SEPA
            United States
            Environmental Protection
            Agency
           Office of Air Quality
           Planning and Standards
           Research Triangle Park NC 27711
EMB Report 78-NHF-7
October 1979
            Air
Urea  Manufacture
                       Test Report
           Union Oil Company of
           California
           Brea, California

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           AIR POLLUTION EMISSIONS
               TEST OF AN UREA
             MANUFACTURING PLANT
           Contract No. 68-02-2815
                 Task No. 26
           EMB Report No. 78-NHF-7
                 Submitted to

     U.S.  ENVIRONMENTAL PROTECTION AGENCY
         EMISSIONS MEASUREMENT BRANCH
Research Triangle Park, North Carolina  27711
                 Submitted by

             ENGINEERING-SCIENCE
          125 West Huntington Drive
          Arcadia, California 91006
                  -i-

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                                   PREFACE

     The work  reported  herein was  conducted by personnel  from Engineering-
Science, Inc.  (ES),  Arcadia,   California  and  McLean,  Virginia;  the  GCA/
Technology Division  (GCA);  the  Union  Oil  Company,  Brea,   California;  the
Analytical Research  Laboratory,  Inc.  (ARLI);   and  the  U.S.  Environmental
Protection Agency (EPA).
     The scope  of  work  issued  under  EPA  Contract  No.  68-02-2815,  Work
Assignment No.  26,  was under  the  supervision of  the  ES  Technical Director,
Mr. John T.  Chehaske.   Mr. Dennis  Becvar served as Project  Manager  and was
responsible for  summarizing the  test  and  analytical data   in  this  report.
Analysis of  samples  performed at  the   ES   field  laboratory  was  under the
direction of  Ms.  Stefanie  Fullmer.  Analysis  of  samples  conducted  at the
ES laboratories  located  in McLean,  Virginia  was  under  the direction  of
Mr.  Scott  Lambert.  Kjeldahl  analysis  was performed at  the  ARLI  labora-
tories under the direction  of Mr. Ray R.  Jay.  Process samples were analyzed
at the Union Oil, Brea,  California  labs under the  direction of Mr. Robert W.
Waddell.
     Mr. Mark  I. Bernstein and Mr.  Stephen  K.  Harvey of GCA were responsi-
ble for monitoring  the process  operations  during  the testing program.   GCA
personnel were  also  responsible for   writing  the  Process   Description  and
Operations Section, along with Appendix N of  this report.
     Members of  the Union  Oil  Company,  Brea,  California,   whose assistance
and guidance  contributed  greatly  to the  accomplishments of  the test  program
include Mr. J.  D.  Swanburg, Plant Superintendent and  Mr. Robert W. Waddell,
Process and Control Superintendent.
     Mr. Eric  A. Noble,  Office of Air Quality Planning and  Standards, Indus-
trial Studies  Branch,  EPA, served  as Test Process  Project  Engineer  and was
responsible for coordinating the process operations monitoring.
     Mr. Clyde  E.   Riley,  Office   of  Air  Quality  Planning   and  Standards,
Emissions Measurement  Branch,  EPA,  served  as  Technical  Manager  and  was
responsible for coordinating the emission test program.
                                       -ii-

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                            TABLE OF CONTENTS
SECTION I




SECTION II




SECTION III




SECTION IV




SECTION V
PREFACE




LIST OF FIGURES




LIST OF TABLES






INTRODUCTION




SUMMARY AND DISCUSSION OF RESULTS




PROCESS DESCRIPTION AND OPERATION




LOCATION OF SAMPLING POINTS




SAMPLING AND ANALYTICAL PROCEDURES
                                                                        ii




                                                                        iv
1-1




II-l




III-l




IV-1




V-l
                        "Appendices Not Included'
                                    -iii-

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                             LIST OF FIGURES
1-1       Urea Flow Diagram                                            1-2

II-l      Particle Size Summary - Urea Cooler                          11-20
II-2      Particle Size Summary - Fertilizer Grade Urea
            Prill Tower Scrubber Inlet                                 11-22
II-3      Particle Size Summary - Feed Grade Urea
            Prill tower Scrubber Inlet                                 11-24
II-4      Six Minute Averages of April 2, 1979 Opacity Readings
            on the Rotary Cooler                                       H-29
II-5      Six Minute Averages of April 4 and 5, 1979 Opacity
            Readings for the Urea Prill Tower Feed Grade               11-30
II-6      Six Minute Averages of April 4 and 5, 1979 Opacity
            Readings for the Urea Prill Tower Fertilizer Grade         11-31

III-l     Urea Flow Diagram                                            III-2

IV-1      Sampling Point Locations - Urea Prill Tower Scrubber         IV-2
IV-2      Schematic of Sampling Location - Urea Prill Tower
            Scrubber Inlet                                             IV-3
IV-3      Schematic of Sampling Location - Urea Prill Tower
            Scrubber Outlet                                            IV-4
IV-4      Overhead Schematic of Prill Tower Scrubber Outlets           IV-5
IV-5      Urea Prill Tower Scrubber Solution or Liquor Sampling
            Point                                                      IV-7
IV-6      Observer Positions                                           IV-8
IV-7      Fertilizer Grade Urea Rotary Cooler Sampling Site            IV-11
IV-8      Schematic of Sampling Location - Rotary Cooler Outlet
            Duct                                                       IV-12
                                    -iv-

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                              LIST OF TABLES
1-1       Summary Log for Fertilizer Grade Urea Cooler Sampling
            on April 2, 1979                                            1-6
1-2       Summary Log for Various Testing of Urea Prill Tower
            on April 3, 1979                                            1-7
1-3       Summary Log for Fertilizer Grade Urea Prill Tower
            Sampling on April 4, 1979                                   1-8
1-4       Summary Log for Fertilizer Grade Urea Prill Tower
            Sampling on April 5,'1979                                   1-10
1-5       Summary Log for Feed Grade Urea Prill Tower Sampling
            on April 5, 1979                                            1-11
1-6       Summary Log for Feed Grade Urea Prill Tower Sampling
            on April 6, 1979                                            1-12

II-l      Percent Urea Collected in Sulfuric Acid Impingers             II-2
II-2      Percent Urea Collected in Sulfuric Acid Impingers             II-3
II-3      Percent Urea Collected in Sulfuric Acid IMpingers             II-4
II-4      Summary of All Engineering-Science Colorimetric Urea
            Analysis Calibration Graphs                                 II-8
II-5      Summary of All TRC Colorimetric Urea Analysis
            Calibration Graphs (Oct. 1978 and Aug. 1979)                11-13
II-6      Summary of Formaldehyde Results for the Urea Cooler
            Fertilizer Grade Emissions Test                             11-16
II-7      Summary of Formaldehyde Results for the Urea Prill Tower
            Fertilizer Grade Emissions Test                             11-17
II-8      Summary of Formaldehyde Results for the Urea Prill Tower
            Feed Grade Emissions Test                                   11-18
II-9      Summary of Urea Cooler Particle Sizing Test Results           11-19
11-10     Summary of Prill Tower Scrubber Inlet Fertilizer Grade
            Urea Particle Sizing Test Results                           11-21
11-11     Summary of Prill Tower Scrubber Inlet Feed Grade Urea
            Particle Sizing Test Results                                II-23
11-12     Opacity Averages During Sampling Runs                         II-25
11-13     Summary of Prill Tower Scrubber Gas Velocity and Gas
            Volume Data                                                 11-32
11-14     Summary of Pressure Drop Readings at Prill Tower
            Scrubber During Feed Grade Urea Testing                     11-33
11-15     Summary of Pressure Drop Readings at Prill Tower
            Scrubber During Feed Grade Urea Testing                     11-34
11-16     Summary of Ambient Temperature and Relative Humidity
            During Rotary Cooler Testing                                11-36
11-17     Summary of Ambient Temperature and Relative Humidity
            During Prill Tower Fertilizer Grade Urea Testing            11-37
11-18     Summary of Ambient Temperature and Relative Humidity
            During Prill Tower Feed Grade Urea Testing                  11-38
                                      -v-

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                         LIST OF TABLES (CONT'D.)
11-19     Summary of Sieve Analysis and Bulk Density
            Measurements on the Rotary Cooler and Prill Tower          11-39

III-l     Average Values and Ranges for Process Equipment
            Operating Parameters During Mass Emissions Test of
            Cooler, 4/2/79                       ,           "           III-5
III-2     Average Values and Ranges for Process and Control
            Equipment Operating Parameters During Mass
            Emissions Tests of Prill Tower - Fertilizer Grade          III-7
III-3     Production Rates During Mass Emissions Tests                 1II-8
III-4     Average Values and Ranges for Process and Control
            Equipment Operating Parameters During Mass Emissions
            Tests of Prill Tower - Feed Grade                          111-10
                                     -vi-

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 SECTION I
INTRODUCTION

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                                  SECTION I
                                 INTRODUCTION

     Section III of  the  Clean Air Act  of 1970 charges  the  Administrator of
the U.S.  Environmental  Protection Agency  (EPA)  with  the responsibility  of
establishing Federal  standards  of  performance  for new  stationary  sources
which may  significantly   contribute  to  air   pollution.   When  promulgated,
these standards  of  performance  for new  stationary sources (SPNSS)  are to
reflect the degree  of  emission limitation achievable  through application of
the best  demonstrated  emission control  technology.   To  assemble  this back-
ground information,  EPA utilizes emission data obtained from uncontrolled and
controlled sources involved in the particular industry  under consideration.
     Based on the above  criteria, EPA's  Office  of Air  Quality  Planning and
Standards (OAQPS) selected  the Union Oil  Company's urea manufacturing plant
at Brea,  California  as a site  for  an emission test program.  The test pro-
gram was  designed  to provide  a portion  of  the  emission data base  required
for SPNSS for the processes associated with the production of urea.
     The EPA  Emissions   Measurement  Branch  (EMB),  contracted  Engineering-
Science (ES)  to  collect  data  for  urea manufacturing  plants.   The  data
reported herein  will  be  evaluated  to  determine the  degree  of  emission
reduction achievable through application  of one  type of demonstrated control
technology.  This report  presents the  results of  a  test program conducted
during the week of April  2, 1979.
     The manufacture of  urea  includes  the use of  a  prill  tower  to produce
the "prills"  of  urea.   Liquid urea  is pumped to  a rotating chamber  at the
top of  the  prill   tower.   This  chamber  contains several  small  openings,
through which urea  droplets are  sprayed.   As  the droplets  fall through the
ambient air inside  the  prill tower, they  dry  to  form  the urea  product (see
Figure 1-1).  The Union  Oil prill tower  operates  twenty-four hours  per day,
365 days  per year and  can  be  used  to  produce  either  a feed grade or ferti-
lizer grade  of  urea.   The  chemical  processes are identical,   however,  the
prill tower operation is  changed for feed grade in order to produce a smaller
sized urea granule.
                                        1-1

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                                    _*.TO SEWER
UREA - UNION OIL COMPANY OF CALIFORNIA
            BREA, CALIFORNIA
M
ro

CESS " ^
NSATE MAKEUP
SCRUBBI
99.8 % UREA^
FOR
:RS
.• b

V
PRILL
TOWER
J*
                                       BUCKET
                                      ELEVATOR
                 )FFSIZE,TO  DISSOLVIM9  TANK
                                                           TO ATMOSPHERE
                                                    SCREEN
                                                                1
    ROTOCLONE
     SCRUBBER
                                                                             SCRUBBER  LIQUOR
                                                                             TO DISSOLVING TANK
                                                                    COOLER
                         AGRICULTURE (FERTILIZER)
                         GRADE PRODUCT
                                                                                    PEED  GRADE
                                                                                    PRODUCT
                                                                  SAMPLING P01KTS
                                                                  I. ROTARY  DRUM COOLER
                                                                  Z, INLET  TO K£ SCRUBBER
                                                                  3. OUTLET  FROM NE SCRUBBER

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     The emissions  control device  used  on  the  250-foot  high prill  tower
is a  group  of four  scrubbers located  at  the top.   The four  scrubbers  are
operated simultaneously and have a common sump and pump system for collecting
and recycling the scrubber  solution.  ES sampled  the  inlet  and  outlet simul-
taneously on  one of  the  four  scrubbers  during  fertilizer  and feed  grade
operations.   Prill tower sampling occurred on April 3, 4 and 5 for fertilizer
grade and April 5 and 6 for feed grade urea.
     In addition  to  the  prill  tower  testing, ES  sampled the  uncontrolled
emissions of  the  urea  cooler.   The  cooler is  connected  by  a  conveyor to the
prill tower   product  outlet  during  fertilizer  grade  urea  manufacturing.
Testing of the urea cooler occurred  on April 2, 1979.
     The sampling  data collected  from the  prill tower  scrubbers  and  urea
cooler were  used  to  determine  the  mass  emissions  of  urea,   ammonia,  and
formaldehyde.
     All emission  tests  conducted   at  this   facility  were  performed  only
during times  of  normal  operation  as described  in   Section   III  "Process
Description and  Operations".    The   emission  testing  program   conducted  at
this plant consisted of the following:
     1.  Particulate:  The  three  repetitions of concurrent inlet and outlet
     test runs were  performed  on the  northeast  prill tower  scrubber.   The
     tests were conducted  using  a modified EPA Method  5 sampling train which
     provided velocity,  moisture and  particulate  data.   The  modification
     included six  impingers  in  series.   The  first   two  were  filled  with
                           v
     deionized water and  the  second  two were  filled  with IN  sulfuric acid.
     The fifth  impinger was  dry and  the  sixth  contained  silica  gel.   No
     in-line filters were used.
     2.  Particle  Size:   Data were   collected  at  the  inlet to  the  northeast
     scrubber and  on the uncontrolled emissions of the  cooler.   An Anderson
     six-stage cascade impactor with pre-separator was used.
                                         1-3

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3.  Visible Emissions:  Data  were collected by one observer  during  the entire
course of the test.   Readings were taken  at several locations  including some
readings approximately fifty feet from the outlet.  Observations were performed
in accordance with EPA Method 9 guidelines.
4.  Process Samples:  Grab  samples  of urea product were  collected once during
each test run.  They  were collected at the conveyor before  urea is  carried to
the cooler and  storage  bins.   Bulk density  and sieve analyses  were performed
by ES, while  analyses  for ammonia,  urea and formaldehyde  concentration of the
product samples were conducted by Union Oil laboratory  personnel.  The analysis
was performed on an aliquot of the  samples used for the  bulk density and sieve
analysis.
5.  Scrubber Solution:  Samples of  the outlet scrubber solution were collected.
The scrubbers have a common sump which serves all four scrubbers.  The solution
from the sump is  then pumped  through  a low pressure manifold system.  It is at
this location that  scrubber  solution grab  samples  were taken,  measuring pH,
temperature, urea, ammonia, ect.
6.  Scrubber  Velocity  and Differential Pressure:   Method 5  sampling  occurred
on only one of  the  four  scrubbers.   On the remaining  three scrubbers, velocity
traverses were  performed  before  and after each Method 5  sampling run.   During
sampling runs,  velocities through  the scrubber  were  monitored  every  fifteen
minutes at a  single  average  point.  These  data will be used to determine total
air flow through  the  prill tower and  to  estimate total emissions.   Also, the
differential pressure across  all  four scrubbers was monitored  during  each run
using water-filled U-tube manometers.
7.  Relative  Humidity  and Ambient  Temperature:  The  prill  tower is  operated
using ambient air.   In  order to  establish operating  conditions  for the prill
tower, relative humidity  and ambient temperature  data  were  collected  during
the sampling runs.
8.  Urea Cooler Particulate:   Three  runs  of modified Method 5  sampling were
conducted on the  outlet air  duct of the rotary  cooler.-  The test location was
just before the rotoclone scrubber.   Urea process  samples  were  collected  at
the inlet and outlet of the cooler.
                                        1-4

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     ES personnel  were responsible  for  collecting  and measuring  the  above
emission parameters.   Simultaneously, GCA was  responsible for monitoring and
recording necessary process and control equipment operating parameters.
     Most of  the  test runs  were  discontinuous due  to excessive  loading at
the inlet  sampling locations.  These  interruptions  which also  delayed  the
concurrent outlet  sampling  were encountered throughout the  test  program as
indicated in Tables 1  through 6 (Daily Summary  Logs).
     The following  sections of this  report cover the  summary of  results,
process description and operation, location  of  sampling points, and sampling
and analytical procedures.  In  addition,  Appendix L  contains  the summary  re-
sults for the Quality  Assurance Audit  samples  supplied by the EPA.  Detailed
descriptions of  methods  and  procedures,  field  and  laboratory  data,  and
calculations are presented in various appendices, as noted.
                                         1-5

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                                              TABLE 1-1
SUMMARY LOG FOR FERTILIZER GRADE UREA COOLER SAMPLING

