POWELL COUNTY, MONTANA

AIR  POLLUTION  ABATEMENT  ACTIVITY
        U.S. DEPARTMENT OF HEALTH. EDUCATION, AND WELFARE
                    Public Health Service
     Bureau of Disease Prevention and Environmental  Control
           National Center for Air Pollution Control
                         July 1967

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            POWELL COUNTY, MONTANA
        AIR POLLUTION ABATEMENT ACTIVITY

        PRE-CONFERENCE INVESTIGATIONS
          Prepared for Conference Use Only
   U.S. DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE
               Public Health Service
Bureau of Disease Prevention and Environmental  Control
      National  Center for Air Pollution Control
                     July  1967

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       Following the Powell County, Montana, Air Pollution Abatement Conference a
comprehensive report including this report; the Conference presentations of the
Department of Health, Education, and Welfare; and the recommendations resulting
from the Conference, will be prepared and made available for general distribution.

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                                     CONTENTS

  I.   Introduction 	  1
 II.   Rocky Mountain Phosphates, Inc.  - Process  and Emissions  	  7
      General  	  7
      Process  Description 	  7
      Air Pollution Emissions 	  11
      Design,  Operation, and Maintenance Deficiencies  	  12
III.   Fluoride Emission Control  Technology 	  17
 IV.   Topography and Climatology of Garrison Area 	  19
      Topography 	  19
      Temperature 	  19
      Precipitation 	  20
      Atmospheric Stability 	  20
      Wind Speed 	  24
      Wind Direction 	  27
  V.   Distribution of Fluoride In Garrison Area  	  33
      Fluorides in Grass 	  33
      Fluorides in Evergreen Foliage 	  37
      Fluorides in Water 	  37
      Fluorides in Soil 	  41
  APPENDICES 	  43
      Appendix A  Correspondence and Resolutions 	  43
      Appendix B  Analytical Methodology for Fluoride  	  49
  REFERENCES 	  51

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                           POWELL COUNTY, MONTANA
                      AIR POLLUTION  ABATEMENT  ACTIVITY


                                   I.  Introduction

       By letter of March 8,  1967,  the  Governor of the State of Montana forwarded
to the Secretary of Health, Education,  and Welfare a resolution of the Board of
Commissioners of Powell  County, Montana, requesting the Secretary to call  a
Conference to deal  with  the problem of  air pollution In the County.  In forwarding
the resolution, the Governor  stated his concurrence in the reouest.  Concurrence
was received from the Montana State Health Officer as well.  The resolution of the
Powell County Board of Commissioners, and a resolution of the Senate of Montana,
both recognize the air pollution  problem In the Garrison area of the County.
Copies of the letters from the Governor and from the State Health Officer to the
Secretary of Health, Education, and Welfare,  and copies of the Powell County and
the Senate resolutions appear in  Appendix A.

       Powell County, located in  west central Montana, has an area of 2,337 square
miles and an estimated 1965 population  of 7,300.  The County seat 1s Deer Lodge.
The more than 200 farms  and ranches in  the County yield products valued at more
than $4,000,000 per year.  Livestock  production accounts for almost 80 percent of
the total value of the County's agricultural  products.  Powell County 1s shown
1n Figure 1.

       Garrison is located near the junction  of the Clark Fork and the Little
Blackfoot Rivers, approximately 45  miles west of Helena, Montana.  The town of
Garrison is situated in  a mountain  valley slightly west of the junction of U.S.
Highways 10 and 12.  The valley floor is approximately 4,400 feet above sea level,
and the surrounding mountains rise  to elevations of 9,400 feet.

       Approximately 200 people live  within a half-mile of the junction of
U.S. Highways 10 and 12.  Garrison  contains about 50 permanent homes, as shown
in Figure 2, and about 20 mobile  units  at Lahman's Trailer Court about a half
mile south of the junction of the highways.

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                                                        MCDONALD
                                                          PASS
                       Figure 1.   Map of Powell  County,  Montana.


       In 1963 Rocky Mountain Phosphates, Inc., installed a phosphate rock defluor-
ination plant in Garrison and began producing an animal feed supplement in August
of 1963.  In the early days of its operation the plant had practically no air pol-
lution control devices, and sulfur dioxide, acid mist, and gaseous and particulate
fluoride were released directly to the atmosphere.  Vegetation damage and glass
etching were soon apparent.  Montana State authorities received many complaints
about these emissions.

       Personnel from the Montana Board of Health analyzed grass samples from the
vicinity of the plant prior to operation and found fluoride concentrations of less
than 10 ppm.  Very shortly after the plant began operating, the fluoride content
of the grass in the vicinity of the plant increased to over 300 ppm.  Between
September 1963 and March 1964, classes at the Garrison Public School reportedly

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                                                         ROCKY
                                                         MOUNTAIN
                                                         PHOSPHATES, INC.
                  Figure 2.   Map of Garrison,  Montana.
were interrupted 35 times because of air pollution from the plant.  During this
time court action was brought against Rocky Mountain Phosphates, Inc., by the
citizens of Garrison for alleged nuisance and health effects caused by the
emissions.  Because of the serious complaints and court actions, technical
personnel from the Public Health Service, U.S. Department of Health, Education,
and Welfare; the Montana State Board of Health; and private consultants inspected
the plant and/or the vegetation in the area.  All inspectors agreed that signifi-
cant quantities of fluoride and/or sulfur dioxide were released during the 1963
and 1964 growing season.  Donald F. Adams, Technical Consultant to the Third
Judicial District Court, found varying degrees of needle burn of up to 100 percent
on pinus ponderosa, depending on the distance and direction from the Rocky
Mountain Phosphates, Inc., operation.

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       During the time of these early complaints and court trials, the company
installed spray towers in an attempt to remove the fluorides from the exhaust
gases.  In August of 1964 personnel from the Public Health Service and the
Montana State Board of Health conducted a stack test at the plant.  The findings
of this stack test indicated conclusively that the collection equipment provided
by Rocky Mountain Phosphates, Inc., was ineffective in removing fluorides from the
            2
stack gases.

       Reports of these studies also testify to the poor maintenance and operating
procedures applied by the Company to limit pollution.

       Further court action filed by local ranchers in 1965 alleged cattle damage
by fluorides emitted by the plant.  The court ruled in favor of the plaintiffs in
this case and awarded $123,000 in damages.

       Complaints against the plant continued, and in a letter dated March 8, 1967
Governor Tim Babcock of Montana concurred in a request by the Powell County Board
of Commissioners for the Secretary of Health, Education, and Welfare to initiate
a Federal air pollution abatement action under the provisions of Section 105 of
the Clean Air Act (42 U.S.C. 1857 et seq.).

       The following is a brief chronological record of the plant operation:
   (Approximate Dates)
   January 14, 1960           Plant opened 1n Butte, Montana.  Complaints were
                              received by Montana Board of Health almost immedi-
                              ately.  One school was interrupted several times,
                              and a nuisance action was filed but no action was
                              taken.
   August 1, 1963             Plant began operation in Garrison.  Complaints of
                              severe air pollution were made to Montana Board of
                              Health soon after plant began operating.
   September 1963 to          Garrison school interrupted 35 times by gas and
   March 19, 1964             smoke.
   October 1963               Donald F. Walters, Engineer, Public Health Service
                              inspected the plant with Benjamin F. Wake of the
                              Montana State Board of Health.
   October 1963               Court action brought by citizens of Garrison against
                              Rocky Mountain Phosphates, Inc.

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February 1964




March 9, 1964



June 12 to 15, 1964


July 27, 1964



August 1964


August 17. 1964



November 6, 1964



November 11, 1964


November 11. 1964


November 20. 1964


December 7, 1964
March 1965


April 5, 1965
Hearing before Judge Haswell  in Powell  County with
plant's consulting engineer and R.  Smith of Montana
School of Mines.  Plant's consulting engineer stated
2.000 Ib/day of fluoride being emitted.

Court action, Mollenberg et al. versus  Rocky Mountain
Phosphates, Inc., before Judge Haswell  In Powell
County.

Plant closed by court order;  then allowed to open
again.

Plant ordered closed by State Board of  Health as
health menace.  Plant back In operation within a
few days.
80-foot section added to lengthen stack.
stack height Increased to 210 feet.
Total
Public Health Service and State Board of Health
began stack testing at plant.   Findings  were
conclusive that controls were  poor to nonexistent.

Plant ordered by State Board of Health to cease
operations until court order of June 10, 1964, had
been compiled with.  Plant closed for a  few days.

Affidavit from Plant stating compliance  with all
court orders.  Production resumed.

Contempt order Issued by State Board of Health.
Plant continued to operate.

