitable at bulk plants
but not at gasoline service stations.  Therefore, the only control  costs
for gasoline transfer reported in this chapter are those incurred by
service stations.

Costing Methodology

          Table A3.4.2 presents the total  compliance costs for this
industry.  The cost methodology for each emission source is described
below.

          Catalytic Cracking Regenerators.   Electrostatic precipitator cost
estimates were developed from EPA cost engineering documents.   Average
costs for a model refinery were applied to capacity figures derived from
historical capacity data, compliance assumptions, and forecast growth.

          Costs and annual  credits for steam generation were computed for a
model carbon monoxide boiler.  Because a net credit was obtained, no
further computations were made.

          Sulfur Recovery Plants.  Costs for tail gas units were based on
model plant costs and actual and projected capacity data.   We  subtracted
the value of additional  sulfur recovered from the tail  gas.   The total
sulfur credit was based on actual sulfur prices for 1972-1981.
                                                                            i
          Miscellaneous Refinery Equipment.  Control  costs and  product
recovery credits for miscellaneous refinery equipment are reported  in EPA
control technique guideline documents.   Because there is a net  credit from
operating the control  systems, costs for these sources  are not  included in
this report.

                                  A3.4-11

-------
          Petroleum Storage Facilities.  We estimated the costs and produ
recovery credits associated with floating roof installation and a double
seal on floating roofs for model crude oil and gasoline storage tanks.
Since a net credit was produced, no costs are included in the chapter for
these controls.

          The incineration system on the storage tanks of the Trans-Alask
pipelines does not recover product; it is the only control for crude oil
and gasoline storage that has a net cost.  Also, control  costs for naphth
jet fuel storage are reduced but not outweighed by product recovery
credits.  Costs for the Alaska storage tanks and net costs for the naphth
jet fuel tanks are reported in this chapter.

          Petroleum Transfer Operations.   We calculated costs and credits
for two types of vapor recovery systems on model bulk terminals using
current gasoline prices.  EPA reported costs and credits  for a vapor
balance system on a model bulk plant.   Because a net credit exists for ea<
system, no costs are reported.

          There are, however, net costs for a vapor balance system on
gasoline service stations.  These costs and credits were  based on model
plant costs and actual and forecast gasoline prices and industry data.
                                  A3.4-12

-------
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                        Chapter A3.5  Coal Cleaning


          Revision of this chapter included adjusting pollution control
costs to 1981 dollars, expanding the discussion of applicable regulations
to include SIPs, and updating the discussion of industry characteristics.

Regulations

          NSPS for coal preparation plants that process more than 200
tons/day of bituminous coal (40 CFR 60.250} were promulgated on January 15,
1976.  The standards limit particulate emissions and plume opacity for
thermal dryers and pneumatic coal cleaning equipment.  They set opacity
limits for processing and conveying equipment, storage systems, and
transfer and loading systems.

          SIPs regulate opacity and particulate emissions from coal
cleaning facilities.  Most of the SIP particulate regulations are patterned
after process weight rate emission limits suggested in Appendix B (40 CFR
51, App. B) as standards achievable with RACT.

Industry Characteristics

          This chapter covers the mechanical coal cleaning process and does
not include desulfurization.  Control costs are estimated for thermal
drying plants, because the thermal drying process results in the greatest
level of emissions from the coal cleaning industry.

          Mechanical coal cleaning involves methods similar to those used
in the ore-dressing industries.  About 97 percent of coal cleaning is done
by wet-processing methods, with pneumatic or air cleaning methods being
used for the remainder.  About 13 percent of the coal cleaned by
wet-processing methods is thermally dried before being loaded.  Coal is
dried to avoid freezing problems, to facilitate handling, to improve
quality, or to decrease transportation costs.   In 1976, there were 114
thermal drying plants that processed a total of about 35 million short tons
of coal.  The annual quantity of thermally dried coal depends both on the
amount of coal produced and the proportion of coal  that is cleaned.

          In 1980, the total production of bituminous and lignite coal  in
the United States was 780 million short tons from more than 6000 mines.
The average annual rate of growth in production for 1971 through 1980 was
about 4.5 percent.  Production is expected to rise to 1.4 billion tons by
1990, representing an average annual growth rate of about 4 percent for
1980-1990.  This increase is a result of the relatively higher prices of
oil and gas since 1979, which induced the substitution of coal for oil  and
gas.
                                  A3.5-1

-------
          About 40 percent of the coal mined in this country is
mechanically cleaned.  The percentage declined slightly in the 1970's as c
result of increased use of surface mining.  Coal taken from surface mines
contains fewer impurities than coal from underground mines and, therefore
requires less cleaning.  The proportion of coal mined in surface mines  (a;
opposed to underground mines) increased during the 1970's, largely because
of the strict regulations of the 1969 Coal Mine Health and Safety Act.   Ir
the early 1970's, production was equally divided between underground and
surface mining.  By 1980, about 40 percent of the production came from
underground mines and the remainder from surface mines.

          The increased use of flue gas desulfurization (FGD) systems by
utilities may increase future demand for mechanically cleaned coal.
Although utilities that burn naturally-available low sulfur coal do not
require cleaned coal, those that operate FGD systems demand clean coal  for
more efficient operation of the FGD systems.  The revised NSPS for utility
boilers (40 CFR 60.40a), which virtually requires the use of FGD systems •
meet the sulfur dioxide standards (see Chapter A3.1), may provide incenti\
for utilities to use higher sulfur, deep-mined coal that would require
cleaning.  The percentage of coal that is cleaned may increase as a resuV
We assume, however, that the current percentage will not change
substantially in the 1980's.

Pollutants and Sources

          The emissions of primary concern from mechanical coal cleaning
plants are the particulates resulting from drying operations.  Data
available indicated that 74 percent of the coal drying capacity was
equipped with the devices capable of removing at least 99 percent of the
particulate matter in the effluent gas.  The remainder of the capacity  wa:
equipped with low-energy cyclones which remove only about 90 percent of  tf
particulate matter.  To meet environmental regulations, these cyclones  wi'
have to be replaced with the high-energy venturi scrubbers.

Control Technology and Costs

          In most cases, the technology used for removing particulate
matter will be venturi scrubbers.  If other technology is used for some o-
the driers, its cost should be comparable to the cost of venturi scrubbers
thus a cost analysis based on venturi scrubbers should be valid.

          A report, Background Information For Standards of Performance:
Coal Preparation Plants gives some cost information on scrubbers for coal
driers.  This cost information was applied to the plant population of
thermal driers to produce the aggregated costs of compliance.  The costs
shown in Table A3.5.1 reflect the costs for the previously uncontrolled
fraction of the industry to comply with State Implementation Plans.
Additionally, costs for new dryers subject to NSPS are shown, in agreement
with information in the NSPS review (i.e., 17 new dryers since
promulgation).  This NSPS cost trend is extrapolated into the future years
The aggregated costs for compliance with both SIP and NSPS regulations  are
shown in Table A3.5.2.
                                  A3.5-2

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                      Chapter A3.6  Coal Gasification

          Revision of this chapter was limited to adjusting pollution
control costs to 1981 dollars, general editing, and revising the discussion
of regulations.

Industry Characteristics

          Currently, no commercial coal gasification plants operate within
the United States.  Coal gasification is an emerging industry in which the
first announced commercial plants will produce a high-Btu synthetic gas
from coal to supplement domestic natural gas production.

          Consumption of natural gas is constrained by the available
supply.  Dwindling reserves and the rising cost of natural gas are forcing
consumers to seek alternative forms of energy such as coal, oil  and
electricity.  Consumption of natural gas is expected to decline as a
percent of total U.S. energy consumption.  Synthetic gas from coal is one
alternative source of natural gas which is anticipated to supplement
domestic natural gas production.

          Coal  gasification is the combination of coal and water to form
carbon monoxide, hydrogen, and some methane.  Both pressure and elevated
temperatures are required to promote the gasification reactions, which are
many and varied.  Thus, the key requirements for coal gasification are coal
(carbon), water (steam), and heat.

          Commercial coal gasification processes in use today outside the
United States include the Lurgi, Koppers-Totzek, and Winkler processes, all
for the manufacture of synthesis and fuel gases.  Practically all  of the
first-generation coal gasification projects—those being engineered for the
United States in commercial sizes today—are based on use of the Lurgi
process.  Three types of coal gasification plants have been proposed—
low-Btu gasifiers for industrial and utility boiler fuels; intermediate-Btu
gasifiers producing "synthesis" gas as feedstock for manufacture-of liquid
fuels, methanol, ammonia and possibly other valuable chemicals;  high-Btu or
substitute natural gas (SNG) to supplant declining natural gas supplies;
and an intermediate-Btu gas for local use.  For the low-Btu case,  no
commercial-sized plants exist; however, pilot-scale and demonstration
plants are planned.  Intermediate-Btu gas projects in the United States are
also under consideration at this time, with no announced commercial plants.

          High-Btu gas is well advanced with at least 22 plants  under
study.  Because high-Btu gasification is nearest commercial production, and
process and emission control schemes are unclear for the other cases, this
report is directed toward high-Btu gas (SNG).

          It is difficult to project the growth of the coal gasification
industry.  Uncertainties about world oil prices, coal  and heater
availability, and FPC decisions concerning incremental or roll-in  pricing


                                  A3.6-1

-------
have already delayed the construction of the first proposed coal
gasification plants.  Government incentives, including loan guarantees
and/or subsidies, could encourage more rapid development of coal
gasification.  For purposes of this report, it has been estimated that one
plant will be constructed by 1986 and that the industry will grow at an
annual rate of 20 percent from 1986 through 1990.

Emission Sources and Pollutants

          As previously noted, the first-generation gasification processes
are based on the Lurgi coal gasifier.  In the Lurgi gasifier, gasification
takes place in a countercurrent moving bed of coal at 2.07-2.76 x 10  N/m
(300-400 psig) and 540-760°C (1000-1400°F).  A cyclic operation using a
pressurized lock hopper is used to feed coal.

          The pressurizing medium is a slip stream of raw gas which may
later be repressurized and put back into the raw gas stream.  The gasifier
has a water jacket to protect the vessel and provide steam for
gasification.  Other features include blades to mechanically overcome
caking, a moving grate on the bottom to remove dry ash, and a mechanism to
introduce steam and air or oxygen uniformly over the gasifier.

          Several high-Btu gas projects using the Lurgi coal gasifier have
been announced and are at various stages of engineering.  In addition to
the gasification process itself, other major components include a large,
250-500 megawatt power boiler and steam superheater to provide steam for
the gasification process; an oxygen plant which supplies oxygen to the
gasifier; coal receiving, handling, storage, and preparation facilities;
by-product recovery and storage, and waste-treating and -disposal
facilities.  The product gas has a typical heating value of 35-36 million
joules per cubic meter (950-970 Btu per standard cubic foot) and consists
of roughly 96 percent methane, 2 percent COp, 1 percent inert gas, and les
'than 1 percent mixture of hydrogen and .carbon monoxide.

          Lurgi coal gasification plants emit particulate matter, sulfur
dioxide, nitrogen oxides, nonmethane hydrocarbons, and carbon monoxide.
The steam generating facility is the primary point source that accounts fc
the bulk of the nitrogen oxides, particulate matter and sulfur dioxide
emissions.  The coal handling facility accounts for the remaining
particulate matter emissions.  The primary point sources of virtually all
of the nonmethane hydrocarbon emissions, the remaining sulfur dioxide
emissions (in the form of hydrogen sulfide), and carbon monoxide emissions
are the coal gasifier lockhoppers, coal gas purification facilities,
by-product recovery facilities, gas/liquor separation facilities, and the
sour water stripping facilities.

Regulations

          Because coal gasification is an infant industry, all plants are
newly constructed and subject to standards governing new sources.  Althoug
no NSPS has been proposed for coal gasification plants, two promulgated
NSPS cover emissions from selected sources in the plants.  The NSPS for
                                  A3.6-2

-------
fossil-fuel-fired steam generators (40 CFR 60.40) covers participate,
sulfur dioxide, and nitrogen oxides emissions from the steam generating
facilities.  The NSPS for coal preparation plants (40 CFR 60.250) covers
particulate emissions from the coal handling facility.  For purposes of
this report, it is expected that an NSPS will be proposed to regulate the
remaining emission sources in this industry by the time the first plant has
been constructed.  This NSPS would regulate nonmethane hydrocarbons and
hydrogen sulfide from the waste gas stream.

          Only the New Mexico SIP has emission regulations specific to coal
gasification plants.  Other SIP regulations that would apply to these
plants are general emission standards for particulates, sulfur dioxide,
nitrogen oxides, and hydrocarbons.

Control Technology

          The Lurgi coal gasification plants projected for construction in
the United States by the domestic  natural gas industry will employ the
Lurgi Rectisol process to remove carbon dioxide and hydrogen sulfide from
the coal gas.  The Rectisol system is not considered an emission control
system because sulfur removal is a process requirement of coal
gasification.

          Data and information developed by the domestic natural gas
industry indicate that this process will  discharge two waste gas streams.
Depending on the properties of the coal gasified, the composition of one of
the waste gas streams will be about 90-95 percent carbon dioxide, 0.5-1
percent nonmethane hydrocarbons, and 0.25-5 percent hydrogen sulfide; and
the composition of the other waste gas stream will be about 55-95 percent
carbon dioxide and 5-40 percent hydrogen sulfide.

          Standards of performance for these emissions expected to be
proposed by 1986 can not be based on existing plants because none exist.
Therefore, emission control systems estimated for compliance with the
expected NSPS covering these waste gas streams have been based on a
"transfer-of-technology" from other industries.

          The emission control technology demonstrated in the steel
industry, the oil and natural gas production industry, the petroleum
refining industry, and the carbon black manufacturing industry to control
emissions of hydrogen sulfide and nonmethane hydrocarbons can be
"transferred" to the coal gasification industry for application to Lurgi
coal gasification plants.  These control  technologies include the use of
Stretford and Glaus sulfur recovery plants, tail-gas scrubbing to reduce
sulfur emissions further, and incineration to reduce nonmethane hydrocarbon
and carbon monoxide emissions.  These control technologies will control
about 98 percent of the sulfur compounds and nonmethane hydrocarbons.

          Compliance with the steam generator NSPS is assumed to be
achieved with an electrostatic precipitator and Wellman-Lord flue gas
desulfurization system.  It is assumed that fabric filters and water sprays
are installed for compliance with the coal preparation plant NSPS.


                                  A3.6-3

-------
Costing Methodology

          The emission control capital costs under existing regulations
range from $13.0 to $46.8 million for a 7 million cubic meter per day (25
million standard cubic feet per day) plant.  These costs range from 1 to
percent of the anticipated capital costs of the coal gasification plant
($870 million).  The cost variations result from variations in the sulfur
content of the coal and the availability of water.  The associated total
annualized costs range from $18.8 to $28.7 million or 8 to 12 mills per
cubic meter ($0.23 to $0.35 per thousand standard cubic feet).

          The standards of performance expected to be proposed by 1986
would not increase the control costs over those of existing regulations ft
low-sulfur coal.  The increase in installed capital costs to meet the
proposed standards of performance for other coal would range from $1.7 to
$3.3 million or 0.2 to 0.4 percent of the anticipated capital costs of a
Lurgi plant.  The associated total annual costs are $0.76 to $1.5 million
or $0.35 to $0.70 per thousand cubic meters ($0.01 to $0.02 per thousand
standard cubic feet).  These are incremental costs of emission control
above those to meet existing regulations.

          The emission control stated above excludes estimated emission
control costs associated with coal handling and steam generation.  These
installed costs range up to $29.0 million with annualized cost up to $7.4
million or 3 mill per cubic meter ($0.09 per thousand standard cubic feet
of product.

          The total costs summarized in Table A3.6.1 are indicated for bo-
SIP and NSPS regulations.
                                  A3.6-4

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                      Chapter A3.7 Wood Waste Boilers '


          Revision of this chapter was limited to adjusting pollution
control costs to 1981 dollars and editing the discussion of regulations.

Regulations

          The NSPS (40 CFR 60.40) for fossil-fuel-fired steam generators
cover those larger wood-waste boilers that are capable of burning fossil
fuels at a heat input rate greater than 250 million Btu per hour.  A NSPS
for non-fossil fuel-fired boilers, a category that includes wood waste
boilers with a heat input rate less than 250 million Btu per hour, is
currently under development.

          SIP regulations govern the smaller wood-waste boilers and larger
boilers constructed prior to 1971.  Most state regulations limit wood-waste
boiler emissions under general emissions standards, which are patterned
after suggested RACT standards for fuel burning (40 CFR 51, Appendix B).
The limits for most states fall  in the range from 0.1 to 0.6 Ib per million
Btu.  Alaska and Florida have SIPs that distinguish wood-waste boilers from
other types.  The Florida SIP limits particulate emissions to 0.3 Ib per
million Btu from wood-waste boilers with heat input greater than 30 million
Btu per hour.

Industry Characteristics

          The burning of wood/bark waste in boilers is generally largely
confined to those industries where it is available as a by-product.  The
wood/bark wastes are burned both to recover heat energy and to alleviate
the potential solid waste problem.  The fuel  for a wood-waste boiler is
generally wet bark and wood refuse originating from the debarking and
cleanup of logs prior to shredding.  A machine, called a hog, is used to
reduce the size of the wood and  bark materials to prepare them for firing
in a boiler.  A variety of furnace designs are used for wood-waste firing,
such as Dutch ovens, spreader stokers, and suspension burners.   For some of
the larger operations, conventional boilers have been modified to burn
wood-bark wastes.  These latter  units may include spreader stokers with
travelling grates, vibrating grate stokers, as well as tangentially fired
or cyclone-fired devices.

          Heating values of hogged fuel range from about 8000 to 9000
Btu/lb on a dry basis.  However, because representative moisture contents
of 40 to 75 percent, the as-fired heating values for many wood-bark waste
materials range from about 4000  to 6000 Btu/lb.  Typical wood-waste boilers
are 6 million Btu/ hr with larger units as high as 900 million Btu/hr.
Most commonly, industrial wood-bark fired boilers have steam capacities of
20,000 to 150,000 Ib/hr.
                                  A3.7-1

-------
          The estimated number of wood-waste boilers in 1979 was 500.  Of
these, it was estimated that 35 had capacities of 200,000 to 900,000 Ib
steam/hr.  The remainder of the units ranged in capacities from about 5,OC
to 180,000 Ib steam/hr.

          The growth rate for wooa-waste boilers was assumed to be 4
percent per year from 1965 through 1979, and 3 percent per year for 1979
thereafter.

Pollutants and Sources

          The major pollutant of concern from wood/bark waste boilers is
particulate matter.  Furnace design and operating conditions are
particularly important for efficient burning of wood-bark wastes.   In wooc
bark waste combustion, the primary pollutant is particulate matter from tf
entrainment of ash and sand in the combustion gases.  Wood, unlike coal or
oil, has a negligible quantity of sulfur and sulfur emissions are therefor
very low, so that it was assumed that no SOp control would be needed for
wood-waste boilers.

          The emission factor for particulates from wood/bark waste boiler
is 25 to 30 pounds per short ton of wood waste (50 percent moisture).

Control Technology

          Various devices can be applied to wood-waste boilers to control
particulate emissions.  Generally, particulate removal efficiencies for
various units are as follows:

          Multitube Cyclones:  94-95 percent
          Wet scrubbers:  98 percent
          Electrostatic precipitators:  97-99 percent
          Baghouse:  99.5 percent.

          According to a 1976 study, one of the best available systems fo
handling particulates from wood-waste boilers is a multitube cyclone
collector in series with a low energy impingement scrubber.

Costing Methodology

          Control costs were estimated using the combination
cyclone/scrubber unit.  Equipped with a unit with a removal efficiency of
99.9 percent, boilers can readily meet the strictest emission regulations
of 0.1 grain/SCF or 0.1 lb/10° Btu.

          Pollution control costs for wood-waste burning were estimated
using two sizes of model boilers (i.e., 300,000 and 55,000 Ib steam/hr).
The large 300,000 Ib steam/hr boiler was representative of 35 boilers in
1979 with capacities of 200,000 to 900,000 Ib steam/hr.  The 55,000 Ib
steam/hr unit was representative of 465 boilers with capacities ranging
from about 5,000 to 80,000 Ib steam/hr.
                                  A3.7-2

-------
          The costs of control  are given in Table A3.7.1 and were estimated
for the following industry sectors and regulations:

                    Sector                      Regulation
                 Small  boilers                      SIP

                 Large boilers                 SIP and NSPS
                                  A3.7-3

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                        Chapter A4  Mobile Sources

          Mobile sources costs have not been substantially revised.
Changes in total costs primarily reflect updates of production data.
Revisions to the chapter text include general editing and minor updates to
the regulations.

          Mobile sources are significant contributors to national
air-quality problems.  In areas subject to photochemical smog formation,
over half the reactants can generally be attributed to motor-vehicle
emissions.  Similarly, motor-vehicle emission frequently cause large
concentrations of carbon monoxide in high-traffic-density urban areas
during traffic peaks,  in cities with large and busy commercial airports,
aircraft operations are often the principal source of high levels of carbon
monoxide, hydrocarbons, nitrogen oxides, and particulates in the vicinity
of the runways and terminals.

          Light duty vehicles (automobiles) and light-duty trucks have been
highly significant and visible pollutant sources because of the large
numbers in service.  Consequently, they have been under federal controls
since the 1968 models.  Federal emission standards for heavy-duty motor
vehicles have been in effect since 1970, standards for aircraft emissions
went into effect in 1974, and standards for motorcycles were imposed
beginning with the 1978 model year.  Evaporative emission standards and
their control are not included in this chapter.

          EPA began regulating lead content in gasoline in 1974.  The costs
associated with the lead phase-down requirements may logically be
associated with either the petroleum refining industry or mobile sources.
Lead phase-down costs have been included in this chapter so that the light
duty vehicle emission control costs represent the total consumer cost of
automobile emission regulations.

          Other mobile sources, such as railroad locomotives, marine
engines, and farm, construction, and garden equipment have been under study
by EPA.  Since no regulations for these sources have been promulgated or
proposed, they are not included in this report.

          This chapter is organized into three sections:  regulations,
control technology and cost methodology.  The regulation and control •
technology sections are further subdivided by source category.   The source
categories are (1) light duty vehicles, (2) light duty trucks,  (3)  heavy
duty vehicles, (4) motorcycles, (5) aircraft, and (6) gasoline.
                                   A4-1

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Regulations

Light Duty Vehicles

          Table A4.1 presents the emission standards for light duty
vehicles.   The standards are expressed in terms of maximum levels of
gaseous emissions per unit distance permitted from the vehicle while
operating  on a prescribed duty cycle.   Sampling procedures and test
equipment  are also prescribed by the regulations.  The certification
procedure  requires that test cars meet emission standards after being
driven over a prescribed durability schedule for 50,000 miles.  For certa'
standards, waivers to less stringent levels are available on a case-by-ca:
basis.

          Accompanying the revisions in emission standards themselves have
been changes in the Federal Test Procedure.  These were implemented for tf
1972 and 1975 model years.

          The EPA Administrator suspended the 1975 statutory standards for
carbon monoxide and hydrocarbons and the 1976 statutory standards for
nitrogen oxides for one year.  The suspension followed a determination the
the effective control technology was not available.  EPA established
interim standards attainable with then existing emission control
technology.

          Federal standards prior to 1975 applied only to gasoline fueled
vehicles.   Those for 1975 and later model years apply to both gasoline anc
diesel fueled vehicles.

          The Clean Air Act also allowed California to set more stringent
standards  for vehicles sold only in that state.  California sets standard;
more stringent than federal standards for most model years.  This chapter
does not include costs for meeting California regulations.

Light Duty Trucks

          Table A4.2 presents the emission standards for light duty trucks
which are expressed in the same terms as those for light duty vehicles.
Before 1975, trucks weighing less than 6,000 pounds were subject to
standards  for light duty vehicles (automobiles), and trucks weighing more
than 6,000 pounds were subject to standards for heavy duty gas engines.
Beginning  with the 1975 model year, EPA set standards for light duty true!1
with an upper gross vehicle weight limit of 6,000 pounds.  The light duty
truck regulations covering the 1979 through 1983 model years increased the
upper gross vehicle weight limits of 6,000 pounds.  The light duty truck
regulations covering the 1979 through 1983 model years increased the upper
gross vehicle weight limit from 6,000 pounds to 8,500 pounds, made minor
changes in test procedures, and increased the stringency of exhaust
emission standards.
                                   A4-2

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Heavy Duty Vehicles

          Separate emission control regulations have been in effect since
1970 for new heavy duty gasoline and diesel truck engines manufactured for
use in over-the-highway trucks and buses.  These standards apply to trucks
with a minimum gross vehicle weight of 6,000 pounds for 1978 and earlier
model years and a minimum of 8,500 pounds for model years after 1978.
Heavy duty truck engine certification test procedures are performed on the
engine itself and do not pertain to the vehicle, as is the case for light
duty truck and light duty vehicle (automobile) regulations.

          Federal emission standards for heavy duty gasoline engines are
presented in Table A4.3 and for heavy duty diesel engines in Table A4.4.
The regulations covering 1970 through 1973 model year heavy duty gasoline
engines set hydrocarbon and carbon monoxide emission standards.  The 1973
heavy duty diesel engine standards covered smoke emissions only.
Regulations for 1974 and later model years added standards for carbon
monoxide and hydrocarbon emissions for heavy duty diesel engines and set
either nitrogen oxides or hydrocarbon plus nitrogen oxides emission
standards for both gasoline and diesel engines.  All of these standards are
expressed in terms of grams per unit work, i.e., grams per brake horsepower
per hour (bhp/h).

          The pre-1979 model year heavy duty gasoline engine standards
measured emissions in terms of average concentrations in the engine exhaust
over a nine mode, constant speed, variable load dynamometer cycle.  The
pre-1979 test procedure for diesels was different:  emissions were averaged
over a 13 mode, variable speed, variable load dynamometer cycle.  The 1979
through 1983 regulations for both gasoline and diesel engines changed both
test procedures and test instrumentation.

          The 1977 Clean Air Act Amendments required that EPA prescribe
(for heavy duty engines and vehicles) emission standards requiring at least
a 90 percent reduction for hydrocarbons and carbon monoxide from
uncontrolled levels beginning with the 1984 model year, unless certain
findings are made.  A new test procedure based on a transient driving
schedule representative of on-road operation is being considered.

Motorcycle

          EPA promulgated both the interim (1978-1979) and longer term
emission standards (1980 and later) for motorcycles in 1977.  The
standards, which do not apply to motorcycles with engine displacements of
less than 50 cubic centimeters (cc), prohibit crankcase emissions  and set
limits on gaseous emissions.

          Motorcycle gaseous emission standards are summarized in  Table
A4.5.  The interim hydrocarbon exhaust emission standard varies with engine
displacement:  from 50.0 g/km (8.1 g/mi) for motorcycles with up to 170 cc
displacement and increasing proportionately with displacement up to 14.0
g/km (22.6 g/mi) for motorcycles with displacement of 750 cc and greater.
Hydrocarbon standards for 1980 and later model years and carbon monoxide

                                   A4-9

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        Table A4.5  New vehicle standards summary - motorcycles !_/
    The following is a summary of motorcycle standards adopted by the
                      Environmental Protection Agency
Year
Prior to
Controls 3/
1978-79
1980 &
later
Displacement 2/
All (average)
50-169
170-749
750 & larger
All (50 & larger)

5.
5.
5.
14
5.
Hydrocarbons
6 g/km
0 g/km
0 + 0.0155(0-170)
g/km
0 g/km
Carbon
monoxid
21.5 g/k
17 g/km
17 g/km
g/km 4
17 g/km"
12 g/km
_!/   A motorcycle is any motor vehicle with a headlight, taillight, and
     stoplight, and having:  two wheels or three wheels and a curb mass
     less than or equal to 680 kilograms (1499 pounds).
2/   Displacement shown in cubic centimeters
J/   Uncontrolled Emissions:

                                   Hydrocarbons       Carbon monoxide
      2-stroke       range         7.0-13.8 g/km      12.5-21.0 g/km
                     average          9.6 g/km           16.8 g/km
      4-stroke       range         1.0-2.1 g/km       11.0-31.0 g/km
                     average          1.8 g/km           26.1 g/km

4_/   Motorcycle Hydrocarbon Formula
          D = engine displacement in cubic centimeters
              e.g., 300 cc engine;
               standard =  (300-170) X .0155 + 5.0 = 7.0 g/km

g/km - grams per kilometer
                                                                 4/28/82
                                A4-14

    -------
standards for 1978 and later model years do not vary with size of engine.
No standard for nitrogen oxides has been promulgated, because the
motorcycle contribution to motor vehicle nitrogen oxides emissions is
negligible, estimated to be less than one-half percent in 1990.

Aircraft

          Table A4.6 presents the aircraft emission standards.  The
regulations, which cover various new and in-use aircraft engines, are based
on the need to control emissions occurring under 900 meters (3,000 feet) to
protect ambient air quality in urban areas.  They reflect emission levels
judged by EPA to be practicable with present and projected technology.  The
regulations include fuel venting restrictions beginning in 1974, smoke
emission standards beginning in 1974, 1976, 1978, and 1981 for various
engine classes, and gaseous emission standards (carbon monoxide,
hydrocarbon, and nitrogen oxides) beginning in 1981 and 1982.   Gaseous
emission regulations are based on a simulated landing and take off operating
cycle that includes taxi/idle (out), takeoff, climb out, approach, and
taxi/idle (in).  Piston engines were included in the standards beginning in
1980 but have since been deleted.

          In August 1976, EPA promulgated regulations limiting emissions
from currently certified SST aircraft manufactured after January 1, 1980,
and more stringent emission standards for SST aircraft that are newly
certified after January 1, 1984.  In March 1978, EPA extended the
compliance date for gaseous emission standards from January 1, 1979,  to
January 1, 1983, for most engines except piston aircraft.

          In late 1982, EPA issued standards for new and in-use aircraft
gas turbine engines with the exception of those used for general aviation
aircraft.  These most recent standards set new limits on hydrocarbon
emission, eliminated carbon monoxide and nitrogen oxides standards, and
designated new engine classes.

Gasoline

          EPA regulations governing lead content in gasoline directly
affect fuel costs for light duty vehicles.  Gasoline marketers were
required to make available 91 research octane number lead-free gasoline by
July 1, 1974, for use in oxidation catalyst-equipped vehicles.  Another
regulation required that the lead content of the total  gasoline pool  be
reduced to an average of 0.13 gram per liter (0.5 gram per gallon) by
October 1980 for large refiners and by October 1982 for small  refiners.  In
October 1982, EPA promulgated a new lead content regulation that limited
lead content to 1.1 grams per gallon (gpg) for leaded gasoline only.   The
1.1 gpg "lead only" standard is intended to be equivalent (in  terms of
total lead usage) to the existing 0.5 gpg standard in the near term and to
accelerate the removal of lead from gasoline thereafter.

          Lead phase-down requirements advanced the need for installation of
new octane-generating capacity compared to the requirement that would
naturally result from the gradual replacement of vehicles that use leaded
gasolines by vehicles that use unleaded gasoline.

                                   A4-15

    -------
Control  Technology

Light Duty Vehicles

          1968-1974 Model  Years.   From 1968 to 1974, compliance with
federal  emission standards was achieved by utilizing various combinations
of the following:

          •  Purging crankcase fumes through the engine

          •  Recalibration and tighter precision in carburetor fuel
             metering

          •  Engine intake air preheat and temperature control

          •  Spark retard at idle and low speeds

          •  Reduced compression  ratios and eliminating combustion chamber
             pockets

          t  Air injection into the exhaust manifold

          •  Changes in value timing and recirculating exhaust gas

          •  Capturing fuel evaporative emission in charcoal canisters or
             in the crankcase.

          1975-1976 Model  Years.   When the 1975 statutory standards were
suspended for a year and replaced with less stringent interim standards, '
became apparent that two types of emission-control  systems could be used
for the 1975 model year:  (1) oxidation catalyst-equipped systems, and (2
advanced engine modifications systems.  The oxidation catalyst systems we
preferred by the industry, and approximately 85 percent of the 1975 model
year sales included catalysts.  Other changes and additions for some 1975
model-year cars included:

          t  Quick-heat manifold
          •  High-energy ignition
          0  Advanced carburetors
          •  Air injection.

          Because the 1976 emission standards called for the same
hydrocarbon, carbon monoxide, and nitrogen oxide levels as the 1975 inter
standards, only minor changes in  emission control  systems were made from
1975 models.  Proportional exhaust gas recirculation was introduced in sot
models.

          1977-1979 Model  Years.   Automobile companies met the 1977
standards with only minor modifications to engines  and control devices.
These modifications took the form of increased use  of secondary air for
catalyst operation, improved exhaust gas recirculation, and ignition timi
modification or modified catalysts with decreased use of secondary air.

                                   A4-16

    -------
          1980  Model Year.  1980 standards required addition of a modified
catalyst, and electronic control modules for the following items:  spark
control, exhaust-gas recirculation, air-to-fuel ratio, and air injection.

          1981 and Subsequent Model Years.  In addition to the
modifications in the prior model years, 1981 standards required a three-way
(HC, CO, NO ) catalyst system plus a downstream oxidation catalyst on some
models.

Light Duty Trucks

          The emission control technology used in light duty trucks is
similar to that in light duty vehicles.

Heavy Duty Vehicles

          The emission control technology used for heavy duty gasoline
engines through 1973 is similar to that employed for light duty trucks and
light duty vehicles through the 1972 model year.  Many heavy duty gasoline
engines are derivatives of light duty vehicle engines.  For 1974, the
nitrogen oxide control standards were generally attainable without the use
of exhaust gas recirculation (EGR), which was required for light duty
trucks and vehicles.  However, some engines with EGR were certified to meet
the 1973 California standards, which are the same as 1974 federal
standards.

          Most heavy duty diesel engines have achieved both smoke and
gaseous emission standards, including those for 1974, with fuel-injection
system modifications.  Carbon monoxide standards are easily attainable by
most diesel engines; even uncontrolled diesels are usually well  within
carbon monoxide standards.

Aircraft

          Aircraft met the 1974 - 1975 fuel venting restrictions by
plumbing and/or operational changes and the 1974 smoke standards by
combustor and fuel nozzle retrofit.  The 1976 through 1980 smoke and
gaseous emission standards required no additional hardware for compliance.
The 1981 and 1982 gaseous emission standards were met with a modified
engine hot section.  1983 and later model  year standards are expected to
require advanced combustor and engine concepts.

Cost Methodology

          Table A4.6 presents the total cost of mobile source pollution
control.  Capital expenditures for mobile source air pollution controls
represent the costs of pollution control hardware requirements for
automobiles, five weight classes of trucks (less than 6,000 pounds,
6,000-8,500 pounds, 8,500-10,000 pounds, gasoline trucks over 10,000
pounds, and diesel trucks over 10,000 pounds), motorcycles, and aircraft.
For all except aircraft, these costs were calculated by multiplying an
average cost per vehicle by the annual production (actual  historical  and

                                   A4-17

    -------
forecast) of that vehicle type.  Historical production results were taken
from an MVMA report and earlier EPA studies.  Future production figures
were based on forecasts in Automotive News and projections by DRI.  Per
vehicle cost estimates were based on previous EPA studies.

          Costs for light duty trucks and heavy duty vehicles are primari'
based on cost estimates for light duty vehicles.  Cost estimates for
aircraft controls were based on the economic impact assessment prepared ft
a recent relaxation of the aircraft emission control standards.  The most
recent standards for which costs per vehicle were estimated are the 1979
moael year light duty trucks and heavy duty vehicles, the 1980 and later
model year motorcycles, and the 1981 and later model year automobiles and
aircraft engines.

          O&M expenditures for mobile sources were developed based on
estimates of the average impact of emission controls on maintenance cost,
fuel economy, and fuel cost (due to requirements for unleaded fuel) in eac
model year.  A simple model that takes into account the stock of various
model year vehicles in each year, numbers of miles driven per year by age
and average fuel economy was employed.

          Emission controls may result in either an increases or a reduct'
in maintenance costs.  Emission controls that generate a net reduction in
maintenance costs include high-energy ignition systems, long-life exhaust
systems, the use of catalysts, and unleaded fuel.  The net
emissions-related maintenance costs are estimated to be either negative o
zero for most model years.

          EPA has estimated that the application of some control technique
reduces fuel economy.  Although there is much controversy over the issue,
the costs in this chapter include the penalties and benefits of fuel
economy effects originally estimated by EPA.  Fuel economy penalties are
estimated for pre-1976 model year light duty vehicles and trucks and
pre-1983 model year heavy duty vehicles.  Fuel economy benefits are
estimated for post-1975 model year light duty vehicles and trucks.  It is
difficult to estimate fuel economy benefits associated with 1977 and late»
model year vehicles, because manufacturers are required to meet corporate
average fuel economy (CAFE) standards mandated by the Energy Policy and
Conservation Act of December 1975.

          The cost of lead phase-down requirements was incorporated into
the total unleaded gas price penalty incurred by owners of automobiles the
require unleaded gasoline.  This gas price penalty also includes the cost
of additional pumps at service stations.
                                   A4-18

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    -------

    -------
                     Chapter A5.  Chemicals Industries
          For the purposes of this report, the Chemicals Industries are
defined as those establishments which manufacture products primarily by
chemical  modifications of raw materials and for which the final product is
a chemical.

          Those included are the:

             Petrochemicals Industry
             Vinyl  Chloride
             Nitric Acid Industry
             Sulfuric Acid Industry
             Phosphate Fertilizer Industry
             Nonfertilizer Phosphorus Chemicals
             Mercury-Cell Chior-Alkali Industry
             Ammonia and Urea
             Ammonium Nitrate Fertilizers

          Costs for the abatement of air pollution for these industries are
summarized in Table A5.  These costs and other data are repeated below in
the appropriate section together with the assumptions specific to the
industrial sector and other details.
                                   A5-1

    -------
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    -------
                   Chapter A5.1  Petrochemicals Industry

          This chapter contains emissions control cost estimates for the
following six large-volume petrochemicals that are manufactured by
oxidation processes:

             Formaldehyde
             Acrylonitrile
             Ethylene Oxide
             Ethylbenzene/Styrene
             Maleic Anhydride
             Dimethyl Terephthalate/Terephthal ic Acid

There are many other petrochemicals.  These six chemicals were selected for
inclusion because EPA projected both their 1982 production and potential
uncontrolled emissions of regulated pollutants to be high.

Industry Description

          There is no hard and fast definition that clearly separates
petrochemicals from all other segments of the organic (containing carbon)
chemical industry.  In general, petrochemicals are relatively simple
organic chemicals that are manufactured from the primary organic chemicals
derived from cracking and distillation of petroleum.  However, some of the
same "petrochemicals" may be produced from primary chemicals derived from
coal-tar or natural gas.

          The six chemicals considered in this chapter are also products of
the synthetic organic chemical manufacturing industry (SOCMI).  SOCMI
chemicals ultimately yield synthetic products:  fibers, plastics, dyes and
synthetic rubber.  The NSPS for VOC fugitive emissions lists several
hundred SOCMI chemicals in addition to those discussed in this chapter.
The six chemicals included in this chapter are also chemicals that can be
produced by air oxidation processes.  In fact, 100 percent of
acrylonitrile, formaldehyde, DMT, and TPA production is via air oxidation.
About 18 percent of styrene and 50 percent of ethylene oxide are
synthesized in this manner.  The apparent trend is that emission of
criteria pollutants from the individual  petrochemical manufacturing
industries will be regulated by generic standards that apply to broad
categories such as SOCMI.

          From 1967 until the 1975 recession, the organic chemical  industry
was growing at an annual rate of 8.5 percent.  A growth of 5.9 percent per
year is forecast for the 1980's.  The trend to petroleum feedstocks has
changed the organic chemical industry in two ways.  It has attracted most
of the major petroleum refiners into the chemical industry, and major
chemical companies have acquired or merged with oil companies.  The
potential decontrol of oil and natural  gas is making coal-based feedstocks
more attractive again.

                                  A5.1-1

    -------
          About 46 percent of the plants discussed in this chapter are
located in the states of Texas and Louisiana.  Ohio, New Jersey, and Nort
Carolina each contain about seven percent, and the remainder are sprinkle-
throughout the country, mainly in the southeast.

          Model plant sizes used as the basis for the cost estimates in
this chapter are shown in Table A5.1.1 along with the number of plants
represented by each size category.  A discussion of specific industries
follows.  The four-digit SIC codes to which each chemical is assigned are
shown with the headings below.

          Formaldehyde (SIC 2869).  Formaldehyde is synthesized by oxidat
methanol with air and is sold as an aqueous solution (usually 37 percent
weight).  About 75 percent of the domestic formaldehyde production used t
silver catalyst process and the other 25 percent used the metal oxide
process in 1980.

          The industry is characterized by a large number (53) of
relatively small plants.  Since more than half the formaldehyde is
ultimately used for wood products, the producing plants are located main!;
in the South and Northwest.  Because most formaldehyde is shipped as a
solution containing 50 percent or more water, shipping costs are relative
high.  Thus, formaldehyde plants tend to be located near consumption poin
where possible.

          Production in 1980 was 5,693 million pounds of 37 percent
formaldehyde.  The manufacture of adhesive for particle board and plywood
constitutes 60 percent of formaldehyde end uses.  Plastics (primarily use1
in automobiles and appliances) account for about 15 percent more.
Formaldehyde is also an intermediate in many polymers and derivatives.

          There is evidence that urea/formaldehyde foam insulation and
particle board may emit toxic gases.  Research is now underway on this
problem; its impact on future control requirements is not yet clear.
However, the Consumer Product Safety Commission banned the use of
urea/formaldehyde foam insulation in February 1982.

          Formaldehyde production is expected to grow at a rate of about
five percent per year through 1990.  This growth rate assumes improvement
in the demand for materials used for residential cons-truction (for new
units and/or expansion and repair of existing units).

          Acrylonitrile (SIC 2869).  Domestic acrylonitrile is produced b;
four companies at six locations.Each plant employs a process involving
the catalytic ammoxidation of propylene.  Other methods have been used in
the past and a pilot plant has been built to produce acrylonitrile from
propane.

          The average annual growth rate for acrylonitrile production was
5.8 percent from 1970 through 1980 and 8.5 percent from 1975 through 1S80
Production in 1980 was 1,830 million pounds.  Growth was due primarily to
increased demand for acrylic fibers in the apparel and home furnishings

                                  A5.1-2

    -------
           Table A5.1.1  Plant sizes for selected petrochemicals
                                               Million pounds per year
Product/Process
Number of
plant sites
Plant size
Range Average
EPA Model
Plant Size
Formaldehyde
  Silver Catalyst

  Metal Oxide Catalyst
Acrylonitrile

Ethylene Oxide
  Air Oxidation
  Oxygen Oxidation

Styrene
Maleic Anhydride
  Benzene
  Butane

DMT/TPA
  DMT from crude - TPA

  TPA
24
10
11
 8
 6
 9

 8
 5
 7
 2
 2
 2
 3
  60- 195
 200-1500
  45- 117
 120- 250

 265- 440
  99-1274
  99- 701

  80- 600
 900-1500
  26-  84
  21-  60
 500- 550
1250-1344
 240-2000
 101
 406
  83
 155

 358
 728
 283

 344
1230
  50
  37
 517
1297
1080
 100

 100


 397
 500
 300

 661
 50
593 I/
\j  This is a crude TPA plant.

Sources:  1980 Directory of Chemical  Producers United States,  pp.  60, 61,
            64, 241-2, 581-2, 587-8,  557-8, 822-3, 933.
          1981 Directory of Chemical  Producers United States,  pp.  49, 51,
            53, 56.
          EPA-450/3-80-028d.  IT Enviroscience, Inc.   Organic  Chemical
            Manufacturing Volume 9:   Selected Processes,  Formaldehyde,"
            "Ethylene Oxide," December 1980, p. IV-1.
          EPA-450/3-80-028a.  IT Enviroscience, Inc.   Organic  Chemical
            Manufacturing Volume 6:   Selected Processes,  Maleic
            Anhydride," "Ethylbenzene/Styrene," December 1980, p.  IV-1.
          EPA-450/3-80-028e.  IT Enviroscience, Inc.   Organic  Chemical
            Manufacturing Volume 10:   Selected Processes, "Acrylonitrile,1
            December 1980, p. IV-1.
          EPA-450/3-80-028b.  IT Enviroscience, Inc.   Organic  Chemical
            Manufacturing Volume 7:   Selected Processes,  Crude
            Terephthalic Acid, Dimethyl  Terephthalate, and Purified
            Terephthalic Acid,"  December 1980, p.  IV-1.
                                  A5.1-3

    -------
industries.  Acrylic fibers accounted for 67 percent of acrylonitrile
production in 1977.  Exports accounted for 22 percent of production in 198
and were expected to increase in 1981.  Acrylonitrile's derivative
acrylonitrile-butadiene-styrene (ABS) copolymer is used in packaging and,
along with styrene-acrylonitrile polymer (SAN), had an annual growth rate
of eight percent from 1977 through 1980.  However, because acrylonitrile i
still considered a potent carcinogen by the FDA, additional regulations
concerning its use may appear soon and slow its growth rate.  A 5.9 percen
annual growth rate may be estimated tnrough the 1980's, based on the
expected growth for SOCMI.

          Ethylene Oxide (SIC 2869).  Ethylene oxide is produced by the
direct oxidation of ethylene, with either air or oxygen used as the oxidan
and with a silver catalyst.

          There were 12 producers in 1981 and a total  of 15 plants.
Production in 1980 was 5,300 million pounds.  Ethylene oxide's growth is
dependent on the automobile and polyester industries.   Ethylene glycol,
which is used in anti-freeze and polyester fibers and films consumed 60
percent of 1980 production.  Ethylene oxide production grew at an annual
rate of 3.9 percent from 1975 through 1980, and an EPA-suggested growth
rate of about five percent per year from 1978 through 1983 could continue
through the 1980's.

          Ethylene oxide is considered a health hazard by the Occupational
Safety and Health Administration (OSHA) and by the Food and Drug
Administration (FDA).  Its use as a sterilant or fumigant may be further
regulated.

          Ethylbenzene/Styrene (SIC 2865).  Ethyl benzene and styrene are
being considered together because practically all (99 percent) ethylbenzen
is used as an intermediate in styrene production, often in the same plant.
There are 14 companies producing ethyl benzene in 17 plants.  Styrene is
produced by 10 companies in 13 plants.

          The primary process for domestic ethyl benzene production is by
benzene alkylation with ethylene.  Except for one plant using the Oxirane
process, all domestic styrene is produced by the catalytic dehydrogenation
of ethylbenzene.  Future plants' use of the Oxirane process will depend on
the economics of both the styrene and the propylene oxide that are
coproduced by this process.

          Production of ethylbenzene was 7,611 million pounds in 1980.
Production of styrene in 1980 was 6,904 million pounds.  Demand for styren
(and, therefore, for ethylbenzene) has recently been reduced by the
severely depressed housing and auto markets.  Eighty percent of styrene
production goes into polymers that yield plastics and resins for both
markets.    Another 10 percent of production goes toward styrene-butadiene
rubber for tires.  Exports account for the remainder.   The industry could
have a growth rate of five percent per year through the 1980's after
recovery from the recession of the early 1980's.


                                  A5.1-4

    -------
          Maleic Anhydride (SIC 2865).  Approximately 73 percent of
domestic maleic anhydride is produced by the oxidation of benzene.
Twenty-five percent is produced by the oxidation of n-butane and the
remainder (at one small plant) is derived as a by-product of phthalic
anhydride production.   Although the proposed benzene NESHAPs would require
using the n-butane process in new maleic anhydride plants, manufacturers
would select this process anyway because lower feedstock costs make it more
economical.  We assume in this report that all maleic anhydride production
capacity now using the benzene oxidation process will continue to do so.

          There are presently eight companies producing maleic anhydride at
eight locations.  One plant uses both the n-butane and benzene processes;
it is treated as two separate facilities in the plant inventory in Table
A5.1.1.  A 130 million pound facility is due on-stream in 1983.  Production
in 1980 was 298 million pounds.  Approximately 52 percent of maleic
anhydride production is consumed in the manufacture of the unsaturated
polyester resins that go into glass-fiber-reinforced plastics for the auto
and construction industries.  Annual  growth projections in the six to seven
percent range are now suggested for maleic anhydride.

          Dimethyl Terephthalate/Terephthal ic Acid (DMT/TPA) (SIC 2860).
DMT and TPA are alternative raw materials for the production of polyester
products.  One gram of purified TPA can be substituted for 1.17 grams of
DMT.   Both DMT and purified TPA are produced from crude TPA.  Crude TPA is'
synthesized by air oxidation of p-xylene in the presence of acetic acid.

          Production in 1980 was 5,995 million pounds.  Polyester fiber
accounts for 80 percent of production, films account for eight percent,
polyethylene terephthalate (PET) barrier resins for soft drink bottles
account for about eight percent, and other forms and exports account for
the rest.  PET barrier resins are the fastest growing use for DMT/TPA at
this time.

          This industry exhibited an average annual growth rate of 30
percent from 1966 to 1976, making it the fastest growing of all the major
intermediate petrochemicals during that period.  Industry sources project
annual growth for the 1980's between three and eight percent.

Emission Sources and Pollutants

          The major air pollution problem in the petrochemicals industry is
the emission of VOCs and carbon monoxide via off-gases produced in
oxidation processes.  The petrochemicals creating this problem include not
only oxygen-containing compounds, such as oxides, aldehydes, and
anhydrides, but also compounds in which oxygen serves an intermediate role
in the synthesis, such as acrylonitrile.

          A typical process of this type begins with the raw material, air
(sometimes oxygen), and sometimes a third reactant being fed into a
vaporphase catalytic oxidation reactor.  The reactor effluent gases go to
an absorber in which the desired product is scrubbed out.   The off-gas from
this absorber, which is vented to the atmosphere, is primarily nitrogen and

                                  A5.1-5

    -------
carbon dioxide, but smaller amounts of carbon monoxide and unconverted
hydrocarbons are also present.   The emission sources and pollutants are
discussed below for each of the six petrochemicals.

          Formaldehyde.  Two processes are currently used to produce
formaldehyde: silver catalyst and metal  oxide.   In both processes methanol
is converted into formaldehyde  by mixing with air.

          The primary source of VOC emissions in both processes is the
product absorber vent.  The product fractionator vent is also a major
source in the silver catalyst process.  Smaller amounts of emissions occur
from storage and handling of methanol  and formaldehyde, and fugitive VOCs
are potentially emitted from process pumps, valves, and circulating coofir
water.  VOC emissions are in the form of unreacted methanol, methanol
vapors, formaldehyde, methyl formate,  methylal, and water vapor.

          Acrylonitrile - SOHIO Process.  The absorber vent gas is the
largest source of emissions; it contains nitrogen, oxygen, propane,
propylene, acrylonitrile, hydrogen cyanide, acetonitrile, other organics,
and some water vapor.  The composition of the vent gas depends on such
factors as the catalyst, reactor conditions, and propylene purity.
Propylene and propane account for approximately 90 percent of the VOCs
emitted.

          The column vents are  the next largest emissions source.
Emissions also result from the  storage and handling of acrylonitrile and
by-product and intermediate streams.  Fugitive  emissions from process
pumps, compressors, and valves  account for approximately 11 percent of
uncontrolled emissions.

          Ethylene Oxide - Air  Oxidation Process.   The main process vent
emits 89 percent of VOC emissions in the form of nitrogen, unreacted
oxygen, ethane, unreacted ethylene, ethylene oxide and CO-.  The overhead
stream from the stripper column is vented through  a stripper purge vent
which emits six percent of total VOC emissions.

          Fugitive emissions come from pumps, compressors, valves, and als
from the process water from the desorbers.  Emissions also result from the
storage and handling of ethylene oxide.

          Primary emissions from the oxygen oxidation process of ethylene
oxide production are generated  by a C02  purge vent and an argon purge  vent
Controls have not been required on the C02 purge vent because of the
extraordinarily high cost.  Control of the argon purge vent is estimated t
be insignificant.

          Styrene.  The primary reactions in the production of styrene are
catalytic alkylation of benzene with ethylene to produce ethylbenzene  and
catalytic dehydrogenation of ethylbenzene to produce styrene.  This proces
emits VOCs in the form of benzene, ethylbenzene, styrene, ethane, ethylene
and methane.  About 60 percent  of these  process VOC emissions is in the
form of benzene.

                                  A5.1-6

    -------
          Seventy-two percent of the benzene emissions is from the process
itself, including 62 percent from the column vents, and 21 percent is from
storage and handling.  Seventy-five percent of the VOC emissions is from
the process (56 percent from the column vents and 19 percent from the
alkylation reaction section), 14 percent is from storage and handling, and
11 percent is fugitive.

          Maleic Anhydride.  Ninety-seven percent of the VOCs and benzene
emitted comes from process emissions.  The product-recovery scrubber vent
gas containing CO, benzene, and other VOCs is the major source of air
pollutants.  At most maleic anhydride plants, emissions from seme or all of
the storage tanks are vented directly to the atmosphere.  These emissions
include benzene, maleic anhydride and xylene.  Process pumps and valves are
a potential source of fugitive emissions.

          The n-butane process does not use benzene so there are no benzene
emissions.  There are no public data on this process yet, but other VOC
emissions are believed to be about the same as those from the benzene
process.

          DMT/TPA-Crude TPA.  The reactor vent is the principal emitter of
pollutants"!  The vent gas contains unreacted p-xylene, acetic acid, carbon
dioxide, methyl acetate, and carbon monoxide.  VOCs are emitted from vents
at each stage of the process.

          Emissions result from the storage of p-xylene, acetic acid and
n-propyl acetate.  There are no VOC handling emissions since crude TPA is
transferred in solid form, and by-product waste methyl acetate is
transported by pipeline to incinerators.  Fugitive VOC emissions also occur
from this process.

          This report does not include costs for control of emissions from
DMT production from crude TPA or purified TPA production from crude TPA.
Adequate data are unavailable for costing control of DMT production
emissions.  Emissions from purified TPA production are insignificant.

Regulations

          SIPs.  The applicable air-pollution regulations are the various
state requirements for the control of volatile organic compounds (VOCs),
carbon monoxide, and particulate organic materials.  Only a few states
established VOC regulations in their original 1972 SIPs, but almost all
states (especially those with non-attainment areas for ozone) set limits
for VOC sources in SIPs revised after 1977.  Most states pattern their SIPs
after Appendix B RACT (40 CFR Part 51) or LA Rule 66.

          NESHAPs.  NESHAPs were proposed for Benzene Emissions from Maleic
Anhydride Plants on April 18, 1980 (45 FR 26660), Benzene Emissions from
Ethylbenzene/Styrene plants on December 18, 1980 (45 FR 83448), Benzene
Fugitive Emissions on January 5, 1981 (46 FR 1165) and Benzene Emissions
from Benzene Storage Tanks on January 19, 1980 (45 FR 83952).


                                  A5.1-7

    -------
          The two NESHAPs for benzene process emissions are more stringen'
than typical  SIP VOC regulations.  For a new production unit in a
sufficiently large maleic anhydride plant, the maleic anhydride NESHAP
would permit JTO detectable benzene emissions.  (Required controls for
existing plants are somewhat less stringent.)  The ethyl benzene/styrene
NESHAP would set limits for benzene emission from each process vent strear
at new and existing ethylbenzene/styrene plants.

          Benzene fugitive emissions would be limited from sources
containing liquids with ten percent or more benzene by weight.  The
proposed standard would allow no detectable emissions due to leaks from
safety/relief valves and product accumulator vessels.  The standard would
require a leak detection and repair program for pipeline valves and
existing pumps and compressors and would require certain specific equipme
for new pumps, compressors, sampling connections, and open-ended valves.

          The NESHAP for benzene storage vessels affects tanks with
capacity greater than four cubic meters.  Each new and existing storage
tank would be required to have a fixed roof plus an internal floating roo'
that rests on the liquid surface inside the vessel.  Each storage vessel
would also need a liquid-mounted primary seal and a continuous secondary
seal.  Periodic inspections would be required.

          NSPS.  EPA proposed a NSPS for VOC Fugitive Emission Sources in
the Synthetic Organic Chemical Industry on January 5, 1981 (46 FR 1136).
It would require a leak detection and repair program for valves and would
specify certain equipment to reduce VOC emissions from pumps, compressors
sampling connections and open-ended lines.  Leaks from safety/relief valvi
would be prohibited during normal operations.  The standard would apply
only to equipment containing 10 percent or more VOC.

          Other "generic" regulations expected to be proposed are a NSPS
for Air Oxidation Processes in the Synthetic Organic Chemical Industry am
a NSPS for Volatile Organic Liquid Storage.

Control Technology

          Formaldehyde - Silver Catalyst.  VOC and CO emissions from the
product absorber vent can be reduced by 99 percent if the vent stream is
oxidized by thermal oxidation in a waste heat boiler.  This option was
chosen for cost estimation purposes because the high heat value of the ga
makes it more cost-effective than flaring or catalytic oxidation.

          Product fractionator vent VOC emissions can be controlled by
condensing and recycling the gas stream to the secondary absorber, thus
obtaining essentially 100 percent reduction in emissions.  Storage and
handling VOC emissions can be reduced by an estimated 96 percent by
installing vent scrubbers to scrub vapors emitted and collected in
formaldehyde storage and handling areas.  Controls for fugitive emissions
from sources such as pumps, valves, and other equipment can be reduced by
an estimated 81 percent through repair and maintenance programs.
                                  A5.1-8

    -------
          The above-mentioned control technology, which is assumed for
costing, yields an estimated reduction of 94 percent of the total VOC
emissions for the silver catalyst process.  Approximately one third of
existing plants were in compliance with SIPs in 1979.  In estimating
control costs, it was assumed that the remainder would be in compliance by
1983.

          Formaldehyde - Metal Oxide.  The absorber vent emission of VOCs
and CO can be reduced by an estimated 99 percent by thermally oxidizing the
gas stream.  The vent gas is largely inert, making preheating of the
incoming stream with recuperative heat exchangers the most cost-effective
thermal oxidation system.

          Storage and handling VOC emissions can be reduced by 96 percent
by employing a vent scrubber system to scrub formaldehyde storage and
handling vapors.  The VOC content of fugitive emissions can be reduced by
74 percent by repairing and maintaining equipment and by efficient
detection and repair of leaks.

          A reduction of 91.2 percent can be obtained in the total VOC
content of emissions if the above mentioned control technologies are
used.  Approximately eight percent of the plants were in compliance with
SIPs as of 1979.  In estimating control costs, it was assumed that the
remainder would comply by 1983.

          Acrylonitrile.  Absorber vent VOC, CO, and acrylonitrile
emissions can be reduced by 99 percent by thermal oxidation of the vent
gases.  Thermal oxi.dation is most cost-effective when used in conjunction
with a recuperative heat recovery system to preheat incoming gas streams.
VOC emissions from the column vents are reduced 99 percent by incineration
in a flare..  The reduction in total VOC emissions from the acrylonitrile
production process is 86.4 percent when the above mentioned control
technologies are employed.

          For the purpose of estimating control costs, it was assumed that
50 percent of acrylonitrile plants complied with SIPs by 1979 and the
remainder would comply by 1983.

          Ethylene Oxide - Air-Oxidation.  The technology currently
employed to reduce main process vent VOC emissions is catalytic oxidation.
Catalytic oxidation has a VOC removal efficiency of 95 percent and is most
cost-effective when used in conjunction with a waste heat boiler.

          VOC emissions from the stripper purge vent are currently
compressed and recycled to the process (purge reactor).   This system can
produce a control efficiency of 97.3 percent.

          Combining these two technologies (catalytic oxidation and
recycle) provides a Deduction in total VOC emissions from the air-oxidation
process of 90.9 percent.  Conversations with EPA personnel  suggest that all
air oxidation plants have been in compliance with SIPs since at least 1979.


                                  A5.1-9

    -------
          Ethyl benzene/Styrene (Styrene from Benzene-Ethylene).  VOC
emissions from the alkylation reaction section can be controlled by
incinerating the emissions and using the heat for a process boiler.  This
technique lowers the emissions by more than 99.9 percent.  VOC emissions
from the various column vents and from the emergency vent on the separate
can be reduced by 99 percent by venting through a flare.  These controls
are sufficient to meet SIPs and NESHAPs.  It was assumed that plants
subject to SIPs would reach full  compliance by 1983 and those subject to
NESHAPs, by 1984.

          An adequate maintenance program lowers fugitive emissions by up
to 74 percent.  Storage and handling emissions are controlled in various
ways.  Floating-roof tanks reduce benzene storage emissions by 85 percent,
Floating roof tanks are also used for ethyl benzene and toluene storage,
with the same control effectiveness.  Because such storage emission contrc
techniques yield a net credit, their costs are not reported in this
chapter.  Styrene, crude styrene, and tar storage tanks may be vented
through the column vent flare system.  This procedure reduces emissions b^
99 percent.  Crude ethylbenzene storage tanks may be fitted with
refrigerated vents that reduce benzene emissions by 80 percent.  The VOC
emissions from other storage facilities at these plants are insignificant
and not controlled.

          If all of these controls are used at plants employing this
process, 92.6 percent of the benzene emissions and 92.5 percent of the VOC
emissions are controlled.

          For existing styrene plants to comply with the Ethylbenzene/
Styrene NESHAP, the plants would need to retrofit a piping system to
transport the vent gas to the existing process boilers.  Additional burne
and controls must also be added.  Fifty percent of the plants are assumed
to comply within 90 days and the remainder, two years after promulgation.

          Maleic Anhydride.  (Benzene Oxidation Process)  VOC emissions
from the main product recovery vent and from the refining vacuum vent can
be controlled by either carbon adsorption or incineration.  Both VOC and
benzene emissions can be reduced by 99 percent.  The cost estimates for
both SIP and NESHAPs compliance in this chapter are based on use of
incineration rather than carbon adsorption.  Plants subject to SIPs are
assumed to comply by 1983 and those subject to NESHAPs, by 1984.

          Fugitive emission control with a properly designed maintenance
program reduces VOC emissions by up to 73 percent and benzene emissions b:
almost 82 percent.

          Storage and handling emissions may be controlled in various way;
Floating roof tanks reduce emissions from benzene storage by 85 percent.
The emissions from maleic anhydride storage are controlled by an aqueous
scrubber or a xylene scrubber.  Although this is done more for
housekeeping reasons (preventing buildup of solid maleic anhydride), these
methods lower emissions by 99 percent.  The emissions from o-xylene storac
are insignificant and need not be controlled.

                                  AS.1-10

    -------
          If all of these controls are used at plants employing the benzene
oxidation process, 98.5 percent of the benzene and 98.3 percent of the VOC
emissions are controlled.  Based on discussions with EPA personnel, it was
assumed that one-half of the plants would comply with the maleic anhydride
NESHAP within a year and the remainder within two years after promulga-
tion.  Compliance with the benzene storage tank NESHAP by all existing
sources was assumed to occur within two years after promulgation.

          The control technologies for VOC emissions from the process which
produces maleic anhydride by n-butane oxidation should be the same as those
for the benzene oxidation process.  The VOC emission reductions.should also
be similar.  There are no benzene emissions to be controlled, however.

          Because the butane process is not yet sufficiently documented,
control costs for butane maleic anhydride were not estimated.  Since it is
assumed that all new plants will use butane feedstock, no new plant costs
are presented.

          DMT/TPA (Crude TPA Process).  VOC emissions from the terephthalic
acid process vents can be reduced 97 percent by carbon adsorption.  Since
there is a net credit resulting from this technique, the costs are not
reported in this chapter.

          Fugitive emissions can be reduced by up to 71 percent by a
maintenance program.  It is assumed that storage and handling emissions are
controlled with an internal floating roof and secondary seal for NESHAP
compliance.  For purposes of this report plants comply with NESHAP storage
requirements by 1984.

          If all of these controls are used at plants employing this
process, 95.7 percent of total  VOC emissions are controlled.

Cost Methodology

          Table 5.1.2 reports the air pollution control cost estimates for
this industry.  The costs were  based on model plant cost functions for the
sectors described in this chapter.  As discussed above, costs for
controlling process emissions from ethylene oxide - oxygen oxidation
plants and new maleic anhydride plants were not included.

          Product recovery credit functions were estimated separately for
each sector where appropriate.   As shown in Table 5.1.2, plants subject to
NSPS have net O&M savings for 1981 through 1990.  There is a net annual
cost for these plants,- however, because the capital costs are large
relative to the O&M savings.

          Fugitive emission control costs were estimated by using a cost
function approach.  However, a  measure of plant complexity was used as the
basis for the function instead  of plant capacity.  Each petrochemical  was
assigned to a complexity class  based on the physical makeup of typical
plants.
                                  A5.1-11

    -------
          The main sources of cost data were Organic Chemical
Manufacturing, Volumes 6-10 (EPA 450/3-80-028a through e) and the
background information documents prepared by EPA for the proposed NESHAP
and NSPS.
                                  A5.1-12

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                                                               A5.1-13

    -------
                       Chapter A5.2  Vinyl Chloride

          This chapter discusses the vinyl chloride industry and other
chemical industries whose processes emit vinyl chloride to the atmosphere.
The end products of such processes include vinyl chloride monomer (VCM),
ethylene dichloride (ED) manufactured by oxychlorination in a balanced
EDC-VCM plant, and polyvinyl chloride (PVC) and copolymers of PVC.
Revision of this chapter included adjusting the costs to 1981 dollars and
updating the discussion of applicable regulations.

Regulations

          A NESHAPS for vinyl chloride, a hazardous pollutant (40 CFR
61.60), was promulgated on October 21, 1976.  The vinyl chloride
limitations, which are summarized in Table A5.2.1, cover processes in vinyl
chloride plants, ethylene dichloride plants, and polyvinyl chloride plants.

          These plants would also be subject to two NSPS currently under
development to regulate volatile organic compounds (VOC), including vinyl
chloride.  One NSPS will govern VOC emissions from volatile organic liquid
storage containers.  The other will regulate fugitive VOC emissions in the
synthetic organic chemical manufacture industry, which includes these
plants.

          The vinyl chloride standard is being reviewed to evaluate its
adequacy and appropriateness in light of new information on health effects,
technology, and compliance and enforcement experience with the standard.

Industry Characteristics

          Vinyl chloride is produced in the United States by two methods:
the addition of hydrogen chloride to acetylene and the dehydrochlorination
of ethylene dichloride.  Only two plants in the United States use the first
method.

          Ethylene dichloride is also produced by two methods:  the
catalytic chlorination of ethylene with chlorine and the oxychlorination of
ethylene with hydrogen chloride and oxygen.

          The major use for ethylene dichloride in the United States  is in
the production of vinyl chloride.  It is usually convenient and economical
to manufacture both products in the same plant in a balanced operation in
which part of the ethylene dichloride requirement for the plant is produced
by the chlorination of ethylene with chlorine.  After purification,  the
ethylene dichloride is converted to vinyl  chloride and hydrogen chloride in
a cracking furnace operating at about 510 C (950 F) dehydrochlorina.tion of
ethylene dichloride).   Hydrogen chloride is recovered and recycled to an
oxychlorination process for the conversion of additional  ethylene to
additional ethylene dichloride (oxychlorination of ethylene).  In this

                                  A5.2-1

    -------
            Table A5.2.1.   Vinyl  chloride emissions limitations
    Emission source/process
         Limitation
Balanced ethylene dichloride - vinyl  chloride plants
EDC formation and purification                10 ppm
VCM formation and purificatiun                10 ppm
Oxychlorination process                       0.2 g/kg (0.4 Ib/ton) EDC
Relief valve discharges                       prohibited*
Manual venting of gases                       prohibited*
Polyvinyl chloride plants
Equipment through stripper
Equipment following stripper

Reactor openings
Relief valve discharges
Manual venting of gases
10 ppm
2000 ppm (dispersion resins
400 ppm (all other resins)
0.02 g/kg (0.04 Ib/ton) PVC
prohibited*
prohibited*
*Except under emergency conditions
                                 A5.2-2

    -------
manner, essentially all of the chlorine that is used eventually winds up in
vinyl chloride.

          Polyvinyl chloride (and copolymer) is produced by the catalyzed
polymerization of vinyl chloride (and comonomers).

          Four types of processes are used in the United States to effect
this polymerization.  These processes and the percentage of total U.S.
capacity each represented in 1973 are as follows:  suspension
polymerization (78 percent), dispersion or emulsion polymerization (13
percent), bulk polymerization (6 percent), and solution polymerization (3
percent).

          The production of ethylene dichloride, vinyl chloride, and
polyvinyl chloride was 1.15, 0.91, and 0.82 million metric tons (1.27, 1.0
and 0.91 million short tons), respectively, in 1965.  By 1974 these had
grown to 4.2, 2.60, and 2.15 million metric tons (4.6, 2.9, and 2.4 million
short tons).  Growth of the production of these chemicals is projected to
continue at an average annual rate of approximately 4 percent.  This report
and its estimations of air-pollution control costs are based on the current
regulations for controlling vinyl chloride emissions.  It is not believed
that meeting these regulations will  have a particularly adverse impact on
the production of polyvinyl chloride and its precursors.  However, if
certain contemplated control regulations are promulgated, such as zero
discharge of vinyl chloride emissions from all establishments, the costs
may be higher.

Pollutants and Sources

          The primary air pollutant of concern in the manufacture of
ethylene dichloride (by oxychlorination), vinyl chloride, and polyvinyl   .
chloride is vinyl  chloride monomer (VCM).  When VCM is incinerated as a
means of control,  hydrogen chloride becomes a by-product air pollutant.

          The contributions of vinyl chloride emissions from the
uncontrolled sources in an EDC-VCM plant are shown in Table A5.2.2.

          The contributions of various emission sources to total emissions
of vinyl chloride  differ somewhat from process to process, but the
breakdown shown in Table A5.2.3 for the dispersion process is generally
typical for other processes.

Control Technology

          The best available control technology for balanced EDC-VCM plants
involves the collection and incineration of all emissions from the
formation and purification of vinyl  chloride and ethylene dichloride (by
oxychlorination) and the control  of fugitive emission sources.  Fugitive
emissions can be controlled by the use of:

          •  Multipoint and portable detectors


                                  A5.2-3

    -------
           Table A5.2.2.   Uncontrolled sources of vinyl  chloride
                        emissions in VCM production
                                                   Uncontrolled emissions
            Emission source                         average plant, percen-

Vinyl  chloride formation  and purification                     54
Fugitive emission sources                                     27
Ethylene dichloride purification                              11
Oxychlorination reactor                                      	8
Total                                                         100
      Table A5.2.3.  Uncontrolled sources of vinyl chloride emissions
                  in PVC production (dispersion process)
                                                   Uncontrolled emissions
            Emission source                         average plant, percen'
Sources following stripper*                                   33
Stripper                                                       8
Fugitive emissions sources                                    38
Monomer recovery system                                       12
Relief valve discharge                                         5
Reactor valve discharge                                      	4
Total                                                        100

*Slurry blend tanks, concentrators, dryers, bulk storage, etc.
                                 A5.2-4

    -------
          •  Control  systems on sampling and transfer operations

          •  Collection header systems to connect equipment undergoing
             maintenance or inspection to either the monomer recovery
             system or to an add-on control device

          •  Rupture discs and pressure gauges prior to safety discharge
             valves on pressure vessels and

          •  Dual  mechanical seals on pumps and compressors.

          It is anticipated that fugitive emissions can be reduced by 90
percent by applying these above measures in the typical plant.
Incineration should reduce emissions form the other sources by at least 95
percent.

          The best available control technology for PVC plants varies
somewhat with the type of process.  For all processes, fugitive emissions
can generally be controlled through containment, capture, and ducting of
emissions to a control system, and early leak detection and repair.  Losses
on opening equipment can be reduced by using water to displace VCM to a
control system before opening the equipment.  Reactor relief valve
discharges can generally be eliminated by chemically short-stopping the
polymerization reaction or manually venting gases to a recovery system.
Strippers are used to remove vinyl chloride from the polymer, and carbon
adsorption systems can be used to recover the monomer from the stripper.

          Improved stripper effectiveness solves most of the emissions
problems in operations that follow the stripper, including emissions of VCM
in PVC fabrication operations, although incineration with scrubbing to
remove HC1 is an alternative control strategy.  Emission control  effected
by the stripper, however, is not uniformly applicable to all processes.
Current technology is available to strip the majority of resins except
dispersion resins to 400 ppm or lower.  Dispersion resins, however, are
sensitive to the high temperatures used in stripping other resins, but they
can be stripped effectively to 2,000 ppm.  Most of the remaining VCM is
removed from dispersion resins in the drying process.

          Suspension resins and dispersion resins are polymerized in water
and are ultimately blended in water slurry.  This water contains some vinyl
chloride, which can be removed by steam distillation.  No water is involved
in the bulk polymerization process, so this emission source does not exist
for the bulk process.  However, this process accounts for only about 6
percent of U.S. PVC production.  No consideration is" given here to the
solution process, which is practiced by only one company and accounts for
only about 3 percent of production.

Costing Methodology

          Capital  costs and annual operating and maintenance costs were
estimated for model plants using factors derived from the EPA Support
Document.  It is assumed that very few plants were in compliance before the

                                  A5.2-5

    -------
regulations were promulgated in 1976.  Full compliance for most existing
plants should have been completed by 1978, although it may be 1980 before
all dispersion PVC plants can be brought into compliance.

          The costs developed on this basis are listed in Table A5.2.4.
The industry sectors and regulations costed include the following:

                        Sector                        Regulation

            EDC-VCM Balanced-small plants               NESHAPS
            EDC-VCM Balanced-large plants               NESHAPS
            PVC-Dispersion                              NESHAPS
            PVC-Suspension                              NESHAPS
            PVC-Bulk                                    NESHAPS
                                  A5.2-6

    -------
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    -------
                    Chapter AS.3  Nitric Acid Industry

          Revision of this chapter was limited to adjusting pollution
control costs to 1981 dollars and editing the discussion of regulations.

Regulations

          Both NSPS and SIPs limit nitrogen oxides (nitrogen dioxide)
emissions from nitric acid plants.  Nitric acid plants were among the first
facilities for which NSPS were promulgated on December 23, 1971 (40 CFR
60.70).  The NSPS limits nitrogen dioxide emissions and plume opacity from
process equipment.

          The SIPs of many states contain nitrogen oxides limits that are
patterned after either the NSPS or suggested RACT standards for nitric acid
plants (40 CFR 51, App. B).  Several states specify that the NSPS and RACT
standards based on 100 percent strength nitric acid also apply to plants
that manufacture weak nitric acid (30-70 percent strength).  Several states
have opacity standards stricter than NSPS.

Industry Characteristics

          Nitric acid is produced in 96 privately-owned and 12
government-owned production plants ranging in size from 14 to 390,000
metric tons per year.

          Nitric acid is used in the manufacture of ammonium nitrate and in
numerous other chemical processes.  Ammonium nitrate, which is used both as
a fertilizer and in explosives, accounts for about 80 percent of the nitric
acid consumption.  Nitric acid is produced by oxidation of ammonia,
followed by absorption of the reaction products in dilute acid solution.
Most nitric acid plants in the United States are designed to manufacture
acid with a concentration of 55 to 65 percent, which may subsequently be
dehydrated to produce 99 percent acid.

          The chemical, petroleum and fertilizer industries produce 47,  12,
and 34 percent of the acid, respectively, to account for 93 percent of the
total; lesser quantities are produced by the primary iron and steel  and
aluminum industries.  Total production in the private sector in 1978 was
about 7.30 million metric tons, which shows only a 1.0 percent annual
growth rate from 1970's production rate of 6.74 million metric tons.  In
January, 1979, total capacity of the private sector was 10.6 million metric
tons while the government-owned plants represented an additional  1.1
million tons per year.

Pollutants and Sources

          Nitrogen oxides, the primary pollutants of concern in the
production of nitric acid, are emitted in the tail-gas from absorption
towers.  Numerous variations on the basic nitric acid production  process


                                  A5.3-1

    -------
affect both the emissions and difficulty of control.  Two of the more
important variables are the amount of excess oxygen present in the
absorption tower and the pressure under which the absorption tower
operates.  Many plants practice partial pollution abatement
(decolorization) in accordance with local regulatory agencies.  Under thi
practice, the highly visible reddish-brown nitrogen dioxide is converted
colorless nitric oxide.  Although visible emissions are reduced, the
practice does nothing to prevent emission of nitrogen oxides to the
atmosphere.

Control Technology

          Catalytic reduction with natural gas is a feasible and proven
control technology used in nitric acid plants both here and abroad.  The
absorber tail-gas is mixed with 38 percent excess natural gas and passed
over a platinum or palladium catalyst.  Catalytic reduction with ammonia
hydrogen has the advantage of being selective in the sense that only the
nitrogen oxides are reduced.  However, in addition to higher costs,
reduction with ammonia requires close temperature control to prevent the
reformation of nitrogen oxides at higher temperatures or the formation of
explosive ammonium nitrate at lower temperatures.  Catalytic reduction is
appropriate both in new plants (construction started since 1972) and olde
facilities to meet both SIP and NSPS requirements; reductions in nitrogen
oxide emissions by about 93 percent are achieved.

Costing Methodology

          Cost functions derived from published papers and an EPA report
were applied to arrays of data showing plant capacity range, average
capacity, and number of plants within a capacity range.  These were applii
to both government- and privately-owned plants for new and old plants to
meet NSPS and SIP standards; all plants were assumed to be required to me'
such standards.  It has been assumed that the government-owned plants
achieved compliance by 1975 for both SIPs and NSPS; privately owned plant
were assumed to have achieved NSPS since 1975 but will not achieve SIP
compliance until 1980, having started in 1973.

          The costs developed for this industry are shown in Table A5.3.1
                                  A5.3-2

    -------
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    -------

    -------
                   Chapter A5.4  SuIfuric Acid Industry

          Revision of this chapter was limited to adjusting pollution
control costs to 1981 dollars and editing the discussion of regulations.

Regulations

          Sulfuric acid plants were in the first group of industries for
which NSPS were promulgated on December 23, 1971 (40 CFR 60.80).  The NSPS
sets sulfur dioxide, sulfuric acid mist, and opacity standards for process
equipment of sulfuric acid plants.

          Since sulfuric acid mist is not a criteria pollutant, the setting
of a NSPS for mist forces the states to establish standards for sulfuric
acid mist as a designated pollutant for existing sulfuric acid plants (40
CFR 62).  On October 18, 1977 (42 FR 55796), EPA issued guidelines to
states for setting sulfuric acid mist limits for existing plants,

          Many states'  SIPs have regulations identical to the NSPS; some
apply to new plants and some, to new and existing plants.  At least one
state has opacity standards more stringent than the NSPS.  Other states
patterned their regulations of existing plants after the RACT sulfur
dioxide limits for sulfuric acid plants suggested in Appendix B (40 CFR 51,
App. B) and the guideline sulfuric acid mist limits.  A number of  states,
however, have not yet required existing plants to meet standards as strict
as any of these limitations.

Industry Characteristics

          Sulfuric acid is manufactured by chemical and fertilizer
companies and by companies primarily engaged in smelting nonferrous metals;
both sources compete for the same buyers.  Nevertheless, the sulfuric acid
manufactured by the smelter industry is primarily a by-product resulting
from efforts to reduce sulfur dioxide emissions to the atmosphere, and
secondarily, as an attempt to generate additional revenue.   For the
purposes of this report, smelter produced acid is considered to be part of
the smelter industry rather than the sulfuric acid industry.

          The major products of the sulfuric acid industry  are concentrated
sulfuric acid (93 to 99 percent) and oleum.  A few sulfuric acid plants
associated with the fertilizer industry produce less-concentrated  grades of
acid.  Essentially, all sulfuric acid in the United States  is produced by
the contact process, less than 0.1 percent being produced by the older
chamber process.

          About 65 percent of the sulfuric acid produced in the United
States is used in the manufacture of phosphate fertilizers; the rest is
used in myriad industrial applications ranging from steel pickling to
detergent manufacturing/
                                  A5.4-1

    -------
          In sulfur-burning plants, sulfuric acid is produced by burning
elemental  sulfur with dry air in a furnace to produce sulfur dioxide.  Th>
latter is  catalytically converted to sulfur trioxide.  The hot converter
effluent is cooled and introduced to an absorption tower where the sulfur
trioxide is absorbed in a sulfuric acid solution to form more sulfuric ac'
by its reaction with water.

          Some plants (including spent-acid plants and smelter-gas plants'
operate on the same principle as sulfur-burning plants, except that tne
sulfur dioxide is obtained from the combustion of hydrogen sulfide or fror
smelter off-gas.  In these plants, the sulfur-bearing gas is dried with
sulfuric acid and cleaned (subjected to particulate and mist removal
process) before introduction to the acid plant.

          As of January 1, 1979, 59 companies operated sulfur-burning or
wet-process contact acid plants in 121 locations and 13 companies operatet
smelter-acid plants in 24 locations; only 1 company operated a chamber ac
plant in one location.  Production plants range in size from 4,500 to
1,823,400  metric tons per year.

          In 1978 production of sulfuric acid was about 35.9 million metr
tons of which about 3.6 million metric tons was smelter acid.  Although
1977 and 1978 each showed increases in production of about 10 percent
annually,  longer term forecasts are more in the range of a growth rate of
about 3.5  percent per year.  Total capacity of contact acid plants
excluding  smelter-gas-based plants was 38.6 million metric tons per year
January 1, 1979; capacity including smelter-gas plants was 44.6 million
metric tons per year.

Pollutants and Sources

          Emissions from sulfuric acid plants consist of sulfur dioxide.
gases and sulfuric acid mist.  These pollutants evolve from incomplete
conversion of sulfur dioxide to sulfur trioxide in the converter, and froi
the formation of a stable mist consisting of minute particles of sulfuric
acid that resist absorption in the acid absorber.

Control Technology

          Control of sulfur dioxide emissions may be achieved by the use i
several technologies including molecular sieves, the Wellman-Lord process
ammonia scrubbing, and dual absorption.  Because dual absorption acceptab
meets EPA standards and is universally applicable, its costs were used in
computing S02 control costs.

          Control of acid mist to meet NSPS can be reliably met only
through the use of vertical tube demisters.  SIP guidelines can be met in
sulfur burning plants producing acid and weak oleum by the less costly
vertical panel or horizontal dual pad demisters.  However, in plants usin<
chemical-bound sulfur as feedstock or producing strong oleum (>20 percent
SO-,) only the vertical tube demister is reliable.
                                  A5.4-2

    -------
Costing Methodology

          Cost functions were derived from data in numerous sources over
the period 1974 to 1977 including EPA Guideline Documents and were applied
to arrays of data showing plant capacity range, average capacity, and
number of plants within a given capacity range.  Data on industry
characteristics reflect information available in the published literature
up through 1979.

          NSPS costs were applicable to plants put on stream after January
1, 1975.  SIP costs for SO  control on existing plants were estimated to
start in 1973 and be completed in 1980.  SIPs on acid mist were not
effective until 1979, and it was estimated that most installations were
complete by late 1981.

          The costs developed on the above basis are shown in Table AS.4.1.
The costs do not include costs of controls for smelter-acid plants.
                                  A5.4-3

    -------
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                                                                        A5.4-4

    -------
                Chapter A5.5  Phosphate Fertilizer Industry

          Revision of this chapter was limited to adjusting the pollution
control costs to 1981 dollars and expanding the discussion of applicable
regulations.

Regulations

          Five NSPS covering fluoride emissions from the phosphate
fertilizer industry were promulgated on August 8, 1975 (40 CFR 60.200, 210,
220, 230, 240).  Specific standards were established for different industry
sub-classes or processes as follows:

                       Total Fluoride Emission Limit
                 (grams per metric ton of phosphorus feed)

                   Subclass or Process                    Limit

           Wet process phosphoric acid plants             10.00
           Superphospnoric acid plants                     5.00
           Diammonium phosphate plants                    30.00
           Triple superphosphate plants                  100.00
           Granular triple superphosphate
             storage facilities                            0.25*

           *grams/hour/metric ton


          Since fluoride is a designated pollutant, states are required to
revise their SIPs to include fluoride standards for existing phosphate
fertilizer plants.   The EPA guidelines for fluoride standards, which  were
issued March 1, 1977, recommended that states use the NSPS standards.

          Process weight standards and other general  particulate emission
limitations in SIPs govern the particulate emissions  from phosphate
fertilizer plants.   A NSPS for phosphate rock plants  (40 CFR 60.400),  which
was promulgated April 16, 1982, set particulate limits for the processes
that prepare phosphate rock for conversion to phosphate fertilizer.  The
costs of complying  with this recent NSPS are not included in this  chapter.

Industry Characteristics

          The major products of the phosphate fertilizer industry  are
ammonium phosphates, triple superphosphate (TSP), normal  superphosphate
(NSP), and granular mixed fertilizers (NPK).  Phosphoric acid and
superphosphoric acid are intermediate products.

          All  phosphate fertilizers are processed from ground phosphate
rock treated with sulfuric acid to produce either normal  superphosphate or


                                  A5.5-1

    -------
wet-process phosphoric acid.  A phosphoric acid intermediate may then be
reacted with ammonia to produce diammonium phosphate and other ammonium
phosphates, or reacted with ground phosphate rock to manufacture triple
superphosphate.  Superphosphoric acid, produced by dehydration of
wet-process phosphoric acid, is used in preparing some mixed fertilizers.
Granular mixed fertilizers are made from either normal superphosphate or
triple superphosphate, with ammonia and potash.  Bulk-blended mixed
fertilizers and liquid mixed fertilizers are manufactured by physically
mixing particles of other fertilizer components.

          The phosphate fertilizer industry is characterized by a number i
large, modern, efficient plants located near the source of raw materials.
In general, these plants manufacture more concentrated forms of fertilize
diammonium phosphate (DAP and triple superphosphate (TSP).  These
industries are found particularly in Florida.

          Smaller plants, located near the retail markets, manufacture thi
less concentrated forms:  granulated mixed fertilizer (NPK) and normal
superphosphate (NSP).  The smaller NSP, NPK, and bulk-blend plants are
located in the farming states.

          Due to the seasonal demand for fertilizer, many plants
manufacturing NSP and NPK operate only a portion of the year.  In contras'
those plants manufacturing DAP and TSP generally operate year-round.

Pollutants and Sources

          Emissions from phosphate fertilizer processing plants are main!;
fluorides (in the form of hydrogen fluoride and silicon tetrafluoride) an<
particulates.  Fluorides are generated in the processes of acidulation of
phosphate rock which contains calcium fluoride.

          In the phosphate fertilizer industry, particulate emissions of
significance originate from:  phosphate rock grinding; TSP manufacture; D,
production; NSP manufacture; and NPK bulk-blending and granulation plants

          In phosphate rock processing, particulate emissions are issued
from the drying, grinding, and transfer processes.  The emission factors
for these processes are 7.5, 10, and 1 kg per metric ton (15, 20, and 2
pounds per short ton) of rock respectively.

          In granular TSP production, particulate emissions may originate
from a number of points in the process.  Most of the particulates .are giv1
off in the drying and product-classification processes.  The off-gas from
the reactor (in which phosphate rock is acidulated with phosphoric acid)
and the blunger (in which the reactor effluent is mixed with recycled
product fines to produce a paste) may account for a considerable percenta
of the total particulates emitted.

          Particulate emissions from DAP manufacture originate mainly fro
the granulator and the dryer.  It has been estimated that the total
emissions amount to approximately 20 kg per metric ton (40 pounds per sho
ton) of product from both sources.

                                  A5.5-2

    -------
          Emissions from the manufacture of run-of-pile NSP originate from
both the acidulation and "denning" processes.  Although the emission
factors for particulates are not known, they are estimated to be in the
order of 5 kg per metric ton (10 pounds per short ton).

          The NPK or granulation plants manufacture a variety of products.
Many emission factors probably will apply for this class of fertilizer
plant.  In fixing the emission factors, these plants are assumed to employ
an ammoniation-granulation process similar to that used in the DAP process,
or to emit approximately 20 kg of particulates per metric ton of product
(40 pounds per short ton).

          The emission factors for particulates are high in the TSP, DAP,
and NPK plants.  The bulk of these emissions in all three processes
originates from the granulation process.  There is a strong economic
incentive to reduce these emissions since they contain valuable products
and in many cases are associated with ammonia vapors (from the ammoniation
process), whose recovery is an economic necessity.

Control Technology

          Most of the phosphate rock of higher available phosphorus
pentoxide content is ground and beneficiated to enhance its reactivity and
to eliminate some of the impurities.  The particulate emissions from the
grinding and screening operations may be controlled effectively by
baghouses in which the dust is deposited on mechanically cleaned fabric
filters.  The dust-laden gas from the rock-drying (and perhaps
defluorination) operations may first pass through'a cyclone and then
through a wet scrubber (such as venturi).  The efficiency of this
combination should be better than 99 percent.
                                                    •
          Particulate and fluoride emissions from phosphate fertilizer
plants traditionally have been removed from gaseous waste streams by wet
scrubbing.  While efforts have been directed at removing 'fluorides, up to
99 percent of the particulates are simultaneously removed.  Wet scrubbers
of varying efficiencies have been used for this double purpose.  The
fluoride and particulate-laden scrubber water is usually disposed of in a
gypsum pond.

          For control of particulate emissions from granular TSP plants, it
is assumed that various wet scrubbers will be provided for a number of
gaseous waste streams.  The effluent from the reactor.-granulator is assumed
to be scrubbed in two stages,'first by a cyclone and second by a cross-flow
packed scrubber.  The gases from the drier and cooler are assumed to be
scrubbed in venturi-type packed scrubbers.  Waste gases from storage of the
granular product are usually scrubbed in a cyclone scrubber, although some
plants use packed scrubbers.  The scrubbing liquid used in all scrubbers is
assumed to be recycled pond water except for the first-stage scrubbing of
gases from the reactor-granulator, where weak phosphoric acid is used and
recycled to the reactor.
                                  A5.5-3

    -------
          In DAP plants, control  of particulates is assumed to be achieve-
for gaseous streams originating from the reactor-granulator, the drier, a
the cooler, together with combined gaseous streams ventilating such
solids-processing equipment as elevators, screens, and loading and
unloading.   Two-stage scrubbing is assumed to be employed for each of the
streams listed.  The first stage is assumed to consist of a cyclone
scrubber; the scrubbing medium is diluted phosphoric acid (30 percent) fo
purposes of recovering ammonia and the product.  Most of the particulate
matter is assumed to be removed in the first stage, and the balance in th
second stage consisting of a cross-flow packed scrubber in which recycled
pond water is used as the scrubbing medium.

          It is assumed that only run-of-pile normal superphosphate is
produced in NSP plants.  A cyclone scrubber often is employed in removing
particulates in gaseous streams originating from the reactor-pugmill, den
and curing operations.

          An ammoniation-granulation process is assumed for NPK plants.
Cyclones are normally installed ahead of primary scrubbers.  The primary
scrubber (typically employing dilute phosphoric acid as a scrubbing mediu
is considered an integral part of the process in which valuable reactants
(ammonia) and the product are recovered.

          Cross-flow scrubbers have been used in estimating costs of
controlling emissions of both particulates and fluorides.  Most of the
control technologies described above have been applied for more than a
decade.  Wet scrubbers of varying efficiencies have been integral parts o
many phosphate fertilizer processes.  The collection of waste gaseous
streams and the removal of fluoride compounds from these streams has long
been practiced to protect the health and safety of process operating
personnel.  Collection of particulate materials from those waste gaseous
streams is dictated by economic necessity because valuable products are
involved.

