United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park NC 27711
EPA-450/2-78-049a

 February 1979
Air
Primary Aluminum
Draft Guidelines for
Control  of Fluoride
Emissions from
Existing Primary
Aluminum Plants

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                            EPA-450/2-78-049a
     Primary Aluminum Draft
     Guidelines for Control of
Fluoride Emissions from Existing
     Primary Aluminum  Plants
           Emission Standards and Engineering Division
           U.S. ENVIRONMENTAL PROTECTION AGENCY
              Office of Air, Noise, and Radiation
           Office of Air Quality Planning and Standards
           Research Triangle Park, North Carolina 27711
                 FEBRUARY 1r'79

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This report has been reviewed by the Emission Standards and
Engineering Division of the Office of Air Quality Planning and
Standards, EPA, and approved for publication.  Mention of
trade names or commercial products is not intended to constitute
endorsement or recommendation for use.  Copies of this report
are available through the Library Services Office (MD-35) ,
U.S.  Environmental Protection Agency, Research Triangle Park,
N.C.  27711, or from National Technical Information Services,
5285 Port Royal Road, Springfield,  Virginia 22161.
            Publication No. EPA-450/2-78-049a

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                         TABLE OF CONTENTS

                                                               Page

1.   INTRODUCTION AND SUMMARY                                   1-1

    1.1   INTRODUCTION                                         1-1

    1.2  HEALTH AND WELFARE EFFECTS OF FLUORIDES               1-5

    1.3  FLUORIDES AND THEIR CONTROL                           1-6

         1.3.1  Fluorides                                      1-6

         1.3.2  Control of Fluorides:   New  Primary             1-7
                Aluminum Plants

         1.3.3  Control of Fluorides:   Existing                1-9
                Primary Aluminum Plants

    1.4  EMISSION GUIDELINES                                   1-13

         1.4.1  State Emission Guidelines                      1-13

         1..4.2  Performance of Recommended  Emission Controls   1-17

         1.4.3. Emission Testing                               1-19

    1.5  ASSESSMENTS                                           1-20

         T.5.1  Economic                                       1-20

         1.5.2  Environmental                                  1-24

         1.5.3  Energy                                         1-24

    1.6  COMPLIANCE TIMES                                      1-26

    1.7  REFERENCES FOR SECTION 1                              1-30

2.   HEALTH AND WELFARE EFFECTS OF FLUORIDES                    2-1

    2.1  INTRODUCTION                                          2-1

    2.2  EFFECT OF FLUORIDES ON HUMAN HEALTH                   2-2

         2.2.1  Atmospheric Fluorides                          2-2

         2.2.2  Ingested Fluorides                             2-4

    2.3  EFFECT OF FLUORIDES ON ANIMALS                        2-4

    2.4  EFFECT OF ATMOSPHERIC FLUORIDES ON VEGETATION         2-6

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                                                               Page


    2.5  THE EFFECT OF ATMOSPHERIC FLUORIDES ON
         BUILDING MATERIALS                                     2-7

         2.5.1  Etching of Glass                                2-7

         2.5.2  Effect of Fluorides on Structures               2-7

    2.6  RATIONALE                                              2-9

    2.7  REFERENCES FOR SECTION 2                               2-9

3.   U.S. PRIMARY ALUMINUM MANUFACTURING STATISTICS              3-1

    3.1  EXISTING PLANTS                                        3-1

         3.1.1  Introduction                                    3-1

         3.1.2  Location and Size                               3-2

    3.2  FUTURE TRENDS                                          3-8

         3.2.1  Domestic Industry and Plant Growth              3-8

         3.2.2  Plant Location and Cell type                    3-13

         3.2.3  New Producers and Technology                    3-13

    3.3  PRICE STATISTICS                                       3-16

    3.4  REFERENCES FOR SECTION 3                               3-17

4.   PROCESS DESCRIPTION                                         4-1

    4.1  PRIMARY ALUMINUM REDUCTION                             4-1

    4.2  PREBAKE PROCESS                                        4-10

         4.2.1  Anode Bake Plant                                4-10

         4.2.2  Reduction Cells                                 4-14

    4.3  SODERBERG CELLS                                        4-15

         4.3.1  Vertical  Stud Reduction Cells                    4-16

         4.3.2  Horizontal Stud Reduction Cells                 4-18

    4.4  REFERENCES FOR SECTION 4                               4-19

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                                                               Page

5.  FLUORIDE EMISSIONS                                         $-1

    5.1  POINTS OF EMISSION                                    5-1

    5.2  UNCONTROLLED EMISSIONS—SOURCE, CHARACTERISTICS,      5-9
         AND MINIMIZATION

         5.2.1  Reduction Cells (All  Types)                     5-9

         5.2.2  Anode Bake Plant                               5-20

    5.3  TYPICAL FLUORIDE EMISSIONS AND EXTENT OF CONTROL      5-22

         5.3.1  Reduction Cells (All  Types)                     5-22

         5.3.2  Anode Bake Plant                               5-26

    5.4  REFERENCES FOR SECTION 5                              5-28

6.  CONTROL TECHNIQUES FOR POTROOM AND ANODE BAKE PLANT
    FLUORIDES                                                  6-1

    6.1  POTROOM RETROFIT PRIMARY COLLECTION SYSTEMS           6-1

         6.1.1  Cell Hooding                                   6-2

         6.1.2  Calculation of Primary Collection Efficiency   6-11

         6.1.3  Primary Exhaust Rates                          6-19

         6.1.4  Ducting Layouts                                6-23

    6.2  POTROOM AND ANODE BAKE PLANT RETROFIT REMOVAL EQUIPMENT
         AND ITS PERFORMANCE                                   6-29

         6.2.1  Potroom Primary Dry Scrubbing                  6-29

         6.2.2  Potroom Primary and Anode Bake Plant
                Wet Scrubbing                                  6-34

         6.2.3  Potroom Secondary We't Scrubbing                6-39

         6.2.4  Summary of Best Retrofit Performance           6-47

    6.3  RETROFIT CASE DESCRIPTIONS                            6-50

         6.3.1  Plant A—HSS Cells—Primary Dry Scrubbing      6-52
                Retrofit

         6.3.2  Plant B—HSS Cells—Primary Wet ESP Retrofit   6-76

         6.3.3  Plant C—Prebake Cells—Primary Injected
                Alumina Dry Scrubbing Retrofit                  6-100


                                    i i i

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                                                                 Page

          6.3.4  Case Description Summary                        6-117

6.4  DESIGN, INSTALLATION AND STARTUP TIMES FOR RETROFIT         6-127
     CONTROLS

6.5  REFERENCES FOR SECTION 6                                    6-135

7.   COSTS OF ALTERNATIVE FLUORIDE EMISSION CONTROLS             7-1

     7.1  INTRODUCTION                                           7-1

     7.2  SELECTION OF ALTERNATIVE CONTROL LEVELS                7-2

     /.3  CAPITAL AND ANNUAL COSTS FOR FLUORIDE EMISSION         7-11
          CONTROL OPTIONS

          7.3.1  Procedure                                       7-11

          7.3.2  Capital Costs                                   7-11

          7.3.3  Annualized Cost                                 7-14

          7.3.4  Cost Effectiveness                              7-16

     7.4  REFERENCES FOR SECTION 7                               7-23

8.   RATIONALE OF STATE EMISSION GUIDELINES FOR EXISTING         8-1
     PRIMARY ALUMINUM PLANTS '

     8.1  INTRODUCTION                                           8-1

     8.2  FLUORIDE EMISSION CONTROL EQUIPMENT AND COSTS          8-3

     8.3  RECOMMENDED STATE GUIDELINES AND COLLECTION            8-6
          AND  REMOVAL EFFICIENCIES OF CONTROL EQUIPMENT
          FOR  FLUORIDE EMISSIONS

          8.3.1  State Fluoride Emission Guidelines              8-9

          8.3.2  Compliance Time                                 8-13

     8.4  EMISSION TESTING                                       8-14

9.  ENVIRONMENTAL ASSESSMENTS                                    9-1

    9.1  AIR                                                     9-3

         9.1.1  National Fluoride Emissions from Primary         9-3
                Aluminum Reduction Cells

         9.1.2  Fluoride Emission Control Systems with           9-6
                Extreme Air Pollution Impacts
                                  iv

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                                                              Page

     9.1.3  Fluoride Dispersion                               9-8

     9.1.4  Particulate Emissions from Aluminum  Reduction
            Cells                                             9-14

     9.1.5  National Particulate and Fluoride  Emissions
            from Anode Bake Plants                            9-14

9.2  WATER            '                                        9-17

     9.2.1  Effluent Limitations Guidelines for  Primary
            Aluminum Plants                                   9-18

     9.2.2  Water Pollution Control Technology Required to
            Meet 1983 Effluent Guidelines Standards           9-18

     9.2.3  National Effluent Emissions from Primary
            Aluminum Reduction Plants                         9-18

     9.2.4  Fluoride Air Emission Control Schemes with
            Extreme Water Pollution Impacts                   9-24

9.3  SOLID WASTE DISPOSAL                                     9-26

     9.3.1  National Solid Waste Generation Due  to Fluoride
            Control by the Primary Aluminum Industry          9-26

     9.3.2  Fluoride Emissions Control Systems with
            Extreme Solid Waste Impacts                       9-30

9.4  ENERGY                                                   9-32

     9.4.1  National Fluoride Emissions Control  Energy
            Requirements for the Primary Aluminum Industry    9-34

     9.4.2  Fluoride Emission Control Systems with Extreme
            Energy Impacts                                    9-37

9.5  OTHER ENVIRONMENTAL IMPACTS                              9-37

9.6  OTHER ENVIRONMENTAL CONCERNS                             9-39

     9.6.1  Irreversible and Irretrievable Commitment
            of Resources                                      9-39

     9.6.2  Environmental Assessment of Delayed  Standards     9-42

     9.6.3  Environmental Assessment of No Standards          9-42

9.7  REFERENCES FOR SECTION 9                                 9-45

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                           LIST OF TABLES
Table                                                                 Page
1-1    Potroom Total Fluoride Emissions in U.S., 1975                 1-8
1-2    Retrofit Emission Reductions and Costs for Ten                 1-10
       Primary Aluminum Plants
1-3    Retrofit Controls for Eight Primary Aluminum Plants            1-11
1-4    State Guidelines for Control of Fluoride Emissions             1-14
       From Existing Primary Aluminum Plants
1-5    Fluoride Emission Ranges Corresponding to State                T-^8
       Guidelines for Existing Primary Aluminum Plants
1-6    Primary Aluminum Control Strategies                            1-23
1-7    Environmental Impact of Best Control for Total Fluoride        1-25
       Emissions from the Primary Aluminum Industry
1-8    Increments of Progress for Installation of Fluoride            1-27
       Emission Controls in an Existing Primary Aluminum Plant
1-9    Total Construction Time for Retrofit Emission Controls         1-28
       for Primary Aluminum Plants
2-1    Examples of HF Concentrations (ppb) and Exposure               2-8
       Durations Reported to Cause Leaf Damage and Potential
       Reduction in Crop Values
3-1    U.S. Primary Aluminum Plants and Capacities, 1974              3-3
3-2    Distribution of Plants by Population, 1971                     3-8
3-3    Estimated Distribution of Plants by Environment                3-9
                                      VI

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Table
3-4     Production of Primary Aluminum in the United States    3-10
3-5     Growth in Primary Aluminum Plant Average Capacity      3-12
        in U.S.
3-6     U.S. Trends in Adoption of Cell  Types                  3-14
3-7     Primary Aluminum Ingot Price History                   3-17
5-1     Experimental Effect of Three Operating Variables       5-15
        on Fluoride Generation
5-2     Potroom Total Fluoride Emissions in U.S., 1975         5-24
5-3     Extent of Potroom Control, 1975                         5-25
5-4     Ring Furnace Fluoride Emissions  in U.S., 1970          5-27
6-1     Primary Collection Efficiency Versus Exposed Annular   6-10
        Area for Two VSS Plants
6-2     Calculation of Primary Collection Efficiency for       6-12
        One Swiss-Design SUPB Plant
6-3     Calculation of Primary Collection Efficiency for       6-14
        One French-Design SWPB Plant—Retrofit Case
        Description C
6-4     Calculation of Primary Collection Efficiency for       6-16
        Typical American-Design CWPB Plants
6-5     Calculation of Primary Collection Efficiency for One   6-17
        HSS PI ant--Retrofit Case Description A
6-6     Estimate of Primary Collection Efficiency for          6-20
        Typical VSS Plants
6-7     Primary Collection Efficiency Versus Standard Cubic    6-22
        Foot per Ton of Aluminum Produced for Seven Primary
        Aluminum Plants
6-8     Gas Volumes and Control Device Module Sizes for        6-27
        Economic Impact Analysis
6-9     Capital Cost Comparison Between Courtyard and Central  6-28
        Primary Collection Systems
                             VI1

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Table                                                         Page
6-10    Performance  of  Spray Screen Secondary Scrubbers at     6-44
        Six Existing Primary Aluminum Plants
6-11    Performance  of  Best Retrofit Emission Controls for     6-48
        Primary Aluminum  Potrooms
6-12    Summary of Anode  Bake Plant Best Retrofit Performance  6-49
6-13    Major Retrofit  Items—Plant A—Lines 1 and 2           6-57
6-14    Major Retrofit  Items—Plant A—Line 4                  6-65
6-15    Before Retrofit Emissions—Plant A—Lines 1, 2, and 4  6-67
6-16    After Retrofit  Emission Estimates—Plant A—Lines  1,   6-67
        2, and 4
6-17    Retrofit Capital  Cost Estimate—Plant A—Lines 1,  2,   6-71
        and 4
6-18    Retrofit Annual Operating Cost Estimate—Plant A—     6-74
        Lines 1,2,  and 4
6-19    Major Retrofit  I terns--Plant B—South Plant             6-80
6-20    Major Retrofit  Items—Plant B—North Plant             6-85
6-21    Before Retrofit Maximum Emissions—Plant B—North       6-87
        and South Plants
6-22    After Retrofit  Maximum Emission Estimates—Plant B--   6-87
        North and South Plants
6-23    After Retrofit  Average Emission Estimates—Plant B—   6-90
        North and South Plants
6-24    Retrofit Capital  Cost Estimate—Plant B                6-95
6-25    Revised Retrofit  Capital Cost Estimate—Plant B        6-97
6-26    Retrofit Annual Operating Cost Estimate—Plant B—     6-99
        North and South Plants
6-27    Major Retrofit  Items—Plant C--PDP Design              6-107
6-28    Major Retrofit  Items—Plant C—Alcan Design            6-109
                             vm

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Table                                                           Page
6-29    Retrofit Increments of Progress—Place C                6-111
6-30    Emissions Before and After Retrofit—Place C—
        Lines 1, 2, and 3                                       6-112
6-31    Retrofit Capital Cost—Plact C—Lines 1, 2, and 3       6-115
6-32    1974 Annual Cost—Plant C—Lines 1,  2, and 3            6-116
6-33    Potroom Retrofit Emission Reductions and Costs for
        Ten Primary Aluminum Plants                             6-118
6-34    Sequence of Major Activities in Design and Construction 6-128
        of Air Emission Control for an existing Primary
        Aluminum Plant
6-35    Delivery Times for Items Required to Construct
        Emission Controls for Primary Aluminum Plants            6-131
6-36    Total Construction Time for Retrofit Emission  Controls
        for Primary Aluminum Plants                             6-133
6-37    Increments of Progress for Installation of Fluoride
        Emission Controls in an Existing Primary Aluminum
        Plant                                                   6-134
7-1     Primary Aluminum Plant Capacity by Cell Type            7-3
7-2     Total Fluoride Emissions by Cell Type without
        lll(d) Regulations                                      7~4
7-3     Primary Aluminum Control Strategies                     7.5
7-4     Control Modules for Upgrading Existing Aluminum
        Plants.  Capital Costs                                  7-12
7-5     Waste Water Lime Treatment Investment Cost by  Size
        of Plant                                                7-15
7-6     Fixed Cost Components                                   ;-17
7-7     Control Modules for Upgrading Existing Aluminum Plants. 7-18
        Annualized Cost
7-8     Waste Water Treatment Plant Operating Cost              7-19
7-9     Primary Aluminum Control Strategies                     7-21

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Table                                                           Page

8-1     Control Equipment and Costs                             8-4

8-2     The Use of Capital Cost Modules                         8-3

8-3     State Guidelines for Control of Fluoride Emissions      8-7
        from Existing Primary Aluminum Plants

8-4     Fluoride Emission Ranges Corresponding to State         8-8
        Guidelines for Existing Primary Aluminum Plants

9-1     National Total Fluoride Emissions from Primary          9-4
        Aluminum Reduction Cells

9-2     Average Fluoride Emissions for Primary Aluminum
        Reduction Cells                                         9-5

9-3     Fluoride Emission Control Systems with Extreme
        Air Pollution Impacts                                   9-7

9-4     Fluoride Emissions at Plants A, B, and C                9-9

9-5     Maximum 30-day Average Ambient Fluoride Concentra-
        tions  in the Vicinity of Plants A, B, and C             9-13

9-6     National Particulate Emissions from Primary Aluminum
        Reduction Cells                                         9-15

9-7     Average Particulate Emissions for Primary Aluminum
        Reduction Cells                                         9-16

9-8     Anode  Bake Plant Air Pollutant Emissions                9-17

9-9     Effluent Limitations for Primary Aluminum Plants        9-19

9-10    National Effluent Emissions from Primary Aluminum
        Plants                                                  9-21

9-11    Average Effluent Emissions from Primary Aluminum
        Reduction Plants                                         9-22

9-12    Extent of Wet Controls at Alternative Levels of
        Fluoride Air Emissions Control                           9-23

9-13    Fluoride Air Emissions Control Schemes with Extreme
        Water  Pollution Impacts                                  9-25

9-14    Solid  Waste Generation for Various Fluoride Emissions
        Control Schemes                                          9-27

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Table                                                             Page

9-15    National Solid Waste Generation from Fluoride
        Control by the Parimary Aluminum Industry                 9-28

9-16    Average Solid Waste Generation Resulting from
        Fluoride Control for the Primary Aluminum Industry        9-29

9-17    Fluoride Emissions Control Systems with Extreme Solid
        Waste Impacts                                             9-31

9-18    Energy Requirements for Primary Aluminum Fluoride
        Emission Control System                                   9-33

9-19    National Fluoride Emissions Control Energy Requirements
        for the Primary Aluminum Industry                         9-35

9-20    Average Fluoride Emissions Control Energy Requirements
        for the Primary Aluminum Industry                         9-36

9-21    Fluoride Emissions Control Systems with Extreme
        Energy Impacts                                            9-38

9-22    National Criteria Pollutant Emissions Resulting from
        the Electric Power Generated to Control Primary
        Aluminum Fluoride Emissions                               9-40

9-23    National Bituminous Coal Requirements Implied by
        Primary Aluminum Fluoride Control                         9-41

9-24    Environmental Impact of No Fluoride Emission
        Guidelines for the Primary Aluminum Industry              9-44
                                 XI

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                      LIST OF FIGURES
Figure                                                        Page
4-1     Aluminum Reduction Process                             4-2
4-2    Aluminum Reduction Cell Diagram                        4-3
4-3    Typical Plan View of a Potroom                         4-6
4-4    Typical Elevation View of a Potroom                    4-6
4-5    General Flow Diagram for Primary Aluminum Reduction    4-8
4-6    Flow Diagram for Preparation of Prebake Anodes         4-9
4-7    Details of Prebake Reduction Cell                      4-15
4-8    Details of Vertical Stud Soderberg Reduction Cell      4-17
4-9    Details of Horizontal Stud Soderberg Reduction Cell    4-19
5-1    Prebake Plant with Anode Ring Furnace                  5-2
5-2    Potroom Fluoride Emission Balance                      5-3
5-3    Room Collection System, Sidewall Entry                 5-6
5-4    Room Collection System, Basement Entry                 5-6
5-5    Specific Prebake Potroom Fluoride Balance              5-7
5-6    Particle Size Weight Distribution of Potline           5-10
       Primary Cell Emissions
5-7    Particle Size Weight Distribution of HSS Primary       5-12
       Cell Emissions
6-1    Typical Prebake Cell Hooding                           6-3
6-2    Typical Horizontal Stud Soderberg Cell Hooding         6-7
6-3    Typical Vertical Stud Soderberg Cell Hooding           6-9
6-4    Primary Collection Systems:  Typical Ducting           fi_?4
       Layouts for a Single Prebake Potline with 160
       Cells, 2 Rooms
6-5    Primary Collection Systems:  Typical Ducting           fi  25
       Layout for a Single VSS Potline with 160
       Cells, 2 Rooms
                             xii

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Figure
6-6      Primary Collection  Systems:  Typical  Ducting Layouts       6-26
         for a Single HSS Potline with  160  Cells, 2 Rooms
6-7      Flow Diagram for Fluidized Bed Dry Scrubbing               6-31
         Process
6-8      Flow Diagram for Injected Alumina  Dry Scrubbing            6-33
         Process
6-9      Unpowered Roof Spray Screen                                6-40
6-10     Powered Potroom Spray Screen Scrubber                     6-41
6-11     Powered Spray Screen Scrubber                              6-42
6-12     Powered Monitor Spray Screen Scrubber                     6-43
6-13     Retrofit Layout—Plant A—Lines  1  and 2                    6-56
6-14     Retrofit Layout—Plant A—Line 4                          6-62
6-15     Retrofit Layout—Plant B—South  Plant                     6-79
6-16     Retrofit Layout—Plant B—North  Plant                     6-83
6-17     Retrofit Layout—Plant B—Cryolite Recovery Plant          6-91
6-18     Flow Diagram—Plant C—Injected  Alumina  Process            6-104
6-19     Retrofit Schematic—Plant C—POP Design                    6-106
6-20     Retrofit Schematic—Plant C—A!can Design                  6-108
6-21     Diagrammatic Representation  of Activity  Schedules          6-130
         on a Major Process  Industry  Construction Project
7-1      Investment and Annualized Costs  for Waste Water            7-20
         Treatment Plants vs. Aluminum  Plant Capacity
                                  xm

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                  1.   INTRODUCTION AND SUMMARY

1.1  INTRODUCTION
     Section lll(d)  of the Clean Air Act, 42 U.S.C. 7411(d), as
amended, requires EPA to establish procedures under which States submit
plans to control certain existing sources of certain pollutants.  On
November 17, 1975 (40 FR 53340), EPA implemented section lll(d) by
promulgating Subpart B of 40 CFR Part 60, establishing procedures and
requirements for adoption and submittal  of State plans for control of
"designated pollutants" from "designated facilities."  Designated
pollutants are pollutants which are not included on a list published
under section 108(a)  of the Act (National Ambient Air Quality Standards)
or section 112(b)(l)(A) (Hazardous Air Pollutants), but for which
standards of performance for new sources have been established under
section lll(b).  A designated facility is an existing facility which
emits a designated pollutant and which would be subject to a standard
of performance for that pollutant if the existing facility were new.
     Standards of performance for three categories of new sources in
the primary aluminum industry were promulgated in the FEDERAL REGISTER
(40 FR 3826) on January 26, 1976, to be incorporated into the Code of
Federal Regulations under 40 CFR Part 60.  New subpart S was added to
set standards of performance for fluoride emissions from new and
modified affected facilities within primary aluminum reduction plants.
The States, therefore, are required to adopt fluoride emission
standards for existing primary aluminum plants which would be subject
to the standard of performance if they were new.

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     Subpart B of 40 CFR Part 60 provides that EPA will publish a
guideline document for development of State emission standards after
promulgation of any standard of performance for a designated pollutant.
The document will specify emission guidelines and times for compliance
and will include other pertinent information, such as discussion of
the pollutant's effects on public health and welfare and a description
of control techniques and their effectiveness and costs.  The emission
guidelines will reflect the degrees of emission reduction attainable with
the best adequately demonstrated systems of emission reduction, considering
costs as applied to existing facilities.
     After publication of a final guideline document for the pollutant in
question, the states will have nine months to develop and submit plans
for control of that pollutant from designated facilities.   Within four
months after the date of submission of plans, the Administrator will
approve or disapprove each plan (or portions thereof).   If a State
plan (or portion therefor) is disapproved, the Administrator will
promulgate a plan (or portion thereof) within six months after the
date for plan submission.  These and related provisions of subpart B
are basically patterned after section 110 of the Act and 40 CFR Part 51
(concerning adoption and submittal of state implementation plans under
section 110).
     As discussed in the preamble to subpart B, a distinction is drawn
between designated pollutants which may cause or contribute to
endangerment of public health (referred to as "health-related pollutants")
and those for which adverse effects on public health have  not been
demonstrated (referred to as "welfare-related pollutants").  For
                                1-2

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health-related pollutants, emission standards and compliance times in
state plans must ordinarily be at least as stringent as the corresponding
emission guidelines and compliance times in EPA's guideline documents.
As provided in Subpart B, States may apply less stringent requirements
for particular facilities or classes of facilities when economic factors
or physical limitations make such application significantly more
reasonable.
     For welfare-related pollutants, States may balance the emission
guidelines, times for compliance, and other information provided in a
guideline document against other factors of public concern in establishing
emission standards, compliance schedules, and variances, provided that
appropriate consideration is given to the information presented in the
guideline document and at public hearing(s) required by subpart B and
that all other requirements of subpart B are met.  Where sources of
pollutants that cause only adverse effects to crops are located in
non-agricultural areas, for example, or where residents of a community
depend on an economically marginal plant for their livelihood, such
factors may be taken into account (in addition to those that would
justify variances if a health-related pollutant were involved).  Thus,
States will have substantial flexibility to consider factors other than
technology and cost in establishing plans for the control  of welfare-
related pollutants if they wish.  In developing and applying standards for
existing primary aluminum plants, the States are encouraged to take into
consideration, among other factors, the remaining useful life of the affected
facility.  Where a facility includes both old and new cells, it may be

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reasonable to apply less stringent standards to the old cells provided
that they are significantly closer to retirement than the new cells.
     For reasons discussed in chapter 2 of this document, the
Administrator has determined that fluoride emissions from primary
aluminum plants may cause or contribute to endangerment of the public
welfare but that adverse effects on public health have not been
demonstrated.  As discussed above, this means that fluoride emissions
will be considered a welfare-related pollutant and the States will
have greater flexibility in establishing plans for the control of
fluorides than would be the case if public health might be affected.
     This guideline document for primary aluminum plant fluoride emissions
provides a brief description of the primary aluminum industry and an
explanation of the four types of electrolytic cells, along with a summary
of  national statistics on production, plant location, cell type, and
future trends.  The causes, nature, and source of fluoride emissions from
primary aluminum reduction are discussed, and the health effects
associated with this pollutant are described.  The greatest emphasis,
however, has been placed on the technical and economic evaluation of
control techniques that are effective in reducing fluoride emissions,
with particular emphasis on the retrofit of existing plants.  Because of
this emphasis, EPA personnel visited nine primary aluminum plants to
gather engineering information and cost data on actual emission control
retrofits.  Detailed trip reports were composed as background source
materials to support this document.  Section 6.3 presents "retrofit case
descriptions" for three of the nine plants visited:  these case
                             1-4

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descriptions give in depth engineering scopes of work including plant
layouts to scale; duct sizes and lengths; major items of structure,
emission control, and auxiliaries, along with cost breakdowns; and air
'emission reductions realized for the money spent.
     The control equipment and the emission guidelines on which they
are based are discussed in Chapters 6 and 8.  The environmental
assessment of the emission guidelines is presented and discussed in
Chapter 9.  The remainder of this introductory chapter summarizes
information presented in subsequent sections.
1.2  HEALTH AND WELFARE EFFECTS OF FLUORIDES
     Fluoride emissions from primary aluminum plants have been determined
to be welfare related [i.e. no demonstrated impact upon public health
for purposes of section lll(d)].  The daily intake of fluoride inhaled
from the ambient air is only a few hundredths of a milligram - a very
small fraction of the total intake of the average person.  If a person is
exposed to ambient air containing about eight micrograms (yg) of fluoride
per cubic meter, which is the maximum average concentration that is projected
in the vicinity of a primary aluminum facility with only moderate control
equipment (Table 9-5), his total daily intake from this source is
calculated to be about 150 yg.  This is very low when compared with the
estimated daily intake of about 1200 yg from food, water and other sources
for the average person.  Also, the intake of fluoride indirectly through
standard,food chains is insignificant.  Fluorides are not passed into
dairy products and are only found in farm produce in very small amounts.
                             1-5

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     Fluorides do, however, cause damage to livestock and vegetation
in the immediate vicinity of primary aluminum plants.  Ingestion of
fluorides by livestock frem hay and forage causes bone lesions, lameness
and impairment of appetite that can result in decreased weight gain or
diminished milk yield.  It can also affect developing teeth in young
animals, causing more or less severe abnormalities in permanent teeth.
Exposure of plants to atmospheric fluorides can result in accumulation,
foliar lesions, and alteration in plant development, growth, and
yield.
1.3  FLUORIDES AND THEIR CONTROL
1.3.1  Fluorides
     For purposes of  standards of performance for new stationary sources,
(SPNSS) and the attendant requirements of section lll(d), "total
fluorides" means  the  particulate and gaseous fluorides that are measured
by test methods as set forth in Methods 13A, 13B and 14, Appendix A to
40 CFR Part 60.
     Particulate  fluorides emitted from primary aluminum plants include
cryolite  (NaJUFg), aluminum fluoride (A1F3), calcium fluoride (CaF2),
and chiolite  (Na5Al3F^4).
     The principal gaseous fluoride compounds emitted during normal
operation  are  hydrogen fluoride  (HF) and silicon tetrafluoride (Si'F.).
     The  intent of the SPNSS is to limit emissions of all of the above
compounds.  EPA source tests have shown that if fluorides are well-
controlled, the resulting  control of particulates and organics will
also be good.  Control of  all these pollutants requires good capture of
gases from the electrolytic cell and good fluoride removal from the
captured cell  gases.  Good capture requires not only good cell and
ventilation system design, but also superior equipment maintenance and
                                1-6

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careful cell working in a manner to minimize the time during which any
cell or cell door is open.  Thus, the SPNSS requires control by other
methods than best practical design alone.
1.3.2  ronf"ol of Fluorides:  New Primary Aluminum Plants
     In accordance with section 111 of the Clean Air Act, standards of
performance were promulgated on January 26, 1976, for total  fluoride and
visible air emissions from new modified, or reconstructed primary aluminum
plants.  (40 CFR 60 - Subpart S).
     Section 60.192 of Subpart S states that no owner or operator shall
cause to be discharged into the atmosphere from any affected facility any
gases which contain total fluorides in excess of:
     (1)  1 kg/Mg (2 Ib/ton) of aluminum produced for vertical  stud
Soderberg and horizontal stud Soderberg plants;
     (2)  0.95 kg/Mg (1.9 Ib/ton) of aluminum produced for potroom groups
at prebake plants; and
     (3)  0.05 kg/Mg (0.1 Ib/ton) of aluminum equivalent for anode
bake plants.
     The owner shall record aluminum and anode production with an accuracy
of +_ 5 percent.  In addition, the air pollution control system for each
affected facility shall be designed for accurate volumetric flow rate
determination and representative total fluoride sampling.
     Amendments to Subpart S were proposed on September 19, 1987 (43
FR 42188) and are scheduled for promulgation in July of 1979.
     Table 1-1, based on Table 5-2, gives emissions for each of the
aluminum reduction cell types, and indicates overall control efficiencies
for total fluorides.  It is evident that future new plants will require much
better control.
                                1-7

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                               Table 1-1.  POTROOM TOTAL FLUORIDE EMISSIONS IN U.S., 1975
I
oo
Cell Type3
CWPB
SWPB
HSS
VSS
All Cell Types
Controlled and Uncontrolled
Plants
Average
^
kg Al
3.15
6.3
2.85
2.6
3.5
Emissions
Ib F
ton Al
6.3
13.0
5.7
5.2
7.0
Overall Control
Efficiency, %
85
71
83
88
83
Controlled Plants
Average
kg~AT
2.3
2.4
2.85
2.5
2.5
Emissions
Ib F
ton Al
4.6
4.8
5.7
5.2
5.0
Overall Control
Efficiency, %
89
89
83
88
88
           CWPB - center-worked prebake; SWPB
           vertical stud Soderberg.
- side-worked prebake;  HSS  -  horizontal  stud  Soderberg;  VSS -

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1.3.3  Control of Fluorides:  Existing Primary Aluminum Plants
     The intent of Subpart B is to apply best adequately demonstrated
control in order to limit the emissions of designated pollutants from
designated facilities.  As applied to Subpart S, this means applying
particulate and gaseous fluoride control to existing primary aluminum
plants.
     Table 1-2 is based on Table 6-33 and summarizes costs and total
emission reductions for retrofit emission controls at 10 primary
aluminum plants visited and studied by EPA personnel.   Plants A, B,
and C represent those that are presented as retrofit case descriptions
in Sections 6.3.1, 6.3.2, and 6.3.3, respectively.  Cost and retrofit
information for plants D through M is much less complete and detailed.
Table 1-3 identifies the retrofit controls used on eight of the plants
visited.
     As Table 1-3 indicates, one or two of the retrofits were not fully
installed when the costs were collected; the final costs of these were
therefore not known.  Plants A and B (Table 1-2) were chosen for case
descriptions over plants D through G for several reasons other than cost
alone.   Indeed, a rating system was used to choose the best three of the
seven plants for retrofit case descriptions.  Additional rating factors
included amount of available engineering description, decrease in
fluoride emissions by retrofitting, and quality of emission data before
and after retrofitting.
                                1-9

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            Table 1-2.   RETROFIT EMISSION  REDUCTIONS AND COSTS  FOR TEN PRIMARY ALUMINUM PLANTS
Plant
code
G
D
F
H
C
K
A
B
E
M
Cell
type
CWPB
CWPB
CWPB
CWPB
SWPB '
SWPB
HSS
HSS
-vss
VSS
Plant capacity,
short tons/yr
250,000
115,000
32,850
130,000
265,000
35,000
80,000
210,000
91 ,000
180,000
Total emissions, Ib F/torv Al
Before ,
retrofit
19.0
7.3
5.1
6.9
9.0
7.7
9.3
5.4
4.2
5.3
After ,
retrofit0
2.7
2.6
1.2
2.5;
1.3
10. 6d
2.4
2.9
2.0
1.9
Retrof i t
capital
cost, $/ton Al
124
102
54
216
54
121
Change in
annual operating
cost, $/ton Al
NA
MA
NA
NA
3.53C
NA
141 1 -4.78e
02
64 I
115
0.81
NA
9.57
s
        CWPB  - center-worked  prebake; SWPB - side-worked nrebake; HSS - horizontal stud Soderberg;
        VSS - vertical  stud Soderberg.
        Average primary and secondary total fluoride emissions.
       °Credit not taken for fluoride adsorbed on alumina and returned to process.
       dSee Section 6.3.4.2.
'Credit taken.

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               Table 1-3.   RETROFIT CONTROLS FOR EIGHT PRIMARY  ALUMINUM  PLANTS
hant
code
G
D
F
C
A
H
B
E
Retrofit control ^
Primary
Collection system
Dry scrubbing
Dry scrubbing
Dry scrubbing
Dry scrubbing
Dry scrubbing
Dry scrubbing
Wet ESPa
Wet ESP
Secondary
None
None
None
No change
None
None
None
Elevated
scrubbers
Retrofit status (March 1975)
Started */73; comnlete earlv 1976
Start mid-1975; complete about 7/78
Started 9/71; complete 8/74
Completed in May 1970
Completed in Spring 1973
Started 7/72; complete ?/74
Started 5/75; complete early 1977
Started late 1970; complete about 6/75
Complete
ESP - electrostatic precipitator.

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     Table 1-2 indicates that dry scrubbing - baghouse devices can be
retrofitted to reduce total fluorides.  Dry scrubbing absorbs gaseous
fluoride on alumina.  This is followed by baghouse collection of  residual
particulate fluoride and alumina.  Both the alumina and fluorides can  then
be recycled to the electrolytic cells, thus avoiding a solid and  liquid
waste problem.  Wet electrostatic precipitators (ESP) can approach the
dry scrubber in performance, but they produce an aqueous waste and must
be coupled with scrubbers to absorb all of the HF.
     The important message in Table 1-2 is that fluoride controls installed
in existing primary aluminum plants vary greatly in capital cost  and even
in operating costs.  Indeed, the actual control must be specified to the
plant and tailor-made for it.  No off-the-shelf control devices are
available and retrofit emission control models are valid only for the
conditions and situations upon which they are based, when single  plants are
studied.
     Under the Clean Air Act Amendments of 1977, existing facilities must be
controlled to the degree of emission reduction attainable with the best
adequately demonstrated system, considering costs and any non-air quality
health, environmental impact, and energy requirements.  For fluoride
emission control from existing primary aluminum facilities, the efficient
removal of fluorides from a gas stream is relatively easy.  However, a
significant portion of the gaseous emissions from the reduction cells
can escape capture by the collection hoods, thus by-passing the primary
control system.  This situation results in two types of emissions:  those
captured by the hood system which pass through the primary control device
                               1-12

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(or primary emissions) and those which elude the hood system and exit
the building through the roof monitors (or secondary emissions).
     Examination of the average fluoride removal efficiencies of primary
(98.5% removal) and secondary (75% removal) control devices reveals the
importance of good capture of reduction cell emissions by the primary
collection system.  Most plants presently do not control secondary
emissions.  The conclusion, therefore, is that the best system of emission
reduction, considering costs, is an effective hooding system (which
minimizes secondary emissions) in combination with wet or dry scrubbing
of the primary gases.  Because of the relative cell gas volumes of
differing cell designs and plant ages; the physical layout of the plant
which in turn affects duct lengths, available space and access to areas;
the variation in nature and amount of required demolishments, movings,
and removals; and the availability of electrical power; the necessary
collection and control system must be plant-specific.
     As illustration of the preceding paragraph, capital costs in dollars
per ton of aluminum produced vary up to threefold or more among the ten
primary aluminum plants shown in Table 1-2.  This variation was approached
among the three plants detailed as case descriptions.
1.4  EMISSION GUIDELINES
1.4.1  State Emission Guidelines
     Table 1.4 presents the State guidelines for control of total fluoride
emissions from existing primary aluminum plants.  These guidelines consist of:
recommended control technologies that EPA believes can  readily achieve the
stated fluoride collection and removal efficiencies; an indication
of the status of  primary control on a national  basis, and the conditions
under which better primary control should be installed  or secondary control

                           1-13

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                                                                V"
 Table 1-4.   STATE  GUIDELINES  FOR CONTROL OF FLUORIDE EMISSIONS FROM EXISTING PRIMARY ALUMINUM PLANTS
Cell Type
VSS

SWPB

HSS

CWPB

Recommended Efficiencies
for Proposed Retrofits
Primary Collection
80

80

90 (a)

95 (a)

Primary Removal
98.5

98.5

98.5

98.5
0

Secondary Removal
75(a)

75 (a)





Guideline Recommendations
All plants now have best achievable hooding
and primary removal .
Install secondary control, but only if justified
depending on severity of fluoride problem.
Install best available hooding and primary removal
equipment.
Install secondary control wherever justified,
depending on the severity of the fluoride problem.
All plants but #26 now have the best achievable
primary collection efficiency. PI ant #26 should
install best primary control if needed.*
Secondary control does not appear to be justified,
in most locations.
Best control is best hooding and primary removal
equipment. Install where needed.
Secondary control does not appear to be justified,
in most locations.
   Plant #26; see Tables 7-2 and 7-3
(a) See Section 1.4.1

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added.
     Column 1  of Table 1-4 shows each of the four primary aluminum
electrolytic cell types.  Column 2 shows the corresponding primary
collection (hooding) efficiencies chosen by EPA as readily achievable for
new retrofits.  The values in Columns 3 and 4 were similarly chosen for
primary anu secondary removal efficiencies, respectively.
     Column 5 of Table 1-4 gives EPA findings and recommendations.  All
VSS plants and all but one HSS plant currently (1975) have best achievable
primary collection efficiency, and the VSS plants all have the best
achievable primary removal.  The best available primary control systems
should be installed on SWPB and CWPB plants.  Secondary controls may be
installed on VSS and on SWPB plants with severe fluoride problems, but
do not appear to be justified on HSS and CWPB plants in most locations.
It is assumed that anode butts will be carefully cleaned and their
fluoride content minimized before recycle to the anode bake plant;
otherwise, anode bake plant control should be required, depending upon
the severity of the fluoride problem.
     The primary collection (hooding) efficiencies were chosen from
values calculated by EPA and compared—with good agreement—to values
measured or otherwise arrived at by plant owners.  These derivations of
                                                                            2
hooding efficiencies are discussed in detail in Section 6.1.2 and elsewhere.
Well-designed retrofit hoods can easily obtain the tabulated efficiencies
if properly maintained and if the cells are carefully operated.  Similarly,
good retrofit dry scrubbers or spray tower-electrostatic precipitator
combinations can readily achieve 98.5 percent fluoride removal.
     Some existing secondary removal units (scrubbers) may not be able to
achieve 75 percent efficiency (see Section 6.2.3).  Control officials should
carefully study costs, impacts, and energy requirements before requiring
either improvements or initial retrofits.
                           1-15

-------
     If hooding were added to, or replaced on,  an existing HSS plant,
EPA believes that modern technology can achieve 90% collection efficiency,
in almost all cases.  A plant may exist, however, where there is insufficient
space to install proper ducting, or it may be economically impractical  to
install best hooding.
     If a modern primary removal system were added to, or replaced on,
an existing HSS plant, EPA believes that modern technology can achieve
98.5% removal efficiency.  A modern spray tower added ahead of existing
wet ESP's can raise primary removal efficiency to 98.5.  This spray tower
addition may be economically impractical if sufficient space does not exist
within a reasonable distance of fluoride source and wet ESP.
     If an HSS plant has existing primary collection efficiency of 85-90%
and primary removal efficiencies of 95 - 98.5%, control agencies should
closely study costs and benefits, before requiring retrofits.  In the
above efficiency ranges, retrofit does not seem justified unless there  is
a local fluoride problem.
     If hooding were added to, or replaced on, an existing CWPB plant,
EPA believes that modern technology can achieve 95% collection efficiency,
in almost all cases. _A plant may exist, however, where there is insufficient
space to install proper ducting, or it may be economically impractical-to
install best hooding.
     If a modern primary removal system were added to, or replaced on,  an
existing CWPB plant, EPA believes that modern technology can achieve 98.5%
removal efficiency.
     If a CWPB plant has existing primary collection efficiency of 90-95%
and primary removal efficiencies of 95 - 98.5%, control agencies should
closely study costs and benefits, before requiring retrofits.  In the above
efficiency ranges, retrofit does not seem justified unless there is a
local fluoride problem.
                            1-16

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1.4.2  Performance of Recommended Emission Controls
     Table 1-5 shows the performance to be expected by application of
the State guidelines for control of emissions from existing primary
aluminum plants.  The performances are expressed as average fluoride
emissions, in Column 7; they were calculated with equation 7.1,
using the cell evolution values in Column 6 and the recommended fluoride
collection and removal efficiencies of Columns 2-4.  The cell fluoride
evolution values in Column 6 correspond to the largest and smallest
values reported by industry for the given cell types.  Therefore, the
average fluoride emission values shown in the last column of Table
1-5 represent expected ranges.  For example, the last column shows that
the average emissions from CWPB plants will range from 1.7 - 4.2 Ibs
F/ton Al, provided that all these plants have or install controls equivalent
to 95 percent hooding efficiency and 98.5 percent primary removal efficiency.
     The incremental cost effectiveness for the guidelines of Table 1-4
can be inferred from those given in Table 7-9.  Secondary control of HSS
and CWPB cells has very high incremental cost effectiveness of $10 - $40
per pound of fluoride removal.  Corresponding figures for VSS are $4 -
$8 per pound and are a minimum of $4 per pound for SWPB.
     The States should, therefore, be guided by the principles set forth
in this discussion and in Section 8, and should set emission limits with
consideration of-severity of fluoride problem, costs, and any nonair
quality health and environmental impact and energy requirements.
     It should be noted that changes in the cell bath ratio, NaF/AlF-,
will change a cell evolution rate, which will change - or tend to change -
the emissions from the fluoride control devices.
                            1-17

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                    Table 1-5.   FLUORIDE EMISSION RANGES  CORRESPONDING TO STATE GUIDELINES FOR EXISTING PRIMARY ALUMINUM PLANTS
Cell
Type
VSS
SWPB
HSS
Recommended Efficiencies
for Proposed Retrofits
Primary
Collection
80
80
90
CWPB : 95
; i
Primary
Removal
98.5
98.5
98.5
98.5
i
i
Secondary
Removal
75
75


Assumed Average
Guideline Fluoride Cell
Recommendations Evolution-lb/ton Al
All plants now have best achievable
hooding and primary removal.
Install secondary control, but only
if justified, depending on severity
of fluoride problem.
Install best available hooding
and primary revmoval equipment.
Install secondary control wherever
justified, depending on the severity
of the fluoride problem.
Install best primary control if
needed. All plants but #26 now
have best achievable primary collection
efficiency.
Secondary control does not appear to be
justified, in most locations.
Best control is best hooding and
primary removal equipment.
Install where needed.
Secondary control does not appear to
be justified, in most locations.
30 - 54
37 - 53
28 - 45
26 - 66
Average Fluoride Emission
range, Ib F/ton Al
Control
Primary 6.4* - 11.4
Secondary 1.9** - 3.4
Primary 7.8 - 11.2
Secondary 2.3 - 3.3
Primary 3.2 - 5.1
Secondary 1.1 - 1.7
Primary 1.7 - 4.2
Secondary — —
 I
CO
      *    30 [ 1 - .80 x .985] = 6.4 Ibs F/ton Al
      **   30 [ 1 - .80 x .985 - (1 - .80) x .75] = 1.9 Ibs F/ton Al

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1.4.3.  Emission Testing
     The above guidelines are structured to give the States maximum
flexibility in use of existing emission control  and of source sampling
and analytical methods.   State regulations are now in place which limit
fluoride emissions from existing primary aluminum plants.  These regulations
vary from State to State and differ from Federal new source performance
standards.  EPA compliance test reference methods 13(a), 13(b), and 14 were
developed for use with these new source performance standards.  However,
installation of Method 14 ductwork on existing plants may be very expensive in
some cases, or may even be precluded because of unadaptability to the
existing roof monitor.  Therefore, in order to avoid costly and unnecessary
modifications of roof monitor sampling systems,  EPA does not specify
compliance testing for existing plants.
                               1-19

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1.5  ASSESSMENTS
1.5.1  Economic
     Control costs might have been derived from Table 1-2, where actual
costs for retrofit emission controls are shown.  However, the plant sample
is not large, even though all four cell types are represented.  Also, the
costs of greater or lesser degrees of control would be difficult to
estimate.  Considerable engineering design, quotations, and drawings would
be required to make these emission level costs consistent in quality with
the actual costs shown in Table 1-2.
     The model approach of reference 3 was used to investigate the
effects of various controlled fluoride emission levels on costs.  Nineteen
costed control modules were chosen to represent various degrees of emission
collection and control.  For example, capital cost modules for a prebake
plant included those for hooding improvement, primary collection system,
and for fluidized bed dry scrubber.  The latter two items represent
different degrees of fluoride emissions control and also different costs.
The total retrofit capital cost for a given plant is estimated by determining
the items that have to be improved, installed, dismantled or replaced,
and adding the corresponding control  module costs.
     The control modules are based on generalized costs applicable to
courtyard control systems.  They are also based on typical values of gas
                               1-20

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volumes to primary and secondary controls.  In addition, control costs per
unit of production derived by using these modules do not vary significantly
with plant size.  These, and other assumptions underlying the modules,
are approximations.  In general, direct cost comparison with specific
plants is not justified.
     The value of models lies mainly in their ability to evaluate changes,
not to estimate accurate construction costs.  The latter requires very
accurate information; the former is less demanding since errors tend to
cancel out when differences are measured.  This offsetting of positive
and negative cost errors should reduce the average error as the number of
plants studied increases.  The cost differences among levels of control
should be more realistic than absolute cost levels.
     Fluoride emission control costs were arrived at by the following
general process:
     1.  Data shown in Table 7-2 were obtained on fluoride emissions
         from the 31 U.S. primary aluminum plants, along with current
         fluoride controls at these plants.  Cell evolution rates,
         primary and secondary loadings, and emissions were obtained
         mostly from Section 114 letter responses from plants
         representing 86 percent of CWPB capacity and all of the
         domestic VSS, HSS, and SWPB capacity.
         The initial, or existing controls and corresponding performances
         for each plant are illustrated in Table 7-2.
     2.  Eight plants were taken for study and illustration and
         additional controls were added for logical  steps from existing
         to better control combinations.  Specifically, these steps
         were to install:
                               1-21

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         a.  Best primary collection for the cell type, if needed.
         b.  Best primary removal and water treatment, if needed.
         c.  Secondary control with scrubber water treatment.
         d.  Anode bake plant control system and water treatment, if
             needed.
     The cost results for all eight plants are given in September 1977 dollars
in Table 7-9, part of which is reproduced below as Table 1-6  for purposes
of illustration.  Table 7-9 is too limited to allow making general
statements on costs of other plants, but the following tabulation will
serve to illustrate how model costs can be drawn up.  For HSS plant 26
as illustrated:
                                                        $/Annual Ton Al
         Install  lime treatment of cryolite
           bleed  stream                                    $ 2.43
         Improve  hooding                                    18.54
         Install  wet ESP                                   243.09
         Remove spray tower                                  6.10
         Install  lime treatment for additional
           cryolite bleed stream                             2.43
         Install  spray screen                               97.36
         Install waste water lime treatment                 15.90
                                                          $385.85
The capital cost of $386 per annual ton of aluminum results from addition
of all the cost modules, and the annualized cost can be derived in the
same way.   Tables 7-4 and 7-7  contain these control module costs.  As
Table 1-6 shows, water treatment of cryolite bleed plus improved hooding
                                 1-22

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                                                          Table 1-6.  PRIMARY ALUMINUM CONTROL STRATEGIES
IN3
Plant
Code
26
Emission Control Required for
Hooding Primary (lu)
Poor Spray tower
Average
Fluoride Uni
the Specified Average Fluoride Emission Evolution Capital
Controls Secondary (2°) Controls Ib/ton Al S/ton Al
None 41.6 0
" Install lime treatment of " " 2.43
cryolite bleed stream

Improve Hooding " "
20.97
" " Install wet ESP; remove
spray tower. " " 270.16
" " Install lime treatment of " " 070 ..,„
additional cryolite bleed ///,:»
stream

it ti n
" " Install spray screen and " 386.01
t Costs Emissions Cost-Effectiveness
Annualized Controlled Cumulative Incremental
. S/ton Al IbF/ton Al. $/lb F $/lb F
0 34.5 0 0
1.04 34.5 0 0
5.68 18.4 0.35 0.35
61.13 5.7 2.12 4.37
62.17 5.7 2116 4.45-
101.02 ' 2.5 3.i6- 12.14
                                                                 waste water lima treatment

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costs $2.43 + $18.54 = $20.97 per annual ton, for a decrease in average
fluoride emission of 16.1 Ib F/ton Al.   It costs $5.68 to remove 16.1
pounds of fluoride for a cumulative cost of $0.35 per pound of fluoride;
in this case, the incremental cost is also the same.  The cost effectiveness
is based on the annualized cost.
1.5.2  Environmental
     Table 1-7  gives the environmental impacts of best primary control
and of maximum control.   For best primary control, each existing plant is
upgraded to the level of best cell hooding and primary control for that
particular plant.  This level is not meant to be the lowest national level
of emission control improvement.  However, the second case - that of
maximum or best primary and secondary control - does represent the
highest possible level of improvement.   Thus, the environmental impacts
of Table 1-7 bracket the conditions that should result from applying
State guidelines.  This table is based on the status of the primary
aluminum domestic plants as of the Spring of 1975.
     The table shows the annual removal of particulate emissions; good
control of particulates is necessary for good fluoride removal.
     There will be a negligible change in aqueous and solid wastes caused
by adoption of State guidelines.
     The data on cell fluoride emissions in the final rows of Table 1-7
indicate that existing plants require much better than current controls.
1.5.3  Energy
     Table 1-7 shows the national tonnage of coal that is equivalent to
the energy required for fluoride emission control.  National control to
the level of best hooding and primary control will increase fluoride
control energy expenditures by as little as 120,000 megawatt hours per
                               1-24

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               Table 1-7.   ENVIRONMENTAL IMPACT OF BEST CONTROL FOR TOTAL FLUORIDE EMISSIONS FROM THE

                                                 PRIMARY ALUMINUM INDUSTRY
                                                                Fluoride Emissions Control Level
no
en
National Impacts
National Fluoride Air Emission (tons F/yr)
National Particulate Emissions (tons F/yr)
National Water Effluent Emissions
(tons/yr)
Fluoride
Total Suspended Solids
National Fluoride Control Energy Requirements
(Mwh/yr)
National Solid Wastes from Fluoride Control
(tons/yr)
Bituminous Coal Used for National Fluoride
Control (tons/yr)
Average Fluoride Emissions, Ib F/ton Al
cell: CWPB
SWPB
VSS
HSS
Existing
18,000
44,000


110
210
1,470,000

160,000

612,000

6.3
13.0
5.2
5.7
Best Hooding & Primary
Control
9,000
25,000


85
170
1,590,000

130,000

662,000

2.7
4.0
5.2
4.0
Best Primary & Secondary
Control
4,000
21,000


260
510
2,900,000

220,000

1,210,000

1.2
2.2
2.1
1.7

-------
year over existing control.  This energy is equivalent to the generation
of an additional 14 megawatts of electrical power nationally, or to an
average incremental fluoride control power expense of 0.44 megawatts
per plant.  In comparison, an average of 283 megawatts of electrolytic
power is required per domestic primary aluminum plant.
1.6  COMPLIANCE TIMES
     The compliance times for the installation of a typical fluoride
emission control system at a primary aluminum plant is shown in Table 1-8.
This table represents a moderately complicated case involving the
improvement of hooding and the installation of fluidized bed dry scrubbers.
Such a project involves not only the installation of the very large dry
scrubbers  (see Figures 6-13 and 6-14) but also of storage and surge tanks,
conveyors, fans and long  lengths of huge ductwork with associated foundations,
structural steelwork, and electrical drive systems.
     As explained in Section 6.5, and indicated above, the large amount
of material procurement causes an overlap of most design and construction
activities.  At a given time, numerous items are in various stages of
design, procurement, and  construction.  For this reason, contracts for
major items cannot be awarded simultaneously, but are made over a range
of time as shown in Table 1-8.
     One important step that is almost wholly beyond the control of the
customer or the control official is the delivery time.  Table 1-8  is
based on delivery times as of the summer of 1974.  The time required from
order to delivery increased greatly from 1973 to 1974 and passed all
former bounds for certain items used for adding retrofit controls at
                                1-26

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primary aluminum plants.  Thus, delivery reports gave 35-50 weeks for

electrical switchgear, 25-60 weeks for fans and 35-65 weeks for

electrical motors.  Deliveries can depend partly upon quantity ordered,

continuity of business through the years, and most favored customer

statue.

