United States        Office of          EPA 130/6-81-003
             Environmental Protection     Federal Activities       October 1981
             Agency          Washington, DC 20460
&EPA       Environmental
             Impact Guidelines

             For New Source
             Phosphate Fertilizer
             Manufacturing  Facilities

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This document is available to the public through the National Technical
Information Service, Springfield, Virginia  22161.

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                                  EPA-130/6-81-003
                                  October 1981
 ENVIRONMENTAL IMPACT GUIDELINES
          FOR NEW SOURCE
       PHOSPHATE FERTILIZER
     MANUFACTURING FACILCTIKS
        EPA Task Officer:
        Frank Rusincovitch
US Environmental Protection Agency
   Office of Federal Activities
     Washington, D.C.  20460

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                                  Preface

This document is one of a series of industry-specific Environmental Impact
Guidelines being developed by the Office of Federal Activities (OFA) for
use in EPA's Environmental Impact Statement preparation program for new
source NPDES permits.  It is to be used in conjunction with Environmental
Impact Assessment Guidelines for Selected New Source Industries, an OFA
publication that includes a description of impacts common to most industrial
sources.

The requirement for Federal agencies to assess the environmental impacts
of their proposed actions is included in Section 102 of the National
Environmental Policy Act of 1969 (NEPA), as amended.  The stipulation that
EPA's issuance of a new source NPDES permit as an action subject to NEPA
is in Section 511(c)(l) of the Clean Water Act of 1977.  EPA's regulations
for preparation of Environmental Impact Statements are in Part 6 of Title
40 of the Code of Federal Regulations; new source requirements are in
Subpart F of that Part.

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                            TABLE OF CONTENTS                           Page


List of Figures	    iv

List of Tables	.-	   vii

INTRODUCTION	     1

1.0  OVERVIEW OF THE INDUSTRY	     3

     1.1  SUBCATEGORIZATION	     7

     1. 2  MARKETS AND DEMANDS	    10

     1.3  PROCESSES	    16

          1.3.1  Background Information	    16

          1.3.2  Major Processes of Phosphate Fertilizer
                 Manufacture	     21

          1.3.3  Auxiliary Support Systems.,.,,.,.,,,,.,,,,,,,,,,,...     84

     1.4  SIGNIFICANT ENVIRONMENTAL PROBLEMS	     88

          1.4.1  Raw Materials	     88

          1.4.2  Process-Related Problems	     89

          1.4.3  Pollution Control	     92

          1.4.4  Location	     92

     1.5  TRENDS	     93

          1.5.1  Locational Trends	     93

          1.5.2  Trends in Raw Materials	     96

          1.5.3  Process Trends	     98

          1.5.4  Trends in Pollution Control	    100

          1.5.5  Environmental Impact Trends	    102

     1. 6  POLLUTION CONTROL REGULATIONS	    105

          1.6.1  Water Pollution	    105

          1.6.2  Air Pollution	    109

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                                                                           Page

          1.6.3  Land Disposal of Wastes	  116

          1.6.4  Monitoring Requirements	  117

2.0  IMPACT IDENTIFICATION	  118

     2.1  PROCESS WASTES	  118

          2.1.1  Materials Balance and Typical Waste
                 Characteristics	  118

          2.1.2  Environmental Impact of Industry Wastes	  139

          2.1.3  Other Impacts	  148

          2.1.4  Modeling of Impacts	  151

3.0  POLLUTION CONTROL	  153

     3.1  STANDARDS OF PERFORMANCE TECHNOLOGY:  END-OF-PROCESS
          CONTROLS AND EFFECTS ON WASTE STREAMS (AIR EMISSIONS)	  153

          3.1.1  Dust Control in Raw Materials Handling
                 Handling Operations	  153

          3.1.2  Control of S02 from Contact Process Sulfuric
                 Acid Plants	  154

          3.1.3  Control of Acid Mist Emissions from Contact
                 Process Sulfuric Acid Plants	  157

          3.1.4  Control of Fluoride Emissions	  160

     3.2  STANDARDS OF PERFORMANCE TECHNOLOGY:  IN-PROCESS
          CONTROLS AND EFFECTS ON WASTE STREAMS AND EMISSIONS	  167

          3.2.1  Sulfuric Acid Plant Effluent Control	  167

          3.2.2  Wet Process Phosphoric Acid - Pond Water Dilution
                 of Sulfuric Acid	  168

          3.2.3  Ammonium Phosphate Self-Contained Process	  169

     3.3  STANDARDS OF PERFORMANCE TECHNOLOGY:  END-OF-PROCESS
          CONTROLS AND EFFECTS ON WASTE STREAMS (WASTEWATER
          EFFLUENTS)	  170

          3.3.1  Gypsum Pond Water Treatment	  170

          3.3.2  Gypsum Pond Water Seepage Control	  174

          3.3.3  Other End-of-Process Controls	  174
                                      ii

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     3.4  STATE OF THE ART TECHNOLOGY:  END-OF-PROCESS CONTROLS AND
          EFFECTS ON WASTE STREAMS (SOLID WASTE)	  176

          3.4.1  Disposal in Gypsum Ponds and Piles	  177

          3.4.2  Disposal in Abandoned Mine Pits	  177

          3.4.3  Disposal in Sea Outfalls	  177

          3.4.4  Resource Recovery	  178

     3.5  POLLUTION CONTROL RECOMMENDATIONS EXCERPTED FROM THE
          CENTRAL FLORIDA PHOSPHATE INDUSTRY FINAL AREAWIDE
          ENVIRONMENTAL IMPACT STATEMENT	  179

4 .0  OTHER CONTROLLABLE IMPACTS	  181

     4.1  AESTHETICS	  181

     4.2  NOISE	  181

     4.3  ENERGY SUPPLY	  183

          4.3.1  Cogeneration	  184

          4.3.2  Energy Consumption and Conservation	  184

     4.4  SOCIOECONOMICS	  186

5.0  EVALUATION OF AVAILABLE ALTERNATIVES	  190

     5.1  SITE ALTERNATIVES	  190

     5.2  ALTERNATIVE PROCESSES , DESIGNS , AND OPERATIONS	  192

     5.3  NO-BUILD ALTERNATIVE	  192

6.0  REGULATIONS OTHER THAN POLLUTION CONTROL	  193

7.0  REFERENCES	  195
                                    iii

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                            LIST OF FIGURES


Figure                                                              Page

  1.   U. S.  phosphate fertilizer exports	   14

  2.   Phosphate rock supply-demand projections	   14

  3.   Location of major phosphate rock deposits in the
       United States 	   18

  4.   Schematic diagram of  phosphate fertilizer industry	   22

  5.   Contact-process sulfuric acid plant burning elemental
       sulfur - single absorption	   27

  6.   Dual absorption sulfuric acid plant flow diagram	   31

  7.   Rock grinding (flow rate per ton rock)	   35

  8.   Normal superphosphate flowsheet 	   37

  9.   Precipitation and stability of calcium  sulfates in
       phosphoric acid	   42

 10.   Wet process phosphoric acid flowsheet 	   43

 11.   Flow diagram for Prayon phosphoric acid plant	   45

 12.   Dorr-Oliver reaction  system (vacuum-cooled) 	   45

 13.   Flow diagram for Singmaster and Breyer  dihydrate
       phosphoric acid process 	   47

 14.   Flow diagram of Singmaster and Breyer hemihydrate-dihydrate
       process	,  .  .  .  .   47

 15.   Tilting pan filtration system 	   48

 16.   Operating cycle of rotary horizontal tilting pan
       filter	   48

 17.   Concentration and clarification of phosphoric acid	   51

 18.   Stauffer process for  wet process superphosphoric
       acid	   55

 19.   Vacuum evaporation SPA concentration processes	   55
                                    iv

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                       LIST OF FIGURES (Cont . )
20.    Triple superphosphate (run of pile) (flow rate per
      ton ROP) ...
                                                                   Page
21.   Granulated triple superphosphate (flow rate per
      ton GTSP) ..... ....................   61

22.   Monoammonium phosphate plant (flow rate per ton MAP). ...   54

23.   Flowsheet for production of diammonium phosphate
      (DAP) ...... .....................   65

24.   Details of pipe reactor in drum granulator .........   69

25.   Flow diagram of granulation pilot plant using pipe
      reactor process for NPK fertilizers ............   70

26.   Pipe-reactor/pugmill process. ....  ...........   73

27.   Pipe reactor and vapor disengager .............   74

28.   Pipe-reactor/drum-granulator process without a
      preneutralizer ....... . ...............   76

29.   Pipe-cross reactor/drum-granulator process .........   78

30.   Typical ammoniation-granulation plant  using the
      pipe-cross reactor. ........  ............   79

31.   Plant pipe reactor system for production of high-
      polyphosphate liquid fertilizer ..............   83

32.   Locations of phosphate fertilizers and ammonia
      production.  ... ..... . ...............   94

33.   Sulfuric acid plant - double catalysis (flow rates
      per ton 100% I^SO^) ....................  119

34.   Contact process sulfuric acid plants,
      SO  emissions .......................  124

35.   Contact process sulfuric acid plants,
      acid mist emissions ....................  125

36.   Wet process  for production of phosphoric acid .......  127

37.   Production of superphosphoric acid .............  127

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                        LIST OF FIGURES (Cont.)






Figure                                                              Page




 38.   Major gypsum pond equilibrium	-j^g




 39.   Pond water treatment system	173




 40.   Recommended minimum cross section of dam 	  176




 41.   Gypsum pond water seepage control	176
                                   vi

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                            LIST OF TABLES
Table                                                                 £S8£
  1.  Phosphate rock sold or used by producers in the United States
      for all uses	12

  2.  Phosphate trade - U.S. and world	13

  3.  Marketable production of phosphate rock in the United States,
      by region	15

  4.  Description of phosphate fertilizer complexes in the United
      States by unit operations	24

  5.  Sulfuric acid manufacture from elemental sulfur	29

  6.  Phosphate rock crushing, grinding,  and screening 	  34

  7.  Normal superphosphate production 	  39

  8.  Wet process phosphoric acid production 	  49

  9.  Concentration and clarification of  wet process
      phosphoric acid	  53

  10.  Superphosphoric acid production	57

  11.  Granular triple superphosphate production	52

  12.  Ammonium phosphate production	67

  13.  Supply pattern for sulfur in the United States 	  97

  14.  Water effluent disposal and containment practices for
      the phosphate fertilizer industry	103

  15.  Standards of performance for new sources for wastewater
      effluents	107

  16.  New source performance standards for emissions of air
      pollutants from sulfuric acid plants and phosphate
      fertilizer  manufacturing facilities	HO

  17.  Federal ambient air quality standards	HI

  18.  Nondeterioration increments for S02 and particulate
      matter in areas with different air  quality
      classifications	113

  19.  Sulfuric acid production materials  balance 	 120

  20.  New source  performance standards compliance test
      results for sulfuric acid plants 	 122

  21.  Phosphate rock processing materials balance	123
                                  vii

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                        LIST OF TABLES (Cont.)


Table                                                                Page

  22.  Phosphoric acid  materials balance 	  128

  23.  Normal superphosphate materials balance  ....  	  ^3^

  24.  Granular triple  superphosphate materials balance.  ......  132

  25.  Ammonium phosphate materials  balance	  133

  26.  Typical equilibrium composition of  gypsum pond water	135

  27.  Analysis of solids from wet process phosphoric acid	137

  28.  Scrubber performance in wet process phosphoric
       acid plants	161

  29.  Spray-crossflow  packed bed scrubber performance  in
       diammonium phosphate and granular triple superphosphate
       plants	163

  30.  Venturi scrubber performance  in superphosphoric  acid
       and  diammonium phosphate plants	165

  31.  Cyclonic spray tower performance in wet  process
       phosphoric acid,  diammonium phosphate, and run of
       pile triple superphosphate plants .....  	  166

  32.  Energy for fertilizer nutrient production 	  186
                                   viii

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INTRODUCTION
     The Clean Water Act requires that the United States Environmental Pro-
tection Agency (USEPA) establish standards of performance for categories of
new source  industrial  wastewater dischargers.  Before the discharge of any
pollutant to the navigable waters of the United States from a new source in
an industrial  category for which performance standards have been proposed,
a new source National  Pollutaiit Discharge Elimination System (NPDES) permit
must be  obtained  from either USEPA or the State (whichever is the adminis-
tering  authority  for  the  State in which the  discharge  is  proposed).   The
Clean Water  Act  also requires  that the issuance of a permit by USEPA for a
new source  discharge  be  subject to the National  Environmental  Policy Act
(NEPA),  which  may  require preparation of an Environmental Impact Statement
(EIS) on the new  source.   The  procedure established  by USEPA regulations
(40 CFR  6  Subpart  F)  for applying NEPA to the issuance of new source NPDES
permits  may  first  require  preparation  of  an Environmental  Information
Document (EID) by  the  permit applicant.  Each EID is submitted to USEPA and
reviewed to  determine  whether  there are potentially significant effects on
the quality of the human environment resulting from construction and opera-
tion of the new source.  If there are, USEPA publishes an EIS on the action
of issuing the permit.
     The purpose  of  these Guidelines is to provide industry-specific guid-
ance to  USEPA  personnel  responsible for determining  the  scope and content
of EID's and  for  reviewing them after submission to USEPA.  It is to serve
as  supplementary   information  to   the  previously  published  Environmental
Impact  Assessment Guidelines  for  Selected  New  Source  Industries  (USEPA
1975), which includes the general format for an EIA and those impact assess-
ment considerations  common  to all or most industries.   Both  that document
and these Guidelines  should  be used in the development of an EID for a new
source phosphate fertilizer manufacturing facility.

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     These Guidelines provide  the  reader  with an indication  of  the nature
of the potential impacts on the environment and the  surrounding region from
construction and operation of phosphate fertilizer plants. In this capacity,
the volume is  intended  to assist USEPA personnel in  the identification of
those impact areas  that should be  addressed in an EID.  In addition, these
Guidelines present  (in  Section 1.0)  a description of  the industry; demand
for  industry  output,  its  principal  processes and  environmental problems;
and recent trends in location, raw materials,  processes,  pollution control,
and environmental impacts.   This  "Overview of the Industry" is included to
familiarize USEPA staff with existing conditions  in  the industry.

     Although  this  document  may  be transmitted to an applicant for inform-
ational purposes, it should not be construed as representing the procedural
requirements for obtaining an NPDES permit or as  representing the applicant's
total responsibilities relating to the new source EIS program.  In addition,
the content of  an EID for a  specific  new source application is determined
by USEPA in accordance with Section 6.604(b)  Title 40 of  the Code of Federal
Regulations and  this  document does not supersede any directive received by
the  applicant   from  USEPA's  official  responsible   for   implementing  that
regulation.

     These Guidelines  are divided  into  six sections.   Section  1.0 is the
"Overview of the  Industry,"  described above.   Section 2.0, "Impact Identi-
fication," discusses  process-related  wastes  and  the impacts that may occur
during construction and operation of the facility.  Section 3.0, "Pollution
Control," summarizes  the  technology  for controlling environmental impacts.
Section 4.0  discusses other  impacts  that can be mitigated  through design
considerations  and proper site and facility planning.  Section 5.0, "Evalua-
tion  of  Alternatives,"  summarizes possible  alternatives to  the proposed
action and discusses evaluation of  their consideration and impact assessment.
Section 6.0 describes  regulations  other than  pollution  control  that apply
to the industry.  Section 7.0 is a list  of  references,  arranged by topic,
which are  useful for additional or more detailed  information.

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                        1.0  OVERVIEW OF THE INDUSTRY

     These  Guidelines  deal with phosphate  fertilizer  manufacturing in the
United States  as  it is today and  as  it is presently evolving.  "Phosphate
Fertilizer  Manufacturing" refers  to  that  industry which  takes  phosphate
rock,  a  relatively insoluble  raw material, and processes  it  to  produce a
number of  water-soluble  phosphorus-containing  chemicals  which are further
utilized  in the manufacture  of  fertilizers.   The  products of  these  pro-
cesses are  fertilizer  materials,  some of which  could  be  applied  directly.
In practice this  is rarely done because most  areas which can benefit from
fertilizers suffer from soil deficiencies besides that of available phosphorus.
For most  purposes,  then,  the phosphate fertilizer industry produces inter-
mediate  products  which  are used  in  other  segments  of  the fertilizer  or
inorganic chemical industries.

     Some phosphate  fertilizer plants produce  a single  product primarily,
while others are  integrated  complexes which produce a full  range of phos-
phate  fertilizer  products,  and  may  produce  a number  of   other  chemical
products at the same facility.  It is common for one company to be involved
in industry segments  ancillary  to phosphate  fertilizer  manufacture.   For
example, many  companies are  located at or near the mine  site for phosphate
rock and may be involved  both in the ore extraction and  processing as well
as in the manufacturing processes to produce phosphate fertilizers or other
phosphate chemicals.

     The  inter-relationships  and distinctions  among  industry  segments can
be summarized as follows:

     1)   Phosphate mining  industry  - this  is  a  segment  of the  mining
         industry   which  extracts  phosphate  ores  and  processes  them  to
         produce  marketable  quality  "phosphate  rock".    Most  ores  are
         sedimentary deposits  of the  mineral  fluorapatite  and associated
         impurities,  along with  clays,  sands,  or other rock matrix.  These
         constituents  usually  must be  separated to concentrate  the phos-
         phate  bearing deposits  which  are  referred to as "phosphate rock,"
         "phosrock",  "phosphate rock concentrate", and "beneficiated phosphate
         rock."  The phosphate mining industry  is  described more fully in
         Section 1.3.1.
                                     3

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2)  Phosphate fertilizer  industry  -  as  described  before,  this  industry
    uses phosphate rock from the  phosphate  mining processes and  manu-
    factures phosphate fertilizer  chemicals.

3)  Non-phosphate  fertilizer  industries -  in reference  to the
    phosphate  fertilizer  industry,   these   industries   include  the
    "nitrogen" or  "nitrogenous"  fertilizer  industry  and the  "potas-
    sium" or "potash"  fertilizer industry.   A minor, often overlooked,
    industry  engaged  in  fertilizer production, is the  "natural"  or
    "organic" fertilizer  industry.   The products of the  nitrogen  and
    potash  fertilizer  industries  are  also  usually considered  inter-
    mediate  products,  which  are  combined   with  other  materials  or
    processed further  for  specific applications.

4)  Mixed  (and  blended)  fertilizer  industry -  this  is  the  industry
    which  actually  produces most  of  the  fertilizer  materials  com-
    mercially marketed.   Phosphate,  nitrogen, and potassium fertilizer
    chemicals, along  with various  fillers,  coating agents,   insecti-
    cides, and other  useful  additives  are  combined by  this  industry
    to produce popular blends or formulations tailored  to the  needs of
    certain geographic areas.   In  the parlance of the  industry,  "mixed
    fertilizer" refers to  a  fertilizer  containing more  than one  of  the
    primary plant  nutrients  (phosphorus, nitrogen,  potash).  There  are
    three types of mixing  plants:
     •  Bulk blending  plants  physically mix  dry  fertilizer materials,
        without  chemical  reaction,  to  produce  a  dry,  granular mixed
        fertilizer.
     •  Ammoniation-granulation plants chemically  react  liquid and/or  dry
        raw materials  in  a  granulator  to  produce a dry  fertilizer with
        the constituent nutrients blended in each  granule.
     •  Liquid mixing  plants  are either "hot"  or "cold".   Hot mix plants
        are termed "hot"  because of  the exothermic reaction between phos-

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             phoric acid and ammonia; they produce a  liquid mixed fertil-
             izer.  Cold mix plants physically mix liquid materials to de-
             rive a liquid mixed  fertilizer without a chemical reaction
             (USEPA 1976f).
         Rapid  developments  are underway in the mixed fertilizer industry.
         New liquid  fertilizers are being developed and promoted with con-
         current  development  of improved spreading equipment.  Slurry-type
         mixtures are being marketed as fluid fertilizers, to be applied us-
         ing conventional liquid  spreading machinery.

     5)  Phosphorus and non-fertilizer phosphate industries - USEPA effluent
         guidelines  and  standards have  established  the  "non-fertilizer"
         terminology  to encompass  the  manufacture of  certain phosphorus-
         derived  chemicals  that  are  widely used  for purposes  other than
         soil fertilization.  This broad industry category includes the pro-
         duction  of  phosphorus  and  ferrophosphorus by  smelting phosphate
         ore;  production of  phosphoric  acid,  phosphorus  pentoxide,  phos-
         phorus  trichloride,  and  phosphorus  oxychloride directly from ele-
         mental  phosphorus;  production  of  sodium  tripolyphosphate  and
         animal  feed  grade  and  human  food  grade calcium  phosphate from
         phosphoric  acid;  defluorination  of phosphate  rock by  high tem-
         perature  and   other   treatments;   defluorination  of  phosphoric
         acid;   and  purification  of  sodium  phosphates  from wet  process
         phosphoric  acid  (the   "wet  process"  is  described  in  detail  in
         Section  1.3.2.4).    The  above  processes produce  products  used
         in  such  applications  as  human  food  additives  and animal  feed
         supplements,   plastics   manufacture,   metal   treating,   detergent
         builders, and incendiary chemicals.

     For  the  most  part,  the  industry  segments  other  than  the phosphate
fertilizer industry will not be discussed further in these Guidelines. They
will, however,  be referred  to,  due to  the  interrelationships of industry
segments.

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     Mixed fertilizers are usually described based on their NPK formulation -
that is, on the ratio by weight of the percentage of nitrogen, phosphorous,
and  potassium  contained  in the formulation.   For  example,  the formulation
for  a  typical  mixed  liquid fertilizer (ammonium polyphosphate) is 11-37-0,
meaning that 11% of the weight is nitrogen, 37% is phosphorus  (expressed as
P»0  equivalent), and none is potassium.   These ratios are also referred to
as  "nominal  grades"  based  on their  identification  of  the  percentages of
each  primary  nutrient  irrespective  of  the  type  of chemical  compound in
which each may occur.

     The  NPK  formulation  is  not  a descriptor normally  used  for  the basic
phosphate  fertilizer  chemicals with  the exception  of  ammonium phosphates.
Because  of  their economic  importance as an  intermediate  to  numerous bulk
blended  and  liquid  fertilizers  and  because  the production  processes  for
ammonium phosphates are commonly performed in phosphate fertilizer complexes,
effluents  from  these  processes  are  frequently combined  with  the  waste
streams  from  other  phosphate fertilizer  processes  and  treated  together.
For  these reasons, ammonium phosphates are covered under phosphate fertilizer
industry  effluent  and  emissions   guidelines  rather  than  those  for  mixed
fertilizer  industries,  and  are  included  in  this  Guidelines  document.

     For phosphate rock and its products  the phosphorus content is commonly
expressed in one of four ways:

     •  BPL (bone phosphate of lime or tricalcium phosphate - Ca~(PO,)9)
     •  Phosphorus pentoxide  (Vj0^
     •  Elemental phosphorus  (P.)
     •  Phosphoric acid (H-PO,)
     The  common  industry practice  is  to report  all phosphorus-containing
materials in terms of the equivalent content of phosphorus pentoxide (P-0,.).
That practice  is used  throughout  this document,  unless  otherwise stated.
     The table below  illustrates  the relationships among the  four  sets of
units:

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             Conversion factors for phosphorus content units.
To  convert  from                     To                         Multiply by
       H3P04                             %  P                          0.316
       H3P04                             %  P205                       0.724
      BPL                              %  P                          0.1997
      BPL                              %  P205                       0.4576
       P20_                              %  H3P04                      1.381
      P205                             %  BPL                        2.1853
Source:  U.S.  Environmental  Protection Agency.   1979a.  Source assessment:
   Phosphate fertilizer industry.  Office of Research and Development, Washing-
   ton, B.C.  Prepared by Nyers, J.M., G.D. Rawlings, E.A. Mullen, C.M. Mos-
   cowitz, and R.B. Reznik, Monsanto Corp., Dayton OH, 201 p.

For  example,  orthophosphoric  acid  (phosphoric  acid  concentrated  to  its
highest common  H»PO,  content)  would  be expressed as  75%  H_PO,,  54%  P^O,.,
and 24% P.
1.1  SUBCATEGORIZATION

     Effluent  Guidelines  and Standards  (commonly called  "effluent  guide-
lines") are established by USEPA for specified pollutants which are regulated
at specified  allowable  levels for various  industry  segments  (Point  Source
Categories).   In the  Code  of Federal Regulations USEPA sets forth effluent
guidelines  under  Part  418  for the  Fertilizer Manufacturing  Point  Source
Category (40 CFR 418).  This Guidelines document applies only to Subpart A,
Phosphate Subcategory, of  40 CFR 418.

     The provisions  of the Phosphate Subcategory apply to discharges resulting
from the manufacture of :

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        sulfuric acid by sulfur burning;
        wet process phosphoric acid;
        normal superphosphate;
        triple superphosphate; and
        ammonium phosphates.


     The five  regulated  processes represent those processes which,  due to

either  the  character  or the  quantity of  their  wastes, produce  effluent

streams capable of  significant  environmental  degradation,  as identified in

the  Development Document  for  the  Fertilizer Manufacturing Point  Source

Category (USEPA 1974a).  There  are  four  additional processes (described in
Section 1.3)  for which  either no waste stream is  normally  produced or the

waste stream is regulated under one  of  the other  processes  with which it is
closely associated.  The nine  basic  processes can be described as  follows:


     •  Sulfuric Acid by Sulfur Burning  is the  dominant  process  in  the
        United States.   Virtually all plants use  sulfuric acid  to treat the
        raw  phosphate  rock   (acidulation)  and  produce  phosphoric  acid.
        Sulfuric acid is usually produced on the  premises by burning molten
        sulfur  in  the  presence  of  air to  produce SO. gas.   In the usual
        process, known as the "contact  process,"  the SO2 is  further oxidized
        to form SCL  using  a  catalyst contact  surface.   The  sulfur  trioxide
        (S0») gas is then  hydrolized in  a number  of steps  by  the  addition
        of water to form sulfuric acid  (H_SO,) of  the required  concentrations,

     •  Phosphate Rock Processing -  Crushing,  Grinding, and  Screening
        reduces the phosphate rock feedstocks  to  sizes  optimal  for  reaction
        in further  processes.   This operation may be performed at  a pro-
        cessing plant  associated with  the  mine,   at a central  point in a
        fertilizer  plant, or  as  a beginning operation  feeding  into another
        process.

     «  Normal Superphosphate Production  is a process which was initially
        developed more than a century ago.   Ground phosphate rock is reacted
        with  sulfuric   acid  to  produce  a  water-soluble but,  by  today's
        standards,  low analysis phosphate.

     »  Wet Process Phosphoric Acid  Production is   the foundation  of  the
        phosphate fertilizer  industry.    Ground phosphate rock  and  sulfuric
        acid are reacted to form phosphoric acid  and to precipitate calcium,
        sulfur, and other unwanted materials in insoluble forms that can be
        separated from  the acid.  The  product, when completely processed,
        is  an  intermediate  used  to  produce high analysis  fertilizers.

     •  Phosphoric  Acid Concentration  is  a continuation of  the processing
        of wet  process  phosphoric acid whereby water is removed to improve
        concentration  and  reactability  of  the.  acid  and  also  to  improve
        shipping and storing  efficiencies when sold as  a product.

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     •  Phosphoric Acid Clarification  completes   the   processing   of  wet
        process phosphoric acid.  Solids are caused to floculate or precipi-
        tate  and  are  separated  to  avoid  later problems  in  storage  and
        handling.    If  not  removed early  in the  production of the  acid,
        solids will precipitate out as the acid ages in forms and locations
        that can incapacitate handling and process equipment.

     •  Superphosphoric Acid Production  is  a process  to  remove additional
        water and further  concentrate  the P?0, equivalent content  of phos-
        phoric  acid.   The product  is  used  in  production of  certain high
        analysis fertilizers.

     •  Triple Superphosphate Production   reacts   phosphoric  acid   with
        phosphate rock  to produce  a  high analysis -solid fertilizer  which
        can be  applied  directly or can be used  as a feedstock in  the pre-
        paration of high analysis mixed fertilizers.

     •  Ammonium Phosphate Production  yields  highly   concentrated  sources
        of  water  soluble  plant food which combine  nitrogen  and phosphorus
        in a single granule.  The product is less bulky than dry mixes of N
        and P straight fertilizers, and easy to apply and handle due to the
        granular form  in  which it is usually produced.   The granular form
        mitigates caking and dust problems.  In addition,  ammonium  phosphates
        are more  profitable to  produce than some  other products  such  as
        triple superphosphates.


As a  chemical  category,  ammonium phosphates include monoammonium phosphate
(MAP),  diammonium  phosphate (DAP), and a vast  range  of  other ammoniated
phosphates containing different ratios of ortho- and polyphosphate  molecular
components called collectively  ammonium polyphosphates (APP).  MAP and DAP
are  the "ammonium phosphates"  included in  the  regulated  processes  of  the
Phosphate  Subcategory  (40 CFR  418).  APP's are  regulated  under Subpart  G,
Mixed and Blend Fertilizer Production Subcategory.   The essential distinction

is that MAP and DAP are included in the Basic Fertilizers Phosphate Subcategory
because they are  produced  at the same  plants  as the  other basic phosphate

fertilizer materials,  even though  they are technically  mixed, containing

both N and P nutrients.  APP's on the other hand are produced in the numerous

mixing  plants  in  areas of  application throughout  the  country. APP's  are
produced by reacting superphosphoric acid and ammonia or, in recent process

improvements,  phosphoric  acid  and ammonia,  which are  basic  or  straight

fertilizer materials shipped  into the mixing plants  from basic fertilizer

manufacturers.

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 1.2  MARKETS AND DEMANDS

     The markets and economics of fertilizer use indicate a worldwide trend
 toward increasing overall demand on which are superimposed sometimes widely
 fluctuating  market  conditions from  year to  year.   Demand is  expected  to
 continue increasing, but  a  host of variables confound  the best efforts  of
 industry experts accurately to predict short-term specific product demands.
 Despite these uncertainties, and allowing for reluctance by industry spokes-
 men to announce expansion plans before commitments are firm and site proper-
 ties  secured,  the phosphate  fertilizer  industry appears  to  be increasing
 long-range production capacities.

     United States demand for phosphates has grown steadily since World War
 II  with  rapid growth  since 1965.  Growth  has  been based on the farmer's
 need to maximize yield, but  the market has been stimulated by the development
 of new  fertilizer  products  which make application easier  and less costly.
 Mixed fertilizers account for 85.18% of current  phosphate fertilizer consumption
 (TVA  1979). These products  incorporate a balance of NPK nutrients in a dry
 blend  or  liquid mix,  and also can include  sulfate, micronutrients,  lime,
 soil  conditioners,  and  pesticides.   Thus,  with  timed release  coatings,
 fertilization and pest control that used to require several operations, can
 be done at one time.  In addition, local plants  market  soil analysis services
 as  part  of  their product.   Fertilizers  are  blended  in these  plants  to
 supply the needs  of  the  particular soil, and the  company delivers and may
 even apply the fertilizer mix.

     Production  and  consumption  patterns  of phosphate rock  products  are
 decidely toward  a  continuing  concentration in wet  process phosphoric acid
 production,  which  reflects the  market  for  concentrated P~0   content  and
mixed and  blend  final fertilizer  products.  Rock  consumption  in  normal
superphosphate (NSP) declined sharply in  1978.   NSP  is a product  of  low
H?2®5 content and diminishing importance,  which is now manufactured primarily
in small,  low  technology  plants  in close proximity to  the sales area.  NSP
is used primarily as  a  direct  application fertilizer or as a  constituent  in
some  dry  blended  fertilizers.    Production  of   triple   superphosphate  has
remained  at a  level  of  5% to  6%  of  total  phosphate fertilizer production,
                                    10

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for  use  in dry blended fertilizers  primarily.   The most recent production
figures  for  phosphate  rock and P^O- content are broken down by product use
in Table  1.

     Largely through the efforts of  the United Nations Food and Agriculture
Organization  (FAO),  the United States Agency for International Development
(AID), the Tennessee Valley Authority  (TVA), and other United States institu-
tions and businesses,  overseas interest in fertilizer use has grown into a
substantial market.  The effectiveness of fertilizers has been a foundation
for  many  achievements  of  the  "green revolution" in agriculture.  That plus
the  huge  United States market  and limited long-term United States supplies,
have brought new foreign competitors  into  the  phosphate fertilizer field.
Among them, Morocco stands alone as  the potential "Saudi Arabia" of phosphate
rock. With  proven reserves of at least  10  billion tons of phosphate rock,
Morocco holds  62.2% of  the 16.065 billion-ton world reserve, which is based
on economically recoverable rock at  1974 prices.  The United States holds a
reserve of roughly 2.5 billion tons.   Furthermore,  the Moroccan reserve may
be  as  large as 40  billion tons  (Stowasser 1975).  From  1964  to  1973, the
United States  exported approximately 23% of domestic production (Stowasser
1977) and accounted for  roughly  38%  of  world  production  (USEPA   1978b).
The  USSR  and Morocco accounted for approximately 20% and 17%, respectively,
of world  production, and both  countries are currently increasing production
capacity.   More  recently,  figures  for United  States  phosphate  exports,
excluding phosphate rock, show increases in United  States exports (Harre in
TVA  1978a) (Table 2 and Figure 1).

     Despite  recent  improvements  in the United  States  export  market,  pro-
ducers are accustomed to unprofitable periods of one or more years as large
fluctuations  have  traditionally  occurred  in  both  exports  and  domestic
consumption.  The markets are  extremely sensitive to price, as was indicated
in 1975 when  inventory buildup of phosphate  rock  abruptly exceeded demand
after five years  of  short supply  (TVA  1977a).   This  sudden lack of sales
was  due  to higher  prices  set by  the industry  to offset  costs  of recent
capital   expansion.   In that   instance, Morocco  cut prices  drastically to
stimulate sales,  and United  States  suppliers were forced  to  follow suit.
The  most  recent  summary of production and  dollar  values of U.S. phosphate
rock is  given in Table 3.
                                     11

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             Table 1.   Phosphate rock sold or used by producers
                  in the  United States  for all  uses  (1000  metric tons).
                                      1977
1978
Use
Domestic:
Wet process phosphoric acid
Normal superphosphate
Triple superphosphate
Def luorinated rock
Direct applications
Elemental phosphorus
Ferrophosphorus
Total (1)
Exports
Grand Total (1)
Rock
27,024
913
1,852
298
36
3,904
180
34,207
13,230
47,437
P2°5
Content
8,377
283
587
99
7
1,011
46
10,410
4,251
14,660
Rock
29,322
- 298
1,781
193
39
4,371
200
36,204
12,570
48,774
P2°5
Content
9,000
93
571
65
7
1,135
52
10,923
4,025
14,948
(1) Data  may not  add  to  totals  shown because  of independent  rounding.

Source:   U.S. Department of  the  Interior,  Bureau  of Mines.   1979.   Mineral
         industry  surveys,  phosphate rock  -  1978.  Washington, D.C.   6  p.
                                    12

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                 Table 2.   Phosphate trade - U.S. and world.
                                 World
U.S.
Year
1962
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976
1977
Total
consump-
tion
10,578
11,311
12,675
13,955
14,949
16,111
16,957
18,175
18,818
19,844
21,096
22,440
24,114
22,653
24,129
26,479
Total.
trade
1,275
1,328
1,560
1,683
1,802
2,049
2,650
2,554
2,634
2,630
3,343
3,891
4,117
4,151
3,799
4,337
Trade as
% of
consumption
12
12
12
12
12
13
16
14
14
13
16
17
17
18
16
16
Total.
trade
257
248
363
392
400
713
1,039
902
767
815
999
1,264
1,347
1,498
1,974
2,268
Trade as
% of
world trade
20
19
23
23
22
35
39
35
29
31
30
32
33
36
52
52
1.  1,000 metric tons of P^

Source:  Harre, E.A.  and H.A. Handley.   1978.   World fertilizer trade and
         the U.S.  market outlook.   _In_ Situation 78, TVA Fertilizer Con-
         ference.   National Fertilizer Development Center, Bulletin Y-131,
         Muscle Shoals,  Alabama,  p. 17-24.
                                    13

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                       MILLION SHORT TONS OF P,0, •
                                                  /
                                             /
                Figure 1.  U.S. phosphate fertilizer exports.

Source:   Harre, E.A.  and Hazel A.  Handley.  1978.   World  fertilizer  trade and
    the U.S. market  outlook, Situation 78, TVA  Fertilizer  Conference, August 15-
    16, 1978, St. Louis,  Missouri.   Bulletin Y-131.   National  Fertilizer Develop-
    ment  Center, Muscle Shoals AL,  83 p.
       80
     i 60
     £

     I
     

                                           20


                                           10
                1930
                        1985
                                1990
1995      2000
    YEAR
                                                         2005
                         2010
                                                                          2015
                                                                                  2020
            Figure 2.   Phosphate rock supply - demand projections.

Source:   Adapted from  Stowasser, W.F.   1977a.   Phosphate rock,  the present  and
   future supply and demand.  Letter from U.S.  Bureau of Mines  to R.E. McNeill,
   USEPA,  Region IV, February 18 in  USEPA 1978b.
                                        14

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            Table 3.   Marketable production of phosphate
                 rock in the United States, by region.
                  (1000 metric tons and 1000 dollars)

1977:


Fla. & N. Carolina
Tennessee
Western States

(1)
Rock

40,575
1,747
4,934
P2°5
Content

12,679
442
1,440
$Value

718,393
14,253
89,011
     Total                  47,256      14,561      821,657

1978:
Fla. & N.
Tennessee

Carolina

Western States (1)

43,258
1,709
5,070

13,421
442
1,469

817,165
14,047
97,608
     Total                  50,037      15,332      928,820
(1) Includes Alabama, California, Missouri, Montana,  Utah,
and Wyoming.

Source:  U.S. Department of the Interior, Bureau of Mines.
         1979.  Mineral industry surveys, phosphate rock -
         1978.  Washington, D.C.  6 p.
                               15

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     Projections of United  States  production and consumption (Figure 2) of
phosphate rock  indicate that  Tennessee  production* will  terminate around
1990. North Carolina production is expected to grow slowly through 1985 and
then increase rapidly  to  a maximum mining rate of 20 million tons by 2000.
This  will occur  as the  Florida  production rate  is  expected to  reach a
plateau  of  48 million  tons between  1985  and 1990 and  then  to decline as
higher  grade  ores  play out  and  production turns  to  lower  grades.   The
western  states'  production  is expected  to  increase  slowly  and continue
steadily  at  approximately  8 million tons  per year  (USDI  1977).   It seems
likely  that the  United States  will become a net importer of phosphate rock
early in  the 21st century.

1.3  PROCESSES

1.3.1   Background Information

     1.3.1.1  The Development of Modern Fertilizers - Historical Perspective

     The  use of fertilizers has from early on been closely interrelated for
the  three primary  plant nutrients -  nitrogen, phosphorus,  and potash.   In
1840, Justus Liebig published results of his investigations into the elements
plants  need as  nutrients,  and  laid  the  foundations  of fertilizer science.
Liebig  identified ammonia  (as  ammonical liquor from coal gas,  treated with
gypsum),  potash (from wood ash), and phosphorus and lime (from  the treatment
of  ground bones  with sulfuric  acid), as well  as  other elements beneficial
to  plants.    Liebig  also  described   the ability  of superphosphate  to  fix
ammonia  (superphosphate is  the  product  of  treating  phosphate  rock with
sulfuric  acid).  By 1853, 14 firms in England, one in Austria,  and three in
the United States were  producing "superphosphate of lime" by acidulation of
bone meal (Russel et al. 1977).  The  search for other  sources of phosphorus,
as  bones  became  an  undependable supplier, led eventually to phosphate rock
deposits,  but  superphosphate  remained  the dominant P fertilizer for more
than 100  years.
 *
 Tennessee  production  is  used  for  "furnace  grade"  phosphoric  acid and
 elemental  phosphorus  and  does  not  figure  in as  fertilizer production.
                                    16

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     The United  States  Government  established ammonia plant facilities and
laboratories at Muscle Shoals, Alabama, in 1918 to produce synthetic ammonia
needed  in  the World War.   In 1933,  the TVA was  established  as a regional
resource development agency.  TVA's mandate included the national responsi-
bility  for  improving   fertilizer  manufacture  and  use  through  research,
development,  and education  programs.   During World  War II,  the ammonium
nitrate was made available for fertilizer use, and TVA intensified develop-
ment of other fertilizer materials, including improved phosphate fertilizers.
Because of its role in education, through its National Fertilizer Development
Center, TVA has been a catalyst in developing both new fertilizer materials
and processes,  and  the  markets and demands to utlize them.   The Fertilizer
Institute  (TFI), based  in Washington,  D.C. has been  active  as a forum for
discussion and  dissemination of  industry views and technical developments,
and has  recently become involved in symposia  on  environmental regulations
and pollution control technology.

     1.3.1.2  Phosphate Rock Mining and Processing

     The phosphate mining industry is not included in the subject matter of
this  document.   Since  most  phosphate  rock  mined,  however,  is  used  for
production of fertilizer materials, most mining operations include phosphate
fertilizer processing  in their  corporate  activities.   For  example,  of 34
major  phosphate  industry  operations  in the large Central Florida District,
18 perform processing of phosphate fertilizer or animal feed grade products
(USEPA  1978b).   Examined  by company organization, the vertical integration
is  even more  apparent.   Many of  the  mining/beneficiation  operations  are
owned by one parent company which may hold as many as three mining operations
dedicated largely to supplying feedstocks for one or more processing plants
of  the same  parent  company.   Mining and processing  are briefly  described
below to assist the reader in distinguishing between the mining and manufac-
turing functions in an integrated facility-

     After  any   prospecting  and  mining  claims  are  complete, the  mining
operation concentrates on matrix or ore extraction and beneficiation of the
ore.  Figure 3 is a map  showing the locations of the major phosphate deposits
in the  United  States.   Ore is actually mined in only four areas - Florida,
North Carolina,  Tennessee, and several  western contiguous states.
                                    17

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                           NUMEROUS SCATTERED FIELDS
                             OF PHOSPHATE ORES
                  Figure 3.   Location of major phosphate rock  deposits
                       in the United States.

Source:  Stowasser, W.F.  1977.  Phosphate  -  1977.   Publication No. MCP-2,
   U.S. Department of Interior, Bureau  of Mines,  Washington, B.C., 18 p. in
   USEPA 1979a.
                                      18

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     Extraction of  the matrix or ore is done by different processes depend-
 ing on the  location and characteristics of the deposits.  In Florida, which
 accounts  for  roughly  78% of  the United States production of phosphate rock,
 deposits  are  alluvial.   The phosphate-rich beds are a  loosely consolidated
 conglomerate  of  phosphate  pebbles  and clays,  known as matrix.   The thin
 overburden  deposits are unconsolidated sediments.   Mining  is  conducted by
 stripping  overburden  from  the  matrix  desposits  by  use  of  electrically
 driven  "walking  draglines"  equipped  with buckets  of  20 to  65 cubic yard
 capacities  and booms  of 165  to 275 feet (USEPA 1978b).  In successive moves
 of  the draglines,  matrix  is  removed  and spoil  from succeeding  cuts  is
 sidecast.   As the ore is removed it is stacked in a sluice pit where hydraulic
 monitors  (high-pressure water guns) slurry the ore  into pumps for transport
 by pipeline to  the washing  plant (USEPA  1978b).  One recent alternative is
 to remove oversize material  near the mine pit and move  dewatered and deslimed
 (clay removed) matrix by overland conveyors to the washing plant (Timberlake
 1978).

     In North Carolina  the  process is basically the same.  The North Caro-
 lina deposits occur in  interbedded phosphatic clays, limestones, and sands
 (USEPA   1971) Hydraulic  sluicing  and transport  are  also  used  in  North
 Carolina where, as  in Florida, level terrain and excellent pumping character-
 istics make these methods feasible.

     In Tennessee,  the  high  grade  brown  rock deposits  are  a  weathered
phosphatic  limestone  that occurs  in  a north-south belt across  the  state
 (Figure 3).   Deposits are concentrated in small pockets of phosphate sands
 surrounded by silica sands.  Mining is done by open pit methods. In Tennessee
and also the western states, however, overburden is removed well in advance
of  actual  mining  operations  (USEPA  1974a).   Draglines  and  small  power
shovels are used to mine  the  phosphate sand, which is hauled  by truck or
rail to the processing plant.

     In the western United  States,  phosphate deposits  are  mined  in Idaho,
Montana,  Wyoming, and Utah, and account for 14% of United States production
 (Harre  1976).   Western  deposits  are "hard rock"  (consolidated) layers,
with degree of  hardness   generally  decreasing  the farther  north is  the
location.  Conventional  earth moving  equipment  is  used to remove  5  to 50
                                     19

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feet of  overburden.   In Utah,  the hard rock must be blasted with dynamite.
In softer  rock  areas,  "rippers" are used,  which  are toothed machines that
gouge and break the rock from the surface.  In Montana, two small underground
mines are  operated,  using  the  room-and-pillar method, which is  a kind of
underground  quarrying.   Western  rock  is  usually  transported  by  rail to
processing plants.

     Benef iciation is the  upgrading  of the ore by application of processes
to the mined  matrix  or  ore to remove inert materials (such as silica sand)
or extremely  fine materials that cannot be economically separted.  Florida
and North Carolina beneficiation processes vary from plant to plant, depending
on grade,  size,  and  ratio of  pebbles  to fines.   A generalized  procedure
starts with washing.   The matrix slurry (20 to 50% solids) is passed through
a  series of  screens, mills,  and washers  which break  down the  matrix to
separate phosphate-bearing  pebbles  from sand and clays.   Coarse  screening
obtains  a  first fraction  of oversize phosphate ore.  Further processing of
the  remaining matrix is  done  by cyclones  to remove  very fine  sands  and
colloidal size  materials.   These  are pumped to settling  ponds  and the re-
maining  fraction  undergoes  a series  of flotations  (with  tailings  going to
settling  ponds)  and  finally  the  ore  is  dried.    Some  ore is ground  and
stored in silos,  from which it  is transferred to railroad hopper cars for
transport (USEPA  1978e).

     Tennessee  ores are beneficiated  by a similar process, except that all
water is added at the beneficiation plant since matrix is received dry,  and
cyclones are  operated in  a water medium rather than air.   A further step
for most Tennessee ore  is  nodulizing in kilns, which  prepares  the ore for
use in electric  arc  furnaces  for production of elemental phosphorus (USEPA
1978d).

     Western  ore  beneficiation  starts with  crushing  and/or  scrubbing.
Subsequent sizing is  done  by  further crushing, grinding,  and size  classi-
fication. Very  fine and  colloidal  size materials  are discharged to a slime
pond  or  thickened for storage  as a  solid  waste.   The product is  dried or
may be  calcined  before shipment  as a product.
                                     20

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     Calcining is an operation done on some phosphate rock which is high in
organic content or  which will be used  in  processes requiring higher phos-
phate  content.   The  rock  is  subjected  to  temperatures   of  650-975  C
(1200-1800 F)  in  rotary  drum calcining units  (USEPA 1978b).   Organics are
destroyed  and  tramp iron  materials  are  removed  magnetically.   Because of
the high energy demands of calcining, it is not done as routinely as it was
in the past.  Alternate methods can be used in some cases to remove impuri-
ties in later processes.

     The product of the above processes, ground beneficiated phosphate rock
or concentrate,  is the  raw  material for a number  of  basic  fertilizer and
phosphorus chemical processes.   Additional grinding may be performed after
transport, or  farther  along  in the plant  complex.   The beneficiation pro-
cess produces slurry effluents that have caused notorious pollution problems
in the past  in the form of  phosphatic  clay  slurries,  or slime ponds.  The
magnitude of the disposal problem is indicated by the fact that approximately
one ton of slimes (dry weight) is produced per ton of beneficated phosphate
rock  (USEPA  1977b).   Just  one of the  larger  mining operations  in Florida
produces 111.4 billion gallons per year of slimes, with up to 45% by weight
-0.5 microns  in  size.   These slimes are typically only 5% solids by weight
(Hocking  1978).   Florida slimes  are usually  about  70% water after  15 or
more years' dewatering and occupy, therefore, more volume than the original
matrix from which they were derived  (White et al. 1978).

