&EPA
            United States
            Environmental Protection
            Agency
           Office of Air Quality
           Planning and Standards
           Research Triangle Park NC 27711
EPA-450/3-78-030
OAQPS No. 1.2-113
June 1978
Air
            OAQPS Guideline
            Series

            Air Pollutant Control
            Techniques for
            Phosphate Rock
            Processing  Industry

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                                         EPA-450/3-78-030
                                        OAQPS No. 1.2-113
     Air Pollutant  Control Techniques
for Phosphate Rock  Processing  Industry
                            by

                       David M. Augenstein

                     PEDCo Environmental, Inc.
                        Chester Towers
                       11499 Chester Road
                      Cincinnati, Ohio 45246
                     Contract No. 68-01-4147
                    EPA Project Officer: Lee L. Beck
                         Prepared for

               U.S. ENVIRONMENTAL PROTECTION AGENCY
                  Office of Air and Waste Management
                Office of Air Quality Planning and Standards
               Research Triangle Park, North Carolina 27711

                         June 1978

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                                OAQPS GUIDELINE SERIES
The guideline series of reports is being issued by the Office of Air Quality Planning and Standards
(OAQPS) to provide information to state and local air  pollution control agencies; for example, to
provide guidance on the acquisition and  processing of air quality data and on the planning and
analysis  requisite for the maintenance of air quality. Reports published in this series will  be
available - as supplies  permit   from the Library Services Office  (MD-35), U.S.  Environmental
Protection Agency, Research Triangle Park, North Carolina 27711, or, for a nominal fee, from the
National Technical Information Service, 5285 Port Royal Road, Springfield, Virginia 22161.

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                          CONTENTS



                                                       Page




FIGURES                                                  vi



TABLES                                                  vli



ACKNOWLEDGMENT                                           xi



1.0  INTRODUCTION                                      1-1



2.0  SOURCES AND TYPES OF EMISSIONS                    2-1



     2.1  General                                      2-1



     2.2  Mining and Beneficiation                     2-5



     2.3  Drying                                       2-9



     2.4  Calcining                                    2-16



     2.5  Grinding                                     2-16



     2.6  Materials Handling and Storage               2-25



3.0  APPLICABLE EMISSION REDUCTION TECHNIQUES          3-1



     3.1  Mining and Beneficiation                     3-1



     3.2  Conveying of Rock                            3-2



     3.3  Phosphate Rock Drying                        3-2



     3.4  Phosphate Rock Calciners                     3-11




     3.5  Grinding                                     3-18



     3.6  Materials Handling and Storage               3-23



     3.7  Wet Grinding                                 3-26



     3.8  Retrofitted Control Systems                  3-28



4.0  COST OF APPLYING CONTROL TECHNOLOGY               4-1



     4.1  Introduction                                 4-1




     4.2  Drying                                       4-12
                              ill

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                    CONTENTS (Continued)
                                                          Page
     4.3  Calcining                                       4"27
     4.4  Grinding                                        4-35
     4.5  Wet Grinding                                    4-41
5.0  ENVIRONMENTAL IMPACT OF APPLYING CONTROL             5-1
     TECHNOLOGY
     5.1  Introduction                                    5-1
     5.2  Ambient Air Imp act                              5-2
     5.3  Water Pollution Impact                          5-7
     5.4  Solid Waste Impact                              5-12
     5.5  Energy Impact                                   5-14
     5.6  Radiation Impact                                5-21
6.0  EMISSION MEASUREMENT AND CONTINUOUS MONITORING       6-1
     6.1  Emission Measurement Methods                    6-1
     6.2  Continuous Monitoring                           6-2
     6.3  Performance Test Methods                        6-3
7.0  ENFORCEMENT ASPECTS                                  7-1
     7.1Regulations                                     7-1
     7.2  Format of Emission Standards                    7-2
     7.3  Enforcing Regulations                           7-10
8.0  REGULATORY OPTIONS                                   8-1
     8.1  Control  Technology and Impacts                  8-1
     8.2  New Versus Existing Plants                      8-7
     8.3  Emission Limits                                 8-8

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                    CONTENTS (Continued)




     8.4  Format of Emission Limits                       8-10

     8.6  Process Modifications                           8-11

APPENDICES

  A.   Summary of Test Data                                A-l
  B.   Alternative Emission Level                          B-l
  C.   Florida Air Pollution Rules of the Department       C-l
         of Pollution Control
  D.   The Stack Gas Dispersion Model                      D-l

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                           FIGURES

No.                                                    Page

2-1  Generalized Flow Scheme for Florida Operations    2-6

2-2  Generalized Flow Scheme for Tennessee Phosphate
     Rock
                                                       2-6
2-3  Generalized Flow Scheme for Western Phosphate     2-6
     Rock

2-4  Direct-Fired, Co-Current, Rotary Dryer            2-10

2-5  Fluid-Bed Dryer                                   2-11

2-6  Fluid-Bed Calciner                                2-17

2-7  Typical Grinding Circuit                          2-21

2-8  Roller Mill                                       2-22

2-9  Rotary Ball Mill                                  2-24

2-10 Typical Air Slide Conveyor                        2-29

4-1  Capital Costs for Control Alternatives for Dryers
     and Calciners                                     4-25

4-2  Cost Effectiveness of Control Alternatives for
     Model Dryers                                      4-26

4-3  Cost Effectiveness of Curves for Calciner
     Emission Control Alterantives                     4-34

4-4  Capital Costs for Fabric Filter and Venturi
     Scrubbing Systems Serving Model Grinders          4-40

4-5  Cost Effectiveness Curves for Fabric Filters
     and Venturi Scrubbers Serving Model Grinders      4-43

7-1  State Mass Emission Limitations for New and
     Existing Sources                                  7-3
                              VI

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                           TABLES

No.                                                    Page
2-1  Phosphate Rock Producers and Plant Capacities -
     1977                                              2-2

2-2  Production and Shipments of Phosphate Rock        2-3

2-3  Capacities and Gas Flow Rates for Phosphate Rock
     Dryers                                            2-13

2-4  Characteristics of Exhaust Gas From Fluid-Bed
     and Rotary Dryers                                 2-15

2-5  Capacities and Gas Flow Rates for Phosphate Rock
     Calciners                                         2-18

2-6  Characteristics of Exhaust Gases from Fluid-Bed
     and Rotary Calciners                              2-19

2-7  Characteristics of Exhaust Gases from Phosphate
     Rock Grinders                                     2-26

2-8  Capacities and Gas Flow Rates for Phosphate Rock
     Grinders                                          2-27

3-1  Emissions from Rock Dyers Equipped with Various
     Types of Control Equipment                        3-3

3-2  Performance of Venturi and Cyclonic Wet Scrubbers
     on Phosphate Rock Dryers                          3-7

3-3  ESP Performance on Phosphate Rock Dryer Particu-
     late Emissions (Outlet Data)                      3-9

3-4  Particulate Emissions from Phosphate Rock
     Calciners (S.I. Units)                            3-13

3-4a Particulate Emissions from Phosphate Rock
     Calciners (English Units)                         3-14

3-5  Performance of Venturi Scrubber on Phosphate
     Rock Calciner  (Outlet)                            3-15

3-6  Particulate Emissions from Phosphate Rock
     Grinders (S.I. Units)                             3-19
                             vi i

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                     TABLES (Continued)

No.                                                    Page

3-6a  Particulate Emissions from Phosphate Rock
      Grinders (English Units)                          3-20

3-7   Fabric Filter Performance on Phosphate Rock
      Grinder Emissions                                3-22

4-1   Process/Control Systems Considered for Cost
      Analyses                                         4-2

4-2   Production Capacities of Selected  Model
      Processes                                        4-3

4-3   Information Sources for Purchase Costs of
      Selected Equipment                               4-7

4-4   Direct Cost Components Used in Computing
      Installed Costs                                  4-8

4-5   Indirect Cost Components Used in Computing
      Installed Costs                                  4-9

4-6   Cost Components Used in Computing  Annualized
      Costs                                            4-13

4-7   Characteristics of Phosphate Rock  Dryer Exhaust
      Gases and Emissions (SI units)                    4-14

4-7a  Characteristics of Phosphate Rock  Dryer Exhaust
      Gases and Emissions (English units)               4-15

4-8   Capital and Annual Control Costs for Fabric
      Filters Serving Model Dryers                     4-20

4-9   Capital and Annual Control Costs for Venturi
      Scrubbing Systems Serving Model Dryers           4-21

4-10  Capital and Annual Costs for Electrostatic
      Precipitator Systems Serving Model Dryers        4-22

4-11  Characteristics of Model Calciner  Exhaust Gases
      and Emissions (SI Units)                          4-28

4-lla Characteristics of Model Calciner  Exhaust Gases
      and Emissions (English Units)                     4-29
                             VI 1 1

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                     TABLES (Continued)

No.                                                    Page

4-12  Capital and Annual Costs for Fabric Filter
      Systems Serving Model Calciners                  4-30

4-13  Capital and Annual Costs for Venturi Scrubbing
      Systems Serving Model Calciners                  4-32

4-14  Capital and Annual Costs for Electrostatic
      Precipitators Serving Model Calciners            4-33

4-15  Characteristics of Exhaust Gas and Emissions
      From Model Phosphate Rock Grinders (SI Units)     4-36

4-15a Characteristics of Exhaust Gas and Emissions
      From Model Phosphate Rock Grinders (English
      Units)                                           4-37

4-16  Capital and Annual Costs for Fabric Filter
      Systems Serving Model Grinders                   4-39

4-17  Control Costs for Venturi Scrubber Systems
      Serving Model Grinders                           4-42

4-18  Purchase Costs of Wet and Dry Grinding Systems   4-45

4-19  Annual Savings and Operating Costs for Wet
      Grinding Systems                                 4-47

5-1   Results of Dispersion Modeling to Determine
      Ambient Impact of Dryer Emissions (S.I. Units)   5-3

5-2   Results of Dispersion Modeling to Determine
      Ambient Impact of Calciner Emissions (S.I
      Units)                                           5-4

5-3   Results of Dispersion Modeling to Determine
      Ambient Impact of Grinder Emissions (S.I. Units) 5-5

5-4   Estimated Air Impacts of Uncontrolled Processes  5-6

5-5   Chemical Analysis of Phosphate Rock Produced
      and Dust Emissions from Calciner Cyclones        5-10

5-6   Predicted Effluent Quality from Wet Scrubbers
      on Calciners and Grinders                        5-11
                               IX

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                     TABLES (Continued)
No.                                                       Page
5-7    Summary of Solid Waste Impact for Two Worst-Case   5-13
      Model  Plants
5-8    Solid  Wastes  Generated by Dryer Emission Controls  5-15
5-9    Solid  Wastes  Generated by Calciner Emission        5-16
      Controls
5-10  Solid  Wastes  Generated by Grinder Emission         5-17
      Controls
5-11  Energy Consumption  for Phosphate Rock Processed    5-19
      and Associated Control Devices
5-12  Energy Impact of Applying Emission Control         5-20
      Technology
7-1    Opacity Regulations for Various Jurisdiction       7-4
8-1    Summary of Impacts  of Applying  Control  Technology  8-2

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                       ACKNOWLEDGEMENT





     This report was prepared for the Environmental Protec-



tion Agency by PEDCo Environmental, Inc., Cincinnati, Ohio.



Mr. Richard W. Gerstle was the PEDCo Project Manager.



Principal investigator and author of the report was Mr.



David M. Augenstein.



     Mr. Lee L. Beck was the Project Officer for the Environ-



mental Protection Agency.

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                                1.0   INTRODUCTION
     This document  contains  information  on the  control  of  particulate  emissions
from phosphate  rock processing  plants.   Both typical  and best  demonstrated
control techniques  are  discussed,  and the cost  and  environmental  impacts  of
several levels  of emission control  are  presented  for  phosphate rock  dryers,
calciners,  grinders,  and  ground  rock handling systems.   In  addition  to
presenting  data on  emissions  and their  control, regulatory  options and enforce-
ment aspects  of potential regulations for air emissions  are discussed.
1.1  NEED TO  REGULATE PHOSPHATE  ROCK PROCESSING PLANTS
     The United States  is the largest producer  and  consumer of phosphate  rock
in the world, producing an estimated 40  percent and consuming  approximately 35
percent of  the  world's  supply.   In  1977, the United States  produced  over  46 Tg
(51 million tons) of  phosphate  rock.  About 70  percent  of  domestic consumption
of phosphate  rock is  as fertilizer.  The other  major  uses  are  in  animal feeds,
detergents, electroplating and  polishing of metals, insecticides,  and
medicines.
     Demand for phosphate rock  in  the years 1985  and  2000,  respectively,  is
projected to  be 40.5  and 62.1 Tg (45 and 69 million tons)  for  the  United  States
and 146 and 348 Tg  (162 and 387 million  tons) for the rest  of  the  world.
     The phosphate  rock processing  industry presents  a  significant potential
contribution  to air pollution for  two reasons.  First,  of  course,  is the  large
volume of material  handled.   Any step in which  the  phosphate rock  is handled in
                                      1-1

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the dry state presents a potential for emission of participate matter.   In
addition, many of the processes employed in preparation of the rock; drying,
calcining, grinding, and pneumatic materials transfer, use large volumes of air
which, at the process exhaust, contain suspended particulates.  The environ-
mental effects of particulate emissions have been investigated by the
Environmental Protection Agency (EPA) and have been determined to pose  a
significant threat to public health and welfare.
1.2  SOURCES AND CONTROL OF EMISSIONS
     Operations which are discussed in this document are drying, calcining,
ground rock transfer systems, and grinding.  The bases for selection of these
processing steps are:  (1) significant potential for emissions, and (2)  avail-
ability of technology to insure significant reduction of emissions.  Each
operation is discussed separately.
     Drying is chosen for study as a major emissions source largely because of
the importance of this operation  in preparing Florida rock for fertilizer
manufacture.  About 96 percent of the rock produced in Florida is dried.
Dryers are also used to some extent in the other processing areas, usually for
processing rock destined for shipping or manufacture of fertilizers.  Since the
future growth of fertilizer industries (estimated at four percent per year) is
dependent on supplies of phosphate rock, it is likely that demand for addi-
tional dryers will parallel demand for additional fertilizer.  Drying presents
a potential for emission of particulate matter because of attrition of  the rock
in the dryer and the large volume of air which sweeps through the dryer and
must be vented to the atmosphere.  The magnitude of the potential for emissions
can be estimated by considering a typical rock dryer, processing 225 Megagrams
(250 tons) of rock per hour, discharging 40.8 dry standard cubic meters of
                                      1-2

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exhaust  gases  per  second  (85,000 dry  standard  cubic  feet  per minute).   The
average  loading  of particulate matter in  the air  stream  is  about  7  grams per
standard  cubic meter  (3 grains per  standard cubic  foot).  The potential  annual
emission  for such  a dryer is  7,762  Mg (8,625 tons) per year of particulate
matter,  assuming 90 percent operating factor and  no  control  of emissions.   As
detailed  in Chapter 3, technology is  available to  ensure  significant  reduction
in these  emissions.
     The  potential  growth of  calcining  operations  is  also substantial,  since
any  new  fertilizer installation processing North  Carolina or Western  phosphate
rock will  require  a calciner.  Processing of rock  from these two  reserves  is
likely to expand since the reserves in  both locations are extensive and  are not
developed to their potential.  As a source of  emission of particulate matter,  a
typical  calciner processes 54 Mg  (60  tons) of  rock per hour exhausting  19.2 dry
standard  cubic meters per second  (40,000  dscfm) of gases with a particulate
loading  of 7 to  11 grams  per  dry  standard cubic meter (3 to 5 grains  per dry
standard  cubic foot). The potential  annual emissions rate  for such a calciner
is over 3,600 Mg (4,000 tons) per year, assuming  a 90 percent operating  factor
and no emission  control.   Technology  is available to  permit significant
reduction in the uncontrolled emissions rate.
     Projected growth of  grinding operations can  also be expected to  parallel
the growth of fertilizer  production.  The potential  for contribution  to  air
pollution is substantial;  a typical milling installation grinds 45  Mg  (50  tons)
                                                o
of rock per hour,  exhausting  2.16 dry standard rir/s  (4,500  dscfm) of  gases with
a particulate loading of  7 grams per  dry  standard  cubic meter (3  grains  per dry
standard  cubic foot)  before emission  control.   The annual emissions potential
for such  a unit is  about  414 Mg (460  tons) per year,  assuming 90  percent
                                      1-3

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operating factor and no attempt at emission control.  Technology  is  available
for significant reduction of this potential emission.
     Ground phosphate rock is usually transferred  pneumatically,  with  the
exhaust of the transfer system controlled by a fabric filter.   Though  the  mass
emissions rate from ground rock transfer systems has not  been  sampled,  visible
emission measurements have shown that these systems can be  operated  without  a
visible exhaust, thus preventing significant emissions from this  potential
source.
                                      1-4

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          2.0 SOURCES AND TYPES OF EMISSIONS

2.1   GENERAL
     The phosphate rock industry consists of mining and rock
processing operations centered close to ore reserves.
     Phosphate rock mines of significant commercial impor-
tance are located in Florida, North Carolina, Tennessee,
Idaho, Wyoming, Utah, and Montana.'  Table 2-1  lists pro-
ducers of phosphate rock and their respective capacities.
In 1975, 21 producers were spread over 36 locations and
employed a total of about 12,000 people.3'4  Table 2-2
presents the total domestic production and shipments for
years from 1965 to 1977.  Future production is expected
to grow at an annual rate of about four percent.
     Nearly three-quarters of the domestic production capa-
city is located in Florida.  In 1976, Florida and North
Carolina produced some 37.5 Tg (41.3 million tons), account-
ing for more than 84 percent of the total domestic produc-
tion.
     Phosphate rock is used primarily to produce phosphatic
fertilizers.  About 20 percent of the rock is converted  to
other products, such as elemental phosphorus and defluori-
nated animal-feed supplements.  Thirty percent is exported.7
                             2-1

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Table 2-1.  PHOSPHATE ROCK  PRODUCERS AND




        PLANT CAPACITIES -  19772
Company
Agrico Chemical Co.
Beker Industries
Borden Chemicals
Brewster Phosphates
Cominco- American
Cuyama Phosphate
Gardinier, Inc.
W. R. Grace
Hooker Chemical Co.
International Minerals and
Chemicals
Mobil Chemical Co.
Monsanto Industrial Chem-
ical Co.
Occidental Chemical Co.
Poseidon Mines
Presnell Phosphate
George Relyea Co.
J. R. Simplot Co.
Stauffer Chemical Co.
Swift Chemical Co.
T-A Minerals Corp.
Texasgulf, Inc.
U.S.S. Agri-Chem
TOTAL
Location
Fort Green, Fla
Pierce, Fla
Dry Valley, Idaho
Tenor oc, Fla.
Brewster, Fla.
Garrison, Mont.
New Cuyama , Calif.
Ft. Meade, Fla.
Bonny Lake, Fla.
Hooker's Prairie, Fla.
Columbia, Tenn.
Bonnie, Fla.
Kingsford, Fla.
Nichols, Fla.
Ft. Meade, Fla.
Ballard, Idaho
Columbia, Tenn.
White Springs, Fla.
Lakeland, Fla.
Columbia, Tenn.
Garrison, Montana
Conda, Idaho
Ft. Hall, Idaho
Cherokee, Utah
Vernal, Utah
Mt. Pleasant, Tenn.
Bartow, Fla.
Rock City, Fla.
Lee Creek, N.C.
Ft. Meade, Fla

Capacity,
Tg/yr (103 tpy)
3.17
5.44
0.91
0.91
5.71
0.25
0.45
1.81
2.27
2.54
0.45
2.72
8.62
1.36
2.90
0.91
0.91
4.54
0.54'
0.45
0.09
0.41
1.81
0.73
0.54
0 .54
2.72
0.45
4.54
1.81
60.52
(3,500)
(6,000)
(1,000)
(1,000)
(6,300)
(275)
(500)
(2,000)
(2,500)
(2,800)
(500)
(3,000)
(9,500)
(1,500)
(3,200)
(1,000)
(1,000)
(5,000)
(600)
(500)
(100)
(450).
(2,000)
(800)
(600)
(600)
(3,000)
(500)
(5,000)
(2,000)
(66,725)
                     2-2

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   Table 2-2.  PRODUCTION AND SHIPMENTS OF PHOSPHATE ROCK
Year
1965
1966
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976a
1977a
Production
Tg
26.74
35.41
36.01
37.41
34.22
35.14
35.26
37.03
38.22
41.44
44.28
44.13
46.50
(10J tons)
(29,482)
(39,044)
(39,700)
(41,251)
(37,725)
(38,739)
(38,886)
(40,831)
(42,137)
(45,686)
(48,816)
(48,659)
(51,266)
Shipments
Tg
26.34
33.05
34.32
33.84
33.31
35.16
36.54
39.69
40.85
43.93
43.93
39.21
46.60
(10J tons)
(29,039)
(36,443)
(37,835)
(37,319)
(36,730)
(38,765)
(40,291)
(43,755)
(45,043)
(48,435)
(48,439)
(43,230)
(51,383)
a Information on 1976 and 1977 production and shipments was
  obtained from Mr. Ed Harre, Tennessee Valley Authority,
  National Fertilizer Development, Muscle Shoals, Alabama.
  April 17, 1978.
                               2-3

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     The ingredient of the rock that is of economic interest


is tricalcium phosphate lCa_(PO.)_], also known in the


industry as bone phosphate of lime  (BPL) because the first


commercial source of this chemical was charred animal


bones.  The rock is usually graded on the basis of its BPL


content, e.g., 68 BPL rock contains 68 percent by weight of


tricalcium phosphate.  The final product contains roughly 68

                  g
to 74 percent BPL.


     Chemically, phosphate rock may be considered to contain


a substituted fluorapatite.  The basic fluorapatite struc-

                                       g
ture is represented as 3Ca_(PO.)2«Ca_F.   Nearly all phos-


phate ores contain a modified form of this structure in


which some of the phosphate is replaced by fluoride and


carbonate.    The total fluoride content of typical phos-


phate rock is approximately 4 to 5 percent by weight, ex-


pressed as fluorine.


     Commercial phosphate rock contains 30 to 38 percent


P2°5 Plus a variety of impurities such as iron, aluminum,


magnesium, silica, carbon dioxide, sodium, potassium, and


sulfates.


     The hardness and organic content of phosphate rock


determine the way it is mined and processed.  Generalized


flow diagrams for mining and processing operations in


Florida, Tennessee, and the Western States are presented in
                                2-4

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Figures 2-1, 2-2, and 2-3, respectively.  Only those phos-



phate rock operations associated with the manufacture of



fertilizer were investigated for development of the control



techniques document.  Drying, calcining, and grinding are



the major emission sources for which control techniques were



studied.  Materials handling and storage and wet grinding



are also discussed.



2.2  MINING AND BENEFICIATION



     Hard rock is found in the western states.  Its hardness



generally decreases the further north the ore is located.



Conventional earth moving equipment is used to remove the



first 1.5 to 15 meters  (5 to 50 feet)  of earth (overburden)



to expose the layer of phosphate rock.  Hard rock found in



Utah is removed by blasting with dynamite.  Softer rock is



removed by a "ripper", a toothed implement that gouges and



breaks the rock from the surface.  In Montana, two small



underground mines are also operated for removal of phosphate



rock.



     Western rock is usually hauled to the rock processing



plant by truck.  The first processing step separates the



rock from impurities; this process is called beneficiation.



The sequence of steps in the beneficiation process at



plants mining western hard-rock ores differs from plant to



plant depending on the hardness of the ore and the end use
                               2-5

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                                        TO CMTftOl taWMNUT
                                                           TO MftTlllZtM
                                                           MANUMCTUftlNK
   Figure 2-1.  Generalized flow scheme for  Florida  phosphate rock.
                                                  TO CONTROL IOUMMT
                                           I     _t
OPEN
FIT
MINIM

	 -\
<

o)

^

:>)-



— MOT
BENEFICIATIOK


NOOULIZINB
TO ELEMENTAL
— *• PNOSTHORH
FURNACI
                                                  FUll    AIR
Figure  2-2.  Generalized  flow scheme for Tennessee  phosphate  rock,
CALCININC


...«


TRANSFER
                                                             TO FERTILISER
                                                             MANUFACTURE
                                                    TO ELEMENTAL
                                                    - r*ammat
                                                     FURNACI
  Figure 2-3.   Generalized flow  scheme for  Western  phosphate rock,
                                     2-6

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of the rock.  Crushing is employed at some western mines;



however, in the United States as a whole, it is only used on



only 12 percent of the rock mined.  In the beneficiation



plant, primary crushers first reduce the ore to less than



0.6 centimeter (1/4 inch).   (This practice is particularly



common in the southern sector of the West.)  Further size



reduction is accomplished in several steps, the last of



which is a slurry-grinding process that uses a wet rod mill



to reduce the ore to particles about the size of beach sand.



The slurry is then size-classified in hydrocyclones in which



centrifugal force is used to separate product-size material



from the tailings (clay and sand particles smaller than



about 100-mesh).  The ore is then filtered from the slurry



and conveyed to the next processing step.  The tailings are



discarded.



     The deposits in Tennessee consist of small pockets of



brownish phosphate sands surrounded by brown silica sand.



Draglines and small power shovels are used to mine the



phosphate sand, which is then hauled by truck or rail to the



processing plants.  A typical Tennessee beneficiation pro-



cess consists of a unit called a "log-washer.-" in which the



ore is slurried with water to break up any large agglomer-



ated masses, then sent to a hydrocloning unit for size



classification.  The product-size fraction then goes to
                                2-7

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nodulizing kilns, where it is prepared for feeding to elec-



tric arc furnaces to produce elemental phosphorus.



     The Florida and North Carolina deposits consist of a



consolidated mass of phosphate pebbles and clays known as



matrix, which is deposited in a discrete layer of consider-



able extent.  Mining is conducted by stripping overburden



from the matrix deposits and removing the matrix layer by



use of electrically driven draglines.  After extraction, the



ore is normally transported by conveyor belt to washing and



beneficiating operations.



     No air pollutants are generated during either the



mining or beneficiation processes except at a few plants



that mine the hard, dry rock in the southern part of the



western reserves.  Because of the dry climate in that area,



rock mining and hauling produce dust similar to that gen-



erated in rock quarrying operations.  The ground moisture



content is sufficient in most phosphate rock mining opera-



tions to prevent emissions, and because beneficiation is



always conducted in a water slurry, it does not produce air



emissions.




     After it leaves the beneficiation plant, ore must be



dried, calcined, or nodulized before it can be further



processed.  The process used depends on the organic content



of the ore and the ultimate product for which it is des-
                              2-8

-------
tined.  Since Florida rock is relatively free of organics,



it is dried by simply heating it to about 394°K (250PF) to



drive off free water.  Rock from other reserves in the



nation, however, contains organics, and must be calcined by



heating to 1000° to 1150°K (1400° to 1600°F).  If the



organics are not removed, they cause a slime that hinders



filtration during the manufacture of wet-process phosphoric



acid, which is the starting material for phosphate fertil-



izer.  When the nodulizing process is required, the ore is



heated to 1500° to 1700°K (2200° to 2600°F).  This process



not only drives off water, carbon dioxide, and organic



matter, but also causes the ore to fuse into larger lumps



suitable for feeding to the electric arc furnace used in the



manufacture of elemental phosphorus.  Only Tennessee ore and



some western ores are nodulized.



2.3  DRYING



     Phosphate ores are dried in direct-fired dryers, i.e.,



the combustion products are placed in direct contact with



the ore.  Most dryers are fired with natural gas, No. 2 oil,



or No. 6 fuel oil; many are equipped to burn more than one



type of fuel.  Throughout the late 1960's and early 1970's



the trend was toward fuel oil, usually No. 6.  Although both



rotary and fluidized-bed units are employed, the rotary is



more common.  Figures 2-4 and 2-5 are typical schematics of
                                2-9

-------
         COMBUSTION FURNACE
           BURNER,
                                   /FEED CHUTE
I
(—'
o
                                                                                                DISCHARGE
                                                                                                OUTLET
                              Figure  2-4.   Direct-fired,  co-current,  rotary  dryer.

-------
to
i
                  I
TO SECONDARY CONTROL DEVICE
           COARSE PRODUCT
                                                        WET PHOSPHATE

                                                            ROCK
                                                                                               AIR
                                             Figure 2-5.   Fluid-bed  dryer.

-------
the two types of dryers.  The ore is discharged when the



moisture content reaches 1 to 3 percent, the percentage



determined by the ultimate use of the ore.  As shown in



Table 2-3, capacities of dryers range from 4.5 to 320 Mg/h



(5 to 350 tons/h), with 180 Mg/h (200 tons/h) a representa-



tive average.  The newer installations tend to be larger



units.  Conservative operators minimize air usage to de-



crease fuel consumption and reduce the size and cost of air



pollution control devices.  Characteristics of emissions and



exhausts from dryers are presented in Table 2-4.



     Process variables that affect emissions from a phos-



phate rock dryer include the type of rock being processed  (a



factor at Florida plants only), fuel type, air flow rate,



product moisture content, and in the case of a rotary dryer,



speed of rotation.  A unique situation regarding rock types



in the Florida industry deserves some comment.  The pebble



rock described earlier receives much less washing than does



the concentrate rock from the flotation processes and



therefore has a higher clay content.  Uncontrolled emissions



from drying pebble rock are substantially higher than those


                                                     14
resulting from drying ore from the flotation process.



This difference is recognized by the Florida Department of



Pollution Control,   and variances have been granted to some



operators when drying pebble rock and using scrubbers as the
                                2-12

-------
               Table 2-3.   CAPACITIES AND GAS FLOW RATES FOR PHOSPHATE ROCK DRYERS
                                                                                  13
to

M
U»
Company
Agrico Chemical
Beker Industries
Bo r den Chemical
Brewster Phosphates
Conserv, Inc.
Freeport Chemicals
Gardinier, Inc.
W. R. Grace S Co.
Hooker Chemical
IMC Corporation
IMC Corporation
Mobil Chemical
Occidental Chemical
Location
Pierce, Fla.
Conda, Idaho
Plant City, Fla.
Bradley, Fla.
Nichols, Fla.
Uncle Sam, La.
Ft. Meade, Fla.
Bartow, Fla.
Columbia, Tenn.
Noralyn, Fla.
Kingsford, Fla.
Nichols, Fla.
White Springs, Fla.
Product
rate,
Mg/h (tons/h)
907
57
136
286
100
181
181
178
300
150
19
500
300
317
317
220
(1,000)
(63)
(150)
(315)a
(110)
(200)
(200)
(196)
(330)
(165)
(21)
(550)a
(333)
(350)
(350)
(242)
Type of
facility
NR
Fluid-bed
Rotary
NR
NR
Fluid-bed
Fluid-bed
NR
Rotary
Fluid-bed
Rotary
NR
NR
Fluid-bed
Rotary
Rotary
Fluid-bed
Stack
flow
std. m3/
378
12.7
24.5
68.4
12.7
NR
NR
36.3
61.4
8.5
73
33
37
37
44
gas
rate,
s (103 scfm)
(800)
(27)
(52)
(145)3
(27)
NR
NR
(77)
(130)3
(18)
(155)3
(70)
(78)
(78)
(93)
               (Continued)

-------
          Table 2-3  (continued).   CAPACITIES AND GAS FLOW RATES FOR PHOSPHATE ROCK DRYERS
                                                                                                        13
NJ
I
Company
Rocky Mtn. Phosphates
J. R. Simplot
Stauffer Chemical
Stauffer Chemical
Swift Chemical
Texasgulf, Inc.
U.S.S. Agri-Chem
Location
Garrison, Montana
Conda, Idaho
Leefe, Wyoming
Vernal, Utah
Bartow, Fla.
Aurora, N.C.
Ft. Meade, Fla.
Product
rate,
Mg/h (tons/h)
4.5 (5)
136 (150)
50 (55)
24 (26)
24 (26)
161 (178)
240 (265)
211 (233)
170 (187)
Type of
facility
Rotary0
d
Rotary.
Rotary
Rotary
Rotary
Rotary
Fluid-bed
Fluid-bed
Rotary
Stack gas
flow rate,
std. m3/s (103 scfm)
NR
10.4
7.0
4.7
4.7
26.4
35.9
NR
NR
NR
(22)
(15)
(10)
(10)
(56)
(76)
NR
NR
                   Total for two dryers.
                   This dryer operates at 477°K (400°F)  (exit gas temperature).
                 0 This dryer operates at 394 to 422°K (250°-300°F)  (exit gas temperature).
                   This dryer operates at 422°K (300°F)  exit gas temperature.
                 NR - not reported.

-------
Table 2-4.  CHARACTERISTICS OF EXHAUST GAS FROM




          FLUID-BED AND ROTARY DRYERS
Exhaust flow rate
Temperature
Moisture
Uncontrolled mass
emissions
Grain loading
Particle size distribu-
tion16




0.13 - 0.23 wet
std. m^ • s^-^/Mg *h
394 - 422°K
8-30% v
2-9 g/kg product

. 7-11 g/dry
std. m3





250-450 sdrm/tons/h
product
250-300°F
8-30% v
4-18 Ib/ton pro-
duct
3-5 gr/dscf
98% < 10 ym
92.9% < 5 ym
73.8% < 2 ym
39.9% < 1 ym
7.2% < 0.5 ym
                          2-15

-------
control device.  Emission control techniques are discussed



in more detail in Chapter 3.



2.4  CALCINING



     The most common type of calciner is the fluidized-bed



unit (illustrated in Figure 2-6); rotary calciners are also



used.  Calciners operate at much higher temperatures than



dryers and they require refractory linings.  Also, as shown



in Figure 2-5, the fluidized-bed dryer has an external



combustion chamber from which the flue gases pass through



the dryer, whereas the calciner  (Figure 2-6) employs com-



bustion within the bed of phosphate rock to achieve the



higher temperatures.  Calciners range in capacity from 18 to



63.5 Mg/h (20 to 70 tons/h); a representative average is



about 45 Mg/h  (50 tons/h).   As noted for the dryers, the




newer calciner installations also tend to be of larger



capacity.  Table 2-5 summarizes the production rate and the



volumetric flow rate for fluid-bed and rotary calciners.



Table 2-6 presents the characteristics of exhaust gases from



calciners.



2.5  GRINDING



     Grinding is widely employed in the processing of



phosphate rock.  After drying or calcining, these fine



pulverizing mills produce a product of talcum powder con-



sistency-  These pulverizing mills or grinders (either
                                2-16

-------
 FEED
FUEL
              PREHEAT
            COMPARTMENT
              CALCINING
            COMPARTMENT
C              COOLING
             OMPARTMENT
     LOWER
    WIND BOX
                                                                              BLOWERS
                               Figure 2-6.  Fluid-bed  calciner.

-------
                         Table 2-5.  CAPACITIES AND  GAS FLOW RATES FOR


                                PHOSPHATE ROCK CALCINERS (1975)13
Company
Beker Industries
Mobil Chemical
J. R. Simplot
Stauffer Chemical
Texasgulf, Inc.
Location
Conda, Idaho
Nichols, Fla.
Pocatello, Idaho
Leefe, Wyoming
Aurora, N.C.
Production
rate,
Mg/h (tons/h)
63.5 (70)
63.5 (70)
45 (50)
32 (35)
37 (41)
50 (55)
18 (20)
18 (20)
27 (30)
54.4 (60)
54.4 (60)
54.4 (60)
54.4 (60)
Type of
calciner
Fluid-bed
Fluid-bed
Rotary
Fluid-bed
Fluid-bed
Fluid-bed
Fluid-bed
Fluid-bed
Fluid-bed
Fluid-bed
Fluid-bed
Fluid-bed
Fluid-bed
Stack
flow
std. m-Vs
16.3
18.9
26.0
11.8
13.2
27.4
8.0
8.0
13.7
25.0
25.0
25.0
25.0
gas
rate,
(105 scfm)
(34)
(40)
(55)
(25)
(28)
(58)
(17)
(17)
(29)
(53)
(53)
(53)
(53)
I
h-1
CD

-------
 Table 2-6.  CHARACTERISTICS OF EXHAUST GASES FROM FLUID-BED

                    AND ROTARY CALCINERS
Exhaust flow rate
0.26 - 0.52 wet
std. m *s~
                                         -1
                     500-1000 scfm/
                    tons/h product
Temperature

Moisture content

Uncontrolled mass
 emissions

Grain loading
Particle size distribu-
 tion17
394°K

6-25% v

3-20 kg/Mg
5-11 g/dry
std. m3
                     250°F

                     6-25% v

                     6-40 Ib/ton
                     product

                     2-5 gr/dscf


                    95.9% < 10 vim

                    81.2% <  5 ym
                    52.3% <  2 ym
                    26.2% <  1 ym
                     5.2% < 0.5 ym
Composition of emission
from cyclone collec-
tors!7

     Calcium (CaO)

     Phosphorous  (P2°

     Silica (Si02)

     Aluminum (A120_)

     Iron (Fe203)

     Magnesium (MgO)

     Other
                    18.3

                    14.4

                    35.5

                     8.4

                     2.3

                     0.1

                    21.
                         % by weight
  The rock is calcined at 760°to 870°C  (1400° to 1600°F) but
  the exhaust gas is cooled in the upper windbox and preheat
  compartments of the calciner before discharge.
                                2-19

-------
roller or ball mills1 are used by all manufacturers to



produce fertilizer.



     Roller mills and ball mills reduce the phosphate rock



to a fine powder—typically specified as 60 percent by



weight passing a 200-mesh sieve.  Roller and ball mills are



about equally favored in the industry.  A typical grinding



circuit is illustrated in Figure 2-7.



     The roller mill is composed of hardened steel rollers



that rotate against the inside of a steel ring, as shown in



Figure 2-8.  Ore is fed into the mill housing by a rotary



valve that prevents the escape of air into the feed system.



The rock is scooped up from the floor of the housing by



plows and directed into the path of the rollers, where it is



ground between the rollers and the steel ring.  Ground rock



is swept from the mill by a circulating airstream.  Some



product size classification is provided by the "revolving



whizzers" at the top of the housing.  The average particle



size leaving the mill can be controlled by varying the speed



of revolution of the whizzers.  Further size segregation is



provided by the air classifier, which separates oversize



particles from product-size particles and recycles the



oversize portion to the mill.  The product is separated from



the carrying air stream by a cyclone and conveyed to ground-



rock storage.  The air stream is returned to the mill in a
                               2-2 0

-------
to
I
to
OVER-
 SIZE
                                                                               DUST
                                                                             COLLECTOR
                                                                             (BAGHOUSE)
                                                                          WWWVW]
                                                                                  TO
                                                                               PRODUCT
                                                                                 BIN
                                   Figure  2-7.   Typical grinding circuit.

-------
          A Product outlet
                           -Revolving
                             whizzers
                             - Whizzer
                               drive
                         Grinding ring
                         'Grinding roller

                                »

                                -Feeder
Figure 2-8.   Roller mill,
            2-22

-------
closed loop, although there is a bleed stream from the



system, as described below-



     The ball mill is basically a drum revolving about an



axis slightly inclined to the horizontal (Figure 2-9).  The



drum contains a large number of steel balls about 2.5 cm (1



in.) in diameter.  Rock is charged into the mill through a



rotary valve, ground by attrition with the balls, and swept



from the mill by a circulating air stream, as described



above for roller mills.



     Roller and ball mills are operated slightly below



atmospheric pressure to avoid the discharge of fugitive rock



dust into the air.  As a result, atmospheric air infiltrates



the circulating streams.  This tramp air is discharged from



the circuit, through a dust collector, to the atmosphere.



Mill capacities range from 13.6 Mg/h  (15 tons/h) of phos-



phate rock for a smaller roller mill to about 236 Mg/h (260



tons/h) for a large ball mill.  A typical mill has a capac-



ity of 45 Mg/h (50 tons/h).  Because roller mills are



usually limited to about 68 Mg/h (75 tons/h) per unit many



operators install several in parallel rather than a single



large ball mill.   No clear trend toward either method of



grinding is evident.  The volume of the tramp air discharge



stream is more dependent upon the design and construction of



the grinding circuit than on the capacity of the mill.  For
                                2-23

-------
              PRODUCT  OUT
NJ
I
                                                                                        ROCK IH
                                        Figure 2-9.   Rotary ball  mill,

-------
example, it would not be unusual for a 136 Mg/h (150 tons/



h) mill to discharge 8.97 dry Std. m /s  C19,000 dscfm),



whereas a 227 Mg/h  (250 tons/h) unit might discharge 4.72



dry std. m /s  (10,000 dscfm}.  Table 2-7 shows the char-



acteristics of the exhaust gases from grinding operations.



