United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park NC 27711
EPA-450/3-79-034b
October 1980
Air
Ammonium Sulfate EIS
Manufacture —
Background Information
for Promulgated Emission
Standards
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EPA-450/3-79-034b
Ammonium Sulfate Manufacture —
Background Information for
Promulgated Emission Standards
Emission Standards and Engineering Division
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air, Noise, and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
October 1980
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This report has been ^eviewed by the Emission Standards and Engineering Division
of the Office of Air Quality Planning and Standards, EPA, and approved for publication.
Mention of trade names or commercial products is not intended to constitute endorsement
or recommendation for use. Copies of this report are available through the Library
Services Office (MD-35), U. S. Environmental Protection Agency, Research Triangle
Park, N. C. 27711, or from National Technical Information Services, 5285 Port Royal
Road, Springfield, Virginia 22161.
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ENVIRONMENTAL PROTECTION AGENCY
Background Information
and Final
Environmental Impact Statement
for Ammonium Sulfate Manufacture
Prepared by:
Don R. Goodwi
Director, Emission Standards and Engineering Division
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
(Date)
1. The promulgated standards of performance will limit emissions of
part icul ate matter from new, modified, and reconstructed ammonium
sulfate dryers. Section 111 of the Clean Air Act (42 U.S.C. 7411),
as amended, directs the Administrator to establish standards of
performance for any category of new stationary source of air
pollution which ". . . causes or contributes significantly to air
pollution which may reasonably be anticipated to endanger public
health or welfare."
2. Copies of this document have been sent to the following Federal
Departments: Labor, Health and Human Services, Defense,
Transportation, Agriculture, Commerce, Interior, and Energy; the
National Science Foundation; and Council on Environmental Quality;
to members of the State and Territorial Air Pollution Program
Administrators (STAPPA) and the Association of Local Air Pollution
Control Officials (ALAPCO); to EPA Regional Administrators; and
to other interested parties.
3. For additional information contact:
Gene W. Smith
Standards Development Branch (MD-13)
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
telephone: (919) 541-5421
4. Copies of this document may be obtained from:
U.S. EPA Library (MD-35)
Research Triangle Park, NC 27711
National Technical Information Service
5285 Port Royal Road
Springfield, VA 22161
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TABLE OF CONTENTS
Page
1.0 SUMMARY 1-1
1.1 Summary of Changes Since Proposal 1-1
1.2 Summary of Impacts of Promulgated Action 1-1
2.0 SUMMARY OF PUBLIC COMMENTS 2-1
2.1 General 2-1
2.2 Emission Control Technology 2-4
2.3 Test Methods and Monitoring 2-9
2.4 Other Considerations 2-11
2.5 References 2-12
Table 2-1. List of Commenters on the Proposed Standards of
Performance for Ammonium Sulfate Manufacture. . . 2-2
IV
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1.0 SUMMARY
On February 4, 1980, the Environmental Protection Agency (EPA)
proposed standards of performance for ammonium sulfate manufacture (45
FR 7758) under authority of Section 111 of the Clean Air Act, as
amended. Public comments were requested on the proposal in the Federal
Register publication. There were six commenters which included State
air pollution control agencies and representatives of three ammonium
sulfate manufacturing plants. The comments that were submitted, along
with EPA's responses to these comments, are summarized in this document.
The summary of comments and responses serves as the basis for the
revisions made to the standard between proposal and promulgation.
1.1 SUMMARY OF CHANGES SINCE PROPOSAL
Only two minor changes have been made to the proposed regulation.
The indirect method of determining ammonium sulfate production rate
for caprolactam by-product plants using a material balance computation
now consists of an equation based on the combined feed stream leading
directly to the crystallizer. The proposed standard provided an
equation based on the two separate feed streams prior to being combined,
The other change involves a clarification that if a plant uses
weigh scales to directly measure production rate, the use of flow
monitors for the ammonium sulfate feed streams is not required. The
standards as proposed would have required flow monitors even if weigh
scales were provided.