Costing Methodology

          As shown in Table A5.5.1, there are no costs which are
attributable to air pollution regulations.  This is the result of
widespread use of control devices as a part of industry processes. EPA ha
issued guidelines (Federal Register, March 1, 1977) by which the States a
to control fluoride emissions.  Costs may accrue in the future, depending
on the regulations in revised State Implementation Plans.
                                  A5.5-4

    -------
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    -------
             Chapter A5.6  Nonfertilizer Phosphorus Chemicals

          This chapter includes the production of elemental phosphorus,
defluorinated phosphate rock, and feed-grade calcium phosphate.  Revision
of this chapter was limited to adjusting pollution control costs to 1981
dollars and editing the discussion of regulations.

Regulations

          SIPs govern the particulate and fluoride emissions from the
defluorination processes in this industry.  Particulate control is required
for these processes to meet the general process weight standards and other
types of limitations found in most SIPs.  Several states have also
established control regulations for fluorides.  The fluoride emission cost
estimates for the industry were based on the Florida standard.

          There is no NSPS for this industry.  The NSPS for phosphate rock
plants specifically excludes mining, beneficiation, thermal defluorination,
elemental phosphorus production, and nodulizing.

Industry Characteristics

          In 1979, 21 plants were engaged in producing elemental
phosphorus, defluorinated phosphate rock (DFP), and feed-grade calcium
phosphates (Dical).  The combined capacity of these plants was
approximately 1.9 million metric tons per year (2.1 million short tons per
year) (PpOc equivalent) in 1979,  Nine plants producing elemental
phosphorus account for nearly 60 percent of the total capacity (P^Og basis)
involved in producing these nonfertilizer phosphorus products.  A sQmmary
of model plant size distributions and capacities for the three products is
provided in Table A5.6.1.

          The production of industrial  phosphorus and phosphate-containing
animal feeds begins with thermal and/or chemical processing of phosphate
rock.  Phosphates that are suitable as additives to feeds may result from
the direct defluorination of phosphate rock, defluorination of phosphoric
acid from wet-process acid, or by use of furnace acid (made from elemental
phosphorus).  The production of feed-grade phosphates from furnace acid is
not included here because the defluorination occurs in the phosphate-—
reduction to elemental phosphorus, which is included.  Furthermore, the
production of furnace acid is declining because of the high energy
requirements of the thermal reduction process.  Decreased production by •
this process will be compensated for by increased production from wet
process acids, so the overall production of feed-grade phosphates  will
increase at an annual rate of approximately 2 percent.   Current production
is estimated to be at about 70 percent of capacity.
                                  A5.6-1

    -------
           Table A5.6.1.  Model plant size distribution for the
                nonfertilizer phosphorus chemicals industry
                                                   Plant capacity,
                                                1000 metric tons/year
Product
Number
of
plants
Product,
average
P^Oj- Equivalent
Average Total
Elemental  phosphorus
 (phosphate reduction)
Defluorinated phosphate
  rock
Calcium phosphate
3
3
3
3
1
4
3
1
 14
 39
101
  61
 281
  45
 120
 395
 31
 89
231
  28
 128
  26
  69
 227
   9:
  26;
  69.'
TTos;

   8-
  121
                                                                       20;
                                                                       22:
                                 A5.6-2

    -------
Pollutants and Sources

          Atmospheric emissions from the manufacture of defluorinated
phosphates are primarily fluorides and particulates.  Gaseous fluorides are
released during the thermal and/or chemical reduction of phosphate rock
with the major point of emissions in feed preparation.  Emission factors
may be as high as 33 kilograms of fluorine per metric ton (66 pounds per
short ton) of phosphorus processed.

Control Technology

          Fluorides can be controlled by wet scrubbers.  These devices,
which could include liquid ejector venturi scrubbers, liquid impingement
control systems, and spray towers, also serve to control particulate
emissions to levels of 95 percent or more.

Costing Methodology

          An engineering and cost study by Resources Research Inc. and the
TRW Systems Group for EPA in 1972 gave capital and operating costs (1971
dollars) for controlling fluoride emissions with scrubbing systems.   These
cost estimates were used as the basis for estimating costs for the various
model plant sizes found in this study.  Estimates of the costs in 1981
dollars of controlling fluoride emissions are given in Table A5.6.2.
                                  A5.6-3

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    -------
             Chapter AS.7  Mercury-Cell Chlor-Alkali Industry

          Revision of this chapter was limited to updating the pollution
control costs to 1981 dollars and rewriting the discussion of the
applicable NESHAPS.

Regulations

          The NESHAPS for mercury (40 CFR 61.50), promulgated on April 6,
1973, is the only federal regulation governing mercury-cell chlor-alkali
plants.  (A NSPS was considered in 1977, but development of that regulation
was not pursued.)  The NESHAPS covers mercury emissions from hydrogen and
end-box ventilation gas streams and the cell room ventilation system.

Industry Characteristics

          Twenty-seven plants manufacture chlorine in electrolytic mercury
cells ranging in capacity from 99 to 626 metric tons per day.  The size
distribution is as follows:
                          Chlorine Capacity—1979
                                                           Percent of
        Number of               Metric Tons/Day               total
         plants             Range           Average         capacity

            8               <150              120             13.3
           10             150 - 250           231             31.9
            4             251 - 400           362             20.0
            5               >400              503             34.8
These plants produce chlorine, caustic soda, and hydrogen.  Nearly all of
these plants are operated by the chemical industry (SIC 2812), except one
plant that is operated by the primary aluminum industry (SIC 3334),
representing 5.8 percent of industry capacity, and one that is operated by
the pulp and paper mill industry (SIC 2611), representing an additional 3.2
percent of capacity.

Mercury-cell caustic soda has a higher purity than diaphragm-cell
caustic soda, which is advantageous in selected applications.   However,
emerging technology will make the economical production of such high-purity
caustic soda possible using diaphragm cell concepts.   Thus, the future need
for increased mercury-cell-derived caustic soda will  likely be negligible;
it is believed that some of the older mercury-cell plants will be shut
down.  However, improved mercury-cell technology has  recently made possible
the production of increased chlor-alkali  products by  redesign of existing
cells, which has resulted in modest incremental increases in nameplate


                                  A5.7-1

    -------
capacities of older plants.   Although the overall  chlorine-caustic soda
industry is expected to grow at a rate of about 4 percent per year over t
next decade, it is anticipated that all of this growth will use
diaphragm-cell  technology.   In the meantime, it is anticipated that about
20 percent of the existing  mercury-cell plants will  close because of age
for an effective "growth" rate of -2.2 percent per year.

Pollutants and Sources

Mercury is the pollutant of concern which arises from three
principal sources:

            •    Mercury vapor and mist in by-product hydrogen
            •    End-box ventilation system
            •    Mercury-cell room general ventilation air.

Control Technology

Control technology for treatment of by-product hydrogen includes
cooling, condensation, and  demisting; depleted brine scrubbing;
hypochlorite scrubbing; absorption on molecular sieves; and adsorption on
treated activated carbon.  End-box ventilation-system treatment
technologies include the same methods as mentioned for by-product hydroge
except for adsorption on activated carbon.  Strict adherence to good
housekeeping and operating  practice is the only suggested control
technology for dealing with the mercury-cell room ventilation air.  All o
these techniques will be applied on a subprocess basis.

Costing Methodology

Costs were developed from data in a 1977 EPA draft document
associated with the contemplated development of an NSPS.  The control
techniques and costs in this document are appropriate for compliance with
the NESHAP.  Generalized cost functions were developed and applied to a
model of industry as shown  in the following listing:
Number
   8
  10
   4
   5
 Size, metric tons/day
  RangeAverage
  <150
150 - 250
251 - 400
  >400
120
231
362
503
Percent of
  total
 capacity

   13.3
   31.9
   20.0
   34.8
                        Costs, end 1976 doll
Capital

315,200
466,900
611,400
744,800
Operati

  77,30
 130,50
 187,00
 243,20
The control technology behind these costs includes molecular sieve, mist
elimination, and hydrogen cooling.  The compliance schedule has been
assumed to be 50 percent in 1975 and 50 percent in 1976.

Table A5.7.1 shows investment and'annual  costs for air-pollution
controls for the mercury-cell segment of the chlor-alkali industry betwee
1970 and 1988.
                                  A5.7-2

    -------
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    -------

    -------
                      Chapter AS.8  Ammonia and Urea

          Pollution control costs for ammonia and urea are considered
together because both products are classified in SIC 2873, Nitrogenous
Fertilizers, and virtually all establishments that manufacture urea also
manufacture ammonia.  Revision of this chapter was limited to adjusting the
pollution control costs to 1981 dollars.

Regulations

          Both ammonia and urea are included in a list of industrial
categories for which new source performance standards (NSPS) are to be
developed by EPA.  Until such standards are promulgated, air-pollutant
emissions can be controlled only by state regulations.

          About two-thirds of the states in which ammonia is produced have
regulations patterned after Appendix B (40 CFR, Part 51) or Los Angeles
Rule 66.  If hydrocarbon emissions are reduced by 85 percent, the sources
are in compliance, regardless of the residual emission level.  There is
some question about the general applicability of these regulations to the
manufacture of ammonia because methane, the only significant hydrocarbon
emitted from the process, is excluded from some state regulations.

          Only one state, New Mexico, has a regulation on ammonia emissions
that is applicable to the synthesis of ammonia from natural  gas or other
hydrocarbon feed stocks.  Less than 2 percent of the U.S. capacity for
producing ammonia is located in New Mexico, and this regulation is not
considered in this report.

          Most of the states in which urea is manufactured have specific
limitations on particulate emissions that are applicable to urea
production.  The regulations vary from state to state, but the most common
limitation for a process weight rate of 40 tons per hour is for limitation
of particulate emissions to 42.5 pounds per hour.  Texas' regulations are
the most liberal and California's South Coast regulations the most
rigorous.  For this report, it is assumed that all urea plants are subject
to state regulations for particulate control.

Industry Characteristics

          Ammonia is manufactured by the catalyzed reaction between
hydrogen and nitrogen.  The hydrogen is generally produced by the steam
reforming of natural gas, which also produces carbon dioxide as a
by-product.  Urea is manufactured by the reaction of ammonia and carbon
dioxide to form ammonium carbonate, and subsequent dehydration of this
product to yield urea and water.  Most urea plants are located in
establishments that produce ammonia and carbon dioxide, but not all
establishments that produce ammonia also produce urea.
                                  A5.8-1

    -------
          There were 97 ammonia plants in the United States in 1977.  OnV
 the 67 plants that are located in states that are expected to have
 hydrocarbon-control regulations applicable to ammonia production by  1982
 were used to derive model plant data.  There were 48 urea plants in  1977,
 all of which were used in the determination of model plant sizes.  Size
 ranges and average sizes of ammonia and urea plants are  shown in Table
 A5.8.1.

          The U.S. production of ammonia increased from  12.5 million metr
 tons in 1970 to 15.5 million metric tons in 1978.  Continuation of the
 average rate cf growth of production between 1972 and 1978 (2.45 percent
 per year, compounded) should give a production of about  20 million metric
 tons in 1988.

          The U.S. production of urea increased from nearly 3 million
 metric tons in 1970 to nearly 5 million metric tons in 1978.  The rate of
 growth between 1970 and 1978 (6.54 percent per year) continued to 1988
 should lead to production of about 8.6 million metric tons that year.

          It is estimated that about 90 percent of the production capacit;
 for ammonia and 95 percent of that for urea is in establishments classifi'
 under SIC 2873.  The remainder of the capacity for both  chemicals is in
 various other SIC categories.

 Pollutants and Sources

          In the production of ammonia, a portion of the recycled synthes
 gas is purged from the system to prevent the build-up of gases that  are
 inert in the ammonia synthesis.  The purge gas stream contains hydrogen,
 nitrogen, and ammonia, as well as the synthesis-inert argon and methane.
 Typical uncontrolled hydrocarbon (methane) emissions in  the purge gas
 stream amount to about 45 kg/metric ton of ammonia.

          In the production of urea, after urea has been formed in aqueou:
 solution, unreacted ammonia and carbon dioxide gases are separated from t
 solution.  All ammonia, and possibly carbon dioxide, is  either recycled t
 the process or used in the production of liquid fertilizers.

          About 40 percent of the urea produced is sold  as a 70 percent
 urea solution, and is not a source of particulate emissions.  The remaini
 60 percent is concentrated in a crystal!izer or an evaporator, then
 solidified.  The solid .urea is formed by either prilling or granulation.
'Particulate emissions may arise from the evaporator, prilling tower,
 granulator, product finishing, bagging and loading, and  from bulk loading
 points.  The prilling tower and granulator are alternative, not sequentia
 steps in the process.  Average particulate emissions are estimated to be
 3.5 kg/metric ton in prilling plants and 2.25 kg/metric  ton in granulatio
 plants.

 Control Technology

          Hydrocarbons and carbon monoxide in the purge  gas from ammonia
 synthesis can be controlled by thermal incineration, without the use of

                                  A5.8-2

    -------
Table A5.8.1.  Model plants for ammonia and urea production
                Number                    Capacity,
                  of          	1000 Metric tons/year
                plants             Range            Average
 Ammonia
   Small          28          less than 100            53
   Medium         17              100-250             150
   Large          22          more than 250           383

 Urea
   Small          28          less than 100            49
   Medium         13              100-200             152
   Large           7          more than 200           306
                        A5.8-3

    -------
significant fuel  other than for a pilot light.  Some ammonia producers
already use the purge gas to supplement their fuel  supplies.

          Urea particulates for prilling and granulation plants can be
controlled by the use of wet scrubbers.

Costing Methodology

          Equipment costs for thermal incinerators without heat exchanger
for specified gas flows and temperature differentials were obtained from
vendors.  Capital costs (installed costs) were obtained by multiplying
equipment costs by 1.7.  Operating and maintenance (O&M) costs were
estimated by standard methods.  The costs based on gas flow through the
incinerator were related to ammonia production.  Straight-line log-log
relationships were calculated for capital and annual O&M costs for small
plants and for medium and large plants.

          It was necessary to make several assumptions before control cos
could be estimated for urea plants.  It was assumed that each plant sells
only one type of urea product and 40 percent of the model plants sell ure
solutions and 30 percent each sell prilled or granulated urea.

          It was assumed that 400 pounds of air should be required to
collect and transport one pound of urea particulate to a wet scrubber.
This air is equivalent to about 41,500 acf (at 70 F)/metric ton of prille
urea and 26,680 acf/metric ton of granulated urea.

          Capital and annual O&M costs for medium-efficiency wet scrubber
used with spray dryers in the soap and detergents industry were adapted f
use with the urea industry.  The value of recovered urea was subtracted
from annual O&M costs.

          Capital and annual O&M costs for air-pollution control of model
ammonia and urea plants are shown in Table A5.8.2.

          It is estimated that about 31 percent of existing ammonia
capacity in small plants and 28 percent in medium and large plants will n
come under state regulations for existing plants.  Investment schedules f
the remaining ammonia plants were prorated between 1975 and 1982.

          About 50 percent of prilling urea plants and 80 percent of
granulation plants were assumed to be using scrubbers for particulate
control in 1977.  The remaining plants were prorated to come into
compliance by 1982.

          Table A5.8.3 shows investment and annual costs for air-pollutio
controls for ammonia and urea production between 1970 and 1988.
                                  A5.8-4

    -------
               Table A5.8.2.  Control costs for model plants

Ammonia
Small
Medium
Large
Number
of
plants
28
17
22
Average
capacity
1,000 metric
tons/year
53
150
383
Costs
SI
Capital
292
362
463
per plant,
,000(a)
Annual
operating and
maintenance(b)
29.8
33.6
39.4
Urea Prilling
  Small              8
  Medium            4
  Large             2
 49
152
306
33.17
60.61
87.98
 -6.02
•18.85
-38.23
Granulation
Small
Medium
Large

9
4
2

49
152
306

26.22
47.91
69.53

-3.86
-12.08
-24.48
(a)   1977 dollars for ammonia, 1973 dollars for urea.

(b)   For urea plants, includes value of recovered urea.
                                A5.8-5

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    -------
                 Chapter A5.9  Ammonium Nitrate Fertilizer

          Ammonium nitrate is manufactured by reacting ammonia with nitric
acid.  About 85 percent of U.S. ammonium nitrate production is used as
fertilizer, in either solid or liquid form.  Essentially all of the
remainder is used in explosives.  Revision of this chapter was limited to
adjusting the pollution control costs to 1981 dollars and editing the
discussion of regulations.

Regulations

          SIPs regulate particulate emissions from ammonium nitrate
production.  Most states rely on general process weight or stack gas
concentration regulations.  Appendix B (40 CFR 51, App. B) provides a
process weight rate table of particulate limitations achievable with RACT.
Pennsylvania is the only state with a regulation specifically limiting
particulate emissions from ammonium nitrate production.  No NSPS has yet
been proposed for this industry.

Industry Characteristics

          Ammonium nitrate is produced in solution, prilled, granulated,
and crystalline forms.  Of the 62 ammonium nitrate plants in the United
States, 32 plants produce prills, six produce granules, and one produces
crystals.  One of these plants produces both prills and granules.   Most
also produce solutions, as well as 24 plants that produce only solutions.

          Ammonium nitrate that is used as a fertilizer is classified in
SIC 2873, whereas that used as an explosive is classified in SIC 2892.
Most of the establishments that produce ammonium nitrate also produce other
nitrogenous fertilizer materials.  It is doubtful  if more than 5 percent of
ammonium nitrate production capacity is in establishments classified in SIC
2892.

          Only the production of solid ammonium nitrate is important from
the point of view of air-pollution control.  The production of solid
products decreased an average of nearly 3 percent per year between 1973 and
1978.  This decline represented a reduction in the use of solid ammonium
nitrate fertilizers, partially balanced by an increase in the use  of
ammonium nitrate explosives.   Meanwhile, the use of ammonium nitrate
solutions in fertilizer applications increased at about 3 percent  per year
during the same period.

Pollutants and Sources

          Particulates from the drying and cooling of prilled and
granulated products are the only emissions of significance in the
manufacture of ammonium nitrate.   It is standard industry practice in the
prilling sector to collect such emissions and return them to the process.


                                  A5.9-1

    -------
Consequently, emission control costs are applicable only to the granulatic
sector, consisting of six plants.

Control Technology

          Two-stage wet cyclconic scrubbers recommended for recovery of
diammonium phosphate (DAP) particulates from process dryer vents should be
equally satisfactory for the recovery of ammonium nitrate (AN) particulate
from dryer and cooler vents.

Costing Methodology

          It was assumed that the drying and cooling of DAP and AN would
require about the same air flow per unit quantity of product.  Therefore,
cost functions determined for the control of DAP particulate with two-stac
wet cyclonic scrubbers were applied to similar control of AN particulates.
These cost functions were applied to two groups of AN model plants, as
follows:

              Number               Capacity, 1000 metric tons/year
             of plants               RangeAverage

                 3                   23-86                 49
                 3                  157-167               161

It is assumed that none of the six plants producing granulated
ammonium nitrate was in compliance with state implementation plans in 197(
but all will be in compliance by 1982.  The estimates of the cost"of
compliance are shown in Table A5.9.1.
                                  A5.9-2

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                      Chapter A6.   Metals Industries
          For the purpose of this report, the Metals Industries have been
defined as those establishments primarily engaged in refining, extracting,
processing, fabricating, or recovering ferrous or nonferrous metals and
processes performed by establishments in direct support of these
operations.  The industries included are:

             Iron and Steel
             Iron Foundries
             Steel  Foundries
             Ferroalloy
             Primary Aluminum Smelting
             Primary Copper Smelting
             Primary Lead
             Primary Zinc Smelting
             Secondary Aluminum
             Brass  and Bronze
             Secondary Lead Smelting
             Secondary Zinc

          Costs associated with the control  of air pollution by these
industries are summarized in Table A6.  These numbers are repeated below in
the appropriate section together with discussion of the assumptions
specific to the sector and other details.
                                   A6-1

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                       Chapter A6.1  Iron and Steel

          This chapter covers the air pollution control  costs incurred by
the iron and steel  industry.  The costs and text have been completely
revised for this edition of the Cost of Clean Air Report.

Industry Characteristics

          The iron  and steel industry incorporates four major processes:
iron ore mining, iron production, steel production,  and steel finishing.
Some iron and steel  companies are fully integrated—with operations in all
four process areas.   Other enterprises manufacture iron (merchant blast
furnaces), steel from purchased iron or scrap (e.g., minimi 11s), or
finished iron or steel, or are involved in a combination of  these
processes.

          This chapter provides air pollution control costs  both for
integrated iron and  steel  plants and for enterprises operating at fewer
than four stages of  production, including minimills.  Excluded are the
mining stage, which  has a  relatively insignificant level of  emissions, and
iron and steel foundries,  which are covered in Chapters A6.2 and A6.3.

          The iron  and steel manufacturing industry  covered  in this chapter
is classified -into  SIC 3312 which includes blast furnaces  (including coke
ovens), steel works, and rolling mills.  In 1977, there were a total of 504
establishments classified  in SIC 3312, of which 35 were fully integrated,
99 were partially integrated, and 370 were engaged in only one level of
production.  The value of  shipments was $42 billion  in 1977  and $50 billion
in 1980.  Almost three-fourths of raw steel production and the associated
value of industry shipments is produced in the five  states of Pennsylvania,
Ohio, Indiana, Illinois, and Michigan.

          The production of raw steel fell from 137  million  short tons in
1978 to 73 million  short tons in 1982.  The decrease is a  result of import
competition and the  diminished demand for final  goods that use steel,
especially automobiles, construction, and machinery  and equipment.  In 1982
the steel industry was operating at about 50 percent of capacity, and many
plants were closed.   According to industry trade journals, there will  be
only a modest increase in  production through 1984.  It was assumed for this
report that no new  facilities will  be constructed in the 1985 through 1990
period.

Emission Sources and Pollutants

          The major  sources of air pollution in the  production of iron and
steel are ore and coal yards, sintering plants,  coke ovens,  blast furnaces,
steel making furnaces—open hearth, basic oxygen, and electric arc—and
casting operations.   Coal, iron ore, and limestone are the basic materials
of iron and steel production.  Coke ovens transform  coal to  coke, and

                                  A6.1-1

    -------
sintering plants prepare a mixture of coke, iron, and limestone.  A blast
furnace then charges the mixture to produce molten pig iron.  The hot
molten iron, steel scrap, and flux materials are combined to form steel ir
either an open hearth (OH) furnace, a basic oxygen furnace (BOF), or an
electric arc furnace (EAF).  The raw steel product of these furnaces is
then cast into basic steel forms such as billets, blooms, and slabs.

          Ore and Coal  Yards.  The primary pollutant from ore and coal
yards, where the iron ore and coal are transferred, prepared (crushed), ar
stored, is particulate matter in the form of dust.  The emissions are a
function of the material characteristics, the weather, and the method of
handling and storing.

          Sintering Plants.  Sintering plants prepare a mixture known as
sinter by crushing and combusting coke, breeze, fine iron ore, mill scale.
flue dust, iron, and limestone.  Particulates are emitted from the windbo>
and the discharge end of the sintering machine.  Windboxes are compartmen'
that collect particles from the downdraft of air, which passes through the
mixture of materials to maintain combustion.  At the discharge end of the
machine, the sintered material is removed and conveyed to the blast
furnace.  Fugitive particulate emissions in the sintering building are
created in the handling and grinding of the raw materials.

          Coke Ovens.  Coke oven batteries, which comprise a large set of
ovens, generally produce coke for either blast furnaces or foundries.  Bo-
types of coke producers are included in this chapter.

          Coke oven emissions arise from several processes or sources
within the coke oven battery.  Particulate matter is primarily emitted fn
(1) the charging operation, when the coal is charged into the coke ovens;
(2) door and topside leaks, as the coal is transformed to coke;  (3) the
pushing process, when the hot coke is pushed from the oven to a quench ca
(4) the quenching operation, when a direct spray of water cools the hot
coke in a quench tower; and (5) the final skeleton and screening operatio
where the cooled coke is broken down for further processing.  The
combustion stacks, door leaks, and topside leaks are other sources of
particulate emissions.  Sulfur dioxide and other volatile constituents su<
as benzene soluble organics, benzo-a-pyrene, and benzene are contained in
the coke oven gases formed during the charging process.  All coke ovens
currently operating in the U.S. are by-product coke ovens, meaning that
they have the capability of directing part of the gas stream to a
by-product recovery plant.  Benzene is the primary regulated pollutant of
the by-product recovery plant.

          Blast Furnaces.  Emissions from the blast furnace occur during
the transfer of materials into and out of the furnace.  Particulate matte
is generated when the raw materials are transported to the furnace.  Gase:
and particulates in the form of iron oxides and flake graphite are emitte<
when the molten pig iron  (slag) is removed or tapped from the furnace and
processed.
                                  A6.1-2

    -------
          Open Hearth Furnaces.  The open hearth furnace  is the oldest and
least efficient of the three types of steel-making furnaces currently in
operation.  It requires additional fuel for refining the  metals and a
process time of from eight to twelve hours.  In the past  two decades it has
been replaced with the other two furnace types.  It produces an
increasingly smaller proportion of raw steel than either  other furnace
type.

          The primary pollutant from open hearth furnaces is particulate
matter in the form of iron oxides.  Particulate matter is emitted during
the refining process, hot metal transfer, and slag processing.  Fugitive
particulate emissions also escape in the building.  The flue gas from the
refining process contains varying amounts of sulfur dioxide, nitrogen
oxides, and fluorides, depending on the type of fuel used to charge the
scrap, fluxes, and molten pig iron.

          Basic Oxygen Furnaces.  The basic oxygen process is a relatively
new type of steel making process (first operated in the United States in
1955) that refines the mixture of steel scrap, hot metal, and flux without
external heat and in a total process time of thirty minutes.  A supply of
pure oxygen reacts with the hot molten iron to refine the mixture.
External iron desulfurization units are operated in conjunction with BOFs
when the hot iron from the blast furnace has a higher sulfur content than
can be processed in the BOF.

          The BOF is less flexible than the other two types of furnaces
because of its limitation on the percent of scrap that can be charged with
the molten iron.  Nevertheless, because of its greater efficiency relative
to OH furnaces and greater capacity relative to EAFs, BOF furnaces produce
a higher percentage of raw steel than the other two furnace types.

          Particulate matter and carbon monoxide are the major BOF
pollutants.  Particulates are emitted from the refining process, hot metal
transfer, charging and tapping, slag pouring, and slag processing.  The BOF
waste gases contain large amounts of carbon monoxide.

          Electric Arc Furnace.  In the electric arc furnace,  a
metallurgical reaction refines steel scrap and flux materials  with heat
generated from electrical currents.  Because of its shorter processing time
(about four hours) relative to the open hearth furnace, its proportion of
raw steel production exceeds that of OH furnaces.   Because EAFs do not
depend on the molten pig iron from the blast furnace,  they may be located
near a supply source of scrap, where an integrated iron and steel  plant
would not be economical.   Such installations are known as minimi 11s.   As
with the other two types of furnaces, particulate matter is the primary
pollutant during refining, slag pouring,  and slag processing.   Carbon
monoxide is also generated during the refining cycle.

          Casting.  There are two types of casting processes:  ingot casting
and continuous casting.  Ingot casting involves pouring raw steel  from a
steel furnace into ingot molds.  After the ingots are  cooled and stripped
from their molds, they are reheated in soaking pits and rolled into blooms,

                                  A6.1-3

    -------
billets, or slabs in a primary mill.  This process leaves defects on the
surface, which are removed by the scarfing process.  The hot scarfing
machine burns the surface of the steel with a jet of oxygen combined with
fuel gas.

          Continuous casting is the forming of blooms, billets, or slabs
directly from the hot raw steel produced by a steel-making furnace.  It i
a more efficient system than ingot casting, because the rolling steps are
eliminated and the scarfing steps are greatly reduced.  Continuous castin
has become the predominant casting process since its introduction into th
United States in the 1960's.

          Particulate matter is the primary pollutant from both casting
processes.  In this report, ingot pouring and reheating are included in t
hot metal transfer operation that is part of the steel-making process, an
scarfing is considered a separate primary emissions source in the casting
process.

Regulations

          The primary air pollution regulations covering the integrated
iron and steel industry are SIPs and two NSPS.  One NSPS regulates basic
oxygen process furnaces and the other, electric arc furnaces.

          The NSPS for BOFs was promulgated March 8, 1974 (40 CFR 60.140)
It provides standards for primary particulate emissions and opacity.  In
response to the most recent review of these standards, EPA has proposed a
revision to this NSPS and an additional NSPS to regulate secondary
particulate emissions (48 FR 2657, January 20, 1983).

          The NSPS for EAFs was promulgated September 23, 1973 (40 CFR
60.270).  It sets particulate matter and opacity limits on emissions from
control devices on EAFs and opacity limits on emissions from EAF shops an
dust-handling equipment.

          The general process weight rate limits for particulate matter
suggested as achievable with RACT in Appendix B (40 CFR 51) apply to iron
and steel sources.  Similar limits for general process industries found i
most SIPs cover the iron and steel industry.  Of the five states where th
bulk of the industry is located, Illinois, Michigan, and Pennsylvania
establish limits for specific process categories in iron and steel
manufacturing.

          Appendix B and most states do not set sulfur dioxide limits for
process emissions in this industry.  Indiana, Ohio, Pennsylvania, West
Virginia, New York, and Kentucky set limits on sulfur dioxide (in the for
of hydrogen sulfide) from by-product coke ovens.  Although Appendix B
suggests complete secondary combustion of waste gases as a means of
controlling carbon monoxide from blast furnaces and basic oxygen steel
furnaces, most states did not adopt this as a requirement.
                                  A6.1-4

    -------
          The SIPs of most states with iron and steel plants have been
recently revised.  Promulgation of the revised SIPs has been delayed beyond
the originally scheduled 1979 date.  This delay has served to extend the
compliance dates for iron and steel sources.

          In response to requests by the iron and steel industry for
compliance extensions, Congress amended Section 113 of the Clean Air Act by
enacting the Steel Industry Compliance Extension Act (SICEA) in July 1981.
This act, known as the steel stretch-out act, provides for negotiations
between steel companies and EPA to determine extensions of installation
deadlines.  Such extensions apply to certain capital intensive air
pollution control equipment for a maximum of three years on a case-by-case
basis.  SICEA allows extensions only if the funds that would have been
required to meet an existing compliance schedule are invested in other
capital improvements.

          EPA's "bubble policy" has been applied to the iron and steel
industry.  This policy allows tradeoffs in emissions among stack and
fugitive emission sources within a plant site and effectively bases
compliance on the entire plant rather than on individual sources.  Bubble
approvals have been incorporated into renegotiated consent decrees with
individual plants.

          Two NESHAPs are under development for this industry.  One would
regulate benzene emissions from coke oven by-product recovery plants and
the other, coke oven emissions from by-product coke oven charging, door
leaks, and topside leaks.,

Control Technologies

          Table A6.1.1 presents a summary of the control technologies by
emissions source that are assumed as the basis for cost estimates in this
report.  It also reports the percentage of the controlled sources estimated
to employ each technology in 1981.  If uncontrolled (as of 1981) sources
are expected to use a significantly different mix of control technologies,
the percentage of such sources expected to employ the respective technology
in the period from 1981 through 1990 is also provided in parentheses.

          Electrostatic precipitators (ESPs), scrubbers, and fabric filters
(baghouses) are installed in various combinations on most of the
particulate emitting sources.  These include sintering plants, coke oven
pushing operations, coke oven combustion stacks, coke handling, blast
furnaces, all three types of steel furnaces (OH, BOF, and EAF), external
iron desulfurizati-on facilities, and scarfing plants.  Canopy hoods,
enclosures, and evacuation systems are accessory controls to capture
fugitive emissions from many of the facilities.  Evacuation systems in
particular are installed on a large percentage of blast furnaces and
electric arc furnaces.

          Simple water sprays and dust suppression are sufficient to
control the particulate dust in the ore and coal yards.  The control


                                  A6.1-5

    -------
Table A6.1.1.  The distribution of control
          technologies by process
Process
ORE YARDS
COAL YARDS
SINTERING
1) Windbox




2) Discharge
and Fugitive
Building
COKE OVENS
1) Charging


2) Pushing





3) Quenching

,
4) Combustion
Stacks

5) Coke Oven
Gas
6) Coke Oven
Doors
Applicable
control technology
Water sprays and dust suppression
Water sprays and dust suppression

a) Wet ESP
b) Venturi scrubber
c) Combination, ESP with baghouse or scrubber
d) Baghouse
e) Other (cyclones, gravel bed filter)
a) Canopy hood with baghouse
b) Rotoclones and mul tic! ones
c) Scrubbers

a) Stage charging, modified larry car
b) Stage charging, new larry car
c) Pipeline charging with ESP or scrubber
a) Enclosed hot car with scrubber
b) Bench mounted hood with scrubber or
baghouse
c) Traveling hood with scrubber or baghouse
d) Coke-side shed with ESP, scrubber or
baghouse
a) Diverted flow tower, baffles, clean water
b) Conventional tower, baffles, clean water
c) Conventional tower, baffles, dirty water
a) Dry ESP
b) Baghouse
c) Oyen patching
a) Desulfurization

a) Door cleaning and maintenance
b) New doors with cleaning and maintenance
Percent c
source;
using
control*
100
100

40
35
11
7
7
50
25
25

46
47
7
60

20
10

10
7
42
51
60
40
0
100

65
35















(0)

(0)
(50)

(50)



(20)
(0)
(80)




                                                Continued,
                A6.1-6

    -------
                        Table A6.1.1.  (Continued)
    Process
                  Applicable
              control technology
 Percent of
   sources
    using
  control*
7) Coke
   Hand!ing
   (Screening)

BLAST FURNACES

1) Casthouse
OPEN HEARTH
FURNACES

1) Refining
2) Hot Metal
   Transfer

EXTERNAL IRON
DESULFURIZATION

BASIC OXYGEN
FURNACES

1) Refining
2) Hot Metal
   Transfer

3) Charge
   and Tap
a) Canopy hood with baghouse
100
a) Taphole hood evacuation with baghouse 1
b) Total evacuation with baghouse        J
c) Nonevacuation techniques
a) Dry ESP
b) Scrubbers
c) Combination, ESPs and scrubbers

a) Canopy hood with baghouse
a) Baghouse
a) Open hood with dry ESP
b) Closed hood with scrubber
c) Open hood with scrubber

a) Canopy hood with baghouse
a) Gaw damper
b) Furnace enclosure with baghouse
c) Canopy hoods, tapping enclosures, etc.
 60    (0)

 40  (100)
 40
 30
 30

100
100
 45
 25
 30

100
 15    (0)
  5  (100)
 80    (0)

Continued.,
                                 A6.1-7

    -------
                        Table A6.1.1.   (Continued)
    Process
                  Applicable
              control  technology
Percent
  source
   using
 control
ELECTRIC ARC
FURNACES
1) Refinery
   (including
   fugitives)
PRIMARY
BREAKDOWN
(SCARFING)
1) Billets

2) Blooms and
   slabs
a) Direct evacuation, canopy hood with
   baghouse
b) Direct evacuation with baghouse,
   scrubber or ESP
c) Canopy hood, building evacuation with
   baghouse
d) Other variations
a) Wet ESP

a) Wet ESP
b) Scrubbers
c) Baghouse or rotoclones
d) Water spray tunnel
    30

    15

    25
    30
   100

    45
    30
     5
    20
SOURCE:   GCA Corporation, Reconciliation of Estimates of Investments by
          Iron and Steel  Industry in the Pollution Control Equipment, TEP
          Contract No.  68-01-6316), March 1983, Tables 4-7, pp. 43-44.

*The percent of sources with controls installed as of 1981.  This
historical distribution is assumed for the forecast period unless a
parenthetical number appears.  In these exceptions, the number in
parentheses represents  the percent of sources uncontrolled as of 1981 tha
are expected to employ  the respective technology in the future.  The
estimated compliance schedule is described in the test.
                                 A6.1-8

    -------
assumed in coke oven charging is use of the more efficient stage charging
technique and a more efficient new or modified Tarry car to prevent
fugitive emissions when the coal is charged into the ovens.  The baffles
installed as controls on the quenching towers of coke ovens are capture
devices that prevent emissions from escaping.  The desulfurization unit
installed to control the hydrogen sulfide in the coke oven waste gases is
assumed to include a vacuum carbonate plant and a Claus plant for sulfur
recovery.

Cost Methodology

          Total costs of control are presented by year in Table A6.1.2.
The costs for the control technologies outlined in Table A6.1.1 were taken
from a study performed for EPA by GCA Corporation (Reconciliation of
Estimates of Investments by Iron and Steel Industry in Air Pollution
Control Equipment Final Memorandum, March 1983, EPA Contract No.
68-01-6316).The costs are based primarily on cost curves developed by
PEDCo Environmental, Inc.  Historical costs (1970 through 1981) were
derived by applying these cost curves to GCA's data base of iron and steel
facilities and installed control devices.  Forecast costs (1982 through
1990) were derived by applying these cost curves to controls expected to be
installed in the future as estimated by EPA Regional Office engineers,
taking into account slow industry recovery, the steel stretchout act, and
existing bubble approvals.

          Compliance assumptions for each source type differ for stack and
fugitive emission controls.  Compliance with stack emission regulations in
1981 was estimated to be 30 percent for sintering plants, 50 percent for
coke ovens, 60 percent for OH furnaces, 75 percent for BOFs, 95 percent for
EAFs, and 60 percent for scarfing operations.  Full compliance with stack
emission regulations is assumed to be achieved by 1985 for all operations.

          For fugitive emission controls, compliance levels in 1981 were
estimated to be 25 percent for ore and coal yards, 40 percent for sintering
plants, 20 percent for coke ovens, 5 percent for blast furnaces, 20 percent
for OH furnaces, 35 percent for BOFs, 90 percent for EAFs, 100 percent for
continuous casting operations, and 85 percent for scarfing operations.
Compliance with fugitive emission regulations is assumed to be complete by
1985 for all operations.
                                  A6.1-9

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    -------
                       Chapter A6.2  Iron Foundries

          This chapter describes the iron foundry industry and presents
estimates of the costs of particulate and carbon monoxide emission control
for gray iron cupolas and particulate emission control for electric arc
furnaces in iron foundries.  This revision of the iron foundries chapter
incorporates updated industry information, revised furnace population data,
cost estimates for carbon monoxide control, and new cost estimates for
electric arc furnace controls.

Industry Characteristics

          Iron foundries are part of the foundry industry, which produces
castings: metal  molds, pipes, and a wide variety of specialized forms and
parts.  The foundry industry is subdivided into ferrous (iron and steel)
and nonferrous (copper, aluminum, zinc, and other) metal foundries.

          Iron foundries may be categorized by their production of gray
iron, ductile iron, or malleable iron castings, although many ferrous
foundries cast more than one metal.  If foundries are defined by the major
metal cast in each, there were 1,343 gray and ductile iron foundries and 53
malleable iron foundries in 1980.  Gray iron was cast in a total of 1,461
foundries; ductile iron, in 643; and malleable iron, in 110.

          In 1980, 44 percent of all iron foundries were small operations,
having fewer than 50 employees.  Only 13 percent employed 250 or more.  The
number of very small foundries is declining over time.  They  are being
replaced by additional capacity in new and existing larger foundries.

          Iron foundries are located in almost every state, but more than
half are concentrated in the Great Lakes and Mid-Atlantic regions - in the
iron and steel producing areas and near the major markets for industrial
castings.  Many of the larger iron foundries are captives, producing metal
parts for the parent company's end products.  In 1976, 40 percent of iron
foundries were captive, while 60 percent were exclusively jobber (all their
tonnage was sold on the open market).  Of the captive foundries, 62 percent
sold at least some castings in the open market.

          Demand for iron castings is characterized by cyclical
fluctuations.  Total shipments of iron castings were 12.2 million tons in
1980, down from an average of 15.5 million tons per year for  the 1975-1979
period.

          Gray iron shipments totalled 9.4 million tons in 1980.   About 32
percent of that tonnage was in ingot molds and in pipe and fittings.   The
top three markets for the remaining industrial  castings are automotive,
farm machinery,  and engine manufacturers.
                                  A6.2-1

    -------
          Ductile iron shipments were 2.4 million tons in 1980.   Ductile
iron casting is the newest and fastest growing segment of the iron foundry
industry.   Many gray iron and some malleable iron foundries are  adding
ductile iron casting capabilities.  About 40 percent of ductile  iron
shipments  are pressure pipes.  Other important markets for ductile iron ar
the automotive and farm equipment industries.

          Malleable iron shipments totalled 450 thousand tons in 1980.
Malleable  iron's position in the industry is minor and declining.
Historically, the automotive industry has used 75 percent of malleable ire
tonnage, but ductile iron has proven 3 superior substitute for malleable
iron in many automotive applications.

          Demand for iron castings may increase to historic levels as the
current recession ends, assuming improvement in the domestic automobile
market.  Only slight additional growth is expected for gray iron.  Demand
for ductile iron should increase more rapidly, and demand for malleable
iron is expected to continue to decline.   There is some excess capacity ir
the industry (capacity utilization for gray iron foundries was 83 percent
in 1979 and 76 percent in 1981), and the  trend to replace smaller foundrie
with larger ones tends to result in more  efficient capacity utilization.
Thus, it was assumed that there will be no net melting capacity  increase •
the remainder of the 1980's.

          Gray and ductile iron foundries are classified in SIC  3321;
malleable iron foundries are in SIC 3322.  The reported value of shipment'
for gray and ductile iron foundries was $7.4 billion in 1977; malleable
iron shipments were valued at $722 million.  Many captive foundries are
departments of manufacturing operations and are not included in  SICs 3321
and 3322.   They are included in other SICs such as 371 (motor vehicles anc
equipment), 355 (industrial machinery), and 352 (farm and garden
machinery).

Emission Sources and Pollutants

          Iron foundries produce iron castings through the following serie
of distinct operations: raw materials storage and handling, pattern makinc
sand preparation, mold making, core making, melting, pouring, cooling,
shakeout,  and cleaning and finishing.

          The majority of emissions is produced by the melting process in
foundry furnaces.  The level of melting emissions depends on furnace
design, charging practice, quantity and quality of charged materials, and
melting zone temperature.  Also important are the quantity of coke use.d,
the volume and rate of combustion air, and the use of techniques such as
oxygen enrichment and fuel injection (cupola furnace only).

          Four types of furnaces are used in iron foundries: cupola,
electric arc, electric induction, and reverberatory.  About 70 percent of
all foundry iron is produced in the cupola furnace because of its
flexibility in handling different types of scrap and its low energy
consumption.  Cupola emissions include carbon monoxide, particulates, and
                                  A6.2-2

    -------
oil vapors.  Participate emissions amount to approximately 17 pounds per
ton of iron melted per hour.  They arise from dirt on the metal charge and
from fines in the coke and limestone charge.  Carbon monoxide and
hydrocarbon emissions arise primarily from partial combustion and/or
distillation of oil from greasy scrap charged to the furnace.

          In electric arc furnaces, electrodes are placed into the charge
of the vessel and an electric arc between the electrodes and the charge
generates the heat required to melt the metal.  The high temperature arcs
produce dense fumes consisting of iron and other metal oxides plus organic
particulates from oil and other contaminants in the scrap.  These furnaces
produce approximately 14 pounds of particulates per ton of iron charged.

          Electric induction furnaces are used for melting iron where high
quality, clean, dry, grease-free metal is available for charging (reducing
explosion potential).  Because of the high quality of the material charged
to induction furnaces, particulate emissions are only from 0.1 to 1.5
pounds per ton of iron charged per hour.

          Reverberatory furnaces in large facilities are used to provide
additional refining and super heating prior to pouring.  They are used for
melting in very small facilities (capacities less than two tons).  These
furnaces produce relatively few emissions.

          Many other operations in the foundry produce particulates and
gases that create significant fugitive emission control problems.  The core
making operation produces particulate and hydrocarbon emissions.  Sand
preparation, molding, and finishing produce dust (dirt, sand, metal
pieces).  The casting shakeout process generates dust and gases (sand,
dirt, metal pieces, metal vapors).  Gaseous emissions (metal  oxide gases,
oil vapors) result from pouring melted metal into molds.

          This chapter only includes control cost estimates for cupolas and
electric arc furnaces.  Adequate cost estimates for fugitive controls in
iron foundries were not available.

Regulations

          There are no NSPS for the iron foundry industry.  State air
pollution control regulations include limitations on emissions of
particulate matter and carbon monoxide from iron foundry operations.

          Particulates.   General industrial process weight rates or
concentration limitations usually govern iron foundry particulate
emissions.  In addition, foundries must meet opacity standards, except in
areas where existing cupolas are exempt from the limitations.  Foundry
operations are also increasingly subject to fugitive emission control
standards as these requirements are adopted by more and more states.

          Several states have separate regulations that apply specifically
to iron foundry cupolas.  For existing gray iron cupolas,  these regulations
are often less stringent than the general  industrial  limitations.   Some
                                  A6.2-3

    -------
states also distinguish between gray iron jobbing cupolas and production
foundries.  (Jobbing cupolas have a single melt cycle and are operated on
job-by-job basis, usually only a few hours per day.  Production cupolas a
characterized by continuous melting and may operate eight to twenty-four
hours per day.)  Specific limitations for jobbing cupolas are less
stringent than those for production cupolas.

          Carbon Monoxide.  State regulations for cupolas located in carbc
monoxide nonattainment areas and in regions where carbon monoxide control:
are needed to maintain air quality are often patterned after the RACT
suggested in Appendix B (40 CFR 50).  Appendix B states that carbon
monoxide emissions in the waste gases of gray iron cupolas can be limited
by complete secondary combustion.

          Lead.  Several states have identified iron foundries as lead
point sources in preparing their lead SIPs.  However, very few foundries
are expected to require additional control to meet ambient lead standards
since iron foundry lead emissions are usually adequately controlled by
existing particulate collection devices.

Control Techniques

          Fabric filters and wet scrubbers are the devices most frequently
used to reduce particulate emissions from cupolas.  Afterburners are also
installed when carbon monoxide control is required.  The cupola gases are
incinerated in the afterburner.  The hot gases leaving the afterburner are
cooled, usually in either a quencher or an evaporative cooler, before goir
into the particulate collector.  The choice of the cooling device depends
somewhat on the type of collector used.  For example, quenchers would not
be used with fabric filters since the resulting moisture would damage the
bags.

          The cost estimates in this chapter are based on evaporative coo'
and fabric filters for small and medium sized cupolas and quenchers and w«
scrubbers for large cupolas.  These controls allow compliance with SIP
limitations on particulate emissions.  Medium efficiency scrubbers are
costed for existing (pre-1972) large cupolas while high efficiency
scrubbers are costed for newer large cupolas.

          Control of electric arc furnace emissions is accomplished in tw<
steps: (1) collection and evacuation of the exhaust gas and (2) removal o-
particulates from the collected gas.  Side draft hoods are commonly used  <
exhaust gas collection devices.  Fabric filters are the only particulate
removal devices commonly used on electric arc furnaces in the United
States.

          The combination of a side draft hood and fabric filter provides
sufficient control to meet the process weight regulations and visible
emission limitations found in typical state pollution control regulations
Use of these devices is assumed as the basis for the cost estimates for
electric arc furnace controls.
                                  A6.2-4

    -------
          It was assumed that 75 percent of cupolas and electric arc
furnaces were in compliance with SIP requirements by the end of 1976, 90
percent complied by the end of 1978, and 100 percent complied by the end of
1982.  This assumption was based on summary reports for gray iron foundries
from EPA's Compliance Data System for 1980 and earlier years.

Costing Methodology

          Model plant cost data from previous EPA studies were used to
develop capital and O&M cost functions for the quencher/scrubber and
evaporative cooler/fabric filter systems used with cupolas.  Similar data
sources were also used for the side draft hood/fabric filter systems used
with electric arc furnaces.  Capital and O&M cost functions were estimated
separately for cupola afterburners, since afterburner costs were not
included in the model plant cost data for cupola controls.

          Capital and O&M costs are expressed as functions of the melting
capacity (in tons per hour) of individual furnaces.  Thus, total industry
costs were based on estimates of the numbers and capacities of cupolas and
electric arc furnaces in iron foundries (not on the number of foundries).

          Note:  Costs labeled "NSPS" in Table A6.2.1 are actually SIP
compliance costs for new furnaces installed in 1972 and later.  Costs
labeled "SIP" are for furnaces existing in 1971.
                                  A6.2-5

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                       Chapter A6.3  Steel Foundries


          This chapter presents costs for participate emission controls for
electric arc furnaces in steel foundries.  The chapter revision included
expanding the discussions of industry characteristics and of emission
sources, reorganizing and rewriting the entire chapter, and removing the
NSPS costs that were included in the most recent edition of this report.

Industry Characteristics

          In 1980, 637 U.S. foundries produced steel castings.  Steel was
the principal metal cast in approximately 450.  During the 1970-1979
period, annual steel casting production averaged 1.8 million tons.   There
was cyclical variation in the annual production figures but no apparent net
growth.  The total number of foundries producing steel castings increased by
15 to 20 percent during that period.  At the same time, the total  number of
electric arc and induction furnaces (in all  foundries) increased by
approximately 30 percent.  These statistics  may explain the drop in steel
foundry capacity utilization from 90 percent in 1974 when 2.09 million tons
were produced to 82 percent in 1979 when a comparable 2.04 million tons of
castings were produced.  Capacity utilization averaged 76 percent during
the 1977-1981 period.

          Two types of steel are produced by steel foundries:   carbon steel
castings and alloy steel castings.  During the 1970's, carbon  steel
constituted approximately two-thirds of total steel foundry shipments.
Carbon and low alloy castings together made  up over 90 percent of steel
castings production.  The following industries provide the most important
markets for carbon and low alloy steel  castings:   railroads, construction,
mining, materials handling, and metal working equipment.   The  remainder of
steel castings production is high alloy.  The principal users  of these
castings are the construction industry, machinery manufacturers, and the
motor vehicles industry.

          Steel  foundries generally use electric arc and/or induction
furnaces for melting.  In 1976, approximately 80 percent of steel  foundries
had melting capacity less than 10 tons per hour.

Emission Sources and Pollutants

          Steel  foundries produce castings through the following series of
distinct operations:  raw materials storage  and handling, pattern  making,
sand preparation, mold making, core making,  melting, pouring,  cooling,
shakeout, and cleaning and finishing.

          This chapter includes control cost estimates only for electric
arc furnaces.  The furnace processes generally create the majority  of
foundry emissions although there are other foundry operations  that  produce


                                  A6.3-1

    -------
particulate and some gaseous emissions.  For example, the core making
operation produces particulate and hydrocarbon emissions.  Sand
preparation, molding, and finishing produce dust (dirt, sand, metal
pieces).  The casting shakeout process generates dust and gases (sand,
dirt, metal pieces, metal vapors).

          Electric arc and electric induction are the furnace types most
commonly used in steel foundries.  Emissions from electric induction
furnaces are usually low (approximately 0.1 pounds per ton), requiring
little control.  Particulate emission rates from uncontrolled electric an
furnaces in steel foundries average about 16 pounds per ton for melting a
refining and about 1.6 pounds per ton for charging and tapping.  Emission:
vary considerably from furnace to furnace, depending on the furnace type
and age, kinds of scrap processed, additives to the melt, and the types o-
steel products produced.  In addition, significant increases in emission
rates occur during backcharging and oxygen lancing.

Regulations

          There are no NSPS for steel foundries.  The NSPS developed for
electric arc foundries in ferrous foundries has been withdrawn.

          Steel foundry operations are regulated under SIPs.  A few state
provide particulate limits specifically for electric arc furnaces.  In mo
states, however, steel foundry particulate emissions regulation is
accomplished under general industrial process weight rates or concentrate
limitations.  In addition, foundries must meet opacity standards,.and
foundry operations are also increasingly subject to fugitive emissions
control requirements.

Control Techniques

          Control of electric arc furnace emissions is accomplished in tw
steps:  (1) collection and evacuation of the exhaust gas and (2) removal
particulates from the collected gas.  Fabric filters are the only
particulate removal devices commonly used on electric arc furnaces in the
United States.  Direct furnace evacuation is commonly used to collect
emissions from steel-making electric arc furnaces.  Side draft hoods are
also used as collection devices, especially for small steel furnaces whic
often cannot support direct evacuation.

          The combination of direct evacuation (for medium and large •
furnaces) or side draft hood (.for small furnaces) and fabric filter is
assumed as  the basis for the cost estimates for electric arc furnace
controls.   Use of these devices provides sufficient control to meet the
process weight regulations and visible emission limitations found in
typical state pollution control regulations.

Costing Methodology

          The control costs shown in Table A6.3.1 are based on model plan
cost data from the May 1980 draft NSPS document, "Electric Arc
                                  A6.3-2

    -------
Furnaces in Ferrous Foundries - Background Information for Proposed
Standards."  Capital and O&M cost functions were estimated by linear
regression of the logarithms of the cost and capacity variables for the
"baseline" control alternative in the document.   These functions were
derived separately for small steel  furnaces (using side draft hoods) and
for medium/large furnaces (using direct evacuation).

          Capital and O&M costs are expressed as functions of the melting
capacity (in tons per hour) of individual  furnaces.   Thus, total industry
costs were based on estimates of the number and  capacities of electric arc
furnaces in steel foundries (not on the number of foundries).

          Note:  Costs labeled "NSPS" in the table are actually SIP
compliance costs for new furnaces installed in 1973  and later.
                                  A6.3-3

    -------
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                     Chapter A6.4  Ferroalloy Industry

          Revision of this chapter was limited to adjusting the pollution'
control costs to 1981 dollars and editing the discussion of regulations.

Regulations

          NSPS were promulgated for ferroalloy production facilities on May
4, 1976 (40 CFR 60.260), and revised in 1976 and 1977.  These standards
cover particulates, carbon monoxide, and plume opacity from electric
submerged arc furnaces and plume opacity of dust handling equipment.

          Unlike most of the metal industries' facilities, ferroalloy
production is not identified as a major stationary source subject to
special review for BACT or BART.  Thus, ferroalloy facilities must have 250
tons per year of potential emissions before they may be required to meet
BACT requirements.

          Most SIPs include particulate standards patterned after the
process weight tables suggested as RACT standards in Appendix B (40 CFR 51,
App. B).  Pennsylvania is the only state that has a limitation specifically
for ferroalloy production furnaces.

Industry Characteristics

          Ferroalloys are made by two methods, electric furnace smelting
and metallothermic reduction.  Until a few years ago, two integrated steel
companies produced high carbon ferromanganese in blast furnaces.  These
operations are now closed.  Submerged electric arc furnaces are used for
making the majority of ferroalloys in the United States.  These furnaces
are of three types, (1) open furnaces, (2) semicovered furnaces, and (3)
sealed furnaces.

          Open furnaces are equipped with hoods.  The "open" description
concerns the vertical opening around the furnace extending from the
charging floor to the bottom of the hood.  This opening is required in the
production of certain ferroalloys because crusts tend to form on top of the
charge.  The crust must be broken with mechanical equipment for proper
furnace operation,

          Semicovered furnaces are equipped with water-cooled hoods to
collect emissions.  The charge material is fed to the furnace through
openings around the electrodes.  Charging through the hood permits a
reduction in the height of the opening around the furnace.

          Sealed furnaces are completely sealed to prevent the escape of
emissions and to minimize the influx of air.

          Ferroalloy production by the metal!othermic reduction route is
quite small and tends to produce speciality ferroalloys rather than tonnage


                                  A6.4-1

    -------
alloys.   Seven companies make ferroalloys by this procedure.  Because the:
is insufficient information on metallothermic plants as to number of
furnaces, emissions, and air-pollution control  methods, those plants have
been included with electric furnace plants in estimating control  costs.

          Industry Structure.  At the end of 1976, 32 companies were
operating 54 plants to produce ferroalloys.   Ten of these plants produced
ferrophosphorus, seven used the metal!othermic process, and the rest
operated electric furnaces.

          Over the past decade the number of furnaces with a power rating
of less  than 10 megawatts has decreased drastically, while the number of
furnaces having 20 or more megawatts  in power has increased significantly,
This illustrates the trend in the industry toward closing the small,
inefficient furnaces and replacing them with larger, more efficient units,

          During 1978, Airco, Inc., closed its ferromanganese plant at
Theodore, Alabama.  This plant has been purchased by Autlan, a Mexican
producer, and the plant will  restart.  Airco recently sold its Charleston
S.C. plant to a new firm, Macalloys Inc., and its Niagara Falls and Calve
City plants to SKW, a German  firm.  The three plants will continue to
operate.
          The largest consumption of ferroalloys, by far, is in the
production of steel and iron  alloys.   Therefore, the future production anc
consumption of ferroalloys will depend almost entirely on the production <
raw steel and cast iron.  Over the past 10 years or so, imports of
ferroalloys have increased essentially annually, especially ?or manganese
and chromium alloys.  Foreign countries have expanded their ferroalloy
capacity and production in order to export their products to the large
steel-producing nations.  Some of these new foreign ferroalloy plants are
partially owned by American companies.  This situation, along with certai
domestic problems, obviously  has deterred present ferroalloy producers fn
expanding their capacity in this country.  Therefore, imports probably wi
continue to provide an ever increasing share of ferroalloy consumption in
the United States to the detriment of the domestic industry.

Pollutants and Sources

          Particulate emissions are generated during the handling of ores
fluxes,  and reductants used in the production of ferroalloys.  Particular
and gaseous emissions are continuously evolved during the smelting
operations.  These emissions  occur at the top of the furnace, at the
taphole intermittently, and at the ladle after tapping.  Particulate
emissions are'composed of oxides of the metals being produced and used in
the process.

          The water emissions occur only when a wet scrubber is used for
pollution control.  The slurry is settled, filtered, and treated.  The
water is returned to the furnace as a coolant and the filter cake is
dumped.
                                  A6.4-2

    -------
Control  Technology and Costs

          Baghouses, electrostatic precipitators, and high-energy scrubbers
are all  used to control  emissions from submerged arc electric furnaces.
Baghouses are preferred, while electrostatic precipitators are seldom used.

          A total  of 126 ferroalloy furnaces was used in developing cost
estimates.  Those furnaces that were not identified as having specified
control  systems were prorated so that the totals were in the same
proportion as the 66 baghouses and 39 scrubbers that were identified.
There are only two furnaces with electrostatic precipitators.  Costs were
estimated on the basis of control equipment air flow, or if that
information was unavailable, on the basis of furnace megawatt rating.

          Control  costs  are summarized in Table AS.4.1.
                                  A6.4-3

    -------
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                                                                       A6.4-4

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                  Chapter A6.5  Primary Aluminum Smelting


          Revision of this chapter was limited to updating the pollution
control costs to 1981 dollars and rewriting the discussion of applicable
regulations.

Regulations

          The NSPS for primary aluminum reduction plants, which was
promulgated on January 26, 1976 (40 CFR 60.190), set standards for fluoride
emissions and opacity.  Since fluoride is a designated pollutant, EPA's
promulgation of NSPS for aluminum reduction plants forces states to include
in their SIP revisions a fluoride standard for all existing aluminum
reduction plants.  EPA issued guidelines to the states for development of
these standards in December 1979.  Fluoride standards for existing aluminum
reduction plants need not be as stringent as the NSPS since the emissions
are considered to be "welfare-related" rather than "health-related."

          Six states (Alabama, Louisiana, Montana, Nevada, Oregon, and
Washington) have had particulate emission standards for primary aluminum
plants for several years.  Other states have general particulate standards
that apply to primary aluminum plants, which are patterned after the
particulate process weight table of Appendix B (40 CFR 51, App. B).

Industry Characteristics

          The domestic primary aluminum industry includes approximately 10
companies operating reduction facilities in 16 states.  Three companies
operate about two-thirds of the total capacity.  The largest 50 percent of
the plants constitute about two-thirds of industry capacity.  Plants tend
to be located in areas where low-cost electrical power is available.

          Aluminum is one of the most abundant elements and when measured
either in quantity or value, its use exceeds that of any other primary
metal except steel.  It is used to some extent in virtually all segments of
the economy, but its principal uses have been in transportation, building
construction, electrical industry, containers, packaging, consumer
durables, machinery, and equipment.  The annual growth rate of aluminum
production in the United States has averaged 7 percent in recent years.

          Bauxite ore (typically containing 50-55 percent alumina) is the
principal source of aluminum.  Alumina is extracted from bauxite by one of
the variations of the Bayer process.  In turn, alumina is dissolved in
molten cryolite and reduced to aluminum by electrolysis in the universally
used Hall-Herould aluminum reduction cells, which are connected in series
to form a pot!ine.
                                  A6.5-1

    -------
          The aluminum reduction plant may be classified according to the
type of anodes used in the cells.  Prebaked anodes are replaced
intermittently, and Soderberg anodes are replaced continuously.  In the
Soderberg continuous system, an anode paste is continuously supplied to a
rectangular metal  shell  suspended above the cell.  As the anode shell
descends, it is baked by the heat of the cell.  Two types of Soderberg
anodes use different support methods:  a vertical stud system supported o
vertical  current-carrying pins (studs), and a horizontal stud system
supported by pins  which  are inclined slightly from the horizontal.

Pollutants and Sources

          All three anode systems used to produce aluminum release
particulates and fluorides (in both gaseous and particulate form) which
must be controlled.

          Of the three anode systems in use, the vertical Soderberg syste
emits the lowest quantity of particulates.  The prebaked and horizontal
Soderberg systems  are higher in pollutant emissions.  On the other hand,
the emissions from the prebaked system are easiest to control, those from
the vertical Soderberg are somewhat more difficult, and those from the
horizontal Soderberg the most difficult to control.  This has led to a
gradual phasing out of the latter two processes.

          The principal  sources of emissions at primary aluminum smelters
are the electrolytic cells and, in the case of prebake-anode type plants,
the anode bake furnace.   The raw, uncontrolled rates of emissions from
these processes have been identified as averaging 25 kg per metric ton (5
pounds per short ton) of fluorides and 56 kg per metric ton (112 pounds p
short ton) of particulates per ton of aluminum produc'ed.

Control Technology

          In this  analysis, it was assumed that all sources would be
controlled to a standard allowing emissions of one kilogram of fluoride p.
metric ton (two pounds per short ton) of aluminum produced.  New sources
are assumed to be  of the prebaked process only.  It is further assumed th
the New Source Performance Standards for fluorides will be met by the sam
control processes  applied for particulate control at no additional cost.
Assumed control processes for the three production processes are shown
below:
                                  A6.5-2

    -------
Cell type                     Primary control            Secondary control

Prebaked          Primary Collection (Hoods and         None Needed
                  Ducting), Plus Fluidized-Bed Dry
                  Scrubber

Horizontal        Primary Collection, Wet Electro-      Spray Screen and
  Soderberg       static Water Treatment Precipita-     Water Treatment
                  tor, Spray Tower, or Fluidized-
                  Bed Dry Scrubber (experimental)

Vertical          Primary Collection, Wet-              Spray Screen and
  Soderberg       Electrostatic                         Water Treatment
                  Precipitator, or Spray Tower

          In essence, these control measures consist of either very tight
hooding of the electrolytic cell (usually possible only with prebake-anode
systems) with control devices (adsorption on dry alumina followed by
baghouse recovery of particulate) which control both volatile fluorides and
particulate.  On cells where hooding of the necessary tightness cannot be
achieved, the escaping emissions are collected at the roof and controlled,
usually with wet control devices capable of dealing with the more dilute
concentrations of fluoride and particulate.  In the case of prebake-anode
type plants, separate control devices are applied to the anode-bake furnace
(usually a wet scrubber to collect fluorides and hydrocarbons from the hot
furnace gases).  Carbon grinding and milling (in the paste plant) are
usually controlled with baghouses or wet scrubbers.

Costing Methodology

          Table A6.5.1 shows the estimated costs for air-pollution
abatement.  Note that the prebaked anode process is the dominant one now,
and that all new plants are assumed to employ  this process.  Two new
production processes, the Alcoa and the Toth,  which are claimed to be
essentially nonpolluting, are now being investigated.  If successful, costs
for new sources in the future might be substantially lower than indicated.

          Currently, the development is in progress of standards for
control of fluorides as a designated pollutant under Section III (d) of the
Clean Air Act.  Costs associated with whatever SIP revisions are developed
are not included in this estimate.
                                  A6.5-3

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                       A6.6  Primary Copper Smelting

          This chapter covers the costs of air pollution controls for
primary copper smelters.  The chapter is limited to the smelting stage of
copper production because federal air pollution regulations primarily apply
to smelters, not to copper mines or refineries.

Industry Characteristics

          The production of primary copper — from mined copper ore rather
than scrap -- comprises three major process stages:  mining, smelting, and
refining.  Several  of the largest copper producers are vertically
integrated into all three stages.  Of the seven companies that operated
smelters in 1981, six operated refineries and all  seven operated mines.
Most smelting and refining facilities are located  near the mines, the
majority being in the southwestern states of Arizona, Utah, and New Mexico.

          Copper is used predominantly for electrical and electronic
products (e.g., power transmission lines, conductors, machinery), building
construction products (e.g., tubing and plumbing), and automobile parts
(e.g., radiators, wiring, and bearings).  Despite  the relatively strong
demand for copper in the 1970's, U.S. smelting and refining of copper fell
slightly in response to lower profit margins.

          There were fifteen smelters in operation in 1981.  The fifteen
had a total capacity of 1.5 million tons of copper output per year.   When
compared with a total capacity of 1.9 million tons in 1975, this represents
an average annual decline in smelter capacity of four percent per year.
One smelter opened  in 1976, one closed in 1980, and another is planning to
close in the near future.

          Copper smelting and refining capacity is expected to remain
relatively stable in the future.  Additional  demand for copper will  be met
by exporting mined  copper ore to foreign smelters  and refineries and
importing the refined copper to domestic fabricators.

          The primary copper industry is classified into SIC 3331.   Copper
smelter products are further classified into SIC 33311.  The value of
product shipments for SIC 33311 rose from $1.36 billion in 1972 to $2.05
billion in 1979.

Emission Sources and Pollutants

          Copper ore concentrate passes through three processes at a
smelter:  roasting  or drying, smelting, and converting.  Either roasting or
drying prepares the ore for more efficient subsequent processing.   A
smelting furnace then removes iron and other impurities from the feed to
form a matte of copper, iron, and sulfur.  Ladles  transfer the molten matte
to a converter, which produces crude blister copper product by blowing


                                  A6.6-1

    -------
compressed air into a mixture of flux (e.g., silica, sand, or rock) and t
molten matte.  Residual  slag is returned to the smelter for further
processing.

          Roasters.  Roasting reduces the sulfur content, removes volatil
impurities, and oxidizes some of the iron in the ore concentrate to form
calcined feed.  Drying lowers the moisture content to form green feed and
is used instead of roasting when better concentration methods have been
applied to remove free pyrite from the ore.  Some smelters do not use
roasters or dryers because the grade of the ore concentrate obtained from
mines does not require pretreatment.  Both particulate matter and sulfur
dioxide emissions are generated by roasting; dust only is emitted during
the drying process.

          Smelters.  The major types of smelting furnaces used in copper
smelters are reverberatory, electric, flash, and Noranda.  Both
reverberatory and electric smelting are batch processes.  The reverberate
furnace is the oldest and most widely used.  They are found in eleven out
of the fifteen smelters and were installed when the smelters were built i
the early 1900's.  Two smelters have electric furnaces.

          Flash smelting is a continuous process in which ore concentrate
and flux are continuously injected into the furnace and burned in a "flas
combustion that requires no additional fuel source.  A flash furnace, whi
is larger and more efficient than a reverberatory furnace, was installed
the most recently constructed smelter.

          A Noranda smelter is a continuous smelter that performs all thr
processes in a single furnace.  Only one of these energy efficient smelts
is operating in the United States.

          Sulfur dioxide is emitted from all four types of furnaces.  The
waste stream from batch processes flows sporadically whereas that from
continuous processes is steady and easily controllable.  The reverberator
furnace and Noranda smelter also emit particulate matter.

          Converters.  Most U.S. copper smelters use Peirce-Smith
converters"Only one smelter uses the Hoboken converter.  The primary
pollutant of this process is sulfur dioxide, which is emitted at a
relatively high concentration in the waste gas.

          Fugitive Sources.  All processes generate fugitive emissions of
sulfur dioxide and particulate matter.  Most of these emissions result fr
leaks in the process equipment or in the transfer equipment that directs
the gas stream to process emission control equipment.

Regulations

          Primary copper smelters are subject to sulfur dioxide,
particulate, and opacity standards in both NSPS and SIPs.  Of the two
smelters subject to NSPS, one was recently constructed and the other made
major modifications.  The remaining smelters are subject to SIPs.
                                  A6.6-2

    -------
Visibility standards requiring Best Available Retrofit Technology (BART) do
not apply to most smelters, because BART applies to sources that have been
in operation less than fifteen years before the 1977 amendments.  Most
copper smelters were in operation before 1962.

          NSPS.  The NSPS for primary copper smelters (40 CFR 60.160) were
promulgated January 15, 1976.  Sulfur dioxide standards govern roasters,
smelting furnaces, and converters.  Particulate matter standards govern
dryers, and opacity standards govern dryers and any facility that uses a  ..
sulfuric acid plant to comply with the sulfur dioxide standard.
Reverberatory smelting furnaces are exempt from the sulfur dioxide standard
when processing copper ore with a high level of volatile impurities (40 CFR
60.163).

          The NSPS governing sulfuric acid plants (40 CFR 60.80) does not
cover sulfuric acid plants at copper smelters, which'are installed for the
purpose of pollution control.

          SIPs.  Most SIPs developed in the early 1970's established sulfur
dioxide emission standards achievable with RACT, as suggested by EPA (40
CFR 51, App. B).  The Arizona SIP, which applies to 57 percent of smelter
capacity (eight of the fifteen smelters), is the most notable exception.
It places direct responsibility on smelters for meeting the primary
National Ambient Air Quality Standard (NAAQS) for sulfur dioxide in the
area surrounding the smelter.

          The particulate matter standards are either patterned after the
process weight table in Appendix B (40 CFR 51) or expressed on a control
efficiency or a gas volume basis.

          Since the development of these SIPs in the early 1970's, EPA
determined that the sulfur dioxide emission reductions established in the
SIPs could not be obtained.  The 1977 Clean Air Act amendments provided for
the issuance of Primary Nonferrous Smelter Orders (NSOs), which are
temporary operating permits for smelters that could not comply with the
standards.  The NSO is an agreement among the smelter operator, the state
pollution control enforcement agency, and EPA as to the technology
reasonably available to each smelter.  The Act required that EPA establish
a mechanism for a smelter to apply for two NSOs, the first expiring in
1983, the second in 1988.  NSOs were designed to permit smelters to use
temporary measures of control such as tall  stacks and production
curtailment (discussed below).

Control Technology

          Copper smelters can employ three types of control  techniques to
reduce emissions levels:   installation of control  equipment for permanent
control or use of tall stacks and/or production curtailment for temporary
control (only allowed for smelters operating under NSOs).   Each of these is
discussed below.
                                  A6.6-3

    -------
          Control  Equipment.   Copper smelters generally control sulfur
dioxide and particulate matter process emissions with one primary type of
control equipment for each pollutant.  Fugitive emissions of both
pollutants are controlled with auxiliary equipment.  Often, one control
device is used to treat the combined emissions of one pollutant from
several sources in the smelter.   The following discussion of the
application of control techniques is divided into three sections:  sulfur
dioxide process emissions, particulate matter process emissions, and
fugitive emissions.

          Sulfur dioxide process emission controls include sulfuric acid
plants, DMA absorbers, and flue gas desulfurization (FGD) systems.
Sulfuric acid plants require gas streams that have a high concentration o
sulfur dioxide and a constant flow.  DMA (dimethylaniline) absorbers
produce liquid SCL from gas streams with lower or uneven SO-
concentrations.  FGD systems are absorbers that capture 50^ from flue gas
with even lower SO- concentrations.

          The conventional acid plant has a single contact, single
absorption process.  Conversion efficiencies can range from 95 to 96
percent but have been reported to be as low as 60 percent.  The double
contact, double absorption process is an improved acid plant design that
capable of achieving conversion efficiencies as high as 99.8 percent.  Th
high efficiency results in significantly lower tail gas emissions than
those emitted from a single contact plant.  The double contact acid plant
provides sufficient control to meet the NSPS for sulfur dioxide.

          Acid plants can efficiently control S02 emissions from
fluidized bed roasters, electric, flash, and Noranda furnaces, and both
Peirce-Smith and Hoboken converters.  SO, emissions from multi-hearth
roasters and conventional reverberatory furnaces cannot be controlled wit
an acid plant, because their gas streams do not have a sufficiently high
S02 concentration for an acid plant to operate efficiently.  The high
S02 concentration waste stream emitted at a uniform rate from flash
furnaces and furnaces with oxygen enriched firing provides acid plants th
necessary feed for efficient performance and SO- control.

          DMA absorbers are often used in conjunction with acid plants.
The DMA process yields a concentrated SO- liquid that can be sold or
directed to the acid plant for more efficient recovery of the sulfur
dioxide.
          FGD systems can also be applied to gas streams with weak SO-
concentrations.  Such systems generally use lime or limestone to absorb t
SO- from copper smelter flue gases.  Although none are now operating in t
U.S., several smelters are considering an FGD system as an SO- control
strategy.

          Twelve of the fifteen copper smelters have acid plants.  Acid
plants in five of these smelters are double contact design, including the
installed for two smelters to comply with NSPS.  Two smelters operate DMA
absorption (liquid SO-) plants in conjunction with their acid plants.


                                  A6.6-4

    -------
          Five smelters plan furnace conversions during the 1982-1988
period.  Two smelters plan to convert their reverberatory furnaces to the
oxygen sprinkle process, an oxygen enrichment system.  Three smelters are
converting their reverberatory furnaces to INCO flash furnaces.  Both types
of conversion will  create a more consistent furnace gas stream with higher
SCL concentration,  which can be treated with existing acid plants.  One
of these smelters has built a new double contact acid plant.  The other
smelters are upgrading their acid plants from single to double contact or
installing an FGD system for improved collection of the sulfur dioxide.

          Of the three smelters without acid plants, one has sufficiently
low emissions that  no SOo controls are necessary for compliance.  Another
smelter will either install an acid plant or an FGD system.  It is assumed
that the third will  remain uncontrolled through the 1980's, because
construction of S02 control equipment would force it to close.

          Particulate matter process emission controls are applied to gas
streams prior to sulfur dioxide treatment.The electrostatic precipitator
(ESP) is the collector most widely used for emissions from all  sources in
the copper smelter, particularly multiple hearth roasters, rotary dryers,
and reverberatory furnaces.  Wet scrubbers are employed on a few fluidized
bed roasters, and fabric filters are used on a few multiple-hearth
roasters.  Cyclone  collectors, which are used to capture the larger
particles, often precede ESPs.  Gas streams from reverberatory furnaces  and
Noranda smelters pass through waste heat boilers before entering the ESP.
Collected dusts, which contain a high proportion of copper, are usually
recycled in the smelting furnace.

          Fugitive  emission controls include secondary hood systems and
building evacuation systems.  An efficient secondary hood system comprises
a fixed hood and a  type of movable hood for covering specific operations.
Building evacuation systems are structures that enclose the smelter and
vent the emissions  to the atmosphere through a baghouse.

          Three smelters installed secondary hood systems by 1981, and
eight are planning  to install them by 1987.  Because building evacuation
systems cause occupational health problems, only one smelter has installed
the system.

          Tall Stacks.  Smelters use tall stacks to direct flue gases to a
sufficiently high altitude that the sulfur dioxide is diluted when
dispersed into the  lower atmosphere.  The resulting ambient sulfur dioxide
concentration is dependent on other smelter controls, the ambient
concentration prior to discharge, and weather patterns.  Emissions modeling
must be used to achieve effective dispersion.

          Production Curtailment.  Copper smelters curtail production to
control emissions when ground level concentrations increase as  a result  of
adverse weather conditions.  A Supplementary Control System (SCS)  or
"closed loop control" is the system of curtailing production in response to
concentration information provided by a set of ground level moaitors in  the
surrounding area.  Use of an SCS causes a reduction in effective capacity


                                  A6.6-5

    -------
that is reflected in the lower.total  capacity figures for the industry in
recent years.

Cost Methodology

          Air pollution control cost estimates for the copper smelting
process are presented in Table A6.5.1.  These costs are based on a
comprehensive study of the copper industry performed for EPA by Arthur 0.
Little, Inc. (ADL) (EPA 230/3-78-002-1) in 1977.  The costs reported in t
ADL document cover controls for air,  water, and solid waste pollution.  E
estimates that the air pollution control  costs constitute 97 percent of t
total, and we have adjusted the costs accordingly.

          ADL presented annual costs for 1970 through 1987.  The historic
costs for 1970 through 1977 were updated to 1981 dollars and adjusted by
the 97 percent factor.  These and further adjustments were made to the
annual costs for the period 1978 to 1987.  The controls forecast by ADL i
1977 were compared to those actually installed during 1978-1981 and those
currently planned for installation during 1982-1987.  ADL projected that
smelters would install building evacuation systems during 1979-1986.  Sin
these were not installed, the costs for these systems were subtracted fro
the 1979-1986 annual ADL costs.  ADL did not include costs for
reverberatory furnace conversions by five smelters, an acid plant upgrade
from single to double contact by one smelter, and a new double contact ac
plant by another smelter, which are currently planned for 1982-1988.
Estimates of these costs, which were provided by EPA along with a project
investment schedule, were added to the total.
                                  A6.6-6

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                        Chapter A6.7  Primary Lead

          This chapter presents cost estimates for sulfur dioxide and
particulate omission controls for primary lead smelting operations.  The
chapter text has been revised substantially for this edition of the Cost of
Clean Air Report.  Several of the changes were made to account for closure
of the Bunker Hill smelter in 1981.  The projected costs for meeting the
ambient lead standard were revised, but the sulfur dioxide control cost
estimates have not been changed for this edition.

Industry Characteristics

          Lead production in the United States involves three major steps:
mining, crushing, and grinding of sulfide ores, and beneficiation to
produce lead concentrates; smelting of the concentrates by
pyrometallurgical methods to produce impure lead bullion; and refining the
bullion to separate other metal values and impurities.   This chapter
presents estimates of the costs of air pollution control for primary lead
smelting operations.  Secondary lead smelting is discussed in Chapter
A6.ll.

          In 1979, the domestic lead mining industry included about 25
mines in seven states.  All  of the larger mines and many medium-sized mines
concentrate ores at the mine site.  Some of the smaller mines use
centralized mills.  Ninety percent of lead mined in the U.S. in 1979 was
produced by eight Missouri mines.  Primary lead smelting and refining are
also concentrated in Missouri.  Smelting is now done by three companies
that operate five smelters (three in Missouri) and four refineries (three
in Missouri).  Another smelter and refinery (Bunker Hill in Idaho) was
closed in 1981.

          Primary lead production in the United States  was 550,000 short
tons in 1981.  Secondary production was 778,000 tons.   Sixty-five percent
of the 1.29 million tons of lead consumed in the U.S.  in 1981 was used in
battery components.  Gasoline antiknock additives  accounted for ten
percent, pigments seven percent, ammunition four percent, solder three
percent, and miscellaneous products, such as cable covering, castings,
weights, and ballast, the remainder.

Pollutants and Sources

          Methods of metallurgical operation at all of  the primary lead
smelters are similar; the differences stem from the type of ore handled by
the Missouri smelters and by the western smelters.  In  the West, lead ore
concentrates are cleaner and have much higher amounts  of gold,  silver,
zinc, cadmium, copper, antimony, and arsenic present.   Except for a
slagfuming furnace operation in the western smelters to remove  the higher
amounts of zinc in the concentrates, there are no  major differences in the
basic smelter operations.

                                  A6.7-1

    -------
          Emissions from lead smelters are primarily participates
(including lead) and sulfur dioxide.   Most of the sulfur dioxide is
generated in the sintering machine.   Flue-gas particulates include the
following metals:   lead (as high as  30 percent)  and traces of zinc,
antimony, cadmium, and copper.   In western smelters, significant quantiti
of noble metals are often also  emitted; at one smelter over 1 kilogram pe
metric ton (30 ounces per short ton)  of silver and 4.8 grams per metric t
(0.14 ounces per short ton) of  gold  were recovered from flue-gas
particulates.  Thus, there is an economic reason to recover particulates
addition to fume control.  The  emissions from the slag furnaces (used in
the western smelters to recover zinc) also include particulates containin
zinc oxide and zinc dust.

          Stack and fugitive lead emission levels are discussed in Contro
Techniques for Lead Air Emissions, Volume II (EPA-450/2-77-012).  The maj
sources of atmospheric lead emissions are the sintering machines, blast
furnaces, and dross reverberatory furnaces.  The major sources of fugitiv
lead emissions are sintering operations, lead ore concentrate handling an
transfer, and zinc fuming furnace vents.

Regulations

          NSPS promulgated in 1976 (41 FR 2331)  and revised in 1977 (42 F
37936 and 41424) regulate the level  of particulate and sulfur dioxide
emissions and the opacity of particulate and gaseous emissions.
Particulate emissions from blast or  reverberatory furnaces and from
sintering machine discharges are limited to 50 milligrams per dry standar
cubic meter (0.022 grams per dry standard cubic foot) and 20 percent
opacity.  Gaseous emissions from sintering machines, electric smelting
furnaces, and converters may not contain more than 0.065 percent sulfur
dioxide and may not exceed 20 percent opacity.

          Several  states have specific regulations for nonferrous smelter
that govern primary lead smelters.  Appendix 8 (40 CFR 50) suggests sulfi
dioxide emission limits achievable with RACT for lead smelters and provic
general process weight rate limitations for particulate emissions.  The
1977 Clean Air Act Amendments provide for the issuance of Nonferrous
Smelter Orders in cases where enforcement of the SIP limits would result
closure of the smelter.

          NAAQS for lead were promulgated in 1978 (43 FR 46258).  Primary
lead smelters are listed among  other significant point sources whose air
quality impact must be specifically  addressed in the SIPs (40 CFR 51.80).
The ambient standard of 1.5 micrograms per cubic meter requires stringent
control of both stack and fugitive emissions.  Controls required to meet
the ambient standard may also assist in achieving OSHA lead control
standards.

Control Techniques

          In 1973, two of the five U.S. smelters now in operation used
sulfuric acid plants to control sulfur oxides in sintering machine

                                  A6.7-2

    -------
off-gases.  Removal of particulates from the strong sulfur dioxide gas
stream (e.g., via scrubbing) is also a requirement for effective operation
of the acid-plant system.  In smelters without acid plants, baghouses are
used to remove most of the particulates in the cooled processing off-gases,
and sulfur oxides are not controlled.  Baghouses are also used by smelters
with acid plants to treat exhaust gases from blast and dross reverberatory
furnaces and weak gas streams from sintering machines.  These baghouses may
be considered part of the smelter's process equipment.  Their use is common
industry practice due to the value of the recovered products.

Costing Methodology

          The SIP costs reported in Table A6.7.1 assume the addition of
single-contact sulfuric acid plants to three of the smelters, one of which
was in place by 1979.  The other two acid plants were assumed to be
installed by 1984.  The additional gas-cleaning equipment required to
operate the acid plants is also included in the SIP cost estimates.
Capital and operating cost functions were developed from control cost
estimates provided in Volume 1 of the NSPS background document
(EPA-450/2-74-002a).

          The control costs in the table also include a component for
compliance with the ambient lead standard.  These estimates are based on
the "Economic Impact Assessment for the National Ambient Air Quality
Standard for Lead" (EPA, OAQPS, November 22, 1977) and an addendum (May 25,
1978).  The total capital investment for additional fugitive controls for
the five primary lead smelters is estimated at $12.9 million (1976
dollars).  Annual O&M costs are estimated at $1.5 million.  Capital
expenditures were assumed to be spread evenly over the years 1985-1987.
                                  A6.7-3

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    -------
               Chapter A6.8  Primary Zinc Smelting Industry


          Revision of this chapter was limited to adjusting the pollution
control costs to 1981 dollars and editing the discussion of regulations.

Regulations

          The NSPS for primary zinc smelters (40 CFR 60.170) was
promulgated on January 15, 1976, and revised in 1977.  The regulations set
particulate and opacity standards for sintering machines and sulfur dioxide
and opacity standards for roasters.

          Appendix B (40 CFR 51, App. B.) states that 90 percent removal of
sulfur oxides is achievable by RACT at existing zinc smelters.  However,
because it was determined that this degree of control was not achievable,
Primary Nonferrous Smelter Orders were established in the 1977 Clean Air
Act Amendments as a means for industry, EPA, and state air pollution
control agencies to agree upon RACT on a pi ant-by-plant basis.

          As of 1976, Pennsylvania was the only state to have regulations
controlling primary zinc smelters specifically.  The regulations limit
sulfur oxide emissions from zinc roasting and zinc sintering operations.

Industry Characteristics

          Zinc ranks after aluminum, copper, and lead in tonnage of
nonferrous metals produced in the United States.  Major uses are zinc-base
alloys, particularly die-cast alloys used in automotive and electrical
equipment (41 percent); galvanized steel  used in construction and
electrical transmission equipment (36 percent); brass and bronze used for
plumbing, heating, and industrial  equipment  (14 percent); zinc chemicals,
particularly zinc oxide, used in the rubber, paint, and ceramic industries
(4 percent); and rolled zinc used in dry cells and lithographic plates (2
percent).

          The principal ore minerals are sulfides, which may be
predominantly zinc ores or lead-zinc ores.  Also, some zinc is obtained
from lead-base and copper-base ores.  Zinc sulfide concentrates produced
from these ores are converted to the oxide state (calcine)  by roasting, and
then reduced to metallic zinc either by electrolytic deposition or by
distillation in retorts or furnaces.  In plants using distillation methods,
the calcine is given an additional sintering step to provide a more compact
feed as well as to remove impurities.  Some  zinc-producing  companies also
produce zinc oxide.  In pyrolytic plants, both zinc metal and zinc oxide
are produced from zinc vapor, either condensed to zinc metal, or oxidized
in a chamber.
                                  A6.8-1

    -------
          The zinc industry has undergone great changes in the period 196£
to 1976, shrinking from 15 smelters in 1968 to seven in 1979.  The old
technology of horizontal  retort smelting has been completely replaced, am
five of the seven plants  use the electrolytic process.   One of the
remaining pyrothemic plants is presently scheduled for closure.

          The zinc industry is projected here to remain essentially the
same size for the foreseeable future due to the balance of process
technology, production costs, competitive materials, and foreign
competition.

Pollutants and Sources

          Emissions from zinc reduction plants are primarily particulates
and sulfur dioxide from the roasters in the electrolytic plants,  and from
the roasters and traveling-grate sintering machines in  the pyrothermic
plants.  In the electrolytic plants, the calcine from the roaster is
substantially sulfur free so that there is a heavy concentration  of sulfu
dioxide in the off-gases.  For the pyrothermic plants,  roaster off-gases
are also heavy in sulfur dioxide, but there are only light concentrations
of sulfur dioxide in the sintering machine off-gases.  Particulates are
relatively heavy in both streams.

Control Technology and Costs

          Sulfur oxide and particulates in roaster off-gases are  now bein<
controlled by the use of sulfuric acid plants in all of the present seven
plants.  Particulate control necessary for the effective operation of the
acid plant system is achieved with associated gas-cleaning equipment.  Wi
the closing of the horizontal retort plants, all the roasters in  the
primary zinc plants are controlled with acid plants.  In the two  remainin
pyrothermic plants, the sintering machine particulates  are controlled in
one plant by settling flues, electrostatic precipitators, and a baghouse,
in the other, by a venturi scrubber.

Industry Cost Model

          The approach to estimating the cost of compliance for this
industry considered SO  control in terms of sulfuric acid plant
installations, and divided those into the following categories:

          •  "Old", single-pass acid plants; acid plants constructed befo
             1970 were not considered to be associated  with the costs due
             to the Clean Air Act

          •  "New", double-pass acid plants installed since 1970

          The costs estimated on the above basis are listed in Table
A6.8.1.
                                  A6.8-2

    -------
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                     Chapter A6.9  Secondary Aluminum

          Revision of this chapter was limited to adjusting the pollution
control costs to 1981 dollars and editing the discussion of regulations.

Regulations

          No NSPS has been proposed for secondary aluminum plants.
Particulate standards in SIPs apply to this industry.  Most states have
general process weight rate standards patterned after those suggested in
Appendix B (40 CFR 51, App. B) as achievable with RACT.  Only Pennsylvania
specifically regulates particulate emissions from the sweating, melting,
and refining of aluminum.

Industry Characteristics

          In this report, the secondary aluminum industry is defined as
that industry which produces secondary aluminum ingot, or hot metal, to
chemical specifications from aluminum scrap and sweated pig.  Therefore,
the industry covered here excludes primary aluminum companies, the
activities of the nonintegrated fabricators, and scrap dealers.

          All metallic scrap can be divided into new and old (or obsolete)
scrap.  New aluminum scrap is generated in primary aluminum production,
semi fabricated aluminum mill products, or. finished industrial  and consumer
products.  Such scrap includes aluminum borings, turnings, clippings and
punchings, forgings, dross, skimmings, and slag.

          Old aluminum scrap consists of those aluminum-bearing end
products that are discarded at the end of their economically useful lives
and are collected for metal recovery.  Old aluminum scrap therefore may be
almost any aluminum item that has sufficient weight and cleanliness that is
economical to recycle.  Typical items are cans, utensils, automobile parts,
wire and cable, and pipe.  The major markets for aluminum are in building
and construction, transportation, electrical equipment and supplies,
containers and packaging, and machinery and equipment.  Obsolete products
from any of these market segments can and probably will end up as recycled
scrap.  It is estimated that the secondary aluminum industry will have an
annual growth rate of about 6 percent between now and 1985.  The basis for
this estimate is the growing realization that the recycling of aluminum
aids in conserving natural resources, that recycling of aluminum requires
approximately 10 percent of the energy required to produce primary
aluminum, and recycling helps in cleaning up the environment.   Also, there
is considerable interest in recycling municipal solid wastes for recovery
of Btu values from paper, plastics, and rubber, recovery of ferrous and
nonferrous metals, and alleviating the problems of landfill disposal.

          The secondary aluminum smelter industry at the end of 1977
consisted of about 70 companies operating about 90 plants.  These figures


                                  A6.9-1

    -------
do not include those plants operated by primary aluminum producers.  The
plant inventory available to this study is believed to be approximately
accurate with regard to the relatively large secondary aluminum smelters.
However it is likely that not all small smelters were identified.  The
secondary metals industry, including the secondary aluminum smelters, is
different from many other industries.  The secondary aluminum smelter
industry is made up of a rather large group of small- to medium-sized
companies, and a small group of large companies.  The smaller companies a
not highly capitalized and their existence tends to rest on being able to
purchase scrap at the proper price so that a company may process it and
make a profit at the price the buyer will  pay.  It is not unusual for
secondary smelters to suspend operations or go out of business when the
price structure of buying and selling is not favorable.   The level  of
availability of the proper scrap raw material in a smelter area also
influences the size of operation.

          The identifiable annual capacity of the secondary aluminum ingo
industry at the end of 1977 was estimated to be 968,300 metric tons
(1,065,100 short tons).  It is believed that the actual  capacity may be
closer to 1.1 million metric tons (1.2 million short tons).