Table 2-8 summarizes the production rate and volumetric flow



rate for several types of mills.



2.6  MATERIALS HANDLING AND STORAGE



     Provision is usually made to convey and/or store the



rock between each of the operations described.  The mate-



rials handling and storage operations employed by the phos-



phate rock industry range from truck hauling and open



storage to sophisticated pneumatic transfer systems and



silos.  Normal methods of conveying ore from the mines to



beneficiation plants have been mentioned earlier in this



report.  The handling and storage procedures commonly em-



ployed at other steps in the various processes will now be



discussed.



     Beneficiated rock is commonly stored wet in open piles.



Several methods are used to reclaim the material from the



piles, such as skip loaders, underground conveyor belts, and



above-ground reclaim trolleys.  The reclaimed ore is normal-



ly conveyed to the next processing step  (drying, calcining,



or nodulizing) by either open or weather-protected conveyor



belts.
                                2-25

-------
Table 2-7.   CHARACTERISTICS OF EXHAUST GASES FROM




             PHOSPHATE ROCK GRINDERS
Exhaust flow rate
Temperature
Moisture
Uncontrolled mass
emissions
Grain loading
31-83 wet _1
std. m3's~1/kg-h
310-339°K
Up to 9% v
<3.5 kg/Mg
7-11 g/dry
std. m3
17
Dust composition
Calcium (CaO)
Phosphorous (P-O-)
Silica (Si02)
Aluminum (Al-O.,)
Iron (Fe203)
Magnesium (MgO)
Other
60-160 scfm/
tons/h product
100-150°F
Up to 9% v
<7.0 Ib/ton
product
3-5 gr/dscf

45.5 % by weight
32.5
11.0
2.0
0.8
0.7
7.5
                       2-26

-------
            Table 2.8  CAPACITIES AND GAS  FLOW RATES  FOR PHOSPHATE ROCK GRINDERS (1975)
                                                                                              13
10
I
ro
-j
Company
Agrico Chemical
Beker Industries
Brewster Phosphates
Farmland Industries
Freeport Chemicals
Gardinier, Inc.
H. R. Grace and Co.
IMC Corporation
IMC Corporation
Mobil Chemical
Occidental Chemical
Royster Company
J. R. Simplot
Stauffer Chemical
Swift Chemical
Texasgulf, Inc.
U.S.S. Agri-Chem
U.S.S. Agri-Chem
Location
Pierce, Florida
Conda , Idaho
Bradley, Florida
Bartow, Florida
Uncle Sam, La.
Tampa, Florida
Bartow, Florida
Noralyn, Florida
Kingsford, Florida
Nichols, Florida
White Springs, Fla.
Mulberry, Florida
Pocatello, Idaho
Leefe, Wyoming
Bartow, Florida
Aurora , N . C .
Bartow, Florida
Ft. Meade, Florida
Production
rate, Number
Mg/h (tons/hH of mills
157 (173)
54.5 (60)
68 (75)
NR
100 (110)
363 (400)
213 (235)
40 (45)
141 (155)
218 (240)
100 (110)
190 (209)
112.5 (124)
59 (65)
91 (100)
36 (40)
40 (45)
136 (150)
40 (45)
68 (75)
6
1
2
2
1
2
1
5
3
2
7
3
4
1
2
6
3
3
2
3
4
Type of mill
Roller
Ball
Ball
Roller
Ball
Ball
Roller
Roller & ball
Roller
Ball
Roller & ball
Roller
Roller
Ball
Roller & bowl
Roller
Roller
Roller
Ball
Roller
Roller
Stack gas
, flow rate,
m /s (1C3 scftn)
9.63 (20.4)
1..8 (3.8)
3.4 (7.1)
6.8 (14.4)
NR
4.5 (9.6)
15.3 (32.3)
7.7 (16.3)
5.8 (12.2)
18.9 (40.0)
9.9 (21.0)
3.8 (8.0)
6.4 (13.6)
3.0 (6.3)
16.1 (34.0)
NR
2.8 (6.0)
11.3 (24.0)
4.3 (9.1)
4.6 (9.8)
              Total for all mills.

            NR = Not reported.

-------
     Rock discharged from the rock dryers or calciners is



usually conveyed to storage silos on weather-protected



conveyors.  From the silos, the rock is either transported



to the consumers in rail cars and trucks or is conveyed to



grinding mills, which prepare the rock for feed to ferti-




lizer plants.



     Ground rock is usually conveyed in some type of totally



enclosed screw conveyor, in a dust pump system, or in an air



slide system.  The screw conveyor consists of a long screw,



driven at one end and enclosed in a tube or covered trough.



Ground rock fed into one end of the tube is carried along



the flights of the screw and discharged at the opposite end.



The dust pump system employs an aerated bin to generate a



continuous stream of fluidized rock.  The rock dust is then



blown from the ground-rock surge bin to the receiving units



through pipelines.  Provision must be made to vent the



conveying airstream at the discharge end.  Potential emis-



sions from typical materials-handling and storage systems



are estimated at 1.0 kg/Mg (2 lb/ton) of rock handled.14



The air slide system, illustrated in Figure 2-10, is com-



posed of a rectangular duct that is separated into upper and



lower segments by porous tile.  The duct is inclined down-



ward from the feed end to the discharge.  Rock dust is fed



into the upper segment of the duct and low-pressure air is
                                2-28

-------
to
                            TO TREATMENT
                                                                          FLOWING STREAM
                                                                           OF ROCK DUST
                                                                       LOW PRESSURE AIR-
                                    Figure 2-10.   Typical  air slide  conveyor.

-------
blown into the lower segment.  The air diffuses -upward



through the porous tile into the rock dust, thereby as-



sisting the gravity flow of the rock down the incline to the



discharge end.  Provision must be made to inject air at



intervals throughout the length of a long conveyor and to



purge the excess air from the upper segment.
                              2-30

-------
                  REFERENCES FOR CHAPTER 2
 1.  Stanford Research Institute.  1975 Directory of Chemi-
     cal Producers.  Menlo Park, California.  1975.

 2.  Fertilizer Trends, 1976.  Bulletin Y-lll.  National
     Fertilizer Development Center, Tennessee Valley Author-
     ity.  Muscle Shoals, Alabama.  March 1977.  p. 40.

 3.  Blue, T.A., and T.F. Torries.  Phosphate Rock.  Chemi-
     cal Economics Handbook.  Menlo Park, California.
     Stanford Research Institute.  December 1975.  pp.
     760.OOOOA-760.0010.

 4.  a) Florida Phosphate Council.  Economic Fact Sheet -
     1973. b) E/MJ International Directory of Mining and
     Mineral Processing Operations:  Engineering and Mining
     Journal.  1973-74 Edition.  McGraw Hill.  New York.

 5.  Wiley, J.H.  The Outlook for Phosphate Fertilizers.
     TVA Fertilizer Conference.  Kansas City, Missouri.
     July 26-27, 1977-

 6.  Op. cit.  Reference 2.  p. 15.

 7.  Stowasser, W.F.  Phosphate Rock.  United States Depart-
     ment of the Interior, Bureau of Mines.  Preprint from
     Bulletin 667.  1975.

 8.  Trace Pollutant Emissions from the Processing of Non-
     metallic Ores.  PEDCo Environmental, Inc.  U.S. En-
     vironmental Protection Agency Contract No. 68-02-1321,
     Task No. 4.  p. 6-1.

 9.  Stevenson, R.M.  Introduction to the Chemical Process
     Industries.  Reinhold Publishing Corporation.  New
     York.  1966.  p.  157.

10.  Barber,  J.C., and T.D. Farr.  Fluoride Recovery from
     Phosphorus Production.  Chemical Engineering Progress,
     66: 11 pp. 56-62.
                               2-31

-------
11.   Lehr,  J.R.,  and McClellan,  G.H.   Fluorine Content and
     Properties of Commercial Phosphate Rocks.  Technical
     paper  presented at the American  Chemical Society
     Symposium Fluorine Sources  and Technology on August 30,
     1972,  in New York, New York.

12.   Considine, D.M.  (ed.).   Chemical and Process Technology
     Encyclopedia.   McGraw Hill  Book  Co. New York, New York.
     1974.   p.  872.

13.   Information obtained from the following sources:  a)
     Letters from A.B.  Capper, Catalytic,  Inc., to Lee Beck,
     EPA, dated August  30,  1974; September 6, 1974;  October
     18,  1974;  October  25,  1974; October 30,  1974; November
     4,  1974;  November  20,  1974; December 30, 1974;  and
     January 6, 1975.   b)  Letter from R.A.  Schutt, EPA,  to
     Mr.  Lee Beck,  EPA, dated October 15,  1974.

14.   U.S. Environmental Protection Agency.   Compilation of
     Air  Pollutant Emissions Factors.   2nd Edition.   April
     1973.   Document No.  AP-42.  Section 8.18.

15.   Florida Department of  Pollution  Control.  Hearing
     officer's  report,  22  November 1972, in the matter of
     W.R. Grace and Co.,  Cities  Service Co.,  and Mobil
     Chemical Co.

16.   Lindsey,  A.M.,  and R.  Segars.  Control of Particulate
     Emissions  from Phosphate Rock Dryers.   Environmental
     Protection Agency, Region IV-  Atlanta,  Georgia.
     January 1974.

17.   Smith,  J.L.,  and Snell,  H.A.   Selecting Dust Collec-
     tors.   Chemical  Engineering Progress,  64 (1)  1968.   pp.
     60-64
                               2-32

-------
        3.0  APPLICABLE EMISSION REDUCTION TECHNIQUES





     The sequential operations in a phosphate rock proces-



sing plant require the application of several systems to



control emissions.  Operations that require some type of



emission control are drying, calcining, conveying and stor-



age of dry rock, grinding, and conveying and storage of



ground rock.  Generally, each operation has its own emission



control system.



3.1  MINING AND BENEFICIATION



     Over 98 percent of the phosphate rock produced in the



United States is mined in areas where the ground moisture



content is high enough to preclude particulate emissions



during extraction of the ore.  In the relatively dry areas,



where ground moisture content is not sufficient to prevent



emissions (such as the hard-rock areas of Utah and Wyoming)



mining operations generate particulate emissions during



blasting and in the handling of overburden and ore body.



The active mining area is wetted with water from tank trucks



to minimize these emissions.  Beneficiation is performed in



a water slurry, and the wet rock does not become airborne.
                               3-1

-------
3.2  CONVEYING OF ROCK


     Mined rock is normally moved by conveyor belts; some


are open and others are closed for weather protection.


Except in the relatively small plants in the hard rock areas


of Utah and Wyoming, the high moisture content of the rock


(from 10 to 15 percent by weight)  prevents emission of


particulate matter.  In arid or windy locations, weather-


protected conveyors aid in emission control.


3.3  PHOSPHATE ROCK DRYING


     The air stream from a rock dryer contains particulate


and combustion products, including moisture.  The tempera-


tures at which the rock is dried are too low to drive off

                 2
gaseous fluoride.   The effluent temperature ranges from


344° to 422°K  (160° to 300°F) and the particulate loading is


about 7 g/dry std. m  (3 gr/dscf).    The most commonly used


control systems are various types of wet scrubbers, although


two facilities use electrostatic precipitators.  Table 3-1


and 3-la give the operating and emission data for several


collection systems, four of which are EPA tests (as indi-


cated) .  Appendix A contains additional details of the EPA


tests and the results of some sampling conducted by the


industry.


3.3.1  Scrubbers


     Scrubbers are by far the most common control device
                               3-2

-------
CO

U)
                     Table 3-1.    EMISSIONS  FROM  ROCK  DRYERS  EQUIPPED WITH VARIOUS  TYPES  OF


                                                            CONTROL EQUIPMENT


                                                                 (S.I.  UNITS)
Company
Agrieo Chemical




Beker Industries
Borden Chemical
Brewster Phosphates


Co&serv, Inc.
Gardinier , Inc .
H.R. Grace « Co.





Hooker Chemical

INC Corporation

IMC Corporation
Mobil Chemical

Occidental Chemical

Rocky Htn.
Phosphates

J.R. tlmplot



Stauffer Chemical
Stauf fer Chemical

Swift Chemical

Texasgulf, Inc.

USS Agri-Chem
Location
Pierce, Fla.




Conda, Idaho
Plant City, Pla
Bradley, Fla.


Nichols, Fla.
Ft. Heade, Fla.
Bartow, Fla.





Columbia, Tenn.

Horalyn, Fla.

Kingsford, Fla.
Nichols, Fla.

Hhite Springs,
Fla.
Garrison, Mont.


Conda, Idaho



Leefe, Wyoming
Vernal, Utah
~
Bartow, Fla.

Aurora, NC

Ft. Meade, Fla.
Product
rate
Hg/h
907




57
136
266


100
178
152





19

499

302
319
318
220

4.5


136



50
24
24
161
240
211

170
Type of
facility
UNR




fluid bed
rotary
UNK


UNK
UHK
rotary
fluid bed




rotary

UNK
UNK
fluid bed
rotary
rotary
fluid bed

rotary


rotary



rotary
rotary
rotary
rotary
fluid bed
fluid bed

rotary
Control
device3
IS




CS
C
ESP


IS
CS
ISSESP
ISSESP




ES

CS
CS
CS
vs
vs
CS

vs


C



TS
C
C
ws
CS
C

CS
Stack gas
flow rate
dry std.m3/s
378




12.7
24.5
68.4


12.7
36.3
Ml





8.5

73. 2b

11
35
42 '
43.9

UHK


10.4



7.1
4.7
4.7
26.4
35.9
UNK

UNK
Missions
3
g/dry std.m"
0.46




0.16
2.75
0.34


0.34
0.32
0.02





0.37

0.16
0.14
0.09
0.015
0.07
0.07

UNK


0.53



0.23
3.43
2.52
0.92
0.14
UNK

UNK
kg/h g/Mg
62.6 310




7.3 130
240 1750
86.2 300


15.9 160
41.7 235
4.5 12.5





11.3 600

21.3 80
18.1
10. » 40
4.) 20
9.1 30
10.9 SO

UNK UHK


19.1 140



5.9 120
57.6 2450
41.3 1750
86.6 535
17.7 75
UN* UNK

UNK UNK
Remarks
Production rate is total for four
dryers; g/Mg and g/std. m3 were i
calculated using total production, •
total gas flow and total emissions
from all four units.

•
Production rate is for two
dryers. Both are ducted
to one ESP. )
i
1
1
Dryers are ducted to separate f
scrubbers. The combined
scrubber outlet emissions
follow one common 4vct to two
parallel LSP's which have j
separate stacks. EPA Teet. Facility B
This dryer operates at <77*K
(exit gas temperature).
Production rate is total for
two dryer •.
EPA Test.4 Facility A
BPA T«t * Facility A
EPA T*«t. Facility A


This dryer has not been tested.
Dryer operates at 394-422°K
(exit gas temperature) .
This dryer operates at approx-
imately 422*K (exit «a> tem-
perature) which is about 311*K
hotter than Fla. dry arc.





Emissions from this dryer have
never been sampled.

                       "LEGEND:
                       C  - Cyclone         ESP - Electrostatic Precipitator  VS
                       CS «= Cyclonic scrubber IS » Impingement scrubber      WS
                       ES - Educto'r scrubber  TS = Spray tower
                                                                  UNK
Venturi scrubber         Total for two dryers.
Wet scrubber (generic type cTh«se dryers averaged 252 and
not known)              100 Hg per hour production
Unknown
                                                                                          , during th* tests.
                                                                                           See Appendix A for additional test results.

-------
                    Table  3-la.    EMISSIONS  FROM  ROCK DRYERS  EQUIPPED WITH  VARIOUS  TYPES


                                                       OF  CONTROL  EQUIPMENT 4

                                                            (ENGLISH UNITS)
10
 I
Company
JUjrioo Chemical


taker Industrie*
Borden Cheedcal
Conaerv, Inc.
N.R. Grace t Co.





Hooker Chenlcal

po
INC Corporation
Mobil Chemic*!

Occidental Chemical
*>c*T Mtn.
Phosphate*

J.I. Binplot


Stanffer chemical

Swift Chemical

Tenaagulf , Inc.

WS8 Agri-Chem
Location
Pierce, Fla.


Conda , Idaho
Plant City, Pla
Nichole, Fla.
Bartow, Fla.





Columbia, Tenn.

Y '
King* ford, Fla.
Nichola, Fla.

lAite Sprino*,
Fla.
Garrison, Mont.


Condi, Idaho


Vernal, Utah

Bar tow, Fla.

Aurora, HC

Ft. Heade, Fie.
Product
rate,
tona/h
1,000


63
ISO
110
196
3M





21


333
HI
350
242
5


150


26
26
178
2fi5
233

187
Type of
facility
UNK


fluid bed
rotary
UNK
UN*
UNK
rotary
fluid bed




rotary
UNK
UNK
fluid bed
rotary
rotary
fluid bed
rotary


rotary


rotary
rotary
rotary
fluid bed
fluid bed

rotary
Control
device8
IS


cs
c
ESP
IS
IStESP
ISC ESP




ES

CS
cs
cs
vs
vs
cs
VB


c


c
c
KS
CS
C

Cl
Stack
flow f
decfnxlO--
BOO


27
52
145
27
77
112"





i»

155
IS
75
78
t*
UK*


21


10
10
56
7«
an

urn
?••
"1
gr/dacf
0.2


0.07
1.2
O.ls'
0.15
0.14
0.01





a. it

0. 07
0.0«
».»4J
0.0151
0.03
• .»]
umt


0.2}


1.5
1.1
0.4«
O.M
UM

UMt
Partioulat*
niiniqnfl
Ib/h
138


16
530
190
35
92
».7





as

47
40
23.1
1,5
20
24
UMd


42


127
n
191
39
UNK

um
Ib/ton



0.26
3.5
0.60
0.32
0.47
0.025'





1.2

0.1C
O.«7i
0.039
O.M
o.ie
uwt


O.H


4.9
3.5
l.«7
0.15
UNK

UHK
Rmarka
dryerli Ib/ton and gr/6cC w«ra
total gal flow and total anl»«lons
from all four unita.

Production ratfl is for two
to one ESP.
Dryara are ducted to aeparate
•crabbers. The combined
•crubber outlet emiBSionB
follow one connon duct to two
parallel E£P'« which have
aeparate atacke. EPA t»at<> Facility B
Thla 4rr«r of«vat«« at 400*V
(exit ?mm tM|ieratare) .
FrodoctioB rate ia total for
two dryera.
B>A Teat.' Facility A
m Teat.*1 Facility A

«P» Teat.11 Facility A
Thia irffr Um* a»t bam teated.
Drr«r otarata* at 2M-3M-F
(axit gaa tcoparature) .
lUa «rraz aacntM at approji-
imately 300°F (exit gaa teia-





•aiaalon. fro* thla dryer ham
never been sampled.

                                 LEGEND:
                                C • Cyclone        BBP • Electrostatic Pncipitator VB •
                                CS • Cyclonic acrubber IS * Ia.Bin9ea.ent »crabber     WS •
                                ES - Edwctor Bcrubber  TS • Spray tower
Ventori ecrubber        Total for two dryer*.
Nat ccruMmr (generic type  Tlmae dryera averaged 27S and
not known)            110 tons per hour production
                                                                                         See Appendix
                                                                                                  for additional detalla.

-------
used in the operation of phosphate rock dryers.  Probably



the most important design parameters for scrubbers are the



amount of scrubber water used per unit volume of gas treated



(liquid-to-gas ratio) and the intimacy of contact between



the liquid and gas phases.   The latter parameter is gen-



erally related to the pressure drop across the scrubber.



     Although wet collectors of various designs are used on



rock dryer effluents, venturi, impingement, and cyclonic



scrubbers are the most common.  Venturi scrubbers generally



achieve the highest emission reduction, usually at the



expense of higher pressure drops and energy requirements.



It is possible for a venturi scrubber to reduce emissions to



as low as 0.071 g/dry std. m  (0.031 gr/dscf).  An EPA test



of the Occidental rock dryer venturi scrubber indicated an



emission reduction from 4.48 to 0.034 g/dry std. m  (1.96 to



0.015 gr/dscf), representing over 99 percent collection



efficiency.   This system operated at 4.5 kPa (18 in.  WG)



pressure drop and a liquid-to-gas ratio of 1.44 Jl/actual m



(10.8 gpm/10  acfm) .   Table 3-1 indicates other types of



scrubbers can reduce emissions to a level of 0.07 to 0.46



g/dry std. m  (0.03 to 0.2 gr/dscf), and efficiencies of 90



to 95 percent are common.



     The predicted collection efficiency of venturi scrub-



bers with a relatively low pressure drop of 3 kPa (12 in.
                                3-5

-------
WG) is 80 to 99 percent for particulates 1 to 10 micrometers


in diameter and 10 to 80 percent for those less than 1


micrometer.  The predicted collection efficiency of scrub-


bers with a high pressure drop of 7.5 kPa  (30 in. WG) may


reach 96 to 99.9 and 80 to 96 percent, respectively, for


particles in the same size ranges.  These data were obtained


by actual field tests on scrubber efficiency and particle

                                       7
size distribution by cascade impactors.


     Source test data on the performance of a venturi and a


cyclonic wet scrubber are shown in Table 3-2.  These data


represent what might be classified as typical performance.


Additional data are given in Appendix A for these and other


EPA source tests.


3.3.2  Electrostatic Precipitators


     Plate  (electrode) voltage and the ratio of plate area


to the volume of gas to be treated are the most important


design parameters of an ESP.  Particle resistivity and the


ease of cleaning collected dust from the plates also affect


ESP performance.  Electrostatic precipitation is sometimes


an economically attractive control technique in cases where


fine dust particles predominate.  Removing fine particles


with a venturi scrubber requires relatively large power


inputs  (high pressure drops) to achieve the necessary effi-


ciency.  If power cost savings effected by the ESP exceed
                                3-6

-------
U)
                   Table  3-2.   PERFORMANCE OF VENTURI AND CYCLONIC WET SCRUBBERS ON

                                             PHOSPHATE  ROCK  DRYERS3
-
Exhaust volume,
dry std. m3/s (dscfm)
Temperature °K, (°F)
Moisture content, % v
Feed rate, Mg/h (tons/h)
Grain loading.
g/dry std. m^ (gr/dscf)
Mass emission,
kg/h (Ib/h)
Emission factor,
g/Mg feed (Ib/ton)
Venturi scrubber '
Inlet
33.0 (70,000)
364 (195)
26
220 (243)
4.48 (1.96)
533.4 (1176)
2.420 (4.84)
Outlet
35.2
340
26
220
0.034
4.31
19.5
(74,600)
(153)

(243)
(0.015)
(9.51)
(0.039)
Cyclonic scrubber '
Inlet
30.9 (65,500)
349 (168)
26.5
220 (243)
0.828 (0.362)
89.8 (198)
400.0 (0.80)
7
Outlet
42.0
337
26.5
220
0.076
10.9
47.0
(89,000)
(148)

(243)
(0.033)
(24)
(0.094)
                   Additional performance test data are given in Appendix A.
                   Operating at 4.5 kPa  (18 in. WG) pressure drop and 1.44 i/m  (10.8  gpm/10  acfm).
                 c Test operating data,  such as pressure drop and liquid rate are not  available.

-------
the increased capital charges,  this system can be more
                                     o
economical than the venturi scrubber.

     Two operators of phosphate rock dryers now use electro-

static precipitators.  One has  a conventional dry ESP to

control emissions from two rotary dryers.   The precipitator

was designed for 95 percent efficiency,  but typically

operates at 93 percent.10  The  other uses  a wet ESP designed

at 150 m2/™3^"1 (0-75 ft2 plate area/acfm) .   This unit

controls emissions from two dryers operated in parallel, one

a rotary design and the other a fluid bed.   The control

system at this plant is unusual in that  the exhaust from

each dryer is first cleaned by  an impingement scrubber.  The

streams from both dryers are then combined and discharged

through the ESP.  Although the  ESP was designed for an

efficiency of 90 percent, it is probably operating at a

higher efficiency because the gas flow rate is about 60

percent of design capacity.  Simultaneous  inlet and outlet

tests have not been performed on the dryers;  however, the

operator reports inlet loadings to be 1.37 to 2.29 g/dry

std.  m  (0.6 to 1.0 gr/dscf)  and EPA tests show outlet

emissions to average about 0.023 g/dry std.  m  (0.01 gr/

dscf),  or 98 to 99 percent efficiency.    Outlet test data

for the wet ESP are shown in Table 3-3.  Additional data on

this unit can be found in Appendix A.
                              3-8

-------
     Table 3-3.  ESP PERFORMANCE ON PHOSPHATE ROCK DRYER

            PARTICULATE EMISSIONS (OUTLET DATA)
Exhaust volume

Temperature

Moisture content

Feed rate

Outlet loading

Mass emission rate

Emission factor

ESP design

Plate area

Water rate

Estimated efficiency
52.86 dry std. m /s

316°K

8.9% v

353 Mg/h

0.023 g/dry std. m

4.42 kg/h

12.5 g/Mg feed

Wet-type

4700 m2

75.7 JL/8

98 to 99%
 112,000 dscfm

 110°F

8.9% v

 389 tons/h

 0.01 gr/dscf

 9.74 Ib/h

 0.025 Ib/ton

Wet-type

 50,600 ft2

 1200 gpm

98 to 99%
  ESP preceded by impingement-type wet collectors,  which are
  preceded by cyclone separators.  ESP operated at 60% of design
  level.
b Inlet loading estimated at 1.37 to 2.29 g/dry std.  m
  (0.6 to 1.0 gr/dscf).
                              3-9

-------
3.3.3  Fabric Filters



     No fabric filters are known to be in use for phosphate



rock dryer emission control.  Many industry members believe



that moisture condensation would be a major problem because



water droplets could mix with the clay-like dust mat formed



on the fabric media and cause a mud cake.  Were this con-



dition to occur, it would "blind" the bags.  Furthermore,



since the dust usually has no economic value, dry recovery



for reprocessing is not an attractive incentive to opera-



tors.



     To avoid condensation, a difference of 28°K (50°F)


                                                      12
between the wet and dry bulb temperature is desirable.



This can be achieved by insulating all ductwork and the



filter; however, the condensation potential still remains



during process upsets, startup, and shutdown.  Careful



operating procedures and provision for an emergency bypass



around the filter may prevent serious damage.



     Overheating of the fabric media is not a problem,



because the dryers operate at about 394°K  (250°F) and the



exhaust temperature is generally less than this.  A tempera-



ture control system would ensure a temperature difference of



at least 28°K (50°F) above the dew point and prevent over-



heating.



     Contrary to the opinions expressed by industry experts,



two major manufacturers, Wheelabrator-Frye and American Air
                                3-10

-------
Filter, believe that fabric filters can be effective in this
application.  These companies state that successful opera-
tion of fabric filters are common in more difficult opera-
tions such as asphalt plants, cement plants, fertilizer
                              o
dryers, and the clay industry.
     Under proper operating conditions, fabric filters
generally exceed 99 percent efficiency and reduce emissions
to less than 0.023 g/dry std. m3 (0.01 gr/dscf).   Similar
processes for which fabric filters are used include clay and
kaolin rotary and spray dryers.  For this reason, fabric
filters are considered a viable control technique along with
wet scrubbers and ESP's, even though no direct evidence of
their capability can be presented.  (For more details on design
and performance of fabric filters, consult Control Tech-
                                      1 2
m'ques for Particulate Air Pollutants.  )
3.4  PHOSPHATE ROCK CALCINERS
     As discussed in Chapter 2, calciners and dryers have
similar emission characteristics.  The gas stream leaving
the commonly used fluid-bed calciner passes through a
windbox, aftercooler, and cyclone separator prior to the
point of final collection of the particulate emissions.
Although calcining temperatures are 760* to 870'C (1400* to
1600*F), the effluent gas temperature is about the same as
that of the dryer, about 392*K (250*F), because of the heat
                             3-11

-------
recovery that takes place in the aftercooler.  Wet scrubbers



are by far the most common control device, although an ESP



is used by one company.  Table 3-4 gives examples of various



control devices and their measured emission reduction.



3.4.1  Wet Scrubbers



     The wet scrubber achieves reasonable emission reduction



at a nominal pressure drop and eliminates the danger of high



temperature damage to the control system.  Table 3-4 indi-



cates particulate emission rate from calciners equipped with



various types of wet collectors, including wet cyclones,



impingement scrubbers, and venturi scrubbers.  The venturi



scrubber, which offers high efficiency at higher pressure



drops, is the most frequently used control device.



     One EPA test at Beker Industries indicated an outlet

                                   3
concentration of 0.073 g/dry std.  m  (0.032 gr/dscf)  on a



venturi scrubber operating at a pressure drop of 3 kPa (12



in. WG) and a liquid recirculation rate of 2.4 H/m  gas (18


         14
gal/scf).    Table 3-5 gives additional performance data



obtained from this source test.



     The general range of emissions from calciners using



other wet scrubbers is 0.114 to 0.69 g/dry std. m3 (0.05 to



0.3 gr/dscf).  Appendix A provides additional source test


data.
                                3-12

-------
      Table 3-4.   PARTICULATE EMISSIONS FROM PHOSPHATE ROCK CALCINERS

                                      (S.I. Units)
                                                                                  13
Company
Beker Industries

Mobil Chemical
J. R. Simplot


Stauffer Chemical



Texasgulf, Inc.



Location
Conda, ID

Nichols, FL
Pocatello, ID


Leefe, WY



Aurora , NC



Production
rate
Mg/h
59
63.5
45.5
31.8
37.2
49.9
18.1
18.1
27.2

54.4
54.4
54.4
54.4
Type of
calciner
Fluid bed£
Fluid bed
Rotary
Fluid bed
Fluid bed
Fluid bed
Fluid bed
Fluid bed
Fluid bed

Fluid bed
Fluid bed
Fluid bed
Fluid bed
Control
device
™*
vsc
IS
IS
cs
ESP
C
C
C
d
vsd
vsd
vsd
vs
Stack gas
flow rate,
wet std. mVs
16.0
18.9
26.0
11.8
13.2
27.4
8.0
8.0
13.7

25.0
25.0
25.0
25.0
Particulate
emission rate.
g/dry std m3
0.07
0.23
0.11
0.69
0.23
0.14
3.52
2.75
1.44

0.09
0.09
0.09
0.09
kg/h
4.0
15.4
11.3
29.0
10.9
13.6
102.1
79.4
71.7

7.4
7.4
7.4
7.4
g/Mg
68.0
245
250
900
290
270
5625
4375
2630

135
135
135
135
LEGEND;

C    = Cyclone
CS   = Cyclonic Scrubber
ESP  = Electrostatic  Precipitator
IS   = Impingement Scrubber
VS   = Venturi Scrubber
EPA Test Facility C, Appendix A.

Scrubber pressure drop is 2 kPa.

Scrubber pressure drop is 3 kPa.

Scrubber pressure drop is 5 kPa.

-------
Table 3-4a.   PARTICULATE EMISSIONS FROM PHOSPHATE ROCK CALCINERS

                                (ENGLISH UNITS)
                                                                              13
Company
Beker Industries

Mobil Chemical
J. R. Simplot


Stauffer Chem-
ical


Texasgulf, Inc.



Location
Conda , ID

Nichols, FL
Pocatello, i:


Leefe, WY



Aurora , NC



Product ior
rate
tons/h
65
70
50
5 35
41
55
20
20
30

60
60
60
60
Type of
calciner
Fluid bed
Fluid bed
Rotary
Fluid bed
Fluid bed
Fluid bed
Fluid bed
Fluid bed
Fluid bed

Fluid bed
Fluid bed
Fluid bed
Fluid bed
Control
device3
i b
vs
vs °
IS
IS
cs
ESP
c
c
c
a
vsd
vsa
VS<1
vsd
Stack gas
flow rate ,
scfm x 10~3
32.8
40
55
25
28
58
17
17
29

53
53
53
53
Particulate
emission rate,
gr/dscf
0.032
0.10
0.05
0.3
0.1
0.06
1.54
1.20
0.63

0.04
0.04
0.04
0.04
Ib/h
8.8
34
25
64
24
30
225
175
158

16.4
16.4
16.4
16.4
Ib/ton
0.136
0.49
0.5
1.8
0.58
0.54
11.25
8.75
5.26

0.27
0.27
0.27
0.27
   LEGEND;

  C    = Cyclone
  CS   = Cyclonic Scrubber
  ESP  = Electrostatic Precipitator
  IS   = Impingement Scrubber
  VS   = Venturi Scrubber
* BPA Test Facility C, Appendix A.
  Scrubber pressure drop is 8 in. WG.
° Scrubber pressure drop is 12 in.  MG.
  Scrubber pressure drop is 20 in.  WG.

-------
  Table 3-5.  PERFORMANCE OF VENTURI SCRUBBER ON PHOSPHATE


                  ROCK CALCINER (OUTLET)14'3
Exhaust volume

Temperature

Moisture content

Feed rate

Grain loading

Mass emissions

Emission factor

Control device



Pressure drop

Liquid rate
15.48 dry std. m /s


329°K


6.4% v


58.8 Mg/h

                  3
0.073 g/dry std. m


4.0 kg/h


68.01 g/Mg feed


ARCO venturi
 scrubber


3 kPa


37.9 I/a
 32,800 dscfm

 132°F


 6.4% v


 64.8 tons/h


 0.032 gr/dscf


 8.8 Ib/h


 0.136 Ib/ton

ARCO venturi
 scrubber

12 in. WG

600 gpm
  EPA Test Facility C, Appendix A.
                             3-15

-------
3.4.2  Electrostatic Precipitators



     Electrostatic precipitators can be an economical con-



trol technique.  For example, when calciner dusts contain a



high fraction of very fine particles, venturi scrubbers



require a high power input to achieve a satisfactory collec-

                         t

tion efficiency.  The power cost savings effected by using



an ESP to collect these dusts could offset the increased

                                             9
capital cost over that of a venturi scrubber.   This is



shown in the cost analyses in Chapter 4.


                                             2           2
     A calciner at one operation has a 1605 m  (17,280 ft )



two-stage, dry ESP, which operates at 33.47 actual m /s



(70,900 acfm) at 419°K C295°F) D.B. and 347°K (165°F) W.B.



This corresponds to a volume to plate area ratio of 0.015


 32             2
m /s per m   (2.9 scfm/ft ).   The company reports inlet and



outlet loading averages of 10.75 g/dry  std. m  (4.7 gr/



dscf) and 0.022 g/dry std. m  (0.0094 gr/dscf),  correspond-



ing to an overall efficiency of 99.8 percent.  Tests per-



formed by the operators using the WP-50 Test Methods show an



outlet loading of 0.14 g/dry std. m  (0.06 gr/dscf)  at a 99



percent efficiency.    ESP maintenance at this facility is



minimal, mostly routine cleanout and inspection.



3.4.3  Fabric Filters



     Problems associated with using fabric filters on



calciner exhausts are similar to those described for the
                                3-16

-------
dryer operation (Section 3.3.3).  No fabric filters are now
being used on phosphate rock calciners.  Producers commonly
cite high exhaust gas temperature as the major difficulty
expected with this kind of control device.  During normal
operation, the gases are cool enough not to endanger the
fabric material or the baghouse collector (394'K [250*F])
During periods of operational upsets, however, temperatures
can approach 644'K (700*F).  Upsets occur frequently during
start-up and shutdown and sometimes during normal operation
because of equipment or power failures.  The high tempera-
tures during these periods could result in excessive main-
tenance expenses, primarily for bag replacements.
     As in the dryer application, moisture content (up to
25% v) poses a potential problem of condensation on the
fabric during normally low exhaust temperatures [less than
366*K (200*F)].  With higher temperatures, condensation is
less troublesome but fabric overheating becomes a problem.
     The installation of cooling equipment such as heat
exchangers and water sprays can maintain safe temperature
levels for fabric filters on calciners.  On similar operations
where fabric filtration is used, such as clay and
kaolin rotary and spray dryers, particulate emissions are
controlled to less than 0.023 g/dry std. m  (0.01 gr/dscf)
at an efficiency of more than 99 percent.  There is no reason
why this technology cannot be transferred to phosphate
calciners.
                            3-17

-------
                     Table  3-6.   PARTICULATE  EMISSIONS FROM  PHOSPHATE ROCK  GRINDERS18


                                                        (S.I.  UNITS)
 I
M
VO
Company
Agrico
Chemical
Beker
Industries



Brewster
Phosphates
Farmland
Industries
Gardinier,
Inc.

K.R. Grace
and Co.
IMC Corp-
oration

IMC Corp-
oration
Mobil
Chemical
Occidental
Chemical

Royster
Company



J.R. Sim-
plot
Stauffor
Chemical
Swift
Chemical
Texasgulf ,
Inc.
USS Agri-
Chen
OSS Agri-
Chem
Location
Pierce,
Florida
Conda ,
Idaho



Bradley,
Florida
Bartow
Florida
Tampa ,
Florida

Bartow,
Florida
Noralyn,
Florida

Kingsford,
Florida
Nichols,
Florida
White
Springs,
Florida
Mulberry,
Florida



Pocatello,
Idaho
Lecfc,
Wyoming
Bartow,
Florida
Aurora ,
N.C.
Bartow,
Florida
Ft. Meade,
Florida
Production
rate
Mg/h
157

74
66



NR

100

213

41
141
218
12

100

190

ll«


70




91

36

41

136

41

68

Number
of
mills
6

1
2



2

1

1
5

3
2
7
1

3

4

1


2




6

3

3

3-

3

4

Type
of mill
Roller

Ball
Ball



Roller

Ball

Roller
Roller <
ball
Roller
Ball
Roller 1
ball

Roller

Roller

Ball


Roller <
ball



Roller

Roller

Roller

Ball

Roller

Roller

1
*
Control Device
number
6

1
2



1

1

1
5

1
1
5
1

2

2

1


1




3

3

3

2

5

5

type
BH

BH
BH



BH

BH

IS
BH

HS

BH
BH

VS

ws

BH


BH




BH

BH

HS

BH

BH

BH

Stack qas
flow rate
std. m3/s
0.19

1.8




3.4

2.1

4.5
5.8

7.7
J.I
4.7
1.21

9.9

3.8

6.42


).»




16.1



2.8

11.3

4.3

4.6

Particulate
g/std. m3| kg/h g/Mg>
0.12-
0.46
O.C04I
HR



0.0083

0.018

.25
.037-
.16
.14
.18
0.1S
0.015

0.39

0.46

0.024


0.004«




0.007-
0.016
NR

0.14-
0.35
0.35

0.20

0.005

6.8

0.03*
NR



0.10

0.45

• 4.3
5.0

3.2
3.6
12.3
0.0* t

14.5

5.0

0.5


0.041




0.06

NR

2.9

14.0

3.0

0.06

45

0.4S
MR



NR

4.5

40
NR

75
25
55
2.1

145

22

4.4


0.65




6.5

HR

65

105

74

1.0

Remarks


Emissions from two of the
three ball mills have never
been sampled . The plant used
EPA Method -5 to samole the
third mill. Facility C in Appendix A.




Production rate and g/Mg
emissions are for all six
mills.



EPA Test Facility G.
Appendix A.




EPA Test Facility D, Appendix A.


One baghouse cleans emis-
sions from both mills.
Emission tests performed
using HP-50 method with
slight variation*. Facility F in Appef


Emissions from the mills
have never been sampled.








                      'LBGBMD:  BH - Baghouse     IS - Impingement scrubber
                             HS - Het scrubber (Generic type not known)
VS - Venturi scrubber
NR - Mot reported

-------
10
I
NJ
O
                     Table 3-6a.   PARTICULATE EMISSIONS FROM  PHOSPHATE ROCK  GRINDERS18

                                                     (ENGLISH  UNITS)


Company
Agrico
Chemical
•eker
Industries




Brewster
Phosphates
Farmland
Industries
Gardinier,
Inc.