1.2 SUMMARY OF IMPACTS OF PROMUGATED ACTION
1.2.1 Alternatives to Promulgated Action
The regulatory alternatives are discussed in Chapter 6 of the
Background Information Document (BID), Volume I, Ammonium Sulfate
Manufacture-Background Information for Proposed Emission Standards.
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The two options, identified through review of the industry, are based
on emission control techniques representative of two distinct levels
of control. Option I is equivalent to no additional regulatory action.
Option II (the promulgated regulatory limit) is based on the best
demonstrated control technology. These alternatives remain the same;
no new alternatives were identified.
1.2.2 Environmental Impacts of Promulgated Action
The environmental impacts are discussed in Chapter 7 of the BID,
Volume I. Impacts on air pollution, water pollution, solid waste, and
noise are discussed. The impacts remain unchanged. Therefore, the
analysis of environmental impacts in Volume I of the BID now becomes
the final Environmental Impact Statement for the promulgated new
source performance standards.
1.2.3 Energy and Economic Impacts of Promulgated Action
The energy impacts are discussed in the BID, Volume I, Chapter 7.
There are no changes to the estimated impacts. The impacts, therefore,
remain unchanged.
Chapter 8 of the BID, Volume I, discusses economic impacts.
There are no changes to these estimated impacts.
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2.0 SUMMARY OF PUBLIC COMMENTS
The list of conunenters, their affiliations, and the EPA docket
number assigned to each of their comments are shown in Table 2-1.
Six letters commenting on the proposed standard and the BID, Volume I,
for the proposed standard were received. The significant comments
have been combined into the following four categories:
1. General
2. Emission Control Technology
3. Test Methods and Monitoring
4. Miscellaneous
The comments, issues, and their responses are discussed in the
following sections of this chapter. A summary of the changes to the
regulations is included in Section 1.1 of Chapter 1.
2.1 GENERAL
Impact on New Sources
One comment stated that since ammonium sulfate is being used less
frequently as a fertilizer, impact on new sources should be minimal.
Ammonium sulfate is one of the older forms of nitrogen fertilizer
and is still used in significant quantities. However, since 1950 AS's
share of the total nitrogen fertilizer market has declined as other
nitrogen fertilizers have grown more rapidly. Although AS's percentage
of the total nitrogen market will likely continue to decrease, total
production is expected to increase. This increase in tonnage would be
a result of additional by-product material from the steady growth in
caprolactam production.
The production of caprolactam by-product ammonium sulfate, which
represents over half of current production, is expected to increase at
annual rates of 5 to 7 percent through 1985. Increased capacity and
dryer replacement in the caprolactam by-product sector of the industry
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TABLE 2-1. LIST OF COMMENTERS ON THE PROPOSED STANDARDS OF PERFORMANCE
FOR AMMONIUM SULFATE MANUFACTURE
Item Number
in Docket
A-79-31 Comments and Affiliation
IV-C-1 Mr. Steve Small wood
Department of Environmental Regulation
State of Florida
Twin Towers Office Building
2600 Blair Stone Road
Tallahassee, Florida 32301
IV-C-2 Mr. B.M. Beal
NIPRO, Incorporated
Post Office Box 1433
Augusta, Georgia 30903
IV-C-3 Mr. F.L. Piguet
Hopewell Chemical Plant
Allied Chemical
Post Office Box 761
Hopewell, Virginia 23860
IV-C-4 Mr. James F. McAvory
State of Ohio Environmental Protection Agency
Box 1049
361 East Broad Street
Columbus, Ohio 43216
IV-C-5 Mr. Daniel J. Goodwin
Illinois Environmental Protection Agency
2200 Churchill Road
Springfield, Illinois 62706
IV-C-6 Mr. J.F. Cochrane, Director
Environmental Engineering Department
J.R. Simplot Company
P. 0. Box 912
Pocatello, Idaho 83201
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is expected to result in six new ammonium sulfate dryers coming on-line
by 1985. While no new plants are expected to be constructed in the
synthetic and coke oven by-product sectors of the industry, it is
estimated that the replacement of existing process dryers in these
sectors will result in six additional affected facilities by 1985.