Pollutants and Sources

          The most serious emission sources during secondary aluminum
smelting are:  the drying of oil from borings and turnings, the sweating
furnace, and the reverberatory furnace.  Emissions from the drying proces
are vaporized oils, paints, vinyls, and other hydrocarbons; the sweating
furnace produces vaporized fluxes, fluorides, etc; and the reverberatory
furnace emissions are similar to the other two plus hydrogen chloride,
aluminum chloride, and magnesium chloride from the chlorine gas treatment
used to remove magnesium.  As of 1970, an estimated 25 percent of
chlorination station emissions were controlled, and it is estimated that
1980, 80 percent will be controlled.

          The several processes that cause emissions during the operation
of a reverberatory furnace must be understood to calculate control  costs
properly.  These are:

          •  Emissions at the forewell,
          •  Emissions from the bath, and
          •  Emissions caused by chlorination.

          Emissions at the Forewell.  Secondary smelters charge scrap
directly into the forewell of the reverberatory furnace, and any oil,
paint, vinyl, grease, and other hydrocarbons, on the scrap vaporize.  The
emissions from the charging process vary greatly with the material  charge
Quantitative data on the forewell emissions or the need  for control are n
available and costs or possible costs cannot be estimated.

          Emissions From the Bath.  During the time the  aluminum bath is
molten, it is covered with a flux to protect it from oxidation.
                                  A6.9-2

    -------
          Emissions Caused by Chiorination.  The magnesium content of scrap
aluminum can be reduced by chlorination, but chlorination produces chloride
emissions.  Maximum magnesium removal  requires about 18 kilograms of
chlorine per metric ton (36 pounds per short ton) of aluminum which has an
emission rate of 9 kilograms of particulates per metric ton (18 pounds per
short ton) of aluminum.  Magnesium removal  is practiced by plants
representing 92 percent of the estimated industry capacity.  A small
portion of these plants use aluminum fluoride fluxing for magnesium removal
rather than chlorine.   This report assumes  that control costs for these few
plants are similar to  those that use chlorination.   Wet scrubbing is the
usual means of controlling chlorination station emissions; recent
innovations on a dry control process are being tested.

Control Technology and Costs

          Dryer emissions are often treated with afterburners; however,
there are insufficient data relating to the drying  operations to permit
evaluations of possible costs that might be expended to meet air-quality
specification.

          Sweating furnace emissions,  fluoride emissions from fluxes,
organic materials, oils, and others, can be controlled  by using
afterburners, followed by a wet scrubber or baghouse.  However, no data are
available on the number, capacity, or  location of sweating furnaces.  Thus,
a realistic estimate of control costs  cannot be made.

          The costs reported here were based on the assumption of the
application of caustic scrubbers to the known chlorine  dejagging
operations.  The estimated costs developed  for this industry are given in
Table A6.9.1.
                                  A6.9-3

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    -------
                 Chapter A6.10  Brass and Bronze Industry

          Revision of this chapter was limited to adjusting the pollution
control costs to 1981 dollars and editing the discussion of regulations.

Regulations

          The NSPS for secondary brass and bronze smelters (40 CFR 60.130)
was promulgated on March 8, 1974.  The standards govern particulate
emissions from reverberatory furnaces and plume opacity from reverberatory,
blast, and electric furnaces.

          The brass and bronze industry is subject to SIP particulate
standards.  Most states have general particulate standards, which are
patterned after Appendix B (40 CFR 51, App.  B).  Several states have
applied the NSPS to existing brass and bronze smelting operations.
Pennsylvania is the only state with a process weight regulation for
particulates from the melting and refining of brass and bronze.

Industry Characteristics

          The secondary brass and bronze industry may be divided into two
segments:  ingot manufacturers and brass mills.  Both segments of the
industry charge scrap into a furnace where it is melted and alloyed to meet
design specifications for chemical composition.  Ingot manufacturers use
either a stationary reverberatory furnace or a rotary furnace for most of
their production.  The daily capacity range  is from 4.5 to 90 metric tons
(5 to 100 short tons) for reverberatory furnaces, and from 2 to 27 metric
tons (2 to 30 short tons) for rotary furnaces.  Small quantities of special
alloys are processed in crucible or electric-induction furnaces.  A few
cupolas exist in which highly oxidized metal, such as skimmings and slag,
is reduced by heating the charge in contact  with coke.  Ingot manufacturing
invariably requires injection of air to refine the scrap.   Brass mills use
scrap that does not require such extensive refining; the channel induction
furnace is the most common type used in these mills.

          The number of bronze ingot manufacturing furnaces in the industry
was estimated to be 122.  Of these furnaces, 13 were large, 29 were medium,
and 80 were small.  The large furnaces produced 50 percent of the total
annual ingots, while the medium furnaces produced 30 percent, and the small
furnaces produced 20 percent.

          No substantial growth is expected  in the ingot manufacture; in
1980, ingot production is expected to be at  the level of 272 thousand
metric tons (300 thousand short tons).  Adequate capacity  currently exists
in terms of additional available operating hours to be able to meet
increases in demand.
                                  A6.10-1

    -------
          The capacity of channel induction furnaces for brass mills range
from 0.5 to 5 metric tons (0.6 to 6 short tons), with smaller furnaces
being the most common.  It was estimated that there were 35 plants in 197S
with an average of 3.7 furnaces per plant, or a total of 13C furnaces.

Pollutants and Sources

          Metallurgical fumes, containing chiefly zinc oxide and lead
oxide, are the major emissions from the reverberatory and rotary furnaces
used by ingot manufacturers and from the induction furnaces used by the
brass mills.  Fly ash, carbon, and mechanically produced dust are often
present in the exhaust gases, particula'rly from the furnaces used by the
ingot manufacturers.  Zinc oxide and lead oxide condense to form a very
fine fume which is difficult to collect.  The emission factors for
particulates are 35 kg per metric ton (70 pounds per short ton) of metal
charged for a reverberatory furnace, 30 kg per metric ton (60 pounds per
short ton) for a rotary furnace, 3.2 kg per metric ton (6.4 pounds per
short ton) for an electric induction furnace, 6 kg per metric ton (12
pounds per short ton) for a crucible furnace, and 36.75 kg per metric ton
(73.5 pounds per short ton) for a cupola furnace.

Control Technology and Costs

          Ingot manufacturers use fabric-filter baghouses, high-energy we'
scrubbers, and electrostatic precipitators because of their high efficiem
in collecting the fine zinc oxide fumes; 67 percent use a baghouse, 28
percent use a scrubber, and 5 percent use an electrostatic precipitator.

          Assumptions were that the collected dust has a value of 10 cent:
per kilogram (4.5 cents per pound), and an average collector 97.5 percent
efficiency.  This value of collected dusts was applied as a credit to
control costs.

          Fabric filter baghouses are used on the brass induction furnaces
to collect the particulates.  Investment and annual costs were obtained
from three plants that use furnaces with capacities ranging from 22 to 32
metric tons (24 to 35 short tons) per day.  The average value for the thre
plants was used for the model furnace of 25 metric tons (27.6 short tons)
per day.  No credit for collected dust is assumed for brass mills.

          Control costs and industry operating statistics are detailed in
Table A6.10.1.
                                  A6.10-2

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               Chapter A6.ll  Secondary Lead Smelting

     This chapter presents cost estimates for control of lead and
other participate emissions from secondary lead smelting processes.  This
edition incorporates revisions of the regulations and industry
characteristics sections of the chapter text, in addition to minor changes
in the costing methodology.

Regulations

     Secondary lead smelters are regulated by NSPS promulgated on
March 8, 1974 (40 CFR 60.120).  The NSPS limit particulate emissions and
opacity for reverberatory and blast (cupola) furnaces and opacity for pot
furnaces with a capacity greater than 550 pounds.

     SIPs establish particulate and lead emission limits for secondary
lead smelters.  State standards for particulate emissions are often
provided in general industrial process weight rate or concentration
limitations.  RACT can meet the standards of the particulate process weight
table of Appendix B (40 CFR, Part 51).  Pennsylvania has a specific process
weight limit for secondary lead smelting.  Several states have incorporated
the NSPS into their regulations and have made them applicable to existing
secondary lead smelters.  SIPs must also include additional  requirements
for control of fugitive lead emissions at secondary smelters whose
emissions contribute to violations of the lead NAAQS.

Industry Characteristics

     The secondary lead industry is defined as the industry that
recovers lead or lead alloys by smelting lead scrap; this does not include
the activities of scrap dealers who may sweat lead.  Approximately 30
companies in the secondary lead smelting industry operate about 44 plants.

     The amount of secondary lead produced by all sources, as reported by
the Bureau of Mines, rose from 685,000 short tons in 1975 to 880,000 tons
in 1979.  Secondary production then decreased to 742,000 tons in 1980 and
776,000 tons in 1981.  A large component in these overall figures is
associated with battery manufacture.

Emission Sources and Pollutants

     Emission of particulates occurs  from lead-processing furnaces.
Generally, about 67 percent or more of the output of the secondary lead
industry is processed in blast furnaces that are used to reduce lead oxide
in the form of battery plates or dross to lead.   If oxide reduction is not
needed, then lead scrap can be processed in reverberatory furnaces.  Kettle
or pot furnaces may be used to produce small batches of alloys for molding
or refining lead.  These lead processing furnaces represent obvious
particulate emission sources, the primary emissions being lead oxide fumes.

                                  A6.11-1

    -------
Other participate emission sources are the slag tap and feeding ports on
the cupolas and reverberatory furnaces.  Although lead is occasionally
sweated in a reverberatory furnace, reclamation of secondary lead by this
means represents a very small portion of the total lead production.
Emissions factors from slag operations are not known.

     The industry estimate of 90 percent net control in 1970 indicates
that nearly all plants had emission controls of some sort.  A control
increase to 98 percent estimated by 1980 was based on implementation of t
New Source Performance Standards.

     The ambient air quality standard of 1.5 micrograms per cubic
meter will require stringent fugitive emission controls.  The earliest
attainment date is anticipated to be 1985.

Control Technology and Costs

     Either a baghouse or a wet scrubber can be utilized to achieve
emission control.  The baghouse is chosen for this cost analysis because
is generally less expensive; it is assumed baghouse life averages 20 year
Since the lead oxide collected in the control equipment is recycled into
the smelting furnace, it has value as a by-product; therefore, the recove
of this lead oxide lowers estimated operating and maintenance costs.

     The air pollution abatement costs for the secondary lead
industry presented in Table A6.11.1 were based on the following key
considerations:

     t    Costs for controlling stack emissions were based on
          information in EPA-450/2-77-012 (Control Techniques for Lead),
          December 1977, and include costs for controlling blast and
          reverberatory furnaces.  These costs are net of the estimated
          value of recovered dust.

     t    Costs as currently projected for controlling fugitive
          emissions amount to $99 million dollars (in 1976 dollars) in
          capital costs in the mid 1980's with an associated annual cost
          of $22 million per year.

          These cost estimates were developed for the economic impact
          assessment of the lead NAAQS and are based on installation of
          building evacuation systems by the plants existing at the time
          the NAAQS was proposed.  These costs are overstated to the
          extent that secondary smelters are able to use less expensive
          controls, and they do not reflect the recent closure of
          several secondary smelters.
                                  A6.11-2

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    -------
                       Chapter A6.12  Secondary Zinc


          Revision of this chapter was limited to adjusting the pollution
control costs to 1981 dollars and editing the discussion of regulations.

Regulations

          There is no NSPS for secondary zinc plants.  The industry is
subject to SIP particulate standards, most of which apply to all process
industries and are patterned after RACT standards in Appendix B (40 CFR 51,
App. B).  Pennsylvania's process weight rate table has specific standards
for the sweating and refining operations of secondary zinc smelting.

Industry Characteristics

          Zinc ranks after aluminum, copper, and lead in tonnage of
nonferrous metals produced in the United States.  Major uses are zinc-base
alloys, particularly die-cast alloys used in automotive and electrical
equipment (38 percent), galvanized steel used in construction and
electrical transmission equipment (38 percent), brass and bronze used for
plumbing, heating, and industrial equipment (15 percent), zinc chemicals,
particularly zinc oxide, used in the rubber, paint, and ceramic industries
(4 percent), and rolled zinc used in dry cells and lithographic plates (3
percent).

          Secondary zinc comes from two major sources:  the zinc-base
alloys and the copper-base alloys.  Most of the secondary zinc that is
recovered comes from reconstituted copper-base alloys; slab zinc is next in
importance, followed by chemical products, and zinc dust.  For purposes of
this report, the 11 operating plants that comprise the secondary zinc
industry use sweating and/or distilling operations to produce zinc slab,
dust, and oxide solely from scrap.  The secondary zinc industry is not
considered to include the activities of:

          •  Primary zinc producers that may manufacture zinc from scrap
             and .ore

          •  Secondary brass and bronze plants that recover zinc in copper
             alloys

          •  Chemical manufacturers that produce zinc compounds by chemical
             treatment of zinc scrap

          •  Scrap dealers that may sweat zinc.

          The Bureau of Mines' 1976 Minerals Yearbook lists eleven
secondary zinc plants with a total capacity of about 44,000 metric tons of
slab zinc.  The same source indicated that in 1976 about 23,500 metric tons
                                  A6.12-1

    -------
of redistilled secondary zinc was produced at secondary smelters.  Zinc
oxide and zinc dust were also produced by the secondary zinc plants and b}
the primary zinc smelters, but no definitive tonnages of these products ar
published for secondary smelters.

Pollutants and Sources

          At least four operations generate emissions in the secondary zir
industry:  materials handling, mechanical pretreatment, sweating, and
distilling.  This analysis considers only control costs for emissions fror
the sweating and distilling operations, as insufficient data are available
for calculating the possible costs of controlling emissions from the othe
sources.

          In the sweating operation, various types of zinc-containing sere
are treated in either kettle or reverberatory furnaces.  The emissions va
with the feed material used and the feed material varies from time-to-time
and from plant-to-plant.  Emissions may vary from nearly 0 to 14 kg of
particulates per metric ton (0 to 30 pounds per short ton) of zinc
reclaimed.  For purposes of this report, it is assumed that the maximum
emission rate applies.

          In the case of the various types of zinc distilling furnaces, t
accepted emission rate is 23 kilograms per metric ton (46 pounds per shor
ton) of zinc processed.  Some distillation units produce zinc oxide, and
normally utilize a baghouse for collection of the product.  This report
assumes that these baghouses are sufficient to meet national ambient air
standards.  However, for the purpose of calculating control costs, it was
assumed that essentially all of the estimated zinc oxide capacity could bi
switched to slab zinc or dust production, and emission controls would be
required.

          Controlled and uncontrolled emissions from secondary zinc
sweating operations cannot be estimated with an acceptable degree of
probable accuracy because reliable data are not available.

Control Technology

          The major emission of concern is particulates, consisting main!;
of zinc oxide.  Baghouses have been shown to be effective in controlling
both distillation and sweating-furnace emissions except when the charge
contains organic materials such as oils.

Costing Methodology

          A complete accounting of secondary zinc plants by type of
furnaces used and the product or products produced is not available.  Bas
on the  limited information, it is assumed that the industry's 11 plants c
be represented by two models:  two plants, each consisting of 7,260 metri
tons per year (8,000 short tons per year) sweating capacity and 10,900
metric  tons per year (12,000 short tons per year) distilling capacity; an
nine plants, each consisting of 4,080 metric tons per year (4,500 short


                                  A6.12-2

    -------
tons per year) of sweating capacity and 4,990 metric tons per year (5,500
short tons per year) of distilling capacity.

          In the industry cost model, costs for baghouses are applied 'to
the sweating and distilling capacities of the respective large and small
model plants.  Some uncertainty exists in the factors of utilization rate
of reported capacity and multiple product lines (slab, dust, and oxide);
however, the estimated costs given in Table A6.12.1 are judged to represent
the costs of control at recent production levels.
                                  A6.12-3

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    -------
                   Chapter A7.  Mineral-Based Industries


          For the purposes of this report, the Mineral-Based Industries are
defined as those establishments which gather, process,  and prepare
materials to be used in the construction industry.   Wood products are
specifically excluded; these are covered in Chapter 9.   The industrial
sectors covered in this chapter are the:

          •  Cement Industry
          0  Structural Clay Products Industry
          •  Lime Industry
          •  Asphalt Concrete Processing
          •  Asphalt Roofing Manufacture

          Costs for the abatement of air pollution  for  these industries are
summarized in Table A7.  These costs and other data are repeated below  in
the appropriate section together with the assumptions and other details
specific to each industrial sector.
                                   A7-1

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    -------
                       Chapter A7.1  Cement Industry

          Revision of this chapter was limited to adjusting the pollution
control  costs to 1981 dollars and editing the discussion of regulations.

Regulations

          The NSPS for port!and cement plants (40 CFR 60.60) was
promulgated on December 23, 1971.  The regulation sets particulate and
opacity limits for cement kilns and clinker coolers, and opacity limits for
several  other affected facilities in port!and cement plants.

          The cement industry is also subject to SIP particulate standards.
Most states have general  process weight standards patterned after Appendix
B (40 CFR 51, App. B).

Industry Characteristics

          Portland cement, which accounts for approximately 96 percent of
cement production in the  United States, is  processed from a blend of
various calcareous, argillaceous, and siliceous materials including
limestone, shell chalk, clay, and shale.   As the binder in concrete,
Portland cement is the most widely used construction material  in the United
States.   The four major steps in producing  portland cement are:   quarrying
and crushing; blending, grinding, and drying; heating the materials in a
rotary kiln to liberate carbon dioxide and  cause incipient fusion; and
fine-grinding the resultant clinker, with the addition of 4 to 6 percent
gypsum.   Finished cement  is shipped either  in bulk or in bags.  All
Portland cement is produced by either wet or dry grinding processes, the
distinguishing characteristic being whether the raw materials  are
introduced into the kiln  as a wet slurry  or as a dry mixture.

          In 1971, 170 plants producing portland cement clinker, plus five
plants operating grinding mills to produce  finished cement, were controlled
by 51 companies and were  located in 41 states and Puerto Rico.  These
plants had an annual capacity of 79.5 million metric tons (87.7  million
tons).

          By 1977 (year end), some 160 plants were in operation  with an
annual capacity of 87.5 million metric tons (96.4 million short  tons).
Fifty percent of this cement industry capacity is owned by multiplant
companies, and the eight  leading companies  account for about 47  percent of
the total.  Overcapacity  has resulted in  low profit margins and  has
inhibited modernization and construction  of new plants.  More  stringent
air-pollution regulations have increased  both capital and operating costs.
Recent trends are toward  an increase in utilization.  Typical  utilization
is about 80 percent.  Recent trends are toward increased operations through
installation of larger kilns to replace older marginal kilns,  permitting
more economic and efficient pollution control.  The cement manufacturing
plant capacity and size distribution are  given in Table A7.1.1.

                                  A7.1-1

    -------
Table A7.1.1.  Cement Manufacturing Plant Size Distribution
(capacities in metric tons with short tons in parentheses)
Annual capacity
range (1000)
Less than 181
(less than 200)
181-363.1
(200-400)
363-544
(400-600)
544-726
(600-800)
726-907
(800-1000)
Greater than 907
(1000)
Totals
No.
plants
4
43
47
38
8
20
160
Total annual
capacity
1000
603
(665)
12,061
(13,298)
21,303
(23,487)
24,037
(26,502)
6,483
(7,148)
23,030
(25,392)
87,521
(96,495)
Total
capacity (
0.7
13.8
24.3
27.5
7.4
26.3
100.0
                          A7.1-2

    -------
          Size distribution is expected to shift upwards as new plants are
constructed and existing plants modified or closed, so the total number of
plants is expected to remain about the same.  It is also assumed that there
will be no major shift in production capacity percentages between dry and
wet grinding processes, with the latter presently estimated at 56 percent.

Pollutants and Sources

          Primary emission sources are the dry-process blending and
grinding, kiln operation, clinker cooler, and finish grinding.  Other
sources include the feed and materials-handling systems.  The primary air
pollutant is dust particulates.  The estimated dust-emission factor for an
uncontrolled dry-process kiln is 122 kg per metric ton (244 pounds per
short ton) of cement, compared with 114 kg per metric ton (228 pounds per
short ton) for the wet-process plant, giving a weighted average emission
factor of 118 kg per metric ton (236 pounds per short ton) of product.  The
corresponding emission factors for the blending, grinding, and drying
processes are 48 kg (dry) and 16 kg (wet) per metric ton (96 and 32 pounds
per short ton), respectively, for a weighted average of 32 kg per metric
ton (64 pounds per short ton).

Control Technology

          Emissions from the blending, grinding, and drying process are
generally controlled with fabric filters.  Where ambient gas temperatures
are encountered during grinding, conveying, and packaging processes, fabric
filters are used almost exclusively.  The greatest problems are encountered
with high-temperature gas streams which contain appreciable moisture.

          Both fabric filters and electrostatic precipitators are used in
controlling dust emissions from the kilns.  Condensation problems from the
high-moisture content in the wet-process plant may be overcome by
insulating the ductwork and preheating the systems on start-up.  Current
State regulations may be met either with fabric filters or with
electrostatic precipitators; however, fabric filters may be required to
meet emissions limits established by the NSPS.  At least one plant has a
wet scrubber, but costs for the plant were estimated on the basis of an
electrostatic precipitator.

Costing Methodology

          The total cost of control for portland cement plants was found by
estimating the costs for control devices for grinding, mixing and drying
(drying not included in the wet process) and/or kilns, which are the major
sources of pollutants.  Baghouses are used for dry-process kilns and
electrostatic precipitators for wet-process kilns.  Baghouses were assumed
to have been used for the combined grinding, mixing, and drying processes.
Other sources, including clinker coolers, packaging, and crushing, are not
costed due to prevailing industry control prior to the 1970 Clean Air Act
and/or minimal costs.

          The capital cost of baghouses is assumed to be proportional to
the 0.91 power of capacity, while the capital cost of electrostatic

                                  A7.1-3

    -------
precipitators is proportional  to the 0.67 power of capacity, in each case
the operating cost is linearly proportional  to the capacity.  The cost of
baghouses for the grinding, mixing, and drying operations was scaled in t
same manner.   However, the required size was scaled by 0.78 (dry) and 0.2
(wet) to account for the smaller airflow rates of these processes, and th<
absence of control required for the wet-process raw material grinding
mills.

          Control costs for the cement industry are detailed in Table
A7.1.2.  It should be noted that only costs  for new sources are indicated
reportedly all existing plants are in compliance with State Implementatio
Plans.  (EPA report FR-41U-649, August, 1972).
                                  A7.1-4

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    -------
              Chapter A7.2  Structural Clay Products Industry

          Revision of this chapter was limited to adjusting the pollution
control costs to 1981 dollars and editing the discussion of regulations.

Regulations

          No NSPS covers the structural clay products industry.  SIPs
regulate sulfur dioxide, hydrocarbon, and carbon monoxide emissions from
facilities in this industry.  The SIP limits, which are often patterned
after RACT standards in Appendix B (40 CFR 51, App. B), apply to general
process industries and are expressed as concentrations, gas volumes, or
process weight rates.

Industry Characteristics

          In 1978, 466 plants in the United States manufactured structural
clay products, including common brick, fireclay or refractory brick, and
sewer pipe.  The brick category represents approximately 90 percent of the
total production of structural  clay materials, with common brick being by
far the largest category, representing approximately 75 percent of total
production.  Plants are located in 45 states with North Carolina, South
Carolina, Ohio, Pennsylvania, and Texas accounting for about 45 percent of
production capacity.

          For purposes of estimating air abatement costs, the industry was
divided into those plants using either continuous tunnel kilns or batch
kilns; an average plant capacity was selected for each process, as shown in
Table A7.2.1.

          Miscellaneous clays and shales are used to manufacture common
brick, sewer pipe, and refractory brick.  Typically, the plants are located
in the proximity of the clay mines.   The clays are crushed and ground at
the plant, after which they are screened and mixed with water for the
forming operation.  Common brick, sewer pipe, and some refractory brick are
formed by extrusion; most refractory brick are formed by die pressing.

          The formed materials  are fire-treated by either continuous tunnel
or intermittent periodic kiln processes.  In the continuous tunnel kiln,
the charge is preheated by airflow escaping from the bake oven, passed
through the oven at temperatures of approximately 1,050 C (1,900 F), then'
passed through a cooling stage.  In contrast, the periodic kiln heats the
charge from ambient temperature to a peak temperature, after which the fuel
is shut off, allowing the charge to cool to ambient temperature again; this
cycle requires about 2 weeks, during which fuel is burned about 50 percent
of the time.  The remainder of  the period is used for cooling and physical
discharging of the product, steps which emit few, if any, air pollutants.
                                  A7.2-1

    -------
       Table A7.2.1  Plant distribution assumed for structural  clay
          industry (capacity in  thousands  of metric tons  per year
           with thousands  of short tons per year in parentheses)
                                             Estimated 1974
                       Average       No.         capacity           Total
                      capacity     plants       (thousands)      capacity (
Periodic kilns
Continuous Tunnel
  kilns
  21
 (23)
 100
(110)
336
130
  6.9
 (7.6)
 12.9
(14.2)
35
65
Total
              466
             19.8
            (21.8)
                   100
                                  A7.2-2

    -------
          A process frequently practiced by manufacturers of common brick
is flashing.  This process involves firing the brick in a reducing
atmosphere to achieve architecturally desirable surface colorations.  The
process is noted because when it is used in conjunction with periodic
kilns, carbon monoxide and/or hydrocarbon emissions usually result.

Pollutants and Sources

          Atmospheric emissions from the manufacture of clay construction
products are primarily sulfur dioxides released during the firing process.
These originate from the sulfur contained in the clay and in the fossil
fuels consumed in the firing operation.  Uncontrolled sulfur dioxide
emissions are estimated to be about 3.7 kg per metric ton (7.4 pounds per
short ton) of clay processed.  The flashing process associated with the
manufacture of certain types of brick can also result in hydrocarbon and
carbon monoxide emissions.  Approximately 4.2 kg of hydrocarbons and/or
carbon monoxide are estimated to be released per metric ton (8.4 pounds per
short ton) of brick flashed.

Control Technology and Costs

          It is anticipated that wet scrubbers will be used to control
sulfur dioxide emissions from the production of clay construction
materials.  Only a few plants were found to be exercising this or any other
control option.  Hydrocarbon and carbon monoxide emissions can be
controlled by using afterburners.  The requirement for afterburners will
depend on the duration of the flashing treatment at different plants.-
Likewise, it is probable that certain plants will  have minimal requirement
for scrubbers because of the negligible sulfur content of some clays.
About 10 percent of existing plants producing common brick, sewer pipe, and
refractory brick were assumed to be either equipped with adequate controls
or using new clay materials sufficiently low in sulfur content to avoid the
need for wet scrubbers.

          Costs and industry operating statistics  are detailed in Table
A7.2.2.
                                  A7.2-3

    -------
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  Chapter A7.3  Lime Industry
this chapter was limited to adjusting the pollution
dollars and editing the discussion of applicable
          Revision of
control costs to 1981
regulations.

Regulations

          The NSPS for lime manufacturing plants (40 CFR 60.340) was
promulgated on March 7, 1978.  The regulation set particulate and opacity
limits for rotary lime kilns and particulate limits for lime hydrators.
Following a review of this NSPS, EPA proposed a revision on September 2,
1982, that would relax the particulate limit and exempt lime hydrators from
the standard (47 FR 38831).

          States set general particulate emission standards, which apply to
lime plants.  Most SIPs are patterned after the general process weight
table in Appendix B (40 CFR, 51 App. B).  Only a few states (e.g.,
Pennsylvania and Iowa) have regulations with specific limits on lime
manufacturing emissions.

Industry Characteristics

          As of 1977, there were 162 lime-producing plants in the United
States.  These plants can be divided into seven size ranges, based upon
production; the number of plants in each size range and their estimated
production are shown in Table 7.3.1.

          The U.S.  lime industry can be conventionally divided into two
product sectors.  Approximately 22 percent of the output is consumed by the
producers, while the remaining 78 percent is sold in the open market.
Plants are located in 41  states and Puerto Rico.  Over 22 percent of U.S.
capacity is in Ohio, and  other major capacities are located in
Pennsylvania, Texas, and  Michigan.  Recent trends are toward the closing of
small, old plants and replacing old kilns with larger units.

          In 1977,  producers at 162 plants sold or used 18,1 million metric
tons (19.9 million  short  tons), according to the Bureau of Mines, U.S.
Department of Interior.  This was a 1 percent decrease from 1976, and 8
percent below the 1974 record.

          Should the use  of lime in processes for the removal  of sulfur
oxides from combustion gases become standard practice, the demand for lime
will be increased substantially.  The number of plants, meanwhile, has
declined from 195 in 1970 to 162 in 1977.  Further consolidation may be
expected to economically  justify the increased cost of emissions controls.
            A7.3-1

    -------
       Table A7.3.1.  Lime  Industry Production Distributions  in 1977
           in  Thousands of  Metric Tons Per Year  (with thousands
                 of  short  tons per year  in parentheses)
Size range
0-9
(0-10)
9-23
(10-25)
23-45
(23-50)
45-91
(50-100)
91-181
(100-200)
181-363
(200-400)
More than 363
(More than 400)
Total
No.
plants
22
27
32
21
24
28
8
162
Estimated 1977
production (1,000)
112
(124)
419
(462)
1,050
(1,158)
1,429
(1,575)
3,310
(3,649)
6,390
(7,640)
4,879
(5,378)
18,128
Perce
of tot.
1
2
6
8
18
38
27
100
Source:   Mineral  Industry  Surveys,  Bureau  of Mines,  1977.
                                 A7.3-2

    -------
          Lime is formed by expelling carbon dioxide from limestone or
dolomitic limestone by high temperatures.  This calcination process forms
quicklime.  Hydrated lime is made by the addition of water to the
quicklime.  The calcination of dolomite results in dead-burned (refractory)
dolomite.

          Major uses of lime are for basic oxygen steel furnaces, alkalies,
water purification, other chemical processes, and refractory dolomite.

          About 70 percent of lime is produced in two basic types of rotary
kilns:  the long rotary kiln, and the short rotary kiln with external
preheater.  Vertical kilns are used to supply 28 percent of lime.  Almost
all new lime production is done using the rotary process.

Pollutants and Sources

          Atmospheric emissions from lime manufacture are primarily
particulates released when crushing the limestone to kiln size, calcinating
the limestone in a rotary or vertical kiln and crushing the lime to size;
also, fly ash is released if coal is used in calcination.  Other emissions,
such as sulfur oxides, may be generated by fuel combustion.

          Uncontrolled emissions from rotary kilns are about 170 kg per
metric ton (340 pounds per short ton) of lime processed, compared with 4 kg
per metric ton (8 pounds per short ton) from vertical kilns.  However,
economics favor use of the rotary kiln, and virtually all new and expanded
production is expected to use this method.

Control Technology and Costs

          Gases leaving a rotary kiln are usually passed through a
dust-settling chamber where the coarser material settles out.   In many
installations, a first-stage, primary dry cyclone collector is used.  The
removal efficiency at this stage can vary from 25 to 85 percent by weight
of the .dust being discharged from the kiln.

          The selection of a second stage to meet a high efficiency level
of 23 mg per actual cubic meter (0.01 grain per actual  cubic foot) may be
either a high-energy wet scrubber, fabric filter, or electrostatic
precipitator.  The higher capital cost of the electrostatic precipitator
may be more than offset for specific installations by lower operating and
maintenance costs.

          It is believed that vertical kilns can be effectively controlled
to allowable emission limits with baghouses, scrubbers, or cyclone/scrubber
combinations.  In the latter cases, efficiencies of 99 percent have been
reported.

Industry Cost Model

          The industry cost model was based on production levels and plant
populations from Bureau of Mines data.  Eighty percent of the total U.S.


                                  A7.3-3

    -------
production was considered to be commercial, independent operations based c
a recent EPA estimate (NSPS Support Document).   The costs for the twenty
percent of production by captive plants are covered by other chapters (Ire
& Steel, Paper).  Vertical  kiln capacity has been constant since 1969 (ze
growth).  Baghouses were considered the predominant methods of control (6(
percent) with some wet scrubbers and ESPs being used (20 percent each).
The resulting estimated costs are listed in Table A7.3.2.
                                  A7.3-4

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    -------
                 Chapter A7.4  Asphalt Concrete Processing


          Revision of this chapter was limited to adjusting the pollution
control costs for 1981 dollars and rewriting the discussion of applicable
regulations.

Regulations

          The NSPS for asphalt concrete plants (40 CFR 60.90) was
promulgated on March 8, 1974.  The regulation sets particulate and opacity
limits for dryers; screening and weighing systems, storage, transfer, and
loading systems; and dust handling equipment.

          General particulate limits in SIPs apply to this industry.  Most
states pattern these regulations on the suggested RACT standards in
Appendix B (40 CFR 51, App. B).

          The asbestos NESHAP (40 CFR 61.20), which was promulgated April
6, 1973, prohibits visible emissions of asbestos from the manufacture of
asphalt concrete.  Compliance with SIPs or NSPS virtually assures
compliance with this NESHAP.

Industry Characteristics

          Asphalt concrete comprises a mixture of aggregates and an asphalt
cement binder.  Aggregates usually consist of different combinations of
crushed stone, crushed slag, sand, and gravel.  Asphalt concrete plant
processing equipment includes raw-material apportioning equipment, raw
material conveyors, a rotary dryer, hot-aggregate elevators, mixing
equipment, asphalt-binder storage, heating and transfer equipment, and
mineral-filler storage and transfer equipment.

          About 4,400 asphalt concrete plans in the United States directly
employ about 15,400 people.  In 1975, production was estimated to be 265
million metric tons (292 million short tons).  Based on a 1974 survey
conducted by the National Asphalt Pavement Association (NAPA) covering 960
plants, 78 percent were stationary plants and 22 percent were portable.
Continuous mixers comprised 27 percent of the portable plants, compared
with only 4 percent for stationary plants.

          Estimation of the size distribution of plants is difficult
because of a lack of data.  Of the plants surveyed by NAPA, 12 percent were
less than 98 metric tons per hour (108 short tons per hour) capacity at
average moisture condition.  About 60 percent were between 99 and 198
metric tons per hour (109 and 218 short tons per hour) and 28 percent were
larger than 198 metric tons per hour (218 short tons per hour).   The
average size was 160 metric tons per hour (176 short tons per hour).  The
balance of the industry, 80 percent of the plants, has only 75 percent of


                                  A7.4-1

    -------
the capacity.   By difference, the average for these plants is 94 metric
tons per hour  (104 short tons per hour).   The overall  industry average is
110 metric tons per hour (121 short tons  per hour).

          Plants operate an average of only 666 hours  per year because of
the seasonal  and intermittent nature of the work.   Asphalt concrete
production is  essentially a batch-type operation;  continuous mix
represents, at most, 10 percent of the industry.

Pollutants and Sources

          The  predominant emissions are dust particulates from the
aggregates used in making asphalt concrete.  The largest sources of
particulate emissions are the rotary dryer and screening, weighing, and
mixing equipment.  Additional sources that may be  significant particulate
emitters, if they are not properly controlled, are:  the mineral-filler
loading, transfer, and storage equipment; and the  loading, transfer, and
storage equipment; and the loading, transfer, and  storage equipment that
handles the dust collected by the emission-control  system.  Generally, th
uncontrolled emissions .from asphalt batching plants amount to 22.5 kg of
dust per metric ton (45 pounds per short  ton) of product.

Control Technology

          Practically all plants use primary dust  collection equipment,
such as cyclones or settling chambers.  These chambers are often used as
classifiers with the collected aggregate  being returned to the
hot-aggregate  elevator to combine with the dryer aggregate load.

          The  gases from the primary collector must be further cleaned
before venting to the atmosphere.  To meet SIP requirements, 98.3 percent
abatement is sufficient.  This can be achieved by  the  use of multiple
centrifugal scrubbers.  NSPS issued in 1975 allow  no more than 90 mg/dscn
(0.04 grain per cubic foot) of particulates or any opacity greater than 2
percent.  In effect this requires the use of a high energy scrubber or a
fabric filter (baghouse).  The most common secondary collector used to me
NSPS is expected to be the baghouse, although venturi  scrubbers are used
some plants.   The baghouse allows dry collection of dust which can be
returned to the process or disposed of in a landfill.   The venturi scrubb
makes dust hauling expensive due to the wetting of the dust.  Also, the u
of large settling ponds and the possible  need for  water treatment
discourage the use of venturi scrubbers.

Costing Methodology

          The industry cast model developed from data  discussed above
covers about 4400 plants (in 1974) with growth rates in the range from 4.
to 1.3 percent in the future.  Sixty percent of the industry was estimate
to use baghouses and 40 percent to use wet scrubbers.   The estimated cost
of compliance, based on this model, are given in Table A7.4.1.
                                  A7.4-2

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                    A7.5.  Asphalt Roofing Manufacture

          This chapter describes the cost to the asphalt roofing industry
of complying with air pollution control regulations.  Revisions of the
chapter includes an update of industry data, redevelopment of SIP costs,
development of costs for the NSPS that was proposed in late 1980, and
estimation of credits due to produce recovery.

Industry Characteristics

          The asphalt roofing industry produces asphalt roofing and siding
products (shingles and rolls) and saturated felts.  The primary raw
materials are asphalt, dry felts and minerals.

          In 1977, there were 110 plants producing 9.5 million tons of
asphalt roofing and siding per year.  Roofing accounted for 90 percent of
production; siding accounted for the remainder.  The distribution of
production by region is fairly uniform—one-third each in the North Central
and Southern regions, and the remainder about equally divided between the
Northeast and the West.  The value of product shipments of this industry,
which is classified into SIC 29523 (Prepared Asphalt and Tar Roofing and
Siding Products) totalled $1.9 billion in 1977.

          Between 1972 and 1977, the number of plants increased from 102 to
110, but production remained relatively stable.  Demand for roofing- and
siding has been stable because it is dependent on both the demand for new
construction and the demand for building renovation.  When new construction
demand falls, renovation and remodeling demand generally rises so that the
demand for roofing and siding is noncyclical.

          Asphalt is a residual  of oil  refining.  Fifteen percent of
asphalt production is used to manufacture asphalt roofing and 80 percent,
asphalt paving.  About one-third of firms that own asphalt roofing plants
also produce asphalt.

          Since the primary raw material  is an oil derivative, the price of
asphalt roofing is a function of the price of oil.  Increases in the price
of oil, which subsequently produce increases in the price of asphalt
roofing, have depressed the demand for asphalt roofing.   No growth is
expected for the industry during the next several  years.

Pollutants and Sources

          The production of asphalt roofing shingles and felts involves
saturating fiber media with asphalt.  Raw asphalt (asphalt flux) is  first
prepared by an air "blowing" or dehydrogeneration process in a blowing
still.  Asphalt roofing plants either operate their own blowing stills or
purchase prepared asphalt.   The products  of the blowing operation are
asphalt saturant and coating asphalt.  Asphalt saturating machines saturate


                                  A7.5-1

    -------
felts with hot asphalt saturant by either spraying or dipping or by a
combination of spraying followed by dipping.   The saturated felt passes t<
a wet looper where saturant asphalt continues to saturate the felt.  For
surfaced products, a coater coats felts with  a mixture of coating asphalt
and mineral stabilizers, called fillers (e.g., lime, silica, and slate).
Mineral surfacing materials, either parting agents (talc or sand) or
granules, are applied to surfaced products for protection.

          Inorganic and organic particulate matter and gaseous hydrocarbo
are the primary pollutants from asphalt roofing plants.  There are also
small amounts of carbon monoxide, sulfur dioxide, and aldehydes.  The maj<
source of gaseous hydrocarbon emissions is the asphalt blowing still.  Th<
sources of particulate emissions are asphalt  blowing stills (for plants
that operate them), saturators, wet loopers,  coaters, asphalt storage
tanks, and mineral storage bins.

Regulations

          SIPs.  Most states in which asphalt roofing plants are located
have particulate standards for all types of process emission sources.
These regulations are similar to RACT process rate tables (40 CFR 51, App
B).  Volatile organic compound (VOC) standards are patterned after
suggested RACT standards in Appendix B or Los Angeles Rule 66 for organic
compound emissions from organic solvents.  By 1977, only twenty states ha<
included VOC standards in their SIPs.  The 1977 Clean Air Act Amendments
require that the remaining states with ozone  nonattainment areas revise
their SIPs to include VOC regulations.

          NSPS.  The NSPS for asphalt processing and asphalt roofing
manufacture was proposed November 18, 1980 (45FR764Q4).  It includes
particulate emission standards for blowing stills and saturators and
opacity standards for blowing stills,, saturators, asphalt storage tanks,
and mineral handling and storage areas.  The  particulate limits for blowi
stills vary according to the type of blowing  process, either conventional
or catalytic, and the type of fuel oil fired  in the afterburner.

Control Technology

          Control systems applied to asphalt  roofing plants include vario
types of hoods, enclosure capture systems, and add-on control devices.  T
most commonly used control devices are afterburners, high velocity air
filters (HVAFs), electrostatic precipitators  (ESPs), cyclones, and fabric
filters.

          Afterburners incinerate both particulate and gaseous VOC
emissions from blowing stills, saturators, coaters, and asphalt storage
facilities for compliance with both SIPs and  NSPSs.  HVAFs and ESPs can
control particulate emissions from saturators and coaters to meet SIP and
NSPS requirements.  Control of inorganic particulate matter from filler
surge artd parting agent bins is achievable with cyclones for SIP compliant
and fabric filters for NSPS compliance.  The  afterburners recover heat,
which may be used for many plant processes, and the collection devices
                                  A7.5-2

    -------
recover both hydrocarbons and minerals, which are in the form of filler and
parting agent.

          Compliance with SIPs requires about 80 percent removal efficiency
for controls on blowing stills, filler surge bins, and parting agent bins
and more than 90 percent efficiency for controls on saturators and coaters.
NSPS compliance requires from 93 to over 98 percent removal  efficiency for
controls on all emission sources.

          Existing asphalt plants are assumed to comply with SIPs by 1982
as more states  establish hydrocarbon regulations in their SIPs.  New and
modified plants beginning operation in 1982 are assumed to comply with the
NSPS upon completion.

Costing Methodology

          Table 7.5.1 reports the control devices and removal efficiency
assumed for costing the compliance of each emission source with SIPs and
NSPS.  The SIP  controls include a HVAF with hood, fan, and duct on the
saturator, wet  looper, and coater; cyclones on the filler and parting agent
bins; and an afterburner on the blowing still.  The NSPS costs assume a
HVAF with full  enclosure hood, fan, and water spray cooler on the
saturator, wet  looper, and coater and on the asphalt storage tanks;
baghouses on the filler and parting agent bins; and an afterburner on the
blowing still.   The removal efficiency levels are assumed to be sufficient
for meeting each regulation, as described in the previous section.  The
largest one-third of the plants are assumed to operate their own blowing
still.

          Total costs for controls on asphalt roofing plants are presented
in Table A7.5.2.  Capital and O&M cost equations were developed from data
on costs for SIP and NSPS controls for three model plant sizes as reported
in the Environmental Impact Statement background document for the proposed
NSPS (EPA 450/3-80-021a).  Separate credit equations were also developed
from this document to account for the value of products recovered with the
pollution control devices.  Both costs and credits are expressed as a
function of total annual production in thousands of tons.
                                  A7.5-3

    -------
             Table 7.5.1,
Control  devices costed for asphalt
 roofing operations
    Emission Source
    Controls and Control  Device Efficiency
                                    NSPS
Saturator, wet looper,
  and coater
Filler surge bin
  and storage

Parting agent bin
  and storage

Asphalt storage
Blowing still
    HVAF*, 93.3%, with
    hood, fan and duct
    Cyclone, 80%


    Cyclone, 80%
    Afterburner with
    heat recovery,
    77.7%, with duct
    and fan
HVAF*, 93.3%, wit
full enclosure hoi
ducts, fan, and
water spray coole

Baghouse, 98.4%,
with duct and fan

Baghouse, 98.4%,
with duct and fan

HVAF*, 93.3%, wit
full enclosure ho>
ducts, fan, and
water spray coole

Afterburner with
heat recovery,
93.9%, with duct
and fan
*HVAF - high velocity air filter.
                                 A7.5-4

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    -------
            Chapter A3.   Manufacturing and'Services Industries


          The subject group of industries include the following categories

             Paint Manufacturing Industry
             Surface Coatings
             Dry Cleaning Industry
             Printing Ink Manufacture
             Synthetic Fiber (Nylon) Manufacture
             Lead-Acid Storage Batteries

          These types of activities have in  common the characteristics of
(1) not being based on primary raw materials, their starting materials
being manufactured items and (2) generating  similar types of emissions,
i.e., solvents and other hydrocarbons.

          Costs for the  control  of air pollution in these industries are
given in summary form in Table A8.  The specific aspects and costs of air
pollution control  for the individual industry segments are given in more
detail in the following  sections.
                                   A8-1

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                Chapter A8.1  Paint Manufacturing Industry


          Revision of this chapter included adjusting pollution control
costs to 1981 dollars, updating industry data, and editing the discussion
of regulations, industry characteristics, and emission sources and
pollutants.

Regulations

          No NSPS have been developed for paint manufacturing nor are any
scheduled.  SIPs regulate both VOC and particulate emissions from this
industry.

          An increasing number of states are adopting general VOC
regulations for industries, such as paint manufacturing, for which no CTG
is available.  These regulations are generally patterned after Los Angeles'
Rule 66 or Appendix B (40 CFR 51, App. B).   Both of these regulations have
pounds-per-day and pounds-per-hour limits,  but compliance is achieved if 85
percent control is demonstrated.  Appendix  B suggests the use of
incineration or carbon adsorption to achieve this level  of emission
reduction.

          Most states also pattern their general particulate standards
after the suggested RACT process weight tables in Appendix B.

          The asbestos NESHAP (40 CFR 61.20), promulgated April 6, 1973,
prohibits visible emissions of asbestos from the manufacture of paints and
coatings.  Compliance with the asbestos NESHAP is achievable with
particulate controls.

Industry Characteristics

          In 1977, 1300 companies operated  1600 paint manufacturing plants,
approximately the same number as were operated in 1972.   Production of
paint increased at an annual rate of 1.2 percent from 927 million gallons
in 1972 to 1,040 million gallons in 1981.  Production is expected to rise
by only 0.1 percent annually in the 1980's.

          Of 1,700 plants operated in 1978, only 653 had more than 20
employees.  Based on 1972 figures, the largest 33 percent of plants account
for 89 percent of paint production.  It "is  these larger  plants whose
control costs are included in this chapter.  The emissions levels of the
smaller plants are low enough that they are exempt from  regulations.

          The VOC emission rate is substantially lower in the production of
water-based than for solvent-based paints.   Control  costs in this chapter
are given only for the solvent-based paint  manufacturing process.   Of total
paint production, about 78 percent is organic solvent-based, and the


                                  A8.1-1

    -------
remainder is water-based.  This proportion is expected to remain relative!
constant through the 1980's.

          Paint manufacturing is classified into SIC 2851 (Paints,
varnishes, lacquers, enamels, and allied products).  The value of shipment
for the entire SIC was $6.6 billion in 1977.

Pollutants and Sources

          Paint manufacturing involves mixing or dispersing pigments in
oil, resin, resin solution, or latex at room temperature.  Mixing is then
followed by the addition of specified proportions of organic solvents or
water to obtain the desired viscosity.

          Air pollutants from paint manufacturing are VOCs originating frc
organic solvents and particulates from paint pigments.  About 1.8 pounds c
particulates are emitted per short ton of pigment dispersed while the
emissions of hydrocarbons are 30 pounds per short ton of pigment.

Control Technology and Costs

          Reduction of hydrocarbon emissions from paint production by 85
percent, which will meet all  SIPs, may be accomplished by flame combustior
thermal combustion, catalytic combustion, or adsorption.  Thermal
combustion (with heat exchange) is considered the most feasible method of
control; equipment incorporating heat-exchange devices was chosen because
of currently anticipated future fuel shortages and assumed removal
efficiencies of 95 percent.  Catalytic combustion units, while highly
promising from the standpoint of lower fuel requirements (but higher
initial investment costs),  still present technical operating problems.
Baghouses (fabric filters)  are suitable for control of particulates
emissions from pigments; particulate removal efficiencies of more than 95
percent are readily achieved.

          Estimates for air-pollution control  for the total  industry were
based on assumed compliance by plants averaging about 7.95 million liters
(2.1 million gallons) of paint production per year; about 520 plants of
this capacity were assumed  to be in operation.  Future cost predictions a
complicated by the emergence  of technological  trends away from the use of
solvent-based paints.  Control costs are aggregated in Table A8.1.1.
                                  A8.1-2

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                       Chapter A8.2  Surface Coating

          This chapter provides emission abatement costs associated with
the use of organic solvent-borne surface coatings for the following four
industries.

          •  Automobiles and light-duty trucks
          •  Metal furniture
          •  Large appliances
          t  Metal coil coatings

These industries are considered together because of similarities in the
coating processes employed, the nature of the resulting emissions, ana the
applicable control technologies.  The chapter includes cost estimates for
controlling VOC emissions to comply with both SIPs and NSPS.

          This chapter has been revised to include the metal furniture
industry and to update industry data for costing compliance with NSPS and
current SIPs.  Beverage can coating, for which an NSPS has been proposed,
is not included in this report.  Can coating emission control costs should
be considered in the next version of this report.

Industry Characteristics

          In 1980, approximately 96 million gallons (363 million liters) of
surface coatings were consumed by the following four industries:
automobiles and light duty trucks, metal furniture, major appliances and
metal coil coatings.

          A discussion of the specific industries follows.

          Automobiles and light-duty trucks.  In 1980 6,375,506 automobiles
(SIC 3711) were assembled at 43"plants.Twenty-six percent of total output
was produced in Michigan, 9.5 percent in Ohio, and 8.2 percent in Missouri.
Fourteen other states accounted for the remaining 56.5 percent.

          About 75 percent of total truck production (SIC 3713) consists of
light-duty trucks, vehicles weighing 8500 pounds or less.  Light-duty truck
production was estimated to be 1,465,894 in 1980, with production taking
place at 20 plants.  Michigan accounted for about one-quarter of truck
production, Ohio accounted for 15 percent, Missouri for 13 percent, and
Kentucky for 8 percent.  Twelve other states accounted for the remainder.

          This chapter estimates pollution control costs for the 51 plants
which produce automobiles and/or light-duty trucks.  These plants consumed
approximately 43 million gallons of surface coatings in 1980.  This level
of consumption is expected to remain relatively constant through 1990.   In
addition to the number of vehicles produced, three factors have affected
the volume of coatings used by this industry.   First, there has been a
significant increase in the use of precoated metal. This decreases the


                                  A8.2-1

    -------
amount of coatings applied by the vehicle manufacturer.   Second, automobi'
size is decreasing, although this factor may be offset by the application
of more paint per car for better durability and corrosion-resistance.
Third, plastic parts that do not need a coating have already found much u<
in interior applications and are being developed for more exterior
applications.

          Metal Furniture.  The metal furniture industry consists of the
following categories:

          •  Metal household furniture (SIC 2514)
          t  Metal office furniture (SIC 2522)
          •  Public building and related furniture (SIC 2531)
          •  Metal partitions and fixtures (SIC 2542)

In 1976, about 1400 establishments made shipments  of metal furniture value
at $3,657 million.  Over half of those establishments were located in New
York, California, Illinois, Pennsylvania, and Ohio, with the rest being
spread throughout the country.

          Manufacturers of metal furniture used about 20 million gallons c
surface coatings in 1980.  Industry growth depends on factors such as the
number of new households, office building and remodeling construction, an<
government spending (for public facilities).  EPA  documents estimate an
annual growth rate of 4 percent in shipments through 1985.

          Large Appliances.  In 1978, 95 companies operated 171 plants
involved in the production of large appliances.  They are classified as
follows:

          *  Household cooking equipment (SIC 3631)
          •  Household refrigerators and home and  farm freezers (SIC 3632
          •  Household laundry equipment (SIC 3633)
          •  Household appliances, not elsewhere classified (SIC 3639)

          These plants, located in 29 states, consumed approximately 13.5
million gallons of surface coatings in 1980.  Their 1977 shipments were
valued at $7,269 million with approximately 32,600,000 units produced.

          Annual growth in shipments from 1967 to  1977 was about 3.0
percent, and economists predict an annual growth rate of about 2.6 percen'
through the 1980's.  Growth will probably be in the production of
dishwashers, trash compactors and microwave ovens, items that are far fro
the market saturation point.

          Coil Coating.  Coil coating is the application of organic
coatings to flat metal sheet or strip that is packaged in rolls or coils.
Coil coating (a small part of SIC 3479) is performed in approximately 109
plants with 147 coating lines.  The plants are typically located in or ne«
industrial areas.  One-half of the plants are located in Illinois, Ohio,
Pennsylvania, and California.
                                  .AS.2-2

    -------
          In 1977, North American shipments of coated metal coil were
approximately 4 million tons (3.63 million Mg) and were valued at $3.5
billion.  About 19 million gallons of surface coatings were used in coil
coating in 1980.  Major markets for coil coated metal include the
transportation industry, the building products industry, and the packaging
industry.   Industry spokesmen indicate that large appliance manufacturers
will also begin to make greater use of precoated metal stock.

          The continual emergence of new end uses for the product enabled
the industry to maintain a 10 percent average annual growth rate (in square
meters of metal coated) between 1968 and 1977.  The average growth rate
from 1970 through 1980 was 5.2 percent.   A 12 percent growth rate is
forecast for the 1980s.

Pollutants and Sources

          The surface coating process consists basically of three steps:
application of the coating, air drying of the product after application
(flashoff), and curing in an oven.  All  stages produce VOC emissions
through evaporation of the organic solvent in the coating.  The coatings
may be applied by spray (the most commonly utilized method), dip, flow, or
roller processes.  About 60 percent of all the paint, shellac, lacquers,
and primers used in 1980 were organic solvent-borne.

          The volume of VOC emissions depends on coating content,
application efficiency (which can vary from 10 to 100 percent), and add-on
pollution controls, if any.  The major sources of coating process emissions
are usually the spray booth and its associated flashoff area.

Regulations

          SIPs.  Many of the early SIPs  regulated VOC emissions from
organic solvents either by setting limits on pounds per hour and pounds per
day or by requiring that 85 percent control be demonstrated.  These SIPs
were patterned after Appendix B in the Code of Federal Regulations (40 CFR
Part 51, Appendix B) or LA Rule 66 (the  latter listed some solvents which
were exempt from regulation).  Some states also regulated surface coating
facilities by a permit system, i.e., on  a plant-by-plant basis.

          Some newer SIPs are patterned  after RACT described in EPA's
Control Technique Guideline (CTG) documents.  These SIPs establish, by
industry, allowable VOC emissions per volume of coating solids applied..
The state regulations of Michigan and Missouri contain company specific
standards for surface coating operations in automobile and light-duty truck
manufacturing.

          The cost estimates assume that SIP compliance for the surface
coating facilities of the metal furniture, large appliances, and metal  coil
coating industries was complete by December 1982.   SIP compliance for
automobile and light-duty truck surface  coating facilities is assumed to be
complete by 1987.
                                  A8.2-3

    -------
          NSPS.   NSPS have been promulgated for surface coating of
automobiles and  light-duty trucks,  metal  furniture,  appliances, and metal
coil coatings.   Each of the NSPS allows for coating  changes, process
changes, and/or  add-on controls to  meet the emissions limits.

          The NSPS for Surface Coatings of Automobiles and Light-Duty
Trucks (45 FR 85410) was proposed on October 5, 1979 and promulgated on
December 24, 1980.  VOC emission limits are given for coatings used in ea
prime, guide (an extra coat needed  if electrodeposition is used for the
prime cost), and top coat.  These limits  are based on the use  of waterbor
coatings.  Innovative technology waivers  from NSPS for five automobile an
light-duty truck surface coating operations were promulgated on February
1983 (48 FR 5452).  Cost impacts of these waivers are not estimated in th
report.

          The NSPS for Surface Coating of Metal Furniture (45  FR 79390) w
proposed on November 28, 1980.  The standard promulgated on October 29,
1982 (47 FR 49278) sets a standard  for VOC emissions per liter of coating
solids applied.   The NSPS suggests  various coatings  changes, process
changes, and emissions control devices.

          An NSPS for Industrial Surface Coating:  Appliances  (45 FR 8508
was proposed on  December 24, 1980.   The standard promulgated on October 2
1982 (47 FR 47778) sets a VOC emission limit per volume of coating solids
used for each prime coat and each top coat operation within assembly plan
where large appliance parts are coated with organic  coatings.   The standa
does not apply to powder coatings.   It may be met through use  of coatings
with higher solids content, application equipment with higher transfer
efficiency, emission control devices, or combinations of these approaches
This standard applies to surface coating facilities  used in the productio
of  10 different  appliances.

          NSPS for Metal Coil Surface Coating (45 FR 1102) was proposed o
January 5, 1981, and promulgated on November 1, 1982 (47 FR 49606).  The
standard may be  met by use of low VOC-content coatings, emission control
devices, or combinations of the two.

Control Technology

          The trend in the coatings industry has been toward development
greater product  efficiency, including better protection or decoration for
longer periods at lower cost.  Present research is aimed toward replicati
the performance  of traditional (low soli.ds, organic  solvent-borne) coatin
through the development of:

          •  low organic solvent materials (e.g., waterborne,  high-solids
             powder coatings)

                                    and

          •  new application techniques for these materials (e.g.,
             electrostatic spray of powder coatings, electrodeposition of
             waterborne coatings).

                                  A8.2-4

    -------
          Most surface coating facilities are expected to control VOC
emissions through the use of new technologies rather than through the
conventional control techniques of incineration and carbon adsorption used
in many other industries.  These traditional methods are very expensive
when VOC concentration is low, as is the case for many surface coating
operations.  The presence of personnel in spray booths means that large
quantities of air must be injected to dilute the quantity of VOCs to limits
tolerable to humans.  If, instead, robots are used in spray booths (as is
beginning to be seen in motor vehicle production), then the traditional
control methods might become more economical.  Although incineration of VOC
emissions from ovens is technically feasible, ovens discharge only about 15
percent of the VOC emissions from a coating line.  Thus, incineration of
the bake oven exhaust goes only a limited way toward reducing VOC
emissions.

          A discussion of industry-specific control techniques follows.

          Automobile and Light-Duty Trucks.  Electrodeposition of
waterborne coatings (EDP) for the prime coat provides superior corrosion
protection.  This report estimates costs for conversion to EDP (for the
prime coat) for SIP compliance.  However, it is assumed that new sources
would choose the EDP process even without the NSPS; thus, no incremental
cost is estimated for EDP for NSPS compliance.  VOC reduction depends on
the original process and coating material.  A change to EDP from a 32
percent solids (68 percent solvent) primer applied by spray, for example,
reduces VOC emissions by 80 percent.

          Costs were estimated for two control alternatives for guide coats
and top coats for compliance with SIPs and NSPS:  waterborne coatings, and
solvent-borne coatings followed by incineration of the bake oven exhaust.

          Metal Furniture.  In order to meet the SIP (CTG) limitations,
manufacturers are assumed to use 60 percent solids coating for spray
coating and waterborne coating for dip and flow coating, rather than the 35
percent solids organic solvent-borne coating associated with an
uncontrolled facility.  VOC emissions are thereby reduced by 60 to 67
percent.  The cost estimates include conversion to waterborne coatings for
20 percent of existing spray plants.

          Most new spray plants (80 percent) are expected to comply with
NSPS through use of a high-solids coating.  Capital costs for high-solids
coatings are believed to be zero since different equipment is not required.
O&M costs are negative (i.e., a savings is realized) since materials cost
is lower for high solid coatings than for the conventional solvent-borne
coating.  The balance of spray plants will use either waterborne coating,
powder coating, or a 60 percent solids coating (SIP complying) followed by
incineration of bake oven emissions.  Cost estimates were based on use of
waterborne coating for this remaining 20 percent of the spray plants in
order to simplify the costing.  It was assumed that all  dip plants would
use electrodeposition of waterborne coatings to comply with NSPS.   Cost
estimates for NSPS compliance in flow coating plants were based on 80/20
waterborne coatings (80/20 is the water to solvent ratio). With NSPS


                                  A8.2-5

    -------
controls in place, VOC emissions are reduced an additional 30 percent be!
the CTG level.

          Major Appliances.  Most SIP (CTG) limitations for existing
sources in this industry are equivalent to the NSPS.  This report estimat
costs for two alternatives for prime coat emissions control:  applicatior
of a high (62 percent) solids coating at a transfer efficiency of 60
percent and application of a waterborne coating by electrodeposition.
These give 70 percent and 94 percent VOC reductions, respectively, and be
meet NSPS and typical SIP requirements.   Use of a high-solids coating at
60 percent transfer efficiency was assumed for topcoat emissions control.

          Metal coil coating.  Since personnel can be isolated from the
coil coating operation, VOC concentration can be high.  NSPS compliance
cost estimates were based on the use of thermal incineration with heat
recovery (primary and secondary) and coating rooms for 85 percent of new
sources.  This control strategy reduces VOC emissions by 90 percent.  It
was assumed that approximately 15 percent of the coating lines would use
waterborne coatings for SIP and NSPS compliance (also resulting in a 90
percent reduction).  These control costs were assumed to be zero in EPA
documents.   Cost estimates for SIPs requiring 85 percent control were
based on thermal incineration with heat recovery.  Multiple zone
incinerators and coating rooms were costed for compliance with the currer
SIPs.  VOC emissions are reduced by 64 percent, using these controls.

Costing Methodology

          EPA has estimated control costs for various model plants (by s-
and/or type) and control alternatives for each industry in the CTG and N5
documents.  The costs and capacity figures were fitted to exponential cos
functions by linear regression of the logarithms.  The resulting cost
equations for-capital and O&M were used to estimate total capital
investment and annual O&M costs for each control alternative for each
industry sector, using actual capacity figures and the control technique
assumptions described above.  Heat recovery credits were calculated
separately for coil coating.  Control costs are shown in Table A8.2.1.

          As discussed above, costs are not included for the following
plants:  those spray plants that manufacture metal furniture and would
comply with NSPS or SIPs by means of high-solids coatings and those plan
that produce coated metal coil and would comply with NSPS or SIPs by mear
of waterborne coatings.
                                  A8.2-6

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                    Chapter A8.3  Dry Cleaning Industry


          The dry cleaning industry is a significant source of volatile
organic compounds (VOC), a precursor of oxidants.  Since dry cleaning
facilities are concentrated in urban areas where ambient oxidant standards
are likely to be exceeded, there are increasing efforts to regulate this
industry.  Revisions of this chapter included adjusting pollution control
costs to 1981 dollars, editing and updating discussion of regulations, and
updating industry data.

Regulations

          Although no NSPS has been promulgated for this industry, a NSPS
for perchloroethylene dry cleaning was proposed on November 25, 1980, (45
FR 78174) and a NSPS for petroleum solvent dry cleaning is currently under
development.  Both of these regulations would control VOC emissions.  The
proposed NSPS for perchloroethylene dry cleaning would limit process wastes
and leaks and require the use of a carbon adsorber or refrigeration
equipment to control emissions from exhausts and vents.

          Dry cleaning plants are subject to VOC regulations in SIPs.  An
increasing number of states have regulations that limit the VOC emissions
from handling and use of organic solvents.  Historically, these regulations
were patterned after Los Angeles' Rule 66 or Appendix B (40 CFR 51, App.
B).  Both of these regulations have pounds-per-day and pounds-per-hour
limits, but compliance is achieved if 85 percent control is demonstrated.

          In the late 1970's and early 1980's, EPA issued draft and final
control technique documents covering control of volatile organic emissions
from both types of dry cleaning operations as guidance to states for
setting standards for this industry achievable with RACT.  States with
ozone non-attainment areas in 1977 were required to revise their SIPs to
include VOC regulations for perchloroethylene dry cleaning facilities by
January 1981.  States that were unable to demonstrate attainment for ozone
by the statutory deadline of December 31, 1982, could request extensions
for attainment of the standard.  States granted such an extension are
required to submit a further revised SIP including VOC regulations for
petroleum solvent dry cleaning facilities.

          In the past, the use of the synthetic solvent, perchloroethylene,
instead of a petroleum solvent, such as Stoddard, was encouraged as a means
of reducing the oxidant problem even when control of the perchloroethylene
was not anticipated.  The synthetic solvent was judged to be less reactive
in the atmosphere and thus would tend to reduce photochemical  oxidant
formation.  However, in 1976 and 1977 EPA released statements  (41 FR 5350
and 42 FR 35315) recommending that controls be imposed on perchloroethylene
emissions because (1) even compounds having low reactivity can form
considerable amounts of oxidant under certain atmospheric conditions and
                                  A8.3-1

    -------
(2) perch!oroethylene has been reported to have adverse health effects.
Both the health effects and photoreactivity of perchloroethylene are
currently under study.

Industry Characteristics

          There are primarily two types of dry cleaning installations  tha
release organic-solvent vapors resulting in the formation of photochemica
oxidants in the atmosphere.  About 70 percent use synthetic solvents such
as perchloroethylene, and the remainder use petroleum solvents such as
Stoddard.

          The trend in dry cleaning operations has been towards increasin
business for "laundromat" facilities and industrial  establishments, while
business in the commercial sector (small neighborhood dry cleaning shops)
has declined.  The number of facilities predominantly offering dry cleani
services fell from about 28,000 in 1972 to 22,000 in 1977.  This 5 percen
annual decline reflected the increased use of synthetic fibers in clothin
which reduced the need for dry cleaning.  Because consumer demand for
synthetics has stabilized, we assume that the number of dry cleaning plan
will remain relatively constant in the 1980's.

          The dry cleaning plants covered in this chapter are classified
into SIC 7216.  Other laundry facilities, which are classified into SIC
7211 (power laundries), 7218 (industrial launderers), and 7213 (linen
supply), also operate some dry cleaning machines.  The value of receipts
for SIC 7216 rose only slightly from $1.8 to $1.9 billion between 1972 an
1977.

Pollutants and Sources

          In perchloroethylene plants, average solvent losses have been
estimated to be about 10-12 kg of solvent per 100 kg of clothing.  Unlike
petroleum plants, where no emission controls are used, many dry cleaning
operations using perchloroethylene solvents have vapor adsorbers to reduc
solvent usage.  For adsorber-equipped plants, the solvent losses are
approximately 5 kg per 100 kg of clothing.  Other plants are equipped wit
a  regenerative filter and a muck cooker.  For these facilities, solvent
losses average about 8 kg of solvent per 100 kg of clothing.

          Because there is no solvent recovery during the drying cycle nc
from the filter muck, petroleum plants have much higher solvent losses th
synthetic plants.  Emissions for petroleum dry cleaners are estimated  to
average 23-29 kilograms of solvent per 100 kilograms of materials cleanec
At the present time, very few control systems are known to be operating i
petroleum plants in the U.S.

Control Technology

          Historically, the dry cleaning industry has met emission
standards by replacing petroleum solvents with synthetic solvents and  usi
equipment that recycles these synthetic solvents.  Recycling is encourage
because of the high cost of these solvents.

                                  A8.3-2

    -------
          Fire-hazards and the lack of economic incentives or air pollution
regulations are the primary reason why carbon adsorbers are not widely used
in the petroleum dry cleaning industry.   The low cost of petroleum solvents
in the past has provided little motivation for controlling losses.

          The high cost of perchloroethylene solvent has made carbon
adsorption attractive to the synthetic solvent users.  Presently about 35
percent of synthetic solvent plants are equipped with adsorption units.
Maintenance, however, is frequently very poor.

          Carbon adsorption can be used in perchloroethylene plants to
reduce vented emissions from the washer, dryer, storage tanks, distillation
systems, and chemical separators to a concentration less than 100 ppm.  The
application of add-on controls and better house-keeping practices can
reduce annual dry cleaning solvent consumption by an average of 60-70
percent.

          Because of the higher capital  investment and operating costs
required for emissions controls on petroleum-solvent plants, it is believed
that most new plants will  use synthetic solvent and that many of the
petroleum-naphtha solvent plants will convert to synthetic solvent
operations by the mid-1980's.  Increasing solvent costs will provide an
incentive for more effective evaporative emission control.

Costing Methodology

          Control costs are aggregated in Table A8.3.1.  The costing
methodology is largely based on data given in a 1977 draft EPA document but
using the following conditions:

          •  only industrial and commercial  plants will be controlled
             (coin-operated plants will  not be controlled)

          •  petroleum solvent plants will convert to other solvents

          •  compliance will occur in the years 1982 to 1987 by virtue of
             Air Quality/SIP and NSPS timing

          •  thirty-five percent of all  perchloroethylene plants are
             considered to install carbon adsorption units for reasons of
             solvent recovery rather than air regulations.
                                  A8.3-3

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                  Chapter A8.4  Printing Ink Manufacture


          Revision of this chapter was limited to adjusting the pollution
control costs to 1981 dollars and expanding the discussion of applicable
regulations.

Regulations

          No NSPS has been promulgated for printing ink manufacture.  The
volatile organic compound (VOC) and particulate emission standards in SIPs
apply to this industry.   An increasing number of states are including
general emissions limits for photochemically reactive hydrocarbons in their
SIPs.  Most of the regulations are patterned after Appendix B (40 CFR 51,
App. B) or after Los Angeles'  Rule 66.  Although Rule 66 sets emission
limits, the standard can also be met if uncontrolled emissions are reduced
by 85 percent.  Appendix B states that the 85 percent reduction is
achievable with RACT.  Many states also pattern their general particulate
standards after the suggested RACT process weight tables in Appendix B.

Industry Characteristics

          The printing ink manufacturing industry is similar in many
respects to the paint manufacturing industry, although it is considerably
smaller in size.  The industry sector described in this chapter is
contained in SIC 2893.  Captive shops and their production are part of SIC
27 and are not included  in this chapter.

          The major components of ink include drying oils, resins, varnish,
shellac, pigments, solvents, and many specialty additives.  The three
principal ingredients, vehicles (or varnishes), pigments, and solvents,  are
mixed together thoroughly to produce a uniform dispersion of pigments
within the vehicle.  The mixing is accomplished using high-speed mixers,
ball mills, three-roll mills, and other types of mills.

          Annual printing ink production in the United States now exceeds a
billion pounds.  The principal types of printing inks manufactured by the
industry are lithographic, letterpress, gravure, flexographic, and special.
In 1976, the industry was estimated to be composed of about 460 plants with
about 9000 employees involved in production.  About 40 percent of the
plants had less than ten employees and about 70 percent less than 20
employees.  The historical growth rate of industry sales has been reported
in 1976 as having been about 5 percent per year.

Pollutants and Sources

          Varnish or vehicle preparation by heating is the largest source
of emissions from printing ink manufacturing.  Air pollutants from printing
ink manufacturing are gaseous organic (hydrocarbons) materials originating


                                  A8.4-1

    -------
from the varnishes and organic solvents, and participates from pigment
mixing operations.  About 120 pounds of gaseous organics are emitted per
short ton (2000 pounds) of product.   About 2 pounds of particulate are
emitted per short ton of pigment dispersed.

Control Technology

          Reduction of the gaseous organic emissions from printing ink
formulation by 85 percent, which will meet practically all  SIP's, can be
accomolished by thermal combustion,  catalytic combustions flame combustic
or adsorption.  Incineration of gaseous organic or hydrocarbon emissions
from ink formulating operations using thermal afterburners  has proved to
the most effective control method and one that is relatively free of
maintenance problems.  Thermal incineration using a direct-fired
afterburner (with heat exchange) achieves control efficiencies of 95
percent, and was considered the preferred method for controlling the
gaseous organic emissions.  Catalytic afterburners, although capable of
adequate control, still present some technical operating problems.

          Fabric filters (baghouses) are suitable for control of
particulate emissions from pigment mixing.  Particulate removal
efficiencies of greater than 95 percent are achieved readily.

Costing Methodology

          Estimates of pollution control costs for the printing ink
formulating industry were based on assumed compliance of 230 large plants
in the industry.  The model plant for the large-plant category, which
represents about 90 percent of industry production, had an  annual
production of 3,750,000 pounds in 1976.  The cost of the above technology
for these plants is indicated in Table A8.4.1.  Compliance  with SIPs was
assumed to occur over the period from before 1970 through 1987.
                                  A8.4-2

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             Chapter AS.5  Synthetic Fiber (Nylon) Manufacture


          Revision of this chapter was limited to adjusting the pollution
control costs to 1981 dollars, editing the discussion of regulations, and
reorganizing the industry description.

Regulations

          No NSPS has been promulgated for this industry.  General
hydrocarbon standards in SIPs apply to synthetic fiber manufacturing
plants.  Most state regulations of hydrocarbon emissions are patterned
after Appendix B (40 CFR 50, App. B) or after Los Angeles Rule 66.  Both of
these regulations have pounds-per-day and pounds-per-hour limits, but
compliance is achieved if 85 percent control  is demonstrated.

          The NSPS underdevelopment for synthetic fiber production plants
will cover only those plants that use an organic solvent in the process.
Production of fibers such as acrylic, modacrylic, cellulose acetate, and
spandex will be included, but not nylon production.  In the next edition
of this report, this chapter will be revised to include fibers that will be
covered by the NSPS.

Industry Characteristics

          Nylon was probably the first important truly synthetic fiber
produced.  It accounted for 26 percent of total synthetic fiber production
in 1976.  Nylon fibers have applications in all major fiber use areas,
including carpeting, hosiery, apparel, and tire cord.

          The total production of all nylon fibers in 1976 amounted to
about 2,150 million pounds.  The estimated plant capacity for 1976 was
2,675 million pounds.  Of the 39 plants on line in 1976, 11 plants were
relatively small and had plant capacities of 4.4 million pounds or less.
The average plant capacity for the small plants was 2.6 million pounds per
year.  The average plant capacity for the remaining 28 plants was
calculated to be 95 million pounds per year.   This average capacity value
was taken to be representative of a model large plant and was used to
estimate emission control costs for nylon fiber manufacture.

Process Description

          Melt spinning is used to convert bulk nylon polymer chips into
fiber materials.  Polymer chips are melted in a heated screw extruder,
processed in a nitrogen atmosphere, then filtered through a series of metal
gauzes or a layer of graded sand.  The filtered molten polymer is then
extruded under pressure at a constant rate through nickel  or stainless
steel spinnerets.  Extrusion is followed by air cooling.  For Nylon 66
fibers, the filaments pass through a steam conditioning tube before


                                  AS.5-1

    -------
converging.  After the fiber is converged, it is given further treatments
which are dictated by the fiber's intended end use.  These treatments
generally include lubrication, drawing, and fiber modification, with the
end product being the finished fiber.

Pollutants and Sources

          The source of gaseous emissions from nylon fiber manufacturing
plants is the fiber finishing (drying) operation.  Uncontrolled hydrocarb
and oil vapor emissions from nylon fiber production are 7.0 and 15.0 poun
(respectively) per short ton of nylon fiber produced.

Control Technology

          Reduction of gaseous organic emissions from nylon fiber
production by 85 percent, which will meet most SIP's, can be readily
accomplished in a direct-fired afterburner.  Applicable control methods
include incineration and carbon adsorption.  Direct fired afterburners ca
generally achieve 98-99 or more percent reduction of emissions, whereas
carbon adsorption systems can reduce emissions by about 80 to 95 percent.
Because of the greater degree of emission control provided by use'of the
direct fired afterburner, incineration was selected as the control  method
for the emissions from nylon fiber manufacturing operations.

Costing Methodology

          Pollution control  costs for the nylon fiber industry were
estimated using a model plant.  The model plant selected was considered
representative of 28 large plants each with an annual capacity for
producing 95 million pounds  of nylon fiber.  These 28 large plants
accounted for* 99 percent of the plant capacity in the industry.

          The estimated costs of control developed on the above basis are
given in Table AS.'S.l.  An assumed compliance schedule was used which
distributed compliance over the period from 1970 to 1987.
                                  A8.5-2

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                 Chapter A8.6  Lead-Acid Storage Batteries


          This chapter has been added to the Cost of Clean Air report
because emissions from lead-acid battery manufacturing facilities present a
significant pollution control problem.  Available data indicate that
uncontrolled lead emissions may cause symptoms of lead poisoning to appear
in certain individuals in the vicinity of battery plants.  These plants
generally are located near residential areas.   The chapter includes cost
estimates of controlling lead-bearing and non-lead bearing particulates for
compliance with SIPs and NSPS.

Industry Description

          The lead-acid storage battery manufacturing industry is the
largest single consumer of lead in the United  States, accounting for
approximately 62 percent of domestic lead consumption in 1980 (Ref. 6,
p. 33).  There were about 190 lead-acid battery plants in 1977.   Plants
owned by the six largest companies produced 70 percent of the total output
(Ref. 2, p. 8-1).

          Battery plants are generally located in urban areas near outlets
for their products.  The larger plants tend to have secondary smelting
facilities and/or lead oxide production facilities; smaller firms tend to
purchase the lead constituents (Ref. 2, p.  3-1).

          There are two major types of lead-acid batteries:
(1) starting-lighting-ignition (SLI) batteries used in automobiles, golf
carts, recreational vehicles, and aircraft  (SIC 36911) and (2) industrial
storage batteries for low voltage power systems, industrial fork lift
trucks, etc. (SIC 36912).  SLI batteries make  up 80 percent of the battery
market; 80 percent of SLI batteries are used in automobiles (Ref. 2,
p. 3-6).

          Total lead-acid battery production was about 87 million units in
1979 (Ref. 5, p. 109).  In 1977, the value  of  shipments was $1,983 million
(Ref. 7, p. 36 F-12).  Throughout the 1970's,  the replacement sector
accounted for approximately^ 80 percent of automobile battery production
(Ref. 5, p. 109).  Current demand for replacement batteries is dependent
upon automobile sales three to four years ago, automobile sales  six to
eight years ago, and extremes, in the weather (Ref. 4, p. M180).   This
replacement market is forecast to grow, since  owners are keeping their
automobiles longer (Ref. 8).

          The decline in new car sales and  the recession of the  early
1980's have caused uncertainty regarding growth of the lead-acid battery
industry.  Between 1968 and 1977 the industry  grew at an average rate of
4.9 percent per year (Ref. 2, p. 8-7) but output declined in 1980 and 1981
(Ref. 9).


                                  A8.6-1

    -------
          Industry sources suggest a three to eight percent growth rate
when the economic downturn ends.  Possible growth areas include
recreational vehicles, trucks and commercial vehicles, and electric cars
(if powered by lead-acid batteries (Ref. 8).

          According to EPA personnel, new capacity will probably be creat
by expanding the larger existing plants (those with capacities of more th<
6500 batteries per day (Ref. 2, p. 3-8).

Pollutants and Sources  (Ref. 2, Chapter 3,4)

          The manufacturing of lead-acid batteries has five distinct step;
lead oxide manufacturing, paste mixing, grid casting, the three-process
operation (including plate stacking, element burning, and battery
assembly), and formation.

          At approximately 20 percent of the plants there is a sixth
process, lead reclamation, in which scrap lead from defective batteries i:
recycled.  Generally, these six processes and their facilities may be
considered independent of one another in that there is not a continuous
flow of materials from one to another.

          The major air pollution problem associated with lead-acid batte
manufacture is the emission of particulates, 50 percent of which are
lead-bearing.  These particulates are emitted from all but the formation
process.  In addition, sulfuric acid mist is emitted during formation.  T
manufacture of the new "no maintenance" battery yields the same amount an<
type of pollutants.

Regulations
•MWWP^K^M^B*««MB^-«.                                  ^

          SIPs.  The various state requirements for particulate control
apply to the lead-acid battery manufacturing industry.  Those requirement
are often expressed in terms of allowable emission rates for given proces
weight rates.  SIPs may also specify any additional controls needed to me
the lead NAAQS.  EPA now requires states to expand their SIPs to regulate
certain specific lead sources, one of which is lead-acid battery plants
producing at least 2,000 batteries per day (40 CFR part 51 subpart E).
State requirements for sulfuric acid emission control also affect lead-ac
battery manufacture.

          NSPS.  EPA promulgated the first NSPS for sources of lead
pollution ^n~A~pril 16, 1982 (47 FR 16564, 40 CFR 60.370).  The proposed
standards regulate the five main lead-emitting operations in a lead-acid
battery plant by setting a lead emissions limit for each operation.  Ther
is also a lead emissions limit for "other lead emitting operations."  The
regulation covers plants with the design capacity to produce in one day
batteries that would contain, in total, at least 5.9 Mg of lead.

          As discussed in the NSPS proposal (45 FR 2790), sulfuric acid
mist from lead-acid battery plants may be regulated in the future when
quantitative data on those emissions are available.  Such a NSPS would
                                  A8.6-2

    -------
establish sulfuric acid mist as a designated pollutant, and states would
also be required to regulate sulfuric acid mist emissions from existing
lead-acid battery plants.

Control Technology (Ref. 2, Chapter 4)

          An estimated 60 percent of the particulate control devices used
by the lead-acid battery industry are baghouses with control efficiencies
ranging from 96 to 99.8 percent; the remaining 40 percent consist of
scrubbers and cyclones with reported efficiencies ranging from 50 to 98
percent.

          Most plants vent the stacking, burning, and assembly operations
(the three-process operation) into a common duct prior to cleaning the
gases.  Other plants clean the exhaust from paste mixing and the
three-process operation with a common system.  Lead oxide production
facilities use mechanical collectors and a baghouse in series to remove the
product lead oxide from the carrier air stream.  The baghouse is considered
as both process equipment and air pollution control equipment.  The exhaust
gas stream from the lead reclamation process is similar to the grid casting
exhaust gases in that both are characterized by high temperatures and lead
fumes.  It is common for these two gas streams to be treated by one control
device, generally a low-energy wet scrubber.  Fabric filters are not
presently used to control this stream in any battery plant, but they have
been proven effective in controlling emissions from similar processes in
other industries.

          The control  technologies for NSPS compliance are impingement
scrubbers for the grid casting and lead reclamation facilities and fabric
filters for the other facilities.   NSPS costs are estimated for expansions
of larger (6,500 batteries per day) existing plants.  The NSPS cost for
lead oxide manufacturing includes only the incremental  cost of a baghouse
with a two to one air to cloth ration relative to one with a three to one
air to cloth ration, which is assumed to be part of the process equipment.
The NSPS costs do not include the costs for impingement scrubbers on the
paste mixing and lead reclamation facilities, which are required for SIP
compliance.

          The control  technology costed for SIPs includes impingement and
entrainment scrubbers for the paste mixing and lead reclamation processes.
Because of their high process weights the other processes are able to
comply with the typical  SIP particulate regulation without control  devices
(Ref. 2, p. 8-16).   The uncontro^ed formation facility also complies with
SIPs (Ref. 2,-p. 7-9).  This report assumes that all SIP particulate
controls were in place by 1978.

Costing Methodology

          EPA has estimated costs  for the SIP and NSPS  controls for various
sized model plants in its Background Information Documents for the proposed
and promulgated NSPS.   These cost  and capacity figures  were fitted to an
exponential cost function by linear regression of the logarithms.   The


                                  A8.6-3

    -------
resulting cost equations for capital  and O&M were employed to generate
total  capital  investment and annual  O&M costs, based on estimated plant
capacities.  Control costs are shown in Table A8.6.1.
                                  A8.6-4

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         Chapter A9.   Forest and Agricultural  Products Industries
          For the purpose of this report, the Forest and Agricultural
Products Industries are defined as those establishments which process
products grown on the land.  Those covered here are:

          •  Kraft Pulp Industry
          •  Neautral Sulfite Semichemical Paper Industry
          t  Grain Elevators
          •  Feed Mills
          •  Plywood Veneer

          The costs of air pollution control  for these categories of
industry are listed in table A9.  The industries and more specific details
of controls and costs are discussed in the following sections.
                                   A9-1

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                     Chapter A9.1  Kraft Pulp Industry


          Revision of this chapter was limited to adjusting the pollution
control costs to 1981 dollars and editing the discussion of regulations.

Regulations

          The NSPS for kraft pulp mills (40 CFR 60.280) was promulgated on
February 23, 1978, and revised in 1978 and 1979.  The regulation sets
limits for particulate emissions from recovery furnaces, smelt dissolving
tanks, and lime kilns and opacity limits for recovery furnaces.  It also
regulates total reduced sulfur (TRS) emissions from lime kilns, smelt
dissolving tanks, cross recovery furnaces, straight kraft recovery
furnaces, digester systems, brown stock washer systems, multiple effect
evaporator systems, black liquor oxidation systems, and condensate stripper
systems.

          Since TRS is not a criteria pollutant, the establishment of NSPS
for TRS required the states (under Section 111 (d) of the Clean Air Act) to
regulate emissions of this "designated" pollutant from existing kraft pulp
mills.  EPA provided guidance to the states for establishing these
standards in a March 1979 control technique guideline document.  As a
result, states with kraft pulp mills are including TRS limits for the
existing facilities in their regulations.

          The general particulate standards in SIPs apply to kraft pulp
mills.  Most are patterned after the process weight rates in Appendix B (40
CFR 51, App. B), which were suggested as achievable with RACT.  Several
states have regulations covering particulate and TRS emissions from
specific sources at kraft pulp mills.  At least one state also regulates
sulfur oxide emissions while another limits organic vapors.

Industry Characteristics

          This chapter discusses air pollution control costs for kraft
pulping, the predominate chemical pulping  process; chapter 9.2 covers
neutral sulfite semichemical (NSSC)  pulping.  Wood pulping processes
separate the fiber from other wood constituents and prepare it for further
use in manufacturing paper products.  Some pulping methods rely primarily
on mecha'nical processes, others use chemical processes, and others (the
semichemical methods) combine aspects of both mechanical  and chemical
pulping.

          The kraft pulp industry has a capacity of about 40 million short
tons of pulp per year, with little scheduled capacity growth.   In 1979,
there were 121 kraft mills in the U.S., with the majority located in the
South.
                                  A9.1-1

    -------
          Kraft pulp is used in the production of linerboard, solid-fiber
board, high-strength bags, wrapping paper, high grade white paper,
food-packaging materials,  and other products.   The kraft pulp industry an
other pulping processes are categorized in SIC 2611.

Pollutants and Sources

          Kraft pulping, in simplified terms,  consists of seven separate
processes.  The digesting  liquor in this process flow is a solution of
sodium hydroxide and sodium sulfide.   The spent liquor (black liquor) is
concentrated, then sodium  sulfate is  added to  make up for chemical losses
and the liquor is burned in a recovery furnace, producing a smelt of sodi
carbonate and sodium sulfide.  The smelt is dissolved in water to form
green liquor, to which is  added quicklime to convert  the sodium carbonate
back to sodium hydroxide,  thus reconstituting  the cooking liquor.  The
spent lime cake (calcium carbonate) is recalcined in  a rotary lime kiln t
produce quicklime (calcium oxide) for recausticizing  the green liquor.

          Main emission sources in the kraft process  are the recovery
furnace, lime kiln, smelt  dissolving  tank, and the power boilers.  The
kraft pulping economics depend upon reclamation of chemicals from the
recovery furnace and lime  kiln.  Hence, emissions from these processes ar
controlled to minimize losses of chemicals.

          Particulates and gasses are emitted  from the various sources of
the kraft process.  Numerous variables affect  the quality and quantity of
emissions from each source of the kraft pulping process.  There are sever
sources of emissions in the process and the applicable control technology
and attainable efficiencies of the control methods depend on the quantity
and quality of emissions.   The gaseous emissions occur in varying mixture
and are mainly hydrogen sulfide, methyl mercaptan, dimethyl sulfide,
dimethyl disulfide, and some sulfur dioxide.  The sulfur compounds are
detectable at a concentration of a few parts per billion.  The particulat
emissions are largely sodium sulfate, calcium  compounds, and fly ash.

          The rates of uncontrolled and controlled emissions of
particulates, total reduced sulfur (TRS), and  sulfur  dioxide from various
sources of kraft pulping processing are shown  in Table A9.1.1.

          Most states do not have emission regulations for pulp and paper
making.  For this study it has been assumed that all  the states would adc
the most stringent current state regulations—those of Oregon and
Washington.  Costs for compliance are based on all mills meeting these
regulations.  The regulations include the following control provisions:

          (1) Total reduced sulfur (TRS) compounds from the recovery
              furnace:  No more than  1 kg/ADMT (2 Ib/ADT) (1972) to be
              reduced to no more than 0,25 kg/ADMT (0.5 Ib/ADT) by 1975.

          (2) Noncondensible gases from the digesters and multiple-effect
              evaporators:  collected and burned in the lime kiln or prov
              equivalent.


                                  A9.1-2

    -------
           Table A9.1.1.  Rates af emissions from Kraft process
                   (In kg/ADMT with Ib/ADT in parentheses) I/
Process

Digester

Washer

Multiple effect evaporator

Recovery furnace

Smelt tank

Lime kiln

Power boiler 2J

Totals


Digester

Washer

Multiple effect evaporator

Recovery furnace

Smelt tank

Lime kiln

Power boiler
*
Totals

Particles
Uncontrol
0.0
(0.0)
0.0
(0.0)
0.0
(0.0)
60.0
(120.0)
7.8
(15.6)
34.0
(68.0)
35.3
(70.6)
137.1
(274.2)
Control!
0.0
(0.0)
0.0
(0.0)
0.0
(0.0)
2.00
(4.00)
0.25
(0.50)
0.50
(1.00)
2.47
(4.94)
5.22
(10.44)
TRS
led
0.72
(1.44)
0.05
(0.10)
0.18
(0.36)
2.95
(5.90)
0.05
(0.10)
0.22
(0.44)
0.0
(0.0)
4.17
(8.34)
ed
Trace

Trace

Trace

0.25
(0.50)
Trace

Trace

0.0
(0.0) '
0.25
(0.50)
Sulfur dioxide

Trace

Trace

Trace

1.2
(2.4)
Trace

Trace

19.7
(39.4)
20.9
(41.8)

Trace

Trace

Trace

1.2
(2.4)
Trace

Trace

10.5
(21.0)
11.7
(23.4)
I/  ADMT = Air-dried metric ton (ADT = Air-dried short ton).

21  Fuel requirement = 3.26 x 1010 joules/ADMT (3.09 x 107 Btu/ADT).   Coal
    provides 35%, oil 27%, gas 26%, and bark/wood 12% of the  energy.   Sulfur
    content = coal  1.9% and oil 1.8%.   Ash content = coal  8.1% and bark/wood

    2'9%"                         A9.1-3

    -------
          (3)  Particulates from the recovery furnace:  no more than 2
              kg/ADMT (4 Ib/ADT).

          (4)  Particulates from the lime kiln:  no more than 0.5 kg/ADMT
              (1 Ib/ADT).

          (5)  Particulates from smelt tank:  no more than 0.25 kg/ADMT
              (0.5 Ib/ADT).

          (6)  Emissions from power boiler will meet the Federal emission
              standard.

Industry Costs

          The  costs reported here were adopted empirically from an Econonr
Impact study published in May, 1977 (EPA-230/3-76-014).  Aggregate costs
reported there were adapted using estimated schedules of compliance;
compliance costs for new plants were assumed to be associated largely wit
Kraft mills.  The aggregated costs developed on this basis are given in
Table A9.1.2.
                                  A9.1-4

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    -------
         Chapter A9.2  Neutral Sulfite Semi chemical Paper Industry


          Revision of this chapter was limited to adjusting the pollution
control costs to 1981 dollars and editing the discussion of regulations.

Regulations

          No NSPS governs this industry.  Neutral Sulfite Semichemical
(NSSC) paper mills are subject to sulfur dioxide and particulate emission
standards in SIPs.  Most of the limits in SIPs are patterned after
standards suggested in Appendix B (40 CFR 51, App. B) as achievable with
RACT.