ON APRIL 2, 1979

Union Oil, Brea, California
Urea Participate Testing Meteorolocy
Clock Production
Time Race Inlet
(tons/hr)
1020
1030
1045
1048
1100 Data not
1110 recorded Started Run 1
1115 during
1130 these
1133 times
1145
1146 Changed Ports
1157 Continued
1200 1
1215 . ' 1
1221 Run 1 Completed
1230
1300 Started Run 2
1302 Stopped
1306 Continued
1308 Stopped
1315
1330 Continued
1345 ]
1358 Changed Ports
1400
1415
1430
1433
1445
1500
1506 Continued
1515 j
1524 Run 2 Completed
1530
1541
1545
1550
1556
1600
1613 Started Run 3
1615
1630
1640 . ,
1645 . Changed Ports
1655 Continued
1657 Stopped
1700
1701 Continued
1703 Stopped
1707 Continued
1709. Stopped
1713 Continued
1715 Stopped
1721 Continued
1730 |
1731 Run 3 Completed
1806
1813
Visible Particle Product Relative
Emissions Sizing Sample Humidity
(%)
57
51
47
. Crab ill
Inlet 43

43
43
Crab-#l
Outlet 42

36
39
35
43




39
(Prill 36
Tower) 31

Started Grab #2 40
Inlet 42
45
Crab //2
{ Outlet 43
Stopped 46

43

Continued 45
1 Started
I Run 1 Grab 03 45
Stopped ]f . Inlet
Completed
Run 1 44

43
43
Grab «
Outlet 38


36





31

32
Started
Completed
Run 2
Temperature

(°F)
66.5
69.0
70.5

73.0

71.0
72.5

71.0

73.0
72.0
74.0
74.'0




77.0
77.5
79.0

75.0
74.5
79.0

73.0
72.0

/l.O

70.0

68.5


68.5

63.5
68.5

70.0


70.5





70.5

70.0



Urea
                                                    1-6

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TABLE  1-2

SUMMARY
LOG FOR VARIOUS
TESTING OF
UREA PRILL TOWER

ON APRIL 3, 1979


Union Oil,
Brea, California
Meteorology . Velocity
Clock Production.
Time Rate
(tons/hr)
0820
0920
0945
0952 Data not
0959 recorded
1045 during
1110 these
1140 times
1146
1149
1250
1330
1345
1350
1400
1415
1425
1430
1445
1448
1500
1515
1530
1545
16CO
1604
1605
1615
1630
1635
1637
1645
1652
1700
Visible
Emissions

Started
Stopped
Continued
1
1
Stopped
Continued
Stopped


Continued

I
Stopped


Continued


\r
Stopped


Continued
I
Stopped
Continued
1
1
Stopped




Particle
Sizing




Started
Completed
Run 3


Started
Completed
Run 4

















(Cooler)

Started
I
Completed
Run 1
Relative
Humidity
(Z)











26
26

24
23

22
21

25
29
29
27
26


25
26


28

26"
Temperature
NW Unit
<°F)











79.5
79.5

80.5 Complete
85.0 Traverse

84.5
85.0

84.0
81.0
80.0
79.5
80.5


80.0
76.0


75.5

74.5
Traverse Monitoring

S!i Unit SW Unit












Complete
Traverse




Complete
Traverse















    1-7

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TABLE 1-3
SUMMARY LOG FOR FERTILIZER GRADE UREA PRILL TOUER SAMPLING
ON APRIL 4, 1979
Union Oil, Brea, California



Urea Particulate Testing2 Meteorology
Clock Production Visible Particle Product Relative
Time Rate Inlet Outlet Emissions Sizing Sample Humidity
(tons/hr) (%)
0819
0328
0345 Started
0900
0915
0930
0945
0947 Started
0950 Run 1
0954
0955 14.8
0957
0958
1000 Started
1009 Run 1
1010
1011
1015
1016
1017
1020
1028
1029
1030
1045
1046 |
1048 Changed Ports v
1059 Changed Ports
1100
1104 14.8 Cont'd
50
41
33
33






27



27


Crab 91
Outlet

27
25





1115 Run 1 Stopped 23
1116
1120 Cont'd Run 1 Cont'd
1129
1130
1131
1135
1145
1146 Y
1156 Stopped
1159
1200 Continued
1201 1
1202 i
1210 14.8 I
1212 Completed
1213 Run 1
1214
1215
1216 Y
1217 Completed

22


24










20


1220 Run 1 Stopped (Cooler)
1230 Started 23
1237 Completed
1247 Run 2
1400 24
1415 24
1424 Started
Run 2
Temperature

(°F)



65.0
70.0
74.0
75.5






78.5



78.5





79.5
80.0





82.5



82.5


81.5










81.0



80.0


86.5
87.0


   1-8

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                                          TABLE 1-3 (Continued)

                       SUMMARY LOG FOR FERTILIZER GRADE UREA PRILL TOWER SAMPLING
                                            ON APRIL 4, 1979
                                       Union Oil, Urea, California

Urea Participate Testing3 Meteorology
Clock Production Visible Particle Product Relative Temperature
Time Rate Inlet Outlet Emissions Sizing Sample Humidity
(tons/hr) (%) ("[••)
1430 14.8
1431
1435
1436
1437
1440
1444
1445
1447
1448
1450
1459
1500
1501
1510
1514
1515
1516
1528
1529
1530
1531
1536
1539
1545
1546
1547
1550
1559
1600



Started
Run 2











1












Changed Ports



Continued 24 87.0


















\






23 87.5




21 87.0

Grab it2
Outlet
22 87.5



Stopped 23 85.0
r
Changed Ports
Continued



Continued


1601 14.8
1614
1615
1616
1628
1629
1630
1631
1644
1645
1646
1651
1655
1656
1657
1658
1700
1701
1718
1731
1740
1745
1755
















•
Completed
Run 2 \
23 85. C




Cor









Completed
Run 2



Stop;
tinued 26 83.0


24 82.0



28 80.0

27 80. 5





'ed 30 79.0



(Cooler)
Started
Completed
Run 3
Urea partlculates also analyzed  for  ammonia content
                                                       1-9

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                                                    TABLE I-t

                            SUMMARY LOG FOR FERTILIZER CRAOE UREA PRILL TOWSR SAMPLING
                                                ON A?1UL 5, 1979
                                           Union Oil, Brea, California
Urea Particulate Testing3 Meteorology
Clock Production Visible Particle Product Relative
Time Rate Inlet Outlet Emissions Sizing Sample Humidity
(tons/hr) (Z)
0926
0930 Started '34
0935
0940
1000
1015 14.5
1016
1017
1020
1025
1026
1030
1031
1040
1041
1045
1043
1C49
105(1
1051
1055
1059
1100
1102
1110
1111
1114
1115
1120
1125


Started
Run. 3



















.
1130 14.5
1131
















,


30
29





30

Crab #3
Outlet
34






30




Stopped 26
Continued



1132 Changed
1133 Plant down Ports ,, >

7.7



1135 Stopped
1140
1145 29
1155
1200 29
1215 27
1220 14.5 Started Cont'd.
1224
1225
1226
1230
1235
1244
1245
1250
1259
1300
1305
1305 ^
Run 3














Continued







1308 14.5 Changed
1315 Ports
1317
1313 Continued
1320
1329
1330
1335
1344 14.5
1345
1347
1350
1357
1358
1359
1400
1402
1409
1415
1416
1419
1425












••

















Completed
Run 3


r
Stopped



30


26


23



26




26








26
Stopped

29

Continued
Completed
,' Run 3
1430 14^5 Change to Feed Grade Urea 30
Temperature
(°F)

74.5


78.5
81.5





80.0



79.0






79.0




85.0


81.5





81.0

81.0
82.0




81.0


83.0


88.0



87.5




88.0








83.5


89.0




87.5
a)  Urea particulars  also analyzed for an-onia content.
                                                            1-10

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                                                     TABLE 1-5

                               SUMMARY LOG FOR FEED GRADE UREA PRILL TOWKR  SAMPLING
                                                 ON APRIL 5,  1979
                                           UNION OIL,  UREA,  CALIFORNIA

Urea Particulate Testing-1
Clock Production
Time Race Inlet Outlet
(tons/hr)
1545 8.92
1600
1615
1630
1641
1642
1644
1645
1646
1647
1649
1650
1658
1659
1700
1702
1705
1715
1716
1720
1723
1727
1723
1730
1735
1741
1744
1745
1750 '



Started Started
Run 1 Run 1






















V >























1753 8.92 Changed Equipment
1757
1758
1800
1815
1830
1852
1859
1915
1930
1945
2000
2004
2015
2030
2040
2043
2044
2045
2055
2059
2100
2110
2114
2115
2117
2125
2128
2129
Ports Problems
Test
Voided


Started
Run 1A



,



t
Changed
Ports

Continued
Continued












2130 ¥
2140 8. 92
2144
2145
2146
2152
2155
2159


i >
Comp


















eted
Completed Run 1A
Run 1
2200 8.92
2209
2210
2215
2216
Meteorology
Visible Particle Product Relative
Emissions Sizing Sample Humidity
U)
25
26
26
26

Sta ted

26






26


31


Crab Si
Outlet

31

Stopped

33




37
39
40


46
51
52
53

58
57



63


63


57




63


65




64




Temperature
(°F)
85.5
82.5
81.5
79.5



79.0






78.0


76.5





76.5



72.5




71.5
70.0
69.5


67.0
66.0
64.5
63.0

62.5
61.5



60.0


59.5


61.0




59.5


59.0




60.5




a) Urea parttculates also analyzed for  ammonia  content
                                                            1-11

-------
                                                    TABLE 1-6

                              SUMMARY LOG FOR FEED GRADE UREA PRILL TOWER SAMPLING
                                                ON APRIL 6, 1979
                                           Union Oil, Urea, California

Urea Particulate Testing3 Meteorology
Clock Production Visible Particle Product Relative Temperature
Time Rate Inlet Outlet Emissions Sizing Sample Humidity
(tons/hr) (%) (°F)
0911
0920
0931
0932
0946
1009 Started
1015 Completed 53 67.0'
1022 Run 1
1030 54 68.5
1045 8.92 . 51 69.0
1055
1057
1100
1102
1103
1104
1109
1110
1115
1116
1125
1130
1131
1.140
1145
1146
1151
1159
1200
1205 8.
1207
1209
1211
1212
.1213
1214
1215
1220
1223
1230
1231
1243
1245
.1246
1247
1259
1300
1310
1315
1316
1323
1325
1329
1330
1331
1333
1335
Started
Started Run 2
Run 2















•
92
. , Cha
Sta ted 49 71.0





47 71.0


48 70.0


48 70. 0

Grab 92
Outlet
StooDed 48 70.0
ContM
ged
Changed Ports I
Ports Continued \y





Continued











Stopped


47 72.0


54 70. 5

Cont'd
51 72.0


V
Stopped 51 72.5
Cont'd
49 74.5
'
Completed
Test 2

48 75.0
v
, Stopped
Completed
1340 8 92 Run 2
a)  Urea participates also analyzed  for ammonia content
                                                         1-12

-------
                                              TABLE 1-6 (Continued)

                              SUMMARY LOG FOR FEED GRADE UREA PRILL TOWER SAMPLING
                                                ON APRIL 6, 1979
                                           Union OH, Urea, California
Urea Particulate Testing3 Meteorology
Clock Production Visible Particle Product Relative
Tine Rate Inlet Outlet Emissions Sizing Sample Humidity
(tons/hr) (%)
1345 48
1400
1422
1530 8.92 Started
1534
1605
1612
1615
1616
1620
1622
162.9
1630
1635
1644 .
1645
1650
1632
1659
1700
1705
1710
1714
1715
1717
1720
1722
1724
1725 1
Completed
Started Run 2
Run 3 Started

















Run 3 52
















Changed
Ports
,


Cont'd

60




Grab #3
Outlet
59



63

V
i Stopped
Changed
' Ports Cont'd
1730 Stopped 66
1745 65
1752 8.92 Continued Continued
1755
1759
1800
1810
1814
1815
1825
1823
1829
1830
1831
1840
1844
1345
1855
1859
1900
1904
1915
1931
1934




































65


63



66



69


f 73
Completed Completed
Run 3 Run 3 71
Started
i . Completed
1935 8.92 Run 3
1959
2002
2004
2025
2031
2045
Temperature
(°F)
73.5






71.0




67.5






66.0



65.0





62.5
64.0



64.0


64.5



62.5



63.0


61.0

61.5









a) Urea partlculates  also  analyzed  for ammonia content
                                                        1-13

-------
            SECTION II
SUMMARY AND DISCUSSION OF RESULTS

-------
                                SECTION II
                    SUMMARY AND DISCUSSION OF RESULTS

     Emissions testing was performed at the Union Oil Company of California
plant in Brea,  California, during the  week of April  2,  1979.   During the
testing program,  specific  pollutants  were  sampled  simultaneously  at the
inlet and outlet  of one of  the four scrubbers that  control the emissions
from the  urea  prill  tower.   The  outlet  of  the   fertilizer   grade  urea
rotary cooler was  also  monitored for specific pollutants.  In all instances,
sampling was  conducted during process  conditions which were considered to
be similar to those used during normal plant operation.  Process parameters
were carefully  observed by  representatives  from GCA  and  emission tests
were performed only when the processes appeared to be operating  normally.
     The manufacture of both fertilizer grade and feed grade urea generates
ammonia, urea and  formaldehyde  emissions  to the atmosphere.  The  use  of a
routine method of  testing,  such as EPA Method  5, would not yield  an accurate
measure of each of the pollutants.   Sampling  and analytical methods which
represented extensive  modification to  EPA Method  5 were  developed by  EPA.
These modifications  were  used  to determine  the  concentrations  of urea,
ammonia, and formaldehyde in the various air streams tested.
     However, the  results  for  urea  and ammonia appear  to  be atypical from
those of other  plants  tested by  EPA.   As  a  result of  this,  an extensive
review of the  ES  laboratory  procedures and analysis  was  conducted  by two
independent contractors.   A  review  of  their  results is  summarized  in the
following narrative.
     In the  review,  it was  attempted   to  trace  the urea  values presented
in the summary  tables  of  the report to the raw data  contained  in the lab-
oratory notebook  pages (see Tables  II-l  and  II-3).   These tables  present
the percent of  urea  collected in the acid  impingers.   The data shows that
the Union Oil  values are very high as  compared  to the values  obtained at
other urea plants.  Comments are as  follows:
                                     II-l

-------
                                  TABLE  II-l


         PERCENT  UREA COLLECTED  IN SULFURIC ACID  IMPINGERS
                           (values in mg of urea)
 Union Oil. 9rea.  California

 Prill Tow.vr Test  Fertilizer Grade  Mo. 1

 Northeast Stack                                            „     _ ,
 Inlet                                                      Percent Urea Collected
              Impq Water        Impo Acid        Total        	jn Acid	

               484               1380          1864                 74
               755               1071          1826                 59
               303                685           983                 69
Outlet

Run 1           653               1082          T735                 62
Run 2           610                552          1162                 43
Run 3           374                650          1024                 63
Prill Tower Test Feed Grade No. 1

Northeast  Stack
Inlet	

Run 1           321              1132          1453                 78
Run 2          2330              1173          3503                 34
Run 3          1939              1031          3070                 35


Outlet

Run 1         313               1164            1982                 59
Run 2         656               1065            1721                 62
Run 3         734               1300            2034                 64
Cooler Test Ho.  1
Inlet
              2133             75              2203                  3
              1803              0              7803                  0
              2146             43              2189                  2
Union 011,  Brea. California

Prill Tower Test Fertilizer Grade No. 2

Northeast  Stack                                           Percent Urea Collected
Outlet         Imog Water       impo Acid        Total              in Ursa

Run 1          77.9             1.6             79.5                 2.0
Run 2          50.1             1.6             51.7               .  3.0
Run 3          62.0             1.5             63.5                 2.4
Union Oil, 3rea, California

Cooler Test No. 2

Inlet

              5357             1.7             5359                 <1
              3780             1.5             3782                 <1
              4517             1.9             4519                 <1
                                           II-2

-------
                              TABLE II-2

     PERCENT  UREA COLLECTED  IN  SULFURIC ACID IMPINGERS
                      (values  in mg  of  urea)
Prill  Tower Test Fertilizer Grade .'lo. 1
Stack  A
Inlet

Run 1
Run 2
Run 3
Impq Water

449
622
502
  Impq Acid

  7.7
  9.8
  9.5
             Percent Urea Collected
 Total        	in Acid

 457                   2
 632                   2
 512                   2
Outlet

Run 1
Run 2
Run 3
33.0
85.4
59.7
 6.1
 7.5
 12.3
 39.1
 92.9
 72.0
16
 8
17
Stack C
Inlet