Table 1-8.   INCREMENTS OF PROGRESS FOR INSTALLATION OF FLUORIDE
          EMISSION CONTROLS IN AN EXISTING PRIMARY ALUMINUM PLANT

Increments of progress                     Elapsed time - weeks

Preliminary control plan and compliance
schedule to appropriate agency                        25

Award of major contracts                           35 - 55

Start of construction                                 60

Completion of construction                           124

Final compliance                                     130



     Table 1-9  gives the time required to retrofit eight actual  primary

aluminum plants.  In each case, the whole plant was retrofitted,  except for

plant F.  Only plants C, E, and H had secondary control originally and

only plant E improved its secondary control, at a cost of about 65 percent

of its total retrofit expenditure.  Plant B built and operated a pilot

plant during two of the 4-1/2 years of retrofit activity.  The completion

time of 5-1/2 years for plant G includes 3 years for improved cell hooding

and 3 years for dry scrubber installation.  The 3 years for improved

hooding is due to a claimed economic advantage for modifying cells over
                              1-27

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               Table 1-9 .   TOTAL CONSTRUCTION TIME FOR RETROFIT EMISSION CONTROLS FOR

                                          PRIMARY ALUMINUM PLANTS
Plant
Code

A
B
C
D
E
F
G
H
Cell
Type

HSS
HSS
SWPB
CWPB
VSS
Cl/PB
CURB
CWPB
Plant Capa-
city
(tons/yr)

80,000
210,000
265,000
115,000
91,000
32,850
250,000
130,000
Retrofit Capital
Cost ($)

11,300,000
19,300,000
14,300,000
11,800,000
5,800,000
1,800,000
31,000,000
28,000,000
Description of
Retrofit Emission Controls

Dry scrubbers-primary
Improved cell hooding and wet
ESP-primary
New cell hooding and dry
scrubbers -primary
Dry scrubbers-primary
Wet ESP-primary
Dormer tunnel -secondary
Time Required
for Retrofitting
(years)

2-1/2
4-1/2
3
1
3
2-1/2
Dry scrubbers-primary 1-1/2
(1 potline) !
Improved cell hooding and dry
scrubbers-primary
Improved cell hooding and
dry scrubbers-primary
5-1/2
i
' 2
r\j
oo

-------
the normal 3-year life of their cathode linings.  Had plant G so
elected, the dry scrubber installation could have proceeded simultaneously
with cell hooding improvements, reducing the completion time to about 3
years.
     The actual time requirements shown in Table 1-9 could probably have
been decreased if there had, at the time, been a requirement or incentive
to do so.  With no capital return, the usual requirements for haste was
reduced, except for any time when production could have been held up.
     In view of the above discussion, a reasonable total time for
retrofitting emission controls to a primary aluminum plant may be taken
as about 2-1/2 years.  Because of the changing situation on equipment
manufacturing and delivery times, however, it is recommended that
enforcement officials consider each plant on a case-by-case basis.  They
should require proof for the time requirements claimed for each milestone
shown in Table 1-8.  Additional time allowance may be made if it takes longer
than indicated in Table 1-8 to reach compliance after completion of construction.
                            1-29

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1.7  REFERENCES FOR SECTION 1

1.   Varner, Bruce A.  and Crane, George B.   Actual  Costs for Retrofit of
     Fluoride Emission Controls to Existing Primary Aluminum Plants.
     Paper presented at 83rd National  Meeting American Institute of
     Chemical Engineers, Houston, Texas.   March 20-24, 1977.

2.   Varner, Bruce A.  and Crane, George B.   Estimation of Primary Collection
     Efficiency for New or Retrofit Hooding for Primary Aluminum Cells.
     Paper presented at 69th Annual Meeting of the  Air Pollution Control
     Association, Portland, Oregon, June 27-July 1, 1976.

3.   Air Pollution Control in the Primary Aluminum  Industry.  Singmaster
     and Breyer, New York, New York.   Prepared for  Office of Air Programs,
     Environmental Protection Agency,  Research Triangle Park, North
     Carolina, under Contract Number CPA 70-21.  July 1973.
                               l-3u

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           2.  HEALTH AND WELFARE EFFECTS OF FLUORIDES

2.1  INTRODUCTION
     In accordance with 40 CFR 60.22(b),  promulgated on November 17,  1975
(40 FR 53340), this chapter presents a summary of the available infor-
mation on the potential health and welfare effects of fluorides and the
rationale for the Administrator's determination that it is  a  welfare-
related pollutant for purposes of section lll(d) of the Clean Air Act.
     The Administrator first considers potential health and welfare
effects of a designated pollutant in connection with the establishment
of standards of performance for new sources of that pollutant under
section lll(b) of the Act.  Before such standards may be established,
the Administrator must find that the pollutant in question  "may contribute
significantly to air pollution which causes or contributes  to the endanger-
ment of public health or welfare" [see section 111(b)(l)(a)].  Because
this finding is, in effect, a prerequisite to the same pollutant's being
identified as a designated pollutant under section lll(d),  all  designated
pollutants will have been found to have potential adverse effects on
public health, public welfare, or both.
     As discussed in section 1.1 above, Subpart B of Part 60  distinguishes
between designated pollutants that may cause or contribute to endangerment
of public health (referred to as "health-related pollutants") and those
for which adverse effects on public health have not been demonstrated
("welfare-related pollutants").  In general, the significance of the
distinction is that States have more flexibility in establishing plans
for the control of welfare-related pollutants than is provided for
plans involving health-related pollutants.
                              2-1

-------
     In determining whether a designated pollutant is health-related
or welfare-related for purposes of section lll(d), the Administrator
considers such factors as: (1) Known and suspected effects of the
pollutant on public health and welfare; (2) potential ambient concentrations
of the pollutant; (3) generation of any secondary pollutants for which
the designated pollutant may be a precursor; (4) any synergistic effect
with other pollutants; and (5) potential effects from accumulation in
the environment  (e.g., soil, water and food chains).
     It should be noted that the Administrator's determination whether
a designated pollutant is health-related or welfare-related for purposes
of section lll(d) does not affect the degree of control represented by
EPA's emission guidelines.  For reasons discussed in the preamble to
Subpart B, EPA's emission guidelines [like standards of performance for
new sources under section lll(b)] are based on the degree of control
achievable with  the best adequately demonstrated control systems (considering
costs), rather than on direct protection of public health or welfare.  This
is true whether  a particular designated pollutant has been found to be
health-related or welfare-related.  Thus, the only consequence of that
finding is the degree of flexibility that will be available to the States
in establishing  plans for control of the pollutant, as indicated above.
2.2  EFFECT OF FLUORIDES ON HUMAN HEALTH1
2.2.1  Atmospheric Fluorides
     The daily intake of fluoride inhaled from the ambient air is only a
few hundredths of a milligram - a very small fraction of the total intake
for the average  person.  If a person is exposed to ambient air containing
about 8 micrograms (yg) of fluoride per cubic meter, which is the maximum
average concentration that is projected in the vicinity of a primary
                              2-2

-------
aluminum facility with only mediocre control equipment (Table 9-5), his total
daily intake from this source is calculated to be about 150 yg.   This
is very low compared with the estimated daily intake of about 1200 yg
from food, water, and other sources for the average person.
     Few instances of health effects in people have been attributed
to community airborne fluoride, and they occurred in investigations
of the health of persons living in the immediate vicinity of fluoride-
emitting industries.  The only effects consistently observed are
decreased tooth decay and slight mottling of tooth enamel when compared
to control community observations.  Crippling fluorosis resulting from
industrial exposure to fluoride seldom (if ever) occurs today, owing
to the establishment of and adherence to threshold limits for exposure
of workers to fluoride.  It has never been seen in the United States.
Even persons occupationally exposed to airborne fluoride do not usually
come in contact with fluoride concentrations exceeding the recommended
industrial threshold limit values (TLV).  The current TLV for hydrogen
fluoride is 3 parts per million (ppm) while that for particulate
fluoride is 2.5 milligrams per cubic meter (mg/m ) expressed as elemental
fluorine.
     There is evidence that airborne fluoride concentrations that
produce no plant injury contribute quantities of fluoride that are
negligible in terms of possible adverse effects on human health and
offer a satisfactory margin of protection for people.
     Gaseous hydrogen fluoride is absorbed from the respiratory tract
and through the skin.  Fluoride retained in the body is found almost
entirely in the bones and teeth.  Under normal conditions, atmospheric
                              2-3

-------
fluoride represents only a very small  portion of the body fluoride
burden.
2.2.2  Ingested Fluorides
     Many careful studies, which were  reviewed by the National  Academy
of Sciences, have been made of human populations living in the  vicinity
of large stationary sources of fluoride emissions.  Even in situations
where poisoning of grazing animals was present, no human illness due
to fluoride poisoning has been found.   In some of these areas much of
the food used by the people was locally produced.  Selection, processing,
and cooking of vegetables, grains and  fruits gives a much lower fluoride
intake in human diets than in that of  animals grazing on contaminated
pasture.
     In poisoned animals, fluorine levels are several thousand  times
normal in bone, and barely twice normal in milk or meat.  Calves and
lambs nursing from poisoned mothers do not have fluorosis.  They do not
develop poisoning until they begin to graze.  Meat, milk and eggs from
local animals contain very little more fluoride than the same foods
from unpoisoned animals.  This is due  to the fact that fluorine is
deposited in the bones almost entirely.
2.3  EFFECT OF FLUORIDES ON ANIMALS1
     In areas where fluoride air pollution is a problem, high-fluoride
vegetation is the major source of fluoride intake by livestock.
Inhalation contributes only a negligible amount to the total fluoride
intake of such animals.
     The available evidence indicates that dairy cattle are the
domestic animals most sensitive to fluorides, and protection of dairy
cattle from adverse effects will protect other classes of livestock.

                             2-4

-------
     Ingestion of fluoride from hay and forage causes bone lesions,
lameness, and impairment of appetite that can result in decreased
weight gain or diminished milk yield.  It can also affect developing
teeth in young animals, causing more or less severe abnormalities in
permanent teeth.
     Experiments have indicated that long-term ingestion of 40 ppm
or more of fluoride in the ration of dairy cattle will  produce a
significant incidence of lameness, bone lesions, and dental fluorosis,
along with an effect on growth and milk production.  Continual inges-
tion of a ration containing less than 40 ppm will give  discernible
but nondamaging effects.  However, full protection requires that a
time limit be placed on the period during which high intakes can be
tolerated.
     It has been suggested that dairy cattle can tolerate the ingestion
of forage that averages 40 ppm of fluoride for a year,  60 ppm for up to
2 months and 80 ppm for up to 1 month.  The usual food  supplements are
low in fluoride and will reduce the fluoride concentration of the total
ration to the extent that they are fed.
     Fluoride-containing dusts can be non-injurious to  vegetation but
contain hazardous amounts of fluoride in terms of forage for farm
animals.  Phosphate rock is an example of a dust that seemingly has
not injured plants but is injurious to farm animals.  This was made
evident forty years ago when an attempt was made to feed phosphate
rock as a dietary supplement source of calcium and phosphate.  Fluoride
                               2
injury quickly became apparent.   Phosphate rock is used for this
purpose today, but only after defluorinating by heat treatment.  Phos-
phate rock typically contains up to about four weight percent fluorine.
                              2-5

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2.4  EFFECT OF ATMOSPHERIC FLUORIDES ON VEGETATION1' 3
     The previous sections state that atmospheric fluorides are not a
direct problem to people or animals in the United States, but that
animals could be seriously harmed by injestion of fluoride from forage.
Indeed, the more important aspect of fluoride in the ambient air is
its effect on vegetation and its accumulation in forage that leads to
harmful effects in cattle and other animals.  The hazard to these
receptors is limited to particular areas:   industrial sources having
poorly controlled fluoride emissions and farms located in close
proximity to facilities emitting fluorides.
     Exposure of plants to atmospheric fluorides can result in accumu-
lation, foliar lesions, and alteration in plant development, growth,
and yield.  According to their response to fluorides, plants may be
classed as sensitive, intermediate, and resistant.  Sensitive plants
include several conifers, several fruits and berries, and some grasses
such as sweet corn and sorghum.  Resistant plants include several
deciduous trees and numerous vegetable and field crops.  Most forage
crops  are tolerant or only moderately susceptible.  In addition to
differences among species and varieties, the duration of exposure,
stage  of development and rate of growth, and the environmental condi-
tions  and agricultural practices are important factors in determining
the susceptibility of plants to fluorides.
     The average concentration of fluoride in or on foliage that appears
to be  important for animals is 40 ppm.  The available data suggest
that a threshold for significant foliar necrosis on sensitive species,
or an  accumulation of fluoride in forage of more than 40 ppm would
                             2-6

-------
result from exposure to a 30-day average air concentration of gaseous


fluoride of about 0.5 micrograms per cubic meter (yg/m ).


     Examples of plant fluoride exposures that relate to leaf damage

                                          2
and crop reduction are shown in Table 2-1.   As shown, all  varieties


of sorghum and the less resistant varieties of corn and tomatoes are


particularly susceptible to damage by fluoride ambient air concentra-


tions projected in the immediate vicinity of primary aluminum facilities


(See Table 9-5).


2.5  THE EFFECT OF ATMOSPHERIC FLUORIDES ON MATERIALS OF CONSTRUCTION

                       2
2.5.1  Etching of Glass


     It is well known that glass and other high-silica materials are


etched by exposure to volatile fluorides like HF and SiF..   Some


experiments have been performed where panes of glass were fumigated


with HF in chambers.  Definite etching resulted from nine hours


exposure at a level of 590 ppb.  Pronounced etching


resulted 14.5 hours exposure at 790 ppb.  Such levels would,


of course, cause extensive damage to many species of vegetation.


However, ambient concentrations of this magnitude are improbable


provided that a aluminum facility properly maintains and operates


some type of control equipment for abating fluoride emissions.


2.5.2  Effects of Fluorides on Structures


     At the relatively low gaseous concentrations of fluorides in


emissions from industrial processes, 1000 ppm or less, the damage


caused by fluorides is probably limited mostly to glass and brick.


Occasionally, damage to the interior brick lining of a stack has


been attributed to fluorides emitted in an industrial process.
                            2-7

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                     Table 2-1.  EXAMPLES OF HF CONCENTRATIONS AND EXPOSURE DURATIONS REPORTED
                     	TO CAUSE LEAF DAMAGE AND POTENTIAL REDUCTION IN CROP VALUES2

      p1ant                                                  Concentration and Time
                                                Most sensitive varieties - most resistant varieties

      Sorghum                                           0.7 ppb for 15 days - 15 ppb for 3 days

«>o     Corn                                              2 ppb for 10 days - 800 ppb for 4 hours

      Tomato                                            10 ppb for 100 days - 700 ppb for 6 days

                                                        100 ppb for 120 days - 700 ppb for 10 days
00

-------
     Fluoride damage occurs to the high silica brick used in the

furnaces for baking carbon anodes for aluminum reduction cells.

2.6  RATIONALE

     Based :n the information provided the preceding sections of

Chapter 2, it is clear that fluoride emissions from primary aluminum

plants have no significant effect on human health.   Fluoride

emissions, however, do have adverse effects on livestock and vege-

tation.  Therefore the Administrator has concluded  that fluoride

emissions from primary aluminum plants do not contribute to the

endangerment of public health.  Thus, fluoride emissions will be

considered a welfare-related pollutant for purposes of section lll(d)

and Subpart B of Part 60.


2.7  REFERENCES FOR SECTION 2

1.   Biologic Effects of Atmospheric Pollutants:  Fluorides.  National
     Academy of Sciences, Washington, D.C.  Prepared for Environmental
     Protection Agency, Durham, NC, under Contract  Number CPA 70-42.
     1971.

2.   Robinson, J. M. et al.  Engineering and Cost Effectiveness  Study
     of Fluoride Emissions Control.  Resources Research, Inc. and TRW
     Systems Group, McLean, VA.  Prepared for Office of Air Programs,
     Environmental Protection Agency, Durham, NC, under Contract
     Number EHSD 71-14.  January 1972.

3.   Carlson, C. E. and Dewey, J. E.  Environmental Pollution by
     Fluorides in Flathead National Forest and Glacier National  Park.
     U.S. Department of Agriculture - Forest Service.  Missoula,
     Montana.  October 1971.

4.   Peletti, E.  Corrosion and Materials of Construction.  In:
     Phosphoric Acid, Volume I, Slack, A. V. (ed).   New York, Marcel
     Dekker, Inc., 1978.  p. 779-884.
                            2.9

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      3.  U. S. PRIMARY ALUMINUM MANUFACTURING STATISTICS

3.1  EXISTING PLANTS
3.1.1   Introduction
     Aluminum ranks first in production among all  nonferrous metals
produced in the United States.1   The United States is the world's leading
producer of primary aluminum.  Primary aluminum is produced by electro-
lytic reduction of alumina which in turn is produced by refining bauxite
ore; secondary aluminum is produced by re-working aluminum scrap.
Primary production in the U. S.  in 1977 totalled 4.54 million short tons
                                                                   2
compared with an estimated world total of 15.05 million short tons.
U.S. production reached a record high in 1974 of 4.90 million short tons.
     Primary capacity in the U.S. at the end of 1977 was estimated at
                       3                                    4
5.19 million short tons  and was accounted for by 31 plants.   At
the end of 1977, there were 12 U.S. primary producers; about 65
percent of primary capacity was  accounted for by three producers—
                            3
Alcoa, Reynolds, and Kaiser.
     Aluminum produced by electrolytic reduction of alumina has an
average purity of about 99.5 percent.  The largest market for aluminum
in 1977 was the building and construction field (23.1 percent), fol-
lowed by transportation (21.7 percent), containers and packaging (20.8
percent), electrical (10.0 percent), consumer durables (7.9 percent),
other - primarily for defense (4.2 percent), machinery and equipment
(6.9 percent), and exports (5.4 percent).   Further refining of aluminum
can produce "super purity" aluminum, which is 99.99 percent pure.  This
grade of aluminum is used as a catalyst carrier in making high octane
gasoline, for forming jewelry, and, in the form of foil, for the electronics
industry.

-------
     Molten primary aluminum may be shipped directly to a customer's
plant in insulated ladles.  More commonly, it is cast into ingots or
billets of varying shapes and sizes, sometimes after being alloyed.
These may be fabricated at the reduction plant site or shipped to
another site for fabrication by the primary producer or an independent
fabricator.
     Fabricating may consist of:  rolling the ingot into plate, sheet,
and foile; forging into special shapes; drawing the ingot into rod, bar,
wire, and drawn tube, extruding billets into tubings, rod, bar, and
special shapes; or melting ingot and atomizing into powder, paste,
and flake.  Molten aluminum may also be cast, although casting proudcers
use mostly secondary aluminum for this purpose.
     In 1977, 6.68 million short tons of aluminum were shipped from U.S.
primary and secondary producers at a value of $13.3 billion.  In 1976,
shipments totalled 6.37 million short tons at an estimated val,ue of
$11.22 billion.6

3.1.2  Location and Size
     The 31 U.S. primary aluminum plants producing alumina by electro-
lytic reduction of alumina at the end of 1977 are listed in Table
    3  7-14-
3-1. *       The list includes location, company ownership, and
annual capacity by the type of reduction cell in use.  Table 3-1
shows that plant capacities range from 35,000 to 285^000 short tons
per year and that 20 of the 31 plants exclusively or primarily use
center-worked or side-worked prebake reduction cells.  The horizontal
Soderberg reduction cell is the second most popular choice.
                             3-2

-------
                          Table 3-1.  U. S. PRIMARY ALUMINUM PLANTS AND CAPACITIES,  19743'  7"14
                                                   (short tons)
State and City
Alabama
Scottsboro
Sheffield
Arkansas
Arkadelphia
Jones Mills
Indiana
Evansville
Kentucky
hawesvi lie
Sebree
Louisiana
Chalmette
Lake Charles
Maryland
Frederick
Company
Revere Copper & Brass, Inc.
Reynolds Metals Co.
Reynolds Metals Co.
Reynolds Metals Co.
Aluminum Co. of America

National-Southwire Aluminum Co.n
The Anaconda Aluminum Co.
Kaiser Aluminum & Chemical Corp.
Consolidated Aluminum Corp.
Eastalco Aluminum Co.
Annual capacity by cell type3'
CWPB

1 ,300C
125,000
280,000

180,000
120,000


SWPB
112,000
15,700C



35,000
174,0006
VSS







HSS
202,000
51,000°



260,000

CO

GO

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                    Table 3-1(continued).   U. S. PRIMARY ALUMINUM PLANTS AND CAPACITIES, 1974
State and City
Missouri
New Madrid
Montana
Columbia Falls
New York
Massena
Massena
North Carolina
Badin
Ohio
Hannibal
Oregon
The Dalles
Troutdale
Tennessee
Alcoa
Company
Noranda Aluminum, Inc.
The Anaconda Aluminum Co.
Aluminum Co. of America
Reynolds Metals Co.
Aluminum Co. of America
Ormet Corp . '

Martin Marietta Aluminum Inc.
Reynolds Metals Co.

Aluminum Co. of America
Annual capacity by cell type9'
CWPB
70,000

135,000
120,000
250,000

130,000

210,000
SWPB









VSS

180,000




90,000

60,000
HSS


126,000






OJ

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                   Table 3-1 (continued).  U. S. PRIMARY ALUMINUM PLANTS AND CAPACITIES, 1974
State and City
New Johnsonville
Texas
Corpus Christi
Point Comfort
Rockdale

Washington
Ferndale
Goldendale
Longview
Head
T a coma
Vancouver
w'enatchee
West Virginia
Ravenswood
Totals
Company
Consolidated Aluminum Corp,
Reynolds Metals Co.
Aluminum Co. of America
Aluminum Co. of America

Intalco Aluminum Corp.
Martin Marietta Aluminum Inc.
Reynolds Metals Co.
Kaiser Aluminum & Chemical Corp.
Kaiser Aluminum & Chemical Corp.
Aluminum Co. of America
Aluminum Co. of America
Kaiser Aluminum & Chemical Corp. •
Annual capacity by cell type9'
CWPB

285,000

206,000
115,000
180,000
163,000
2,570,300
SWPB i VSS
140,000


260,0009

649,700

185,000
HSS

115,000
i
120,000

635,000
210,000
81 ,000

1,045,000
GO
en
     Total  - all cell types
4,900,000

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                    Table 3-1  (continued).   U.S.  PRIMARY ALUMINUM PLANTS AND CAPACITIES, 1974

     FOOTNOTES:

     aThe design capacity of a reduction  plant  is not an exact figure; rather it is an estimated rate
      that is often below the level  at  which a  plant can actually produce.  For this reason, some capacity
      figures are more realistic than others.

     3CWPB— center-worked prebake cells,  SWPB-
      and HSS--horizontal  stud Soderberg  cells.

     :Based i
      cells.
 CWPB--center-worked prebake cells, SWPB—side-worked  prebake  cells, VSS—vertical  stud  Soderberg  cells.


cBased on a total  plant capacity of 68,000  short tons  per year;  120 HSS  cells;  37 SWPB cells;  3 CWPB
      Jointly  owned  by  National  Aluminum Company and Southwire Company.
01    e!00  percent  interest  by  Howmet  Corporation.

     Jointly owned  by  Revere  Copper  & Brass,  Inc

     950 percent interest by Howmet Corporation; 50 percent interest by Amax Aluminum Company.
 Jointly owned by Revere Copper & Brass,  Inc.  and  Consolidated  Aluminum  Corporation.

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     In selecting sites for primary aluminum reduction plants,
producers have had to consider several  factors that affect production
cost.  Three principal  factors are:
     1.  Costs for shipping the major raw material, alumina, to the
         reduction plant site,
     2.  Electrical energy costs for reducing alumina to aluminum
         in the reduction cells;, and
     3.  Costs for shipping aluminum to the fabricator or to the
         market.
     Alumina consumed by U. S. primary  producers  is manufactured in
the south central U. S., in South America, and in the West Indies and
Australia.     Although  principal fabricator sites are found in the
Northeast and the Midwest and in California,   the availability of
low cost hydroelectric  power has been the overriding factor in plant site
selection and has resulted in the location of plants in such areas as the
                                                 18
Pacific Northwest and the Tennessee River Valley.    Moderate cost steam-
generated power  has attracted several plants to the Ohio River Valley,
closer to the Northeast and Midwest markets.
     Most of the aluminum reduction plants in the United States are
located in predominantly rural areas with a sparse population density,
as estimated by  the total population of towns or cities within a 10-mile
radius of each plant given in 1960 or later census figures.
     Table 3-2 shows the distribution of plants with respect to
population.
                               3-7

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      Table 3-2.   DISTRIBUTION  OF  PLANTS  BY  POPULATION,  1971
                                                            19
Number
of plants
13
9
2
7a
Percent
capaci ty
41.1
28.7
5.7
24.5
Surrounding 300-mi> area
Population
Less than 10,000
10-25,000
25-50,000
More than 50,000
Population/mi^
Less than 32
32-80
80-160
More than 160
      One plant is surrounded by residential  sections  in  an  urban
      community.   The other six plants  in the high  density areas
      are located on the outskirts of medium  sized  communities  where
      the surrounding land is utilized  for dairy farming  or  truck
      farming.
     The distribution of plant capacity with  respect to the  type of
surrounding land  use is shown in Table  3-3.
3.2  FUTURE TRENDS
3.2.1  Domestic Industry and Plant Growth
     Primary aluminum production in the U.  S.  started in 1888.   Table 3-4
shows the yearly U. S.-primary aluminum production since 1893,  the date
of the-earliest recorded data.  Primary aluminum production has'experienced
a steady, but somewhat cyclical, growth pattern.  Average annual produc-
tion growth rates have been:  14;5 percent for'the period 1893  to 1973:,
9.5 percent for the quarter century 1946 to'1971;  7V5  percent  for"
the decade 1961 to 1971  ; and 6.9 percent for the decade 1963 to .1973.'
     The cyclical growth pattern has given rise to periods of excess
capacity.  For the past few years, the industry has been in a period of
low profitability because of excess capacity,  but indications are that
excess capacity and inventories are being eliminated.  This should lead
                                     22
to higher prices and greater profits.
                              3-8
20,21

-------
Table 3-3.  ESTIMATED DISTRIBUTION OF PLANTS BY ENVIRONMENT
                                                           19
Environmental category
Urban

Orchard growing
Dairy farming
Truck farming
Cattle raising
Lumbering
General agriculture
Dairy plus truck farming
Dairy plus cattle

Dairy plus agriculture
Dairy plus lumber
Truck farming plus cattle
Truck farming plus lumber
Truck farming plus general
agriculture
Lumber plus general
agriculture
Truck farming plus
cattle plus general
agriculture
Total
i
\ Number
; of
| plants
j -
!
i «
i 3
i «
\ 1
j
i '
\
i
; 2
] _ 2
i
i i
1
i -1
i 1
1 1
i 4
; 1
i
i 1
i
i
1
! 3
! 31
Percent of total U. S.
aluminum capacity in
envi ronmental category
5.5

15.4
9.4
10.9
1.9
5.6
2.4
6.3
4.4

3.0
1.7
3.0
11.3
3.5
4.7
11.0
100.0
                         3-9

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Table 3-4.  PRODUCTION OF PRIMARY ALUMINUM  IN THE UNITED  STATES
                                                                20
Year


1893
1894
1895
1896
1897
1898
1899
1900
1901
1902
1903
1904
1905
1906a
1907
1908
1909
1910
1911
1912
1913
1914
1915
1916
1917
1918
1919
1920
Production,
IbxlO6


0.2
0.5
0.5
1.0
2.4
3.0
3.3
5.1
5.8
5.8
6.6
8.1
10.8
14.1
16.3
10.7
29.1
35.4
38.4
41.8
47.3
58.0
90.5
115.1
129.9
124.7
128.5
138.0
Year
1921
1922
1923
1924
1925
1926
1927
1928
1929
1930
1931
1932
1933
1934
1935
1936
1937
1938
1939
1940
1941
1942
1943
1944
1945
1946
1947
1948
1949
1950
Production,
lbxlQ6
54.5
73.6
128.5
150.6
140.1
147.4
163.6
210.5
228.0
229.0
177.5
104.9
85.1
74.2
119.3
224.9
292.7
286.9
327.1
412.6
618.1
1,042.2
1,840.4
1,552.9
990.1
819.3
1,143.5
1,246.9
1,206.9
1,437.2
Year
1951
1952
1953
1954
1955
1956
1957
1958
1959
1960
1961
1962
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976
1977



Production,
lbx!06
1,673.8
1,874.7
2,504.0
2,921.1
3,131.4
3,357.9
3,295.4
3,131.1
3,908.2
4,029.0
3,807.4
4,235.9
4,625.1
5,105.5
5,509.0
5,936.7
6,538.5
6,510.1
7,586.1
7,952.3
7,850.4
8,244.8
9,058.2
9,806.9
7,758.3
8,512.8
9,077.4



Data prior to 1907 represent fiscal years ending August 31
during last 4 months of 1906 totaled 5.4 million pounds.
Production
                           3-10

-------
     At the end of 1972, U. S.  primary capacity was 4.8 nillion  short
tons, and it has been estimated that domestic aluminum needs  will
require a capacity increase to  7.2  million short tons by 1980.
(The capacity increase will not necessarily be all  domestic.) This
                                                    23
estimate is based on the following four assumptions:
     1.  Growth in demand averaging 7.5 percent per year between
         1971 and 1980.
     2.  Mill imports, secondary recovery, and primary imports at
         the same percentage level in 1980 as in 1972.
     3.  Stockpile sales of 77,000 tons per year in 1980, based  on  the
         current General Services Administration disposal schedule.
     4.  Industry operating ratio of 95 percent.
     The anticipated increase represents an average annual  capacity
growth rate of 5.2 percent for  the period 1972 to 1980.  Growth  in
consumption of aluminum has generally been quoted at 6 to 8 percent
over the period 1972 to 1980.    The fact that capacity growth is
forecast to be less than consumption growth reflects the present
excess capacity.  Applying a 5.2 percent growth rate to capacity for
the period 1980 to 1985 results in a capacity increase to 9.2 million
short tons by 1985.  Applying a 7 percent growth rate results in a
capacity increase to 10.1  million short tons by 1985.
     The EPA standards of performance for new primary  aluminum plants
are not expected to have an adverse impact upon future growth in the
                                   25
domestic primary aluminum industry.
                              3-11

-------
     Table 3-5 shows the gradual  increase in the average capacity of
primary aluminum plants in the U.S.  since I960.3'4'26  Although the
average capacity stood at 158,000 short tons per year in 1973, the
seven plants built from 1970 to 1973 have capacities of 35,000;
70,000; 87,000; 112,000; 120,000; 120,000; and 180,000 short tons per
year.  The average capacity for these seven plants is thus only 104,000
short tons per year.

Table 3-5.  GROWTH IN PRIMARY ALUMINUM PLANT AVERAGE CAPACITY IN U.S.3'4'26
Year
1960
1967
1973
Number
of plants
22
24
31
Annual capacity, short tons x lO^/year
Total
2468.8
3321.0
4893.0
Average
112.2
138.4
157.8
      As  for  future changes in average plant size, no new plants are
 known to be  under construction as of the end of 1974.  A lead time of
 about 3  years  is needed for construction of a new plant.23  Hence, if
 the  anticipated growth rate is to be met by increased U.S. capacity,
 it seems likely that much of the immediate capacity increases will
 probably be  in the form of expansions, thus further increasing the
 average  plant capacity.
                               3-12

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3.2.2  Plant Location and Cell  Type

     No pronounced geographical shifts in the location of primary
aluminum plants have occurred since 1966.  Plants continue to be
located mainly near sources of low-cost power in the Pacific
Northwest and the Tennessee and Ohio River Valleys; however, most
of the available hydroelectric power in the U.S. has now been
harnessed.  Greater use of nuclear and nonnuclear steam-generated
power could result in any future U.S. primary aluminum plants beino
located closer to the marketplace.
     Table 3-6, which summarizes U. S. trends in cell  design since World
                                                %
War II, shows that the primary aluminum industry favored adoption of
Soderberg cells during the 1950s but that the present trend is toward
prebake cells.  This trend is expected to continue since new prebake
cells should be able to meet EPA standards of performance for new
primary aluminum plants (see Section 1.3) more easily and less
                                      28
expensively than new Soderberg plants.
3.2.3  New Producers and Technology
     It appears that unless government regulation intervenes, aluminum
                                                                        29
producers may become part of multi-material industries by the mid-1980s.
Aluminum would most likely become allied with two of its strongest competitors,
steel and plastic.  One steel company has already become a primary
aluminum producer.  Also, some aluminum fabricators have accomplished or
are considering backward integration into primary aluminum.  Furthermore,
there appears to be a trend for foreign producers to establish primary
plants in the U. S. to gain easy access to U. S. markets.

                              3-13

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                               Table 3-6.   U.  S. TRENDS  IN ADOPTION OF CELL TYPES
                                                                                 27

pre - 1946
1946
1947 - 1950
1951 - 1958
1959 - 1965
1966 - 1969
1970 - 1972
Prebake plants
Installations
New
-
-3a
lb
4
1
1
6
Cumulative
10
7
8
12
13
14
20

Expansions
-
-
-
2
-
1
2C
Soderberg
Horizontal stud
Installations
New
-
-
-
3
1
-
-
Cumulative
2
2
2
5
6
6
6

Expansions
»
-
-
2
-
2
-
plants
Vertical stud
Installations
New
-
-
-
3
-
-
1
Cumulative
-
-
-
3
3
3
4

Exnansinns
-
-
-
-
-
2
-
GO
I
      Government-owned (DPC) plants deactivated.


     5One DPC plant reactivated under private ownership.
     •»

     'Estimated.

-------
     From its inception over 80 years ago, the U. S.  primary aluminum
industry has relied upon the Bayer process for refining bauxite ore
and the Hall-Heroult process for electrolytically reducing alumina to
aluminum.  The Bayer process discharges air and water pollutants;
the Hall process discharges air (notably fluoride) and sometimes water
pollutants.  The Hall process uses huge amounts of electricity and
requires huge capital investments.  The Bayer-Hall processes have  made
the U. S. largely dependent on foreign sources of bauxite ore.  In spite
of these disadvantages, technology has not changed because alternate
processes have shown higher production costs than the Bayer-Hall
processes and because bauxite ore has been in adequate supply.  Improve-
ments in the Bayer-Hall processes have made it more difficult for
alternate processes to compete economically.  However, it now appears
that it may not be long before other processes can compete, and the day
will come when available bauxite will no longer support the world's demand
for aluminum.
     Efforts to find alternate processes have generally fallen into
three classes:
     1.  Production of alumina from non-bauxite ores.
     2.  Direct reduction of bauxite or non-bauxite ore to aluminum.
     3.  Conversion of alumina to aluminum by means other than
         electrolytic reduction in a cryolite bath.
     Non-bauxite ores that have been considered for commercial development
in the U. S. include:  high-alumina clay; dawsonite;  aluminous shales;
alunite; aluminum phosphate rock; igneous rock, notably anorthosite;  and
saprolite- and sillimamte-group minerals.    The Poles are presently
                             3-15

-------
using high-alumina clay commercially and the Russians are using alunite
and an alumina-containing igneous rock known as nepheline syenite.  It
appears that high-alumina clay is the most likely candidate for
                                   31
commercial development in the U. S.
     U. S. and foreign producers have experimented with various
methods of directly reducing bauxite or non-bauxite ore to aluminum.
Applied Aluminum Research Corp.* has announced that it is developing
the Toth Process by which non-bauxitic ores are directly reduced to
aluminum.  The process involves conversion of the ore to aluminum
chloride, purification, reaction of aluminum chloride with manganese
to produce aluminum and manganese chloride, and regeneration of the
manganese.
     Alcoa has announced the development of a process involving the
conversion of conventionally made alumina to aluminum trichloride
and subsequent electrolytic reduction to yield aluminum metal and
                    32
recyclable chlorine.    This method, known as the Alcoa Smelting
Process, reduces electric power requirements by 30 percent.
3.3  PRICE STATISTICS
     Table 3-7 gives average list prices  of virgin  primary aluminum
                                          33 34
ingot for selected years from 1930 to 1969  »   and closing New York
                                                                 1  35
cash prices for selected dates from August 1970 to  February 1975.  '
*Mention of specific companies or products in this document does not
constitute endorsement by the U.S. Environmental  Protection Agency.
                              3-16

-------
     Table 3-7.   PRIMARY  ALUMINUM  INGOT  PRICE  HISTORY
                         (cents  per pound)
Year
1930
1932
1937
1941
1944
1947
1950
1951
1953
1957
1959
1961
1964
1967
1968
1969
Average
List Price
23.8
23.3
20.1
16.5
15.0
15.0
17.7
19.0
20.9
27.5
26.9
25.5
23.7
25.0
25.6
27.2
Date
8/13/70
8/13/71
10/18/72
12/31/72
3/25/73
5/29/73
8/1/73
10/18/73
12/31/73
3/25/74
5/29/74
7/31/74
8/1/74
10/74
12/74
2/25/75
Closing New York
Cash Price
29.0
29.0
25.0
25.0
25.0
25.0
25.0
25.0
29.0
29.0
31.5
33.5
36.0
39.0
39.0
39.0
The table shows that the price increased dramatically from October

1973 to October 1974, and has levelled out since then.  It is also

obvious that increased production costs are being passed on to the

consumer.
3.4  REFERENCES FOR SECTION 3

1.  Survey of Current Business.  Bureau of Economic Analysis,  U.  S.
    Department of Commerce.  Washington, D.  C.  5J?:S-33, Januerv 1975.

2.  Aluminum Statistical Review 1973.  The Aluminum Association.
    New York, N. Y.  p. 52.
                            3-17

-------
3.  Reference 2, above, pp. 32-33.

4.  Reference 2, above, p. 34.

5.  Reference 2, above, p. 16.

6.  U.S.  Industrial Outlook with Projections to 1980.  Domestic and
    International Business Administration, U.S. Department of
    Commerce, Washington, D.C. 1974 edition, p. 77.

7.  Air  Pollution Control in the Primary Aluminum Industry.  New York,
    N.Y.  Singmaster and Breyer.  Prepared for Office of Air Programs,
    U.S.  Environmental Protection Agency, Research Triangle Park, N.C.,
    under Contract Number CPA 70-21.  July 23, 1973.  p. 2-22, 2-23.

 8.  Letter from  Dr. P. R. Atkins, Aluminum Company of America,
    Pittsburgh,  Pa. to D.R. Goodwin, Emission Standards and Engineering
    Division, OAQPS,  Environmental Protection Agency, Research Triangle
    Park, N.C.,  dated June 20, 1974.

 9.  Personal  communication from Dr. P. A. Atkins, Aluminum Company of
    America,  Pittsburgh, Pa. to B. A. Varner, Emission Standards and
    Engineering  Division, OAQPS, Environmental Protection Agency,
     Research  Triangle Park, N.C., June 25, 1974.

10.   Letter from  Dr.  B. S.  Hulcher, Reynolds Metals Company, Richmond, Va.
    to D. R.  Goodwin, Emission Standards and Engineering Division, OAQPS,
    Environmental Protection Agency, Research Triangle Park, N.C., dated
    June 28,  1974.

11.  Letter from  K. Cyr, Anaconda Aluminum Company, Louisville, Ky. to
     D. R. Goodwin, Emission Standards and Engineering Division, OAQPS,
    Environmental Protection Agency, Research Triangle Park, N.C.,
     dated June 21, 1974.

12.  Letter from  J.  L. Loyer, Howmet Corporation, Greenwich, Conn, to
    D.R. Goodwin, Emission Standards and Engineering Division, OAQPS,
    Environmental Protection Agency, Research Triangle Park, N.C., dated
    October 31,  1974.

13.  Letter from  W. F. Boyer, Jr., Consolidated Aluminum Corporation,
    Lake Charles, La. to B. A. Varner, Emission Standards and Engineering
    Division, OAQPS,  Environmental Protection Agency, Research Triangle
    Park, N.C.,  dated June 25, 1974.

14.  Letter from  J. L. Byrne, Martin Marietta Aluminum, to D.R. Goodwin,
    Emission  Standards and Engineering Division, OAQPS, Environmental
    Protection Agency, Research Triangle Park, N.C., dated October 10,
    1974.

15.  Farin, P. and G.  G. Reibsamen.  Aluminum, Profile of an Industry.
    New York, N.Y., Metals Week, McGraw-Hill Inc., 1969. p. 153.

                               3-18

-------
16.  Reference 15, above, p. 25.
17-  Reference 2, above, pp. 37-39.
18.  Reference 15, above, p. 148.
19.  Reference 7, above, p.  2-28,  2-29.
20.  Reference 2, above, pp. 30-31.
21.  Aluminum Statistical Review 1971.   The Aluminum Association.
     New York, N.Y.  p. 30.
22.  Background Information for Standards of Performance:   Primary
     Aluminum Industry.  Volume 1: Proposed Standards.   Emission
     Standards and Engineering Division, OAQPS, Environmental
     Protection Agency, Research Triangle Park, N.C.  October  1974.
     p. 64.
23.  Reference 22, above, p. 78.
24.  Hamilton, W. F., Trip  Report:  Meetings Held in Washington, D.  C.
     and New York City on March 28 - 29, 1973 to discuss Aluminum
     Industry.  Strategies  and Air Standards Division,  OAQPS,  OAWP,
     Environmental Protection Agency, Research Triangle Park,  N. C.
25.  Reference 22, above, p. 93.
26.  Aluminum Statistical Review 1970.   The Aluminum Association.
     New York, N. Y.  pp. 8, 16.
27.  Reference 7, above, p. 3-17-
28.  Reference 22, above, pp. 74-76.
29.  Reference 15, above, p. 164.
30.  Reference 15, above, p. 163.
31.  Reference 15, above, pp. 154-156.
32.  New Processes Promise  Lower Cost Aluminum.  Chemical  and  Engineering
     News.  51_(9):11-12,  February  26, 1973.
33.  Minerals Yearbook.   Bureau  of Mines,  U.S.  Department of the
     Interior.   Washington,  D.C.
34.  Metal  Statistics,  The Purchasing Guide of  the Metal Industries.
     The American Metal  Market Company.   New York, N.Y.
35.  Cash Prices.   The  Wall  Street Journal.  August  16,  1971; October 19,
     1973;  January 2,  1974;  March 26, 1974; May 30,  1974; August 2,  1974;
     February 26, 1975.
                                3-19

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                      4.  PROCESS DESCRIPTION

4,1  PRIMARY ALUMINUM REDUCTION ]"5

     All primary aluminum in the United States is produced by
electrolytic reduction of alumina (AlgOg)—the Hall-Heroult
process.  Alumina, an Intermediate product, is produced by the
Bayer process from bauxite, a naturally occurring ore of hydrous
aluminum oxides and hydroxides containing 45 to 55 percent AlgO-j.
The production of alumina and the electrolytic reduction of alumina
to aluminum are  seldom accomplished at the same  geographical  loca-
tion.
     Alumina is shipped to the reduction plant where it is reduced
to aluminum and oxygen by direct electric current (Figure 4-1).  This
reduction is carried out in shallow rectangular cells (pots) made of
carbon-lined steel with carbon blocks that are suspended above and
extend dov/n into the pot (Figure 4-2),  The pots and carbon blocks
serve as cathodes and anodes, respectively, for the electrolytical
process.
     Cryolite, a double fluoride salt of sodium and aluminum
(NaJ\lFg), serves as an electrolyte and a solvent for alumina.
Alumina is added to and dissolves in the molten cryolite bath.  The
cells are heated and operated between 950° and 1,000°C with heat
that results from resistance between the electrodes.  During the
reduction process, the aluminum is deposited at the cathode where,
                                       3                3
because of its heavier weight (2.3 g/cm  versus 2.1 g/cm ), it
                              4-1

-------
                                                                                       REDUCTION
                                                                                         PLANT
i
ro
                 RAW MATERIAL
                 (SHIP OR RAIL)
ALUMINUM
 SHIPMENT
                                                                           POWER
                                                      Figure 4-1. Aluminum reduction process.

-------
                                        DIRECT CURRENT
CO
                                                                                              MOLTEN CRYOLITE BATH,
                                                                                                               CARBON
                                                                                                              CATHODE
                                             Figure 4-2.  Aluminum reduction cell diagram.

-------
 remains as a molten metal layer underneath the cryolite.  The
 cryolite bath thus also protects the aluminum from the atmosphere.
 The  byproduct "oxygen migrates to and combines with the consumable
 carbon anode to form carbon dioxide and carbon monoxide, which
 continually evolve from the cell.
     Alumina and cryolite are periodically added to the bath to
 replenish material that is removed or consumed in normal operation.
 The  weight ratio of sodium fluoride (NaF) to aluminum fluoride
 (AlFo) in cryolite ts 1,50.  However, it has been found that adding
 excess AlFo to reduce the bath ratio to 1.30 to 1.45  will increase
 cell current efficiency and lower the bath melting point permitting
 lower operating temperatures.  Fluorspar, or calcium fluoride, may
 also be added to lower the bath melting point.
     Periodically, the molten aluminum is siphoned or "tapped" from
 beneath the cryolite bath, moved in the molten state to holding
 furnaces in the casting area," and fluxed to remove trace impurities.
 The  product aluminum is later tapped from the holding furnaces and
 cast into ingots or billets to await further .processing or shipped
 molten in insulated ladles.
     The reaction:
     A12 03 + 1 1/2 C ^ 2A1 + 1 1/2 C02                          (4.1)

absorbs  261.9  kcal per gram mole of alumina reacted at 1000°F, which
 is equivalent to 2.56 kilowatt-hours (kwh) of energy per pound of
 aluminum produced.   In actual practice, however, some energy is used
 to bring the reactants (including the carbon anode) up to temperature
                               4-4

-------
and is lost in the byproduct gas stream, with the tapped aluminum,
and to the building.  The latter occurs principally through the low
temperature heat leak provided by the molten aluminum layer beneath
the cryolite bath.  A small portion of the molten aluminum mixes
with the bath and is carried to the anode where it is oxidized back
to alumina, reducing some of the carbon dioxide to carbon monoxide.
(Much of the hot carbon monoxide is oxidized back to carbon dioxide
upon contacting air.)  This reduction absorbs additional energy, and
practically the total cell energy requirement is from 6 to 9 kwh per
pound of aluminum produced.  Furthermore, although the stoichiometric
carbon requirement by equation (4.1) is 0.33 pound per pound of
aluminum produced, the reduction of carbon dioxide to carbon monoxide
increases the carbon requirement to about 0.50 pound per pound of
                  7 8
aluminum produced, '
     A typical late design cell may operate at 100,000 amperes and
4.5 volts (450 ktlowatts), producing 1540 pounds of aluminum per
day for an energy consumption of approximately 7 kwh per pound of
                  q
aluminum produced.
     A large number of cells are linked together electrically in series
to form a potline, the basic production unit of the reduction plant.
The potline may be housed in one or two long ventilated buildings
called potrooms.   A typical plan view of a potroom in schematic
form is shown in Figure 4-3.  A typical elevation might be as shown
in Figure 4-4.  The pots may be arranged end to end or side by side.
The roof "monitor" or ventilator shown in Figure 4-4 usually
                               4-5

-------
                1000 TO 1600 FEET-
O
ss
(A
      ooo
             ooo
              lOQiOOOO
         CELLS
                                       o
DDOI 'D(]DE:::::JD
       OOO
        SCRUBBERS
             ooo
           Figure 4-3. Typical plan view of potroom.10
 SCRUBBER

          \
                  POTROOM
             CELL
                 |      I
                 I PLENUM  |

                 I	J
                          ROOF
                          MONITOR

                          CELL
                                    SCRUBBER
          Figure 4-4. Typical elevation view of potroom.1"1

                    4-6

-------
runs the length of the building and serves the important function
of releasing the heat lost from the pots to the building air,  thus
maintaining workable conditions around the pots.  Outside air  may
be introduced to the potroom through side vents, or forced through
a central floor plenum, or both.
     The "process" of primary aluminum reduction is essentially
one of materials handling.  It can be shown schematically as a flow
diagram such as Figure 4-5.  The true difference in the various
process modifications used by the industry lies in the type of
reduction cell used.  Three types of reduction cells or pots are
used in the United States:  prebake  (PB), horizontal stud
Soderberg (HSS), and vertical stud Soderberg (VSS).  Both Soderberg
cells employ continuously formed consumable carbon anodes where the
anode paste is baked by the energy of the reduction cell itself.
The prebake cell, as indicated by its name, employs a replaceable,
consumable carbon anode, formed by baking in a separate facility
called an anode bake plant, prior to its use in the cell.
     The preparation of anode materials is usually an ancillary
operation at the reduction plant site.  Figure 4-6 is a typical
flow diagram for the preparation of prebake anodes.  In the carbon
plant, or "green mill", coke is crushed and sized; cleaned, returned
anode butts are crushed; and both are mixed together with pitch and
molded to, form self-supporting green anode blocks.  Figure 4-6 shows
solid coal tar pitch moving to a crusher.  The pitch may not  be coal
tar, and it may be received and handled as a liquid.  The green anode
blocks are fired and baked in a pit baking furnace, or ring furnace.
Subsequently, a steel or  iron electrode is bonded into a preformed hole

                               4-7

-------
        r
       Ul
       II
       gl
   BALL
   MILL
   VIBRATING
    SCREEN
      l£
 "I
     BALL
     WILL

                 AIR
               CLASSIFIER
     PRESS
UU--
 I	I
 r
      OVEN     —  — — — —
 I	I
NEEDED FOR PREBAKED
   PROCESS ONLY
CRYOLITE
NaF, AIF3
 CaF2
      Figure 4-5. General flow diagram for primary aluminum reduction.12
                                4-8

-------


BUTTS


\-
r
-/

MIXER
                               u
                             I"   "
         .COOLING
         CONVEYOR
                             MOLDING
                              PRESS
                                                                    O
                                                               WATER
COOLING
 TOWER
i
                                                                        PRECIPITATOR
                                                                                   STACK
                                                                • TO POTLINE

            Figure 4-6.  Flow diagram for preparation of prebake anodes.13
                                       4-9

-------
in each block.  The electrode serves as an electrical connector and
holds the anode in place in the bath.  The ring furnace operation
comprises the anode bake plant.  A second typa of furnace, the
tunnel kiln, has also been developed for baking anodes.
     The preparation of Soderberg anode material is similar to that
for prebake cells, except that the pitch is always liquid, the anode
paste is not molded and baked prior to cell usage, and no anode
material is returned from the cells to the carbon plant.
     Since the potrooms housing the reduction cells and the prebake
anode bake plant are the facilities affected by the standards of per-
formance for new primary aluminum plants and attendant State plans for
controlling existing plants, the different cell types and the bake plant
merit further consideration.  Process items specific to each are dis-
cussed  in the following sections.