Montana State Board of Health  hearing with Rocky
Mountain Phosphates representatives.

Trial before Judge Jack Green  at Deer Lodge, Montana.
Suit brought by State Board of Health on contempt
charge and charge that Plant was a menace to health.
A suit was also brought by Garrison citizens and
heard at the same time to abate the Plant as a
nuisance.  Mrs. Ralph Davis, teacher at Garrison
School, was given authority to close plant during
2-week period.  Board of Health authorized to close
plant if good reason could be given.

Plant defluorinating process changed from acid  to
alkali process.

Ruling by Judge Green on December 1964 trial -
contempt charges disallowed; health hazard charge
disallowed; nuisance charge upheld.  Plant shut down
for short time by order of Judge Green.  Permitted
to operate again after few days to allow sampling by
Resources Research, Inc.
April 1965
Plant capacity doubled by addition of second kiln.

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 May  5,  1965
Suit brought by local ranchers to close Plant and to
collect damages.
 July 1965 to
 September 1965

 July 1965 to
 October 1965

 February 1966
 April  2, 1966




 May 11, 1966



 Summer 1966


 September 1966


 Late 1966


March 3, 1967

March 8, 1967
Study of emissions at Plant made by Montana State
University for Judge W. W. Lessley.

Donald F- Adams, Court Consultant, studied ambient
air and vegetation in Garrison for Judge Jack Green.

First commercial scrubber installed at Rocky
Mountain Phosphates, Inc.  James T. Tomany, engineer
for the vendor, testified that if the vendor's
scrubber was operated in accordance with design flow
rates, the fluoride removal from the stack gases
would be 98 percent and that a total of less than
7 pounds/hour would be emitted when the Plant was
producing 70 tons per day.

Final trial on ranchers damage action; $123,000
damages awarded.  Decision now being appealed to the
Montana Supreme Court by Rocky Mountain Phosphates,
Inc.

Abatement action requested by ranchers denied by
Judge Lessley.  Decision being appealed to Montana
Supreme Court.

Plant stack collapsed and was replaced by discarded
product cooler, 4 feet diameter, 90 feet high.

Commercial scrubber severely corroded and removed
from service.  Replaced by "plant designed" scrubber.

Second scrubber built by Rocky Mountain Phosphates for
use on No. 2 kiln.

Montana Air Pollution Control Law signed by Governor.

Governor Tim Babcock of Montana concurred in the
resolution of Powell County Board of Commissioners
requesting Federal Abatement Action in Powell County.

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     II.  ROCKY  MOUNTAIN  PHOSPHATES, INC.- PROCESS AND EMISSIONS
GENERAL
       Rocky Mountain  Phosphates, Inc., 1s engaged In defluorinating phosphate
rock to make a product suitable for an animal feed supplement.   Phospate rock
used 1n this process ordinarily contains from 3.5 to 5 percent fluorine.  In the
processing of phosphate rock for use as an animal feed, the  fluorine content of
the def1uorinated product must be reduced to at least 0.18 percent.

       Two processes,  the acid process, and the alkali process,  have been used
by Rocky Mountain Phosphates, Inc., 1n removing fluorine from phosphate  rock at
Its Garrison plant.

       Originally the  add process was used.  This process Involved adding
phosphoric add and sulfurlc acid to ground rock in a mixing operation.  Sulfur
oxides, add mists, and gaseous fluorides are released In this process.  The
resulting mix, similar to normal superphosphate fertilizer,  1s passed through
a high-temperature, gas-fired kiln, where most of the remaining  fluorides are
released.  This type of process was used by the plant from the beginning of Its
operation until early  In 1965 when the process was changed to the alkali process.
The process now used 1s essentially a modification of the soda-ash process
patented by the Smith-Douglas Company of Norfolk, Virginia,  under U. S.  Patents
2,839,377, dated June  17, 1958; and 2,995,437, dated August  8, 1961.

       Only the mixing operation 1s changed in converting from the add  to the
alkali process.  Ground phosphate rock, phosphoric add, and soda ash are mixed
to form a relatively dry mixture called "add rock."  Little or  no emissions
are released in the mixing operation.  The resulting "add rock" 1s further
processed in the fired kiln to release the fluorides in a manner similar to that
of the add process.

PROCESS DESCRIPTION
       Figure 3 shows  the plant layout, and Figure 4 1s a flow diagram of the
def1uorination process. The mixing operation is performed in a  small pug mill.
The phosphate rock, soda ash, and phosphoric add are transferred from storage
to small weigh tanks directly above the mixer.  These feed materials are charged
to the mixer in the proper proportion.  Mixing is continued  at a steady  rate

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                                                          TO GARRISON (1/4 Ml )
                                                  RAW ROCK
                         RAW ROCK STORAGE
                         RAW
                         ROCK
 ACID
STORAGE
NORTHERN
PACIFIC
R.R.
    TRAILER COURT
          Ml )
NOTE: Drawing not to scale.
                                                      KILNS
OFFICE
LAB
                                                                  ROUTE   12
             TO  DEER  LODGE  6  BUTTE
                   -	
                    ROUTE   10

       Figure 3.   Rocky Mountain Phosphates Inc. plant layout.
                                                                TO HELENA

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PHOSPHATE
  ROCK
 STORAGE
  SODA
   ASH
STORAGE
PHOSPHORIC
   ACID
 STORAGE
STORAGE OF ACID ROCK
                   GASEOUS
                  FLUORIDES
I
ROTARY

KILN
4
                                                    L
                                                COOLING   NATURAL     COARSE
                                                 WATER     GAS       STORAGE
                                                           FUEL        BIN
                                                                                  PARTICULATE
SCREEN

1

FINE
STORAGE
BIN
                                                                                                 PRODUCT
                                                                                                 TO BAGGING
                                                                                                 AND BULK
                                                                                                 LOADING
           Figure  4.   Flow  diagram of  Rocky Mountain Phosphates, Inc., phosphate rock
                      defluorination plant in Garrison, Montana.

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 of one  2,400-pound batch about every 5 minutes.  Approximate feed rates  and
 fluoride content of the feed material  as supplied by Rocky Mountain Phosphates,
 Inc.,  are as follows:
           Phosphate rock     21,600 Ib/hr @ 3.4 - 3.6% fluoride
           Soda ash            2,100 Ib/hr @ 0.1% fluoride
           Phosphoric acid     3,960 Ib/hr P 1.0 - 1.5% fluoride

        Because the capacity of the mixing equipment is greater than the  capacity
 of the  kilns, the mixing equipment is  usually operated on 8-hour shifts  at
 required intervals to maintain sufficient "acid rock"  feed material  for  the
 kilns.

        The acid rock from the mixer is dropped onto a  conveyor belt and  moved
 to the  storage building.  Normal  practice is to hold the  acid rock  in  the
 storage building 1 to 7 days prior to  charging it to the  kiln.   This holding
 time may vary, depending on product demand.

        Acid rock is moved from storage to the calcination equipment by a
 front  bucket loader.  The operator charges a load into the process  at  specified
 intervals in an attempt to maintain a  uniform feed.  The  feed material is
 "run of pile" in particle size and must be crushed prior  to entering the kilns.
 Feed rate varies according to the time Interval  between charges  and  the  weight
 of add rock in each load of the  loader.

        The acid rock is dropped onto a grizzly screen.  Large lumps  fall to the
 floor,  and lumps less  than  3 inches in diameter fall  to  the charge  hopper.
 From the charge hopper the acid rock is moved by a bucket elevator  to  a  crusher,
 which  reduces the particle size to 3/8 inch and  drops  the ground  rock  into a
 surge tank.   A vibrating feeder meters the material  to  a  belt conveyor,  which
 feeds the kilns.

        If feed to the  belt were continuous , the  kilns would be fed at  a  uniform
 and  continuous rate.  Frequent equipment failures  make  it necessary to estimate
 kiln feed rate from the frequency and  weight of  add rock charges added  to the
 process.   The feed is  at the cold end  of the kiln  opposite the burners.  Each
 kiln is about 150 feet long and 8 feet in diameter.  Natural  gas  is used as
 fuel.   The retention time of the  material  in the kiln  is  around 6 hours.
 Temperatures in the kiln range from about 1800F at  the hot end to about 650F
 at the  charging end.

        As the defluorinated rock  leaves the hot  end  of  the  kiln,  it is cooled by
 a  water spray.   The spray  also supplies the moisture in the  kiln essential  to
10

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fluoride removal.  The cooled product 1s screened to separate large pieces,
crushed as required to meet specifications, and discharged Into a hopper for
storage.  The product may be bagged for sale or may be sold 1n bulk.  The
product is about 16 mesh in size and contains less than 0.18 percent fluorine.
The product trade name is "Feed Phos."