          Appendix B presents limits for sulfur oxides, expressed as sulfur
dioxide, for several processes of sulfite pulp mills, including blow pits,
washer vents, storage tanks recovery systems, and digesters.  The
Appendix B process weight rate limits for particulate emissions from
process industries also apply to these mills.  A few states, however, have
set particulate as well as sulfur dioxide standards specifically for
sulfite mills.

Industry Characteristics

          Current industry capacity is about 3.95 million dry metric tons
(4.36 million short tons) per year.  Most of new capacity is replacement or
expansion capacity due to the high cost of completely new mills.  Mills are
currently operating at between 85 and 90 percent of capacity, so the
industry has some marginal capacity to fill limited increases in demand.

          Semichemical pulps are produced by digesting pulp wood with
reduced amounts of chemicals, followed by mechanical  treatment to complete
the fiber separation.  The most prevalent Semichemical  pulping process is
the neutral  sulfite Semichemical process.  In this process, sodium sulfite
in combination  with sodium bicarbonate, or ammonium sulfite buffered with
ammonium hydroxide, are used as cooking chemicals.  These cooks are
slightly alkaline in contrast to the highly alkaline kraft, and highly or
moderately acidic sulfite cooks.  The Semichemical pulping processes are
used for production of high-yield pulps ranging from 60 to 85 percent of
dry wood weight charged to the digestion vessel, and can include kraft and
sulfite processes suitably modified to reduce pulping action in order to
produce higher-than-normal yield pulps.

          Semichemical pulps are used in preparing corrugating medium,
coarse wrapping paper, linerboard, hardboard, and roofing felt, as well  as
fine grades  of  paper and other products.
                                  A9.2-1

    -------
Pollutants and Sources

          Discussions and calculations of air emissions from the neutral
sulfite semichemical  (NSSC)  process are limited to particulate and sulfur
dioxide.  The used cooking liquors are discharged to sewers or in some
cases they are evaporated and cross-recovered with an adjacent kraft mill
or treated in a fluidized-bed system.   In this study, fluidized-bed
combustion was assumed for the liquor treatment.   Emissions are summarizec
in Table A9.2.1.

Control Technology

          For the purposes of this report it was  assumed that particulate
emissions from the recovery  furnace and power boilers burning coal and
bark/wood, and sulfur dioxide emission from power boilers burning
high-sulfur coal and oil, were subject to control.  To meet the particula
emissions standard for recovery furnaces, a control  efficiency of at leas'
90 percent is required for the control system.  A sodium-based, double
alkali system was assumed for the control of sulfur dioxide from coal- am
oil-burning power boilers.

          Control methods for new plants were selected as follows:

     Process                Pollutant                 Control Methods
Recovery Furnace
Power Boiler
Particulate
Particulate
Sulfur Dioxide
Electrostatic
Electrostatic
Double alkali
Precipitate
Precipitate
          Costs are summarized in Table A9.2.2.   Since cost data were taki
from a specific source, rather than developed within the computer model,
new plant costs are included with existing plants.
                                  A9.2-2

    -------
     Table A9.2.1.  Controlled and uncontrolled emissions from various
         processes in the NSSC paper industry (in kg per ADMT with
                       Ib per ADT in parentheses) I/
     Process
Particulate    Emissions
Sulfur dioxide
    emissions

Recovery furnace
Power boiler
Totals
At 1971
control
levels
20.0
(40.0)
35.3
(70.0)
55.3
(110.6)
With
legislated
controls
2.0
(4.0)
2.47
(4.94)
4.47
(8.94)
At 1971
control
levels
0.01
(0.02)
19.7
(39.4)
20.71
(41.42)
With
legislated
controls
0.01
(0.02)
10.5
(21.0)
10.5
(21.0)
_!/  ADMT = Air-dried metric ton (ADT = air-dried short ton).

Source: Atmospheric Emissions from the Pulp and Paper Manufacturing
        Industry - Report of NCASI - EPA Cooperative Study Project,
        Technical Bulletin No. 69, February 1974.
                                  A9.2-3

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                       Chapter A9.3  Grain Elevators


          This chapter and Chapter A9.4, Feed Mills, discuss participate
emissions control from two stages of the feed and grain industry.  The cost
for grain elevator compliance with SIPs and NSPS is estimated in this
chapter.

Industry Characteristics

          The grain distribution system effects the transfer of grain from
farm to mill to final user.  Grain elevators perform a storage and transfer
function in this system.  This chapter covers only grain storage facilities
at distribution sites, not those located in grain or feed mills.

          There are two main classifications of grain elevators—country
and terminal.  Most country elevators receive grain by truck from nearby
farms for storage or shipment to terminal  elevators or processors (mills).
Terminal elevators are generally larger than country elevators and are
located at significant transportation or trade centers.  Port terminals
transfer grain to ships for export to foreign countries, whereas inland
terminals transfer grain by truck and rail  car to processors and to other
terminals.

          Based on Department of Agriculture statistics, we have estimated
that about 9,000 grain elevators with a total capacity of about 6.0 billion
bushels were affected by air pollution control  regulations in January 1982.
Country elevators account for 70 percent of capacity, and terminals the
balance.  Port terminals represent 15 percent of all  terminals with the
remainder being inland terminals.

          Country elevator capacity is expected to continue to grow at the
3.5 percent annual rate experienced during  the past decade, whereas
terminal capacity will continue to remain  relatively constant.  Smaller
country elevators are being replaced with  larger elevators, which have a
greater throughput.  Existing terminals are being expanded to transfer a
larger throughput of grain.  This expansion in the number of terminals is
expected to occur at the rate of 1 percent  per year.

          Grain elevators are classified into SIC 5153, grain wholesale
facilities.  In addition to country and terminal  elevators, SIC 5153
includes other merchants marketing grain.   The Census of Wholesale Trade
reported about 9000 establishments in this  SIC with sales of $68.5 billion
in 1977.

Emission Sources and Pollutants

          In addition to storage and distribution, grain elevator
operations include the screening, cleaning, and drying of the grain in


                                  A9.3-1

    -------
order to prevent spoilage during storage.   The major sources of emissions
at a grain storage facility are unloading  and loading rail cars, trucks,
and barges; conveying grain within the facility; and screening, cleaning,
and drying.

          Most of the air emissions are particulates in the form of grain
kernels, dirt, and dust.   The level of emissions depends on the
characteristics of the grain, which include its type, quality, grade, and
moisture content, and the amount of entrained foreign material.  Emission
rates are also affected by the method of unloading and the size of the
receiving hopper, the speed of transport on conveyors during tne conveyin'
process, the free fall distance between the loading spout and the receivi
carrier during loading, and the degree of protection from winds during
loading and unloading.

Regulations

          NSPS.  The NSPS for grain elevators (40 CFR 60.300) was
promulgated August 3, 1978.  It regulates  both process and fugitive
particulate emissions from truck, barge, and rail car loading and unloadi
stations, grain dryers, and all grain handling operations at grain termin
elevators and grain storage elevators located at feed mills.  Exemptions
include grain terminals with storage capacity less than 2.5 million bushe
and grain storage elevators at grain mills with storage capacity less tha
1.0 million bushels.  Elevators at feed mills, discussed in Chapter A9.4,
are not covered by this NSPS.

          SIPs.  Most states set general standards for particulate
emissions from all types of process industries, although some states
specifically address feed milling or grain processing.  The emission
standards are expressed in one of four measures:. concentration in air
volume, control efficiency, gas volume, and process weight rate.  RACT
standards suggested in Appendix B (40 CFR 51, App. B) are expressed as
emission rate limits for process weight rates.

Control Technology

          Particulate emissions from grain handling operations can be
controlled either by eliminating emissions at the source or by collecting
emissions.  Techniques that eliminate dust emissions or that retain dust
within the process include enclosed conveyors, covers on bins, tanks, and
hoppers, and maintenance of the system's internal pressure below the
external pressure so that airflow is inward rather than outward from the
openings.  Control methods that capture and collect the dust that is
entrained or suspended in the air include cyclones and fabric filters.
These dust collection systems require extensive hooding and aspiration
systems.

          In 1972, about 30 percent of country elevators, 40 percent of
inland terminals, and 55 percent of port terminals had dust collection
systems.  Most of these were cyclones, although a few terminals used fabr
filters.  High efficiency cyclones provide sufficient control for country


                                  A9.3-2

    -------
elevators to meet most SIPs.  Terminals can comply with SIPs by installing
cyclones on most loading operations and fabric filters on grain handling
and unloading operations.  New and modified larger country elevators and
terminals must install fabric filters on all operations to comply with
NSPS.

Costing Methodology

          Table A9.3.1 presents a summary of grain elevator control costs.
These total compliance costs for grain elevators were estimated with cost
functions developed from control costs for model plants.  There are
separate functions for new and existing small country, large country,
inland terminal, and port terminal elevators.  Credit for the grain
recovered with cyclones and fabric filters was estimated with credit
functions derived from product recovery rates and an average grain price.
Costs and credits are functions of million bushels of grain throughput per
year.

          Both costs and credits are based on data in the Environmental
Impact Statement for the Grain Elevator NSPS (EPA 450/2-77-OOla).
                                  A9.3-3

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    -------
                          Chapter A9.4 Feed Mills
          This chapter and Chapter A9.3, Grain Elevators, discuss the
control of participates from two stages of the feed and grain industry.
The cost for feed mill compliance with SIPs is estimated in this chapter.

Industry Characteristics

          Feed mills process grain, the primary raw material, and other
constituents into finished livestock feed grains, including corn, oats,
barley, and sorghum grains.  Feed mills are distinct from grain mills,
which process food grains such as wheat, rice, and rye.  Feed mills receive
grain either directly from farms or from country elevators and grain
terminals, which are discussed in Chapter A9.3.

          In 1975 there were about 7000 feed mills with a total production
of 110 million tons per year.  Almost 60 percent of mills and almost 40
percent of production are in the north central region of the country.  This
region includes the corn belt, the northern plains, and the lake states.
Since 1969, the number of smaller mills (production less than 10 thousand
tons per year) has declined relative to the number of larger mills
(production greater than 25 thousand tons).

          Feed mill production grew at an annual rate of 1.1 percent
between 1969 and 1975 and increased to 2.5 percent between 1975 and 1981.
Capacity utilization is estimated to have increased from about 80 percent
in 1975 to an estimated 85 percent in 1981.

          Feed mills are classified into SIC 2048, which covers the
manufacturing of prepared feeds for animals and fowls by commercial mills.
Mills operated by livestock and poultry producers are not included in this
SIC code.  According to the Census of Manufactures, this industry had 2000
commercial mills with a value of shipments of $8.8 billion in 1977.  This
implies that the remaining 5000 mills were operated by livestock and
poultry producers.

Emission Sources and Pollutants

          Feed milling involves the receiving, conditioning (drying,
sizing, cleaning), grinding, mixing, and pelleting of the grains, and their
subsequent bagging or bulk loading.  The emissions from feed manufacture
are particulates, especially dust.

          The greatest source of emissions comes from unloading bulk
ingredients from rail cars and trucks.   The other major emission sources
are the grinding and conveying operation and the pellet coolers.  Factors
affecting emissions include the type and amount of grain handled, the
degree of drying, the amount of liquid blended into the feed, the type of


                                  A9.4-1

    -------
conveying, and the configuration of the receiving pits (whether deep or
shallow).

Regulations

          Particulate emissions from feed mills are regulated primarily b;
SIPs.  Although most states set general standards for particulate emissio
from all types of process industries, some states specifically address fe
milling or grain processing.  The emission standards are expressed in one
of four measures:  concentration of air volume, control efficiency, gas
volume, and process weight rate.  RACT standards suggested in Appendix B
(40 CFR 51, App. B) are expressed as particulate emission rate limits for
various process weight rates.  Most states pattern their SIPs after the
Appendix 8 process weight rates.

          No NSPS apply to feed mills.  The NSPS for grain elevators (40
CFR 60.300) covers grain handling at grain mills but not at feed mills.
Chapter A9.3 (Grain Elevators) discusses this NSPS.

Control Technology

          Cyclones and fabric filters are the principal types of pollutio
control equipment used in feed mills.  Cyclones are commonly installed on
pellet coolers and grinding operations for product recovery and dust
control.  In 1972, cyclones were installed on pellet coolers in almost 90
percent of feed mills and on grinding operations in about 40 percent of
feed mills.  Fabric filters were installed on grinding operations in 15
percent of feed mills.  About one third of the mills had installed either
cyclone or fabric filter on receiving and transferring operations.

          We assume that cyclones are sufficient controls for plants
existing in 1972 to comply with a typical SIP.  Plants beginning operatic
after  1972, however, are expected to install fabric filters on all
operations except pellet coolers to comply with SIPs.  Plants existing in
1972 were assumed to be in full compliance by 1978.  New plants are
assumed to comply immediately.

Costs

          Air pollution control costs are shown in Table A9.4.1.
Compliance costs were estimated with cost functions derived from model
plant  cost data.  Feed mills were divided into two categories of operatio
processing and handling.  Processing includes grinding and pellet coolers
and  handling includes receiving, transferring, and shipping.  Costs are a
function of feed processing capacity measured in thousands of tons per
year.

          Cost functions for cyclones and fabric filters are based on dat
in the 1973 Midwest Research Institute grain and feed study (EPA
450/3-73-003a) and the Environmental Impact Statement for the grain
elevator NSPS (EPA 450/2-77-OOla).  Neither the cost functions nor the
resulting cost estimates for this chapter consider the value of products
recovered by the air pollution  control.

                                  A9.4-2

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                       Chapter A9.5  Plywood Veneer


          Revision of this chapter was limited to adjusting the pollution
control costs to 1981 dollars, editing the discussion of industry
characteristics, and revising the discussion of regulations..

Regulations

          No NSPS governs this industry.  Plywood veneer mills are subject
to particulate and opacity regulations in SIPs.

          Most general particulate and opacity standards in SIPs are taken
from Appendix B (40 CFR 51).  Oregon is the only state that has particulate
matter and opacity regulations that apply specifically for plywood
manufacture.  The opacity regulations cover the condensable organic
compounds from veneer dryers.  The noncondensable organic compound
emissions from veneer dryers are not regulated.

Industry Characteristics

          It is reported that there are about 500 veneer and plywood mills
in the U.S., 248 of which use softwood, 253 use hardwood, and 27 use a
combination of softwood and hardwood.  Hardwood plywood is distinguished
from softwood plywood in that the former is generally used for decorative
purposes and has a face ply of wood from deciduous or broad leaf trees.
Softwood plywood is generally used for construction and structural
purposes, and the veneers are of wood from coniferous or needle bearing
trees.  Hardwood and softwood mill locations are based on the availability
of raw materials and product distribution patterns.  The largest
concentrations of mills are in Oregon, Washington, and North Carolina.

Pollutants and Sources

          Emissions from the manufacturing of plywood include both
particulates and organic compounds.  Particulate matter results primarily
from cutting and sanding operations.  Veneer dryers emit condensable and
non-condensable organic compounds.  The condensable compounds form aerosols
whose plume is regulated by opacity standards.

Control Technology

          The control technology costed is incineration of organic compound
emissions from the veneer dryers in a direct fired afterburner (with heat
exchange).'
 »
Costing Methodology

          Since there were no specific industry data available on  either
the applicable technology or costs of controlling the hydrocarbon  emissions

                                  A9.5-1

    -------
from the plywood veneer industry,  the nation-wide  cost impact was  develop
from the estimated costs of a 100  million  square feet  of plywood (3/8"
basis) per year model  plant and summarized in  Table  A9.5.1.   The costs  of
controlling particulates were not  considered because there were  no data
available and also because of their insignificant  impact relative  to the
organic compound emissions control  costs.   The estimated costs presented
the table are based on the use of  two sizes of model  plants  (representing
hard- and softwood operations, each being  an average size for that
category) and the application of a cost function reflecting  the  use of
gas-fired incineration (with heat  recovery) of the volatile  organic
compounds in the gases from glueing and drying oven  operations.
                                  A9.5-2

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              Chapter A10.   Solid Waste Reduction Industries

          Except for ocean  dumping (which is no longer widely practiced),
the only ultimate disposal  for solid wastes is on the land,  either in
sanitary landfills or in open dumps.  Frequently, however,  the volume of
solid waste is reduced by burning, shredding, or composting  prior to final
disposal in order to conserve available land disposal areas.

          Solid waste reduction contributes to air pollution through
incineration, with or without heat recovery, and by open burning.  Air
pollutants emitted to the atmosphere from these practices include
particulates, carbon monoxide, sulfur oxides, nitrogen oxides,
hydrocarbons, fluorocarbons, hydrochloric acid, and odors.   The levels of
pollutants emitted are primarily dependent upon the particular waste being
burned.  Incinerator emission levels are also dependent upon the
incinerator design and upon the method of operation.

          Particulate emissions are the greatest, making them the specific
pollutant subject to controls.  There are no current Federal regulations
for odors, hydrochloric acid, or fluorocarbons.  Besides air-pollution
laws, federal and state solid waste management regulations  have had an
effect on air pollution by  reducing open dumps, and thereby  reducing open
burning.  The relative effect of air-pollution laws versus  solid waste
regulatory laws has not been determined.

          The costs for control of air pollution from municipal  and
industrial incineration operations are shown in summary form in Table
A10-1.  These costs represent the application of various control  devices to
the different types of incinerators.  Details of each category and the
associated costs are given  in Chapter A10.1, Municipal  Waste, and A10.2,
Industrial, Commercial, and Building Incinerators.
                                   A10-1

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                      Chapter A10.1  Municipal Waste


          This chapter covers three aspects of municipal waste reduction:
land disposal, traditional incineration, and the newer practice of refuse
incineration in steam-generating (water-wall) incinerators.  The
incineration of sewage sludge is not considered here as it is included in
the consideration of Municipal Water Pollution Control in the companion
report.  Revision of this chapter was limited to updating the cost
estimates in the tables to 1981 dollars, making minor changes in the
discussions of regulations and industry characteristics for municipal
incineration, and expanding the discussion of regulations for refuse-fired
steam generators.

Land Disposal

          Burning in open dumps has been a source of smoke and other
emissions in past decades.  Because of this, dumps are discussed here in
terms of regulations and control measures.  However, the concept of the
costs of control is complex, because of the difficulty in determining
either the control  approach provoked by the prohibition of open burning, or
the fraction of the cost of the control measure attributable to the Clean
Air Act.  Previously, the approach to costing the control of burning at
open dumps was to cost the conversion to sanitary landfills.  However, it
is judged that such conversions are not totally due to the Clean Air Act
but should be allocated to regulations dealing with public health and waste
disposal.  The cost of conversion of open dumps to sanitary landfills for
the period 1970 to  1990 has been estimated to involve a capital  investment
on the order of $5  billion and cumulative total annual costs on the order
of $20 billion (both amounts over the twenty-year period).  These estimated
costs are not reported here as stated above, although the Clean Air Act
has, by prohibition of open burning, contributed to the elimination of open
dumps.

          Regulations.  While some state and local  air pollution control
agencies had established regulations limiting open burning before the 1970
Clean Air Act, the  State Implementation Plans required by the Act
universally included prohibitions on open burning (40 CFR Part 51).  Some
types of open burning may still  be conducted or may be allowed if a permit
is issued.  These include burning in support of crop management, forest
management, petroleum exploration and the flaring of waste gases.   The
practice of open burning for reduction of waste volume and for metal
salvage is generally prohibited throughout the country.

          Industry  Characteristics.   Open burning refers to the  unconfined
burning of any kind of material  or waste, such as leaves, agricultural
waste, domestic waste, etc.  Open burning may be intentional, as in the
case of many open burning dumps, agricultural waste burning, leaf burning,
training fires, etc.  It may also be accidental, as in the case  of forest
fires, coal-refuse  fires, structural fires, etc.

                                  A10.1-1

    -------
          Pollutants and Sources.   Emissions from open burning reflect thi
composition of the material  burned (volume of paper, plastic, wood, rubbe
etc.), and its physical  state (degree of compaction, moisture content,
particulates, carbon monoxide, and hydrocarbons).

          Control  Technology.  There is no control technology that can be
applied to open burning in general.  Many common uses of open burning, su<
as burning for silvicultural, agricultural, range, and wildlife managemen
training fires for firefighters; and heating for outdoor workers, are
allowed only under limited conditions of weather, time, and location.
Other frequent sources of open burning, such as forest fires and
coal-refuse pile fires, are accidental, and are extinguished as soon as
possible.  The only suitable emission control for open dumps is to
substitute the use of sanitary landfills.  For the purposes of this repor
it was assumed that the waste currently going to open dumps would be
diverted to sanitary landfills.

Municipal Incineration

          Regulations.  New Source Performance Standards for particulate
emissions from incinerators with charging capacities greater than 45.36
metric tons (50 short tons) per day were first promulgated on December 21
1971 (36 FR 24876).  Revisions were made in 1974 (39 FR 20790) and 1977 (
FR 37936 and 41424).  The NSPS require particulate emissions to be
controlled to 0.18 grams/dry standard cubic meter (0.08 grains/dry standa
cubic foot) corrected to 12 percent C02-

          States preparing their SIP's in 1971 were provided with a RACT
for particulate emissions from incinerators (Appendix B of 40 CFR, Part
51).  At the time it was promulgated, the RACT stated that the emission o
particulate matter from any incinerator could be limited to grams per
kilogram (0.2 pounds/100 pounds) of refuse charged.

          Many states have specific emission regulations for large
incinerators.  For existing units the particulate emission standards rang
from 0.1 to 0.3 grains per dry standard cubic foot, although some states
have required that existing incinerators achieve the NSPS.

          Industry Characteristics.  There are two basic types of municip
incinerators"!  The refractory-lined furnace is the most common typ*~ in th
country, the other type is the water-wall, or waste-heat recovery tvpe,
more common in Europe.

          Conventional refractory-lined incinerators are usually
continuously fed, large rectangular chambers.  The amount of air supplied
to the combustion chamber is greatly in excess of the amount theoretical!,
needed for combustion.  The excess air serves as a cooling medium, but it
also causes turbulence and entrains large amounts of particular matter.
The air pollution control equipment must be large enough to handle the
great volumes of air and particulates.  With strict air pollution control
requirements, it has become very costly to build adequate air pollution


                                  A10.1-2

    -------
control systems for these incinerators.  The result has been the
substantial decrease in the popularity of the refractory-lined incinerator
noted above.

          Since 1920, 322 municipal-scale incinerators have been built, and
42 modifications have been made to increase the capacity of these
facilities.  By 1972, however, there were-only 193 incinerator plants in
operation.  The number of facilities decreased to 145 in 1974 and 103 in
1977.

          Pollutants and Sources.  Municipal incinerators contribute to air
pollution by releasing a variety of pollutants, but primarily particulates,
to the atmosphere.  The levels of these pollutant emissions are directly
related to the design and operation of the incinerator, as well as to the
composition of the refuse burned.  Particulate limitations generally range
from 80 to 200 grams of particulate per 100 kg (0.08 to 0.2 pounds per 100
pounds) of refuse charged.

          Control Technologies.  Electrostatic precipitators and wet
scrubbers are used to control  particulates.  Most commonly, however,
incinerators are closing, rather than upgrading facilities to meet air
regulations.  Thirty-nine percent (39%) of the operating incinerators
closed from 1969 to 1974.
      s

          The Costing Methodology.  An estimated population of traditional
municipal incinerators was developed and the costs for application of
electrostatic precipitators applied to this sector of operations.  As noted
above, this category of incinerator was considered to decline in numbers
and be replaced by either more modern incinerators discussed below or by
alternative waste disposal such as sanitary landfill.
                                                                 •
Refuse-Fired Steam Generators

          Regulations.  NSPS for non-fossil fuel  fired boilers are under
development.  These standards  will include particulate emission limits for
municipal solid waste and refuse-derived fuels.  Refuse-fired steam
generators are now governed by SIP regulations established for fuel-burning
installations.  The particulate, sulfur dioxide,  and nitrogen oxides
standards for refuse-fired generators are generally less stringent than
those for fossil fuel fired boilers.

          Industry Characteristics.   Domestic, commercial, and industrial
solid wastes contain large quantities of combustible material  which can be
used as fuel in a steam generator.  In some cases, refuse may be the only
fuel or refuse may be supplemental to fossil fuels.  Both cases are covered
in this section.  Other waste-to-energy techniques, such as pyrolysis and
small modular incinerators which recover energy in the form of hot water,
are not covered.

          The amount of recoverable, dry, combustible material  in various
wastes is shown in Table A10.1.1.
                                  A10.1-3

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          It is estimated that solid wastes from the largest metropolitan
areas in the U.S. could be converted to supply a small but significant
percentage of the nation's energy needs.

          Two principal technologies are used for refuse-fired steam
generators.   One is production of steam in a water-wall incinerator,
burning refuse (with or without prior shredding and classification) on
moving grates.  The other technology is the preparation of refuse-derived
fuel (RDF),  which involves shredding, followed by separation of the wastes
into the light organic (fuel) fraction, and the heavy, principally
inorganic, fraction which may undergo additional processing for recovery of
metals and glass.  The RDF is generally suspension-fired in a utility-type
boiler, often as a supplement to fossil fuel.

          As of October, 1979, four refuse-fired water-wall incinerators
and five RDF-fired boilers were known to be in operation.   At lease four
other RDF-fired systems appeared to be close to operation.  Three other
facilities were producing RDF fuel, which was being evaluated as boiler
fuel.  It has been estimated that 30-40 such facilities will be committed
by 1982.

          Pollutants and Sources.  Refuse-fired steam generators emit
principally  particulates, sulfur oxides, and nitrogen oxides.  Uncontrolled
emissions from coal-fired utility boilers and for municipal incinerators
are shown in Table 10.1.2.

          Control Technologies.  Electrostatic precipitators are capable of
meeting the  particulate standards for existing sources.  Most utility
boilers burning supplemental RDF will be equipped with ESP's.  The proposed
regulations  for new sources will necessitate the installation of fabric
filters.  Sulfur oxides are not expected to occur in excess of standards
due to the low sulfur content of solid waste.  Nitrogen oxides emissions
are controlled by maintaining the furnace temperature within a range in
which nitrogen oxides do not form in significant amounts.

          The Costing Methodology.   Costs were estimated empirically.
Costs for pollution control for a typical water-wall incinerator and for a
typical utility boiler burning supplemental RDF are as shown in Table
A10.1.3.

          Total estimated costs for the control of emissions from municipal
incinerators are shown in Table A10.1.4.  These estimated  costs include
both the declining numbers of traditional incinerators 'and the increasing
numbers of steam-generating incinerators.
                                  A10.1-5

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   Table AID.1.3.  Pollution control costs for a typical utility boiler
               burning refuse-derived fuel (in 1977 dollars)


                                          Existing sources     New sources


Water-wall incinerator:    Investment         2,000,000           860,000
                               O&M               14,000            98,000

RDF/Utility                Investment         2,000,000           950,000
                               O&M               14,0.00           100,000
                                 A10.1-7

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    -------
     Chapter A10.2  Industrial, Commercial,  and Building Incinerators
          Revision of this chapter was limited to adjusting the pollution
control costs to 1981 dollars and editing the discussion of regulations.

Regulations

          The NSPS for incinerators, promulgated on December 23, 1971 (40
CFR 60.50) and revised in 1974, sets flue gas concentration limits for
particulate emissions from incinerators with a charging rate greater than
50 tons per day.  Control cost estimates for these large incinerators are
developed in Chapter A10.1.   This chapter presents costs only for
intermediate-sized units.

          Most SIPs have particulate standards for incinerators.  These
standards are expressed in a variety of forms:  on a concentration basis  or
on the basis of process weight rate, gas volume, or control efficiency.
The limits in many SIPs vary with the capacity size and age of the
incinerator.  Some states require that existing larger incinerators meet
the NSPS standard.  Appendix B suggest particulate standards achievable
with RACT (40 CFR 51, App. B).  Many of the state regulations are patterned
after these limitations, which are based on the weight of refuse charged
per hour.

Industry Characteristics

          In 1972, approximately 100,000 on-site incinerators were in use
in this country.  These intermediate-sized units are usually associated
with office buildings, large retail  stores, and apartment buildings.   Of
the over 24 million metric tons (26  million short tons) of solid waste
incinerated annually in the  United States, more than one-third is processed
by on-site units that typically process about 81 metric tons (89 short
tons) annually, or approximately 103 kg (228 pounds) per hour.  States
bordering the Great Lakes (Minnesota, Ohio, Illinois, Wisconsin, Michigan,
Indiana, New York, and Pennsylvania) account for about 60 percent of the
total number of on-site units in the United States.

          There are two types of commercial, building, and industrial
incinerators:  single-chamber and multiple-chamber.   Single-chamber
incinerators are similar to  residential or domestic units and consist of  a
refractory-lined chamber with a grate on which the refuse is burned.
Combustion products are formed by contact between under-fire air and waste
on the grate.  Additional air (over-fire air) is admitted above the burning
waste to promote complete combustion.  Multiple-chamber incinerators  employ
a second chamber to which combustion gases from the primary chamber are
directed for further oxidation of combustible gases.  Auxiliary burners are
sometimes employed, in the second chamber to increase the combustion
temperature.


                                  A10.2-1

    -------
          It is estimated that the use of apartment incinerators, which
account for about 6 percent of installations for refuse disposal, will
virtually disappear during the 1976-85 period.  The number of industrial
and commercial  units should remain stable during that decade because new
installations will primarily be replacements of older units.

          Approximately 88 percent of all on-site incinerators are the
multiple-chamber type; emissions from multiple-chamber incinerators are
generally lower than from the single-chamber incinerators.  The design
capacity of the incinerator considered in this report is from 23 kg (50
pounds) per hour to 1,800 kg (4,000 pounds) per hour, ana the average
incinerator operates from 3 to 5 hours a day.

Pollutants and Sources

          While on-site units emit various products of combustion, only
particulates are released in sufficient quantities to warrant installatio
of controls.  Approximate emission factors for single-chamber and
multiple-chamber incinerators of intermediate size are respectively 7.5 a
3.5 kg per metric ton (15 and 7 pounds per short ton) of refuse charged.

Control Technology

          Operating conditions (e.g., air supply to the combustion
chamber), refuse composition, and basic incinerator design have a
pronounced effect on the volume and composition of air emissions.
Afterburners and wet scrubbers can be installed to control particulate
emissions and some other combustion products.  However, with the shortage
and expense of natural gas and fuel oil, the use of afterburners as
retrofit controls on building incinerators will probably be curtailed.
Furthermore, the newer multiple-chamber units already employ auxiliary
firing techniques which, in effect, fulfill the function of an afterburne

          Wet scrubbers will achieve approximately an 80 percent reductio
in particulate emissions.  This level of control is sufficient to meet
federal particulate emission standards of 2 kg per metric ton (4 pounds pi
short ton) of refuse charged.

Costing Methodology

          The unit investment cost for a wet scrubber required to control
an intermediate size incinerator (approximately 82 metric tons or 90 shor
tons per year) is estimated to be $7,500.  Annual operating and maintenan
costs will be about $1,500 per installation.

          Control costs are detailed in Table A10.2.1.  No costs are show
in the "new plant" category due to the above-mentioned conditions of net
decreasing use of such incinerators.
                                  A10.2-2

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    -------
                     THE COST OF CLEAN WATER



                   REPORT OF THE ADMINISTRATOR

                             OF THE

                 ENVIRONMENTAL PROTECTION AGENCY

                             TO THE

                  CONGRESS OF THE UNITED STATES

                       IN COMPLIANCE WITH

SECTION 516(b)  OF PUBLIC LAW 92-500, THE FEDERAL WATER POLLUTION
                 CONTROL ACT AMENDMENTS OF 1972

    -------

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                                 CONTENTS

Chapter                                                          Page

Wl    Introduction and Summary                                   Wl-1

W2    Government Expenditures for Water Pollution Control        W2-1

W3    Energy Industries                                          W3-1
W3.1  Coal Mining                                                W3.1-1
W3.2  Oil and Gas Extraction                                     W3.2-1
W3.3  Petroleum Refining Industry                                W3.3-1
W3.4  Steam Electric Power Generating Industry                   W3.4-1

W4    Chemicals Industries                                       W4-1
W4.1  Organic Chemicals Industry                                 W4.1-1
W4.2  Inorganic Chemicals                                        W4.2-1
W4.3  Plastics and Synthetics                                    W4.3-1
W4.4  Rubber Manufacturing                                       W4.4-1
W4.5  Soap and Detergent Industry                                W4.5-1
W4.6  Carbon Black Industry                                      W4.6-1
W4.7  Explosives Industry                                        W4.7-1
W4.8  Pesticides and Agricultural Chemicals '                     W4.8-1
W4.9  Fertilizer Manufacturing Industry                          W4.9-1
W4.10 Phosphorus Chemicals Industry                              W4.10-1
W4.ll Paint Formulating                                          W4.11-1
W4.12 Printing Ink Formulating                                   W4.12-1
W4.13 Photograph Processing                                      W4.13-1
W4.14 Textiles Mills                                             W4.14-1

W5    Metals Industries                                          W5-1
W5.1  Ore Mining and Dressing                                    W5.1-1
W5.2  Iron and Steel                                             W5.2-1
W5.3  Ferroalloys Industry                                       W5.3-1
W5.4  Bauxite Refining Industry                                  W5.4-1
W5.5  Primary Aluminum Smelting Industry                         W5.5-1
W5.6  Secondary Aluminum Smelting Industry                       W5.6-1
W5.7  Electroplating and Metal Finishing Industry                W5.7-1
W5.8  Coil Coating                                               W5.8-1
W5.9  Porcelain Enameling                                        .W5.9-1

W6    Mineral-Based Industries                 '                  W6-1
W6.1  Mineral Mining and Processing                              W6.1-1
W6.2  Glass Manufacturing Industry                               W6.2-1
W6.3  Insulation Fiberglass                                      W6.3-1
W6.4  Asbestos Manufacturing                                     W6.4-1
W6.5  Cement Industry                                            W6.5-1
W6.6  Paving and Roofing Materials                               W6.6-1

    -------
                           CONTENTS (Continued)

      Chapter                                                    Page

W7    Forest Products Industries                                 W7-1
W7.1  Timber Products Processing                                 W7.1-1
W7.2  Timber Products Processing:   Wood Furniture and
        Fixture Manufacturing                                    W7.2-1
W7.3  Gum and Wood Chemicals                                     W7.3-1
W7.4  Pulp, Paper and Paperboard                                 W7.4-1

W8    Foods and Agricultural Industries                          W8-1
W8.1  Grain Milling                                              W8.1-1
W8.2  Sugar Processing                                           W8.2-1
W8.3  Canned and Preserved Fruits  and Vegetables                  W8.3-1
W8.4  Canned and Preserved Seafood                               W8.4-1
W8.5  Dairy Products Processing Industry                         W8.5-1
W8.6  Feedlots Industry                                          W8.6-1
W8.7  Meat Products Processing                                   W8.7-1
W8.8  Leather Tanning and Finishing Industry                     W8.8-1

W9    Other Industries                                           W9-1
W9.1  Parmaceutical Manufacturing                                 W9.1-1
W9.2  Hospitals                                                  W9.2-1

W10   Nonpoint Sources                                           W10-1

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                   Chapter Wl  Introduction and Summary


          The Cost of Clean Water Report is written to fulfill the
requirements of the Federal Water Pollution Control Act Amendments
(PL92-500, hereafter noted as FWPCA) of 1972.  Section 516(b) of the
amendments requires the completion of a detached summary of the costs of
meeting the provisions of that Act.

          This report, therefore, provides water pollution control cost
estimates for each industry (or other source category) which incurs high
control costs and/or produces high levels of uncontrolled emissions.  The
costs included in this report are those costs which are directly
attributable to control measures (devices, process changes, etc.) and
program costs for research, administration, and enforcement at the federal,
state, and local  levels.  Sources of water pollution are broken down into
industrial, municipal, and nonpoint source categories.

          The costs included in this report are assessments of what will be
required to meet existing technology and water quality standards and to
provide for replacement and expansion of existing facilities and new
facilities.  They are not based on surveys of actual industry expenditures
nor projected oulays by federal, state, and local governments to construct
or operate wastewater treatment facilities or non-point source controls.

          This report does not attempt to include all  costs associated with
the reduction of the pollution of the Nation's Waterways or costs of
various state and local regulations which preceded federal water pollution
control regulations.  Thus the costs summarized in this document are
restricted to incremental costs which are over and above any control costs
incurred on the level of control practiced prior to the FWPCA.  Incremental
costs were calculated using 1972 as the baseline year.  The estimated
direct cost of measures to control water pollution from industrial and
other sources are calculated within this framework, and investment costs
are projected through 1990.  All abatement costs in this report are stated
in January 1981 dollars.  Where costs are derived relative to another time
period, these costs were updated using the Implicit Price Deflater of the
Gross National Product (Fixed nonresidential  investment part).

          Estimates of the capital investment and annualized costs
required for implementing the .FWPCA in the year 1981 and 1972-78, 1979-81,
1979-84, and 1981-90 are summarized in Table W1.6.  (Annualized costs
include operating and maintenance costs, depreciation  of investments, and
interest charges.)  Each number in Table W1.6 is repeated within the
appropriate chapter of this report where specific assumptions and
background data are presented and discussed.
                                   Wl-1

    -------
          The chapter corresponding to each industry is divided into five
sections:  Regulations, Industry Characteristics, Pollutants and Sources,
Control Technology, and Cost Methodology.  Appendices for each of the
individual chapters are grouped together in a separate volume.  The
appendices contain more detailed cost information, descriptions of
regulations, industry data, assumptions, and references.  A comprehensive
reference list also appears at the end of this volume.  The purpose of tlr
report is to estimate and summarize water pollution control costs for a
very broad range of industries.  The report is not intended to provide
detailed discussions of production processes and the complete range of
applicable control techniques..  Interested readers are encouraged to
consult the references for more complete technical descriptions and
evaluations.

          Note that this report specifically does not dictate EPA policy
with respect to the application of presently available or projected
technology for the control of effluent quality by an industry or activity,
Simplifying assumptions were required in order to estimate the effect of
EPA Regulations on the industries included.  The control technologies, or
mix thereof, which were assumed in order to provide these estimates are
neither specifically required by law nor by EPA; no contrary interpretatit
of the contents of this document should be made.

          The remainder of this introduction is presented in two sections
The first section provides an overview of federal water pollution control
requirements and regulations.  The second section describes the methodolo*
used in this report to estimate water pollution control costs.  These
discussions are presented in this introduction to avoid excessive
repetition within the main body of the report.  A thorough reading of the:
sections will enhance the reader's understanding of the individual
chapters.

Federal Water Regulations

          EPA promulgates regulations limiting the discharge of pollutant
under  Sections 301, 304, 306, 307, and 501 of the FWPCA as amended by the
Clean  Water Act of 1977, Pub. L. 95-217  (The "Act").  The Act requires thi
Agency to promulgate water pollution control limitations for industries
discharging to the Nation's waters.  The promulgation of these limitation
was intended to occur in phases, beginning with limitations based on the
best practicable control technology currently available (BPT) and later
advancing to the best available technology economically achievable (BAT).
Limitations must also be considered for  conventional pollutants such as
biochemical oxygen demand based on the best conventional pollutant contro
technology  (BCT).  New sources are to be regulated under new source
performance standards (NSPS).  The Act also requires the Agency to
promulgate  regulations limiting the discharge of pollutants by industry t
publicly  owned treatment works (POTW).   These limitations are known as
pretreatment standards for existing sources (PSES) and pretreatment
standards for new sources (PSNS).
                                   Wl-2

    -------
          In 1976, EPA was sued by several environmental groups for failure
to promulgate toxic pollutant regulations within the time periods specified
in the Act.   This lawsuit resulted in a Settlement Agreement (also known as
the NRDC Consent Decree) which sets forth a timetable for promulgation of
regulations controlling the discharge of 65 toxic pollutants and classes of
toxic pollutants from 21 major industries.  It also sets forth, in
paragraph 8, bases for an Agency decision not to promulgate regulations for
the various industries or pollutants.  The permissible bases for exclusion
are listed in Table Wl.l.  A list of industries excluded is included in
Table W1.2.   The effect of these exemptions is included in this report.

          Management, technical, and legal difficulties precluded EPA from
incorporating the effects of all of the regulatory changes related to the
NRDC Consent Decree and the Clean Water Act.  In making a decision whether
to revise estimates of an industry's pollution control costs, EPA
considered the industry's contribution to total pollution control costs and
the availability of supporting documents.  The "report status", Table W1.3
provides a summary of the regulatory changes incorporated in the cost
estimates included in this report for the NRDC industries.

          Application of the best available technology economically
achievable (BAT) must be attained by July 1, 1984, for toxic pollutants.
BAT must be achieved for nonconventional  and non-toxic pollutants within
three years  of their establishment or July 1, 1984, whichever is later,
but not later than July 1, 1987..  EPA issued regulations for BAT for some
industries before the NRDC Consent Decree.  Some of these regulations were
directed at conventional pollutants, others at toxic pollutants.  These BAT
regulations  are referred to in the individual chapters as "BAT (old)".
Application of the best conventional pollutant control technology (BCT)
must be attained by July 1, 1984.

Cost Methodology

          Cost estimates for each industry are presented in a table
following the corresponding chapter text.  To estimate compliance costs the
industry is usually divided into a number of sectors.  Sectors are defined
according to production process, control  technology, regulations, available
cost data, or any other factors that can influence costs.  The cost data
for an individual sector may take one of two forms:  "exogenous" total
costs, or cost functions.  The cost methodology section in each chapter
indicates the type of cost data used in that chapter.

          Exogenous costs are calculated outside the computer model  for the
report.  The exogenous form is sometimes used because the complexity of the
chapter precludes the use of cost functions alone.  In other instances,
these costs are taken from a detailed economic study of the industry
commissioned by the EPA.  The use of these studies improves the consistency
and coherency of this report with other EPA publications.  Some of these
economic reports may not provide detailed information about control  costs.
In these cases the reported costs do not necessarily conform to the
standard format, e.g., new plant costs may not be separately identified,
although costs projected into the future include costs for both new and

                                   Wl-3

    -------
Table Wl.l.
Permissible bases for exclusion of toxic pollutants
industry subcategories from regulation If
and
      equal or more stringent protection is already provided by
      the Agency's guidelines, limitations, and standards under
      the Act [8(a)(l)];

      except for pretreatment standards, a specific pollutant is
      present in the effluent discharge solely as a result of its
      presence in intake waters taken from the same body of water
      into which it is discharged; [8(a)(ii)];

      for pretreatment standards, the specific pollutant is
      present in the effluent which is introduced into a POTW
      solely as a result of its presence in the point source's
      intake water [8(a)(ii)];

      a pollutant is not detectable with the use of analytical
      methods approved pursuant to 304(h) of the Act, or where
      approved methods do not exist, with the use of
      state-of-the-art analytical methods [8(a)(iii )];

      a pollutant is detectable from only a small number of
      sources within a subcategory and the pollutant is uniquely
      related to those sources [8(a)(iii)J;

      a pollutant is present only in trace amounts and is neither
      causing nor likely to cause toxic effects [8(a)(iii)];

      the pollutant is present in amounts too small to be
      effectively reduced by technologies known to
      Administrator [8(a)(iii)];

      the pollutant will be effectively controlled by the
      technologies upon which other effluent limitations and
      guidelines, standards or performance, or pretreatment
      standards are based [8(a)(iii)];

      the amount and toxicity of each pollutant in the discharge
      does not justify developing national regulations in
      accordance with the Settlement Agreement schedule
       for  pretreatment standards, if 95 percent or more of the
       dischargers  in the  industrial category or subcategory
       discharge pollutants into publicly owned treatment works and
       the  pollutants are  susceptible to treatment by such
       treatment works and do not interfere with, do not pass
       through, or  are not otherwise incompatible with the
       treatment works [8(b)(i)J;
                                                     Continued ----
                             Wl-4

    -------
                        Table  Wl.l.   (Continued
          for pretreatment standards,  if the  amount  and  toxicity  of
          incompatible pollutants  discharged  to  publicly owned
          treatment works  is  so  insignificant as not to  justify
          developing pretreatment  standards  in accordance with the
          schedules in the Agreement [8(b)(ii)].
If  Paragraph 8 of the NRDC consent  decree.
                                 Wl-5

    -------
         Table  W1.2.   Industires  excluded from further regulation
        under provisions  of paragraph  8  in the NRDC Consent Decree
                              (modified  1979)
                                                          CFR part
                    Industrial  category                     number
          Adhesives  and sealants                              456

          Auto and other laundries                           444

          Carbon  black                                        458

          Explosives manufacturing                           457

          Gum and wood                                        454

          Ink formulation                                    447

          Paint formulation                                  446

          Paving  and roofing                                 443

          Photographic  equipment  and supplies                459

          Printing and  publishing                            448

          Rubber  processing                                  428

          Soaps and detergents manufacturing If              417


If  Exclusion only from those SIC's addressed in the Consent Decree.
                                 Wl-6

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    -------
existing plants.  Similarly, the source document may not use the same
breakdown of annual costs or the same interest rate as is normally used it
the existing computer model.  Nevertheless, the overall costs and timing <
the costs are reported as developed in the designated source document.

          Costs in most chapter sectors are generated from cost equations
that express control costs as a function of plant capacity.  (Larger plan-
usually benefit from economies of scale.)  In most cases future cost
estimates are based on the assumption of continued application of current
technologies.  Capital and operating and maintenance costs are calculated
separately.  The computer program computes total industry costs by applyi
the cost functions to industry plant data, taking into account compliance
schedules estimated by the chapter author.  The cost functions, which are
based on engineering model plant costs, are expressed in a standard
exponential form:  Cost - AX , where X is a measure of capacity.  O&M cos-
are adjusted according to estimates of capacity utilization percentages.
Industry plant data include the plant population for a base year,
historical growth rates, and expected future growth rates.  Compliance
information is simply the percentage of the plant population that complie<
with a regulation in each past year and estimates of the percentage that
will comply in each future year.  These estimates are based on the
compliance date specified in the pertinent regulation, allowing for lead
time required to construct and install the control technology required.
New plants are assumed to comply upon construction.

          To calculate the annual cost of capital, the computer program
uses the stated life of the control equipment and an interest rate of ten
percent.  It is understood that other systems of depreciation are used,
that other interest rates are sometimes applicable, that "opportunity
costs" for other uses of capital are not taken into account, and that tax
write-offs are commonly applied to control equipment.  The ten percent
interest rate is used as a "compromise" value which is intended to reflec
an average value of the highly varied individual cases.

          The computer program also calculates the cost of replacing
control equipment at the end of its useful life.  These costs are assumed
to be some fraction of the original cost of equipment as certain elements
such as the foundations, do not need to be replaced.

          The program excludes costs associated with water pollution
control that would have been incurred without the inducement of federal
regulations.  It does this by excluding from the plant population a
precompliance fraction that is provided by the chapter author.  This
fraction represents plants that either can comply with the applicable
regulation without installing controls or plants that installed controls
even in the absence of regulations.

          Wastewater treatment costs estimated in this report do not
reflect any actions taken by industrial plants to decrease overall
wastewater discharge after promulgation of regulations.  Consequently, thi
cost estimates may be overstated.  While it is beyond the scope of this
report to account for this type of overestimate, data collected by the

                                   Wl-10

    -------
Bureau of Census indicate that the amount of water which is discharged by
industry is decreasing.  This finding implies that industry may be
instituting water conservation measures.

          Tables W1.4 and W1.5 reveal wastewater discharge data collected
by the Bureau of Census for 1973 and 1978.  The intake and discharge status
of the industry when the Clean Water Act was passed is represented by 1973
data, while the data which are representative of intake and discharge
status after the issuance of BPT regulations and permits are shown for the
year 1978.

          Table W1.4 indicates that gross water intake and total water
discharged declined from 1973 to 1978, by 14 percent and 17 percent
respectively.  The sources of wastewater by last use are shown on Table
W1.5.  This table indicates that only two source categories have
experienced an increase in water discharge since 1973.

          The data collected by the Bureau of Census imply that BPT costs
may be overstated due to decreases in the discharge of contact cooling
water (water that comes into direct contact with raw material, intermediate
product, waste product or finished product), which EPA regulations
generally control.  However, the amount of the potential overstatement of
costs is unknown, since the data collected by the Bureau of Census does not
delineate between contact and non-contact cooling water.

          The cost methodology differs from that followed in the August,
1979 report in that it:

          (1) includes estimates of replacement costs,

          (2) does not assume that any fraction of industry was controlling
             emissions to the level set by New Source Performance Standards
             before the promulgation of these standards.
                                   Wl-11

    -------
           Table W1.4.   Wastewater intake and discharge summary
                                   1973
                 1978
                % Chang
Establishments Reporting
  Water Intake of 20
  Million Gallons

Gross Water Intake
  (Billion Gallons)

Gross Water Intake Per
  Establishment
  (Billion Gallons)

Total Water Discharged
  (Billion Gallons)

Water Discharged Per
  Establishment
  (Billion Gallons)

Treated Wastewater
  Discharged
  (Billion Gallons)

Untreated  Wastewater
  Discharged
  (Billion Gallons)
10,668



15,024


  1.41
 6,156
 7,987
 9,605



12,992


  1.35
 4,709
 6,973
-10



-14


 -4
14,144
1.33
11,682
1.22
-17
-8
 -8
-13
Source:   U.S. Department of Commerce, Bureau of the Census, "1977 Census
          of Manufactures; Water Use in Manufacturing."  MC77-SR-8 (Augu;
          1981).
                                 Wl-12

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    -------

    -------
      Chapter W2  Government Expenditures for Water ^Dilution Control
Introduction

          Government funds for water pollution cont ol are spent for three
major purposes:

          •  To conduct programs of monitoring, enf rcement, technical
             assistance, grant assistance, and rese rch,

          •  To abate pollution created at governme :-owned facilities, and

          •  To treat wastewater at municipal treat ant facilities.

          Generally, states have primary responsibi ity for monitoring and
enforcement, with financial and other assistance pr /ided by the federal
government.  Research is conducted primarily by the federal government, and
treatment of municipal wastewater is the responsibi ity of local and state
governments, with major financial assistance from t 2 federal and state
governments.
Federal and State Pollution Control Expenditures
          Summary.  Federal and state government ex
pollution control are summarized in Table W2.1 for
1990.  Actual incremental expenditures, in 1981 do!
1972 through 1981.  Projections are shown for 1982
pollution control expenditures are detailed for aba
monitoring, and research and development.  Federal
program costs and expenditures by other federal age

          Definitions.  Abatement is any direct act
emission of pollutants at federal installations.  R
is a governmental activity that is indirect in the
that others take action to reduce pollutant emissic
monitoring includes monitoring point discharges, te
pollution, developing and reviewing standards, issu
enforcing existing standards.   Research and develop
the purpose of finding and demonstrating new and be
techniques.

          Federal Program Costs.   Federal pollution
responsibilities, exercised primarily through the U
Protection Agency (EPA), encompass a broad range of
particularly since enactment of the Federal Water P
Amendments of 1972 and 1977.  Compliance is encoura
other types of assistance, and it is required throu
anditures for water
alendar years 1972 to
ars, are reported for
hrough 1990.  Federal
ament, regulation and

    -------
          Assistance Programs.  The EPA conducts several assistance
programs, including grants for wastewater treatment facilities, grants fo
regional water quality planning program development, technical assistance
and manpower development.

          The construction grants program for wastewater treatment
facilities is by far the largest federal pollution control assistance
program.  The level of assistance under this program has gradually
increased since the first permanent federal pollution control legislation
was enacted in 1956.  A variety of projects are eligible for funding,
including treatment plants and interceptor sewers.  Federal, state, and
local government expenditures for wastewater treatment facilities are
discussed in this chapter under Municipal Pollution Control Expenditures
and are not included in the expenditures shown in Table W2.1.

          The EPA also provides program grants to assist the state,
interstate, and regional agencies in the expansion and improvement of a
variety of activities essential to the control of water pollution.  These
activities include water quality planning and standards setting,
surveillance, enforcement, issuance of permits, executive management, anc
administration of the construction grants program.  The level of assistar
varies from one activity to another, as well as from year to year.

          Technical assistance is another program receiving major EPA
attention.  Many pollution problems are too complex for states,
communities, and industries to handle alone.  The EPA offers assistance  •
such cases by providing services ranging from technical advice and
consultation to extensive, long-term field and laboratory studies.  With-
the limits of available resources, this assistance is provided on reques-
primarily to the states and municipalities.

          Federal expenditures for assistance programs related to planni
technical assistance, and manpower development are included in the
regulation and monitoring category in Table W2.1.

          Regulatory Programs.  To facilitate enforcement of the many ne\
pollution control requirements, the Federal Water Pollution Control Act
Amendments of 1972 and 1977 replaced former enforcement authorities with
new authorities and provided a new regulatory scheme based largely on ttr
imposition of specific requirements through a system of permits termed t
National Pollutant Discharge Elimination System (NPDES).  Permit conditii
and other requirements of the Act are enforceable through EPA compliance
orders and civil suits.  Violators are subject to penalties.  A state ma;
assume this responsibility if it meets certain requirements, including t
capability and authority to modify, suspend, or revoke a permit, and it
the powers and procedures necessary for criminal  penalties, injunctive
relief, and other enforcement mechanisms.

          The Act also required federal agencies to comply with federal,
state, interstate, and local pollution control and abatement requirement
to the same extent as any person must comply.  The EPA's role stems from
the Act and is amplified in Executive Order 11752.  This role also inclui
                                   W2-2

    -------
       Table W2.1.  Federal and state government incremental water
         pollution control expenditures (historical and projected
                    costs in millions of 1981 dollars)
                Federal Expenditures _!/
Year   Abatement
        Regulation
            and
        monitoring
           Research
              and
          development
          Federal
           total
            State
        expenditures
            Total
1972
1973
1974
1975
1976
1977
1978
1979
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
137
242
325
393
355
365
383
386
279
236
236
236
236
236
236
236
236
236
236
Total     5,225
  154
  186
  228
  226
  213
  195
  230
  264
  340
  293
  293
  293
  293
  293
  293
  293
  293
  293
  293

4,966
   66
  117
  132
  114
  118
  120
  129
  134
   99
  121
  121
  121
  121
  121
  121
  121
  121
  121
  121

2,239
   357
   545
   685
   733
   686
   680
   742
   784
   718
   650
   650
   650
   650
   650
   650
   650
   650
   650
   650

12,430
  215
  233
  220
  214
  275
  323
  292
  241
  232
  231
  231
  231
  231
  231
  231
  231
  231
  231
  231

4,555
   572
   778
   905
   947
   961
 1,003
 1,034
 1,025
   950
   881
   881
   881
   881
   881
   881
   881
   881
   881
   881

16,985
\J   Excludes construction grant costs which are included in the municipal
     cost section and state program grant costs which are included in the
     state totals.

Source:   1972-1981 data are from Rutledge, Gary L., "Pollution Abatement
          and Control Expenditures in Constant and Current Dollars,
          1972-1981," Survey of Current Business, February 1983.
          Projection for 1982-1990 assume a continuation of the 1981 levels
          of expenditures.  Historical costs for 1972-1981 and projected
          costs for 1982 were adjusted by inflation factors to obtain costs
          in 1981 dollars.  For updated water pollution control
          expenditures, refer to the February 1984 Survey of Current
          Business, "Pollution Abatement and Control Expenditures,
          1972-1982," by Gary L. Rutledge.
                                  W2-3

    -------
reviewing the compliance of federal  facilities with applicable standards,
providing guidance to the federal  agencies for implementing provisions of
the Order, coordinating the compliance actions of federal  agencies with
state and local  agencies, and furnishing technical  advice on waste
treatment technology.

          State  Program Costs.   Although the federal  government has taken
increasing responsibility in dealing with water pollution, the states
continue to bear the major share of the responsibility.   States inherently
have broad powers to deal with water pollution, and these powers, together
with delegated federal authorities,  place the states  in  a strong position
to regulate all  sources of pollution.  State powers and  responsibilities
under the Act are exercised through  a broad range of activities, including

          •  Preparation of an annual strategy and program report that
             describes the interim goals to be achieved  during the year,
             the state resources to be assigned in meeting the goals, and
             the method of assigning resources.

          •  Development of basin water quality management plans, as
             required by Section 303(e) of the 1972 Act.  These plans are
             designed to be the central management tools of the states in
             administering their water quality programs.

          •  Review of areawide waste treatment management plans called fo
             by Section 208 and prepared by local agencies.

          •  Administration of the construction grants program, including
             the responsibility for assigning priorities to the projects
             eligible for federal financial assistance.   It is intended
             that certain federal responsibilities, such as review of plan
             and specifications, be transferred to the states as they are
             able to assume them.  Some states provide funds to assist
             communities in constructing waste treatment works.  Primary
             responsibility for monitoring municipal  treatment plants to
             see that they operate correctly also rests  with the states.

          •  Planning and implemention of programs for control of nonpoint
             sources of pollution.

          •  Administration of the NPDES permit program.  Some states have
             assumed, and others are in the process of assuming this
             responsibility.  States that have assumed responsibility for
             this program have concurrently assumed extensive enforcement
             responsibilities associated with permit compliance.

          •  Shared  responsibility, with the federal  government, for
             enforcement.

          •  Establishment and implementation of water quality standards.
             Under the 1972 Act, such standards are extended to intrastate
             as well as interstate, waters.
                                   W2-4

    -------
          •  Monitoring and surveillance functions to identify and assess
             existing and potential water pollution problems, and also to
             measure the effectiveness of the permit and construction
             grants program.

          Municipal Pollution Control Expenditures

          Introduction.  The 1972 amendments to the Clean Water Act
established technology objectives and water quality objectives for
controlling pollution from municipal sources.  The objectives were restated
and clarified by the 1977 amendments to the Act.  The technology objectives
require that all publicly owned wastewater treatment works be upgraded to
secondary treatment levels by 1977 and best practicable wastewater
treatment levels by 1983.  Currently, secondary treatment (85 percent
removal of organic and suspended solids waste loads, with the plant
effluent quality not to exceed 30 mg/1 for both BODr and suspended solids,
and pH between 6.0 and 9.0) is considered equivalent to best practicable
treatment.  In addition, publicly owned treatment works must control  their
waste discharge as necessary to meet water quality standards by 1983.
These standards are based on achieving a level  of water quality that  will
provide for the protection and propagation of fish, shellfish, and
wildlife, and will provide for recreation in and on the water.  This
section reports the costs associated with meeting these dual objectives in
Table W2.2, with the exception of those costs incurred in the treatment and
control of stormwaters.

          Defining and Measuring Need.  The 1982 Needs Survey, a joint
State/EPA activity, conducted in compliance with Sections 205(a) and
516(b)(2) of the Act, requested that municipal  treatment authorities  and
the U.S. EPA estimate the expenditures required to meet existing technology
and water quality standards and to provide for replacement or expansion of
facilities as necessary to serve the population projected to 2000.  Thus, a
"need" consists of the resources associated with the upgrading,
replacement, expansion, or construction of treatment facilities which
federal, state, and local governments consider to be necessary, based upon
the federal standards, or more stringent state standards.

          Details of the Needs Survey may be found in a separate report,
"1982 Needs Survey—Cost Estimates for Construction of Publicly-Owned
Wastewater Treatment Facilities," EPA-430-9-82-009, December 31, 1982.

          Defining Cost.  The estimate of municipal costs is based on an
assessment of the expenditures that will be required to meet existing
technology and water quality standards and to provide for replacement or
expansion of wastewater treatment facilities.  It is not an estimate  of
projected outlays by federal, state, and local  governments to construct or
operate these facilities.  During the period 1971 through 1982, federal
outlays or construction grants amounted to roughly $30 billion.  Assuming a
state cost share of 25 percent would'bring total outlays to $40 billion.
                                   W2-5

    -------
       Table W2.2.  Total  municipal  expenditures for water pollution
              control  I/ (historical  and projected costs in
                         millions of 1981 dollars)
          Year
    Capital
expenditures 2/
Operation and
 maintenance
1972
1973
1974
1975
1976
1977
1978
1979
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
1991-2000
6,258
6,774
7,476
7,709
8,192
7,828
9,114
9,084
8,198
6,539
5,936
5,936
5,936
5,936
5,936
5,936
5,936
5,936
5,936
59,360
2,193
2,459
2,657
2,719
3,031
3,384
3,670
3,875
4,099
4,492
4,640
4,891
5,143
5,394
5,645
5,897
6,148
6,399
6,651
80,330
          Total
    189,962
  163,717
_!/   Expenditures apply to wastewater treatment facilities and sewer
     systems, but do not include costs incurred for stormwater control
     systems.        '

2J   Capital expenditures include funds from federal construction grants
     and matching funds from state and local governments.

Sources:  1972-1981:  Rutledge, Gary L., "Pollution Abatement and Control
          Expenditures in Constant and Current Dollars," 1972-81, "Survey
          of Current Business," February 1983 (current dollars were
          converted to 1981 dollars for Table 2.2).

          1982-2000:  Capital expenditure projections are based on needs 0'
          $112.79 billion in 1981 dollars and an assumption of uniform
          annual expenditures.  The needs are based on the estimate of
          $118.35 billion in 1982 dollars, as given in U.S. EPA, 1982 Need'
          Survey - Cost Estimates for Construction of Publicly-owned
          Wastewater Treatment Facilities, December 31, 1982, p. 6.
          Operation and Maintenance (O&M) cost projections are based on
          extrapolation of 1972-1981 data by least squares linear
          regression.  Although some of the capital expenditures will be
          for new facilities to replace obsolete existing facilities and
          O&M costs would not be expected to increase for such new
          facilities, this condition has existed in the past.  Therefore,
          annual increases in O&M costs according to historical trends are
          expected.
                                   W2-6

    -------
          Not all costs reported herein are proper!;
standards created under the authority of P.L. 92-5CK
attributable to those standards are incremental.  Or
associated with upgrading from an existing level of
level of treatment necessary to meet technology and
objectives are properly attributable to the standan
replacement of facilities built prior to 1972 which
different level of treatment, the cost associated w
treatment than would otherwise have been achieved ir
1972, and the cost associated with a higher level o-
necessary to meet the standards should be excluded •
attributed to meeting standards.  However, since Se<
assessment of the costs of "carrying out the provis
the construction grant program is an integral part <
range of costs attributed to that program are repor

          Actual capital expenditures and operation
in 1981 dollars, are reported in Table W2.2 for 197;
Projections are given for 1982 to 2000.

          Categories of Need.  The joint State/EPA i
constructing publicly owned treatment works needed •
of the Act are divided into six major categories wh
1982 Needs Survey.  All six categories are briefly <

          Category I.  Secondary Treatment.  This C£
costs which facilities incur to achieve  secondary
regardless of the treatment levels required at the :
sewers are also included in this category.  Incremet
levels beyond secondary treatment were reported in (

          Costs for systems designed to serve indiv
reported in Category I.  For purposes of the Survey
wastewater treatment technology (BPWTT)" and second;
considered synonymous.

          Category IIA.  Advanced Secondary Treatme-
costs which are incurred to achieve advanced second,
are reported for those facilities that must achieve
requirement generally exists when water quality stai
of standard pollutants at levels higher than 85 pen
than 95 percent removal, or 10/10.

          Category IIB.  Advanced"Treatment (AT).
those incurred in Category IIA are reported for fac'
advanced levels of treatment.  This requirement gem
water quality standards require removal of such pol
ammonia, nitrates, or organic and other substances.
requirement exists where removal requirements for cc
exceed 95 percent.
attributable to the
  The costs
y those costs
reatment to a higher
ater quality
.  Thus, costs for
o not require a
h the lower level of
facilities built after
treatment than is
om the costs
ion 516(b) directs
ns of the Act," and
 the Act, the entire
d herein.

nd maintenance costs,
through 1981.
timates of the cost of
 meet the 1983 goals
h are outlined in the
scribed below.

egory includes the
vels of treatment,
cility site.  Outfall
al costs for treatment
tegories IIA and IIB.

ual residences are
"best practicable
y treatment were
 (AST).  Incremental
y levels of treatment
nese levels.  This
ards require removal
nt or 30/30, but less
cremental costs above
ities which require
ally exists where
tants as phosphorus,
In  addition, this
ventional pollutants
                                   W2-7

    -------
          Category IIIA.  Correction of Infiltration/Flow.  These costs a
for correction of sewer system infiltration/inflow problems.  Costs are
also reported for preliminary sewer analysis and a detailed sewer system
evaluation survey.

          Category IIIB.  Major Rehabilitation of Sewers.  Requirements f
replacement and/or major rehabilitation of existing sewage collection
systems are reported in this category.  Costs are to be reported if
corrective actions are necessary to maintain the total integrity of the
system.  Major rehabilitation is considered extensive repair of existing
sewers beyond the scope of normal maintenance programs, e.g. where sewers
are collapsing or are structurally unsound.

          Category IVA.  New Collector Sewers.  This category consists of
the costs of constructing new collection systems in existing communities,
and appurtenances designed to correct violations caused by raw discharges
The cost of protecting public health from such things as malfunctioning
septic tanks is also included.

          Category IVB.  New Interceptor Sewers.  Included in this catego
are costs for new interceptor sewers and transmission pumping costs
necessary for bulk transport of wastewaters from collector sewer systems
treatment facilities.

          Category V.  Control of Combined Sewer Overflow (CSO).  Costs
reported for this category are to prevent periodic bypassing of untreatec
wastes from combined sewers to an extent violating water quality standarc
or effluent limitations.  This*category does not include treatment and/or
control of stormwaters in separate storm and drainage systems, nor costs
for flood control or drainage improvement.

          Category VI.  Control  of Stormwater Runoff.  Costs in this
category are for abating pollution in urbanized areas from stormwater
runoff channeled through sewers and other conveyances used only for such
runoff.  The costs of abating pollution from stormwaters channeled throuc
combined sewers that also carry sewage are included in Category V.
Category VI was added so the survey would provide an estimate of all
eligible facility costs, as explicitly required by P.L. 93-243.

          The estimates were reported in January 1982 dollars, and the
present population was defined as the U.S. population as estimated by the
1980 Census.  The future population was projected for the year 2000 by th
Bureau of Economic Analysis.

          Results of the Survey.  The results of the 1982 Needs Survey ar
presented in Table W2.3 in aggregate national totals, by category.  Varic
subtotals are presented to give an indication of needs versus priorities.
State-by-state data for the same categories may be found in the
aforementioned separate report.  '

          Assessment of Backlog.  An addition to the Needs Survey in 1976
was the assessment of need for present populations (the backlog of need).


                                   W2-8

    -------
    Table W2.3.   Summary table of national  estimates for construction
             of publicly-owned wastewater treatment facilities
                        (billions of 1981 dollars)
Needs category
I (Secondary Treatment)
IIA Advanced Secondary Levels
I IB Advanced Treatment Levels
IIIA (Infiltration/Inflow)
1 1 IB (Replacement/Rehabilitation)
IVA (New Collector Sewers)
IVB (New Interceptor Sewers)
V (Combined Sewer Overflows)
Total Treatment (I, II)
Total I, II, IIIA and IVB
Total I-V
2000 EPA
assessment
29.67
4.64
.83
2.44
4.47
19.69
16.99
34.06
35.14
54.57
112.79
Backlog
estimate
19.18
3.10
.50
2.44
4.47
15.98
8.51
34.06
22.79
33.74
88.25
Source:    U.S.  EPA 1982 Needs Survey - Cost Estimates  for Construction  of
          Publicly-Owned Wastewater Treament Facilities,  December 31,  1982
          p.  6.
                                  W2-9

    -------
This assessment was retained in 1982r and the needs for the present
population, Categories I-V, are estimated to be $92.60 billion.  Note the
because combined sewer systems are no longer built, Category V needs are
exclusively backlog needs.

          The costs reported for the backlog are sufficient only for the
facilities necessary to serve the 1980 population.  They do not include e
costs for the reserve capacity which would be required by the Act to be
included in these facilities for population growth beyond 1980.  They als
exclude estimates for treatment and sewers that were not necessary in 19£
but are projected to be necessary for populations in the year 2000.

Aggregate Costs

          The aggregate costs reported in Table W2.4 include the followir
components:

          t  Federal and state program expenditures as listed in Table
             W2.1, which are taken as operating costs

          •  Municipal expenditures as listed in Table W2.2, divided
             between Capital Investment (including construction grants) c
             O&M costs as shown in that table.
                                   W2-10

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    -------
                      Chapter W3.   Energy Industries


          For the purpose of this  report, the broad category "Energy
Industries" was defined to include those industries that gather,  transfer,
process, and deliver energy to the ultimate user.   These include:

          •  Coal Mining
          •  Oil  and Gas Extraction
          0  Petroleum Refining
          •  Steam-Electric Power  Generation

          Costs for the reduction  of water pollution for these industries
are summarized in Table W3.  These costs and other data are  repeated below
in the appropriate sections together with the assumptions specific to the
industry and other details.
                                   W3-1

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                                                          wa-a

    -------
                          Chapter W3.1  Coal Mining
Regulations
          Regulations affecting this industry were revised under the
provisions of the NRDC Consent Decree.  EPA promulgated BPT, BAT, and NSPS
in November 1982 for the coal mining industry.  However, revision of this
chapter was limited to adjusting pollution control costs to 1981 dollars.
The effect of any changes in the regulations affecting the coal mining
industry is not reflected in the text of the chapter or the cost estimates
included in Table W3.1.1.  The cost estimates represent the impact of BPT
regulations promulgated and BAT and NSPS regulations proposed in 1975.

Industry Characteristics

          Control costs are based on the assumption that industry capacity
will grow from its 1976 level of 735 million metric tons (820 million short
tons) to 920 million metric tons (1.03 billion short tons).

Pollutants and Sources

          The disruption of the earth's surface by mining operations causes
chemical and physical modifications that often adversely affect both
surface- and ground-water resources.  The major causes of concern are
sedimentation from disturbed areas and acid mine drainage discharges.

          Although coal mining activities exist in numerous states, acid
mine drainage is a more critical problem in the eastern coal fields.
Because of limited coal production, variations in mining practices, lack of
precipitation, abundance of limestone, high natural alkalinity of surface
water, and scarcity of acid-forming materials in some coal  producing areas,
the distribution of acid mine drainage varies markedly from state to state
and within the states.  While significant areas of disturbed land may be
identified in most states, the estimated costs of abating acid mine water
pollution developed for this report are based on the treatment of water
from active operations, assuming compliance with all  promulgated (BPT) and
proposed (BAT, NSPS) regulation.

Costing Methodology

          Bituminous and Lignite Coal Control Costs.   Mine water must be
pumped out to allow mining to continue.This technique is  also used to
prevent aquifers from being polluted by metals in solution, COD, and acid
formation (although flooding the mine may also prevent acid formation).   To
develop costs for BPT, BAT, and NSPS compliance, "Economic Document" model
plants and costs were used for BPT and NSPS compliance levels.  For BAT
compliance costs, neutralization equipment, chemicals, and distribution
piping and pumps remained the same but the settling pond was doubled in
size and cost, and limited amounts of flocculation agents were added.  To

                                  W3.1-1

    -------
determine costs for BPT and BAT level  compliance, production for 1976,
1982, and 1986 was split into Targe, medium, and small  model mines.  It w<
assumed that all mines will require treatment at least for suspended soli<
and pH.

          Anthracite Coal  Control  Costs.   Anthracite coal is showing a lo
term decreasing production trend.   Control costs were estimated using modi
facility costs as in the previous  section.  In estimating mine pumpout
treatment costs it was assumed that 42 percent of yearly production is
surface mined and 10 percent is deep mined (the remainder is assumed to t>
comb, bank, and auger mined).  Because the production rate of anthracite
decreasing, it was assumed that treatment facilities equivalent to 6.4
million metric tons (7 million short tons) per year capacity would be
required to install water treatment facilities.

          This methodology has overstated costs in that many cleaning
plants are at the "mine mouth", and mine pumpout is often used as process
water in the cleaning plant (the effluent then needs treatment only once)

          The resulting estimated costs of compliance are listed in Table
W3.1.1.
                                  W3.1-2

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                                                                      W3.1-3

    -------
                   Chapter W3.2  Oil and Gas Extraction
Regulations
          Proposed regulations for NSPS, BAT, and pretreatment for the
industry covered in this chapter were revoked.  In addition, existing BPT
standards have been revoked for some subcategories.  The Agency is
developing guidelines for NSPS and investigating the need for BAT
requirements.  Because of the uncertainty regarding future pollution
abatement requirements this chapter has not been updated.  The costs shown
are for the BPT requirements.

Industry Characteristics

          The extraction of gas and oil through the use of conventional
wells, the subject of this chapter, constitutes all of the commercial
activity in SIC category 1311 since the other activities (producing oil
from oil sands and oil shale) are at the present time only in the research
and development stage in the United States.  The extraction of oil and gas
consists of the production from wells onshore and offshore.  The largest
number of wells are onshore or in coastal waters.   Most of the far-and
near-offshore platforms are located in the Gulf of Mexico off the coast of
Louisiana.  The offshore wells beyond the historic state limit, in what is
known as the Outer Continental Shelf (or Far Offshore) Waters are under
Federal jurisdiction.  Wells in Offshore waters inside the State limit are
classified as being in Near Offshore Waters.  The bayous and estuaries of
Louisiana and Texas are known as Coastal Waters.  In the Coastal Waters,
things are complicated because water from a well onshore may discharge its
formation water to a nearby bayou or a platform built out in the water may
pipe its formation water onshore for treatment followed by dumping or
injection.  The onshore wells can be subdivided into stripper wells, wells
with beneficial use of formation water, and other nonstripper wells.
Stripper wells are those that produce 10 barrels of oil per day or less.
Wells that produce water that is sufficiently low in salinity that it can
be used for agricultural or livestock watering purposes constitute the
beneficial use category.  The balance of the onshore wells in the United
States can be categorized as other nonstripper onshore wells.  The
pollution regulations discussed below are grouped by these categories.

          The interrelation of gas and oil  production is complex.   When oil
and gas are found together, the usual case, the gas is spoken of as being
associated gas.  Gas from wells having no oil production is called
nonassociated gas.  However, the nonassociated gas has a high content of
vapors of petroleum liquids; before the natural gas is put into the
pipeline, these vapors are condensed and sold as natural gas liquids.
(This activity is discussed in the section of the Clean Air Report on
                                  W3.2-1

    -------
Natural  Gas Processing).   Some oil  wells have so little associated gas the
it is not economical  to bring this  gas to a pipeline.

          Gas wells have been included for the offshore region since these
data were readily available and the costs of the proposed regulations are
high.  Nonassociated  gas wells onshore have been ignored in this study as
well as  in the EPA studies done previously since the pollution problems
involved are minor.

Pollutants and Control  Technology

          The chief pollutant from the operation of oil and gas wells
onshore  is the brine  that is produced with the oil  and gas.  (In certain
areas of the West, the water is low in salts and is acceptable for wateri
stock.)   There are a  number of ways to handle brine produced onshore.  It
can be stored in a pit and allowed  to evaporate, or it can be reinjected
beneath  the surface.   The last is by far the most common disposal
technique.

          Although the salts in the brine are nonpolluting when added to
ocean water, the oil  dispensed in the brine is a potential pollutant.  Th'
oil-laden water can be treated with coalescents and dissolved air flotati'
equipment to lower the oil content  to an acceptable level before discharg
to the ocean.  If complete elimination of oil discharge is desired,
injections into underground strata  can be used, although this is expensiv
especially if the well  is in deep water.  In the regions close to shore,
is also  possible to send the water  ashore by pipeline for treatment
followed by dumping,  reinjection, or by evaporation from a pit area.

          One way to  increase the total amount of oil  that is recovered i
to inject water into  the formation, a process known as water flooding.
Very frequently, the  production water is reinjected.  Since this is an
economic use of the water and is not related to the pollution abatement
that is  obtained as an incidental by-product, the cost of reinjection for
purposes of secondary recovery is not included in this report.

          Another source of pollution is oil from drill cuttings and from
spent muds that are discharged.  Water-based muds and drill cuttings can
washed before dumping offshore.  Onshore, they can be landfilled.
Oil-based muds used offshore can be collected and hauled ashore and then
disposed of in a landfill.  Hauling to shore is also used to dispose of
refuse and toxic chemicals from platforms.  Water running off the deck of
platform is another possible source of pollution since the deck is
frequently spotted with oil.  Deck  washings and rainwater can be collecte
and treated in the same manner as the produced water.   Another potential
source of water pollution is the sanitary sewage water.  This can be
treated, chlorinated and discharged.  All of the above potential sources
pollution are from activities that  are more or less expected in everyday
operations.  The prevention of blowouts and catastrophic spills is not
treated here.
                                  W3.2-2

    -------
Costing Methodology

          Each of the states where oil and gas is produced has its own set
of regulations governing the discharge of water, casing depth, and
reinjection of water, as well as the disposal of solid waste from drilling
and operation of the well.   Since the coastal states have jurisdiction out
to their historic boundary (usually 3 miles, but in the case of Texas, 9
miles offshore), they also promulgate regulations concerning possible
pollutants from offshore oil and gas rigs and platforms in the coastal and
near offshore waters.  The State of California has a limit of 20 parts per
million for the long-term average of oil  and grease.  Louisiana's limit is
30 ppm.  In Texas, a permit is issued for each platform based on the
potential impact on the local water quality.  Some of the permits in
sensitive areas have a limit of oil and grease as low as 25 ppm.  In the
area of Federal control, the outer continental shelf, the U.S. Geological
Survey (USGS) has the authority to issue regulations designed to protect
the environment and to make navigation safe.  For example, the USGS's
regulations limit the average oil and grease discharge to no more than 50
ppm.

          The costs given in the Development Document were used for the
contiguous 48 states.  The Alaskan offshore platforms pipe their produced
formation water to shore where it is treated and dumped.  The costs for
Alaska are assumed to be about three times as high as they would be for the
contiguous 48 states.  (The water is treated and dumped even though the
fields use water for secondary recovery.   This is because the produced
formation water is incompatible with the seawater that is used for the
repressurization of the reservoir.)  No costs for disposal of oil from
onshore wells in Alaska were included because of a lack of data.

          EPA requirements concerning the disposal of trash, drill
cuttings, spent mud, and sanitary wastes from offshore platforms duplicate
requirements that were in the various state or U.S. Geological Survey
Regulations.  Hence, no incremental costs are occasioned by the Clean Water
Act.  The cost of extra casing to meet the Clean Drinking Water Act's
provisions have not been included in this analysis.

          Growth of Unit Numbers.  The growth of the number of discharge
points in the offshore region was estimated as follows.  For the coastal
and near offshore regions,  it was assumed that the number of abandonments
would equal the number of new wells so that there would be no net growth.
For the far offshore, the historic rate of growth of platforms was used as
an approximation of the growth with the number of discharge points, using
data from Offshore (June 20, 1977).  For 1977-1978, a 10 percent increase
was assumed; for 1979-1985, 15 percent per year.   These percentages include
expected growth in the Gulf of Alaska and offshore Atlantic.  The growth
rate for onshore well numbers is based on the Project Independence Report
using the "Business-as-usual" scenario.

          The cost of abatement of pollution problems in oil and gas
extraction has been calculated to be as shown in Table W3.2.1.
                                  W3.2-3

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                                                                        W3.2-4

    -------
                 Chapter W3.3  Petroleum Refining Industry

Regulations

          The costs of the petroleum refining industry for water pollution
control were based on regulations promulgated by EPA on October 18, 1982.
These regulations provide effluent limitations guidelines for BAT, new
source performance standards (NSPS), pretreatment standards for existing
sources (PSES) and for new sources (PSNS) (47FR46434).  BAT was promulgated
at the same level as BPT (40FR419).  NSPS, PSES and PSNS regulations were
left at existing cost levels (42FR15684).  BPT regulations are detailed in
the Code of Federal Regulations (40CFR419).

Industry Characteristics

          As of January 1, 1979, the petroleum refining industry comprised
174 firms operating 308 refineries in 42 states and Puerto Rico, the Virgin
Islands and Guam.  (In addition there are some small asphalt plants that
are shut down in the winter.) All refineries are necessarily multiproduct
but range from simple to complex.  The size distribution of these
refineries is shown in Table W3.3-1.  As of January 2, 1979 the 16 largest
firms accounted for 74 percent of the industry's operating capacity.  The
number of refineries and capacity for refineries operated by the large
firms are shown in Table W3.3-2.

          The- petroleum industry produces hundreds of different products in
refineries, which can be grouped in six major categories:   gasoline (44%),
jet fuel (6.5%), middle distillates (21%), residual  fuel oil (11%),
liquefied refinery gases (2.5%) and others, such -as lubricants, waxes,
asphalt and petrochemical  feedstocks (15 percent).  (Percentages are by
volume for 1979.)  Although crude oil is the most important refinery feedstock.
natural gasoline and other natural gas liquids provide about 7 percent of
hydrocarbon refinery inputs.

          Although a typical  oil refinery is technically complex, the
process is conceptually simple.  Crude oils, which are liquid mixtures of
many carbon-containing compounds, are first separated into several
fractions of varying molecular size  The chemical composition of some of
these fractions is then altered by changing the average molecular size
and/or the structure of the molecules.  Many of the intermediate fractions
are "treated" to make the  impurities innocuous or to remove them
completely.  These are then blended to produce finished products, to which
various substances, known  as additives, may be added to impart certain
desirable properties.

          In general, the  number and complexity of refining operations
increases with increasing  refinery size.   Most of the simple topping
refineries are small while the petrochemical and integrated refineries are
generally large.  There are some fairly small  lube oil refineries.
                                  W3.3-1

    -------
Table W3.3-1.   Refinery distribution  by  size,  operating  as
     of Jan.  1, 1979, US and territories (in thousands
      of cubic meters per calendar day with  thousands
        of barrels per calendar day in parentheses)
Capacity
Range
(Up to 4.9)
Up to 0.078
(5 to 24.9)
0.079 to 3.96
(25 to 74.9)
3.97 to 11.8
(75 to 149.9)
11.9 to 23.7
(150 to 449.9)
23.8 to 71.4
(450 and over)
71.5 and over
Totals
Number of
Refineries
44
113
80
40
28
3
308
Total
Capacity
(111)
17.6
(1,378)
219
(3,577)
569
(4,173)
663
(7,121)
1,132
(1,840)
293
(18,200)
2,894
Total
Industry
Capacity (%)
0.6
7.5
19.7
22.9
39.2
10.1
100.00
Avera
Capaci
(2.5
0.4
(12.2
1.9
(44.7
7.1
(104.
16.
(254.
40.
(613.
97.
(59.1
9.'
                       W3.3-2

    -------
Table W3.3-2.   The refinery  inventory—operating capacity,
      Jan.  1,  1979 by operator (capacity in thousands
      of cubic meters per calendar  day with thousands
        of barrels per calendar day in parentheses)

Exxon
Chevron
Amoco
Shell
Texaco
Gulf
Mobil
Atlantic Richfield
Amerada Hess
Sun Oil
Marathon
Union Oil
Sohio/BP
Ashland
Conoco
Phillips
Subtotal
Remaining Finns
Total
Number of
refineries
5
11
10
8
12
8
7
5
2
5
4
5
3
6
8
5
104
204
308
Crude
capacity
250
230
197
179
168
218
143
135
116
90
85
78
72
58
58
48
2125
777
2,902
(1,574)
(1,450)
(1,238)
(1,123)
(1,059)
(1,371)
(901)
(847)
(730)
(569)
(533)
(490)
(452)
(365)
(363)
(302)
(13,367)
(4,884) '
(18,251)
Crude
capacity (%)
8.6
7.9
6.8
6.2
5.8
7.5
4.9
4.6
4.0
3.1
2.9
2.7
2.5
2.0
2.0
1.7
73.2
26.8
100
                          M3.3-3

    -------
Pollutants and Sources

          Wastewater pollutants generated in the various refining
processes, such as BOD, COD, total organic carbon, total suspended solids,
oil and grease, phenols, ammonia, sulfides, chromium, and acids or bases,
are present in untreated refinery effluent.  Some pollutants enter the
wastewater directly from processing, while others enter the waste stream
from washing tanks, equipment catalysts, etc., from cooling water blowdowr
and from leaks and spillage.  Additional flows and waste loads are createc
by storm water runoff from the refinery grounds and from the disposal of
tanker ballast water.

          The following parameters are covered under the effluent
limitations guidelines: BOD,., total suspended solids, COD, oil and grease.
phenolic compounds, ammonia (as N), sulfide, total chromium, hexavalent
chromium, and pH.  The effluent limitations for each pollutant vary with
the type, size and complexity of the refinery.

Control Technology

             Wastewater treatment processes currently used in the petrol ei
refining industry include equalization and storm water diversion; initial
oil and solids removal (API separators or baffle plate separators); furth'
oil and solids removal (clarifiers, dissolved air flotations, or filters)
carbonaceous waste removal (activated sludge, aerated lagoons, oxidation
ponds, trickling filter, activated carbon, or combinations of these); and
filters (sand or multi-media) following biological treatment methods.
          BPT-guidelines are based upon both in-plant and end-of-pipe
control practices widely used within the industry.  These include the abo'
listed end-of-pipe technologies plus:
                •
             t  Installation of sour water strippers to reduce the sulfidi
             and ammonia concentrations entering the treatment plant.

             •  Elimination of once-through barometric condenser water by
             using surface condensers or recycle systems with oily water
             cooling towers.

             •  Segregation of sewers, so that unpolluted storm runoff an>
             once-through cooling waters are not treated, along with the
             process and other polluted waters.

             •  Elimination of polluted once-through cooling water by
             monitoring and repair of surface condensers or by use of wet
             and dry recycle systems.

          NSPS includes discharge flow reduction of from 25 to 50 percent
of average BPT flow, depending on subcategory, achieved through greater
reuse  and recycle of wastewaters in addition to BPT treatment.

          The reduction of oil and grease and ammonia based on oil/water
separation and steam stripping technologies is the basis for both PSES an


                                   U3.3-4

    -------
PSNS.  Also a mass limitation for ammonia is included for both for indirect
dischargers consists solely of "sour" waters.

Costing Methodology

          All costs were estimated exogeneously using published EPA cost
estimates (EPA 440/1-79/0246, Dec., 1979) and the October 18, 1982 Federal
Register.  Due to reductions in world petroleum markets no additional new
grass roots refineries will be built after 1982.

          The aggregate costs developed on this basis are given in Table
W3.3.3.
                                  W3.3-5

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          Chapter W3.4.  Steam Electric Power Generating Industry
Regulations

          Regulations affecting this industry were revised under the
provisions of the NRDC Consent Decree.  EPA promulgated BAT, NSPS, PSES,
and PSNS in November 1982 for the steam electric power generating industry.
However, revision of this chapter was limited to adjusting pollution
control costs to 1981 dollars.  The effect of any changes in the
regulations affecting the steam electric power generating industry is not
reflected in the text of the chapter or the cost estimates included in
Table W3.4.2.  The cost estimates represent the impact of regulations as
proposed in 1980.

Industry Characteristics

          The steam electric power industry can be subdivided according to
the type of fuel consumed in the production of electricity, i.e., fossil
fuels (coal, gas, and oil) and nuclear fuels.  Table W3.4.1 illustrates the
recent and projected distribution of steam plants and capacity among the
major fuel types.

            Table W3.4-1.  Capacity categorization by fuel type
                          (Capacity in gigawatts)
                          1978
1985
1990
1995
Coal Capacity
Number of Plants
Oil/Gas Capacity
Number of Plants
Nuclear Capacity
Number of Plants
227.4
352
170.1
429
53.8
38
301.8
467
173.5
438
139.0
98
365.1
565
157.4
397
173.1
122
473.9
734
100.4
253
281.0
198
Pollutants and Sources

          Effluent guidelines promulgated October 8, 1974
(39 FR 36186-36207) control  the following pollutants:
                pH
                PCB
                TSS
                Oil and grease
                Total copper
                Total iron
 Free available chlorine
 Total  residual  chlorine
 Corrosion inhibitors
 Zinc
 Chromium
 Phosphate  •
                                  W3.4-1

    -------
          Main  sources contributing to the  total waste load are:

          •  Low volume wastes which  include scrubber waters, discharge
             from  ion exchange treatment systems, water  treatment,
             evaporator blowdown,  laboratory and sampling  streams,  floor
             drainage, cooling tower  basin  cleaning wastes, and blowdown
             from  recirculating  house service water systems

          •  Metal cleaning wastes
             •  Ash  transport water
             •  Boiler and cooling tower blowdown
             •  Area runoff from material storage and construction  areas.

 Control  Technology

          A  variety  of control and treatment technologies  are in  use by o
 available to the steam electric  power generating industry.  Thus  water
 management programs  vary  among plants.

          The amount of heat rejected to available waters  is reduced by
 in-process means,  use of  cooling towers, and by dissipating the heat in
 on-property  cooling  ponds or lakes.

          Clarification,  flotation, and filtration are common methods of
 removing suspended solids.  Chemical  reduction, ion exchange, and
 chemically induced precipitation are  among  the methods used to control
 metals  in wastewater.  Oil and grease are removed by skimming, flotation,
,demulsification, and coagulation.

          Approaches to controlling chlorine in effluents  involve reducin
 dosage  frequency,  amount, and/or duration,  splitting the effluent into  tw
 streams  and  chlorinating  one stream at a time, use of feedback control
 systems, dissipation, and aeration.

          The following technologies  were considered in  the economic
 analysis made recently of the  revised effluent guidelines  of BAT, NSPS,
 PSES  and PSNS.

             Dry fly ash  handling
             Chemical precipitation (fly ash transport water)
             Dechlorination (cooling  water)
             Chlorine minimization (cooling water)
             Dechlorination a-nd  chlorine minimization (cooling water).

 Costing  Methodology

          Compliance costs were  adapted on  an empirical  basis from econorr
 analyses performed for EPA by  Temple, Barker, and Sloane,  Inc.  Costs
 associated with recent revisions of regulations were taken from the repor
 dated August, 1980.  Costs for compliance with regulations not covered  by
 the August,  1980 report were based on the prior similar  study of  May 1976
                                   W3.4-2

    -------
          The aggregated costs,  as developed from those  documents  and
updated to 1981 dollars, are given in Table W3.4.2.
                                  W3.4-3

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    -------
                     Chapter W4.  Chemicals Industries
          For the purpose of this report, the Chemicals Industries are
defined as those establishments which manufacture products primarily by
chemical modification of raw materials and for which the final product is a
chemical.  These include:

             Organic Chemicals Industry
             Inorganic Chemicals
             Plastics & Synthetics
             Rubber Manufacturing
             Soaps and Detergent Industry
             Carbon Black Industry
             Explosives Industry
             Pesticides and Agricultural  Chemicals
             Fertilizer Manufacturing Industry
             Phosphorus Chemicals Industry
             Paint Formulating
             Printing Ink Formulating
             Photographic Processing
             Textiles Industry

          The textiles industry has been  included in this grouping
primarily because it is largely the chemical  operations within that
industry which are responsible for water  pollution.   Costs associated with
the implementation of the FWPCA for the Chemicals Industries are summarized
in Table W4.
                                   W4-1

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    -------
                 Chapter W4.1  Organic Chemicals Industry

Regulations

          Regulations affecting this industry were revised under the
provisions of the NRDC Consent Decree.  In 1983 EPA proposed new
regulations for BPT, BAT, NSPS, PSES, and PSNS.  However, revision of this
chapter was limited to adjusting pollution control costs to 1981 dollars.
The effect of any changes in the regulations affecting the organic
chemicals industry is not reflected in the text of the chapter or the cost
estimates included in Table W4.1.2.  The cost estimates represent the
impact of the regulations as originally promulgated.