Run 1
Run 2
Run 3
304
217
275
  6.6
  3.8
 11.0
.311
 226
 286
Outlet

Run 1
Run 2
Run 3
 37.4
 66.6
 61.7
 5.2
 8.2
 7.8
 42.6
 74.8
 69.5
12
11
11
 Prill Tower Test Feed Grade No. 1
 Stack A
 Inlet

 Run 1
 Run 2
 Run 3
 380
 590
 534
10.0
 9.3
10.9
 390
 599
 545
 Outlet

 Run 1
 Run 2
 Run 3
 30.4
 94.0
111.0
 6.0
 6.9
 8.2
 36.4
 101
 119
16
 7
 7
Stack C
Inlet

Run 1
Run 2
Run 3
 411
 425
 463
   9.8
   9.0
   10.5
 421
 434
 474
Outlet

Run 1
Run 2
Run 3
 36.6
 86.6
 99.7
   7.0
   8.6
   7.4
 43.6
 95.2
107.
16
 9
 7
                                    II-3

-------
                                     TABLE  II-3


           PERCENT UREA  COLLECTED  IN SULFURIC  ACID  IMPINGERS
                             (values in mg of urea)


Prill  Tower Test Fertilizer Grade no. 2
 Inlet
                                                 Percent Urea Collected
    Impg Water       Iiroq Acid        Total        	in Acid	


      730              10             740                1.0
      232              12             244                4.9
      481              7.6            433.6              2.0
 Outlet

 Run 1
 Run 2
 Run 3
      '6.0
      17.1
      20.3
                               6.0
                              17.1
                              20.3
Outlet

Run 1
Run 2
Run 3
      11.9
      13
      14.6
                              11.9
                              13
                              14.6
                                        0
                                        0
                                        0
Granulator Test No.  1
Inlet
Run 1
Run 2
Run 3
Probe
Water
Wash
37,104
31.423
23.880
Impg
Water
27,176
28.665
16,320
Water
Total
64,280
60.083
40,200
Iinpg
Acid
0
1.5
0
Total
b4.230
60,090
40,200
Percent Urea Collected
0
<1
0
in Acid

Outlet

Run 1
Run 2
Run 3
15.3
31.0
24.6
22.6
35.8
28.1
37.9
66.8
52.7
1.62
7.08
9.33
39.5
73.9
62.0
 4
10
15
Granulator Test No.  2

Inlet       Ifiipqr Water
Kun 1
Run 2
Run 3
    23,905
    25.063
    26.218
          Impq Acid       Total      Percent Ursa Collected In Acid

          15.0           23.920                 <1
          27.0           26,090                 <1
          40.0           26,253                 <1
Outlet

Run 1
Run 2
Run 3
    65.9
    65.8
    57.1
          7.3
          5.2.
               70.6
               73.1
               62.3
                              7
                             10
                            '  8
                                          II-4

-------
1.  Appendix  G,  Section  I,   Discussion of  Analytical  Methods.
    The analytical  methods  for  urea,   ammonia  and  formaldehyde
    appear to be  correct  as explained in this  section.   However,
    there are errors in the presentation of  the calculations:
    a.  The urea colorimetric  analysis graph is correct.  The slope
        is similar  to   graphs done  by   other participating  labs
        (see EMB report 80-NHF-15).
    b.  The ammonia graph  is  similar to those done  at  other labs
        (see EMB  report 78-NHF-3).   The ammonia equation  should
        read:
                gNH3/ml = Abs. of aliquot  (not mgNH3/ml).
                               0.166
    c.  The formaldehyde equation  and graph  should have the units
        mg formaldehyde /ml.   Then the  graph would  be  similar to
        those presented by other labs.
2.  Appendix G,  Section II,  Laboratory Data Summaries; Section III,
    Copy of ES Laboratory  Notebook.
    The numbers presented  in  Tables  G-l and G-2 were  traced back
    to the raw data in  Section III.   The  scrubber  water data were
    not reviewed.
    a.  Table G-l presents  the  urea  colorimetric results in total
        mg.  It was possible to verify the sample number, volumes,
        dilution factors and absorbance  readings and calculations.
        The first dilution factor comes from the dilution of either
        50 or 100 mis to 250 ml.  The second  factor accounts for a
        10 ml aliquot  in  25 ml.  The third factor  comes  from the
        dilution of the  total sample to  1000  ml if the  original
        volume was less than 1000 ml. Although it  was  possible to
        follow the calculations, there was one very  serious omis-
        sion from  the  data  for  the prill  tower  fertilizer  and
        feed results.   These   samples wre  analyzed  on  4-14-79.
        The calibration curve  that corresponds  to  this  data could
        not be located.  It appears  that these results were  cal-
        culated using  calibration data  from  4-2-79 and  4-3-79.
                              II-5

-------
    Without a  calibration check  on the day  of the  analysis,  it
    is not possible  to judge  the validity  of this  data.   These
    samples contained  extremely  large  proportions  of  urea  in
    the acid  impingers.   In addition,  there are  no comments  on
    the appearance of these samples  after the color was developed.
    The fertilizer  grade  cooler  outlet  samples were analyzed  on
    4-3 and  4-5-79.   Calibration  data similar  to  that  obtained
    by TRC of  New England  on  a similar test  was  run  on  4-2 and
    4-3-79.  The  sample analyses  were repeated on 4-5-79  because
    the analyst noted  that the line  current  fluctuated when the
    readings were  being  taken  on 4-3.  On  4-5 the  Spec 20 was
    connected to a  stable power source.  The  majority  of  samples
    were calculated  from  the  data  of 4-3.   The   absorbances  for
    the acid  impinger  samples  were  low  as  should  be  expected,
    and since  the calibration  curve   appears  correct,  this  data
    is believed  to  be  correct.    However,   the   water  impinger
    absorbances (approximately   1.0  Abs.)   were  well  above  the
    highest point  on the calibration  curve  (0.58  Abs.)   These
    samples should  have   been   repeated  using  smaller  aliquots.
    These calculations of  urea in  the water portion are  invalid
    unless  it  was  determined  elsewhere   that  the  calibration
    graph was  linear up   to  1.0 Abs.   Normally  for  high  concen-
    trations, the  line  tends  to   flatten  out  so  that the  true
    results should actually  be much  higher  than  those presented
    in Table G-l.
b.  Table  G-2  presents  the ammonia colorimetric results as  total
    mg NH3.   The  method  of analysis  was  direct  nesslerization.
    It was possible  to verify the  sample  number,  volume,  four
    factors,  absorbance and calculation  of  mg   ammonia  in  the
    samples.   The dilution factors  for the prill  tower  fertilizer
    and feed  samples followed  the  EPA ammonia dilution procedure
    exactly with an  additional dilution of  100 —>  1000  recorded
    in the  notebook.   The  fertilizer  cooler  sample   dilutions
    were different and  were found in  the  notebook  next  to  the
    absorbance readings.
    The units  for  column  five should  be  y g/ml  (not mg/ml)  but
    the end  calculation was correct.  The  calculation was  based

                           II-6

-------
        on the equation  presented  in  Section  I  of  Appendix G  under
        ammonia analysis.   This   graph  is   very   similar  to  direct
        nessler ammonia  graphs  run countless  times  by lab  personnel
        with consistent  results.    Copies  of  the  ammonia  standards
        preparation done on 3-23-79 were found  in  the ES lab notebook.
        The lab notes stated that the absorbances were  read @ 405  nm,
        but the absorbance  readings were  not  found in  the  notebook
        copies.  The cooler samples were  run on 4-6-79 and  the  prill
        samples were run  on 4-14-79.    There  was  no  calibration data
        presented in the notebook  on   these  dates  or at  any   other
        time.  Since the  graph used for the calculations  agreed with
        reproducible graphs presented  by other  labs,  it  would  seem
        reasonable to  accept  the  calculations as   valid  except  for
        those with absorbance readings  above   0.65  (the highest point
        of the calibration  line).   The  two  samples  above  this  value
        should have  been  repeated  using a  smaller aliquot.   These
        were for the fertilizer  grade,  cooler outlet R2-1  and  R3-1.
3.   Appendix G, Section III, Copy of ES Laboratory Notebook
    The colorimetric urea analysis  calibration graphs have  been com-
    piled in an effort  to determine the consistency  of the  method as
    performed by ES  (.see Table  II-4).   Although the  concentration of
    the standard was not always  recorded with each run,  it was assumed
    that they were  consistent and  corresponded to the EPA Calibration
    Procedure.
    Graphs #2B and  3 appeared  to be used for  the sample  urea  calcu-
    lations.  The correlation coefficients were very  good,  the  slopes
    were similar to  graphs done at  TRC  and the y-intercepts  were very
    close to 0.000 Absorbance.   Samples analyzed  with these standards
    would be valid  (cooler  samples).  Graphs  2B and  3 may  be readings
    of the  same  standards.   The lack  of good linear  regression data
    makes using the  graph for  calculating results of samples done on
    4-14-79 questionable.
    In order to follow  proper colorimetric  analytical procedures,  the
    y-intercept should   pass  through 0.00 Absorbance.  The  remaining
    graph intercepts were much  higher  than  this.    The  other  seven
                                II-7

-------
                                                                       TABLE II-4
  Graph I
    1

    2A
 I
00
l-ab Page


   13

   13

   LW

   3I.W
   16
SUMMARY OF ALL ENGINEERING-SCIENCE COLORIMETRIC UREA
ANALYSIS
CALIBRATION GRAPHS
Linear Repression


Date
03-28-79
03-28-79
04-02-79
04-03-79



08-27-79
08-28-79
08-29-79
Calibration Points
Absorbancc at (mp/ml)
0.00 0.05 ~0.10 0.1S 0
.72 .92 1.20 2
0 .55 .65 .76 .
0 0.14 0.31 0.445 0
0 0.16 0.30 0.43 0
U18\ / 18 \
••'••
.17 / I .19J
\ *
.08 .12 .17 .18
0.0 .699 .866 .999 1.
0.0 .605 .805 .900 1.


.20 0.25
.15
.85
.58
.58

21

21
029
10
Corr.
Cocf.
r
.966
.904
.9991
.9994


.9214
.9792
.8828
.9374

Slope
in
9.56
3.82
2.93
2.86


0.98
0.64
4.72
4.99

Y-Incpt.
y_
.042
0.18
.002
.008


.04
0.088
0.247
0.183
                                                                                                                                   Continents
Spec 505.

Diluted with 11,0?

Diluted with clhnnol.

Oilier readings written
 be si ilu this Mis. appear
 to be absorbance vendini;  -
 much lower.  These appear
 in parentheses.

Rend  on Spec 20.  "needle
 waivcrcd,  recalibrated
 machine."  Some readings
 were crossed out.  Diluted
 with elhanol.

Readings drifted.

"Run  in Orange City Lab"  -
 Thcnc anpear to be the saino
 standards  from Graplt  5.
                                    08-30-79
                                0.0     0.400   0.625   0.850  1.08     1.2S ?      .9908  4.866   .093
 Run  in  Orange  City.

-------
    slopes varied greatly  from that  used  to  calculate the  sample
    concentrations and  the   correlation  coefficients  were  not  as
    good.
    During some  urea analysis  at ES,  comments  were  made  in  the
    notebook that ethanol was  used to  dilute the standards  and/or
    samples to volume after the color reagent  was added in order to
    "ensure clarity".  The only difference  between graphs  2A  and 2B
    was that water  was  used to dilute  standards  A and  ethanol  was
    used to dilute standards B.  The high value for  the y-intercept
    for Graph  2A  (0.18  Abs.) indicates that  there was  some  inter-
    ference (turbidity  or  improper color)  in these samples.   From
    this observation, one  might presume that the lab  water at ES
    introduced an  interference  in  the  standards.   In  accordance
    with the EPA  procedure,  all  samples  were  diluted  to 1000  mis
    with water  before  the  analyses   were  done.   For  most  of  the
    water samples, this was  a relatively small addition  of  water.
    The acid  samples,  however,  had much  smaller  volumes, so  that
    between 500-800 ml  of  lab water  were  added.   The  acid  samples
    were also diluted more for the urea analysis.   If  the  lab  water
    was the  source   of  interference,  then  the acid  samples  would
    have had more of the interfering  agent in them.  This hypothesis
    would be invalid  if the water used in the  field  sampling  trains
    and cleanup came  from the same source as  the  laboratory  water.
4.   Appendix H, Discussion of Kjeldahl Method
    The raw data  from the ARLI  notebook  was  reviewed  and a  brief
    study  of the discussion and  data  summary  was done.
    a.   The Kjeldahl  analytical  procedure  as  specified in the  EPA
        urea determination method was not  followed.  The  specified
        EPA Kjeldahl  urea analytical  procedure is referred to  as a
        "Direct  Method  with  Preliminary  Distillation  to   Remove
        Ammonia".  The Kjeldahl area  analytical  procedure  employed
        by the Analytical  Research Laboratories is referred to as an
        Indirect Method of Analysis.
                                II-9

-------
Direct Method with Preliminary Distillation to Remove Ammonia
A buffering  compound  is  added to the sample  and the solution
is then  distilled  (boiled)  to  remove  ammonia.   Digestion
reagents are then added to convert all organic nitrogen (urea)
to ammonia.   The solution  is distilled,  and  the  distillate
is analy.zed  for ammonia  either by  direct nesslerization  or
by titration.   The  urea  concentration  is  then  calculated,
stoichiometrieally from the  measured ammonia concentration.
Indirect Method
Two equal aliquots of  sample  are  drawn.   A buffering compound
is added to  the  first  aliquot and this solution  is  then dis-
tilled.  The distillate is  analyzed for ammonia.  The digestion
reagents are added to  the  second aliquot,  converting  organic
nitrogen (urea)  to  ammonia.   The  solution is  then  distilled
and this distillate is analyzed  for  ammonia.   Urea concentra-
tion is  calculated  by  subtracting  ammonia  nitrogen  (first
aliquot) from  total  nitrogen (second  aliquot)  and  applying
a stoichiometrie conversion factor.
The indirect method  of  analysis  used  by  ARLI is  susceptible
to inaccuracy,   since  errors  in  the  component analyses  (for
total nitrogen and  ammonia nitrogen) may  be  compounded  when
urea nitrogen is calculated by  subtraction.   Relatively  small
titrant volumes  were  used  in the ARLI titration analyses:  the
total nitrogen  and  ammonia  nitrogen titrant  volumes  ranged
from 5.0  ml to  10.0  ml.    In  order  to  minimize  titration
errors, it  has  been found  that titrant  volumes  of at  least
20 ml  should be  used.   A disadvantage  of  the  indirect  ti-
tration method  is  that  the   entire  sample  is used  for  one
titration; consequently, if  an error is  made or if a  result
is suspect,  there is no recourse for re-analysis.
Both of  the  Kjeldahl  urea  analysis  methods  require  that
correction factors be  applied  to  the  urea  and  ammonia  con-
centrations  in  order  to account  for the  conversion of  some
                       11-10

-------
        urea to ammonia  during distillation.  The  standard  correc-
        tion factor is:  7 percent of the urea content of the sample
        is converted  to  ammonia  during distillation1).   Thus,  the
        urea concentrations  should  be  increased  by 7  percent,  and
        the ammonia concentrations should  be decreased  by  a  stoich-
        iome trie ally equivalent amount.
        In the Laboratory  Data Summary,  the correction  for the  7
        percent conversion of  urea  to  ammonia during  the  distilla-
        tion step   was not  done  properly.   Seven  percent  of  the
        ammonia value was  subtracted from  itself  to give the  cor-
        rected ammonia value.  The  correct method is to  subtract  7
        percent of  the  ammonia  equivalent  to  the  corrected  urea
        value.  Doing this would  make  many of  the  ammonia  results
        negative.   However, this  would be  consistent  with  results
        obtained at other sites.
5.  Appendix L, EPA Audit Sample Analysis Results
    Two sets  of  audit samples were analyzed by  the Kjeldahl  urea
    method by  Analytical Research  Laboratories.   The  second  set
    was also  analyzed by  the colorimetric urea  method  by  ES  in
    August 1979.   Graphs  4 to 7  in Table  I were  generated  during
    the analysis of  the  audit samples.  It  was attempted  to  calcu-
    late the audit results based  on the sample absorbance readings
    obtained when  these graphs were  run.   Calculations  based  on the
    three graphs did  not yield  results that matched  the  reported
    values.  Calculations using the  equation presented  in Appendix
    G-l for the urea sample  analysis  did  not  yield  corresponding
    results.  The  audit calculations were  not done  out  in  the  note-
    book and  it  was  not  possible   to  follow the  dilution  and/or
    colorimetric absorbance  data.   Due  to  incomplete  data  within
    the report it was not possible  to  verify the  reported values.
1)  Standard Methods of Water and Wastewater Analysis,   APHA,   AWWA,
    WPCF, 14th edition, 1975, p.  408.
                                 11-11