       The exhaust gases leave the charge end of the kiln and pass through
a water scrubber and a blower, and into a common stack.  Separate water
scrubbers and blowers are provided for each of the two kilns.  The exhaust
gas rate for each kiln is between 14,000 and 17,000 scfm.  The gases, leaving
the kiln at about 650F, contain water vapor, gaseous fluorides, particulate,
and combustion products.

       The water for the two scrubbers is supplied from a pond located about
200 yards south of the scrubbers.  The water flows from the pond to the base of
the scrubbers and returns to the pond in open ditches.  Adjacent to the
scrubbers, a sump pump forces water 1n an 8-inch line to an overhead water tank.
This tank is kept full at all times, and the overflow from the tank 1s divided
into the two scrubbers.  Water rate to the scrubbers Is reported to be from
1,000 to 1,500 gallons per minute.  The pond is about 80 feet wide, 150 feet
long, and 4 feet deep.

AIR POLLUTANT EMISSIONS
       Air pollutant emissions from the Rocky Mountain Phosphates, Inc., rock
defluoH nation plant are of two types, parti cul ates and gaseous.  Parti cul ate
emissions from the crushing, bagging, and handling of both the feed and product
result in a fine gray dust, which covers buildings, cars, yards, and other
exposed surfaces in the vicinity.  These emissions for the most part, consist
of relatively large particles, which normally settle near the plant property.
Particulate released from handling the feed material contains 3.5 to 5 percent
fluorine; particulate from product handling contains no more than the 0.18
percent fluorine permissible in the finished product.

       Gaseous pollutants escape from the plant processing equipment and the
stack.   The reactions involved in the defluorination of phosphate rock and the
chemical analysis of the rock itself are quite complex.  Typical of the reactions
thought to occur in defluorination is the following:
          (CaF) Ca4 (P04)3 + 7 H3P04 + 5 H20 *- 5 CaH4 (P04)2'H20 + HF.
                                                                                  11

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        Silicon tetrafluoride may also be formed at elevated temperature  by  a
 number of reactions.   It is probable that both hydrogen fluoride and  silicon
 tetrafluoride are formed.

        The gaseous phase reaction of water vapor with silicon  tetrafluoride
 under high-temperature conditions  has been studied by Lenfesty et al?,
 who found that the equilibrium favored the formation  of hydrogen fluoride at
 high temperature.  The following reaction is  involved:
        SiF4 (g) + 2 H20  (g)Z^:Si02 (s) + 4 HF (g)

        Semrau4 reports that no significant amounts of silicon  tetrafluoride
 should exist as such  in  moist, high-temperature furnace gases,  the  conditions
 which exist at the Rocky Mountain Phosphates, Inc., plant.

        Plant inspections have revealed that fluoride  emissions  come from three
 locations and appear  to  be  about equally divided among  these locations.  The
 normal point of discharge is the top of the stack, where the fluoride content
 of the effluent depends  upon the efficiency of the scrubbing equipment.  A
 second emission comes from  the many leaks in  and around the bottom  of the stack
 and in the piping. These emissions are practically at  ground  level.  Fluoride
 content here also depends upon the efficiency of the  scrubbing  system.  A third
 emission source, perhaps the most significant, is leakage at the end of the
 kiln where the gases  are collected for transport to the scrubbing system.   This
 emission, which can be detected visually during nighttime observations, contains
 completely unscrubbed gases having high concentrations  of fluoride.  This
 emission is also practically at ground level.

 DESIGN, OPERATION, AND MAINTENANCE DEFICIENCIES
        Deficiencies in design and in operation and maintenance  practices at
 the Rocky Mountain Phosphates, Inc., plant have contributed greatly to the
 emission of fluerides.  This condition began  when the plant originally started
 operating without air pollution control equipment and has generally continued to
 the present time.  Evidence of these poor practices have been  described in
 previous reports.1'2'5  Some examples of poor practices used in the past are the
 following:
        1.  By-passing of gas in water spray towers due  to improper  liquid
 seals in the tower.  This results in inefficient scrubbing.
        2.  Operating  the plant without addition of lime to  the  scrubbing
 medium.  In a recirculating water scrubbing system the  fluoride content of  the
12

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scrubbing solution continually Increases.  Unless lime 1s added to remove the
fluoride from the scrubbing water, the efficiency of the scrubber 1s reduced.
Rocky Mountain Phosphates, Inc., frequently has operated the plant without
addition of lime.  During a plant Inspection on April  12, 1967 no lime was
available for addition to the scrubber, but both kilns were being operated.
       3.  Poor fabrication of piping, which results in direct discharge of
pollutants to the atmosphere.  A specific example is the copious leakage of
fluoride gases at the charge end of the kiln.  Some attempt was being made in
the Spring of 1967 to correct this situation, but the  plant has continued to
operate many months with this condition existing.  Another example is the poor
construction of the gas inlet of the south scrubber.  An opening about 4 by
12 inches in this line, adjacent to the scrubber, was  noted during the inspection
of the plant on April 12, 1967.
       4.  Poor water distribution in the scrubbers.  During the plant
Inspections of August 1964, one-third of the spray nozzles were completely
plugged.  The reduced scrubbing capacity results in decreased fluoride collection
efficiency.  In the Inspection of April 1967 no method  of water distribution
was provided in the scrubbers.
       5.  Corrosion of piping which results in leakage of gas and scrubbing
water, indicates generally poor maintenance.  Toxic gas is discharged through
these holes at ground level, where there 1s little chance for atmospheric
dispersion.  In addition, holes 1n gas piping reduce the draft on the equipment
and affect the collection of toxic gases from the kiln.
       6.  Lack of spare or standby equipment to Insure continuous operation of
air pollution control equipment.  The south scrubber,  purchased from a commercial
company, originally consisted of several beds  of plastic spheres supported  on a
grid similar to that depicted in Figure 5.  Spray nozzles distributed the
scrubbing liquid uniformly over the packed section.  Several beds of spheres
were provided.  The gas to be cleaned entered the scrubber near the bottom and
traveled upward through the sphere bed while the scrubbing liquid cascaded down
from the spray heads at the top.  Under the influence  of this counter-current
gas and liquid flow, the spheres are forced into violent, random motion, and
Impinge against each other.

       The unit functions 1n this manner to provide contact surfaces for
absorbing gases and also serves as a gas cooler.  Several types of scrubbers
of this general design are available commercially.
                                                                                   13

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                                        GAS  OUTLET
                             ENTRAINMENT
                              SEPARATOR
                                 LI.QUOR
                                  INLET
                           LIQUOR SPR7
                                      GRID

                                    GRID
                                PLASTIC
                                SPHERES
                                     GRID
                                  GAS
                                 INLET
                               LIQUOR
                               OUTLET
                             Figure 5.   Fluoride scrubber.

        Equipment failures  at  the Garrison plant caused  loss of cooling water in
 the scrubber within  a  few  months after  it was  installed in 1966.  The gases
 from the kiln at a temperature of  about 650F  melted the corros1onresis^ant
 lining  and the plastic balls  in the scrubber.   Because  of the low pH of the
 circulating water, severe  corrosion soon resulted and the original scrubber was
 destroyed within 6 months.  In its place the Company has erected two "plant
 designed" scrubbers  of somewhat similar design.

        One of these,scrubbers  is 6 feet in diameter and the second is 8 feet
 in  diameter.   The south scrubber still  retains the top  portion of the commercial
 scrubber; however the  bottom  consists of several sections of concrete pipe.
 Wooden  supports  and  grids  support the plastic  balls and restrain them from
 passing out  with the exhaust gases.  The north scrubber has a steel shell, but
 its  internal  parts also are wooden.  To operate  a scrubber of this type
 properly  consideration must be given to both gas and liquid flow rates.  In an
 oversized scrubber,  gas and liquid flow rates  are too low for adequate turbulence
 and  efficiency of pollutant gas absorption is  reduced.  In an; undersizedscrubber,
 contact time  is  limited and inadequate  absorption results.

       *As  the  result of the scrubber pump failures the  wooden lining and support
 structure 1ft  the existing  scrubbers were charred by the hot gases.  Charred pieces
 of scrubber  Internal parts were found lying about the scrubber area.  No alternative
method  is  provided at  the  present to insure water flow  to the scrubber.

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       In order for the scrubber to function properly, the fluoride content of
the scrubbing water must be controlled by adding lime to the scrubber water
either at the pump or at the pond.  The desired result is that calcium fluoride
precipitates within the pond and thereby removes fluoride from the recirculating
water.  Approximately 2 pounds of lime is required for each pound of fluorine
absorbed.  When the plant was inspected in April 1967, no lime was being added
to the scrubber water.  In fact, there was no lime available on the plant site.
At the time of this inspection both kilns were operating.