Industry Characteristics

          The organic chemicals industry includes a vast number of products
and processes.  The Phase I effluent limitations guidelines cover only part
of the organic chemicals industry.  At the time of this report, no Phase II
regulations had been proposed for other parts of the organic chemicals
industry.  Primary petrochemical processing (i.e., chemicals produced at
petroleum refineries), plastics, fibers, agricultural chemicals,
pesticides, detergents, paints, and Pharmaceuticals are not included.
These are discussed elsewhere in this report.

          Synthetic organic chemicals are derivative products of naturally
occurring raw materials (petroleum, natural gas, and coal) which have
undergone at least one chemical conversion.  The organic chemicals industry
was initially dependent upon coal  as its sole source of raw materials.
However, during the last three decades it has moved so rapidly from coal to
petroleum-based feedstocks that the term "petrochemicals" has come into
common use.

          The basic raw materials are usually obtained by physical
separation processes in petroleum refineries.  The raw materials are then
chemically converted to a primary group of reactive precursors; these
precursors are then used in a multitude of specific chemical conversions to
produce both intermediate and final products.

          Processing of organic chemicals usual-ly involves four stages:

          •  Feed preparation -- vaporization, heating, compressing, and
             chemical or physical  purification of raw materials

          t  Reaction — the reaction of the raw materials, frequently in
             the presence of a catalyst

          t  Product separation -- condensation, distillation, absorption,
             etc., to obtain the desired product
                                  W4.1-1

    -------
          •  Product purification — distillation, extraction,
             crystallization, etc., to remove impurities.

          Processing methods may be carried out either in continuous
operations or in individual  batches.  Facilities using the continuous
processing method manufacture products at much greater volumes and at low*
unit costs than those using  batch methods.

          The effluent limitatinns guidelines promulgated to date by EPA
(for Phase I) apply only to  those products  of the organics chemicals
industry produced in continuous processing  operations.  These operations
have been divided into seven subcategories, based first upon the degree o-
process water used, and second upon the raw waste loads generated; Table
W4.1.1 lists the seven subcategories and the products and processes
included.

Pollutants and Sources

          Water is used in many production  processes as a reaction vehicl
and also as a vehicle to separate or to purify the final  products by
scrubbing, steam stripping,  or absorption.   In addition,  a considerable
amount of water is used for heating (steam) and cooling,  and for washing
reaction and storage vessels, etc.

          The effluent limitations guidelines for the organic chemicals
industry cover the following pollutants:  BOD, COD, total suspended solid:
phenols, and pH.  The limitation placed upon pH in all cases is between 6
and 9.0.  It should be noted that process wastewaters subject to
limitations include all process waters exclusive of auxiliary sources, su<
as boiler and cooling water blowdown, water treatment backwash,
laboratories, and other similar sources.

Control Technology

          Technologies employed in the organic chemicals  industry for the
control of wastewater pollutants include in-process modifications,
pollution control equipment, and end-of-pipe wastewater treatment.  From
pollution-control standpoint, the most significant change that can be mad
in process chemistry is from a "wet" process to a "dry" process; that is,
the substitution of some other solvent for water in which to carry out th
reaction or to purify the product.  Other in-process technologies observe
or recommended for the organic chemicals industry include the substitutio
of surface heat exchangers for contact cooling water, the substitution of
mechanical pumps for vacuum pump steam jet  ejectors, the  recycle of
scrubber water, and the regeneration of contact process steam from
contaminated condensate.

          Biological treatment systems are  the most common end-of-pipe
technologies used in the organic chemicals  industry today.  These systems
include activated sludge, trickling filters, aerated lagoons, and anaerob
lagoons.  Other systems used include stripping towers, deep-well disposal
physical treatment, activated carbon, and incineration.  Where phenols ar


                                  W4.1-2

    -------
          Table W4.1.1.
Organic chemicals manufacturing industry
   products and related processes
Subcategory A

       Products

BTX Aromatics
BTX Aromatics
Cyclohexane
Vinyl Chloride

Subcategory B


      Bl Products

Acetone
Butadiene
Ethyl benzene
Ethylene and propylene
Ethylene dichloride
Ethylene oxide
Formaldehyde
Methanol
Methyl  amines
Vinyl acetate
Vinyl chloride

      B2 Products

Acetaldehyde
Acetylene
Butadiene
Butadiene
Styrene

Subcategory C

      Cl Products

Acetic acid
Acrylic acid
Coal  tar
Ethylene glycol
Terephthalic acid
Terephthalic acid
      Nonaqueous Processes

                  Process Descriptions

      Hydrotreatment of pyrolysis gasoline
      Solvent extraction from reformate
      Hydrogenation of benzene
      Addition of hydrochloric acid to acetylene

      Process with Process Water Contact as Steam
        Diluent or Absorbent

                 Bl Process Descriptions

      Dehydrogenation of isopropanol
      Co-product of ethylene
      Alkylation of benzene with ethylene
      Pyrolysis of naphtha or liquid  petroleum gas
      Direct chlorination of ethylene
      Catalytic oxidation of ethylene
      Oxidation of methanol
      Steam reforming of natural gas
      Addition of ammonia to methane
      Synthesis of ethylene and acetic acid
      Cracking of ethylene dichloride

                 82 Process Descriptions

      Dehydrogenation of ethanol
      Partial oxidation of methane
      Dehydrogenation of n-butane
      Oxidative-dehydrogenation of n-butane
      Dehydrogenation of ethylbenzene

      Aqueous Liquid Phase Reaction Systems

                 Cl Process Descriptions

      Oxidation of acetaldehyde
      Synthesis with carbon monoxide  and acetylene
      Distillation of coal  tar
      Hydrogenation of ethylene oxide
      Catalytic oxidation of p-xylene
      Purification of crude terephthalic acid

                                  Continued...
                                  W4.1-3

    -------
                         Table W4.1.1 (Continued)
      C2 Products                         C2 Process Descriptions

Acetaldehyde                   Oxidation of ethylene with oxygen
Caprolactam                    Oxidation of cyclohexane
Coal tar                       Pitch forming
Oxo chemicals                  Carbonylation and condensation
Phenol and Acetone             Cumene oxidation and cleavage

      C3 Products                         C3 Process Descriptions

Acetaldehyde                   Oxidation of ethylene with air
Aniline                        Nitration and hydrogenation of benzene
Bisphenol A                    Condensation of phenol and acetone
Dimethyl terephthalate         Esterification of terephthalic acid

      C4 Products                         C4 Process Descriptions

Acrylates                      Esterification of acrylic acid
p-cresol                       Sulfonation of toluene
Methyl methacrylate            Acetone cyanohydrin process
Terephthalic acid              Nitric acid process
Tetraethyl lead                Addition of ethyl chloride to lead amalgair


Source:  EPA Development Document, April 1973, pp. 28-29
                                   W4.1-4

    -------
present in wastewaters, they may be removed by solvent extraction, carbon
absorption, caustic precipitation, or steam stripping.  Cyanide may be
removed by oxidation.

          In-process controls commensurate with BPT include segregation of
waste streams, the substitution of nonaqueous media in which to carry out
the reactions or to purify the products, recycling or reuse of process
water, and the recovery of products and byproducts from the wastewaters by
solvent extraction, absorption, or distillation.  End-of-pipe treatment
commensurate with BPT is based on the use of biological systems as
mentioned above.  These systems include additional treatment operations
such as equalization, neutralization, primary clarification with oil
removal, nutrient addition, and effluent polishing steps, such as
coagulation, sedimentation, and filtration.  Phenol removal is also
required in some cases.

          Technology commensurate with BAT includes the additional of
activated carbon to the BPT biological systems to achieve substantial
reductions of dissolved organic compounds.  In-process controls applicable
to BAT include:

          •  Substitution of noncontact heat exchangers for direct contact
             water cool ing

          •  Use of nonaqueous quench media

          t  Recycle of process water

          •  Reuse of process water as a make-up to evaporative cooling
             towers

          •  Use of process water to produce low pressure steam by
             noncontact heat exchange

          t  Recovery of spent acids or caustic solution for reuse

          •  Recovery and reuse of spent catalysts

          •  Use of nonaqueous solvents for extraction products.

          End-of-pipe technology for NSPS is defined as biological
treatment with suspended solids removal via clarification, sedimentation,
and sand or dual-media filtration.  In addition, exemplary in-process
controls, as previously enumerated, are also assumed to be applicable,
particularly where biotoxic pollutants must be controlled.

Costs

          A summary of the costs to the organic chemicals industry
associated with the implementation of regulatory provisions is given  in
Table W4.1.2.
                                  W4.1-5

    -------
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    -------
                    Chapter W4.2  Inorganic Chemicals
Regulations
          The inorganic chemicals industry is a large and complex industry
which is covered by numerous regulations.  The industry as defined by EPA
includes 63 chemical product subcategories of which 44 are covered by some
level of effluent control regulations.  The level  of regulation for each
subcategory can vary from BPT only to a full  set of BPT, BAT, NSPS, PSES,
and PSNS regulations.  BCT limitations have been set equal to BPT
(FR 47, 120) and will not generate additional costs.  While regulations
exist for 44 subcategories, the specific regulations will not generate
costs in all cases as control requirements may be minor.

          The inorganics chemicals industry has been covered in previous
Cost of Clean reports.  It has received major attention in this edition
because of the potential magnitude of costs and the extensive amount of
revisions that have occurred in the regulations.  The regulations are too
extensive to be summarized in this chapter and interested readers are
referred to the Federal Register, Vol. 45, No. 144, January 24, 1980, p.
49450-49501 and Vol. 47, No. 125, June 29, 1982, p. 28260-28303 for current
information on revisions and regulatory status.

Industry Characteristics

          The inorganic chemicals industry comprises establishments that
process ores or other chemicals through refining or purifying into useful
inorganic chemical products.  Most of the establishments are included in
one of four major Standard Industrial Classification groups:

          SIC 2812:  Alkalies and Chlorines
          SIC 2813:  Industrial Gases
          SIC 2816:  Inorganic Pigments
          SIC 2819:  Industrial Inorganic Chemicals, Not Elsewhere
                     Classified (N.E.C.)

          In 1977, these industries included  1,281 establishments that
shipped $12.8 billion of inorganic and related chemical  products.
Employment in 1977 for these establishments was over 109,000 with an
average of 85 employees per plant.  The highest share of the establishments
(44%), shipments (67%), and employment (71%)  is accounted for by the SIC
2819 group, Industrial Inorganic Chemicals N.E.C.  which encompass a large
number of the specific inorganic chemical products, many of which are
covered by the regulatory subcategories.

          Some of the major products for the  industry and their 1977 value
of shipments are listed below:
                                  W4.2-1

    -------
               Product (SIC group)              Value of shipments, 1977
                                                      (S million)

     Chlorine (2812)                                       590
     Sodium hydroxide (2812)                               997
     Oxygen (2813)                                         375
     Nitrogen (2813)                                       279
     Titanium pigments (2816)                              627
     Chrome pigments (2816)                                454
     Sulfuric acid (2819)                                  427
     Aluminum oxide (2819)                                  827
     Potassium and sodium compounds (2819)               1,103
     Phosphorus (2819)                                     461

It should be noted that the Department of Commerce lists over 230 inorgan'
chemical products as being  covered by the four major SIC codes comprising
the industrial inorganics industry.

          Only part of the  industry will  be impacted by water quality
regulations.  However, because of the complexity and size of the industry
and lack of data, it was not practical to segment the general industry
characteristics into "affected" and "not affected" segments.  Nonetheless
a review of Development Documents and other data suggests that between 75<
and 900 plants will be required to comply with effluent regulations and
indicates the general level of industry coverage of the regulations.

          Inorganic chemical plants tend to be located in industrial area1
Leading states in terms of plant numbers include California,- Texas, Ohio,
Pennsylvania and New Jersey.

          Most of the plants will tend to be direct 'dischargers.  Of a
sample of 711 plants, only  11 percent were'on sewers or generated no
discharge.

          The industry growth has been sporadic in recent years.  Dependi
on use and economic conditions, individual products have experienced real
annual growth in the magnitude of +_ 20 percent.  Trends seem to suggest,
however, that overall a small positive long-term growth should occur in
most segments.

          Capacity utilization will vary by-company, plant and year
reflecting wide combinations of management, marketing, and economic
conditions.   In 1978, the capacity utilization for the four major SIC
groups ranged from 76 percent (SIC 2819)  to 90 percent (SIC 2812).

Pollutants and Sources

          Most of the steps involved in inorganic chemicals production" wi
produce wastewater.  Depending on the plant and manufacturing 'complex,
these wastewaters may then  be combined with wastewater from other chemica
and related production or discharged separately.  Water is used for
cooling, process operations, scrubbing towers, product washes, waste


                                  W4.2-2

    -------
transport and other uses; and water use for products range from zero to 17
million gallons per day.

          The industry wastewaters contain a broad range of pollutants.
Toxic pollutants include, but are not limited to, chromium, nickel, lead,
mercury, copper, cadmium, zinc, and cyanide.  Conventional pollutants, TSS
and pH also occur, as do such nonconventional pollutants as COD, fluoride,
iron, and ammonia.  The wastewater and chemical  constituents also cause
additional problems such as equipment corrosion, hazardous gas generation,
treatment plant malfunctions, and problems in disposing of sludges
containing toxic metals.

          Again sources and pollutants will vary extensively depending on
the product or industry subcategory.  For additional information on this
subject, subcategory summaries on pollutants and sources are provided in
the appendix.

Control Technologies

          The EPA has recommended several distinct control and treatment
technologies for potential  use in the inorganic  chemicals industry.  These
can include combinations of neutralization, precipitation, settling,
clarification, flocculation, oxidation, reduction and others.   While
technologies are recommended, such technologies  may not be required if a
plant can achieve effluent limitations with the  operation of alternative
technologies.  Specific recommended technologies for each of the affected
subcategories are not presented here due to the  large number of
subcategories but they are summarized in the appendix.

Costing Methodology

          Water pollution costs for compliance with effluent limitations,
pretreatment standards and new source performance standards were estimated
by one of two methods.  The first used model  plant costs as presented in
the Development Documents and developing cost equations for each of the
subcategories and regulations for.which model plant costs were available.
A power equation of the form y=Ax  was used where:

          y = investment costs or 0 & M costs, and
          x = plant capacity

          The second used exogenous costs as presented  in the  Development
Documents and Federal  Register notices.

          A detailed explanation of the costing  methodology is presented in
the appendix.

          The resulting cost of compliance for the  inorganic chemicals
industry is presented in Table W4.2.1.  These costs are based  on the
methodologies described above and data from various Development Documents,
economic impact analyses, Federal  Register notices, and other  industry
related sources.
                                  W4.2-3

    -------
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    -------
                   Chapter W4.3  Plastics and Synthetics
Regulations
          Regulations affecting this industry were revised under the
provisions of the NRDC Consent Decree.   In 1983 EPA proposed new
regulations for BPT, BAT, NSPS, PSES, and PSNS.  However, revision of this
chapter was limited to adjusting pollution control costs to 1981 dollars.
The effect of any changes in the regulations affecting the plastics and
synthetics industry is not reflected in the text of the chapter or the cost
estimates included in Table W4.3.1.   The cost estimates represent the
impact of regulations as originally  promulgated.

Industry Characteristics

          The plastics and synthetics industry comprises 13 product
subcategories in Phase I (for which  the promulgated effluent guidelines and
standards were revoked on August 4-,  1976) and eight product subcategories
in Phase II.   The subcategories in Phase I include polyvinyl chloride,
polyvinyl acetate, polystyrene, polypropylene, polyethylene (high-density
and low-density), cellophane, rayon, acrylonitrile-butadiene-styrene (ABS)
and styrene-acrylonitrile (SAN), polyester fiber, nylon 66, nylon 6,
cellulose acetate, and acrylics.  Those in Phase II include ethylene-vinyi
acetate copolymers (EVA), polytetrafluoroethylene, polypropylene fibers,
alkyds and unsaturated polyester resins, cellulose nitrate, polyamide
(nylon 6/12), polyester resins (thermoplastic), and silicones.   Other
products covered in the Development  Documents but for which there are no
effluent limitations guidelines include epoxy, phenolic, melamine and urea
resins, cellulose derivatives (ethyl cellulose, hydroxyethyl cellulose,
methyl cellulose, and carboxymethlcellulose), polyvinylindene chloride,
polyvinyl butyral, polyvinyl ethers, nitrile barrier resins, and Spandex
fibers.

          Production of the various  resins and plastics materials involves
a variety of chemical polymerization processes in which large synthetic
polymers are formed from monomers.  Organic fibers, such as polyester,
polypropylene, the nylons, rayon, and cellulose acetate, are produced by
adding a spinning process after the  polymer has been produced.

Waste Sources and Pollutants

          In order to set effluent limitations guidelines, the  dimension of
wastewater characteristics was chosen as a basis for subcategorization.
The four major subcategories are defined as:

          •  Major Subcategory I:  Low waste load (< 10 kg/metric ton), low
             attainable BODr concentration (< 20 mg/1).  Products affected:
             polyvinyl chloride, polyvinyl acetate, polystyrene,


                                  W4.3-1

    -------
             polyethylene,  polypropylene,  ethylenevinyl  acetate,
             fluorocarbons,  and  polypropylene  fiber.

          •  Major Subcategory  II:   High waste load  (>  10  kg/metric  ton),
             low attainable  BOD-  concentration (<  20  mg/1).   Products
             affected:   ABS/SAN,  cellophane, and  rayon.

          •  Major Subcategory  III:   High  waste load  (>  10 kg/metric ton)
             medium attainable  BODr  concentration  (30-75 mg/1).   Products
             affected:   polyesters,  nylon  66,  nylon  6,  cellulose  acetates
             alkyd and  unsaturated  polyester resins,  cellulose nitrate,
             polyamides, saturated  thermoplastic  polyesters,  and  silicone:

          •  Major Subcategory  IV:   High waste load  (>  10  kg/metric  ton),
             low treatability.   Product affected:   acrylics.

          The main sources  contributing to the total  waste load are  spill
leaks, and accidents.   Other sources include:   washdown  of process vessel
area housekeeping, utility  blowdown, and  laboratory  wastes.   Waste stream
from cooling towers, steam-generating facilities,  and water treatment
facilities are generally combined with process wastewater  and then are se
to the treatment plant.

          In order to  define waste  characteristics,  the  following basic
parameters were used to develop  guidelines for meeting  BPT, BAT,  and NSPS
BODc, COD, TSS, zinc,  pH, phenolic  compounds,  and total  chromium.

Control  Technology and  Costs

          Waste treatment methods in the  plastics  and synthetics  industry
include the following:   biological  treatment,  single- or double-stage
aeration, adsorption,  granular  activated  carbon systems, chemical
precipitation, anaerobic processing, air  stripping,  chemical  oxidation,
foam separation, algal  systems,  incineration,  liquid  extraction,  ion
exchange, reverse osmosis,  freeze-thaw, evaporation,  electrodialysis,  and
in-plant controls.

          BPT guidelines for existing point sources  are  based on  the
application of end-of-pipe  technology, such as biological  treatment  for  B
reduction by activated  sludge,  aerated lagoons, trickling  filters,
aerobic-anaerobic lagoons,  etc.,  with preliminary  treatment typified by  -
equalization, dampening of shock  loadings, settling,  and clarification.
BPT also calls for chemical  treatment for  the  removal  of suspended solids
oils, and other elements, as well as pH control  and  subsequent treatment
typified by clarification and polishing processes  for additional  BOD and
suspended solids removal, and dephenolizing units  for phenolic compound
removal  when needed.  In-plant  technology  and  other  changes that  may be
helpful  in meeting BPT  include  segregation of  contact process wastewater
from noncontact wastewaters, elimination  of once  through barometric
condensers, control of  leaks, and good housekeeping  practices.
                                  W4.3-2

    -------
          BAT standards call for the segregation of contact process waters
from noncontact wastewater, maximum wastewater recycle and reuse,
elimination of once-through barometric condensers, control of leaks, good
housekeeping practices and end-of-pipe technology, further removal of
suspended solids and other elements typified by multi-media filtration,
chemical treatment, etc.  Also included are further COD removal  as typified
by the application of adsorptive floes, and incineration for the treatment
of highly-concentrated, small-volume wastes, as well as additional
biological  treatment for further BOD removal when needed.

          New Source Performance Standards are based on BPT and call for
the maximum possible reduction of process wastewater generation and the
application of multi-media filtration and chemical treatment for additional
suspended solids, other element removal, and additional biological
treatment for further BOD removal as needed.

          Control costs are detailed in Table W4.3.1.
                                  W4.3-3

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                    Chapter W4.4  Rubber Manufacturing
Regulations
          Regulations for the control of effluents from the production of
tires and inner tubes and emulsion crumb, solution crumb, and latex rubber
were proposed October 1, 1973 (Federal Register, Oct. 11, 1973) and
promulgated February 8, 1974 (Federal Register, Feb. 21, 1974), to become
effective April 22, 1974.

          Regulations for the control of small, medium and large plants
producing general  molded, extruded, and fabricated rubber products;
reclaimed rubber;  latex-dipped products; and latex foam were proposed
August 9, 1974 (Federal Register, Aug. 23, 1974) and promulgated December
30, 1974 (Federal  Register, Jan. 10, 1975), to become effective January 10,
1975.

          Pretreatment standards for emulsion crumb rubber and solution
crumb rubber were  revoked, effective March 16, 1978 (Federal Register, Feb.
14, 1978).

          In addition, a regulatory amendment to revoke the BAT limitations
for producers of tires and inner tubes and to revise the BAT limitations
for emulsion crumb rubber solution crumb rubber; latex rubber; general
molded, extruded and fabricated rubber products; latex-dipped products; and
latex foam was proposed on November 30, 1979 (Federal Register, December
18, 1979).  The promulgated regulations as well as the proposed regulations
are analyzed in this chapter.

Industry Characteristics

          The rubber processing industry includes the manufacture of tires
and inner tubes; synthetic rubber; general molded, extruded, and fabricated
rubber products; reclaimed rubber; latex-dipped products; and latex foam.

          Plants that produce tires and inner tubes are classified in SIC
3011.  The typical tire manufacturing process includes the following:
          t  Preparation or compounding of the raw materials,
          •  Transformation of these compounded materials into five tire
             components—tire bead coating, tire treads, tire sidewall ,
             inner liner stock, and coated cord fabric,
          0  Building, molding, and curing the final product.

          The raw  materials used include a variety of synthetic and natural
rubbers; three categories of compounding materials: filler, extenders, and
reinforcers (carbon black and oil  are two common examples); and other
chemicals that are used as antioxidants, pigments, or curing and
accelerating agents.  Compounding is usually carried out in a batch-type,


                                  W4.4-1

    -------
internal mixing device called a Banbury mixer.   After mixing, the compounc
is sheeted out in a roller mill, extruded into  sheets, or pelletized.  The
sheeted materials are tacky and must be coated  with a soapstone solution •
prevent the materials from sticking together during storage.  The
compounded rubber stock is transformed into one of the tire components by
molding, extruding, calendering, and a variety  of other operations.  The
tire is built up as a cylinder on a collapsible, round rotating drum by
applying the inner layer, then by adding layers of cord, beads, belt, and
tread.  Finally the "green" tire is molded and  cured in an automatic press
and the excess rubber is ground off.  Inner tubes are produced using the
same basic processing steps.

          Tire and tube products are produced in fifty-six major plants ar
several smaller plants in the United States.  Tire plants vary widely in
capacity, the largest produce approximately 30,000 tires per day, and the
smallest produces less than 5,000 tires per day.  In 1972, the industry
produced 233 million tires and by 1981 production decreased to 195 millio
tires.  Long-term trends indicate that future growth in production will bi
closely related to annual growth rates in domestic and foreign vehicle
registrations which are estimated at a combined rate of 1.5 percent.

          The production of synthetic rubber is classified in SIC 2822.
For the purpose of establishing effluent limitations guidelines, the
synthetic rubber industry was divided into three subcategories: emulsion
crumb, solution crumb, and latex.  Crumb rubbers, generally for tires, ar
sold in a solid form, and are producted through two different processes:
emulsion polymerization and solution polymerization.  Latex rubbers,
generally for specialty products, are sold in latex form, and are produce
through emulsion polymerization.

          Emulsion polymerization is the traditional and dominant process
for producing synthetic rubber.  The raw materials (monomers) are usually
styrene and butadiene, to which a catalyst, activator, and modifier are
added in a soap solution to produce an emulsion in an aqueous medium;
polymerization proceeds step-wise through a train of reactors.   The produ
rubber is formed in the emulsion phase of the reaction mixture, which is
milky white emulsion called latex.  Unreacted monomers are then recovered
from the latex by vacuum stripping; the production process ends at this
point for latex rubbers.  If crumb rubber is desired, sulfuric acid and
sodium chloride are added to the latex to coagulate the crumb rubber, whi
is then dewatered, rinsed, filtered, and finally dried with hot air to
produce the final product.

          The production of synthetic rubbers by solution polymerization
a step-wise processing operation very similar to emulsion polymerization.
For solution polymerization, the monomers must  be extremely pure, and the
solvent (hexane, for example) must be completely anhydrous.  The
polymerization reaction is more rapid (1 to 2 hours) and is taken to over
90 percent conversion as compared to 60 percent conversion for emulsion
polymerization.  Both monomers and solvents are generally passed through
drying columns to remove all water.  After reaction, the mixture leaves t
reactor as a rubber cement; i.e., polymeric rubber solids dissolved in
                                  W4.4-2

    -------
solvent.  As with emulsion polymerization, coagulation, washing,
dewatering, and drying processes produce the final product.

          Thirteen companies operating twenty-eight plants produce most of
the crumb synthetic rubber in the United States.  Most of these plants are
part of diversified complexes that produce other products, such as rubber
processing chemicals, plastics, and basic intermediate organic chemicals.
Latex is produced by seventeen plants owned by eight companies, three of
which are not included in the preceding listing.

          Annual production of synthetic rubber increased from 2.45 million
metric tons in 1972 to a peak of 2.72 million metric tons in 1979.
Production dropped to 2.15 million metric tons in 1980 and has begun to
recover in 1981 on the uptick of a cyclical growth pattern.  The industry
will continue to follow short-term cyclical production patterns and
long-term growth is projected at an annual rate of one percent.

          General molded, extruded, and fabricated rubber products include
such disparate items as rubber footwear (SIC 3021), rubber hose and belting
(SIC 3041), fabricated rubber products not elsewhere classified (SIC 3069),
and rubber gaskets, packings, and sealing devices (SIC 3293).  The
manufacturing processes for these rubber products include compounding of
the rubber stocks, then forming of the compounded stock by a variety of
means, such as molding, extrusion, lay-up, or other fabrication means.

          There are approximately 1,355 plants in this subcategory with the
largest number in SIC 3069, fabricated rubber plants not elsewhere
classified.  The value of shipments from plants in SIC 3069 has increased
at an annual adjusted rate of 1.7 percent (in 1972 dollars) and the growth
rate is expected to increase to a 2.4 percent annual rate reflecting
growing manifests, including the automotive markets.  Competition from
foreign products has severely hampered the growth in domestic manufacturing
establishments classified in SIC 3021 as evidenced by the decline in
domestic product shipments from $500 million in 1972 to $300 million in
1981.  No significant changes are projected and future levels of shipments
should remain constant.  The value of shipments from firms producing hoses
and belting (SIC 4031) has increased at an annual rate of .9 percent from
1972 to 1978 and is projected to increase with economic activity at an
annual rate of 3.5 percent.  Firms producing products classified in SIC
3293 (rubber gaskets, packings and sealing devices) experienced a 2.2
percent adjusted annual growth in value of shipment from 1972 to 1979 and
this annual growth rate is projected for the future.

          Reclaimed rubber is classified in SIC 3031, although some of the
establishments in which rubber is reclaimed may be classified in SIC
3011—Tires and Inner Tubes.  The promulgated regulation specified two
subcategories of this industry--(l) wet digestion and (2) pan, dry
digestion or mechanical.  Scrap separation and size reduction steps are
common to all reclaim rubber processes.  In wet digestion processes, the
ground rubber is partially depolymerized by heating with reclaiming agents
and water in an autoclave, followed by digestion with defibering agents to
remove fibers.  In the pan process, the ground rubber scrap is further


                                  W4.4-3

    -------
 reduced  in  size  and  defibered  by  additional  grinding.   It  is  blended  with
 reclaiming  oils  and  heated  in  open  pans  in  a pressure  vessel.   In  the
 continuous  mechanical  process,  the  finely ground,  fiber-free  scrap is fed
 continuously  into  a  heated,  high-shear screw machine  in  the  presence  of
 reclaiming  agents  and  depolymerization agents.   The reclaimed products ar
 shipped  in  slabs or  bales.

          The annual adjusted  value of shipments from  the  eleven  reclaime
 rubber plants in the U.S. has  declined from about  $30  million in  1972 to
 $20  million in 1981.   Future production  in  the  industry  is projected  to
 remain constant  at the 1981  level.

          Latex-based  products  are  included in  SIC 3069, Fabricated Rubbe
 Products not  Elsewhere Classified,  and in SIC 3021, Rubber and Plastics
 Footwear.   There are approximately  eighty-four  plants  in the  U.S.  produci
 latex-dipped, extruded and  molded rubber products  and  zero plants  produci
 latex foam  products.

 Pollutants  and Sources

          The pollutants  or pollutant properties controlled  by effluent
 guidelines  and standards  for the  rubber  processing industry  are presented
 in Table W4.4.1.  The  major sources of the  regulated  pollutant are also
 included.   Certain pollutants  are contributed by dischargers  unrelated to
 the  primary production operations.   These nonprocess  effluents result fro
 utility  and water  treatment discharges,  and from domestic  wastewater
 discharge generated  within  the  plant boundaries.   These  nonprocess relate
'dischargers are  not  regulated  by  effluent guidelines  and standards.
 However, when process  and nonprocess effluents  are combined,  nonprocess
 related  pollutants may contribute to the quantity  or  quality  of pollutant
 or  pollutant  properties controlled  by effluent  guidelines  and standards.
 The  major process  wastewater streams of  the subcategories  of  the  rubber
 processing  industry  are summarized  below:

          The primary  water usage in the tire and  inner  tube  industry is
 for  noncontact cooling and  heating. The process wastewaters  consist  of
 mill area oily waters, soapstone  slurry  and latex  dip  wastes, area washdc
 waters,  emission scrubber waters, and contaminated storm waters from  raw
 material storage areas, etc.  For the purposes  of  establishing effluent
 limitations guidelines for  manufacturers of tires  and  inner  tubes, the
 following pollutant  parameters  have been designated as significant:
 suspended solids,  oil  and grease, and pH.

          The principal waste  streams from  synthetic  rubber  manufacture c
 steam and condensate from the  monomer recovery  stripping operation,
 overflow of coagulation liquors,  and overflow of the  crumb rubber  rinse
 waters.   Area washdown and  equipment clean-out  wastewaters are also major
 sources  of  pollutants, particularly in latex rubber plants where  cleanup
 more frequent because  of smaller  production runs.  For manufacturers  of
 synthetic rubbers, the following  pollutant  parameters  have been designate
 as  significant:  chemical  oxygen demand,  biochemical oxygen demand,
 suspended solids,  oil  and grease, and pH.


                                  W4.4-4

    -------
                                     Table U4.il. 1.   Pollutants and sources
Subcategory
 Pollutant a/
                      Source
A.  Tires and inner cubes
Synthetic Rubber Industries:


3.  Emulsion crumb rubber


C.  Solution crumb rubber

0.  Latex rubber
General Molded, Extruded and
Fabricated Ruober Product?

E.  Small

F.  Medium

G.  Large
Declaimed Ruober

H.  Wet digestion
 I.  Pan , dry digestion,
    and mechanical
TSS




Oil and grease



PH

COD


30DS.


TSS




Oil and grease




pH





TSS




Oil and grease



pH

Lead



COD
TSS
•  Washdown and runoff 'rom compounding areas
•  Discharges of soaostone solution
•  Nonprocsss boiler Slowdowns
•  Water treatment wastes

•  Washdown, runoff, spills, and leakage in
   process areas wmch pick up lubricating
   and extender oils

•  Process wastewaters

•  Organic compounds which contact process
   wastewater

•  Organic compounds which contact process
   wastewater

«  Uncoagulated rubber (emulsion crumb and latex
   rubber subcategories
•  Rubber crumb fines (emulsion crumb and
   solution crumb subcategories

•  Insoluble monomers
•  Solvents and extender oils  (emulsion crumb ar,c
   solution crumb suocategones)
•  Miscellaneous machinery and hydraulic oils

•  Acidic coagulation liouors  (emulsion crumb
   subcategory)
•  Strong caustic soda solutions  bled into
   effluent where monomer inhibitors are removed
•  Washdown and runoff from compounding areas
t  Discharge from anti-cack solutions
•  Nonprocess boiler blowdowns
•  Water treatment wastes

•  Washdown, runoff, spills, and leakage in
   process areas which pick up lubricating,
   process, and fuel 01 Is

»  Process wastewaters

•  Vulcamzer conaensate and contact cooling
   waters from nose proouction facilities  using
   a lead sheath cure
   Qewatering wastewaters  (wet aigest'.on  sub-
   category)
   Condensed  vapor streams for depolymenzation
   Anti-tack  solutions
   Oi 1  and grease
   Washdown and runoff from compounding  areas
   Discnargers  of anti-tack solutions
   Nonprocess  boiler blowdowns
   Water treatment works
   Dewatering  liquor when  fibrous  stock  is  fed
   to digesters (wet digestion  subcategory)

                   Continued  ...
                                                    W4.4-5

    -------
                                          Table  W4.4.1.   (Continued)
Subcategory
 Pollutant a/
                   Source
Latex Based Products
J.  Latex dipped, extruded
    and molded rubber
Oil and grease        «  Digester arocess oil  in dewatering liquor
                         (wet digestion subcategory)
                      •  Organics scrubbed from vapor streams
                      •  Lubricating oil  leakage

pH                    •  Dependent on formula  used in wet digestion

3005_                  •  Organic compounds which contact process
   ~                     wastewater (dependent on product washing
                         technique employed)

TSS                   •  Uncoagulated latex from washdown and clean c
                         waste
    Latex foam
pH


Chromium



Zinc
pH adjustment made in process wastewaters f(
chemical coagulation treatment process

When chromic acid is used in form-cleaning
solution (latex dioped, extruded and molded
rubber subcategory)

Foam wash waters when zinc is used (latex
foam subcategory)
a/  Pollutants listed include only tnose regulated oy erfluent  limitations  guidelines  ana  standards.

Source:  Development Documents EPA-440/l-74-013-a, pp.  65-31  and  £PA-440/l-74-030-a,  pp. 91-116.
                                                    W4.4-6

    -------
          The major process wastewater streams from the production of
general molded, extruded, and fabricated rubber products are spills,
leakage and washdown, from processing areas, and runoff, from outdoor
storage areas; vulcanizer condensate and contact cooling water from the
curing of lead-sheathed and cloth-wrapped hoses; and vulcanizer condensate
from the curing of cement dipper items.   Process wastewaters evolved from
sources within the general molded, extruded, and fabricated rubber plants
subcategories are to be treated for suspended solids (TSS), oil and grease,
lead (from lead-sheathed hose production) and pH.

          The primary sources of process wastewater streams for the
reclaimed rubber industry are dewatering liquor and defibering scraps from
the wet digester process; spills, leaks  and washdown from processing areas;
and vapor condensate collected by air pollution control devices.   The
effluent guidelines and standards for the reclaimed rubber subcategories
have designated chemical oxygen demand (COD), suspended solids (TSS), oil
and grease, and pH as the contaminated constituents to be controlled.

          The major wastewater streams from the production of latex based
products are product washwaters (which will contain zinc when zinc oxide is
used in late foam manufacture); spills,  leaks, washdown and run-off from
latex storage, compounding and transfer areas; discharges from foam
cleaning operations.  The effluent guidelines and standards for the latex
based products subcategories regulate the quantity or qualities of
biological oxygen demand (BOD5_), suspended solids (TSS), pH, chromium (from
chromic acid cleaning operations), and zinc (from zinc oxide curing).

Control Technology

          Various control technologies used to meet BPT, and NSPS were
recommended and costed in the rubber processing industry's Development
Documents.  Various control technologies were also recommended to meet
pretreatment standards for new sources but were not costed.  Existing
source pretreatment standards have not yet been promulgated and all of the
BAT limitations are less than or equal to BPT.  The recommended
technologies for this industry are summarized below:

          BPT, NSPS.  The technologies recommended to meet BPT
regulations, and NSPS consist of:

          t  Elimination of any discharge of soapstone solution by:

             -  Recycling soapstone solution;
             -  Installation of curbing  and sealing drains around the
                soapstone dipping area;  and
             -  Reuse of recirculating system washwater as makeup for
                fresh soapstone solution.

          •  Elimination of any discharge of latex solution by:

             -  Installation of curbing  and sealing drains around the
                latex dipping area; and
             -  Containment of all  wastewaters in the area.

                                  W4.4-7

    -------
          •  Segregation, control  and treatment of all  oily waste streams
             by:

             -  Isolation of process wastewaters from nonprocess
                wastewaters;
             -  Treatment of process wastewaters with API-type gravity
                separation; and
             -  Additional  treatment through an absorbant filter.

          The control  and treatment technology recommended to meet BPT an<
NSPS guidelines for emulsion crumb and latex plants is chemical coagulatii
and clarification; biological  treatment by activated sludge processes;
improved housekeeping and maintenance practices; and in-plant modificatio
for crumb plants such as the use of crumb pits to remove crumb rubber fin>
from coagulation liquor and crumb rinse overflows.

          Because solution crumb wastewaters do not contain uncoagulated
latex solids, the chemical  coagulation step is not necessary.  BPT and NS
technology for solution crumb plants have been defined as comparable to
primary clarification and biological treatment, with the use of crumb pit:
to catch crumb rubber fines before treatment.

          The control  and treatment technology recommended for general
molded, extruded, and fabricated products plants to meet BPT and NSPS
guidelines consists of eliminating anti-tack or latex solution discharge
and isolation, control, and treatment of all oily waste streams.  The
discharge of anti-tack and latex solutions can be eliminated by recycling
of soapstone solution, installation of curbing around the soapstone dippi
area and latex storage and transfer areas, sealing of drains in the dippi
area and latex use areas, reuse of the recirculating system wash water as
makeup for fresh soapstone solution, and the containment of all
latex-contaminated waste streams.   Control and treatment of oily waste
streams involves segregation, collection, and treatment of runoff from oi
storage and unloading areas and leakage and spills in the process areas.

          For plants manufacturing hose via lead-sheathed processes
additional control technology for the control of lead is required.  The
recommended treatment for lead is accomplished by segregation and precoat
filtration and lead-laden waste water.

          None of the wet-digestion reclaim rubber plants discharge
directly, and no new plants will use the wet-digestion process.

          Waste from the pan, mechanical, and dry digestion reclaim
processes are comparable to those from the general molded rubber plants.
The technology recommended for meeting BPT and NSPS guidelines includes
eliminating anti-tack solution discharge and segregation, control, and
treatment of all oily waste.

          The control  and treatment technology recommended for latex-dipp-
products to meet BPT, BAT and NSPS guidelines includes chemical stream
segregation of process wastewater from nonprocess wastewater;  coagulatio


                                  W4.4-8

    -------
and clarification; and biological treatment of the clarified waste stream
in an aerated lagoon and subsequent settling and removal of the settled
solids.  Additional control and treatment techniques are required for latex
dipping operations which use chromic acid as a form cleaning agent.  These
wastes can be eliminated by use of alternative cleaning techniques.  If the
chromic acid cleaning technique cannot be replaced, chemical precipitation
and sedimentation is required.

          PSNS.  For latex foam, the technologies recommended to meet BPT
and NSPS guidelines include chemical coagulation and clarification of
latex-bearing wastewaters and chemical precipitation of zinc ^rom the rinse
waters.  The clarified wastewaters from these two streams are combined in a
neutralization tank and the pH is adjusted to a level  suitable for
biological treatment.

          A minimum level of pretreatment must be given to wastewaters that
will be discharged from new production facilities to publicly owned
treatment works, and pollutants which would inhibit or upset the
performance of such treatment works must be eliminated.  Pretreatment
recommendations for process wastewaters from the tire and inner tube
industry include the separation of oils and solids in an API gravity
separator and the use of an equalization basin to prevent shock loads of
oil, suspended solids, or batch dumps of dipping solutions.  For nonprocess
wastewaters, such problems as acidity, alkalinity, solids, oils, and heavy
metals may require control at the plant to conform to local ordinances for
discharge to publicly owned treatment works.

          Pretreatment standards for emulsion crumb rubber and solution
crumb rubber were revoked February 14, 1978.  The pretreatment requirements
for wastewater discharges to publicly owned waterworks from latex rubber
plants are chemical coagulation of latex-laden wastewaters and
neutralization or equalization of utility wastes.

          Pretreatment recommendations for process wastewaters from
facilities producing molded, extruded, and fabricated rubber products
including latex-dipped products and latex foam; wet-digestion reclaimed
rubber; and pan, mechanical, and dry digestion reclaimed rubber include the
separation of oils and solids in an API gravity separator, and the use of
an equalization basin to prevent shock loads of oil, suspended solids, or
batch dumps of dipping solution from upsetting the performance of treatment
works.  In addition, lead-laden wastewaters from general rubber products,
latex-laden wastewater from latex-based products, chromium from
latex-dipped products, and zinc from latex foam products must be treated.
If fibers are digested with rubber scrap, a large sedimentation lagoon may
be required.

Costing Methodology

          Waste pollution control costs to the rubber processing industry
for compliance with effluent limitations, pretreatment standards,  and new
source performance standards were presented by EPA in  the two Development
Documents for the rubber processing industry.   These costs were developed


                                  W4.4-9

    -------
for one plant of typical size for each of the industry subcategories.  T
analysis used these costs and typical plants to derive cost regulations
the total capital and O&M costs of the regulations.  These costs of
compliance for the rubber industry are presented in Table W4.4.2.
                                  W4.4-10

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                                                                     W4.4-11

    -------
                 Chapter W4.5  Soap and Detergent Industry
Regulations

          The costs included in this chapter are for BPT, BAT and NSPS
regulations promulgated in 1974 and 1975.  Little regulatory activity has
occurred since that time.  This industry has been exempted from additional
federal guidelines under Paragraph 8 of the 1976 settlement agreement with
NRDC.

Industry Characteristics

          Soap and detergent industry establishments are engaged in the
manufacture of soap, synthetic organic detergents, inorganic alkaline
detergents, or any combination of these processes.  The term "soap" refers
to those cleaning agents which are derivatives of natural fat.  The term
"detergent" is generally restricted to cleaning compounds derived largely
from petrochemicals.

          Soaps and detergents are produced by a variety of manufacturing
processes.   For the purpose of establishing effluent limitation guidelines
and standards of performance the industry has been divided into 19
subcategories based on processes and products:
Soap Manufacture
                Soap Manufacture—Batch Kettle and Continuous
                Fatty Acid Manufacture by Fat Splitting
                Soap from Fatty Acid Neutralization
                Glycerine Recovery
                Glycerine Concentration
                Glycerine Distillation
                Soap Flakes and Powders
                Bar Soaps
                Liquid Soap
Detergent Manufacture
                Oleum Sulfonation and Sulfation (Batch and Continuous)
                Air- Sulfur Trioxide Sulfation and Sulfonation (Batch ana
                Continuous)
                Sulfur Trioxide Solvent and Vacuum Sulfonation
                Sulfamic Acid Sulfation
                Chlorosulfonic Acid Sulfation
                Neutralization of Sulfuric Acid Esters and Sulfonic Acids
                Spray Dried Detergents
                Liquid Detergent Manufacture
                Detergent Manufacturing by Dry Blending
                                  W4.5-1

    -------
             •  Drum Dried Detergents
             •  Detergent Bars and Cakes

          The leading products for each class are toilet bars in the soa
segment and laundry detergents in the detergent segment.  Household laum
detergents also account for a large percent of the total value of shipme
of soaps and detergents made by all industries.

          The largest fraction of the industry's establishments,
approximately one-third, is located in the North Central region of the
United States.  Although there are a large number of producers, the soap
and detergent industry is an oligopolistic industry.  About 2 percent of
the establishments account for 47 percent of the industry's value of
shipments, 5 percent account for 69 percent of the industry's value of
shipments.  The "big three" companies in the soap and detergent industry
are Proctor & Gamble, Lever Brothers, and Colgate-Palmolive.

          Production has been maintaining a 4.6 percent growth, and is
expected to continue.

Pollutants and Sources

          The manufacturing of soaps and detergents represents a minor
source of water pollution.  Approximately 98 percent of the plant efflue
go to municipal treatment plants with the remaining 2 percent of the
industry discharging as point sources.  Raw waste loads from the soap an
detergent manufacturing process vary considerably.

          The processes that are heavy effluent generators are:  (1) bat
kettle, (2) fatty acid manufacturing by fat splitting and distillation,
glycerine recovery, (4) bar soap manufacture, (5) spray drying of
detergents, and (6) manufacture of liquid detergents.  The major polluti
sources for these processes are:  washout of equipment, leaks and spills
discharge of barometric condenser water, cooling tower blowdown, and
discharge of scrubber waters from air pollution control equipment.
Constituents of these wastewater streams are fats, fatty acids, glycerin
oil and grease, salts, lye, and the soap or detergent produced in the
plant.

          The other processes are able to recycle their wastewater or us
dry cleanup process.  Therefore, they have virtually no water pollutants

          The pollutants covered by the effluent limitations guidelines
the soap and detergent industry are BOD5, COD, suspended solids,
surfactants, oil and grease, and pH.

Control Technology and Costs

          The largest reductions in the pollution load from this industr
can be made through lower process water usage.  One of the biggest
improvements would be either changing the operating techniques associate
with the barometric condensers or replacing them entirely with surface


                                  W4.5-2

    -------
condensers.  Large reductions in water usage in the manufacture of liquid
detergents could be achieved through the installation of additional water
recycling, and by the use of air rather than water to blow out filling
1i nes.

          BPT guidelines call for plants to adopt good housekeeping
procedures, adopt recycling where appropriate, and install biological
secondary treatment (bioconversion).  BAT guidelines assume improvement in
manufacturing processes such as the replacement of barometric condensers by
surface condensers, installation of tandem-chilled water scrubbers (for
spray-dried detergents), and the use of a batch counter current process in
air-sulfur trioxide sulfation and sulfonation.  In addition, improvements
in end-of-pipe treatment are expected including the addition of sand or
mixed-media filtration or the installation of a two-stage, activated sludge
process.  New source performance standards are the same as BAT for most
product subcategories.  Improvements over the old BAT requirement are
expected as some plants are installing new, lower polluting processes, such
as continuous processes instead of batch processes.

          Since approximately 98 percent of the soap and detergent
manufacturers discharge into municipal sewers, the total cost to the
industry of meeting these guidelines is low.  For the purpose of estimating
annualized control costs, three model plants were created.  These models
contain principally those processes to be heavily impacted by the effluent
guidelines recommendations.  The models are:

             (1)  A small soap company
             (2)  A small liquid detergent company
             (3)  A very large integrated soap and detergent company.

          The control costs for the industry are shown in Table W4.5.1.
These costs represent the situation as determined by consultation with
cognizant EPA staff as of February, 1982.
                                  W4.5-3

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                                                                     W4.5-4

    -------
                     Chapter W4.6  Carbon Black Industry


          Costs in this report are based on nine non-conforming plants
(38.6 percent of industry capacity) of a total population of 30 plants.
The other plants were in conformance with EPA water regulations before the
regulations were promulgated.

Regulations

          On January 9, 1978, the proposed guidelines for BAT, NSPS, and
pretreatment for this industry were promulgated without modifications, and
BPT regulations for the furnace process were withdrawn.  Most of the plants
were in compliance before the regulations were promulgated.  The withdrawal
of the BPT regulations effectively gave the remaining 9 furnace plants
until July 1, 1983 to achieve no discharge of wastewater pollutants.

Industry Characteristics

          Carbon black is a black, fluffy, finely divided powder consisting
of 90 to 99 percent elemental carbon.  Carbon black is uniquely different
from other bulk carbons, such as charcoals and cokes, both in terms of
properties and applications., Although there are many different grades of
carbon black, it is generally treated as a single product.

          In essence, carbon black is manufactured by producing carbon from
either liquid or gaseous hydrocarbon materials.  Depending upon the
process, the production is achieved either by thermal degradation or
incomplete combustion.  In the United States, four different manufacturing
processes have been employed, including the furnace, thermal, channel, and
lampblack processes.  The furnace process accounts for about 95 percent of
U.S. production, the thermal process about 5 percent, and the lampblack
process for a very small fraction.  The last U.S. channel" carbon black
plant closed in 1976.

          Seven companies operate 30 furnace black plants, two of which
also contain facilities for the production of thermal black.  The
capacities of these 30 plants range from 23,000 to 130,000 metric tons per
year.  In addition, two small plants produce lampblack, one small  plant
produces bone black, and one small plant produces acetylene black.   All
establishments producing furnace or thermal black are classified in
SIC 2895.  This establishment classification accounts for about 99  percent
of all U.S. carbon black production.

          The major end uses of carbon black are in the manufacture of
rubber, printing ink, paint, paper, and plastics.  Typically, more  than 93
percent of total carbon black consumption is in rubber applications, and
                                  W4.6-1

    -------
the rubber tire industry is by far the principal consumer.  Printing ink
represents the second largest use of carbon black.  The United States is
net exporter of carbon black (typically 5 percent of total production).
Recently installed overseas production capacity has resulted in a trend
toward shrinking U.S. exports, however.

          The U.S. production of carbon black has fluctuated considerably
since 1967.  Average growth in the period 1967 to 1978 was 1.85 percent
year.  The various pressures on the automotive industry are expected to
reduce future growth of the carbon black industry to about 1.6 percent p>
year.  U.S. carbon black production was 1.497 million metric tons in 197v
and should be about 1.755 million metric tons in 1988.

Pollutants and Sources

          The thermal black process produces an inherent process wastewa
stream.  It consists of recirculating cooling-water purge contaminated w
carbon black.  In the thermal black process, furnace gas is quenched wit
water to reduce its temperature before it is passed through bag filters
where the product carbon is removed.  The hydrogen-containing exit gas t
contains an appreciable amount of water vapor, which must be removed bef
recycling the hydrogen back into the process as fuel.  The water vapor i
the gas stream is removed by cooling the gas stream with water sprays, t
lowering the gas temperature below the boiling point of water and thereb
condensing out most of the moisture.  The spent spray water undergoes a
temperature rise caused by the liberated heat of condensation and must,
therefore, be cooled prior to reuse.  Typically, the spray water is part
a cooling water circuit in which fresh makeup water is added to replenis
inevitable losses within the system.  As with most cooling circuits, it
necessary to purge or "blow down" a certain fraction of the total
circulation to prevent the buildup of undesirable contaminants.  In the
thermal black process, this blowdown stream is contaminated with small
amounts of carbon black lost from the process.  Thermal black plants may
eliminate this blowdown stream by using it to quench the hot gases leavi
the furnaces.  Otherwise, the purge stream forms a point-source discharg
The two thermal black plants still in operation are located on the same
sites as two furnace black plants, and had achieved no discharge of proc
wastewater contaminants by 1976.  No further consideration will be given
thermal plants.

          Carbon black manufacturing plants employing the furnace black
process do not produce an inherent process wastewater stream.  Certain
furnace black plants, however, do have small plant washdown streams and
stormwater runoff streams.  The local rainfall/evaporation relationship
plays a large role in determining whether there is, or is not, a
point-source discharge from the plant.  Of a total of 30 furnace black
plants, 21 do not have point-source discharges.  Some plants have no
discharge primarily because of favorable climate conditions, while other
are able to use excess water as quench water.  Nine furnace black plant;
were found to discharge process wastewaters in 1976, whereas the remain'
furnace plants had no discharge.
                                  W4.6-2

    -------
Control Technology

          The control technologies recommended and costed by EPA in the
Development Document consist of two wastewater treatment steps:  Step 1
consists of sedimentation and Step 2 consists of filtration.   It is
anticipated that certain plants will require only Step 1, while other
plants will require both Step 1 and Step 2.  In any case, the  cost model
provides for the treated effluent to be totally recycled back  to the
process.  This treatment is intended to reduce the discharge of total
suspended solids (TSS) from an average of 0.97 kg/metric ton of product to
zero.

Costing Methodology

          Water-pollution control costs are given in 1974 dollars in the
EPA Economic Analysis of the Carbon Black Industry for a thermal black
plant having a capacity of 214 metric tons per day (74,900 metric tons per
year).  The capital cost is given as $279,900 and annual operating and
maintenance costs as $11,200 for control involving both sedimentation and
filtration.  Costs were applied to the nine plants that were discharging
process wastewaters in 1976.  The average capacity of these plants is
77,800 metric tons per year.  In 1974 dollars, the investment  cost averages
$286,350 per plant, or total investment costs are $2,577,150.  The annual
operating and maintenance cost is $11,640 per plant, or $104,760 for all
nine plants.

          The BPT regulation was withdrawn in 1978 for these plants,
although one plant was scheduled to be in compliance by July 1, 1977.  It
is estimated that about 50 percent of these plants will have made their
investments by 1981 and the remaining 50 percent by 1983.

          The costs estimated on the above basis are given in  Table W4.6.1.
As stated above these costs are based on achievement of zero discharge by
nine plants.
                                  W4.6-3

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                                                                     W4.6-4

    -------
                     Chapter W4.7  Explosives Industry
Regulations
          Effluent limitations were established for this industry in 1976
for BPT and BAT.  The non-military sector of this industry was exempted
under Paragraph 8 of the 1976 settlement agreement with the Natural
Resources Defense Council.  This sector will not be affected by any
national effluent limitations other than the BPT.

Industry Characteristics

             The U.S. explosives industry includes over 600 plants.
Explosives plants generally are evenly distributed in the eastern portion
of the United States, away from large population centers.  Plant sites
range from a few hundred to several thousand acres.  The general production
process for the manufacture of explosives involves the nitration of an
organic molecule, such as glycerine, toluene and cellulose.  Raw materials
used in this process are nitric acid, acting as a nitrate source, and
sulfuric or acetic acid, acting as a dehydrating agent.  Nitration products
include nitroglycerin, dinitroglycerin, trinitrotoluene, dinitrotoluene,
trinitroresorcinol, nitromannite, and nitrocellulose.

             For the purpose of establishing effluent limitations guidelines,
the explosives industry has been divided into the following four
subcategories based upon the raw material used and the process employed:

             •  Explosives - Category A
             t  Propel!ants - Category B
             »  Load, Assemble, and Pack plants (LAP) - Category C
             t  Initiating-Compound Plants - Category D.

Pollutants and Sources

             The wastewater sources associated with each subcategory are
presented in the following sections.

             Manufacture of Explosives.  The wastes from this category are
characteristically high in BODr, COD, nitrates, sulfates, and TOC.  Highly
variable pH is also characteristic of the wastewater from the explosive
industry.  The major waste loads generally come from the finishing area
where the crude explosive becomes the finished product.

             Manufacture of Propel!ants.  The waste loads associated with the
manufacture of propellents are usually higher than those associated with
the manufacture of explosives.  Suspended solids are a troublesome problem,
especially in the manufacture of nitrocellulose.  Wide variation in pH is
also a problem.  High BODr, COD, and TOC levels can be attributed to the
organic compounds and solvents involved in the processes, while high


                                  W4.7-1

    -------
nitrate and sulfates can be attributed to the use of nitric acids and
sulfuric acids, respectively.
             Load, Assemble, and Pack Plants.  Waste loads from this cate<
are the mildest in the explosive industry but the most variable.  BODr,
COD, nitrates, sulfates, TOC, and TSS are in the effluent waste loads.
             Im'tiatin^-Compound Plants.  The waste loads associated with
manufacture of initiating compounds are the highest of any category in th
explosives industry, due to the highly concentrated waste streams and sma
volumes of production.  Because of the small  quantities, batch processes
are used in this category and recovery of spent materials is not attempte
Waste loads are high in the following parameters:  BODr, COD, nitrates,
sulfates, TOC, TSS, and TKN (Total Kjeldahl Nitrogen).

             For the purpose of establishing effluent guidelines for the
explosives industry the following parameters have been defined to be of
major significance:  BOD5, COD, TSS, pH, and oil and grease.

Control Technology and Costs

             The technology for the control and treatment of waterborne
pollutants in the explosives industry can be divided into two broad
categories:  in-process and end-of-pipe.  In-process depends on two major
conditions.

             •  Altering the processes that generate water pollutants
             •  Controlling water use in non-process as well as process a

             Specific in-process control practices applicable to the
explosives industry include good water management, which, with recycling
of process cooling water, can have a significant effect on hydraulic
loading and would reduce treatment costs.  Separation of process and
noncontact waters is a first step in economical pollution abatement.  Pri
to end-of-pipe treatment, the following plant control measures will be
mandatory:  neutralization facilities, catch tanks on finishing explosive
lines, and other pretreatment facilities.

             The recommended technology for achieving BPT guidelines reli
upon the use of an activated sludge treatment plant for Categories A, 8,
and D.  For Category C an extended aeration package system was recommende
Also, since many of the waste streams have extreme pH values,
neutralization is necessary.

             Costs for this industry are summarized in Table 4.7.1.
                                  W4.7-2

    -------
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    -------

    -------
             Chapter W4.8.  Pesticides and Agricultural Chemicals
Regulations

          Regulations affection this industry were revised under the
provisions of the NRDC Consent Decree.   In November 1982 EPA proposed
regulations for BCT, BAT, NSPS, PSES, PSNS, and expanded BPT to include
active ingredients which were excluded  from the original BPT regulations.
However, revision of this chapter was limited to adjusting pollution
control costs to 1981 dollars.  The effect of any changes in the
regulations affecting the pesticides and agricultural  chemicals industry is
not reflected in the text of the chapter or the cost estimates included in
Table W4.8.3.  The cost estimates represent the impact of the regulations
as originally promulgated.

Industry Characteristics

          The pesticide chemicals manufacturing industry is classified
under SIC 2879 and has been subdivided  for pollution control purposes into
six subcategories.  Five of these relate to the type of product, and the
sixth to a specialty operation concerned with formulating and packaging.
The subcategories are as follows:

             Subcategory A—Halogenated organics production
             Subcategory B~0rgano-phosphorus production
             Subcategory C—Organo-nitrogen production
             Subcategory D--Metallo-organic production
             Subcategory E--Formulation and packaging
             Subcategory F—Miscellaneous pesticides not otherwise
                            classified.

          The products of the pesticide industry have  generally been
divided into three basic classes—herbicides, fungicides, and insecticides.
The largest group in terms of value is  the herbicides.

          The products of this industry are highly varied and over 400 have
been identified according to the various subcategories.   Note that
separate, more strict standards have been enacted for  several pesticides as
toxic pollutants.

          The chemistry involved in the production of  pesticides is highly
varied and complex, so that many different chemical  operations are used.
In addition, the plants which formulate rather than  produce the pesticides
usually employ a number of operations.   The five production subcategories
are discussed below.

          Halogenated Organic Compounds.  Ninety-eight products were
identified in this Subcategory.These  have been further broken down into
five groups, and are related to their major use as shown in Table  W4.8.1.
                                  W4.8-1

    -------
              Table W4.8-1.  Halogenated organic pesticide
                          groupings and use
       Group            Compound

        Al        DDT*
                  Dithiocarbamates
                  Methoxychlor
                                      Use
                           Insecticide
                           Fungicide
                           Insecticide
        A2
2.4-0
2.4.5-T*
MCPA
Herbicide
Herbicide
Herbicide
        A3
Toxaphene
Chlordane/heptachlor
Endosulfan
Endrin
Insecticide
Insecticide
Insecticide
Insecticide
        A4
Methyl bromide

Lindane
Fumigant (insects,
  weeds, rodents, etc.)
Insecticide
        AS
Dicamba*
Amiben*
Propanil
Herbicide
Herbicide
Herbicide
'Representative of the subcategory and used in the economic impact anal
 of  the  prepared standards on this subcategory.
                                W4.8-2

    -------
          Orqano-Phosphorus Compounds.  This category contains 93 compounds
used primarily as insecticides.Some widely used materials in this group
are listed below:

             Methyl  parathion
             Fenthion
             Ronnel
             Diazinon
             Guthion
             Malathion
             Oisulfoton

          Qrgano-Nitrogen Compounds.   Two-hundred-nine (209) compounds were
identified as belonging to this group which contains some of the largest
selling pesticides produced.   These have been further classified into seven
groups, as shown in  Table W4.8.2.   Most of the large selling items are
herbicides, with minor production  of insecticides and fungicides.

               Table W4.8.2.   Nitrogen-containing pesticide
                             groupings and use


                  Grouping                         Primary Use

       Cl)  Aryl and alky!carbonates         Insecticides, herbicides
       C2)  Thiocarbamates                  Herbicides
       C3)  Amides and amines               Herbicides
       C4)  Ureas and Uracils               Herbicides
       C5)  s-Triazines                     Herbicides
       C6)  Nitro compounds                 Herbicides
       C7)  Other      '                     Fungicides,  herbicides
          Metal!o-organic Compounds.   This is the smallest category of
pesticides in both volume and value.   Products are primarily fungicides and
herbicides.

          Formulations.   In addition  to the many pesticides directly
manufactured, there are  also many products on the market produced by
formulation  of combinations of pesticides or other chemicals.   Good
statistics are not readi-ly available  on the distribution of establishments
belonging to this classification.

Pollutants and Sources

          The pesticide  chemical  manufacturing industry  is involved in the
production of many complex organic materials utilizing  sophisticated
processes.  Wastewater pollution  is therefore highly  variable  from plant  to
plant.
                                  W4.8-3

    -------
          Halogenatad Organic Pesticides.   The manufacture of this type
pesticide, usually results in wastewaters  that contain high loadings of
organic materials from operations such as  decanting, distillation, and
stripping.  Spillage, washdowns, and runoff can also be significant if
suitable operational control  is not maintained.  The most significant
pollutants are BOD, COD, suspended solids, phenol, and the pesticide
product.

          Organo-Phosphorus Pesticides.  There are many sources of
wastewater from the manufacture of organophosphorus pesticides.  These
include decanter units, distillation towers, overhead collectors, solver
strippers, caustic scrubbers, contact cooling, hydrolysis units, and
equipment washing.

          The most significant pollutants  are considered to be BOD, COD,
suspended solids, ammonia, nitrogen, phosphorus, and the pesticide prodi

          Organo-Nitrogen Pesticides.  In  the manufacture of this type
pesticide, the principal sources of wastewater are decanting,
extractor/precipitator unit operations, scrubbing, solvent stripping,
product purification, rinsing, and runoff of spillage.  The significant
pollutants are the same as those identified for organo-phosphorus
pesticides.

          Metallo-Qrganic Pesticides.  The primary wastewater sources f
the production of organo-metallic pesticides are product stripping,
washing, caustic scrubbing, and cleaning operations.  The significant
pollutants are dissolved solids, suspended solids, BOD, COD, and the
pesticide product.

          Formulation and Packaging.  Washing and cleaning operations a
the principal sources of wastewater in the establishment.

          MuHi category Producers.  Previous discussions were related tt
plants for which the production was restricted to one category of
pesticide, or to plants for which the waste from one category was
identifiable.  However, there are plants which produce more than one
category of pesticide and, for these, the individual wastes are not rea<
separated.

Control Technology

          The plants producing pesticides  are highly variable in nature
therefore, the control technology in plants producing essentially the s.
product can also be highly variable.  Factors such as economics, pollut.
concentration, and wastewater flow have to be considered when choosing •
control and treatment technology to be used.

          As is the case for other industries, treatment technologies c,
conveniently be divided into (1) in-plant control and treatment and (2)
end-of-pipe control and treatment.
                                  W4.8-4

    -------
          In-Plant Control and Treatment.  In-plant control and treatment
includes steps to reduce wastewater strength and/or volume.  Important
in-plant techniques include proper wastewater segregation in the plant, use
of dry housekeeping equipment, replacement of steam jet ejectors and
barometric condensers by vacuum pumps and surface condensers, and
replacement of process water by an appropriate organic solvent.

          End-of-Pipe Control  and Treatment.  The recommended methods for
end-of-pipe treatment basically involve various clean-up steps such as
setting, skimming, equalization, or other treatment, followed by
detoxification, usually with carbon absorption, followed by biological
treatment.  However, because of the highly variable nature of this
industry,- it is difficult to generalize about the advantages and
disadvantages of the various treatments.  Rather, the approach used has
been to handle each on an individual  basis, and to provide case histories
from background information which has been obtained.

Costing Methodology

          For the purpose of this report the approach used to estimate
control costs was to develop model systems which would meet the wastewater
guidelines and then make cost estimates for implementing those model
systems in actual plants.

          Model systems were planned (1) for end-of-pipe treatment to a BPT
level of Subcategories A, B, and C only.  Plants in Subcategories D and E
should not have a wastewater discharge if properly operated.  All three
model plants are similar in that each waste stream contains separable
organics which must be removed by an oil separator of the API type.
Wastewater streams for Subcategory C also contain considerable quantities
of suspended solids which can be removed in combination with the organic
material.  Some wastestreams contain materials from distillation tower
bottoms which need to be removed and incinerated.  Wastewater from
Subcategory A can be detoxified by carbon absorption, while hydrolysis is
the most satisfactory method for detoxification of wastes from
Subcategories B and C.

          The basic biological treatment consists of an activated sludge
system.  This should include aeration basins, flocculator-clarifiers, and
sludge handling facilities.

          Cost data are summarized in Table W4.8.3.
                                  W4.8-5

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    -------
              Chapter W4.9  Fertilizer Manufacturing Industry


Regulations

          Effluent guidelines and standards for fertilizer manufacturing
were published in 1974; amendments were published in 1975 and 1976.  The
regulations covered BPT, BAT, NSPS and pretreatment for new sources.  BCT
regulations were promulgated in 1979.  This report, however, does not
include the effects of-the amendments and regulations which were made in
1979 and 1980.

Industry Characteristics

          The fertilizer industry can be divided into the production of
phosphatic and nitrogenous fertilizers and the production of mixed N-P-K
fertilizers.  The following products are included in this sector of the
chemical industry:

             Nitrogenous Fertilizers
               Ammonia
               Ammonium nitrate
               Urea
               Ammonium sulfate
             Phosphatic Fertilizers
               Phosphoric acid
               Ammonium phosphate
               Triple superphosphate
             Mixed Fertilizers.

          The manufacture of these fertilizers involves a variety of
chemical processes.  Three of the processes—phosphate rock grinding,
phosphoric acid concentration, and phosphoric acid clarification—do not
require process waters.  The remaining processes are summarized in Table
W4.9.1.

          Sulfuric acid and nitric acid are intermediate products in the
basic fertilizer chemicals industry.  Approximately 25 percent of the
plants produce these chemicals as part of the production of the final
products listed earlier; they are not considered as separate plants for the
purposes of this report.  Plants which produce'sul furic acid or nitric acid
as end products are covered under the inorganic chemicals industry.

          Because fertilizers are traded in a worldwide market, and the raw
materials used are also used in a wide variety of markets, the fertilizer
market is subject to many outside influences.  These influences include
worldwide agricultural demand, the use of nitrates  in explosives, and hence
pressures from the international military situation, and the world market
for synthetic fibers.


                                  W4.9-1

    -------
                 Table  W4.9-1.   Basic  fertilizer  chemicals
                              manufacturing  process
   Product
      Raw Material
          Process
Wet process
Phosphoric acid

Normal super-
phosphate

Triple super-
phosphate
Ammonium
phosphates

Sulfuric acid
Ammonia
Urea
Ammonium
nitrate
Ammonium
sulfate

Nitric acid
Phosphate rock, sulfuric
 acid, water

Sulfuric acid, ground
phosphate rock, water

Ground phosphate rock,
phosphoric acid, water
Ammonia, wet process
phosphoric acid

S02, CL, pelletized
vanadium oxide catalyst,
water
Natural gas or other
hydrogen source,
nitrogen from air,
catalysts

Ammonia, carbon dioxide
Ammonia, nitric acid
Ammonia, sulfurfc acid
Ammonia, air, water,
platinum-rhodium gauze
catalyst
Mixing
mixing, curing
for 3-8 wee^s

Run of pile
process mixing, curinc

    or

Granular triple
superphosphate process
(GTSP) = mixing into «
slurry, drying

Similar to GTSP above
Sulfur-burning process
SO- catalyzed to form
SOj, water added to fc
final product

Hydrogen production  •
followed by reaction v
nitrogen to form arnmor
Ammonium carbamate for
is dehydrated to prodi
urea.

Formed by neutralizat-
then prilled or evapo
to concentrate the pn

Neutralize sulfuric a<
with ammonia

Ammonia oxidized
catalytically by air,
nitrogen pentoxide
absorbed in water
                                 W4.9-2

    -------
Pollutants and Sources
          The major fertilizer waste components include the following:  pH,
phosphorus, fluorides, total  suspended solids (TSS), total  dissolved solids
(IDS), high temperature, cadmium, total  chromium, zinc, vanadium, arsenic,
uranium, radium-226, COD, oil  and grease, ammonia, ammonia  nitrogen,
organic nitrogen, nitrate nitrogen, iron, and nickel.

          The main waste sources contributing to the total  waste load can
be identified as coming from the following processes in each production
area:

          Phosphate Fertilizers

             •  Water treatment plant effluent including raw water
                filtration and clarification, water softening, and water
                deionization
                Closed-loop cooling tower blowdown
                Boiler blowdown
                Contaminated  water (gypsum pond water)
                Spills and leaks
                Area-source discharges including surface runoff from rain
                or snow that  becomes contaminated

          Nitrogen Fertilizers

             •  Water treatment plant effluent including raw water
                filtration and clarification, water softening, and water
                deionization
                Closed-loop cooling tower blowdown
                Boiler blowdown
                Process condensate
                Spills and leaks that are collected in  pits or trenches
                Area sources  collected from rain or snow.

          Mixed Fertilizers

             0  Wet scrubbing  of drier and/or ammoniator exhaust gases
             •  Spills and leaks from pumps and plant wash-ups that are
                collected and  recirculated
             «  Dry product from conveying equipment, when  dissolved by
                precipitation.

          In order to define  waste characteristics, the following basic
parameters were used to develop guidelines for meeting  BPT  and BAT:

          Phosphate Fertilizers
             t  Phosphorus
             •  Fluorides
             t  Total  Suspended
sol ids and pH
                                  W4.9-3

    -------
          Nitrogen  Fertilizers

             t  Ammonia
             •  Organic Nitrogen
             •  Nitrate
             •  pH

          Mixed Fertilizers

                Ammonia nitrogen
                pH
                Phosphorus
                Fluorides
                Nitrate
                Organic nitrogen.

Control  Technology

          Waste treatment practices in the fertilizer industry include:
monitoring units, retaining areas, cutoff impoundments, reuse, recycling
atmospheric evaporative cooling, double-liming (two-state lime
neutralization) surrounding dikes  with seepage collection ditches, sulfi
acid dilution with  pond water,  evaporation, ammonia stripping (steam anc
air), high-pressure air/stream  stripping, urea hydrolysis, nitrificatior
and denitrification, ion exchange, cation/anion separation units, select
ion exchange for ammonia removal,  oil  separation, and ammonium nitrate
condensate reuse.

          BPT guidelines for the phosphate segment call for limitations
pH, TSS, phosphates, and fluorides by  installing the following:
double-lime treatment of gypsum pond water, pond design to contain a
10-year storm, monitoring system for sulfuric acid plant control, and
facilities for contaminated water isolation.   BPT guidelines for the
nitrogen segment can be met by  installing the following:  ammonia steam
stripping, urea hydrolysis, leak and spill control, containment  and reu:
and oil  separation.  BPT guidelines for the mixed fertilizer segment
include manufacturing process control, use of recycle water systems,
recovery and reuse  of wastewater,  and  use of dry collectors for  airborm
sol ids.

          The estimates of the  cost to comply with BAT are based on
installation of pond water dilution of sulfuric acid for the phosphate
segment and by installation of  one of  the following for the nitrogen
segment:  continuous ion exchange followed by denitrification, advanced
hydrolysis followed by high-flow ammonia air stripping or ammonia steam
stripping followed  by either high flow ammonia air stripping or  biologic
nitrification-denitrification.   Because the latter two technologies wen
required in the 1980 amendments to BAT limitations, costs to meet BAT
guidelines may be different than those shown here.  BAT and BPT  guide!i
are identical for the mixed fertilizer segment.

          NSPS standards call for the  following process improvements fo
the nitrogen segment (NSPS standards for the phosphate and mixed fertil
segments are the same as the respective BAT standards):

                                  W4.9-4

    -------
          •  Integrate ammonia process condensate steam-stripping column
             into condensate boiler feed water systems of ammonia plant

          •  Use centrifugal rather than reciprocating compressors

          •  Segregate contaminated water collection systems so that common
             waste streams can be treated more efficiently and cheaply

          •  Locate cooling towers upwind to minimize chance of absorbing
             ammonia in tower water

          t  Design low-velocity airflow prill tower for urea and ammonium
             nitrate to minimize dust loss

          •  Design lower pressure steam levels in order to make process
             condensate and recovery easier and cheaper

          •  Install air-cooled condensers and exchangers to minimize
             cooling water circulation and blowdown.

Costing Methodology

             Capital costs and annual operating and maintenance costs for
control were estimated for model plant sizes for the various manufacturing
processes on the basis of cost data presented in EPA publications.  Costs
for the production of ammonium sulfate and mixed fertilizers were based on
cost data in 1973 dollars presented in the Economic Analysis, Phase II.
Costs for all of the other products were based on cost data in 1971 dollars
presented in the Development Document, Phase I.  The resulting estimates of
the costs of compliance are given in Table W4.9.2.
                                  W4.9-5

    -------
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                                                                         W4.9-6

    -------
               Chapter W4.10  Phosphorus Chemicals Industry
Regulations

          Effluent limitations for the six subcategories in this industry
have not changed substantially since they were originally adopted in 1974
and 1976.  Control level for BPT, BAT (old), NSPS and pretreatment for new
sources were specified and subsequently challenged.  Portions of the
regulations involving specialized definitions and new source performance
standards were remanded for further study in 1976.  No new guidelines for
BAT or NSPS have yet been promulgated.

          On October 5, 1978 the pretreatment standards for the phosphorus
producing, phosphorus consuming, and phosphate subcategories were revoked.
BCT and non-conventional BAT limits were proposed on August 23, 1978 for
the Phase II subcategories.  In 1981, the Fourth Circuit Court of Appeals
remanded BCT requirements because it found that the basis for setting them
was unsound.  This chapter does not reflect this change, and this includes
costs for both BPT and BCT.

Phosphorus Chemicals (Phase I)

          Industry Character!stics.  Establishments included in the
phosphorus chemicals manufacturing industry as defined by the Phase I
effluent limitations guidelines are manufacturers of the following
chemicals:
             Phosphorus
             Ferrophosphorus
             Phosphoric acid
             Phosphorus
             Phosphorus
             Phosphorus
             Phosphorus
                (dry process).
           pentoxide
           pentasulfide
           trichloride
           oxychloride
Sodium tripolyphosphate
Calcium phosphates (food grade)
Calcium phosphates (animal  feed grade).
          This industry is almost entirely based on the production of
elemental phosphorus from mined phosphate rock.  Elemental phosphorus and
ferrophosphorus (a by-product) are manufactured by the reduction of
phosphate rock by coke in very large electric furnaces, using silica as a
flux.  Because elemental phosphorus is relatively low in weight compared to
phosphate rock and phosphoric acid, the elemental phosphorus is produced
near the mining site and shipped to locations near the final markets for
further processing.
                                  W4.10-1

    -------
          Over 87 percent of the elemental  phosphorus is used to
manufacture high-grade phosphoric acid by burning liquid phosphorus in a
the subsequent quenching and hydrolysis of the phosphorus pentoxide vapo
and the collection of the phosphoric acid mist.

          The manufacture of the anhydrous phosphorus chemicals--phospho
pentoxide (P205), phosphorus pentasulfide (Po^c). and phosphorus
trichloride fPCl^)— is essentially the direct union of phosphorus with t
corresponding element.  Phosphorus oxychloride (PQCU) is manufactured f
PCU and air or from PCU, PO^KJ an<^ chlorine.

          Sodium tripolyphosphate is manufactured by the neutralization
phosphoric acid with caustic soda and soda ash in mix tanks.  The result
mixture of mono- and disodium phosphates is dried and the crystals calci
to produce the tripolyphosphate.

          The calcium phosphates are similarly made by the neutralizatio
of phosphoric acid with lime.  The amount and type of lime used and the
amount of water used in the process determine the final  product-- anhydr
monocalcium phosphate, monocalcium phosphate monohydrate, dicalcium
phosphate dihydrate, or tricalcium phosphate.  Animal feed grade
dicalcium phosphate is produced by almost the same process as the other
calcium phosphates.  Because of the lower purity needed in the final
product, defluorinated, wet process phosphoric acid is normally used and
the reaction may be conducted without excess water.

          For the most part, the products included in the phosphorus
chemical industry are produced by divisions of large chemical or petrole
companies.  The derivatives of phosphorus are generally manufactured by
same companies that produce elemental phosphorus, but in different
locations.  Furthermore, a large proportion of the products are used
internally by the producing company for the production of other products
and, hence are not sold on the open market.

          The biggest factors determining the future of the industry are
government regulations and technological innovations.  The declining
production of phosphorus, for example, is the result of government bans
phosphate detergents.  In addition, the TVA plant was shut down in 1976,
a shift to production of wet phosphoric acid was accomplished.

          Pollutants and Sources.  Water is primarily used in the
phosphorus chemical industry for eight principal purposes:  non-contact
cooling water, process and product water, transport water, contact cooli
or heating water, atmospheric seal water, scrubber water, auxiliary proc
water, and water used for miscellaneous purposes.  Very large quantities
non-contact cooling water are used for cooling the electric furnaces use
in phosphorus production.  Contact cooling water is used to quench the s
from the phosphorus furnaces.  Process or product water contacts and
generally becomes part of the product, such as the hydrolysis and diluti
water used in phosphoric acid manufacture and the water used as a reacti
medium in food-grade dicalcium phosphate manufacture.  Because yellow
phosphorus spontaneously ignites on contact with air, air is kept out of


                                  W4.10-2

    -------
reaction vessels with a water seal.  Liquid phosphorus is protected by
storage under a water blanket; these seal waters are considered process
waters.  Auxiliary process waters include those used in such auxiliary
operations as ion exchange regeneration, equipment washing, and spill and
leak washdown.

          The following pollutant parameters have been designated for the
industry's process wastewaters:  total  suspended solids, phosphate and
elemental phosphorus, sulfates and sulfites, fluoride, chloride, dissolved
solids, arsenic, cadmium, vanadium, radioactivity, temperature (heat), and
pH.  The primary parameters, i.e., those which need to be used to set
effluent standards, are total suspended nonfilterable solids, total
phosphorus, fluoride, arsenic, and pH.   The remaining pollutants are either
adequately treated when the primary parameters are treated, or are present
only in waste streams for which a no-discharge standard has been set.

          The effluent limitations guideline for most of the phosphorus
chemical industry is no discharge of process wastewater pollutants to
navigable waters.  Process water is defined as any water that comes into
direct contact with any raw material, intermediate product, by-product, or
gas or liquid that has accumulated such constituents.

          The only exceptions to these  standards are the BPT guidelines for
phosphorus and ferrophosphorus, phosphorus trichloride, phosphorus
oxychloride, and food-grade calcium phosphates.

          Control Technology.  Control  and treatment of wastes are of the
chemical variety.These include neutralization, precipitation, ionic
reactions, filtration, centrifugation,  ion exchange, demoralization,
evaporation and drying.  In-process abatement measures include segregation
of waste streams, recycling of scrubber water, dry dust collection,
containment of leaks and spills, and minimization of the quantity of wash
water.  Many of the manufacturing establishments currently have no
treatment installed, while others have  already achieved a no-discharge
status.

          The technology recommended to achieve zero discharge of
wastewaters in the phosphorus chemical  industry consists of:

          •  Recycling atmospheric seal ("phossy") waters, scrubber
             liquors, and other process waters following lime treatment and
             sedimentation (or alternative methods of reducing water flow,
             such as the use of dilute  caustic or lime slurry instead of
             pure water in the process)

          •  Use of dry dust collectors

          •  The return of process waste streams and blowdown streams to
             the process.

          Zero discharge of arsenic-rich still residues from the
manufacture of phosphorus trichloride can be achieved through treatment
with trichloroethylene.

                                  W4.10-3

    -------
          For those industry subcategories where some discharge is allow
the recommended treatment consists of waste-reducing steps such as those
above, but with some discharge following lime treatment and sedimentatio
sometimes with flocculation.  Additional treatment to achieve no-dischar
for these subcategories consists of:

          •  Total recycling of all process waters by the phosphorus
             producer

          •  Control of PCU vapors by installation of refrigerated
             condensers, minimization of wastewaters with treatment
             by lime neutralization followed by evaporation to dryness
             (for manufacturers of phosphorus trichloride and phosphorus
             oxychloride)

          •  The addition of vacuum filtration of treated wastewaters
             followed by total recycling (for producers of food-grade
             calcium phosphates).

Phosphorus Chemicals (Phase II)

          Industry Characteristics.  Establishments included in this
industry sector manufacture phosphate products by processes that include
defluorination step.  The specific products included are defluorinated
phosphate rock, defluorinated phosphoric acid (both in SIC 2874, Phosphe
Fertilizers), and sodium tripolyphosphate (STPP, in SIC 2819, Industrial
Inorganic Chemicals, n.e.c.) produced from wet-process phosphoric acid.
The one plant that produces STPP by this process was included in the Phe
I report with the 17 plants that use furnace process phosphoric acid, sc
STPP will not be considered here.

          The defluorination of phosphate rock is accomplished in a rote
kiln or fluid-bed reactor.  The rock is blended with sodium-containing
chemicals, wet-process phosphoric acid, and silica then defluorinated ir
the reactor at 1200-1400C (2200-2600F).

          Wet-process phosphoric acid is defluorinated by either of thre
processes.  In two of the processes, wet process phosphoric acid is
dehydrated by evaporation to produce superphosphoric acid, and
defluorination is accomplished adventitiously.  The evaporation may be
accomplished by either vacuum or submerged combustion processes.
Defluorinated phosphoric acid can be produced by an aeration process in
which fine silica is added to wet-process phosphoric acid and is removec
ultimately, along with fluoride, as volatile silicon tetrafluoride under
conditions that do not remove water.

          The major use for defluorinated phosphate rock is as an
ingredient of animal feeds.  Production of this product has been increas
at a rate of nearly 4.5 percent per year since 1968, and is expected to
show a similar growth rate through 1986.  A large fraction of defluorin<
phosphoric acid is used to produce dicalcium phosphate for animal feeds.
Increasingly large quantities are being used in liquid fertilizers and c
                                  W4.10-4

    -------
an intermediate in the production of dry mixed fertilizers.  The production
of superphosphoric acid from wet-process phosphoric acid is expected to
increase at about 9.5 percent per year.  Defluorinated phosphoric acid
other than the super acid is expected to increase at about 4 percent per
year.

          Pollutants and Sources.  The major source of water pollution in
these processes is the water used to scrub contaminants from gaseous
effluent streams.  Process conditions are such that recirculated
contaminated water can be used for this purpose.  Spills and leaks are
collected and added to the contaminated water pond.

          The proposed effluent limitations guidelines specify no discharge
of process wastewaters except under certain chronic or catastrophic
precipitation events.  If wastewaters must be discharged under such events,
they must be treated so they do not exceed the following limitations:

                                         Daily            30-Day
                                        Maximum,          Average,
                                         mg/1              mg/1

           Suspended solids               150               50

           Phosphorus                     105               35

           Fluoride                        75               25

           pH                           Within the range 6.0 to 9,0

          Control Technology.  The major control technology is the use of
ponds of adequate size.  To accommodate rainfall incidents for BPT, at
least 60 cm (24 inches) freeboard is required (150 cm or 60 inches in
Florida).  For SAT, additional  dike height is required (assumed for cost
purposes to be 15 cm or 6 inches).

          To achieve the necessary reduction of contaminants for discharge
of waters, pond water can be treated with lime to neutralize the phosphorus
and fluorides.  Solids are then settled prior to discharge.  Two separate
settling ponds are needed for contaminated water treatment -- one each for
calcium fluorides and calcium phosphates.  Most of the existing plants
already meet BAT guidelines.

Industry Cost Model

          The approach to estimating the costs of compliance for the above
categories of operations consisted of developing model  plant populations
and cost functions for each of the subcategories defined by the
regulations.  Data were obtained from the EPA Development and Economic
Analysis Documents, and modified or updated with information from the NCWQ
study of 1975, the 1976 NBER study for EPA, and data from the 1979
Directory of Chemical Producers.   Although BAT guidelines have been
remanded, permit writers may still impose BAT level  discharge limitations.


                                  W4.10-5

    -------
The costs indicated under the BAT category refer to the costs incurred
beyond BPT which are imposed by individual permit conditions.  The
estimated costs developed on the above basis are given in Table W4.10.1,
                                  W4.10-6

    -------
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    -------
                     Chapter U4.ll  Paint Formulating
Regulations
          New regulations were proposed in January of 1980 (45CFR912) for
BPT, BAT, NSPS, PSES and PSNS for this industry.  Subsequently, this
industry was excluded from Paragraph 8 under a settlement agreement.  These
proposed regulations and their impacts are not reflected in the text of
this chapter nor costed along with other regulations.  Regulations
established through 1975 are costed and discussed in the text of this
chapter.

          The original regulations published in 1975 cover only
solvent-based production operations.  The regulations established in 1980
are based on the premise that water-based production operations would also
be required to achieve no discharge of process wastewater pollutants.
Pretreatment is required in cases where the discharge of water-based paint
wastes could cause sewer maintenance problems because of solids settling in
low spots or adhering to sewer walls.

Industry Characteristics

          The manufacturing of paint involves the mixing or dispersion of
pigments in oil, resin, resin solution, or latex.  Mixing is then followed
by the addition of specified portions of organic solvents or water to
obtain the desired viscosity.

          In 1972 there were 1,599 plants manufacturing paint and allied
products in the United States.  Production is not divided evenly among
these plants.  Roughly 40 percent of the plants, each employing fewer than
10 persons, shipped only 3 percent of the total value of shipments for the
industry.  Plants employing 250 or more workers accounted for less than 10
percent of the number of plants, and 33 percent of the industry's total
value of shipments.

A historic trend in the industry toward fewer and larger plants is expected
to continue.

          In 1976, total production is estimated at 4,644 million liters
(1,227 million gallons), with about 22 percent water-based.  It is
estimated that total production will be about 7,525 million liters (1,988
million gallons) in 1986, 29 percent of which is expected to be
water-based.  Production of water-based paints was 754.4 million liters
(199.3 million gallons) in 1972, about 1,022 million liters (270 million
gallons) in 1976, and should be about 2,184 million liters (577 million
gallons) in 1986.

Pollutants and Sources

          The products of the paint industry are either solvent-based or
water-based.  The production of solvent-based paints produces little
                                  W4.11-1

    -------
wastewater effluent.  The bulk of the wastewater from the industry is the
result of clean-up operations in the manufacture of water-based paints.
Most paint plants are located in highly industrialized urban areas near tf
markets, and most of the wastewater is discharged to municipally operated
sewer systems, with or without pretreatment.

          The major wastewater contaminants in paint plants are pigments
and latex.  Other significant water pollutants are driers and wetting
agents, oils, resins, and caustics (used in cleaning).  There may also be
some contamination by fungicides (including mercurials), heavy metals, anc
solvents.  Recent State and Federal regulations are forcing the paint
industry to find substitutes for mercurial biocides.  Cadmuim, lead, and
other heavy metals should appear mainly as insoluble pigments and should t
readily controllable as suspended solids.  Furthermore, the Lead-Based
Paint Poisoning Prevention Act of 1973 has forced the search for suitable
replacements for lead pigments and drying agents.  The quantities of
organic solvents that reach wastewater streams are very small.

Control Technology and Costs

          For solvent-based paint production, good housekeeping, with
control of spills and leaks, will allow all wastewater pollutants to be
collected in sumps, placed in drums, and periodically disposed of in a
landfill.  The base level of practice is already no discharge of process
waste liquids, so BPT, BAT, and NSPS can be achieved at no cost.
Negligible cost would be required to insure good housekeeping and prevent
leaks and spills from being discharged to surface waters.

          The added cost of achieving no discharge of water pollutants in
manufacturing oil-based paints is zero.  Most oil-based paints are produc
for trade sales, not industrial finishes.  Data extrapolated from a surve
conducted by the National Paint and Coatings Association (NPCA) shows tha
only 44 plants producing trade sales paints were discharging water
pollutants to surface water.  All other plants producing trade sales pain
were discharging wastewaters in some apparently approved manner and shoul
have no compliance costs for meeting EPA standards.  Of these 44
nonconforming plants, 22 were large, 10 medium, 6 small, and 6 very small

          For water-based paints, the control technology selected to
minimize costs is greatly affected by plant size.  Small plants, averagin
about 7,600 liters per day (2,000 gallons per day) of paint production, c
best achieve zero discharge by minimizing water use and recycling wash
waters through a packaged system for settling and sludge collection.
Larger plants, averaging about 19,000 liters per day (5,000 gallons per
day) production, would be better off installing a mechanical automatic
high-pressure spray-cleaning system with recycle.

          Based on the anticipated production of approximately 2,200
million liters (575 million gallons) of water-based paints in 1986, new
                                  W4.11-2

    -------
capacity above the 1972 level  will  be required to produce about 1,400
million liters (f370 million gallons) per year, or about 5.5 million liters
(1.1 million gallons per day).  This new production can be achieved with
240 new large plants, producing an  average of 23,000 liters (6,000 gallons)
of paint per day.  These new plants will be required to meet New Source
Performance Standards.

          Control costs based  on the above condition are summarized in
Table W4.11.1.
                                  W4.11-3

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    -------
                  Chapter W4.12  Printing Ink Formulating


Regulations

             New regulations were proposed in January of 1980 (45FR928) for
BPT, BAT, NSPS, PSES, and PSNS for this industry.  Subsequently, this
industry was excluded from Paragraph 8 under a settlement agreement.  These
proposed regulations and their impacts are not reflected in the text of
this chapter.  The costs shown here are based on documentation associated
with the regulations originally promulgated.

Industry Characteristics

             The ink manufacturing industry resembles the paint manufacturing
industry, although it is considerably smaller in size.  The industrial
sector described here is contained in SIC 2893 with captive shops appearing
in SIC 27.

             Printing ink production in the United States exceeds 450 thousand
metric tons (one billion pounds) per year.  The major components include
drying oils, resins, varnish, shellac, pigments, and many specialty
additives.

             The profile of the paint industry is applicable to inks also.
Many of the raw materials are the same and the methods of producing ink and
the equipment used are nearly identical to those for producing paint.
Milling is used more extensively in the ink industry as a method of
dispersing pigments.

             Printing inks can be either water- or oil-base.  Many of the raw
materials are the same regardless of the vehicle.  The waste
characteristics are similar to the paint counterpart.

             A check of the Refuse Act Permit Program applications and
consultation with industrial representatives led to the conclusion that
there are no ink manufacturing plants in the country discharging process
wastes to surface streams.

             Many of the plants that are on municipal systems practice no
discharge of wastewater pollutants.  Ink process wastewaters are either
sent to sanitary landfills for disposal or the wastewaters are recycled and
reused with the plant.  A limitation of "no discharge of process wastewater
pollutants" would have little, if any, effect on the industry.