M.R. Grace
and Co.
IMC Corp-
oration
IMC Corp-
oration
Mobil
Chemical
occidental
Chemical

Royster
Company


J.R. Sim-
plot
Stauffer
Chemical
Swift
Chemical
Texasgulf.
lac.
aSS Agri-
Cms*
USS Agri-
Chem


Location
Pierce,
Florida
Idaho'




Bradley,
Florida
Bartow
Florida
Tampa,
Florida

Bartow,
Florida
Noralyn,
Florida
Kingeford,
Florida
Nichols,
Florida
White
Springs,
Florida
Mulberry,
Florida


Pocatello,
Idaho
Leefe,
Wyoming
Bartow,
Florida
Aurora,
N.C.
Bartow,
Florida
Ft. Heade,
Florida

Product Ion
rate*
toms/h
173
11
75




NR

110

235

45
155
240
IS
110

209

124


70



100

40

45

150

45

75


of
mills
6

2




2

1

1
5

3
2
7
1
3

4

1


2



6

3

3

2

3

4


Type
of mill
Roller
Ball
Ball




Roller

Ball

Roller
Roller 1
ball
Roller
Ball
Roller <
ball
Roller

Roller

Ball


Roller I
ball


Roller

Roller

Roller

Ball

Roller

Roller


Control
number
6

2




1

1

1
5

1
1
5
1
2

2

1


1



3

3

3

2

5

5


Device.
type
BH
BH
BB




BH

BH

IS
BH

H8

BB
BH
VS

WE

BH


BH



BH

BH

WE

BH

BH

BH


flow rate
scfmX10-3
0.4
4.1





7.1

4.4

9.6
12 3

It. 3
12.2
10.0
2.7
21.0

e.o

13.6


6.3



34.0

NB

6.0

24.0

9.1

9.8


em
gr/scf '
0.05-
0.2
0 002
HR




0.0036

0.008

0.11
0 016—
0.070
0.06
0.00
0.0»
0.00*5
0.17

0.2

0.010


0.002



0.003-
0.007
NB

0.06-
0.15
0.15

0.086

0.002


psion*
IWn
15
0. 00
MR




0.22

1.0

9.4
11 0

7.0
1.0
27.0
0.15
32

11

1.10


0.103



1.33

NR

6.4

30.9

6.6

0.13



Ib/ton
0.09
0 . OO09'
HR




NR

0.009

0.08

0.15
0.05
0.11
0.0042
0.29

0.044

0.00*


0.0013



0.013

NR

0.13

0.21

0.147

0.002



Remarks


three bell Kilftsj have never
been sampled. Ins plant used
•PA Method 5 to ssmple UM
third mill. Facility G in
Appendix A.




Production rate and Ib/ton
•ills.



Facility E in Appendix A.







One baghouse cleans emis-
sions fro* both mills.
•mission tawts cartoned
using KP-50 method with
•light variations.
Facility F in Append i« A.

Emissions fron the mills
have never been sampled.








                                  B*9faouse    IS * IsaTpingaaent scrubber
                                  Net scrubber (Generic type not known)
VS - Venturi acrtitoter
NB - Hot reported

-------
3.5.1  Fabric Filters
     Fabric filters are normally used to control emissions
from grinders, probably because the dust collected by a
fabric filter can be added directly to the product and
thereby increase yields.  Also, the low moisture content of
5 percent or less and low temperatures of 310 to 339°K (100
to 150°F) make fabric filtration technically and economi-
cally feasible.  In some plants, however, the moisture
content of the ground rock dust collected by fabric filters
causes much difficulty.  At these plants, wet collectors are
usually chosen for control.  However, as discussed in
Section 3.3.3, the problem of moisture condensation in
fabric filters can be overcome.  Refer again to Table 3-6
for typical emission rates for grinders equipped with fabric
filters.  Table 3-7 indicates typical performance of fabric
filters during EPA tests.  Appendix A presents details of
these and other tests.  Operators report no variation in
emissions from fabric filters as a result of such factors as
fineness of grinding, type of rock, ambient conditions, or
any other equipment or process variable that can be con-
trolled.17
     Pulsed-air fabric filters designed with a filter
velocity of 2 to 2.5 cm/s  (4 to 5 fpm) are common.  Con-
tinuous-shaker fabric filters with a filter velocity of 1 to
1.5 cm/s (2 to 3 fpm) could be used.
                                3-21

-------
             Table  3-7.   FABRIC FILTER PERFORMANCE ON PHOSPHATE ROCK GRINDER EMISSIONS
ui
l
to
NJ
Parameter
Exhaust volume, dry std, m /s
(dscfm)
Temperature, «K (T)
Moisture content, S v
Feed rate, Mg/h (tons/h)
Grain loading, g/dry std. m
(gr/dscf)
Mass emissions, kg/h (Ib/h)
Emission factor, g/Mg
(Ib/ton) feed
System I3'14
Inlet
1.75 (3700)
380 (224)
2.9
73 (81)
8,47 (3.7)
53.5 (118)
730 (1.46)
Outlet
1.89 (4000)
386 (235)
'o
73 (.81)
0.0048 (0.0021)
0.036 (0.08)
0.45 (0.0009)
System 2b'19
Inlet
1.42 (3000)
367 (202)
6
31.3 (34.5)
7.44 (3.25)
37.6 (83)
1200 (2.4)
Outlet
1.27
• 345

31.3
0.015
0.068
2.10
if •
(2700)
(161)
6
(34.5)
(0.0065)
(0.150)
(0.0042)

                                            '* *"**' Vel°City °f 2'5 Cm/S (5 f pm) '  Bek« Industries,

                                      filter velocity of 2 cra/s (4 fpm)? 1MC corp-

-------
     The information in Tables 3-6 and 3-7 and EPA test data



given in Appendix A indicate that fabric filters can gener-



ally achieve emission levels below 0.03 g/dry std. m



(0.013 gr/dscf) and maintain efficiencies greater than 99



percent.  Well-designed units can achieve even greater than



99.9 percent efficiency.



3.5.2  Scrubbers



     Scrubbers are sometimes used to control emissions from



grinders; they are usually low-energy venturi or impingement



scrubbers that operate at 2 to 2.5 kPa (8-10 in. WG) pres-



sure drop.  Based on data in Table 3-6 and Appendix A,



emissions from these devices typically range from 0.137 to



0.458 g/dry std. m  (0.06 to 0.20 gr/dscf), depending on the



pressure drop.  Such devices can be designed to meet typical



state emission requirements.



     For performance data for the various types of scrubbers



in operation, refer again to Table 3-6.  For more informa-



tion on scrubber design and operation, consult Air Pollution


                                                          12
Control Techniques for Particulate Air Pollutants (AP-51).



3.6  MATERIALS HANDLING AND STORAGE



     Emissions from materials handling systems are difficult



to quantify because many different systems are employed to



convey rock and because fugitive emissions comprise a large



part of the emission potential.  Materials handling systems
                                3-23

-------
range from front-end loaders and other manual conveyances to



automated pneumatic systems.  From an emissions standpoint,



the basic differences in the systems are the precautions



taken to prevent the dust from becoming airborne and the



ease with which the dust can be captured.



     The most common type of transfer system for unground



rock consists of conveyor belts and bucket elevators.  In



order to minimize fugitive emissions caused by ambient air



currents, conveyor belts for moving dried rock are usually



covered and sometimes enclosed.  The transfer point where



the material falls by gravity from the conveyor belt is the



major source of emissions from this type of system.  Hot



rock or ambient winds can also cause small amounts of fugi-



tive dust at points along the housed enclosure.  Although



transfer points are sometimes hooded and evacuated to



minimize fugitive emissions, all of those observed by EPA in



the phosphate rock industry had visible emissions.  Some



conveyors used for similar applications in the crushed-stone



industry are able to control transfer points to the extent



that no emissions are visible.



     Bucket elevators are usually enclosed and evacuated to



a control device; otherwise they would generate substantial



amounts of dust.
                               3-24

-------
     Rock that has been ground is normally conveyed in



totally enclosed systems, such as those described in Chapter



2.  These systems limit fugitive emissions very effectively,



since discharge points of material and of particulate-laden



air are well defined and easily controlled by fabric fil-



ters.  In essentially all cases, proper maintenance of the



transfer system and its control device ensures effective



control of particulate emissions.  Because the pneumatic



systems operate under positive pressure, a leak in the



transfer system itself requires immediate attention by plant



personnel to minimize product loss.



     The usual procedure is to store both ground and un-



ground dry rock in enclosed bins or silos that are vented to



the atmosphere.  Emissions from the vents are frequently



controlled by fabric filters.  On pneumatic ground-rock-



handling systems, this is the same fabric filter that con-



trols emissions from the transfer system.  The collected



dust is returned to the silo.



     The control of air pollution must be a priority item in



the design of new materials-handling systems; retrofitting



is frequently costly and difficult because of space limita-



tions and often results in a less efficient system.  This



is discussed in detail in Section 3.8 and Chapter 4.
                                3-25

-------
3.7  WET GRINDING


     The recent move toward wet grinding of rock for the


manufacture of wet-process phosphoric acid (WPPA) holds the


most promise for emission control from dryers and calciners.


The rock is ground in a water slurry, then added to the WPPA


reaction tanks without drying.  This technique has not been


practiced previously because the water entrained with the


ground rock required either the use of a stronger acid in


the WPPA reaction or removal by evaporation to maintain the


54 percent P2°5 strength needed for production of fertili-


zer.  Historically, 93 percent sulfuric acid has been di-


luted to 58 percent for the WPPA reaction to permit removal


of the heat of dilution prior to its addition to the reac-


tor.  If added to the reactor at 93 percent strength, the


heat of dilution coupled with the heat of reaction would


exceed the capacity of the vacuum flash cooler used for


temperature control.  Also, it was widely accepted that the


higher temperatures would result in formation of smaller


crystals of waste gypsum, which would complicate the separa-


tion of product acid from waste gypsum.


     Two companies overcame their reservations about the wet


grinding process and designed larger flash coolers on the


reactors to remove the heat of dilution.  They found no

                                                         O I
significant difference in the crystal size of the gypsum.
                               3-26

-------
The products from the reactor are fed to the evaporators at



28 to 32 percent P2°5 aci^/ as in th& conventional WPPA



process.



     One possible problem created by wet grinding is in-



creased water treatment costs.  The EPA's effluent water



regulations call for zero discharge by 1980.  About 460 £ of



water per Mg of throughput  (110 gal/ton) is generated and


                                21
requires treatment at one plant.    The potential savings



resulting from elimination of the energy-intensive phos-



phate-rock dryer, its air pollution control system, and the



air pollution controls for the grinder is, however, a



strong incentive to the operator.



     Plant management contends that the major driving force



regarding this process is not improved technology, but



increasingly expensive fuel costs and stringent air emission


            21
regulations.    It is now less expensive to treat the wet



rock than to contend with high energy costs and stringent



air regulations.



     The impact of the wet grinding process could be far-



reaching because about 70 percent of all phosphate rock is


                                      22
ultimately used to produce fertilizer,   and 85 percent of



the rock used for fertilizer must first be converted to


                23
phosphoric acid.    Present indications are that the trend


                            24
will be toward wet grinding,   and the growth rate for phos-
                              3-27

-------
phate rock dryers will become negligible.   Of course,  some

dry rock will still be required unless ways are found to

introduce wet ground rock into processes other than WPPA.

Much of this need may well be filled by the capacity of

existing dryers, thereby precluding the construction of new

ones.  The need for emission controls on phosphate rock

grinders may be diminished, but it will not be eliminated

because the calcination process is likely to continue at its

current rate of growth and calcined rock must be ground.

3.8  RETROFITTED CONTROL SYSTEMS

     It is more difficult to retrofit an emission control

system in an existing facility than to incorporate it into a

new plant design.  Installation of control systems on exist-

ing processes is more difficult for the following major

reasons:

     Plant age - Installation of control equipment may
     require structural modifications to the plant and/or
     process alterations.  In some cases,  however, it may  be
     feasible to locate control equipment on the ground
     adjacent to the phosphate rock processes.

     Available space - Installation may require extensive
     steel supports and/or site preparation.  Control
     equipment may have to be custom-designed to meet space
     allocations.  Longer duct runs are usually necessary.

     Utilities - Electrical, water supply, and waste removal
     and disposal facilities may require expansion.  These
     will not generally be a problem in this industry.

     Production shutdown - Loss of production during retro-
     fit adds to the initial cost of installing control
     equipment.  Long-term shutdowns due to installation of
     control equipment are not expected in the phosphate
     rock industry.
                              3-28

-------
     Labor - Higher labor costs result from the additional
     labor usually required because of increased installa-
     tion time and from overtime wages paid during normal
     shutdown periods.

     Engineering - Engineering time is required to integrate
     control systems into the existing operation.

     The major restriction encountered when retrofitting air

pollution control equipment in the phosphate rock processing

industry is limited space.  The arrangement of existing

process equipment may necessitate locating the new control

device and some auxiliary equipment, such as fans, pumps,

etc., on a site 15 to 30 meters (50 to 100 feet)  or more

from the emissions source.

     In the phosphate rock industry medium-energy impinge-

ment or cyclonic wet collectors are often replaced with

venturi scrubbers or other high-efficiency wet collectors.

Such replacement may require installation of a new fan.  If

a wet collector is replaced by a fabric filter or electro-

static precipitator, considerably more space is necessary,

and rearrangement of existing ductwork and extension of new

ductwork is sometimes required to allow adequate space for

the control device.

     Because most calcining, drying, and grinding operations

are already equipped with some type of emission control

system, the retrofitting of a control system to achieve

higher collection efficiencies normally entails the removal
                              3-29

-------
of the existing control  device and the use of some of the
auxiliary equipment and  ductwork.   The use of existing fans
depends on the fan capacity specified for the system pres-
sure drop and exhaust flow rate.   Existing ductwork dimen-
sions must be adequate to incorporate into the new system.
Remaining equipment life must also be considered in reusing
this equipment.
     One company completely replaced a fabric filter on a
                                                         25
grinding operation, using existing ductwork and supports.
In this case, the same location was adequate for the new
fabric filter and no new ductwork, foundations, supports, or
fan was required.  A spokesman for another company stated
that there are no unique problems  associated with retro-
fitting, although location, space, and structural limita-
                  ? fi
tions are typical .
     A Florida producer retrofitted an ESP on the drying
operation.  The ESP was installed  downstream from two
existing scrubbers.  Because placing the ESP near the
drying operation would have crowded the area around
the grinding mill, it had to be situated over
service railroad tracks, causing the use of the rail-
road tracks to be discontinued.  Because the distance between
the drying operation and the ESP was 24 to 30 m (80 to 100 ft)
greater than it would have been at a new plant, additional
                      ? 7
ductwork was required.
                          3-30

-------
     At the same facility a three-stage scrubbing unit was



retrofitted to replace an old wet collector on the dryer



operation.  The new unit had to be situated at an elevation



of 30m (50 ft) above ground level in a structure built in



1953 in order to utilize the existing water drainage system.



The major problem encountered was that of the excess weight



on the foundation of the building (the structural steel was



sufficient to handle the weight).  Grout and concrete were


                                             27
pumped under the foundation to strengthen it.



     At another operation in Florida, scrubbers were added



to an existing drying facility.  The scrubbers were installed



on a foundation at ground level, and ducting was connected



to an elevated cyclone system that served as the only con-



trol device for the dryer emissions.  This retrofitted sys-



tem was similar to a system installed on a new plant because



no space limitations, long duct runs, or other problems were


                                    28
encountered during the installation.



     Conversion to wet grinding can be feasible at plants



that produce phosphate for wet process phosphoric acid plants,



even though replacement of dry grinding with wet grinding



can be a difficult conversion.  Such conversion lowers



grinder capacity, and some problems have been encountered



with controlling the moisture content of the product.  It is



necessary to remove air conveying systems and install piping
                              3-31

-------
and pumping systems to facilitate the transport of the pro-



duct slurry.
                              3-32

-------
                        REFERENCES
1.  Sauchelli, V.  Chemistry and Technology of Fertilizers.
    New York.  Reinhold Publishing Corporation.  1960.  p.
    75.

2.  Letter from J.C. Barber, Tennessee Valley Authority,  to
    Lee Beck, Environmental Protection Agency, dated
    November 18, 1975.

3.  Chemical Construction Corporation.  Engineering and
    Cost Study of Emissions Control in the Phosphate Indus-
    try.  Unpublished draft.  Volume XI.   August 1972.

4.  Information obtained from the following sources:
    a. Letters from A.B. Capper, Catalytic, Inc., to Lee
    Beck, EPA, dated August 30, 1974; September 6, 1974;
    October 18, 1974; October 25, 1974; October 30, 1974;
    November 4, 1974; November 20, 1974;  December 30, 1974;
    and January 6, 1975.
    b. Letter from R.A. Schutt, EPA, to Mr. Lee Beck, EPA,
    dated October 15, 1974.

5.  Tomany, J.P.  A guide to the Selection of Air Pollution
    Control Equipment; Air Correction Division, Universal
    Oil Products.  Darien, Connecticut.  Undated.  p. 14.

6.  Source Test Report on Measurement of Emissions from
    Occidental Chemical Company.  White Springs, Florida.
    Engineering-Science and Engineering,  Inc.  Gainesville,
    Florida.  For Emission Standards and Engineering Divi-
    sion, U.S. Environmental Protection Agency-  Contract
    No. 68-02-0232.  Task No. 12.

7.  Lindsey, A.M., and R. Segars.  Control of Particulate
    emissions from Phosphate Rock Dryers.  Environmental
    Protection Agency Region IV, Atlanta, Georgia.  January
    1974.

8.  Telephone conversation between Mickey Martinasek of
    W.R. Grace in Bartow, Florida, and David M. Augenstein
    of PEDCo Environmental, Inc. , in Cincinnati, Ohio, on
    March 14, 1977.
                              3-33

-------
 9.   Air Pollution Emission Test.   Mobil Chemical,  Nichols,
     Florida.   Engineering-Science.  McLean,  Virginia.   EPA
     Contract  No.  68-03-1406.   January 1976.

10.   Letter from R.C.  Timberlake,  Brewster Phosphates,  to P-
     J.  Traina, Environmental  Protection Agency,  dated May
     3,  1974.

11.   Air Pollution Emission Test.   W.R.  Grace Chemical Co.,
     Bartow, Florida.   Engineering-Science, Inc., McLean,
     Virginia.  For U.S.  Environmental Protection Agency.
     Contract  No.  68-02-1406.   Task No.  14.  January 1976.

12.   Environmental Protection  Agency.  Control Techniques
     for Particulate Air  Pollutants,  Environmental  Protec-
     tion Agency.   Publication No.  AP-51.  January  1969.

13.   Op. cit.   Reference  5.

14.   Air Pollution Emission Test.   Beker Industries, Inc.,
     Conda, Idaho.  Midwest Research Institute.   For U.S.
     Environmental Protection  Agency.  Contract No. 68-02-
     1403.  November 19,  1975.

15.   Letter from Mr. J. G.  Cochrane,  Jr., R.  Simplot Com-
     pany, to  Mr.  Don R.  Goodwin,  Environmental Protection
     Agency, dated May 27,  1975.

16.   Smith, J.L.,  and H.A.  Snell.   Selecting  Dust Collec-
     tors.  Chemical Engineering  Progress. 64 (1) pp. 60-64.
     1968.

17.   Conversations between  Mr. Lee Beck, Environmental
     Protection Agency, and Messrs. Basil Powell, U.S.S.
     Agri-Chemical, and J.  Gadston, Royster Company, on
     September 23 and 26, 1974, respectively.  Also reported
     in trip report from  Mr. C. L.  Vacher, Catalytic, Inc.,
     to Mr. Lee Beck,  Environmental Protection Agency,  dated
     October 17,  1974.

18.   Op. cit.   Reference  5.

19.   Kulujian, N., and R. Gerstle.   Test No.  73-ROC-2.
     International Minerals and Chemical Corp.  Noralyn,
     Florida.   PEDCo-Environmental, Inc.  Cincinnati, Ohio.
     For U.S.  Environmental Protection Agency.  Contract No.
     68-02-0237.   Task No.  19. June 1973.
                               3-34

-------
20.  Vervaert, A.E.,  R.  Jenkins, and A.  Basala.   An Investi-
     gation of the Best Systems of Emissions Reduction for
     Quarrying and Plant Process Facilities in the Crushed
     and Broken Stone Industry.  Draft document prepared by
     the Environmental Protection Agency,  Research Triangle
     Park, North Carolina.   August 1975.   p. C-17.

21.  Telephone conversation between Mr.  Lee Beck, Environ-
     mental Protection Agency, and Mr. Fred Hughes on June
     23, 1975.  Also, letter from Mr. Harold Long, Agrico
     Chemical Company, to Mr.  Don R. Goodwin, Environmental
     Protection Agency,  dated August 19,  1975.

22.  PEDCo-Environmental Specialists.  Trace Pollutant
     Emissions from the Processing of Non-metallic Ores.
     Environmental Protection Agency Contract Number 68-02-
     1321, Task No.  4. p. 6-1.

23.  Stowasser, W. F. Phosphate Rock.  United States Depart-
     ment of the Interior,  Bureau of Mines.  Preprint from
     Bulletin 667.  1975. p. 6.

24.  Telephone conversation between Mr.  Lee Beck, Environ-
     mental Protection Agency, and Mr. Fred Hughes, on June
     23, 1975.  Also, letter from Mr. Harold Long, Agrico
     Chemical Company, to Mr.  Don P. Goodwin, Environmental
     Protection Agency,  dated August 19,  1975.

25.  Inter-office memo from R. H. Schippers, Economic Anal-
     ysis Branch, U.S. Environmental Protection Agency,
     Research Triangle Park, North Carolina, to Files.
     Subject: Retrofit Costs for Baghouses, Scrubbers, and
     Precipitators used in Phosphate Rock Processing Indus-
     try.  January 11, 1977.

26.  Telephone conversation between David M. Augenstein,
     PEDCo Environmental, Inc., Cincinnati, Ohio, and Mr.
     Harold Long, Agrico Chemical Co., Pierce, Florida.
     February 2, 1977.

27.  Telephone conversation between David M. Augenstein,
     PEDCo Environmental, Inc., Cincinnati, Ohio, and Mr.
     Michael Lloyd,  Agrico Chemical Co.,  Pierce, Florida.
     April 26, 1978.
                                3-35

-------
27.   Telephone conversation between David M. Augenstein,
     PEDCo Environmental,  Inc.,  Cincinnati, Ohio, and Mr.
     Micky Martinesek,  W.R. Grace Co.,  Bartow, Florida.
     April 28, 1978.

28.   Telephone conversation between David M. Augenstein,
     PEDCo Environmental,  Inc.,  Cincinnati, Ohio, and Mr.
     Bruce Galloway,  Borden Chemical Company, Plant City,
     Florida.   May 1, 1978.

29.   Telephone conversation between David M. Augenstein,
     PEDCo Environmental,  Inc.,  Cincinnati, Ohio, and Mr.
     Harold Long,  Agro  Chemical  Co., Pierce, Florida.  April
     28,  1978.
                              3-36

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          4.0  COSTS OF APPLYING CONTROL TECHNOLOGY





4.1  INTRODUCTION



4.1.1  Purpose



     This section presents capital, operating, and annualized



cost estimates for the control of particulate emissions from



selected phosphate drying, calcining, and wet and dry grind-



ing operations.  The costs presented herein are not detailed



estimates from actual system designs, but rather predesign



cost estimates, accurate to within + 20 to 30 percent for the



model plants chosen, which can serve as a guide for control



officials and industry personnel.  All costs have been



escalated to reflect fourth quarter 1977 prices by using the



Chemical Engineering Index (212) for plant construction



costs.  The costing methodology is also presented to allow



cost estimations at specific sites where design and operating



parameters are considerably different from those assumed



herein.



4.1.2  Scope



     Process and emission control systems for which costs



are presented are given in Table 4-1.  Annualized, direct



operating, and capital costs are determined for three levels
                             4-1

-------
of control:  two state regulations  (SIP, and SIP-), and an



alternative emission level (AEL).  Appendix B contains an



explanation of Sip and AEL controls and includes plots of



allowable emissions versus process weight rate.



     Table 4-1.  PROCESS/CONTROL SYSTEMS CONSIDERED FOR



                        COST ANALYSES
Process
Drying
Calcining
Grinding
Control system
Venturi
scrubber
X
X
X
Fabric
filter
X
X
X
Electrostatic
precipitator
X
X

     The wet grinding process is one alternative control



method gaining wide recognition throughout the industry as a



replacement for the drying and grinding operation (see



Section 2.5).  This method of eliminating emissions is



feasible only when the phosphate rock being produced is used



for the raw material in the manufacture of wet process



phosphoric acid (WPPA).   The costs for replacing conventional



grinding equipment with wet grinding are also discussed.



     Typical capacities were selected for each process to



represent small,  medium, and large production rates as shown



in Table 4-2.  All costs are developed from the model pro-



cesses.
                             4-2

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Table 4-2.  PRODUCTION CAPACITIES




   OF SELECTED MODEL PROCESSES
Process
Drying
Calcining
Dry grinding
Wet grinding
Capacity, Mg/h (tons/h)
Small
45 (50)
45 (50)
45 (50)
45 (50)
Medium
181 (200)
41 (45)
91 (100)
91 (100)
Large
272 (300)
64 (70)
136 (150)
136 (150)
               4-3

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     In addition, costs are presented as a function of the



exhaust flow rate for each process.  Since exhaust flow



rates per unit production rate vary significantly from one



operation to the next,  control costs for a given process and



control system are expressed as a function of exhaust flow



rate instead of production rate.   These estimates based on



flow rate are likely to represent the actual costs within a



20 to 30 percent range since exhaust gas characteristics are



based upon actual field testing.



     The capital and annual costs for installing control



equipment on existing plants only (retrofitted systems)  are



given in this document.  Retrofitted systems may be sig-



nificantly higher or lower in total cost than systems



installed on new plants, depending on site-specific parame-



ters such as available space, foundation requirements, duct



location, etc.  Retrofitted control systems are discussed in



more detail later in this section.



     The capital and annualized costs developed by the



analyses described in this chapter are compared to actual



costs in the industry.   Generally, most estimated and actual



costs compared reasonably well.



     As discussed in Section 3, costs are not presented for



electrostatic precipitators on grinding operations since



they are not used in the industry.  Calcining and drying
                               4-4

-------
operations normally require a product recovery cyclone,



which could be considered process equipment; therefore the



control costs do not include these recovery cyclones.



Fabric filters used on ground rock transport systems are



considered product recovery equipment; therefore, no costs



are presented.



4.1.3  Use of Model Processes and Plants



     Usually, each of the multiple-parallel processes, i.e.



three 91.0 Mg/h  (100 tons/h) dryers, is controlled by a



separate system.  To estimate the total control cost for an



entire model plant, the cost for a combination of the model



processes must be added.



     The total number of possible process configurations for



an entire plant is well over 100, with two to three control



options per process.  Possible process/control configura-



tions are numerous for one specific plant size, and none is



typical.  For this reason, total model plant costs are not



developed.  This chapter is presented so that costs may be



estimated for individual processes with a known exhaust flow



rate.  By this approach, error in cost estimating will be



minimized.



4.1.4  Bases for Capital Cost Estimates



     Capital costs developed in this chapter include the



total cost of buying and installing equipment items such as
                                4-5

-------
control devices, ductwork Cinclxiding flanges, expansion



joints, and dampers), fans,  stacks, pumps, and tanks.  Re-



search and development costs and production losses during



construction and start-up are not included.  No cost esti-



mates are included for additional solid waste or wastewater



treatment and disposal facilities since they are generally



unnecessary.  Sections 5.3 and 5.4 will show that increases



in wastewater and solid waste volumes are insignificant.



Furthermore, treatment facilities normally are available on



site and do not need expansion to handle the increase in



waste treatment and disposal.



     Purchase Costs - Cost information is primarily from



reliable vendors and cost handbooks.  Information sources



for purchase costs of selected equipment are given in Table



4-3.  Field data obtained by EPA and/or engineering judgment



determined equipment specifications to achieve a desired



system performance.



     Direct Costs - Installed costs are estimated by multi-



plying the unit price for a given equipment item (obtained



from a vendor or other reliable source) by the direct cost



factor shown in Table 4-4.  The final cost includes items



such as instrumentation, piping, electrical, foundation,



structures, sitework, insulation, painting, and labor



required for installation.
                               4-6

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        Table 4-3.  INFORMATION SOURCES FOR PURCHASE

                 COSTS OF SELECTED EQUIPMENT
Fabric filters
Venturi Scrubbers
Electrostatic precipitators
Fan systems
Ductwork


Pump systems

Tanks

Temperature control loops


Insulation

Stacks

Dry and wet grinding systems
American Air Filter
Flex-Kleen, Inc.
Standard-Havens
Fisher-Klostermann
Sly Equipment Mfg.
Air-Pro., Inc.

Sly Equipment Mfg.
Fisher-Klostermann
Card Cost Manual6

Members of Industrial Gas
 Cleaning Institute11

Twin City Fans
Air-Pro., Inc.
Buffalo-Forge
PEDCo Files

Means Cost Data
PEDCo Files

Ingersoil-Rand

Chemical Engineering

Leeds and Narthrup
 1976-77 Catalogue

Kramig Co., Cincinnati

Card Cost Manual6

Kennedy Von Saun
                             4-7

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       Table 4-4.  DIRECT COST COMPONENTS USED IN

              COMPUTING INSTALLED COSTS1'2'3
   Base equipment
   Fabric filters

   Electrostatic precipitators

   Venturi scrubbers

   Hold tanks

   Ductwork

   Fan systems

   Pump systems

   Stacks
Direct cost factor'
        2

        2

        3

        2

        2.6

        2.5

        3.5

        1.5
   Components included in direct costs are equipment,
   instrumentation, piping, electrical, foundations,
   structures, sitework, insulation, and painting.


Multiply direct cost factor by base equipment price to
obtain material and labor costs for direct field erection
costs.  Installation factors were obtained from Chemical
Engineering Magazine, Perry's Handbook, IGCI, and PEDCo
Environmental.
                           4-8

-------
     Indirect Costs - Table 4-5 shows the Indirect cost com-

ponents as a percent of total direct costs.  Total indirect

costs amount to about 36 percent of the total direct costs

and include engineering, field labor and expenses, con-

tractor's fees, freight, offsite, spares, taxes, and shake-

down.

        Table 4-5.  INDIRECT COST COMPONENTS USED IN

                 COMPUTING INSTALLED COSTS1'2'3
Item
Engineering
Field labor and expenses
Contractor's fee
Freight
Offsite
Spares
Taxes
Shakedown
Total indirect costsa
Percent of direct cost
10
10
5
1.3
3
0.5
1.5
5
36.3
  Production losses and interest during construction and
  research and development costs are not included.

     Contingencies - To determine the total capital cost,

the sum of the direct and indirect cost is multiplied by a

contingency factor.  Contingencies include unforeseen costs

attributable to omissions and field changes, inclement
                             4-9

-------
weather, strikes, delayed shipments, material shortages,
price increases, breakage, and additional material require-
ments.  The contingencies are generally between 10 and 30
percent of the indirect and direct costs.  Therefore, a
contingency cost of 20 percent of the total direct and
indirect cost (contingency factor of 1.2) is assumed to be
typical.
     Retrofit Factors - To obtain capital costs for an
existing plant,  the total capital costs for a new plant are
multiplied by a retrofit factor.  Retrofit factors can only
be determined for site-specific cases where actual plant
layouts, plot plans, building designs, and other information
are available.  A meaningful retrofit factor cannot be
developed on a generalized basis.
     To illustrate, consider a plant in which the existing
ductwork, fan, and stack are suitable for use in the pro-
posed control system.  The overall costs would be lower than
for a new plant installation.  One company completely
replaced a fabric filter and estimated that the total cost
could be up to 40 percent lower, using existing ductwork and
supports, than a completely new installation.   This situ-
ation would be common in the phosphate rock industry since
some degree of dust control has already been implemented by
most plants.
                             4-10

-------
     In contrast, consider a process that requires a com-



pletely new control system (.including fan, ductwork, and



stack), structural modifications, removal of existing



controls, extra long duct runs, and additional labor for



site preparation.  The overall capital costs would be con-



siderably higher than for a new plant installation.  One



equipment manufacturer has estimated retrofitted costs to be



an additional 10 to 15 percent of the capital costs for a



new plant installation.   These costs could be as high as 50



percent of the total capital.  The retrofit factor is



assumed to be 1.2 for the purposes of this cost analysis and



represents the typical additional costs for a completely new



control system retrofitted on an existing plant.



     Total Installed Costs - The total installed costs for



retrofitted systems on existing processes are determined by



multiplying the individual equipment costs by the respective



direct cost factor (Table 4-4).  The summation of the direct



equipment costs are multiplied by an indirect cost factor of



1.363  (Table 4-5), a contingency factor of 1.2, and a retro-



fit factor of 1.2.  Collectively, the total direct cost can



be multiplied by 1.96 to account for indirect, retrofit, and



contingency costs.



4.1.5  Bases for Annualized Cost Estimates



     Annualized costs developed in this chapter include



utilities, operating labor, maintenance, and fixed costs
                                4-11

-------
(including annualized capital charges).   Product recovery



credits are included for the grinder fabric filter option



only; dust recovered from other processes has little value



and is usually discarded in the tailings pond.  Costs are



not included for operation of sludge or  wastewater treatment



and disposal equipment since these facilities are normally



available and no significant increases in waste handling



requirements are expected.  The annualized costs do not



include return-on-investment and production losses resulting



from breakdown and maintenance of control equipment.  Adjust-



ments for geographical area and other site-specific factors



can also be made where necessary.



     Table 4-6 gives the cost factors used in computing



total annualized costs.  When site-specific information is



available, it can be substituted for the assumed values



shown.



4.2  DRYING



4.2.1  Model Process Parameters



     Three typical dryer capacities were selected for the



basis of the control cost analysis shown in Table 4-7.  For



multiple parellel configurations, separate control systems



are generally installed.  For the purposes of estimating the



annual operating costs, these systems are assumed to operate



80 percent of the time, or about 7000 hours per year.
                                4-12

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        Table 4-6.   COST COMPONENTS USED IN COMPUTING

                      ANNUALIZED COSTS
   I.     Operating factor

  II.     Utilities
          Electricity
          Water

 III.     Operating labor

          Direct labor
          Supervision

  IV-     Maintenance
          Labor and materials

          Replacement parts
   V.    Fixed costs
          Annualized capital
           charges^

          Taxes, insurance,
           administration,
           plant overhead,
           miscellaneous^

  VI.    Solid waste disposal

 VII.    Wastewater treatment

VIII.    Product recovery credit
                                             80%'
                                        $0.03/kWh
                                        $0.25/1000 gal

                                        $10/man-hour

                                   0.1 to 0.3 man-hour/h operation
                                             15% Direct
                                   2%(ESP),  4%(FF),  8%(VS)  of
                                     installed cost
                                   5% installed cost (FF)
                                     3% installed cost (VS  and ESP)
                                   13.2% Installed cost (FF and ESP)
                                   16.3% Installed cost (Scrubber)c
                                      4% Installed cost

                                            0

                                            0
                                        $20/ton
                                               8
a
  Most processes operate 80% of the time (7000 h/yr);
  however,  some may operate less.
  Labor requirements vary with size and type of equipment.

  Equipment life (ESP and FF)  is assumed to be 15 years and
  compounded interest,  10%.  Equipment life of scrubber
  is assumed to be 10 years.

  Grinding  operation only.
                             4-13

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     Table 4-7.  CHARACTERISTICS OF PHOSPHATE ROCK DRYER

                 EXHAUST GASES AND EMISSIONS

                         (SI units)
Production rate, Mg/h
Throughput rate, Mg/ha
Exhaust flow rate, m /s
Temperature, °K
Moisture content, %vol. -.
Dust loading, g/dry std. m
Emission rate, kg/hc
Outlet emissions, kg/h
SIP d'e
1
siP2f'g
AELh
Required efficiency, %1
SIPI
SIP2
AEL
45
50
11
394
25
12
256

21.4

15.0
2.1

91.7
94.1
99.4
181
200
44
394
25
12
1024

26.8

18.6
8.2

97.4
98.2
99.4
272
302
66
394
25
12
1534

29.1

20.0
12.2

98.1
98.7
99.4
a

b

c


d

e



f

g



h

i
Assumed a 10 percent weight loss during drying.
                               3  —1     —1
Based on an average 0.18 std. m -s  /Mg-h   product.

Calculated from 12 g/dry std. m , generally a high
dust loading.

Regulation for all states except Florida (see Appendix B).

Mass emissions at^IP-]^ levels correspond to 1.0, 0.31, and
0.23 g/dry std. m  for the small, medium, and large model
dryers, respectively.

Florida regulation for existing sources  (see Appendix B).

Mass emissions at SIP2 levels correspond to 0.71, 0.22, and
0.16 g/dry std. m3 for the small, medium, and large model
dryers, respectively.

Based on AEL of 0.07 g/dry std. m3 for dryers.

Calculated from the above data and may vary significantly
from one dryer operation to another.
                             4-14

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    Table 4-7a.
CHARACTERISTICS OF PHOSPHATE ROCK DRYER
EXHAUST GAS AND EMISSIONS
      (English units)
Production rate, tons/h
Throughput rate, tons/ha
Exhaust flow rate, acfm
Temperature, °F
Moisture content, % vol.
Dust loading, gr/dscf
Emission rate, lb/hc
Outlet emissions, Ib/hr
SIP*'*
SIP2f'g
AElJ1
Required efficiency, %1
SIPn
1
SIP2
AEL
50
56
23,400
250
25
5
563

47
33
4.5

91.7

94.1
99.4
200
222
93,500
250
25
5
2,252

59
41
18

97.4

98.2
99.4
300
333
140,000
250
25
5
3,375

64
44
26.9

98.1

98.7
99.4
  Assumed a 10 percent weight loss during drying.
b Based on an average 350 scfm per ton/hr product.
c Calculated from 5 gr/dscf generally a high dust loading.
d Regulation for all states except Florida (see Appendix B).
6 Mass emissions at SIP^ levels correspond to 0.42,  0.13, and
  0.10 gr/dscf for the small, medium, and large model dryers,
  respectively.
f Florida regulations for existing sources (see Appendix B).
g Mass emissions at SI?2 levels correspond to 0.30,  0.090, and
  0.065 gr/dscf for the small, medium, and large model dryers,
  respectively.
h Based on AEL of 0.031 gr/dscf for dryers.
1 Calculated from the above data and may vary significantly
  from one operation to another.
                                4-15

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     The exhaust gas characteristics and required control



efficiency are shown in Table 4-7 for the three emission



levels:  AEL, SIP-^ and SIP2.  Alternative control tech-



niques for which costs are developed are the venturi scrub-



ber, fabric filter, and electrostatic precipitator.



A.   Fabric Filter



     Pulse-jet fabric filters, which operate at a system



pressure drop of about 1 kPa (4 in.  WG)  and filtering



velocity of 3 cm/s (6 ft/min), were selected.  Polypropylene



bags are recommended.  A temperature control system should



be included in the design to prevent overheating or  con-



densation, a serious problem encountered on this applica-



tion.  The temperature control system consists of tempera-



ture detectors, a transmitter, a position adjusting  con-



troller, a chart recorder, a valve-drive mechanism,  and an



alarm.  Mineral wool insulation with aluminum casing will be



provided for the ductwork and fabric filter housing  to



prevent excessive temperature drop and maintain the  tempera-



ture at 28°C (50°F) above the dew point.  The fabric filter



inherently achieves very high collection efficiencies (99%+),



hence no cost differentiation can be made between the three



control levels.  System components included in capital costs



are fabric filter, fan system, stack, ductwork, expansion



joints, damper, insulation, and temperature control  system.
                              4-16

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B.   Venturi Scrubber


     Costs were estimated for a venturi scrubbing system to


achieve the three control levels for each model dryer.


Accurate particle size data must be available to predict the


relationship between pressure drop and collection effici-


ency.  Moreover, efficiency and pressure drop requirements


vary significantly from one dryer to another because of the


variation in inlet dust, loading, as well as the particle


size.  Tests on two dryer scrubbing systems indicated a 3kPa


(12 in. WG) pressure drop would achieve a 91 percent effici-


ency and a 7.5 kPa (30 in. WG) pressure drop would achieve a

                        q
96.2 percent efficiency.


     For the purposes of estimating capital and annualized


costs and to differentiate between the cost of the three


control levels, it is assumed that a venturi pressure drop


of 3.8 kPa (15 in. WG), 5 kPa (20 in. WG), and 7.5 kPa (30


in. WG) will generally achieve emission levels designated

                                     9
by SIP,, SIP2, and AEL, respectively.


     An increased design pressure drop across a scrubber


will increase the capital cost of the complete system by  (1)


increasing the cost of the fan system (higher power require-


ments)  and (2) increasing the costs of the ductwork and


venturi (extra thickness for additional strength).  The


capital cost increase for an additional 1 kPa (4 in. WG)
                              4-17

-------
pressure drop is insignificant;  however, the incremental



capital costs become significant when design pressure drops



are increased by 3 to 5 kPa (12  to 20 in. WG).



     Increases in pressure drop  directly affect annual costs



mainly because of increased power costs.  For example, if



the pressure drop is doubled,  the power costs are also



doubled.  This can significantly affect the annual operating



costs.  An increase in fixed charges (and other annual cost



components, which are dependent  on capital investment)



will also increase annualized costs.