       Good water distribution in the scrubbers is essential if high collection
efficiency is to be achieved.  In a commercial scrubber, water sprays are
provided to insure good distribution and to prevent channeling.  In the scrubber
designed by the plant the water is added in the top of the scrubber through an
8-inch pipe.  This pipe ends within 12 inches of the scrubber wall and merely
dumps the water on the upper grid.

       Scrubber water flows from the base of the tower to the pond and back
to the pump in open ditches.  No method of preventing freeze-up during cold
weather operation is provided.

       Both scrubbers are severely corroded.  The most recently installed
scrubber was leaking from at least ten holes in the shell within 6 months
of installation.
                                                                                 15

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                 III. FLUORIDE  EMISSION  CONTROL TECHNOLOGY
       The most effective method  for  removing fluoride from stack discharge is by
the use of liquid scrubbers.   Hundreds of scrubbers are operating for this purpose
throughout the country.   Efficiency of collection depends upon factors such as
design features, pressure drop, scrubbing medium, and temperature as well as on
proper maintenance and attention  to operation.

       Corrosion of metallic  surfaces and plugging of sprays and packing are ser-
ious operating problems that  must be  considered  in the design of equipment.  Some
method of removing the fluoride from  the scrubbing liquid must be provided if a
recirculating system is used. Removal of fluoride from discharge gases decreases
markedly when the concentration of hydrofluorosilic add in the recycle solution
exceeds 2 percent.

       Phosphate rock defluornation plants  similar to that of the Rocky Mountain
Phosphates, Inc., plant in Garrison are operating in several other locations in
the United States.  Most of these plants use water scrubbers as air pollution
control equipment.

       Defluorinated phosphate rock is manufactured in Florida in one of the
largest and best equipped plants  in the country.  This plant had an air pollution
problem in the past, but installation of a  three-stage water scrubber has eliminated
the problems.  Effluent gases from the kilns are cooled by water sprays, scrubbed
in two packed spray scrubbers in  series for removal of most of the fluoride, and
then passed through a milk-of-lime scrubber for  removal of the remaining traces of
fluoride.  Milk-of-lime solution  is prepared in  separate mixing equipment, and
only the overflow solution is added to the  milk-of-lime scrubber.  Overall effi-
ciency of fluoride removal for this plant is reported by the Florida Board of
                                     Q
Health to be greater than 99  percent.  This Florida plant has almost ten times
the pollution potential  of the Rocky  Mountain Phosphates, Inc., plant.

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           IV.  TOPOGRAPHY AND CLIMATOLOGY OF GARRISON  AREA
TOPOGRAPHY
       Garrison, Montana,  is  located at the fork of a Y-shaped mountain valley
system containing the Clark Fork River and the Little Blackfoot River.   The town
is at the north end of the Deer Lodge Valley, which is approximately 35 miles
long and 8 to 10 miles wide,  and which extends straight north and south.  In the
vicinity of Garrison the Clark Fork River, which flows from the south,  turns to
flow generally west-northwestward  so that its valley forms the stem and left arm
of the Y.  The Clark Fork River valley narrows and is curving in parts  just west
of Garrison, but the valley straightens and widens further westward. At
Drummond, Montana, which is 20 miles west-northwest of Garrison, the valley
becomes 15 miles wide; but just west of there, it becomes very narrow and continues
so through high mountains  for many miles.

       The Little Blackfoot River  begins near the Continental Divide, 25 miles east
of Garrison, and flows generally in an east-to-west direction.  Its valley, which
forms the right arm of the Y, is relatively narrow where it cuts through the
Garnet Range, about 10 miles  east  of Garrison.  In effect, Garrison, at 4,400  feet
mean sea level and surrounded by mountains 7,000 to 9,000 feet high, is in a
closed-off irregularly shaped, bowl-like valley system.

TEMPERATURE
       Air temperature is  important with respect to the air pollution problem  in
Garrison, Montana, primarily  because of its effect on the growing season.  In  the
Deer Lodge Valley, frosts  and freezes do not have quite the same effects as in the
warmer parts of Montana, largely because growers concentrate on crops not suscep-
tible to damage at temperatures as low as 25 F.  Crops grown in the area include
hay and grasses.

       Based on 25 years of data,  1921-1950 (some data incomplete), the average
last date in spring for a  temperature of 24 F is May 3, and the average first
date in fall for this temperature  is September 30; consequently, there are 151
days in an average year between 24 F freezes.
                                        19

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PRECIPITATION
       Official precipitation records are not available for Garrison, Montana,
but 30 years of data are available for Deer Lodge, about 10 miles to the south.
Other locations in the general area for which precipitation data are available  are
Drummond, 19 miles west-northwest and Elliston, 18 miles east.  The mean annual
precipitation for Deer Lodge is 11 inches; Drummond, 11 inches; and Elliston, 16
inches.  The mean annual precipitation for Garrison, Montana, is estimated to be
about 12 inches.

       Figure 6 shows monthly means, mean number of days with precipitation of  0.10
inch or more, and monthly means of inches of snow and sleet on the ground for Deer
Lodge.  The pattern of distribution of precipitation throughout the year is similar
to those for Drummond, Elliston, and the Garrison area.  In Deer Lodge,  7.56 inches,
or 71 percent, of the precipitation falls during the growing season (April-September)
Normal years, therefore, have enough rainfall for many types of dryland  farming
and ranching.  The winter is relatively dry, with February, the month with the
least precipitation having only one-sixth that of June, the wettest month.   Snow-
fall in the surrounding mountains provides enough water for irrigation during most
of the summer in many years.

ATMOSPHERIC STABILITY
       If in the atmosphere the temperature decrease with elevation is greater  than
5.4  F per 1,000 feet, conditions are described as "unstable" and air pollution  is
readily dispersed.  Such a condition generally occurs on sunny days when the ground
becomes heated and warms the air above.   Wind speeds are low and wind directions,
variable on such days.

       If the temperature decrease is close to 5.4 F per 1,000 feet, the atmospheric
stability is "neutral."  When atmospheric conditions are neutral, dispersion poten-
tial is relatively good.  The meteorological conditions associated with  neutral
stability are cloudy skies and strong enough winds to cause thorough mixing.  Wind
directions are more or less steady.

       If the temperature decrease with elevation is less than 5.4 F per 1,000
feet, conditions are "stable."  As the rate decreases, the dispersion rate for  air
pollutants also decreases.  If the temperature of the atmosphere increases with
elevation, dispersion of air pollutants is poor.

       The condition in which temperature increases with elevation is called a
"temperature inversion."  The base of a layer of temperature inversion may be
located either at the surface or aloft.  Over land, surface-based temperature in-
20

-------
o "
c
K
z
o
 2
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LU
\ 1
LU
1 n
ANNUAL MEAN =
2.

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0.72
0-47 0.38 ',54 \
\ \ \\
65



26 10.64 INCHES
*30 YEARS OF DATA ~

1.16


0.85 0.92 -
0.60 0.59 0_5Q
                                     M   J     J     A
                                         MONTH
N    D
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i
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~~ 22
"Till
"iill





	 ANNUAL HtAN = 	
7 34 DAYS 

*30 YEARS OF DATA 
4




1
3 3
11222
1 1 1 1 =
                 JFMAMJJASOND
                                          MONTH
.a 2
E"1 3
zo 1
^ n



	


o   	
4.8 4










9 **22 YEARS OF DATA 5
3.7




3 
^_,
	


"~
                                          MONTH
        Figure  6.   Summary of precipitation records for Deer Lodge, Montana.

versions occur at night under clear or partly cloudy  skies with calm or  light winds.
When the ground cools by radiation, the layer of  air  above it  also  cools  progres-
sively.

       Mountain valleys, such as the one in which Garrison is  located, are  partic-
ularly subject to intense and long-lasting inversion  conditions for several  reasons.
The air in these valleys is  usually an insignificant  barrier to outgoing  heat for
several reasons:  it is less dense than air at lower  altitudes and  is generally  dry,
                                                                                  21

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winter nights are relatively long, surrounding mountains are a barrier to strong
winds, and snow cover during the colder months reflects away solar energy and is
an excellent radiator of heat at night.  Furthermore, cool air in time drains to
lower elevations because of its greater density and thereby causes deeper and more
intense inversions in a valley than would occur on level ground.
                                  g
       A U.S. Weather Bureau study  reports the following inversion frequencies for
the general region of the United States in which Garrison is located:

                                Inversion frequency
Season
Winter
Spring
Summer
Fall
Annual
Percent of
total hours
45-55
30
30-35
40-50
40
        Protected mountain  valleys  such as the Deer Lodge Valley have even higher
 percentages  of inversions.   In  fact,  the study  indicates that the total of the
 fall  and  winter frequencies  of  inversions for this and some of the other valleys
 of western Montana  1s  higher than  for any other location in the contiguous United
 States.