1.3.2  Major Processes of Phosphate Fertilizer Manufacture

     The phosphate fertilizer industry utilizes nine separate processes, as
discussed  in Section  1.1.    Figure  4  shows   the  relationships  of  basic,
intermediate, and final  product  materials involved in phosphate-containing
fertilizers.    The  two  important  basic processes  are sulfuric acid (H SO,)
production and  wet process  phosphoric  acid  production.   Sulfuric acid is
produced and reacted with prepared phosphate rock to form either NSP or wet
process phosphoric  acid.  NSP is  used primarily  as a  direct  application
material or as a constituent in dry blended fertilizers.
                                     21

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                                    PHOSPHATE ROCK
                V°4
                  NORMAL
               SUPERPHOSPHATE
    TRIPLE
SUPERPHOSPHATE
                           ¥°4
PHOSPHORIC
  ACID
                          PHOSPHATE FERTILIZER PRODUCTS
                                                AMMONIUM
                                                PHOSPHATES
                             Products  not included in the
                             phosphate fertilizer subcategory
      Figure 4.  Schematic diagram of  phosphate fertilizer industry.

Source:   Adapted from U.S. Environmental  Protection Agency.  1971.  Inorganic
   fertilizer and phosphate mining industries,  Water pollution and control.
   Prepared by Battelle Memorial  Institute,  Richland WA, 226 p. ^.n USEPA  1979a,
                                      22

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     Wet  process phosphoric acid is  concentrated  and clarified to product
strength and is  used to produce triple superphosphate or mono- or diamraoniura
phosphate. Alternately, wet process phosphoric acid can be further concentrated
and  impurities  removed  to form  superphosphoric  acid  (SPA).   Wet  process
phosphoric acid  is  also used in production of blend  fertilizer products or
sold to other  industrial users.  The concentration of wet process phosphoric
acid  to  form  SPA is  a process not specifically  included  in the phosphate
fertilizer effluent guidelines Development Document (USEPA 1974a).  Because
of specialized operations and problems, however, and because the process is
done only  at  plants also producing phosphoric acid (utilizing common waste
streams, utilities, and pollution controls), a description of the superphos-
phoric acid manufacturing process is included.

     In Figure 4, the product blocks with hatching represent mixed or blend
fertilizers which are  not  covered in these Guidelines.  The ammonium phos-
phates are technically mixed fertilizers because they contain more than one
of the  basic  plant nutrients,  but they were  included  in  the subcategori-
zation for phosphate  fertilizer manufacture (and in  this document) because
                              ~-\
they  are  normally  produced  in  the  same  facilities  as basic  fertilizer
materials  and contribute  to  the  same  waste streams  (By   telephone,  Dr.
Elwood Martin, USEPA,  January 26, 1979).

     The  phosphate  fertilizer  industry is  remarkable  for  the  degree of
integration maintained among the processes at a typical installation.  Con-
sequently, the majority of  the  United States production is carried  on at
plant complexes, and the wastewater and gaseous effluents have largely been
channeled into combined streams with common treatment systems to the extent
this  is feasible, or unless contaminants from certain processes may produce
conditions more costly to treat at a later point.

     The  integrated  character  of  the  industry  can  be appreciated  with
reference to Table  4.   The table shows that of the 114 plants in operation
(in 1976) over  70%  produce one type of phosphate fertilizer material only,
and less  than 30%  of  the  plants  consist  of  multiunit operations.   Those
relatively few multiunit plants,  however,  account for more than 80% of the
total volume  of phosphate fertilizers (USEPA 1979a).
                                    23

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     Table 4.  Description of phosphate fertilizer complexes in the
          United States by unit operations.
Unit operations
at plant site
WPPA only
NSP only
DAP only
WPPA, SPA
WPPA, NSP
WPPA, TSP
WPPA, DAP
NSP, TSP
WPPA, TSP, DAP
WPPA, SPA, DAP
WPPA, NSP, TSP
NSP, TSP, DAP
WPPA, SPA, TSP, DAP
WPPA, NSP, TSP, DAP
SPA, NSP, TSP, DAP
TOTAL
Number of plants
with this combination
7
54
20
3
1
2
10
1
6
2
1
1
4
1
1
114
Percent
of total
6.1
47.3
17.4
2.6
0.9
1.8
8.8
0.9
5.3
1.8
0.9
0.9
3.5
0.9
0.9
100
  WPPA - Wet process phosphoric acid.
  DAP - Diammonium phosphate.
  NSP - Normal superphosphate.
  SPA - Superphosphoric acid.
  TSP - Triple superphosphate.

Source:  US Environmental  Protection Agency.   1979a.  Source assessment:
         Phosphate fertilizer  industry.   Office  of  Research and Develop-
         ment,  Washington, DC.   Prepared  by Nyers,  J.M.,  G.D.  Rawlings,
         E.A.  Mullen,  C.M. Moscowitz,  and R.B. Reznik,  Monsanto Corp.,
         Dayton OH,  201 p.
                                    24

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     In  addition,  although effluent  guidelines apply  to both single unit
and multi-unit  operations, those  standards were  promulgated  cognizant of
the operating procedures of the integrated complexes, in which contaminated
water is typically used for all processes where presence of contaminants is
not critical.   For  example,  contaminated water is  recycled  for use in wet
scrubbers,  to  rinse  precipitates  from  filters,  and to  supply barometric
condensers  and  heat  exchangers  (USEPA 1979a, USEPA  1974a).   Each time the
water  is recycled,  the levels  of contaminants are increased, but  a key
point applicable  to  the process descriptions in the sections  which follow
is that  typically  this  contaminated wastewater is aot  discharged from the
complex.  It  is a process effluent or wastestreara,  but it is not a regularly
discharged effluent.  The Source Assessment conducted by Monsanto researchers
during  1976  and 1977 (USEPA 1979a) revealed  that  only  approximately  8% of
all  phosphate  fertilizer  plants   still routinely  discharge  wastewater.

     These figures do not reflect,  however, that most existing plants  still
have the  need  to discharge  water  for certain periods  of  time during most
years.    Because the recycled water systems are usually  a  series of  large
outdoor  ponds,  extended heavy rains necessitate discharge  of  excess  accu-
mulated water.  Excess water can also develop due to occasional miscalcula-
tions or misadjustments- of chemical reaction processes,  resulting in errors
in water  management  plans.   In general, plant operators  attempt to  avoid
such discharge  events due  to USEPA and state requirements for pretreatment
of discharged wastewaters,  at  additional  cost to  the  operators.  Further
wastewaters from uses which  are not involved in production processes  (non-
process wastewaters) can be  discharged continuously and  in  many cases are
kept separate  from  process  wastewaters to  effect  economies  in treatment
costs.
                                    25

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1.3.2.1  Sulfuric Acid Production

     Production of phosphoric  acid  by the wet process requires almost one ton
of  sulfur  (as sulfuric  acid)  for each  ton of P205 produced.   In the United
States virtually  all  sulfuric  acid  is produced by  the  contact process, which
represented  99.3% of  total production  in  1971 and had  increased  to 99.8% in
1976  (USEPA   1978a).   Since New Source Performance Standards  (NSPS)  for S02
were promulgated in 1971, the "double" or "dual" absorption process has become
the system of choice because of its efficacy as a combined process option/emis-
sions control system that meets the NSPS for SO-.

     All contact sulfuric acid  manufacturing processes incorporate three basic
operations:

     (1)  burning of sulfur or  sulfur-bearing feedstocks to form SCL;
     (2)  catalytic oxidation of S02 to SO ; and
     (3)  absorption of SO  in  a strong acid stream.

The  least  complicated systems   burn  elemental sulfur.   Additional operations
are required to remove moisture, organics,  and particulates prior to catalysis
and  absorption  when feedstocks  such  as spent  acid and acid  sludge are used
(USEPA 1978a).

Elemental Sulfur Burning Sulfuric Acid Production - Single Absorption

     Elemental sulfur is the feedstock for sulfur burning contact process acid
for  about  68% of  total  U.S. production (USEPA  1978a)  and  for sulfuric acid
produced at  fertilizer plants  for captive use it is the only feedstock in use
(USEPA 1977b, USEPA 1978b).  The process is represented by the schematic flow
diagram, Figure 5.

     In  this  process  molten elemental  sulfur is filtered and  sprayed into a
dry air  stream inside  a  furnace.  Combustion air has been predried by passing
it through a drying tower containing 93.2-99% sulfuric acid.   The high furnace
temperature auto-ignites  the sulfur and oxidizes it to form SO^. This exothermic
                                      26

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     BLOWER
                         STEAM DRUM

                     SLOWDOWN •*-
STEAM  JO
  ^ATMOSPHERE
                                          BOILER   CONVERTER
         STORAGE
                                               ACID PUMP
                                                TANK
                                                     PRODUCT
           Figure 5.  Contact-process  sulfuric acid plant burning
                elemental sulfur -  single absorption.

Source:  U.S. Environmental  Protection Agency.  1971a.  Background  information
   for proposed new source performance standards.  Office of Air Programs,
   Research Triangle Park NC in USEPA 1978a.
                                      27

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reaction releases  large  amounts of heat.  The  mixture of SCL and excess  com-
bustion air  (8-11% SO   by volume) reaches temperatures  of  980-1140 C  (1800-
2000  F)  as it  leaves  the  furnace.   It is  cooled by  being  routed through  a
boiler, where steam is generated and the temperature of the SO -air mixture is
reduced to an  optimum  temperature for  chemical  conversion of the SO^ to  S0_.

     The cooled  S0? gas,  together with predried  air, then  enters the solid
catalyst converter  where  it is converted to  SO  in a series of three or  four
steps.  Several  different  catalysts are available, but  vanadium pentoxide is
the  most  commonly  used.   Each of  the  conversion  steps  takes  place  under  a
different reaction condition to achieve optimum conversion of S02 to S0_.  The
gas temperatures in each conversion stage rise until equilibrium is approached;
the gases are  cooled  after each intermediate stage as well as after the final
stage.  The gas exiting the converter is cooled in an economizer (heat exchanger)
to  temperatures  between 230  and  260 C (450-500  F).   At this  stage  S02-S0
conversion efficiency is about 98%.

     Following conversion  the SO   gas  is  circulated  upward  through a packed
absorption tower.   The  tower contains  ceramic  packing with  98-99% sulfuric
acid  (H SO,)  circulating downward,  counter  to  the  gas current.   The SO,, is
readily hydrolized  to  H-SO,  by the  water  in the  acid.   Since  the hydrolysis
reaction is also exothermic, the acid circulating from the tower flows through
cooling coils  and  then  to  the pump  tank whence it is recirculated.  The acid
strength and temperature are carefully regulated to prevent excessive SO,, re-
lease.  Normally, absorption efficiency  is  essentially 100%.

     The pump  tank acts as a  reservoir for  process  sulfuric  acid.   The en-
riched 98-99% acid enters the pump tank, and  a portion is recycled through the
absorption tower.   Also  a  portion of  the acid is cycled to  the  air drying
tower.  In this  operation  the  98-99% acid is  first  diluted  to approximately
93% and  circulated  through  the  drying  tower,  counter-current  to  the upward
circulating air.   Moisture  in the  air is absorbed by the acid (slightly diluting
it further) and  the dry  air enters the  furnace.  The 93% diluted acid returns
to the pump tank  for  mixing with  the 98-99%  acid  flowing in from the absorp-
tion tower.   Product acid is the excess  over  drying tower and absorption tower
recycle requirements.  It  is  diluted with  water to the  desired concentration
                                      28

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(normally  93%)  and is  pumped to  storage  as  the  pump tank  is  monitored and
maintained at a constant level.


     The  basic  requirements  and  functions  of  suIfuric  acid  production are

summarized in the following table:


         Table 5.  Sulfuric acid manufacture from elemental sulfur.


Input Materials

     •  Sulfur
     •  Air
     •  Water (make-up water)

Utilities

     •  Cooling water (process water)
     •  Electrical energy
     •  Filter acid
     •  Steam (production)

Waste Streams

     •  Tail gas (containing SO  and acid mist)
     •  Cooling water blowdown
     •  Boiler blowdown

Product

     e  Sulfuric acid, which may be used for

        —normal superphosphate processing
        —wet process phosphoric acid production
        —ammonium phosphate processing
        —ammoniation/granulation/drying
        —out of plant sales
Several  terms  introduced  above  are  used repeatedly  in  industrial  process
descriptions:


     Make-up water  is feed  water  that  is of  acceptable  quality  for utili-
     zation within a process, including use as a raw material.


     Process water is any water which, during the manufacturing process, comes
     into contact with any raw material, intermediate, product, or by-product,
     or with gas or liquid that has accumulated such constituents.

                                      29

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     Slowdown  is  the purge  from  the system  of a  small portion  of  the con-
     centrated water  (from  a boiler or recirculating process stream) in order
     to maintain  the maximum  level  of  dissolved and  suspended  solids  in the
     system.

     Tail gas  is  the  accumulated  captive gaseous waste stream at the end of a
     process.

Elemental Sulfur Burning Sulfuric Acid Production - Double ^sorption

     The double absorption  process,  which was used partially as the rationale
for  the  SCL NSPS  has become  the  control system  of  choice by  sulfuric acid
manufacturers  since  the  NSPS were promulgated in 1971.   Because  it is a very
widely utilized process  option,  rather  than an add-on emission control system
such as an  ammonia scrubber, it is  described  at  this point and is referenced
in the Section 3.2 discussion of pollution control technology.

     Figure  6  is  a process  flow diagram which incorporates the double absorp-
tion system.   The essential  feature that differentiates  it from  the  single
absorption process is the addition of the second absorption tower.  The second
tower is installed at a point intermediate between the first and final SCL-to-SCL
catalytic conversion steps.   This second absorption process permits the achieve-
ment of  a  greater  conversion of  SO,  to SO-  and significantly  reduces  the
quantity of  SO, in the effluent gas stream.   Double absorption plants achieve
SO-  conversion efficiencies  of   99.5+%  as compared  with   approximately  98%
efficiencies for single  absorption  plants.   Wastewater effluents are the same
for either process in regard to quantities and contaminant levels.

     In either process option,  single or double absorption, the cooling tower
closed   loop  and   the  boiler  for  waste  heat  removal  are  standard  systems.
Closed  loop  cooling  systems  function with forced air and water circulation to
effect  water  cooling  by evaporation.   Evaporation  acts to  concentrate  the
natural water impurities  as  well as  the  treatment chemicals required to inhibit
scale growth,  corrosion, and  bacteria  growth.  Such  cooling  systems require
routine blowdown to maintain impurities  at an acceptable operating level.  The
blowdown quantity  will  vary  from plant  to  plant and  is dependent  upon  the
cooling water circulation system.
                                      30

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      98% ACID    PRIMARY    HEAT     CONVERTER     ECONOMIZER  SECONDARY  98% ACID
               ABSORBER EXCHANGER                           ABSORBER
                   Figure  6.   Dual absorption sulfuric  acid
                         plant flow diagram.

Source:  U.S. Environmental  Protection Agency.  1971a.   Background information
   for proposed new  source performance standards.  Office of  Air Programs,
   Research Triange  Park NC  in USEPA 1978a.
                                       31

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     "The  type  of process  equipment  being cooled normally  has  no bearing  on
the effluent quality.   Cooling  is by an  indirect  (no process liquid contact)
means.  The only  cooling  water  contamination from process  liquids is  through
mechanical leaks in heat exchanger equipment.  Such contamination  does  period-
ically occur and continuous monitoring equipment is used to detect such equip-
ment failures" (USEPA 1974a).

     The  boiler   in  the sulfuric  acid  process  is  the only  steam generation
equipment  operated  in  a phosphate fertilizer plant.   Medium pressure  (9.5-52
atm) steam systems  are the most generally used  (USEPA 1974a).  No contamina-
tion of boiler  water is caused by process gases, except minor amounts through
leakage.

Sulfuric Acid Production by Burning of Spent Acid and Other By-Products

     Where spent  acid,  sludge,  and similar feedstocks are employed,  the pro-
cesses are more  elaborate  and expensive than sulfur-burning plants due to the
fact that  the  S0_ gas  stream is contaminated.  Sulfur from the Frasch process
(Sec.  1.3.3.1)  is  the usual raw material  for  sulfuric  acid production for
phosphate  fertilizer manufacture.  By-product  acid  is not produced and seldom
used because of  possible  adverse effects of  the  impurities  on the phosphoric
acid process (USEPA 1977b).

     There have  been  instances of  short supply of  Frasch  sulfur  caused  by
sudden  increases  in phosphate   fertilizer  capacity   around  the  world  (Slack
1968) but  U.S.  producers  generally  purchase sulfuric acid  when necessary to
supplement in-plant production.   Normally, other types of  sulfur feedstock are
not utilized by the phosphate fertilizer industry.

1.3.2.2.  Phosphate Rock Processing - Crushing, Grinding,  and Screening

     Beneficiated phosphate rock  usually requires  additional  processing to
reduce the  ore  to  the particle size  range for  optimal  phosphoric  acid pro-
duction.   Crushing  and  grinding  are  done  with ball, ring-roller,  or  bowl
mills, and with hammer mills.   The first three are rotational mills where the
feed material is crushed and ground (respectively) by:

                                    32

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     (1)   crushing  among  steel balls  in a  rotating  compartment  (a  type of
          "tumbling mill");
     (2)   crushing  between  a  grinding  ring  and two  or more  rollers  which
          rotate orbitally around the outer surface of the ring;
     (3)  crushing between rotating rollers and the inner surface of a
          grinding ring within a bowl shaped chamber.

Hammer mills operate by crushing material by impact and grinding.  The hammers
(massive protrusions  in a  variety  of shapes)  project from  a rotating  shaft
which rotates  in  a  housing containing grinding plates or liners (Perry 1969).

     After  the  rock enters  the mill system, flow through  sizing and reclam-
ation circuits  is by  pneumatic means when  dry  grinding  is performed.  Air is
constantly exhausted from the mill system to prevent precipitation of moisture
released  from  the  fractured  rock  and  entrained  rock particles  are removed
usually  by bag  type   filters  before  the air  is vented  to  the atmosphere.
Figure 7 illustrates the process flow for rock grinding.

     An alternative to this process is wet grinding of phosphate rock.  It was
in the period of 1973-1975 that the first commercial installations were developed
for use  in conjunction with wet process phosphoric acid production. The major
objective  was  to  reduce  energy  requirements  by  eliminiating drying of  the
rock.  Wet  grinding also eliminates the need for dry storage of incoming rock
and greatly reduces problems in collection and handling of dust.  Wet grinding
is accomplished with  the addition of small  amounts  of water to the feed, and
flow of ground rock to the phosphoric acid process is in the form of a slurry.
The  wet  grinding  process  is  operating  well  in several  installations and is
considered a  promising  recent  technological advance.  At one new source plant
the  operator  is planning  to  utilize wet phosphate rock  without  any grinding
(USEPA 1978p).  In  that instance at the proposed Swift Creek Chemical Complex
in Hamilton County, Florida,  the operator will utilize phosphate ore from the
Hawthorn geologic  formation,  which  occurs  in  sand-size  particles  unlike the
pebble-size ore in  the  central Florida Bone  Valley  formation and the massive
hard rock ores of  western states.
                                      33

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     No wastewater effluents  are  produced by either dry or wet grinding. Only
small amounts of  water  (Figure  7) are utilized for indirect cooling of lubri-
cating oil  and  mechanical  equipment.   Exact amounts utilized  for cooling in
wet  grinding were not  determined,  but  would  also be  very minor.  The water
added  to  phosphate  rock for wet grinding  is  incorporated into  the process
reactants.   The  required  basic  materials  for  the  phosphate  rock grinding,
crushing,  and screening process  are listed in the following summary:

          Table  6.  Phosphate rock crushing, grinding, and screening.

Input Materials

     •  Phosphate rock,  as mined for certain high grade ores, or beneficiated
     •  Air (not consumed; dry grinding only)
     •  Water (make-up water; wet grinding only)
Utilities
     •  Cooling  water (process water)
     •  Electrical energy
Waste Streams
     •  Air (containing particulate phosphate rock)
     •  Cooling  water (non-contaminated discharge; water has increased
        temperature only)
Product
        Ground phosphate rock (dry grinding)
        Ground phosphate rock slurry (wet grinding)
     Since phosphate rock being  ground  is for reaction  in  a particular down-
stream process  or,  in the  case of  some  high grade  ores,   for  sale  to other
industries, the  desired  particle  size  varies according to  ultimate  use.  For
example,  most  wet-process  phosphoric acid  in the  United  States  is  produced
from 35-mesh  to 150-mesh particulate  (0.4mm-0.09mm), the  size of medium to
very fine  sand.   Standard  practice  has been  to  grind to the  very  fine sand
sizes to  optimize chemical reaction of  the phosphate rock.   Energy is required
whenever  size reduction is  used  to achieve these sizes  (some sizing is first
accomplished  by screening  in  the  beneficiation  process).   Less energy  is
                                     34

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                          LEGEND
                            MAIN ROCK
                            MINOR ROCK
                           •MINOR AIR
                                                  EXHAUST AIR
             PHOS. ROCK
  COOLING WATER
  (8~ 150 GAL/TON)
  33 ~ 625 l/kkg


  COOLING WATER
  (8~ 150 GAL/TON)
   33 ~ 625 l/kkg
 TON = SHORT TON
 kkg = METRIC TON
   DUST
COLLECTOR
                                                                   PRODUCT
        Figure 7.  Rock grinding (flow rate per ton rock)-
Source:   Adapted from U.S.  Environmental Protection Agency.  1974a.  Develop-
   ment  document for effluent limitations guidelines and new source performance
   standards for the basic  fertilizer chemicals segment of the fertilizer
   manufacturing point source category.   Office of Air and Water Programs,
   Washington DC,  168 p.
                                     35

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required when less grinding is required, and at least one process, the Kellogg
Lopker  process  (Anonymous 1972a),  is  in use  in England  which requires less
grinding  (90-95%  -40  mesh).   Depending  on the  phosphate rock  source, some
portion of  this sizing is accomplished by  screening  alone.   No United  States
plants are utilizing the Kellogg-Lopker process at this time.

1.3.2.3  Normal Superphosphate Production

     Because of its low investment costs and ease of preparation, NSP is still
produced in  small  plants  throughout the United States.   The  process involves
reacting  phosphate rock  with sulfuric  acid  to  form  monocalcium phosphate:
The  monocalcium  phosphate produced  is  water-soluble and  the  phosphate is
available to plant  uptake  in  soil solutions.  The calcium sulfate (gypsum) is
not  separated  from  the  monocalcium phosphate, which makes  use of this ferti-
lizer more popular in areas of sulfur deficient soils.

     Processes  may  utilize batch or  continuous  process modes  with various
modifications,  but  the  basic  process  operations  do  not vary.   Figure 8 re-
presents a normal continuous process operation.  Phosphate rock which has been
ground  to  90%  -100 mesh   (0.15 mm.)  is fed  at  a controlled  rate  to a mixer
where it is thoroughly mixed with 65-75% sulfuric acid.  The acid-rock mixture
is a slurry which  is  discharged to  a pug  mill where  additional  mixing and
reaction takes place.   The reaction is very rapid and  exothermic.

     A pug mill  consists  of a horizontal cylindical or trough shaped chamber
containing one  or two  rotating  shafts fitted with short heavy paddles.  The
slurry is  fed   into one  end  of  the  mill and is both cut  through and forced
forward by  the paddles until  the slurry is  discharged  through an opening at
the  other end  of  the  mill.  Residence time in the pug mill for NSP production
is two minutes or less.

     From the mill the slurry  discharges to a slow moving conveyor (continuous
den)  where the  reaction  continues and the  slurry  stiffens  to a plastic mass.
                                     36

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           SULFURIC  ACID
                   WATER
U)
-J

PONF /"T.""3 ~


i D»\ /
PUG MI
! c
1
S r

CAL


\ 1
Z*t-f MIXER
LL
ONTINUOUS DE
CUTTERO^
'~O CONVEYOR ()

1
i
ES •*•

— -GROUND PHOSPHATE ROCK
i
EXHAUST GAS
Nj
11
() CONVEYOR



i
i
"N
^>l
1
metric ton P205
WATER
	 *• GAS DISCHARGED
f
i
1 	 » WASTEWATER
0.9 to .0 m3
EXHAUST GAS metric ton P205

BUILDING * PULVERIZER » PROD
                                 Figure 8.  Normal superphosphate flowsheet.

      Source:  Adapted from U.S. Environmental Protection Agency.   1971.   Inorganic fertilizer and phosphate mining
         industries, Water pollution and control.   Prepared by  Battelle Memorial Institute, Richland WA, 226 p.

-------
 (In  batch  processes  the den is internally stationary, with no conveyor).  Den
 residence  time  varies  from one to four hours.  As the plastic mass leaves the
 conveyor it  is  cut into chunks.  At this stage evolving gases have given it a
 honeycomb  appearance.

     The cut up product is transferred to a storage area, where it "cures" for
 two  to six  weeks,  depending on  process  conditions,  as  the slowing reaction
 between rock and acid continues.  If granulated final product is being produced
 granulation is  usually done before curing.  Otherwise, when curing is complete
 the  solidified  NSP is  fed through a pulverizer  (hammermill usually)  where it
 is crushed and  screened.

     Returning  to  the  mixer and pug mill reaction, calcium fluoride contained
 in  the phosphate  rock  is  also attacked by the  sulfuric  acid.   This reaction
 forms  hydrofluoric acid  (HF),  which  reacts  with  silica in  the  rock to form
 SiF,  plus  water.  This  in turn  reacts  with  some of the water  to form fluo-
 silicic  acid (H SiF,) , but  some  of the  SiF, is  volatilized before reaction
 with  water  can take place.   The proportion  of  SiF, volatilized  depends  on
 concentration of H SO,  used.   The higher the acid concentration the more SiF,
 is  evolved.  SiF,  is also evolved through the denning operation, with a small
 amount forming  during the curing step.   In actual operations  the mixer and den
 are enclosed and emissions are scrubbed with water to remove  fluorides and any
 acid mist  and dust particles.  Air from the curing building is also circulated
 through the wet scrubber to remove the smaller amounts of fluorides evolved in
 that stage.

     In  integrated  phosphate  fertilizer  complexes  (producing phosphoric acid
 and/or triple superphosphate and/or ammonium phosphates) the  scrubber uses the
 common contaminated  water  (or  pond water) stream; that is, in most instances,
 a closed loop  wastewater  circulation  that does  not  usually require discharge
 from  the  plant  system.   Solids  removed or precipitated  in this solution are
contained in the gypsum pond, or filtered out and stacked on  the premises.  In
 smaller plants  producing NSP only or primarily, the scrubber  liquor is usually
run  into beds  of limestone to  precipitate CaF_, which is  considered  to be a
solid waste (USEPA  1979a).
                                       38

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     The basic process  constituents for NSP production  are summarized below:

                  Table 7.  Normal superphosphate production.

Input Materials

     •  Pulverized phosphate rock
     •  Sulfuric acid
     •  Water (make-up water to dilute sulfuric acid)
Utilities
     •  Electrical energy
     •  Scrubber water
Waste Streams
     •  Air (particulate phosphate rock, acid mist, fluorides)
     •  Water (process water) - the only process water involved is scrubber
        effluent
     •  Solids - CaF  and dust absorbed in scrubber effluent are precipitated
        or allowed to settle out in gypsum ponds
Product
        Normal superphosphate - generally sold as fertilizer or dry mixed
        with other fertilizer materials and sold as solid mixed fertilizer
1.3.2.4  Wet Process Phosphoric Acid Production

     Phosphoric acid  is the  most  important  intermediate  manufactured  by  the
phosphate fertilizer  industry  because  it is  a basic  ingredient  to every pho-
sphate fertilizer product which the industry produces other than normal super-
phosphate and salable  phosphate  rock.   Phosphoric  acid  can be  produced  by
either the digestion of phosphate rock with a mineral acid (wet process) or by
hydration of phosphorus with air in an electric furnace (thermal process).  The
acid produced by  the  thermal process,  which requires considerable energy con-
sumption, is  known as  furnace grade acid  and is  of higher  purity  than  wet
process acid.  Furnace  grade acid  is used  for animal feeds, detergents, fire
retardant  chemicals,   and  other  industrial  phosphorus  products,  but  is  no
longer used to produce phosphate fertilizers  (USEPA 1979a).
                                      39

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     Wet process  acid  contains  more impurities than  does  furnace grade acid,
and  is known  as  merchant  grade phosphoric  acid.   All  phosphate fertilizer
production  from phosphoric acid  in the United States  uses  wet process acid.
The  wet process is based on reaction of phosphate rock with a  suitable strong
acid to produce phosphoric  acid and an acid  salt.  The choice of strong acid
depends on  such  factors  as  cost and  availability,   simplicity  of operation,
materials of construction and type of equipment required, and the waste streams
and  end  products  generated.  In  the United States,   sulfuric acid is far and
away the most  widely used,  but  nitric and hydrochloric acid can also be used.
In 1973 98.77%  of all wet process phophoric acid utilized sulfuric acid acidula-
tion,  with  1.23%  utilizing  nitric acid and no  plants using hydrochloric acid
(USEPA  1974a).   Current data on  type  of  acid  used  for acidulating phosphate
rock is not readily available, but no mention of commercial use of acids other
than  sulfuric  has been  noted in references  since the  surveys done  for  the
USEPA Development Document (USEPA 1974a).

     In general,  nitric  acid  acidulation has  been   characterized  by complex
multi-stage processes,  requiring  use of additional mineral  acids  and organic
solvents,   with serious consequent  corrosion problems.   Furthermore, several
additional stages involving costly cooling, crystallizing of dissolved calcium
nitrate, and addition  of  additional reagents to  precipitate calcium, results
in  typically  viscous  phosphoric  acid  of  27  to  35% P-,0,..  Alternatives  to
remove  calcium cleanly  require use of  ammonia,   which  is  itself  an energy-
consuming  somewhat costly product to manufacture.   The simplest of nitric acid
acidulation processes utilizes ammoniation of the acidulated acid-rock solution
to produce nitric phosphate,  a fertilizer  material, but the phosphoric acid is
not obtained,  having  been present only in  the solution, and some of the phosphate
becomes tied up in calcium phosphate, which is not water soluble and therefore
not useful  as  a fertilizer (Slack 1968).  For such reasons, nitric acid acidula-
tion is not widely used and  has normally  been  employed only when nitric acid
is a cheap  or  readily available  coproduct  in an industry.  No further discussion
of nitric  acid  acidulation is  warranted in this Guidelines document.
                                      40

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                  Sulfuric Acid Acidulation of Phosphate Rock

     The popular process  of  acidulation of phosphate rock  with  sulfuric acid
has the advantage  of  quick formation of calcium  sulfate dihydrate,  or gypsum
(CaSO,'2H20) .  All acidulation  processes  produce  gaseous and liquid effluents
which must  be  controlled,  but disposal of  the  solid  by-products formed poses
the most  cumbersome  potential  problem.   1.76  metric  tons  of phosphate rock
concentrate  (average 32%  P2°5^  and lt53 metric tons of sulfuric acid (average
93%  H2SO,)  are  reacted  per  metric  ton  of  phosphoric acid  produced   (USEPA
1977b).  Typically. 4.6 to 5.2 metric tons of gypsum by-product are formed per
metric ton of phosphoric acid (USEPA 1979a).  Nonetheless, as described in the
discussion  of  nitric acid acidulation,  the formation of  a  stable,  filterable
by-product which does not take significant amounts of phosphate ion out of the
system is a distinct  advantage.

     Besides the dihydrate form, it is also possible with sulfuric acid diges-
tion processes  to  precipitate calcium sulfate as the hemihydrate (CaSO, '^H-O)
or the anhydrite (CaSO.) form.  The dihydrate process has offered basic advan-
tages over  the other  two processes, such as less severe operating conditions,
lower  rates  of  corrosion,   better  f ilterability ,  and  lower  capital  cost.
Figure 9 shows the precipitation conditions for calcium sulfates in phosphoric
acid .

     A  flowsheet  typical  of  the  dihydrate  process  is  shown  in  Figure 10.
Ground beneficiated  or concentrated  phosphate  rock is  fed  continuously to a
reaction system  where   it  is  mixed with sulfuric acid.   The  sulfuric  acid is
diluted,  sometimes with  contaminated  process  water,   to  a  proper  strength
depending on the  process  design  and on phosphate  rock composition to ensure
optimal  dihydrate  crystallization.   Some  commercial  processes  also  recycle
some dilute  phosphoric  acid  into the reaction  system.   Older plants may have
one or  more digestion  or  attack  tanks, but in more  recent  installations the
the  reaction  system  is a  single  large  compartmented  tank.   In  this  attack
vessel, the rock and  acid react to form dihydrate (gypsum) and phosphoric acid
according to the following reaction:
                                      41

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                 120
                 100
              o
              o
              a:
              on
              LU
              O-
                  60
                  40
                  20
                 HEMIHYDRATE
                  PRECIPITATED; ANHYDRITE
                       (CaS04) STABLE
DIHYDRATE(CaS04-2H20)
PRECIPITATED; ANHYDRITE
      STABLE
                       DIHYDRATE PRECIPITATED
                           AND STABLE
                            10
            20
                                                     _L
                                     _L
                                             30
                             40       50
       ACID CONCENTRATION, PERCENT P205
                                                                      60
                 Figure 9.   Precipitation and stability of  calcium
                      sulfates in phosphoric acid.
Source:   Slack, A  V.   1967.   Chemistry  and technology of  fertilizers.
   Wiley  & Sons, Inc.,  New York NY, p.  69-97 in USE?! 1979a
                                                      John
                                        42

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Vu4
PHOSPHATE 	 1
ROCK *1
D
HH 1 LK ~

RECYCLE fpLUOF
ACID J FUM!
4 1 '
iii


~p_



UDE '
IS

	 > VENT TO ATMOSPHERE
FLUORINE
Sf.RllRRFR


r WATER
i ! J
R
r— — WATER

: : 1 g
y

. 1 ,-
r


L

ACID
* UONCLNIkAlUK

GYPSUM SLURRY
TO GYPSUM POND
~ — WATER
	 -*• VENT TO ATMOSPHERE
FLUORINE
SCRUBBER

PHOSPHORIC
STORAGE
     Figure 10.   Wet  process  phosphoric  acid flowsheet.

Source;   Adapted from U.S.  Environmental Protection Agency.   1971.   Inorganic
   fertilizer and phosphate mining industries,  Water pollution and  control.
   Prepared by Battelle Memorial Institute,  Richland WA,  226 p.
                                      43

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      To obtain complete  reaction  commercial processes  mix or recirculate the
 rock-gypsum-acid  slurry  through the tank compartments.  The temperature in the
 attack vessels is also  controlled  (usually at about 75 C) to ensure  formation
 of  dihydrate.  The  reaction is exothermic, with  higher  heats  produced  when
 more concentrated acids  are used.   Cooling water, vacuum coolers, air sparging
 (flowing air through a  liquid)  and dilution and cooling of the acid  are tech-
 niques used  to control process  temperatures.

      Retention time  in the  attack  vessel varies with different process designs
 from 3 to 8  hours.   Efficiencies  of commercial  systems are usually  in excess
 of   96%  extraction of VyO?  from the  rock.   The  recirculation of  the  slurry
 controls the supersaturation necessary to attain good growth of gypsum crystals.
 Th«  gypsum  crystals  must  be easily filtered  and retain  a minimum  of  P?0 •

      Regardless of  process design,  the calcium  fluoride  constituent  of  the
 phosphate  rock ore  will  also   react  during acidulation   to produce  hydrogen
 fluoride  according to the following reaction:

                    CaF9  +  H SO. +• 2HF  + CaSO,
                       f-     /   H             4

 In  addition, calcium fluoride  reacts  with  phosphoric  acid  according  to  the
 reaction:
                                          04)2  +  2HF

The  hydrogen fluoride evolved may  leave  the slurry as  a gas or  it  can react
with silica  present in the phosphate rock:

                    SiO  + 6HF * H9SiF, + 2H00
                       *•          *•   o      2

During  the  later acid  concentration steps,  fluosilicic acid  (H2SiF6)  in the
phosphoric acid solution can dissociate by the  following reaction:

                    H2SiF6 -*-SiF4 + 2HF

The fluoride products formed can all volatilize and are  major emission species
                                     44

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in the contaminated emission stream.  All reaction systems include a system to
pass evolved  gases  through wet scrubbers to remove fluorides, along with acid
mists and particulates.

     Each system  design  varies as to the number  and  location of sgitaior.- or
recirculation  mechanisms  and  in  the locations and methods  of  phosphate rock
and sulfuric  acid  points.   In the United States,  approximately 75% of all wet
process reaction  systems  or "trains" use the Prayon or the Prayon/Dorr-Oliver
systems.  Figures  11  through  14  illustrate  schematically four  systems  using
different  equipment,  but  the basic process  and the  resulting  product  and
by-products are essentially the same.

     The acid slurry in all systems  flows from the digester to a filter system
where  the gypsum  solids  are  removed.   A   typical  filter system  yields  two
phosphoric acid streams:
        a 30-32% P20  product stream;
        an approximately 20% P90,- content acid stream which recycles to the
        digestor.
Figures  15  and 16  illustrate the widely used  tilting  pan filtration system,
Slurry is discharged onto the filter and the undiluted mother liquor  (product)
is collected and  pumped  to a surge  tank,  from which it  is  fed  into the next
process (concentration).

     The residual  slurry on  the  filter pans  is washed  in  three stages by a
continuous  countercurrent stream  to  remove additional phosphoric acid.  These
streams ultimately  recycle into  the digestor  system and the  filter cake is
washed from the filter by recycled contaminated water (gypsum pond water) and
pumped to the gypsum pond for cooling and solids settling.

     Wet process phosphoric  acid  production conditions are  shown in Table 3n
                                      45

-------
                              WATER
                                      93% H2S04

                                     TO SEWER
WATER
       STEAM
                       cJo  cJo  do  cJo  
-------
             COOLING WATER
               H2S04 ACID
                  WATER
                                 DILUTER COOLER
                                 ' (OPTIONAL)
                            VAPOR TO -— c-s
                        FLUORINE RECOVERY  I
                       CONDENSER AND VACUUM JJ- -
                        	RECYCLE ACID
                               FROM FILTER

                            ,-3 —. VAPOR TO
                            |[  FLUORINE RECOVERY
                         -	II CONDENSER AND VACUUM
                              PRIMARY DIGESTER
                                                SECONDARY DIGESTER
         Figure 13.
Flow diagram for Singmaster and -Breyer
dihydrate  phosphoric acid  process.
                                               WATER-
              H2SO«
                ROCK
                              HEMIHYDRATE
                               VACUUM
                               COOLER
              PHOSPHATE  Q
                eivv —i V
                   NO. I REACTOR
                   HEMIHYDRATE
               NO. I DIGESTER
                 GYPSUM
NO. 2 DIGESTER
  GYPSUM
          Figure  14.
  Flow  diagram of  Singmaster  and  Breyer
  hemihydrate-dihydrate process.
Figures 13 and  14  reprinted from Phosphoric Acid, Volume  I,  A.V.  Slack, Editor,
   by permission of Marcel Dekker,  Inc.,  Year of first  publication 1968.
                                       47

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           SLURRY
            FROM -
           REACTOR
                                      Jt
                                             WASH WATER
                    LIQUOR
          TO MAIN
       VACUUM PUMP AND
          FUMES TO
        WET SCRUBBER
 1ST WASH
                        Y
                                    2ND WASH
                 3RD WASH
                                  FILTRATE
                                  RECEIVERS
                                  J   L
    Y    Y
DISCHARGE CAKE
                              I       I      I
                         MULTI - COMPARTMENT FILTRATE SEAL TANK
                              I	I
      WEAK ACID
    TO ATTACK TANK'
                                                          RECYCLE
                                                                          WATER
                                          - PROCESS
                                           EFFLUENT
                                            WATER
                                                    RECYCLE
                                        • TO EVAPORATOR
                                                             TO GYPSUM POND
              Figure  15.   Tilting  pan  filtration system.

Source:  U.S.  Department  of  Health,  Education, and  Welfare.   1970.  Atmospheric
   emissions from wet process phosphoric acid manufacture.  Raleigh NC,  86 p.
   in USEPA 1979a.
                                          CAKE WASHING
                                                     CAKE DEWATERtNG
                                                                     FEED SLURRY
                                                 CAKE DISLODGING
                                                 AND DISCHARGING
            Figure 16.
Operating cycle  of  rotary horizontal
tilting pan  filter.
Reprinted from Phosphoric Acid, Volume I, A.V.  Slack, Editor, by permission of
   Marcel Dekker,  Inc.,  Year of first publication 1968.

                                       48

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               Table 8.  Wet process phosphoric acid production.
Input Materials


     •  Phosphate rock (ground)
     •  Sulfuric acid

Utilities

     •  Steam (from sulfuric acid process)

        — for vacuum induction when vacuum flash coolers are used
        - in stream ejectors to clean noncondesibles in systems using flash
          coolers

     •  Cooling water
     •  Process water
     •  Electrical energy

Waste Streams

     •  Tail gas

        -  particulates of phosphate rock
        -  sulfur oxides and acid mists
           fluorides

     •  Gypsum solids
     •  Contaminated water (from cooling and scrubbers)

Product

     •  Phosphoric acid (26-32% P^)

        - this is an intermediate product
        - product is too weak for either sale or for econimic use in
          other phosphate fertilizer products
        - product is passed to next process for concentration


Note:  Fluorides and, to a minor extent, gypsum can also be treated as
       recoverable coproducts.  These products of pollution control systems
       are discussed in Section 3.0.

1.3.2.5  Phosphoric Acid Concentration


     The phosphoric  acid  produced  in  the sulfuric  acid  digestion process is

too  low in concentration  for sale or for processing of dry phosphate fertili-

zers.  Concentration of  the  26-32%  P~0  phosphoric  acid  is  accomplished by
                                      49

-------
vacuum  evaporation  of water  from the acid solution.   The  acid is circulated
through a  shell-and-tube heat  exchanger and  then  through a  series  of three
flash chambers under vacuum pressure conditions, each separated by a shell-and-
tube heat exchanger, as shown in Figure  17.  The flash chambers or evaporators
provide  comparatively large  liquid  surface  areas  where water vapor  can be
released with minimum phosphoric acid entrainment.

     Some of  the  phosphoric  acid along  with minor  acid impurities,  including
fluorides,  volatilize with  the water  vapor.   The  evolved  vapors pass  to a
barometric condenser, where they are condensed and, arlong with condensed steam
and process cooling water, flow to a hot well.  From the hot well the contami-
nated water is recycled back to the phosphoric acid reaction process, where it
is fed  into  the  barometric condenser used with  the acid flash cooler. Vapors
from the hot well are vented to the wet scrubber system.

     The above process describes a tube-type forced-circulation evaporator. It
is the prevailing method currently in use, largely because it tends to generate
fewer air  emissions than  other methods.  This is  so  because  practically all
the  vapors  are  condensed  (Slack  1968).   Operating conditions, however,  are
harsh.  The acid  stream  is very corrosive and  special  non metallic materials
must be used  for  construction.   Precipitation of solids  within the system is
also  a  chronic  problem that  has  been partically  solved but  still  prompts
continuous  research  and development  of equipment  and  process modifications.
Efficiency of the process  depends on composition of the feed and its level of
impurities, and on available utilities, such as cooling water and steam sources;
but  a  properly  designed  forced-circulation evaporator  can  recover over 99.5%
of the ?205 during concentration of acid from 30 to 54%.

     Industry and process  design engineers (Slack  1968) have noted that phos-
phoric  acid  concentration and  clarification  in most  operations are  now con-
sidered part of the  phosphoric acid process.   The utility streams are integrated
between and among the process units in most installations.  Waste streams are
generally  treated by the  same  equipment.   Common  scrubbers are used  for the
emissions, and wastewater contaminants are incorporated into the common contami-
nated water system.
                                      50

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                                                                          PROCESS WATER
        HEAT
      EXCHANGER
                  STEAM
                                    TO     TO FILTER
                                  GYPSUM  CAKE WASH
                                   POND
                                                            RECYCLED TO EVAPORATOR
                                                                 FEED TANK OR
                                                               TO GYPSUM POND
                                                                                                      STEAM
                                          EVAPORATORS ( THREE IN SERIES )
                                                                                                       VENT TO SCRUBBER

                                                                                                      TO BAROMETRIC
                                                                                                       CONDENSER IN
                                                                                                     REACTION SECTION
                                                                                                          VENT TO SCRUBBER
                                                                                                       STORAGE
                        Figure   17.  Concentration and clarification of  phosphoric  acid.


Source:   U.S.  Department of  Health,  Education and Welfare.   1970,  Atmospheric  emissions from wet-process
   phosphoric  acid manufacture.  Raleigh NC,  86 p. in USEPA  1979a.

-------
     The  requirements  for phosphoric acid concentration  and  clarification are
 tabulated  together  in  Section  1.3.2.6.

 1.3.2.6  Phosphoric Acid  Clarification

     This  process as  currently  practiced in  the  United  States is  often  con-
 sidered as a final stage to the  concentration process rather  than  full scale
 process.   Physical  treatment  of  the acid  is  used, rather than  more expensive
 solvent extraction methods as  used in Europe and Mexico.

     Impurities  in wet process  acid,  such  as iron  and  aluminum phosphates,
 soluble gypsum,  and fluosilicates  form supersaturated  solutions  in 54%  P^O
 phosphoric  acid,  and  will  precipitate during  storage.   These precipitates
 cause  problems  in unloading  tank cars and  further processing using  the acid.
 Recycled contaminated  water  is used to  cool  the  acid to optimum temperatures
 and  the acid  is  stored  in  a  detention  chamber  to  promote  precipitation of
 solids.   The precipitated  impurities   are then  separated  from the  acid by
 settling and/or  centrifuging  (see Figure  17).  The resulting sludge  is either
 sent to the gypsum pond,  processed into a low quality fertilizer, or recycled
 to  the evaporator  feed tank.   Recirculation  of  the  sludge adds precipitated
 solids  to  the  evaporator  feed, providing crystal surfaces in the acid.  Since
 salts  coming out  of  solution during  the evaporation  process will tend to
 deposit on  these  crystals rather  than  on evaporator  surfaces,  scaling is
 reduced.   The  clarified  acid  is  then  stored  at  ambient  temperatures  (USEPA
 1979a).

     The basic requirements for the integrated concentration  and clarification
 processes  of phosphoric acid are summarized in Table 9:

 1.3.2.7  Superphosphoric Acid Production

     Superphosphoric acid  is produced by further concentration  of the 54%  P-O.
phosphoric acid to 66% or  greater P^O^ equivalent.  Concentration is  either by
submerged  combustion or by  vacuum evaporation.  The  54%  P^Cv phosphoric  acid
feed,  from  the  wet  process,  is in the ortho form; that is, molecular composi-
tion is  H.PO,.   In the  concentration  process,   elevated  temperatures cause
molecular   dehydration  and molecules combine  into  polyphosphoric  acid  chains
                                    52

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  Table 9.   Concentration and  clarification of wet  process  phosphoric acid,


Input Materials


     •  Phosphoric acid (26-32% P^O^)

Utilities

     •  Steam (for vacuum condensers, heat exchangers, and flushing
        barometric condensers)
     •  Process water (for barometric condensers and acid cooling)
     •  Electrical energy (blowers, pumps, and scrubbers)

Waste Streams
     •  Contaminated water (from cooling and condensers)
     •  Emissions (fluorides and acid mist from hot well)
     •  Acid sludge

Product

     •  Concentrated phosphoric acid (54% P2^5^' use<^ f°r

        - salable product
        - production of triple superphosphate
        - production of ammonia phosphates
        - further concentration to superphosphoric acid
        - production of dry mixed and liquid blend fertilizers

     •  Acid sludge (potential coproduct for sale as low analysis fertilizer
        if not handled as a solid waste)
                                     53

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(USEPA  1979a).   For example,  tripolyphosphoric acid is formed by the following
reaction:

                    3H3P04 - H5P301Q + 2H20

Superphosphoric   acid  (SPA) is  a  mixture of  orthophosphoric acid  and poly-
phosphoric acid  molecules of differing  chain  lengths.   Wet  process  acid is
normally concentrated to 68.5  to 72% P^ by conventional processes.