-------
6.   Co lor line trie Analysis by TRC at a Urea Facility
    In October 1978, TRC performed its first urea sampling and analy-
    tical program for the  Emission  Measurement Branch.   The colori-
    metric urea procedure  was  the same  as  used by  ES.   Analytical
    calibrations and problems  realized  by TRC have  been summarized
    in an effort to  point out some of the  possible sources of problems
    with the ES analytical data.
    a.  Table 11-5 lists the calibration data for six series of urea
        standards done over a period of ten days.   The seventh series
        of standards were  done almost one  year later.   The linear
        regression data were consistently good  for  these analyses.
        The correlation coefficient approached 1.000 (perfect corre-
        lation) and the y-intercept approached 0.000 absorbance.
    b.  A  problem  occurred  with  the  color  development  of samples
        extremely high in ammonia (11 to 40 grams).  After the color
        reagent was  added,  the  sample  color  was  similar  to  the
        blanks, but the absorbance  readings  were  high.   The sample
        pH's were high due to  the amount  of  ammonia. These samples
        were repeated;  first diluting them and then adjusting the pH
        to less than seven with hydrochloric  acid  before adding the
        color reagent.    The  absorbance  of  the  samples then  were
        close to 0.000  which corresponded to  the  visual appearance
        of the  samples.   The regular samples  had  ammonia values in
        the range of  0.1 -  1.0 grams and proper  color development
        was observed.  The ES  samples  were also  in this  same range,
        so the high  urea  values  in  the  acid  impinger  samples  were
        probably not due to ammonia interference.
        To summarize, the notebook  raw analytical data  presented in
        Appendix G, Section III does not provide proof of consistent
        and reliable  calibration  data  for   the  urea  colorimetric
        analysis.  It does  show  that  an effort  was made  to  rerun
        standards on different instruments,  in  other  laboratories,
        and with different solvents (water or ethanol) in an attempt
        to achieve reliable  calibrations.  The laboratory  water may
                                11-12

-------
1 JJ-M-89
2 JfM-90
5 MF5-61
4 MP5-68
M
H
£ 5 MP5-78
6 Mf5-78
7
10-18-78 .00
10-19-78 .00
10-20-78 .00
10-24-78 .OC
10-25-78 .0(
10-27-78 .01
08-28-79 .01
                         TABLE II-5


     SUMMARY OF ALL  TRC COLORIMETRIC  UREA  ANALYSIS
      CALIBRATION'GRAPHS  (OCT.  1978 AND AUG. 1979)



                                                                                    Linear Regression
                                  Calibration Points                             Corr.
                                AbsorEnnce  at TmBTmH                            ^^   Slopc    ^'lnc^-
Date          0.00   0.01    0.02    OT05    0.10     0.15    0.70    0.75            r      m        £


                              .08    0.216    .425     .644    .854               1.0000   4.285     -.002


               .000    .042           .213    .416     .630    .838   1.024        0.9998   4.127      .004


               .000    .033           .191    .418     .598    .828   1.032        0.9997   4.146     -.007


                                     .210    .424     .635    .839               1.0000  4.206      .001


                                     .178    .385    .574    .775               0.9998   3.89     -.007


                                      .199    .403    .605    .812                1.0000   4.06     -.002


                                      .186    .362    .526    .68                0.9993   3.40     0.011

-------
             have been a  source  of  interference,  but the ammonia concen-
             centration of the  samples  should not  have  caused a problem
             with the color development.
     Based on  the  review  of  the Engineering-Science  report,  it  can be
concluded that  the  problems with  the Union  Oil  data resulted  from the
analytical techniques used during the analyses.  The values presented for
the prill  tower acid  impingers  were  extremely  large  as  compared  with
results obtained from  other similar  tests  (Union  Oil,  Brea,  California,
EMB Report No.  80-NHF-15).   Examination of the ES  lab  data reveals that
the acid impinger samples were analyzed approximately two weeks after the
standards calibration  curve  was prepared.   A  summary   of the  various
standard curves prepared  by  ES  show a  tremendous  variation  from day to
day in the slope and intercept for the calibration  line.  As there was no
standard calibration curve prepared during the actual sample analysis the
unusual high  values are  believed  to  be the  result of  poor analytical
techniques.
     During some of the  urea  analyses,  ethanol was used  to  dilute the
standards and/or samples  to  volume  after  the  color reagent  was added.
High intercept  values  indicate  there was  some  interference (turbidity
or improper color)  associated  with  the  samples.   This interference would
have produced a positive effect on the sample values.
     The cooler sample values were produced from a  calibration curve that
was well  below the actual  sample  range.   The  absorbances for  the acid
samples were low as would  be  expected, however the  absorbances  for the
water samples were well above the highest point on  the calibration curve.
These sample analyses  should have  been repeated using  smaller aliquots.
This procedure  would have a  negative effect on  the data thus producing
lower values than were actually present.
     The Kjeldahl urea results  are  considered to  be totally  invalid due
to prescribed  analytical  procedures  and  techniques  not being  followed as
specified in the EPA analytical procedure.
     In conclusion, it  is believed  that  the  urea  and  ammonia emissions
data produced  in  the ES  report are  invalid  and   should  not  be  used to
support the industry Background Information Document.
                                     11-14

-------
     Formaldehyde Results for Fertilizer Grade Urea
     Determinations for formaldehyde concentrations were performed by ES.
A chromotropic acid colorimetric method was used for these determinations.
The inlet side  of  the  scrubber  yielded  3.42 Ibs. per hour and the outlet
side yielded 1.22 Ibs. per hour,.for a scrubber efficiency of 63 percent.
The formaldehyde data are summarized  in  Tables  II-6 and II-7.  The lower
scrubber efficiency  for the  formaldehyde can  be attributed  to  reduced
solubility of formaldehyde in water.
     Formaldehyde Results for Feed Grade Urea
     The formaldehyde  results  are summarized  in Table  II-8.   The  inlet
yielded 0.77 Ibs.  per  hour  and 1.62 Ibs. per hour  for  the  outlet with a
zero scrubber efficiency.
Particle Size Test Data
     Particle size testing data was collected at the prill tower scrubber
inlet and the rotary cooler.  An  Anderson six-stage cascade impactor was
used for these determinations.
     The results  of  the urea  cooler particle  sizing  are  summarized in
Table II-9.  The  majority  of  the particles were  in the 17.00ym range.
With this large  sized  particle, the  efficiency  of the  Anderson  unit is
extremely limited.  Grain loading averaged 4.52 grains per dry normalized
standard cubic  feet  (DNCF).  The  particle  size  data  is  also presented as
a graph in Figure II-l.
     The results  of  the fertilizer grade urea particle  size  testing is
summarized in Table  11-10.   The  majority of  the  particles were  in the
1.5 ym  range.   Grain  loading  averaged  0.05 grains/DNCF.   The particle
size data is also presented as a graph in Figure II-2.
     The results of the feed grade urea particle size  testing  is summarized
in Table  11-11.   The majority  of  the particles were  in the  3.0um range.
Grain loading averaged  0.02 grain/DNCF.   The particle size  data for feed
grade urea is also presentd  as  a  graph  in Figure  II-3.  Appendix B con-
tains an extensive discussion and graphical presentation of the particle
size results.
                                     11-15

-------
                                                       TABLE I1-6


                                   SUMMARY OF FORMALDEHYDE RESULTS FOR THE UREA COOLER
                                             FERTILIZER GRADE EMISSIONS TEST
                                           UNION OIL COMPANY, BREA, CALIFORNIA
H
H
I
M
CT>

Date
Volume of Gas Sampled (DSCF)
Percent Moisture by Volume
Average Stack Temperature (°F)
Stack Volumetric Flow Rate (DSCFM)a
Percent Isokinetic
Production Rate (tons/hr)
Formaldehyde Concentration and
Mass Flow Rate
Analysis Procedure -
mg
gr/DSCF
lb/hrb
Ib/ton
Run 1
4/2/79
33.12
2.7
168
4519
102




120.0
0.06
2.16
— —
Run 2
4/2/79
37.95
2..2
167
7471
85
Data Not Recorded



212.6
0.09
5.52
— —
Run 3
4/2/79
25.58
2.1
160
4236
101
During Test Period



311.7 -
0.19
6.81
— —
Average

32.22
2.3
165
5409
96




214.8
0.11
4.83
__
      a)  Volumetric flows determined from flow data (see Table 11-10).
      b)  Emission factors calculated using outlet volumetric flow rates.

-------
                                                        TABLE II-7

                                         SUMMARY OF FORMALDEHYDE RESULTS FOR THE
                                     UREA PRILL TOWER FERTILIZER GRADE EMISSIONS TEST
                                           UNION OIL COMPANY, BREA, CALIFORNIA
M
Inlet Location
Run Number :
Date
Volume of Gas Sampled (DSCF)
Percent Moisture by Volume
Average Stack Temperature (°F)
Stack Volumetric Flow Rate (DSCFM)a
Percent Isokinetic
Production Rate (tons/hr)
Formaldehyde Concentration and
Mass Flow Rate
Analysis Procedure -
mg
gr/DSCF
lb/hrb
Ib/ton
1
4/4/79
26.59
1.3
146
13,599
102
14.8



53.4
0.03
3.61
0.24
2
4/4/79
28.29
1.5
149
12,928
103
14.8



43.8
0.02
2.64
0.18
3
4/5/79
25.32
2.9
149
12,931
102
14.5



59.5
0.04
4.01
0.28
Average

26.74
1.9
148
13,153
102
14.7



52.3
0.03
3.42
0.23
1
4/4/79
120.16
3.1
72
13,599
98
14.8



109.9
0.01
1.64
0.11
Outlet Location
2
4/4/79
121.02
3.4
76
12,928
104
14.8



92.3
0.01
1.30
0.09
3
4/5/79
124.20
3.5
74
12,931
107
14.5



53.9
0.01
0.74
0.05
Average

121.79
3.4
74
13,153
103
14.7



85.4
0.01
1.22
0.88
      a)  Volumetric flows determined from flow data (see Table 11-10).
      b)  Emission factors calculated using outlet volumetric flow rates.

-------
                                                       TABLE II-8


                                         SUMMARY OF FORMALDEHYDE RESULTS FOR THE

                                        UREA PRILL TOWER FEED GRADE EMISSION TEST
                                           UNION OIL COMPANY, BREA, CALIFORNIA
M
M
I
M
oo
Inlet Location
Run Number :
Date
Volume of Gas Sampled (DSCF)
Percent Moisture by Volume
Average Stack Temperature (°F)
Stack Volumetric Flow Rate (DSCFM)a
Percent Isokinetic
Production Rate (tons/hr)
Formaldehyde Concentration and
Mass Flow Rate
Analysis Procedure -
mg
gr/DSCF
lb/hrb
Ib/ton
1
4/5/79
86.57
1.0
222
3109
100
8.92



57.2
0.01
0.27
0.03
2
4/6/79
99.01
1.5
230
2933
101
8.92



184.3
0.03
0.72
0.08
3
4/6/79
78.88
1.8
230
3035
104
8.92



266.4
0.05
1.35
0.15
Average

88.13
1.4
227
3026
102
8.92



169.3
0.03
0.77
0.09
1
4/5/79
52.98

96
3109
109
8.92



106.2
0.03
0.82
0.09
Outlet Location
2
4/6/79
47.67
4.0
100
2933
103
8.92



175.9
0.06
1.43
0.16
3
4/6/79
48.33
5.2
100
3035
102
8.92



322.3
0.11
2.67
0.30
Average

49.66
5.1
98
3026
105
8.92



201.0
0.07
1.62
0.18
       a)   Volumetric  flows determined from flow data  (see Table 11-10).
       b)   Emission  factors calculated using outlet volumetric flow rates.

-------
                                                      TABLE II-9
i
M
VO
SUMMARY OF UREA COOLER
PARTICLE SIZING TEST RESULTS


Union Oil Company, Brea, California
Particulate Aerodynamic"
ES Test Sampling Test Test Concentration Size Range
No. Location Date Time grains/dscfa ym
1 Cooler 4/3/79 1637-1652 4.20 >17.49
(Pert.) 10.92-17.49
5.05-10.92
3.24-5.05
1.63.3.24
0.75-1.63
2 Cooler 4/4/79 1237-1247 4.74 XL6.57
(Pert.) 10.35.16.57
4.78-10.35
3.07-4.78
1.54-3.07
0.7-1.54
3 Cooler 4/4/79 1745-1755 4.61 XL6.87
(Pert.) 10.53-16.53
4.87-10.53
3.13-4.87
1.57-3.13
0.72-1.57
Mass in
Size Range
%
98.8
0.5
0.5
0.1
—
—
99.2
0.4
0.3
—
—
—
99.2
0.4
0.4
—
—
— —
    a)  Standard conditions are 20°C and 760 mm Hg.

    b)  As unit density spheres.

-------
                                                                          FIGURE II-l
                             PARTICLE SIZE  SUMMARY

                                  UREA COOLER

                       EQUIVALENT  AERODYNAMIC DIAMETER

                                      VERSUS

                              .-PERCENTAGE OF MASS


                    UNION  OIL COMPANY, BREA, CALIFORNIA
    10.

    9


    8


    7



    6



    5
99.99   99.9 99.8
               99  98    95   90    80   70  60 5O 40  30  20    10   5    2  1  0.5  0.2 0.1 0.05 001

eS
H
H
a
Q   2.

0
M

3
53

S

§   '.
EQUIVALENT
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   ±ji'i
in;
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        •-i-l=£

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                                                                                      S
0.01  O.OS 0.1 0.2  0.5  1   2    S   10    20   30  40  50  60  70  80   90  95   98  99     99.8 99.9   99.99
            PERCENTAGE OF MASS <  CORRESPONDING  SIZE
                                                  0 ---- -
                                                                  Test  #1 4/3/79

                                                                  Test  n 4/4/79

                                                                  Test  #3 4/4/79
                                      11-20

-------
                                                  TABLE 11-10




ES Test Sampling
No. Location
1 Scrubber In
(Fert.)





2 Scrubber In
(Fert.)





3 „ Scrubber In
(Fert.)





4 Scrubber
In
(Fert.)




SUMMARY OF PRILL TOWER SCRUBBER INLET
FERTILIZER GRADE UREA - PARTICLE SIZING TEST RESULTS
Union Oil Company, Brea, California
Particulate Aerodynamicb
Test Test Concentration Size Range
Date Time grains/dscfa p m
4/2/79 1541-1556 0.06 >16.16
10.09-16.16
4.66-10.09
3.00-4.66
1.50-3.00
0.09-1.50
<0.09
4/2/79 1806-1813 0.05 >17.79
11.11-17.79
5.14-11.11
3.31-5.14
1.66-3.31
0.77-1.66
<0. 77
4/3/79 0952-0959 0.06 XL9.88
12.42-19.88
5.75-12.42
3.70-5.75
1.87-3.70
0.87-1.87
<0. 87
4/3/79 1146-1149 0.09 XL5.01
9.37-15.01
4.33-9.37
2.78-4.33
1.39-2.78
0.63-1.39
<0.63



Mass in
Size Range
%
16.7
2.7
4.5
4.7
16.5
21.5
37.8
5.2
0
3.3
4.2
18.7
50.5
18.2
11.5
1.9
2.9
3.6
4.9
44.5
30.7
4.9
3.8
3.0
3.1
30.0
26.5
28.7
a)  Standard conditons are 20°C and 760 mm Hg.
b)  As unit density spheres.

-------
                                                                 FIGURE II-2
                      PARTICLE SIZE SUMMARY
                      FERTILIZER GRADE UREA
                   PRILL TOWER SCRUBBER INLET
                 EQUIVALENT AERODYNAMIC DIAMETER
                               VERSUS
                         PERCENTAGE OF MASS
               UNION  OIL COMPANY, BREA, CALIFORNIA
               • '  .   '   .••••• — ' ..... - "•'•'" • • - '-'
      32 J:
Ed
3
M

O
a
§
w
H
Z
2.
                          (M  1< M V 4,1 W  .11   10  *   ?
                                                  i  o> o.' o i it n  »oi
                ;i~^
                       ^u
                              ~P4:
                                        -to
                               :rr

                                  ::tr^-:rrr:l:
                                        ^iH
            lijliiiii


              PERCENTAGE OF MASS < .CORRESPONDING  SIZE
O	O  Test #1, 4/2/79
Q—o Test #2, 4/2/79
                                   2
O—O Test #3,  4/3/79
A—A Test #4,  4/3/79

-------
                                                      TABLE 11-11



                                 SUMMARY OF PRILL TOWER SCRUBBER INLET FEED GRADE UREA
i
to
U)
PARTICLE SIZING TEST RESULTS
Union Oil Company, Brea, California
Particulate Aerodynamic*)
ES Test Sampling Test Test Concentration Size Range
No. Location Date Time grains/dscf a p m
1 Scrubber In 4/6/79 1009-1015 0.02 >16. 61
(Feed) 10.37-16.61
4.79-10.37
3.07-4.79
1.53-3.07
0.69-1.57
<0. 69
2 Scrubber In 4/6/79 1530-1534 0.02 XL7.20
(Feed) 10.74-17.20
4.96-10.74
3.18-4.96
1.59-3.18
0.72-1.59
<0. 72
3 Scrubber In 4/6/79 1931-1934 0.02 >15.99
(Feed) 9.98-15.99
4.60-9.98
2.95-4.60
1.47-2.95
0.66-1.47
<0.66

Mass in
Size Range
%
7.4
2.4
7.0
24.8
45.6
8.3
4.5
11.5
6.7
9.2
22.6
34.2
13.2
2.6
12.7
7.6
10.6
20.0
28.6
11.2
9.3
    a)   Standard conditons are 20°C and 760 mm Hg.

    b)   As unit density spheres.