     System components include the venturi scrubber, fan



system, dampers, expansion joints, ductwork, stack, reten-



tion tank, and pump.  A stainless steel venturi, ductwork,



and fan may be necessary when sulfur dioxide content of the



exhaust gases is high because of combustion of  sulfur-



bearing fuel oil in the dryer furnace.



C.   Electrostatic Precipitator



     Design and cost estimations of electrostatic precipita-



tors are more difficult than for fabric filters and wet



scrubbers, since the size of the unit depends on particulate



drift velocity, which is not a well-quantified  value.



     One actual ESP installation on a phosphate rock dryer



was designed for 90 percent particulate removal at 88.3 m3/s



(187,000 acfm).  The total ESP plate area was 4700 m2
                             4-18

-------
          2
 (50,600 ft ), corresponding to a particle drift velocity of

4.3 cm/s (8.5 f t/min) .    This calculated drift velocity

will vary from one dryer to another depending mainly on the

composition of the dust, temperature, and moisture content.

However, this velocity will be used for the basis of sizing

the ESP's on the model dryers.

     The plate area required for each flow rate and effi-

ciency  (Table 4-7) is calculated by the following equation:


          A = - & In (1 - n)

     where w = drift velocity, 0.043 m/s (8.5 ft/min)
           Q = gas flow rate, m^/s (acfm)
           n = fractional efficiency
           A = plate area, m^ (ft^)

     A direct relationship occurs between the plate area and

the base purchase price of the ESP.  ESP costs, which repre-

sent flange-to-flange costs, are based on vendor quotations.

     Equipment items included in the capital cost estimates

are the ESP, hopper, screw conveyor, transformer, rectifier,

fan system,  ductwork, insulation, and stack.

4.2.2  Control Costs

     Tables 4-8 through 4-10 summarize control costs for

each control alternative and emission level for each model

dryer.  These costs represent those for retrofitted systems

only.
                               4-19

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    Table 4-8.  CAPITAL AND ANNUAL CONTROL COSTS FOR

           FABRIC FILTERS SERVING MODEL DRYERS
Capacity, Mg/h (tons/h)
Volume, m3/s (10^ acfm)
Temperature, °K (°F)
Equipment cost
Direct cost
Indirect cost
Contingency cost
Retrofit cost
Total capital costa
Direct operating cost
Annual capital charges
Total annual costa
Cost-effectiveness , C /kg ( C/lb
46 (50)
11 (23.4)
394 (250)
65
129
47
35
42
253
46
44
90
)b 5.1(2.3)
181 (200)
44 (93.5)
394 (250)
192
384
139
105
126
754
123
130
253
3.5(1.6)
272 (300)
66 (140)
394 (250)
290
580
211
158
190
1139
173
196
369
3.5(1.6)
Carbon steel construction.   For stainless steel construction,
multiply capital costs by 1.95 and annual costs by 1.60.

Calculated at AEL control,  99.2 percent efficiency.
                             4-20

-------
           Table 4-9.
CAPITAL AND ANNUAL CONTROL COSTS FOR VENTURI SCRUBBING SYSTEMS
              SERVING MODEL DRYERS
                                    ($io3,
                    4th qtr. 1977)
Capacity, Mg/h (tons/h)
Volume, m3/s (103 acfm)
Temperature, °K (°F)
Equipment cost
Direct cost
Indirect cost
Contingency cost
Retrofit cost
Total capital costa
Direct operating cost
Annual capital
charges
Total annual costs
Cost-effectiveness, C/kg
(C/lb) pollutant
removed
45 (50)
11 (23.4)
394 (250)
SIP-L
60
130
47
36
43
256
65
52
117
7.0
(3.2)
SIP2
63
136
48
37
45
266
70
54
124
7.3
(3.3)
AEL
68
148
54
41
49
291
83
59
142
7.9
(3.6)
181 (200)
44 (93.5)
394 (250)
SIP-L
140
321
115
89
105
630
170
128
298
4.2
(1.9)
SIP2
161
370
133
101
122
726
200
147
347
4.8
(2.2)
AEL
182
419
151
115
138
823
250
167
417
5.9
(2.7)
272 (300)
66 (140)
394 (250)
SIP^
204
484
174
133
159
950
249
193
442
4.2
(1.9)
SIP2
220
521
188
143
171
1023
286
208
494
4.6
(2.1)
AEL
251
595
214
165
196
L168
361
237
598
5.7
(2.6)
I
NJ
          Carbon steel construction.  For complete stainless steel construction, multiply
          capital costs by 2.65 and annual costs by 2.1.

-------
          Table 4-10.
CAPITAL AND ANNUAL COSTS FOR ELECTROSTATIC PRECIPITATOR SYSTEMS

              SERVING MODEL DRYERS
                                    ($103/
                    4th qtr.  1977)
Capacity, Mg/h (tons/h)
Volume, m3/s (103 acfm)
Temperature, °K (°F)
Control level
Equipment cost
Direct cost
Indirect cost
Contingency cost
Retrofit cost
Total capital costa
Direct operating cost
Annual capital
charges
Total annual costs
Cost-effectiveness, C/kg
(C/lb) pollutant
removed
45 (50)
11 (23.4)
394 (250)
SIP..
283
563
203
155
185
1105
99
190
269
16.3
(7.4)
SIP2
293
583
210
160
192
1145
81
197
278
16.5
(7.5)
AEL
353
703
253
194
231
1380
97
237
334
18.7
(8.5)
181 (200)
44 (93.5)
394 (250)
SIP-j^
556
1107
399
304
363
2173
167
374
541
7.7
(3.5)
SIP2
578
1147
413
315
375
2250
175
387
562
7.9
(3.6)
AEL
606
1207
345
332
396
2370
185
408
593
8.4
(3.8)
272 (300)
66 (140)
394 (250)
SIP..
670
1335
481
368
437
2621
217
451
668
6.4
(2.9)
SIP2
690
1375
495
378
452
2700
225
464
689
6.6
(3.0)
AEL
710
1415
508
389
466
2778
233
478
711
6.6
(3.0)
I
ro
            Carbon  steel  construction.   To  estimate costs for stainless steel construction,
            multiply capital  costs  by  3  and annual costs by 2.8,

-------
A.   Fabric Filter



     Table 4-8 summarizes capital and annualized costs for



fabric filter systems.  There is no differentiation between



degree of control, since fabric filters will inherently



maintain a very high collection efficiency.  For this pur-



pose it is assumed to maintain an efficiency of 99.2 per-



cent, corresponding to AEL control.  The costs are graphi-



cally illustrated in Figure 4-1 and are plotted as costs



versus flow rate to allow cost estimating for site-specific



cases.  If stainless steel construction is required, capital



costs are multiplied by a factor of 1.95 and annualized



costs are multiplied by a factor of 1.60.



B.   Venturi Scrubber



     Table 4-9 summarizes capital and annualized costs for



venturi scrubbing systems.  Significant increases in costs



occur as pressure drop (efficiency) increases.  Capital



costs are shown as a function of flow rate in Figure 4-1 to



allow cost estimating for site-specific cases.  Other cap-



ital cost estimates are compared to those generated in this



report.  To obtain costs for stainless steel construction,



multiply capital costs by 2.65 and annualized costs by 2.1.



C.   Electrostatic Precipitator



     Table 4-10 summarizes the control costs for electro-



static precipitators on the model dryers.  Costs increase



moderately with efficiency (plate area).  Capital costs are
                               4-23

-------
shown as a function of flow rate in Figure 4-1 to allow cost


estimating for site-specific cases.  The capital costs


generated by this study are compared with other cost esti-


mates in Figure 4-1.  To obtain costs for stainless steel


systems, multiply capital costs by 3.0 and annualized costs


by 2.8.


4.2.3  Cost-effectiveness


     The cost-effectiveness of the control alternatives can


be expressed in terms of cost per unit weight of pollutant


removed.  Tables 4-8 through 4-10 indicate the cost-effec-


tiveness for each application.  Figure 4-2 shows the varia-


tion of cost-effectiveness with the size of control system


and process.  This plot applies only to the model processes


and is not suitable to estimate costs for specific cases.

                          ^
     Fabric filtration is the most cost-effective alterna-


tive if maintenance costs can be kept low; however, its


technical feasibility has been questioned by many operators


(see Section 3.4.3).  The most probable control alternative


is the venturi scrubber, for which costs increase moderately


with level of control.  Electrostatic precipitators are far


more expensive, except for the large dryer at the most


stringent control level.  Here, ESP's may be economically


attractive, especially when high pressure drops [7 to 10 kPa


(30 to 40 in. WG)}  are required for scrubbers.  This is
                              4-24

-------
              4000


              3000
    2000

 |  1500

 iJ
 ••  1000
 f
 *  800 £,'
"k
 ~  600-
 £  500
 g
 "  400h

 £  300
               100H
                                                     FABRIC FILTER
                                   VENTURI  SCRUBBER
                                                 4
                                             ss r«*B
                             10
                        15  20
                      EXHAUST VOLUME, nT/s
           30 340  ^T^ii   80  l6o
                  I
                            \
                                  I
                                       I   I   I
                 10
30  40  50 607080
                                    708090
WT
                                EXHAUST VOLUME. 10J acfm

                  OTHER COST ESTIMATES FOR NEW PLANTS

                  O - VENTURI SCRUBBER
                     A - IGCI ESTIMATE
                     B - IGCI ESTIMATE
                     C - SIMPLOT INC. ENTROLETOR SCRUBBER
                     D - MOBIL CHEMICAL CO.

                  D - ELECTROSTATIC PRECIPITATOR
                     E - W.R. GRACE, 90% EFFICIENT (RETROFIT)

                  A - FABRIC FILTER
                     F - IGCI ESTIMATE
Figure  4-1.   Capital costs for  control  alternatives  for

                       dryers and  calciners.
                                     4-25

-------
                      DRYER CAPACITY, Mg/h
i
UJ
O
D-
£}

-«.
I/)
O
O


1ft
1 U
9
8
7

6

5

4

3
2.5


2


1.5




2
50 75 100 150 200 300
1 II 1 ' '
DRYER CAPACITY, TPH
50 75 100 150 200 300
i ii | i i
- ,.EL
- ,.**'\2
~SIPi';;'*:;... ***••..
1 **•*•• **•
**••*;••. ***••. ESP
***^**» ***•
****•*.*••?**••.
*••**•» *•• ~
'*':::%>x

S!PT *
Ul
z
r- UJ
6 >
i— i
H-
<_>
5 ^
J u.
U_
LU
1—
4 g
0

3
cT



                    EXHAUST VOLUME, 10  acfm
 Figure  4-2.   Cost effectiveness of  control alternatives

                      for model dryers.
                               4-26

-------
indicated by the ESP cost-effective curve approaching the



curve for scrubbers in Figure 4-2.



4.3  CALCINING



     Three model calciners were selected for the control



cost analyses as shown in Table 4-11.  Control systems for



calciners are identical to those for dryers.  Hence, control



costs for a specific exhaust volume will also be identical.



Figure 4-1 is used to estimate control costs for calciners.



4.3.1  Model Process Parameters



     Exhaust gas characteristics and required control



efficiency are shown in Table 4-11 for the three control



levels.  Alternative control techniques for which costs are



developed are the venturi scrubber, fabric filter, and



electrostatic precipitator.  Emissions from calciners are



similar to those of dryers.  Control costs are identical to



those for dryers based on exhaust volume.  Therefore no



additional discussion of control system design parameters is



necessary.



4.3.2  Control Costs



A.   Fabric Filter



     Table 4-12 shows annualized and capital costs for the



fabric filter systems serving the model calciners.  For



stainless steel construction, capital costs are multiplied



by a factor of 1.95 and annualized costs are multiplied by
                              4-27

-------
    Table  4-11.   CHARACTERISTICS OF MODEL CALCINER EXHAUST
                    GASES- AND EMISSIONS
                        (SI units)
Production rate, Mg/h.
Throughput rate, Mg/ha
Exhaust flow rate, m /s
Temperature, °K
Moisture content, %vol. ->
Dust loading, g/dry std. m
Emission rate, kg/hc
Outlet emissions, kg/hr
SIP^'6
SIP f'g
AELh
Required efficiency, %1
SIPI
SIP2
AEL
18
20
9.5
394
25
12,
219

14.5
10.9
1.4

93.4
95.0
99.4
41
45
21.4
394
25
12
493

19.1
14.1
3.2

96.1
97.1
99.4
64
71
33.2
394
25
12
767

21.8
15.9
4.5

97.2
97.9
99.4
a
b
c
d
e

f
g
Assumed 10 percent weight loss during calcining.
Calculated at 0.39 wet std.  m •s~ /Mg-h~  product; gases
are cooled to 394°K by a process heat exchanger.
Calculated from 12 g/dry std. m  and 25% vol. moisture.
Regulation for all states except Florida (see Appendix B).
Mass emissions for SIP-L levels correspond to 0.79, 0.47, and
0.34 g/dry std. m3 for small, medium, and large calciners,
respectively.
Florida regulations for existing sources (see Appendix B).
Mass emissions for SIP2 levels correspond to 0.60, 0.35, and
0.25 g/dry std. m3 for small, medium, and large calciners,
respectively.
Based on AEL  of 0.07 g/dry std. m3 for calciners.
Calculated from the above data and may vary significantly
from one operation to another.
                              '-28

-------
 Table  4-lla.
CHARACTERISTICS OF MODEL CALCINER EXHAUST
   GASES AND EMISSIONS
     (English units)
Production rate, tons/h
Throughput rate, tons/h
Exhaust flow rate, acfm
Temperature , ° F
Moisture content, % vol.
Dust loading, gr/dscf
Emission rate, lb/hc
Outlet emissions, Ib/h
SIP d'e
SIP2f'g
AELh
Required efficiency, %^~
SIP-L
SIP2
Wfe
20
22
20,100
250
25
5
482

32
24
3

93.4
95.0
99.4
45
50
45,200
250
25
5
1085

42
31
7

96.1
97.1
99.4
70
78
70,300
250
25
5
1688

48
35
10

97.2
97.9
99.4
Assumed 10 percent weight loss during calcining.
Calculated at 750 scfm per tons/h product; exhaust gases
are cooled to 250 °F by aftercooler.
Calculated from 5 gr/dscf and 25% vol. moisture.
Regulation for all states except Florida  (see Appendix B) .
Mass emissions for SIPi levels correspond to 0.33, 0.20, and
0.14 gr/dscf for small, medium, and large calciners,
respectively.
Florida regulations for existing sources (see Appendix B) .
Mass emissions for SIP2 levels correspond to 0.25, 0.15, and
0.10 gr/dscf for small, medium, and large calciners,
respectively.
Based on AEL  of 0.031 gr/dscf for calciners.
Calculated from the above data and may vary significantly
from one operation to another.
                             4-29

-------
Table 4-12.  CAPITAL AND ANNUAL COSTS FOR FABRIC FILTER
            SYSTEMS SERVING MODEL CALCINERS

                   ($103, 4th qtr. 1977)
Capacity, Mg/h (tons/h)
Exhaust volume, m /s
(103 acfm)
Temperature, °K (°F)
Equipment costa
Direct cost
Indirect cost
Contingency cost
Retrofit cost
Total capital costa
Direct operating cost
Annual capital charges
Total annual cost
Cost-effectiveness, C/kg
(C/lb) pollutant removed
18 (20)
9.5 (20.1)
394 (250)
57
113
41
31
37
222
42
38
80
5.3 (2.4)
41 (45)
21.3 (45.2)
394 (250)
113
225
81
61
73
440
69
76
145
4.2 (1.9)
63 (70)
33.2 (70.3)
394 (250)
160
320
117
88
105
630
102
108
210
4.0 (1.8)
Carbon steel construction.   For stainless steel construction
multiply capital costs by 1.95 and annual costs by 1.60.
                           4-30

-------
1.6.  Figure 4-1 graphically illustrates the variation of
calciner control costs with the exhaust volumetric rate.
B.   Venturi Scrubbers
     Table 4-13 shows the capital and annualized costs for
the venturi scrubbing systems serving the model calciners.
Note the moderate increase in costs as the pressure drop
(efficiency) increases.  To estimate costs for complete
stainless steel construction, multiply the capital costs by
2.65 and the annualized costs by 2.1.  In Figure 4-1 capital
costs are plotted as a function of exhaust flow rate.
C.   Electrostatic Precipitators
     Table 4-14 shows the capital and annualized costs for
the ESP systems serving the model calciners.  Note the
increase in capital costs as the efficiency (ESP plate area)
increases.  ESP systems are far more expensive than fabric
filters or venturi scrubbers.  To estimate control costs for
stainless steel construction, multiply the capital costs by
a factor of 3.0 and the annualized costs by 2.8.  Figure 4-
1 illustrates the ESP capital costs as a function of exhaust
flow rate.
4.3.3  Cost-effectiveness
     The cost-effectiveness curves for each control alterna-
tive are shown in Figure 4-3.  Fabric filtration is the most
cost-effective control method.  ESP's are far less cost
                               4-31

-------
             Table  4-13.
CAPITAL AND ANNUAL COSTS FOR VENTURI SCRUBBING SYSTEMS

        SERVING MODEL CALCINERS

                 4th qtf.  1977)
                                    ($103,
Capacity, Mg/h (tons/h)
Volume, m3/s (1Q3 acfm)
Temperature, °K (°F)
Control level
Equipment cost
Direct cost
Indirect cost
Contingency cost
Retrofit cost
Total capital cost
Direct operating cost
Annual capital
charges
Total annual costs
Cost-effectiveness, C/kg
(C/lb) pollutant removed
18 (20)
9.5 (20.1)
394 (250)
SIP1
98
107
39
29
35
210
57
43
100
7.0
(3.2)
SIP2
111
122
44
33
41
240
66
499
115
7.9
(3.6)
AEL
121
134
48
36
43
263
77
53
130
8.6
(3.9)
41 (45)
21.3(45.2)
394 (250)
SIPI
173
194
70
53
63
380
103
77
180
5.5
(2.5)
SIP2
200
224
81
61
74
440
111
89
200
5.9
(2.7)
AEL
268
301
108
82
99
590
113
120
233
6.8
(3.1)
63 (70)
33.2 (70.3)
394 (250)
SIP,
240
276
100
75
89
540
140
110
250
4.8
(2.2)
SIP2
271
311
112
85
102
610
156
124
280
5.3
(2.4)
AEL
307
352
127
96
115
690
190
140
330
6.2
(2.8)
.fc-
I
00
       Carbon steel construction.  To estimate costs for  stainless  steel  construction,  multiply
       capital costs by 2.65 and annual costs by 2.1.

-------
               Table 4-14.
CAPITAL AND ANNUAL COSTS FOR ELECTROSTATIC PRECIPITATORS

         SERVING MODEL CALCINERS

          ($103, 4th qtr. 1977)
Capacity, Mg/h (tons/h)
Volume, m-vs (103 acfm)
Temperature, °K (°F)
Level of control
Equipment cost
Direct cost
Indirect cost
Contingency
Retrofit cost
Total capital cost
Direct operating cost
Annual capital charges
Total annual cost
Cost-effectiveness, C/kg
(£/lb) pollutant removed
18 (20)
9.5 (20.1)
394 (250)
SIP-j^
268
535
195
145
175
1050
79
181
260
18.3
(8.3)
SIP2
280
560
203
152
185
1100
81
189
270
18.5
(8.4)
AEL
338
662
240
180
218
1300
96
224
320
20.9
(9.5)
41 (45)
21.3 (45.2)
394 (250)
SIP^
382
764
277
208
251
1500
117
258
375
11.2
(5.1)
SIP2
408
816
296
222
268
1600
120
275
395
11.7
(5.3)
AEL
458
917
333
249
301
1800
130
310
440
12.8
(5.8)
63 (70)
33.2 (70.3)
394 (250)
SIP^
424
968
351
263
218
1900
138
327
465
9.0
(4.1)
SIP2
509
1019
270
277
334
2000
141
344
485
9.0
(4.1)
AEL
548
1095
397
298
360
2150
160
370
530
9.9
(4.5)
I
CO
U)
    a Carbon steel construction.  To estimate costs for stainless steel construction, multiply
      capital costs by 3 and annual costs by 2.8.

-------
 10
CALCINER CAPACITY, Mg/ih
   20       30     40    50   60     80


o
LU
o
LU
0
O
t—
t—
1
2
.a
•t*
oo
iii
z
LU
i— i
O
1 1 1
LI-
LI-
LU

!/>
0







CALCINER CAPACITY, TPH
10
9
8
7
6
5

4



3

2r
.5



2




1 5
10 20 30 40 50 60 80
i AEL"*V ' iii i
CTD*« ***«
*'*•••. *\
\\ESP
**• ***
* *•
""••£>-,
\:-*.. -
AEL< '•••.::
SIP>_^^-^ VENTURI SCRUBBER
£. ^^^ ^ * ^^
C T D * ^^ ^^ * ^^
^^ * ^fc- ^^ * ^ * ^^
— ^^ % ^ ^^ % ^^*i » ^^
^" * ^^ ^^ * * ^** • A«
ALL CONTROL%X((^ %^"^*>r^-^

^^^^^^^ ^^ * -•_ ^* '
^^^^^^^•^ ^^ 4§^^
^^^^^^^^^ ^^ •
_ ^^^^^^^^^^
FABRIC FILTERS ' 	 ^
• __


i i i i i i i
22
20
18 S
16 tJ
14 g
^ I
10 d
a.
01
8 $

to

LU
6 Ul
J^
5 o
LU
U_
LJ_
LU
4 £
0
O

5 10 15 20 25 30 40
EXHAUST VOLUME, m3/ s
i i i ii i i i i i i i
10 15 20 25 30 40 50 60 70 80 90100
               EXHAUST VOLUME, 103 acfm
Figure 4-3.   Cost-effectiveness curves  for

 calciner  emission control  alternatives.
                      4-34

-------
effective as scrubbing and fabric filtration except for very



large calciners.  This is indicated by the ESP curve approach-



ing the scrubber curve for large capacities.  ESP cost-



effectiveness for SIP. and SIP- control levels is essen-



tially the same.  These curves are for the model calciners



only and are not suitable for cost estimating for specific



cases.



4.4  GRINDING



4.4.1  Model Process Parameters



     Three model grinders were chosen for the control cost



analysis as shown in Table 4-15.  Exhaust gas characteris-



tics and required emission levels are shown in Table 4-15.



The alternative control techniques for which costs are



developed are the fabric filter and venturi scrubber.



A.   Fabric Filter



     Pulse-jet fabric filters/ which operate at a filtering



velocity of 3 cm/s (6 ft/min) and a pressure drop of 1 kPa



(4 in. WG), were selected to control emissions.  Polyester



or polypropylene bags are suitable for this application.



The temperature rarely exceeds 310°K (100°F); however,



exhaust moisture content can be a potential problem in some



situations.  No temperature control system or insulation is



required.   The fabric filter inherently achieves very high



collection efficiencies (99+ percent);  hence, no cost dif-



ferentiation can be made between the three levels of control.
                               4-35

-------
Table 4-15.  CHARACTERISTICS OF EXHAUST GAS AND EMISSIONS
           FROM MODEL PHOSPHATE  ROCK GRINDERS
                       (SI units)
Production rate, Mg/h
Throughput rate, Mg/h
3 a
Exhaust flow rate, actual m /s
Temperature , ° K
Moisture content, % vol. ,
Dust loading, g/dry std. m
Emission rate, kg/hb
Outlet emissions, kg/hb
SIP^'6
siP2e/f
AELg
h
Required efficiency, %
SIP-j^
SIP2
AEL
45
45
2.6
322
5
12
92.7

20
14.5
0.26


78.4
84.3
99.7
91
91
5.2
322
5
12
185

22.7
16.4
0.56


87.7
91.2
99.7
136
136
7.8
322
5
12
278

25
17.3
0.8


91.2
93.8
99.7
                                    3  -1
-1
Based on an average 0.052 dry std. mJ-s ^/Mg-h * product.
Calculated from dust loading and exhaust flow rate.
Based on least stringent regulation (see Appendix B).
Mass emissions for SIPj_ levels correspond to 2.60, 1.48, and
1.06 g/dry std. m3 for small, medium,  and large grinders,
respectively.
Based on most stringent regulation (see Appendix B).
Mass emissions for SIP2 levels correspond to 1.88, 1.06, and
0.74 g/dry std. m3 for small, medium,  and large grinders,
respectively.
Based on AEL of 0.03 g/dry std.  m  for grinders.
Efficiency required may vary significantly from one operation
to another.
                            4-36

-------
Table 4-15a.  CHARACTERISTICS OF EXHAUST GAS AND EMISSIONS
            FROM MODEL PHOSPHATE ROCK GRINDERS
                      (English units)
Production rate, tons/h
Throughput rate, tons/h.
Exhaust flow rate, acfma
Temperature , ° K
Moisture content, % vol.
Dust loading, gr/dscf
Emission rate, lb/hk
Outlet emissions, Ib/h
SIP.,,0'3
siP2e'f
AEL5
•L.
Required efficiency, %
SIPI
SIP2
AEL
50
50
5,500
120
5
5
204

44
32
0.58

78.4
84.3
99.7
100
100
11,000
120
5
5
408

50
36
1.16

87.7
91.2
99.7
150
150
16,500
120
5
5
612

54
38
1.75

91.2
93.8
99.7
 Based on an average 100 scfm per ton/hr product.
 Calculated from dust loading and exhaust flow rate.
 Based on least stringent regulation (see Appendix B).
 Mass emissions for SIPj levels correspond to 1.08,  0.62,  and
 0.44 gr/dscf for small, medium,  and large grinders,  respectively.
 Based on most stringent regulation (see Appendix  B).
 Mass emissions for SIP2 levels correspond to 0.78,  0.44,  and
 0.31 gr/dscf for small, medium,  and large grinders,  respectively.
 Based on AEL of 0.013  gr/dscf for grinders.
 Efficiency required may vary significantly from one  operation
 to  another.
                             4-37

-------
System components in the equipment cost include the fabric




filter, ductwork, fan system, damper, and stack.




B.   Venturi Scrubber



     Venturi scrubbing systems for grinding facilties are



essentially the same for dryers and grindings, however, no



insulation or temperature control system is required.  No



credits for the dust collected can be accounted since the



dust is in a slurry form.  Components included in the equip-



ment costs are the venturi scrubber, tank,  pump, fan system,



ductwork, venturi throat, and stack.



4.4.2  Control Costs



     In estimating the control costs for the fabric filter



and venturi scrubbing systems, no costs were assumed to be



associated with wastewater treatment or solid waste dis-



posal.  An annual operating time of 7000 hours is assumed.



A.   Fabric Filter



     Table 4-16 shows the capital and annualized costs for



the fabric filter systems serving the model grinders.  A



product recovery credit of $22/Mg ($20/ton)  of dust col-



lected is applied, constituting a very significant savings.



To obtain control costs for stainless steel systems, multi-



ply the capital costs by 2.3 and the annualized costs by



1.8.  Figure 4-4 illustrates capital costs  as a function of



exhaust volume.
                              4-38

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 Table 4-16.  CAPITAL AND ANNUAL COSTS FOR FABRIC FILTER
             SYSTEMS SERVING MODEL GRINDERS
                    ($103,  4th qtr. 1977)
Capacity, Mg/h (tons/h)
3
Exhaust volume, m /s
(103 acfm)
Temperature, °K (°F)
Equipment cost
Direct cost
Indirect cost
Contingency cost
Retrofit cost
a
Total capital cost
Direct operating cost
Annual capital charges
Product recovery credit
Total annual cost
Cost-effectiveness, C/kg
(C/lb) pollutant removed
45 (50)
2.6 (5.5)
322 (120)
16
33
12
9
11
65
23
11
14
20
3.1
(1.4)
91 (100)
5.2 (11.0)
322 (120)
32
70
25
19
22
136
31
23
29
25
1.9
(0.88)
136
7.8
322
51
112
41
31
36
220
39
38
43
34
1.
(0.
(150)
(16.5)
(120)










8
80)
To estimate costs for stainless steel construction, multiply
capital costs by 2.3 and annual costs by 1.8.
                           4-39

-------
    400



    300


    250
 ^ 200-



 gf 150-
 ey

 f

m
 o


 ^  90"

 s  M

 i  70"
 S  60-
 5
    50-


    40-



    30

    25
     20
       OTHER COST ESTIMATES FOR NEW PLANTS
                                    /
                                  /xx
                                  *•*
                                                        
                           AELxXX
        • D
              1.5
                                   SIPi>sV
                             •A
                                           • B
                            • B
            2        3^4
FABRIC FILTER EXHAUST VOLUME. nT/S
2.5
                           4
                5   6
    EXHAUST VOLUME, 103 acfm
                                               7  8  9 10
                                                               Mrt
                                                                     10
15     20
Figure  4-4.   Capital costs  for fabric filter  and venturi

         scrubbing systems  serving  model grinders.
                                  4-40

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B.   Venturi Scrubber



     Table 4-17 shows the capital and annualized costs for



the venturi scrubbing systems serving the model grinders.



Note the slight increase of costs with efficiency  (pressure



drop).  Annualized costs increase with efficiency mainly



because of power requirements.  No product recovery credit



is applied against annual costs since the wet slurry is not



in a recoverable state.  To obtain control costs for com-



plete stainless steel systems, multiply the capital costs by



2.65 and the annualized costs by 2.1.  Figure 4-4  illus-



trates control cost as a function of exhaust volume.



4.4.2  Cost-effectiveness



     Figure 4-5 illustrates the cost-effectiveness for the



grinder control options.  Fabric filters are, by far, the



most cost-effective control method, primarily because of



lower energy requirements and the product recovery credits.



Cost-effectiveness for venturi scrubbing increases from



medium to large grinders because of the large increase in



capital charges and power requirements, which offset the



increase in pollutant collection.



4.5  WET GRINDING



     One viable emission control alternative for phosphate



rock plants that produce phosphate for the manufacture of



phosphoric acid is the installation of wet grinding equip-



ment.  The use of wet grinding eliminates the need for
                              4-41

-------
Table 4-17.  CONTROL COSTS FOR VENTURI SCRUBBER SYSTEMS SERVING MODEL GRINDERS
                             ($10 ,  4th qtr.  1977)
Capacity, Mg/h (tons/h)
Exhaust volume, m /s (10 acfm)
Temperature, °K (°F)
Control level

Equipment cost
Direct cost
Indirect cost
Contingency cost
Retrofit cost
Total capital costs
Direct operating cost
Annual capital charges
Total annual costs
Cost-effectiveness, 
-------
                       GRINDER CAPACITY, Mg/h
                                         100
                                          i
 150    200
_j	i
                       GRINDER CAPACITY, TPH




0
LU
i
LU
1—

2 G
LU
1-8 6
1.6 ,1
00
o
1.4 °
1.2
i
                       EXHAUST VOLUME, m3/s
                       6   7   8 9  10        15


                      EXHAUST VOLUME, 103 acfm
  20    25
Figure  4-5.   Cost-effectiveness curves for fabric filters and



          venturi scrubbers serving  model grinders.
                                4-43

-------
drying and its dust control system and the grinding dust




control system.  The cost savings for the use of wet grind-



ing is difficult to estimate because of the many variables



involved.  However, this section attempts to quantify the



cost savings associated with wet grinding.




4.5.1  Capital Costs12



     Table 4-18 indicates and compares the capital costs for



complete grinding systems for model capacities of 45 Mg/h



(50 tons/h), 91 Mg/h (100 tons/h) and 136 Mg/h (150 tons/h).



Grinding options include wet or dry systems and open or



closed circuits.  These costs vary with the type of rock and



raw material and product specifications.  The basis for



these costs are 0.64 cm (1/4 in.) diameter inlet rock and 60



percent by weight less than 200 mesh outlet product.  Mois-



ture content within the grinder is a typical 28 to 32



percent.



     For the large 136 Mg/h (150 tons/h) grinding facili-



ties, the capital costs do not vary substantially between



grinding options.  For the small 45 Mg/h  (50 tons/h) grind-



ing system, the wet system cost is 35 percent less than the



dry system.



4.5.2  Annualized Costs



     The total operating cost for a drying operation at one



plant is $1.85/ton product, including dust control and
                             4-44

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 Table 4-18.   PURCHASE COSTS OF WET AND DRY GRINDING SYSTEMS
                        (.1977 prices)
                                     12
Type
of circuit
Dry-closed
Dry-open
Wet-open
Wet-closed
45 Mg/h
(50 tons/h)
$735,000

475,000
c
Capacity
91 Mg/h.
(100 tons/h)
$990,000

735,000
c
136 Mg/h
(.150 ! tons/h) .
$1,150,000

950,000
900,000
Specifications:
1/4 in. rock inlet:  60% with <_ 200 mesh
outlet 68-72% solids.
  Includes feeders, mill, classifier, motor, balls, and fans,
  Dry system prices include ductwork, cyclone, and fabric
  filter.
  Uncommon.
  Uncommon,  operating problems.
                              4-45

-------
capital charges.  Another plant reports about $0.86/ton,


                       14
including dust control.     These are PEDCo estimates based



on information given by the companies.  An average operating



cost may be taken as $1.40/ton of product, thus representing



part of the savings by eliminating drying and using wet



grinding.  Actual costs will vary depending on the type of



fuel and emission control device.



     The operating cost for air pollution control on grind-



ing facilities were estimated previously in Section 4.4.



The estimated annual savings by installing wet grinding is



$1.65/Mg ($1.50/ton) of ground product.   Table 4-19 presents



an estimate of annual operating costs.
                            4-46

-------
   Table 4-19.  ANNUAL SAVINGS AND OPERATING COSTS FOR

                  WET GRINDING SYSTEMS
Production capacity, Mg/h
(tons/h)
Operating time, h/yr
Annual savings from dryer
Annual savings from grinder
APC system
0 Fabric filter
0 Wet collector
Total estimated savings
0 With wet collector
0 With fabric filter
Assumed annual savings
Cost of new wet grinding
Pay-out period
45 (50)
70QO
$490,000

20,000
60,000
550,000
510,000
530,000
523,000
12 months
91 (100)
7000
$980,000

25,000
98,000
1,078,000
1,005,000
1,050,000
810,000
10 months
136 (150)
7000
$1,470,000

34,000
161,000
1,630,000
1,500,000
1,600,000
990,000
1,050,000
8 -months
Includes dryer operating expenses, APC control costs, and
depreciation.  Average savings of $1.50/Mg ($1.40/ton).

Includes air pollution control system operating costs,
depreciation, and product recovery (see Tables 4-16 and
4-17)

Assuming wet grinding and dry grinding operating costs are
the same.  Includes a and b above.

Assuming an installation factor of 1.10.
                            4-47

-------
                        REFERENCES
1.  Guthrie,  K.M.  Capital Cost Estimating.  Chemical
    Engineering.   March 24, 1969-  pp. 114-140.

2.  Peters,  M.S., and K.D. Timmerhaus.  Plant Design and
    Economics for Chemcial Engineering.  2nd Edition.
    McGraw-Hill Book Company,  New York City.  1968.  pp.
    90-151.

3.  Perry,  J.H.  Chemical Engineers'  Handbook.  4th Edition,
    McGraw-Hill Book Co., New York City-  1969.  p. 15-26.

4.  Memo to Economic Analysis Branch (EAB)  from R.H.
    Schippers, EAB, U.S. Environmental Protection Agency.
    Research Triangle Park, North Carolina.  January 11,
    1977.

5.  Ibid.  January 6, 1977.

6.  Kinkley,  M.L., and R.B. Neveril.   Capital and Operating
    Costs of Selected Air Pollution Control Systems.  Card,
    Inc.  Niles,  Illinois.  For U.S.  Environmental Pro-
    tection Agency.  Research Triangle Park, North Carolina,
    Contract No.  68-02-2072.  Publication No. 450/3-76-014.
    May 1976.

7.  Memo from Bill Hamilton, Chief of Economic Analysis
    Branch.  Environmental Protection Agency, Research
    Triangle Park, North Carolina, to EAB Members, dated
    March 14, 1977.  Attachment p. 2.

8.  Standards Support and Environmental Impact Statement.
    An Investigation of the Best Systems of Emission Reduc-
    tion for the Phosphate Rock Industry.  Draft.  U.S.
    Environmental Protection Agency,  Research Triangle
    Park, North Carolina.  February 1976.

9.  Lindsey,  A.M., and R. Segars.  Control of Particulate
    Matter from Phosphate Rock Dryers.  Environmental
    Protection Agency, Region IV, Atlanta, Georgia.
    January 1974.
                            4-48

-------
10.  Air Pollution Emission Test.  W.R. Grace Chemical Co.
     Bartow, Florida.  Report No. 75-PRP-l, by Engineering-
     Science, McClean, V.A., for U.S. Environmental Protec-
     tion Agency, Research Triangle Park, North Carolina.
     January 1976.

11.  PEDCo Environmental, Inc., Cincinnati, Ohio.  Control
     Cost Estimates for Lead Emission Sources.  For Environ-
     mental Protection Agency, Research Triangle Park, North
     Carolina.  Contract No. 68-02-1473, Task 20.  March
     1977.

12.  Telephone conversation between David M. Augenstein,
     PEDCo Environmental, Inc., and Bryan Hall, Kennedy Van
     Saun Corp., Danville, Pennsylvania.  December 2, 1977.

13.  Letter to Don R. Goodwin, ESED, Environmental Protec-
     tion Agency, Research Triangle Park, North Carolina
     from J.R. Terry, W.R. Grace and Co., Bartow, Florida.
     April 16, 1975.

14.  Letter to Don R. Goodwin, ESED, Environmental Protec-
     tion Agency, Research Triangle Park, North Carolina
     from N. Mason Joye, Occidential Chemcial Co., White
     Springs, Florida.  June 2, 1975.
                           4-49

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  5.0 .ENVIRONMENTAL IMPACT OF APPLYING CONTROL TECHNOLOGY





5.1  INTRODUCTION



     This section identifies the incremental environmental



and energy impacts in relation to each control alternative



and level of control.  Analyses are based on model situa-



tions in which impacts are the highest expected.  The



results of the study show that significant improvement in



ambient air quality is achieved by the application of con-



trols to meet two typical State Implementation Plan emission



levels (SIP, and SIP-).  Further improvement can be achieved



by applying control technology that meets more stringent



alternative emission levels (AEL).   Emission levels are



discussed in Appendix B in more detail.  The study also



indicates that maximum expected impacts on water pollution,



solid waste disposal, and radiation exposure are negligible.



Although energy demand increases significantly with applica-



tion of control technology, the incremental increase in



demand resulting from achieving AEL or SIP2 emission levels



over SIP, levels is negligible.
                             5-1

-------
5.2  AMBIENT AIR IMPACT



     An atmospheric dispersion model was used to predict the



level of the ambient particulate concentrations (yg/m )



caused by emissions from phosphate rock processes.  Disper-



sion modeling was performed on drying, calcining, and



grinding operations.  Process parameters were selected



within a reasonable range so as to maximize air impact and



simulate "worst-case" conditions.  Pollutant concentrations,



estimated by state-of-the-art modeling techniques and



accurate to within a factor of 2, represent 24-hour averages



and annual means.  Florida meteorological data were used to



simulate atmospheric conditions and behavior.  All pollu-



tants are assumed to display the dispersion behavior of



nonreactive gases.   Refer to Appendix D for a more detailed



description of the modeling technique.  Input and output



data for the modeling program for the drying, calcining, and



grinding operations are shown in Tables 5-1, 5-2, and 5-3,



respectively.  The results indicate it is not likely that



the primary national ambient air quality standard (NAAQS)



for particulate matter 1260 yg/m  (24-h average) and 75



yg/m  (annual mean)] will be exceeded at the stringent



control level (SIP-).