4.2  PREBAKE PROCESS
     Prebake cells use a number of anodes suspended in the
electrolyte, in essence the original design of the Hall-Heroult
process,  The anodes are press-formed from a carbon paste and are
baked in a ring furnace or tunnel kiln.
4.2.1  Anode Bake Plant
                     14 15
4.2.1.1  Ring Furnace  '  --The ring furnace consists of compartmentalized,
sunken, brick baking pits with surrounding interconnecting flues.
Green anodes are packed into the pits, with a blanket of coke or
anthracite filling the space between the anode blocks and the walls
                               4-10

-------
of the pits.  A 10- to 12-inch blanket of calcined petroleum coke
fills the top of each pit above the top layer of anodes.  The
blanket helps to prevent oxidation of the carbon anodes.
     The pits are fired with natural gas-fired or oil-fired
manifolded burners for a period of about 40 to 48 hours.  The flue
system of the furnace is arranged so that hot gas from the pits being
fired is drawn through the next section of pits to gradually preheat
the next batch of anodes before they are fired, in turn, when the
manifold is progressively moved.  Air for combustion is drawn through
the sections previously under fire, cooling them down.  The anodes
are fired to approximately 1,200°C, and the cycle of placing green
anodes, preheating, firing, cooling, and removal is approximately
28 days.
     Firing of sections proceeds down one side of the rectangular
furnace building and back the other in a "ring" pattern.  Proceeding
around the building, the pattern of sections cooling down, sections
under fire, sections heating up, and empty sections is repeated
several times.
     Ring furnaces use outside flues under draft, and since the flue
walls are of dry-type construction, most volatile materials
released from the anodes during the baking cycle (principally
hydrocarbons from the pitch binder) are drawn, with the combustion
products of the firing, into the flue gases where they are burned
at about 1300°C.15
                               4-11

-------
     Flue gases may be passed through fluoride scrubbers and perhaps
electrostatic precipitators to reduce temperature and scrub or co-
precipitate out a portion of the hydrocarbons before exhausting to
a stack.
     The furnace buildings spanning the lines of baking pits are
usually open at the side and ventilated through gravity roof
monitors without emission controls.
     The baked anodes are stripped from the furnace pits by means
of an overhead crane on which pneumatic systems for loading and
removing the coke pit packing may also be mounted.  The packing
may  subsequently become part of other green anodes in the carbon
plant.15

4.2.1.2 Tunnel Kiln  --A second type of furnace, the tunnel kiln,
has  been developed for application in the baking of anodes.  The
kiln is an  indirect-fired chamber in which a controlled atmosphere
is maintained  to prevent oxidation of the carbon anodes.  Green
anode blocks are loaded on transporter units that enter the kiln
through an  air lock,  pass successively through a preheating zone, a
firing  zone, and a cooling zone, and leave the kiln through a
second  air  lock.  The refractory beds of the cars are sealed
mechanically to the  kiln walls to form the muffle chamber, and yet
permit  movement of the units through the kiln.
                            4-12

-------
     The muffle chamber is externally heated by combustion gases,
and the products of combustion are discharged through an independent
stack system.
     Effluent gases from the baking anodes may be introduced into
the fire box so as to recover the fuel  value of hydrocarbons and
reduce the quantity of unbunned hydrocarbon to approximately 1
percent of that coming from a ring furnace.  Further reduction  of
solid and gaseous emissions may be achieved by the use of heat
exchangers, scrubbers, and electrostatic precipitators.
     Although the tunnel kiln presents  mechanical problems in design
and operation, it is reported to have several appreciable advantages
over the ring type of furnace:
     1.  Baking cycle from green to finished anode is much shorter.
     2.  Anode baking is more uniform.
     3.  Space requirements for equal capacity furnaces is less.
     4.  Smaller gas volumes are handled through the furnace
         emission control  system.
     The successful development of the  tunnel kiln in this application
is recent, and to date only one installation is in normal operation.
     Baked anodes are delivered to air  blast cleaning machines
utilizing fine coke as blasting grit.  Fins, scrafs, and adherent
packing is removed by this treatment, and the baked anodes are  then
transferred to the rodding room where the electrodes are attached.
                             4-13

-------
4.2.2  Reduction Cells17'18
     Figure 4-7 shows a sectional view of a typical prebake (PB)
reduction cell  with a hood for collection of cell  emissions.
     Prebake cells use up to 26 anode assemblies per cell, which
are attached to the anode bus on the cell superstructure by means of
clamps.  The anode bus is attached to the steel superstructure by
anode jacks that may be driven by an air motor or by other means,
giving a travel of from 10 to 14 inches and permitting the raising
or lowering of all 26 assemblies in the cell simultaneously.  Each
of the 26 assemblies may also be raised or lowered individually
by means of an overhead crane after the anode clamp is loosened.
     The anodes are lowered as they are consumed,  typically at a
                             18
rate of about 1 inch per day.    When the anodes are completely
spent, they are removed and replaced on a rotating basis, usually
a pair at a time.  The total operating time before replacement is
dependent on the size of the anode blocks and the  amperage of the
potline.
     The anode assemblies are usually installed in two rows
extending the length of the cell.  In some arrangements the two
rows are closely spaced in the center of the cell, providing a
working area on each side of the cell between the  cell side lining
and the anodes (sfde-worked).  In other cases, the rows are separated
and placed closer to the cell side lining, providing the working
area in the center of the cell between the rows of anodes (center-
worked) .
                               4-14

-------
                      ALUMINA
                       HOPPER
               ELECTROLYTE
      GAS COLLECTION
         HOOD
 SOLIDIFIED CRUST
OF ELECTROLYTt AND
    ALUMINA
STEEL SHELL
INSULATION
CARBON LINING
                     MOLTEN ALUMINUM
       GAS COLLECTION DUCT
ANODE BUS BAR
     CARBON ANODE
       GAS & FUME EVOLVING
               CATHODE
            COLLECTOR BAR
                                                                   BUS BAR
                   Figure 4-7.  Details of prebake reduction cell.18
      The general  trend in prebake anode design  has  been toward
 larger anode  blocks,  obtaining greater effective anode/cathode
 surface ratios  and lower current densities  at the anodes for
 equivalent power  inputs.
 4.3  SODERBERG CELLS18'19'20
      There are two  types of Soderberg cells,  each  having a single
 large carbon anode, but differing in the method  of anode bus
 connection to the anode mass.  In both the  vertical  stud Soderberg
 CVSS) and the horizontal stud Soderberg (HSS),  a green anode paste
 is fed periodically into the open top of a  rectangular steel
 compartment and  baked by the heat of the cell to a solid coherent
 mass as the material moves down the casing.
                                  4-15

-------
     In both types of Soderberg cells, the in-place baking of the
anode paste results in the release of hydrocarbon fumes and
volatiles derived from the pitch binder of the paste mixture.  These
products are a component of the Soderberg cell emissions and are
essentially absent from those of the prebake cells.  If not removed
from the gas stream, the pitch components will condense in and
plug subsequent doctwork and emission control devices.
     Although the Soderberg cells require more electrical energy to
produce a given weight of metallic aluminum and create problems
in emission control, they were acclaimed initially because they did
away with the need for a separate anode manufacturing facility.
     Partially because the volatile pitch components can condense
in the ductwork and the control device, and partially because
of .the problems of simultaneously controlling fluorides and organic
emissions, any economic advantage of the Soderberg systems is
diminishing and the trend appears to be toward the prebake cell.
     Furthermore, although prebake cells may be center-worked or
side-worked, .the use of a single large carbon anode requires that
both types of SoderBerg cells be side-worked.  As will be discussed
in Section 6.1, center-worked cells lend themselves to more
efficient hooding and hence more efficient emission control.

4.3.1  Vertical Stud Reduction Cells
     Figure 4-8 shows a sectional view of a typical vertical stud
Soderberg reduction cell.  The anode casing is stationary, the
electrical connection from, the  studs  to  the bus  bar is  rigid,  and
                             4-16

-------
                        STUDS
            ANODE CASING
BUS BAR
RISERS
ANODE PASTE
BAKED ANODE
           SKIRT
SOLIDIFIED CRUST
OF ELECTROLYTE
AND ALUMINA

STEEL SHELL
CARBON LINING
ELECTROLYTE
MOLTEN ALUMINUM
              TO GAS
         . », TREATMENT
              PLANT
         BURNER
         GAS AND TAR BURNING
         GAS EVOLVING
          CATHODE
          COLLECTOR
            BAR
           THERMAL
          INSULATION
             Figure 4-8.  Details of vertical stud Soderberg reduction cell.18
  the steel  current-carrying  studs  project vertically through  the
  unbaked paste portion and into  the baked portion of the anode.   As
  the anode is consumed and moves down the casing, the bottommost
  studs are periodically extracted  before they become exposed  to  the
  bath at the bottom of the anode.
       The stationary anode casing  and the projection of the studs
  through the top of the anode  allow the installation of a  gas
  collection skirt between the  anode casing and the bath surface.
  The gases are ducted to integral  gas burners where the hydrocarbon
  tars are burned to gaseous  fractions that do not interfere with
  the operation of subsequent pollutant removal equipment.
  Maintenance of the skirt system is a problem, however.
  Irregularities in cell operation  can extinguish the burner flame,
  and the skirts may melt or  be deformed by the heat.  Pilot lights
  can help ensure that the burners  stay lighted.
                             4-17

-------
4.3.2  Horizontal Stud Reduction Cells
     Figure 4-9 shows a sectional view of a typical horizontal
stud Soderberg reduction cell.  The anode, suspended over the pot,
is contained in a rectangular compartment made of aluminum sheeting
and perforated steel channels that is raised or lowered by means
of powered (jacks.  The entire anode assembly is moved downward as
the working surface is oxidized.  Studs are inserted into the anode
through 3-inch perforations in the steel channels at a point about
3 feet or so above the molten bath where the paste is still fairly
soft.  Electrical contact is through flexible connectors between
the studs and the bus bar.  As the anode is moved downward, the
paste bakes solid and grips the stud.  When the bottom channel reaches
the bath, the flexible connectors are moved to a higher row of studs,
the studs in the bottom row are pulled out, and the bottom channels
are removed.
     The construction of the HSS cell prevents the installation of
an integral gas collection device such as a skirt, since the anode
casing is formed by removable channels supporting the horizontal
stud electrodes, and these channels are periodically changed as the
anode moves downward and is consumed.  Hooding is restricted to
canopy suspension, resulting in so much air dilution that self-supporting
combustion in burners is not possible.  The hydrocarbon tars thus
condense in the ductwork and tend to plug pollutant removal
equ i pment.
                               4-18

-------
ALUMINA HOPPER -
FULLY BAKED ANODE
                       ,— REMOVABLE
                       \  CHANNELS

                      —1\
SOLIDIFIED CRL'-f
 OF ELECTROLYTE
 AND ALUMINA

STEEL SHELL
INSULATION
CARBON LINING
                          ELECTROLYTE
GAS COLLECTION DUCT

       ANODE PASTE

         POT
    ENCLOSURE DOOR

    PARTIALLY BAKED
        PASTE

       ANODE STUDS

      GAS AND FUME
        EVOLVING


   MOLTEN ALUMINUM


         CATHODE
         COLLECTOR
           BAR
          Figure 4-9.  Details of horizontal stud Soderberg reduction cell.18
  4.4  REFERENCES  FOR  SECTION 4


  1.  Air Pollution  Control  in the Primary Aluminum Industry.   Sinqmaster
      and Breyer,  New  York,  M.Y.  Prepared for Office of Air Pronrams,
      Environmental  Protection Agency, Research Trianqle Park,  M.C.,  under
      Contract Number  CPA 70-21."  July 23, 1973.  p. 3-1, 3-2,  3-6  to 3-10,
      3-16, 3-18 to  3-23.

  2.  Background Information for Establishment of National Standards
      of Performance for  New Sources. Primary Aluminum Industry.
      Environmental  Engineering, Gainesville, Florida.  Prepared  for
      Air Pollution  Control  Office, Environmental Protection Agency,
      Durham, N.C.,  under Contract Number CPA 70-142, Task Order
      No. 2.  (Draft Copy dated March 15, 1971).  p. 2-1 to 2-8.

  3.  Shreve, R. N.  Chemical Process Industries. 3rd Ed.  New  York,
      N.Y., McGraw-Hill Book Company, 1967.  pp. 246 - 250.

  4.  Robinson, J. M.  et  al.  Engineering and Cost Effectiveness  Study
      of Fluoride  Emissions  Control.  Resources Research, Inc.  and
      TRW Systems  Group,  McLean, Va.  Prepared for Office of Air
      Programs, Environmental Protection Agency, Durham, N.C.,  under
      Contract Number  EHSD 71-14.   January 1972.  p.  3-13,  3-15,  3-17.
                                 4-19

-------
 5.   Background  Information  for  Standards  of  Performance:   Primary
     Aluminum Industry.   Volume  1:  Proposed Standards.   Emission
     Standards and  Engineering Division, OAQPS,  Environmental
     Protection  Agency,  Research Triangle  Park,  N.C., Ockober  1974.
 6.   Reference 1, above,  p.  3-1, 3-2.
 7.   Reference 3, above,  p.  246.
 8.   Reference 4, above,  p.  3-17.
 9.   Reference 1, above,  p.  3-6, 3-8.
10.   Reference 2, above,  p.  2-5.
11.   Reference 2, above,  p.  2-6.
12.   Reference 2, above,  p.  2-8.
13.   Reference 1, above,  p.  3-20.   (Modified)
14.   Reference 1, above,  p.  3-21.
15.   Varner,  B.  A.,  Trip  Report:  Trip  to  Alcoa  (Badin, N.C.)
     Aluminum Plant, Standards Development and Implementation
     Division, SSPCP, Environmental  Protection Agency, Research
     Triangle Park,  N.C.   August 21, 1972.
16.   Reference 1, above,  p.  3-22.
17.   Reference 1, above,  p.  3-10, 3-12.
18.   Reference 2, above,  p.  2-9,  2-10.
19.   Reference 1, above,  p.  3-12, 3-13, 3-16.
20.   Reference 2, above,  p.  2-11.
                              4-20

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                     5.   FLUORIDE EMISSIONS1
     Pollutants emitted from primary aluminum plants include fluorides,
particulates, hydrocarbons (organics), sulfur oxides, carbon monoxide,
and nitrogen oxides.  EPA tests have shown nitrogen oxide levels to
be insignificant.  Although significant levels of sulfur oxides and
carbon monoxide can be emitted, control technology has not been
demonstrated and adequate source test data defining emission levels
have not been obtained for these two pollutants.  On the other hand,
fluoride control has been demonstrated and characterized through EPA
source tests.  These tests have also shown that, if fluorides are"
well controlled, the resulting incidental control of particulates and
organics will be good.  For these reasons , the EPA standards of per-
formance for new primary aluminum plants  are  stated in terms  of
fluoride.   Likewise, discussion of emissions,  control  techniques, economic
impact and emission standards  in this document is restricted to fluorides
except where other pollutants  have a bearing  on cost or performance.
5.1  POINTS  OF  EMISSION1'2
     The  principal  points of  fluoride  emission  are the  primary and
secondary emissions  from  the  potrooms  housing  the  reduction  cells
and, in the  case  of the prebake  cell,  the  emissions  from  the associated
anode  bake plant.   Figure 5-1  shows  these  emission points from a
prebake plant with  an  anode ring furnace.  The  anode  bake plant,
together  with  its emissions,  is  not  part of the  Soderberg plant.
     Figure  5-2 shows  how the reduction  cells  are  hooded  and how  the
evolved gas  stream  is  ducted  to  a primary  control  device  exterior to
                            b-1

-------
CJ1
I
PO
                       SECONDARY EMISSIONS
                          PREBAKE CELL POTROQM
                                                                                    X-  ^-x^^^^^   •>.

                                                                                          ANODE RING
                                                                                           FURNACE
                                                                                                                 BAKE PLANT
                                                                                                                 EMISSIONS
EMISSION
 CONTROL
EQUIPMENT
                                            Figure 5-1.  Prebake plant with anode ring furnace.

-------
                                                                                                                                PRIMARY EMISSIONS
                                                                        SECONDARY EMISSIONS
cn
 i
CO
                                               Figure 5-2.  Potroom fluoride emission balance.

-------
the potroom.  Emissions from this device are termed primary emissions.
That portion of the evolved gas stream that escapes the hooding passes
to the monitor in the roof of the potroom, where there may or may
not be a secondary control device.  Emissions from the building are
termed secondary emissions.
     For potroom emissions, the overall control efficiency (OCE) may
be expressed as:

                  OCE = VV+  ° - V)nsc"sr                    (5J)
where:  n   =  Primary collection  efficiency
        n   =  Primary removal efficiency
        n   =  Secondary collection efficiency
         s c
        n   =  Secondary removal efficiency
      Some plants  in  the United States employ both primary and secondary
 removal equipment.   However, the  majority of plants do not have secondary
 equipment,  relying on efficient primary collection (good hooding) to
 obtain  high overall  control efficiencies.  For these plants, n   =0
 and  equation  (5.1) reduces to:

                           OCE=  VV                             (5-2)
     A  few  U.  S. plants  employ only secondary removal equipment.
 For  these plants, n   = 0 and equation (5.1) reduces to:

                           OCE =  nscnsr                             (5.3)
 Although secondary collection efficiency might be assumed to be 100
 percent in  this scheme, deficiency in the design of the provisions  for
                                5-4

-------
air intake to the buildings may bring about a reduction in the collection
efficiency.  Some potline buildings have openings in the sidewalls at
working floor level through which ventilation air enters as shown in
Figure 5-3.  This air is supposed to sweep past the cells and up
through the roof monitor collection system, but adverse winds may blow
through the buildings in such a way as to carry potline emissions out
through wall openings in the buildings, thus short circuiting the
collection system and reducing its efficiency.  Figure 5-4 shows a
building arrangement that helps to avoid this short circuiting of the
collection system.  Fresh air is drawn into the building below the working
floor level and is allowed to pass up through gratings past the cells
to the monitor collection system.
     For the more general case of primary plus secondary control, if
it is assumed that all secondary emissions are from the roof monitor,
then:

                             nsc = 1.0                             (5.4)

 and  equation  (5.1)  can  be  written  in  terms  of three  variables:

                    OCE = VV + ° " V)nsr                    (5'5)
 Equation  (5.5)  is the expression of OCE  that will  be used  in
 discussing retrofit control  techniques  (Section  6).   However,  the
 aforementioned  limitation  on secondary collection  efficiency because of
 short circuiting should be kept in mind.
     Fluoride  is lost from  the potroor in other ways  besides  the
 airborne  primary and secondary emissions.   Figure  5-5  shows  a fluoride
                              5-5

-------
      INDUCED DRAFT FAN
                                          ROOF MONITOR SPRAYS
      Figure 5-3.  Room collection system, sidewall entry.3
ROOF MONITOR SPRAYS
INDUCED DRAFT FAN
                                                             FLOOR GRATING
      Figure 5-4.  Room collection system, basement entry.3
                             5-6

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RECOVERED
 SOLIDS
               16
               44
  CRYOLITE
 ALUMINUM-
  FLUORIDE
               24
  CALCIUM <
  FLUORIDE
               2.8
                              PRIMARY
                                AIR
                              EMISSION
                                  4.2
                             SPRAY
                             SCRUBBER
                             WET
                             REMOVAL
                                  38.4
                              MULTIPLE
                              CYCLONE
                              DRY
                              RECOVERY
                                  54.4
SECONDARY
    AIR
 EMISSION
                                                 10.8
          34.2
 WATER
 EFFLUENT
> - IMPOUNDED.
 LOST,  OR
 RECOVERED
 AS CRYOLITE
                                                10.8
                                    POTROOM
                                                           20
                                                                 •»- POT LININGS
                                                           1.6
                                                                 -»•- SPENT BUTTS
      Figure 5-5.  Specific prebake potroom fluoride balance (balance values
      in pounds of total fluoride per ton of aluminum produced).4
                                    5-7

-------
balance, in pounds of total  fluoride per ton of aluminum produced,
                                  A
around a specific prebake potroom.    This particular plant has no
secondary removal equipment.   Its primary removal  equipment consists
of multiple cyclones for dry recovery of particulate fluoride followed
by spray scrubbers to remove most of the gaseous fluoride and some
particulate fluoride.  This  level of control is neither representative of
best demonstrated control technology for new plants nor of best retrofit
for existing plants.
    For the potroom shown in Figure  5-5, approximately 65 of the 87
pounds of fluoride (or 75 percent of the total) added to the pots is
released in the potroom emissions.   About 20 pounds is absorbed into the
pot cathode linings and 1.6  pounds  adheres to the  anode butts.  The butts
are returned to the carbon plant (see Figure 4-6)  and the linings may
be treated to recover cryolite after their useful  life (about 3
years).
    Of the approximately 54 pounds directed to the primary removal
equipment, only 16 pounds are recovered and returned directly to the
pots. About 34 pounds end up in the scrubber water discharge.  This
 large quantity of fluoride may be discharged directly with  the  plant
effluent,  treated to remove most of the  fluoride  content  and then
 discharged, or sent  to  a cryolite recovery  plant  for further process-
 ing.   Zero  fluoride  water discharge  is  difficult to attain  with  any
of these alternatives.
      Although the airborne primary  emission is  only  about 4  pounds,
the relatively low primary collection efficiency  (83.4  percent) and
the lack of any secondary removal equipment for the  specific potroom
                             5-8

-------
result in a secondary emission of about 11  pounds,  for  a  total emission
of 15 pounds and an overall control efficiency of only 77 percent
of the 65.2 pounds generated.
  5.2  UNCONTROLLED EMISSIONS - SOURCE, CHARACTERISTICS, AND
      MINIMIZATION
  5.2.1   Reduction Cells  (All Types)5'6
      Fluorides  are  emitted  from  the  reduction  cell  as particulates
  and  gases.
  5.2.1.1   Parti oilates-~Particulates  originate  from  the volatilization
  of the  cryolite bath with subsequent condensation,  from mechanical
  entrainment  of  bath material by  the  air  sweep  over  the cell surface,,
  and  from  dusting of raw materials  during the raw material feeding
  operations.
      The  largest particulate component is alumina.   Fluoride
  components that have been identified include cryolite (Na,AlFg),
  aluminum  fluoride (A1F-), calcium  fluoride  (CaF^),  and chiolite
  (Na5Al3F,.). Other  non-fluoride  particulates are carbon,  hydrocarbon
  tars, and iron  oxide (Fe203).  It  is estimated that fluorides
  comprise  10  to  25 percent of the total particulates.
      Reported determinations of  particle size  distributions in
  primary uncontrolled cell emissions  are  plotted in  Figure 5-6.
  Two  plots are shown for prebake  potlines, one  reported as the
  average of four samples of  pot emissions, the  other as the average
  of five samples of  electrostatic precipitator  intake.  A  single  plot
                              5-9

-------
   100a
E
3.

Ul
N

co
1
             95
                     90
  WEIGHT PERCENT LARGER PARTICLES


80    70   60    50  40    30    20
                                                                        10
                     10
                                                                        90
                                                                               95
                                                                                        100
                                                                                     — 0.2
20    30    40    50   60   70    80


WEIGHT PERCENT SMALLER PARTICLES


                                INDUSTRY REPORTED DATA
                                                                                        0.1
•8
      Figure 5-6.  Particle size weight distribution of potline primary cell emissions.8

                                          5-10

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of average samples is shown for HSS.  No comparable data have been
obtained for VSS emissions.
     These plots are illustrative of the comparative size
characteristics of the'primary dusts from two types of cells.
The slopes of these data give an indication of the range of particle
sizes in the samples, and the placement of the curves on the plot
indicates that a substantial fraction of the prebake and HSS
particulate weight is submicron, or in the range where particulate
removal efficiencies of most equipment are low.
     A more recent determination of particle size distributions
in primary uncontrolled HSS cell emissions is shown in Figure 5-7.
For this study:   (1)  The mass mean particle diameter was 5.5 micro-
meters  (pm).   (2)  The  geometric standard  deviation was  quite hioh
(around 25).   (3)  Thirty percent by mass of the particles were less
than 1 ym and 16 percent were less than 0.2 pm in diameter.  (4)  The
mass mean particle diameter and the standard deviation were  lower,
and the particle mass concentration was higher when the  cell crust
was unstable (gas vents).  (5)  Increasing the air collection flow
rate increased the mass mean particle diameter, but the  particle
mass concentration remained the same.   (6)  The fraction of  particles
less than 0.5 um decreased as the distance from the cell increased
in the primary cell  gas collection duct.
     Published or reported particle size distribution data are
sparse and techniques for measurement are  subject  to variations,
even among different investigators  using similar equipment,  so
caution should be exercised in drawing  conclusions from  these data
or in comparing data from one source with  those from another.
                            5-11

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                          WEIGHT PERCENT LARGER PARTICLES
                        80    70   60    50    40    30     20
                                        10
0.
                 10
20    30    40   50   60    70     80
  WEIGHT PERCENT SMALLER PARTICLES
                                                                  90
                                                                         95
                                                                                  0.1
98
     Figure 5-7  Particle size weight distribution of HSS primary cell emissions.9
                                         5-12

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5.2.1.2  Gases—The principal gases emitted from the reduction cell
are carbon monoxide and carbon dioxide.   Gaseous fluoride components
present during normal operation include hydrogen fluoride (HF) and
silicon tetrafluoride (SiF^).  Other gaseous, non-fluoride components
are sulfur dioxide (S02), hydrogen sulfide (H2S), carbonyl sulfide (COS),
carbon disulfide (CS2), and water vapor.   During an anode effect
(discussed below), fluorocarbons, principally carbon tetrafluoride (CF^)
                                                                            o
and very small amounts of hexafluoroethane (CoFg), are known to be produced.
     Thermal hydrolysis of volatized bath materials appears to be
responsible for a substantial part of the hydrogen fluoride found in
reduction cell fumes.  This reaction of solid or vaporized fluorides at
elevated temperatures takes place primarily at the point where the hot
gases escape through vents in the crust at the cell surface.
     A source of hydrogen is necessary for the generation of hydrogen
fluoride.  Water vapor in the air is a contributor of part of this hydrogen.
Other sources include residual moisture in alumina and bath raw materials,
and hydrocarbons in the carbon anodes.  Generation of HF increases with
increased cell operation temperature.
     Some gaseous hydrogen fluoride is removed from the reduction cell
fumes by interaction with the contained particulate matter.  Chemical
reaction is responsible for some of this pickup, and some is the result
of chemisorption, absorption, and adsorption.
5.2.1.3  Composition and Quantity—Although the determination of total
fluoride content of fumes may be quite reliable, estimates of the distri-
bution of fluoride between gaseous and particulate forms is subject to

                            5-13

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uncertainty because of such factors as the degree of thermal hydrolysis
during burning of the gases and the method of separation of gases  and
particulates during sampling.  One study reports that the ratio of gaseous
to particulate fluoride in reduction cell fumes varies over a  range of
about 0.5 to 1.3.10  These values are given for fumes that have burned
in contact with air.  Weighted average data obtained in a data
acquisition questionnaire indicate that this ratio is about 1.2 for
prebake cells, 1.7 for HSS cells, and 3.0 for VSS cells with  integral
    bur
    10
gas burners.     Unburned fumes  usually show a lower rationof about
0.3.
     The rate of uncontrolled total fluoride emissions (evolution or
generation) also varies over a wide range, from 25 to 65 pounds per
ton  (Ib/ton) of aluminum produced.  Section 5.3.1 gives the range and
average evolution for each cell type.
     The effective control of emissions from an aluminum reduction
potline involves attention to:
     1.   Operating conditions  in  the cells.
     2.   Collection of pollutants  from the cells.
     3.   Removal of pollutants from the collected streams.
Uncontrolled emission minimization through proper operation will now
be discussed.  Items (b) and (c) will be taken up in Section  6.
     The quantity and composition of uncontrolled emissions can
be strongly influenced by operating conditions such as temperature,
                                 5-14

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bath ratio, frequency of anode effects, and method of crust breaking.
Moreover, it may vary with time for any given plant, because of
gradual changes that may occur in potline operations.
5.2.1.4  Normal Operation—Under normal cell operation, experimental
work established correlations between three cell operating parameters
and the level of fluoride generation for a 10,000 ampere laboratory
experimental prebake type aluminum reduction cell.    It was shown that
increasing bath ratio (NaF/AlF.J, increasing alumina content of the
bath, and decreasing the bath temperature combine to effect a decrease
in the fluoride generated.  These effects would be expected from the following
principles of physical chemistry:  (a) A1F- is more volatile than NaF and
tends to be driven off as its relative amount increases; (b) decreased
temperature decreases the evolution of all volatiles, including A1F,;
and, (c) the addition of alumina should tend to increase aluminum ions
concentration in the melt, which may decrease fluoride ion concentration
by a mass action effect.  This effect would change fluoride ions into A1F3.
Fluoride ions in the bath are probably not volatile, but A1F- is volatile.
Table 5-1 summarizes the findings of these tests.

                Table 5-1.  EXPERIMENTAL EFFECT OF THREE OPERATING
                       VARIABLES ON FLUORIDE GENERATION12



Bath ratio
(1.44 to 1.54)
1.50
1.50
Range of variable

Alumina Temperature
content, % °C
4 975
(3 to 5) 975
4 (982 to 972)

Fluoride
level,
% decrease
31
20
24
                             5-15

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     The report of the above experimental  work calls attention to the
fact that "determination of the effect of operating variables on the
fluoride emission from electrolytic reduction cells is difficult to
accomplish with a high degree of certainty.  This is true even with
small-scale experimental cells operated by research personnel.  It
appears from the work reported here, however, that cell temperature,
bath ratio, and alumina concentration are the most important variables
                                   12
affecting total fluoride emission."
     It should be noted that the researchers did not carry out an
exhaustive study of all the variables that could affect fluoride
emissions.  Also, the absolute relationships reported may not hold
for  full-scale cell operation.
5.2.1.5   Process Interruption—Normal cell operation is interrupted by
occasional anode effects, cell working to introduce alumina feed, and
periodic  tapping of molten  aluminum.  Cells may also be operated at
elevated  temperatures in a  "sick" condition.  Normal operation of prebake
cells  is  interrupted  by the periodic changing of anodes, and normal
operation of VSS cells  can  be  interrupted by a "stud blow."
     Tapping and changing anodes cause moderate increases in fluoride
evolution, depending  upon how  much  of the molten electrolyte is
exposed.   Anode  effects, operation  at elevated temperatures, cell working,
and stud  blows can cause significant increases in fluoride evolution and
will now  be examined  in some detail.
5.2.1.5.1  Anode effects—Normally  a cell operates with about  2  to  5
percent of alumina in solution in the bath, but as  the electrolysis
proceeds  the alumina  content is decreased, being intermittently  replenished
                                                                          •
                            5-16

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by feed additions.  When this content falls to about 1.5 to 2.0 per-
cent the phenomenon of an "anode effect" occurs.   It is  believed  that
at this alumina concentration the bath fails to wet the  carbon anode
and a gas film of CF^ collects under the anode.  This film causes a
high electrical resistance, the normal cell voltage increases 10
to 15-fold, and the power input to the cell increases more than 10-
fold.  To correct the condition the cell crust must be broken and
more alumina added to bring the concentration back to its normal
content.  The gas film under the anode is dispersed and  the cell
returns to normal voltage.
     The power increase to the cell is converted into heat, which in
turn raises the temperature of the cell electrolyte.  At the
higher cell temperature, the fluoride evolution is increased.  For
the anode effect evolution rate compared with quiet cell operation,
        1 ^
one study    found  a  27-fold  increase  in  solid  F  and a 2.7-fold
increase in  HF.  Another study    determined  that  the normal fluoride
evolution from a crusted-over cell is approximately 30 pounds of  fluoride
per ton of aluminum produced, but during an anode  effect the fluoride
evolution  rate increases  to  approximately  756  Ib/ton of aluminum.
     Depending on the promptness with which the cell operator reacts,
this anode effect may last from 3 to 15 minutes.   Occasionally
cell operators will deliberately allow anode effects to  continue  in or-
der to soften an unusually hard crust.  Automatic  crustbreakers help
to minimize the need for this practice.  In normal cell  operation
                             5-17

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with manual crust breaking, the frequency of anode effects  is  from less
than 1/2 to as many as 6 anode effects per cell-day.
     The frequency of anode effects can be reduced to  the range  of 1/2
to  1 anode effect per cell-day by placing cells on an  anode effect
suppression system.  Workings  of  the  cell are  scheduled so  that  the
alumina content of the electrolyte is replenished before it falls  below
the concentration causing the anode effect.  The newer computer-controlled
potlines may operate almost free from anode effects.
5.2.1.5.2  Elevated temperature operation--The  higher  the bath temperature,
the more will the bath salts vaporize and be carried into the  cell  emissions.
Normal  operating temperatures  for cells with a  bath ratio of approximately
1.40 are between 970 and 980 °C.  Abnormal or  "sick" cells  operate at
temperatures  in excess of 1000 °C and sometimes they do not crust  over.
Under  these conditions, the high-temperature molten electrolyte  is
exposed, and  there is a large  increase in volatilization of bath salts
with a corresponding increase  of  fluoride.  Operation  of cells at
the lowest possible temperature to minimize fluoride emissions requires
trained, conscientious cell operators or computer control.
     The temperature of the cell may be lowered by adding lithium-
salts  to the  electrolyte to lower its freezing  point,  but the  net
benefit of these additions is  the subject of controversy.   One foreign
investigator   reports among other advantages,  a substantial decrease
of fluoride losses in waste gases, which resulted in a reduction of
fluoride emissions.  In this country, experiments undertaken by  a  major
producer were reported to have demonstrated an  increase in  fluoride
emissions  upon adding lithium  salts.
                                 5-18

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     The electrolyte system is complex, and electrolyte conditions
which reduce fluoride emissions from the molten bath, but which
simultaneously destroy the ability of the bath to crust over and
carry a cover of alumina, may result in a net increase in cell em'ssions;
the alumina cover intercepts a substantial quantity of fluoride and
returns it directly to the molten bath.
5.2.1.5.3  Cell  working, mechanization, and computer control--Breaking
the crust of the cell for a cell  working causes the fluoride evolution
rate to rise to approximately 106 Ib/ton of aluminum.    The duration
of a cell working varies according to the size and type of the cell  and
whether the cell is equipped with automatic crust breakers.   With the
automatic crust breaker on a prebake cell, working is accomplished quickly,
taking only 1 or 2 minutes.  For a normal-size prebake cell  of approximately
90,000 amperes, a manual working may be accomplished in 5 to 10 minutes
depending upon the hardness of the crust.  Soderberg cells and side-
worked prebake cells are normally worked by means of a pneumatic crust
breaker similar to a paving breaker.  A working may be accomplished in
approximately 5 minutes on a 90,000-ampere side-worked cell.
     Mechanization of crust breaking and cell feeding allows the cell
operators time to maintain close watch over the operating cells and
to control  them within narrow temperature ranges.  The overall effect is
lower average operating cell temperature, fewer and briefer anode effects,
and a reduction  in the fluoride content of cell off-gases compared with
normal  manual cell operation.
     Full mechanization of reduction cells makes it possible to apply
computer control, which incorporates the frequent scanning of operating
                                5-19

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variables on each cell  and the triggering of automatic corrective
action for any variation that is outside set operating limits.  Such
control makes it possible for all cells in a potline to be operated
at the lowest practical temperature and with nearly complete freedom
from upsets caused by anode effects.  Cell feeding and crust breaking
operations can be cycled in response to the needs of individual cells,
and the number of abnormal or "sick" cells usually associated with
manual potline operation can be reduced.  Variations in cell operation
caused by having different shift personnel tending the cells over the
24-hour period are largely avoided.
     Many plants are developing various degrees of computer control in
combination with mechanization.  Full automation has been satisfactorily
accomplished  on at least one plant.
5.2.1.5.4   VSS stud blows—An abnormal occurrence that can increase
emissions from a VSS cell  is a  stud blow.  (See Section 4.3.1 for a
process  description of the VSS  cell).  This abnormality happens when the
steel, current-carrying studs are  not extracted before being exposed
to  the bath at the bottom  of the anode.   Stud blows can last up to an
hour  before the  unbaked paste portion of  the anode eventually covers
over  the  exposed area.  Stud blows  can be prevented by proper operator
attention.
5.2.2  Anode  Bake Plant
      Uncontrolled fluoride emissions from anode bake plants originate from
the recycled  anode butt scraps  that carry absorbed or adherent  bath
materials  (principally cryolite) back into the anode cycle.  The  fluorides

                                    5-20

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are incorporated into the green anode paste and released during the
subsequent baking process.   (See Sections 4.1  and 4.2 for further
process information.)
5.2.2.1  Ring Furnace--Although the physical  state of the fluorides
evolved from the ring furnace has not been thoroughly investigated,
it is believed that most of the fluorides evolved are gaseous at the
elevated operating temperature.  (Combustion  temperature is around
1300°C.)
     The fluoride balance in Figure 5-5 shows  1.6 pounds of fluoride
recycled with the butts  per ton of aluminum produced.  An emission
level of 1.6 Ib/ton represents emissions that can be expected when
adherent cryolite is simply knocked off the butts at the potroom prior
to sending them to the anode plant.  It is reported that fluoride
emissions can be maintained at less than 0.4  Ib/ton (a four-fold
reduction) by exercising particular attention to cleaning the spent
anode butts.
     The principal ring  furnace emissions are solid products of firing
combustion (smoke) and burned and unburned hydrocarbons derived from
the heating and carbonizing of the paste binder pitch.  Some S02 and
sulfur trioxide (SO.,) is derived from the sulfur in the coke.  Visible
emissions can be reduced by:
     1.  Using natural gas  instead of oil to  fire the furnace,
     2.  Preventing leakage of cold air into  the sections under
         fire, and
     3.  Not locating the exhaust manifold too far from the sections
         under fire.
                                  5-21

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5.2.2.2  Tunnel  Ki"ln--A1 though the direct-fired ring furnace  has  been
the normally used type for prebake anodes, attention has  been given  to
the development of continuous tunnel kilns for this purpose.   (See
Section 4.2.1.2 for a process description of the tunnel kiln.)
Combustion conditions are significantly different and zonal temperature
control closer, with one result being a reduction in the  emission of
fluorides by a factor of 0.02,16 or to a level of <_ 0.03  Ib/ton of
aluminum produced.  Drastic reductions in the emission levels of  other
ring furnace pollutants are also achieved.
     Test data on tunnel kilns are old.  Emission criteria developed for
tunnel kilns should be based on new sampling data collected by prescribed
EPA methods, or other methods.
5.2.2.3  Production Bases—The above discussion of  fluoride emissions
is based on weight of fluoride emitted per weight of aluminum produced.
This generally involves converting the weight of carbon anode produced
to the equivalent weight of aluminum produced.  The proper method for
performing the calculation is given in the primary  aluminum Standards
                                          18
of Performance for New Stationary Sources.    The weight  of total
fluoride emitted per unit of time is divided by the weight of anode
produced per same unit of time.  This ratio is divided by 2 or some
other proven factor representing the ratio of the weight  of aluminum
produced to the weight of anode consumed.

5.3  TYPICAL FLUORIDE EMISSIONS AND EXTENT OF CONTROL
5.3.1  Reduction Cells  (All Typed)
     Figure 5-5 shows a total fluoride balance around a specific  pre-
bake potroom that has no secondary removal equipment.  The plant's
                           5-22

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primary removal  equipment consists of multiple cyclones followed by
spray scrubbers.   The total  fluoride emission level  is 15 Ib/ton of
aluminum produced.  This emission level  is typical  of a poorly controlled
prebake, VSS, or HSS potroom.
     Table ">2 gives a range of cell evolution for center-worked prebake
(CWPB), side-worked prebake (SWPB), VSS  and HSS plants.  The table also
shows average evolution, average total primary plus  secondary emissions,
and overall control efficiencies for all  31 U.S.  plants and for the 29
plants comprising the controlled segment of the industry; one CWPB and
one SWPB plant are uncontrolled.  The ranges and averages in Table 5-2 are
computed directly from existing control  combinations shown in Table 7-2.
     Table 5-2 shows wide ranges of cell  evolution,  particularly for
CWPB plants.  Average evolution is highest for SWPB  and VSS plants
being about 10 Ib/ton higher than for HSS plants and nearly 5 Ib /ton
higher than for CWPB plants.  Inclusion  of the uncontrolled SWPB plant
lowers SWPB overall control  efficiency much more than does inclusion
of the uncontrolled CWPB plant lower CWPB efficiency, because the SWPB
plant accounts for a much larger percentage of its respective total cell
type capacity.
     In 1970, an EPA contract study determined overall control efficiencies
                                   2
for the domestic aluminum industry.   Compared to Table  5-2, efficiencies
for the controlled segment of the industry were 8 percent lower for
prebake plants,  13 percent lower for HSS plants, and 9 percent lower for
VSS plants.    Overall control efficiency for all plants, controlled and
                                  19
uncontrolled, was 8 percent lower.    The improvement in overall
control from 1970 to 1975 demonstrates existence of a potential for
emission reduction.
                                 5-23

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                         Table  5-2.  POTROOM TOTAL FLUORIDE EMISSIONS IN U.S.,  1975
Cell Typea
CWPB
SWPB
HSS
VSS
All Cell
Types
Range of
Evolution,
Ib F/ton Al
25.7 - 65.6
37.3 - 53.0
28.4 - 45.0
30.5 - 53.5
25.7 - 65.6
Controlled and Uncontrolled Plants
Average
Evolution,
Ib F/ton Al
40.8
44.7
34.0
44.4
40.4
Average
Emission,
Ib F/ton Al
6.3
13.0
5.7
5.2
7.0
Overall
Control
Efficiency, %
85
71
83
88
83
Controlled Plants Only
Average
Evolution,
Ib F/ton Al
40.8
43.9
34.0
44.4
40.2
Average
Emission,
Ib F/ton Al
4.6
4.8
5.7
5.2
5.0
Overall
Control
Efficiency, %
89
89
83
88
88
en
ro
    CWPB -- center-worked prebake cells, SWPB — side-worked prebake cells, VSS -- vertical stud Soderberg
   cells, HSS -- horizontal  stud Soderberg cells.

-------
     Table  5-3  shows  the  extent of control  in the domestic industry
by cell  type.   The  percentages  are computed directly from the collected
control  status  information  that was used to construct Table 7-2.  The
table shows that  CWPB plants  have the greatest potential  for improving
primary  control.  It  also shows that secondary control  is not employed at
any CWPB or HSS plants.   By comparison,  the aforementioned contract study
determined  that,  in 1970, only  31  percent of capacity had best primary
                                                                  20
control  and only  4  percent  had  best primary and secondary control.

                   Table  5-3.   EXTENT OF POTROOM CONTROL, 1975
Annual
Capacity, At Least
Cell Type tons Al Primary Control
CWPB
SWPB
HSS
VSS
All Cell
Types
2,704,000
738,000
1,045,000
635,000
5,122,000
95
81 b
100
100
95
Percentage of Capacity Having:
At Least Best Best Primary Control
Primary Control + Secondary Control
61
79b
83
100
73
0
59
0
33
11
  CWPB -- center-worked  prebake  cells,  SWPB -- side-worked prebake cells,
  VSS -- vertical stud Soderberg cells,  HSS -- horizontal  stud Soderberg
  cells.
  Or, secondary control  with  equivalent overall  control  efficiency.
                                     5-25

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5.3.2  Anode Bake Plant
     Table 5-4 gives a 1970 breakdown of evolved and emitted participate,
gaseous, and total fluorides on a pounds per ton of aluminum basis and
                                                         19
resultant overall control efficiencies for ring furnaces.    The breakdown
                                  2
is based on an EPA contract study.   The data in this study are based on
reported data on furnace gases, the control equipment identified in
individual bake plants, and estimated control efficiencies ascribed to
these control systems.  The evolved total fluoride emission factor of
0.86 Ib/ton lies between uncontrolled emission factors of 1.6 Ib/ton
representative of poor cleaning of the anode butts and of 0.4 Ib/ton
representative of proper cleaning.  (See Section 5.2.2)  According to
Table 5-4, 95 percent of the evolved and emitted ring furnace fluorides
are gaseous.
     It is estimated that prebake plants representing about 43 percent
of bake plant capacity have some sort of emission control, much of it
             21
experimental.     It is estimated that spray scrubber control can achieve
96 percent removal efficiency on gaseous fluorides and 75 percent removal
efficiency on particulates and that 40 percent of bake plant capacity
have this level of control.
     Tunnel kilns are reported to produce much lower emissions than ring
furnaces  (See Section 5.2.2).  However, the proportion of prebake anode
capacity  baked in tunnel kilns in 1970 was small enough  (about 7
percent)  that to  ignore them in the above discussion does not affect the
limited accuracy of the calculations.
                                     5-26

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    Table 5-4.   RING  FURNACE  FLUORIDE  EMISSIONS IN U.S., 1970
                                                             19
                                        Controlled and uncontrolled
                                                 furnaces
Gaseous fluoride
     Evolved,  Ib/ton  Al
     Emitted,  Ib/ton  Al
     Overall  control  efficiency,
0.816
0.483
   41
Particulate fluoride
     Evolved,  Ib/ton Al
     Emitted,  Ib/ton Al
     Overall  control efficiency,
0.044
0.024
   45
Total fluoride
     Evolved,  Ib/ton Al
     Emitted,  Ib/ton Al
     Overall  control efficiency,
0.859
0.507
   41
     Primary  aluminum  is  a  significant contributor of atmospheric

                    22
fluorides.  One  study   estimated that aluminum accounted for 13.5

percent of  total  fluoride atmospheric emissions from major industrial

sources in  1968.   Section 9.1  gives potroom and anode bake plant annual

total  U.S.  fluoride  emissions, as well  as  annual  particulate emissions.
                               5-27

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5.4  REFERENCES  FOR  SECTION  5


1.   Background  Information  for  Standards of Performance:  Primary
     Aluminum Industry.   Volume  1:  Proposed Standards.  Emission
     Standards and Engineering Division, OAQPS, Environmental
     Protection  Agency,  Research Triangle Park, N.C.  October 1974.

2    Air  Pollution  Control  in the  Primary  Aluminum  Industry.   Singmaster
     and  Breyer,  New York,  N. Y.   Prepared for Office of Air  Programs,
     Environmental  Protection Agency, Research Triangle  Park,  N.  C. ,
     under  Contract Number  CPA  70-21.   July  23,  1973.  p. 3-3 to 3-6,
     3-25,  5-5  to 5-7, 8-9, 8-13.

3.    Reference  2, above, p. 5-6.

4.    Reference  2, above, p. 3-4.

5.    Reference  2, above, p. 4-2 to 4-9, 5-1  tn 5-4.

6.    Background Information for Establishment of National Standards  of
      Performance for New Sources.  Primary Aluminum  Industry.  Environmental
      Engineering, Gainesville,  Florida.  Prepared for Air Pollution  Control
      Office, Environmental  Protection Agency, Durham, N. C.,  under Contract
      Number CPA 70-142,  Task  Order No.  2.  (Draft Copy dated March 15, 1971).
      p. 3-3 to  3-4.

 7.    Reference  2, above, p. 4-2.

 8.    Reference  2, above, p. 4-6.

 9.    Hanna, T.  R. and M. J. Pilat.  Size Distribution of Particulates
      Emitted from a Horizontal  Spike Soderberg Aluminum Reduction Cell.
      J. Air Pol. Contr.  Assoc.  2^:b33-b3b, July iy72.

 10.   Henry, J.  L.  A Study  of Factors Affecting Fluoride Emission from
      10 KA Experimental  Aluminum Reduction Cells.  In:  Extractive
      Metallurgy of Aluminum.   New  York, Interscience Publishers, 1963.
      pp.  67-81.

 11.   Reference  2, above, p. 7-4 to 7-6.

 12.   Reference  2, above, p. 4-9.

 13.   Less,  L. N. and  J.  Waddington.  The Characterization of Aluminum
      Reduction  Cell Fume.  In:   Light Metals.  New  York, Proceedings
      of Symposia, 100th  AIME  Annual Meeting, March  1-4, 1971.

 14.   Miller, S. V.  et al.  Emission of  Fluorine Compounds From Electro-
      lysis  Cells in the  Production of Aluminum.  Sverdlovsk Nolich,
      Issled Inst.
                                 5-28

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15. Wendt, G.  Operating Experiences With Electrolytes Containing
   Lithium Fluoride.  IMS of AIME Paper No. A70-39, February 16, 1970.

16. Reference 2, above, p. 4-11.

17. Varner, B. A., Trip Report:  Trip to Alcoa (Badin, N. C.) Aluminum
   Plant.  Standards Development and Implementation Division, SSPCP,
   Environmental Protection Agency, Research Triangle Park, N. C.
   August 21, 1972.

18. Title 40 - Protection of Environment.  Subpart S - Standards of
   Performance for Primary Aluminum Reduction Plants.  Federal Register.
   39(206):37732, October 23, 1974.

19. Reference 2, above, p. 7-13.

20. Reference 2, above, p. 9-11 to  9-21.

21. Reference 2,  above, p. 7-2.

22. Biologic Effects  of Atmospheric Pollutants:   Fluorides.   National
   Academy of  Sciences,  Washington, D.  C.   Prepared for Environmental
   Protection  Agency, Durham,  N.  C., under  Contract Number  CPA 70-42.
   1971.   p. 9.
                                5-29

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 6.   CONTROL TECHNIQUES  FOR  POTROOM AND ANODE BAKE PLANT FLUORIDES

     Section 6.1  discusses potroom retrofit primary collection systems,
and explains in detail a method for calculating hooding efficiencies for
each of the four  cell  types.   The calculated efficiencies are shown to
agree well witn those  given  by several  plant operators, and are important
in later development of  the  State guidelines for existing primary aluminum
plants.
     Section 2 discusses potroom and anode bake plant removal equipment,
both in general terms.   It is  difficult to generalize about retrofit
controls for this industry since costs  and methods of emission control
vary widely from  plant to plant.  Hence, Section 6.3 gives three detailed
and seven capsule case descriptions for potroom retrofits at ten actual
plants.  These descriptions  cover nine  best primary control retrofits
and two best secondary control retrofits, but the plants selected do not
necessarily typify all domestic plants.
     Finally, Section  6.4 discusses the length of time needed to install
fluoride controls at existing  primary aluminum plants.
6.1   POTROOM RETROFIT  PRIMARY  COLLECTION SYSTEMS1"6
     For potroom  emissions,  overall control efficiency (OCE) was expressed
in Section 5.1 as:
     OCE = VV     + (1  -  V)nsr                       (5'5)
where:  r\    =   Primary collection efficiency
         pc
        TI    =   Primary removal efficiency
        n    =   Secondary removal efficiency
         sr
                                 6-1

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     The best retrofit primary removal equiorient  characteristically have
high total  fluoride primary removal efficiencies,  generally 98 percent or
greater.  Secondary removal equipment characteristically have total fluoride
secondary removal efficiencies no higher than 75  percent and many plants
have no secondary control.   Hence a high overall  control  efficiency greatly
depends on an efficient primary collection system.
     Primary collection systems include the hooding devices  installed
at the reduction cells, the individual cell ducting to  common headers
serving groups of cells, and the main ducting leading to the primary
removal equipment.  This section discusses hooding design,  presents an
experimental method for calculating primary collection  efficiency,  and
discusses primary exhaust rates and ducting layouts.
6.1.1  Cell Hooding
     A high primary collection efficiency greatly depends on a hood
.that is highly efficient at containing fluoride emissions and directing
them to the primary removal equipment.  The characteristics  of the
different cell types place various limitations on hooding design.

6.1.1.1  Prebake Cells — Figure 6-1 illustrates  the hooding for a
typical prebake cell.  The hooding consists of removable end doors  and
a gas collection skirt on both sides made up of segmented,  lightweight
aluminum doors or side covers.
     As mentioned in Section 4.2.2, prebake (PB)  cells  may  be center-
worked  (CWPB) or side-worked (SWPB).  CWPB  cells  can be worked from the
end or internally without removing the side covers.  Because of this,
CWPB potlines have total fluoride primary collection efficiencies of
                                                                          •
                                  6-2

-------
                                                                               ALUMINA HOPPER
I
oo
         SEGMENTED
           DOORS
                                                                                                      ALUMINA
                                                                                         CARBON ANODES
                                        Figure 6-1.  Typical prebake cell hooding.

-------
at least 95 percent or are capable of achieving this  level  through
appropriate cell design changes to improve hooding.   The  proper  approach
is to tightly seal the hood and to perform as many cell operations  as
possible with the hood intact.  Tight seals are achieved  by having  tight-
fitting end doors and side covers that fit snugly and align with each
other. Edge sealing of worn and misaligned covers is  improved by
including deep  90° side edges on  covers  at time of fabrication.
The top seals around the anode stems are the most difficult to achieve.
This  is due to  the low density of the gases inside the hooding enclosure.
This  top seal is  particularly difficult  for prebake cells equipped  with
anode stems that  vary in cross-sectional area, resulting  in variable
clearances as the anodes are lowered.  As for internal  working,  CWPB
cells can be equipped with automatic crust breakers and are capable
of achieving the  full mechanization with computer control described in
subsection 5.2.1.5.3.
     At least one CWPB plant has adopted a different  hooding design
from that shown in Figure 6-1.   In this design,  the side  covers are
flat, heavy aluminum doors hinged at the bottom with  a gravity seal
at the top.   In addition, a labyrinth seal  provides  an excellent cover-
to-cover fit.   This door is expected to provide a  retrofit primary
collection efficiency of 97 percent, although  this has not yet been
demonstrated  in full-scale potline operation.
     SWPB cells must be  worked  manually along  both sides with the side
covers removed.   Hence,  SWPB  potlines are typically  capable of achieving
a  total  fluoride primary collection efficiency of  no  higher than 85
percent,  and  some can do no better than 80  percent.   The  tight sealing

                               6-4

-------
and computer control  discussed above are possible with SWPB cells,
but the installation  of automatic crust breakers and full mechanization
are not.
     To accomplish side working on all SWPB cells in a potroom within
a reasonable time period, all the side covers on one cell are normally
removed while that cell is worked.  For this reason, some SWPB plants
have installed flat aluminum or steel hood doors that extend the full
length of both sides  of the cell.  When closed, they form an angular
gas collection skirt similar to that shown in Figure 6-1, but not seg-
mented.  They are opened by air cylinder or air motor to one or more
open positions, depending on operating requirements.  The opening linkages
must be precisely designed, and can be quite complicated.  At each end
of the cell, the doors seal against stationary wing panels that can be
adjusted to minimize leakage.  SWPB plants employing these hood designs
have cells set into the floor rather than elevated.  Heat-resistant
cloth is installed around the door bottom and gravity seals the hood
when the door is closed.
     SWPB potlines can seldom be converted to CWPB potlines to improve
their primary collection efficiency and reduce the need for secondary
control.   This is because the steel superstructure is the most expensive
part of the SWPB cell and would have to be completely replaced in con-
verting to a CWPB design.  The relatively less costly common cathode
shell is  removed anyway about once every three years for lining replace-
ment.  All CWPB cells and some SWPB cells are aligned side by side as
shown in  Figure 4-3.   However, with SWPB cells, more space is required
between the cells and less between the cells and the potroom walls.  Hence
a SWPB potroom would  probably be too narrow for CWPB cells, and much of

                             6-5

-------
its length would be wasted in a conversion.  If left no alternative but
to convert to the CWPB design, the owner of a SWPB potline would probably
abandon the potline and build a new CWPB facility.
     As shown in Figure 6-1, CWPB and SWPB cells generally have single-
point pickup at one end of the cell.  To get uniform gas flow across
the cell, the gas duct at the top of the cell is vaned to give the
same pressure drop from various points above the cell to the single-
point pickup.

6.1.1.2 -- Horizontal Stud Soderberg (HSS) Cells — Figure 6-2 illu-
strates the total-enclosure hooding for a typical HSS cell; however,
the anode pins and the steel casing generally extend closer to the
bath than is indicated.  The hood doors extend the full length of both
sides of the cell, and working a side requires opening an entire door.
Most draft systems cannot provide sufficient capture velocity to
efficiently collect emissions under these circumstances.
     HSS potlines are capable of achieving total fluoride primary
collection efficiencies of 85 to 95 percent.  Like CWPB potlines,
the proper approach involves tighter hood sealing and internal working
with the hood doors closed.  Tighter sealing can be achieved by replacing
manual with mechanically operated doors and by eliminating
gaps on the top and the ends of the cell hooding enclosure.  To minimize
door openings, at least one HSS plant (See section 6.3.1.1) has installed
a mechanized feeding system that feeds most of the alumina with
the hood doors closed.  It is still necessary to manually work the cell
periodically, but the length of time per cell-day that the doors are
open is reduced.  The mechanized feeding system may operate at preset
                               6-6

-------
                TO PRIMARY CONTROL
                    EQUIPMENT
CTi
                     ANODE PINS
                                                                                                       END DOOR
                                     Figure  6-2.      Typical  horizontal stud Soderberg cell hooding.