-------
                                                                    FIGURE  I1-3
                           PARTICLE  SIZE  SUMMARY
                              FEED GRADE  UREA
                        PRILL TOWER  SCRUBBER INLET
                      EQUIVALENT AERODYNAMIC DIAMETER
                                  VERSUS
                            PERCENTAGE  OF MASS
                   UNION OIL COMPANY, BREA,  CALIFORNIA
9999   99099.8
                                                       J  1  0.5  02 01 0.05 001
                     5   KJ   .'I  j&  «0 10 to  /O  Wl   V)
                                                        9?  '/•    Vl 8 
                                                                         0-1
                      PERCENTAGE OF MASS < CORRESPONDING SIZE
                                               0 - 0  Test #1 4/6/79
                                               0 — O  Test #2 4/6/79
                                    11-24      Q — Q  Test #3 4/6/79

-------
                                                        TABLE 11-12
M
M
I
to
OPACITY AVERAGES DURING SAMPLING RUNS
Union 01
Rotary Cooler
Run Run Observation
No. Date Time Time
1 4/2/79 1110-1221 No Readings

2 4/2/79 1300-1524 1400-1406
1407-1413
1414-1420
1421-1427
1428-1434
1435-1441
1442-1448
1449-1454
1454-1500
-
3 4/2/79 1613-1731 1530-1536
1537-1543
1544-1550
1551-1552







1 Company, Brea, California
Urea Prill Tower
Average Run Run
Opacity No. Date Time
Taken 1 4/4/79 0947-1216

20
26
16
14
16
20
23
18
29

24
19
24
26









Fertilizer Grade
Observation
Time
0945-0951
0952-0954
1005-1006
1007-1012
1213-1019
1020-1026
1027-1033
1034-1040
1041-1047
1048-1054
1055-1101
1102-1108
1109-1115
1120-1126
1123-1129
1130-1136
1137-1143
1144-1150
1151-1157
1158-1204
1205-1211
1212-1218
1219-1220
Average
Opacity
5
4
5
5
3
5
5
6
5
5
3
3
4
8
14
31
11
8
4
11
12
7
11

-------
                                                   TABLE 11-12 (Cont'd.)
I
NJ
OPACITY AVERAGES DURING SAMPLING RUNS

Union Oi
1 Company, Brea, California


Urea Prill Tower Fertilizer Grade
Run
No.
2

















Run Observation
Date Time Time
4/4/79 1424-1651 1430-1436
1437-1443
1444-1450
1451-1457
1458-1504
1505-1511
1512-1518
1519-1525
1526-1530
1600-1606
1607-1613
1614-1620
1621-1627
1628-1634
1635-1641
1642-1648
1649-1654
1655-1701
Average Run Run
Opacity No. Date Time
15 3 4/5/79 1020-1132
10
12
12
10
10
13
12
0
0
0 (cont'd) 1235-1447
2
2
2
3
2
0
1
Observation
Time
1020-1026
1027-1033
1034-1040
1041-1047
1048-1054
1055-1101
1102-1108
1109-1115
1120-1126
1127-1133
1305-1311
1312-1318
1319-1325
1326-1332
1333-1335
1340-1346
1347-1353
1357-1402
Average
Opacity
7
8
5
8
5
7
9
5
13
10
7
4
4
10
11
22
31
29

-------
                                                    TABLE 11-12 (Cont'd)
M
I
K3
OPACITY AVERAGES DURING SAMPLING RUNS


Run
No.
1








2


















Union Oil
Urea
Run Observation
Date Time Time
4/5/79 1852-2152 1642-1648
1649-1654
1655-1701
1702-1708
1709-1715
1716-1722
1723-1729
1730-1736
1737-1743
4/6/79 1055-1333 1100-1106
1107-1108
1112-1116
1122-1128
1129-1135
1136-1142
1143-1141
1150-1156
1157-1203
1204-1210
1211-1213
1243-1249
1250-1256
1257-1303
1304-1310
1311-1317
1318-1324
1325-1331
1332-1333
Company, Brea, California
Prill Tower Feed Grade
Average Run Run
Opacity No. Date Time
5 3 4/6/79 1612-1944
5
5
5
5
5
5
5
5
13
10
23
43
36
29
32
29
33
30
25
31
25
23
38
31
27
27
23


Observation
Time
1622-1628
1629-1635
1636-1642
1643-1649
1650-1656
1651-1703
1704-1710
1711-1717
1718-1724
1725-1730




















Average
Opacity
11
15
13
14
13
14
16
15
16
14



















-------
Visible Emission Data
     Visible emission data  were  collected during all periods of testing.
The observer  changed his  position  as  the time  of  day   changed.   The
observer's readings are  summarized  in Table 11-12.  The average readings
were calculated  at six  minute intervals.  A  graphical presentation  of
this data  is presented  in Appendix  C,   Section  III.   In  comparing the
visible emissions  data   to  production,   no conclusions  could  be  made
correlating production variables  and  visible  emissions.   Great variation
in opacity  readings  was  shown.   Also,  graphical  summaries  are  shown in
Figures II-4, II-5, and II-6.
Velocity Traverse Test Data
     During the  prill  tower fertilizer  grade urea  and  feed  grade  urea
testing, velocity  determinations  were made for the  untested scrubbers.
These data are summarized in Table 11-13.   The  average  flow for fertilizer
grade urea for the scrubber tested was 13,153 cubic feet per minute,  dry,
normalized conditions (DSCFM).   The average  flow through  each  scrubber
was 12,357  DSCFM.   Therefore,  the flow  conditions  through  the  tested
scrubber are representative of all four prill tower scrubbers.
Scrubber Solution Test Data
     Samples of  scrubber  solution were  collected  during   each of  the
sampling runs.  Five samples per  run  were collected and then composited.
The composite  samples  were analyzed for  urea, ammonia,  formaldehyde,  pH
and temperature at collection.   These  data are summarized in Table 11-24.
The average pH was 8.5 for  fertilizer grade and  9.0 for feed grade urea.
The average values for  ammonia and  urea are reported as  concentration in
milligrams per milliliter  (mg/ml)  and  averaged 3.9 mg/ml and 0.05 mg/ml
ammonia and urea, respectively, for fertilizer grade.   During feed grade
urea production, the correlation  of ammonia  and  urea was  2.3 mg/ml and
0.85 mg/ml, ammonia and  urea, respectively.
Pressure Drop Measurements Test Data
     U-tube manometers  were connected  across the inlet and  outlet of  each
scrubber.   Data was recorded every 15 minutes during each run.  These  data
are summarized in Tables  11-14 and  11-15.  These data are  reported as an
indicator of overall scrubber function during the testing period.
                                     11-28

-------
                                                           FIGURE  I1-4
                   SIX MINUTE AVERAGES OF
             APRIL 2, 1979  OPACITY READINGS ON THE
                      ROTARY COOLER
                UNION OIL COMPANY, BREA, CA
4-1
c

-------
      50
                         SIX MINUTE  AVERAGES  OF APRIL 4  &  5,  1979 OPACITY READINGS FOR THE
                                          UREA PRILL TOWER FEED GRADE
                                          UNION OIL COMPANY,  BREA, CA
   (I)
   O
4J
•H
O
CO
P.
O

(U
00
I
U)
o
      45
      40
      30
      25
      20
      10
                                     1
            1642
                           1743  1100
                  4/5/79
1213 1243          1333 1622

         4/6/80
1730
                                                                                                                          M


                                                                                                                          I

-------
c

o


-------
                               TABLE  11-13

                     SUMMARY OF  PRILL TOWER  SCRUBBER
                     GAS VELOCITY AND GAS VOLUME DATA
                       Union Oil, Brea, California
Scrubber
Location

Northeast
Northwest
Southeast
Southwest
. Average
Northeast
Northwest
Southeast
Southwest
"Average
Northeast
Northwest
Southeast
Southwest
Average

Northeast
Northwest
Southeast
Southwest
Average
Northeast
Northwest
Southeast
Southwest
Average
Northeast
Northwest
Southeast
Southwest
Average
Run
No.

1
1
1
1

2
2
2
2

3
3
3
3


1
1
1
1

2
2
2
2

3
3
3
3

Gas Velocity3
Fertilizer Grade Urea
19.35
15.99
18.89
12.73
16.74
18.53
16.06
19.77
12.73
16.77
18.71
16.09
17.99
15.03
16.96
Feed Grade Urea
4.80
4.04
5.11
3.16
4.28
4.45
4.52
6.10
4.87
4.99
4.67
4.52
5.82
4.11
4.78
Gas Volumeb

13,599
11,515
13,603
9,166
11,971
12,928
13,400
14,218
11,566
13,028
12,931
11,588
12,955
10,819
12,073

3,109
2,908
3,682
2,273
2,993
2,933
3,252
4,395
3,509
3,522
3,035
3,252
4,191
2,958
3,359
a)  Feet per second, stack conditions.
b)  Standard cubic feet per minute, dry, 70°F, 29.92 in Hg.
                                    11-32

-------
                  TABLE 11-14




SUMMARY OF PRESSURE DROP READINGS AT PRILL TOWER
SCRUBBER DURING FEED GRADE
Union Oil
Run
No. Date Time
1 4/4/79 0958
1011
1017
1030
1046
1100
1116
1131
1146
1202
1215
Average
2 4/4/79 1437
1448
1501
1516
1531
1547
1600
1615
1629
1646
1657
Average
3 4/5/79 1017
1031
1051
1100
1115
1131
1226
1231
1245
1300
1317
1330
1345
1359
1416
Average
Company, Brea,

NE
1.85
1.85
1.85
1.90
1.90
1.90
1.90
1.85
1.85
1.90
1.85
1T87
1.80
1.80
1.80
1.80
1.80
1.80
1.80
1.80
1.80
1.80
1.80
1.80
1.85
1.90
1.85
1.85
1.85
1.85
1.85
1.85
1.85
1.85
1.85
1.85
1.85
1.85
1.85
1.85
UREA TESTING
California
AP,
NW
1.35
1.35
1.35
1.40
1.40
1.40
1.40
1.35
1.35
1.35
1.35
1.37
1.30
1.35
1.40
1.35
1.30
1.30
1.35
1.35
1.30
1.35
1.35
1.34
1.35
1.40
1.40
1.35
1.35
1.30
1.35
1.35
1.35
1.35
1.35
1.35
1.35
1.35
1.35
1.36

"H?0
SE
2.30
2.30
2.30
2.30
2.25
2.25
2.25
2.25
2.25
2.30
—
2728
2.25
2.25
2.25
2.25
2.20
2.25
2.20
2.20
2.20
2.25
2.20
2.23
2.20
2.20
2.25
2.25
2.25
2.20
2.15
2.15
2.15
2.15
2.10
2.15
2.15
2.15
2.15
2.18


SW
1.35
1.35
1.35
1.30
1.35
1.30
1.30
1.30
1.30
0.75
0.75
1.21
0.90
0.85
0.80
0.80
0.80
0.85
0.85
0.80
0.80
0.80
0.80
0.82
0.95
0.95
1.00
0.95
1.00
1.00
1.00
1.00
1.00
1.00
1.00
1.00
1.00
1.00
1.00
0.99
                      11-33

-------
                   TABLE H-15




SUMMARY OF PRESSURE DROP READINGS AT PRILL TOWER
SCRUBBER DURING FEED GRADE
Union Oil
Run
No. Date Time
1 4/5/79 1647
1700
1716
1728
1745
1758
2045
2100
2115
2130
2146
Average
2 4/6/79 1110
1116
1131
1146
1200
1214
1231
1247
1300
1316
1330
Average
3 4/6/79 1616
1630
1645
1700
1715
1800
1815
1830
1845
1900
Average
Company, Brea,

NE
0.15
0.15
0.15
0.15
0.15
0.15
0.15
0.20
0.15
0.15
0.15
0.15
0.20
'0.20
0.15
0.15
0.15
0.15
0.15
0.15
0.15
0.15
0.15
0.16
0.15
0.20
0.15
0.15
0.15
0.15
0.20
0.20
0.20
0.20
0.17
UREA TESTING
California
AP,
NW
0.10
0.10
0.10
0.10
0.10
0.10
0.10
0.10
0.15
0.15
0.10
0.14
0.15
0.15
0.15
0.10
0.10
0.10
0.15
0.10
0.15
0.10
0.10
OTTT
0.10
0.10
0.10
0.05
0.05
0.05
0.07
0.10
0.10
0.10
0.08

"H20
SE
0.20
0.20
0.20
0.20
0.20
0.20
0.20
0.25
0.20
0.20
0.25
0.21
0.20
0.20
0.20
0.20
0.20
0.20
0.15
0.15
0.10
0.15
0.20
0.18
0.20
0.20
0.20
0.20
0.20
0.20
0.22
0.22
0.25
0.25
0.21


SW
0.10
0.10
0.10
0.10
0.10
0.10
0.10
0.10
0.05
0.05
0.05
0.085
0.10
0.10
0.10
0.10
0.10
0.05
0.10
0.10
0.10
0.10
0.10
0.09
0.15
0.10
0.10
0.10
0.10
0.10
0.10
0.10
0.10
0.10
0.10
                       11-34

-------
Relative Humidity and Ambient Temperature Data
     Relative humidity  and  ambient  temperature data  are summarized  in
Tables 11-16,  17 and  18.   This data  was  recorded  during  the  emission
testing on the rotary  cooler and prill temperatures.  This data summarizes
the ambient conditions present during the testing program.
Process Sample Test Data
     During the  prill  tower  testing  for  each ,sample  run,   one  process
sample was collected.   Inlet  and outlet  samples were collected  for the
rotary cooler.  The collection point for  the  cooler  inlet sample  was the
same as the  prill  tower outlet point.  These  samples were  measured for
bulk density  and sieve  analysis  to  determine particle size distribution.
These data are summarized in Table 11-19.
                                      11-35

-------
                     TABLE 11-16
SUMMARY OF AMBIENT TEMPERATURE AND RELATIVE HUMIDITY
DURING ROTARY COOLER
Union Oil Company, Brea,
Run Sampling
No. Date Time
1 4/2/79 1020
1030
1045
1100
1115
1130
1145
1200
1215
1230
Average
2 4/2/79 1300
1315
1330
1345
1400
1415
1430
1445
1500
1515
1530
Average
3 4/2/79 1545
1600
1615
1630
1645
1700
1715
1730
Average
TESTING
California
Ambient
Temperature
67
69
71
73
71
73
71
73
72
74
71.4
74
77
78
79
75
75
73
73
72
71
70
74.3
69
69
69
69
70
71
71
70
697S

Relative
Humidity
57
51
47
43
43
43
42
36
39
35
43.6
43
39
36
31
40
42
45
43
46
43
45
41.2
45
44
43
43
30
36
31
32
3F7o
                        11-36

-------
                     TABLE 11-17

SUMMARY OF AMBIENT TEMPERATURE AND RELATIVE HUMIDITY
 DURING PRILL TOWER FERTILIZER GRADE UREA TESTING

        Union Oil Company, Brea, California
Run
So.
1















2













3











3









Sampling
Dace Time
4/4/79 0900
0915
0930
0945
1000
1015
1030
1045
1100
1115
1130
1145
1200
1315
1230
Average
4/4/79 1400
1415
1430
1445
1500
1515
1530
1545
1600
1615
1630
1645
1700
Average
4/5/79 0930
1000
1015
1030
1045
1100
1115
1130
1145
1200
1215
Average
4/5/79 1230
1245
1300
1315
1330
1345
1400
1415
1430
Average
Ambient
Temperature
65
70
74
76
79
79
80
80
84
83
83
82
83
81
80
78.6
87
87
87
88
87
88
85
85
83
82
80
81
29 	
84.5
75
79
82
80
79
79
85
82
81
81
82
80.5
81
83
88
88
88
87
89
89
88
"86TB"
Relative
Humidity
50
41
33
33
27
27
27
25
24
23
22
24
23
20
23
28.1
24
24
24
23
21
22
23
23
26
24
28
27
12—
24.5
34
30
29
30
34
30
26
27
29
29
27
29.5
30
26
23
26
26
26
26
29
30
I6T9"
                          11-37