Pollutants and Sources

             Oil-base ink discharges contain substances whose entry into most
municipal sewer systems or surface waters is prohibited.  Most cities have
waste ordinances which have attempted to deal with the release of these

                                  W4.12-1

    -------
substances.  Due to the highly volatile nature and the odor of these
materials, the source of any substances that do find their way into the
sewer system through accidental  spills could quickly be located.

             Water-base ink discharges would generally be classified as
acceptable to municipal treatment systems.  The possibility of solids
causing sewer maintenance problems depends on the pipe size and hydraulic
load in the sewer.  Some of the organic pigments have colors that are
highly persistent, and therefore they are not removed by existing treatmer
methods.

             The general practice of the ink formulating industry is to
discharge only to municipal sewers.  There are no known discharges of
process wastes directly to waterways.

Control Technology and Costs

             As ink formulators do not discharge wastes to water courses <
their wastes are generally considered to be compatible with municipal
treatment except for problems of brilliant colors and solids, few data an
available on the waste characteristics.  The practices of recycling
wastewater and water conservation can reduce the quantity of ink waste
discharged to the sewers.

             The significant parameters for measuring the pollution poten'
of ink wastes are BOD5, COD, pH, total suspended solids (TSS), heavy
metals, and color.

             As the ink manufacturing plants discharge only to municipal
systems, there is little sophistication in the treatment methods.  The
complexity of the treatment process is a function of the restrictions
applied by the municipality.  In areas where high surcharges are placed o
BOD and TSS, there is a trend toward strict water conservation, reuse, am
disposal of ink solids to landfills.

             Sedimentation is the most common treatment method employed d1
the high level of suspended solids in the wastewater.  Flocculation is al
used to increase the effectiveness of removing suspended solids.
Neutralization, principally of caustic cleaning solutions, is employed to
some degree.  The only wastewaters requiring control in the ink industry
are the wash and rinse solutions resulting from cleanup.

             A summary of the costs for the printing ink industry is show
Table VJ4.12.1.
                                  W4.12-2

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                     Chapter W4.13  Photograph Processing


Regulations

          The Photographic Processing industry comprises a single
subcategory for which only BPT level controls have been promulgated (41 CFR
29078, July 14, 1976).

Industry Characteristics

          The photographic processing subcategory of the photographic point
source category is defined to include all film processing activities listed
under SIC 7221 (Photographic Studios, Portrait), SIC 7395 (Photofinishing
Laboratories), and SIC  7819 (Developing and Printing of Commercial Motion
Picture Film).

          Of the estimated 12,500 processing plants in the United States
approximately 3,000 are amateur operations, 3,000 are "captive"
laboratories in business and industrial firms, 650 are major laboratories
specializing in work for professional and industrial photographers, and the
remaining plants are portrait and commercial studios.

          The photographic processing subcategory serves the photographic
trade, the military establishment, the scientific community, the medical
profession, the dental  profession, and the general public in the developing
of films and in photoprinting and enlarging.  Only 650 major laboratories
have significant wastewater discharges.  Approximately 5 percent of all
major photoprocessing plants are classified as existing point sources and,
therefore, are subject  to the
effluent limitations discussed here.  The remaining 95 percent of the
plants discharge their  wastewater to municipal treatment systems.

          Plant sizes range from small amateur operations to the major
laboratories which may  process as much as 9,000 square meters (100,000
square feet) of film and paper daily.  Many plants process between 2,000
and 5,000 square meters (between 25,000 and 50,000 square feet) per day.
These plants are located in urban areas throughout the country.

          The products  produced by the industry are primarily finished
color and black and white films and prints, produced in a wide variety of
photoprocessing machines used to finish a specific film or paper.  The
nature, basic principles and waste characteristics of the photographic
processing are the same in all facilities regardless of size and age.   The
quantity of waste per unit of production shows a consistent relationship.

Pollutants

          Parameters of major concern are BODc, COD, silver and cyanides in
various forms including complexes (ferrocyaniae and ferricyanide).

                                  W4.13-1

    -------
Control Technology

          After varying degrees of in-plant pollution abatement measures
which serve as a pretreatment step most photographic processing plants
discharge their effluents to municipal sewer systems.  Certain constituen
(i.e., silver and cyanide) which could exert toxic effect on a biological
system and various non-biodegradable material may also be present.
Therefore, in-plant measures or pretreatment to reduce the concentrations
of such contaminants to levels acceptable to local authorities must be
utilized.

          To avoid substantial economic injury to small business concerns
a size exemption for photographic processing plants handling less than 15
square meters (1,600 square feet) per day of film was established.
Implicit in the recommended guidelines for the photographic processing
subcategory of the photographic point source category is the use of
in-plant control  measures to reduce silver and cyanide.  In-plant
modifications will lead to reductions in wastewater flow, increasing the
quantity of water used for recycle, and improving the raw wastewater
quality.  In-plant treatment technologies should be utilized by the
photographic processing subcategory to achieve BPT effluent limitations a
guidelines.

          The selection of technology options depends on the economics of
that technology and the magnitude of the final effluent concentration.
Control and treatment technology may be divided into two major groupings:
in-plant pollution abatement and end-of-pipe treatment.  Applicable
technologies are outlined as follows:

          In-plant Pollution Abatement—Regeneration and Reuse

          •  Silver Recovery
            -Metallic Replacement
            -Electrolytic Recovery
            -Ion Exchange
            -Sulfide Precipitation

          0  Regeneration of Ferricyanide Bleach
            -Persulfate Regeneration
            -Ozone Regeneration

          •  Developer Recovery
            -Ion Exchange
            -Precipitation and Extraction

          •  Use of squeegees (to inhibit carry-over from one tank to the
             next)

          •  Use of Holding Tanks (for slow release rather than dumping)
                                  W4.13-2

    -------
End-of-PIpe Treatment

          •  Biological Treatment
             -Activated Sludge
             -Lagoons

          •  Physical/Chemical Treatment
             -Ozonation
             -Activated Carbon Adsorption
             -Chemical  Precipitation
             -Reverse Osmosis

Costing Methodology

          Capital investment and Operating and Maintenance cost functions
were taken from the Development Document, which gave estimated costs for
two plant sizes:  128.3 and 1283 thousand square meters per year
production.  Only 650 plants have significant wastewater flows, and 95
percent of these are on sewers.  Capital and O&M costs for BPT standards
for a 128.3 thousand square meters per year plant (5,000 square feet per
day) are $112,370 and $12,540 respectively (in 1979 dollars).  These BPT
costs represent the minimum-cost technology:  in-plant changes to achieve
control of silver and cyanide.

          Since BPT regulations were effective upon promulgation in July
1976, and called for BPT compliance for July 1, 1977, 100 percent
compliance was achieved in twelve months.  The Development Document points
out, however, that in reality, a great degree of treatment has been
practiced by industry for some time for economic reasons.

          This report assumes an industry growth corresponding to the
growth of GNP--approximately 4 percent.  This is a departure from previous
estimates, which assumed an 8.5 percent growth.

          A summary of costs for the treatment of photographic wastes
appears in Table W4.13.1.
                                  W4.13-3

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                       Chapter U4.14  Textile Mills
Regulations
          Regulations for the Textile Mills Point Source Category were
promulgated in July 1974 and covered BPT, BAT, NSPS, and pretreatment
standards for new sources (PSNS)(Ref. 1).  In January 1975, the BAT
regulations were challenged in the courts with the result that EPA was
required to reconsider BAT in light of technological and economic data
developed by the textile industry.  In May 1977, regulations were
promulgated for PSES and, two years later, proposed for BCT and revised
BAT.  These latter regulations were also proposed to supercede prior NSPS,
PSNS, and PSES.  In September 1982, regulations were promulgated to
supercede all existing regulations, except BPT.  These regulations, which
establish nine subcategories, set BAT limitations equal to the previously
promulgated BPT and based NSPS on the median performances of the best
biological treatment systems currently used to treat textile mill
wastewaters; the regulations do not establish categorical pretreatment
standards for existing or new source indirect dischargers.

Industry Characteristics

          The textile industry, which is classified in SIC Major Group 22,
Textile Mill Products, comprises establishments primarily engaged in
receiving and preparing fibers; transforming these materials into yarn and
web into fabric or related products; and finishing these materials at
various stages of the processing.  The entire industry includes
approximately 7000 mills and plants.  However, of this total less than 1500
are engaged in finishing (or scouring) which involves the generation of
process-related wastewater discharge.  These establishments are the point
sources to which the proposed regulations apply.  The subcategories of the
Textile Mills Point Source Category are listed below along with the numbers
of direct and indirect dischargers for each of the subcategories.
                                  W4.14-1

    -------
                               Number of             Number of
      Subcategory         Direct Dischargers   Indirect Dischargers   Tot;

Wool scouring                      6                     10             It
Wool finishing                     8                     26             3^
Low water use processing I/       69                    227            2St
Woven fabric finishing 2/         85                    243            321
Knit fabric finishing 3_/          46                    385            43'.
Carpeted finishing                11                     45             5(
Stock and yarn finishing          36                    178            21<
Nonwoven manufacturing             5                     26             3!
Felted fabric processing           1                     15             If
         Total                   267                   1155           142;

I/  Includes water jet weaving subdivision.
?/  Includes 3 subdivisions:  Simple processing, complex processing, and
    desizing.
3/  Includes 3 subdivisions:  Simple processing, complex processing, and
    hosiery products.

Most of the facilities in the nine subcategories are concentrated along t
Eastern Seaboard--80 percent are located in the Mid-Atlantic and Southern
regions while the remaining are distributed about equally between New
England and the North Central and Western  regions.  The mills and plants
New England are generally the older facilities in the industry while thos<
in the Southern states are, in most cases, its newer ones.

          The value of shipments for the textile industry have increased
from $31 billion in 1975 to over $56 billion in 1981 for an average annua
increase of over 10 percent.  The largest  increases occurred in the
mid-1970s.  Since 1977 the annual increases have been less than 10 percen
with a 9.2 percent change occurring between 1979-1980 and 3.7 between 198
through 1981.

Pollutants and Sources

          Many textile plants are integrated and perform dry, low water
use, and major wet-processing operations.  Principal dry operations inclu
spinning, tufting, knitting, and weaving.  Principal low water use
operations include slashing, web formation (nonwoven manufacturing only),
bonding, adhesive processing, coating, and functional finishing.  Major w
operations include scouring, carbonizing,  fulling, desizing, mercerizing,
bleaching, dyeing, and printing.  It is in these major wet operations tha
the major waste effluents are produced.  Table W4.14.1 lists those
pollutants generated by  the major wet operations in the textile industry.

          The most significant pollutants  and pollutant parameters in ter
of  occurrence and concentration include:
                                  W4.14-2

    -------
        Table W4.14.1.   Wastewater pollutants and their sources
                       for the textile industry \f .
       Process
        Wastewater Pollutants
1.  Raw Wool  Scouring
2.  Carbonizing
    Fulling
4.  Desizing
5.  Scouring
Significant quantities of natural oils,
fats, suint, and adventitious dirt.  Also
includes sulfur, phenolies, and other
organic compounds brought in with wool.

Residual sulfuric acid and neutralizing
agents (generally sodium carbonate).
Acid bath must be dumped when it becomes
too contaminated for efficient
carbonization.  Wastewater is high in
total solids.

The two common methods of fulling are
acid and alkali.  The wastewater from
acid fulling will contain sulfuric acid,
hydrogen peroxide, and small amounts of
metallic catalysts (chromium, copper, or
cobalt).  The wastewater from alkali
fulling will contain soap or detergent,
sodium carbonate, and sequestering agents
(phosphate compounds).

Desizing contributes a significant amount
of organic load, some oil and grease, and
most of the suspended material found in
woven fabric finishing wastewater.
Enzymatic removal generates starch
solids, fat, wax, enzymes, sodium
chloride and wetting agents.  Sulfuric
acid removal generates starch solids,
fat, wax, and sulfuric acid.

The nature of the scouring operation is
highly dependent on the fiber type thus,
the hydraulic and organic load of the
wastewater will  contain detergents,
wetting agents,  emulsifiers, alkali, and
ammonia.  Cotton and cotton-synthetic
fiber blend wastewaters will contain
significant quantities of oil and grease,
some suspended solids, sodium hydroxide,
phosphate, chelating agents, and wetting
agents.  Synthetic fibers wastewaters
will contain weak alkalis, anti-static
agents, lubricants, and soap or
detergents.
                                                            Continued.
                                  W4.14-3

    -------
                        Table W4.14.1 (Continued)
       Process
        Wastewater Pollutants
6.  Mercerizing
7.  Bleaching
8.  Dyeing
9.  Printing
Wastewater contains high levels of
dissolved solids and may have a pH of li
to 13.  Also may include small amounts <
foreign material and wax.

Primarily accomplished with hydrogen
peroxide.  Hydrogen peroxide bleaching
contributes very small waste loads, mos
of which are inorganic (sodium silicate
sodium hydroxide, and sodium phosphate)
and organic (surfactants and chelating
agents) dissolved solids.  Also include
a low level of suspended solids when
goods containing cotton are bleached.

Wastewater contains dyestuff and other
auxiliary chemical such as acids, bases
salts, wetting agents, retardants,
accelerators, detergents, oxidizing
agents, reducing agents, developers, an
stripping agents.  Color is an obvious
adverse pollutant and high levels of
dissolved solids are present.

Waste water constituents are similar to
dyeing although the volumes are much
lower and the concentrations greater.
The thickeners contribute to the BOD, a
solvents used to prepare pigments and
clean pigment equipment are often -
present.
II  Source:  Reference (6)
                                 W4.14-4

    -------
                      Chapter W5.   Metals Industries
          For the purpose of this report, the Metals Industries are defined
as those establishments which are primarily engaged in the mining,
refining, extracting, processing, fabricating or recovering of ferrous and
nonferrous metals, and processes performed by establishments in direct
support of these operations.  The industries included are:

             Ore Mining and Dressing Industries
             Iron and Steel
             Ferroalloys Industry
             Bauxite Refining Industry
             Primary Aluminum Smelting Industry
             Secondary Aluminum Smelting Industry
             Electroplating and Metal  Finishing Industry
             Coil Coating
             Porcelain Enameling

          Costs are associated with the implementation of the FWPCA for the
metals industries are summarized in Table W5.
                                   W5-1

    -------
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    -------
                   Chapter VI5.1  Ore Mining and Dressing
Regulations
          Regulations affecting this industry were revised under the
provisions of the NRDC Consent Decree.  In November 1982, EPA promulgated
BAT, NSPS, and minor amendments to the existing BPT regulations.  However,
revision of this chapter was limited to adjusting pollution control  costs
to 1981 dollars.  The effect of any changes in the regulations affecting
the ore mining and dressing industry is not reflected in the text of the
chapter or the cost estimates included in Table W5.1.1.  The cost estimates
represent the impact of the regulations as originally promulgated.

Industry Characteristics

          The Ore Mining and Dressing Industry category is defined as
including the mining, milling, and beneficiation of the following:

          1)  iron ore             7)  ferroalloys ore*
          2)  copper ore*          8)  uranium, radium, and vanadium ores
          3)  lead/zinc ore*       9)  titanium ore
          4)  gold ore*           10)  platinum ore*
          5)  silver ore*         11)  antimony ore*
          6)  bauxite ore         12)  mercury ore.

Regulations have been revoked for those subsectors marked with an asterisk.
Compliance costs for those subsectors were based on meeting the equivalent
of the revoked regulations.

          The production of ore in the U.S. is closely associated with the
rise and fall of the Gross National Product.  Many subsectors have a small
production rate in the U.S. due to competition with high grade foreign ores
(e.g., ferroalloys) or environmental concerns (e.g., mercury).  Gold and
silver prospecting activity has increased and, since gold and silver
are allowed to be sold on the open market now, mining activity may
increase.

          Iron Ore.  There are presently a total of 58 iron ore mining
operations (39 of these are major operations) in the United States that
mine about 200 million metric tons (200 million long tons) of crude iron
ore annually.  These operations are located in the states of Wyoming,
California, New York, Wisconsin, Alabama, Minnesota, Utah, Pennsylvania,
Michigan, Texas, Georgia, Missouri and Colorado.  Sixteen of these mines
are in Minnesota and five are in Michigan—these account for the major part
of the ore produced in the United States.

          Copper Ore.  Open pit mines produce 83 percent of the total
copper output with the remainder of U.S. production coming from underground


                                  W5.1-1

    -------
operations.   Ten percent of the mined material  is treated by dump (heap)
and in-situ  leaching.   Recovery of copper from leach solutions by iron
precipitation accounted for 87.5 percent of the leaching production;
recover of copper by electro-winning amounted to 12.5 percent.

          Lead and Zinc Ores.   Lead and zinc ores are produced almost
exclusively  from underground mines.  There are some deposits which are
amenable to  open pit operations; a number of mines during their early
stages operated as open-pit mines and then developed into underground
mines.  The  most common lead mineral mined in the U.S.  is galena (lead
sulfide).  This mineral is often associated with zinc,  silver, gold, and
iron minerals.  There are, however, numerous other minerals which contain
zinc.  The more common include sphalerite (zinc sulfide), zincite ("zinc
oxide), willernite (zinc silicate), and franklinite (an  iron, zinc,
manganese oxide complex).   Sphalerite is often found in association with
sulfides of  iron and lead.  Other elements often found  in association wit
sphalerite include copper, gold, silver, and cadmium.

          Silver Ore.   Current domestic production of new silver is deriv'
almost entirely from exploitation of low-grade and complex sulfide ores.
Only one-fourth of this production is derived from ores in which silver i:
the chief value and lead,  zinc, and/or copper are valuable byproducts.
About three-fourths of the production is from ores in which lead, zinc, a
copper constitute the principal values, and silver is a minor but importa
byproduct.  Free-milling--simple, easily liberated--gold/silver ores,
processed by amalgamation and cyanidation now contribute only 2 percent o
the domestic silver produced.

          Primary recovery of silver is largely from the mineral
tetrahedrite, (Cu, Fe, Zn, Ag^Sb^S,.,.  A tetrahedrite concentrate
contains approximately 25 to 32 percent copper in addition to the 25.72 t
44.58 kilograms per metric ton (750 to 1300 troy ounces per short ton) of
silver.  A low-grade (3.43 kg per metric ton or 100 troy oz. per short to
silver/pyrite concentrate is produced at one mill.  Antimony may comprise
up to 18 percent of the tetrahedrite concentrate and may not be extracted
prior to shipment to a smelter.

          Gold Ore.  The domestic production of gold had been on a downwa
trend for the last 20 years, largely as a result of the reduction in the
average grade of ore being mined and ore depletions at some mines.
However, large increases in the free market price of gold during recent
years has stimulated a widespread increase in prospecting and exploration
activity.

          In the United States, this industry is concentrated in eight
states:  Alaska, Montana, New Mexico, Arizona, Utah, Colorado, Nevada, an
South Dakota.

          Gold is mined from two types of deposits:  placer and lode, or
vein, deposits.  Placer mining consists of excavating gold-bearing gravel
and  sands.  This is currently done primarily by dredging but, in the past
included hydraulic mining and drift mining of buried placers too deep to


                                  W5.1-2

    -------
strip.  Lode deposits are mined by either underground or open-pit methods,
the particular method chosen depending on such factors as the size and
shape of the deposit, the ore grade, the physical and mineralogical
character of the ore and surrounding rock, and the depth of the deposit.

          Bauxite Ore.  Bauxite mining, for the eventual production of
metallurgical grade alumina, occurs in two operations near Bauxite,
Arkansas.  Both operations are associated with bauxite refineries, at which
purified alumina (Al^CU) is produced.   Characteristically, only a portion
of domestic bauxite Ts refined for use in metallurgical  smelting; one
operation reports that only about 10 percent of the alumina it mines is
smelted, while the remainder is destined for use as chemical  and refractory
grade alumina.  A gallium byproduct recovery operation occurs in
association with one bauxite mining and refining complex.

          Ferroalloy Ores.  The ferroalloy ore mining and milling category
embraces the mining and beneficiation  of ores of cobalt, chromium,
columbium (niobium) and tantalum, manganese, molybdenum, nickel, and
tungsten.  SIC 1061, although presently including few operations and
relatively small total production, covers a wide spectrum of  the mining and
milling industry as a whole.  Sulfide, oxide, silicate,  carbonate, and
anionic ores all are, or have been, mined for the included metals.
Open-pit and underground mines are currently being worked; placer deposits
have been mined in the past and are included in present  reserves.
Operations vary widely in scale, from  very small mines and mills
intermittently worked with total annual production measured in hundreds of
tons, to two of the largest mining and milling operations in  the nation.
Geographically, mines and mills in this category are widely scattered,
being found in the southeast, southwest, northwest, north central, and
Rocky Mountain regions.  These operate under a wide variety of climatic and
topographic conditions.  Historically, the ferroalloy mining  and milling
industry production has undergone sharp fluctuations in  response to
variations of the prices of foreign ores, government policies, and
production rates of other metals with  which some of the  ferroalloy metals
in the U.S. are found.  Ferroalloy ores in the U.S. are  usually of lower
grade (or more difficult to concentrate) than foreign ores and consequently
are only marginally recoverable or uneconomic at prevailing prices.  At
present, ferroalloy mining and milling (with the exception of molybdenum)
is being conducted at a very low level of production.  Increased
competition from foreign ores, the depletion of many of  the richer
deposits, and a shift in government policies from stockpiling materials to
selling concentrates from stockpiles has resulted in the closure of most
of the mines and mills that were active in the late 1950's.  For some of
the metals, there is little likelihood of further mining and  milling in the
foreseeable future; for others, increased production in  the next few years
is possible.

          Uranium Ores.  Uranium mining practice is conventional.  Special
precautions for the ventilation of underground mines reduce the exposure of
miners to radon, a shortlived gaseous  radioactive decay  product of radium
which can deposit daughter decay products in miners'  lungs.  Because of the
small size of pockets of high-grade ore, open-pit mines  are characterized


                                  W5.1-3

    -------
by extensive development activity.   At present, low-grade ore is being
stockpiled for future use.   Ore stockpiles on polyethylene sheets are
heap-leached at several  locations by percolation of dilute sulfuric acid
through the ore.   Because it is uneconomical  to transport low-grade urani
ores very far, -mines are closely associated with mills that yield a
concentrate (yellowcake) containing about 90 percent uranium oxide.  This
concentrate is shipped to plants that produce compounds of natural and
isotopically enriched uranium for the nuclear industry.

          Titanium Ores.  The principal  mineral sources of titanium are
ilmenite (FeTi02) and rutile (Ti02).  The United States is a major produc
of ilmenite but not of rutile.   Most of the U.S. mining of titanium ore
occurs in New York and Florida.

          Platinum Ores.  The geologic occurrence of the platinum-group
metals as lodes or placers  dictates that copper, nickel, gold, silver, ani
chromium will be either byproducts  or coproducts in the recovery of
platinum metals, and that platinum will  be largely a byproduct.   With the
exception of occurrences in the Stillwater Complex, Montana, and producti<
as a byproduct of copper smelting,  virtually all the known platinum-group
minerals in the United States come  from alluvial deposits in present or
ancient stream valleys, terraces, beaches, deltas, and glaciofluvial
outwash.  The other domestic source of platinum is as a byproduct of
refining copper from porphyry and other copper deposits and from lode and
placer gold deposits, although  the  grade is extremely low.

          Mercury and Antimony  Ores.  Mercury and antimony ore are
currently produced at two respective mines in the U.S.  Antimony product!
has fallen because of the state of the current market and availability of
foreign supplies.  Mercury production has increased due to the opening of
large mine in Nevada, currently the only significant mercury mining
operation in the U.S.

Pollutants and Sources

          Effluents are generally from two distinct sources:  mine
dewatering and ore-dressing operations (milling, washing, and separation
of ore).  The effluent from dressing operations is usually higher in
suspended solids.  Effluents from this industry are generally high in
suspended solids, dissolved metals  (depending on the solubility of the
specific ores), and small quantities of flotation and flocculation
reagents.  The suspended solids result from the opening of geological
structures to seepage and erosion,  and from the milling of the ore for
beneficiation.

Control Technology

          The wastewaters are generally discharged to a tailings or
settling pond in which the suspended solids are allowed to settle.  A
portion of the water is recycled if possible, and a portion discharged.
Raw tailings wastewater contains on.the order of 70,000 to 500,000 mg/1
suspended solids.  The settling rates of solids in tailing ponds vary.


                                  W5.1-4

    -------
Ninety-eight percent of the solids settle rapidly.  However, graillaceous
materials present in raw ore and fines produced in grinding operations
settle very slowly.

          The principal method of water effluent treatment consists of
settling ponds.  Almost all mines and beneficiation plants use settling
ponds and recycle water.  The wastewater currently discharged could be
treated by further retention to reduce the suspended solids content.  The
retention times in many of these pond systems, however, are not sufficient
to reduce the level  of suspended solids adequately, particularly during
periods of heavy surface run-off.  The basic differences between the
operation of present tailings systems and that proposed as BPT are the
increased retention time achieved by additional ponds, or clarifiers,
coagulation flocculation systems, and the use of lime neutralization.  Some
cases will require the destruction of cyanides and the selective
precipitation of specific metals.  Where settling ponds are not sufficient,
filters can be used to augment treatment.

Costing Methodology

          Table W5.1.1 contains a summary of BPT compliance costs for all
the above categories of ore mining, based on the models and costs
identified in the Guidelines Development Document for the 1975 Interim
Final Rulemaking.
                                  W5.1-5

    -------
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    -------
                       Chapter W5.2  Iron and Steel
Regulations
          Promulgated regulations have established effluent limitations
guidelines for best practicable technology (BPT) and best available
technology (BAT), performance standards for new sources (NSPS) and
pretreatment standards for new and existing sources (PSNS, PSES) for firms
in the iron and steel manufacturing point source category.  These final
regulations were published in the Federal  Register on May 27, 1982.  These
regulations contained specific guidelines and standards for twelve
subcategories of the iron and steel industry.  These subcategories are:

          A.  Cokemaking                   G.  Hot Forming
          B.  Sintering                    H.  Scale Removal
          C.  Ironmaking                   I.  Acid Pickling
          D.  Steelmaking                  J.  Cold Forming
          E.  Vacuum Degassing             K.  Alkaline Cleaning
          F.  Continuous Casting           L.  Hot Coating

Industry Characteristics

          The manufacture of steel involves many processes which require
large quantities of raw materials and other resources.   The iron and steel
production processes can be segregated into two major components:  basic
Steelmaking; and forming and finishing operations.

          In the first major process, coal is converted to coke which is
then combined with iron ore and limestone in a blast furnace  to produce
crude iron (pig iron or cast iron).  The crude iron is  then converted into
steel in either open hearth, basic oxygen or electric arc furnaces.
Finally, the steel can be further refined by vacuum degassing.

          Following the Steelmaking processes are the hot forming
(including continuous casting) and cold finishing operations.  Hot forming
primary mills reduce steel ingots to slabs or blooms and secondary hot
forming mills reduce slabs or blooms to billets, plates, shapes, strip, and
various other products.  Steel finishing operations involve a number of
other processes that do little to alter the dimensions  of the hot rolled
product, but which impart desirable surface or mechanical  properties.

          The steel industry is included within the United States
Department of Commerce, Bureau of Census Standard Industrial  Classification
(SIC) Major Group 33 - Primary Metal Industries.  The parts of the industry
covered by the regulations are the SIC subgroups - 3312, (except coil
coating), 3315, 3316, and 3317.  These include all processes, subprocesses
and alternate-processes involved in the manufacture of  intermediate or
finished products in the above categories.

                                  W5.2-1

    -------
          Steel  facilities range from comparatively small plants engaging
in one or more production processes to extremely large integrated complex
engaging in several  or all production processes.  Even the smallest steel
facility, however, represents a fairly large industrial  complex.  The
Agency estimates that there are about 680 plant locations containing over
2,000 individual steel making and forming and finishing operations.  The
1980 revenues of the United States steel  industry were about 72 billion
dollars and total employment was approximately 570,000 employees.  The
fifteen largest steel corporations provided approximately 87 percent of t
total annual U.S. steel ingot production.

          Domestic steel  shipments in 1981 were estimated to be about 87
million tons, an increase of 3.7 percent over the depressed level of 83.9
million tons in 1980, when the high interest rates that curbed demand in
major steel-consuming sectors, as well as the relative cost advantage of
foreign steel, kept shipments at low levels.  Because of uncertainty
surrounding future domestic steel shipments, the Economic Impact Report
derived two growth scenarios for domestic steel shipments and analyzed th
economic impacts of wastewater pollution control regulations under both
scenarios.  This chapter presents the costs associated with growth scenar
1 in which the industry is assumed to recover from the current recession
1982 and grow at an annual rate of 2 percent through 1990.

Pollutants and Sources

          Water is essential to the iron and steel industry and is used i
appreciable quantities in virtually all  process operations.  An average o
40,000 gallons of water is used in the production of every ton of finishe
steel, making the industry one of the highest water users of any
manufacturing industry.

          Total  process water usage in the steel industry is about 5,740
million gallons per day.   The untreated process wastewaters contain about
43,600 tons per year of toxic organic pollutants, 121,900 tons per year c
toxic inorganic pollutants and 14.5 million tons per year of conventional
and nonconventional  pollutants.

          The following wastewater pollutants have historically been
regulated in the steel industry.  Suspended solids, oil  and grease,
ammonia-N, cyanide,  phenols, fluoride, iron, total and hexavalent chromii
tin, lead, and zinc.  Other pollutants are found in the industry's
wastewaters; however, the Agency did not limit these pollutants in the
regulations because the technology for their removal is presently
considered beyond the scope of BPT and BAT for the industry.

Control Technologies

          Many different wastewater treatment technologies are currently
employed in the iron and steel industry.   Generally, primary wastewater
treatment encompasses physical/chemical  methods of treatment, including
neutralization, sedimentation, flocculation and filtration.  Treatment fc
toxic pollutants requires advanced technologies such as biological

                                  W5.2-2

    -------
treatment, carbon adsorption, ion exchange, reverse osmosis, and
sophisticated chemical techniques.

          Within the cokemaking subcategory, organic pollutant removal is
accomplished by biological treatment in bio-oxidation lagoons and activated
sludge plants; and, physical/chemical treatment in ammonia stills,
dephenolizers and activated carbon systems.  Sedimentation and filtration
are also used in this subcategory.

          Treatment facilities at plants in the sintering, ironmaking and
steelmaking subcategories rely heavily upon flocculation, sedimentation and
recycling of treated wastewaters.  Clarifiers and thickeners are
principally used in connection with polymers and coagulants such as lime,
alum, and ferric sulfate.

          Wastewaters from nearly all hot forming operations are treated in
scale pits followed by lagoons, clarifiers, filters, or combinations
thereof.   Polymers and coagulants such as lime, alum, and ferric sulfate
are normally used in conjunction with clarifiers.  The filters employed are
usually either gravity or pressure type with sand or other media.

          Treatment techniques at cold finishing operations include
equalization prior to further treatment; neutralization with lime, caustic
or acid;  flocculation with polymers; and, sedimentation.  Central or
combined treatment systems are common for these operations.

          Advanced control measures for the toxic pollutants include
two-stage (i.e. extended) biological treatment (cokemaking); granular
activated carbon; powdered carbon addition; pressure filtration; pressure
filtration accompanied with sulfide addition; and, multi-state
evaporation/condensation systems.

          A summary of the model treatment system by subcategory and a more
detailed description of the systems are presented in the appendix.

Costing Methodology

          The water pollution control compliance costs for the iron and
steel industry were obtained exogenously from the Economic Analysis Report.
The costs of compliance for the iron and steel  industry are presented in
Table W5.2.1.
                                  W5.2-3

    -------
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                                                                       W5.2-4

    -------
                     Chapter W5.3  Ferroalloy Industry
Regulations
          BAT regulations for the industry covered in this chapter are
currently under review by EPA.  It is anticipated that the review may
result in some change in the regulations, with subsequent effects on the
estimated cost of compliance.  Because of possible changes in the BAT
regulations following the review, this chapter has not been updated.  The
costs shown here are based on documentation associated with the regulations
as originally promulgated, and the costs for compliance with BAT are
subject to change if the BAT regulations are modified.

Industry Characteristics

          The ferroalloy industry produces most of its products through
electric-furnace smelting, exothermic refining, and electrolytic
processing.

          The products of electric-furnace smelting and/or exothermic
refining include such products as ferrosilicon, silicon metal,
ferromanganese, silicomanganese, ferromanganese-silicon, ferrochromium,
ferrochrome-silicon, calcium-silicon, ferrotitanium, ferrovanadium,
ferrocolumbium, and silicomanganese-zirconium.  The products of the
electrolytic process are primarily manganese, manganese dioxide, and
chromium.

          Since electric-furnace smelting is also the manufacturing process
for calcium carbide, and the largest producers of calcium carbide are
ferroalloy companies, calcium carbide is considered with the ferroalloy
industry (rather than the inorganic chemicals industry) for pollution .
abatement consideration.  The products of the ferroalloy industry are
classified in SIC 3313 (Electrometallurgical Products); calcium carbide
appears in SIC 2819 (Industrial  Inorganic chemicals, Not Elsewhere
Classified).

Pollutants and Sources

          For purposes of establishing water effluent limitation guidelines
and standards of performance, the industry has been divided into the
following categories:

          •  Ferroalloy Smelting and Refining Segment
             -Open Electric Furnaces with Wet Air Pollution Control
              Devices
             -Covered Furnaces and Other Smelting Operations with Wet Air
              Pollution Control  Devices
             -Slag Processing


                                  W5.3-1

    -------
          •  Calcium Carbide Segment
             -Covered Calcium Carbide Furnaces with Wet Air Pollution
              Control Devices
             -Other (i.e.,  Open)  Calcium Carbide Furnaces

          •  Electrolytic Segment
             -Electrolytic  Manganese
             -Electrolytic  Manganese Dioxide
             -Electrolytic  Chromium

          Most of the water usage by this industry is for noncontact
cooling purposes.  From 700 to 5000 gallons per minute (or 3,000 to 11,00(
gallons per megawatt-hour)  may be used to cool the furnace and components
of the electrical systems.   The largest source of water-borne pollutants •
the ferroalloy smelting and refining segment and the calcium carbide
segment is related to the use of  wet methods (e.g., wet scrubbers and
precipitators) to control air pollution.  Scrubbers are the principal wet
air pollution control device (APCD) presently used in the industry.
Scrubber water usage ranges from  about 500 to 3500 gallons per
megawatt-hour.

          The ferroalloy and calcium carbide segments are further divided
and categorized based upon  the furnace operation being of the open or
closed type.  In the open furnace operation, the carbon monoxide rich
off-gas is combusted at the top of the furnace mix and the burned gases
plus excess air are subsequently  ducted to the air pollution control
device.  In the closed-type operation, the furnace is covered to exclude
air from the furnace interior.  However, as the closed furnace gases to bi
cleaned are uncombusted, they contain components such as cyanide and
phenols, which are not found in appreciable amounts in the open-furnace
off-gases.  Additional water treatment is required for the effluent from
wet air pollution control devices (APCD) serving closed furnaces.

          Slag processing is an additional source of water pollution in
several of the ferroalloy plants.  As it represents an additional source
water pollution, slag processing  is introduced as a separate subcategory.
Thus, in the case of the ferroalloy and calcium carbide smelting and
refining segments, the preferred  categorization factor for water effluent
considerations is the type  of furnace equipment (i.e., open or closed
furnace, dry or wet APCD) and the auxiliary processing (i.e., slag
processing) utilized.

          The preferred basis for water effluent characterization and
treatment for the electrolytic segment of the industry is by product, i.e
manganese (Mn), manganese dioxide (MnO^) or chromium (Cr).

          It should be noted and  appreciated that many of the large
ferroalloy plants have concurrent in-plant operations which fall in sever
of the water effluent categories  and subcategories.  Thus, as proposed by
EPA, the water guidelines and performance standards may be applied to
specific plants on the basis of a "building block" or unit operation
approach, with the total plant effluent limitations based on the summatio


                                  W5.3-2

    -------
of each pollutant in each category.  The same approach is taken for costing
the required water treatment systems for a multi-operation plant.  As
expected, the costs associated with the treatment of a particular plant's
wastewater are best determined through detailed engineering and cost
analysis for the specific plant and operation.

Control Technology

          The water pollutants to be controlled for each segment are
presented in Table W5.3.1.  The achievement of BPT limitations for all
segments is based upon physical/chemical treatments, while BAT limitations
require physical/chemical treatment plus partial recycle of water.
               Table W5.3.1.  Ferroalloy industry pollutants
          Open electric
          air pollution
          devices
furnaces with
control
          Covered electric furnace
          and other smelting operations
          with wet air pollution
          control devices
          Slag processing
          Closed calcium carbide furnace
          Electrolytic manganese
TSS
Chromium total
Chromium VI
Manganese total

TSS
Chromium total
Chromium VI
Manganese total
Cyanide total
Phenols

TSS
Chromium total
Manganese total

TSS
Cyanide

TSS
Manganese
Chromium
NH3-N
Costing Methodology

          The estimates of water pollution control  costs reported here were
developed on the basis of a plant-by-plant review to determine the type of
air pollution control  device (wet or dry) in use, and the use of published
costs of water pollution control for some specific  plants.   Where published
data were not available, engineering estimates of costs based on cost
factors from Guidelines Development Documents were  applied.   The costs
listed in Table W5.3.2 are largely those of the portion of the industry
using wet air pollution control devices.
                                  W5.3-3

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                  Chapter W5.4  Bauxite Refining Industry
Regulations
          The regulations for BPT, BAT, and NSPS are essentially zero
discharge of process wastewaters to navigable waters (39 FR 12811, April 8,
1974).

          In addition there is a pretreatment standard for new bauxite
plants (40 CFR 421) which calls for the treatment of incompatible
pollutants except that if the publically owned treatment works is committed
to remove some percentage of any incompatible pollutant, then the bauxite
refinery may be less stringent in its treatment.

Industry Characteristics

          There are nine bauxite refineries in the United States; one of
the plants is located at St. Croix, Virgin Islands.  Modest capacity
increases are believed to be occurring by minor process changes that do not
in reality constitute a new source with respect to emission control. These
plants produce alumina from bauxite which is subsequently used in the
manufacture of aluminum.  Although the refineries are categorized as being
a part of the Miscellaneous Inorganic Chemicals Industry, Not Elsewhere
Classified (SIC 2819), they are integral with the Primary Aluminum
Industry.

Pollutants and Sources

          Major pollutants arising from a bauxite refinery are the
suspended solids and dissolved solids contained in the discharged waste in
"red mud" after the alumina values have been leached from bauxite.
Although other pollutants are produced, the relative magnitude of the
problems imposed are incidental.

Control Technology

          Total impoundment of the red mud and all other process
wastewaters was proposed by the regulations to achieve zero discharge of
all pollutants.  Liquids are recycled to the refineries while the red mud
solids settle in the impoundment areas.

Costing Methodology

          Empirical cost data based on the plant-by-plant analysis in the
Development Document were used in costing because several of the plants
were already impounding either their total flow or the red mud slurries
before the Act and, thus, a model plant combined with cost function
methodology was not appropriate.  All plants within the contiguous United


                                  W5.4-1

    -------
States were included in the costs.   Total  industry costs  (in  1973  dollars
for capital were 52.8 million and for annual  operating  were 5.64 million
per year.

          Costs are tabulated in 1981 dollars in Table  W5.4.1.
                                  W5.4-2

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    -------
             Chapter W5.5  Primary Aluminum Smelting Industry
Regulations
          Regulations affecting this industry were revised under the
provisions of the NRDC Consent Decree.  In January 1983, EPA proposed new
regulations for BAT, NSPS, BCT, and PSNS.  EPA did not propose a PSES
regulation because there are no indirect dischargers.  BPT was not revised.
However, revision of this chapter was limited to adjusting pollution
control  costs to 1981 dollars.  The effect of any changes in the
regulations affecting the primary aluminum smelting industry is not
reflected in the text of the chapter or the cost estimates included in
Table W5.5.1.  The cost estimates represent the impact of the regulations
as originally promulgated.

Industry Characteristics

          The primary aluminum industry has three production stages:
bauxite mining, bauxite refining to produce alumina (aluminum oxide), and
the reduction of alumina to produce aluminum metal; this last state is
commonly known as aluminum smelting.

          The reduction of alumina to produce aluminum metal is carried out
in electrolytic cells', or pots, that are connected in series to form a
potline.  The facility containing a number of potlines is referred to as
the potroom.  The electrolysis takes place in a molten bath composed
principally of cryolite? which is a double fluoride of sodium and aluminum.
Alumina is added to the bath periodically.  As electrolysis proceeds,
aluminum is deposited at the cathode, and oxygen is evolved at the carbon
anode.  The oxygen reacts with the carbon to produce a mixture of carbon
monoxide and carbon dioxide while the anode is consumed.

          Two methods of replacing the anodes are practiced; these are
referred to as the prebaked anode (intermittent replacement) and the
Soderberg anode (continuous replacement).  For either system, the anode
preparation begins in the anode paste plant, where petroleum coke and pitch
are hot-blended.  For prebaked anodes, the anode paste is pressed in molds,
and the anodes are baked.in the anode bake plant.  The baked anodes are
used to replace consumed anodes, and the anode butts are returned to the
anode preparation area.  In the Soderberg anode system, the anode paste is
not baked initially, but is fed continuously through a tubular steel sleeve
into the pot.  As the paste approaches the hot bath, the paste is baked in
place to form the anode.  Soderberg anodes are supported in the sleeves by
vertical or horizontal studs.

          The continuous evolution of gaseous reaction products from the
aluminum reduction cell yields a large volume of fumes that require
ventilation systems for removal from the potroom.  The ventilation air must


                                  W5.5-1

    -------
be scrubbed to minimize air pollution and both dry and wet scrubbing
methods are used for this purpose.  Water from wet scrubbers, used for ai
pollution control on potroom ventilation air, is the major source of
wastewater in the primary aluminum industry.

          The liquid aluminum produced is tapped periodically, and the
metal is cast in a separate cast-house facility.  The molten metal is
degassed before casting by bubbling chlorine or a mixed gas through the
melt.  The chlorine degassing procedure also produces a fume which must bi
scrubbed for air pollution control.

          A few aluminum smelters have metal fabrication facilities, such
as rod mills, rolling mills, etc., on the primary reduction plant site.
Since these metal fabrication operations will be covered under separate
effluent limitations, they are not covered by this report.

Pollutants and Sources

          As mentioned previously, the major source of wastewater in the
primary aluminum smelting industry is the water used in air pollution
control equipment (scrubbers) that are installed on potline and potroom
ventilation air systems.  Scrubbers are also used on anode bake furnace
flue gas, and on cast-house gases.  Other significant sources of wastewat
include:  cooling water used in casting, rectifiers, and fabrication;
boiler blowdown; and storage area run-off, especially water contaminated
with fluoride from spent cathodes.

          Significant pollutants from the primary aluminum smelting
industry for the purposes of establishing effluent limitations guidelines
are:  fluoride, total suspended solids, and pH.  Other wastewater
pollutants identifiable with the industry, but not considered significant
include:  oil and grease, cyanide, dissolved solids, chloride, sulfate,
chemical oxygen demand, temperature, and trace metals.

Control Technology

          BPT includes the treatment of wet scrubber water and other
fluoride-containing effluents to precipitate the fluoride, followed by
settling of the precipitate and recycling of the clarified liquor to the
wet  scrubbers.  A holding pond or lagoon might also be necessary to
minimize the discharge of suspended solids.  Precipitation methods
currently available use lime.  Alternate control technologies which can b
employed to achieve the required effluent levels include dry fume
scrubbing, total impoundment, and reuse of effluent water by a companion
operation.

          The application of the BPT described above results in a
relatively low-volume, high-concentration bleed stream from the recycling
system.  BAT is lime or calcium chloride precipitation treatment of the
bleed  stream to further reduce the discharge of fluorides.  Use of this
technology assumes that the volume of fluoride-containing effluent is
reduced to approximately 5,000 liters per metric ton (1,200 gallons per


                                  W5.5-2

    -------
short ton) of aluminum.  Alternatively, volumes as high as 50,000 liters
per metric ton (12,000 gallons per short ton) may be possible if the
effluent is treated by absorption methods (activated alumina or
hydroxyapatite).

          NSPS technology assumes the application of dry fume scrubbing
systems or, alternatively, wet scrubbing equipment together with total
impoundment or total recycling of the scrubber water.  The treatment for
fluoride and suspended solids removal is essentially the same as for BPT
above.  The NSPS  require the restriction of the discharge volume to 835
liters per metric ton (200 gallons per short ton) of aluminum with a final
fluoride concentration of 30 mg per liter; or an equivalent combination of
fluoride level and volume.  Alternatives for reducing water use and
pollutant levels  include air-cooled, solid state rectifiers; non-chemical
methods of molten metal degassing; and careful cleaning of the anode butts
before recycling.

          Approximately two-thirds of the primary aluminum smelting plants
in the United States are currently operating with discharge levels of
pollutants within the July 1977 guidelines.

Costing Methodology

          Nationwide costs of the primary aluminum smelting industry were
estimated from model plant costs and are summarized in Table W5.5.1.  Model
plant numbers and sizes, compliance costs and other data were taken from
the Development Document.  No costs are indicated for new sources as new
plants are using  the dry gas-scrubbing process which uses no water in the
control of pollutants.
                                  W5.5-3

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    -------
            Chapter W5.6  Secondary Aluminum Smelting Industry
Regulations
          Regulations affecting this industry were revised under the
provisions of the NRDC Consent Decree.  In January 1983, EPA proposed new
regulations for BAT, NSPS, PSES, and PSNS.  BPT was not revised.  However,
revision of this chapter was limited to adjusting pollution control costs
to 1981 dollars.  The effect of any changes in the regulations affecting
the secondary aluminum smelting industry is not reflected in the text of
the chapter or the cost estimates included in Table W5.6.1.  The cost
estimates represent the impact of the regulations as originally
promulgated.

Industry Characteristics

          The secondary aluminum industry comprises an estimated 54 firms
with 66 plants.  Other sources list the industry as having more plants, but
these numbers include sweaters, scrap dealers, and non-integrated
fabricators.  For purposes of this report, the number of plants reported
excludes these portions of the industry as they do not employ any of the
processes included in the effluent limitations guidelines.

          The secondary aluminum smelting industry is a subcategory of the
aluminum segment of the nonferrous metals manufacturing category.  This
subcategory recovers, processes, and remelts various grades of
aluminum-bearing scrap to produce metallic aluminum or an aluminum alloy as
a product.  This product is used primarily to supply the following
industries:  construction, aircraft, automotive, electrical equipment,
beverage cans, and fabricated metal products (which includes a wide variety
of home consumer products).  The largest user of secondary aluminum ingot
is the automotive industry.

          Secondary aluminum ingot is produced to specifications; melting
to specification is achieved mainly by segregating the incoming scrap into
alloy types.  The magnesium contained in the scrap is removed, as desired,
by a chlorine-gas treatment (demagging) in a reverberatory furnace.

Pollutants and Sources

          Wastewaters are generated by the following processes:  (1) ingot
cooling and shot quenching, (2) scrubbing of furnace fumes during
demagging, and (3) wet milling of residues or residue fractions.

          The following are the primary wastewater pollutants discharged by
the above processes:  oil and grease, suspended and dissolved solids, and
salts of aluminum and magnesium.
                                  W5.6-1

    -------
          In metal cooling, molten metal in the furnace is usually either
cast into ingot or smaller (sow) molds or is quenched into shot.  Ingot
molds are sprayed while on conveyor belts to solidify the aluminum and
allow its ejection from the mold.  Shot is solidified by having metal
droplets fall into a water bath.  The wastewater generated is either
vaporized, discharged to municipal sewerage or navigable waters, recycled
for some period and discharged (6-month intervals), continuously recycled
with no discharge, or discharged to holding ponds.

          Fume scrubbing is necessitated when aluminum scrap contains a
higher percentage of magnesium than is desired for the alloy produced.
Magnesium removal, or "demagging", is done either by passing chlorine
through the melt (chlorination) or with aluminum fluoride.  When magnesiu
is extracted, heavy fuming results; this requires passing the fumes throu
a wet scrubbing system.  Water used in scrubbing picks up pollutants,
primarily in the scrubbing of chlorine demagging fumes.

          Residue processing takes place in the industry since residues a
composed of 10 to 30 percent aluminum, with attached aluminum oxide fluxi
salts (mostly NaCl and KC1), dirt, and various other chlorides, fluorides
and oxides.  The metal is separated from the non-metals by milling and
screening (which is performed either wet or dry).  In wet milling, the du
problem is minimized but the resulting waste stream is similar in make-up
to scrubber waters but more concentrated in dissolved solids.

          Pollutant parameters for wastewater from wet milling of residue
include total suspended solids, fluorides, ammonia, aluminum, copper, COC
and pH.  Pollutant parameters for wastewater from fume scrubbing include
total suspended solids, COD, and pH.

Control Technology

          Approximately 10 percent of the industry is currently dischargi
directly to navigable waters.  The majority of the industry discharges
effluents to municipal treatment works, usually with some pretreatment.

          Currently, some plants are utilizing various control alternativ
for each of the three major wastewater sources.  The control technologies
required to meet BPT and BAT are as follows:

          BPT.  Metal Cooling.  Air cooling or continuous recycling of
cooling water with periodic removal, dewatering, and disposal of sludge.

          Fume Scrubbing.  Chlorine Fume Scrubbing (for magnesium removal
using chlorine):  pH adjustment and settling.  Fluoride fume scrubbing (f
magnesium removal using aluminum fluorides):  pH adjustment, settling, ar
total recycling.

          Residue Milling.  Adjustment of pH with settling and water
recycle.
                                  W5.6-2

    -------
          BAT.   Metal  Cooling.   Air cooling, water cooling (for complete
evaporation),  and total  use and recycle of cooling water by use of settling
and sludge dewatering.

          Fume Scrubbing.  Use of aluminum fluoride for magnesium removal,
and entrapment of fumes  without major use of water, using alternatives such
as the Alcoa process,  Derham process or the Tesisorb process.

          Residue Milling.  Dry milling, and a water recycle evaporation
and salt reclamation process.

Costing Methodology

          The  costs for  compliance were developed on the basis of the plant
numbers, sizes, processes, air pollution control  status, and treatment and
discharge status as given in the Development and  Economic Analysis
Documents published in 1974.  Three cost sectors  were modeled:  one for
each of the three operations generating wastewaters; the models thus
reflect the population of these unit operations rather than the total
number of plants.  The aggregate costs of compliance developed on this
basis are given in Table W5.6.1.
                                  W5.6-3

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                                                               W5.6-4

    -------
         Chapter W5.7 Electroplating and Metal Finishing Industry
Regulations

          The regulations analyzed in this chapter are based on the final
rule amendments promulgated on January 28, 1981 and new proposed
regulations on August 31, 1982, specifying pretreatment standards for
existing sources (PSES) of the Electroplating Point Source Category and
BPT, BAT, NSPS, PSES, and PSNS for the Metal  Finishing Point Source
Category.  The effluent limitations guidelines for BPT for the
electroplating industry were suspended indefinitely on December 3, 1976 and
were then revoked on January 28, 1981.  In addition, the effluent
limitations guidelines for BAT, new source performance standards (NSPS) and
pretreatment standards for new sources (PSNS) for the industry were revoked
on December 3, 1976.

          Under the regulations which were proposed on August 31, 1982, the
PSES guidelines which were promulgated January 28, 1981, will apply to all
indirect discharging electroplaters.  All  electroplating facilities, other
than indirect discharging, job shops and independent printed circuit-board
manufacturing, will subsequently be subject to the regulations for Metal
Finishing point source category and will  comply with regulations proposed
for this category.

Industry Characteristics

          The Electroplating and Metal Finishing Categories consist of
13,000 plants.  These establishments apply surface treatments by
electrolytic deposition and other methods.  The treatments provide
corrosion protection, wear or erosion resistance, antifrictional
characteristics, lubricity, electrical conductivity, heat and light
reflectivity, or other special surface characteristics,

          In the economic impact analyses, the universe of electroplating
and metal finishing firms was defined in  terms of the following three
production sectors:

          •  Job shops — Independent operations performing the metal
             finishing processes covered  by the regulations as their
             primary line of business.

          •  Printed board manufacturers — Independent producers of wire or
             circuit boards whose products involve copper and electroless
             plating.
Captive shops— Production centers, found within manufacturing
firms, that provide finishing services to the products of the
          •

             parent company
The number of plants by category are presented in Table 5.7.1.
                                  W5.7-1

    -------
                               Table W5.7.1
Job shops and IPCBM* (3470)            Nonintegrated            Integrate*


Indirect dischargers
   (10,561):
   3061                                3,750                    3,570
   Job & IPCBM                         Nonintegrated            Integrate'
   Indirect                            Captive                  Captive

Direct Dischargers
   (2,909):
   409                                 2,500
   Job & IPCMB                         Captive
   Directs                             Directs


*Independent Printed Circuit Board Manufacturers.
                               W5.7-2

    -------
          Independent job shops are classified in SIC 3471 (Plating and
Polishing) and 3479 (Metal Coating and Allied Services, n.e.c.)«  Firms in
SIC 3471 are major consumers of common plating metals (i.e., copper, zinc,
nickel, chromium) whereas firms in SIC 3479 are distinguished by their
technical  production processes (anodizing, phosphating, precious metal
plating, etching, etc.).  Output charges in real  constant dollars (1982)
increased to $3.2 billion in 1979 from $2.16 billion in 1972 for a growth
rate of 5.8 percent per year.

          Printed board manufacturers, which are classified in SIC 3679
(electronic components, n.e.c.) had a value of $1.5 billion in 1980.  A
growth rate of 20 percent per year was assumed based on projected, trends of
the U.S. semiconductor industry.

          Captive operations are classified in SIC 34 through 39.  Average
plant sales of metal finished goods was approximately $10.9 million in 1976
according to the most relevant information sources.  Total industry sales
are approximately $109 billion, of which $11 billion or 10 percent of sales
account for the total value added by metal finishing.  Annual growth in the
industry is expected to amount to 3 percent per year.

Pollutants and Sources

          Wastewater from this industry comes from pretreatment and post-
treatment operations as well as the actual metal  finishing and
electroplating steps.  Table W5.7.2 lists the major types of wastes
generated by these operations.  The known significant pollutants and
pollutant properties from these operations include pH,  total  suspended
solids, cyanide, chromium, copper, nickel, zinc,  cadmium, lead, alumin^,,,,
and various precious metals and organic compounds.  The present EPA study
indicates that many of these pollutants may occur together and that their
individual concentrations may exceed 100 mg/1.

          Wastewater results from the following operations in this
industry:   rinsing to remove films of processing solution from the surface
of work pieces at the site of each operation; rinsing away spills;
scrubbing ventilation exhaust air; dumping of spent solutions; washing of
equipment; and discharging cooling water used in heat exchangers to cool
solutions in metal finishing processes.

          Approximately 90 percent of the water consumed is in rinsing.
That used as cooling water is usually recycled for rinsing.

          Many of the pollutants which are generated are toxic pollutants
which have potential for environmental or POTW damage.   Therefore, the most
important pollutants associated with the electroplating industry which are
controlled by PSES regulations are:

          1. Toxic pollutants—cyanide, lead, cadmium,  copper, nickel,
             chromium, zinc, silver, and toxic organics (lumped together as
             total-toxic organics); and
                                  W5.7-3
num,

    -------
  Table W5.7.2.   Major wastes and their sources generated by the electroplating and metal finishing industr
              Waste
                                                                           source
Proprietary solutions
Catalysis and accelerators
Concentration acid and pickling
waste
Strong acid rinse waters
Concentrated alkalies
Cvanide concentrates
Chromates
These are mainly cleaners or plating process accelerators
of various types of which the chemical composition is
proprietary.

In electroless plating on plastics, a catalyst must be
applied to the plastic to initiate the plating process.
The catalyst consists of tin and palladium, and in the
acceleration process the tin is removed.  A chromic acid
surface preparation of the plastic usually precedes the
catalyst application.

Originate primarily from stripping and cleaning of metal.
Usually contain one or more of the following: hydrochloric
acid (most common), sulfuric acid, nitric acid, chromic acid,
fluoroboric acid, and pnospnoric acid.  The solution composit
vary according to the nature of the base metals and the type
of tarnish or scale to be removed.  These acid solutions
accumulate appreciable amounts of metal  as a result of dis-
solution of metal from worx pieces or uncoateo areas of platii
racks that are recycled repeatedly through cleaning, acid
treating, and electroplating baths.  As a result, the baths
usually have a relatively short life, and when they are dumpe1
and replaced, large amounts of chemicals must be treated or
reclaimed.  These chemicals also enter the waste stream by
way of dragout from the acid solutions into rinse waters.

From rinsing after acid dips, pickling solutions, and strong
acid process solutions.

Cleaning solutions usually contain one or more of the followi
chemicals: sodium hydroxide, sodium carbonate, sodium meta-2
silicate, sodium phosphate (di- or trisodium), sodium silicat
sodium tetra phosphate, and a wetting agent.  The specific
content of cleaners varies with the type of soil being remove
For example, compositions for cleaning steel are more alkalin
and active than those for cleaning brass, zinc die castings,
and aluminum.  Waste waters from cleaning operations contain
not only the chemicals found in the alkaline cleaners but als
soaps from the sapomfication of greases left on the surface
polishing and buffing operations.  Some oils and greases
are not saponified but are, nevertheless, emulsified.  The
raw wastes from cleaning process solutions and dissolution
of basis metals show up m the rinse waters, spills, dumps
of concentrated solutions, wash waters from air-exnaust ducts
and leaking heating or cooling coils ana heat exchangers.
The concentrations of dissolved basis meta! in rinses follow-
ing alkaline cleaning are usually small  relative to acid aip
rinses.

Includes cyanide plating solutions ana cyanide plated or dipp
metal parts.

Originate from both plating and rinsing of metals that have
been treated with chromate solutions.
 (Ref.  1, 8).
                                                    W5.7-4

    -------
          2. Conventional pollutants—TSS and pH.  (Note: These pollutant
             parameters are optional.)
Control Technologies
          The two general approaches to removing or recovering wastewater
pollutants generated by plating, metal  finishing, and printed board
manufacturing processes are in-plant technologies and end-of-pipe treatment
technologies.
          The intent of in-plant technology for the overall Electroplating
and Metal Finishing Point Source Category is to reduce or eliminate the
waste load requiring end-of-pipe treatment and, thereby, improve the
efficiency of waste treatment.  In-plant technology involves the selection
of rinse techniques, plating bath conservation, good housekeeping
practices, recovery and/or reuse of plating and etch solutions, and process
modification.

          For metal finishers, precipitation and clarification of effluents
has been proposed for compliance with BPT.  In addition, for cyanide or
hexavalent chromium the technology basis incorporates techniques to destroy
cyanide and reduce hexavalent chromium to trivalent chromium.  This
technology is the same as that promulgated for PSES for electroplaters.
BAT for metal finishers is proposed as the same as BPT limitations for
metal finishers.  PSES is also the same as BPT.

          BPT plus in-plant control of cademium is proposed for NSPS.  PSNS
is proposed as equivalent to NSPS.

Costing Methodology

          Water pollution control costs for compliance with PSES
electroplating industry and BPT/BAT and PSNS/PSES for the metal finishing
industry were obtained exogenously from the August 31, 1982 Federal
Register.  Capital cost estimates are based on the total cost of equipment
that EPA estimates will enable a discharger to meet the regulations.  The
O&M costs were estimated by subtracting the estimated capital recovery
costs from the annual costs presented in the Federal Register where all
costs were expressed in 1982 dollars.

          Estimated abatement costs are summarized in 1981 dollars in Table
W5.7.3.
                                  W5.7-5

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    -------
                        Chapter U5.8  Coll Coating
Regulations
          The coil coating industry, which coats large rolls or "coils" of
flat metal with various types of organic polymer coatings and laminates to
give the metal decorative or protective qualities, has not beerr included in
previous Cost of Clean reports.  The regulations proposed for this industry
establish effluent limitations guidelines for BPT and BAT, pretreatment
standards for new and existing sources (PSES, PSNS) and performance
standards for new sources (NSPS) (Ref. 2).  The proposed regulations do not
require the installation of any particular treatment technology.  Rather,
they require achievement of effluent limitations through the proper
operation of demonstrated control  technologies or through control
technologies that achieve an equivalent reduction.

Industry Characteristics

          EPA developed two sets of subcategories for the coil  coating
industry.  The first set which was devised for promulgating regulations was
based upon the type of metal coated (i.e., aluminum, cold and rolled steel,
and galvanized steel),  since most plants in the industry are capable of
coating more than one type of metal, the first subcategorization scheme was
inappropriate for estimating the economic impacts of the proposed
regulations.  Therefore, EPA developed a second subcategorization scheme
which was used in the Economic Impact Report and this chapter,  and was
reflective of the three operational modes of coil coating plants:

          •  Toll Coaters, which coat customer-owned metal (generally do
             not perform metal fabricating operations),

          •  Captive Operations, which are part of a proprietary product
             manufacturing process (e.g., building products, food container
             packaging),

          •  Adjustment Operations, which are performed in plants  with
             rolling mills on the plant site (the metal is coated as part
             of the customers' orders).

          In 1976, the coil coating industry consisted of seventy plants
which produced a total of 11.4 billion square feet of coil coating.  The
number of captive operations was slightly larger than the number of adjunct
operations (26 versus 23), although the annual production volume of the
captives was less than one-half that of the adjunct operations  (19 percent
versus 46 percent).  Toll coaters, on the other hand, account for
approximately 30 percent of the plants (21) and a comparable 35 percent of
annual production.  On an average plant size basis, the square  footage of
production for adjunct operations was slightly larger than that of the toll
coaters and almost three times greater than that of captive operations.
                                  W5.8-1

    -------
          Over 70 percent of the captive plants had annual  production
volumes of less than 100 million square feet, whereas over 65 percent of
the adjunct plants and toll  coater plants had annual  production volumes
greater than 100 million square feet.   This disparity in size is explainec
by the nature of the captive operations, which operate as a part of a tot<
product manufacturing process and thus are limited by the end-product
production requirements, as  opposed to that of toll coaters and adjunct
operations which produce coil coated metals as a primary product.

          The coil coating industry which is classified in SIC 3479, has
enjoyed a healthy growth rate in the past fifteen years.  It experienced <
30 percent growth rate from  1976-79 and is projected to grow through 1985
at the rate of 12 percent.  Rapid technological change and product
improvement should continue  to contribute to industry growth.

Pollutants and Sources

          Wastewaters are generated in the cleaning, chemical conversion
coating, and finishing processes of the coil coating industry.  Strong
alkaline, mild alkaline and/or acid is used to remove soil, corrosion,
dirt, and oxides that interfere with the conversion coating of the metal
strip.  Water is used to rinse the strip after it has been cleaned.
Conversion coating employs one of the following types of coating material;
phosphate, chromate, complex oxides, or no-rinse.  Most of these conversi
coating processes are water  based and water is used to rinse spent and
excess solutions from the strip.  In painting, the final process of the
coil coating operation, water is used to quench the strip after oven curi
the paint.  This prevents the development of internal and external
stresses.

          The exact composition of the wastewater generated will vary
depending on the options selected for cleaning and for chemical conversio
coating, and the type of base metal coated.  The most important pollutant:
or pollutant parameters as recognized by EPA are:

          •  toxic pollutants—chromium, zinc, nickel, lead, copper, and
             cyanide;

          •  conventional pollutants—suspended solids, oil and grease, a
             pH; and

          •  unconventional  pollutants — iron, aluminum, phosphorus, and
             fluoride.

EPA did not find significant quantities of toxic organic pollutants in th>
wastewater.

Control Technologies

          The control technologies that EPA recommended to meet the
proposed effluent limitation guidelines for BPT, BAT, PSES, NSPS, and PSN
are as follows:

                                  W5.8-2

    -------
          •  BPT—The recommended end-of-pipe treatments as to meet BPT
             are:  reducing hexavalent chromium, skimming oil, adjusting
             pH, allowing sedimentation to remove the resultant precipitate
             and other suspended solids, destroying cyanide where used, and
             dewatering sludge from the settling tank to facilitate
             landfill disposal.

          •  BAT and PSES—Control technologies for BAT and PSES build on
             the technologies established for BPT by adding a mixed-media
             filter, to reduce process wastewater generation, and by
             recycling quench water.

          •  NSPS and PSNS—The recommended technologies for NSPS and PSNS
             build on the technologies established for BAT and PSES.  They
             further reduce the generation of process wastewater by
             employing countercurrent rinse modes and no-rinse conversion
             coating.

          Table W5.8.1 illustrates the effectiveness of these technologies
by showing the percentage of the various pollutants removed from the raw
waste load.

Costing Methodology

          The costs for compliance were based on information from the 1981
Development Document and 1980 Economic Impact Report (Ref.  3 and 4)
concerning the production process, the number, size, and discharge status
of the plants, and the recommended treatment technologies.   As mentioned
earlier, these cost estimates were based on information concerning the
costs of control for toll coaters, captive operations, and adjunct
operations.

          The total costs of compliance were estimated for each level  of
treatment for each of the three plant types.  Compliance costs for BPT,
BAT, and PSES were projected exogenously, while compliance costs for NSPS
and PSNS were projected by using cost estimation equations relating costs
to production.  These equations were based on model plant data presented in
the Development Document (Ref. 3).

          Technologies costed for BAT and PSES do not reflect the change
EPA made in its proposal.  EPA modified the subcategory "BAT 2/Pre 3"  (as
presented in the 1981 Development Document (Ref. 3)) to include
countercurrent rinse and no-rinse conversion.  EPA estimated in the Federal
Register that this modification could reduce the total BPT and BAT
investment by 20-25 percent.

          The underlying assumptions for this analysis are that replacement
capital costs are 90 percent of the original capital investment, O&M costs
for the replacement equipment are the same as those for the original
equipment, and equipment is replaced after 15 years.
                                  W5.8-3

    -------
               Table W5.8.1  Percent of pollutant removed I/
    Parameter                            BPT                 NSPS and PSN
Toxic Pollutants
Chromium
Zinc
Nickel
Lead
Copper
Cyanide
Conventional Pollutants
Suspended solids
Oil and grease
Unconventional Pollutants
Iron
Aluminum
Phosphorus

98.7
96.9
0
84.5
0
79.0

91.2
93.1

89.3
99.8
80.2

99.9
99.4
75.2
94.3
0
93.9

99.2
97.5

96.6
99.9
95.0
_!/  These values were calculated using Table X-ll in the Development
    Document (Ref. 3).

Note:  The percentage of pollutants removed under the BAT and PSES
       treatment levels would be approximately the same as those found
       under the NSPS and PSNS treatment levels.
                                  W5.8-4

    -------
          The costs of compliance for the coil coating industry are
presented in Table W5.8.2.  These costs are based on a 1976 survey data of
58 plants in the coil coating industry.  They have been extrapolated to the
then existing industry total of 70 plants, to plants that have begun
operations since 1976, and to expected new plants.
                                  W5.8-5

    -------
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    -------
                     Chapter W5.9  Porcelain Enameling
Regulations
          The regulatory bases for this chapter are the regulations, as
promulgated by EPA on November 24, 1982, that limit the effluent discharges
to waters of the United States and introductions of pollutants into
publicly owned treatment works (POTWS) from facilities engaged in porcelain
enameling.  The purpose of the regulations is to specify effluent
limitations for best practicable technology (BPT),  best available
technology (BAT), new source performance standards  (NSPS)  for direct
dischargers and to establish pretreatment standards for indirect
dischargers.

          The regulations specify the effluent limitations guidelines,
performance standards and pretreatment standards for each  of the material
basis subcategories defined as:   (1)  steel, (2) cast iron, (3) aluminum,
and (4) copper.

Industry Characteristics

          Porcelain enameling is a metal finishing  process that consists  of
the application of a glass coating (frit) to steel, cast iron, aluminum,
strip steel or copper.   The purpose of the coating  is to improve the
metals' resistance to chemical abrasion and corrosion, and to improve
thermal stability, electrical insulation and appearance.  The major end
uses for porcelain enameling products are the major home appliances (which
account for approximately 80 percent of porcelain enamel usage); sanitary
ware (which accounts for approximately 10 percent of total usage); and
other products such as  cookware, architectural panels, and barbecues.

          EPA chose the base metal treated as the basis to subcategorize
the industry in the technical analysis and regulations, since the
pollutants generated in the surface preparation of  the metal  vary by the
type of metal enameled.  While this scheme is appropriate  from a technical
standpoint, the economic and financial impacts of the regulations vary  with
the type of product enameled, because product market strength, pricing
latitude and the ability of manufacturers to substitute alternate materials
for porcelain enameling vary by  end product.   Consequently,  in the
Economic Impact Report  the base  metal subcategories were subdivided into
the major end product groups.  The major end product groups and the number
of plants represented by each group are as follows:
(1) ranges--27, (2) home laundry—9,  (3) dishwashers—4, (4)  hot water
heaters—10, (5) sanitary ware—9, (6) cookware—11, (7) architectural
panels —11, (8) job shops—23, and (9) miscellaneous (refrigerators,
barbecues, etc.)—12.
                                  W5.9-1

    -------
          Company organization within the industry can be defined by two
basic types—captive operations which are located within an integrated
manufacturing facility and independent job shops.  Job shops are plants tf
perform porcelain enameling on a contract basis and produce a wide range c
items.  These shops represent approximately 20 percent of the plants but
only about 5-3 percent of the production in the industry.  The job shops
were defined as a separate end product group because they could not be
classified in any other end product group.

          Of the 116 porcelain enamel plants identified by EPA, sufficien-
data to conduct economic impact analyses were available from 106 plants.
Consequently, the economic impact analyses were conducted on these 106
sample plants and projected for the 116 known plants in the industry.

          In 1976, the annual production rates of the 108 plants ranged
from 25,000 square feet (of exposed surface area enameled) for a small jot
shop to 62,190,000 square feet (of exposed surface area) for an integratec
appliance manufacturer.  All  total, the industry enameled 775,000,000
square feet of exposed metal  surface area.

          Growth in the porcelain enamel industry is highly dependent on
trends in porcelain enamel usage and the demand for porcelain enameled enc
products.  The future of porcelain enamel usage depends on whether the
substitutions that took place in the last ten to twenty years substantial'
represent all of the technically feasible and economically viable
substitutes.  Current trends indicate a continued, though decelerated,
decline in the usage of porcelain enamel finishes.  On the other hand,
porcelain enameled major home appliance demand is highly correlated with
new housing starts.  Consequently, utilization in the industry will a!way:
be cyclical, and industry growth will depend on the long-term trends in tl
general economy.  Over the 1982 to 1987 period, growth of household
appliances that contain porcelain enamel is expected to range from 3 to 7
percent annually.  This compares to 4.2 percent from total durable
manufactures.

          The-plants in the porcelain enamel industry are classified in t
SIC Codes 3431 (enameled iron and metal sanitary ware), 3469 (porcelain
enameled products except plumbing supplies), 3631 (household cooking
equipment), 3632 (household refrigerators and home and farm freezers), 36;
(household laundry equipment), and 3639 (household appliances, not
elsewhere classified).  Included among these areas are the large appliana
cookware, architectural panel, and plumbingware industries.

Pollutants and Sources

          Wastewaters are generated in the surface preparation and coatim
processes of the porcelain enameling industry.  In the surface preparatio
process, water-based alkaline cleaners are used to remove oil and dirt.
Acid pickling solutions are used to remove corrosion, oxides, and to etch
the base metal to be coated, and water is used to rinse spent and excess
solutions from the prepared surfaces.


                                  W5.9-2

    -------
          The coating process includes the ball milling of the frit and the
enamel application.  Water is used in the ball milling operation for
flushing the mills between mixing batches and for cooling the mills during
operation.  The enamel application operation may employ water as a curtain
device for entrapping waste coating materials from over spray.

          The exact composition of the wastewater generated will vary
depending on the process options selected for cleaning and the type of base
metal coated.  The most important pollutants or pollutant parameters as
recognized by EPA are:

          •  Toxic metal pollutants—antimony, arsenic, cadmium, chromium,
             copper, cyanide, lead, nickel, selenium, and zinc.

          •  Conventional  pollutants—total suspended solids, pH, oil  and
             grease.

          •  Nonconventional  pollutants—aluminum and iron.

Toxic organic pollutants were not found in the samples analyzed.

Control  Technologies

          The control  technologies which EPA promulgated to meet effluent
limitations guidelines for BPT, BAT,  PSES, NSPS, and PSNS are as follows:

          t-  BPT--the control technology promulgated to meet this guideline
             applies to the steel, cast iron and aluminum subcategories and
             consists of flow normalization, hexavalent chromium reduction
             (for facilities  which enamel  aluminum), oil  skimming,  pH
             adjustment, and  sedimentation to remove resultant precipitate
             and other suspended solids.

          •  BAT and PSES—the technology basis for the final regulation
             includes flow normalization, reuse of treated wastewater  in
             most coatings water using operations,  chromium reduction,  oil
             and grease removal  and lime and settle end-of-pipe treatment.
             BAT and PSES  requirements apply to the steel, cast iron and
             aluminum subcategories.

          0  NSPS and PSNS—  the recommended control  technology to  meet
             these guidelines applies to all  four subcategories and is
             based on multi-stage countercurrent cascade  rinsing after  each
             metal  preparation operation,  reuse of water'for most coating
             operations as is required for BAT, oil  and grease removal  and
             lime,  settle  and filter  end-of-pipe treatment technology for
             all  wastewaters.

Costing  Methodology

          The costs for compliance were developed on the  basis of number of
plants,  size, process, treatment and  discharge status as  given in the
Federal  Register, Development Document and the Economic Impact Report.

                                  W5.9-3

    -------
          As stated earlier, the proposal  regulations  were subcategorized
on the basis of the type of metal  coated because the chemicals and
processes that create the discharged pollutants vary by the metal  type.
However, most plants in the industry have  the flexibility to coat  more th
one metal type, as such, the regulatory subcategories  are inappropriate f
estimating costs.  Consequently, the cost  estimates are based on the majo
end product categories listed below.

          •  Category 1 (steel)—ranges, home laundry, dishwashers,  hot
             water heaters, sanitary ware,

          •  Category 2 (aluminum or steel)--cookware, architectural
             panels.

          0  Category 3 (steel,  copper, cast iron,  aluminum, or strip
             steel) job shops, miscellaneous.

          Compliance costs for BPT, BAT, PSES, NSPS, and PSNS were
projected exogenously from the Development Document.  The cost of
compliance for the porcelain enameling industry are presented in Table
5.9.1.
                                  W5.9-4

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    -------
                   Chapter W6.   Mineral-Based Industries
          For the purpose of this report,  Mineral-Based Manufacturing
Industries are defined as those establishments primarily engaged in the
gathering or physical  processing of minerals into  a form suitable for use
by the ultimate consumer.  These include:

             Mineral  Mining and Processing
             Glass Manufacturing Industry
             Insulation Fiberglass
             Asbestos  Manufacturing
             Cement Industry
             Paving and Roofing Materials

          Costs for the reduction of water pollution for these industries
are summarized in Table W6.
                                   W6-1

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    -------
                Chapter W6.1  Mineral Mining and Processing
Regulations

          The only regulations that have been promulgated for this industry
are BPT for industrial sand and BPT and NSPS for phosphate rock.  The costs
shown here are based on these two subcategories of this industry.

Industry Characteristics
mining.
  The mineral  mining and processing industry is concerned with the
separation, cleaning, and beneficiation of the following minerals:
      dimension stone
      crushed stone
      construction sand and gravel
      industrial sand
      gypsum
      asphaltic minerals
      asbestos & wollastonite
      lightweight aggregates
      mica
      barite
      fluorspar
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      salines
      tripoli
      garnet
      phosphate rock
      talc
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      feldspar
                               potash
                               trona
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                               mineral  pigments
                               lithium
                               bentonite
                               diatomite
                               Frasch sulfur
                               graphite
                               jade
                               magnesite
                               novaculite
                               shale and common clay
                               aplite
                               attapulgite and montmorillonite
                               rock salt
                               kyanite
                               fire clay
                               ball clay
          The production of minerals in the U.S. is closely associated with
the rise and fall of the U.S. Gross National Product.  Many subsectors have
a small production rate in the U.S. due to competition with higher grade or
cheaper foreign minerals, small demand for selected U.S. minerals, or
alternative supplies of minerals, e.g., sulfur, which is a by-product of
many chemical and pollution control processes.  Production of minerals from
year to year is a dynamic phenomenon for the separate sectors, showing
great growth and recession.  The following discussion includes only the
industrial sand and phosphate rock subcategories, since no final
regulations exist for the other groups.

          Industrial Sand.  Industrial sands are deposits that have been
worked by natural processes into segregated mineral fractions.  Such
deposits are utilized for their contained quartz (S.CL).  The deposits are
                                  W6.1-1

    -------
found in a broad range of locations and formations, some as loose and
visible as dune sand, others as dense and obscure as the hardest of rocks
buried under a variety of surface materials, and in literally all
intermediate types of formations.  They may be found as low-lying
water-bearing sands, as hard-faced bluffs and cliffs, as out-cropped
escarpments on a level plain or as a massive ridge or mountain face.  It
believed that there is only one operating underground mine.

          Phosphate Rock.  "Phosphate rock" is a commercial term for a ro
that contains one or more phosphate minerals—usually calcium phosphate—
sufficient grade and suitable composition to permit its use, either
directly or after concentration, in manufacturing commercial products.  T
term "phosphate rock" includes phosphatized limestones, sandstones, shale
and igneous rocks.

          Present western phosphate mining operations are open pit.
However, most of the western reserve is deep, requiring selective
underground mining, which will continue to be economically viable only if
future phosphate rock prices are high.   The western region accounts for
only 13 percent of domestic phosphate rock production.  Due to local
mineral characteristics and corresponding process practices, and because
the favorable rainfall/evaporation balance existing for the western
facilities, all six producers in this region will soon be operating with
discharge of wastewaters.  Therefore, they will experience no incremental
costs upon implementation of the proposed effluent guidelines.  Producers
in the eastern district must already comply with effluent guidelines clos
to those proposed.  Only four facilities are known to be exceeding the
proposed limits; all four are in Central Florida.  As far as is known, tf
facilities in North Carolina and Tennessee (each state accounting for on!
about 5 percent of national production) will not be affected.

Pollutants and Control Technology

          Effluents from the mineral mining and processing industry are
generally high in suspended solids and mineral content, depending on the
solubility of the specific ores.  Typically, treatment technology consist
of settling ponds to remove suspended solids and sometimes lime
precipitation to remove metals and adjust pH.  For difficult suspended
solids, flocculant addition and thickeners can be used.  Where settling
ponds are not sufficient, filters can be used to augment treatment.
Effluents are generally from two distinct sources, mine dewatering and
beneficiation operations (milling, washing, and separation of minerals).
The effluent from beneficiation operations is usually higher in suspendec
solids than that from mining operations.

Costing Methodology

          Table W6.1.1 is a summary of BPT compliance costs for the above
categories of the mineral mining and processing industry.  The costs were
developed using model plant treatment technology sufficient to meet the
effluent guidelines.
                                  W6.1-2

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                                                         W6.1-3

    -------
                Chapter W6.2  Glass Manufacturing Industry
Regulations

          The costs presented in this chapter are reflective
of EPA's promulgated regulations that establish effluent limitations
guidelines for best practicable technology (BPT) and best available
technology (BAT), performance standards for new sources (NSPS) and
pretreatment standards for new and existing sources (PSNS, PSES) for firms
in the glass manufacturing point source category.  The promulgated
regulations were specified for twelve subcategories of the industry in two
phases.  The first phase of regulations addressed firms engaged in the
manufacturing of flat glass and were published in the Federal Register on
February 14, 1974 (Ref. 7).  The second phase addressed those firms engaged
in the manufacturing of pressed and blown glass, and were published in the
Federal Register on January 16, 1975 (Ref. 8).  Subsequent amendments to
the regulations were published in the Federal Register on February 11, 1975
(Ref.  9) and August 29, 1979 (Ref.  10).

          Since the subcategories of the industry were divided into two
groups in the regulations (Ref. 7,8) and contractor's cost reports (Ref. 3,
4, 5,  6), the remaining sections of this chapter are presented separately
for each group—(1) flat glass, and (2) pressed and blown glass.

Industry Characteristics (Flat Glass)

          The flat glass industry may be divided into six major
subcategories based on the process  employed.   These are:

             Sheet Glass Manufacturing
             Rolled Glass Manufacturing
             Plate (or primary) Glass Manufacturing
             Float Glass Manufacturing
             Automotive Glass Tempering
             Automotive Glass Laminating

          The sheet and rolled glass manufacturing industries do not
discharge wastewater, therefore, they are not considered in this analysis.

          Plate glass is formed by  a rolling  process; then it is ground and
polished on both sides. Float glass is formed by cooling a layer of molten
glass  on a bed of molten tin.  Tempered glass is flat glass that has been
toughened by being heated above its strain point and then quickly cooled.
Laminated glass consists of plates  of glass bonded to a sheet of plastic to
provide protection against shattering.

          The major division within the industry is between primary and
automotive glass manufacturers and  the processes they use.   Plants that
                                  W6.2-1

    -------
produce plate and float glass are classified in SIC 3211 as establishment
primarily engaged in manufacturing flat glass and flat glass products fro
materials taken from the earth in the form of sand (i.e., primary glass
manufacturers).  Plants that fabricate glass products (e.g., automotive
window glass) from purchased glass are classified in SIC 3231 (Ref. 3, pp
15, 18).

          The flat glass industry is a cyclical industry, heavily affecte
by economic conditions in the construction and automotive industries, the
two largest users of flat glass.   Both of these industries were depressed
in 1980 and 1981 but are expected to recover in 1982.  Concerns for energ.
conservation will continue to aid the market for double and triple glazin
and for solar products.  The rehabilitation and retrofitting of real esta
are other expanding markets for flat glass.  Consequently, for the five
years ending in 1985 flat glass shipments are expected to rise at a real
compound growth rate of 4 percent (Ref. 2, p. 21).  For the same period,
automotive glass shipments are expected to grow at the same rate as
automotive production, i.e., 1.5  percent.

Pollutants and Sources (Flat Glass)

          In the manufacture of sheet and rolled glass, no process
wastewater is produced.  Although water is added to raw materials for dus
suppression, the water is evaporated in the melting tank.

          In plate glass manufacturing, process wastewater is produced in
the grinding, polishing and washing operations.  Most of the wastewater i
contributed by the grinding process.  The major waste constituent,
resulting from plate glass manufacturing is suspended solids, although
dissolved solids, BOD, and COD may also be present in the wastewater.  Tf
grinding operation contributes most of the suspended solids.

          Some plants in the float subcategory wash the glass prior to
packing and this constitutes the  only wastewater stream.  TSS, oil, COD,
and dissolved solids were identified in the wastewater.

          In the automotive glass tempering subcategory, wastewater is
produced in the seaming, grinding, drilling, quenching, cooling, and
washing operations with the washing and drilling operations accounting fc
90 percent of the wastewater.  Suspended solids are added by the seaming,
grinding, and drilling wastewaters; oil by the grinding solution carryove
BOD by oil in the coolant solution carryover; and dissolved solids by wat
treatment regenerants and boiler blowdown.

          Water is used in the automobile glass laminating subcategory fc
cooling, seeming, and washing.  Three or four washes are required when oi
autoclaves are used, and initial  vinyl, and postlaminated washes are
required in all cases.  Some plants still employ prelamination washes.
Eighty percent of the wastewater is contributed by initial washing, and
final washing.  Major wastewater constituents are suspended solids, oils,
COD, BOD and phosphorus.  Suspended solids are contributed to the
wastestream by the seeming operation; oil is contributed by the laminatir


                                  W6.2-2

    -------
process; COD is contributed by the post!ami nation wash as a result of the
high oil content.  Phosphorus results from detergents used in the
preassembly and post!ami nation.

          The concentration of pollutants in the wastewater varies by
subcategory.  EPA estimated that the concentration of suspended solids was
as high as 15,000 mg/1 in the plate glass subcategory and only 15 mg/1 in
the float glass subcategory.  Oil and COD concentrations were estimated to
be 1700 mg/1 in the automobile glass lamination subcategory and
significantly lower in all other subcategories.  Phosphorus was found only
in the automobile glass lamination subcategory, although information was
not available for the float glass subcategory.

Control Technologies (Flat Glass)

          There are no specific pretreatment standards for new sources
other than to comply with national pretreatment standards.   The
pretreatment standards for existing sources in all  subcategories except
automotive laminating and float glass specify no limitations.   Pretreatment
standards for the automotive laminating and float glass subcategories have
not been promulgated.

          Although BPT, BAT, and NSPS effluent limitations  for the sheet
glass and rolled glass subcategories call for zero discharge,  plants in
these subcategories have no process wastewater, thus, no technologies are
needed to meet these regulations.

          For the plate glass subcategory, BPT technology requires
partitioning of existing lagoon cells and polyelectrolyte addition.   No BAT
regulations are currently in force.  For NSPS, EPA has promulgated zero
discharge limitations, although it does not recommend a specific
technology.  The Development Document indicates that it is  unlikely  that
any new plants will be built, consequently no costs were assigned for new
source plants.

          For the float glass subcategory, BPT technology is the
elimination of detergents in the float washer to reduce the discharge of
phosphorus.  BAT regulates only phosphorus and at the same  level  as  BPT,
thus, no additional treatment technology is needed.  For NSPS, EPA
recommended diatomaceous earth filtration and elimination of detergents.

          In the automotive glass tempering, BPT technology is coagulation
- sedimentation with centrifugation of waste sludge.   No BAT regulations
are currently in fo-rce.  For NSPS, EPA recommended diatomaceous earth
filtration in addition to BPT technology.

          For automotive glass laminating, EPA recommended  continuously
recycling initial hot water rinse, centrifugation of the recycled hot water
rinse to remove oil, and gravity oil  separations.   BAT regulations are
currently in force for phosphorus control, however, no end-of-pipe
treatment exists.  NSPS standards are diatomaceous  earth filtration  in
addition to BPT.
                                  W6.2-3

    -------
Costing Methodology (Flat Glass)
          Model plants are used to estimate the regulatory costs in the
flat glass industry.   These model  plants for each subcategory were derive-
in the Development Document (Ref.  3).   The Appendix summarizes the sizes '
model plants, the costs for each model  plant and the resulting equations.

Industry Characteristics (Pressed and  Blown Glass)

          The effluent limitations guidelines for the pressed and blown
glass manufacturing industry cover manufacturers of glass containers for
commercial packing, bottling, home canning, and the manufacturers of glas
and glassware, which is pressed, blown, or shaped from glass produced in
the same establishment.

          The industry has been divided into the following subcategories,
based upon differences in production processes and wastewater
characteristics:

             Glass containers
             Machine-pressed and blown glass
             Glass tubing
             Television picture tube envelopes
             Incandescent lamp envelopes—forming and frosting
             Hand-pressed and blown glass—leaded and hydrofluoric acid
             finishing, and nonhydrofluoric acid finishing

          Four manufacturing steps are common to the entire pressed and
blown glass industry: weighing and mixing of raw materials, melting of ra
materials, forming of molten glass, and annealing of formed glass product
Further processing (finishing) is required for some products, especially
television tube envelopes, incandescent lamp envelopes, and hand-pressed
and blown glass.

          Sand (silica) is the major ingredient of glass and accounts for
about 70 percent of the raw materials  batch.  Other ingredients may inclu
soda or soda ash (13-16 percent), potash, lime, lead oxide, boric oxide,
alumina, magnesia, and iron or other coloring agents.   The usual batch al
contains between 10 and 50 percent waste glass (cullet).

          Melting is done in three types of units: continuous furnaces,
clay pots, or day tanks.  Methods used to form glass include blowing,
pressing, drawing, and casting.  After the glass is formed, annealing is
required to relieve stresses that might weaken the glass or cause the
product to fail.  The entire piece of  glass is brought to a uniform
temperature that is high enough to permit the release of internal stresse
and then cooled at a uniform rate to prevent new stresses from developine
finishing steps include abrasive polishing, acid polishing, spraying witF
frosting solutions, grinding, cutting, acid etching, and glazing (Ref. 4)

          The U.S. Bureau of Census, Census of Manufacturers, classifies
the manufacturers of glass containers  in SIC 3221 and the manufacturers c
all other pressed and blown glass products in SIC 3229 (Ref. 6).

                                  W6.2-4

    -------
          The most promising growth prospects for the glass container
industry are in the beer and soft drink markets.   Competition from other
types of containers, however, is expected to keep the annual  growth rate in
the glass container industry at approximately 1.0 percent per year (Ref. 4,
p. 73).  Indirect competition from plastics will  continue to affect the
demand for handmade glassware and glasstubing;  however, the adverse affects
are expected to be minimal  and growth will  be at  about the same annual  rate
as the GNP, i.e., 3.2 percent.  There is no material  competitive with glass
for electric light bulbs, as such, demand will  grow as electricity demands
increase (Ref. 6).

Pollutants and Sources (Pressed and Blown Glass)

          Water is used during the manufacture  of pressed and blown glass
for noncontact cooling, quenching of cullet, contact  cooling of metallic
forming of cutting devices, batch wetting,  abrasive polishing, edge
grinding, washing, and assorted other uses.

          For the purpose of establishing effluent limitations guidelines,
the following pollution parameters were determined significant:  fluoride,
ammonia, lead, oil, total suspended solids  (TSS), and pH.  These parameters
are not present in the wastewater from every subcategory, and may be more
significant in one subcategory than in another.   Wastewaters from
noncontact cooling and boilers are not considered process wastewaters and
are not covered by the-guidelines.

          In the manufacturing of glass containers, process water is used
for cullet quenching, batch wetting, and contact  cooling of shears.  Water
used for cullet quenching accounts for nearly all of  the flow.  Principal
pollutants associated with  this subcategory are oil,  which is present in
the shear spray or is due to leaking lubricants,  and  TSS, which  is present
in the wastewater from cullet quenching.

          In the Danner tubing subcategory, the major source of process
wastewater is from cullet quenching while the principal  pollutant
discharged is TSS.

          In the manufacturing of television picture  tube envelopes,
process wastewater originates from many sources.   TSS originates in the
cullet quench water, batch  wetting, abrasive polishing and acid  polishing
discharge streams.  Fluoride is contributed to  the waste stream  by the  fume
scrubbers and acid polishing rinse waters.   Lead  is present in both the
abrasive polishing and edge grinding streams.

          In the incandescent lamp envelope subcategory, major pollutants
include oil, TSS, fluoride, and ammonia. Oil is  contributed  by  shear spray
drippage and lubrication leaks, while TSS is present  in the cullet quench
water, contact cooling of shears, and the rinse water of frosted bulbs.
Fluoride and ammonia are present only in wastewaters  of plants that have
frosting operations.  The frosting rinse water  contains fluoride and
ammonia.  Ammonia is also present in fume scrubber discharge.
                                  W6.2-5

    -------
          In the production of hand pressed and blown glass, TSS is preser
in wastewaters of all  finishing steps including grinding, polishing, and
cutting.  Lead is contributed to the waste stream by acid treatment of lee
glass.  Acid polishing and etching rinse waters contain fluoride.

          The concentration of these pollutants in the wastewater varies t
subcategory.  In the sampling of wastewaters from plants in the pressed
blown and glass industry, EPA found that TSS in the raw wastewater was as
low as 24 mg/1 while the concentration of lead varied from 30 mg/1 to 100
mg/1.  Oil varied the least from 10 mg/1 to 25 mg/1.  Ammonia which was
found only in the wastewater •from frosting operations of incandescent lamf
plants was 650 mg/1.