        The behavior of a plume  from a stack during stable, neutral, and unstable
 conditions is  shown 1n Figure 7.   The unstable  plume  is described as "looping,"
 the neutral  plume as "coning,"  and the stable plume as "fanning."  The cross sec-
 tions of  the looping and coning plumes are somewhat circular, whereas the fanning
 plume 1s  greatly flattened because of restricted vertical motion.  Both the un-
 stable  and stable plumes, when  viewed from above, generally show evidence of
 meandering motion because of wind  direction changes.

       A  plume from a  source at the surface behaves similarly to that from a stack.
 One difference, however, is  that the  maximum ground concentrations for pollutants
 emitted from a stack occur some distance away from the stack, whereas with a ground
 level source the maximum concentration is at the source and the concentration
 decreases with increasing distance.

       As would be  expected,  plume behavior is  greatly affected by topography, and
 it  follows that ground  concentrations of air pollution are also affected.  Air is
 channelled by  a valley, especially during stable conditions; and a plume of air
 pollution is confined  by a valley, or will follow valley walls.   Effluent from the
22

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    1000
\_-   UNSTABLE
    ATMOSPHERE
                                              LOOPING PLUME
     1000
     NEUTRAL
    ATMOSPHERE
                                                 CONING  PLUME
     1000
             STABLE
           ATMOSPHERE
                                                FANNING PLUME
         TEMPERATURE

        Figure 7.   Temperature  lapse  and  plume  behavior  in  unstable, neutral, and
                   stable  atmospheric conditions.

Rocky Mountain Phosphates, Inc., stack moves up and down the Clark Fork River
Valley or up the valley of the Little Blackfoot River, following the turns in the
valley.  It also spreads out over the ridges that project into the valleys.   It
follows errosion channels  up and down ridge slopes and tops the ridges at low
points.  Consequently, exposed locations  on slopes facing the source receive
relatively high concentrations, as do draws on  both sides of the slope where air
is channelled.  Because of the "valley effect"  high ground concentrations can occur
at a greater distance downwind from the source  than would occur in flat terrain.
                                                                                  23

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WIND SPEED
       The Montana State Board of Health operated a wind recording system on the
roof of the County Courthouse in Deer Lodge from November 1965 through June 1966.
Calm or very light winds, with wind speeds ranging from 0 to 7 miles per hour,
were observed 70 percent or more of the time in all months except December (65
percent) and June (58 percent).  In February, the month with most light winds,
speeds of 0 to 7 miles per hour were observed 91 percent of the time.

       A Public Health Service wind recording system installed on the north edge
of Lahman's trailer court began to record data in mid-May of 1967.   The light-
weight design of the wind vane and anemometer cups makes it possible to record wind
conditions when speeds are as low as 1 mile per hour.  The wind sensors are located
on top of a telephone pole, approximately 20 feet above the ground.

       Without a longer period of observational records from Garrison, monthly
wind conditions throughout the year and annual average conditions must be estimated
from observations made at the Drummond airport, 20 miles west-northwest down the
Clark Fork River Valley.  At the present time wind observations are made at Drummond
only during the hours of 0500 to 1700, but summarized data are available for 24
hours daily for the years 1951-1954.  Although the topography at Garrison and the
Drummond airport are different, a comparison of the limited amount of Garrison data
with Drummond observations shows that wind conditions are similar.   The average
wind speed at Drummond for the month of June 1967 during the hours  of the day the
station operates was 4.4 miles per hour.  The average wind speed for the same hours
at Garrison was 4.6 miles per hour, an insignificant difference.

       As is shown by the graph of average monthly wind speeds for  Drummond,  Figure
8, there is a seasonal variation of wind speed in the Garrison area.   At Drummond
October, November, and December have the lowest wind speeds.   The average monthly
speed for these months is about 6 miles per hour.  Highest monthly  averages occur
from January through July, when wind speeds average about 8 miles per hour.

       The greatest number of periods of calm occur in Drummond during the late
fall and early winter.  A calm is reported in  about  12  percent  of all  observations
during the months of November and December.  Fewest calms occur during the warmer
months of the year, April through September, when calms occur only  5 to 6 percent
of the time (Figure 9).  Annually, wind speeds in the range of 0  to 7 miles per  hour
occurred 52 percent of the time.

       The limited amount of wind speed data available for Garrison,  Montana,
indicates that average wind speeds are relatively very low, as would  be expected

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   10
Q.
                                                        1     T
          j	I
                    I      I      l
      6



      5
      JAN   FEB   MAR  APR   MAY   JUN   JUL  AUG   SEP  OCT   NOV   DEC

                                    MONTH


Figure 8.  Average monthly wind speeds in Drummond,  Montana  -  U.  S.  Weather
           Bureau data from 1951  through 1954.
        13


        12


        11


        10
     c
     HI
     o
     1_
     (U
     o.
1     I
                    I
                I     I    I
         3
         JAN  FEB  MAR  APR  MAY  JUN  JUL  AUG  SEP  OCT NOV  DEC

                                   MONTH


      Figure 9   Percent of calms each month during  1951  through
                 1954 in Drummond, Montana  - U.  S. Weather  Bureau
                 data.
                                                                            25

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from its sheltered location.  The average speed for the month of June 1967 was
only 3.8 miles per hour.

       For comparison, the average June wind speed for Washington, D. C.,is 9
miles per hour; Los Angeles, California, 8 miles per hour; and St. Louis, Missouri,
8 miles per hour.
       In Garrison during June, the highest hourly average speed of 7 mph occurred
at 3 p.m., whereas the wind speeds during the hours 10 p.m. to 6 a.m. average 2
miles per hour or less (Figure 10).  Examination of the wind record showed that
true periods of calm when no air movement was detected are rare in Garrison.   Wind
speeds of at least 1 or 2 mph occur most of the time.   During the hours of darkness,
when calms are most likely to occur, cold drainage off the slopes causes some move-
ment of air.
    CL
    E
                                         Average speed for
                                          period 3.8 mph
            MID    02    Ok    06  .   08    10     12    lit    16   18   20    22   MID
                                       HOURS OF DAY

     Figure 10.  Average hourly wind speed for June 1967 in Garrison, Montana.
       Wind speed is very significant in air pollution considerations.  With
respect to a continuous point source, such as emissions from a stack, ground level
concentrations are inversely proportional to wind speed, i.e., low wind speeds
produce high concentrations.  Also, in the Garrison valley area, where air pol-
lution can be confined by surrounding hill and mountain sides, low wind speeds are
associated with atmospheric processes that permit air pollution to accumulate in
the vicinity of a continuous source and remain in the general vicinity of it for
many hours.
 26

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WIND DIRECTION
       Topography greatly influences wind direction in the Garrison area.   It also
is a factor at Deer Lodge, where wind records were obtained by the Montana State
Board of Health in May 1966, and at Drummond, the nearest station making official
wind observations.  The limited data for Deer Lodge confirmed the north-south
channelling of air by the north-south orientation of the Clark Fork River  Valley
in the vicinity of this city.  Few westerly and hardly any easterly winds  were
observed.  The sheltering effect of the mountains is shown by the fact that 21
percent of the winds were classified as light and variable.

       Wind direction data for the Drummond, Montana, airport are available for
all hours of the day for the period July 1950 through December 1954; these data
have been summarized by the U.S. Weather Bureau.  At the present time, however,
meteorological observations, including hourly wind direction readings of an instru-
ment by a Federal Aviation Administration observer, are made daily only for the
hours 0500 through 1700.

       The annual wind rose for Drummond (Figure 11) gives the percent frequency
of occurrence of wind directions and speeds for each direction and the percentage
of calm.  The relative high frequency of winds from the west through northwest
shows the effect of the prevailing westerlies of this latitude.  Cold air  also
drains off the nearby hill sides from a westerly direction.  The higher frequency
of southwest and northeast winds are indicative of the effect of the Flint Creek
Valley and a pass through the Garnet Range in a general northeasterly direction
from Drummond.  Because of the manner in which large-scale meteorological  features
affect this region, a large percentage of easterly winds  would not be expected.
Further, airflow from east to west is inhibited by the high mountains west of
Drummond and the narrow, winding nature of the Clark Fork River Valley to  the west.

       Figure 12 shows wind roses for the 4 months of the year representative of
the four seasons.  There do not appear to be important seasonal differences in
direction, as is often the case at weather stations in other geographical  regions.