     Major impurities in wet process phosphoric acid'are calcium, iron, alumi-
num, magnesium,  potassium,  sodium,  fluorine (HF, H2SiF6,  SiF^),  and sulfate.
These materials  precipitate at different  temperatures and acid concentrations,
but one overall  effect is great  potential for scaling and high viscosity.  The
concentration processes used commercially are designed to restrict scaling and
clogging problems.

Submerged Combustion

     This process takes advantage of an old maxim that "no scale can grow on a
bubble" and effects heat  transfer  primarily by bubbling  a  stream of hot com-
bustion gas  through the  phosphoric acid solution  (Slack   1968).   A study by
USEPA (USEPA 1974b) noted that this process is considered outmoded and unlikely
to be used in the future.  In addition, gaseous emissions are highly polluting
and difficult to control.  Currently, only two United States plants  (accounting
for  approximately   26%  of  SPA  production)  use  submerged  combustion  (USEPA
1979a).  The fact  that  submerged combustion also entails high energy consump-
tion  in  the  form  of  natural  gas,  make  it an unlikely  option for new source
facilties.

Vacuum Evaporation

     Seven plants  in  the  United States  (Section  1.5.1)  produce SPA by vacuum
evaporation;  four  use  the Stauffer falling film  evaporator and three use the
Swenson forced circulation evaporator.  The Stauffer process  and  the Swenson
process are shown in Figures 18 and 19.  The basic processes have been described
by Rawlings,  et  al. (USEPA 1979a):

-------
                                                                    WATER
    HICH
    PRESSURE
    STEAM
           FALLING FILM
           EVAPORATOR
            EVAPORATOR RECIRCULATION
             RECYCLE     PUMP
              TANK
                                        TO
                                       SEWER
      Figure 18.   Stauffer process for wet  process superphosphoric  acid.

Source:   Barber,  J.C.   1979.   Falling film evaporator  process.  Adapted from
   TVA file drawings.   Florence  AL.
                                                  TO AIR EJECTOR
                                                         COOLIN9 WATER
HOT WELL
/


»v
WATER OUT

UJ
'
~l


            DOWTHERM
             HEATER
SURGE
TANK
                                       F.C. EVAPORATOR
COOLINO
 TANK
 72%P205
ACIO STORAGE
       Figure 19.  Vacuum evaporation SPA concentration  processes.

Source:   Adapted from Rushton, W.E.   1966.   Swenson superphosphoric  acid
   process.   Phosphorus and Potassium No. 23,  June/July,  p.  13-16, 19.
                                        55

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     In the Stauffer process, clarified 54% P^O,. orthophosphoric acid  is  con-
tinously fed to the evaporator recycle tank where it mixes with superphosphoric
acid from the evaporator.  Some of the mixture (approximately  1.2%) is  drawn
off as product acid, but most (approximately 98.8%) is pumped  to the top  of
the evaporator and is distributed across the heat exchanger tube bundle.  The
falling acid, heated by high-pressure steam condensing on the  outside  of  the
tubes, evaporates.  The vapors and dehydrated acid then enter  the separator
section where entrained acid mist is removed.  Product acid flows to the
recycle tank, and the vapor is drawn off, condensed in a barometric condenser,
and delivered to a hot well.  Noncondensables are removed by a two-stage  steam
ejector and are vented to the hot well.  Superphosphoric acid  flows to  the
recycle tank where it is mixed with more 54% P?0c orthophosphoric acid, and
recycled or removed as product.   The approximate recycle to feed acid  ratio is
80:1.  The product stream is cooled and stored before shipping.  Both  the hot
well and cooling tank are vented to wet scrubbing systems.

     The Swenson process utilizes closed heat exchanger tubes  filled with heat
exchanger fluid to provide the heat of reaction.   Feed acid (54% P2°s) pumped
into the evaporating system mixes with recycled superphosphoric acid. As  the
acid leaves the exchanger tube bundle and enters  the flash chamber, evaporation
begins.  Vapors are removed by a barometric condenser.  Condensed materials
and noncondensed vapors are delivered to a hot well.  Product acid flows
toward the bottom of the flash chamber where part (approximately 0.6%) is
removed to a cooling tank and the rest (99.4%) is recycled.  An approximate
recycle to feed ratio is 150:1 (compared with 80:1 for the Stauffer process).

     Cooling in both systems is  accomplished by circulating water through
stainless steel tubes in the holding tank.
     72% PoO, is the maximum concentration practical for commercial production
(Dinauer 1971).  Any higher  concentrations  of wet process acid cause handling
problems including pump  failure,  valve and tubing breakdowns, and overheating

of  motors,  due to  the viscosity  of  the fluid.   The viscosity  problems  are

largely due  to  the  impurities  in wet  process  acid.  Higher concentrations and
many non fertlizer uses  of SPA therefore require  either  furnace acid deriva-
tion  or costly  extraction  of  wet process  impurities before concentration.


     SPA is used primarily in mixed liquid fertilizers, where it makes possible

higher analysis products.  The  polyphosphate molecules also sequester some of

the iron and magnesium impurities which attain their lowest solubility around

the 54% ?2®5 concentration level for wet process acid, and would cause handling
problems if  in  liquid  fertilizers.   Early anticipated marketing advantages of
SPA in  reducing shipping  costs  as compared with  less concentrated phosphoric
acid have not been realized due  to its handling problems.


     A summary inventory of the  process requirements follows:

                                     56

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                  Table 10.  Superphosphoric acid production.
Input Materials

     •  54% P~Cv phosphoric acid

Utilities

     •  Steam (from sulfuric acid process or auxiliary steam boiler)
     •  Electrical energy (pumps, circulators, blowers)
     •  Cooling water
     •  Natural gas (submerged combustion process)

Waste Streams

     •  Fluoride emissions
     •  Sulfur oxides
     •  Acid mist
     •  Combustion products (submerged combustion process)

Products

     •  Superphosphoric acid (68.5 to 72% P^O,.) ,  used primarily for production
        of liquid mixed fertilizers
     •  Fluorine in the form of CaF  or fluosilicic acid are recovered as
        coproducts at some installations


Note:  SPA production is normally included under existing effluent guidelines
for the phosphate fertilizer manufacturing subcategory.  Since SPA is produced
at such facilities and since it can utilize the common contaminated wastewater
system, there is no contradiction implied in the fact that the process is not
specifically identified in effluent guidelines.  It was not intended that the
process be excluded; it simply was not chosen to be addressed in the Develop-
ment Document for basic fertilizer chemicals (USEPA 1974a); By telephone. Dr.
Elwood Martin, USEPA, Effluent Guidelines Division, March 27, 1979).
                                     57

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 1.3.2.8  Triple Superphosphate Production

     Triple  superphosphate (TSP) is a  high  analysis phosphate  fertilizer  (46
 to  48.5% P?0  content).  TSP can be produced either  as  run  of  pile  (ROP)  or as
 granular  triple  superphosphate  (GTSP) .   ROP and  GTSP  can be manufactured  in
 batch  or  continuous process modes.  ROP triple  superphosphate can be  used in
 hot-mixed  fertilizers whereas GTSP is preferable for use  in dry  bulk  blends or
 for direct application.   ROP,  however, involves difficult  air pollution  prob-
 lems  due  to  dust  and can cause materials  handling problems  if shipment  is
 involved.   Most  new  plants are  expected  to  produce  the  granular   type TSP.

     Both  processes  utilize the same raw materials, ground phosphate rock  and
 approximately  54%   P^O,.  phosphoric acid.  The  basic chemical reaction  takes
 place  by the following reaction  (USEPA  1974a):
                                       3H20 — *  3Ca(H2P04)2 » H20

The  overall  reaction,  taking into account the fate of  fluorine  in  the  fluora-
patite ore is as follows  (USEPA 1971):
                                           ^)-»- lOCaH, (P04)2»H20 +  2HF

As  is  the  case  in normal  superphosphate,  the HF  reacts  with silica to  form
SiF  ,  which partially  hydrolyzes  to  form  fluosilicic acid  (H SiF,)  and  is
partially  evolved as  gas.  As  with  NSP,  SiF,  and H0SiF,  are  also evolved
                                                *f       2.   b
during  denning,  curing, and  storage operations.   The similarity   between  the
ROP  and  GTSP processes,  however,  does not  go  beyond the initial  acidulation
operation.

Run of Pile TSP Production

     The  ROP  process is  virtually identical  to  the  NSP  process   except  that
phosphoric  acid  is  used  instead  of  sulfuric  acid.   Figure 20 shows  a  flow
diagram of  the process.   Batch mode is  carried out in older plants, but  con-
tinuous process mode is assumed for process discussion.
                                      58

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    CLARIFIED OR CONTAMINATED WATER
 940 ~ 1040 l/kkg
(225 ~ 250 GAL/TON)
                                                                                       STREAM LEGEND

                                                                                      —— MAIN PROCESS
                                                                                      	GAS
                                                                                      	 MINOR PROCESS
    PHOSPHORIC ACID
    PHOSPHATE ROCK
                    I
                 c
     TON = SHORT TON
     kkg = METRIC TON
TO ATMOS.

   t
    I
    I
                                                                                  CONTAMINATED WATER
                                                        ROP ~ TSP TO CURING
                                                                                  (225 ~ 250 GAL/TON)
                                                                                  940- 1050 l/kkg
          Figure 20.  Triple superphosphate  (run of pile)  (flow rate per ton ROP).

Source:  Adapted from U.S. Environmental Protection Agency.  1974a.  Development document for effluent
   limitations guidelines and new source performance standards for the basic fertilizer chemicals segment
   of the fertilizer manufacturing point source category.  Office of Air and Water Programs, Washington DC.

-------
     Most facilities use the continuous cone mixer process  developed  by TVA in
the  1930's.   Finely ground  phosphate rock  and 54%  I^s  phosphoric acid  are
metered  into  the cone  mixer.   The acid enters  the  cone tangentially  at  high
velocity, setting up a swirling action that mixes the materials  within  seconds
(Dinauer  1971).   The  acidulate is discharged  quickly onto a long  rubber  con-
veyor belt.  On discharge, the slurry becomes plastic within  15  to  30 seconds.
The  material  is  conveyed  to  a  den  (or,  in  many  cases,  the  conveyor moves
through a  continuous  den)  where  large amounts  of  noxious gas are  evolved  and
vented  to scrubbers.   The  mass  hardens  during this  stage and  takes  on  the
vesicular honeycomb appearance  as described in NSP production.  At the end  of
the  conveyor,  the product  is  broken  up in a  rotary  mechanical cutter before
being  discharged  to the storage  area for  an additional 2  to 4 weeks  curing.
Product is  crushed  and  sized after the curing  period and processed  for ship-
ping or for on-site use in mix fertilizers (USEPA 1974a).

Granular TSP Production

     A number of  plants produce GTSP by utilization  of  crushed or ground ROP
material and treatment  with water and steam or with  38 to 40% P2°s Phosphoric
acid in rotating or agitating chambers (Dinauer 1971, USEPA 1971).  Those pro-
cesses do not produce  significant emissions because  the  major  portion of the
fluorides were evolved in the original ROP manufacture (USEPA  1974b),  but  the
product quality  is  not  as  good  as  with  one-step  granulation  process  (USEPA
1977c), described below.

     In  the  direct-slurry  process (see  Figure 21),  the  product  is a hard,
uniform,  pellitized granule  produced  in enclosed continuous process  equipment
which facilitates collection and  treatment of dust and fumes.  The phosphoric
acid used is 40%  p2(-)s'  ratner  than the 54%  used in ROP manufacture. The acid
and ground phosphate  rock  are  mixed  together  in  an agitating tank.  The lower
strength acid  maintains the resultant slurry as a fluid and allows the  chemical
reaction to proceed appreciably toward completion before solidification starts.
After  1-2  hours  mixing  the slurry is discharged onto  recycled undersize dry
GTSP.  This  takes  place in a  granulator chamber  - either  a  pug mill  or a
rotating drum.   Slurry-wetted GTSP granules then discharge into a rotary dryer
where  the  chemical  reaction is accelerated and  excess water  removed  by  the
dryer heat.  Dried  granules are  next sized on vibrating  screens.   Over-  and
                                    60

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                        STREAM LEGEND
                       i      MAIN PROCESS
                      	GAS
                      	 MINOR PROCESS
            CLARIFIED OR CONTAMINATED WATER
 660 ~ 750 l/kkg
(158 ~ 180 GAL/TON)
            PHOSPHATE ROCK
                                     f~
                                     I
           TON = SHORT TON
           kkg = METRIC  TON
                                                        r

3RANULATOR 1
I M
^
1
1
1
1
1
1
DRYER

-*>
DUST
RECOVERY





r
                                                               SIZING
                                                                                         CONTAMINATED
                                                                                            WATER
                                                                                         (5 ~ 10 GAL/TON)
                                                                                         21 ~ 40 l/kkg
                                                                                                GTSP OUT
                 Figure 21.  Granulated triple superphosphate (flow rate per ton GTSP).

Source:  Adapted from U.S. Environmental Protection Agency.  1974a.  Development document for effluent
   limitations guidelines and new source performance standards for the basic fertilizer chemicals segment
   of the fertilizer manufacturing point source category.  Office of Air and Water Programs, Washington DC.

-------
undersized granules are  separated  and used as recycle material.  Product size

granules are cooled and conveyed to storage or shipped directly (USEPA  1974a).

Most plants allow curing for one to five days in a sheltered storage building,

during which some fluorides evolve, before shipping (USEPA  1977c).


     In  another  popular  one-step  process  developed  by  TVA, finely  ground

phosphate  rock  and recycled  fines  are reacted with 54% phosphoric acid, but

steam is  also  introduced to accelerate the  reaction  and  ensure an even mois-

ture distribution in the mix (USEPA  1977c).


     A summary  of  the  operating requirements for  the  direct-slurry GTSP pro-

cess is given below:


             Table 11.   Granular triple superphosphate production.
Input Materials


     •  Pulverized phosphate rock
     •  Phosphoric acid (40% P20  equivalent)
Utilities
        Contaminated water (for scrubber)
        Steam for reactor or rotary drier (some processes use reaction
        heat for drying)
        Electrical energy
Waste Streams
        Emissions, off-gas from reaction and curing, containing fluorides
        and acid mist; particulates of phosphate rock
        Contaminated scrubber water
Products
     •  Triple superphosphate, granular or run of pile

        -  used in production of dry blended fertilizers
        -  used in production of fluid fertilizers

     •  Fluorine, in the form of CaF? or fluosilicic acid, are recovered
        as coproducts by some manufacturers
                                     62

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1.3.2.9  Ammonium Phosphate Production

     Monoammonium  phosphate  (MAP)  and  diammonium  phosphate  (DAP)  are basic
concentrated  fertilizer  materials  containing N  and  P,  used  in bulk blend
fertilizers  and  to  some  extent  for  direct application.   Ammonium  polyphos-
phates, conventionally  produced by reacting SPA  with  ammonia,  are considered
to be mixed fertilizers and currently are used primarily in fluid fertilizers.
Although not included in the phosphate subcategory,  APP processes and products
commonly  include  MAP  and DAP  production.   For  this  reason a  discussion of
APP's is included in this section.

Monoammonium Phosphate and Diammonium Phosphate Production

     Ammonium phosphate  fertilizers include  a variety of  formulations which
differ  in the  amounts of  nitrogen  and phosphorus  present.   In  the United
States the most important grades are:
                    MAP:           11-48-0
                                   13-52-0
                                   11-55-0*
                                   16-20-0
                    DAP:           16-48-0**
                                   18-46-0

     *15 to 25% P205 equivalent is APP (L.B. Nelson 1978 in TVA 1978a)
    **approximately 1/3 MAP and 2/3 DAP (Dinauer 1971)

     In  a  typical  ammonium phosphate  process  40% P-jOr  phosphoric  acid  is
partially reacted wtih  ammonia in a preneutralizer or reactor (see Figures 22
and 23).   The  resultant slurry is sprayed  or  dripped onto a  bed  of fine re-
cycled  solids  in  an ammoniator-granulator.   Additional ammonia  is  injected
under the bed to complete reaction and resulting granules are dried and screened,
with undersize material recycled to the ammoniator  (Slack 1968a).
                                      63

-------
          CLARIFIED OR CONTAMINATED WATER
5000 ~ 6500 l/kkg
(1200 ~ 1500 GAL/TON)
PHOSPHORIC ACID
|
4r
£ — 1
1
1
_*J
i
f

	 . —

V V
SCRUB
            NH,
            NH3
         VAPORIZER
                                    GRANULATOR
        TON = SHORT TON
        kkg = METRIC  TON
                                                         DUST
                                                       RECOVERY
                                          T r
                                          DRYER
                                               STREAM LEGEND
 MAIN PROCESS
 GAS
 MINOR PROCESS
                                                                                        TO ATMOS
                                                                                        .	I
                                                                                         CONTAMINATED
                                                                                            WATER
                                                                                        (0~ 72 GAL/TON)
                                                                                        0 ~ 300 l/kkg
                                 MAP TO STORAGE
                  Figure 22.   Monoammonium phosphate  plant  (flow rate per  ton MAP),

Source:  Adapted from U.S. Environmental Protection Agency.   1974a.  Development  document  for  effluent limi-
   tations guidelines and new source performance standards  for the basic  fertilizer  chemicals  segment  of the
   fertilizer manufacturing point source category.   Office  of Air  and Water  Programs,  Washington DC.

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  PHOSPHORIC ACID
                                                     *• GAS DISCHARGED
   AMMONIA
OTHER  MAT'LS
 (OPTIONAL)
AMMONIATOR
GRANULATOR
   Figure  23.  Flowsheet  for  production of diammonium phosphate (DAP).

  Source:   U.S  Environmental Protection Agency.  1971.  Inorganic fertilizer
     and phosphate  mining  industries,  Water pollution and control.  Prepared
     by Battelle Memorial  Institute.   Richland WA, 226 p.
                                       65

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     Basic reactions are as follows:

     H PO,     +      NH3   -»-    NH4H2P04     (USEPA 197Aa) or,
   (Phosphoric     (Ammonia)   (Monoammonium
        acid)                      Phosphate)

     HPO,     +      2NH,  -+• (NH.KHPO,   (USEPA 197 7c)
      34               J        4 z   4
                                   (Diammonium
                                      Phosphate)

A variation, to produce 16-20-0 MAP, utilizes sulfuric acid with the following
reaction, which occurs concurrently with the MAP reaction:
     (sulfuric                     (Ammonium
      acid)                         Sulfate)

The  resulting MAP-ammonium  sulfate  combination usually  also  contains  DAP.
Obviously, these reactions cross idealized product boundaries between straight
and  mixed fertilizers,  but   traditional  plant  organizations  include various
combinations of these  processes  in phosphate fertilizer complexes.  Chemistry
and  accurate  analyses  of  some  ammonium phosphates have been  studied only in
recent  years.   Also,  not  all MAP produced  is  granular;  MAP  crystal is also
produced  and  crushed for use in granulation processes  for mixed fertilizers.
In  MAP production only  one   preneutralizer  tank is  used,  as  opposed  to two
tanks which are used for DAP production.

     Variations in ammonium phosphate production include use of nitric instead
of  sulfuric  acid,  which  in  combination with  phosphoric  acid produces nitric
phosphate  or  ammonium  phosphate nitrate.   Another  process arrangement allows
the  neutralization  reaction   to  go  to completion in  a  series  of tanks before
the product slurry is fed to a "blunger," which  is a  paddle mixer where granu-
lation is completed with the addition of dried recycled fines,  (Dinauer 1971),
(USEPA  197 7b).  Another variation injects phosphoric acid directly  onto  a bed
of  recycled  product  fines  in  a rotary  drum  granulator  and  injects ammonia
under  the  bed  of  fines.   In  this  arrangement,  neutralization and granulation
                                     66

-------
occur in the same piece of equipment.  Heat of ammoniation evaporates water in

all  these  arrangements.   (USEPA  1977b).  In  general,  the  end  products  are

varied by the acids used and the N content is varied by the degree of ammonia-
tion (Dinauer 1971).


     Cyclone collectors and/or venturi scrubbers are used for dust and off-gas

recovery and recycle in most systems.  Wet scrubbers are used for end-of-process
emissions control, using contaminated water.  A summary of process requirements
is presented below  for ammonium phosphates production including MAP, DAP, and
ammonium sulfates and nitrates:


                   Table 12.  Ammonium phosphate production.
Input Materials

     •  Anhydrous ammonia
     0  Phosphoric acid (30-52% P-O,., depending on product)
     •  Sulfuric acid
     •  Nitric acid

Utilities

     •  Electrical energy for pumps, mills, fans, and blowers
     •  Fuel for drying - older processes  (most recent processes use
        heat of ammoniation for drying)

Waste Streams

     •  Contaminated wastewater for scrubbers (or incoming phosphoric acid
        can be used)
     •  Air emissions - off-gases

        -  ammonia
           fluorides
        -  phosphate rock particulates
        -  acid-ammonia mists
 Products

        Monoammonium phosphate
        Diammonium phosphate
        Ammonium phosphate nitrate and ammonium nitrate
        Ammonium sulfate
        Fluorides as CaF^ or fluosilicic acid are potential coproducts
                                     67

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Process Variations

     The basic MAP  and  DAP processes described  above  are in use in plants in
the United States,  but  recent innovations in technology are being implemented
at  numerous  locations,  sometimes  alongside  an  existing  conventional process
train, sometimes  in new installations.   In other  cases,  adaptations are made
to existing conventional equipment to incorporate recent technology.

     A wide range of process variations are in use.  Many of these are propri-
etary, patented, or protected by company secrecy classification.  Consequently,
details are  not readily available.  Furthermore,  manufacturers routinely in-
novate and operate  using  temporary process modifications for trial periods of
several days  to  several  months.   If  successful  these modifications  may  be
permanently  ins tallied.  For  these  reasons,  several  basic process  modifi-
cations are discussed below which are indicative of processes in use, although
operational details vary  from plant to plant.   Reference  is made to TVA pro-
cesses described  in pilot  plant operations.   Due to the cooperative relation-
ship, however,  between  manufacturers and TVA, these processes  are considered
indicative of commercial operations.

  Pipe Reactor

     One of the  most  significant process developments  for ammoniated granular
fertilizers is the  TVA  pipe reactor, developed in 1971 (Nelson in TVA 1978a).
The pipe reactor  is  a process modification in which the acid and ammonia are
reacted in the  delivery system and introduced under pressure  into the granu-
lation chamber  (a pug  mill or  a  drum type  granulator) as  an  atomized melt.
Figure 24  is  a detail of a standard pipe reactor arrangement.

     Figure 25 shows a pipe reactor system set up for a number of NPK formula-
tions. NP products are  produced by excluding the  potassium chloride and urea
feeds. A  preneutralizer is  used to blend part  of the ammonia with the acid
(NH«:H,PO,  mole ratio of  0.4).   This is done to prevent rapid scale formation
downstream in the pipe  reactor.  In TVA demonstrations,  and in some industry
applications,  the phosphoric  acid  feed to the preneutralizer is introduced at
a  metered  rate  to  the  scrubber  handling  the  ammoniator-granulator  exhaust
                                    68

-------
                    PARTIALLY\
                  NEUTRALIZED
                        ACID
   DRUM
GRANULATOR
    ' 6'
                                  ENLARGEMENT
                                         STEAM
                                          FOR
                                  PRESS  CLEANOUT
                                  GAGE
                      PARTIALLY
                     NEUTRALIZED -CX}-»
                        ACID
                                  DRAIN
                                 TO LIQUID
                                FERTILIZER
                        AMMONIA —OO
                                         STEAM
                                           FOR
                                        CLEANOUT
      Figure  24.   Details of pipe  reactor in drum  granulator.


Source:  Tennessee Valley Authority.   1974.  New developments in fertilizer
   technology,  10th demonstration,  October 1-2, 1974.   National Fertilizer
   Development  Center.  Muscle  Shoals AL, 72 p.
                                        69

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           STEAM
   PHOSPHORIC
      ACID
                                              PARTIALLY
                                             NEUTRALIZED
                                                ACID
  OZZ)
RECYCLE
 FEEDER
                               DRUM
                             GRANULATOR
                                 31  j-. i
                                 x 6
                                                                                             ONSIZE
                                                                                             PRODUCT
                                                                                             19-19-19
                                                                                             12-24-24
                                                                                             15-30-15
                                                                                                           \
                       Figure  25.   Flow diagram of granulation pilot plant using pipe
                            reactor process for NPK fertilizers.

Source:  Tennessee Valley  Authority.   1974.  New developments in fertilizer technology,  10th demonstration,
   October 1-2,  1974.   National Fertilizer Development Center.  Muscle Shoals AL,  72 p.

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gases. Phosphoric acid  is more effective than water for ammonia scrubbing and
this arrangement  also precludes  introducing unwanted  water  into  the process
while  recycling  costly  ammonia.   The  partially  neutralized acid  is blended
with  additional  ammonia  to  achieve  an  NH0:H^PO.  mole  ratio of  about  1,05
                                            334
(Hicks   1977).  This produces  a melt  (instead  of the  slurry in conventional
processes) which is  nearly anhydrous.  Melt temperature is  usually about 430
to 440 F  (206-212  C) (TVA   1974).  The melt is sprayed from the pipe reactor
onto recycled fines,  which they readily  agglomerate.   The  drying  takes place
in a  cooling chamber  utilizing the  heat of the melt  to  complete  drying and
solidification (conventional processes require natural gas heaters).

     The  TVA pipe   reactor has  largely  replaced  the  tank  reactor process
(Nelson  in TVA  1978a)  and is  currently among  the more  attractive systems
available because emission  problems are largely eliminated at the source.  The
method of  mixing and  reaction retards evolution of  particulates  and produce
strong granules  which.generate fewer immediate dust  problems and  retard dust
emissions  in  later  handling also.   The potential energy savings due  to elimi-
nation of  the  need for  a fuel-fired  dryer  has  been  a  major factor  in the
interest in pipe reactor systems.

     The pipe reactor  process is undergoing continuous development by TVA and
improvements have been  made both by TVA and by the industry.  A discussion of
these modifications and their advantages follows.   The first major  improvement
had to do with the preneutralizer tanks.

     Conventional processes generally  all  use  preneutralizer  tanks, as does
the original TVA pipe  cross reactor  process.   For  more than 17 years MAP and
DAP  processes  have  employed  them.   These  tanks  are usually  constructed  of
stainless  steel  or of  mild steel  with a lining  of acid brick.   A plant may
have  either  a single preneutralizer  tank or several tanks  in  series,  but  in
either case, the moisture content  of the  slurry  can  be pumped with  a conven-
tional centrifugal pump and uniformly distributed in a granulator.   Because of
this high moisture content, the granulator product must be dried.  The following
operating problems have been reported by companies that produce MAP and DAP in
processes using preneutralizer tanks:
                                      71

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     1.   Difficulty  in  pumping  and  metering  the hot  slurry  from the  pre-
         neutralizer.

     2.  Foaming and boiling over of the slurry in the preneutralizer.

     3.   Difficulty  in  controlling the slurry  level in  the preneutralizer.

     4.   Plugging  of  the  ammonia  sparger  and  poor ammonia distribution in
         the preneutralizer.

     5.   Scarcity  and  high  price of  fuel  needed  for  drying  the product.
         (Parker et al.  1977).

     The original pipe  reactor put  into operation by TVA in December 1973 did
use the preneutralizer  but  the heat generated in the reaction tube was effec-
tive in evaporating much of the water and produced a slurry or melt much lower
in moisture than those in conventional preneutralizer processes.  This process,
which  also  employed  a pugmill,  is  shown in Figure 26.   The nearly anhydrous
melt produced  contains  15  to  30%  polyphosphate.   Also,  in  this process the
pipe-reactor melt  enters  a vapor  disengager  (see  Figure  27)  where helical
rotary blades spread  the melt to facilitate removal of water vapor  (steam) and
free ammonia and thus  compact and defoam the melt.  The melt flows by gravity
down a short  heated chute  from the  disengager  to  a  double-shaft pugmill.

     Recycle is  fed  to  the pugmill,  and composite scrubbing liquor from the
dust-recovery system  (about  40-50%  concentration) is added after being heated
in a steam-jacketed vessel containing internal steam coils.  Fertilizer mixing
plants  have  adopted  this  process  for use  in mixed  formulations.  An 11-55-0
grade APP can be produced using this process and the addition of  highly concen-
trated   (98.5%  or  greater)  urea  solution in essentially  equal proportions to
the APP melt permits  production of  28-28-0  grade, generally considered a mix
fertilizer.  Increasing  the proportion of urea permits production of a 35-17-0
grade.   Although moisture  content  of  material in  the pugmill is increased by
the return of  scrubbing  liquor,  only cooling is  required  to produce granules
of good quality.   The polyphosphate content of  these products ranges from 15
to 35%, and  the  moisture  content is usually 1% or less.   A diatomaceous earth
                                    72

-------
                                                                    STEAM AND
                                                                  NONCONDENSABLES
                                                                         34% WP.
                                                                          HiPO*
 PREEVAPORATOR
 75% UREA
 SOLUTION
37% HCHO
 SOLUTION
                             TO
                        •* SCRUBBER
                          CONDENSER
       97-99% UREA
        SOLUTION
                   PUG MILL
                 6RANULATOR
PRODUCT TO
 STORAGE
 28-E8-0
 35- 17-0
 II -56-0
                                                                                RUSHER
               Figure 26.  Pipe-reactor/pugmill  process.

 Source:   Parker, B.C., M.M.  Norton, and D.G. Salladay.  1977.  Developments
    in production of granular NP and NPK fertilizers using the pipe  and pipe-
    cross  reactor.  Paper presented at FAI-IFDC Seminar.  New Delhi,  India, 48 p
                                         73

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           GAS
         TO SPRAY
         REACTOR
TANGENTIAL
   ENTRY
           ACID INLET ,
          2-INCH PIPE
                                                      MELT TO
                                                    .GRANULATOR
                                PIPE
                              REACTOR
                              6-INCH PIPE
                              APPROX.IOFT. LONG
                                AMMONIA INLET
                                 3-INCH PIPE
                               WELDED THRU FLANGE
        Figure  27.  Pipe  reactor and vapor disengager.

Source:  Parker, B.C.,  M.M. Norton, and D.G.  Salladay.   1977-  Developments
   in production of granular NP and NPK fertilizers using the pipe and pipe-
   cross reactor.  Paper presented at FAI-IFDC Seminar.  New Delhi,  India, 48 p,
                                   74

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or kaolin clay  conditioner is needed for the 35-17-0 grade product (Parker et
al  1977).   Use  of this  system,  which  does  not  require  a rotary  dryer and
related equipment  has  substantially reduced both  capital  and  operating cost,
thus  accelerating  its  acceptance  in  both  straight and  mixed manufacturing
facilities.

     In 1974 TVA demonstrated the use of a drum granulator in a melt-type pipe
reactor process (TVA 1974).  This process has been widely accepted, especially
since it eliminates the need for dryers in plants already equipped with conven-
tional TVA  ammoniator-granulators.   Good granulation can  be obtained without
the  mixing  action of a pugmill  by  discharging the  melt directly  into a drum
granulator  through a  perforated pipe  (see  Figure  25)  rather than  a single
orifice.  The melt is  atomized by the steam that expands through the holes in
the pipe.  In this process the size and number of holes are adjusted so that a
pressure of  10  to  15 psig is  maintained.   Obviously,  the presence of a small
amount of  water in  the melt  is  now turned to  beneficial  use, atomizing the
melt.  In addition, the rotary vapor disengager is eliminated.  Several NP and
NPK  formulations and MAP  have been produced with  this  process, which is less
expensive to  operate  and  somewhat more energy efficient than the pugmill pipe
reactor  process  because the  rotary drum requires   less horsepower  to drive.

     Figure  28  is a flowsheet  of  a modified  version of  the pipe-reactor/
drum-granulator process in which a preneutralizer is not  used.  This simpli-
fies  the process  considerably  because  a  major  piece  of  equipment  and its
related piping,  transfer  and metering equipment, and scrubbing system are not
needed.   11-55-0 MAP (5%  polyphosphate) produced  using  this process compares
favorably with that of the process using a preneutralizer.  With this process,
both  investment and  operating  cost  are significantly  lower  because  of the
equipment eliminated.

Pipe-Cross Reactor

     In 1974, TVA  in cooperation with the Missouri Farmers Association developed
a modification of  the pipe reactor in which a pipe cross instead of a pipe tee
is used to allow for the introduction of a second acid (sulfuric acid usually)
in addition to phosphoric acid and ammonia.  This reactor, called a pipe-cross
                                     75

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             ATMOSPHERE
                    RECIRCULATED
                        ACID
                    |i I SCRUBBER
                    J"   2'xlO1
PHOSPHORC
   ACID
                                      ACID
                                   PREHEATER
                                    (OPTIONAL)
                                       DRUM
                                    GRANULATDR
                                       3' x6'
                                DRYER
                                 3'x24'
                             (USED AS COOLER)
                                                                                         ONSIZE
                                                                                        PRODUCT
          Figure 28.  Pipe-reactor/drum-granulator  process without a preneutralizer.


Source:   Parker, B.C..-M.M. Norton, and D.G. Salladay.   1977.  Developments in production of  granular NP
   and NPK fertilizers using the pipe and pipecross reactor.  Paper presented at FAI-IFDC Seminar.   New
   Delhi, India, 48  p.

-------
reactor (Figure 29) has proved very successful in the production of NP and NPK
grades of granular fertilizers that require little or no drying.  Although NPK
formulations have  been predominant,  MAP has  also  been produced commercially.
The  preneutralizer is  also eliminated  when  the  pipe  cross reactor  is  used
(Achorn and Kimbrough in TVA 1978a).   Grades such as 12-48-0, 12-12-12, 6-24-24,
8-22-11, 10-40-10, 20-10-10, 17-17-17, 33-11-0, and 18-46-0 have been produced
either  in  commercial  plants  or  in  TVA's  pilot  plant.    Several  pipe-cross
reactors are  in commercial  operation,  and others  are planned.   TVA is  con-
tinuing  pilot-plant  studies of  the  process  to  further refine  variables  and
operating conditions  for  various  grades (L. B.  Nelson  in  TVA I978a).  Figure
30  shows  a typical  ammoniation-granulation plant  in  which MAP,  NP,  and  NPK
formulations can all be produced.

     In addition  to  the advantages already described for a pipe reactor with-
out  preneutralizer the pipe cross reactor  offers  additional benefits (Parker
et al. 1977):

     1.  Larger amounts of  acid,  both  phosphoric  and sulfuric,  can be  used
         in formulations.

     2.  There is  less formation of troublesome ammonium chloride fume
         which is difficult to scrub  from exhaust gases.

     3.  Moisture  content of  the  slurry or melt produced  is  lower and  there
         is a more favorable moisture balance in the process.

     4.  Granular MAP,  which is  an excellent  product  for blending, can  be
         produced more conveniently;  a wider range of grades can be
         blended  with  MAP  (12-48-0  or  11-55-0)  than with DAP  (18-46-0).

Non-TVA Commercial Processes
     A number  of  other processes for production  of  ammonium phosphate are in
use  in  the United  States.   The Fisons  process and  the  Swift  process utilize
mixing nozzles and the Gardinier process utilizes an all-in-one reactor-tnixer-
spray nozzle.  These processes spray the resulting melt or slurry into the top
                                    77

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         ATMOSPHERE
  RECIRCULATED
      AGIO
                    SCRUBBER
                     2'xlO"

                    EXHAUST
                        iS
GA?
    PHOSPHORIC
      ACID
   ACID
PREHEATER
(OPTIONAL)
                                     STEAM  UREA
                                            MELT
                                                   PE-
                                                 CROSS
                                                REACTOR
                                              PHOSPHORIC ACID!
                                            "-AMMONIA
                                    DRUM
                                GRANULATOR
                                    3'x6'
                                                            PHOSPHORIC
                                                               ACID
                                         AMMONIA
                                        -  AND
                                          WATER
                                  SULFURIC
                                    ACID
                                     DRYER
                                      3' > 24'
                                  (USED AS COOLER)
                                                             RECYCLE FINES
                                                                                                    %
                                                                     L-*-ONSIZE
                                                                       PRODUCT
                 Figure 29.  Pipe-cross reactor/drum-granulator process.

Source:   Parker,  B.C.,  M.M. Norton, and D.G. Salladay.  1977.   Developments in production of granular NP
   and NPK fertilizers  using  the pipe and pipecross reactor.   Paper  presented at FAI-IFDC Seminar.  New
   Delhi, India,  48 p.

-------
                                                                                        mcmeuumm
                                                                     SCREENS
*
3»
1

• —

v/
3U»r
•"— 1
1-
r
•4
j
                          Figure  30.   Typical anunoniation-granulation plant using
                               the  pipe-cross reactor.
                         J30DUCT
                         L-» PRODUCT
                          TYPICAL GRftOES
                           10-20-20
                           6-24-24
                           8- 16- 16
                           12- 12- 12
                           8- 24-24
                           16-8-8
                           12-48-0
                           8-22-11
                           10-40-10
                           tO* 10- 10
                           17-17- 17
                           1J- II - 0
                           18-48- 0
Source:   Parker, B.C.,  M.M. Norton,  and D.G. Salladay.  1977.
   and NPK fertilizers  using the  pipe and pipe-cross reactor.
   Delhi,  India, 48  p.
Developments in production of granular NP
Paper presented at FAI-IFDC Seminar,  New

-------
of a  reaction tower  where  the  droplets  solidfy before  reaching the  bottom,
with moisture contents of 2 to 6%.  The ammonium phosphate produced is  generally
in a  powdered or nonuniform  semigranular form.  In  1973  there were 15  Fison
plants  in  operation or  under construction.   The  Swift process  was put  into
operation in at least one plant in about  1975.  Three Gardinier process plants
were  in operation  or being  developed  between 1972  and  1974  (Hicks 1977).

     Although  processes  that  produce  granular product are  advantageous and
expected in  new  installations,  the above three processes are included  in  this
discussion because it is not uncommon for manufacturers to modify or add  on to
existing hardware to  improve  existing capital equipment or expand production.
In such cases NSPS may have to be met.

Discussion—Ammonium Polyphosphate Production

     Production of high  polyphosphate fertilizers  such as APP is usually  done
at mixing plants  because it is more  economical  to  ship and more practical to
store the SPA and ammonia feedstocks than the APP and because formulations can
be varied using the feedstocks directly.  Some phosphate fertilizer complexes,
however, also produce APP's in order to sequester magnesium and iron impurities
in their  wet process acid  and  thus avoid sludge problems.   In addition, MAP
and DAP processes discussed above produce ammonium phosphate products in which
the molecular structure may also contain APP's as polyphosphate chains, depending
on conditions of reaction.

     Conventional methods for production of APP's are also in use, especially
in older  mixing plants.   In  a  typical  process for solid  APP,  thermal SPA is
ammoniated  in a  water-cooled reactor  at elevated  pressure  and temperature.
This  produces  an anhydrous melt that  is granulated by  mixing with recycled
fines  in  a  pugmill to  produce  27-34-0.   The product contains  nearly  equal
amounts of  ortho- and polyphosphate  (Dinauer  1971).   An alternative  process
uses orthophosphoric acid  directly.   The acid  is preheated  and ammoniated in
two  stages.  Conditions  are controlled  so  that heat  of  reaction is  used to
cause the molecular dehydration required  to form polyphosphate molecules.  The
resulting melt is  then  granulated by mixing  it  with  cooled recycled material
in a pugmill  (Dinauer 1971).
                                     80

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     A TVA  process  produces 15-62-0 grade  APP  from thermal SPA.  The acid  is
neutralized  in  a cooled, pressurized  reactor  with anhydrous gaseous ammonia,,
The melt  is granulated in  a pugmill,  cooled, and  screened.  Dust  is  collected
by  wet scrubbers and  scrubber  liquor is  recycled  into the acid feed.  The
product contains 75-80% of  the P content  as  polyphosphate (Lee  and Waggoner
1975). Such high concentrations are needed  in some  liquid fertilizers produced
from  the  material  in  order to  prevent precipitation  of  magnesium  compounds
(TVA  1974). This  process  produces  granular product,  but  adding water in a
final  step  produces a liquid for  use  as a base for liquid blend  fertilizers.

     Liquid APP  is  being produced  in a large number of  United States  commercial
plants by use of a  TVA-developed pipe  reactor which utilizes wet process super-
phosphoric  acid  (TVA  1974).   In  the  past  it  has been difficult to produce
satisfactory  10-34-0  and 11-37-0  liquid  fertilizers from wet process SPA in a
conventional  tank  reactor because the  polyphosphate contents of  the acid and
products  were less than desired.  Because of  impurities,  wet  process  super-
phosphoric  acid  normally  is  too  viscous  to handle satisfactorily when it  is
concentrated  to  a  range that provides much more than 50% of the P2°5 as P°ly~
phosphate.  Liquids such as 11-37-0 require at  least 65%, and 10-34-0 at least
50%,  of  their   P90r  as polyphosphates  to prevent precipitation  of ammonium
phosphate for  extended periods  of storage  at  standard  80 F (27 C) or 32 F  (0
C)  temperatures.  Still higher polyphosphate content of  75% to 80% is required
to  avoid  precipitation  of magnesium compounds.   The pipe reactor process
permits production  of  liquids containing  much more  polyphosphate than had been
possible  previously by conventional  methods using wet  process acid.  An addi-
tional  advantage of this process  is that  feed  acid containing only 15%  to 30%
of  the P^O,. as polyphosphate can be used.   This acid is  cheaper to produce and
can be stored and handled more easily  than  acid containing about 50%  polyphos-
phate, which was needed with prior technology,.

     In the TVA process,  liquids containing  from 70%  to  80%  of  the P20<.  in
polyphosphate form are produced from low-polyphosphate  (15% to 30%) wet  process
superphosphoric  feed acid.  Also,  either  furnace or mixed superphosphoric acid
(a mixture of electric-furnace superphosphoric  acid and  wet process orthophos-
phoric  acid)  can be  successfully ammoniated  simultaneously  with wet process
orthophosphoric  acid  to produce  11-37-0 of high-polyphosphate content.  The
                                       81

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high-polyphosphate process consists of reacting the acid with anhydrous gaseous
ammonia in a simple pipe reactor.  The heat of reaction results in temperatures
of about  600°  to  750° F and  converts  a  large part of the orthophosphate con-
tained in the  feed acid to polyphosphates.   The  reaction product made at the
high temperature  is  an anhydrous melt of  about  10-62-0  grade with  70% to 80%
of the P70r as polyphosphates.  As shown in Figure 31, this melt is  discharged
continuously  into  the  liquid  fertilizer vessel  where water and supplemental
ammonia are added.   The pH of the fluid is  maintained at about 6 as the melt
is dissolved.  The  fluid  in the reaction  vessel  is  maintained at about 150 F
(66  C)  by  recirculation  through  a water-cooled heat exchanger  (TVA 1974).

     Ammonium phosphates have  been the  leading phosphate fertilizers produced
in  the  United  States  since  1968.  The process  equipment  for  ammoniation-
granulation usually  has  the capacity,  or is  easily  modified,  to include pro-
duction of numerous NPK formulations.  These process modifications are readily
effected by adding  in feed systems for granular or fine particulate potassium
solid fertilizers  or for nitrogen solids, such as granular urea.  Sulfates are
produced by adding in a sulfuric acid feedstream in the reaction system, often
to  take  advantage of  operating  improvements it  offers,  such  as  reduction in
scaling which occurs with phosphoric acid alone, or to increase polyphosphates
content.  APP's can be produced in the same process trains and most  NPK products
contain phosphorus in both orthophosphate and polyphosphate forms.  Manufacturers
appreciate the flexibility in NPK processes because they can change  the product
they are  manufacturing in response to market demands, feedstock availability
and profitibility, and to solve operational problems such as scaling or trouble-
some emissions.   As discussed  in  Section  1.1,  operations performed  at  such
plants  place  them  concurrently  or  at  different periods  in  both  phosphate
fertilizer and  mixed  fertilizer  subcateogries.   For  the  most  part  APP's are
produced at mixing plants, but the similarity in process equipment and formula-
tions,   and  the inclusion  of  some  APP-rich formulations  in  MAP   production
categories have tended to invalidate conventional categories.
                                     82

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                   WATER -

                 GASEOUS
                 AMMONIA'
                                  r r i'
                           GASEOUS
                          ' AMMONIA
                                                    FEED ACID (10-35 %)
                                                   " POLYPHOSPHATE
                   COOLER
        COOLING
         WATER
           IN
 COOLING
• WATER
  OUT
                                                                COOLING
                                                                 WATER
                                                                    IN
                                          COOLING
                                           WATER
                                            OUT
                       PRODUCT (11-37-0)
                         TO STORAGE
            Figure  31.   Plant pipe reactor system  for production of
                 high-polyphosphate liquid fertilizer.


Source:  Tennessee Valley  Authority.   1974.  New developments in fertilizer
   technology, 10th demonstration, October 1-2, 1974.   National Fertilizer
   Development Center.   Muscle Shoals AL, 72 p.
                                     83

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 1.3.3   Auxiliary  Support  Systems

      1.3.3.1  Raw Materials  Transportation

         Phosphate Rock

     Phosphate  fertilizer facilities  generally receive ground  phosphate rock
 concentrate by  enclosed  systems.   Pneumatic  systems  are  used for dry material
 (USEPA  1978d)  and pipelines for  slurries.   Outdoor storage piles  are  built
 over systems of vertical  feed pipes and horizontal  conduits  enclosing conveyors,
 so  that feeding into the  plant  is  done by  gravity from  within the storage pile
 and  then  moved in  enclosed conduits.   Other plants are  delivered  phosphate
 rock by railroad  hopper car.  If ground rock  is delivered, covered hopper cars
 are  used.   Unloading  is  done in enclosed  transfer  areas, and enclosed  eleva-
 tors move the rock to storage silos. Exhaust  systems  in the  transfer  areas and
 storage silos are passed  through  baghouses to recover  particulates.   When wet
 grinding  is to be  employed  at the  fertilizer facility,  rock can be shipped
 unground and stored uncovered.

         Sulfur

     The prevailing  U.S.  pattern  is  to  mine, ship,  and  store sulfur in  "all
 liquid" systems.   This  approach makes  sense because of  the volume  of  sulfur
 used  in the  United  States  (world's  largest  consumer) and  is  made  feasible
 because the  Frasch process  is  used to  mine the sulfur.   The Frasch process
 takes advantage of very pure massive deposits of sulfur in salt dome  structures
 and in  other structures along the  Gulf Coast in Louisiana, Texas, and Mexico.
 In  the  Frasch  process heated  water and  steam are injected into sulfur  beds
 through jacketed  concentric  pipe casings,  and sulfur melted by the process is
 withdrawn  through an annular  space  in  the  casing.   The  Frasch process is
energy intensive but  viable,  largely because of the advantages of  transporting
and handling sulfur in molten form in controlling air pollution and  lessening
equipment  corrosion.   Most uses require  that sulfur  feedstocks  be melted  for
processing,  so  there  is  a  partial payback of energy consumption at that stage.
                                    84

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     The conversion  to  liquid  handling systems in  the  United  States began in
the early 1960's (Carrington 1962).  Consequently, multi-million dollar liquid
sulfur  transportation  and handling networks are  now  well established.  Phos-
phate fertilizer  facilities receive  Frasch sulfur by  road  and  rail tankers,
pipelines, bargelines,  and ocean-going tankers.  Transportation facilities and
all pumps and  tank terminals are equipped with insultation and heating equip-
ment to  maintain  the sulfur at temperatures between 240 and 320 F (116-160 C)
(Anonymous 1970).