-------
time intervals, or the potline may be computer-controlled with alumina
being added on a demand basis.
     The primary collection efficiency an HSS potline can achieve depends
upon cell age and cell geometry.8  Older, smaller cells may  need to be
opened more frequently than newer ones.  For example, one plant has
cells installed in the early 1940's that must be opened about 50 times
per ton of aluminum produced,  and  cells  installed  in the late
1960's that are opened only 16 times per ton.  As for geometry, two
HSS plants have cells with an unusually high lengthrwidth ratio of
8:1 as opposed to a normal ratio of 5:1.  Cell working constraints
require  single point  pickup at one end of the cell,  rather  than
the desirable  pickup  at both  ends.
6.1.1.3  -  Vertical Stud Soderberg  (VSS) Cells — Figure 6-3 illustrates
the hooding for a typical VSS  cell.  The hood skirt  consists of an in-
verted U-  or  V-shaped channel  that runs around the edge of  the anode
assembly at the bath  level.  The channel is formed by the anode itself
and the  outer  anode casing.  The channel serves as a duct to carry the
evolved  gases  to  integral gas  burners, typically one on each end of the
cell.  Hence,  a substantial area of the cell surface is outside the
hood  skirt.  This annular, exposed area is normally  covered by a crust
of cryolite and alumina,  the  latter adsorbing fluorides that otherwise
would escape.  However, this  crust is broken when the cell  is worked,
exposing the molten bath  until the crust reforms or  the bath is covered
with  alumina  after the cell is worked.  During the exposed  period, large
quantities of  fluoride escape  to the potroom roof.   Total fluoride pri-
                                6-8

-------
                                                           ORGANIC FUMES
                                                                                                        TO PRIMARY
                                                                                                     CONTROL EQUIPMENT
     ANODE PINS
                                                                                                                     CARBON ANODE
 i
vo
                                                                                                                             .GAS AND TAR
                                                                                                                               BURNING
                                         SKIRT
                                                                                                 ALUMINA
                                    Figure  6-3,    Typical vertical stud Soderberg cell hooding.

-------
mary collection efficiencies for VSS potlines vary from  75  to  92  per-
cent.
     Table 6-1 shows the effect that exposed bath area has  on  primary
collection efficiency for two VSS plants.9  Both plants  were built  by
the same firm and have cells capable of producing about  one-half  ton
of aluminum per day.  Table 6-1 shows that the plant with the  greater
exposed surface area has a correspondingly lower primary collection
efficiency.
Table 6-1.  PRIMARY COLLECTION EFFICIENCY VERSUS EXPOSED ANNULAR
                       AREA FOR TWO VSS PLANTS9
 Plant
  T
Exposed Annular
Area, ft?
                           37.6
    62.4
Primary Collection
Efficiency. %
                              80 - 85
    75 - 80
 6.1.1.4  Effect of Hooding on Overall Control -- The aforementioned
 hooding limitations mean that CWPB and some HSS plants appear capable
 of  achieving high overall control efficiencies without installing
 secondary control if appropriate cell design changes are made to im-
 prove hooding.  High primary collection efficiencies (90 percent or
 greater) are not achievable on SWPB, most VSS, and some HSS  plants,
 and secondary control would be necessary for these plants  to achieve
 high overall control efficiencies.
                                6-10

-------
6.1.2  Calculation of Primary Collection Efficiency
     One primary aluminum company operating SWPB cells of Swiss-design
submitted an experimental method for calculating primary collection
efficiency.   All the fluoride generated from unhooded cells in a tight
building was sent to a secondary wet scrubber, whose water was analyzed.
Analysis was repeated for all the cell  functions; this resulted in the
generation severity indices shown in Table 6-2.    For instance, anode
changing generates six times as much fluoride as normal cell operation.
Since all but the normal  operation requires the hood to be open, the
number of minutes in 24 hours required for each function is measured,
and designated as "function time" in Table 6-2.
     Using the submitted data, generation rates for each function
and an overall generation rate are calculated.  Establishing the percent
of leakage for each cell  function, the secondary loading (non-primary
collection)  for each function and an overall secondary loading can be
calculated.   For one plant employing this cell design, the leakage rate
is estimated to be 7 percent when the cell is closed.    For this same
plant, the hood door opens fully for anode changing, and leakage is
assumed to be 85 percent.  For all other non-normal operations, the hood
door is partially open, and leakage is assumed to be 70 percent.
     Primary collection is determined as the difference between generation
rate and secondary loading, from which a primary collection efficiency
of 80 percent is calculated.  As of spring 1975, the above plant had not
completed hood installation, and hence had not measured primary collec-
tion and secondary loading.  However, they estimate primary collection
                             6-11

-------
Table 6-2.  CALCULATION OF PRIMARY COLLECTION  EFFICIENCY  FOR
                   ONE SWISS-DESIGN SWPB PLANT™,11
Cell Function
Fluoride
Generation
Severity    Function Time,
Index (A)   Minutes (B)
Generation Rate,
    A '  B          Leakage
Normal Operation
Anode Effects
Anode Changing
Metal Tapping
Bath/Metal Measure-
ment .
Short Side Crust
Breaking
Long Side Crust
Breaking
Bath Addition
Alumina Addition

Other Controls
Totals
1 Xa
5.5 X
6 X
2 X

1 X

4.5 X

7 X
1 X
1 X

2.5 X

1359
6
3
6

2

10

26
1
20

2
1440
1359 X
33 X
48 X
12 X ~^

2 X

45 X !

182 X
1 X :
20 X

5 X _
1707 X
n
70%
85%
\





'-- 70%


i


 Average generation rate = 1707 X / 1440 = 1.185 X

 Secondary (2°) loading = Generation •  Leakage =  [0.07 (1359 X)  +  0.85

 (48 X) + 0.70 (300 X)] / 1440 = 0.240  X

 Primary'collection efficiency = [(Generation - 2° loading)  / Generation]

 '  100% = [(1.185 X - 0.240 X) / 1.185  X]  •  100% = 80%
 aX is defined as the normal fluoride generation from a  crusted-over cell,
  expressed in units of weight of fluoride generated per weight  of aluminum
  produced—e.g., Ib F/ton Al.
                                  6-12

-------
                              11  12
efficiency will  be 81  percent,  *    in close agreement with the
calculated efficiency.
     No other aluminum companies  submitted severity indices or function
times for ^ny cell types.   However, the above calculational procedure
was extrapolated to other cell types, keeping the same severity indices
but modifying function times and  leakages.  Other cell types chosen for
this analysis were:
     a.   An SWPB plant of French design that is retrofit case descrip-
          tion C in section 6.3.3.
     b.   A typical American-design CWPB plant.
     c.   An HSS plant that is retrofit case description A in section 6.3.1
     d.   A typical VSS plant.
     Table 6-3 shows the calculations for the French-design SWPB plant.
The function time for anode effects has been reduced from 6 minutes to
3 because this plant is computer-control led, while the Swiss-design
plant was not.  Leakage rate is estimated to be 5 percent when the cell
is closed.    The hood door opens fully for all  non-normal operations.
Leakage is assumed to be 70 percent instead of the 85 percent for the
Swiss-design plant because, unlike the latter, the French-design plant
has a fixed superstructure that should cover a greater portion of the
cell with the doors open.   The calculated primary collection efficiency
                                                                   13
of 83 percent agrees well  with a  measured efficiency of 85 percent.
                             6-13

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Table 6-3.  CALCULATION OF PRIMARY COLLECTION EFFICIENCY  FOR ONE
           FRENCH-DESIGN  SWPS  PLANT  -  RETROFIT CASE  DESCRIPTION C.
Cell Function
Fluoride
Generation
Severity    Function Time,
Index (A)   Minutes (B)
Generation Rate,
    A ' B          Leakage
Normal Operation
Anode Effects
Anode Changing
Metal Tapping
Bath/Metal Measure-
ment
Short Side Crust
Breaking
Long Side Crust
Breaking
Bath Addition
Alumina Addition
Other Controls
Totals
1 X
5.5 X
6 X
2 X
1 X
4.5 X
7 X
1 X
1 X
2.5 X
1362
3
8
6
2
10
26
1
20
2
1440
1362
16
48
12
2
45
-182
1
20
5
TO-3
X
X
X
X
X
X
.X
X
;
x
X
V
5%
\
j
)
> 5%


^ 7Q%


                                                    i u :> o A
Average generation rate = 1593X / 1440 = 1.176 X

Secondary (2°) loading = Generation •  Leakage = [0.05 (1376 X) + 0.70

(317 X)] / 1440 = 0.202  X
                                                                      V
Primary collection efficiency = [(Generation - 2°  loading)  /  Generation]

'  100% = Cd.176 X -  0.202 X) /  1.176  X] •   100% = 83%
                               6-14

-------
     Table 6-4 shows  the calculations for a typical modern American-
design CWPB plant.  Compared to Table 6-2, the plant is again assumed
to be computer-controlled,  the function time for anode effects being
reduced from 6 minutes to 3.  The function time for short side crust
breaking is zero since there is none; and that for long side crust
breaking is halved  since a CWPB cell has one crust break area while an
SWPB cell  has two.  The cell remains closed during normal operation,
crust breaking, and raw material additions.  The leakage rate with the
door closed is estimated at 3 percent.     The cell end covers must be
removed for metal  tapping and, presumably, for bath/metal measurement
with an estimated leakage rate of 8 percent.    Removal of side covers
during anode effects  and anode changing increases the leakage rate to 50
percent.    The calculated primary collection efficiency of 95 percent
agrees with measured  efficiencies at numerous CWPB plants.
     Table 6-5 shows  the calculations for the HSS plant that is retro-
fit case description  A in section 6.3.1.  For HSS plants, the function
times for anode changing and short side crust breaking are zero since
these operations are  not performed.  Plant A estimates that only 20 per-
cent of crust breaking is done with the doors open.  This translates to
a function time of  5  minutes with the doors open; 21 minutes with the
doors closed.   Plant  A estimates the door is open a total of 8 minutes
per cell day.   For  Table 6-5, this means that only 3 minutes open time
remain for metal tapping, anode effects, flex raising and stud pulls
combined.   Function times have been arbitrarily assigned for these
functions, and anode  effects do occur even though the table shows a
                             6-15

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Table 6-4.  CALCULATION OF PRIMARY COLLECTION  EFFICIENCY FOR

                  TYPICAL AMERICAN-DESIGN CWP3 PLANTS
Cell Function
Fluoride

Generation
Severity    Function Time,

Index (A)   Minutes (B)
Generation Rate,

    A  ' B
Normal Operation
Anode Effects
Anode Changing
Metal Tapping
Bath/Metal Measure-
ment
Short Side Crust
Breaking
Long Side Crust
Breaking
Bath Addition
Alumina Addition
Other Controls
Totals
1 X
5.5 X
6 X
. 2 X
1 X
4.5 X
7 X
1 X
1 X
2.5 X
1385
3
8
6
2
0
13
1
20
2
1440
1385 X
15 X
48 X
12 X
2 X
OX
91 X
1 X
20 X
5 X
IRRf) X
Leakage
                                                                     3%
                                                                     3%
Average generation rate = 1580 X / 1440 =  1.097 X



Secondary (2°) loading = Generation  • Leakage = [O.o3  (1502  X) + 0.50



(64 X) + 0.08 (14 X)]  /  1440 = 0.054  X
                                                                       V


Primary collection efficiency = [(Generation - 2°  loading) / Generation]



  100% = [(1.097  X - 0.054 X) /  1.097 X] '  100% =  95%
                               6-16

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Table 6-5.   CALCULATION  OF  PRIMARY COLLECTION EFFICIENCY FOR
             ONE HSS PLANT - RETROFIT CASE DESCRIPTION A.

                  Fluoride
                  Generation
                  Severity     Function Time,    Generation Rate,
Cell Function      Index  (A)    Minutes (B)           A '  B	   Leakage
Normal Operation
Anode Effects
Anode Changing
Metal Tapping
Bath/Metal Measure-
ment
Short Side Crust
Breaking
Long (" Door
Side j Closed
Crust ' Door
Breaking , Open
Bath Addition
Alumina Addition
Other Controls
Flex Raise &
Stud Pull
1 X
5.5 X
6 X
2 X

1 X

4.5 X
7 X

7 X

1 X
1 X
2.5 X

1 X
1386
0
0
2

2

0
21

5

1
20
2

1
1386 X
0 X
0 X
4 X

2 X

0 X
147 X

35 X

1 X
20 X
5 X

1 X
5%
-
-
70%

5%

-
5%

70%


5%


70%
       Totals                       1440           1601  X


Average generation  rate = 1601 X / 1440 = 1.112  X

Secondary  (2°)  loading  = Generation •  Leakage = [0.05  (1561 X) + 0.70

(40 X)] /  K40  =  0.073  X
                                                                       V
Primary collection  efficiency = [(Generation -  2° loading) / Generation]

' 100%  = [(1.112  X  -  0.073 X)  / 1.112  X]  •  100%  =  93%
                                  6-17

-------
zero function time.  Also, the fluoride generation  rate for flex raising
and stud pulls has been assumed equal to normal  operation -- participate
generation rate would not be equal.  Cell  leakages  are assumed identical
to the French design SWPB plant since the  cell has  a  fixed superstructure,
The calculated primary collection efficiency of  93  percent agrees well
with a plant estimated efficiency of 95 percent  that  is based on proto-
type testing—see section 6.3.1.3.
     This method of calculating primary collection  efficiency is not
very sensitive to errors in function time  or duration of hood opening.
For example:  at unchanged leakage for normal operation, all  other
leakages listed in Table 6-2 were increased by 10 percent - all  in the
same direction.  The calculated primary collection  efficiency decreased
less than 2 percent from that shown.
     The 3 percent hood leakage under normal operation (Table 6-4) was
assumed to double to 6 percent.  All other operating  leakages were held
constant.  The calculated primary collection efficiency decreased less
than 3 percent.  Another calculation on this same CWPB cell assumed that
all cell openings were 3 times as frequent as shown in Table 6-4.  The
primary collection efficiency decreased less than 2 percent from that
s hown.
     The examples shown in Tables 6-2 through 6-5 apply to specific
plants and are given to illustrate this method for  estimating primary
collection efficiency.  Users of the method should  -  as a minimum -
determine the function times for plants that they want to check.

                             6-18

-------
     Extrapolation  of the  above calculational  procedures to VSS cells
is probably without theoretical justification  since the hooding is
radically different.   However,  Table 6-6 shows such an estimate for
a typical  VSS  plant.   The  function times are the same as in Table 6-2,
except there is  no  anode changing.  Stud blows have been ignored
since their severity index is  unknown.   It is  assumed there is no
capture of emissions from  all  non-normal operations, and a 3 percent
leakage from the anode channel  during normal operation.  The calculated
primary collection  efficiency  of 80 percent is within the range of VSS
cell  performance of 75 to  92 percent given in  section 6.1.1.3.

6.1.3  Primary Exhaust Rates
     Operating the  cells at the proper primary exhaust rate is important
for efficiency primary collection.  Too low an exhaust rate results in
a low collection efficiency; too high a rate results in the primary removal
equipment being  oversized  and  in solids being  needlessly entrained from
the cell  surface into the  equipment.  The proper exhaust rates for a
given cell  design cannot be empirically determined because the total open
area  of an operating cell's hood is virtually  impossible to calculate.  Instec
                             6-19

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Table 6-G.  ESTIMATE OF PRIMARY COLLECTION EFFICIENCY FOR
                         TYPICAL VSS PLANTS

                  Fluoride
                  Generation
                  Severity    Function Time,    Generation  Rate,
Cell Function     Index  (A)   Minutes (B)          A ' B	  Leakage
Normal Operation
Anode Effects
Anode Changing
Metal Tapping
Bath/Metal Measure-
ment
Short Side Crust
Breaking
Long Side Crust
Breaking
Bath Addition
Alumina Addition
Other Controls
Totals
1 X
5.5 X
6 X
2 X
1 X
4.5 X
7 X
1
1 X
1 X
2.5 X
1367
6
0
6
2
10
26
1
20
2
1440
1367 X
33 X
0 X
12 X
2 X
45 X
182 X
1 X
20 X
5 X
1667 X
2%
100%
-
]
|
i
i
i
i
N 100%
!
i
1
 Average generation rate =1667 X / 1440  =  1.158 X

 Secondary  (2°)  loading = Generation  • Leakage  = [o.03 (1367 X) + 1.00

 (300 X)] / 1440 = 0.237 X

 Primary collection efficiency  = [(Generation - 2° loading) / Generation]

 1  100% =  [d.158 X - 0.237 X) / 1.158 X] '  100% = 80%
                              6-20

-------
the optimum exhaust rate is usually determined from a cell prototype.
This rate is that which will continuously maintain a sliqht negative
pressure drop across all the hood openings.  The pressure drop can be
measured by sensitive pitot tubes and anemometers, or proper operation
can be visually checked by releasing smoke just outside the openings
and observing the resultant travel path.
     The  proper exhaust rate is  most  difficult to  maintain when the hood
door is open.  Some  designs  maintain  it  through "dual  range ventilation"
as explained in section 6.1.4.   Consideration should  also  be given to the
fact that the  hood will  inevitably deteriorate with time as  the cell
deteriorates.  Such  deterioration can be held to a minimum,  however,  by
maintaining  the hoods  in proper  condition and makinn  sure  that  ooerators
exercise  care  in  handling  hood doors.
     EPA  personnel visited seven primary aluminum  plants in  the Spring
 of 1973  to  develop  data for this guidelines  document.   For  these  seven
 plants,  Table 6-7 shows primary collection efficiencies and  primary  ex-
 haust rates for  retrofits either underway or completed. '  '   '
 The age  of  the plant  and  of the control  equipment (if different)  is
 also given.   From Table 6-7 it  can be concluded that:
     1.   HSS potlines  generally  require  higher primary exhaust rates
         than  CWPB  potlines  to  achieve the same primary collection
         efficiency.
     2.   Older CWPB  potlines generally require higher primary exhaust
         rates than  newer  CWPB  potlines  to achieve the same primary
         collection  efficiency.

-------
Table 6-7   PRIMARY COLLECTION EFFICIENCY VERSUS STANDARD CUBIC
            FOOT PER TON OF ALUMINUM PRODUCED FOR SEVEN PRIMARY
                           ALUMINUM PLANTS 3,4,13,16-18
Cell
type
CWPB
CWPB
CWPB
CWPB
SWPB
VSS
HSS
HSS
HSS
HSS
HSS
Plant
code
D
F
G
G
C
E
B - south
plant
B - south
\ plant
B - north
plant
A
i
A
t
Year plant
started up
1939C
1952
1958
1958
1965
1958
1941
1941
1968
1/2 - 1942f
1/2 - 1968
1/2 - 1942f
1/2 - 1968
Before/after,
retrofit
Both
Both
Before
After
After6
Both
Before
After
Both
Before
After
Primary
collection
efficiency, %
95
98
65
95d
85
81
80
87
95
94
95
Scf/ton,
Al x 106
5.05
4,78
4.11
4.11
3,44
0.67
5.06
7.85
6.81
6.57
7.09
-
 FOOTNOTES:

 a.   Plants  have  the  same codes  here and  in  Section  6.3.

 b.   As  of May  1975,  retrofits were in progress at plants  D,  G,  and B-
     south;  and had been completed within the previous  five years at
     plants  F,  C, E,  B-north, and A.

 c.   Hoods,  ducts, fans, and  removal equipment were  installed in 1949.

 d.   Collection efficiency will  be  increased by cell  design  changes to
     effect  tighter hood sealing.

 e.   Plant had  no primary control before  retrofit.

 f.   Present ducts, fans, and removal  equipment were installed in 1951.
                               6-22

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     3.   Even with higher exhaust rates, older HSS potlines may not
          readily achieve primary collection efficiencies as high as
          those attainable by newer HSS potlines.
VSS cells characteristically have lower primary exhaust rates than
either prebake or HSS cells.
6.1.4  Ducting Layouts
     Practice varies among aluminum plants as to the number of cells
connected with a single control system.  In centralized or "central"
installations, an entire potline of 150 or more cells may be ducted to
a single control system; whereas, in decentralized or "courtyard"
installations where smaller control units are usually located in
courtyards between potlines, 20 or fewer cells may be ducted to each
control system.  Figures 6-4 through 6-6 illustrate schematically several
possible ducting layouts for PB, VSS, and HSS potlines.19  The manifold
ducts are generally inside the potroom and elevated above and near the
cells.  However, some SWPB and VSS potrooms have basements, the primary
exhaust being directed downward into manifold ducts in the basement.
     The illustrative courtyard installations are patterned after existing
installations and were selected as the bases for the cost analysis in
Section 7.  With a courtyard layout, each piece of removal equipment
is a separate module.  To control a larger plant, additional modules
are added.  The use of courtyard layouts thus eliminates the possible
economy of scale associated with control of larger plants.  Further-
more, the control costs can be presented on a cost per ton of aluminum
capacity basis because the control cost per ton does not vary with plant
                             6-23

-------
                COURTYARD SCHEME (20 CELLS PER MANIFOLD DUCT)
          20
         CELLS
 20
CELLS
                                                     .MANIFOLD DUCT
                                                                     MAIN DUCT
                               JL9      "LB
          20
        CELLS
                                   T	r

i\

A i
i j i " i |
6 i\ ti 6 d A
                CENTRAL SCHEME (80 CELLS PER MANIFOLD DUCT)
MANIFOLD DUCT.
       80
      CELLS
                    \     T
                                                                    MAIN
                                                                    DUCT
                                ..4
      Figure 6-4.  Primary collectiorW-systems:  typical ducting layouts for a         iq
      single prebake potline with 160 cells, 2 rooms (R indicates removal equipment).
                                     6-24

-------
            COURTYARD SCHEME (10 CELLS PER MANIFOLD DUCT )
 10       10
CELLS     CELLS
                    MAIN
                    DUCT-
                                                    •MANIFOLD DUCT
                                               J?d
                                                                        ~n
                i
                                               flfl
 10
CELLS
           10
         CELLS
  Figure 6-5. Primary collection systems:  typical ducting layout for a
  single VSS potline with 160 cells, 2 rooms (R  indicates removal equipment).19
                               6-25

-------
            COURTYARD SCHEME (10 CELLS PER MANIFOLD DUCT
                                                    	MANIFOLD DUCT
10
CELLS
r-^~
9


R

10
CELLS
^r-' 	
gg

*

b




R


N
gg

«—


ifi




R

MAIN
DUCT 	

W

*•

i
\b
/ ' ' 	 1
P\P/ gg gg gg g


R

*•

to

I 1


-GO


-0


*m


*B

fl fl flfi fld GO o
 10        10
CELLS     CELLS
               CENTRAL SCHEME (80 CELLS PER MANIFOLD DUCT)
80
MANIFOLD DUCT 	 . CELLS
f \ S
9 \ 9 9 9

i i
i i
I 1
i i

i A i
MAIN 	 ,
DUCT 1


   Figure 6-6.  Primary collection systems:  typical ducting layouts for a
   single HSS potline with 160 cells, 2 rooms (R indicates removal equipment).19
                                 6-26

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 size.  Table  6-8 shows the gas volume relationship to aluminum  production
 capacity  that was used in Sectiqn 7 to determine the required primary
                        20
 control equipment size,   and the sizes of the courtyard primary control
 device modules  used as the bases for the cost estimates.21   For com-
 parison,  Table  6-8 also shows the gas volume relationships  and  equipment
 capacities  used for secondary control.20'21... For an equivalent  production
 capacity, secondary removal  equipment must be larger by at  lea.st an
 order of magnitude.
       Table  6-8.   GAS VOLUMES AND CONTROL DEVICE MODULE SIZES FOR
                        ECONOMIC IMPACT ANALYSI$20,21

Gas volume to primary control
device, 106 acf/ton Al
Primary control device module size
Dry systems, acfm
Wet systems, acfm
Gas volume, to secondary control ...
device, 106 acf/ton Al
Secondary system equipment capacity,
106 acfm
Cell tvpe
Prebake
5.0
100,000
82,000
50
10
vss
1.0
10,000
7,000
70
10
HSS
7.0
70,000
70
10
     Table 6-9 gives  1975  primary collection system capital costs  for
courtyard and- central  installations.22  With a central layout, the
ductwcrk is larger and  longer,  and thus more expensive.
     For a specific retrofit,  it is not possible to generalize as  to
which approach is more  economical.   Central  installations are used when
the courtyard is too  narrow  to  install the primary removal equipment.
                               6-27

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 Table 6-9.   CAPITAL COST COMPARISON BETWEEN COURTYARD AND  CENTRAL
                   PRIMARY COLLECTION SYSTEMS^
       ($/annual  ton of Al at full capacity, new construction)
                          (December, 1975)


Cell hoods and
branch duct
Manifold duct
Main duct
Total
CWPB
Courtyard ! Central
8.78
15.46
7.98
32.22
8.78
35.44
3.61
47.83
HSS
Courtyard
8.78
25.45
14.09
48.32
Central
8.11
48.85
3.72
60.68
Dry scrubbing systems—like the fluidized bed and injected alumina processes--
require particularly wide courtyards.  A courtyard that is 50  to 60
feet wide may be too narrow for retrofitted dry scrubbing equipment, but
wide enough for retrofitted wet scrubbing equipment.  Of the nine plants that
EPA personnel visited in developing this document, the two that had courtyard-
installed dry scrubbing retrofits had courtyards that were 100 to 150 feet wide,
     Other considerations, such as flexibility by provision of duct inter-
connections for continued pollution control when part of a control system
may be out of service, and the ease of cleaning deposits from the inside of
ducting, may influence the design of ducting layouts.  Maximum collection
efficiencies are realized when the designs provide for continuous exhausting
of all operating cells through removal equipment even when parts of a
potline are being serviced, and when dampers are available to  increase the
air flow rate from a cell that may have part of its hooding removed for
cell working or anode replacement (dual range ventilation).  Duct pluggage
is a problem in HSS potlines and in poorly operated VSS potlines because
unburned hydrocarbon tars will condense in the ductwork.
                                 6-28

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6 2  POTROOM AND ANODE  BAKE  PLANT RETROFIT REMOVAL EQUIPMENT AND
     ITS  PERFORMANCE
     This section  discusses  potroom primary and secondary removal
equipment,  along with anode  bake plant controls.   Although the intent
is to describe  retrofit operation and performance, there is no known
difference  in the  operation  and performance of a specific piece of re-
moval equipment on a new versus a retrofitted primary aluminum plant.
Hence, the  descriptions should apply to both new and retrofit instal-
lations.  The removal equipment considered falls into three classes:
     a.    Dry scrubbing equipment suitable for potroom primary control.
     b.   Wet scrubbing equipment suitable for potroom primary control
         and anode bake plant control.
     c.   Wet scrubbing equipment suitable for potroom secondary control.
     Finally, potroom and anode bake plant best retrofit performance
is summarized.  Evolution rates in Section 5.3 are combined with best
retrofit  collection and removal efficiencies in Sections 6.1 and 6.2 to
show the  overall effect on potroom total fluoride emissions.  Evolution
rates in  Section 5.3 are combined with best retrofit removal efficiencies
from an EPA contract study  to estimate controlled anode bake plant
performance.

6.2.1  Potroom  Primary  Dry Scrubbing
     Two  types  of  dry scrubbing systems, fluidized bed and injected
alumina,  are discussed  in the following subsections.  These systems
have been applied  to many domestic and foreign plants.  In addition,
                             6-29

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one domestic company  has been  installing  its own dry  scrubbing
system on  two CWPB and  two HSS plants.  One of these  HSS  retrofits
is retrofit case  description plant A  in Section 6.3.1.  This  dry
scrubbing  process is  proprietary.  However, operating conditions  are
similar  to those  of the fluidizied bed and injected alumina processes
described  below.  Total fluoride  removal  efficiencies are projected to
be 98-98.5 percent for  the two CWPB plants and 97-98  percent  for  the
two HSS  plants.
6.2.1.1  Fluidized Bed  -- Figure  6-7  is a flow diagram  of the fluidizied
.bed dry  scrubbing process.  The fluidized bed dry  scrubber employs  a
fluidized  bed of  sandy  alumina to contact and chemically  absorb HF
in the cell gas followed by a  baghouse to trap particulates.   Floury
alumina  will not  fluidize and, hence,  is  not suited for this  process
or for the injected alumina process.
      Alumina is continuously fed  to the reactor bed in  amounts up to
TOO percent of the potline feed requirements, and  the reacted bed
material overflows and  is used as cell feed.  Virtually all  of the  cell
gas particulate  is trapped in  the fluid bed -- perhaps  by electrostatic
agglomeration.  Fugitive particulate,  primarily alumina,  is stopped by a
bag filter mounted over the  reactor.   The bags are cleaned intermittently,
                                                    po  oc
and the  catch drops back into  the fluid reactor bed.
      The vendor of the  fluidized  bed  dry  scrubber  reports that, with
proper operating  and  maintenance  procedures, this  system  is capable of 98
percent  particulate and 99 percent HF removal efficiencies on prebake
                  ?7
potline  effluents,    or about  98.5 percent on total fluoride.
                              6-30

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 CRUDE
ALUMINA
 TANK
                                                                                                   ROOF
                                                                                                 EMISSIONS
                                                       ' BLENDED
                                                       ALUMINA
                                                         TANK
  FLUID BED
DRY SCRUBBER:
                 FAN
                                              CELL GAS
                 Figure 6-7. Flow diagram for fluidized bed dry scrubbing process.

-------
     The fluidized bed dry scrubber has been applied in foreign plants
to VSS cell gases with pilot lights or other devices used to ensure that
                                                                        27
all burners are lit.   The system has not been applied to HSS cell  gases.
It has been installed in one domestic VSS plant with a projected re-
moval efficiency of 98.8 percent.
     Dry scrubbing processes afford much less cooling for the cell
gas than wet scrubbing processes.  Since conventional filter fabrics
like Dacron or Orion deteriorate above 275°F, the cell gas is usually
                                                 25
delivered to the fluidized bed at 275°F or below.    Typical pressure
drops are 8 to 10 inches of water across the fluidized bed and 4 to 5
                                    3 28
inches of water across the baghouse.  '    A typical power requirement is
                                                         3      29
4.4 horsepower per thousand cubic feet per minute (hp/Mft -min).
6.2.1.2  Injected alumina —  Figure 6-8 is a flow diagram of the
injected alumina dry scrubbing process.  The process is similar in con-
cept to the fluidized bed — reaction of gaseous fluoride with sandy
alumina followed by baghouse collection of particulate -- except that
the reaction occurs by injecting the alumina into the flowing gas stream
rather than by passage of the gas stream through a fluidized bed.  The
                                       3
reaction occurs in a matter of seconds.
     Alumina is continuously fed to the process in amounts up to 100
percent of the potline feed requirements.  The removal efficiencies
of the injected alumina process are similar to those of the fluidized
bed.  One major difference, however, is that loss of feed to the
fluidized bed (Figure 6-7) will not result in a loss in removal
efficiency for 8 hours thereafter because of the large alumina inventory
in the fluidized bed.  Loss of feed to the injected alumina process on
                               6-32

-------
01

GO
CO
                                                                                                                         ROOF
                                                                                                                       EMISSIONS
                                         iALUMINA
                                              Figure 6-8.  Flow diagram for injected alumina dry scrubbing process.

-------
the other hand can quickly result in a loss in removal efficiency due
to a low alumina inventory.   Recycling a portion of the reacted
alumina back into the cell gas stream provides some insurance against
a total feed loss.
     More than one vendor markets an injected alumina process designed
for prebake potlines.  An Alcan and a Prat-Daniel-Poelman design are
explained in Section 6.3.3.
     Cell  gases from VSS potlines have higher concentrations of HF
than prebake cell  gases, and they may contain unburned tar fumes.
Here again, alumina is injected into the flowing gas stream, but from
this point on, the Alcan process is modified slightly.  Provision is
made to separate the bulk of the alumina containing adsorbed HF from
the portion containing unburned hydrocarbons.  The latter minor quantity
of alumina is calcined to remove the tar prior to being returned to the
cells along with the main portion of the collected alumina.  This system
                                                               3D
does not require that all VSS cell  burners be lit all  the time.
     Comments on temperature limitations for the fluidized bed also
                                    *
apply to the injected alumina process.  A typical pressure drop is
6 inches of water across bag filters operating at an air-to-cloth ratio of
          3                                   27
about 6 ft /min per square foot of filter area.    A typical power
requirement is 2.2 hp/Mft3-min.29

6.2.2  Potroom Primary and Anode Bake Plant Wet Scrubbing
     A potroom primary wet scrubbing scheme that gives removal efficiencies
comparable to dry scrubbing  is the combination control of spray tower
followed by wet ESP.  This combination control is most frequently applied
                               6-34

-------
to VSS and  HSS  plants.   Spray tower-wet ESP or wet ESP-spray tower con-
trols also  effectively  remove particulate and fluoride from anode bake
plant exhaust.   Since most  of the latter fluoride is gaseous, the spray
tower —  and  not the ESP -- controls fluoride emissions.

6.2.2.1  Spray  Tower — The term spray tower is applied to gas scrubbing
devices in  which the gas passes through an enclosure at relatively low
velocity  and  is contacted by water, alkaline liquor or limed water
liquor sprayed  from headers usually in counterflow with the gas.  In pre-
bake or HSS potline service, the units may range from 38,000 to 630,000
actual cubic  feet per minute capacity and may spray from 1.7 to 10.0
gallons of  liquor per thousand cubic feet of gas.  A typical spray tower
in prebake  service uses water or limed water and consists of an open
top redwood tower, 12 to 15 feet in diameter and 40 to 70 feet high,
with cyclonic inlet breeching and a mist eliminator at the top.  Liquor
may be sprayed  down from the top or at several elevations in the tower.
     Spray  towers operate at a low pressure drop, typically 1 inch
        32                                                   3
of water.     Typical power  reauirements are 0.4 to 0.9 hp/Mft -min for
prebake service, 1.0 to 1.3 hp/Mft -min for VSS service, and 0.3 to 0.5
      3                     29
hp/Mft -min for HSS service.    Spray towers cool the cell gas stream
to near ambient temperatures.
     Properly operated  and  maintained spray towers can achieve removal
efficiencies  for potline HF in percentages ranging from the low to hioh
nineties.   Compared with other types of wet scrubbing equipment, spray
towers  show relatively  low  removal  efficiency for fine particulates.
Spray towers  in  HSS service appear to perform less efficiently than similar
                               6-35

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scrubbers in prebake or VSS service.  This has been suggested to be the
result of an interference by the hydrocarbons in the wetting of the particu-
                                                31
lates and diffusion of HF to the spray droplets.
     Typical gaseous fluoride removal efficiencies are 95 percent
for prebake potlines, 99 percent for VSS potlines, 93 percent for HSS
potlines, and 96 percent for anode bake plant ring furnaces.  '33  Typical
particulate fluoride removal efficiencies are 80 percent for prebake
                                                                        33
potlines, 75 percent for VSS potlines, and 64 percent for HSS potlines.
     Additional information on spray towers can be found in many texts
including references 32 and 34.   Two points worth mentioning are:
     1.  As with any mass transfer unit, the added increase in
         fluoride removal efficiency drops off rapidly with each
         subsequent mass transfer stage; therefore, the attainment of
         fluoride removal efficiencies that are higher than those
         previously given is most difficult.
     2.  Exhaust from a redwood  spray tower that is capped with a
         cone mist eliminator can be easily ducted to other control
         equipment (such as an ESP)  downstream of the tower.  On the
         other hand, it is difficult to cap redwood towers that were not
         originally designed with caps.  Such capping is necessary in
                                                             4
         ducting the exhaust to  downstream control  equipment.

6.2.2.2 Wet Electrostatic  Freetpttator  CESP)  -  -  The electrostatic
precipitator is a  relatively large  chamber through which  cell  gas  streams
pass  at low velocity,  usually 3  to  5 feet  per  second  (ft/sec).   In  its
usual  form,  high  negative  voltage corona discharge wires  are  suspended
                                t>-36

-------
across  the  air  stream and  grounded collector plates form parallel
passageways for the air.   The ionizing field surrounding the discharge
wires ionizes part of the  gas stream and imparts electric charge to most
particles,  some positive but most negative.   Positively charged particles
migrate toward  the discharge wires and negatively charged particles
migrate to  the  grounded collection plates.   When collected particles
lose their  charges, they tend to agglomerate and collect on the surface.
     The removal  efficiency of electrostatic precipitators for many
kinds of particulate is improved if the entering gas is conditioned
by raising  its  moisture content.  When applied to VSS or HSS potlines,
precipitators are usually  preceded or followed by a spray tower that
removes most gaseous fluoride.   Spray towers preceding precipitators
also condition  the gas. However, for some HSS retrofits, space limita-
tions and requirements for balanced ducting layouts have necessitated
removal of  the  spray towers that would have otherwise preceded the
ESPs.  In these instances, effective gaseous fluoride control and
conditioning is achieved by a scrubbing section in the ESP inlet.
     Electrostatic precipitators fall into two categories:  dry ESPs
where the collected particulates are knocked off the plates and wires
by mechanical rapping to be gathered dry in a hopper; and wet ESPs where
the plates  and  wires are washed with falling water or electrostatically
collected mist  with the particulates removed as a slurry.  A dry ESP
followed by a spray tower  is not widely applied as primary equipment for
Soderberg cells since it does not prevent the emission of a blue
hydrocarbon haze.
     Unlike many types of  control equipment, electrostatic precipita-
tors may be designed for almost any selected efficiency.  By using

                              6-37

-------
conservative design dimensions, by controlling humidity of  the  incoming
gas, and by operating at high voltage, both wet and dry precipitators
can achieve 98 to 99 percent removal of potline cell gas particu-
lates.35  Total fluoride removal efficiencies for scrubber-wet  ESP
controls vary from 99.2 to 99.9 percent on domestic VSS plants, and
from 95 to 99 percent on domestic HSS plants.
      Electrostatic  precipitators  operate  at  a  pressure drop of less than
 1  inch  of water.  Typical  power requirements for the wet ESP are 0.66  to 1,
       o                                   3                     29
 hp/Mft  -min  for  VSS service  and 1.4 hp/Nft -min  for HSS service."   Liquor
                                 3       29
 requirements  are 5  to  10  gal/Mft   of gas.    Because wet ESPs are usually
 preceded  by  a wet scrubbing  device, they  operate at near ambient tempera-
tures in potline service.   For anode bake plant service, a typical
power requirement is 3.8 hp/Mft -min, and typical liquor requirements
are 0.3-0.4 gal/Mft3 of gas.29
     Additional information on ESPs can be found  in many texts including
references 35,36, and 37.   Three points worth mentioning are:
     1.  The design of the ESP should insure  that the plates are not
         likely to warp in service.  Such warping will cause the affected
         sections to short out with a resultant loss in removal  efficiency.
     2.  The design of the ESP should insure  that the plates do not
         develop dry spots and short out.   One  plant reports that
         this problem was  overcome by installing  internal sprays to
         continuously irrigate the plates.3
     3.   Wet ESPs in potline service are subjected to corrosive
         operating conditions.  For this reason,  the ESP internals are
                               6-38

-------
        usually of stainless steel construction, and the interior
        steel  shell  walls are lined or coated.  Steel ESPs are likely
        to corrode rapidly unless the composition and pH of the feed
        liquor are carefully controlled."3

 6.2.3  Potroom Secondary Wet Scrubbing
     For practical purposes, choice of potroom secondary control is
                                                         \
 limited to the spray screen scrubber.  The term spray screen scrubber is
 applied to wet scrubbing equipment in which the liquor is sprayed into a
 gas stream and on to screens or open mesh filters enclosed in a plenum
 chamber.  The assembly also usually includes a mist eliminator.  Gas
 flow may be powered by exhaust fans, or may be moved by unpowered con-
 vection.  Figures 6-9 through 6-12 illustrate several designs of spray
 screen scrubber installations that have been used in the primary
 aluminum industry.  "    The particulate removal mechanisms are inertial
 impaction on and interception by the liquid droplets or filters.  The
 gaseous removal mechanism is absorption into the liquid droplets.
     The low gas  pressure drop across spray screen scrubbers and their
 relatively low power cost recommends them for secondary, or potroom,
 scrubbing service.   For secondary prebake service, typical  power require-
ments  are 0.3  to  1.0 hp/Mft3-min and typical  liquor requirements are 3 to
 10 gal/Mft3 of gas. 29
     Table 6-10 gives total  fluoride secondary removal  efficiencies for
                                                   3 13 17 42 43
spray  screen scrubbers  at six existing U.S.  plants.  '  '  '  '
Without primary control,  all  the fluoride generated at the cell is
directed to the secondary scrubbers  that remove 80-85 percent of the total
                               b-39

-------

                                         SPRAY SCREEN
                                         \     i     /
                                   \    \         '
                                 -.



                                  V\\!/,
                                                 '
Figure 6-9.  Unpowered roof spray screen.38
                     6-40

-------
                                                         CLEANED AIR
  AIR
 FROM
POTROOM
                                 SCREEN
                FOUR BANKS OF
                 FINE SPRAYS
COARSE
SPRAYS
                                                       -<
                                                       •<
                                                       <
k
-c
-<
                                                                                                                        AIR
FROM
                                                                                                                      POTROOM
                                     Figure 6-10.  Powered potroom spray screen scrubber. 39

-------
                              SEPARATOR
                               SECTION
FAN
       Figure 6-11.  Powered spray screen scrubber. tf°

-------
                 EXHAUST FAN
      SPRAY NOZZLES
SPRAY CHAMBER.
                                       PLASTIC WIRE MESH
                                             SPRAY NOZZLES
                    WATER COLLECTING TROUGH
        Figure 6-12.  Powered monitor spray screen scrubber.41

-------
Table 6-10.  PERFORMANCE OF SPRAY SCREEN SECONDARY SCRUBBERS AT
                   SIX EXISTING PRIMARY ALUMINUM PLANTS
                        Total Fluoride Secondary Removal Efficiency
Cell Typea
SWPB
SWPB
SWPB
VSS
VSS
VSS
Without Primary
Control
80
-
85.5
-
-
-
With Primary
Control
87
71b
-
75
75
80C
aSWPB - side-worked prebake; VSS-vertical stud Soderberg.
 Projection based upon limited testing.
Projection based upon detailed contractor study.
   fluoride.   With primary control  at SWPB and VSS plants, only 10-20
   percent of the fluoride generated at the cell  escapes the hooding and
   is  directed to the secondary scrubbers.  At this reduced fluoride loading,
   Table 6-10 shows that the scrubbers have a removal  efficiency of 75-80
   percent, on the average.   The two secondary scrubber efficiency readings
   of  80 and  87 percent for the SWPB plant - first line of table - were
   taken at different times,  and emission  variability  and sampling error
   are factors to help explain  why  the two efficiency  figures  seem reversed;
   i.e., the  secondary efficiency should be higher without primary
   control.   However,  the 87  percent reading was  the result of 93 tests,
                                6-44

-------
24 hours per test, and 3 tests per week.  At this same time, 92 similar
tests showed a primary collection (hooding) efficiency of 83 percent.
Thus, the value of 87 percent for secondary removal efficiency in the
presence of primary collection seems firmly supported.  In addition,
one aluminum company had plans to build a new CWPB plant that included
primary control and spray screen scrubber secondary control.    They
anticipated achieving a 98 percent primary collection efficiency, so that
only 2 percent of the fluoride generated at the cell would be directed to
the secondary scrubbers.  At this very low loading, they projected a
secondary removal  efficiency of 75 percent.    Hence, based on this plant's
projected performance and Table 6-10, a secondary removal efficiency of
75 percent should be achievable at almost all plants adding on secondary
                                    46
control to existing primary control.    Although the above mentioned plant
was not built, it was proposed to a State that has extremely strict fluoride
emission limitations, and was based on designs by a major engineering firm
that is highly experienced in the design of aluminum plants and their
emission controls.  It is therefore clear that both the aluminum manu-
facturer and the designer were confident that their proposed secondary
scrubber could achieve 75 percent total fluoride removal after primary
control.
     In practice,  a scrubber designer would balance costs of the simultaneous
addition of packing depth and wash water flow increase; both of these
design factors work to produce increased fluoride removal efficiency.
An additional  factor is, that coarser particulate sizes are the easier
to remove by water scrubbing; addition or improvement of primary hooding
tends to preferentially remove the fine particulate from the secondary
                              6-45

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stream, thus shifting the size distribution to the larger sizes which
are much easier to scrub out in the secondary scrubbers.
     Obviously, either increased packing depth or increased wash water
flow adds to costs.  This is why secondary retrofits should not be
required in most locations (See Section 8.3) and then only if there is
a fluoride problem and costs are balanced against fluoride reduction
benefits.  In addition, secondary scrubbing is rather energy intensive.
     Although more sophisticated scrubbing devices, such as the cross-
flow packed bed scrubber, can achieve higher removal efficiencies for
both particulates and HF than does the spray screen,   the costs are
30 to 100 percent greater and the cost effectiveness much lower when
applied to secondary treatment.  It is the consensus of the industry
that, for secondary treatment in combination with primary control, the
cost differential would be more effectively invested in improved primary
collection and removal equipment.  Among the alternative secondary
scrubbers only the spray screen is considered economically feasible.
     Two points worth mentioning are:
     1.   Although many plants with secondary scrubbing use once-through
          water, tighter effluent regulations will require that the water
          be treated and recycled.  Recycled treated water has the added
          advantage of inhibiting corrosion.
     2.   Although Figure 6-9 through 6-12 show secondary equipment lo-
          cated on the roof, the potroom roof at many plants may not
          support the equipment.  This may be particularly true in northern
          plants that are subjected to heavy snowfalls.  Installing secondary
          controls in the courtyard may be time-consuming and more expensive
          than installing them on the potroom roof.
                              6-46

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6.2.4  Summary of Best  Retrofit Performance
6.2.4.1   Potrooms --  Table  6-11  shows the effects of various degrees of
emission  control on total  participate and gaseous fluoride potroom emissions.
For all four  cell types,  typical  upper and lower evolution limits and
averages-  are  given, each  based  on actual  values reported in Table 5-2.
Best retrofit primary collection  efficiencies are taken from Section 6.1,
an upper  and  a lower limit being  given for all cell types except CWPB.
Best retrofit primary removal efficiencies are taken from Sections 6.2.1
and 6.2.2, an upper and a  lower limit being given for both Soderberg cell
types.  Best  retrofit secondary removal  efficiency is taken from Section
6.2.3.
     Table 6-11 shows that CWPB plants with or without secondary control
consistently  achieve lower average fluoride emissions than do other
cell types.   However, CWPB emissions  without secondary control are
matched at those HSS plants  that  achieve  the upper limits of primary
collection and removal; also, HSS and VSS plants having such upper
limits  and additional secondary control  perform comparably to CWPB plants,
but SWPB  plants do not.
     The  emissions in Table  6-11  bracket  the performance of individual
plants, but any given emission  does not necessarily correspond to that
of any specific plant.  Known and projected emissions for some actual
plants with best primary and secondary control are given in Table 7-3.  In
addition, Section 6.3.4 gives capsule retrofit descriptions for ten
actual retrofits including the  after-retrofit emissions.

                                 6-47

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Table 6-11.   PERFORMANCE OF BEST RETROFIT EMISSION CONTROLS FOR PRIMARY ALUMINUM POTROOMS




Cell
Type
CWPB
II
II
SWPB
II
II
II
II
II
vss
"
II
"
II
II
"
II
II
II
II
"
HSS
u
it
"
"
"
"
"
"
"
n


With or
Average
Fluoride
Evolution,
Lb F/Ton Al
25
40
65
35
M
45
II
55
II
30
II
II
II
45
II
II
II
55
II
II
II
30
n
H
II
35
II
II
II
45
"
"


Without Secondary

Primary
Collection
Efficiency. %
95
"
"
85
80
85
80
85
80
90
II
75
II
90
II
75
II
90
II
75
II
95
11
85
II
95
II
85
H
95
M
85
"

Control

Primary
Removal
Efficiency, %
98.5
"
11
98.5
II
II
II
" II
II
99.9
98.5
99.9
98.5
99.9
98.5
99.9
98.5
99.9
98.5
99.9
98.5
99.0
96.0
99.0
96.0
99.0
96.0
99.0
96.0
99.0
96.0
99.0
96.0
Without Sec-
ondary Control
Average
Fluoride
Emission,
Lb F/Ton Al
1.61
2.57
4.18
5.70
7.42
7.32
9.54
8.95
11.66
3.03
3.40
7.52
7.84
4.54
5.11
11.28
11.76
5.55
6.24
13.79
14.37
1.78
2.64
4.76
5.52
2.08
3.08
5.55
6.44
2.68
3.96
7.13
8.28


With Secondary Control

Secondary
Removal
Efficiency, %
75
"
M
75
II
II
"
II
II
75
II
»
»
II
II
II
II
"
II
II
n
75
II
II
II
II
II
II
II
II
II
II
II
Average
Fluoride
Emission,
Lb F/Ton Al
0.67
1.07
1.74
1.76
2.17
2.26
2.79
2.76
3.41
0.77
1.16
1.90
2.21
1.17
1.73
2.85
3.32
1.42
2.12
3.48.
4.06
0.66
1.52
1.38
2.14
0.77
1.77
1.61
2.50
0.99
2.27
2.07
3.22
                                          6-48

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6.2.4.2 Anode Bake Plants — Table 6-12  shows  the average evolution,
best  retrofit removal efficiency, and  resultant emissions for gaseous,
particulate and total fluoride  at anode  bake  plants.   All of the
quantities are expressed as pounds of  pollutant per ton of aluminum
produced, not per ton of carbon anode  produced.  The evolution rates
in Table 6-12 are the same as those  for  ring  furnaces shown in Table 5-4.
Hence, they are intermediate between uncontrolled total fluoride emission
factors of 1.6 Ib/ton representing poor  cleaning of the anode butts and
of 0.4 Ib/ton representing proper cleaning.   The removal efficiencies
are taken from the EPA contract study.48
     By comparing Table 6-12 with Table  6-11,  it can be seen that the
best retrofit anode bake plant  total fluoride emission is much less
than  the best retrofit potroom  total fluoride emissions.  Total fluoride
emissions from CWPB, VSS and HSS potrooms that have secondary control,
lowest possible evolution rates, and best possible primary collection and
removal efficiencies are about  the same  as uncontrolled total fluoride
emissions from anode bake plants.

  Table 6-12.  SUMMARY OF ANODE BAKE PLANT BEST RETROFIT PERFORMANCE

Gaseous Fluoride
Particulate Fluoride
Total Fluoride
Average
Evolution,
Ib/ton Al
0.816
0.044
0.859
Removal
Efficiency,
%
95
80
94.2
Average
Emissions,
Ib/ton Al
0.041
0.009
0.050
                                 6-49

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6.3  RETROFIT CASE DESCRIPTIONS
     This section contains three case descriptions of  actual  potline
retrofits underway or completed in the United States as of  the  summer
of 1973.  These case descriptions are for best retrofit controls for
specific plants and are not necessarily representative of the industry.
The section contains descriptions, engineering information, performance
results, and cost data for actual retrofits.  Since it is unlikely that
any two aluminum plants will  face the same problems in retrofitting, one
of the objectives of this section is  to make the States aware of many
of the varying problems that  different plants may encounter.  No attempt
has been made to match these  case descriptions with the control  equipment
specified in Section 6.2 or to include all types of cells and control
equipment.
     Instead, engineering descriptions of actual retrofit emission
controls at three primary aluminum plants are presented.   Each case
includes a description of control units, ductwork, supports, fans and
other accessories, along with practical  considerations such as inter-
ferences, spatial relationships, and  procurement and construction
difficulties.  Capital and operating  costs are accompanied by the
overall fluoride reductions obtained  by the expenditures outlined.
The result is a description of some retrofit controls, each of which
is practical for its plant and for its owners and each of which will
meet the performance described.  For  a process as complex as a primary
aluminum plant, it is evident that a  retrofit control must be tailor-
made and should not be generalized as to costs or even as to method
of emission control.
                             6-50

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    •The coverage of the three detailed retrofits in this section is
primarily based upon a trip report covering visits to several primary
aluminum plants  plus supplementary drawings, emission estimates, and
cost data subsequently provided by the plants visited.  Most of the
drawings are considered proprietary in nature and hence are not referenced
in the case descriptions.   Retrofits under construction are described
for mid-1973,  but estimated construction lead times, completion dates,
emission data,  and costs have  been updated.
     Following  the three detailed case descriptions  is a subsection
containing capsule descriptions of the three retrofits and of retrofits
at seven other  plants.  The presentation includes a  summary of the actual
retrofit emission reductions and costs for the ten plants.
    Although EPA conducted source tests at  several  retrofitted plants
in developing the data  base for the standard of performance for new
primary aluminum  plants, most  of the detailed and capsule descriptions
are for plants  other than  the  ones tested.   Furthermore, descriptions
are not given for all  the  plants tested by EPA.   The lettered plant
codes  in the case description  are not meant  to correspond to those in
                                                                   2
the background  document for the new plant standards  of performance.
Whenever possible,  emission data furnished by the companies have been
included with  the ten case descriptions contained herein.
                             6-51

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6.3.1  Plant A--HSS Cells—Primary Dry Scrubbing  Retrofit49
     This plant has three operating HSS potlines (lines 1, 2 and 4)
with wet scrubbers presently used for primary emission control.  Plans
are to retrofit the primary exhaust with two dry scrubbing systems,
one for lines 1 and 2 and one for line 4.  The potlines have no
secondary control and none is planned.
     Dry scrubbing has not previously been installed for HSS primary
control in the United States because of the inherent plugging tendency
of the unburned hydrocarbons in the primary exhaust.  Nevertheless,
tests on a company prototype have shown that the system planned for
plant A effectively removes fluoride, particulate, and hydrocarbon
from the primary exhaust.  However, the long-term effect on metal
purity and potline operation when using the recovered materials in a
"closed loop" system is not yet known.
     Potline operation, present controls, and the planned retrofit are
now described, first for lines 1 and 2 and then for line 4.  Next the
present emissions and the  emissions expected after total retrofit are
presented.  Finally, capital and annual operating costs for the total
retrofit are estimated.
6.3.1.1  Engineering Description - Lines 1 arid 2
6.3.1.1.1  Potline operation — Lines 1 and 2 have a total capacity of
40,000 short tons of aluminum per year  (ton/year).  Each line has 120
cells set  in four rows in  one potroom,  30 cells per row.  The lines
were built in 1942 and the present primary controls were installed in 1951.