Control Technologies (Pressed and Blown Glass)

          BPT--None of the subcategories need additional treatment to mee'
BPT effluent limitation guidelines although EPA projected that improved
housekeeping techniques may be needed for some glass container and glass
(Danner) tubing plants.  However, most plants could meet the guidelines
through normal maintenance and cleanup operations.

          For plants in the television picture tube envelope and
incandescent lamp envelope subcategories, EPA also recommended no further
treatment.  At the time of promulgation, it was common practice for plant:
in both subcategories to employ lime addition, precipitation, coagulation
sedimentation and pH adjustment.  Incandescent lamp envelope plants also
used oil skimmers.  Some plants may need to employ stricter housekeeping
to meet the BPT guidelines.

          For plants in the hand pressed and blown glass manufacturing
subcategory, EPA did not specify any BPT limitations due to anticipated
serious economic impacts.

          BAT—for two subcategories (glass containers and glass tubing),
EPA has revoked BAT standards and no cost estimates were made.  For the
remaining subcategories, EPA recommended technologies to meet BAT-standar
are:
             TV tube envelopes: sand filtration of lime precipitati
on
          •  Incandescent lamp envelopes: sand filtration, stream strippi
             for removal of ammonia, recarbonation

          •  Hand pressed and blown glass: batch lime precipitation,
             sedimentation, recarbonation, sand filtration.  (Plants in
             this subcategory with a discharge of less than 50 gallons pe
             day of process wastewater are exempted from meeting BAT
             guidelines.)

          NSPS--For TV tube envelopes, incandescent lamp envelopes and
hand-pressed and blown glass, NSPS is identical to BAT standards and the
same technologies are assumed.  For glass containers and glass (Danner)
tubing, the following technologies were costed:

                                  W6.2-6

    -------
          1. Glass containers: stream segregation, recycling of cullet
             quench through a gravity oil separator, treatment of blowdown
             by dissolved air flotation

          2. Glass (Danner) tubing: recirculation of cullet quench through
             a cooling tower with blowdown treated by a diatomaceous earth
             filter

          PSNS—For PSNS regulations, EPA specified no limitations for the
glass (Danner) tubing subcategory.  For the glass container subcategory,
EPA specified standards for oil (mineral) which were identical to the BPT
standards.  Since the BPT standards did not require further treatment, it
was assumed that no further treatment would be required for new source
pretreaters.  Thus, for glass (Danner) tubing and glass containers, costs
were assumed to be zero.  For all other subcategories, PSNS limitations are
identical to BAT limitations for oil (mineral) and fluoride while no
limitations were specified for other pollutants.  Because limitations for
oil (mineral) and fluoride were identical to BAT, BAT technologies were
assumed.

          PSES—EPA has not promulgated regulations for existing
pretreaters.

Costing Methodology (Pressed and Blown Glass)

          For each of the subcategories, capital and O&M costs were
presented for a typical model plant in the Development Document (Ref. 4).
The cost estimating equations for each subcategory are presented in the
Appendix.  The costs for each of the model plants as presented in the
Development Document (Ref. 4) are also included.

          These costs and model plants are used in this study to estimate
the total regulatory cost, shown in Table W6.2.1.
                                  W6.2-7

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    -------
                    Chapter W6.3  Insulation Fiberglass
Regulations
          The costs of compliance shown in this chapter are based on
documentation associated with the regulations as originally promulgated.
BAT regulations for this industry are currently under review.  The chapter
has not been updated since costs for compliance are subject to change if
the BAT regulations are modified.

Industry Characteristics

          The insulation fiberglass industry has no subcategories.  The raw
materials for fiberglass production are 55-73 percent silica and 45-27
percent fluxing oxides (e.g., limestone and borates) to manufacture the
fiberglass filaments, and a phenolic resin to bind the filaments together.
Four basic types of glass are used:  low-alkali lime alumina borosilicate,
soda-lime borosilicate, lime-free borosilicate, and soda-lime.

          The basic process for fiberglass manufacture is as follows.  The
raw materials batch is melted to form a homogeneous glass stream.  There
are two ways that the melting process can  be done:  direct melting or
marble process.  The molten glass stream is then fiberized to form a random
mat of fibers which are bonded together with a thermosetting phenolic
binder or g.lue.  The glass is fiberized by either flame attenuation or
rotary spinning.  The trend in the industry is toward more direct melting
and rotary spinning.

          The primary domestic uses for insulation fiberglass are:
insulating material, noise insulation products, air filters, and bulk wool
products.

          There are 19 insulation fiberglass plants owned by three major
companies.  Ten of these plants currently  have BPT equipment in place.  The
typical plant produces 123 thousand metric tons (136 thousand short tons)
per year, and all plants have a wastewater discharge.

Pollutants and Sources

          The main sources contributing to total waste load are summarized
in Table W6.3.1.

Control Technology and Costs

          Because of the large volume of process waters and because the
chain wash water often contains phenol, formaldehyde, and other
contaminants, total recycling of wastewaters is the most economical
treatment alternative for the insulation fiberglass industry.   Sample


                                  W6.3-1

    -------
recycling systems consist of coarse filtration,  followed  by  either fine
filtration or flocculation and settling.

          Effluent control costs  are summarized  in  Table  W6.3.2.
                                  W6.3-2

    -------
          Table W6.3.1.
Insulation fiberglass industry pollutant
  sources waste streams
Air
Pollutants Scrubbing
Phenols
BOD,
CODD
IDS
TSS
Oil and
Grease
Ammonia
PH
Color
Turbidity
Temperature
(Wasted
heat)
Specific
conductance
X
X
X
X
X

_
_
-
X
X
X



X
Boiler
Blow-
down
-
-
X
X

_
_
-
-
X
X



X
Caustic
Blow-
down
-
-
X
X

_
_
X
-
X
X



X
Chain
Spray
X
X
X
X
X

X
X
X
X
X
-



X
Gullet
Cooling
-
-
X
X

-
-
-
-
-
X



"
Fresh
Water
Treat-
ment
-
-
X
X

_
-
X
-
X
X



X
Hood
Spray
X
X
X
X
X

X
X
X
X
X
-



X
Noncon-
tact
Cooling
Water
-
-
X
-

_
_
-
-
-
X



**
Source:   EPA Development Document,  January,  1979
                                  W6.3-3

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                                                              W6.3-4

    -------
               Chapter W6.4  Asbestos Manufacturing

Regulations

          Regulations for all eleven industry subcategories have been
promulgated for BPT, BAT (old), NSPS and pretreatment for new sources.  BAT
limitations have been revised.  In 1981, the BCT requirements, originally
added in 1979, were remanded.  Therefore this chapter does not include any
estimate of BCT costs.  All other costs are based on the development
documents referenced in the Appendix.

Industry Characteristics

          As of 1978, the main asbestos consumers were the manufacturers of
cement pipe (35%), floor tiles (20%), friction products (12%), roofing
products (10%) and cement sheet (6%).  Asbestos-cement pipe is used mainly
for sewer lines.  Asbestos sheet is used for laboratory table tops and
other structural uses.  Asbestos paper and millboard have a wide variety of
uses, but are particularly used for applications where direct contact with
high temperatures occurs.  Asbestos roofing and floor tiles are fabricated
products that take advantage of the unique qualities of asbestos.  The
primary reasons for the use of asbestos fiber in textile products are its
durability and resistance to heat, fire, and acid.   Asbestos is the only
mineral that can be manufactured into textiles using looms and other
equipment.  Textile products are primarily used for friction materials,
industrial packing, and electrical and thermal insulation.

          Asbestos cement pipe, cement sheet, paper, and millboard are
manufactured with similar methods.  The asbestos fibers and other raw
materials are slurried with water and then formed into sheets.  Settling
tanks (save-alls) are used in all  processes.  In roofing manufacture,
asbestos paper is impregnated with asphalt or coal "tar.  In floor tile
manufacture, asbestos is added to the tiles for its special structural and
dimension-holding qualities.  Textile manufacture involves the coating of
asbestos yarn or cloth.  The material is drawn through one or more dip
tanks and the coating material is spread by rollers, brushes, or doctor
blades.  The coated textile product then passes through a drying oven where
the solvent is evaporated.

          Shipments of asbestos (mostly chrysotile)  in 1978 from mines in
the United States increased minimally from those in 1977.   Imports were 4
percent higher than in 197-7, but U.S. demand continued to lag well  below
the peak year of 1973.  The predicted annual growth rate of 2.0 percent for
U.S. asbestos consumption is an average of three predicted growth rates
presented in Table 2 of the Appendix.  The apparent consumption for 1974
was about 767,000 MT and for 1978 about 619,000 MT.   It is expected to
increase to about 800,000 MT by 1985 and to about 940,000 MT by the year
2000.
                                   W6.4-1

    -------
Pollutants and Sources

          Asbestos manufacturing wastes  include total  suspended solids
(including asbestos fibers),  BOD-,  COD,  pH,  alkalinity,  high temperature,
total dissolved solids, nitrogen, phosphorus,  toxic substances, oil  and
grease, organic matter, nutrients,  color and turbidity.   The basic
parameters used to define asbestos  plant effluents are COD,  TSS, and pH.

          The major source of wastewater in  the industry is  the machinery
that converts the asbestos slurry into the formed wet  product.   Water is
used as an ingredient, as a carrying medium, as a coolant, and for such
auxiliary uses as pump seals, wet saws,  and  pressure-testing pipes.
Textile plants use little water in  their operations.   The addition of
moisture during weaving or braiding and  during coating generates small
amounts of wastewater.  In all subcategories,  water is removed to the
settling tank (save-all system).

Control Technology

          The basic treatment technology used  by the  asbestos industry to
meet BPT guidelines is sedimentation.  Neutralization, coagulation,  and
skimming are also used in combination with settling tanks to achieve BPT
levels.  No discharge limitations,  which apply to most BAT and some NSPS
and BPT guidelines, can be met with a complete recycle process.

Costing Methodology

          The costs of compliance were estimated using an industry model
for each of the regulated subcategories  and  a  single  model for the Phase
portion of the industry.  Most of the information for  the cost estimate v\
taken from Development Documents, Economic Analysis Documents, or
associated prior studies of economic impact  by EPA contractors.  The
estimated costs of compliance are listed in  Table W6.4.1.
                                   W6.4-2

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                       Chapter W6.5  Cement Industry
Regulations
          BAT regulations for the industry covered in this chapter are
currently under review by EPA.  It is anticipated that the review may
result in some change in the regulations, with subsequent effects on the
estimated cost of compliance.  Because of possible changes in the BAT
regulations following the review, this chapter has not been updated.  The
costs shown here are based on documentation associated with the regulations
as originally promulgated, and the costs for compliance with BAT are
subject to change if the BAT regulations are modified.

Industry Characteristics

          The cement industry is divided into two basic manufacturing
processes:  wet and dry.

          A facility using the wet process grinds up the raw materials with
water and feeds them into the kiln as a slurry.

          A facility using the dry process dries the raw materials, grinds
and then feeds them into the kiln in a dry state.

          In each of these processes, there are three major steps:
grinding and blending, clinker production, and finish grinding.  .Clinker is
a material about the size of a large marble which has been through the kiln
but has not been fine-ground into finished cement.

          The raw materials for cement production include lime (calcium
oxide), silica, alumina, iron, and gypsum.  Lime, the largest single
ingredient, comes from cement rock, oyster shell marl, or chalk.

          Prices have increased due to higher production costs and
pollution abatement costs.  Fuel cost increases are also expected to affect
prices.

Pollutants and Sources

          In terms of the generation of water pollutants," the cement
industry is divided into three subcategories:

          •  Leaching plants.  The contaminated water is from leaching
             systems installed to reprocess collected kiln dust and from
             the wet scrubbers that control stack emission.

          •  Nonleaching plants.  The contamination of water is not a
             direct function of the water usage.


                                  W6.5-1

    -------
          •  Pile materials.   Runoff from piles of kiln dust, clinker, coe
             or other materials that are subject to rainfall.

          The main sources contributing to the total  waste load come from
the following:  in-plant leakage, noncontact cooling  water, process water,
kiln dust pile runoff water,  housekeeping water, and  effluent from wet
scrubbers.

          In order to define  waste characteristics, the following basic
parameters were used to develop guidelines for meeting BPT and BAT:  pH,
total  dissolved solids, total suspended solids, alkalinity, potassium,
sulfate, and temperature (waste heat).

          BPT for plants in the nonleaching subcategory has been defined «
no discharge of pollutants from manufacturing except  for thermal discharge
for which an increase of 3°C  (5.5°F) is permitted.

          For plants in the leaching subcategory, BPT is the same as for
the nonleaching subcategory except for the dust-contact streams where a
reduction of pH to 9.0 and of suspended solids to 0.4 kg/metric ton of du:
leached is required.  For plants subject to the provisions of the Materia'
Storage Piles Runoff Subcategory, either the runoff should be contained tc
prevent discharge or the runoff should be treated to  neutralize and reduce
suspended solids.

          BAT for both leaching and nonleaching plants is defined as zero
discharge of pollutants.  For plants subject to the provisions of the
Materials Storage Piles Runoff Subcategory, the definition of BPT is
applied to BAT.

          NSPS is the same as BPT except that no discharge is permitted f<
plants with materials storage pile runoff.

Control Technology and Costs

          The main control and treatment methods for  the cement industry
involve recycle and reuse of  wastewater.  The devices employed include
cooling towers or ponds, settling ponds, containment  ponds, and clarifier

          For leaching plants, additional controls are needed for adequat
control of alkalinity, suspended solids, and dissolved solids.  Alkalinity
is controlled by neutralization, or carbonation; suspended solids by
clarification, sometimes with the addition of flocculating agents.
Although none of the leaching plants currently uses a treatment method to
control dissolved solids, several processes that might be employed includ>
precipitation, ion exchange,  reverse osmosis, electrodialysis, and
combinations of these followed by total evaporation.

          In-plant control methods include good maintenance and operating
procedures to minimize solid spillage and to return dry dust to the
process.  Solids introduced into storm water runoff can be minimized by
paving areas for vehicular traffic, providing good ground cover in other
                                  W6.5-2

    -------
pen areas, removing accumulations of dust from roofs and buildings, and by
building ditches and dikes to control runoff from materials storage piles.

          Control  costs are summarized in Table W6.5.1.
                                  W6.5-3

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                Chapter W6.6  Paving and Roofing Materials

Regulations

          The costs included in this chapter are for 8PT, BAT, and NSPS
requirements.  This industry has been exempted from additional federal
guidelines under paragraph 8 of the 1976 settlement agreement with NRDC.
The regulations for this industry are cited in 40 CFR 443.

Industry Characteristics, Pollutants and Control Technology

          Establishments covered under these guidelines include:  (1)
Asphalt emulsion plants (SIC 2951); (2) Asphalt concrete plants (SIC 2951
and 1611); (3) Asphalt roofing plants (SIC 2952) and (4) Linoleum and
asphalt felt flooring (SIC 3996).

          Asphalt Emulsion Plants.  About 50 plants produce asphalt
emulsions.  The chief source of pollutants is water from the wet collection
of waste fumes and the runoff of precipitation.

          The costs of meeting the regulations for a typical plant of 5,500
metric tons (6,000 short tons) per day have been developed by EPA for the
BPT, BAT, and NSPS case, and are applied to the 7 plants not in compliance
in 1974, the year the regulations were proposed.  Eighteen plants at that
time were meeting the BPT standards, of which 8 met BAT standards.  (This
was industry practice, not anticipation of the regulations.)  Twenty-five
plants discharge to municipal sewers.

          Industry size was static from 1971-75 but was expected to grow at
4 percent per year through 1980 and at 1.65 percent per year from 1981 to
85.  These estimates were based qn expected highway construction and
repair.

          Asphalt Paving Plants.  Approximately 3,180 plants usa wet
scrubbers to remove particulates from the air, thereby creating a potential
water pollution problem.  (The rest of the industry group uses fabric
filters.)  The BPT, BAT, and NSPS requirements are the same—no discharge
of pollutants.  This can be readily achieved by the use of an earthen'
settling basin or lagoon, or by use of a mechanical sedimentation tank.
Costs derived in the EPA Development Document have been used.  No
pretreatment costs have been calculated, since, according to a recent
survey, only one plant discharges to a municipal system.  Forty percent of
new plants or expansions occurring after 1974 are expected to use wet
scrubbing; the balance will use dry air pollution control  methods and thus
will not incur water pollution control costs.  The balance are estimated to
have changed to fabric filters to abate air pollution and avoid the costs
of upgrading their water clean-up system.  Forty percent of future plants
are expected to use wet systems.
                                   W6.6-1

    -------
          Asphalt Roofing..  In 1974, 225 plants produced a variety of
asphalt and tar roofing materials including shingles, felts, siding
materials, and coatings.  The chief pollution problem arises from oil and
particulate in the cooling water that is used directly on the material.
addition, most plants have a tower for blowing asphalt.  The ground
adjacent to this unit is usually saturated with asphalt so that
precipitation runoff becomes contaminated with oils.

          The costs for meeting BPT, BAT, and NSPS for a plant of 450
metric tons per day (500 short tons per day) have been developed by EPA a
have been applied to the 21 plants not conforming to BPT regulations and
the additional 21 plants meeting BPT but not BAT standards.

          Growth of the industry was assumed to be 3.5 percent per year.

          Linoleum and Asphalt Felt Flooring.  This industry segment of t
tar and asphalt products industry is quite small (3 plants estimated) and
the costs for conforming to the regulations are small ($6,100 capital
investment and $2,570 O&M for a typical plant).  For these reasons, the
costs have not been tabulated or included.

Control Costs

          The total costs for asphalt emulsion plants, asphalt paving
plants and asphalt roofing plants are shown in Table W6.6.1.
                                   W6.6-2

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                  Chapter W7.  Forest Products Industries
          For the purpose of this report, the Forest Products Industries
are defined as those establishments engaged in gathering and processing
forest products and in the manufacture of consumer goods from these
materials.  These are the:

          •  Timber Products Processing
          t  Timber Products Process:  Wood Furniture and Fixture
               Manufacturing
          •  Gum and Wood Chemicals
          •  Pulp, Paper, and Paperboard

          Costs for the reduction of water pollution for these industrial
sectors are summarized in Table W7.  These costs and other data are
repeated below in the appropriate sections together with the assumption
specific to the industry and other details.
                                   W7-1

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          Chapter W7.1  Timber Product Processing (Nonfumiture)


Regulations

          Effluent discharge regulations for the timber product processing
(nonfurniture) subcategories are reported in the Federal Register (Vol.
46, No. 16, Monday, January 26, 1981) and summarized in the appendix.  The
regulations apply to fourteen subcategories including:

          A.  Barking                H.  Wood Preserving - Boulton
          B.  Veneer                 I.  Wet Storage
          C.  Plywood                J.  Log Washing
          D.  Dry Process Hardboard  K.  Sawmills and Planning Mills
          E.  Wet Process Hardboard  L.  Finishing
          F.  Wood Preserving -      M.  Particleboard
              Water Borne or         N.  Insulation Board
              Nonpressure
          G.  Wood Preserving-Steam

          The prior categories cover both processes (i.e., barking and log
washing) and products (i.e., plywood and particleboard) and an individual
establishment may be impacted by more than one category if it is a
multi-product plant or encompasses a regulated process as well as a
product.

Industry Characteristics

          The nonfurniture timber product processing industry encompasses
a large, diversified and complex set of establishments and companies.  The
industry converts wood raw materials in a wide range of lumber, flat board,
and other wood building and construction materials.  Over 15,000
establishments (1979) are covered by this industry category including:

             Type of plant                           No. of plants

          Sawmills                                       11,000
          Millwork and finishing                          3,000
          Veneer and plywood                                500
          Wood preserving - NP, steam and boulton           476
          Particleboard                                      75
          Dry process hardboard (only)                       16
          Wet process hardboard (only)                       11
          Insulation board                                   10
          Combined insulation and wet process
            hardboard                                         5
          Total (approximate)                            15,000 plus
                                  W7.1-1

    -------
          The plants are located contiguously with the natural range of
timberlands in the Pacific Northwest, Southeast, North Central and
Northeastern United States.   Their capacity will vary from small  family
operations to facilities employing a thousand workers.  Capacity
utilization generally varies from 80 to 95 percent although the recent
housing market recession has dropped utilization rates much lower and
caused several plant closings.

          In 1981, industry value of shipments were over $18.5 billion.
Real annual growth rates were growing at 4.1 percent per year from 1972-7
but showed declines of 6.2 percent per year for the 1978-81 period.  Grow
is expected to be positive in the near future, if the housing industry
recovers.

          Most of the nonfurniture timber processing industry is covered
the following SIC groups.

          2421  Sawmills and Planning Mills
          2435  Hardwood Veneer and Plywood
          2436  Softwood Veneer and Plywood
          2491  Wood Preserving
          2492  Particleboard

Of these groups, the sawmill and planning mill group is the largest
accounting for about two-thirds of the employment and value of shipment.
Softwood veneer and plywood plants are the second largest group
representing one-fifth of employment and value of shipments.  Each of the
other groups accounts for less than ten percent of the industry employmer
or shipments.

          The method of waste disposal is highly variable, with some
categories including all or predominately indirect dischargers.  Detailec
information on method of discharge is presented in the appendix.

Pollutants and Sources

          Water use varies widely among the subcategories in the timber
products processing industry.  The major pollutants are chemicals leachec
from wood, particles from washing or cutting operations, and oils, pheno'
and metals from fishing and preserving opera-tions.  The major pollution
parameters considered in developing treatment standards are BOD, COD,
suspended solids, oil and grease, phenols, and metals.

          Water use and major pollutants in each subcategory are summari;
below.

          The barking subcategory includes the operations which remove b<
from logs.  Barking may be accomplished by several types of mechanical
abrasion or by hydraulic force.  For the purpose of this regulation
"hydraulic barking" means that method of barking wood that utilizes wate
at a pressure of greater than 68.0 atm (1000 psi) as the means of removi
bark from logs.  The product from the barking subcategory is normally us<


                                  W7.1-2

    -------
as a raw or feed material to other subcategories in the timber products
processing category rather than being sold as a finished product.
Wastewaters generated by the barking operation vary widely.  Large volumes
of water are used in hydraulic barking.  Abrasion type barkers use less
water and certain type barkers are operated dry.  The wastewaters contain
suspended solids and BODS in concentrations ranging up to 3,000 and 1,000
mg/1 respectively.

          The veneer subcategory includes the operations used to convert
barked logs or heavy timber into thinner sections of wood known as veneer.
Log conditioning, veneer dryer wash water, and cooling water are the main
sources of wastewaters.  The primary parameters contained in raw
wastewaters are BODS and suspended solids.  BODS loading may be as high as
2,500 kg/million sq m (515 Ib/million sq ft) of board on a 9.53 mm (3/8 in)
basis, and suspended solids may range as high as 29,000 kg/million sq m
(6,000 Ib/million sq ft) of board on the same basis from log conditioning
steam vat wastewater.

          The plywood subcategory includes the operations of laminating
layers of veneer to form finished plywood.  Plywood manufacturing is an
almost entirely dry operation using water in significant quantities only
for cleaning the glue mixing and glue application equipment.  This
wastewater may contain the various components in protein, urea or phenolic
glues.  Principal pollutants include suspended solids, nitrogenous
materials, BOD5, phenols and formaldehydes.  Both suspended solids and BOD5
concentrations may be extremely high ranging into hundreds of thousands of
mg/1.

          The dry process hardboard subcategory includes all of the
manufacturing operations attendant to the production of finished hardboard
from chips, dust, logs, or other raw materials using the dry matting
process for forming the board mat.  Water usage in dry process hardboard
manufacturing is low, and waste dischargers are minimal.  Sources of
wastewater are log and chip washing, caul wash water, resin wash water, and
cooling water.  Typical wastewater flows are less than 2,000 I/day (500
gal/day).

          The wet process hardboard subcategory includes all of the
manufacturing operations attendant to the production of finished hardboard
from chips, dust, logs, or other raw materials using the wet matting
process for forming the board mat.  The nature of the wet matting process
in which the fibers are diluted from 40 percent consistency to less than
1.5 percent prior to mat formation, is such as to create volumes of
wastewater in the range of 4.6 to 46 cu m/kkg (1,100 to 11,000 gal/ton).
While the water use may vary from mill to mill, the main sources of
wastewater are log wash, chip wash, and caul washwaters, fiber preparation,
and mat formation (wet matting).  The principal pollutants found in these
wastewaters are BOD5 and suspended solids.  BODS may reach 50 kg/kkg (100
Ib/ton), and suspended solids loading usually averages under 19 kg/kkg (38
lb/ton).
                                  W7.1-3

    -------
          The wood preserving—water borne or non-pressure subcategory
includes all wood processes in which steaming or boultonizing is not the
predominant method of conditioning, all  non-pressure preserving processes
and all pressure or non-pressure processes employing water-borne salts.
The actual volume of water used at a wood preserving plant is not static,
but varies depending upon the condition  of the stock being treated (eithe
green or seasoned) and the size of the individual  items.  Wastewater
characteristics vary with the particular preservative used, the volume of
stock that is conditioned prior to treatment, the conditioning method use
and the extent to which effluents from retorts are diluted with water fro
other sources.  Typically, wastewaters from creosote and pentachlcrophenc
treatments have high phenolic, COD, and  oil content and may have a turbid
appearance that results from emulsified  oils.  They are always acid in
nature and the pH values usually fall within the range of 4.1 to 6.0.  Th
COD for such wastes frequently exceeds 30,000 mg/1 , most of which is
attributable to entrained oils and to wood extractives (principally simp!
sugars) that are removed from wood during conditioning.  The wastewater
resulting from vat type treatment using  water soluble salts is highly
variable in both volume and pollutant content.  As the source of this
wastewater is primarily from drips, leaks and minor spills, it cannot be
effectively characterized.

          The wood preserving—steam subcategory includes all processes
that use direct steam impingement on the wood as the predominant method c
conditioning.  Steam conditioning of wood produces a large volume of
condensate containing extraneous components from the wood in addition to
the wood preserving chemicals.  The volume of wastewater may vary widely
from day to day within the same processing facility; value ranges from
6,000 to 150,000 I/day (2,000 to 40,000  gal/day) have been recorded in a
single facility.  Pollutants are generally similar to those outlined for
the wood preserving subcategory above.

          The wood preserving—boultonizing subcategory covers those wooc
preserving processes which use the Boulton process as the method of
conditioning stock.  Boultonizing generates wastewaters similar in
character to those in the steam subcategory.  The volume, however, is
substantially lower because the only source of process wastewater is the
water removed from the wood during the conditioning step.

          Wet storage includes storage of logs in estuaries and streams,
log ponds, mill ponds and wet decks.  Pollutants are washed'off the surfa
of logs and leached from the wood.  The  principal  pollutants of concern c
COD, BOD, dissolved and suspended solids and phenols.

          The processing operations of sawmills and planning mills have
very limited process water requirements  and the volumes of wastewater
generated are not sufficient, with reasonable process management, to resi
in a process wastewater stream.

          Finishing operations include gluing, application of surface
coatings, and the application of sealers, stains, dyes, primers, and
fillers, of either organic or inorganic  nature.  Pollutants typically
                                  W7.1-4

    -------
include mercury and other metals, dissolved solids, phenols and organic
resins, BOD, COD, and pH.

          The primary sources of wastewater generation in the particleboard
manufacturing industry are resin blender cleaning water, cleaning of
additive storage tanks, caul  cooling sprays, mat sprays, and fire control
water.  Pollutants typically include high BOD, COD, dissolved and suspended
solids and phenols, nitrogen and phosphorus.

          Insulation board manufacture generates a large volume of process
water.  Water may be used in a number of the following operations:  chip  ~
washing, white water (i.e., water used in processing and carrying the wood
fibers through the insulation board manufacturing process) finishing
operations, cooling, seal water, fire control  and housekeeping.  Pollutants
typically include BOD, COD, dissolved and suspended solids, and dissolved
organic materials.

Treatment Technologies

          Various treatment technologies can be used to achieve BPT, BAT,
and NSPS guidelines.  Technologies for the nine subcategories that are to
achieve zero discharge under BPT or BAT include a combination of:

             Water conservation
             Recycling and reuse
             Waste stream segregation
             Inplant process  changes, and
             Disposal  processes such as spray  irrigation, evaporation,
             incineration, and discharge to impoundments

          Technologies for the five other subcategories have been  chosen to
reduce pollution loadings without completely eliminating discharges under
BPT or BAT.  These technologies have been chosen because standards
requiring zero discharge would not be cost effective or economically
feasible.  Technologies and standards for these subcategories are
summarized below.

          Hydraulic barking,  wet process hardboard, and insulation board
plants are required under BPT to achieve numerical  discharge limitations
for BOD, suspended solids, and pH based on primary treatment followed by
biological treatment.   More stringent BAT standards have been withdrawn.

          Wood preserving—steam facilities are required to achieve
numerical discharge limitations for BOD, phenols, oil  and grease,  and pH,
based on oil recovery, waste  stream segregation and water conservation
followed by one or more of the following:

             Biological treatment
             Oxidation
             Soil irrigation
             Evaporation; and
             Incineration of  oil wastes
                                  W7.1-5

    -------
          More stringent BAT standards have been withdrawn.

          8PT and BAT standards for wet storage require minor modificatic
to existing facilities to eliminate discharge of debris.

          NSPS treatment technologies are designed to achieve zero
discharge for all subcategories except hydraulic barking and wet storage.
In each of these categories NSPS technologies are the same as BPT
technologies.

          PSES for eleven subcategories are based on general pretreatment
regulations.  Technologies for these subcategories have not been specifie

          The wood preserving—water borne or non-pressure subcategory mi
achieve zero discharge under PSES.   This requirement is based on careful
water management and recycling, as  specified in the BPT standard.

          The wood preserving—steam and wood preserving—boulton
subcategories have PSES requirements which require facilities to meet
numerical standards for oil and grease, copper, chromium and arsenic.
These limitations can be met using  in-place oil separation technology.

Costing Methodology

          Cost estimates for each subcategory are derived from one or mor
of the following sources:

          0  Model plant costs from a Development Document
          t  Plant specific data from a Development Document
          •  Exogenous data from an Economic Analysis
          •  Exogenous data from a  Federal Register notice

          For each subcategory, the cost estimates reflect the currently
promulgated regulations.

          Total costs for each regulation affecting direct dischargers w<
estimated from a cost estimating power equation developed from model plar
data or from exogenous data.  Cost  estimating equations were presented ir
the form y=Ax  , in which:

          y = capital or O&M costs, and
          x - plant capacity

          If more than one model plant was available for a technology, A
and b were calculated using regression techniques.  If only one model pl<
was available, values for A were calculated assuming b = .6 for capital
costs and b =  .8 for O&M costs.

          Cost estimating equations, model plant data, exogenous data, a
costing assumptions for direct dischargers in each subcategory are
presented in the Appendix to this chapter.
                                  W7.1-6

    -------
          Pretreatment standards more stringent than general  pretreatment
levels have been established for:

          •  Wood preserving - water borne or non-pressure
          t  Wood preserving - steam
          •  Wood preserving - boulton

          Compliance costs for these subcategories are minimal  and have
been assumed to be zero.
          The aggregate cost of compliance  for all  significantly impac
subcategories is presented in Table W7.1.1.   These  costs  are developed
a combination of exogenous and model  plant  data depending on the
subcategory.  Specific cost data and assumptions are presented in the
appendix.
                                  W7.1-7

    -------
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    -------
          Chapter W7.2
Timber Product Processing: Wood Furniture
 and Fixture Manufacturing
Regulations

          The wood furniture and fixture manufacturing industry is subject
to BPT, BAT, NSPS, PSES, and PSNS regulations described in the Code of
Federal Regulations Title 40, Part 429, Subparts 0 and P and as updated in
the Federal Register (January 26, 1981).  The two subparts are:

          0,  Wood Furniture and Fixture Production Without Water Wash
              Spray Booth(s) and Without Laundry Facilities

          P.  Wood Furniture and Fixture Production With Water Wash Spray
              Booth(s)  or With Laundry Facilities

          The specific  regulations causing significant costs are BPT and
NSPS for Subpart 0 and  BAT and NSPS for Subpart P.  Each of these
regulations allow no discharge of process wastewater pollutants into
navigable streams.  BAT limitations for Subpart 0 equal BPT and thus
generate no additional  costs.  BPT limitations for Subpart P are estimated
to generate minimal costs.  Dischargers to POTWs meet no special standards
but must conform with general pretreatment standards provided in 40 CFR,
Part 403.13.

Industry Characteristics

          The two regulatory subcategories cover a diverse set of
establishments that produce upholstered and nonupholstered wood household
furniture; wood cabinets for televisions, radios, stereos, and sewing
machines; wood office furniture; wood public building and related
furniture; and wood partitions, shelving, lockers, and various other wood
fixtures.  Most of these special groups of producers are identified under
the standard industrial classification (SIC) major group No. 25.

          The wood household furniture segment has historically accounted
for the majority of production in this industry as well as the largest
number of plants.

          The furniture and fixture manufacturers have experienced little
or no growth in demand  in recent years.  Constant dollar sales for the
period of 1972 to 1980  for wood furniture, upholstered furniture and wood
cabinets have exhibited average annual changes of -0.2, 0.9 and -4.8
percent respectively.  Only moderate growth is anticipated for the future
and it is dependent on  real economic growth in the U.S., a decline in
interest rates and a recovery in the housing industry.
                                  W7.2-1

    -------
          The total  number of establishments covered by the SIC categoric
6,898, is larger than the number of wood product plants effected by wood
furniture and fixture regulations as some of these plants produce only
metal products.  The number that produce only metal products is unknown i
this study will use plant number estimates in development and economic
documents to estimate costs.  These sources indicate 6,097 plants would t
covered by the wood furniture and fixture products.

Pollutants and Sources

          Wastewater from wood furniture and fixtures manufacturing is
produced primarily by three processes:  glue cleanup, water wash spray
booths, and laundry operations.  Minor amounts of wastewater may also be
produced by bleaching and steaming operations, and blowdown from air
pollution scrubbers.

          The wastewater parameters of primary significance in this
industry include COD, total suspended solids, dissolved solids, pH,
temperature and phosphorus.  Parameters of secondary significance include
BOD, phenols, color, oil and grease and inorganic ions.

          For the purpose of establishing effluent limitations guidelines
the wood furniture and fixtures manufacturing industry has been divided
into two subcategories, based on water usage.  One subcategory includes
those facilities which do not have water wash spray booths or laundry
operations.  Facilities in this subcategory typically have small wastewat
loads.  The other subcategory includes facilities which have water wash
spray baths or laundry facilities (or both).  Facilities in either
subcategory may or may not include glueing, bleaching, steaming, or air
pollution scrubbing operations.

          Spray booths are used to filter air from finishing operations t
provide fire and health protection.  Dry booths, which use paper or
fiberglass materials to collect overspray, are.used in some plants.
However, water wash spray booths are generally preferred because of safet
and efficiency considerations.

          The characteristics of the wastewater discharged from spray
booths is dependent on the amount and type of overspray material capturec
by the water.  The amount of material captured is a function of the
efficiency of the booth in removing overspray from the air, the intensify
of usage of the spray booth, and the length of time between drainages.  1
type of material used is dependent primarily upon the particular type of
finishing operation being performed.  The pH of these wastewaters is
generally high because of alkaline dispersing agents which are used in
finishing materials.  Solids concentrations, COD and BOD are all high.
Wastewater from spray booths are typically drained weekly.

          Laundry facilities are used to clean rags used in finishing
operations.  Wastewaters from laundry machines have high pH and solids
concentrations from the addition of soda ash, caustics, clay, and strong
detergents to the wash water.  The wastewaters are highly colored and
contain high levels of COD and BOD.

                                  W7.2-2

    -------
          Glueing operations occur during furniture assembly, prior to
finishing.  The glues, which may be applied manually or by automatic
machines, may be solvent based or water based.  Small  volumes of wastewater
may be generated during clean up of glueing operations.  These waters have
high COD and volatile solids concentrations, low pHs and low phenol
concentrations.

          Bleaching may be included in finishing operations to remove
natural wood coloring by treating furniture pieces with a strong oxidizing
agent such as hydrogen peroxide.  Wastewaters from bleaching operations are
generally small in volume, but high in solids concentrations and pH.  They
may also contain low concentrations of phenol.

          Steaming may be used for wood bending operations.  Wastewaters
from steaming, which contain phenols, and high COD, BOD and solids
concentrations, are generally small in volume.

          Wet scrubbers are used at some plants to control air pollutant
emissions from boilers.  Continuous bleed off of scrubber waters may be
required to avoid high solids build up and a resulting loss of efficiency.
These wastewaters have high COD and solids concentrations.

Control Technologies

          Wastewater has not been a major concern in the wood furniture and
fixtures manufacturing industry.  The Development Document estimates that
90 to 96 percent of all furniture factories either discharge their
wastewaters to a municipal sewage system, contract to  have them hauled away
by a commercial disposal company or use a combination  of these disposal
methods.

          The Development Document identified existing treatment or
disposal technologies which could be used in this industry to achieve no
discharge of wastewater to surface waters.  The designated technologies
are:

          1.  discharge to a publicly owned treatment  works;
          2.  trucking wastewater to landfills;
          3.  incineration by spraying on hog fuel;
          4.  use of evaporation ponds; and
          5.  spray irrigation.

          All of the technologies, except spray irrigation, can be used by
both of the industry subcategories.  Spray irrigation  was considered
applicable to only facilities with laundry facilities  because their
wastewaters are sufficiently biodegradable.

          Table W7.2.1 summarizes the technologies required for BPT, BAT,
and NSPS.  The effluent limitations guidelines for the two subcategories
are summarized briefly below.
                                  W7.2-3

    -------






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          BPT.  Facilities without water wash spray booths or laundry
facilities are required to achieve no discharge using one or more of the
technologies listed above.  Facilities with water wash spray booths or
laundries are required to meet a less stringent standard because of the
adverse economic impact which could be expected from requiring these
facilities to meet a no discharge requirement.  Facilities in this
subcategory are required to meet an effluent quality limitation which can
be achieved with existing technology.  They are required to minimize the
effect of wastewaters on the environment by removing settled sludge and
allowing the water portion to settle before discharging.  Compliance cost
data are not available; however, costs are assumed to be minimal.

          BAT.  Facilities in both subcategories are required to achieve no
discharge by using one or more of the technologies listed above.

          NSPS.  Facilities in both subcategories are required to achieve
no discharge by using one or more of the technologies listed above.

          PSES and PSNS.  Facilities in both subcategories are required to
meet the general pretreatment requirements listed in 40 CFR Part 403.

Costing Methodology

          Costs for the furniture and fixture manufacturers were determined
from a model plant approach.

          The Development Document presents capital  and 0+M costs for four
model plants.  One model plant represents the subcategory of facilities
without water wash spray booths or laundry facilities.   Three model plants
represent the subcategory of facilities with water wash spray booths or
laundry facilities.

          Cost estimating equations of the form y =  Ax  were used to
estimate total costs (y represents capital or 0+M costs, while x represents
plant capacity).  Data relating plant production to  wastewater generation
were not available from the Development Document; consequently,  plant
capacity has been expressed as gallons of wastewater per day.

          The cost estimating equations for each model  plant,  costing
assumptions, and the method for assigning size categories to model  plants
are summarized in the appendix.

          The cost of compliance for wood furniture  and fixture
manufacturers are presented in Table W7.2.2.   They are based on  an  industry
population of 6,097 plants of which only about 10 percent were estimated to
be direct dischargers.
                                  W7.2-5

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                               W7.2-6

    -------
                   Chapter W7.3  Gum and Wood Chemicals
Regulations

          Effluent regulations for BPT were promulgated in interim final
form on April 30, 1976.  On the same date, effluent regulations were
proposed for BAT, NSPS, and pretreatment for new sources.   Costs are based
on the promulgated BPT regulations and the other proposed regulations.
This industry has been exempted from additional federal guidelines under
Paragraph 8 of the 1976 settlement agreement with NRDC.

Industry Characteristics

          While the majority of products included in this  chapter are
classified under SIC 2861, some products are also classified under SIC 2821
or SIC 2899 and some of the establishments producing these products are
almost certainly classified the same way.

          The Gum and Wood Chemicals Industry has been divided, for
pollution control purposes, into six categories, as follows:

             Charcoal and charcoal briquets
             Gum rosin and turpentine
             Wood rosin, turpentine, and pine oil
             Tall oil rosin, fatty acids,  and pitch
             Essential oils
             Rosin derivatives.

          Charcoal and Charcoal Briquets.   There are no wastewater
discharges from the industry subsector, and it will not be discussed in
detail, although it represents about 50 percent of the value of shipments
of SIC 2861 establishments.

          Gum Rosin and Turpentine.   These products are produced by
distillation of crude oleoresin (gum) collected from scarified longleaf and
slash pine trees in southeastern United States.  These plants are primarily
located in Georgia or Alabama.  It is estimated that 90 percent of the
capacity is in establishments classified in SIC 2861 and 10 percent in SIC
2821.

          The annual  production of gum rosin and turpentine has been
declining for several years.  The collection of gum oleoresin is a
labor-intensive operation, and this  industry is expected to continue to
decline.

          Wood Rosin, Turpentine and Pine  Oil.   These products are obtained
by distillation of oleoresin extracted from chipped stumps remaining after
the harvesting of southern pine forests.   Plants in this sector are located


                                  W7.3-1

    -------
in Florida, Georgia, and Mississippi.   It is estimated that 40 percent of
production is in plants classified in  SIC 2861, 40 percent in SIC 2899, a
20 percent in SIC 2821.

          The annual production of wood rosin and steam-distilled
turpentine (from stumps) has also been declining.  The availability of
stumps of a size that is economic for  collection is decreasing as the
inventory of sawmill size pine trees is diminishing in the Southeast.  Th>
production of natural pine oil from pine stumps is also declining, being
displaced by the production of synthetic pine oil from turpentine.

          Tall Oil Fractionation.  Crude tall oil is a by-product of the
kraft pulping process, although it is  classified by the Bureau of the
Census as a SIC 2861 product.  The fractional distillation of crude tall
oil yields tall oil  rosin, tall oil fatty acids, and tall oil pitch.  It
estimated that about 80 percent of the fractionation of crude tall oil
occurs in establishments assigned to SIC 2861 and about 10 percent each i
establishments assigned to SIC 2821 and SIC 2899.

          As long as kraft paper is produced from pine trees, a potential
supply of tall oil rosin and tall oil  fatty acids should be available.
This product is gradually replacing both gum rosin and wood rosin.

          Essential  Oils.  These products are obtained by the steam
distillation of scrap wood fines of the appropriate wood.  The only
essential oil included in the EPA documentation is cedarwood oil, which i
classified in SIC 2899.

          Rosin Derivatives.  Most rosin is chemically modified to improv'
some of its properties prior to its ultimate use.  The most common chemic
modifications are probably condensation reactions with unsaturated organi
acids or esterification with mono- or  polyhydric alcohols.  One reason fo
the decline in demand for rosin is that 30 pounds of fortified rosin is a:
effective in sizing paper as is 100 pounds of unmodified rosin.  It is
assumed that about 50 percent of rosin derivatives are produced in
establishments classified in SIC 2821  and the remainder in establishments
classified in SIC 2899.

Pollutants and Sources
          The pollutant characteristics for the six categories of gum and
wood chemicals are outlined below.

          Char and Charcoal.   No wastewater discharge has been identified
from this process since it involves high temperature kiln distillation.
One possible discharge is storm water runoff which carries suspended
solids.  This discharge can be controlled, however, by proper materials
handling systems that reduce dust and solid materials in the plant area.

          Gum Rosin and Turpentine.  Three wastewater sources have been
identified in this process.  These are (1) rosin washing to remove solubl
impurities, (2) distillate condensation, and (3) brine used to dehydrate


                                  W7.3-2

    -------
the gum rosin.  This waste load is largely generated during washing
operations.

          Wood Rosin, Turpentine, and Pine Oil.  Process wastewater
includes stripping as well as vacuum and steam condensates from the
distillation operation.  Another possible source of wastewater is from the
washing of stumps for dirt removal.  In a properly operated plant, however,
this washwater is returned to a settling pond and reused after the solids
have settled out.  The solids are then periodically removed to a land fill.

          Tall Oil Rosin, Pitch, and Fatty Acids.  This is a highly
efficient distillation process, with the primary source of wastewater being
an acid wash given to the crude tall oil.  Additional  wastewater is
accumulated during washdowns of process equipment.

          Essential  Oils.  This process generates large amounts of
wastewater since it is based primarily on steam distillation and the use of
separators to recover the desired oils from the steam condensate.  Large
amounts of wastewater are involved, with a high waste load in the water.

          Rosin Derivatives.  These processes produce wastewater from a
variety of point sources, including water of reaction, spray steam, vacuum
jet steam, and condenser cooling water.

Control Technology

          The Development Document identified 139 facilities in this
industry category and found that approximately one-third used municipal
sewage plants and were not covered by the final effluent guidelines.
Approximately 20 percent of the plants had treatment ponds with no direct
discharge, while 8 percent used the effluent for land irrigation in remote
areas.  Only approximately four percent had point-source discharges, and of
these, eighty percent had no additional requirements to meet the BPT
guidelines.

          Treatment of wastewater consists of both in-plant and end-of-pipe
treatment.

          In-Pi ant Treatment.  In-plant treatment techniques generally
amount to more efficient housekeeping practices such as:

          •  Separating drainage lines so that effluent not requiring
             treatment (i.e. storm water) is handled separately.

          0  Improved efficiency of equipment washing procedures such as
             the use of several small quantities of rinsewater which can be
             recycled into the process.

          •  Use of techniques such as a squeegee to remove material  before
             rinsing.
                                  W7.3-3

    -------
          End-of-Pipe Treatment.   Applicable end-of-pipe treatment
processes include the use of primary clarifiers, aerated lagoons, oxidati<
ponds, dissolved air flotation, and combinations of these.   Additional
improvement in wastewater quality can be obtained through the use of
filtration or carbon adsorption of the biological treatment plant effluen-

Costing Methodology

          The cost of controlling the waste load in the effluent for five
categories of the Gum and Wood Chemicals Industry has been estimated at
three levels of control  (BPT, BAT, and NSPS).  To obtain the estimate,
model systems were developed for the various subcategories, and cost
estimates made based on  end-of-pipe treatment.   In-plant costs were not
included because of their highly variable nature depending upon the purpo
for which the plant was  constructed.

          Costs for end-of-pipe technologies were applied to the model
plants, as applicable.  Of the 51 plants included in the five subsectors
when the regulations were promulgated, BPT costs were applicable to only
one producer of rosin derivatives.  BAT costs,  however, will apparently bi
applicable to two wood chemicals plants, ten tall oil fractionation plant
and eight rosin derivatives plants.  All other  plants were in compliance
with BAT regulations which were expected to be  promulgated in 1980.  It i
assumed that all plants  will be in compliance by 1984.

          Costs derived  for this industry are summarized in Table W7.3.1.
                                  W7.3-4

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                 Chapter W7.4  Pulp, Paper and Paperboard
Regulations

          Effluent control regulations affecting the pulp, paper and
paperboard industry arise from the Clean Water Act and are codified in the
Code of Federal  Regulations, Title 40, Chapter 1, Subchapter N, Parts 430
and 431.  Amendments to these regulations are announced in the Federal
Register with the following announcements being critical  for limitation
guidelines on best practical technology (BPT), best available technology
(BAT), new source performance standards (NSPS), pretreatment standards for
existing sources (PSES) and pretreatment standards for new sources (PSNS).

          •  39 FR 18747, May 29, 1974:  Promulgated BPT guidelines for
             Part 430, Subparts A-E, and Part 431, Subpart A

          •  42 FR 1407, January 6, 1977:  Promulgated BPT'guide!ines for
             Part 430, Subparts F-V

          t  47 FR 52006, November 18, 1982:   Promulgated BPT guidelines
             for certain subcategories of 40  CFR Part 430 and Promulgated
             BAT, NSPS, PSES, and PSNS guidelines for 24 of 25
             subcategories, (supersedes 46 FR 1430)

          t  47 FR 52006, November 18, 1982:   Proposed BAT and NSPS
             guidelines to limit PCBs where fine and tissue papers are
             made from deinked wastepaper.

          Effluent control regulations exist  for 26 industry subparts or
subcategories within the pulp, paper, and paperboard industry.  These
include:
430 CFR

A.  Unbleached Kraft
B.  Semi-Chemical
C.  [Reserved]
D.  Unb'leached Kraft-Neutral
    Sulfite Semi-Chemical
    (Cross Recovery)
E.  Paperboard from Wastepaper
F.  Dissolving Kraft
G.  Market Bleached Kraft
H.  BCT Bleached Kraft
I.  Fine Bleached Kraft
J.  Papergrade Sulfite
    (Blow Pit Wash)
K.  Dissolving SUlfite Pulp
L.  Grounded-Chemical -Mechanical
M.  Groundwood-Thermo-Mechanical
N.  Groundwood-CMN Papers
0.  Groundwood-Fine Papers
P.  Soda
Q.  Deink
R.  Nonintegrated-Fine Papers
S.  Nonintegrated-Tissue Papers
T.  Tissue from Wastepaper
U.  Papergrade Sulfite (Drum Wash)
V.  Unbleached Kraft and Semi-
    Chemical
W.  Wastepaper-Molded Products
X.  Nonintegrated-Lightweight Paper
Y.  Nonintegrated-Filter and Woven
Z.  Nonintegrated-Paperboard
431 CFR
    Builders1
    Felt
Paper and Roofing
                                  W7.4-1

    -------
Industry Characteristics

          A total  of 674 operating facilities have recently been identifi
as pulp, paper and paperboard producers.   The industry is highly
diversified utilizing both wood and nonwood pulp and paper materials to
produce a wide variety of products including pulp, newsprint, printing an
writing papers, unbleached and bleached packaging
glassine, greaseproof papers, vegetable parchment.
papers,
board.
bleached
and
unbleached paperboard, felts
 papers,  tissue  papers,
,  special  industrial
,  and  building paper  and
          For analytical purposes, the industry is divided into three maj
segments: integrated, secondary fibers and nonintegrated mills.  Mills
in which pulp alone or pulp and paper or paperboard are manufactured
on-site are referred to as integrated mills.   Those mills in which paper
paperboard are manufactured but pulp is not manufactured on-site are
referred to as nonintegrated mills.  Mills which use wastepaper as the
primary raw material to produce paper or paperboard are referred to as
secondary fibers mills.  While the virgin fiber source is predominantly
wood (98 percent), secondary fiber sources such as wastepaper have gained
increasing acceptance.  Wastepaper recently accounted for over 22 percent
of the fiber used in the United States.

          In 1980, the value of shipments by the pulp, paper and paperbo?
industry was estimated at $30.7 billion dollars.  Total employment was
220,000 and the quantity of shipments was 70.9 million short tons.  Basec
on 706 facilities, shipments per plant would average about $43 million or
100,000 short tons in 1980.  Shipments per employee would equal $140,000
about 320 short tons.

          The plants in the industry are also classified in SIC codes.
These categories and the distribution of plants and shipments are as
follows:
SIC Code             Title

  2611       Pulpmills
  2621       Papermills
  2631       Paperboard mills
  2661       Building paper & building
                                    % of Plants

                                          6
                                         50
                                         36
                                          8
                                        TOU
                                           % of Shipment

                                                11
                                                54
                                                33
                                                 2
                                               TM
          Historically, the pulp, paper and paperboard industry has been
a solid performer with stable annual growth rates.  The growth has evolve
from a strong domestic market and active exporting.  The current recessic
(1981-82) has depressed growth recently, but the overall long-term trend
favorable.
Pollutants and Sources

          The production of pulp,
general manufacturing processes:
                          paper, and paperboard involves four
                          (a) raw material preparation, (b)
                                  W7.4-2

    -------
pulping, (c) bleaching, (d) papermaking.   Water is used in each of the four
major manufacturing processes as a medium of transport, a cleaning agent,
and as a solvent or mixer.
          Depending on the form in which the raw materials arrive at the
mill, log washing, bark removal, and chipping may be employed to prepare
wood for pulping.   These processes can require large volumes of water.   The
use of dry bark removal techniques or the recycle of wash water or water
used in wet barking operations significantly reduces water consumption.

          Pulping  is the operation of reducing a cellulosic raw material
into a pulp suitable for further processing into paper or paperboard or  for
chemical conversion.  The primary types of pulping processes are:

          (a)  Mechanical pulping (groundwood); and

          (b)  Chemical pulping (alkaline, sulfite, or semi-chemical
               processes).

          After pulping, the unbleached pulp is brown or dark colored due
to the presence of lignins and resins or because of inefficient washing  of
the spent cooking  liquor from the pulp.  In order to remove these color
bodies from the pulp and to produce a light colored or white product, it is
necessary to bleach the pulp.

          In stock preparation, the pulp is resuspended in water.  Further
mixing, blending,  and the addition of non-cellulosic materials are
necessary to prepare the stock for making most paper or board products.
The various papermaking processes have basic similarities regardless  of  the
type of pulp used  or the end-product manufactured.  A layer of fiber is
deposited from a di.lute water suspension of pulp on a fine screen, called
the "wire."  This  layer is then removed from the wire, pressed, and dried.
The two basic types of machines used to make paper or paperboard are a
Fourdrinier machine or a cylinder machine.

          As indicated above, the pulp, paper, and paperboard industry is a
high water-use industry.  Major uses of water are similar throughout the
industry although  the amount used varies from segment to segment.  The two
methods of wastewater discharge include direct discharge to navigable
waters and indirect discharge to a publicly owned treatment works (POTW).
At some mills, recycle systems or evaporation techniques are used so  that
no wastewater is discharged.  It has been estimated that wastewater
discharges from the industry total 4.2 billion gallons per day.   The
wastewater characteristics differ from subcategory to subcategory due to
the varying nature of processes employed and/or products manufactured.   In
general, the wastes are complex mixtures of natural  and synthetic organic
materials and inorganic chemicals.  Pulping wastes,  which are the major
portion of the industry's water pollution, come from grinding,  digester
cooking, washing,  bleaching, thickening, deinking, and defibering.   These
wastes contain sulfite liquor, fine pulp, bleaching  chemicals such as zinc
hydrosulfite and chlorine, mercaptans, sodium sulfides, carbonates and
hydroxides, sizing, casein, clay, ink, dyes, waxes,  grease,  oils, fibers,


                                  W7.4-3

    -------
and chlorophenolics from biocide and slimicide formulations.  Papermill
wastes originate in water which passes through the screen wires, showers,
and felts of the paper machines, beaters, regulating and mixing tanks, anc
screens.  The paper machine wastes contain fine fibers, sizing, dye, and
other loading material.  The most important pollutants associated with the
production of pulp, paper, or paperboard which are controlled by BPT, BAT,
NSPS, PSES, and PSNS regulations are:

          1. Toxic pollutants—chloroform, zinc, trichlorophenol, and
             pentachlorophenol; and

          2. Conventional po!lutants--BOD5_, TSS, and pH.

Control Technologies

          The two major technological approaches used to reduce wastewater
and/or wastewater pollutant discharge in the pulp, paper, and paperboard
industry are:  (a) production process controls; and (b) effluent treatmen'
technology.  Production process controls are those technologies implement*
in-plant to reduce the effluent volume and pollutant loading discharged
from the manufacturing facility.  Effluent treatment technologies are tho:
end-of-pipe treatment systems used to reduce the discharge of pollutants
contained in mill effluents.  In most instances, pollution abatement
programs developed for use at individual mills include both approaches.

Production Process Controls.  Available methods for reduction of pollutan'
discharges by internal measures include effective pulp washing, chemicals
and fiber recovery, treatment and reuse of selected waste streams and
collection of spills and prevention of "accidental discharges."  Internal
measures are essentially reductions of pollutant discharges at their
origins and usually result in the recovery of chemicals, by-products, and
the conservation of heat and water.

Effluent Treatment Technologies.  Effluent treatment technologies are tho1
processes which are employed after the effluent leaves a mill for the
reduction of suspended solids and BOD5_ and adjustment of pH before it
enters  the receiving waters.  Many types of wastewater treatment systems
are employed at mills  in the pulp, paper, and paperboard industry and can
include:
   •  Screening
   •  Pumping stations
   •  Primary clarification
   • _ Sludge lagoon
   • ' Biological treatment
      -  Aerated stabilization basis (ASB)
      -  Activated sludge
      -  Oxidation basins
Equalization basins
Secondary clarification
Neutralization
Flotation thickening
Sludge dewatering
Foam control
Outfall sewers
Diffusers
                                  W7.4-4

    -------
Control Technologies for Compliance with Regulations

          The control technologies are based on regulations in the Code of
Federal Regulations, revised as of July 1, 1981, and promulgated and
proposed regulations in the Federal Register of November 18, 1982.  The
regulations promulgated in the Federal Register notice include 8PT and
revised BAT regulations and supersede prior NSPS, PSNS, and PSES
regulations for the pulp, paper, and paperboard industry.  The proposed FR
regulations are to control PCBs from deinked wastepaper.  Table 1 (in the
Appendix) lists the status of the effluent limitations guidelines,
pretreatment standards, and new source performance standards which were
used in selecting control technologies for compliance.

          BPT Control Technology.  The control  technologies selected for
compliance with BPT effluent limitations are a combination of in-plant and
end-of-pipe control technologies.  In-plant technologies can include
additional spill collection, low volume-high pressure cleaning showers,
collection and reuse of vacuum pump waters, and water reduction.
End-of-pipe technologies include bar screens, mechanical clarifiers,
emergency spill basins, one and two stage biological treatment, foam
control, sludge lagoons and sludge dewatering.   The specific technologies
used for coating of the various subcategories are listed in the appendix to
this chapter.  It should be noted that all  of the end-of-pipe technologies
developed for Phase I and II subcategories would probably not be
implemented by a mill.   The end-of-pipe technologies developed are merely
guidelines for the types of technologies that work for a subcategory.

          The pollutant parameters regulated by BPT are BOD, TSS, and pH
for all subcategories and zinc for those mills  using zinc hydrosulfite as a
bleaching agent in the  manufacturing process in the Grounded-Chemical-
Mechanical, Groundwood-Thermo-Mechanical, Groundwood-CMN Papers,  and
Groundwood-Fine Papers  Subcategories.

          BAT Control Technology.  In general,  BAT uses BPT as a basis for
further improvements.With one exception,  the  additional technology
considered BAT is chemical substitution for the control of toxic
pollutants.  Slimicides and biocides containing trichlorophenol  and
pentachlorophenol can be replaced with formulations that do not contain
toxic chemicals.  The exception is the proposed control of PCBs for the
Deink-Fine and Deink-Tissue subcategories which requires the best
performing existing technology for all Deink subcategory mills.

          The pollutant parameters proposed for regulation by BAT are
trichlorophenol and pentachlorophenol for all subcategories; zinc for the
Groundwood Subcategories; chloroform for the Dissolving Kraft,  Market
Bleached Kraft, BCT Bleached Kraft, Fine Bleached Kraft, Papergrade Sulfite
(both drum wash and blow pit wash), Dissolving  Sulfite Pulp, Soda,  and
Deink Subcategories; and PCB (1242) for the Deink Subcategories.   In the
Groundwood Subcategories, the proposed BAT limitations for zinc are
identical to BPT limitations for control of this toxic metal.   It has  been
determined that zinc discharges from mills  in the Groundwater Subcategories
have been greatly reduced to levels in compliance with BPT effluent


                                  W7.4-5

    -------
limitations guidelines through the substitution of the bleaching chemical
sodium hydrosulfite for zinc hydrosulfite.  The control of chloroform is
based on the application and proper operation of biological treatment,
which forms the basis of existing BPT regulations.  The necessity for
additional end-of-pipe treatment or production process controls is thus nc
required except for best performing existing technology to control PCBs
from Deink mills.

          NSPS Control Technology.  The control technology required for
compliance with New Source Performance Standards (NSPS) is the best
available demonstrated technology.  These include in-plant and end-of-pin*
treatment technologies for the integrated segment, nonintegrated segment,
and secondary fibers segment of the pulp, paper, and paperboard industry.

          The pollutant parameters promulgated for regulation by NSPS are
BOD, TSS, pH, trichlorophenol and pentachlorophenol for all subcategories
zinc for the Groundwood Subcategories, and chloroform for the Dissolving
Kraft, March Bleached Kraft, BCT Bleached Kraft, Fine Bleached Kraft,
Papergrade Sulfite (both drum wash and blow pit wash), Dissolving Sulfite
Pulp, Soda, and Deink Subcategories.  NSPS pollutant parameter regulation;
are proposed for PCBs for the Deink Subcategory.  Significant costs will
originate only from the control of BOD, TSS, and pH based on information
the November 18, 1982 Federal Register.

          PSES Control Technology.  The treatment technology for complyin<
with Pretreatment Standards for Existing Sources (PSES) is based on
chemical substitution.  Slimicide and biocide formulations containing
trichlorophenol and pentachlorophenol can be replaced with formulations
that do not contain these toxic pollutants.  Zinc hydrosulfite, a chemica
used to bleach groundwood pulps, can be replaced with sodium hydrosulfite

          The pollutant parameters proposed for regulation by PSES are
trichlorophenol and pentachlorophenol for all subcategories and zinc for
the Groundwood Subcategories.

          PSNS Control Technology.  The treatment technology required for
compliance with Pretreatment Standards for New Sources (PSNS) is the same
as that for PSES described above.  The pollutants controlled are also the
same as those for PSES listed above.

Costing Methodology

          Water pollution control costs to the pulp, paper, and paperboan
industry for compliance with effluent limitations and new source
performance standards' were obtained exogenously from the Economic Analyse
Development Documents, and the Federal Register.  These documents cover
various guidelines, industry subcategories and specific phases of
regulatory action'including:

          •  BPT - Phase I Subcategories A-E and Builders' Paper
          t  BPT - Phase II Subcategories F-V Except Builders1 Paper
          •  BPT - Four new proposed subcategories
          •  BAT - Proposed PCB standards for the Deink Subcategory

                                  W7.4-6

    -------
          t  NSPS - BODS, TSS, and pH standards for all subcategories
          •  BAT except Deink, PSES & PSNS - Regulatory guidelines
             generally cause minimal or insignificant costs

          The exogenous costs of compliance developed from the reports and
used as input for the ABTRES costing model are presented below.  The
exogenous cost data are primarily based on existing plant data that were
obtained from EPA "308" surveys.  Model plants were not utilized in cost
aggregation.  These data are net costs as costs for capital-in-place were
also deducted on an exogenous basis.

                            Base year       Capital costs        O&M costs
     Regulations             of costs        ($ million)        ($ million)

Phase I - BPT                  1971              368.1             51.3
Phase II - BPT                 1975            1,672.0            191.0
Wastepaper molded-BPT          1982                8.4             0.72
Deink-BAT                      1982               29.4             3.21
NSPS                           1982               27.7             3.51
BAT                             —          	insignificant	
PSES                            —          	insignificant	
PSNS                            —          	insignificant	
The cost of compliance for the pulp, paper and paperboard industry derived
from the previous input data are presented in Table W7.4.1.
                                  W7.4-7

    -------
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    -------
              Chapter W8.  Foods and Agricultural  Industries
          For the purpose of this report the Foods and Agricultural
Industries are defined to include those establishments which prepare or
process farm or ranch products for delivery to an ultimate consumer.  Farms
and ranches are specifically excluded;  these are discussed in Chapter 10
under Nonpoint Sources.   The industries covered in this chapter are:

             Grain Milling
             Sugar Processing
             Canned and Preserved Fruits and Vegetables
             Canned and Preserved Seafood
             Dairy Products Processing  Industry
             Feedlots Industry
             Meat Products Processing
             Leather Tanning and Finishing Industry

          Costs for the abatement of water pollution for these sectors are
summarized in Table W8.   These costs and other data are repeated below in
the respective sections  of this chapter, together with the assumptions
specific to the industry and other details.
                                   W8-1

    -------
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    -------
                        Chapter W8.1  Grain Milling
Regulations
          In August, 1979, BCT was defined as being equal to BAT for all
but one of the subcategories in this industry.  BAT regulations for bulgur
wheat flour milling were found to be unreasonable and were suspended.
Pending revision of these regulations and the publication of new cost data,
this chapter has not been updated.  Only BPT and NSPS regulations have been
costed for this chapter.

Grain Milling Industry (Phase I)

          For purposes of establishing water effluent guidelines, Phase I
of the grain milling industry was divided into four major subcategories:
wet corn milling, dry corn milling, bulgur wheat flour milling, and
parboiled rice milling.  Two other subcategories, normal wheat flour
milling and normal  rice milling, have been excluded because they do not use
process water.

          Industry Characteristics.   Wet corn milling comprises three
basic process operations:  mi 11 ing, starch production, and syrup
manufacturing.  The finished products of starch and corn sweeteners are
used for paper products, food products, textile manufacturing, building
materials, laundries, home uses, and miscellaneous operations.

          Dry corn (Hilling processes separate the various fractions of
corn, namely the endosperm, hull, and germ.   These fractions are later
ground and sifted after separation.  The final products include:  corn
meal, grits, flour, oil, and animal feed.

          Bulgur wheat flour milling produces parboiled, dried, and
partially debranned wheat for use in either cracked or whole grain form.
Bulgur is produced primarily for the Federal  Government as part of a
national effort to utilize surplus wheat for domestic use and for
distribution to underdeveloped countries.

          Parboiled rice milling utilizes rice that is carefully cleaned,
parboiled by soaking in water, and then cooked to gelatinize the starch.
After cooking, the water is drained and the parboiled rice is dried before
milling.  The bran and germ are later separated from the milled rice.  The
final product has superior nutritive qualities because vitamins from the
bran are forced into the endosperm.

          Shipments of wet corn milling products are expected to increase
at an annual rate of 7.5 percent.  The use of dry corn milling products
directly in foods has declined significantly over the past 20 years but
this decline has been offset by the growing use of the products as


                                  W8.1-1

    -------
ingredients in processed foods.   Total  production has remained about
constant.  Consumption of bulgur wheat  flour milling products has been
increasing in developing nations due to the high nutritional  values of
bulgur wheat.  Rice milling including parboiled products are  about 60
percent exported and 40 percent used for domestic trade.  An  increase in
rice mill products of 2.3 percent is expected annually from 1976 to 1985.

          Pollutants and Sources.  Principal wastewater sources in wet co
milling are modified starch washing, condensate from steepwater
evaporation, mud separation, and syrup  evaporation.   Dry corn milling
process wastes originate from washing of corn and infrequent  grain rail  c<
washing.  Bulgur wheat flour milling process wastewater stems from steami
and cooking of bulgur, although these quantities are relatively small.
Parboiled rice milling process wastewater stems from steeping or cooking
operations, and at least one plant uses wet scrubbers for dust control,
which generates an additional source of wastewater.

          The basic parameters used to  define wastewater characteristics
are BODc, suspended solids, and pH.  About one-fourth of the  wet corn
milling plants discharge directly into  surface water.  The majority of thi
plants in the other subcategories discharge into municipal systems.

          Control Technology and Costs.  Except for wet corn  milling,
little attention has been focused on either in-plant control  or treatment
of wastewaters.  In many instances, the treatment technologies developed
for wet corn milling can be transferred to the other industry
subcategories.  Current in-plant control consists of water recycling,
cooling systems (barometric condensers), and some plants use  biological
treatment (activated sludge).

          Best practicable technology for the four subcategories consists
of the following:

          •  Wet corn milling—Equalization of flows, activated sludge
             treatment, and stabilization lagoon

          •  Dry corn milling--Primary  sedimentation and activated sludge
             treatment

          •  Bulgur wheat flour milling—Activated sludge treatment

          t  Parboiled rice milling—Activated sludge treatment.

          New source performance technology for the  four subcategorie.s is
deep bed filtration in addition to BPT.

          Since the wet corn milling industry contributes the largest
amount of wastewater discharges, control costs for this industry are of
primary concern.
                                  W8.1-2

    -------
Grain Milling Industry (Phase II)

          For purposes of establishing water effluent guidelines, the Phase
II segments of the grain milling industry consist of three major
subcategories:  animal feed, breakfast cereal  (ready-to-eat and hot
cereal), and wheat gluten and starch.  Animal  feed and hot cereal mills do
not generate any significant process wastewaters.

          Industry Characteristics.   For the  purpose of estimating costs,
the ready-to-eat cereal subcategory has been divided according to average
daily production into plant classes consisting of:  small (91 metric tons
or 100 short tons per day), medium (230 metric tons or 250 short tons per
day), and large (540 metric tons or 600 short  tons per day).   The division
of the wheat gluten and starch subcategory daily production values is:
small (30 metric tons or 33 short tons per day), medium (45 metric tons or
50 short tons per day) and large (60 metric tons or 66 short tons per day).

          The animal feed, breakfast cereal, and wheat gluten and starch
industries all utilize products from the basic grain processing mills for
raw materials.  Grain and grain milling by-products are the chief
ingredients in animal feed.  The manufacture of breakfast cereals utilizes
both milled and whole grain, particularly corn, wheat, oats,  and rice.
Wheat gluten and starch manufacturing employs  wheat flour as its raw
material.

          Animal feed manufacturing comprises:  ingredients mixing, meal
production, pelleting, cooling and drying pellets, rolling, and finally,
formation of granules.  Of all the cereal grains produced in the U. S.,
only about 15 percent is used directly as food for human consumption.  The
vast majority of the grain harvest is used to  feed poultry and livestock.

          Breakfast cereals can be broadly classified as either hot cereals
or ready-to-eat cereals.  Hot cereals require  cooking before serving and
are normally made from oats or wheat.  Ready-to-eat cereal manufacturing
methods vary depending on the type of cereal.   Raw materials include whole
grain wheat and rice, corn grits, oat flour, sugar, and other minor
ingredients.  The general processes involved include ingredient mixing,
cooking, drying, forming (either flaking or extruding), toasting or
puffing, and vitamin addition.

          The wheat starch industry may be properly termed the wheat gluten
and starch industry, as the gluten presently brings a higher economic
return than the starch.  Basically, wheat starch manufacturing involves the
physical separation and refinement of the starch and gluten (protein)
components of wheat flour.

          Pollutants and Sources.  Animal feed and hot cereal  manufacturing
plants utilize little or no process water and  generate no wastewaters.
Water is used quite extensively in ready-to-eat cereal manufacturing
plants.  The various operations where water is used include:   grain
tempering, flavor solution makeup, cooking, extrusion, and coating.   Water
is also used for cooling, flaking, and forming rolls; extruders; and for


                                  W8.1-3

    -------
wet scrubbers.  Most of the unit processes do not result in process
wastewaters.  Only the cooking operation in shredded cereal manufacturing
generates a continuous or semi-continuous waste stream.  In wheat starch
manufacturing, process water is used for dough making, dough washing,
backwashing of screens, and counter-current washing of centrifuge
discharges.  Water is also used for plant cleanup and for auxiliary syster
such as boiler feed water and cooling.

          The basic parameters used to define wastewater characteristics
are BODr, suspended solids, and pH.  For all practical purposes, all of tt
plants in both the ready-to-eat cereal and wheat gluten and starch
categories discharge to municipal systems.

          Control Technology and Costs.  The costs for the industry
categories Tn this group include increased user charges for plants
discharging to municipal sewerage.  New plants may be expected to pretrea
their process waste before discharging to municipal systems or to provide
secondary treatment.

          Best practical technology (BPT) for the ready-to-eat cereal
subcategory is activated sludge treatment and sedimentation.  Activated
sludge treatment and equalization is required for wheat gluten and starch
plants.

          Abatement costs for Phases I and II of the Grain Milling Indust
are combined in Table W8.1.1.
                                  W8.1-4

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    -------

    -------
                      Chapter W8.2  Sugar Processing
Regulations
          BPT standards have been promulgated for the seven subcategorles
included in this industry, although they were later revoked for one of the
subcategories.  BAT, NSPS, and pretreatment standards have been promulgated
for three of the subcategories but only proposed for the other four.  This
chapter has not been updated pending promulgation of the remaining
regulations and publications of applicable cost data.

Sugar Processing, Phase I—Cane Sugar Refining

          Industry Characteristics.  Raw sugar consists primarily of
crystals of sucrose with small percentages of dextrose and levulose.
Various impurities such as particulates, organic and inorganic salts, and
microorganisms are also present.   A film of molasses is contained on raw
sugar.  Crystalline raw sugar is  washed to remove part of the molasses
film, put into solution, taken through various purification steps, and
finally recrystallized.

          The major processes involved in cane sugar refining are:  (1)
melting, (2) clarifying, (3) decolorizing, (4) evaporating, (5)
crystallizing, and (6) finishing.  Melting is the first step in which raw
crystals are put into solution by heating; this syrup is then fine screened
to remove insoluble materials.  In the clarifying step, screened melt
liquor which still contains fine  suspended and colloidal matter is treated
chemically to cause these to precipitate.  Decolorizing involves the
physical adsorption of impurities; bone char is the primary adsorbent used
to remove color.  The object of the evaporating process is concentration of
the decolorized sugar liquor and  sweet water (water containing syrup); this
is done in continuous evaporators.  Crystallizing of the concentrated sugar
liquor and sweet waters is done in batch evaporators called vacuum pans.
Finishing is a drying or granulation step in which moisture is removed and
the crystals are separated and later cooled and fine screened.

          The molasses produced as a by-product of cane sugar refining is
used as a sweetener, as an ingredient in animal feed, for making alcohol,
for organic chemicals, and for other uses.

          The cane sugar refining industry consists of two subcategories:
(1) crystalline cane sugar refining, and (2) liquid cane sugar refining.
Liquid sugar production is essentially the same as crystalline sugar
production except that the primary product is not recrystallized.

         The domestic sugar industry in recent years has not been very
profitable with the exception of  1974, when the prices of sugar were very
high.  Currently, there is very keen competition from foreign sugar


                                  W8.2-1

    -------
producers.  Although a price-support system has recently been activated,
resurgence of the industry is not expected.  Ratner, it is believed that
this will  protect the industry as it is and will  not encourage increased
acreage of cane or the building of new sugar mills.   As a matter of fact,
in a period from 1973 through 1976, three mills closed in Louisiana, thre
in Hawaii, and the rated capacity in Puerto Rico  declined.  For these
reasons, the study used a zero growth rate.

          Pollutants and Sources.  Major process  wastewaters from cane
sugar refining include char (activated carbon process water from nonchar
refineries) wastewater from decolorization.  Most of the waste streams
produced in other processes are recovered as low-purity sweet water.
Wastewater from barometric condenser cooling is usually recirculated and
represents a minor waste stream.

          Wastewater contaminating pollutants are associated with (1) the
water used as an integral part of the process (primarily the decolorizing
steps of either bone char or activated carbon washing), (2) the result of
entrainment  of sucrose into barometric condenser cooling water, and (3)
the water used to slurry the filter cake.

          Parameters under effluent guidelines for meeting BPT, BAT, and
NSPS include BODc, suspended solids, and pH.  Additional parameters of
significance to the industry include COD, temperature, sucrose, alkalinit
total coliforms, fecal coliforms, total dissolved solids, and nutrients.

          Currently, 50 percent of crystalline sugar refineries and 60
percent of liquid cane sugar refineries discharge into municipal systems.
On an average 38,400 liters per metric ton (9,200 gallons per short ton)
wastewater is discharged from crystalline sugar refineries; the
corresponding figure is 18,800 liters per metric  ton (4,500 gallons per
short ton) from liquid cane sugar refineries.

          Control Techno!ogy.  Current technology for control and treatme
of cane sugar refinery wastewaters consists primarily of process control
(recycling and reuse of water, preventing sucrose entrainment in barometr
condenser cooling water and recovering sweet waters), impoundage (land
retention), and disposal of process water to municipal sewerage systems.

          Best Practicable Technology (BPT) consists of a combination of
in-plant changes and end-of-pipe treatment.  In-plant changes include:  (
collection and recovery of all floor drainage, (2) use of improved
baffling systems, demisters, and/or other control devices in evaporators
minimize sucrose entrainment in barometric condenser cooling water, and (
dry handling of filter cakes after desweetening,  with disposal  to sanitar
landfills, or complete containment of filter cake slurries.  End-of-pipe
treatment consists of biological  treatment of all wastewater discharges
other than uncontaminated (noncontact) cooling water and barometric
condenser cooling water.

          Best Available Technology (BAT) is essentially the same as BPT
but, in addition to BPT, the following are applicable:  (1) recycle of


                                  W8.2-2

    -------
barometric condenser cooling water by utilizing either a cooling tower or
pond, (2) biological treatment of the (assumed 2 percent) blowdown from the
cooling system, and (3) sand filtration of effluent from the biological
treatment system.  Essentially the same control technology is applicable to
both crystalline and liquid cane sugar refineries.

Sugar Processing, Phase II—Raw Sugarcane Processing

          Industry Characteristics.  Sugarcane milling (SIC 2061) involves
the conversion of freshly harvested sugarcane into raw sugar and molasses.
Because the quality of the juice drops rapidly after harvest, sugar mills
are located close to the fields in which the cane is grown.  On the other
hand, refineries, which convert raw sugar to refined sugar, are typically
located close to the market area.  Only a few cane mills are integrated
with a refinery.  (Pollution problems in sugarcane refining are discussed
elsewhere.)

          The processes carried out in the sugar mill  are conceptually
rather simple.  The cane is hauled into the mill, weighed, and dumped.  In
areas where collection procedures cause large amounts  of dirt and rocks to
be included in the material brought to the mill (Hawaii, Louisiana, and
Puerto Rico), the cane is usually cleaned by blowing air through it and
washing it with water.  Rocks are removed by passing the material over
grates.  (In some regions of Hawaii, it is not unusual for 50 percent of
the gross weight of cane brought to the mill to be rocks, dirt, and field
trash such as leaves.)  The clean cane is then chopped or run through a
hammermill and then crushed with rollers that squeeze  much of the juice
out.  This is followed by 4-6 three-roll mills that squeeze out almost all
the remaining sugar.  Water is added at the last mill  to help wash the last
of the sugar from the fiber.  This juice is then used  to wash the fiber in
earlier stages so that a counter-current extraction is achieved.  The
bagasse from the last mill has about 50 percent moisture and is sent to the
boiler or to the bagasse house.  The bagasse can be used as boiler fuel,
processed to make the chemical furfural, or used in making wallboard or
paper.  In some regions where fuel is cheap or where the bagasse exceeds
the needs for the boiler and where no by-product industry exists, unwanted
bagasse is either landfilled or dumped in the ocean.

          The fresh cane juice is heated and treated with lime to
precipitate impurities.  The precipitate, "mud", is separated from the
clarified juice by decantation and vacuum filtration of the sludge from the
clarifier.  The mud, which is mostly inorganic material  but which contains
sugar, wax, organic salts, and fine bits of bagasse, is frequently a
disposal  problem.  The clarified juice is next evaporated using
multiple-effect evaporators to reduce its volume and increase the
concentration of sugar.  After the solution is partly  evaporated, it is
conveyed to vacuum pans in which it is further concentrated.   The final
concentrated sugar solution in the vacuum pans is seeded with crystals of
pure sugar and, because the solution is supersaturated,  the sugar grows
around these seeds, excluding the water and impurities.   The final  product
is raw sugar, which is centrifuged, washed with hot water,  and discharged.
It is pure enough to be free-flowing even though it has  a light brown


                                  W8.2-3

    -------
color.  The centrifugate, which Is known as blackstrap molasses, contains
roughly 44 percent sugar but also contains dissolved salts and water.  It
Is sold for animal feed or as a starting material  for rum or other
fermentation products.

          Pollutants and Sources.  A number of points in the process can
give rise to water pollution.The greatest problem in areas with dirty
cane is the handling of the cane washings.  In the washing process, some
sugar is lost to the wash water and organic particles are suspended in it
each of which gives rise to  biological  oxygen demand.  In addition, ther
are large amounts of suspended dirt and dissolved inorganic solids.  In
areas where irrigation  is practiced, the cane wash water can be used for
irrigation.  In other areas, storage in ponds followed by appropriate
treatment is needed.  The solid trash, rocks, etc., are landfilled.

          The mud which is removed from the vacuum filters contains about
75 percent water which  has dissolved organic and inorganic material in it
To avoid problems some  mills dry the mud, which can then be returned to t
fields.  In other sugar mills, the filter mud is slurried and discharged
to waterways, which can present a significant water problem.

          In the final  stage of the multiple-effect evaporator, and in tf
vacuum pans, barometric condensers are used; that is, cooling water is
mixed directly with the steam to condense it and create a vacuum.  This
allows sugar particles  that are entrained in the steam to become mixed ir
the condenser water, producing a biological oxygen demand when that water
is ultimately discharged.  Condenser water can amount to as much as 25
thousand liters per metric ton (6 thousand gallons per short ton) of cane
processed and can have  a BODj- loading of up to 1.5 kg per metric ton (3
pounds per short ton) of cane processed.  When this water is used for
irrigation, there is no significant problem.  On the other hand, in areas
where irrigation is impractical, the water produces a pollution problem i
discharged into navigable waterways.  Control can be obtained by
impoundment followed by biological treatment before discharge.
Alternatively, the condenser water can be used in cane washing.  If the
cane wash water is collected and treated it can be recycled to the
condenser.

          Minor sources of problems are the water from washing the floors
of the sugar mill which contain sugar from the spills and spatters that
continually occur in the mill as well as mud tracked in on boots.  The
boiler systems can also give rise to pollutants.  The water in which the
ash is slurried for removal from the boiler can cause problems as well  as
the blowdown water from the boiler itself.

          Control Technology.  Recommended BPT, BAT and NSPS control
technologies for cane sugar processing states are discussed below.

          BPT Technology for Louisiana.   Improved controls and practices
reduce pollution such as the reduction of entrainment of sucrose in the
barometric condenser cooling water are recommended.   The use of settling
ponds to remove solids  from the wash water and biological  treatment for t


                                  W8.2-4

    -------
effluent from settling ponds and all  other waste streams except barometric
condenser cooler water and excess condensate are recommended.

          BAT and NSPS Technology—Louisiana.  Recycling of barometric
condenser cooling water and cane wash water and biological treatment of
blowdown and miscellaneous waste streams is suggested.

          BPT, BAT, and NSPS Technology—Florida and Texas.  The
containment of all wastewaters is required except when rainfall causes an
overflow from a facility designed to contain wastewaters.

          BPT. BAT, and NSPS Technology—State of Hawaii except for Hilo
Coast.  These are the same as for Florida and Texas.

          BPT, BAT, and NSPS Technology—Puerto Rico.  These are the same
as for Louisiana.

          Costing Methodology.  The Economic Analysis Document gives the
expected pollution costs for Louisiana and for Puerto Rico for the
promulgated BPT and proposed BAT and NSPS regulations.  These costs were
developed through the use of several  model plants.  The degree of
conformance of each of the existing mills to a model plant was evaluated
and costs for upgrading each one were developed separately.  Current
practices in Florida and Texas and in the portions of Hawaii other than the
Hilo Coast are such (irrigation or recycle) that there is already a full
compliance with BPT and BAT requirements.  Therefore there are no costs
involved in these regions.  Since the regulations for the Hilo Coast of
Hawaii are in suspense, no costs have been calculated for this region.

          No limitations have been proposed for pretreatment before
discharge to municipal sewage systems.  No sugar mills are now known to be
discharging to municipal sewers.

Beet Sugar Processing

          Production Characteristics and Capacities.  The plant size ranges
for beet sugar processing are classified according to production capacity,
small (less than 2,100 metric tons or 2,300 short tons per day), medium
(2.100-3,500 metric tons or 2,300-3,900 short tons per day), and large
(greater than 3,500 metric tons or 3,900 short tons per day).

          Typical plant production is estimated to be 3,200 metric tons
(3,600 short tons) of sliced beets per day.  The main products from this
industry are refined sugar, dried beet pulp (used for animal feed), and
molasses.

          The beet sugar processing industry is a subcategory of the sugar
processing industry.  Water is commonly used for six principal  purposes:
(1) transporting (fluming) of beets to the processing operation, (2)
washing beets, (3) processing (extraction of sugar from the beets), (4)
transporting beet pulp and lime mud cake waste, (5) condensing vapors from
evaporators and crystallization pans, and (6) cooling.


                                  W8.2-5

    -------
          Beets are transported into the plant by water flowing in a narn
channel (flume) that removes adhered soil.  The beets are then lifted fror
the flume and spray washed.   Flume water accounts for about 50 percent of
the total plant water consumption.

          Process water is associated with the operations of extracting
sugar from the beets.  Diffusers draw the raw juice from the beets into a
solution which contains 10-15 percent sugar.   Exhausted beet pulp is late
pressed to remove moisture.   This exhausted pulp water is usually recycle-
back to the diffuser.

          Lime mud cake waste results when lime is added to the raw juice
and the solution is purged with carbon dioxide gas, causing calcium
carbonate to precipitate.   The sludge formed  removes impurities which are
suspended in the juice.

          Water from barometric condensers is employed in the operation o'
pan evaporators and crystallizers in the industry.  Water is used in larg
quantities.  Condenser water is usually cooled by some device and recycle*
for use in the plant.

          In addition to the above, about 40  percent of the plants employ
the Steffen process to recover additional sugar.  In the Steffen process,
syrup remaining from the above processes is concentrated to form molasses
which is then desugared to recover the sugar.  In this step, water is use
to dilute the molasses and calcium oxide is added to the solution, causin
a precipitate to form.  The precipitation process produces the Steffen
filtrate and recovered sugar; the filtrate may be directly discharged as
waste or it may be mixed with beet pulp to produce by-products.
                                           •
          Areas of future growth of beet sugar production are expected to
be along the Red River between northern Minnesota and North Dakota, and i
the Columbia River Basin.

          Pollutants and Sources.  The major  waste sources stem from the
primary production processes.These include:  (1) beet transporting and
washing, (2) processing (extraction of sugar  from the beets), (3)
carbonating of raw juice,  and (4) Steffen processing (for those plants
involved in desugaring of molasses).  Barometric condensers are also a
wastewater source.  The primary wastewaters resulting from the beet sugar
processing industry are:  flume water, lime mud cake from the carbonation
process, barometric condenser water, and Steffen process water used to
dilute molasses for desugarization.

          The basic parameters used in establishing water effluent
guidelines to meet BPT are:   BODg, total suspended solids, pH, and
temperature.

          Control Technology.   Current pollution control  technology does
not provide a single operation that is completely applicable under all
circumstances.  The major disposal methods are:  reuse of wastes,
coagulation, waste retention ponds or lagooning, and irrigation.


                                  W8.2-6

    -------
          BPT and BAT involve extensive recycle and reuse of wastewaters
within the processing operations with no discharge or controlled discharge
of process wastewater pollutants to navigable waters.

          BAT permits no discharge of wastewaters.  One method of
accomplishing this is to apply the wastewaters to the land after BPT steps
have been taken.  It is possible that after sufficient concentration of
wastewaters, only salt-tolerant grasses could be grown.  Farm lands  may be
taken out of production and no credit is taken for the value of crops grown
on these lands.  It is uncertain how long the soil can remain stable under
these conditions.

Control Costs—Sugar Processing

          The combined control costs for cane sugar refining, raw sugarcane
processing, and beet sugar processing are summarized in Table W8.2.1.
                                  W8.2-7

    -------
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    -------
         Chapter W8.3  Canned and Preserved Fruits and Vegetables


Regulations

          The canned and preserved fruits and vegetables processing
industry is subject to BPT, NSPS, PSES, PSNS, and BCT regulations described
in the Code of Federal Regulations Title 40, Part 407, and as updated in
the Federal Register (47 FR 49175, 10/29/82).

          The regulations causing significant costs are BPT and NSPS.
Point source discharge limitations are defined for the discharge of process
wastewater pollutants.  Existing BCT regulations, when they exist, equal
BPT limitations for all  subparts.  Existing and new dischargers to POTW's
meet no special standards, but must conform to general pretreatment
standards provided in 40 CFR, Part 403.  In some instances new dischargers
to POTW's must reduce incompatible pollutant levels to those designated
under NSPS standards.

Industry Characteristics

          The fruits and vegetables processing industry includes processors
of canned fruits and vegetables, preserves, jams, jellies, dried and
dehydrated fruits and vegetables, frozen fruits and vegetables; fruit and
vegetable juices, and specialty items.  The effluent limitations guidelines
issued by the EPA are limited to processors of apple products (except
caustic peeled and dehydrated products),'citrus products (except pectin and
pharmaceutical products), frozen and dehydrated potato products, and
specialty fruits and vegetables.  The principal items in each group are as
follows:

          •  Apples:  slices, sauce, and juice (cider)
          •  Citrus:  juice, segments, oil, dried peel, and molasses
          •  Potatoes:  chips, frozen products, dehydrated products, canned
             hash, stew, and soup products.
          •  Specialty fruits and vegetables.

          The manufacturing processes employed after harvesting depend on
the particular product to be manufactured.   Specific processes include
receiving, storing, washing and sorting, peeling and coring, sorting,
slicing, segmenting or dicing, pressing or  extracting (for juice products),
cooking, finishing, blanching (for potatoes), juice concentrating,
dehydrating, canning, freezing, can rinsing and cooling, and cleaning up.
Many processes previously performed by hand, such as peeling and coring,
have been automated.  Peeling, for example, may be performed mechanically
or caustically.  In the caustic process the fruit or vegetable is dipped in
a hot lye solution to loosen and soften the peel, which is then removed by
brushes and water spray.


                                  W8.3-1

    -------
          The fruits and vegetables canning and freezing industry comprise
approximately 1,680 plants that are subdivided into 1,038 canned fruits ar
vegetables plants plus 642 frozen fruits, vegetables, and specialties
plants.  These plants are further subdivided into canning plants, freezinc
plants, combination canning and freezing plants, and dehydrating plants.
According to the 1982 U.S. Industrial  Outlook, shipments of canned and
frozen fruits and vegetables reached $13 billion in 1981, an increase of ;
percent over 1980.  Approximately 70 percent of all these plants are
multiproduct producers, although an equivalent percentage confine their
operations to either fruits or vegetables.

          The canning and freezing industry is characterized by a large
number of small, single-plant firms.  These firms share a very small
segment of the total market and have very little influence on industry
prices and total supply.  Over the past 20 years, there has been a steady
trend in the industry to fewer large plants from many smaller operations.
The four largest firms in the canning, freezing, and dehydrating industrii
account for approximately 20, 25, and 35 percent, respectively, of the
total value of industry shipments.  Although a large proportion of the
plants are relatively old, the industry has generally maintained modern
technology through renovation and equipment modernization.

          It is likely that the trend toward fewer plants will continue.
New large plants will probably continue to replace the production capacit.
of the small, older plants that will close.
Pollutants and Sources

          Water is used extensively in all
industry, it is used as:
phases of the food processing
             A cleaning agent to remove dirt and foreign material
             A heat-transfer medium for heating and cooling
             A solvent for removal of undesirable ingredients from the
             product
             A carrier for the incorporation of additives into the produc
             A vehicle for transporting and hauling the product.

          Although the steps used in processing the various commodities
display a general similarity, there are variations in the equipment used
and  in the amount and character of the wastewaters produced.  For example
caustic peeling produces a much higher pollution load than does mechanica
peeling.  Similarly, water transport adds a great deal to a plant's
wastewater flow compared to dry transportation methods.