         Ammonia

     Phosphate manufacturing utilizes ammonia for production of ammonium phos-
phates.   Plants that do not produce ammonium phosphates would not use ammonia
in  significant  quantities (58.45% of the  phosphate straight fertilizers  pro-
duced from wet process  phosphoric acid are ammonium phosphates (USEPA 1974d)).

     Ammonium  phosphates are  produced  either  at facilities near  sources  of
phosphate rock  or at  facilities  that  produce  ammonia or  are  nearby ammonia
sources.  Those facilities that produce ammonia require good sources of natural
gas, and  ammonia  product is transported by in-plant pipelines and inventories
stored  at  low  temperatures  (as low  as  -50 F  or -46  C)  in cryogenic tanks.
Facilities  which  purchase   ammonia  receive  shipments  of  compressed  liquid
anhydrous  ammonia or  aqua  ammonia  by  barge  or  road  or  rail  tanker (USEPA
1976b).    Throughout  the Midwest anhydrous  ammonia  is  available  (primarily  to
mixing  plants)  by  pipeline  networks.  Ammonia storage  tanks may be cryogenic.
Modern ammonia terminal systems are also designed to deliver ammonia to pressure
tanks at ambient temperatures.

     1.3.3.2  Product Handling, Storage, and Transportation

     Granular and  ground solid  products are handled,  stored,  and loaded for
shipment using  some  of  the same systems or similar systems used for phosphate
rock  (1.3.3.1).    Loading  is  done  by  covered conveyors  or from  hoppers  to
barges,   rail hopper  cars,  or trucks for  shipment.   Loading areas are usually
enclosed  or  equipment   and  receiving  vehicles  are  hooded during  transfer.
Materials that are handled using dry transfer facilities  are product phosphate
                                     85

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rock,  NSP,  TSP,  and ammonium phosphates.   Hopper  cars are open,  however,  and
can  lose some dry  products as  particulates  to the  air  or by spillover  from
overloaded hoppers.

     Phosphoric  acid and  SPA require  special  materials  for construction of
storage  tanks,  pumps, and  pipe-work that  are  strong, flexible,  resistant to
strong acids,  and  able  to withstand  temperature  extremes.  Details of  selec-
tion  of   proper  materials  for  process  equipment  or handling,  storage,   and
transportation equipment is not a subject of this document.   Spill and  leakage
prevention  can be  enhanced,  however,  by  use  of  suitable materials  such as
certain  stainless steel alloys, plastics, rubber, and fiberglass.

     Phosphoric  acid is  delivered  to  tanks  and  transport  vehicles  through
pipes  and hoses made  of  the above materials.   Phosphoric acid storage tanks
may be flat-bottom or cone-bottom, and are  usually constructed of  a mild steel
shell  with  rubber  lining.   When flat-bottom tanks are  used, good design  for
leakage control includes construction of tanks on a concrete  foundation elevated
to keep  the shell from coming in contact with any spilled  acid.  The foundation
should have  grooves  (drain  spokes) in its  upper  surface radiating toward  the
edges; this  transmits  any  leaking acid from the  tank base out from under  the
tank to  minimize corrosion  and allow easier detection (Barber 1975a).  Cone-
bottom tanks  are  used  to facilitate removal of settled solids.  Since  removal
pipes are at  the  bottom of cone-bottom tanks,  the  tanks are usually elevated
on a  supporting  frame  (Balay  and Kimbrough  1978).   Smaller  tanks, for  inter-
mediate  storage, are  frequently  of the horizontal cylindrical type; these  are
supported on  concrete buttresses.  All storage tanks  are  ideally surrounded by
a  diked-in  area  large  enough  to  contain  the contents  of  the  largest tank
(Barber  1975a).

     Phosphoric acid  is transported  by rail or  road tankers  (USEPA  1978b).
Superphosphoric acid  from wet  process acid presents  special handling problems
due to  its  high viscosity.   This  characteristic  can be largely  overcome by
loading  the  acid  at  elevated temperatures in especially designed insulated
tank, cars known  as  "hot dog" cars.   A  stainless  steel shell is surrounded by
six inches  of polyurethane  foam and an  outer carbon steel  shell.  Internal
pipe coils are  located  around the bottom of the inner shell  so that steam  and

                                    86

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hot water can be piped in to keep the SPA between 150 and 200 F (52-75 C). The
storage  tank and  lines  to the  transfer area are  also insulated  (Balay  and
Achorn 1971).

     1.3.3.3 Intake Water Treatment

     The  only  process which  requires water  treatment  is the  boiler make-up
water  for the sulfuric  acid  process.  Impurities which would  scale  and foul
boilers  are  removed  by  hot lime-zeolite  treatment.   Raw water  is heated by
steam in this lime softening process and filtration is through zeolite filters
and a final anthracite (coal) filter.  Impurities are collected in the softener
tank and  released  by sludge blowoff  (USEPA  1974a,  Drew Chemical Corp.  1977).

     1.3.3.4  Uranium Recovery

     There is a small amount of uranium in phosphate rock, and it is dissolved
as part  of  the  32% acid in the  wet-process  system.   In the 1950's there were
three  plants  where solvent extraction units  were  operated  commercially.  All
were plagued with operating difficulties, both in the uranium plant and  in its
effect on the phosphoric acid plant.  None was economically successful and all
were shut  down  in  favor of more  conventional methods  of  uranium processing
(USEPA 1976b).

     Currently  there is  a revival  of  interest  in  extraction of  uranium as
uranium oxide (yellow cake)  because improvements have been made in extraction
techniques and because  the price of  yellow  cake  has increased from $8  to $43
per  pound since  the early  1970's.   Several  plants  in central  Florida have
experimentally recovered uranium from phosphoric acid, and commercial recovery
is nearing reality.  The most likely processes to be used involve liquid-liquid
solvent extraction processes.   Uranium Recovery Corporation (URC) in 1974-1975
installed a uranium  recovery  module consisting of two units, one at the phos-
phoric acid plant  of  W.  R. Grace & Company near Bartow and the other at URC's
central processing plant near Mulberry.   The acid-plant unit has been involved
in initial  extraction and  stripping, while  the  central-plant unit  has been
involved  in  final  production  of  yellow cake  (Engineering  and Mining Journal
1975).   International Minerals  and  Chemical Corporation (IMC) is developing  a
                                    87

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uranium recovery facility  at  its New Wales plant.  The operation will  utilize
a two-cycle solvent  extraction process using di(2-ethylhexyl) phosphoric  acid
plus trioctylphosphine oxide  in kerosene (Interview, J. Allen, IMC,  16 August
1979).

     The U.S. Energy  Research and Development Administration  (ERDA)  estimated
that more  than  900  metric (1,000 short)  tons of uranium  oxide  would be ex-
tracted in  the  study area by  1978;  this  would represent approximately 8  % of
the  total  U.  S.  production  for 1975  (USERDA 1976).  Recent estimates  from
central Florida place uranium production at nearly 1500 short tons,  about 10%
of U. S. demand.  Four chemical companies are currently involved in or  setting
up  facilities for uranium extraction in Florida.  This spin-off industry  from
the phosphate industry has been operated quasi-independently in several cases,
as  cooperative  ventures   between the  phosphate company  and  the  extracting
company.  At least one phosphate processing company has now begun operation of
uranium extraction in their  own facilities, and other phosphate complexes are
expected to follow.

1.4  SIGNIFICANT ENVIRONMENTAL PROBLEMS

     The discussion  in  this  section is a brief  summary of the major environ-
mental  considerations  associated  with  phosphate   fertilizer  manufacturing
facilities.  More comprehensive  treatment  of industry impacts is developed in
Chapters 2.0 through 6.0.   Problems inherent with specified factors and materials
are  discussed  even  though environmental  effects  may normally  be  mitigated
through process and  control  techniques.  The  intent  is  to  identify  potential
significant problems  which, as a minimum, new source EID's would be expected
to address.

1.4.1  Raw Materials

       Phosphate rock.  Beneficiated  rock  has generated serious environmental
problems in poorly controlled facilities.   Dust can  be a significant air  con-
tamination  problem  at  each   point  of  transfer  of  the  materials  and  in the
grinding process when dry grinding is  used.   A  typical milling operation for
rock grinding  associated   with a mining  operation  has the  potential  to  con-

                                     88

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tribute 7 grams  of  particulate per dry standard cubic meter of exhaust before
emission control (USEPA 1978d).  Mass emission rates for rock transfer systems
were not  sampled in  the  1978 USEPA study,  but  visible  emission measurements
have shown that these systems can be operated with no visible exhaust.

        Sulfur and Ammonia.   These  raw materials  and  their reaction products
in  the environment,  have significant  potential  to contribute  to  pollution.
Neither  sulfur nor  ammonia,  however,  as  raw materials  present  significant
problems  to  the environment.   This  is due  largely  to the efficient handling
and  transportation  systems  in use  (1.3.3.1)  and due to  the expense  of  the
materials and  their  obnoxiousness  if  spilled.  Spills are rare and with the
adequate recovery systems in use losses are held to a minimum.

1.4.2   Process-Related Problems
        S0n/S0, and Acid Mists.   Gaseous oxides  of  sulfur  are used  in pro-
duction of sulfuric acid from elemental sulfur.  Uncontrolled, these emissions
can  exceed 46  kg/metric ton  (103 Ib/ton)  of  sulfuric acid  produced  (USEPA
1978b).   Prior  to the  promulgation  of NSPS in 1971  USEPA measured SO  emis-
sions  as  high as  42.5  kg/metric  ton (94 Ib/ton) of  100% sulfuric acid.  In
addition, acid mist emissions uncontrolled can be as high as 3.7 kg/metric ton
(9 Ib/ton) of  100% acid.  Oxides of  sulfur and acid mists are also evolved in
wet  process phosphoric  acid  production,  NSP, and TSP  production.   Acid mists
in these processes include phosphoric acid, nitric acid, and fluosilicic acid.

        Fluorine.  Significant gaseous emissions of fluorine, including mists,
are  evolved in  the processes for wet process  phosphoric acid, SPA concentra-
tion,  TSP,  and ammonium  phosphates.   They are also  evolved  in NSP processes
but  have   received  less  attention  (no  NSPS have  been promulgated)  because
production of  NSP is small  relative  to  other  phosphate fertilizer products.

     A major source of fluorine pollution is the gypsum pond which most facili-
ties use  to contain  solid wastes and act as a reservoir and settling pond for
contaminated process water.   Fluorides may be evolved from the gypsum ponds as
volatile fluorine, hydrogen fluoride, and silicon tetrafluoride.
                                     89

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        Particulate Air Emissions.   Particulates   can   be   generated  in  all
processes  in  which  phosphate rock is acidulated and  in  all  processes in which
a  solid  product is manufactured.  Those  processes with significant  potential
for particulate emissions are:

     •  wet process phosphoric acid production
     •  NSP production
     •  TSP production (especially nongranular)
     •  ammonium phosphates  (nongranular)

     Solid wastes from  gypsum ponds  and gypsum stacks have  not proven  to be a
source of significant particulates.

        Process Wastewater.   If  they were discharged regularly and untreated,
process wastewaters would  cause  severe  and long-lasting or  permanent environ-
mental damage to surface water ecosystems.  New source facilities will  be per-
mitted to  discharge only  treated  process wastewaters.   Due  to  the costs of
pretreatment and the requirements of  NSPS, they will discharge only during wet
weather or periods  of  water  balance   misadjustments,   when the  capacity  of
storage ponds might otherwise be exceeded.  But the possibility of accidential
or uncontrolled discharge  cannot  be  ignored.   The gypsum pond (from which any
discharge would emanate) contains  harmful pollutants including the following:

     •  phosphorus
     •  fluorides
     •  ammonia
     •  cadmium
     •  chromium
     •  zinc
     •  vanadium
     •  arsenic
     •  uranium
     •  radium-226
     •  sulfate
                                    90

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and significant levels of the following parameters:

     •  pH (extreme acidity, pH 1-2)
     •  suspended solids
     •  dissolved solids
     •  temperature

There  is  the possibility  of environmental  problems associated with contami-
nated wastewaters, even with no discharge, if seepage occurs through dikes and
pond bottoms, thereby polluting surface- or  groundwaters.

         Solid Wastes.  The major solid waste is gypsum, which is a by-product
of wet process phosphoric acid production.   The quantity of gypsum produced in
a wet process plant ranges from 4.6 to 5.2 metric tons per ton of P2°s Pr°duced.
In volume,  this  translates  to 1,360 cubic  meters  (1,779  cubic yards) yearly
per metric ton of P2°5 Pr°duced Per day.  This is enough material to cover one
acre  1.1  feet  deep  each year per  each  metric ton of P^O,. produced on a daily
basis. A  representative  plant with only one process train produces 630 metric
tons of P2°5*

     Disposal is  a  major materials problem  which can become a major pollution
problem if  improperly handled.   Plants  near the mine can  dispose  of  some of
the  solid residue  in mine  pits;  most others  use  gypsum ponds  and piles.
Rainfall runoff can  cause  serious ecological problems if suspended solids and
phosphate and  sulfate compounds  are washed  into  surface  streams  and lakes.
When rainfall drainage  is  controlled properly, the major concern remaining is
for land  use  effects,  due  to the large amount of land used and its unsightli-
ness.

     In practice  the disposition  of waste  gypsum  rarely  qualifies  truly as
disposal.   Operators  often  refer  to gypsum  piles as "storage," and some con-
sider  the gypsum  to  be stockpiled for  the  future,  when it might have an eco-
nomic  value.   Some waste gypsum has  been  disposed  of in  mine  pits very near
plants, but  this  is  a very minor  portion  of the total.  Gypsum piles eventu-
ally  fill available  pits  and  are  graded   over  original  surface  levels,  to
heights of 50-100 feet or  more.  No  gypsum  piles  are known to have ever been
                                     91

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retired  because  plant sites  have been expanding  or adding on  throughout  the
history of phosphate fertilizer production rather  than shutting  down.

1.4.3  Pollution Control

  There are  no  direct  environmental problems brought  about by  pollution  con-
trol  methods.   Air  emissions  technology  removes  fluorides  and  particulates
from gaseous wastestreams and adds them to wastewater effluents.   These  incre-
ments are  not  considered  a problem because  wastewaters  are  not  discharged.
Ultimately,  the  additional fluorides  and  particulates  (phosphate) and acids
and  other  minor impurities  collected  in  scrubber liquor  become part of  the
solid  waste disposal  problem,  but  the  quantities  amount  to   insignificant
increases.

     An indirect environmental  impact  is  a possible slight increase in fluor-
ide  emissions from  gypsum ponds due to increased  levels of fluorides  from  wet
scrubbers.   This  is a minor increase which  is outweighed  by  the beneficial
effects of the  original fluoride scrubbing.

     The only aspect of pollution control which adversely  affects  the  environ-
ment  is  the cumulative   effects  of  improper  maintenance of the equipment.
Catalytic  converters in  sulfuric  acid  production  are  sometimes  used when  the
catalytic  beds  should  be  replaced.   In general,  emissions control equipment
capable  of  bettering standards of  performance  is usually serviced  when  the
standards  are   being approached  or  exceeded.    Scrubbers and   precipitators
sometimes  break  down or  malfunction.   The actual  impact  of  these factors is
not known.

1.4.4  Location

     Ambient Air Quality.   Ambient  air  quality is not generally a  limiting
factor.   Phosphate  fertilizer  facilities  are  typically  in areas of low popu-
lation density  and little other industrial development.  Facilities in certain
areas where  natural gas  and ammonia  are  produced  are  often in more indus-
trially developed areas.
                                    92

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     Hydrologic Regime.  The  ratio  of  rainfall to evaporation  can be a major
concern in maintenance  of  the plant water balance to meet requirements for no
effluent  discharge.   Amount  of  rainfall, drainage  properties, and  depth to
water  table  are  of importance  through their  effects  on efforts  to control
contamination of surface and groundwaters from gypsum disposal areas.

     Soils and Geology.  Plants  which  do not have suitable land to lay out or
add  on wastewater and  solid  waste  disposal  facilities have  problems elimi-
nating  wastewater  discharges  and properly storing solid  wastes.   Unstable or
weak soils and  steep topography are elements of plant location that may limit
the capacity to properly handle  liquid and solid wastes.

1.5  TRENDS

1.5.1  Locational Trends

     1.5.1.1  Geographic Trends

         A distinction  should be made between trends in phosphate fertilizers
and  trends  in phosphate rock  production.  The  phosphate  fertilizers capacity
in the United States is located  about 30% on the Gulf Coast (Texas, Louisiana,
Mississippi), about  50% in Florida, about 10%  in  the western states, and 10%
scattered  throughout the  United States including North  Carolina (Blouin and
Davis  1975), with more than 80%  of domestic production of phosphate rock being
produced by Florida  and North Carolina.  The reason that the phosphate fertilizer
production figure  is significantly  lower than  proportionate  rock production
for Florida and North Carolina is that phosphate rock from those two states is
exported  to  Gulf  Coast states (while  sulfur  from  the Gulf states is returned
to Florida and North Carolina).

     These geographic  trends  are expected to continue with substantial varia-
tions  by  individual  products.   For example,  Figure  32  shows  locations of
phosphoric acid,  TSP,  ammonium  phosphates,  and  anhydrous  ammonia production
facilities projected  for  1980.  Phosphoric acid plants are usually located at
the  phosphate rock  source.   In  some cases they are  located  near sulfur  when
N-P  grades are  produced.   Very  few of the  acid  plants are  market  located.
                                     93

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                           U.S. AND CANADIAN
                        PHOSPHORIC ACID PLANTS
                                 1980           -  •
U.S. AND CANADIAN ANHYDROUS
      AMMONIA PLANTS
           1980
   U.S. AND CANADIAN TRIPLE SUPERPHOSPHATE PLANTS
                       1980
                                                                                 LEGEND

                                                                             .1171 CONSTRUCTION < J60.000 T(V
                                                                             1B6 CONSTRUCTION > 360,000 TAT
                                                                           Ifff-ON CONSTRUCTION < 3GOJOO T/Y
                                                                          A ttT&ON CONSTRUCTION > XOJJOO T/Y
                                                                       U.S. AND CANADIAN AMMONIUM
                                                                             PHOSPHATE PLANTS
                                                                                   1980
      LEGEND

  • PRE-1975 CONSTRUCTION
  » 1976-ON CONSTRUCTION
     Figure 32.   Locations of  phosphate fertilizers  and ammonia production.

Source:   Adapted from Lyon,  Fred D.   1976.   Trends in storage,  handling, and
   transport.   Proceeding of TVA Fertilizer Conference,  July 1976.   Cincinnati
   OH,  p. 37-42.
                                               94

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     Triple superphosphate  plants are  located near  phosphate  rock deposits.
These plants  are also  located next  to phosphoric  acid  production so  as  to
utilize  sludge  from  acid  operations.   All  but  three  are located  close  to
navigable channels which provide a choice in mode of transportation.

     Ammonium phosphates  require  phosphoric acid  and  ammonia.  Most  of  the
plants are  located  either at the phosphoric acid plant or at an ammonia faci-
lity.  Only  a few  small  plants  are  market  located.   Locations  of anhydrous
ammonia  facilities  illustrate  the degree  to  which ammonium  phosphates  are
being produced at these facilities (Lyon 1976).

     After 1980,  the  production of mine-oriented materials should continue to
follow the  same  pattern,  with some  production continuing in  the  Gulf Coast
states,  increased production  in  Florida through  1990,  and substantially  in-
creasing production in  North Carolina through  the  year  2000.   The  production
in  the  western  states  will hold  steady  or  increase slowly through  the year
2000.  The  shipping  advantages  of  concentrated  materials such  as SPA over
phosphate rock should enforce  the trend toward liquid  fertilizers  and result
in  a continuing  increase  in ammonium  phosphate  plants  located  near  ammonia
facilities and  inexpensive  transportation  such as  pipelines  and bargelines.

     In  Florida   the majority  of  the  mining is  done  in  the  Central  Florida
District east of  Tampa  Bay.   Polk County  is the  site of  most  of the current
mining and  fertilizer production,  with several  phosphate chemical plants  in
operation in Hillsborough and  Manatee Counties.  Planned mining and phosphate
production  facilities  will  be  built  in  Hillsborough,  Manatee, Hardee,  and
DeSoto Counties  as the richer Polk County deposits are depleted (USEPA 1978i).
In addition, less extensive deposits are being rained in North Florida.

     1.5.1.2  Siting Trends

     In  Florida,  where  the  majority  of phosphate  production  will  take place
over the next 20  years,  facilities will be close to mines.  Many of the older
facilities will  be continued, but new facilities will be located in new mining
areas  in Hillsborough,  Manatee,  Hardee,  and  DeSoto  Counties, and  in North
Florida.
                                      9-5

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     In North  Carolina,  increasing production will  entail  new plant capacity
in the Beaufort County mining area.  Phosphate fertilizer plants will continue
to be  close to mines  to take  advantage of  slurry  transport systems.   (Note:
some operators have determined that dry transportation of rock by conveyors to
beneficiation and processing  plants  may be economically competitive or advan-
tageous for their  locations,  and these will be used by some plants.)

     In general, siting  of phosphoric acid production at  sulfur and nitrogen
producing  facilities  will continue.   With  United  States  demand  for  sulfur
growing,  it  is likely  that  some  new sulfur production  capacity  will incor-
porate  phosphoric  acid  processes  into  the  facilities.   Siting  of ammonium
phosphate  production  will be concentrated  in Florida  complexes  but  with a
greater percentage  at  ammonia producing plants on the Gulf  Coast  and  in the
midwest,  and  at blending plants  along  ammonia pipelines and  barge systems.

     The  majority  of  production of  phosphate products will  be  done at sites
which are  complexes for production of more  than  one product.  84.7% of basic
fertilizers  are produced  in  such  complexes.   Very  few manufacturers  are
totally dependent  on fertilizer production.  Many  are subsidiaries of chemical
or  petrochemical  manufacturers, pipeline  companies, steel manufacturers,  or
are run by a farm  cooperative or a  sulfur producing company.  Siting may be at
a complex  where other  materials are produced  in  completely  separate or inte-
grated  process  trains.   The  overriding  trend in  siting  is  toward  large com-
plexes.   Economically,  it is  more  profitable to  operate  a  larger  complex per
ton of product.  Capital investment per ton decreases in larger complexes, and
pollution  control  costs per  ton  of  PO^S  are  ^ower *n  a  1»500 ton  per day
phosphoric acid plant  than in one producing 500 tons per day.

1.5.2  Trends In Raw Materials

     1.5.2.1  Sulfur

         In 1975 consumption of sulfur in fertilizer production was  6.6 million
long tons.  Of  that,  6.1 million  (92%)  was  used  in phosphate fertilizers. By
1985, the projected consumption of  sulfur in the United States is 15.1 million
long  tons,  with 9.3 million  projected for fertilizer use.   The  trend  is  for
more  use  of recovered  and  by-product  sulfur.  Data projecting sulfur-supply
                                      96

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patterns are summarized in Table 13 (Douglas and Davis  1977).

     These changes are  not expected to have significant effects on fertilizer
production technology.   If economically  feasible technology  is developed to
recover  sulfur  from high  and medium-sulfur coals  burnt  in  electrical power
plants,  this  source is  expected to become  a  significant  factor  by the late
1980's (Douglas and Davis 1977).

           Table 13.  Supply pattern for sulfur in the United States
               Source
       Estimated Production
   (long tons sulfur equivalent)
1975          1985
               Frasch                        7.8
               Recovered
                 Ref inery                    1.7
                 Sour gas                    1.2
               By-product sulfuric acid
                 Nonferrous smelters         1.0
                 Stack-gas cleanup            -
               Pyrites-based sulfur acid     0.4
                 Other                       0.1
                 Total                      12.1
                8.2

                4.0
                3.6

                2.0
                0.6
                0.5
                0.2
               19.0
Source:  Douglas, John R. and Charles H. Davis.  1977.  Fertilizer supply and
         demand.  Chemical Engineering 84(15):88-94.

         1.5.2,2  Phosphate Rock

     Research is ongoing to develop technology to allow use of lower grades of
rock (TVA  1978b).   Use  of somewhat lower grades in Florida has already begun,
                                     97

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with the consequence  that  MAP has become more popular with basic producers of
ammonium phosphates because rock with lower ^2°5 content can be used w^0" are
difficult to use for production of 18-46-0 DAP (Nelson 1978). Expansion of the
Central Florida Phosphate District is expected during the 1980's into counties
surrounding Polk  County, which  will be using lower  grades  of  phosphate rock
(USEPA  1978b).  Techniques  under development to extract  calcite and dolomite
from phosphate  rock,  along  with the current production  of  high polyphosphate
liquid base solutions  from high iron and magnesium North Carolina ores, point
to a continuing trend to utilize phosphate rock sources previously considered
too low in purity  or P20  analysis.

     1.5.2.3  Ammonia

     Ammonia production  currently uses  natural  gas  as  a feedstock,  of which
the United  States  has only a 10-year proven reserve.  Natural gas is expected
to  remain   important  over  the  next  decade,  but developing  efficient  United
States technology  to  make  ammonia from coal has been widely identified as the
number one national research priority for food production.

1.5.3  Process Trends

     Processes are  described  in detail in Section  1.3.   This discussion is a
summary  of  the important process  trends  that  are expected to  be  used  in new
source facilities and in upgraded existing facilities where they can be adopted.

     Sulfuric Acid Production.   The  double  absorption process has gained wide
acceptance  and  is  expected to become the  standard  because it allows achieve-
ment of  NSPS  for  sulfur oxides.   Of  32 new units completed since issuance of
the NSPS only three have not adopted double absorption.

     Phosphate Rock Processing.    A  trend is  anticipated to wet  grinding of
phosphate rock.  Wet  grinding reduces particulate emissions and eliminates the
energy-consuming step of drying  the beneficiated rock.  It is not known whether
facilities  that purchase (dried) rock  plan to utilize wet grinding.  Although
not  yet  in commercial  operation, small  pilot  projects  to produce phosphoric
acid  directly  from ground  unbeneficiated  rock  have  proven relatively  encour-
                                     98

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aging;  this  procedure offers  the potential to recover  some  of  the phosphate
content now  lost  in clay slimes  and  to  reduce the production of slime ponds,
currently a  major land use problem at mining  facilities (White et al. 1978).

     Normal Superphosphate Production.  Due  to its low  analysis,  competition
from other fertilizer products, and transportation costs of the phosphate rock
feedstock, production  is  expected to decline  slowly  and reach a maintainable
level  of  about 5%  of  total processed  straight phosphate  direct  application
materials.  This  production  will  be  done  primarily  in  small plants  in  the
market areas.

     Wet Process Phosphoric Acid.  There  are  no  new trends  -  sulfuric  acid
acidulation  is the  standard.    Auxiliary  processes  for recovery  of  uranium
oxide  are expected  as  add-on process loops during acid production and purifi-
cation steps.   These  involve  solvent extraction instead  of or in  addition to
clarification by settling.

     Clarification of Phosphoric Acid.  The  use  of settling  and gravity  pre-
cipitation techniques  should  continue.   Use of  solvent  extraction techniques
is not popular in the United States except in connection with uranium recovery,
once  the  phosphoric acid  has  been  produced.   Use of  lower   grade ores  with
higher impurities may  result  in greater interest in solvent extraction in the
raid-to late 1980's.

     Superphosphoric Acid Production.   Industry  units  are  divided  between
submerged combustion and vacuum evaporation processes.  The trend is to vacuum
evaporation  to avoid  the drawbacks  of   submerged combustion,  which  require
extensive scrubbing facilities  due  to  the large  volume of  effluent  gases.

     Triple  Superphosphate Production.  The  use  of   granulator  proce. ses  is
currently more popular  and  should  continue.   Nongranular  forms are  still
produced  largely  for  use as  seed  material  in  granulation-ammoniation  pro-
cesses. This practice  may  continue but  is expected to  decline further due to
process modifications  in  ammoniation-granulation plants  which use  recycled
fines and can  use other  fertilizer materials in granulation.   Nongranular TSP
is troublesome  because of  potential dust emissions at each handling stage; it
is not wellsuited for dry blended fertilizers.
                                    99

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     Ammonium Phosphate Production.  DAP  is  popular and well-established. Its

production levels are  expected  to trend downward,  however,  due to the diffi-

culties  in  maintaining DAP  formulations  when lower analysis  rock is used in

production.    MAP production  is  expected to  regain marketing  and production

acceptance due to a number of reasons (Achorn & Kimbrough 1978):


     1.  Conventional DAP plants can produce MAP with exising equipment
         and at the same time eliminate one preneutralizer, reduce am-
         monia losses, and produce a lower moisture slurry that requires
         no drying.

     2.  MAP can be produced in a pipe-cross reactor with no preneutralizer.

     3.  MAP has more versatility for use by the bulk blender since a larger
         number of grades can be produced from MAP as compared to using DAP.

     4.  MAP is compatible with TSP whereas DAP reacts and causes caking when
         mixed with most commercially available TSP.

     5.  MAP can be used to produce suspension fertilizers by the addition
         of  only ammonia whereas when DAP is used to produce these suspen-
         sions, phosphoric acid must be mixed with it and acid storage must be
         available at the dealer level.

     6.  The dual marketing of anhydrous ammonia and MAP is probably more
         economically attractive than ammonia and DAP.

     7.  Most phosphate producers desire to ship mostly P?0  and add ammonia
         to the product only to convert the P?0,. to a suitable form for
         shipping.

1.5.4  Trends in Pollution Control
     Pollution control systems and  process designs are described in detail in
Section 3.0.  This discussion is  a summary of the more widely adopted pollution
control methods being integrated  into new source facilities including upgraded
existing facilities.


     Wastewater  treatment   comprises  a  small  segment  of effluent  control.
Housekeeping,  operational,  and design controls are the  foundations  of waste-

water  effluent  management.   Control  techniques  which are  expected  include:


     •   Spill control and monitoring systems in sulfuric acid plants to
         contain, treat,  and recycle spills and leaks.
                                    100

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     •   Elimination of discharge during normal operations by achieving
         water balance within or among the process trains.  Techniques  to
         meet this criterion include:

         1.   Use of contaminated water for dilution of sulfuric and phosphoric
             acid.

         2.   Use of recycled contaminated water in wet scrubbers.

         3.   Routing of condensed contaminated water from steam ejectors
             and barometric condensers to the gypsum pond.

         4.   Sale of scrubber liquor for fertilizer or fluorine recovery.

     •   Use of surface drainage systems to pass washdown and runoff waters
         to  the contaminated gypsum pond.

     •   Design of gypsum ponds to contain specified rainfall events.

     •   Double-lime treatment of controlled discharge from gypsum ponds
         during rainfall events that exceed design capacities.

     •   Design and siting of gypsum ponds to control seepage and  recycle
         collected seepage back to the pond.

     •   Control of NH»-N loading to the gypsum pond by use of self-con-
         tained systems in the ammonium phosphate process to recycle or treat
         separately secondary wet scrubber liquor.

     Control systems expected  for gaseous emissions include pollutant  control

technologies and design modifications:


     •   Double absorption process modifications are usually chosen in  sul-
         furic acid plants.  Less popular techniques for new source facilities
         such as ammonia scrubbing, sodium sulfite-bisulfite scrubbing, and
         molecular sieves have experienced some operational or cost-related
         drawbacks.

     •   Use of acid mist eliminators; a number of systems are acceptable
         (Section 3.1).

     •   Use of baghouse filters and efficiently designed vent and cir-
         culation systems for capture  and recycling of captured emissions.

     •   Use of enclosed dry material  transfer and handling systems.

     •   Use of continuous process mills in NSP and TSP production with
         scrubbing and recycling of emissions.

     •   Use of pipe reactors and pipe-cross reactors in granulated fertilizer
         production, with the evolution of less ammonia (eliminating pre-
         neutralizers) and of lower particulate emissions.
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     Trends which attenuate the production of solid wastes include:

     •   Recycling of acid sludge to the phosphoric acid evaporator  feed
         tank (USEPA 1979a).
     •   Production of SPA from high iron and magnesium phosphoric acid
         to sequester impurities in solution.  This product can be used most
         readily in liquid fertilizers.

1.5.5  Environmental Impact Trends

     1.5.5.1  Water Quality

     Surface water  contamination in  phosphate  processing drainage  areas has
been  significant  in  the  past.   Untreated  discharges  from gypsum  ponds are
characterized  by  heavy  loadings of  sediment  (suspended  filterable solids),
inorganic phosphorus, and fluorides.

     Since  promulgation  of effluent  guidelines for  the  phosphate  fertilizer
industry in  1974  regular discharge  of gypsum pond effluents have been largely
eliminated.  Seepages and  accidental  discharges still occur and some existing
sources  have  not   completely  discontinued  regular   discharges  that will  be
prohibited  in  1984.  New  sources  constructed  since  1974 and  most  phosphate
fertilizer  plants  in operation have eliminated regular  discharges.   Table 14
is  a  summary of the  results  of  a survey completed by  Monsanto Research Cor-
poration  in 1976  and 1977  for the  USEPA  Industrial  Environmental Research
Laboratory (USEPA 1979a).

     Definitive time  series data are not available to  compare baseline  (pre-
effluent guidelines) and present water quality.   It is presumed that the  trend
to  fewer discharges  with specified  limits on contaminant  concentrations is a
basis for a  trend  to less serious  water  pollution problems currently, and in
the future.

     The potential  for groundwater  contamination  is based on an assemblage of
variables including  permeability of soils underlying gypsum ponds,  effective
gypsum pond bottom  sealing and seepage control, and  depth to water table.  A
study by  the  USEPA Office of Radiation Programs completed  in  October 1977

                                    102

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                  Table 14.    Water  effluent disposal and  containment
                         practices  for the  phosphate  fertilizer industry,



Wet process
• phosphoric
acid plants
Process water discharged continuously:
Treated
Untreated
Discharge of treated process water only j
No discharge of process water reported
Insufficient information
Total
Fond system onsite for water containment
and reuse:
Continuous discharge from pond system
Discharge only when necessitated by
periods of excessive rainfall
No discharge from pond system reported
Treat pond system with lima to precipitate
fluorides and other contaminants
Uncertain
No pond systea onsite
Information regarding wastewater
handling system incomplete
Recover fluosilicic acid
Number of plants contacted
Number of plants in industry
Percent of industry surveyed

7
3
IP
JO
52
	 0_
100

90
7

38
45

3
0
0

10
28
29
36
81

(2)8
(1)C
(ll)f
(15)
(0)
(29)

(26)
(2)8

(11)
(13)

(1)
(0)
(0)

(3)
(8)





Superphosphor ic
acid plants

0
0
AA
44
56
0
100

89
0

44
44

11
0
0

11
0
9
9
100

(0)
(0)
(4)f
(4)
(5)
(0)
(9)

(8)
(0)

(4)
(4)

(1)
(0)
(0)

(1)
(0)




Industry
Normal
superphosphate
plants

0
0

6
88
	 6_
100

36
0

6
23

13
6


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indicates, with  a  number of qualifications  regarding  the variability of  con-
ditions  and  performance  of  individual  plants,  that  there  may  be  no major
wide-spread groundwater contamination by radium-226 levels in gypsum ponds and
effluents (USEPA 1977d).  Studies of Florida groundwater, however, are compli-
cated by some high natural background levels of radionuclides and by anoraolous
and  incomplete data.   Although exceedingly  low percolation rates through com-
pacted aged  gypsum cake and the underlying  clay-permeated sediments have been
reported  (Wissa  1977),  some local contamination of the water table aquifer is
occurring at some  sites,  near gypsum stacks and ponds  (TRC 1979).  It has not
been demonstrated  definitively  whether  migrations of radionuclides take place
through gypsum pond bottoms nor what degree  of sealing  is effective.

     1.5.5.2  Air Quality

     Since sulfuric acid  and  phosphate  fertilizer NSPS have been promulgated,
emission  levels  for  particulates,  sulfur  oxides,  acid mists,  and fluorides
have mandated performance  levels  which  can  be attained using  available tech-
nology to control  plant process emissions.  The phosphate rock segment of the
chemical  and fertilizer  mineral  industry  was  estimated to have  contributed
44,276,000 metric  tons  of  particulate  emissions in 1975, or  39% of the total
for  all  chemical and  fertilizer production  (USEPA  1978e).  The above figures
include  the  mining and  beneficiation processes,  but it  is evident that par-
ticulates are  a  major  potential  emission  source for  fertilizer handling and
processes.   Fluorides  are contributed  to  emission streams in  volatile forms
and as constituents of particulate emissions.  The overall environmental trend
is  for   lowered  emissions  of  particulates,  sulfur oxides,  acid  mists,  and
fluorides using  control  technologies.   Gypsum ponds have long been posited as
a major  virtually  uncontrolled  source  of fluoride emissions.   Recent modeling
by  Environmental Science  and  Engineering  for  the USEPA  Industrial  Environ-
mental Research  Laboratory  dispute  the  significance of volatile emissions and
suggests that fugitive  dust from gypsum piles and deposits have been inadver-
tently  included  in  measurements  of gypsum  pond  emissions   (USEPA  1978c).

     It  is  clear  that the  lowering of  emissions of  fluorides will  not be
effective until sources are defined and  agreed on.  Meanwhile,  a general trend
that can be  agreed  on is that  fluoride  emissions  could ultimately be lowered

                                    104

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effectively by  removing them  completely from  the  waste system  as a salable
product, fluosilicic acid (USEPA 1978c).  There is a trend toward the recovery
and sales  option,  but  it is not overwhelming  due to unfavorable economics in
some areas and for some removal processes.

     1.5.5.3  Physiographic Impacts

     The major environmental effect of the industry on the quality of the land
resources  is  the  disruption  of the topography caused by  the accumulation of
gypsum  deposits  and  long  term dedication  of  land areas  to  gypsum  ponds.
Unlike  the  case  of phosphate mines, however, where vast areas have been mined
and/or  tied up in  slime ponds,  fertilizer plants  themselves involve relatively
smaller land areas.  Past experience has been that these impacts are, however,
equally  long  term in  that  no  major plants,  gypsum piles,  or ponds have been
totally retired or reclaimed.

1.6  POLLUTION CONTROL REGULATIONS

1.6.1  Water Pollution

     The  Federal  Water Pollution Control  Act  (FWPCA)  Amendments of  1972
(P.L. 92-500)  established   two  major  interrelated procedures  for controlling
industrial  effluents  from  new  sources,  and specifically  included phosphate
manufacturing  in  the  list  of   affected categories of  sources.  The principal
mechanism  for  discharge  regulation is the NPDES  permit.   The other provision
is  the  new  source  performance  standard.   The  Clean  Water  Act  of  1977
(P.L. 95-217),  which amends P.L.  92-500, made no change  in  these basic pro-
cedures.

     The  NPDES permit,  authorized by  Section 402  of  FWPCA,  prescribes the
conditions  under  which effluents  may be  discharged  to surface  waters.   The
conditions  applicable  to new  or expanded phosphate  fertilizer manufacturing
facilities  will  be  in accordance  with  NSPS,  adopted  by USEPA  pursuant  to
Section  306,   and  pretreatment standards  promulgated  to implement  Section
307 (b).  Stricter  effluent  limitations may be applied on a site specific basis
if required to achieve water quality standards.
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     The effluent  NSPS promulgated  for new  sources  in  the  Fertilizer  Manu-
facturing Point  Source,  Phosphate  Subcategory under 40  CFR  418 are shown  in
Table  15.   "Calcium sulfate"  in Table  15  refers  to  gypsum  or other  calcium
sulfate solid materials,  which normally include dihydrate, anhydrite, or  hemi-
hydrite.

     In principle, phosphate fertilizer manufacturing facilities can discharge con-
taminated nonprocess  wastewater, with pretreatment,  to  publicly owned treat-
ment  works   (POTW).    In  practice,  however,  nonprocess  wastewater  is  often
either  combined   with  process  wastewater  or treated  separately  and  either
discharged  or,  once  treated  to remove  such constituents  as  cooling  water
treatment chemicals (zinc or chromium compounds, for example), may be combined
with process wastewater.

     The USEPA pretreatment regulations  stipulate that  certain POTW's  cate-
gorized by  size  and influent  characteristics develop  POTW Pretreatment Pro-
grams.  These programs are  intended to prevent the introduction of pollutants
by  industrial  users  that  would  interfere with  the operations  of treatment
works,  would  pass through  treatment  works, or would  adversely affect oppor-
tunities to  recycle and reclaim wastewaters and sludges.

     Regardless of specific limitations required by the Pretreatment Programs,
the regulations (40 CFR 403.5) state the following may not be  introduced into
a POTW:

     •  Pollutants  which create  a  fire  or  explosion  hazard  in  the  POTW.
     •  Pollutants which  will cause corrosive structural  damage to the
        POTW, but  in  no case  discharges with  pH  lower  than 5.0,  unless the
        works is  specifically designed to accomodate such discharges.
     •  Solid or  viscous  pollutants  in  amounts  which  cause  obstruction  to
        the  flow  in sewers, or  other interference with  the  operation of the
        POTW.
     •  Any  pollutant, including oxygen  demanding pollutants,  released  in a
        discharge  or such volume or strength as  to cause interference in the
        POTW.

     «  Heat tn amounts which will inhibit biological activity  in the
        POTW resulting  in interference  but in  no case heat in  such quantities
        that the  temperature at the treatment  works influent exceeds 40  C
        (104 F) unless  the works  is  designed to accommodate such heat.

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              Table 15.  Standards of performance for new sources
                  for wastewater effluents.
     The following standards of performance establish the quantity or quality
of pollutants or pollutant properties which may be discharged by a new source
subject to the provisions of this subpart:

(a)  Subject to the provision of paragraphs (b) and (c) of this section, the
following limitations establish the quantity or quality of pollutants or
pollutant properties, controlled by this section, which may be discharged by a
point source subject to the provisions of this subpart after application of
the best available demonstrated control technology:  there shall be no dis-
charge of process wastewater pollutants to navigable waters (41 FR 20582,
May 19, 1976).

(b)  Process wastewater pollutants from a calcium sulfate storage pile runoff
facility operated separately or in combination with a water recirculation
system designed, constructed, and operated to maintain a surge capacity equal
to the runoff from the 25-year, 24-hour rainfall event may be discharged,
after treatment to the standards set forth in paragraph (c) below, whenever
chronic or catastrophic precipitation events cause the water level to rise
into the surge capacity.  Process wastewater must be treated and discharged
whenever the water level equals or exceeds the midpoint of the surge capacity
(41 FR 20582, May 19, 1976).

(c)  The concentration of pollutants discharged in process wastewater pursuant
to the limitations of paragraph (b) shall not exceed the values listed in the
following table:
                                     Effluent Limitations (mg/1)
                                                       Average of daily
    Effluent                  Maximum for              values for 30 con-
Characteristic                any one day              secutive days shall
	not exceed	

Total Phosphorus (as P)           105                          35
Fluoride                           75                          25
TSS                               150                          50

     (42 FR 16140,  March 25, 1977)

The total suspended solids limitation set forth in this paragraph shall be
waived for process  wastewater from a calcium sulfate storage pile runoff
facility operated separately or in combination with a water recirculation
system, which is chemically treated and then clarified or settled to meet the
other pollutant limitations set forth in this paragraph (41 FR 20582, May 19,
1976).
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 Table 15 concluded.
 (d)  The concentration of pollutants discharged in contaminated nonprocess
 wastewater shall not exceed the values listed in the following table:
                                   Effluent Limitations  (mg/1)
                                                  Average of daily
    Effluent                  Maximum for         values for 30 con-
Characteristic                any one day         secutive days shall
                                                     not exceed
Total Phosphorus (as P)
Fluoride
105
75
35
25
      (41 FR 20582, May 19, 1976; 42 FR 16140, March 25, 1977)


      The  effluent  guidelines  listed above do  not  presently include standards
for  pH.   Standards of 8.0  to  9.5 which were  previously  promulgated were re-

manded  in 1976,  but limitations on pH  of  6-9 are generally  set  at the State
level or as a condition of the NPDES permit.


      The  pretreatment  standards  promulgated  for new sources  in the phosphate
subcategory are quoted below:
     The pretreatment standards under Section 307(c) of the Act for a
     source within the phosphate subcategory, which is a user of a
     publicly owned treatment works (and which would be a new source
     subject to Section 306 of the Act, if it were to discharge pol-
     lutants to the navigable waters), shall be the standard set forth
     in 40 CFR part 128, except that for the purpose of this section,
     40 CFR 128,  133 shall be amended to read as follows:
     In addition to the prohibitions set forth in 40 CFR 128, 131, the
     pretreatment standard for incompatible pollutants introduced into
     a publicly owned treatment works shall be as follows:  There shall
     be no discharge of process waste water pollutants (40 CFR 418.16).
Note:   40  CFR  128,  Environmental  Protection Agency  Pretreatment  Standards,
were issued in the June 26,  1978 Federal Register as 40 CFR 403.
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     In addition,  there is  a restriction on  thermal  discharges  that becomes
effective in June 1981.

     Since new  sources discharging  to PO'TW's do  not require  NPDES  permits,
they are  not subject to NEPA under  Section 511 (c) of the  Federal  Water Pol-
lution Control Act, as amended by the Clean Water Act of  1977.

     NPDES permits also  impose special conditions beyond the effluent limita-
tions  stipulated,  such  as  schedules  of  compliance and  treatment  standards.
Once facilities  are  constructed in conformance with  all  applicable standards
of performance,  however, they are relieved by Section 306(d) from meeting any
more stringent standards of  performance for 10 years  or  during the period of
depreciation  or  amortization, whichever ends  first.   This  guarantee  does not
extend,  however, to  toxic  effluent standards adopted under  Section 307(a),
which  can be  added  to the facility's  NPDES  permit when  they are promulgated.
Toxic pollutants thus far identified do not include phosphate-fertilizer-related
substances.   The process which would be most likely to be considered in future
toxic standards are solvent extraction processes for uranium oxide.

     Many states have qualified,  as  permitted by Public Law  92-500,  to ad-
minister their own NPDES  permit programs.  The major  difference  in obtaining
an NPDES  permit through approved  State programs  vis-a-vis  the Federal NPDES
permit program is  that  the Act does not  extend  the NEPA environmental impact
assessment requirements  to State  programs.  It is  likely  that new  facilities
or major expansions  of  existing facilities will come under increased environ-
mental review in the  future.  Because the scope  of  the  implementing regula-
tions  varies considerably,   current   information  on  prevailing  requirements
should be obtained early  in   the planning  process  from permitting authorities
in the appropriate jurisdiction.

1.6.2  Air Pollution

     The Federal regulations  applicable  to the  air  emissions from phosphate
fertilizer manufacturing  facilities  are  promulgated  under  six industry sub-
categories.    The NSPS for  the Sulfuric Acid  Subcategory  apply to  sulfur di-

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oxide and  acid  mist.   The NSPS for the other five subcategories - Wet Process

Phosphoric  Acid Plants,  Superphosphoric Acid  Plants,  Triple Superphosphate

Plants,  Granular  Triple  Superphosphate Storage  Facilities,  and  Diammonium

Phosphate  Plants - apply  to emissions of fluorine  and all fluoride compounds

(total fluorides).


     The NSPS  for   the  applicable  subcategories  are  shown in  Table 16.  The
standards  for  sulfuric  acid plants, although promulgated,  have been involved

in lengthy litigations and have been virtually non-effective.  A review of the

standards  was  completed in  August  1978  (USEPA  1978a) which  has  recommended

that no  revisions  be  made to the NSPS for sulfur dioxide or acid mists.  Some
states have, however,  adopted  stricter standards, although some of them apply
           Table 16.  New source performance standards for emissions
                of  air pollutants  from  sulfuric  acid  plants and  phosphate
                fertilizer manufacturing facilities.
         Process
Sulfuric Acid Plants
Wet Process Phosphoric
Acid Plants

Superphosphoric Acid
Plants

Diammonium Phosphate
Plants

Triple Superphosphate
Plants

Granular Triple Super-
phosphate Storage
Facilities
               Standard

Sulfur  dioxide:   2kg/metric ton  (4  Ib/ton)  of
  100% H2SO, produced.