     The incremental improvement of air quality by applying




     control on a previously uncontrolled process is highly
                             5-2

-------
Ul
 I
u>
                   Table 5-1.   RESULTS OF  DISPERSION MODELING TO  DETERMINE  AMBIENT  IMPACT OF

                                             DRYER EMISSIONS  (S.I.  UNITS)
Production rate, Mg/h
Exhaust rate, m /sa
Uncontrolled emission, g/sb
Stack height, m
Stack diameter, m
Tempera ture , * K
Velocity, m/s
Building height, m
45
14.2
91
15
1.34
394
10
10
272
85
845
20
3.3
394
10
•15

Emission, g/s
MGLC,f ug/m3 @ 0.1 km
MGLC, ug/m3 ,@ 0.3 km
MGLC, yg/m3 § 2 km
MGLC, pg/m3 e 20 Jon
Level of control
SIPj0
5.95
140 (19)
68 (11)
19 (4)
1.1 (0.2)
siP2a
4.18
98 (13)
48 (7.7)
14 (2.8)
0.78 (0.14)
AELe
0.57
13 (1.8)
6.5 (1.1)
1.9 (0.4)
0.1 (0.02)
SIP.0
8.07
61 (5.4)
21 (1.7)
8.1 (1.2)
0.8 (0.2)
SIP2a
5.55
42 (3.7)
14 (1.2)
5.6 (0.8)
0.6 (0.1)
AEL6
3.38
26 (2.3)
8.9 (0.7)
3.4 (0.5)
0.3 (0.07)
                 a        *                "?   1     —1
                  Based on 0.23 wet std.  mj's  /Mg-h   product.
                  Based on 11.4 g/dry std.  m3  and 25% v moisture content.
                 c Based on least stringent state regulations.
                  Based on most stringent state regulations.
                 e Based on AEL of 0.071 g/dry  std. m .
                 f MGLC - maximum ground level  concentration of particulate matter;  24-h  average
                   (annual mean)

-------
 Table  5-2.   RESULTS  OF DISPERSION  MODELING  TO DETERMINE AMBIENT IMPACT  OF
                           CALCINER EMISSION  (S.±.  UNITS)
Production rate, Mg/h
Exhaust rate, m^/s
Uncontrolled emission, g/sc
Stack height, m
Stack diameter, m
Temperature, °K
Velocity, m/s
Building height, m
18.1
12.7 (17.2)b
81.0
15
1.27
394 (5?3)b
10 (13.6)b
10
63.5
44.2 (60.2)b
2284
15
2.38
394
10 (13.6)b
10

Emissions, g/s
MGLC,g yg/m @ 0.1 km
MGLC, pg/m @ 0.3 km
MGLC, yg/m3 @ 2 km
MGLC, yg/m3 @ 20 Jon
Level of control
SIP1d
3.78
96 (13)
49 (8.3)
13 (2.7)
0.7 (0.1)
siP2e
2.90
73 (10)
38 (6.4)
10 (2.1)
0.5 (0.08)
AEL
0.50
13 (1.7)
6.6 (1.1)
1.7 (0.4)
0.09 (0.01)
SIP^
5.93
71 (6.1)
23 (2)
11 (1.8)
0.7 (0.2)
SIP/
4.29
51 (4.4)
17 (1.4)
8 (1.3)
0.50 (0.14)
AELf
1.76
21 (1.8)
7 (0.6)
3.3 (0.5)
0.2 (0.06)
3 Based on  0.51 wet std. m  -s~ /Mg-h   product.
  Exhaust rates, velocity,  and temperature indicate conditions prior to  cooling the gas  stream.
c                         3
  Based on  11.4 g/dry std.  m  and 25% v moisture content.
  Based on  least stringent  state regulations.
e Based on  most stringent state regulations.
f Based on  AEL of 0.070 g/dry std. m .
' MGLC - maximum ground level concentration of particulate matter; 24-h   average (annual mean).

-------
Ul
I
en
                 Table 5-3.   RESULTS OF  DISPERSION MODELING TO  DETERMINE AMBIENT IMPACT  OF


                                          GRINDER EMISSIONS  CS.I. UNITS)
Production rate, Mg/h
Exhaust rate, m /sa
Uncontrolled emissions, g/s
Stack height, m
Stack diameter, m
Temperature, °K
Velocity, m/s
Building height, m
45
4
38
15
0.91
373
10
10
136
12
117
15
1
373
10
10

Emissions, g/s
MGLC,f yg/m3 @ 0.1 km
MGLC , yg/m3 @ 0.3 km
MGLC, yg/m3 @ 2 km
MGLC, yg/m3 @ 20 km
Level of control
SXP^
5.55
285 (54)
180 (42)
22 (5.4)
1.2 (0.17)
SIP2d
4.04
207 (39)
131 (31)
16 (3.9)
0.9 (0.12)
AELS
0.10
5.1 (1)
3.2 (0.8)
0.4 (0.1)
0.02 (0)
SIP.^
6.81
197 (28)
116 (21)
24 (5.3)
1.2 (0.2)
SIP/
4.92
143 (21)
84 (15)
17 (3.8)
0.9 (0.14)
AEL6
0.31
9.0 (1.3)
5.3 (1)
1.1 (0.05)
0.05 (0)
                 a Based on 0.08 wet std. m -s~ /Mg-h~  product.

                   Based on 11.4 g/dry std. m and 10% v moisture content.

                 c Based on least  stringent state regulations.
                   Based on most stringent state regulations.

                 e Based on AEL of 0.023 g/dry  std. m3.

                   MGLC - maximum ground level  concentration of particulate matter; 24-h; average  (annual mean).

-------
significant.  The estimated maximum ground level concentra-

tion  (MGLC) of particulate matter for uncontrolled processes


is given in Table 5-4 by linear extrapolation.


      Table 5-4.  ESTIMATED AIR IMPACTS OF UNCONTROLLED


                         PROCESSES
Process
Drying
Calcining
Grinding
Capacity,
45
272
18
63
45
136
Mg/h (tons/h)
(50)
(300)
(20)
(70)
(50)
(150)
MGLC,
24-h avg
2150
4120
1215
1560
2000
3390
yg/m
(annual mean)
(288)
(365)
(120)
(94)
(380)
(490)
     It is important to restate that SIP mass emission


levels may not always be as stringent as opacity regula-


tions, especially in smaller processes.  If these processes


were to meet opacity regulations by reducing particulate


emissions, the source might well achieve NAAQS in the local


environment.  In this regard, the analysis of SIP levels is


not entirely valid for all cases.  Clear or near clear plume


opacity is assumed for a dust loading of 0.12 to 0.23 g/m3

                      2
(0.05 to 0.1 gr/dscf).    At these conditions, NAAQS can be


achieved.   On a plant-wide basis, the impact of the collec-


tive sources on the air quality appears to be less than the

NAAQS.
                             5-6

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5.3  WATER POLLUTION IMPACT



     The application of air pollution control technology



does not significantly affect wastewater volume or pollutant



loadings.  No wastewater is generated by fabric filters or



ESP's.  The wet scrubber is the only control device that gen-



erates wastewater.  The major source of wastewater is the



beneficiation process, which generates nearly 41.7 m /Mg of



product  (104 gal/ton).3



     To consider the potential impact, a "worst-case" model



plant was selected to maximize wastewater generation by air



pollution controls.  The model plant produces 90.7 Mg/h (100



tph) of calcined rock, which is ground in a 90.7 Mg/h (100



tph) grinding facility-  Emissions from all operations are



controlled by a wet collector with a liquid-to-gas ratio of


        3           3
1.34 a/m  (10 gal/10  acf).  Inlet concentrations are



assumed to be high at 11.4 g/dry std. m  (5 gr/dscf).



Scrubbers operate at 95 percent collection efficiency.



     The total wastewater generated by the wet scrubbers,



assuming 90 percent recycle, is about 9.5 H/s (150 gpm).



The total wastewater generated by the beneficiation opera-

                     3
tion is about 1.053 m /s (16,700 gal/min).   Thus, the addi-



tional volume contributed by the wet scrubbers constitutes



an increase of less than 1 percent.  If the wastewater is



pumped directly to the tailings ponds from the scrubber
                              5-7

-------
without a retention tank (once-through water), the increase



in the discharge volume to the ponds is about 10 percent.



     Wastewaters from control operations are normally com-



bined with other wastewaters prior to treatment, recycling,



and/or discharge.  Treatment of wastewaters from phosphate



rock processing normally consists of gravity separation in



ponds that also contain wastewaters from beneficiation



and/or phosphoric acid production.  Occasionally, the over-



flow from these ponds is treated by addition of flocculating



agents and pH adjustment.  Discharge of the overflow waters



from these ponds is dependent upon a number of factors:



     0    the percent recycled



     0    rainfall, total and frequency



     0    surface runoff



     0    evaporative losses



     0    available pond acreage



     In the western states, where evaporative losses are a



major factor, the entire overflow from the ponds is usually



recycled and accounts for 65 percent or greater of the



process water.  In the eastern states,  evaporative losses



normally do not offset the effect of precipitation.  Hence,



part of the overflow from the ponds is  intermittently or



continuously discharged to receiving bodies of water; the



remaining portion, 60 to 90 percent, is recycled.3
                              5-f

-------
     Table 5-5 shows the chemical analysis of a typical



phosphate rock product and the corresponding dust from the



calcining operation.  The quality of the wastewater dis-



charged from a scrubber and the recirculation tanks is



predicted from this information.  Table 5-6 gives the pre-



dicted effluent quality for the model plant described above



based on these chemical analyses.  Since these concentra-



tions are independent of the production capacity under the



assumptions made, it is not likely that the solids content



of any calciner scrubber effluent will exceed 5000 ppm (0.5%



by wt.)  or that grinder scrubber effluent will exceed 7500



ppm (0.75% by wt.).  If wastewater is recirculated at a



recycle rate of 90 percent and settling efficiency in the



recirculation tank is maintained at 90 percent, outlet



concentrations are nine times the inlet concentrations.
                              5-9

-------
       Table 5-5.  CHEMICAL ANALYSIS OF PHOSPHATE ROCK




 ROCK PRODUCED AND DUST EMISSIONS FROM CALCINER CYCLONES'




                   (in percent by weight)
Component
Calcium (CaO)
Phosphorous (P-Oj.)
Silica (SiO_)
Aluminum (A120_)
Iron (Fe20 )
Magnesium (MgO)
Other
Phosphate rock
product
45.5
32.5
11.0
2.0
0.8
0.7
7.5
Dust from
cyclones
18.3
14.4
35.5
8.4
2.3
0.1
21.0
     Effluent is discharged to the tailings pond directly



from the scrubber or the recirculation tank.  A high degree



of solids removal (>90 percent)  and dilution is achieved in



these ponds.  Pond effluent may require additional treatment



prior to recycling to the beneficiation facility or dis-



charge to surface waters.




     No significant increase in the wastewater discharge



volume and no increase in pollutants or contribution of a



different pollutant are expected by the use of wet grinding



techniques.   No additional solid waste is generated.  Ef-



fluent limitations established by EPA will require no dis-



charge at all by 1980.
                            5-10

-------
Ul
I
                    Table  5-6.   PREDICTED EFFLUENT  QUALITY FROM WET  SCRUBBERS ON

                                            CALCINERS AND GRINDERS

Exhaust volume, m /s (acfm)
Dust loading, g/dry std. m
(gr/dscf)
Bnission rate, Mg/h (Ib/h)
Solids collected, Mg/h (lb/h)c
Raw wastewater flow, t/s
(gal/min)d
Recirculation tank waste-
water composition, ppme
by weight
Calcium (CaO)
Phosphorous (P_O_)
Silica (SiOj)
Aluminum (Al-O-)
Iron (Fe203)
Magnesium (MgO)
Total suspended solids, ppm
by weight
90.7 Mg/h (100 tons/h)
Calciner
63.25

11.4
1.46
1.39

84.5

Inletf

830
653
1610
381
104
45

4560
(134,000)

(5.0)
(3214)
(3054)

(1340)

Outlet9

7470
5880
14,490
3430
936
405

41,000
90.7 Mg/h (100 tons/h)
Grinder
7.55

11.4
0.281
0.267

10.09

Inletf

3350
2390
810
147
59
51

7357
(16,000)

(5)
(620)
(589)

(160)
*
Outlet5

30,200
21,500
7290
1320
530
460

66,210
Calciner exhaust flow is based on  0.51- wet  std. m
exhaust flow is based on 0.08  wet  std. m^-s
                                                                -s  /Mg«h   (1000 scfm per  tons/h); grinder
             .                            .          .             -'- (160 scfm/tph) .
               Moisture content of exhaust assumed at 25% v for calciner and 10% v for grinder.
             ^ Wet scrubber collection efficiency is 95 percent.
               Liquid-to-gas ratio is 1.34 fc/m^  (10 gpm/lO-' acfm).
               Calculated  from Table 5-5.  Grinder dust emissions have the same composition  as  the
             j product composition.
               Inlet to recirculation tank is the same as the outlet from the scrubber.   If  no  recirculation
               is used, the inlet composition is the same as the discharge to the tailing pond.
               The outlet  composition from the tank assumes 90 percent recycle and 90 percent settling
               efficiency.  This stream would be discharged to the tailings pond.

-------
5.4  SOLID WASTE IMPACT



     It is not anticipated that air pollution control will



have a significant incremental impact on the solid waste



from phosphate rock processing.  The major source of solid



wastes is from the beneficiation of the ore.  About 70



percent of the mined rock in Florida is wasted in beneficia-



tion.   Solid wastes generated by air pollution control



devices originate from drying, calcining, and grinding



operations.  Since dust collected by fabric filters on



grinding and rock handling operations is recycled, it is not



a source of solid waste.



     The increase in solid waste volume contributed by



emission control over that generated by beneficiation is



illustrated in Table 5-7.  A "worst-case" analysis is given



to show the maximum expected impact.  The "worst-case"



assumes the extreme mass emission rate and the grinding of



all dried and calcined rock.



     Model Plant A consists of one 272 Mg/h (300 tons/h)



dryer and two 136-Mg/h  (150-tph) grinders, each controlled



by wet collectors.  Model Plant B consists of four 63.5 Mg/h



(70-tons/h) calciners and two 136-Mg/h (150-tph) grinders,



each controlled by wet collectors.  The maximum incremental



impact on solid waste generation is shown to be 0.44 percent



(dry) for Model Plant A and 0.83 percent (dry)  for Model



Plant B.
                             5-12

-------
      Table  5-7.  SUMMARY OF SOLID WASTE IMPACT FOR TWO

                   WORST-CASE MODEL PLANTS
Control level
                         Solid wastes generated, Mg/yr (tons/h)
      Model Plant Ar
 Model Plant Bc
SIP2

AEL

Total solid wastes ^
 from beneficiation

Percent increase by
 dry weight

Percent increase by
 total weight6
   20,330 (22,410)

   20,510 (22,610)

   20,790 (22,926)


4,730,000 (5,210,000)


       < 0.44


       < 1.5
   35,810 (39,480)

   36,090 (39,790)

   36,440 (40,171)


4,410,000 (4,860,000)


        < 0.83


        < 2.8
  These model plants operate at 85 percent of the annual
  capacity.
  Model plant A includes one 272 Mg/h (300 tons/h) dryer and two
  136-Mg/h  (150 tons/h) grinding systems.
  Model plant B includes four 63.5 Mg/h  (70 tons/h) calciners
  and two 136 Mg/h  (150 tons/h) grinders.

  Seventy percent of the processed ore is wasted in beneficiation.
  Assuming sludge from settling ponds is 30 percent solids.
                             5-13

-------
     Tables 5-8, 5-9, and 5-10 indicate the amount of dust



(dry weight)  collected by the control devices for each of



three control levels for the drying, calcining, and grinding



operations.  A comparison between the two plants is given in




Table 5-7.



     Based on this analysis, solid waste impact from the



application of air pollution control technology is small.



5.5  ENERGY IMPACT



     Application of emission control technology to meet



SIP,, SIP-, and AEL emission levels will not result in a



significant energy impact.  Energy impact is defined as the



increase in energy required to operate air pollution control



devices and related systems over the energy required for the



operation itself  (fuel oil, electricity, natural gas, etc.).



Control systems use electrical energy.  The corresponding



increased consumption of fossil fuels at the power genera-



tion plant is estimated by assuming a 30 percent efficiency



for power generation and transmission.



     A dryer generating 0.23 wet std. m3*s~ /Mg-h"1  (450



scfm per tons/h) requires an additional 14 MJ/Mg product



 (12,000 Btu/ton) of electrical energy to operate a venturi



scrubber at a system pressure drop of 7.5 kPa  (30 in. WG) .



A fabric filter system operating at 2.5 kPa (10 in. WG)



requires an additional 4.7 MJ/Mg product  (4000 Btu/ton) of
                              5-14

-------
         Table  5-8.  SOLID WASTES GENERATED BY DRYER

                      EMISSION CONTROLS
Production rate, Mg/h (tons/h)
Throughput rate, Mg/h (tons/h)a
Uncontrolled emission, Mg/h
(lb/h)b
SIP, dust collected, Mg/h
(lb/h)c
SIP7 dust collected, Mg/h
(lb/h)d
AEL dust collected, Mg/h
(lb/h)e
45
51
0.329
0.307
0.314
0.327
(50)
(56)
(723)
(676)
(690)
(719)
272
302
1.972
1.944
1.953
1.960
(300)
(333)
(4339)
(3396)
(4296)
(4312)
  Assumed 10 percent weight loss during drying.
b Calculated at 0.23 wet std. m3-s~1/Mg-h~1 (450 scfm 'per tons/h),
  11.4 g/dry std. m^ (5 gr/dscf), and 25% v moisture.
  Based on Florida regulation for particulate emissions.
  Based on regulations for all states except Florida.
8 Based on AEL of 0.070 g/dry std.  m3 (0.031 gr/dscf).
                              5-15

-------
   Table  5-9.  SOLID WASTES GENERATED BY CALCINER  EMISSION

                          CONTROLS
Production rate, Mg/h  (tpns/h)

Throughput rate, Mg/h (tons/h)

Uncontrolled emissions, Mg/h
       '(lb/h)b

SIP., dust collected, Mg/h
       . db/h)c

SIP2 dust collected, Mg/h
        (lb/h)d

AEL dust collected, Mg/h
       (lb/h)e
                                   18    (20)

                                   20    (22)


                                    0.291  (642)


                                    0.277  (610)


                                    0.280  (618)


                                    0.289  (638)
63.5 (70)

71   (78)


 1.021 (2250)


 1.005 (2215)


 1.011 (2228)


 1.014 (2236)
  Assumed 10 percent weight loss during calcining.
  Calculated at 0.52 wet std. m «s  /Mg'h"1  (1000 scfnt per tons/h)
  11.4 g/dry std. m3 (5 gr/dscf), and 25% v moisture.
0
  Based on Florida emission regulations.
  Based on regulations for all states except Florida.
e Based on AEL of 0.070 g/dry std.' m3 (0.031 gr/dscf),.
                             5-16

-------
  Table 5-10.  SOLID WASTES GENERATED BY GRINDER EMISSION


                          CONTROLS
Production rate, Mg/h (tons/h)
Throughput rate, Mg/h (tons/h)
Uncontrolled emissions, Mg/h
db/h)a
SIP, dust collected, Mg/h
- :(lb/h)b
SIP- dust collected, Mg/h
(lb/h)c
AEL dust collected, Mg/h
(lb/h)d
45, (50)
45 (50)
0.140 (309)
0.120 (265)
0.126 (277)
0.140 (308)
136
136
0.420
0.396
0.403
0.419
(150)
(150)
(926)
(872)
(888)
(923)
a Calculated from 0.08 wet std. m »s~ /Mg*h~  (160 scfm per tons/h) ,
11.4 g/dry std.
                     (5 gr/dscf ) ,  and 10% v moisture.
  Based on Florida emission regulations.


0 Based on regulations from all other states except Florida.
j                                   ^

  Based on AEL of 0.030 g/dry std.  m  (0.013 gr/dscf).
                             5-17

-------
electrical energy, and an electrostatic precipitator  (ESP)



operating at a pressure drop of 1.3 kPa (5 in. WG) requires



an additional 2.6 MJ/Mg (2200 Btu/ton).


                                          3  -1     -1
     A calciner generating 0.51 wet std. m «s  /Mg-h



(1000 scfm per tons/h) requires an additional 31 MJ/Mg



product (26,700 Btu/ton)  of electrical energy for a venturi



scrubber,  10.4 MJ/Mg  (8890 Btu/ton) for a fabric filter, and



5.8 MJ/Mg (4890 Btu/ton)  for an ESP.  These systems operate



at the same pressure drop as for the dryer applications.



     A grinder generating 0.08 wet std. m -s~ /Mg-h~   (160



scfm per tons/h) requires an additional 3.8 MJ/Mg product



(3200 Btu/ton) of electrical energy for a venturi scrubber



and 1.3 MJ/Mg  (1100 Btu/ton) for a fabric filter.



     The above energy requirements were calculated from



energy balances based on flow rate and system pressure drop.



Table 5-11 shows the energy data reported by the industry-



     As shown in Table 5-12, the overall increase in fossil



fuel consumption resulting from emission control technology



is substantial, up to 17 percent by high-energy scrubbing of



calciner emissions and up to 12 percent by high-energy



scrubbing of dryer emissions.  The increase in energy re-



quirements for a fabric filter and an ESP would be 33 and 80



percent lower, respectively.  The incremental impact  (addi-



tional increase in energy consumption) of more stringent
                             5-18

-------
                 Table  5-11.   ENERGY CONSUMPTION FOR PHOSPHATE ROCK PROCESSES  AND


                                       ASSOCIATED CONTROL  DEVICES1
en
I
M
VO
Process
Rotary dryer
Fluid bed dryer
Fluid bed dryer
Fluid bed dryer
Rotary and fluid
bed dryer
Rotary dryer
Rotary dryer
Roller mill
Ball mill
Ball mill
Roller mill
Process energy,
,MJ/Mg
(10 Btu/ton)
292 (251)
324 (279)
515 (443)
460 (395)
509 (438)
354 (305)
326 (281)
76 (66)
65 (56)
44 (38)
138 (119)
Control
device*3
IS + ESP
IS + ESP
CS
Unknown
CS
IS
VS
FF
FF
Unknown
VS
Energy required
by control device,
MJ/Mg (Btu/ton)a
6.6 (5690)
10.3 (8900)
3.3 (2810)
Unknown
3.6 (3130)
9.6 (8310)
23.9 (20,600)
1.7 (1500)
1.4 (1280)
Unknown
4.3 (1300)
Increase in equivalent
fossil fuel consumption,
percent0
7.7
10.8
2.1
Unknown
2.4
9
24
7.7
7.7
Unknown
10.3
            Reported  by the industry.

            Key:  IS,  impingement scrubber; ESP, electrostatic precipitator; CS,  cyclonic scrubber;
                  VS,  venturi scrubber;  FF, fabric-filter.

            Assuming  30% power transmission and generation efficiency.

-------
     Table 5-12.  ENERGY IMPACT OF APPLYING EMISSION

                   CONTROL TECHNOLOGY
Process
Drying
Calcining
_ . ,. d
Grinding
_ a
Process energy
MJ/Mg (Btu/ton)

397
611
270

(341,000)
(525,000)S
(233,000)
Increased equivalent fossil fuel
consumption, %t>
VS
12
17
4.6
FF
3.9
8.5
1.6
ESP
2.1
4.7
-
Averages of energy requirements reported by the industry;
Table 5-11.

Based on calculated energy requirements and 30% generating
and transmission efficiency; Key: VS, venturi scrubber;
FF, fabric filter; ESP, electrostatic precipitator.

Practically all energy in the form of fossil fuel.

All energy used in grinding is electrical.  These numbers
represent equivalent fossil fuel consumption.

Estimated in reference 1.
                            5-20

-------
control called for by AEL or new state regulations over SIP



controls may be considerably less.  If more stringent



regulations require an additional 2.5 kPa (10 in. WG) pres-



sure drop across a venturi scrubber, the incremental impact



will be 4 percent additional fossil fuel.



     Operations presently controlled by fabric filters or



ESP's have little or no incremental energy impact because



efficiency for these devices is independent of the system



pressure drop.  Energy required by ESP plates is about 0.03


    2                        2
kW/m  plate area (0.003 kW/ft ) in addition to the power re-



quired by the fan system.  However, the additional energy



demand by application of high-energy scrubbers can be sig-



nificant.



     By replacing dry grinding with wet grinding systems



where feasible, the dryer and its fuel consumption are



eliminated.  This savings is estimated to be 397 MJ/Mg



(341,000 Btu/ton),  equivalent to about 10 & of oil/Mg rock



(2.4 gal oil/ton).



     In summary, the incremental energy impact is small for



operating control equipment to meet more stringent emission



regulations than existing SIP levels.



5.6  RADIATION IMPACT



     The pollutants in plant wastewaters can include not



only the common ones such as suspended solids, high acidity,
                             5-21

-------
fluorides, and phosphates, but also radiochemical pollutants

(e.g., radium-226).   The source of the radiochemical

pollution problem is the widely acknowledged presence of

uranium in phosphate rock in the range of 50 to 200 g/Mg

(0.1 to 0.4 Ib/ton) of rock.  Discharge or leakage from the

holding ponds described in subsection 5.3 could therefore

constitute a major pollution problem to the aquatic environ-

ment of receiving streams.  Also, seepage of these waters

into aquifers could contaminate drinking waters.  Sampling

of recycled water reportedly has indicated that such waters

contain 90 to 100 picocuries per liter of radiochemical

pollutants.   This is more than 3 times the Atomic Energy

Commission (AEC) standard for release to an unrestricted

environment within an AEC licensed plant, and 30 times the

maximum permissible concentration for water.

     Sizable quantities of radioactive particles have also

been found in solid wastes discarded from phosphate rock

plants.  One analysis of radiochemical pollutants in phos-

phate rock slimes  (a by-product of beneficiation) revealed

radium-226, uranium, and thorium in quantities of 45, 89,

and 53 picocuries per gram, respectively.   Soil throughout

the United States typically contains between 0.15 and 2.8
                                  Q
picocuries of radium-226 per gram.


     Recent attention has been given to the exposure to

radioactivity of persons living in structures built on
                            5-22

-------
reclaimed phosphate land.  One study indicated that exposure


of these inhabitants was up to 50 times the normal back-

                          o
ground level of radiation.   This exposure is about 2.5


times greater than the present Federal guideline for maximum

                           9
exposure of uranium miners.   These recent findings, part of


an ongoing EPA study, will most likely result in the estab-


lishment of guidelines for disposal of radioactive wastes.


     Air emission standards will not cause a significant


increase in radiochemical pollutants discharged from the


plants by aqueous discharge and sludge disposal. As ex-


plained in subsection 5.3, water used for emission control


devices is negligible compared with total water usage at a


phosphate rock plant.  The additional amount of particulate


collected and ultimately disposed as solid waste also will


be negligible.  In fact, particulate collected by dry col-


lection devices such as baghouses will have a positive


impact on radiochemical pollution since it can be returned


to product inventories rather than discarded.
                             5-23

-------
                        REFERENCES
1.   Standards Support and Environmental Impact Statement.
    An Investigation of the Best Systems of Emission
    Reduction for the Phosphate Rock Processing Industry.
    Draft.   U.S.  Environmental Protection Agency.  Research
    Triangle Park,  N.C.  February 1976.

2.   News Focus.   "IGCI Reports Consensus on Industrial
    Emission Levels Producing Clear or Near Clear Stacks."
    Journal APCA -  June 1973, p. 608.

3.   Versar, Inc.   Development Document for Effluent Limita-
    tion Guidelines and Standards of Performance, Mineral
    Mining and Processing Industry.  Volume II.  Prepared
    for U.S. Environmental Protection Agency.  Contract No.
    68-01-2633.   January 1975.  ppV-65, V-69.

4.   Smith,  J.L.,  and H.A. Snell.  Selecting Dust Collec-
    tors.  Chemical Engineering Progress.  j^4_(l) 1968.  pp.
    60-64.

5.   Fullen, H.T., and B.P. Faulkner.  Inorganic Fertilizer
    and Phosphate Mining Industries - Water Pollution and
    Control.  Battelle Memorial Institute.  Battelle -
    Northwest.  Richland, Washington.  12020 FPO.  August
    1971.  p. 207-

6.   Rouse,  J.V.   Radiochemical Pollution from Phosphate
    Rock Mining and Milling.  Environmental Protection
    Agency-  Presented at Water Resources Problems Related
    to Mining, American Water Resources Association, Proc.
    No. 18.  June 1974.  p. 65-71.

7.   Guimond, R.J.,  and S.T. Windham.  Radioactivity Distri-
    bution in Phosphate Products, By-Products, Effluents,
    and Wastes.   EPA Technical Note No. ORP/CSD-75-3.
    August 1975.   p. 5.
                           5-24

-------
8.   Environmental Protection Agency.  Preliminary Findings
    Radon Daughter Levels in Structures Constructed on
    Reclaimed Florida Phosphate Land.  EPA Technical Note
    No. ORP/CSD-75-4.  September 1975.  p. 6.

9.   Ibid.  p. 14.
                            5-25

-------
     6.0  EMISSION MEASUREMENT AND CONTINUOUS MONITORING






6.1  EMISSION MEASUREMENT METHODS



     The Environmental Protection Agency has successfully



used Reference Methods 1 through 5 to measure particulate



emissions from the phosphate rock processing industry, ap-



plying these methods as described in Appendix A of CFR 40



Part 60 and published in the Federal Register (December 23,



1971, and October 23, 1974).



     The particulate mass catches obtained from the process



emission streams were relatively low, especially when emis-



sions were controlled by fabric filters.  The mass catch



amounts ranged from about 12 mg (0.19 gr) to over 300 mg



(4.63 gr) .  When concentrations were particulary low, some



tests had to be extended to more than 3 hours to obtain



accurately measurable catches.  In-house EPA tests show that



an accuracy of + 10 percent can be obtained with a minimum



catch of 25 mg (0.39 gr).   Inaccuracies at this level and



below tend to bias the sample on the high side of the



measurement; that is, the measurement will indicate somewhat



more mass than is actually collected by the impingers.
                                6-1

-------
     Visible emission readings are difficult to measure



because of the high moisture content of the scrubber ex-



hausts from several of the dryer and calciner exhausts.



Opacity readings are usually made at the leading edge of the




steam plume.



6.2  CONTINUOUS MONITORING



     The EPA performance standards for opacity monitors are



contained in Appendix B of 40 CFR Part 60 (Federal Register,



September 11, 1974).  These monitors are especially useful



for measuring opacity when the exhaust gases are above the



dew point and formation of water vapor plume makes measure-



ment difficult by visual methods.



     Effluent gases from phosphate rock processes are not



excessively hot Iless than 120°C (250°F)], but they some-



times contain fluorides, which react with water to form



acids that etch glass materials.  Glass lenses on opacity



monitoring equipment should either be protected from fluo-



ride deposits or replaced with material that is not subject



to etching.




     Equipment and installation costs for an opacity monitor



are estimated to be $18,000 to $20,000; annual operating



costs, including data recording and reduction, are estimated



to be $8000 to $9000.l
                               6-2

-------
6.3  PERFORMANCE TEST METHODS1



     The performance test method recommended for measuring



particulate matter is EPA Method 5.  Because of the con-



struction of some control equipment, special stack exten-



sions are sometimes required to obtain acceptable sampling



conditions.  The recommended minimum sample volume is 4.5



dry std. m  (160 dscf).   Because of the lower particulate



concentrations in the stack gases from processes controlled



by fabric filters, longer sampling times and larger sample



volumes are required to produce acceptable data.  High-



volume sampling trains,  which are commercially available and



conform to Method 5 specifications, are capable of obtaining



the minimum sample volume in tests of shorter duration.



     Sampling cost for a test consisting of three particu-



late runs is estimated to be about $5000 to $9000.  This



estimate includes $2000 to $4000 for sampling site modi-



fications such as ports, scaffolding, ladders, and exten-



sions.



     Reference Method 9 is recommended for determining



visible emissions.
                                6-3

-------
                     REFERENCE
Standards Support and Environmental Impact Statement.
An Investigation of the Best Systems of Emission Re-
duction for the Phosphate Rock Processing Industry.
Draft.  U.S. Environmental Protection Agency.  OAQPS,
ESED.  Research Triangle Park, North Carolina.  Febru-
ary 1976.
                           6-4

-------
                  7.0  ENFORCEMENT ASPECTS





     In setting an emission limitation, the aspects of en-



forcing that limitation must be considered.  This section



discusses alternative regulations and enforcement aspects of



these regulations.



7.1  REGULATIONS



     Applicable source emission limitations are of three



types:  existing state source regulations, state new source



regulations or performance standards, and alternative emis-



sion levels that might be imposed by future legislation.



The applicability of state regulations is determined by the



respective SIP and the definition of a "new, modified,



and/or reconstructed source."  Appendix B discusses regula-



tions in more detail, and Appendix C presents Florida reg-



ulations as an example of state regulations.  No Federal New



Source Performance Standards have been promulgated for this



industry.



7.1.1  State New Source Regulations



     Although no state has specifically set New Source



Performance Standards for phosphate rock processing facil-



ities, opacity and mass emissions will generally be more
                               7-1

-------
stringent for new facilities than for existing sources.



Figure 7-1 shows state new source regulations for mass



emissions.  Table 7-1 presents state opacity regulations for



new and existing sources compared with opacity limits des-



ignated by an alternative emission level  (AEL).



7.2  FORMAT OF EMISSION STANDARDS



     A variety of formats may be used to write standards



governing how emission sources in the phosphate rock in-



dustry will be controlled.  Possible formats for each



potential source include mass per unit production Ig/kg



product (lb/ton)], mass per unit feed [g/kg feed (lb/ton)],



mass per unit heat input Ig/J (lb/10  Btu)], concentration



[g/dry std. m   (gr/dscf)J, mass rate tkg/h (lb/h)], equip-



ment specifications, required maintenance procedures, etc.



These different formats and their application to the pro-



cesses under consideration are discussed below.



7.2.1  Dryers



7.2.1.1  Mass Rate per Unit Feed or Production—



     Dryers are designed for a fixed moisture removal rate,



which is based primarily on heat input.   The rock feed rate



is therefore a function of its moisture content and the type



of rock.  It can vary up to 100 percent for a given unit



operating at maximum capacity.  A standard based on a



format of mass rate per unit of feed or production Ig/kg
                               7-2

-------
u>
                                                     PROCESS THROUGHPUT,

                                                       5    10    20 30  50   100
      300 500
                 to
                 O
                 I—I
                 to
                 to
                 co
                 •a:
A-A1 - FLORIDA REGULATION (NEW SOURCE
      REGULATION FOR TENNESSEE AND
      WYOMING).
                                                                               B-B' - TENNESSEE, NORTH CAROLINA, IDAHO.
                                                                                     MONTANA, AND WYOMING EXISTING
                                                                                     SOURCE REGULATIONS.
UTAH - 852 CONTROL REQUIRED.
O
I—I

to
I—I

LU

UJ

CO


O
                                         1     2  345    10   2030  50   100     300500

                                                       PROCESS  THROUGHPUT, tons/h
                                1000
                             Figure 7-1.   State  mass emission  limitations for  new  and

                                                         •  ...               2
                                                      existing  sources.

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Table 7-1.  OPACITY REGULATIONS FOR VARIOUS JURISDICTIONS
  Jurisdiction
   Alternative emission levels'
        Drying and calcining
        Grinding
        Rock conveying
   Florida

   Montana

   Utah

   North Carolina

   Tennessee

   Idaho

   Wyoming
   Opacity
limitation, %
     < 5
     < 5

     <20

      40

      40

      40*

      401

      40*

      401
EPA Method 9.   6-minute  averages.

Twenty percent opacity limitation for new sources per
SIP definition of new source.
                             7-4

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(Ib/ton)] would therefore penalize the operator when he is



processing an unusually moist feed, since the residence time



for the material would be longer and attrition of the rock



would be greater than when the rock is less moist and passes



through the dryer quickly.  The reverse would be true  (the



standard would be unduely lenient) for an operator drying



rock with a low moisture content.  The effect of the mois-



ture in the rock on suppression of emissions is not known,



but is not believed to be great enough to cancel the effect



of greater residence time on emissions.



7.2.1.2  Mass per Unit Heat Input—



     A standard based on mass per unit heat input [g/J  (lb/



10" Btu)] would penalize the operator when he processes very



dry rock because the amount of heat applied per ton of rock



(i.e., the denominator of the standard units) would be



unusually small.



7.2.1.3  Concentration and Mass Rate—



     Standard formats of concentration [g/dry std. m



(gr/dscf)] and mass rate [kg/h (Ib/h)] would provide the



same degree of fairness for a given dryer over a given



period of time, since concentration relates mass emissions



to gas volume, and mass rate relates mass emissions to time.



The allowable mass rate must be specific to a certain pro-



duction rate since, as production increases, gas volume and
                             7-5

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particulate emissions will increase.   Concentrations of



emissions are somewhat independent of production rate.



     Circumvention of a concentration standard is possible



by dilution of the gas stream.   This  is unlikely, however,



since the size and operating costs of the control device are



functions of the volume of gas  treated.  Dilution of the gas



stream after the control device can be specifically dis-



allowed by the wording of the regulations.   An example of



such wording is found in §60.12 of the General Provisions of



40 CFR Part 60.



     To develop a standard based on mass per unit time



(kg/h), emissions should be investigated from a number of



different sizes of dryers because larger units will, of



course, have greater emission potential than smaller ones.



7.2.1.4  Equipment Specifications—



     Specification of the control equipment to be used might



be a viable option for control  agencies whose funds for



performance tests are limited or nonexistant.  A major



disadvantage of this kind of standard is that the operator



has little incentive to keep the control system operating at



peak performance levels.  Required maintenance programs



could accompany the equipment specifications, but the burden



of proving inadequate maintenance would be on the control



agency.  Another disadvantage is the  lack of flexibility it



gives the operator in choosing  the control system he prefers.
                               7-6

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7.2.1.5  Visible Emissions--
     Visible emission standards also have the advantage of
being inexpensive to administer.   The major disadvantages of
visible emission standards are the decreased enforcement
potential  at night and during adverse atmospheric conditions
(i.e., fog, rain, overcast sky),  and the inability to relate
plume opacity to actual mass emissions.  Visible emission
standards are also open to the charge that enforcement is
too subjective, and water vapor in the plume can make
observations difficult.
     The Environmental Protection Agency has frequently
promulgated visible emission standards to accompany regula-
tions of mass emissions.  Such an arrangement allows the
operator to install control equipment designed to meet the
mass emission rate.  Then, if the control system fails (as
indicated by visible emissions),  the control agency has a
legal basis for requiring repairs without having to perform
an expensive mass emission measurement.
7.2.2  Calciners
     Considerations for formats for  standards to apply to
calciner emissions are the same as those discussed for
dryers.
7.2.3  Grinders
     A format relating mass emissions  to unit heat input  is
                           7-7

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obviously not applicable to standards for grinders.  With



that exception, the pros and cons of formats for standards



for grinders are the same as those discussed for dryers.



However, an additional consideration is necessary when



evaluating a format to apply to standards for existing



grinders.  Neither feed nor production rates are typically



measured at grinders.  When the material into or out of a



grinder is measured, the method is usually crude, intended



only to estimate the flow of material.  One plant tested by



EPA measures the depth of rock in the ground rock silo at



the end of a shift.  That information, coupled with measure-



ments of feed to the silo and from the silo to subsequent



processes, permits an estimation of the grinding rate.



Another plant measures, with a ruler, the height of rock at



the center of a moving conveyor belt.  The belt speed is



then measured to obtain production rate.



     Because of the lack of accurate flow measuring capa-



bilities at currently operating grinders, the standard for



grinders should not have production or feed rate as an



integral part of the format unless there is also a require-



ment for the affected plant to institute an accurate flow



measurement technique.  There are no technical reasons why



rock flow into or out of a grinder cannot be measured



accurately.
                               7-8

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7.2.4  Grcmnd-rock Transfer Systems



     As explained in Chapter 2, there are several kinds of



ground-rock transfer systems.  The type of system used will



often limit the choices of formats for a standard.  If an



enclosed screw conveyor is used, the only potential sources



of emissions are from the conveyor housing or the silo fed



by the conveyor.  Formats for this type of system would be



limited to a measurement of visible emissions from the



conveyor and/or the silo.  The silo will be closed to



protect the ground rock from the weather, but may have a



breathing port to equalize pressure inside the silo during



loading and unloading of the ground rock.  The breathing



port could be ducted to a control device, in which case the



device could be made subject to a standard with one of the



formats discussed for dryers (except the one relating



emissions to heat input).  Because materials flowing



through the silo usually are not measured, one of the



formats that does not rely on such a measurement would be



desirable.



     The most common ground-rock transfer systems are those



that use pressurized air to move the rock, such as the dust



pump (the most common system) or the air slide.  With these



systems, there is always an air discharge, usually at the



receiving silo.  This discharge is usually controlled to
                              7-9

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prevent product loss from the dust-laden air stream.  Emis-


sions from the control device are thus amenable to regula-


tion using one of the formats discussed for dryers (except


the one relating emissions to heat input).   Materials flow,


however, is typically not measured.

                          2
7.3  ENFORCING REGULATIONS


     The enforcement aspects of the standards and regula-


tions just discussed are given in this section.