Emission Limits for Other Pollutants
It was recommended by one commenter that an emission limit be
established for sulfur dioxide and ammonia through specification of a
modified Method 5 test procedure.
Study of the ammonium sulfate industry has shown that ammonium
sulfate particulate matter is the principal pollutant emitted to the
atmosphere from ammonium sulfate plants. Sulfur dioxide and ammonia
are not emitted from ammonium sulfate plants in amounts significant
enough to warrant regulation. EPA Method 5 provides detailed proce-
dures, equipment criteria, and other considerations necessary to
obtain accurate and representative particulate emission data and is
the appropriate test procedure to measure ammonium sulfate particulate
emissions. EPA Method 5 was used to gather the data which is the
basis for the promulgated standards and is therefore specified as the
method to be used for compliance testing.
New Source Performance Standards for Other Processes
One commenter thought that new source performance standards
(NSPS) should be applied to any new ammonium sulfate dryer regardless
of the manufacturing process used. The commenter referred to one
plant which recovers ammonium sulfate from a scrubber controlling the
emissions from'a sulfuric acid unit at a phosphate fertilizer plant.
The standards regulate new, modified, and reconstructed dryers at
three types of ammonium sulfate manufacturing plants: synthetic,
caprolactam by-product, and coke oven by-product. Over 90 percent of
ammonium sulfate is generated from these types of plants. During
development of the standard, EPA determined that the impact of regulation
and potential for emission reduction with new source performance
standards is significant only within these industry sectors. These
types of plants are the major sources of ammonium sulfate emissions.
Only two plants in the U.S. are known to produce ammonium sulfate as a
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by-product of sulfuric acid manufacture using the Cominco-Swenson
process; the trend in this industry is toward using the dual absorption
process of manufacturing sulfuric acid which eliminates the output of
ammonium sulfate. Since there does not appear to be any growth or
replacement potential for plants using the Cominco-Swenson process
(this segment is in fact contracting), there is no justification to
include this process in the standard.
Ammonium sulfate is also a by-product of the manufacture of
nickel from ore concentrates and the manufacture of methyl methacrylate
at one existing facility. However, no new plants of either type are
expected to be built. Furthermore, new technology for-the manufacture
of methyl methacrylate now being put in use at existing plants eliminates
the production of ammonium sulfate altogether.
2.2 EMISSION CONTROL TECHNOLOGY
Specification of Control Equipment
One commenter suggested that the proposed standard be "equipment
specific" requiring the use of venturi scrubbers. However, Section lll(h)
of the Clean Air Act establishes a presumption against design, equipment,
work practice, and operational standards. Such standards cannot be
promulgated if a standard of performance is feasible. (Feasibility is
defined in Section lll(h)(2) of the Act.) Performance standards for
control of ammonium sulfate particulate emissions have been determined
as practical and feasible; therefore, design, equipment, work practice,
or operational standards are not considered as regulatory options.
Use of Fabric Filters to Meet Proposed Standards
Two comments were received which questioned the feasibility of
utilizing fabric filters for the collection of particulate emissions
at ammonium sulfate plants. Both commenters noted the fact that
frequent and serious operational problems can occur with the use of
fabric filter systems at ammonium sulfate plants. One commenter, a
synthetic ammonium sulfate producer, pointed out that his company's
efforts to utilize a baghouse were totally unsuccessful. The plant
discontinued use of the fabric filter system because excessive blinding*
*The embedded material blinds or plugs the fabric pore to such an
'-- 'tent, that fabric resistance becomes permanently excessively high
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of the fabric and caking of the collected dust in the baghouse, bins,
and discharge chutes occurred which required frequent plant shutdown
(an operating pattern considered entirely unacceptable at large scale,
continuous process ammonium sulfate plants).