Acid  Mist:   (1)   No  more  than  0.075 kg/metric
  ton  (1.15  Ib/ton)   of  100% ^SO,  produced.
  (2)   Not  to  equal  or  exceed   10%  opacity.
Total  fluorides:
  ton  of
         Not  to  exceed 10.0  g/metric
equivalent ?20  feed  (0.020  Ib/ton)
Total  fluorides:   Not  to  exceed  5.0 g/metric
  ton  of  equivalent  P  0_  feed  (0.010 Ib/ton)

Total  fluorides:   Not  to  exceed  30 g/metric
  ton  or  equivalent  P  0   feed  (0.060 Ib/ton)
Total  fluorides:   Not
  ton  of  equivalent  I
              to exceed  100  g/metric
             205  feed  (0.20  Ib/ton)
Total fluorides:  Not to exceed 0.25  g/hr/metric
  ton of  equivalent  P-O  stored  (5.0 x 10    lb/
  hr/ton)
Sources:   40 CFR Part 60, 40 CFR Part 422.
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only to  specific  industries  or only to combustion sources.  The applicability
of these standards  should be clarified when considering the impact of any new
source.

     It  is  possible  that the Federal sulfur dioxide ambient air quality stan-
dards  (40 CFR  Part  50),  which are nonenforceable  goals  for acceptable levels
of  this  pollutant,  may  be  exceeded in  the vicinity  of  phosphate fertilizer
facilities.   Depending on site-specific  operations,  ambient air standards for
particulates could be  violated  by many types of  operations  in this industry,
especially  in  processing  and handling  phosphate rock and dry phosphate ferti-
lizer  products.   Standards   for  sulfur  dioxide and  particulates  are  shown in
Table 17.

               Table 17.   Federal ambient air quality standards.
Sulfur Dioxide
                                                       (Ug/m3)
Primary standard:
     Annual arithmetic mean                              80
     Maximum 24-hour concentration not to
     be exceeded more than once a year                  365
Secondary standard:
     Maximum 3-hour concentration not to
     be exceeded more than once a year                1,300
Particulates
Primary standard:
     Annual geometric mean                               75
     Maximum 24-hour concentration not to
     be exceeded more than once a year                  260
Secondary standard:
     Annual geometric mean                               60

SOURCE:  40 CFR Part 50.
                                    Ill

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     Sulfuric  acid  plants  or phosphate  rock  processing  facilities  with  the
capacity to emit 100 tons (91 kkg, or metric tons) or more per year of any  air
pollutant may  be  prohibited from constructing new facilities in certain areas
under the Clean Air Act (P.L. 95-95) Prevention  of  Significant Deterioration
(PSD) regulations.  Also, any facility (which would include plants which react
phosphoric acid but  do not actually process phosphate rock) with the potential
to emit 250 tons (227 kkg) or more per year of any pollutant may be prohibited
from constructing new facilities in certain areas.  Alternately, facilities in
either of these  two categories could be required to meet stricter air quality
goals than the ambient air standards in other areas.   The Clean Air Act Amend-
ments of 1977  (P.L.  95-95) establish three types of areas to which PSD regula-
tions may apply:

     •  Class I areas, in which almost any deterioration of air quality
        is deemed significant.
     •  Class II areas, in which*a moderate increase in pollution concen-
        tration is acceptable, to allow for moderate growth.
     «  Class III areas, in which a greater pollutant increase is acceptable.

     Increases in pollutant concentrations over baseline values are limited in
these areas  to those  shown in Table 18.   The allowable increments are limited
to those which will  not cause violations  of the ambient air quality standards.
The  PSD program  requires  preconstruction  approval of  all new  sources  with
significant potential  emissions  of  SO.  or particulate matter.  Applicants for
construction  permits  must  demonstrate  by  monitoring  and submission  of  air
quality  data that  the  new facility  will not violate  an applicable  NSPS  or
increment or any air quality standard.

     All international parks, national wilderness areas, and national memorial
parks that exceed 5,000 acres, and all national parks that exceed 6,000 acres
are  classified  as Class I  areas.   However,  an exception may be  granted  to a
source exceeding  the Class  I allowable  increase  on these mandatory  Class I
areas  if  a  Federal  land  manager  certifies  that the  facility will  have  no
adverse impact  on the  air  quality-related values,  including visibility.   In
such  cases,  the  allowable  increases listed  in  the last  column of Table  18
apply.

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             Table 18.   Nondeterioration increments  for  502 and
                  particulate matter  in  areas with different air
                  quality classifications.
        Pollutant            Class^I     Class II   Class III  Class I exception
                             (yg/m )     (yg/m )    (yg/m )          (yg/m )


Particulate matter:

  Annual geometric mean         5           19         37              19

  24-hour maximum              10          37         75              37

Sulfur dioxide:

  Annual arithmetic mean       2           20         40              20

  24-hour maximum              5*          91        182              91

   3-hour maximum             25*         512        700             325
*A variance may be allowed to exceed each of these increments on 18 days
 per year,  subject to limiting 24-hour increments of 36 yg/m^ for low
 terrain and .62 yg/m^ for high terrain and 3-hour increments of 130 yg/m^
 for low terrain and 221 yg/m^ for high terrain.  To obtain such a variance
 requires both State and Federal approval.
 SOURCE:  Clean Air Act Amendments of 1977.
                                      113

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     All other  areas are  designated  as Class II, but  states  may redesignate

these areas  as  Class  I  or III,  provided certain requirements  of Public Law

95-95 are fulfilled.


     Similar  air  quality  regulations  may  be  applied  to  new  facilities  or

significantly modified  existing facilities in  industrial  areas  where ambient

air  standards  are   being  exceeded  (nonattainment  areas).   Permits  will  be

required for  construction  and  operation of major new or  modified sources and

applicants will be  required  to achieve the "lowest achievable emission rate"

(LAER) of any pollutant  which  exceeds the standards.   This rate is defined as

a rate of emissions  which reflects:


     e  the most stringent emission limitation in the applicable state
        implementation plan unless the applicant can demonstrate that such
        limitations  are not achievable; or

     e  the most stringent limitation which is actually  achieved in prac-
        tice by similar facilities.


     Public Law 95-95 further requires that the permit to construct and operate

may be issued only if:


     •  by the time  the facility is to commence operation, total allowable
        emissions from all existing and new sources in the Air Quality Control
        Region,  including the new or modified  facility,  will permit reasonable
        further  progress toward attainment of  the applicable national ambient
        air standard for the identified pollutant; or

     •  the emissions of such pollutant from the new or  modified facility
        will not cause the total emissions of  the pollutant to exceed the
        allowance permitted by  the implementation plan for the pollutant from
        all new or modified sources in the area.


     The purpose of  these requirements is to allow, under strict stipulations,

that  the  economic benefits to  a  region from introduction  of  new industry or

new expansion of  existing  industry (new sources) may be obtained.  The quali-

fying condition is that the new action must be accomplished in a way to assure

progress toward compliance in the nonattainment area.   Thus, permits issued by

USEPA or  the  approved State  agency  must require  "offsets"  in  the existing

levels  for  pollutants  which   exceed  Federal   ambient  air  quality standards.
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     Offsets  are  enforceable  reductions  from  the existing  sources of  air

pollutants which will be greater than the emissions of those pollutants antici-

pated from  the  new source.  A  "new  air  quality  benefit" must result from the
combined new project plus the offsets attained (44 FR 3284, Part IV.A.4 and 44

FR  3275).   The quantity of  offsets  must match the new  source  emissions  on a
"more than one-for-one" basis.  The manner in which offsets may be attained is
not specified.  Several possible approaches have been used:


     •   when  the new  source  is  an expansion of  an existing  facility,  the
         owner may install  tighter controls on existing operations to achieve
         emissions which  may be  lower than those  otherwise  required for the
         existing sources;

     •   when  the  new source  is  an  entirely  new plant under a  new owner in
         the nonattainment area, the applicant may reach an agreement with one
         or more  existing  sources  whereby they agree to apply stricter pollu-
         tion control measures, presumably in exchange for compensation by the
         new source applicant;

     •   .in some  instances,  the  applicant  may purchase  outright an existing
         facility, especially  an  obsolete facility with  high  pollutant  emis-
         sions, and either clean it up or simply close it down;

     •   in  cases where   the   state  and/or  local  government  are  extremely
         interested in locating the  new source industry in the area, say, due
         to the benefits  to the local economy, they may assist the applicant
         either by putting pressure on the existing sources to achieve stricter
         pollution control standards or by public works actions such as paving
         of roads in the area to help reduce background particulate emissions.


     The  amount  of  time  required  to process PSD  applications  could run to
several years in  some  controversial  cases and adequate  lead  time for design,

for modeling  of  air quality effects, and for required  monitoring  (one  year)

should  be  anticipated.   The USEPA  is  committed  to  a policy  of  expediting

permit  application processing,  public participation activities,  and internal

reviews so that the  entire PSD review process could  theoretically be carried

out within 90 days after  receipt  of  a complete  and technically substantiated

application.  This time,  however,  could be extended by state review procedures,

litigation, or  offset  arrangements  in a highly  industrialized nonattainment
area.    Hoffnagle  and Dunlap  (1978)  emphasize that  an  industry  should  allow

adequate time  for the one-year baseline monitoring.   Review  and approval by

regulatory  agencies  of  the  design  of  the  monitoring  plan at  the earliest

possible time can be  a time saver.  Total time involved in the PSD process for

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 the permit applicant may realistically range from 18-43 months, as illustrated
 below (Hoffnagle and Dunlap 1978):
          Activity
 Specify monitoring required
 Select vendors and contractors
 Procure and install equipment
 Conduct 1-yr baseline monitoring
 Complete data analysis,  modeling
   and permit application
 Request special model (if
   necessary) with agency hearing
   and review
 Hearings on application and
   agency review
Time for
Activity
(Months)
  1-2
  0-3
  1-4
   12

  1-4
  0-6

  3-12
Cumulative
  Time
 (Months)
   1-2
   1-5
   2-9
  14-21

  15-25


  15-31

  18-43
1.6.3  Solid Waste Regulations

     The Resource Conservation and Recovery Act (RCRA),  P.L.  94-580,  defines
"solid waste" as including solid,  liquid,  semisolid,  or  contained gaseous
materials.  Regulations implementing Subtitle C of the Act (40 CFR Part 261)
provide that a solid waste is a hazardous  waste if it is,  or  contains, a
hazardous waste listed in Subpart  D of Part 261 or the waste  exhibits any of
the characteristics defined in Subpart C.   These charcateristics include:

     o  Ignitability (flash point  below 60° C (140° F)
     o  Corrosivity
     o  Reactivity
     o  Toxicity

     Hazardous wastes are identified in 40 CFR 261 Subpart D.   The hazardous
substances identified at this time in Subpart D do not include the major
solid wastes of the phosphate fertilizer industry.   However,  this does not
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eliminate the possibility of industry wastes having "hazardous" designations
in the future.  Wastes containing arsenic or cadmium, for example, may be
considered hazardous if the toxic materials can be leached out at concentrations
of 5 mg/1 and 1 tng/1, respectively, using the EP (Extraction Procedure) toxicity
test.  The natur of the wastes to be generated by a particular new source
phosphate fertilizer plant will have to be carefully examined to determine the
applicability of the hazardous waste designation.
     All new facilities that will generate, transport, treat, store, or dis-
pose of hazardous wastes must notify US EPA of  this occurrence and obtain a
USEPA identification number.  Storage, treating, and  disposal also require a
pe rmi t.

     The determination of whether wastes  generated or handled are hazardous  is
the responsibility of the owner or  operator of  the generating or handling
facility.  The first step is to consult the promulgated  list  (CFR 261  Subpart
D).  If the waste is not listed, the second step is to determine whether the
waste exhibits any of the hazardous characteristics of listed through analytical
tests using procedures promulgated in the regulations of by applying known
information about characteristics of the waste based on process or materials
used.

      If it is determined  that  a hazardous waste is generated, it should be
 quantified to determine  applicability of  the  small generator exemption.  This
 cutoff  point  is  2,200  pounds  per month,  but it drops to 2.2 pounds for any
 commercial product  or  manufacturing chemical  intermediate having a generic
 name  listed  in Section 261.33.   Containers that have been used to contain less
 than  21 quarts of Section  261.33  materials and less  than 22 pounds  of  liners
 from  such  containers are also  exempt.   It is  anticipated that this  exemption
may be  available  to many very  small plants with,  for example, only one machine
 tool and one  small  painting operation.   However,  as  more information is ob-
 tained  on  the  behavior of  substances in  a disposal environment,  the terms of
 th:'.s exemption may  be altered  from time  to time.
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     The hazardous waste management system is based on the use of a manifest
prepared by the generator describing and quantifying the waste and designating
a disposal, treatment, or storage facility permitted to receive the type waste
described to which the waste is to be delivered.  One alternate site may be
designated.  Copies of the manifest are turned over to the transporter and a
copy must be signed and returned to the generator each time the waste changes
hands.  If the generator does not receive a copy from the designate'  receiving
facility or alternate within 35 days, he must track the fate of the waste
'.'•.rough the transporter and designated facility or facilities.  If the mani-
fest copy is not received in 45 days, the generator must file an Exception
Report with US EPA or the cognizant state agency.

     A copy of each manifest must be kept for three years or until a  signed
copy is received from the designated receiving facility.   In turn, the si.aed
copy must be kept for three years.  The same retention period applies to each
Annual Report required whether disposal, storage,  or treatment occurs on-site
or off-site.

     The generator must also:

     e  package the waste in accordance with the applicable DOT regulations
        under 49 CFR Parts 173, 178, and 179;
     #  label each package in accordance with DOT regulations under 49 CFR 172;
     r  imrk each package in accordance with the applicable DOT regulations
        under 49 CFR 172;
     9  nark each container of 110 gallons or less with the following DOT
        (49 CFR 172) notice:
               "Hazardous Waste - Federal Law Prohibits Improper Disposal.
               If found, contact the nearest police or public safety  authority
               or the U.S. Environmental Protection Agency."

     «  supply appropriate placards for the transporting vehicle in accordance
        with DOT regulations under 49 CFR Part 172, Sub part F.
                                      H6b

-------
     Waste in properly labelled and dated containers  in  compliance with  the
regulations may be stored on the generator's premises  for up to 90 days  with-
out a storage permit.  This is to permit time for accumulation for more  economic
pickup or to find an available permitted disposal facility.

     Due to the cost and stringent design and operating  requirements for
permitted landfills, it is anticipated that most new  generator plants will
utilize off-site disposal facilities.  However, any companies desiring to
construct their own will be subject to 40 CFR Part 264.

     Incineration is considered to be "treatment," and,  as such, is also
subject to Part 264 as are chemical, physical, and biological treatment  of
hazardous wastes, and a permit will be required.  Totally enclosed treatment
systems--such as in-pipe treatment of acid and alkaline  solutions—are i  ot
subject to this part.

     Although underground injection of wastes constitutes "disposal" as  de-
fined by RCRA, this activity will be regulated by "he  underground injection
control (UIC) program adopted pursuant to the Safe Drinking Water Act  (P.L.
93-523).  The consolidated permit regulations (40 CFR Parts 122, 123,  124)
govern the procedural aspects of this program; the technical considerations
are contained in 40 CFR Part 146.
     The disposal of innocuous solid wastes  is subject  to  Subtitle D of RCRA
and the implementing regulations  (40 CFR  Part 256).  Recovery or  disposal  in
an approved sanitary landfill will be  required under a  state program.  Disposal
in open dumps is prohibited.  All existing state  regulations which do  not  meet
the requirements of Subtitle D are superseded.
                                     116c

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1.6.4  Monitoring Requirements

     In addition  to  applying the best available  technology  to abate and con-
trol adverse environmental impacts from air emissions, wastewater streams, and
land disposal of  wastes,  an NPDES permit applicant will be required to demon-
strate compliance  with applicable  pollution control  regulations.   The NPDES
permit itself may  require monitoring, recording, and recordkeeping on flow of
all  pollutants  that are  subject to reduction or  elimination  under the terms
and  conditions  of the permit,  as  well as any other  pollutant as required by
the  State  or USEPA.   Monitoring intervals  must  be  sufficiently  frequent to
yield  data  that reasonably  characterize the nature  of  the  discharge.


      Similarly,  monitoring of leachate,  runoff, and air emissions will be
 required  under  the Federal RCRA on  sites where wastes determined to be hazar-
 dous are  landfilled.   In  addition,  it  is not  inconceivable that some type of
 monitoring may  be required for some,  if  not  all,  disposal sites for non-hazar-
 dous wastes to  ensure  that "there  is  no  reasonable probability of adverse
 effects on health of the  environment"  (Section 4004(a), RCRA).
                                   117

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                          2.0  IMPACT IDENTIFICATION

2.1  PROCESS WASTES

2.1.1  Materials Balance and Typical Waste Characteristics

     2.1.1.1  Sulfuric Acid Production

     The only wastewater streams produced in the sulfuric acid production
process are blowdown from boilers and cooling towers.  Figure 33 illustrates
the blowdown sources and quantities for a typical installation using double
absorption; older units using single absorption produce the same wastewater
quantities.  A materials balance for sulfuric acid production is given in
Table 19.

     A plant producing phosphoric acid will usually include sulfuric acid
production.  The EID should include the operating data categories listed
above.  Several plants built since 1971 have installed single absorption
process designs, usually with an ammonia scrubbing type of emission control
system for SO- removal, but double absorption is preferred by most operators,
depending on economic variables (Section 3.2.1).

        Cooling Water Contaminants

     The EID should include computations of planned quantities of cooling
water blowdown and list the probable range of contaminants, based on operating
parameters and make-up water quality.   The quality of cooling system blowdown
varies both with the level of impurities in the make-up water and the amount
and types of inhibitor chemicals used.  Data collected for the effluent guide-
lines study (USEPA 1974a)  indicated the following normal range of contaminants
in cooling water blowdown:

     Contaminant                             Concentration (mg/1)
     Chromate                                       0-250
     Sulfate                                      500-3000
     Chloride                                      35-160
     Phosphate                                     10-50
     Zinc                                           0-30
     TDS                                          500-10,000
     SS                                             0-50
     Biocides                                       0-100
                                    118

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                                                                                        STREAM LEGEND
                                                                                               MAIN LIQUID
                                              (2.2 TON/TON)
                                                         OFF GAS
                                                                                        — —  MAIN GAS
                                                                                         	\ MINOR
           FEED STREAM   L_
                                1300— 1670 l/kkg
                                (310 ~ 400 GAL/TON;
  1875 ~ 2080 l/kkg
  (450 ~ 500 GAL/TON)
    BLOW DOWN
       1
  [ COOLING H20[4
r
                  SULFUR
                 FURNACE
       «^,000 ~ 83.500 l/kkg
      (3.COO ~ 20.000 GAL/TON)
ED

Ft
:E
w n L
H20 |_
BOILER
r

STEAM


WASTE
HEAT
BOILER
BLOWDOWNl 	 .
5 ~ 10 GAL/TON) 21-
f


1
1
y+
i
CONVERSION

	 1-»
*"T"
- 40 l/kkg ~~{ !

ACID


1 I

HEAT
EXCH.
                                                COOLING &
                                                 PUMPING
                                                  ABSORPTION
               INTERSTAGE
               ABSORPTION
                                                                                                 PRODUCT
                                                              PROCESS WATER
                                              (15 - 20 GAL/TON)
                                              03 ~ 83 l/kkg
         *GN = SHORT TON
         kkg = METRIC TON
                      Figure 33.  Sulfuric  acid  plant - double catalysis
                            (flow rates per  ton 100% H SO ).
Source:  Adapted  from U.S. Environmental Protection  Agency.   1974a.  Development document  for effluent
   limitations  guidelines and new source performance standards for the basic fertilizer chemicals segment
   of the  fertilizer manufacturing point source  category.   Office of Air and Water  Programs,  Washington DC,
   168 p.

-------
            Table  19.   Sulfuric  acid  production materials balance.
       Input Materials
(per unit weight  of  100%  H
                                  Waste Streams
                          (per unit weight of 100%
   Air
   Sulfur  -
   Water
10.6 ton/ton
(10.6 Mg/Mg)

0.33 ton/ton
(0.33 Mg/Mg)

15-20 gal/ton
(3.6-4.8 1/Mg)
•  Tail gas
2.2 ton/ton
(2.2 Mg/Mg)
   - S0? (single absorption with
          no emission controls)

        21.5 - 85 Ib/ton
        (10.8 - 42.5 kg/Mg)

   - SO-  (double absorption)

          (1.8 Ib/ton)
          (0.9 kg/Mg)

   - Acid mist (no emission controls)
        0.4a> - 9 Ib/ton
        (2-50 mg/scf)b>

   Discharge water - 710-1000 gal/ton
    (170-240 1/Mg)

   - Cooling blowdown - 400-600 gal/
      ton (96-144 1/Mg)

   - Boiler blowdown - 310-400 gal/
      ton (74-96 1/Mg)
Notes:  a.   Lower value from a plant burning high purity sulfur.
        b.   scf = standard cubic foot.
SOURCE:   Adapted from U.S.  Environmental Protection Agency.  1978a.  A review
         of standards of  performance for new stationary sources - sulfuric
         acid plants; U.S.  Environmental Protection Agency.  1974a.  Develop-
         ment document for  effluent limitations guidelines and new source per-
         formance standards for the basic fertilizer chemicals segment of
         the fertilizer manufacturing point source category; and U.S. Environ-
         mental Protection  Agency.   1977b.   Industrial process profiles for
         environmental use, Chapter 22:   The phosphate rock and basic ferti-
         lizers industry.
                                    120

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     The EID should describe the proposed method of treating cooling tower
blowdown.  It can be treated separately or combined with other plant effluents
for treatment.  The method to be employed depends on the chemical treatment
method used and other cost factors.  Those plants which utilize chromate or
zinc treatment compounds generally treat the blowdown stream separately to
minimize effluent treatment costs  (USEPA 1974a).

        Boiler Blowdown Contaminants

     The EID should report anticipated quantities and contaminant levels for
boiler blowdown.  The typical range of contaminant concentrations reported in
the effluent guidelines study (USEPA 1974a) for 310-400 gal/ton of boiler
blowdown are listed below:

     Contaminant                             Concentration (mg/1)
     Phosphate                                      5-50
     Sulfite                                        0-100
     TDS                                          500-3,500
     Zinc                                           0-10
     Alkalinity                                    50-700
     Hardness                                      50-500
     Silica (Si02)                                 25-80

     To date, no effluent guidelines for either thermal discharge or con-
taminants associated with boiler blowdown have been proposed or promulgated,
but contaminants are monitored and State and/or USEPA regional offices involved
in new source permitting set up contaminant criteria.  The EID should demon-
strate that boiler blowdown contaminants levels will conform to the locally
applicable criteria.

        Air Emissions
     Recent test data are available illustrating compliance with SO^ and acid
mist emissions.  The study done by the MITRE Corporation for USEPA to evlaute
sulfuric acid plant NSPS (USEPA 1978a) obtained 29 sets of data representing
all 32 new sulfuric acid units built since the NSPS were issued.  The results
indicate tested emission levels which can be compared with EID projections for
S09 and acid mist emissions (Table 20).  Figures 34 and 35 display the data

                                    121

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          Table 20.     New  source performance  standards  compliance  test
                                 results for  sulfuric  acid  plants
Nominal
UnlL Size
(1001 H2S04)
ML Industries, Inc. Sayreville, N.J. 910
910
IV Agrico Chemical, Inc. So. Pierce, Fla. 1640
CF Chemicals, Inc. Bartou, Fla. 1800
CF Chemicals, Inc. plant City, Fla. 1460
1460
GardLnier, Inc. Tampa, Fla. 2370
1460
W.R. Grace Co. Bartow, Fla. 1460
1460
1460
IMC Chemical Corp. Mulberry, Fla. 1800
1800
1800
Occidental Petroleum Corp. Uhlte Springs, 1640
Fl*' 1640
Am. Cyanamld Co. Savannah, Ga. 730
Miasissippl Chemical Corp. Pascagoula, Miaa. 1370
Texasgulf, Inc. Lee Creek, N.C. 1370
1370
(1000)
(1000)
(1800)
(2000)
(1600)
(1600)
(2600)
(1600)
(1600)
(1600)
(1600)
(2000)
(2000)
(2000)
(1800)
(1800)
(800)
(1500)
(1500)
(1500)
Average S02
Emissions
ItftAg of 1002
0.71
1.9
1.11
0.56
0.76
1.26
0.97
0.87
0.16
1.03
1.2
0.73
0.79
0.65
1.62
0.47
1.17
0.48
0.85
0.91
(1.
42)
(3.7)
(2.
(1.
(1.
(2.
(1.
22)
.12)
.52)
52)
.94)
(1.73)
(0.
(2.
(2.
(1.
(1.
(1.
(3.
(0.
.32)
16)
.3)
.45)
.58)
.30)
.23)
.93)
(2.33)
(0.95)
(1.
(1
.70)
.82)

Emission
of 1001
(lb/ton)
0.018
0.062
0.055
0.010
0.058
0.026
0.036
0.030
0.03
0.02
0.07
0.008
0.008
0-.011
0.071
0.064
0.030
0.064
0.023
0.037
Actual Plant Hcasured
B IlK/Hg
H2S04
(.035)
(.123)
(0.
(0.
(0.
(0.
(0.
109)
.021)
.116)
.052)
.071)
(0.061)
(0.
.06)
(.04)
(0.13)
(0,
.016)
(0.016)
(0
.022)
(0.142)
(0.
(0
(0
(0
(0
.127)
.059)
.128)
.046)
.073)
During NSPS During
Test Mg/day Test
IOOZ H2SO4 (TPD) (Percent)
845
808
1629
1781
1562
1277
2424
1616
1547
1535
1643
2457
2366
2503
1756
1641
779
1387
1474
1313
(929) 0
(888) 0
(1790)
(1957)
(1717)
(1403)
(2664) 015
(177O 0<5
(1700)
(1687)
(1805)
(2700)
(2600)
(2750)
(1930)
(1803)
(856)
(1524)
(1620)
(1443)
Reference
19f5ry et
Mlatry et
1975
CDS, 1978
CDS, 1978
CDS, 1978
CDS, 1978
Garrett ,
Garret t ,
CDS, 1978
Uu. 1978
Wu, 1978
CDS. 1978
CDS , 1978
CDS, 1978
CDS, 1978
CDS. 1978
Gardner,
CDS, 1978
CDS, 1978
CDS, 1978
.1..
al. .




1978
1978



;
1
1


1978



        Anlln Corp."
                                Wood River, 111.
                                                                     0.072 (0.144)
        Agrico Chemical. Inc.
        Agrico Chemical, Inc.
        Freeport Chemical Co.
        Rohn i Baas, Inc.
Donaldeonvllle,
 La.
Convent, La.
Deer Park, Tx.
             1640 (1800)
             1640 (1800)
             1460 (1600)
             640 (700)
0.55 (1.10)
0.55 (1.11)
1.0 (1.99)
1.16 (2.32)
0.037 (.073)
0.042 (0.085)
0.08 (0.15)
0.041 (0.082)
1830 (2011)
1677 (1843)
1694 (1862)
 716 (787)
Shonk, 1978
Shonk. 1978
Spruiell, 1978
Sprulell, 1978
                                Helms, Calif.
                                            1640 (1800)
                                                                     0.04 (.07)
                                                                                                        Reynolds, 1978
        Beker Industries, Inc.
        J.R. Slmplot Co.
        Allied Chemical Corp.
Conda, Idaho     770 (850)     1.56 (3.02)       0.053 (0.105)       1001 (1100)
Pocatello, Idaho   810 (900)b    0.53 (1.05)b      0.046 (0.092)b      853 (938)b
Anacortes, Wash.   300 (330)     1.70 (3.41)c      0.04  (0.07)c       222 (244)
'This facility was purchased by shell Oil Co. in 1976; the plant is being modified to incorporate . double absorption process for S02 control.
 Total output of two units.
cAverage of three units.
                                                                        Pfaider, 1978
                                                                        Pfander, 1978
                                                                        Snowden & Alguard,
                                                                        1976
Source:    U.S.  Environmental  Protection  Agency.   1978a.   A review of  standards of
    performance  for new  stationary  sources - sulfuric acid plants.   Prepared by
    Marvin Drabkin  and Kathryn  J.  Brooks,  MITRE  Corp., McLean  VA.   Variously paged,
    80  p.

-------
graphically and indicate a high degree of scatter.  This scatter has been
interpreted to indicate problems in the USEPA Method 8 used since 1971 to
monitor compliance.  If so, the probable effect has been that some SO- results
are low and some acid mist results are high.  Method 8 was revised effective
August 18, 1977 (USEPA 1978a).

     2.1.1.2  Phosphate Rock Processing

     The EID should include operating data for rock processing, which includes
handling, grinding, and storage of the beneficiated phosphate rock.  Table 21
indicates the materials balance for phosphate rock processing.

           Table 21.  Phosphate rock processing materials balance.
           Input Materials                            Waste Streams
 (per unit weight of marketable rock)       (per unit weight of marketable rock)
     •  Phosphate rock - 1 ton/ton         •  Particulates - less than 20 lb/
                         (1 Mg/Mg)              ton (10 kg/Mg)
     •  Cooling water -  8-150 gal/ton     •  Cooling water - 8-150 gal/ton
                         (33-625 1/Mg)          (33-625 1/Mg)
 non-contaminated - temperature increase only in discharge.
SOURCE:  U.S. Environmental Protection Agency.  1974a.  Development document
         limitations guidelines and new source performance standards for the
         basic fertilizer chemicals segment of the fertilizer manufacturing
         point source category; and U.S. Environmental Protection Agency.
         1977b.  Industrial process profiles for environmental use, Chapter 22:
         The phosphate rock and basic fertilizers industry.

     The option to utilize wet grinding does not substantially alter the
information in Table 21.  The small amount of make-up water introduced in the
grinding operation is transferred to the next process and is equivalent to a
slight lowering of the sulfuric acid concentration in the acidualtion operation.
Definitive data on quantities of particulate air emissions generated are not
available.
                                     123

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                -H4 Current EPA NSPS - Sulfuric Acid Plants
                       500       1000       1500      2000
                                Plant Production Rate, TPD
2500
          3000
             Figure  34.   Contact process  sulfuric acid plants,
                   SC>2  emissions.

Source:  U.S.  Environmental Protection  Agency.   1978a.  A  review of standards
   of performance  for  new stationary  sources - sulfuric acid  plants.  Prepared
   by Marvin Drabkin and Kathryn J. Brooks,  MITRE Corporation,  McLean VA.
   Variously paged.
                                     124

-------
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          .12
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 06
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               Current EPA NSPS   Sulfuric Acid Plants"
                         "T

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                                     -=rTH
                                               mtg:
Legend:


O - Region 2


O - Region 4


B   Region 5


Q - Region 6


^ - Region 9


0 - Region 10
                                                               4-1-
                                                               •-*-)•-
                                                     t
                                                               Tttl
                                                               +XX£l!HT
                                                  tttx
                                                                   :±:
            500
                               1000       1500       2000

                                Plant Production Rate, TPD
                                                             2500
                                                                       3000
              Figure 35.  Contact process sulfuric acid plants,

                       acid mist  emissions.


Source:  U.S.  Environmental  Protection Agency.   1978a.  A review of standards

   of performance for new stationary sources  -  sulfuric acid  plants.  Prepared

   by Marvin Drabkin and Kathryn J. Brooks.   MITRE Corporation,  McLean VA.

   Variously paged, 80  p.

-------
     2.1.1.3  Wet Process Phosphoric Acid Production, Concentration, and
              Clarification

     Because of the integrated nature of the phosphate fertilizer processes
downstream of sulfuric acid production, waste streams arising from different
operations are combined for treatment at as few locations as feasible.  Infor-
mation compiled in the Source Assessment:  Phosphate Fertilizer Industry
(USEPA 1979a) is available to characterize combined and component waste streams
for the more than 80% of the industry which operate multi-unit plants.  To
utilize the Source Assessment information, waste stream characteristics are
discussed in reference to integrated processes and treatment.

          Wastewater Characteristics

     Three types of wastewater streams are generated at phosphate fertilizer
plants:

     •  contact process water;
     •  noncontact cooling water;
     •  steam condensate.
Wastewater sources from the integrated wet process phosphoric acid production
including concentration and clarification are:

     (1)  For contact process water -
         •  wet scrubber liquor;
         •  gypsum slurry;
         •  barometric condensers;
         •  acid sludge.
     (2)  For non-contact cooling water -
         •  control of exothermic reaction in dilution of sulfuric acid
            and acidulation of phosphate rock.
     (3)  For steam condensate -
         •  steam jet ejector, vapor condensate from barometric condenser.
          Wet Process Phosphoric Acid Processes

     The EID should include operating data to support projected waste stream
rates.   Table 22 is a materials balance including typical values from the
USEPA Development Document (USEPA 1974a).  Figures 36 and 37 illustrate input
and outflow quantities of materials in the production of wet process phosphoric
acid and superphosphoric acid.
                                    126

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                            t    I
                            IN   OUT
                          COOIINO WATER
                        0 TO 20 m / metric ton P
—5 TO 6 m / metric ton P,0,
                                                          5 TO 6 m3/ metric ton PO
                                                  — AIR STREAM
                                                  — AQUEOUS STREAM
          Figure 36.   Wet process for  production of phosphoric acid.
                               STEAM    _    	
                          CONTAMINATED WATER FROM GYPSUM POND
r —
i
PHOSPHORIC ACID <
_L r S
STEAM Pi 3

CONDENSATE
PUMP SEAL WATER


BAROMETRIC
CONDENSER
-On



i




LI STEAM JET
J EJECTOR
CONCENTRATED
PHOSPHORIC ACID

wtu


CONTAMINATED WATER
8 TO 16x10 m/ metric ton P205
2.2 TO 2.4 m3
                                                              25
          Figure 37.   Production of  superphosphoric  acid.

Source  (Figures 36 and 37):   U.S.  Environmental Protection Agency.  1977a.
   (Preliminary)  Source assessment:  Phosphate fertilizer industry, phosphoric
   acid and  superphosphoric  acid.   Office  of  Research and Development.  Washing-
   ton DC.   Prepared by G.D.  Rawlings, E.A. Mullen, and J.M.  Nyers, Monsanto
   Corporation, Dayton OH,  93 p.
                                      127

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                Table 22.  Phosphoric acid material balance.
          Input Materials
          (per ton PO^)

Acidulation Phase

   •  Phosphate rock (32% avg.
      - 0.96 ton
                                ^,-
                                             Waste Streams
                                             (per ton P0OJ
   •  Sulfuric acid (93% avg. H_SO,)
      - 1.11 ton
   •  Non-contact cooling water
      - 0 to 4,500 gal
       (0 to 19,000 1/Mg)

   •  Contaminated process water
      - 3,800 to 5,000 gal
        (16,400 to 20,800 1/Mg)

Concentration Phase

   •  Contaminated process water
      - 550-570 gal
        (2500-2600 1/Mg)
                                               0 to 4,500 gal
                                               (0 to 19,000 1/Mg)
                                               3,800 to 5,000 gal
                                               (16,400 to 20,800 1/Mg)
                                             - 550-570 gal (+0.2-0.4 gal)
                                               condensate) (2500-2600 1/Mg)

                                          •  Fluorides emissions
                                             - 0.02-0.07 Ib
                                             - 0.60 Ib in poorly controlled
                                               plants

                                          •  Combined gypsum wastes from
                                             first two phases
                                             - 1.36 tons (contains 0.5%
                                               fluorine)
Clarification Phase
   •  Contaminated cooling and wash
      water
      - 165-770 gal
        (690-3200 1/Mg)
                                             - 165-770 gal
                                               (690-3200 1/Mg)
                                     128

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                   Table 22.   Phosphoric acid (concluded).
        Input  Materials
        (per ton PO^)

Superphosphoric Acid Phase

   •  Input  quantities  not available
Waste Streams
(per ton PnOr)
Fluorides
- less than 0.01 Ib. for
  vacuum evaporation process

- 0.12 Ib for submerged com-
  bustion process
SOURCES:   U.S.  Environmental Protection Agency.   1974a.   Development document
          for effluent limitations guidelines and new source performance
          standards for the basic fertilizer chemicals segment of  the fer-
          tilizer manufacturing point source category; U.S.  Environmental
          Protection Agency.  1977a. (Preliminary) Source assessment: Phos-
          phate fertilizer industry, phosphoric  acid and superphosphoric acid,
          Office of Research and Development, Washington DC, U.S.  Environ-
          mental Protection Agency.  1974b.   Background  information for standards
          of  performance:   Phosphate fertilizer  industry, Volume 1, Proposed
          standards; U.S.  Environmental Protection Agency.  1977c.   Final
          guideline document:  Control of fluoride emissions from existing
          phosphate fertilizer plants.
                                    129

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     2.1.1.4  Dry Phosphate Fertilizer Production

     Plants which produce NSP, TSP, and ammonium phosphates have similar waste
stream characteristics.  The wet scrubber liquor is the only process wastewater
stream generated.  Recycled gypsum pond water is used in the scrubber system
to reduce the level of fluoride gases and particulate matter evolved from the
mixer, den, and conveyors at NSP and run of pile TSP plants.  At granular TSP
plants, offgases from the reactor, mixer, dryer, granulator, cooler, and
screens are absorbed in the scrubbing water.   At ammonium phosphate plauts,
wet scrubbers are used primarily for ammonia recovery from the acid neutralizer
and ammoniator-granulator.  Weak (28% PO*^) phosphoric acid is used as the
scrubbing liquor and is recycled back to the ammoniator-granulator.  Secondary
wet scrubber systems are occasionally used to further remove fluorides, particu-
lates, ammonia, and combustion products issuing from the dryer, cooler, and
product screening operations.  This secondary system uses contaminated water
as a scrubber liquor and is therefore a wastewater source (USEPA 1979a).

     The wastewater and air emissions produced in the three solid product
processes are similar, with the addition of ammonia to wastewaters in ammonium
phosphates production.  Since the processes all yield a salable end product
and do not feed into one another, three separate materials balances are given
in Tables 23, 24,, and 25.

     Quantifying data for MAP and DAP ammonium phosphate processes are not
available for feedstocks.  Wastewater streams associated with these conven-
tional processes, estimated in the USEPA Development Document, are given
below:

   Contaminated Water -
         input                               Waste Stream
MAP     - 1200-1500 gal/ton                  - 0-72 gal/ton*
         (5000-6500 1/Mg)                    (0-300 1/Mg)
DAP     - 1200-1500 gal/ton                  - 1200-1500 gal/ton
         (5000-6500 1/Mg)                     (5000-6500 1/Mg)
*
 The fate of the difference in input and waste stream water is not accounted
for.
                                    130

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              Table 23.   Normal superphosphate materials balance.
     Input  Materials                    Waste Streams
     (per ton of NSP)                    (per ton of NSP)

   Phosphate rock (34% avg.  P2°5^

   - 1200 to 1220 Ib
     (600 to 610 kg/Mg)

   Sulfuric acid (100% H2SO,  basis)      •  Fluorine (solid waste or byproduct)

   - 700 to 720 Ib                         - 16 to 20 Ib  (as CaF, from removal
     (350 to 360 kg/Mg)                      in limestone beds)
                                             (8 to 10 kg/Mg)

   Contaminated water (scrubbers)

   - 225 to 250 gal                          - 225 to 250 gal
     (940 to 1040 1/Mg)                        (940 to 1040 1/Mg)
SOURCES:   U.S.  Environmental Protection Agency.   1974a.   Development document
          for effluent limitations guidelines and new source performance
          standards for the basic fertilizer chemicals segment of the ferti-
          lizer manufacturing point source category;  U.S. Environmental Pro-
          tection Agency.   1977b.  Industrial process profiles for environ-
          mental use,  Chapter 22:  The phosphate rock and basic fertilizers
          industry.  Office of Research and Development,  Cincinnati OH.
                                     131

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         Table 24.  Granular triple superphosphate materials balance,
     Input Materials                    Waste streams
     (per ton of GTSP)                  (per ton of GTSP)

   Phosphate rock (34% avg. P^O,-)

   - 840 to 880 Ib
     (420 to 440 kg/Mg)

   Phosphoric acid (53% avg. P^O,.)      •  Fluorine (solid waste or byproduct)

   - 980 to 1020 Ib                        - 20 to 24 Ib (as CaF, from removal
     (490 to 510 kg/Mg)                      in limestone beds)
                                             (10 to 12 kg/Mg)
                                           - emissions of 0.20 to 0.60 Ib are
                                             reported (0.10 to 0.30 kg/Mg)
•  Contaminated water (scrubbers)
  - 158-180 gal                            - 5-10 gal
    (660-750 1/Mg)                            (21-40 1/Mg)
SOURCES:   U.S. Environmental Protection Agency.   1974a.   Development document
          for effluent limitations guidelines and new source performance stan-
          dards  for the basic fertilizer chemicals segment of the fertilizer
          manufacturing point source category;  U.S. Environmental Protection
          Agency.   1977b.   Industrial process profiles for environmental use,
          Chapter  22:   The phosphate rock and basic fertilizers industry.
          Office of Research and Development, Cincinnati OH.
                                    132

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               Table 25.  Ammonium phosphate materials balance
                    (12-48-0-3.6S, MAP sulfate, 3-inch pipe-cross
                    reactor with ammoniator-granulator.
     Input Materials                       Waste Streams
  (per ton of product)                  (per ton of product)

•  Ammonia

   - 293 Ib                                - 2-3 Ib (recoverable in scrubbers)
     (147 kg/Mg)                             (1.0-1.5 kg/Mg)

•  Sulfuric acid (93% H2S04)

   - 228 Ib
     (144 kg/Mg)

•  Phosphoric acid (54% P2°5^

   - 1865 Ib
     (932 kg/Mg)

•  Make-up water

   - 59 Ib
     (30 kg/Mg)

•  Contaminated water (scrubbers)

   - 1200-1430 gal*                        - 1200-1430 gal*
     (5000 - 6000 1/Mg)                      (5000 - 6000 1/Mg)

 Surmised, based on DAP scrubber requirements (USEPA 1979a); quantities may
 be less with pipe-cross reactor.
SOURCES:   Compiled from Parker, B.R., M.M. Norton, and D.G. Salladay.  1977.
          Developments in production of granular NP and NPK fertilizers using
          the pipe and pipe-cross reactor; U.S. Environmental Protection
          Agency.   1979a.  Source assessment:  Phosphate fertilizer industry.
          Office of Research and Development, Washington DC.
                                     133

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     2.1.1.5  Gypsum Pond Characteristics

     The BID should detail the design and capacity of wastewater storage
arrangements.  All contaminated wastewater in new source phosphate fertilizer
facilities will be retained in gypsum ponds or recirculated using cooling
towers.  Use of cooling towers is possible but usually economically imprac-
tical.  Furthermore, meeting the no-discharge requirement becomes extremely
difficult without the freeboard buffer of the gypsum pond and precise water
balance among processes.  More than 90% of the wet process phosphoric acid
plants in the United States use gypsum ponds (TRC 1979).

     Besides being a reservoir and cooling pond, the gypsum pond plays an
integral part in the wastewater treatment scheme.  The pond serves as a set-
tling basin for gypsum and other waste solids.  To function properly and avoid
effluent discharge to surface waters,  the size of the gypsum pond at a wet
process phosphoric acid plant is approximately 2.23 x 10 3 km2/metric ton
P«0j./day.   Gypsum ponds are located adjacent to the plant complex; they are,
in many cases,  abandoned phosphate rock mine pits (USEPA 1979a).

     In most plants, more than one wastewater containment area is available.
As one gypsum pond becomes filled, the gypsum slurry is diverted to another
area and the original pond is dried and excavated into piles (TRC 1979).  In
large ponds used for both cooling and  gypsum settling, the area where gypsum
slurry enters the pond, where most of  the gypsum settles, is known as the
gypsum flats.  Wet gypsum from this area of the pond is removed by draglines
and transferred to an active gypsum pile while clarified gypsum pond water
farther downstream continues to be recycled to the plant (USEPA 1978c).  With
each recycle, the level of dissolved contaminants in the water increases.
After 3 to 5 years of recycle, impurities in the pond waters approach equi-
librium concentrations (USEPA 1978c),  a function of pH and temperature, which
is maintained by volatilization and precipitation of impurities (USEPA 1979a).
The typical ranges of equilibrium concentrations are shown in Table 26 (USEPA
1978c).
                                    134

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       Table 26.  Typical equilibrium composition of gypsum pond water.
     Contaminant

Phosphorus pentoxide,
  equivalent
Fluoride
Sulfate
Calcium
Ammonia
Nitrate
Silica
Aluminum
Iron
PH
Concentration, g/nr
  6,000 to 12,000
  3,000 to 5,000
  2,000 to 4,000
    350 to 1,200
      0 to 100
      0 to 100
       1,600
     100 to 500
      70 to 300
     1.0 to 1.8
SOURCES:  U.S. Environmental Protection Agency.  1978c.  Evaluation of emissions
          and control techniques for reducing fluoride emissions from gypsum
          ponds in the phosphoric acid industry in U.S. Environmental Protection
          Agency.   1979a.  Source assessment:  Phosphate fertilizer industry.
          Office of Research and Development, Washington DC.


     At pH less than 2, it is estimated that 80% of the phosphate present

exists as H-jPO,, the remaining 20% being the anion H2?04 (USEPA 1978c).  The
major equilibrium of fluoride compounds as depicted in a model developed by

Environmental Science and Engineering, Inc., is shown in Figure 38 (USEPA 1978c).
In addition to the predominant compounds fluosilicic acid (H SiF,) and hydrogen

fluoride (HF), small amounts of fluoride will be present in the water as
soluble and insoluble aluminum and iron complexes.  In addition, concentrations
of radium-226 in gypsum pond water reach 60-100 picocuries/liter (USEPA 1974a).
                                    135

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                                        ATMOSPHERE
                            SOLUBLE
                            Fe AND Al
                           COMPLEXES
                                                   H2SiF6>
                                                          SiO,
                          . :(AI,Fe) F, :':;•-•;•/ CaF? •'•;:;>:'v: (Na,K), SiF, :;.".
                          : /       J ;,'.--.:..••'     .•"..'••'.••'     ^   0
                 Figure 38.   Major gypsum pond equilibrium.

Source:   U.S.  Environmental Protection Agency.   1978c.  Evaluation of  emissions
   and control techniques  for reducing fluoride  emissions  from gypsum  ponds in
   the phosphoric acid industry.  Research Triangle Park NC,  218 p.  in USEPA
   1979a.
                                      136

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     2.1.1.6  Solid Waste Characteristics

     There are three sources of solid residue in the phosphate fertilizer
industry (USEPA 1979a):
     •  gypsum from the  filtration of wet process phosphoric acid
     •  wet process phosphoric acid sludge
     •  wet scrubber liquor
The quantity of gypsum produced in a wet process phosphoric acid plant
ranges from 4.6 to 5.2 metric tons of gypsum/metric ton P90,- produced.  As
                                      3
a rule of thumb, approximately 1,360 m  of gypsum will be accumulated yearly
per metric ton of P2°5 Pr°duced per day (Slack 1968).