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     The cells  in  lines  1  and 2 are unique in that their anodes are
channel-less.   The casing  remains stationary, much as in a VSS cell.
The current-carrying  studs move downward with the anode by means of
vertical  slots  in  the casing.   Anode weight limits usage of this
design to small  HSS cells.
     The cells  in  lines  1  and 2 have total-enclosure hooding with hood
doors extending the full length of both sides of the cell.  A mechanized
time-feed system adds alumina to the cells with the hood doors closed.
This system consists  of  four sets of vertical crust punchers and
alumina feeders, two  sets  on each side of the cell.  At preset time
intervals, the  puncher makes a hole in the crust and the feeder
immediately dumps  alumina  into the hole.  The result of this system
is that over 90 percent  of the alumina is fed with the doors closed
and the cell  doors are only open an average of 8 minutes per cell-
day.  The cell  doors  do  have to be opened to work both sides of each
cell every 24 hours and  to raise the flexible current connectors and
pull the bottom row of studs every 10 to 12 days.  They also have to
be opened every 24 hours to tap the molten aluminum from beneath the
cryolite bath.
6.3.1.1.2  Present controls ~ Two ducts, one on each end of each cell,
pick up the primary exhaust from the top of the cell hoodinq enclosure
and carry it to a  circular manifold duct.  Primary exhausts from 15
cells (half of  one row)  are manifolded together.  Total manifold
exhaust is 30,000  acfm at  150°F, or 2000 acfm per cell.
                             6-53

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     Each manifold originates in the middle of the potroom and grows
in size from a diameter of 2 feet to a diameter of 4 feet as  it proceeds
to a fan that is outside on the end of the potroom.  Each fan is driven
by a 100-hp motor and is upstream of a redwood spray tower.  Hence,
lines 1 and 2 have a total of 16 towers, 4 on each end of each potroom.
Each tower is capped with an inverted cone that serves as a mist elimina-
tor.  The capping was strictly for design purposes, and there was never
any intention of adding on control equipment downstream of the towers
at a later date.
     The plant has experienced emission control problems on lines 1
and 2 because of improper hood sealing and duct pluqgage.  The cell
cathode shells tend to bow down in the center of the sides due to lack
of proper structural support.  This tendency makes effective sealing
of the hood doors difficult.  Duct pluggage is caused by the hydrocarbons
present in an HSS primary exhaust and by the fact that the ducts in
lines 1 and 2 are retrofitted and contain design flaws.

6.3.1.1.3  Aqueous waste -- Water passes once through the spray towers
and, along with the water discharged from the scrubbers on line 4,
goes to water treatment.  At the water treating facility, water from
the scrubbers is fed to a circular, ground-level, open-top reactor
tank about 25 feet in diameter.  Lime is added as a slurry from an
elevated 14-foot by 25-foot tank.  The water is continuously mixed
and bled off to a second circular, ground-level, open-top tank for
continued mixing and reaction but no lime addition.  This second
                             6-54

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tank discharges to a large porid for solids settling.  About three-
fourths of the water is pumped out of the pond and recycled, and about
one-fourth is  discharged to a nearby waterway.  The effluent discharged
to the waterway has a pH of 6.8 to 7.0.
     Upon conversion of the potlines to dry scrubbing, no scrubbing
water will be  discharged from the plant.  The existinq water treating
facility, consisting of reactor tanks and a settling pond, will  remain
to handle the  plant's cooling water, but there will be no lime treating.
6.3.1.1.4  Planned retrofit — The two potrooms comprising potlines 1
and 2 are oriented in a north-south  direction.  The 60-foot  width
of the courtyard between the potrooms will not permit courtyard
installation of the control equipment.  The planned retrofit consists
of ducting all the primary exhaust from lines 1 and 2 to 18 dry scrubbers
located together in an area north of the potrooms.  This is termed
a central, as  opposed to a courtyard, installation.
     Figure 6-13 is a layout of the retrofit for lines 1 and 2,  Table
6-13 lists the major retrofit items.  The ductwork inside the potrooms
will remain unchanged, and the existing fans and spray towers will be
bypassed.  The two circular ducts listed as item 1 in Table 6-13 will
pick up the exhaust from the eight manifolds servicing the south halves
of both potrooms and convey it north between the potrooms.  A new damper
will be required at the end of each manifold.
                            6-55

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en
cr>
                                                            1000-ton
                                                          ALUMINA BIN
                                                                                      X     10 ton/hr
                                                                                      C    AIR SLIDES
                                                                                                         DRY SCRUBBER
                                                                                                             UNIT
                                                    150,000 acfm FAN
                                                    WITH 800-hp MOTOR
                                                       ALUMINA   AIR SLIDE
                                                      UNLO
                                                           ADING
                                                       STATION
20 ton/hr
AIR SLIDE
Jv_  20 ton/hr
vJ>*--AIR SLIDE
                                                                       EXISTING 900-ton
                                                                        ALUMINA BIN
                                             FROM SOUTH
                                             END MAIM I-
                                               HOLDS
                                             Figure 6-13. Retrofit layout -- plant A — lines 1  and 2.

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   Table  6-13.  MAJOR  RETROFIT ITEMS—PLANT A—LINES 1 AND 2
1.    Two  circular  elevated mild  steel  ducts,  each  8  feet  in diameter
     and  700  feet  long, convey primary exhaust  from  the south halves
     of potlines 1  and 2  to  the  retrofit  area north  of the ootlines.
     Each duct  is  designed to handle  150,000  acfm  of exhaust at 180°F.

2.    Four fans, each  driven  by an  800-hp  motor,  designed  to handle
     150,000  acfm  of  exhaust at  180°F and 26  inches  of water total
     pressure drop.   Each fan has  two inlet dampers  and one outlet
     damper.

3.    Two  ground-level  rectangular  mild steel  ducts,  each  about 200
     feet long.  Each duct feeds nine reactor-baghouse dry scrubbinq
     units,  reducing  in size from  a height of 13 feet and a width
     of 6 feet  to  a height of 4  feet  and  a width of  2 feet.

4.    Eighteen mild steel  reactor-baghouse dry scrubbers,  set in two
     rows of  nine  each.   Each scrubber is a rectangular box, 11 feet
     by 42 feet and 15 feet  high.   The top of each scrubber is 40
     feet above the ground.  Each  scrubber has  four  compartments.  Each
     compartment has  a gas inlet section  shaped like an inverted
     rectangular pyramid  on  the  bottom and a  stack on the top, or a
     total of 72 stacks for  the  18 scrubbers.  The stacks are 15 feet
     high, discharging 55 feet above  the  ground.  Each scrubber is
     designed to handle 40,000 acfm of exhaust  at  180°F.  The bag-
     houses on  each scrubber are cleaned  by air pulse, requiring 90
     psig compressed  air. Each  scrubber  requires  one damper in the
     inlet gas  line,  air  activated gravity alumina feed and discharge
     devices, and  five manually  operated  alumina shut-off gates.

5.    Alumina  unloading station containing a hopper with screen to
     receive  alumina  from railroad dump cars.  The station is located
     immediately north of the potrooms.

6.    Combination mild steel  air  slide about 400 feet long.  It is
     designed to simultaneously  convey 50 ton/hr of  fresh alumina
     from the new  unloading  station to the new  fresh alumina storage
     bin  and  20 ton/hr of reacted  alumina from  the scrubbers to the
     four existing 900-ton reacted alumina storage bins that are
     located  at the north ends of  the potrooms.  Each end of the air
     slide is preceded by an equivalently-sized air  lift.

7.    Mild steel 1000-ton  fresh alumina storaae  bin located near the
     18 dry scrubbers with high, intermediate,  and low level bin
     indicators.   The bin is circular, 38 feet  in  diameter, with conical
     top  and  bottom.  Straight side height is 19 feet.  The bottom of
     the  bin  is 45 feet and"the  top is 95 feet  above the  ground.
                          6-57

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   Table 6-13  (continued).   MAJOR RETROFIT ITEMS—PLANT A—LINES 1 AND 2

8.    Two  10 ton/hr mild steel  air slides, each slide  conveying  alumina
     to nine dry scrubbers and equipped with a flow control  valve  and
     a manually'operated shut-off gate.  Total length of  each slide  is
     about 230 feet.
9.    Two 10 ton/hr mild steel  air slides, each slide  conveying  reacted
     alumina from nine scrubbers to an activator  tank that  services
     both air slides and feeds the 20 ton/hr air  slide in item  6.  Total
     length of each slide is about 190 feet.

10.  Three small cylonic dust collectors for alumina  transfer and
     storage operations.
11.  A 30- by 4U-foot control  building with a power substation.
      At the north end of the potrooms, exhaust from the eight manifolds
 servicing the north halves of both potrooms joins the two central ducts
 as depicted in Figure 6-13.  A new damper will be required at the
 end of each manifold.  The central ducts cross a plant roadway and lower
 into rectangular ducts 7 feet wide and 13 feet high.  Each of these ducts
 handles the total primary exhaust from one potroom of 300,000 acfm at
 180°F.  Each duct splits and feeds two of the four fans installed on a
 north-south axis.  As shown in Figure 6-13, the two north fans move
 exhaust from potline 2 to feed the nine dry scrubbers on the north side;
 while the two south fans handle potline 1 and feed the dry scrubbers
 on the south side.
      The per-cell primary exhaust rate on lines 1 and 2 should increase
 from 2000 acfm at 150°F to 2500 acfm at 180°F.  Hence, the primary
 collection efficiency on lines 1 and 2 should increase.  The ducts
 inside the potrooms are undersized for handling the increased flowrate,
 resulting in a high fan pressure drop requirement and a resultant
 increased power cost.  However, it was considered to be more economical
 to leave the internal ducts unchanqed.
                                b-58

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     Dry scrubbing involves reaction of gaseous fluoride with alumina
followed by baghouse collection of fluoride and non-fluoride particulate.
The scrubbers  are  sized so that any one in a set of nine can be off-
line at a given  time and the remaining eight will  still handle the 300,000
acfm exhaust.
     Considerable  solids handling is involved in the retrofit.  Presently
each of the four existing 900-ton alumina storage bins has its own small
alumina unloading  station.  A new larger alumina unloading station
is needed to supply fresh alumina to the dry scrubbers.  The existing
stations will  be left as a backup.  The percentage of the alumina cell
feed that will have to pass through the dry scrubbers is not known, but
all of the solids  handling equipment is befno designed for 100 percent
feed.  Alumina will  normally pass once through the scrubbers before
being fed to the cells, although it will be possible to recycle alumina
from two of the  four reacted alumina storage bins to the fresh alumina
storage bin.   It will  also be possible to unload fresh alumina directly
to the four reacted alumina storage bins.  All of the air slides will
be operated by blowers.
     The fans, the fresh alumina storage bin, and the dry scrubbers
will occupy an area roughly 350 feet long by 150 feet wide.  To
accomodate the equipment, a 25-by 100-foot engineering building had to
be torn down,  an existing well had to be covered, and some power lines
had to be moved.   The existing control equipment will be left in place
until  the tie-in to the dry scrubbers is made and will then be removed.
     Retrofit  items that are common to lines 1 and 2 and to line 4 are:
     1.   A 25- by  100-foot bag rehabilitation buildino.
                              6-59

-------
     2.  A 45- by 50-foot compressor building to supply  compressed
         air to the baghouse (cleaned by air pulse).
     3.  A crane to remove the baghouse internals for maintenance.
     The funding for the retrofits for lines 1, 2 and 4  was
approved in July 1972.  The retrofit for lines 1 and 2 just discussed
was operating in September 1974.  The retrofit  for  line  4 to  be
discussed in the next section was operating in  July 1974.   Hence
total  installation took 26 months.
6.3.1.2  Engineering Description - Line 4

6.3.1.2.1  Potline operation — Line 4 has a capacity of 40,000
ton/year for a total  plant capacity of 80,000 ton/year.  Line 4 has
four rows of 160 cells in two potrooms,  or two 40-cell rows per pot-
room.   The line was completed in 1969 with a centralized primary control
system.  The cells in line 4 are larger than those in lines 1  and 2,
and the anodes have channels.
     The cells in line 4 have total-enclosure hooding with hood doors
exteriding the full  length of both sides  of the cell.  A mechanized
feeding system operates  with the hood doors closed.   However,  rather
than operating at  preset  time intervals, the potline is computer-
controlled, alumina being added on a demand basis.   There are four
crust punchers and four alumina feeders, two to a side, and the puncher
and feeder are both in one vertical  mechanism.  Seventy percent of the
alumina is fed with the  doors closed and the cell doors are only open
an average of 8 minutes  per cell-day.  As in lines 1 and 2, the cell
doors  have to be opened  to work the cells, pull  the studs, and tap the
aluminum.
                                  6-60

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6.3.1.2.2  Present controls — Every cell has a duct at each end that
carries the primary exhaust from the top of the cell hooding enclosure
to a circular manifold duct.  Primary exhaust from 10 cells -- 25 percent
of one cell  row ~ is manifolded together.  These are a total  of 16
cell gas r^nifolds for line 4.  The exhaust rate is 4400 acfm per cell
at 180°F.
     The two potrooms in line 4 are west of lines 1 and 2 and are also
oriented in a north-south direction.  The control equipment for line 4
is southwest of the line 4 potrooms and constitutes a central
installation.  Two elevated circular steel ducts running south alonq
the west side of the westernmost potroom pick up the sixteen 4-foot
manifold ducts, four at a time.  Each set of four pickups consists of
one manifold from each of the four cell rows in the potline.  The
elevated ducts increase in size from a diameter of 6 feet to a diameter
of 10 feet  as they proceed south.   The two ducts .jointly handle all  of
the exhaust from the preceding manifolds.
     Near the south end of the potroom, each elevated circular duct
divides in  two, turns west, and lowers to a pair of ground-level fans.
The four fans are installed on a north-south axis as shown in Figure 6-14.
Each fan is  driven by a 500-hp motor and is rated at 218,000 acfm, a
capacity exceeding the 4400 acfm per cell exhaust rate.  Flow is dampered
during normal dual-fan operation,  and if one fan is not operating, the
exhaust rate only drops 30 to 40 percent in the respective feeder duct,
not 50 percent.
     Exhaust from each pair of fans is recombined into a rectangular
steel  duct.   The two rectangular ducts proceed west, then north
to four cement blockhouse scrubbers in one building.  One rectangular
                               6-61

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  1000-ton
ALUMINA Bl
1













i

1-

f

f

1

1

F

f

t

          11
CONTROL
BUILDING
^
I

I

I

I

\

\

\

%

1
AIM OL
^S
\

\

f












                     RY SCRUBBER
                        UNIT
                                        0   15  30     60
                                            J   I	
                                            SCAL E, ft
                                                  150.000 acfm
                                                 FAN WITH 700-hp
                                                     MOTOR
EXISTING DAMPER
  AND DUCT-
    ,WORK
                                                                             FROMPOTLINE4
                    Figure 6-14.  Retrofit layout -- plant A - line 4.
                                    6-62

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duct feeds  two scrubbers from the east side of the building and the
other feeds two scrubbers from the west side.
     Each of the four scrubbers has three gas inlets to a single spray
chamber, the inlets  being on the same horizontal  plane.  There is a bank
of nine countercurrent sprays at each inlet.  The qas flows upward
through the chamber  and out the top through a single exit.  Near the
top is another bank  of countercurrent sprays, with a mist eliminator
above this  bank.  Gas enters the scrubbers at 150 to 160°F and leaves
at about 5°F above ambient temperature.  Hence scrubbing causes a
loss of thermal  stack lift.
     Rectangular wooden ducting conveys the exhaust from the four
scrubbers to a common inlet on a single stack that discharges to the
atmosphere  500 feet  above grade.
     The plant has experienced less emission control problems on line 4
than on lines 1  and  2.  The cell cathode shells do not bow down in the
center of the side,  making tight hooding possible.  The ducts are better
designed to handle the hydrocarbons in the primary exhaust.
     Water  passes once through the cement blockhouse scrubbers and,
along with  the water discharged from the scrubbers on lines 1 and 2,
goes to water treatment.  The operation of the water treating facility is
described in subsection 6.3.1.1.3.

6.3.1.2.3  Planned retrofit — The planned retrofit consists of rerouting
the line 4  primary exhaust downstream of the fans.  The primary exhaust
will  go to  18 dry scrubbers located together in an area west of the
blockhouse  scrubbers — again a central installation.  The existing
scrubbers will  be bypassed.
                              6-63

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     Figure 6-14 is a layout of the retrofit for line 4, and Table 6-14
lists the major retrofit items.  The ducting to the f?.ns will  remain
unchanged.  The existing fans will be modified to handle the increased
pressure drop requirement.  Primary exhaust from all four fans is
ducted together as shown.  Hence, four fans handle both potrooms of
line 4 and feed all 18 dry scrubbers as pictured in Figure 6-14.
     The per-cell primary exhaust rate on line 4 should not increase
as a result of the retrofit.  Hence, there should be no increase in
the primary collection efficiency.
     The dry scrubbers are sized so that at least two of the 18 can be
off-line at a given time and the remaining scrubbers will still handle
the 600,000 acfm exhaust.  Originally the plant planned to manifold
the 72 stacks and convey all the scrubbed line 4 primary exhaust to the
existing 500-foot stack.  However, a private firm did a meteorological
study that indicated that it was not necessary to go to the stack in order
to achieve ambient air quality standards.  The plan now is not to use
the stack.  One advantage in not using it is the ability to pinpoint
broken bags.  The 72 stacks could be tied in to the existing stack at a
later date.
      As in the retrofit for lines 1 and 2, considerable solids
 handling is involved in the line 4 retrofit.  The existing alumina
 unloading station is adequate to supply fresh alumina to the dry
 scrubbers.  All of the solids handling equipment is being designed
 for 100 percent feed.  Although one-pass feeding to the scrubbers is
 planned, it will be possible to recycle alumina from the reacted alumina
 storage bin to the fresh alumina storage bin.   It will  also be possible

                             6-64

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        Table 6-14.  MAJOR  RETROFIT  ITEMS—PLANT A—LIKE 4
1.   Four  fans, each modified  to  handle  150,000  acfm  at  180°F  and  20
     inches of water total  pressure  drop and  driven by a 700-hp motor.
     Modification will  include a  new damper on the outlet of each  fan.

2.   Two ground-level  rectangular mild steel  ducts, each about 150
     feet  long, feeding into one  rectangular  duct about  200 feet lonq.
     The latter duct feeds  all  18 reactor-baghouse dry scrubbing units,
     reducing in size  from  a height  of 13 feet to a height of  4 feet.

3.   Eighteen mild  steel  reactor-baghouse dry scrubbers, set in two
     rows  of nine each.   Each  scrubber is a rectangular  box, 11 feet
     by 42 feet and 15 feet high.  The top of each"scrubber is 40  feet
     above the ground.   Each scrubber has four compartments.   Each
     compartment has a gas  inlet  section shaped  like  an  inverted
     rectangular pyramid  on the bottom and a  stack on the top, or  a
     total of 72 stacks  for the 18 scrubbers.  The stacks are  15 feet
     high, discharging 55 feet above the ground.  Each scrubber is
     designed to handle 40,000 acfm  of exhaust at 180°F.  The  baghouses
     on each scrubber  are cleaned by air pulse,  requiring 90 psio  com-
     pressed air.   Each scrubber  requires one clamper  in  the inlet  aas
     line, air activated  gravity  alumina feed and discharge devices,
     and five manually operated alumina  shut-off gates.

4.   Combination mild  steel belt conveyor-air slide about 500 feet
     long. The 24-inch belt conveyor is designed to  handle 100 ton/hr
     of fresh alumina.   An  existing  belt conveyor transports alumina
     uphill from the existing  unloading  station  east  of  the line 4
     potrooms to the top  of the existing 2750 ton reacted alumina
     storage bin.   This  bin is located between and above the two line 4
     potrooms, centered along  the length of the  potrooms.  The new
     conveyor transports  alumina  from the existing conveyor up a slight
     grade to the top  of  the new  fresh alumina storage bin —  item 5.
     The 20-ton/hr  air slide returns reacted  alumina  from the  scrubbers
     to the existing reacted alumina storage  bin.  The air slide is
     preceded by a  20-ton/hr air  lift.

5.   Mild  steel, 1000-ton fresh alumina  storage  bin located near the
     18 dry scrubbers  with  high,  intermediate, and low level bin
     indicators.  The  bin is circular, 38 feet in diameter, with
     conical top and bottom.   Straight side height is 19 feet.  The
     bottom of the  bin is 45 feet and the top is 95 feet above the
     ground.

6.   Two 10-ton/hr  mild steel  air slides, each slide  conveying alumina
     to nine dry scrubbers  and equipped  with  a flow control valve  and
     a  manually operated  shut-off gate.   Total length of each  slide
     is about 190 feet.
                               6-65

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  Table 6-14 (continued).  MAJOR RETROFIT  ITEMS-PLANT A—LINE 4
7.   Two 10-ton/hr mild steel  air slides, each slide conveying reacted
     alumina from nine scrubbers to an activator tank that services
     both air slides and feeds the 20-ton/hr air slide in item 4.
     Total  length of each slide is about 230 feet.
8.   Four small  cyclonic dust collectors for alumina transfer and
     storage operations.
9.   A 20- by 25-foot control  building.
 to unload fresh  alumina  directly  to  the  reacted alumina storage bin.  All
 of the air slides  will be  operated by blowers.
      The fresh alumina storage  bins  and  the dry scrubbers will  occupy
 an area roughly  220  feet long and 110 feet wide.   Nothing had to be
 torn down or moved to accomodate  the equipment.  The existinq cement block-
 house scrubbers,  located east of  the dry scrubbers, will  continue to
 operate until the  tie-in to  the dry  scrubbers  is  made and will  not be torn
 down afterwards.
      The fate of  the existing waste  treating facility is  explained in
 subsection 6.3.1.1.3.
      Retrofit items  common to line 4 and to line  1  and 2, and estimated
 installation times are given at the  end  of subsection 6.3.1.1.4.

 6.3.1.3  Emissions Before  and After  Retrofit
      Tables 6-15 and 6-16  present data on before and after
 retrofit emissions provided  by  the  operating company in mid-
 1973 and re-submitted  in October  1974.  Table 6-15 shows the
 quantities of fluoride and particulate generated at the cells, the
                              6-66

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Table 6-15.  BEFORE RETROFIT EMISSIONS-PLANT A--LINES 1,2, AND 4
                           (Ib/ton AT)

Fluoride (as F")
Gaseous
Particulate
Total
Particulate
Dry solids
Condensibles
Total
Generation

19.0
11.0
30.0

114.3
12.8
127.1
Emissions
Primary

5.0
-fc.5
7.5

20.1
9.0
29.1
Secondary

0.6
1.2
1.8

9.5
0.9
10.4
Total

5.6
3.7
9.3

29.6
9.9
39.5
Removal

13.4
7.3
20.7

84.7
2.9
87.6
Table 6-16.  AFTER RETROFIT EMISSION ESTIMATES—PLANT A—LINES 1,2,  AND 4
                              (Ib/ton Al)

Fluoride (as F")
Gaseous
Particulate
Total
Particulate
Dry solids
Condensibles
Total |
Generation

19.0
11.0
30.0

114.3
-12.8
127.1
Emissions
r Primary

0.4-0.6
0.2-0.4
0.6-1.0

2.0-3.0
T. 5-2.5
3.5-5.5
Secondary

0.5
1.1
1.6

6.0
0.5
6.5
Total

0.9-1.1
1.3-1.5
2.2-2.6

8.0-9.0
Z.0-3>0
10.0-12.0
Recovery

18.0
9.6
27.6

105.8
10.3
116.1
                              6-67

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quantities emitted from the present primary  control  equipment and the
secondary building roof monitors, and the quantities removed by the
primary control equipment that eventually become  solid and liquid
waste.  All of the quantities are expressed  as  pounds  of pollutant per
ton of aluminum produced (Ib/ton Al).  The fluoride  values are expressed
as fluoride ion.  Dry solid particulate includes  particulate fluoride as
well as alumina and carbon.  Condensibles could be alternately labeled
"CgH6 Solubles" or "Hydrocarbon Tar Fog and  Gas."
     The generation and emission levels in Table  6-15  correspond  to a
primary collection efficiency of 94 percent, a  primary removal  efficiency
of 73 percent, and an overall control efficiency  of  69 percent on total
fluoride for plant A.  These levels also correspond  to a primary  collection
efficiency of 92 percent, a primary removal  efficiency of 75 percent, and
an overall control efficiency of 69 percent  on  total  particulate.  Overall
control efficiency on hydrocarbon condensibles  is only 23 percent.
     Table 6-16 shows the quantities of fluoride  and particulate  that are
expected to be emitted after the dry scrubbing  retrofit is installed by
late 1974, and the quantities recovered and  recycled to the cells.  The
emissions are preliminary estimates based on prototype tests mentioned in
the introduction of this case description.   Although the retrofit does not
include secondary control, secondary emissions  should  be reduced  through
increased primary collection.  This improved collection should be brought
about by the increase in the per-cell primary exhaust rate on lines 1 and 2,
mentioned under subsection 6.3.1.1.4, and by better  hood sealing  and
improved operating practices throughout the  plant.
                               6-68

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    The emission levels in Tables 6-15  and  6-16  are  averages.
However, the preliminary nature of the data  upon  which  the
primary emissions in Table 6-16 are  based necessitates  stating
these  emissions  in  ranges.
     The  generation and emission  levels  in Table 6-16 correspond to a
primary collection  efficiency of  95  percent, an average primary removal
efficiency of  97 percent,  and an  average overall  control efficiency of
92 percent on  total fluoride  for  plant A.  They also correspond to a
primary collection  efficiency of  95  percent, an average primary removal
efficiency of  96 percent,  and an  average overall  control efficency of
91 percent on  total particulate.   Average overall control  efficiency on
hydrocarbon condensibles  should  increase to 80 percent.
     The  105.8 Ib/ton  Al  of dry  solids that are expected to be  recovered
after retrofit includes 52.4  Ib/ton  Al  of alumina.  This alumina and the
27.6 Ib/ton Al  of fluoride are considered to be the only valuable
materials  recovered.
     Three conclusions that can be drawn from Table 6-16 are:
     1.  The expected  total fluoride emissions for this existing plant
        are somewhat  higher  than the EPA standard of performance for
         new primary aluminum plants of 2.0 Ib/ton Al.
     2.  After retrofit this  plant should be well within the existing
        State  emission standard  of  15 pounds of soVid particulate
        per ton of aluminum produced.   The  retrofit  is  being installed
                              6-69

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         to bring the plant into compliance with the State particu-
         late standard.   The State has no fluoride emission standard.
         According to company personnel, plant emissions have not
         resulted in any fluoride vegetation damage.  The plant is
         located in an industrial region.
     3.   The retrofit should simultaneously bring about low emission
         levels of fluoride, solid particulate, and hydrocarbon.
     The generation and emission levels in Tables 6-15 and 6-16 show
that the ratio of total  particulate to total fluoride at plant A is
4.24 for generation, 4.25 for total (primary and secondary) emissions
before retrofit, and 4.58 for average total emissions after retrofit.
6.3.1.4   Capital and Annual Operating Costs of Retrofit

6.3.1.4.1  Capital costs — Table 6-17 presents actual capital costs
and estimates for the total retrofit furnished by the company in
December 1974 and broken down into the major retrofit Items.  Al-
though the installation is complete, not all of the final figures are
known.  Assuming an annual aluminum capacity of 80,000 tons, $11,313,000
is equivalent to a capital cost of $141 per annual capacity ton.
     The largest cost item in Table 6-17 is ductwork.  Of the $1,819,000,
$1,600,000 is estimated for the  collector  ducts on lines 1 and 2.
Equipment purchase costs for fans, reactors, and baghouses amount
to $200,000, $500,000, and $987,000 respectively.  Costs of the
seven small cyclonic dust collectors listed in Tables 6-13 and
                             6-70

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Table 6-17.  RETROFIT CAPITAL COST ESTIMATE—PLANT A—LINES 1,2, AND 4

  Direct—Capital
      Ducts                                $1,819,000
      Fans                                    341,000
      Reactors                              1,775,000
      Baghouses                             1,269,000
      Alumina transfer                      1,196,000
      Alumina storage                         415,000
      Electrical                              975,000
      Instrumentation and sampling            320,000
      Bag maintenance                         670,000
      Compressed air                          458,000
      Capital spares                            60.000
          Subtotal                         $9,298,000
  Direct—NonCapital
      Preoperating expense                 $  150,000
      Equipment testing                         35.000
          Subtotal                         $   185,000
  Indirect—Capital
      Engineering   «.                       $1,830,000
      Contingency
      Escalation                                 -
          Subtotal                          $1,830,000
  Project total                              $11,313,000
                                6-71

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6-14 are covered under alumina transfer and storage  in  Table  6-17.
Site preparation costs total $367,000 and are covered under ducts, fans,,
reactors, and alumina storage in Table 6-17; the costs  include
building and equipment demolition both before and after retrofitting.
Of the $320,000 for instrumentation and sampling, the control buildinas
are estimated at $68,000, instrumentation at $220,000,  and sampling at
$30,000.  All of the sampling cost is for gas sampling; part  of it for
sample ports and part for sampling equipment.  The  $670,000 for bag
maintenance covers the cost of the aforementioned (see  subsection
6.3.1.1.4) bag rehabilitation building, a mobile crane  and associated
equipment.  The $458,000 for compressed air covers  the  cost of the
aforementioned compressor building and associated equipment.  Of the
$1,830,000 for engineering, engineering performed by the operating
company is estimated at $200,000; plant engineering  at  $60,000; con-
struction management at $200,000; and contract engineering, fee, and
procurement at $1,160,000 for a total actual engineering cost of
$1,620,000.  There are no contingency and escalation costs since total
installation is complete.
     All of the ducts, reactor-baghouses, bins, and  conveyors are mild
steel construction.  This is a cost advantage that a dry control retrofit
enjoys over a wet ESP retrofit, as the latter normally  requires 316
stainless steel construction.
     The book value of all assets to be retired as a result of the
retrofit was $801,214 as of December 31, 1971.  Approximately
50 percent of these assets will be demolished or abandoned in place.
                              6-72

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The remaining assets,  including  fans,  motors,  pumps,  and steel
ductwork, may have some  salvage  value  if they  can be  sold.   Because
of the  uncertainty of  the  disposition  and recoverable value of
these assets, their  salvage  value  has  been ignored by the company
in its  capital  cost  estimate.
     The company has done  considerable development work at this plant
and at  other locations.  These development costs are not reflected
in Table 6-17.
6.3.1.4.2  Annual  operating  costs  — Table 6-18 is a company estimate
of what the gross  and  net  annual operating costs of the total  retrofit
should  be during the first year of operation.   Net annual operating cost
for the before-retrofit control  is estimated to be $292,800.
Assuming a daily aluminum  production of 205 tons equivalent to an
annual  production  of 74,825  tons,  the gross annual operating cost in
Table 6-18 of $741,450 amounts to  $9.91 per ton.  Making the same
assumptions, the net annual  operating cost of -$65,128 amounts to
-$0.87  per ton.  The negative net  annual operating cost does not
represent profit because capital-related charges are not included.
     Most of the items under gross annual operating cost in Table 6-18
are self-explanatory.   The electric power rate is equivalent to 2.99
mills per kilowatt-hour, which is  very low for the United States.  Part
of the  power requirement is  for producing compressed air for bag clean-
ing.
                             6-73

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Table 6-18.  RETROFIT ANNUAL OPERATING  COST  ESTIMATE—PLANT A--
                          LINES 1, 2, AND  4
Gross Annual Operating Cost
Based on 1975 (first year of operation) cost  levels.
     Operating Supplies
     Bags:  28,080 installed + 5% damaged = 29,484  replaced
            once per 18 months or 19,656 per  year
                 19,656 replaced @ 5.50 each  =                 $108,108
     Other supplies (15% of operating labor)                     30,500
                                                               $138,608
     Operating Labor
     Bag change-out @ 3 bags/manhour @ $8.55/manhour
          19,656  X $8.55                                      $  56,020
            3
     Operating and control:  1 operator/shift = 8,760
     manhours at $10.31/manhour                                  90,316
     Fan and duct cleaning:  7,500 manhours @ $7.60/manhour     57,000
                                                               $203,336
     Maintenance
     Labor:  11,484 manhours @ $12.47/manhours                 $143,205
     Material:  57% of labor                                     81,627
     Outside contract:  Painting @ $140,000/5 years              28.000
                                                               $252,832
     Power
     49,056 megawatt-hours @ $2.99                             $146.677
                       Total Gross Annual Operating Cost       $741,450
Value of Recovered Material
     Alumina Recovered:   1960 ton/year @ $96.80/ton           $189,728
     Aluminum Fluoride Recovered:  1690  ton/year  @ $3657ton   616.850
                    Total  Value of Recovered  Material          $806,578
Net Annual Operating Cost                                    -$  65,128
                             6-74

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     As mentioned in subsection 6.3.1.3, only the recovered alumina
 and fluoride are considered to be valuable materials.  The amount of
 recovered alumina is estimated from a recovery rate of 52.4 Ib/ton Al
 and an annual production of 74,825 tons.  The amount of recovered
 aluminum fluoride is estimated from a recovery rate of 27.6 Ib/ton Al
 (Table 6-16) equivalent to 45.2 pounds of aluminum fluoride containing
 61.1 percent fluoride, and an annual production of 74,825 tons.  The
 latter estimate assumes that both gaseous and particulate fluoride
 ion will be returned to the cells as aluminum fluoride.  An alumina
 cost of $96.80 per ton is equivalent to 4.8 cents per pound.  A cost
 of $365 per ton for aluminum fluoride containing 61.1 percent fluoride
 is equivalent to 29.9 cents per pound of fluoride.  By comparison, an
 EPA contract study gives 1971 recovered alumina and fluoride values
                                            50
 of 3.2 and 25 cents per pound, respectively.    The value of recovered
 materials has increased due to rather significant increases in the
 value of alumina which reflects the recent changes in bauxite prices
 around the world, as well as some increase in the value of fluorides.
     Net annual  cost includes the above operating costs  along  with
capital-related  charges.   Such charges  include depreciation,  interest,
administrative overhead,  property taxes,  and insurance.   These were
not  furnished by the company  and,  hence,  are not  included in Table 6-18.
Based oh  a  "capital  recovery" factor of 11.683 percent,  an "administrative
overhead" factor of  2  percent,  and a "property taxes  and insurance"
factor of 2  percent,  capital  related charges would amount to  15.683
percent of capital cost  for this  retrofit.   The "capital  recovery"
factor covers depreciation and  interest and  is based  on  a 15-year equip-
                             6-75

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ment life and 8 percent interest.  Capital related charges for
this retrofit thus amount to 15.683 percent of $11,313,000 — or
$1,774,218.   Adding these charges to Table 6-18 would result in a nross
annual cost of $2,515,668 and a net annual cost of $1,709,090.
6.3.2 Plant B—HSS Cells—Primary Wet  ESP  Retrofit51
     This plant's reduction facilities include two HSS plants — a
south plant and a north plant.  Primary control presently consists
of wet scrubbers, but plans are to retrofit the primary exhaust with
31 wet electrostatic precipitators, 10 for the south plant and 21  for
the north plant.   The plants have no secondary control and none is
planned.
     Wet ESPs  are being installed because:
     1.   The presence of a cryolite recovery plant to handle the
         scrubber-ESP effluents makes dry scrubbing less attractive.
     2.   Aluminum product purity at plant B is high, among the
         highest in the nation.  According to plant personnel, dry
         scrubbing with attendant recycle would lower this purity.
     3.   High  energy scrubbers would require excessive power inputs
         to achieve the desired control.
      4-  The  cross flow  packed bed  scrubber  with  TelleretteR  packinci
         applied to  an HSS  potline  will  plug after only 30 minutes of
         operation.
     5.   Although the floating bed scrubber does not plug, it cannot
         attain as high a level of control  as the  ESP.
                              6-76

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     Potline  operation,  present controls, and the planned retrofit
are now described,  first for the south plant and then for the north
plant.   Next  the  present air emissions and the emissions expected after
Urtal  retrofit  are  presented.   Then the plant's present water treating
facility and  the  changes to  it necessitated by the retrofit are
explained.  Finally,  capital  and annual operating costs for the total
retrofit are  estimated.

6.3.2.1   Engineering  Description -- South Plant

6.3.2.1.1   Potline  operation -- The south plant has three potlines and
a total  capacity  of 70,000 ton/year.  Each potline has 124 cells set in
four rows  in  one  potroom for a plant total of 372 cells.  The ootrooirs
have sidewall ventilation.  The plant was built in 1941 and expanded
in 1952.
     The cells  have total-enclosure hooding with manually operated steel
roll-down  hood  doors  extending the full length of both sides of each
cell.   Pollutants continuously escape from the top of the cell enclosure
and also from the hood doors when they are open.  The doors have to be
opened  frequently to  add alumina to the cryolite bath by working the
cell,  to tap  the molten  metal  layer from beneath the bath, and to
insert  and  remove studs  from the anode block while raising the flexible
current  connectors.
                              6-77

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6.3.2.1.2  Present controls -- Four 8-inch ducts, two on each end
of each cell, pick up the primary exhaust from the top of the cell
hooding enclosure and carry it to a circular manifold duct.  Each
manifold handles primary exhaust from 15 or 16 cells.  The primary
exhaust rate is 2000 to 2500 acfm per cell at 200°F.
     Each manifold leads to a fan that is driven by a 50-hp motor
and is located just outside the potroom.  Originally each fan was
upstream of one Douglas fir spray tower, each potroom having eight
spray towers apiece.  However, four of the 24 towers have been replaced
by two larger towers, the larger towers each handling exhaust from two
fans or manifolds.  Each tower is capped with an inverted cone.  The
20. smaller towers are each about 8 feet in diameter and 35 feet high,
and the two larger towers are each about 15 feet in diameter and 50 feet
high.  By way of comparison, the peaks of the adjacent potrooms are 39 feet
high and the tops of the roof monitors are 22 feet above the peaks, for
a total building height of 61 feet.
     The towers are equipped with dual sprays that are fed with a cir-
culating alkaline solution that contains 2 grams of fluoride per liter of
solution.  Because fine sprays plug, plant personnel consider it essential
to use a coarse spray and thoroughly wet  the walls of the tower in order
to maximize gaseous and particulate fluoride removal efficiency.

6.3.2.1.3  Planned retrofit — Figure 6-15 is a layout of the south
plant retrofit and Table 6-19 lists the major retrofit items.  The
three potrooms are oriented in a northeast-southwest direction.  The
                                6-78

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0  25  50     100

    SCALE, ft.
                                        POTROOM L
                                        POTROOM K
                                         POTROOM J
                                                                                                      \
                                                                         14 ft.
                                                                     DUCT DI-
                                                                      AMETER
5 ESP'S
                                                                         7 ft.
               Figure 6-15.  Retrofit  layout - plant B - south plant.

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     Table 6-19.   MAJOR RETROFIT ITEMS—PLANT B—SOUTH PLANT
1.  Several  circular elevated mild steel ducts conveying primary
    exhaust to two retrofit areas southeast and southwest of the
    plant.   For each area, 4-foot ducts combine and grow into
    one 14-foot duct that reduces in size to 7 feet as it feeds
    5 ESPs.
2.  Ten fans, each driven by a 300-hp motor and upstream of an ESP.
    Each fan is designed to handle 100,000 scfm of exhaust at about
    4 inches of water total pressure drop.
3.  Ten steel ESPs each designed to handle 100,000 scfm of exhaust.
    Each ESP is a rectangular box 29 feet square and 29 feet high with
    a stack discharging about 80 feet above the ground.  Each ESP
    has a gas side-inlet section of flattened rectangular pyramidal
    shape.
4.  A 20- by 50-foot control building.
planned retrofit consists of ducting all the primary exhaust from
potroom J and half from potroom K to five ESPs located together as shown
in Figure 6-15, and ducting all the primary exhaust from potroom L and
the other half from potroom K to five ESPs also located together.  Each
set of five ESPs is termed a central installation.
     The per-cell primary exhaust rate will be increased from 2000-2500
acfm at 200°F to 3500 acfm at 200°F, increasing the south plant's
primary collection efficiency.  The ducts inside the potrooms are
presently oversized, so they will not have to be modified to handle
the increased flowrate.  Primary collection efficiency will also be
improved by installing new motorized doors on the cells and sealing
the top of each cell's hooding enclosure with glass wool.

                              6-80

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     Redirecting the south plant's primary exhaust from courtyard
to central  controls will require a balanced ducting layout design
that ensures equal pressure and flowrates in all of the 12 manifolds
that are serviced by each set of 5 ESPs.
     The ducting changes for this central retrofit will be external
to the potrooms.  The existing fans and spray towers will be bypassed.
All of the spray towers will eventually be torn down, but many will
have to be torn down during the installation to make room for the
ducting shown in Figure 6-15.  This will mean that portions cf the
plant will  run uncontrolled for varying periods of time during the
installation.  Nothing but the spray towers will have to be torn
down as a result of the south plant retrofit.
     Removal of the existing spray towers will force the wet ESPs
to act as absorbers for gaseous fluoride and require that liauor be
fed to the inlet sections of the ESPs.  Plant personnel hope to control
corrosion of the ESP steel internals by controlling the composition and
pH of this feed liquor.  Even so, they anticipate having to rebuild the
internals every 10 years.
     Estimated installation times are given at the end of Subsection
6.3.2.2.

6.3.2.2  Engineering Description - North Plant

6.3.2.2.1  Potline operation — The north plant also has three potlines
and has a capacity of 140,000 ton/year for a total plant capacity of
210,000 ton/year.  Each potline has four rows of 168 cells in two pot-
                                 6-81

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rooms, or two 42-cell  rows per potroom, for a plant total of 504
cells.  The potrooms have sidewall  and basement ventilation.  The
plant was built in 1968.
     The cells are elevated slightly above the floor and have total -
enclosure hooding with mechanically operated aluminum doors extending
the full length of both sides of each cell.  Comments on emissions from
the top of the cell  enclosure and on door opening for the south plant
also apply to the north plant.

6.3.2.2.2  Present controls — Four ducts, two on each end of each
cell, pick up the primary exhaust from the top of the cell hooding
enclosure and carry it to a circular manifold duct.  One manifold
handles primary exhaust from 14 cells.  The primary exhaust is 3600
scfm per cell.
     Each manifold proceeds to a 50,000 scfm fan that is driven by a
125-hp motor, is located outside the potroom, and is upstream of a
spray tower.  Figure 6-16 shows the general location of the 36 spray
towers at the north plant.  Each tower is 13 feet in diameter and is
capped with an inverted cone that connects to a 5-foot stack.  This
stack discharges to the atmosphere about 70 feet above the ground.
By way of comparison, the peaks of the potrooms are 54 feet high
and the tops of the roof monitors are 8 feet above the peaks, for
a total building height of 62 feet.  The towers are fed with the same
alkaline solution as the towers at the south plant.
                              6-82

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                                o o

POTROOM
o
o
CO
CO
D
SPRAY TOWERS 	 -<^O
Qi 	 ESP
o
o
D
POTROOM
0
O
D
O
o
D
o
D
POTROOM
O
o
D
8
D
o
o
D
POTROOM
O
o
D
o
o
a
o
o
D
POTROOM
O
o
D
o
o
a
o
o
D
POTROOM
                                o a
o  o
 0  50 100     200

 111     -1
    SCAL f., ft.
Figure 6-16.  Retrofit layout — plant B — north plant (location and position
of control equipment not exact).

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6.3.2.2.3  Planned retrofit — Figure 6-16 is a layout of the north
plant retrofit and Table 6-20 lists the major retrofit items.  The
south end of the north plant is 1100 feet northwest of the north end
of the south plant.  The planned retrofit consists of adding 21  ESPs
downstream of the existing fans and spray towers.  The plan is to install
three 50,000 scfm wet ESPs on the outside of each of the two end
buildings, one per spray tower, and three-100,000 scfm wet ESPs in each
of the five 51-foot wide courtyards between potrooms and between pot-
lines (see Figure 6-16).  Each of the latter ESPs will handle the exhaust
from two spray towers, one from each adjacent building.
     Primary collection efficiency should not increase at the north
plant as a result of the retrofit because the north plant already in-
corporates all of the same modifications that are expected to increase
collection efficiency at the south plant.  The per-cell primary exhaust
rate will remain at 3600 scfm.  The existing fans and spray towers and
all the ductwork upstream of the spray towers will not be changed, and
nothing will have to be torn down as a result of the north plant retrofit.
Downstream of each tower a 5-foot duct will carry the tower exhaust
from the tower's inverted cone to the inlet section of the adjacent ESP.
There will also be a valving arrangement to vent the tower exhaust to
the atmosphere if the ESP is inoperative.
     At the north plant, liquid will be fed to the inlet section of the
ESPs and will pass through an ESP before passing through its associated
spray tower(s).  As at the south plant, plant personnel hope to control
corrosion by controlling the composition and pH of the  liauor,  but
anticipate rebuilding the ESP internals every 10 years.
                             6-84

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      Table 6-20.  MAJOR RETROFIT ITEMS—PLANT B—NORTH PLANT


 1.  Six steel ESPs, each designed to handle 50,000 scfm of exhaust
    Each ESP is a rectangular box 29 feet by 14 feet and 29 feet high
    with a stack discharging about 80 feet above the ground.  Each
    ESP has a gas side-inlet section of flattened rectangular
    pyramidal shape.

 2.  Fifteen steel ESPs, each designed to handle 100,000 scfm of
    exhaust.  Each ESP is a rectangular box 29 feet square and 29
    feet high with a stack discharging about 80 feet above the ground.
    Each ESP has a gas side-inlet section of flattened rectangular
    pyramidal shape.

 3.  Seven 8- by 20-foot control buildings, one for each set of three
    ESPs.
     It was necessary to have the wet ESP tailor-made to the plant.

It was also necessary to prove its operability before makinci a total

plant commitment.  For these reasons, and because of the limited

availability of funds and manpower, the retrofit was completed in

phases.

     In late 1970, design was started on a pilot 50,000 scfm unit on

the north plant.  As of September 1973, one more 50,000 scfm unit and

three 100,000 scfm units were operating on the north plant.  These

five units comprise Phase I of the retrofit.  Phase II involves

installing the remaining 16 ESPs on the north plant, and Phase III

involves installing the 10 ESPs and accompanying fans and ductwork on

the south plant.

     Plant B completed Phases I and II in January 1975 and, as of

 March 1975, planned to complete all three phases by June 1975.  It
                              6-85

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will then have been about 4-1/2 years from the start of  development
through total plant installation.  Had the pilot unit not proven
operational, this time could have been much longer.
     Because the plant's  engineering design capabilities increased
with operating experience, each subsequent phase has taken less time
to design than the former.  By necessity, work on a subsequent phase
begins before the installation of the former phase is completed.

6.3.2.3  Emissions Before and After Retrofit
     Tables 6-21  and 6-22 reflect estimates of emissions before and
after retrofit provided by the company.  All of the quantities are
expressed as pounds of total  fluoride ion per ton of aluminum pro-
duced (Ib/ton Al).  The tables show the quantities generated at the
cells, the quantities emitted from the applicable primary control equip-
ment and the secondary building roof monitors, and the quantities removed
by the primary control equipment that eventually become either cryolite
or liquid waste.   The overall plant average is a weighted average
based on the north plant accounting for 67 percent of plant B's pro-
duction.
     The generation estimates in Tables 6-21 and 6-22 are based on a
statistical analysis for the 10-month period beginning June 1, 1972,
and ending April  1, 1973.  Plant personnel selected this time interval
because the total  plant was at full production and had the fewest
in-process variables to distort the results.  Data from other time
periods would,  of course, be somewhat different.
                              6-86

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Table 6-21.   BEFORE RETROFIT MAXIMUM EMISSIONS-PLANT B--NORTH
                           AND SOUTH PLANTS
                         (Ib total  F'/ton Al)

North plant
South plant
Overall plant
average
Generation
38.2
50.0
42.1
Emissions
Primary
3.6
4.0
Secondary
1.9
10.0
Total
5.5
14,0
8.3
Removal
32.7
36.0
33.8
Table 6-22.  AFTER RETROFIT MAXIMUM EMISSION ESTIMATES—PLANT B--
                          NORTH AND SOUTH PLANTS
                           (Ib total F"/ton Al)

North plant
South plant
Overall plant
average
Generation
38.2
50.0
42.1
Emissions
Primary
0.7
1.4
Secondary
1.9
5.1
Total
2.6
6.5
3.9
Removal
35.6
43.5
38.2
                             6-87

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     The method of analyzing the data was taken from Probability and
                         f o
Statistics for Engineers.'    Sample averages and standard  deviations
were calculated from data derived from the plant's standard monthly
sampling program.  In this program, the plant samples the  input  to and
the output from 6 to 10 spray tower fume control units and the output
from 4 to 6 roof monitor locations.  Different locations are sampled
each month.  The plant's objective is to sample every location across
the plant once every 6 months.
     The average pounds of total fluoride generated per day was  computed
on a monthly basis by adding the average daily emissions from the
monitors to the average daily spray tower inputs per month per plant.
The monthly average pounds of total fluoride generated per ton of aluminum
produced was then computed for each of the 10 months by dividing each such
average generation per month per plant by that plant's average daily
production rate for the month.  The average and the standard deviation
for the 10-month period in each plant was then computed from the 10
monthly averages.  The Kolomogorov-Smirnov Test was conducted on the data
derived for each plant and it was determined that a normal distribution
provided a good fit for each plant and for the total plant.  The generation
estimates in Tables 6-21 and 6-22 represent 95 percent tolerance limits
at a 95 percent confidence level.
     The primary and secondary emissions in Tables 6-21 and 6-22 are
computed by applying estimated primary collection and removal efficiencies
to the above generation estimates.  Estimated primary collection and
                              6-88

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removal efficiencies for Table 6-21 are 95 and 90 percent, respectively,
for the north plant, and 80 and 90 percent, respectively, for the south
plant.  Estimated primary collection and removal efficiencies for Table 6-22
are 95 and 98 percent, respectively, for the north plant, and 90 and 97
percent, respectively, for the south plant.  Assuming a zero percent
secondary removal efficiency, the above primary collection and removal
efficiencies correspond to overall control efficiencies before retrofit
for the north and south plants of 86 and 72 percent, respectively; and to
overall control efficiencies after retrofit for the north and south plants
of 93 and 87 percent, respectively.
     Although not shown in Tables 6-21 and 6-22, the retrofit should
increase the total particulate primary removal efficiency from 55 to
98 percent, and the hydrocarbon primary removal efficiency from a control
level of 8 to 10 percent up to a control level of 92 to 94 percent, the
latter being a ten-fold increase.  The hydrocarbons comprise a substantial
portion of the small-diameter particulate that the present scrubbers are
incapable of removing.
     Table 6-23 contains  revised June 1974 company estimates  of emissions
after retrofit.  The sampling methods and statistical  treatment are the
same as for Table 6-22.   However, the data are averages rather than 95
percent tolerance limits  and are computed over a 14-month period of full
production that includes  the 10-month period used for Table 6-22.  Also,
the primary emission estimates at both the north and south plants are 95
percent confidence level  estimates based on actual testing of primary
emissions at the north plant.  Twelve months of emission'testing in 1972
yielded an average total  emission before retrofit of 5.4 Ib F/ton Al.
                                 6-89

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Table 6-23.  AFTER RETROFIT AVERAGE EMISSION ESTIMATES—PLANT B--
                 NORTH AND SOUTH PLANTS (Ib total F/ton Al)

North plant
South plant
Overall plant
average
Generation
32.1
31.1
31.8
Emissions
Primary
0.25
1.10
Secondary
1.6
4.0
Total
1.85
5.1
2.9
Removal
30.25
26.0
28.9
     The primary and secondary emissions in Table 6-23 correspond to
primary collection, primary removal, and overall control efficiencies
of 95, 99.2, and 94 percent, respectively, for the north plant; and of
87, 96, and 34 percent, respectively, for the south plant.
     From Table 6-22 it can be seen that the maximum expected total
fluoride emissions of 3.9 Ib/ton Al for this existing plant after
retrofit is about twice that of the EPA standard of performance for
new primary aluminum plants of 2.0 Ib/ton Al.  The average expected
total fluoride emission of 2.9 Ib/ton Al in Table 6-23 is somewhat
higher than the average expected total fluoride emission for plant A
of 2.4 Ib/ton Al  shown in Table 6-16.  However, as can be seen by com-
paring the efficiencies for plant B with those for plant A in Section
6.3.1.3, the total  fluoride primary removal efficiency for the wet ESP
retrofit at plant B is the same or higher than the 96 percent primary
removal  efficiency for the dry scrubbing retrofit at plant A.  The
expected total fluoride emissions at plant B are higher than those
expected at plant A because the  primary collection  efficiency  of  the
                             6-90

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 south plant at  plant B after  retrofit is estimated to be only


 87-90 percent.  The primary  collection efficiency  at plant A and at

 the north plant of plant B  are both estimated  to  be 95 percent after

 retrofit.




 6.3.2.4  Water Treatment



 6.3.2.4.1   Current  practice--  Fluoride is removed  from  the  primary exhaust

 in the north and south plant spray  towers into a recirculatinq liquor

 stream.   Fluoride  is  recovered from this liquor as  standard grade (90

 percent) cryolite  in  a cryolite recovery plant.  This recovery is

 illustrated in Figure 6-17:
    LIQUOR
     FROM
SCRUBBING TOWERS
THICKENERS
                                                   ALKALINE LIQUOR
                                                    OVERFLOW
                  SLUDGE OR
                  UNDERFLOW
              NaOH
                                               BLEED
                                                TO
                                               RIVER
                       DIGESTER
             C02
                      PRECIPITATOR
                         TANK
                                           ALKALINE LIQUOR
                                               LIQUOR TO
                                            SCRUBBING TOWERS
                                        (30 grams/liter TOTAL SODA)
                        CRYOLITE
                Figure 6-17.  Flow diagram - plant B -- cryolite recovery plant.
                                6-91

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The lowering of the pH in the precipitator tank causes cryolite
precipitation.
     At the spray towers, the recirculating liquor nicks up some of
the sulfur dioxide that is generated at the reduction cells.  This
causes a sulfate buildup in the liquor, and it is necessary to bleed a
small portion of the liquor to control the sulfate level.  The bleed
is controlled by a constant volume regulator.  It goes directly to a
waste water discharge sump where it is thoroughly mixed  before being
discharged to a nearby waterway.
     Plant B also recovers fluoride from its spent potliner.  It used
to buy potliner from other plants, but no lonner does this due to
stricter water effluent standards.
                                                                  53
    Plant B water effluent loadings are presented in an EPA study.
Plant B in this document is plant J in the EPA study.  Plant B
net effluent loadings include fluoride and suspended solids loadings
of 2.2 and 3.8 Ib/ton Al, respectively.0   By comparison, the recom-
mended 30-day effluent limitations for the primary aluminum industry
to be achieved by July 1, 1977, are 2 and 3 Ib/ton Al for fluoride and
suspended solids, respectively; and the recommended daily effluent
limitations are 4 and 6 Ib/ton Al, respectively.55  These limitations
are considered to be attainable through the application  of the best
practicable control technology.  For wet scrubbing systems, best
practicable control technology is defined as cryolite precipitation
with recycle as practiced at plant B, or lime treatment  with either re-
cycle or subsequent adsorption on activated alumina.06
                              6-92

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     Table 6-21 shows that 33.8 pounds of  total fluoride are removed
 by  the spray towers per ton of aluminum produced.  Plant personnel
 did not provide an estimate of the fluoride recovered from potliners.
 If  we assume the latter to be 20  Ib/ton Al (see Figure 5-5), then the
 cryolite recovery plant handles 53.8  Ib/ton Al of fluoride.  If it is
 assumed that there is 100 percent recovery of fluoride from the pot-
 liners and that the plant's net effluent fluoride loading of 2.2 Ib/ton
 Al  is all attributable to cryolite recovery, then it can be concluded
 that the cryolite plant fluoride  recovery efficiency for plant B is
 95.9 percent.

