&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
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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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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.
-------
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
-------
(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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
(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-
C-5
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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.
06
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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
C-7
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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
C-l
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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-
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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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