     A second source of  solid residue is the phosphate rock from which
impurity-bearing minerals settle out of the clarifier to form acid sludges.
Phosphate rock salts which contribute to the formation of acid sludges in-
clude:  fluorine, iron,  aluminum, silicon, sodium, and potassium salts.
Table 27 shows an analysis of solids collected at various stages of wet pro-
cess phosphoric acid production.
              Table 27.   Analysis of solids from wet process
                   phosphoric acid.
Analysis
Solids from
32% P205 acid (feed
to evaporators)
54% P205 acid from
evaporators
54% P20s acid after
storage
Phosphorus
pentoxide
1.9
6.8
38.9
Calcium
14.8
12.9
3.3
Sulfate
38.9
29.0
4.7
Alu-
minum
0.3
5.1
1.5
Iron
0.2
0.3
9.6
Fluo-
rine
19.9
22.0
12.9
Silica
10.3
5.3
6.1
Reprinted from Phosphoric Acid, Volume I, A.V. Slack, Editor, by permission of
Marcel Dekker, Inc.  Year of first publication 1968.
      Fluosilicates, fluorides, silica, cryolite (Na or K)3A1F6), sulfates,
unreacted phosphate rock, and various other combinations of the impurities as
complex salts have been  identified in the acid sludge.  The separated solids
                                     137

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can either be dried and sold as fertilizer or sent to the gypsum pond.
Effluent from the clari
ton P0  (USEPA 1974a).
                                                         3         3
Effluent from the clarification process ranges from 0.7 m  to 3.2 m /metric
     The third source of solid residue wastes is the wet scrubber liquor.
At ammonium phosphate plants, for example, the scrubber liquor going to the
gypsum pond contains about 10 g of solid residue/kg P2°5°  This solid residue
is primarily hydrated silicon oxides (SiO-'xH-O).  Solid residue values for
wet scrubber systems at the other phosphate fertilizer operations are not
available,  but they should be/similar to those for ammonium phosphate plants
(USEPA 1979a).

     Approximately 99% of the solid residue wastes are stored at
phosphate fertilizer plants.   The remaining 1% is sold as a raw
material for various products.   Radioactivity of solid wastes varies depend-
ing on process and type of waste.  For example, phosphate rock product
contains about 42 picocuries per gram (pCi/g) radium-226, whereas by-product
gypsum from acid plants contains 21-33 pCi/g.  Due to the relative solubility
of gypsum,  however, seepage water from gypsum piles can be as high as
90-100 pCi/1.   An Office of  Radiation Programs study has recommended that
moisture control techniques be considered in land disposal of gypsum pile
wastes (USEPA 1977d),  but this  is not current practice.

     Rainfall drainage from the gypsum piles is collected in a ditch and
recycled to the gypsum pond.   A major concern regarding these wastes is the
large amount of land area required to store the gypsum and the unsightly
appearance of the piles of gypsum.

     To date, there are no data specifically to evaluate the potential
effect on groundwater due to leaching from gypsum piles (USEPA 1979a) .  Since
gypsum wastes contain mainly calcium sulfate and lesser quantities of phos-
phates and fluorides,  potential adverse effects may be regionally minimal
(USEPA 1979a), but local contamination can be high.
                                    138

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2.1.2  Environmental Impact of Industry Wastes
     Effluent guidelines were established for four primary factors and
contaminants:
     •  phosphorus
     •  fluorides
     •  suspended solids
     •  pH
Air emission-NSPS were established for:
     •  fluorides
     •  sulfur dioxide
     •  acid mist
These pollutants have been selected for direct control and monitoring because
their harmful environmental effects have been well documented. The EID
applicant should address the expected environmental impacts of these pollutants
based on their magnitude and rates of discharge, and their effects interacting
in the particular environmental setting.
     Other pollutants in wastewater effluents have been identified as
secondary parameters (USEPA 1974a):
     •  ammonia
     •  total dissolved solids
     •  temperature
     •  cadmium
     •  total chromium
     •  zinc
     •  vanadium
     •  arsenic
     •  uranium
     •  radium-226
These pollutants require monitoring, but specific effluent guidelines were not
established because treatment of the primary factors and contaminants will
also effect removal of the secondary, and because data sufficient  to establish
effluent limitations were lacking  (USEPA 1974a).  The applicant's  EID should
identify sources of the above and  any other pollutants, expected discharges,
and effectiveness of treatment techniques.
                                      139

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     2.1.2.1  Human Health Impacts

     The following listings summarize documented effects of primary and
secondary pollutants on human health (USEPA 1974a).

     Fluorides.  Fluorides are rare in natural surface waters, but may occur
in detrimental concentrations in groundwaters.  Ingestion of fluoride com-
pounds can result in:
     •  lowering of tooth decay in children - 0.8 to 1.5 mg/1 fluoride ion
        in drinking water; but,
     •  mottling of tooth enamel in children, in quantities (varying with
        individuals) above 0.9 - 1.0 mg/1;
     •  endemic cumulative fluorosis and skeletal effects in adults, in
        (varying) quantities above 3 or 4 mg/1;
     •  death, or severe symptoms, in doses of 250-450 mg; severe symptoms
        are "diffuse abdominal pain; diarrhea and vomiting; excessive
        salivation, thirst, and perspiration; and painful spasms of the
        limbs" (National Academy of Sciences 1971).

Experts disagree on how much airborne  fluoride is dangerous,  but believe
that levels equivalent to workplace heavy exposure would be required.
Apparently airborne  fluorides are largely retained when ingested, but the
dangers of airborne fluorides include resettling and transport into drinking
water or vegetable food supplies (National Academy of Sciences 1971).

     Total Suspended Solids.  Suspended solids include both organic and
inorganic materials.  The inorganic components include sand, silt, and clay.
The organic fraction includes such materials as grease, oil, tar, animal
and vegetable fats, various fibers, sawdust, hair, and various materials
from sewers.   These solids may settle out rapidly and bottom deposits are
often a mixture of both organic and inorganic solids.  Besides the aesthetic
displeasure associated with turbid waters or with bottom sludges when the
suspended solids settle out, they can cause untreated water to be unpala-
table and:
     •  suspended particles can absorb pesticide and other chemical
        impurities that might not be transported otherwise in the water.
                                    140

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     pH (Acidity/Alkalinity).   pH is a logarithnic expression of the concen-
tration of hydrogen ions.  At pH 7, hydrogen and hydroxyl (OH ) ion con-
centrations in solution are essentially equal and the water is neutral.   Lower
pH values indicate acidity and higher values indicate alkalinity, in a
nonlinear relationship.  Extremes of pH are harmful or fatal to aquatic  life,
but human contact with pH in water is usually avoidable:
     •  a deviation of 0.1 pH unit from 7.0 may result in eye irritation to
        swimmers; appreciable irritation causes severe pain;
     •  by effects on plumbing fixtures, water lines, and water works struc-
        tures, pH below 6.0 can cause high levels of iron, zinc, copper,
        cadmium and lead in drinking water.
     Ammonia and Nitrate Nitrogen.  Ammonia is a common product of the de-
composition of organic matter.  Dead and decaying animals and plants along
with human and animal body wastes account for much of the ammonia entering
the aquatic ecosystem.  Ammonia exists in its non-ionized form only at
higher pH levels and is the most toxic in this state.  The lower the pH, the
more ionized ammonia is formed and its toxicity decreases.  Ammonia, in the
presence of dissolved oxygen, is converted to nitrate (NO^) by nitrifying
bacteria.  Nitrite (NO ) , which is an intermediate product between ammonia
                      2                         ]
and nitrate, sometimes occurs in quantity when depressed  oxygen  conditions
permit.  Ammonia can exist  in several other chemical combinations including
ammonium chloride and other salts.   The following direct  and  indirect stresses
can accrue, to human health:
     •  Sodium nitrate is a poisonous constituent of mineralized waters;
        potassium nitrate is more  poisonous.  Excess nitrates (500 mg
        consumed in one  liter of water) cause irritation:
        - to mucous linings
        - to the gastrointestinal  tract  (symptom  -  diarrhea)
        - to the bladder  (  sympton - diuresis),
     •  Infant methemoglobinemia,  can be  caused by  more than 10 mg/1 (guide-
        line) of nitrate nitrogen  (N03-N)   in water consumed; symptoms  are:
        - blood  disorders
        -  cyanosis, a  bluish  discoloration of  the skin, from inadequate
          blood  oxygenation.
                                    141

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     Total Dissolved Solids (IDS).   In natural waters the dissolved solids
consist mainly of carbonates,  chlorides, sulfates, phosphates, and possibly
nitrates of calcium, magnesium, sodium, and potassium, with traces of iron,
manganese and other substances.  Although IDS levels above 500 mg/1 in
drinking water are progressively unpalatable, levels of:
     •  4,000 mg/1 are unfit for human use, except in hot climates where
        the salt content may be tolerable;
     •  5,000 mg/1 in drinking water causes bladder and intestinal irritation.

     Cadmium.  Cadmium in drinking  water supplies is extremely hazardous to
humans, and conventional treatment, as practiced in the United States, does
not remove it.  Cadmium is cumulative in the liver, kidney, pancreas, and
thyroid of humans and other animals.  Human health effects include:
     0  a severe bone and kidney syndrome reported in Japan, from ingestion
        of as little as 600 mg/day;
     •  as a cumulative toxicant,  cadmium causes insidious chronic poisoning
        in mammals and also fish and probably other animals;
     •  organic compounds of cadmium may cause mutagenic or teratogenic
        (monstrous deformities) effects.

     Chromium.  In its various valence states chromium is hazardous to humans.
The levels of chromate that are completely safe are so low as to prohibit
determination.  Effects of chromium include:
     »  lung tumors, from inhalation;
     •  skin sensitizations;
     9  in large doses,
        - corrosive effects on intestinal tract
        - inflamation of the kidneys.

     Zinc.  Zinc used in industry enters waste streams as both soluble and
and insoluble salts.  The soluble salts in drinking water at levels of 5 mg/1
cause an undesirable taste that persists through conventional treatment. Zinc
can have an adverse effect on man and animals at high concentrations.
                                    142

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     Arsenic.   Arsenic is found to a small extent in nature in the elemental
form.  It occurs mostly as arsenites of metals or as mineral pyrites.  If
ingested, arsenic compounds can be a sudden or a cumulative poison:
     •  100 mg - severe poisoning
     •  130 mg - possibly fatal poisoning
     •  Smaller doses can accumulate and be fatal - arsenic accumulates in
        the body faster than it is excreted.

     Uranium and Radium-226.  Radioactive materials present a host of
hazards through direct exposure or by accumulation in the biological
ecosystem.  "Ionizing radiation, when absorbed in living tissue in quantities
substantially above that of natural background levels, is recognized as in-
jurious.  It is necessary, therefore, to prevent excessive levels of
radiation from reaching any living organism humans, fishes, and invertebrates.
Beyond the obvious fact that radioactive wastes emit ionizing radiation, they
are also similar in many respects to other chemical wastes.  Man's senses
cannot detect radiation unless it is present in massive amounts.

     "Radium-226 is one of the most hazardous radioisotopes of the uranium
decay scheme, when present in water.  The human body preferentially utilizes
radium in lieu of calcium when present in food or drink.  Plants and animals
concentrate radium, leading to a multiplier effect up the food web.

     "Radium-226 decays by alpha emission into radon-222, a radioactive
gas with a half life of 3.8 days.  The decay products of radon-222, in turn,
are particulates which can be absorbed onto respirable particles of dust.
Radon and its decay products has been implicated in an increased incidence
of lung cancer in those workers exposed to high levels (Bureau of Mines, 1971).
Heating or  grinding  of  phosphate rock would liberate radon and its decay
products to the surrounding atmosphere." (USEPA 1974a).

     Guidelines for radiation exposure cannot be defined in terms of threshold
values but it is agreed that exposure to radiation should be held to a minimun
and should be encountered at all only when the necessity is justified.
                                    143

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     2.1.2.2  Ecological and Environmental Impacts


     Phosphorus.  Increases of phosphorus in surface waters have been linked

to a wide range of direct and indirect ecological disruptions.  These include:


     •  proliferation of nuisance water plants;
     •  accelerated eutrophication of water bodies; and
     •  bioaccumulation and toxicity (of elemental P) for marine fish.


The plant overgrowth and eutrophication aspect of the effects of increased
phosphorus availability have specific negative effects:


        dangerous to swimming, boating, and water skiing;
        interferes physically with sport fishing;
        interferes with development of fish populations;
        vile stenches and tastes associated with water;
        ineffectuates standard water treatment processes;
        aesthetic effects
           - reduced resort trade
           - lowered property values;
     •  contact rashes to human skin; and
     •  improved breeding environment for flies.


     Fluorides.   The effects of fluorides on the animal environment are related

to vegetative accumulations and surface water contamination.  Effects include:


     •  chronic fluoride poisoning of livestock when water contains 10-15 mg/1;
     •  shorter term fluoride poisoning of livestock when water ration contains
        30-50 mg/1;
     •  toxicity to fish in concentrations above 1.5 mg/1.


The effects of acute poisoning in livestock include (National Academy of Sciences
1974):
        restlessness
        stiffness
        anorexia
        reduced milk production
        nausea and vomiting
        incontinence of  urine and feces
        necrosis of mucosa of digestive tract
        weakness and severe depression
        cardiac failure
                                    144

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Chronic toxicosis is not always distinguishable from acute symptoms,  but
also results in (National Academy of Sciences 1974):

     •  debilitating osteoarthritis and lameness
     •  dental enamel lesions

Although milk production in livestock is affected, fluoride transfer to the
milk is very slight.  With poultry, however, a greater concentration of
fluoride does show up in the eggs.

     Suspended Solids.  In the aquatic environment suspended solids cause a
number of problems:
     •  turbid waters decrease photosynthetic activity of aquatic plants;
     •  settled solids on stream or lake beds
             - eliminate normal benthic species
             - reduce dissolved oxygen available in the area
             - stimulate populations of benthic sludgeworms and associated
               organisms.
     pH Effects.  Extremes or rapid fluctuations in pH level can create
 problems to aquatic organisms including:
     •  rapid death, and associated rotting of fishkills and generation
        of algal blooms;
     •  increased toxicity of other dissolved substances in the water,
        such as
             - matalocyanide
             - ammonia.
     Ammonia and Nitrate Nitrogen.  In the aquatic ecosystem, ammonia can
 lead to severe impacts:
     •  fish oxygen uptake is impaired and fish suffocate at 1.0 mg/1
        un-ionized ammonia;
     •  direct toxicity on all aquatic life in levels less than 1.0 mg/1
        to 25 mg/1, depending on pH and DO level;
     •  acceleration of eutrophication by supplying nitrogen through
        breakdown  of ammonia.
                                     145

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     Dissolved Solids.  Dissolved solids levels in water affect aquatic
organisms and in general make water troublesome to industrial uses and for
irrigation.  Effects on the ecosystem include:
     •  loss of habitat at 5,000-10,000 mg/1 for species of freshwater fish;
     •  death to freshwater fish when salinity is changed rapidly;
     •  increased toxicity of heavy metals and organic compounds to fish
        and other aquatic life.

     Temperature.  Temperature is one of the most important and influential
ecological water quality characteristics.  Temperature determines those
species that may be present;  it activates the hatching of young, regulates
their activity, and stimulates or suppresses their growth and development;
it attracts, and may kill when the water becomes too hot or becomes chilled
too suddenly.  Colder water generally suppresses development.  Warmer water
generally accelerates activity and may be a primary cause of aquatic plant
nuisances when other environmental factors are suitable.

     Temperature is a prime regulator of natural processes within the water
environment.  It governs physiological functions in organisms and, acting
directly or indirectly in combination with other water quality constituents,
it affects aquatic life with each change.  These effects include chemical
reaction rates, enzymatic functions, molecular movements, and molecular ex-
changes between membranes within and between the physiological systems and
the organs of an animal.
     The specific mechanisms and results of elevated temperature extremes
include:
     •  higher chemical reaction rates;
     «  decreased DO;
     &  increased bacteria production;
     •  spawning perturbations;
     •  increases in predator, parasite, and competing species populations;
     •  fish food alterations;
     •  increased synergistic reactivity of pollutants;
     •  increase in green and blue-green algae and decrease in number and
        distribution of benthic organisms (food chain disruptions) ;
     •  in the presence of sludge, increased gas formation and multiplication
        of saprophytes and fungi.
                                    146

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     Cadmium.   Cadmium pollution problems are derived from direct toxicity
and synergistic actions with other metals.  These include:
     •  acute and chronic poisoning of aquatic and terrestrial species;
     •  Increase synergLstlc  toxicity  of  copper ami zinc;
     •  concentration of cadmium in marine organisms, particularly molluscs.

     Chromium.  The toxicity of chromium salts toward aquatic life varies
widely with the species, temperature, pH, valence of the chromium, and
synergistic or antagonistic effects, especially that of hardness.  Fish
are relatively tolerant of chromium salts, but fish food organisms and other
lower forms of aquatic life are extremely sensitive.  Chromium also inhibits
the growth of algae.

     In some agricultural crops, chromium can cause reduced growth or death
of the crop.  Adverse effects of low concentrations of chromium on corn,
tobacco, and sugar beets have been documented.

     Zinc.  Zinc is most toxic to aquatic organisms in soft water-  Growth
and survival of fresh- and saltwater species have been severely affected:
     •  0.1 to 1.0 mg/1 in soft water is lethal to fish;
     •  presence of copper in the water  increases toxicity;
     •  but presence of calcium or hardness decreases the relative toxicity;
     •  invertebrate marine organisms are very sensitive - 30 pg/1 retards
        growth of the sea urchin;
     •  marine environment problems include long-term sub-lethal  effects of
        metallic compounds;
     0  zinc sulfate is lethal to many plants.

     Vanadium.  Vanadium and its compounds cause physiological disorders in
mammals.  The major concern is for effects in the aquatic ecosystem:
     •  the common bluegill fish can be  killed by 6 ppm in soft water  and by
        55 ppm in hard water;
     •  other  fish are similarly affected.

     Arsenic.   Arsenic ions and compounds can be lethal and  harmful  in both
water and  soil environments.  Typical effects are:
      •  an accumulative  poison in oysters and shellfish;

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     •  arsenic trioxide is extremely harmful to some fish species
        (5.3 mg/1 for 8 days);
     •  arsenic trioxide is lethal to mussels at 16 mg/1 in 3 to 16 days;
     •  certain food crops are made unmarketable grown in water of 1 mg/1;
     •  soils containing 4-12 mg/kg are unproductive.

     Uranium and Radium-226.  The life spans of many animal species are not
long enough to show adverse effects of low level radiation, but radionuclides
tend to be accumulated in the food chain so that the greatest danger from
radionuclides is to species high on the food chain.  The potential effects
for human health, or for economic disaster, are severe when food species
accumulate potentially dangerous levels of radionuclides (resulting in a
ban on production if controls are enforced).  The most significant pathway
to humans is through the accumulative effects on fish and shellfish, or
through drinking water.

2.1.3  Other Impacts
     2.1.3.1  Special Problems in Obtaining, Shipping, Storing, and Handling
              of Raw Materials and Products
     In most instances potential major problems related to shipping, storing,
and handling are well identified and systems are in place or methods available
to keep these problems in check (1.5.2).

     Continuing use of phosphate rock is  assured and any special problems
should be discussed that cause impacts related to the mining area, where
the majority of the phosphate processing  will be conducted.  Phosphate mining
in North Carolina is carried on adjacent  to the Pamlico Estuary, below the
water table.  Cofferdams and pumps are used to expose phosphate deposits
100 feet deep.  Even though the facility  is well managed, eutrophication in
the estuary occurs as the result of phosphate laden pumping waters being
discharged to waters with significant nitrogen levels.  The wastes of phosphoric
acid production also are disposed in this high-water-level environment.
Potential for leaching and for sedimentation and contamination of surface
waters is high, especially in hurricane conditions.
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     In Florida, the significant special problems are related to new mining
areas.  The richer deposits still unmined lie below deeper overburdens and
some deposits are in several layers.  Higher volumes of overburdens must be
moved and replaced.  The effects of this problem on phosphate processing
are less limiting, and the materials can be useful as supplies  of  sands  and
tailings for slime pond dewatering.

     Effects of phosphate production on transportation facilities in new
source industries should be assessed.  Florida, North Carolina, and Gulf
Coast facilities have good access to ocean, barge (river and intracoastal),
pipeline, rail, and truck transportation.  The EID should identify advantages
of alternate transportation modes.  When properly controlled, pipeline and
barge transportation offer both environmental and economic advantages.

     Since most facilities are near mines, stockpiles of phosphate rock are
not necessary.  Facilities that purchase phosphate rock should specify
storage arrangements to prevent particulate air emissions and rainfall
runoff of waters contaminated with phsophorus and TSP.  When wet grinding
is to be used the EID should detail whether storage will be exposed to the
weather and what impacts of fugitive particulate emissions and runoff
waters would be.

     Ammonia and sulfur are normally stored in sealed tanks.  The permit
applicant's EID should address:
     •  administrative measures to deal with a catastrophic release;
     •  clean up and isolation techniques;
     •  collection and treatment systems;
     •  short-term and long-term effects of a spill on the soil and water
        ecosystems;
     •  human health impacts.

     2.1.3.2  Special Problems in Site Preparation and Facility Construction

     The environmental effects of site preparation and construction  of  new
phosphate fertilizer manufacturing facilities are common  to  land  disturbing
activities  on  construction sites in general.  Erosion, dust, noise,  vehicular
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traffic and emissions, and some loss of wildlife habitats are to be expected
and minimized through good construction practices wherever possible.  At
present, however, neither the quantities of the various pollutants resulting
from site preparation and construction nor their effects on the integrity
of aquatic and terrestrial ecosystems have been studied sufficiently to
permit broad generalizations.

     Therefore, in addition to the impact assessment framework provided in
the USEPA document, Environmental Impact Assessment Guidelines for Selected
New Sources Industries, the permit applicant should tailor the conservation
practices to the site under consideration in order to account for and to
protect certain site specific features that warrant special consideration
(e.g., critical habitats, archaeological/historical sites, high quality
streams, or other sensitive areas on the site).  All mitigation/conservation
measures that are proposed should be discussed in the EID.

     Erosion Control During Construction.  The major pollutant at a con-
struction site is loosened soil that finds its way into the adjacent water
bodies as sediment.  Common remedial measures include, but are not
limited to, proper planning at all stages of development and application of
modern control technology to minimize the production of huge loads of sedi-
ment.  Specific control measures include:
     •  the use of paved channels or pipelines to prevent surface erosion;
     •  staging or phasing of clearing, grubbing, and excavation activities
        to avoid high rainfall periods;
     •  the use of storage ponds to serve as sediment traps, where the
        overflow may be carefully controlled;
     •  the use of mulch or seeding immediately following disturbance.

     If the applicant chooses to establish temporary or permanent ground
cover, grasses normally are more valuable than shrubs or trees because of
their extensive root systems that entrap soil.  Grasses may be seeded by
sodding, plugging, or sprigging.  During early growth, grasses should be
supplemented with mulches of wood chips, straw, and jute mats.  Wood fiber
mulch has also been used as an antierosion technique.  The mulch, prepared
commercially from waste wood products, is applied with water in a hydroseeder.
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     Site Selection Factors.  The EID should include information to indicate
the capacity of the soils and geology to accommodate production and waste
storage.   Problems which would require special consideration include:
     •  unstable soils;
     •  steep topography;
     •  presence of wetlands;
     •  location relative to floodplains;
     •  permeability of soils;
     •  erosion problems during construction and operation.

     The applicant is responsible for assessing the effects of the proposed
facility on groundwater quality and quantities.  The areas of particular
relevance to the phosphate manufacturing industry are:
     •  potential and effects of seepage of gypsum pond wastewaters into
        aquifers;
     •  potential for groundwater contamination from storage piles of raw
        materials and waste gypsum;
     •  use of groundwater  for process and make-up water.

     In western states water supply can be a limiting factor.  The EID should
 evaluate effects of water consumption in terms of both groundwater and sur-
 face water supplies in the  region.

 2.1.4  Modeling of Impacts

     The ability to forecast environmental  impacts  accurately  often  is
 improved by the use of mathematical modeling of  the dispersion and dissipa-
 tion of  air and water  pollutants as well as the  effects  of storm runoff.

      Two of the most widely used and  accepted  models are:
      •   DOSAG (and its modifications);
      •   the QUAL series  of  models developed by the  Texas Water Development
         Board and  modified  by Water  Resources  Engineers, Inc.

      Some of the parameters that  these  models  simulate are:
      •  dissolved oxygen
      •  BOD
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     •  temperature
     •  pH
     •  solids
     •  phosphorus
     •  NH3
     •  radioactive materials

     Another model, extensively used in modeling estuaries is:
     •  RECEIV or RECEIV II,  developed by Raytheon for the USEPA Water
        Planning Division.

     The RECEIV models incorporate the salinity parameter.

     In addition, there are many available water quality models that were
developed in association with NPDES activity and the need for optimization
of waste load schemes for an entire river basin.

     There are also available mathematical models that have been used for air
pollution studies and solid waste management optimization:
     •  for short-term dispersion modeling of point sources, EPA's PTMAX,
        PTDIS, and PTMTP models may be employed;
     •  for modeling of long-term concentrations over larger areas, the
        EPA Climatological  Dispersion Model may be used for point and area
        sources.

     The types of models to be used, their design, and the parameters to be
modeled (or monitored for modeling)  will vary in different USEPA regions, State
jurisdictions, and air quality attainment areas.  These details should be agreed
upon between the regulating authority and the applicant early in the permitting
stage.  Even in instances when USEPA issues a "finding of no significant impact,'
and no EID is required, the processing of a PSD construction permit may still re-
quire air quality modeling  and preconstruction monitoring.

     In general, the use of mathematical models is indicated when arithmetic
calculations are too repetitious or too complex.  Their use also simplifies
analysis of systems with intricate interaction of variables.  Models thus
offer a convenient way of describing the behavior of environmental systems.
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                             3.0  POLLUTION CONTROL

     NSPS have been  established  for air and  water  discharges  based on USEPA
surveys and tests  (USEPA 1974a)  of facilities  in  the phosphate subcategory,
40 CFR  418.   These  investigations  include analyses  of  plant  operating data
and sampling of pollutant loadings in wastestreams.  Standards of Performance
are  based  on  determinations  of  efficiency  and attainability  of  pollution
control technology and  process options for existing and new facilities.  New
sources must attain  discharge  levels  which are  indicated as achievable using
the  "best practicable  control  technology currently available" (BPT).  BPT is
largely based  on technology that was  observed in facilities  identified  as
"exemplary plants" in the USEPA study.  "Standards of Performance Technology"
refers to technological  options  which meet the NSPS.   They may be the BPT's
identified  by  USEPA  in  the  development  of  the  NSPS  or  they  may  be
alternatives which meet  the  NSPS by other  techniques.   For wastestreams for
which NSPS  do  not exist, technological  control applications  which represent
the  state of the art are of interest  in the EID.  The permit applicant must
demonstrate that NSPS  will  be met.  The sections  which  follow identify and
describe typical  Standards of  Performance and  state  of  the art technologies
with which NSPS can be met.

3.1  STANDARDS OF PERFORMANCE TECHNOLOGY; END-OF-PROCESS CONTROLS AND EFFECTS
     ON WASTE STREAMS (AIR EMISSIONS)

3.1.1     Dust Control in Raw Materials Handling Operations

     Enclosed  operation  and  baghouses  are  typical  methods  of  control  at
ground  phosphate  rock  unloading  stations.    Satisfactory  control  of dust
emissions from unloading hopper-bottom railroad cars or  trucks is achieved by
the  use  of  flexible  skirts around  bases  of the vehicles  to contain  dust and
flexible-contact  hoods  to  channel emissions  to baghouses,  which realize high
efficiency  in  collection of  this size  particle (60%  to  80%  of the rock  is
less than  74 ym)  (Slack 1968).  Efficiencies are reported to  be greater than
99%  (USEPA  1979a).
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      Feed  hoppers,  storage bins, and  conveyors  are  usually enclosed to reduce
 particulate  emissions  and moisture contamination of  the  rock.  When transport
 of  ground  rock from storage bin  to  feed hopper is accomplished by pneumatic
 conveyors,  a cyclone  separator  and  baghouse are  located at the  destination
 for control  of  the  bulk material and  discharged dust  (USEPA 1979a).

 3.1.2     Control of S00  Emissions from  Contact Process Sulfuric Acid
           Plants

      There are  a few physical mechanisms and many  chemical  means  of removing
 SO- from  gas streams.   Almost any  soluble alkaline  material  will absorb a
 significant  fraction  of  S0«  even  in a  crude  scrubber.   For  years,   sulfur
 dioxide  has been  removed from  many process gases where  the  S0» adversely
 affected the product.  The problems of removing SO- from  acid plant gases are
 principally  that of  finding  the  least  expensive  mechanism consistent with
 minimal  formation  of  undesirable by-products.  The control processes  in use
 by  the sulfuric acid industry  in those units installed since the  promulgation
 of  the NSPS  (see Table 20) are reviewed below (USEPA  1978a).

      3.1.2.1  Double Absorption Process

      The  double absorption  process  (used  partially  as  the  basis  of  the
 rationale  for  the  S02 NSPS) has  become  the SO  control  system of choice by
 the  sulfuric acid  industry  since the promulgation of the NSPS.  This process
 offers the following advantages over other SO- control process:

      •    As opposed to  single absorption with scrubbing, a greater fraction
          of the sulfur in the feed is converted to sulfuric acid.
     •    There are no by-products.
     •    Contact  acid  plant  operators  are  familiar  with  the  operations
          involved.

     The process, described  in Section 1.3.2.1,  builds in a second  absorption
tower to absorb S03 in the  process  gas  and achieves  at  least  99.7% overall
conversion of feed  sulfur to sulfuric acid (USEPA 1978a).  Double  absorption
offers the  following operational  advantages:
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     »    permits  higher  inlet  S02  concentrations  than single  absorption
          (second absorber handles residual  SO  from first conversion step);
     •    higher  inlet  SO   concentrations   allow  reduced  equipment  size
          (partially  offsetting  cost  of  additional absorption  equipment);
     •    spent   acid   or H2S  may  be  used  as  feedstock,  with  appropriate
          convential pretreatment;
     •    no reduction in on-stream production;
     •    needs  no additional manpower.

     3.1.2.2  Sodium Sulfite-Bisulfite  Scrubbing

     Tail  gas scrubbing  systems are  generally applicable to all  classes  of
contact  acid  plants.   They  can  provide  simultaneous  control  of  SO-  and  to
some  extent  SO.,  and  acid mist.  To date  only the  sodium  sulfite-bisulfite
scrubbing  process  has been  demonstrated  to  be capable  of  meeting  the  SO-
limit in  the  most cost  effective  manner.   Other  control  processes  such  as
ammonia  scrubbing  can meet  the  standard, but  costs are  relatively  highly
dependent  on  the  marketability  of  by-products, i.e. , ammonium  sulfate,  for
which there  may  be little demand  (USEPA 1978a).

     In  the Wellman-Power  Gas  process,  the  tail  gases  are  first  passed
through  a mist  eliminator to  reduce  acid mist. Following  mist  removal,  the
SO., is absorbed in a  three-stage absorber with a sodium sulfite solution.   A
sodium bisulfite solution  results  and  is fed  to a heated crystallizer where
sodium sulfite crystals  are  formed  and S02 gas and water vapor are released.
The  crystals  are  separated   from  the mother  liquor and  dissolved  in  the
recovered  condensate for recycle to  the  absorber.    The  recovered  wet SO™ is
sent back  to the acid  plant (USEPA  1978a).

     In  all processes employing sulfite-bisulfite  absorption  even without
regeneration, some portion of  the  sulfite is oxidized to sulfate, from which
the  sulfur  dioxide  cannot be regenerated  in the  heating  sequence.   This
sulfate must  be  purged  from  the system.  In  the  Wellman-Power Gas process,
some  thiosulfate is  also formed.   Apparently  the  extent  of  oxidation  is
dependent on  several factors:
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     •    oxygen content of the gas stream;
     •    the temperature  and residence  time  of the  liquor  in the recovery
          sections;
     •    the presence  of  contaminants that may  act  as oxidation catalysts.

     Despite  the effectiveness  of  the  sodium  sulfite-bisulfite scrubbing
process, none of the sulfuric acid plants installed since the promulgation of
the NSPS have employed  this process for  tail  gas SC>2 control  (USEPA 1978a).

     3.1.2.3  Ammonia Scrubbing

     The ammonia scrubbing  process  uses  anhydrous  ammonia  (NH»)  and  water
make-up in  a two-stage  scrubbing  system to remove SCL  from  acid plant tail
gas.   Excess ammonium  sulfite-bisulfite  solution  is  reacted  with sulfuric
acid  in a   stripper  to  evolve  SO-  gas  and  produce  an ammonium  sulfate
byproduct solution.   The SO  is returned to the acid plant while the solution
is  treated   for  the production  of  fertilizer  grade ammonium  sulfate.   The
process is  dependent  on a suitable  market for ammonium sulfate.  Since the
promulgation of  the NSPS for sulfuric acid plants, one new plant  (two units)
and a new unit added to an existing plant, are employing an ammonia scrubbing
system for tail  gas  S0» emmissions control  (USEPA 1978a).

     3.1.2.4  Molecular Sieve

     This process utilizes  a proprietary molecular sieve system in which SCL
is  absorbed  on  synthetic   zeolites.   The  absorbed  material  is  desorbed  by
purified hot tail gas  from the operating  system and  sent back  to the acid
plant.

     Since the promulgation of the sulfuric acid plant NSPS, one new unit has
incorporated a molecular sieve system for S0? control in the original design.
However, extensive operational difficulties with this system have  caused this
plant  to  be retrofitted  with  a  dual  absorption system  for  S09  control
(USEPA 1978a).
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3-1-3    Control of Acid Mist Emissions from Contact Process Sulfuric Acid
         Plants

     Effective  control  of  stack  gas acid mist  emissions  can  be achieved by
fiber  mist  eliminators  and  electrostatic  precipitators  (ESP's).   Although
ESP's are frequently  used in the purification  section of  spent acid plants,
none are  known to  be in  use in any new sulfuric  acid  plants.  Even though
ESP's have  the  advantage of  operating with  a  lower pressure drop than fiber
mist eliminators  (normally less than 1 inch of HO),  lack of  application of
this equipment  to new  sulfuric acid units is  probably  due  primarily to its
relatively  large size and resultant high installation cost compared to fiber
mist eliminators, and to  the  high maintenance cost  required to  keep the ESP's
operating  within  proper  tolerances  in  the   acid  environment,  which  is
corrosive to the mild steel equipment.

     Fiber  mist   eliminators  utilize   the  mechanisms  of    impact ion  and
interception to capture large to intermediate size  acid mist particles and of
Brownian movement  to  effectively collect micron to submicron size particles.
Fibers  used  may be  chemically  resistant glass  or  fluorocarbon.  Fiber mist
eliminators are available  in  three different configurations (described below)
covering a range of efficiencies required for various plants.

     3.1.3.1  Vertical Tube Mist Eliminators
     Tubular  mist  eliminators  consist  of  a  number  of  vertically oriented
 tubular  fiber elements installed  in parallel in the  top  of  the absorber on
 new acid plants  and  usually installed in a separate tank  above or  beside the
 absorber on  existing plants.   Each element  consists  of  glass fibers packed
 between  two  concentric   316   stainless  steel  screens.    In  an absorber
 installation  the bottom end cover of  the element  is  equipped with a liquid
 seal pot to  prevent  gas bypassing.  A  pool  of acid provides  the seal in the
 separate tank design.   Mist particles collected on  the surface of  the fibers
 become a part of the liquid film  which  wets the fibers.  The liquid film is
 moved  horizontally  through the  fiber  beds  by  the  gas  drag and is  moved
 downward  by   gravity.   The  liquid  overflows  the  seal  pot continuously,
 returning to  the process  (USEPA 1978a).
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     Tubular  mist  eliminators   offer  a  number  of  advantages  and  operate
through a range of operating conditions:

     *  collection method
        - inertial impact ion (particles greater than 3y)
        -  direct  interception   and  Brownian  movement  (smaller particles:)
     •  gas velocity is low (6-12 m/min);
                                                                       3
     •  volumetric  flow  is  28.3 standard  cubic  meters/minute   (sin /min);
        10-100 elements may be used depending on plant size;
     •  pressure drop -  13-38  cm (5-15 in) of water,  higher drop  for higher
        efficiency removing particles less than 3^;
     •  usual efficiency
        - 100%, particles larger than 3y
        - 99.3%, particles smaller than 3y

Because the vertical tube mist eliminator does not depend only upon impaction
for mist removal,  it  can be turned  down  (operated  at a volumetric  flow rate
considerably below design) with no loss in efficiency.  Available information
indicates  that  the vertical  tube  mist  eliminator  is  used  in  the great
majority of  new  sulfuric acid  units  for acid  mist  control  (USEPA  1978a).

     3.1.3.2   Vertical Panel Mist Eliminators
Panel  mist  eliminators  use  fiber  panel  elements  mounted  in a  polygon
framework closed at  the bottom by a slightly conical drain pan equipped with
an acid  seal  pot  to prevent gas bypassing.  The polygon top  is surmounted by
a circular ring which is usually installed in the absorption  tower and welded
to the  inside  of  the absorption tower head.   Each  panel element consists of
glass fibers  packed between  two flat parallel  316  stainless steel screens.
In  large  high velocity  towers,  recent  designs  have  incorporated  double
polygons, one  inside the other,  to  obtain  more bed  area in  a  given tower
cross section  (USEPA 1978a).
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     Operating and efficiency information for vertical panel mist eliminators
follows:

     •  collection method - inertial impaction;
     •  gas velocity is somewhat high (120-150 m/min);
     •  pressure drop - 8 in of water;
     •  efficiency  - 70  mg/m ,   equivalent  to  0-375  Ib/ton of  100%  H SO,.

     These units  are unsatisfactory  for spent  acid plants  but  usually find
application  in  new  dual absorption  plants  for  acid  mist removal  from  the
intermediate absorber in  order to afford corrosion protection for downstream
equipment.

     3.1.3.3  Horizontal Dual Pad Mist Eliminators

     Two circular fluorocarbon fiber beds held by stainless steel screens  are
oriented horizontally in  a  vertical cylindrical  vessel one  above the  other,
so  that  the coarse  fraction of  the  acid mist  is  removed by  the  first  pad
(bottom contactor) and  the  fine fraction by  the other (top contactor).  The
bottom contactor  consists of  two plane  segmented  sections installed  at  an
angle to  the  horizontal to  facilitate drainage  and  give  additional area for
gas  contact.   The assembly  may  be  located  adjacent  to  or  positioned on an
absorption tower.

     This unit uses the high velocity impaction  mist collection mechanism, as
does the  panel  mist  eliminator;  however, the  collected  acid drains downward
through the pads countercurrent to the gas flow,  producing a scrubbing action
as well.  Collected acid may be drained from external  connections or returned
directly to the absorber through liquid seal traps (USEPA  1978a).

     Operating  data for the horizontal dual pad  mist eliminators  are:

     •     collection method - high velocity impaction;
     •     superficial velocity - 2.7-3.0 m/s;
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     •    pressure drop - 23 cm of water  (9 in);
     •    efficiency -  70  mg/m3 (0.375 Ib/ton of  100% I^SOJ  provided  that  a
          particle  size  distribution  shows   that  this  level  can  be  met.
3.1.4  Control of Fluoride Emissions
     3.1.4.1  Spray-Crossflow Packed Bed Scrubber
     The  spray-crossflow packed bed  scrubber has  been accepted for  several
years  as  the  most  satisfactory  fluoride  control   device   available  for
wet-process phosphoric acid plants.  Most wet-process acid  plants built since
1967  probably  have installed  this scrubber as  part  of the original  design.
During  this  same  time,  however, the  spray-crossf low  packed  bed  design has
seen  less general  use  in  processes  other  than wet acid  manufacture.  The
reluctance  of   the  fertilizer  industry fully  to  adopt the  spray-crossf low
packed bed scrubber  can be traced primarily to concern about  its operational
dependability  when treating  effluent  streams  with  a  high solids loading.
Such  effluent  streams  can be handled by placing a  venturi  scrubber  in series
with  and  before a spray-crossflow packed bed scrubber.  Also,  improvements in
spray-crossflow packed scrubber  design have alleviated  the  initial problem of
plugging and allow a greater solids handling capacity (USEPA 1977c).
     The  spray-crossflow packed bed  scrubber consists  of two  sections  - a
spray chamber  and  a packed bed - separated by a series  of  irrigated baffles.
Scrubber  size  will  depend primarily  upon the  volume  of  gas treated.  All
internal  parts  of  the  scrubber  are  constructed  of  corrosion resistant
plastics  or rubber-lined  steel.   Teflon can  be  used  for high  temperature
service.  General  maintenance consists of replacement  of  the  packing  once or
twice a  year.   Both the spray and  the packed section  is  equipped with a gas
inlet.  Effluent  streams  with  relatively  high  fluoride  concentrations  -
particularly those  rich  in silicon tetrafluoride  -  are treated  in the spray
chamber  before  entering the  packing.   This preliminary  scrubbing  removes
silicon  tetrafluoride  thereby reducing  the  danger  of plugging  the bed.  At
the same  time,  it  reduces the loading on the packed  stage and provides some
                                                      H
solids  handling  capacity.   Gases  low  in  silicon  tetrafluoride   can  be
introduced directly to the packed section (USEPA 1977c).
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     The  spray section  accounts for  approximately 40  to 50% of  the  total
length  of the  scrubber.   It  consists of  a series of  countercurrent  spray
manifolds with each pair of spray manifolds  followed by a system of irrigated
baffles.  The  irrigated baffles  remove precipitated  silica  and  prevent the
formation of scale in the spray chamber.
     Packed beds  of  both cocurrent and crossflow design have been tried with
the crossflow design proving to be the more dependable.  The crossflow design
operates  with  the gas  stream moving horizontally  through  the  bed  while the
scrubbing  liquid  flows  vertically through the  packing.   Recycled pond water
is normally used as the scrubbing liquor.
     Typical operating data for spray-crossflow packed bed scrubbers include:
          pressure losses - 1-8 in of water, 4-6 in average;
          efficiency - 98.5 - 99.9% are attainable.
     Table  28  lists  the  levels of  fluoride  control reached  by several wet
acid  plants  tested by  the  USEPA during  the development  of  standards  of
performance.  All plants used a spray-packed bed type scrubber to control the
combined  emissions  from the  reactor,  the  filter,  and  several miscellaneous
sources  and  were  felt  to  represent  the  best  controlled  segment  of  the
industry.   Gypsum  pond  water  was used as the scrubbing  liquid.   Emission
rates ranged from 0.002 to 0.015 pounds flouride (as F)  per ton P«0,_ input to
the process.
Table  28
            .   Scrubber  performance in  wet  process phosphoric  acid  plants.
Plant
  A
  B
  C
  D
             Scrubber design
         spray-cocurrent packed bed
         spray-crossf low packed bed
         spray-crossf low packed bed
         spray-crossf low packed bed
.Average of testing results
 Second series of tests
                                                      Fluoride emmissions
                                                        (Ib F/ton
                                                            0.015
                                                            0.006
                                                         0.002, 0.012
                                                            0.011
Source:  U.S. Environmental Protection Agency.  1977c.  Final guidelines
         document:  Control of fluoride emissions from existing phosphate
         fertilizer plants.  Office of Air and Waste Management; Office of
         Air Quality Planning and Standards.  Research Triangle Park NC, 274 p
                                    161

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     Spray-packed bed  type scrubbers  have  seen only  limited  service in DAP
and GTSP plants and none at all in run of pile TSP plants.  Table 29 presents
performance data, collected  during  the development of performance standards,
for spray-crossflow  packed bed scrubbers treating  effluent  streams  from DAP
and  GTSP  production,  and  GTSP  storage  facilities.   In  most  cases,  a
preliminary scrubber  (venturi  or  cyclonic)  was used to reduce the loading of
other   pollutants   (ammonia   or   solids)    prior  to   treatment   in   the
spray-crossflow  packed  bed  scrubber.   Gypsum  pond  water  was  used  as  the
scrubbing solution except where indicated (USEPA 1977c).

     3.1.4.2  Venturi Scrubbers

     Venturi scrubbers are primarily particulate collection devices, however,
they are  also applicable  to  gas absorption  work  and are  in  widespread use
throughout  the phosphate  fertilizer  industry.   They are  particularly  well
suited  for  treating  effluent  streams  containing  large amounts  of  solids or
silicon  tetrafluoride  because  of   their  high  solids  handling  capacity  and
self-cleaning  characteristics.   Operational reliability  and  low maintenance
requirements  are  major  reasons  for the popularity  of this scrubber design
(USEPA 1977c).

     A  venturi  provides  a  high  degree  of  gas-liquid  mixing,  but  the
relatively short contact time and the concurrent flow of the scrubbing liquid
tend to  limit its absorption  capabilities.  When treating  effluent streams
requiring a high  degree  of fluoride removal, Venturis are  often used as the
initial component in a multiple-scrubber system.

     Two types of venturi  scrubbers, gas actuated and water actuated, are in
general use.   In  both  cases,  the necessary  gas-liquid contacting is obtained
from  velocity  differences between  the  two phases  and  turbulence  in  the
venturi  throat.   Both  types  also   require  the use  of  a  mist elimination
section  for  removal  of  entrained  scrubbing  liquid.   The  major difference
between the designs  is the source of motive  power for operating  the scrubber.
In  the  case  of   the  gas  actuated  venturi,  the velocity  of the  gas stream
provides the energy required for gas-liquid  contacting.  The scrubbing liquid
is introduced  into the  gas stream at the throat of the venturi  and is broken
                                    162

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                          Table 29.   Spray-crossflow packed bed  scrubber performance
                                in  diammonium phosphate and granular triple
                                          superphosphate plants.
 Type of
 facility
             Sources controlled
Primary controls
Secondary controls
                           Fluoride emissions'
                           (lb F/ton P2f>5)
 DAP
 DAP
 TSP
GTSP
• G7SP
Istorane
             reactor, granulator,
             drier, and cooler
             reactor, granulator,
             drier, and cooler
             reactor, qranulator,
             drier, and cooler
             reactor, granulator,
             drier, and cooler
             storage buildina
3 venturi scrubbers
in parallel0
3 venturi  scrubbers
in par-all elb
3 venturi  scrubbers
in parallel
                                       process qases com-
                                       bined and sent to 2
                                       venturi  scrubbers in
                                       parallel followed by
                                       a cyclonic scrubber
3 spray-crossflow
packed bed scrubbers
in parallel

3 spray-crossflow
packed bed scrubbers
in parallel
                                                             I
I 3 spray-crossflow
 packed bed scrubbers
 in parallel

 spray-crossflow
! oacked bed scrubber
                       spray-crossflow
                       packed bed scrubber
                              0.034,  0.029C
                                  0.039
                            0.18, 0.06C
                                                       0.21
                               0.00036C
A/\veraqe of testing results.

^Weak phosphoric acid scrubbing solution.

GSccond series of tests.
          rate is in tenns  of pounds  F  per hour per ton of
                                                               in storage.
 Source-   U S  Environmental Protection Agency.   1977c.   Final guidelines document:   Control of fluoride
    emissions from  existing phosphate fertilizer  plants.   Office of Air and Waste Management; Office of  Air
    Quality Planning  and Standards.  Research  Triangle Park NC, 274 p.

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into fine  droplets  by the accelerating gas stream.  Pressure  drop  across the
scrubber is generally high - from 8 to 20 inches of water.  A  fan is  required
to compensate for this loss in gas stream pressure  (USEPA  1977c).

     In  a  water actuated  venturi,  the  scrubbing  liquid  is  introduced  at  a
high velocity  through a  nozzle located upstream of the venturi throat.   The
velocity of the  water streams is used to pump the  effluent gases through the
venturi.   Drafts of  up to 8 inches of  water can be developed at high  liquid
flow rates (USEPA 1977c).

     The removal of  the  fan from the system  makes the water  acutated  ventui
mechanically simpler,  more reliable, and less costly  than the gas  actuated
type.  An additional advantage is its relative insensitivity to variations in
the  gas  stream flow  rate.   Gas actuated  Venturis rely upon  the  gas  stream
velocity for  the  energy  for gas-liquid contacting,  therefore, variations in
the  gas  flow  can  greatly affect scrubber efficiency.  The performance  of  the
water-actuated venturi depends mainly on the liquid stream velocity.

     Water actuated  Venturis  find application principally as  gas  absorption
units.   Their  use  is usually  limited,  however,  to  small gas  streams  with
moderate scrubbing  requirements.   The water-actuated venturi  is  seldom  used
for gas flows  greater than 5,000 acfm because of the large water requirements
(USEPA 1977c).