 6.3.2.4.2  Changes due to retrofit—Presently the hydrocarbons collected
 in  the recirculating scrubber liquor  cause foaming in the cryolite
 recovery plant when treating the resultant sludge.  Such foaming can
 make it extremely difficult to operate sludge treating equipment and
 can result in airborne fluoride emissions.  The plant can process in
 spite of the present foaming, but, as noted in subsection 6.3.2.3,
 the retrofit is expected to result in a ten-fold increase in the hydro-
 carbon collected.   If foaming is a direct function of the hydrocarbon
 content in the sludge, then something must be done.
     The plant has investigated three possible solutions.  The first
 two involve oxidizing the hydrocarbons and the third involves con-
 trolling cryolite plant process variables so foaming does not occur.
     The oxidation methods considered are direct calcination in a
 rotary kiln and the Zimpro wet oxidation process.  Direct calcination
is difficult to operate, has high energy requirements and high operating
                              6-93

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costs, and probably will require one more wet ESP to control emissions.
The performance of the Zimpro process on this type of sludge is not
well known and the capital costs are quite high.
    The plant hopes to be able to identify the process variables that
affect foaming and thus accomplish a solution with considerably lower
capital costs.  As of March 1975, it was not known if oxidation
would be required.
    The plant has no immediate plans to reduce the effluent loadings
associated with its bleed stream.
6.3.2.5  Retrofit Capital and Annual Operating Costs
6.3.2.5.1  Capital costs—Table 6*-24 is a spring 1973 estimate of the
total retrofit capital costs for the north plant, south plant, and the
sludge treatment project broken down into the major retrofit items.
Assuming an annual aluminum capacity of 210,000 tons, $23,457,500 is
equivalent to a capital cost of $112 per annual capacity ton.
    Plant B furnished the direct costs in Table  6-24.  Reduction cell
sealing, new motorized doors, and new fans at the south plant will
increase primary collection efficiency.  Two new thickeners, one for
each plant, are included under phases II and III in Table  6-24; but
in reality, they are part of cryolite recovery.  New thickeners are
needed to handle the higher flowrate and higher fluoride loading re-
sulting from the retrofit and to remove smaller particulate.  Smaller
particulate removal is required because the ESPs will have finer
spray nozzles than the present spray towers, and finer nozzles are more
likely to plug.

                            6-94

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          Table  6-24.   RETROFIT  CAPITAL  COST ESTIMATE—PLANT B
.
Direct costs
Reduction cell
sealing
Motorized doors
Ducts
Fans
Electrostatic
preci pita tors
Foundations
Drains, pumps,
and piping
Thickeners
Electrical
Control buildings
Equipment sales tax
Subtotal s
North plant
Phase I


Not
broken
down






Phase II
-
-
$520,000
-
4,810,000
200,000
200,000
400,000
380,000
42,000
328,000
$1,480,000 i $6,880,000
South plant
Phase III
$200,000
280,000
1,395,000
160,000
3,430,000
300,000
100,000
300,000
1,115,000
30,000
365,000
$7,675,000
Sludge treatment costs
  Site preparation  and foundation
  Slurry tank  and  pumps
  Centrifuge,  kiln, feed screw,
   afterburner and  scrubber
  Treated solids handling equipment
 _Electrical
  Wet oxidation equipment, including
   foundations and  electrical
  Subtotal— sludae treatment  including  sales  tax
$127,000
  33,500

 705,000
 101,000
 156,000

 887.500
$2,010,000
                                6-95

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     Table  6-24 (continued).   RETROFIT CAPITAL COST ESTIMATE—PLANT B
  Subtotal    Phase I                                      $1,480,000
             Phase II                                      6,880,000
             Phase III                                     7,675,000
             Sludge treatment                              2.010.000
  Subtotal  direct costs                                   $18,045,000

Indirect costs
  Engineering                                             $1,804,500
  Contingency                                              1,804,500
  Escalation                                               1,804,500
  Subtotal  indirect costs                                  5,412,500
  Subtotal  direct costs                                    18.045,000
Project total cost                                       $23,457,500


       Sludge treatment  costs are shown for the equipment associated with
  both direct calcination and wet oxidation because plant personnel believed
  that, regardless of the alternative selected, they will probably spend
  $2 million for suitable sludge treatment equipment.  The sludge treat-
  ment equipment will be installed on land that is presently used to store
  used potliners.  The site preparation costs for sludge treatment in Table
  6-24 represent the funds necessary to prepare this land.
       Plant B did not furnish indirect costs.  Engineering, contingency,
  and escalation costs in Table  6-24 are each based  on arbitrary  factors
  of 10 percent of direct capital.

                                 6-96

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    The plant B retrofit would  have  been  more costly had the ESPs
been constructed of 316 stainless  steel,  the  normal  material  of con-
struction for wet ESPs applied  to  an aluminum plant.  As mentioned  on
subsection 6.3.2.1.3, the  plant hopes to  control  corrosion  of the
  asl  internals but still  anticipates rebuilding  the internals every
10 years.
    The assets to be retired  as a  result  of the planned retrofit have
essentially no book value.
    Table 6-25 is an October  1974  update  of the total  retrofit capital
costs  for the north plant, south plant, and the sludge treatment pro-
jects.  Assuming an annual  aluminum  capacity  of 210,000 tons, $19,300,600
is equivalent to a capital  cost of $92 per annual  capacity  ton.   The
direct costs in Table 6-25 are  from  the company.   The  indirect engineering
cost is based on an arbitrary factor of 10 percent of  direct capital.
There  are no escalation and contingency costs since installation is
nearing completion.
            Table  6-25.   REVISED RETROFIT CAPITAL  COST
                               ESTIMATE—PLANT B
             Direct costs
                 North plant                $8,871,000
                 South plant                 7,675,000
                 Sludge treatment            1,000,000
                              Subtotal     $17,546,000
             Indirect costs
                 Engineering                $1,754,600
                 Contingency
                 Escalation                  	-_	
             Project total  cost            $19,300,600

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6.3.2.5.2  Annual  operating costs— Table  6-26 is a company estimate
of year-to-year additional  gross and net annual operating costs for
operating the ESPs after the plant has been retrofitted.  Assuming
an annual aluminum production equal to the annual capacity of 210,000
tons, $171,000 for operating the ESPs amounts to $0.81 per ton.  Plant
personnel stated that, even though these additional costs are quite
modest, annual operating costs for plant B's present system are
substantial.  However, plant personnel are not able to break out the
present emission control annual operating costs.  Also, although
an estimate of annual  operating costs for sludge treatment was not
obtained, plant personnel stated that its operating costs should be
considerably smaller than that shown for the ESPs in Table 6-26.
    The planned retrofit will not directly recover any valuable
material; hence, the zero credit.  Generally, the value of the
fluoride recovered in an aluminum plant that has a wet scrubbing
system and  cryolite recovery is offset by the operating costs of
recovering  the fluoride.
    The  capital-related charges that are part of net annual cost were
not furnished by plant  B and are not included in Table  6-26.  Based on a
"capital recovery" factor of 14.903 percent, an  "administrative over-
head" factor of 2 percent and a "property taxes and insurance" factor
of 2 percent, capital related charges would amount to 18.903 percent of
capital  cost for this retrofit.  Since the plant anticipates rebuilding
the ESPs every "10 years, the "capital recovery" factor covering
                               6-98

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 Table 6-26.  RETROFIT ANNUAL OPERATING  COST ESTIMATE—PLANT B—
                      NORTH AND:SOUTH PLANTS
 Gross annual operating cost^
    Operating labor and materials                       $56,000
    Utilities
        Fuel                                                -0-
        Electricity                                      40,000
        Water                                             5,000
    Maintenance labor and materials                      70,000
        Total gross annual  operating cost              $171,000
 Value of recovered materials                                -0-
 Net annual operating cost                              $171,000
depreciation and interest is based on a 10-year equipment life and 8
percent interest.   Capital related charges for this retrofit thus amount
to 18.903 percent of $19,300,600—or $3,648,000.   Adding these
charges to Table 6-26 would result in gross and net annual  costs  of
$3,819,000.
                             6-99

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6.3.3  Plant C--Prebake Cells—Primary Injected Alumina Dry
       Scrubbing Retrofits?
    This plant has three side-worked prebake potlines.  As built,
the potlines had only secondary control consisting of wet scrubbers,
but all three potlines were recently retrofitted with primary control
systems.  Hoods were installed on the cells, and the primary cell gas
exhausts were directed to injected alumina dry scrubbers.
    In the following sections, potline operation, secondary controls
with associated water treatment, and the primary retrofit are described;
Next the emissions before and after total retrofit are presented; and
capital and annual costs for the total retrofit are estimated,
6.3.3.1  Engineering Description
6.3.3.1.1  Potline operation--The plant was built in 1965 using
European technology.  Its three computer-controlled potlines have a
total capacity of 265,000 ton/year.  Each potline has 240 cells in
4 rows of 60 cells per row, installed in 2 buildings, for a plant total
of 720 cells.   Each building consists of 2 single-row potrooms with
side-wall ventilation on the outside walls and a corridor between the
center walls, so that there are 4 potrooms per potline or 12 potrooms
for the whole plant.  The cells are set into the potroom floor, bat
the potrooms have no basements.
    Each cell has "18 anode assemblies, 9 to a side.  Each assembly
consists of three small rectangular carbon anode blocks, two copper
branch rods to a block - six rods to an assembly.  The six branch rods
are connected to a center rod that introduces electrical current.  The
                             6-100

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cells are designed for 4 volts and 130,000 amperes, and are amonq
the lowest-voltage cells in the industry.

6.3.3.1.2  Secondary control system—The as-built secondary controls
consisted of 30 fiberglass Ceil cote scrubbers per building, on a floor
on top of the corridor between the potrooms but under the building
roof.  Each scrubber thus handled four cells.  To reduce water effluent
discharges, only 17 scrubbers per building are now operating — about
every other one -- and each thus handles emissions from about  7 cells.
    Each scrubber consists of a horizontal spray section with 80 co-
current spray nozzles, a 40-hp fan on the inlet, and a slat mist
eliminator on the outlet.  Each scrubber handles 104,000 scfm at 20 to
22°C and discharges through a 12- by 18-foot rectanoular stack 18 inches
above the peak of the potroom.  This peak is 52 feet above the ground.
A 40-hp pump recirculates the scrubbing water at 1200 gal/min from a
hold tank beneath the scrubber.  A small amount of water is bled off
this scrubbing loop to a water treatment plant.
    The secondary control system as installed cost $10 million.

6.3.3.1.3  Water treatment—In the water treatment plant, water from  the
scrubbers is treated with sodium aluminate to form cryolite.  The
cryolite is filtered on a vacuum drum filter and then dried in a kiln
and recycled to the cells.  This cryolite is of poor quality.
    The water treatment plant was installed in 1971 for $1.45 million.
                             6-101

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6.3.3.1.4  Primary control  retrofit—Overall control efficiency with
just the secondary system was low, and plant management started
investigating improved control  in 1970.  After experimenting with
small hoods over the gas holes  in the crust, they constructed a
Quonset hut over a cell  to find out what was being emitted.  They
determined that fine particulates were the most difficult to control,
installed a 20-cell  ESP, and ran it for 6 months.  The level of control
obtained by ESP was not satisfactory.  They also considered the venturi
and determined that it lacked the proper level of control.  At about
that time, the plant designers  had been investigating bag collectors,
and the plant decided to abandon wet scrubbing for the injected alumina
dry scrubbing system.  The retrofit that was completed in the Spring of
1973 consisted of installing primary collection systems and injected
alumina primary removal  equipment on all three potlines.

6.3.3.1.5  Primary collection retrofit—Side-worked prebake cells must
be worked manually along the entire side of a cell.  Hence, the gas
collection skirt at plant C consists of two nonsegmented doors, one
on each side of the cell.  Some of the cells have doors operated by air
cylinder, others by air motor.
    The doors have to be open about 10 percent of the time to change
anodes and to add alumina by manually working the cells.  The 20
cells whose primary exhausts were directed to the ESP prototype
have doors that must also be opened to tap aluminum.  The remaining
700 cells have small  tapping doors in the cell doors, so the cell
doors remain closed during  tapping.
                             6-102

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    A door closes with its bottom edge on the potroom floor.  This
 edge has an asbestos cloth seal.  The closinq doors hit the floor
 forcefully, generating considerable dust.  The doors are made of steel
 because gas jets from the cells can cause holes in aluminum doors.
    In the middle of the cell superstructure, two circular ducts
 pick up the primary exhaust and direct it upwards to a horizontal
 12-inch circular branch duct that runs along the centerline of the
 cell.  The primary exhaust rate is about 3000 acfm per cell at 200°F-
    Duct headers run along the corridors between the potrooms, each
 header picking up branch ducts from 30 cells per potroom in line 1
 and 15 cells per potroom in lines 2 and 3.  The headers are rectangular
 and increase in size as they pick up more branch ducts.  An average
 size is about 2 feet by 4 feet.  Two headers join at the top of the
 corridor, one from each potroom, and the common duct passes through
 the roof to the control equipment in the courtyard.  A secondary
 scrubber has been removed to accomodate each common duct.  Line 1 has
 two common ducts, and two scrubbers were removed per buildinq.  Lines 2
 and 3 have four common ducts, and four scrubbers were removed per buildinq.
 Nothing else had to be torn down or moved to accomodate the retrofit
 equipment.
 6.3.3.1.6  Primary removal retrofit—Each potline has two injected
alumina units located in the courtyards between its two buildings,
each unit servicing half of each building.  Figure 6-18 is a oer.eral
flow diagram for the injected alumina process at plant C.  The process
                             6-103

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2   j
                                        FUMES
                                 n-77] CONTAINING
                                 [••'I FLUORIDES
                                                      DAY BIN FOR
                                                  FLUORINATED ALUMINA
                                                        STORAGE
                          CLEAN
                           AIR
CLEAN
 AIR
FLUORINATED ALUMINA
         D TO POTS
                                     FLUORINATED ALUMINA
                                                           )    DUCTING
                                                           /   TO COLLECT
                                                           /      FUMES

                                                       .HOODS COVERING
                                                        INDIVIDUAL POTS
                            FILTER BAG
                              HOUSES

                        FRESH ALUMINA INJECTED
                      TO ADSORB FLUORIDES IN FUMES
                                   Figure 6-18.  Flow diagram — plant C — injected alumina proces's.

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 involves reaction of gaseous fluoride with the alumina to be fed to
 the'cells followed by baghouse solids collection.  Alumina is injected
 into the flowing gas stream and the reaction occurs in a matter of
 seconds.  As designed, 100 percent of the alumina fed to the cells
 should pass through the units.  97 percent passage is actually achieved.
    Plant C's retrofit is somewhat unusual in that the fans are located
 downstream of the baghouses.  This location helps keep the fan blades
 from scaling.  Scale deposits will cause the fans to lose their dynamic
 balance.  However, a downstream fan location requires that the baq-
 houses operate under negative pressure, and a negative operating pressure
 requires a stiffer baghouse structure.
    Potline 1 has injected alumina control units designed by Prat-
 Daniel -Poel man (POP) and potlines 2 and 3 have control units designed
 by Alcan.  The order of retrofit was 2-3-1.  Both designs are unique
 in this country and will now be described in detail.
 6.3.3.1.7  PDP design—Figure 6-19 is a schematic of the retrofit and
 Table 6-27 lists the major retrofit items for one of the two control
 units on potline 1.  Each unit has a total of 12 Venturis, 12 baghouses,
 6 fans, and 6 stacks.
 6.3.3.1.8  Alcan design—Figure 6-20 is a schematic of the retrofit
 and Table 6-28 lists the major retrofit items for one of the four
 control  units on potlines 2 and 3.  There are no Venturis in the
Alcan design.  Each unit has a total of 22 baghouses, 22 fans and
22 stacks.
                                6-105

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     EXHAUST
      FROM
     POTROOMS
                                                             FRESH
                                                           ALUMINA-
                                                             FEED
          REACTED
         ALUMINA
 TO EXISTING
 DAY BINS ON
BOTH BUILDINGS
                                                                                   EXHAUST
                                                                                     FROM
                                                                                  POTROOMS
8ft.
                                                                        FAN
             CONTINUOUS
              LOW PRES-
             SURE CON-
               VEYING
               SYSTEM
        Figure 6-19.  Retrofit schematic -- plant C -- POP design (Venturis, ducts,
        fan, stack, and solids handling are depicted for one pair of baghouses on.ly).
                                            6-106

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Table 6-27.   MAJOR RETROFIT ITEMS—PLANT C--PDP DESIGN


1.  Two  8-foot ducts,  one from each building (see Figure  6-19),
    join opposite ends and sides of an 8-foot horizontal  duct.
    This horizontal  duct runs underneath the control  unit and feeds
    six  paired venturi-baghouse subsections.

2.  Six  pairs of vertical Venturis.  Gas flows upward through the
    Venturis  each of which has two injection ports -  one  for fresh
    alumina and one for reacted alumina that is recycled  from the
    baghouse.  The ratio of recycled to fresh alumina is  fixed at
    20:1.

3.  Six  pairs of baghouses.  Each baghouse handles 30,000 acfm of
    200°F primary exhaust.  Gas flow'entering and leaving a baghouse
    is horizontal.  Gas leaving one of the two baghouses  in each pair
    passes horizontally through the opposite baghouse but not through
    the  bags—there is no process connection—and the two baghouse
    exhausts  join downstream of the opposite baghouse. Each baghouse
    is a rectangular box 18 feet square and 20 feet high  with an
    inverted  pyramid bottom gas inlet.  The top of each baghouse is 40
    feet above the ground.  The bags are cleaned by shaking with reversed
    air  flow.  At the  end of every 30 seconds, one baghouse is shaken
    for  4 seconds.  Thus the total cycle time for all 12  baghouses is
    6 minutes.

4.  Six  250-hp fans located at ground level.  Each fan exhausts a pair
    of baghouses  (60,000 acfm) and discharges to a 60-foot stack.

5.  A 100-ton fresh alumina bin.

6.  A continuous low-pressure conveying system to convey  reacted and
    unrecycled alumina to the existing day bins on top of both pot-
    line 1 buildings.

7.  Local  controls mounted on the baghouse structure.

8.  A roof of simple truss design covering the Venturis,  baghouses,
    and  local controls.  The roof is about 20 feet above  the  tops
    of the baghouses and is supported by 14 I-beams,  7 to a side.
                             6-107

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                                FAN WITH
                                 STACK
en
 i
o
oo
        EXHAUST FROM
          POTROOMS
                                          NOT SHOWN ARE
                                          11 DUPLICATE
                                          BAG HOUSES AND A
                                          FEEDER DUCT, IN-
                                          STALLED AT
                                          THE RIGHT
                                           FEEDER DUCT
                    6ft.
REACTED ALUMINA TO
EXISTING DAY BINS
ON BOTH BUILDINGS
BATCH WISE
HIGH PRES-
SURE CONVEY-
ING SYSTEM
                                         Figure 6-20.  Retrofit schematic -- plant C - Alcan design (side view -- 5
                                        baghouses in a farther plane are not shown).

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   Table  6-28.   MAJOR RETROFIT ITEMS—PLANT C--ALCAN DESIGN


1.  Two 6-foot  ducts, one from each building (see Figure 6-20),
    join  an  8-foot duct that runs underneath the control  unit
    and feeds 11  baghouses.   The horizontal duct reduces in diameter
    after each  pair of take-offs.  There are three alumina  injection
    ports -two  for recycled  alumina and one for fresh—in the  8-foot
    duct  upstream of the control unit.  The ratio of recycled  to  fresh
    alumina  is  variable from one to 10.

2.  Ductwork identical  to that just described under item 1  to  feed
    a control unit that is installed to the right, and in reverse,
    of the control  unit shown in Figure 6-20.

3.  Twenty-two  baghouses in  2 groups of 11  each as shown in Figure  6-20.
    Each  baghouse except the eleventh (nearest the bin) has a  twin
    beyond the  plane of the  paper.   Each baghouse handles 16,400  acfm
    of 200°F primary exhaust.  Gas  flow entering and leaving a baghouse
    is vertical.   Each baghouse is  a rectangular box 10 feet square
    and 18 feet high with an inverted pyramid bottom gas inlet.   The
    top of each baghouse is  about 50 feet above the ground. The  bags
    are cleaned by a variable 15- to 30-second high pressure jet  air
    pulse.

4.  Twenty-two  60-hp fans, one for each baghouse (16,400 acfm).
    Each  fan sets on top of  its respective baghouse and discharges
    to a  stack.  The stacks  discharge to the atmosphere 60  feet above
    the ground.

5.  A 100-ton fresh alumina  bin.

6.  A batchwise high-pressure conveying system to alternately  convey
    reacted  and unrecycled alumina to the existing day bins on top
    of each  potline building.

7.  Local controls mounted on the baghouse structure.
                            6-109

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6.3.3.1.9  Retrofit increments of jirgqress--Table 6-29  presents  the
time increments of progress for each of the three ootline retrofits.
As Table 6-29 shows, the four major contracts were awarded at different
times for lines 2 and 3, but for line 1 they were awarded all at once.
Compliance testing for line 2 started after several weeks of shakedown
operation, approximately on September 15, 1972.  The line 1 retrofit was
operational  when EPA personnel visited plant C on May 9, 1973.
    For each of the potline retrofits, only 9 to 10 months elapsed
between the date that the first contract was awarded and the date that
both control units on that potline were operational.  However, as mentioned
in subsection 6.3.3.1.4, the plant started investigating improved control
in 1970, which was 3 years prior to all control units being operational.
6.3.3.2  Emissions Before and After Retrofit
    Table 6-30 shows average emissions before and after retrofit
furnished by the company in October 1974.  All of the quantities are
expressed as pounds of total fluoride ion per ton of aluminum produced
(Ib/ton Al).  The table shows the quantities generated  at the cells;
the quantities directed to the injected alumina primary removal equip-
ment after retrofit (primary collection); the quantities escaping
collection (secondary loading); the primary, secondary, and total
emissions; the quantities removed by the secondary equipment that are
sent to the cryolite recovery plant; and the quantities recovered by
the dry primary retrofit and recycled to the cells.
                             6-110

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                           Table 6-29.  RETROFIT INCREMENTS OF PROGRESS—PLANT C

Portion of control unit
contract awarded
Treatment system and
baghouses
Hood fabrication and
installation
Ducting fabrication and
installation
Electrical wiring
Total project
Construction started
Construction completed
Unit operational

Line 2
11/19/71
12/28/71
2/11/72
2/17/72
-
January 1972
Unit 1 Unit 2
6/27/72 8/4/72
7/5/72 8/15/72
Line 3
1/26/72
2/2/72
2/16/72
2/17/72
-
NAa
Unit 3 Unit 4
9/29/72 10/27/72
*1 0/1 5/72 *1 1/1 5/72
Line 1

-
-
-
7/7/72
8/1/72
Unit 5 Unit 6
3/1/73 4/10/73
NAa NAa
 t
C
I

IT;
           Not available.

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   Table 6-30.  EMISSIONS BEFORE AND AFTER RETROFIT—PLANT C-
                        LINES 1, 2, AND 3
                      (15 total F"/ton Al)

Emissions
Generation
Primary collection
Primary emission
Secondary loading
Secondary emission
Total emission
Secondary removal
Primary recovery
Before
retrofit

45.5
-
-
44.5
9.0
9.0
35.5
-
After
retrofit

45.5
37.8
0.4
6.7
0.9
1.3
5.8
37.4
    Monthly average inlet loadings  to the  primary and secondary con-
trol systems were 37.76 and 6.72 Ib F/ton  Al  in September 1974.  The
generation level  of 45.5 Ib/ton  Al  is the  sum of these loadings, plus
a rough approximation that building leakage is 1.0 Ib/ton Al.   These
loadings and the  secondary emission of 9.0 Ib/ton Al  before retrofit
were measured with the plant operating at  capacity.   The primary and
secondary emissions of 0.4 and 0.9  Ib/ton  Al  are based on 92 and 93
tests, respectively, during January-September 1974 when the plant
was at or near full production.   For these nine months, testing typi-
cally consisted of three tests per  week on both the primary and secondary
                               fi-119

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systems.   Each of the three tests was for emissions from a different
potline and lasted 24 hours.  Plant personnel  have not been able to
determine any difference between the performance of the POP units and
that of the Alcan units.
    The emissions before retrofit in Table 6-30 correspond to a secon-
dary removal efficiency of 80 percent and an overall control  efficiency
(including building leakage) of 78 percent on  total fluoride  for plant
C.  The emissions after retrofit correspond to a primary removal
efficiency of 99 percent, a secondary removal  efficiency of 87 percent,
a primary collection efficiency of 83 percent and an overall  control
efficiency (including leakage) of 95 percent on total fluoride for
plant C.
    Two conclusions that can be drawn from the above efficiencies and
Table 6-30 are:
    1.  Without secondary control, a primary collection efficiency
        of 83 percent would result in a secondary emission of 7.7
        Ib/ton Al and a total emission of 8.1  Ib/ton Al for total
        fluoride after retrofit.
    2.  The retrofit reduced by 84 percent the quantity of total
        fluoride that is removed by the secondary control system and
        sent to the water treatment plant.  This in turn has reduced
        the plant water effluent discharges.
                               6^113

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 6.3.3.3   Retrofit  Capital  and Annual  Costs

 6.3.3.3.1   Capital  costs—Table 6-31  presents the total retrofit
 capital  cost  for the  three potlines  broken down into the major retrofit
 items.   Assuming an annual  capacity  of 265,000 tons, $14,300,000 for
 retrofit is equivalent  to  a capital  cost of $54 per annual  capacity ton.
     The  duct  costs  in Table 6-31  include all  ductwork from the cells
 to  the 8-foot horizontal ducts  underneath the control  units.   The
 control  unit  costs  include the  remaining ductwork,  Venturis,  baghouses,
 fans, stacks, and  solids handling  for all  the Alcan and PDF units.
 Nondistributed costs are primarily, but  not exclusively,  related to
 the control units  and include such things  as  utilities  (primarily
 compressed air) and instrumentation.   Research and  development (R&D)
 costs include only  the  development work  that  eventually became part
 of  the retrofit.   Hence, the  costs are included for the hoods  on'the
 20  cells whose primary  exhausts were  directed to  the ESP  prototype,
 but not  for the ESP itself.   Plant personnel  are  unable to  determine
 the remaining R&D costs  from  their  records.   All  contractor  engineering
 and the  plant R&D engineering costs that  pertain  to the installed
 retrofit are  included in the  Table 6-31  costs.  Plant personnel  are
 unable to determine the remaining plant  engineering costs from their
 records.
    The  secondary scrubbers were the only assets that were  retired
as a result of the  retrofit.  They were installed for $1,166,000,
were being depreciated over a 20-year life, and when retired had  a
book value of  $907,000.
                             6-114

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          Table 6-31.  RETROFIT CAPITAL COST-PLANT C-
                           LINES 1, 2 AND 3
          Hoods                           $3,160,000
          Ducts                            1,190,000
          Emission control  units          7,970,000
          Nondistributed costs            1,250,000
          Research and development          730.000
                             Total      $14,300,000
6.3.3.3.2  Annual  costs—Table 6-32 gives annual costs for both the
primary injected alumina retrofit and the secondary scrubbers as
furnished by the company in March 1975.  Assuming an annual  aluminum
production equal to the annual capacity of 265,000 tons, the total
retrofit annual  cost amounts to $12.99 per ton; the total  secondary
scrubber annual  cost amounts to $7.07 per ton; and the plant's ool-
lution control  an.nual  cost amounts to $20.06 per ton.  The total retro-
fit annual  operating cost of $936,000 amounts to $3.53 per ton.
    The cost of producing compressed air for the retrofit is included
in maintenance  materials.  The plant pays no royalty costs for the
Alcan or the Prat-Daniel-Poelman designs.  The secondary scrubbers  are
leased.   Hence  the depreciation cost of $1,190,000 is rent,  and there
are no charges for interest or taxes.
                               6-115

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    In Table 6-32,  no  credit is  given  for the  alumina and  fluoride
recovered by the retrofit because  the  plant accounting system does
not credit these recovered materials.   Assuming  a  fluoride recovery
rate of 37.4 Ib/ton of aluminum  produced (see  Table  6-30), an annual
aluminum production of 265,000 tons, and a fluoride  cost of $0.25  per
pound,50 the value  of  the recovered  fluoride would be $2,477,750
per year.
      Table 6-32.  1974 ANNUAL COST—PLANT C—LINES  1, 2,  AND 3

Operating costs:
Labor incl . dir. supv.
Supplies
Electricity
Mater
Maintenance materials & labor
Bag replacement
Subtotal
Capital -related charges:
Depreciation
Interest
Insurance
Taxes
Administrative & overhead
Subtotal
Total
Injected
Alumina
Retrofit

413,000
20,000
130,000
-
152,000
221 ,000
936,000

973,000
1,317,000
9,000
176,000
32,000
2,507,000
3,443,000
Secondary
Scrubbers

141,000
38,000
104,000
21 ,000a
355,000
_
659,000

l,190,000a
-
7,000a
-
17,000
1,214,000
1,873,000
Both

554,000
58,000
234,000
21 ,000
507,000
221 ,000
1,595,000

2,163,000
1,317,000
16,000
176,000
49,000
3,721,000
5,316,000
a
 Estimated.
                                6-116

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 6^.3.4  Case Description Summary
     Table 6-33 shows actual retrofit emission reductions and cost
 for potroom retrofits at ten primary aluminum plants.3"6'43  EPA
 personnel had visited seven of these plants (A-G) at the time the
 detailed case descriptions were developed.  Since any one of these
 seven could have served as a retrofit case description, a comparison
 table and a rating sheet were prepared to select the best cases.
 The three cases that have been selected (plants A, B and C)--
 together with the discussion of primary collection, primary removal
 and secondary removal systems—are believed to adequately cover
 primary aluminum fluoride retrofit control techniques.
     The emission numbers in Table 6-33 are average total primary
 and secondary total fluoride emissions expressed as pounds of fluoride
 ion per ton of aluminum produced.  The increase in plant K emissions
 after retrofit is explained in subsection 6.3.4.2.  The capital  costs
 include direct and indirect costs.  The indirect costs include
 engineering and, where a retrofit is underway, contingency and
 escalation costs.  However, as noted in Section 6.3.3, not all the
 engineering costs are included in the plant C retrofit.  Except for
 plants G and M, the retrofit costs are final or, where the retrofit
 is still  underway, are the customary accurate appropriation request
estimates.   Plant G costs are based on written vendor quotations and
 should thus be reasonably accurate.  Since the accuracy of plant M
 costs is questionable, this plant is separated from the others in
Table 6-33.  The capital costs are also shown adjusted to April 1974
using plant cost indices from Chemical Engineering magazine.
                              6-117

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Table 6-33.  POTROOM RETROFIT EMISSION REDUCTIONS AND COSTS FOR TEN PRIMARY ALUMINUM PLANTS
Cell
type
CWPB
CWPB
CWPB
CWPB
SWPB
SWPB
HSS
HSS
VSS
VSS
Plant
code
D
Fd
G
H
C
K
B
A
E
M
Plant capacity
short tons/yr
115,000
32,850
250,000
130,000
265,000
35,000
210,000
80,000
91 ,000
180,000
Total ootroom emissions,
Ib F/ton Al
Before .
retrofit
7.8
5.1
19.0
6.9
9.0
7.7
5.4
9.3
4.2
5.3
After .
retrofit
2.6
1.2
2.7
2.5
1.3
10.6
2.9
2.4
2.0
1.9
Retrofit capital cost,
$/annual ton Al
Actual
102
54
124
216
54
121
92
141
64
115
Adjusted to
Anril 1974
117
71
108
188
62
105
98
157
81
121
Increased net
annual operating
cost, $/ton Al
NAC
NA
NA
NA
3.53e
NA
0.81
-4.78f
MA
9.57

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Table 6-33 (continued).  POTROOM RETROFIT EMISSION REDUCTIONS AND COSTS FOR TEN PRIMARY ALUMINUM PLANTS


FOOTNOTES:

aCWPB - center-worked prebake cells, SWPB - side-worked prebake cells, VSS -  vertical  stud
 Soderberg cells, HSS - horizontal stud Soderberg cells.

 Average primary and secondary total fluoride emissions.

CNA = Not available.

 Results shown for only the one potline retrofitted.

Increased gross annual operating cost; net not available.  Net annual operating cost includes
 credits for recovered alumina and fluoride; gross does not.
f
"Negative sign means decreased net annual operating cost.

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Plants A and B furnished the additional net annual operating cost and
plant C furnished the additional gross annual operating cost for their
retrofits as shown in Table 6-33.  Additional net annual operating cost
is also shown for plant M.  These annual operating costs do not include
capital-related charges.
     Table  6-33 shows as much as a three-fold variation in cost for
actual retrofits.  Real-life differences between  plants that can
affect the  cost include:  the need to  tear down varying types of
existing control; the possible need to tear down  other equipment and
buildings;  the extent to which support structure  for the retrofit
already exists; and, the need for installing or modifying primary
collection  systems.  The latter includes the extent of modification
that is dictated by potroom layout and by cell geometry and operating
requirements.
     To further illustrate the complexity of real-life situations,
the vendor  of the fluidized bed claims that the installation cost of
fluidized bed removal equipment can vary greatly, from as low as about
$30 per annual ton on some new prebake installations to levels such
as shown for Plant D 1n Table 6-33 ($117 per annual ton).  This four-
                                                                      58
fold variation 1n cost 1s largely determined by the following factors:
      1.  The volume of cell  gas to be treated per ton of metal
          produced.   Smaller and older design prebake cells, such as
          those of Plant D, genertte as much as twice the gas volume
          of some newer cell  designs on a cubic foot per ton basis.
                               6-120

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     2.  The  physical  layout  of the existing plant,  which  affects:
        a.   The  length  of the duct svstem.
        b.   The  availability of alumina storage tanks  for storage
             both preceding and following the fume treatment system.
        c.   The  available space for locating the fume  treatment svstem
        d.   The  access  to the area by large construction  equipment
             used to erect the reactors, baghouses,  etc.
         e.   The  availability of sufficient electrical  power close  to
             the  site chosen for the control equipment.
     This  section Illustrates the point that for a process as complex
 as a primary aluminum plant, a retrofit control must be tailor-made
 and should not be generalized as to costs or even as to method of
 emission control.
     In the following  subsections,  capsule descriptions of each  of
 the  ten actual retrofits  are  given  by  cell  type.

 6.3.4.1  Center-worked  Prebake  Cells
    Plant D completed a central  primary  fluidized bed  dry scrubbing
 retrofit in July 1974.  A total  of  25  reactor-baghouses units were
 installed, along with supporting equipment,  to  replace 30 courtyard
 rotoclone-to-spray tower  fume control  units  on  the  five plant
 potlines.   Total  system capacity is 1,250,000 acfm.  The  retrofit
 did not improve primary collection  efficiency,  although the  capital
 cost included replacing the side shields on  all  650 cells  with  new
 identically-designed covers.  There was no secondary control before
 or after retrofit.  Total  retrofit  capital cost was $11,766,900
which included the cost of removing and relocating  the former control
equipment.
                              6-121

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    Plant F completed a courtyard primary fluidized bed dry scrubbing
retrofit on one of its five potlines in May 1970.  A total of 10
reactor-baghouse units were installed, along with supporting equip-
ment, to replace three courtyard dry ESP-to-dual spray tower fume
control units.  Total system capacity is 400,000 acfm, and the
retrofit did not improve primary collection efficiency.  There
was no secondary control before or after retrofit.  Total retrofit
capital cost was $1,772,000.  This did not include the cost of
removing the six spray towers.  The three ESPs were left in
place because it was considered too costly to remove them.
    Plant G has  12  courtyard dual  multiclone-to-quadruple  spray
tower primary control  units  and  plans  to  install  a  primary courtyard
fluidized bed or injected alumina  dry  scrubbing  retrofit on  all  six
potlines  by July 1978.   As  of January  1975,  the  retrofit  capital
cost estimate for the dry scrubbers  was $28  million,  the median  of
three vendor preliminary estimates.  The  retrofit also  includes  im-
proved primary collection efficiency by modifications  to  the plant's
1032 cells.  These  modifications included tighter sealing  between the
hood side shields and around the anode stems,  replacement  of the curved
side shields with braced, flat side  shields, and installation of new
end doors.   Cost of these hooding  modifications  is  estimated at  $3 mil-
lion for a total retrofit cost of  $31  million.   Table  6-33 shows the
combined emission reductions and costs for the hooding-dry scrubbing
retrofits.   Plant G has  no secondary control  before or after retrofit.
                             6-122

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  •   Plant H plans  to  install  a central  primary control  injected alumina
dry scrubbing retrofit on  all  five potlines by November 1976.   Present
controls  on four of the five potlines are courtyard primary multi-
clone-to-spray  tower units and 50 secondary cyclone scrubbers per
potline along one edge of the potroom roof.  Present controls on the
other potline are primary central Venturis with no secondary controls.
The retrofit  includes new hoods on all 700 cells which will improve
primary collection efficiency to such a degree th*at the company plans
to abandon  all  secondary controls.  As of February 1975, the total
retrofit capital cost was estimated at $28,046,000, equivalent to
$216 per annual  ton in Table 6-33.  This figure does not include any
costs for dismantling existing equipment.  In addition, plant H plans to
install two parallel sets of spray cyclone scrubber-to-wet  ESP
controls on its uncontrolled anode bake plant  at  a cost of
$2,150,000.

6.3.4.2  Side-worked Prebake Cells
    The Plant C retrofit is described in detail in Section  6.3.3.
In April  1973,  plant C completed  a courtyard primary injected
alumina dry scrubbing retrofit on all three potlines.  There are
six control modules with a total  system capacity  of 2,160,000 acfm.
Former control  consisted only of  180 roof-mounted secondary spray
scrubbers.  By  necessity, the retrofit included the hooding of  all
720 cells.  The total retrofit capital cost of $14,300,000  included
the removal of  20 secondary scrubbers.
                               6-123

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    Plant K plans to retrofit its one potline with a  central
primary injected alumina dry scrubbing system and to  abandon  the
present spray screen secondary controls along the entire peak of
the potroom roof.  The retrofit also includes hooding all 90  cells and
oversizing the removal equipment to handle primary exhaust
from an additional 48 cells that are part of a possible plant expan-
sion.  The total retrofit capital cost was estimated  to be $4,250,000
in March 1975.  The plant plans to abandon secondary  control  because
they consider a projected capital cost of $56 per annual ton  for water
treatment of their once-through scrubbing water to be economically ex-
cessive.  The before retrofit emission of 7.7 Ib F/ton Al is  an average
for the first five months of operation in 1974.  The  after-retrofit
emission of 10.6 Ib F/ton Al is based on an average generation level
of 53  Ib  F/ton  Al for the same five months and a projected
plant  overall control efficiency of 79.86 percent.  The actual emis-
 sion level  will not be  known  until  the  retrofit  has  been  completed  in
 the  summer of 1975  and  then operated  for  several  months.   Plant  personnel
are  hopeful  that emissions  will  average 6-7  Ib F/ton  Al.
6.3.4.3  Horizontal  Stud Soderberg  Cells
     The Plant B retrofit is described in  detail  in  Section  6.3.2.
 Former controls were courtyard primary spray towers.   The plant  is
 installing fifteen  100,000 scfm and six 50,000 scfm courtyard pri-
mary spray tower-to-wet ESP units  on  the  six potrooms comprising
 two-thirds of its capacity, and ten 100,000  scfm central  primary
 wet  ESP-only units  on the  three potrooms  comprising the other one-
third.  The former  does not include improved primary collection  while
the  latter does.  Improved  collection on  the latter includes  an  in-
creased exhaust rate, new  doors, and  better  sealing  on 372 cells.
                              6-124

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Estimated retrofit completion date is June 1975.   There was no secon-
dary control before or after retrofit.  An October 1974 total  retrofit
capital cost estimate of $19,300,000 does not include costs of removing
any of the 22 existing spray towers for the central  retrofit.
    The Plant A retrofit is described in detail  in Section 6.3.1.
The plant has installed a central primary dry scrubbing retrofit in
two locations, each having 18 reactor-baghouse units and handling
two potrooms, or half the plant's capacity.  For half the capacity,
the retrofit involves bypassing the 16 spray towers at the ends of the
potrooms and improving primary collection efficiency on all 240 cells
by an increased primary exhaust rate.  For the other half, the
retrofit involves  using the  central ductwork of the existing  cement
blockhouse  scrubbers  and not improving primary collection  efficiency.
Total  system capacity for the whole plant  is 1,200,000 acfm.  The
retrofit was operational in  September  1974.  There was no  secondary
control before or  after retrofit.  A  December 1974 total retrofit
capital cost estimate of $11,313,000  includes demolition costs for
half  the retrofit.  The  bypassed  spray towers ana a  25-  by
100-foot building  were torn  down,  but  the  cement blockhouse scrubbers
were  not.

6.3.4.4  Vertical  Stud Soderberg  Cells
    Plant E completed a  secondary  retrofit in November  1970 and a
primary retrofit  in  February 1972  on  all  five of its potrooms.  The
secondary retrofit consisted of  abandoning previously  retrofitted
roof  monitor spray screen  scrubbers  and  installing  a new dormer-
tunnel design  that is shown  in Figure 6-10, one dormer  tunnel  along
one enttre  edge of each  potroom  roof.   The primary  retrofit
                               6-125

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consisted of adding eight 12,000 acfm and four 6,000 acfm wet
ESPs downstream of 20 previously retrofitted courtyard bubbler-
scrubbers.  The ESP retrofit did not improve primary collection
efficiency.  Table 6-33 shows the combined emission reduction and
costs for the dormer-tunnel and ESP retrofits.  Retrofit capital
costs were $4,155,078 and $1,662,701 for the secondary and primary
retrofits, respectively.  The primary retrofit included removal of
the plant's 20 multiclones.
      Plant M has ten potrooms, courtyard multiclone-to-
venturi  primary controls and no secondary control.  It has been
developing a foam  scrubber secondary control system.  If this scrub-
ber proves too ineffective or costly, the plant will revert to in-
stalling spray screen secondary controls.  An EPA contract study
estimated that, in December 1973, roof mounted powered spray screen
scrubbers would cost $20,688,000 or $115 per annual ton to reduce total
fluoride emissions to 1.8 Ib F/ton Al.  There would be 60 scrubbers
and 60 fans per potroom, or 600 apiece for the plant.  Total system
capacity would be  25,800,000 acfm with a Hquid-to-gas ratio of 5
gallons  per thousand acfm.  The retrofit would also Include 20 redr-
culating pumps, 10 recirculating tanks, six miscellaneous pumps, and
one clarifier.  The scrubber water would be lime treated.  The con-
tractor  estimated  that  final installed costs for other systems, such
as a  foam scrubber, would not vary more than about 30 percent from
that  of  the spray  screen.  A December 1973 annual1zed operating cost
estimate of $1,723,000  1s equivalent to $9.57 per ton.
                              6-126

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 6.4  DESIGN,  INSTALLATION AND STARTUP TIMES FOR RETROFIT CONTROLS
     The emission control retrofit cases studied and described in
 Section 6.3 have shown that the upgrading of fluoride emission controls
 or the initiation of control for a primary aluminum plant is a major
 engineering undertaking.   Such a project does not involve the instal-
 lation of one simple item of control equipment, but instead involves
 complex controls which may be several in number.  Associated with the
 controls are  storage and  surge tanks, conveyors, fans, and long lengths
 of huge ductwork along with the necessary foundations, structural
 steelwork and electrical  drive systems.
     Table 6-34  shows the approximate sequence of activities which are
 necessary to  design  and install an improved air emission control  system
 in a primary  aluminum plant.  The sequence of work outlined is not
 necessarily normal,  but it should apply to periods such as the summer of
 1974,  when structural  steel had particularly long delivery time.
 Obviously,  such  steel  would be ordered as soon as possible—in fact,
 even before the  full  requirement is known.   Thus, some parts of item 5
 may  not be firm  until  item 7 and item 11 are done.   Similarly, it will
 be understood that other  items of Table 6-34 may overlap in time.
     Figure 6-21  illustrates that the activities in a big engineering
job—such  as  retrofitting controls to a primary aluminum plant—tend to
progress  in a continuous, non-stepwise manner.   This is because there is
so much to  do;   at a  given time, numerous items are in various stages of
design,  procurement,  and  construction.  The four curves in Figure 6-21
show the typical  progress for the named activites throughout
                                 6-127

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 Table  6-'34-  SEQUENCE OF  MAJOR  ACTIVITIES IN DESIGN AND CONSTRUCTION
         OF AIR  EMISSION CONTROL FOR AN EXISTING PRIMARY ALUMINUM PLANT
 1.    Process  design  and  flow diagram.
 2.    Engineering  flow  diagram and  preliminary plot plans.
 3.    Specification and procurement of  major items such as  dry scrubbers,
      and fans.  Long delivery items first.
 4.    Ductwork and piping arrangements, specification, and  procurement.
 5.    Structural steel  design.
 6.    Foundation design.
 7.    Specification of  minor items, obtainable without complete drawings,
      such as  pumps and materials  handling equipment.
 8.    Design of electrical  starters, switchgear and distribution system.
 9.    Specification of  instruments.
10.    Receipt of certified dimension drawings of dry scrubbers, storage
      tanks, conveyors, fans.
11.    Dimension drawings  for ductwork.
12.    Release of foundation and structural steel drawings.
13.    Start construction.  Site preparation, necessary removals or
      relocations  will  have already taken place.
14.    Complete the pipe and ductwork takeoffs, and drawings for field
      supports.
15.    Release drawings  and material listings for construction.
16.    Complete underground installations.
17.    Complete foundations.
18..   Delivery of  structural steel  and  major items of equipment.
19.    Erect major  items of equipment.
20.    Install  ductwork  and conveyors.
21.    Install  piping.
                               6-128

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 Table  6-34(continued).  SEQUENCE OF  MAJOR ACTIVITIES IN DESIGN AND
 CONSTRUCTION OF AIR EMISSION CONTROL  FOR AN EXISTING PRIMARY ALUMINUM
 PLANT
 22.  Install electrical.
 23.  Install instrumentation.
 24.  Startup.
 25.  Source testing and analytical.
 26.  Compliance with air pollution  control  regulations.
 the job.   The relative positions of the  curves  vary with the actual  job
 and the graph is diagrammatic only.  However, each  line tends to approach
 linearity in the 25-75 percent completion  interval.   This figure shows
 that process design usually continues  into the  early stages  of procurement
 Engineering also continues well into the construction period.  For this
 reason, total time requirements are best estimated  from experience and
 cannot be derived by adding the time requirements for design, ordering,
 manufacture, delivery, installation and  startup as  can be done for one
 simple control.
     One  important step that is almost wholly out of control  of the
 customer  or the  control official is the  construction item delivery
 time.   Table 6-35 gives some historical delivery times for items which
 are very  important in installing emission  controls  at primary aluminum
 plants.   The historical variation is somewhat obscured because data
 extending back to the Korean war period  (when deliveries were very
 long)  is  not available.  However, deliveries greatly increased
from 1973 to 1974,  and many lead times passed all previous
                                 6-129

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                       TOO
CO
o
                          START
                                                                               (a)  PROCESS  DESIGN
                                                                               (b)  PROCUREMENT
                                                                               (c   ENGINEERING
                                                                               (j)  CONSTRUCTION
FINISH
                                                  TIME
                          Figure 6-21-  Diagrammatic representation of activity schedules on a major
                          process  industry construction project.

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                           Table 6-35.  DELIVERY TIMES FOR ITEMS REQUIRED TO CONSTRUCT EMISSION
                                             CONTROLS FOR PRIMARY ALUMINUM PLANTS'59,60
CO
Construction Items
Structural steel
Ductwork
Fans & blowers
Airslides
Motors
Electrical controls
Electrical switch gear

1960
17-21
10-14
26




Delivery Times (weeks)
1966
23-30
10-14
30




1969
21-28
17-22

17-19
12
13
23
1971
23-31
18-23
25
17-19
12
13
21
1973
27-35
18-23
26
20-22
14
15
21
May 1974
34-50
32-37
26
28-30
36
25
35
Remarks
>500 tons

Large

No specials
AC standard
<_ 600 volt

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bounds.   Table  6-3E represents the experience of an  aluminum  company
doing its own purchasing.  Another company reports up  to  52 weeks  for
delivery of switchgear. 61  A contractor reports 61 weeks  for  blowers;
                                          62
and about 65 weeks for motors over 40 HP.    Deliveries may depend
partly upon quantity bought, continuity of business  through the years,
and most-favored customer status.  Fabrication and shipping consumes a
significant fraction of the total time required to design  and install
emission controls.
     The actual time in years that was required to add retrofit controls
to eight aluminum plants is given in Table 6-36.  Plant codes  are the
same as in Section 6.3.  Except for plant F, the whole plant  was retrofitted
in each case.  Only plants C, E, and H had secondary control  and only
plant E improved its secondary control, at a cost of about 65 percent of
its total retrofit expenditure.  Plant B built and operated a pilot
plant during two of the 4-1/2 years of retrofit activity.  The completion
time of 5-1/2 years for plant G includes 3 years for improved cell
hooding and 3 years for dry scrubber installation.   The 3  years for
improved hooding is due to a claimed economic advantage for modifying
cells over the normal 3-year life of their cathode linings.   Had plant 6
so elected, the dry scrubber installation could have proceeded simultaneously
with cell hooding improvements, reducing the completion time  to about 3
years.
     The actual time requirements shown in the last  column of Table 6-36
are probably greater - on the average - than needed  for enforcement
purposes.  In spite of the large capital tied up, there is no return,
and the usual economic incentive for haste in startup  is  lacking.  Any
interferences with production during installation of controls are
                                 6-132

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                  Table 6-36.   TOTAL CONSTRUCTION TIME FOR RETROFIT EMISSION CONTROLS FOR
                                              PRIMARY ALUMINUM PLANTS
CO
GO
Plant
Code
A
B
C
D
Cell
Type
HSS
HSS
SWPB
CWPB
IE ; vss
Plant Capa-
city
(tons/yr)
80,000
210,000
265,000
115,000
1 91,000
Retrofit Capital
Cost ($)
11,300,000
19,300,000
H, 300, 000
1 1 ,800^000
5,800,000
; F • Ck'PB : 32,850 I 1,800,000
i ; '
! G
H
CWPB
CWPB
250,000
130,000
: 31,000.000
28,000,000
Description of
Retrofit Emission Controls
Dry scrubbers-primary
Improved cell hooding and wet
ESP-primary
New cell hooding and dry
scrubbers-primary
Dry scrubbers-primary
Wet ESP-primary
Dormer tunnel -secondary
Time Required
for Retrofitting
(years)
2-1/2
4-1/2
3
3
2-1/2
Dry scrubbers-primary 1-1/2
i (1 potline)
i
Improved cell hooding and dry
scrubbers -primary
Improved cell hooding and dry
dry scrubbers-primary
5-1/2
2

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normally few and brief and, of course, the plant will make haste when
these occur.
     In view of the above discussion, a reasonable total time for
retrofitting fluoride emission controls to a primary aluminum plant may
be taken as about 2-1/2 years.  Table 6-37 shows the approximate lead
times required to reach a few important milestones in providing emission
controls for an existing primary aluminum plant.  The first  item in the
table can require a year or two if piloting must be done or  if con-
siderable cost study has not already been done.  Also, for reasons shown
by Figure 6-21, the time for item 2 must be given as a range.
     In practice, enforcement officials should consider each plant on a
case-by-case basis and they should require proof for the time requirements
claimed for each milestone.
  Table  6-37.   INCREMENTS OF PROGRESS FOR INSTALLATION OF FLUORIDE
                EMISSION CONTROLS IN AN EXISTING PRIMARY ALUMINUM
                                    PLANT
 Increments of Progress                          Elapsed Time, weeks
 Preliminary control plan and compliance                 25
 schedule to appropriate agency
 Award of major contracts                              35 -  55
 Start of construction                                   60
 Completion of construction                             124
 Final compliance                                       130
                                 6-134

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6.5  REFERENCES FOR SECTION 6

1.   Air Pollution Control in the Primary Aluminum Industry.   Sing-
     master and Breyer, New York, NY.   Prepared for Office of Air
     Programs, Environmental Protection Agency, Research Triangle
     Park, NC under Contract Number CPA 70-21.   July 23, 1973.

2.   Background Information for Standards of Performance:   Primary
     Aluminum Industry.  Volume 1:  Proposed Standards.   Emission
     Standards and Engineering Division, OAQPS, Environmental
     Protection Agency, Research Triangle Park, NC.  October  1974.

3.   Varner, B. A., Trip Report:  Six Pacific Northwest  Primary
     Aluminum Plants.  Emission Standards and Engineering Division,
     OAQPS, Environmental Protection Agency, Research Triangle
     Park, NC.  June 11, 1973.

4.   Varner, B. A., Trip Report:  Ormet Hannibal, Ohio Primary
     Aluminum Plant.  Emission Standards and Engineering Division,
     OAQPS, Environmental Protection Agency, Research Triangle
     Park, NC.  July 2, 1973.

5.   Varner, B. A. and G. B. Crane, Report on 1975 Primary Aluminum
     Pacific Northwest Trip.  Emission Standards and Engineering
     Division, OAQPS, Environmental Protection Agency, Research
     Triangle Park, NC.  March 17, 1975.

6.   Crane, G. B.  and B. A. Varner, Trip Report to the Primary Aluminum
     Plant of Conalco at Lake Charles, LA.  Emission Standards and
     Engineering Division, OAQPS, Environmental Protection Agency,
     Research Triangle Park, NC.  March 28, 1975.

7.   Personal communication from D. Rush, Singmaster and Breyer, New
     York, NY, to B. A. Varner, Emission Standards and Engineering
     Division, OAQPS, Environmental Protection Agency, Research
     Triangle Park, NC.  February 25, 1974.