7.3.1  Dryers


     Factors affecting the level of uncontrolled emissions


from phosphate rock dryers include the design and operation


of the dryer and the type of rock being dried.  The effect


of process design and operation on uncontrolled emissions is


discussed in Chapter 2.  The operator usually has little


control over the design of the dryer after  it is installed,


and operation during a compliance test should not differ


from the way the process is normally operated.  The com-


pliance test should be performed while the  dryer is opera-


ting at the maximum production rate at which it is expected


to run in the future, which may be greater  than design para-


meters indicate.  As stated in the facility descriptions in


Appendix A, dryers are designed for a certain degree of


moisture removal, and production at this moisture removal


rate will be a function of the characteristics of the feed
                                7-10

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to the dryer.  Generally, production throughput at a con-



stant moisture-removal rate will be greater for small, dry



feed than for large, wet feed.  The enforcement official



should therefore be concerned with the heat input Cfuel



addition rate) to the dryer, production throughput,  and type



of feed.  Some dryers are designed to burn more than one



kind of fuel  (i.e., natural gas or fuel oil).  In these



cases, emissions from the dryer should be sampled while the



dryer is burning the dirtiest fuel it will be burning.



     The type of rock being processed by the dryer may



affect emissions from some dryers processing rock from the



Florida deposits.  The Florida rock falls into two classi-



fications, pebble rock and concentrates.  Most operators



indicate that they experience greater particulate emissions



when drying pebble rock than when drying concentrates be-



cause the pebble rock goes through fewer washings in the



beneficiation process (see Chapter 2), which causes it to



have more clay adhering to its surface.  Attrition in the



dryer causes submicron-sized clay particles to be sloughed



off, resulting in greater emissions to the control system.



Though data comparing emissions while drying pebble rock



with emissions while drying non pebble rock are not avail-



able, this appears to be a valid claim.  The EPA performance



tests were conducted while at least half of the rock being



processed was pebble rock.
                               7-11

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7.3.2  Calciners



     The enforcement aspects for calciners are essentially



the same as those presented for dryers.  The only noteworthy



difference is that is is unlikely that any units will be



built to calcine Florida rock, so the possibility of pro-



cessing pebble rock in the calciner need not concern the



enforcement official.



7.3.4  Grinders



     Phosphate rock grinders are of two basic designs:  ball



mills and roller mills.  Ball mills are usually ducted to a



single control device; however, roller mills are frequently



operated in parallel, with several ducted to one control de-



vice.  Therefore, it is incumbent on the enforcement offi-



cial to be certain that all mills ducted to the control



device are operating during the compliance tests.  Types of



raw materials do not affect emissions from phosphate rock



grinders.



     Factors that affect production rate from phosphate rock



grinders are the mesh size (fineness) of the grind and the



design of the grinder.  Generally, emissions per ton of



production will increase as the rock is ground to smaller



mesh sizes.  To increase the fineness of the grind, the



operator must increase the residence time of the rock in the



grinder, biasing the particle size distribution toward the
                               7-12

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smaller sizes.  However, the process that will utlimately



use the ground rock has been designed to accept a certain



size rock, typically 60 percent through 200 mesh, and oper-



ates most efficiently with that size.  Therefore, fineness



of the grind is not generally a parameter that the operator



changes frequently.  As with dryers and calciners, pro-



duction throughput of grinders is incidental to other con-



siderations.  Production tonnage decreases as the mesh size



being produced gets smaller.  Once the product size is set,



the operator usually monitors the amperage of the mill motor



and/or mill fan and runs the grinding mill at the maximum



production rate possible without damaging the equipment.



The enforcement official should obtain these operating



limitations from previous operating data (usually available



from past log sheets) or, if necessary, from design data.



7.3.5  Ground-rock Handling Systems



     If a ground-rock handling standard only regulates



visible emissions, the performance test should be performed



only during clear days when visible emissions can be deter-



mined accurately.  Also, because the ground-rock handling



system usually operates intermittently, the performance test



must be scheduled when the system will be operated for the



duration of the observations.
                                7-13

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                         REFERENCES
1.    Memorandum to Don R.  Goodwin,  Director of Emission
     Standards and Engineering Division,  U.S.  Environmental
     Protection Agency,  Research Triangle Park, North Caro-
     lina,  from Chiefs of  Industrial Studies Branch and
     Standards and Cost Analysis Branch.   Subject:  Recom-
     mended Standards of Performance for  the Phosphate Rock
     Processing Industry.   February 27,  1976.

2.    Standards Support and Environmental  Impact Statement.
     An Investigation of the Best Systems of Emission Re-
     duction for the Phosphate Rock Processing Industry.
     Draft.  OAQPS,  ESED.   U.S.  Environmental Protection
     Agency, Research Triangle Park, North Carolina.   Febru-
     ary 1976.
                               7-14

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                     8.0  REGULATORY OPTIONS

     This chapter presents a discussion of the various
regulatory options -available for the control of particulate
emissions from phosphate rock processing plants.   Regulatory
options are discussed in terms of applicable control  technology;
new versus existing plants; environmental, energy, and cost
impacts; emissions limits; format of emission limits  or
standards; and process modifications.
8.1  CONTROL TECHNOLOGY AND IMPACTS
     Alternative control technologies are fabric  filtration,
wet scrubbing, and electrostatic precipitation.  Electrostatic
precipitators are not used in grinder operations  and  fabric
filters are not being used on calciners or dryers; however,
these technologies are believed to be feasible.  Wet  grinding is
considered a feasible control technology by process change
if the rock is to be used in wet process phosphoric acid
plants.
     Table 8-1 summarizes the estimated energy, environmental
and cost impacts at various levels of emission control.
Air, water, solid waste, energy and cost impacts  are  discussed
in Sections 8.1.1 through 8.1.5; however, it can  be generally
stated that fabric filtration can achieve highest emission re-
duction for the least cost and generates no wastewater.  There
are no differences in energy, environmental, and  cost impacts

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                             Table 8-1.   SUMMARY  OF  IMPACTS  OF  APPLYING  ALTERNATIVE CONTROL  TECHNOLOGIES


Systems
45 Mg/h
(50 tons/h)

Dryer
272 Mg/h
(300 tons/h)

18 Mg/h
(20 tons/h)

Calciner
63 Mg/h
(70 tons/h)

45 Mg/h
(50 tons/h)
Grinder
136 Mg/h
(150 tons/h)

Impacts

Fabric filter
Scrubber
ESP'

Fabric filter
Scrubber
ESP'
Fabric filter
Scrubber
ESP'

Fabric filter
Scrubber
ESP1'
Fabric filterJ
Scrubber

Fabric filterj
Scrubber
AEL3

A1rd
13 (1.8)
13 (1.8)
13 (1.8)

26 (2.3)
26 (2.3)
26 (2.3)
13 (1.7)
13 (1.7)
13 (1.7)

21 (1.8)
21 (1.0)
21 (1.8)
5.1 (1.0)
5.1 (1.0)

9.0 (1.3)
9.0 (1.3)

Water6
0.0
3.7
0.0

0.0
3.7
0.0
0.0
8.0
0.0

0.0
8.0
0.0
0.0
1.0

0.0
1.0
Solid,
W.-'.te
0.19
0.19
0.19

0.19
0.19
0.19
0.44
0.44
0.44

0.43
0.43
0.43
0.00
0.09

0.00
0.09

Energy*)
3.9
12.
2.1

3.9
12.
2.1
' 8.5
17.
4.7

8.5
17.
4.7
1.6
4.6

1.6
4.6
Annua '
costh
90
14?
334

369
598
711
80
130
320

210
330
530
20
60

34
161
SIP,b

Aird
13 (1.8)
98 (13)
98 (13)

26 (2.3)
42 (3.7)
42 (3.7)
13 (1.7)
73 (10)
73 (10)

21 (1.8)
51 (4.4)
51 (4.4)
5.1 (1.0)
207 (39)

9.0 (1.3)
143 (21)

Water*
0.0
3.7
0.0

0.0
3.7
0.0
0.0
8.0
0.0

0.0
8.0
0.0
0.0
1.0

0.0
1.0
sona
Wastef
0.19
0.18
0.18

0.19
0.19
0.15
0.44
0.44
0.44

0.43
0.43
0.43
0.00
0.09

0.00
0.09

Energy?
3.9
8.0
2.1

3.9
8.0
2.1
8.5
11.
4.7

8.5
11.
4.7
1.6
3.1

1.6
3.1
Annual
cost"
90
124
278

369
494
689
80
115
270

210
280
485
20
57

34
151
SIPiC

Aird
13 (1.8)
140 19)
140 (19)

26 (2.3)
61 (5.4)
61 (5.4)
13 (1.7)
96 (13)
96 (13)

21 (1.8)
71 (6.1)
71 (6.1)
5.1 (1.0)
285 (54)

9.0 (1.3)
197 (28)

Water6
0.0
3.7 •'
0.0 ,

0.0
3.7
0.0
0.0
8.0
0.0

0.0
8.0
0.0
0.0
1.0

0.0
1.0
Solid
waste^
0.19
0.18
0.18

0.19
0.19
0.15
0.44
0.44
0.44

0.43
0.43
0.43
0.00
0.09

0.00
0.09

Energy9
3.9
6.0
2.1

3.9
6.0
2.1
8.5
8.5
4.7

8.5
8.5
1.7
1.6
2.3

1.6
2.3
Annual
costh
90
117
269

369
442
668
80
100
260

210
250
465
20
54

34
146
CO
 I
           AEL * alternative emission levels; 0.07 g/dry std. m  (0.03 gr/dscf) outlet for dryers  and calciners;  0.023 g/m  (0.01  gr/dscf) outlet for grinders.
           SIP? = most  stringent state regulation; see Appendix B.
           SIP] = least stringent state regulation; see Appendix B.
           Expressed  as maximum ground level concentration, ug/m , 24-hour max. (annual mean).   Fabric filter is  assumed to reduce emissions to AEL
           regardless of applicable regulation.  Si  Tables 5-1, 5-2, and 5-3.
           Expressed  as percent increase in total plant wastewater volume, assuming no recycle  of  scrubber water.
           Expressed  as maximum expected percent increase in  total plant solid waste generation.   See Tables 5-7,  5-8, and 5-9.
           Expressed  as percent Increase in equivalent fossil fuel energy over process energy requirements.  See  Section 5.5.
           Expressed  in thousands of 4th quarter 1977 dollars.  Retrofitted carben stPel systems.   See Chapter 4.0.
           A  wet-type ESP generates  a wastewater strew.  The  water pollution Impact 1s estimated to be  approximately that of a wet scrubber.
           Collected  dust is recycled and product recovery credits are included 1n annual  costs.

-------
for fabric filtration for a specific operation regardless of
required emission level.   Despite the advantages of lower
cost and environmental impacts for fabric filters, wet
scrubbers are the most popular control  method used by the
industry for dryers and calciners.
     For complete plants  including beneficiation, there is
no potential for significantly increased solid waste or
water pollution impacts,  regardless of control technology,
emission level, or plant size.  This is because of the
relatively large amounts of wastewater and solid waste
generated by beneficiation.
     The energy impact from the use of wet scrubbers is con-
siderably more than for ESP's or fabric filters, especially
at the more stringent control levels.
     The cost of applying control technology  is much higher
for ESP's than for fabric filters or wet scrubbers.
     Fabric filters are the most popular and  least expensive
control method for grinder emissions.  The primary advan-
tages of dry collection are that it provides  excellent
control of air emissions, has no attendant aqueous efflu-
ents, and facilitates recovery of valuable product.
8.1.1  Air Quality
     Emissions and air impacts are significantly different
for the AEL and SIP control levels, especially on the smaller
capacity units.  Air emissions from dryers and calciners  can
be up to about 10 times higher at the SIP level  compared  to
                               8-3

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AEL control.  The emissions from small grinders at the SIP]
control level are about 60 times those for the AEL control.
This comparison for the large grinder is a factor of 20.
The reason for the widespread difference in emission and
air impact is because SIP levels are based on rates of mass
emissions which yield relatively high outlet grain loadings
of 2.3 g/dry std. m  (1.0 gr/dscf), whereas AEL control is
based directly on relatively low concentration, i.e.,
 0.07 g/dry std. m3 (.0.03 gr/dscf).
     As shown on Table 8-1, the system with the least air
impact would be any one that operates with emissions equiva-
lent the AEL.  If fabric filtration is chosen to achieve
this emission limitation, cost and water impacts will be
less than the cost and water impacts from scrubbers or
ESP's.  Energy requirements for a fabric filtration system
are greater than those for an ESP.  Solid wastes will be the
same regardless of the control device chosen to achieve the
AEL for a given process.
     If an operator chooses a high-efficiency scrubber to
achieve the AEL, he will do so at the expense of greater
costs resulting from the high energy requirements necessary
to maintain a sufficient pressure drop sufficient to attain
the low emission rate.  In addition, aqueous effluents
generated by the scrubber will have to be piped to a receiv-
ing pond or treated before discharge to public waters.
     Negative aspects of selecting a system with the least
                            8-4

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impact on air quality can be increased solid wastes, increased
water effluents (unless a fabric filter or dry ESP is chosen),
higher energy requirements, and greater cost.  Solid wastes
attendant to achieving the AEL increase from 0 to 117 percent
over the SIP^ level.  Water effluent volume from venturi
scrubbers is the same for all levels of control for a given
operation.  Increased energy required to achieve AEL range
from 0 to 100 percent over that required to achieve the SIP-j
level, and annual costs increases range from 0 to 35 percent,
depending on the control device chosen.
8.1.2  Water Pollution Impact
     The control systems with the least water pollution
impact are the fabric filter and dry ESP because no water  is
discharged from these units.  The use of an ESP or fabric
filter will also result in an energy savings of 40 to 65
percent over the energy required by wet scrubbers at the
SIP, level and 45 to 80 percent at AEL control.  Air and
solid waste impacts are identical at the same control level
for each control option and process.  Costs of the fabric
filter do not increase with control level; costs of the ESP
Increase from 20 to 35 percent from SIP-, to AEL control.
     As stated on page 8-3, for complete plants that include
beneficiation the small increase in water pollution impacts
(regardless of control technology, emission level, or plant
size) is due to the relatively large amount of wastewater
generated by beneficiation.
                             8-5

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8.1.3  Solid Waste Impact
     When fabric filters are used to control emissions from
phosphate rock grinders, no solid waste is generated because
the collected dust is recycled, and no wastewater is discharged,
This is one reason why the annual cost of using fabric
filters on grinders is 20 to 35 percent lower than when wet
scrubbers are used.
     The solid waste impacts increase about 0.2 percent for
dryers and 0.4 percent for calciners, regardless of size,
control device, or control level.  The solid waste impact is
very small for any regulatory option since relatively large
amounts of solid waste are generated by beneficiation.
8.1.4  Energy Impact
     Use of an ESP will decrease energy demand by 50 to 80
percent below that required by scrubbers at AEL control and
45  to  65 percent at SIP-,, depending on process size.  Fabric
filters require 85 percent more energy than the ESP's.
However, annual costs for electrostatic precipitators are
from 80 to 270 percent more than fabric filters and 18 to
160  percent more than scrubbers, depending on process, size,
and  control level.  Also, the use of ESP's to attain SIP  levels
results in the sacrifice of the  incremental emission reduction
achieved by fabric filters.  Emissions are about 2 to  10  times
higher with ESP's  than with fabric filters, depending on  the.
process and process size.
                               8-6

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     The control system with the least energy impact for the
grinding operation is the fabric filter, which requires 30
to 65 percent less energy than scrubbers.  As previously
stated, no wastewater or solid waste is generated, and the
costs are 37 to 79 percent of those for scrubbers.  Emissions
are 20 to 60 times greater when using scrubbers than
when using fabric filters at SIP-j, depending upon the size.
8.1.5  Cost Impact
     The least costly control system for each of the processes
is the fabric filter.  The annual cost of other control
systems ranges from 1.2 (large calciner/scrubber/SIP1) to
4.7 times (large grinder/ scrubber/AEL) the annual cost of
fabric filters, even though fabric filters consume almost
twice as much energy as ESP's.  As stated before, no wastewater
is generated, and the solid waste impact from dryer and cal-
ciner fabric filters is no more than that for scrubbers and
ESP's,  A major advantage of fabric filters on the grinder
is the ability to recycle the dust that is collected.
8.2  NEW VERSUS EXISTING PLANTS
     Regulatory options specified for each process would not
be different for new versus existing plants.  There are
usually no technical or physical constraints that would
preclude the installation of a certain control device on an
existing facility if it can be applied to a new facility.
Space restrictions may be encountered in retrofitting (i.e.,
replacement of a scrubber with a fabric filter), which would
would
                           8-7

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increase the capital cost but would not preclude the use of
fabric filtration.
 8.3  EMISSION LIMITS
     When evaluating appropriate emission limits for a
regulation, one must consider the control equipment that the
emission limit will require.   The capabilities of fabric
filters, ESP's and scrubbers  are discussed below.
8.3.1  Fabric Filters
     Fabric filters, if operating properly, will deliver a
relatively constant emission  rate regardless of external
conditions such as pressure drop or inlet grain loading.  As
a result, a properly designed fabric filter will meet any of
the emission limits described in this chapter and will
exceed the requirements of the SIP-, and SIP,, emission limits.
As stated in Chapter 3, a properly operated fabric filter is
capable of reducing emissions from phosphate rock dryers and
calciners to less than 0.023  g/dry std. m  (0.01 gr/dscf).
For a typical 181 Mg/h (200 tph) phosphate rock dryer with
an exhaust flow rate of 44 m3/s (93,500 acfm), this would
result in an emission rate of 60 g/sec (8 Ib/hr).  For a typical
phosphate rock calciner operating at 41 Mg/h (45 tph) and 21.4 m3/s
(45,200 acfm) of exhaust gas, the emission rate would be 29.3 g/sec
(3.9 Ib/hr), and for a typical 91 Mg/hr (100 tph) phosphate rock
grinder with an exhaust gas flow rate of 5.2 m3/s (11,000 acfm)
the emission rate would be 7.2 g/sec (0.94 Ib/hr),
                            8-8

-------
     If fabric filters were allowed to operate at the AEL level of
                              •3
control [0.07 g/dry standard m  (0.03 gr/dscf) for dryers and
                                    o
calciners and 0.035 g/dry standard m  (0.015 gr/dscf) for grinders],
then the maximum allowable emission rates would be 180 g/sec (24 Ib/hr),
88 g/sec (11.7 Ib/hr), and 10.8 g/sec (1.41 Ib/hr), respectively, for
the typical  phosphate rock dryers, calciners, and grinders character-
ized above.
8.3.2  Electrostatic Precipitators
     As stated in Chapter 3, collecting surface (plate) area is
one of the most important factors affecting the dust collection
efficiency of electrostatic precipitators (ESP's).  Since ESP's can
theoretically be designed for any collection efficiency, economics
rather than  technical feasibility is the restraining factor when
considering  emission limits.
     The plate area theoretically needed for the typical phosphate
rock dryer [181 Mg/h and 44 m3/s (200 tph and 93,500 acfm)] would
range from 3,734 m2 (40,150 ft2) for the SIP1 level to 5,233 m2
(56,300 ft2) for the AEL level.  The typical phosphate rock
calctner [41 Mg/h (45 tph) and 21.4 m3/s (45,200 acfm)] would
require 1,604 m2 (17,251 ft2) and 2,530 m2 C27.205 ft2) for the
SIP, and AEL levels, respectively, and the typical phosphate
rock grinder [91 Mg/h (TOO tph) and 5.2 m3/s (11,000 acfm)]
would require from 252 m2 (2,712 ft2) to 699 m2 (7,517 ft2) for
those levels of control.
                                                          3
     For an  ESP designed to achieve 0.023 g/dry standard M
(0.01 gr/dscf) and the AEL level of control, the emission rates
will be the  same as those presented in Section 8.3.1 for dryers,
calciners, and grinders.  The emission rates for the SIP™ and
SIP2 levels  are tabulated below:
                              8-9

-------
Process
Dryer
Calciner
Grinder
Production Rate
Mg/hr (tph)
181 (200)
41 (45)
91 (100)
Exhaust Gas
flow rate
m /s (acfm)
44 (93,500)
21.4 (45,200)
5.2 (11,000)
Level of
Control
SIPI
SIP2'
SIP]
SIP2'
SIP,
SIP^
Emission Rate
g/sec (Ib/hr)
454
318
325
250
378
242
(60)
(42)
(43)
(33)
(50)
(32)
8.3.3  Venturi Scrubbers
     The primary factor affecting the particulate collection
efficiency of a venturi scrubber is the pressure differential (AP)
under which it operates.  Though the minimum AP required will differ
for each of the nine process/control level combinations, the maximum
AP required, as stated in Section 4.2.1, is 7.5 kPa (30 inches of water
gage).   The least stringent combination is the grinder operating under
the SIP.J regulation.  It is estimated that a AP of only 1.5 kPa (6
inches  water gage) would be required for this case.
     The emission levels resulting from the various process/control
level combinations will, of course, be the same as those presented in
Sections 8.3.1 and 8.3.2.
8.4  FORMAT OF EMISSION LIMITS
     As discussed in Chapter 7.0 there are several formats for speci-
fyina emission limits for emission sources in the phosphate rock
industry.   Generally, the most suitable format is a concentration
limit,  expressed as  g/dry std. m3 (qr/dscf) of a particulate matter
in the  outlet streams of control devices on all  emission sources.  In
                            8-10

-------
addition to the concentration limit, a maximum plume opacity
limitation can also be specified for each emission source.
8.5  PROCESS MODIFICATIONS
     The conversion of dry grinding operations to wet grinding
offers considerable environmental, energy, and economic
advantages when phosphate rock is produced for wet process
phosphoric acid plants.   This process change eliminates the
drying operation with its energy requirements and emissions,
and also eliminates emissions from grinding.  Any increases
in wastewater or solid waste are believed to be offset by
the benefits of the process.  As shown in Section 4.5,
considerable cost savings can be realized by use of wet
                                                        N
grinding (because of the reduction in energy consumption).
                               8-11

-------
              APPENDIX A.  SUMMARY OF TEST DATA






     A test program was undertaken by EPA to evaluate the



best particulate control techniques available for control-



ling particulate emissions from phosphate rock dryers,



calciners, grinders, and ground-rock handling systems.



This appendix describes the facilities tested and summarizes



the results of particulate tests and visible emission obser-



vations made by the EPA and operators.



     Two dryers, one calciner, and five grinders were tested



for particulate emissions using EPA Reference Method 5.



In addition, visible emission observations were made at two



dryers, one calciner, three grinders, and three ground-rock



handling systems.  These observations were made using EPA



Reference Method 9.  Results of the back-and front-half



catches from the particulate emission measurements conducted



are presented in Tables A-l through A-3.



DESCRIPTION OF FACILITIES



     A.  The oil-fired (No. 6 fuel oil) rotary dryer was



designed to reduce the moisture in phosphate rock from



between 10 and 15 percent to less than 3 percent.  Its pro-
                               A-l

-------
Table A-l.   PARTICULATE EMISSION TEST RESULTS ON  PHOSPHATE  ROCK DRYERS
                                    (S.I.  Units)
Facility
Process
Control Device
Date
Test time, min
Production rate, Mg/h
Stack effluent
Flow rate, m^/s
Flow rate, dry std. m-Vs
Temperature, °K
Water vapor, % vol.
Visible emissions at collector
discharge, % max. opacity
Particulate emissions
Probe and filter catch
g/dry std, m
g/actual m
kg/h
g/Mg
Total catch
g/dry std m
g/actual m^
kg/h
g/Mg
A3
Dryer
Venturi scrubber
AP = 4.5 kPa
I = 4.0 1/s
3/19/75
108
219

54.939
34.869
340.
26.6
0
0.0343
0.0259
4.27
19.5

0.117
0.0732
14.59
66.51
Aa
Dryer
Venturi scrubber
AP = 4.5 kPa
L = 4.0 1/s
9/4/74

327

51.45
30.68
344.
24.8
0
0.0503
0.0297
5.58
19.0

0.0984
0.0595
10.93
33.51
Ba
Dryer
Wet collector
4700 m2 ESP
3/20/75
108
353

62.479
52.836
316.
8.9
7.7
0.0229
0.0183
4.42
12.5

0.0297
0.0252
5.82
16.50
Bb
Dryer
Wet collector
4700 m2 ESP
6/10/74-8/14/74
N.R.
384

58.704
54 .444
N.R.
N.R.
N.R.
N.R.
N.R.
N.R.
N.R.

0.0526
0.0481
10.34
27.01
     EPA Test Method 5.
     Operator performed  tests using
   N.R. - Not recorded.
State of Florida Method.

-------
>
               Table A-la.   PARTICULATE  EMISSION TEST RESULTS ON  PHOSPHATE ROCK DRYERS
                                                  (English  Units)
Facility
Process
Control Device
Date
Test time, min
Production rate, tons/h
Stack Effluent
Flow rate, acfm
Flow rate, dscfm
Temperature, °F
Water vapor, % vol.
Visible emissions at
collector discharge, %
opacity (maximum)
Probe and filter catch
gr/dscf
gr/acf
Ib/h
Ib/ton
Total catch
gr/dscf
gr/acf
Ib/h
Ib/ton
Aa,b
Dryer
Venturi Scrubber
AP = 18 in. WG
L = 950 gpm
3/19/75
108
242

116,397
73,875
153
26.6
0
0.015
0.009
9.42
0.039
0.051
0.032
32.16
0.133
Aa
Dryer
Venturi Scrubber
AP = 18 in. WG
L = 950 gpm
9/4/74

360

109,000
65,000
160
24.8
0
0.022
0.013
12.3
0.038
0.043
0.026
24.1
0.067
Ba
Dryer
Wet Collector
50,600 ft2 ESP
3/20/75
108
389

132,371
111,940
110
8.9
7.7
0.010
0.008
9.74
0.025
0.013
0.011
12.84
0.033
Bc
Dryer
Wet Collector
50,600 ft2 ESP
6/10/74-8/14/74
N.R.
423

124,373
115,348
N.R.
N.R.
N.R.
N.R.
N.R.
N.R.
N.R.
0.023
0.021
22.8
0.054
                     EPA Test Method 5.
                     Company conducted test.
                   ° Operator performed tests using State of Florida method.
                   N.R. - Not recorded.

-------
Table  A-2.   PARTICULATE  EMISSION  TEST RESULTS ON PHOSPHATE  ROCK CALCINERSC
                                      (S.I.  Units)
Facility
Process
Control Device
Date


Test time, min
Production rate, Mg/h
Stack effluent
Flow rate, m /s
Flow rate, dry std. m /s
Temperature, °K
Water vapor, % vol.
Visible emissions at
collector discharge, %
maximum opacity
Particulate Emissions
Probe and filter catch
g/dry std. m
g/actual m
kg/h
g/Mg
Total catch
g/dry std. m
g/actual m^
kg/h
g/Mg
C
Calciner
Venturi Scrubber
AP = 3 KPa
L = 2.6 1/s
4/8-10/75


120
73

23.845
12.851
337
24.2

0



0.108
0.057
4.17
70. 0

0.121
0.064
5.57
75.0
cb
Calciner
Venturi Scrubber
AP = 3 KPa
L = 2.6 1/s
8/20/74


98
37.4

19.873
12.899
326
10.9

N.R.



0.096
0.062
4.29
120.0





Cb
Calciner
Venturi Scrubber
AP = 3 KPa
L = 2.6 1/s
3/9/75


120
58.8

22.869
15.461
328
6.37

N.R.



0.073
0.048
3.99
68.0





K
Calciner
Scrubber
t = 5-7.5 kPa
3/9/75
9/2/75
12/17/75
N.R.
23.3

5.176
N.R.
N.R.
N.R.

N.R.



0.057
N.R.
3.29
47.0





       a All tests conducted by EPA test Method 5.
        Conducted by company.
       N.R. - Not recorded.

-------
            Table  A-2a.   PARTICULATE  EMISSION TEST RESULTS  ON  PHOSPHATE ROCK CALCINERS*
                                                (English Units)
>
Facility
Process
Control Device
Date
Test time, min
Production rate, tons/h
Stack effluent
Flow rate, acfm
Flow rate, dscfm
Temperature, °F
Water vapor, % vol.
Visible emissions at
collector discharge,
% opacity (maximum)
Probe and filter catch
gr/dscf
gr/acf
Ib/h
Ib/ton
Total catch
gr/dscf
gr/acf
Ib/h
Ib/ton
C
Calciner
Venturi Scrubber
AP = 12 in. WG
L = 600 gpm
4/8-10/75
120
80

50,520
27,226
146.7
24.2
0
0.047
0.025
9.20
0.14
0.053
0.028
12.29
0.15
C
Calciner
Venturi Scrubber
AP = 12 in. WG
L = 600 gpm
8/20/74
98
41.2

42,103
27,328
127
10.90
N'. R.
0.042
0.027
9.46
0.24




C
Calciner
Venturi Scrubber
AP = 12 in. WG
L = 600 gpm
3/9/75
120
64.8

48,451
32,756
132
6.37
N.R.
0.032
0.021
8.80
0.136




K
Calciner
Scrubber
AP = 20-30 in. WG
3/9/75
9/2/75
12/17/75
N.R.
25.7

10,967
N.R.
N.R.
N.R.
N.R.
0.025
N.R.
7.26
0.094




                    All tests are conducted by EPA Test Method 5.
                    Conducted by company.
                   N.R. - Not recorded.

-------
          Table A-3.   PARTICULATE  EMISSION TEST  RESULTS  ON  PHOSPHATE ROCK  GRINDERS
                                                 (S.I.  Units)
Facil ity
Process
Control Device
Date
Test time, min
Production rate, Mg/h
Stack effluent
Flow rate, m /s
Flow rate, dry std. m-Vs
Temperature, °K
Water vapor, % vol.
Visible emissions at
collector discharge, %
maximum opacity
Particulate emissions
Probe and filter catch
g/dry std. m
g/actual m
kg/h
g/Mg
Total catch
g/dry std. m
g/actual m
kg/h
g/Mg
Da
Grinder
Fabric Filter
1/12/73
128
116

7.03
6.42
320
5.70
N.R.

0.0242
0.0165
0.4981
4 .40
0.0295
0.0217
0.649
0.60
3
E
Grinder
Fabric Filter
2/16/73
120
31.8

1.563
1.278
345
5.97
N.R.

0.0149
0.0121
0.0680
2.10
0.0311
0.0254
0.142
4.45
F3
Grinder
Fabric Filter
Pulsed-air, filter
velocity = 2 cm/s
3/25/75
120
70.3

3.912
3.136
337
8.91
0

0.0046
0.0023
0.0467
0.650
0.0069
0.0046
0.0658
0.950
I*>
Grinder
Fabric Filter
Pulsed-air, filter
velocity = 2 cm/s
1/3/74-6/27/74
N.R.
N.R.

N.R.
2.423
N.R.
N.R.
N.R.

N.R.
N.R.
N.R.
N.R.
0.0064
N.R.
0.054
N.R.
Ga
Grinder
Fabric Filter
Pulsed air, filter
velocity = 2 cm/s
4/7/75
200
73.6

3.145
1.947
386
0.0
0

0.0048
0.0032
0.0363
0.450
0.0071
0.0043
0.054
0.650
G"
Grinder
Fabric Filter
Pulsed-air, filter
velocity = 2 cm/s
10/3/73
120
47.2

3.890
2.628
350
0.28


0.0112
0.0076
0.109
2.25




  EPA Test Method 5.
fc WP-50 Test Method conducted
N.R. - Not recorded.
by company.  Range of 15 tests over a 6-month period.

-------
              Table A-3a.   PARTICULATE  EMISSION TEST RESULTS ON PHOSPHATE  ROCK GRINDERS
                                                   (English Units)
-j
Facility
Process
Control Device
Date
Test time, min
Production rate, tons/h
Stack Effluent
• Flow rate, acfm
Flow rate, dscfm
Temperature, °F
Water vapor, % vol.
Visible emissions at
collector discharge, %
maximum opacity
Particulate emissions
Probe and filter catch
gr/dscf
gr/acf
Ib/h
Ib/toh
Total catch
gr/dscf
gr/acf
Ib/h
Ib/ton
Da
Grinder
Fabric Filter
1/12/73
128
124

14,900
13,600
116
5.70
N.R.
0.0098
0.0072
1.098
0.0088
0.0129
0.0095
1.43
0.0012
Ea
Grinder
Fabric Filter
2/16/73
120
35.0

3,312
2,708
161
5.97
N.R.
0.0065
0.0053
0.150
0.0042
0.0136
0.0111
0.314
0.0089
Fa
Grinder
Fabric Filter
Pulsed-air
A/C = 4
3/25/75
120
77.5

8,288
6,645
147
8.91
0
0.002
0.001
0.103
0.0013
0.003
0.002
0.145
0.0019
Fb
Grinder
Fabric Filter
Pulsed-air
A/C = 4
1/3/74-6/27/74
N.R.
N.R.

N.R.
5,133
N.R.
N.R.
N.R.
N.R.
N.R.
N.R.
N.R.
0.0028
N.R.
0.12
N.R.
Ga
Grinder
Fabric Filter
Pulsed-air
A/C = 5
4/7/75
200
81.1

6,663
4,124
235
0.0
0
0.0021
0.0014
0.08
0.0009
0.0031
0.0019
0.12
0.0013
Ga-c
Grinder
Fabric Filter
Pulsed-air
A/C = 5
10/3/73
120
52

8,241
5,568
171 *
0.28

0.0049
0.0033
0.24
0.0045




             EPA Test Method 5.
             WP-50 Test Method conducted by company.
           c Conducted by company.
           N.R. - Not recorded.
Range of 15 tests over a 6-month period.

-------
duction rate varies from 200 to 400 Mg/h (220 to 440 tons/h),



depending on the moisture content and the type of rock being



processed.  Florida land pebble was dried during each of the



EPA tests and during the first test conducted by the opera-



tor.  Flotation cell concentrates were being dried during



the second operator test.  Emissions from the dryer are



cleaned by a Ducon venturi scrubber which has a pressure



drop of 4.5 kPa  (18 in. WG) and uses 60 liters/s (950 gal/



min) of recirculated water.  The EPA tests were conducted



only while the process was operating normally.  Both EPA and



operator particulate measurements were performed using EPA



Method 5.  Visible emission measurements were made by EPA at



the scrubber exhaust in accordance with EPA Method 9.



     B.  One oil-fired rotary dryer and one oil-fired fluid



bed dryer were operated in parallel.  Nominal production



rates are 300 Mg/h (330 tons/h)  for the rotary dryer and 150



Mg/h (165 tons/h) for the fluid bed dryer;  however, actual



production rate is dependent on the amount of moisture and



type of rock fed to the dryers.   Both dryers were operated



normally at full capacity and processed 100 percent Florida



land pebble for each of the EPA tests.  Emissions from both



dryers are partially cleaned by two parallel impingement



scrubbers (one for each dryer).   Emissions from the scrub-



bers are combined and ducted to a two-stage wet electro-
                               A-j

-------
static precipitator (ESP), which has a total collecting area



of 4700 m2 (50,600 ft2! and a gas velocity of 0.47 m/s (1.53



ft/s).  The cleaned gas exits the ESP from two vertical



stacks.  The ESP was reportedly designed for approximately



twice the volume of gas currently being processed.  The EPA



particulate measurements were performed using EPA Method 5.



The operator conducted measurements using the State of



Florida Department of Pollution Control Method.  Visible



emission observations were made at the ESP exhausts in



accordance with EPA Method 9 -



     C.  A fluid bed, oil-fired (No. 2 fuel oil) calciner



was used to remove moisture and organics from phosphate



rock.  The calciner is designed to calcine 63.5 Mg/h  (70



tons/h), but the operator has increased the calcining



capacity to 73 Mg/h (80 tons/h) by drying a portion of the



feed prior to calcination.  Calciner emissions are cleaned



by an ARCO venturi scrubber, which has a pressure drop of 3



kPa  (12 in. WG) and uses about 38 liters/s (600 gal/min)



recirculated water.  Tests were conducted only while the



process was operating normally.  Both EPA and company



particulate measurements were performed using EPA Method 5,



and visible emissions were recorded using EPA Method 9.



     D.  A Kennedy Van Saun ball mill was used to grind



phosphate rock.  Production throughput is nominally rated at
                              A-9

-------
112 Mg/h (124 tons/h),  but is dependent on the degree of



fineness to which the rock is ground.  Emissions from the



grinder are cleaned by  a Mikro-Pulsaire baghouse.  Tests



were conducted only during normal process operation.



Particulate measurements were performed using EPA Method 5.



Visible emissions were  not recorded.



     E.  A Raymond roller mill was used to grind dried



phosphate rock.  Production throughput is nominally rated 32



Mg/h (35 tons/h), but is dependent on the degree of fineness



to which the rock is ground.   During the first two tests,



rock was ground to 65 percent through 200 mesh, and it was



ground to 90 percent through 100 mesh (65 to 85 percent



through 200 mesh), during the third test.  Emissions from



the grinder are cleaned by a baghouse.  Tests were conducted



only during periods when the process was operating normally.



Particulate measurements were performed using EPA Method 5.



Visible emission observations were not performed.



     F.  One roller mill and one bowl mill were operated in



parallel.  Production rates cannot be measured accurately,



but experience shows that the roller mill normally operates



at 25 Mg/h (27.5 tons/h) and the ball mill at 45 Mg/h (50



tons/h).   To determine  if mills are operating at full



capacity, an amperage reading is made of the mill motors and



fans.  Mills were operated at full capacity during all EPA
                               A-10

-------
tests.  Emissions from both grinders are combined and



cleaned by a baghouse, which has a superficial filter



velocity of 2 cm/s  (4 ft/min).   Tests were conducted only



while the process was operating normally-  The EPA particu-



late measurements were performed using EPA Method 5.  Par-



ticulate measurements made by the operator were performed



using Western Precipitation Method WP-50.  The results are



presented in Table A-3.  Visible emission observations were



made at the baghouse exhaust in accordance with EPA Method



9.



     G.  A Harding ball mill was used to grind calcined



phosphate rock to 50 percent minus 200 mesh.  Production



throughput is nominally rated at 54 Mg/h (60 tons/h).  Emis-



sions from the grinder are cleaned by a Mikropul, pulse-air



cleaned baghouse with a superficial filter velocity of 2.5



cm/s  (5 ft/min).  Tests were conducted only during periods



when the process was operating normally.  Both EPA and



company particulate measurements were performed using EPA



Method 5.  Visible emission observations were made at the



baghouse exhaust in accordance with EPA Method 9.



     H.  A pneumatic system was used to transfer ground



phosphate rock from a storage silo at a phosphate rock



grinder to a storage silo at a wet-process phosphoric acid



plant.  About 60 percent of the rock transferred was small
                              A-11

-------
enough to pass through a 200 mesh screen.  The system was



transferring about 54 Mg/h  (60 tons/h) of ground rock,



which is its normal operating rate.  It has an exhaust gas



flow rate of about 0.8 m /s (1700 dscfm).  Emissions from



the system pass first through a cyclone and then through a



Mikro-Pulsaire baghouse, which has an filter velocity of 2



cm/s (4 ft/min) .   Visible emission measurements were made at



the baghouse exhaust in accordance with EPA Method 9.



     I.  A fluid-bed, natural-gas-fired calciner was used to



remove moisture and organics from phosphate rock.  It was



designed to calcine 41.7 Mg/h (46 tons/h), but operator has



difficulty maintaining the design production rate because of



lack of surge capacity between calciner and grinder.



Calciner emissions are cleaned by an Entoleter Centrifield



scrubber, which operates in a range of 5 to 6 kPa (20 to



in. WG) pressure drop.  Particulate measurements were con-



ducted by the operator, using EPA Method 5, while the



calciner was operating normally.  Visible emissions were



recorded by EPA,  using EPA Method 9, but these measurements



were not recorded simultaneously with the Method 5 tests.
                               A-12

-------
         APPENDIX B - EMISSION REGULATIONS



ALTERNATIVE EMISSION LEVEL (AEL)


     On March 18, 1976, Federal New Source Performance Stan-

dards were recommended for dryers, calciners, grinders, and

ground-rock transfer systems.   However, as of the publication

of this document, standards have not yet been proposed.

     The tentative recommendations were to limit particulate

emissions from dryers and calciners to no more than 0.071  g/dry
      o
std.  m  (0.031 gr/dscf) and visible emissions to less than 10

percent opacity.  Particulate emissions from rock grinders
                                                     o
were  to be limited to no more than 0.030 g/dry std. m  (0.013

gr/dscf: and visible emission to less than 5 percent opacity.

Recommended NSPS for particulate emissions from ground-rock


transfer systems stipulated no visible emissions.  These

recommended emission levels were considered as the alternative


emission levels (AEL) used in this document.