     Performance data  are available  for  venturi  scrubbers  installed  in  SPA
and DAP plants.  This information is presented in Table 30.

     3.1.4.3  Spray Tower Scrubber >

     Spray  towers   provide  the  interphase  contacting  necessary   for   gas
absorption by  dispersing  the scrubbing liquid in the gas phase in the form of
a  fine  spray.   Several  types  of  spray  towers  are   in  general   use.   The
simplest consits  of any empty  tower  equipped with liquid  sprays  at the  top
and  a  gas  inlet at the  bottom.   Scrubbing liquid  is  sprayed  into the  gas
stream  and droplets  fall  by  gravity through  an  upward  flow of  gas.    This
design  has the advantages  of  a very low  pressure drop  and  an inexpensive
construction  cost   but   it  can  provide  only  about  one  transfer  unit   for
absorption.  Entrainment  of scrubbing liquid is also a problem (USEPA 1977c).
                                    164

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       Table 30.  Venturi  scrubber  performance  in superphosphoric acid
                         and  diammonium phosphate  plants.
Type of Plant  Sources Controlled
Vacuum evap-   Barometric  conden-
tion SPA
DAP
ser, hotwell, and
product cooling
tank
Reactor, granula-
tor, drier, and
cooler
 1. Average of testing  results
Control   Scrubbing
System     Liquid
Water     Pond
actuated  water
venturi
3 gas     Weak acid
actuated  (20-22% ^
Venturis
in parallel
Fluoride Emissions
  (Ib F/ton P205)
     0.0009
                                                                           1.
       0.129
 Source:  U.S.  Environmental  Protection Agency.   1977c.   Final guidelines
         document:   Control  of  fluoride emissions  from  existing phosphate
         fertilizer  plants.   Office  of Air  and Waste Management; Office of
         Air Quality Planning and Standards.  Research  Triangle Park NC,
         274 p.

     Cyclonic  spray  towers  eliminate the excessive entrainment of scrubbing
 liquid  by  utilizing  centrifugal  force to  remove  entrained  droplets.   A
 tangential  inlet  is used  to  impart  a  spinning  motion to  the  gas stream.
 Water  sprays  are  directed  parallel  to the  gas flow providing crossflow
 contacting of  the  gas and  liquid  streams.  Pressure drops across the scrubber
 ranges  from 2 to  8 inches of  water.  Solids  handling  capacity  is  high,
 however,  absorption  capacity  is   limited to  about two  transfer units  (USEPA
 1977c).

     Fluoride  removal efficiencies ranging from 84 to  95%  have been reported
 for  cyclonic spray towers treating  wet acid  plant effluent gases.  Table 31
 presents  performance  data   obtained  by USEPA   for  cyclonic  spray   towers
 installed  in  wet-process  phosphoric acid,  diammonium  phosphate,  and run of
 pile  triple   superphosphate plants.   In  most   cases,  the  control   system
 consisted of a primary  venturi  scrubber or  cyclonic spray  tower  followed by a
.secondary cyclonic spray tower.   Gypsum  pond water was used  as  the  scrubbing
 solution except where indicated.
                                     165

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             Table  31.   Cyclonic spray tower performance  in wet  process phosphoric acid,
                 diammonium phosphate, and run of pile triple superphosphate plants.
Type of plant
Sources controlled
Primary controls
Secondary controls
:luoride emissions3
 Ib  F/ton P90r)
WPPA


DAP
ROP-TSP
ROP-TSP
reactor, filter, and
miscellaneous sources

reactor, granulator,
drier, and cooler
two-stage cyclonic
spray tower

3 cyclonic spray
tower scrubbers  in
parallel.  Scrub-
bers treating re-
actor-granular
and drier gases
use weak (28-30%
      acid
mixing cone, den,
transfer conveyor,
and storage pile

mixing cone, den,
and storage pile
venturi  scrubber
2 cyclonic spray
tower scrubbers
in parallel
2 cyclonic spray
tower scrubbers  in
parallel  treating
reactor-granulatbr
and drier gases
cyclonic spray tower
scrubber with packed
bed section

2 cyclonic spray tower
scrubbers in parallel
   0.056


   0.380
    0.194,  0.2111
    0.125
^Average of testing  results

^Second series  of tests
Source:  U.S. Environmental  Protection Agency.  1977c.  Final guidelines document:  Control of  fluoride
   emissions'from existing phosphate fertilizer plants.  Office of  Air and Waste Management; Office of
   Air Quality Planning  and  Standards.  Research Triangle Park NC,  274 p.

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3.2  STANDARDS OF PERFORMANCE TECHNOLOGY; IN-PROCESS CONTROLS AND EFFECTS ON
     WASTE STREAMS AND EMMISSIGNS

3.2.1  Sulfuric Acid Plant Effluent Control

     This technology is  a process design modification  which  is  installed  to
prevent  accidental  entry  of  contaminated  water  into  surface  drainage  or
sewage systems.   The  sulfuric acid plant has  no  process water effluent, and
boiler blowdown  is  treated before discharge to the gypsum pond or to surface
waters.   Cooling coils  in  the cooling  tower, are vulnerable to  accidental
break, causing rapid contamination of cooling  water.

     Process Description

     The  process  involves  installation  and operation  of  the  following
facilities:

     •    a reliable pH or conductivity  continuous monitor on either
          - combined non-contaminated plant effluent  stream (preferred),  or
          - cooling tower blowdown stream;
     •    a  retaining  area  along  the  (usually)  non-contaminated  effluent
          stream capable of holding  a 24 hour  normal flow;
     •    a positive cutoff  on the  retaining  area  discharge point, such as a
          concrete abuttment fitted  with a valve.

Optional  features which could be built in are:

     •    lime treatment facilities  at the retaining area;
     •    equipment  for  transferring the acid water  from the retaining area
          to
          - a contaminated holding area, or
          - a recirculation system into  an acid-consuming process.

      When an acid break occurs an  alarm sounds  and the retaining area valve
 is shut  (automatically  is preferable).  The  plant necessarily will  be shut
 down to  locate  and  repair the leak.  The  contaminated water in the retaining

                                     167

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area  can  be treated and  neutralized,  or be transferred  to storage where  it
can be  treated  through  central treating facilities,  or  be recirculated.   If
treatment is performed,  the  standard of performance  is lime treatment,  which
can  raise  pH   and  also  remove  sulfate  by precipitation of  gypsum.   The
required pH standard is at least 6.

3.2.2  Wet Process Phosphoric Acid - Pond Water Dilution of Sulfurlc Acid

     The  need   to  treat  phosphate fertilizer  process contaminated  water is
almost entirely dependent upon the local rainfall/evaporation ratio.  Barring
poor water management and concentrated periods  of heavy rainfall, fresh water
use and pond water  evaporation should be  essentially in  balance.  Any means
of making an in-process  change to reduce significantly  fresh  water use will
create a  negative water  balance.   In turn,  this  will eliminate the need for
treatment of contaminated water and effect  a no discharge condition.

     The  most   effective  way  of  attaining  a  negative  water  balance  is to
utilize contaminated water for dilution of sulfuric  acid.  The  use of fresh
water for this  dilution  step represents approximately 50% of  the total fresh
water  intake  to  a  phosphoric  acid  plant.   Use  of  contaminated  water for
gulfuric acid dilution can:
     •    eliminate water  effluent  from  the  complex  (except  during extreme
          weather conditions);
     «    increase  overall P 0   recovery  by  the  amount   of  ?„(),.  in  the
          contaminated water.
     Two methods for  successfully  using contaminated water  exist.   Both are
proprietary.    One  is  a  trade  secret;  the other  is  protected by  patent.

     The trade  secret  procedure  involves two key points:

          1.    a mechanical  means  to  effect  dilution  without  pluggage  of
               process equipment;
          2.    redesign of  the  phosphoric acid  reactor  cooling  system  to
               remove   the  heat  load  formerly  removed  by  the sulfuric  acid.
               dilution cooler.
                                    168

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     The  patented  process  involves  sulfuric  acid  dilution  by a  two-step
procedure in a manner radically different from current practice.  The details
of  procesi  control,  vessel  design,  and  materials  are  all  proprietary
information.

3.2.3  Ammonium Phosphate Self-Contained Process

     The best means  of  reducing NH -N in the contaminated water system is to
prevent  its  entry   into   the  water.   NH -N enters  the contaminated  water
principally  through the  ammonium phosphate plant  gas  scrubber system.   A
secondary entry point  is  washdown or water  spillage  into  a surface drainage
system.  These  sources  can  be segregated from the gypsum  pond water  system
and  can  be either  introduced  back  into  the process or treated  for ammonia
removal prior to discharge into the gypsum pond.

     One means  of doing  this  is  to  adjust the  in-process  water balance to
permit the absorption of the collected water containing NH_-N.   The  degree of
water balance adjustment  is  dependent upon  the quantity  of  water  in the two
identified  streams.  Reduction  of  these  water  streams  to  a minimum  may
require design changes to maximize scrubber water recirculation.

     The principal  means   of adjusting  the  ammonium  phosphate  process  water
balance is  to increase  the concentration of the phosphoric acid feed used in
the plant.   In conventional processes 30-40% P20,- phosphoric acid is required
to  produce  ammonium phosphates.   It  may  be  necessary   to   increase  this
concentration to  as  high as  54%  P2°5'   This is  dePendent uPon  the  water
quantity to  be  absorbed  and the acid concentration  required  to  produce the
specific ammonium phosphate product.

     The TVA pipe   reactor  and  pipe-cross  reactor  have  been demonstrated
effective in  meeting these  criteria.   54% P^ acid is  used  and  dust-laden
(and fluorine-laden) contaminated water is returned to the product and leaves
the  plant   as   product  (Lee  and  Waggoner  1975).   The  remaining   water  in
scrubber liquor is  flashed off in the  granulator  or stripped  out by airflow
through the cooler.
                                     169

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 3.3 STANDARDS  OF PERFORMANCE TECHNOLOGY;  END-OF-PROCESS CONTROLS AND EFFECTS
 ON WASTE STREAMS (WASTEWATER EFFLUENTS)

 3.3.1   Gypsum  Pond Water Treatment

     The closed-loop contaminated  water stored  in the  gypsum pond must  be
 treated prior  to any discharge necessitated  by  unusually high rainfall  (which
 should be in excess  of  the  local 24-hour 25-year frequency event).   Once the
 storage  area  approaches  capacity   it is  necessary  to begin treating  the
 contaminated  water  for  subsequent  discharge   to natural  drainage bodies.

     Treatment  must  accomplish  NSPS  levels for  phosphorus,  fluorides,  and
 total  suspended  solids  (TSS) .  In most cases pH is also  regulated  through the
 NPDES  permit.    "Double  liming,"  or a  two stage  lime neutralization is  the
 standard  of performance  procedure.

     The  first  treatment  stage  provides sufficient  neutralization to raise
 the  contaminated water  (containing  up to  9000  mg/1 F and up  to 6500 mg/1 P)
 from pH 1-2  to pH 3.5-4.0.  The resultant treatment effectiveness is largely
 dependent on constancy  of the pH control.   At  a pH level of  3.5 to 4.0, the
 fluorides  will  precipitate  principally  as  calcium  fluoride  (CaF  )  by  the
 following reaction:
                H2SiF6 -I- 3CaO -I- H20  — >  3CaF2 + 2H20 + Si02

This  mixture  is held  in  a  quiescent  area to allow  the particulate CaF? to
settle.

     Equipment used for neutralization ranges from crude manual distribution
of  lime  with  localized agitation  to  a  well engineered  lime control system
with  a compartment ed  mixer.  The  quiescent  areas  range  from  a pond  to a
controlled  settling  rate  thickener  or  settler.  The  partially neutralized
water following separation from the CaF2 (pH 3.5-4.0) now contains 30-60 mg/1
F and up to 5500 mg/1  P.   This water is again treated with lime sufficient to
increase the pH  level  to  6.0 or above.  At  this pH level calcium compounds,
                                    170

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of CaF2,  precipitate from solution.  The  primary  reactions  are shown by the
following chemical equation:
                          CaO
                             Ca° + H2°
As before,  this  mixture is retained  in  a quiescent area to allow the CaHPO
and minor amounts of CaF« to settle.


     The  reduction  of  the  P value  is strongly dependent  upon  the  final pH

level,   holding   time,  and   quality  of   the  neutralization  facilities,

particularly mixing  efficiency.   Figure 39 shows a sketch of a well designed

"double lime" treatment facility.


     Laboratory  and  plant  data for response  of  phosphorus  and  fluoride con-
centrations to pH levels are presented below:


            pH       Phosphorus  (mg/1)        Fluoride (mg/1)
                     laboratory  plant     laboratory  plant

            5.5
            6.0
            6.5
            7.0
            7.5
            8.0
            8.5
            9.0
            9.5
           10.0            1.2      1.2       4.6      12.5

Source:  U.S. Environmental Protection Agency.  1974a.  Development document
         for effluent limitations guidelines  and new source performance stan-
         dards for the basic fertilizer chemicals segment of the fertilizer
         manufacturing point source category.  Office of Air and Water Programs.
         Washington DC, 168 p.


     Although the starting concentrations are either arbitrary or specific to

certain plants  tested by  USEPA,  the  data  show that P and  F are  removed in

significant amounts at higher pH.
-
—
—
500
330
200
120
20
3
-
42
24
18
14
12
8
6
3
-
—
—
13
8.5
6.8
5.8
5.2
4.8
17
14
12.5
12.5
12.5
12.5
12.5
12.5
12.5
                                   171

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                                                                ~* — *^
                                                                     ^  L.
P. STEAM
                                                                   HOT WATER

                                                                     TANK
                                                             *   i   r>
                                                             SUMP I—(-
                                                            »     1   2^L
                                                                                n
  MILK OF

    LIME
  STORAGE"—*
  i	i
                                                                                      AE^q
                                                                                      CALCIUM PHOSPHATE
                                                   TO GYPSUM POND
                                                                                            POND
                                                                                          TO RIVER OR

                                                                                          PROCESS UNITS
                                Figure 39.  Pond water treatment system.



Source:  U.S. Environmental Protection Agency.   1974a.  Development document for effluent limitations guide-

   lines and new source performance standards for the basic fertilizer chemicals segment  of  the fertilizer

   manufacturing point source category.  Office of Air and Water Programs.   Washington DC, 168 p.

-------
     Data   from   one  plant  tested   (USEPA   1974a)   show  that  phosphorus
concentrations also  decrease  with time once pH ranges above 5 are met.  When
a 46-hour  holding period  was employed,  the  following values  were  derived:

                         pH             Phosphorus (mg/1)
                         5.8                   20
                         6.5                    9.1
                         8.3                    3.6
     The time effect on phosphorus concentration is:
            Time-hours             ^            Phosphorus (mg/1)
                0                  7.85                  60
                5                  7.6                   29
               22                  6.7                   19
               46                  6.4                    9

     Data from three  years  of double  lime  treatment  of  gypsum pond effluent
from one plant at a pH of 5 to 7 show a phosphorus concentration (as P) of 10
to 40 mg/1.

     Radium-226  is  also  precipitated  by lime treatment  incrementally  with
increasing pH as  presented below  (USEPA 1974a):

                                      Radium-226
                     pH              (picocuries/1)
                     2.0 (sic)            91
                     1.5 (sic)            65
                     4.0                   7.6
                     8.0-8.5               0.04

     Double  liming  is  not  effective  in  controlling NH»-N  in contaminated
water.   This  is   why  the  self-contained  ammonium phosphate  NSPS has  been
established.  There  is  no  acceptable  method  of  economically removing NH^-N
from aqueous  solutions  as  weak  as 20-60  mg/1.   It is instead most important
to keep NH^-N from entering the  contaminated water system.
                                    173

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3.3.2  Gypsum Pond  Water Seepage Control

     The contaminated  (gypsum  pond)  water storage  areas are  surrounded by
dikes except when mining pits are used.  The base of these dikes are normally
natural soil from  the  immediate surroundings.  When height  of  the retaining
dikes must  be  increased, gypsum from  inside  the diked area  is  added to the
top of  the  earthen base.   Dikes in Florida now extend 100-120 ft in vertical
height and  tend to  have continual seepage of contaminated water through them.
To prevent   this  seepage  from reaching natural drainage streams, it should be
collected and returned  to the pond.

     Figures  40 and 41 illustrate the  design and use of  a seepage collection
ditch  around  the  perimeter  of the   diked  area.    The   ditch  should  be of
sufficient  depth and size to collect contaminated water seepage and to permit
collection  of seepage surface water from the immediate outer perimeter.   This
is accomplished  by erection  of  a  small secondary dike.   The secondary  dike
also  serves  as a  back-up  or reserve  dike  in the  event  of a  failure of the
major dike.

     The design  of the  seepage  ditch  in  respect  to  distance  from the  main
impounding   dike  and  depth  is a  function of  the geology  of the  area  and the
type  material  used for  the dike.   Some  data  suggest that  the  gypsum  pond
bottoms tend to be  self-sealing  (Wissa 1977).   That is, compacted gypsum  plus
clay  fines  and aluminum and iron  silicates  forced  into  the  interstices may
form  an artificial "cement"  like  layer on  the bottom  of old  gypsum ponds
which  is both  acid resistant and of very low permeability.  In the design of
gypsum  ponds and. ditches the applicant must consider the area geology and the
phreatic water  level of  the impounding dike material  to  achieve an effective
seepage  control  system.   Water  table  aquifers,  and  conceivably  deeper
aquifers,  have  been contaminated  in  the vicinity  of  ponds  (TRC 1979).  An
installation of  a  pump  station at  the low or collection  point of the seepage
ditch  is  an essential  part of  the  seepage  control  system.   (USEPA 1974a).

3.3.3   Other End-of-Process Controls

      It  is   reportedly   possible   for  a  fertilizer  plant  to  meet   the
no-discharge  criterion without  the  use  of  gypsum  ponds  for  storage.   One
                                    174

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                 SLOPE NO GREATER
                     THAN 2:1
                              MINIMUM 6 m
                                       _     FREEBOARD,
                                             MINIMUM 1.5m
                                             I
   DRAINAGE
    DITCH
            OUTSIDE TOE

                  BERM\
                                            WATER LEVEL    SLOPE N0 GREATER THAN 2:1
                                                     ,-INSIDE TOE
                                                    JBERM 8 m MINIMUM
                                                          \ BORROW PIT
                                             MINIMUM DEPTH 1 m

      Figure  40.   Recommended minimum cross  section of dam.

Reprinted from Phosphoric Acid, Volume  I,  A.V.  Slack, Editor, by permission of
Marcel Dekker,  Inc.,  Year of first publication  1968.
         GYPSUM POND
GYPSUM POND ' ^ x-'X'"'^Sv;
    BED         ^ \  $'j
                           SEEPAGE DITCH
                           RETURN TO GYPSUM  /-
                           POND BY PUMP
                                                            OUTSIDE OF PLANT
                                                                  A	
                                     SECONDARY ;.
                                        DIKE
          SEEPAGE ^ \* s^
                                               -APPROXIMATELY
                                                3m WIDE BY
                                                ABOUT 1 m DEEP
                                                               Ji;
         *?^\
^.^.'YS^^ff'f^'   ^
XX!^2^     SEEPAGE
   SEEPAGE
    DITCH
                                                             SURFACE DRAINAGE
                                                             DITCH EXTERNAL TO
                                                             THE PLANT
           Figure  41.   Gypsum pond water  seepage  control.
Source:  Environmental Protection Agency.   1974a.  Development document for efflu-
   ent limitations  guidelines and new  source performance standards for the basic
   fertilizer chemicals segment of  the fertilizer manufacturing point source
   category.  Office of Air and Water  Programs,  Washington DC, 168 p. in USEPA
   1979a.
                                     175

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plant along the Houston Ship  Channel in Texas  has  claimed success by use of
process modifications  tailored  to its  operation (Mabrey  1978).   This plant
operates  on a  relatively  small  sight  and  previously  took  advantage  of
once-through channel  water (10,000-12,000  gpm) to  cool  the  evaporator and
barometric  condenser,  and  to  supply scrubber water  for the  phosphoric acid
and  fertilizer  product  reactors  and  for  the dryer  gas.   The  water  was
neutralized with lime,  clarified, and discharged.

     To meet Texas Water Quality Board and NPDES permit requirements,  zero
discharge (as  of March  1978) had been maintained.  The plant continues to use
cooling towers  to cool and recirculate contaminated water.  The key to using
the  towers  successfully has  been  to  control  fluoride  emissions from  the
phosphate  fertilizer  processes   contaminated wastwater, with  pH  of  1-3  and
fluoride concentrations of 4000-5000 ppm at equilibrium (Mabrey 1978).  NSPS
fluoride emission  levels reportedly have been achieved by  adjusting the ratio
of  fluoride to silica in a  company  classified procedure.    Meanwhile,  to
prevent  discharge  of   contaminated  runoff  water   from  the   piles  due  to
rainfall,  the  plant has  constructed  retaining ponds  on top  of  stabilized
gypsum piles.    The retaining  procedure has not been thoroughly proven and is
not  a  typical requirement.  It  was required due to  run off containing NH~-N
contamination  from existing gypsum  piles caused by  wastes from non-phosphate
fertilizer  processes  also performed at  the plant  described  (Mabrey 1978).

3.4  STATE OF  THE ART TECHNOLOGY; END-OF-PROCESS CONTROLS  AND EFFECTS ON
     WASTE STREAMS (SOLID  WASTE)

     The quantity of waste gypsum produced  in  a wet process phosphoric acid
plant  ranges  from  4.6 to 5.2  metric  tons  gypsum/metric ton  P00  produced
                                      0                           / J
(Slack  1968).   Approximately  1,360  m  of gypsum will be  accumulated yearly
                                                           2
per  metric  ton  of  P20   produced per  day;  at least  2,230  m  of land area per
daily metric ton  P^  should  be reserved  for  gypsum disposal  (USEPA 1979a).

     In  the United  States and  other  locations  three disposal practices are
currently  used:  gypsum  ponds  and  piles,  abandoned  mine  pits,  and sea
disposal (USEPA 1979a).
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3.4.1  Disposal in Gypsum Ponds and Piles

     In  the  United States  more than 90%  of  the  phosphate fertilizer plants
use  gypsum  ponds  to  collect the  slurry.   Initially, two  or  more areas are
converted to  lagoons  by means of  low dikes provided with proper outfalls for
potential effluent discharge.   As one area becomes filled, the gypsum stream
is diverted  to  the second area,  and  the first section is allowed to dry out
sufficiently  to  support mechanical equipment.  The dike is then increased in
height,  using deposited gypsum as the source  of  material,  and the procedure
is repeated.  An alternative is the use  of draglines to stack wet gypsum from
the  gypsum  flats  area of  the  pond onto  an   active  gypsum  pile to  dry
(USEPA 1978c).   Existing gypsum  piles  range  in  height  from 30  m to  36  m
(100-120 ft)  (USEPA 1979a).

     In  the western states where poor land stability or availability prevents
the  use  of  gypsum  ponds, gypsum  cake  from the vacuum filters is transported
by conveyor to gypsum stacks (USEPA 1979a).

3.4.2  Disposal in Abandoned Mine Pits

     This disposal technique is practiced primarily  in Florida.   Instead of
constructing gypsum ponds, abandoned phosphate rock surface mines are used as
gypsum ponds and for other solid residue disposal.  A potential environmental
hazard from this disposal technique is the possible leaching of fluorides and
phosphates  into the   groundwater system.   Because the  mined-out pits  are
closer  to subsurface  aquifers,  their  potential  for adverse  environmental
effects  is  greater  than that  of  the  surface  gypsum ponds  (USEPA  1979a).

3.4.3  Disposal in  Sea Outfalls

     This  disposal  technique,  used  by  less  than  2%  of  the  phosphate
fertilizer plants  in  the United  States,  but more  widely used  throughout
Europe,  is  practiced  at  plants located  in coastal areas.   Gypsum is pumped
into  the ocean  or,   in a  few cases, discharged  into major  rivers.   After
removal  from  the vacuum filter, the gypsum  is slurried  with about a tenfold
quantity of  seawater or cooling water (Slack 1968, USEPA 1979a).
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     Seawater  is  a  better  solvent  for  gypsum  than  fresh  water.    The
solubility  of  gypsum in seawater  is  about 3.5 g/1 as  compared  to about  2.3
g/1 in fresh water.  The solids content of the gypsum slurry is below  5%,  low
enough for quick dispersion and dissolution in ocean water  (Slack  1968,  USEPA
1979a).

3.4.4  Resource Recovery

          Soil Treatment
     In  1975,   approximately  30  x  10   metric  tons  of  gypsum  waste were
generated by  the phosphate  fertilizer industry.  Of  this  total,  about 90 x
10  metric tons were applied to calcium-deficient soil  in the southern  states
for peanut growing.   Gypsum was also used for improvement of alkali soils in
California and for land reclamation in coastal areas.   It conditions the soil
and causes sodium  chloride  to leach out  faster  (USEPA 1979a).  Since  gypsum
waste  contains  varying quantities  of  phosphoric acid, it also  serves as a
light fertilizer.

     Wallboard Problems
     Waste  gypsum  has been  used  for  wallboard.   In  the  United States, the
dihydrate process for phosphoric acid production produces a gypsum waste high
in phosphoric  acid,  which results in poor quality wallboard.  Also, there is
some concern  about the  possible  low-level  radiation effects from wallboard
made of uranium- and radon-containing gypsum wastes.

     In  Europe .id  Japan,   where  the  hemihydrate  process is  more commonly
used,  the  resulting gypsum  waste is  purer,  containing less phosphoric acid
and uranium.   More  of  this  gypsum waste  is  used for wallboard.  In England,
where  only  the standard dihydrate  process  is  used,  special  purification
methods  make  the  by-product suitable  for  wallboard.   This purification step
is more  economically  feasible  in England  than in  the United States, because
aatural  (and  purer) gypsum  is  not  as  abundant in  England  as  it  is in the
United States  (USEPA 1979a).
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     Cement Supplement Problems

     Another possible  use  for  gypsum is in cement  and  other road toppings.
However, the  phosphoric acid  and other phosphates  retard  setting and lower
the strength  of the  hardened  body.  Fluorine  compounds  reduce setting time
and lower  the  concrete strength, but these effects are small compared to the
effects of  phosphate contamination.  In Florida,  there  are further concerns
over public  exposure  to  low level  radiation  from  road  surfaces  containing
gypsum  wastes  or from road base material  containing phosphate  rock mining
overburden (USEPA 1979a).

     Ammonia and C02 Treatment

     Gypsum can  be  reacted with ammonia and carbon  dioxide to form ammonium
sulfate  and  calcium  carbonate.   This  is  an  old  and   well-known  practice
applied to natural  gypsum, but there has been  relatively little  application
to by-product gypsum.  Only a few plants in India, Japan, and Europe use this
technology (USEPA 1979a).

Silica Thermal Treatment

     Another potential resource recovery method is treating by-product gypsum
with silica  at high  temperatures to produce  sulfuric acid.  The  additional
product of calcium silicate could be used for cement.  Although the method is
technically feasible,  the  high water content of gypsum,  the corrosive effect
of  fluorides,  and  the  adverse  effect of P?°c content on cement  quality  are
all major  drawbacks.  Also, due  to the price and availability of sulfur in
the United  States,   this  technology is  not  yet  economically feasible (USEPA
1979a).

3.5  POLLUTION CONTROL RECOMMENDATIONS EXCERPTED FROM THE CENTRAL FLORIDA
     PHOSPHATE INDUSTRY FINAL AREAWIDE ENVIRONMENTAL IMPACT STATEMENT

     The recently  published Areawide EIS  for  the central  Florida phosphate
industry  lists  several  recommended  practices  which  are  anticipated  to be
required  for  new source phosphate  fertilizer facilities  in central Florida.

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Because of  the concentration  of  the  industry  in that  area,  and because of

their   potential   relevance   to    future   policy   determinations,   the

recommendations are  included below.  These  recommendations  are included for

information only, and are  not  to  be taken as final policy.  The applicant is

advised to coordinate the  scope of  the EID with the regional USEPA officials

in all cases,  prior to starting work.


     USEPA Region IV Phosphate Fertilizer Facility Recommendations


     •  Meet Federal air quality new source performance standards and design
        surge  capacity in the USEPA  Standards of Performance for New Sources
        for process water systems.

     •  Line gyp ponds  with an impervious material unless it can be demon-
        strated in the site-specific EIS that such lining is unnecessary in
        protecting ground water from chemical and radiological contamination.

     •  Recirculate process and non-process water.  The non-process system
        should have the  same design  surge capacity as required in the
        Standards  of Performance for New Sources for process water systems.

     •  Provide for recovery of fluorine compounds from phosphoric-acid
        evaporators unless  it is determined at the time of permit application
        that market conditions  are such that the cost of operation (not
        including  amortization  of  initial capital cost) of the recovery
        process exceeds  the market value of the product.  If there is an
        exception, the site-specific EIS is to contain an estimate of
        pond-water fluoride concentrations to be attained and levels of
        fluorine emission.   Estimated fluorine emissions from new source gyp
        ponds  should not cause  the plant complex to exceed the total
        allowable  point  source  fluorine emissions within the plant complex if
        a  permit is to be issued.

     •  Encourage  recovery  of uranium based on economic feasibility data
        to be  included in the site-specific EIS.

            Shortened  term:   gypsum  ponds.

Source: U.S.  Environmental Protection Agency.  1978q.   Final areawide
        environmental impact statement, Central Florida phosphate industry,
        Volume 1.  EPA  904/9-78-26a.   Atlanta GA, 80 p.
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                        4.0  OTHER CONTROLLABLE IMPACTS
4.1  AESTHETICS


     New source phosphate facilities may involve large and complex operations

occupying hundreds of acres.  Rock storage and handling areas, haul roads,

rock conveyors, and slurry pipelines, gypsum ponds and piles, dust, erosion,

and sediment-laden streams are aesthetically displeasing to many.   Particularly

in rural and suburban areas, phosphate fertilizer manufacturing (and possible

associated mining activity) can represent a noticeable intrusion on the land-

scape.  Measures to minimize the impact on the enviornment must be developed

during site selection, plant planning design, and reclamation. The applicant

should consider the following factors where feasible to reduce potential

aesthetic impacts:
     •  Existing Nature of the Area.  The  topography and major  land   uses  in
        the area of the candidate sites are important.  Topographic conditions,
        and existing trees and vegetation visual barriers can be used to screen
        the operation  from  view.   A lack of topographic relief and vegetation
        would require  other  means  of minimizing impact, such  as regrading  or
        planting of vegetation buffers;

     •  Proximity of Parks and Other Areas Where People Congregate for
        Recreation and Other Activities.   The  location of  public use  areas
        should  be  mapped and  presented  in the  EID.   Representative  views
        of the  plant site  from observation points  should  be  described.   The
        visual  effects on  these  recreational  areas  should be  described  in
        the  EID  in order  to  develop  the  appropriate mitigation  measures;

     •  Transportation System.  The  visual  impact  of new  access  roads,  rail
        lines, haul  roads,  barge  docking,  pipelines,  and  storage facilities,
        the landscape or waterfront should be considered.  Locations, construc-
        tion  methods  and materials,  and  maintenance  should  be specified.

4.2  NOISE
     The major sources of noise associated with phosphate fertilizer manu-
facturing include:
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     •  Plant construction equipment (bulldozers, graders).
     •  Rock  transport  systems   (haul  roads,  conveyors,   pipelines,  loading
        dozers).
     •  Rock grinding and  handling.
     •  Boilers  and steam  venting.
     •  Product  transport  systems (truck,  railroad and barge loading).
     •  Land reclamation/grading equipment.
     These activities can  create significant ambient noise levels that may
decrease with increasing distance from the site.  Noise can be attenuated
effectively with thick stands of vegetation or other barriers.  Even at dis-
tances of 1,500  to 2,000 feet the increases  in noise levels due to manufac-
turing activities still may be noticeable.  Noise receptors within a half mile
of the source are the most pertinent for most facilities and should be documented
in the EID.

     Noise also  can create serious health hazards for exposed workers;
therefore, the necessary source and  operational control methods should be
employed.   Such measures  include:

     •  Enclosed process machinery.
     •  Mufflers on engines.
     •  Lined ducts.
     •  Partial  barriers.
     •  Vibration insulation.
     •  Imposed  speed limits  on vehicles.
     •  Scheduled equipment operations and maintenance.
     A suitable  methodology to evaluate noise generated from a proposed new
source facility  would require the applicant  to:

 USEPA has recommended a 75-dBA,  8-hour exposure level to protect from loss
 of hearing, and a 55-dBA  background exposure level to protect from
 annoyance of outdoor activity.
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     •  Identify all noise-sensitive land uses and activities adjoining
        the proposed plant site.

     •  Measure the existing ambient noise levels of the areas adjoining
        the site.

     •  Identify existing noise sources, such as traffic, aircraft fly-
        over, existing mining and other industry, in the general area.

     •  Determine whether there are any State of local noise regulations
        that apply to the site.

     •  Calculate the noise level of the manufacturing processes, compare
        that value with the existing area noise levels and the applicable
        noise regulations.

     »  Assess the impact of the operation's noise and, if required, determine
        noise abatement measures to minimize the impact (quieter equipment,
        noise barriers, improved maintenance schedules, etc.)

4.3  ENERGY SUPPLY


     Cogeneration in industrial processes denotes any form of the simultaneous

production of electrical or mechanical energy and useful thermal energy (usually

in the form of hot liquids or gases) (USDOE 1978).


     The permit applicant should evaluate the energy efficiencies and demands

of all methods considered during project planning in the context of an alter-

native analysis.  Also, feasible design modifications should be considered in

order to reduce energy needs.


     At a minimum, the applicant should provide the following information in

the BID:


     •  Total external energy demand for operation of the mine.

     •  Total energy generated on site.

     «  Energy requirements by type.

     •  Source of energy off-site.

     ®  Proposed measures to conserve or reduce energy demand
        and to increase efficiency of mine operation.
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4.3.1  Cogeneration

     Phosphate complexes which produce sulfuric acid on site obtain, due to
the exothermic combustion and absorption reactions, a net yield of energy in
the form of moderate pressure steam.  This steam is usually used to generate
the major on-site electrical energy requirements.  After generation of elec-
tricity, process steam amounts to about 1,900,000 Btu per ton of 100% sulfuric
acid (Blouin 1975).  Highly integrated complexes which produce wet process
phosphoric acid, SPA, and/or conventional process granulated fertilizer products
may consume this energy for steam ejectors, vacuum evaporators, dryers, or
steam powered machinery.  The EID should indicate the power demands of pro-
cesses to be used and assess potential for excess steam capacity for cogenera-
tion of marketable electric power.  Process options,  such as melt-type ammoniator-
granulators should be considered in view of the potential for converting
energy savings from unneeded dryers into power generation.  The Public Utility
Regulatory Policies Act of 1979 provides for Federal Energy Regulatory Commission
rules favoring cogeneration facilities, and requiring utilities to buy or sell
power from qualified cogenerators at just and reasonable rates.

4.3.2  Energy Consumption and Conservation

     In 1976 the energy consumption in the U. S. was about 74 x 10   Btu
(quads) per year.  The U. S.  Federal Energy Administration and U. S. Department
of Agriculture estimated the energy consumption in fertilizer production to be
0.621 quad per year.  Blouin and Davis' estimate for the chemical fertilizer
industry energy consumption was 0.522 quad per year.   Thus 0.7 - 0.8% of the
nation's energy goes for fertilizer production.  Table 32 indicates that
roughly 68% of that energy consumption is to for ammonia production, and about
12% for phosphate fertilizer.

     Although the phosphate fertilizer industry accounts for a small portion
of total energy consumption,  energy conservation practices are of benefit to
the producer,  the regional energy supply, and the U.S. economy.
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             Table 32.  Energy for fertilizer nutrient production.3


          Nutrient                               Energy requirement,

                                                   Btu's per pound


          N                                             28,000

          P2°5                                           5,000
          K20                                            4,000

          S                                              4,OOOb'C
a.  Source:  White, Bill.  1977.  Fertilizer cost trends - energy,  environment,
             transportation.  Fertilizer Progress, Volume 8.  January-February
             1977 in Barber 1978a.

b.  Energy for Frasch mined sulfur

c.  Source:  Blouin, Glenn M. and Charles H. Davis.  1975.  Energy require-
             ments for the production and distribution of chemical fertilizers
             in the U.S.  Energy and Agriculture, Proceedings of a workshop.
             Southern Regional Educational Board.  Atlanta GA, p. 51-67 in
             Barber 1978a.
     Conservation practices applicable to the phosphate fertilizer industry
are described below (Barber 1978a):
     •  Wet grinding of phosphate rock instead of dry grinding conserves
        energy.   Phosphate drying consumes energy and results in the dis-
        charge of particulates and operation of abatement equipment.

     •  Melt-type granulation processes eliminate drying of granulated
        fertilizer.   Energy is conserved by eliminating the drying step
        and by decreasing the volume of air to be treated for air
        pollution control.

     •  Emission of  dust from granulation processes is reduced by making
        strong granules.  Formation of particulates from handling is held
        to a minimum and dust control simplified.

     •  The pipe reactor installed in ammoniator-granulators eliminates
        formation of small particulates and reduces the volume of gas to
        be treated.   Otherwise, high pressure drop scrubbers (about 50
        inches of water) are necessary to meet air emission standards.
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     •  Particulate collecting systems are designed to provide optimum
        dust pickup and transport velocities.   Long and complicated ducts
        give rise to duct stoppages or expenditure of excessive energy
        to transport dust at high enough velocity to prevent stoppages.

     •  Baghouse collectors  are used instead of scrubbers  for particulate
        collection when the  particulates have  low hygroscopicity and the
        gas temperature does not exceed the limit for fabric filters.   Bag-
        house collectors consume less energy than scrubbers unless gases
        have to be heated to overcome the hygroscopicity problem.   When
        the gases have to be heated, energy for baghouses  and scrubbers
        is about the same.

     •  Effluent from granulation processes may be reused  in the process or
        the effluent may be  sold as a fluid fertilizer.   This saves energy
        for nutrient production and eliminates a waste treatment facility.

In addition, well planned siting of the fertilizer plant can greatly affect

net energy consumption of the operations.   The amount of energy consumed in
transportation by the four major transportation modes is shown below in Btu's/

ton-mile (Achorn & Kimbrough 1978) :


                             Pipeline        450
                             Barge          500
                             Rail            700
                             Truck       2,500-2800

These data indicate that to  conserve energy, the applicant should use  pipe-
line, barge, and perhaps rail as much as possible, and avoid truck trans-
portation.


     Finally, uranium production, which can have significant effects on energy

supply, should be considered.  This practice can help toward making phosphate
fertilizer manufacturing a net producer rather than consumer of energy.


4.4  SOCIOECONOMICS


     The introduction of a large new phosphate fertilizer  facility into a

community may cause land use, economic, and social changes.  Therefore,  it is

necessary for an applicant to understand the types of impacts or changes that

may occur so that they can be evaluated adequately.  The importance of these

changes usually depends on the size of the existing community where the facility

is located.  The significance of the changes caused by a facility of a given
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size normally will be greater near a small rural community than near a large
urban area.  This generally is due to the fact that a small rural community is
likely to have a nonmanufacturing economic base and a lower per capita income,
fewer social groups, a more limited socioeconomic infrastructure, and fewer
leisure pursuits than a large urban area.  There are situations, however, in
which the changes in a small community may not be significant, and conversely,
in which they may be considerable in an urban area.  For example, a small
community may have had a manufacturing (or natural resource) economic base
that has declined.  As a result, such a community may have a high incidence of
unemployment in a skilled labor force and a surplus of housing.  Conversely, a
rapidly growing urban area may be severely strained to provide the labor force
and services required for a new phosphate facility.

     The rate at which changes occur (regardless of the circumstances) also is
often an important determinant of the significance of the changes.  The appli-
cant should distinguish clearly between those changes occasioned by the construc-
tion of the facility, and those resulting from its operation. The former
changes could be substantial but usually are temporary; the latter may or may
not be substantial, but normally are more permanent in nature.  The potential
impacts which should be evaluated include:

        Increased consumption and rate of land development.
        Land use pattern and compatibility changes.
        Economic base multiplier effects.
        Population size and composition changes.
        Increased labor force participation and lower unemployment rates.
        Increased vehicular traffic and congestion.
        Loss of prime agricultural land and environmentally sensitive areas.
        Increased demand for community facilities and services.
        Increased demand for water supply, sewage treatment and solid
        waste disposal facilities.
During the construction phase, the impact will be greater if the project
requires large numbers of construction workers to be brought in from outside
the community than if local unemployed workers are available.  The potential
impacts include:

     •  Creation of social tension.
     •  Short-term expansion of the local economy.
     •  Demand for increased police and fire protection, public utilities,
        medical facilities, recreation facilities, and other public services.

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     •  Increased demand for housing on a short-term basis.
     •  Strained economic budget in the community where existing infra-
        structure becomes inadequate.
     •  Increased congestion from construction traffic.
Various methods of reducing the strain on the budget of the local community
during the construction phase should be explored.  For example, the company
itself may build the housing and recreation facilities and provide the utility
services and medical facilities for its imported construction force. Or the
company may prepay taxes, and the community may agree to a corresponding
reduction in the property taxes paid later.  Alternatively, the community may
float a bond issue, taking advantage of its tax-exempt status, and the company
may agree to reimburse the community as payments of principal and interest
become due.

     During operation, the more extreme adverse changes of the construction
phase are likely to disappear.  Longer run changes may be profound, but less
extreme, because they evolve over a longer period of time and may be both
beneficial and adverse.

     The permit applicant should document fully in the EID the range of poten-
tial impacts that are expected and demonstrate how possible adverse changes
will be handled.  For example, an increased tax base generally is regarded as
a positive impact.  The revenue from it usually is adequate to support the
additional infrastructure required as the operating employees and their families
move into the community.  The spending and respending of the earnings of these
employees has a multiplier effect on the local economy, as do the interindustry
linkages created by the phosphate facilities. The linkages may be backward and
forward.  Backward linkages are those of the facility's suppliers.  Forward
linkages are those of the facility's markets.

     Socially, the community may benefit as the increased tax base permits the
provision of more diverse and higher quality services, and the variety of its
interests increases with growth in population.  Contrastingly, the transfor-
mation of a small community into a larger community may be regarded as an
adverse change by some of the residents who chose to live in the community, as
well as by those who grew up there and stayed because of its small town amenities.
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     The applicant also should consider the economic repercussions if, for
example, the quality of the air and water declines as a result of various
emissions from the phosphate facility.  In some cases, other more traditional
sectors of economic activity may decline because labor is drawn away from them
into higher paying phosphate related or tertiary sector activities.  As an
illustration, the fishing sector may decline if water pollution increases, or
if fishermen abandon the occupation in favor of employemnt at the phosphate
facility.  Again, the tourist sector may decline if air and water pollution is
noticeable or if the landscape is degraded.

     Thus, the applicant's framework for analyzing the socioeconomic impacts
of the location of a phosphate facility must be comprehensive.  Most of the
changes described can and should be measured to assess fully the potential
costs and benefits.  The applicant should distinguish clearly between the
short-term (construction) and long-term (operation) changes, although some
changes may be common to both (e.g., the provision of infrastructure).  The
significance of the changes depends not only on their absolute magnitude, but
on the rate at which they occur.  The applicant should also develop and main-
tain close coordination with State, regional, and local planning and zoning
authorities to ensure full understanding of all existing and/or proposed land
use plans and other related regulations.

     US EPA's Office of Federal  Activities  ts developing a methodology to be
used to forecast the socioeconomic impacts of new source industries and the
environmental residuals associated with those impacts.
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5.0  EVALUATION OF AVAILABLE ALTERNATIVES

     The alternatives section of the EID should address each reasonable alter-
native equitably.  The purpose of this analysis is to identify and evaluate
alternate plans and actions that may accomplish the desired goals of the
project.  These alternatives can include process modifications, site reloca-
tions, project phasing, or project cancellation.

     For the alternatives to a proposed project to be identified and evaluated
properly, the impact assessment process should commence early in the planning
phase.  In this manner, social, economic, and environmental factors against
which each alternatiave is to be judged can be established.  Cost/ benefit
analysis should not be the only means whereby alternatives are compared.  The
environmental and social benefits of each alternative also must be considered.
In general, the complexity of the alternative analyses should be a function of
the magnitude and significance of the expected impacts of the proposed pro-
cessing operations.  A small operation that uses purchased raw materials or
existing by-products may have a relatively minimal impact on a region and
generally would require fewer alternatives presented in the EID.

     The public's attitude toward the proposed operation and its alternatives
also should be evaluated carefully.   In this way key factors such as aesthetics,
community values, and land use can be assessed properly.

5.1  SITE ALTERNATIVES

     The phosphate fertilizer industry locates facilities on the basis of
convenience to raw materials,  an adequate labor force and water supply, prox-
imity to energy supplies and transportation, minimization of environmental
problems,  and only to a limited extent on the basis of market demand and other
factors.   A variety of sites initially should be considered and, following a
detailed analysis of each one,  a preferred alternative should be selected that
appears to satisfy the objectives and that is expected to result in the least
adverse environmental impact.   When  the site is planned in the mining area,
the selection factors will also be related to mining impacts and any integra-
tion possible for processes,  handling systems, and common waste disposal sites
and treatment techniques.
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     The factors considered in selecting each site, and especially those that
influenced a positive or negative decision on its suitability, should be
carefully documented in the permit applicant's EID.  Adequate information on
the feasible alternatives to the proposed site is a necessary consideration in
issuing, conditioning, or denial of an NPDES permit (40 CFR 6, Subpart  F).
Proposals to build in areas of steep terrain, unstable soils, wetlands  or high
water tables, and urbanized areas should devote comprehensive analysis  to
siting alternatives.

     Specifically, the advantages and disadvantages of each alternative site
must be catalogued with due regard to preserving natural features such  as
wetlands, coastal zones, and other sensitive ecosystems and to minimizing use
of flood plains or other areas of significant adverse environmental impacts.
The applicant should ascertain that all impacts are evaluated as to their
significance, magnitude, frequency of occurrence, cumulative effects, reversi-
bility, secondary or induced effects, and duration.  Accidents or spills of
hazardous or toxic substances vis-a-vis site location should be addressed.

     When a proposed site is controversial, it may have to be abandoned for a
number of reasons.  Such opposition may derive from the fact that the proposed
facility would significantly impact a unique, recreational, archaeological, or
other important natural or man-made resource area.  It may destroy the  rural
or pristine character of an area.  It may conflict with the planned develop-
ment for the area.  The site may be opposed by citizen groups.  It may  have to
be discarded for meteorological and climatological reasons.   It may be  subject
to periodic flooding, hurricanes, earthquake, or other natural disasters.

     If the proposed site location proves undesirable, then alternative sites
from among those originally considered should be reevaluated, or new sites
should be identified and evaluated.  Expansion or continued use of an existing
facilities site also could be a possible alternative solution.  It is critical
that a permit applicant systematically identify and assess all feasible alter-
native site locations as early in the planning process as possible.
                                      191

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 5.2  ALTERNATIVE PROCESSES DESIGNS, AND OPERATIONS

     Typically, when the decision is made to expand manufacturing capacity—
 either  through a new plant or an addition to an existing one—the type of
 facility to be constructed is already fixed; that is, the demand for phos-
 phoric  acid and/or other end products would have dictated the general types of
 processes to be used.  The limitation on process alternatives is not as severe
 as it once was in dry products because of improved versatility of granulation
 processes.

     In addition to demand, the process alternatives should be selected on the
 basis of availability and quality of required raw materials as well as environ-
 mental  considerations.  The applicant should present clearly and systemati-
 cally in the EID the methodology used to identify, evaluate, and select the
 preferred process alternatives.  In unusual cases where water supplies or raw
 materials quality is a constraint or land availability of concern, process
 alternatives now only in research or pilot plant stages may be considered by
 the applicant.  For example, the thermal process for phosphoric acid would
 eliminate gypsum-pond-related waste problems, but it has other solids disposal
 problems.  Other alternatives continuously being investigated include solvent
 extraction of wet process acid impurities and use of alternate acids to produce
 alternate fertilizer products directly from phosphate rock and eliminate
 gypsum  wastes (although other wastes may pose other serious difficulties).