8.   Letter from C. A. MacPhee, Reynolds Metals Company, Richmond,
     VA, to D. R.  Goodwin, Emission Standards and  Engineering
     Division, OAQPS, Environmental Protection Agency, Research
     Triangle Park, NC, dated November 19, 1974.

9.   Letter from Dr. P. R. Atkins, Aluminum Company of America,
     Pittsburgh, PA, to B. A. Varner, Emission Standards and Engineering
     Division, OAQPS, Environmental Protection Agency, Research
     Triangle Park, NC, dated April 21, 1975.

10.  Memorandum from G. B. Crane to S. T. Cuffe.   Meeting with  Conalco
     and Revere on Proposed Primary Aluminum lll(d) Standards.
     September 26, 1974.   (Also meeting notes of  Crane and B. A. Varner.)
                              6-135

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11.   Boyer, W.  F., Jr., Arguments in Opposition to State Guidelines for
     Standards of Performance for Existing Primary Aluminum Plants (Second
     Draft of August 1974).  Consolidated Aluminum Corporation, St.
     Louis, MO.   September 23, 1974.  pp. 6-8.

12.   Letter from C. L. Keigley, Consolidated Aluminum Corporation, Lake
     Charles, LA, to G. B. Crane, Emission Standards and Engineering
     Division, OAQPS, Environmental Protection Agency, Research Triangle
     Park, NC, dated April 1, 1975.

13.   Letter from J. L. Loyer, Howmet Corporation, Greenwich, CT,
     to D. R. Goodwin, Emission Standards and Engineering Division,
     OAQPS, Environmental Protection Agency, Research Triangle Park,
     NC, dated October 31, 1974.  pp. 1-2.

14.   Letter from Dr. P. R. Atkins, Aluminum Company of America,
     Pittsburgh, PA, to G. B. Crane, Emission Standards and
     Engineering Division, OAQPS, Environmental Protection Agency,
     Research Triangle Park, NC, dated January 30, 1975.  p. 9.

15.   Reference 14, above, p. 3.

16.   Letter from Dr. P. R. Atkins, Aluminum Company of America,
     Pittsburgh, PA, to D. R. Goodwin, Emission Standards and
     Engineering Division, OAQPS, Environmental Protection Agency,
     Research Triangle Park, NC, dated June 20, 1974.

17.   Letter from J. L. Byrne, Martin Marietta Aluminum, The Dalles, OR,
     to D. R. Goodwin, Emission Standards and Engineering Division,
     OAQPS, Environmental Protection Agency, Research Triangle Park,
     NC, dated October 10, 1974.

18.   Letter from Dr. B. S. Hulcher, Reynolds Metals Company, Richmond,
     VA, to D. R. Goodwin, Emission Standards and Engineering Division,
     OAQPS, Environmental Protection Agency, Research Triangle Park,
     NC, dated June 28, 1974.

19.   Reference 1, above, pp. 8-10 to 8-12.

20.   Reference 1, above, p. 8-8.

21.   Reference 1, above, pp. 8-27 to 8-29.

22.   Reference 1, above, p. 8-22.

23.   Cook, C. C. and L. L. Knapp.  Treatment of Gases Evolved in the
     Production of Aluminum.  U.S. Patent No. 3,503,184.  March 31, 1970.

24.   Cook, C. C. and G. R. Swany.  Evolution of Fluoride Recovery
     Processes Alcoa Smelters.  In:  Light Metals 1971.  New York, NY.
     Proceedings of Symposia 100th AIME Meeting, March 1-4, 1971.
                              6-136

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25.   Cook, C. C., G. R. Swany, and J. N. Colpitts.  Operating
      Experience with the Alcoa 398 Process for Fluoride Recovery-
      Journal of the A1r Pollution Control Association. 21_, August 1971.


26.   Cochran, C.N., W. C. Sleppy, and W. B. Frank.  Chemistry cf
      Evolution and Recovery of Fumes in Aluminum Smeltinq.  TMS of
      AIME Paper No. A70-22.  February 16, 1970.

27.   Reference 1, above, p. 5-27.

28.   Varner, B. A., Trip Report:  Trip to Alcoa (Badin, N.C.) Alumi-
      num Plant, Standards Development and Implementation Division,
      SSPCP, Environmental Protection Agency, Research Trianole Park,
      N.C.  August 21, 1972.

29.   Reference 1, above, pp. 5-14 to 5-17.

30.   Reference 1, above, p. 5-29..

31.   Reference 1, above, p. 5-34.

32.   Control Techniques for Particulate Air Pollutants.  National
      Air Pollution Control Administration, Washington, D. C.  Pub-
      lication Number AP-51.  January 1969.  p. 54~.

33.   Reference 1, above, p. 5-40.

34.   Reference 1, above, pp. 5-34 to 5-40.

35.   Reference 1, above, pp. 5-29 to 5-33.

36.  Reference 32, above, pp.  81-96.

37.   A Manual of Electrostatic Precipitator Technology.  Southern
      Research Institute, Birmingham, Alabama.  Prepared for National
      Air Pollution Control Administration, Cincinnati, Ohio under
      Contract Number CPA 22-69-73.  August 25, 1970.

38.   Callaioli, G., et al.  Systems for Gas Cleaning in Electro-
      lytic Cells of Montecatini Edison Aluminum Plant.  TMS of
      AIME Paper No. A70-57.  February 16, 1970.

39-   Byrne, J. L.  Fume Control at Harvey Aluminum.  (Presented at
     Annual Meeting Pacific Northwest Section, Air Pollution Control
     Association.  Spokane, Wash.  November 16 - 18, 1970).

*°-  Calvez, C. et al.  Compared Technologies for the Collection of
     Gases and Fumes and the Ventilation of Aluminum Potlines.
     (Presented at the AIME Meeting, Chicago.  December 11 - 16, 1967.)
                              6-137

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41.   Moser, E.  The Treatment of Fumes from Primary Aluminum Reduction
      Plants.  (Presented at International Conference on Air Pollution
      and Water Conservation in the Copper and Aluminum Industries.
      Paper Number 12.   October 21-23, 1969).

42.   Letter from W.  F.  Boyer, Jr., Consolidated Aluminum Corporation,
      Lake Charles, La., to B. A.  Varner,  Emission Standards and Enaineerina
      Division, OAQPS,  Environmental  Protection Agency, Research Triangle
      Park, N.C., dated June 25, 1974.

43.   Ponder, T.  C. and R.  W.  Gerstle.  Particulate and Fluoride Emission
      Control, Anaconda Aluminum Company,  Columbia Falls, Montana.
      PEDCo-Environmental,  Cincinnati, Ohio.   Prepared for Division  of
      Stationary Source Enforcement,  Environmental Protection Agency
      under Contract Number 68-02-1321.   February 1974.

44.   Air Contaminant Discharge Permit Application.   Test Reports.
      Ammax Pacific Aluminum Corporation,  Warrenton,  Oregon.   June 1974.

45.   Letter from J.  J.  Miller, Amax  Aluminum  Company, San Mateo, Calif.
      to D. Trerice,  Kaiser Engineers, Oakland, Calif., dated June 19,
      1974.  In:   Air Contaminant  Discharge  Permit Application.  Test
      Reports.  Amax Pacific Aluminum Corporation, Warrenton, Oregon.
      June 1974.

46.   Memorandum from G. B. Crane  to  S.  T. Cuffe.  Retrofitting  Secondary
      Scrubbers at Existing Primary Aluminum Plants.   Scrubber Efficien-
      cies.  Emission Standards and Engineering Division, OAQPS, Environ-
      mental Protection Agency.  July 22,  1975.

 47.   Reference  1, above, p. 5-49.

 48.   Reference  1, above, p. 7-13.

 49.   Reference  3, above, pp. 33-39.   (Corrected).

 50.   Reference  1, above, p. 8-31.

 51.   Reference  3, above, pp.3-8.   (Corrected).

 52.   Miller, I., and J. E. Freund.  Probability and Statistics  for
      Engineers.  Englewood Cliffs, N. J., Prentice-Hall, 1965.   pp.
      349, 350, 413.

 53.   Development  Document  for Effluent Limitations Guidelines  and New
      Source  Performance Standards for the Primary Aluminum  Smelting
      Subcategory  of the Nonferrous Metals Manufacturing  Point  Source
      Category.  Effluent  Guidelines  Division, Office  of  Air and Water
      Programs,  Environmental  Protection  Agency,  Washington, D.C. Report
      Number  EPA-440/l-74-019-d.  March 1974.  '
                              0-138

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54.   Reference  53,  above,  p.  43.

55.   Reference  53,  above,  p.  3.

56.   Reference  53,  above,  p.  99.

57.   Reference  3, above,  pp.  22-27.

58.   Letter from Dr.  P. R.  Atkins,  Aluminum Company of America,
     Pittsburgh, Pa.,  to  B. A.  Varner,  Emission Standards and Engineering
     Division,  OAQPS,  Environmental  Protection Agency, Research  Triangle
     Park, N.C., dated July 23,  1973.

59.   Personal communication from Dr.  P.  R.  Atkins,  Aluminum Company
     of America, Pittsburgh,  Pa.,  to  B.  A.  Varner,  Emission Standards
     and  Engineering  Division,  OAQPS,  Environmental  Protection Agency,
     Research Triangle Park,  N.C.   June  25, 1974.

60.   Purchasing Lead  Time  Reports.  Aluminum Company of America,
     Pittsburgh, Pa.   August  1969,  August 1971, August 1973, May 1974.

61.   Letter from A. L.  Morgan,  PPG Industries, Inc., Pittsburgh, Pa.,
     to B. A. Varner,  Emission  Standards and Engineering Division,
     OAQPS, Environmental  Protection  Agency, Research Triangle Park,
     N.C., dated May  30,  1974.

62.   Personal communication from R.  Davis,  Chemical  Construction
     Corporation, New York, N.Y.,  to  B.  A.  Varner,  Emission Standards
     and  Engineering  Division,  OAQPS,  Environmental  Protection Agency,
     Research Triangle Park,  N.C.   May 31,  1974.
                                 6-139

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         7.   COSTS OF ALTERNATIVE FLUORIDE EMISSION CONTROLS

7.1  INTRODUCTION
     This chapter presents the status of fluoride emission control for all
domestic primary aluminum plants as of early 1975.  It also illustrates
the application of available control strategies to two selected plant
examples from each of the four cell types.  The effect on emissions of
each successive control  is shown.  Also, cost models are developed and
used to estimate the capital and annualized costs of the above control
strategies.   Other plants than those illustrated here can be investigated
for emission reductions  and costs in an analogous matter.  In general,
cost modules cannot apply closely to any actual plant:  they are
approximations, and are  especially useful in showing cost comparisons
among various degrees and kinds of control.
     Plant code numbers  will be spoken of and tabulated in various tables
in this Section.   This is done because EPA wishes to avoid identifying
plants, production rates, and other items which may be proprietary, but
are unnecessary to the mission of this document.  No meaning should be
sought in the ordering of the code numbers, nor in the numerous uppercase
letters used.
                                     7-1

-------
7.2  SELECTION OF ALTERNATIVE CONTROL LEVELS
     Table 7-1 presents the structure of the domestic primary aluminum
industry by cell type.  Slight differences in plant capacity exist
between this table and Table 3-1.  This is because Table 7-1 includes
planned capacity additions.
     Table 7-2 presents the total gaseous plus particulate fluoride
emissions that each domestic plant would be expected to have in the
absence of lll(d) regulations, organized by cell type and with existing
controls.   Existing plant emission control, average cell evolution
rates, and collection and removal efficiencies were obtained for the
combinations that describe existing plant control situations in Table
7-2.  Most of the evolution rates, primary and secondary loadings, and
emissions were taken from Section 114 letter responses received from
plants representing 100 percent of domestic VSS, HSS, and SWPB capacity,
and 86 percent of CWPB capacity. These responses were supplemented and
modified as necessary with trip reports, letters, phone memoranda and
other EPA file information.
     Table 7-3 adds alternate control systems for successive steps from
existing to better control combinations.  The following illustrates
the general procedure that has been made specific by Table 7-3 with two
plants from each of the four primary aluminum cell types,
     a.  First: install best available hooding (primary collection) for
         cell type, if needed.
                                 7-2

-------
      Table  7-1.   PRIMARY ALUMINUM PLANT CAPACITY BY CELL TYPE
                     (thousands of annual tons)


Company           VSSa     HSSa     CWPBa     SWPBa       Total

Alcoa             245      --       1390      —          1635


Reynolds           —       704       255       17          976


Kaiser            —       341       369      --           710


Martin Marietta  210       —        --       --           210


Anaconda          180       --        120      --           300


Conalco          —        —        —       175          175


Eastalco          —        --        —       174          174


Intalco          --        --        --       260          260


Revere           --        —        --       112          112


Noranda          --        —        140      —           140


Ormet            --        —        250      —           250


Nat'l Southwire  ^        ^        ]80      ==_           180


Total            635      1045     2704       738         5122


aVSS  vertical  stud Soderberg; HSS - horizontal stud Soderberg;
 CWPB - center-worked prebake; SWPB - side-worked prebake.

bSpring 1975
                                 7-3

-------
      Table 7-2.   TOTAL FLUORIDE EMISSIONS BY CELL TYPE  WITHOUT lll(d)  REGULATIONS
                                              Total  Fluoride  Emissions,  1b  F/ton A1
Cell Type              Plant No.
   VSS
   Weighted Average VSS
   SWPB
    Weighted Average SWPB
 19
 20
  5A
  9
  3B
 18
 17B
 23B
 11
 26
 24
   HSS
   Weighted Average HSS
   CWPB
   Weighted Average CWPB
 31C
 16B
 13B
 25B
 31D
 30B
 28
 26
 8B
15B
 2C
14B
 1
29B
10
 6B
22B
 7B
 7A
21B
 4B
 8A
 5B
12
 4A
21A
 2B
27
Cell Average
42
42
30.5
53.5
42.9

44.5
45.6
53
37.3
41.6
48

32.1
30
36.7
30
31.1
45
28.4
41.6

45.5
25.7
50
33.9
42
40.1
43.2
40
38
50
31.7
43
53
43.5
44.7
41.5
65.6
43
43.2
40.3

Primary
0.03
0.03
0.2
0.8
0.4
0.4
0.4
0.4
0.6
0
4.3
0
0.4
0.3
0.8
0.8
1.3
1.1
1.2
3.5
4.3
1.4
0.2
0.5
0.5
0.5
0.5
0.5
0.6
0.4
0.8
0.8
0.8
0.6
2.1
3.6
2.2
1.8
8.7
11.9
4.4
0
1.8
+ Secondary
2.0
2.0
4.0
4.5
8.6
478
0.9
1.7
10.0
10.6
30.2
48.2
TO"
1.6
1.6
2.4
3.3
4.0
4.5
4.3
30.2
~473
1.0
1.4
1.5
1.5
1.5
2.0
2.0
2.2
1.9
2.1
2.1
2.2
2.8
1.5
3.1
8.3
3.8
2.1
9.9
40.3
4.5
= Total
2.03
2.03
4.2
5.3
9.0
0
1.3
2.1
10.6
10.6
34.5
49.0
13.0
1.9
2.4
3.2
4.6
5.1
5.7
7.8
34,5
~5T7
1.2
1.9
2.0
2.0
2.0
2.5
2.6
2.6
2.7
2.9
2.9
2.8
4.9
5.1
5.3
10.1
12.5
14.0
14.3
40.3
6.3
                                     7-4

-------
                                                              Table 7-3.  PRIMARY ALUMINUM CONTROL STRATEGIES
                                                                                 VSS CELLS
en
Plant
Code
5A


3B

18

24

Emission Controls Required for the Specified
Hooding Primary (1°) Controls
Best Available Spray tower + wet ESP
" Install waste water
lime treatment
' ' No change (water treat-
ment handled by 2°)
' Fluidized bed dry scrubber
n i n n n
" ' Injected alumina dry
scrubber

None None
Install primary Install injected alumina
Average Fluoride Emission
Secondary (2°) Controls
None
"
Install spray screen and
waste water lime treatment
1° and 2°
None
Install spray screen and
waste water lime treatment
SWPB CELLS
Spray scrubber
Install lime treat-
ment of cryolite bleed
stream
None
None
Average
Fluoride
Evolution
Ib/ton Al
30.5
II
II
42.9
11
44.5
1
48
'
Average
Fl uori de
Efficiencies Emission
1° collection 1° removal 2" removal Ib/ton Al
87 99.2 0 4.2
II II II II
75 1.2
80 98.8 0 9
75 2.6
85 99 87 1.3
II II II
00 0 48.0
80 98.5 " 10.2
                   collection       dry scrubber
                   system
                                                                Install spray screen &
                                                                waste water lime treatment
75
            3.0

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                                                  Table 7-3.   PRIMARY ALUMINUM CONTROL  STRATEGIES   (Continued)
                                                                      HSS  CELLS
Plant  Emission Controls Required for the Specified Average Fluoride Emission
Code      HoodingPrimary (1°) Control?Secondary (2°)  Controls
 31C   Best Available
Spray tower + wet electro- None
static precipitator  (ESP)
Average
Fluoride
Evolution
Ib/ton Al

32.1
                                                                                                            Average
                                                                                                            Fluoride
                                                                    	Efficiencies  	  Emission
                                                                     1° collection  1° removal  2° removaT  Ib/ton AT
                         Install lime treatment
                         of cryolite bleed stream
                                                    Install  spray screen  and
                                                    waste water lime treatment
                         spray tower;  install  lime
                         treatment of cryolite bleed
                         stream
                                                    Install  spray screen  and
                                                    waste  water lime  treatment
                                               95
                             99
                                                                                                                        75
                                                                                               75
                                                                                                                                     1.9
                                                                                                            0.7
26



Poor Spray tower
Install lime treatment of
cryolite bleed stream
Improve hooding ' "
' Install wet ESP; remove
None
I
1
II
41.6 27
II II
90
1
62
1
II
96
0
II
II
1
34.5
II
18.4
5.7
                                                                                 2.5
                                                                    CWPB CELLS
8B Best Available Fluidized bed scrubber
i H ii ii H
None 45.5
Install spray screen '
and waste water lime
treatment
98 99.5 0
75
1.2
0.5
4A
Dry ESP + spray tower

Install waste water lime
treatment
None
65.6
                  94
                                                          86
                                                                                                                                    12.5
                         Install  fluidized bed  dry  "
                         scrubber;  remove dry ESP
                         & spray  tower;  lime treatment
                         unnecessary
                                                    Install  spray screen  &
                                                    waste water lime  treatment
                                                    -2°
                                                                                     98.5
                                                                                               75
                                                                                                            4.;
                                                                                                            1.9

-------
     b.   Second:  install  best available primary control  (fluoride removal)
         with water treatment, if needed; and,
     c.   Third:  install  spray screen or spray scrubber secondary control
         with water treatment.
     Plants without Initial  primary control  obviously require both steps
a and b.   It is  assumed  that all  plants will, as a minimum, maintain
their present control  combinations.  It is further assumed that all
companies will add new retrofits  that are the best that their cost
class allows.
     Average emission rates are calculated as:
                    /   \
     EM = EV
1  -
                    100
            100
                                               fn
        sr
                               /
100    100
(7.1)
where:
     EM = average emission rate, Ib F/ton Al
     EV = average evolution rate, Ib F/ton Al
   npc = primary collection efficiency, percent
   npr = primary removal  efficiency, percent
   "sr = secondary removal efficiency, percent
     A removal  efficiency of 75 percent is assumed for secondary control
retrofits to all cell  types.  This is based on performance with primary
control as reported in Section 6.2.3.
     Facilities to meet'1983 effluent guidelines are included for plants
with wet primary or secondary control.  The two water treatment systems
considered are:
     a.  Waste  water lime treatment of a bleed stream off the scrubber
         loop,  with total recycle.
                                7-7

-------
     b.   Cryolite recovery with lime treatment of the cryolite bleed
         stream.
System b. is considered only when the plant already has cryolite recovery.
If a plant has a suitable water treatment system for secondary control,
it is assumed that this system can additionally handle wet primary
control  effluent; but a suitable water treatment system for primary
effluent is assumed to be undersized for handling secondary effluent and
a new secondary effluent treatment system would be required.  If a plant
has cryolite recovery for primary effluent and adds secondary control, it
is assumed that the secondary effluent will be lime treated.  Addition of
water treatment systems should be considered for plants not undergoing
air pollution retrofits, because the plants might choose to abandon
effluent-generating control systems in the absence of lll(d) regulations.
Costs for lime treatment of the cryolite bleed stream are taken from the
                                 2
EPA effluent guidelines document.
     In Table 7-3, it is believed that each VSS plant presently has the
highest primary collection efficiency achievable for that plant.  Both
plants have best available primary control.  Plant 5A has no water treatment.
Plant 3B has no need for water treatment with present controls.
     In Table 7-3, it is assumed that no SWPB plant can achieve a primary
collection efficiency higher than 80 percent unless it is already doing
so.  Plants achieving higher efficiencies are of French design, while
Swiss-design plants are not capable of higher efficiencies for reasons
                                                  •
detailed in Section 6.1.2.  All SWPB primary retrofits would probably be
dry scrubbing systems; these already predominate SWPB plants with primary
controls.  It is assumed that plant 24 would install injected
alumina since it is operated by a small company, and injected alumina has
                                 7-8

-------
slightly lower capital and operating costs than the fluidized bed.  A
primary removal efficiency of 98.5 percent is assumed for the dry scrubbing
retrofits, based on past performance at CWPB and SWPB plants.  An efficiency
of 75 percent is assumed for secondary removal based on demonstrated
retrofit performance reported in Section 6.2.3.  Plant 18 has cryolite
recovery that will require lime treatment of the bleed to meet 1983
effluent guidelines. Plant 24 has no need for water treatment with present
controls, or lack of controls.
     It is assumed that all HSS plants except plant 26 have the highest
primary collection efficiency achievable within existing cell constraints.
Cell age and geometry affect the ability of an HSS plant to achieve high
collection efficiencies, as explained in Section 6.1.1.2.  Geometry
restricts plant 26.  Courtyard space limitations, or the necessity for
balanced ducting layouts in central intallations, necessitates removal of
the scrubbers that would otherwise precede the ESPs at plant 26.  Gaseous
fluoride control is--or would be—achieved by a scrubbing section in the
ESP inlets.  A primary removal efficiency of 96 percent is
assumed for a primary retrofit for plant 26, based on experience at
similar plants 25B, 31D, and 30B.  Plants 31C, and 26 are believed to
                      •3
have cryolite recovery  and to require lime treatment of the bleed to
meet 1983 effluent guidelines with present controls.
     In Table 7-3, it is assumed that no CWPB plant can achieve a primary
collection efficiency higher than 95 percent unless it is already doing
so.  All CWPB primary retrofits would probably be dry scrubbing
systems, following the general practice of the industry.   However, it
is assumed that primary retrofit at 4A would be fluidized bed, the
system marketed by the company operating these plants.
                             7-9

-------
A primary removal efficiency of 98.5 percent is assumed  for  all  dry
scrubbing retrofits, based on past performance at CWPB and SWPB  plants.
Replacement of fluidized bed with fluidized bed should improve
primary removal efficiency because there have been different generations
of fluidized beds, with newer beds achieving 98.5 percent removal.  For
primary retrofits, all former control equipment is considered to be
removed from service except multiple cyclones.  Plant 4A has no water
treatment.  Hence, this plant will have to install lime  treatment with
recycle to meet 1983 effluent guidelines.  All other CWPB plants except
one have no need for water treatment with present controls.
     The "best hooding + best primary control" option requires only two
plants in Table 7.3 to retrofit primary controls, while  the  "secondary
control" option additionally requires all plants but plant 18 to retrofit
secondary controls.  For this reason, intermediate levels are established;
levels which would require some plants to install secondary  control.
     All "existing + water treatment" control options afford no  improve-
ment in emission control over levels expected without lll(d)  emission
guidelines and thus are not considered in measuring economic impact.
The added water treatment is that which is adequate to meet  1983 effluent
guidelines; it is assumed that these will universally have to be met.
     The above analysis options do not consider CWPB and SWPB anode bake
plant total fluoride emissions.  Table 6-12 shows controlled bake plant
emissions to be only 0.05 Ib F/ton Al.  Capital cost for such control is
estimated at $10.49/annual ton Al, and annual cost at $5.79/ton Al.
                             7-10

-------
Since these costs are small compared to potroom retrofit control costs
and no bake plants are known to have effective fluoride control, it is
assumed that these costs will be incurred at all prebake plants.  Within
the accuracy of the emission data, a controlled bake plant emission of
0.05 Ib F/ton Al is so small that it was not considered.
7.3  CAPITAL AND ANNUAL COSTS FOR FLUORIDE EMISSION CONTROL OPTIONS
7.3.1  Procedure
     Since primary aluminum plants consist of a grouping of modules
(potlines), the control devices are also modular.  This reduces the
economies of scale advantage for the larger plants and also allows the
calculation of capital and annualized costs on a per ton of capacity
basis for use with any size of plant.  However, the number of much
greater interest is the cost in dollars per ton of aluminum actually
produced.  This can be calculated for each plant using either a historical
or a forecasted operating ratio and dividing it into the annualized cost
at capacity.  The only exception to this modular approach is the waste
water lime treatment facility.  This was estimated from an EPA  design.
7.3.2  Capital Costs
     The module approach for capital costs is presented in Table 7-4.
Modules are segregated by cell type.  For instance, since all the
vertical stud Soderberg plants have acceptable primary controls, only a
spray screen secondary control to capture and remove emissions  eluding
primary control systems is presented.  The center-worked and side-worked
pre-baked plants can be modified by means of thirteen modules.  One
module provides water treatment for the cryolite bleed stream.  Two
modules can be used to improve the collection system.  Two modules will
                                  7-11

-------
                          Table 7-4
 I

IN:
Control Modules for Upgrading  Existing Aluminum Plants.  Capital Costs

                (September  1977 Dollars)

          	($/Ton Annual Capacity	
               Control Module
  VSS

  1.   Install spray screen secondary

  CWPB  and SWPB
               Basic    ,
           Capital  Cost8
              $ 51.94
Capital Cost
Adjustment
  Factor5
   1.0
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
HSS
15.
16.
17.
18.
19.
20.
Lime treatment of cryolite bleed stream
Improve hooding
Install primary collection system
Install Inj. Alum, dry scrubber-primary
Install spray screen secondary
Remove dry ESP primary
Remove floating bed wet scrubber-primary
Install Fluidized bed dry scrubber-primary
Remove coated bag filters-primary
Remove fluidized bed dry scrubber-primary
Remove multiple cyclone-secondary
Remove spray tower-primary
Install anode bake plant controls

Lime Treatment of cryolite bleed stream
Improve hooding
Install wet ESP primary
Remove spray tower-primary
Install spray screen-secondary
Remove floating bed scrubber-secondary
—
6.18
22.69
32.41
37.10
5.46
5.33
37.10
10.00
14.27
0.87 (35.67/5.33)
2.47
--

— g—
6.18
129.68
4.34
51.94
7.99 (35.67/5.33)
—
1.6
1.0
1.08e
1.0
0.75
0.75
1 .084e
0.75
0.75
0.75
0.75
—


1.6
1.0
0.75
1.0
0.75
                                                                                                Old Plant
                                                                                                 Factor13
                                                                                                  1.15
                                                                                        15
                                                                                        15
                                                                                        15
                                                                                        15
                                                                                        15
                                                                                        15
                                                                                        15
                                                                                        15
                                                                                      1.15
                                                                                      1.15
                                                                                      1.15
                                                                                      1.15
                                                                                      1.15
                                                                                      1.15
                                                                                      1.15
                                                                                      1.15
1977 Adj.
 Factorc
  1.63
                                                             1.63
                                                             1.63
                                                             1.63
                                                             1.63>
                                                             1.63
                                                             1.63
                                                             1.63
                                                             1.63
                                                             1.63
                                                             1.63
                                                             1.63
                                                              1.63
                                                              1.63
                                                              1.63
                                                              1.63
                                                              1.63
Adjusted
 Capital
  $ 97.36
                                                    2.43U
                                                   18.54
                                                   42.53
                                                   65.86
                                                   69.54
                                                    7.68
                                                    7.49
                                                   75.39
                                                   14.06
                                                   20.06
                                                    8.19
                                                    3.47
                                                   20.49
                                                    2.43°
                                                   18.54
                                                  243.09
                                                    6.10
                                                   97.36
                                                   75.17
aTaken from reference 4.  Significant figures were retained for identification in original  reference.  Removal  cost is  taken as  75% of
 direct installation change of original equipment.
Reference 5.

cAdjust costs from January 1971 to September 1977.
 Taken from reference 6 and adjusted to September 1977.

eWeighted average gas flow adjustment factor from reference 7.

-------
provide improvement of the primary removal  system.  The installation of
a spray screen will improve the removal of secondary emissions.  The
final  module represents control of the anode bake plant.  Horizontal
stud Soderberg (HSS) modules are similar to the pre-bake modules.
     The numbers in the second column are the basic costs taken from
. ^ference 4.  In the two cases where a ratio is used to multiply a base
cost, the cost is listed as a primary module, but not as a secondary
module in reference 4.  However, the floating bed wet scrubber is listed
both as a primary and as a secondary module.  The cost ratio between the
two is $35.67 for the secondary module divided by 5.33 for the primary
module.  This ratio of 35.67/5.33 is used to convert "Remove multiple
cyclone" and "Remove floating bed wet scrubber" from primary to secondary
modules.
     The next column is the capital cost adjustment factor.  The factor
1.6 for the hooding modules is derived from reference 5 which assumes
that, in most cases, modifications will be made and new ducting added to
the primary collection systems amounting to an arbitrary 160 percent of
the estimated cost for main ducting in courtyard systems.  It is further
assumed that, when elements of existing control systems are changed from
one type to another, the original element will be either bypassed without
cost, or will be removed to provide physical space for the new element.
In the latter case, the net cost of demolition, including salvage credit,
is estimated to be 75 percent of the direct installation cost of equipment
removed.  The factor 1.08 represents the weighted average of the flow
adjustment between the model used in reference 4 and a sampling of
conditions existing in actual plants.  The column labeled "1977 Adj.
Factor" is the inflation adjustment using the Chemical  Engineering  Plant
                                  7-13

-------
Cost Index to convert reference 4 costs to September  1977.   The final
column represents the conversion of the basic costs to  current costs
with all the adjustments included.
     Reference 6, the source of costs for the water pollution  treatment
of the cryolite bleed stream, did not contain costs for a wastewater
lime treatment unit.  Therefore, cost estimates were  prepared  for  a
treatment unit designed by the Emission Standards and Engineering  Division
of EPA.  Since this treatment unit is not susceptible to the modular
treatment, units were estimated for three sizes of primary  aluminum
plants, 78,000, 156,000, and 312,000 tons of aluminum per year.  These
costs are shown in Table 7-5.
7.3.3  Annualized Cost
     Annualized costs are based on data in reference  4  just as  were the
capital costs.  However, the updating adjustments are considerably
different from those for capital costs.  Operating labor is adjusted
using the Department of Commerce Index of Hourly Earnings - Manufacturing.
Electric power is adjusted using the Wholesale Price  Index  for  Industrial
Power.  Circulating water, since most of its cost is  in electricity for
pumping plus a small amount for treating chemicals, is  adjusted by a
factor 10 percent higher than the electric power adjustment to  account
for this extra expense.  Lime costs are adjusted using  the  Chemical
Market Reporter quotations.  Product recovery credits are based on data
found in reference 4 updated from 1972.  For aluminum returned  to  the
                                  8               Q
cells, the ratio of current prices  to 1971 prices  for aluminum ingot
was determined to be 1.8.  This was applied to the unit price  for  the
credit.  The same publications were used to obtain the  ratio of fluorspar
                            7-14

-------
prices.   This ratio was 2.0.   Royalties are often tied to Wholesale
Price Index (Industrial).   The few cases where royalties are involved,
this index was used.
     In  the cases where the modules specified the removal of control
equipment, the annualized cost represents the savings resulting from not
operating the equipment or the loss incurred by not realizing the recovery
credits  gained by operating the equipment.
Table 7-5.   WASTE WATER LIME TREATMENT INVESTMENT3 COST BY SIZE OF PLANT
                     (September 1977 Dollars)
                               78.000 TPY   156.000 TPY    312.000 TPY
Installed Major Equipment      $828,000     $1,101,000     $1,477,000
Contingencies and Fee (? 20%     166.000        220.000        295.000
TOTAL                          $994,000     $1,321,000     $1,772,000
Unit Cost, $/ton capacity       $12.74         $8.47          $5.67
a
   Process and instrumentation design by the Emission Standards and
   Engineering Division of EPA.  Cost estimates prepared by vendor
   contacts by the Economic Analysis Branch, SASD, EPA.
                                  7-15

-------
     In order to bring the treatment of fixed cost  into  line with  EPA's
current practice of combining interest and depreciation  into a  capital
recovery factor, the fixed cost components of the annualized costs were
changed from those found in the contract report.    These changes are
detailed in Table 7-6.
     The annualized costs, recalculated as outlined above are found in
Table 7-7.  The annualized costs for the waste water lime treatment
appear in the next table - Table 7-8.
     Since the waste water lime treatment unit is not calculated in the
module basis, the investment and annualized costs for the three plant
sizes are plotted in Figure 7-1 so that interpolation can be made for
individual plants.
7.3.4  Cost-Effectiveness
     Cost-effectiveness is defined as the annualized cost of operating a
given control system divided by the number of pounds of pollutants captured
by the system per year.  When several systems are installed in succession,
the total overall cost divided by the overall weight of pollutant captured
is the "cumulative cost-effectiveness", shown in the next-to-last column
of Table 7-9.  Sometimes it is of interest to examine the stepwise effect
of the addition of each of the several systems.  This is referred to as
the "incremental cost-effectiveness" shown in the last column in Table 7-9.
This is obtained by dividing the annualized cost of each individual system
by the additional pollutants captured by it.  From this table, it appears
that the installation of spray screen secondary control with its attendant
waste water lime treatment is much less cost-effective than primary controls.
In fact, it adds from 1 to 2
-------
                  Table 7-6.  FIXED COST COMPONENTS
                                     Percent  of  Investment
Component                           Reference  TO            EPA
Taxes  and  Insurance                    2%                   2%
Administration                         5%                   5%
Depreciation                           8%
Interest                               8%
Capital  Recovery                       —                  13%
  (15  yrs  @ 10*)
   TOTAL                              23%                  20%
                                    7-17

-------
        Table  7-7.  CONTROL MODULES  FOR  UPGRADING  EXISTING
                    ALUMINUM  PLANTS  ANNUALIZED  COSTa
                    ($/ton Aluminum  Produced, in 1977  $)
                                                   Net  Annualized Cost
 Control Module                                         (Credit)
 VSS
   1.  Install  spray screen-secondary                      $31.71
 CWPB  and  SWPB
   2.   Lime treatment  of  cryolite  bleed stream             1.04
   3.   Improve  hooding                                    4.64
   4.   Install  primary collection  system                  11.56
   5.   Install  injected alumina  dry scrubber-primary     (1.76)
   6.   Install  spray screen-secondary                    22.84
   7;   Removal  dry ESP-primary                            1.69
   8.   Remove  floating bed wet scrubber-primary           (7.94)
   9.   Install  fluidized  bed dry scrubber-primary          3.16
  10.   Remove  coated bag  filters - primary                1.14
  11.   Remove  fluidized bed dry  scrubber  - primary        (3.16)
  12.   Remove multiple cyclone - secondary               (5.78)
  13.   Remove  spray tower-primary                         (4.12)
  14.   Install  anode bake plant                            5.79
HSS
  15.   Lime Treatment  of  cryolite  bleed stream             1.04
  16.   Improve  hooding                                     4^54
  17.   Install  wet  ESP  -  primary                        61.93
  18.   Remove spray  tower - primary                       (6.48)
  19.   Install  spray screen -  secondary                  31.70
  20.   Remove floating  bed scrubber - secondary          (77.79)

  aSource:  Reference  4 data updated  as described  in text.
                                   7-18

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                            Table 7-8.
 WASTE WATER TREATMENT PLANT OPERATING COST
        (By Size of Aluminum Plant)
         (September 1977 Dollars)
350  Days  Operated/Year
Annualized Cost
  Operating Costs
  A.  Direct
    1. Supplies
       CaO 135 Ib/ton Al. P
       FeCl3 0.135 Ib/ton Al.
       Separan (AP-30)
         0.00675 Ib/ton
    2. Operating Labor
    3. Supervision, 15% of 2
    4. Utilities
       a. Electricity
       b. Process Water
    5. Maintenance
    6. Laboratory 30% of 2
    7. Total Directs
 B. Indirects
    8. Taxes and Insurance
       (2% of capital)
    9. Administration
       (4% of capital)
    10. Capital Recovery
       (13% of capital)
    11. Total Indirects
Total Annualized Cost
Unit  Cost $/ton Al.
Unit Cost
78,000 TRY
156,000 TPY
312.000 TPY
l%t/lb.
4$/lb.
300
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                      Figure  7-1.   Investment and  Annualized Costs for Waste
                                   Water  Lime Treatment Plants vs. Aluminum
                                   Plant  Capacity
It)'
                           Plant  Capacity,  Tons  Al./Yr.
                                          7-20

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                                                             Table 7-9.   PRIMARY ALUMINUM CONTROL  STRATEGIES
                                                                                 VSS CELLS.
F\3
Plant
Code
5A
3B
18
24
Emission Controls Required for the Specified
Hooding Primary (1°) Controls
Best Available Spray tower + wet ESP
Install waste water
lime treatment
" No change (water
treatment handled
by 2»)
Fluidized bed dry scrubber
" " Injected alumina dry
scrubber
None None
Install primary Install injected alumina
Average Fluoride Emission
Secondary (2°) Controls
None
Install spray screen and
waste water lime treatment
1° and 2°
None
Install spray screen and
waste water lime treatment
SWPB CELLS
Spray scrubber
Install lime treatment
of cryolite bleed stream
None
None
Average
Fluoride
Evolution
Ib/ton Al
30.5
1
II
42.9
I
44.5
48
Unit Cost
Capital
$/ton Al
0
14.70
84.24
0
77.19
20.49*
22.92
20.49*
128.88
Annual 1 zed
$/ton Al
0
6.50
29.34
0
26.89
5.79*
6.83
5.79*
15.59
Average
Fluoride
Emissions
Ib F/ton Al
4.2
4.2
1.2
9.0
2.6
1.3
1.3
48.0
10.2
Cost-Effectiveness
Cumulative Incremental
$/lb F $/lb F
9.78 7.61
4.20 4.20
0.41
                  collection         dry scrubber
                  system
Install spray screen &
waste water lime treatment
207.42
42.88
                                                                                                                                  3.0
0.95
                                                                                                                                                          3.79
             Anode bake  controls  required on all  prebake plants

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                                                             Table 7-9.  PRIMARY ALUMINUM CONTROL STRATEGIES  (Continued)
ro
ro
Plant
Code
31C


26




8B

4A

HSS CELLS
Average
Fluoride
Emission Controls Required for the Specified Average Fluoride Emission Evolution
Hooding Primary (1°) Controls Secondary (2°) Controls Ib/ton Al
Best Available Spray tower + wet electro- None 32.1
static precipitator (ESP)
Install lime treatment
of cryolite bleed stream
' Install spray screen and
waste water lime treatment
Poor Spray tower None 41 . 6
Install lime treatment of '
cryolite bleed stream
Improve Hooding ' '
Install wet ESP; remove '
spray tower; install lime
treatment of cryolite bleed
stream
Install spray screen and
waste water lime treatment
CWPB CELLS
Best Available Fluidized bed scrubber None 45.5
Install spray screen
and waste water lime
treatment
Dry ESP + spray tower None 65.6
" Install waste water lime '
Unit Cost
Capital Annuall zed
$/ton AT $/ton AT
0 0
2.43 1.04
108.60 37.14
0 0
2.43 1.04
20.97 5.68
272.59 62.17
386.01 101.02
20.49* 5.79*
102.43 34.21
20.49 5.79*
29.39 10.19
Average
Fluoride
Emissions
1b F/ton Al
1.9
1.9
0.7
34.5
34.5
18.4
5.7
2.5
1.2
0.5
12.5
12.5
Cost-Effectiveness
Cumulative Incremental
$/1b F $/lb F
0 0
0 0
30.95 30.95
0 0
0 0
0.35 0.35
2.16 4.45
3.16 12.14
0 0
48.87 40.60
0 0
0 0
                                    treatment

                                    Install  fluidized bed dry '                                         107.03        6.52         4.7           0.84
                                    scrubber; remove dry ESP
                                    and scrubber;  lime treatment
                                    unnecessary

                                            "                 Install  spray screen and                 185.74       33.76         1.9           3.18       9.72
                                                              waste water lime treatment
                                                              -  2°
            Anode bake controls required on all prebake plants.

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7.4  REFERENCES FOR SECTION 7

1.   Memorandum from B. A. Varner to 6. B. Crane.   Estimation of
     Secondary Removal Efficiencies for Two Side-Worked  Prebake Plants
     Adding Primary Control of Existing Secondary Control.   Emission
     Standards and Engineering Division, OAQPS,  Environmental Protection
     Agency.  June 2, 1975.

2.   Development Document for Effluent Limitations  Guidelines and
     New Source Performance Standards for the  Primary Aluminum Smelting
     Subcategory of the Nonferrous Metals Manufacturing  Point Source
     Category.  Effluent Guidelines Division,  Office of  Air  and Water
     Programs, Environmental Protection Agency,  Washington,  D. C.
     Report Number EPA-440/l-74-019-d.  March  1974.  p.  110.

3.   Air Pollution Control in the Primary Aluminum  Industry.  Singmaster
     and Breyer, New York, N.Y.  Prepared for  Office of  Air  Programs,
     Environmental Protection Agency, Research Triangle  Park, N.C.  under
     Contract Number CPA 70-21,  July 23, 1973.   p.  2-31.

4.   Ibid.  pp. 8-22, 8-27 thru  8-31.

5.   Ibid, page 9-12.

6.   Reference 2

7.   Singmaster and Breyer op. cit. p. 9-10.

8.   Chemical Marketing Reporter, January 2, 1978.

9.   Minerals Yearbook, Volume I, 1973 United  States Department of the
     Interior, Bureau of Mines,  pp. 137, 155.

10.   Singmaster and Breyer op. cit. p. 8-25.
                                   7-23

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              8.   RATIONALE OF STATE EMISSION GUIDELINES
                   FOR EXISTING PRIMARY ALUMINUM PLANTS

8.1  INTRODUCTION
     The recommended State fluoride emission guidelines in Section 8.3
are not expressed in terms of emission limitations, but are presented as
recommended control technologies that will achieve certain average
fluoride control  efficiencies when applied as new retrofits to existing
plants.  The relative performances of the recommended controls are
calculated from known cell fluoride evolution rates.
     The data base underlying the State guidelines has been derived from
State and industry test methods that often differ from EPA methods of
emission measurement.  Therefore, significant differences among the
accuracy of these methods is possible.  Because of the varying design of
existing roof monitors, the use of source test method 14 may be precluded.
The different roof monitor configurations may also prohibit the deter-
mination of the relationship between the emission test method used and
Method 14.
     State regulations are now in force that limit fluoride emissions
from existing primary aluminum plants.  The terms of the regulations and
their compliance  test requirements tend to differ among States and from

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the Federal standards of performance for new primary aluminum plants.
The guidelines are therefore structured to give the State maximum flexibility
to utilize existing emission control and source sampling and analytical
methods, and to avoid the requirement for unnecessary modifications of
roof monitor sampling systems.
     Good operation and good maintenance of potrooms is essential to
good control, and the States should take steps to insure such objectives
in their plans for implementing the guidelines.
     .  All hood covers should be in good repair and properly positioned
        over the pots.  The amount of time hood covers are removed during
        pot working operations should be minimized.
     .  Some hooding systems are equipped with a dual low and high hood
        exhaust rate.  This should be conscientiously used whenever hood
        covers are removed and returned to the normal exhaust rate once
        the hood covers are replaced.
     .  A fuming pot often indicates a sick cell or clogged hooding ductwork.
        Either case represents poor potroom operation and should not be
        allowed to continue.
     .  Some tapping crucibles are equipped with hoses which return
        aspirator air under the hood.  The hoses should be in good repair
        and the air return system should function properly.
     .  Dust entrainment should be minimized during the sweeping of work
        aisles.  Some plants utilize vacuum sweepers which collect floor
        sweepings in fabric bags.

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8.2  Fluoride Emission Control  Equipment and Costs (September 1977)


     Table  8-1  gives some typical costs for certain model operations

pertaining  to fluoride control  at existing aluminum plants.  Conservative

values for  capture and removal  efficiencies are also included as

percents.   The  given cost values are taken from Tables 7-4 and 7-7

and represent only three of the several plant construction operations

that may take place in any real situation.  To illustrate the use of such

modules refer to plant 26 in Table 7-9.


                 Table 8-2.    The Use of Capital  Cost Modules
     Fluoride  Emission                              Capital Cost
     Control Module                              $/Annual ton Al

     Install lime treatment of
       cryolite bleed stream                         $2.43
     Improve hooding                                 18.54
     Install wet ESP                                243.09
     Remove spray tower                               6.10
     Install lime treatment for additional
       cryolite bleed stream                          2.43
     Install spray screen                            97.36
     Install waste water lime treatment              15.90
                                                   $385.85

As shown,  the  final  cost involved in any selected degree of control simply

involves a determination of the construction scope of work (new equipment,

deletions, etc.) followed by addition of the respective module costs.  The

seven cost modules shown for plant 26 add up to a total capital cost of

$386 per annual  ton of aluminum produced.  The annualized costs could be

derived in an  analogous manner.
                                  8-3

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                           Table 8-1.  CONTROL EQUIPMENT AND COSTS (September 1977)
CO
Fluoride Emission
Control Module

Improve Hooding
CWPB
SWPB
HSS
Install Primary Removal
CWPB
SWPB
HSS
Install Secondary Removal
VSS
CWPB
SWPB
HSS

Capital
$/annual ton
18.54
18.54
18.54

75.39
75.39
243.09

97.36
69.54
69.54
97.36
Cost
Annual i zed
$/ton
4.64
4.64
4.64

3.16
3.16
61.93

31.71
22.84
22.84
31.71
Efficiency,
Percent

95
80
90

98.5
98.5
98.5

75
75
75
75

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    The  cost  modules  are estimates and may be used when actual
engineering  cost  estimates or retrofit costs are not available.  They
also allow cost comparisons among degrees of control at the same plant
or of  costs  among different plants.  Some actual retrofit costs are
given  in  Table 6-33.
                                  8-5

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8.3  RECOMMENDED STATE GUIDELINES AND COLLECTION AND REMOVAL
     EFFICIENCIES OF CONTROL EQUIPMENT FOR FLUORIDE EMISSIONS

     The recommended State guidelines haye been developed as described
in Section 8.3.1 and are summarized in Table 8-3.  The  table may  be
explained in the following manner:  Column 1 shows each of  the  four cell
types. Column 2 gives the recommended average primary collection  efficiencies
(hooding) and Column 3 the primary removal efficiencies that EPA  believes
are readily achievable with new retrofits.  An achievable secondary
removal efficiency is also presented in Column 4.  Column 5 shows the
recommended technology for control of total fluoride emissions. Included
is an indication of the status of primary control on a  national basis
and the conditions under which better primary control should be installed
or secondary control added.
     The fluoride emission ranges corresponding to the  State guidelines
are presented in Table 8.4.  The recommended minimum fluoride collection
and removal efficiencies have been used in equation 7-1 to  estimate
average fluoride emissions after the various controls are applied.  Two
cases are worked out for each of the four cell types:   these cases
correspond to the smallest and greatest evolution rates shown for each
cell type in Table 7.2, and these extreme evolution rates are displayed
in Column 6 of Table 8.4.  The calculated cell average  emissions
corresponding to the evolution rates are arranged in the last column to
show the range of emissions caused by the variations in cell fluoride
evolution at the various plants from which EPA received cell evolution data.
     The guideline primary collection efficiencies of Column 2,
                             8-6

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                Table  8-3.   STATE GUIDELINES FOR CONTROL OF FLUORIDE EMISSIONS FROM EXISTING PRIMARY ALUMINUM PLANTS
Cell Type
VSS

SWPB

HSS

CWPB

Recommended Efficiencies
for Proposed Retrofits Guideline Recommendations
Primary Collection
80

80

90 (a)

95 (a)

Primary Removal
98.5

98.5
t
98.5

98.5

Secondary Removal
75 (a)

75(a)





All plants now have best achievable hooding
and primary removal .
Install secondary control, but only if
justified depending on severity of fluoride
problem.
Install best achievable hooding and primary
removal equipment.
Install secondary control wherever
justified, depending on the severity of
the fluoride problem.
All plants but #26 now have the best
achievable primary collection efficiency.
Plant #26 should install best primary
control if needed.
Secondary control does not appear to be
justified, in most locations.
Best control is best hooding and primary
removal equipment. Install where needed.
Secondary control does not appear to be
justified, in most locations.
•
oo
-•j
     (a)  See Section 8.3.1

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                       Table 8-4.   FLUORIDE  EMISSION  RANGES CORRESPONDING TO STATE GUIDELINES FOR EXISTING PRIMARY ALUMINUM PLANTS
Cell
Type

VSS
SWPB
HSS
CWPB
Recommended Efficiencies
for Proposed Retrofits
Primary Primary Secondary
ol lection Removal Removal
80 98.5 75
V
/
80 98.5 ' 75
90 98.5
(a)
95 98.5
(a)
Guideline
Recommendations
All plants now have best achievable
hooding and primary removal.
Install secondary control, bat only
if justified, depending on severity
of fluoride problem.
Install best available hooding
and primary revmoval equipment.
Install secondary control wherever
justified, depending on the severity
of the fluoride problem.
InstaVI best primary control if
needed. All plants but #26 now
have best achievable primary collectic
efficiency.
Secondary control does not appear to t
justified, in most locations.
Best control is best hooding and
primary removal equipment.
Install where needed.
Secondary control does not appear to
be justified, in most locations.
Assumed Average
Fluoride Cell
Evolution-lb/ton Al
30 - 54
37 - 53
n
28 - 45
e
26 - 66
Average Fluoride Emission
range, Ib F/ton Al
Control
Primary 6.4* - 11 .4
Secondary 1.9** - 3.4
Primary 7.8 - 11.2
Secondary 2.3 - 3.3
Primary 3.2 - 5.1
Secondary 1.1 - 1.7
Primary 1.7 - 4.2
Secondary — —
00
CO
         *    30 [ 1 - .80 x .985] = 6.4 Ibs F/ton Al         (a)  See Section 8.3.1
         **   30 [ 1 - .80 x .985 - (1 - .80) x .75] = 1.9 Ibs F/ton Al

-------
Table  8.3  are  based on methods of calculation given in detail in Section
6.1.2.   These  calculated efficiencies agree well with those that were
directly measured or otherwise arrived at by the owners of similar
plants.  Hooding efficiency depends on several factors such as cell
design,  age, operation and maintenance, and hood exhaust rate; and Table
7.3 ;hows  cases  where claimed efficiencies vary from those of the guide-
lines.   There  are various reasons for the cell hooding efficiencies for
given  cell  types.   The VSS cell has exposed molten electrolyte bath area
around the hood  skirt that varies with cell design.  This factor limits
cell collection  efficiency and also causes fluoride escape according to
the amount of  cell  bath area exposed.  Hood efficiency also depends on
the number of  times a cell hood has to be opened to produce a ton of
aluminum;  fluoride escapes during openings.  The HSS cell varies from 16
to 50 openings per ton of aluminum produced, depending on cell design.
     The plants  considered in Table 8-4 are hypothetical plants, and
therefore,  costs have not been derived for these specific cases.  Instead,
the cost of Table 7-9 for analogous cases will be discussed in the
guidelines.  The costs derived in Table 7-9 are applied to actual plants,
but are model  plant costs.  Considering their uncertain accuracy applied
to real  situations, they will be sufficient to illustrate the cost
effectiveness  of State guidelines.
8.3.1   State Fluoride Emission Guidelines
     The following State emission guidelines for control of total fluoride
emissions  from existing primary aluminum plants are restated from Table
8.3.   The range of average fluoride emissions, according to the last
column of  Table  8-4, is given after the guideline for each cell type.
                                  8-9

-------
As explained above, the range of the average emissions reflects the
range of known cell evolutions.
     VSS CELLS
      The primary collection efficiencies for all existing plants are
only about 80 percent, but are essentially the best achievable for this
type of cell.  The primary removal efficiencies for all existing plant
VSS cells are high, in the range of 98.4 to 99.9 percent.  Therefore,
secondary controls should be installed only if justified by the severity
of the fluoride problem.  The expected emission ranges are as
follows:
     Average emissions from primary control (calculated):
       = 6.4 to 11.4 Ib F/ton Al
     Average emissions from primary plus secondary control (calculated):
       = 1.9 to 3.4 Ib F/ton Al
     Incremental cost effectiveness for secondary control is in the
approximate range of $4 to $8 per pound of fluoride removed, as indicated
in Table 7-9.  Essentially, no expenditures are required for primary
control.  The cases in Table 7-9 were all chosen to represent—for each
cell type—the least and the greatest emission rates after installation
of best primary and secondary control.
     SWPB CELLS
     SWPB cells must be worked along both sides with the side covers
removed, and for longer times than other cells (Tables 6.2-6.6).  Therefore,
there is an inherent limitation to the primary collection efficiency of
these cells.
     The best achievable hooding for this type of cell has about 80%

                           8-10

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collection efficiency.  In addition to installing the best available
primary hooding and removal equipment, secondary controls should be
installed, if justified, depending on the severity of the fluoride
problems.  The emission ranges are as follows:
     Average emissions from primary control (Calculated):
       = 7.8 to 11.2 Ib F/ton Al
     Average emissions from primary plus secondary control (calculated):
       = 2.3 to 3.3 Ib F/ton Al
     The cost effectiveness of secondary control is $3.79 per pound of
fluoride removed for plant #24.  It will be somewhat higher for other
SWPB plants because they are initially better controlled.
     HSS CELLS
     All plants except plant #26 presently have essentially the best
achievable primary collection efficiencies of about 90 percent.  If the
primary removal systems for HSS cells are upgraded to 98.5 percent, this
should be suitable for best retrofit control technology.  The emission
ranges are as follows:
     If hooding were added to, or replaced on, an existing HSS plant,
EPA believes that modern technology can achieve 90% collection efficiency,
in almost all cases.  A plant may exist where it is difficult or
economically impractical to install best hooding.
     If a modern primary removal system were added to, or replaced on,
an existing HSS plant, EPA believes that modern technology can achieve
98.5% removal efficiency.  A modern spray tower added ahead of existing
wet ESPs can raise primary removal efficiency to 98.5.  This spray tower
addition may be economically impractical if free space does not exist
within a reasonable distance of fluoride source and wet ESP.
                           8-11

-------
     If an HSS plant has existing primary collection efficiency of
85-90% and primary removal efficiencies of 95 - 98.5%, control agencies
should closely study costs and benefits, before requiring retrofits.
In the above efficiency ranges, retrofit does not seem justified unless
there is a local fluoride problem.
     Average emissions from primary control (calculated):
       = 3.2 to 5.1 Ib F/ton Al
     The lowest incremental cost effectiveness to improve the hooding is
about $0.35 per pound of fluoride, and to add best primary removal is
about $4 per pound of fluoride removed.
     Secondary control does not seem justified at an incremental cost
effectiveness ranging from $12 to $30 per pound of fluoride removed,
depending on the plant.  No HSS plants now have secondary control.