       Because wind data for June 1967 are available for Garrison, the wind roses
shown in Figure 13 were prepared for both Drummond and Garrison.  Only the hours
between 0500 and 1700, inclusive, were used.  These correspond to the part of the
day when the Drummond Station is operating.  Both of these wind roses show wind
frequencies  of 20 percent from a northwesterly direction, a pattern similar to that
seen in the  annual  wind rose for Drummond.   The Garrison wind rose shows a much
greater frequency of winds from the east (13%) than Drummond (1%).  Air draining
from the mountain slopes west of the Continental Divide and down the Little Black-
                                                                                   27

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                           0-3   4-7  8-12  13-18 19-24
                                                        <25
                                    MILES PER HOUR

                                       10          15          20

                                        I      I     I      I      I
                                    PERCENT


    Figure  11.   Drummond, Montana, annual wind rose based on data from July 1950
                through  December  1954  -  U. S. Weather Bureau record.
28

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              JANUARY
                                                               APRIL
0     5
I  .   I
                                          10     15
                                           I   i  I
                                                     20
                                       PERCENT

                           Value in center is percent calm.
16
               JULY
                                                               OCTOBER
Figure 12.   Wind roses for January,  April,  July,  and  October  from  1950 through
            1954 for Drummond,  Montana  -  U.  S.  Weather  Bureau data.
                                                                                  29

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                    20.0
            CALM
         13-18   >25

         CZM
0-3   8-12   I9_2it


    SPEED,mph
                                                      5     10     15     20

                                               I   I    I   I   I   I   I   I    I

                                                          PERCENT
             20.5
         Figure  13.   June 1967 wind roses for Garrison and Drummond,  Montana.
30

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foot River Valley produces an east wind at Garrison.   This air combines  with
drainage from the Deer Lodge Valley to produce as east southeasterly wind down the
valley of the Clark Fork River from Garrison.

       The Drummond wind rose shows 30 percent calm,  whereas  the Garrison rose
rose shows none.   The apparent high frequency  of calms at Drummond is caused by
the type of wind  equipment in operation there.  It is designed for routine aviation
purposes and is less responsive to both speed  and direction than the wind system
in use at Garrison.  A wind direction is not recorded unless  a speed other than
zero is also observed.  Also, the wind is observed only for 1  minute each hour,
when there may be no wind; whereas at Garrison the wind is recorded continuously
and any wind during the hour is considered in  the hourly average values  used for
constructing the  wind rose.  A large percent,  if not  all, of  the calms for Drummond
represent low average hourly wind speeds of perhaps 1 or 2 miles per hour; and the
frequency of occurrence of various wind directions is actually greater than shown
in the wind roses.

       An examination of the wind records at Garrison showed  that the wind vane
was in a large eddy with slow wind speeds for intervals during many of the nights
when drainage flow was being established.  At such times the  wind vane would turn
slowly around, through 360 degrees or more, with the  period of turning covering an
hour or two.  Eighty such periods occurred during June.  During some periods the
rotation was clockwise and during others it was counter-clockwise.  At the end of
the period of vane rotation, wind direction was often southeasterly.

       Wind direction is important in air pollution problems  because it  determines
the direction of transport of pollutants from the source.  Wind direction frequen-
cies indicate the percent of the time a particular receptor is downwind.  Calms,
light variable winds, or an eddy condition such as has been observed at  Garrison
can result in relatively high concentrations distributed nearby and around the
source, and relatively great exposures or dosages near it.
                                                                                   31

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               V.  DISTRIBUTION  OF  FLUORIDE  IN GARRISON  AREA
FLUORIDES IN GRASS

       Vegetation  absorbs  hydrogen fluoride when the gas is present in the ambient
atmosphere.   The accumulation of fluoride in vegetation can be determined by
chemical  analysis.

       Specimens of grass  from several locations in the Garrison area were
collected during 1963,  1965, 1966, and 1967 and analyzed for fluoride content by
the Montana  State  Board of Health.  Locations from which these specimens were
taken are identified as follows on the area map, Figure 14:

               Station                            Map location
               Garrison North                           2
               Garrison East                           27
               Garrison South                          39
               Garrison West                            7
               Garrison West Meadow                    50
               Jens                                   16
               Deer Lodge                              42

The concentrations  of fluoride in the specimens taken from these locations and
the dates upon  which the specimens were collected are listed in Table 1.  The
earliest  specimens  from the Garrison North and Garrison East stations were taken
on June 17,  1963,  before operation of the Rocky Mountain Phosphates, Inc., plant
began. The  results are consistent with fluoride content of such specimens from
locations where there is no substantial source of atmospheric fluoride.

       Data  for an interval of about 2 years following the beginning of operation
of the Rocky Mountain Phosphates, Inc., plant in Garrison are available for the
Garrison  North, Garrison East, and Garrison West stations (map locations 2, 27,
and 7).  The month-by-month concentrations of fluoride in grass specimens from
these locations exhibit a  consistent pattern.  Concentrations increase rapidly
during the late autumn  to  very high values during the late winter, decrease during
the spring,  and remain:  relatively lower than winter values during the summer.
                                         33

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                                                                    37
   (Sampling sites are shown by
    small-sized numbers.
                 N
                                    100
                                                             100 50
  Figure 14.   Sampling sites and fluoride concentrations  (ppm)  for grass
              specimens collected in Garrison area on April  15,  16,  and
              17. 1967.
This pattern 1s consistent with the growing season for grass and, in general, with
the seasonal fluctuations in production rate for the Rocky Mountain Phosphates,  Inc.,
plant.  During time of rapid grass growth the concentration of fluoride  is lower
than during periods when growth 1s static, even though fluoride exposure  continues.
Further reason for the observed pattern is the greater production rate for the
Rocky Mountain Phosphates, Inc., plant reported for the winter season than for the
summer.  Seasonal fluctuations of fluoride content in grass from the three
locations are depicted in Figure 15.

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              Table  1.  CONCENTRATION OF FLUORIDES IN GRASS SAMPLES
                        IN GARRISON, MONTANA, AREAa(ppm)
Garrison
Date of North
Collection Station
6/17/63
10/16/63
4/19/65
7/15/65
8/11/65
8/31/65
10/15/65
11/17/65
12/17/65
1/12/66
2/9/66
3/15/66
4/11-12/66
5/9/66
6/2/66
6/30/66
7/28/66
8/29/66
9/26/66
10/26/66
11/23/66
12/21/66
1/20/67
2/16/67
2/24/67
3/21/67
4/25/67
5/23/67
6/23/67
2
55
79
7
10
-
8
20
92
170
564
860
130
193
45
14
8
52
28
33
63
141
380
327
-
660
121
74
28
Garrison
East
Station
8
320
47
15
11
17
77
148
132
220
416
1450
750
340
434
159
154
412
246
355
1000
1750
-
-
2530
1750
1283
880
182
Garrison Garrison
South West
Station Station




2
10
53



767
870
175
273

30
75
235
151
78 95
231 26
484 362
695 380
450 230

97 598
531 393
176 68
10
Garrison
West
Meadow Jens Deer Lodge

















13
8
161 67 0
316 14 0
590 83
14
340 200 70

106 198 25
380 51 61
68 22 17
28 9 2
aSamples collected and analyzed by Montana State Board of Health.

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E
Q.
Q.
   2,500
   2,000
    1,500
     ,000
      500
               GARRISON  EAST  STATION
               (1-1/3 miles from  RMP)
                  
         JUNE     0     AMJJAS  ONDJFMAMJJ  A SONDJFMAMJJA
O


O
     ,000
      500
                     > f~\
               GARRISON  NORTH  STATION
               (1-1/3  miles  from RMP)
    1 ,000
      500
         JUNE     0      AMJJAS   ONDJFMAMJJASONDJFMAMJJA
                  ir*  ) i  iiir
              GARRISON WEST STATION
               (5 miles from RMP)
         JUNE     0
            1963
                         AMJJAS OND

                               1965
JFMAMJJASOND
          1966
JFMAMJJA

      1967
                  Fluoride concentrations  in grass specimens from Garrison area,
                  1965-1967.
 36

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       The concentrations of fluoride found in grass  specimens  from the Deer Lodge
and Jens stations (map locations 16 and 42) are generally lower than those  from
the other stations.   The Jens and Deer Lodge stations are located farther from
the Rocky Mountain Phosphates, Inc., plant than are the other stations.

       Some 50 grass specimens were collected in the  Garrison area April  15 to 17,
1967, by personnel of the Public Health Service and the Montana State Board of
Health.  Thirty-five of the Powell County specimens,  selected to give good
geographic distribution, were analyzed for fluoride content in  Public Health
Service laboratories.  Analytic methods and sample handling procedures used in the
Public Health Service laboratories for the vegetation specimens, and other  samples
examined for fluoride, are referenced or described in Appendix  B.