          The pollutant parameters that have been designated by EPA as
being of major significance for apple, citrus, and potato processors are
BOD, suspended solids, and pH.  Minor pollutant parameters include COD,
total dissolved solids, ammonia and other nitrogen forms, phosphorus, fee
coliforms, and heat.
                                  W8.3-2

    -------
Control Technologies

          Control technologies applicable to wastewaters from the fruit and
vegetable processing industry consist of both in-plant (or in-process)
technologies and conventional end-of-pipe waste treatment technologies.
In-plant control methods include field washing of crops; substitution of
dry transport methods for flumes; replacing conventional hot water and
steam blanching methods by fluidized bed, microwave, hot gas, or individual
quick blanching methods; using high-pressure nozzles and automatic shutoff
valves on hoses; reusing process waters in countercurrent flow systems,
recirculating of cooling waters, etc.; and minimizing the use of water and
detergents in plant cleanup.

          End-of-pipe treatment technologies used in the fruits and
vegetables processing industry generally include preliminary screening,
equalization, the use of catch basins for grease removal, sedimentation and
clarification, followed by a biological treatment system such as activated
sludge and the use of trickling filters, anaerobic lagoons, or aerated
lagoons.  Where necessary, neutralization and chlorination are also
included.  Other technologies that are or may be used by the industry
include solids removal  by air flotation or centrifugal  separation, chemical
coagulation and precipitation, biological treatment (through the use of a
rotating biological contractor), sand or diatomaceous earth filtration,
and other advanced treatment technologies.  The liquid portion of cannery
wastes can be "completely" treated and discharged through percolation and
evaporation lagoons or by spray irrigation.

          Because the wastes from fruit and vegetable processing plants are
primarily biological, they are compatible with municipal sewage treatment
systems.  Therefore, discharge into municipal systems is also a practicable
alternative for fruit and vegetable processors.

          BPT guidelines are based upon the average performances of
exemplary biological treatment systems.  Thus, the technology includes
preliminary screening,  primary settling (potatoes only), and biological
secondary treatment.  The use of cooling towers for the recirculation of
cooling water is considered a BPT for the citrus industry.  In-plant
control methods should include good housekeeping and water use practices.
No special in-plant modifications are required.  Land treatment methods
such as spray irrigation are, of course, not excluded from use.

          NSPS guidelines assume the use of BPT, plus additional secondary
treatment, such as more aerated lagoons and/or shallow lagoons and/or a
sand filter following secondary treatment; disinfection (usually
chlorination) is also included.  Management controls over housekeeping and
water use practices are assumed to be stricter than BPT.  Although no
additional in-plant controls are required, several  modifications may be
economically more attractive than additional treatment facilities.   These
include:  recycling raw material wash water, utilizing low water-usage
peeling equipment, recirculating of cooling water, and utilizing dry
clean-up methods.  Where suitable land is available, land treatment is not
only recommended from the discharge viewpoint, but will  usually  be more
economical than other treatment methods.

                                  W8.3-3

    -------
Costing Methodology

          Model  plants were used to estimate the regulatory costs in the
canned and preserved fruits and vegetables industry.   These model plants
for each subcategory were derived in the Economic Analysis and the NCWQ
Report.  Control costs are summarized in Table W8.3.1.
                                  W8.3-4

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    -------
                Chapter W8.4  Canned and Preserved Seafood

Regulations

          The canned and preserved seafood processing industry is subject
to BPT, NSPS, PSES, PSNS, and BCT regulations described in the Code of
Federal Regulations Title 40, Part 408, and as updated in the Federal
Register (47 FR 49175, 10/29/82).

          The regulations causing significant costs are BPT and NSPS.
Point source discharge limitations are defined for the discharge of process
wastewater pollutants.  Existing BCT regulations equal BPT limitations for
all except the following subparts where BCT limitations exceed BPT
limitations:  Y - Pacific Coast Hand-Shucked Oyster Processing, Z -
Atlantic and Gulf Coast Hand-Shucked Oyster Processing, AD - Non-Alaskan
Scallop Processing, and AG - Abalone Processing.  Existing and new
dischargers to POTW's meet no special  standards, but must conform to
general pretreatment standards provided in 40 CFR, Part 403.

Industry Characteristics

          There are approximately 1,800 seafood processors located in the
United States, including tuna processing plants located in Puerto Rico and
American Samoa.  For the purpose of establishing effluent limitations guidelines,
the seafood processing industry has been divided into 33 subcategories, as
listed in Table W8.4.1.  Of these, 14 are in Phase I and 19 are in Phase
II.  The groupings are based upon the type of product, the degree of
mechanization, and the location or remoteness of the processing plant.
Remote Alaskan plants have been placed in a separate subcategory because
their isolated locations render most wastewater treatment alternatives
infeasible because of the high cost of overcoming engineering obstacles and
the undependability of access to transportation during extended severe sea
or weather conditions.

          In general, the seafood processing industry can be characterized
as possessing many small, underutilized, old plants that in some cases
compete with efficient, low-cost foreign producers.  On the other hand, the
tuna industry is dominated by five firms that operate 14 large-scale plants
which account for over 90 percent of the industry production.

          Processing seafood involves variations of a common sequence of
operations:  harvest, storage, receiving, preprocessing (washing, thawing,
etc.), evisceration, precooking, picking or cleaning, preservation, and
packaging.  Many of the operations, such as picking, shelling, and
cleaning, have been mechanized, but much of the industry still depends on
conventional hand operations.

          In general, the volume of production is dependent upon the amount
of seafood harvested, both domestic and imported.  Analyses by the U.S.

                                  W8.4-1

    -------
TABLE W8.4.1  SEAFOOD PROCESSING INDUSTRY SUBCATEGORIES
                        Phase I
 (1)  Farm-raised Catfish
 (2)  Conventional Blue Crab
 (3)  Mechanized Blue Crab
 (4)  Non-Remote Alaskan Crab Meat
 (5)  Remote Alaskan Crab Meat
 (6)  Non-Remote Alaskan Whole Crab and Crab Section
 (7)  Remote Alaskan Whole Crab and Crab Section
 (8)  Dungeness and Tanner Crab Processing in the
      Contigous States
 (9)  Non-Remote Alaskan Shrimp
(10)  Remote Alaskan Shrimp
(11)  Northern Shrimp in the Contiguous States
(12)  Southern Non-Breaded Shrimp Processing in the
      Contiguous States
(13)  Breaded Shrimp Processing in the Contiguous States
(14)  Tuna
                       Phase II

 (1)  Fish Meal
 (2)  Alaska Hand-Butchered Salmon
 (3)  Alaska Mechanized Salmon
 (4)  West Coast Hand-Butchered Salmon
 (5)  West Coast Mechanized Salmon
 (6)  Alaskan Bottom Fish
 (7)  Non-Alaskan Conventional Bottom Fish
 (8)  Non-Alaskan Mechanized Bottom Fish
 (9)  Hand Shucked Clam
(10)  Mechanized Clam
(11)  Pacific Coast Hand-Shucked Oyster
(12)  Atlantic and Gulf Coast Hand-Shucked Oyster
(13)  Steamed and Canned Oyster
(14)  Sardine Processing
(15)  Alaskan Scallop Processing
(16)  Non-Alaskan Scallop Processing
(17)  Alaskan Herring Fillet
(18)  Non-Alaskan Herring Fillet
(19)  Abalone Processing
                        W8.4-2

    -------
National Marine Fisheries Service indicate that a 3.1 percent annual
compound growth rate can be sustained through 1985 by the extension of the
U.S. fisheries jurisdiction to 200 miles, raising additional fish by
aquaculture, and by encouraging the catch and sale of presently
underutilized fish species.  A fully operational predictive model to
forecast the effect of the 200-mile limit is not yet available.

          The effluent limitations guidelines issued for the seafood
processing industry by the EPA cover all methods of preservation—
fresh-pack, freezing, canning, and curing.

Pollutants and Sources

          Pollution sources in the seafood processing industry include both
the fishing boats (mostly their discharged bilge water) and the processing
plants themselves.  Water uses in the processing plants include:  washing
the seafood, plants, and equipment; flumes for in-plant transport of
product and wastes; live holding tanks; cooling and ice making; cooking;
freezing; and brining.

          The solids and effluents from all  fish and shellfish operations
consist of:

          •  Solid portions consisting of flesh, shell, bone, cartilage,
             and viscera

          •  Hot and cold water (fresh or seawater) solutions containing
             dissolved materials (proteins and breakdown products)

          t  Suspended solids consisting of bone, shell, or flesh

          t  Foreign material carried into the plant with the raw material.

          Phase I Subcategories.  The major wastes from Phase I seafood
processing include blood, viscera, bits of flesh and other tissues,  scales,
slime and cooking liquors.  Wastewaters from processing contain heavy loads
of dissolved and suspended fats and proteins.  Parameters under effluent
guidelines for meeting BPT and BCT include (I) five-day biochemical  oxygen
demand (BOD,-), (2) total suspended solids, (3) oil  and grease, and (4) pH
(Table W8.4.2).

          Industrial Fishes.   There are three primary sources of wastewater
in processing of menhaden and anchovies:  (1) the bailwater used to
transport the fish from the boats, (2) the stickwater, which* separates from
the oil after the pressing operation, and (3) washwater from refining of
the fish oil.  Stickwater, a  mixture of dissolved and suspended proteins,
fats, oil and ash, contributes the heaviest  waste!oad.  In factories
equipped with a solubles plant, the stickwater and other wastewaters are
evaporated to yield protein concentrate.  The barometric condensor of the
evaporator produces large volumes of low-strength wastewater.   Factories
without solubles plants dispose of stickwater by barging to sea.
Bailwater, which is commonly  recycled, carries a high load of BOD and
suspended solids.

                                  W8.4-3

    -------
TABLE W8.4.2.  SEAFOOD INDUSTRY  RAW WASTE CHARACTERISTICS
Subcategory
Catfish (farm)
Crabs
[STue conventional)
(Slue Mech.)
(Alaska) NR/R
(Dungeness/Tanner)
Shrimp
(Alaska) NR/R
(West Coast)(a)
(Gulf, breaded)
Tuna
Fish Meal
(U solubles)
(W/0 solubles)
Sardines
Herring
rFTTTeting)
Salmon
(Tian~d-butchered)
(Mechanical )
West/Alaska (composite)
Bottom Fish
Alaska
Non Alaska-Conv.
Non Alaska-Mach.
Clams
[Conventional )
(Mechanized)
Oysters
Steamed or canned
Hand-shucked (West)
Hand-shucked (East)
Scallops
(Alaska)
(N. Alaska)
Aba lone
Flow
1/kkg
23,000
1,190
36 ,300
51,700
19,600
73,400
60 ,000
116,000
18,300

35,000
1,900
3,640
8,090
3,960
18,500
13,300

6,230
5,240
13,500
3,700
21,100
65,100
55,300
32,600
11,700
11,700
35,700
30D5
7.9
5.2
22
66
3.1
130
120
84
13

2.96
62.2
10.1
32.0
2.11
50.8
33.3

2.00
3.32
11.9
5.71
13.7
31.0
23.9
14.9
2.85
2.85
17.1
kg/kkg
TSS
9.2
0.74
12
54
2.7
210
54
93
10

0.920
34.3
2.93
22.6
1.21
20.3
13.4

1.61
1.42
8.92
13.6
5.48
29.0
34.2
13.6
0.526
0.526
3.37
O&G
	 Phase I 	
4.5
0.26
5.5
13
17
42
5.8
.___pua<:0 TT 	

0.562
22.8
1.99
6.11
0.153
6.49
4.21

0.084
0.348
2.48
0.141
0.444
1.13
1.55
0.665
0.158
0.158
0.897
8005
343.4
4,369.7
597.3
1,276.5
413.2
1,771.1
2,000.0
724.1
710.3

84.5
32,737
2,747
3,955
532.3
2,746
2,501

321
633.5
881.4
1,543
549.3
476.2
432.2
457.1
243.5
243.5
479.0
mg/1
TSS
400.0
621.8
326.0
1,044.4
137.7
2,361.1
900.0
801.7
546.4

26.2
18,315
304.9
2,793
305.5
1,097
1,008

258.4
270.9
660.7
3,676
259.7
445.5
- 513.4
417.2
45.0
45.0
234.5
0
195
213
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                           W8.4-4

    -------
          Finfish.  The primary source of wastewater from the processing of
salmon is the wash tank operation, where eviscerated fish are cleansed of
blood, loose tissues and flesh particles.  Mechanical processors produce
much heavier wasteloads than manual operations.  The same is true for the
mechanical processing of bottom fish, such as whiting.  Skinning and
scaling may produce high waste loads in the conventional processings of
bottom fish.  For very large bottom fish, i.e., halibut, the primary
wastewater flow and wasteload may result from washing the gut cavity.  In
sardine processing the principal  wasteloads are contributed by the precook
stickwater and the flume to the packing tables.  For the herring filleting
industry the largest percentage of flow and wasteload is produced by the
filleting machine and associated fluming, with a lesser contribution from
the bail water.

          Municipal dischargers comprise a small fraction of the total
plants in the industry.  Alaskan plants are in an especially difficult
position with respect to this option.

          According to the EPA Development Documents, the sludge volumes
from treatment of seafood wastes, although not demonstrated on a
significant scale, are up to 10 percent of raw waste volume from dissolved
air flotation, 10 to 15 percent from activated sludge, 5 to 10 percent from
extended aeration and 2 percent from anaerobic contact processes.  These
sludges have a high water content (95-98 percent) and are amenable to
conventional sludge handling except for sludge from air flotation which may
be difficult to dewater.

          Waste waters from the seafoods industry contain compatible
pollutants.  There is no evidence that toxic pollutants as defined in the
EPA toxic pollutant effluent standards are present in the wastewaters from
any subcategory.

Control Technologies

          Control technologies applicable to the seafood processing
industry include both in-plant changes and end-of-pipe treatment.  Basic
in-plant changes include:

          •  Minimizing the use of water by substituting dry handling for
             flumes, using spring-loaded hose nozzles, etc.

          •  Recovering dissolved proteins by precipitation from effluent
             streams, enzymatic hydrolysis, brine-acid extraction, or
             through the conventional reduction process for converting
             whole fish or fish waste to fish meal.

          •  Recovering solid portions for use as edible product or as
             by-products by mechanical deboning and extruding, and by
             shellfish waste utilization.

          Very few end-of-pipe waste treatment systems are currently
installed in the seafood processing industry.   However, the essentially

                                  W8.4-5

    -------
biodegradable nature of the wastes allows for the easy application of
conventional treatment methods.  These include screening and sedimentatio
to remove suspended solids; air flotation and skimming to remove heavy
concentrations of solids, greases, oils, and dissolved organics; biologic.
treatment systems, such as activated sludge, rotating biological
contractors, trickling filters, ponds, and lagoons to remove organic
wastes; and land disposal methods where land is available.

          In general, BPT guidelines call for in-plant "good housekeeping
practices, but do not assume significant equipment changes.  End-of-pipe
technologies associated with BPT are represented by simple screening and
grease-trap methods, with dissolved air flotation for tuna plants and
grinders or comminutors, followed by discharge to deep water for remote
Alaskan processors where adequate flushing is available.  NSPS guidelines
place much more emphasis on in-plant changes, including in-process
modifications which promote efficient water and wastewater management to
reduce water consumption, recycling some water streams, and solids or
by-product recovery where practicable.  End-of-pipe technologies associat
with NSPS guidelines include more extensive use of dissolved air flotatio
for tuna processors in 1983.

Costing Methodology

          Model plants were used to estimate this regulatory cost in the
canned and preserved seafood industry.  These model plants for each
subcategory were derived from Development Documents and the NCWQ Report.
Control costs are summarized in Table W8.4.3.
                                  W8.4-6

    -------
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    -------
             Chapter W8.5  Dairy Products Processing Industry
Regulations
          Regulations which were published as of February 11, 1975 are the
basis for this chapter.  Since publication BAT has been redesignated BCT,
and in 1981, BCT requirements were remanded.   Therefore, only compliance
costs for BPT and NSPS regulations are presented in this chapter.

Industry Characteristics

          In 1970, there were 5,241 dairy plants reported in the United
States, and by 1977, the number of plants had dropped to 3,731 plants, a 29
percent decline.  The size of each plant is determined by the number of
employees required, where a small  operation has 1-19 employees, a medium
one has 20-99 employees, and a large plant over 100 employees.

          The dairy processing industry comprises 12 product-related
subcategories:  (1) receiving stations, (2) fluid products, (3) cultured
products, (4) cottage cheese, (5)  butter, (6) natural cheese, (7) ice
cream, (8) ice cream mix, (9) condensed milk, (10) dry milk, (11) condensed
whey, and (12) dry whey.

          A great variety of operations are employed in the dairy products
industry.  For simplification, they are considered to be a chain of
operations involving:  (1) receiving and storing, (2) clarifying, (3)
separating, (4) pasteurizing, and (5) packaging.

          Receiving and storing of raw materials is conducted by using bulk
carriers, pumps, and refrigerated tanks.  Clarifying is the removal  of
suspended matter by centrifuging.   Separating is the removal of cream by
centrifuging.  Pasteurizing is accomplished by passing the material  through
a unit where it is rapidly heated then cooled by contact with heated and
cooled plates or tubes.  Packaging involves the final handling of the
finished product prior to storage.

Pollutants and Sources

          Materials are lost during direct processing of raw materials into
finished products and 'from ancillary operations.  The former group consists
of milk, milk products, and nondairy ingredients (sugar, fruits, nuts,
etc.), while the latter consists of cleaners  and sanitizers used in
cleaning equipment and lubricants  used in certain handling equipment.  All
of these contribute to the release of organic materials, which appear as
high BOD and suspended solids in the process  water.   Phosphorus, nitrogen,
chlorides, heat, and dairy fat can also be found.
                                  W8.5-1

    -------
          The major sources of wastes in the dairy products processing
industry are the following:  (1)  the washing and cleaning out of product
remaining in tanks and piping which is performed routinely after every
processing cycle, (2) the spillage produced by leaks,  overflow,
freezing-on, boiling-over and careless handling, (3)  processing losses, (<
the wastage of spoiled products,  returned products, or by-products such a:
whey, and (5) the detergents used in the washing and sanitizing solutions
          The primary waste materials that are discharged to the waste
streams in practically all dairy  plants include:  (1)  milk and milk
products received as raw materials, (2) milk products  handled in the
process and end-products manufacture, (3) lubricants (primarily soap and
silicone-based) used in certain handling equipment, and (4) sanitary and
domestic sewage from toilets, washrooms, and kitchens.  Other products,
such as nondairy ingredients (sugar, fruits, flavors,  and fruit juices) a
milk by-products (whey and buttermilk) are potential  waste contributors.

Control Technology and Costs

          Dairy wastes are usually subjected to biological breakdown.  Jh
standard practice for reducing the concentration of oxygen-demanding
materials in the wastewater has been to use secondary or biological
treatment consisting of:  activated sludge, trickling filters, aerated
lagoons, stabilization ponds, or land disposal.  Tertiary treatment (sand
filtration, carbon adsorption) is practically nonexistent at the present
time.

          BPT consist of in-plant and end-of-pipe controls.  In-plant
control includes improvement of plant maintenance, waste monitoring
equipment and quality control improvements.

          End-of-pipe control includes biological treatment (activated
sludge, trickling filters, or aerated lagoons).  If in-house controls are
not used, end-of-pipe biological  treatment must be supplemented by rapid
sand'filtration.  Small dairies may be able to meet BPT through land
disposal options.

          Based on the Development and Economic Analysis documents, the
industry was modeled in terms of small, medium, and large plants in five
product sectors:  (1) butter, (2) milk and cottage cheese, (3) processed
cheese, (4) ice cream, and (5) condensed evaporated milk.  Treatment
technologies, costs, and estimates of existing compliance levels were
also obtained from the same documents.  The estimated costs of compliance
are given in Table W8.5.1.
                                  W8.5-2

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                      Chapter U8.6  Feedlots Industry
Regulations
          The feedlots point source category is comprised of two
subcategories for which BPT, BAT (old), NSPS and pretreatment have been
adopted.  These standards are applicable only to large scale feedlot
operations.

Industry Characteristics

          Feedlots is a term which applies to many different types of
facilities used to raise animals in a "high density" situation.   For the
purpose of establishing effluent limitations guidelines, the term feedlots
has been defined by the following three conditions:

          •  There is a high concentration of animals held in a  small area
             for periods of time in conjunction with the production of
             meat, milk, eggs, and/or breeding stock; and/or the stabling
             of horses;

          t  There is transportation of feed from other areas to the
             animals for consumption and;

          •  By virtue of the confinement  of animals or poultry, the land
             or area will neither sustain  vegetation nor be available for
             crop or forage production.

          The effluent limitations guidelines issued to date (Phase I) by
the EPA cover feedlots for beef cattle, dairy cattle, swine, chickens,
turkeys, sheep, ducks, and horses.  A variety of facility types  are
included within the definition of feedlots.  These include:  open lots,
housed lots, barns with stalls, free-stall barns, slotted-floor  houses,
solid concrete floor houses, a variety of  poultry houses, and wet lots
containing swimming areas for ducks.

          Raw materials used in the feedlots industry are feed,  water, and
in some cases, bedding.  The production processes are defined by the type
of facilities employed, and consist mostly of delivering supplies to the
animals and carrying away manure and litter.

          Although most of the feedlots are classified as small, for many
animals the bulk of production is accounted for by the very large
producers.  Although this concentration is not so dominant in some of the
other animal groups, the trend'toward larger units of production is common
to all segments of the industry.
                                  W8.6-1

    -------
                            •s.
          Many producers have diversified into grain production for direc
marketing and production of other livestock and poultry.  Some are invo1v<
in feed grain producing, feed-manufacturing, feeder-cattle producing,
and/or meat packaging.

          Ownership of commercial feedlots ranges from sole-proprietorshi
to corporate farms, including co-operatives.  The feedlot operator may ow
the animals being fed or, (particularly in the case of fed-cattle) may
custom-feed animals owned by others.

          Projections of production capacity through 1983 for the cattle,
dairy, and hog segments of the feedlots industry anticipate that the tren
is toward fewer numbers of production units with the very large units
continuing to increase their output volume.  Similar projections are not
available for the remaining segments of the feedlots industry.  However,
the growth of production of major agricultural commodities for the period
1970-85 has been estimated.  The percentage changes are as follows:  beef
and veal (33 percent); pork (13 percent); milk (2 percent); chicken (36
percent); turkey (44 percent); eggs (10 percent); and lamb and mutton (65
percent).  In all segments of the feedlots industry, it is anticipated th
the trend toward larger feedlots will continue.  No substantive growth
projections are available for the duck or horse subcategories.

Pollutants and Sources

          Feedlot wastewater originates from two principal sources:

          •  Rainfall runoff

          •  Flush or washdown water used to clean animal wastes from per
             stalls, milk center areas, houses; runoff from continuous
             overflow watering systems or similar facilities; spillages;
             runoff from duck swimming areas; runoff from washing of
             animals; runoff from dust control; etc.

          The amount of wastewater varies considerably, depending upon tf
way manure, bedding, etc., are stored and handled; in the outdoor feedlo'
rainfall and soil characteristics determine wastewater characteristics.

          Animal Feedlot wastes generally include the following pollutan'

             Bedding or litter (jf used) and animal hair or feathers
             Watering- and milling-center wastes
             Spilled feed
             Undigested and partially digested food or feed additives
             Digestive juices
             Biological products of metabolism
             Micro-organisms from the digestive tract
             Cells and cell debris from the digestive tract
             Residual soil and sand.
                                  W8.6-2

    -------
          The primary discharge constituents of concern for pollution
control can be described as organic soils, nutrients, salts, and bacterial
contaminants.  The following specific pollutant parameters have been
identified as being of particular importance:  BOD-, COD, fecal coliform,
total suspended solids, phosphorus, ammonia and otner nitrogen forms, and
dissolved solids.

          With the exception of the duck feedlot subcategory, the EPA has
concluded that animal feedlots can achieve a BPT level of waste control
which prevents the discharge of any wastes into waterways, except for
overflows due to excessive rainfall or similar unusual climatic events (a
10-year, 24-hour storm as defined by the National  Weather Service).   The
effluent limitations for discharges from duck feedlots have been set at 0.9
kilogram (2 pounds) of BOD5 per day for every 1,000 ducks being fed, and a
total viable coliform count less than that recommended by the National
Technical Advisory Committee for shellfish-producing waters, which is 400
fecal coliform per 100 milliliters.  The effluent limitations guidelines
for all subcategories effective July 1, 1984 (BAT), and for all new sources
(NSPS) are no discharge of wastewater pollutants,  except for overflows due
to rainfalls in excess of the 25-year, 24-hour storm (as defined by the
National Weather Service).

Control Technology

          In-process technologies used for the control of wastewaters from
animal feedlots include:  site selection, selection of production methods,
water utilization practices, feed formulation and utilization, bedding and
litter utilization, and housekeeping procedures.  All of these are
important in minimizing wastewater flow and pollutants.

          The various technologies available for end-of-process treatment
may be classified as either partial or complete.  Partial technologies are
defined as those that produce a product or products which are neither sold
or completely utilized on the feedlot.  Thus, gasification and incineration
of manure are considered partial technologies because each generates a
significant quantity of ash that must be disposed of.  Lagoons, trickling
filters, and other biological systems are classified as partial
technologies because the effluent may not be suitable for discharge, and,
in all cases sludge disposal is necessary.  Complete treatment technologies
produce a marketable product or a product that can be entirely reused at
the feedlot, and which has no appreciable by-products, residues, or
polluted water discharge.  The dehydration and sale of manure, for example,
is a complete technology.  Spreading animal wastes on land for crop
fertilization is also a complete control technology.

          The 1977 BPT guidelines for all animal feedlots (except those for
ducks), the 1984 BAT, and the NSPS guidelines all  assume the use of
complete control technology.  The BPT guidelines are based on the
containment of all contaminated liquid runoff and the application of these
liquids, as well as the generated solid wastes, to productive cropland at a
rate which will provide moisture and nutrients that can be utilized  by the
crops.  Technologies applicable to BAT guidelines  include some of the


                                  W8.6-3

    -------
complete technologies, such as wastelage (addition of waste products to
feed), oxidation ditch mixed liquor refeed, and the recycling of wet-lot
water for ducks, which are not yet fully available for general use.  The
BPT guidelines for duck feedlots require the equivalent of primary
settling, aeration, secondary settling, and chlorination prior to
discharge.

Costing Methodology

          The costs of compliance were estimated using an industry model
based on separate costing sectors for each of the regulatory subcategories
(beef, ducks, etc).  Plant sizes and numbers were derived from data in the
Development and Economic Analysis Documents supplemented by other data
sources.

          Comprehensive and reliable data were not available on the numbe
of feedlots that will require construction of pollution control facilities
to meet the effluent limitations guidelines.  It is generally accepted th<
housed (total confinement) and pasture operations can generally meet the
guidelines without new investment or operating cost outlays.

          Furthermore, open or partially open feedlots may be situated so
that they are not point-source dischargers.  Finally, some feedlots have
already installed control facilities which meet the guidelines'
requirements.  Control costs were developed from the cost functions of
model plants and are summarized in Table W8.6.1.
                                  W8.6-4

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                  Chapter W8.7  Meat Products Processing
Regulations
          The costs discussed  in this chapter are associated with  the
regulations as originally promulgated.  BAT regulations for the  industry
are currently under review by  EPA; the costs for compliance with BAT are
subject to change if the BAT regulations are modified.

Meat Packing (Phase I)

          Industry Characteristics.  A total of 90 percent of the
industry's production is accounted for by 15 percent of the plants.
Although the total number of plants  in the Development Document
slaughterhouse and packinghouse categories is only 793, it was assumed that
these plants produce 90 percent of the output, and that locker plants (very
small meat packing plants that slaughter animals and may produce processed
meat products which are usually stored in frozen form) account for the
remaining 10 percent.

          The meat processing  industry comprises four subcategories:
simple slaughterhouse, complex slaughterhouse, low-processing packinghouse,
and high-processing packinghouse.  The plants in this industry range from
those that carry out only one  operation, such as slaughtering, to plants
that also carry out commercial meat  processing.

          Simple slaughterhouses have very limited by-product processing
.and usually no more than two other operations such as:  rendering, paunch
and viscera handling, blood processing, or hide processing.  Complex
slaughterhouses carry out extensive  by-product processing with at least
three of the aforementioned operations.  Low-processing packinghouses
process only animals killed at the plant; normally they process  less than
the total kill.  High-processing packinghouses process both animals
slaughtered at the site and additional carcasses from outside sources.

          Factors serving to restrain potential growth of the American meat
packing industry include higher meat prices, removal of import quotas, and
the availability of synthetic  (soybean protein) substitutes.  The trend is
for any new plants to be larger and  more specialized (such as large beef or
pork slaughterhouses) and to be located closer to the animal supply
(movement from urban to rural  areas).

          Pollutants and Sources.  Wastewaters from slaughterhouses and
packinghouses contain organic  matter including grease, suspended solids,
and inorganic materials such as phosphates, nitrates, and salt.  These
materials enter the waste stream as  blood, meat and fatty tissue, meat
extracts, paunch contents, bedding,  manure, hair, dirt, curing and pickling
solutions, preservatives, and  alkaline detergents.


                                  W8.7-1

    -------
          Water is used in the meat processing industry to cleanse produc
and to remove unwanted material.   The primary operations where wastewater
originates are:  animal holding pen operations (waste from water troughs,
washdown, and liquid wastes), slaughtering (killing, blood processing,
viscera handling and offal washing, and hide processing), and clean-up.

          The basic parameters used to define waste characteristics are
BOD, suspended solids, grease, and ammonia (NSPS and BAT).  The total
number of municipal dischargers is 70 percent of the number of plants.  T
average wastewater flows for simple slaughterhouse, complex slaughterous
low-process packinghouse, and high-process packinghouse are 1.17, 4,35,
3.41 and 4.54 million liters (0.31, 1.15, 0.90, 1.2 million gallons)
respectively per day.  About 70-75 percent'of the total wastewater volume
is discharged to municipal systems.

          Control Technology and  Costs.  Current end-of-pipe treatment fo
direct dischargers assumes that all plants have in-plant controls for
primary treatment, and a secondary treatment system employing anaerobic a
aerobic lagoons.  Dissolved air flotation is used for primary treatment,
either alone or with screens; however, 30 percent of the plants use a  cat
basin.  Since a small percentage  of the industry have more advanced
secondary treatment systems (such as activated sludge, trickling filters,
or spray irrigation) and a small  percentage of meat packers have no waste
treatment beyond primary treatment, it can be assumed that the typical
plant today is characterized by primary treatment plus anaerobic and
aerobic lagoons.

          Best Practicable Technology consists of end-of-pipe treatment
represented by anaerobic-plus-aerated lagoons and aerated lagoons with
efficient solid-liquid separation.  Disinfection by chlorination is also
required.  Land disposal, when available, may be an economical option,
especially for small plants.  End-of-pipe treatment is assumed to be
preceded by in-plant controls; these are:  reduction of water use through
shut-off valves, extensive dry cleaning, use of gravity catch basins,  blo>
recovery, and dry dumping of paunch waste.  NSPS are the same as BPT with
an additional requirement for control of ammonia.

          In addition to BPT, Best Available Technology suggests chemical
additions prior to dissolved air  flotation, nitrification-denitrification
(or ammonia stripping), and sand  filtration following secondary treatment

Meat Products (Phase II) -
Red Meat Products

          Industry Characteristics.  Plants have been classified by size'
according to the production of finished product.  A small  processor
produces less than 2,720 kilograms (6,000 pounds) per day while a large
processor produces in excess of that amount.   Large processors are furthe
divided into the following product-mix categories:   meat cutter, sausage
and luncheon meat processor, ham  processor, and canned meat processor.
                                  W8.7-2

    -------
          Production processes for subcategories in this segment of the red
meat industry are varied but most often include:  receiving and storage;
boning and sizing; cooking, preserving, and other preparing of finished
products; packaging; and finished product storing and shipping.

          Pollutants and Sources.  Wastewaters from meat processing plants
contain organic matter, suspended solids and inorganic materials, such as
phosphates, nitrates, nitrites, and salt.  These materials enter the
wastestream as meat and fatty tissues, grease, meat juices, product spil.ls,
curing and pickling solutions, preservatives, and detergents.  In order to
define waste characteristics, the following basic parameters were used to
develop guidelines for meeting BPT and BAT:  five-day biochemical oxygen
demand (BOD5), total suspended solids (TSS), oil and grease, and fecal
coliforms.

          The wastes from the meat products industry contain compatible
pollutants.  There is no evidence that toxic pollutants as defined in
the EPA toxic pollutant effluent standards are present in the wastewaters
from any of the meat products industry subcategories.

          Control Technology and Costs.  Waste treatment practices in the
meat processing industry vary widely according to the age, size, and
location of plants.  Many now use primary treatment (including screening
and catch basins) for waste material  recovery.  Where secondary wastewater
treatment is practiced, anaerobic processes are commonly employed, followed
by a trickling filter, aerated lagoon, or activated sludge process.   BPT
guidelines for large plants discharging to waterways call for a major
removal of BOD,-, TSS, and grease through installation of primary treatment
(screening, equalization, dissolved air flotation)  followed by secondary
biological treatment, such as activated sludge or extended aeration
combined with a facultative lagoon and disinfection.  EPA assumed that BPT
investment for existing plants was limited to chlorination equipment.   BAT
guidelines project a further reduction in BODg, TSS, and oil  and grease by
means of filtration.  In-plant controls for reduction in wastewater  volumes
are also assessed.  Septic tanks are  considered to  provide BPT and BAT for
small processors.

          The Meat Packing (Phase I)  and Red Meat Products (Phase II)
categories were combined for the estimation of control  costs.

Meat Processing (Phase II) -
Poultry Processfng"

          Industry Characteristics.   The size of a  model  plant is
determined by the number of birds processed per day.  Large plants may
process in excess of 120,000 birds in a single day.

          This segment of the meat products industry has  been  divided  into
the following subcategories:   Chicken processor, Turkey processor, Fowl
processor (mature chickens, geese, and capons), Duck processor,  and  Further
processor (no slaughtering).
                                  W8.7-3

    -------
          The production processes for poultry processing include:
receiving birds; killing; bleeding, defeathering including scalding,
picking, singeing and washing; eviscerating, including viscera removal,
giblet processing, and carcass washing;  weighing, grading, packaging, and
chilling; and shipping.  These steps with minor variations, are used in t
processing of chickens, turkeys, fowl, and ducks.

          "Further Processing" includes  these poultry plants that conduct
further processing of poultry products only, but do no on-site slaughter.
Further processing of poultry products (chickens, fowl, turkeys, or ducks
includes the following steps:  receiving and storage; thawing; cut-up
operations; cooking; battering and breading; cooking; freezing and
packaging; and cold storing; or alternatively, after receiving and storag>
thawing; boning; dicing, grinding, and chopping; mixing and blending;
stuffing or canning; cooking; final product preparing; freezing and
^ v*u i i i i ty u i  wui m t 11^ )  v*uw rs, t 11
packaging; and cold storing
          The compound annual growth rate over the period 1973 to 1980 ha1
been estimated at between 4.9 and 5.6 percent.

          Pollutants and Sources.  Materials are generated through direct
processing of raw materials into finished products and from ancillary
operations.  The former group consists of blood, viscera, fat, and flesh
scraps, while the latter consists of cleaners and sanitizers used in
cleaning equipment and lubricants used in certain handling equipment.  Al
of these contribute to the release of organic materials, which exert a hi
BOD and elevate the oil, grease and suspended solids levels in the proces
water.  Phosphorus, nitrogen, and chlorides can also be found.

          The most significant single waste source in the poultry product
processing industry is blood from the walls of the blood tunnel which is
washed into sewers.

           The following basic parameters were used to define waste
characteristics and to develop guidelines for meeting 8PT:  BOD5, total
suspended solids, oil and grease, fecal  coliforms, and pH.  Poultry
industry subcategories wastes contain compatible pollutants as defined by
EPA Pretreatment Standards, hence pretreatment is not required.
Furthermore, no toxic materials as defined in the Toxic Pollutants Efflue
Standards are present in wastes from this industry.

          Control Technology and Costs.   Poultry wastes are usually
amenable to biological breakdown.FTew plants in various subcategories
this industry are currently meeting the  BPT limitations promulgated by EP
Most plants in all subcategories either  discharge to municipal treatment
systems or utilize some form of secondary biological treatment.  Either a
three-lagoon system or an activated sludge system, both followed by
chlorination, are suitable alternatives  for meeting BPT limitations
provided that in-plant grease and solids recovery are practiced.   Spray
irrigation (land application) is practiced by a few plants.   The sale of
crops grown on the irrigated acreage can help defray the costs of the lar
                                  W8.7-4

    -------
          To meet BAT limitations, most plants in all subcategories will
require, in addition to the BPT requirements, in-plant water conservation
practices, dissolved air flotation with pH control and chemical
flocculation for oil and grease removal, an ammonia control process, and a
final sand filter or microstrainer.

          Control costs were estimated for the Poultry Processing category
(Phase II).

Meat Products (Phase II) - Renderers

          Industry Characteristics.  Independent rendering resulting in
inedible products is distinguished from on-site rendering (slaughterhouse
or packinghouse)  producing edible (lard) products.

          Independent rendering plants range in size from very small plants
having only one to four employees and a value of shipments of about
$150,000 to large plants hiring in excess of 100 employees and having
annual sales of $12 million.  Average size plants, according to EPA, employ
23 persons and have annual sales of about $1.5 million.  For purposes of
pollution control costing, three plant size are used—1-9 employees, 10-49
employees, and 50 and more employees.

          A single product-related subcategory has been deemed adequate to
represent the activities and the pollutants of this industry.

          The production steps in independent inedible rendering are as
follows:

             Raw material  recovery
             Crushing and grinding
             Cooling and moisture removal
             Liquid-solid separation
             •Grease clarifying, storing, and shipping
             Meal grinding and screening
             Blending
             Meal storing and shipping
             Hide curing.

          Variations in the overall rendering process occur depending on
whether batch or continuous systems are used.

          Pollutants and Sources.   Rendering is a process to convert animal
products, by heating, into fats, oils, and proteinaceous solids.   A variety
of waste meat products including fat trimmings, meat scraps, feathers,
offal, bone, and whole carcasses are processed continuously or in batches.
The raw material is crushed, then cooked under pressure as required.  Fats
and oils are allowed to drain off, and the solid material remaining is
pressed, ground, and screened to prove a protein-bone meal mixture.   Tallow
and greases are separated.  The large amounts of moisture released in
cooking are collected by condensation.  Plants which process a large number
of dead animals may include facilities for hide curing.


                                  W8.7-5

    -------
          The principal operations and processes in rendering plants wher«
wastewater originates are raw material receiving, condensing cooking
vapors, plant cleanup, and truck and barrel washing.  Wastewaters from
rendering plants contain organic matter, suspended solids, and inorganic
materials, such as phosphates, nitrates, nitrites, and salt.  These
materials enter the wastestream as blood, meat and fatty tissues, body
fluids, hair, dirt, manure, tallow and grease, meal products, detergents,
and hide curing solutions (where used).

          The wastes from all subcategories in the meat products industry
contain compatible pollutants.  There is no evidence that~toxic• pollutant:
as defined in the EPA toxic pollutant effluent standards are present in t
wastewaters from any of the meat products industry subcategories.

          In order to define waste characteristics, the following basic
parameters were used to develop guidelines for meeting BPT and BAT:
five-day biochemical oxygen demand (BOD,-), total suspended solids (TSS),
oil and grease, pH, fecal coliform, and ammonia.

          Control Technology and Costs.  Wastes in the independent
rendering industry are amenable to biological treatment.  Off-site
rendering plants are divided nearly evenly between those which discharge
municipal sewer systems and those which treat their wastes.  Of the latte
group, half achieve no discharge of pollutants by means of spray irrigati
or ponding.  The treatment technology is essentially the same as for meat
processors.  BPT guidelines for plants discharging to waterways call for ,
major removal of BODr, TSS, grease, and fecal coliform bacteria through
installation of primary treatment (equalization, screening, dissolved air
flotation, and disinfection).  Next is secondary biological treatment, su
as activated sludge or extended aeration combined with a facultative lago
and disinfection.  BAT criteria call for further reductions in BOD,-, TSS,
and grease, to be achieved by sand filtration; ammonia control is also
mandated.  In-plant controls for reduction in wastewater volume are also
assumed.  New source performance standards are the same as BPT for existi
plants with the addition of ammonia limitations.

Control Costs—Meat Packing Industry

          Table W8.7.1 shows combined control costs for all sectors of th
Meat Products Processing Industry.
                                  W8.7-6

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           Chapter W8.8.  Leather Tanning and Finishing Industry
Regulations

             Effluent limitations and standards applicable to the leather
tanning and finishing industry were proposed in Federal Register, Vol. 44,
No. 128, July 2, 1979.  As a result of comments received from the industry,
EPA reviewed the entire database and all documentation supporting the
rulemaking; it also conducted a program to acquire supplemental data during
and after the comment period.  Regulations were promulgated by EPA in
Federal Register, Vol. 47, No. 226, November 23, 1982, which supercede all
previously promulgated BPT and BAT limitations and NSPS, PSES and PSNS.

Industry Characteristics

          The Leather Tanning and Finishing Industry (SIC 3111) comprises
establishments primarily engaged in tanning, currying, and finishing hides
and skins into leather.  It includes two types of tanneries: regular and
contract.  The regular tanneries, which account for about 70 percent of the
establishments in the industry, process purchased hides for shipment (or
sale) to other industries.  The contract tanneries, which are generally the
smaller plants, process raw materials owned by others on a fee basis.  Both
types of tanneries generate' significant amounts of effluent and are covered
by the proposed regulations on effluent guidelines.  In addition to the
tanneries, the industry also includes a small  number (less than ten percent
of the industry) of converters, who buy hides  and skins for processing by
others on a contract basis.  These are nomially small nonmanufacturing
agencies which do not fall within the purview  of the regulations.

          The 1977 Census of Manufactures indicates that there were a total
of 465 establishments in the industry, 315 regular tanneries, 107 contract
tanneries, and 43 converters.  EPA sponsored surveys of the industry
revealed that only 158 of the 422 tanneries (regular and contract) were
generating any significant levels of waste water.  The remaining
establishments classified as tanneries were either small nonmanufacturing
agencies or small plants involved in dry-finishing, only.

          The 158 tanneries are subcategorized into nine subcategories as
listed below.  The'first seven were identified in the proposed regulations.
The eighth and ninth subcategories were established in the recent
regulations.
                                  W8.8-1

    -------
                                                              Number of
             Subcategory      ,                                tanneries
1.  Hair pulp/chrome tan/retan-wet finish                         1TI
2.  Hair save/chrome tan/retan-wet finish                           7
3.  Hair save/non-chrome tan/retan-wet finish                      13
4.  Retan-wet finish-sides                                         16
5.  No beamhouse                                                   24
6.  Through-the-blue                                               13
7.  Shearling                                                       8
8.  Pigskin                                                         2
9.  Retan-wet finish-splits                                        14
    Total                                                         138

          Production in the industry reached a peak in 1965 with total
shipments of 33.1 million equivalent units of cattle hide.  Since then,
production has been declining; although, the level  has remained, relative
stable over the past five years.  Shipments in 1981 amounted to 19.5
million cattle hides.  The value of shipments (in current dollars) in 198
was $1.0 billion and increased to $2.2 billion in 1981.

Pollutants and Sources

          There are three major groups of standard processing steps
required to manufacture leather:

          1. Beamhouse processes in which hides or skins are washed and
             soaked and attached hair is removed;

          2. Tanyard processes in which the proteinaceous matter in the
             hides or skins reacts with and is stabilized by the tanning
             agent, primarily trivalent chromium; and

          3. Retanning and wet finishing processes in which further tanni
             is accomplished by chemical agents; color is imparted by dye
             lubrication is affected by natural and synthetic fats and
             oils; and related finishing steps are completed to dry the
             leather, correct surface irregularities, and apply surface
             coatings.

          The leather making processes are highly water dependent.  Large
quantities of water are used in the leather tanning and finishing industr
for the following purposes:

          1. For soaking.and washing unprocessed hides -or skins;

          2. As a medium for dissolving chemicals needed for the treatmen
             of hides or skins;

          3. As a carrier for dyes and pigments, which impart the desirec
             color to the final product; and

          4. For cleaning processing areas and equipment.


                                  W8.8-2

    -------
          As indicated above, water is essential to leather-making and is
used in virtually all leather-making processes.  Various chemical reagents,
chemicals, preservatives, biocides, coloring pigments, and solvents are
also integral to leathermaking.  Characteristics of the wastewater
effluents discharged by tanneries vary depending upon the mix of production
processes at a given plant.  General  wastewater constituents, which
contribute to numerous problems for POTW and industrial treatment
facilities, include large pieces of scrap hide and leather and excessive
quantities of hair and other solids that clog or foul operating equipment
and cause fluctuations in wastewater flow and pH.  The wastewater contains
high levels of suspended and settleable solids, biodegradable organic
matter, and significant quantities of toxic pollutants.

          The most important pollutant or pollutant parameters to the
leather tanning and finishing industry are:

          1. Toxic pollutants—trivalent chromium, lead, zinc, cyanide,
             phenol, substituted phenols, dichlorobenzenes, maphthalene,
             benzene, chloroform, ethyl benzene, and toluene;

          2. Conventional pollutants—BOD, TSS, pH, and oil and grease; and

          3. Non-conventional pollutants—ammonia, total kjeldahl  nitrogen
             (TKN), sulfide and COD.

          These and other chemical constituents contribute to odors,
facility corrosion, hazardous gas generation, and problems in treatment
plant performance and disposal  of sludges containing chromium and other
toxic pollutants.  Table W8.8.1 lists the major pollutants generated by the
leather tanning and finishing industry and the processes which generate
them.

Control Technologies

          The control technologies costed in this analysis are based on the
regulations promulgated in the  Federal Register of November 23, 1982.
These regulations specify effluent limitations for BPT, BCT, BAT,  and NSPS
for direct dischargers and PSES and PSNS for indirect dischargers.

          BPT.  The control technology selected for compliance with BPT
effluent limitations is extended aeration activated sludge biological
treatment, including coagulation-sedimentation with equalization.

          The pollutant parameters regulated by BPT are BOD, TSS,  oil  and
grease, total chromium and pH.

          BAT.  Equals BPT.

          NSPS.  The control technology required for compliance with New
Source Performance Standards (NSPS) is the same as that for BAT (BPT)
described above.  The pollutants controlled are also the same as those for
BPT listed above.
                                  W8.8-3

    -------








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          PSES.   The treatment technology  for complying  with PSES is
in-plant controls,  including stream segregation  and water conservation,
chromium recovery and reuse, segregated stream pretreatment, including fi
screening/equalization and catalytic oxidation of beamhouse wastewater;  p
control  and monitoring (pH and flow) at the combined sewer discharge;
coagulation-sedimentation of tanyard wastewater; and dewatering of sludge
PSES includes control capability for sulfide and chromium.

          The pollutants regulated by PSES are sulfide,  total  chromium,  a
pH.

          PSNS.   The treatment technology  for complying  with PSNS is  the
same pretreatment technology as that for PSES.

Costing  Methodology

          Water pollution control  costs to the leather tanning and
finishing industry for compliance with effluent  limitations, pretreatment
standards, and new source performance standards  were developed using  mode
plants of different sizes for the various  industry subcategories.  The
models utilized to represent the industry, their respective sizes,
capacities, and mode of discharge are shown in the Appendix.  The cost
equations and model plants used in the analysis  were developed from data
obtained in the Development Document.  Table W8.8.2 summarizes the
compliance costs for the leather tanning and finishing industry.
                                  W8.8-8

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                       Chapter W9.   Other Industries
          This group of industries contains  two point source categories:

          •  Pharmaceutical  Manufacturing
          •  Hospitals

          The costs developed for these two  categories are summarized  in
Table W9.  These costs and other data,  assumptions,  and details  are
discussed in the following subsections.
                                   W9-1

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                Chapter W9.1  Pharmaceutical Manufacturing

Regulations

          Interim final 8PT regulations for the Pharmaceutical
Manufacturing Point Source Category were promulgated on November 17, 1976
(41 FR 50676; 40 CFR Part 439) for five subcategories of the industry.
These BPT regulations set monthly limitations for BODc and COD based on
percent removals for all subcategories; no daily maxifnums were established
for these two parameters.  The pH was set within the range 6.0 to 9.0
standard units.  Average daily TSS values for any calendar month were
established for three of the five subcategories; no TSS values were
established for the remaining two subcategories.  Subpart A, which is
applicable to the fermentation operations, was amended on February 4, 1977
(42 FR 6814) to improve the language referring to separable mycelia and
solvent recovery.  In addition, the amendment allowed the inclusion of
spent beers (broths) in the calculation of raw waste loads for Subpart A in
those instances where the spent beer is actually in the wastewater
treatment system.  These regulations were never challenged.

          Regulations expanding water pollution control requirements were
proposed for the industry on November 26, 1982 (47 FR 53584).  In this
round of rulemaking, efforts were directed toward amending BPT based on a
more complete data base and instituting BCT and BAT effluent limitations,
new source performance standards (NSPS), and pretreatment standards for
existing and new sources (PSES and PSNS respectively) that will result in
reasonable further progress toward the national goal of eliminating the
discharge of "classical" and toxic pollutants.  The proposed regulations,
however, do not require the installation of any particular technology.
Rather, they require achievement of effluent limitations representative of
the proper application of the recommended or equivalent technologies.

Industry Characteristics

          Pharmaceutical manufacturing, using many different methods and
raw materials to create a wide range of products, is one of today's more
profitable industries.  Products include medicinal and feed grades of
organic chemicals having therapeutic value, whether obtained by chemical
synthesis, fermentation, extraction from naturally occurring plant or
animal substances, or refining a technical grade product.  Pharmaceutical
products, processes, and activities include:

          •  Biological products covered by the U.S. Department of
             Commerce, Bureau of the Census Standard Industrial
             Classifications (SIC) Code No. 2831.

          •  Medicinal chemicals and botanical products covered by SIC Code
             No. 2833.

          •  Pharmaceutical products covered by SIC Code No. 2834.


                                  W9.1-1

    -------
          t   All  fermentation,  biological  and natural  extraction, chemica'
             synthesis,  and formulation  products which are considered as
             pharmaceutically active ingredients by the Food and Drug
             Administration, but are not covered by SIC Codes Nos.  2831,
             2833, or 2834.  Products of these types,  such as citric acid
             which are not regarded as pharmaceutically active ingredient!
             are  included if they are manufactured by  a pharmaceutical
             manufacturer with  processes resulting in  wastewaters closely
             corresponding with those from the manufacture of
             pharmaceutical products.

          •   Cosmetic preparations covered by SIC Code No. 2844 which
             function as a skin treatment.  This group of preparations do>
             not  include products such as lipsticks and perfumes which
             serve to enhance appearance or to provide a pleasing odor an<
             do not provide skin care.  In general, this would also exclui
             deodorants, manicure preparations, and shaving preparations
             which do not primarily function as a skin treatment.

          •   Products with multiple end  uses which are attributable to
             pharmaceutical manufacturing as a final  pharmaceutical
             product, component of a pharmaceutical formulation, or a
             pharmaceutical intermediate.   Products which have
             non-pharmaceutical uses may also be covered entirely by this
             point source category provided that they  are primarily
             intended for use as a pharmaceutical.

          •   Pharmaceutical research includes biological, microbiological
             and  chemical research, product development, clinical and pil<
             plant activities,  but excludes farms which breed, raise and/'
             hold animals for research at another site.  Also excluded an
             ordinary feedlot or farm operations utilizing feed which
             contains pharmaceutically active ingredients.

          EPA has identified 464 potential pharmaceutical facilities in t
United States and its possessions.  Approximately 70 percent of the plant
with significant  wastewater discharges are.located east of the Mississipp
River.  Older plants are located in the  Northeast and  Midwest while newer
facilities tend to be located in the nation's "Sun Belt."  Puerto Rico
contains almost ten percent of the total-number of pharmaceutical
facilities and is developing into a major center for pharmaceutical
manufacturing.

          Pharmaceutical manufacturers use four major  kinds' of
manufacturing activity in the production of their products:  fermentation
biological and natural extraction, chemical synthesis, and formulation.
Over half of the  pharmaceutical facilities surveyed (271) perform only
formulation, a smaller number (47) are involved only in chemical synthesi
and a total  of 42 plants use both chemical synthesis and formulation.  Th
remainder of the  plants perform fermentation, biological, or natural
extraction,  or a  combination of activities.
                                  W9.1-2

    -------
          Ten percent of the pharmaceutical facilities are direct
dischargers, 53 percent are indirect dischargers, 21 percent are zero
dischargers, and 16 percent utilize more than one mode of wastewater
discharge.

          The industry was first subcategorized during the development of
the 1976 BPT guidelines into five product or activity areas based on
distinct differences in manufacturing processes, raw materials, products,
wastewater characteristics, and treatability.  These subcategories were
defined as:

          Subcategory A - Fermentation Products

          Subcategory B - Biological and Natural Extraction Products

          Subcategory C - Chemical  Synthesis Products

          Subcategory D - Fermentation Products

          Subcategory E - Pharmaceutical Research

          Fermentation is the basic method used for production of most
antibiotics and steroids.  It is accomplished by preparing a seed, allowing
the seed to ferment a batch of raw materials, and then recovering the
desirable product by solvent extraction, precipitation, or ion exchange.

          Biological and natural extraction involve the removal of
pharmaceutical  products from natural sources such as plant roots and
leaves, animal  glands, or parasitic fungi.

          Chemical  synthesis is used in the production of most drugs.  They
are prepared in batch reactors which can be used for many processes
including heating,  chilling, mixing, condensation, vacuum evaporation,
crystallization, and solvent extraction.  These reaction vessels are often
constructed of stainless or glass-lined steel for corrosion resistance.
This type of construction with the appropriate auxiliary equipment enables
these vessels to be used for multiple functions.  Since these reactors are
versatile, many different compounds can be produced in any one vessel.

          Formulation is the process by which Pharmaceuticals are prepared
into forms useable  for consumers.  These forms include tablets, capsules,
liquids, and ointments.  The active ingredients are mixed with filler,
formed into a useable state (dosage quantities), and packaged for
distribution.

          Pharmaceutical research covers research in any of the active
ingredients areas.

          EPA reevaluated the 1976 subcategorization of the industry in
light of newly acquired information to confirm the conclusions of the
previous studies and to determine the possibilities of further subdividing
or combining existing subcategories.  As a result, EPA decided that no


                                  W9.1-3

    -------
additional  subcategories were needed and, in fact, there was no need to
distinguish among the original  subcategories.  This decision was made aft*
consideration of the following points.

          •  Most of the industry subject to regulation is composed of
             plants using more than one process.  Wastewaters from all the
             processes are routinely combined before treatment for
             conventional and nonconventional pollutants.  Additionally,
             the relative volumes of wastewater from the various processes
             are subject to considerable variation.  Thus, since wastewate
             in most plants is not normally distinguishable by process, it
             is difficult to apply different limitations to different
             subcategories.

          t  The product/process diversity within each subcategory tends 1
             obscure the distinctions between subcategories.  In some
             cases, differences in pollutant loadings for plants within a
             subcategory may be greater than for plants from different
             subcategories.  Subcategorization schemes along different
             product/process lines were considered, but were rejected as
             being too complex and not necessarily more accurate.

          •  Wastewater treatability at plants within each subcategory is
             not characteristically related to the product/process engagec
             in by each manufacturing subcategory.  Conventional pollutan
             loadings for BOD,- and TSS are generally amenable to reductior
             by biological treatment, regardless of their subcategory
             source.  It has also been demonstrated that reduction to
             identical pollutant levels is achievable for wastewater from
             each of the different subcategories.  Pollutant loadings may
             vary within each subcategory and across subcategories, but
             such differences may be addressed by design and operating
             modifications to the biological systems.  This conclusion is
             evidenced by the fact that the current BPT regulation
             establishes identical limitations for each subcategory
             covered.  The costs of treatment are a function of flow, raw
             waste load, and effluent level to be achieved and not process
             per se.

          t  The existing Subcategorization scheme is irrelevant to the
             regulation of toxic pollutants for this industry.  The
             occurrence of toxic pollutants in a plant's wastewater is no'
             dependent on its process subcategory designation(s), but on
             the particular mix of individual product/processes.

          t  Available performance data as well as screening and
             verification sampling results for toxic pollutants suggest
             that the industry can be equitably regulated by a single set
             of limits.  Therefore, one set of limitations and guidelines
             is proposed for the entire industry, excluding facilities
             which only perform research.
                                  W9.1-4

    -------
Pollutants and Sources

          Wastewater discharges from pharmaceutical manufacturing
facilities are not entirely related to the particular processes used.  A
significant portion of the wastewater from all four general process
operations may consist of washwater from floor and equipment cleaning,
spills from bulk processing, spent raw materials, and noncontact cooling
water.  Some wastewater may be generated as a result of the specific
requirements of a particular process, e.g., air scrubber wastewater from
some extraction processes.

          The most commonly found pollutants or pollutant parameters in the
effluent of pharmaceutical manufacturing facilities are:

          a.  toxic pollutants (cyanide, benzene, methylene chloride,
toluene, chromium, copper, lead, mercury, nickel, and zinc),

          b.  conventional pollutants (BOD,-, TSS, and pH), and

          c.  the nonconventional pollutant parameter COD.

          In addition to their adverse effect on water quality, aquatic
life, and human health, these and other chemical constituents contribute to
equipment corrosion, hazardous gas generation, treatment plant
malfunctions, and possible problems in disposing of sludges containing
toxic chemicals.

          Following are the pollutants to be regulated by the 1983 proposed
regulations for the pharmaceutical industry.

          •  BPT.  The conventional pollutant TSS and the toxic pollutant
             cyanide will be controlled through implementation of the
             revision to the BPT regulation.  TSS limitations replace
             existing limitations and will apply to all  plants covered in
             the existing BPT regulation.  Cyanide limitations are new and
             will apply to all plants covered in the existing BPT
             regulation except for pharmaceutical research facilities.
             Existing BPT limitations for BODc, COD, and pH are
             unchanged.

          •  BAT.  The nonconventional pollutant parameter COD and the
             toxic pollutant cyanide will be controlled through
             implementation of the proposed regulation.   Toxic metal and
             organic pollutants may be regulated on a case-by-case basis.

          0  BCT.  Pollutants controlled by BCT regulation for the
             pharmaceutical industry include the conventional  pollutants
             BODj. and TSS.  The pollutant parameter pH is specified again
             as a range of 6.0 to 9.0.

          •  PSES and PSNS.  Cyanide is controlled by PSES and PSNS
             regulations.


                                  W9.1-5

    -------
Control Technologies and Costs

          Status of In-place Technology
          Current treatment practices in the pharmaceutical industry
include both in-plant and end-of-pipe pollution control technologies.
Approximately 72 percent of direct dischargers have some type of
end-of-pipe treatment system in place, 17 percent of direct dischargers
utilize in-plant technology, and ten percent of direct dischargers have
both end-of-pipe and in-plant control technologies in place.

          The majority of those using end-of-oipe systems employ
equalization and neutralization followed directly by biological treatment
In addition, some facilities use primary treatment, physical-chemical
treatment, and other methods, e.g., polishing ponds and filtration.

          The majority of plants utilizing in-plant controls rely on
solvent recovery.  In addition, some plants use cyanide destruction,
chromium reduction and metals precipitation, steam stripping, and other
allied treatment techniques.  Solvent recovery techniques are widely
practiced in the industry because of the economic value of reusing
solvents.  Some plants, in order to make reuse possible, try to use a sma
number of different solvents.  When recovered solvent mixtures are too
complex to be separated and reused, they are disposed of by incineration,
landfill ing, deep well injection and contract hauling.  Wastewater
containing significant amounts of volatile organic solvents may be treate
by steam stripping.  Preliminary studies indicate that steam strippers in
use by the industry may reduce such commonly used solvents as benzene, 1,
2-dichloroethane, chloroform, ethylbenzene, methylene chloride, and tolue
to a concentration level  of 50 ug/1 and achieve a 55 percent reduction in
the concentration level of phenol.   Cyanide is destroyed by using chemica
oxidation (alkaline chlorination or ozonation) and thermal/pressure
techniques.  Cyanide destruction systems in the pharmaceutical industry c
achieve a long term average effluent concentration of 200 ug/1 total
cyanide.   This performance is confirmed by the results of similar studies
in the metal finishing industry.  Metals are treated by chromium reductio
and either hydroxide or sulfide precipitation with concentration levels
ranging from 100 to 500 ug/1 being achieved for various toxic metals.

          Many new pharmaceutical plants are being built with in-plant
source controls which may reduce the need for additional controls further
downstream.  Examples of in-plant source controls include modification of
production processes, separation of wastes as they are produced, use of
automatic pollutant detection equipment within the process, chemical or
solvent substitution, material reclamation, and water reduction or recycl
Pharmaceutical manufacturers, however, cannot practice substitution of
solvents  or use of recovered chemicals as easily as other chemical
manufacturers.  FDA requirements specify that any recycled chemicals or
solvents  must meet the same specifications as virgin chemicals or solvent
to be used in an FDA approved drug (active ingredient) manufacturing
process.   The substitution of a different solvent or chemical  in an FDA
approved  manufacturing process may reopen the approval process for the dr
                                  W9.1-6

    -------
involved.  If contaminants are present in the recycled solvents, the
manufacturer must prove to FDA that no deleterious effects result in the
active ingredient and final product.  Pharmaceutical manufacturing plants
also are required by FDA to track by lot number all chemicals used in each
process.

Cost Data

          Capital and O&M costs were estimated exogenously using values
reported in the 47 FR 53584 and the recent Development Document
(EPA440/1-82/084).  These costs are for BPT, BCT, BAT, PSES and NSPS and
are as follows (in 1982 dollars):
          BPT
          BCT
          BAT
          PSES
          NSPS

          Total
Capital costs

S 2,000,000
 21,800,000
      0
  1,000,000
     na

$24,800,000
Annualized costs

  $  723,000
   8,500,000
        0
     379,000
       na
  $9,602,000
The annualized cost includes both capital related costs and
make these costs compatible with ABTRES it was necessary to
costs from the annualized estimates.  This was accomplished
the detailed costs presented in the Development Document.
                                  O&M costs.  To
                                  separate O&M
                                  by reviewing
          Equipment is assumed to be replaced in 15 years and should
represent 90 percent of the original capital costs.  O&M costs are not
expected tg change significantly due to equipment replacement as reflected
in the ABTRES input file.

          Costs-are summarized in Table W9.1.1.
                                  W9.1-7

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                          Chapter W9.2  Hospitals
Regulations
          Only BPT regulations have been promulgated for hospitals,
although other regulations have been proposed.  The costs of compliance are
based on promulgated and proposed regulations and have not been updated
since it not known when BAT and NSPS regulations will be promulgated.

Industry Characteristics

          The U.S. Hospital industry includes over 7,000 hospitals
primarily engaged in providing diagnostic services, extensive medical
treatment, surgical  services, and other hospital services as well as
continuous nursing services.  Specific hospital types are:

          •  General medical and surgical hospitals

          •  Psychiatric hospitals

          •  Specialty hospitals except psychiatric hospitals; childrens
             hospitals; orthopedic hospitals; chronic disease hospitals;
             maternity hospitals; geriatric hospitals; eye, ear, nose, and
             throat hospitals; tuberculosis hospitals.

          The vast majority of hospitals are nonprofit institutions in
which expenses are recovered by charges for hospital  services.  Most
hospitals are located in densely populated areas and discharge into
municipal sewers.  The Development Document estimated that approximately 90
percent of all hospitals discharge into municipal sewers.  Table W9.2.1
presents estimated numbers of hospitals that have their own treatment
facilities.

               Table W9.2.1.  "Direct discharger" hospitals*
Bed Size
Category
50-99
100-199
200-299
300-399
400-499
500 or more
Total Number
of Hospitals
1,748
1,533
766
444
291
634
Estimated Number of Hospi
With Own Treatment Facili
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153
77
44
29
63
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*Assumption:  Only 10% of all  hospitals in each size category will  have
              their own wastewater treatment facilities.
Source:  "Hospital Statistics:  1975 Edition".


                                  W9.2-1

    -------
Pollutants and Sources

          The primary sources of wastewater streams from hospitals includ*
sanitary wastewaters, discharges from surgical  rooms, laboratories,
laundries, X-ray departments, cafeterias, and glassware washings.
Wastewaters from hospitals can be characterized as containing BOD,;, COD,
and TSS concentrations comparable to normal domestic sewage and riadily
amenable to biological treatment.

          Specific contaminants in hospital wastewater include mercury,
silver, barium, beryllium, and boron.  Mercury is used in laboratories,
silver and boron result from X-ray development.  Barium is used in
diagnostic work and beryllium is used in dental clinics.

Control Technology and Costs

          The technology for the control and treatment of waterborne
pollutants in the hospital industry can be divided into two broad
categories:  in-plant control and end-of-pipe control.

          Specific in-house control practices that are applicable to the
hospital industry include:  recovery of silver from spent X-ray developer
prevention of discharge of volatile solvents and toxic chemicals into
drains, and restriction of the discharge of mercury-containing compounds
into the sinks and drains.

          To meet the proposed NSPS and BAT regulations,  end-of-pipe
treatment technologies equivalent to biological treatment followed by mul
medi filtration are recommended.

          Relatively few hospitals treat their wastewater since most
hospitals are located near urban areas.  Of the hospitals that treat thei
own wastewaters, the most prevalent end-of-pipe wastewater treatment syst
is the trickling filter plant; however some hospitals used activated slud
treatment systems.

          Treatment costs are summarized in Table W9.2.2.
                                  W9.2-2

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                      Chapter W1Q.  Nonpolnt Sources

          During the 1979 oversight hearings on the Clean Water Act,
Congress concluded that:  "the attainment of a goal of 'fishable'
swimmable' waters is highly dependent on the degree to which nonpoint
pollution can be controlled...".  However, controlling nonpoint sources,
primarily agricultural runoff, urban runoff, silvicultural runoff, and mine
drainage is extremely difficult, both technically and politically.
Technically, controlling pollutants carried from the surface of the land
into waterways by rain and snowmelt requires careful consideration of such
site-specific factors as soil type, crop type, slope, and proximity to
water body.  Politically, an effective control program must consider how
implementation will be achieved; through regulation, technical assistance
education, or cost-sharing.

          The need to tailor both control techniques and implementation
strategies to the particular needs of specific sites makes the use of a
nationally uniform technology based standard, such as those mandated by
Congress to control pollution emitted from point sources, (i.e. industrial
and municipal discharge pipes) impossible.  Instead, in 1977 Congress
mandated that each state develop and implement a plan for achieving state
water quality goals.  State water quality plans were supposed to provide
states with a vehicle for addressing the nonpoint source problem on a
site-specific basis.  However during the formulation of these plans states
discovered a serious lack of information concerning the effectiveness of
the various control options.  Due to this lack of information, and a lack
of incentives and financial resources, very few states have actually
implemented their water quality plans.  As a result nonpoint source
pollution was identified as the most serious cause of water quality
problems in six out of ten EPA Regions (1983 Environmental Management
Reports).

          The lack of verifiable cause-and-effect information, and the
necessity for control programs to be individually designed, also makes it
difficult to estimate the national cost of controlling nonpoint source
pollution.  Nevertheless, a variety of governmental agencies and private
organizations have attempted to provide national cost estimates.  This
chapter provides an overview of these estimates.  Although it is the best
available information, in many cases-the data are unverified-and further
work remains to be done.  Thus, this report should be viewed as
illustrating the range of costs for implementing a variety of control
strategies—not as projected estimates of actual investments.   A single
estimate of non-point source control costs will not be presented.

          The benefits associated with each cost estimate also vary.  The
lower level, less expensive control options will achieve state water
quality goals either to a limited extent in the near term or fully over a
greater length of time.  The higher level, more expensive options are
designed to fully comply with water quality goals in a shorter time frame.


                                   W10-1

    -------
However, the lower level  options are expected to achieve greater reductio
in pollutant loads per dollar spent and will result in improved water
quality, if not meeting the standards in all cases.

          The following sections present and compare the costs of differe
options for controlling water pollution from agricultural, silvicultural,
and urban nonpoint sources.  This chapter also contains a section
discussing the cost of administrating and implementing a nonpoint source
program.  All costs are in 1981 dollars.


                        Agricultural Control Costs

          Runoff from agricultural lands is the largest and most pervasiv
contributor to the nonpoint pollution problem.  Over half of the total
man-made sediment load results from agricultural activities.  Agricultura
activities also contribute significant amounts of nitrates, phosphorus,
various pesticides, and salts.  Most techniques for controlling
agricultural runoff require the farmer to alter current management
practices.-  For example, the most commonly used erosion control practice
'best management practice1 (BMP) is conservation tillage; a technique
whereby the farmer reduces land disturbances by reducing the amount of
plowing and discing.  Other techniques, such as building a detention basi
to catch runoff, require the farmer to make structural changes.  Structur
techniques are usually extremely expensive while nonstructural techniques
may even increase farm profits.

          In 1980 the U.S. Department of Agriculture completed a Soil anc
Water Resources Conservation Act (RCA) Appraisal.  Based on the results c
this study it is possible to estimate the cost of controlling agriculture
pollution in three different ways.  The first is to install all the
practices necessary to prevent soil erosion.  The second is to modify the
erosion control program to focus on water quality problems.  The third  is
to install only nonstructural control techniques.

          It is also possible to estimate the cost of implementing a
national conservation tillage program.  This would be the least expensive
manner of controlling agricultural pollution short of leaving fields  in
uncultivated, unforaged pasture.  The national conservation tillage
estimate is based on a demonstration program recently completed in the
western basin of Lake Erie.

1980 Soil and Water Resources Conservation Act Appraisal

          According to the 1980 Soil and Water RCA appraisal, a nationwic
program to control agricultural nonpoint source pollution would cost  aboi
$7.3 billion over ten years  (see Table W10.1).  All water quality probler
resulting from agricultural  nonpoint sources would be well controlled by
this option.  This estimate  includes the application of both structural c
nonstructural control practices to control erosion throughout the nation.
Cost-sharing and educational and technical assistance would be utilized t
ensure  BMP  implementation.
                                   W10-2

    -------
                                Table W10.1

       Cost of 10 year program to control agricultural NFS pollution
                    (RCA projections in billions of 5)
                  Program Segment                 Billions of 1981 dollars


          Problem Identification*
          Planning*
          Research*
          Technology Transfer*
          Application of Controls (BMPs)
          Enforcement

            Total Federal & State Costs                       7.3

                            Annual Cost                         .73t
* Federal support programs.
t Costs are not amortized for this estimate or any of the options.

1980 RCA Appraisal Modified to Focus on Water Quality

          The $7.3 billion RCA erosion control projection can be modified
by focusing implementation on only those areas needing controls to improve
water quality, as opposed to controlling all erosion problems.  This would
reduce the cost for application of controls to approximately $5.8 billion
over the ten year life of the program.  Application would be ensured
through a program of cost-sharing.  Identification of the critical areas
requiring nonpoint source controls to protect water quality is based on a
1980 evaluation of the 105 agricultural producing areas completed by
Resources for the Future (RFF)(See Figure 1).

          The procedures and estimates used by USDA for the RCA appraisal
and the delineation of critical areas were combined to arrive at the
modified estimate below (See Table W10.2).  These figures are based on
observed field values for the cost per critical acre to control selected
pollutants.  Sediment control figures are based on the expenditure required
to reduce sediment reaching streams to .2 tons/acre.

          As sediment is controlled, so is a portion of the toxics and
nutrients which are attached to soil particles.  To compensate for this
overlap factor, the costs for nutrient and toxics control are reduced by
50%.
                                   W10-3

    -------
                              FIGURE 1

         Critical areas where potential for degraded water
         quality is high due to agricultural NFS pollutants
* Source:  USDA.  "1980 RCA Appraisal Part II."
                               W10-4

    -------
     Table W10.2.  Annual costs to control agricultural NFS pollutants
Pollutant
Sediment
Nutrients
Toxics
Organic
wastes

Critical areas
70 million acres
10 mil lion acres
85 million acres
1 ,550 systems/yr

Annual control
cost
$4.50/acre
$4.50/acre
$5.40/acre
$9k/system
Total
Overlap
factors
N/A
50%
50%
N/A
Annual
Total annual
cost ($000,000)
1981 dollars
5315
23
230
14
Cost $582
1980 RCA Appraisal Modified to Only Nonstructural Techniques

          The second way to modify the RCA appraisal erosion control cost
is to limit cost-sharing of management practices to nonstructural control
measures.  Structural control techniques, for example terracing, are
expensive and appear to be less cost-effective than nonstructural control
measures.  This modification would reduce the cost for application of
controls to approximately $2.7 billion over the ten year life of the
program.  However, this type of reduction would also limit the program's
effectiveness.

National Conservation Tillage Program Estimate

          In 1973 the U.S. Army Corps of Engineers implemented a program to
provide educational  and technical  assistance in conservation tillage for
farmers in the western basin of Lake Erie.  This demonstration program is
the basis for the development of the Conservation Tillage Program estimates
in Table W10.3.  These estimates are based on applying the costs identified
in this project to the critical areas identified in the RFF study.

          The demonstration project also found that implementation of an
Integrated Pest Management (IPM)(Column F) program is recommended for 45
percent of the critical areas.  Costs for an IPM program involving
educational and technical assistance to farmers were estimated by reviewing
similar cost data.  Also, nutrient management was found to be essential for
controlling NFS pollution from 50  percent of the critical areas.  Costs for
a nutrient program similar to the  IPM program were estimated nationally in
Column G.

State Program Management Costs

          The FY 1979 EPA Water Quality Management Needs Survey projected
state needs for implementing an agricultural NFS control program.  This
                                   W10-5

    -------
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                                                                    H10-6

    -------
needs survey estimated that $95* million, over a four year period, or $24
million annually (non-amortized), would be necessary to identify problems,
and develop and administer a nonpoint source program.  This would fund
state programs ranging in size from $6,683 to $6.1 million annually.  The
average annual program cost is $387,585 and utilizes eleven staff years.
The program size and corresponding management costs are based on the
magnitude of the NFS problem identified in each state.

Comparison of Total Agricultural Program Costs

          Total annual NFS control costs are estimated to range from
approximately $58 million for a relatively low-level conservation till-age
educational program to $734 million for a comprehensive cost-sharing
program that includes program management, technical assistance, training,
education, and cost-sharing for BMPs (See Table W10.4).

       Table W10.4.  Total annual control costs for agricultural NFS
                    (Costs in millions of 1981 dollars)


                             State program
     Control options       management cost*    Control costs    Total costs
Option 1 - RCA Control
Program Estimate
Option 2 - RCA Control
$24
24
$734
581
$758
605
 Costs Modified to Focus
 More on Water Quality

Option 3 - RCA Control             24               266             290
 Program Estimate for
 Nonstructural BMPs

Option 4 - National               24                 58              82
 Conservation Tillage
 Program
* The State Program Management Cost does not take into consideration the
varying control levels of the estimated programs (i.e., higher levels of
control will require higher levels of state program management).   Added
management costs are included in some of the higher level control cost
options.  Comprehensive evaluation of management costs is beyond the scope
of this assessment.
                                   W10-7

    -------
                           Silvicultural Sources

          Forty states have identified silvicultural NFS pollution as a
significant or potential problem (see Figure 2).  Most of these states
employ a voluntary approach to encourage the use of best management
practices.  The remainder use a regulatory approach; applying existing
water quality regulations to forest lands.  Resource requirements for the:
types of programs are modest, usually consisting of the addition of a watf
quality specialist to the State Forester's staff and increasing training
materials and resources.

          There are two distinct components of a silvicultural nonpoint
source control program; program management and application of best
management practices.  These costs will  be discussed individually and the
combined to indicate total program costs.

Program management Costs

          The administrative costs associated with the 'start-up1 of a
silvicultural control program, either voluntary or regulatory, will be
significantly higher than costs in subsequent years.  Administrative cost
will decrease as voluntary programs are developed and carried out, and as
staff members are hired and trained.  Conversely, regulatory programs wil
have higher costs for enforcement, staff, and equipment.  These costs are
generally fixed and continuing.

          Table W10.5 shows program costs for two levels of effort for th
35 voluntary  (and quasi-regulatory) program states.  Level 2 provides for
an enhanced program that would result in additional work such as BMP
evaluation and more rapid implementation.

Cost of Applying Controls

          Most water quality problems occur when steep- slopes and fragile
soils are disturbed for timber harvesting or road building.  Every year
approximately 4 million acres of harvest area are so disturbed that some
application of 8MP--either land treatment or management techniques is
required.  Those areas needing controls are defined as critical areas.

          The cost of applying controls ranges from $2.25 per acre for
low-level treatment to a high of $12.60 per acre.  These costs are for
activities such as seeding unused road beds or constructing water barrier
on skid trails and roads.  The high-level treatment also includes operati
and maintenance costs associated with structural control measures.

          Table W10.6 identifies the major timber harvesting regions in t
nation, their annual harvest areas, critical acreages within the harvests
the percentage of high and low-cost BMPs in use, and the total cost for
their application.
                                   W10-8

    -------
                                 Figure 2
                                 TYPES OF STATE NONPOINT SOURCE CONTROL
                                  PROGRAMS FOR SIIVICULTURAL ACTIVITIES
    Hawaii
         REGULATORY OR
         QUASI-REGULATORY
         VOLUNTARY OR
         STATE/FEDERAL AGREEMENT

         MO PROGRAM
REGULATORY

Alaska
Ca 1 i f o rn i a
Idaho
Oregon
Washington
QUASI-REGULATORY

Hawaii
Maine
Nevada
New Hampshire
Pennsylvania
Massachusetts
Reference:
                 CONTROL APPROACH

                                 VOLUNTARY

                                 Alabama
                                 Ari zona
                                 Arkansas
                                 Colorado
                                 Connecticut
                                 Florida
                                 Georgia  '
                                 IIlinois
                                 Kentucky
                                 Louisiana
                                 Maryland
                                 Michigan
                                 Minnesota
                                 Mississippi
                                 Montana
                                 New Jersey
"Nonpoint Source  (NPS)  Water  Pollution Control
(Draft),  C-19-83,  prepared  by  US EPA Office of
Operations,  Water  Planning  Division.
     New Mexico
     New York
     North Carolina
     Oklahoma
     South Carolina
     South Dakota
     Tennessee
     Utah
     Vermont
     Virginia
     West Virginia
     Wisconsin
     Wyomi ng
Needs  and Costs'
Water  Program
                                   W10-9

    -------
       Table  W10.5.   Costs  of  administering  voluntary  and  regulatory
           programs  for  controlling  silvicultural NPS  pollution
                       (in  millions  of  1981  dollars)
Program costs for Program costs for Total national
Year voluntary states regulatory states program cost
Level 1 Level 2
1st $ 1.58 $ 3.78
2nd 1.11 3.33
to 1.11 3.33
20th 1.11 3.33
20 Yr. Total Costs 22.67 67.05
10 Yr. Total Costs 11.34 33.53
Average Annual
Costs $ 1.13 $ 3.35
$ 4.68
4.68
4.68
4.68
93.60
46.80
$4.68
Level 1 Level
$ 6.26 $ 8.'
5.79 8.
5.79 8.
5.79 8..
116.21 160.
58.11 80.
$ 5.81 $ 8.
NOTE:  Both levels include the costs  of developing  an  educational  and
       information training program.   For each  of the  35  voluntary states
       level  1 accounts for one man year per state,  and level  2,  for thre
       man years per state.
                                  W10-10

    -------










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    -------
Total Cost for Controlling Silvlcultural NPS Pollution

          The estimated cost of controlling silvicultural NPS pollution i
approximately $33.5 - to S35.7 million annually for the 10-year program.
This includes the annual cost of administering voluntary, quasi-depending
on the level  of support as well as the annual cost of applying control
measures ($27.2 million) on the 4 million acres of land disturbed by
silvicultural operations.

                 Costs of Controlling Water Pollution from
                    Urban Storm-Water and Construction

          Storm-water runoff from built-up urban areas and erosion from
urban construction sites are significant nonpoint sources of pollution.
According to the Aquatic Life Survey, (EPA, 1982) urban storm-water affec
about 20% of the river miles across the nation, and construction about 3%
The problems associated with sedimentation from construction sites are
visible, and the control methodologies are well understood and proven.  I
contrast there has been some confusion over the exact nature and extent o
water quality problems caused by urban stormwater and the effectiveness o
available control measures.  The next two sections examine these threats
water quality and the costs of controlling them.

Controlling Runoff of Urban Storm Water

          In light of the unknowns associated with urban runoff, EPA
initiated its Nationwide Urban Runoff Program (NURP) to improve available
information on sources of urban sedimentation and their effects on water
quality.  The NURP funded monitoring projects at 28 sites throughout the
nation.  Preliminary results indicate that water quality problems arisinc
from urban storm-water runoff, and the control measures to prevent or
alleviate such problems, are heavily site-specific and therefore must be
approached from that perspective (U.S. Environmental Protection Agency,
"Draft Final Report of the Nationwide Urban Runoff Program:  Volume I."
(1982).

          A wide range of technologies exists for controlling urban runof
They can be as simple as straw bales to catch sediments in runoff or as
complex as physical and chemical treatment and chlorination.  All can be
effective depending on circumstances.  However, based on the NURP findinc
it would be difficult to justify a national program to construct separate
treatment plants for storm sewer discharges.

          In developing and redeveloping areas, the quality of urban rune
can be controlled easily for a moderate cost.  Developments can be desigr
to decrease runoff by using natural drainage systems, greenways,
infiltration trenches, and porous pavement to increase infiltration.
Detention basins have been found to be one of the more cost-effective
practices for the long-term control of urban runoff.  This conclusion is
based on actual monitoring over several years of the performance of eleve
detention basins by NURP.  Reductions of up to 95 percent of most
conventional pollutants were obtained in these detention basins.


                                  W10-12

    -------
          The NURP projects also demonstrated that the type of receiving
water body is significant in determining costs.  For example, urban runoff
causes the biggest problems in quiescent water bodies, such as lakes.
Lakes are natural  sinks that collect and store pollutants.  In contrast,
urban runoff is less of a problem in large rivers with moving water or in
the oceans where dilution is great.  It follows that less controls are
needed to protect rivers and oceans than lakes.

          The level of control necessary is also dependent on the desired
benefit from improving quality:  aesthetics, fish and wildlife, and/or
recreation.

          The level of control, and consequently the cost of control, is
highly dependent on the effectiveness of the detention basin.  One of the
critical factors in the effectiveness of detention basins is the ratio
between the area of drained urban surface to the detention basin's volume.
Generally, the greater the volume relative to the drained urban surface,
the greater the basin's efficiency in removing pollutants.  Based on this
finding, a method was developed in the NURP study to determine the level of
control by the basin's volume.  Specifically, detention basin costs were
estimated for achieving a 40 percent reduction for aesthetics, 85 percent
reduction for fish and wildlife, and 95 percent reduction for recreation.
Based on the above assumptions, Table W10.7 and W10.8 summarize the cost
estimates for urban runoff control.  Table W10.9 breaks down the cost of
treatment based on water body type.
 Table W10.7.  Option 1 - Total cost of controlling storm sewer discharges
                from all urban areas (13.2 million acres)*
                       (in millions of 1981 dollars)


 Beneficial use                  Capital                Annual  0 & M Costs*


Aesthetics                      $1,141.                       S 46.
Fish and Wildlife                3,623.                        145.
Recreation                      11,498.                        460.

*Annual 0 & M is 4 percent of capita] costs.
                                  W10-13

    -------
 Table W10.8.  Total capital costs of controlling storm sewer discharges
        by receiving water body type (in millions of 1981 dollars)


Beneficial Use  Streams <10'  Rivers >10'   Lakes  Estuaries  Oceans   Tot;
Aesthetics
Fish and Wildlife
Recreation
(includes
disinfection)
$233.
933.
3,273.


$ 318.
1,399.
4,549.


$357.
357.
402.


$ 233.
933.
3,273.


SO
0
0


$ 1,1'
3,5;
11,4!


Since lakes and estuaries are particularly affected by urban runoff, the
above estimates could be modified to emphasize control of urban runoff to
such surface waters.
     Table W10.9.
Total  cost for controlling urban stormwater runoff
          (in 1981 dollars)
                                                        Cost
Option 1 - Total Cost of Controlling
  Separate Storm Sewer
  Discharges from All Urban Areas

Option 2 - Total Cost of Controlling
  Separate Storm Sewer Discharges
  to Lakes and Estuaries

State Level Program Management
  Annual Costs

Local Level Program Management
  Annual Costs
                       $ 1,141. million (Aesthetics)
                       $ 3,623. million (Fish & Wildli
                       $11,498. million (Recreation)

                       $   590. million (Aesthetics)
                       $ 1,290. million (Fish & Wildli
                       $ 3,669. million (Recreation)
                       $4-$13.2 million
                       $22.5 million
Urban Runoff Program Management Costs

          To oversee the types of storm-water quality controls discussed
above, states would initially need extensive resources.  EPA's 1980 Needs
Assessment projected a cost of $13.2 million (in 1981 dollars) for FY 19£
The costs of managing such a program would decrease after a state passes
legislation requiring storm-water quality controls or after major urban
areas adopted local ordinances.

                                  W10-14

    -------
Total Costs for UrbanRunoff Control

          Table W10.9 summarizes the total cost for controlling urban
stormwater runoff.  The program management costs are estimated as annual
costs while the cost of controlling urban runoff is based on total urban
control needs.

Controlling Runoff From Urban Construction

          Every year approximately 1.5 million acres of land are disturbed
for constructing houses, factories, and other facilities.  Although this
figure is relatively small, the sediment loadings from construction sites
are higher than those from most land uses.  Erosion rates of 30-200
tons/year/acre—or 10-20 times that of cropland—are reported in the
literature.  Consequently, even small  amounts of construction may
significantly affect local water quality.

          Sediment is the primary pollutant of concern from construction
sites.  In addition, such materials as pesticides, cleaning solvents,
concrete compounds, asphalt, salts, and petroleum products are frequently
washed from building sites and carried to surface waters.

          Technical and institutional  solutions to construction erosion
problems are relatively straight-forward and well-understood.  Many states
have technical manuals explaining how to control erosion from construction
sites.  Technical measures include such vegetative or mechanical practices
as seeding and mulching, straw bale barriers, diversion ditches, and
sediment basins installed on site.  Institutional laws and ordinances are
necessary because such measures are rarely carried out unless required by
law.

          Regulatory programs to control construction runoff have been
increasing gradually in the United States since 1967, when Montgomery
County, Maryland, instituted the first mandatory control program.  About
fifteen states, the District of Columbia, and the Virgin Islands have
developed effective regulatory programs.  These regulatory programs
typically require local jurisdictions (counties, towns, cities, and
villages) to adopt and enforce local construction erosion ordinances that
meet minimum standards.  Several of the state programs predate the Clean
Water Act and are funded largely from state and local revenues and permit
fees.

Cost Estimate for Construction Control Program Management Costs

          The estimated program costs for controlling construction erosion
include the program costs of managing the program and applying the needed
controls at the state and local levels.

          Cost estimates for state and local  program management are based
on the State of Maryland's program for controlling sediment.  We choose
Maryland because its program is good and data on manpower was readily
available.
                                  W10-15

    -------
          In estimating the program management cost we made the following
assumptions:

          t  The number of staff required in Maryland is the basis for
             staff estimates in other states.  However, local inspection
             personnel were increased by 20 percent, as an evaluation of
             Maryland's program indicated that inspection was weak.

          •  Salaries were estimated at $18,000 for plan reviewers, $15,3
             for inspectors, and $9,000 for secretaries, with 35 percent
             overhead.

          •  The populations of States were used to correlate Maryland's
             program with those needed for other states.

          •  Construction erosion control regulatory programs can be part
             self-sustaining; program management at the local level shoul
             be recovered through construction permit fees.

          Given the above assumptions, the number of state and local
program management staff were estimated for each state (see Table W10.10)
A total of $14,499,000 was estimated for state program management staff c
$93,152,700 for local program management staff, totalling $107,651,700 pe
year.  Dividing that total by the approximately 1.5 million acres of lane
used annually for construction yields an annual program cost of $72 per
acre.  Because a large percentage of the local program costs can be
recovered through construction permit fees, there is no need for any type
of cost sharing.  However, state program costs are not similarly
recoverable.

Industry's Costs for Applying Controls

          The cost for controlling erosion has been estimated by DOW
Chemical Company at $2,374 per acre.  Thus, the annual estimated cost to
the construction industry to control erosion from all of the disturbed
construction sites across the nation is $3,561 million per year.  These
costs  are typically included in construction prices and are generally not
cost shared by federal, state or local governments.

          Table W10.ll summarizes, the total annual costs for constructor
erosion control.  The total of $3,669 million includes the annual cost fc
administering construction erosion control programs at both the state anc
local  levels and the cost to the private sector for applying control
measures.
                                  W10-16

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                   Table W10.10.   Annual  state  and local program management costs for
                                  NSPS construction regulatory programs

State
MARYLAND*
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
25.
26.
27.
28.
29.
30.
31.
32.
33.
34.
35.
36.
37.
38.
39.
40.
11.
42.
13.
44.
45.
46.
47.
48.
49.
50.
A1 abama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgi a
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyomi ng
Total
State Program Management
(including state project plan
reviewers, program management,
secretaries)
Person
years ' Costs
3
7
1
5
4
33
5
6
1
1
12
10
2
14
10
6
4
7
3
2
3
10
12
3
5
9
2
3
2
2
9
3
22
11
1
13
6
5
15
2
6
]_
7
IB
3
1
10
8
4
9
1
362
S 320
304
36
205
165
1,205
205
229
36
36
484
417
72
531
417
229
165
304
320
72
320
417
484
320
205
364
72
109
72
72
364
109
393
446
36
550
229
205
503
72
229
36
304
721
109
36
417
320
165
364
36
S14.499
,400
,200
,000
,200
,600
,100
,200
,500
,000
,000
,200
,600
,000
,400
,600
,500
,600
,200
,400
,000
,400
,600
,200
,400
,200
,500
,000
,300
,000
,000
,500
,300
,700
,400
,000
,300
,500
,200
,900
,000
,500
,000
,200
,300
,300
,000
,600
,400
,500
,500
,000
,000
Local 3rogram Management
(including plan reviewers,
inspectors, and secretaries)
Person
years Costs
97
39
9
62
52
365
66
71
14
15
150
125
21
176
126
67
54
34
96
25
97
131
143
93
57
113
18
36
18
21
113
30
271
135
15
166
69
SO
183
22
71
16
105
220
34
12
122
95
44
108
11
4,393
$2
1

1
1
7
1
1


3
2

3
2
1
1
1
2

2
2
3
1
1
2




2

S
z

3
1
r
3

i

2
4


2
2

2

S93
,052,000
,392,700
194,400
,322,100
,112,400
,718,400
,405,300
,512,000
239 ,300
313,200
,176,100
,559,500
452,700
,723,300
,672,100
,417,500
,150,200
,782,000
,045,700
547,200
,052,000
,791,800
,018,600
,984,500
,226,700
,393,100
386,100
711,000
386 , 100
452,700
,401,200
532,700
,724,900
,359,300
313,200
,520,300
,472,400
,280,700
,369,100
460,300
,517,400
335,700
,233,300
,660,200
711,000
248,400
,501,900
,000,700
948,600
,239,600
228,500
,152,700
Program developed from this state.
                                                W10-17

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Table W10.ll.  Total  annual  cost for controlling construction NPS
          pollution costs (in millions of 1981 dollars)
                  Types of Cost
    State Program Management Costs                   $   14.5
    Local Program Management Costs                       93.2
    Costs to Industry for Applying Controls           3,561.3
      Total Annual Cost                              $3,669.0
                             W10-18

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