 5.3  NO-BUILD ALTERNATIVE

     In all proposals for facilities developed, the applicant must consider
 and evaluate the alternative of not constructing the proposed new source
 facility.  Because this analysis is not unique to the development of phosphate
 fertilizer manufacturing facilities, no detailed guidance is provided as part
 of this Guidelines document.  The permit applicant is referred to Chapter IV
 (Alternatives to the Proposed New Source) in the document, Environmental Impact
Assessment Guidelines for Selected New Sources Industries (USEPA 1975).   The
no-build alternative in the present context can include sale of raw materials
 to existing facilities in instances where an applicant produces one or more of
the raw materials for phosphate fertilizers and where transportation impacts
may be   less severe than impacts of siting a new source phosphate manufacturing
plant in the proposed area.
                                    192

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                 6.0  REGULATIONS OTHER THAN POLLUTION CONTROL

The applicant should be aware that there may be a number of regulations other
than pollution control regulations that have some application to the siting
and operation of new phosphate fertilizer manufacturing facilities.  The
applicant should coordinate with the appropriate USEPA Regional Administrator
regarding applicability of such regulations to the proposed new source.
Federal statutes which generated regulations that may be pertinent to a pro-
posed facility iaelude:

     Council of Environmental Quality, Rules and Regulations for NEPA, Imple-
       mentation of Procedural Provisions (40 CFR 1500, rev. Nov. 29, 1978)
     Environmental Protection Agency, Implementation of Procedures on the
       National Environmental Policy Act (40 CFR 6,  November  6,  1979)
     Coastal Zone Management Act of  1972
     The Fish and Wildlife Coordination Act
     The National Environmental Policy Act of 1969
     USDA Agriculture Conservation Service Watershed Memorandum 198  (1971)
     Wild and Scenic Rivers Act of 1969
     The Flood Control Act of 1944
     The National Flood Insurance Act of 1968
     The National Flood Disaster Protection Act of 1973
     Federal-Aid Highway Act, as amended (1970)
     The Wilderness Act (1964)
     Endangered Species Preservation Act, as amended (1978)
     The National Historical Preservation Act of 1974
     Executive Orders 11593, 11938, and 11990
     Archaeological and Historic Preservation Act of 1974
     Procedures of the Council on Historic Preservation (1973)
                                     193

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     Occupational Safety and Health Act of 1979
     Safe Drinking Water Act, as amended (1977)
     Atomic Energy Act

     In connection with these regulations, the applicant should place particular
emphasis on obtaining the services of a recognized archaeologist to determine
the possibilities of disturbing an archaeological site,  such as an early
Indian settlement or a prehistoric site.  The National Register of Historic
Places also should be consulted for historic  sites such  as battlefields.  The
applicant should consult the appropriate wildlife agency (State and Federal)
to ascertain that the natural habitat of a threatened or endangered species
will not be adversely affected.
                                    194

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                                7.0  REFERENCES
     The literature references  listed  in  this  section  include cited references
and additional selected bibliographic  references.   The listings immediately
below are short form citations  arranged according  to topics.  A complete
listing of full references, arranged alphabetically, follows the short form
citations.  These citations are useful for  further  information in specific
topic areas.
General

Alsager 1978
Anonymous 1978a
Dinauer 1971
Drew Chemical
  Corporation 1977
Hooks 1978
Kirk-Othmer 1969
Perry 1969
Russel 1977
Schneider 1976
Slack 1968a
Slack 1968b
USEPA 1975
USEPA 1978b
USEPA 1978e
USEPA 1978h
USEPA 1978i
USEPA 1978g

Subcategorization

USEPA 1974a
USEPA 1974b
USEPA 1974C
USEPA 1976c

Processes (including
trends in processes)

Achorn and
  Kimbrough 1974
Achorn et al 1976
Anonymous 1972a
Anonymous 1972b
Anonymous 1972c
Anonymous 1976a
Anonymous 1976d
Balay and Achorn  1971
Balay and Kimbrough
   1978
 Barber  1976
 Barber  1978b
 Bostwick 1970
 Brown 1976
Market and Demands

Anonymous 1970
Anonymous 1974a
Anonymous 1974b
Anonymous 197 6b
Anonymous 1976c
Anonymous 1976d
Carrington 1962
Douglas and Parker 1977
Douglas and Davis 1977
Harre 1975
Harre 1976
Stowasser 1975
Stowasser 1977
TVA 1977a
TVA 1977b
TVA 1978a
TVA 1979
USDOI 1977
USDOI 1979
U.S. Department of
  Commerce 1979
USEPA 1974d
USEPA 1974e
USEPA 1977a
USEPA 1978a
USEPA 1978p
USEPA 1979a

Pollution Control
Technology	

Achorn and Barger 1972
Anonymous 1972a
Bakke 1976
Barber 1975a
Barber 1975b
Barber 1978a
Cheremisinoff
  et al 1979
Cochrane  1976
Cochrane  1978
Drew Chemical  Corp.
Flagg  1978
Industry Trends
(location, raw materials ,
products) _

Anonymous 1975
Barber 1975c
Barber 1978a
Douglas 1978
Hicks 1977
Hignett 1972
Lyon 1976
Parker et al 1977
Russel 1977
Stowasser 1975
Stowasser 1977
TVA 1977a
TVA 1978a
U.S. Department of
  Commerce 1979
USEPA 1974d
USEPA 1974e
USEPA 1976d
USEPA 1977a
USEPA 1978a
USEPA 1979a

Human Health

Hodge and Smith 1979
National Academy of
  Sciences  1971
Prister  1971
Schiager 1978
TRC 1979
USEPA 1974a
USEPA 1974f
 Anonymous  1976e
 Aoyama  and Inoue  1973
 Maslov  1973
 Prister 1971
 Schiager 1978
 USEPA I977d
 USEPA 1978p
                                      195

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(Processes Cont.)

Davis 1975
Dell 1967
Dinauer 1971
Donovan 1976
Engineering and
  Mining Journal
Hicks 1977
Hignett 1972
Hurst 1976
Hurst and Grouse 1974
Johnson 1967
Lee and Waggoner 1975
Lombardi and
  Teller 1976
McCollough 1976
Miyamoto 1975
Orekhov et al 1976
Parker et al 1977
Rushton and Smith 1964
Rushton and Williams
  1977
Scott et al 1974
Slack 1968a
Slack 1968b
Stern and Ellis 1970
Striplin and
  Achorn 1970
TRC 1979
TVA 1974
U.S. Atomic Energy
  Commission
U.S. Energy Research
  & Development Admin-
  istration 1976
USEPA 1971
USEPA 1974a
USEPA 1974b
USEPA 1974c
USEPA 1976a
USEPA 1976b
USEPA 1976c
USEPA 1976d
USEPA 1977a
USEPA 1977b
USEPA 1978a
USEPA 1978c
USEPA 1979d
USEPA 1979a
White et al 1978
(Pollution Control Cont.)   Air quality
Friedman 1976
Gartrell and Barber 1979
Harman and Ramsey 1978
Hill 1976
Mabrey 1978
Malone 1978
Palm 1976
Pflaum 1978
Pound 1976
Powers 1976
Rodgers 1976
TRC 1979
USEPA 1971
USEPA 1974a
USEPA 1974b
USEPA 1974c
USEPA 1976d
USEPA 1977c
USEPA 1978a
USEPA 1978c
USEPA 1978d
USEPA 1978e
USEPA 1978m
USEPA 1978n
USEPA 1978o
USEPA 1979a
Wilson 1978
Wissa 1977

Water Quality

Bouldin et al 1975
DuPuis 1978
Frazier et al 1977
Lehr 1978
USEPA 1974a
USEPA 1976a
USEPA 1976b
USEPA 1976e
USEPA 1977a
USEPA 1978e
USEPA 1978g
USEPA 1978h
USEPA 1978i
USEPA 1979a

Energy

Blouin and Davis 1975
Achorn and Barber 1972
Frazier et al 1977
Hentrickson 1961
McCune et al 1964
Suttie 1969
TRC 1979
USEPA 1974b
USEPA 1976a
USEPA 1976b
USEPA 1976e
USEPA 1977a
USEPA 1977c
USEPA 1978a
USEPA 1978c
USEPA 1978d
USEPA 1978e
USEPA 1978f
USEPA 1978h
USEPA 1978i
USEPA 1978p
USEPA 1978q
USEPA 1979a

Solid Waste

Barber 1975b
Barber 1976
Hocking 1978
Lehr 1978
Palm 1976
Palm and Wissa 1978
USEPA 1974a
USEPA 1976e
USEPA 1977a
USEPA 1978j
USEPA 1979a
White et al 1978
Williams 1975
Wissa 1977

Geology and Geography

Cheremisinoff et al  1979
Pound 1976
Stowasser 1975
U.S. Bureau of
  Mines 1977
U.S. Energy Research &  Develop-
  ment Admistration  1976
                                       196

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Ecology Impacts
                        (Energy  Cont.)
(Geology  and  Geography  Cont.)
Alsager 1978
Aoyama and Inoue 1973
Bouldin et al 1975
Maslov 1976
McCune and Weinstein
  1971
National Academy of
  Sciences 1971
National Academy of
  Sciences 1974
Prister 1971
Suttie 1969
USEPA 1974a

Modeling of  Impacts
                         Engineering  and Mining
                           Journal  1975
                         USEPA 1978
                         USEPA 1976a
                         USEPA 1976b
                         White 1978

                         Noise and  Vibration

                         USEPA 1974f
                         USEPA 1974g

                         Socioeconomics/Land Use
 USEPA 1976e
 USEPA 1977d
 USEPA 1978J
 USEPA 1978p
 Williams 1975

 Regulations

 Beck 1976
 Berry 1978
 Hoffnagle and Dunlap 1978
 Ritch 1978
 Sanjour 1978
 USEPA 1978k
                         Alford et al 1976
                         Alsager 1978
Cheremisinoff et al 1979 Cheremisinoff et al 1979
                         USEPA 1976e
                         USEPA 1978b
                         USEPA 1978h
                         USEPA 1978j
                         USEPA 19781
                         USEPA 1978p
 USEPA 1977a
 USEPA 1978c
 USEPA 1978d
 USEPA 1978f
 USEPA 1978g
 USEPA 1979a
 Aesthetics and Cultural

 Bouldin et al 1975
 USEPA 1978b
 USEPA 1978i
                                       197

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Achorn,  Frank and J.  C.  Barber.   1972.   Bulk blenders - Environmental control
     and OSHA.   Fertilizer  Progress,  Volume 3,  p. 24-27, 42, 47-49 (September-
     October) and p.  10-13  (November-December).

Achorn,  Frank P.  and  H.  L.  Kimbrough.  1974.  Latest developments in commer-
     cial use of  the  pipe reactor process.   Fertilizer Solutions  18:8-9, 12,
     14, 16,  20-21.

Achorn,  Frank P., Eugene B.  Wright,  Jr., and Hubert L. Balay.  1976.  Corrosion
     problems can be  alleviated  with right  materials.  Fertilizer Solutions
     20(3):34,  36,  38-40.

Alford et al.  1976.   Evaluation of  the use of  existing and modified land use
     implementation measures to  achieve and maintain environmental quality.
     Final Report:  Contract No. 68-01-3231, U.S. Environmental Protection
     Agency,  Washington, D.  C.

Alsager, Melvin D.  1978.  Idaho phosphate  environmental impact statement.
     In Proceedings of Environmental Symposium, The Fertilizer Institute,
     New Orleans, Louisiana, p.  181-188.

Anonymous.  1970. Liquid sulfur transportation - Part 1.   Sulphur 88:40-46.

Anonymous.  1972a.  The  Kellogg-Lopker  process, a revolution in phosphoric
     acid production  technology.  Phosphorus &  Potassium 62 (Nov./Dec.1972):
     20-23.

Anonymous.  1972b.  The  BESA phosphoric acid processes, solvent extraction
     technique with choice  of feedstocks.   Phosphorus and  Potassium 59:26-28.

Anonymous.  1972c.  Cleanup  pays off  for fertilizer plant.  Environmental
     Science  and  Technology, 6(5):400-401.

Anonymous.  1974a.  Sulphuric acid production costs.  Sulphur 114:38-40.

Anonymous.  1974b.  U. S. fertilizer industry faces higher sulphur costs.
     Fertilizer Industry 66:1-2.

Anonymous.  1975. New plants and projects:  Phosphorus.  Phosphorus and
     Potassium 80:15-17.

Anonymous.  1976a.  Tennessee Valley Authority  fertilizer  process use.  Farm
     Chemicals 139(4):82.

Anonymous.  1976b.  More U.  S.  'rock' for foreign markets.  Chemical Week
     (8 December), p.15-16.

Anonymous.   1976c.  Phosphoric acid  production.  Phosphorus & Potassium  83
      (May/June 1976):48-50.

Anonymous.   1976d.  Ammonia pipeline set for major  expansion.  Chemicals
     Market  Report 209(18):47.
                                    198

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Anonymous.  1976e.  Radioactivity in phosphates.  Phosphorus and Potassium 84:
     44-45.

Anonymous.  1978a.  Farm chemicals handbook.  Published annually.  Meistor
     Publishing Company, Willoughby OH, p. B11-B42; B55-B77.

Anonymous.  1978b.  Method eases use of sludge in fertilizer.  Chemical &
     Engineering News 56(38):23.

Aoyama, I. and Y. Inoue.  1973.  Estimation and evaluation of radioactive
     contamination through a food web in  an aquatic ecosystem.  Journal of
     Radiation Research 14(4):375-381.

Bakke, E.  1976.  Wet electrostatic precipitators on phosphate rock dryers.
     In Proceedings of Environmental Symposium, The Fertilizer Institute,
     New Orleans, Louisiana, p. 401-409.

Balay, H. L. and F. P. Achorn.  1971.  Updated uses and handling of wet-
     process superphosphoric acid.  Fertilizer Solutions 15:24, 26, 28, 30.

Balay, H. L. and H. L. Kimbrough.  1978.  Selecting equipment and materials
     of construction for fluid fertilizer plants.  Phosphorus & Potassium
     93:28-32.

Barber, J. C.  1975a.  Pollution control  in fertilizer manufacture.  Journal
     of Environmental Quality 4(1):1-11.

Barber, J. C.  1975b.  Solid wastes from  phosphorus production.  Chapter VII.2
     in Solid wastes, C. L. Mantell, ed., John Wiley & Sons, Inc., 18 p.

Barber, J. C. 1975c.  Storage and containment of phosphoric acid and liquid
     fertilizer.  Fertilizer Solutions 19(5):40, 42, 44, 46, 48.

Barber, J. C., Tennessee Valley Authority-  1976.  Reuse of wastes in the
     production of granular fertilizers.  In Proceedings of Environmental
     Symposium, The Fertilizer Institute, New Orleans, Louisiana, p. 351-381.

Barber James C.  1978a.  Environmental control in fertilizer production -
     Energy consumption and conservation.   In Proceedings of Environmental
     Symposium, The Fertilizer Institute, New Orleans, Louisiana, March 5-8,
     1978, p. 79-100.

Barber, J. C.  1978b.  (Draft).  New fertilizer production  process - Use of
     sewage sludge in granulation.  Paper presented at the  American Chemical
     Society meeting in September 1978.   22 p.

Barber, J. C.  1979.  Falling film evaporator  process.  Adapted  from TVA
     file drawings.  Florence, AL.

Beck,  L. L.  1976.  Federal standards of  performance.   In Proceedings  of
     Environmental Symposium, The Fertilizer Institute, New Orleans,
     Louisiana, p. 9-23.
                                    199

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Berry, D. Kent.   1978.  Implementing the 1977 Clean Air Act Amendments.  In
     Proceedings of Environmental Symposium, The Fertilizer Institute, New
     Orleans, Louisiana, p. 129-138.

Blouin, Glenn M. and Charles H. David.  1975.  Energy requirements for the
     production and distribution of chemical fertilizers in the U. S.  Energy
     in Agriculture, Proceedings of Conference Workshop, Southern Regional
     Educational Board, held at Atlanta, GA., October 1-3, 1975, p. 51-67.

Bostwick, Louis E.   1970.  Loop system slashes costs for making phosphoric
     acid.        Chemical engineering (November 30, 1970), p. 47-49.

Bouldin, D. R.,  H.  R. Capener, G. L. Caster, A.  E. Durfee, R. C. Lochr, R. T.
     Oglesby, and R. J. Young.  1975.  Lakes and phosphorus inputs, A focus
     on management.  Information Bulletin 127, 13 p.

Brown, M, L.  1976.  The Lurgi double contact sulfuric acid process.  In
     Proceedings of Environmental Symposium, The Fertilizer Institute, New
     Orleans, Louisiana, p. 471-486.

Carrington, J. C.  1962.  Transport of liquid sulphur.  The Industrial Chemist
     (January 1962), p. 10-12.

Cheremisinoff, N. P., P. N. Chereinisinoff,  F. Ellerbush, and A. J. Perna.
     1979.  Industrial and hazardous wastes impoundment.  Ann Arbor Science
     Publishers, Inc., Ann Arbor, Michigan, 475  p.

Cochrane, J. F.   1976.  Scrubbers for calciners.  J,n Proceedings of Environ-
     mental Symposium, The Fertilizer Institute, New Orleans, Louisiana,
     p. 449-463

Cochrane, John F.  1978.  Monitoring  SO- for compliance.  In Proceedings
     of Environmental Symposium, The Fertilizer  Institute, New Orleans,
     Louisiana,  p.  199-210.

Davis, C. H.  1975.  New developments in fertilizer technology.  Phosphorus
     in Agriculture 65:27-33.

Dell, George J.   1967.  Construction materials for phos-acid manufacture.
     Chemical Engineering  (April 10, 1967), p. 234, 236, 238, 240, and 242.

Dinauer, Richard C. (Editor).  1971.  Fertilizer technology and use.  2nd
     edition.  Soil Science Society of America,  Inc.  Madison, WI, 611 p.

Donovan, J. R.  1976.  Double absorption sulfuric acid plants.  In
     Proceedings of Environmental Symposium, The Fertilizer Institute,
     New Orleans, Louisiana, p. 465-470.

Douglas, John and J. Harold Parker.  1977.   The phosphate industry rebounds.
     Farm Chemicals 40(6):32-33, 36, 38.

Douglas, John R. and Charles  H.  Davis.  1977.  Fertilizer supply and demand.
     Chemical Engineering 84(15):88-94 .
                                    200

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Douglas, John.  1978.  1990:  Musings on the U.S. fertilizer industry.
     Fertilizer Progress, (November-December), 6p.

Drew Chemical Corporation.  1977.  Principles of industrial water treatment.
     Published by Drew Chemical Corporation, Boonton, N.J., 310p.

DuPuis, Louis.  1978.  EPA's water pollution control program.  In_ Proceedings
     of Environmental Symposium, The Fertilizer Institute, New Orleans,
     Louisiana, p. 139-148.

Engineering and Mining Journal.  1975.  Large-scale uranium recovery from
     phosphoric acid looks promising.  Nov. p. 32.

Flagg, Robert B.  1978.  Fugitive emission monitoring.  In Proceedings of
     Environmental Symposium, The Fertilizer Institute, New Orleans,
     Louisiana, p. 211-216.

Frazier, A. William, James R. Lehr, and Ewell F. Dillard.  1977-  Chemical
     behavior of fluorine in production of wet-process phosphoric acid.
     Environmental Science Technology 11(10):1007-14.

Friedman, L. J.  1976.  Ammonia scrubbing of sulfuric acid plant tail gas -
     Recent Davy Powergas experience.  In Proceedings of Environmental
     Symposium, The Fertilizer Institute, New Orleans, Louisiana, p. 487-505.

Gartrell, F. E. and J. C. Barber.  1970.  Environmental protection - TVA
     experience.  J. Sanitary Eng. Div., Proc.  ASCE 96(SA6), 1321-34.

Harman, Dale L. and Geddes H. Ramsey.  1978.  Novel particulate collection
     devices.  In Proceedings of Environmental Symposium, The Fertilizer
     Institute, New Orleans, Louisiana, p. 245-262.

Harre, Edwin A.  1975.  The supply outlook for phosphate fertilizers.  In
     Tennessee Valley Authority, Proceedings of TVA  fertilizer conference,
     July 29-31, 1975, Louisville, Kentucky.  National Fertilizer Develop-
     ment Center, Muscle Shoals, AL, p. 36-44.

Harre, Edwin E.  1976.  What's ahead in fertilizer supply-demand.   In
     Tennessee Valley Authority, Proceedings of TVA  fertilizer conference,
     July 1976, Cincinnati, Ohio.  National Fertilizer Development  Center,
     Muscle Shoals, AL, p. 18-24.

Harre, E.A. and Hazel A. Handley.  1978.  World  fertilizer trade and  the U.S.
     market outlook.  Situation 78, TVA fertilizer conference, August 15-16,
     1978, St. Louis, Missouri.  Bulletin Y-131.  National Fertilizer Develop-
     ment Center, Muscle Shoals, AL, 83p.

Hendrickson, E.R.  1961.  Dispersion and effects  of  air  borne  fluorides  in
     central Florida.  Journal of the Air Pollution  Control  Association
      (11(5) -.220-225.

Hicks, G.C.  1977.  Review of the production  of  monoammonium phosphate.
      National  Fertilizer Development Center.   Bulletin Y-119.   Muscle Shoals,
      Al,  10  p.

                                    201

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Hignett, Travis P., Director of Chemical Development, TVA.  1972.  Trends in
     fertilizer development.  52p.

Hill, L. J. 1976.  Removing gaseous pollutants from phosphate fertilizer
     operations.  In Proceedings of Environmental Symposium, The Fertilizer
     Institute, New Orleans, Louisiana, p. 421-436.

Hocking, H. Treve.  1978.  Reclamation - an overview.  In Proceedings of Environ-
     mental Symposium, The Fertilizer Institute, New Orleans, Louisiana, p. 409-411

Hodge, Harold C. and Frank A. Smith.  1970.  Air quality criteria for the
     effects of fluorides on man.  Journal of the Air Pollution Control Associa-
     tion  20(4):  226-232.

Hoffnagle, G. F. and R. Dunlap.  1978.  Industrial expansion and the 1977 Clean
     Air Act Amendment.  Pollution Engineering 10(12), December, pp. 36-43.

Hooks, Homer.  1978.  EPA's area-wide environmental impact statement on
     Florida phosphate.  In Proceedings of Environmental Symposium, The
     Fertilizer Institute, New Orleans, Louisiana, p. 189-198.

Hurst, F. J.  1976.  Recovery of uranium from wet process phosphoric acid
     by solvent extraction.  Paper presented at the AIME Annual Meeting, Las
     Vegas, NV. 22 February 1976.  34p.

Hurst, F. J. and D. J. Grouse.  1974.  Recovery of uranium from wet-process
     phosphoric acid by extraction with octylphenylphosphoric acid.  Indus-
     trial Engineering Chemistry 13(3) :286-291

Johnson, T. E.  1967.  Phosphoric acid processing, Alloy selected for use in
     wet process.  Materials Protection (February 1967), p.  58-59.

Kirk-Othmer Encyclopedia of Chemical Technology.  1969.  Second Edition,
     Volume 18.  John Wiley & Sons, Inc.,  New York, New York, p. 95-96.

Lee, R. G. and D. R. Waggoner.  1975.  Scrubber liquor recovery and energy
     utilization in fertilizer melt-granulation processes.  Paper presented
     at the American Chemical Society Meeting, Chicago, Illinois, August
     24-29, 1975.  9 p. and appendix.

Lehr, James R.  1978.  Fluorine chemical redistribution in relation to gypsum
     storage pond systems.  In Proceedings of Environmental Symposium, The
     Fertilizer Institute, New Orleans, Louisiana, p. 277-312.

Lorabardi, C. E. and A. J. Teller.  1976.  Scrubbing fluoride emissions.  I_n
     Proceedings of Environmental Symposium, The Fertilizer Institute,
     New Orleans, Louisiana, p. 437-448.

Lyon, Fred D.  1976.  Trends in storage, handling, and transport.  Jja
     Tennessee Valley Authority, Proceedings of TVA fertilizer conference,
     July 1976, Cincinnati, Ohio.  National Fertilizer Development Center,
     Muscle Shoals, AL, p. 37-42.
                                    202

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Mabrey, J. E.  1978.  Experiences in meeting phosphate fertilizer industry
     wastewater guidelines.  Ln Proceedings of Environmental Symposium, The
     Fertilizer Institute, New Orleans, Louisiana, p. 263-276.

Malone, Albert V.  1978.  NPK process emission control systems.  In
     Proceedings of Environmental Symposium, The Fertilizer Institute,
     New Orleans, Louisiana, p. 313-326.

Maslov, V. I.  1973.  Accumulation of uranium, radium, and thorium by animals
     of a radioecological group in close contact with radioactive substances
     in the medium of habitation.  Mater.Vses. Simp. "Teor. Prakt. Aspekty
     Deistvya Malykh Doz loniz.  Radiats., " 100-101.

McCollough, John F. , Tennessee Valley Authority.  1976.  Phosphoric acid
     purification:  comparing the process choices.  Chemical Engineering 83
     (26):101-103.

McCune, D. C., Leonard H. Weinstein, Jay S. Jacobson, and A. E. Hitchcock.
     1964.  Some effects of atmospheric fluoride on plant metabolism.  Journal
     of the Air Pollution Control Association 14(11):465-468.

McCune, Delbert C. and Leonard H. Weinstein.  1971.  Metabolic effects of
     atmospheric  fluorides on plants.  Environmental Pollution 1:169-174.

Miyamoto, Mitsuya.  1975.  New Nissan process for concentrated phospheric
     acid and current trends in phospheric acid manufacture.  Chemical Economy
     & Engineering Review 7(5):20-27.

National Academy of Sciences.  1971.  Biologic effects of atmospheric pollu-
     tants:   Fluorides.  Washington, D. C. 295 p.

National Academy of Sciences.  1974.  Effects of fluorides in animals.  70 p.

Orekhov, I. I., V. P. Sverdlova, G. L. Slobodkiva, and S. B. Kopileva.  1976.
     Production of concentrated phosphoric acid solutions.  The Soviet
     Chemical Industry 8(1): 27-28.

Palm, Gordon F.  1976.  Gypsum stacks and cooling ponds - Design requirements
     and control technology.  In Proceedings of Environmental Symposium,
     The Fertilizer Institute, New Orleans, Louisiana, p. 309-327.

Palm, Gordon F. and Anwar E. Z.  Wissa.   1978.   Environmental  aspects  of
     waste disposal in the phosphate industry.  In Proceedings of Environ-
     mental Symposium, The Fertilizer Institute, New Orleans, Louisiana,
     p. 347-370.

Parker, B. C., M. M. Norton, and D. G. Salladay.  1977.  Developments  in
     production of granular NP and NPK fertilizers using the  pipe and  pipe-
     cross reactor.  Paper presented at FAI-IFDC Seminar, New Delhi,
     December 1-3, 1977.

Perry, John H. Editor.  1969.  Chemical Engineers' Handbook.  McGraw-Hill,
     New York, p. 8-1 - 8-49.
                                     203

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Pflaum, Craig A.   1978.  Practical design of cross-flow scrubbers in the
     phosphate industry.  In Proceedings of Environmental Symposium, The
     Fertilizer Institute, New Orleans, Louisiana, p. 233-244.

Pound,  C. E.  1976.  Land disposal for fertilizer plant effluents.  In
     Proceedings  of Environmental Symposium, The Fertilizer Institute,
     New Orleans, Louisiana, p, 329-349.

Powers, H. G.  1976.  Case history:  Use of bag dust collectors to control
     particulate  emission from dryers and coolers in NPK plants,  In
     Proceedings  of Environmental Symposium, The Fertilizer Institute,
     New Orleans, Louisiana, p. 383-399.

Prister, B. S.  1971.  Behavior of uranium in the biological chain.  Nuclear
     Science Abstracts 25(22) :5109.

Rich, John B.  1978.  Implementation of the Toxic Substances Control Act.
     In Proceedings of Environmental Symposium, The Fertilizer Institute,
     New Orleans, Louisiana, p. 153-178.

Rodgers, J.  1976.  Scrubbing particulate emissions.  In Proceedings of
     Environmental Symposium, The Fertilizer Institute, New Orleans,
     Louisiana, p. 411-419.

Rushton, W. E. and J. L. Smith.  1964.  Superphosphoric acid from wet process
     phosphoric acid.  Chemical Engineering Progress 60(7):97-99.

Rushton, W. E.  1966.  Swenson superphosphoric acid process,  j[n_ Phosphorus
     and Potassium, No. 23, June/July, p 13-16, 19.

Russel, D. A. and G. G. Williams.  1977.  History of chemical fertilizer develop-
     ment.  Soil  Sci. Soc. America Journal 41(2):260-65.

Sanjour, William.  1978.  Hazardous waste management regulations.  In
     Proceedings  of Environmental Symposium, The Fertilizer Institute, New
     Orleans, Louisiana, p. 149-152.

Schiager, Keith J.  1978.  Radiation - A perspective.  In Proceedings of
     Environmental Symposium, The Fertilizer Institute, New Orleans,
     Louisiana, p. 327-346.

Schneider, W. J.   1976.  The Idaho Phosphate EIS.  I_n  Proceedings of
     Environmental Symposium, The Fertilizer Institute, New Orleans,
     Louisiana, p. 301-308.

Scott, W. E., G.  G. Patterson, and C. A. Hodge.  1974.  Status of modern
     wet-process  phosphoric acid technology.  Fertilizer Solutions 18:62,
     64, 65, 68,  70, 72, 74-77.

Slack, A. V-  1967.  Chemistry and technology of fertilizers.  John Wiley &
     Sons, Inc.  New York, NY, p. 69-97.
                                     204

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 Slack,  A.  V.   Editor.   1968a.  Phosphoric acid, Volume I:   Part I.   Marcel
      Dekker,  Inc., New York, 501 p.

 Slack,  A.  V.   .Editor.   1968b.  Phosphoric acid, Volume I:   Part II.   Marcel
      Dekker,  Inc., New York, p. 502-1159.

 Stern,  R.  C.  and J. D. Ellis.  1970.  Processing problems  pared for  super-
      phosphoric acid.   Chemical Engineering 77(6):98-100.

 Stowasser,  W. F.  1975.  Phosphate Rock.  U. S. Bureau of Mines Bulletin
      667:1-16.

 Stowasser, W. F.  1977.  Phosphate-1977-   Publication No.  MCP-2, U.  S.
      Department of the Interior, Bureau of Mines, Washington,  D. C., May
      1977, 18 p.

 Stowasser, W. F.  1977a.  Phosphate rock, the present and  future supply and
      demand.   Letter from U.S. Bureau of Mines to R.E. McNeill, USEPA Region IV,
      February 18.

 Striplin,  M.  M. and F. Achorn.  1970.  Phosphoric acid. U. S. Patent
      assigned to Tennessee Valley Authority.  U.S.  3,507,614,  April  21,
      1970.  Application, March 14, 1966.   p. 8.

 Suttie, J. W.  1969.  Air quality standards for the protection of farm animals
      from fluorides.  Journal of the Air Pollution Control Association 19(4):
      239-242.

 Tennessee Valley Authority.  1974.  New developments in fertilizer technology,
      10th demonstration, October 1-2, 1974.  National Fertilizer Development
      Center,  Muscle Shoals, AL, p. 10-12, 20-21, 42-46.

 Tennessee Valley Authority.  1977a.  Fertilizer trends, 1976.   Bulletin Y-lll.
      National Fertilizer Institute, Muscle Shoals,  AL, 44  p.

 Tennessee Valley Authority.  1977b.  1976 fertilizer summary data.   Bulletin
      Y-112.  National  Fertilizer Development Center, Muscle Shoals,  AL, 132  p.

 Tennessee Valley Authority.  1978a.  Situation 78,  TVA Fertilizer Conference,
      August 15-16, 1978, St. Louis, Missouri.  Bulletin Y-131.  National
      Fertilizer Development Center, Muscle Shoals,  AL, 83  p.

 Tennessee Valley Authority.  1978b.  New developments in fertilizer  technology,
      12th demonstration, October 18-19.  National Fertilizer Development
      Center,  Muscle Shoals, AL, 91 p.

 Tennessee Valley Authority.  1979.  (Draft)  1978 fertilizer summary data,
      National Fertilizer Development Center, Muscle Shoals, AL, p.  6-7.

Timberlake, R.C.  1978.  Environmental control aspects of the Lonesome Mine.
     In Proceedings of  Environmental Symposium, The Fertilizer Institute, New
     Orleans,  LA, p. 397-407.
                                     205

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TRC - The Research Corporation of New England.  1979.  Evaluation of control
     technology for the phosphate fertilizer industry, Final Draft Report.
     Prepared for Industrial Research Laboratory, U.S. Environmental Protec-
     tion Agency.  Research Triangle Park, NC, 210 p.

U. S. Atomic Energy Commission,   1974,   Oxidative stripping process for the
     recovery of uranium from wet-process phosphoric acid,  by Fred J, Hurst
     and David J, Grouse,   4 p,

U, S. Department of Health, Education and Welfare,  1970.  Atmospheric
     emissions from wet-process  phosphoric acid manufacture, AP-57 (PB-
     192-222),  Raleigh, NC, 86  p,

U, S. Department of the Interior, Bureau of Mines,  1977.  Phosphate rock,
     The present and future supply and demand,  10 p.

U, S, Department of the Interior, Bureau of Mines,  1979.  Mineral industry
     survey, phosphate rock - 1978,   Washington,  DC, 6 p,

U, S. Energy and Development Administration,  1976.   National uranium resource
     evaluation, preliminary report,  Grand Junction (Colo.) Off.   June.

U. S. Environmental Protection Agency.   1971,  Inorganic fertilizer and phos-
     phate mining industries, Water pollution and control.   Prepared by
     Battelle Memorial Institute, Richland, WA, 226  p.

U. S. Environmental Protection Agency,   1971a,  Background  information for
     proposed new source performance standards.  Office of  Air Programs,
     Research Triangle Park, NC,

U. S. Environmental Protection Agency.   1974a.  Development document for
     effluent limitations  guidelines and new source  performance standards for
     the basic fertilizer  chemicals segment of the fertilizer manufacturing
     point source category.  Office of Air and Water Programs, Washington,
     D. C., 168 p.

U. S. Environmental Protection Agency.   1974b.  Background  information for
     standards of performance:  Phosphate fertilizer industry;  Volume 1,
     Proposed standards.  Office of Air and Waste Management;  Office of
     Air Quality Planning and Standards, Research Triangle  Park, NC, 148 p.

U. S. Environmental Protection Agency.   1974c.  Development document for
     proposed effluent limitations guidelines and new source performance
     standards for the formulated fertilizer segment of the fertilizer
     manufacturing point source category. Washington DC, 66 p.

U. S. Environmental Protection Agency.   1974d.  Economic analysis of effluent
     guidelines, Fertilizer industry.  Prepared by Development Planning and
     Research Associates,  Inc.,  Manhattan, KS.  Variously paged, 202 p.

U. S. Environmental Protection Agency.   1974e.  Economic analysis of proposed
     effluent guidelines for the fertilizer manufacturing industry (Phase 2).
     Prepared by Milton, L. D.,  C.  D. Jones, and J.  M. Malik.  125 p.
                                    206

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U. S. Environmental Protection Agency.  1974f.  Information on levels of
     environmental noise requisite to protect public health and welfare
     with an adequate margin of safety.  Performed by Environmental Protection
     Agency - Office of Noise Abatement and Control, Arlington, VA.  Various-
     ly paged, 159 p.

U. S.  Environmental  Protection  Agency.  1974g.  Background for portable air com-
     pressor  noise emission regulations.  Document  number EPA - 550/9-74-016.
     Washington,  D.  C.   Variously paged.

U. S.  Environmental  Protection  Agency.  1975.  Environmental impact assess-
     ment  guidelines for selected new source  industries.  Office of Federal
     Activities,  Washington D.  C.,  35 p. plus appendices.

U. S.  Environmental  Protection  Agency.  1976a.  "Executive Summary", Environ-
     mental considerations  of selected  energy conserving manufacturing process
     options;  Volume 15,  Fertilizer  industry  report.  Office of Research
     and Development,  Cincinnati,  OH,  74 p.

U. S.  Environmental  Protection  Agency.  1976b.  "Executive Summary", Environ-
     mental considerations  of selected  energy conserving manufacturing process
     options;  Volume 13,  Elemental  phosphorus and phosphoric acid  industry
     report.   Office of  Research  and  Development, Cincinnati, OH,  96 p.

U. S.  Environmental  Protection  Agency.  1976c.  Development document for
     effluent  limitations guidelines  and new  source performance standards
     for the  other non-fertilizer phosphate chemicals segment of the phosphate
     manufacturing point  source category.  Office of Water and Hazardous
     Materials, Washington,  D.C.,  106 p.

U.S. Environmental Protection Agency.   1976d.  Source assessment:  Fertilizer
     mixing plants.   Office of  Energy,  Minerals, and Industry, Research
     Triangle  Park,  NC.   Prepared by  Gary D.  Rawlings and Richard  B. Reznik,
     Monsanto  Research Corp., Dayton,  OH, 201 p.

U. S.  Environmental  Protection  Agency-  1976e.  Disposal of hazardous wastes,
     Manual on hazardous  substances  in  special wastes.  Washington, D. C.,
     p. 369-379.

U. S.  Environmental  Protection  Agency.  1976f.  Areawide assessment procedures
     manual, Volume  II.  Municipal  Environmental Research Laboratory, Office
     of Research  and  Development,  Cincinnati, OH, July, 579 p.

U. S.  Environmental  Protection  Agency.  1977a.  (Preliminary) Source assess-
     ment:  Phosphate fertilizer  industry, Phosphoric acid and superphosphoric
     acid.  Office of Research  and  Development, Washington, D. C.  Prepared
     by G. D.  Rawlings,  E.  A. Mullen,  and J. M. Nyers, Monsanto Corp., Dayton,
     OH, 93 p.

U. S.  Environmental  Protection  Agency.  1977b.  Industrial process profiles
     for environmental use,  Chapter  22:  The  phosphate rock and basic  ferti-
     lizers industry.  Office of  Research and Development, Cincinnati, OH.
     Prepared  by  P.  E. Muehlberg,  J.  T. Redding, and B. P. Shepherd, Dow
     Chemicals, Freeport, TX, and Terry Parsons and Glynda E. Wilkins, Radian
     Corporation,  Austin, TX, 208 p.

                                    207

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U. S. Environmental Protection Agency.  1977c.  Final guidelines document:
     Control of fluoride emissions from existing phosphate fertilizer plants.
     Office of Air and Waste Management; Office of Air Quality Planning and
     Standards, Research Triangle Park, NC, 274 p.

U. S. Environmental Protection Agency. ' 1977d.  Effects of phosphate minerali-
     zation and the phosphate industry on radium-226 in ground waters of central
     Florida.  Office of Radiation Programs, Las Vegas, NV, 125 p.

U. S. Environmental Protection Agency.  1978a.  A review of standards of per-
     formance for new stationary sources - sulfuric acid plants.  Prepared by
     Marvin Drabkin and Kathryn J. Brooks, MITRE Corp., McLean, VA.  Variously
     paged, 80 p.

U. S. Environmental Protection Agency.  1978b.  Central Florida phosphate
     industry areawide impact assessment program, Volume 1:  Program and
     industry description.  Performed by Texas Instruments, Inc., Dallas, TX,
     93 p.

U. S. Environmental Protection Agency.  1978c.  Evaluation of emissions and
     control techniques for reducing fluoride emissions from gypsum ponds in
     the phosphoric acid industry.  EPA-600/2-78-124.  Office of Research and
     Development, Washington, D.C.  Prepared by A.A. Linero and R.A. Baker,
     Environmental Science and Engineering, Inc., Gainesville, FL, 228 p.

U. S. Environmental Protection Agency.  1978d.  Air pollutant control techniques
     for phosphate rock processing industry.  Office of Air Quality Planning
     and Standards, Research Triangle Park, NC, 189 p.

U. S. Environmental Protection Agency.  1978e.  Source assessment:  Chemical
     and fertilizer mineral industry state of the art.  Office of Research
     and Development, Cincinnati, OH.  Prepared by J.C. Odsner and T.R.
     Blackwood, Monsanto Research Corporation, Dayton, OH, 138 p.

U. S. Environmental Protection Agency.  1978f,  Central Florida phosphate
     industry areawide impact assessment program; Volume 4:  Atmosphere.
     Performed by Texas Instruments, Inc., Dallas, TX, 146 p.

U. S. Environmental Protection Agency.  1978g.  Central Florida phosphate indus-
     try areawide impact assessment program, Volume 5:  Water.  Performed by
     Texas Instruments, Inc., Dallas, TX, 309 p.

U. S. Environmental Protection Agency.  1978h.  Central Florida phosphate
     industry areawide impact assessment program, Volume 7:  Alternative
     effects assessment.  Performed by Texas  Instruments, Inc., Dallas, TX,
     330 p.

U. S. Environmental Protection Agency.  1978i.  Draft areawide environmental
     impact statement, Central Florida phosphate industry.  Variously paged,
     187 p.

U. S. Environmental Protection Agency.  1978j.  Central Florida phosphate
     industry areawide impact assessment program, Volume 6:  Land.  Performed
     by Texas Instruements, Inc., Dallas, TX, 221 p.
                                   208

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U. s. Environmental Protection Agency.  1978k.  Central Florida phosphate
     industry areawide impact assessment program, Volume 2:  Environmental
     permits and approvals relating to phosphate mining and fertilizer manu-
     facturing in Florida.  Performed by Texas Instruments, Inc., Dallas, TX,
     85 p.

U. S.^Environmental Protection Agency.  19781.  Central Florida phosphate
     industry areawide impact assessment program, Volume 3:  Socioeconomics.
     Performed by Texas Instruments, Inc., Dallas, TX, 221 p.

U. S. Environmental Protection Agency.  1978m.  Particulate control highlights:
     Performance and design model for scrubbers.  Office of Research and
     Development, Washington, B.C.  Prepared by S. Yung and S. Calvert,  A.P.T.,
     Inc., San Diego, CA, 19 p.

U. S. Environmental Protection Agency.  1978n.  Particulate control highlights:
     Research on fabric filtration technology.  Office of Research and Develop-
     ment, Washington, D.C.  Prepared by R. Dennis and N.F. Surprenant,  GCA
     Corporation, Bedford, MA, 15 p.

U. S. Environmental Protection Agency.  1978o.  Particulate control high-
     lights:  Fine particle scrubber research.  Office of Research and Develop-
     ment, Washington, D.C.  Prepared by S. Calvert and R. Parker, A.P.T.,
     Inc., San Diego, CA, 12 p.

U. S. Environmental Protection Agency.  1978p.  (Draft) Environmental impact
     statement for proposed issuance of a new source National Pollutant  Dis-
     charge Elimination System permit to Occidental Chemical Company, Swift
     Creek Chemical Complex, Hamilton County, Florida, Summary document.
     Region IV Office, Atlanta, GA, 218 p.

U. S. Environmental Protection Agency.  1978q.  Final areawide environmental
     impact statement, Central Florida phosphate industry, Volume 1.  EPA
     904/9-78-026a.  Atlanta, GA, 80 p.

U. S. Environmental Protection Agency.  1979a.  Source assessment:  Phosphate
     fertilizer industry.  Office of Research and Development, Washington,
     D.C.  Prepared by Nyers, J.M., G.D. Rawlings, E.A. Mullen, C.M. Moscowitz,
     and R.B. Reznik, Monsanto Corp., Dayton, OH, 201 p.

White,  Bill.  1977-  Fertilizer cost trends - energy, environmental, trans-
     portation.  Fertilizer Progress.  Volume 8, January-February.

White,  Bill.  1978.  Energy, food, and fertilizers.  Fertilizer Progress.
     July-August, 5 p.

White,  J.C., T.N. Goff, and P.C. Good.  1978.  Continuous-circuit preparation
     of phosphoric acid from Florida phosphate matrix.  U.S. Department of the
     Interior, Bureau of Mines, Report of Investigations 8326, Washington,
     D.C., 22 p.

Wilson, Miles M.  1978=  Fertilizer granulation plant dust collection systems.
     In Proceedings of Environmental Symposium, The Fertilizer Institute, New
     Orleans, Louisiana, p. 217-232.
                                    209

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Wissa, A.E.Z.  1977-  Gypsum stacking technology.   Presented at the Annual
     Technical Meeting,  Central and Peninsular Florida Sections, American
     Institute of Chemical Engineers, Clearwater,  FL,  May 22, 1977.  44 p.
                                   210

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 1. REPORT No;	
   EPA-130/6-81-005
                                    TECHNICAL REPORT DATA
                             (1 lease read Instructions on the reverse before completing)
2.
                              3. RECIPIENT'S ACCESSION NO.
 4. TITLE AND SUBTITLE
   Environmental  Impact Guidelines for New  Source
   Phosphate Fertilizer Manufacturing Facilities
                              5. REPORT DATE
                              ____ _   ___________________
                              6. PERFORMING ORGANIZATION CODE
 7. AUTHOFKS)	
   Don R. McCombs,  James C. Barber, and Richard  Bonskowski
                              8. PERFORMING ORGANIZATION HLI'ORT NO.
 9. PERFORMING ORGANIZATION NAME AND ADDRESS
   Wapora, Inc.
   6900 Wisconsin  Ave.,  N.W.
   Washington, D.C.   20015
                                    613/A

                              10. PROGRAM ELEMENT N"6T
                              11. CONTRACT/GRANT NO.


                                    68-01-4957
 12. SPONSORING AGENCY NAME AND ADDRESS
   EPA, Office of Federal Activities
   401 M Street, S.W.
   Washington, D.C.   20460
                              13. TYPE OF REPORT AND PERIOD COVERED
                                    Final       	
                              14. SPONSORING AGENCY CODE

                                    EPA/100/102
 15. SUPPLEMENTARY NOTES
   EPA Task Officer  is Frank Rusincovitch,  (202)755-9368
 16. ABSTRACT
      This  guideline document  has been prepared to augment  the  information previously
      released by the Office of  Federal Activities entitled Environmental Impact
      Assessment Guidelines for  Selected New Source Industries.   Its purpose is to
      provide guidance for the preparation and/or review of environmental documents
      (Environmental Information Document or Environmental  Impact  Statement) which
      EPA may require under the  authority of the National Environmental  Policy Act
      (NEPA)  as part of the new  source (NPDES) permit application  review process.

      This document has been prepared in seven sections, organized in a  manner to
      facilitate analysis of the various facets of the environmental review process.
      The initial section includes  a broad overview of the  industry intended to
      familiarize the audience with the processes, trends,  impacts and applicable
      pollution regulations commonly encountered in the phosphate  fertilizer industry.
      Succeeding sections provide a comprehensive identification and analysis of
      potential environmental  impacts, pollution control technologies available to
      meet Federal standards,  and other controlable impacts.  The  document concludes
      with three sections:  available alternatives, a listing of Federal regulations
      (other  than pollution control) which may apply to the new source applicant,
      and a comprehensive listing of references for further reading.
17.
                                 KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                               b.lDENTIFIERS/OPEN ENDED TERMS
                                                                          c. COSATI Field/Group
   Phosphate fertilizer  plants
   Watet Pollution
   Air Pollution
                     Environmental  Impact
                     Assessment
10A
13B
 8. DISTRIBUTION STATEMENT

   Release Unlimited
                 19 SECURITY CLASS fTllis Report)
                      Unclassified
                 20. SECURITY CLASS (This page)
                      Unclassified
                                            22. PRICE
EPA Form 2220-1 (9-73)
                                             OU.S. GOVERNMENT PRINTING OFFICE:  1981  341-082/262 10

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United States                      Official Business
Environmental Protection            Penalty for Private Use
Agency                           $300
Washington DC 20460

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