The condensation which causes the blinding and caking results
from failure to maintain the temperature of the dryer exhaust and/or
baghouse surfaces sufficiently above the dew point at all times. The
commenter noted that the presence of even low level sulfuric acid (or
hydrocarbon) vapor effectively results in a gaseous mixture that has a
dew point considerably higher than would be predicted solely on the
basis of the moisture content. (This dew point elevation can exceed
200°F.)
EPA feels that this is a reasonable comment. Volume I of the BID
and the preamble to the proposed standards contain information and
data regarding the use of fabric filters for ammonium sulfate particulate
control. Emission data include test results from the one fabric
filter system presently in use in the ammonium sulfate industry. This
control system was tested by EPA because it represents a unique application
of this control method in the ammonium sulfate industry. From
consideration of the emission test results, EPA judged that fabric
filtration had the potential to reduce ammonium sulfate particulate
emissions to the level required by the standards.
The baghouse used for particulate control at the synthetic ammonium
sulfate plant was, however, not considered representative of normal
fabric filter system operation. The baghouse in use was originally
designed for another application but was applied to the ammonium
sulfate plant in an effort to cut cost, since it was already in place
at the site. The plant operates only intermittently and reported
frequent operational problems associated with the use of the fabric
filter system. EPA assumed that normal operation of a baghouse for
ammonium sulfate particulate collection should be feasible (i.e., at
temperatures above the dew point of the exhaust gas), albeit fabric
filtration had not been demonstrated for the operational conditions
encountered at a typical plant in the ammonium sulfate industry.
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Industry personnel have previously stated that the large quantity
of collected material (as high as 220 Ibs of particulate matter per
ton of ammonium sulfate produced) would create material handling
problems associated with recycling the ammonium sulfate particul ate
o
collected by a fabric filter. This is especially relevant when
caking of the collected dust causes buildup in the baghouse, bins, and
discharge chutes. Wet scrubbing, on the other hand, is more suitable
for application to ammonium sulfate dryers. In wet scrubbing, ammonium
sulfate process streams are used as the scrubbing liquor; this allows
the collected ammonium sulfate (in solution) to be easily recycled to
the process.
Capital and operating cost as well as energy requirements are
also significantly higher for baghouses than for medium energy wet
scrubbers of the same construction material. For example, the invest-
ment cost of a medium size caprolactam by-product ammonium sulfate
plant is approximately $800,000 for fabric filters, compared to $150,000
for venturi scrubbers.
For the purpose of calculating environmental, economic, and
energy impacts, EPA assumed that because of the relative advantages of
wet scrubbing all facilites coming on-line by 1985 would elect to
install wet scrubbers to meet the standards. EPA maintained that
fabric filtration also had the potential to meet the proposed standards
although their use has not been demonstrated in the industry.
With the additional information gained from investigation of the
comments submitted on operational experience with fabric filtration at
ammonium sulfate plants, there is now adequate evidence to conclude
that fabric filtration is not a viable control alternative applicable
to particulate collection at ammonium sulfate plants. Normal operation
of a baghouse no longer appears feasible. This conclusion, however,
does not affect the numerical emission limits proposed for ammonium
sulfate dryer new source performance standards. The level of control
in the proposed regulation was based on the use of a medium energy wet
scrubber and represents the most stringent control level that can be
met by all segments of the industry. Therefore, no change has been
made in the numerical emission limit.
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Fabric Filter Efficiency
One commenter reported that the efficiency as calculated from EPA
test results appears to be in error. The commenter also stated that
the 99.9 percent control efficiency for fabric filters cannot be
relied upon for normal operating conditions at ammonium sulfate plants
and that, although a control efficiency of 99.9 percent may be achieved,
it cannot be sustained on a continuous basis during normal operating
conditions.
Page C-10, Appendix C, of the BID, Volume 1, contains the reported
efficiency calculated from EPA emission tests. Footnote "a" on that
page outlines the efficiency calculation. A review of the calculation
shows that the reported value of 98.7 percent is correct. That portion
of the comment dealing with the operation of fabric filters is referred
to in the preceding comments dealing with overall fabric filter
feasibility.