-------
                     TABLE 11-18
SUMMARY OF AMBIENT TEMPERATURE AND RELATIVE HUMIDITY
DURING PRILL TOWER FEED GRADE UREA TESTING
Union Oil Company,
Run Sampling .
No. Date Time
1 4/5/79 1915
1930
1945
2000
2015
2030
2045
2100
2115
2130
2145
2200
Average
2 4/6/79 1045
1100
1115
1130
1145
1200
1215
1230
1245
1300
1315
1330
1345
Average
3 4/6/79 1615
1630
1645
1700
1715
1730
1745
1800
1815
1830
1845
1900
1915
Average
Brea, California
Ambient
Temperature
67
66
65 .
63
63
62
60
60
61
60
59
61
62.3
69
71
71
70
70
70
72
71
72
73
75
75
74
71.8
71
68
68
66
65
66
64
64
65
63
63
61
62
65.1

Relative
Humidity
46
51
52
53
58
57
63
63
57
63
65
64
57.7
51
49
47
48
48
48
47
54
51
51
49
48
48
49.2
52
60
56
59
63
61
65
65
63
66
69
73
71
63.3
                         11-38

-------
                                                         TABLE 11-19
M
H


VD
SUMMARY OF SIEVE ANALYSIS AND BULK DENSITY
MEASUREMENTS ON THE ROTARY COOLER AND PRILL TOWER





Sieve No. 8
10
12
14
16
20
Pan
Sum of Mass
on Sieves
Bulk Density
grams/25 ml

Sieve No. 8
10
12
14
16
20
Pan



Mass
gm

8.2
40.9
134.9
62.4
12.4
6.9
2.9

268.6
180.4

4.1
22.5
117.2
58.9
18.4
9.3
9.6

Run 1

% of Total
Mass

3.1
15.2
50.2
23.3
4.5
2.6
1.1




1.7
9.4
48.8
24.5
7.6
3.8
4.2
Union Oil

Cumul. %
of Total
Mass
Rotary
100 0
96.9
81.7
31.5
8.2
3.7
1.1



Rotary
100.0
98.3
88.9
40.1
15.6
8.0
4.2
Company, Brea, California


Mass
gm
Cooler
6.9
33.3
116.1
50.9
18.1
8.1
6.1

239.5
182.6
Cooler
4.7
27.5
111.5
55.3
15.8
6.7
5.9
Run 2

% of Total
Mass

Cumul. %
of Total
Mass
Inlet Fertilizer Grade
2.9
13.9
48.5
21.2
21.2
7.6
2.5



Outlet Ferti
2.1
12.1
49.0
24.3
6.9
3.0
2.6
100.0
97.1
83.2
34.7
34.7
13.5
2.5



lizer Grade
100.0
97.8
85.8
36.8
12.15
5.6
2.6


Mass
gm
Urea
6.2
31.6
103.1
52.4
52.4
15.1
7.6

22.34
183.5
Urea
5.5
32.5
110.1
53.5
15.7
6.7
7.0
Run 3

% of Total
Mass

2.8
14.1
46.2
23.4
23.4
6.8
3.4




2.4
14.1
47.6
23.2
6.8
2.9
3.0

Cumul. %
of Total
Mass

100.0
97.2
83.1
36.9
36.9
13.5
3.4




100.0
97.6
83.5
35.9
12.7
5.9
3.0
     Sum of  Mass
     on Sieves  240.6

     Bulk Density
     grams/250  ml
                     227.4
                     231.0
194.1
194.5
192.0

-------
                                                TABLE 11-19 (Cont'd)
                                     SUMMARY OF SIEVE ANALYSIS AND BULK DENSITY
MEASUREMENTS





Run 1
Union

ON THE ROTARY COOLER AND PRILL TOWER
Oil Company, Brea, California

Run 2
Cumul. %



Sieve No. 8
10
12
14
16
20
Pan
i— i
i i
i Sum of Mass
o on Sieves
Mass
gm

8.9
45.0
107.4
42.8
17.0
5.6
17.4

244.1
% of Total
Mass

3.6
18.4
44.0
17.5
6.9
2.4
7.2


of Total
Mass

100.0
96.4
78.0
34.0
16.5
96.
7.2


Mass
gm
Urea Prill
2.5
24.9
119.3
65.1
15.0
5.2
12.7

244.7
% of Total
Mass

Cumul. %
of Total
Mass
Tower Fertilizer Grade
1.0
10.2
48.8
26.5
6.2
2.1
5.2


100.0
99.0
88.8
40.0
13.5
7.3
5.2




Mass
gm
Urea
6.0
36.9
101.6
45.7
17.0
10.9
11.0

229.1
Run 3

% of Total
Mass

2.6
16.1
44.3
20.0
7.4
4.8
4.8



Cumul. %
of Total
Mass

100.0
97.4
81.3
37.0
17.0
9.6
4.8


Bulk of Density
grams/250 ml
188.3
                                        182.9
                                                 Urea Prill Tower Feed Grade Urea
                                                      191.9
Sieve No.
Pan
 8
10
12
14
16
20
Sum of Mass
on Sieves

Bulk Density
grams/250 ml
  6.7
  0.8
  0.8
  0.5
  0.5
  6.4

182.9
        198.6
        199.7
 3.4
 0.4
 0.4
 0.2
 0.2
 3.3
92.1
100.0
                                          ,6
                                          ,2
 96.
 96.
 95.8
 95.6
 95.4
 92.1
  0.6
  0.2
  0.1
  0.1
  0.2
  7.4
286.9
                                295.5
                                196.7
0.20
0.06
0.03
0.03
0.06
2.50
100.0
9.8
99.7
99.7
99.7
99.6
                                                   97.10
97.1
  0.5
  0.2
  0.1
  0.1
  0.1
  5.2
263.9
                                                      270.1
                                                      198.5
 0.20
 0.07
 0.04
 0.04
 0.04
 1.90
97.70
100.0
 99.8
 99.7
 99.7
 99.7
 99.6
 97.7

-------
            SECTION III
PROCESS DESCRIPTION AND OPERATION

-------
                                SECTION III
                     PROCESS DESCRIPTION AND OPERATION

PROCESS DESCRIPTION
     Process Equipment
     The urea solution  leaving  the  synthesis  section is at a concentration
of 75 percent.  This  solution passes through two falling film vacuum evapora-
tors in series  and  is concentrated to 99.7 percent.  From  the evaporators,
the urea melt is pumped to a head tank at the top of the prill tower.  Melt
is sprayed  from the  top  of the prill tower  by a  spinning bucket.  Tower
capacity is estimated  to  be 370 tons/day for  fertilizer  grade product and
220 ton/day for feed grade product.
     At the top of the  prill tower  are  four exhaust ducts, each controlled
by a packed bed scrubber.   Each duct  is  equipped with a fan.  While ferti-
lizer grade prills  are being  produced,  these  four fans are  in  operation
pulling air upward through the  tower.  Air enters the tower through louvers
at the base of the prill tower.  When feed grade prills are being  produced,
the fans are  not  operated but  the  louvers  at the  bottom  of  the  tower are
left open.  Air flow in  the column  results  from  natural  convection;  the
air in  the tower  being  heated by  the  falling  prills  and  rising  to   be
replaced by the cooler ambient  air entering through the louvers.
     Prills are removed from  the  bottom of  the tower  by  a  conveyor and
screened.  Agriculture  grade  product passes  through a  rotary  drum cooler
and is then transported to bulk storage.  Feed  grade  is conveyed from the
prill tower,  screened,  and transported directly  to bulk  storage.  Offsize
material is dissolved and  reconcentrated.   Figure  III-l  is a flow diagram
of the process.
     Control Equipment
     The scrubbers at the  top of the prill tower were designed by  personnel
from Union Oil Company.  The scrubbers are packed beds with two sections, a
low pressure  spray section and a high pressure  spray  section.   The design
of these devices is considered  proprietary by Union Oil Company.
                                     III-l

-------
              PROCESS
             CONDENSATE
                                        _>.TO SEWER
                                     TO ATMOSPHERE
                                     i  i  i   i
                          MAKEUP FOR
                          SCRUBBERS
    i
   to
                  99.8 % UREA
                                         PRILL
                                         TOWER
                                           BUCKET
                                          ELEVATOR
                     >FFSIZ£,TO DISSOLVING TAMK
                                                               UREA - UNION OIL COMPANY OF CALIFORNIA
                                                                          BREA, CALIFORNIA
                                                              TO ATMOSPHERE
                                                        SCREEN
                                                                    t
                                                                   ROTOCLONE
                                                                    SCRUBBER
                                                                                SCRUBBER  LIQUOR
                                                                                TO  DISSOLVING TANK
                                                                       COOLER
AGRICULTURE CFERTiUZEA)
GRADE PRODUCT
                                                                                       FEED  GRADE
                                                                                       PRODUCT
n
n
-o
                                                                     SAMPLING  POIMTS
                                                                     I. ROTARY  DRUM COOLER
                                                                     2. INLET  TO ME SCRUBBER
                                                                     3- OUTLET  FROM NE SCRUBBER
                                                                                                                        Tl
                                                                                                                        O
                                                                                                                        M
Tl
-X

-------
PROCESS OPERATION
     During process  operation,  urea builds  up in the  second  evaporator's
vacuum vent and  gradually  decreases  the vacuum applied  to  the  system.  To
alleviate this problem, the steam rate  to  the second evaporator is increased
to melt the urea which has built up.  This procedure also has the effect of
raising the temperature of the melt leaving the evaporator and going to the
holding tank at  the  top  of the prill tower.  This tank  is  small and while
the process is  operating at  capacity,  there is very  little holding time.
The result is that  shortly  after the second  evaporator  is  heated to clear
the vacuum, the  overheated melt is being  sprayed  from the top of the prill
tower.  Theoretically, this will result in higher emissions, resulting pre-
dominantly from  increased  fume formation.   It was therefore  necessary to
schedule emissions tests around heating of the second evaporator.
     Figure III-l presents a flow diagram of  the solids  formation section of
the Union Oil plant.   Uncontrolled emissions  from  the cooler were measured
at the  location  marked 1.   The exhaust  ducts  and scrubbers are  referred
to by their compass location, i.e., NE, NW, SE, SW.  Uncontrolled emissions
were measured at  the inlet to the NE  scrubber,  marked  2 in Figure III-l.
Controlled prill tower emissions were tested at the outlet of the NE scrub-
ber, shown as location 3.  Prill  tower  emissions measurements were  run for
both agriculture grade and feed  grade  product;  cooler emissions tests were
performed only  while  fertilizer  grade  product  was  being   produced since
feed grade product  does  not  require  additional  cooling  after  leaving the
prill tower.
     While testing  on the prill  towers  was  being performed,  ES  recorded
visible emissions readings.   A review  of these  recorded values indicates
that the opacity varied considerably during testing.  Air flow rate through
the scrubbers also  appeared   from  observation to  vary,  though  stack test
results should indicate  whether  this  did in fact occur  and if  so,  to what
extent.  It was noted  that the air flow rate through the four scrubbers was
different, the highest flow  being almost 45 percent higher than the lowest
value.
     It was hoped that a comparison of visible emissions readings with pro-
cess parameter values  would  result in some  sort of correlation to  explain
the inconsistencies  encountered  in the  former.  A quick review reveals no
clear correlation between process or control equipment operating parameters
and the variations experienced in visible emissions readings.
                                    III-3

-------
     Possible explanations for some of  the  variations which occurred include
the buildup  of material  on  the  rake at  the bottom  of the  prill tower.
Material can  reach a  height  of  3 feet before  collapsing.   The collapse
reportedly causes a great deal  of  fines  to be drawn up the tower resulting
in increased  emissions.   A similar occurrence  is  buildup of  material on
the inside of  the  tower wall  around the  sprayhead.   Since the sprayhead is
a spinning bucket,  material  is  thrown radially  and  some of  the  urea may
hit and buildup on the  tower  wall.  After  significant buildup of material,
large chunks may fall  off,  resulting in  considerable dust and contributing
to an increase in emissions.   This  may  be particularly true with the produc-
tion of feed  grade urea as  the bucket  operates at a higher  rpm for  this
grade product.   Operators   admitted  that  caking  on  the  walls  had   been
experienced.  It was  also  suggested  that  wind   speed  and wind  direction
(the louvers are protected  from the wind  on the western site by the  syn-
thesis equipment,   but  exposed to  the  wind  on the eastern  side), may   have
an effect on emissions, although this  is at present speculation.
     While testing was being performed, a number  of parameters were recorded
to monitor process  stability.   During testing of  the cooler, nine parameters
were recorded, as shown in Table III-l.  The Rotameter  75 percent Solution to
Evaporator reading  reflects the  flowrate of  75  percent  urea  solution  from
the synthesis section to the concentration section (two falling film vacuum
evaporators in  series).   The  Temperature  Urea  to Head  Tank  indicates the
temperature of the 99.7 percent melt flowing to  the head tank at the top of
the prill tower.   From  the  head tank, the  melt  is sprayed  from a spinning
bucket.  This parameter is  a reasonably accurate  estimate of the melt spray
temperature shortly after the  parameter is  recorded.  The Ammonia  to Reactor
value is the amount of  fresh  ammonia entering the reactor and  not only in-
dicates process stability  in  the  synthesis  section,  but  can be  used to
calculate production in the  synthesis section.   The  level of  75  percent
storage tank readings  gives  the  level in  the holding tank of  75 percent
urea solution.  This  value  is recorded to  follow  process stability.  A
sharp change in level  could mean  a process upset affecting  production  rate
in the  solids  formation section.   The  CC>2  to  reactor  parameter  is  the
flow of fresh  carbon dioxide  to the  reactor  and  reflects  process  stability
in the  synthesis  section.   It  can  also be  used  to  calculate production
rate of  75  percent  urea   solution.   Air  temperature  into  cooler,  air

                                    III-4

-------
                                                  TABLE  III-l

                      AVERAGE VALUES AND RANGES FOR PROCESS EQUIPMENT OPERATING PARAMETERS
                                  DURING MASS EMISSIONS TEST OF COOLER, 4/2/79*
         Parameter
1110 to 1220
Mean   Range
1400 to 1530
Mean   Range
1600 to 1730
                                                                                          Mean
        Range
Rotameter 75% Solution to Evaporator

Temperature Urea to Head Tank

Ammonia to Reactor

Level of 75% Storage Tank

C02 to Reactor

Air Temperature into Cooler

Air Temperature from Cooler

Product Temperature to Cooler

Product Temperature from Cooler
 100    99-100

 100   100-100

 101    92-109

  87    87-87

 100   100-100

  99    96-100

  98b   98-98

  973

  96a
 100   100-100

 100   100-101

 100    91-104

 100    91-106

 100    99-100

 I03b  102-104

 lOlb   98-104

 I03a

 I04a
 100   100-100

 100    99-100

  99    97-101

 111   Ill-Ill

 100   100-100

 100b   99-100

 104a



 100a
* Ranges and averages are expressed as percentages of the overall time-weighed average values of the
  three test periods.