       Locations and fluoride concentrations for the  April  specimens are  listed
in Table 2.  Results of the analyses and the topographic features of the  area
were used to estimate the locations of isopleths of fluoride concentration  in
grass for mid-April  1967 in the Garrison area.  The locations from which  grass
specimens were collected and the estimated Isopleths  of fluoride concentrations
are shown in Figure 14.

       Grass specimens from two of the locations listed in  Table 2 were washed
gently with water, and the washed grass and washings  were then  analyzed for
fluoride.  The technique, while not precise, yields information on the relative
amounts of fluoride materials readily removed from the surfaces of the specimens.
Results of these examinations are shown in Table 3.  Some 5 to  10 percent of the
fluoride was removed by gentle washing of these specimens.

FLUORIDES IN EVERGREEN FOLIAGE
        Specimens  of evergreen  foliage  were collected in  the  Garrison  area
April  15-17,  1967 and analyzed for fluoride content  in  laboratories  of the
Public Health  Service.   Two-inch  long  portions  from  the  tips of the  needles  were
analyzed.   The type of tree,  its  location, and  the concentration of  fluoride in its
foliage are listed  in Table  4.

FLUORIDES  IN WATER
        Water samples  were  collected in three  locations  in  the  Garrison area  in
January 1965 and  analyzed  for  fluoride content  by  the Montana  State  Board  of
Health.  Locations  from  which  these samples were obtained  and  results of the
analyses are shown  in Table  5.  Locations,identified by  letter,  are  shown  in
Figure 16.
                                                                                  37

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               Table 2.  FLUORIDE CONCENTRATIONS IN GRASS SPECIMENS
               COLLECTED APRIL 15-17, 1967, BY PUBLIC HEALTH SERVICE
Station
1
2
4
6
7
9
10
11
12
13
14
15
18
19
20
21
22
23
24
25
26
27
29
34
35
36
37
38
39
40
41
43
49
50
51
Location
1/2 mi north of RMPa
1-1/2 mi north of RMP
2 mi NW of RMP
4 mi WNW of RMP
4-1/2 mi NW of PMP
5 mi west of RMP
6 mi WNW of RMP
8 mi NE of RMP
8 mi NW of RMP
8 mi NW of RMP
7 mi NW of RMP
9 mi NW of RMP
5 mi ESE of RMP
7 mi SE of RMP
9 mi SE of RMP
4 mi SE of RMP
3 mi south of RMP
5 mi SSE of RMP
15 mi SSE of RMP
13 mi SSE of RMP
8 mi SE of RMP
1-1/2 mi east of RMP
3 mi ESE of RMP
2-1/2 mi ESE of PMP
7 mi ENE of RMP
11 mi ENE of RMP
12 mi NE of RMP
11 mi WNW of RMP
2 mi SSE of RMP
3 mi SSW of RMP
7 mi SW of RMP
1-1/4 mi south of RMP
1500 ft SE of RMP
1 mi NW of RMP
1/2 mi ESE of RMP
Fluoride, ppm
8,400
200
1,600
250
800
50
700
60
80
70
80
55
70
260
70
290
80
180
165
300
300
1,500
240
430
240
40
25
60
970
95
50
710
11,000
2,400
12,600
 aRocky  Mountain  Phosphates,  Inc.
38

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                  Table 3.  FLUORIDE CONTENT OF WASHED GRASS
                        SPECIMENS AND OF WATER WASHINGS
Station
49
51
Parts Per Million Fluoride
Unwashed Grass Washed Grass
11,000 9,400
13,000 10,000

Washings8
940
820
 aAs  ppm of  grass sample.
Table 4. FLUORIDE CONTENT OF EVERGREEN FOLIAGE
COLLECTED IN APRIL 1967a
Type of evergreen
Fir
Juniper
Ponderosa Pine
Ponderosa Pine
Ponderosa Pine
Ponderosa Pine
Ponderosa Pine
Location
1 mi east of Garrison
5 mi WNW of Garrison (Clark Fork Valley)
8 mi WNW of Garrison (Clark Fork Valley)
8 mi WNW of Garrison (Clark Fork Valley)
25 mi east of Garrison (West Side of
MacDonald Pass)
25 mi NNW of Garrison (Helmville)
12 mi WNW of Garrison (Jens)
Fluoride, ppm
760
80
50
60
40
10
30
Specimens collected and analyzed by Public  Health Service personnel.
           Table 5.   FLUORIDE  CONTENT  OF WATER  SAMPLES COLLECTED ON
                JANUARY 8,  1965,  MONTANA STATE  BOARD OF HEALTH
           Location
Fluoride, ppm
           AA - Lahman's House
                12-foot dug well
           BB - Warm Springs Creek
                William Knope Ranch
           CC - Welsh's Truck Stop
      0.2

      1.4

      0.2
     Samples of surface waters  in the Garrison  area were  collected on April  15
and 16, 1967, and analyzed for  fluoride content in Public Health  Service
laboratories.  Locations from which these samples were  obtained and  results  of
the analyses are shown in Table 6.   Locations are shown in Figure 16.
                                                                               39

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               0   1    2
               I    I    I
AA, BB,  CC  :   COLLECTED IN JANUARY 1965.
A   H:   COLLECTED APRIL 15, and 16, 196?.
Figure 16.  Water sample collection  locations in Garrison area.
/Clark
, Fork
 River

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              Table 6.   FLUORIDE CONTENT OF WATER -  APRIL  15-16,  1967.
                           PUBLIC HEALTH SERVICE ANALYSIS
              Location	Fluoride,  ppm
              A - Clark Fork River south of Deer Lodge           0.8
              B - Rock Creek, Tavenner Ranch                     0.5
              C - Pond, Dutton Ranch                             0.6
              D - Carter Creek, 1  mi from Clark Fork              0.4
                  River
              E - Brock Creek, 1  mi from Clark Fork River        0.8
              F - Warm Springs Creek, Knope Ranch                1.0
              G - Pond, Mollenberg Ranch                         0.7
              H - Little Blackfoot River, Lahman's               0.5
                  Trailer Court
FLUORIDES IN SOIL
       Samples  of soil  were  collected  on  May  23,  1967,  and  analyzed  for fluoride
by the Montana  State Board of Health.   These  samples, with  locations of the
sampling stations the same as Identified  in Figure  14,  yielded  the following
results:

             Sampling Station      Map Location       Fluoride,  ppm
             Garrison East             27               230
             Garrison West               7               280
             Garrison South             39               300

       At the end of June 1967, topsoil and subsoil  samples were taken from  two of
these stations, and analyzed for fluoride content and for water-soluble fluoride
in laboratories of the Public Health Service.  Results  of these analyses  are given
in Table 7.
                        Table 7.  ANALYSIS OF SOIL SAMPLES FOR
                       WATER-SOLUBLE AND TOTAL FLUORIDE CONTENT

Sampling station
Garrison East
Garrison East
Garrison West
Garrison West

Sample type
Topsoil
Subsoil
Topsoi 1
Subsoil
Fluoride,
Water soluble
60
60
50
60
ppm
Total
160
160
140
180
                                                                                  41

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                                  APPENDICES

APPENDIX A.   CORRESPONDENCE AND RESOLUTIONS
       a.  Letter from Governor T. Babcock to Secretary J.  Gardner
       b.  Letter from Dr. J. S. Anderson to Secretary J.  Gardner
       c.  Resolution of Powell County Board of Commissioners
       d.  Resolution of Senate of Montana

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                         State of Montana
                      Office of The Governor
                              Helena
                                                   March 8,  1967
Mr. John Gardner
Secretary of Health, Education, and Welfare
Washington, D.C.

Dear Secretary Gardner:

            I am forwarding herewith a resolution of the Board
of County Coimrissioners of Powell  County,  Montana, together with
my concurrence to initiate an abatement proceeding by the National
Center for Air Pollution Control under Section 105 of the Clean Air
Act.

            This matter has been discussed with representatives
of the abatement, control division of the center, and I was at one
point advised that they might conceivably  be far enough along with
several interstate abatement proceedings then pending to give
attention to our problem sometime this month.

                                       Sincerely yours,
                                       Tim Babcock
                                       GOVERNOR
cc:  Mr. S. Smith Griswold
     Dept. of Health, Education, and Welfare
     Washington, D.C.

     Mr. Newman Raymond, Chairman
     Powell County Commissioners
     Deer Lodge, Montana

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                         State  of Montana
                       State  Board  of Health
                          Helena, Montana
                                                 AIR MAIL
                                                 March 21, 1967
Mr. John Gardner, Secretary
Health, Education, and Welfare
Washington, D.C.