     CWPB CELLS
     Retrofit primary hooding can be added to achieve a collection
efficiency of 95 percent for CWPB cells, while primary fluoride removal
systems of 98.5 percent are common.  A primary collection and removal
system should therefore suffice for best retrofit control technology.
     If hooding were added to, or replaced on, an existing CWPB plant,
EPA believes that modern technology can achieve 95% collection efficiency!
in almost all cases.  A plant may exist where it is difficult or
economically impractical to install best hooding.
     If a modern primary removal system were added to, or replaced on,
an existing CWPB plant, EPA believes that modern technology can achieve
98.5% removal efficiency.
     If a CWPB plant has existing primary collection efficiency of
90-95% and primary removal efficiencies of 95 - 98.5%, control agencies

                           8-12

-------
should closely study costs and benefits, before requiring retrofits.
In the above efficiency ranges, retrofit does not seem justified unless
there is a local fluoride problem.
The emission ranges are as follows:
     Average emissions from primary control (calculated)
       = 1.7 - 4.2 Ibs F/ton Al
     Secondary control does not seem justified at an incremental cost effect-
iveness of $10 to $40 per pound of fluoride removed, depending on the
plant.  No CWPB plants now have secondary control.
     Secondary Removal
     Some secondary removal units (scrubbers) may not be able to achieve
75 percent efficiency (See Section 6.2.3).  Control officials should care-
fully study costs, impacts, and energy consumption before requiring either
replacements or initial retrofits.
8.3.2  Compliance Time
     Section 6.4 has discussed at some length the design, construction,
and startup time requirements for retrofit air emission controls on
existing primary aluminum plants.  The historical variation of delivery
times for supplies and equipment has been shown, and it was pointed out
that these deliveries are often completely outside the control of either
customer or control official.
     Because of the nature of plant construction and emission source
testing, compliance times for either activity tend toward a case-by-case
basis for the primary aluminum industry.  However, most air pollution
retrofits can be designed and installed in not more than 2-1/2 years.
States should add to this time any compliance demonstration time in excess
of that indicated in Table 6-37.  In all cases, States should require
proof for the time requirements claimed for each milestone.
                            8-13

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8.4  EMISSION TESTING
     EPA Reference Methods 13(a), 13(b), and 14 were developed for use
in the determination of total fluoride emissions from primary aluminum
plants, and are adapted for use with new sources.  However, it is
recognized that installation of Method 14 ductwork on existing sources
will result in variable costs, depending on the plant.   In some existing
plants, unreasonable costs may be incurred.  For these reasons, EPA
does not specify compliance testing for existing plants:  such testing
is to be decided by each State on a case-by-case basis, taking into
account economic feasibility.
                               8-14

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                    9.  ENVIRONMENTAL ASSESSMENT
     An environmental assessment for emission guidelines for existing
plants is unique in that the exact number of affected facilities is or
can be known.  Further, for the primary aluminum industry, individual
capacities, existing or proposed control schemes, and fluoride emissions,
are known for each plant.  From this degree of knowledge and specificity,
the national environmental impacts of alternative emission control
systems or levels were evaluated by simply summing individual plant
impacts for the entire population of United States primary aluminum
plants.
     A vast number of fluoride emissions control scheme permutations
exist within the primary aluminum industry.  There are four basic
aluminum reduction cell types, two fundamental levels of control--
primary and secondary—and many possible primary control schemes.  For
this reason, an environmental impact assessment of every control
scheme permutation was not attempted.  Instead, national environmental
imapcts—the sums of 31 individual plant impacts—of a few fundamental
levels of fluoride control were analyzed to illustrate the methods
that are applicable to all such analyses.  The levels of fluoride
emissions control considered were:
     1.  Initial  - The level of fluoride emissions control which would
                               9-1

-------
be expected in the absence of lll(d) State guidelines emissions (Table 7-2)
limitations for existing plants.  At this level, all plants are expected
to install water treatment systems which comply with 1983 effluent
guidelines for all existing or proposed fluoride emissions control
schemes.
     2.  Best Hooding with Best Primary Control - Each existing plant
is upgraded to the level of best cell hooding and primary control for
that particular plant.
     3.  Best Cell Hooding with Best Primary and Secondary Control -
     Each existing plant is further upgraded to the level of best cell
hooding and best primary and secondary control for that particular
plant.
     National air pollution, water pollution, energy, and solid waste
disposal impacts were estimated for each of these alternative levels
of fluoride emissions control.   Future experience will  probably show
that the national degree of control achieved by the States will lie
somewhere within the boundaries of levels 2 and 3, above.  However,
step 2 is not meant to be the lowest national level  of emission control
improvement, even though step 3 does represent the highest possible
improvement.  Levels 2 and 3 may be thought of as examples of two
national levels of fluoride emission control.
     Although it was not possible to illustrate individual impacts for
all fluoride control scheme permutations, examples of control schemes
with extreme impacts have been  provided.  For example,  in the water
pollution impact assessment, examples are given of plants with fluoride
                              9-2

-------
emissions control schemes which both maximize and minimize water pollution.
Thus, for each of the four major impact areas (air, water, energy, and
solid waste), specific plant examples showing maximum and minimum impacts
have been provided, along with national impact assessments for each of
the three fundamental levels of fluoride emission control.
9.1  AIR POLLUTION ASSESSMENT
     The air pollution assessment for emission guidelines progresses
from a generalized evaluation of fluoride emissions impact to more
specific impacts.  The first three sections of the air pollution assessment
discuss national fluoride emission impacts, extremes in source strengths,
and fluoride dispersion calculations.  The last two sections of the
assessment discuss particulate emissions from aluminum reduction cells
and anode bake plant emissions.
9.1.1  National Fluoride Emissions from Primary Aluminum Reduction Cells
     National fluoride emissions from primary aluminum reduction cells
have been calculated for all plants by methods indicated for plant 5A,
etc., in Table 7-3.   For each alternative level of fluoride emissions
control, the products of individual plant capacities and average emissions
were added to yield national fluoride emissions for each of the four
reduction cell types.  The results of these calculations, along with
average fluoride emissions by cell type and weighted by capacity, are
presented in Tables 9-1 and 9-2.
     The dramatic effects of emission control are illustrated by the
mass fluoride emissions figures in Table 9-1.  Implementation of the
lowest illustrated degree of control would result in a 50 percent
reduction in mass emissions of fluorides from primary aluminum reduction
                              9-3

-------
    Table 9-1.   NATIONAL TOTAL FLUORIDE EMISSIONS FROM PRIMARY
                     ALUMINUM REDUCTION CELLS
                                  National  Fluoride Emissions by
control Level
Initial
Best Hooding and
Primary Control
Best Primary and
Secondary Control
vssa
1,700
1,700
660
tei i
HSSa
3,000
2,100
890
lype uons
CWPBa
8,500
3,700
1,600
r/rr;
SWPBa
4,800
1,500
810
Total
18,000
9,000
4,000
VSS - vertical  stud Soderberg;  HSS  - horizontal  stud Soderberg;
CWPB - center-worked prebake;  SWPB - side-worked  prebake.
                               9-4

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        TABLE  9-2.   AVERAGE FLUORIDE EMISSIONS FOR PRIMARY
                          ALUMINUM REDUCTION CELLS
                                   Average Fluoride Emissions
Control Level
Initial
Best Hooding
and Primary Control
Best Primary and
Secondary Control
vssa
5.2
5.2
2.1
(Lb F/T<
HSSa
5.7
4.0
1.7
)n Al)
CWPB3
6.3
2.7
1.2
SWPB3
13
4.0
2.2
VSS -  vertical  stud Soderberg;  HSS - horizontal  stud Soderberg;
CWPB - center-worked prebake;  SWPB - side-worked prebake
                               9-5

-------
cells.  National fluoride emissions from this source would thus  be
reduced from 18,000 tons/yr to 9,000 tons/yr.  Although the  average
fluoride emissions for all cell types under this degree of control are
similar (Table 9-2), the fundamental level of control varies somewhat
among plants.  Secondary control exists at plants 18, 19, and  20.
9.1.2  Fluoride Emission Control Systems with Extreme Air Pollution
       Impacts
     To illustrate the extremes in effectiveness of fluoride emissions
control systems, the overall environmental impact for two individual
plants is presented in Table 9-3.  Plant 6B represents the most  effective
fluoride emissions control system applied to the most controllable cell
type--center-worked prebake.  One of the least effective emission
control systems is typified by Plant 26.  Table 9-3 compares the overall
environmental impacts of the two extremes in fluoride emissions  control
effectiveness.
     The range of control scheme effectiveness is best indicated by the
difference in average fluoride air emissions; 1 Ib F/ton Al  for  Plant
6B, and 34.5 Ib F/ton Al for Plant 26.  Although the more effective
emission control scheme reduces fluoride emissions by more than  a
factor of thirty over the poor control scheme, only twice as much
energy is required per ton of aluminum produced.  More solid waste is
generated by the poor control scheme compared to the effective control
scheme, mainly because of the higher percentage of mass removed  in a
wet primary versus a wet secondary control system.  Effluent emissions
per ton of aluminum produced must be the same for both examples, due to
the applicability of 1983 Effluent Guidelines Standards.
                                 9-6

-------
Table 9-3.  FLUORIDE EMISSION CONTROL SYSTEMS WITH EXTREME AIR
                         POLLUTION IMPACTS

Plant Code
Cell Type
Capacity (Tons Al/Yr)
Primary Control Scheme
Secondary Control Scheme
Air Fluoride Emissions
(Tons F/yr)
Average Fluoride Air
Emissions
(Lb F/ton Al )
Effluent Emissions
1. Fluoride: (Tons F/yr)
2. Total Suspended Solids
(Tons/Yr)
Fluoride Control
Energy Requirements
(Mwh/yr)
Average Fluoride Control
Energy Requirements
(Kwh/ton Al)
Solid Waste Generated from
Control of Fluoride
Emissions (Tons/yr)
Average Solid Waste Gen-
eration from Control of
Fluoride Emissions
(Lb/ton Al)

6B 26
CWPB HSS
115,000 51,000
Fluidized bed Spray tower
dry scrubber
Spray screen None
scrubber
57.5 880
1 34.5
5.75 2.55
11.5 5.1
58,800 13,200
511 259
2300 3,930
40 154
                               9-7

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9.1.3  Fluoride Dispersion
     Dispersion estimates were prepared comparing ground level con-
centrations before and after the retrofit of emission controls described
under cases A, B, and C in Section 6.3.  The purpose of those estimates
is to demonstrate the improvement in air quality that may result from
the retrofit.  The estimates pertain to specific primary aluminum
plants located in the northwestern United States.
Receptors
     As stated in Section 2.3, the most sensitive receptors are dairy
cattle grazing on forage that has a fluoride accumulation of more than
40 ppm.  Such an accumulation can be caused by a 30-day average ambient
air concentration of gaseous fluoride of about 0.5 micrograms per cubic
           3
meter (yg/m ).  Hence, dispersion calculations should be concerned with
the 30-day average concentration out to distances where the concen-
tration is normally diluted to 0.5 yg/m3.
Source Characteristics
     Emissions (Table 9-4) and ambient air concentrations (Table 9-5)
are expressed in terms of total  fluoride, because emission breakdowns
into gaseous and fine particulate forms were not available.  Both forms
are harmful and EPA New Source Performance Standards are in terms of
total fluoride.
                                9-8

-------
        Table 9-4.  FLUORIDE EMISSIONS AT PLANTS A, B, AND C
Plant Source
A Potrooms
" Scrubbers
11 Fume Control Units
500-foot Stack
B Potrooms
C Potrooms
" Fume Control Units
Fluoride Emissions (g/s)
Before Retrofit After Retrofit
2.08 1.84
4.3 	
	 0.92
4.3 	
16.3 8.6
(including ESPs)
34.3 3.4
	 1.5
     Table 9-4 presents the before and after retrofit fluoride emissions
at the three plants studied.  The fluoride emission rates are annual
averages, and are treated as constant on a year-round basis.  The
following paragraphs describe the basic emission characteristics at
each facility.
     At Plant A, potroom, scrubber, and fume control unit emissions are
from stacks and rooftop monitors about 55 feet above grade; effluent
temperatures are slightly above ambient temperatures.  The emissions
from the 500-foot stack are at a temperature of 90°F, with a flow rate
of 700,000 CFM.

                           9-9

-------
     At Plant B, all fluoride emissions before retrofit and about 90
percent of the emissions after retrofit are from the potroom areas.
Potroom area emissions are from roof monitors and from spray towers
near roof-top level.  All such emission are at or near ambient temperature
and should be characterized by negligible plume rise.  The remaining 10
percent of emissions after retrofit are from nearby ESPs, also near
roof-top level.  The proportion of emissions from the ESPs is small
enough to permit the simplifying assumption that all emissions are from
the potroom areas.
     At Plant C, all fluoride emissions before retrofit and about 70
percent of emissions after retrofit are from the potroom roof monitors.
Those roof monitor effluents, as at the other plants, are near ambient
temperature and are characterized by negligible plume rise.  The
remainder of emissions after retrofit are from fume control units near
roof-top level at a temperature between 150°C and 200°F.
     Generalized illustrations of roof monitor and stack emissions are
contained in Figures 5-1 to 5-4, Section 5.1.  In Section 6.3, retrofit
layouts are given for Plant A in Figures 6-13 and 6-14, for Plant B in
Figures 6-15 and 6-16, and for Plant C in Figures 6-19 and 6-20.
Dispersion Estimates
     For this analysis, a computerized dispersion model (CRS-1) recently
developed by the Meteorology Laboratory, NERC, was utilized. The CRS-1
is a Gaussian point source dispersion model.  The model generates, for
any given year, maximum 1-hour, 24-hour, and annual ground level con-
centrations.  Maximum concentrations for other averaging times (e.g., a
30-day averaging time in this case) can be obtained through special
analysis of the model output.
                                9-10

-------
     Maximum 30-day fluoride concentrations were estimated for distances
of 0.75, 2, 10, 20, and 40 kilometers from the center of each facility.
The 0.75 kilometer distance is assumed to be approximately that of the
plant boundary in each case.  All three facilities were assumed to be
isolated from other sources of fluorides.
     The CRS-1 is designed to accept one year of hourly atmospheric
stability-wind data as input.  For these analyses, the meteorological
input to the model consisted of one year of 3-hourly data, specially
preprocessed to generate estimated hourly values.  The data were obtained
from a National Weather Service Station characterized by generally
restrictive dispersion conditions and reasonably representative of
conditions at the facilities studied.  Probably the most important
characteristic of the dispersion conditions, as they pertain to this
analysis, is the high frequency of wind from a few directions, resulting
in higher 30-day concentrations than would occur with less restricted
air flow.  Possible impaction of the effluent plumes on elevated terrain
was not considered.
     The characteristics of the facilities, discussed earlier, required
modifications to the CRS-1 model itself.  The facilities have certain
area-source characteristics and are affected by aerodynamic downwash of
plant effluents much of the time.  Except for the 500-foot stack in the
before-retrofit case at Plant A, all fluoride emissions at the facilities
were of a low-level, area source configuration.  The height and areal
extent of low-level emissions were similar at all three facilities.
For modeling purposes, low-level fluoride emission at all three facilities
were approximated by a uniform circular area source 500 meters across
                                9-11

-------
and 20 meters above grade.   The area source was handled by approximating
low-level emissions as a "virtual point source" upwind of the facility
for each of the hourly CRS-1 computations.
     Aerodynamic downwash of plant effluents was simulated by assuming
an effective stack height of 10 meters (one-half the average height of
low-level emissions) for wind speeds greater than or equal to 2 m/s.
For wind speeds less than 2 m/s, downwash was assumed to have a lesser
influence, and an effective stack height of 20 meters was assumed.
     The 500-foot stack (in the before-retrofit case at Plant A) was
modeled through a separate CRS-1 analysis, which included a plume rise
estimate.  Ground level ambient fluoride concentrations were superimposed
on concentrations due to low-level emissions to determine total impact
of Plant A before retrofit.
     The highest 30-day average ground level ambient fluoride concen-
trations that were estimated for the year of data are presented in Table
9-5 for several downwind distances.  The given concentrations are the
maximums for each of the specified distances.  Note that best adequately
demonstrated control technology does not preclude undesirably high
fluoride concentrations, although the improvements in air quality are
still significant. Ambient fluoride concentrations may still exceed 0.5 p
up to 14, 24, and 20 Km downwind of plants A, B, and C respectively
after retrofit.  Close to the source (e.g., at the plant boundary),
where the greatest impact on air quality occurs, the ambient ground
level fluoride concentrations resulting from controlled emissions can
be reduced further by directing most of the emissions up stacks tall
enough to avoid aerodynamic downwash of the effluent.  Usually, a stack
                                 9-12

-------
     Table 9-5.   MAXIMUM 30-DAY AVERAGE  AMBIENT FLUORIDE
     CONCENTRATIONS IN THE VICINITY OF PLANTS  A,  B,  AND C
Plant
A
ii
ii
it
ii
it
B
n
n
n
n
ii
C
ii
n
n
n
Downwi nd
Distance (km)
0.75
(plant boundary)
2
10
14a
20
40
0.75
(plant boundary)
2
10
20
24a
40
0.75
(plant boundary)
2
10
20
40
o
Fluoride Concentration (yg/m )
Before Retrofit
41
13
2
-
0.6
0.2
104
34
5
2
-
0.5
219
72
10
3
1
After Retrofit
18
6
0.8
0.5
0.3
0.1
55
18
3
0.7
0.5
0.2
31
11
1
0.5
0.1
aThese values were interpolated.

                          9-13

-------
height about 2-1/2 times the height of any nearby buildings, or  other
obstacles to wind flow, is sufficient to avoid such downwash problems.
With increasing distance from the source, the benefits of a taller
stack diminish.  To significantly reduce ground level fluoride concen-
trations beyond a few kilometers from the source, there is no choice
but to further reduce emissions.
9.1.4  Particulate Emissions from Aluminum Reduction Cells
     Particulate emissions will be significantly reduced by emission
controls.  Reference (2) gives the particulate removal efficiencies for
various fluoride emissions control equipment.  These efficiencies were
used with Tables 7-2 and 7-3  to calculate national particulate  emissions
and average emissions for all plants for the three alternative levels of
fluoride emissions control as illustrated by Table 7-3.   The results of
these particulate emissions calcualations are presented in Tables 9-6
and 9-7.  The particulate fluoride emissions are reduced by about 50
percent.
     As shown in Table 9-6, national particulate emissions from  primary
aluminum reduction cells will be reduced from 44,000 to 25,000 tons/yr,
or to 21,000 tons/yr at the lowest level technically feasible.   The
effectiveness of good controls in controlling particulate emissions is
not coincidental; a substantial percentage of the total fluorides
emitted from primary aluminum reduction cells is in particulate  form.
Thus, in order to effectively control total fluoride emissions,  total
particulate emissions must also be well controlled.
9.1.5  National Particulate and Fluoride Emissions from Anode Bake
       Plants
     Fluoride and particulate emissions for anode bake plants are
                              9-14-

-------
 Table 9-6.   NATIONAL PARTICULATE EMISSIONS FROM PRIMARY ALUMINUM
                               REDUCTION CELLS
                       National  Participate Emissions by Cell  Type
Control Level
Initial
Best Hooding and
Primary Control
Best Primary and
Secondary Control
vssa
5,200
5,200
4,500
HSSa
8,700
6,400
5,200
(Tons/Yr)
CWPBa
18,000
8,300
6,600
SWPB3
12,000
5,400
5,000
Total
44,000
25,000
21 ,000
VSS - vertical  stud Soderberg;  HSS  -  horizontal  stud Soderberg;
CWPB - center-worked prebake;  SWPB  -  side-worked prebake
                              9-15

-------
   Table 9-7.   AVERAGE PARTICIPATE EMISSIONS FOR PRIMARY ALUMINUM
                                REDUCTION CELLS
Control Level

Initial
Best Hooding and
Primary Control
Best Primary and
Secondary Control
Average Participate Emissions
by Cell Type (Lb/Ton Al )
vssa
16
16
14
HSSa
17
12
10
CWPBa
13
6.1
4.9
SWPB3
32
15
13
aVSS - vertical  stud Soderberg;  HSS -  horizontal  stud Soderberg;
 CWPB - center-worked prebake;  SWPB -  side-worked prebake
                               9-16

-------
listed  in Table 9-8,  assuming that all  anode bake plants retrofit with
spray tower and wet electrostatic precipitator (WESP) control.  Accordingly,
before  and after retrofit emissions are given.

        Table 9-8.   ANODE BAKE PLANT AIR POLLUTANT EMISSIONS
Air Pollutant
Emissions

Parti cul ate
Fluoride
Before Retrofit
Average
(Ib/ton Al)
5
0.86
National
(ton/yr)
8600
1500
After Retrofit
Average
(Ib/ton Al)
0.5
0.05
National
(ton/yr)
860
86
Table 9-8 shows that fluoride and particulate mass emissions from anode
bake plants can be reduced by 94 and 90 percent respectively through
application of the indicated control scheme.  This degree of control
will reduce fluoride emissions from anode bake plants by 1,400 tons/yr
and decrease national particulate emissions by 7,700 tons/yr.
9.2  WATER POLLUTION IMPACT
     As  stated in Section 7.2, all plants with either wet primary or
secondary control were expected to meet 1983 effluent limitations
guidelines for primary aluminum plants.  The only two factors which
could influence mass effluent emissions were capacity and the percentage
                               9-17

-------
of capacity with wet controls.  In the following sections, 1983 effluent
guidelines are given, effluent emissions control schemes are outlined,
and national effluent emissions have been estimated for the alternative
levels of fluoride air emissions control.  A more detailed discussion
of water pollution control can be obtained from Reference (4).
                                                                   5
9.2.1.  Effluent Limitations Guidelines for Primary Aluminum Plants
     Table 9-9 lists 1977 and 1983 effluent limitations guidelines for
existing primary aluminum plants.  As shown by the table, 1983 standards
require fluoride effluent emissions to be reduced by a factor of twenty
over the 1977 standards.  1983 effluent guidelines will affect all
existing primary aluminum plants by the date indicated; consequently,
they have been applied in calculating effluent emissions for all alter-
native levels of fluoride air emissions control.
9.2.2  Water Pollution Control Technology Required to Meet 1983
       Effluent Guidelines Standards
     The two basic water treatment schemes which will be practiced by
the primary aluminum industry are scrubber water recycle with lime pre-
cipitation  of a bleed stream, and cryolite recovery with lime treatment
of the bleed stream.  The two methods differ only in that alumina and
fluoride are recovered from  the aqueous stream when cryolite recovery
is practiced.  Success of both these methods require lime treatment of
a low volume, high concentration bleed stream; the bulk of the scrubber
water is recycled.  This water pollution control approach allows fluoride
effluent emissions to be adequately controlled at a feasible cost.
9.2.3  National Effluent Emissions from Primary Aluminum Reduction  Plants
     National effluent emissions from primary aluminum plants have  been
 estimated  by  applying  1983  effluent  guidelines  standards  to  the  individual
                               9-18

-------
                       Table 9-9.  EFFLUENT LIMITATIONS FOR PRIMARY ALUMINUM PLANTS
vo
      To Be
      Achieved
      by July 1,
      1977
   Effluent
Characteristic
Fluoride

Total Suspended
Solids

pH
                      Effluent Limitations
         Maximum for               Average of Daily Values for 30
	any 1 Day	   Consecutive Days Shall Not Exceed
 Metric Units     English Units    Metric Units     English Units
(Kg/1000 Kg Al)    (Lb/Ton AT)    (Kg/1000 Kg AT)    (Lb/Ton AT)
                                              2.0
                                              3.0
                       4.0
1.0
                       6.0              1.5

                  Within the range of 6.0 to 9.0.
2.0
                 3.0
To Be
Achieved
by July 1 ,
1983
Metric Units
(Kq/1000 Kg Al)
English Units
(Lb/Ton Al)
'letric Units
(Kg/1000 Kg Al)
English Units
(Lb/Ton Al)
                   Fluoride

                   Total Suspended
                   Solids

                   PH
                           0.1
                           0.2
                       0.2
.05
                       0.4              0.1

                  Within the range of 6.0 to 9.0.
0.1
                 0.2

-------
plant control options contained in Table 7-2, illustrated in Table 7-3,
and employed in Section 9.   In estimating national effluent emissions,
all aluminum plants with wet controls at a particular fundamental level
of fluoride control were assumed to discharge aqueous wastes at the
maximum level allowed by 1983 standards.  Thus, by a simple summation
procedure, similar to the one used to calculate national fluoride air
emissions, national effluent emissions at alternative levels of control
were derived.
     Table 9-10 gives national effluent emissions by cell type for the
two pollutants regulated under the 1983 standards.  Average effluent
emissions by cell type—equal to national cell effluent discharges
divided by total cell capacity--are contained in Table 9-11.  As mentioned
in the introduction to this section, the applicability of 1983 effluent
limitations guidelines to the alternative levels of fluoride emissions
control allows the percent of capacity with wet controls to be determined
by inspection of the table of average effluent emissions.  The ratio of
average emissions to 1983 effluent standards for a particular level  of
control represents the fraction of capacity with wet controls at that
level.  For example, if a particular cell type had average fluoride
effluent discharges of 0.050 Ib/ton Al, then the degree of wet control
would be 0.050/0.100 or 50 percent of capacity.   Table 9-12 presents the
percent of capacity employing wet controls for the various cell types
and levels of air pollution control.
     Tables 9-10 and 9-12 show that the example controls will not sig-
nificantly alter effluent emissions compared to the initial level of
air pollution control.   Returning to the impact analysis procedure,

                               Q- 20

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Table 9-10.   NATIONAL EFFLUENT EMISSIONS FROM PRIMARY ALUMINUM PLANTS
Air Pollution
Control Level
Initial: Fluoride
Total Suspended Solids
Best Hooding and Primary
Control :
Fluoride
Total Suspended Solids
Best Primary and Secondary
Control :
Fluoride
Total Suspended Solids
Nati
b
vssa
23
45
23
45
32
64
onal Efflu
y Cell Typ
HSSa
35
70
35
70
52
104
ent Emissio
e (Tons/Yr)
CWPBa
21
42
0
0
135
270
ns
SWPBa
28
56
27
55
37
74
Total
no
210
85
170
260
510
 VSS -  vertical  stud  Soderberg;  HSS -  horizontal  stud Soderberg;
 CWPB - center-worked prebake;  SWPB -  side-worked prebake.
                               9-21

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       Table 9-11.   AVERAGE  EFFLUENT EMISSIONS FROM PRIMARY
                          ALUMINUM REDUCTION PLANTS
Air Pollution
Control Levels
Initial :
Fluoride
Total Suspended Solids
Best Hooding and Primary
Control :
Fluoride
Total Suspended Solids
Best Primary and Secondary
Control :
Fluoride
Total Suspended Solids
A\
vssa
0.07
0.14
0.07
0.14
0.10
0.20
/erage Eff
(Lb/1
HSSa
0.07
0.13
0.07
0.13
0.10
0.20
uent Emij
fon Al)
CWPBa
0.02
0.03
0
0
0.10
0.20
;sions
SWPBa
0.08
0.15
0.07
0.15
0.10
0.20
VSS - vertical  stud Soderberg;  HSS
CWPB - center-worked prebake;  SWPB
horizontal  stud Soderberg;
side-worked prebake.
                              9-22

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     Table 9-12.   EXTENT OF WET CONTROLS AT ALTERNATIVE LEVELS
                       OF FLUORIDE AIR EMISSIONS CONTROL
Air Pollution
Control Level
Initial
Best Hooding and
Primary Control
Best Primary and
Secondary Control
vssa
71
71
100
P
HSSa
67
67
100
ercent of Ce"
with Wet C(
CWPBa
16
0
100
1 Capacity
Dntrols
SWPBa
76
74
100
Tota
42
33
100
VSS - vertical  stud  Soderberg;  HSS  -  horizontal  stud Soderberg;
CWPB - center-worked prebake;  SWPB  -  side-worked prebake.
                              9-23

-------
this can be interpreted to mean that effluent emissions in the absence
of emission guidelines would be comparable to effluent emissions with
additional emission controls.  Thus, installing better air pollution
controls will not significantly increase water pollution.
9.2.4  Fluoride Air Emissions Control Schemes with Extreme Water
       Pollution Impacts
     To illustrate fluoride air emissions control systems with extreme
water pollution impacts, the overall environmental impact for two
individual plants is presented.  Plant 14B represents the air pollution
control system with the most beneficial water pollution impact, primary
dry scrubbing.  A typical wet air pollution control system is illustrated
by Plant 25B.  It should be emphasized that the applicability of 1983
effluent guidelines standards makes the mass effluent emissions a
function only of plant capacity for a plant with wet controls.  As a
result, all wet control syterns have been assumed to have average effluent
emissions equal to the 1983 standards.
     Table 9-13 shows the overall environmental desirability of primary
dry scrubbing versus primary wet control.  The CWPB plant generates no
fluoride control-related solid waste, nor does it discharge any effluent
emissions.  Plant 25B generates 15,600 tons of solid waste resulting
from fluorides control and discharges 10.1 tons of aqueous fluorides
per year. Air fluoride emissions can also be controlled as--or more—
effectively with primary dry scrubbing, versus wet control for most
cell types.  However, SWPB and VSS cells generally require secondary
control to achieve an acceptable level of fluoride emissions, and dry
scrubbing is not technically or economically feasible as a secondary
                               9-24

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Table 9-13.  FLUORIDE AIR EMISSIONS CONTROL SCHEMES WITH EXTREME
                          WATER POLLUTION IMPACTS
Plant Code
Cell Type
Capacity (Tons Al/yr)
Primary Control Scheme
Secondary Control Scheme
Air Fluoride Emissions
(Tons F/yr)
Average Fluoride Air Emissions
(Lb F/ton Al)
Effluent Emissions
1. Fluoride: (Tons F/yr)
2. Total Suspended Solids:
(Tons/yr)
Fluoride Control Energy Require-
ments (mwh/yr)
Average Fluoride Control Energy
Requirements (kwh/ton Al)
Solid Waste Generated from Control
of Fluoride Emissions (Tons/yr)
Average Solid Waste Generation
from Control of Fluoride Emissions
(Lb/ton Al)
14B
CWPB
206,000
Dry Scrubbing
None
206
2.0
0
0
43,500
211
0
0
25B
HSS
202,000
Wet Electrostatic
Preci pita tor
None
465
4.6
10.1
20.2
20,200
100
15,600
154
                            9-25

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control strategy.  Because of the necessity of secondary control  in some
instances, the abandonment of all wet control schemes is precluded.
9.3  SOLID WASTE DISPOSAL IMPACT
     All fluoride control related solid waste produced by the primary
aluminum industry is a direct result of wet, fluoride air emissions
control and the accompanying water treatment.  Dry scrubbing techniques
do not generate any solid wastes, because all captured solids are returned
to the process.  National and average solid waste generation from wet
fluoride control by the primary aluminum industry has been estimated by
applying the average solid waste generation figures in Table 9-14 to the
individual plant control options listed in Tables 7-2 and 7-3, or
derived as for plant 5A, etc.  As with other impact evaluations, a
summation procedure was used to obtain national impacts.  Solid waste
generation quantities listed with an asterisk in Table 9-14 were estimated
from probable effluent loadings based upon average fluoride generation.
All other solid waste entries in the table were obtained from Reference
(6).
9.3.1  National Solid Waste Generation Due to Fluoride Control by
       the Primary Aluminum Industry
     Tables 9-15 and 9-16 present national and average solid waste
generation caused by fluoride control in the primary aluminum industry.
Emission limitations will have an effect upon national solid waste
production similar to that for water pollution, namely:  installation  of
best controls will not significantly increase the solid waste over the
amount produced at the initial level of air pollution control.  As shown
in Table 9-15, the national generation of solid waste by the aluminum
                              9-26

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    Table 9-14.   SOLID WASTE GENERATION FOR VARIOUS FLUORIDE
                         EMISSIONS CONTROL SCHEMES6
Fluoride Emissions Control Scheme
Primary Dry Scrubbing
Primary Wet Scrubbing with Cryolite Recovery
Secondary Wet Scrubbing with Cryolite Recovery
Primary Wet Scrubbing with Lime Treatment
Secondary Wet Scrubbing with Lime Treatment
Primary Wet Electrostatic Precipitator (WESP)
with Lime Treatment
Primary WESP with Cryolite Recovery
Solid Waste
Generation
(Lb/Ton Al)
0
154
160
120
40*
150*
154*
*These values were estimated from probable effluent loadings.
                            9-27

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Table 9-15.  NATIONAL SOLID WASTE GENERATION FROM FLUORIDE CONTROL
                       BY THE PRIMARY ALUMINUM INDUSTRY
Air Pollution
Control Level
Initial
Best Hooding and
Primary Control
Best Primary and
Secondary Control
Natioi
Resull
vssa
35,000
35,000
44,000
lal Solid I
ting from
(Ton;
HSSa
54,000
54,000
75,000
daste Generc
Huoride Cor
3/Yr)
CWPBa
25,000
0
54,000
ition
itrol
SWPBa
45,000
44,000
48,000
Total
160,000
130,000
220,000
VSS - vertical stud Soderberg; HSS - horizontal  stud Soderberg;
CWPB - center-worked prebake; SWPB - side-worked prebake
                              9-28

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Table 9-T6.  AVERAGE SOLID WASTE GENERATION RESULTING FROM FLUORIDE
                    CONTROL FOR THE PRIMARY ALUMINUM INDUSTRY
Air Pollution
Control Level
Initial
Best Hooding and
Primary Control
Best Primary and
Secondary Control
AVI
vssa
110
110
140
2rage Solic
by C(
(Lb/-
HSSa
100
100
140
J Waste Gene
2ll Type
Fon Al)
CWPBa
19
0
40
jration
SWPBa
120
120
130
VSS - vertical  stud Soderberg;  HSS -  horizontal  stud Soderberg;
CWPB - center-worked prebake;  SWPB -  side-worked prebake
                              9-29

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industry from fluoride control is equal to 160,000 tons per year at the
initial, and 220,000 tons per year at the best, control levels of air
pollution control.
     Average fluoride control solid waste generation is lowest for
center-worked prebake cells at all levels of fluoride emissions control.
Table 9-16 illustrates the large difference in average solid waste
generation for CWPB cells as compared to the other three cell types.
Soderbergs and side-worked prebake cells generate at least 100 pounds of
sludge per ton of aluminum produced at all levels of air pollution
control; CWPB cells produce from 0-40 pounds of sludge per ton of
aluminum over the same range of control levels.  This difference in
solid waste generation can be attributed to the almost universal use of
primary dry scrubbing in controlling fluoride emissions from CWPB cells.
9.3.2  Fluoride Emissions Control Systems with Extreme Solid Waste
       Impacts
     Extremes in  solid waste generation resulting from fluoride control
are  illustrated by two individual plant examples.  Table 9-17 compares
the  overall environmental impacts of a plant with both primary and
secondary wet control and a plant with dry primary control only.  The
two  plants chosen as illustrative examples are both vertical stud
Soderbergs.  Plant 3B employs primary dry scrubbing only, while Plant 20
utilizes primary  wet scrubbers and wet electrostatic precipitators as
well as secondary spray screen scrubbers.  These two examples also show
the  large fluoride air emissions reductions which can be realized with
judicious application of secondary control.
                               9-30

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Table 9-17.   FLUORIDE EMISSIONS CONTROL SYSTEMS WITH EXTREME SOLID
                               WASTE IMPACTS
Plant Code
Cell Type
Capacity (Tons Al/Yr)
Primary Control Scheme
Secondary Control Scheme
Air Fluoride Emissions
(Tons F/Yr)
Average Fluoride Air Emissions
(Lb F/Ton Al )
Effluent Emissions:
Fluoride (Tons F/Yr)
Total Suspended Solids (Tons/Yr)
Fluoride Control Energy Requirements
(Mwh/Yr)
Average Fluoride Control Energy
Requirements (Kwh/Ton Al)
Fluoride Control Related Solid Waste
Generation (Tons/Yr)
Average Fluoride Control Related
Solid Waste Generation (Lb/Ton Al)
3B
VSS
185,000
Fluidized Bed
Dry Scrubbing
None
833
9.0
0
0
39,000
211
0
0
20
VSS
120,000
Wet Scrubber and
Electrostatic
Preci pita tor
Spray Screen
Scrubber
122
2.0
6
12
55,600
463
11,400
190
                            9-31

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     As shown in Table 9-17, Plant 20 generates 190 pounds of fluoride
sludge per ton of aluminum produced.   This sludge generation implies an
annual production of 11,400 tons of solid waste containing CaF2, CaS04
(generated from sulfur in carbon anodes) and other insoluble compounds.
Sludge of this type can usually be safely landfilled..  Plant 3B does not
discharge any effluent emissions or produce solid waste, but this plant
has average fluoride air emissions 4.5 times greater than Plant 20.  For
vertical stud Soderberg cells and other cells with similar emissions
characteristics, the increase in solid waste and effluent emissions
resulting from wet primary and secondary control is justified by the
dramatic decrease in fluoride emissions. Plant 3B with primary dry
control only, discharges 833 tons of fluoride per year into the atmos-
phere; Plant 20 emits only 122 tons of fluoride per year.
9.4  ENERGY
     The energy assessment has been prepared through application of a
procedure similar to the ones employed for the other impact area analyses.
Average energy consumption requirements for the numerous fluoride emissions
control schemes (Table 9-18) have been applied to the individual plant
control options contained in Tables 7-2 and 7-3 or defined in Section
9.  National and average fluoride emissions control energy requirements
are presented in Section 9.4.1, and examples of fluoride control systems
with extreme energy impacts are outlined in the section immediately
following.  Energy consumption figures in Table 9-18 and throughout the
energy assessment represent the amount of energy required for both air
and water pollution control and have been obtained from References (6)
and (7).  In some instances, the energy required for water treatment

                             9-32

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    Table
9-18.  ENERGY  REQUIREMENTS  FOR  PRIMARY  ALUMINUM
        FLUORIDE EMISSIONS  CONTROL  SYSTEMS6'7
Fluoride Control
System
Dry Scrubbing
Primary Wet Scrubbing with
Cryolite Recovery Water Treatment
Secondary Wet Scrubbing with
Cryolite Recovery Water Treatment
Primary Wet Scrubbing with Lime Water
Treatment
Secondary Wet Scrubbing with Lime Water
Treatment
Electrostatic Precipitator Incremental
Power when Used in Series with Another
Primary Control Device
Primary Venturi Scrubbing
Primary Multiclone
Primary Wet Electrostatic Precipitator
with Lime Water Treatment
Average Energy Requirements
(kwh/ton Al)
Electrical
211
78
357
76
300
87
600
75
100
Thermal3
0
181
181
0
0
0
0
0
0
aThermal  energy supplied by fossil  fuels is required to operate rotary
 kilns and generate steam when practicing cryolite recovery water
 treatment.
                           9-33

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exceeds that for fluoride air emissions control.
                                                                 t
9.4.1  National Fluoride Emissions Control Energy Requirements for
       the Primary Aluminum Industry
     National energy requirements for the three basic levels of fluoride
emissions control are listed in Table 9-19.  As shown in the last
column of Table 9-19, emission control will increase fluoride control
energy expenditures for the primary aluminum industry by as little as
120,000 megawatt-hours (Mwh) per year over the initial level of control.
This increase in energy demand would require an additional 14 megawatts
of electrical power generation nationally.  With 31 existing domestic
primary aluminum plants, the average incremental fluoride control power
expense resulting from best hooding and primary control will amount to
only 0.44 megawatts per plant.  In comparison, an average of 283 megawatts
of electrolytic power is required per domestic primary aluminum plant.
Thus, incremental fluoride control power expenditures for the case given
are equivalent to only a 0.15 percent increase in average electrolytic
power.
     Table 9-20 presents the average fluoride control energy require-
ments by cells type for the alternative levels of emissions control.  On
an absolute basis, the average energy requirements per ton of aluminum
for each cell type is primarily a function of the percentage of that
cell type with secondary control.  By examining the row entitled "Best
Primary and Secondary Control", it is clear that when all cell types are
upgraded to the level of best secondary control the average energy
requirement for all cell types is 600 - 90 kilowatt-hours (kwh) per ton
of aluminum.  In contrast, the other two levels of control require a wide
range of average fluoride control energy expenditures:  these range from
                              9-34

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Table 9-19.  NATIONAL FLUORIDE EMISSIONS CONTROL ENERGY REQUIREMENTS
                        FOR THE PRIMARY ALUMINUM INDUSTRY

Air Pollution
Control Level
Initial
Best Hooding and
Primary Control
Best Primary and
Secondary Control
National Fluoride Control
vssa
270,000
270,000
400,000
Enet
HSSa
280,000
280,000
590,000
-gy Requirei™
(Mwh/Yr)
CWPBa
520,000
590,000
1,400,000
?nts
SWPBa
400,000
450,000
510,000
Total
1,470,000
1,590,000
2,900,000
 VSS - vertical stud Soderberg; HSS - horizontal stud Soderberg;
 CWPB - center-worked prebake; SWPB - side-worked prebake.
                               9-35

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 Table 9-20.   AVERAGE FLUORIDE  EMISSIONS  CONTROL ENERGY REQUIREMENTS
                        FOR THE PRIMARY ALUMINUM INDUSTRY
Air Pollution
Control Level
Initial
Best Hooding and
Primary Control
Best Primary and
Secondary Control
;
vssa
420
420
620
Average Fli
Energy R(
(Kwh/-
HSSa
260
270
570
joride Coi
squiremen'
fon Al)
CWPBa
190
220
520
itrol
ts
SWPBa
540
610
690
VSS - vertical  stud Soderberg;  HSS -  horizontal  stud  Soderberg;
CWPB - center-worked prebake;  SWPB -  side-worked prebake
                              9-36

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a low of 190 kwh per ton of aluminum for CWPB cells to a high of 610 kwh
per ton of aluminum for SWPB cells.  The wide range of fluoride control
energy requirements reflects the varying percentages of cell capacities
that would be required to install or maintain secondary controls.
9.4.2  Fluoride Emissions Control Systems with Extreme Energy Impacts
     Table 9-21 shows the extremes in energy requirements of the various
fluoride emissions  control  schemes, and lists the overall environmental
impact for two individual  plants.  Plant 21A employs CWPB cells and is
equipped with primary multiclones only.  Plant 18 is one of the best
controlled, but the most control-energy-intensive of primary aluminum
plants.  Although Plant 21A has  no effluent emissions or solid waste
production, its average energy expenditure of only 75 kwh per ton of
aluminum yields high average emissions  of 14 pounds of fluoride per ton
of aluminum produced.   Plant 18  uses ten times as much energy to control
fluoride emissions; however, its average emissions are 1.3 pounds of
fluoride per ton of aluminum produced.   One significant aspect of Plant
18 is that nearly one-third of the energy utilized in control of fluorides
is a result of cryolite recovery water  treatment.  Substitution of lime
treatment only, in  place of the  cryolite recovery systems, would decrease
average energy consumption  by 240 kilowatt-hours per ton of aluminum
produced.
9.5  OTHER ENVIRONMENTAL IMPACTS
     Because of the electrical power required to control fluorides
emitted by the primary aluminum industry, each alternative level of
fluoride control has a unique indirect pollution penalty.  Although many
primary aluminum plants are supplied with hydroelectric base load power,
                               9-37

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Table 9-21.  FLUORIDE EMISSIONS CONTROL SYSTEMS WITH EXTREME ENERGY IMPACTS
Plant Code
Cell Type
Capacity (Tons Al/Yr)
Primary Control Scheme
Secondary Control Scheme
Air Fluoride Emissions
(Tons F/Yr)
Average Air Fluoride Emissions
(Lb F/ton Al)
Effluent Emissions:
Fluoride (Tons F/Yr)
Total Suspended Solids
(Tons/Yr)
Fluoride Control Energy
Requirement (Mwh/Yr)
Average Fluoride Control Energy
Requirements (Kwh/Ton Al )
Solid Waste Generated from
Control of Fluoride Emissions
(Tons/Yr)
Average Solid Waste Generation
Factor from Control of Fluoride
Emissions (Lb/Ton Al)
21 A
CWPB
70,000
Mul tic! ones
None
490
14
0
0
5,250
75
0
0
18
SWPB
260,000
Injected Alumina
Dry Scrubbing
Spray Scrubbing
with Cryolite
Recovery
169
1.3
13
26
195,000
750
20,800
160
                               9-38

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swing loads are often handled by coal-fired steam generators.  In order
to determine the maximum indirect pollution penalty associated with the
alternative levels of fluoride control, it has been assumed that all
fluoride control power requirements are supplied by coal-fired steam-
electric plants.  Table 9-22 lists incremental SOp, nitrogen oxides
(NO ), and particulate emissions which would be emitted by the power
   A
generation required for the alternative levels of fluoride control.  In
preparation of Table 9-22,  it has been assumed that the steam generators
employed can meet the applicable standards of performance for new stationary
sources.
     Comparing the first and last rows of Table 9-22, the incremental
indirect pollution penalty  of the fluoride emissions controls is apparent.
Adoption of the proposed emission limits would cause an incremental
minimum of 700 tons per year of S09,  500 tons per year of NO , and 60
                                  £                         A
tons per year of particulates to be discharged to the atmosphere from
the impacted power plants.   Although  the national mass emissions of
indirect pollutants seems to be high, only a negligible effect on ambient
air quality will result.
9.6  OTHER ENVIRONMENTAL CONCERNS
9.6.1  Irreversible and Irretrievable Commitment of Resources
     The only major irreversible impacts of the alternative fluoride
emissions control  levels are the amounts of ultimate fossil-fuel required
to generate the necessary electrical  power.  Continuing with the assumptions
made in Section 9.5, national bituminous coal requirements have been
calculated for the same alternative levels of fluoride control and are
presented in Table 9-23.  Although the probability is not high that all
                               9-39

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Table 9-22.  NATIONAL CRITERIA POLLUTANT EMISSIONS RESULTING FROM
               THE ELECTRIC POWER GENERATED TO CONTROL PRIMARY
                         ALUMINUM FLUORIDE EMISSIONS
Fluoride Air
Pollution Control
Level

Initial
Best Hooding and
Primary Control
Best Primary and
Secondary Control
National Criteria Pollutant
Emissions from Impacted Power
Plants (Tons/Yr)
so2
8,800
9,500
17,400
NOX
5,100
5,600
10,200
Parti cul ate
740
800
1,500
                             9-40

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Table 9-23.  NATIONAL BITUMINOUS COAL REQUIREMENTS  IMPLIED  BY  PRIMARY
                           ALUMINUM FLUORIDE  CONTROL
Fluoride Emissions
Control  Level
National Bituminous
Coal  Requirements
     (Tons/Yr)
Initial
     612,000
Best Hooding and
Primary Control
     662,000
Best Primary and
Secondary Control
   1,210,000
  For calculational  purposes,  bituminous coal  was assumed to have a
  high heating  value of  12,000 Btu/lb.
                               9-41

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fluoride control energy requirements would be supplied by bituminous
coal, incremental fluoride control energy consumption will increase
fossil-fuel consumption directly or indirectly.
     As shown in Table 9-23, the best fluoride primary control will
increase national bituminous coal (or other equivalent fossil-fuel)
consumption by 50,000 tons per year.  Any additional drain upon fossil -
fuel reserves would be negligible compared to overall national fossil-
fuel energy requirements.  In fact, an equivalent amount of energy would
be required if only one average size aluminum plant increased its capacity
by about 3 percent.
9.6.2  Environmental Impact of Delayed Action
     Postponement of any fluoride emission limits would have some
deleterious effect upon the environment.  Although some states have
strict fluoride  emissions standards for primary aluminum plants, many do
not.  Without the impetus for proper maintenance of existing control
systems, current fluoride emissions could conceivably increase significantly.
Federal effluent guidelines for primary aluminum plants will go into
effect regardless of air emissions limitations, and consequently, several
wet  control systems could be abandoned if adequate air emissions limits
are  not implemented.  Thus, the suggested air emissions limitations
procedures will  not only require poorly controlled plants to upgrade or
install new control systems, they will also force well-controlled plants
to maintain their existing control systems.
9.6.3  Environmental Impact of No Action
     The environmental impact of failing to implement any additional
emission limits  is represented by the "Initial" level of fluoride control
                            9-42

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used throughout the environmental impact assessment.  As stated in the
previous section, the environmental impact of no fluoride emission
limits could be considerably more severe than that for the initial level
of control.  Poor maintenance and the abandonment of existing control
systems could further increase fluoride air emissions.  Thus, it
mist be realized that the initial level of fluoride control is a conservative
estimate of the effect of not implementing additional controls for
existing plants.  With this limitation in mind, Table 9-24 compares the
overall environmental impact of the "Best Hooding and Primary Control"
to that for the initial level of control.
     As discussed in Section 9.1, failure to adopt any of the suggested
emission controls for the primary aluminum industry would result in
national fluoride emissions of at least 18,000 tons per year, versus
9,000 tons per year for the improved control.  With or without State
action on air emissions limits, effluent discharges and solid waste
generation by the primary aluminum industry will remain at nearly the
same level.  The only beneficial impact of failing to adopt additional
emission limits would be an energy savings of 120,000 megawatt-hours per
year for the case shown in Table 9-24.  This energy savings is negligible
in comparison to the amount of energy used in normal primary aluminum
plant operation.
                            9-43

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Table 9-24.  ENVIRONMENTAL IMPACT OF NO ADDITIONAL STATE FLUORIDE
             AIR EMISSIONS LIMITATIONS FOR THE PRIMARY ALUMINUM
                                INDUSTRY
National Impacts
National Fluoride Air
Emissions (Tons F/Yr)
National Effluent
Emissions:
.Fluoride (Tons F/Yr)
Total Suspended Solids
(Tons/Yr)
National Fluoride Control
Energy Requirements
(Mwh/Yr)
National Fluoride Control
Related Solid Waste
Generation (Tons/Yr)
Initial
18,000
110
210
1,470,000
160,000
Fluoride Emissions
Control Level
Best Hooding and Primary Control
9,000
85
170
1,590,000
130,000
                             9-44

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9.7  REFERENCES FOR SECTION 9

1.   Memorandum from Laurence J.  Budney to Stanley T. Cuffe.  Primary
     Aluminum Retrofit Controls;  Impact.  Monitoring and Data Analysis
     Division, OAQPS, EPA.   February 4, 1974.

2.   Air Pollution Control  in the Primary Aluminum Industry.  Singmaster
     and Breyer,  New York,  N.Y.   Prepared for  Office of Air Programs,
     Environmental  Protection Agency,  Research Triangle Park, N.C. under
     Contract Number CPA 70-21.   July  23, 1973.   pp. 5-14 to 5-16.

3.   Reference 2,  above, p.  4-11.

4.   Development  Document for Effluent Limitations Guidelines and
     Standards of Performance.  Nonferrous Metals  Industry.   Part II -
     Primary Aluminum Smelting.   Battelle Columbus Laboratories,
     Columbus, Ohio.   Prepared for  Office of Air and Water Programs,
     Environmental  Protection Agency,  Washington,  D.C.  under Contract
     Number 68-01-1518.   (Draft Contractor's Report, dated June 1973).

5.  Reference 4,  above,  pp.  3 and 4.

6.   Reference 4, above,  p.  115.

7-  Reference 2,  above,  pp.  5-14  to  5-16.
                               9-45

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                                   TECHNICAL REPORT DATA
                            (Please read Instructions on the reverse before completing)
  REPORT NO.
    EPA 450/2-78-0493
                                                            3. RECIPIENT'S ACCESSION NO.
 TITLE AND SUBTITLE
    Primary Aluminum:   Draft.Guidelines for Control of
    Fluoride  Emissions From Existing  Primary Aluminum
    Plants                        	^_____
             5. REPORT DATE
               2/14/79
             6. PERFORMING ORGANIZATION CODE
  AUTHOR(S)
                                                            8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
                                                            10. PROGRAM ELEMENT NO.
    U.S. Environmental  Protection Agency
    Office of Air Quality Planning  and Standards
    Research Triangle Park, NC  27711
             11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
                                                            13. TYPE OF REPORT AND PERIOD COVERED
                                                            14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
         This  document serves as a  text to State agencies  in  planning for control  of
    fluoride emissions from existing  primary aluminum plants.   Achievable fluoride
    capture and  removal efficiencies  are given for new retrofit hooding and for
    primary and  secondary removal devices, respectively.   Methods  for deriving
    capital and  annualized costs are  illustrated by a few  examples.   Costs and
    fluoride emission reductions achieved by actual retrofits  are  given for ten
    plants, and  the construction scope  of work is described in detail for three  of
    these plants.   The guidelines are presented as recommended control technologies
    that will  achieve certain average control  efficiencies when applied as new
    retrofits  to existing plants.
17.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                               b.lDENTIFIERS/OPEN ENDED TERMS
                                                                             COS AT I Field/Group
    Primary aluminum plants, existing
       Fluorides
       State Guidelines for emission control
       Hooding efficiency
       Fluoride removal efficiency
       Retrofit control costs
   Air Pollution Control
13B
 18. DISTRIBUTION STATEMENT
    Unlimited
19. SECURITY CLASS (This Report)
    Unclassified
                                                                           21. NO. OF PAGES
  343
                                               20. SECURITY CLASS (Thispage)
                                                   Unclassified
                           22. PRICE
                              No Charge
 EPA Form 2220-1 (Rev. 4-77)   PREVIOUS EDITION is OBSOLETE

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