  Number of readings taken during test period (2 or less):

  a One
  b Two

-------
temperature out  of  cooler,  product   temperature  to  cooler,  and product
temperature from cooler are self-explanatory and used to assure the process
is in normal operation.
     During the tests run on the prill tower, eight  parameters were recorded
as listed in Table  III-2.  These values include  Rotameter 75  percent solution
to evaporation, temperature urea to head tank, ammonia  to reactor, level 75
percent storage tank,  and  C02 to reactor as were recorded  during tests on
the cooler.  Three other parameters were recorded, all  of which were consi-
dered confidential by Union Oil.  These values are scrubber liquor make-up,
low pressure  scrubber  liquor flowrate,  and high pressure  scrubber liquor
flowrate.  Scrubber  liquor  make-up  records  the flowrate  of fresh scrubber
liquor makeup  solution  to  the scrubber  liquor  holding tank  at the  top of
the column. The low pressure scrubber liquor flowrate measures the flowrate
of scrubber liquor  from the holding tank to the low pressure  spray section
of the  scrubber.   The  high pressure  scrubber  liquor flowrate measures the
flowrate of the scrubber  solution from the holding  tank to the high pres-
sure spray  section  of  the scrubber.   No  normalized  values  are  shown in
Table III-2 for these  parameters as this information,  combined with other
information in this  report,  would  compromise  the confidentiality  of these
parameters.
     During testing, the process operated smoothly  and  at production capa-
city.  Table  III-l  shows  the  variation  encountered  in  seven  process
variables recorded  during  mass  emissions  testing  of  the  rotary  drum
cooler.  As indicated,  most parameters  were  steady over  the  entire  day.
The level  of  75 percent storage  tank reading  varied somewhat  from  run to
run, but was relatively stable over the course of each  run.   A rapid change
in level  could  be indicative  of  a  process  upset.  Gradual  changes  over
the course of  the  day  is not  considered abnormal.   A  summary  of  the  data
appears in Table  N-l of Appendix N.  (This table  also shows  mean  values
for parameters  during   the particle  size  runs.)  Production  rate  during
testing of the cooler was steady and close to capacity level,  approximately
350 ton/day.
     Table 1II-2 illustrates the variations of five process parameters taken
during the mass emissions testing of the prill tower while fertilizer grade
                                    III-6

-------
                                                   TABLE II1-2
AVERAGE VALUES AND RANGES FOR
PARAMETERS DURING MASS EMISSIONS
Parameter
Rotameter 75% Solution to Evaporator
Temperature Urea to Head Tank
Ammonia to Reactor
Level 75% Storage Tank
CO 2 to Reactor
Scrubber Liquor Make-up
Low Pressure Scrubber Liquor Flowrate
High Pressure Scrubber Liquor Flowrate
PROCESS AND CONTROL EQUIPMENT OPERATING
TESTS OF PRILL TOWER - FERTILIZER GRADE *
4/4/79
0955 to 1210
Mean
101
100
102
88
102



Range
101-101
100-100
99-104
87-90
102-103



4/4/79
1430 to 1700
Mean Range
101 101-101
100 100-101
100 96-103
88 87-90
99 98-100
Confidential
Confidential
Confidential
4/5/79
1015 to 1130
1220 to 1430
Mean Range
99 98-101
100 99-100
99 96-103
115 104-118
99 98-101



* Ranges and averages are expressed as percentages of the overall time-weighed average values
  of the three test periods.

-------
                                 TABLE III-3
                 PRODUCTION RATES DURING MASS EMISSIONS TESTS
Test No.
 Date
  Time
Production Rate
   (tons/day)
Product Grade
    1

    2

    3


    4

    5

    6
A/4/79

4/4/79

4/5/79


4/5/79

4/6/79

4/6/79
0955-1210

1430-1700

1015-1130
1220-1430

1545-2200

1045-1340

1530-1935
      356

      356

      347


      214

      214

      214
Fertilizer

Fertilizer

Fertilizer


    Feed

    Feed  '

    Feed
                                     III-8

-------
prills were being  produced.   The three other  recorded  variables were con-
sidered confidential by  Union Oil.   All variables  except  Level of 75 Percent
Storage Tank were  steady  over the entire  test  period.   Minor variation of
this parameter occurred,  but  this  fluctuation should not have affected the
reliability of the emission test  results.   A summary of these data appears
in Table N-2 of Appendix N.  mean values for these parameters are given for
the periods when  particle size  runs were  performed.   The  process  was in
operation during  these  tests.  Production  rate data were  supplied  by the
plant.  A letter confirming these data appears in Section III of Appendix N.
Production rate for 4 April was 365  ton/day and for 5 April was 347 ton/day
according to  plant calculations.  Production  data is  summarized  in Table
III-3.  These  quantities  indicate that  the plant  was   operating  close to
capacity during the test period.
     Table III-4  shows  the variation of the  five recorded variables taken
during the mass  emissions tests  on the prill  tower during the production
of feed  grade  urea.  All  variables except  Level 75 Percent  Storage Tank
were extremely stable during the test period.  This one variable fluctuated
considerably during the test period, but does not indicate  that the process
was not operating  properly or in a  stable  manner.   The level of this tank
should have no effect  on emissions.  The  summary  of these data appears in
Table N-3  of  Appendix N.   The exact  time periods  when the particle size
runs were made were  not  available at the  time of this report.  The process
was operating  normally  over  the  time  periods  in which the  particle size
runs were known to have  been  performed.   Production rate  as calculated by
the plant was near capacity at 214 ton/day  (see Table III-3).
     During testing of the prill tower at this plant, the process operation
appeared to be somewhat  enigmatic.   Process  parameters  indicated steady,
normal operation.   Visible emissions observations recorded a great deal of
variation in opacity from the  prill tower scrubbers.  Recorded air flow rates
from the  scrubbers during  testing,  if  available,  should  be  checked  for
variation.  Based on the  process parameters, the tests run  on the urea prill
tower and the urea cooler should provide reliable emissions data.
                                    III-9

-------
                                                           TABLE II1-4
H

M
O
AVERAGE VALUES AND RANGES FOR PROCESS AND CONTROL EQUIPMENT OPERATING
PARAMETERS DURING MASS EMISSIONS TESTS OF PRILL TOWER - FEED GRADE3
Parameter
Rotameter 75% Solution to Evaporator
Temperature Urea to Head Tank
Ammonia to Reactor
Level 75% Storage Tank
CO 2 to Reactor
Scrubber Liquor Make-up
Low Pressure Scrubber Liquor Flowrate
High Pressure Scrubber Liquor Flowrate
4/5/79
1645 to 2200
Mean
98
100
97
101
97



Range
96-101
100-100
95-100
58-153
96-99



4/5/79
1045 to 1340
Mean Range
103 103-103
100 99-100
102 100-104
97 95-102
102 100-103
Confidential
Confidential
Confidential
4/6/79
1530 to 1935
Mean
101
100
102
101
102



Range
101-101
100-100
100-104
85-108
101-103



        a) Ranges and averages are expressed as percentages of the overall time-weighed average values
          of the three test periods.

-------
         SECTION IV
LOCATION OF SAMPLING POINTS

-------
                                  SECTION IV
                         LOCATION OF SAMPLING POINTS

PRILL TOWER
     The urea prill  tower  at Union Oil  is  constructed with  four  fiberglass
scrubbers located at  the  top of  the  tower.   The scrubbers  were  constructed
with four inch  diameter ports  located   on  the  inlet  and  outlet.    A sketch
showing the location of the inlet and outlet ports is presented in
Figure IV-1.
Inlet Sampling Locations for Urea Particulate
     The inlet  port  was a  four-inch pipe  nipple  sampling  port located  36
inches below  the  scrubber packing.   The diameter  of  the  inlet side of the
scrubber was  48  inches.  The  sampling  ports were  two pipe  diameters down-
stream from the scrubber fan.   Since  the location of the ports was not under
ideal flow conditions, it was  necessary  to  sample on a 24-point traverse per
sample port.  This is  in accordance with EPA Reference Method 1.   The sample
ports were  oriented  90°  to  one  another on  a  horizontal  axis (see Figure
IV-2).
     Particle size sampling  was  conducted on the inlet side of the scrubber.
Traverse point  No.  6  of  port A  was  chosen  as  the  location to  sample for
particle sizing. The point was arbitrarily chosen as a central point yielding
the most representative particle size data.
Outlet Sampling Locations for Urea Particulate
     The outlet  ports  were  four  inches in  diameter  and located  24-inches
from the outlet opening and  24 inches from  the  nearest upstream disturbance.
The outlet duct  was  47 inches in  diameter.   As a result of  the  location of
the outlet port, a 24-point  sampling  traverse per sample  port was  necessary.
The outlet ports were oriented 90° to one another (see Figure IV-3).
     During each  sampling  run,   all  unused  ports  were  either  capped  or
temporarily plugged to prevent leakage.
     Figure IV-4  diagrams  the location  of  the  four scrubber  outlets.   All
four scrubbers are of  similar design  and construction.  The  scrubber located
on the northeast corner of the prill  tower was  the  one selected for testing.
                                     IV-1

-------
                                                                      FIGURE IV-1
SCRUBBER WATER IN
         74'
      16'
                 36*
         15'
              58'
                                    48'
                               PRILL TOWER
                                                     OUTLET SAMPLING PORTS
    SCRUBBER WATER IN
I
8" FIBERGLASS
                                                                    SCRUBBER WATER
                                                                    OUT
  INLET SAMPLING  PORTS


 U-TUBE MANOMETER TAP
 FOR SCRUBBER DIFFERENTIAL
 PRESSURE

   FAN MOTOR
                                                                 CONCRETE BASE
                      SAMPLING  POINT LOCATIONS
                     UREA  PRILL  TOWER SCRUBBER
                    UNION  OIL, BREA,  CALIFORNIA
                                    IV-2
                                                             ENGINEERING-SCIENCE

-------
                                               FIGURE IV-2
SCHEMATIC OF SAMPLING LOCATION
UREA PRILL TOWER SCRUBBER INLET
  UNION OIL, BREA, CALIFORNIA



Traverse Point Tra-
No.
1 20
2 21
3 22
4 23
5 24
6
7
8
9
10
11
12
13
14
15
16
17
18
19
/

1 B
Afl"

1
^
in
verse Point Location Trav
^••M
A


erse Traverse Point Location
From Outside Nipple (IN.) Point No.
4-1/2 47 25
5-1/2 48-1/4 26
6-5/8 49-3/8 27
7-7/8 50-1/2 20
9 51-1/2 29
10-3/8
11-3/4
13-3/8
15
17-1/8
19-1/2
23-1/8
32-7/8
36-1/2
39
41
42-5/8
44-1/4
45-5/8
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48














From Outside Nipple (IN]
4-1/2 47
5-1/2 48-1/4
6-5/8 43-3/8
7-7/8 50-1/2
9 51-1/2
10-3/8
11-3/4
13-3/8
15
17-1/8
19-1/2
23-1/8
32-7/8
36-1/2
39
41
42-5/8
44-1/4
45-5/8
            IV-3
ENGINEERING-SCIENCE

-------
                                                FIGURE IV-3
 SCHEMATIC OF SAMPLING LOCATION
UREA PRILL TOWER SCRUBBER OUTLET
   UNION OIL, BREA, CALIFORNIA
                48

Traverse Point
No.
1 20
2 21
3 22
4 23
5 24
6
7
8
9
10
11
12
13
14
15
16
17
18
19
/
o/V
V
\
\ X
y
B
L.
A
N

H/ J.LI />
Traverse Point Location Traverse
From Outside Nipple (IN.) Point No.
3-1/2
3-1/2
4-1/2
5-3/4
7
8-1/2
9-1/2
11
12-3/4
14-3/4
17
20-3/4
30-1/4
34
36-1/4
38
40
41-1/2
42-3/4
44 25
45-1/4 26
46-1/2 27
47-1/2 28
47-1/2 29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48














Traverse Point Location
From Outside Nipple (IN.]
3-1/2 44
3-1/2 45-1/4
4-1/2 46-1/2
5-3/4 47-1/2
7 47-1/2
8-1/2
9-1/2
11
12-3/4
14-3/4
17
20-3/4
30-1/4
34
36-1/4
38
40
41-1/2
42-3/4
             IV-4
                                       ENGINEERING-SCIENCE

-------
                                                                      FIGURE  IV-A
LADDER
                OVERHEAD SCHEMATIC OF PRILL TOWER SCRUBBER OUTLETS
                       AT UNION OIL COMPANY, B3EA, CALIFORNIA
                                     IV-5
ENGINEERING-SCIENCE

-------
Scrubber Solution Sampling Location
     The scrubber  solution   samples  were  collected  at  an existing  valve
located in  the low  pressure  scrubber solution  recirculating  system.   All
scrubber solutions are collected in a  common sump and then circulated through
two pump  systems;  a  high pressure  and a  low pressure  system.  Therefore,
the scrubber solution  samples  were collected downstream  of  the  sump and are
composite samples of  the scrubber solution.  Figure  IV-5 shows  the location
of this sampling site.
Visible Emissions Observations Location
     During all  sampling runs  visible emissions  data were collected  by  a
single observer.  Figure IV-6 shows the approximate locations of the observer
during different times of the day.  The observer started  the morning readings
usually 200 to 400 feet  southeast  of the  prill tower.   As the day continued,
the observer would change  positions  in order to keep his back  to the  sun.
     While the prill  tower  was operating on feed  grade  urea, it was  neces-
sary for  the  observer  to  relocate  nearer  the scrubber  outlets.   This  was
accomplished by  the  observer  positioning himself  on a  staircase  near  the
top of  the  prill tower  elevator.   In  this  position the  observer  was  about
50 feet from the scrubber outlets.
Pressure Drop Measurement Tap Locations
     A U-tube  manometer  was connected  across  the  inlet  and outlet side  of
all four scrubbers.   On  the  inlet side, a 1-inch port was  located  58  inches
from the base  of  the  scrubber on  the downstream  side of  the  fan.   One side
of the  manometer was  connected   to  this port.   On  the  outlet  side,  the
sampling ports located  24 inches  upstream  of  the  outlet  were  adapted  using
a rubber stopper, the  remaining  side of the manometer was  then  connected to
the stopper.   This  arrangement was  the  same  on all  four  scrubbers.   Each
manometer was  filled  with  a water  solution  containing  flourescent dye  to
facilitate reading.
                                    IV-6

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                                                                  FIGURE  IV-5
UREA  PRILL  TOWER  SCRUBBER SOLUTION  OR LIQUOR SAMPLING  POINT
                  UNION  OIL, BREA, CALIFORNIA
                              TO SCRUBBERS
                      HE
SE
  FROM
  SUMP
SW
NW
                                                      2  STAINLESS
                                                      STEEL LINES
                                                        ROTAMETERS
 t      I      t
                                                              LINE
                                                              PRESSURE
                                                              GUAGE
                                                              -tx—
            PUMP
                                 SCRUBBER
                                 WATER SAMPLE
                                 COLLECTION
                                 POINT
                                 IV-7
                             ENGINEERING-SCIENCE

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                                                                      FIGURE  IV-6
          ELEVATOR'
                                                     2  STEAM PIPES
                                                   4 WET  SCRUBBERS
                                               PRILL TOWER
                          FIGURE  1  -  UREA  PRILL  TOWER
<
 O
SUN

OBSERVER
RELATIVE HUMIDITY &
TEMPERATURE LOCATION
                                                                     N
                                                                \
                         FIGURE  2  - OBSERVER POSITIONS
                                    IV-8
                                                       ENGINEERING-SCIENCE

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Velocity Traverse Measurement Location
     Velocity traverses were performed at the  oultets  of  all four scrubbers.
Ports were located  24 inches upstream and  downstream  from  the  nearest flow
disturbance.  Traverse points  were located  in accordance  with EPA Reference
Method 1.  Twenty-four  traverses were conducted  on each  port,  for  a total
of 48 points  per scrubber  outlet.   Each outlet  was  traversed  twice  during
each velocity  test  with  velocity head  and stack  gas temperature  measured
at each point.
ROTARY COOLER
     A rotary cooler  is connected  on the  product  outlet side  of the prill
tower.  Sampling for  urea  particulate and particle  sizing were conducted on
the inlet  side.   The inlet  side  was selected  because  of  the counter-flow
air movement through  the  cooler.  The outlet  duct  is 24  inches in diameter
and is connected to a rotoclone scrubber.
     Sampling for urea  particulate was  accomplished by  specially installed
sampling ports.  Two  ports,  4  inches in diameter  are oriented  90°  to  one
another.  The  nearest upstream  disturbance was  an  in-line  damper  located
55" from  the  ports.   The nearest downstream disturbance  was  47  inches from
the ports.   In  the  first  sampling run  a  20 point  traverse  was  sampled,
15 points  per  port.   On  sampling  run  two and  three, a  24-point traverse,
12 points  per  port,  was  sampled.  Port A was  located  on  an  horizontal axis,
and Port  B was  located  on  a  vertical  axis  (see  Figure  IV-7  and  IV-8).
Particle Size
     Particle size data  were  collected  at the  same sampling  location used
for the  urea  particulate.  Traverse  point  No.  9  on  Port  A was  chosen as
the location  of the  most  representative  flow.   Three  particle  size runs
were conducted at this location.
AMBIENT TEMPERATURE AND RELATIVE HUMIDITY LOCATIONS
     Throughout  the entire period of testing ambient temperature and relative
humidity data  were  collected.   The  location  of  this  data  collection  was
approximately 30 feet on  the  northeast side of the  prill  tower.  The  tester
positioned himself at groundlevel and directly  across from one  of  the  air
inlets to the prill tower.
                                     IV-9

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Process Sample Collection Location
     During each  sampling  run,  one urea  product sample  was  collected  for
bulk density and sieve analysis.  The point of collection was at the conveyor
inlet which is located  at  the  bottom  center  of  the  prill  tower.   An access
hatch 12" x 24" was momentarily opened and a sample was collected.
                                     IV-10

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                                            FERTILIZER  GRADE  UREA ROTARY