STATE EMISSION LIMITATIONS

     Figure B-l illustrates the maximum allowable particulate

emission rate in pounds per hour as a function of process


throughput in tons per hour for sources covered  by

-------
State Implementation Plans (SIP).  Florida's regulation



(Appendix C)  is the most stringent; however, if Tennessee or



Wyoming sources are subject to state NSPS, then the allow-



able emissions for soucres in these states are the same as



for Florida sources.  Utah requires an emission reduction of




at least 85 percent.



     SIP emission levels are illustrated in terms of g/dry



std. m  (gr/dscf) in Figures B-2, B-3, and B-4 for dryers,



calciners, and grinders.  These figures compare uncontrol-



led, AEL, and SIP emission levels for the range of flow



rates given.



     Because a source meets mass emission limits does not



guarantee its compliance with opacity regulations.  This is



particularly true for processes with a small throughput



capacity.  The design of control equipment in this document,



especially scrubbers and electrostatic precipitators (ESP's),



is based only on meeting the mass emission limits, even



though in some cases this control is not sufficient to meet



opacity regulations.  The opacity of particulate emissions



is difficult  to predict since this property is dependent



upon stack diameter, velocity,  particle size and color, and



other variables.
                               B-2

-------
I
U)
                                                 PROCESS  THROUGHPUT, Mg/h.

                                                   5    10   20 30  50   TOO
                      300 500
              00
              to
              co
              <
              O
                                                                           A-A1 - FLORIDA REGULATION (NEW SOURCE
                                                                                 REGULATION FOR TENNESSEE AND
                                                                                 WYOMING).
                                                                           B-B1 - TENNESSEE, NORTH CAROLINA, IDAHO,1
                                                                                 MONTANA, AND WYOMING EXISTING
                                                                                 SOURCE REGULATIONS.
                UTAH - 85% CONTROL REQUIRED.
                                           2345    10

                                                   PROCESS
20 30  50   100      300500

THROUGHPUT,  tons/h
                          Figure  B-l.    State mass  emission limitations  for  new  and

                                                     •  a.-               2
                                                  existing  sources.

-------
               10
                8
                6
                5
                DRYER THROUGHPUT,  Mg/h
        20    30  40 50   70   TOO   150 200
                                                                   40(F506
              T   \   I
UNCONTROLLED PARTICULATE EMISSIONS
              1.0
              0.8
                                        STATE MASS EMISSIONS REGULATIONS
             0.04
             0.03

             0.02
             0.01
                                                    iff;
                                                    ^X INORTH CAROLINA, IDAHO,
                                                       ' -; ^MONTANA, WYOMING,
                                                         UTENNESSEE
                                                           FLORIDA
    RECOMMENDED NEW SOURCE PERFORMANCE STANDARD  (0-10% opacity)   -
    Emissions  from product  recovery cyclones.
    Calculated from maximum allowable emissions  (Ib/hr)
    and exhaust flow rate (250-450 scfm/TPH)and  25% v moisture
                               _L
               DRYER THROUGHPUT. TPH
               —I	1	1	I	I	I      III
                                                           20
                                                                              10
                                                                               8
                                                                               6
                                                                               5
                                                                               4
                                                                                     6

                                                                                     "O
                                                             1.0
                                                             0.8
                                                             0.6
                                                             0.5
                                                             0.4
                                                             0.3

                                                             0.2
0.10
0.08
0.06

0.04
0.03
                                                                                    o
                                                                                    £
                                                                                    o
                                                                                    to
                                                                                    §
                10
      20    30  40 50   70   100    150 200   300 400 500
                                                                            1000
 Figure  B  2.   Comparison of uncontrolled emissions  with
state  and  Federal  limitations  for  phosphate rock dryers.
                                   B-4

-------
             10
              8
              6
              5
              4
            1.0
         o>   0.6
          "   0.5
         I   0,

         t   0.3
         LU
         o
         8   0.2
         CO
         CO
            0.10
            0.08
            0.06
            0.05
            0.04
            0.03

            0.02
            0.01
                                CALCINER THROUGHPUT,  Mg/h
                         20    30   405060   80100      200  300400500
UNCONTROLLED EMISSIONS8
           STATE MASS EMISSIONS REGULATIONS15
                          if  (NORTH CAROLINA,  IDAHO,
                           i  } MONTANA, WYOMING ,  TENNESSEE
                           \i
                              FLORIDA

RECOMMENDED NEW SOURCE PERFORMANCE STANDARDS (0-10* opacity)
   "Emissions from product recovery cyclones.
    Calculated from maximum allowable emissions (Ib/hr)
    and exhaust flow rate (500-1000 scfm/TPH)and 255S v  moisture
                CALCINER THROUGHPUT, TPH
      i	i	i  i   i  i  i i  i         i     i    11  	
                                                       20
                                                       10
                                                        8
                                                        6
                                                        5
                                                        4
     •o
     ~-v
     a:
1.0    .
0.8   §
     I—
0.6   fl
0.5   ^
0.4   §
0.3   o

0.2   i
                                                        0.10
                                                        0.08
                                                        0.06
                                                        0.05
                                                        0.04
                                                        0,03
               10
  20    30  40 50 60  80 100
                                                      200   300 400500
                                                        1000
   Figure  B-3.  Comparison of  uncontrolled  emissions with
state and  Federal  limitations for  phosphate rock calciners
                                    B-5

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             0.06
             0.04
             0.03
             0.02
            0.013
             0.01
            o.ooaC
                                GRINDER THROUGHPUT, M
-------
            APPENDIX C




  FLORIDA AIR POLLUTION RULES OF




THE DEPARTMENT OF POLLUTION CONTROL
                 C-l

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                                               APPENDIX  G
                                    FLORIDA AIR POLLUTION RULES
                           OF THE DEPARTMENT OF  POLLUTION CONTROL

           (Florida Administrative  Code, Chapter  17-2, Air  Pollution; Amended February 11,
      1972; September 24,  1973; April 9, 1974; April 25,  1974; December 28, 1974; June 30,
      1975)
17-2.01  Declaration and Intent
  The State  of Florida Department  of Pollution Control
promulgates this chapter to eliminate, prevent, and  con-
trol air  pollution.  This chapter shall apply to all sources
of  air  pollution  except  open  burning  or  the  use of
outdoor heating devices allowed by chapter 17-5, Florida
Administrative  Code,  unless otherwise  provided in  this
chapter.
  To  protect and  enhance  the air quality of Florida, this
chapter  furthers the Department's nondegradation policy
and establishes  ambient air quality standards and emission
standards. The  policy inherent in the standards shall be to
protect  the air  quality  existing at the time  the air quality
standards  were  adopted  or to upgrade  or enhance the
quality  of the air of the Stale. In any event, where a new
or increased source of  air pollution poses a possibility of
degrading  existing  high air  quality or ambient air quality
established by   this chapter,  such  source  or proposed
source shall not be issued a Dcparlmcnt  permit  until the
Department has  reasonable assurance that  such  source
construction or development will  not violate this chapter.
  This  chapter is  adopted to achieve and  maintain  such
levels  of air  quality as  will protect human  health and
safety, prevent  injury to plant  and animal life and proper-
ty,  foster  the  comfort and  convenience of the people,
promote the economic and social development  of this
Slate  and facilitate the enjoyment of the  natural  attrac-
tions  of this State.
  Genera)  Authority  403.061   FS.  Law  Implemented
403.021, 403.031,  403.061  FS. History  - New 1-11-72.

17-2.02 Definitions
  The  following words and phrases when used  in this
chapter  shall, unless context clearly  indicates otherwise,
have the following meanings:
  (1) "Air pollutant"  — Any  matter found in the atmo-
sphere other  than  oxygen, nitrogen, water vapor,  carbon
djoxide  and the inerl gases in natural concentrations.
  (2) "Air pollutant source"  or  "source"  — Any source
at,  Irom, or by reasons of which  there is  emitted into the
atmosphere any air  pollutant(s).
  (3) "Process  weight"    The  total weight of all mate-
mis introduced into any process. Solid fuels and recycled
materials  arc  included  in  the  determination  of process
w-igiits, but  uncombmed  water, liquid and gaseous fuels,
combustion air  or excess air are not included.
   (4) "Standard  conditions"    A gas temperature of 70
degrees  fahrenheit and a gas pressure of 14.7 psia.
   (5) "Existing source" - A source  which is in existence,
(except  for  reactivation  of older  plants) operating or
under construction  or has received a permit  to construct
prior to the effective date of this chapter.
   (6) "New Source" — Any source other than an existing
source.  New source includes  reactivating existing  or older
plants which have been  shutdown  for  a period  of more
than one year.
   (7) "Particulate matter"  - Means any  material, other
than uncombined water,  which  exists in a finely  divided
form  as a  liquid or solid, as measured  by the sampling
methods approved by the  Board.
   (8) "Sulfuric  Acid  Plant" — Means  any  installation
producing sulfuric acid by the contact process by burning
elemental  sulfur, alkylation  acid, hydrogen  sulfides, or-
ganic sulfidcs and mercaptans, or acid sludge.
   (9) "Acid mist" - Means  any si/.c liquid drops of  any
acid including but not limited to sulfuric acid and sulfur
trioxide, hydrochloric acid and nilric acid as measured by
test methods approved  by  the Board.
   (10)  "Visible emission" -  Means an  emission  greater
than 5  percent opacity or  1/4 Ringclmann measured by
standard methods.
   (II)  "Fugitive  particulatc"    Particulate mailer which
escapes  and becomes airborne from unenclosed operations
or which is emilled  into  the atmosphere without  passing
or being conducted  through a  flue  pipe, stack  or other
structure designed for the purpose of emitting air pollu-
tants into the atmosphere.
   (12)  "Air  Pollution  episode"  -  An  occurrence of
elevated levels  of pollutants in the  atmosphere which
require hasty and  unusual  abatement  action.
   (13) "Odor" - Means  a sensalion  resulting from stimu-
lation of the human olfactory organ.
   (14) "Objectionable Odor"  -  Any odor present in  the
outdoor atmosphere  which  by  itself  or in combination
wilh other  odors, is or may be  harmful or  injurious to
human  health or welfare, which unreasonably interferes
with  the  comfoitable  use  and  enjoymenl  of life  or
property, or which creates a nuisance.
   (15) "Fossil  fuel  steam gencralois"    Furnaces  and
boilers which produce steam by  combustion of oil, coal
or gas of fossil origin.
                                                        C-2

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  (16) "Plant section" - A part  of a plant consisting of
one  or  more  unit operations  including  auxiliary  equip-
ment which  provides  the  complete  processing of  input
(raw) materials to produce  a marketable  product, includ-
ing but not limited to, granular  triple super  phosphate,
phosphoric acid, run-of-pile triple super phosphate and
di-ammonium  phosphate, or one or  more unit operations
including  auxiliary equipment  or structures  which  are
used for the functions of,  including but not  limited to,
storage, shipping, loading, unloading, or bagging.
  (17) "Department"  - Means the State of Florida  De-
partment of Pollution Control.
  (18) "Director" - Means the Executive Director of the
Department.
  (19) "Volatile organic  compounds" or  "Organic Sol-
vents" -  Are any  compounds  containing carbon and
hydrogen  or carbon and hydrogen  in combination with
any  other element  which  has  a vapor  pressure of  1.5
pounds  per square inch absolute (77.6 mm.  Hg) or greater
under actual storage conditions.
  (20) "Portland  cement  plant" - Means any  facility
manufacturing Portland Cement by either the  wet  or  dry
process.
  (21) "Nitric acid  plant"  - Means any facility produc-
ing weak nitric acid  by either the  pressure or atmospheric
pressure process.
   (22) "Kraft Pulp Mill" - Means an industrial operation
which  processes  wood to  produce  cellulose  or cellulose
materials by means of chemically  cooking the wood with
a liquor consisting of an alkaline sulfide solution contain-
ing sodium hydroxide  and  sodium sulfide, also known as
the sulfate process.
   (23) "Sulphur Recovery  Plant" -  Any  plant that re-
covers sulphur from  crude (unrefined)  petroleum  mate-
rials.
  (24) "Ringelmann Chart" - Means the chart published
and  described in the  U.S.  Bureau of Mines Information
Circulars No. 8333 and No.  7718.
   (25) "Stagnant atmospheric  condition"  —  Denotes
when the atmospheric and  meteorological conditions will
reduce the necessary  diffusion and  dispersement  of air
pollutants in the atmosphere.
   (26) "Opacity" - Means a state which renders material
partially  or wholly  impervious to  rays  of light  causing
obstruction of observer's view.
  (27) "Carbonaceous   Fuel"   —  Means  solid  materials
composed  primarily  of vegetative matter  such as  tree
bark, wood waste, bagasse,  and/or the combustible frac-
tion  of municipal wastes.
  (28) "Fossil  Fuel"  - Means natural  gas,  petroleum,
coal  or any form of solid,  liquid,  or gaseous fuel derived
from such material.
  (29) "Carbonaceous   Fuel Burning  Equipment"  — A
fire  box,  furnace  or  combustion  device  which   burns
carbonaceous fuel  or a combination  of carbonaceous and
fossil fuel  for the primary  purpose  of producing thermal
energy which  is used  indirectly  to  produce steam  or to
heat  other  liquids or gases,  including,  but not limited to,
bagasse  burners, bark  burners, and  waste wood burners,
but  not  intended  to   include  teepee  or  conical   wood
burners or  incinerators.
  (30) "Latest Reasonably  Available  Control Technolo-
gy"  means air  pollution control equipment, facilities, or
devices  or processes  (including fuels  and  raw materials
used) which  cause or allow  the  least emission  of pol-
lutant^) and which have been  determined to  be reason-
ably available  in  accordance  with Section  17-2.03 (1),
Florida  Administrative Code.
  General  Authority 403.061   FS.  Law Implemented
403.021, 403.031, 403.061, 403.087 F.S.

 17-2.03 General Restrictions
   (1)  Latest Reasonably Available Control Technology.
   (A)  Determination - the  Department  shall determine
 Latest Reasonably Available Control Technology.
   (1)  In making  the determination the Department shall
 give due consideration to:
   a. Environmental  Protection  Agency determinations of
 Reasonably Available Control Technology pursuant to 40
 C.F.R.  Section 51.1 (o) and 40  C.F.R., Part 51, Appendix
 B;  and Environmental  Protection Agency determinations
 of  Standards of Performance  for New Stationary  Sources,
 pursuant  to 40 C.F.R., Part 60.
   b. AJ1  scientific,  engineering,  and  technical material,
 reports, publications, journals,  and  other  competent rele-
 vant information  made  available  to  or  known  by the
 Department.
   c. Recommendations  of  any.ad hoc technical  advisory
 committee  appointed  pursuant to  paragraph 3  of this
 Subsection (17-2.03 (1) (a)).
   d. The social and economic impact of the  application
 of  such technology,  including consideration of any useful
 life of presently  installed  control  equipment  and the
 amortization of the value  of  such equipment 'balanced
 with the  cost  and  advantages of the new  technology;
 public  interest  served  by  such equipment;   and  other
 appropriate factors, such as materials, manufacturing proc-
 esses,  all environmental  impacts,  control  and treatment
 technology  available,  ability   to  construct,  install, and
 operate the facility, energy  requirements, and cost.
   (2)  The Department shall specify and  publish its  deter-
 mination of Latest  Reasonably Available Control  Tech-
 nology by source  or  category of sources.
   (3)  To assist the Department in making the determina-
 tion of Latest  Reasonably  Available Control Technology,
 the Executive  Director  may  appoint an  ad hoc  technical
 advisory committee of persons  with expertise  and knowl-
 edge in  the particular  matter  under  consideration. The
 committee  shall be  representative  of scientific, affected
 industry, citizen, and conservation interests. If an affected
 party so requests  the committee shall be appointed.
   (4)  Any  citizen or affected  party may, in accordance
 with the Florida  Administrative Procedures Act, Chapter
 120, Florida Statutes, request  a  determination of Latest
 Reasonably Available Control Technology for  a source  or
 category  of sources.
   (5)  The  determination of Latest  Reasonably Available
 Control Technology shall  be  made  by   the  Board only
 after notice and public hearing  is requested by an affected
 party.

    (6)  Determinations  of  Latest   Reasonably   Available
 Control Technology shall  be periodically  reviewed by the
 Department, and  shall be subject to revision in accordance
 with  this  Section  17-2.03  (1),  Florida Administrative
                                                        C-3

-------
Code, subsequent  to such  review if the Hoard determines,
on  (lie  basis  of  competent  substantial  evidence,  that
different equipment, devices  or processes will  result in
reduction of emissions.
  (B) Application
  (1) If the application of the Latest Reasonably Availa-
ble  Control Technology  to  an air pollutant source will
result in lower or  improved  air pollutant  emissions,  then
the  Department shall require that  the  Latest Reasonably
Available Control Technology  be applied.
  (2) Exceptions.
  The  Latest  Reasonably Available Control Technology
shall not be required:
  a. If  there  is  an emission  limiting  standard  for the
source and it is being complied with; and
  b. If the source complies  with  all requirements of any
duly promulgated  air quality maintenance or improvement
plan adopted by the Department; and
  c. If the source complies  with  the Department  Rule
Section 17-2.03 (4) (b), Florida Administrative Code; and
  d. If the Department does not  find that public interest
factors other than  those in a., b., and c. above require the
use of  Latest Reasonably Available  Control  Technology.
In making  such a finding the Department shall;
   1. Give  due consideration to all  the following:
  (a) The   necessity  of imposing  the level  of emission
limitation which would be achieved  by the application of
such technology in order to  attain and maintain Ambient
Air Quality Standards  specified in Section  17-2.05,  and
prevent  degradation  of air  quality in accordance  with
these rules; and
  (b) The  social and economic impact of the application
of such technology, including consideration of any useful
life  of  presently  installed, permitted control equipment
and  the amortization  of the value of  such equipment
balanced with  the  cost  and  advantages of the  new  tech-
nology; and
  (c) The  energy  consumption  or  conservation  associated
with such technology; and
  (d) Alternative   means  of   providing  attainment   and
maintenance of the Ambient Air Quality Standards speci-
fied in Section  17-2.05, and the prevention of degradation
of air quality in accordance with these rules; and
  (e) Secondary  pollution problems created by the appli-
cation of any particular technology.
  2. Provide the  owner  or  operator of the source ade-
quate notice and an opportunity for public hearing.
  3. Set forth  its specific findings on applicable issues
and ultimate determination and the rationale therefor,  if
requested by a  party prior to the hearing.
  (3) For  those  sources  for  which  there is  no emission
limiting  standard,  the  application  of  Latest Reasonably
Available Control Technology shall  be required unless:
  (I)  The  owner of the source affirmatively shows that
  ( 1 ) The   source  complies with  all requirements of any
duly promulgated  air quality maintenance or improvement
plan adopted b> the Department; and
  (2) The   source  complies  with  the Department  Rule
Section  17-2.03 (4) (b). Florida Administrative Code; and
  (II)  The  owner  of the  source affirmatively shows and
the  Department finds after considering all the matters set
 foith  in (IJ)  (2)  d.  I.  lh;i( (he application  of L.RACT is
 not necessary to the  public interest.
   (2)  h'xisling Source Compliance   Mxccpt where com-
 pliance dates arc  specified, exJsting sources shall comply
 with this chapter as  expeditiously as possible  but in  no
 case later than July  1, 1975.
   (3)  Operation Rates - No plant or source shall operate
 at  capacities  which exceed the limits of  operation of a
 control device or exceed  the capability of the plant  or
 control device  to  maintain the  air  emission  within  the
 standard limitation imposed by this chapter, or  by permit
 conditions.
   (4) (a) Air  Quality Standards   Violated  - No  person
 shall build, erect,  construct, or implant any new source or
 operate, modify or rebuild an existing source or by any
 other means release or take action which  would result in
 release  of  air  pollutants  into  the  atmosphere  of any
 region, which will, as determined  by  the Board, result  in,
 including  concentrations of existing air pollutants, ambi-
 ent  air concentrations  greater than  ambient  air quality
 standards.
   (b)  Significant Degradation
   (i) "In  those  counties  of  the state   which  have  a
 baseline air  quality   better  than  that  defined  by the
 Ambient Air  Quality  Standards, Section  17-2.05, no per-
 son  shall  emit into  the  atmosphere any air  pollutant
 which   significantly  degrades  that  quality and  in such
 counties no  person   shall   construct  a  new  source   or
 expand an  existing source, groups of sources, or a com-
 plex source which by itself, or in  association with mobile
 sources, significantly degrades the baseline air quality."
   (ii) Whether a new source or proposed expansion of an
existing source will  significantly degrade the  baseline air
 quality  shall be determined  by  the  Board only after;
   a) Notice and hearing,
   b) Considering all relevant matters,  and
   c) The  source  owner has  affirmatively  demonstrated
 that the degradation is not contrary to the  public interest.
   (iii)  Increases of  air  pollution  levels  or  Baseline Air
Quality may  be determined by use of scientifically valid
predictive air quaJity dispersion models.
   (iv)  No  increase in pollutant concentrations above the
baseline  air  quality   will  be  allowed unless  the latest
reasonably   available   control  technology   is  utilized   to
control  emissions from the source.
   (v) The phrase  "Baseline Air Quality" means  the maxi-
mum concentrations   of  pollutants  in  the  ambient air
representative  of  one  of  the  following   calendar years
measured or estimated in the area in  which the proposed
new source  or expanded source would have a significant
effect:
   a) Calendar year 1973 for all sources except  fossil fuel
steam generators,
   b) Calendar year  1972 for all fossil fuel steam genera-
 tors, except such steam generators which were  burning
natural  gas during  this period of time, or
   c) For  those fossil fuel  steam  generators  which were
burning natural gas   during  1972, the baseline  will   be
calculated  as  if said  generators were burning  the BTU
equivalent of 2.5% sulfur content oil.
                                                       C-4

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   In the  absence  of ;iir  quality data, any approved ail
 tjtialily dispersion  model  may  be  used to  predict the
 Baseline Air Quality.
   (vi) This Subsection  17-2.03  (4)  (b), F.A.C., shall be
 effective for one year or until such  time that a superced-
 ing  rule is duly adopted; provided  however,  that  in the
 event a superceding rule is not adopted within a one year
 period this subsection shall cease to  be operative, and the
 Subsection 17-2.03 (4) (b),  which  was adopted  by the
 Florida Pollution Control Board  on January 11, 1972 and
 which became  effective  on January  18, 1972, shall be-
 come effective  and operative at  the  end of the one year
 period.
   (5) Concealment - No person shall build, erect, install
 or  use  any  article,  machine, equipment  or  other con-
 trivance, the  use of which will conceal an emission which
 would  otherwise  constitute  a violation  of any  of the
 provisions  of this chapter.
   (6) Circumvention  — No person  shall circumvent any
 air  pollution  control device,  or  allow  the emission of air
 pollutants  without the  applicable air pollution  control
 device operating properly.
   (7) Maintenance - All air pollution control  devices and
 systems shall  be properly and consistently maintained in
 order  to maintain  emissions  in  compliance with Depart-
 ment Rules.
   General  Authority  403.061   FS.  Law  Implemented
 403.021, 403.031, 403.061  FS. History - New 1-11-72.
 17-2.04 Prohibitive Acts
   (1)  Visible Emissions  -  No person  shall cause, let,
 permit, suffer or  allow  to be discharged into  the  atmo-
 sphere any air pollutants from:
•  (a)  Existing Sources, until  July  1, 1975, the  density of
 which  is  equal   to  or  greater  than  that designated as
 Number  2  on the Ringelmann  Chart  or the opacity of
 which  is equal to or greater than 40 percent.
   (b)  New   Sources,  and after July  1, 1975,  existing
 sources, the density of which is equal  to or  greater than
 that designated as Number 1  on the Ringelmann Chart or
 the  opacity of  which  is equal to or  greater than  20
 percent.
   (c)  This subsection  17-2.04(1) does not apply to emis-
 sions emitted in accordance with specified emission limit-
 ing standards or  in accordance  with  the process  weight
 table (Table I) provided in this chapter.
   (d)  It  the presence of  uncombined  water is the only
 reason for  failure  to meet visible emission standards given
 in this section such  failure shall not be a violation of this
 rule.
   (2)  Particulate  Matter  -  No person  shall cause, let,
permit, suffer, or  allow the emission of particulate matter
from any  air pollutant source in total quantities in excess
of the amount  shown in Table I, except  as otherwise
provided  for in this  chapter for  specific emission limiting
standards of particulate matter from specified  sources.
            PROCESS WEIGHT TABLE
                      TABLE I
Process
    Rate
(pounds per hour)
50      	
100     	
500     ...
1,000   	
5,000   	
10..000    ....
20,000    ....
60,000    ....
80,000
                                        Emission  rate
                                     (pounds per  hour)
                       	    0.03
                       	    0.55
                       	    1.53
                       	    2.2'j
                       	    6.3'i
                       	    9.73
                       	   11.99
                       	   ?6.90
                       	   31.19
 120,000   '.'.'.'.'.'.	33-28
 100,000	3'i.85
 200,001)	   36.11
 '100,000     	   10. '35
 1,000,000  •	'IC.V2

Interpolation of the data in Table I for the process weight
rates up to 60,000 pounds per hour shall be accomplished
by the use of the equation:  E=3.59P°-62 , P less than or
equal to 30  tons per hour and  interpolation and extra-
polation of the  data for process weight rates in excess of
60.000  pounds  per day shall be accomplished by use of
the equation: E= 17.3IP0-16 , P  is greater than  30  tons
per hour.  Where: E = Emissions in pounds per hour. P =
Process  weight  rate in tons per hour. Application of  mass
emission limitations  on the basis of all similar units at a
plant is recommended in  order  to  avoid unequal applica-
tion  of this  type of limitation  to plants  with the  same
total  emission  potential  but different size  units.  Upon
establishing  the  total  mass  limitation, individual source
emissions  will be determined by  prorating the mass emis-
sion  total on the basis of the percentage weight  input to
each source process.
   (3) Fugitive  Particulate — No  person  shall cause, let,
permit, suffer or allow the emissions of particulate matter,
from any source whatsoever, including but not limited to
vehicular movement, transportation of materials,  construc-
tion, alteration,  demolition  or  wrecking,  or industrially
related  activities such  as loading, unloading, storing or
handling,  without taking reasonable  precautions to  pre-
vent such emission, except  particulate matter emitted in
accordance with the  weight process table  (Table I), the
visible  emissions  standards  or  specific  source  limiting
standards specified in this chapter.
   (4) Objectionable  Odor Prohibited  — No  person  shall
cause, suffer, allow  or permit the  discharge  of air pollu-
tants which cause or  contribute to an objectionable odor.
   (5) Volatile  organic compounds  emissions or organic
solvents emissions.
   (a) No  person shall store,  pump, handle, process, load,
unload  or  use  in  any  process  or  installation  volatile
organic  compounds or organic solvents without  applying
known  and  existing  vapor  emission  control devices  or
systems deemed  necessary and ordered  by  the  Depart-
ment.
   (b) All  persons  shall  use  reasonable  care  to  avoid
discharging,  leaking,  spilling,  seeping,  pouring, or dumping
volatile  organic compounds or organic solvents.
   (6) Stationary sources -  No person shall cause, let,
permit,  suffer,  or allow  to be discharged into the atmo-
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sphere emission from  (he  following lislcd sources  greater
than any emission limiting standard given.
   (a)  Incinerators
   1.  The emission limiting standards for new incinerators
with a charging rate of fifty or more tons per day are:
   a. Particulate  matter - 0.08 grains  per standard cubic
foot dry gas corrected to 50 percent excess air.
   b.  Odor - there shall be no objectionable odor.
   2.  The emission limiting standards for new incinerators
with a charging rale of less than fifty tons per day  are:
   a. Visible  emissions     no  visible  emissions  except,
visible emissions are allowable for up to three minutes in
any hour at densities  up to but  not more than, a  density
of Ringelmann Number I. (Opacity of 20 percent)
   b.  Odor -- there shall be no objectionable odor.
   3.  As soon as possible,  but not later than July 1, 1975,
existing incinerators  shall comply with the standards for
new  incinerators except thai  the  particulatc matter emis-
sion  limiting  standard  for  existing incinerators  with  a
charging  rate of fifty  or  more tons per day shall  be 0.1
grains per standard  cubic  foot of dry gas corrected to 50
percent excess air.
   (b) Sulfuric Acid Plants   the emission limiting stand-
ards for sulfuric  acid plants arc:
    1.  Existing Plants
    a.  Sulfur dioxide (S02) — ten pounds of S02  per ton
of  100  percent  H2S04  produced, as  cxpcditiously as
 possible  but not later  than July  1, 1975; in  (he  Florida
 portion of  the Jacksonville. Florida -- Brunswick, Georgia,
 Interstate Air  Quality  Control  Region as defined in 40
 C.F.R. Section 81.91,  twenty-nine pounds of S02  per ton
 of  100  percent II:S04  produced as  cxpeditiously as
 possible but not later than July 1, 1975.
    b.  A plume with visibility of 5 percent opacity  (equiva-
 lent  to 1/4 Ringelmann Number), except for  30  minutes
 during plant startup  periods with opacity allowed up to
 40 percent (equivalent to  Ringelmann Number 2)
    2.  New Plants
    a. Sulfur dioxide  - four pounds  of S02  per ton of
 100 percent H2S04 produced
    b.  Acid  Mist -  0.15 pounds  per  ton of 100  percent
 acid produced.
    c.  No visible  emission except for  30 minute period
 during  startup,  but no greater  than  the opacity of 40
 percent (equivalent to Ringelmann Number 2)
    (c) Phosphate Processing - the emission limiting stand-
 ards for  phosphate processing arc:
    1.  Fluorides (water  soluble  or gaseous-atomic  weight
 19)  the  following  quantities  expressed  as   pounds of
 fluoride  per  ton  of  phosphatic  materials  input  to  the
 system, expressed as tons  of P;0S for
    a.  New plants or plant  sections:
    a  1. Wet process phosphoric acid production, and auxi-
 liary equipment  - 0.02 pounds of F per ton of P2O5.
    a  2.  Run  of pile  triple  super phosphate  mixing bell
 and den  and auxiliary equipment -- 0.05  pounds of F per
 ton of P205.
    a  3.    Run  of  pile  triple  super  phosphate   Curing
 or storage process and auxiliary equipment - 0.12 pounds
 of F per ton of P205.
  a 4.  Granular triple  super phosphate  production and
auxiliary equipment.
  i.  Granular triple super phosphate made by granulating
run-of-pilc  triple  super  phosphate 0.06  pounds  of F per
ton of P2 O5.
  ii. Granular  triple  super  phosphate  made from phos-
phoric acid and phosphate rock slurry - 0.15 pounds  of
F per ton of P205.
  a 5.  Granular triple super  phosphate storage and auxili-
ary equipment  — 0.05 pounds of F per ton of P2O5.
  a 6.  Di ammonium phosphate  production and auxiliary
equipment   0.06 pounds of F per ton of P205.
  a 7.  Calcining or other thermal phosphate rock process-
ing and auxiliary equipment  excepting  phosphate  rock
drying and defluorinating —  0.05 pounds  of F per ton  of
P20S.
  a 8.  Defluorinating phosphate rock by thermal process-
ing and auxiliary equipment  - 0.37 pounds of F per ton
of P205.
  a 9.  All  plants, plant sections or  unit  operations and
auxiliary equipment  not listed in a.l  to a.8  will comply
with best technology  pursuant to Section  2.03(1)  of this
rule.
   b.  Existing  plants  or  plant  sections.  Emissions  shall
comply with above section,  17-2.04(6)(c) l.a., for existing
plants  as expcditiously  as possible but not later than July
 1, 1975 or
   b I.  Where  a  plant  complex  exists with an  operating
wet process  phosphoric acid section  (including any items
 17-2.04(6)   I., a., a.l.   through  a. 6. above) and other
plant sections  processing or handling phosphoric  acid  or
products or  phosphoric acid  processing,  the total emission
of  the  entire complex  may  not  exceed 0.4 pounds of F
per ton of P20S  input  to the wet process  phosphoric acid
section.
   b 2.  For   the   individual  plant   sections  included  in
17-2.04(6)(c),  1., a.,  a.l.  through  a.6  above  but not
 included as  a  part as  defined in  17-2.04(6)(c)l., b., b.l
above,  if it  can  be  shown  by comprehensive engineering
study   and  report  to the Department  that  the  existing
 plant  sections aie not suitable  for  the  application  of
existing technology,  which  may  include  major  rebuilding
or  repairs and  scrubber  installations, the emission limiting
standard  to  apply will be   the  lowest  obtained by any
similar  plant  section existing  and  operating.
   (dj  Kraft  (sullatc liquor)  Pulp  Mills
   1.  black liquor recovery furnace. The emission limiting
standards arc:
   a. Participate  mailer     existing  sources  as  cxpcdi-
tiously  as  possible, but  not  later than  July  I,  1975,  no
greater   than  three  pounds  particulatc   per  each  3,000
pounds black liquor solids fed.  For new sources the same
emission limiting standards apply.
   b Total  Reduced  Sulfur    existing  plants as expedi-
tiously  as possible,  bul  nol  later  than  July  1,  1975   -
17.5 ppm expressed as I|2S on a  dry gas basis, or one-half
(0.5)  pounds per 3,000  pounds of  black liquor solids fed,
whichever  is more restrictive  For  new  plants no greater
than  1  ppm expressed  as H2S on  the dry basis, or 0.03
pounds  per  3,000 pounds  of black  liquor solids fed,
whichever is  the more restrictive.
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  (e) Fossil  Fuel  Steam Generators - The emission limit-
ing standards for Fossil Fuel Steam Generators are:
   1. New  Sources -  plants with more than 250 million
BTU per hour heat input.
  a. Particulate matter  -  0.1  pounds per  million  BTU
heat input, maximum 2 hour average.
  b. Visible  emissions - the density of which is equal to
or greater  than Number  1  of the Ringelmann Chart (20
percent opacity) except that a shade as dark as Number 2
of  the  Ringelmann Chart  (40  percent  opacity) shall be
permissible for not more than 2 minutes in any hour.
   c. Sulfur Dioxide - 0.8 pounds  per million BTU heat
input,  maximum  2 hour  average, when liquid fuel  is
burned.
   d. Sulfur dioxide - 1.2 pounds  per million BTU heat
input,  maximum   2  hour   average, when  solid fuel  is
burned.
   e. Nitrogen  oxides  -  0.20  pounds per  million  BTU
heat input maximum  2 hour average,  expressed  as  N02
when gaseous fuel is burned.
   f. Nitrogen  oxides  -  0.30  pounds per  million  BTU
heat input, maximum 2  hour average, expressed  as  N02
when liquid fuel is burned.
   g. Nitrogen  oxides  —  0.70  pounds per  million  BTU
heat input, maximum 2  hour average, expressed  as  N02
when solid fuel  is  burned.
  2. Existing Sources  —  plants with  more than  250
million BTU per hour heat input.
   a. Particulate — no greater than  the standard for new
sources.
   b. Visible  emissions -  no greater than the standard for
new sources.
   c. Sulfur  dioxide  emissions  -  When liquid  fuel  is
burned emissions shall  be no greater than 2.75 pounds per
million BTU  heat input for sources  in  all   areas  of the
State except  as  follows:
   (i) 2.5 pounds  per million BTU heat  input for sources
north  of Hecksher Drive within Duval  County and  1.65
pounds per million BTU heat  input for all  other sources
in Duval County.
   (ii)  1.1  pounds per  million  BTU  heat input for  all
sources in Hillsborough County including Tampa Electric
Company's  Gannon   Station  Units  1   through  4   and
Hooker's Point Generation Station.
   d. Sulfur  dioxide  emissions  -  When  solid  fuel  is
burned emissions shall  be  no greater than 6.17 pounds per
million BTU  heat input  for sources  in  all   areas  of the
State,  except for  the  following sources in   Hillsborough
County the emissions shall be no greater than:
  (i) 2.4 pounds per million BTU heat input for Units 5
and  6  at  Tampa  Electric Company's  Francis J. Gannon
Generating Station and;
  (ii) 6.5 pounds per  million  BTU heat  input  at Tampa
Electric Company's Big Bend Generating Station.
  e. This rule  shall be re-evaluated and reconsidered  by
the Board at a public hearing prior to  July  1, 1977. As part
of the re-evaluation and  reconsideration  required by  this
rule, the Department shall  consider and give due weight
to all competent substantial evidence  including any  find-
ings and  conclusions of any studies  directed  or supervised
by the Board.  Unless  the Board  finds that  the emission
limitations  set  forth in  Section  17-2.04(6)(e) 2.c  &  d
adequately  protect  public  health  and  welfare, existing
fossil fuel  steam generators shall be subjected to compli-
ance schedules which  must be  submitted to the Depart-
ment on  or before August  1,  1977 and which propose
increments of progress dates that will as  expeditiously as
possible bring them into compliance  with the following
emission limiting standards:
   (i) Sulfur dioxide — 1.1  pounds per million BTU heat
input when liquid fuel is burned.
   (ii) Sulfur dioxide —  1.5 pounds per million BTU heat
input when solid fuel is burned.
   If  the  Board  finds  that  the  emission limitations set
forth in 17-2.04(6)(e) 2.c & d  adequately protect  public
health  and  welfare  this  rule  shall  be  continued  or
amended to reflect  such findings and conclusions.
   f. Owners of fossil  fuel steam generators  shall monitor
their emissions  and  the effects  of  the emissions on
ambient concentrations  of sulfur  dioxide, in a manner,
frequency, and  locations approved,  and  deemed reason-
ably  necessary  and  ordered  by  the  Department. The
owners  shall submit to the Department a  written proposal
for such monitoring program on or before July  1,  1975.
   g. A  rule  for limiting nitrogen oxides emission  from
existing fossil  fuel steam generators will be developed by
July 1,  1975.
   3. New  and  existing Plants  with 250 million or less
BTU per hour heat  input.
   a. Visible  emissions  standards  as  set  forth  in  item
17-2.04(6) (e) l.b of this section.
   b. Particulate matter, sulfur  dioxide and nitrogen ox-
ides apply  17-2.03 (1) latest technology.
   4. Compliance Schedules
   (i) Compliance  schedules, S02  Emissions for existing
plants   regulated by  Section  17-2.04(6)(e)  2.c  and  d,
Florida  Administrative Code are  repealed as of the  effec-
tive  date of this rule.
   (ii) All  fossil fuel steam generators, regardless of size,
need not  comply  with any  existing compliance schedule
S02 Emissions  required by  the Department, but shall as
expeditiously  as   possible   comply  with  the  specific
emission standards  set  forth in  Subsection  17-2.04(6)(e)
2.c and d or, if  applicable, Subsection 17-2.04(6)(e) 3, at
option  of the owner.
   5. If at any  time  the Board determines, after  notice
and public hearing,  that appropriate and  substantially
lower sulfur fuels are  available on  a long term basis at a
reasonably comparable cost (including all costs such as
contract revision or termination costs) with  fuels allowed
under this rule,  the Board may establish  revised  emission
limiting standards.
   (0 Portland  Cement  Plants     the emission limiting
standards  for Portland Cement  Plants arc:
   1. Existing and new sources.
   a. For  Kilns  -  paniculate  shall be  not  greater  than
allowed by the  Process Weight Table. Table I.  set forth in
17-2.04 (2). The table  shall  be  applied to each individual
source  rather than  being applied  on the basis of mass
emission limitations.
   b.  For clinker-coolers the emission limiting standard of
17-2.04 (6) (f) l.a above apply.
   (g) Nitric Acid Plants -- the emission limiting standards
for nitric  acid plants  producing weak nitric acid  (50-70
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percent)  by pressure or atmospheric pressure  process arc:
   1. New plants
   a. Nitrogen oxides no greater than 3 pounds per ton of
acid produced (100 percent basis)
   b. Visible emissions  — none permitted.
   2. Existing  plants shall comply with  the  standard as
expeditiously as possible but no later than July  1, 1975.
   (h) Sulfur  Recovery  Plants  -  the  emission  limiting
standards for sulfur recovery  plants recovering sulfur from
crude oil gas are:
   1. New Plants
   a. Sulfur oxides calculated  as sulfur dioxide - no greater
than 0.004 pounds of S02  per pound of sulfur  input to
the recovery system or no greater than 0.004 pounds of
SO2 per  pound of sulfur removed  from an oil  well.
   2. Existing Plants.
   a.  For those sulfur  recovery plants  for which a valid
 Department Construction Permit  was issued  prior to July
 1,  1973,  the emission  limiting  standard  shall  be:  no
 greater  than  0.08 pounds  of S02 per  pound  of sulfur
 input  to the  recovery  system or no  greater than  0.08
 pounds  of SO2 per pound of sulfur removed from crude
 oil or gas processed.
   (i) Carbonaceous fuel burning equipment.
   A. The  emission  limiting standards  for  carbonaceous
fuel burning  equipment for which a  valid  Department
operation or construction permit  has been issued prior to
July 1, 1974,  are:
   (1)  Particulate
   (a)  For  burners of capacity less than 30 million BTU/
 hr total  heat input - no particulatc limiting standard.
   (b)  For  burners of capacity equal to  or greater than 30
 million BTU/hr - the  particulatc  matter emitted  shall not
 exceed the sum  of 0.3 pound per million BTU of heat
input  of carbonaceous  fuel  and  0.1  pound per million
 BTU of  fossil  fuel.
   (2)  Visible  Emissions
   (a)  For  burners less than 30  million  BTU/hr input —
 the visible  emission or density shall not exceed Ringel-
 mann  I  or an opacity  of 20  percent except  that a density
 of Ringelmann II is permissible  for  not  more  than two
 minutes  in any hour.
   (b)  For  burners of capacity  equal to  or greater than 30
 million  BTU/hr  input  — the  visible  emission or density
 shall  not exceed  Ringelmann 1.5 or  an opacity of 30
 percent  except that  a density of Ringelmann  II or opacity
 of 40  percent is permissible  for  not  more  than  two
 minutes  in any hour.
   B.  New  Sources — The emission limiting standards  foi
carbonaceous  fuel burning equipment  for which a  valid
Department operation  or construction  permit is issued on
or after July 1, 1974, are:
   (1) Particulatc
   (a) For burners of capacity  less than 30  million BTU/
hr total heat input - no particulate limiting standard.
   (b)  For  burners of capacity  equal to  or greater than 30
million BTU/hr - the  particulate matter emitted  shall not
exceed the  sum  of  0.2 pound per million BTU of heat
input of carbonaceous  fuel  and  0.1  pound per million
BTU of fossil  fuel.
   (2)  Visible Emissions
   (a)  For  burners  of  capacity  less  than  30 million
BTU/hr  input  - same as paragraph 2.04(6) (i) A (2) (a)
above.
   (b)  For burners of capacity equal to or greater than 30
million BTU/hr input - same as paragraph 2.04(6) (i) A
(2) (b).
   (3)  The Department  shall provide  for an annual  review
and evaluation of  the  particulate and visible  emission
standards applicable  to new sources.
   c. The above  standards  shall not  relieve  any person
from complying  with  more  stringent  Department permit
conditions  promulgated  pursuant  to  Section   403.087,
Florida  Statutes,   and   Department  Rule  17-4.07(5),
Florida Administrative Code.
   (7)  Mobile Sources
   (a)  No person shall cause, let, permit,  suffer  or allow
the  emission of  smoke  from  motor  vehicles on public
roadways which  is  visible within  the  proximity of the
engine exhaust outlet for a period  of more than five (5)
seconds.
   1. Definitions  -  apply to this  paragraph  17-2.04 (7)
(a) only
   a. Smoke  is  defined  as  small  gasborne and  airborne
particles,  exclusive  of  water vapor, from a process of
combustion, in sufficient number to be observable.
   b. Motor vehicle  is  defined  as any  device  powered by
an  internal  combustion  engine  and on  or in which  any
person or property may be transported.
   2. Exception —   all  2  cycle  gasoline  engines manu-
factured  prior to  the year 1976.
  (8) Complex Sources
  (a) For  the purposes  of this  section  the following
definitions shall apply:
   1. "Complex Source" means  any facility, or  group of
facilities, which is a  source of air pollution by reason that
it  causes, directly or  indirectly, significant increases or
emissions  of pollutants  into the  atmosphere or which
reasonably can be expected  to  cause  an increase in  the
ambient  air concentrations  of pollutants,  either  by itself
or in association with mobile sources.
   2. "Commencement of Construction"  shall mean  the
actual  on site,  continuous and  systematic  activity of land
surface alteration,  construction, and  fabrication of the
source.
   3. "Modification" means  any physical  change in  the
source  which will result  in the source causing or contrib-
uting to an increase of emissions to  the ambient air.
   (h)  No person shall  construct  or modify or operate or
maintain  any  complex  source  of air  pollution  which
results in  or  causes an increase  in  ambient  pollutant
concentrations  in  violation  of  the Ambient  Air Quality
Standards.
   (c)  After  December  15,  1973,  no person shall com-
mence construction  or modification of any of the follow-
ing  listed complex  sources without  a  permit  from  the
Department, or other governmental agency authorized by
the Department to issue such permit:
   1. Any new complex  source  with which is associated  a
single  level  unenclosed  parking  facility  with  a  design or
use  capacity of  1500  cars  or more,  or  any modification
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which will increase such unenclosed parking facility to a
design or use capacity of 1500 cars or more.
  2. Any multi-level unenclosed parking facility  with a
design  or use  capacity  of  750 cars  or  more,  or  any
modification  which will  increase  a multi-level unenclosed
facility to a design or use  capacity of 750 cars or more.
  3. Any new  road  designed   to  accommodate 2000
vehicles per  hour or more  at peak traffic flow rates, or a
modification  of an existing  road the  result  of which  is
designed  to  accommodate 2000 vehicles or more at peak
traffic flow rates.
  4. Any new  road  or  modification  to accommodate
1000 vehicles per hour or  more of peak traffic flow rates
or a modification which results  in a design  capacity for
accommodation  of 1000 vehicles per  hour  or more of
peak traffic  flow rates in  the  following urban  counties'
Dadc,  Broward,  Palm  Beach,  Brcvard,  Ilillsborough,
Pincllas,  Orange, Duval,  liscambia, Polk,  Leon, Sarasota,
Volusia, Alachua, Pasco and Lcc.
  5. All  major  tollways  or interstate  highways or other
major roads  of more  than  two lanes of traffic outside of
the urban areas named in paragraph 4 above.
  6. Any new  airport which is designed or may be used
to serve commercial airlines regularly scheduled  or other-
wise or  any modification  of a parking facility such  an
airport which results in a 10 percent increase in capacity.
   7. If the  Department  finds after notice, and hearing, if
requested, that  projected  emissions associated  with  any
proposed  complex  source  not  listed above may result  in
the  failure of the  Ambient  Air  Quality Standards being
achieved  and maintained, the Department may require an
application to be  submitted and a permit required prior
to construction.
   (d) Any  person seeking  a  permil  shall  submit such
information  that is necessary for  the Department to make
a determination that  the complex source will not  cause a
violation of ambient  air  quality standards. Such informa-
tion shall include, but not be limited to:
   1. The nature and amounts of pollutants to be  emitted
or  caused to be emitted by the complex source, or by
associated  mobile  sources,  and  an  air quality  impact
statement.
   2. The location, design, construction  and  operation of
such facility.
   (e) No such  permit shall  be  issued without an  oppor-
tunity  for public  comment in  accordance with  Section
17-2.09,  F.A.C.
  (0 This  subsection   17-2.04  (8),   Florida  Adminis-
trative Code shall  not apply to  air  pollution sources for
which  a  permit is  required by Chapter  174,  Florida
Administrative  Code, and  shall  not  apply to sources for
which  the  commencement of construction  was prior  to
December  15,  1973, unless construction is,  or has been
discontinued for more than ninety days.
   (g) Public Highway projects which would otherwise be
covered  by  this section  (17-2.08 (8))  and  for which bid
letting has  been  advertised  prior  to  April   1, 1974 arc
exempted from  the formal permitting requirements of this
section  provided, however, that  the staffs of the  State of
 Florida DOT and DPC will re-examine the environmental
assessments  for  each project  to identify those  projects
which  will violate  State  ambient air quality  standards.
Those  projects  so  identified  will  not be exempted from
the permitting requirements of this section.
 17-2.05 Ambient Air Quality Standards
   (1)  The air quality of  the State's atmosphere is deter-
 mined by  the  presence of specific  pollutants in  certain
 concentrations. Human  health and welfare  is affected and
 known or anticipated adverse results  are produced by the
 presence of pollutants in  excess of the certain concentra-
 tions.  It is, therefore, established that maximum limiting
 levels. Ambient Air Quality Standards, of pollutants exist-
 ing in the ambient air are  necessary to protect  human
 health and public welfare. The following  statewide Am-
 bient  Air Quality Standards are established  for Florida:
   (a)  Sulfur  Dioxide
   1.  60  micrograms  per cubic  meter (0.02  ppm)  -
 annual arithmetic mean.
   2.  260 micrograms per cubic  meter (0.1  ppm) maxi-
 mum   24  hour concentration,  not to be exceeded more
 than once per year.
   3.  1300 micrograms per cubic meter (0.5  ppm) maxi-
 mum  3  hour concentration,  not to  be  exceeded more
 than once per year.
   (b)  Particulate Matter
   1.  60  micrograms per cubic  meter — annual geometric
 mean.
   2.  150 micrograms per cubic  meter  -- maximum  24
 hour  concentration, not  to be exceeded more than once
 per year.
   (c) Carbon Monoxide
   1.  10  milligrams per cubic meter (9 ppm) — maximum
 8 hour concentration, not to be exceeded more than once
 per year.
   2.  40  milligrams per  cubic meter (35  ppm)  - maxi-
 mum  1  hour  concentration, not to be exceeded  more
 than  once per year.
   (d)  Photochemical Oxidants — measured and corrected
 for interference due to  nitrogen oxides and sulfur dioxide.
   I.  160 micrograms  per  cubic meter  (0.08 ppm)  -
 maximum 1 hour concentration, not to be  exceeded more
 than once per year.
   (e)  Hydrocarbons  — For  use  as  a  guide  in  devising
 implementation plans to achieve oxidant standards. To be
 measured and corrected for methane
   1.  160 micrograms per cubic  meter (0.24  ppm) maxi-
 mum   3  hour  concentration  (6  to  9 a.m.) not  to  be
 exceeded more  than once  per year.
   (f)  Nitrogen  Dioxide
   1.  100 micrograms per  cubic meter (0.05 ppm) annual
 arithmetic mean.
   (2)  Exception  - in  Dade,  Broward, and  Palm Beach
 County,  the  above Ambient  Air  Quality Standards apply
 except as provided  differently below:
   (a)  Sulfur Dioxide
   1.  8.6  micrograms per cubic  meter (0.003 ppm)  -
 annual arithmetic mean.
   2.  28.6 micrograms per cubic  meter (0.010 ppm) - 24
 hour  concentration.
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  3. 57.2  microgranis per  cubic  meter (0.020 ppm)
maximum four hour concentration.
  4. 286 micrograms per cubic meter  (0.100 ppm)
maximum one hour concentration.
  (b) Suspended Parliculates
  1. 50  micrograms per  cubic meter  - annual geometric
mean.
  2. 180 micrograms per cubic meter  - maximum  24
hour concentration.
  (c) Carbon Monoxide
   1. 9 milligrams per cubic meter (8 ppm) — maximum 8
hour concentration.
  2. 14  milligrams  per  cubic  meter (12 ppm) — maxi-
mum 1 hour concentration.
  (3) Sampling   and analyses  of  contaminants  in  this
section shall be  performed by the methods approved  by
the Board.
  (4) Abatement  -  a  determination  that  any  of  the
above standards, 17-2.05 (1), has been exceeded, shall be
adequate  evidence for (he Department to commence  an
investigation   to  determine  the  cause  and  to  execute
appropriate  remedial measures.
  General  Authority  403.061   FS.   Law  Implemented
403.021,  403.031,  403.061 FS.  History - New  1-11-72.