Volatile Organic Compound Emissions At Caprolactam By-Product Plants
Two commenters were concerned with the effect of using fabric
filters on volatile organic compound (VOC) emissions at caprolactam
by-product ammonium sulfate plants. Both contended that although the
use of fabric filters would reduce particulate emissions, VOC emissions
would increase because a fabric filter would capture very little, if
any, of the VOC which would be captured by a wet collection method.
Caprolactam is introduced into the ammonium sulfate process from
those streams which, in the caprolactum formation reactions, produce
ammonium sulfate as a by-product. Caprolactam, (CH2)5 COHN, has a
melting point of 60°C and a boiling point of 140°C. This means that
the majority of caprolactam present in the ammonium sulfate dryer at
the operating temperature involved (about 85°C) is in the liquid
phase. The liquid caprolactam in the dryer adheres to the ammonium
sulfate crystals and passes through the drying and classifying process.
This residual caprolactam is a solid at ambient storage conditions.
Any volatile caprolactam present in the ammonium sulfate dryer (and
exit gas) results from the vapor pressure of caprolactam at the operating
temperature of the dryer. EPA test data indicate that uncontrolled
volatilized caprolactam emissions are relatively low level: at least
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two orders of magnitute lower than uncontrolled ammonium sulfate
particulate emissions (110 kg/Mg for particulate matter versus 0.78 kg/Mg
for caprolactam emissions). In addition, wet collection currently in
use as particulate control has demonstrated nearly 90 percent removal
of efficiency of the uncontrolled caprolactam emissions.
Furthermore, as pointed out in the previous comment concerning
fabric filters, there is now adequate evidence to conclude that fabric
filtration will not be selected to control particulate emissions from
ammonium sulfate plants. For this reason it is concluded that VOC
emissions will not increase as a result of baghouse use.
Control Equipment Efficiency and Process Variations
One commenter stated it is doubtful that either the venturi
scrubber or fabric filter will be able to sustain 99.9 percent efficiency
during all variations associated with normal operating conditions at
ammonium sulfate plants. The commenter went on to say that EPA has
repeatedly failed to consider variations associated with processes,
control devices, testing equipment, and laboratory procedures and that
EPA has failed to recognize the wide variations obtained from the same
plant and pollution control system, as measured by EPA methods, during
representative operating conditions.
The new source performance standards for this industry are not
based on percent removal efficiency but on the performance level of
the best system of continuous emission reduction considering cost and
other factors. The percent efficiencies were provided for information
purposes only. EPA determined the performance level through direct
emission testing at a number of ammonium sulfate plants. To adequately
consider all commonly occurring process and emission control variations
found in the industry, EPA selected several plants for emission testing.
The plants tested used the various drying techniques and gas-to-product
ratios currently found in the industry and likely to be used in the
future. For instance, both fluidized bed and rotary drum dryers were
tested utilizing both direct-fired and steam heated air as the drying
medium. Each emission test consisted of three separate test runs
conducted during normal or representative operating conditions utilizing
EPA Method 5. In the future, performance tests for determination of
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source compliance will be conducted using procedures similar to those
used in development of the promulgated standards. Emission test
results from these different drying techniques indicate that the
performance levels selected for the standards can be met by all segments
of the ammonium sulfate industry.
2.3 TEST METHODS AND MONITORING
Use of Weigh Scales and Flow Monitors
One commenter suggested that §60.423(a) of the proposed standards,
Monitoring of Operations, be changed to provide consistency with
§60.424(d) which states that production rate may be determined by use
of product weigh scales, or by material balance calculations. As
proposed, §60.423(a) of the regulation would have required installation
of process feed stream flow meters, even if weigh scales were used to
measure production rate.
This is a reasonable comment. The emission limit of the regulation
is expressed in allowable emissions per unit mass of product. Therefore,
production rate must be determinable. Flow meters were required in an
effort to provide a means to accurately determine the production rate
at those facilities electing not to install weigh scales. It is not
EPA's intention that owners or operators of affected facilities who
elect to install weigh scales should also be required to install
process stream flow monitors. The regulation has therefore been
changed to note that if a plant uses weigh scales, then flow monitors
are not required.