                                                COOLER  SAMPLING SITE
<1
             FERTILIZER

             UREA COOLER
                                                                          SAMPLING PORTS
                                                                                                  TO ROTOCLONE

                                                                                                  SCRUBBER
m
m
CO
I
e/3
                                                                                                                       O
                                                                                                                       f

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                                              FIGURE IV-8
SCHEMATIC OF SAMPLING LOCATION
   ROTARY COOLER OUTLET DUCT
  UNION OIL, BREA, CALIFORNIA
Traverse Point
No.
1
2
3
4
5
6
7
8
9
10
11
12
1 B L^^^^
IA A
24 ID 	 7
Traverse Point Location Traverse
From Outside Nipple (IN.) Point No.
4-1/2 13
5-5/8 14
6-7/8 15
8-1/4 ig
8-7/8 17
12-3/8 18
19-1/2 19
22 20
23-3/4 . 21
25-1/8 22
26-3/8 23
27-1/2 24
Traverse Point Location
From Outside Nipple (IN.'
4-1/2
5-5/8
6-7/8
8-1/4
8-7/8
12-3/8
19-1/2
22
23-3/4
25-1/8
26-3/8
27-1/2
            IV-12
ENGINEERING-SCIENCE

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            SECTION V
SAMPLING AND ANALYTICAL PROCEDURES

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                                SECTION V
                    SAMPLING AND ANALYTICAL PROCEDURES

INTRODUCTION
     This section contains the procedures  followed  in collecting samples
at the  urea prill  tower  and the  rotary  cooler.   All emission samples
were collected following specific protocols prepared by EPA.
     The analytical procedures were  also prepared  by  EPA.   The analysis
of the samples was conducted at the ES, Arcadia,  California air laboratory,
and at  Analytical  Research  Laboratories  (ARLI),  Monrovia,  California.
The particle size analysis was conducted at the ES, McLean, Virginia,.air
laboratory.  Union  Oil  Company analyzed product samples at their quality
control laboratory, Brea, California.
EPA Reference Methods for Sampling
     The location of the sampling sites was selected following the recom-
mendations in EPA Reference Method  1,  Sample and  Velocity  Traverses for
Stationary Sources, CFR 40, Part 60.
     The velocity and  volumetric  flow rates through  the  prill  tower and
rotary cooler were determined  by following  the guidelines in EPA Reference
Method 2, Determination  of  Stack Gas Velocity  and  Volumetric  Flow Rate,
CFR 40, Part 60.
     Moisture content  of  the  gas streams  tested  was determined  by  fol-
lowing EPA  Reference  Method  4,  Determination  of Moisture  Content  in
Stack Gases, CFR 40, Part 60.
     Particulate sampling  was conducted  employing modifications  to EPA
Reference Method  5, Determination of Particulate  Emissions, CFR 40,  Part
60.  The modifications  to  EPA Method 5 are addressed  in more  detail  in
the following sections.
     During the entire  period of  field testing, visual observations for
opacity of emissions were performed.  EPA Reference Method 9 was followed
for these determinations, as referenced in CFR 40, Part 60.
                                   V-l

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Urea Particulates
     Modified Method 5 sampling was conducted simultaneously at the inlet
and outlet  of the  northeast  scrubber  located  at the  top of  the prill
tower.  A total  of  48 traverse points  were  sampled  at three minutes per
point for  the  outlet  and two  minutes  per  point  for  the   inlet.
     Borosilicate heated  glass  probes were  used for  all  sampling.   Be-
tween the probe  and sample  box,  an  unheated  5/8"  O.D. teflon tube was
used.  The  sample box  contained  six impingers.   The first and third were
Greenburg-Smith impingers, the remainder were 1/2" straight  tube impingers
with the open end within 1/2" of the bottom of the impinger jar.   The
first two impingers contained deionized-distilled water.   The third and
fourth contained  one normal  sulfuric  acid  (IN 112804).   The  fifth  was
operated dry and the sixth contained 200 grams of silica gel.  All impin-
gers were contained  in  an insulated container and kept  under  ice during
sampling.
     All sampling was  performed  isokine tic ally.   Sampling  and  meter  box
conditions were recorded every  two minutes for the inlet and three minutes
for the outlet.  During port changes both sampling teams completed one port
and would then begin sampling the second port concurrently.
     When the prill tower was switched  to  fertilizer grade urea,  special
manometers were necessary to monitor  flow.   Inclined oil manometers with
a range of 0 to 0.02 inches of water were used for flow determinations.
     Testing of  the rotary cooler  was  similar  in  method to  the prill
tower.  However, no concurrent testing was  conducted since  the  outlet
duct was tested prior to the rotoclone scrubber.  No  emission data for the
scrubber outlet were collected.  Also, the rotary cooler is used only for
fertilizer grade urea; therefore, only  data  for  fertilizer grade urea is
reported.
Sample Recovery
     At the conclusion of  each sample run, the Method 5 sample box, teflon
tube, and probe for each team were delivered to a mobile field laboratory
set-up at the  Union Oil  plant.   During transport from the prill tower to
the laboratory, rubber plugs  were  inserted into all  open  probes,  teflon
tubes and sample box openings  to prevent loss of  sample and contamination.
                                  V-2

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     Before clean-up began,  two  borosilicate glass bottles  with teflon-
lined caps were labeled to identify the sample run, location, prill tower
product, date, and time.  One container was identified  as "Container #1"
and contained the contents of the first two impingers (deionized-distilled
water), and all  deionized water washings,  which included the  first two
impingers, connecting  glassware,   teflon  tube,  and  probe.   The  second
glass container was  identified  as "Container #2" and  contained the con-
tents and rinses  of  the third,  fourth (the  impingers  which contained the
IN H2SC-4) and  fifth impingers.   When these  impingers  were  emptied and
rinsed, all rinses  were performed using  IN 112804.   After emptying  each
impinger into  the appropriate  container,  the  impinger   and  associated
glassware were  rinsed  three times  with  the  corresponding  liquid  wash.
During the  clean-up  procedures the  impingers remained assembled,  i.e.,
the impinger  tube assembly  was not  removed  from the  impinger  jar.
     The teflon tube was  washed with three separate  deionized-distilled
water rinses.  Prior to  each  washing,  a glass  flask with  28/12 ground
glass joint  was  attached  to  the  tube.   The  flask  was  filled  with
approximately 75  ml  of deionized-distilled  water and  then  washed three
times by rinsing  the rinse  water from one  end  of the tube to the other.
The rinse was then emptied  into  Container #1 and the  procedures repeated
two additional times.
     The probe was washed with the nozzle  attached.   Seventy-five ml of
rinse water  were placed  into  the same  flask used  for  the  teflon tube
washings.  The  rinsing  for  the  probe was  performed  in  the  same manner
as the  teflon  tube  washings  above.   In  addition  to the rinsings, the
probe was  brushed and  rinsed  an  additional three times to  remove all
particulates.
     After the  clean-up procedure  was  completed,  the  liquid  levels  in
container #1  and Container  #2 were  marked  and the  caps  sealed.   The
containers were  then transported  to  the  ES laboratory  in  Arcadia for
analyses.  All clean-up procedures were identical for all sample runs and
were the responsibility of the same two field technicians.
Sample Handling
     Once the field  samples were brought into  the  laboratory,  they were
immediately logged into a lab  notebook and  then measured volumetrically
to determine their initial sample volumes.  The volume of  each sample was
                                  V-3

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recorded in a hard-bound chemistry lab book as were all of the subsequent
dilutions and concentration results.   Two hundred milliliters were removed
from each sample  and  delivered  to  Analytical Research Laboratories, Inc.
for Kjeldahl  analysis  to  determine  the concentrations  of ammonia  and
urea.
     When a sample  was  transported  from one location to another, the lid
of the sample jar was taped and the solution level was marked on the side
of the  container.  There  were  two  types  of  sample  solutions,  labeled
Container #1  and  Container #2  (identified  in the report  as Cl  and  C2,
respectively).  Number  1  Containers  were samples  in  water solutions  and
Number 2 Containers were samples in IN H2S04.
Analysis
     Colorimetric Analysis -  One  of  the methods of  analysis employed to
determine the mass of  urea in a sample was by a colorimetric determination
following an  EPA  draft  method "Determination  of Particulates,  Urea,  and
Ammonia Emissions  from  Urea  Plants".   An  aliquot of  field sample  was
prepared for  analysis by  adding  P-dimethylaminobenzaldehyde  as a  color
reagent.  The  color  intensity  was  determined  using  a  visible  light
spectrophotometer set  at  a  wavelength  of 420  nanometers  (nm).   The
concentration of  urea  is   determined  by  comparing  the  data  from  the
spectrophotometer for  the   samples  to  a calibration curve  constructed
from samples of known urea concentrations.
     The urea concentration of the samples was determined by the following
equation:
        mg/ml of urea sample *» 	absorbance	
                               slope of calibration curve
     Kjeldahl Analysis -  The  Kjeldahl  analysis was  performed by  ARLI.
A sample aliquot  was  prepared and digested  for  approximately  two  hours.
The distillate was collected in  a solution of boric acid and then titrated
to a  bromo-creosol green-methyl  red  end point  using a  IN solution  of
hydrochloric acid.  This  distillation  and   titration  yielded   the  total
Kjeldahl nitrogen as follows :
   Total Kjeldahl Nitrogen  (mg/ml) = (ml  of  HC1) (Normality  of  HC1
                                   V-4

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The amount of ammonia nitrogen  was calculated from the amount of ammonia
determined by Nesslerization:
             Ammonia Nitrogen = (Ammonia mg/ml) (0.82)
In the above  formula  for Kjeldahl nitrogen,  14  represents  the molecular
weight of  nitrogen.   In the  second  formula,  0.82  is the  percentage of
nitrogen in one mole of ammonia.  Total organic nitrogen is then determined
by subtracting:
     Total Organic  Nitrogen  =  Kjeldahl  Nitrogen  -  Ammonia  Nitrogen
From the Total Organic Nitrogen, the  concentrations of urea in the aliquot
can be calculated as follows:
            Urea (mg/ml) = Total Organic Nitrogen x 2.14
The factor of  2.14 represents the  ratio  of nitrogen in one mole of urea,
calculated as follows:
           2.14 =   MW of Urea    =  MW of (NH?)9 CO  =>  6£
                  MW of Nitrogen        MW of N2         28
Ammonia Analysis
     The samples  collected  for urea  analysis  were  also  used  for  the
determination of  ammonia.   The  sample  recovery  and  preparation  was
identical to that of the urea samples.
     Two methods of analysis  were  used.   At the ES laboratory the amount
of ammonia was determined by direct Nesslerization.  The final concentra-
tion was  determined  by  comparing the  absorbance  units  of  the  samples
from a visible  light  spectrophotometer,  and  then  calculating the amount
of ammonia from a calibration curve as follows:
            mg of ammonia/ml = absorbance of sample aliquot
                                        0.166*
*0.166 is the calculated slope of the calibration curve.
                                     V-5

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Formaldehyde Particulates
     The analysis of  formaldehyde was performed on a sample aliquot from
the same  sample used  for  the  determination  of  urea and  ammonia.  The
formaldehyde method  is a  colorimetric determination  using chromatropic
acid as the  color  indicator.  A  calibration curve was  constructed from
solutions with  a  known  formaldehyde  content.   The  concentration  of
formaldehyde was determined  as follows:
                Formaldehyde mg/ml =  absorbance
                                        0.333*
Particle Sizing Test
     A total  of ten particle  size  determinations were  conducted  on the
urea production area.   These tests  were run  on the  inlet of  the urea
cooler, and  seven  tests were  run on  the  inlet of the  urea prill tower
scrubber.  Three of  the  prill  tower  tests  were conducted while the plant
was producing feed  grade urea.  The  remaining  four  tests were conducted
during fertilizer grade urea production.
     An Anderson Six-Stage   Cascade  Impactor was  used for  these  deter-
minations.  The  sampling  time  per  run  was  approximately 15  minutes.
This shorter  sampling time  was  required  because  the grain  loading  was
so heavy.   Also,  most  of.  the  particles  were in  the  15  to  20  micron
range, with the majority  of particles in this  range;  the ability  of the
impactor to fractionate the  particulate was limited.
     After the samples were  collected they were shipped to the ES, McLean,
Virginia laboratory  for  gravimetric  determination.   A  Cahn,   Model  21,
Electro Balance was used for these weighings.  All substrates were weighed
in triplicate, or until a stable weight was achieved.
Visible Emission Observations
     During the  entire  period  of  testing  at  the  urea  plant,  visible
observations for opacity  were conducted.  All observations were conducted
by the  same  individual.  EPA  Reference Method  9 was  followed for  all
visible emission observations.
*0.333 is the calculated slope of the calibration curve.
                                    V-6

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     The observer changed his observation position as each day developed.
During the  feed grade  urea  production,  when  opacity  was  difficult  to
observe, the observer  moved to within 25  feet  of the  scrubber outlets.
The majority of  the  other  readings  were made  from  about 200  feet  from
the prill tower scrubber outlets.
Velocity Measurements on the Untested Scrubbers
     Union Oil has four  scrubbers  located  at the top of the prill tower.
Only one scrubber was tested for  emissions.   The remaining three scrubbers
were measured for volumetric flow.  These determinations were made during
modified Method 5 tests.  Before and after each test a 48-point traverse
was conducted  on each  scrubber using  Type-S  pitot  tubes.   An  average
point of flow  was  determined, and it  was  this point that  was  monitored
during each test.
     The purpose of monitoring the  air flow through the untested scrubbers
was to determine the flow through the entire prill tower.  After the flow
has been determined,  estimates of total emissions could be calculated.
Scrubber Solution Test
     During the modified  Method 5 testing,  a protocol  for  sampling the
scrubber solution was developed.  This  protocol  included  the collection of
scrubber solution every 15  minutes for a  total  of five  samples per test
run.  The temperature of each sample  was measured at collection.  When the
samples were  at room  temperature,  pH measurements  were made on  each
sample.  A composite  sample  was  then  made from the five individual samples
collected and the pH was measured again.
     The composite  samples  were delivered to ES, Arcadia laboratory for
analysis.  Each  sample  was analyzed  for  ammonia,  urea,  formaldehyde,
percent solids,  Kjeldahl  ammonia  and  urea.  The  Kjeldahl analysis  was
conducted at ARLI laboratories.
                                  V-7

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Pressure Drop Measurements
     A U-tube manometer  was installed  on  each scrubber.  During testing
each manometer was read  to determine the pressure drop across each scrub-
ber.  Average  pressure  drop  determinations   were   calculated   for  each
scrubber and for each test run.
     During some of  the  tests, the inlet  side  of  the scrubber  connected
to the U-tube would  become  plugged  with the urea product.   When this oc-
curred the manometer was disconnected,  the opening  cleaned and  manometer
readings resumed.
Relative Humidity and Ambient Temperature Test
     Data for  relative  humidity  and ambient  temperature  was   collected
during all  phases  of  testing.  The  tester positioned  himself  approxi-
mately 30 feet  to  the  northeast of the  prill  tower.   A  Bendix  Model 556
Aspirated Wet-Dry  Bulb  Psychrometer was used  for  these determinations.
Readings were  taken  every  15  minutes.  Averages  for  relative  humidity
and temperature were then calculated.

BULK DENSITY AND SIEVE ANALYSIS METHODS
Bulk Density
     Bulk density of the urea  product was  performed  on  samples  taken at
the prill  tower and  rotary cooler according  to  the  method listed  in
Appendix I  of  this report.  Briefly,  a sample  of  500 ml  in  volume was
taken at each  of  the previously mentioned  sites.  Each  of these samples
was divided into two parts  containing  250 ml  of product.   One-half was
set aside for sieve analysis  (discussed  later).   The other half was poured
through a  funnel  into   a specially  prepared,  tared 250 ml   graduated
cylinder.  When  completely  filled,  the  cylinder   was  leveled with  a
straight edge  and  weighed again.   The  results were  then  calculated and
recorded (see Section II and Appendix E).
                                  V-8

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Sieve Analysis
     Sieve analysis of the urea product was  performed according to methods
listed in  Appendix I  on the  first half  of the  samples collected  and
described above.   A 200  gm sample  was poured  into  a  nest of  sieves,
containing No. 8, 10, 12, 14,  20, 30, 40,  and  50 mesh  screens and shaken
for one minute.  The nest was  then  placed  on a mechanical shaker and  run
for five minutes.   The  material on each  screen  and bottom  pan  was then
weighed.  The  results  were  then calculated and recorded  (see Section II
and Appendix E).
Chemical Analysis by Union Oil
     Union Oil, Brea, California, performed analysis on the urea product.
Their analysis included determination of  ammonia,  urea and formaldehyde.
This data  is  considered proprietary information  and  is  not included in
this report.
                                     V-9

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