17-2.06 Air Pollution Kpisode
   An  episode describes  a  condition  which  exists when
meteorological conditions  and rates  of discharge  of  air
pollutants combine   to  produce pollutant  levels in  the
atmosphere  which, if sustained, can lead to a  substantial
threat  to the health of  the people.  In  order  to  prevent
episode  conditions  from continuing  or from  developing
into more severe conditions,  positive  action and  a rapid
abatement  response  is  necessary.  The  severity  of  an
episode has  been classified upon the basis of the criteria
given in  the  following sections with the three levels, alert,
warning and  emergency described.
   Due  to  the  exigent  nature   of  named  episodes  the
Director  shall determine  and declare that an air pollution
•episode  exists. His  determination shall be in accordance
with the following criteria:
   (I) (a) Air Pollution Forecast    the existence or fore-
cast of a stagnant atmospheric condition as advised by a
National  Weather  Service  advisory  is  in  effect  or  an
equivalent  state or  local  determination  of  a  stagnant
condition.
   (b)  "Alert"   the alert  level  is lh.it  concentration of
pollutants at  which  first  stage control actions is to begin.
An  ":ilcrt"  shall  be declared  when  any  one  of  the
following levels  is reached al any monitoring site:
   I. Sulfur  Dioxide  (S0;)    800 micrograms per cubic
meter (0.3 ppm)  24  hour aveiage.
   2 I'.iiliculatc     3.0  (.'Oils  or  375  micrograms  per
cubic meter,  24  hour average.
   3. Sulfur  Dioxide  (SO2) and  Paniculate combined
product  of  S0:  ppm. 24  hour average, and COHs equal
to 0.2 IT product of S0; nucrngrams per cubic meter. 24
hour j-. crige equal to (S5 X iO3
   4 ("jrbon  Monoxide  (CO)    17 milligrams  per tubi<-
mete' ( 15 ppm), * hour  averiiL'c
   c  O-.jdaru (0,1     200 micrograms per  cubic meter
(0  1 pr>m) I  hour average
  6. Nitrogen  Dioxide (NO2)     1130 microgrnms per
cubic meter (0.6 ppm),  1  hour average, 282  micrograms
per cubic meter (0.15 ppm), 24 hour average,
and  meteorological  conditions  are  such  that  pollutant
concentrations  can be expected  to  remain ill the above
levels for twelve (12) or  more hours or  increase unless
control actions are taken.
  (c) "Warning" —  the warning  level indicates that  air
quality  is  continuing  to   degrade  and  that additional
control  actions  are  necessary.  A  "warning" shall be de-
clared when any one of the following levels is reached at
any  monitoring site:
   1. Sulfur Dioxide (S02) — 1600  micrograms per cubic
meter (0.6  ppm), 24 hour average.
   2. Particulate  -  5.0  COHs  or 625  micrograms  per
cubic meter, 24 hour average.
   3. Sulfur Dioxide  (SO2)  and  Particulate combined -
product of S02 ppm, 24 hour average and COHs equal to
0.8 or product of SO2 micrograms per cubic meter, 24 hour
average  and paniculate micrograms  per  cubic meter, 24
hour average equal to 261   X 103
   4. Carbon  Monoxide (CO)    34 milligrams per cubic
meter (30 ppm), 8 hour average.
   5. Oxidanl  (O3)   800  milligrams per cubic meter (0.4
ppm)   1 hour average.
   6. Nitrogen   Dioxide  (NO2)     2260  milligrams  pei
cubic meter (1.2 ppm)    I  hour  average;  565 milligrams
per cubic meter (0.3 ppm), 24 hour average,
and  meteorological  conditions  are  such  that  pollutant
concentrations  can be expected  to  remain at the above
levels for  twelve  (12) or  more hours or  increase unless
control actions are taken.
   (d) "limergency" -- the  emergency  level indicates that
air quality is continuing to degrade  to a level that should
never  be reached  and that  the  most stringent  control
actions  are  necessary. An  "emergency"  shall  be  declared
when any  one  of the following levels is  reached at any
monitoring site:
   1. Sulfur Dioxide (S02) - 2,100 micrograms per cubic
meter (0.8 ppm), 24 hour average.
   2. Particulate     7.0 COHs  or  875  micrograms per
cubic meter 24 hour average.
   3. Sulfur  Dioxide  (S02) and Particulate  combined -
product  ol SO2 ppm,  24 hour average and COHs equal to
 1.2  or product of SO2  microgiams per cubic meter, 24
hour avciagc and paiticulale micrograms per  cubic meter
24 hour  average equal  to 3'>3 X It)-1
   4. CO    46 milligrams  per cubic  meter (40  ppm), 8
hour average.
   5. Oxidant (()T)    1.200 micrograms  per  cubic meter
(0.6 ppm), 1 hour aveiage.
   6. Nitrogen   Dioxide (NO2)     3,000  micrograms  per
 cubic mclcr  (1.6 ppm),  I  hour average, 750  micrograms
 per cubic meter (0.4 ppm), 24 hour average,
 and  meteorological conditions are such  that pollutant
 concentrations  can  be expected  to remain  at  the  above
 levels tor twelve (12) or more hours

   (e) Area  ol  Lpisode. The Director shall, when declaring
any cxpisode  level,  declare the  counties  in which the
episode exists.
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  (0 "Termination" - once  declared, any episode level
will  remain  in  effect  until the  pollutant  concentration
increases  to  meet  the next  higher  level criteria or  de-
creases to a point below the declared criteria level.
  (2) (a) Emission  Reduction Plans and Actions.
  Upon  a declaration  by the Director that any episode
level exists — alert,  warning, or emergency  — any person
'responsible for the operation or conduct of activities which
result in  emission of air pollutants  shall take actions as
required  for  such  source  or activity for the  declared
episode level as set  forth in Episode Tables I, II, and III
of this  section and  shall put  into effect the Preplanned
Abatement Strategy.


                  EPISODE TABLE I

Alert Level Emission Reduction Plans
  Part A. General
  During an  "alert" level episode:
   1.  All forms of open burning arc prohibited.
  2.  The use of incinerators for  disposal of any form of
solid waste or liquid waste is prohibited.
  3.  Persons  operating fuel-burning  equipment which re-
quires boiler  lancing or soot  blowing  shall  perform such
operations only between the hours of 12 noon and 4 p.m.
  4.  Persons operating motor vehicles should eliminate all
unnecessary operations.
  Part B. Source Curtailment
  During an  alert  level episode  any persons responsible
for  the  operation  of a source  of  air pollutants listed
below shall take  all  required control actions for this alert
level:

Source of Air Pollution:
   1.  Coal or oil-fired  electric power generating facilities.
Required Control Action:
  a.  Substantial  reduction  by utilization of fuels having
low ash or sulfur content.
  b.  Maximum   utilization  of mid-day (12  noon  to 4
p.m.) atmospheric turbulence  for boiler lancing and soot
blowing.
  c.  Substantial  reduction  by  diverting electric  power
generation to facilities outside  of alert area.
Source of Air Pollution:
   2.  Process  steam  generating facilities which fire coal or
oil.
Required Control Action:
  a.  Substantial  reduction  by utilization of fuels  having
low asli and sulfur content.
  b.  Maximum   utilization  of mid-day (12  noon  to 4
p.m.) atmospheric turbulence  of boiler lancing and soot
blowing.
  c. Substantial  reduction  of steam  demands consistent
with continuing plant operations.
Source of Air Pollution:
  3.  Process  steam  generating facilities which fire wood,
bark, or  bagassee;  totally  or  in  combination with  other
fuels.
Required Control Action:
  a.  Substantial  reduction  by  switching  to fossil fuels
with  low  ash  and sulfur content or by  diverting steam
demands to steam  generators utilizing low ash and sulfur
content fuels.
   b.  Maximum  utilization  of mid-day  (12  noon  to 4
p.m.)  atmospheric  turbulence for boiler  lancing and  soot
blowing.
   c. Substantial  reduction of steam demands consistent
with continuing plant operations.

Source of Air Pollution:
   4.  Manufacturing industries of the following classifica-
tions:
   Pulp and paper industries
   Citrus industries
   Mineral Processing industries
   Phosphate and allied chemical industries
   Secondary metal industry
   Petroleum operations
Required Control Action:
   a. Substantial  reduction of air pollutants from manu-
facturing  operations by enacting preplanned  abatement
strategics including curtailing postponing or deferring pro-
duction and all operations.

   b.  Curtail trade  waste  disposal operations which  emit
air pollutants.
Source of Air Pollution:
   5.  Bulk   handling  operations  which transfer  or  store
material  including but not limited to:
   Cement
   Fertilizer
   Phosphate rock
   Grain  or Feed
   ROP Triple Super Phosphate
   Lime
   Sand and Gravel
   Dolomite
Required Control Action:
   a. Maximum  reduction of fugitive dust  by curtailing,
postponing or deferring bulk handling operations.

Source of Air Pollution:
   6.  Any  other industrial or commercial establishments
which emit air pollutants.

Required Control Action:
   a. Substantial  reduction of air  pollutants by curtailing,
postponing, or deferring operations.
   b. Curtail trade  waste disposal operations  which emit
air pollutants.

                  EPISODE TABLE II

Warning  Level Emission Reduction Plans
   Part A.  General
   During a "Warning"  level episode:
   1.  All forms of open burning are prohibited.
   2. The use of incinerators for  disposal  of any form of
solid waste or liquid waste is prohibited.
   3.  Persons  operating  fuel  burning equipment  which
requires boiler lancing  or soot blowing shall perform  such
                                                        C-ll

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operations only between the hours of 1 2 noon and 4 p.m.
  4. Persons operating motor vehicles must reduce opera-
tions by the use  of car  pools and increased use of public
transportation and elimination  of unnecessary operation.
  5. Unnecessary space healing or cooling is prohibited.
  Part B. Source Curtailment
  During a warning level episode any  persons responsible
for  the  operation  of a source  of air  pollutants listed
below  shall  take  all  required  control  actions  for  this
warning level:

Source of Air Pollution:
  \. Coal  or oil-fired electric power generating facilities.
Required Control Action:
  a. Maximum  reduction by utilization of fuels  having
lowest ash and  sulfur content.
  b. Maximum  utilization   of  mid-day  (12  noon  to 4
p.m.) atmospheric  turbulence for boiler lancing and soot
blowing.
  c. Maximum reduction by diverting electric power gen-
eration  to facilities  outside  of warning area or to generat-
ing  stations  emitting less pollutants per  kilowatt generat-
ed.
Source of Air Pollution:
  2. Process steam generating  facilities  which fire oil  or
coal.
Required Control Action:
  a. Maximum  reduction by utilization  of fuels  having
the  lowest available  ash and sulfur content.
  b. Maximum  utilization   of  mid-day  (12  noon  to 4
p.m.) atmospheric  turbulence for boiler lancing and soot
blowing.
  c. Stand-by  to   enact  preplanned  emergency  action
plan.
Source of Air Pollution:
  3. Process steam generating  facilities which fire wood,
bark or bagassee.
Required Control Action
  a. Maximum  reduction  by  reducing heat and steam
demands  to absolute necessities consistent with preventing
equipment damage.
  b. Maximum  utilization   of  mid-day  (12  noon to 4
p.m.) atmospheric turbulence for  boiler lancing and soot
blowing.
Source of Air Pollution:
  4. Manufacturing industries  of  the  following classifica-
tions:
  Pulp  and paper industries
  Citrus industries
  Mineral processing industries
  Phosphate and allied chemical industries
  Secondary metal industry
  Pel rcilcum operations
Required Control Act inns:
  a. C'nmmcnce  preplanned  abatement  strategics  for  the
elimination of all air pollutants.
  b.  Himmation  of air  pollutants from  trade waste dis-
posal operations which emit air  pollutants.
Source i.ij Air Pollution
   ~>  Bulk  handling operations wruch  transfer  or store
material including but not limited to.
   Fertilizer
   Phosphate Rock
   Grain or Feed
   ROP Triple Super Phosphate
   Cement
   Lime
   Sand and Gravel
   Dolomite
Required Control Action:
   a.  Elimination  of fugitive  dust  by ceasing,  curtailing,
postponing or deferring transfer or storage of material.
Source of Air Pollution:
   6.  Any other  industrial  or commercial  establishments
which emit air pollutants.
Required Control Action:
   a.  Maximum   reduction  by curtailing,  postponing  or
deferring operations.
   b.  Eliminate   trade  waste  disposal  operations which
emit  air pollutants.

                  EPISODE TABLE III

Emergency Level Emission Reduction Plans
   Part A.  General
   During an "emergency"  level episode:
   1.  All forms of open burning are prohibited.
   2.  The  use of incinerators  for  disposal of any  form of
solid  or liquid waste is prohibited.
   3.  All   places  of employment described  below  shall
immediately cease operations.
   a.  Mining and quarrying of  nonmctallic minerals.
   b.  All  construction work except that which  must pro-
ceed  to avoid emergent physical harm.
   c.  All  manufacturing establishments  except  those re-
quired  to  have  in  force an  air pollution emergency plan.
   d.  All  wholesale  trade  establishments; i.e.,  places  of
business primarily engaged in selling merchandise to retail-
ers,  or industrial, commercial, institutional or professional
users, or  to other  wholesalers, or  acting  as  agents in
buying merchandise for or selling  merchandise  to  such
persons  or companies, except  those engaged in  the distri-
bution of drugs,  surgical supplies  and  food.
   e.  All  offices  of  local, county  and State  government
including  authorities, joint  meetings,  and  other public
bodies  excepting such  agencies which arc determined by
the chief administrative  officer of local, county, or State
government, authorities, joint  meetings  and other public
bodies  to  be vital  for public  safety  and welfare  and the
enforcement of the  provisions  of  this  order.
   f.  All  retail  trade  establishments  except  pharmacies,
surgical  supply distributors,  and  stores primarily  engaged
in the sale of food.
   g.  Banks,  credit  agencies other  than hanks,  seciinlics
and commodities brokers,  dealers, exchanges and services.
offices  ol  insurance  carriers,  agents and  brokers, real
estate offices.
   h.  Wholesale  and  retail laundries,  laundiy  services anjJ
cleaning and  dyeing  establishments,  photographic  studios;
beauty shops, barber shops, shoe  repair shops.
   i.  Advertising offices,  consumer credit reporting, adjust-
ment   and  collection  agencies;  duplicating, addressing,
                                                         C-12

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blueprinting;  photocopying,   mailing,  mailing  list  ami
stenographic services; equipment  rental services, commer-
cial testing laboratories.
  j.  Automobile repair,  automobile services, garages.
  k.  Establishments  rendering amusement and recreation-
al services including motion picture  theaters.
  1.  Elementary  and  secondary schools, colleges, universi-
ties,  professional  schools,   junior  colleges,  vocational
schools, and public and private libraries.
  4.  All  commercial and  manufacturing  establishments
not included in  this  section will  institute such actions  as
will  result in  maximum  reduction  of air pollutants from
their  operation by ceasing, curtailing or postponing opera-
tions  which emit  air pollutants  to  the extent  possible
without causing injury to persons or  damage to equipment.
  5.  The use  of motor vehicles  is  prohibited except  in
emergencies with the  approval of local or state police.
  6.  Unnecessary lighting,  heating  or cooling in unoccu-
pied structures is prohibited.

Source of Air Pollution:
  1.  Coal or  oil-fired electric power generating facilities.
Required  Control Action:
  a.  Maximum  reduction by utilization of fuels  having
lowest ash and sulfur content.
  b.  Maximum  utilization  of mid-day  (12  noon to  4
p.m.)  atmospheric turbulence for boiler lancing or soot
blowing.
  c.  Maximum  reduction by  diverting electric power gen-
eration to  facilities  outside  of  emergency  area  or   to
generating stations emitting  less  pollutants  per kilowatt
generated.

Source of Air Pollution:
  1.  Coal,  oil,  natural  gas,  wood, bark and bagassee  -
fired  process steam generating facilities.

Required Control Action:
  a.  Maximum  reduction  by reducing, heat and  steam
demands to absolute  necessities consistent with preventing
equipment damage.
  b.  Maximum   utilization  of mid-day  (12  noon to  4
p.m.)  atmospheric turbulence for boiler lancing or soot
blowing.
  c.  Taking the  action  called for in preplanned emergen-
cy action  plan.

Source of Air Pollution:
  3.  Manufacturing  industries of the following classifica-
tions:
  Pulp and  paper industries
  Citrus industries
  Mineral processing  industries
  Phosphate and allied chemical industries
  Secondary metal industries
  Petroleum operations

Required Control Action:
  a. Continuation of preplanned  abatement strategies for
the  elimination of air pollutants.
  b.  Elimination  of  air  pollutants  from trade waste dis-
posal  operations which emit air pollutants.
Source of Air I'ollulion:
   4.  Hulk  handling  operations  which transfer  or  store
material  including but not limited to:
   Cement
   Fertilizer
   Phosphate Rock
   Grain
   ROP Triple Super Phosphate
   Lime
   Sand and Gravel
   Dolomite
Required Control Action:
   a.  Elimination  of  fugitive dust by ceasing, curtailing,
postponing or deferring transfer or storage of material.
Source of Air Pollution:
   5.  Any other industrial or commercial establishments
which emit air pollutants.
Required Control Action:
   a.  Elimination of air pollutants by ceasing, curtailing,
postponing or deferring operations.
   b.  Elimination of  air pollutants  from  trade waste dis-
posal  process which emit air pollutants.
   (b)  Preplanned Abatement  Strategies  —  any person
responsible  for  one  or  more  air  pollutant sources shall
prepare and  submit,  upon written request from the De-
partment,  a  stand-by  plan which describes  the  action
which will be  taken  by that person  to reduce  emissions
when  an  episode is declared. The plan shall be submitted
within 30 days  of  the request and  will be subject to
approval, modification or  rejection  by the  Department.
The plan shall be in  writing and shall include but not be
limited to:
   1.  Identity and  location of pollutant  sources and of
contaminants discharged.
   2.  Approximate  amount  of normal emission  and of
reduction of emission expected.
   3.  A brief  description  of the manner  in which  reduc-
tion will   be achieved, for each of the  episode levels, alert,
warning and emergency.
   (c)  Whenever  during an episode  (alert,  warning, or
emergency) any person responsible for the operation of a
source or conduct of  activities which result in emission of
air pollutants docs not take  actions  as required for the
source or activity for  the  declared episode level or put
into effect the Preplanned Abatement  Strategy, the Direc-
tor shall   immediately  institute  proceedings in a  court of
competent jurisdiction for injunctive relief to enforce this
chapter.
   General Authority   403.061  FS.  Law  Implemented
403.021,  403.031, 403.061  FS. History - New  1-11-72.

17-2.07 Sampling and Testing
   (1)  All persons shall, upon request of the  Department,
provide continuous automatic monitoring  testing and rec-
ords of contaminants being emitted from a source.
   (2)  All persons shall provide facilities for continuously
determining the  input process  weight  or input  heat  when
such factors are the basis  for limiting standards.
   (3)  A  person  responsible for the emission of air pollut-
                                                         C-13

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anls Irom  ;iny source shall, upon  request of (he Depart-
ment provide  in connection  willi such sources and related
SOUTLC  operations,  such  sampling  and  testing  facilities
exdusive  of instruments  and  sensing devices as  may  he
necessary for  the  proper  determination of the nature and
quantity of air pollutants  which are, or may be emitted as
a result of such operation.
  (4)  Such facilities may be  either  permanent  or  tem-
porary  at  the discretion of the  person  responsible for
their   provision and shall   be  suitable  for  the  use  of
methods and  equipment  acceptable to the  Department,
who shall  indicate  in writing  the  required  size,  number
and  location of sampling holes; the si/c and location  of
the sampling platform; and  the utilities for operating the
sampling and  testing equipment. The  facilities shall  com-
ply  with  all applicable  laws and  regulations concerning
safe  construction  and safe  practice in connection  with
such facilities.
  (5)  When the Department upon  investigation has  good
reason   to  believe  that  the  provisions  of  this  chapter
concerning  emission  of  pollutants  arc being violated, it
may require  the  person responsible  for the  source  of
pollutants  to conduct tests which will identify the nature
and  quantity of pollutant emissions from the source and
to provide  the results  of said  tests to the Department.
These  tests shall  be carried  out under the supervision  of
the Department, and at the expense of the person respon-
sible for the source of pollutants.
  (6)  All  analyses  and   tests  shall  be  conducted  in a
manner specified by  the Department.  Results of  analyses
and  tests shall be calculated and  reported  in  a  manner
specilied by the Department.
  (7)  Analyses and  tests for  compliance may  be  per-
formed by  the IX'parlmcnt  at the cost  of the person
responsible foi  the emission of  air pollutants.
  General  Authority 403.061,  403.101  FS.  Law Imple-
mented 403.021,  403.031, 403.061, 403.101  FS. History
- Revised  1-1 1-72.
17-2.OX Local  Regulations.  Regulations  controlling air
pollution may  be  adopted by local  governmental  authori-
ties  provided that  such regulations  shall not be in  conflict
herewith or that  standards  so  adopted  shall  not be less
stringent than  those  established herein.
  General  Authority 403.061,  403.182  FS.  Law Imple-
mented 403.021. 403.031, 403.061, 403.182 FS. History
- Formerly 17-2.09,  FAC.
17-2.0') Public Comment
  (\)  Before  any  depaitment  permit  is issued  for  any
source of air pollution  the  department  shall provide an
opportunity  for public  comment which shall include as a
minimum the following:
  (a) Availability  for public inspection in  at  least one
location  in the region affected the information submitted
by  the owners or  operator and the Department's analysis
of  the  effect  of  such construction or  modification  on
ambient  air quality, including the Department's proposed
approvaJ or disapproval.
  (b) A 30-day period for  submittal of public comment;
and
  (c) A notice by prominent advertisement  in the  region
affected, specifying  the nature  and location of the pro-
posed source and that the information specified in subsec-
tion 17-2.09  (1) (a), F.A.C.  is available for public inspec-
tion at a designated  location.
  (d) A copy  of the notice  shall also be sent to the U.S.
Environmental  Protection Agency through the appropriate
regional  office, and  to  all other  slate  and  local  air
pollution control agencies having jurisdiction in the region
in  which  such new  or  modified  installation will  be
located. The  notice  also shall be  sent to any other agency
in the region having responsibility  for  implementing the
department's permit  program.
  (e) A  copy of the  notice  shall be  displayed in  the
appropriate   Regional,  Subregional, and Local Program
offices.
  (2) Because public comment  or  lack of same is vital
information  to a proper determination of a permit  appli-
cation,  the Department shall not make a final decision on
the application until the time period for public comment
has expired,  but shall make  the final determination within
sixty days thereafter.

17-2.10  Local (lovcrnmcnt
  No municipality  or  political  subdivision  of  the  state
shall  issue  any building or other permit to  constiuct or
modify  a source  of air pollution  for  which a  permit  is
required by  department  rule  unless  the source has  re-
ceived a valid department permit.

 17-2.12  Source Testing Method
   Air Pollutant emissions shall  be tested and analyzed in
 accordance  with  the Standard  Sampling Techniques and
Methods of Analysis for  the Determination of Air Pol-
 lutants from Point Sources,  January, 1974, as adopted by
 the Board  and as may be amended from time to time by
 the Board.
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         APPENDIX D.  THE STACK GAS DISPERSION MODEL


     The model used to estimate ambient concentrations for

the phosphate rock processing plant is one developed by the

Meteorology Laboratory of the EPA.  This model is designed

to estimate concentrations due to sources at a single loca-

tion for averaging times from 1 hour to 1 year.

     This model is a Gaussian plume model using diffusion

coefficients suggested by Turner  (1970).*  Concentrations

are calculated for each hour of the year from observations

of wind direction (in increments of 10 degrees), wind speed,

mixing height, and atmospheric stability.  The atmospheric

stability is derived by the Pasquill classification method

as described by Turner (1970).  In the application of this

model, all pollutants are considered to display the dis-

persion behavior of nonreactive gases.

     Meteorological data for 1964 are used as input to the

model.  The reasons for this choice are  (1) data from

earlier years did not have sufficient resolution in the wind

direction, and (2) data from subsequent years are readily
  Turner, D.B.  Workbook of Atmospheric Dispersion Estimates
  U.S. DHEW.  PHS Publication No. 999-AP-24.   (Revised 1970),
                               D-l

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available on magnetic tape only for every third hour.

     Mixing height data are obtained from the twice-a-day

upper air observations made at the most representative upper

air station.  Hourly mixing heights are estimated by the

model, using an objective interpolation scheme.

     A feature of this model is the modification of plume

behavior to account for aerodynamic effects for plants in

which the design is not optimal.  Another important aspect

of the model is the ability to modify concentration to

account for the physical separation between the stacks since

all are assumed to be located at the same geographical

point.

     Calculations are made for 180 receptors (at 36 azimuths

and 5 selectable distances from the source).  The JMHCRD-1

model used here can consider both diurnal and seasonal

variations in the source.  Separate variation factors can be

applied on a monthly basis to account for seasonal fluctua-

tions and on an hourly basis to account for diurnal varia-

tions.  Another feature of the model is the ability to

compute frequency distributions for concentrations of any

averaging period over the course of a year.  Percentages of

various ranges in pollutant concentrations are calculated.

AERODYNAMIC-EFFECTS MODIFICATION OF THE SINGLE SOURCE MODEL

Note:  The aerodynamic-effects version is a more general
       form of the single source model.  All remarks made
       in Appendix B apply equally to either version.


                             D-2

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     The single source model does not address the aerodynam-



ic complications that arise when plant design is less than



ideal.  These effects result from the interaction of the



wind with the physical structure of the plant.  Such inter-



action can retard or, in the extreme, prevent plume rise.



The extreme case is commonly referred to as "downwash."



With downwash, the effluent is brought downward into the



wake of the plant, from which point it diffuses as though



emitted very close to the ground.  In the retardation case,



some of the dispersive benefits of plume rise are lost;



whereas in the downwash case, all of the benefits of plume



rise are lost, along with most of the benefits of stack



elevation.  Both phenomena—but especially downwash—can



seriously increase the resulting ambient air impact.



     The aerodynamic-effects modification is an attempt to



include these effects in a predictive model.  It was de-



veloped within EPA and, while not yet validated, is the



best-known operational approach.  Basically, it enables the



model to make an hour-by-hour, stack-by-stack assessment of



the extent of aerodynamic complications.  The parameters



used in making the assessment are wind speed, stack gas exit



velocity, stack height, stack diameter, and building height.



If a particular assessment indicates no aerodynamic effect



for a specific stack and time, the model behaves just like
                               D-3

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the unmodified version.  If there are aerodynamic effects,



the modified version contains equations by which the impact



of these effects on ground-level concentrations is esti-



mated.
                              D-4

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                                   TECHNICAL REPORT DATA
                            (Please read Instructions on the reverse before completing)
1. REPORT NO.
  EPA-450/3-78-030
                              2.
                                                           3. RECIPIENT'S ACCESSION-NO.
4. TITLE AND SUBTITLE
  Air Pollutant Control  Techniques for Phosphate  Rock
  Processing Industry
                                                           5. REPORT DATE
                   June 1978
             6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)

  David M.  Augenstein
             8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
  PEDCo Environmental,  Incorporated
  Chester Towers
  11499 Chester Road
  Cincinnati, Ohio 45246
                                                           10. PROGRAM ELEMENT NO.
             11. CONTRACT/GRANT NO.
               68-91-4147, Task 12
 12. SPONSORING AGENCY NAME AND ADDRESS
  U.  S.  Environmental Protection  Agency
  Office of Air Quality Planning  and Standards
  Research Triangle Park, North Carolina 27711
             13. TYPE OF REPORT AND PERIOD COVERED

                     Final
             14. SPONSORING AGENCY CODE
                   200/04
 15. SUPPLEMENTARY NOTES
  EPA Task Manager  -  Lee L.  Beck,  Emission Standards  and  Engineering Division
 16. ABSTRACT
       This document provides  information needed by State  and local pollution  control
  agencies for development of  regulations for control of particulate emissions from
  phosphate rock processing plants.   Information on process  and particulate  emission
  control  equipment is included  for  phosphate rock dryers, calciners, grinders,  and
  ground rock handling equipment.  Cost and economic  information is given for  both
  new and  retrofitted facilities,  and environmental impacts  are presented for  different
  levels of emission control.  Results of emission measurements performed by EPA at
  phosphate rock dryers, calciners,  and grinders are  tabulated and presented with brief
  descriptions of the facilities tested.  EPA particulate  emission test methods  are
  also briefly described.

       Information presented in  the  document is summed  up  in an objective discussion
  of regulatory options and enforcement aspects of potential regulations.
17.
                               KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                              b.IDENTIFIERS/OPEN ENDED TERMS C.  COSATI Field/Group
  Air Pollution Control
  Phosphate Rock
  Fertilizer
Particulate
State Implementation Plans
Scrubbers
Fabric Filters
Electrostatic
   Precipitators
 3. DISTRIBUTION STATEMENT
                                              19. SECURITY CLASS (This leport)
                                                 UNCLASSIFIED
                                                                         21. NO. OF PAGES
                             224
                                              20. SECURITY CLASS (Taispage)

                                                 UNCLASSIFIED
                                                                         22. PRICE
EPA Form 2220-1 (9-73)

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