Pressure Drop Monitoring
One commenter requested that instead of continuous monitoring of
pressure drop, periodic monitoring of pressure drop across the control
system for any affected facility be allowed. It was suggested that
the pressure drop across the control system should be taken by operating
personnel at a frequency no greater than once every 2 hours and entered
in an operator log. It was contended that the reliability of venturi
scrubbers is such that more frequent measurements or continuous pressure
drop monitors could not be justified and would be a waste of both
capital and energy. It was stated that imposing more costly or
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time-consuming monitoring requirements than is necessary to adequately
demonstrate emission compliance will, in the long run, be
counterproductive.
In EPA's experience, continuous pressure drop monitoring provides
a more accurate indication of emission control equipment operation and
maintenance than periodic or intermittent readings and thereby facilitates
enforcement activities. It has also been determined that the costs
of continuous pressure drop monitoring at ammonium sulfate plants are
reasonable, and that there are no technical or process reasons to
monitor periodically. Therefore, no change in the pressure drop
monitoring requirements of the proposed regulation was made.
Flow Monitoring Requirements
One commenter noted that for caprolactam by-product plants the
ammonium sulfate feed streams which require flow monitoring devices
for determination of mass product flow are, in some cases, inappro-
priate. It was pointed out that not all ammonium sulfate solution
produced is taken to the solid form; some is sold as solution.
Therefore, the total combined feed streams to the ammonium sulfate
crystallizer, prior to any recycle streams, would be the most accurate
place to measure process input feed.
This is considered a reasonable comment. For those caprolactam
by-product ammonium sulfate plants not equipped with product weight
scales, the proposed standards would have required that the oximation
ammonium sulfate stream to the ammonium sulfate plant and the oleum
stream to the caprolactam rearrangement reactor must be monitored
separately as a means of determining the ammonium sulfate production
rate. It did not specify that the total combined feed stream leading
directly to the crystallizer stage can also be monitored. Therefore,
in response to this comment, §60.424(d) has been changed to specify
monitoring of the total or combined feed streams leading directly to
the crystallizer stage for caprolactam by-product plants. A new
equation has been developed for §60.424(d) to allow calculation of
ammonium sulfate production rate from the flow rate of the total feed
stream.
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Flow Monitoring Accuracy
One commenter recommended that flow monitoring equipment be
specified as ±10 percent and not ±5 percent as specified in the proposed
standard. However, an accuracy of ±5 is considered to be practicably
achievable. Equipment with this accuracy is available. Therefore, no
change was made.
Opacity Standard
Another commenter contended that visual opacity measurement is
unscientific, inaccurate, and, at best, arbitrary. It was suggested
that the proposed opacity standard is unnecessary to adequately monitor
ammonium sulfate manufacturing emissions; and since there is no reliable
method for its measurement, the opacity standard should be deleted.
An opacity standard of 15 percent was proposed for all affected
facilities to ensure proper operation and maintenance of control
systems on a day-to-day basis. The proposed method for opacity moni-
toring is EPA Method 9. The reliability of opacity standards and the
reference test method has been rigorously tested in the field and in
4 5
the courts. * In the case of Portland Cement Association versus
Russel E. Train, EPA Administrator, 513 F.2d 506 (D.C. Cir. 1975), the
court ruled that plume opacity was not too unreliable to be used
either as a measure of pollution or as an aid in controlling emissions.
As a basis for the standard, ammonium sulfate dryers were observed to
have no opacity readings greater than 15 percent opacity during
observation periods totalling more than 19 hours. Therefore, no
change was made in the opacity standard.
2.4 OTHER CONSIDERATIONS
Medical Evidence
One commenter could not find justification for proposing a standard
for modified and new sources that is more stringent than the baseline
emission level of existing SIP. It was contended that since there was
no medical evidence presented showing any harm being created by ammonium
sulfate dryer emissions allowed under existing State regulations,
there is no justification for standards requiring additional investment
and energy.