Dear Secretary Gardner:

            I concur with the resolution of the Board  of County
Commissioners of Powell County, Montana, forwarded  to  you  by
Governor Tim Babcock on March 8, 1967,  in his  request  to you for
initiating abatement proceedings at Garrison,  Montana, under the
federal Clean Air Act.

            This department will cooperate with you to the fullest
extent possible.  It is my hope that action can be  initiated with
a minimum of delay.

                                       Sincerely yours,
                                       John S.  Anderson,  M.D.
                                       Executive Officer
JSA/acw
cc:  Mr. Griswold, National Center for Air Pollution Control
     Governor Tim Babcock, Capitol Building, Helena, Montana
     Mr. Newman Raymond, Chairman, Powell  County Commissioners
        Deer Lodge, Montana

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   RESOLUTION OF THE BOARD OF COMMISSIONERS OF POWELL COUNTY, STATE OF MONTANA,
REQUESTING THE SECRETARY OF HEALTH, EDUCATION AND WELFARE TO CALL A CONFERENCE
TO DEAL WITH THE PROBLEM OF AIR POLLUTION IN POWELL COUNTY.

          WHEREAS, residents of the Garrison area of Powell County, Montana,
have petitioned the Board of Commissioners for Powell County, to request the
United States Secretary of Health, Education and Welfare to call a conference
to deal with the problem of air pollution in Powell County, Montana; and
          WHEREAS, the Board of Commissioners of Powell County is strongly
desirous of initiating an effective program leading to the prevention and
control of air pollution in this county,
          NOW THEREFORE BE IT RESOLVED BY THE BOARD OF COMMISSIONERS OF
POWELL COUNTY, STATE OF MONTANA, that the United States Secretary of Health,
Education and Welfare is respectfully requested to call a conference, pursuant
to the provisions of Public Law 88-206 as amended by Public Law 89-272, to
deal with said pollution.  On condition that Powell County bear no part of any
expenses or costs Incurred.
                      Originally signed by:
                                            Newman  Raymond	

                                            Sandy 0. Reierson
                                            R.M. Bauman
                                         BOARD OF COMMISSIONERS FOR POWELL  COUNTY
          I concur in the above request.
                                         TIM M.  BABCOCK
                                         Governor  of  the  State of Montana

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                               SENATE
                       JOINT RESOLUTION NO. 1
                      INTRODUCED BY FLYNN, McKEON

 A RESOLUTION  OF  THE  SENATE OF MONTANA URGING THE GOVERNOR TO REQUEST
     THE SECRETARY  OF HEALTH, EDUCATION, AND WELFARE TO CALL A CONFERENCE
     ON AIR POLLUTION IN THE VICINITY OF GARRISON, MONTANA.

 1    WHEREAS, the  people, the animals, and the plant life 1n the
 2 vicinity of Garrison have suffered, are suffering, and will con-
 3 tlnue to suffer  from the demonstrated effects of air pollution
 4 which endangers  their health and welfare; and
 5    WHEREAS, the  federal Clean Air Act makes provision for the
 6 Secretary of Health, Education, and Welfare to call a conference
 7 if such air pollution exists whenever requested by the Governor of
 8 any State.
 9 NOW, THEREFORE,  BE IT RESOLVED BY THE SENATE OF THE STATE OF
10 MONTANA:
11    That the Governor 1s urged to request the Secretary of Health,
12 Education,  and Welfare  to call a conference, as provided 1n the
13 Clean A1r Act.
14    BE IT FURTHER RESOLVED, that the Secretary be requested to
15 direct such conference  to consider, among such other matters as
16 the Secretary  may  deem  appropriate, the occurrence of air pollution
17 in the vicinity  of Garrison, the adequacy of measures taken
18 toward abatement of the pollution, and  the  nature of the
19 delays, If any,  being encountered  in  abating the pollution.

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 APPENDIX B.  ANALYTICAL METHODOLOGY FOR FLUORIDE
        Various types of materials collected 1n the vicinity of Garrison,  Montana,
 were analyzed for fluoride content.  The sample treatment for each type was
 necessarily different; however, the measurement technique was the same for all
 samples except the water samples.  Water samples were analyzed for fluoride with
 an Orion fluoride selective electrode.   All other samples were analyzed by the
 Willard and Winter* distillation followed by the SPADNS** colorimetric procedure.

 Vegetation Specimens
        Vegetation samples were analyzed for total fluoride on a dry basis.  Some
 samples were analyzed for water-insoluble particulate fluoride deposited  on the
 surface, and these or other samples were analyzed for water-soluble fluoride in
 the deposited material.

 Total Fluoride - Vegetation is blended with calcium oxide and a small  amount of
 water.  The mixture is dried at 70 to 80 C, ignited at 600 C for 2  hours, and
 fused with sodium hydroxide at 600 C for 10 minutes.  This melt is dissolved in
 water and neutralized with perchloric acid.  The solution is then analyzed for
 fluoride by the combined Willard and Winter distillation and SPADNS colorimetric
 method.

 Water-Soluble and -Insoluble Particulate Fluoride in Vegetation Samples - Total
 fluoride content of vegetation samples can include fluorides Incorporated Into
 the vegetation and particulate fluorides deposited upon the vegetation.  To
 estimate the amount not contained within the vegetation, selected vegetation
 samples were washed gently with water.  These washings were collected  and
 separated according to water-soluble and water-insoluble portions.

        The insoluble portion was treated and analyzed in the same way as were
 the vegetation samples.  The soluble portion was distilled directly by the method
 of Willard and Winter and measured by the SPADNS method.

 Soil Samples
        Soil samples were analyzed for both total fluorides and for water-soluble
 fluorides.
 *H.H. Willard and O.B. Winter.  Volumetric method for determination of fluoride.
  Ind. Eng. Chem., Anal. Ed.  5:7-10.  1933.
**E. Bellack and P.J. Schoube. Rapid photometric determination of fluoride in
  water.   Anal. Chem. 30:  2032.  1958.

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Total Fluoride - The sample was dried at 75 c and passed through a 100-mesh sieve
to remove small stones and vegetation.  The dry sample was blended with calcium
oxide, ignited at 600 C for 2 hours, and fused with sodium hydroxide at 600 C for
10 minutes.  The melt was dissolved in water and neutralized with perchloric acid.
This solution was analyzed by the SPADNS method after perchloric acid distillation.

Water-Soluble Fluoride - The dried sample of soil was blended with water and
filtered.  The filtrate was analyzed by the SPADNS method after distillation from
perchloric acid.

Water Samples
       The fluoride content of water was measured instrumentally by means of an
Orion fluoride selective electrode.

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                                     REFERENCES
 1.   Adams,  D.F.,  An air quality survey. Garrison, Montana, July 5 - November 13,
     1965.   January 1966.

 2.   Goodwin,  D.R., Report on air pollution emissions from Rocky Mountain Phosphates,
     Inc., Garrison, Montana, August 18-22, 1964.  Taft Sanitary Engineering Center,
     Cincinnati, Ohio.  October 1964.

 3.   Lenfesty,  F.A., T.D. Farr, and T.C. Brosheer.  Industrial and Enqineerinq
     Chemistry, 44: 1448-50.  1952.

 4.   Semrau,  K.T., Emission of fluorides from industrial processes - a review
     JAPCA.   7:92-108.  August 1957.

 5.   Scuter,  R.C.  and M.A. Hannah.  Industrial Development Center Report on Rocky
     Mountain  Phosphates Plant operation in connection with the cases of David
     Dulton  et  al. and Edward and Isabelle Mollenberg vs. Rocky Mountain Phosphates.
     July 12,  1965.

 6.   Douglas,  H.R., W.A. Snider, and G.H. Tomlinson. An evaluation of mass and heat
     transfer  in the turbulent contact absorber.  Presented at 50th annual meetinq
     of  American Institute of Chemical Engineers.  Buffalo, New York.  May 8, 1963.

 7.   Specht,  R.C.  and R.R. Calaceto.  Gaseous fluoride emissions from stationary
     sources.   Chemical Engineering Progress.  63:78-84.  May 1967.

 8.   Huffstutler,  K.K.  and W.E. Starnes. Source and quantities of fluorides
     evolved  from  manufacture of fertilizer and related products.  Presented at Air
     Pollution  Control Association Annual Meetinq.  June 20-24, 1966.  San Francisco,
     California.

 9.   Hosier,  C.R.  Low-level inversion frequency in the contiguous United States.
     Monthly  Weather Review 89:319-39.  September 1961.

10.   A study  of air pollution in the Deer Lodge Valley, August 1965 - June 1966.
     Montana  State Department of Health, Division of Disease Control.  Helena,
     Montana.   29  pp.

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