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On August 21, 1979, ammonium sulfate manufacturing was listed
under Section lll(f) of the Clean Air Act as a stationary source
category for which standards should be promulgated (44 FR 4922). This
listing represents the Administrator's determination that based on a
preliminary assessment of the industry ammonium sulfate manufacturing
causes, or contributes significantly to, air pollution which may
reasonably be anticipated to endanger public health or welfare.
Under Section lll(a), any standards which are promulgated for
source category must reflect the degree of emission control achievable
through application of the best demonstrated technological system of
continuous emission reduction which (taking into consideration the
cost of achieving such emission reduction, any non-air quality health,
and environmental and energy impacts) has been adequately demonstrated.
Based on a thorough study of control alternatives, including no additional
regulatory action, EPA has determined that the promulgated emission
limits best satisfy these criteria for ammonium sulfate manufacture.
Furthermore particulate matter, the principal pollutant emitted
to the atmosphere from ammonium sulfate plants, is a criteria pollutant
(listed as such under Section 108 of the Clean Air Act) for which
national ambient air quality standards have been established. Specific
information regarding the health and welfare effects of particulate
matter in the atmosphere was provided in association with the listing
of particulate matter as a criteria pollutant.
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2.5 REFERENCES
1. Comment on Ammonium Sulfate BID by Mr. Thomas A. Blue, Manager
of SRI's Agricultural Chemicals Business Studies Group. Contained
in Mrs. B.J. Johnson's May 7, 1979, letter to S.T. Cuffe, EPA/I SB.
2. Telephone conversation between R. Zerbonia, PES, Incorporated,
and R. Ray, Badische Corporation. April 19, 1979.
3. Telephone conversation between R. Zerbonia, PES, Incorporated,
and R. Myers, EPA/DSSE, Washington, D.C., April 9, 1980.
4. EPA Response to Remand Ordered by U.S. Court of Appeals for
the District of Columbia in Portland Cement Association vs.
Ruckelhaus. EPA-450/2-74-023. November 1974.
5. Guidelines for Evaluation of Visible Emissions. EPA-340/1-75-007.
April 1975.
6. Air Quality Criteria for Particulate Matter. National Air
Pollution Control Administration.Publication No. AP-49.
January 1969.
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; _:H" >CAL REPORT DATA
c rcaa Instructions on .'..<; 'i rcrsi t^-fore complex
1. REPORT NO.
EPA-45Q/3-79-Q34b
4. TITLE AND SUBTITLE
Ammonium Sulfate Manufacture - Background
Information for Promulgated Emission Standards
3 RECIPIENT'S ACCESSION NO.
5. REPORT DATE
October 1980
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Office of Air Quality Planning and Standards
Environmental Protection Agency
Research Triangle Park, North Carolina 27711
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-02-3061
12. SPONSORING AGENCY NAME AND ADDRESS
DAA for Air Quality Planning and Standards
Office of Air, Noise, and Radiation
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
EPA/200/04
15. SUPPLEMENTARY NOTES volume 1 discussed the proposed standards and the resulting environ-
mental and economic effects. Volume II contains a summary of public comments, EPA re-
sponses and a discussion of difference between the proposed and promulgated standards.
16. ABSTRACT
Standards of performance for the control of emissions from ammonium sulfate
manufacture plants in the U.S. are being promulgated under Section 111 of
the Clean Air Act. The standards apply to new, modified, or reconstructed
facilities at caprolactam by-product, synthetic and coke oven by-product
ammonium sulfate manufacturing plants.
17.
KEY WORDS AND DOCUMENT ANALYSIS
a.
DESCRIPTORS
Air pollution
Pollution control
Standards of performance
Ammonium Sulfate
Caprolactam by-product plants
Fertilizer
b.lDENTIFIERS/OPEN ENDED TERMS
Air Pollution Control
{18. O'STRI&ijTIO'-' STATE. MFNT
: 19 CFC JR, 7 Y CLASS (ThL f.-t,
' Unclassified
c. COSATI Field/Group
13 B
21. NO. OF PAGES
J7
;2 PRICE
Unclassified
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